J.5 - BIEN HOA THERMAL STUDY FINAL REPORT (KEMRON).pdf

BIEN HOA AIRBASE THERMAL STUDY

FINAL REPORT

KEMRON PROJECT #: SH0738

July 1, 2020

Prepared for:

Prepared by:

1359-A Ellsworth Industrial Blvd

Atlanta, GA 30318 404-636-0928 (Phone)

404-636-7162 (Fax)

Submitted By: Reviewed By:

Mark Clark Tomecia Bradley Technical Manager Program Manager

Data contained on this sheet shall not be disclosed without prior approval from KEMRON Environmental Services, Inc. (Proprietary)

Bien Hoa Airbase Thermal Study Draft Final Report SH0738 Cardno GS July 1, 2020 i

Table of Contents

1.0 INTRODUCTION

2.0 TEST SAMPLES

2.1 Sample Receipt and Handling

3.0 UNTREATED MATERIAL CHARACTERIZATION

4.0 THERMAL TREATMENT TESTING

4.1 BH-PI-2-T-COMP 7-Day Thermal

4.1.1 BH-PI-2-T-COMP 7-Day Thermal Analytical Results

4.2 BH-PI-2-T-COMP 14-Day Thermal

4.2.1 BH-PI-2-T-COMP 14-Day Thermal Analytical Results

4.3 Additional Testing For Off-Gas VOC Evaluations

5.0 CONCLUSIONS

FIGURES

Figure 1 – 335C Temperature Graph @ 7-Day Treatment Figure 2 – 335C Temperature Graph @ 14-Day Treatment Figure 3 – 670C Temperature Graph

TABLES

Table 1 Untreated Physical Characterization

Table 2 Untreated Analytical Characterization – Total VOC, TPH, Arsenic

Table 3 Untreated Analytical Characterization – Total SVOC Table 4 Untreated Analytical Characterization – Dioxins and Furans Table 5 Treated Material Characterization – Condensate Table 6 Treated Material Characterization – 335C Off Gas VOC Table 7 Treated Material Characterization – 335C Off Gas SVOC Table 8 Treated Material Characterization – 335C Off Gas Dixions Table 9 Treated Material Characterization – Soil (VOC, TPH, Arsenic) Table 10 Treated Material Characterization – Soil (SVOC) Table 11 Treated Material Characterization – Soil (Dioxins & Furans) Table 12 Summary of Testing Parameters Table 13 Treated Analytical Characterization – 670C Off Gas VOC

APPENDICES

APPENDIX A Material Chain of Custody APPENDIX B Untreated Physical Properties Testing Data Sheets APPENDIX C Untreated Material Analytical Reports APPENDIX D Thermal Treatment Data Sheets APPENDIX E Treated Analytical Characterization Reports – 7-Day Treatment APPENDIX F Treated Analytical Characterization Reports – 14-Day Treatment APPENDIX G Treated Analytical Characterization Reports – 670C Treatment

1.0 INTRODUCTION

The Bien Hoa Airbase Thermal Treatability Study, as outlined in this final report, has been developed to present the results of bench-scale testing performed to date on materials from the Bien Hoa Airbase Site, located in Vietnam. The treatability study was performed based on information provided by Cardno GS (Cardno) and in general accordance with the Statement of Work (SOW) developed by KEMRON, and subsequent conversations with Cardno. The objectives of the study were to:

1. Quantify concentrations of dioxins/furans, VOCs, SVOCs, Gasoline Range

Organics (GRO), Diesel Range Organics (DRO), and arsenic present in two untreated as-received soil samples received from the site. Additionally, a composite test soil was developed by compositing the two as-received site materials and analyzed for dioxins/furans, VOCs, SVOCs, Gasoline Range

Organics (GRO), Diesel Range Organics (DRO), and arsenic;

2. Evaluate the composition of off-gas collected during heating (information will be used to select and design the vapor treatment system);

3. Evaluate the composition of condensate collected from the testing (information will be used to select and design the liquid treatment system);

The following sections of this final report present information regarding the tasks and protocols followed in performing the treatability study to date. All testing conducted during this study was performed by KEMRON Environmental Services, Inc., located in Atlanta, Georgia, and subcontract laboratories selected by KEMRON and Cardno based on their ability to perform the analytical and specialized testing performed in the study.

2.0 TEST SAMPLES

The following test samples were collected by Cardno and shipped to KEMRON’s Atlanta, GA laboratory for testing. All samples were forwarded under proper chain of custody, and in compliance with KEMRON’s Foreign Soils Permit.

Materials provided for the study included:

BH-PI-2-T-0-30

BH-PI-2-T-90-120

Copies of the Material Chain of Custody are included in Appendix A of this report.

2.1 Sample Receipt and Handling

Upon receipt by KEMRON, the untreated site materials were photographed, logged into a sample-tracking database and placed into refrigerated secure storage (maintained at a temperature of 4ºC ± 2ºC).

Prior to testing, each sample material was homogenized to obtain a uniform material.

Homogenization of the site test materials was conducted by placing the contents of each shipping container into a large mixing bin. The test material was then gently mixed by hand using stainless steel utensils. Any large or agglomerated particles were then broken into sizes that are more manageable or removed from the test material if the diameter was greater than 0.5 inches. Any free liquids present in the site material, at this stage of homogenization, were re-incorporated in the test materials during homogenization.

The establishment of the baseline level of constituents of concern (COCs) is important for comparing and determining the effectiveness of the various treatment processes evaluated. The analyses also allow verification that the samples are representative and consistent with conditions anticipated during full-scale activities.

Note that all homogenization activities were conducted on the chilled materials in order to reduce potential volatilization of COCs. KEMRON understands that some volatilization of contaminants may have occurred during homogenization activities. However, due to the small quantities of site materials that were utilized for bench-scale treatment simulations, and analytical evaluations, thorough homogenization of the site samples is critical for accurate and meaningful results. As such, KEMRON believes that proper homogenization outweighs the risk of potential contaminant loss during the homogenization activities.

KEMRON performed characterization testing on the as-received untreated materials as outlined in the initial SOW. The following is a summary of physical properties testing performed on the untreated site materials:

Parameter Method

Particle Size Distribution ASTM D422

Soil Classification ASTM D2487

Moisture Content ASTM D2216

Loss on Ignition (organic content) ASTM D2974 Modified

Bulk Density ASTM D7263

Solid Specific Gravity ASTM D854

Porosity ASTM D7263

Additionally, aliquots of each as-received untreated material were forwarded to Eurofins

Test America, in Chicago, Illinois, for analytical characterization testing. The following outlines the chemical testing parameters performed on the untreated materials:

Total Volatile Organic Compounds (VOCs) EPA Method 8260B

Total Semivolatile Compounds (SVOCs) EPA Method 8270

Total Gasoline Range Organics (GRO) EPA Method 8015C

Total Diesel Range Organics (DRO) EPA Method 8015D

Total Arsenic EPA Method 6010C

Total Dioxins/Furans EPA Method 8290A

In addition to the physical properties testing of the as-received site materials, KEMRON prepared a single untreated composite soil for use in the thermal simulations testing. This composite material was prepared by combining the two as-received site soils into a single mixing bin and then thoroughly blending the soils until visually homogenous. This composite soil was then labeled as BH-PI-2-T-Comp and placed into refrigerated storage.

Prior to conducting any thermal simulation testing, KEMRON removed two large aliquots of the Composite soil from the storage containers for use in three thermal simulations.

These samples were labeled BH-PI-2-T-Comp (7 day), and BH-PI-2-T-Comp (14 day) and

BH-PI-2-T-Comp (670°C). These separated materials were then re-homogenized separately. BH-PI-2-T-Comp (7 day) and BH-PI-2-T-Comp (14 day) were then sampled for the previously outlined physical and chemical properties testing.

3.0 UNTREATED MATERIAL CHARACTERIZATION

The results of all untreated material characterization testing performed on the original as-received site soils and the Composite soil materials are presented in Tables 1 through 4.

Laboratory data sheets for all physical characterization testing are included in Appendix

B. Complete reports for the analytical characterization is included in Appendix C.

Review of the physical properties testing results in Table 1 show that the grain-size distribution of the two as-received site materials were very similar and described as Clayey

Silty Sands with an SC/SM soil classification. The as-received soil sampled from the top

0-30 centimeters of the site exhibited a noticeable higher moisture content than the lower

90-120 centimeters sample. Additionally, the density and porosity values of the two materials varied. The testing results of the two Composite samples, representing duplicate samples, showed that the preparation and blending of the Composite soil produced very similar materials.

Table 1 - Untreated Physical Characterization.xlsx Page 1 of 1 Applied Technologies Group

KEMRON Environmental Services, Inc.

BH-PI-2-T-0-30 BH-PI-2-T-90-120 BH-PI-2-T-Comp (7 day) BH-PI-2-T-Comp (14 day) Particle Size Distribution ASTM D422 Gravel (<1/2") % 8.8 5.9 2.4 8.8 Sand % 48.9 45.7 51.6 48.9 Silt % 19.7 20.8 20.0 18.4 Clay % 22.6 27.6 26.0 23.9

Sample Description (1) ASTM D2487 Dark Yellowish Brown Clayey Silty

Sand Dark Yellowish Brown Clayey Silty

Sand Dark Yellowish Brown Clayey Silty

Sand Dark Yellowish Brown Clayey Silty

Sand

Sample Classification (2) ASTM D2487 SC/SM SC/SM SC/SM SC/SM

Solid Specific Gravity ASTM D854 2.63 2.53 2.51 2.58

Moisture Content ASTM D2216 Average ASTM Moisture Content % 33.64 23.18 27.84 26.78 Average Percent Solids % 74.83 81.18 78.22 78.87

Loss on Ignition ASTM D2974 Average Moisture Content @ 60°C % 32.31 23.14 25.87 26.17 Average Moisture Content @ 100°C % 32.77 23.45 26.16 26.42 Average Loss on Ignition @ 200°C % 0.61 0.39 0.51 0.54 Average Loss on Ignition @ 325°C % 1.77 0.99 1.25 1.43 Average Loss on Ignition @ 440°C % 3.43 1.71 1.87 2.61 Average Loss on Ignition @ 750°C % 6.58 6.44 2.39 3.44

Porosity Calculated % 46.4 36.1 39.2 40.0

Unit Weight ASTM D7263 Average Bulk Unit Weight pcf 117.3 124.4 121.5 122.4

Notes:

(1) Sample color determined by the Munsell Soil Color Charts.

(2) Sample classification based on the Unified Classification System.

Sample description and classification is based on visual classification where Atterberg limits were not performed %= Percent pcf = pounds per cubic foot

Untreated Material Testing Parameter Test Method Unit

CARDNO GS, INC.

BIEN HOA AIRBASE THERMAL STUDY

KEMRON PROJECT No. SH0738

TABLE 1

Untreated Material Characterization

At the request of Cardno, KEMRON performed the Loss on Ignition (LOI) organic content testing using a modified method developed for this study. Specifically, because of anticipated presence of petroleum products, as well as potential solvent type chemicals, KEMRON performed LOI/ ASH testing using numerous testing temperatures. The initial moisture content testing was performed at temperatures of both 60 and 100 degrees

Celsius (°C). The results of the initial moisture content testing indicates that the majority of the natural moisture was removed at the 60°C testing temperature. The initial moisture content testing shows that the LOI and Moisture content testing samples were very similar.

As outlined in the ASTM moisture content method, the samples were heated at each temperature until a constant weight was achieved. The organic material loss shows that the shallower 0-30 centimeters as-received sample contained slightly higher organic material loss at each temperature. The LOI results are also presented in Table 1.

Table 2 is a presentation of the results of Total Volatile Organic Compound (VOCs), Total

Gasoline Range Organics (GRO), Total Diesel Range Organics (DRO) and Total Arsenic analyses performed on the two as-received soils as well as the duplicate composite sample.

Review of Table 2 shows that Acetone was the only VOC detected in the untreated samples. The Acetone analyses were performed at a 1X dilution for the as-received BH-

PI-2-T-0-30, and BH-PI-2-T-90-120 samples with concentrations of 81.2 and 83.1 micrograms per kilogram (µg/Kg) respectively. However, Acetone was analyzed using a

50X dilution in the untreated 7-day and 14-day duplicate composite soils. The results of

Acetone for these soils using a 50X dilution showed estimated results of 356 µg/Kg in the

7-day soil and 374 µg/Kg in the untreated 14-day sample. These results were qualified with a “J” flag indicating that the results are estimated and between the analytical Method

Detection Limit (MDL) and the analytical Reporting Limit (RL). Additional analyses presented in Table 2 indicates that no Gasoline Range Organics were detected in any of the samples. DRO analyses indicate detected values ranging from 17.2 to 25.4 milligrams per kilogram (mg/Kg) showing some variation between the four samples. Total Arsenic results ranged from 6.4 to 10.1 mg/Kg, also showing slight variability.

Table 3 summarizes the results of Total SVOC analyses conducted on the four test materials. The results indicate that no SVOCs were detected above the analytical MDLs.

Table 4 presents the results of total Dioxin/Furan analyses performed on the four untreated soil materials. Review of Table 4 shows that numerous Dioxins/Furans were detected in all of the test samples. Compounds detected at the highest concentrations included Total TCDD, 2,3,7,8-TCDD, OCDD, and Total HpCDF. Note that the results of

Dioxins/Furans analyses shows some variability between the four soil materials.

Result Qual. MDL Result Qual. MDL Result Qual. MDL Result Qual. MDL

1,1,1-Trichloroethane µg/Kg ND 0.551 ND 0.670 ND 0.360 ND 0.354 1,1,2,2-Tetrachloroethane µg/Kg ND 0.525 ND 0.638 ND 0.343 ND 0.337 1,1,2-Trichloro-1,2,2-trifluoroethane µg/Kg ND 0.741 ND 0.900 ND 0.483 ND 0.476 1,1,2-Trichloroethane µg/Kg ND 0.705 ND 0.856 ND 0.460 ND 0.453 1,1-Dichloroethane µg/Kg ND 0.563 ND 0.684 ND 0.367 ND 0.362 1,1-Dichloroethene µg/Kg ND 0.565 ND 0.687 ND 0.369 ND 0.363 1,2,4-Trichlorobenzene µg/Kg ND 0.592 ND 0.719 ND 0.386 ND * 0.380 1,2-Dibromo-3-Chloropropane µg/Kg ND 1.65 ND 2.01 ND 1.08 ND 1.06 1,2-Dibromoethane µg/Kg ND 0.628 ND 0.763 ND 0.410 ND 0.403 1,2-Dichlorobenzene µg/Kg ND 0.611 ND 0.743 ND 0.399 ND 0.393 1,2-Dichloroethane µg/Kg ND 1.28 ND 1.56 ND 0.836 ND 0.824 1,2-Dichloropropane µg/Kg ND 0.425 ND 0.516 ND 0.277 ND 0.273 1,3-Dichlorobenzene µg/Kg ND 0.597 ND 0.726 ND 0.390 ND 0.384 1,4-Dichlorobenzene µg/Kg ND 0.629 ND 0.765 ND 0.411 ND 0.404 2-Hexanone µg/Kg ND 1.28 ND 1.56 ND 0.836 ND 0.824 Acetone µg/Kg 81.2 7.16 83.1 8.69 356 J 138 374 J 117 Benzene µg/Kg ND 0.419 ND 0.509 ND 0.273 ND 0.269 Bromodichloromethane µg/Kg ND 0.334 ND 0.406 ND 0.218 ND 0.215 Bromoform µg/Kg ND 0.480 ND 0.583 ND 0.313 ND 0.308 Bromomethane µg/Kg ND 1.55 ND 1.89 ND 1.01 ND 0.998 Carbon disulfide µg/Kg ND 0.855 ND 1.04 ND 0.557 ND 0.549 Carbon tetrachloride µg/Kg ND 0.477 ND 0.579 ND 0.311 ND 0.306 Chlorobenzene µg/Kg ND 0.606 ND 0.737 ND 0.396 ND 0.390 Chloroethane µg/Kg ND * 1.22 ND * 1.48 ND * 0.793 ND * 0.781 Chloroform µg/Kg ND 0.570 ND 0.693 ND 0.372 ND 0.366 Chloromethane µg/Kg ND 1.65 ND 2.01 ND 1.08 ND 1.06 cis-1,2-Dichloroethene µg/Kg ND 0.459 ND 0.558 ND 0.300 ND 0.295 cis-1,3-Dichloropropene µg/Kg ND 0.495 ND 0.602 ND 0.323 ND 0.318 Cyclohexane µg/Kg ND 0.635 ND 0.771 ND 0.414 ND 0.408 Dibromochloromethane µg/Kg ND 0.537 ND 0.653 ND 0.351 ND 0.345 Dichlorodifluoromethane µg/Kg ND * 0.970 ND * 1.18 ND * 0.632 ND 0.623 Ethylbenzene µg/Kg ND 0.786 ND 0.955 ND 0.513 ND 0.505 Isopropylbenzene µg/Kg ND 0.592 ND 0.719 ND 0.386 ND 0.380 Methyl acetate µg/Kg ND 5.43 ND 6.60 ND 3.54 ND 3.49 Methyl Ethyl Ketone µg/Kg ND 1.82 ND 2.22 ND 1.19 ND 1.17 methyl isobutyl ketone µg/Kg ND 1.22 ND 1.48 ND 0.793 ND 0.781 Methyl tert-butyl ether µg/Kg ND 0.482 ND 0.586 ND 0.315 ND 0.310 Methylcyclohexane µg/Kg ND 0.566 ND 0.688 ND 0.369 ND 0.364 Methylene Chloride µg/Kg ND 1.62 ND 1.97 ND 1.06 ND 1.04 Styrene µg/Kg ND 0.496 ND 0.603 ND 0.324 ND 0.319 Tetrachloroethene µg/Kg ND 0.560 ND 0.680 ND 0.365 ND 0.360 Toluene µg/Kg ND 0.415 ND 0.504 ND 0.271 ND 0.267 trans-1,2-Dichloroethene µg/Kg ND 0.728 ND 0.884 ND 0.475 ND 0.468 trans-1,3-Dichloropropene µg/Kg ND 0.577 ND 0.701 ND 0.376 ND 0.371 Trichloroethene µg/Kg ND 0.555 ND 0.675 ND 0.362 ND 0.357 Trichlorofluoromethane µg/Kg ND 1.66 ND 2.02 ND 1.08 ND 1.07 Vinyl chloride µg/Kg ND 0.727 ND 0.883 ND 0.474 ND 0.467 Xylenes, Total µg/Kg ND 0.526 ND 0.639 ND 0.343 ND 0.338

Gasoline Range Organics (C6-C9) µg/Kg ND 690 ND 580 ND 797 ND 678

DRO (C10-C28) mg/Kg 21.1 4.05 22.9 3.95 17.2 3.87 25.4 3.85

Arsenic mg/Kg 10.1 0.403 6.64 0.383 7.07 0.408 7.48 0.385

Notes:

µg/Kg = microgram per kilogram mg/Kg = milligram per kilogram MDL = Method Detection Limit ND = Not Detected J = Result is less than the Reporting Limit (RL) but greater than or equal to the MDL and the concentration is an approximate value

* = Relative percent difference (RPD) of the laboratory control sample (LCS) and laboratory control sample duplicate (LCSD) exceeds the control limits

Total VOC, THP, GRO, DRO & Metals

Gasoline Range Organics (GRO) 8015C

Diesel Range Organics (DRO) 8015D

Metals 6010C

CARDNO-GS, INC.

BIEN HOA AIRBASE THERMAL STUDY

PROJECT No. SH0738

TABLE 2

Untreated Analytical Characterization

Volatile Organic Compounds (VOC) 8260B

Parameters Units BH-PI-2-T-0-30 BH-PI-2-T-90-120 BH-PI-2-T-COMP (7 day) BH-PI-2-T-COMP (14 day)

Table 3 - Untreated Analytical Characterization - Total SVOC.xlsx 1 of 1

KEMRON Environmental Services, INC

Result Qual. MDL Result Qual. MDL Result Qual. MDL Result Qual. MDL

1,1'-Biphenyl µg/Kg ND 53.6 ND 48.4 ND 48.8 ND 49.7 2,2'-oxybis[1-chloropropane] µg/Kg ND 51.3 ND 46.4 ND 46.7 ND 47.6 2,4,5-Trichlorophenol µg/Kg ND 101 ND 91.3 ND 92.0 ND 93.7 2,4,6-Trichlorophenol µg/Kg ND 152 ND 137 ND 138 ND 141 2,4-Dichlorophenol µg/Kg ND 105 ND 95.0 ND 95.7 ND 97.5 2,4-Dimethylphenol µg/Kg ND 168 ND 152 ND 153 ND 156 2,4-Dinitrophenol µg/Kg ND 780 ND 704 ND 710 ND 723 2,4-Dinitrotoluene µg/Kg ND 70.4 ND 63.6 ND 64.1 ND 65.3 2,6-Dinitrotoluene µg/Kg ND 87.0 ND 78.6 ND 79.2 ND 80.7 2-Chloronaphthalene µg/Kg ND 48.9 ND 44.2 ND 44.5 ND 45.4 2-Chlorophenol µg/Kg ND 75.6 ND 68.3 ND 68.8 ND 70.1 2-Methylnaphthalene µg/Kg ND 8.14 ND 7.36 ND 7.41 ND 7.55 2-Methylphenol µg/Kg ND 71.0 ND 64.2 ND 64.7 ND 65.9 2-Nitroaniline µg/Kg ND 59.6 ND 53.8 ND 54.2 ND 55.3 2-Nitrophenol µg/Kg ND 105 ND 94.5 ND 95.2 ND 97.0 3 & 4 Methylphenol µg/Kg ND 73.8 ND 66.7 ND 67.2 ND 68.5 3,3'-Dichlorobenzidine µg/Kg ND 62.0 ND 56.0 ND 56.4 ND 57.5 3-Nitroaniline µg/Kg ND 137 ND 124 ND 125 ND 127 4,6-Dinitro-2-methylphenol µg/Kg ND 356 ND 322 ND 324 ND 330 4-Bromophenyl phenyl ether µg/Kg ND 58.4 ND 52.7 ND 53.1 ND 54.1 4-Chloro-3-methylphenol µg/Kg ND 151 ND 136 ND 137 ND 140 4-Chloroaniline µg/Kg ND 208 ND 188 ND 189 ND 193 4-Chlorophenyl phenyl ether µg/Kg ND 51.7 ND 46.7 ND 47.1 ND 48.0 4-Nitroaniline µg/Kg ND 185 ND 167 ND 169 ND 172 4-Nitrophenol µg/Kg ND 421 ND 381 ND 383 ND 391 Acenaphthene µg/Kg ND 7.96 ND 7.19 ND 7.24 ND 7.38 Acenaphthylene µg/Kg ND 5.84 ND 5.27 ND 5.31 ND 5.41 Acetophenone µg/Kg ND 110 ND 99.8 ND 101 ND 102 Anthracene µg/Kg ND 7.40 ND 6.68 ND 6.73 ND 6.86 Atrazine µg/Kg ND 130 ND 117 ND 118 ND 120 Benzaldehyde µg/Kg ND 440 ND 397 ND 400 ND 408 Benzo[a]anthracene µg/Kg ND 5.96 ND 5.38 ND 5.42 ND 5.53 Benzo[a]pyrene µg/Kg ND 8.57 ND 7.74 ND 7.80 ND 7.95 Benzo[b]fluoranthene µg/Kg ND 9.56 ND 8.63 ND 8.70 ND 8.86 Benzo[g,h,i]perylene µg/Kg ND 14.3 ND 12.9 ND 13.0 ND 13.2 Benzo[k]fluoranthene µg/Kg ND 13.0 ND 11.8 ND 11.9 ND 12.1 Bis(2-chloroethoxy)methane µg/Kg ND 45.2 ND 40.8 ND 41.1 ND 41.9 Bis(2-chloroethyl)ether µg/Kg ND 66.4 ND 60.0 ND 60.4 ND 61.6 Bis(2-ethylhexyl) phthalate µg/Kg ND 80.9 ND 73.1 ND 73.6 ND 75.0 Butyl benzyl phthalate µg/Kg ND 84.2 ND 76.1 ND 76.7 ND 78.1 Caprolactam µg/Kg ND 133 ND 120 ND 121 ND 123 Carbazole µg/Kg ND 111 ND 100 ND 101 ND 103 Chrysene µg/Kg ND 12.1 ND 10.9 ND 11.0 ND 11.2 Dibenz(a,h)anthracene µg/Kg ND 8.56 ND 7.73 ND 7.79 ND 7.94 Dibenzofuran µg/Kg ND 51.8 ND 46.8 ND 47.2 ND 48.1 Diethyl phthalate µg/Kg ND 75.0 ND 67.8 ND 68.3 ND 69.6 Dimethyl phthalate µg/Kg ND 57.8 ND 52.3 ND 52.7 ND 53.6 Di-n-butyl phthalate µg/Kg ND 67.4 ND 60.9 ND 61.4 ND 62.5 Di-n-octyl phthalate µg/Kg ND 72.2 ND 65.3 ND 65.8 ND 67.0 Fluoranthene µg/Kg ND 8.21 ND 7.42 ND 7.47 ND 7.61 Fluorene µg/Kg ND 6.22 ND 5.62 ND 5.67 ND 5.77 Hexachlorobenzene µg/Kg ND 10.3 ND 9.27 ND 9.34 ND 9.52 Hexachlorobutadiene µg/Kg ND 69.6 ND 62.9 ND 63.3 ND 64.5 Hexachlorocyclopentadiene µg/Kg ND 255 ND 230 ND 232 ND 236 Hexachloroethane µg/Kg ND 67.3 ND 60.8 ND 61.3 ND 62.4 Indeno[1,2,3-cd]pyrene µg/Kg ND 11.5 ND 10.4 ND 10.4 ND 10.6 Isophorone µg/Kg ND 49.7 ND 44.9 ND 45.3 ND 46.1 Naphthalene µg/Kg ND 6.81 ND 6.15 ND 6.20 ND 6.32 Nitrobenzene µg/Kg ND 11.0 ND 9.98 ND 10.1 ND 10.2 N-Nitrosodi-n-propylamine µg/Kg ND 54.1 ND 48.9 ND 49.3 ND 50.2 N-Nitrosodiphenylamine µg/Kg ND 52.2 ND 47.2 ND 47.6 ND 48.5 Pentachlorophenol µg/Kg ND 710 ND 642 ND 647 ND 659 Phenanthrene µg/Kg ND 6.17 ND 5.58 ND 5.62 ND 5.72 Phenol µg/Kg ND 98.4 ND 88.9 ND 89.5 ND 91.2 Pyrene µg/Kg ND 8.80 ND 7.95 ND 8.01 ND 8.16

Notes:

µg/Kg = microgram per kilogram MDL = Method Detection Limit ND = Not Detected

Total SVOC

TABLE 3

Untreated Analytical Characterization

CARDNO-GS, INC.

BIEN HOA AIRBASE THERMAL STUDY

PROJECT No. SH0738

Semi Volatile Organic Compounds (SVOC) 8270D

Table 4 - Untreated Analytical Characterization - Dioxins & Furans.xlsx 1 of 1

KEMRON Environmental Services, INC

Result Qual. EDL Result Qual. EDL Result Qual. EDL Result Qual. EDL

1,2,3,4,6,7,8-HpCDD pg/g 57.9 B 0.797 30.4 B 0.374 25.9 B 0.323 33.6 B 0.433 1,2,3,4,6,7,8-HpCDF pg/g 7.20 B 0.153 3.66 J B 0.0978 3.00 J B 0.110 4.36 J B 0.118 1,2,3,4,7,8,9-HpCDF pg/g 0.572 J 0.180 0.277 J 0.116 ND 0.130 0.288 J 0.139 1,2,3,4,7,8-HxCDD pg/g 1.43 J 0.201 1.41 J 0.464 0.879 J 0.201 0.980 J 0.201 1,2,3,4,7,8-HxCDF pg/g 1.41 J 0.321 0.793 J 0.311 ND 0.279 0.911 J 0.296 1,2,3,6,7,8-HxCDD pg/g 4.95 J 0.186 5.32 J 0.428 3.43 J 0.185 4.02 J 0.185 1,2,3,6,7,8-HxCDF pg/g 0.707 J 0.301 ND 0.291 ND 0.261 0.434 J 0.277 1,2,3,7,8,9-HxCDD pg/g 3.71 J 0.174 3.10 J 0.402 2.03 J 0.174 2.64 J 0.174 1,2,3,7,8,9-HxCDF pg/g 0.483 J B 0.332 0.369 J q B 0.322 0.398 J B 0.288 ND 0.306 1,2,3,7,8-PeCDD pg/g 2.97 J 0.302 13.5 0.854 3.13 J 0.267 3.48 J 0.261 1,2,3,7,8-PeCDF pg/g 0.962 J B 0.563 ND 0.466 0.505 J q B 0.410 0.843 J B 0.258 2,3,4,6,7,8-HxCDF pg/g 0.624 J 0.310 0.372 J 0.300 0.312 J q 0.269 0.418 J 0.286 2,3,4,7,8-PeCDF pg/g ND 0.578 ND 0.478 ND 0.421 0.581 J q 0.265 2,3,7,8-TCDD pg/g 761 G E 2.36 347 1.15 326 0.767 349 0.718 2,3,7,8-TCDF pg/g 10.2 0.139 13.4 0.157 8.27 0.200 9.51 0.150 OCDD pg/g 461 B 0.438 177 B 0.306 180 B 0.339 241 B 0.338 OCDF pg/g 11.3 J 0.116 5.08 J 0.0947 5.36 J 0.101 6.06 J 0.102 Total HpCDD pg/g 106 B 0.797 54.7 B 0.374 48.3 B 0.323 63.1 B 0.433 Total HpCDF pg/g 15.4 B 0.166 7.49 B 0.107 6.63 B 0.120 10.1 q B 0.129 Total HxCDD pg/g 39.6 0.187 109 0.431 32.5 0.187 37.7 0.186 Total HxCDF pg/g 15.7 q B 0.316 12.5 q B 0.306 8.41 q B 0.274 11.0 q B 0.291 Total PeCDD pg/g 20.0 q 0.302 148 0.854 27.1 0.267 24.5 q 0.261 Total PeCDF pg/g 79.6 B 0.570 57.2 B 0.472 44.0 q B 0.415 23.0 q B 0.261 Total TCDD pg/g 775 G 2.36 418 1.15 345 0.767 368 q 0.718 Total TCDF pg/g 65.0 0.373 56.4 q 0.289 41.4 q 0.241 42.3 q 0.257

Notes:

pg/g = picogram per gram EDL = Estimated Detection Limit ND = Not Detected J = Result is less than the Reporting Limit (RL) but greater than or equal to the MDL and the concentration is an approximate value B = Compound was found in the blank and sample G = The reported quantitation limit has been raised due to an exhibited elevated noise or matrix interference E= Result exceeded calibration range.

q = The reported result is the estimated maximum possible concentration of this analyte, quantitated using the theoretical ion ratio. The measured ion ratio does not meet qualitative identification criteria and indicates a possible interference.

Dioxins & Furans

CARDNO-GS, INC.

BIEN HOA AIRBASE THERMAL STUDY

PROJECT No. SH0738

TABLE 4

Untreated Analytical Characterization - Dioxins & Furans

Dioxins & Furans 8290A

4.0 THERMAL TREATMENT TESTING

The thermal simulations were performed utilizing a target temperature of 335°C, at durations of 7 and 14 days while at the target temperature. All tests were performed using a stainless steel box reactor to hold the test sample being treated. Heating was accomplished using a Fisher Scientific muffle furnace. A stainless steel line was attached to a compression fitting on the lid of the reactor to carry pressurized breathing quality air into the reactor. The airflow was regulated to approximately 10-20 ml/min using an adjustable air manometer. A Type “K” thermocouple was inserted through a second compression fitting on the reactor lid so that the tip of the thermocouple resided in the middle of the test material mass. A second thermocouple was placed within the air space of the oven at a location near the reactor to record the furnace temperature during the testing. Finally, a stainless steel off-gas line was connected to a third fitting on the reactor lid to carry off-gas vapors from the rector during testing. The off-gas line was connected to a cold-water condenser and a vacuum flask used as a condensate collection vessel.

Throughout the testing various off-gas sample collection media was connected to the vacuum nipple on the condensate collection flask as necessary. The following photograph represents the set up utilized for testing of the site materials with the injection of air:

Throughout the thermal treatment simulations, KEMRON measured and collected the condensate produced during each test. The condensate was removed from the collection flask daily and placed into refrigerated storage. At the conclusion of the testing, all condensate samples from a specific treatment scenario were composited and sampled for

Total VOCs. In addition to condensate sampling, KEMRON collected air samples using various media and collection methods to evaluate the production or release of non-condensable chemical compounds including Total VOCs, Total SVOCs, and Total Dioxin/Furans. Specifically, Total VOCs were collected during the period of the test where the soil temperature was between approximately 90 and 100°C. SVOC off-gas collection was performed during heating where the soil temperature was between 100°C and 335°C, and Dioxin/Furan air-samples were collected while the soil temperature was at the target temperature of approximately 335°C throughout the treatment duration. The thermal testing data sheets are included in Appendix D.

4.1 BH-PI-2-T-COMP 7-Day Thermal

KEMRON performed the 7-day thermal treatment simulation to evaluate the treatment effectiveness as well as quantifying potential COCs collected in the test condensate and non-condensed air sampling events. The treatment was performed by, initially, slowly increasing the soil temperature to approximately 100°C over the course of 10 to 11 hours.

Total VOC air sampling was performed during the period where the soil temperature measured 95-246°C using a 3 liter Summa Canister equipped with a flow controller to allow continuous sampling over a 72.6 hour period.

Immediately following the completion of VOC air sampling, the off-gas sampling media, the Summa canister, was replaced with a mini PUF cartridge attached to a low flow personal vacuum pump regulated to approximately 50 ml/min for the collection of an

SVOC off-gas sample. The SVOC air sample was collected during the heating period where the test soil exhibited a temperature of approximately 247 to 332°C, roughly 5,494 hours, or 3.82 days. Once the test soil reached the operating target temperature of 335°C, plus or minus 5°C, the air sampling media was replaced with media for Dioxin/Furan air sampling. Dioxin/Furan air sampling was performed for approximately 7 days while the soil temperature was maintained at the 335°C target temperature. The following photograph depicts a typical off-gas condensate collection system:

Over the course of testing, KEMRON continually collected condensate produced during the simulation. To reduce the potential for volatilization of compounds present in the condensate, KEMRON replaced the condensate collection vessel daily and stored all condensed liquids under refrigeration maintained at approximately 4°C. The condensate collected during the treatment simulation was clear in color with a strong chemical odor detected. A total of 412.01 grams of condensate was collected throughout the testing.

Throughout the testing simulation KEMRON monitored and recorded the soil and oven temperatures using a dual thermocouple data logger. The following is a graphical representation of Figure 1, the temperature monitoring activities for the 7-day test duration simulation:

Figure 1

Following the completion of the 7-Day thermal simulation test, the soil reactor was removed from the oven and chilled to 4oC prior to analytical sampling. After being chilled, the weight of the reactor was recorded. The test material was then removed, homogenized, and sampled for the following chemical analyses:

Total Volatile Organics EPA Method 8260B Total Gasoline Range Organics EPA Method 8015C Total Diesel Range Organics EPA Method 8260D Total Arsenic EPA Method 6010C Total Semi Volatile Organics EPA Method 8270D Total Dioxins / Furans EPA Method 8290A

0 5000 10000 15000 20000

Te m p er at u re °C

Elapsed Time (minutes)

335C Temperature Graph @ 7-Day Treatment

Soil Temperature Oven Temperature

4.1.1 BH-PI-2-T-COMP 7-Day Thermal Analytical Results

Condensate Analytical Results

The results of Total VOC analyses performed on the 7-Day treatment condensate is summarized in Table 5. Review of this data shows that Acetone was detected in the liquid at a concentration of 31.2 milligrams per Liter (mg/L), Methyl Ethyl Ketone was detected at an estimated concentration of 0.283 mg/L, and Chloroform was detected at an estimated concentration of 0.0488 mg/L. Note that estimated concentrations were flagged with a “J” qualifier indicating that the detected concentration is between the analytical

Reporting Limit (RL), and the Method Detection Limit (MDL). The complete analytical report is included in Appendix E.

Off-Gas Analytical Results

The results of Total VOC analyses, performed on the off-gas collected using the Summa

Canister during a 3.02 day testing period, where the soil exhibited a temperature ranging from 95 to 246.8°C, are summarized in Table 6. The following is a presentation of the compounds detected in the VOC air sample:

TABLE 6 - Off-Gas VOCs in BH-PI-3-T-COMP (7 day)

Parameters Units BH-PI-2-T-COMP (7 day)

Result Qual. MDL

Volatile Organic Compounds (VOC) 8260B

1,3-Butadiene ppb v/v 7,670 30.7

2-Butanone (MEK) ppb v/v 797 118

Acetone ppb v/v 21,600 918

Benzene ppb v/v 69.2 J 12.9

Chloromethane ppb v/v 285 J 107

Hexane ppb v/v 36.5 J 21

The results of SVOC analyses performed on the sampling media utilized for the collection of off-gas is presented in Table 7. The sampling activities for SVOCs took place over a duration of 3.82 days while the test soil exhibited temperatures ranging from 246.7 to

332.4°C. KEMRON has calculated that approximately 262.61 liters of air was passed through the sampling media during this sampling activity. Review of Table 7 shows that

Bis(2-ethylhexyl) phthalate was detected at the highest concentration of 4.3 micrograms/sample (µg/sample), 3,3’-Dichlorobenzidine was detected at a concentration of 3.37 µg/sample, and Diethyl phthalate was detected at a concentration of 0.707 µg/sample. The other SVOC compounds were not detected above the analytical MDLs.

Total Dioxin/Furan off-gas sampling was performed over a period of 6.97 days. Sampling was initiated when the test soil reached the target treatment temperature of 332.4°C and was continued for the remainder of the 7-day testing duration. KEMRON calculated that approximately 501.5 liters of post-condenser off-gas was passed through the sampling media during this sampling event. The results of analytical testing performed on the sampling media is presented in Table 8. Table 8 indicates that OCDD was detected at a concentration of 2.92 picograms per sample (pg/sample), OCDF was detected at a concentration of 0.63 pg/sample, and Total TCDD was detected at a concentration of

0.487 pg/sample. The analytical laboratory indicated that all three compounds were approximate values, where the detected concentration was between the analytical RL and the MDL, and that all three compounds were detected in the blank and sample which may indicate possible sample contamination. Additionally, OCDF and Total TCDD results were flagged with a qualifier indicating that there may have been some possible interference in the analyses. The complete analytical reports are included in Appendix E.

Treated Soil Analytical Results

Prior to sampling of the treated soil material for analytical testing, the entire soil mass was removed from the chilled test reactor and homogenized. KEMRON personnel indicated that the soil material was orange/brown in color with no noticeable odor, was easily broken up with moderate effort into a fine-grained powder. The results of analytical testing are summarized in Tables 9, 10 and 11.

Review of the Total VOC, GRO, DRO, and Arsenic analyses presented in Table 9 is summarized below:

Table 9 –Total VOCs, GRO, DRO, Arsenic Analyses – Treated Soil

Result Qual. MDL

Volatile Organic Compounds (VOC) 8260B

Acetone µg/Kg 101 8.71

Benzene µg/Kg 5.48 0.510

Methyl Ethyl Ketone µg/Kg 4.65 J 2.22

Toluene µg/Kg 1.27 J 0.505

Gasoline Range Organics (GRO) 8015C

Gasoline Range Organics (C6-C9) µg/Kg ND 509

Diesel Range Organics (DRO) 8015D

DRO (C10-C28) mg/Kg 7.85 J 3.20

Metals 6010C

Arsenic mg/Kg 7.70 0.316

Table 10 is a presentation of Total SVOC analyses performed on the soil material thermally treated for 7 days while at the target operating temperature. Review of Table

10 shows that no SVOC compounds were detected in the treated soil material.

Table 11 is a summary of Total Dioxins/Furans analysis performed on the 7-day treated soil material. The following is a presentation of the compounds detected during analytical testing:

TABLE 11 – Total Dioxins/Furans Analyses – Treated Soil

Result Qual. EDL

Dioxins & Furans 8290A

1,2,3,4,6,7,8-HpCDD pg/g 3.07 J B 0.0646

1,2,3,4,6,7,8-HpCDF pg/g 0.481 J B 0.0450

1,2,3,4,7,8,9-HpCDF pg/g 0.218 J q 0.0535

1,2,3,4,7,8-HxCDD pg/g 0.606 J B 0.0774

1,2,3,4,7,8-HxCDF pg/g 0.168 J q 0.0913

1,2,3,6,7,8-HxCDD pg/g 0.668 J 0.0732

1,2,3,7,8,9-HxCDD pg/g 0.591 J q 0.0688

1,2,3,7,8,9-HxCDF pg/g 0.174 J B 0.0991

1,2,3,7,8-PeCDD pg/g 1.01 J 0.170

2,3,4,6,7,8-HxCDF pg/g 0.161 J 0.0890

2,3,4,7,8-PeCDF pg/g 0.0885 J q 0.0758

2,3,7,8-TCDD pg/g 3.85 0.100

2,3,7,8-TCDF pg/g 0.466 J 0.0560

OCDD pg/g 15.1 B 0.103

OCDF pg/g 0.872 J B 0.0925

Total HpCDD pg/g 6.43 B 0.0646

Total HpCDF pg/g 0.882 J q B 0.0492

Total HxCDD pg/g 11.1 q B 0.0731

Total HxCDF pg/g 0.503 J q B 0.0919

Total PeCDD pg/g 12.1 0.170

Total PeCDF pg/g 2.40 J q 0.0760

Total TCDD pg/g 7.13 q 0.100

Total TCDF pg/g 1.58 q 0.0560

Note that several compounds were flagged with qualifiers indicating potential interference, compound detected in the blank and sample, and/or approximated value because the concentration was below the RL but above the analytical MDL. Complete analytical reports are included in Appendix E.

4.2 BH-PI-2-T-COMP 14-Day Thermal

KEMRON performed the 14-day thermal treatment simulation in a similar manner implemented during the 7-day testing, including slow temperature ramping, condensate collection, handling off-gas sampling and analyses, and treated soil sampling and analyses. Note that the condensate collected during the 14-day thermal simulation was not analyzed at the request of Cardno.

KEMRON collected a total of 373 grams of condensate during the 14-day treatment simulation. Note that there is a relatively significant discrepancy between the mass loss exhibited in the treated soil and the mass of condensate collected. KEMRON often sees variability in these weights due to several factors including mass of condensate remaining in off-gas tubing and not recovered in the condensate collection flask, potential volatilization of constituents, loss of condensate during transfer between daily collection flasks and storage containers and non-condensable gases that pass through the system.

Figure 2 is a graphical presentation of the temperature monitoring activities performed during the 14-day test simulation. The following is a summary of Figure 2:

Figure 2

Following the completion of the 14-Day thermal simulation test, the soil reactor was removed from the oven and chilled to 4oC prior to analytical sampling. After being chilled, the weight of the reactor was recorded. The test material was then removed, homogenized, and sampled for the following chemical analyses:

0 5000 10000 15000 20000 25000 30000

Te m p er at u re °C

Elapsed Time (minutes)

335C Temperature Graph @ 14 -Day Treatment

Total Volatile Organics EPA Method 8260B Total Gasoline Range Organics EPA Method 8015C Total Diesel Range Organics EPA Method 8260D Total Arsenic EPA Method 6010C Total Semi Volatile Organics EPA Method 8270D Total Dioxins / Furans EPA Method 8290A SPLP Volatile Organics EPA Method 1312/8260B SPLP Gasoline Range Organics EPA Method 1312/8015C SPLP Diesel Range Organics EPA Method 1312/8260D SPLP Arsenic EPA Method 1312/6010C SPLP Semi Volatile Organics EPA Method 1312/8270D SPLP Dioxins / Furans EPA Method 1312/8290A

4.2.1 BH-PI-2-T-COMP 14-Day Thermal Analytical Results

Condensate Analytical Results

As previously mentioned, the condensate collected during the 14-day testing was not analyzed for Total VOCs.

Off-Gas Analytical Results

The results of Total VOC analyses, performed on the off-gas collected using the Summa

Canister during a 3.16 day testing period where the soil exhibited a temperature ranging from 88.1 to 246.6°C, are summarized in Table 6. The following is a presentation of the compounds detected in the VOC air sample:

TABLE 6 - Off-Gas VOCs in BH-PI-3-T-COMP (14 Day)

BH-PI-2-T-COMP (14 day)

Result Qual. MDL

Volatile Organic Compounds (VOC) 8260B

1,3-Butadiene ppb v/v 306 2.3

2-Butanone (MEK) ppb v/v 44.2 J 8.83

Acetone ppb v/v 2,420 68.7

Acetonitrile ppb v/v 18.2 J 17.8

Acrolein ppb v/v 36.4 J 26.7

Benzene ppb v/v 65.7 0.968

Butane ppb v/v 268 10

Chloromethane ppb v/v 37.8 7.99

Cyclohexane ppb v/v 4.31 J 2.78

Heptane ppb v/v 4.67 J 1.69

Hexane ppb v/v 44.5 1.57

Nonane ppb v/v 2.67 J 2.18

Pentane ppb v/v 153 9.56

Tetrachloroethene ppb v/v 1.96 J 0.847

The VOC results indicate that several compounds in the 14-day off-gas sample were detected at significantly lower concentrations compared to the 7-day VOC results.

Specifically Acetone, 1,3-Butadiene, and 2-Butanone were reported at much higher concentrations in the 7-day specimen. Note that the 7-day testing results were reported using detection limits over 10 times the detection limits utilized in the 14-day testing.

These elevated concentrations may be partially due to a dilution being utilized in the 7-day analyses. Compounds including Butane, Acrolein, Acetonitrile, Heptane, Nonane, and Tetrachloroethene were detected in the off-gas from the 14-day test may have been present in the 7-day off-gas samples but at concentrations below the reported analtycal

MDLs.

The results of SVOC analyses performed on the sampling media utilized for the collection of off-gas in the 14-day testing is presented in Table 7. The sampling activities for SVOCs took place over a duration of 2.91 days while the test soil exhibited temperatures ranging from 246.6 to 331°C. KEMRON has calculated that approximately 209.8 liters of air was passed through the sampling media during this sampling activity. Review of Table 7 shows some variability in the compounds detected as well as the concentrations of compounds compared to the 7-day analyses. For example, Phenol was detected at the highest concentration of 24.1 µg/sample in the 14-day testing but was not detected in the

7-day test sample. Bis(2-ethylhexyl) phthalate was detected in both the 7 and 14-day off-gas samples but at a higher concentration in the 14-day sample than the 7-day sample.

Finally, 3,3’-Dichlorobenzidine was detected in the 7-day sample but not in the 14-day media. For a complete list of SVOC analytical results please refer to Table 7 attached to this text.

Total Dioxin/Furan off-gas sampling was performed over a period of 13.92 days with a total volume of 1,002 liters of off-gas being passed through the sampling media. Air sampling was initiated when the test soil reached the target treatment temperature of

331°C and was continued for the remainder of the 14-day testing duration. The results of analytical testing performed on the sampling media is presented in Table 8. Table 8 indicates that OCDD was detected at a concentration of 4.28 pg/sample, and OCDF was detected at a concentration of 2.33 pg/sample. All other compounds were not detected above the analytical EDLs. The complete analytical reports are included in Appendix F.

Treated Soil Analytical Results

Prior to sampling of the treated soil material for analytical testing, the entire soil mass was removed from the chilled test reactor and homogenized. KEMRON personnel indicated that the soil material was orange/brown in color with no noticeable odor, was easily broken up with moderate effort into a fine-grained powder. The results of analytical testing are summarized in Tables 9, 10, 11, 14, 15 and 16.

The Total VOC, GRO, DRO, and Arsenic analyses presented in Table 9 is summarized below:

Table 9 –Total VOCs, GRO, DRO, Arsenic Analyses – Treated Soil

Result Qual. MDL

Volatile Organic Compounds (VOC) 8260B

Acetone µg/Kg 45.7 9.18

Benzene µg/Kg 14.4 0.537

Cyclohexane µg/Kg 1.01 J 0.814

Ethylbenzene µg/Kg 1.12 J 1.01

Methyl Ethyl Ketone µg/Kg 4.84 J 2.34

Methylcyclohexane µg/Kg 1.18 J 0.726

Toluene µg/Kg 5.08 0.532

Xylenes, Total µg/Kg 3.10 J 0.674

Gasoline Range Organics (GRO) 8015C

Gasoline Range Organics (C6-C9) µg/Kg ND 377

Diesel Range Organics (DRO) 8015D

DRO (C10-C28) mg/Kg 5.93 J B 3.20

Metals 6010C

Arsenic mg/Kg 8.74 0.292

Review of the 14-day Total VOC results show some variability in the various compounds detected in the soil as well as the concentrations of those compounds compared to the 7-day soil analysis. Specifically acetone was detected at a significantly higher concentration in the 7-day specimen compared to the 14-day sample. Other compounds that were detected in the 14-day treated soil only included, Cyclohexane, Ethylbenzene, Xylenes, and Methylcyclohexane. GROs were not detected above the analytical MDLs, and DROs and Total Arsenic were relatively similar in both the treated 7 and 14 day soils.

Table 10 shows that, like the 7-day soils, no SVOC compounds were detected in the treated 14-day soil material.

Table 11 is a summary of Total Dioxins/Furans analysis performed on the 14-day treated soil material. The following is a presentation of the compounds detected during analytical testing:

TABLE 11 – Total Dioxins/Furans Analyses – Treated Soil

Result Qual. EDL

Dioxins & Furans 8290A

1,2,3,4,6,7,8-HpCDD pg/g 1.85 J B 0.0489

1,2,3,4,6,7,8-HpCDF pg/g 0.466 J B 0.0614

1,2,3,4,7,8,9-HpCDF pg/g 0.192 J q 0.0715

1,2,3,4,7,8-HxCDD pg/g 0.254 J q B 0.0835

1,2,3,4,7,8-HxCDF pg/g 0.213 J 0.0442

1,2,3,6,7,8-HxCDD pg/g 0.427 J 0.0794

1,2,3,6,7,8-HxCDF pg/g 0.142 J B 0.0409

1,2,3,7,8,9-HxCDD pg/g 0.403 J 0.0746

1,2,3,7,8,9-HxCDF pg/g 0.186 J q B 0.0493

1,2,3,7,8-PeCDD pg/g ND 0.115

1,2,3,7,8-PeCDF pg/g ND 0.0650

2,3,4,6,7,8-HxCDF pg/g ND 0.0453

2,3,4,7,8-PeCDF pg/g ND 0.0690

2,3,7,8-TCDD pg/g 1.60 Q 0.0925

2,3,7,8-TCDF pg/g 0.344 J q 0.0219

OCDD pg/g 10.1 B 0.0902

OCDF pg/g 1.09 J B 0.0997

Total HpCDD pg/g 3.63 J B 0.0489

Total HpCDF pg/g 0.858 J q B 0.0665

Total HxCDD pg/g 4.08 J q B 0.0792

Total HxCDF pg/g 0.659 J q B 0.0449

Total PeCDD pg/g 1.29 J q 0.115

Total PeCDF pg/g 1.39 J 0.0670

Total TCDD pg/g 1.60 Q 0.0925

Total TCDF pg/g 0.344 J q 0.0219

Table 14 is a summary of SPLP VOC, GRO, DRO, and Arsenic analyses performed on the 14-day treated soil material. Review of the analytical results show that 1,2-

Dichlorobenzene was detected at 0.0150 milligrams per Liter (mg/L), Acetone at 0.175 mg/L, Toluene at 0.0107 mg/L and Xylenes at 0.0122 mg/L. These compounds were flagged with “J” flags indicating that the reported concentration is estimated and detected between the analytical Reporting Limit and the MDL.

Table 15 is a summary of the SPLP SVOC analysis also performed on the 14-day treated soil material. The review of the results show that Naphthalene was the only SVOC compound detected at 0.0124 mg/L.

Table 16 is a summary of the SPLP Dioxins/Furans analysis performed on the 14 day treated soil material. The following is a presentation of the compounds detected during analytical testing:

TABLE 16 – SPLP Dioxins/Furans Analyses – Treated Soil

Result Qual. EDL

Dioxins & Furans 8290A

1,2,3,4,7,8-HxCDD pg/L 8.23 J B 1.43

1,2,3,7,8,9-HxCDF pg/L 1.93 J q 1.59

OCDD pg/L 6.98 J B 2.34

Total HpCDD pg/L 3.01 J q B 1.53

Total HxCDD pg/L 8.23 J B 1.45

Total HxCDF pg/L 1.93 J q 1.67

Review of the total analytical results show that the majority of the detected compounds in the 14-day treated soil were similar or slightly lower compared to the 7-day treated soil.

The results of the 14-day treated soil Dioxin/Furan analysis also indicates that several compounds were flagged with qualifiers indicating potential interference, compound detected in the blank and sample, and/or approximated value because the concentration was below the RL but above the analytical MDL. Complete analytical reports are included in Appendix F.

A complete summary of the 7 and 14 day thermal testing set-up and testing conditions are summarized in Table 12. This table presents the weights of the test soils pre and post treatment, durations and methods of off-gas sampling activities, and condensate data.

Review of this table indicates that testing was completed as anticipated with no significant alterations in the proposed scope.

4.3 Additional Testing For Off-Gas VOC Evaluations

At the request of Cardno, KEMRON performed an additional thermal treatment simulation to evaluate the release or production of volatile organic compounds during a complete on-site soil treatment cycle potentially viable for full-scale activities. For this test, an aliquot of the BH-PI-2-T Comp soil was placed into the thermal treatment box. Heating of the soil was performed over an extended period of time until the approximate target temperature of 335°C had been achieved. KEMRON maintained this temperature for approximately 7 days, and then the treatment temperature was slowly increased until soil material reached a temperature of 670°C. During the treatment simulation KEMRON collected a total of seven (7) VOC off-gas samples via summa canister collection. Each summa canister was equipped with a 3-day flow controller calibrated at the analytical laboratory that supplied the canisters.

The testing simulation was performed in the same manner as employed in the previous testing. The soil was initially heated for approximately 385 minutes until the soil reached a temperature of approximately 80°C. At this time, the first summa canister (#1) was attached to the off-gas system post condenser, and off-gas collection was initiated.

Summa canister #1 collected the air sample for 3.13 days at temperatures between 81.3°C and 271.3°C. At the completion of this sample collection, the canister #1 was removed from the system and replaced with canister #2. Summa canister #2 was used to collect the VOC sample for the next 3.58 days at soil temperatures from 271.3°C to the treatment target temperature of 335.9°C.

KEMRON collected two additional VOC off-gas samples during the seven (7) day period that the soil was maintained at the approximate 335°C treatment target temperature.

Summa canister #3 collected the test off-gas for 3.44 days while at approximately 335°C, and canister #4 collected off-gas for 3.56 days while at 335°C. At the conclusion of the 7-day treatment duration at 335°C, KEMRON again slowly increased the treatment temperature to a maximum soil temperature of approximately 670°C. This additional heating is intended to simulate potential temperatures at locations nearer and adjacent to the heating elements being utilized at the site. During this additional heating, three (3) VOC off-gas samples were collected. Summa canister #5 was collected over a 3.45 days while the treatment soil was at temperatures between 335.3 to 491.7°C. Canister #6 was collected over the next 3.02 days while the soil was at temperatures between 491.7 and 644.8°C, and the final VOC sample was collected over the remaining 12.7 hour period that the testing was performed, reaching a maximum temperature of approximately 670°C.

Throughout the 670°C testing simulation, KEMRON recorded the soil and oven temperature via a dual channel temperature data-logger and thermocouples. A graphical representation of the temperature monitoring activities are included in Figure 3. The following is a graphical representation of the temperature monitoring activities performed during the 670°C testing:

Figure 3

Table 13 presents the results of Total VOC analyses performed on the off-gas samples collected during the treatment simulation. Note that the analytical laboratory notified KEMRON that the final Summa canister #7 had not been completely filled with sample and retained a significant vacuum. As a result of only collecting the off-gas sample over a 12.7 hour period, it was necessary to completely fill the canister with ambient air prior to processing the air sample for VOC analyses. This dilution was accounted for in the reported compound detection values and resulted in higher analytical reporting limits and reported method detection limits.

Review of the data presented in Table 13 indicates that benzene was detected in each of…