Area of Concern 22 – Old Reclamation Yard

Public Comment Period for AOC 22 has Expired

KDHE held a public comment period for this site from January 20 through February 18, 2022. All comments received during the public comment period will be addressed in the Final Agency Decision.

Proposed Remedial Measure

The proposed remedy for AOC 22 was excavation and off-site disposal for surface soils. Excavation and removal of surface soil off-site to an appropriate landfill or treatment facility was completed as an Interim Corrective Measure (ICM). Site-specific groundwater samples were below the Target Media Cleanup Levels (TMCLs) for Contaminants of Concern (COCs) as was subsurface soil.


A Relative Risk Site Evaluation (RRSE) was performed in 2003 by Battelle. Eight surface soil samples were collected and analyzed for RCRA metals (arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver), PCBs, volatile organic compounds (VOCs), and semi-volatile organic compounds (SVOCs). Target Media Cleanup Level (TMCL) exceedances of at least one Resource Conservation and Recovery Act (RCRA) metal occurred at seven sample locations; exceeding metals included arsenic, cadmium, chromium, lead, and mercury (CAPE, 2021).

Between 2008-2010, RFI field activities consisted of collection of 1,115 in-situ and 180 ex-situ x-ray fluorescence (XRF) readings, 105 surface and 13 subsurface soil samples, and two surface water samples. Arsenic, cadmium, chromium, copper, lead, mercury, benzo(a)pyrene, and PCBs exceeded their surface soil TMCLs (CAPE, 2021).

In 2019, twenty-two surface soil samples were collected, analyzed for benzo(a)pyrene, PCBs, and metals (arsenic, cadmium, hexavalent chromium, copper, lead, and mercury) and identified as surface soil Contaminants of Concern (COCs). Several subsurface areas had total chromium above the residential TMCL but speciated hexavalent chromium was below the residential TMCL, therefore subsurface chromium was not part of the excavation effort.

Corrective Measures Investigation (CMI) field activities, including excavation, were completed in 2020.  From June 22 to August 5, 2020, 5287.57 tons of soil were transported by Kansas-licensed waste transporters for off-site disposal at Johnson County Landfill after the results of waste characterization sampling determined the samples were non-hazardous (Cape 2021).

According to the Conceptual Land Use Plan, AOC 22 falls within the area designated as parks, trails, or open space (Johnson County, 1998).

KDHE Site Documents