On September 7, 2005, the Commodity Credit Corporation of the U.S. Department of Agriculture (CCC/USDA) presented a Scoping Memo (Argonne 2005) for preliminary consideration by the Kansas Department of Health and Environment (KDHE). This document suggested possible remedial options for the carbon tetrachloride contamination in groundwater at Everest, Kansas. The suggested approaches were discussed by representatives of the KDHE, the CCC/USDA, and Argonne at the KDHE office in Topeka on September 8-9, 2005, along with other technical and logistic issues related to the Everest site. In response to these discussions, the KDHE recommended (KDHE 2005) evaluation of several remedial processes, either alone or in combination, as part of a Corrective Action Study (CAS) for Everest. The primary remedial processes suggested by the KDHE included the following: (1) Hydraulic control by groundwater extraction with aboveground treatment; (2) Air sparging-soil vapor extraction (SVE) in large-diameter boreholes; and (3) Phytoremediation. As a further outcome of the 2005 meeting and as a precursor to the proposed CAS, the CCC/USDA completed the following supplemental investigations at Everest to address several specific technical concerns discussed with the KDHE: (1) Construction of interpretive cross sections at strategic locations selected by the KDHE along the main plume migration …

On February 15, 2007, the Commodity Credit Corporation of the U.S. Department of Agriculture (CCC/USDA) submitted Recommendations for Remedial Action at Everest, Kansas. Those Recommendations were accepted by the Kansas Department of Health and Environment (KDHE) in a letter to the CCC/USDA dated March 5, 2007. The approved Recommendations document outlines a plan for systematic groundwater sampling and monitoring at Everest to provide data necessary for the critical evaluation of remedial options - including a phytoremediation alternative - for restoration of the groundwater and protection of the surface waters of the intermittent creek at this site. Phase I of the KDHE-approved monitoring plan includes the following activities: (1) Groundwater sampling at existing monitoring wells, with analyses for volatile organic compounds (VOCs) and selected biodegradation parameters; (2) Sampling of surface waters along the intermittent creek for VOCs analyses; and (3) Periodic manual measurement and automated recording of groundwater and surface water levels in the vicinity of the intermittent creek. The locations selected for groundwater and surface water sampling and analyses under the approved monitoring program were determined in consultation with the KDHE. As a result of subsequent discussions among representatives of the KDHE, the CCC/USDA, and Argonne regarding the technical program …