PB99-963121
EPA541-R99-097
1999
EPA Superfimd
Record of Decision Amendment:
G.E. Wiring Devices Site
Juana Diaz, PR
7/1/1999
-------
-------
TABLE OF CONTENT
DECISION SUMMARY
I. INTRODUCTION 7
II. G. E . WIRING DEVICES SUPERFUND SITE 8
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 11
IV. REASONS FOR ISSUING THE RECORD OF DECISION AMENDMENT..12
V. DESCRIPTION OF ALTERNATIVES 14
VI. EVALUATION OF ALTERNATIVES 18
VII. SELECTED REMEDY .24
VIII. STATUTORY DETERMINATION. . 24
IX. DOCUMENTATION OF SIGNIFICANT CHANGE 27
APPENDICES
1. INDEX FOR THE ADMINISTRATIVE RECORD
2. RESPONSIVENESS SUMMARY
3 . PUERTO RICO ENVIRONMENTAL QUALITY BOARD CONCURRENCE LETTER
4. 1988 RECORD OF DECISION
-------
-------
DECLARATION STATEMENT
RECORD OF DECISION AMENDMENT
fiTTE NAME AND LOCATION
G.E. Wiring Devices Superfund Site
juana Diaz, Puerto Rico
STATEMENT OF BASIS AND PURPOSE
This Record of Decision Amendment presents the United States
Environmental Protection Agency's (EPA's) selection of a
modification to the remedial action for the G.E. Wiring Devices
Superfund Site (the "Site"), in accordance with the requirements of
the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, as amended (CERCLA), 42 U.S.C. S9601-9675,
and to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan, 40 CFR Part 300. This
Record of Decision Amendment explains the factual and legal basis
for selecting the modified remedy for the Site. The original
remedial action was selected in the Record of Decision issued by
EPA on September 30, 1988.
The attached index (Appendix 1) identifies the items that comprise
the Administrative Record upon which the selection of the remedial
action is based.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the
Site, if not addressed by implementing the response actions
selected in the September 30, 1988 Record of Decision, as revised
by this Record of Decision Amendment, may present an imminent and
substantial threat to the public health, welfare, or the
environment.
DESCRIPTION OF MODIFICATION TO THE SELECTED REMEDY
The modification to the selected remedy implements the off-site
disposal of all excavated mercury-impacted materials in a Subtitle
C (hazardous waste) landfill in the mainland United States without
additional treatment, in place of the on-site hydrometallurgical
treatment using the G.E. Mercury Extraction Process (GEMEP) system
and subsequent backfill.
-------
The components of the modification to the selected remedy consist
of the following:
o Elimination
t?eatednmaterial
of
the on-site hydrometallurgical treatment
includin9 the on-site backfilling of the
o Complete excavation of remaining mercury impacted materials,
including the clean washed coarse materials (mercury concentration
below the residential remediation goal (RG) of 39 parts per
million or ppm) that were backfilled in the West Field and
contaminated materials remaining underneath structures in three
electrical substation pads,
°f
o Placement of approximately 1,600 tons of clean, oversized
material currently in the West Field into Lift Liners.
Li- Trfn?port of the approximately 11,600 tons of containerized
material to a permitted RCRA Subtitle C hazardous waste landfill
e*pected that the specific landfill that will be
located in Pinewood, South Carolina; the wastes
p f tran;P°rted via truck to Ponce, by covered barge to
Charleston, and by truck to Pinewood.
o Backfill of the excavation areas with imported clean fill
material .
o Grading and seeding of the backfilled areas to support
revegetation, and to make it available for productive future use.
All the other components of the original remedy as selected in the
September 1988 Record of Decision are NOT affected by this
modification. These components are:
o Limited groundwater monitoring (i.e., for a minimum of three
^!ar!i' u9^Veu ^ additional groundwater investigation has
established that there is no need for groundwater remediation.
o Confirmatory air monitoring and re-sampling of soil in
residential yards.
-2-
-------
EXPLANATION OF FUNDAMENTAL CHANGE
The September 1988 Record of Decision addressed mercury
contamination in the waste-fill area known as the West Field,
including the waste-fill materials, contaminated near-surf ace soils,
and perched ground water expected to be encountered in the West
'Field having mercury concentrations above the health-based cleanup
levels specified by EPA. Major remedy components were (1)
excavation of wastes from the West Field and the contaminated near-
surface soils, (2) on-site hydrometallurgical treatment of materials
containing mercury in excess of 39 ppm, (3) on-site backfilling of
the treated materials having mercury levels less than 39 ppm in the
West Field, and (4) installation of a two-foot thick clean soil
cover over the backfilled area.
The conceptual hydrometallurgical treatment component described in
the 1988 Record of Decision differs from the specific GEMEP
hydrometallurgical treatment system which was ultimately designed
for the Site in two significant ways.
1) The 1988 Record of Decision did not consider a physical
separation treatment step that would remove both clean, coarse
material and high concentration metallic debris from the materials
to be treated hydrometallurgically.
2) The 1988 Record of Decision envisioned use of a readily
available leaching agent, such as cyanide, hypochlorite or nitric
acid, which were subsequently determined to be ineffective based
upon treatability study results. It also assumed the need for only
one batch of leaching agent. The GEMEP uses iodine, which was never
evaluated or even considered as a leaching agent.
During initiation of remedial activities, excavation of waste-fill,
and implementation of the physical separation treatment step, G.E.
encountered Site conditions that significantly differed from those
which served as basic assumptions in developing the 1988 Record of
Decision. These changed conditions make the original remedy less
implementable and more costly than other remedial alternatives.
The significant changed conditions include a 250 percent increase
in the waste volume; significant differences in the physical
characteristics of the waste (e.g., clay content); and serious
concerns regarding the inability to procure the additional quantity
of chemical extraction agent (iodine) needed to complete
hydrometallurgical treatment of the expanded waste volume using the
-3-
-------
GEMEP system. These variations and their impact on the original
remedy are described as follows:
Waste Volume - The estimated volume of contaminated materials
excavated to date has increased from 5,005 tons calculated in the
1994 Preliminary Design report to 11,700 tons. The estimated volume
of contaminated material requiring GEMEP treatment has increased
from 4,105 tons, calculated in the 1994 Preliminary Design Report
to 10,000 tons. The difference between these two sets of volumes
represents the clean coarse materials and the high concentration
materials which were disposed off-site. The majority of these
additional wastes consist of fine-grained clay soils, which are not
conducive to GEMEP treatment. Moreover, the amount of soil to be
excavated as part of the remedy has more than quadrupled from
original estimates.
The major increase in waste volume will cause the GEMEP treatment
system, which is based on mass, to run significantly longer and cost
significantly more than anticipated in 1988. The increased tonnage
from the West Field has already contributed to a significant
increase in the duration of the excavation and physical treatment
components. Also, the available space on-site to stockpile
materials awaiting treatment is limited.
Waste Composition - The content of fine soils (i.e., clay) in the
materials from the West Field is much greater than anticipated in
the remedial design, which assumed that 34 percent of the materials
would consist of fines. Recent grain-size analyses indicated that
the wastes actually consist of 85 percent fines. The tests also
showed that about 63 percent of the material is clay-sized.
These changes in waste composition will cause a significant increase
in the amount of clay materials requiring treatment, which is
expected to result in substantial materials handling difficulties
The new waste characteristics already have caused the excavation and
physical treatment components to far exceed the original time
schedule. For example, the physical separation process took 34
weeks to complete, in comparison to the projected 4-week schedule
High clay content coupled with increased volume caused plugging and
fouling of the physical separation treatment equipment. Similar
setbacks to the GEMEP time frame are now expected due to materials
handling and dewatering difficulties.
Iodine Usaqe - The GEMEP treatment system uses iodine, a limited
commodity on the world market, as an extraction agent. Laboratory
tests indicated a conservative consumption rate of iodine equal to
1 percent of the treated soil/waste. Based on the projected waste
volume at that time, G.E. procured 40 tons of iodine. At present
-4-
-------
assuming the 1 percent consumption rate, at least 100 tons of iodine
will be needed by GEMEP because of the 250 percent increase in waste
volume. The additional 60 tons of iodine now required for the
GEMEP system will be difficult, time consuming and costly to obtain,
given that the majority of the global iodine production is sold out
for the next two years.
Two major operational factors, the significant increase in waste
volume and the uncertainties associated with the iodine consumption
rate in a full-scale GEMEP treatment system, further exacerbate the
situation. G.E. would need to procure the additional iodine prior
to system start-up to provide an adequate supply for continuous
operation.
Based on iodine losses of 1 percent and the treatment of 10,000 tons
of material, the estimated total cost of the GEMEP remedy is now
estimated at $8.8 million, assuming the treatment system runs 'for
52 weeks. Four other scenarios were developed in the Focused
Feasibility Study, illustrating the cost impact associated with
higher and lower treatment rates, higher iodine losses, and an
increase in the total quantity of material'. These estimated total
costs ranged from $7.9 to $11.4 million.
In light of these factors, EPA proposed to eliminate the on-site
treatment component of the original remedy in favor of off-site
disposal in a permitted-RCRA Subtitle C hazardous waste landfill.
EPA is NOT proposing to change the mercury cleanup level it adopted
for the Site in 1993, which remains at 39 ppm. The only
modification to the remedy involves the off-site disposal of
materials greater than 39 ppm mercury, including the three areas of
waste deposition yet to be excavated. In comparison to the GEMEP
treatment approach described above, off-site disposal has an
estimated cost of less than $3.5 million. Thus, the modified remedy
will also result in a significant cost savings.
DECLARATION OF STATUTORY DETERMINATIONS
The original remedy, as revised by the selected modification, meets
the requirements for remedial actions set forth in CERCLA §121, 42
U.S.C. §9621 in that it: (1) is protective of human health and the
environment; (2) attains a level or standard of control of the
hazardous substances, pollutants and contaminants, which at least
attains the legally applicable or relevant and appropriate
requirements under federal and state laws; (3) is cost-effective;
(4) utilizes alternative treatment (or resource recovery)
technologies to the maximum extent practicable; and (5) satisfies
the statutory preference for remedies that employ treatment to
-5-
-------
reduce the toxicity, mobility, or volume of the hazardous
substances, pollutants or contaminants at a site. Physical
separation treatment, consisting of dry screening, wet soil washing,
and magnetic separation of the mercury contaminated materials to
remove both clean coarse material and high concentration materials
containing "free" mercury was conducted.
Because the modified remedy will not result in hazardous substances
remaining on-site above health-based levels, the five-year remedial
action review will not apply to this action.
Jeanne M.
Regional
/
Date
-6-
-------
DECISION SUMMARY
RECORD OF DECISION AMENDMENT
G.E. Wiring Devices Superfund Site
Juana Diaz, Puerto Rico
I. INTRODUCTION
The G.E. Wiring Devices Site is located in the south central part
of the island of Puerto Rico on Calle Carrion Maduro Final (Carr.
149, Km. 67) in the municipality of Juana Diaz. The Site is
northeast of Ponce, close to the intersection of Routes 14 and 149.
See Location Map (Figure 1). The General Electric Company (G.E.)
operates a wiring devices plant at the Site, manufacturing various
residential, institutional, and commercial electrical devices, such
as night lights, wall outlets, and switches. The plant covers about
six acres, and includes a 1.1 acre waste-fill area, referred to as
West Field, that is the source of mercury contamination. See Site
Map (Figure 2) . G.E. has not used mercury in its manufacturing
process at the Juana Diaz plant since 1970.
Several residences are located about 400 feet south of the West
Field area. Ground water in the area is used as a source of potable
water. A public supply well is located about 1,500 feet west of the
waste-fill area.
From 1957 until 1969, G.E. used the waste-fill area known as West
Field to dispose of defective electrical components, including parts
from silent mercury switches. Each switch contained a hermetically
sealed, stainless-steel button that encased a ceramic core
containing elemental mercury. At the Site, G.E. broke open buttons
that did not meet quality specifications to reclaim the mercury.
G.E. then discarded the steel button shells, with residual mercury
and ceramic cores, in the waste-fill area, along with other
defective switch parts and plastic scraps.
Test pit excavations indicated that the waste-fill area was roughly
1 to 4 feet thick and covered 1.1 acres. Site investigations
confirmed that the mercury is tightly bound to the components in the
waste-fill area and has not migrated or entered the ground water.
Based on available data, including sampling and analysis by EPA in
April 1982, the Site was included on the National Priorities List
of hazardous sites in December 1982.
-7-
-------
II. G.E. WIRING DEVICES SUPERFUND SITE ^^
Throughout the mid- to late-1980s, EPA and G.E. conducted numerous
field studies to determine the extent of contamination and to
evaluate cleanup alternatives. In 1987, Law Engineering performed
a remedial investigation/feasibility study (RI/FS) of the West Field
for G.E.
After review of the FS, EPA directed the U.S. Bureau of Mines (BOM)
to evaluate additional treatment technologies that could achieve a
permanent remedy. BOM evaluated hydrometallurgical treatment, using
a variety of chemical reagents, such as acid and chlorine, to leach
mercury from a generic host material. BOM concluded that additional
studies of leaching using Site-specific' waste materials would be
necessary.
In September 1988, based on an Addendum FS, EPA selected a remedy
and issued the ROD for the Site. This remedy called for excavation
of wastes from West Field and the contaminated near-surface soils
•on-site hydrometallurgical treatment of the materials, backfilling
of the excavated area with treated materials, and placement of a
two-foot thick cover of clean soils over the backfilled area
Hydrometallurgical treatment involves mixing on-site waste
containing mercury with a leaching agent to create a solution
containing the mercury. The solution is filtered, and the mercury
is then removed by precipitation or cementation. The mercury can
then be recovered.
EPA revised the Baseline Risk Assessment for the Site in 1993. The
Risk Assessment calculated a residential remediation goal (RG) of
39 parts per million (ppm) for mercury levels in soil at the Site
The residential RG is based on a residential exposure scenario
involving ingestion of soil and waste. This meant that all material
with mercury concentrations above the residential RG of 39 ppm would
be removed, and that treated materials returned to the West Field
would be required to have mercury concentrations of less than 39
ppm. The ROD also included a groundwater component that consisted
of the installation of monitoring wells and groundwater sampling.
In late 1988, G.E. took over the treatability studies from the BOM
with EPA oversight. From 1994 to 1997, under EPA oversight, G.E!
patented a mercury removal process called the G.E. Mercury
Extraction Process (GEMEP) treatment system. GEMEP uses a water
solution of iodine and iodide to extract mercury from waste-fill
components and soil, leaving behind clean materials. The mercury
and iodine and iodide are then recovered and recycled.
-8-
-------
In June 1994, based upon successful laboratory studies, G.E.
designed the final conceptual treatment process for the Site, which
consisted of excavation of wastes having mercury concentrations
above the residential RG of 39 ppm from the West Field, followed by
a two-step treatment process:
1) physical separation treatment, consisting of dry screening, wet
soil washing, and magnetic separation of the materials to remove
both clean coarse material and high concentration materials
containing "free" mercury, and
2) hydrometallurgical (GEMEP) treatment of remaining residual wastes
containing non-mobile mercury at concentrations greater than 39 ppm.
Treated materials would be backfilled in the West Field and covered
with a soil' cover.
In mid-1996, G.E. contracted with Metcalf & Eddy, Inc. (M&E) to
design, fabricate, and operate the system, including the waste
separation (screening/washing) component (using (M&E's Hydrosep
process) and the GEMEP treatment component. This contract would
represent the first full-scale application-of the GEMEP technology.
In June 1997, G.E. initiated excavation of wastes from the West
Field for physical separation, and construction of the dry screening
and Hydrosep treatment systems. The physical separation treatment
(screening/washing) of excavated wastes occurred in conjunction with
the excavation activities.
The estimated duration of the physical separation treatment step of
the remedy was approximately 4 weeks. However, the physical
separation treatment extended 34 weeks due to two significant
variations between the design conditions and the conditions
encountered during its implementation at the Site:
1) The quantity of material that actually underwent physical
treatment was more than double the amount originally expected
(11,700 tons versus 5,005 tons), resulting in an associated increase
in the duration of the physical treatment step, and
2) The actual clay content of the material that underwent treatment
was much higher than expected (63 percent versus 18 percent),
resulting in major production delays related to various equipment
operational difficulties.
From June 1997 to April 1998, excavation of waste-fill and impacted
soils in the West Field and on PRIDCO property west of the G.E.
facility was completed concurrent with the physical treatment step.
Excavations on PRIDCO property were backfilled with clean off-site
-9-
-------
*
•
soil, and the backfilled area was graded, compacted, and seeded.
Clean (less than the residential RG of 39 ppm mercury) oversized
material from the physical separation (screening/washing) treatment
process was returned to the West Field. This material, washed
plastic components and small stones, was spread along the west wall
of the West Field excavation and leveled to an average thickness of
4 feet. The excavated slopes along the east side of the West Field
and around the cold storage building were backfilled with off-site
soil, which was compacted and seeded to protect the slope from water
erosion. A new chain link fence was installed along the west Site
boundary between the G.E. facility and the PRIDCO property.
During physical separation, material less than 1/4-inch, called
fines, was stored in piles on a concrete pad and in a second pile
near the pad while the system was operational. After completion and
demobilization of the physical separation process, these stockpiles
were consolidated on the concrete pad. The settled fines from all
three modu-tanks were removed and added to the fines pile on the
pad. Oversized material, greater than 2 inches, that was separated
during physical separation was added to the fines pile on the pad
and surrounded with concrete barriers at the toe. The entire
stockpile was then covered with four 100-foot by 100-foot tarps,
which were secured to the concrete pad around the perimeter of the
pile outside of the concrete barriers.
Over the 34-week period, approximately 100 tons of high
concentration wastes containing free mercury were generated from the
separation stage. This waste was packaged and transported off-site
for treatment in the mainland United States.
In May 1998, as a result of the two significant changed conditions
noted above, EPA and G.E. suspended all Site activities. The GEMEP
treatment system, which was near completion at that time, was
decommissioned. Consequently, no residual wastes from the physical
separation (screening/washing) treatment process were treated in the
GEMEP system.
At present, the Site is in a standby condition pending
identification of the final remedial alternative. In addition,
three areas of waste deposition remain to be excavated on the Site.
Access to material in these areas will require either significant
modifications to or demolition (and relocation) of various
structures, as follows:
o A small deposit of material underneath the northwest corner of
the cold storage building in the West Field.
-10-
-------
o Two small areas underneath the electrical substation pads on the
eastern side of West Field.
o A small area near the northwest corner of the maintenance shop
under the road and plant access ramp.
III. HIGHLIGHTS OP COMMUNITY PARTICIPATION
The Post-Decision Proposed Plan (PDPP) for the Site was released to
the public on April 26, 1999. The PDPP, along with other Site-
related documents, is available to the public at both the
administrative record and the information repository locations. A
summary of the PDPP and a notice as to the availability of those
documents and the administrative record was published in the San
Juan Star daily newspaper April 26, 1999, and in the El Nova Pi a
daily newspaper on May 10, 1999. A copy of the public notice is
included as an attachment to this Record of Decision Amendment.
The public comment period began on April 26, 1999 and ended on May
26, 1999. A public meeting was held on May 13, 1999 at the City
Hall in Juana Diaz. The purpose of the public meeting was to
discuss the proposed changes to the September 1988 Record of
Decision.
The responses to the comments received during the public comment
period as well as those expressed orally at the public meeting are
stated in the Responsiveness Summary, which is an attachment to this
Record of Decision.
This Record of Decision Amendment presents the selected modification
to the original remedial action for the disposition of mercury
impacted materials located at the Site. The modification to the
original remedial action is chosen in accordance with CERCLA and,
to the extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP) , 40 CFR Part 300. The decision as
made for the Site is based upon the administrative record. An index
for the administrative record is included as an attachment to this
document. This Record of Decision will become a part of the
administrative record file.
The administrative record file, containing the information upon
which the modification to the original remedy is based, is available
at the following locations:
U.S. Environmental Protection Agency
290 Broadway, 18th Floor
New York, New York 10007-1866
Byappt.: 212-637-3263
-11-
-------
Mon.- Fri., 9 am- 5 pm
The Press Office at che Mayor's Office
Casa Alcaldia de Juana Diaz
Calle Degetau
Mon. - Fri., 8 am - noon; 1 pm - 4:30 pm
Sat. & Sun., closed
U.S. Environmental Protection Agency
Caribbean Environmental Protection Division
Centre Europa Building
1492 Ponce De Leon Avenue, Suite 207
Santurce, PR 00907
By appt.: (787)729-6951 Ext. 263
Mon to Fri.: 7am to 4 pm
IV. REASONS FOR ISSUING THE RECORD OF DECISION AMENDMENT
GEMEpthni'E' CTfUCted laboratory studies which indicated the
GEMEP technology would meet ROD requirements. G.E. added a physical
^£art£°^tr?atment Step Pr±0r t0 hydrometallurgical treatment to
remove both clean coarse material and high concentration materials
free" mercury. GEMEP would then treat the remaining
Waf^eS containing non-mobile mercury at concentrations
~ n Ppm" Treated materials would be backfilled in the
West Field and covered with 2 feet of clean soils.
During initiation of remedial activities, excavation of waste-fill
imP menuati(?n °f the Physical separation treatment
1^ pr,ocLess' G'E- encountered Site conditions that
differed from the conditions which served as basic
assumptions in developing the 1988 ROD. These changed conditions
made the original remedy less implement able, and more costly than
other remedial alternatives.
The significant changed conditions include a 250 percent increase
in the waste volume; significant differences in the physical
characteristics of the waste (e.g., clay content); and serious
concerns regarding the inability to procure the additional quantity
j* J =hemical extraction agent (iodine) needed to complete
rpM^S J iUrgiCal treatment of the expanded waste volume using the
GEMEP treatment system. These variations and their impact on the
original remedy are described as follows:
-12-
-------
Waste Volume - The estimated volume of contaminated material
requiring GEMEP treatment has increased from 4,105 tons calculated
in the 1994 Preliminary Design Report, to 10,000 tons. This
increase is 2.5 times the original estimate of tonnage requiring
hydrometallurgical treatment. Additional areas to the north, east,
and south of the originally anticipated waste footprint were
discovered during excavation activities in the West Field. The
majority of these additional wastes consisted of fine-grained clay
soils, which are not conducive to this type of treatment. Moreover,
the amount of soil to be excavated as part of the remedy has more
than quadrupled from the original estimates.
This major increase in the amount of material requiring treatment
will cause the GEMEP treatment system, which is based on mass, to
run significantly longer and cost significantly more than
anticipated. The increased tonnage from the West Field has already
contributed to a significant increase in the duration of the
excavation and physical treatment components of the remedy.
Furthermore,' the available space on-site to stockpile materials
awaiting treatment is limited, and has required the placement of
residual materials in overflow storage areas outside of the
containment pad for the treatment system.
Waste Composition - The content of fine soils (i.e., clay) in the
materials from the West Field is much greater than anticipated in
the remedial design. While the remedial design assumed that
approximately 34 percent of the materials would consist of fines,
grain-si.ze analyses performed during implementation of the physical
treatment indicated that the wastes consist of approximately 85
percent fines. The tests also showed that about 63 percent of the
material is clay-sized.
The overall impact of these changes is a significant increase in the
amount of clay materials requiring treatment, which is expected to
result in substantial materials handling difficulties. These new
waste characteristics have already caused the excavation and
physical treatment components to far exceed the original schedule.
For example, the physical separation (screening/washing-) process
required 34 weeks to complete, in comparison to the projected 4-week
schedule. The high clay content coupled with the increased volume
caused plugging and fouling of the dry screening and Hydrosep
process component of the physical separation treatment equipment.
These materials handling problems lead to an increase in time spent
on equipment maintenance, resulting in project delays. Similar
setbacks to the GEMEP time frame are now expected due to materials
handling and dewatering difficulties.
-13-
-------
hydro™ctallurg±cal treatment process proposed in
relatvelv On the P°tential us* of readily available anS
*a£?ah°.f 11SaC1hlng *gent- The GEMEP treatment system uses ?odine
agent Y ^ C0mmodity on the «Prld market, as an extract^.
conservative consumption rate of iodine
nn-, the X Percent consumption rate, at least 100
tons of iodine wall be needed by GEMEP because of the increase in
the volume of waste (4,105 tons to 10,000 tons). increase in
°f 10dine n°W r^ired in the GEMEP will be
time consuming and costly to- obtain, qiven that th^
majority of the global iodine production is sold out for the next
in J^S' iTW° maj^ °Peration^ factors, the significant increase
in waste volume and the uncertainties associated with the" iodinl
consumption rate in a full-scale GEMEP treatment system !ncrea"st
the uncertainties of the situation. At the least, G E would need
an ^T^^6 ^^ iodin« P^or to system start-up to^rovidf
an. adequate supply for continuous operation. in addition the
consumption of 100 tons of iodine in the GEMEP will produce an
equivalent tonnage of iodide for landfill disposal Produce an
iodine losses of 1 percent and the treatment of 10,000 tons
etmatdaa; to B**^™*™* T*1 C°St °f the GEMEP remedV is nSw
estimated at $8.8 M. This best-case scenario assumes the GEMPP
devJlSS SYSt^m ^^ rUn f°r 52 Weeks" Four other scenarios were
developed in the Focused Feasibility Study, illustrating the cost
impact associated with higher and lower treatment rate's hig^r
iodine losses, and an increase in the total quantity of material
These estimated total costs ranged from $7.9 to $11 ?4 M material '
and
V. DESCRIPTION OP ALTERNATIVES
The comprehensive Environmental Response, Compensation
Liability Act (CERCLA) requires that each selected li^erem'e
protective of human health and the environment, be cost^eflScve
comply with other laws, and use permanent solutions and \?ternatlve
treatment technologies and resource recovery alternatives to
maximum extent practicable. in addition! CERCLA includes
-14-
-------
preference for treatment as a principle element for the reduction
of toxicity, mobility, or volume of the hazardous substances.
The present-worth costs presented below for each alternative include
capital costs and operation and maintenance (O&M) costs. The O&M
costs are for post-remediation monitoring of the Site over a three-
year period.
ALTERNATIVE 1 - EXISTING REMEDY IN THE SEPTEMBER 1988 RECORD OF
DECISION
Hydrometallurgical Treatment and Subsequent On-site Replacement of
the Treated Material
This alternative is defined as the selected remedy in the September
1988 Record of Decision. The original remedy addresses mercury
contamination in the waste-fill area known as the West Field,
including the waste-fill materials, contaminated near-surface soils,
and perched ground water expected to be encountered in the West
Field having mercury concentrations above the health-based cleanup
levels specified by EPA. Major remedy components are:
o Further treatability studies during remedial design to insure the
implementability of hydrometallurgical processes, as well as
continued study of other treatment alternatives.
o On-site hydrometallurgical treatment of the waste-fill materials
(approximately 4,000 cubic yards), perched water (approximately 0.5
million gallons) , and contaminated near surface soils (approximately
1,500 cubic yards).
o Treatment of the material to below health-based levels and
backfilling the waste-fill area with the treated materials. The
area would then be covered with 2 feet of clean soil.
o Additional investigation of the ground water to determine the
extent of groundwater contamination.
o Limited groundwater monitoring (i.e., for a minimum of three
years), provided that the additional groundwater investigation
establishes that there is no need for groundwater remediation.
o Confirmatory air monitoring and re-sampling of soil in
residential yards.
The hydrometallurgical treatment component is described in further
detail in the 1988 ROD on pages 18 and 19 as follows:
-15-
-------
"This alternative involves putting the mercury into solution by
using a leaching agent such as cyanide, hypochlorite or nitric acid.
The mercury would then be recovered from the aqueous solution by
using various metallurgical techniques such as filtration and
cementation/precipitation. The waste would be mixed with the
leaching agent until the desired level of mercury is extracted from
the waste and put into solution. The process stream from the
leaching stage would then be filtered. The residue from filtering
would be disposed of in the former waste-fill area and capped with
two feet of clean soil. The process would be designed to achieve
treatment of mercury from the waste to below health-based levels.
Since it is anticipated that the treatment process could attain
treatment of mercury to below acceptable levels, the actual
performance standard for the treatment process would be determined
by the maximum removal efficiency associated with the technology
with due consideration to the corresponding incremental cost
involved in achieving further removal. The mercury-laden liquid
from the filtering stage would then be subjected to cementation or
precipitation. This process is achieved by passing the liquid
through a material such as stainless steel, zinc, copper or
aluminum.
During cementation the mercury is exchanged with the metal and
precipitated out. The liquid would then be recycled back through
the process. It is anticipated that only one batch of leaching
agent would be needed. Upon completion of the process, the
remaining liquid would be treated on-site prior to discharge to a
POTW. Further treatability studies will be conducted during design
to optimize the treatment process. The process would be designed
to meet or exceed levels protective of public health."
The conceptual hydrometallurgical treatment component described
above in the 1988 ROD differs from the particular GEMEP
hydrometallurgical treatment system which was ultimately designed
for the Site in two significant ways:
1) The ROD did not consider a physical separation treatment step
that would remove both clean, coarse material and high concentration
metallic debris from the materials to be treated
hydrometallurgically.
2) The ROD called for use of a readily available leaching agent,
such as cyanide, hypochlorite or nitric acid/5 which were
subsequently determined to be ineffective based upon treatability
study results. The GEMEP uses iodine, which was never evaluated or
even considered in the ROD as a leaching agent.
-16-
-------
The estimated incremental cost of implementing Alternative 1 is
$8,810,3191, including the cost of post-closure groundwater
monitoring. This estimate considers the on-site treatment of 10,000
tons of residual material and its subsequent backfill over a 52-week
period, and iodine losses equivalent to one percent of the total
feed material.
ALTERNATIVE 2 - MODIFIED REMEDY AS SELECTED IN THIS RECORD OF
DECISION AMENDMENT
Off-site Disposal of all Remaining Site Wastes in a Subtitle C
(hazardous waste) Landfill in the Mainland United States Without
Further Treatment
This alternative is defined as the selected remedy in the Record of
Decision Amendment. It does not modify the remediation goal
established by EPA in the 1993 Baseline Risk Assessment for the
Site, which calculated a residential RG of 39 ppm for mercury levels
in soil.
This alternative eliminates the on-site hydrometallurgical treatment
component of the remedy, including the on-site backfilling of the
treated material. All remaining mercury- impacted materials at the
Site will be excavated, including the clean, washed coarse materials
(mercury concentration below the residential RG of 39 ppm) that were
backfilled in the West, Field and contaminated materials remaining
underneath structures in three discrete areas (cold storage
building, electrical substation pads, and maintenance shop).
Approximately 10,000 tons of mercury impacted fines and 1,600 tons
of clean, oversized material currently in the West Field will be
placed into containers called Lift Liners. It is currently expected
the 11,600 tons of containerized material will be transported to a
permitted RCRA Subtitle C hazardous waste landfill in Pinewood,
South Carolina (via truck to Ponce, by covered barge to Charleston,
and by truck to Pinewood).
Excavation areas will be backfilled with imported clean fill
material. The backfilled areas will be graded and seeded to support
revegetation, and will be made available for productive future use.
xThis cost is in addition to the costs GE'has spent on the
physical separation treatment and off-site disposal of highly
concentrated wastes.
-17-
-------
•
«•
The estimated total cost of Alternative 2 is $3,447,522', based on
• 11,600 tons of material to be loaded into Lift Liners at a rate of
20 containers per day.
VI. EVALUATION OF ALTERNATIVES
In accordance with the NCP, this section presents a detailed
analysis of the. original remedy and the alternative remedy
considered in the preceding section. The detailed analysis consists
of an assessment of the two alternatives against each of the NCP's
nine evaluation criteria and a comparative analysis focusing upon
the relative performance of each alternative against those criteria.
The following "threshold" criteria must be satisfied by an
alternative to be eligible for selection:
1. Overall protection of human health and the environment
addresses whether or not a remedy provides adequate protection and
describes how risks posed through each exposure pathway (based on
a reasonable maximum exposure scenario) are eliminated, reduced, or
controlled through treatment, engineering controls, or institutional
controls;
2. Compliance with applicable or relevant and appropriate
requirements (ARARs) addresses whether or not a remedy will meet all
of the applicable or relevant and appropriate federal and state
environmental statutes and requirements (i.e.. those federal or
state laws that 'specifically address a hazardous substance,
pollutant or contaminant, remedial action or other circumstance
found at a CERCLA site, or which address problems or situations
sufficiently similar to those encountered at a site that their use
is well suited to the site) or provide grounds for invoking a
waiver.
The following "primary balancing" criteria are used to make
comparisons and to identify the major trade-offs between
alternatives:
3. Long-term effectiveness and permanence refers to the ability
of a remedy to maintain reliable protection of human health and the
environment over time, once cleanup goals have been met;
4. Reduction of toxicity, mobility, or volume through treatment
refers to the degree to which remedial alternatives employ recycling
-18-
-------
*
•»•
or treatment that reduces the toxicity, mobility, or volume of
hazardous substances at a site;
5. Short-term effectiveness addresses the period of time needed
to achieve protection and any adverse impacts on human health and
the environment that may be posed during the construction and
implementation periods until cleanup goals are achieved;
6. Implexnentability refers to the technical and administrative
feasibility of a remedy, including the availability of the materials
and services needed to implement a particular option; and,
7. Cost includes estimated capital and operation and maintenance
costs, and net present-worth costs for alternatives expected to last
more than two years.
The following "modifying" criteria are considered fully after the
formal public comment period on the Post-Decision Proposed Plan is
completed:
8. State acceptance indicates whether, based on its review of the
remedial investigation/feasibility study (RI/FS), and the proposed
plan, the State supports, opposes, and/or has identified any
reservations with the preferred alternative; and,
9. Tribal/Community acceptance refers to the public's general
response to the alternatives described in the proposed plan and the
RI/FS reports; factors of community acceptance to be discussed
include support, reservation, and opposition by the tribe/community.
The following section presents a comparative analysis of the
alternatives based upon these evaluation criteria. The comparative
analysis focuses upon the essential differences in the two
alternatives:
Alternative I - Hydrometallurgical Treatment Using the GEMEP System
and Subsequent On-site Replacement of the Treated Material, and
Alternative 2 - Off-site Disposal of all Site Wastes in a Subtitle
C (hazardous waste) Landfill in the Mainland United States Without
Further Treatment.
1. Overall Protection of Human Health & the Environment
Both alternatives would be protective of human health and the
environment by preventing direct exposure to mercury-contaminated
materials. Alternative 1 would permanently reduce the mercury
concentration in residual materials to less than the residential RG
-19-
-------
of 39 ppm by treating the materials on-site using the GEMEP system.
The treated materials would then be backfilled in the West Field.
For Alternative 2, all materials containing mercury in excess of 39
ppm would be disposed off-site at an EPA-approved, RCRA-permitted
(Subtitle C) disposal facility.
2. Compliance with Applicable, or Relevant and Appropriate
Requirements (ARARs)
Both alternatives would achieve Applicable or Relevant and
Appropriate Requirements (ARARs), which include all federal and
Commonwealth regulations and public health regulations that address
a hazardous substance, pollutant, contaminant, remedial action,
location, or other circumstance at a - site. Three ARAR
classifications exist:
o chemical-specific ARARs, which 'are health- or risk-based
concentration limits of chemicals which may be found in, or
discharged to, the ambient environment;
o location-specific, which are based on the geographical location
of a site and its surroundings; and
o action-specific, which are typically technology-based or
activity-based requirements or limitations on actions taken with
respect to hazardous substances, pollutants, or contaminants.
No chemical-specific ARARs were identified for Alternative 1 or
Alternative 2. Both alternatives would achieve the residential RG
of 39 ppm for mercury by removing materials that exceed this
criterion from the Site by on-site treatment or off-site disposal,
respectively.
No location-specific ARARs have been identified for Alternative 1
or Alternative 2.
Action-specific ARARs for Alternatives 1 and 2 would include air
emissions and OSHA health and safety requirements. In addition, the
RCRA guidelines for facility operation would apply to Alternative
1, and the RCRA guidelines for generators, land disposal and waste
transportation would apply to Alternative 2.
3. Long-Term Effectiveness and Permanence
Both alternatives would achieve long-term effectiveness and
permanence.
-20-
-------
For Alternative 1, approximately 10,000 tons of stockpiled and
unexcavated residual materials would be treated on-site using the
GEMEP system to achieve the 39 ppm cleanup goal, and then backfilled
in the West Field and covered with a clean soil cap. Hazardous
GEMEP process residuals, including elemental mercury and spent iron
filings, would be sent off-site to an EPA-approved facility for
recycling or disposal.
For Alternative 2, all residual materials containing mercury
concentrations in excess of 39 ppm -and clean coarse materials
previously backfilled in the West Field would be transported off
site to an EPA-approved, RCRA-permitted (Subtitle C) disposal
facility, which is specifically designed to provide long-term
effectiveness and permanence for disposal of RCRA-hazardous wastes.
Most of the materials requiring off-site disposal under this
alternative have undergone physical treatment to remove any mobile
mercury, rendering the materials as non-hazardous.
4. Reduction in Toxicitv. Mobility, or Volume Through Treatment
The toxicity, mobility, and volume of mercury contamination were
reduced at the Site as a result of prior remedial activities, which
included excavation and physical treatment to remove mobile mercury.
Alternative 1 would achieve further reductions in waste toxicity,
mobility, and volume by using the on-site GEMEP treatment system to
remove mercury from residual materials to concentrations below the
39 ppm RG. The clean soil cap would also reduce mobility by
preventing erosional transport of backfilled materials, which
contain residual mercury below 39 ppm.
Alternative 2 would achieve a further reduction in waste mobility
by transporting residual materials containing mercury in excess of
the 39 ppm RG to an off-site, RCRA-permitted (Subtitle C) disposal
facility without further treatment, which is designed to effectively
and permanently contain RCRA hazardous wastes. Waste toxicity and
volume would not be effectively reduced; however, the contaminated
materials would be removed from the Site as a result of off-site
disposal.
5. Short-Term Effectiveness
Both alternatives involve short-term risks during the performance
of remediation work, which are considered to be manageable through
the implementation of standard administrative, procedural, and
engineering controls. However, from a comparative standpoint, the
short-term,risks associated with Alternative 2 are considered to be
-21-
-------
lower than Alternative i based upon the anticipated duration of work
and the controls required to prevent exposure.
Short-term risks associated with Alternative 1 include worker
exposure to hazardous chemicals required for GEMEP treatment system
operation. Risks associated with residential exposure would also
exist to a lesser extent due to potential emissions resulting from
GEMEP treatment system operation. Standard administrative and
procedural controls would be employed to prevent accidents
associated with handling of process chemicals and residual wastes.
Exposure to treatment system emissions and dust would be prevented
by the implementation of engineering controls, such as water sprays.
These risks would exist for an extended period of one to two years
to implement the remedy, based upon the anticipated system
maintenance requirements (intensive), increased waste volume for
treatment, and waste characteristics (higher clay content,less
suitable for treatment).
Short-term risks associated with Alternative 2 include worker and
residential exposure to waste materials and wind-blown particulate
during off-site handling and transport. Engineering controls, such
as the use of secure shipping containers and methods, would be
implemented to prevent exposure to wastes during their off-site
transport. Dust controls, such as water or foam sprays, and
standard procedures would also be implemented to prevent exposure
associated with any off-site handling of waste. These risks would
exist for a duration of approximately three months to implement this
alternative.
6. Implementability
Alternative 1 would be difficult to implement based upon the
following factors:
o treatment of the increased volume of residual material would
require the procurement of 60 tons of iodine, in addition to the 40
tons (32 tons of iodine and 8 tons of potassium iodide)already in
G.E.'s possession, which would be difficult based upon its limited
availability on the world market;
o uncertainties associated with iodine consumption by the GEMEP
treatment process could require subsequent procurement of
additional iodine above the 60-ton estimate; and
o the increased clay content would cause frequent fouling of GEMEP
system filters, centrifuges, filter presses, and downstream
processes in general.
-22-
-------
Alternative 2 could be readily implemented using standard equipment
and services associated with transporting residual materials to a
RCRA-permitted (Subtitle C landfill), off-site disposal facility
approved by EPA.
7. Cost
Cost estimates for implementing each alternative were developed
considering direct capital costs, indirect capital costs, and
operation and maintenance costs in accordance with EPA's "Guidance
for Conducting Remedial Investigations and Feasibility Studies Under
CERCLA."
The estimated total cost of implementing Alternative 1 is
$8,810,319. This estimate considers the on-site treatment of 10,000
tons of residual material and it's subsequent backfill over a 52-week
period, and iodine losses equivalent to one percent of the total
feed material. It also includes the cost of post-closure
groundwater monitoring. The following four cases illustrate the
cost impact associated with varying key assumptions:
o Case 1 - 10,000 tons of material, 52 weeks, and 2 percent iodine
loss. Estimated total cost: $10,696,319
o Case 2 -. 10,000 tons of material, 40 weeks, and 1 percent iodine
loss. Estimated total cost: $ 7,884,433
o Case 3 - 10,000 tons of material, 70 weeks, and 1 percent iodine
loss. Estimated total cost: $10,199,045
o Case 4 - 13,000 tons of material, 52 weeks, and 1 percent iodine
, loss. Estimated total cost: $11,431,002
The estimated total cost of Alternative 2 is $3,447,522. This
estimate considers the off-site disposal of 11,600 tons of residual
material at a RCRA-permitted, Subtitle C landfill. It was assumed
that the residual materials would be loaded into Lift Liners at a
rate of 20 containers per day. The following three cases -illustrate
the cost impact associated with varying key assumptions:
o Case 1 - 11,600 tons at 10 Lift Liners per day.
Estimated total cost: $3,609,897
o Case 2 - 11,600 tons at 30 Lift Liners per day.
Estimated total cost: $3,393,811
o Case 3 - 14,600 tons at 20 Lift Liners per day.
Estimated total cost: $4,150,802
-23-
-------
8- Commonwealth Acceptance
The Commonwealth of Puerto Rico concurred with the off-site disposal
alternative in November 1998.
9- Community Acceptance
Community Acceptance is addressed in the Appendix 2 Responsiveness
Summary. In general, the community appears to have no objections
to Alternative 2.
VII. SELECTED REMEDY
Based on considerations of the requirements of CERCIA, the detailed
analysis of the alternatives, and the comments received during the
public comment period, EPA has determined that Alternative 2, off-
site disposal of mercury impacted materials in a permitted RCRA
Subtitle C hazardous waste landfill, is the most appropriate remedy
for the Site. As described, Alternative 2 would replace Alternative
1, hydrometallurgical treatment using the GEMEP system and
subsequent on-site replacement of the treated material. All other
components of the original remedy will remain the same.
Alternative 2 encompasses the complete excavation of remaining
mercury-impacted materials on the Site, including the washed coarse
material that was determined to be below the residential RG of 39
ppm and was backfilled in the West Field, as well as the-
contaminated materials remaining underneath the cold storage
building, electrical substation pads, and maintenance shop.
Off-site disposal provides the best balance of trade-offs among the
two alternatives with respect to the NCP evaluation criteria. EPA
believes Alternative 2 will provide comparable overall
protectiveness of human health and the environment, greater
implementability, fewer short-term risks, and significantly lower
costs when compared to the GEMEP treatment system and on-site
disposal of treated materials. Alternative 2 also could be
implemented within a few months and is consistent with Site-specific
cleanup levels.
VIII. STATUTORY DETERMINATIONS
Under CERCLA and the NCP, EPA's responsibility at Superfund sites
is to undertake remedial actions that achieve adequate protection
of human health and the- environment. In addition, Section 121 of
CERCLA establishes several other statutory requirements and
preferences that the selected remedy must meet. Section 121 of
CERCLA specifies that when complete, the selected remedial action
-24-
-------
for the Site must comply with ARARs established under federal and
state environmental laws unless a statutory waiver is justified.
The selected remedy also must be cost-effective and use permanent
solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable. Finally,
the statute includes a preference for remedies that employ treatment
that permanently and significantly reduces the volume, toxicity, or
mobility of hazardous wastes as their principal element. The
following sections discuss how the modified remedy meets these
statutory requirements.
1. Protection of Human Health and the Environment
The modified remedy maintains a comparable level of protection of
human health and the environment as the original remedy set forth
in the 1988 Record of Decision. Complete excavation will be
performed to remove all remaining mercury-impacted materials,
thereby achieving the residential RG of 39 ppm, as calculated in the
Baseline Risk Assessment for the Site in 1993. The modified remedy
includes the excavation of clean, washed coarse materials that were
backfilled in the West Field and contaminated materials remaining
underneath structures in the three aforementioned areas. The
removal of all Site contaminants to the established cleanup level
will mitigate the health threats posed at the Site, primarily the
i.ngestion of soil and waste by local residents, by minimizing
exposure to the mercury-impacted materials.
The off-site landfilling of all materials containing mercury in
excess of 39 ppm at an EPA-approved, RCRA-permitted (Subtitle C)
disposal facility where adequate engineering controls are provided
will permanently remove those contaminants from the Site and
encapsulate them in a secure and monitored containment system.
2. Compliance with Applicable. or Relevant and Appropriate
Requirements (ARARs)
The original analysis with respect to ARARs, as contained in the
1988 Record of Decision, held that the original remedy did comply
with all federal and state ARARs.
The key element which is changed in the modified remedy will also
comply with federal and state ARARs. The modified remedy will
comply with air emissions and Occupational Safety and Health
Administration (OSHA) requirements. In addition, the modified
remedy will comply with applicable or relevant and appropriate RCRA
requirements and/or corresponding state requirements for the
identification, transportation, storage, treatment and disposal of
hazardous waste (40 CFR Parts 261 through 264 and 268).
-25-
-------
The off-site disposal facility which is expected to be used is
located in the State of South Carolina; those State requirements for
hazardous wastes will be met by the disposal facility to the extent
applicable. All necessary approvals will be obtained prior to
disposal to ensure the excavated materials meet the facility's
permit restrictions.
3. Cost-Effectiveness
Cost-effectiveness is a critical component used in the balancing of
the evaluation criteria. With the 250 percent increase in the
estimated volume of waste requiring hydrometallurgical treatment,
the estimated total cost of the original remedy increased from
$1,912,870 (in 1988 dollars) to $8,810,3192 (in 1999 dollars). The
cost savings associated with off-site disposal, rather than on-site
treatment, was therefore a factor which eventually led to the
selection of the modifications as opposed to the original remedy.
The estimated total cost for the modified remedy, also based on the
revised waste volume estimates, is $3,447,5222.
4- Utilization of Permanent Solutions and Alternative Treatment
Technologies (or Resource Recovery Technologies) to the Maximum
Extent Practicable
This statutory determination is satisfied by the selected
modification.
EPA believes that, based on the information that was available when
the Record of Decision was issued in 1988, the original remedy
represented the maximum extent to which permanent solutions and
treatment technologies could have been used in a cost-effective
manner at the Site. We also believe that the modified remedy uses
permanent solutions and alternative treatment technologies to the
maximum extent practicable after consideration of the most recent
volumetric and cost estimates and mitigating factors associated with
the implementability of the GEMEP treatment system.
5- Preference for Treatment as a Principal Element
For the modified remedy, the preference for treatment is satisfied
since most of the materials requiring off-site disposal have already
2This cost is in addition to the costs GE has spent on the
physical separation treatment and off-site disposal of highly
concentrated wastes.
-26-
-------
*
3
undergone the physical separation phase o£ GEMEP treatment to remove
mobile mercury. Additionally, all residual materials containing
mercury concentrations in excess of 39 ppm and clean coarse
materials previously backfilled in the West Field will be
transported off-site to an EPA-approved, RCRA-permitted (Subtitle
C) disposal facility, designed to effectively and permanently
contain RCRA-hazardous wastes.
IX. DOCUMENTATION OP SIGNIFICANT CHANGE
There are no significant changes from the preferred alternative, as
presented in the Post-Decision Proposed Plan released to the public
on April 26, 1999.
-27-
-------
Oft 5001000 2000ft
APPROX. SCALE: 1'=2000'
VICINITY MAP
NOT TO SCALE
Federal Programs Corporation
A SutiUiitf ftCtmt Ortitir t UcKtt Inc.
G.E. WIRING DEVICES SITE
JUANA DIAZ, PUERTO RICO
FIGURE
1
-------
w »
'
APPENDIX 1
-------
-------
G E WIRING DEVICES SITE
ADMINISTRATIVE RECORD UPDATE
INDEX OF DOCUMENTS
5.0 RECORD OF DECISION
5.2 Amendment to the Record of Decision
p. 500001- Letter to Ms. Caroline Kwan, New York/Emergency
500013 and Remedial Response Division, U.S. EPA, Region
II, from Mr. Vijay K. Kakaria, Project Manager,
Morrison Knudsen Corporation, re: Remedial Design
Work Plan for Juana Diaz, Puerto Rico Project
GE Lighting,(attached), January 15, 1995.
p. 500014- Letter to Ms. Caroline Kwan, New York/Emergency
500015 and Remedial Response Division, U.S. EPA, Region
II, from Mr. Vijay K. Kakaria, Project Manager,
Morrison Knudsen Corporation, re: Progress Report
for February, 1995, AOC for Remedial Design,
GE Wiring Devices, Juana Diaz, Puerto Rico,
(attached), May 17, 1995.
p. 500016- Letter to Ms. Caroline Kwan, New York/Emergency
500017 and Remedial Response Division, U.S. EPA, Region
II, from Mr. Vijay K. Kakaria, Project Manager,
Morrison Knudsen Corporation, re: Progress Report
for March, 1995, AOC for Remedial Design,
GE Wiring Devices, Juana Diaz, Puerto Rico,
(attached), May 17, 1995.
P. 500018- Letter to Ms. Caroline Kwan, New York/Emergency
500019 and Remedial Response Division, U.S. EPA, Region
II, from Mr. Vijay K. Kakaria, Project Manager,
Morrison Knudsen Corporation, re: Progress Report
for April, 1995, AOC for Remedial Design,
GE Wiring Devices, Juana Diaz, Puerto Rico,
(attached), May 17, 1995.
-------
500020-
500021
500022-
500023
P.
500024-
500025
P. 500026-
500027
500028-
500029
500030-
500031
Letter to Ms. Caroline Kwan, New York/Emergency
and Remedial Response Division, U.S. EPA, Region
II, from Mr. Vijay K. Kakaria, Project Manager,
Morrison Knudsen Corporation, re: Progress Report
for May, 1995, AOC for Remedial Design, GE Wiring
Devices, Juana Diaz, Puerto Rico, (attached),
June 12, 1995.
Letter to Ms. Caroline Kwan, New York/Emergency
and Remedial Response Division, U.S. EPA, Region
II, from Mr. Vijay K. Kakaria, Project Manager,
Morrison Knudsen Corporation, re: Progress Report
for June, 1995, AOC for Remedial Design, GE Wiring
Devices, Juana Diaz, Puerto Rico, (attached),
June 30, 1995.
Letter to Ms. Caroline Kwan, New York/Emergency
and Remedial Response Division, U.S. EPA, Region
II, from Mr. Vijay K. Kakaria, Project Manager,
Morrison Knudsen Corporation, re: Progress Report
for July, 1995, AOC for Remedial Design, GE Wiring
Devices, Juana Diaz, Puerto Rico, (attached),
July 28, 1995.
Letter to Ms. Caroline Kwan, New York/Emergency
and Remedial Response Division, U.S. EPA, Region
II, from Mr. Vijay K. Kakaria, Project Manager,
Morrison Knudsen Corporation, re: Progress Report
for August, 1995, AOC for Remedial Design,
GE Wiring Devices, Juana Diaz, Puerto Rico,
(attached), September 20, 1995.
Letter to Ms. Caroline Kwan, New York/Emergency
and Remedial Response Division, U.S. EPA, Region
II, from Mr. Vijay K. Kakaria, Project Manager,
Morrison Knudsen Corporation, re:/Progress Report
for September, 1995, AOC for Remedial Design,
GE Wiring Devices, Juana Diaz, Puerto Rico,
(attached), October 11, 1995.
Letter to Ms. Caroline Kwan, New York/Emergency
and Remedial Response Division, U.S. EPA, Region
-------
II, from Mr. Vijay K. Kakaria, Project Manager,
Morrison Knudsen Corporation, re: Progress Report
for October, 1995, AOC for Remedial Design,
GE Wiring Devices, Juana Diaz, Puerto Rico,
(attached), November 30, 1995.
»' -
500032- Letter to Ms. Caroline Kwan, New York/Emergency
500033 nd Remedial Response Division, U.S. EPA, Region
II, from Mr. Vijay K. Kakaria, Project Manager,
Morrison Knudsen Corporation, re: Progress Report
for November, 1995, AOC for Remedial Design,
GE Wiring Devices, Juana Diaz, Puerto Rico,
(attached), December 5, 1995.
500034- Letter to Ms. Caroline Kwan, Project Manager, New
500035 York/Caribbean Superfund Branch II, U.S. EPA
Region II, from Mr. Tom J. Harlan, Jr.,
Environmental Specialist, General Electric
Company, re: GE Lighting Wiring Devices Site,
Juana Diaz, Puerto Rico — Monthly Report,
(attached: M&E Staffing Plan, GE Wiring Devices
Site, Juana Diaz, Puerto Rico), August 26, 1996.
500036- Letter to Ms. Caroline Kwan, Project Manager, New
500036 York/Caribbean Superfund Branch II, U.S. EPA
Region II, from Mr. Tom J. Harlan, Jr.,
Environmental Specialist, General Electric
Company, re: GE Lighting Wiring Devices Site,
Juana Diaz, Puerto Rico -- Monthly Report,
November 5, 1996.
500037- Letter to Ms. Caroline Kwan, Project Manager, New
500038 York/Caribbean Superfund Branch II, U.S. EPA
Region II, from Mr. Tom J. Harlan, Jr.,
Environmental Specialist, General Electric
Company, re: GE Lighting Wiring Devices Site,
Juana Diaz, Puerto Rico -- Monthly Report,
December 5, 1996.
500039- Letter to Ms. Caroline Kwan, Project Manager, New
500041 York/Caribbean Superfund Branch II, U.S. EPA
Region II, from Mr. Tom J. Harlan, Jr.,
Environmental Specialist, General Electric
Company, re: GE Lighting Wiring Devices Site,
Juana Diaz, Puerto Rico -- Monthly Report,
-------
500042'
500045
500046-
500046
P.
P.
P.
500047-
500051
500052-
500068
500069-
500070
P.
500071-
500071
(attached: Juana Diaz Site Remediation Schedule),
January 6, 1997.
Letter to Ms. Caroline Kwan, Project Manager, New
York/Caribbean Superfund Branch II, U.S. EPA
Region II, from Mr. Tom J. Harlan, Jr.,
Environmental Specialist, General Electric
Company, re: GE Lighting Wiring Devices Site,
Juana Diaz, Puerto Rico -- Monthly Report,
(Attached: Juana Diaz Site Remediation Schedule),
February 6, 1997.
Letter to Ms. Caroline Kwan, Project Manager, New
York/Caribbean Superfund Branch II, U.S. EPA
Region II, from Mr. Tom J. Harlan, Jr.,
Environmental Specialist, General Electric
Company, re: GE Lighting Wiring Devices Site,
Juana Diaz, Puerto Rico -- Monthly Report,
March 7, 1997.
Public Notice: "SUPERFUND REMEDIAL ACTION PUBT.Tr
MEETING STATEMENT", GE Wiring Devices, Juana Diaz,
Puerto Rico, prepared by General Electric Company,
Cleveland, OH, April 1997.
Plan: Erosion And Sm-f^ce Water Control Plan fpr
General Electric Wiring Devices Site. Juana Diaz.
Puerto Rico, prepared by Metcalf & Eddy, prepared
for the U.S. EPA, Region II, April 1997.
Letter to Ms. Caroline Kwan, Project Manager, New
York/Caribbean Superfund Branch II, U.S. EPA
Region II, from Mr. Tom J. Harlan, Jr.,
Environmental Specialist, General Electric
Company, re: GE Lighting Wiring Devices Site,
Juana Diaz, Puerto Rico — Monthly Report,
(attached: Juana Diaz Site Remediation Schedule),
April 6, 1997.
Letter to Ms. Caroline Kwan, Project Manager, New
York/Caribbean Superfund Branch II, U.S. EPA
Region II, from Mr. Tom J. Harlan, Jr.,
Environmental Specialist, General Electric
Company, re: GE Lighting Wiring Devices Site,
-------
500072-
500073
500074-
500076
500077-
500081
500082-
500083
500084-
500084
Juana Diaz, Puerto Rico—Monthly Report,
May 5, 1997.
Letter to Ms. Caroline Kwan, Project Manager, New
York/Caribbean Superfund Branch II, U.S. EPA
Region II, from Mr. Tom J. Harlan, Jr.,
Environmental Specialist, General Electric
Company, re: GE Lighting Wiring Devices Site,
Juana Diaz, Puerto Rico — Monthly Report,
June 6, 1997.
Letter to Ms. Caroline Kwan, Project Manager, New
York/Caribbean Superfund Branch II, U.S. EPA
Region II, from Mr. Tom J. Harlan, Jr.,
Environmental Specialist, General Electric
Company, re: GE Lighting Wiring Devices Site,
Juana Diaz, Puerto Rico -- Monthly Report,
(attached: June 1997 Update, Juana Diaz Site
Remediation Schedule), June 20, 1997.
Letter to Maheyar R. Billimoria, Ph.D., CDM
Federal Programs Corporation, Ms. Caroline Kwan,
U.S. EPA, Region II, and Mr. Miguel Rullan, Puerto
Rico Environmental Quality Board, from Scott R.
Smith, P.E., Metcalf & Eddy, re: GE Wiring Devices
Site-Stormwater, July 2, 1997.
Letter to Ms. Caroline Kwan, Project Manager, New
York/Caribbean Superfund Branch II, U.S. EPA
Region II, from Mr. Tom J. Harlan, Jr.,
Environmental Specialist, General Electric
Company, re: GE Lighting Wiring Devices Site,
Juana Diaz, Puerto Rico — Monthly Report,
(attached: June 1997 Update, Juana Diaz Site
Remediation Schedule), July 9, 1997.
Letter to Ms. Caroline Kwan, Project Manager, New
York/Caribbean Superfund Branch II, U.S. EPA
Region II, from Mr. Tom J. Harlan, Jr.,
Environmental Specialist, General Electric
Company, re: GE Lighting Wiring Devices Site,
Juana Diaz, Puerto Rico — Monthly Report,
August 10, 1997.
500085- Letter to Ms. Caroline Kwan, Project Manager, New
-------
500087
500088-
500093
500094-
500095
500096-
500104
500105-
500118
P.
500119-
500176
York/Caribbean Superfund Branch II, U.S. EPA
Region II, from Mr. Tom J. Harlan, Jr.,
Environmental Specialist, General Electric
Company, re: GE Lighting Wiring Devices Site,
Juana Diaz, Puerto Rico — Monthly Report,
(attached: Generalized Site Plan),
September 9, 1997.
Letter to Ms. Caroline Kwan, Project Manager, New
York/Caribbean Superfund Branch II, U.S. EPA,
Region II, from Mr. Tom J. Harlan, Jr.,
Environmental Specialist, General Electric
Company, re: GE Lighting Wiring Devices Site,
Juana Diaz, Puerto Rico-Cold Storage Building,
September 30, 1997. \
Letter to Ms. Caroline Kwan, Project Manager, New
York/Caribbean Superfund Branch II, U.S. EPA
Region II, from Mr. Tom J. Harlan, Jr.,
Environmental Specialist, General Electric
Company, re: GE Lighting Wiring Devices Site,
Juana Diaz, Puerto Rico — Monthly Report,
October 7, 1997.
Letter to Ms. Nina Kuchar, US EPA CLASS, Dyncorp
Information and Engineering Technology, Inc., from
Maheyar R. Billimoria, Ph.D., Work Assignment
Manager, CDM Federal Programs Corporation,
re: Original CLP Paperwork for RAS Case Number
25729, (attached), October 14, 1997.
Letter to Ms. Janet Trotter, RSCC Lockhead, from
Maheyar R. Billimoria, Ph.D., Work Assignment
Manager, CDM Federal Programs Corporation, re:
Sampling Trip Report for RAS Case Number 25729,
prepared by CDM Federal Programs Corporation
prepared for U.S. EPA, Region II,(attached),
October 14, 1997.
Letter to Mr. Mark Austin, Project Officer, U.S.
EPA, Region II, and Ms. Caroline Kwan-Appleman
Remedial Project Manager, U.S. EPA, Region II,
from Mr. Robert D. Goltz, P.E., ARCS II Program
Manager, CDM Federal Programs Corporation, re: Bi-
Weekly Field Oversight Progress Report, Document
-------
Control No. 7720-072-LR-CPKG, prepared by CDM
Federal Programs Corporation, prepared for U.S.
EPA, Region II, (attached), October 22, 1997.
500177- Letter to Ms. Caroline Kwan, Project Manager, New
5:00178 York/Caribbean Superfund Branch II, U.S. EPA
Region II, from Mr. Tom J. Harlan, Jr.,
Environmental Specialist, General Electric
Company, re: GE Lighting Wiring Devices Site,
Juana Diaz, Puerto Rico — Monthly Report,
November 7, 1997.
500179- Letter to Ms. Molly Boyter, US EPA CLASS, Dyncorp
500183 Information and Engineering Technology, Inc.,
Maheyar R. Billimoria, Ph.D., Work Assignment
Manager, CDM Federal Programs Corporation, re:
Original CLP Paperwork for RAS Case Number 25793,
prepared by CDM Federal Programs Corporation,
prepared for U.S. EPA, Region II,(attached),
November 11, 1997.
Letter to Mr. Mark Austin, Project Officer, US
EPA,Region II, and Ms. Caroline Kwan-Appleman,
Remedial Project Manager, U.S. EPA, Region II,
from Mr. Robert D. Goltz, P.E., ARCS II Program
Manager, CDM Federal Programs Corporation, re: Bi-
Weekly Field Oversight Progress Report, Document
Control No. 7720-072-LR-CPPD, prepared by CDM
Federal Programs Corporation, prepared for US EPA,
Region II, (attached), November 18, 1997.
500219- Letter to Sra. Clara O'Neill, Directora Interina-
500219 Area de Servicios Ambientales, Autoridad de
Acueductos y Alcantarillados, from Mr. Tom J.
Harlan, Project Manager, General Electric Company,
re: GE Wiring Devices - Superfund Site, Permit
GDG-97-405-033, dated July 9, 1977, November 24,
1997.
500220- Letter to Ms. Caroline Kwan, Project Manager, New
500221 York/Caribbean Superfund Branch II, U.S. EPA
Region II, from Mr. Tom J. Harlan, Jr.,
Environmental Specialist, General Electric
Company, re: GE Lighting Wiring Devices Site,
Juana Diaz, Puerto Rico — Monthly Report,
P. 50.0184-
500218
-------
December 5, 1997.
500228'
500261
500262-
500262
500222- Letter to Ms. Nicole Coene, US EPA CLASS, Dyncorp
500227 Information and Engineering Technology, Inc., from
Maheyar R. Billimoria, Ph.D., Work Assignment
Manager, CDM Federal Programs Corporation, re:
Original CLP Paperwork for RAS Case Number 25897,
prepared by CDM Federal Programs Corporation,
prepared for US EPA, Region II,(attached),
December 16, 1997.
Letter to Mr. Mark Austin, Project Officer, U.S.
EPA, Region II, and Ms. Caroline Kwan-Appleman,
Remedial Project Manager, U.S. EPA, Region II,
from Mr. Robert D. Goltz, P.E., ARCS II Program
Manager, CDM Federal Programs Corporation, re: Bi-
Weekly Field Oversight Progress Report, Document
Control No. 7720-072-LR-CPVF, prepared by CDM
Federal Programs Corporation, prepared for US EPA,
Region II, (attached), December 19, 1997.
Letter to Ms. Caroline Kwan, Project Manager, New
York/Caribbean Superfund Branch II, U.S. EPA,
Region II, from Mr. Tom J. Harlan, Jr.,
Environmental Specialist, General Electric, re: GE
Lighting Wiring Devices Site, Juana Diaz, Puerto
Rico -- Monthly Report, January 12, 1998.
Letter to Ms. Caroline Kwan, Project Manager, New
York/Caribbean Superfund Branch II, U.S. EPA,
Region II, from Mr. Tom J. Harlan, Jr.,
Environmental Specialist, General Electric
Company, re: GE Wiring Devices Site - Juana
Diaz,(attached: constructing a temporary pile),
January 19, 1998.
Letter to Ms. Nicole Coene, US EPA CLASS, Dyncorp
Information and Engineering Technology, Inc., from
Maheyar R. Billimoria, Ph.D., Work Assignment
Manager, CDM Federal Programs Corporation, re:
Original CLP Paperwork for RAS Case Number 25958,
(attached), January 20, 1998.
500273- Letter to Ms. Janet Trotter, RSCC Lockhead,
500263-
500265
500266-
500272
-------
500284 Maheyar R. Billimoria, Ph.D., Work Assignment
Manager, CDM Federal Programs Corporation, re:
Sampling Trip Report for RAS -Case Number 25958,
prepared by CDM Federal Programs Corporation,
prepared for US EPA, Region II,(attached),
' January 20, 1998.
500285- Letter to Mr. Mark Austin, Project Officer, U.S.
500315 EPA, Region II, Ms. Caroline Kwan-Appleman,
Remedial Project Manager, U.S. EPA, Region II,
from Mr. Robert D. Goltz, P.E., ARCS II Program
Manager, CDM Federal Programs Corporation, re: Bi-
Weekly Field Oversight Progress Report Document
Control No. 7720-072-LR-CQCY, prepared by CDM
Federal Programs Corporation, prepared for US EPA,
Region II, (attached), January 29, 1998.
500316- Letter to Ms. Caroline Kwan, Project Manager, New
5003,17 York/Caribbean Superfund Branch II, U.S. EPA
Region II, from Mr. Tom J. Harlan, Jr.,
Environmental Specialist, General Electric
Company, re: GE Lighting Wiring Devices Site,
Juana Diaz, Puerto Rico -- Monthly Report,
February 9, 1998.
500318- Letter to Ms. Nicole Coene, US EPA CLASS, Dyncorp
500322 Information and Engineering Technology, Inc., from
Maheyar R. Billimoria, Ph.D., Work Assignment
Manager, CDM Federal Programs Corporation, re:
Original CLP Paperwork for RAS Case Number 25996,
(attached), February 17, 1998.
500323- Letter to Ms. Janet Trotter, RSCC Lockhead,
500332 Maheyar R. Billimoria, Ph.D., Work Assignment
Manager, CDM Federal Programs Corporation, re:
Sampling Trip Report for RAS Case Number 25996,
prepared by CDM Federal Programs Corporation,
prepared for U.S. EPA, Region II,(attached)
February 17, 1998.
500333- Letter to Mr. Mark Austin, Project Officer, U.S.
500358 EPA, Region II, and Ms. Caroline Kwan-Appleman,
Remedial Project Manager, U.S. EPA, Region II,
from Mr. Robert D. Goltz, P.E., ARCS II Program
Manager, CDM Federal Programs Corporation, re: Bi-
-------
500359-
500359
500360-
500366
500367-
500379
500380-
500400
P.
500401-
500407
Weekly Field Oversight Progress Report, Document
Control No. 7720-072-LR-CQHN, prepared by CDM
Federal Programs Corporation, prepared for U.S.
EPA, Region II, (attached),February 24, 1998.
Letter to Ms. Caroline Kwan, Project Manager, New
York/Caribbean Superfund Branch II, U.S. EPA,
Region II, from Mr. Tom J. Harlan, Jr.,
Environmental Specialist, General Electric
Company, re: GE Lighting Wiring Devices Site,
Juana Diaz, Puerto Rico -- Monthly Report,
March 10, 1998.
Letter to Ms. Nicole Coene, US EPA CLASS, Dyncorp
Information and Engineering Technology, Inc., from
Maheyar R. Billimoria, Ph.D., Work Assignment
Manager, CDM Federal Programs Corporation, re:
Original CLP Paperwork for RAS Case Number 26044,
(attached), March 18, 1998.
Letter to Ms. Janet Trotter, RSCC Lockhead,
Maheyar R. Billimoria, Ph.D., Work Assignment
Manager, CDM Federal Programs Corporation, re:
Sampling Trip Report for RAS Case Number 26044,
prepared by CDM Federal Programs Corporation,
prepared for U.S. EPA, Region II,(attached),
March 18, 1998.
Letter to Mr. Mark Austin, Project Officer, U.S.
EPA, Region II, and Ms. Caroline Kwan-Appleman,
Remedial Project Manager, U.S. EPA, Region II,
from Mr. Robert D. Goltz, P.E., ARCS II Program
Manager, CDM Federal Programs Corporation, re: Bi-
Weekly Field Oversight Progress Report, Document
Control No. 7720-072-LR-CQLS, prepared by CDM
Federal Programs Corporation, prepared for U.,,S.
EPA, Region II, (attached), March 19, 1998. •'
Letter to Ms. Nicole Coene, US EPA CLASS, Dyncorp
Information and Engineering Technology, Inc., from
Maheyar R. Billimoria, Ph.D., Work Assignment
Manager, CDM Federal Programs Corporation, re:
Original CLP Paperwork for RAS Case Number 26161,
(attached), May 12, 1998.
10
-------
P. 500427-
500448
500408- Letter to Ms. Janet Trotter, RSCC Lockhead,
500419 Maheyar R. Billimoria, Ph.D., Work Assignment
Manager, CDM Federal Programs Corporation, re:
Sampling Trip Report for RAS Case Number 26161,
prepared by CDM Federal Programs Corporation,
prepared for US EPA, Region II,(attached),
May 12, 1998.
500420- Letter to Mr. Scott Kirchner, CDM-FPC, from
500426 Mr. John Birri, Special Projects Coordinator,
Laboratory Branch, U.S. EPA, Region II, re:
results of the GE Wiring sampling survey conducted
the week of April 6, 1998. (attached: Completed
Analysis Report for GE Wiring Devices, project
number 771), May 14, 1998.
Letter to Mr. Mark Austin, Project Officer, U.S.
EPA, Region II, and Ms. Caroline Kwan-App1eman,
Remedial Project Manager, U.S. EPA, Region II,
from Mr. Robert D. Goltz, P.E., ARCS II Program
Manager, CDM Federal Programs Corporation, re: Bi-
Weekly Field Oversight Progress Report, Document
Control No. 7720-072-LR-CQWM, prepared by CDM
Federal Programs Corporation, prepared for U.S.
EPA, Region II, (attached), May 18, 1998.
500449- Report: Lab Data Management System, re: results of
500454 the GE Wiring sampling survey conducted the week
of April 6, 1998. (attached: Completed Analysis
Report for GE Wiring Devices 771, project number
833), June 22, 1998.
500455- Letter to Mr. Scott Kirchner, CDM-FPC, from
500468 Mr. John Birri, Special Projects Coordinator,
Laboratory Branch, U.S. EPA, Region II, re:
results of the GE Wiring sampling survey conducted
the week of March 2, 1998. (attached: Completed
Analysis Report for GE Wiring Devices, project
number 832 and project number 740), June 24, 1998.
500469- Plan: Superfund Post-Decision Proposed Plan.
500481 GE Wiring Devices Superfund Site.Juana Diaz.
Puerto Rico, prepared by U.S. EPA, Region II,
March 1999.
11
-------
500482-
500586
Report: Focused Peasibi^tv Study, qg
Devices Supe-rfynd Site. Juana Diaz. Puerto-pj
prepared by Metcalf & Eddy, Inc., March 1999
12
-------
07/15/97 Index Chronological Order Page: 1
GE WIRING Documents
Doeunent Number: GEH-001-0022 To 0022 Parent: GEW-001-0018 Date: / /
Title: Juana Diaz Plant Soil Evaluation Samples: Location Sketch
Type: GRAPHIC
Author: none: none
Recipient: none: none
Document Number: GEU-001-0025 To 0025 Parent: GEW-001-0023 Date: / /
Title: Juana Diaz Plant Soil Evaluation Samples: Location Sketch
Type: GRAPHIC
Author: none: none
Recipient: none: none
Document Number: GEU-001-0158 To 0160 . Date: / /
*itle: Analytical data and field data from standpipes at the Juana Diaz site
Type: DATA
Author: none: Law Engineering Testing
Recipient: none: none
Document Number: GEW-001-0177 To 0177 Parent: GEW-001-0170 Date: / /
Title: Figure 1 • Generalized Locations of August 1982 Test Pits 1 through 12
Type: GRAPHIC
Author: none: Law Engineering Testing
Recipient: none: none
Document Number: GEW-001-0286 To 0286 Parent: GEM-001-0285 Date: / /
Title: Results of Mercury Analyses, Law Engineering Project Ho. MH2317
Type: DATA
Author: Haroneelli, Janes M.: Law Engineering Testing
Recipient: none: none
-------
07/15/97 - Index chronological Order p -
CE WIRING Documents
Document Nurfcer: GEW-001-OU8 To 0449 P,Pents QEW-001-0447 Date: / /
Title: Principles of Engineering Geology and Ceotechnlcs: Chapter 18: Earthquake, and As.ismic Design
Type: CORRESPONDENCE
Condition: INCOMPLETE
Author: Krynlne, Dirttrf P.: McGraw Hill look Conpany
Recipient: none: none
Document N«*er: GEW-001-0537 To 0537 p.rent: CEW-001-0511 Date: /"/
Title: Results of Mercury Analyses, Law Engineering Project No. MH2317
Type: PLAN
Author: MaronceUI, James M.: Law Engineering Testing
Recipient: none: none
Document Nunfcer: GEU-001-0556 To 0607
Date: / /
Title: Nap of Generalized Site Setting. Initial Assessment Findings, and other presentation materials
for a GE Wiring meeting
Type: OTHER
Author: none: none
Recipient: none: nor*
Docunent Number: GEW-001-0650 To 0651 0,te. f
Title: (News release: GE Consents to EPA order to Act on Juana Diai, P.R. Contamination)
Type: CORRESPONDENCE
Author: none: us EPA
Recipient: none: none
Document Umfcer: GEW-001-0692 To 0700 P.rent: GEW-001-0689 Date: / /
Title: Data Report Notice and Report of Data
Type: PLAN
Author: Scanmell. Diana A.: CocrpuChem
Recipient: Nell, Larry A.: Law Engineering Testing
-------
07/15/97 Index Chronological Order Page: 3
CE UIRING Documents
Document Number: GEU-001-0759 To 0765 Parent: GEW-001-0758 Date: / /
Title: Community Relations Plan, General Electric Company, Juana Diaz Plant
Type: PLAN
Author: none: none
Recipient: none: none
Document Number: GEW-001-0767 To 0767 Parent: GEW-001-0766 Date: / /
Title: Remedial Investigation Work Plan Projected Schedule
Type: PLAN
Author: none: none
Recipient: none: none •
Document Number: GEU-001-0774 To 0774 Parent: GEW-001-0770 Date: / /
Ftle: Table 2, Comparative Analyses of Soil Samples for Mercury Concentration
Type: DATA
Author: none: none
Recipient: none: none
Document Number: GEW-001-0776 To 1210 Parent: GEU-001-0775 Date: / /
Title: Remedial Investigation Report for General Electric Wiring Devices Site, Juana Diaz, Puerto
Rico
Type: REPORT
Condition: MARGINALIA
Author: none: Law Engineering Testing
Recipient: none: General Electric
Document Number: GEW-001-1317 To 1323 Parent: GEW-001-1316 Date: / /
Title: Document No. 1 - Work Plan for Supplemental Soil Sampling, General Electric Company Wiring
Devices Facility, Juana Diaz, Puerto Rico
Type: PLAN
Author: none: none
pient: none: none
-------
07/15/97
Index Chronological Order
GE WIRING Documents
Doctmnt Nurber: GEW-001-1324 To 1326
Parent: GEW-001-1316
Date: / /
Title: Document Ho. 2 - Work Plan for PCB Analyse,, General Electric Company wiring Devices Facility
Jusna Diaz, Puerto Rico
Types PIAM
Author: none: none
Recipient: none: none
Document Number: GEW-001-2220 To 2227 perent: GEW-001-2218 Date: / /
Title: Interim Guidance on Compliance with Applicable or Relevant and Appropriate Requirements
Type: PLAN
Condition: DRAFT
Author: none: none
Recipient: none: none
ocuflent Number: CEW-001-02B8 To 0384
Title: Sumary of ConpuChem data
Parent: CEW-001-02B7
Type: DATA
Author: gloom, Richard L.: Mead ConpuChem Laboratory
Recipient: Maroncelli, James M.: Law Engineering Testing
Date: / /
Page:
Document Number: GEU-001-2209 To 2209 Parent: GEW-001-2199
Title: Proposed Renedy Selection Process Under Reauthorization Chart
Type: GRAPHIC
Author: none: none
Recipient: none: none
Date: / /
Bocusent Number: GEW-001-0012 To 0013
Parent: GEW-001-0011
Date: 10/21/76
Titles Resource Conservation and Recovery Act, Public law 94-580, as amended by the Quiet Coranunities
Act of 1978
Type: LEGAL DOCUMENT
Author: none: us EPA
ecipient: none: none
-------
Fj7/15/97 Index Chronological Order Page: 5
GE WIRING Documents
Document Number: GEU-001-0001 To 0001 Date: 06/12/79
Title: (Memorandum re: Mercury Sampling)
Type: CORRESPONDENCE
Author: Figueroa, Solange I.: General Electric
Recipient: Poland, J.B.: General Electric
Attached: GEU-001-0002 GEW-001-0004 GEU-001-0006 6EU-001-0009
Document Number: GEU-001-0002 To 0003 Parent: GEU-001-0001 Date: 06/18/79
Title: (Memorandum re: Mercury Sampling on 6/16/79)
Type: CORRESPONDENCE
Author: Figueroa, Solange I.: General Electric
Recipient: Poland, J.B.: General Electric
Document Number: GEW-001-0006 To 0008 Parent: GEU-001-0001 Date: 06/20/79
tie: (Memorandum re: Mercury Sampling - Follow Up)
Type: CORRESPONDENCE
Author: Figueroa, Sotange I.: General Electric
Recipient: Poland, J.B.: General Electric
Document Number: GEU-001-0009 To 0010 Parent: GEU-001-0001 Date: 06/22/79
Title: (Memorandum re: Mercury Button Handling, Plating Area, Juana Diaz)
Type: CORRESPONDENCE
Author: Figueroa, Solange I.: General Electric
Recipient: Poland, J.B.: General Electric
Document Number: GEW-001-0011 To 0011 Date: 06/25/79
Title: (Memorandum re: Juana Diaz Plating Area Situation)
Type: CORRESPONDENCE
Author: Figueroa, Solange 1.: General Electric
Recipient: Poland, J.S.: General Electric
Attached: CEW-001-0012
-------
*3H10 :
suuoj isanb*y *»3jAj»s i«3joAjtu
6Z/SO/01 :»J«0 8lOO-tOO-fl30 uu»jtd 1200
s»13
U3»l:
uoii«n]»A3 ][os jutH :aj
6///E/60 ••»*«o /too 01 zioo-ioo-nsa :
9ioo-Loo-n3a stoo-ioo-nas
3}j)3ai3 i»jaus9 :*s
3ua3»13 11
C'S'd 'ZIIQ euenp . uotjtutu«juo3 jios
6//91/80 :»J»a ^100 01 9lOO-lOO-n3D s
(*»ldu«
6//61/ZO s»»«0 nOO-lOO-fl39 :»u»JBd gtOQ 01 SIOO-LOO-/130 :
auou :«uou
~~ 3iui3«]3 IUMMO :*uou
VIVO
6Z/31//0 s»J«a nOO-lOO-H30 :>u»atd 9100 01 9100-100-W33
********************************:
33
x«pu|
-------
07/15/97 Index Chronological Order Page: 7
GE WIRING Document*
Document Number: GEW-001-0018 To 0019 Date: 10/11/79
Title: (Letter re: Juana Diaz Plant Soil Evaluation Samples)
Type: CORRESPONDENCE
Author: Figueroa, Solange I.: General Electric
Recipient: Faliu, Leo: General Electric
Attached: GEW-001-0020 GEW-001-0022
Document Number: GEW-001-0024 To 0024 Parent: GEU-001-0023 Date: 10/24/79
Title: Environmental Analysis of Mercury contained in soil samples received 10/12/79
Type: DATA
Author: none: General Electric
Recipient: none: General Electric
Document Number: GEU-001-0023 To 0023 ,' Date: 11/02/79
ritle: (Letter re: Laboratory Analysis of the Juana Diaz Plant Soil)
Type: CORRESPONDENCE '
Author: Figueroa, Solange I.: General Electric
Recipient: Schauseil, Robert I.: General Electric
Attached: GEW-001-0024 GEW-001-0025
Document Number: GEW-001-04SO To 0502 Date: 11/02/80
Title: (Letter re: Attached Report of Clay Continuity Study, Waste Fill Area, Juana Diaz Plant, Puerto
Rico, Lau Engineering Project No. HH1367)
Type: CORRESPONDENCE
Author: Geraond, Bart J.: Law Engineering Testing
Recipient: Schauseil, Robert I.: General Electric
Document Number: GEW-001-0026 To 0046 Date: 04/22/81
Title: Field notes «ade by W.J. Alexander during auger borings and test pit excavations at the West
Field Site
Type: OTHER
Author: Alexander, W. Joseph: Law Engineering Testing
Recipient: none: none
-------
J7/15/97
Index Chronological Order
GE WIRING Documents
Page: 8
***********
*******************
Document Number: GEU-001-0047 To 0047
TWt: (Certificate of Analysis for eight water sanples received M/30/81)
'Type: DATA
Author: illegible: Stewart Laboratories
Recipient: Phillip.. J.M.: General Electric
************************Knfnmmnmnfx
Date: 05/19/81
: CEU-001-0505 To 0508 D.te: w/05/8,
Title: notification of Hazardous Waste Site: General Electric Conpany • wiring Devices Department
Type: OTHER
Author: Schauseil, Robert 1.: General Electric
Recipient: Frisco. John S.: US EPA
Oocuwnt NiMber: GEW-001-0099 To 0099 , p.rent: GEu-001-0048
Title: {Certificate of Analysis on two samples of waste material)
Type: DATA
Author: illegible: Stewart Laboratories
Recipient: Phillips, J.M.: General Electric
Date: 06/18/81
Ooomnt Nu*er: CEU-001-05M To 0504 Ptrent: CEW.0oi-0503
Tittt: Certificate of Analysis (for two sanples of waste material)
Type: LEGAL DOCUMENT
Author: illegible: Stewart Laboratories
Recipient: Phillip*. Marvin: General Electric
Date: 06/18/81
Oocimnt Ninber: CEU-001-OW8 To 0098
Date: 06/19/81
Tftlt: (Letter re: Attached Report Subnittal. Hydrogeologic Investiflatigation, Waste Fill Area Juana
Diaz. Puerto Rico, Law Engineering Job Hunter HH1223)
Type: CORRESPOTOEHCE
Author: Alexander. U. Joseph: Law Engineering Testing
Recipient: Phillips. J.H.: General Electric
Attached: GEU-001-0099
-------
07/15/97 Index Chronological Order p.ge: 9
GE WIRING Documents
Document Number: CEW- 001 -0503 To 0503 Date: 10/30/81
Title: (Letter re: Amendment to the June 19th Report, Hydrogeologic Investigation Waste Fill Area,
Juana Diaz Plant, Puerto Rico, Law Engineering Job Ho. MH1223)
Type: CORRESPONDENCE
Author: Germond, Bart J.: Law Engineering Testing
Recipient: Schauseil, Robert 1.: General Electric
Attached: GEW-001-0504 .
Document Number: GEU-001-0100 To 0150 Date: 11/02/81
Title: (Letter re: Attached Report of Clay Continuity Study, Uaste Fill Area, Juana Diaz Plant, Puerto
Rico, Law Engineering Project No. MH1367)
Type: CORRESPONDENCE
Condition: MARGINALIA
Author: Germond, Bart J.: Law Engineering Testing
Recipient: Schauseil, Robert I.: General Electric
Document Number: GEW-001-0151 To 0152 Date: 01/27/82
Title: -(Letter re: EPA's review of comments regarding Law Engineering Testing Company's Clay Continuity
Report)
Type: CORRESPONDENCE
Author: Frisco, John S.: US EPA
Recipient: Phillips, Marvin: General Electric
Document Number: CEU-001-0509 To 0510 Date: 01/27/82
Title: (Letter re: U.S. EPA's comments on Law Engineering Testing Company's Continuity of Clay Report) .
Type: CORRESPONDENCE
Author: Frisco, John S.: US EPA
Recipient: Phillips, Marvin: General Electric
-------
07/15/97
Index Chronological Order
GE WIRING Documents
Oocunent Nuiber: GEW-001-0554 To 0554
Title: Water Analyst Report (for sample* received 01/28/82)
Type: DATA
Author: illegible: Caribtec Laboratories
Recipient: none: none
Date: 02/04/82
Page: 10
Oocunent Wueber: GEW-001-0153 To 0157 Oate. 02/15/82
Title: Attachment 2-5 Certified Laboratory Results (water samples from selected standpipes)
Type: DATA
Author: illegible: Omni Research Incorporated
Recipient: none: General Electric
Oocunent Nunber: GEU-001-0161 To 0162
Date: 02/19/82
Title: (Letter re: Water Level Monitoring Program, Waste Fill Area, Juana Diaz Plant, Puerto Rico,
Law Engineering Project No. HH1440)
Type: CORRESPONDENCE
Author: Germond, II. Bart J.: Law Engineering Testing
Recipient: Marques, Jose A.: General Electric
Document Hunber: GEW-001-0163 To 0165
Date: 02/23/82
Title: (Letter re: Response to U.S. EPA'S Review. Juana Diaz, Puerto Rico Study, by Mr. John S. Frisco,
Chief, Hazard Assessment Section, Law Engineering Project Wo. MH1367)
Type: CORRESPONDENCE
Condition: HISSING ATTACHMENT
Author: White, Robert M.: Law Engineering Testing
Recipient: Phillips. Marvin: General Electric
-------
'/15/97
Index Chronological Order
GE WIRING Documents
Page: 11
••••••••••*••••••«»••••••••**•*•••••••••••««•••••••••*»*•«»••»•••••«»•••«•••••••••••*«•«••
Document Number: GEU-001-0168 To 0169
Title: (Letter re: General Electric Juana Diaz)
Type: CORRESPONDENCE
Condition: MARGINALIA
Author: de la Cruz, Luis E: PR Environmental Duality Board
Recipient: Colon, Javier: General Electric
Date: 03/04/82
Document Number: GEU-001-0549 To 0549
Parent: GEW-001-0511
Date: 04/21/82
Title: Sampling Trip Report (at Juana Diaz site for sampling trip on 04/19/82 and 04/21/82 and stating
"measurement* taken with Bachrach Mercury Sniffer along fence perimeters- No mercury detected")
Type: PLAN
Condition: MISSING ATTACHMENT
Author: Lipsky, David: US EPA
Recipient: none: none
Toeument Number: GEU-001-0166 To 0167
Date: 05/18/82
Title: (Letter re: Questions and answers from the March 4, 1982 letter that raised concerns about
the Clay Continuity Report and Nydrogeologic Study)
Type: CORRESPONDENCE
Condition: MARGINALIA
Author: de la Cruz, Luis E.: PR Environmental Quality Board
Recipient: Colon, Javier: General Electric
Document Number: GEU-001-0511 To 0549 Date: 08/04/82
Title: Hazardous Ranking System Scores Package: General Electric - Wiring Devices of Puerto Rico
Type: OTHER
Author: Lipsky, David: US EPA
Recipient: none: none
Attached: GEU-001-0537 GEW-001-0549
-------
8unt*l
CLO*4l£ZHH -ON »3*fojd 6u}j**u)Su3
put Aiinuijuog At,3 ,<803
:•! aarut
ouand •«»»$ zt|
-------
J7/15/97 Index Chronological Order Page: 13
6E WIRING Documents
mmmm***m
Docuwnt Number: GEW-001-0197 To 0197 Date: 11/05/82
Title: (Letter re: General Electric, Juana Diaz Site, P.R.)
Type: CORRESPONDENCE
Author: Jernigan, Bruce L.: Law Engineering Testing
Recipient: Castillo, Luis Vasquez: Vazquez Agrait, Vazquez 'CastiIlo I Caspian
Document Nusber: GEW-001-0220 To 0230 Parent: 6EW-001-0218 Date: 11/17/82
Title: (Copies of driller's logs for the monitoring wells recently installed from 10/03/82-11/17/82)
Type: OTHER
Condition: ILLEGIBLE
Author: none: Caribbean Soil Testing Company •
Recipient: none: none
unent Number: GEW-001-0198 To 0217 Date: 11/22/82
Title: (Letter re: Attached Status Report of Hydraulic Conditions. Perched-Water Table; Waste Fill
Area, Juana Diaz Plant, Puerto Rico, Law Engineering Project No. MHU40.03)
Type: CORRESPONDENCE
Author: Alexander, W. Joseph: law Engineering Testing
Neal, Larry A.: Law Engineering Testing
Recipient: Schauseil, Robert I.: General Electric
Document Number: GEW-001-0553 To 0553 Date: 12/09/82
Title: (Letter re: Receipt of November 29, 1982 letter)
Type: CORRESPONDENCE
Author: Schauseil, Robert 1.: General Electric
Recipient: de la Cruz, Luis E.: PR Environmental Quality Board
-------
» i
07/15/97
Index Chronological Order
GE WIRING Documents
Docunent Nmber: GEU-001-0219 To 0219 Parent: GEH-001-0218
Tftle: (Letter re: Enclosed copy of the original test boring field logs)
Type: CORRESPONDENCE
Author: Ramirez, Hector Laverone: Caribbean Soil Testing Company
Recipient: Schauseil. Robert I.: General Electric
Page: 14
Date: 12/10/82
Document Hunter: CEU-001-0218 To 0218
Title: (Letter re: Enclosed copies of Driller's Logs)
Type: CORRESPONDENCE
Author: Schauseil, Robert I.: General Electric
Recipient: de la Cruz, Luis E.: PR Environmental Quality Board
Attached: GEU-001-0219 GEU-001-0220
Date: 12/13/82
Document Number: GEW- 00 1-0231 To 0233 Date: 12/20/82
fitle: Permeability test results from boring locations MW-2 and MW-4 taken 12/13/82-12/20/82
Type: DATA
Author: O'Kelly, M.: Law Engineering Testing
Recipient: none: none
Document Number: GEU-001-0550 To 0552
Date: 12/22/82
Title: (Letter re: Response to December 16, 1982 letter relating to the inclusion of the Juana Diaz
site as a priority project)
Type: CORRESPONDENCE
Author: DeSorbo, L.A.: General Electric
Recipient: Madera, Jose R.: PR Economic Development Administration
Document Nusber: GEU-001-0234 To 0242
Title: (Letter re: Attached Chemical Analyses on the Water and Sediment Samples)
Type: CORRESPONDENCE
Author: Naroneelli, James M.: Law Engineering Testing
Recipient: Alexander, U. Joseph: Law Engineering Testing
Date: 01/11/83
-------
07/15/97 -Index Chronological Order Page: 15
GE WIRING Document*
Document Number: GEU-001-0243 To 0245 Date: 01/13/83
Title: (Letter re: Attached Brief Statement on analyses of data gathered on the Hydrogeologic Investigation)
Type: CORRESPONDENCE
Author: Long, David T.: HI State University -
Recipient: Jernigan, Bruce L.: Law Engineering Testing
Document Number: GEW-001-0246 To 0284 Date: 01/27/83
Title: Presentation materials used by GE and Law Engineering Testing Company
Type: OTHER
Author: none: none
Recipient: none: none
Document Number: GEW-001-0553 To 0555 Date: 01/27/83
itle: Handwritten list of attendees to GE meeting
Type: OTHER
Author: none: none
Recipient: none: none
Document Number: GEU-001-0608 To 0608 Date: 02/08/83
Title: (Letter re: On-site disposal of hazardous and/or toxic wastes) -
Type: CORRESPONDENCE
Author: Madera, Jose R.: PR Economic Development Administration
Recipient: DeSorbo, L.A.: General Electric
Document Number: GEU-001-028S To 0285 Date: 02/24/83
Title: (Letter re: Results of Mercury Analysis, Juana Diaz Plant, Puerto Rico, Law Engineering No.
MH2317)
Type: CORRESPONDENCE
Author: Alexander, W. Joseph: Law Engineering Testing
Recipient: Frist, Janes T.: General Electric
Attached: GEW-001-0286
-------
07/15/97 Index Chronological Order Page: 16
GE WIRING Documents
*********************************************
Doctnent Nunber: GEU-001-0609 To 0609 Date: 02/24/83
Titli: (Letter n: Results of Ntrcury Analysts, Juana Oiaz Plant, Puerto Rico, Law Engineering Projtct
No. HH2317)
Type: CORRESPONDENCE
Condition: MISSING ATTACHMENT
Author: Alexander, W. Joseph: Law Engineering Testing
Recipient: Friss, James 7.: General Electric
document Nuaber: GEH-001-0610 To 0611 Date: 02/25/83
Title: (Letter re: Comment» on Proposed Amendment to National Oil and Hazardous Substance Contingency
Plan; the National Priorities List, 47 Federal Register 5«,«76, December 30, 1982)
Type: CORRESPONDENCE
Author: Schauseil, Robert I.: General Electric
Recipient: Wytr, Russell H.: US EPA
Document Ninfcer: GEU-001-02B7 To 0287 Date: 03/09/83
Title: (Letter re: Attached summary of CompuChem data)
Type: CORRESPONDENCE
Author: none: Mead CompuChem Laboratory
Recipient: Maroncelli, James H.: Law Engineering Testing
Attached: GEU-001-0288
Document Number: GEU-001-0385 To 0386 Date: 03/11/83
Title: (Letter re: Attached results of chemical analyses soil samples)
Type: CORRESPONDENCE
Author: Maroncelli, Janes M.: Law Engineering Testing
Recipient: Alexander, W. Joseph: Law Engineering Testing
-------
07/15/97 Index Chronological Order r*i
-------
07/15/97 Index Chronological Order Page: 18
GE WIRING Documents
Document Nunber: GEU-001-0434 To 0643 Date: 05/25/83
Title: (Letter re: Seisnic Risk of the Proposed Encapsulation Alternative. Uaste Fill Area, Item
1 of Proposal Mo. MS3022.20, Law Engineering Project No. UM3233)
Type: CORRESPONDENCE
Author: Parker, Nark: Law Engineering Testing
Recipient: Schauaeil. Robert I.: General Electric
Docinent Nunbtr: GEU-001-0612 To 0612 Date: 05/27/83
Title: (Letter re: General Electric Wiring Devices, Jumna Diaz, Puerto Rico)
Type: CORRESPONDENCE
Author: Unpierre, Victor R.: PR Economic Development Administration
Recipient: Diamond, Larry: US EPA
Attached: CEU-OD1-0613
Document Nutter: GEW-001-0444 To 0446 Date: 06/06/83
Title: (Letter re: Flooding Analyses, Juana Diaz Site, Puerto Rico, Reference Proposal HS3022.20
Clt«a2>, Law Engineering Project No. WH3233)
Type: CORRESPONDENCE
Author: Lawing, Raymond J.: Law Engineering Testing
Recipient: Schauseil, Robert I.: General Electric
Document Ninber: GEU-001-0447 To 0447 - Date: 07/19/83
Title: (Letter ra: Intensity of Earthquakes, Law Engineering Project No. UH3233>
Type: CORRESPONDENCE
Author: Alexander, U. Joseph: Law Engineering Testing
Recipient: Schauseil, Robert I.: General Electric
Attached: CEU-001-0448
Document Hunter: GEU-001-0615 To 0615 Parent: CEU-001-06U Date: 08/04/83
Title: (Letter re: Immediate action for proper disposal of mercury contaminated wastes)
Type: CORRESPONDENCE
Author: Kadera, Jose R.: PR Economic Development Administration
Recipient: Rivera, Ignacio: General Electric
-------
'J7/15/97 Index Chronological Qrcter P9ge.
GE WIRING Documents
Document Nunber: GEW-001-06U To 0614 Date: 09/28/83
Title: (Letter re: On-site encapsulation of toxic wastes)
Type: CORRESPONDENCE
Author: Nadera, Jose R.s PR Economic Development Administration
Recipient: Rivera, Ignacio: General Electric
Attached: GEU-001-0615
Document Number: GEU- 001 -0616 To 0620 , Oate: 10/07/83
Title: (Letter re: Evaluation of hazardous sites in Puerto Rico for inclusion on the National Priorties
List)
Type: CORRESPONDENCE
Author: Librlzzl, William J.: US EPA
Recipient: Kadera. Jose R.: PR Economic Development Administration
Document Number: GEW-001-0645 To 0646 Date: 12/15/83
Title: Resolution and notification (written in Spanish)
Type: LEGAL DOCUMENT
Author: Gelabert, Pedro A.: PR, Connonwealth of
Recipient: none: General Electric
Document Number: GEW-001-0621 To 0643 Date: 01/16/84-
Title: Administrative Order on Consent (regarding actions end studies to be done at Juana Diaz site)
Type: LEGAL DOCUMENT
Condition: MARGINALIA
Author: Schafer, Jacqueline E.: US EPA
Recipient: Vineyard, William: General Electric
Attached: GEW-001-0644
Document Number: GEW-001-0647 To 0649 Date: 01/27/84
Title: (Letter re: Complete removal of toxic wast* from the site)
Type: CORRESPONDENCE
Author: Madera, Jose R.s PR Economic Development Administration
Recipient: Rivera, Ignacio: General Electric
-------
J
•\
J7/15/97 Index Chronological Order paae: 20
GE WIRING Documents
Document Number: GEW-001-0644 To 0644 . Parent: GEW-001-0621 Date: 02/01/84
Title: (Public Notice re: General Electric Company entering Into Administrative order on Consent)
Type: CORRESPONDENCE
Author: Carlos, O'Neil: us EPA -1 -
Recipient: none: none
Document Number: GEW-OD1-0652 To 0652 ' Date: 02/03/84
Title: (Public notice re: Administrative Order on Consent (written in Spanish))
Type: CORRESPONDENCE
Author: none: El Nuevo Dia
Recipient: none: none
Document Number: GEW-001-0653 To 0653 Date. 02/07/84
Title: (Newspaper article titled: "GE Will Cleanup Juana Diaz site where Toxic Waste Was Dumped")
Type: CORRESPONDENCE
Author: Chigliotty, Julio: San Juan star
Recipient: none: none
Document Number: GEU-001-0654 To 0654 Oate: 02/13/84
Title: (Newspaper article titled: "PA Exige GE Limpie Vertedero en Juana Oiaz")
Type: CORRESPONDENCE
Author: none: El Hundo, San Juan
Recipient: none: none
Document Nunber: GEW-OD1-0655 To 0656 Date: 02/15/84
Title: (Article titled: "GE Will Cleanup Waste Disposal Site: Conpany signs consent order with EPA
to attend to 27-year-old Juana Diaz dump")
Type: CORRESPONDENCE
Author: Eehavarri. Christian M.: Carribean tusiness .
Recipient: none: none
-------
57/15/97 Index Chronoloflical Order p.ge: 21
GE WIRING Docunents
Document Nuwber: GEW-001-0657 To 0659 Oate: 03/09/84
Title: (Letter re: General Electric Company, EPA Order on Con»ent, Index Mo. II CERCLA-30301. To
Clean Up Juana Diaz Plant Site)
Type: CORRESPONDENCE
Condition: MISSING ATTACHMENT
Author: Madcra, Jose I.: M Economic Dev«lopnent Administration
Recipient: none: US EPA
Document Number: GEW-001-0661 To 0663 Parent: GEW-001-0660 Date: 06/01/84
Title: Response to comments on Administrative order
Type: PLAN
Author: none: US EPA
Recipient: none: none
Document Number: GEU-001-0004 To 0005 Parent: GEU-001-0001 Date: 06/19/84
Title: (Memorandum re: Ground Samples/Mercury Percent)
Type: CORRESPONDENCE
Author: Figueroa, Solange 1.: -General Electric
Recipient: Gulp, Dale: General Electric
Document Number: GEW-001-0660 To 0660 . Date: 07/16/84
Title: (Letter re: EPA's response to the public comments received on Order No. II-CERCLA-30301)
Type: CORRESPONDENCE
Condition: MISSING ATTACHMENT
Author: Dewling, Richard T.: us EPA
Recipient: Vineyard, William: General Electric
Attached: GEW-001-0661
-------
07/15/97 Index Chronological Order Page: 22
CE WIRING Documents
Oocunent Nuriser: GEW-001-2237 To 2283 Date: 09/01/84
Title: Health Effects Assessment for Mercury
Type: PLAN
Author: none: IK EPA
Recipient: none: none
Document Number: GEU-001-0691 To 0691 Parent: GEw-001-0689 Date: 01/22/85
Title: (Letter re: Suwnary of data from requested sample analysis)
Type: CORRESPONDENCE
Author: Carrington, Pamela S.: CompuChem
Recipient: Neil, Larry A.: Law Engineering Testing
Document Number: GEW-001-0665 To 0686 Parent: GEW-001-0664 Date: 03/11/85
Title: Work Plan for Remedial Investigation, Mercury Waste Site, Juana Diaz, Puerto Rico
Type: PLAN
Author: none: Law Engineering Testing
Recipient: none: General Electric
Document Number: GEW-001-0690 To 0690 Parent: GEw-001-0689 Date: 03/19/85
Title: (Letter re: Analytical Results of Priority Pollutant, Analysis of Water Sample from Stand-Pipe
No. 11, General Electric Juana Diaz Facility)
Type: CORRESPONDENCE
Author: Heal, Larry A.: Law Engineering Testing
Shugart, Steven L.: Law Engineering Testing
Recipient: Sehauaeil, Robert 1.: General Electric
Document Nuaber: GEW-001-0664 To 0664 Date: 03/26/85
Title: (Letter re: K Wiring Device Site. Juana Diaz, Puerto Rico)
Type: CORRESPONDENCE
Author: Kaplan, Arthur L.: General Electric
Recipient: Font, Jose C.: US EPA
Attajehed: GEW-001-0665
-------
•15/97
Index Chronologies! Order
GE WIRING Documents
Page: 23
Date: 04/09/85
mmmmmmmmmmmmmmmm»mmmmmmmmmmmmmmm**mm «••••••••••••••«••••»•««•••«•*••••••«•*•
Document Kuaber: GEU-001-0687 To 0686
Title: (Letter re: Request for data on ground-water wells in the vicinity of Juana Diaz. Puerto Rico)
Type: CORRESPONDENCE
Author: Shugart, Steven 1.: Leu Engineering Testing
Recipient: Font, Jose C.: US EPA
Document Number: GEU-001-0689 To 0689
Date: 04/24/85
Title: (Letter re: Analytical Results of Priority Pollutant Analysis of Water Sample from Stand-Pip*
No. 11. General Electric Juana Diaz Facility)
Type: CORRESPONDENCE
Author: Mart, Steven W.: Law Engineering Testing
Recipient: Font, Jose C.: US EPA
Attached: GEW-001-0690 GEW-001-0691 GEW-001-0692
eument Number: GEW-001-0722 To 0729 Parent: GEW-001-0701
:le: (Utter re: Report for analysis of sample from monitoring well No. 1)
Type: CORRESPONDENCE
Author: Scamnell, Diana A.: CompuChem
Recipient: Neil. Larry A.: Law Engineering Testing
Date: 08/22/85
Document Hunter: GEW-001-0730 To 0737 Parent: GEU-001-0701
Title: (Letter re: Report for analysis of sample from monitoring well No. 2)
Type: CORRESPONDENCE
Author: Scanmell. Diana A.: CompuChem
Recipient: Neil, Larry A.: Law Engineering Testing
Date: 08/22/85
Document Number: GEW-001-0738 To 0745 Parent: GEW-001-0701 Date: 08/22/85
Title: CLetter re: Attached report for analysis of sample from aonitoring well No. 3)
Type: CORRESPONDENCE
Author: Scanned, Diana A.: CompuChem
Recipient: Neil, Larry A.: Law Engineering Testing
-------
j!
"I
17/15/97 • Index Chronological Order
Page: 24
G£ WIRING Oocunents
Document Number: GEW-001-0746 To 0753 Parent: GEU-001-0701 Date: 08/22/85
Title: (Letter re: Attached analysis results of sanplc from monitoring well Mo. *>
Type: CORRESPONDENCE
Author: Scaomeli. Diana A.: CoapuCtiem
Recipient: Neil, Larry A.: Law Engineering Testing
Document Number: GEU-001-0754 To 0754 Oate. 10/29/85
Title: (Letter re: Review of possible trichloroethylene contamination at Juana Diaz site)
Type: CORRESPONDENCE
Condition: HISSING ATTACHMENT
Author: Kaplan, Arthur L.: General Electric
Recipient: Font. Jose C-: US EPA
Attached: GEU-001-0755 GEU-001-0756
Doctmnt Number: GEW-001-0755 To 0755 Parent: GEw-001-0754 Date: 12/13/85
ftle: (Letter re: Proposed Schedule of Soil Sairpling for Trichloroethylene, G.E. Juana Diaz, Puerto
Rico Plant)
Type: CORRESPONDENCE
Author: Neil, Larry A.: .Law Engineering Testing
Recipient: Font, Jose C.: US EPA
Document Number: GEW-001-0756 To 0756 Parent: CEU-001-.07W Date: 01/10/86
Title: (Letter re: Revised Schedule of Soil Sampling for Trichloroethylene, G.E. Juana Diaz, Puerto
Rico Plant)
Type: CORRESPONDENCE
Author: Spiers, Charles A.: Law Environmental Services
Recipient: Font, Jose C.: US EPA
-------
37/15/97 Index Chronological Order Page: 25
GE WIRING Documents
Document Number: GEW- 001 -2194 To 2198 Date: 06/15/86
Title: (Memorandum res Discharge of Wasteuater from CERCLA Sites into POTWS)
Type: CORRESPONDENCE
Condition: MARGINALIA
Author: Longest, II, Henry L.: US EPA
Recipient: none: US EPA
Document Number: GEW-001-0757 To 0757 Date: 05/05/86
Title: (Letter re: Revised Work Plan for Remedial Investigation, G.E. Wiring Devices Site, Juana
Diaz, Puerto Rico)
Type: CORRESPONDENCE
Author: Czapor, John V.: US EPA
Recipient: Kaplan, Arthur L.: General Electric
^^Vo
locunent Number: GEU-001-0771 To 0772 Parent: GEW-001-0770 Date: 06/01/86
Title: Table 1, Mercury Concentration, General Electric • Juans Diaz
Type: DATA
Author: none: none
Recipient: none: none
Document Number: GEW-001-0758 To 0758 - Date: 06/03/86
Title: Favor De Finnar (handwritten list of names, organization and addresses), General Electric
Wiring Devices
Type: OTHER
Author: none: none
Recipient: none: none
Attached: GEW-001-0759
-------
07/15/97 Index Chronological Order ftge.
GE WIRING Documents
Document Number: CEW-001-D766 To 0766 0,tt: 06/18/86
Title: (Letter re: Revised Work Plan for Remedial Investigation, C.E. Uirina Devices Site, Juana
Diaz, Puerto Rico)
Type: COMESPO®£ircE
Author: Kaplan, Arthur l.t General Electric
Recipient: Czapor. John V.: US EPA
Attached: GEW-001-0767
Document Number: GEU-001-0768 To 0769 Date. 08/20/86
Title: (Letter re: Notification of Time Extension, G.E. Wiring Devices Site, Juana Diaz, Puerto Rico)
Type: CORRESPONDENCE
Author: Kaplan, Arthur L.: General Electric
Recipient: Czapor, John V.: US EPA
Document Number: GEU-001-1633 To 1851 D-te: 09/01/86
Title: OC Package for Project 6331 - GE/Juana Diaz, July, August, and Septentwr, 1986
Type: DATA
Condition: MARGINALIA
Author: none: none
Recipient: none: none
Attached: CEU-001-1852
Docimnt Nirfcer: GEU-001-0773 To 0773 Parent: GEW-001-.0770 Date: 09/11/86
Title: (Letter re: Analyses of soil sanples sent to Oxford Laboratories, Inc., for conparative Mercury
study by Cold Vapor Technique)
Type: CORRESPONDENCE
Author: Tersegno, Vincent J.: Law Environmental Services
Recipient: Sellers, Mark A.: Law Engineering Testing
-------
07/15/97 Index Chronological Order Page: 27
CE WIRING Documents
Document Number: GEW-001-0770 To 0770 Date: 09/23/86
Title: (Letter r»: G.E. Wiring Devices Site, Juana Diaz, P.R., CERCLA *106 Order)
Type: CORRESPONDENCE
Author: Kaplan, Arthur L.: General Electric
Recipient: Font, Jose C.: US EPA
Attached: GEW-001-0771 GEW-001-0773 GEW-001-0774
Document Number: GEW-001-0775 To 0775 Date: 10/08/86
Title: (Letter re: Submittal of Report, Remedial Investigation, General Electric Wiring Devices Site,
Juana Diaz, Puerto Rico)
Type: CORRESPONDENCE
Author: Sellers, Hark A.: Law Engineering Testing
Recipient: Czapor, John V.: US EPA
Attached: GEW-001-0776
ument Number: GEW-001-1395 To 1415 Parent: GEW-001-1345 Date: 12/02/86
Title: (Letter re: Attached Report of Preliminary Testing and Evaluation, Solidification/Fixation
Agent, G.E. Wiring Devices Plant, Juana, Puerto Rico)
Type: CORRESPONDENCE
Author: McNelis, Kathleen A.: Law Environmental Services
Recipient: Schauseil, Robert 1.: General Electric
Document Number: GEU-001-1416 To 1493 Parent: GEW-001-1345 Date: 12/02/86
Title: (Letter re: Attached Chemical Analyses of Samples Received on August 4, 1986)
Type: CORRESPONDENCE
Author: Tersegno, Vincent J.: Law Environmental Services
Recipient: Wheeleu, Dave: Law Environmental Services
Document Number: GEW-001-2199 To 2208 Date: 12/24/86
Title: (Memorandum re: Interim Guidance on Superfund Selection of Remedy)
Type: CORRESPONDENCE
Author: Porter, J. Winston: US EPA
ipient: none: US EPA
Ittaehed: GEW-001-2209
-------
57/15/97
Index Chronological Order
CE WIRING Documents
Page: 28
Docuwnt Nueber: CEU-001-22U To 2217
Title: (Letter re: Requirements of Section 121)
Type: CORRESPONDENCE
Author: Florfo, James J.: US Congress
Recipient: Thorns. Lee M.: US EPA
Parent: GEW-001-2210
Date: 03/27/87
Docuwnt Nuaber: CEU-001-1211 To 1211
Date: 04/09/87
Title: (Letter re: Remedial Investigation Report. General Electric Wiring Devices Site. Juana Diaz,
Puerto Rico)
Type: CORRESPONDENCE
Author: Ignacio. Rafael L.: PR Industrial Development Conpany
Recipient: Gelabert. Pedro A.: US EPA
Docinem Number: GEW-001-1212 To 1264
mie: Transcript of GE Meeting held 04/28/87 (written in Spanish)
Type: OTHER
Author: none: none
Recipient: none: none
Attached: GEU-001-1265
Date: 04/28/87
Document Number: GEU-001-1265 To 1314 Parent: GEW-001-1212
Title: English translation of transcript of GE Meeting held 04/28/87
Type: OTHER
Author: none: none
Recipient: none: none
Date: 04/28/87
Docuwnt Nusber: GEU-001-1315 To 1315
Date: 04/30/87
Title: News article titled: "Mercury Only Pollutant Found at GE Juana Diaz Waste Site: GE dunp one
of eight P.R. Superfund sites; total estimated cleanup cost could be S37M"
Type: OTHER
Author: luxntr, Larry: Caribbean Business
Recipient: none: none '
-------
•07/15/97 Index Chronological Order p,8e.
CE WIRING Document*
Document Number: GEW-001-2210 To 2213 Date: 05/21/87
Title: (Letter re: Agency's implementation of the Superfund Amendments and Reauthorization Act of
1986 (SARA))
Type: CORRESPONDENCE
Author: Thomas, lee M.: us EPA
Recipient: Florio, James J.: US Congress
Attached: GEW-001-22U
Document Number: CEW-001-2218 To 2219 Date: 05/29/87
Title: (Memorandum re: Review of Interim Guidance on Compliance with ARAR's}
Type: CORRESPONDENCE
Author: Weissman, Arthur B.: US EPA
Recipient: none: none
Attached: 6EW-001-2220
:ument Number: GEW-001-2228 To 2236 Date: 07/09/87
Title: (Memorandum re: Interim Guidance on Compliance with Applicable or Relevant and Appropiate
Requirements)
Type: CORRESPONDENCE
Condition: MARGINALIA
Author: Porter, J. Winston: US EPA
Recipient: none: none
Document Number: GEW-001-1316 To 1316 Date: 07/31/87
Title: (Transmittal slip re: Work Plan for Supplemental Soil Sampling and PCB Analyses)
Type: CORRESPONDENCE
Author: Coffuros, Glenn N.: Law Environmental Services
Recipient: O'Neil. Carlos E.: US EPA
Attached: GEU-001-1317 CEW-001-1324
-------
07/15/97 I"d*x Chronolooical Order P-9es 30
GE WIRING Documents
Oocuaent Number: GEW-001-1327 To 1343 D-te. oa/01/87
Title: Work Plan for Feasibility Study, Mercury Waste Sfte, Juana Diaz. Puerto Rico
Type: PLAN
Author: none: Law Environmental, Inc.
Recipient: none: General Electric
Doctmnt liuaber: GEW-001-2409 To 2425 Catt. 10/0V87
Title: Research and Development: Site Analysis, G.E. Wirins Devices, Juana Diaz, Puerto Rico
Type: REPORT
Author: Fauss, L. Mike: Bionetics Corporation
Recipient: none: US EPA
Document Nuaber: GEW-001-0701 To 0753 Oate: 10/23/87
Title: CLetter re: Results of Chemical Analysis of Water Samples from Water Wells and Monitorino
Wells)
Type: CORRESPONDENCE
Condition: MARGINALIA
Author: Spiers, Charles A;: taw-Environmental-Services
Recipient: Schauseil, Robert I.: General Electric
Attached: GEW-001-0722 GEW-001-0730 GEW-OD1-0738 GEW-001-0746
— """""""*""""""""*""*"""""""""""•»»"""""•"•••»«•••••••••••••••••••»,
Dociwent Nucber: GEW-001-1345 To U93 Parent: GEW-001-13W Date: 11/01/87
Title: Feasibility Study. Corrective Action Alternatives for Waste with Mercury Constituent. Wirin8
Devices of Puerto Rico, Inc., Juana Diaz, Puerto Rico
Type: PLAN
Condition: MISSING ATTACHMENT
Author: none: Law Environmental, Inc.
Recipient: none: General Electric
Attached: GEW-001-1395 6EW-001-H16
-------
Sfl "P
(uuoj
89/Sl/CO :»1»0 Z£9l 01 Z£9l-lOO-«30 :
S6n-tOO-rt33 :
Vd3 SO :
:
1N3HH3V11V ONtSSIN -.uoijlpuoj
-jcd 'zi;a tutnp '
'9961 '91 ^Jenusr p»iep '0£Q£-vi3s33-n *ON J»PJQ auasuoo aAilOJiSjuiupy •*•» J»Ji»n) :a)i!i
«utnr
:uo(>ipuo}
(03 n ouanj 'zt(o
•utnp '»jis *»3iA«a Su.ujn 3.ua3»l3 )«j*u»g 'Xpnjs SJ/IS »M» oj unpo»ppy
1591 01
39
xapuj
-------
A
f-
•J7/15/9r Index Chronological order P.fle.
CE WIRING Documents
Document Number: GEW-001-1852 To 1852 p.rent: GEW-001-1633 Date: W/11/88
Title: (Inter-office awnorandua re: Project 6331 - CE Juana Diaz, Work Performed July to September,
1986)
Type: CORRESPONDENCE
Author: McBride, Clifford H.: Law Engineering Testing
Recipient: Sellers, Nark A.: Lau Engineering Testing
Document Number: GEW-001-1853 To 1853 08te. 04/15/88
Title: (Letter re: Supplemental Data Submittal, Laboratory Quality Assurance/Quality Control, General
Electric Wiring Devices Site, Juana Diaz, Puerto Rico)
Type: CORRESPONDENCE
Condition: MISSING ATTACHMENT
Author: Allen, David A.: Lau Engineering Testing
Recipient: Kaplan, Arthur L.: General Electric
Jocunent Nuraber: GEW-001-1854 To 1856 Date: 05/12/88
Title: (Memorandum re: Mercury Validation Results)
Type: CORRESPONDENCE
Author: Messina, Frank J.: US EPA
Recipient: DiForte, Nicoletta: US EPA
Document Number: GEW-001-1895 To 1918 Parent: GEW-001-1B57 Date: 08/22/88
Title: (Letter re: Status report on the work performed by the Bureau of Mines with attached Bureau
of Nines Report)
Type: CORRESPONDENCE
Author: Schmidt. William B.: US Dept of the Interior
Recipient: DiForte, Nicoletta: US EPA
-------
F17/15/97
Index Chronological Order
CE WIRING Documents
Page: 33
Document Hunter: GEW-001-2284 To 2320 Date: 08/31/88
Title: Draft Cost Estimate* for Remedial Action Alttrnatives
Type: FINANCIAL/TECHNICAL
Author: none: Lee Wan i Associates
Recipient: none: Caap Dresser t NcKee (COM)
Document Number: CEU-001-1857 To 1894 Date: 09/01/88
Title: G.E. Wiring Devices, Addendum Feasibility Study, September, 1988
Type: PLAN
Condition: MISSING ATTACHMENT
Author: none: US EPA
Recipient: none: none
Attached: GEW-001-1895 GEW-001-1919 CEW-001-1920
jgJlpcunent Number: CEW-001-19T9 To 1919 Parent: CEU-001-1B57 Date: 09/01/88
itle: (Letter re: Quality Assurance Project Plan for EPA Work Assignment 649, Sampling and Analysis
of Ground Water and Soil Samples, C.E. Wiring Devices. Juana Diaz, Puerto Rico)
Type: CORRESPONDENCE
Author: Goltz, Robert D.: -Camp Dresser I HcKee (COM)
Recipient: Harvell, Rose: US EPA
Document Number: CEW-001-1920 To 1941 Parent: GEW-001-1857 Date: 09/01/88
Title: Quality Assurance Project Plan, Sampling and Analysis of Groundwater and Soil Samples. G.E.
Wiring Devices, Juana Diaz, P.R.
Type: PLAN
Author: none: Lee Wan t Associates
Recipient: none: US EPA
-------
Jk
f
57/15/97 Index Chronological Order Page: 34
GE WIRING Documents
********
Document number: GEU-001-2321 To 2326 Date: 09/01/88
Title: {Proposed Remedial Action Plan for site, written in Spanish)
Type: FLAN
Author: none: US EPA
Recipient: none: none
Attached: GEW-001-2327
Document Number: GEU-001-2327 To 2332 Parent: GEW-001-2321 Date: 09/01/88
Title: Proposed Remedial Action Plan, G.E. Wiring Devices Superfund Site, Juana Diaz, Puerto Rico
Type: PLAN
Author: none: US EPA
Recipient: none: none
Document Hunter: GEW-001-1942 To 1943 Date: 09/13/88
Title: (Letter re: Trip Report, Sampling Investigation Report, Data Summary, and Evaluation Report
for EPA Work Assignment 649, G.E. Wiring Devices, Juana Diaz, Puerto Rico)
Type: CORRESPONDENCE
Author: Goltz, Robert D.: Camp Dresser t McKee (COM)
Recipient:.Harvell, Rose: US EPA
Attached: GEW-001-1944
Document Number: CEW-001-1944 To 2193 Parent: GEU-001-1942 Date: 09/13/88
Title: Trip Report, Sampling Investigation Report, Data Summary and Evaluation Report, G.E. Wiring
Devices, Juana Diaz, Puerto Rico
Type: PLAN
Author: none: Lee Wan t Associates
Recipient: none: US EPA
Document Nurber: GEW-001-2333 To 2334 • Date: 09/22/88
Title: (Letter concurring with EPA that alternative 9. Hydrometallurgical Treatment, is the most
environmentally sound and safe alternative while noting more detailed studies on grounduater
are needed prfor to talcing any action)
Type: CORRESPONDENCE
Author: Torr«s, Heriberto: PR, Commonwealth of
Recipient: O'Neill, Carlos E.: US EPA
-------
punjjadns
euou :euou
oua* :*jtis :joqin»
11043* :
*3*9
saisen JOj. Xpnis
euenr '
3jOo]ouq3ai sau}M *o nwajng
909Z 01 £S£Z-lOO-n39 :jaqur«
E8R-100-MD r
«,naajng
jd»o sn :'t
m 40 saidoa
Z8CZ 01 Z9£2-LOO-n33 :
:adXi
luaunaoa
auou :auou
8«/0£/60 s
Vd3 SO "P iwinjfl 'tJtsuAzsriM :JOi|jnv
'ztiQ tuenp 's93iA»a Buijin '3'9 'uoistaao >o
S/00 01 7700-ZOO-n30 :jaqwN luaur
uraov^
•".•Jin
88/62/60 '•
i«jauag 'tuauissassy
Vd3 sn :auou tjuajdisaj
Vd3 sn :auou :joyjnv
radXi
ouanj 'zeia euenp 'a»j$
jtuij :ju»udoiaA»o pu«
01
8fl/£Z/60 :
S£ :
Xuedu»3
(uodaa
Vd3 Sn "3
)efj»«npui IM J'T lae^ea 'ojaeuBi :jomn»
33N3C«CWS3a»03
01
************************
3D
-------
07/15/97 • Index Chronological Order P«8*: 36
GE WIRING Documents
Document Nu*ers GEW-001-2464 To 2464 Date: 08/26/93
Title: (Letter r«: Draft lite line Risk Assessment, G.E. Wiring Devices Site, Juan* Diaz, Puerto Rico,
•nd Health end Endangerment Assessment Work Assignment)
Type: CORRESPONDENCE
Author: Graber, Scott ».: CD* Federal Program Corporation
Recipient: Saieszek, Erwin: US EPA
Attached: GEW-001-2465
Document Nunfeer: GEW-001-2465 To 0043 Parent: GEW-001-2464 Date: 08/26/93
Title: Draft Baseline Risk Assessment for the G.E. Wiring Devices Site, Work Assignment No. C02120
Type: REPORT
Author: Faulk, Jack: COM Federal Programs Corporation
Recipient: none: US EPA
Document Nuntoer: CEW-001-2426 To 2426 fate: 12/01/93
Title: (Letter re: Addendun to the Revised Baseline Risk Assessment, G.E. Wiring Devices Site, Juana
Di*z, Puerto Rico, and Health and Endangerment Assessment Work Assignment)
Type: CORRESPONDENCE
Author: Graber. Scott 8.: COM Federal Programs Corporation
Recipient: Sntieszek, Erwin: US EPA
Attached: GEW-001-2427
• •••••••••••••«•••»*•••*-••••-••••••••«•»«•-•»•»•••«•••--"»""»«•••"•*•"""••••••••'"""'•*"""""""*""'""*"""'"'""**'
Document Nwfcer: GEW-001-2427 To 2463 Parent: GEW-001-2426 Date: 12/01/93
Title: Revised laseline Risk Assessment Addendum for the G.E. Wiring Devices Site, Work Assignment
No. C02120
Type: REPORT
Author: Oxford, Jeniffer: COM Federal Programs Corporation
Recipient: none: US EPA
-------
fc
'*
17/15/97 Index Author Name Order
GE WIRING Documents
Document Number: GEW-001-0022 To 0022 Parent: GEU-001-0018 Date: / /
Title: Juan* Diaz Plant So?I Evaluation Samples: Locution Sketch
Type: GRAPHIC
Author: none: none
Recipient: none: none
Document Number: GEW-001-0025 To 0025 Parent: GEW-001-0023 Date: / /
Title: Juana Diaz Plant Soil Evaluation Samples: Location Sketch
Type: GRAPHIC
Author: none: none
Recipient: none: none
Document Number: GEW-001-0246 To 0284 Date: 01/27/83
hie: Presentation materials used by GE and Law Engineering Testing Company
Type: OTHER
Author: none: none
Recipient: none: none
Document Number: GEU-001-0555 To 0555 Date: 01/27/83
Title: Handwritten list of attendees to GE meeting
Type: OTHER
Author: none: none
Recipient: none: none
Document Number: GEW-001-0556 To 0607 Date: / /
Title: Hap of Generalized Site Setting, Initial Assessment Findings, and other presentation materials
for a GE wiring eweting
Type: OTHER
Author: none: none
Recipient: none: none
-------
07/15/97
Index Author Name Order
CE WIRING Documents
Page: 2
Docunent Number: GEW-001-0758 To 0758
Date: 06/03/86
Title: Favor Oe Firmer (handwritten list of names, organization and addresses}. General Electric
Wiring Devices
Type: OTHER
Author: none: none
Recipient: none: none
Attached: GEU-001-0739
Document Number: GEW-001-0759 To 0765 Parent: GEW-001-0758
Title: Conraunity Relations Plan, General Electric Company, Juana Diaz Plant
Type: PLAN
Author: none: none
Recipient: none: none
Date: / /
Document Number: GEU-001-0767 To 0767 Parent: GEW-001-0766
Title: Remedial Investigation Work Plan Projected Schedule
Type: PLAN
Author: none: none
Recipient: none: none
Date: / /
Document Number: GEW-001-0771 To 0772 Parent: GEU-001-0770
Title: Table 1. Hercury Concentration, General Electric - Juana Diaz
Type: DATA
Author: none: none
Recipient: none: none
Date: 06/01/86
Document Number: GEU-001-0774 To 0774 Parent: GEW-001-0770
Title: Table 2, Cooperative Analyses of Soil Sample* for Mercury Concentration
Type: DATA
Author: none: none
Recipient: none: none
Date: / /
-------
IT/15/97
Index Author Mane Order
GE WIRING Documents
mmt:mu*mmm*m*mmmrm**m*mmmmm*mmmmmmmmmmm**mumnm
Document Murfcer: GEW-001-1212 to 1264
Title: Transcript of GE Meeting held 04/28/87 (written In Spanish)
Type: OTHER
Author: none: none
Recipient: none: none
Attached: GEW-001-1265
Page: 3
Date: 04/28/87
Oocuatnt Number: CEW-001-1265 To 1314 Parent: GEW-001-1212
Title: English translation of transcript of GE Meeting held 04/28/87
Type: OTHER
Author: none: none
Recipient: none: none
Date: 04/28/87
Document Nunber: GEU-001-1317 To 1323
Parent: GEU-001-1316
Date: / /
le: Document No. 1 - Work Plan for Supplemental Soil Sampling. General Electric Company Wiring
Devices Facility, Juarta Diaz, Puerto Rico
Type: PLAN
Author: none: none
Recipient:' none: none
Document Number: GEW-001-1324 To 1326
Parent: GEU-001-1316
Date: / /
Title: Document No. 2 • Work Plan for PCS Analyses, General Electric Company wiring Devices Facility,
Juana Diaz, Puerto Rico
Type: PLAN
Author: none: none
Recipient: none: none
Oocuwnt Nunber: GEU-001-1633 To 1851 Date: 09/01/86
Title: OC Package for Project 6331 • GE/Juana Diaz, July, August, and September, 1986
i
m
Type: DATA
Condition: MARGINALIA
Author: none: none
ipient: none: none
'ttached: GEW-001-1852
-------
07/15/97 Index Author Name Order pap,.
GE WIRING Documents
Document Number: GEW-001-2209 To 2209 Parent: GEW-001-2199 Date: / /
Title: Proposed Remedy Selection Process Under Reauthorization Chart
Type: GRAPHIC
Author: none: none
Recipient: none: none
•-"•••—•••••••«•••——-•»---•—.—.....................»..........„..............................
Document Number: GEW-OD1-2220 To 2227 Parent: GEW-001-2218 Date: / /
Title: Interim Guidance on Compliance with Applicable or Relevant and Appropriate Requirements
Type: PLAN
Condition: DRAFT
Author: none: none
Recipient: none: none '
Document Number: GEW-001-0012 To 0013 . Parent: GEW-001-0011 Date: 10/21/76
/itle: Resource Conservation and Recovery Act. Public law 94-SSO, as amended by the Quiet Communities
Act of 1978
Type: LEGAL DOCUMENT
Author: none: US EPA
Recipient: none: none
Document Number: CEU-001-0016 To 0016 Parent: 6EU-001-OOH Date: 07/12/79
Title: Analytical results of mercury soil samples for samples received 06/26/79
Type: DATA
Author: none: General Electric
Recipient: none: none
Document Number: GEU-001-0020 To 0021 Parent: GEU-001-0018 Date: 10/05/79
Title: Environmental Monitoring Analytical Services Request Forms
Type: OTHER
Author: none: General Electric
lecipient: Fttiu, Leo: General Electric
-------
P7/15'97 I»d«x Author Ham Order p.8e. 5
CE WIRING Documents
Document Number: GEW-001-0024 To 0024 p.rent: CEU-001-0023 Date: 10/24/79
Title: Environmental Analysis of Mercury contained in soil samples received 10/12/79
Type: DATA
Author: none: General Electric
Recipient: none: General Electric
Document Number: GEW-001-0158 To 0160 Date. / /
Title: Analytical data and field data from standpipes at the Juana Diaz site
Type: DATA
Author: nones Law Engineering Testing
Recipient: none: none
Document Number: GEW-001-0177 To 0177 Parent: GEW-001-0170 . Date: / /
Jitle: Figure 1 - Generalized Locations of August 1982 Test Pits 1 through 12
Type: GRAPHIC
Author: none: Law Engineering Testing
Recipient: none: none
Document Number: GEU-001-0220 To 0230 P.rent: GEW-001-0218 Date: 11/17/82*'
Title: (Copies of driller's logs for the monitoring wells recently installed from 10/03/82-11/17/82)
Type: OTHER
Condition: ILLEGIBLE
Author: none: Caribbean Soil Testing Company
Recipient: none: none
Document Number: GEW-001-0287 To 0287 Oate. 03/09/83
Title: (Letter r«: Attached summary of ConpuOteM data)
Type: CORRESPONDENCE
Author: none: Mead ConpuChem Laboratory
Recipient: Maroncelli, Janes M.: Law Engineering Testing
Attached: GEU-001-0288
-------
17/15/97
Index Author Nam- Order
GE WIRING Documents
*••»*•»»•••••••••
Doctmnt Number: GEW-001-0650 To 0651 Date: / /
Title: (News release: GE Consents to EPA order to Act on Juana Diaz, P.R. Contamination)
Type: CORRESPONDENCE
Author: none: US EPA
Recipient: none: none
Document Worker: GEW-001-0652 To 0652
Title: (Public notice re: Administrative Order on Consent (written in Spanish))
Type: CORRESPONDENCE
Author: none: El Nuevo Dia
Recipient: none: none
Page: 6
Date: 02/03/84
Document Number: GEW-001-0654 To 0654
Title: (Newspaper article titled: "PA Exige GE Limpie Vertedero en Juana Diaz")
Type: CORRESPONDENCE
Author: none: El Hundo, San Juan
Recipient: none: none
Date: 02/13/84
Document Number: GEU-001-0661 To 0663 Parent: GEU-001-0660
Title: Response to cements on Administrative order
Type: PLAN
Author: none: US EPA
Recipient: none: none
Date: 06/01/84
Docunent Number: GEW-001-0665 To 0686 Parent: GEW-001-0664 Date: 03/11/85
Title: Work Plan for Remedial Investigation. Nercury Waste Site, Juana Diaz, Puerto Rico
Type: PLAN
Author: none: Law Engineering Testing
Recipient: none: General Electric
-------
f07/15/97 index Author Name Order p,ge. 7
CE WIRING Documents
Document Number: CEW-001-0776 To 1210 Parent: GEW-001-0775 Date: / /
Title: Remedial Investigation Report for General Electric Wiring Devices Site, Juana Diaz, Puerto
Rico
Type: REPORT
Condition: MARGINALIA
Author: none: Law Engineering Testing
Recipient: none: General Electric
Document Number: GEW-001-1327 To 1343 Oate: 08/01/87
Title: Work Plan for Feasibility Study. Mercury Waste Site. Juana Diaz, Puerto Rico
Type: PLAN
Author: none: Law Environmental, Inc.
Recipient: none: General Electric
ocument Number: GEW-001-1345 To H93 Parent: GEW-001-1344 Date: 11/01/87
Title: Feasibility Study, Corrective Action Alternatives for Waste with Mercury Constituent, Wiring
Devices of Puerto Rico, Inc., Juana Diaz. Puerto Rico
Type: PLAN
Condition: MISSING ATTACHMENT
Author: none: Law Environmental, Inc.
Recipient: none: General Electric
Attached: GEW-001-1395 GEW-001-U16
Document Number: GEW-001-1632 To 1632 Date: 03/15/88
Title: (Law Environmental Client Contact Form)
Type: CORRESPONDENCE
Condition: MARGINALIA
Author: none: Law Engineering Testing
Recipient: Messina. Frank J.: US EPA
-------
37/15/97 Index Author Name Order pS8es 6
GE WIRING Documents
Oocunent Number: CEW-001-1857 To 1894 0»;c. 09/01/88
Titlt: C.E. Hiring Devices. Addendum Feasibility Study, September, 1988
Type: PLAN
Condition: MISSING ATTACHMENT
Author: none: us EPA
Recipient: none: none
Attached: GEU-001-1895 GEU-001-1919 GEU-001-1920
Oocinent Nuaber: GEW-001-1920 To 1941 Parent: CEW-001-1857 Date: 09/01/88
Title: duality Assurance Project Plan, Sampling and Analysis of Grounduater and Soil Samples, G.E.
Wiring Devices, Juana Diaz, P.R.
Type: PLAN
Author: none: Lee Wan I Associates
Recipient: none: US EPA
Docunent Number: GEW-001-1944 To 2193 Parent: GEW-001-1942 Date: 09/13/88
Title: Trip Report, Sampling Investigation Report, Data Summary and Evaluation Report, G.E. Wiring
Devices, Juana Diaz, Puerto Rico
Type: PLAN
Author: none: Lee Wan t Associates
Recipient: none: US EPA
Document Nwfcer: GEW-001-2237 To 2283 ' Date: 09/01/84
Title: Health Effects Assessment for Mercury
Type: PLAN
Author: none: US EPA
Recipient: none: none
-------
J7/15/97 Index Author Name Order Page: 9
G£ WIRING Documents
Document Number: GEW-001-2284 To 2320 Date: 08/31/88
Title: Draft Cost Estimate* for Remedial Action Alternatives
Type: FINANCIAL/TECHNICAL
Author: none: Lee Wan t Associates
Recipient: none: Camp Dresser I McKee (COM)
Document Number: GEW-001-2321 To 2326 Date: 09/01/88
Title: (Proposed Remedial Action Plan for site, written in Spanish)
Type: PLAN
Author: none: US EPA
Recipient: none: none
Attached: GEU-001-2327
Document Number: GEU-001-2327 To 2332 Parent: GEW-001-2321 Date: 09/01/88
Mtle: Proposed Remedial Action Plan, G.E. Wiring Devices Superfund Site. Juana Diaz, Puerto Rico
Type: PLAN
Author: none: US EPA
Recipient: none: none
Document Number: GEW-001-2337 To 2381 ' Date: 09/29/88
Title: Research and Development: Final Draft, Endangerment Assessment, "General Electric Wiring Devices
Site, Juana Diaz, Puerto Rico
Type: REPORT
Author: none: US EPA
Recipient: none: US EPA
Document Number: GEW-001-0026 To 0046 Date: 04/22/81
Title: Field notes made by W.J. Alexander during auger borings and test pit excavations at the West
Field Site
Type: OTHER
Author: Alexander, V. Joseph: law Engineering Testing
eciptent: none: none
-------
,37/15/97 Index Author Name Order Page:
GE WIRING Documents
**********
Document Nunber: GEW-001-0048 To 0098 Oate: 06/19/81
Title: (Letter re: Attached Report Submittal, Hydrogeologic Investigatigation, Uaste Fill Area. Juana
Diaz, Puerto Rico. Lau Engineering Job Number MH1223)
Type: CORRESPONDENCE
Author: Alexander. U. Joseph: law Engineering Testing
Recipient: Phillips, J.M.: General Electric
Attached: GEU-001-0099
Document Nunfcer: GEU-001-0170 To 0176 ' D,te. 09/22/82
Title: (Letter r«: Report of August, 1982 Site Visit, Juana Dial Plant, Puerto Rico, Law Engineering
Project No. MH2296)
Type: CORRESPONDENCE
Condition: MARGINALIA
Author: Alexander, U. Joseph: Law Engineering Testing
Recipient: Frist, James T.: General Electric
Attached: GEW-001-0177
• *•<•><**><*•<•<»••<»•••» <• w* «*« • • «* •*** v«iiw*w«vw4w »•>•<•• *«>*******«.••> B
Jocunent Number: GEU-001-0198 To 0217 Date: n/22/82
Title: (Letter re: Attached Status Report of Hydraulic Conditions, Perehed-Water Table; Waste Fill
Area. Juana Diaz Plant, Puerto Rico, Lau Engineering Project No. MHU40.03)
Type: CORRESPONDENCE
Author: Alexander. U. Joseph: Lau Engineering Testing
Neal, Larry A.: Law Engineering Testing
Recipient: Schauseil. Robert I.: General Electric
Document Nuxfcer: CEW-001-0285 To 0285 Oate: 02/24/83
Title: (Letter re: Results of Mercury Analysis, Juana Diaz Plant. Puerto Rico, Law Engineering Mo.
NH2317)
Type: CORRESPONDENCE
Author: Alexander, U. Joseph: Law Engineering Testing
Recipient: Frfss, James T.: General Electric
Attached: GEW-001-02B6
-------
07/15/97 Index Author Name Order Page: 11
GE WIRING Documents
Document Number: GEW-001-0387 To MOB Date: 03/15/S3
Title: (Letter r«: Ground-Mater Quality Analyses, Juana Diaz Site, Puerto Rico, Reference Proposal
MS3022.20 (Item 5>. Law Engineering Project No. UM3233)
Type: CORRESPONDENCE
Condition: MARGINALIA
Author: Alexander, U. Joseph: Law Engineering Testing
Recipient: Schauseil, Robert I.: General Electric
Document Number: GEW-001-0409 To 0413 Date: 04/18/83
Title: (Letter re: Test Soring Records, General Electric Company Plant Site, Juana Diaz, Puerto Rico)
Type: CORRESPONDENCE
Author: Alexander, U. Joseph: Law Engineering Testing
Recipient: Pierre, Wayne N.: US EPA
'Document Number: GEW-001-0414 To 0433 Date: 04/20/83
Title: (Letter re: Report of Test Results, Juana Diaz Site, Puerto Rico, Reference Proposal KS3022.20
(Items 3 and 4), Law Engineering Project No. UH3233)
Type: CORRESPONDENCE
Author: Alexander, W. Joseph: Law Engineering Testing
Neal, Larry A.: Law Engineering Testing
Recipient: Schauseil, Robert I.: General Electric
Document Number: GEU-001-0447 To 0447 Date: 07/19/83
Title: (Letter re: Intensity of Earthquakes, Law Engineering Project No. WM3233)
Type: CORRESPONDENCE
Author: Alexander, W. Joseph: Law Engineering Testing
Recipient: Schauseil, Robert I.: General Electric
Attached: G£U-001-0448
-------
J*
.r
V7/15/97 Index Author Nanw Order Plge: 12
CE WIRING Documents
Document Number: CEU-001-0609 To 0609 Date: 02/24/83
Titl«: (Utter r«: Results of Kercury Analysts, Juana Diaz Plant, Puerto Rico, Law Engineering Project
No. HH2317)
Typ*: CORRESPONDENCE
Condition: MISSING ATTACHMENT
Author: Alexander, W. Joseph: Law Engineering Testing
Recipient: Friss. Jaaes T.: General Electric
Document Number: GEU-001-1853 To 1853 Date: 04/15/88
Title: (Letter re: Supplemental Data Submittal, Laboratory Quality Assurance/Quality Control, General
Eitctric Wiring Devices Site, Juana Diaz, Puerto Rico)
Type: CORRESPONDENCE
Condition: KISSING ATTACHMENT
Author: Allen, David A.: Law Engineering Testing
Recipient: Kaplan, Arthur L.: General Electric
Document Number: GEW-001-0288 To 0384 Parent: GEW-001-0287 Date: / /
Title: Suanary of ConpuChem data
Type: DATA
Author: Bloom. Richard L.: Mead ConpuChem Laboratory
Recipient: Haroncelli, James M.: Law Engineering Testing
Document Number: GEW-001-0644 To 0644 Parent: GEU-001-0621 Date: 02/01/86
titlt: (Public Notice re: General Electric Ccnpany entering into Administrative order on Consent)
Type: CORRESPONDENCE
Author: Carlos, O'Ueil: US EPA
Recipient: none: none
-------
J7/15/97 Index Author Name Order f»Bge: ',3
GE WIRING Documents
Document Number: GEU-001-0691 To 0691 Parent: GEU-001-0689 Dnte: 01/22/85
Title: (Letter re: Summary of data from requested sample analysis)
Type: CORRESPONDENCE
Author: Carrington, PaneIa S.: CompuChem
Recipient: Neil, Larry A.: Law Engineering Testing
Document Number: GEW-001-1344 To 1344 Oate: 11/25/87
Title: (Letter re: Feasibility Study Report, Wiring Devices of Puerto Rico, Inc., Juana Diaz, Puerto
Rico)
Type: CORRESPONDENCE
Author: Chopan, Phil M.: Law Environmental, Inc.
Recipient: Kaplan, Arthur L.: General Electric
Attached: GEW-001-1345
Document Number: GEW-001-1316 To 1316 Date: 07/31/87
Title: (Transmittal slip re: Work Plan for Supplemental Soil Sampling and PCB Analyses)
Type: CORRESPONDENCE
Author: Coffuros, Glenn N.: Law Environmental Services
Recipient: O'Neil, Carlos E.: US EPA
Attached: GEW-001-1317 GEW-001-1324
Document Number: GEW-001-0757 To 0757 , Date: 05/05/86
Title: (Letter re: Revised Work Plan for Remedial Investigation, G.E. Wiring Devices Site, Juane
Diaz, Puerto Rico)
Type: CORRESPONDENCE
Author: Czapor, John V.: US EPA
Recipient: Kaplan, Arthur L.: General Electric
Document Number: GEW-001-0168 To 0169 Date: 03/04/82
Title: (Letter re: General Electric Juana Diaz)
Type: CORRESPONDENCE
Condition: MARGINALIA
Author: de la Cruz, Luis E: PR Environmental Quality Board
cipifent: Colon, Javier: General Electric
-------
17/15/97 Index Author Name Order Page: U
GE WIRING Documents
••••*•*»*
Document Nunber: GEW-001-0166 To 0167 Date: 05/18/82
Title: (Letter re: Questions and answers from the Harch 4. 1982 letter that raised concerns about
the Clay Continuity Report and Hydrogeologic Study)
Type: CORRESPONDENCE
Condition: MARGINALIA
Author: de la Cruz, Luis E.: PR Environmental Quality Soard
Recipient: Colon, Javier: General Electric
Document Number: GEU-001-0550 To 0552 Date: 12/22/82
*
Title: (Letter re: Response to December 16, 1982 tetter relating to the inclusion of the Juana Diaz
site as a priority project)
Type: CORRESPONDENCE -
Author: DeSorbo, L.A.: General Electric
Recipient: Madera, Jose R.: PR Economic Development Administration
Document Number: GEW-001-0660 To 0660 Date: 07/16/84
Title: (Letter re: EPA's response to the public comments received on Order No. II-CERCLA-30301)
Type: CORRESPONDENCE
Condition: HISSING ATTACHMENT
Author: Dewling, Richard T.: US EPA
Recipient: Vineyard, William: General Electric
Attached: GEW-001-0661
Document Number: CEU-001-0655 To 0656 Date: 02/15/84
Title: (Article titled: "GE Will Cleanup Waste Disposal Site: Company signs consent order with EPA
to attend to 27-year-old Juana Diaz dump")
Type: CORRESPONDENCE
Author: Echavarri, Christian M.: Carribean Business
Recipient: none: none
-------
J7/15/97 Index Author Name Order Page: 15
GE WIRING Documents
Document Number: GEW-001-2465 To 0043 Parent: GEW-001-2464 Date: 08/26/93
Title: Draft Baseline Risk Assessment for the G.E. Miring Devices Site, Work Assignment No. C02120
Type: REPORT
Author: Faulk, Jack: COM federal Programs Corporation ~
Recipient: none: US EPA
Document Number: GEW-001-2409 To 2425 Date: 10/01/87
Title: Research and Development: Site Analysis, G.E. Wiring Devices, Juana Diaz, Puerto Rico
Type: REPORT
Author: Fauss, 1. Mike: Bionetics Corporation
Recipient: none: US EPA
Document Number: GEU-001-0014 To 00U Date: 08/16/79
Title: (Letter re: Mercury Soil Contamination - Juana Diaz, P.R.)
Type: CORRESPONDENCE
Author: Feliu, Leo: General Electric
Recipient: Burns, William S.: General Electric
Attached: GEW-001-0015 GEW-001-0016
Document Number: GEW-001-0017 To 0017 Date: 09/27/79
Title: (Memorandum re: Plant Soil Evaluation Program)
Type: CORRESPONDENCE
Author: Feliu, Leo: General Electric
Recipient: Poland, J.B.: General Electric
Document Number: GEU-001-0001 To 0001 Date: 06/12/79
Title: (Memorandum re: Mercury Sampling)
Type: CORRESPONDENCE
Author: Figueroa, Solange I.: General Electric
Recipient: Poland. J.S.: General Electric
Attached: GEW-001-0002 GEW-001-0004 GEU-001-0006 GEW-001-0009
-------
07/15/97 Index Author Name Order Page: 16
GE WIRING Documents
Document Muttber: GEW-001-0002 To 0003 Parent: GEW-001-0001 Date: 06/18/79
Title: (Memorandum re: Mercury Sampling on 6/16/79)
Type: CORRESPONDENCE
Author: Figueroa, Solange I.: General Electric
Recipient: Poland, J.B.: General Electric
Document Number: GEW-001-0004 To 0005 ' Parent: GEW-001-0001 Date: 06/19/84
Title: (Memorandum re: Ground Samples/Mercury Percent)
Type: CORRESPONDENCE
Author: Figueroa, Solange I.: General Electric
Recipient: Culp, Dale: General Electric
" m *****"""**'***"**""""""•"•"""""""»"""""""""»••"•*««»•••••••••••••••*•••••••••«»••••••.•»»,
Document Number: GEW-001-0006 To 0008 Parent: GEW-001-0001 Date: 06/20/79
'itle: (Memorandum re: Mercury Sampling - Follow Up)
Type: CORRESPONDENCE
Author: Figueroa, Solange 1.: General Electric
•ecipient: Poland, J.B.: General Electric
Document Number: GEW-001-0009 To 0010 Parent: GEW-001-0001 Date: 06/22/79
Title: (Memorandum re: Mercury Sutton Handling, Plating Area. Juana Diaz)
Type: CORRESPONDENCE
Author: Figueroa, Solange I.: General Electric
Recipient: Poland, J.S.: General Electric
Document Number: GEW-001-0011 To 0011 Date: 06/25/7V
Title: (Memorandum re: Juana Diaz Plating Area Situation)
Type: CORRESPONDENCE
Author: Figueroa. Solange I.: General Electric
Recipient: Poland, J.«.: General Electric
Attached: GEW-001-0012
-------
07/15/97 Index Author Name Order P«fl*: '7
GE WIRING Documents
••••••••KB
Document Number: 6EW-001-0015 To 0015 Parent: GEU-001-OOU Date: 07/17/79
Title: (MemoranduB re: Mercury SolI Samples)
Type: CORRESPONDENCE
Author: Figueroa, Sotange 1.: General Electric
Recipient: Poland, J.B.: General Electric
Document Number: GEW-001-0018 To 0019 Date: 10/11/79
Title: (Letter re: Juana Diaz Plant Soil Evaluation Samples)
Type: CORRESPONDENCE
Author: Figueroa, Sotange I.: General Electric
Recipient: Feliu, Leo: General Electric
Attached: CEU-001-0020 CEW-001-0022
€i
:unent Number: GEU-001-0023 To 0023 Date: 11/02/79
tie: (Letter re: Laboratory Analysis of the Juana Diaz Plant Soil)
Type: CORRESPONDENCE
Author: Figueroa, Solange I.: General Electric
Recipient: Schauseil, Robert I.: General Electric
Attached: CEU-001-0024 GEU-001-0025
Document Number: GEU-001-2214 To 2217 Parent: CEW-001-2210 Date: 03/27/87
Title: (Letter re: Requirements of Section 121)
Type: CORRESPONDENCE
Author: Florio, James J.: US Congress
Recipient: Thoaas. Lee M.: us EPA
Document Number: GEW-001-0151 To 0152 Date: 01/27/82
Title: (Letter n: EPA's review of cownenta regarding Law Engineering Testing Company's Clay Continuity
Report)
Type: CORRESPONDENCE
Author: Frisco, John S.: US EPA
Recipient: Phillips, Marvin: General Electric
-------
7/15/97 Index Author Name Order Page: 18
GE WIRING Documents
*•••*»•«••«•••••••«•»»*••••»••••••••••*•
Document Number: GEU-001-0509 To 0510 Date: 01/27/82
Title: (Letter re: U.S. EPA'« conroents on Law Engineering Testing Company's Continuity of Clay Report)
Type: CORRESPONDENCE
Author: Frisco, John S.: US EPA
Recipient: Phillips, Marvin: General Electric
Document Nutfcer: GEU-001-0645 To 0646 Date: 12/15/83
Title: Resolution and notification (written in Spanish)
Type: LEGAL DOCUMENT
Author: Gelabert, Pedro A.: PR, Commonwealth of
Recipient: none: General Electric
Document Nurcber: GEW-001-0100 To 0150 Date: 11/02/81
Title: (Letter re: Attached Report of Clay Continuity Study, Waste Fill Area, Juana Diaz Plant, Puerto
Rico, Law Engineering Project No. MH1367)
Type: CORRESPONDENCE
Condition: MARGINAllA
Author: Germond, iart J.: Law Engineering Testing
Recipient: Schauseil. Robert I.: General Electric
Document Number: GEW-001-0450 To 0502 Date: U/02/80
Title: (Letter re: Attached Report of Clay Continuity Study, Waste Fill Area. Juana Diaz Plant, Puerto
Rico, Law Engineering Project No. MH1367)
Type: CORRESPONDENCE
Author: Germond, Bart J.: Law Engineering Testing
Recipient: Schauseil, Robert I.: General Electric
-------
(MQ3) aaj|3M 1
du*3 :'0 Uaqoa 'll)O3
nutnr '«»3jA»o Buntin '3*3 't»idu»$ no$ pu» j»itn
auwuuBissv )|jon Vd3 Mi. u«id
put
88/10/60 :a«d ZS8l-lOO-rl33 uuaj«d 6161 01 6l6l-lOO-«33 :J
auou :auou
JBJS utnp ue$ :ot]np '/
sixoi »J»4" ajjs ZIIQ euBfip dnuta
W/ZO/ZO :ano £590 Oi £S90-100-PI3D
'II 'f
N30HOc
•ON isafojd 6uuaaut8u3 nti
'O31JI ouanj 'luejd z*}0 tump 'sajy DIJ a;s»n 'uwjBojj BU^JOIJUOM la^ai jatan :aj ja^ai)
38/6t/ZO sajta 2910 01 1910-100-M33 sjaq«fi|» juauraoo
WSO-100-M33 ~-f
9uj3ai3 ituauao :•{ )jaq<
33N30NOdS3il]K)3 :<
(£Z21HH 'ON qop Buija*u|6u3 ««i '031 a ouand *iuv)4 I«IQ cutnp
'•ajy DM aistfl uoijoB}JS»AUI 3iBo|oaBojp/H 'JJOdag q)0i «unp am 01 juauupuawy :»J J»ll»l) :»UU
18/0£/01 saj«a £0so 01 £OSO-lOO-fl33
61 :aStd
sjuawnsoo 8N I SIM 39
aui«N JOMtny xapu]
Z6/SI/ZO
-------
J7/15/97 Index Author Name Order Page: 20
GE WIRING Documents
Document Number: GEW-001-1942 To 1943 Date: 09/13/88
Titlt: (Letter re: Trip Report, Sampling Investigation Report, Data Summary, and Evaluation Report
for EPA Work Assignment 649, G.E. Wiring-Devices, Juana Diaz, Puerto Rico)
Type: CORRESPONDENCE
Author: Goltz, Robert D.: Camp Dresser I McKee (COM)
Recipient: Marvel I, Rose: US EPA
Attached; GEW-OD1-194*
Document Number: GEW-001-2426 To 2426 Date: 12/01/93
Title: (Letter re: Addendum to the Revised Baseline Risk Assessment. C.E. Wiring Devices Site, Juana
Diaz, Puerto Rico, and Health and Endangerment Assessment Work Assignment)
Type: CORRESPONDENCE
Author: Graber, Scott B.: COM Federal Programs Corporation
Recipient: Smieszek, Erwin: US EPA
Attached: GEW-001-2427
>oeunent Number: GEW-001-2464 To 2464 Date: 08/26/93
Title: (Letter re: Draft Baseline Risk Assessment, G.E. Wiring Devices Site, Juana Diaz, Puerto Rico,
and Health and Endangerment Assessment Work Assignment)
Type: CORRESPONDENCE
Author: Graber, Scott B.: COM Federal Programs Corporation
Recipient: Smieczek, Erwin: US EPA
Attached: GEW-001-2465
Document Nutfcer: GEW-001-0689 To 0689 Date: 04/24/85
Title: (Letter re: Analytical Results of Priority Pollutant Analysis of Water Sample from Stand-Pipe
No. 11, General Electric Juana Diaz Facility)
Type: CORRESPONDENCE
Author: Hart, Steven W.: Law Engineering Testing
Recipient: Font, Jost C.: US EPA
Attached: GEW-001-0690 C£W001-0691 GEW-001-0692
-------
Index Author Name Order
GE WIRING Documents
********xxxxxx*xxxxxxxxxxxxxxxx**xxxxxxx*xxxx*mxxxxxxxxxxxxmxxxxxxxxxxmxitxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
Document Nunber: GEW-001-1211 To 1211 OMe! 04/09/87
Title: (Letter re: Remedial Investigation Report, General Electric Wiring Devices Site, Juana Diaz,
Puerto Rico)
Type: CORRESPONDENCE
Author: Ignacio, Rafael L.: PR Industrial Development Company
Recipient: Gelabert, Pedro A.: US EPA
e: 21
•MXXXXXXXXXXXXXXXXX
Document Number: GEU-001-2335 To 2336
Title: (Letter re: Receipt of Draft Feasibility Study Report)
Type: CORRESPONDENCE
Author: Ignacio, Rafael L.: PR Industrial Development Company
Recipient: O'Neill, Carlos E.: US EPA
Date: 09/23/88
—.
it Number: GEW-001-0047 To 0047
Mtle: (Certificate of Analysis for eight water samples received 04/30/81)
Type: DATA
Author: illegible: Stewart Laboratories
Recipient: Phillips, J.M.: General Electric
Date: 05/19/81
Document Number: GEW-001-0099 To 0099 Parent: GEW-001-0048
Title: (Certificate of Analysis on two samples of waste Material)
Type: DATA
Author: illegible: Stewart Laboratories
Recipient: Phillips, J.N.: General Electric
Date: 06/18/81
Oocuwnt Number: GEU-001-0153 To 0157
Date: 02/15/62
Title: Attachment 2-5 Certified Laboratory Results (water samples from selected standpipes)
Type: DATA
Author: illegible: Omni Research Incorporated
Recipient: none: General Electric
-------
•t
V.
J7/15/97 Index Author Name Order Page: 22
GE WIRING Documents
Document Nurfcer: CEU-D01-05M To 0504 Parent: CEW-001-0503 Date: 06/18/81
Titlt: Certlficatt of Analysis (for tuo samples of waste material)
Type: LEGAL DOCUMENT
Author: it legible: Stewart Laboratories
Recipient: Phillips, Marvin: General Electric
Document Munber: GEW-001-0554 To 0554 Date: 02/04/82
Title: Water Analysis Report (for sample* received 01/28/82)
Type: DATA
Author: illegible: Caribtec Laboratories
Recipient: none: none
Document Number: GEU-001-0178 To 0183 Date: 09/29/82
*itle: (Letter re: Drilling and Monitoring Well Installation. General Electric Site, Juana Diaz,
Puerto Rico)
Type: CORRESPONDENCE
Condition: MARGINALIA
Author: Jernigan, Bruce L.: Law Engineering Testing ;
Recipient: Castillo, Luis Vasquez: Vazquez Agrait, Vazquez Castillo 4 Despiau
Document Number: GEW-001-0193 To 0196 Date: 10/28/82
Titlt: (Letter re: Attached Technical Response to EQB's Clay Continuity and Alluvial Contamination
Concerns, Juena Diaz Site, Puerto Rico, Law Engineering Project No. MH2317.01)
Type: CORRESPONDENCE
Author: Jernigan. Bruce L.: Law Engineering Testing
Recipient: Friss, James T.: General Electric
-------
tutnf '
'J0d«3 :
'u«idtj| :
33N30NOdS3aS03 :
'3-3 '
98/OZ/80 ••*
Vd3 Sn :*A uqor 'jodiza nuajdiaaj
33N3dNOdS3SW
(oaja oajanj 'ztjo
98/81/90 !»*•1l»»»«»«««««»»»«n»«lim«»»»»«««»»««««»««»««»»»««««»»»«»«»»««»»»«»»««»»»»"»»»»«»»"»»»J
siuaunaoQ ON lam 33
japjQ SNIIIN JOqmy xapu]
£2 :3-,d
-------
J7/15/97 Index Author Name Order Pass: 24
i CE WIRING Documents
•••••••••••••»•••»«»«""•*»»*»"•••••••»»»•»«««»•»»•»•«»•«»••«•»«••»«»•»»«»»«««»•»«»»«••»••••••»««
Docunent Number: CEW-001-0770 To 0770 Date: 09/23/86
Title: (Letter re: G.E. Wiring Devices Site. Juana Diaz, P.I.. CERCLA *106 Order)
Type: CORRESPONDENCE
Author: Kaplan, Arthur L.: General Electric _
Recipient: Font, Jose C.: US EPA
Attached: GEU-001-0771 CEU-001-0773 GEW-001-0774
Docunent Number: GEU-001-1494 To 1494 Oate: 12/08/87
Title: (Letter re: Administrative Consent Order Ho. II-CERCLA-3030, dated January 16, 1984, General
Electric Company, Juana Diaz, P.R. Plant)
Type: CORRESPONDENCE
Condition: MISSING ATTACHMENT
Author: Kaplan, Arthur L.: General Electric
Recipient: DiForte, Nicoletta: US EPA
Attached: GEW-001-1495
Document Number: GEW-001-0448 To 0449 Parents GEW-001-0447 Date: / /
Title: Principles of Engineering Geology and Geotechnics: Chapter 18: Earthquakes and Aseismic Design
Type: CORRESPONDENCE
Condition: INCOMPLETE
Author: Krynine, Dimitri P.: McGraw Hill Book Company
Recipient: none: none
Docunent Number: GEW-001-0444 To 0446 . Date: 06/06/83
Title: (Letter re: Flooding Analyses, Juana Diaz Site, Puerto Rico, Reference Proposal HS3022.20
••(Item 2), Law Engineering Project No. WH3233)
Type: CORRESPONDENCE
Author: Lawing, Raymond J.: Law Engineering Testing
Recipient: Schauseil, Robert I.: General Electric
-------
T
J
17/15/97 Index Author Name Order P«8e: 25
GE WIRING Docunents
Document Number: 6EU-001-0616 To 0620 Date: 10/07/83
Title: (Letter re: Evaluation of hazardous site* in Puerto Rico for inclusion on the National Priorties
List)
Type: CORRESPONDENCE
Author: LlbMzzi. William J.: US EPA
Recipient: Madera, Jose R.: PR Economic Development Administration
Document dumber: GEW-001-0511 To 0549 Date: 08/04/82
Title: Hazardous Ranking System Scores Package: General Electric - Wiring Devices of Puerto Rico
Type: OTHER
Author: Lipsky, David: US EPA
Recipient: none: none
Attached: GEW-001-0537 GEW-001-0549
*
locunent Number: GEW-001-0549 To 0549 Parent: GEW-001-0511 Date: 04/21/82
Title: Sampling Trip Report (at Juana Diaz site for sampling trip on 04/19/82 and 04/21/82 and stating
"measurements taken with Bachrach Mercury Sniffer along fence perimeters- No mercury detected")
Type: PLAN
Condition: MISSING ATTACHMENT
Author: Lipsky. David: US EPA
Recipient: none: none
Document Number: CEW-001-0243 To 0245 Date: 01/13/83
Title: (Letter r«: Attached Brief Statement on analyses of data gathered on the Hydrogeologic Investigation)
Type: CORRESPONDENCE
Author: Long, David T.: Ml State University
Recipient: Jernigan, truce L.: Law Engineering Testing
-------
07/15/97
*«•«••«•••••••
Index Author Name Order
GE WIRING Documents
Page: 26
Document Number: GEW-001-2194 To 2198
Title: (Memorandum r«: Discharge of Wastewater from CERCUA Sites into POTWS)
Type: CORRESPONDENCE
Condition: MARGINALIA
Author: Longest, II, Henry L.: US EPA
Recipient: none: US EPA
Date: 04/15/86
Docunent Number: GEU-001-1315 To 1315
Date: 04/30/87
Title: News article titled: "Mercury Only Pol.lutant Found at GE Juana Diaz Waste Site: GE dump one
of eight P.*. Superfund sites; total estimated cleanup cost could be *37M"
Type: OTHER
Author: Luxner, tarry: Caribbean Business
Recipient: none: none
ocunent Number: GEW-001-0608 To 0608
Title: (tetter re: On-site disposal of hazardous and/or toxic wastes)
Type: CORRESPONDENCE
Author: Madera. Jose R.: PR Economic Development Administration
Recipient: DeSorbo, L.A.: General Electric
Date: 02/08/83
Document Number: GEU-001-0613 To 0613
Parent: GEW-001-0612
Date: 04/11/83
Title: (tetter re: Technical Alternatives available for correcting the environmental problems created
by the disposal of toxic wastes at the General Electric Manufacture Wiring Devices, Inc.)
Type: CORRESPONDENCE
Author: Madera, Jose ».: PR Economic Development Administration
Recipient: Rivera, Ignacio: General Electric
-------
a 115/97
Index Author Name Order
GE WIRING Documents
Page: 27
Document timber: CEW-001-06U To 06U
Title: (Letter re: On-site encapsulation of toxic wastes)
Type: CORRESPONDENCE
Author: Madera, Jose R.: PR Economic Development Administration
Recipient: Rivera, Ignacio: General Electric
Attached: GEW-001-0615
Date: 09/28/83
Document Hunter: GEW-001-0615 To 0615 Parent: GEU-001-0614 Date: 08/04/83
Title: (Letter re: Immediate action for proper disposal of mercury contaminated wastes)
Type: CORRESPONDENCE
Author: Madera, Jose R.: PR Economic Development Administration
Recipient: Rivera, Ignacio: General Electric
Document Number: GEW-001-0647 To 0649
itle: (Letter re: Complete removal of toxic waste from the site)
Type: CORRESPONDENCE
Author: Madera, Jose R.: PR Economic Development Administration
Recipient: Rivera, Ignacio: General Electric
Date: 01/27/84
Document Number: GEW-001-0657 To 0659
Date: 03/09/84
Title: (Letter re: General Electric Company, EPA Order on Consent, Index Ho. II CERCLA-30301, To
Clean Up Juana Diaz Plant Site)
Type: CORRESPONDENCE
Condition: MISSING ATTACHMENT
Author: Madera, Jose R.: PR Economic Development Administration
Recipient: none: US EPA
Document Number: GEW-001-0234 To 0242
Title: (Letter r«: Attached Chemical Analyses on the Water and Sediment Samples)
Type: CORRESPONDENCE
Author: Maroncelli, Janes N.: law Engineering Ttcting
^Recipient: Alexander, U. Joseph: Law Engineering Testing
Date: 01/11/83
-------
J7/15/97
Index Author Name Order
GE WIRING Documents
«•••••• ••••••••••«•»•••*•••••••••••••••••••••••«•••»•••••••**•••*•••«*•*••
Ooeunent Nunber: GEW-001-0286 To 0286 Parent: GEU-001-028S
Title: Results of Nercury Analyses, Law Engineering Project No. MH2317
Type: DATA
Author: Maroncelli, James H.: Law Engineering Testing '
Recipient: none: none
Date: / /
Page: 28
Docimnt Number: GEU-001-0385 To 0386
Title: (Letter re: Attached results of chemical analyses soil samples)
Type: CORRESPONDENCE
Author: Haroncelli, James M.: Law Engineering Testing
Recipient: Alexander, U. Joseph: Law Engineering Testing
Date: 03/11/83
Document Nutter: GEU-001-0537 To 0537 Parent: GEW-001-0511
Title: Results of Mercury Analyses, Law Engineering Project No. MH2317
Type: PLAN
Author: Maroncelli, James H.: Law Engineering Testing
Recipient: none: none
Date: / /
Document Number: GEW-001-0184 To 0192 Date: 08/27/82
Title: General Electric Company, Juana Diaz Plant, Retaining Wall (Muro de Comencion)
Type: GRAPHIC
Author: Marques, Jose A.: General Electric
Recipient: none: none
Document Nunber: GEU-001-1852 To 1852
Parent: GEW-001-1633
Date: 04/11/88
Title: (Inter-office Moorandun re: Project 6331 - GE Juana Diaz, Work Performed July to September,
1986}
Type: CORRESPONDENCE
Author: McBride, Clifford H.: Law Engineering Testing
Recipient: Sellers, Nark A.: Law Engineering Testing
-------
17/15/97 Index Author Name Order Psi«: 29
GE WIRING Documents
Document Number: GEW-001-1395 To U15 Parent: GEW-001-1345 Date: 12/02/86
Title: (Letter re: Attached Report of Preliminary Testing and Evaluation, Solidification/Fixation
Agent, G.E. Wiring Devices Plant, Juana, Puerto Rico)
Type: CORRESPONDENCE
Author: McNeils, Kathleen A.: Law Environmental Services
Recipient: Schauseil, Robert I.: General Electric
Document Number: GEU-001-1854 To 1856 Date: 05/12/88
Title: (Memorandum re: Mercury Validation Results)
Type: CORRESPONDENCE
Author: Messina, Frank J.: US EPA
Recipient: DiForte, Nicoletta: US'EPA
ocument Number: GEW-002-0044 To 0075 Date: 09/30/88
.itle: Record of Decision, G.E. Wiring Devices, Juana Diaz, Puerto Rico
Type: REPORT
Author: Muszynski, William J.: US EPA
Recipient: none: none
Document Number: GEW-001-0198 To 0217 Date: 11/22/82-
Title: (Letter re: Attached Status Report of Hydraulic Conditions, Perched-Water Table; Waste Fill
Area, Juana Diaz Plant, Puerto Rico, Lau Engineering Project No. MH1440.03)
Type: CORRESPONDENCE
Author: Alexander, W. Joseph: Law Engineering Testing
Heal, Larry A.: Law Engineering Testing
Recipient: Schauseil, Robert I.: General Electric
-------
07/15/97 Index Author Name Order Page: 30
GE WIRING Documents
Document Number: GEW-001-M14 To 0433 Dete: 04/20/83
Title: (Utter re: Report of Test Results, Juana Diaz Site, Puerto Rico, Reference Proposal MS3022.20
(Items 3 and «>, Law Engineering Project No. WM3233)
Type: CORRESPONDENCE
Author: Alexander. U. Joseph: law Engineering Testing
Neal, Larry A.: Law Engineering Testing
Recipient: Schauceil, Robert I.: General Electric
Document Number: GEW-001-0690 To 0690 Parent: GEW-001-0689 Date: 03/19/85
Title: (Letter re: Analytical Results of Priority Pollutant. Analysis of Water Sample from Stand-Pipe
No. 11, General Electric Juana Diaz Facility)
Type: CORRESPONDENCE
Author: Neal, Larry A.: Law Engineering Testing
Shugart, Steven L.: Law Engineering Testing
Recipient: Schauseil, Robert I.: General Electric
Document Number: GEU-001-0755 To 0755 Parent: GEU-001-0754 Date: 12/13/85
Title: (Letter re: Proposed Schedule of Soil Sampling for Trichlorewthylene, G.E. Juana Diaz, Puerto
•Rico Plant)
Type: CORRESPONDENCE
Author: Neil, Larry A.: Law Engineering Testing
Recipient: Font, Jose C.: US EPA
Document Number: GEU-001-0231 To 0233 Date: 12/20/82
Title: Permeability test results from boring locations MU-2 and HW-4 taken 12/13/82-12/20/82
Type: DATA
Author: O'Kelly, N.: Law Engineering Testing
Recipient: none: none
-------
07/15/97 Index Author Name Order Page: 31
GE WIRING Document*
Document Number: GEW-001-2427 To 2463 Parent: GEW-001-2426 Date: 12/01/93
Title: Revised Baseline Risk Assessment Addendum for the G.E. Wiring Devices Site, Work Assignment
No. C02120
Type: REPORT
Author: Oxford, Jeniffer: COM Federal Programs Corporation
Recipient: none: US EPA .
Document Number: GEW-001-0434 To 0443 Date: 05/25/83
Title: (Letter re: Seismic Risk of the Proposed Encapsulation Alternative, Waste Fill Area, Item
1 of Proposal No. MS3022.20, taw Engineering Project No. WM3233)
Type: CORRESPONDENCE
Author: Parker, Mark: Law Engineering Testing
Recipient: Schauseil, Robert I.: General Electric
Document Number: GEW-001-2199 To 2208 Date: 12/24/86
Title: (Memorandum re: Interim Guidance on Superfund Selection of Remedy)
Type: CORRESPONDENCE
Author: Porter, J. Winston: US EPA
Recipient: none: US EPA
Attached: GEW-001-2209
Document Number: GEW-001-2228 To 2236 Date: 07/09/87
Title: (Memorandum re: Interim Guidance on Compliance with Applicable or Relevant and Appropiate
Requirements)
Type: CORRESPONDENCE
Condition: MARGINALIA
Author: Porter, J. Winston: US EPA
Recipient: none: none
-------
J7/15/97
Index Author Name Order
CE WIRING Documents
•*••»»••••«••••••••••••
Document Umber: GEU-001-0219 To 0219 Parent: CEU-001-0218
Title: (Utter re: Enclosed copy of the original test boring field logs)
Type: CORRESPONDENCE
Author: Ramirez, Hector Laverone: Caribbean Soil Testing Company
Recipient: Schauseil, Robert I.: General Electric
Page: 32
Date: 12/10/82
Document Nunber: GEW-001-0692 To 0700
Title: Data Report Notice and Report of Data
Type: PUN
Author: Scanned, Diana A.: ConpuChem
Recipient: Neil, Larry A.: Law Engineering Testing
Parent: GEW-001-0689
Date: / /
Document Number: GEU-001-0722 To 0729 Parent: GEW-001-0701
Title: (Letter re: Report for analysis of sample from monitoring well No. 1)
Type: .CORRESPONDENCE
Author: Scanmell, Diana A.: CompuChem
Recipient: Neil, Larry A.: Law Engineering Testing
Date: 08/22/85
Document Nuafcer: GEW-001-0730 To 0737 Parent: GEU-001-0701
Title: (Letter re: Report for analysis of sample from monitoring well No. 2)
Type: CORRESPONDENCE
Author: Scanmell, Diana A.: ConpuChem
Recipient: Neil, Larry A.: Law Engineering Testing
Date: 08/22/85
Oocuaent Number: GEW-001-0738 To 0745 Parent: GEU-001-0701 Date: 08/22/85
Title: (Letter re: Attached report for analysis of sample from Monitoring well No. 3)
Type: CORRESPONDENCE
Author: Seamed, Diana A.: CoopuChew
Recipient: Neil, tarry A.: Law Engineering Testing
-------
J7/15/W Index Author Mame Order Page: 33
CE WIRING Documents
*mm***M****m************************************************************v********************mmmmm*mm*m*™
Document Nurtwr: GEW-001-0746 To 0753 Parent: GEW-001-0701 Date: 08/22/85
Title: (Letter re: Attached analysis results of sample from monitorins well No. 4)
Type: CORRESPONDENCE
Author: Scammell, Diana A.: CompuChem
Recipient: Neil. Larry A.: Lau Engineering Testing
Docustnt Number: GEU-001-0621 To 0663 Date: 01/16/84
Title: Administrative Order on Consent (regarding actions and studies to be done at Juana Dial site)
Type: LEGAL DOCUMENT
Condition: MARGINALIA
Author: Schafer, Jacqueline E.: US EPA
Recipient: Vineyard, William: General Electric
Attached: GEW-001-0644
|ocuroent Number: GEW-001-0218 To 0218 Date: 12/13/82
Title: (Letter re: Enclosed copies of Driller's Logs)
Type: CORRESPONDENCE
Author: Schauseil, Robert I.: General Electric
Recipient: .de la Cruz, Luis E.: PR Environmental Quality Board
Attached: GEW-001-0219 GEW-001-0220
Document Number: GEU-001-0505 To 0508 Date: 06/05/81
Title: Notification of Hazardous Waste Site: General Electric Company - Hiring Devic.es Department
Type: OTHER
Author: Schauseil, Robert !.: General Electric
Recipient: Frisco, John S.: US EPA
Document Number: 6EW-001-OSS3 To 0553 Date: 12/09/82
Title: (Letter re: Receipt of November 29, 1982 letter)
Type: CORRESPONDENCE
Author: Schauseil, Robert I.: General Electric
Recipient: de la Cruz. Luis E.: PR Environmental Duality Board
-------
»
)
J7/15/97 Into* Author Name Order Plge: 34
GE WIRING Documents
Document Number: CEW-001-0610 To 0611 Date: 02/25/83
Title: {Letter re: Coanent* on Proposed Amendment to National Oil and Hazardous Substance Contingency
Plan; the National Priorities list, 47 Federal Register 54.476, December 30, 1982)
Type: CORRESPONDENCE
Author: Schausefl, Robert I.: General Electric
Recipient: Wyer. Russell H.: US EPA
Oocunent Number: GEU-001-1895 To 1918 Parent: GEW-001-1857 Date: 08/22/88
Title: (Letter re: Status report on the work performed by the Bureau of Nines with attached Bureau
of Mines Report)
Type: CORRESPONDENCE
Author: Schmidt, William I.: US Dept of the Interior
Recipient: DiForte, Nicoletta: US EPA
locument Nurober: GEU-001-23B2 To 2382 Date: 10/27/88
Title: (Letter re: Attached copies of the final version of the Bureau's report)
Type: CORRESPONDENCE
Author: Schmidt, William B.: US Dept of the Interior
Recipient: Oiforte, Nicoletta: US EPA
Attached: GEU-001-23S3
Document Number: GEW-001-0775 To 0775 Date: 10/06/86
Title: (Letter re: Submittal of Report, Remedial Investigation, General Electric Wiring Devices Site,
Juana Diaz, Puerto Rico)
Type: CORRESPONDENCE
Author: Sellers, Nark A.: Law Engineering Testing
Recipient: Czapor, John V.: US EPA
Attached: GEU-001-0776
-------
8££0-lOO-ft33
VI1VNIOSVH
33N3QNOdS3SS03
put si)»n J»J8n tuojj.
01
13 itjauag :•
J»auj8u3 nai
8uus»i
(Xinptj ziig Buonr 3jj}3*i3 itjawg '^ -ON
S9/6l/£0 !»»«0 6890-100-039 :juaj*d 0690OL 0690-100-(139 '
Vd3 sn :*3 »sop 'auoj :
ni
ut sn»n jajt«-punoj6 uo
S8/60/M ?»l«0 8890 «i /890-LOO-fl33
33H30NOdS3iM(03
tutnr '»JJS «»3}Aao BuiJjn 3{j)3«]3 juauao 'Xpnjs Sj/18 *M) O) urpuappy
Z8/ZI/U :'1«0 9691-100-139 :iu»j»d l£9i 01 $691-100-139 :
9KUJI/1 39
-------
(9961
uo paA}»3»a ««]dut«s
99/ZO/Zl :
33H3l-lQO-fl30 :
Xjnaj»H »A|jej«diuo3
98/U/60 :
if J
:-f juasuiA 'ou8»tJ»i :jomny
Xq Xpnj»
o» mas sa)du»s i.ios ^o sasA)tuy :aj
'3'D
98//Z/01 :
auou :auou :
'ZIIQ ruinr '
Xpnis
01
9£ !
tuenp -3-9 '
99/01/10 :*1»0
Vd3 SO "3 »»or 'juoj :iu«}d|3«)|
(»u«id
95/0 01 9SZO-100-N30 :j*qunn
********************************
30
xaput
/6/Sl/ZO
-------
J7/15/97 Index Author Nsme Order Page: 37
GE WIRING Document s
Document Number: GEW-001-2210 To 2213 Oute: 05/21/87
Title: (Letter re: Agency's implementation of the Superfund Amendments and Reauthorization Act of
1986 (SARA))
Type: CORRESPONDENCE
Author: Thous, Lee N.: US EPA
Recipient: Florio, Ja*ec J.: US Congress
Attached: GEW-001-22U
Document Number: GEW-001-2333 To 2334 Date: 09/22/88
Title: (Letter concurring with EPA that alternative 9, Hydrometallurgical Treatment, is the most
environmentatly sound and safe alternative while noting nore detailed studies on groundwater
are needed prior to taking any action)
Type: CORRESPONDENCE
Author: Torres, Neriberto: PR, Commonwealth of
Recipient: O'Neill, Carlos E.: US EPA
Document Number: GEW-001-0612 To 0612 Date: OS/27/83
Title: (Letter re: General Electric Wiring Devices, Juana Diaz, Puerto Rico)
Type: CORRESPONDENCE
Author: Umpierre, Victor R.: PR Economic Development Administration
Recipient: Diamond, Larry: US EPA
Attached: GEW-001-0613
Document Number: GEW-001-2218 To 2219 Date: 05/29/87
Title: (Memorandum re: Review of Interim Guidance on Compliance with ARAR's)
Type: CORRESPONDENCE
Author: Ueissman, Arthur I.: US EPA
Recipient: none: none
Attached: GEW-001-2220
-------
07/15/97 Index Author Name Order Page: 38
GE WIRING Documents
Doctnent Number: GEW-001-0163 To 0165 Date: 02/23/82
Title: (Letter re: Response to U.S. EPA'S Review. Juana Diaz, Puerto Rico Study, by Mr. John S. Frisco,
Chief, Hazard Assessment Section, Law Engineering Project No. HH1367)
Type: CORRESPONDENCE
Condition: HISSING ATTACHMENT
Author: White, Robert M.: Law Engineering Testing
Recipient: Phillips, Marvin: General Electric
-------
> *
-4
APPENDIX 2
-------
-------
APPENDIX 2
RESPONSIVENESS SUMMARY
G.E. WIRING DEVICES SUPERPDND SITE
JUANA DIAZ, PUERTO RICO
In accordance with Sections 113 and 117 of the Comprehensive
Environmental Response, Compensation and Liability Act, as amended,
EPA has conducted community involvement activities at the G.E.
Wiring Devices Superfund Site (the "Site") to solicit community
input and ensure that the public remains informed about Site
activities. EPA's Post-Decision Proposed Plan was released to the
.public on April 26, 1999. A copy of the Post-Decision Proposed
Plan was placed in the Administrative Record and was made available
in the information repository at the Press Office at the Mayor's
Office, Juana Diaz City Hall. A public notice was published in the
San Juan Star in San Juan, Puerto Rico on April 26, 1999, advising
the public of the availability of the Post-Decision Proposed Plan
and the Focused Feasibility Study, and the date of the upcoming
public meeting. The public notice also was published in El Nuevo
Dia in San Juan on May 10, 1999.
During the public comment period, EPA held a public meeting at
Juana Diaz City Hall on May 13, 1999, to answer questions and
receive comments on the Agency's preferred alternative for
addressing Site contamination. Comments received during the public
meeting were recorded in an official transcript; a copy is included
in the Administrative Record and information repository. The
public comment period opened on April 26, 1999 and closed on May
25, 1999.
This responsiveness summary provides information about the
community's views regarding EPA's proposed action, documents how
the Agency has considered public comments during the decision-
making process, and provides answers to major comments received
during the public comment period. EPA received many comments
regarding issues unrelated to EPA's proposed remedy change. All
comments are summarized in this document; however, only those
comments related to the proposed remedy change for off-site
disposal have been considered in EPA's final decision for selection
of a remedial alternative for the Site.
These sections follow:
o Overview: This section discusses the recommended action for
the Site and the public reaction to this alternative.
-------
o Background on Community Involvement: This section provides a
brief history of community interest in the Site and identifies
key public issues.
o Summary of Comments Received During the Public Comment Period
and Agency Responses: This section provides EPA's responses
to oral and written comments submitted during the public
comment period, and is divided into two parts, as follows.
Part I: Summary and Response to Local Community Concerns
Part II: Comprehensive Response to Specific Legal and
Technical Questions
o Remaining Concerns: This section discusses issues and
concerns that EPA was unable to address during the remedial
planning activities.
o Attachment A - Community Relations Activities at G.E. Wiring
Devices Superfund Site: This attachment contains a list of
community relations activities conducted at the Site to date.
A. OVERVIEW
At the time of the public comment period, EPA had identified a
preferred alternative for the Site, which would replace only a
focused portion of the September 30, 1988 Record of Decision. EPA
documented this change in its Post-Decision Proposed Plan, dated
April 26, 1999. The recommended alternative involves the off-site
disposal of all remaining Site wastes at a permitted RCRA Subtitle
C hazardous waste landfill located on the mainland United States,
in place of on-site treatment and backfill of processed wastes
using the G.E. Mercury Extraction Process treatment system, which
was a part of the original remedy.
This modification is in direct response to significant variations
in Site conditions which were encountered during excavation and
construction phases of the original remedy. These variations made
the original, remedy less effective, less implementable, and more
costly than other remedial alternatives. EPA has not changed the
mercury cleanup level it adopted for the Site in 1993, which
remains at the residential preliminary remediation goal (PRG) of 39
parts per million (ppm).
Judging from the comments received during the public comment
period, local residents and other concerned parties generally
support the Post-Decision Proposed Plan, and agree that off-site
disposal provides equivalent protection of human health and the
environment, greater implementability, fewer short-term risks, and
significantly lower costs when compared to the original remedy.
-------
The public also understands that the preferred alternative would be
accomplished within a few months and is consistent with Site-
specific cleanup requirements.
B. BACKGROUND ON COMMUNITY INVOLVEMENT
Since discovery of environmental problems at the Site, EPA has
worked closely with residents in the affected community to solicit
their concerns and answer their questions on a regular basis.
Based upon community reaction, EPA has revised its Community
Relations Plan for the Site twice, prior to the Remedial
Design/Remedial Action phase in July 1992 and at the start of
Remedial Action activities in May 1997.
During community interviews conducted in April 1992, residents in
the neighborhood adjacent to the Site expressed their concerns
about three main issues: 1) lack of sufficient information on the
Superfund process and how it applies to the Site, 2) potential
effects of the Site contamination on public health and the
environment, and 3) their reaction to sampling activities.
In March 1997, issues and concerns solicited during the community
interviews were focused on issues related more closely to the
Remedial Action. These included:
o Off-site migration of contamination
o Cleanup technology and schedule
o Current monitoring activities
o Public health and safety
o Ongoing communication efforts.
In August 1997, EPA prepared and distributed a fact sheet to the
community in English and in Spanish which directly addressed these
community concerns in a special question-and-answer section.
The major concerns and how EPA addressed them are presented below:
(1) Residents were concerned that Site contamination could reach
the ground water and migrate to their properties during heavy rain
and flood conditions.
EPA Response: Mercury has not migrated from those areas where
plastic and other scrap materials were deposited. Surface water
runoff from the fill area is controlled, and will continue to be
controlled throughout the cleanup. Run-off to adjacent residences
is from the south field, an area of property which is not
contaminated.
-------
(2) Residents requested more information on the cleanup
technology, an explanation of the term "clean soil," and an overall
time frame for the cleanup process.
EPA Response: EPA described the cleanup technology in basic
language in the August 1997 fact sheet. EPA also defined its
established cleanup level for mercury in soil as 39 parts per
million. The fact sheet presented a project schedule with major
milestones and anticipated completion dates. In addition, EPA held
an informational meeting with the community on September 23, 1997
to 'discuss the cleanup technology and answer questions.
(3) Residents expressed some confusion about sampling events and
requested their soil sampling results.
EPA Response: In May 1997, EPA prepared letters and sent them
to residents on Calle #2 whose properties were sampled in 1993.
The letters presented the sampling results and compared the mercury
concentrations found in the samples with the cleanup levels
considered by EPA to be safe for human health. The letters also
contained information on the potential health effects of exposure
to mercury.
(4) The^community wanted to know if G.E. Wiring continued to use
mercury in its manufacturing process?
EPA Response: G.E. Wiring has not used mercury in its
manufacturing process at the Juana Diaz facility since 1970.
(5) Residents wanted to know the whereabouts and contents of drums
that were once located near G.E. property.
EPA Response: Drums were used to contain materials produced
during soil sampling and well installation activities. The drums
were sent off-site for proper disposal.
(6) Residents asked about the purpose of red markers observed in
back of the G.E. facility.
EPA Response: The red markers identify soil sampling
locations.
(7) Residents wanted to know what steps would be taken to minimize
disturbances to residents and their properties during the cleanup.
In particular, during the excavation and construction activities,
they were concerned about the spread of rodents to nearby houses.
EPA Response: G.E. will take precautions normal to other
construction projects in Puerto Rico, including the use of silt
-------
fencing, control of working hours, etc. In addition, G.E. will
provide temporary visual barriers and take steps to minimize noise.
G.E. will hire a local exterminator to control rodents.
(8) The community asked about specific measures G.E. will take to
maintain the formerly contaminated site.
EPA Response: G.E. will replant the Site with grass and
maintain a cover on the former waste-fill area. G.E. will also
maintain a fence around the Site.
(9) The community expressed concern about a possible link between
the Site contamination and various illnesses in their families.
They wanted to know whether mercury exposure could cause human
health problems, such as cancer, Parkinson's Disease, asthma, or
allergies, and asked about available studies on the subject. They
also were concerned about health risks to current G.E. employees.
EPA Response: There is no clear medical evidence that mercury
can cause cancer, allergies, or Parkinson's Disease in humans.
Extreme exposure to mercury can cause harmful effects on the
central nervous system and kidney. Lung reactions can also result
from inhalation exposure to mercury vapors, while stomach problems
may follow significant swallowing of organic mercury compounds.
Body levels of mercury can be accurately determined using either
blood or urine samples.
The potential risk associated with mercury exposure to GE factory
employees and neighboring residences resulting from the cleanup
work to be completed and the residual mercury level, (below the 39
ppm PRO) to be left in placed is considered to be minimal. EPA
will use cleanup methods at this site that are designed to prevent
environmental releases.
(10) Residents, local officials, and other interested parties were
eager to receive information on cleanup activities, and suggested
a variety of techniques to stay informed of Site news. The Mayor's
Office in cooperation with the Press Office expressed a willingness
to distribute information to the community, and to relocate the
information repository to Juana Diaz City Hall.
EPA Response: Residents will be kept informed through the
information repository, which was relocated to the Mayor's Press
Office at Juana Diaz City Hall, and through distribution of
periodic newsletters and fact sheets. EPA will inform the local
community of completion of the cleanup project through a public
notice. (See Attachment A for a complete listing of community
relations activities at the Site.)
-------
C. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
AND AGENCY RESPONSES
The public comment period on the Focused Feasibility Study and
Post-Decision Proposed Plan was held from April 26, 1999 to May 25,
1999. The following correspondence was received during that time
period:
o Letter from Rene R. Rodriguez (citizen) dated May 17, 1999
o Letter from the General Electric Company dated May 22, 1999
A summary of the comments contained in the above letters and the
comments provided by the public at the May 13, 1999 public meeting,
as well as EPA's responses to those comments, is provided below.
Part I of this section addresses those community concerns and
comments that are non-technical in nature. Responses to specific
legal and technical questions are provided in Part II. Comments in
each Part are categorized by relevant topics.
Part I - Summary and Response to Local Community Concerns
Public Participation Process
(1) A resident of the community requested that EPA review the
translation of the public meeting. He was concerned that the
facilitator did not translate word for word.
EPA Response: EPA contracted to have an interpreter at the
public meeting to assist with communications between the
community and EPA. A court reporter also was at the meeting
to record the entire meeting proceedings. The court reporter
recorded comments and responses of both the public and the
interpreter spoken in Spanish. An audio recording of the
meeting was used to translate into Spanish those comments and
responses given in English. A copy of the transcript is
available for review in the information repository at the
Major's Press Office in Juana Diaz and at the EPA Caribbean
Division Office located at 1492 Ponce DeLeon Avenue, Suite
207, Santuce, Puerto Rico. EPA has reviewed the transcript to
assure that EPA's Responses are accurate in addressing the
comments received.
(2) One citizen expressed concern that EPA did not present
sufficient technical data for citizens to make an informed choice.
He proposed that EPA hold another public meeting in the near future
to present technical data to support the decision-making process
for the preferred alternative.
-------
EPA Response: EPA presented the technical reasons for the
proposed change at the May 13, 1999 meeting. The primary
technical reasons relate to significant differences between
the actual site conditions encountered during construction and
the conditions which served as basic assumptions in developing
the 1988 ROD. The significant differences are: 1) increased
waste volume and 2) increased composition of silt and clay
materials (fines) in the waste. EPA also presented the
impacts of the changes in both waste volume and
characteristics to the existing ROD remedy as reasons for the
proposed change to off-site disposal. EPA feels that another
public meeting is not warranted. However, we are available to
discuss this further with any citizen who is interested.
Preferred Alternative
(1) Residents raised questions regarding the permeability of the
clay layer and the permeability of the clean material proposed as
backfill. They are concerned about the potential adverse impacts
of backfilling the excavated area (West Field) with clean material
that is more permeable than the underlying clay layer. They
reported that clay fill materials, which are less permeable and are
comparably priced to other imported clean material, are readily
available in Juana Diaz.
EPA Response: The 1987 Remedial Investigation and additional
sampling data collected in 1988 indicated the permeability of
the clay layer to be in the range of 10'4 to 10'5 cm/sec. EPA
considered these values as demonstrating moderate
permeability. The risk-based cleanup goal of 39 ppm was
calculated assuming that the site would be developed for
residential use at some future point in time, considering
relevant exposure pathways. The cleanup goal does not consider
placement of a low-permeability cap (e.g. clay, HDPE liner)
over soils containing residual levels of mercury below this
concentration. The residential exposure scenario is more
conservative than the scenario associated with the current
industrial/commercial use for the site. Any consideration of
industrial/commercial future site use or installation of a
protective cap in the risk-based calculation would result in
a higher cleanup goal. The 39 ppm cleanup goal is considered
by EPA to be protective of human health and the environment.
(2) A citizen suggested that EPA evaluate the use of a HOPE cover
system, if material more permeable than the underlying clay layer
is used as backfill.
EPA Response: EPA selected and described in the Declaration
Statement of EPA's 1988 ROD the major components of the
-------
selected remedy. One of the major components of the selected
remedy was the treatment of material to below health-based
levels (39 ppm of mercury) based on residential use of the
property and backfilling the area with treated materials. The
area would then be covered with 2 feet of clean imported soil,
which was considered suitable as an added physical barrier to
prevent exposure to backfill material containing residual
levels of mercury. Under the new proposed remedy, the entire
waste area would be backfilled with clean imported soil. EPA
believes that there is insufficient technical basis to support
the need for an HDPE cover system, since, under the proposed
remedy, the entire excavated area will be backfilled with
clean imported fill material.
(3) The community is concerned about runoff from the excavated
area during rain events. In particular, residents are concerned
that the excavated area will be subject to overflow conditions,
causing the migration of any remaining residual contamination.
EPA Response: Existing data from soil samples collected at
neighboring residential properties do not support that
significant amounts of mercury were transported off-site by
runoff during historic storm events. Presently, runoff from
the excavation and stockpile areas is fully contained and
treated on-site. Upon completing excavation work, the area
will be backfilled, graded, and vegetated to conform with the
pre-existing topography and runoff flow characteristics.
Soils containing residual mercury concentrations below the 39
ppm cleanup goal will be predominantly located underneath
several feet of clean fill material and will not be exposed to
off-site transport by erosion, runoff, or other mechanism.
(4) ^ The community is concerned about the potential for mercury to
infiltrate into drinkable ground water. They reported that a
municipal supply well is located 500 feet to the west of the Site.
Therefore, the community questioned why the preferred alternative
specifies groundwater monitoring for three years and not a longer
period of time.
EPA Response: In the 1988 ROD, EPA included limited
groundwater monitoring (i.e., for a minimum of three years),
provided that additional groundwater investigation established
that there was no need for groundwater remediation. In 1993,
additional monitoring wells were installed, and groundwater
sampling was performed to address this requirement. The
analytical results from groundwater samples did not indicate
the presence of unacceptable risks associated with groundwater
exposure. Therefore, EPA believes 3 years of groundwater
monitoring following the completion of the remedial action
-------
work (e.g. off-site disposal and backfilling with clean
material) to be sufficient for protection of human health and
the environment. The remedy selected at this Site will allow
for unlimited use and unrestricted exposure. EPA will oversee
the removal of contaminated soils and will review three years
of ground water sampling results to insure the protectiveness
of the remedy.
(5) Several residents expressed frustration regarding the length
of time to solve environmental problems at the Site and complete
the cleanup process. They noted that 10 years have passed since
the original ROD and wonder how much longer the process will take.
EPA Response: EPA plans to advise G.E. to begin off-site
removal of waste materials after the ROD Amendment is issued.
It is hopeful that all material from the Site will be removed
by (or before) the end of the year. Groundwater monitoring
will continue for at least 3 years. A
Risks to Human Health and the Environment
(1) A worker wanted to know if mercury could permeate her lungs or
get into her blood. This worker also reported finding mercury in
the bottom of her toilet bowl and was concerned about how it got
there.
EPA Response: The potential for airborne emissions currently
does not exist. In 1997, G.E. removed all the run-off
materials from the South Field and processed all the
contaminated materials. Currently, all the materials are
under tarps to prevent runoff and airborne migration. G.E.
performed some testing during the remedial investigation and
confirmatory air monitoring was a major component of the 1988
ROD. Confirmatory air monitoring was also performed during
excavation and physical treatment work completed from June
1997 to May 1998 to document that unacceptable levels of dust
and mercury did not become airborne during the course of work.
Confirmatory air monitoring will resume and continue through
completion of the remedial action work.
Ginger M. Rossy, Environmental Quality Board representative,
is investigating the potential presence of mercury in this
worker's home.
(2) A community member reported anecdotal material about deaths
and illnesses of people who lived in Juana Diaz and were in some
way connected to G.E. He was concerned that these illnesses might
be related to mercury contamination at G.E. and was disappointed
-------
that no medical personnel were at the meeting to address his
concerns.
EPA Response: Refer to EPA's response to Question No. 9 on
page 5 .
(3) Residents on Calle #2 are worried that the duration of time
that has passed since Site discovery may increase their risks for
Site-related health problems. They are concerned about future
health problems, because of long-term exposure to mercury waste at
the G.E. facility.
EPA Response: EPA included re-sampling of soil in residential
yards as a component of the remedy selected in the 1988 ROD.
Residential soil sampling was performed in 1993, and again in
April and May 1998. All results were below the residential
remediation goal of 39 ppm. The predominant exposure routes
for this site are ingestiori and inhalation. As existing data
do not support that significant quantities of mercury have
migrated off-site via air, surface water, or other transport
mechanisms, EPA believes that the potential exposure
associated with occupying neighboring residences to be
minimal.
(4) Residents of Calle #2 stated that during Hurricane George, flB
their property was flooded and residual mud was left on their ^^
property. They wanted a guarantee that their yards did not contain
any contamination related to the G.E. Wiring Site.
EPA Response: Runoff from the excavation and stockpile areas
is fully contained and treated on-site, preventing off-site
transport of contaminated materials. Tarps blown off of
stockpiled materials were also replaced and re-secured by G.E.
within one month of the storm. However, G.E. indicated that
it will collect soil samples from the neighboring residential
properties. A notice will be sent in advance of the sampling
events to ensure that the affected residents will be at home.
Extent of Site Contamination
(1) Residents wanted to know if mercury contamination is moving
off-site and, if so, in what direction to determine the safety of
their neighborhood. Also, will the contamination migrate off-site
in the future?
EPA Response: Mercury has not migrated from those areas where
plastic and other scrap materials were deposited. Surface
water runoff from the excavation and stockpile areas is
contained and treated on-site. It will continue to be
10
-------
controlled until the remedial action work is completed.
Historic runoff to adjacent residences was from the south
field, an area of property which is not contaminated. EPA
believes the Site contamination will not affect the adjacent
or distant residential neighborhoods.
(2) Residents wanted to know to what depth the mercury
contamination was found at the Site.
EPA Response: Sampling conducted for the 1988 ROD detected
mercury contamination in on-site soils approximately within
six inches of the surface. At depths below six inches,
mercury concentrations were below health-based levels and
approached background levels. In the waste fill (West Field)
area, contamination was originally detected to depths of about
4 feet. However, excavation depths up to 17 feet were
required during construction (June 1997) to obtain
confirmatory soil sample results below the required cleanup
goal of 39 ppm.
(3) A resident reported that mercury waste was found off-site at
an abandoned landfill in Juana Diaz. He questioned what was being
done to investigate other potentially contaminated sites.
EPA Response: Carlos O'Niell, Superfund Branch Chief for the
EPA Superfund Division in San Juan, Puerto Rico explained that
his office was aware of this abandoned landfill. His office
is in the process of classifying and undertaking preliminary
investigations of landfills in Puerto Rico (including the one
in Juana Diaz) for possible Superfund action.
(4) The community is concerned about long-term impacts of residual
mercury-containing material of up to 39 ppm left at the Site.
EPA Response: The risk-based cleanup goal of 39 ppm was
calculated assuming that the site would be developed for
residential use at some future point in time. It does not
consider the placement of a low permeable cap or clean fill
material over soils containing residual levels of mercury
below this concentration. The residential exposure scenario
is more conservative than the scenario associated with the
current industrial/commercial use for the site. The 39 ppm
cleanup goal is considered by EPA to be protective of human
health and the environment, considering relevant exposure
pathways. , e
(5) . A worker at G.E. reported that he had buried mercury waste on-
Site at his supervisor's direction. He is concerned that EPA did
not find all the mercury at the Site.
11
-------
EPA Response: Sampling conducted for the 1988 ROD detected
mercury contamination in on-site soils within six inches of
the surface. At depths below six inches, mercury
concentrations were below health-based levels and approached
background levels. In the waste fill (West Field) area,
contamination was originally detected to depths of about 4
feet. However, excavation depths up to 17 feet were required
during construction (June 1997) to obtain confirmatory soil
sample results below the required cleanup goal of 39 ppm. EPA
believes that sufficient sampling and excavation was performed
at the Site to locate and remove all waste materials above 39
ppm.
Part II - Comprehensive Response to Specific Legal and Technical
Questions
Future Site Liability
(1) The community would like to know who will assume future
liability for the Site. The community is concerned that once G.E.
closes its Juana Diaz facility, G.E. will no longer be held
responsible for cleanup at the Site. The community wants to know
when G.E.'s responsibility for the Site ends.
EPA Response: EPA, under the enforcement authorities of the
Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), as amended, holds the G.E. Company, as
owner and operator of the G.E. Wiring Devices Site, liable for
the cleanup of the contamination at the Site. G.E. must meets
all cleanup conditions of the ROD, including long-term
monitoring. All of G.E.'s work at the Site will be performed
under EPA oversight. At some point in the future, once the
Site has been cleaned up to the satisfaction of EPA, it may be
deleted from the National Priorities List.
Proposed Remedy
(6) G.E. requested that EPA not place restrictions in the Amended
ROD which prevent or pose obstacles to alternative transportation
routes to the Port of Ponce in the event that the responsible party
can not obtain rights to transport Site materials across PRIDCO
property.
EPA Response: The ROD Amendment does not state what route is
to be used to transport the waste to the Port of Ponce.
(7) G.E. requested that EPA not place restrictions in the Amended
ROD which preclude or obstruct .the possible need to move some bags
12
-------
of Site material to an alternative location outside of the Site
area pending arrival of the barge for transport to the United
States. This request is based on the large volume of Site
materials to be bagged and transported and the relatively limited
space remaining on-Site to maneuver vehicles.
EPA Response: To the extent that G.E. wishes to use such a
temporary alternative storage location for this purpose, G.E.
should discuss the location with EPA in advance.
D. REMAINING CONCERNS
o Members of the community raised many health questions. They
want to know if residents who live close to the Site are
contaminated with mercury. They want to know if EPA is planning to
do medical tests of Juana Diaz residents. If some residents are
found to be ill, they want to know if G.E. will take
responsibility.
EPA Response: The Federal agency responsible for this type of
investigation is the Agency for Toxic Substances and Disease
Registry (ATSDR). There is a provision in the CERCLA law for
individual persons or local physicians to petition ATSDR to
perform a health assessment if the probable source of exposure
is a release. Further information on this procedures is
available from the ATSDR Regional Office in New York City.
Mr. Arthur Block, Regional ATSDR representative can be
contacted at (212) 637-4307.
Residents who want a blood test for mercury levels should
contact the local Health Department or their own physicians.
G.E. officials suggested that anyone who was tested and had
high levels of mercury in the blood report that to G.E. on an
individual basis.
13
-------
ATTACHMENT A
COMMUNITY RELATIONS ACTIVITIES
G.E. WIRING DEVICES SUPERFUND SITE
Community relations activities conducted at the G.E. Wiring Devices
Superfund Site have included:
o EPA held a public meeting with the community to discuss the
provisions of the Administrative Order and to receive and respond
to comments regarding the Site (February 1984) .
o EPA held a public meeting with the community to solicit comments
on and discuss findings of the Remedial Investigation (April 1987).
o EPA held a public hearing with the community to discuss and
receive comments on the draft Remedial Investigation/Feasibility
Study (RI/FS) Report and Proposed Plan for the Site (September 15,
1988). This meeting took place in conjunction with a public
comment period, which was'held from September 1, 1988 to September
26, 1988.
o ^ EPA conducted community interviews prior to the Remedial
Design/Remedial Action phase of the Superfund process (April 1992) .
o EPA prepared a Revised Community Relations Plan (CRP) (July
1992) .
o EPA released a Spanish translation of the Revised CRP to the
public (December 1992).
r
o EPA established an information repository at the San Juan City
College library in Juana Diaz (February 1993).
o EPA conducted community interviews in preparation for the start
of the Remedial Action phase (March 1997).
o EPA updated the 1992 Revised CRP (May 1997).
o EPA relocated the information repository to the Press Office at
the Mayor's Office at Juana Diaz City Hall (March 1997).
o EPA prepared and sent letters to residents on Calle #2 regarding
further explanation of 1993 sampling activities (May 1997)
o EPA prepared and distributed- a fact sheet in English and in
Spanish on the initiation of the Remedial Action, community issues
and concerns, and an upcoming informational meeting (August 1997).
14
-------
o EPA advertised an upcoming informational meeting via a press
release and flyers for local distribution (September 1997).
o EPA held an informational meeting at Juana Diaz City Hall to
discuss the Remedial Action process (September 23, 1997).
o EPA with the assistance of a translator visited residences on
Calle #2 to answer questions and address concerns regarding
Remedial Action activities (April, 1998).
o EPA conducted additional soil sampling in properties along Calle
#2 and sent the results to residents (April, 1998).
o EPA prepared and distributed a Post-Decision Proposed Plan fact
sheet which describes changes to the original remedy selected in
the September 30, 1988 ROD (April 1999) .
o EPA held a public comment period on the Focused Feasibility
Study and Post-Decision Proposed Plan from April 26, 1999 to May
25, 1999.
o EPA held a public hearing at City Hall to solicit public
comments regarding proposed changes to the 1988 ROD. A transcript
of this hearing is available at the Mayor's Press Office at City
Hall (May 13, 1999).
15
-------
-------
07/15/97 Index Document Number Order P«S«:
GE WIRING Documents
Document Number: GEW-001-0001 To 0001 Date: 06/12/79
Title: (Memorandum re: Mercury Sampling)
Type: CORRESPONDENCE
Author: Figueroa. Solange; 1.: General Electric
Recipient: Poland. J.i.s fieneral Electric
Attached: GEW-001-0002 GEU-001-0004 GEW-001-0006 GEW-001-0009
Document Nuiteer: GEW-001-0002 To 0003 Parent: GEW-001-0001 Date: 06/18/79
Title: (Memorandum re: Mercury Sampling on 6/16/79)
Type: CORRESPONDENCE
Author: Figueroa, Solange I.: General Electric
Recipient: Poland, J.B.: General Electric
Document Number: GEW-001-0004 To 0005 Parent: GEW-001-0001 Date: 06/19/84
itle: (Memorandum re: Ground Samples/Mercury Percent)
Type: CORRESPONDENCE
Author: Figueroa, Solange I.: General Electric
Recipient: Culp, Dale: General Electric
Document Number: GEW-001-0006 To 0008 Parent: GEW-001-0001 Date: 06/20/79
Title: (Memorandum re: Mercury Sampling - Follow Up)
Type: CORRESPONDENCE
Author: Figueroa, Solange I.: General Electric
Recipient: Poland, J.B.: General Electric
Cocment Number: GEW-001-0009 To 0010 Parent: GEW-001-0001 Date: 06/22/79
Title: (Memorandum re: Mercury Button Handling, Plating Area, Juana Diaz)
Type: CORRESPONDENCE
Author: Figueroa, Solange 1.: General Electric
Recipient: Poland, J.B.: General Electric
-------
37/15/97 Index Document Number Order Page: 2
GE HIRING Documents
Document Kmber: GEU-001-0011 To 0011 Date: 06/25/79
Title: (Memorandum re: Juana Diaz Plating Area Situation)
Type: CORRESPONDENCE
Author: Figueroa, Solange I.: General Electric
Recipient: Poland, J.B.: General Electric
Attached: CEU-001-0012
Document limber: GEU-001-0012 To 0013 Parent: GEU-001-0011 Date: 10/21/76
Title: Resource Conservation and Recovery Act, Public law 94-580, as amended by the Ouiet Communities
Act of 1978
Type: LEGAL DOCUMENT
Author: none: US EPA
Recipient: none: none
Doeunent Number: GEU-001-OOU To 0014 Date: 08/16/79
fitte: (Letter re: Mercury Soil Contamination • Juana Diaz, P.R.)
Type: CORRESPONDENCE
Author: Feliu, Leo: General Electric
Recipient: iurns, UiI lien S.: General Electric
Attached: GEU-001-0015 GEU-001-0016
Docunent Ntnber: GEU-001-0015 To 0015 Parent: GEU-001-OOU Date: 07/19/79'
Title: (Memorandum re: Mercury Soil Samples)
Type: CORRESPONDENCE
Author: Figueroa, Solange I.: General Electric
Recipient: Poland, J.S.: General Electric
*""***"""*"*********"**************"****"***"**"****"******"***"""""•*"""•*"•"*"*•*"""•"""•«»••••«•«•«
Docunent Number: GEU-001-0016 To 0016 Parent: GEU-001-OOU Date: 07/12/79
i
Title: Analytical results of mercury soil samples for samples received 06/26/79
Type: DATA
Author: none: General Electric
Recipient:
-------
Fl5/97
Index Document Number
GE WIRING Documents
******************************************************
Document Number: GEW-001-0017 To 0017
Title: (Meaorandun rt: Plant Soil Evaluation Program)
Type: CORRESPONDENCE
Author: Feliu, Leo: General Electric
Recipient: Poland, J.B.: Ganaral Electric
Page: 3
Date: 09/27/79
Document Number: GEU-001-0018 To 0019
Title: (letter re: Juana Diaz Plant Soil Evaluation Samples)
Type: CORRESPONDENCE
Author: Figueroa, Solange I.: General Electric
Recipient: Feliu. Leo: General Electric
Attached: GEU-001-0020 GEW-001-0022
Date: 10/11/79
Document Number: GEU-001-0020 To 0021 Parent: GEU-001-0018
e: Environmental Monitoring Analytical Services Request Forms
Type: OTHER
Author: none: General Electric
Recipient: Feliu, Leo: General Electric
Date: 10/05/79
Document Number: GEU-001-0022 To 0022 Parent: GEU-001-0018
Title: Juana Diaz Plant Soil Evaluation Samples: Location Sketch
Type: GRAPHIC
Author: none: none
Recipient: none: none
Date: / 7
Document Number: GEU-001-0023 To 0023
Title: (Letter re: Laboratory Analysis of the Juana Diaz Plant Soil)
Type: CORRESPONDENCE
Author: Figueroa, Solange I.: General Electric
Recipient: Schauseil, Robert I.: General Electric
Attached: GEU-001-002* GEU-001-0025
Date: 11/02/79
-------
07/15/97
Index Document Number Order
GE WIRING Docunent*
Page:
Document Number: GEU-001-0024 To 0026 . Parent: GEW-001-0023 Date: 10/24/79
Title: Environmental Analysis of Mercury contained in toil samples received 10/12/7V
Type: DATA
Author: none: General Electric
Recipients none: General Electric
Document Number: GEW-001-0025 To 0025 Parent: GEU-001-0023
Title: Juana Diaz Plant Soil Evaluation Samples: Location Sketch
Type: GRAPHIC
Author: none: none
Recipient: none: none
Date: / /
Document Nutfcer: GEU-001-0026 To 0046
Date: 04/22/81
"file: Field notes a*de by W.J. Alexander during auger borings and test pit excavations at the West
Field Site
Type: OTHER
Author: Alexander, W. Joseph: Law Engineering Testing
Recipient: none: none
Document Number: GEW- 001 -0047 To 0047
Title: (Certificate of Analysis for eight water samples received 04/30/81)
Type: DATA
Author: illegible: Stewart Laboratories
Recipient: Phillips, J.M.: General Electric
Date: OS/19/81
Docunent Nurrber: GEW-001-0048 To 0098
Date: 06/19/81
Title: (Letter re: Attached Report Submittal, Hydrogeologic Investigategat ion. Waste Fill Area, Juana
Diaz, Puerto Rico, Law Engineering Job Number MK1223)
Type: CORRESPONDENCE
Author: Alexander, U. Joseph: Law Engineering Testing
Recipient: Phillips, J.N.: General Electric
Attached: GEW-001-0099
-------
J7/15/97 Index Document Number Order Page; 5
GE WIRING Documents
Document Number: GEW-001-0099 To 0099 Parent: GEW-001-0048 Date: 06/18/81
Title: (Certificate of Analysis on two samples of waste material)
Type: DATA
Author: illegible: Stewart Laboratories ~
Recipient: Phillips. J.H.: General Electric
Document Nutter: GEU-001-0100 To 0150 Date: 11/02/81
Title: (Letter re: Attached Report of Clay Continuity Study, Waste Fill Area, Juana Diaz Plant, Puerto
Rico, Law Engineering Project No. HH1367)
Type: CORRESPONDENCE
Condition: MARGINALIA
Author: Germond, Bart J.: Law Engineering Testing
Recipient: Schauseil, Robert I.: General Electric
' ••••"
ocuraent Number: GEU-001-0151 To 0152 Date: 01/27/82
Title: (Letter re: EPA's review of comments regarding Law Engineering Testing Company's Clay Continuity
.Report)
Type: CORRESPONDENCE
Author: Frisco, John S.: US EPA
Recipient: Phillips, Marvin: General Electric
Document Number: GEW-001-0153 To 0157 Date: 02/15/82
Title: Attachment 2-5 Certified Laboratory Results (water samples from selected standpipes)
Type: DATA
Author: illegible: Omni Research Incorporated
Recipient: none: General Electric
-------
07/15/9? Index Docunent Number Order Page: 6
GE WIRING Documents
Document Nuifcer: GEU-001-0158 To 0160 Date: / /
Title: Analytical data and field data froa standpipes at the Juene Diaz cite
Type: DATA
Author: none: Lau Engineering Testing
Recipient: none: none
Docunent Number: GEU-001-0161 To 0162 Date: 02/19/82
Title: (Letter re: Water Level Monitoring Program, Waste Fill Area, Juana Diaz Plant, Puerto Rico,
Law Engineering Project No. MHU40)
Type: CORRESPONDENCE
Author: Germond, II, Bart J.: Lau Engineering Testing
Recipient: Marques, Jose A.: General Electric
Document Number: CEW-OD1-D163 To 0165 Date: 02/23/82
Title: (Letter re: Response to U.S. EPA'S Review, Juana Diaz, Puerto Rico Study, by Mr. John S. Frisco,
Chief, Hazard Assessment Section, Lau Engineering Project No. MH1367J
Type: CORRESPONDENCE
Condition: MISSING ATTACHMENT
Author: White, Robert M.: Lau Engineering Testing
Recipient: Phillips. Marvin: General Electric
Document Number: GEW-001-0166 To 0167 Date: 05/18/82
Title: (Letter re: Questions and answers from the March 4, 1982 letter that raised concerns about
-the Clay Continuity Report and Hydrogeologic Study)
Type: CORRESPONDENCE
Condition: MARGINALIA
Author: de la Cruz, Luis E.: PR Environmental Quality loard
Recipient: Colon, Javier: General Electric
-------
07/15/97
Index Document Nunfcer Order
GE WIRING Document*
Page: 7
Document Nuaber: GEW-001-0168 To 0169 Date: 03/04/82
Title: (Letter re: General Electric Juana Diaz)
Type: CORRESPONDENCE
Condition: MARGINALIA
Author: de la Cruz, Luis E: PR Environmental Quality Board
Recipient: Colon, Javier: General Electric
Document Number: GEW-001-0170 To 0176 Date: 09/22/82
Title: (Letter re: Report •* August, 1982 Site Visit, Juan* Diaz Plant. Puerto Rico, Law Engineering
Project No. NH22V6)
Type: CORRESPONDENT
Condition: MARGINALIA
Author: Alexander, if. Joseph: Law Engineering Testing
Recipient: Friss, <4a*es T.s General Electric
Attached: GEW-001-0177
Document Number: GEW-0&KM77 To 0177 Parent: GEW-001-0170 Date: / /
Title: Figure 1 - GeneraflffaBri Locations of August 1982 Test Pits 1 through 12
Type: GRAPHIC
Author: none: Leu En0i*a*ring Testing
Recipient: none: none
Document Nunber: GEtf-tttTKTOS To 0183 Date: 09/29/82
Title: (Letter re: DriliLii* and Monftoring Well Installation, General Electric Site, Juana Diaz,
Puerto Rico)
Type: CORRESPOBSKS
Condition: MARGINALIA
Author: Jernigan. Stuce I.: Lau Engineering Testing
Recipient: Castillo. XuU Maquez: Vazquez Agrait, Vazquez Castillo C Despiau
-------
07/15/97 Index Document Number Order Page: 8
GE WIRING Documents
m****mmmmmmmmmmmmmm
Document Hunter: GEW-001-0184 To 0192 Oat*: OB/27/82
Tlttt: General Electric Company. Juana Diaz Plant, Retaining Wall (Muro dc Contencion)
Typt: GRAPHIC
Author: Marques, Jose A.: General Electric
•ecipient: none: none
Document Nutter: GEW-001-0193 To 0196 Date: 10/28/82
Title: (tetter re: Attached Technical Response to EOB's Clay Continuity and Alluvial Contamination
Concerns, Juana Diaz Site, Puerto Rico, Law Engineering Project No. MH2317.01)
Type: CORRESPONDENCE
Author: Jernigan, Bruce I.: Law Engineering Testing
Recipient: Friu. James T-: General Electric
Document Nusber: GEU-001-0197 To 0197 Oate: 11/05/82
Title: (Utter re: General Electric. Juana Diaz Site, P.R.)
Type: CORRESPONDENCE
Author: Jernigan, Bruce U: Law Engineering Testing
Recipient: Castillo, Lui* Vacquez: Vazquez Agrait, Vazquez Castillo t Despiau
Document Nurtber: GEW-001-019S To 0217 Date: 11/22/82
Title: (Letter re: Attached Status Report of Hydraulic Conditions, Perched-Uater Table; Waste Fill
Area, Juana Diaz Plant, Puerto Rico, Law Engineering Project No. MHU40.03)
Type: CORRESPONDENCE
Author: Alexander, W. Joseph: Law Engineering Testing
Heal. Larry A.: Law Engineering Testing
Recipient: Scheusetl, Robert I.: General Electric
-------
*n 'J»pu*x»iv
r '}H»3uojtH
30N3QHOdS3daO3
put jajtn *qi uo
£8/11/10 s»»«0 Z920 <»i «ZO-100-H33
.•...•*..•»...•_•..••....•..»•.......••«•.«•««••••••••••••••-••••••••••••••••««-«<•••»»••••
aoou :auou
6ui;s»i Bu}j3au(6u3 mi "H '
Cutjoq
£KO «1 ISZO-1
auou :*uou
Bujjsai iios utaqq)j"3 :auou
318ID3m
K3H10
aqi JO> sSoi *,J»IJHP *<»
8lZO-lOO-fl3D :jusj8d 0£ZO «i 02ZO-100-H39 :
Butisai 1105
Suijoq jsaj
Z0/01/ZI. !*>»0 8lZO-lOO-n39 !»u«j«
-------
*
•f
0//15/9? Index Document Number Order page: 10
GE WIRING Documents
Document Number: GEU-001-0243 To 0245 Date: 01/13/83
Titlt: (Letter rt: Attached Britf Statement on analysts of data gathered on the Hydrogeologic Investigation)
Type: CORRESPONDENCE
Author: Long, David T.: MI State University.
Recipient: Jernigan, Bruce I.: Law Engineering Testing
Document Number: CEU-001-D246 To 0284 Date: 01/27/83
Title: Presentation materials used by GE and Law Engineering Testing Company
Type: OTHER
Author: none: none
Recipient: none: none
Document Number: CEW-001-0285 To 0285 Date: 02/24/83
Title: (Letter rt: Results of Mercury Analysis, Juana Diaz Plant, Puerto Rico, Law Engineering No.
MH2317>
Type: CORRESPONDENCE
Author: Alexander, U. Joseph: Law Engineering Testing
Recipient: Friss, James T.: General Electric
Attached: GEU-001-02B6
Document Number: CEU-001-0286 To 0286 Parent: GEU-001-028S Date: / /
Titlt: Result* of Mercury Analysts. Law Engineering Project No. MH2317
Type: DATA
Author: Maroncelli, James M.: Law Engineering Tasting
Recipient: none: none
Document Number: CEU-001-0287 To 0287 Date: 03/09/83
Title: (Latter rt: Attached aurmary of CompuChtm data)
Type: CORRESPONDENCE
Author: none: Mead CompuChera Laboratory
Recipient: Maroneelli, James M.: Law Engineering Testing
Attached: GEU-001-0288
-------
07/15/97 Index Oocunent Number Order
CE WIRING Documents
•X*nnZZZXZZ*ZBZZXB*XZ»ZZ>XZZZZZZZZZZSXZZXZZXBXZZKXXZZZZZXZZZZZZZXXXZZZeZXZZZZZZZXXZZXXZZZZZZXXZXX«ZZZZZZZZ
Page: 11
Document Nwber: CEW-001-0288 To 0384
Title: Sumary of ConpuCham data
Parent: CEU-001-0287
Type: DATA
Author: Bloom, Richard L.: Need CompuChem Laboratory
Recipient: Maroncelli, James M.: Law Engineering Testing
Date: / /
Document Nunfcer: GEW-001-03B5 To 0386
Title: (Letter re: Attached results of chemical analyses soil samples)
Type: CORRESPONDENCE
Author: Maroncelli, James M.: Law Engineering Testing
Recipient: Alexander, W. Joseph: Law Engineering Testing
Date: 03/11/83
Document Nurtwr: GEW-001-0387 To 0408
Date: 03/15/83
itle: (Letter re: Ground-water Quality Analyses, Juana Diaz Site, Puerto Rico, Reference Proposal
HS3022.20 (Item 5), Law Engineering Project No. UM3233>
Type: CORRESPONDENCE
Condition: MARGINALIA
Author: Alexander, V. Joseph: Lau Engineering Testing
Recipient: Schauseil, Robert I.: General Electric
Document Hunter: GEW-001-0409 To 0413 Date: 04/18/83
Title: (Letter re: Test Boring Records, General Electric Company Plant Site, Juana Diaz, Puerto Rico)
Type: CORRESPONDENCE
Author: Alexander, W. Joseph: Law Engineering Testing
Recipient: Pierre, Wayne N.: US EPA
Document Number: GEW-001-0414 To 0433
Date: 04/20/83
Title: (Letter re: Report of Test Results, Juana Diaz Site. Puerto Rico, Reference Proposal NS3022.20
(Items 3 and 4), Law Engineering Project No. 4M3233)
Type: CORRESPONDENCE
Author: Alexander. W. Joseph: Law Engineering Testing
Neal, Larry A.: Law Engineering Testing
Recipient: Schauseil. Robert 1.: General Electric
-------
07/15/97 Index Document Number Order Page: 12
GE WIRING Documents
Document Nuaber: GEU-001-0454 To 0443 Date: 05/25/83
Title: (Utter rt: Scfsnic Rfsk of the Proposed Encapsulation Alternative, Waste Fill Area, Item
1 of Proposal No. MS3022.20, Law Engineering Project No. WW3233)
Type: CORRESPONDENCE
Author: Parker, Nark: Law Engineering Testing
Recipient: Schauseil, Robert I.: General Electric
Document Number: GEU-001-0444 To 0446 Date: 06/06/83
Title: (Letter re: Flooding Analyses, Juana Diaz Site, Puerto Rico, Reference Proposal MS3022.20
(Item 2), Lau Engineering Project No. UH3233)
Type: CORRESPONDENCE
Author: lauing, Raymond J.: Law Engineering Testing
Recipient: Schauseil, Robert I.: General Electric
fiocunent Number: GEW-001-0447 To 0447 Date: 07/19/83
Title: (Letter re: Intensity of Earthquakes, Lau Engineering Project No. WH3233)
Type: CORRESPONDENCE
Author: Alexander, W. Joseph: Law Engineering Testing
Recipient: Schauseil, Robert I.: General Electric
Attached: GEU-001-0448
Document Number: GEU-001-0448 To 0449 Parent: GEU-001-0447 Date: / /
Title: Principles of Engineering Geology and Ceotechnics: Chapter 18: Earthquakes and Aseismic Design
Type: CORRESPONDENCE
Condition: INCOMPLETE
Author: Krynine. Dimitri P.: McGraw Hill Book Company
Recipient: none: none
-------
37/15/97 Index Document Nuifcer Order Page: 13
CE WIRING Oocunent*
Document Number: GEW-001-M50 To 0502 Date: 11/02/80
Title: (Letter re: Attached Report of Clay Continuity Study, Waste Fill Area, Juana Diaz Plant. Puerto
Rico, Law Engineering Project No. MH1367)
Type: CORRESPONDENCE
Author: Cernond, tart J.: Law Engineering Testing
Recipient: Schauseil, Robert I.: General Electric
Document Number: GEW-001-0503 To 0503 Date: 10/30/81
Title: (Letter re: Amendment to the June 19th Report, Hydrogeologic Investigation Waste Fill Area,
Juana Diaz Plant, Puerto Rico, Law Engineering Job No. MH1223)
Type: CORRESPONDENCE
Author: Germond, Bart J.: Law Engineering Testing
Recipient: Sehauseil, Robert I.: General Electric
Attached: GEU-001-0504
unent Number: GEU-001-0504 To 0504 Parent: GEW-001-0503 Date: 06/18/81
Title: Certificate of Analysis (for two samples of waste material)
Type: LEGAL DOCUMENT
Author: illegible: Stewart Laboratories
Recipient: Phillips, Marvin: General Electric
Document Number: GEW-001-0505 To 0508 Date: 06/05/81
Title: Notification of Hazardous Waste Site: General Electric Company - Wiring Devices Department
Type: OTHER
Author: Schauseil, Robert I.: General Electric
Recipient: Frisco, John S.: US EPA
Document Number: GEW-001-0509 To 0510 Date: 01/27/82
Title: (Letter re: U.S. EPA'a comments on Law Engineering Testing Coapeny'a Continuity of Clay Report)
Type: CORRESPONDENCE
Author: Frisco, John S.: US EPA
Recipient: Phillips, Marvin: General Electric
-------
37/15/07
Index Document Number Order
GE WIRING Documents
Page: U
Document Number: GEW-001-0511 To 0549 Date: 08/04/82
Title: Hazardous Rankfne Systan Scores Package: General Electric • Wiring Devices of Puerto Rico
Type: OTHER
Author: Ltpsky, Davfd: US EPA
Recipient: none: none
Attached: GEU-001-0537 GEW-001-0549
Document Nurcber: GEW-001-0537 To 0537 Parent: GEW-001-0511
Title: Results of Mercury Analyses, Law Engineering Project No. MH2317
Type: PLAN
Author: Maroncelli, James M.: Law Engineering Testing
Recipient: none: none
Date: / /
Document Umber: GEU-001-0549 To 0549
Parent: GEU-001-0511
Date: 04/21/82
Title: Sampling Trip Report (at Juana Diaz site for sampling trip on 04/19/82 and 04/21/82 and stating
"measurements taken with Sachraeh Mercury Sniffer along fence perimeters- Ho mercury detected")
Type: PLAM
Condition: MISSING ATTACHMENT
Author: Lipsky, David: US EPA
Recipient: none: none
Document Number: GEW-001-0550 To 0552
Date: 12/22/82
Title: {Letter re: Response to December 16, 1982 letter relating to the inclusion of the Juana Diaz
site as a priority project)
Type: CORRESPONDENCE
Author: DtSorbo. L.A.: General Electric
Recipient: Madera, Jose R.: PR Economic Development Administration
-------
7/15/97
Index Document Number Order
CE WIRING Documents
Document Nunber: GEW-001-0553 To 0553
Title: (Letter re: Receipt of November 29, 1982 letter)
Type: CORRESPONDENCE
Author: Schauseil, Robert I.: General Electric
teeipient: de la Cruz, Luis E.: PR Environmental Quality Board
Page: 15
Date: 12/09/82
Document Number: GEW-001-0554 To 0554
Title: Water Analysis Report (for samples received 01/28/82)
Type: DATA
Author: illegible: Caribtec Laboratories
Recipient: none: none
Date: 02/04/82
Document Number: GEU- 00 1-0555 To 0555
ptle: Handwritten list of attendees to GE meeting
Type: OTHER
Author: none: none
Recipient: none: none
Date: 01/27/83
Document Number: GEW- 001 -0556 To 0607
Date: / /
Title: Map of Generalized Site Setting, Initial Assessment findings, and other presentation materials
for a GE Wiring meeting
Type: OTHER
Author: none: none
Recipient: none: none
Document Number: GEU-001-0608 To 0608
Title: (Letter re: On- site disposal of hazardous and/or toxic wastes)
Type: CORRESPONDENCE
Author: Madera, Jost R.: P* Economic Development Administration
Recipient: DeSorbo, L.A.: General Electric
Date: 02/08/83
-------
07/15/97
Index Document Number Order
GE WIRING Documents
Page: 16
•«*»•»••••*•••»•
Document Htnber: GEW-001-0609 To 0609
Date: 02/24/83
Title: (Letter re: Results of Mercury Analyses, Juana Diaz Plant, Puerto RSco, Law Engineering Project
Ho. MK2317)
Type: CORRESPONDENCE
Condition: MISSING ATTACHMENT
Author: Alexander, W. Joseph: Law Engineering Testing
Recipient: Friss, James T.: General Electric
Document Number: GEU-001-0610 To 0611
Date: 02/25/83
Title: (Letter re: Comments on Proposed Amendment to National Oil and Hazardous Substance Contingency
Plan; the National Priorities List, 47 Federal Register 54,476, December 30, 1982)
Type: CORRESPONDENCE
Author: Schausetl, Robert I.: General Electric
Recipient: Uyer, Russell N.: US EPA
Document Number: GEU-001-0612 To 0612
Title: (Letter re: General Electric Wiring Devices. Juana Diaz, Puerto Rico)
Type: CORRESPONDENCE
Author: Unpierre, Victor R.: PR Economic Development Administration
Recipient: Diamond, Larry: US EPA
Attached: GEW-001-0613
Date: 05/27/83
Docment Nunber: GEW-001-0613 To 0613
Parent: GEU-001-0612
Date: 04/11/83
Title: (Letter re: Technical Alternatives available for correcting the environmental problems created
by the disposal of toxic wastes at the General Electric Manufacture Wiring Devices. Inc.)
Type: CORRESPONDENCE
Author: Madera, Jose X.: PR Economic Development Administration
Recipient: Rivera, Ignacio: General Electric
-------
07/15/97 Index Document Number Order Page: 17
GE WIRING Documents
•«»«»•««««««•««««•«»«•»••»«««»«•««»•»»»»»*«»«»»««»•»»«»««««*»•»•««»«»««»««*«««»«««»*«««»»•«»»*»«•««»«»«»*»»•»•"*»"•«««*
Ooeuaent Ninber: GEW-001-06U To 06U Date: 09/28/83
Titlt: (Lttttr rt: On-sitt encapsulation of toxic wastes) >
Type: CORRESPONDENCE
Author: Nadtra, Jose R.: PR Economic Development Administration
Recipient: Rivera, Ignacio: General Electric
Attached: GEU-001-0615
••••••••••••••••••••••^••••••••••••••••••••••••••""••••••••••••"••"•••••••••"••"""""•••••"••••**"**"™™™"***"*"™™*'****""™
Docunent Number: GEW-001-0615 To 0615 Parent: GEW-001-06U Date: 08/06/83
Titlt: (Lttttr rt: Immediate action for proper disposal of mercury contaminated wastes)
Type: CORRESPONDENCE
Author: Madera, Jose R.: PR Economic Development Administration
Recipient: Rivera. Ignaeio: General Electric
Document Number: GEW-001-0616 To 0620 Date: 10/07/83
itle: (Letter re: Evaluation of hazardous sites in Puerto Rico for inclusion on the National Priorties
List)
Type: CORRESPONDENCE
Author: Librizzi, William J.: US EPA
Recipient: Madera, Jose R.: PR Economic Development Administration
Document Number: GEW-001-0621 To 0663 Date: 01/16/86
Title: Administrative Order on Consent (regarding actions and studies to be done at Juan* Diaz site)
Type: LEGAL DOCUMENT
Condition: MARGINALIA
Author: Schaftr, Jacqueline E.: US EPA
Recipient: Vineyard, William: Central Electric
Attached: GEW-001-0666
Oocuntnt Number: GEU-001-06U To 0644 Parent: GEW-001-0621 Oatt: 02/01/86
Titlt: (PubHe Notict rt: General Electric Company enttring into Administrative order on Consent)
Type: CORRESPONDENCE
Author: Carlo*, O'Neil: US EPA
Recipient: none: none
-------
07/15/97
Index Docunent Number Order
CE WIRING Doeunents
**"*•"*""•"•"*"•«"»*'««•"»«»«»««»««««««««««•«•»«««•«««»„
Document Nuaber: GEU-001-0645 To 0646
title: Resolution end notification (written in Spanish)
Type: LEGAL DOCUMENT
Author: Gelabert. Pedro A.: PR, Commonwealth of
Recipient: none: General Electric
O
: 18
Date: 12/15/83
Document Nmber: CEW-001-0647 To 0649
Title: (letter re: Complete removal of toxic waste from the site)
Type: CORRESPONDENCE
Author: Madera, Jose R.: PR Economic Development Administration
Recipient: Rivera, Iflnacios General Electric
Date: 01/27/84
Docunent Nu*er: GEW-001-0650 To 0651
Date.
Title: (News release: GE Consents to EPA order to Act on Juana Diaz, P.R. Contamination)
Type: CORRESPONDENCE
Author: none: US EPA
Recipient: none: none
Document limber: CEW-001-0652 To 0652
Title: (Public notice re: Administrative Order on Consent (written in Spanish))
Type: CORRESPONDENCE
Author: none: El Nuevo Die
Recipient: none: none
Date: 02/03/84
Oocustnt Nu*»r: GEW-OOI-OttS To 0653
B.t.:
Title: (Newspaper article titled: «GE Will Cleanup Juana Diaz Site where Toxic Waste Was Dunped")
Type: CORRESPONDENCE
Author: Chisliotty, Julio: San Juan Star
Recipient: none: none
-------
15/97 Index Document Number Order Page: 19
GE WIRING Documents
•*•••••*«**•* •*••••*•••••••••••••••••••*•**»*••*•*••*•«*•«*«»•****«*«••••«*••«»*••»*•«•••*••***••••••••••*••••••••*••
Docuaent Number: GEW-001-0654 To 0654 Date: 02/13/84
Title: (Newspaper article titled: "PA Exfoe CE Linpie Vertedero en Juana Diaz")
Type: CORRESPONDENCE
Author: none: El Mundo, San Juan
Recipient: none: none
Document Number: GEU-001-0655 To 0656 Date: 02/15/84
Title: (Article titled: "CE Will Cleanup Uaste Disposal Site: Company signs consent order with EPA
to attend to 27-year-old Juana Diaz dump")
Type: CORRESPONDENCE
Author: Eehavarrt, Christian M.: Cirri bean Business
Recipient: none: none
it Number: GEU-001-0657 To 0659 Date: 03/09/84
le: (Letter re: General Electric Company, EPA Order on Consent, Index No. II CERCLA-30301, To
Clean Up Juana Diaz Plant Site)
Type: CORRESPONDENCE
Condition: MISSING ATTACHMENT
Author: Madera, Jose R.: PR Economic Development Administration
Recipient: none: US EPA
Document Niriber: GEW-001-0660 To 0660 Date: 07/16/84
Title: (Letter re: EPA's response to the public comments received on Order No. 11-CERCLA-30301)
Type: CORRESPONDENCE
Condition: MISSING ATTACHMENT
Author: Dewling, Richard T.: US EPA
Recipient: Vineyard, William: General Electric
Attached: GEU-001-0661
-------
Index Docimnt Number Order
GE WIRING Documents
07/15/97
»»•••••"""•»«*••»•»«»»«»»•»«»«•»»»«»»»»••»«•
Ooeimnt Nuriber: GEW-001-0661 To 0663 Parent: GEU-001-0660
Title: Response to eoawnts on Administrative order
Type: PLAN
Author: none: US EPA
Recipient: none: none
Date: 06/01/84
: 20
Oocunent Number: GEU-001-0664 To 0664
Title: {Letter re: GE Hiring Device Site. Juana Diaz, Puerto Rico)
Type: CORRESPONDENCE
Author: Kaplan, Arthur L.: General Electric
Recipient: Font, Jose C.: US EPA
Attached: CEW-001-0665
Date: 03/26/85
Document Number: GEW-001-0665 To 0686 Parent: GEW-001-0664 Date: 03/11/85
Title: Work Plan for Remedial Investigation, Mercury Waste Site, Juana Diaz. Puerto Rico
Type: PLAN
Author: none: Law Engineering Testing
Recipient: none: General Electric
Document Uunbcr: GEW-001-0687 To 0688 Date: 04/09/85
Title: (Letter re: Request for data on ground-water wells in the vicinity of Juana Diaz. Puerto Rico)
Type: CORRESPONDENCE
Author: Shugart, Steven L.: Law Engineering Testing
Recipient: Font. Jose C.: US EPA
Document Number: G£W-001-0689 To 0689
Date: 04/24/85
Title: (Letter re: Analytical Remits of Priority Pollutant Analysis of Water Sample from Stand-Pipe
Mo. 11, General Electric Juana Dial Facility)
Type: CORRESPONDENCE
Author: Mart, Steven U.: Law Engineering Testing
Recipient: Font Jose C.: US EPA
Attached: GEW-001-0690 GEU-001-0691 GEW-001-0692
-------
17/15/97 Index Document Number Order Page: 21
GE WIRING Documents
Oocumtnt Number: GEW-001-0690 To 0690 Parent: GEW-001-0689 Date: 03/19/85
Title: (Letter re: Analytical Results of Priority Pollutant, Analysis of Water Sample from Stand-Pipe
No. 11, General Electric Juana Diaz Facility}
Type: CORRESPONDENCE
Author: Heal, Larry A.: Law Engineering Testing
Shugart, Steven I.: Law Engineering Testing
Recipient: Schemed, Robert 1.: General Electric
Document Number: GEW-001-0691 To 0691 Parent: GEW-001-06B9 Date: 01/22/85
Title: (Letter re: Summary of data from requested sample analysis)
Type: CORRESPONDENCE
Author: Carrington, Pamela S.: CompuChetn
Recipient: Neil, Larry A.: Law Engineering Testing
locument Number: GEW-001-0692 To 0700 Parent: GEW-001-0689 Date: / /
Title: Data Report Notice and Report of Data
Type: PLAN
Author: ScanneU, Diana A.: CornpuChem
Recipient: Neil, Larry A.: Law Engineering Testing
Document Number: GEW-001-0701 To 0753 • Date: 10/23/87
Title: (Letter re: Results of Chemical Analysis of Water Samples from Water Wells and Monitoring
Wells)
Type: CORRESPONDENCE
Condition: MARGINALIA
Author: Spiers, Charles A.: Law Environmental Services
Recipient: Schauseil, Robert 1.: General Electric
Attached: 6EW-001-0722 GEW-001-0730 GEW-001-0738 6EW-001-C746
-------
07/15/97
Index Document Number Order
GE WIRING Documents
Docimnt Nuiter: GEW-001-0722 To 0729 Parent: CEW- 001-0701
Utter {letter re: Report for analysis of sample from stonitoring well No. 1)
Type: CORRESPONDENCE
Author: Scemmell, Diana A.: CompuChem
Recipient: Neil, Larry A.: Law Engineering Testing
f»it: ZZ
Date: 08/22/85
Document Nmber: CEU-001-0730 To 0737 Parent: CEW-001-0701
Title: (Letter re: Report for analysis of sample from monitoring well Mo. 2}
Type: CORRESPONDENCE
Author: Scvrmetl, Diana A.: CompuChem
Recipient: Neil, Larry A.: Lau Engineering Testing
Date: 08/22/85
Document Number: CEU-001-0738 To 0745 Parent: CEW-001-0701 Date: 08/22/85
Title: {Letter re: Attached report for analysis of sample from monitoring welt Mo. 3)
Type: CORRESPONDENCE
Author: Scarnnell. Diana A.: CompuChem
Recipient: Neil, Larry A.: Lau Engineering Testing
Oocimnt Number: CEU-001-0746 To 0753 Parent: CEW-001-0701
Title: {Letter re: Attached analysis results of sample from monitoring well No.
Type: CORRESPONDENCE
Author: Scammell, Diana A.: CompuChem
Recipient: Neil, Larry A.: Law Engineering Testing
Date: 08/22/85
Document Nuaber: CEW-001-07M To 0754 . Date: 10/29/85
Title: (Latter re: Review ef possible triehloroethylene contamination at Juana Diaz site)
Type: CORRESPONDENCE
Condition: MISSING ATTACHMENT
Author: Kaplan, Arthur L.: Ceneral Electric
Recipient: root, Jose C.: US EPA
Attached: CEU-001-0755 CEW- 00 1-0756
-------
• I
' * •"
•A
I
'07/15/97 Index Document N«btr Order Page: 23
GE WIRING Documents
Document Number: GEV-001-0755 To 0755 Parent: GEU- 001 -0754 Date: 12/13/85
Title: (Letter re: Proposed Schedule of Soil Sampling for Triehloroethytene, G.E. Juana Diaz, Puerto
Rico Plant)
Type: CORRESPONDENCE
Author: Neil, Larry A.: Law Engineering Testing
Recipient: Font. Jose C.: US EPA
Document Number: GEU-001-0756 To 0756 Parent: GEU-001-0754 Date: 01/10/86
Title: (Letter re: Revised Schedule of Sot I Sampling for Trichloroethylene, G.E. Juana Diaz, Puerto
Rico Plant)
Type: CORRESPONDENCE
Author: Spiers, Charles A.: Law Environmental Services
Recipient: Font, Jose C.: US EPA
ument Number: GEW-001-0757 To 0757 Date: 05/05/86
Title: (Letter re: Revised Work Plan for Remedial Investigation, G.E. Wiring Devices Site, Juana
Diaz, Puerto Rico)
Type: CORRESPONDENCE
Author: Czapor, John V.: US EPA
Recipient: Kaplan, Arthur L.: General Electric
Document Number: GEW-001-0758 To 0758 Date: 06/03/86
Title: Favor De Firmer (handwritten list of names, organization and addresses). General Electric
Wiring Devices
Type: OTHER
Author: none: none
Recipient: none: none
Attached: GEW-001-0759
-------
07/15/97
Index Document Munber Ordtr
CE WIRING Documents
Document Nuwber: GEU-001-0759 To 0765 Parents GEW-001-0758
Title: Community Relation* Plan. General Electric Conpany, Juana Diaz Plant
Type: PLAH
Author: none: none
Recipient: nonet none
Page: 24
Date: / /
Document Number: GEW-001-0766 To 0766
Date: 06/18/B6
Title: {Letter re: Revised Work Plan for Remedial lnve*tis»tion. G.E. Wiring Devices Site. Juana
Diaz, Puerto Rico)
Type: CORRESPONDENCE
Author: Kaplan. Arthur I.: General Electric
Recipient: Czapor, John V.: US EPA
Attached: CEU-001-0767
Document Nuraber: GEW-001-0767 To 0767 Parent: GEW-001-0766
title: Remedial Investigation Work Plan Projected Schedule
Type: PLAN
Author: none: none
Recipient: none: none
Date: / /
Document Number: GEW-001-0768 To 0769 Date: 08/20/86
Title: (Letter re: Notification of Time Extension. G.E. Wiring Devices Site, Juana Diaz, Puerto Rico)
Type: CORRESPONDENCE
Author: Kaplan. Arthur L.: General Electric
Recipient: Czapor, John V.: US EPA
Document Nuraber: GEU-001-0770 To 0770
Title: (Letter re: G.E. Wiring Devices Site. Juana Diaz, P.R., CERCLA «106 Order)
Type: CORRESPONDENCE
Author: Kaplan, Arthur L.t General Electric
Recipient: Font, Jose C.i US EPA
Attached: CEW-001-0771 GEW-001-0773 GEW-001-0776
Date: 09/23/86
-------
07/15/97 Index Document Number Order Page: 25
GE WIRING Documents
Document Nunber: GEW-001-0771 To 0772 Parent: GEW-001-0770 Date: 06/01/86
Title: table 1, Mercury Concentration, General Electric - Juana Diaz
Type: DATA
Author: none: none
Recipient: none: none
Document Nunber: GEW-001-0773 To 0773 Parent: GEW-001-0770 Date: 09/11/86
Title: (Letter re: Analyses of soil samples sent to Oxford Laboratories. Inc., for comparative Mercury
study by Cold Vapor Technique)
Type: CORRESPONDENCE
Author: Tersegno, Vincent J.: Law Environmental Services
Recipient: Sellers, Mark A.: Law Engineering Testing
locuaent Nunber: GEW-001 -0774 To 0774 Parent: GEW-001-0770 Date: / /
I
Title: Table 2, Comparative Analyses of Soil Samples for Mercury Concentration
Type: DATA
Author: none: none
Recipient: none: none
Document Nunber: GEW-001-0775 To 0775 Date: 10/08/86*
Title: (Letter re: Submittal of Report, Remedial Investigation, General Electric Wiring Devices Site.
Juana Diaz, Puerto Rico)
Type: CORRESPONDENCE
Author: Sellers, Mark A.: Law Engineering Testing
Recipient: Ciapor, John V.: US EPA
Attached: CEW-001-0776
Document Number: GEW-001-0776 To 1210 Parent: GEW-001-0775 Date: / /
Title: Remedial Investigation Report for General Electric Wiring Devices Site, Juana Diaz, Puerto
Rico
Type: REPORT
Condition: MARGINALIA
Author: none: Law Engineering Testing
ipient: none: General Electric
-------
07/15/97
Index Document Nunfcer Order
GE HIRING Documents
Page: 26
•••••••••••••••••••••••I
************
• »•»«*»«'»«»««»»»»««•
Document number: GEW-001-1211 To 1211
Date: 04/09/87
Title: (Letter r«: Remedial Investigation Report. General Electric Wiring Devices Site. Juana Diaz.
Puerto Rico)
Type: CORRESPONDENCE
Author: I8nacio. Rafael L.: PR Industrial Development Conpany
Recipient: Gelabert. Pedro A.: US EPA
Document number: CEW-001-1212 To 1264
Title: Transcript of GE Meeting held 04/28/87 (written in Spanish)
Type: OTHER
Author: none: none
Recipient: none: none
Attached: GEW-001-1265
Date: 04/28/87
Document Mumber: GEW-001-1265 To 1314 Parent: GEW-OOM212
Title: English translation of transcript of GE Meeting held 04/28/87
Type: OTHER
Author: none: none
Recipient: none: none
Date: 04/28/87
Document Nuraber: GEW-001-1315 To 1315
Date: 04/30/87
Title: News article titled: "Mercury Only Pollutant Found .at GE Ju-na Diaz Waste Site: GE duip one
of eight P.R. Superfund sites; total estimated cleanup cost could be S37M"
Type: OTHER
Author: Luxner, Larry: Caribbean Business
Recipient: none: none
Document Number: GEW-001-1316 To 1316 O.t«. 07/31/87
Title: (Transarfttal clip rt: Work Plan for Supplemental Soil Sampling and Ptt Analyses)
Type: CORRESPOUDEVCE
Author: Coffuroa. Clem M.: Law Environmental Services
Recipient: O'Neil, Carlos E.: us EPA
Attached: CEW-001-1317 CEW-001-1324
-------
07/15/97 Index Oocunent Number Order Page: 27
CE WIRING Documents
•aBBBaaaaaaaBaaaaaaaaaaaaaaBaaaaBBaBBBaaBBKaaaBaBaaaBBaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaaBBBBaBaaaaaaaaaaaBsciaaa
Document Number: CEU-001-1317 To 1323 Parent: GEW-001-1316 Date: II
Title: Document No. 1 - Work Plan for Supplemental Soil Sampling, General Electric Company Wiring
Devices Facility, Juana Diaz, Puerto Rico
Type: PLAK
Author: none: none
Recipient: none: none
Document Number: GEU-001-1324 To 1326 Parent: GEW-001-1316 Date: / /
Title: Document No. 2 - Work Plan for PCS Analyses, General Electric Company Wiring Devices Facility,
Juana Diaz, Puerto Rico
Type: PLAN
Author: none: none
Recipient: none: none
ocument Nunber: GEU-001-1327 To 1343 Date: 08/01/87
Title: Work Plan for Feasibility Study, Mercury Waste Site, Juana Diaz, Puerto Rico
Type: PLAN
Author: none: Law Environmental, Inc.
Recipient: none: General Electric
Document Number: GEW-PQ1-13W To 1344 Date: 11/25/87
Title: (Letter re: Feasibility Study Report. Wiring Devices of Puerto Rico, Inc., Juana Diaz, Puerto
Rico)
Type: CORRESPONDENCE
Author: Chcpan, Phil M.: Law Environmental. Inc.
Recipient: Kaplan, Arthur L.: General Electric
Attached: GEW-001-1345
-------
37/15/97 Index Document dumber Order Page. 28
CE WIRING Document*
Document Nurfcer: GEW-001-1345 To 14H p,rent. CEU.0OM344 Date: 11/01/87
Title: Feasibility Study, Corrective Action Alternatives for waste with Mercury Constituent, wiring
Devices of Puerto Rico, Inc.. Juana Dial. Puerto Rico
Type: »LAK
Condition: MISSING ATTACHMENT
Author: none: law Environmental, Inc.
Recipient: none: General Electric
Attached: CEU-001-1395 GEW-001-K16
Document Number: CEU-001-1395 To U15 Parent: GEW-001-1345 Date: 12/02/86
Title: (Letter re: Attached Report of Preliminary Testing and Evaluation, Solidification/Fixation
Agent, C.E. Wirinfl Devices Plant, Juana, Puerto Rico)
Type: CORRESPONDENCE
Author: McNelis. Kathleen A.: Law Environmental Services
Recipient: Schauseil, Robert !.: General Electric
Jocunent Nuntoer: GEU-001-1416 To U93 Parent: GEW-001-1345 Date: 12/02/86
Title: (Letter re: Attached Chemical Analyses of Samples Received on August 4, 1966)
Type: CORRESPONDENCE
Author: Tersegno, Vincent J.: Law Environmental Services
Recipient: Wheeless, Dave: Law Environmental Services
Document Number: CEW-001-U96 To 1*94 Oatt. u/os/BT
Title: (Letter re: Administrative Consent Order No. Il-CERCLA-3030. dated January 16, 1984, General
Electric Company, Juana Diaz,.P.R. Plant)
Type: CORRESPONDENCE
Condition: KISSING ATTACHMENT
Author: Kaplan, Arthur I.: General Electric
Recipient: D( Forte, Micolett*: US EPA
Attached: GEW-001-U95
-------
'07/15/97 Index Document Number Order P»s«: 29
GE WIRING Documents
Document Number: GEW-001-U95 To 1631 Parent: CEW-001-U94 Date: 11/12/87
Title: (Letter re: Attached Addendum to the BI/FS Study, General Electric Wiring Devices Site, Juana
Diaz, Puerto Rico)
Type: CORRESPONDENCE _
Condition: DRAFT; MARGINALIA
Author: Sellers. Mark A.: Law Engineering Testing
Recipient: Kaplan, Arthur L.: General Electric
Document Number: CEU-001-1632 To 1632 Date: 03/15/88
Title: (Law Environmental Client Contact Form)
Type: CORRESPONDENCE •
Condition: MARGINALIA
Author: none: Law Engineering Testing
Recipient: Messina, Frank J.: US EPA
h * • *
ocument Number: GEW-001-1633 To 1851 Date: 09/01/86
Title: BC Package for Project 6331 - GE/Juana Diaz, July, August, and September. 1986
Type: DATA
Condition: MARGINALIA
Author: none: none
Recipient: none: none
Attached: GEU-001-1852
Document Number: GEW-001-1852 To 1852 Parent: GEU-001-1633 Date: 04/11/88
Title: (inter-office Memorandum re: Project 6331 - GE Juana Diaz, Work Performed July to September,
1986)
Type: CORRESPONDENCE
Author: Helride, Clifford H.: Law Engineering Testing
Recipient: Sellers, Mark A.: Law Engineering Testing
-------
07/15/97
Index Oocunent Nunfcer Order
CE WIRING Documents
Page: 30
Document Hunber: GEU-001-1853 To 1853
Date: 04/15/88
Title: aetter re: Supplemental Data Submittal. laboratory Ouality Assurance/Quality Control, General
Electric Wiring Devices Site, Juan* Diaz, Puerto Rico)
Type: CORRESPONDENCE
Condition: MISSING ATTACHMENT
Author: Allen, David A.: law Engineering Tetting
Recipient: Kaplan. Arthur L.: General Electric
Document Number: GEU-001-1854 To 1856
Title: (Meaorandum re: Mercury Validation Results)
Type: CORRESPONDENCE
Author: Messina, Frank J.: us EPA
Recipient: DiForte, Hicoletta: US EPA
Date: 05/12/66
Docusent Number: GEU-001-1857 To 1894
Title: G.E. Wiring Devices, Addendum Feasibility Study, Septenfcer, 1988
Type: PLAN
Condition: MISSING ATTACHMENT
Author: none: US EPA
Recipient: none: none
Attached: GEW-001-1895 GEW-001-1919 GEU-001-1920
Date: 09/01/88
Document Number: GEU-001-189S To 1918
Parent: GEW-OD1-1857
Date: 08/22/88
Title: (letter re: Status report on the work performed by the Bureau of Mines with attached Bureau
of Mines Report)
Type: CORRESPONDENCE
Author: Schmidt, William B.: US Dept of the Interior
Recipient: DiForte, Nicoletta: US EPA
-------
Index Document Number Order P*i*: 31
GE WIRING Documents
Doc«nt number: CEW-001-1919 To 1919 Parent: GEW-001-1857 Date: 09/01/88
Title: (letter re: Quality Aaaurance Project Plan for EPA Work Assignment 649, Sampling and Analysis
of Ground Water and Soil Samples, G.E. Wiring Devices, Juana Diaz, Puerto Rico)
Type: CORRESPONDENCE
Author: Goltz, Robert 0.: Canp Dresser I McKee (COM)
Recipient: Harvelt, Rose: US EPA
Document Number: GEW-001-1920 To 1941 Parent: GEW-001-1857 Date: 09/01/88
Title: Quality Assurance Project Plan, Sampling and Analysis of Grouodwiter and Soil Samples, G.E.
Wiring Devices, Juana Diaz, P.R.
Type: PLAN
Author: none: Lee Wan I Associates
Recipient: none: US EPA
w™
it Number: GEW-001-1942 To 1943 Date: 09/13/88
title: (Letter re: Trip Report, Sampling Investigation Report, Data Surmary, and Evaluation Report
for EPA Work Assignment 649, G.E. Wiring Devices, Juana Diaz, Puerto Rico)
Type: CORRESPONDENCE
Author: Goltz, Robert D.: Camp Dresser t McKee (COM)
Recipient: Marvel I, Rose: US EPA
Attached: GEW-001-1944
Document Number: GEU-001-1944 To 2193 Parent: GEW-001-1942 Date: 09/13/88
Title: Trip Report, Sampling Investigation Report, Data Summary and Evaluation Report, G.E. Wiring
Devices, Juana Diaz, Puerto Rico
Type: PLAN
Author: none: Lee Wan t Associates
Recipient: none: US EPA
-------
07/15/97
Index Document Number Order
CE WIRING Detriments
: 32
Pocuwnt Muaber: CEU-001-2194 To 2198
Title: (Memorandum re: Discharge of Vastewater from CERCIA Sites fmo POTWS)
Type: CORRESPONDENCE
Condition: MARGINALIA
Author: Longest, II, Henry L.: US EPA ~
Recipient: none: US EPA
Date: 04/15/66
Document Number: GEW-001-2199 To 220B
Title: (Memorandum re: Interim Guidance on Superfund Selection of Remedy)
Type: CORRESPONDENCE
Author: Porter, J. Winston: us EPA
Recipient: none: US EPA
Attached: GEW-001-2209
Date: 12/24/86
Document Kureber: OEU-001-2209 To 2209 Parent: CEU-001-2199
Title: Proposed Remedy Selection Process Under Reauthorization Chart
Type: CKAPKIC
Author: none: none
Recipient: none: none
Date: / /
ficcumnt Kinber: G£W-001-2210 To 2213
Date: 05/21/87
Title: Cletter re: Agency'* iMpteaentation of the Superfund Amendments and Seauthoriration Act of
19S6 (SARA}}
Type: CORRESPONDENCE
Author: Thomas. Lee M.: us EPA
Recipient: Ptorio, James J.t US Congress
Attached: CEU-001-22U
tecumnt Nursber: CEW-001-22U To 2217
Tittt: (Letter re: Requirements of Section 121)
Type: CORRESPONDENCE
Author: Florlo. Jane* J.t US Congress
Recipient: Thomts, Lee H.t US EPA
Parent: CEW-001-2210
Bate: 03/27/87
-------
17/15/97 Index Document Number Order Page: 33
GE WIRING Documents
Document Number: GEW-001-2218 To 2219 Dote: 05/29/87
Title: CNetaorandum re: Review of interim Guidance on Compliance with ARAR's)
Type: CORRESPONDENCE
Author: Wei swan, Arthur B.: US EPA
Recipient: none: none
Attached: GEU-001-2220
Document Number: GEU-001-2220 To 2227 Parent: GEW-001-2218 Date: / /
Title: Interim Guidance on Compliance with Applicable or Relevant and Appropriate Requirements
Type: PLAN
Condition: DRAFT
Author: none: none
Recipient: none: none
it Number: GEW-001-2228 To 2236 Date: 07/09/87
/itte: (Memorandum re: Interim Guidance on Compliance with Applicable or Relevant and Appropiate
Requirements)
Type: CORRESPONDENCE
Condition: HARCINAUA
Author: Porter, J. Winston: US EPA
Recipient: none: none
Document Number: GEU-001-2237 To 2283 Date: 09/01/84
Title: Health Effects Assessment for Mercury
Type: PLAN
Author: none: US EPA
Recipient: none: none
m****m*mm
-------
07/15/97
Index Document Number Orde
CE WIRING Documents
Page: 34
OocuMnt timber: GEW-001-2284 To 2320
Tittt: Craft Coat Estimates for Remedial Action Alternatives
Typt: FINANCIAL/TECHNICAL
Author: none: It* Wan £ Associates
Recipient: none: Camp Dresser t McKee (COM)
Date: 08/31/86
Document Hunter: CEU-001-2321 To 2326
Titlt: (Proposed Remedial Action Plan for site, written in Spanish)
Type: PLAV
Author: none: US EPA
Recipient: none: none
Attached: GEU-001-2327
Date: 09/01/88
Document Nusber: GEW-001-2327 To 2332 Parent: CEW-001-2321 Date: 09/01/88
Title: Proposed Remedial Action Plan, C.E. Wiring Devices Superfund Site, Jusna Diaz, Puerto Rico
Type: PUN
Author: none: US EPA
Recipient: none: none
Document limber: GEW-001-2333 To 2334
Date: 09/22/88
Title: (Letter concurring with EPA that alternative 9, Hydrometsllurgical Treatment, is the most
environmentally sound and cafe alternative while noting more detailed studies on grounduater
are needed prior to taking any action)
Type: CORRESPONDENCE
Author: Torres, Heriberto: PR. Connonwealth of
Recipient: O'Heitl. Carlos E.: US EPA
Docwwnt Nuaberx CEU-001-2335 To 2336
Title: (Letter re; Receipt of Draft Feasibility Study Report)
Type: CORRESPONDENCE
Author: Ignacio, Rafael L.: PR Industrial Development Company
Recipient: O'Neill. Carlos E.: US EPA
Date: 09/23/88
-------
07/15/97
Index Document Number Order
CE WIRING Document§
*****************************nr******************K**m
Page: 35
************************
Document Number: CEU- 001 -2337 To 2381
Date: 09/29/83
Title: Research and Development: Final Draft, Endangernent Assessment. General Electric Wiring Devices
Site, Juana Diaz, Puerto Rico
Type: REPORT
Author: none: US EPA
Recipient: none: US EPA
Document Number: CEU-001-23S2 To 2382
Title: (letter re: Attached copies of the final version of the Bureau's report)
Type: CORRESPONDENCE
Author: Schmidt, William I.: US D«pt of the Interior
Recipient: Diforte, Nicoletta: US EPA
Attached: GEW-001-2383
Date: 10/27/88
ocument Number: CEU-001-2383 To 2408
Parent: CEU-001-2382
Date: 10/27/88
title: lureau of Nines Technologic Screening Study for Wastes from the C.E. Wiring Devices Superfund
Site, Juana Diaz, Puerto Rico
Type: REPORT
Author: staff: Reno Research Center
Recipient: none: none
Document Number: (5EW-001-2409 To 2425 • Date: 10/01/87
Title: Research and Development: Site Analysis, C.E. wiring Devices, Juana Diaz, Puerto Rico
Type: REPORT
Author: Feus*, L. Mike: lionetica Corporation
Recipient: none: US EPA
Document Nuaberi C£W-001-242o To 2426
Date: 12/01/95
Titlt: (Letter re? Addendum to the Revised laseline Risk Assessment, C.E. Wiring Devices Site, Juana
Diaz. Puerto Rico, and Health and Endanaenwnt Assessment Work Assignment)
Type: CORRESPONDENCE
Author: Craber, Scott I.: COM Federal Programs Corporation
cipient: Sniesiek, Erwin: US EPA
Attached: CEW-001-242?
-------
37/15/97 Index Document Number Order p,8,. 35
CE WIRING Documents
mm*mmmmummmmm*mmnnn*************n**mmm*m*mm*m**nmm*m*m*mmmmmmmm*mnmmm*nmnn*umm*m*m***m*mm*mm****ummm*m*n*m**m*
Document Nuaber: CEW-001-2427 To 2463 Mrtflts GEW001-2426 Date: 12/01/93
Title: Revised lasellne Risk Assessment Addendum for the C.E. Wiring Devices Site. Work Assignment
No. C02120
Type: REPORT
Author: Oxford, Jeniffer: COM Federal Programs Corporation
Recipient: none: US EPA
Cocuntnt Ninber: GEW-001-2464 To 2464 0-te: (,8/26/93
Title: (Letter re: Draft laseline Risk Assessment, G.E. Wiring Devices Site, Juana Diaz, Puerto Rico.
and Health and Endangenwnt Assessment Work Assignment)
Type: CORRESPONDENCE
Author: Graber, Scott B.: COM Federal Programs Corporation
Recipient: Smieszek, Erufn: US EPA
Attached: GEU-001-2465
Occunent Mursber: CEW-001-2465 To 0043 Parent: GEW-001-24&4 Date: 08/26/93
Title: Draft Baseline Risk Assessment for the G.E. Wiring Devices Site, Work Assignment No. C02120
Type: REPORT
•Author: Faulk, Jack: COM Federal'Programs Corporation
Recipient: none: US EPA
Document Number: SEW-002-0044 To 0075 Oate: 09/30/88
Title: Record of Decision, G.E. Wiring Devices. Juan. Diaz, Puerto Rico
Type: REPORT
Author: Muszynsfci, uilltMij.: us EPA
Recipient: none: none
-------
May 17th, 1999
Caroline Kwan
Remedial Project Manager
US. Environmental Protection Agency
290 Broadway, 20* Floor
New York, NY 10007-1866
Ref: Superfund Post-Decision Proposed Plan
G.E. Wiring Devices Superfund Site
Juana Diaz, Puerto Rico
Dear Ms. Kwan:
This letter is to provide further comments on the project of reference and to emphasize on
questions that were not properly answered during the public meeting of May 13, 1999, in Juana
Diaz. I am writing as a resident of Juana Diaz who is concerned with the safety and health of the
community. My questions or comments are as follow:
1. Please make sure that the translation of the proceedings in Juana Diaz are properly
addressed. EPA provided a translator to facilitate communication with the community
during the meeting The court reporter was only typing the comments and responses in
Spanish and used an audio tape recorder for the duration of the meeting. The audio tape
needs to be reviewed carefully because the translator was doing interpretation instead of
translation. The translator put things on her own way and did not convey the information
exactly as it was presented by EPA, GE and the public. It is very important that these
proceedings be translated correctly since it was obvious that the translator is in favor of
the project and not a neutral party. She added many comments of her own that were not
expressed by EPA or GE.
2. As expressed and confirmed in the meeting there will be some residual mercury
contamination (less than 39 ppm) left at the site. We were also informed that because the
clay layer at the site is 'Very impermeable" there would not be a concern with
groundwater contamination. No technical data on the permeability of the clays at the site
was available. GE nor EPA were able to provide a specific answer on the permeability.
Please provide this information.
3. We were informed at the meeting that the excavated area will be filled with permeable
clean material. There was no justification or explanation provided for this action. EPA and
GE must justify the rationale for the decision to backfill the excavated area with clean soil
. *
Page 1 of 3
-------
that is more permeable than the underlying clay layer. Even under the Subtitle D
regulations there is a requirement for installation of a protective cap that has the same or
lower permeability as the underlying soil. Clay materials are readily available in Juana Diaz
and the cost of this clay would probably be similar to any other imported clean material.
EPA should also evaluate the use of an HDPE cover system if more permeable material is
used as fill material.
4, Based on the explanation of how the contaminated soil was removed and the presence of
'Very impermeable" clay one must conclude that at the end there will be a clay bowl filled
with permeable material. We must also assume that rain water will not migrate away from
this bowl and will remain there for extended periods of time. What will happen with the
water when this bowl overflows? Where will it go? Will the water cany mercury
contamination with it? Is the remaining mercury in a form that it could leach? Please
explain.
5. The question on long term liability on GE was asked several times and was never
answered. Once the project is completed and GE closes the operations in Juana CHaz, what
happens with the site? Does GE continue to be responsible and liable or is GE released
from all liability? If after GE is gone there is an environmental incident at or near the site
involving GE's mercury, who is responsible for the remediation? Please explain.
6. Please explain and justify the decision to stop ground water monitoring only after three
years. The only answer we heard at the meeting is that nothing has happened in 30 years
and nothing should happen in the future. Should there be ground water monitoring for a
longer period of time?
7. I respectfully request that EPA and GE conduct an additional public meeting as soon as
practicable. The people that conducted this meeting were not properly prepared for it.
There should have been immediate answers to the questions that were presented. One
could tell that the attitude of some of the presenters was not the best one and were
uncomfortable with the questions being asked. The body language of the gentleman
representing EPA's Region II in New York said it all. Too many times people asked him
questions directly and his response would be "Who me? " or "Why are you asking me? ".
One did not need to hear what he said, his gestures said it all.
A new meeting needs to be conducted since the people left the meeting on May 13 feeling
that the presenters did not know what is going on. No clear answers were provided in
many cases. Former GE employees at the meeting are not confident that all mercury has
been removed. We were expected to just accept the general information in good faith. At
a new meeting EPA and GE should present technical data that supports the decisions
made regarding this project. There should be diagrams depicting the hydro-geology of the
site and its surroundings, surface water management, ground water analytical data, and
analytical data of the contaminated soil remaining onsite. In general the meeting should
Page 2 of 3
-------
contain sufficient technical information justifying the project so the citizens of Juana Diaz
feel comfortable with the remedy selected. At this time I am not convinced that this
remedy is fully protective of the environment and the surrounding community.
I trust that GE and EPA will provide us with the information that we need for our peace of mind
Cordially,
Rene R. Rodriguez,
POBox
Juana Diaz, PR 00795-0864
c Santiago Martinez, Juana Diaz Mayor
Page 3 of 3
-------
-------
•->
*
*•*
QE ugnting
May 24,1999
VIA FEDERAL EXPRESS ANH FIRST CLASS MAIL
Caroline Kwan, Remedial Project Manager
U.S. Environmental Protection Agency
290 Broadway, 20th Floor
New York, NY 10007-1866
Re: GE Wiring Devices Superfund Site
Juana Diaz, Puerto Rico
Dear Ms. Kwan:
Enclosed for filing on behalf of the General Electric Company ("GE") are an
original and two copies of GE's comments on EPA's Post-Decision Proposed Plan for
the GE Wiring Devices Superfund Site.
If you have any questions concerning these comments, please do not hesitate to
contact me at (216) 266-3026.
Sincerely
Matthew O. Tanzer
Enclosures
-------
-------
COMMENTS OF THE GENERAL ELECTRIC
COMPANY ON THE POST-DECISION PROPOSED
PLAN FOR THE GE WIRING DEVICES
SUPERFUND SITE, JUANA DIAZ, PUERTO RlCO
MAY 22,1999
Prepared by
Mart/raw O. Tanzw
GE Lighting
General Electric Company
1975 Noble Road- Nela Park
Cleveland, OH 44112
(216) 266-3026
Tom J. Hartan
GE Lighting
General Electric Company
1975 Noble Road - Nela Part
Cleveland, OH 44112
(216) 266-2672
Lawrence W. Diamond
Duane, Moms & HeckscherLLP
One Gateway Center, Suite 1210
Newark, NJ 07102
(973) 733-9880
-------
-------
COMMENTS OF THE GENERAL ELECTRIC COMPANY
ON THE MARCH 1999 POST-DECISION PROPOSED PLAN FOR THE
GE WIRING DEVICES SUPERFUND SITE, JUANA DIAZ, PUERTO Rico
The General Electric Company (GE) submits the following comments on the
March 1999 Post-Decision Proposed Plan for the GE Wiring Devices Superfund
Site, Juana Diaz, Puerto Rico. GE strongly supports EPA's recommended
remedy change to allow for the off-site disposal of mercury impacted materials in
a permitted RCRA Subtitle C hazardous waste landfill in the United States.
These comments provide additional details regarding GE's support for this
proposed remedy change.
GE SUPPORTS EPA'S POST-DECISION PROPOSED PLAN
As stated above, GE provides its unequivocal support for EPA's Post-Decision
Proposed Plan. The change, in remedy recommended by EPA provides the best
balance and is the most suitable remedy with respect to the NCP evaluation
criteria. It will provide complete protection of human health and the environment,
greater implementability, fewer short-term risks and significantly lower costs as
compared to waste treatment in the GEMEP treatment system with on-site
disposal of treated materials. The chosen remedy satisfies not only the statutory
and regulatory criteria, but also is the best option for the people of Juana Diaz
and Puerto Rico. Off-site disposal will completely remove the contaminated
waste fill materials from the island of Puerto Rico and dispose of them in a
permitted, RCRA Subtitle C landfill in the US. Thus, not only will the
contaminants will be removed from the site, but there will be no backfilling of
treated, iodine and mercury containing residuals as was contemplated under the
original remedy.
GE SUPPORTS THE LIMITED SCOPE OF THE COMMENT PERIOD
As explained by EPA in the Proposed Plan,
"EPA is soliciting comment only on a focused portion of the 1988 ROD for
the site. This change deals only with the off-site disposal of mercury
impacted material at a permitted RCRA Subtitle C hazardous waste landfill
on the mainland Uninted States, as an alterative [sic] to on-site treatment
using the GEMEP treatment system and subsequent backfill. EPA is not
proposing to change the established site-specific cleanup goals."
(Emphasis in original.)
G*N«AL ELECTS CO«~MY MAY*, 1W9 -
Commants on Juana Diaz
Poet-Oacisfon Propo«»d Plan
-------
GE fully supports the limited purpose and scope of the comment period, since
the only issue subject to review, and therefore open to public comment, is EPA's
recommended remedy change to off-site disposal instead of GEMEP treatment.
Due to recent events at GE's plant in Juana Diaz, there may be comments
submitted to EPA which seek to open issues unrelated to EPA's proposed
remedy change (e.g., issues related to the plant closure, or requests for
additional investigation activities). Any such comments are not germane to the
limited purpose of the public comment period, and should not properly be
considered in EPA's decision-making process. EPA has clearly and carefully
delineated the limited scope and purpose of the public comment period, and
comments received which do not relate specifically to the proposed change of
remedy should not be entertained by EPA. GE strongly encourages EPA not to
address or include such unrelated or irrelevant comments in its deliberations
relative to this Proposed Plan.
GE BELIEVES NO FURTHER SITE INVESTIGATION IS NECESSARY,
ABSENT NEW INFORMATION ABOUT THE SITE
As mentioned above, some commenters may request additional investigations at
or around the Juana Diaz site, or even at other locations in the Juana Diaz area,
perhaps due to GE's announced plant closing. However, the site was the subject
of numerous investigations in the 1980's and 1990's, and the remedial
investigation was formally completed and approved by EPA in 1993. In addition,
since commencing on-site remediation in 1997, GE has excavated to the edges
of the waste fill area, and documented, through hundreds of confirmatory
samples, that the residential cleanup standard has been achieved. Therefore, in
the absence of new information dictating a need to reopen past investigations,
GE hereby states its opposition to conducting any additional investigations on, at
or around the Site.
GE NOTES THAT THE PROPOSED PLAN WILL RESULT IN LESS RESIDUAL
MERCURY-CONTAINING MATERIAL AT THE SITE
GE supports the Proposed Plan and the removal and off-site disposal of Site
waste materials since that will result in less residual mercury-containing material
remaining at the site. While both the GEMEP remedy and the proposed off-site
remedy would reduce mercury concentrations at the site to the residential
cleanup standard of 39 ppm, the off-site remedy will nmov* all of the washed,
oversized material from the site, whereas the GEMEP remedy would have this
material - which still contains low concentrations of mercury - backfilled on-site.
In addition, the off-site remedy will completely remove the approximately 10,000
tons of untreated fines from the site, whereas the GEMEP remedy would also
have had this material backfilled on-site following treatment, when it also would
contain low concentrations of mercury and high concentrations of iodide.
GENERAL ELECTWC COMMMY MAY 24,1999 - PAOC 3
Comments on Juana Diaz
Post-Decision Proposed Plan
-------
GE RECOMMENDS FLEXIBILITY IN THE PROPOSED PLAN TO ALLOW FOR
EFFECTIVE IMPLEMENTATION OF THE REMEDY
As GE begins preparations for implementation of the remedy, it has become
apparent that a reasonable degree of flexibility in the logistics for completing the
remedy will be necessary. Consequently, GE recommends that any change to
the ROD allow sufficient flexibility for alternative logistical requirements, if
necessary. For example, GE is currently negotiating with its neighbor, PRIDCO,
to obtain rights to transport Site materials across a portion of PRIDCO's property
to access an appropriate transportation route to the Port of Ponce. This right of
access route ren.i.ns to be negotiated. If GE is unsuccessful in obtaining access
rights to PRIDCO property, it may be necessary to follow an alternative route
from the GE Site. Any amendment to the ROD should not prevent or pose
obstacles to such alternative routes.
In addition, due to the large volume of site materials to be bagged and
transported and the relatively limited amount of space remaining on-srte to
maneuver vehicles, GE's contractor, Safety-Kteen, has suggested that it may be
necessary to move some bagged material to an alternative location pending
arrival of the barge for transport to the US. This potential eventuality also should
not be precluded or obstructed by any amendment to the ROD.
In summary, GE strongly supports EPA's recommended decision in the Post-
Decision Proposed Plan, and provides these comments in the spirit of
cooperation and a desire to have the off-site remedy completed as smoothly and
efficiently as possible. If you have any questions regarding these comments,
please contact any of the undersigned.
GENttALELICnUCCOMPANY
Comments on Juana Diaz
Post-Decision Proposed Plan
-------
-------
APPENDIX 3
-------
-------
GOVERNOR OF PUERTO RICO/OFFICE OF THE GOVERNOR
ENVIRONMENTAL QUALITY BOARD
EMERGENCY RESPONSE AND SUPERFUND AREA
CORE A RPM Divisions
Supetfund Program
November 18, 1998
Mr. Melvin Hauptman, P.E., Leader
Sediments/Caribbean Team
New York / Caribbean Superfund Branch II
USEPA Region II
290 Broadway
New York, N.Y. 10007-1866
RE: FOCUSED FEASIBILITY STUDY (FFS)
G.E. WIRING DEVICES, NOVEMBER, 1998
Dear Mr. Hauptman:
The two remedial alternatives presented by GE for the completion of the remedy at General Electric
Company Wiring Devices Superfund Site in Juana Diaz, Puerto Rico are the following:
I. GE Mercury Extraction Process (GEMEP)
2. Off-Site Disposal in a Subtitle C Landfill on Mainland United States
After a thorough evaluation of the alternatives suggested, the Puerto Rico Environmental Quality
Board (PREQB) does not agree with the GEMEP alternatives for the following reasons:
• High costs
• Delays
Plugged Pumps, Eroded Pipes, and Inadequate Mixing
• Reduced Clay Removal
• Poor Filter Press Performance
Overloaded Polishing Filters
Plugged Iron Filing Bed
• Ineffective Mercury Removal
Incomplete Iron Removal
• Incomplete Iodide Oxidation (Iodine Loss)
• Inadequate Recovery of Iodine Crystals (Iodine Loss)
• Personnel Exposure to Process Chemicals
Additionally, this alternative will require 21 months or more to complete along with a long term
monitoring.
Green forests and crystalline waters, clsan air and clear skies
You protect life tf you do not contaminate!
National Bank Plaza / 431 Ponce de Leon Ave. / Hato Rey, Puerto Rico 00917
P.O. Box 11488 / Santurce, Puerto Rico 00910 / (809) 767-8181, Ext 2230 or 3230
-------
Focused Feasibility Study (FFS)
Page 2
o
On the contrary, the Off-Site Disposal in a Subtitle C Landfill on Mainland US alternative is favored
by the PREQB because it only requires 6 months or so to complete, long term monitoring is not
required, relatively low costs, and finally, as indicated on page 3-18 of the Focused Feasibility
Study (FFS) of April, 1998, off-site transportation of contaminated material represents only a
minimal risk.
For any question or comments please contact Mr. Miguel A. Maldonado Negron, Chief of the CORE
& RPM Divisions at phone number 767-8181, extension 2230.
Cordially,
RuSse Martinez
rman
a
PV/MAM/inj
• Ms. Caroline Kwm. USEFA. P^pm m
c:
-------
APPENDIX 4
-------
-------
DECLARATION STATEMENT
RECORD OF DECISION
SITE NAME AND LOCATION
GE Wiring Devices, Juana Diaz, Puerto Rico
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the GE Wiring Devices Site, in Juana Diai, Puerto Rico, developed
in accordance with CERCLA, as amended by SARA, and, to the extent
practicable, the National Contingency Plan. This decision is
based on the administrative record for this site. The attached
index identifies the items that comprise the administrative
record upon which the selection of the remedial action is based.
The Commonwealth of Puerto Rico has concurred in the selected
remedy.
DESCRIPTION OF THE SELECTION REMEDY
The remedial action would remediate the waste-fill area, perched
water, and the mercury contaminated near-surface soils to levels
which would be protective of public health. With respect to
contaminated soils downgradient of the waste-fill area, since the
mercury is primarily in the upper six inches of soil, the remedial
action would include remediation of the upper six inches of soil
at a minimum. Since groundwater data is limited, further investi-
gation and monitoring will be conducted during design to determine
the extent of groundwater contamination.
The major components of this remedial action are:
0 Further treatability studies during remedial design to insure
the implementability of hydrometallurgical processes, as well
as continued study of other treatment alternatives.
0 On-site hydrometallurgical treatment of the waste-fill materials
(approximately 4000 cubic yards), perched water (approximately
1/2 million gallons) and contaminated near surface soils
(approximatedly 1500 cubic yards);
0 Treatment of the material to below health-based levels and
back-filling the waste fill area with the treated materials.
This area will then be covered with two feet of clean soil.
0 Additional investigation of the groundwater to determine the
extent of groundwater contamination;
-------
- 2 -
Limited groundwater monitoring (i.e. for a minimum of three
years), provided that the additional groundwater investigation
establishes that there is no need for groundwater remediation-
and • • '
0 Confirmatory air monitoring and re-sampling of soil in residential
DECLARATION
Consistent with the Comprehensive Environmental Response, Com-
pensation, and Liability Act of 1980 as amended by the Superfund
Amendments and Reauthorization Act of 1986, and the National Oil
and Hazardous Substances Pollution Contingency Plan, 40 CFR Part
300, I have determined that the selected remedy is protective of
human health and the environment, attains Federal and State
requirements that are applicable or relevant and appropriate for
this remedial action, and is cost-effective. This remedy satisfies
555»!ia *to?y Preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element and
utilizes permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable.
Because this remedy will not result in hazardous substances
remaining on-site above health-based levels, the five-year remedial
action review will not apply to this action. ™eaiax
Date
.liam Jy^sfyn^i , p.E.
Acting Regional Administrator
-------
£ite Background
The G.E- Wiring Devices Site is located in the south central part
of the Island in Juana Diaz, Puerto Rico. The Site is northeast of
Ponce, close to the intersection ot Routes 14 and 149 (See, Figures
1 and 2). The General Electric Company (G.L.) operates a wiring
devices plant at this site that occupies approximately 5 acres ot
land. The property was originally leased from the Puerto Rico
Industrial Development Company (PRIDCO)j the property is now owned
by G.E.
The source of contamination at the site is the waste-fill area
where defective parts from silent mercury switches were discarded.
These switches were assembled at the plant from 1957 until 1969.
Each switch contained a hermetically sealed stainless steel button
that encased a ceramic core, containing elemental mercury. Off-
specification buttons were generally broken to reclaim the mercury.
The steel button shells, with residual mercury and ceramic cores,
were then discarded in the on-site waste-fill (pile) area where
other defective switch parts and plastic scraps were also discarded.
Based on test pit excavations, the waste-fill area is approximately
1 to 4 feet thick 110 feet wide and 440 feet long. As calculated
in the Remedial Investigation, it is probable that roughly halt a
ton of mercury was discarded in the waste-fill area, based on
mercury switch production and rejection documentation.
Several residences are located approximately 400 feet south ot the
waste-fill area. A concrete retaining wall and fence exist between
the site and the residences. Groundwater in the area is used as a
source of potable water. A public supply well is located approximately
1500 feet west of the waste-fill area.
Site History
The site was proposed for inclusion to the National Priorities list
in December 1982. The original scoring was changed in June 1983
based on public comment. A Remedial Investigation and a Feasibility
Study (RI and FS) were conducted by the General Electric Company
(GE) through its contractor Law Environmental Services at the G.E. .
Wiring Devices Site. These activities were performed pursuant to
an Administrative Consent Order II-CEkCLA-30301 dated January 16,
1984. An RI report was submitted to the U.S. Environmental Protection
Agency for review in October 1986. EPA determined that additional
investigation was necessary in order to further define the nature
and extent of contamination at the Site. A Supplemental RI and an
FS report were submitted to EPA in draft in October and November
1987, respectively. The data collected during the RI were reviewed
for conformance with EPA data validation requirements. Subsequently,
EPA concluded that the quality of the data did not meet EPA specifi-
cations. Accordingly, in August 1986 £PA in cooperation with G.E.,
collected additional samples to complete the RI activities. Maps
depicting sampling locations and a summary of results are presented
in figure 3 and 4 and Table 1, respectively.
-------
- 2 -
The draft PS did not fully evaluate treatment alternatives tor
remediation of the Site and did not fully conform with the criteria
set forth in the Comprehensive Environmental Response, Compensation
and Liability Act of 1980, as amended (CtRCLA). As a result, EPA
entered into an agreement with the U.S. Bureau of Mines to evaluate
additional treatment technologies. The objectives of this evaluation
were to identify and assess additional treatment technologies which,
if implemented, could result in achieving a more permanent remedy by
reducing the toxicity, mobility or volume ot the contaminant. EPA
then prepared an PS Addendum to further comply with CERCLA.
Community Relations
EPA has kept the local citizens and officials advised throughout
the Superfund process. Several public meetings were held in Juana
Diaz to discuss site developments. Specifically, a public meeting
was held in February 1984 to discuss the provisions of the
Administrative Order, as well as, to receive and respond to comments
concerning the site. In April 1987, a public meeting was held to
solicit comments on and discuss the findings of the RI. In September
1988, a public meeting was held to discuss and receive comments on
the studies and EPA's proposed remedial action plan. Questions ana
comments with their corresponding responses are summarized in the
attached Responsiveness Summary.
Site Characteristics
A silty clay to clayey silt unit exists immediately beneath the
waste-fill materials. This unit is believed to be continuous as
evidenced by its presence at 103 test pit excavations. The unit
appears to be from 1 to 4 feet thick based on monitoring well logs.
The permeability of the unit is in the range ot 6.0 x 10-4 to
8.0 x 10~5. However, roots were observed in the shallow soils
which could increase the permeability of the soil by developing
channels through which contaminated leachate could flow. The silty
clay unit overlies the holocene alluvial sediments deposited by the
Rio Jacaguas River as illustrated schemetically in Figures 5 and 6.
This alluvium is divided into four strata (See Figure 6); a very
silty fine to coarse sand, a sandy clayey silt, a silty sand and a
sand and gravel unit. Results of a resistivity survey indicate low
resistivities at depths of up to 12 feet in the central and western
portions of the waste-fill. This may be indicative that a zone ot
high moisture content is present in the alluvial sands which underlie
the clay stratum in some areas of the waste-fill.
This moisture could be the result of slow downward migration of
perched water through the silty clay stratum. Groundwater was
encountered within the alluvial sand and gravel formation at a
depth of about 45 feet below the existing grade. The groundwater
potentiometric gradient has been reported to be on the order of 0-01
to 0.006 ft./ft., with a groundwater flow direction to the west
towards the Rio Jacaguas River.
-------
- 3 -
Perched water accumulates within the waste-fill area as a* result of
precipitation/recharge; the perched water generally consists of a
few feet of water perched above the top of the above-referenced
clay layer. The depth to the top of the perched water is approx-
imately 2 feet below the existing grade at the waste-fill surface.
The primary route for migration of mercury appears to be through
surface runoff from the waste-fill area. This results in the
contamination of surface soils to the south of the waste-fill area
(downgradient). The waste-fill area formerly received storm-
water runoff directly from the plant area, the runoff has since
been diverted by the construction of a drain pipe in 1982. The
potential for vaporization of the mercury also exists. In addition,
as stated above, the permeability of the clay underlying the fill
area is moderate and roots were observed in these soils. Also, the
resistivity data suggests that the migration of perched water
through the silty clay stratum has occurred.
Furthermore, groundwater sampling suggests that the mercury has
migrated to the water table. The highest concentration of mercury
in the deeper groundwater (i.e., 2.2 ppb) is slightly above the
Maximum Contaminant Level (2.0 ppb). However, this result was
obtained only in one sampling round approximately 50 feet away from
the waste-fill area. The location, number and depth of monitoring
wells are inadequate to fully characterize the extent of groundwater
contamination at the site. Therefore, further investigation of the
groundwater will be conducted during design of the remedial action
to determine the nature and extent of groundwater contamination.
This work will include installation of additional groundwater
monitoring wells and groundwater sampling. Additional remedial
action may be necessary pending the results of this investigation.
The data collected during supplemental sampling indicates that
mercury was found in the following areas:
1) In an on-site surficial waste-fill (pile) area. This area
is approximately 110 feet in width and 440 feet in length and
about 4 feet deep, containing roughly 4000 cubic yards of
contaminated waste. The highest concentration observed in the
waste-fill area is 1400 parts per million (ppm) 'of mercury.
2) In perched groundwater within the waste-fill area. Approx-
imately 1/2 million gallons of contaminated water is found at
shallow depths (approximately 2 feet below the ground surface).
The highest concentration of mercury detected in the perched
water is 6.917 ppm.
3) In soils found approximately within the upper six inches
of the surface (hereinafter referred to as "near-surface
In general, mercury concentrations decreased with depth in these
soils. Ac depths below six inches mercury concentrations were
below health-based levels and approached background levels.
-------
- 4 -
soils") in an area which is in the direction of surface water
runoff from the waste-fill area (i.e., south or downgradient).
Since the number of valid soil samples is limited, the volume of
contaminated soil has been calculated by multiplying the
estimated areal extent of contamination by a depth of six
inches. The volume of contaminated soil has been estimated at
1500 cubic yards using this conservative approach. The highest
concentration of mercury detected in soils is 61.630 ppm.
Site Risks
An endangerment assessment was conducted to determine exposure
routes and concentrations of mercury which may pose a risk to human
health. The endangerment assessment evaluated the baseline public
health risks associated with the site in the absence of any remedial
action. The primary exposure routes of concern which were evaluated
were ingestion of contaminated soils/waste-fill material and inhalation
of mercury vapors. Data gathered for the EPA Mercury Health Effect
Update (1984) indicates that diet and ambient air inhalation yield
an intake of methyl mercury that is 18% of the Reference Dose (the
Reference dose is 0..0003 mg/kg-day). Therefore, in evaluating the
risks posed by ingestion of contaminated soils/waste-fill material,
the daily intake which would result in exceedence of 82% of the
reference dose was calculated using various assumptions. This—-,s
analysis indicates that mercury concentrations in excess of BB.8/ppm
may result in exceeding the reference dose. The sampling ^—^
data indicates that the concentrations of mercury in the soils and
waste-fill area exceed this value. In addition, air modelling was
conducted to predict the concentration of mercury vapors which
could be emitted given the concentration of mercury detected in
the soils and waste-fill materiaLa-r-->O?he modelling showed that
soil concentrations in excess of(l6.4\ppm may cause the EPA
National Emission Standard for a Haxa-tdous Air Pollutant (NESHAP)
to be exceeded. The NESHAP for mercury is 1 ug/m3. The
modelling also .indicates that there is a potential risk associated
with vaporization of mercury from the waste-fill area. Additional
air sampling will be conducted during the design to verify
whether the NESHAP is being exceeded.
Scope of Response Action
The objectives of the remedial action are, in general, to achieve
clean-up levels of mercury in the waste-fill area (including perched
water) and downgradient soils which: adequately protect human'health
.^ -^ _l___^^__,
As discussed previously, the groundwater database for the site 4fe
must be supplemented in order to fully characterize ground- IV
water contamination. Therefore, a supplemental groundwater
investigation will be conducted during design. Consequently,
the risks posed by groundwater contamination will be evaluated
after completion of the investigation.
-------
"- 5 -
and the environment/ are cost-effective/ and utilize permanent
solutions and alternative treatment technologies (e.g./ those which
reduce the toxcity, mobility or volume of a hazardous substance)
to the maximum extent practicable. The remedial action must also
substantively comply with applicable or relevant and appropriate
requirements.
The remedial action would remediate the vaste-fill area and the
mercury contaminated near-surface soils to levels which would be
protective of public health. With respect to contaminated soils
downgradient of the waste-fill area, since the mercury is primarily
in the upper six inches of soil, the remedial action would include
remediation of the upper six inches of soil, at a minimum. This
conservative approach should ensure the removal of all soil with
mercury concentrations above health-based levels. Since ground-
water data is limited, further investigation and monitoring will be
conducted during design to determine the extent of groundwater
contamination. •'•••••
Description of Alternatives
A total of nine remedial alternatives were identified in the
Feasibility Study and addendum for dealing with the mercury
contamination at the G.E. Wiring Devices site. They were numbered
as follows:
1 No Action
*2 Cap with Extraction Wells
3 Fixation
4 Cap, Cut-off Walls and Extraction Wells
*5 Separate Waste by Mechanical Screening
*5a Alternative 5 with Only Off-site Disposal
*6 Separate Wastes by Mechanical Screening and Washing
*6a Alternative 6 with Only Off-site Disposal
7 Excavation and Redisposal On-site
7a Alternative 7 with Off-site Disposal
8 Thermal Treatment
9 Hydrometallurgical Treatment
The six alternatives that EPA considered in greatest detail are
summarized below. Each alternative addresses remediation of approx-
imately 4000 cubic yards of waste-fill material, 1/2 million gallons
of contaminated perched water and 1500 cubic yards of contaminated
near-surface soils.
Although evaluated in the FS, Alternative 2 was eliminated
because it is ineffective compared to Alternative 4.
Alternatives 5, 5a, 6 and 6a were eliminated based on technical
feasibility since the waste is not amenable to physical
separation.
-------
- 6 -
Alternative 1
NO ACTION - This alternative is used as a baseline for comparing
other alternatives and consists of leaving the site as it is. No
response actions would be implemented other than long-term monitor-
ing which would include a minimum of three wells hydraulicallv
downgradient of the waste-fill area and three wells south of the
waste-fill area (i.e., in the area where contaminated soils have
been detected). Because the waste is left on-site EPA must
review the remedial action no less than each 5 years after the
initiation of such action to ensure that the remedial action
remains protective of public health and the environment. This
of the remedial action is required under Section 121 of
Land use restrictions would be required.
Alternative 3
FIXATION - This alternative consists of physically fixing the
waste with cenent to resist erosion. Trenches would be duq
within the waste-fill area to facilitate drainage towards a sump.
The sump, along with a leachate extraction well, would be installed
a* *he downgradient end of the waste-fill area. Perched water
within the waste-fill area would be pumped, via one extraction
well and would be pretreated on-site prior to disposal at a
publically owned treatment works (POTW). Treatment would
consist of filtration then carbon adsorption. Contaminated
near-surface soils will be excavated and consolidated in the Jfr
waste-fill area. The soils and waste-fill material would then be W
mixed with cement to blend into an aggregate solid waste. A soil
cap would be placed over the waste-fill area. This alternative
does not require any long-term pumping of leachate. Long-term
groundwater monitoring would be conducted to verify the long-term
performance of this remedial alternative. Such monitoring would
be consistent with the description provided in Alternative 1, the
No Action Alternative. In addition, the remedial action would be
reviewed every five years as with Alternative 1. Land use restrict-
ions would be required for this alternative in order to ensure
that the integrity of the remedial action or the function of any
ot the monitoring systems are not disturbed where contaminated
materials are left on site.
Alternative 4
CAP, CUT-OFF WALL WITH EXTRACTION WELLS - This alternative consists
of providing a multilayer impervious cap, slurry wall and leachate
collection system. Trenches would be dug within the waste-fill
area to facilitate drainage towards a sump. The sump with a
leachate extraction well would be installed at the downgradient
end of the waste-fill area. Perched water within the waste-fill
area would be pumped, via one extraction well and would be pre-
treated on-site prior to disposal at a POTW. Contaminated near-
surface soils will be excavated and consolidated in the waste-fill A.
area. The cap and slurry wall would then be installed. The cap •!
would be constructed of clay underlain by a synthetic membrane
-------
liner to further reduce infiltration, sand to promote drainage,
and top soil to promote vegetation and mininmize erosion. The
slurry wall would surround the landfill and would be keyed into
fjf.??1 stratum- Pumping and treatment of leachate from the
landfill would be conducted on an as-needed basis and may be
required for an indefinite period of time. The treatment system
constructed for the treatment of perched water would be used to
treat the leachate and -ould consist of filtration followed by
carbon adsorption. The treated leachate would also be disposed
of at a POTW. Long-term groundwater monitoring, consistent with
the description provided in Alternative 1, will be conducted
to assess the long-term effectiveness of this remedial alternative
Since waste remains on-site above health-based levels the remedial
action must be reviewed avery five years as with Alternative 1.
Land use restrictions would be required for this alternative.
EXCAVATION AND CONSOLIDATION ON-SITE - This alternative proposes to
rencve the contaminated material from the site and consolidate them
in a newly constructed on-site landfill to be located in the area
of contamination. The perched water would be pumped from the
waste-fill area in the same manner as in Alternative 4. The waste-
fill area would then be excavated and an impervious liner (i.e.,
with a 10-' permeability) would be placed on top of the clay
stratum. The waste and contaminated soils would then be placed on
the liner. A cap, slurry wall and leachate collection system
would be installed as with the preceding alternative. Pump'ng
and treatment of leachate from the landfill would be conducted on
an as-needed basis and may be required for an indefinite period
of time. The treatment system used for treating the perched
water would be used to treat the leachate and would consist of
filtration followed by carbon adsorption. The treated leachate
would also be disposed of at a POTW. Long-term groundwater
monitoring, consistent with the description provided in Alternative
1, will be conducted to assess the long-term effectiveness of
this remedial alternative. Since waste remains on-site above
health-based levels, the remedial action must be reviewed every
five years as with Alternative 1. Land use restrictions would be
required for this alternative.
Alternative 7a
ALTERNATIVE 7 WITH OFF-SITE DISPOSAL - This alternative is the
same as Alternative 7 except that the soils and waste from the
waste-fill area would be shipped to a RCRA Subtitle C hazardous
waste landfill in the mainland U.S., since there are currently
no permitted Subtitle C disposal facilities in Puerto Rico.
Confirmatory sampling would be necessary to verify that
contaminated materials left on site were below health-based levels
If further investigation of the groundwater confirms that there
is no significant health risked posed by groundwater, then limited
long term monitoring would be conducted (i.e., a minimum of three
-------
- 3 - ,
years consistent with the description provided in Alternative 1).
Land use restrictions would not be required.
Alternative 8
THERMAL TREATMENT - This alternative proposes to treat the contami-
nated material on-site by heating the waste until all the mercury
is vaporized. Mercury has a relatively low boiling point (375*C)
and most of its compounds decompose into metallic mercury readily
upon heating. The mercury could then be recovered and recycled.
This material may have to be reclaimed in the mainland since
currently there are no facilities on the island which recover
mercury. There is a range of temperatures at which a thermal
treatment system for recovery of mercury from the waste could be
operated. At the high end of the range is incineration of the
waste. Since a high percentage of mercury is adsorbed to the
plastic materials in the waste-fill area, the low end of the range
would be a temperature at which the mercury could be recovered
from the plastic without decomposing the plastic (between 375 *C
and 850'C). The optimal operating temparature of the thermal
treatment system would be evaluated during design. Another
potential thermal treatment option is vacuum distillation. In
this process the waste would also be heated to drive-off the
mercury and a vacuum would be applied to extract the mercury out
of the plastic. With either type of thermal treatment the mercury
vapor would be trapped and condensed. If selected, this process
would be designed to achieve levels protective of public health.
The residue from the process would be disposed of on-site in the
former waste-fill area. A two foot soil cap would then be placed
over the former waste-fill area. Since the source of contamination
would be treated and the residuals left on-site would be below
health-based levels, no land use restrictions would be necessary.
In addition, if further investigation reveals no significant
ground water contamination, then only limited groundwater monitoring
would be conducted with this alternative (i.e., a minimum of three
years consistent with the description provided in Alternative 1).
Alternative 9:
HYDROMSTALLURGICAL TREATMENT - This type of treatment would be
utilized to treat the contaminated near-surface soil, perched
water and waste-fill materials. This alternative involves putting
the -nercury into solution by using a leaching agent such as
cyanide, hypochlorite or nitric acid. The mercury would then be
recovered from the aqueous solution by using various metallurgical
techniques such as filtration and cementation/ precipitation.
The waste would be mixed with the leaching agent until 'the desired
level of mercury is extracted from the waste and put into solution,
The process stream from the leaching stage would then be filtered.
The residue from filtering *ould be disposed of in the former
waste-fill area and capped with soil as in Alternative 8. The
process would be designed to achieve treatment of mercury from
the waste to below health-based levels (i.e., less then 16.4 ppm).
Since it is anticipated that the treatment process could attain
treatment of mercury to below acceptable levels, the actual
-------
- 9 -
performance standard for the treatment process would be determined
by the maximum removal efficiency associated with the technology
with due consideration to the corresponding incremental- cost
involved in achieving further removal. The mercury-laden liquid
from the filtering stage would then be subjected to cementation
or precipitation to remove the mercury. This result is achieved
by bringing the liquid in contact with materials such as stainless
steel, zinc, copper or aluminum.
During cementation, the mercury is exchanged with the metal and
precipitated out. The liquid would then be recycled back through
the process. It is anticipated that only one batch of leaching
agent would be needed. Upon completion of the process, the
remaining liquid would be treated on-site prior to discharge to a
POTW. Further treatability studies will be conducted during
design to optimize the treatment process. The process would be
designed to meet or exceed levels protective of public health.
Since the source of contamination would be treated and the residuals
left on-site would be below health-based levels, no land use
restrictions would be necessary. In addition, if further investi-
gation reveals no significant ground water contamination, then
only limited groundwater monitoring would be conducted with this
alternative (i.e., a minimum of three years consistent with the
description provided in Alternative 1).
Analysis of Remedial Action Alternatives
The remedial action alternatives described above, were then
evaluated in accordance with the requirements of the National
Contingency Plan (NCP) and the Comprehensive Environmental Response,
Compensation and Liability Act as amended by the Superfund Amendments
and Reauthorization Act of 1986 (CERCLA). Nine criteria relating
directly to the factors mandated in Section 121 of CERCLA, including
subsection 121(b)(1)(A-G) and EPA's Interim Guidance on Selection
of Remedy (December 24, 1986 and July 24, 1987) were utilized for
this evaluation and are as follows:
Protection of human health and the environment
Compliance with applicable or relevant and appropriate
requirements (ARARs)
Long-term effectiveness and permanence
Reduction of toxicity, mobility or volume
Short term effectiveness
Implementabi1ity
Cost
Community acceptance
State acceptance
PROTECTiqN_qF_HlMAN__HEALTH AND THE ENVIRONMENT
Protection of human health and the environment is the central.
mandate of CERCLA. Protection is achieved primarily by taking
appropriate action to ensure that there will be no unacceptable
risks to human health or the environment.
-------
- 10 -
Except for the No Action Alternative each of the alternatives
affords adequate protection of public health and the environment.*
Alternatives 4 and 7 afford protection by providing a combination
of engineering (cap, slurry wall, etc.) and institutional controls
(land use restrictions). Alternative 3 provides protection by
fixing the waste which limits the availability of mercury for human
exposure. Alternative 7 provides protection by removing the contam-
inated material from the site. Alternatives 8 and 9 provide protection
through treatment of the waste which reduces the concentration of
mercury down to or below health-based levels.
COMPLIANCE WITH ARARs
Section 121(d) of CERCLA requires that remedial actions comply with
all applicable or relevant and appropriate Federal and State require-
ments for the hazardous substances, pollutants or contaminants that
are present on site, as well as any action-specific and locational
requirements.
Applicable requirements refer to those situations where the specific
legal or regulatory jurisdictional prerequisites of a particular
statute or regulation are met. Relevant and appropriate requirements
apply only to on site portions of remedial actions and are those jBk
which were developed to address problems similar to those encountered^P
at a site. A relevant and appropriate requirement must be complied
with to the same extent as if it were applicable.
With respect to requirements which are chemical-specific for mercury
contaminated soil and debris, there are no applicable or relevant
and appropriate requirements (ARARs).** Therefore, an Endangerment
Assessment was performed to determine the concentration of mercury
that would result in an acceptable risk level if left on-site. All
of the alternatives evaluated, with the exception of the No Action
Alternative, will result in site remediation which would minimize
exposure to mercury concentrations above acceptable health-based
levels. Air modelling indicates that 16.4 ppm is the lowest con-
centration of mercury which would pose a risk to public health.
Note, any potential risks posed by groundwater contamination
will be addressed following the supplemental investigation to be
conducted during design.
Note, there are chemical specific ARARs for groundwater contarnin
ated with mercury (i.e., the Maximum Contaminant Level promulgated
pursuant to the Safe Drinking Water Act), however, the risks posed
by groundwater contamination will be addressed using the data
obtained during the additional groundwater investigation to be
conducted during the design of the remedial action.
-------
< - 11 -
Air sampling will be conducted during remedial design to confirm
the results of this air modelling. If the monitoring verifies this
value, then 16 ppm will be the cleanup level for remedial action.
However, if the air monitoring indicates that there are no levels
exceeding the NESHAP, then 21 ppm, the lowest concentration of
mercury which would pose a risk to public health through ingestion,
will be used as the site cleanup level.
Potential action-specific ARARs were identified for the remedial
alternatives which were evaluated. A discussion of such potential
ARARs and the rationale for determining whether the requirement
should be considered as an actual ARAR is presented below.
With respect to locational ARARs, the site appears to be in close
proximity to known historic sites. A Stage IA survey will be
conducted during design to identify any potential undocumented
resources on or eligible for nomination to the National Register
of Historic Places.
For the alternatives which involve landfill closure (Alternatives 4
and 7) the RCRA closure regulations would be relevant and appropriate.
For Alternatives 4 and 7, the landfill would be closed in conformance
with 40 CFR Part 264, Subpart N which describes the closure requirements
for a RCRA hazardous waste landfill. Alternatives 3, 8 and 9 which
treat the contaminated materials to below health-based levels would
be closed consistent with a RCRA clean closure regulations.
For alternatives which involve discharge of perched water to a
POTW, guidance from the EPA memorandum entitled "Discharge of
Wastewater from CERCLA Sites into POTWs" would be used, as well as
the permit requirements for the specific POTW. The guidance would
preclude the use of a POTW which is out of compliance with its
permit requirements. Accordingly, the treated perched water may
only be discharged to a POTW that is permitted to accept such wastes
and is operating in compliance with that permit. The on-site
pretreatment must achieve the levels set forth in the POTW's permits.
The applicablity, relevance and appropriateness of the Land Disposal
Restrictions (LDRs) under RCRA were considered with respect to the
remedial alternatives evaluated. The LDRs would not be applicable
since the contaminated materials are not hazardous wastes. With
respect to relevancy and appropriateness, currently the only LDR
treatment standards which have been promulgated are for non-soil
and debris wastes. Treatment standards for soil and debris wastes
are currently being developed by EPA. In the interim, because there
are no treatment standards for soil and debris wastes and since
the contaminated materials found at the site are not sufficiently
similar to those for which such standards exist, the £DRs are not
considered relevant and appropriate.
-------
- 12 -
Section 121(d)(3) of CERCLA requires that if a remedial action
involves off-site disposal at a RCRA hazardous waste landfill,
such disposal may only take place if releases are not occuring
from the unit which would receive the waste and any other releases
from the disposal facility are controlled under a corrective action
pursuant to RCRA. Alternative 7a, which provides for off-site
disposal, will comply with this requirement.
While permits are not required for on-site remedial actions at
Superfund sites, any on-site remedial action must meet the
substantive requirements of the permitting process. Therefore,
any alternative which includes on-site treatment (i.e., all
alternatives except No Action) would be designed and implemented
so as to comply with the substantive requirements of applicable
permitting processes.
LONG-TERM EFFECTIVENESS AND PERMANENCE
Long-term effectiveness and permanence addresses the long-term
protection and reliability of an alternative. This is a relative
term and is therefore expressed in the degree of long-term
effectiveness and permanence associated with an alternative in
comparison to other alternatives being evaluated.
Alternative 1 The No Action Alternative offers no long-term
protection to human health or the environment. The potential
for direct contact with contaminated materials still exists.
Furthermore, erosion from the waste-fill area would continue to
contaminate downgradient (south of the waste-fill area) soils.
This alternative will require long-term monitoring indefinitely.
This alternative does not offer any degree of permanence.
Alternative 3 The Fixation Alternative would be somewhat effec-
tive in the long term in that contamination in excess of acceptable
health-based levels would be bound up in the cement and thus
exposure pathways (e.g., ingestion, inhalation) would be eliminated
-^•However, the ability of this alternative^ tp_ effectively prevent
the migration of mercury" from the fixed material indefinitely_~is
jjncertain_._ Therefore, long-term monitoring would be necessary"
and tKe" possibility exists that other remedial actions may also
be needed. Although quality control problems could be minimized
by removing the waste and then processing it instead of in-situ
fixation the waste remaining on-site would be above heal_thr.based
levels. Therefore, this alternative would not be more permanent
^TfajT-RTt e rna t i v e s la", B and 9. The degree of permanence associated
"with this alteTnaTlve iff-gteater than that which would be achieved
by Alternatives 1, 4, and 7 since the durability of cement is
greater than the construction material which would be used to
implement Alternatives 4 and 7.
-------
- 13 -
Alternative 4 The Impervious Cap with Extraction Well Alternative
is of limited effectiveness in the long term with respect to the
reliabilty of the remedial action. There is the potential for
remedy failure since the clay unit and underlying clay may not be
adequate barriers to mercury migration. This potential appears
to be further substantiated by the detection of mercury in the
groundwater. Since the waste is left on site untreated, this
alternative would require monitoring and maintenance indefinitely.
As stated above, this alternative is considered less permanent
than Alternative 3.
Alternative 7 The Excavation Alternative is of limited effective-
ness in the long term with respect to its ability to function
indefinitely. Although less likely, the potential for remedy
failure exists, as with Alternative 4. The potential for leakage
through the clays is mitigated relative to Alternative 4 by the
installation of a synthetic membrane liner under the contaminated
material and above the clay stratum. As with Alternative 4, this
alternative would also require indefinite monitoring and maintenance,
With respect to the degree of permanence, although this alternative
offers a greater degree of permanence relative to Alternative 4,
it is far less permanent than Alternative 3.
Alternative 7a Alternative 7 with Off-Site Disposal, calls for
contaminated materials to be excavated down to acceptable health-
based levels. Since all wastes in excess of health-based levels
would be transported off site there would be limited groundwater
monitoring to confirm that the action was satisfactorily completed
and no long-term operation or maintenance. With respect to the
site this alternative offers a higher degree of permanence than
does Alternative 3.
Alternative 8 The Thermal Treatment Alternative is effective in
the long term in that it reduces toxicity of contaminated material
on site and decrease the concentration of mercury found on site
to acceptable health-based levels. As with the preceding altern-
ative, there would be limited confirmatory groundwater monitoring
and no long term operation or maintenance. Since the toxicity and
the concentration of mercury in the waste is reduced to health-
based levels, this alternative offers a higher degree of permanence
than does Alternative 3. With respect to the site, the degree of
permanence associated with this alternative is equivalent to
Alternative 7a. However, in a broader perspective this alternative
is more permanent than Alternative 7a because the waste is treated
instead of being relocated.
-------
- 14 -
Alternative 9 The Hydrometallurgical Alternative is effective in
r^™?^?™ *! that ifc effectiv«ly reduces the toxicity and
^«T??£I J°n °5 mercurvJin the contaminated material 'on site
?™i 9* * dec5ease in exposure to acceptable health-based
i^?d A. F ^5 the Precedin3 alternative, groundwater monitoring
would be limited confirmatory sampling with no long-term ©Deration
arh?aioreSanCe* F^"** th* ***** ls tr^teS thS^.lJSnSSiST has
? Sh „ degree of permanence associated with it than Alternative
3. The degree of permanence is essentially equal to Alternative 8.
REDUCTION OF TOXICITY, MOBILITY OR VOLUME
lternaivhh-, relates to the Performance of a remedial
rinJ™??* * £ involves treatment in terms of eliminating or
controlling risks associated with the toxicity, mobility or volume
of a hazardous substance. Since Alternatives 1, 4, 7 and 7a do
th"e alternatives «•" not evaluated against
S^MS^JS^V?*!101**' the data indicates that a substantial
portion of the total mercury present is in the organic form.
?h2^r.merCVfy iS ^UCh m°?e toxic than inorganic mercury.
Therefore, alternatives which convert organic mercury into ino
mercury would result in a reduction in the toxic ity^f mercury
fh!6^^?^ 3 *Th! Fixation Alternative is effective in reducing
the mobility of the contaminant by preventing further erosion and
reducing infiltration. This_ alternative, however, would increase
the volume of contaminated-material. The toxicity of the waste
could potentially be reduced and" exposure to mercury from the
waste is also reduced because the waste is bound up with the
C 6TH6 n t •
Alternative 8 The Thermal Treatment Alternative would result in
a S^ntial reduction of the volume of contaminated mltlrial
fi™ ? 'i ?ince ^ue or9amc mercury is converted back into the
?Jie mobflifS^f ^ toxjcity Of the waste is significantly reduced.
The mobility of the waste is reduced proportionally to the reduction
in concentration. This alternative would result in "reduction
iS,,«?f concentration of mercury in the contaminated material by
roughly two orders of magnitude. y
Alternative 9 The Hydrometallurgical Treatment Alternative would
also result in a substantial reduction of the volume of contaminated
material on-site. As with Alternative 8, the organic mercury is
converted back into the elemental form, thus the toxicity f thl
waste is significantly reduced, in addition, the mobility of the
waste is reduced proportionally to the reduction in concentration.
This alternative would result in a reduction in the concentration
of mercury in the contaminated material by roughly two orders of
magnitude.
-------
- 15 -
Short-Term Effectiveness
-term effectiveness criterion measures how well an
Alternative 1 The No Action Alternative does not offer anv
tJ™66 ?h Protection' and therefore is not effective in the short-
term. There are however, no adverse impacts associated with
implementation of this alternative. w^*««a witn
Alternative 3 ^The Fixation Alternative would involve excavation
!? f teriai' In the Sh0rt terro' there would be a
*i 5?r W°*ker exP°sure to mercury contamination
ldjtion °f contaminated near-surface soils and
g th,e.flxatlon Process. However, this concern would be
,.
:??2rir,*he h!al?S and Safety *lan for consrcton activities.
alternative should take approximately 2 years to implement.
Alternative 4 The Cap with Extraction Well Alternative would
aiso involve excavation of contaminated materials? Consequently
in the short term, there would be the potential for worker exposure
soiK^^he^eaftn"3^0" $uJ1'V>n«>lid.tion of the near-surf acT
!™Jur* %?*?«. safety plan would address minimizing this
implement. alternative should take approximately 2 yelrs to
7 The Excavation and Consolidation On-site Alternative
e excavation of a greater volume of contaminated
3 nSSr°Xi™at*ly 55°° CUbic yards) "lative to Alternatives
3 and 4 (1500 cubic yards). This may result in an incremental
increase in the potential for worker exposure to mercurJ™S
at ion during implementation. As stated above, ttil SSeS
ShoSd^kf ln the heaJth and Safety Plan« This alternative
should take approximately 2 years to implement.
^fe!?atiY? 7a Alternative 7 with Off-Site Disposal involves
off-site disposal and would thus increase truck traffic in the
area as well as the potential for accidents involving releases
of contaminated materials. As with the preceding alternatives,
in the short term there is the potential for worker exposure to
mercury contamination during implementation. The health and
safety plan would address minimizing this exposure. This- alter-
native should take approximately a year and a half to implement.
-------
- J.O -
Alternative 8 The Thermal Treatment Alternative, as with the
preceding alternatives would involve the potential for worker
^???ur€ S° m*r<;ury contamination during implementation. The
5?S ?hf? »??f!«yi.*lan W°Uld address minimizing "this exposure.
With this alternative mercury from the off-gases would be condensed
and recovered, however, controls may be necessary to ensure that
mercury and other vapors are not released above acceptable levels
This alternative should take approximately 2 years to implement
Alternative 9 The Hydrometallurgical Alternative, as with the
preceding alternatives, involves the potential for worker exposure
to mercury contamination during implementation. The health and
SJJh LPj£n "ould address minimizing this exposure. In addition,
eacn or tne leaching agents used in the process present health
and safety and process control considerations. Specifically, for
nitric acid, since the waste-material contains plastic there is
the potential for formation of picric acid which is explosive-
for cyanide there is the potential for evolution of hydrogen
r^^ri* „„, a^ for hypochlorite there is the potential for
of chlorine gas. It should be noted, however, that
standard processes which are used in industry. These
health and safety concerns would be addressed in the
of the process. For example, the formation of picric acid
;'hl~* *L*?n 1 f *bY adJustin9 the concentration of the acid, Jfe
the formation of hydrogen cyanide gas would be controlled bv W
buffering the pH with a base solution, and the formation of W
S*^1-6!9?* would also be eliminated by buffering the pH using a
basic solution. This alternative should take approximately 2
years to implement. v^*jr
IMPLEMENTABILITY
Implementability addresses how easy or difficult, feasible or
infeasible it would be to carry out a given alternative. This
covers_implementation from design through construction and
operation and maintenance.
The implementability of the alternatives is evaluated in terms
of technical and administrative feasibility, the availability of
fe^?hi2°°dL2™^erViCeS- f11 alternatives evaluated are technically
f!^ J ZK H°yfver' some implementation problems are inherent in
each of the alternatives.
Alternative 1 The No Action Alternative does not have any
implementation problems, however, it does not offer any
degree of protection.
For alternatives which involve handling of mercury-contaminated
K^i?Klt: !? *b! ne?essary to develop and implement a site specific
health and safety plan to reduce the potential for worker exposure
to mercury. Mercury contaminated material would be handled in
fhf M A*?® Al^frnativ?s w^h the exception of Alternative Number 1,
the No Action Alternative.
-------
- 17 -
Alternatives which involve the off-site disposal of contaminated
perched water at a POTW may pose implementation problems with
respect to the availability of a POTW which complies with EPA's
guidance Memorandum entitled "Discharge of Wastewater from CERCLA
Sites into POTWS", dated April 15, 1986. In addition, permission
from the-POTW to accept the waste may be necessary.
Alternatives 8 and 9 are considered to be implementable. Both
the data collected by the U.S. Bureau of Mines in their screening
of potential treatment alternatives and available information on
similar industrial processes suggest that these alternatives are
viable options. However, further bench and pilot scale studies
would be necessary prior to design and construction to further
evaluate the effectiveness of these alternatives and to optimize
the operating and design parameters of the treatment process.
COST
The cost evaluation of each alternative is based on the capital
cost (cost to construct), long term monitoring, operation and
maintenance cost (O&M) and present worth costs.
Present worth analysis was used so that the cost of each alternative
could be compared on the same basis. The present worth value
represents the amount of money, if invested in the base year and
then expended as needed, would be sufficient to cover all costs
of the remedial action over its planned life.
The capital, O&M and present worth value for each alternative is
provided in Table 2.
COMMUNITY ACCEPTANCE
This evaluation criterion addresses the degree to which members of
the local community might support the remedial alternatives being
evaluated; and is addressed in the responsiveness summary.
COMMONWEALTH ACCEPTANCE
This criterion addresses the concern and degree of support that the
commonwealth government has expressed regarding the remedial altern-
atives being evaluated. Puerto Rico's Environmental Quality Board
concurs with EPA's selection of Alternative 9. "
-------
.t
- 18 -
Selected Remedy
The selected remedial action is Alternative 9: Hyrometallurgical
Treatment.
This general type of treatment would be used for the contaminated
near-surface soil, perched water and waste-fill materials (approxi-
mately 1500 cubic yards, 1/2 million gallons and 4000 cubic yards,
respectively). This alternative involves putting the mercury into
solution by using a leaching agent such as cyanide, hypochlorite or
nitric acid. The mercury would then be recovered from the aqueous
solution by using various metallurgical techniques such as filtration
and cementation/precipitation. The waste would be mixed with the
leaching agent until the desired level of mercury is extracted from
the waste and put into solution. The process stream from the
leaching stage would then be filtered. The residue from filtering
would be disposed of in the former waste-fill area and
capped with two feet of clean soil. The process would be designed
to achieve treatment of mercury from the waste to below health-
based levels (See ARAR discussion). Since it is anticipated
that the treatment process could attain treatment of mercury to below
acceptable levels, the actual performance standard for the treatment
process would be determined by the maximum removal efficiency
associated with the technology with due consideration to the corres-
ponding incremental cost involved in achieving further removal.
The mercury-laden liquid from the filtering stage would then be
subjected to cementation or precipitation. This process is achieved
by passing the liquid through a material such as stainless steel,
zinc, copper or aluminum.
During cementation the mercury is exchanged with the metal and
precipitated out. The liquid would then be recycled back through
the process. It is anticipated that only one batch of leaching
agent would be needed. Upon completion of the process, the remaining
liquid would be treated on-site prior to discharge to a POTW.
Further treatability studies will be conducted during design to
optimize the treatment process. The process would be designed to
meet or exceed levels protective of public health. The estimated
cost associated with Alternative 9 is $1,912,870.
As discussed above, the location and number of existing monitoring
wells are inadequate to fully characterize the extent of groundwater
contamination at the site. Therefore, further investigation of the
groundwater will be conducted during design of the remedial action.
This work will include installation of additional groundwater
monitoring wells and groundwater sampling. Additional remedial
action may be necessary pending the results of this investigation.
If further groundwater investigation determines that there are no
current or future risks posed by groundwater contamination, then
limited groundwater monitoring would be conducted to provide further
verification (i.e., a minimum of three years). In addition, air
-------
- 19 -
modelling was used in the endangerment assessment to predict the
concentration of mercury vapors which could be emitted given the
concentration of mercury detected in the soils and waste-fill
materials. The modelling showed that the concentration of mercury
in soils and in the waste-fill area may cause the NESHAP to be
exceeded. The NESHAP for mercury is 1 ug/m3. Therefore, confirm-
itory air sampling will be conducted during the design to verify
the whether the NESHAP is being exceeded. During design, confirmitory
soil samples will also be collected from residential yards which
are downgradient in terms of surface water runoff from the site.
Statutory Determinations
Section 121 of CERCLA mandates that EPA select a remedial action that
is protective of human health and the environment, cost-effective,
and utilizes permanent solutions and alternative treatment technologies
or resource recovery technologies to the maximum extent practicable.
Remedial actions in which treatment which permanently and significantly
reduce the volume, toxicity or mobility of a hazardous substance is
a principal element are to be preferred over remedial actions not
involving such treatment.
Based upon the analyses presented herein the following conclusions
are reached:
0 Overall Protection of Public Health and the Environment
Alternative 9 provides protection through treatment of waste
above health-based levels for mercury
0 Compliance with ARARs
Alternative 9 would be designed to meet or exceed ARARs. As
stated above, this alternative would reduce the concentration
of mercury down to or below health-based levels in the absence
of chemical specific ARARs for soils and debris. The residuals
will be deposited on site and covered with clean soil consistent
with a RCRA clean closure.
0 Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
»
Alternative 9 is considered to be a permanent remedial action
since the concentration of mercury remaining on site would be
below health-based levels. For this reason Alternative 9
has a greater degree of permanence relative to Alternatives 1,
-------
- 20 -
4 and 7 where wastes are left on-site, untreated, in concentrations
exceeding health-based levels. Although Alternative. 3 uses
treatment to reduce the mobility of the waste (and possibly
the toxicity) the concentration of mercury in the waste
remaining on-site would be above health-based levels. Therefore,
Alternative 9 is preferred over Alternative 3 because it does
not require indefinite management and monitoring of the site.
The degree of permanence associated with Alternative 9 is
equivalent to Alternatives 8 and 7a with respect to the site.
The degree of permanence associated with Alternative 7a is
limited in that it only addresses permanence in terms of on-site
conditions. Alternatives 8 and 9 would be permanent with
respect to off-site as well as on-site conditions.
Alternative 9 uses alternative treatment technologies to the
maximum extent practicable since it includes treatment of
all waste with mercury concentrations in excess of health-
based levels. The other treatment alternatives (i.e.,
Alternatives 3 and 8) also require the treatment of all waste
with mercury concentrations in excess of health-based levels.
However, Alternative 3 does not provide for recovery of mercury
from the waste. Thus, Alternatives 8 and 9 have the added
benefit of using alternative treatment technologies to the
maximum extent practicable while recovering mercury from the
waste thereby resulting in the conversion of a waste into a
usable material.
0 Preference for Treatment as a Principal Element
Alternative 9 satisfies the statutory preference for treat-
ment as a principal element of a remedial action since it
provides for treatment of organic mercury to inorganic mercury
which significantly reduces the toxicity of the wastes.
0 Cost-Effectiveness
Although Alternative 9 is not the least costly treatment
option it is cost-effective. The costs are reasonable in
light of the relatively small incremental (approximately
1 million dollars) cost associated with attaining a permanent
remedial action, with limited monitoring, no land use restrictions
and which utlizes treatment as a principal element.
In summary, Alternative 9 is the selected alternative, it is protec-
tive of public health, is cost-effective, and utilizes treatment
as a principal element. Alternative 9 would provide protection of
public health by using treatment to reduce the concentration of
mercury on site to below health-based levels (See ARAR discussion).
-------
V -tv
"I.
- 21 -
The treatment process employed would reduce the toxicity of the
waste by converting organic mercury into a less toxic inorganic
form and would reduce the volume of contaminated materials which
are above health-based levels. Since the residua.1 mercury concen-
tration in materials left on site would be below "health-based
levels, this alternative is considered a permanent remedial action.
Studies conducted by the U.S. Bureau of Mines and available infor-
mation on related industrial processes suggest that this alternative
could be implemented. Further bench and pilot scale studies would
be required to optimize the treatment process and minimize any
potential short-term impacts. Alternative 9 would be designed to
meet or exceed ARARs. The estimated cost for implementing Alternative
9 is $1/912,870, which is reasonable in light of the degree of pro-
tection, treatment and permanence afforded by this alternative.
Currently, Alternative 9 appears to provide the best balance of
trade-offs among the alternatives examined in detial with respect
to the nine evaluation criteria. In addition to satisfying the
statutory preference for remedies which utilize treatment as a
principal element and for permanent remedies. EPA believes that
Alternative 9 is implementable based on current information.
However, since this alternative has not been fully demonstrated and
further treatability studies are necessary, EPA believes that it is
prudent to conduct additional treatability studies on other treatment
options concurrently with those to be performed for Alternative 9.
This approach would minimize any delay in remediating the site, in
the event that hydrometallurgical treatment is not implementable.
-------
-------
> -
TABLE 1
-/
i '
CDM-FPC ' G.E. Wiring TES III HA 649 LWA Project 87525
IKORGANIC RESULTS
Croundwater Samples
LSDG LSDG SEG SAMPLE
8073
8073
3073
8073
8073
8073
8073
8074
80?4
8074
8074
8074
8074
8074
8074
8074
8074
8074
8074
8075
8075
8075
1
2
3
4
5
6
6-DU?
1
2
3
4
5
5-DUP
6
7
8
9
10
11
17
18
19
GE-GW-01
GE-GW-15
GE-GW-14
GE-GW-12
GE-GW-11
GE-GW-10
GE-GW-10-DUP
GE-GW-Jtt'
GE-GW-07
GE-GW-06
GE-GW-05
GE-GW-I6
GE-GW-16-DUP
GE-GW-B2
GE-GW-02
GE-GW-03
GE-GW-04
GE-GW-B3
GE-GW-B4
GE-GW-B5
GE-GW-B6
GE-GW-B7
TOTAL
0.
5525.
3862.
3445.
5011.
5778.
6917.
4046.
6786.
5220.
3654.
0.
0.
0.
2.
0.
0.
0.
0.
0.
MERCURY
UNITS: UG/1-
INORG
0
0
8
2
2
0
X
3
0
0
0
0
X
0
3
0
2
0
0
0
0
0
0.
10.
6.
15.
14.
22.
14.
5.
18.
13.
6.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0
4
4
2
1
8
X
9
0
0
0
4
X
0
0
0
4
0
0
0
0
0
ORG
0.
6514.
3856.
3430.
0
6
4
0
4997.1
5755.
6902.
4041.
6768.
5207.
3647.
0.
0.
0.
1.
0.
0.
0.
0.
0.
2
X
1
0
0
0
6
X
0
3
0
8
0
0
0
s
AMMONIA
-UNITS: HG/L-- '
«s H as NH3 REMARKS
0
570
3,0
300
340
420
410
400
760
590
.17
.00
.00
.00
.00
.00
.00
.00
.00
.00
560.00
890.00
940.00
0.00
0
0
.00
.00
0.00
0.00
0.00
0.21
690.00
411.00
363.00
411. JO
508.00 \
436.00 / Lab Duplicates
484.00
920.00
714.00
678.00
1077.00\Blind dup. -GE-GW-07
1137.00/Lab Duplicates
0.00-Bailer Rinsate Blank
0.00
0.00
0.00
0.00-Field Blank
0.00-Source Water Blank
Spoon Rinsate Blank
Dish Rinsate Blank
Auger Rinsate Blank
Soil Samples
8075
8075
8075
8075
3075
3075
3075
3075
3075
3075
3075
3075
3075
1 GE-S-1SU
3 GE-S-2SU
5 GE-S-3SU
6 GE-S-3DE
7 GE-S-4SU
9 GE-S-5SU
10 GE-S-6SU
11 GE-S-6DE
12 GE-S-7SU
13 GE-S-7DE
14 GE-S-8SU
15 GE-S-8DE
15 GE-3-14SU
unj
19000.0
5188.0
24950.0
61630.0
K30.0
61SO.O
479i.O
270.0
310.0
588.0
2350.0
485.0
270.0
I I SI VU/ N
5360.0
3870.0
3790.0
8710.0
390.0
2430.0
530.0
1:0.0
220.0
0.0
980.0
450.0
160.0
13640.0
1318.0
21160.0
52920.0
940.0
3750.0
4260.0
100.0
90.0
588.0
1870.0
35.0
110.0
Blind Dup.J5E-S-7SU
values reported as 0.0 are actually < 0.2
VV.CNIA values re;;rted as 0.30 ara actually < 0.1 for N ind < 0.12 for NH3.
-------
TABLE 1 CONTINUED
Page 2
VOLATILE ORGANIC RESULTS
Groundwater
..... VGA .....
REMARKS
LSDG LSDG SEG SAMPLE TOTAL COMPOUND REMARKS
8073 1 GE-GW-01
8073 2 GE-GW-15
8073 3 GE-GW-14**
8073 4 GE-GW-12**
8073 5 GE-GW-11**
8073 6 GE-GW-10**
8073 7 GE-GW-B1
8074 2 GE-GW-07**
8074 4 GE-GW-05**
8074 5 GE-GW-16**
8074 6 GE-GW-B2
8074 7 GE-GW-02
8074 8 GW-GW-03
8074 9 GE-GW-04
8074 11 GE-GW-B4
NO
5.0 BENZENE
NO
NO
NO
NO
2.0 CHLOROFORM
ND
NO
NO
ND
ND
ND
ND
ND
Trip Blank
(1)
Bailer Blank
Source water blank
* - All^ analyses performed at CLP detection limits
** "
aPPear.ed to contain surfactantsfroameA
e performed on dilu '
An« . acans
Analyses were performed on diluted samples.
(1) - Blind duplicate of GE-GW-07
ND - Not detected or below CLP detection limit.
-------
SOOBCC: DOCUMENT IS . P«£ HO. 1 . JOB m.
HIRING DEVICES Of PutBIO RICO, INC.
GENERAL UtCIRIC COMPANY
JUANA OIW. PUCRIO RICO
4
1.AW ENVIRONMENTAL
SERVICES
MMIWTT*. •«•••••
GENERALIZED SETTING IN THE
VICINITY Of THE WASTE FILL
J<» NO. 5S633I
fICUBt 1
-------
c
RIO JAGAGUAS
SCALE
SOURCE: DOCUMENT 30, PAGE NO. 10, JOB NO. MH2317.
WIRING DEVICES OF
PUERTO RICO, INC.
GENERAL ELECTRIC
CCMP.S.NY
liiA DIAZ, PUERTO RICO
LAW ENVIRONMENTAL
SERVICZ!
SITE SETTING
J0.8 NO. SS6331 FIGURE 2
-------
L
caouoHUTEit SWUNG LOCATIONS
HIRING OCVICIS OF PUIRIO «ICO. INC.
G(H(RAl IUCIRIC COVANV
JUANA OIA/. PULHtk RICO
LAW ENVIRONMENTAL
INC.
rOTENTKJMCTHIC SURFACE ELEVATION
Of rCRCHCD WATER
(MID MAY 19121
JOB NO. M-6J3I ficuRf 3
-------
— —' —
rf ^^
{jG.f.'l-itif
-------
I* •!•
•rtr
I
EXPLANATION
]«• { MOLOCIMI ALLUVIUM
TIAMV IWAM* OIAI roMMATIOMi
*«•*!*•« W««XAN(C«
CMfACC*IM VOLCANIC*
•MO ••14. «!•£• Ml CALLOW* MM MIMU*«
.'•' !».**•' •*".'•"•'..
TW. fj *B~"ltr_"..*V • Ir.tTk. . •• ••. •*.
...» MHMIM •OWIMMUtV «r MICLt. riCLO
• ^/: •'.••/.'•:• ^i,'i^oj;;i^.^^^v;;V;vf :p$>v;;' 1*0^1^* ;V-'//-:- v^
• • r^ • •''v'>Vt:'f:^/|V*f:*r^-^
f^ -.-•':-^•-'•?®^'?SK^W;:'^
V •••; -' ^^^ \^^^&
.1 • " ' ' jr UAB e*.»imr Vr . • ' :•: n'i •• • r..».
RCFERCNCE
An an oiwati. ••••
I Macs
i
I KILOMCICAS
. . . !.l I I
SOURCr: DOCUMENT 13. PAGE NO. ?9, JOB NO. MHP317.
WJRlNU DEVICES OF PUERTO RICO, INC.
GENERAL ELECTRIC COMPANY
JUANA DIAZ. PUERTO RICO
LAW ENVIRONMENTAL SERVICES
MARIETTA. OKOHOIA
GEOLOGIC UNITS AND WELL
LOCATIONS IN THE VICINITY
OF THE SITE
JOB NO. SS6331
FIGURE'S
-------
UW~1
H
0
E
P
T
H
I
N
F
E
E
T
14W-3
MW-4
WASTE
FILL
SCALE
SOURCE: DOCUMENT 30. PAGE NO. 33. JOB NO. HH2317,
•••
LAW ENVIRONMENTAL SERVICES
MANICTTA. OBOftOIA
WIRING DEVICES OF PUERTO RICO, INC.
GENERAL ELECTRIC COMPANY
JUANA DIAZ. PUERTO RICO
SITE HYDROCEOLOCIC
PROFILE
JOB NO. SS6331
[CURE 6
-------
TABLE 2
&SHARY OF
ALTERNATIVE
1. No Action
3. Fixation
4. Capping 1n place with
slurry wall
7. Excavation
7a. Alt. 7 with off-site
disposal
8. Thermal treatment
9. Hydrometallurglcal
treatment
CAPITAL
- 0 -
834,150
374,540
529,380
2,563,110
5,473,900
1,912,870
and QAM (|)
71,270
82,540
82,540
82,540
4,000
4,000
\.
-------
-------
r-
RESPONSIVENESS SUMMARY
G.E. WIRING DEVICES SUPERFUND SITE
JUANA DIAZ, PUERTO RICO
-------
-------
\
r-.
A. OVERVIEW
On September i, 1988, the U.S. Environmental Protection
Agency (EPA) Region II began a public comment period on the
proposed remedial action plan (PRAP) and supporting information
for the G.E. Wiring Devices Superfund site in Juana Diaz, Puerto
Rico. Prior to the public comment period, EPA had proposed an
alternative for cleanup of the G.E. Wiring Devices site. The
preferred alternative outlined in the PRAP is hydrometallugical
treatment, which involves mixing on-site waste containing mercury
with a leaching agent to create a solution containing the
mercury. The solution is filtered, then the mercury is removed
by precipitation or cementation. The mercury could then be
recovered.
This responsiveness summary addresses questions and comments
about the G.E. Wiring Devices site received during the public
comment period. These sections follow:
_ Community Involvement in the Selection Process
_ Summary of Comments Received During the Public
Comment Period and Agency Responses
_ Remaining Concerns
_ Attachment: Proposed Remedial Action Plan
(English Version)
_ Attachment: Proposed Remedial Action Plan
(Spanish Version).
B. COMMUNITY INVOLVEMENT IN THE SELECTION PROCESS
On the evening of September 15, 1988, EPA held a public
meeting in the Municipal Assembly Office in Juana Diaz, Puerto
Rico, to present the PRAP and supporting documents for the G.E.
Wiring Devices site. Because Spanish is the primary language of
the majority of the local residents, the meeting was held in
Spanish and English to foster public involvement. A member of
the EPA Caribbean Field Office staff translated questions to and
responses for non-Spanish speaking EPA representatives at the
meeting. In addition to being available at the information
repositories, copies of the PRAP and mercury contamination fact
sheets, in English and Spanish, were distributed at the meeting.
The two^-and-one-half hour public meeting was attended by
approximately 25 persons.
Earlier in the day, EPA held a briefing for Commonwealth and
local officials that was attended by approximately 15 people.
Questions raised during both the public meeting and the briefing,
as well as written questions and comments received by EPA during
-------
are addressea
C. SUMMARY OP COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD
Comments received during the G.E. Wiring Devices public
comment period on the PRAP and supporting documents are
?ummaraL2ed below- Tne comment period was held from September 1
1988, to September 26, 1988. The comments are categorized by
topic and similar questions have been consolidated and
summarized.
Site Remediation Schedule
1. A local official asked about the schedule for site
remediation.
PA. Response; EPA expects to sign the Record of
Decision (ROD) for the G.E. Wiring Devices site at the
end of September. After the ROD is signed, six to
twelve months of treatability studies will be
performed; therefore, it will be about one year before
the remedial action is undertaken.
2. Several people asked how long remedial action would
take once the treatability studies were completed.
EPA Response: The time frame for remediation will
depend greatly on the volume of waste that can be
treated at any particular time. It is difficult to
make an accurate prediction as to the actual length of
time for remediation until the treatability studies are
completed.
Rationale for Selection of the Preferred Alternative
1. A local official asked if Alternative 9 was proposed by
EPA because it was one of the least expensive
alternatives.
EPA Response; Although Alternative 9 is less expensive
than Alternatives 7a and 8, it is more expensive than
all of the other alternatives. EPA believes that
Alternative 9 is the most effective method of site
remediation and did not select it purely on a
lower-cost basis.
Past Sampling
1. It was asked if the residential yards near the site
were sampled.
- 2 -
-------
EPA Response? Yes, but the data were not validated.
Further sampling will be performed during the remedial
design phase to attempt to confirm these data.
2. One citizen asked what steps EPA took to talk to people
who live near the site. She stressed that she lived
near the site and her yard was not sampled.
EPA Response; Not all of the houses near the site were
sampled. The decision to sample or not was based on
the probability of finding contamination. Houses that
had the highest probability of contamination were
sampled —that is those houses which are in the
direction of surface ground-water runoff, with respect
to keeping local residents informed as to the status of
the site, EPA has held several public meetings in the
area. A public notice in the newspaper was used to
announce the recent meeting. In addition, local
officials are kept informed of the current site status,
and they in turn, inform their constituents.
Health Effects
1. Several people asked if EPA had considered the effects
of the site on health of local residents.
EPA Response; An Endangerment Assessment was conducted
by EPA which indicated potential emissions of mercury
vapor above health-based levels. With respect to
worker exposure, no exposure levels above the
Occupational Safety and Health Administration (OHSA)
standard were found or predicted at this site.
Although General Electric (G.E.) performed some testing
during the Remedial Investigation, EPA will perform
more air sampling during remedial design.
2. Several people wanted to know if EPA will perform a
health assessment on the site community and plant
workers.
EPA Response; The Federal agency responsible for this
type of investigation is the Agency for Toxic
Substances and Disease Registry (ATSDR). There is a
provision in the law for individual persons or local
physicians to petition ATSDR to perform a health
assessment if the probable source of exposure is a
release. Further information on this procedure is
available from the EPA Regional Office or the Caribbean
Field Office.
Volatile Organic/Waste Water Contamination
1. A local official asked if EPA had investigated a report
- 3 -
-------
that a sump was used to dispose of waste water at the
G.E. plant.
EPA Response?: EPA me- with the Puerto Rico Industrial
£?V?i?^n t.c?rP°»tion (PRIDCO) to obtain blueprints
of the plant in order to find the sump. The plans for
the plant were inconclusive regarding the existence of
the sump. EPA followed up with more monitoring well
and soil sampling and will continue sampling during the
nhaSe
time.*
^?^°nCerIL1Waf- raised that EPA was not addressing the
tnchloroethlyer.a (TCE) problem at the site.
R*sP°nsft? . EpA has performed some testing for
tile organic compounds (VOCs) such as TCE The
V??,that was found was very low levels of benzene.
EPA will conduct further testing for VOCs during site
remediation.
Public Notice
1. A concern was raised that adequate public notice was
not given for the meeting.
Response; EPA used several methods to inform the
public of the meeting. EPA published a public notice
iS a»r£tWSpa?er announci«9 the meeting and summarizing
JKiJ n« • press, f^ease was issued by the Caribbean
I*™. °fllce- Fliers announcing the meeting were
bi?nribU^ed t0 J^11 °f the homes in Juana Diaz ^e wSek
before the meeting and a sound truck was used on the
two days preceding the meeting. At the last minute,
due to construction at the Mayor's Office, it was
necessary to change the meeting location to the
temporary Municipal Assembly meeting room down the
street. A member of the Mayor's staff was posted at
his office to direct attendees to the new location.
Site History
1.
site.
One citizen asked for information concerning the years
that G.E. disposed of contaminated materials at the
Response; G.E. assembled mercury switches and
?,nd-
-------
I
r-
D. The following comments from General Electric were i-ece*ved in
writing during the public comment period.
Comment 1;
The data relied upon does not fully characterize the site.
Specifically, there is a lack of data with respect to air releases,
groundwater conditions and the nature of mercury in the waste.
Response;
Data collected by G.E. during the remedial investigation was
reviewed by EPA for conformance with EPA quality assurance/quality
control protocols. The data was determined to be unusable because
it did not meet EPA specifications. In addition, the groundwater
monitoring wells at the site are insufficient and improperly located.
In August 1988, EPA collected additional samples with the objective
of obtaining data which would be in accordance with EPA guidelines
and representative of the nature and degree of contamination in
the waste-fill materials,, perched water and contaminated near-surface
soils. Groundwater samples were also collected and analyzed from
existing wells to provide some valid data on groundwater conditions
(Because it was recognized the number and placement of monitoring
wells is limited, EPA was aware that this data could not be used to
conclusively demonstrate that no groundwater contamination exists
at the site. However, if positive results were obtained, they
could provide a basis for determining whether leakage had occurred
through the waste-fill area through the underlying strata and
into the aquifer.)
While EPA recognizes that the database is somewhat limited with
respect to air and groundwater sampling, we believe that the data
is sufficient to characterize the nature and extent of contamination
in the waste-fill area and with reasonable interpretation the con-
taminated near-surface soils. The waste-fill area and contaminated
soils may pose unacceptable risks to public health if unremediated.
Rather than delay the remediation of these areas pending additional
study of the groundwater, EPA believes it is more prudent to
address the risks posed by these areas since selection and imple-
mentation of a remedial alternative for these areas is not contingent
upon the results of the groundwater investigation.
In EPA's endangerment assessment an air model was used to calculate
the concentration of mercury in soils and the waste-fill area which
could result in exceeding levels protecive of public health. The
model predicted that a concentration of 16.4 ppm would result in
exceeding health based criteion. The model provides a reasonable
indication of actual field conditions. However, confirmatory air
sampling will be conducted during design to verify the results of
the model since the confirmatory air monitoring will affectd the
- 5 -
-------
volume of contaminated materials which are above health-based
Sd n°te' that each remedial alternative evaluated
F? used the same exact baseline assumptions for
ma^rials tc be remediated. Therefore, any change
<>r selection" of a9
?™~ fesPfct to limited groundwater data, the need for further
investigation is substantiated by, among other things, the
s!e?S S10n ? mercury in one sample of the groundwater above health-
based levels (i.e., the Maximum Contaminant Levels promulgated
dS?nanLt(? the ?afe Drinkin9 Wat®r Act). This work will be conducted
during design. As stated above, the remediation of the waste-fill
area and contaminated soils is not contingent upon the results of
tnis investigation.
In regard to the data defining the nature of mercury in the
wastes, EPA found that the mercury in the perched water, near-
?™aCeJ!01r,Soand> 9roundwater is predominantly in an inorganic
form. The U.S. Bureau of Mines analyzed the plastic portion of
Thl ~f,t;?,.ln.tS? WaS^fi11 3rea for Or9anic forms of mercury
The results indicated low levels of organic mercury in the plastic.
Comment 2:
EPA used air modelling results from its endangerment assessment
for determining cleanup levels. Adequate air monitoring has not
been conducted and therefore the cleanup level has not been defined.
Response
EPA has used the air modelling results in the endangerment assess-
ment as a tool for determining preliminary cleanup levels for the
site, confirmatory air modelling will be conducted during design
to refine this value. Since EPA has demonstrated in its endanger-
£!!?^aSfKSS:neut.that the site may P°se unacceptable risks to public
health through ingestion pathways, confirmatory air sampling
would not negate the need for site remediation. The air sampling,
however, could affect the volume of contaminated material which is
remediated.
Comment 3:
The documents supporting the chosen alternative are by their own
clarification11"11"3^ *" nature and Sub3ect to further change and
clarification.
Response;
EPA encourages public involvement, comment and participation in
the remdy selection process. Accordingly, it is standard Agency
practice to publish draft RI/FS reports and endangerment assess-
ments so that EPA may solicit public input prior to the finali-
- 6 -
-------
zaticn of these documents. For this particular siter these
documents have undergone continued agency review concurrent with
the public comment period. Although the endangerment assessment
has been modified somewhat as a result of this review it continues
to establish a need for site remediation. Specifically, the
modifications have resulted in a reduction of the acceptable
mercury exposure level due to ingestion of contaminated materials
from 38 ppm to 21 ppm. Moreover, for reasons stated above, such
changes do not affect the evaluation or selection of remedial
alternatives.
Comment 4:
"The A[ddendum] FS applied unfounded or improper assumptions
regarding the potential (emphasis added) risk to human health and
environment..." Specifically, "the possibility of leakage through
the clay layer to the groundwater is the basis of rejecting other
alternatives [in particular Alternative 4 which is basically on-
site containment]. Without the data confirming such an assumption,
that conclusion is unsupported."
Response;
EPA's determination that the potential for current and future
groundwater contamination exists is based in part on the work
conducted by G.E. and statements contained in their RI report.
In particular, the RI indicates that the permeability of the clay
layer is in the range of 10~4 - 10~5 cm/sec. EPA considers these
values as demonstrating moderate permeability. (Model RCRA
specification would require a 10"' cm/sec permeability for an
"impervious" liner). In addition, the RI reports that roots were
observed in this unit, which would further facilitate the migration
of mercury through the clay by providing channels for the contam-
ination to flow through, and thus increase the permeability of
the soils. Furthermore, the RI finds low resistivity readings in
portions of the waste-fill area. The report then explains that
these readings may be indicative of a zone of high moisture
content underlying the waste-fill area. The report states that
this moisture could be the result of slow downward migration of
perched water through the silty clay stratum.
Notwithstanding the information provided by G.E., the inability
of the clays underlying the waste-fill area to act as an adequate
barrier to contaminant movement to the groundwater appears to be
evidenced by the detection of mercury in the groundwater.
- 7 -
-------
Comment 5;
EPA selected ARARs used to evaluate the selected alternative which A
were less stringent then those tentatively used to equate the ~
SSSinal alt«fnatives. Specifically, "[w]hen the original FS was
prepard remedies were evaluated based on a tentatively established
level of 4mg/kg mercury in soil. The hydrometallurgical treatment
is being evaluated based on a standard between 16-38 mg/kg of
mercury." "' a
Response;
* ?raft FS Usin9 a tentative level of 4 ppm based
the average background concentrations found in Eastern U.S.
soils and on a qualitative risk assessment performed by its con-
tractor. EPA had not selected either tentatively or definitively
r FPnVaSi-a ?leanu? level- The background documentation used by
™?iv l-ll Jt T1?.^ this.level "ere transmitted to EPA concurr-
ently with the draft FS, subject to Agency review.
" n° fhemi«l-specific ARARs for mercury-contaminated
EPA ?erforn»ed an endangerment assessment to
. determine the levels of mercury which would pose
51Skf to public ^alth. EPA used these health-based
alternaUv' * aS ARARS in the evaluation °« each and every
Comment 6;
p,j (Containment), "was completely supported in the
tb. The addendum FS "has given undue weight to one factor -
treatment of the waste - to reduce toxicity, mobility or
volume as stated in Section 121 (b) of [CJERCLA." —
Response;
One of the deficiencies of the GE draft FS was that it did not
op;i^COnr°rm Wiirh ^he criteria set forth in Section 121 of
CERCLA. in particular, the alternatives were not evaluated with
respect to; long-term effectiveness or permanence; reduction of
toxicity, mobility or volume; and short-term effectiveness. In
addition, due consideration was not given to alternatives which
utilize permanent solutions and alternative treatment technoloqies
or resource recovery technologies to the maximum extent practicable
as directed by CERCLA. Furthermore, CERCLA mandates that remedial
actions in which treatment that permanently and significantly
reduces the volume, toxicity or mobility of a hazardous substance
is a principal element are to be preferred over remedial actions
not involving such treatment. The GE draft FS did not address
evaluation of the alternatives with respect to this preference.
- 8 -
-------
?• »
r-*
EPA believes that Congress* intent is clear with regard to this
issue. We disagree with the assertion that this criterion was
given undue weight to the exclusion of all other criteria.
It is self evident that EPA in the addendum FS fully considered
all of the criteria while giving the prcper preference (as mandated
by law) to remedial actions which involve treatment and which
permanently and significantly reduce the toxicity, mobility or
volume of a hazardous substance.
As stated above, the criterion which involves reduction of
toxicity, mobility or volume was applied to the pertinent alter-
natives (See language and discussion in FS).
Comment 7:
The process proposed by EPA has not been demonstrated as being
viable. Although some processes identified may be practiced in
the extraction industries, no location has been identified where
wastes similar to that at the Site has been successfully processed
on a scale similar to that required at the Site.
Response:
EPA believes that hydrometallurgical treatment is a viable
process. It appears to be implementable based upon laboratory
studies conducted, as well as, other work performed by the U.S.
Bureau of Mines and published literature. As stated above,
aspects of the process are currently and routinely practiced in
the extraction industries. However, EPA recognizes that further
treatability studies are necessary and has committed to conduct
such studies during design. With respect to the concern that no
location has been identified where wastes similar to that at the
Site has been successfully processed on a scale similar to that
required at the Site, Section 121 of CERCLA clearly allows EPA to
select remedial actions with alternative treatment technologies
which meet the objectives of the evaluation criteria, whether or
not such action has been achieved in practice at any other facility
or site that has similar characteristics.
Comment 8: .
The degree of reduction of mercury is highly speculative. All
of the assumptions are based on processing cinnebar ores,
generally containing higher concentrations of mercury. The
wastes found at the site may not pose the same processing issues
as ores.
- 9 -
-------
Response;
Again, Section 121 of CERCLA allows EPA to select remedial
actions with alternative treatment technologies which meet the
objectives of the evaluation criteria, whether or not such
action has been achieved in practice at any other facility or
site that has similar characteristics. EPA is aware that the
wastes found at the site may not pose the same processing issues
as ores which is among the reasons for performing further
treatability studies during design. In addition, the percent
reduction achieved in current industrial extraction processes
should not be used as a basis for determining the upper limits
of the selected treatment alternative. These are commercial
processes where the extraction goals are primarily based on
cost and benefits of further treatment verses value of recoverd
materials. EPA's treatment goals are based on attaining conformance
with the criteria specified in CERLCA. EPA's objective is to select
a remedial action which provides the best balance in terms of
tradeoffs with respect to such criteria. While cost-effectiveness
is a criterion which is considered, it does not necessarily drive
EPA's decision making process.
Comment 9;
The short-term effectiveness has not been addressed with respect
to hydrometallurgical treatment.
Response;
The short-term effectiveness was assessed and short-term impacts
were noted in the addendum FS for each alternative including
hydrometallurgical treatment. This criterion was applied
consistently to each alternative. That is, potential short-term
impacts during implementation were identified for each alternative.
A conservative approach was taken in identifying such potential
impacts. For example, the formation of picric acid is possible
when concentrated nitric acid reacts with phenols in the presence
of sulfates. Although there is nothing in the waste that suggest
that there are high levels of sulfates or sulfite, since the
plastic materials contain phenolic compounds, the potential formation
of picric acid was flagged. Moreover, in laboratory tests the
waste was analyzed using concentrated nitric acid, and picric acid
was not formed. Potential short-term impacts were also addressed
in the same manner for each alternative. That is, EPA believes
that the issues raised can be addressed in the site health and
safety plan for construction. EPA also believes that any short-term
impacts associated with hydrometallurgical treatment can be
addressed through data collected during the treatability studies.
-10 -
-------
Comment 10:
"With all the uncertainties associated with this process
[hydrometallurgical treatment] any cost estimates are at best an
educated guess." "Cost could easily balloon to half again or
more."
Response:
EPA's goal when developing cost estimates for the FS is to achieve
a level of accuracy between + 50% to - 30%. EPA realizes that this
goal may not be pratical for remedial actions which entail excavation
and treatment of wastes. EPA believes that the assumptions made
in the cost estimates are reasonable. However, the cost estimates
will be further refined upon completion of the treatability
studies and subsequent design.
Comment 11:
"The Fixation Alternative was rejected without adequate evaluation.
Although it would meet the necessary requirements for human health
and environmental protection, there appears to be some concern
over its permanence. Some of this is traced back to the erroneous
assumptions that this would be performed in situ." The
resultant material from fixation "has a high degree of permanence
and no specific evidence was presented in the A[ddendum] FS to
the contrary."
Response; .
The evaluation of the degree of long-term effectiveness or permanence
associated with the Fixation Alternative was not solely dependent
upon the difficulties encounted with respect to in-situ treatment
processes. Quality control concerns, such as achieving proper
mixing of the waste, may be addressed by removing the waste for
processing and then returning it to the waste-fill area. And,
these activities may also increase the degree of permanence
associated with this alternative. However, the degree of permanence
is still uncertain. Although acid leaching tests have been
performed on a fixed sample from the waste-fill area, and these
tests give a good indication of the initial short-term effectiveness
of fixation. However, the tests offer no information with respect
to the long-term ability for this alternative to be effective
under a variety of in-situ conditions. Processing the waste
outside of the waste-fill area would still not make the Fixation
alternative a more permanent solution than the chosen alternative,
since wastes would remain on-site above health-based levels.
- 11 -
-------
Comment 12:
o
hHi* ™ ? H ? Alternatives 5, 5a, 6 and 6a were eliminated
based on technical fesibility since the waste is not amenable
to physical separation; this appears to directly contradict Law
Environmental's report of November 1987 which references a
Granulametnc Study Report of November 1986 which indicates
that some physical separation can be achieved by screenino.
EPA provides no supporting documentation for their rejection of
Alternatives 5, 5a, 6 and 6a."
Response:
Because no mass balance was performed, the work conducted bv
Law Environmental with respect to the above-referenced altern-
atives is inconclusive. The data presented in the Bureau of
Mines report demonstrates that some physical separation of the
mercury from the waste materials could be achieved. However
these physical separation methods do not achieve sufficient
S*?*C*i?n-a2d are.thefef°re inefficient and impractical. The
data and information is presented in the Bureau of Mines report
which is an attachment to EPA's addendum FS.
Comment 13:
"EPA does not indicate in their summary that extensive safety
features would need to be designed into a temporary facility
because of the use of hazardous leaching materials, nor do they
state that the leachates would require treatment and disposal
after removal of the mercury."
Response:
The addendum FS does provide for neutralization of the leaching
agent prior to disposal at a POTW. As stated in the addendum
FS, safety concerns will be addressed in the design and health
and safety plan.
Comment 14;
"There is no supporting data to demonstrate that the hazardous
leaching materials (cyanide, nitric acid, or hypochlorite) can
themselves be removed sufficiently that the soil will meet
relevant disposal criteria".
Response:
See response to Comment 7. The remedial action will be designed
to meet relevant disposal criteria.
- 12 -
-------
Comment 15:
"Treatment of perched water is based on an estimated 500,000
gallons already in the area; no allowance appears to be made
for recharge due to nine months percipitation over a 1.16 acre
area, which would amount to an additional 1,140,000 USgal over
the nine month period, assuming 48 inches of percipitation per
year."
Response:
EPA used the same value (i.e., 1/2 million gallons) for the
volume of perched water to be treated when assessing each and
every alternative. The amount of time estimated for implement-
ation of each alternative is sufficiently similar (between 18 to
24 months) and therefore, the incremental amount of perched
water generated should be roughly equivalent. Consequently,
each alternative would be affected in a similar manner if
rainfall increases the volume of perched water to be treated.
Comment 16:
"EPA states that the mercury could be recovered from plastic by
low temperature retorting between 375°C and 850°C, implying
that this is an established process. However, the U.S. Bureau
of Mines letter of August 22, 1988, states only that additional
tests are being run to determine if this could be achieved."
Response:
The first statement in the comment is part of a sentence The
sentence in the addendum FS is explaining the range of possible
temperatures which should be explored to determine the optimal
operating temperature for a thermal treatment process. EPA
does not state or imply that low temperature retorting for this
waste is an established process; this is an inference drawn by
the commentor by taking a statement contained in the addendum
FS out of context.
Comment 17:
"EPA has proposed using cyanide, hypochlorite or nitric acid
to leach mercury from the waste materials and soils based on
the August 22, 1988 letter from the U.S. Bureau of Mines (USBM).
However, the USBM eliminated nitric acid as a leaching medium
because of the hazard of forming potentially explosive nitrated
organic compounds from the phenolic plastics present in the waste*
"Although USBM rejected cyanide as a leaching medium, cyanide
leaching of gold and silver ores is a commercial process '
typically yielding extration efficiencies on finely divided
- 13 -
-------
«ne^ileSVhen J00"*^) °f 95-96%. "The USBM started
on the wastes only (no soils were received for testing)
»i?S?2fi2USd U6 W0rk because the leaching medium was gradual
acidified by the waste, releasing toxic hydrogen cyanide gas.
Response:
did not eli»in«te nitric acid as a leaching
M. — ™* — -..•*-~<~« nor are such statem^nt^n IIIA/^A •!••* 4>v«.
Bureau of Mines report. statements made in the
Comment:
findini:Ladpt0 Consider the Potential problems associated
Alternative 9. ms 9enerate°
Response:
EPA did consider the potential problems associated with
aqueous streams generated --- - - - - - uciatea w*tn
As stated in the Addendum
of Wastewater from CERCLA
must achieve the levels set forth in the pS^'s permits
to
Comment:
EPA failed to consider the proper method of disposal for each
process stream generated with respect to Alternative |°r-each
- 14 -
-------
-~»
Response:
These process streams, as well as their ultimate disposal were
identified in the addendum FS. Hydrometallurgical treatment
consists of leaching mercury from the waste with a leaching
agent. This generates a liquid-sludge stream. This stream is
then filtered. The concentration of mercury in the residual
material (sludge) from the filtering stage is below health-based
levels. The residuals are then rinsed to ensure that all of
the leaching material is removed. The rinsate is treated
on-site, prior to discharge to a POTW. Treatability studies
will determine the design parameters which will ensure that the
residuals will be below health-based levels and not contain
hazardous byproducts from the leaching stage. The residuals
will then be disposed of on site. The liquid stream separated
from the sludge during the filtration stage will then undergo
precipitation/ cementation to remove the mercury. This process
consists of passing the liquid through a material such as
stainless steel, copper, aluminum or zinc. The mercury is then
removed from the solution, and sent to a reclaimer or proper
disposal in accordance with its characteristics. The liquid is
then recycled back to the leaching reactor. When the processing
of all waste is completed the leaching agent is neutralized and
sent to a POTW for disposal.
- 15 -
-------
-------
.
i d>o
o o o
S CD
032
0) O 0^
a« > c
+« 0.0)0
0
3t3
Zo.!S.E
Reproduced by NTIS
National Technical Information Service
Springfield, VA 22161
This report was printed specifically for your order
from nearly 3 million titles available in our collection.
For economy and efficiency, NTIS does not maintain stock of its vast
collection of technical reports. Rather, most documents are printed for
each order. Documents that are not in electronic format are reproduced
from master archival copies and are the best possible reproductions
available. If you have any questions concerning this document or any
order you have placed with NTIS, please call our Customer Service
Department at (703) 605-6050.
About NTIS
NTIS collects scientific, technical, engineering, and business related
information — then organizes, maintains, and disseminates that
information in a variety of formats — from microfiche to online services.
The NTIS collection of nearly 3 million titles includes reports describing
research conducted or sponsored by federal agencies and their
contractors; statistical and business information; U.S. military
publications; multimedia/training products; computer software and
electronic databases developed by federal agencies; training tools; and
technical reports prepared by research organizations worldwide.
Approximately 100,000 new titles are added and indexed into the NTIS
collection annually.
For more information about NTIS products and services, call NTIS
at 1-800-553-NTIS (6847) or (703) 605-6000 and request the free
NTIS Products Catalog, PR-827LPG, or visit the NTIS Web site
http ://www.ntis.gov.
NTIS
Your indispensable resource for government-sponsored
information—U.S. and worldwide
-------
------- |