November 1986 EPA-700/8-87-005
Hazardous Waste Ground-Water
Task Force
Evaluation of
Proteccion Tecnica Ecoiogica (Proteco)
Penuelas, Puerto Rico
3BEPA
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
COMMONWEALTH OF PUERTO RICO ENVIRONMENTAL QUALITY BOARD
Environmental
Quality Board
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUNDWATER TASK FORCE
EPA-700/8-87-005
GROUNDWATER MONITORING EVALUATION
Proteccion Tecnica Ecologica (Proteco)
Penuelas, Puerto Rico
November 1986
Ton H. Moy
Project Coordinator
U.S. Environmenal Protection Agency
Region II
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, IL 60604-3590
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November 14, 1986
Update of the Hazardous Waste Ground-water Task Force
Evaluation of Proteccion Tecnica Ecologica
The United States Environmental Protection Agency's Hazardous Waste
Ground-water Task Force (HWGTF) and the Commonwealth of Puerto Rico Environ-
mental Quality Board (EQB) conducted an evaluation of the compliance
of Proteccion Tecnica Ecologica, Inc. (Proteco) with the interim status
and ground-water monitoring requirements of the Resource Conservation and
Recovery Act (RCRA), as adopted by the Commonwealth of Puerto Rico.
Proteco is one of the 58 facilities to be evaluated by the HWGWTF. The
HWGWTF effort came about in light of concerns over the extent to which
operators of hazardous waste treatment, storage, and disposal facilities
are complying with state and federal ground-water monitoring regulations.
Proteco's on-site field inspection was conducted over a period of
November 14-23, 1985.
A previous evaluation of the ground-water monitoring system at Proteco in
1983 conducted by an EPA contractor and the subsequent sampling inspection
at the facility conducted by the EPA Region II Environmental Services
Division (ESD) in 1984 raised questions regarding possible contamination
of ground water at the site and the adequacy of the interim status ground-water
monitoring system. These inspections resulted in the issuance of a complaint
against the owner/operator of the site for a number of violations of the
interim status requirements. In August 1985, EPA Region II and Proteco
held a settlement conference to address these issues. A Section 3013
Order on consent was issued on October 8, 1985.
The 3013 order required: an evaluation of the geological and hydrogeological
conditions of the facility property sufficient to design an adequate ground-water
monitoring system, development and implementation of ground-water monitoring
and surface water monitoring plans, and sampling and analysis of the soil
surrounding each storage and disposal unit. At the time of the Ground-Water
Task Force visit to Proteco, the company had completed part of the initial
phase of the hydrogeologic investigation. The soil and surface water
assesment had not bpgun.
Subsequent to the Task Force inspection, a Phase 1A Hydrogeologic Work Plan
at Proteco was submitted to the EPA on February 10, 1986. After extensive
meetings with Proteco and the hydrogeologic consultants for the facility,
a revised Phase 1A was submitted to the EPA on April 4, 1986. EPA approved
the Phase 1A work plan in mid-April 1986, and field operations began in
early June 1986 and concluded at the end of September 1986. A final draft
report of the 3013 phased hydrogeological investigation was submitted to
the EPA on September 30, 1986; it is currently under review.
Phased soil sampling work plans were submitted to the EPA between January
and June, 1986. A letter was sent to the facility on October 2, 1986
requesting additional modifications to the plan. If the modifications
are adequate, field work is expected to begin in mid-November, 1986.
In response to the requirement that all ground-water monitoring facilities
certify compliance with the applicable ground-water monitoring requirements
or lose interim status on November 8, 1985, the operator of the Proteco
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-2-
facility certified compliance for two of the regulated land disposal units
and submitted closure plans for the remainder of the land disposal units.
Proteco had previously submitted a Part B application for the facility.
The site investigation conducted in mid-November 1985 revealed a multitude
of violations of RCRA and Commonwealth hazardous waste regulations. The
more serious of them included violations of previous EQB and EPA Orders;
mismanagement of incompatible hazardous wastes; violations of aisle
space; violations of groundwater monitoring requirements; unsafe containers;
violations of closure and post-closure plan requirements; and the unlawful
placing of liquid hazardous wastes into the landfill.
Proteco was notified of these violations by letter dated February 14,
1986, and the regional office decided that judicial enforcement was the
appropriate response. A civil referral was sent to EPA headquarters on
March 31, 1986. The case then was referred to the U.S. Department of
Justice on May 9, 1986. Meetings have been held with Proteco to discuss
settlement of the violations. A complaint was issued on October 29,
1986, asking for a substantial penalty and correction of the violations.
Proteco has submitted to EPA Region II revisions to the closure and
post-closure plans for the waste management units, the training plan,
inspection plan, and the plan to improve the existing container storage
area.
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ACKNOWLEDGEMENTS
It is a pleasure to acknowledge the assistance of the following Task Force
personnel who provided information and technical guidance: Charles Anderson,
Randy Breeden, Joseph Cosentino, Roger Ennis, John Gorman, Fred Haber, and
Andrew Praschak, and the ^CRA employees of the Commonwealth of Puerto Rico
Environmental Quality Board. In addition, we wish to thank the personnel of
Prnteco in assisting us during the period of November 14-23, 1985.
Ton H. Moy
Project Coordinator
U.S. Environmental Protection Agency
Region II
For further information regarding this report please contact:
Hazardous Waste Compliance Branch
U.S. Environmental Protection Agency
Region II
26 Federal Plaza
New York, New York 10278
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Contents
Executive Summary
Introduction 1
Summary of Findings and Conclusion 5
Groundwater Monitoring During Interim Status 6
Audits of Laboratories 6
Groundwater Sampling and Monitoring Procedures 6
Sample & Data Analysis 7
RCRA Inspection 7
Technical Report
Investigation Methods 9
Records/Documents Review 9
Facility Inspection 9
Laboratory Evaluation 10
Ground-water Sampling and Analysis 10
Facility Description 11
General Information 11
Facility Operations 11
SWMUs Identified 13
Ground-Water Monitoring During Interim Status 14
3013 Order 18
Lois Certification 19
Task Force Ground-Water Inspection ..... .... 22
Sampling and Analysis Plan Review 25
Laboratory Audit 29
Timeline of Regulatory Activities Related to Ground-Water
Monitoring at Proteco 33
Regional and Site Specific Geology and Hydrology 40
Regional Hydrogeology 40
Geology of the Juana Diaz Formation 47
Site Hydrogeology 52
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Contents (Continued)
Ground-Water Sampling and Analysis 57
Task Force Sampling Data Analysis 70
Hazardous Waste Treatment, Storage, and Disposal During Interim Status . . 91
Regulatory Requirements 91
State Regulations 91
RCRA Inspection 95
0 Waste Management Units/Observation 95
0 Record Review 100
References
Appendices
A Types of Industries Served by Proteco
B Proposed Closure Summary
C Proposed Closure Schedule
D Work/QA Sampling Plan
E Monitoring Parameters
F Receipt for Samples
G Closure Plan/Cost Estimate for the Waste Management Units
H Liquids in Landfill TI-3
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FIGURES
Figure 1 Site location map 3
Figure 2 1981 RCRA ground-water monitoring system 15
Figure 3 1983 RCRA ground-water monitoring system 17
Figure 4 Present RCRA ground-water monitoring system 20
Figure 5 Location of Puerto Rico in Caribbean Region 41
Figure 6 General geology of Puerto Rico and its offshore islands ... 42
Figure 7 Tallaboa River drainage basin 44
Figure 8 Geologic Map of Tallaboa basin 45
Figure 9 Average annual precipitation, Puerto Rico 48
Figure 10 Average annual rainfall in the Tallaboa basin 49
Figure 11 Mean nonthly rainfall south coast of Puerto Rico 50
Figure 12 Total rainfall during 10/5/86 - 10/6/86 storm event in Puerto
Rico 51
Figure 13 Soil survey map in the vicinity of Proteco facility 54
Figure 14 Location of wells sampled by the Task Force 58
Figure 15 Location of wells sampled in relation to hazardous waste
units 59
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TABLES
Table 1 Well specifications for present RCRA ground-water monitoring
system 21
Table 2 Well construction specifications 61
Table 3 Well head and breathing zone air monitoring data 62
Table 4 Parameter, bottle type and preservative list 66
Table 5 Field measurements 67
Table 6 Sequential order of sample collection 69
Table 7 Results of inorganic analysis on samples collected at
Proteco 73
Table 8 Results of organic analysis on samples collected at Proteco 79
Table 9 Tentatively Identified Compounds 84
Table 10 State and Federal counterpart interim status regulations . . 91
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INTRODUCTION
Concerns have recently been raised about whether commercial hazardous waste
treatment, storage and disposal facilities (TSDFs) are complying with the
ground-water monitoring requirements promulgated under the Resource Conserva-
tion and Recovery Act (RCRA)*. In question is the ability of existing or
proposed ground-water monitoring systems to detect contaminant releases
from waste management units. To evaluate these systems and determine the
current compliance status, the Administrator of the Environmental Protection
Agency (EPA) established a Hazardous Waste Ground-Water Task Force (Task
Force). The Task Force is comprised of personnel from the EPA Office of Solid
Waste and Emergency Responce (OSWER), Natonal Enforcement Investigations
Center (NEIC), Regional offices and State regulatory agencies. The Task
Force is conducting in-depth onsite investigations of commercial TSDFs with
the following objectives:
0 Determine compliance with interim status ground-water monitoring require-
ments of 40 CFR Part 265 as promulgated under RCRA or the State equivalent
(where the State has received RCRA authorization);
0 Evaluate the ground-water monitoring program described in the facility's
RCRA Part B permit application for compliance with 40 CFR §270.14(c);
0 Determine if the ground water at the facility contains hazardus waste
constituents;
o
Provide information to assist the Agency in determining if the TSDF meets
EPA ground-water monitoring requirements for waste management facilities
receiving waste from facilities being remediate pursuant to the Compre-
hensive Environmental Response, Compensation and Liability Act (CERCLA);
Identity significant ground water management, technical and compliance
problems and take enforcement or other administrative actions to correct
these problems.
* Regulations promulgated under RCRA address hazardous waste management
facility operations, including groundwater monitoring, to ensure that
hazardous waste constituents are not released to the environment.
** EPA policy, stated in May 6, 1985 memorandum from Jack McGraw on
"Procedures for Planning and Implementing Off-site Response", requires
that TSFDs receiving CERCLA waste be in compliance with applicable
RCRA groundwater monitoring requirements.
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LOCATION MAP
REFERENCE:
SCALE
4.6
9.2
13.8 MILES
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The unit numbers refer to those used on the facility drawing can be
found under Ground-water Sampling and Analysis.
Proteco certified LOIS compliance with the applicable ground-water
monitoring requirements for two regulated units (units #13 and #16) at
the facility.
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Summary of Findings and Conclusions
The findings and conclusions presented in this report reflect conditions
existing at the facility in November 1985. Relevent actions taken by EPA
Region II, the Commonwealth and Proteco in the period subsequent to this
investigation are included.
Task Force personnel investigated the interim status groundwater monitor-
ing and hazardous waste management programs at the Proteco facility for the
period between November 1980 and November 1985. The investigation indicated
the monitoring and waste management programs were inadequate and did not
comply with the applicable requirements.
The groundwater monitoring program proposed in Proteco's 1983 Part B permit
application and subsequent revisions up to the time of the inspection were
inadequate.
The results of the chemical analyses of groundwater samples collected at
Proteco indicate that the groundwater in the uppermost aquifer is highly
saline and specific conductance values range from 40,000-50,000 micromhos.
Inorganic constituents were detected in the ground water from all 15 wells
sampled, several inorganic constituents including barium and chromium,
exceed federal drinking water standards. However, it is recommended that the
new wells that were installed as part of the 3013 Order be sampled for
inorganic parameters in order to develop a representative data base of
background water chemistry. Organic data from eleven wells was either
non-detect or rejected during the QA/QC process. Four of the wells yielded
samples showing levels of volatile organics. Specific constituents include
chloroform (3.8 -16 micrograms per liter,) bromodichloromethane (2.9-9.5
rnicrograms per liter), and 2-butonone (1100 micrograms per liter). The data
from three of the wells which tested positive for organics is questionable
since these wells were not adequately developed. As a result of QA/QC
considerations, the data collected for semi-volatiles was rejected. A good
portion of the pesticide, PCB, and herbicide data also was discarded due to
QA/QC considerations. Additional sampling for organic constituents is necessary,
After the 3013 hydrogeologic study at the facility is completed and the
hydraulic parameters defined on a site-wide basis, it is recommended that
the remaining data on organic compounds generated by the Task Force be reviewed,
A ground survey was conducted by EPA personnel and no drinking water, irriga-
tion, or stock wells were noted within a mile and one-half radius of the
faci Ii ty.
Under EPA policy, if an off-site TSDF is to be used for land disposal of waste
from a Superfund-cleanup of a CERCLA site, that site must be in compliance
with the applicable technical requirements of RCRA. Interim status facilities
must have an adequate groundwater monitoring system data to detect the release
of hazardous waste or hazardous waste constituents from the regulated units
into the groundwater, and if there is a release, to assess its scope and
extent. The groundwater monitoring program at Proteco is inadequate for this
purpose and, as such, has not complied with Federal and Commonwealth require-
ments.
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Also, in some instances, correct procedures described in the plan were
not carried out in practice. In other instances, incorrect procedures
were described, but correct procedures were being practiced.
EPA Sample Data Analysis
Inorganic constituents detected in Task Force samples include aluminum,
antimony, arsenic, barium, cadmium, calcium, chromium, colbalt, copper,
iron, lead, magnesium, manganese, nickel, potassium, sodium, thallium,
tin, vanadium and zinc. However, no conclusions regarding releases of
of inorganic constituents at the facility can be made at this time
since not only do elevated levels of many of these constituents fre-
quently occur in saline environments, but also the complexity of the
marine depositional environment at the facility, the thirty to fifty
foot sequence of unsaturated clays and the similarity in concentration
of inorganic constituents in many wells throughout the facility require
a more representative site-wide data base of background water chemistry
be developed. It is recommended that the new wells installed at the
facility as part of the 3013 Order be sampled for inorganic parameters
in order to help establish this data base.
Organic data from eleven wells was either non-detected or rejected during
the QA/QC process. Four of the groundwater wells yielded samples showing
levpls of volatile organics. Specific constituents include 2-butanone,
chloroform and bromodichloromethane. QA/QC problems associated with
analysis of for several other volatile organics and semi-volatile compounds,
and the need to specify other tentatively identified compounds, require that
further sampling at the facility be conducted. In addition, after the 3ul3
hydrogeologic study of the facility is completed and the hydraulic parameters
defined on a site-wide basis, it is recommended that the data on oryanic
compounds generated by the Task Force be reevaluated.
RCRA Inspection
Observation of current waste management practices and review of records
maintained at Proteco have identified numerous deficiencies. These
included: inadequate waste analysis plan, failure to conduct waste
analysis, inspection schedule, training program, fire control equipments,
communication system, aisle space, written contingency plan, groundwater
monitoring system, closure/post closure plans, run-on and run-off control in
waste management units, unlined impoundments, and placing of hazardous liquid
wastes in landfill. Prior to the inspection, two methods were used to treat
the hazardous wastes accepted to render the wastes less hazardous, non-hazard-
ous, or more amendable to disposal. The primary method used was stabilization/
fixation. This treatment procedure renders a waste to a concrete-like solid
material by reacting cement kiln dust, water, and waste to form a solid. This
solid was then disposed of in one of the on-site landfills. The facility also
employed neutralization processes to adjust the pH of a waste to an acceptable
level by combining acidic and alkaline materials.
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TECHNICAL REPORT
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INVESTIGATION METHODS
The Task Force investigation of the Proteco facility consisted of:
0 Reviewing and evaluating records and documents from EPA Region II,
Environmental Quality Board and Proteco;
0 Conducting an onsite facility inspection November 14 through
November 23, 1985;
0 Evaluating onsite and offsite analytical laboratories; and
0 Sampling and analyzing data from selected ground-water monitoring
wells.
RECORDS/DOCUMENTS REVIEW
Records and documents from EPA Region II and the EQB office, compiled
by an EPA contractor, were reviewed prior to and during the onsite inspection.
Additional EQB records were copied and reviewed by Task Force personnel con-
currently with the onsite inspection. Onsite facility records were reviewed
to verify informationcurrenly in Government files and supplement Government
information where necessary. Selected documents requiring in-depth evaluation
were copied by the Task Force during the inspection. Records were reviewed
to obtain information on facility operations, construction details of waste
management units and the ground-water monitoring program.
Specific documents and records that were reviewed included the ground-
water sampling and analysis plan(s), outline of the facility ground-water
sampling, monitoring well construction data and logs, site geologic reports,
site operations plans, facility permits, waste management unit design and
operation reports, selected personnel position descriptions and qualifications
and operating records showing the general types, quantities and locations
of wastes disposed of at the facility.
FACILITY INSPECTION
The facility inspection conducted in November 1985 included identifying
waste management units (past and present), waste management operations,
pollution control practices, and surface drainage routes, and verifying the
location of ground-water monitoring wells.
Company representatives were interviewed to identify records and documents
of interest, discuss the contents of the documents, and explain (1) facility
operations (past and present), (2) site hydrogeology, (3) the ground-water
monitoring system, (4) the ground-water sampling and analysis plan, and
(5) laboratory procedures for obtaining data on ground-water quality. Because
ground-water samples were analyzed by offsite laboratories, personnel from
these facilities were also interviewed regarding sample handling, analysis and
document control.
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11
FACILITY DESCRIPTION
A. General Information
Proteccion Tecnica Ecologica (Proteco), Inc. formerly known as
Servicios Carbareon, Inc. operates the facility located at
approximately 18°01'05" latitude and 66°41'03" longitude on the
Southern Coast of Puerto Rico near the City of Ponce. The
operating company Proteco is owned by Resource Management, Inc.
Facility Address: Proteccion Tecnica Ecologica, Inc.
Road 385, Km 3.5
Penuelas, Puerto Rico 00724
Mailing Address: Proteccion Tecnica Ecologica, Inc.
Fi rm Deli very
Ponce, Puerto Rico 00731
Telephone Number: (809) 836-2058
RCRA Contact: Dr. Jorge J. Fernandez
President
Facility Owner: Compania Ganadera Del Sur, Inc.
Facility I.D. Numbere: PRO 091 018 622
Type of Operation: Treatment, storage, disposal, transportation
and generation of hazardous and nonhazard-
ous waste.
B. Description of Facility Operations
A general description of the facility operations will be given here.
A more detailed descripton of each waste management unit can be found
under RCRA Inspection.
The Proteco site occupies approximatly 35 acres in a small valley
with high topographical relief at an elevation ranging between 260
and 400 feet above sea level. The facility is located about 2.5
miles southeast of Penuelas, Puerto Rico, 2 miles north of Tallaboa
Bay in the Caribbean, and 1.5 miles east of the lower Tallaboa River
valley. Surface runofff leaves the site in a small drainage ditch
that travels towards the lower Tallaboa River valley.
The activities conducted at the Proteco hazardous waste management facility
include the treatment, storage and disposal of hazardous waste and the
treatment and disposal of non-hazardous waste. The hazardous wastes
received and accepted at the facility are generated from many diverse
manufacturing operations located in the Commonwealth of Puerto Rico. The
hazardous waste is transported from these generators to the facility
primarily by the Proteco transportation staff. Appendix A lists many of
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13
13 Rainwater Basin (LB)
15 Tank Storage
15A Tank Storage Area
16 Immobilization Facility (Tl 3)
17 Neutralization Impoundments (LF)
19 Temporary Drum Storage Area
C. Solid Waste Management Units (SWNUs) Identified
Solid waste management unit includes any discernable waste management
unit from which hazardous constituents may migrate, irrespective of
whether the unit was intended for the management of solid or hazardous
wastes. The following types of units are therefore included in the
definition of SWMUs: landfills, surface impoundments, waste piles,
land treatment units, incinerators, injection wells, tanks (including
90 day accumulation tanks), container storage areas and transfer
stations. In addition to these types of units, certain areas associ-
ated with production processes at facilities which have become con-
taminated as a result of routine, systematic and deliberate releases
of wastes, or hazardoius constituents from wastes, are also considered
to be solid waste management units. A product may become a waste if
it is abandoned or discarded.
The classification of units (i.e., regulated or SWMUs) was based on
the dates these units became inactive, as provided by Proteco. How-
ever, no documentation was available to verify these dates. The SWMUs
identified at this site include:
Unit Number Description
1 Drum Burial Landfill (Cavidad 1C)
?. Drum Burial Landfill (G.E.)
3 Drum Burial Landfill (Roche)
5 Drum Burial Landfill (Searle)
6 Sanitary Landfill (SL)
8 Drum Burial Landfill (Loctite)
14 Land Treatment Area (AC2)
Empty Drum Storage Area
Parking Lot/Shop/Office Area
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14
Ground-Water Monitoring During Interim Status
The RCRA ground-water monitoring system at the Proteco facility has evolved
gradually from 1981 as a result of a series of hydrogeological studies at the
site.
Preliminary soil sampling was conducted at the site as early as 1976 by Jaca
Sierra Rivera Testing Laboratories; however, the first major hydrogeological
investigation of the site was conducted by Geraghty and Miller, Inc., in 1980-
1981. A series of 10 borings were drilled and a RCRA ground-water monitoring
system consisting of 2 shallow wells and 2 deep wells was developed (see
Figure 2 ).
Ertec Atlantic, Inc., (an EPA contractor) conducted a site inspection
and technical review of the facility on January 23, 1983 in order to assess
the facility's ground-water monitoring program for compliance with thp
requirements of Subpart F -- Ground-Water Monitoring (40 CFR 265.90 - 265.94) --
of the Resource Conservation and Recovery Act (RCRA). A summary of the
deficiencies noted by Ertec in 1983 is listed below:
1. 265.91(a)(l) The presumed upgradient well 4W has not been shown to be
either upgradient or capable of yielding ground-water
samples that are representative of background ground-water
quality unaffected by the facility.
2. 265.91(a)(2) The number and location of downgradient monitoring wells
1W, 2W and 9W do not ensure that they are capable of
immediately detecting any statistically significant amounts of
hazardous waste or hazardous waste consitituents that migrate
from the waste-management area to the uppermost aquifer.
3. 265.92(a)(l) Sample collection procedures are not adequately described in
the sampling and analysis plan.
4. 265.92(a)(2) The sampling and analysis plan does not include the
techniques and procedures to be used for sample preservation
and shipment.
5. 265.92(a)(3) Analytical procedures are not addressed in the sampling and
analysis plan.
6. 265.92(c)(2) Four replicate measurements were not obtained for each of the
indicator parameters listed in 265.92(b)(3) for each sample
taken from the presumed upgradient well.
7. 265.92(e) Ground-water elevations at each monitoring well were not
determined each time a sample was taken.
8. 265.93(a) An outline of a ground-water quality assessment program has
not been prepared.
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Figure 2 1981 RCRA ground-water monitoring system.
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16
9. 265.94(a)(l) Records were not kept of the analyses required in 265.92(c)
and the associated ground-water surface elevations required
in 265.92(e).
10. 265.94(a)(2)(i) Concentrations or values of the parameters listed in
265.92(b)(l) for each ground-water monitoring well were
not submitted to the Regional Administrator within 15 days
after completion of each quarterly analysis.
In 1982-1983 Geraghty and Miller, Inc., in conjunction with Mario Soriano,
Proteco hydrogeologist, conducted an expanded hydrogeologic investigation and
monitoring well installation program. Eleven shallow and deep borings were
drilled during this phase of the study. A RCRA monitoring well system consisting
of 4 deep wells, two of which were part of the original RCRA monitoring system,
was developed and incorporated in the 1983 Part B submittal (see Figure 3 ).
This system resulted in a different approach to monitoring ground water at
the facility, although in each case the concept of monitoring the facility
as one large waste management area was maintained. Results from the drilling
program indicated that the shallow water zone was discontinuous; therefore the
company designated the deeper water zone as the uppermost aquifer and discontin-
ued monitoring the shallow zone. A deep well (11W) was designated as an up-
gradient well and an additional well (12W) was designated as a downgradient
well.
The 1983 well monitoring system and sampling program was reviewed by ERTEC
and an NOD was issued to the company in June, 1984.
The technical NOD addressed several of the 270.14(c) requirements which
are applicable to facilities during interim status. In addition, many of
the requirements for 264 ground-water permits should have been addressed by a
facility during interim status. Many of the deficiencies indicated in the
Ertec interim status review mentioned earlier had not been corrected in the
Part B (1983) submittal. These include: the failure of the facility to
produce data proving that the upgradient well is located upgradient of the
units which require ground water monitoring, the failure of the facility to
correct the inadequacies in the sampling and analysis plan, etc. Specifically,
the 270.14(c) deficiencies include:
the location and
(1) 270.14(c)(l) The failure to provide a map indicating
identification of each monitoring well.
(2) The failure to submit a description of the design and
construction of each well (e.g., depths of screen and
casing, depths at which water was encountered, boring
logs, etc.).
(3) 270.14(c)(2) The failure of Proteco to describe the hydraulic
properties (e.g., hydraulic gradients, ground-water flow
rate and direction) of the uppermost aquifer and to
provide supporting data used to identify this information,
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Figure 3 1983 RCRA ground-water monitoring system.
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18
On March 21-22, 1984, the Region II Environmental Services Division (ESD)
conducted a sampling survey at Proteco. ESD staff were accompanied by
EQB personnel. The survey was conducted at the request of the Region II
Solid Waste Branch in order to verify site conditions, ground-water monitoring
data and unit closures. The areas of concern included a waste oil lagoon,
a non-hazardous waste landfarm, a lindane storage tank area and the ground-
water monitoring wells.
The Ocotober 11, 1984, ESD report on this sampling effort states:
The results indicate significant metals contamination
of the soil in the drum storage area and significant
organics contamination in the oil lagoon and non-hazard-
ous landfarm. The designated RCRA monitoring wells were
relatively free of organics contamination. However, well
depths and locations in light of hydrogeologic conditions
at the site make this data questionable at best.
3013 ORDER
Ertec's review of the ground-water monitoring system at Proteco and the
ESD sampling inspection at the facility raised significant questions
regarding possible contamination at the site and the adequacy of the
interim status well detection system. Environmental issues included the
following areas:
(1) Five drum burial areas and 3 immobilization facilities were constructed
without any synthetic or compacted natural material.
(2) Three unlined surface impoundments were constructed without any synthetic
or compacted natural materials.
(3) ESD soil sampling at a hazardous waste storage area for 55 gallon drums
indicated both organic and metal hazardous wastes.
(4) The EPA evaluation of the ground-water monitoring system installed
by Prnteco concluded that the system was not capable of detecting migration
of hazardous waste constituents, as required by Subpart F of 40 CFR Part
265.
(5) Surface water at the facility discharges into a drainage channel which
ultimately enters the lower Tallaboa River basin.
In August, 1985, the USEPA and the Proteco facility held a settlement
conference to address these issues. A formal agreement was reached on
October 8, 1985, when a 3013 Order was signed by the Regional Administrator.
The 3013 was designed to provide a multiphased approach for the assessment
of ground water, surface water, and soils at the Proteco facility. Work
plans were to be submitted to the EPA for approval prior to implementation,
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Figure 4 Present RCRA ground-water monitoring system.
rsj
o
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TABLE 1
RtSULATEO UNIT MONITORING HELL SPECIFICATIONS
WELL NO.
MONITORED StMVEVEU ELEVATION (FT)
UNIT TOP Of CASING TOTAL DEPTH
HELL
SCREENED SCREEN SCREEN SLOT DIAMETER CASING
INTERVAL (FT.) LENGTH (FT.) SHE (IN.) (INSIDE) MATERIAL
18W-85
23W-8S
30U-8S
26W-45
28u-as
29M-8S
22V-85
iMMOtUutlon
Unit TI3
iMoblltmton
Unit TI3
iMoblltmlOn
Unit TIj
RalMMUr Lagoon
lUtnwttar Lagoon
R«lMMt«r Lagoon
R*1iw»t«r Ltooon
and TI3
271.71
27i.o7
279. M
2M.83
297.33
IM.M
304.07
S9.6
39.0
54.0
69.0
74.0
33.8
SS.O
49. S to S9.S
29.0 to 39.0
44.0 to S4.0
S9.0 to 69.0
64.0 to 74.0
23.8 to 33.8
45.0 to 55.0
10
10
10
10
10
10
10
0.01
0.01
0.01
0.01
0.01
0.01
0.01
2 In.
2 In.
2 In.
2 In.
2 in.
2 In.
2 In.
PVC
Toflon
Teflon
Toflon
PVC
Ttflon
PVC
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23
1. Monitoring wells installed hydraulically upgradient from the
limit the waste of management area. Their number, location,
and depth must be sufficient to yield ground-water samples
that are:
a. Representative of background ground-water quality in the
uppermost aquifer near the facility; and
b. Not affected by the facility.
2. Not less than three (3) monitoring wells installed hydraulically
downgradient at the limit of the waste disposal area. Their
number, location, and depth must insure that they immediately
detect any statistically significant amounts of hazardous
solid waste constituents that migrate form the area into the
uppermost aquifer.
Although Proteco certified LOIS compliance for the rainwater basin (unit #13]
and immobilization basin (unit #16) on November 8, 1985, there was no
groundwater monitoring system associated with the following units which
previously had interim status.
1) Neutralization Impoundment (LC)
2) Oil Lagoon (LA)
3) Immobilization Facility (TI 1)
4) Immobilization Facility (TI 2)
5) Neutralization Impoundment (LF)
6) Land Treatment Area (AC 1)
Rule 804(D) of RCHNSW requires:
D. Ground-Water Quality Assessment Program.
1. Within one (1) year after the effective date of this regulation,
the owner or operator must prepare and submit to the Board for its
approval an outline of a more comprehensive ground-water quality
assessment program than tht described above in Sections A, B, and C.
The more comprehensive program must be capable of determining:
a. Whether hazardous solid waste or its constituents
have entered the ground water;
b. The rate and extent of migration of hazardous solid
waste or its constituents in the ground water; and
c. The concentrations of hazardous solid waste or its
constituents in the ground water.
At the time of the Task Force inspection, the ground-water quality assess-
ment program outline had not been submitted to the EPA. A civil referral
addressing the above ground-water violations is presently pending.
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25
Sampling and Analysis Plan Review
The Sampling and Analysis Plan, dated November 11, 1985, was reviewed for
compliance with 40 CFR § 265.92. Detailed below are the deficiencies of
the plan.
Some of the information contained in the plan appears not to correlate to
actual practice, as noted below.
1. Pages 9 and 10 provide the ground water monitoring parameter list speci-
fically tailored for each of the two regulated units. The list provided
for each unit does not include all of the parameters required under
§ 265.92. For example, Total Organic Halogen (TOX), pesticides, trace
metals, and parameters establishing ground water quality are missing
fron one of the lists; TOX, pesticides, and parameters establishing
ground water quality are missing from the other unit's list.
It should be noted that additional parameters, not specifically required
under § 265.92, are included in both lists. It also should be noted that
past versions of the plan observed by us did include all of the parameters
required under § 265.92 and visits to the laboratories contracted to per-
form the analyses disclosed that all of the 265.92 parameters apparently
were being analyzed at least in the past. Consequently, either the
current plan is inaccurate as to its description of actual practice and
the facility is in compliance regarding actual practice, or the plan is
accurate, practice has changed, and interim status requirements are not
being followed accurately.
2. Table 2 on page 11 presents sample preservation and container requirements,
The following inadequacies exist with respect to at least the details
provided in the table.
a. The use of plastic or glass containers is listed for fluoride; EPA
requires the use of plastic containers for fluoride work.
b. The use of plastic or glass containers is listed for lindane and
glass containers is listed for total organic carbon (TOC); EPA
requires the use of glass containers with Teflon caps for lindane,
all other pesticides, and TOC work.
c. The use of glass containers is listed for volatile organics. The
Agency requires the use of glass containers with Teflon lined septums
for volatile organics.
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27
Additionally, Table 4 on page 27 lists the EPA manual, "Methods for Chemical
Analysis of Water and Wastes", EPA-600/4-79-020, March 1983, for the analysis
of the listed parameters. Based on information obtained during laboratory
audits performed in November 1985, the methods contained in this document
are not the ones being used in most cases (an evaluation of the methods
being used is included in the laboratory audit report). Again, the plan
needs to be based on fact.
8. Page 34 describes the process of background value establishment and of
detection of increases in background. It states that four replicate
samples will be collected and analyzed for each listed parameter in order
to account for any variations resulting from analytical procedures. This
statement is incorrect technically in that analyzing four replicate
samples also accounts for any variations in data resulting from problems
with sample reproducibility and representativeness. It should be noted
that, for some purposes, analysis of four replicate samples is a better
approach from a quality assurance perspective.
§ 265.92(c)(2) interim status regulation says that four replicate measure
ments must be obtained for each sample, rather than, as stated in the plan,
obtaining a measurement on each of four replicate samples. Consequently,
based on interim status regulation, the procedure described in the plan is
incorrect. However, again it is our understanding that the plan is inaccu-
rate in that, at least in the past, the correct procedure has been used.
9. The plan does not provide any details of the facility's and facility con-
tractors' quality assurance/quality control program(s) for sampling and
analytical activities. At a minimum, information needs to be provided
regardi ng:
a. QA organization and responsibilities;
b. procedures used to assess the completeness of data;
c. procedures used to assess the precision, accuracy, and overall
reliability of data, e.g., frequency and types of spikes, the use
of surrogates, duplicates (field and lab), frequency and types of
blanks (e.g., laboratory glassware, sample container, trip, equip-
ment, etc.), internal and external performance evaluation samples,
and systems audits;
d. calibration and quantification procedures;
e. data validation and corrective action procedures;
f. preventive maintenance of instruments and equipment;
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29
Audits of Laboratories Used by Proteco
As part of the HWGWTF's inspection of Proteco, audits were performed of two
analytical laboratories: Envirolabs, Incorporated, and Orlando Laboratories,
Incorporated. Envirolab, located in Ponce, Puerto Rico, recently has been
the primary contract laboratory used by Proteco. Orlando Laboratories, located
in Orlando, Florida, is a subcontractor performing certain analytical work
contracted to Envirolab by Proteco. These audits were performed in order
to determine the reliability of the analytical work currently being performed
as part of Proteco's ground water monitoring program.
The audits covered drinking water suitability parameters (arsenic, barium,
cadmium, chromium, lead, mercury, selenium, silver, fluoride, nitrate, endrin,
lindane, methoxychlor, toxaphene, 2,4-D, and 2,4,5-TP); parameters establishing
ground water quality (chloride, iron, manganese, phenols, sodium, sulfate);
and parameters used as indicators of ground water contamination (pH, specific
conductance, total organic carbon (TOC), total organic halogen (TOX). Total
coliform determinations also were evaluated.
Envirolab has been performing analysis of metals, pH, specific conductance,
parameters establishing ground water quality, and total coliform. Orlando
Laboratories has been performing analysis of TOC, pesticides (endrin, lindane,
methoxychlor, toxaphene), and herbicides (2,4-D and 2,4,5-TP). It should be
noted that in conversation with personnel from both of these laboratories
prior to the audits, it was explained to us that Orlando Laboratories
currently was performing TOX analysis. However, we discovered during the
audits that TOX analysis most recently has been contracted out by Orlando
Laboratories to Herman's Engineering, Alabama.
We did not perform an audit of Herman's Engineering. However, the reliability
of their work will need to be determined if they continue to perform TOX
analyses on well samples from Proteco.
It is important to note that various laboratories apparently have performed
and will perform TOX and other analyses on well samples from Proteco. Deter-
mining statistically significant increases in parameter concentrations is
difficult enough using results from a single laboratory. Using a variety of
laboratories, and thus various operations and adaptations of methods, signifi-
cantly increases further the variability of measurements and the difficulty
of making valid statistical comparisons.
The regulated facility, Proteco, is responsible for ensuring that such control-
lable factors be controlled. This includes ensuring that laboratories under
contract know exactly what is required of them.
Envi rolab
Inadequacies were found in general quality assurance/quality control (QA/QC)
practices, and specific analytical methods and operations. Regarding QA/QC,
a written quality assurance plan does not exist for this facility. Many cred-
itable QA/QC activities are performed and lines of responsibility of personnel
apparently are well established. However, certain basic QC processes have
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31
Regarding analytical methods for all other parameters analyzed by Envirolab,
appropriate methods are being used. However, matrix spikes are not routinely
performed. The routine use of matrix spikes is recommended to further ensure the
reliability of data.
Regarding the field measurements of pH and specific conductance, up to the
time of our inspection these measurements were not being performed in the
field. They were being performed at Envirolab, within six hours of collection.
This is not acceptable. EPA policy is that these measurements be made in the
field, immediately at the time of collection. It was explained to us that all
future measurements would be made in the field, at the time of collection.
Additionally, the instrument used for measuring specific conductance does not
compensate for temperature, and corrections were not made for temperature.
It should be noted that temperature was not recorded at the time of measurement
for at least half of the measurement data observed by us. Consequently, much
of the data cannot be corrected subsequently.
Performance evaluation (PE) samples for all of the parameters of interest,
including pH and specific conductance, are analyzed every six months. Some,
but not all, of the results for 1985 were provided to us. Results were not
provided for arsenic, mercury, and selenium. Results provided indicate possible
problems with the accuracy of barium analysis. (It should be noted that the
results of PE analyses are meant to be an indication of the potential reliability
of a facility's basic operations. They do not give any indication of a labora-
tory's ability to deal with matrix problems. They also do not provide, at
least in this case, an indication of the facility's ability to achieve desired
detection limits.)
Orlando Laboratories
This facility has a quality control manual which covers all sampling and analy-
tical activities. The facility also has a recently established full-time
quality assurance officer.
The laboratory is certified by the State of Florida's Department of Health
and Rehabilitation Services for the pesticide and herbicide analyses of
interest and State Department of Environmental Regulation for TOC analysis.
However, in recent years these certifications have been based solely on re-
sults of performance evaluation samples.
Regarding general laboratory practice, certain inadequacies exist in that
samples and analytical reagents are stored in a refrigerator without a thermo-
meter. Working standards apparently are not always dated. Documpntation of
quality control data is lacking in some areas. Certain standard operating
procedures are not complete. However, many good quality control activities are
performed, and the laboratory currently is in the process of upgrading its
overall quality assurance proyram.
Regarding analytical methods, the pesticide and herbicide analyses are per-
formed by incomplete versions of EPA Method 608 and Method 509b from "Standard
Methods for the Examination of Water and Wastewater", 15th Edition, respectively.
The variations from these EPA approved methods apparently are due to the fact
that they are set up by Orlando Laboratories as screening methods. The screening
is based on a one point rather than five point calibration. The screening pro-
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33
Timeline of Regulatory Activities Related to
Ground-Water Monitoring at Proteco
*SCI (Servicios Carbareon) Inc.) = Proteco
EPA's/EQB's Actions
Proteco's Actions
1978
October - EQB requests from SCI
water table determina-
tions at trenches and
surface impoundments.
1979
February - EQB performs site
i nspection and deter-
mines that wells are
insufficient in number
and not properly located.
August - EQB sends SCI comments on
Environmental Impact
Statement (EIS) submitted
by SCI on July 12th, 1979.
EQB requests information on;
- groundwater quality
- water table contour map
- map of boring and
monitoring well locations
February - SCI subnits information
on water table to EQB.
They drilled two (2)
thirty (30) foot wells.
- SCI submits field pro-
cedures utilized for
dri1ling the two (2)
wells.
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35
June - EQB requests from SCI a
visual inspection plan for
the groundwater and surface
water monitoring system dur-
ing the active life and post-
clsoure care period of the
facility.
August -
EQB requests from the
Planning Board the visual
inspection plan originally
requested from the SCI
i n June.
November - EQB evaluates the Com-
pliance Plan sent by
SCI on October 28th,
1980. Deficiencies
are found in the offi-
cial monitoring system.
11/11/80 facility
quali fies for interim
status.
December - EQB sends notification to
SCI of the evaluation of
the Compli ance PI an.
- EQB issues report on
inspection. Included
in the report are the
comments from the
November 7th evaluation
September - 9/11/80 facility noti-
fies EPA that it is a
TSD.
1981
February - EQB inspects SCI.
SCI does not have
results from the well
sampling program.
January - SCI submits Compliance
Plan including the
official monitoring
system with an effective
date of February 19th,
1981.
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37
May - Internal EQB memorandum states
the need to install liner
system and a leachate collec-
tion system under all the sur-
face impoundments and the
need to install new upgrad-
ient wells.
- EQB sends comments to SCI
about the Compliance Plan.
EQB recommends the placement
of a liner and leachate
collection system under all
the surface impoundments.
1983
January - Ertec(EPA contractor) site
vi sit to faci1ity to
evaluate groundwater monit-
oring system.
February - EQB performs site
inspection at SCI and
finds that they are
drilling thei r last
well for the hydrogeo-
logic study.
March - EQB's Ruling Board approves
a motion not to make any
deci sion unti1 a fi nal
determination is made with
respect to the hydrogeo-
logist study.
April - EQB sends NOD to SCI about
Compliance Plan inadequacies.
The groundwater monitoring
system issue is left pend-
ing until latest hydrogeo-
logic study is submitted
and evaluated.
- At a meeting with EQB and
SCI, Ertec Atlanta states
that the groundwater moni-
toring system does not
comply with federal and
state regulations.
-------
August - Settlement conference
on 3013.
October - EQB evaluates SCI
Monitoring Well Construc-
tion Specifications
document. EPA signs 3013,
November - 11/8 facility files
LOIS certification
- 11/11-11/24, Groundwater
Task Force site investi-
gation.
39
April - SCI sends EQB Phase A of
its hydrogeologic study
work plan for evaluation.
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40
REGIONAL AND SITE SPECIFIC GEOLOGY AND HYDROLOGY
Regional Hydrogeology
Puerto Rico is the smallest and most easterly of the islands which form
the Greater Antilles, and it is part of the Greater Antilles Geologic Province
(see Figure 5__). The structural evolution of Puerto Rico is associated with
plate tectonics, and the island is part of the West Indies Island Arc system.
The Puerto Rico Trench lies approximately 150 kilometers north of the island;
the Atlantic Ocean reaches its maximum depth of 8,516 meters at this location.
Some time after the middle Tertiary, Puerto Rico was separated by block faulting
from the other islands of the Greater Antilles, and it was arched, uplifted
and tilted to the northeast. Culebra, Vieques and the Virgin Islands are part
of the Puerto Rican block, and they are separated from the main island because
of the drowning that resulted from the tilting.
Figure 6 is a geologic map of Puerto Rico. The complex central (east-
west axis) core of the island is flanked on the north and south by Oligocene
and Miocene clastic sediments and limestones. The central core consists
primarily of late Cretaceous and early Tertiary volcanic and intrusive rocks.
The volcanic rocks include submarine volcanic ash deposits interspersed with
lava flows, and they are intruded by a number of masses of plutonic rock.
These rocks have been folded and intensively faulted into hundreds of fault
blocks (Cox $ Briggs, 1978). Outcrops of serpentinite are present in western
Puerto Rico.
The northern carbonates consist primarily of marine limestones, marls and
claystone; they dip gently northward and have an east-west extent of 120
kilometers, and a maximum north-south width of 21 kilometers. The Northern
carbonates have undergone extensive solutioning which has produced a juvenile
karst topography in the northwest and mature karst topography in the northeast.
The south coast carbonates have a maximum extent of 40 kilometers east to west
and are up to 8 kilometers in width.
The south coast carbonates have undergone more structural disturbance than the
northern carbonates, and they are are moderately faulted and dip seaward at a
greater angle than those on the northern flank. The Juana Diaz Formation,
which forms a part of the south coast carbonates, will be examined in detail
in a subsequent section of this report. Extensive Quarternary alluvial deposits
are located on the southern coast.
The divide of the east-west trending Central Cordillera mountain chain is
approximately one-third closer to the south coast than the north coast, and
the river courses which flow to the south therefore have steeper gradients
and greater energy. This has resulted in a series of coalescing alluvial
fans of poorly sorted clastic debris which form a coastal plain between
Ponce and Guayama that reaches an average north/south width of approximately
five kilometers. The coastal deposits form the major aquifer of southern
Puerto Rico and much of the water is used for irrigation. West of Ponce,
the coast is characterised by Tertiary limestone deposits and a series of
alluvial valleys cut into the Tertiary limestone. One of these major
alluvial valleys forms part of the Tallaboa River drainage basin, and since
the Proteco facility is located in a small sub-catchment of this drainage,
the Tallaboa River drainage basin will be examined in some detail.
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7!T
25V
GULF
OF
MEXICO
i
f
\
V
\
V/
ATLANTIC
OCEAN
TOO 4UO 6JO O.OMETERS-
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42
gfej
ATLANTIC OCEAN
oues
EXPLANATION
UaeoftsoKdottd
U tfhnriel dtpotits } QUXTCKMARY
STOmAur
^^
^^Nfi"
TCRTURY
-,r-
Strptffttet 3 OtETACCOUS?
:ous
tt
Figu--c o General geology of Puerto Rico and its offshore islands
(from Gomez and Heisel, 1980).
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43
The Tallaboa River drainage basin (with the approximate boundaries of the
Proteco sub-catchment area delineated) is included as Figure 7 The
drainage basin has an area of 31.0 square miles. The Rio Tallaboa and
its main tributary, the Rio Guyanes, originate on the southern slopes
of the Cordillera Central. North of the town of Penuelas, the Rio
Tallaboa and Rio Guyanes are perennial streams, and they flow in steep,
narrow valleys with relatively thin veneers of alluvium. Just south
of Penuelas, the Rio Tallaboa and the Rio Guyanes join at a point where
the valley floor decreases in slope and begins to widen. The Tallaboa
Valley is the major geomorphological feature in the basin.
A geologic map of the Tallaboa basin is included as Figure 8 As
indicated previously, the headwaters of the Tallaboa River originate in the
volcanic complex of the Central Cordillera. Stream sediments in the valley
include detrital material from the igneous central core and lesser amounts of
transported material from the Ponce Formation and Juana Diaz Formation which
flank the valley walls along much of the main valley. The Ponce Limestone is
a pale orange to grayish orange crystalline calcarenite. It is of Miocene
age and rests unconformably on the Juana Diaz Formation in much of the area.
It is believed to have a thickness of up to 850 meters near the southwestern
corner of the Penuelas quadrangle (Monroe and Krushensky, 1978).
The Tallaboa Valley has been developed primarily by erosion of the relatively
soft beds of the south coastal carbonate sequence. The valley width ranges
from approximately 300 meters near the neck in the valley to over 1400 meters
just north of Highway 2; below Highway 2 the valley broadens to over 6UOO meters
near the coast. The Tallaboa River has built a prograding delta into Tallaboa
Bay. The longshore currents along the south coast are from the east-southeast,
and much of the sediment deposited in the bay has been transported along the
coast and is forming a distinctive spit (see Figure 8 ) which separates
Tallaboa Bay from Guayanilla Bay. The Tallaboa River has shifted its course
over time, widening its valley and forming a complex series of lenticular stream
bed and flood plain deposits. As the carrying load of the stream decreases on
its path from the Cordillera Central to the Tallaboa Bay, there is a concomitant
decrease in detrital particle size along the valley. Grossman et al (1972)
examined well logs in the valley and estimated alluvial thickness to range from
approximately 12 meters near the neck of the valley to over 60 meters near the
shore.
The alluvium represents the major aquifer in the region. Grossman et al (1972)
examined the aquifer characteristics as part of a United States Geological
Survey study of ground water along the south coast of Puerto Rico. Transmissivity
estimates based on 4 well tests were approximately 300,000 gpd/ft; cross
sectional flow was estimated at 2.5 million gallons per day during a wet period
and 1.2 million gallons per day during a dry period. Well yields in the valley
ranged from 2.5 to 2500 gpm. Wells south of Highway 2 tended to yield low
quantities of water due to a predominance of silt and clay in the alluvium.
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44
Figure 7 Tallaboa River drainage basin (modified from Grossman et al, 1972),
-------
45
J.ta.
UMCSTONE
OIAZ ^DKMATION
VOtCAMIC
OMDlFFflUNTIALED
Figure 8 Geologic Map of Tallaboa basin (after Soriano, 1983).
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46
Grossman studied the surface water quality of the Tallaboa Valley in detail.
Samples were collected monthly from the Tallaboa River at Penuelas and at
Tallaboa. Additional samples were collected at infrequent intervals from
headwater streams and canals and irrigation ditches in the valley. All the
surface water supplying the valley is of the calcium bicarbonate type.
Chemical quality of the ground water in the Tallaboa Valley in most places is
similar to that of the surface water. Inputs into the ground-water system
below Penuelas include components from surface water flow that enters the valley
(dervived from volcanic and carbonate outcrops), underground flow to the valley,
local rainfall in the valley and surrounding hills, and salt water from the
Caribbean Sea. Chemical results from approximately 90 wells indicate calcium
bicarbonate type waters. Due to a lack of wells in the upland areas and in the
bedrock abutting the valley walls, the water chemistry of the of the Ponce
Limestone and Juana Diaz deposits is not adequately defined. Giusti (1968)
indicated that the Juana Diaz Formation, being of marine origin and relatively
low permeability, is invariably salty due to its retention of original salinity
at its time of deposition. To further complicate matters, many of the wells in
the valley tap both the alluvial deposits and the Ponce Limestone and are
perforated throughout both deposits. South of Highway 2, a salt water wedge
exists shoreward of the Tallaboa Bay. Water quality in this area was studied
by Diaz (1974), and sodium and chloride were the major inorganic constituents
and water quality is a function of depth.
Grossman attempted a water budget for the Tallaboa basin, and his results
indicate the difficulties of using this approach in semi-arid lands with high
evapotranspiration rates which also experience widely fluctuating levels of
rainfall in wet and dry years. The interested reader is referred to Grossman's
paper.
Historically, the prime use of ground water in the Tallaboa basin has been for
agriculture and domestic supplies. Fresh water is needed for the irrigation of
sugar cane and for fodder, fruit and vegetable fields. The irrigation water
comes from a series of dams and diversion ditches used to exploit surface water
supplies in the valley and from agricultural supply wells in the valley alluvial
aquifer. Grossman estimated that approximately 7 million gallons per day were
pumped from the agricultural supply wells in 1961.
The 1950's witnessed a significant change in water use in the Tallaboa basin.
Commonwealth Oil Refining Corporation (CORCO) and Union Carbide Caribe established
refining and chemical manufacturing plants near the mouth of the Tallaboa Bay,
and other industries established facilities in the same area. The industries
required substantial amounts of fresh water for operation. Grossman estimated
industrial pumpage at the industrial complex to be approximately 4 million
gallons per day in 1960.
Although it appeared in the 1960's that there would be a major conflict between
industry and agriculture for water supplies in the Tallaboa basin, world-wide
economic conditions forestalled a crisis. The petrochemical industry in the
Tallaboa Bay arpa has been largely shut down, and, with the exception of the
power generating station, there is little industrial demand for water. The
agricultural economy, based primarily on sugar cane, has also suffered as a
result of low sugar prices and the shift towards sugar beets as the primary
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48
TL MM TIC
Figure 9 Average annual precipitation, Puerto Rico (from Gomez and Heisel, 1980)
-------
49
oundary of
droinoge erto
C A * I B E
Lint «f tquol avtreot
roinfolli ifittrvot is 10 inches
Main goge ustd in computations
for wottr budget
Figure 10 Average annual rainfall in the Tallaboa basin
(after Grossman et al, 1972).
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50
'X
Figure 11 Mean monthly rainfall south coast of Puerto Rico
(from Grossman et al, 1972).
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51
ATLANTICO
• AN JUAN
MAR CARIBE
«o K«.OMCTC«
Figure 12 Total rainfall during 10/5/86 - 10/6/86 storm event in Puerto Rico
(map prepared by Bob Caluvesbert, National Weather Service).
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52
The Juana Diaz formation is lithologically quite varied. It consists of
clastic beds composed of sands, pebbles and boulders, and mudstone, lime-
stone and reef deposits. The lithologic units of the formation appear to
be lenticular and frequently intertongue with each other. The lower part
of the formation consists mainly of conglomerate and mudstone, with lenses
of limestone present at many horizons. The upper part of the formation
consists mainly of limestone and chalk, with lenses of mudstone and
gravel. No formal members of the formation have been defined due to the
shortage of cored boreholes along the south coast.
The Juana Diaz Formation is continuously exposed, except for alluvial filled
valleys, from an area four kilometers east-southeast of Juana Diaz, west to
the hills southwest of Ensenada. The outcrop is highly irregular because the
formation is cut into many fault blocks. The Juana Diaz Formation is in fault
contact with older rocks of Cretaceous to Eocene age. At other places, the
Juana Diaz rests on an eroded and highly irregular surface of older rocks. The
top of the Juana Diaz was truncated by erosion before the deposition of the
Ponce Limestone.
In the area between the Tallaboa River and the town of Juana Diaz, limestone
remnants of originally discontinous nearshore reefs are present; in the area
between Quebrada del Agua and the Tallaboa River, much of the reef limestone
intertongups with mudstone.
The origin of the Juana Diaz Formation is presently in dispute. Moussa and
Seigle (1970), citing the abundance of planktonic foraminifers, postulated a
deep-water marine origin. This interpretation is difficult to reconcile with
the presence of cross bedded sands and carbonaceous clay which suggest desposi-
tion in a nearshore shallow water environment. In order to reconcile the
conflicting lithologic and paleontologic evidence, Monroe postulated deposition
of the lower Juana Diaz at a time when the upland to the north was being up-
lifted and the sea floor was subsiding, with the result that large qantities of
cobbles, boulders and mud were being deposited by rivers on a subsiding shelf.
Growth of the reef must have been rapid enough for it to remain in the sunlit
zone of water, and mud must have settled rapidly so that the corals were able
to surive. Monroe further postulated that the upper Juana Diaz chalky lime-
stone was deposited during a time when the streams apparently were carrying
less detrital material to the sea and deposition occurred in slightly muddy
water in which lime-secreting organisms supplied most of the sediment.
Site Hydrogeology
The Proteco facility lies in the foothills of the Juana Diaz Formation at an
elevation of approximately 80 meters. Four lithologic units have been recog-
nized in either outcrops or well cuttings at the facility. These include:
(1) A chalky, silty, white to orange soft limestone with
abundant foraminifers. This unit is exposed in several
easily accessible outcrops at the facility.
(2) A tan to brown unconsolidated silty clay. This unit
contains distinct gypsum veins, some of which are visible
at the surface as a result of earth moving work at the
facility.
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54
4 I
V ' C U E B
FIB/
Jf
TuF
TALLABOA/
TALLABOA
ALTA ^
\
V
\
»*'
i ' '
I \ \1
\
\ x
: /
\ S A LI fe'N T E
VeC
A«F
Ttif
TuF
,YcC
ENCARNACION
c /
\;
Ct
^ ) I / ' '
i "", / / j \ V \
; . /! A / O ) ;
v -' ^ \/ r—\._(LA
Figure 13 Soil survey nap 1n the vicinity of PROTECO facility (fro" Sierbolini, 1979)
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55
above the facility in order to establish drainage channels. As mentioned
earlier in the section on storm patterns on the south coast, intense, short
duration storms lead to extensive runoff and flooding. The storm of October,
1985, resulted in severe erosion in the area of the Proteco facility, and the
road to the facility was washed out. A program of revegetation should
be established at the facility in order to help control erosion and caution
should be used to limit further denudation of the area. A work plan as part of
the 3013 order has been designed to quantify the runoff and chemistry of the
surface water at the facility.
In spite of several hydrogeologic investigations at the Protect facility, an
adequate explanation of the hydrogeology at the facility has not been completed.
The 3013 Order signed by Region II and the facility was partly designed to
address this problem. Two work plans for a phased hydrogeological investigation
have been approved by the EPA, and a report examining the results of an extensive
drilling program is to be submitted to the EPA on September 30, 1986. The
comments which follow are based on earlier reports submitted to the agency by
hydrogeologic consultants for the facility, field visits to the site by the EPA
lead hydrogeologist and progress reports submitted to the agency as part of the
phased hydrogeologic investigations.
Proteco is located in a small catchment of the Talloboa River drainage basin,
and is approximately 2.5 kilometers from the Tallaboa valley. The towns of
Seboroco and Tallaboa lie approximately 2.5 kilometers to the west and southwest.
No wells are located between the towns and the facility. There is an elevation
difference of approximately 80 meters between the facility and the valley
floor, and the ridije line above the facility attains an elevation of over 150
meters. The area is a potential recharge zone.
Ground water has been encountered in two major zones at the facility. The
first water bearing unit is located in an upper zone of tan, silty clay. The
tan, silty clay has a thickness of approximately 60 feet in several areas of
the facility. Ground water is associated with gypsum veins in these marine
clays. It should be emphasized that this upper aquifer zone is discontinuous
at the site; many wells drilled into these deposits do not encounter ground
water at shallow depth. Observations from drilling logs indicate that this
water may be partially confined. Well yields are frequently minimal, with
wells being hailed to dryness during sampling. No attempt was made to draw
water level contours for this report due to the lack of borehole spatial controls
and the discontinuous nature of the water bearing zone, but point elevations
indicate flow is toward the valley axis. The water chemistry in the upper zone
indicates a highly saline ground water, with sodium and chloride being the
major inorganic constituents, and specific conductance values are in the range
of 40000-5UOUO micromhos.
A deeper water bearing zone(s) is also present at the facility. This ground
water has been encountered at deaths ranging from 16U-230 feet. The water bearing
material appears to consist of sand and gravel layers within a massive grey
mudstone. This zone appears to be confined -- drilling observations indicate
that water rises 100-130 feet after it is encountered. Water chemistry is
significantly different from that in the upper zone. Specific conductance
-------
57
Groundwater Sampling and Analysis
During the evaluation of Proteccion Tecnica Ecologica (AKA: Servicios
Carbareon), Task Force personnel collected samples from 15 of the facility's
groundwater monitoring wells in an attempt to determine if hazardous
wastes or hazardous waste constituents had migrated from the waste management
units into the underlying groundwater. Well selection was based on a
number of factors. These included: the screened interval of the well,
hydraulic location (upgradient, downgradient), proximity to the waste
management units and the results of previous sampling activities. Table _2
presents the physical characteristics of the wells selected for sampling.
Figure _14_ depicts the approximate location of these wells in relation
to the "hazardous waste management units designated, at the time of this
inspection, as RCRA regulated units. Figure _J^5 depicts the approximate
location of these wells in relation to the active and inactive waste
management units known to exist at this site.
Of the 15 wells selected for sampling 12 were shallow wells. The screened
interval of these wells is in the first groundwater occurrence beneath
the site. This occurrence is found at a depth of between 30 to 75 feet
below the land surface. The shallow wells selected are designated as mon-
itoring wells: 4W81, 9W81, 14W85, 15W85, 18W85, 21W85, 22W85 23W85, 26W85,
28W85, 29W85 and 30W85.
The 3 remaining wells selected for sampling were deep wells. The screened
interval of these wells is in the second groundwater occurrence beneath
the site. This occurrence is found at depths greater than 158 feet beneath
the land surface. The deep wells selected are designated as monitoring
wells: 1W81, 11W83 and 12W83.
Prior to the evacuation of standing water, the well head and the breathing
zone above each well head were monitored with an organic vapor analyzer
(OVA) and/or HNu immediately after the removal of the well cap. The results
of this monitoring are presented in Table 3 . The physical characteristics
of each well, ie: casing diameter, casing construction material, depth to
static water and the total depth of the well, were also recorded.
Well evacuation was accomplished by removing 3 volumes of standing water
from pach well. Standing water volumes were calculated with the following
mathematical equation:
V (gal.) = Tr2 (0.163)
where T is the linear feet of static water (total depth of well minus
distance from top of casing to static water), and r is the inside radius
of the well.
Evacuation procedures as described in the Work/QA Sampling Plan for the
Groundwater Task Force Inspection at Proteccion Tecnica Ecologica, Inc.
were followed. These procedures are outlined below:
-------
58
21WB5
groundwater raonitorino
well
Figure 14 Location of wells sampled by the Task Force
-------
59
21W85
= groundwater monitoring
well
Figure 15 Location of wells sampled in relation to hazardous waste units
-------
60
Proteco
Site Map Legend
Numerical Designation Unit Description
1 Landfill, pre-RCRA drum burial
2 Landfill, pre-RCRA drum burial
3 Landfill, pre-RCRA drum burial
4 Drum storage area (active)
5 Landfill, pre-RCRA drum burial
6 Sanitary landfill (active)
7 Lagoon, corrosive waste (active)
8 Landfill, pre-RCRA drum burial
9 Lagoon, oil (active)
10 Immobilization area (inactive)
11 Immobilization area (inactive)
12 Land application area (active)
13 Lagoon, rainwater (active)
14 Land application, non-hazardous (active)
15 Tank storage area (active)
16 Immobilization area (active)
-------
TABLb 2
— Well Construction Specifications —
Well No.
1W81
4W81
9W81
11W83
12W83
14W85
15W85
18W85
21W85
22W85
23W85
26W85
28W85
29W85
30W85
Total depth
of well
229.0/230.0
53.0/54.02
57.5/73.9
193.0/197.5
174.0/162.0
62.5/43.8
66.0/59.4
59.5/60.3
57.6/58.8
55.0/55.4
39.0/41 .2
69.0/69.2
74.0/76.2
33.8/35.4
54.0/54.8
Depth to
water
71 .2
42.15
32.4
166.65
75.2
25.5
30.4
23.0
14.5
13.25
25.0
23.1
52.5
4.95
37.75
Screened
interval
214-229
39-53
46-56
170-193
158-168
32.5-42.5
48-58
49.5-59.5
47.6-5-7.6
45-55
29-39
59-69
64-74
23.8-33.8
44-54
Screen
length
15
14
10
23
10
10
10
10
10
10
10
10
10
10
10
Screen
slot size
0.01"
0.001"
0.001"
unknown
0.001"
0.015"
0.015"
0.01"
0.01"
0.01"
0.01"
0.01"
0.01"
0.01"
0.01"
Well
diameter
2"ID
4"ID
4"ID
2"ID
2"ID
2"ID
2"ID
2"ID
2"ID
2"ID
2"ID
2"ID
2"ID
2"ID
2"ID
Construction
material
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
PVC
Teflon
Te f Ion
PVC
Teflon
Teflon
note: Total depth of wells are facility measurements/Task Force field measurements.
Depth to water are Task Force measurements, all other construction details
were provided by the the facility (Servicios Carbareon).
-------
62
Table 3_
Well Head and Breathing Zone Air Monitoring Data
Well No.
Instrument Used
Well Head
Breathing Zone
1W81
4W81
9W81
11W83
12W83
1 dURR
i suoc.
18W85
?1 UftR
??u«R
O-JUQC
OCUQC.
9QUQC,
PQUQC;
•jnuQC.
HNu
OVA
HNu
OVA
HNu
OVA
HNu
OVA
HNu
OVA
HNu
OVA
HNu
OVA
HNu
OVA
MNii
OVA
UM,,
OVA
UM,,
OVA
HNu
OVA
HNu
OVA
HNu
OVA
HNu
OVA
2 ppm
background
.4 ppm
1.5 p pm
background
40-100 ppm*
background
background
background
background
background
2 ppm
1 ppm
background
background
background
background
background
background
background
background
background
background
.2 ppm
2 ppm
2 ppm
background
background
background
background
background
background
background
background
background
background
background
background
background
background
= instrument not used
= response characteristic of methane
-------
63
1) Properly locate and identify monitoring well.
2) Remove locking cap and/or protective cap. If needed, the exterior
and interior of the exposed riser pipe of the monitoring well should
be wiped with filter paper and deionized water.
3) Use air monitoring equipment (i.e. OVA, HNU) on escaping gases at
the well head to determine the need and/or level of respiratory
protection. Record readings in a field notebook.
4) Use an interface probe and/or bottom loading teflon bailer to
determine the presence of an immiscible phase.
Record findings in a field notebook.
5) Using a clean weighted steel measuring tape, level indicator and/or
acoustic sounder, determine the following physical measurements:
a) well and casing diameter
b) static water level from top of the casing
c) total depth of the well
Record all measurements in a field notebook and/or Well Monitoring
Data Sheet.
6) Calculate static water volume in gallons using the tables provided.
7) Using a dedicated teflon bailer or bladder pump, begin removal of
water from the well. During evacuation, lower purging equipment or
pump intake into the well a short distance below the water level and
begin water removal. Lower purging equipment as required to maintain
submergence. Collect purge water in 55-gallon drums. The project
coordinator (Ton Moy) will determine appropriate disposal procedures.
8) During the above operation, the following information should be
recorded in a field notebook or on a Monitoring Well Data Sheet.
a) purging times, beginning and ending
b) general characteristics of water being removed (i.e. color, odor,
turbidity, etc...)
c) rate of discharge measured in a calibrated bucket
d) volume of water in casing
e) volume of water removed from well
9) The procedure for purging is dependent upon the yield of the well.
- In low yield wells, the wells should be evacuated to dryness
once and as soon as the well recovers, the first set of para-
meters taken are those which are pH and volatile sensitive.
-------
65
The sampling procedures followed were those described in the Work/QA
Sampling Plan for the Groundwater Task Force Inspection at Proteccion
Tecnica Ecologica, Inc. These procedures are outlined below:
1) Select cleansed dedicated teflon bailer.
2) Attach bailer to either a cleansed stainless steel, teflon coated
stainless steel or monofilament line.
3) Lower bailer until it contacts water surface.
4) Allow bailer to sink and fill with a minimum of surface disturbance.
5) Slowly raise bailer to surface. Do not allow bailer line to contact
the ground. Discard first volume collected in bailer.
6) Begin sampling using a teflon bottom valve attached to the bailer
for sample removal. Avoid, as much as possible, turbulence of
sample in transfer from bailer to sample container.
7) Repeat steps 3-6 as needed to acquire sufficient volume.
8) Contain and preserve samples according to guidelines specified by
the contract laboratory.
9) Measure in-situ parameters: pH, specific conductivity and temperature.
10) Label sample bottles with the following information:
Well name and/or site number
Date
Time
Traffic Report number
Analysis Requested (i.e. metals, VOA, etc...)
Preservative (if required)
Record the information in a field notebook and complete all
Traffic Reports (Inorganics arid Oryanics), and Chain of
Custody Records.
11) Place the sample containers in a metal or plastic cooler maintained
at 4°C throughout the sampling and transportation period.
Samples were collected for the analytical parameters specified in the
list of Monitoring Parameters, attached as Appendix E . Table _4 presents
the parameter, bottle type and methods of preservation used by the Task
Force. The samples were analyzed by EPA contractor laboratories. In
addition, samples requiring immediate measurement, i.e. pH, temperature
and specific conductivity, were measured in the field. These results
are presented in Table 5
-------
TABLE 4
Parameter, Bottle Type and Preservative List
66
Parameter
1. Voltile organics
2. Purgeable Organic
Carbon (POC)
3. Purgeable Organic
Halogens (POX)
4. Extractable Organics
5. Total Metals
6. Dissolved Metals
7. Total Organic
Carbon (TOO
8. Total Organic
Halogens (TOX)
9. Phenols
10. Cyanide
11. Sulfate and Chloride
12. Nitrate and Ammonia
13. Pesticides
14. Dioxin
Bottle Type
4 - 60ml vials
1 - 60ml vial
1 - 60ml vial
4 - 1 qt amber glase
1 qt. plastic
1 qt. plastic
1 - 4 oz. glass
1 qt. amber glass
1 qt. amber glass
1 qt. pla'stic
1 qt. plastic
1 qt. plastic
2 - 1 qt. amber glass
2 - 1 qt. amber glass
Perservative
Cool @4 °C
Cool @4 °C
Cool @4 »C
Cool §4 "C
NH03
Filtered, NH03
H2S04, Cool §4 «C
No Headspace
Cool €4 «C
H2S04, Cool §4 °C
Na OH, Cool §4 »C
Cool §4 »C
H2S04, Cool @4 «C
Cool §4 «C
Cool @4 »C
-------
67
Table 5
-- Field Measurements --
Well
Number
1WH1
4W81
9W81
11W83
12W83
14W85
15W85
18W85
21W85
22W85
23W85
26W85
28W85
29W85
30W«5
Temperature
(°C)
1 1
27.0
26.0
26.0
26.0
29. b
28.0
26.0
29.0
29.0
26.0
27.0
26.5
29.5
26.5
27. U
pH
6.8
6.7
5.8
6.7
6.3
6.1
6.4
7.0
6.2
6.1
6.2
6.5
6.8
6.4
6.3
Specific
Conduct! vity*
(umhos)
3,300
6,000
41,000
6,000
6,000
35,000
39, QUO
41,000
32,000
35,000
19,000
39,000
17,500
40,000
31.5UO
Sal i nity
(ppt)
2
--
26
--
4
--
25
26.5
18.5
--
21
23
10
20.5
21
* = at temperature of groundwater
-- = no measurenents taken
-------
68
All samples, with the exception of those from wells 4W81 and 11W83, were
collected within three hours after evacuation. In the case of wells 4W81
and 11W83, samples for POA, POX, POC, pH, temperature and specific conduct-
ivity were collected following evacuation. The remaining parameters were
collected the following morning, after first resampling pH, specific con-
ductivity and temperature in order to confirm that groundwater equilibrium
had not significantly changed. This deviation from project plan protocol
was necessary in order to facilitate site personnel who had asked that
the Task Force's sampling efforts be curtailed by 4:30Pm. These work
hour limitations were only imposed on the day, 11/18/85, wells 4W81 and
11W83 were evacuated.
Table 6_ presents the sequential order of well evacuation and sampling.
This table also includes the samples collected to fulfill Task Force
quality control/quality assurance protocol. These procedures included
the collection of field blanks, equipment blanks and duplicate well
samples to insure the quality and reliability of the data generated by
the sampling activities of this inspection. In addition, a trip blank
was prepared and shipped with the sample containers prior to on-site
activities.
Following the collection of the samples, EPA contractor personnel placed
the samples in coolers containing ice. The samples were then returned
to a staging area (cargo van) where preservation and filtration, if
required, were completed. The samples were then packaged, in accordance
with applicable Department of Transportation (DOT) regulations, for ship-
ment to the EPA contract laboratories.
Standard chain of custody procedures were employed by Task Force person-
nel throughout this inspection.
As required under Section 3007 (a) of RCRA a receipt for samples was
presented to and signed by facility personnel. These documents are
attached as Appendix F . In addition, the facility was offered split/
rpplicate samples prior to the start of on-site activities. The facility
declined the Task Force offer to collect split/replicate samples.
-------
TABLE 6
Sequential Order of Sample Collection
69
Well
Number
4W81
Equipment Blank
11W83
Equipment Blank
Field Blank
Trip Blank
14W85
15W85
22W85
Field Blank
9W81
9W81 Duplicate
21W85
18W85
Equipment Blank
Field Blank
12W83
23W85
29W85
Field Blank
30W85
Field Blank
1W81
Equipment Blank
28W85
26W85
26W85 Duplicate
Field Blank
Equipment blank
Date Evacuated/Sampled
November 18-19, 1985
November 18, 1985
November 18-19, 1985
November 19, 1985
November 19, 1985
November 19, 1985
November 19, 1985
November 19-20, 1985
November 20, 1985
November 20, 1985
November 21, 1985
November 21, 1985
November 21, 1985
November 21, 1985
November 21, 1985
November 21, 1985
November 22, 1985
November 22, 1985
November 22, 1985
November 22, 1985
November 23, 1985
November 23, 1985
November 23-24, 1985
November 24, 1985
November 23-24, 1985
November 23-24, 1985
November 24, 1985
November 24, 1985
November 24, 1985
Sample
Number
MQO 603
MQO 601
MQO 602
MQO 604
MQO 605
MQO 345
MQO 606
MQO 607
MQO 608
MQO 610
MQO 614
MQO 615
MQO 611
MQO 609
MQO 613
MQO 612
MQO 660
MQO 661
MQO 665
MQO 663
MQO 662
MQO 670
MQO 669
MQO 664
MQO 668
MQO 666
MQO 667
MQO 344
MQO 671
-------
70
Task Force Sampling Data Analysis
During the inspection, Task Force personnel collected samples from 15
ground-water monitoring wells in an atempt to determine if hazardous
wastes or hazardous waste constituents had migrated from the RCRA regu-
lated units into the groundwater. This section presents the results of
data obtained from the analysis of samples collected at ground-water
monitoring wells 4W81, 9W81, 14W85, 15W85, 18W85, 21W85, 22W85, 23W85,
26W85, 28W85, 29W85, 30W85, 1W81, 11W83 and 12W83; however, the data
generated by sample collection and analyses at wells 14W85, 18W85, 22W85,
23W85, 26W85, 28W85, 29W85 and 30W85 is questionable. Wells 22W85, 23W85,
26W85, 28W85, 29W85 and 30W85 were installed immediately prior to the Task
Force inspection and were inadequately developed. According to facility
personnel, Well 14W85 was submerged during the intense storm of October
1985. 16 samples were analysed for quality control/quality assurance
purposes.
The results indicate inorganics in the of ground-water samples collected at
Proteco. The inorganic compounds detected include aluminum, antimony,
arsenic, barium, cadmium, calcium, chromium, cobalt, copper, iron, lead,
magnesium, manganese, nickel, potassium, sodium, thallium, tin, vanadium
and zinc. Table 7 presents the metallic compounds identified and the
concentrations detected. The results of cyanide, selenium, silver and
mercury analysis were rejected by the QA/QC process and are not reported.
Four of the groundwater monitoring wells yielded samples showing levels
of volatile organics. The volatile organic constituents detected include
2-butanone, chloroform and bromodichloromethane. In addition, acetone,
methylene chloride, 1, 1, 1-trichloroethane and toluene were also found
in a number of samples. However, these constituents were also found in
the associated QA/QC samples (i.e., field blanks, equipment blanks and
trip blanks), and this data cannot be used in determining releases from
the facility. Table 8 represents the organic compounds detected in the
samples collected by the Task Force.
The results of semi-volatile compound analysis and a good portion of the
pesticide, PCB, and herbicide data were rejected by the QA/QC process and
are not reported.
Several tentatively identified organic compounds were detected. However,
the specific compounds reported have not been confirmed against labora-
tory standards and additional work is necessary in order to positively
identify these compounds. Table 9 presents these compounds and the
samples in which they were detected.
Task Force data indicates the presence of inorganic constituents in all
of the samples collected. Concentrations of several of the inorganics,
including barium and chromium, exceed drinking water standards. The data
from seven of the wells is questionable due to the fact that six of the
wells were inadequately developed and one of the wells was apparently
submerged during the October, 1985 storm. Of the inorganics sampled,
-------
72
due to sample holding times. Additional sampling and analysis is would be
necessary in order to confirm the absence of presence of semi-volative
compounds.
The tentatively identified compounds indicate the possible presence of
organic contamination. The specific organic compounds have not been posi-
tively identified. Additional sampling and analysis is necesary to identify
these compounds. After the 3013 hydrogeologic study of the facility is
completed and the hydraulic parameters defined on a site-wide basis, it is
recommended that the organic data generated by the Task Force be reviewed.
It is also recommended that the RCRA monitoring wells undergo further well
development and additional organic sampling be conducted in the new wells
recently completed at the facility.
-------
Table 7
Results of Inorganic Analysis on Samples Collected at Proteco
73
Sample Number/Location
Compound
(total)
MQO 603
Well 4W81
MQO 601
Equipment
blank
ug/1
MQO 602
Well 11W83
MQO 604
Equipment
blank
MQO 605
Field
blank
MQO 345
Trip blank
Alumi num
Arseni c
Antimony
Barium
Beryl 1 iutn
Cadmium
"alei urn
Chromium
Cobalt
Copper
Iron
Lead
Magnesi urn
Manganese
Nickel
Potassium
Sodium
Thai 1ium
Tin
Vanadi urn
Zinc
ug/1
621 e
21.1
— r
460000 e
39
666 e
— r
1360UO e
39 e
— r
22500
924000 e
— r
*
(9)
— r
— r
— r
75
ug/1
32200 e
*
*
525
13 r
1380000 e
83
65
22100 e
— r
173000 e
1150 e
56 r
22300
512000 e
— r
— r
98
117
ug/'
*
— r
10
(4b)
— r
— r
43
(6)
ug/"
— r
(7)
— r
— r
— r
ug/1
— r
— r
— r
-------
Table 7 (cont)
74
Results of Inorganic Analysis on Samples Collected at Proteco
MQO 606 MQO
Compound Well 14W85 Well
(total )
odmpie Numuer/ LOLOLL i UM
607 MQO 608 MQO 610 MQO 614
15W85 Well 22W85 Field blank Well 9W81
1
ug/1 ug/1 ug/1 ug/1 ug/1
Aluminum b24UO e 28900 e 3540 e --- *
Arsenic *
* * * *
Antimony 582 r 490 r 316 r --- r *
Barium 882 1330 308
Beryllium —
— — —
Cadmium 24 r 38 r 18 r --- *
Calcium 2490000 e 3800000 e 3490000 e --- 3091)000 e
Chromium 150 258 74 10 *
Cobalt (45) (29) (31) — (32)
Copper 58 40 --- --- (20)
Iron 40300 22500 2060 e (28) *
Lead — r 35.4 e,r — e,r — r — r
Magnesium 3140000 e 1840000 e 1950UOO e — - 312UOOO e
Manganese 1330 e 1600 e 3100 e --- 412 e
Nickel 126 r 326 r 60 r — - 120 r
Potassium 140000 73000 74100 --- 100000
Sodium 6970000 9390000 e 7240000 e — - 9060000 e
Thallium —
Tin *
-- r — - --- r (6.9) r
* * 43 *
Vanadium 148 86 --- --- *
Zinc 122 74 60 (10) 97
MQO 615
Well 9W81
duplicate
ug/1
*
*
*
(49)
—
*
3130UOO e
*
(32)
(19)
*
— r
31301)00 e
376 e
99 r
125000
8810000 e
— r
*
*
36
-------
Table 7 (cont)
Results of Inorganic Analysis on Samples Collected at Proteco
75
Compound
(total )
Al umi num
Arsenic
Antimony
Bari urn
Beryl li urn
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesi urn
Manganese
Nickel
Potassium
Sodium
Thallium
Tin
Vanadi urn
Zinc
MQO 611
Well 21W85
ug/1
4680 e
*
381 r
(144)
—
24 r
4790000 e
100
50
2530 e
— r
3210000 e
1310 e
110 r
123000
6470000 e
—
*
(44)
65
MQO 609 MQO 613 MQO t
Well 18W85 Equipment Field
|_ | blank [
ug/1 ug/1 ug/
449 e
* *
347 r .__ r
— —
— —
20 r
3500000 e
88 (6)
(26)
— — —
420 e (69) (3;
--- e,r --- r (1
2270000 e
187 e
86 r
125000
8280000 e
— r — r —
* * —
— — —
34
512 MQO 660 MQO 6bl
blank Well 12W83 Well 23W85
1
'1 ug/1 ug/1
1040 e 110UOO e
. * * *
- r 102 r 3^8 r
(179) 1620
— —
5 r 26 r
619000 e 183000U e
26 192
(31)
(9) 96
J) 1260 e 64580 e
.6) r — r (4.7) r
149000 e 7b6000 e
354 e 1030 e
... r 104 r
28500 56700
4810UO e 2960000 e
. r — r — r
* *
172
26 281
-------
Table 7 (cont)
Results of Inorganic Analysis on Samples Collected at Proteco
76
Compound
(total)
Alumi num
Arsenic
Antimony
Barium
Beryl lium
Cadmi urn
Calcium
Chromi um
Cobalt
Copper
Iron
Lead
Magnesi um
Manganese
Nickel
Potassium
Sodi um
Thallium
Tin
Vanadium
Zinc
MOO 665 MQO
Well 29W85 Field
ug/1 ug/
6720 e
*
265 r
554
— —
20 r
3620000 e
94 (S
— —
— —
4540 e
(3.2) r
1370000 e
301 e
69900
8800000 e
... r
* (36
— —
83
663 MQO 662 MQO 670
blank Well 30W85 Field blank
'1 ug/1 ug/1
42100 e
. * * *
464 r
2260
— —
28 r
35401)00 e
)) 166 (8)
(38)
34
29900 e
r — r — r
1590000
378 e
82 r
77000
5620000 e
r — r --- r
) * 50
126
121
MQO 669 MQO 664
Well 1W81 Equipment
blank
ug/1 ug/1
4700 e
* *
90 r
(103)
— —
_.. r
462000 e
21
— —
— —
3310 e
(1.1) r — r
57400 e
200 e
... r
11600
445000 e
— r — r
*
— —
45
-------
77
Table 7 (cont)
Results of Inorganic Analysis on Samples Collected at Proteco
Compound
(total)
Aluminum
Arsenic
Antimony
Barium
Beryl li urn
Cadmium
Calcium
Chromi urn
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Sodi urn
Thallium
Tin
Vanadi urn
Zinc
MQO 668
Well 28W85
ug/1
55100 e
*
124 r
302
—
20 r
2860000 e
155
57
149
19600 e
r
619000 e
1220 e
216 r
44700
3740000 e
— r
*
165
6b6
Odli
MQO 666
Well 26W85
ug/1
*
*
b48 r
310
—
30 r
3850000 e
208
(44)
58
44900 e
•~ — «• r*
184UOOO e
1980 e
144 r
64900
8040000 e
— r
*
146
223
MQO 667 MQO 344
Well 26W85 Field blank
| duplicate |
ug/1 ug/1
*
* *
567 r
390
— —
34 r
4010000 e
234
(47)
86
66100 e
— r — r
1880000 e
2150 e
186 r --- r
72900
8170000 e
— r --- r
* ___
226
218
MQO 671
Equipment
| blank
ug/1
—
*
— r
—
—
—
—
—
—
—
—
— r
—
—
—
—
—
— r
56
—
_ . «.
-------
78
Inorganics Data Reporting Qualifiers
* = QA/QC review resulted in data rejection.
e = Indicates a value pstimated due to the presence of interference.
r = Indicates spike sample recovery was not within control limits.
— = Indicates not detected or less than the detection limit.
( ) = Indicates value greater than the detection limit of the instrument
but less than the contract required detection limit.
Note - During the QA/QC review process all data for cyanide, selenium, silver
mercury and all but one data point for arsenic was rejected.
-------
Table 8
Results of Organic Analysis on Samples Collected at Proteco
Compound
Acetone
2-Rntanone
MOO 603
Well 4W81
uq/1
MQO 601
Equipment
blank
uq/1
oampie
MOO 602 MOO 604
Well 11W83 Equipment
| blank
uq/1 uq/1
* *
iNiUTTioer/ L,oca c i on
MOO 605 MOO 345 MQO
Field Trip blank Well
blank
uq/1 uq/1 uc
* *
_»_ — — — . — -
606 MOO 607 MOO 608
14W85 Well 15W85 Well 22W85
3/1 uq/1 uq/1
* 190 *
— 1100
Chloroform
16
Brono-
dichloromethane
9.5
UD
-------
Table 8 (cont)
Results of Organic Analysis on Samples Collected at Proteco
Compound
MQO 610
Field blank
1
uq/1
MOO 614
Well 9W81
uq/1
MOO 615
Well 9W81
| duplicate
uq/1
.^ampie
MOO 611
Well 21W85
1 1
uq/1
1 iNumneL/LiOca
MOO 609
Well 18W85
uq/1
cion
MOO 613
Equipment
blank
uq/1
MOO 612
Field
I blank
uq/1
MOO
Well
1
uc
660
12W83
1
VI
MOO 661
Well 23W85
uq/1
Acetone
2-Butanone
Chlotofofm
Btono-
dichlotomethane
*
11
3.2 j
oo
o
-------
Table 8 (cont)
Results of Organic Analysis on Samples Collected at Proteco
Sample Number/Locat i on
MOO 665 MOO 663 MOO 662 MQO 670 MOO 669 MOO 664 MOO 668 MOO 666 MOO 667
Compound Well 29W85 Field blank Well 30W85 Field blank Well 1W81 Equipment Well 28w85 Well 26W85 Well 26W85
i | | | | | blank | j | duplicate
uq/1 uq/1 uq/1 uq/1 uq/1 uq/1 uq/1 uq/1 uq/1
Acetone ********
2-Rutanone *
Chloroform 3.8 j
Brono-
dichloromethane
00
-------
Table 8 (cont)
Reults of Organic Analysis on Samples Collected at Proteco
Sample Number/Location
MOO 344 MQO 671
Compound Field blank Equipment
I I blank
uq/1
uq/1
Acetone
2-Butanone
Chlotoform
Brono-
dichloiomethane
00
-------
83
Organics Data Reporting Qualifiers
* = QA/QC review resulted in data rejection.
j = Indicates value estimated.
-- = Indicates not detected or less than detection limit.
Note - All semi volatile compound analysis was rejected during the QA/QC review
process.
-------
Table 9
Tentatively Identified Compounds ug/1
84
Compound
MOO 603 MQO 601 MQO 602 MQO 604 MQO 605
Well 4W81 Equipment Well 11W83 Equipment Field
I blank I I blank I blank
Aziridine,2-Hexyl-
Cyclohexane, Methyl
Cyclohexanol
Cyclohexanol,2-Methyl-3-
(1-Methylethenyl )-Acetate
Cyclopentanol,2-Methyl-,Cis
Cyclopentanol,2-Methyl-,Trans
Cyclopentanone,2-Methyl
l,3-Dioxane,4,6-Bis(2,2-
Dimethylpropyl )-
Et.hane,l,2-Dichloro-l,l,2-
Tri fl uoro-
Ethane,l,l,2-Trichloro-l,2,2-
Ti rfluoro
Furan, Tetrahydro-
2-Heptene,5-Ethy1-2,4.Dimethyl-
Hexanoic Acid, 2-Cyano-,Ethyl-
Fster
1,2,-Dithiol-l-ium,Iodide
9-Octadecenamide, (2)-
Oxi rane,(Butoxymethyl)-
Pentane,!,5-Dibromo-
2-Pentanol,2,4-Dimethyl
Phenol,2,4-Dichloro-6-Methyl
1-Propanol,2-Ispropoxy
2-Propanol,1-Propoxy
3-Udecene,6-Methyl-,(E)-
10
-------
Table 9 (cont)
85
Compound
Tentatively Identified Compounds ug/1
MQO 345 MQO 606 MQO 607
Trip blank Well 14W85 Well 15W85
MQO 608
Well 22W85
MQO 610
Field
blank
Aziridine,2-Hexyl-
Cyclohexane, Methyl
Cyclohexanol
Cyclohexanol,2-Methyl-3-
(1-Methylethenyl)-Acetate
Cyclopentanol,2-Methyl-,Ci s
Cyclopentanol,2-Methyl-,Trans
Cyclopentanone,2-Methyl
l,3-Dioxane,4,6-Bis(2,2-
Dimethylpropyl)-
Ethane,l,2-Dichloro-l,l,2-
Trifl uoro-
Ethane,l,l,2-Trichloro-l,2,2-
Ti rfluoro
Furan, Tetrahydro-
2-Heptene,5-Ethy1-2,4,Dimethyl-
Hexanoic Acid, 2-Cyano- .Ethyl -
Ester
1,2,-Dithiol-1-ium,Iodide
9-Octadecenamide, (2)-
Oxi rane,(Butoxymethyl)-
Pentane.l,5-Dibromo-
2-Pentanol,2,4-Dimethyl
Phenol,2,4-Dichloro-6-Methyl
1-Propanol ,2-Ispropoxy
2-Propanol,1-Propoxy
3-UdPcene,6-Methyl-,(E)-
10
15
10
11
140
15
26
48
40
16
-------
Table 9 (cont)
Tentatively Identified Compounds ug/1
86
Compound
MQO 614
Well 9W81
1 I
j
MQO 615
Well 9W81
| duplicate
MQO 611
Well 21W85
1
MQO 609
Well 18W85
MQO 613
Equipment
blank
Aziridine,2-Hexyl-
Cyclohexane, Methyl
Cyclohexanol
Cyclohexanol,2-Methyl-3-
(1-Methylethenyl)-Acetate
Cyclopentanol,2-Methyl-,Cis
Cyclopentanol,2-Methyl -,Trans
Cyclopentanone,2-Methyl
l,3-Dioxane,4,6-Bis(2,2-
Dimethylpropyl )-
Ethanp,l,2-Dichl oro-1,1,2-
Tri fluoro-
Ethane,l,l,2-Trichloro-l,2,2-
Ti rfluoro
Furan, Tetrahydro-
2-Heptene,5-Ethy1-2,4,Dimethyl-
Hexanoic Acid, 2-Cyano-,Ethyl -
Ester
1,2,-Dithiol-1-i urn,Iodide
9-Octadecenamide, (2)-
Oxi rane,(Butoxymethyl)-
Pentane,l,5-Dibromo-
2-Pentanol,2,4-Dimethyl
Phenol,2,4-Dichloro-6-Methyl
1-Propanol,2-Ispropoxy
2-Propanol,1-Propoxy
3-Udecene,6-Methyl-,(E)-
10
-------
Table 9 (cont)
Tentatively Identified Compounds ug/1
87
MOO 612 MOO 660
Field Well 12W83
Compound blank
Azi ridine,2-Hexyl- — —
Cyclohexane, Methyl -— 28
Cyclohexanol — 13
MQO 661 MQO 665 MQO 663
Well 23W85 Well 29W85 Field
bl ank
13
23
Cyclohexanol,2-Methyl-3-
(1-Methylethenyl)-Acetate
Cyclopentanol,2-Methyl-,Cis
Cyclopentanol,2-Methyl-,Trans
Cyclopentanone,2-Methyl
l,3-Dioxane,4,6-Bis(2,2-
Dimethylpropyl )-
Ethane, 1,2-Dichloro-l,1,2-
Tri fluoro-
Ethane,l,l,2-Trichloro-l,2,2-
Ti rfluoro
Furan, Tetrahydro-
2-Heptene,5-Ethy1-2,4,Dimethyl-
Hexanoic Acid, 2-Cyano-,Ethyl -
Ester
1,2,-Dithiol-l-ium,Iodide
9-Octadecenamide, (2)-
Oxirane,(Butoxymethyl)-
Pentane,!,5-Dibromo-
2-Pentanol,2,4-Dimethyl
Phenol,2,4-Dichloro-6-Methyl
1-Propanol,2-Ispropoxy
2-Propanol,1-Propoxy
3-Udecene,6-Methyl-,(E)-
10
67
-------
Table 9 (cont)
88
Compound
Tentatively Identified Compounds ug/1
MQO 662 MQO 670 MQO 669
Well 30W85 Field Well 1W81
I I blank I
MQO 664 MQO 668
Equipment Well 28W85
blank I
Aziridine,2-Hexyl-
Cyclohexane, Methyl
Cyclohexanol
Cyclohexanol,2-Methyl-3-
(1-Methylethenyl)-Acetate
Cyclopentanol,2-Methyl-,Cis
Cyclopentanol,2-Methyl-,Trans
Cyclopentanone,2-Methyl
l,3-Dioxane,4,6-Bis(2,2-
Dimethylpropyl )-
Ethane, 1,2-Dichloro-1,1,2-
Trifluoro-
Ethane ,1,1,2-Tri chloro-1,2,2-
Ti rfluoro
Furan, Tetrahydro-
2-Heptene, 5-Ethy1-2,4,Dimethyl-
Hexanoic Acid, 2-Cyano-,Ethyl-
Ester
l,2,-Dithiol-l-ium,Iodide
9-Octadecenamide, (2)-
Oxi rane,(Butoxymethyl)-
Pentane,!,5-Dibromo-
2-Pentanol,2,4-Dimethyl
Phenol,2,4-Dichloro-6-Methyl
1-Propanol,2-Ispropoxy
2-Propanol,1-Propoxy
3-Udecene,6-Methyl-,(E)-
26
640
3300
110
-------
Table 9 (cont)
89
Compound
Tentatively Identified Compounds ug/1
MOO 666 MQO 667 MQO 344 MQO 671
Well 26W85 Well 26W85 Field Equipment
| duplicate | blank [ blank
Aziridine,2-Hexyl-
Cyclohexane, Methyl
Cyclohexanol
Cyclohexanol,2-Methyl-3-
(1-Methylethenyl)-Acetate
Cyclopentanol,2-Methyl-,Cis
Cyclopentanol,2-Methyl-,Trans
Cyclopentanone,2-Methyl
l,3-Dioxane,4,6-Bis(2,2-
Dimethylpropyl)-
Ethane, 1,2-Dichloro-1,1,2-
Trifluoro-
Ethane,1,1,2-Trichloro-1,2,2-
Ti rfluoro
Furan, Tetrahydro-
2-Heptene,5-Ethyl-2,4,Dimethyl-
Hexanoic Acid, 2-Cyano-,Fthyl-
Ester
1,2,-Dithiol-1-ium,Iodide
9-Octadecenamide, (2)-
Oxi rane,(Butoxymethyl)-
Pentane,l,5-Di bromo-
2-Pentanol,2,4-Dimethyl
Phenol,2,4-Dichloro-6-Methyl
1-Propanol,2-Ispropoxy
2-Propanol,1-Propoxy
3-Udecene,6-Methyl-,(E)-
33
14
15
49
160
16
16
-------
90
Hazardous Waste Treatment, Storage, and Disposal
During Interim Status
Regulatory Requirements
Pursuant to Section 3006 of RCRA, 42 U.S.C. §6926, on October 14, 1982, EPA
authorized the Commonwealth of Puerto Rico to administer certain portions
of its hazardous waste program in lieu of those portions of the federal
hazardous waste program with respect to, Inter alia, requirements for the
generation,transportation, treatment, storage and disposal of hazardous
wastes. The Commonwealth of Pureto Rico Environmental Quality Board ("EQB")
promulgated a regulatury framework in the Commonwealth Rules for the Control
of Hazardous and Non-Hazardous Solid Waste, ("RCHNSW"), which implements a
hazardous waste management program pursuant to the Environmental Public
Policy Act (Law No. 9 of June, 1970, as amended). In Rules 101-1001, of
RCHNSW EQB adopted provisions equivalent to 40 CFR Part 265, which
provide standards for owners and operators of hazardous waste treatment,
storage, and disposal facilities (TSDFs) [with final] or interim status.
Pursuant to Section 3006(d) of RCRA, 42 U.S.C. §6926(d), the Commonwealth
of Puerto Rico hazardous waste statutes and regulations have the same force
and effect as regulations issued by EPA under Subchapter III of RCRA. A
violation of the authorized Commonwealth of Puerto Rico hazardous waste
program is a violation of the requirements of subchapter III of RCRA
State Regulatons
The Commonwealth Regulations for the Control of Hazardous and Non-
Hazardous Solid Waste (RCHNSW) (enacted in November 20, 1981) for owners
and operators of hazardous waste treatment, storage, and disposal facilities
are nearly identical to the RCRA Part 265, interim status requirements. The
substantive differences are that the Commonwealth requires (1) the hazardous
waste facilities that store containers of hazardous waste must have a
continuous base which is impervious to the stored waste and which is con-
structed so that any surface runoff or spill can be contained until the
spilled waste can be removed for either treatment or final disposal; (2)
the facility operator shall store the containers in an area with a roof or
other covering to prevent direct sunlight or rainwater from contact with the
drums; and (3) where gases are generated within the landfill, a gas
collection and control system shall be installed to control the vertical and
horizontal escape of gases from the landfill. Regulation counterparts are
shown in Table [ 10 ].
-------
91
TABLE [ 10 ]
STATE AND FEDERAL COUNTERPART INTERIM STATUS REGULATIONS
Subpart
Title
Subpart A-General
Applicabi lity
Iminent Hazard Action
Subpart B - General Facility
Identification Number
Required Notices
General Waste Analysis
Security
General Inspection Require-
ment
Personnel Training
General Requirement for
Ignitable, Reactive, or
Incompatible Waste
Subpart C - Prepardness and
Maintenance and Operation
Requirement Equipment
Testing and Maintenance of
Equipment
Access to Communications or
Alarms System
Requi red Aisle Space
Arrangement with Local
Authorities
Subpart D - Contingency Plan
Content of Contingency Plan
Copies of Contingency Plan
Puerto Rico
Regulation
(RCHNSW Rule)
801
802
Standards
803A
803B
8071
803D
803F
808C
809
Prevention
810B
810C
810D
810E
810F
81 UG
and Emergency Procedures
207
207
Amendment of Contingency Plan 803E(7)
Emergency Coordinator
Emergency Procedures
803E(1)
803E
RCRA
Regulation
(40 CFR Part)
265.1
265.4
265.11
265.12
265.13
265.14
265.15
265.16
265.17
265.31
265.32
265.33
265.34
265.35
265.37
265.52
265.53
265.54
265.55
265.56
-------
92
Management of Containers 812D(1) 265.173
Inspections 812E 265.174
Special Requirements for 812B(5) 265.176
Ignitable or Reactive Waste
Special Requirements for 812D(3) 265.177
Inconpatible Waste
Subpart J - Tanks
Applicability 813A 265.190
General Operating Requirements 813B 265.192
Waste Analysis and Trial Tests 813C 265.193
Inspections 813D 265.194
Closure 813E 265.197
Special Requirements for 813F 265.198
Ignitable or Reactive Waste
Special Requirements for 813G 265.199
Incompatible Waste
Subpart K - Surface Impoundments
General Operating Requirements 817B 265.222
Containment Systems 817B 265.223
Waste Analysis and Trial Tests 817C 265.225
Inspections 817D 265.226
Closure and Post-Closure 817F 265.228
Special Requirements for 817G 265.229
Ignitable or Reactive Wastes
Special Requirements for 817H 265.230
Incompatible Wastes
Subpart L - Waste Piles
Applicability 818A 265.250
Protection from Wind 818B 265.251
Waste Analysis 818C 265.252
Containment 818D 265.253
Special Requirements for 818F 265.256
Ignitable or Reactive Waste
Special Requirements for 818G 265.257
Incompatible Wastes
Subpart M - Land Treatment
General Operating Requirements 819B 265.272
Waste Analysis 819C 265.273
Food Chain Crops 819E 265.276
Unsaturated Zone Monitoring 819G 265.278
Record Keeping 819H 265.279
Closure and Post-Closure 8191 265.280
Special Requirement for 819J 265.281
Ignitable Reactive Waste
Special Requirement for 819K 265.282
Incompatible Wastes
-------
93
Content of Contengency Plan 207 265.52
Copies of Contengency Plan 207 265.53
Amendment of Contengency Plan 803E(7) 265.54
Emergency Coordinator • 803E(1) 265.55
Emergency Procedures 803E 265.56
Subpart E - Manifest System, Record Keeping and Reporting
Use of Manifest System 504B 265.71
Manifest Discrepancies 504D(2) 265.72
Operating Record 502C 265.73
Availability, Retention and 505 265.74
Disposition of Records
Unmanifested Waste Report 504D(3) 265.76
Additional Reports 503C 265.77
Subpart F - Groundwater Monitoring
Applicability 804A 265.90
Groundwater Monitoring 804B 265.91
Sampling and Analysis 804C 265.92
Preparation, Evaluation and 804D 265.93
Response
Record Keeping and Reporting 503B 265.94
Subpart G - Closure and Post-Closure
Applicability 805A(1) 265.110
Closure Performance Standard 805A(2) 265.111
Closure Plan; Amendment of Plan 805A(3) 265.112
Closure; Time Allowed for 805A(5) 265.113
Closure
Disposal or Decontamination 805A(6) 265.114
of Equipment
Certification of Closure 805A(7) 265.115
Post-closure Care and Use 805B 265.117
of Property
Notice to Local Land 805D 265.119
Authority
Notice in Deed to Property 805C 265.120
Subpart I - Use and Management of Containers
Applicability 812A 265.170
Condition of Containers 812C 265.171
Compatibility of Waste 812C 265.172
with Container
-------
94
Subpart N - Landfills
Applicability 816A 265.300
General Operating Requirements 816B 265.302
Surveying and Record Keeping 816B 265.309
Closure and Post-Closure 816C 265.310
Special Requirements for 816D 265.312
Ignitable or Reactive Waste
Special Requirements for 816E 265.313
Incompatible Wastes
Special Requirements for 816F 265.314
Liquid Waste
Special Requirements for 816G 265.315
Contai ners
Disposal of Small Containers 816H 265.316
of Hazardous Waste in Overpacked Drums
-------
95
RCRA INSPECTION
As part of the Groundwater Monitoring Task Force a full RCRA inspection
was conducted at Proteco's facility operation in accordance with 40 CFR
265 and RCHNSW Rule.
These requirements address the administrative non-technical and technical
regulations and included a visual observation of current waste management
units and a review/evaluation of records maintained at the facility.
WASTE MANAGEMENT UNITS/OBSERVATION
Drum Burial Unit II (Cavidad 1C Landfill)
This unit was used for the disposal of waste in drums from 1975 to 1979.
Records show that there are approximately at least 5,757 drums buried in
this landfill totalling 316,635 gallons. Detailed design plans for this
unit are not available but it is estimated that this unit is approximately
15 to 18 feet deep. This unit does not have a liner system but it was
constructed in a low permeability clay formation.
At the time of the inspection the following was noted:
0 A 40' x 20' section of this had no cover
0 A blue/green chalky material with no odor was scattered throughout
this burial ground
0 Surface was spongy and there is evidence of sliding of the 10 foot
high bank along the north side of the unit
Drum burial Unit #2 (General Electric Landfill)
This unit was used for the disposal of waste in drums from 1975 to 1979.
Records show that there are at least 416 drums buried in this landfill
totalling 22,800 gallons. Detailed design plans are not available for
this unit but it is estimated that this unit is 10 feet deep. This
unit does not have a liner system but it was constructed in a low per-
meability clay formation.
At the time of the inspection the following was noted:
0 Area is grass covpred (4 feet) on a 30+_ degree slope
0 Unable to enter this unit
Drum Burial Unit #3 (Roche Landfill)
This unit was used for the disposal of waste in drums from 1975 to 1979.
Records show that there are at least 1,683 drums buried in this landfill
totalli ng 92,565 gallons.
-------
97
At the time of the inspection the following was noted:
0 The impoundment is unlined
0 Overall freeboard is 2'_+
0 The dike has no cover, is soggy and possible unstable
0 North side of the unit has approximate 15 foot high embankment
with slope failure
Immobilization Facility #10 (Til) (inactive since 1981)
This unit was used for the disposal of immobilized waste until circa
1981. Immobilization process is to fix the waste in a matrix of cement
dust and water. Records show that there are approximately 15,965 gallons
of waste disposed in this unit. This unit is estimated to be 50 feet
long, 14 feet deep, and 22 feet wide, giving a total volume of 15,QUO
FT3. At the time of the inspection no measure were taken to prevent run-
on or run-off control.
Immobilization Facility #U (11-2) (inactive since 8/82)
This unit was used for the disposal of immobilized waste until August 1982.
Records show that there are approximately 201,450 gallons of waste disposed
in this unit.
This unit is estimated to be 160 feet long, twenty eight feet deep, and
forty feet wide for a total volume of 179,200 FT3. At the time of
inspection, no measure were taken to prevent run-on or run-off control.
Immobilization Facility #16 (TI-3) (active)
The volume of this unit is 47 feet by 240 feet by 20 feet deep. It has a
total available capacity of 7.617 cubic yards. A mixture of clay and
sand cover the area. The west and south side of the unit drops off on a
45 degree slope for approximately 30'. This sloped area is grass covered.
The east side of the unit has both an uncontrolled drainage ditch and an
embankment. This ditch could or does carry hazardous waste off of the
unit. The north of the unit is contiguous with unit AC-1, Landfarm. Run-
on to this landfill from AC-1 is uncontrolled.
At the time of the inspection, no measure were taken to prevent run-on or
run-off control.
-------
99
is 7,222 cubic yards. The maximum waste inventory is estimated to be 1.62
million gallons. This lagoon also contains an aqueous solution of salts
and metals, including ferric chloride. Wastewater treatment sludge from
a tuna fish processing plant has also been placed in the surface impoundment.
At the time of the inspection the following was noted:
0 Freeboard is approximately 6 feet
0 Run-on control from the southeast side of the unit is uncontrolled
Tank Storage Area #15
The existing tank at Proteco is an 8,000 gallon horizontal carbon steel
tank.
The shell thickness is a uniform 0.25 inches and the material of construc-
tion is ASTM 283-C carbon steel. The tank is 91 inches in diameter and 24
feet long and was manufactured in accordance with Underwriters Laboratory
standard UL-58 for gasoline storage. It presently stores wastewater from
shampoo manufacture which is EP toxic due to high concentrations of lindane.
At the time of the inspection the following was noted:
0 No discharge control equipment or monitoring equipment
0 Fire prevention consists of a single fire extinguisher
0 Inspections being accomplished weekly
Rainwater Lagoon #13 (LB)
The rainwater basin is used as a holding basin for supernatant water collected
in the oil lagoon, the maximum waste inventory is estimated to be 100,000
gallons. The rainwater basin does not collect run-off and return run-on but
only collects water that is specifically pumped from the oil lagoon.
Water from the oil lagoon is pumped into the rainwater basin after determin-
ation that the water is not hazardous. Rainwater and supernatant liquids
collected in the rainwater basin evaporates, since net annual evaporation
exceeds the rainfall and oil lagoon supernatant discharge.
At the time of the inspection, freeboard is maintained at much more than
two feet.
Empty Drum Storage Area
This unit is for storage of empty drums after liquids are decanted from drums.
-------
101
8/9/85 - 2 gal of hydrochloric acid
6/6/85 - 5000 gal of phosphoric acid
- On 10/11/85 132 Ibs. of potassium cyanide was placed into oil lagoon LA
- On 10/11/85 84 Ibs of sulfuric acid was also placed into this surface
impoundment
The potential consequences of this mixing include generation of
toxic hydrogen cyanide of hydrogen sulfide gas.
- On 9/23/85 200 Ibs of hazardous waste solids consisting of P030 (cyanides),
DD02 (corrosives) and U188 (phenols) were placed into landfill TI3
The following potentially incompatible materials were also placed
into thi s landfi11:
On 11/7/85 500 Ibs of "contaminated solid waste" (D001)
On 11/8/85 22860 Ibs of "corrosive solids" (D002)
- On 8/22/85 5178 Ibs. of waste Pyrethrins was placed in Landfarm AC2
- On 10/3/85 7,200 Ibs of waste slake lime was placed in AC2
Although these substances may not be "hazardous" wastes, pyrethins
are known to be incompatible with alkalies.
Waste Analysis Plan Review
The Proteco facility instituted new Waste Analysis Procedures in October 1985.
These procedures were followed by the facility but were deficient as follows:
- The procedures used to inspect and analyze each shipment of hazardous
waste do not ensure that the waste matches the identity of the waste
designated on the accompanying manifest. The instituted procedures
only verify the characteristic of the waste as it would indicated on
the manifest.
- The procedures used do not provide a detailed chemical and physical
analysis of a representative sample of the waste to identify treata-
bility, ignitability, reactivity, or incompatibility of the wastes.
- The Waste Analysis plan does not include Quality Assurance/Quality
Control Procedures to ensure that the analysis is accurate or up-to-
date (i.e., evaluation of laboratory procedures, data obtained, etc.)
- The Plan does not include the waste analysis that hazardous waste
generators have agreed to supply.
-------
103
REFERENCES
Caluvesbert, Robert, 1986, October, 1985 storm event in Puerto Rico:
National Weather Service.
Diaz, J.R., 1974, Coastal salinity reconnaissance and monitoring system -
south coast of Puerto Rico: U.S. Geological Survey Open-File Report
74-1, 28p.
Gomez-Gomez, F. and Heisel, J.E., 1980, Summary appraisals of the nations
ground-water resources -- Caribbean Region: U.S. Geological Survey
Professional Paper 813-U.
Grossman, I.G., Rogart, D.B., Crooks, J.W., and Diaz, J.R., 1972, Water
resources of the Tallaboa Valley, Puerto Rico: Commonwealth of
Puerto Rico Water-Resources Bullettin 7, 115p.
Krushensky, Richard D., and Monroe, Watson H., 1975, Geologic map of the
Ponce quadrangle, Puerto Rico: U.S. Geological Survey Geological
Quad Map, Scale 1:20,QUO.
Monore, W.H., 1980, Geology of the middle Tertiary formations of Puerto
Rico: U.S. Geological Survey Prof. Paper 953.
Monroe, W.H., and Krushensky, Richard D., 1978, Geologic map of the Penuelas
and Punta Cuchara Quadrangles, Puerto Rico: U.S. Geological Survey
Geological Quad Map 1-1042, Scale 1:20,000.
Mo:issa, M.T., and Siegle, G.A., 1970, Revision of middle Tertiary stratigraphy
of southwestern Puerto Rico: Am. Association of Petroleum Geologists
Bulletin, Volume 54, No. 10, pp. 1887-1898.
Soil Conservation Survey, 1979, Soil survey of the Ponce area of southern
Puerto Rico: U.S. Department of Agriculture and University of Puerto
Rico College of Agricultural Sciences.
Soriano, M., 1983, Hydrogeologic conditions at Carbareon waste-disposal site:
Company Report.
Zapp, A.D., Berguist, H.R., and Thomas, C.R., 1948, Tertiary geology of the
coastal plains of Puerto Rico: U.S. Geological Survey Oil and Gas
Investigation preliminary map 85, scale 1:60,000.
-------
APPENDIX A
TYPES OF INDUSTRIES SERVED BY PROTECO
-------
TABLE B-l
ftame of Industry
i
Abbott Chemicals
'Applied Magnetics
» •
fiayamon Electroplating
•
Becton-Dickinson
1
tarribbean Gulf Refining
Centronics
Checkpoint Systems
C.W. Caribe, Inc.
El Morro Corrugated
Box Corp.
i Lilly Industries, Inc.
\
Ex Lax
Instrumentation Laboratory
Livesavers
Johnson & Johnson
Mi Hi pore Corp.
Mobil Oil
Motorola Portavoz
Motorola Radiomovil
Motorola Radio Sintetizado
Motorola Telcarro
r -maseal
TYPE OF INDUSTRIES SERVICED
SIC Code Typical Manufactured Products
2834 Antibiotics,
Pharmaceutical Products
3679 Magnetic Recording Heads
3471 Metal Finishing-Electroplating
2834 Health Care Products-Thermometers
2911 Petroleum Refining
3679 Electronic Circuit Boards
3679 Electronic Secuirty Components
3679 Printed Circuits Manufacturing
2653 Corrugated Boxes
2834 Pharmaceutical Products
'2834 Laxitives
0
2819 Diagnostic Chemical Reagents
2067 Chewing Gum
3843 Dental Floss
3841 Membrane Filters & Associated
Devices
2911 Petroleum Refining
3666 Communication Devices & Components
3662 Two-way Radios
3651
3662, Mobile Communication Equipment
3666
3842 Disposable Medical Supplies
Typical
Wastes
Generated
F001
F002
D011
U151
D008
F001.D008
D002
F006.D008.DOO
D008
F003
F002
D002.D009
F002.D001
D001
0001
0008
»
0001,F002
0001,F001
0001,F001
F001
D001.F002.FOO
-------
B-4
TABLE b~l (CONTINUED)
TYPE OF INDUSTRIES SERVICED
fame of Industry
'roductos Circuitos de
PR, Inc.
leedco
Jyntex
"exaco
'icks, Inc.
fang
/aters
.«stern Fher
/estinghouse
SIC Code Typical Manufactured Products
3679 Printed Circuit Boards
•
2844 Pharmaceutical Products
2834 Pharmaceutical Products
5172 Petroleum Products
2834 Pharmaceutical Products
3573 Printed Circuit Boards and
Computer Products
3811 High Pressure Chromotography
Systems
,2834 Pharmaceutical Products
3622 Line Starters, Magnetic Contractor
Relays
Typical
Wastes
Generated
F006
D013
D001,D002,U04<
D008
D009
D001.DOOS
D001
D001.F002.FOO!
F002.D008
-------
APPENDIX B
PROPOSED CLOSURE SUMMARY
-------
Updated 04-22-80
TABLE 1 ,
PROfECO FACILITY STATUS AMD CLOSURE SUMMARY
Unit
1. Drum Burial Landfill II
(Cavldad 1C)
2. Drum Burial Landfill 12
(General Electric)
3. Drum Burial Landfill 13 (Roche)
4. Drum Storage Area (DE)
5. Drum Burial Landfill 15
(Searle)
6. Sanitary landfill (SL)
7. Neutralization Impoundment (LC)
8. Drum Burial Landfill 18
(Loctlte)
9. Oil Lagoon (LA)
10. Immobilization Facility (TIj)
Status
Pt. 265 Closure
Pt. 265 Closure
Pt. 265 Closure
Pt. 264 Closure
Pt. 265 Closure
Non-Hazardous
Pt. 264 Closure
Pt. 265 Closure
Pt. 264 Closure
Pt. 265 Closure
Closure Summary
Units 1,2 and 3 are outside of areas to be modified for
future disposal activities. These areas will be regrad-
ed for proper drainage and final cover and toe drains
will be constructed.
Included above.
Included above.
Must be relocated for landfill 1, Stage 1 to Temporary
Drum Storage Area 19.
Estimated 720 drums to be excavated; must be excavated
before construction of landfill 1, see also Un1t8
Proposed excavation and redlsposal In Unit 14 (Awaiting
EPA Approval).
Planned processing of all wastes through proposed
Facilities prior to excavation for Landfill 1, Stage 2.
Conflicts with proposed leachate management. The excava-
tion of an estimated 240 of drums will require the
expansion of Temporary Drum Storage Area 119.
Decanting of lower liquid layer to Rainwater Basin to
allow evaporation. Unit will then be processed through
proposed Stabilization/Fixation Facility.
Units 10, 11 and 12 will be tested to determine If they
are acceptable for direct landfill disposal.
(0936B-1
-------
Unit
11. Immobilization Facility (TI2)
\
12. Land Treatment Area (ACjP
13. Rainwater Basin (LB)
14. Land Treatment Area (AC?)
15. Tank Storage
ISA. Tank Storage Area
16. Immobilization Facility (TI3)
TABLE 1 (CONiINUED)
PROTECO FACILITY STATUS AND CLOSURE SUMMARY
i
Status
Pt. 265 Closure
Pt. 265 Closure
Pt. 264 Closure
Special Status
Pt. 264 Closure
Pt. 264 Closure
Pt. 264 Closure
17. Neutralization Impoundment (LF) Pt. 264 Closure
Closure Summary
19. Temporary Drum Storage Area
As Per Consent Agreement
See unit 10.
See unit 10. •
This unit will be the last existing unit to be processed
through the proposed facilities to allow as much evapo-
ration as possible to occur.
Regradlng to promote proper drainage and cap of existing
waste with 3ft of clay. Facility would then continue
use as sanitary landfill upon EPA approval.
Only one tank Is awaiting closure. The tank w111 be
decontaminated, crushed and sold as scrap or disposed of
In an on-slte landfill.
To be used for on-slte generated hazardous waste dispo-
sal. Interim cap to be constructed prior to excavation
for proposed Landfill 2.
Relocation of liquids to rainwater basin and construc-
tion of Interim cap. Area will eventually be excavated
for proposed Landfill 2.
The proposed expansion of this facility will be used for
temporary storage of Inventory from Unit 4, and excavat-
ed drums from Units 5 and 8. The drums will then be
processed through proposed facilities.prior to excava-
tion of proposed Landfill 2.
(0936B-2)
-------
APPENDIX C
PROPOSED CLOSURE SCHEDULE
-------
-LJ—
Ngv Construction
Local Permitting
and Construction of
Cont. Sto. Facility
and Tank Fare
Local Permitting and
Construction of Stab/Flu.
Facility
Conitnictlon of
Landfill 1 (LF-1)
and
Leachate Pondt A i R
Temp, Or. Sto. Area 19
FIGURE 1
TENTATIVE
INTEGRATED CLOSURE AND NEW FACILITIES
CONSTRUCTION SCHEDULE
0 2 4 '« 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42 44 46 48 50 S2 54 56 58 60
HONTHS
EPA approval of Cont. Sto. Facility and Tank Farm
EPA approval of Stab/Fix, facility
EPA approval of landfill
I Staot 1 i 2 Bottom Llntr Staae 243 Bottom Untr
Ponds A i B
UNIT
CLOSURE
1,2.3 OHM Burial Landfill!
4 Drum Storagt Arta (OE)
5.8 Drum Burial Landfill*
7 Neutralfiatton
Impoundment (LC)
9 Oil Ugoon (LA)
10 Innobntzation
Facility (Til)
11 Immobilization
Facility (112)
2*3
(CW7B-1)
-------
12 Land Treatment
Area (AC-D
13 Rainwater Basin
(LB)
14 Land Treatoent
Arc* (AC-Z)
15.ISA Tank Storage
16 IfwoblHiatlon
Facility
-------
Appendix r>
T-Tork/oz\ Sampling ^
-------
Work/QA Sampling Plan
for the
Groundwater Task Force Inspection
at
Proteccion Tecnica Ecologica, Inc.
(AKA Servicios Carbareon)
Prepared by: Joseph Cosentino -ESD/SWB
Louis DiGuaraia -ESU/SMB
Fred Haber -ESD/MHB
-------
Table ot Contents
Page
1. Project Name 1
2. Project Requested By 1
3. Date of Request..... 1
4. Date of Project Initiation 1
5. Project Officer 1
6 . Quality Assurance Officer 1
7. Project Description
A. Objective and Scope 2
B. Data Usage 3
C. Monitoring Network Design and Rationale 4-5
D. Monitoring Parameters and Frequency of Collection 6
E. Parameter Table 7
8. Project Organization and Responsibility 8
9. Data Quality Requirements and Assessments 9
10.
11.
12. Sampling Procedures 10
Pre-Sampling activities 11-12
Site Safety 13-14
Protocol for Well Purging 15-16
Sample Collection 17
Split and Replicate Samples 18
Field Measurements 19
QA/QC Measures 20-21
Equipment List 22-23
i.
-------
13. Sample Custody Procedures 24
Sample Handling and Shipment 25-26
14. Calibration Procedures ana Preventive Maintenance 27
15. Document, Data Reduction and Reporting 27
16. Data Validation 27
17. Performance ana Systems Audits... 27
18. Corrective Action 27
19. Reports... 27
ii.
-------
1. Project Name: Groundwater Task Force Inspection at Proteccion Tecnica
Ecologies, Inc.
2. Project Requested By: Region II, Solid Waste Branch
3. Date of Request: August 16 ,1985
A. Date of Project Initiation: October 1, 1985
5. Project Officer: Richard Walka, Region II, SWB
6. Quality Assurance Officer: Fred Haber, Region II, ESP
-------
- 2 -
7. Project Description;
A. Objective and Scope:
This project plan will address the sampling activities to be conducted at
Servicios Carbareon in order to determine if the hazardous waste disposal, storage
and treatment activities conducted at this site and regulated by the Resource
Conservation and Recovery Act (RCRA P.L. 94-580) have impacted the quality of
groundwater underlying this facility. The primary objective of these efforts is
to determine compliance with the requirements of 40 CFR, Part 265, Subpart F -
Groundwater Monitoring and potential compliance with the requirements of 40 CFR,
Part 264, Standards for Owners and Operators of Hazardous Waste Treatment, Storage
and Disposal Facilities. Specifically, the sampling of designated RCRA groundwater
monitoring wells will determine the following;
1. If the designated RCRA monitoring wells are properly located and
and constructed (to the extent possible) so that the system
can immediately detect any statistically significant amounts
of hazardous waste or hazardous waste constituents that
migrate from the waste management area to the uppermost
aquifer underlying the facility
2. contamination of the underlying grouodwater exists at this
facility
In order to fulfill the above objectives this inspection will include the sampling
of all RCRA designated groundwater monitoring wells deemed by the inspection team
to be adequately located, installed, constructed, developed and capable of yielding
representative samples and significant results. If the groundwater monitoring
system at the facility is deemed inadequate and sampling will not yield any signif-
icant results then the inspection should be delayed until the facility has installed
an acceptable groundwater monitoring system. The sampling aspects of this inspec-
tion will focus on obtaining the following information:
1. monitoring well locations, construction materials, casing sizes
depths and static water levels
2. the location of existing RCRA regulated hazardous waste units and
extent of hazardous waste management area
3. groundwater contamination resulting from site operations
4. the size and type of containers, sample preservation techniques and
chain of custody procedures used by the facility for split and/or
replicate samples
5. the results of the facility's analysis of replicate samples
-------
- 3 -
B. Data Usage:
The data generated by the monitoring activities will be utilized to determine;
1. the depth to static water level at each well and estimated
direction of groundwater flow
2. the total depth of each well
3. if well construction materials are suited for monitoring the
constituents of interest in the hydrogeologic environment at
Servicios Carbareon
4. if the wells are constructed and protected in a way as to secure
them from tampering and accidential collison
5. the adequacy of the facility's groundwater monitoring system to
immediately detect any statistically significant amounts of haz-
ardous wastes or hazardous waste constituents that migrate from
the waste management area to the uppermost aquifier underlying
the facility
6. if the wells are constructed to function through the active life
and post closure monitoring period for the facility
7. the need for additional sampling, (ie: areas of suspected prior
releases, improper disposal, vadose zone monitoring and areas
of surface water run-off)
8. the need for a comprehensive review of the facility's sampling
and analysis plan
9. the need for a comprehensive laboratory evaluation, ie: appendix
VIII compoumds.
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- 4 -
C. Monitoring Network Design and Rationale
Servicios Carbareon presently has a groundwater monitoring system consisting of
four (4) monitoring wells. There is one (1) upgradient well, designated as monitor-
ing well 11W-&3 and three (3) downgradient welis designated as wells IW-bl, 2W-81
and 12W-83. These wells were constructed of 2.5 inch PVC, slotted with a hand saw
prior to installation and vary in depth from 175 ft. to 240 ft. below the land
surface. The column of standing or static water in these wells ranges from 21 feet
to 164 feet. The location of these wells is depicted in Figure 1. Based upon the
results of past EPA, Region 11 sampling activities these wells appear to be rela-
tively free of organics contamination, with bis(2-ethylhexyl)phthalate, butyl
benzyl phthalate, di-n-butyl phthalate, 1,1,1-trichloroethane and 1,1-dichloro-
ethane being found in the parts per billion range. These results are attached as
Appendix 1.
This RCRA groundwater monitoring system, however, is inadequate in light of hydro-
geologic conditions at the site, well construction materials, construction tech-
niques, well locations and well depths. The facility has until November 8, 1985
to install an acceptable and approved groundwater monitoring system or be faced
with the loss of interim status and possible closure of the facility. At present
the facility has undertaken an effort to install a RCRA groundwater monitoring
system that has been tentatively deemed to be adequate by EQB, EPA, Region II and
EPA, Washington personnel. This system will include three (3) 2.0 inch wells,
constructed of teflon and located hydraulicaily downgradient of each hazardous
waste management unit and two (2) monitoring wells constructed hydraulicaily
upgradient of potential site influence. In all there are three (3) hazardous
waste management units that require groundwater monitoring in accordance with
Subpart F requirements. They include: the rainwater lagoon, immobilization
area and land application area. All other existing hazardous waste management
units are or will be closed. A site map and legend are attached as Figure 2. In
addition, two (2) PVC observation wells will be installed.
The groundwater monitoring system presently in existence at Servicios Carbareon
has been deemed to be an inadequate system. The only useful results and
conclusions that could be drawn from the sampling of these wells would be to
determine the quality and reliability of past sampling techniques and analytical
procedures. The primary sampling objective at this site will be to sample the
twelve (12) new teflon wells, provided they are installed and properly developed
prior to the start of this inspection.
The facility has identified two (2) groundwater occurrences beneath this site.
The first occurrence is found at a depth of between fifty (50) to sixty (60)
feet and is believed to be isolated bodies of perched water. These occurrences
are believed to be sea water that was trapped in the sediments after the geo-
logic unit lifted from the sea. The second groundwater occurrence is found at
a depth of about two hundred (200) feet. This occurrence is found in the thick
muds tone units of Che Juana Diaz Formation and demonstrates groundwater move-
ment. It is unknown, at this time, which of the new wells will intercept the
shallow perched water bodies and which will intercept the deep groundwater oc-
curence. This will not be known until the wells are actually drilled. If a
-------
- 5 -
perched water body is not intercepted during drilling the well will be drilled
to the deep grouadwater occur tenet;.
Upgradient wells - samples ot grouodwater from these wells will establish ground-
water quality prior to site influence. The analytical data obtained from these
samples will be used as a basis for determining if a statistically significant
increase in indicator parameters (pH, TOC, TOX and specific conductivity) or haz-
ardous constituents can be detected in downgradient wells.
Downgradient wells - samples of groundwater from these wells will determine the
facility's impact on the groundwater underlying this site.
Previously installed wells - samples from these wells can be used to determine
the possible quality and reliability of past sampling techniques and analytical
procedures.
Physical measurements - such as: well depth, casing size, construction material
and location will help to establish the adequacy of the monitoring system's ability
to immediately detect any significant amounts of hazardous waste or hazardous
waste constituents that migrate from the hazardous waste management area to the
uppermost aquifer. Static water levels will be used to establish groundwater
flow direction.
It should be anticipated that a total of fifteen (15) groundwater monitoring
wells will be sampled. The wells selected are as follows:
- Two (2) new upgradient wells (2.0 in., teflon)
- Nine (9) new downgradient wells (2.0 in., teflon)
- One (1) old upgradient well (2.5 in., PVC)
- Three (3) old downgradient well (2.5 in., PVC)
The actual depth and location of the new wells is, at this time, unknown. This
information will be provided at a later date. It can be anticipated, however,
that all fifteen (15) wells will be deep, approximately two-hundred (200) feet.
Vehicle access to all of the wells will not be a problem. Sampling parameters
will be the RCRA indicator parameters, groundwater quality parameters, metals
(dissolved and total) and organics (NVOA and POA). A complete parameter list
is attached.
-------
-------
Fioure - 2
Servlcloe Carbareon.Inc.
Site Map Legend
1 - Landfill, drun burial
2 - Landfill, drun. burial
3 - Landfill, drua burial
4 - Dnm storage area
5 - Landfill, drue burial
6 - Sanitary landfill
7 - Lagoon, corrosive vaste
8 - Landfill, drum burial
9 - Lagoon, oil
10 - Immobilization area
11 - Immobilization area
12 - Land application area
13 - Lagoon, rainwater
14 - Land application
15 - Tank ctorage area
16 - Immobilization area
17 — Surface impoundment (future)
18 - Immobilization area expansion (proposed)
19 - Immobilization area expansion (proposed)
20 - Corrosive lagoon expansion (proposed)
21 * Drum storage area (proposed)
22 - Lagoon, rainwater (proposed)
-------
— SFRVICIOS CARBAREON, INC,—
FACILITY
regulated hazardous waste
-------
- 6 -
D. Monitoring Parameters and Frequency of Collection;
A list of the parameters of interest is attached as Appendix 2. Each well
will be sampled once and the samples analyzed for all parameters of interest
for which contractuial arrangements have been made. In addition, split or
replicate samples will be offered to Servicios Carbareon as requested.
There are a total 15 individual sampling locations from which samples will
be collected and analyzed. Samples from each sampling location will be
analyaed for the entire hazardous substance list (HSL) organic and inorganic
parameters.
-------
E. Parameter Table:
Analytical
Number ol Method Sample Holding
Parameter Samples Sample Matrix Reference Preservation Time
See 15 See footnote See attachment 1 - Statement of Work
Attached plus below* for Organic and Inorganic Analyses
Parameter QC
List samples
* Samples will be fresh and salt water, depending on whether lower or
upper aquifer is sampled. The exact groundwater currents that will
be monitored are unknown at this time.
-------
10. Project Organization and Responsibility:
The following is a list of itey project personnel and their corresponding
responsibilities:
Joseph Cosentino (ESP)
- sampling operations
Joseph Cosentino/John Winter
- sampling QC
Stan Kovell (EPA/HQ)
- laboratory analysis
Paul Freedman (OWS)
- laboratory QC
Rich Walka/Ton Moy (SWB)
- data processing activities
Rich Walka/Ton Moy
- data processing QC
ICAIR/Life Systems
- data quality review
John Winters (EHSL-Cincinnati)
- performance auditing
Garreth Pearson (EMSL-Las Vagas) - systems auditing
Fred Haber/Florence Richardson
- QA activities review
Ton Moy (SWB)
- overall project coordination
-------
- 9 -
11. Data Quality Requirements and Assessments
Sample Detection Quantitation Estimated Accuracy Estimated Precision
Parameter Matrix Limit Limit Accuracy Protocol Precision Protocol
See *See
Attached Foot- (See Statements of Work lor Organics and Inorganics Analyses)
Parameter note Attachment 1
List below
Data Representativeness - See Section 3.4 of HQ QA Project Plan (Attachment 2);
representativeness can be accomplished only if all new wells are in place, fully
developed and chemically stable.
Data Comparability - See Section 3.6 of HQ QA Project Plan (Attachment). This
applies only if all new wells are in place, fully developed and chemically
stable.
Data Completeness - See Section 3.5 and 12.1.3 of HQ QA Project Plan.
* Samples will be fresh or salt water depending on whether upper or lower
aquifer is sampled. The exact ground water currents that will be monitored
are unknown at this time.
-------
- lu -
12. Sampling Procedures:
During this inspection, samples will be collected ana analyzed from designated
RCRA monitoring veils to determine if the groundwater beneath the site contains
hazardous waste constituents or other indicators of contamination.
A total of fifteen (15) wells have been tentatively selected for sampling. As
the primary objective of well sampling is to obtain representative samples of
the underlying groundwater, well selection will be made in the the field based
on the following criteria:
1. Wells hydraulically upgradient and downgradient of the RCRA
regulated hazardous waste units.
2. Wells that have been properly located, constructed and developed
prior to the start of on-site sampling activities.
Wells not meeting the above criteria will only be sampled to compare data
to existing facility records and reports (ie: previously generated ground-
water data).
All sampling activities will be conducted by the EPA sampling contractor,
(Versar, Inc.). The contractor will supply all equipment and materials
necessary to collect, handle, document and ship the required samples. All
samples will be shipped to contractor laboratories and analyzed for the
constituents listed in Appendix 2. Samples collected for inorganic analyses
are to be shipped to Rocky Mountain Analytical and samples collected for
organic analyses are to be shipped to California Analytical.
-------
- 11 -
Pre-Sampllng activities:
In preparation for sampling activities, the following equipment and
materials are required to be assembled and prepared as follows:
1. All equipment shall be assembled and compared to a master
equipment checklist.
2. All equipment shall be labeled and given an identification
number prior to field use. Back-up equipment and spare parts
should also be brought to the field.
3. All equipment that will potentially contact the sampling
media will be cleaned/decontaminated. This will include
a thorough washing with hot water and a non-phosphate soap
or detergent followed by successive rinses with an appro-
priate solvent. This equipment will then be air dried and
wrapped in aluminum foil.
4. The equipment should be packaged and shipped in such a man-
ner as to minimize damage and loss. Shipment of equipment
should take place prior to the arrival of the sampling team
and a team member should be on hand to insure equipment ar-
rival. All equipment should be checked and any mechanical
or electrical equipment tested prior to team arrival.
5. All equipment not amenable to shipping, ie: acids, gases
and solvents, should be located and purchased prior to the
arrival of the sampling team. Disposal of these items
must also be considered and an appropriate disposal method
found.
6. Logistics concerning the shipment of samples, le: flight
times and location of vendor sevices, must be known and
secured prior to team arrival. The availability of these
services together with sample holding times will dictate the
amount of time that can be dedicated to field sampling activ-
ities.
7. Logistics concerning equipment storage and transport must
also be considered and resolved prior to the arrival of the
sampling team.
8. The entire sampling team should arrive and assemble at a
common location at least one day prior to the start of
on-site activities in order to discuss team objectives,
procedures and resolve any overlooked logistics.
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- 12 -
An assessment of the areas of on-site sampling using HNUs and
OVAs will be conducted prior to the start of field sampling.
This assessment will dictate the level of personnal protection,
ie: SCBAs, respirators, tyvek... ect., needed by team members
to enter the work areas. Verification of well existence and
location will also result from this assessment, A well location
map will be constructed at this time.
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VELL VOLUME (gallons)
Fig-ore - 3
2.51
Well Diameter (inches)
3.5" 4" 4.5'
.09
.17
.25
.33
.42
.50
.56
.66
.75
.83
.91
1.00
1.07
1.16.
1.24
1.32
1.40
1.49
1.57
1.65
1.73
1.62
1.90
1.97
.13
.26
.39
.50
.64
.77
.90
1.02
1.15
1.28
1.40
1.53
1.66
1.78
1.91
2.04
2.17
2.29
2.42
2.55
2.68
2.80
2.93
3.05
.20
.37
.55
.75
.92
1.13
1.30
1.47
1.65
1.84
2.02
2.20
2.40
2.57
2.77
2.94
3.15
3.33
3.52
3.67
3.82
4.04
4.19
4.41
.26
.50
.75
1.00
1.26
1.50
1.73
2.02
2.25
2.47
2.77
3.00
3.30
3.52
3.75
4.04
4.27
4.49
4.79
5.02
5.24
5.54
5.77
5.98
.32
.65
1.00
1.30
1.6
1.9
2.3
2.6
2.9
3.2
3.5
4.2
4.2
4.5
4.8
5.1
5.4
5.8
6.1
6.4
6.7
7.0
7.3
7.7
.42
.83
1.3
1.7
2.1
2.5
2.9
3.3
3.7
4.1
4.5
5.0
5.4
5.8
6.2
6.6
7.0
7.5
7.9
8.3
8.7
9.1
9.5
10.0
.50
1.0
1.5
2.1
2.6
3.1
3.6
4.1
4.6
5.1
5.6
6.1
6.7
7.2
7.6
8.1
8.6
9.1
9.6
10.1
10.7
11.1
11.6
12.2
.75
1.5
2.2
2.9
3.7
4.4
5.1
5.9
6.6
7.3
8.1
8.7
9.5
10.5
10.9
11.6
12.4
13.1
13.8
14.6
15.3
15.8
16.7
17.5
0.5
1.0
1.5
2.0
2.5
3.0
3.5
4.0
4.5
'>.0
j.5
6.0
6.5
7.0
7.5
8.0
8.5
9.0
9.5
10.0
10.5
11.0
1.5
.2.0
-------
WELL VOLUME (gallons)
2"
2.5
Veil Diameter (inches)
3" 3.5- 4'
4.5'
6"
2.06
2.31
2.53
2.64
2.80
2.97
3.13
3.30
3.46
3.62
3.79
3.95
4.12
4.28
•
4.45
4.62
4.78
4.94
5.11
5.27
5.44
5.60
5.77
3.31
3.57
3.82
4.07
4.33
-4-r5fe
4.84
5.09
5.35
5.60
5.86
6.11
6.36
6.62
6.87
7.13
7.38
7.64
7.86
8.16
8.38
8.68
8.91
4.79
5.17
5.50
5.87
6.21
6.59
6.96
7.34
7.71
6.08
8.46
8.83
9.13
9.51
9.88
10.25
10.63
11.00
11.38
11.75
12.12
12.50
12.87
6.51
7.04
7.49
8.01
8.53
9.06
9.50
10.03
10.55
11.00
11.53
12.05
12.50
13.02
13.55
14.07
14.52
15.04
15.72
16.00
16.54
17.06
17.51
8.3
£.9
9.6
10.1
10.8
11.5
12.1
12.7
13.4
14.0
14.6
15.3
15.9
16.5
17.2
17.8
18.5
19.1
19.7
20.3
21.0
21.6
22.3
10.7
11.5
12.3
13.2
14.0
14.8
15.7
16.5
17.3
18.1
19.0
19.8
20.6
21.14
22.2
23.0
23.9
24.7
25.5
26.4
27.2
28.0
28.6
13.1
14.2
15.2
16.2
17.2
18.2
19.2
20.5
21.1
22.3
23.2
24.3
25.3
26.3
27.3
28.3
29.3
30.3
31.3
32.3
33.3
34.4
35.4
18.9
20.4
21.8
23.2
24.7
26.2
27.7
29.1
30.5
29.1
33.4
34.8
36.3
37.8
39.3
40.7
42.2
43.6
45.0
46.4
47.9
49.4
50.8
13.0
14.0
15.0
16.0
17.0
J8.0
19.0
20.0
21.0
22.0
23.0
24.0
25.0
26.0
27.0
28.0
29.0
30.0
31.0
32.0
33.0
34.0
35.0
j
s
I
-------
- lii -
Site Safety:
As a rule, all wells should be assumed to pose a health and safety
risk. Therefore, the area immediately surrounding each well (ie:
breathing zone) will be monitored with OVA and HNU to determine
appropriate safety gear. The level of protection needed will be
determined by the following breathing zone measurements:
Level C Protection (full face respirator) - Above ambient
(ofi-site OVA ana HNU readings) but less than 5 ppm.
Level B Protection (self-contained breathing appartus) -
Greater than 5 ppm above ambient.
At a minimum all team members entering the active portion of the site
will be equipped witn a fit tested full-face respirator, safety shoes,
hard hat, safety glasses and a long sleeved shirt. In addition, all
team members entering the active portion of the site or engaging in
sampling activities will have completed the necessary Health and Safety
Training for Field Employees as dictated by EPA Order 4014.2.
-------
- 14 -
Safety:
Emergency phone numbers and locations
"Police
Name - Department of Police
Phone number - 636-1010
Location - Pedro Velasquez Diaz St.
Penuelas, P.R.
cFire
Name - Department of Fire
Phone number - 836-2330
Location - Doctor Loyola St.
Penuelas, P.R.
"Injury or Illness
Name - Hospital de Damas
Phone number - 843-5151
Location - Highway 2
Ponce, P.R.
Name - Department of Health
Phone number - 836-1651 location - Penuelas Medical Center
Location - Peneulas Medical Center
Penuelas, P.R.
Name - Tito Mattey Hospital
Phone number - 856-2105
Location - carreterra 128, km 1.0
Yauco, P.R.
-------
- 15 -
Protocol for Veil Purging
The following sequence of operations should be followed:
1) Properly locate and identify monitoring well
2) Remove the locking cap and/or protective cap. If needed, the exterior
and interior of the exposed riser pipe of the monitoring well should
be wiped wich filter paper ana deionized water.
3) Use air detection equipment (i.e. OVA, END) on the escaping gases at
the well head to determine the need and/or level of respiratory
protection. Record reading in field notebook.
4) Use an interface probe and/or a bottom loading teflon bailer
with teflon coated or stainless steel wire to determine the
presence of a immiscible phase. Record findings in field note-
book.
5) Using a clean weighted steel measuring tape, level indicator and/or
acoustic sounder, determine the following physical measurements:
a) well and casing diameter
b) static water level from the top of the casing
c) total depth of well
Record all measurements in field notebook and/or Well Monitoring
Data Sheet.
6) Calculate static volume in gallons using tables such as presented
in Figure 3.
7) Using the same bottom loading teflon bailer used in determining if a
immiscible layer is present, or dedicated bladder pump, begin removal
of water from well. During evacuation, lower purging equipment or
intake into the well to a short distance below the water level and
begin water removal. Lower purging device as required to maintain
submergence. Collect purge water in 55-gallon drums. The project
coordinator will determine an appropriate disposal procedure.
8) During the above operation, the following information should be
recorded in a field notebook or on Monitoring Well Data Sheet
(attached as Appendix A):
a) purging times, beginning and ending
b) general characteristic of water being removed (i.e., color, odor,
turbidity, etc...)
-------
- 16 -
c) rate of discharge measured in a calibrated stainless steel
bucket
d) volume of water in casing
e) volume of water removed from well
9) The procedure for well purging is dependent upon the yield of the
well.
- In low yield wells, the wells should be evacuated to dryness
once and as soon as the well recovers, the first set of para-
meters taken are those pH and volatile sensitive.
- During long recovery times, pH and pressure sensitive parameters,
if possible, should not be taken more than three hours after
evacuation to dryness. The additional parameters should be
taken as water becomes available.
- For rapidly recharging wells, water should continue to be removed
as it recharges until three (3) well volumes have been removed
prior to sampling.
-------
- 17 -
Sample Collection:
Sample with a bottom loading terlon bailer according to the following
procedure:
a) Select cleansed dedicated teflon oailer.
b) Attach bailer to either a cleansed stainless steel, teflon coated
stainless steel or monofilament line.
c) Lower bailer slowly until it contacts water surface.
d) Allow bailer to sink and fill with a au.nimum of surface disturbance.
e) Slowly raise bailer to surface. Do not allow bailer line to
contact ground. Place baxler line on protective liner. Discard
first volume collected in bailer.
f) Begin sampling using a teflon coated bottom valve attached to
bailer for sample removal. Avoid as much as possible turbulence
of sample in transfer from bailer to sample container.
g) Repeat steps b-f as needed to acquire sufficient volume.
h) Contain and preserve samples according to guidelines specified
by the contract laboratory.
i) Measure in-situ parameters: pH, specific conductivety and temp-
erature.
j) Label the sample bottles with the following information:
Well name and/or site number
Locality
Date: Time:
Traffic Report number
Analysis Requested (i.e., metals, VGA, etc...)
Preservative (if required)
Record the information in the field notebook and complete all
Traffic Reports (Inorganic and Organic), and Chain of Custody
Records.
k) Place the properly labeled sample bottle in a metal or plastic
cooler maintained at 4°C throughout the sampling and transpor-
tation period.
-------
- 18 -
Split and Replicate Samples:
Samples will be split with Servicios Carbareon where possible, however
for pressure sensitive (volatile) sample parameters, such as: TOG, TOX
and volatile organics, replicate samples will be provided. Split sampl-
ing procedures call for the transfer of the collected media to a large
common container. Once a sufficient volume has been collected the indi-
vidual sample aliquots are poured off. This practice increases the
chances of cross contamination and the loss of volatiles. Therefore,
samples collected for these parameters will only be split if bailer
volumes allow.
The EPA sampling contractor will provide sample containers sufficient
for split or replicate samples and large volume containers for split-
ing samples.
-------
- 19 -
Field measurements:
During the sampling of each well three in-situ parameters will be
measured: temperature, pH and specific conductivity. A seperate
sample will be withdrawn from the well and transtered to a beaker.
Direct reading instruments will be used and the results recorded
in a field notebook.
All instruments will be calibrated prior to use and calibration
information recorded in a field notebook. Calibration of the
pH meters will utilize three (3) buffers: pH 4, 7 and 10. The
thermometers or temperature measuring instrument instruments
will be calibrated against an NBS certified or NBS traceable
thermometer prior to field activities and the results recorded.
The conductivity meters will be calibrated prior to use according
to the manufacturers instructions. The person performing the
calibration will initial the results recorded.
All instruments and equipment will be marked so that each piece
can be identified and its use recorded.
-------
- 20 -
Quality Assurance/Quality Control Measures:
The sampling activities conducted during this inspection will be
supported by preparing and analysing several sets of quality control
(QC) samples and adherence to quality assurance measures. The field
QC samples will include the following types:
0 Trip blanks - will be used to determine if contamination is
introduced to the sample containers during handling, trans-
port and storage. These blanks will be prepared by the sampl-
ing ttaci. They are prepared by using distilled deionized water
of known high purity, and are sent with sampling equipment and
other bottles into the field. One set of trip blanks will be
prepared for each parameter group, (ie: metals, NVOA... ect.),
and shipped once during toe inspection.
0 Field blanks - will be used to determine if contamination is
introduced by sample collection activities or sampling environ-
ment. They are prepared by bringing a quantity of distilled
deionized water and using this water to prepare aliquots for
each parameter group, while in the field. This is the respon-
sibility of the sampling team and will be done once each day
during the inspection.
0 Equipment blanks - will be used to determine if contamination
is introduced by the sampling equipment. They are prepared
by passing a quantity of distilled deionized water over the
sampling apparatus prior to field use and collecting aliquots
for each parameter group. This is the responsibility of the
sampling team and will be done once during each day of sampling.
It should be stressed that all field QC blanks must be submitted in
the same manner as the field samples, with no distinguishing labeling
or markings. Care should be taken to insure that the contract lab-
oratory does not use a blank for matrix spike.
0 Duplicate Samples - will be collected for each parameter. This
will be done once for each set of parameters per ten (10) sampl-
ing locations.
-------
In addition to the above, the following techniques and procedures will
be adhered to during the sampling activities ot this inspection to
insure sample integrity and representativeness:
0 Equipment such as bailers, bladder pumps and bailer wire will be
dedicated to evacuation or sampling at each well. This will
minimize the need for decontamination and chances of cross con-
tamination during sampling activities.
0 Sampling equipment will be constructed of materials compatible
with the parameters or concern at this site. Teflon and/or
stainless steel are the recommended materials and all equipment
contacting the groundwater will be fabricated of this material.
0 Prior to shipment all equipment that will contact the sampling
media: bailers, pumps, bailer cord/wire, well tape.... etc.,
will be cleaned and decontaminated. This procedure will include a
thorough washing with hot water and a non-phosphate detergent,
followed by successive rinses with deionized water and an appropriate
solvent: acetone, methylene chloride or hexane. The equipment will
then be air dried an wrapped with aluminum foil prior to packaging.
0 Gloves and any soiled outer garments will be removed and dis-
carded between evacuation and sampling at each and between each
well. This will be done to minimize the chances of cross con-
tamination between wells and purging and sampling.
0 The wells will be sampled in the order of least to most contaminated
(if such information is available).
-------
- 22 -
Equipment list:
Personal
hard hats
satety glasses
steel toed safety shoes
rubber boots (safety toe)
disposable booties
coveralls
tyvek (regular and polylaminated)
chemical protection suits
self contained breathing apparatub and air tanks
duct tape
gloves (butyl rubber, neoprene, nitrile)
rainsuits
cartridge respirator (dust, organic vapor, acid mist)
first aid kits
knife
flash light
valkie talkies
0 Sampling
OVA
HNU
interface probe
bottom loading teflon bailers and teflon bladder pumps and bailers
teflon coated wire, stainless steel wire or monofilament line
crank or winch
well measuring tape
carpenters chalk
water level indicator or sounder
55 gallon steel or plastic drums
stainless steel buckets
pH meters, spare probes and batteries
buffers (4, 7 and 10)
distilled deionized water
thermometers
conductivity meters and calibration standards
plastic sheets/ground cloth
plastic bags (garbage and sample size)
plastic bags (ice)
whirl pacs or zip lock bags for VGA vials
ice chests or coolers (metal)
sample containers (plastic and glass)
caps and liners
filters and filtering apparatus for dissolved metals
-------
decon
tubs or buckets
distilled deionized water
sprayers
tap water
sponges and brushes
hexane
non-phosphate detergent (Alconox)
paper towels, kim-wipes or kay-dries
Documentation
caneras and film
field notebooks
custody tape
wire sealers
chain-of-custody forms
traffic reports
receipt for samples
field data sheets
label tape or tags
Miscellaneous
preseratives
pH paper
diaposable pipets
vermiculite or other packing material
electrical tape
fiber tape
compass
waterproof markers
pens (black)
-------
13. Sample Custody Procedures
The field sampler will be personally responsible for the care and custody of all
samples until they are properly dispatched. After collection, identification and
decontamination the samples will be maintained under Chain-oi-Custody procedures.
Sample tags or labels will be completed using water-proof ink. All sample ship-
ments will be accompanied by a Chain-of-Custody record, provided by the contractor,
identifying their contents. If the samples are split with the facility or other
regulatory agency, it will be recorded on the custody record. The original
Chain-of-Custody record will accompany each shipment, a copy of which will be
provided to the project, coordinator. Each shipping container shall be sealed
with custody tape upon completion of packing and insertion of custody records.
Chain-of-Custody procedures to be followed will be based upon NE1C policies and
procedures as described in: "Enforcement Considerations for Evaluation of Un-
controlled Hazardous Waste Disposal Sites by Contractors", U.S. EPA; NE1C, 1980.
When samples are received by the contractor laboratory, the analyst, after signing,
retains a copy of the custody record for the laboratory's files and returns the
original to the project coordinator or designated document control officer.
Serialized Chain-of-Custody records will be assigned and accounted for in a
field notebook. These documents will contain the following information for
each sampling point:
0 Project code number
0 Sample number
0 Station designation (sample location, well number)
0 Date and time of collection
0 Sample type (grab)
0 Signature of sampler
0 Additional remarks (samples split and with whom)
As required under section 3007 (a) of RCRA, a Receipt for Samples will be used
to document all samples collected. This document will be signed and dated by
facility personnel. A copy will be given to Servicios Carbareon and the originals
given to the project coordinator.
The above documents, Chain-of Custody and Receipt for Samples, will be provided
by the sampling contractor. A sample EPA, Region II Chain-of-Custody form and
sample traffic reports are attached as Appendix 3.
-------
- 25 -
Sample Handling and Shipment:
Samples from groundwater monitoring wells are and will be considered "environ-
mental" samples. Environmental samples are not hazardous materials, and conse-
quently they are not subject to DOT hazardous materials transport regulations.
These samples will be handled and shipped according to the procedures detailed
below:
1. Sample volumes and containers will be specified by the analytical
methods. However, plastic containers should be used unless the
speciiic analytical method requires glass. All sample containers
should have screw type lids and appropriate liners, ie; teflon.
Container lids must fit tightly to prevent sample leakage. Sample
volumes should be limited to the quantity necessary to conduct the
required analysis and appropriate QA/QC. All sample containers will
be prepared by I Chem Company. Random containers are selected and
analyzed for cleanliness. Versar receives containers from I Chem,
supplies ORD with bottles to be used for performance evaluation
samples. Sample bottles and performance evaluation samples are
taken by Versar to site.
2. All sample containers will be identified with a sample tag or label
at the time of collection.
3. Preservation, if required, will take place immediately after col-
lection.
4. After preservation all containers will be decontaminated by washing
with water and a non-phosphate detergent. Each sample will then
be placed in a plastic bag and sealed with water-proof tape. In
addition, custody tape will also be used.
5. The sample containers will be placed inside a clean metal cooler.
Appropriate cushioning, absorbent and ice (if required) will be
placed in each cooler to minimize the possibility of breakage and
leakage. If preservation by ice is required the ice will be placed
in sturdy plastic bags to minimize ice water leakage.
6. After all the samples have been carefully arranged and ice added,
the Chain-of-Custody form corresponding to the samples contained in
the cooler will be sealed in a plastic bag and taped to the inside
surface of the cooler lid.
7. The shipping containers will be closed, sealed with a wire sealer/
fiber tape and custody tape.
8. Each container will be labeled to reflect container number and size
of shipment, ie: 1 of X, where X equals total number of containers
-------
being shipped. Each shipping container will be marked " This End
Up" with arrows indicating the proper upward position of the con-
tainer. In addition, a label indicating the responsible Agency's
name, address ancJ telephone number will be placed on the outside
of each shipping container.
8. A team member must accompany each shipment to the carrier and, if
required, be prepared to open and reseal the containers should the
carrier request an inspection of its contents.
-------
- 27 -
14. Calibration Procedures and Preventive Maintenance - See Field Measure-
ments Section of this Project Plan and Sections of Statements of Work
for Organic and Inorganic Analysis referenced by Section 6.0 of HQ QA
Project Plan.
15. Documentation, Data Reduction and Reporting
A. Documentation
Sampling and Field Activities: See Section 7.4 and 7.5.3 of "Revised
Draft Protocol for Ground Water Inspections at Hazardous Waste Treat-
ment, Storage and Disposal Facilities" (.Attachment).
Laboratory Activities: See IFB document WA 84-A267 referenced by
Statements of Work tor Organic and WA84-J092 referenced by Statement
of Work for Inorganic Analysis.
B. Data Reduction and Reporting: See Section 8.2 of HQ QA Project Plan
which references various parts of the Statements of Work for the
various categories of analysis.
16. Data Validation: See Sectioin 8.3 of HQ QA Project Plan; validation to
be performed by ICAIK/Life Systems.
•
17. Performance and Systems Audits - Systems audits performed by EMSL-Las
Vegas; procedures to be followed described in Exhibit E of Statement
of Work for Organics and in Parts II and III of Statement of Work for
Inorganics. Performance audits by EMSL-Cincinnati; procedures fol-
lowed described in same sections referenced above for systems audit.
18. Corrective Action - See Section 13.2 of HQ QA Project Plan.
19. Reports - See Section 8.1 of "Revised Draft Protocol for Ground Water
Inspections at Hazardous Waste Treatment, Storage and Disposal Facil-
ities" (Attachment). The Solid Waste Branch is responsible for the
final report. Personnel responsible for various work assignments will
submit respective reports to the Solid Waste branch.
-------
Appendix - 1
CcL^K-r 1 1 , i*c*
ktt^fi BBt-riit^ itibpcctioi. at Strvicioi. Cart>«rccr., Inc., Penutici , hucru
aucc tPKjX'Vl(-'iot22)
Joscpr. V. Cciseiktj.ru.>, Ln\
Soaici. Honitcricj., S*clicn
iciic WaBti. £r*i.ci,
Ti.KL : Joan Ciaric.it,
Source hcrltoriug S*.ctioc
L. Spear, Ciiei
Surveillance anci Monitoring firancfc
Ob K&rcL 21-22, 19oA a MCkA »aapliD£ survey *a* conduciec at Servicioc
Car bar ecu, Ice. UiUX"9101bt>22) located on let, 365, KB 3.5 in F*nuclat,
Puerto Hico. Partl.cipati.D4 IB tLa* ln»pection w*r« Louit i»i^u«roia,
, to Ian Kovak, Kici. h*^riple» «nc ^'*clt. Myra ptrrcx, lv«ttc
C^k* 4velett kcberto Berber eua, Yaxclb Lopet, harla Rodriquet,
bulcillo Hf-dina and Jo»c Torraca el the LnvlrooBtntal Quality fcuard (£Qt;
oi Puerto Rico «cco6^&aiec EPA. Al»o pr«»t;ut vtre Ldert Ortik, Director
ef Oj-eratloafc, Juan tregroo, Cblcf Cbekl»t, Mario Slaty, Cotflianct Oil let r
lor Servicioc Carbareoii and Aooilo Valccb oi tnvlrolabs Inc.
Servicloe Car bar eon ia engagec io Che traotport, treatment, and
anc dicpuaaa of Industrial «aate«, both Uaccrduuc ace ooD-hataroous. A
site aap ami le&end are attached aa Figure 1.
This aurvey, coruluctttt at the request oi tbc Solid Waktc fcrkucii vet to
verify aite conditions, grounUwater monitor ins data and unit cloaures.
Trie areas of concern vtrt: a uckte oil lA^con, eoxr-hazardoufi waste j-auc1-
fan, druu storage area, linCaoe storage tack area and the ground water
•onitoritg we. lie.
As a result, the ioiloviu^ aacplec ttrre collected at the location*
oJ aoil (auriace to 4 iocUea deep)
collcctec iroc, toe eastern half of the drus atorage area ior vrgauicfc a DC.
•ct a It analysis. The druc storage aria, dt£i£uatec as 44 on cite B&K anc
» L own in photograpLa 14*6 ha» an earttieo floor and oik.c. The flour of
tin- storage KTLB cifl not appear to be aloped nor was a *}>»tce for r&Dov<>]
or »},ilib, leaks or precipitaii&L eviut-ut.. At tue tiar o; tuit. int.! <.ctior. ,
ajproximatfeiy 150 pieetic b&^s (yellow; contfciniiif eJcctroj>iatini cluyi.L
v^rt. bcin^, tiiiiLd ior Digital Lqui)jc.e.nt Corporation p<-&i:int tut outccu.
of a petition to exclude tne watte irot; rcguiatiou. ievfcral oi Che i>cLt'
vtrc ton. aoc a portioi. oi tucir cunter.tb u«iw spiiiec onto the
ai»cn.t IGu ciruck ol various va«tce (i.e. aolvcuts, tara and
ktor«.c prior to Lnk.oui.iitAt.ioL.
Coseutinc Liantit Spear
-------
*6o(ji>6 wj£ « eocjositi o£ fcoil (•urii.c.L to 4 Incfceb oetr;
cf tta cruu ator£te «rui for
Crfti-fc
. Ic _ffcju57 vat a 8li.tli gran coliectto trot* the oil lajooc for rett.it
er.c,' or£f.r.lc.$ aruxiyaie. Iht lagoon is e'etigr.stta t£> fV on cite »a; *uc it
chovT. it t-^oL&< i Cjjlu, F? & c. The l*£,oou it utiiocc «Dd «»ed for Luc
of venous p-ttroltui: vasttB. Accufti;lct«d w«tfr and raiowsttr arv
tc •:. acj«cec,t raiovBtcT I^-LXJU, nucM-r 13 01. Utt K2^.
f66C5fc wck • compel tc of »oil («url«ctr to 5 loctiee
coiltctcc «round AD above ground liooaue storage taru. for £P toxicity
(crt»nics) aualycic. Tbt tank deftiguatea ac 115 CL aitc •*}, 1* ahovn ID
6 3 aou 14. AD eartbeo cont*l«*>tnt a>«tet aurroimcK cue
'13 kbovc tbe loroer llndanc atora^c tank, no longer in
The linctnt it eifiOktd of via »olicJiiic*ti&n/iBu»oHii»atiOD.
-1-? ^^_6(-A? *** * coepo*lte of soil (curface to 5 Inches deep)
colltcttc trot the atnjtfaeru b*Af ci ti*t landian for orgaulca analysis.
TtilB area designated as 114 on cite •*? IB abovn In photographs & thru
13. 71. c lajKuara ia uaec for 6i»posal of uoo-harardoua ioductriai
(i.e. alud^ts, of£-ap«c food stuffa and ofi-apoc pharmaceutical*).
e *bbU6f wes a ceeposite of soil (surface to 5 incuts
collected fro& the eorthero Lalf ct the lanoiars for or^acict
* fcaaj:a.e_>bbl^tj2 , 6bUb3 auc ^6064 vere grabfc iroe the lacillty'a dovngra-
ciect kCkA e»onitorit£ wtils collected for orgaoles aualyiis. It would
• pp*ar froa the itfontition et< bycro^ttoiocic cx.ocitioa* at this site to*t
these veils arc not ciovngradient of the- regulated vostt trt_auart7(ii»pO6«l
ixc its (see figure J).
~ Sample 16 &06 5 vac a grab troc tht iaciiity'a upgradieot KCKA veil
collected fot crjracica analysis.
* grab aajB^le collictetl free the oil lagooc for
testing as an ignltaLl* veate.
- Sacj.-le_ *_6bOt^ vas m grac froa the r*lavater lagoon collected joi
TV.is unit ia cesiguatec as 113 on the site fc&p and abovu in
e 16 thru 1^. Tblb ia^;oou vas aclfcCtfeb for a*u;liit£ alter a
ttnL truck w*e otservec
-------
Ail aattpitc wort- anilyreo at tPA't Lcikor., KJ IfctortLor) . TUV cat..
outaiucc tree, tin anfeijsct ie Altacne-c a* Ttpitf C> taiu 4. lat^i t.
f rtfcents tLt or/«nic cot^uur.ce tor vl-icb anciysit we* cacdaetccl. it)lsi& ate Ttti" 4 yrtsonte the ravolti of i£r.i-
auo LP toxicity
Trie Ttsuits Indicate sigtiticant taetelt cent ati cat ion of tht «oil in tt.t.
crui. «ccra^c ar^£ «af *ipuiiic_i.Qt or^dcic^ conr«t>auatioi> In ttic o^i la, oc:
and r.on-t»azarcou6 lardi&rc. Ibe cJcfcigafctcd KCF^A. scnltorint Wvllt tren
rfciat-ivtiy tree ol cr^aulcA coutatil nAtion. iiowevcr, Veil oe^tUk au>.
location* in light of bydr&fceologlc con^itlo&s at tbt «itc cake this data
at
Table 0 - Li«t of Oif«aic Go«pt-unds tor iri.icd Acaiyaia wak CoucuctcJ.
Zeble 1 - Kcsultc oi Or^a&ica Au^lyeie on S*bplb» collected 2-21-fcti.
Table 2 - £esult« oi Organlce Ais*J.ytl* on Sacplee Coj-ltctcci 2-
Tat/lc 3 - Eefcults of M*t«l& Analysis
Table 4 - *>ew.ts of Ignitabillty anc l.P. Toxicity Acaiysn
figure 1 - Site Ka^ acd Legecc.
yiiure 2 - Sajfplfc Location ha>/.
figure 3 - Veil and Well Sait^lc Location
figure 4 - toouitorlm, WtJ.1
1 - FDotograpbc taken at Scrvicioe Car bar con.
xor
cc; John Jix&cncz - AWl^-SW
-------
Organic Conpounds for which Analysis was Conducted
Sample Nwnbers; 66055, 66056, 66057, 66059; 66060,
66062, 66063, 66064, 66065 and 66067
O
?. ,4ff» ll irllloiOpltenol
i> t;iiloM> n ncfsol
7 cMoi oplieiiol
2,1 »l H
2 -III I lO
4 -ni 1 1 o
7,4 (I I nil m o
|4»enol
fM:en;ipM I M
lw»ny. idiitf
j ,7,4 1 1 ir
2 rlil 01 oiiiijilil I if i It-lie
\ ,7 tiinl I l
I ,7 1 1 Ipliciiy Iliydi n/. SIM?
( af". ;r/< tin -ii/vni1)
I I mil I>M| IM-IM*
\ cliloi ojiltrny 1 pliriiyi rllier
r ol (V
Volal i les
plwnyl oilier acroleln
acrylonii
!>en/ene
»X nci
yc I oj wni.
n ! I
N-nlf
N -nil row*! i -n pi c>| >y 1
""
(ii-n-l)uiyl phi Hal fil
Oi -n-oet yl piilh
|N>IIZO( AJ
7.o( k ) f hir>t iw\ TKMK»
rluyociw
o« onapiil hyiene _ _
mil liracene
fhmrenn
jdiciintii luanp
il HxMi7o( ci ,!•) ani JiVacene
linioiK>( 1 ,?, 1 (xl)pyretie
pyi
t;l rnrhlor
1 ,1 , 1 -I r
j , I -ron«K»rcweiliano
il)c-iiii>r«xi1 f liiortineilinne
otlilii ounioi hniie
r
liyli
I r
vinyl c
'i iiyl
«>ne
IVsl i( l«l«>
aldi in
?!iol«li In _
< hloninne
Rui fan I
sul fan i I
sni fan «;uifale
emir In alcleliytie
iepl acJiloi epix i -I7C.O
iox/iplwue
Diox in.*;
} . I./.H l«-li.»'•
oi otlilMMi7o
y in
-------
Results of OrganlcB Analysis on Samples Collected at Servicioa Carbareon
Febuary 21,1984
Compounds
Identified
1 ,2-dichlorobenzene
f luoranthene
isophorone
naphthalene
bls(2-ethylhexyl)phthalate
butyl benzyl phthalate
dl-n-butyl phthalate
dl-n-octyl phthalate
dlethyl phthalate
fluorene
phenanthrane
pyrene
benzene
1 ,2-dlchloroethane
1,1 ,1-trlchloroethane
lj 1-dlchloroethane
chloroform
1, l-dichloroethene
ethylbenzene
methylene chloride
bromome thane
tetrachloroethylene
toluene
trichloroethylene
BHC-Gama
066055
Drum storage
area ll (soil)
18000. ug/kg
38. ug/kg
80. ug/kg
64. ug/kg
60.3 ug/kg
166056
Drum storage
area 12 (soil)
160. ug/kg
15000. ug/kg
31. ug/kg
290. ug/kg
D>66057
Oil lagoon
(liquid)
290000. ug/1
160000. ugA
17000. ug/1
280000. ug/1
9300. ug/1
120000. ug/1
110000. ug/1
26000. ug/1
tbbQW
Non-hazardoufl
land farm If 1
(soil)
2000. ug/kg
1600. ug/kg
52000. ug/kg
2000. ug/kg
10000. ug/kg
4000. ug/kg
140. ug/kg
3300. ug/kg
5800. ug/kg
200. ug/kg
20000. ug/kg
140. ug/kg
1100. ug/kg
1000. ug/kg
14000. ug/kg
7800. ug/kg
1600. ug/kg
42400. ug/kg
066060
Non-hazardous
land farm H2
(soil)
5300. ug/kg
1900UO. tig /k 15
36000. ug/kg
80UO. ug/kg
1300. ug/kg
2200. ug/kg
76000. ug/kg
2900. ug/kg
63000. ug/kg
2500. u£/kg
2500. ug/kg
3800. UR /kg
230000. ug/kg
57000. ug/kg
21000. ug/kg
1JOH. ug/kg
-------
Resulta of Organica Analysis on Samples Collected at Servicioa Carbareon
Febuary 22. 1984
Compounds
Identified
1 ,2-dlc.hlorobenzene
f luoranthene
Isophorone
naphthalene
bis(2 ethylhexyl)phthalate
butyl benzyl phthalate
dl-n-butyl phthalate
dl-n-octyl pbthalate
diethyl phthalate
f luorene
phenanthrane
pyrene
benzene
1 ,2-dichloroethane
1,1 , 1-trlchloroethane
1 , 1-dlchloroethane
chloroform
1 , 1 -dlchloroethene
ethylene
methylene chloride
bromome t hane
tetrachloroethylene
toluene
trlchloroethylene
BHC-Gnma
166062 '
Well IIW81
-downgradlent-
3 ug/1
7.1 ug/1
3.0 uR/1
166063
Well I2W81
-downgradlent-
3 ug/1
A ug/1
57 ug/1
A4 ug/1
166064
Well I12W83
-downgrad ient-
#66065
Well » HWB3
-upgradient-
350 ug/1
3 ug/1
#66067
Rain water
Jagoon
17 ug/1
40 ug/1
13 ug/1
-------
- Table 3
Results of Metals Analysis on Samples Collected
at Servicios Carbareon
Parameter
#66055
Drun storage
area #1
1
166056
Drum storage
area 12
1 I
#66057
Oil lagoon
silver
arsenic
beryllium
cadmium
chromium
copper
mercury
lead
nickel
antimony
selenium
thallium
zinc
18 mg/kg
1.7 mg/kg
460 mg/kg
800 mg/kg
3.0 mg/kg
160 mg/kg
24 mg/kg
1.7 mg/kg
81 mg/kg
43 mg/kg
4.0 mg/kg
51 mg/kg
60 mg/kg
.84 mg/kg
3.4 mg/kg
160 mg/kg
130 mg/kg
21 mg/kg
-------
- Table
Results of Ignitability and EP Toxicity Analysis OP Samples
Collected at Servicios Carbareon
#66058 #66066
Lindane Storage
Parameter Tank
Oil Lagoon
EP Toxicity (organics) 0
Endrin 0
Gamma BHC (lindane) 0
Methoxychlor 0
2.A.D 0
Silvex 0
Toxaphene 0
Flash point
0 • Sample not analyzed due to lab accident
-------
•n
o
13
CO
"1
O
O
lo
O
73
CO
rn
O
z
o
f
(j
II
h
-------
Servicios Carbareon,Inc.
Site Map Legend
1 - Landfill, drun burial
2 - Landfill, drim burial
3 - Landfill, drum burial
A - Drum storage area
5 - Landfill, drum burial
6 - Sanitery landfill
7 - Lagoon, corrosive waste
6 - Landfill, drum burial
9 - Lagoon, oil
10 - Immobilization area
11 - Immobilization area
12 - Land application area
13 - Lagoon, rainwater
14 - Land application
15 - Tank storage area
16 - Immobilization area
17 - Surface impoundment (future)
18 - Immobilization area expansion (proposed)
19 - Immobilization area expansion (proposed)
20 - Corrosive lagoon expansion (proposed)
21 - Drum storage area (proposed)
22 - Lagoon, rainwater (proposed)
-------
— SERViCIOS CARBAREON, INC.—
FACILITY
\^
-------
&**
-------
Servlclos Carbareon - Monitoring Well Measurements
Figure 4
Well number
Original
Depth of Well
Well size
Water level (from top)
Height of
water (from bottom)
Water level
after bailing
Volume of
water evacuated
Volume necessary
to evacuate one
well volume
1W-81 1
1
229 ft.
2.5 in.
77 ft.
152 ft.
228 ft.
41 gal.
38 gal.
2W-81
240 ft.
2.5 in.
76 ft.
164 ft.
217 ft.
46 gal.
42 gal.
11W-83
193 ft.
2.5 in.
172 ft.
21 ft.
184 ft.
30 gal.
5 gal.
12W-83
175 ft.
2.5 in.
90 ft.
85 ft.
175 ft.
22 gal.
22 gal.
-------
Photograph tl -
Entrance to facility
from Rt. 3b5.
Photograph 12 - Entrance to actual
waste disposal site,
-------
Photograph 13 - General sitt view
looking south froc
•center of site.
Photograph 14 - General Bite view
looking north-west
from center of site.
-------
Photograph 15 - Empty druE storage
area.
Photograph tb -
Drum storage area
(14 on site nap).
Yellow bags contain
electroplating sludge.
-------
Photograph #7 - Shows oil lagoon,
lindane storage tanK.
•nd ittmoDilization area.
Photograph t8 - Collection ot sample
*t>6057 .from oil lagoon.
-------
Photograph
- General view or
lanciam used tor
non-hazaraous waste
disposal.
Photograph 110 - Northeast section of
landfarm.
-------
Photograph #11 - Southern portion
of landfarm.
Photograph 112 - «outhern tip of
landfara.
-------
Photograph 113 - Collection of samples ft>6u59-bo06U
froc landfarn;.
-------
Photograph 114 - Lindane storage tan*
(blue) presently in
use,
Photograph *15 -
Relocated lindane
storage tank (on
right) no longer
usea.
-------
Photograph #16 - Rainwater lagoon
Photograph 117 - Hose used to discharge
into rainwater lagoon.
-------
Photograph #18 -
Tank truck discharging
unknown substance into
rainwater lagoon.
Photograph *19 -
Collection of sample
166067 from rainwater
lagoon.
-------
Photograph *20 - Sampling at well I1W-81 (downgradient).
-------
•CHAIN OF CUSTODY RECORD
IMVIIONMiNTAl MOTtCTlOh AOENCY _ IIO)ON II
SUIVE1UANCE 4 ANAIYSJ WV1BON
IWSON, NIW mSlY 0*117
M...
RC. -BBS.
Pfc06«\lOlB4U.
*••»!•
fron. POA.
I
3
Qt.
1 QC FOR
^01 *-
^
• We acknowledge that the»e areas
•t Carbare6n, Inc. How«Twr ve di
not rcsiv
'
Mcabir
t.Bl.k Iw Ch.«(t •* Coitcdy
n**
t*«>M for Cil.ll«« .(
TIB.
!••>•• tor Ck.nt« •<
TIM*
-------
1.0*2.
WVIIONMENTAl MOnmOH AOBNCY - tfOtON II
SUIVEIU.ANCE A ANAlYflS DtVtBON
«Ht ON, MEW JEISET Mil?
\
JL
\ Qt.
Rom
• We acknowledge that thes
areas were sampled at
Carbareon, Inc. However
we did not receive any
of these •saples,—-
/_
Bxcep't the well' •ample
F*" .^^ 1 ^ * * ^ _ _^
N.aktr
IMM* Iw Ck«»§t •( C.tt.dr
TlBt
-------
To: ESD/REG.II (EPA9281)
Freer,: AKMD/REG.II (EPA9261 } Posted: Fri 18-Oct-85 15:00 EOT Sys 63 (252)
Subject: Attachment E (Analytical Parameters for GW & leachate Samples)
ATTACHMENT B/Ton/10/17
TO: JOE COSENTINO
OM: TON MOY
Analytical Parameters for Groundwater and leacnate Samples
Acrolein
Acetone
Acrylonitrile
Benzeneene
Bronodichlorcmethane
Brcmoform
Br oncmethane racene
Chlorobenzeoranthene
Giloroethaneranthene
2-Chloroethyl vinyl ether
Chloroform
Chloronethane
1,2-Dibrono-3-chloropropane
Dibrcnochlorcmethane
1,1-Dichloroethane
1,2-Dichloroethane
trans-1,2-Dichloroethene
1 ,2-Dichloroethene
Dichloronethane
1,2-Dichloropropane
cis-1,3-Dichloropropsne
trans-1,3-Dichloropropene
1,4-Dioxane
Ethylbenzene
Tr ibr on one thane
1,2,4-Trichlorobenzene
1,1,1-Tr ichloroethane
Tr ichlo roethene
Vinyl chloride
Acenaphthene
Acenaphtalene
Aniline
Anthracene
Benz[a]anthracene
Benzidine
Benzo(a)anthracene
Benzo[b] fluoranthene
Benzo[k]fluoranthene
Benzo[a]pyrene
Benzo[g,h,i]perylene
Benzyl chloride
Bis(2-chlorethoxy) methane
Bi s(2-chloroi sopropyl)ethe r
Bis(2-ethylhexyl)phthalate
4-Bronophenyl phenyl ether
Butyl benzyl phthalate
p-Chloroaniline
p-Chloro-m-cresol
-------
- 2 -
Methyl ethyl ketone (MEK)
Pyridine
Styrene
1,2,4,5-Tetracnlorobenzene
1,2,3,4-Tetrachlorobenzerie
1,1,2,2-Tetrachloroethane
Tetrachloroethene
Tetrachlorcn ethane
Toluene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
3,3'-Dichlorobenizidine
2,4-Dichlorophenol
2,4-Oichlorophenoxyacetic acid
Diethyl phthalate
2,4-Diirethylphenol
Dimethyl phthalate
4,6-Dinitro-o-cresol
2,4-Dini trophenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Di-n-octyl phthalate
Diphenylamine
Fluoranthene
Fluorene
Hexachlorobutad iene
2-Chloronaphthalene
2-Chlorophenol
Chlorqphenylphenyl ether
Chrysene
Dibenzla,h]anthracene
Dibenzofuran
Di-n-butyl phthalate
1,1,2-Trichloroethane
1,2-Dichlorobenzene
Pyrene
1,2,4,5-Tetrachlorobenzene
1,2,3,4-Tetracnlorobenzene
1,2,4-Trichlorobenzene
2,4,5-Trichlorophenol
2,4,6-Tr ichlor cphenol
Acrylonitrile
1,4-Dioxane
Aldrin
alpha BBC
Beta BBC
Delta BBC
Gairrna BBC (Lindane)
Chlordane
4,4'-ODD
4,4'-DDE
4,4'-DDT
-------
- 3 -
Hexachlorocyclopentadiene
Hexachloroe thane
Indeno( 1,2, 3-cd)pyrene
Isophorone
2-Methyl Phenol
4-Methyl Phenol
Naphthalene
4-Nitroaniline
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
N-Nitrosod imethylam ine
N-Nitrosodi pr opylamine
Pentachlorobenzene
Pentachloronitrobenzene (PCNB)
Pentachlorophenol
Phenanthrene
Phenol
Cyanide
Armenia
Gross Alpha
Gross Beta
Radian Total
Radian 226
Uranian
1,1,2-Trichloro~1,2,2-Tri Fluoroethane
Dieldrin
Endosulfan I
Endosulfan II
Endosulfan Sulfate
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide
Methoxychlor
Toxaphene
PCB-1016
PCB-1221
PCB-1232
PCB-1242
PCB-1248
PCB-1254
PCB-1260
Nitrate
TrichlorofLuoronethane
Xylene
Ethyl Acetate
Ethyl Ether
Methyl Isobutyl Ketone
n-butyl Alcohol
Cyclohexanone
Methanol
-------
- 4 -
Benzene
Acetic Acid
Formaldehyde
Methyl ene Oxide
Lead Acetate
Resorcinol
Benzidine( 1 , 1 '-Biphenyl )-4,4 '-Diarrdne
Total Metals
Dissolved Metals
Arsenic
Cadmium
pH )
)
Temperature )
Conductivity )
) — Field Measurements
Color )
)
Odor )
Turbidity )
Sulfate
Priority Pollutants
Extra Peak Scan
Purgeable Organic Carbon
Purgeable Organic Halogens
Carbon Disulfide
Isobutanol
Sodiun Azide
lodcmethane
Chromium
Lead
Mercury
Selenium
Silver
Barium
Iron
Coliform Bacteria
Total Organic Carbon
Total Organic Halogens
Chlorides
Magnesium
Potass ion
Sodium
Carbonate
Bicarbonate
Calcium
Methyl Benzene
-------
)—Field Measurements
pH )
)
Temperature )
Conductivi ty )
Color )
Odor )
Turbidity )
Sulfate
Priority Pollutants
Extra Peak Scan
Purgeable Organic Carbon
Purgeable Organic Halogens
Coliform Bacteria
Total Organic Carbon
Total Organic Halogens
Chlorides
Magnesium
Potassium
Sodium
Carbonate
Bi carbonate
Calcium
Methyl Benzene
-------
CHAIN OF CUSTODY RECORD
Appendix - 3
fNVIIONMtNTAL PtOTECDON AGENCY - IEOION II
Environmental Services Wvision
IDISON, NEW «»SEY 01117
Mint •
;::;';
So.pl.
Nu.htr
{.•pit
Nv.b.r
S.»pl.
I U»H ..rf
•1
• •Imq
.„.„..„„
xntod lr.
ith.d ty.
l«i
I*»iv>d ly:
•
ft»c*iv*d By
llm.
D.It
D«l*
l«(i*n f»r Ck«n|« •! Cvitftdy
l««*n Ur Ckctift •( C«>l*dr
l«.l*» f*r Ck«K|t •' Cviledy
S" 5
f 1
M
e- -f
f \
H
J
N..
-------
c c c c c
y01** 11SS^»2SSEE5S5SS*
E^ INORGANIC!
Q) CARP Number! .„.,
Sample Site Name/Code:
~) Sampling Office:
Sampling Personnel
(Nam«l
(Phone)
Sampling Date
(Begin) (End)
® Sample Description:
(Check One)
Surface Water
Ground Water
Leachate
Mixed Media
Solids
fuller
(specify)
MATCHES ORGANIC SAMPLE NO
o o o o o :
STnS^sjfjWWjgfvr tJMtSHkiW
S5|fc.££|$tiO$ij^;&90 ^0&LSg$S
JITRAFnClREPORT
0 SAMPLE CONCENTRATION
(Check One)
Low Concentration
Medium Concentration
0 SAMPLE MATRIX
ffhfv-V One)
Water
0 Shipping Information:
Name Of Carrier:
n*t* Shipped
Airhil' J\I\imb••>.)
r^^MrSfiT^Tii^F^^^^^**™"""^^^^
IPIPS^W^ t Sample Number
:' MBE 117 1
0 Ship To:
Attn:
Transfer
Ship To:
MBE H7 - Total Metals
• MBE H7 • Total Metals
MBE H7 . Cyanide
MBE H7 • Cyanide
m*nr- A A ^
MBE 117
MBE H7
MBE H7
-------
(£) Case Number:
Sample Site Name/Code:
© Regional Office:
Sampling Personnel:
(Name)
(Phone)
Sampling Date:
3egm) (End)
© Shipping Information
Name of Carrier
Date Shipped:
Airbill Number:
© SAMPLED
(C
Low(
Medii
© SAMPLE1V
(Check C
Water
Soil/S
CONCENTRATION ©Ship To:
lieckOne)
Concentration
iim Concentration
Attn:
1ATRDC m^ mm ^m mm ^m u^
Transfer
ediment Ship To:
© For each sample collected sp
of containers used and mark v
on each bottle.
Number of
Containers
Water
(Extractable)
Water
(VOA)
SoU/Sediment
(Extractable)
Soil/Sediment
(VQA)
Other
© Sample Description
Surface Water M'*^ M^ifl
Groimri Water Solids
I.Aarhate Other (specify)
>ecify num.
volume lev
BC 9 9 9 ' Water
BC ° (Extractable)
Approxi
Total Vol Dr QQQ -Water
(Extractable)
1 ,. 0 0 Q . XFntrr
, C (Ertractatle)
Bc999 -v-iw
(Extractable)
Rr Q Q Q • Water
uL»»y (VQA)
Rr Q Q Q • Water
BL»»y (VOA)
nr Q Q Q ' SoU/Sediment
BC (Extractable)
T,/- Q Q Q • SoU/Sediment
J3Li V ** V ,-n . . , »
(Extractable)
©Sam] -?Cyyy (VOA)
vr Q Q Q ' Soil/Sediment
• ^L yyy (VOA)
3) Special Handling Instructions:
(e.g., safety precautions, hazardous nature)
-------
Appendix - 4
Well Monitoring Data Sheet
Site Name
Location
EPA ID «f
Sampler(s)
Well Measurements
Well Diameter
Well Depth
Casing Size
Vater Depth
cm
in
ft
cm
in
m
ft
Hght of Water (Well Dpt. - Water Dpt)
m ft
Evacuation Method
Vacuum
Bailer
Pressure
Other
Time: Beg.
End
Kate of Discharge
Volume
gal
Volume Removed
Recharge Wait
Analysis;
gal
Date: Beg.
Well No. Lat._
Site Rep.
Ena
Long.
Photo Log
General Observations
Detectable Odor - OVA
- HNU
Temperature
Turbidity
Color
Conductivity
Sample Method
Bailer
Diaphragm
Other
Time: Beg.
Depth Sampled
General Comments:
Preservation Method:
Conversions:
1 meter - 3.28 ft
1 foot « .3048 m
PH
Sediment
Odor
End
-------
Height Of Water ( Ibtal Lcngt ^epth to Water ) in FECT
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-------
Anpendix K
Monitorinq ^aranieters
-------
To: ESD/REG.II (EPA9281)
From: AWMD/REG..II (EPA9261) Posted: j_Fri 18-Oct-85 ISiOOJEDT Sys 63 (252)
Subject: Attachment B (Analytical Parameters for GW & Leachate Samples)
ATTACHMENT B/Ton/10/17
TO: JOE COSEKTTKO
OM: TON MOY
ATTACHMENT B
Analytical Parameters for Groundwater and Leachate Samples
Acrolein
Acetone
Acrylonitrile
Benzeneene
Bromodi chloromethane
Bromoform
Bromomethaneracene
Chlorobenzeoranthene
Chloroethaneranthene
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
1,2-Dibromo-3-chloropropane
Dibromochloromethane
1,1-Dichloroethane
1 ,2-Dichloroethane
Tri bromome thane
1,2,4-Tri chlorobenzene
1,1,1-Trichloroethane
Tri chloroethene
Vinyl chloride
Acenaphthene
Acenaphtalene
Ani line
Anthracene
Benz[ajanthracene
Benzidine
Benzo(a)anthracene
Benzo[b]fluoranthene
Benzo[k]fluoranthene
Benzo[a]pyrene
Benzo[g,h,i Jperylene
-------
trans-1,2-Dichloroethene
1,2-Di chloroethene
Di chloromethane
1,2-Di chloropropane
cis-1,3-Dichloropropene
trans-1,3-Di chloropropene
1,4-Dioxane
Ethylbenzene
Methyl ethyl ketone (MEK)
Pyridine
Styrene
1,2,4,5-Tetrachlorobenzene
1,2,3,4-Tetrachlorobenzene
1,1,2,2-Tetrachloroethane
Tetrachloroethene
Tetrachloromethane
Toluene
1,3-Di chlorobenzene
1,4-Dichlorobenzene
3,3'-Di chlorobenizidine
2,4-Di chlorophenol
2,4-Dichlorophenoxyacetic acid
Diethyl phthalate
Benzyl chloride
Bi s(2-chlorethoxy)methane
Bi s(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
4-Bromophenyl phenyl ether
Butyl benzyl phthalate
p-Chloroaniline
p-Chloro-m-creso1
2-Chloronaphthalene
2-Chlorophenol
Chlorophenylphenyl ether
Chrysene
Dibenz[a,h]anthracene
Dibenzofuran
Di-n-butyl phthalate
1,1,2-Tri chloroethane
1,2-Di chlorobenzene
Pyrene
1,2,4,5-Tetrachlorobenzene
1,2,3,4-Tetrachlorobenzene
1,2,4-Tri chlorobenzene
2,4,5-Tri chlorophenol
2,4,6-Tri chlorophenol
-------
2,4-Dimethylphenol
Dimethyl phthalate
4,6-Di ni tro-o-cresol
2,4-DinJ trophenol
2,4-Di ni trotoluene
2,6-Di ni trotoluene
Di-n-octyl phthalate
Diphenylairane
Fluoranthene
Fluorene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexa ch loroe thane
Indenod , 2 , 3-cd)pyrene
Isophorone
2-Methyl Phenol
4-Methyl Phenol
Naphthalene
4-Ni troaniline
Nitrobenzene
2-Ni trophenol
4-Nitrophenol
N-Ni trosodimethylami ne
N-Nitrosodipropylamine
Pentachlorobenzene
Pentachloronitrobenzene (PCNB)
Acrylonitrile
1,4-Dioxane
Aldrin
alpha BHC
Beta BHC
Delta BHC
Gamma BHC (Lindane)
Chlordane
4,4'-ODD
4,4'-DDE
4,4'-DDT
Dieldrin
Endosulfan I
Endosulfan II
Endosulfan Sulfate
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide
Methoxychlor
Toxaphene
PCB-1016
PCB-1221
PCB-1232
PCB-1 242
PCB-1248
-------
Pentachlorophenol
Phenanthrene
Phenol
Cyanide
Ammonia
Gross Alpha
Gross Beta
Radium Total
Radium 226
Uranium
1 ,1 ,2-Trichloro-1 ,2,2-Tri Fluoroethane
Benzene
Acetic Acid
Formaldehyde
Methylene Oxide
Lead Acetate
Resorcinol
Benzidine( 1 ,1 '-Biphenyl )-4,4 '-Diamine
Total Metals
Dissolved Metals
Arsenic
Cadmium
PCB-1254
PCB-1260
Nitrate
Tri chlorofluoromethane
Xylene
Ethyl Acetate
Ethyl Ether
Methyl Isobutyl Ketone
n-butyl Alcohol
Cyclohexanone
Methanol
Carbon Disulfide
Isobutanol
Sodium Azide
lodomethane
Chromium
Lead
Mercury
Selenium
Silver
Barium
Iron
-------
Appendix T7
Receipt for
-------
-------
Relinquished bv: (Signature!
Relinquished by: (SignatureI
Relinquished by: (Signature!
Orilriluitinn Umiifi.il Plm Out- At iiirii|Miuos Shiptnpnt (mhitf and ypllowl Conv 10 Coordin.itnr FmUl FI!H< li.,.,l. I
-------
Distribution Original Plus One Arcomp.mios Shipment (white and yellow). Copy to Coordinator Field Files (pink).
-------
Distribution Original Plus One Accomp.mips Shtpitiont (white and VP"OVW), Copy to Coordinator Fiptrl Filrs (pitik)
-------
INC.
RECORD
PROJECT NO.
PROJECT NAME
SAMPLERS: (Signature!
PTg/JW* ffitt
TIME
(Pnnted)
STATION LOCATION
obi*- m
I/
(3-W-8S
t/
Relinquished by: (Signature)
inted)
Date / Time
ived by: fiwuature)
Relinquished by: (Signature]
(Printed)
Date / Time
Received by:
(Printed)
Relinquished by: (Signature}
(Printed)
Date / Time
Receive
tSignaturrl
ry by:
Date / Time
(Printed)
Remarks
Distrihudon Onqmal Plus Onp Accompanirs Shipment (white and yellow). Copy to Coordinator Field Files (pink)
-------
PROJECT NO. PROJECT NAME
SAMPLERS: (Signature)
FIELD
SAMPLE
NUMBER
STATION LOCATION
Relinquished by: (Signature)
Relinquished bvj (Signature!
Printed)
Received for Laboratory by
(Signature)
Relinquished by: (Signature)
Distribution Onqin,)! Plus One Accompanies Shipment (white and yellow). Copy to Coordinator Field Files (pink).
-------
INDUSTRIAL
HYGIENE SAMPI
Relinquished bv: (Signature)
Relinquished by: (Signature)
Distribution Original Plus One Accompanies Shipment (white and yel'ow). Copy to Coordinator Field Files (pink).
-------
wrsaiv
-------
PROJECT NO.
PROJECT NAME
PARAMETERS
SAMPLERS: (Signature)
FIELD
SAMPLE
NUMBER
STATION LOCATION
Received by: (Siqnann,<)
Relinquished by: (Signature)
Received by: (Signature)
Relinquished by: (Signature!
*
Received f6r Labora
Datp / Time Remarks
Relinquished by: (Signature/
Dislriliiiliini Otniiii.il I'liis (It"' A< i i>n>|Miiii's Ptiipi'H'til (wliitf .mil ypllnw). Copy In (.inttrlin.itfir F n-M f ilt>? (pink I
-------
IMtiitnMinn Oni|iosl PliM Oni- Air
-------
APPENDIX G
CLOSURE PLAN/COST ESTIMATE FOR
THE WASTE MANAGEMENT UNITS
-------
1. CLOSURE AND POST-CLOSURE REQUIREMENTS
1-1 Closure Plans
Closure plans were not provided or reviewed for
the following units listed on the facility
drawing legend, page '1-6 of the application:
o Facilities listed by applicant as being
nonhazardous waste facilities:
- Number 6, Sanitary Landfill (SL)
- Number 12, Land Treatment Area (AC-1)
- Number 14, Land Treatment Area (AC-2)
o Facilities listed by applicant as being
hazardous waste facilities:
- Number 1, Drum Burial Landfill No. 1
- Number 2, Drum Burial Landfill No. 2
- Number 3, Drum Burial Landfill No. 3
- Number 5, Drum Burial Landfill No. 5
- Number 8, Drum Burial Landfill No. 8
- Number 10, Immobilization Facility (TI-1)
- Number 11, Immobilization Facility (TI-2)
- Number ISA, Tank Storage Area
- Number 19, Temporary Drum Storage Area
The comments provided below are only for the
other units, for which a closure plan was pro-
vided.
I-la Closure Performance Standard; §264.111
Due to the large variety of unit types (i.e.,
container storage, tanks, landfills, etc.) the
text included in Section I-la of the application
should be expanded to provide a brief description
of how the individual closure plans provided for
each type of unit, meets the closure performance
standard.
I-lb Partial Closure Activities; §264.112(a)(1)
On page 1-45 of the application it indicates that
IM-1 and IM-2 »ay be closed "in segments."
However, no detailed plan of how the partial
closure activities are to be performed was
submitted. The applicant must submit a detailed
description of the partial closure activities for
these units.
36
-------
I-lc Maximum Waste Inventory: §264.112(a)(2)
Based on the surface area of the rainwater basin
as shown on the topography map, the estimated
maximum waste volume of 100,000 gallons provided
in Table 1-4 appears to be low. Provide addi-
tional justification of that volume.
The maximum waste volume of 1000 drums or 55,000
gallons shown for the proposed drum storage area
on page 1-14 of the application is less than the
computed capacity of 1088 drums or 59,840 gallons
based on the figure on page D-4 of the applica-
tion. Clarify this issue.
The maximum waste inventory volume provided in
Table 1-4 for the LF neutralization impoundment
indicates a maximum capacity that is approxi-
mately 170,00 gallons in excess of the computed
volume provided on page D-45 of the application
(7222 cubic yards yields a maximum volume of only
1.46 million gallons). The applicant has indi-
cated that the 168,000 gallons of waste in
impoundment LC will be transferred to impoundment
LF, which cannot be done if impoundment LF is
full. Revise Table 1-4 and page D-45 to reflect
the actual maximum capacity of impoundment LF,
independent of any liquid in impoundment LC.
The maximum waste quantity of 292,238 gallons
provided in Table 1-4 for the TI-3 immobilization
facility appears low if the total capacity of the
landfill is 7616 cubic yards as stated on
page D-51 of the application (7616 cubic yards =
about 1.5 million gallons or 375,000 gallons of
waste based on a waste volume of 25% of the total
volume). Justify the figures provided or revise
the quantities in Table 1-4.
The maximum waste volume provided in Table I-5
for the proposed immobilization facility IM-1 is
almost twice the maximum capacity shown on
page D-53 of the application. Clarify this
issue.
Include with list of maximum waste volumes an
estimation of the total volume of sludge in each
impoundment, and indicate if the sludge volume is
included in or separate from the total volume.
Some of the waste volumes included in the maximum
waste inventory for the impoundments are marked
as being nonhazardous. Since these wastes are
stored in hazardous waste impoundments along with
37
-------
> hazardous wastes and can easily become mixed,
they are considered hazardous wastes until
sufficient documentation is provided to indicate
Ithat they are nonhazardous. Revise the waste
volumes to reflect that all the wastes are hazar-
dous or document that they are not hazardous.
I
I
I
I
I
I
I
I-Id Inventory Removal, Disposal, or Decontamination
of Equipment; §§264.112(a)(3), 264.114
On page 1-16 of the application it states that
all equipment will be decontaminated by pressure
washing "whenever possible." Indicate when it is
expected that this procedure will not work and
what alternative procedure(s) will be used. Con-
sidering the variety of wastes handled at this
site it is likely that some other cleaning agent
besides pressurized water will be needed to
decontaminate the equipment. Describe the
procedure and/or criteria that will be used to
determine if the washwaters will be shipped
offsite or treated onsite, and describe the
onsite treatment procedure that will be used.
Provide additional details of the decontamination
trough, and any temporary decontamination troughs
or pads needed at the individual units (i.e.,
size, method of lining, method of water col-
lection, sump site, method used to preventing
splashing onto surrounding soil, etc.)/ and
method of collecting washwater from truck tires.
Some of the information requested below about
soil and washwater testing has been provided in
Section C-10 of the application; however, this
data was not referenced in Section I nor is it
complete. Provide the detailed information
requested in complete form, and if left in
Section C, provide appropriate references in
Section I.
The application indicates, on page 1-18, that the
washwaters will be tested to assure decontamina-
tion is complete. For the washwater testing
program provide a breakdown by unit of the
following:
f
o specific parameters to be tested for,
o justification of the parameters chosen,
o specific test procedures to be used, and
o . criteria (including justification for that
criteria) that will be used to determine if
decontamination is complete.
38
-------
I
I
I
I
I
I
K
I
I
I
I
1
I
I
1
I
On pages 1-2 through 1-4 the applicant has
provided a procedure for decontamination and
sampling of surface soils at the drum storage
areas, impoundments, staging areas and tanks.
The following comments apply to those procedures
in general, with additional specific comments as
applicable in items I-ld(l), I-ld(2), and I-ld(4)
below:
o Using visual observations is an acceptable
first step in identifying contaminated
areas. However, the applicant must also
provide a procedure whereby the visually
unaffected areas are tested for possible
contamination. Therefore, in addition to
the proposed testing frequency provided for
visually affected areas, provide a testing
frequency, and indicate on a plan view a
proposed sampling pattern, for visually
clean areas; since it is unlikely that the
proposed rate of 1 sample per 100 square
feet, which would result in over ISO samples
for drum storage #4 alone, would be used
everywhere. Provide a justification for the
frequency selected.
o Provide for each specific unit where this
procedure will be used, a list of the
proposed test parameters, justification for
those parameters, specific test procedures,
criteria to be used to judge if additional
soil removal is necessary, and a justifica-
tion for that criteria (i.e., background or
some other level).
o Provide additional justification of the
depth at which the sample is to be obtained.
o Provide a detailed description of the
procedures to be used to select background
sample, parameters it will be tested for,
and a justification of how that sample, or
samples, will be representative of the soil
at each specific unit.
o In light of the large surface areas covered
by some of these areas and the lack of a
synthetic or concrete liner (i.e., over
IE-,000 square yards for drum storage area,
#4), justify the assumption that only 20
cubic yards of contaminated soil would
require removal (assuming a removal of only
one foot in depth less than 4% of the drum
39
-------
storage area would be removed). While this
may well be the case, the estimated value
appears to be very optimistic for a facility
which handles large volumes of liquid
wastes.
The closure plans provided for the storage units
(containers, tanks, and surface impoundments)
indicate that the applicant will dispose of the
waste in the onsite landfills. However, in the
event that insufficient capacity were to exist in
the landfills at the time of closure, .or should
there exist some reason whereby these wastes can
not be placed in the landfill, an alternative
disposal plan must be provided. Therefore,
provide an alternative waste disposal plan which
lists specific alternative permitted hazardous
waste disposal facilities which would be used in
the event offsite disposal is required. Also
provide a detailed plan describing how the wastes
will be transported to the alternative site.
I-ld(l) Closure of Containers; §264.178
The following comments apply to the existing drum
storage area (Number 4) and the proposed drum
storage area (Number 27).
As discussed in Comment D-6j, the applicant's
proposed method of liquid stabilization needs
additional justification. Should the proposed
method be found to be unsuitable, the proposed
closure procedures for the two drum storage areas
will require revision. The procedure of placing
bulk liquids in the landfill for mixing is no
longer permitted, therefore the closure plan must
be revised to change those procedures. The ban
on disposal of bulk and containerized liquids in
landfills also affects liquids which are treated
with absorbents, therefore the use of absorbents
during closure will only be permitted under the
conditions set forth in Comment D-6j.
Pages 1-18 and 1-21 indicates that some drums may
be returned to a licensed drum reconditioner. If
this is the ca.se, describe the criteria to be
used to select which drums are disposed of onsite
and which are reconditioned. Also describe in
detail the procedures used to decontaminate the
drums before they are shipped offsite or indicate
why the drums do not need decontamination.
Page 1-19 provides a reference to Appendix D-l
which does not contain the material referred to.
Correct the reference.
40
-------
Based on the discussion on page 1-21 of the
application it would appear that during closure
corrosive wastes along with some other wastes
will be treated and disposed of in a different
manner than that discussed in Section D. Clarify
this issue.
As discussed in Comment D-ld above, the applicant
needs to provide a more detailed sampling plan
for testing the surface soils at the existing
drum storage area.
The closure plan for the existing drum storage
area calls for the drums to be moved to the
proposed drum storage, however no plan was
provided in case the proposed facility is not
built. Revise the plan for the existing drum
storage area and provide a plan which discusses
treatment and disposal of the drums and waste.
Provide a more detailed description of the
proposed decontamination procedure to be used for
the concrete pad at the proposed drum storage
area (i.e., types of solvents to be used, order
in which they are to be used, will brushing of
the surface be done, etc.).
I-ld(2) Closure of Tanks; §264.197
Unless otherwise noted, the following comments
apply to closure of the existing lindane storage
tank (Number 15), the proposed tanks T-l through
T7 (Numbers 21 through 26 and 31), and the
proposed tank storage area (Number 28).
As discussed in Comment D-6j, the applicant's
proposed method of liquid stabilization needs
additional justification. Should the proposed
method be found to be unsuitable, the proposed
closure procedures for the tanks will require
revision. The procedure of placing bulk liquids
in the landfill for mixing is no longer permit-
ted, therefore the closure plan must be revised
to change those procedures. The proposed method
of using absorbents to contain spills may also
need revision*.
Page 1-24 of the application contains two areas
that are not completely addressed. In the first
paragraph it states "Where disposal will take
place..." which indicates that disposal may not
take place, in which case what happens to the
wastewater? In the second paragraph it indicates
that drums containing spill saturated pillows
41
-------
I
will be temporary stored without indicating how
they will be disposed of. Clarify these two
issues and revise the text.
After decontamination of the existing and pro-
posed lindane tanks using sodium hydroxide is
completed, the tank should be rinsed out with
water to remove any alkaline residue. Provide a
justification for not rinsing with water or
revise the closure plan.
The applicant needs to add a statement to the
closure plan for the existing lindane tank
indicating that certification by an independent
engineer will be provided.
I The discussion provided on page 1-26 dealing with
treatment of the wastes contained within the
tanks needs expanded. The application must
. provide a detailed breakdown of the treatment and
I disposal procedures to be used for each tank's
contents and contaminated washwaters. The
discussion provided is unclear and it appears,
(based on that discussion, that some of the wastes
will not be disposed of. Also, based on the
variety of wastes stored in the tanks it would
I appear that some cleaning agents other than steam
will be needed to decontaminate the tank interi-
ors, however, the text implies that only steam
will be used, except for the lindane tank.
Provide a list of parameters and testing proce-
dures that will be used when testing the wash-
waters from each tank. Also provide the criteria
that will be used to evaluate the results and a
justification of that criteria. The general
statement provided at the bottom of page 1-28 of
the application is inadequate.
Based on the discussion provided on page 1-27 it
appears that the applicant intends to demolish
the concrete and block tank storage area without
decontamination in which case the demolition
waste must be disposed of in a permitted hazard-
ous waste landfill. Since it is unlikely that
the applicant plans to do this, revise the
application to provide detailed decontamination
procedures for the tank storage area.
>ld(4) Closure of Surface Impoundments; |§270.17(g),
264.228
Unless otherwise noted, the following comments
apply to all of the impoundments at this facil-
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ity, including the neutralization impoundment LC
(Number 7), oil lagoon (Number 9), neutralization
impoundment LF (Number 17), and the rainwater
basin (Number 13).
As discussed in Comment D-6j, the applicant's
proposed method of liquid stabilization needs
additional justification. Should the proposed
method be found unsuitable, the proposed closure
plans for the impoundments will require revision.
The procedures of placing bulk liquids in the
landfill for mixing is no longer permitted,
therefore the closure plan must be revised to
change those procedures.
For all impoundments provide a procedure for
stabilization of the sludges removed from the
impoundments. The sludge must, as discussed in
Comment D-6j, pass the paint filter test before
placement in the landfill and while the sludges
may pass the test it is quite possible that they
will not, and will therefore require stabiliza-
tion.
On page 1-30 of the application it states that
the sludges in the impoundments will be sta-
bilized at the rate of one part sludge to three
parts cement kiln dust. Since this is the same
ratio as that provided for the liquids, it seems
unlikely that the stabilized liquid will pass the
paint filter test (see Comment D-6j) and in fact
a higher waste to cement kiln dust ratio may be
required. As discussed in other comments, this
issue requires additional discussion and justifi-
cation.
As discussed in Comment I-ld above, the appli-
cant's proposed plan of soil contamination
testing and removal needs to be revised. In the
case of the unlined impoundments a plan which
provides for both visual inspection and soil
sampling and testing of the entire interior soil
surface area is required (in-place soil with a
permeability of 10 5 or 10"6 cm/sec is not
considered a liner). Also, it is reasonable to
assume that any impoundment with the soil perme-
abilities indicated, that has been in service for
several years has had some infiltration of the
liquid wastes into the soil. Therefore, it
should be assumed that the entire soil surface
(i.e. bottom and sides) has become contaminated
and could require removal at closure. Based on
the review of the proposed closure plan, the
applicant has not made this assumption, but has
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instead assumed that only limited areas or less
than 6 inches of the overall surface soil would
require removal (see Comment 1-4). The applicant
must provide test data to justify this approach
or make revisions in their application.
The reference to Appendix D-l on page 1-29 is
incorrect and needs to be revised.
When taking soil samples of the surface impound-
ment for contamination testing, samples must be
taken both from the impoundment bottom and from
the sidewalls below the high-water level.
For closure of the oil lagoon/ the applicant has
indicated on page 1-29 that treatability studies
will be needed before treatment of the wastes
within the lagoon can begin. The applicant must
either do a study now and provide detailed
results of that study, or provide a detailed
discussion of proposed study (i.e., provide test
procedures, sampling procedures and frequency,
and the criteria to be used in evaluating the
results, etc.). Some details of a plan to test
the liquids within the oil lagoon to determine if
they are still hazardous was provided in Sec-
tion C-8 which was not referenced in Section I.
However, the applicant must expand the informa-
tion provided to provide more details on evalu-
ation of the data, and provide appropriate
references in* Section I.
The proposed method of "washing" the earthen
sides of the oil lagoon with an emulsifying agent
requires considerably more discussion. The
applicant has provided no details of how the
proposed operation will work. The following
information, as a minimum, must be supplied:
o Detailed description of how the process will
be performed. For example, is the agent
pressure sprayed onto the soil and allowed
to sit or is it vacuumed just after
spraying?
o What is to prevent the pressure application
of the agent from forcing the contamination
deeper into the soil layer?
o Unless this process is carefully controlled,
surface erosion could occur. How will this
be prevented?
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o Will the vacuum totally remove traces of the
emulsifying agent or will some of it remain,
which would require an additional process to
remove?
o How will the washwaters from both the soil
"washing" procedure and from equipment
decontamination be stabilized for disposal?
o Will the vacuum also remove some of the
surface soil?
o The applicant should provide case histories
of the use of this procedure in the past,
including data indicating its effectiveness;
or provide results of a field test of the
procedure.
On page 1-30 of the application it indicates that
the oil lagoon will contain 63,000 gallons or
about 312 cubic yards of sludge at closure.
However on page D-48 of the application it states
that approximately 545 cubic yards of sludge
accumulates in that impoundment every year.
Clarify this issue.
Page 1-31 the application states that if contam-
inated subsoil from the oil lagoon can be treated
at the immobilization facility it will be dis-
posed of on-site. Provide a detailed description
of the treatability study that will be performed,
including test procedures and the criteria that
will be used to evaluate the results. The
applicant has provided some details of treat-
ability studies in Section C of the application;
however, no references were provided to this
material in Section I. Expand the material
supplied to address these comments and provide
appropriate references in Section I.
The oil lagoon section of the closure plan does
not indicate that a certification of closure
would be provided, as does the other closure
sections. Indicate that it will be provided.
On pages 1-34 and 1-37, the application states
that closure of the neutralization impoundments
LF and LC are based on the assumption that the
wastes within those impoundments are nonhazard-
ous. The application does not describe any
procedure for processing those liquids if they
are hazardous. Unless data is presented with the
application to demonstrate that liquid wastes are
45
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nonhazardous, the applicant must provide a
closure plan which treats them as hazardous
wastes. A testing plan for liquids in the
neutralization impoundments is provided in
Section C-7 of the application; however, this
information was not referenced in Section I.
Provide additional details about the evaluation
criteria and include appropriate references in
Section I.
The closure plan for impoundment LC must discuss
removal and disposal of the liquid wastes without
moving the liquid to impoundment LF (i.e., if LF
contains 1.45 million gallons there is no room
for the additional 168,000 gallons, see Comment
I-lc).
Based on a surface area of 4500 square feet, the
estimated quantity of 6 cubic yards of sludge in
impoundment LC, which is less than 0.5 inches of
sludge, seems low. The volume of 6 cubic yards
does not agree with the volume of sludge indi-
cated in the LC closure cost estimate provided on
page 10 of the March 1985 Fred C. Hart report.
Provide a justification of the sludge volume.
On page 1-35 of the application it states that
the contingent closure plan cover for impoundment
LC consists of the proposed IM-1 landfill liner;
however none of the drawings provided with the
application show impoundment LC being within the
limits of IM-1. Therefore, how will the liner
for IM-1 act as a cover for impoundment LC?
Revise the layout and design of IM-1, or provide
a revised contingent closure plan for impoundment
LC. If IM-1 will include impoundment LC, any
contaminated soil excavated from the impoundment
as part of the site grading for IM-1 must be
placed within a hazardous waste landfill. The
applicant must also provide a contingent closure
plan for impoundment LC to be used in case IM-1
is not constructed.
On page 1-37 of the application it states that
only about 185 cubic yards of sludge will exist
in impoundment LF, and that it is nonhazardous.
Later on the same page it states that there is an
estimated 720 cubic yards of sludge and it
implies that it is hazardous. Provide a justi-
fication of the estimated volume and provide
documentation showing that the sludge is non-
hazardous. Also revise the text to remove the
conflicting statements. ,
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As with the other impoundments, the application
does not state what will occur should the liquids
contained within the rainwater basin be untreat-
able using the proposed process. Provide an
alternative plan. Also, as discussed in Comment
D-6j, the liquids must be stabilized before
placement in the landfill, therefore revise the
rainwater basin closure plan to provide a proce-
dure for stabilization of the liquids.
Justify the volume of sludge estimated for the
rainwater basin (i.e., provide measurements of
the sludge depth and impoundment area)..
Page 1-40 of the application states that the
rainwater basin will be incorporated into IM-1;
however, none of the drawings provided show the
rainwater basin within approximately 1000 feet of
the IM-1. Therefore, the applicant must provide
a revised (from the one provided on page 1-40)
contingent closure plan for the rainwater basin.
See Comments I-le(2) through I-le(7) for comments
concerning the cover proposed for the contingent
closure plans for the impoundments.
I-le Closure of Disposal Units; §§270.14(b)(13),
270.21(e), 264.310(a)
Unless noted, the following Comments I-le(2)
through I-le(8) apply to immobilization facil-
ities (landfills) TI-3, IM-1, and IM-2. As
noted, these comments also apply to the contin-
gent closure plans provided, for the surface
impoundments.
On page 1-41 of the application it states that
Appendix D-l contains results of waste stabi-
lization tests; however, Appendix D-l contains
design calculations for the runoff control
facilities. The reference to Appendix C-6
containing testing data on the immobilized wastes
is incorrect since Appendix C-6 contains sampling
equipment and procedures. Finally, on page 1-41,
the reference to Section C-6, Table C-13 is also
incorrect. Page 1-42 contains a reference to
Appendix D-4 which is incorrect and reference to
Sections B-2(j)l and D-5b(2) which are incorrect.
As noted in the General Comments all the incor-
rect references need to be corrected.
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I-le(2) Cover Design: §§264.22S(a)(2)(iii), 264.310(a)
The applicant has provided two proposed cover
designs. The first which is to be used as
contingent covers for the impoundments meets the
EPA recommended cover design. The second cover
proposed for closure of the landfills (TI-3,
IM-1, and IM-2), does not meet the EPA recom-
mended design since it does not include a syn-
thetic membrane as part of the cover and the
cover layer thicknesses are less than those
recommended. As applicable, the applicant must
supply the following detailed data for both cover
designs:
o detailed drawings showing the cover layers,
thicknesses, slopes, and overall dimensions;
o provide a final grading plan for TI-3 and
the surface impoundment contingent closure
plans;
o the common name, species, variety, and rate
of application of the proposed cover crop
and fertilizer (a specific crop or crops
must be provided, statements of "such as
malojello" on page 1-44 are unacceptable);
o descriptions of the specific synthetic
membrane (liner) to be used, including
chemical properties, strength, and manu-
facturer's specifications and detailed
placement specifications (manufacturer's
specifications for a Water Saver 30 mil
liner were provided in Appendix 1-3; how-
ever, the application does not clearly state
that this is the liner that will be used in
all cases);
o a detailed description of the rationale used
for the cover selection;
o detailed material specifications (i.e. gra-
dation specifications, etc.) and descrip-
tions for the drainage layer materials and
filter fabric; and
t
o characteristics of the soil cover material,
including lift sequencing and placement
procedures.
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In several places in Section I-2d of the closure
plan the applicant refers to "calice" which is
assumed to be a spelling error and the correct
term is "caliche." Correct the text or provide
an explanation of "calice11 if that is the correct
term.
For both cover designs provide a gas venting
system or a demonstration that such a system is
not needed.
I-le(3) Minimization of Liquid Migration; §254.310(a)(1)
Since the proposed landfill covers, as described
on page 1-44 do not meet the EPA recommended
design, provide detailed engineering calculations
showing how the proposed covers will provide for
long-term minimization of liquid migration
through the cover.
I-le(4) Maintenance Needs; §§264.228(a)(2)(iii)(B),
264.310(a)(2)
Provide additional discussion of how the cover
will function with a minimal amount of
maintenance.
I-le(5) Drainage and Erosion; §§264.228(a)(2)(iii)(C),
264.310(a)(3)
Provide the following additional information for
both cover designs:
o engineering calculations demonstrating that
the proposed final slopes will not be
subjected to significant cover erosion,
including estimates of annual soil loss;
o engineering calculations demonstrating free
drainage of precipitation off of and out of
the cover (i.e., a demonstration of the
effectiveness of the drainage layer to
remove water which infiltrates the cover);
o engineering calculations demonstrating that
the drainage layer of the proposed landfill
cover design will not become clogged with
fines from the vegetation soil layer; and
o in view of the thin vegetation layer,
describe the effects of growth on the
drainage layer (i.e. will roots clog the
drainage layer).
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I-le(6) Settlement and Subsidence;
§§264.228 (a) (2) (iii) (D), 264.310 (a) (4)
The applicant has indicated that settlement of
the covers is not considered a problem. However,
in neither case were any calculations or data
provided to support that conclusion. Since the
waste will be removed at closure, settlement of
the impoundment covers is not likely to be very
great, however with the stabilized waste and
containers in the landfills, settlement of the
landfills could be a major problem. Therefore,
provide engineering calculations and supporting
data indicating the amount of potential settle-
ment of the cover and how the cover was designed
to accommodate that settlement. Provide an
analysis for both covers which address possible
waste consolidation due to waste dewatering,
biological oxidation, and chemical conversion of
solids to liquids.
I-le(7) Cover Permeability; §264.228 (a) (2) (iii)(E)
For both covers, demonstrate that the cover
system will have a permeability less than or
equal to that of the liner system. For the
landfill covers analyze both the liner system
existing in TI-3 and the proposed double liner
(as modified in accordance with the comments in
Section D-6) to be installed in the proposed
landfills (IM-1 and IM-2). On both pages 1-32
and 1-44 the applicant indicates that the caliche
material will have a recompacted permeability of
1x10""7 cm/sec or less with a reference to Appen-
dix E. The results of only one permeability test
were provided in Appendix E and no details were
provided as to how the test was performed. There
was a reference to the tests being performed in
accordance with ASTM procedures, however the only
ASTM soil permeability test, D2434 is for testing
of granular soils and is unsuitable for deter-
mining permeabilities that low. Provide addi-
tional information and laboratory testing data
(include full details of how the samples were
obtained and the testing was performed) which
demonstrates that sufficient material exists for
the units which will require a low permeable soil
cover, including the surface impoundments. Also,
since it is possible that the proposed method of
placing and compacting the caliche will not yield
a dense enough material to provide the required
permeability, provide a construction quality
assurance program meeting the requirements
discussed in Comments D-6g to assure that the
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constructed low permeable soil cover meets the •
design requirements. Finally, describe the
effect of root growth on the low permeable soil
in the landfill cover.
I-lf Schedule for Closure; §264.112(a)(4)
The applicant has provided a closure schedule in
Section I-3a of the application which does not
agree with other portions of the application.
For example, Table 1-3 indicates closure of the
four existing impoundments will occur from
October 1985 through March of 1986, while Table
D-14 indicates closure from June 1986 through
December 1986, while stating at the bottom of the
table that closure could take a "minimum" of five
years. Resolve these conflicts and present a
consistent closure plan throughout the applica-
tion which provides consistent starting and
completion dates. As discussed in comment D-4,
the' surface impoundments should be closed by
November 1988 unless a double liner system is
installed.
No closure schedule was provided in Section I-3c
of the application for the existing drum storage
area or the existing lindane tank. Revise the
application to include this information.
Finally, the applicant must provide an estimated
date to begin closure of all the proposed units.
The schedule provided on page 1-51 of the appli-
cation does not indicate if closure will begin in
1985 or 2085. Also, as shown,-the proposed
closure schedule (page 1-51) does not agree with
the closure plans (it implies that all units will
be closed within the same 180 day period). The
closure schedule must be arranged so that it
shows the relationships between all overlapping
and contingent 'activities.
1-2 Post-Closure Plan; §§270.14(b)(3), 270.17(g),
264.118, 264.228(c)(l)(ii), 264.310(b)
The applicant must supply a contingent post-
closure plan for all the surface imDoundments in
accordance with-§§264.228(c)(1)(iif. The contin-
gent post-closure plan must include, as applica-
ble, all items addressed in the plan provided for
the landfills, plus respond to all applicable
comments included in items I-2a through I-2c
below.
51.
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The post-closure plan must also contain the name,
address, and phone number of the person or office
to contact about the facility during the post-
closure period (in accordance with
§§264.118(a)(3)>.
I-2a Inspection Plant §§264.118(a),
264.228(c)(l)(ii), 264.310(b)
The post-closure inspection plan should include
copies of the inspection logs which will be used
during the inspection. Indicate where these logs
will be filed and the period of time which they
will be retained.
Considering the potential for cover settlement
(see Comment I-le(6)), justify only providing
semiannual inspections, at least in the first few
years after closure. Also, with inspections at
only six-month intervals and the proposed cover
design, the depth of leachate within the leachate
collection system could exceed the allowable one
foot; demonstrate how the system will be operated
to prevent the leachate head from exceeding one
foot.
Justify not repairing the stonnwater runoff
control berms or dikes when cracks are first
discovered.
Provide an inspection procedure for the gas
venting system, if installed, and the bench marks
(bench marks required by §§264.309 and
264.310(b)(6)).
I-2b Monitoring Plan; §§264.228(c)(1)(ii), 264.310(b)
The post-closure monitoring plan must address
monitoring of the leachate collection and detec-
tion systems. For example, the plan must detail
the sampling and testing of any leachate in the
leachate detection system and provide a procedure
for analyzing the quality and quantity of leachate
in the leachate collection system to determine if
the cover is functioning as designed or if
chemical or biological reactions are occurring to
generate leachate, etc.
Provide a list of materials and equipment that
will be needed to perform the common maintenance
items which will be required during the post-
closure period (i.e., repair of fence, mowing,
repair of erosion and settlement, replacement of
a well, etc.).
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Provide and describe a rationale that will be
used to determine the need for corrective action
(for example, how much settlement can occur
before corrective action is taken, etc.).
In Section I-4b of the application, it is implied
that the post-closure groundwater monitoring
system will consist of the present network of
three downgradient wells (1W-81, 2W-81, and
12W-83) and one upgradient well (11W-83). These
wells have been located based on structural
considerations to monitor the entire facility
with a single well network. The existing well
network is apparently screened in a relatively
deep water-bearing zone located near the base of
a massive gray mudstone unit. This zone occurs
at depths of 160 to 230 feet below ground surface
at the site.
The presence of a shallower groundwater zone
(Zone 1) has been documented in Section E of the
application. This groundwater is evidently
contained within sandy lenses located in a silty
unit on top of the massive gray mudstone. The
applicant has proposed in Section E-2a(2) of the
application to investigate Zone 1 with respect to
its potential for establishing individual detec-
tion monitoring programs at the two proposed
impoundments. As discussed previously in
Comment E-3, similar investigations to define
Zone 1 must be carried out at all existing
regulated land disposal units (as described in
Comments E-3 and E-5b) for the purpose of estab-
lishing detection monitoring systems in the
shallow zone at each applicable regulated unit.
The list of regulated units requiring individual
monitoring networks is set forth in Comment E-5b.
In keeping with the above requirement, the
applicant must propose a comprehensive post-
closure monitoring plan for these facilities. As
in the detection monitoring program, individual
programs must be developed for each applicable
regulated unit and include the following
features:
i
o Each individual regulated unit must be
monitored for an individual set of detection
monitoring parameters to be chosen based on
the type of wastes placed (or to be placed)
in each unit and the relative mobility/
stability, persistence, and detectability of
the waste constituents in groundwater. As
discussed in Comment E-Sa, a single set of
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parameters for the entire facility is not
appropriate since individual units have
likely accepted different wastes.
o Background values must be established
relative to each individual regulated unit
as discussed in Comment E-5c. In certain
cases, it is possible that wells located
downgradeent from one regulated unit could
function as background wells for other
regulated units located further downgradi-
ent. Background value determination should
be based on continued sampling through the
post-closure period so that the source of
any existing or future leakage may be
identified should the presence of hazardous
constituents be detected in groundwater.
o Proposed sampling and analytical methods
need to be tailored to each regulated unit
to account for possible differences in the
types of parameters monitored at each unit
(see Comments E-5d(l)(2) and (3)).
o Statistical comparisons must be performed
using background and downgradeent well data
from the individual well networks so that
the presence/absence of leakage may be
defined for each applicable regulated unit
(see Comment E-5d(7».
•
I-2c Maintenance Plan; §§264.228(b),
264.228(c)(l)(ii), 264.310(b)
Describe in greater detail the preventative and
corrective maintenance procedures, equipment
requirements and material needs for the following
items in the maintenance plan.
o stormwater control system,
o groundwater monitoring system including
possible well replacement,
o leachate collection/detection systems
(including detailed leachate testing pro-
cedures), and
o making erosion repairs.
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1-3 Notice in Deed; §§270.14(b)(14), 264.120,
264.117(0), 264.119
A copy of the actual Notice to Deed must be
submitted with the permit application. It is
insufficient to only state in the application
that it will be prepared. A copy of the notice
that will be used is required.
1-4 Closure Cost Estimate; §§270.14(b)(15), 264.142
The applicant has provided closure cost estimates
in the application (pages 1-61 through 1-75) and
in Section C-l of the March 1S85 Fred C. Hart
report. The data provided is insufficient and
confusing. In addition, some of the values
provided do not agree. For example, page 1-62
provides a cost of $156,210 for closing the oil
lagoon while the Fred C. Hart report lists a cost
of $127,200.
A revised cost estimate must be provided which
replaces all the existing cost estimates and
which addresses the cost effects of any revisions
to the proposed closure plan as a result of the
comments provided in this NOD. In addition, the
revised cost estimate must address the following
items:
o Provide a summary showing all the site units
and their expected closure costs. Each
summary cost must be supported by a detailed
breakdown of the total cost. Some breakdown
sheets were provided, however they are
confusing and difficult to follow (for
example, page 4 of Section C-l of the
Fred C. Hart report provides a breakdown for
closure of a tank but does not indicate
which tank).
o The cost estimate provided was intended to
reflect the applicant's costs. However, the
closure cost estimate must reflect the costs
of having outside contractors perform the
work (including contractor fees, administra-
tive costs/f profit, etc.).
o All labor rates must be fully burdened
(i.e., include cost of insurance, taxes,
etc.) and should be equivalent to costs for
local construction workers.
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Each closure cost estimate must stand on its
own. For example, the wastes from the
existing drum storage area must be treated
or disposed of, not sent to the proposed
drum storage unit.
The closure cost estimate must reflect the
cost for treatment and disposal of the
maximum waste volumes. For example, the
cost estimate for the oil lagoon in Sec-
tion C-l of the March 1985 Fred C. Hart
report only deals with about one half of the
maximum waste inventory, and the lindane
tank closure estimate only disposes of 7000
gallons, not the 8000-gallon maximum capa-
city of the tank. The closure cost estimate
must also reflect the costs of removal and
disposal of the maximum anticipated volumes
of sludge in each impoundment.
Provide a list of all unit costs, along with
justification and supporting documentation
for each. Some of the unit prices seem low
considering site conditions and normal
construction costs. For example, the unit
price of $0.50 per cubic yard for cement
kiln dust seems low when transportation
costs for getting the dust to the site are
included and since few, if any, cement
plants give the dust away free. Also, a
cost of $5.00 per cubic yard to move con-
taminated material seems low if burdened
labor rates are used and the cost of lost
production time due to the wearing of
personnel protection equipment is included.
The closure costs for the container storage
areas, tanks, and impoundments must include
a cost for offsite disposal of the wastes in
the event onsite disposal cannot be done.
For example, if TI-3 is full and the im-
poundments have to be closed before IM-2 is
opened, the waste would have to go off site.
The applicant must also provide cost esti-
mates for shipment of the waste to a permit-
ted hazardous waste site. These cost
estimates must be documented. In addition,
in light of the lack of disposal sites in
Puerto Rico, the costs for off-site shipment
and disposal should include a site outside
of Puerto Rico. When computing the total
closure cost it must also be assumed that
all washwaters will also require off-site
disposal.
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Detailed costs must be provided for the
surface impoundment contingent closure
plans. Also provide costs for closing LC
and the rainwater basin assuming IM-2 is not
constructed.
While insufficient design data has been
provided to verify this, normally some
regrading of surface impoundments and
landfills is needed to provide for positive
drainage before the cover is placed.
Therefore, provide a demonstration that
grading is not required or include an item
for site regrading before closure in the
contingent closure cost estimate and in the
landfill closure costs.
On page 1-16 of the application it states
that some of the liquid waste in the oil
lagoon can be recycled, thus reducing the
closure cost. For the closure cost estimate
it must be assumed that all liquid wastes
are hazardous, cannot be recycled, and must
be stabilized and disposed of as hazardous
waste. This would include liquids in
containers, all tanks, and all surface
impoundments along with washwaters and
liquids produced during decontamination
procedures.
The existing closure cost estimate is based
on the applicant's current liquid stabiliza-
tion procedures. As noted in Comment D-6j,
the procedure of dumping the bulk liquids in
the landfill (or immobilization facility)
for mixing is no longer permitted. There-
fore, the closure cost estimate must reflect
the cost of stabilization of the liquids in
a mixer and should include stabilization of
the liquids from containers, tanks, and
surface impoundments, and the washwaters.
The applicant has not provided a breakdown
of the total number of soil and washwater
samples that will require testing during
closure. Such a breakdown must be provided
along wizh a documented unit price for the
testing.
While the estimated quantities of con-
taminated soil provided may end up being
accurate, for the purposes of the cost
estimate a more conservative figure should
be used. See Comments I-ld and I-ld(4).
57
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o Based on the unusual method of decontamina-
tion to be used in the oil lagoon (washing
of the soil slopes) the cost estimates
should not only include a documented esti-
mate of the soil washing proposal, but also
. a line item for removal and disposal of
contaminated soil in case the "washing" does
not work.
o Based on the size and complexity of the site
closure operations, along with a large
amount of unknowns (i.e., the amount of
contaminate soil could easily double) a
contingency of only 10% seems low. Provide
a higher contingency or justify the 10%
value.
While all the revisions to the closure plan
resulting from response to this NOD must be
reflected in the closure cost estimate, the
following items are viewed as having major cost
impact:
o the method of liquid and sludge stabiliza-
tion,
o the type of cover used on the landfills, and
o the quantities of contaminated soil.
1-5 Financial Assurance Mechanism for Closure;
§§270.14(b)(15), 264.143
I-Sa Closure Trust Fund; §§264.143(a), 264.151(a)(1)
A signed copy of the closure trust fund agreement
with the wording required by §264.151(a)(1) and a
formal certification of acknowledgment must be
provided with the permit application. ?age 1-76
of the application indicates that this will be
provided later; however, for existing facilities
it must be provided with the application. The
copy provided in Appendix 1-4 was illegible.
1-6 Post-Closure Cost Estimate; §§270.14(b)(16),
264.144
•
The post-closure cost estimate must include the
post-closure costs associated with the contingent
post-closure plans for the surface impoundments.
As presented in Table 1-8, page 1-78, the post-
closure cost estimate is insufficient. The
estimate must include detailed cost breakdowns
58
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for each item including as a minimum justifica-
tion for unit prices, units (i.e., how many
samples will be analyzed, etc.), justification
for those units and replacement costs for items
which will likely require replacement, such as
bench marks and monitoring wells.
As presented, the cost estimate seems low con-
sidering the site of the facility and the number
of landfills (eight).
The cost estimate must also be revised to reflect
1985 costs, the estimate provided on page 1-77 of
the application is for September 1983.
The post-closure cost estimate must include an
item for removal and disposal of leachate col-
lected from the landfill leachate collection and
detection systems. For this cost the applicant
must provide a documented estimated quantity of
leachate and provide a cost for offsite disposal
of the leachate.
1-7 Financial Assurance MechanjL_sm_f_o_r_ Post-closure
Care: §§270.14(b)(16), 264.145
I-7a Post-Closure Trust Fund; §§264.145(a),
264.151(a)(l)
A signed copy of the post-closure trust fund
agreement with the wording required by
§264.151(a)(1) and a formal certification of
acknowledgment must be provided with the permit
application. Page 1-77 of the application
indicates that this will be provided later;
however, for existing facilities it must be
provided with the application. The copy provided
in Appendix 1-4 was illegible.
-
59
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APPENDIX H
LIQUIDS IN LANDFILL TI-3
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LIQUIDS IN LANDFILL TI-3
Date Disposed
5/15/85
5/15/85
5/15/85
5/15/85
6/20/85
5/20/85
5/23/85
5/23/85
5/23/85
6/3/85
5/23/85
6/3/85
6/3/85
6/21/85
7/10/85
8/2/85
8/2/85
7/10/85
7/10/85
7/10/85
7/10/85
7/10/85
7/31/85
7/31/85
7/31/85
7/31/85
8/2/85
8/2/85
8/2/85
107 785
Quantity
May
2200 G
2000 G
275 G
2145 G
2200 G
193 G
25 G
100 G
110 G
1650 G
55 G
1 DM
2200 G
June
2200 G
13191 G
2200 G
July
2200 G
1826 Ibs
458 Ibs
12434 Ibs
591 Ibs
456 Ibs
3080 G
1100 G
220 G
2420 G
1850 G
165 G
189 Ibs
3 DM
Waste
D013
D013
D008
F006
0013
D006, D007
D007, D008
D008
D008
D013
0008
D008, D009
D013
D013
U151
D013
D013
U154
U044
N/A (Noted
Piperacillin Liquid)
N/A (Methotrexate
Liquid)
N/A ( " " )
D001
D001
D001
D001
0013
D010
D010
U151
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Date Disposed Quantity Haste
August
10/26/85 2000 6 D013
10/26/85 2200 G 0013
9/23/85 1/8 G U151
9/23/85 4 G D009
10/26/85 2000 G 0013
September
9/23/85 660 G 0008
9/23/85 710 Kg 0008
9/23/85 275 G 0009, DOO?
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