NEIC
EPA-330/2-86-014
RCRA COMPLIANCE INVESTIGATION
IT CORPORATION, VINE HILL FACILITY
Martinez, California
September 1986
National Enforcement Investigations Center, Denver
CJ.S. Environmental Protection Agency
Office of Enforcement
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE -OF ENFORCEMENT AND COMPLIANCE MONITORING
EPA-330/2-86-014
RCRA COMPLIANCE INVESTIGATION
IT CORPORATION, VINE HILL FACILITY
Martinez, California
September 1986
Eugene Lubieniecki
John Ellison
Timothy Meszaros
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CONTENTS
EXECUTIVE SUMMARY
INTRODUCTION 1
SUMMARY OF FINDINGS AND CONCLUSIONS 10
WASTE SAMPLING/ANALYSIS 10
WASTE TRANSFER 12
SECURITY 12
FACILITY INSPECTION RECORDS 12
PERSONNEL TRAINING 13
CONTINGENCY PLAN 14
OPERATING RECORD/WASTE TRACKING 14
ANNUAL/BIENNIAL REPORT 15
CLOSURE PLAN 15
FINANCIAL RESPONSIBILITY 15
CONTAINERS 16
SURFACE IMPOUNDMENTS 16
TANKS 17
INCINERATOR 18
CENTRIFUGE 18
PRIOR RELEASE DOCUMENT 18
TECHNICAL REPORT'
INVESTIGATION METHODS : 19
FACILITY DESCRIPTION AND OPERATIONS 21
WASTE SAMPLING/ANALYSIS/LABORATORY PROCEDURES 24
WASTE HANDLING UNITS AND FACILITY OPERATIONS 28
FINDINGS 56
WASTE SAMPLING/ANALYSIS/LABORATORY PROCEDURES 56
WASTE HANDLING UNITS AND FACILITY OPERATIONS 62
Waste Transfer 62
Security 64
Facility Inspection Records 65
Personnel Training 74
Contingency Plan 76
Operating Record/Waste Tracking 76
Annual/Biennial Reports . 80
Closure Plan 81
Financial Responsibility 81
Containers 82
Surface Impoundments 84
Tanks 93
Incinerator 102
Centrifuge 106
Prior Release Document 108
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CONTENTS (cont.)
APPENOICIES
A CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD ORDER NO. 78-76,
SAN FRANCISCO BAY REGION
B VINE HILL INTERIM STATUS DOCUMENT
C VINE HILL HAZARDOUS WASTE FACILITY PERMIT (EFFECTIVE SEPTEMBER 26,
1983)
D A SUMMARY DESCRIPTION OF THE OPERATIVE PROCEDURES AND DESIGN
FACTORS TO PROTECT IGNITABLE AND REACTIVE WASTE - FEBRUARY 6,
1986 IT SUBMITTAL TO EPA REGION IX IN RESPONSE TO EPA COMPLAINT
E IT MEMO REGARDING WASTE TREATMENT IN TANK TRUCKS
F TANK 61 CERTIFICATION
G FIGURE FROM FEBRUARY 6, 1985 IT SUBMITTAL TO EPA REGARDING TRANSFER
OF WASTE FROM VINE HILL TO BAKER
H WASTE TRACKING AT IT, VINE HILL
I SEPTEMBER 10, 1984 LETTER FROM IT TO CRWQCB NOTIFYING OF THE CHANGE
OF SERVICE OF IMPOUNDMENT 102B
FIGURES
1 IT, Vine Hill Facility Location 2
2 Vine H111 Facility Plan 4
3 Vine Hill Treatment Plant Plan 22
TABLES
1 Chronology of Applicable Harzardous Waste Management
Regulations, Permits, etc., IT, Vine Hill 6
2 Summary of Prior EPA/State Compliance Inspection Results .... 8
3 Surface Impoundments 30
4 Incoming Waste Constituents Received in Vine H111
Hazardous Waste Units 33
5 Hazardous Waste Storage and Treatment Tanks 42
6 Fuel/Reagent Storage Tanks 43
7 Summary of Laboratory Records Review 57
8 Treatment in Tank Trucks 85
9 Ignitable and Restricted Waste Improperly Placed
in Surface Impoundments 87
10 Record of Use of Tank 61 for Harzardous Waste Storage 95
11 Selected Unloading Locations of Acid Wastes With
Normalities Greater Than 1 99
12 IT Tank Certification Information 101
13 Summary of Incinerator Waste Feed Analysis
Records Review 104
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EXECUTIVE SUMMARY
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INTRODUCTION
The National Enforcement Investigations Center, at the request of the
Toxics and Waste Management Division, EPA Region IX, conducted a comprehen-
sive RCRA* compliance investigation of the IT Corporation, Vine Hill (IT)
waste treatment, storage and disposal facility near Martinez, California
(EPA ID #CAD000094771). The primary objective of this investigation was to
determine the compliance status of the IT facility with applicable RCRA
requirements and the associated environmental permits, licenses, etc. To
accomplish this objective, NEIC:
Reviewed and evaluated relevant records and documents from EPA
Region IX and California State Department of Health Services (DHS)
files
Conducted an onsite inspection of the IT facility between March 3
and March 21, 1986
The facility inspection included review and evaluation of:
Past and present waste handling units and procedures
Onsite laboratory procedures, plans and documentation for waste
pre-acceptance, identification and verification
Selected waste tracking and disposal records and documents
Selected facility inspection and personnel training records and
the facility inspection and training plan
The IT, Vine Hill facility is located east of Martinez, California,
about 20 miles northeast of San Francisco [Figure 1], The 24-acre facility,
originally tidal flats, is bordered on the north and west by the Acme Land-
fill, on the east by marshland and on the south by the Martinez Gun Club.
A western portion of the Vine Hill facility is occupied by the IT Oil
Resource Conservation and Recovery Act
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1
;ooo
t
IN
(revised
i
o' , IMM :':'-[3}. ^N
0 1000 2000 3000 «OOO 5000 6000 7000 FEET '-^0 *jl / ^*0
1 5
0 1 KILOMtTCH + \
CONTOUR INTERVAL 20 FEET
DOTTED LINES REPRESENT 5 FOOT CONTOURS
FIGURE 1 IT,
from IT, Vine
VINE HILL FACILITY LOCATION
Hill RCRA Part B permit application)
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Reprocessing facility (EPA ID 0CAD000092619) which has processed waste from
Vine Hill hazardous waste operations. These two facilities are within a
common perimeter fence. The IT, Baker facility (EPA ID #CAD089680250),
which also receives waste material from Vine Hill, is located southeast of
Vine Hill just across Pacheco Creek. Prior to IT's purchase of the Vine
Hill property in 1958, the area was reportedly used for disposal of munic-
ipal refuse. The current facility is built on this old disposal area. It
is unknown if any hazardous waste was disposed of at the site prior to IT
ownership.
Information regarding early site activity is limited; however, aerial
photographs of the site taken in July 1958 show that most of the site was
occupied by two large surface impoundments. These impoundments evolved
into about 14 separate units by April 1968. In December 1972, there were
only seven distinct units but the number was increased to eight by 1974.
There were still eight distinct units in 1983 but their locations had
changed to a configuration that is similar to that which was present during
the NEIC inspection [Figure 2].
According to IT personnel, initial waste handling activities at the
site involved management of used oils. This activity evolved into the
current IT Oil Reprocessing facility. Chemical waste treatment at Vine
Hill began in October 1967. Early operations were apparently very similar
to current activities; waste storage and treatment in tanks and surface
impoundments. In 1970, IT purchased 135 nearby acres which became the IT
Baker facility, a series of evaporation surface impoundments used primarily
to evaporate wastewater received from Vine Hill.
In the early to mid-1970s, IT installed a fume* and liquid waste
injection incinerator. This unit basically replaced an older 'fume only1
incinerator installed at some prior unknown date. A centrifuge operation
for sludge dewatering was added in late 1984. In late 1985, Vine Hill pur-
chased property immediately southeast of the facility known as the "Acme
property." Although there are four surface impoundments on this property,
they currently are not in use.
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IT OIL
REPROCESSORS
FACILITY
ENTRANCE
FENCE LINE
DRUM -„_
STORAGE^0
6i\ AREA
: 'CHARLIES ALLEY*
SCALE—<«•!
FIGURE 2 VINE HILL FACILITY PLAN
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IT Vine Hill has about 90 employees working three shifts, 5 days a
week and usually one shift on weekends. The facility is equipped with an
onsite analytical laboratory which performs waste analysis for this and
several other IT waste management facilities. General onsite waste treat-
ment and disposal activities involve storage, treatment and/or disposal in
tanks, surface impoundments and the incinerator and centrifuge.
The Vine Hill facility has managed hazardous waste under a complex
series of regulations, permits, licenses, and orders issued by several regu-
latory agencies, predominantly the EPA, the California Department of Health
Service (DHS) and the California Regional Water Quality Control Board
(CRWQCB). Various operating permits related to air emissions were also
issued by the Bay Area Air Quality Management District (BAAQMD). A chronol-
ogy of applicable hazardous waste management regulations, permits, licenses,
etc. from November 1980 to present, was compiled by NEIC through discussions
with the various regulatory agencies and review of documentation, in Table 1.
Vent gases from tank treatment and storage
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Table 1
CHRONOLOGY OF APPLICABLE HAZARDOUS WASTE
MANAGEMENT REGULATIONS, PERMITS, ETC.
IT, Vine Hill
Effective Dates
Regulations, Permits, etc.1
November 19, 1980 - April 5, 1981
April 6, 1981 - June 3, 1981s
June 4, 1981 - December 31, 1982
January 1, 1983 - September 25, 1983
September 26, 1983 - Present
40 CFR 2652; CHWMR3 (CAC4,
Title 22)
40 CFR 265; CHWMR (CAC, Title
22), Interim Status
Document6
CHWMR (CAC, Title 22),
Interim Status Document
40 CFR 2657, CHWMR (CAC, Title
22), Interim Status Document
40 CFR 265, 40 CFR 2648 CHWMR
(CAC, Title 22), Interim Status
Document, Final Hazardous Waste
Facility Permit9
i
2
3
4
5
6
7
Various operating permits related to air emissions were also
effective during this time period Jbut have not Jbeen listed here.
Title 40t Code of Federal Regulations, Part 265 (interium status
regulations)
California Hazardous Waste Management Regulations (promulgated
under the California Hazardous Waste Control Act, CHWCA)
California Administrative Code
Date California received RCRA Phase I interim authorization.
Issued by California Division of Health Services.
Article 5.5, 25159.5 (Jb) of the CHWCA, effective January 1, 1983
incorporated all regulations promulgated under RCRA, including
subsequent amendments.
Final regulations became effective for tank treatment and
storage and container storage when the State issued IT the final
Hazardous Waste Facility permit.
California issued permit for specified treatment and storage
operations.
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Prior to the effective date of RCRA (November 19, 1980), the facility
was operated under California Hazardous Waste Management Regulations of the
California Administrative Code, Title 22* and California Regional Water
Quality Control Board Waste Discharge Order No. 78-76 [Appendix A].** In
addition, DHS issued Vine Hill an interim status document [Appendix B] effec-
tive April 6, 1981, as a site-specific set of additional regulations.
The State of California received RCRA Phase I interim authorization on
June 4, 1981 and Phase II(a) authorization in January 1983. Under this
authorization, the California Department of Health Services (DHS), the des-
ignated State agency, issued IT a hazardous waste facility permit for tank
treatment and storage and container storage (effective September 26, 1983).
In 1983 the California Hazardous Waste Management Regulations [Appendix C]
were amended to include all of 40 CFR 265/264 regulations, including any
subsequent Federal amendments.
Vine Hill submitted a RCRA Part B application for the surface impound-
ments and incinerator to EPA Region IX in August 1983. This was revised to
comply with a subsequent notice of deficiency and resubmitted to EPA on
April 5, 1985. The revised Part B application was under review by EPA and
the State during the NEIC investigation.
Although the State of California lost RCRA interim authorization on
January 31, 1986, a memorandum of understanding between EPA and DHS indi-
cated that facilities such as IT were still regulated by State-promulgated
regulations and permits (including the incorporated federal requirements)
during the NEIC site inspection in March 1986.
EPA Region IX and California DHS have inspected the Vine Hill facility
for compliance on several occasions [Table 2]. The March 1986 NEIC compli-
ance inspection identified problems in all of the areas cited in Table 2.
* Issued under the California Hazardous Waste Control Act of 1977
** Issued under the Clean Water Act through State authorization, currently
in effect.
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Table 2
SUMMARY OF PRIOR EPA/STATE COMPLIANCE INSPECTION RESULTS
AREAS OF INADEQUATE OPERATION/RECORDS*
Inspection
Date
11/01/83
02/08/84
04/12/84
(Appeared
September
complaint)
Secondary Tank Centrifuge Dike Cover
Freeboard Containment Operation Erosion
X X
X X X
X X
in
1984
Security
(Holes in Fence)
X
X
Tank Inspection
Records
X
The 3/3-21/86 NEIC inspection identified problems in all of these areas.
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During the April 12 through 13, 1984 EPA/DHS inspection, areas of
noncompliance included inadequate groundwater monitoring, site security,
waste analysis and inspection plans and inadequate surface impoundment free-
board. Both Federal and State agencies subsequently filed cases against
IT. A Notice of Violation was issued August 3, 1984 and Compliance Orders
were submitted September 27, 1984. The State settled their case against IT
with a fine and Cleanup and Abatement Order No. 85004 (January 16, 1985).
The Federal case is pending.
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10
SUMMARY OF FINDINGS AND CONCLUSIONS
IT treats, stores and disposes of hazardous waste as defined and
regulated under RCRA. The facility has been regulated under a RCRA program
delegated to the State of California and, although the State lost its author-
ity to administer this RCRA program on January 31, 1986,* EPA and the State
have an agreement under which the State will continue to administer the
RCRA program until the State receives final authorization. Therefore, the
facility was operating under the State program during the NEIC investigation.
The California DHS issued a Hazardous Waste Facility Permit (HWFP) to IT
regulating facility treatment and storage operations in tanks and containers.
Operations not covered by the permit, such as incineration and treatment,
storage and/or disposal in surface impoundments, are regulated by the Interim
Status Document (ISO), also issued by DHS. All facility operations are
covered under State regulations [California Administrative Code-CAC] which
incorporated by reference Federal regulations, 40 CFR 265/264, in 1983.
The NEIC investigation of IT's waste handling operations and records
showed IT was not in compliance with the requirements of the State-issued
ISO or HWFP, the CAC and/or 40 CFR 265/264, as summarized below.
WASTE SAMPLING/ANALYSIS
HWFP Section II, Condition All provisions of the DHS-approved Waste
5 and Section III, Condi- Analysis Plan (WAP)** were not followed.
tion 7, ISO Section III, All incoming waste characterization
Condition 3; 22 CAC analyses, as specified in the WAP, are
§67102, 40 CFR not being performed or the results not
265.13/264.13 recorded.
* Under Federal regulations, states which have not received full RCRA
authorization by January 31, 1986, lost any partial authorization and
the RCRA program was delegated back to EPA.
** This includes any supplements submitted to EPA as a result of enforce-
ment action.
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11
All pre-acceptance packages describing
waste received do not contain all the
information required by the WAP.
All waste sampling procedures specified
in the DHS-approved WAP were not followed.
Waste are not analyzed for ignitability
by an approved method and the WAP does
not contain the rationale for the use of
hydrocarbon vapor pressure determination
used in lieu of ignitability testing.
The results of treatability/compatibility
testing has not been conducted or recorded
or maintained.*
Each waste load received has not been
adequately inspected/analyzed to deter-
mine if it matches the identity of the
waste specified on the accompanying
manifest.
Some of the analytical procedures fol-
lowed would not provide reliable quanti-
fication of the constituents present.
Finally, Vine Hill has accepted
waste which does not match the character-
istics of the waste approved during the
predisposal sample analysis and evaluation.
Required by February 1985 IT submittal to EPA
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WASTE TRANSFER
12
22 CAC 6 §66471
40 CFR 262.11
February 6, 1985
IT submittal to EPA
Vine Hill transferred waste from surface
impoundments to another facility (Baker)
without determining if it was hazardous
and identifying waste characteristics.
Waste analyses specified on IT logs were
not always performed prior to transfer.
Additionally, records were inadequate to
determine the quantity of waste trans-
ferred; the transferred waste was not
manifested.
22 CAC Article 6
SECURITY
The waste source for the solids generated
during the centrifuge operation has not
always been accurately identified on the
hazardous waste shipping manifest.
HWFP Section III, Condi-
tion 8 ISO Section II,
Condition 17 22 CAC 18
§67103 40 CFR 265.14/
264.14
FACILITY INSPECTION RECORDS
IT was not maintaining their hazardous
waste area perimeter fence in good condi-
tion, because several holes were observed.
Some, but not all, of these holes were
repaired during the NEIC inspection.
HWFP Section III, Condi-
tion 9, ISO Section III,
Condition 5, 22 CAC 18
§67104 40 CFR 265.15/
264.15
Facility inspections have either not been
conducted, or the results not recorded or
maintained for all areas of general facil-
ity inspections (Facility Inspection Plan).
For the period March 1983 to March 1986,
108 of 1,275 inspection records required
by the inspection plan (about 9%) could
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13
HWFP Section II, Condi-
tion 5 and Section IV,
Condition 3(d) and II 5,
(Operations Plan p.42)
February 6, 1985 IT
submittal to EPA Region IX,
Exhibit 13
HWFP Section XI, Condi-
tion 3(a)(2), ISO Sec-
tion III Condition 5(d)
not be found for the three types of IT
inspections. Additionally, 958 of the
1,167 inspection records reviewed (more
than 82%) were deficient. The March 7,
1986 daily inspection and the weekly
inspection records for the week of
March 14, 1986 were incomplete and/or
deficiencies found during the inspections
were not recorded. Finally, IT is not
conducting all of the inspections of the
Vine Hill/Baker pipeline.
Daily tank waste level determinations
have either not been conducted, recorded
or maintained. About 70% of the required
records were missing and 69% of the ones
that were provided were deficient.
IT has either not conducted, recorded or
maintained records of daily surface
impoundment pH measurements. About 78%
of the records were missing and 60% of
the documents provided were deficient.
All records of hourly observations of
incinerator stack emissions have either
not been conducted, recorded or main-
tained. About 45% of the records
reviewed were deficient.
PERSONNEL TRAINING
HWFP Section III, Condi-
tion 10, ISO Section III,
IT has not followed its DHS-approved
training plan. Employees are either not
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14
Condition 6, 22 CAC 18
§67105 40 CFR
265.16/264.16
receiving the required training or
not properly recording training and job
experience. Records reviewed for 10 IT
employees showed initial training was
not completed within 6 months of initial
employment and/or updated annually.
Also, the DHS-approved training plan in
the March 14, 1983 operations plan is
inadequate because it does not address
training for responses to ground-water
contamination incidents.
CONTINGENCY PLAN
HWFP Section III Condi-
tion 17, ISO Section III,
Condition 15, 22 CAC 20
§67143 40 CFR 265.547
The DHS-approved IT site Contingency Plan
has not been modified to reflect changes
in emergency equipment. The plan cur-
rently shows the existence of eyewash
stations/safety showers that have been
moved.
OPERATING RECORD/WASTE TRACKING
HWFP Section III, Condi-
tion 19(b) ISO Section IV,
Condition 1 22 CAC 21
§67163 40 CFR 265.757
264.73
Facility operating records are not com-
plete. The existing operating record
does not identify method(s) and date(s)
of treatment, storage and disposal of
every hazardous waste load received at
the facility. All of the facility operat-
ing records were not being maintained
onsite during the NEIC inspection.
Finally, the location and quantity of
each hazardous waste load received has
not been recorded on a map or diagram
for each disposal area.
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ANNUAL/BIENNIAL REPORT
15
HWFP Section III, Condi-
tion 19(c)22 CAC 21
§67165 40 CFR 265.757
264.75
All required information was not submit-
ted on the facility annual/biennial
reports. Prior to 1985, the reports
did not show the EPA or State identifica-
tion number for each hazardous waste gen-
erator and describe quantity and method
of treatment, storage and disposal of
each hazardous waste.
CLOSURE PLAN
HWFP Section III, Condi-
tion 20, ISO Section V,
Condition 2,
22 CAC Article 23 §67212
40 CFR 265.112/264.112
FINANCIAL RESPONSIBILITY
IT's DHS-approved Closure Plan is incom-
plete because it does not include a
description on how impoundments 102A and
102B are to be closed nor does the Plan
address how any partial closures of the
facility will be conducted.
HWFP Special Condi-
tion 21(a)(l)
ISO Section VI l(a)
22 CAC 17 § 67002(a)
40 CFR 265.142(a)
IT's closure estimate is not adequate
because it does not address the cost of
closure at the point in the facility's
operating life when the extent and manner
of its operation would make closure the
most expensive. IT assumes use of tanks,
ponds and pumps instead of shutdown with-
out the use of onsite facilities necessi-
tating more expensive offsite disposal.
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CONTAINERS
16
HWFP Section IV, Condi-
tion 2 and Section II,
Condition 6(i) 22 CAC Art-
icle 24 40 CFR 264*
Subpart I
The drum storage area, used to store
ignitable waste, is not located 50 feet
or more from the property line. The
Operations Plan does not identify this
as a container storage area and weekly
inspections of this area are not con-
ducted. DHS was apparently not notified
of the use of this area. Also, because
this was identified as the only drum
storage area at Vine Hill, the March 26,
1985 RCRA Part A application is inaccurate
because it overestimates the facilities
drum storage capacity by almost two orders
of magnitude.
HWFP Section II
Condition (6)(i)
Hazardous waste has been treated in trans-
porting tank trucks onsite without notify-
ing DHS of this activity.**
SURFACE IMPOUNDMENTS
ISO Section XII
22 CAC Article 15
22 CAC Article 26
22 CFR 265 Subpart K
Surface impoundments have been improperly
used to dispose of "restrictive" and
ignitable hazardous waste. The facility
has not maintained the required freeboard
levels in the impoundments and several of
the impoundments did not have freeboard
markers during the NEIC inspection.
There were at least 232 days between
March 1983 and March 1986 when one or
**
DHS issued IT a permit for hazardous waste stored and treated in tanks
and containers so Part 264 regulations apply.
Treatment in tank trucks is considered to be treatment in containers.
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17
ISO, Section I,
Condition 4(c),
22 CAC Article 26
more impoundments did not meet the
minimum freeboard requirements. All the
earthen dikes of the surface impound-
ments did not have protective covering;
some showed signs of erosion.
Portions of the Vine Hill surface
impoundments have been modified/closed
without notifying DHS and/or without
following the DHS-approved Closure Plan.
ISO Section II
Condition 10
Powdered waste has not always been
handled to prevent wind dispersal.
TANKS
HWFP Section IV, Condi-
tion 3 and Section II,
Condition 6(i) ISO Sec-
tion X 22 CAC Article 25
40 CFR 264* Subpart J
All tanks do not have adequate secondary
containment. IT has used at least two
tanks at the adjacent oil reprocessing
facility for hazardous waste handling
without notifying DHS. Waste which is
incompatible with tank material has been
placed in unlined tanks. The required
tank certifications were not submitted to
DHS within the required time and were
incomplete and inaccurate. Periodic
thickness testing required for certifi-
cation of specific tanks has not been
conducted. IT has not managed all
reactive and ignitable waste in tanks
DHS issued IT & permit for hazardous waste stored and treated in
tanks and containers so Part 264 regulations apply to tank processes.
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INCINERATOR
ISO Section XI
22 CAC Article 30
40 CFR 265 Subpart 0
18
properly to prevent uncontrolled reaction/
ignition. Ignitable waste has been
improperly stored in tank 61 which is
located within 20 feet of the facility
property line and does not have proper
secondary containment.
IT has either not maintained records of
or conducted the required waste analysis
of material which has been incinerated.
The dynamic nature of the incinerator
feed tank precludes Vine Hill from iden-
tifying the actual characteristics of
waste incinerated at any given time and
subsequent steady state conditions.
CENTRIFUGE
HWFP Section II
Conditions 5 and 6 (i)
The DHS-approved Centrifuge Operations
Plan is not being followed and IT did not
notify DHS of centrifuge activity until
well after operations commenced and its
operation had been observed by a DHS
inspector.
PRIOR RELEASE DOCUMENT
RCRA Section 3004(u)
The prior release document submitted to
EPA as part of the RCRA Part B permitting
process is incomplete because it does not
identify all the required waste handling
units.
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TECHNICAL REPORT
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19
INVESTIGATION METHODS
The NEIC RCRA compliance investigation of IT, Vine Hill consisted of:
Collection and review of facility background information from
State and Federal files
An onsite inspection including records collection and review
In-depth document evaluation.
The records search and review was conducted February 3 through 7, 1986
at EPA Region IX, the California Bay Area Air Quality Management District
in San Francisco, the California Department of Health Services in Emery-
ville and the Regional Water Quality Board in Oakland. Copies of appro-
priate documents were secured by NEIC for additional evaluation and field
use. Facility operations and regulatory history were discussed with
Region IX and State personnel.
The onsite inspection was conducted between March 3 and March 21, 1986.
It included an overview of facility operations, visual inspection and eval-
uation of the waste management facilities and waste handling procedures,
interviews with facility personnel and selected review of facility documents
including waste pre-acceptance documents, shipping manifests, waste receiv-
ing logs, treatment and disposal records, inspection records, personnel
training records and other documents regarding waste handling/tracking at
the facility.*
To expedite the onsite inspection, selected facility documents were
copied and taken to NEIC in Denver, Colorado for in-depth evaluation. Each
group of documents copied at the site were assigned a unique identifying
number and listed in a document log. A copy of the log was given to IT
personnel following completion of the onsite inspection. Photographs
(slides) taken by NEIC during the inspection were developed by NEIC and a
copy of each, accompanied by a photographic log, was sent to IT.
At the request of EPA Region IX, facility compliance with RCRA require-
ments for ground-water monitoring at the site was not investigated.
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20
Because IT claimed that, except for waste tracking documents, facility
records are normally retained for only 3 years (as required by regulations),
the NEIC records review was generally limited to the time period from about
March 1983 to March 1986.
As a result of a private legal complaint against IT in November 1984,
not directly related to IT's regulatory responsibilities, IT removed facil-
ity operating documents for the Vine Hill site to off site IT offices. IT
claimed that, in general, these documents included most facility records
from at least mid-1980 to sometime in 1983. However, except for shipping
manifests and certain waste receiving/tracking records, IT was never able
to specifically identify all documents removed from the site. The NEIC was
given access to all available documents.
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21
FACILITY DESCRIPTION AND OPERATIONS
The Vine Hill facility is located on about 24 acres east of Martinez,
California in Contra Costa County [Figure 1]. Access to the site is from
Waterbird Way from Marina Vista road off Interstate 680. The site, located
on filled tidal flats protected by levees, is basically bordered on the
north and west by Acme Landfill property, to the south by the Martinez Gun
Club, and to the east by marshland and Pacheco Creek. The nearest residen-
tial area is about k mile southwest of the facility.
The average net annual evaporation rate for the area in 1984 and 1985
was about 30 to 40 inches. Prevailing wind direction is to the south and
southwest.
The Vine Hill facility is a hazardous waste treatment, storage and
disposal facility currently using the following waste management units and
processes [Figures 2 and 3],
Drum Storage Area - storage of laboratory waste
Surface Impoundments - storage, treatment, disposal
Tanks - storage, treatment
Incineration - treatment
Centrifugation - sludge treatment
Waste materials received at Vine Hill are normally the by-products of
chemical and manufacturing processes, predominantly from the following
industries.
Petroleum products
Ferrous and non-ferrous metals
Electronics equipment and components
Resins, paints and pigments
Pharmaceutical
Food processing
National defense
Metal finishing
Photo processing
Analytical laboratories
Spill cleanup residue and liquid from the surface impoundments of IT's
Panoche (formally Benecia) landfill are also handled at this facility.
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ON! of Scrvic*
BOO GdlM Cokkolttf trecsfcr In*
Rtccivmf, Sloreft Sloreft
M«f Service
2I5A i 50% M*OHIByft
Ohl of Service
HoMwf ^ Cr61
CerfralCcakr
FIGURE 3 VINE HILL TREATMENT PLANT PLAN
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23
Primary treatment processes used at Vine Hill include:
Cyanide, sulfide and organic material (phenol, cresol, formalde-
hyde, etc.) oxidation
Heavy metals precipitation
Acid-base neturalization (pH adjustment)
Solids/oil/water separation
Chromium reduction
Odor reduction
Steam stripping
Incineration
Sludge dewatering (centrifugation and evaporation)
Liquid waste reduction (evaporation)
An onsite laboratory is used to identify waste receipts and monitor
treatment processes.
Associated with the Vine Hill hazardous waste site is the IT Oil Repro-
cessing facility and the IT Baker hazardous waste treatment, storage and
disposal facility. The oil reprocessing site, consisting mostly of treat-
ment and storage tanks, is located adjacent to the western portion of the
Vine Hill facility. Oily waste from Vine Hill has been routinely sent to
the oil reprocessing area for blending with other oils for eventual resale.
The Baker site, which occupies approximately 135 acres, is about 1,000 feet
(across Pacheco Creek) from the active portion of the Vine Hill facility.
It consists of a series of storage, treatment and disposal surface impound-
ments which receive aqueous waste from Vine Hill as well as directly from
generating facilities. Waste is transported to the Baker surface impound-
ments from Vine Hill through a pipeline.
Approximately 6 months prior to the NEIC inspection, Vine Hill pur-
chased land immediately south of the facility known as the "Acme Property."
The area, formally owned by Acme Landfill, has three surface impoundments
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24
(Acme Ponds). IT personnel indicated that, except for the fact that scrap
material had been stored there, they had no additional information about
the past use of this area. Although they are reportedly not currently using
this property, IT has cleaned up scrap material stored there and graded
some of the land.
WASTE SAMPLING/ANALYSIS/LABORATORY PROCEDURES
The laboratory at the Vine Hill facility performs the waste stream
predisposal and truck receiving analyses as well as monitoring onsite
treatment/disposal processes. Equipment is available for taking samples of
incoming waste loads as well as for conducting the required determinations,
as specified in the Waste Analysis Plan.
Predisposal
Prior to accepting a waste load for storage/treatment/disposal, IT
personnel obtain a representative sample of each candidate waste stream and
submit it to the Vine Hill laboratory for physical and chemical characteri-
zation. All predisposal analytical results are reviewed by the laboratory
supervisor for acceptable quality control results. The predisposal informa-
tion is used to 1) determine whether or not Vine Hill can handle the waste
and 2) compare with truck receiving analytical results to ensure that the
waste actually received is the same as that approved during the predisposal
evaluation. When a waste stream is accepted for handling at Vine Hill, it
is assigned a waste stream number and each load of the waste is identified
by that waste stream number. In this way IT can control the waste it
receives and ensure that waste that cannot be handled (PCBs and waste
reactives) are not accepted.
The March 14, 1983 DEQ-Approved Vine Hill Waste Analysis Plan (WAP)*
indicates that at a minumum pH, normality, density, phase distribution and
A part of the DEQ-Approved Operations Plan
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25
hydrocarbon vapor pressure (HCVP) are determined on all predisposal samples.
These are necessary to obtain a base characterization upon which the truck
receiving analysis results will be matched to verify waste identification.
Additional analyses may be conducted based on identified characteristics
and generator-supplied information. This may include sulfide, cyanide,
phenols and metals. All oils are reportedly screened for PCBs and priority
pollutant metals. Fluoride is also reportedly analyzed for all acidic waste
to preclude unknown acceptance of hydrofluoric acid, an extremely hazardous
waste, as defined by 22 CAC, Article II.
Predisposal analytical results are recorded on the Hazardous Waste
Disposal Evaluation form (HWDE) and put together with other information on
the waste supplied by the generator (customer evaluation form) to form the
"Job Jacket". Job jackets are maintained in the data processing section of
the laboratory near the truck receiving station. Normally, the predisposal
procedure requires two weeks for completion. On occasion, trucks will
arrive with loads without the required predisposal analyses. In these cases,
an analysis is conducted while the truck waits. This normally takes about
4 hours.
Truck Receiving
Upon arrival of a waste load at Vine Hill, verification of waste char-
acteristics and initiation of a waste tracking process begins. The shipping
manifest is turned over to the facility and the driver assists in sampling
the waste (usually opens the tank hatch). The HWPE form from the "Job
Jacket" is attached to the manifest and the forms and samples are given to
the laboratory for analyses. The WAP requires that the laboratory conduct
pH, normality, density, phase distribution and HCVP on these samples. Also,
all samples with an organic phase are required to be distilled to identify
heavier-than-water solvents (usually chlorinated). Additional analysis,
such as metals, and spot tests for cyanide, sulfide and phenols, are con-
ducted as deemed necessary by IT. Truck receiving analysis results are
recorded on the Disposal (or Treatment/Disposal) Location forms.
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26
IT determines hydrocarbon vapor pressure (HCVP) of the waste in lieu
of ignitability testings. HCVP is determined by placing a calibrated "TLV
sniffer"* probe approximately 2 inches over the sample and recording the
meter reading. The HCVP test is used to determine whether the sample will
require distillation to identify heavier-than-water solvent phases (if HCVP
is greater than 400 ppm hexane equivalents) and to calculate flash point
[Vine Hill indicated that they consider 500 ppm hexane equivalents to equal
a 60° C. (140° F.) flash point].
Waste Acceptance
When truck receiving analysis is completed, the Laboratory Supervisor
reviews the results and the Scheduling/Disposal Supervisor determines if
the waste matches the predisposal information and can be accepted and how
the waste will be handled, including initial off-loading location. Report-
edly, if the results of the truck receiving analysis are similar to those
from the predisposal sample and the waste does not contain any materials
which Vine Hill cannot handle (PCBs, etc.), the shipping manifest is
reviewed for completeness and signed off to show the waste was accepted.
The waste off-loading station (pond or tank number) is recorded on the
Disposal Location form and the driver goes to the appropriate location to
unload.
Process Monitoring
According to a February 6, 1986 IT submittal to EPA Region IX
[Appendix D], IT is conducting treatability/compatibility testing on waste
where conditions or "waste stream components indicate the possibility of an
exothermic reaction." The results of this testing are reportedly recorded
on the Disposal Location form.
Manufactured by Bacharach Instrument Company Division
-------
27
IT also conducts analysis of tank constituents following treatment to
determine if the waste constituents of concern have been adequately treated
(see Tank section).
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28
WASTE HANDLING UNITS AND FACILITY OPERATIONS
As indicated earlier, IT treats, stores and disposes of hazardous waste
in containers, surface impoundments, tanks, incinerator and/or centrifuge.
Following is a discussion of the various management areas and their operation.
Container Storage Area
The IT container storage area consists of a small, approximately
64-square-feet, concrete bermed area located behind the onsite laboratory.
It is reportedly only used to store laboratory waste, such as spent solvents,
generated onsite prior to offsite disposal. Drums are stored on pallets
within this 6-inch-high bermed area. The edge of the storage area is within
20 feet of the IT fence line; Acme Landfill property is on the other side
of the fence. There was one partial drum of lab-packed laboratory solvents,
marked only with a "Flammable Liquid" sticker, in the storage area during
the NEIC inspection.
IT does not have any other designated container storage areas for haz-
ardous waste. Reportedly, any containers received are either emptied into
onsite surface impoundments or tanks immediately upon receipt, or retained
on the transporting truck until they can be emptied.
Tank Truck Treatment
IT has periodically treated various, waste materials in the transport-
ing tank trucks. This includes pH adjustment of acid waste by sodium hydrox-
ide addition, precipitation of nickel through sodium sulfide or sodium
hydroxide addition, hexavalent chrome reduction by sodium sufide addition
and formaldeyde oxidation by hydrogen peroxide addition. This is technically
considered to be treatment in containers (22 CAC I §66028 and 40 CFR 260).
IT reported that, after adding a measured amount of reagent to the
truck, the waste and treating reagents were mixed by driving vehicles around
the yard and periodically applying the brakes. By treating waste in the
tank trucks, IT was able to discharge waste, which normally would have had
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29
to have been treated in the onsite tank treatment system, directly to surface
impoundments. IT reported that waste is no longer treated in the transport-
ing vehicles. However, internal IT memo, dated January 28, 1985
[Appendix E], apparently allows tank truck treatment in the following
situations.
To protect tank truck construction material
To eliminate odor
To protect construction materials of onsite receiving tanks
The last recorded tank truck treatment event found during the NEIC
investigation was on August 21, 1985.
Surface Impoundments
IT currently operates seven surface impoundments* for waste storage,
treatment and disposal, as described in Table 3. An eighth unit, 102B, was
used until about October 1984 when it was filled in and covered with gravel.
According to IT, the area was being retained as a "support facility for
above ground treatment and storage" during the NEIC investigation. However,
a September 10, 1984 letter from IT to the California DHS indicated the
impoundment was "being converted from functioning as direct receipt and
storage of materials, to a service of acting as a containment structure for
additional tankage for plant modernization". The area was being used only
for vehicle parking during the NEIC inspection.
IT refers to its surface impoundments as ponds and designates them 101
through 106.
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30
Table 3
SURFACE IMPOUNDMENTS
Surface
Impoundment
Number
100
101
102A
102B3
Surface Area
(Acres)
0.606
10.727
1.104
1.7
Calculated
Depth1
(feet)
9
9
8
6
Capacity2
(Gallons)
1,383,109
24,467,612
2,158,338
3,300,000
General
Use Category
Lead containing
sludge
General oily/
aqueous waste
Recoverable
oily waste
Oily sludges/
1034
104
105
106
0.292 8
1.585 10
0.507 8
0.341 9
TOTAL CAPACITY
(not including 102B)
570,305
4,082,919
990,607
777,314
34,500,000
sludge
dewatering
Acids and bases;
low solids waste
Oil/water mixtures
High solids waste
Aqueous; no oils,
low solids waste
(Baker feed pond)
i
2
3
4
Calculated from given surface area and capacity, includes operating
freeboard
Capacity represents maximum liquid/sludge volume maintaining 2 feet of
freeboard.
This impoundment was filled between October 1984 through May 1985,
Pond 103 is reportedly maintained with 4 feet of freeboard to serve as
containment for tank 24.
The Vine Hill surface impoundments, except for 101 which has a diked
northeast side, are basically excavations into the area fill. The units,
except for 102A which is apart from the others, are separated by internal
dikes of varying widths. The interior walls of the units, and some of the
tops of the separation berms, do not have any protective covering. The
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31
outside of the northeast dike of impoundment 101 did have vegetative cover
during the NEIC inspection.
IT indicated that ponds 102A and 101 were reduced in size in May/June
1985 and sometime in 1981, respectively. This was accomplished by placing
and compacting fill into the impoundments; sludge/liquid was not removed,
only compacted/displaced by the added fill. IT did not report these changes
to any regulatory agency.
IT reported that the area of pond 101, an extension called "Charlie's
Alley," was filled to "provide mobilization support and storage in connec-
tion with site drilling operations." During the NEIC inspection, this area
was used for storage of out-of-service tanks, raw treatment chemicals and
miscellaneous equipment. No further information was available for these
"filling" activities.
Aerial photographs of the site indicate that 35 feet or more of the
north portion of pond 102A was also filled in, between December 5, 1983 and
February 22, 1984. During the NEIC inspection, the area was used, at var-
ious times, for a roadway and truck parking. A southern portion of 102A
was also filled sometime between March 1974 and December 1983.
Waste received at Vine Hill for surface impounding are normally
received in 102A, 103, 105, or 106 (102B was also used for direct waste
receipts). From these impoundments, waste can be pumped to any other unit
at Vine Hill, as well as to the Baker impoundments. The Vine Hill impound-
ments are not dedicated to very specific type waste or treatment process
but are used interchangeably for storage and treatment including waste
dewatering (evaporation), waste phase separation, pH adjustment, and metals
precipitation. However, as will be described later, some of the impoundments
have patterns of "normal" use. The high volume of waste receipts neces-
sitates that liquid from the major receiving units (103, 105, 102A and 106)
be moved to impoundments 101 and 104 as well as to the Baker ponds as soon
as possible. The apparent intent of the Vine Hill ponds, except for 100
and possibly 101 and 104, is primary treatment of the wastewater while the
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32
Baker units are used for final treatment and evaporation. Table 4 identifies
waste constituents received in the various surface impoundments.*
When sludge in the impoundments accumulates to levels which limit liquid
management, it is normally pumped (submersible pumps) to impoundment 105
where it is removed and dewatered by an onsite mobile centrifuge (see Centri-
fuge Discussion). The centrifuge has also been moved to some of the other
impoundments to remove sludge directly.
IT reportedly follows Article 15 (Land Disposal Restrictions) of the
California Hazardous Waste Management Regulations to determine which incom-
ing waste are placed in the surface impoundments and which must be placed
in the tanks.
Starting in December 1984, pH measurements were reportedly taken daily
of pond contents to assist in properly segregating incompatible waste. No
other routine analytical characterization of pond contents is conducted
even for wastewater pumped to Baker.
Freeboard requirements for the Vine Hill surface impoundments are
established at 2 feet or greater by California Regional Water Quality Con-
trol Board Discharge Order 76-68 [Appendix B], California State regulations
(Article 26, Section 67310), the State-issued interim status document
(issued April 6, 1981) and Federal interim status regulations (40 CFR
265.222). Although IT requested a waiver from these requirements in August
1984, it had not been granted at the time of the NEIC inspection.
Because these surface impoundments are basically excavations without
dikes for runon protection, they receive substantial quantities of rainwater
from the surrounding facility.
Following is a brief description of each of the impoundments as observed
during the NEIC inspection.
* From a review of shipping manifests and Disposal Location forms
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Table 4
INCOMING WASTE CONSTITUENTS RECEIVED IN VINE HILL HAZARDOUS WASTE UNITS*
Pond 102A
Aluminum hydroxide
Aluminum phosphate
Animal fat
Caustic
Detergent
Diesel
Gasoline
Lead
Lubricant
Machine coolant, oil base
Metal sludge
Mud
Oil
Paint waste
Silicate
Sludge
Solvent
Solvent (kerosene based)
Soybean oil
Water
Pond 102B
Ammonia
Boiler Wash Sludge
Boron
Cadmium
Calcium chloride
Carbon
Caustic liquid
Chlorine
Chromium
Copper
Corrosive liquid
Cyanide
Diesel
Ferric chloride
Latex polymer paint
Lead
Lime sludge
Mud
Nickel
Oil
Oil/water separator sludge
Phosphorous
Potassium permanganate
Selenium
Pond 102B (cont.)
Silver
Sodium hydroxide
Sulfur
Tin
Vanadium
White glue (PVA resin)
Zinc
Pond 103
Acetic acid
Acetone
Acrylic paint thinner
Alkaline cleaners
Alkaline liquid
Alkaline salts
Aluminum
Aluminum sulfate
Amines
Ammonia
Ammonium bisulfate
Ammonium bromide
Ammonium citrate
Ammonium ferric EDTA
Ammonium fluoride
Ammonium hydroxide
Ammonium thiosulfate
Anthraquinone-2,6-disulfonic acid
Antimony
Arsenic
Barium
Bentonite
Benzene
Biodegradable soap
Bismaleimide
Brine
Butoxyethanol
Butyl carbitol
Cadmium
Calcium carbonate
Calcium fluoride
Calcium hydroxide
Carbitol
Caustic brine rinse
Caustic soda
Chloroform
Chlorine
Pond 103 (cont.)
Chroraate
Chromium
Cobalt
Copper
Copper chloride
Copper hydroxide
Copper oxide
Copper sulfate
Cyanide
Cyclohexanone
Detergents
Diazinon
1,2-Qichloroethane
Diesel
Dyes (unspecified)
Ethanolamine
Ferrous hydroxide
Ferrous sulfate
Fertilizer
Fluorides
Formaldehyde
Formic acid
Freon
Gallium arsenic
Gasoline
Gravel
Hydrochloric acid
Hydrazine
Hydrofluoric acid
Hydrogen peroxide
Hydroquinone
Hydroxyacetic acid
Ink sludge
Inorganic salts
Iron
Iron phosphate
Isodecanes
Isopropyl alcohol
Kerosene
Lacquer thinners
Latex emulsion
Lead
Lead chloride
Lignon sulphonate
Lime
Manganese
* Only includes those wastes directly off-loaded into units. Does not account for waste punped from other areas within the IT facility.
-------
Table 4 (cont.)
Pond 103 (cont.)
Mercaptan
Mercaptoaniline
Mercury
Methanol
Methylene chloride
Methyl ethyl ketone
Molybdenum
Monoethanol amine
Mud
Muriatic acid
N-butyl acetate
Neutral salts
Nickel
Nickel hdyroxide
Nitrate
Nitric acid
Nitrilotriacetic
Nitrosodimethylamine
Oil
Oil sludge
Organic bases
Paint
Paint skins
Paint sludge
Paint thinners
PCBs (<50 ppm)
Permanganate
Petroleum solvents
Phenols
Phosphates
Phosphoric acid
Phosphorous acid
Polymer solids
Potassium
Potassium ammonium
Potassium hydroxide
Pyrophosphate
Rust and scale
Silica
Sodium chromate
Sodium chloride
Sodium ferrocyanide
Sodium hydroxide
Sodium hypochlorite
Sodium nitrate
Sodium nitrite
Sodium sulfate
Solvents
Sugar
Sulfides
Pond 103 (cont.)
Sulfite
Sulfur
Sulfuric acid
Surfactants
Tallow
Tetrachloroethylene
Thimersal
Titanium
Toluene
Trichloroethane
Triethanolamine
Turbine fuel
Unspecified alcohol
Vanadium
Vanadium pentoxide
Water
Xylene
Zinc
Zinc chloride
Zinc sulfide sludge
Pond 105
Acetic acid
Acrylic latex paint
Acrylic resine
Activated carbon pellets
Alkaline cleaning compound
Alkaline sludge
Alkaline water
Almond oil
Alodine sludge
Aluminum
Aluminum hydroxide
Aluminum oxide
Aluminum phosphate
Ammonia
Ammonium iodine
Animal fat
Antifreeze
Arsenic
Barium
Bentonite
Bisnaleimide
Bleach
Bordens glue
Butyl alcohol
Butyl carbitol
Cadmium
Calcium
Calcium carbonate
Pond 105 (cont.)
Calcium chloride
Calcium fluoride
Calcium hydroxide
Carbon
Casein
Caustic soda
Chlorides
Chromium
Clay
Cobalt
Copper
Copper chloride
Copper hydroxide
Copper oxide
Copper sulfate
Cresol
Detergent
Diesel
Diesel soaked sawdust
Enamel paint
Ferric chloride
Ferrous sulfate
Fluoride
Fluoride salt
Formaldehyde
Gasoline
Glue
Grease
Hydrated alumina sludge
Hydraulic fluid
Hydrochloric acid
Iron
Iron hydroxide
Kerosene
Latex paint
Lead
Lead chloride
Lead hydroxide
Lead oxide
Lime sludge
Machine coolant, oil base
Mercaptans
Mercury
Metal sludge
Mineral oils/spirits
Molasses
Molybdenum
Monoethanol amine
Mud
Neutralized acids in lime sludge
-------
Table 4 (cont.)
Pond 105 (cont.)
Nickel
Nickel hydroxide
Nitrates
Nitric acid
Oil
Organic compounds
Organic pigments
Oxalic acid
Paint sludge
Paint thinners
Paper pulp
Phenols
Phosphoric acid
Polyvinyl alcohol
Pulp slurry
Rosin resin
Si lane (silicon tetrahydride)
Silicon
Silver
Soda Ash
Sodium androxide
Sodium bisulfate
Sodium hydroxide
Sodium phosphates
Sodium sulphate
Solvents
Starches
Styrofoam
Sugar
Sulfates
Sulfides
Sulfur
Sulfuric acid
Tin
Tin sulfate
Titanium dioxide
Trimsol
Unspecified volatile residue
Vanadium
Vanadium pentoxide
Villin black liquor
Water
Waterbase ink
Waterbase paint
Wax emulsions
White glue (PVA resins)
Zinc
Zinc chloride
Zinc phosphate
Zinc sulfide
Pond 106
Alkaline cleaner
Ammonia
Ammonium fluoride
Cumene hydroperoxide
Grease
Hydrofluoric acid
Mercury
Oil
Organic peroxide
Polyglycol
Sludge (unspecified)
Sulfolane (tetramethylene sulfone)
Sulfur
Water
Tank 1
Acetic acid
Alodine
Amines
Ammonia
Ammonia hydroxide
Ammonium fluoride
Ammonium persulfate
Arsenic
Boric acid
Cadmium
Casutic
Chromic acid
Chromium
Copper
Copper sulfate
Ferric chloride
Fluoroboric acid
Fluoride
Hexavalent chrome
Hydrochloric acid
Hydrofluoric acid
Iron
Iron phosphate
Iron sulfate
Lead
Lead fluoborate
Metals
Molybdenum
Nickel
Nitric acid
Nonchlorinated solvent
Paint sludge
Paint waste in water
Palladium
Tank 1 (cont.)
Phosphoric acid
Photo chemicals
Polyphosphoric acid
Potassium persulfates
Sodium ash
Sodium carbonate
Sodium chloride
Sodium dichromate
Sodium hydroxide
Sodium nitrate
Stannous chloride
Sulfamic acid
Sulfonic acid
Sulfuric Acid
Thiourea
Tin
Tin fluoroborate
Toluene
Zinc sulfate
Tank 2
Accelator
Acetic Acid
Alkaline water
Aluminum
Ammonia
Ammonium fluoride
Ammonium persulfate
Arsenic
Bleach
Cadmium
Chromates
Chromic acid
Chromium
Chromium trioxide
Cobalt
Copper
Copper sulfate
Electro-polish solution
Ferric chloride
Fluoroboric acid
Gallium arsenic
Hydrochloric acid
Hydrofluoric acid
Iron
Lead
Nickel
Nitric Acid
Potassium dichromate
Selenium
-------
Table 4 (cont.)
Tank 2 (cont.)
Sodium dichromate
Sodium hydroxide
Sulfite-3 (a Betz product)
Sulfuric acid
Zinc
Tank 11
Acetic acid
Acetone
Alpha olefin
Agricultural fertilizer
Alcohol
Ammonia
Ammonium fluoride
Brine
Cadmiurn
Casein
Caustic soda
Chromium
Oicyclopentadiene
Diemethyl siloxane
Diesel
Enamel paint
Epoxy acrylate sulfate
Ethylene glycol monoethyl ether
Fuel oil
Gasoline
Hydrofluoric acid
Iron
Isopropanol
Jet fuel
Lead
Methanol
Methyl ethyl ketone
Naptha
N-butyl acetate
Nitrosohexamethyleneimine
Oil
Paint thinner
PCB (<50 ppm)
Phenols
Rust and scale
Silver
Soap
Sodium hydroxide
Sodium nitrate
Sodium sulfate
Solvents
Sulfuric acid and lime
Tetraethyl lead
Tank 11 (cont.)
1,1,1-trichloroethane
Unspecified coolant
Wastewater (unspecified)
Xylene
Zinc
Tank 12
Acetone
Alcohols (unspecified)
Alkaline detergent
Ammonia
Aniline
Benzene
Butanol
Caustic soda
Chromi urn
Combustible liquid
Copper
Diesel
Dipropylaniline
Formaldehyde
Gasoline
Glycol
Hydrochloric acid
Inks
Isopropanol
JP-4 fuel
Kerosene
N-butyl acetone
Nitric -acid
Oil
Oil sludge
Paint sludge
Paint thinner
Phenol
Phosphoric acid
Rust and scale
Silver
Sludge (unspecified)
Sodium acetate
Sodium fluoride
Sodium hydroxide
Sodium nitrate
Solvents (unspecified)
Sulphuric acid
Tetraethyl lead
Unspecified coolant
Wastewater (unspecified)
Xylene
Xylol
Zinc
Tank 13
Acid sludge with metals
Acids v
Aluminum
Ammonium persulfate
Cadmium
Calcium carbonate
Carbon
Caustic (unspecified)
Chromate
Chromic acid
Chromium
Cobalt
Copper sulfate
Fluoroboric acid
Formaldehyde
Gasoline
Grease
Hydrochloric acid
Hydrofluoric acid
Iron
Lactic acid
Latex emulsion
Lead
Lime
Methylene chloride
Mud
Nickel
Nickel chloride
Nickel sulfate
Nitric acid
Oil
Phenols
Phosphoric acid
Rust and scale
Sodium dichromate
Sodium hydroxide
Sodium hypophosphite
Sulfides
Sulfur
Sulfuric acid
Tin
Vanadium
Tank 14
Acetic acid
Acetone
Acid sludge
Ammonium fluoride
Ammonium nitrate/phosphate
Ammonium persulfate
-------
Table 4 (cont.)
Tank 14 (cont.)
Arsenic
Cadni urn
Chronic acid
Chromiurn
Cobalt sulfate
Cresol
Detergent
Ethyl acetate
Ethylene glycol
Epoxy
Fluoroboric acid
Formaldehyde
Gasoline
Hydrochloric acid
Hydrofluoric acid
Iron
Isopropanol
Lactic acid
Lead
Machine sump wastewater
Manganese
Methyl ethyl ketone
Methylpyrrolidinone
Mud
Muriatic acid
Nickel
Nickel plating solution
Nickel sulfate
Nitric acid
Oil
Phenols
Phosphates
Phosphoric acid
Printing waste
Selenium
Sodium carbonate
Sodium citrate
Sodium chloride
Sodium hydroxide
Sodium hypophosphate
Sodium phosphate
Sodium sulfate
Sulfides
Sulfuric acid
Water
Water-soluble paint
Wax
Xylene
Tank 15
Ammonia
Ammonium thiosulfate
Chromium
Copper
Cyanide
Diesel
Iron
Lead
Mercury
Nickel
Phenols
Potassium cyanide
Silver
Sodium copper cyanide
Sodium cyanide
Sodium ferrocyanide
Sodium hydroxide
Sodium nickel cyanide
Sodium sulfate
Sulfite
Zinc
Tank 16
Amines
Ammonia
Ammonia hydroxide
Arsenic
Carbon
Chromium
Copper
Detergent
Formaldehyde
Gasoline
Grease
Halogenated inorganic salts of zinc and tin
Lead
Nickel
Nickel sulfate
Nitric acid
Oil
Rust and scale
Plating waste
Sodium hydroxide
Sodium hypophosphate
Solvents
Sulfides
Sulfur
Sulfuric acid
Tank cleaning sludges (sulfides)
Tetraethyl lead
Tank 16 (cont.)
Vanadium
Water
Water-soluble paint
Zinc
Tank 17
Copper
Cyanide
Silver
Water
Tank 18
Acetone
Alcohol
Algecide and fungicide
Aluminum
Ammonia
Cobalt
Copper
Detergent
Gasoline sludge
Heavy metals
Kerosene
Latex
Lead
Leaded gasoline
Methyl ethyl ketone
Nickel
Oil
Organic Compounds
Paint
Paint thinners
Resin
Solvents
Sulfides
Xylene
Tank 19
Acetone
Alcohols (unspecified)
Ammonia
Anilene
Arsenic
Brine
Butyl carbitol
Butyl cello acetate
Butyl cellosolve
Cellosolve acetate
Chromium
Detergent
-------
Table 4 (cont.)
Tank 19 (cont.)
Diesel
Epoxy resin
Ethanol
Gasoline
Hydrochloric acid
Isopropyl alcohol
Hercaptoaniline
Methanol
Methyl butyl ketone (2-hexanone)
Methyl ethyl ketone
N-butyl acetate
N-butyl alcohol
Nickel
Oil
Organic solvents
Oxygenated solvents
Phenols
Photo-resistant resins
Pyridine
Rust scale
Sodium hydroxide
Solvents
Sulfides
Tetraethyl lead
Toluene
Trimethane
Water
Xylene
Tank 20
Acetone
Alcohol (unspecified)
Cresol
Diesel
Formaldehyde
Gasoline
Jet fuel
Kerosene
N-Butyl acetate
Oil
Paint residue
Paint thinner
Phenol
Rust and scale
Sodium hydroxide
Solvent
Sulfides
Toluene
Xylene
Tank 21
Acetone
Ammonia
Brine
Carbon
Cyanide
Diesel
Ethyl acetate
Ethylene dibromide
Ethylene dichloride
Ferrous sulfate
Flexographic printing waste
Gasoline
Glycol
Hydrocarbon resin
Isopropyl alcohol
Jet fuel
Laquer thinner
Latex paint
Lead
Machine sump wastewater
Methyl ethyl ketone
Mineral Spirits
Naphthas
Ni trosohexamethy1eneami ne
Oil
Oil/water vacuum pump waste
Paint solids
Paint solvents
Paint thinner
Petroleum distillant
Phenols
Sodium hydroxide
Solvents
Sulfide
Tars
Tetraethyl lead
Tetrahydrofuran
Toluene
Unleaded fuel
Water
Water-base adhesives
Water-base inks
Tank 22
Gasoline
Hydraulic fluid
Oil
Water
Tank 24
Acrolein
Activated carbon
Arsenic
Arsenic sulfide
Arsenic trisulfide
Ammonia
Caustic
Ethyl glycol
Filter aid
Hydrochloric acid
Methanol
Nitric acid
Oil
Phosphoric acid
p-picoline
Silicate
Sulfuric acid
Water
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39
Impoundment 100
Surface impoundment 100 is used solely for the storage of tetraethyl-
lead sludge received at Vine Hill between about 1957 and 1970 and collec-
tion of stormwater runoff. At least 1 foot of protective liquid cover is
reportedly maintained over the sludge by an automatic float valve. When
the water level drops to about 12 inches, the float drops and opens a valve
which adds city water to maintain the minimum of 1 foot of water over the
sludge. IT anticipates removing this sludge from storage and properly dis-
posing of it in the near future.
At the time of the inspection, there was no accurate freeboard measure-
ment device on this pond. According to IT, a rod type marker was previously
used but the 2-foot level mark is no longer visible. IT had no plans to
replace this marker. Currently, freeboard is reportedly estimated by visual
observation of the position of the automatic float; however, because of the
action of the float, an accurate measurement of 2 feet of freeboard is not
possible.
Impoundment 101
Surface impoundment 101 is the major dewatering (evaporation) impound-
ment at Vine Hill. It receives waste input from the other impoundments, as
well as from tank processing. An arm of Pond 101, extending south and
adjacent to impoundment 100, known as "Charlie's Alley" was filled in 1981.
This area is currently used to store old tanks, other equipment and drums
of raw materials.
There was no freeboard measurement device at impoundment 101 from some-
time in February to March 19, 1986.
Impoundment 102A
Impoundment 102A basically receives direct loads of oily waste for
phase separation. IT also disposes of some laboratory samples, including
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40
some dry, powdery substance, as observed on March 21, 1986, in this
impoundment. Surface oil is periodically skimmed from the impoundment and
sent to the adjacent oil reprocessing facility for blending with other oils
for resale. Liquid is also removed from below the surface and pumped to
other Vine Hill impoundments for evaporation. Impoundment 102A was formed
sometime between March 1974 and December 1983 by dividing a larger impound-
ment (102) into two smaller ones (102A and 102B) by construction of an
internal dike.
Impoundment 102A was reduced in size on at least three occasions since
it was formed. IT reported that in May/June 1985 portions had been filled
in with compacted material. Aerial photographs indicate that at least 30
feet of the southeastern portion of the impoundment was filled in sometime
between 1974 and 1983. This apparently allowed construction of, and access
to, the hydrogen peroxide storage area. A northern portion of at least 35
feet of impoundment 102A was filled in sometime between December 5, 1983
and February 22, 1984. This filled in area was being used interchangeably
for truck receiving (parking) and as an access roadway during the NEIC
inspection.
Impoundment 103
Impoundment 103 is used for direct receiving of low-solids containing
aqueous waste (less than about 10%) and waste from tank treatment. It also
receives "excess water" (caused by rainwater runon) pumped from adjacent
impoundment 100. In fact, operation of 103 was temporarily stopped during
the NEIC investigation, by State order, as a result of this activity. The
State required IT to analyze sludge and liquid from the impoundment for
tetraethyl lead. A letter dated March 20, 1986, from IT to the State DHS,
indicated that, although the sludge in impoundment 103 did contain organic
lead, the aqueous phases from impoundment 103, as well as 100, had less
than 10 ppm organic lead. Operation of impoundment 103 was subsequently
continued at the consent of DHS.
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41
IT also reports that 103 is the secondary containment for tanks 23 and
24 and indicates that a minimum of 4 feet of freeboard is maintained on
this impoundment for that purpose (see Tank discussion). A freeboard marker
was present at the unit during the NEIC inspection.
Impoundment 104
Impoundment 104 is a major evaporation (dewatering) impoundment at
Vine Hill. The unit is not normally used for direct offloading of trucks
but has received liquid from the tank treatment processes and adjacent
pond 100. Liquid from any other impoundment can be pumped to 104 as capac-
ity dictates. As was the case with impoundment 101, there was no freeboard
marker at this unit between sometime in February to March 19, 1986.
Impoundment 105
Impoundment 105 normally receives direct receipts of waste with high
solids content (greater than about 10%) and sludge from other surface
impoundments. A mobile centrifuge set up to the west of this impoundment
is used to remove and further dewater the sludge for offsite disposal.
Impoundment 106
Surface impoundment 106 receives aqueous waste directly from trucks
and tank treatment. It is normally used to contain liquid just prior to
pumping to the Baker facility. The centrifuge has been used to remove sludge
from this impoundment and centrate from the centrifuge operation is often
discharged to this unit.
Tanks
During the NEIC inspection, IT reported that they had 18 active tanks
used for storage and/or treatment of hazardous waste [Table 5]. Eight addi-
tional tanks are currently out of service (inactive), many apparently due
to the lack of secondary containment. Some of these inactive tanks were
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Table 5
HAZARDOUS WASTE STORAGE AND TREATMENT TANKS
Tank
Number
1
2
5
11
12
- 13*
14a
15a
16"
17
18
19
20
21
22
23C
24
25
26
27
61C
201
251
252
254
255
Approximate
Capacity
(Gallon)
15,282
18,220
10,549
23,018
22,512
22,512
22,512
17,699
17,879
17,879
17,757
17,849
17,879
17,939
17,939
254,672
340,000
8,598
7,200
6,700
493,400
11,780
11,508
10,878
3,192
756
General Use
Waste acid
Waste acid
Out of service
Waste caustic
Waste caustic
Waste caustic
Waste caustic
Cyanide treatment
Waste caustic
Cyanide receiving
Waste caustic
Waste solvent
Waste solvent
Waste fuel
Waste fuel
Stripper feed tank
Batch treatment
Waste fuel
Out of service
Out of service
Storage
Out of service
Out of service
Out of service
Out of service
Out of service
Dimensions
(Dia. and Ht.)
10'0"x26'
10'0"x30'
91l"x22l10"
18'l"xl2'
18'0"xll'10"
18'0"xll'10"
18'xl2'
IS'lO'^U'l"
15'10"xl2'2"
15'10"xl2'2"
15'10"xl2'l"
15'10"xl2'2"
15'10"xl2'2"
15'10"xl2'2"
15'10"xl2'2"
46'6"x20'
42'6"x40'
10'0"xl2|Cl
9'4"x23'7"
9'4"x23'7"
49'x35'
13.0'6"xl2"
9'0"x28'10"
9.0'x22'
e^'xie'S"
4'2"x9'9"
Shell
Construction
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Lining
Hypalon
Hypalon
None
None
None
None .
Amercoat 75
None
Amercoat 75
None
None
None
None
.Placite
None
None
None
None
None
None
None
None
None
None
None
None
Vapor
Recovery
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Unknown6
No
Yes
Yes
Yes
Yes
a Tanks 13, 14 and 16 are also used to receive, store and/or treat waste Joads containing suJfides,
phenols, formaldehyde, cresote, mereaptins, etc. and metal precipitation by means of oxidation
using 50% hydrogen peroxide. These tanks are also used for neutralizing waste acid loads using
calcium hydroxide or other caustic (virgin and/or waste) material.
b Corrosion-barrier
c JVote information on tanks 23 and 61 were not included in IT's April IS, 1985 RCRA Part B
application submittal.
d The April 27, 1984 tank certification indicates that tank 25 is 25 feet in diameter and 10 feet
high.
e Although IT indicated that this tank was connected to the facility fume incineration system, the
tank certification indicated it is an atmospheric tank (see text).
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43
used for a solvent recovery operation (distillation), a solids/oil/water
separation process and an old cyanide treatment operation. There are also
about 11 tanks used to store process reagents and fuels [Table 6]. Except
for a few exceptions, the hazardous waste handling tanks are not dedicated
to a specific purpose, and thus, may be used for waste receiving, storage
and/or treatment as capacity and need dictate.
Table 6
FUEL/REAGENT STORAGE TANKS*
Tank
Number Use
25A Diesel fuel (supplemental incinerator fuel)
D-l Diesel fuel - for plant equipment
212 Water storage tank - softened water
213 Pre-heater tank - softened water
214 Brine tank - for water softeners
223 Post scrubber bath - for Phase I incinerator
203 Alum tank - for oil separator - 5,368 gallons (out of
service)
204 Mixing tanks for Na2S, NA2S205, FeS04 - 500 gallons
241 Hydrogen peroxide (H202) - storage tank - 7,000 gallons
242 H202 feed tank - 600 gallons
215A Caustic holding tank (virgin NaOH) - 10,000 gallons
* From April 5, 1985 RCRA Part B completeness check
General tank treatment processes at IT include:
Cyanide, sulfide and organic material (phenol, cresol, formalde-
hyde, etc.) oxidation
Heavy metals precipitation
Acid-base neutralization
Chromium reduction
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44
Sol ids/oil/water separation
Odor reduction
Steam stripping
All of the currently active tanks (except for the possible exception
of tank 61 see later discussion) reportedly vent through an exhaust fan to
the main (Phase II) facility incinerator. Negative pressure is maintained
on the tank head space by the fan to assist venting to the incinerator.
The incinerator supplies process heat (steam) back to the treatment facility
for steam stripping.
Tank treatment is normally conducted on a batch basis with known amounts
of reagent mixed with the waste. IT reported that, following calculated
times for reaction completion, a waste sample is sent to the laboratory to
verify that the waste has been treated below pondable limits.* Although
spot field tests can also be conducted to determine extent of reaction, IT
indicated that laboratory analysis are always conducted prior to tank dis-
charge. Following treatment and analysis, waste is discharged to either
the onsite surface impoundments or the Baker impoundments. Because many of
the tanks have floating suction pumps which cannot pick up the bottom 2 feet
of material in a tank, some waste from the previous treatment will remain
in the tank after most of the treated waste has been pumped to the
impoundments.
An operations building, located next to the tank processing area, con-
tains monitoring equipment and is used as a support and control facility
for the treatment plant.
Prior to offloading a truck of waste to a tank, the truck driver con-
tacts IT personnel at the operations building. An operator accompanies the
truck to the appropriate offloading station and the waste is offloaded. A
"Pondable limits" are reportedly concentrations of specific parameters
as identified in 22 CAC Article 15, Land Disposal Restrictions.
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45
copy of the Disposal Location form,* filled out by IT to identify and
track the waste, is placed on the tank status board in the operations build-
ing to identify the tank into which the waste load is received. The tank
status board has a set of hooks for each tank where the Disposal Location
forms are hung. When a tank is unloaded, the Disposal Location forms are
removed from the original location on the tank status board and either
replaced on the board to correlate to the tank into which the waste was
pumped or taken off the board if the waste was discharged to a surface
impoundment.
Waste treatment in the tanks normally occurs by recirculating waste
material in the tank and injecting prescribed amounts of reagent or neu-
tralizing waste into the recirculation lines. Some waste must be pumped
through several tanks and receive multiple treatments prior to discharge.
IT maintains "Tank Processing Records" which track some waste movements
between tanks as well as tank discharges to the surface impoundments.
IT normally uses waste caustic and waste acid for pH adjustment; how-
ever, when waste material is not available, purchased sodium hydroxide or
hydrochloric acid is used. Dry reagents, such as metal bisulfide for chrome
reduction, are liquified in mixing tank 240 prior to addition to the waste.
Hydrogen peroxide, used for oxidation reactions is stored in tank 241 and
put into metering tank 242 for measurement prior to contact with the waste.
Following is a brief description of each tank, and the associated
operations.
Tanks I and 2
Tanks 1 and 2 are horizontal, hypalon-'lined tanks used to receive and
store acid and chrome waste. Tank 1 is also used to reduce hexavalent
chrome to the trivalent state. There are no automatic feed cutoff controls
Completed by the laboratory, schedules supervision when the truck
is accepted at the facility
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46
or high-level alarms on these units to prevent overfilling. Available tank
capacity is reportedly determined by maintaining a running total of receipts/
removals on the tank status board in the operations building and daily manual
level determinations of the tanks using a calibrated stick. Tanks I and 2
share the same containment area.
Hexavalent chrome reduction in tank 1 is accomplished by recirculating
a metal bisulfide solution through the tank until the chrome is reduced to
the trivalent state. A sample is taken to the laboratory and, if analysis
indicates satisfactory reduction (below the maximum level allowed in sur-
face impoundments), the waste is discharged to surface impoundments.
Tank 5
Tank 5, used for waste acid storage and receiving, was out of service
during the NEIC inspection, reportedly due to lack of secondary tank
containment.
Tanks 11 and 12
Tanks 11 and 12 are receiving tanks for waste having high levels of
volatile organic carbon; this is usually alkaline material. Waste is stored
in these tanks until pumped to treatment, normally to tank 23 or 24 for
eventual steam stripping. No formal treatment reportedly occurs in these
units. Neither tank has automatic feed cutoff control and available capacity
is determined by daily stick gauging and maintenance of a running tally of
receipts/removals. These tanks share a concrete containment area with
tanks 13 and 14.
Tanks 13. 14, 16 and 18
Tanks 13, 14, 16 and 18 receive, store and treat a variety of waste
usually containing sulfides, phenols, formaldehydes, creosotes, mercaptans
or other organics to be oxidized. These tanks can also be used to neutral-
ize acidic waste and precipitate metals. Tanks 13 and 18 are unlined steel
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47
tanks while tanks 14 and 16 are steel covered with a corrosion-resistant
(R)
coating (Ameri-coat 75 ).
Tanks 14 and 16 have continuous waste level indicators which read out
®
in the nearby operations building. Tanks 13 and 18 have Shannon-Jewers
floating line level detectors which read out at the tank. Although IT
indicated that none of these tanks have high waste level alarms, automatic
waste feed shutoff valves or pressure and temperature sensors, a process
schematic submitted with IT's April 5, 1985 RCRA, Part B Completeness Check,
shows both high-level alarms and temperature indicators on tanks 14 and 16.
Tanks 13 and 14 share secondary containment with tanks 11 and 12, while
tanks 16 and 18 share concrete secondary containment with tanks 15, 17, 19,
20, 21 and 22.
Organic materials are oxidized and metals precipitated in all four
tanks by injecting premeasured amounts of reagents (hydrogen peroxide, sodium
sulfide), determined by waste strength, into the recirculation lines of the
tanks. Pumps keep the waste circulating through the lines and back into
the tanks to facilitate mixing. Additionally, tank 14 has a mechanical
agitator for mixing. Acid neutralization is conducted by one of two methods:
(1) offloading acid waste into the tanks, which are reportedly prepared
with highly alkaline material for protection of the tank or (2) injecting
acid waste from tanks 1 or 2 into the recirculation lines followed by sub-
sequent mixing in the tanks.
Tank 15
Tank 15 is dedicated to receive, store and treat cyanide-containing
waste. The tank is equipped with a total waste level indicator, with remote
readout in the operations building, a high level alarm (audible) and a high-
level alarm which automatically closes the waste-receiving valves. Valves
Ameri-coat-75 and Shannon-Jewers are registered trademarks and will
appear hereafter without
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48
on tank 15 are locked at all times when the tank is inactive. Tank 15
shares a common secondary containment area with tanks 16, 17, 18, 19, 20,
21 and 22.
Cyanide is oxidized in tank 15 with the addition of premeasured amounts
of hydrogen peroxide injected into the tank recirculation lines. A catalyst,
ferrous chloride, is added to waste that is difficult to treat.
Tank 17
Tank 17 is dedicated to receiving and storing of cyanide-containing
waste. It is equipped with an automatic high/high level alarm (audible)
activated when the waste level nears tank capacity. Waste is pumped from
tank 17 to tank 15 for treatment. Tank 17 shares a secondary containment
area with tanks 15, 16, 18, 19, 20, 21 and 22. During the NEIC inspection,
tank 17 contained waste received at IT in April 1985. This material was
reportedly being fed, in small quantities, to tank 15 for treatment.
Tanks 19, 20, 21 and 22
Tanks 19, 20, 21 and 22 are all receiving and storage tanks for waste
with high concentrations of volatile organic material to be incinerated or
steam stripped. Some phase separation of organics/water/solids occurs in
these tanks during storage. Waste received and stored in 19, 20 and 21 is
normally pumped to tank 22. Material from the top of tank 22 goes to
tank 25 for eventual incineration while.bottom material from tank 22 is
usually pumped to tank 23 for storage until it can be steam stripped in
tank 24.
These tanks all share a common concrete secondary containment area
with tanks 15, 16, 17 and 18. None of these units have automatic waste
feed shutoff valves although tanks 21 and 22 have high level alarms (aud-
ible) for overflow protection. All of the tanks have Shannon-Jewers float-
line level indicators reading out at the tanks.
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49
Tank 23
Tank 23 is the receiving and storage tank for waste to be steam stripped.
This tank normally receives waste from tanks 19, 20 or 21 but can receive
material directly from trucks by pumping. Waste from tank 23 is pumped to
tank 24 for steam stripping.
Tank 23 is equipped with a Shannon-Jewers floating-line level indicator.
There is no secondary containment area surrounding tank 23 and the area
immediately surrounding this tank consists of porous gravel and soil. Leaked
material could flow to several areas including north over the process area
access roadway to the area of the old impoundment 102B, west into the con-
crete containment area for tanks 15 through 22, and/or east across the facil-
ity's main roadway. A spill could prevent access to adjacent tank 24.
Information on tank 23 was not included in Table III.2 of IT's April 5,
1985 RCRA Part B Completeness Check submitted to EPA Region IX.
Tank 24
Tank 24 is the steam stripping tank. It receives waste from the bottom
of tank 23 and uses steam (from the onsite incinerator) mixed with nitrogen
(from an onsite storage tank truck) to strip organics from waste. The pH
of the waste can also be adjusted in tank 24 by caustic or acid addition.
Following treatment, the waste is usually discharged to the Baker impound-
ments. Fumes generated from the stripping process are withdrawn by a nega-
tive pressure fan to the incinerator for treatment. A vent gas oxygen
analyzer on the fume gas collector of tank 24 automatically adjusts nitro-
gen input (to the steam) to limit oxygen concentration in the vent gas to
less than about 8% to prevent waste ignition. Waste level in tank 24 is
monitored continually and automatically with readout in the operations
building.
Tank 24 has a high-level alarm (audible) which is activated when waste
level approaches tank capacity. If waste level continues to rise, a high/
high-level detector automatically shuts off the waste feed valve. The tank
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50
is also equipped with a flame arrester, emergency vents and automatic steam/
nitrogen shutoff.
Tank 24, like adjacent tank 23, does not have a surrounding secondary
containment area. The area immediately surrounding tank 24 consists of
porous gravel and soil. Leaked material would flow over this area spread-
ing in several directions including west over the main facility roadway,
eventually to surface impoundment 103 (over 100 feet from tank 24) and pos-
sibly to surface impoundment 100; north over the process area access road-
way to the old impoundment 102B area; and east past tank 23 and into the
concrete secondary containment for tanks 17 through 22. A leak could prevent
access to tank 23 and to the adjacent nitrogen gas storage tank truck.
Tank 25
Tank 25 is the waste storage and feed tank to the Phase II incinerator.
This tank normally receives waste from the top of tank 22. Waste from
tank 22 is reportedly sampled and analyzed for waste constituents prior to
pumping to tank 25. Tank 25 shares a concrete containment area with tank
25A, the incinerator supplemental fuel (diesel) storage tank and a fuel
feed pump. Because the waste feed rate to the incinerator is not continu-
ously monitored, periodic waste level determinations in tank 25 are the
only source of incinerator feed rate information.
Tanks 26 and 27
These tanks are no longer in service at IT and have been removed.
They were located just west of tank 24 and used to store waste for
incineration.
Tanks 30 and 31
Tanks 30 and 31 were associated with a past cyanide treatment (chlorine
addition) process. Neither are currently used for waste handling. Tank 31
was the treatment tank and is currently inactive and empty. Tank 30 was to
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51
be used for cyanide waste storage but was never put into service; it is
now used to store water as an emergency water supply source.
Tank 61
Tank 61 is a large vertical tank located in the northwest portion of
the site about 15 feet from the western boundary of the IT facility, away
from the other waste processing units [Figure 2]. It is used for receipt
and storage of various waste including those with high concentrations of
volatile organics to be steam stripped or incinerated. Waste is pumped
between the Vine Hill process area and this tank, as tank capacity dictates.
The secondary containment area for this tank consists of a soil/gravel berm
of varying heights surrounding the tank. A calculation of secondary contain-
ment volume, based on estimated measurements of the bermed area, indicates
maximum containment of less than 3% of total tank capacity.
Tank 61 is not represented on the tank status board in the operations
building and, thus, information on the type and amount of waste in the
unit is not readily available and apparently not accurately tracked. Also,
freeboard for this unit was not noted on the status board or on the daily
tank inspection forms.
Although IT reported that tank 61 was connected with the tank fume
recovery system at the process plant (and thus subject to negative pressure),
the tank certification of August 25, 1983 [Appendix E] indicates the tank
is under atmospheric pressure.
Tanks 251. 252, 254 and 255
These tanks were used for a solvent recovery operation which is out of
operation; there is no secondary containment for these units. All tanks
were empty during the NEIC inspection except for tank 255. There was approx-
imately 3 inches of liquid, with a solvent odor, in the bottom of this tank
on March 13, 1986. Analysis indicated the liquid was a mixture of water
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52
and nonchlorinated solvent with an HCVP of 400 ppm. IT indicated this was
probably residual left from the cleaning of these tanks when they were taken
out of service.
Incineration
IT has two incinerators, a small 'Phase I1 unit and a larger
'Phase II' unit. While the Phase I unit can only oxidize limited fumes
(waste gas), the larger Phase II incinerator treats both fumes and liquid
waste. Currently the Phase I unit is reportedly used only when the larger
unit is not operating. However, only the Phase II unit has the capacity to
handle all of the fumes from the tanks and steam stripping in tank 24; the
small unit is undersized for such operation.
Phase I Incinerator
This horizontal, diesel-fueled unit has no temperature controls and
little information was available regarding its construction. It is piped
in parallel with the larger incinerator and fumes are blown into the unit
near the fuel injection nozzle. A packed stack-gas scrubber recirculates
alkaline water to treat incinerator gas. No records are kept of incinera-
tor activity although IT reported that it can normally be assumed that,
when the big unit is not operating, the smaller one will be manually started
and operated for fume incineration. However, IT did indicate that there
are times when neither unit is operating. In these cases, the vent gas
removal system is shut off and tank gas is no longer removed.
IT claims that because the small incinerator is only used for fume
oxidation it is exempt from the requirements associated with RCRA.
Phase II Incinerator
The Phase II incinerator is the major onsite incinerator. It was built
in the early to mid-1970s and is used for fume and liquid waste incineration.
A tube-type boiler attached to the incinerator captures heat to produce
steam for the steam stripping operation. Liquid waste is fed to the unit
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53
from tank 25 and fumes are blown into the incinerator through a manifold
near the waste feed injection nozzle at the front end of the unit with a
1,000 standard cubic-foot-per-minute blower.
Based on incinerator unit blue prints, this incinerator is a horizontal,
single chambered, brick-lined unit with an inner diameter of about 6 feet
10 inches and length of approximately 14 feet. Liquid waste is injected
through a multi-orificed air-atomized burner nozzle at the front end of the
unit. The boiler is attached to the end of the incineration chamber and is
about 14 feet long. Stack gases vent through a 40-foot-high plenum. There
are no stack-gas emission controls on this unit. IT reports in their RCRA
Part A application that the estimated operating capacity of the unit is 250
gallons per hour.* Normal operating temperature is reportedly between 1500
and 1700° F. Electronic readout of incinerator temperature on March 6,
1986 was 1719° F. Startup procedures are reportedly as follows. Diesel
fuel is used to raise temperature to about 1500° F. After about 5 minutes
at steady-state temperature, the waste feed supply is turned on. The incin-
erator is reportedly automatically prevented from burning waste fuel or
tank fumes at temperatures less than about 1200° F. Temperature is report-
edly maintained by a series of automatic controls. High temperatures cause
reduction in waste feed rates, tank fume feed rates and air/nitrogen mixture
injection to tank 24 (to reduce fumes generated by steam stripping). Temper-
ature probes for incinerator control are located about 12 feet downstream
from the burner tip. This is near the end of the combustion chamber near
the boiler entrance.
According to the interim status document, the operator is required to
observe the incinerator stack gas for visual emissions hourly.
Four continuous monitors relay operating information regarding plenum
temperature, stack-gas oxygen concentration, combustion chamber temperature
and fume gas vent line pressure to a readout board in the operations building.
IT operating records indicate that waste has been burned at an
estimated average rate of 35 to 40 gallons per hour.
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54
Liquid waste feed rate is not continuously monitored, although a rough
estimate can be determined using changes in waste level in tank 25, the
waste feed tank. Waste levels of tank 25 are only recorded approximately
four or five times over a 24-hour period while the incinerator is operating.
Liquid waste is incinerated on a semi-batch basis so, when the waste level
in tank 25 gets low, a new batch of waste is pumped in from the top of
tank 22.
The waste at various levels in tank 22 is reportedly sampled for lead,
mercury, halogenated compounds, sulfur and heating value of waste prior to
discharge to tank 25. Because waste is normally blended in tanks 22 and 25
prior to incineration, the exact time and date of incineration of a partic-
ular waste load is not known. Also, because of this blending, the quality,
and, thus, oxidation characteristics of the waste is not consistent.
Centrifugation (Sludge Dewatering)
IT uses a mobile centrifuge to dewater surface impoundment sludge for
eventual offsite land disposal. Although the unit has been moved to dewater
sludges at various onsite impoundments, it is normally located adjacent to
the west side of impoundment 105. In this position, it can treat sludge
from ponds 103, 105 and 106. The centrifuge basically took the place of
surface impoundment 102B which was reportedly used extensively for sludge
drying. The centrifuge normally operates 6 days a week, Monday through
Saturday, 24 hours a day. The unit is operated by IT-Motech, a division of
IT separate from the division that operates the rest of the Vine Hill facil-
ity. Although OHS reported that the centrifuge was operating prior to
February 24, 1984, the first centrifuge records IT was able to provide NEIC
were dated September 1984.
The centrifuge is a flow-through operation. A submersible pump first
moves sludge from an impoundment to a grinder (mazorator) to reduce the
size of sludge particles. The sludge then goes to a variable speed 20-inch-
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55
diameter centrifuge bowl, rotating at up to 2500 revolutions per minute
(rpm)*, which spins out the liquid or centrate. The centrate is returned
to a surface impoundment while the sludge cake is continuously removed by a
centrifuge conveyor and deposited in a truck for eventual offsite disposal.
Air is pulled through the centrifuge bowl at about 100 cubic feet per minute
and vented through a 2-ton granular carbon filter for emissions control.
An emulsion-type polymer can be added to the sludge to enchance centrifuga-
tion, if necessary. The total unit is mounted on a 40-foot truck trailer.
Sludge processing capacity is reportedly 250 gallons per minute.
Information on centrifuge operating conditions is recorded on the Centri-
fuge Operations Log. This includes sludge feed rate, bowl speed, oil condi-
tions, etc. A Centrifuge Field Analyses Log is used to record information
on treatment efficiency (feed solids/centrate solids) and identifies the
surface impoundment being treated. IT reports that there is no sludge sam-
pling to determine chemical and physical properties of the sludge, except
for determining percent solids of the feed and infrequent pH measurements.
There is no Project Sample Log, as indicated in the October 15, 1984 Opera-
tions Plan for this unit.
Air samples of vent gases are reportedly taken about every 2 weeks
with Dreager tubes to monitor the condition of the carbon filter. Results
are reported on one of the centrifuge logs. If "detectable levels" of phenol
(.5 ppm), benzene (5 ppm), toluene (25 ppm) or hydrogen sulfide (1 ppm) are
found, the carbon is reportedly changed.
The bowl was running at 1437 rpm during the NEIC inspection on March 14,
1986.
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56
FINDINGS
WASTE SAMPLING/ANALYSIS/LABORATORY PROCEDURES
IT, Vine Hill is not following its DHS-approved March 14, 1983, Waste
Analysis Plan (WAP) as reqired by Section II Condition 5 of the HWFP, 22
CAC, Article 18, §67102(6) and 40 CFR 265.13(6)7264.13(b). IT has either
not conducted or recorded all of the waste analysis required in the WAP for
all waste loads handled. All waste samples for truck receiving analysis
are not taken, as discussed in the WAP. IT has either not conducted,
recorded or maintained the results of treatability/compatability testing,
as required by the February 1985 supplement to the Vine Hill Waste Analysis
Plan [Appendix D].
Vine Hill has received and accepted waste which does not closely match
the characteristics of the "representative sample" submitted and analyzed
during the waste predisposal evaluation. The facility had not analyzed each
hazardous waste load received to determine if it matched the identity of
the waste specified on the accompanying manifest as required by 22 CAC,
Article 18 §67102(a)(4) and 40 CFR 265.13(a)(4)/265.13(a)(4). Finally, IT
is following some analytical procedures which would not give reliable
analysis results and which are not approved methods. Specifics of these
general findings follow.
IT has either not conducted or recorded all of the analysis on waste
received at the facility according to the March 1983 WAP, as required by 22
CAC, Article 18, §67102(b), Section II, Condition 5 and Section III, Condi-
tion 7 of the HWFP, and 40 CFR 265.13(6). NEIC requested to review analyti-
cal records, including the Hazardous Waste Predisposal Evaluation forms
(predisposal analysis results), Disposal Location forms (truck receiving
analytical results), and laboratory bench sheets for generators, with names
beginning with the letters C, I, and T, which had shipped waste to Vine
Hill in May of 1983, 1984 and 1985.* Of the 97 "packages" requested,
Because of the large number of waste loads received at Vine Hill
annually, this randomly selected cross-section of waste loads received
was used to identify patterns of laboratory operation and recordkeeping
activity.
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57
IT could not provide 15 or about 15%. Therefore, IT has either not conducted,
recorded or properly maintained the analytical records as required by HWFP
General Condition 6(6), 22 CAC, Article 21 §67103(b)(3) and 40 CFR
265.73(b)(3)/264.73(b)(3).
Not only were complete documents missing but the records that were
provided and reviewed were found to be deficient. As summarized on Table 7,
30 of the required 775 analyses required during truck receiving (about 4%)
were not conducted/recorded, as required by the WAP. Additionally, about
40 of the 395 predisposal analyses necessary to compare and verify waste
load identification (10%) were not conducted/received.
Table 7
SUMMARY OF LABORATORY RECORDS REVIEW
Required
Analytical
Test
PH
Normality
Phase distribution
Density
HCVP
Solvent distribution**
Totals
Truck Receiving Analysis*
Number Number
Required Recorded
146 141 (96%)
146 135 (92%)
146 139 (95%)
146 146 (100%)
146 145 (99%)
45 39 (87%)
775 745 (96%)
Predisposal Analysis
Number Number
Required Recorded
79 73 (92%)
79 68 (86%)
79 69 (88%)
79 71 (90%)
79 75 (96%)
395 356 (90%)
* The nim>her nf rerniVrer? irur.lr rerei'vinrr ana Tricoa ii /Trrea^-er fhan fhe
number of predisposal analyses because while only one predisposal
analysis is required per waste stream accepted, a truck receiving
analysis is required each time a truckload of that waste stream is
received. Thus, if five loads of a particular waste stream were
received, there would have to be five truck receiving analyses but
only one predisposal run.
Solvent distribution is only required on waste samples with an organic
fraction and only required, according to the WAP, during truck receiving.
Although the WAP indicates that all waste with an organic phase will
be distilled to identify heavier-than-water organics (usually chlorinated),
IT laboratory staff indicated that distillation was only conducted if the
HCVP of the waste was greater than 300 ppm hexane equivalents. However,
records show that even waste with an organic phase and HCVP greater than
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58
300 ppm were not always distilled. For instance, there was no record of
distillation results for a solvent/water/sludge waste received at Vine Hill
on May 16, 1983 although the HCVP was 1300 ppm hexane equivalents. The
facility must either follow the DHS-approved WAP or modify it as appropriate
(with subsequent DHS approval) and follow the modification, as required.
IT was not following the waste sampling procedures specified in the
DHS-approved WAP, as required by Section VII, Condition l(b)(2) of the ISD,
22 CAC 18 §67102(c)(2) and 40 CFR 265.13(c)(2). On March 5, 1986, IT sam-
pling personnel were observed on numerous occasions sampling vacuum trucks
through the rear port even though the WAP specifies vacuum trucks are to be
sampled through the center port. The choice of sampling port appeared to
be determined by the truck driver who often opened the rear port prior to
the arrival of an IT sampler. After NEIC discussed sampling procedures
with laboratory personnel, most trucks were sampled through the center port.
Also, following these discussions, the truck drivers began to wear safety
gear while opening the tank ports.
Vine Hill is not analyzing waste for ignitability by an approved method
and the waste analysis plan does not contain the rationale for use of the
HCVP method instead of the accepted ignitability test, as required by 22
CAC, Article 18 §67102(b)(l), 40 CFR 265.13(b)(l)/264.13(b)(l). IT uses a
TLV sniffer, calibrated to hexane, to monitor waste vapors. The facility
considers 500 ppm hexane equivalent to be equal to an ignitability of 140°
F. (60° C.). However, IT has not demonstrated that this method is superior
or equal to that specified in 40 CFR 26.1.20. Proper ignitability testing
is required to properly handle certain waste and ensure that California
land disposal restrictions for ignitable hazardous waste are met.
IT, Vine Hill does not conduct treatability/compatibility testing on
reactive waste, as indicated by IT in the February 6, 1985 submittal to EPA
in response to the EPA complaint. IT indicated that results from all
treatability/compatibility testing are recorded on the waste Disposal Loca-
tion form. While the IT submittal to EPA indicates that a compatibility
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59
test is conducted whenever there is a potential risk or possibility of an
exothermic reaction, there were no records of any compatibility testing
being conducted. Exothermic reactions should be expected whenever pH
neutralization occurs, as well as during some oxidation reactions.
IT has not always analyzed the waste received to ensure that it matches
the identity of the waste description on the manifest, as required by 22
CAC, Article 18 §67102(a)(4) and 40 CFR 265.13(a)(4)/264.13(a)(4). For
example, there are no records of a molybdenum analysis for a waste load
received on January 23, 1986 (manifest #84313818) even though the manifest
showed molybdenum at 1300 mg/L. Other examples are given below.
Constituent
Waste No. Date Received Noted on Manifest Comments
82842
82246
83156
05/23/85
05/29/84
05/29/85
05/26/85
05/29/85
Mercury
Arsenic
Gal 1 i urn
Chromium
nickel ,
silver,
, lead,
copper
zinc
No analysis
mercury
No analyses
arsenic/gall
No analyses
metals.
results for
results for
ium
results for
Although IT indicated that metals analysis may not be conducted on
truck receiving waste if the predisposal analysis shows very low levels, it
has been shown that there are many cases where the waste actually received
(and accepted) has varied substantially from what the predisposal analysis
showed. Thus, the waste actually received may have concentrations of metals
much higher than those shown in predisposal and, if adequate truck receiving
analysis is not conducted on this waste, it may be handled improperly.
Some of the analytical methods used by IT are not adequate to properly
quantify the constituents analyzed for or are not approved for such deter-
minations. For example, the cyanide procedure used by the laboratory is
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60
inadequate as it could result in analytical results biased low. The
laboratory indicated that 10 ml of sample is distilled into 50 to 100 ml of
1 N sodium hydroxide and cadmium nitrate is added to precipitate any sul-
fides. The cadmium nitrate should be added to the sample before distilla-
tion in order to remove any sulfide present which may react with cyanide to
produce thiocyanate ion which does not undergo reaction with silver ion in
the titration. The spot test procedure for cyanide is also inadequate.
While it is recognized that only simple cyanides are determined in the test,
IT indicated that the test consists of adding p-dimethyl-aminobenzalrhodanine
to a 1:8 deionized water dilution of the sample; if color change occurs,
then cyanide is present. However, p-dimethyl-aminobenzalrhodanine is a
silver ion-sensitive indicator which has no color producing reaction with
cyanide ion and thus the test, as described, would be meaningless.
The metals analysis is also improperly conducted as truck receiving
samples are not digested properly. While predisposal samples are digested
by approved EPA Office of Solid Waste methods, the truck receiving samples
are only diluted one to ten [with nitric acid and Triton X-100 (a surfac-
tant)] and then aspirated into the ICP spectrometer. In not using an
approved digestion method for the determination of metals during truck
receiving analyses, results that are attained would be biased low. This
practice may allow waste, which may have metals concentrations in excess of
those found during predisposal analyses or listed on the manifests, to be
handled improperly by site personnel.
Vine Hill has often accepted waste which does not match the character-
istics of the "representative" predisposal sample. For example, waste stream
#81955 had predisposal and truck receiving analytical results for sulfide
of 50 mg/L and ND (not detected), respectively, and solids determinations
70% and 10%, respectively. Although these are substantial differences in
waste characteristics, Vine Hill accepted and disposed of the waste. Waste
stream #82876 had a predisposal HCVP value of 180 ppm of hexane equivalents.
However, a load with this waste stream number, received at the facility on
May 20, 1985, gave a result of 4600 ppm hexane equivalents and another load,
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received on May 31, 1985, produced a value of 5000 ppm hexane equiva-
lents. Although these are also substantial differences, both loads were
accepted. This case is particularly interesting because the waste approved
during predisposal would not be considered ignitable by IT while the actual
load received at the facility would be ignitable and, thus, require totally
different handling.
A last example is for waste stream #83175 which had predisposal analy-
sis characteristics of a phase distribution of less than 1% solids and 100%
non-polar solvents. However, a load received on May 7, 1985 showed 100%
solids, clearly a waste of different physical and most likely chemical
characteristics.
In the three examples given, waste were accepted at the facility for
treatment/disposal although the waste loads received had substantially dif-
ferent characteristics than the waste approved by IT during predisposal
evaluation. Apparent variations in waste such as these indicate that either
the waste generating process has changed, IT did not have a "representative"
sample of the waste during predisposal evaluation, or the generator is send-
ing different (unapproved) waste to IT. In these cases, IT should request
additional/updated information/samples from the generator to ensure that IT
is knowledgeable of the characteristics of the waste received and is capable
of properly handling such waste.
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WASTE HANDLING UNITS AND FACILITY OPERATIONS
Waste Transfer
IT did not follow generator requirements for hazardous waste
determination, as specified in 22 CAC 6 §66471 and 40 CFR 262.11 and did
not always accurately describe waste on the manifests used to transport
centrifuge cake to offsite facilities, as required by 22 CAC Article 6
§66481(b). Waste stored/treated in the Vine Hill surface impoundments is
routinely pumped to the Baker facility without any waste characterization.
Because the Vine Hill impoundments receive an array of manifested hazardous
waste and treated waste from the tanks at Vine Hill and because some "treat-
ment" occurs from commingling of these waste, specific waste characteristics
of material in each impoundment is unknown. IT Vine Hill, as generator, is
responsible for determining if this waste pumped offsite to Baker is hazard-
ous or not and for identifying any hazardous characteristics. IT personnel
indicated they consider Vine Hill and Baker to be one facility and, there-
fore, any waste transfers would be internal waste transfers and not subject
to waste characterization or manifesting; however, the facilities are
physically separated and have separate EPA I.D. numbers. Additionally,
Federal and State agencies consider these to be separate facilities.
IT indicated that they have conducted pH analysis on all wastewater
pumped from Vine Hill to the IT Baker facility. Additionally, Figure IV-1
of a February 6, 1985 submittal to EPA showed "Pond Transfer Analysis" being
conducted on waste pumped from the Vine Hill impoundments to Baker
[Appendix G]. There are no records of such analysis and a review of pond/
tank status records and Treatment Plant (T.P.) Operations Status Sheets for
January 1985 through 1986 indicated that pH was not always measured, as
indicated. Following is a summary of days when waste was pumped from Vine
Hill to Baker when pH measurements of the waste transferred was not recorded.
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Year
1985
1986
TOTAL
Days Pumping
235
57
292
Days Without
pH Measurements
104 (44%)
18 (32%)
122 (42%)
Before December 1984, there are no records of any analysis conducted
on Vine Hill ponded waste before transfer offsite to Baker. From January
1985 through February 1986, pH measurements of transferred wastewater were
made on only 170 out of 292 days, or 58% of the time, when waste was pumped
to Baker.
Not only are waste characterization records incomplete, IT records are
inadequate to determine the quantity of waste transferred from Vine Hill to
Baker. This information is needed for Vine Hill to properly prepare facil-
ity operating records. It is also required to be included in the Vine Hill
Biennial Report required by 40 CFR 262.41(a)(5), CAC Article 6 §66498)(a)(5)
and in the Baker Annual Report (22 CAC 21 §67165).
All of the available information on waste pumping to Baker has been
recorded on the T.P. Operations Status Sheet since September 1984. Before
September 1984, no record of pond pumping was apparently maintained. From
September 1984 through February 1986, there was no record of the time waste
pumping to Baker began or ended (necessary to determine volume of waste
transferred using pump capacities) on 45 of 389 pumping days (12%).
IT did not manifest waste pumped from Vine Hill to Baker. Since
September 1984, waste was pumped from Vine Hill to Baker on 389 days and no
manifests were used. On many days, waste was pumped during different time
periods and from more than one pond. As stated previously, IT personnel
consider Vine Hill and Baker to be one site, so they believed that the waste
would not have to be manifested.
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All of the hazardous waste shipping manifests used to transport
centrifuge (dewatered) solids to IT-Panoche for landfilling do not accurately
describe the waste, as required by 22 CAC, Article 6 §66481(b). The mani-
fests reviewed by NEIC all indicated that the waste solids were "pond 105
sludge" (noted in Section J of the manifest "Additional Descriptions for
Materials Listed Above") even though Centrifuge Operation Logs indicate
that pond 106 sludge was also transported. For instance, Centrifuge Opera-
tions Logs indicate that pond 106 sludge was being dewatered from December 2
to December 6, 1985. However, the shipping manifests for December 3
(84165361, 84165362, 84165360, 84165359) all improperly indicate that it
was "pond 105 sludge". State regulation 22 CAC, Article 6 §66481(b) requires
that "all applicable sections of each manifest be accurately, completely
and legibly filled out".
Security
IT was not maintaining the Vine Hill hazardous waste area perimeter
fence in the condition required by Section III Condition 8 of the HWFP,
Section II, Condition 17 of the ISO, 22 CAC 18 §67103 and 40 CFR 265.14/
264.14. NEIC observed three holes in the perimeter fence north of ponds
101 and 106 on March 11, 1986. IT personnel indicated the holes were a
result of repair work to the pond dikes. No dike repair work was observed
from March 3 through 21 during the NEIC inspection. IT showed NEIC inspec-
tors a work order to repair the fence scheduled for March 13 or 14, 1986.
When rechecked on March 20, 1986, two of the holes had been repaired, but
one hole remained.
Holes in the Vine Hill perimeter fence have been observed during
previous inspections. In February and April 1984, DHS and EPA Region IX
conducted interim status inspections at the IT Vine Hill facility and
observed holes in the perimeter fence which could allow unauthorized entry.
This recurring problem was brought to IT's attention by letter in 1984 and
a State complaint in 1985.
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Facility Inspection Records
IT has not maintained inspection records or conducted facility
inspections, as required by the applicable IT inspection plan and State and
Federal regulations and permits. HWFP Section II Condition 9(b)(l); ISO
Section III, Condition 5(b)(l); 22 CAC 18 § 67104(b)(l) and 40 CFR
265.15(b)(l)/264.15(b)(l) all require IT to develop and follow a written
inspection schedule (plan). The IT Operations Plan, dated March 14, 1983,
contains an Inspection Plan which was applicable from March 1983 to October
1984 and was used to evaluate IT's compliance with inspection requirements
for this time period. A revised inspection plan, submitted to EPA and the
State in October 1984 in response to a State Administrative Order, was used
to evaluate IT's performance from October 1984 to March 1986. Both inspec-
tion plans are similar and specify forms and procedures to be used for spe-
cific inspections.
The October 1984 Plan is identical to the earlier version except that a
section was added to identify the types of problems to look for during the
inspection and the inspection forms were modified slightly.
ISO Section III, Condition 5(d), 22 CAC 18 §67104(d) and 40 CFR
265.15(d)/264.15(d) require inspection records, to include at least:
Date and time of the inspection
Name of the inspector
Notation of observations made
Date and nature of any repairs or other remedial action
NEIC reviewed the following three facility inspection logs for March
1983 to March 1986, or as available, for completeness and conformity to the
applicable facility inspection plan and applicable State and Federal
regulations.
Daily Inspection Report
Weekly Inspection Report
Quarterly Inspection Report
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66
The following general areas of deficiencies were observed in IT
inspection logs.
The Daily and Weekly Inspection Reports generally used prior to
1985 did not require time of inspection to be recorded and, thus,
time was not routinely reported. After January 1985, the time
was occasionally not recorded.
The date and nature of any repairs or other remedial action was
often not recorded. IT inspection plans state that the inspector
is to fill out and record the number of the appropriate Maintenance
Request (work order) corresponding to required repairs/remedial
action and then give all work orders and the Daily Inspection
Report to the Management Supervisor on duty who maintains an "In
Progress" file for inspection logs with repairs/remedial action
pending. As the work orders are completed, the supervisor is to
go back to the "In Progress" file and note on the appropriate
inspection log the remedial action taken, date completed and sign
his name indicating that the job is completed. However, the work
order numbers are often not recorded by the inspector and the
remedial action taken, date completed and signature are often not
recorded by the supervisor. The supervisor sometimes indicates
"scheduled for repairs" or "contractor has been called" and dates
and initials the inspection log without indicating that the work
was actually completed.
Specifics of the inspection records review are discussed below.
Daily Inspection Report
The Daily Inspection Report contains five major categories.
Chemical, physical and biological treatment
Storage tanks
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67
Surface impoundments
Incinerator
Emergency equipment
The inspection is reportedly conducted during the day shift by IT
operations personnel (usually treatment plant operators), including weekends,
if the treatment plant is operated. Below is a summary of the missing and
deficient Daily Inspection Reports for March 5, 1983 through March 14, 1986,
usually involving missing records, no time of inspection or no remedial
action recorded.
Years
1983
1984
1985
1986
TOTAL
Number
of
Records
Required
302
366
365
73
1106
Number
of
Records
Provided
266
319
358
71
1014
Number of
Records
Missing*
36 (12%)
47 (13%)
7 (2%)
2 (3%)
92 (8%)
Number
of Records
Deficient
266 (100%)
313 (98%)
224 (63%)
32 (45%)
835 (82%)
Includes weekends and holidays when facility was
operating
When daily inspections were not conducted due to non-working holidays
or weekends, the word "holiday" or "weekend" is often written across the
form. In one case, "weekend" was indicated on the form and no inspection
was performed, although the dates actually correlated with a Wednesday and
Thursday when the facility should have been inspected [daily inspection
report dated March 7 (Wednesday) and 8 (Thursday), 1984].
NEIC observed IT personnel conduct a daily inspection on March 7, 1986
to check for thoroughness and conformity to the facility inspection plan
and applicable State and Federal regulations. The following deficiencies
were observed during the March 7, 1986 inspection.
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The entire facility was not inspected. The inspector indicated
he had a set routine for inspections and was very thorough with
the areas he covered. However, he did not cover the following
areas.
Freeboard was not checked in ponds 100 and 102A*
Fire extinguisher on centrifuge was not inspected
Tank 61 was not inspected
The container storage area behind IT Analytical Services was
not inspected
The following deficiencies, observed and discussed with IT person-
nel during the inspection on March 7, 1986, were not recorded on
the daily inspection report for that date.
No freeboard markers in ponds 101 and 104
Inoperable eyewash station near tank 23 (this was fixed
during the inspection by maintenance personnel)
No fire extinguisher at the unloading area near tanks 254
and 252 (the extinguisher was replaced by March 10)
No bulb in safety light for eyewash station near pond 100
and 106
Weekly Inspection Report
The Weekly Inspection Report, in use since about February 1984, contains
six major categories.
Chemical, physical and biological treatment
Storage tanks
Surface impoundments (ponds)
The inspector did not go close enough to these impoundments to visually
observe problems.
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Container/drum storage area
Security
Incinerator
The form used prior to February 1984 did not address security or have
a blank to indicate time of the inspection. Below is a summary of the miss-
ing and deficient weekly Inspection Reports for March 7, 1983 through
March 14, 1986. Deficiencies include times of inspection, records, of
remedial action and signature of inspector.
Years
1983
1984
1985
1986
TOTAL
Number
of
Records
Required
42
52
52
10
156
Number
of
Records
Provided
41
49
51
9
150
Number of
Records
Missing
1 (2%)
3 (6%)
1 (2%)
1 (10%)
6 (4%)
Number
of Records
Deficient
41 (100%)
40 (82%)
31 (62%)
8 (89%)
120 (80%)
NEIC conducted an inspection of the facility perimeter and ponds on
March 11, 1986 to check for facility security and pond integrity which are
part of the weekly inspection requirements. The IT weekly inspection for
March 14, 1986 found no deficiencies, but the following deficiencies were
noted by NEIC inspectors on March 11 and were still present March 20, 1986.
Holes in perimeter fence; three holes were found on March 11;
two were repaired by March 20
Erosion on northeast side of pond 103 and no protective cover
on internal impoundment dikes.
Quarterly Inspection Report
Quarterly inspection reports for the period between March 5, 1983 and
March 14, 1986 were requested from IT, but only three reports were provided.
Quarterly Inspection Reports are required in both the 1983 and 1985 inspec-
tion plans. The inspections are reportedly conducted by IT supervisors and
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are narrative in style. Below is a summary of the missing and deficient
quarterly inspection reports.
Years
1983
1984
1985
1986
TOTAL
* In
Number
of
Records
Required
4
4
4
1
13
eludes weeke
Number
of
Records
Provided
0
0
2
1
3
nds and hoi:
Number of
Records
Missing*
4 (100%)
4 (100%)
2 (50%)
0 (0%)
10 (77%)
idays when fa
Number
of Records
Deficient
2 (100%)
1 (100%)
3 (100%)
cilitg was
operating.
Each of the three quarterly inspection reports reviewed recorded at
least one unsatisfactory condition for which "recommended action" was to be
taken but where such action was not reported. Therefore, each report was
determined to be deficient.
Vine Hill/Baker Pipeline Inspections
IT indicated inspections are conducted every 4 hours on the pipeline
transferring waste from Vine Hill to Baker when the pipeline is operating.
IT records pipeline inspections on the Treatment Plant (T.P.) Operations
Status sheets. Records were reviewed for September 1984 through February
1986 and were judged deficient if inspection times were not recorded, if
liquid was pumped and the pipeline was not inspected or if liquid was pumped
and at least one inspection was not conducted every 4 hours during pumping.
Below is a summary of the T.P. Operations Status sheets records review in
regard to the Baker pipeline inspections. As indicated, a total of 43% of
the records were deficient.
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Year
1984
1985
1986
TOTAL
Number
of
Records
110
325
59
494
Number of
Records
Deficient
56 (51%)
128 (39%)
28 (47%)
212 (43%)
Other Inspection Requirements
In addition to not following the required inspection/recordkeeping
requirements of the facility inspection plan, IT is not following other
inspection and equipment monitoring procedures required by the facility
Operations Plan, Interim Status Document (for surface impoundments and
incinerator), the Hazardous Waste Facility Permit (for tank and container
storage and treatment) and other operating procedures submitted to regula-
tory agencies. Additional inspection requirements of these plans, permits
and documents include:
Requirement
Document Citation
Daily determinations of waste
levels in tanks
Daily pH monitoring of sur-
face impoundments
Hourly observations of
incinerator stack emissions
HWFP, Section IV, Condition 3(d)
and Operations Plan, p 42
IT submittal to EPA, Region IX,
February 6, 1985, Exhibit 13
[Appendix D]
HWFP, Section XI, Condition
3(a)(2), ISO Section III,
Condition 5(d)
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72
Daily tank waste levels determinations and surface impoundment pH
measurements are recorded on an inspection form entitled "Tank Status
Record".* Incinerator stack emissions observation are recorded on the
Incinerator Log Sheet. As with other required inspections, the date/time
of inspection and inspectors name are to be recorded along with the mon-
itoring results. All records are to be maintained a minimum of 3 years.
Although NEIC requested all inspection records for the last 3 years,
March 1983 to March 1986, the only Tank Status Record sheets provided were
from December 1984 to March 1986. Because IT did not produce records for
1983 and the first 11 months of 1984, IT either has not conducted or recorded
or is not maintaining daily records for tank level and pond pH determination,
as required by Section III Condition 9(d) of the HWFP, Section IV, Condi-
tion 1(5) and Section III, Condition 5 of the ISO, 22 CAC 18 §67104 and 40
CFR 265.15/264.15. Also, prior to July 2, 1984, IT was either not observing
or recording incinerator stack emissions hourly, as required. The Incinerator
Log Sheet was not modified to include a section for recording stack emission
observations until July 3, 1984. No records of emission observations prior
to this time could be provided. A discussion of the deficiencies of the
records that were provided follows.
Daily Tank Level Determinations
The Tank Status records that were available were reviewed to determine
whether or not daily tank level determinations and surface impoundment pH
measurements were recorded and to note -if date/time and inspector's name
were recorded.
Results of the records review for tank waste level determinations are
summarized below.
During at least the time period from between December 3 and 7, 1984,
surface impoundment freeboard levels, rather than pH, were recorded on
these records.
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73
Year
1983**
1984
1985
1986
TOTALS
* As
** Mar
Number of
Days
Operating*
259
336
363
59
1017
determined by
*rh 74. 79fl-? f-n
Number of
Records
Available
0
17
248
40
305
Number of
Records
Missing
259 (100%)
319 (95%)
115 (32%)
19 (48%)
712 (70%)
facility operation/inspection
n*arr«»mh«ar 37 . 7 OX? 3
Number of
Records
Deficient
N/A
4 (24%)
178 (72%)
27 (68%)
209 (69%)
records
Daily pH Monitoring-Surface Impoundments
Results of the records review for daily pH monitoring of the surface
impoundments is summarized below. As indicated previously, there were no
records for 1983 and the first 11 months of 1984. Most deficiencies in the
records that were reviewed involved no reporting of the time of inspection
or the identity of the inspector.
Year*
1984
1985
1986
TOTAL
Number**
of
Days
Operating
29
363
59
451
Number
of
Records
13
197
39
249
Number of
Records
Missing
16 (58%)
166 (46%)
20 (34%)
202 (45%)
Number of
Deficient
Records
3 (23%)
123 (62%)
25 (64%)
151 (60%)
*
**
There were no records for 1983 and the first
11 months in 1984.
As determined by facility operation/inspection
records
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74
Incinerator Emissions Inspection
Results of the records review of the Phase II Incinerator Log Sheet
are given below. As indicated earlier, July 3, 1984* was the first day a
modified Incinerator Log was used by IT to record incinerator stack obser-
vations. However, even after institution of this modified form, observations
have not always been made/recorded as required. Many of the missing
observations occurred during shift changes or at times when the operators
were "too busy" as noted on the logs.
Number Number Records
Records Missing One or
Year Reviewed More Observations
1984* 112 69 (62%)
1985 226 84 (37%)
1986 _48 JL9 (40%)
Total 386 172 (45%)
Number Records
Missing Two or
More Observations
44 (39%)
41 (18%)
_7 (15%)
92 (24%)
* Starting on July 3, 1984
Incinerator Logs were missing for at least 4 days (two in 1985 and one
each in 1984 and 1986) when the incinerator was apparently operating but
there are no record sheets.
Personnel Training
IT training records indicate that Vine Hill employees have not received
initial training and annual updates in the time periods required by the
HWFP Section III, Condition 10(c) and (d), ISO Section III, Condition 6(c),
22 CAC 18 §66105(b) and 40 CFR 265.16(b)/264.16(b). An annual training
update is also required by the Training Plan in the DEQ-approved facility
Operations Plan.
A February 8, 1984 DHS inspection reported that stack observations
were not being recorded.
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75
The March 14, 1983 IT training plan requires that each new operational
employee receive the following initial training with annual updates.
Contingency plan
Emergency procedures
Fire extinguisher
Shutdown of operations
Site safety rules
Training records were reviewed for 10 current IT employees to determine
adequacy of records and training. As the summary below shows, none of the
10 employees had received the required training 6 months after hire or
annually thereafter, as required by the cited regulations.
Employee
K.
P.
J.
R.
W.
G.
W.
D.
S.
D.
Bailey
Chakich
Hattum
Hays
Kindt
Maderos
Pells
Price
Schwartz
Stunsbury
Job Title
Process Operator
Chemical Tech/Foreman
Process Operator
Process Operator
Process Operator
Process Operator
Site Manager
Process Operator
Process Operator
Process Operator
Hire Date
08/12/85
12/04/79*
03/29/82
06/22/77*
07/06/78*
05/12/82
03/19/79*
07/19/84
08/03/76*
06/23/83
Training
Within
6 Months
No
No
No
No
No
No
No
No
No
No
Annual
Every
12 Months
N/A
No
No
No
No
No
No
No
No
No
ISD Section III, Condition 6(b) required initial training be completed
by the effective date of the ISD (04/06/81) or within 6 months after
hire date.
The IT training plan incorporated into the March 14, 1983 IT Operations
Plan is not adequate as it does not address training responses to ground-
water contamination incidents, as required by the ISD, 22 CAC 18
§67105(a)(3)(E), 40 CFR 265.16(a)(3)(v)/264.16(a)(3)(V). Such training is
required as part of the minimum training for facility personnel. The 1983
plan also did not specify that the initial training would be completed
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76
within 6 months, as required by the HWFP, Section III Condition 10(c) and
(d), ISO Section III, Condition 6.(c), 22 CAC 18 §66105(b) and 40 CFR
265.16(b)/264.16(b).
Contingency Plan
IT has not modified the DHS-approved Contingency Plan to reflect changed
conditions at the facility, as required under Section III, Condition 17 of
the HWFP; Section III, Condition 15 of the ISO; 22 CAC 20 §67143 and 40 CFR
265.54/264.54. The plan improperly shows eyewash stations/safety showers
in locations where the equipment no longer exists, such as between tanks 21
and 23 and south of tank 31. Although new eyewash stations/safety showers
have been installed to replace the removed units, the Contingency Plan had
not been modified (and approved by DHS) to reflect these changes. The Con-
tingency Plan submitted with the IT RCRA Part B application in April 1985,
does locate the units properly; however, this is not the DEQ-approved Con-
tingency Plan or the plan that has been distributed to local emergency per-
sonnel. Because the Contingency Plan may be used by these offsite emer-
gency personnel in the event of an emergency, it is necessary to modify,
receive DHS-approval and disseminate the new plan to offsite emergency ser-
vices and/or replace the equipment.
Operating Record/Waste Tracking
IT, Vine Hill has not maintained a complete operating record, as all
waste received at the facility is not clearly traceable from time of receipt
to treatment, storage and/or disposal at the facility, as required by Sec-
tion III, Condition 19(b) of the HWFP; Section IV, Condition 1 of the ISO;
22 CAC 21 §67163 and 40 CFR 265.73/264.73.
In general, substantial portions of the facility operating record
involving waste tracking were either not recorded or not maintained, as
required. Other portions were not maintained at the facility but at an
offsite location. The methods and dates of treatment and disposal,
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77
including locations cross referenced to specific manifest numbers, have not
been maintained for all waste loads received at Vine Hill. Finally, the
facility has not recorded the location and quantity of each hazardous waste
load received on a map or diagram for each disposal area, as required.
Maintenance of Records
IT, Vine Hill has either not recorded or not properly maintained all
waste tracking records (a part of the facility operating record), as
required by Section IV, Condition l(b) of the ISO; Section III, Condition
19(b)(l) of the HWFP; 22 CAC, Article 21, §67163(b) and 40 CFR 265.73(b)/
264.73(b). Portions of the records were not maintained at the facility, as
specified by ISO Section IV, Condition l(a), HWFP Section III, Condition 19
(b)(l), CAC, Article 21 § 67163(a) and 40 CFR 265.73(a)/264.73(a). During
the NEIC inspection, all facility tracking records, including shipping mani-
fests, Waste Disposal Location forms, Tank Treatment Processing records,
Treatment Plant Operations Status Sheets and Incinerator Log sheets were
requested for the period of time from March 1983 to March 1986. As shown
below, all requested records were not provided and IT could not identify
where or if they existed. Additionally, a substantial number of shipping
manifests and Disposal Location forms were not maintained onsite, as
required, but rather at an offsite location.
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78
General Dates of General Dates of
Record Description Records Provided Records Missing*
Shipping Manifests Mar. 1983 to Dec. 1984**
Jan. 1985 to Mar. 1986
Disposal Location Mar. 1983 to Dec. 1984
Forms Jun. 1985 to Mar. 1986
Tank Treatment Jan. 1984 to Mar. 1986 Mar. 1983 to Jan. 1984
Processing Records
Treatment Plant Sep. 1984 to Mar. 1986 Mar. 1983 to Sep. 1984
Operations Status
Sheets
Incinerator Log Feb. 1984 to Mar. 1986 Mar. 1983 to Feb. 1984
* This only identifies major blocks of missing records but does not
include any single missing documents.
** This group of records was not being maintained at the Vine Hill facil-
ity, rather they were located at an offsite office.
Quality of Records
The records that were maintained by Vine Hill were inadequate to iden-
tify the method and date of treatment/disposal of all waste handled at the
facility including location and cross-reference to specific manifest numbers,
as required by Section IV, Conditions l(b)(l) and (2) of the ISO; Section III,
Conditions 19(b)(l)(i) and (ii) of the HWFP; 22 CAC, Article 21, §67103(b)
(1) and (2) and 40 CFR 265.78(b)(l)/264.78(b)(l). Also, Vine Hill has not
recorded the location and quantity of each hazardous waste load received on
a map or diagram for each disposal area, as required by 22 CAC, Article 21,
(b)(2) and 40 CFR 265.78(b)(2)/264.78(b)(2). A discussion of these defici-
encies follows.
Although IT has numerous record sheets used in tracking/processing the
waste, they do not report all of the required information and the records
are not always completed and maintained adequately. For example, Tank Treat-
ment Processing records which track waste loads through tank treatment to
disposal are not maintained for tanks 18, 19, 20, 21, 22, 25, 33 and 61 and
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79
only infrequently for tanks 11 and 17. All of these tanks are used for
waste receipt, storage and/or treatment and records of their use must be
maintained. Furthermore, many of the records that do exist are incomplete,
as they do not always record all waste loads received in a specific tank
and cross reference the loads received to a specific manifest number.
Using all of the tracking records provided by IT, NEIC attempted to
track 185 waste loads received at Vine Hill between 1983 and 1986. Of these
loads, 169 were chosen, at random, from offsite generators whose names began
with "C" and "I" and who brought waste to the facility during May of the
last 3 years; 16 other loads were selected (two for 1984, one for 1985 and
13 for 1986) in attempts to cover all possible waste handling at IT. A
summary of the results of the waste tracking effort are given below; speci-
fics are presented in Appendix H.
Year
1983
1984
1985
1986
Totals
Number of Waste
Loads Tracked
15
34
123***
13
185
Number of
Loads
to Ponds*
11
20
42
1
74
Number of
Loads
to Tanks
4
14
78
12
108
Number of Loads
to Tanks Unable
to Track Further**
4 (100%)
12 (86%)
71 (91%)
10 (83%)
97 (90%)
* IT considers the surface impoundments to be disposal locations and
thus believes no further tracking is necessary.
** Records are not sufficient to track these waste loads beyond initial
offloading in specific tanks.
IT indicated three of these 1985 waste loads went to IT Oil Reprocessors
and no further information was provided.
***
In general, IT records that were available were adequate to track the
waste load to the initial offloading location/unit (often just for temp-
orary storage). Tracking a specific waste from this initial location to
final treatment/disposal was not usually possible.
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80
All waste which was unloaded directly to the surface impoundments could
be tracked to the initial receiving unit. However, this waste is subse-
quently pumped to various other impoundments at Vine Hill and/or the Baker
facility and no complete records of these transfers exist.
All waste which was unloaded directly to tanks was also tracked to the
initial unloading unit. However, of the 108 waste loads that went to tanks,
97 (or 90%) could not be tracked to final disposition.
Overall, of the 185 waste loads followed, at least 97 or 52% could not
be tracked from receipt at Vine Hill to final disposition, as required.
Annual/Biennial* Reports
The annual/biennial documents submitted to DHS for 1984 are inadequate
as they do not contain all of the information required by Section III, Condi-
tions 19(c)(3) and (4) of the HWFP; 22 CAC, Title 21, §67165 and 40 CFR
265.75/264.75. The 1984 document does not report the EPA or DHS identifi-
cation number of each hazardous waste generator from which Vine Hill received
waste and does not relate this number to the description, quantity and han-
dling method, as required. Similarly, the Annual/Biennial Reports submit-
ted in 1982 and 1983 did not meet 22 CAC, Title 21 for the same reason (the
HWFP first required the Annual Document in 1984 so the HWFP condition does
not apply to 1982 and 1983 annual/biennial documents).
IT personnel indicated that they used the Annual Report form provided
by DHS for their 1982, 1983 and 1984 submittals and that this form did not
require reporting of generator EPA or DHS identification numbers. IT also
indicated that a new form was used to complete the 1985 Annual Report and
that it did contain the necessary EPA/DHS generator identification numbers.
22 CAC requires Vine Hill to stubmit a report of waste receipts annually
while 40 CFR 265.264 requires one Mannually.
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81
Closure Plan
IT's Closure Plan, as presented in the DHS-approved March 14, 1983
facility Operations Plan, is incomplete as it does not include a description
of how impoundments 102A and 102B are to be closed and does not address how
any partial closures of the facility will be conducted, as required by
Section III, Condition 2 of the HWFP; 22 CAC, Article 23 §67212 and 40 CFR
265.112/264.112.
Financial Responsibility
IT has not made adequate financial assurances concerning facility clo-
sure, as required under Section III, Condition 21(a)(l) of the HWFP;
Section VI, Condition l(a) of the ISO; 22 CAC 17 §67002(a) and 40 CFR
265.142(a)/264.142(a). IT's closure estimate is too low because it does
not address the cost of closure at the point in the facility's operating
life when the extent and manner of its operation would make closure the
most expensive [i.e., shutdown with full tanks and ponds necessitating off-
site disposal at other commercial (non-IT) facilities or at IT facilities
at normal costs]. IT assumes normal use of tanks, ponds and pumps for pro-
cessing and waste volume reduction that is a least-expensive option for
closure rather than the required most-expensive option.
IT had not made financial assurances for facility closure, as required
by the ISO Section VI, Condition l(a) in a timely manner. The ISO, effec-
tive April 6, 1981, required financial assurance; however, according to
Section XIV of the IT Operations Plan, IT did not establish this until
sometime in mid-1983. As of February 11, 1983, IT was still negotiating to
set up the required assurances for financial responsibilities.
It should be noted that IT closure and post-closure cost estimates
have been reduced from $800,000 and $20,000 per year, respectively, in 1983
to $600,000 and $13,400 per year in 1986.
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82
Containers
The container storage area at Vine Hill was not in compliance with
several storage area requirements during the NEIC inspection. The container
storage area, used for storage of flammable waste, is not located more than
50 feet from the property line, as required by 22 CAC, Article 24 §67246
and 40 CFR 264.176.* The storage area in use is not designated in the
DHS-approved March 14, 1983, Vine Hill Operations Plan, and, thus, its use
is not in compliance with HWFP, Section IV, Condition 2(c)(l). Also, IT
has apparently not notified DHS of the use of this unit, as required by
Section II, Condition (6)(i) of the HWFP. IT has not conducted weekly
inspections of the containers in the storage area, as required by HWFP,
Section IV.2(d); CAC, Article 24 §67244 and 40 CFR 264.174. Finally, the
March 26, 1985 RCRA Part A application (updated and submitted with Vine
Hill's Part B Completeness Check) does not properly report the current design
capacity of appropriate container storage, as required by 40 CFR 270.13(i).
Although IT indicated that the laboratory waste drum handling area is
an accumulation (<90 days) rather than a storage (>90 days) area, the drum
located in the unit had no waste accumulation date which would be required
for waste being accumulated, rather than stored, prior to offsite disposal.
The small drum storage area located behind the laboratory is situated
within about 20 feet of the facility property line. IT personnel indicated
that ignitable laboratory waste was normally stored at this area, and one
drum of waste solvent (lab pack) with a flammable label on it was in stor-
age during the NEIC investigation. Storage of ignitable waste at this area
is not allowed by Section IV, Condition 2(f) of the HWFP; 22 CAC, Article 24
§67246 and 40 CFR 264.176 as it is within 50 feet of the facility property
line. An Acme Landfill roadway is located directly on the.other side of
the property line.
Part 264 regulations apply to container storage because DHS has issued
IT a final permit for storage activities.
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83
This storage area is not identified in the March 14, 1983 DHS-approved
Operations Plan. In fact, it is not identified on any of the facility maps/
diagrams reviewed during the course of the investigation, including the
General Site Plan in the April 5, 1985 RCRA Part B Completeness Check.
Since Vine Hill is using a storage facility not designated in the approved
Operations Plan, they are not meeting Section IV, Condition 2(c)(l) of the
HWFP which limits container storage to areas designated in the plan. It is
unknown when this area was first used; however, DHS was apparently not noti-
fied of this addition to the facility. If the addition occurred after the
effective date of the HWFP (September 26, 1983), IT did not comply with
Section II, General Condition 6(i) of the HWFP which requires the facility
to notify DHS prior to any planned physical alterations or additions.
Vine Hill has not conducted weekly inspections of the containers in
storage at this area, as required by HWFP Section IV, Condition 2(d); 22
CAC, Article 24, §67244 and 40 CFR 264.174. IT personnel indicated that
the storage area is routinely used for storage/accumulation of laboratory
waste but indicated that no inspections had been conducted.
The Part A RCRA application, submitted with the April 5, 1985 Part B
Completeness Check, inaccurately reports the container storage capacity at
Vine Hill to be 210,000 gallons (more than 3,800 55-gallon drums). The
only identified drum storage area at Vine Hill is a small (approximately
64-foot-square) laboratory waste storage unit which is too small to hold
even 2,500 gallons (50 55-gallon drums stacked three high). The RCRA Part A
application should have been updated to report the actual facility container
storage area capacity, as required by 40 CFR 270.13(i). During the NEIC
inspection, there was no evidence that a container storage area of the capac-
ity reported in the Part A application and meeting the containment require-
ments of CAC, Article 24 §67245 ever existed at Vine Hill.
Treatment Tank Trucks
IT has treated hazardous waste in transporting tank trucks onsite
without notifying DHS of this activity, as required by HWFP, Section II,
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84
Condition (6)(i). Treatment in tank trucks is defined as treatment in
containers by 22 CAC 1 §66028 and 40 CFR 260.
IT records and personnel indicated that reagents had been added to the
hazardous waste in various tank trucks and allowed to react prior to off-
loading to a surface impoundment or tank [Table 8]. This activity is not
identified in the Operations Plan and there is no indication that DHS was
ever notified of this activity.
An internal IT memo regarding this treatment (January 23, 1985,
Appendix E) specifies the situations under which waste can be treated in
tank trucks. The use of tank trucks for waste treatment can be considered
a new process and substantial modification/addition to the facility. Planned
physical alterations or additions are prohibited by HWFP Section II, Condi-
tion 6(i) unless DHS is notified of this activity.
IT indicated that waste is no longer treated in transporting tank trucks.
As indicated in Table 8, the last record of tank truck treatment was on
August 21, 1985.
Surface Impoundments
Vine Hill surface impoundments have been improperly used to dispose of
restrictive and ignitable hazardous waste, as prohibited by 22 CAC, Arti-
cle 15 §66900; 22 CAC, Article 26 §67317 and 40 CFR 265.229. The facil-
ity has not maintained freeboard levels in the hazardous waste surface
impoundments at levels equal to or greater than levels required by the Cali-
fornia Regional Water Quality Control Board Order No. 78-76; ISO, Section XII,
Condition I; 22 CAC, Article 26 §67310(a) and 40 CFR 265.222(a) and cited
in the March 1983 and April 1985 facility inspection plans.
All earthen dikes at Vine Hill do not have a protective cover to mini-
mize wind and water erosion, as required by ISO, Section XII, Condition (2);
22 CAC, Article 26 §67311 and 40 CFR 265.223. There was evidence of erosion
at several of the facility surface impoundments during the NEIC inspection.
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Table 8
TREATMENT IN TANK TRUCKS
85
Manifest Date
Number Received
Waste
Description
Remarks
83063482 01/15/84
83174608 03/13/84
83383982 05/05/84
83383984
83383985
83383987
83383989
83489308
83555615
83669683
83489327
83494303
83665864
83574596
83130766
CA-84-57
05/05/84
05/05/84
05/05/84
05/05/84
05/16/84
08/01/84
08/07/84
08/09/84
08/16/84
08/22/84
08/28/84
09/20/84
10/31/84
Not known 08/21/85
4,500 gallons of
HF acid
1,700 gallons of
waste acid
5,460 gallons of
HCL
5,460 gallons of
HCL
5,460 gallons of
HCL
4,800 gallons of
HCL
4,800 gallons of
HCL
3,797 gallons of
HF acid
4,800 gallons of
waste acid
1,700 gallons of
waste acid
3,200 gallons of
HF acid
4,200 gallons of
waste acid
1,800 gallons of
corrosive liquid
5,421 gallons of
corrosive liquid
950 gallons of HCL
1,300 gallons of
formaldehyde waste
4,200 gallons
acidic waste
pH 1, normality 0.3. Reportedly neutralized in trailer 115AV and
discharged to pond 105. No records of amount of caustic added or
pre-discharge analysis.
pH 0.5, normality 0.9. Reportedly neutralized in trailer 114AV
and discharged to tank 15. No records of amount of caustic added
or pre-discharge analysis.
pH 1, normality 0.8. Disposal Location form indicates neutralized
in trailer 138V and discharged to tank 13. No records of amount of
caustic added or pre-discharge analysis except amount of Ni appar-
ently reduced from >134 to <50 ppm.
pH 0.8, normality 0.8. Disposal Location form indicates neutralized
in trailer 274V and discharged to pond 103. No records of amount
of caustic added or pre-discharge analysis.
pH 1, normality 0.8. Disposal Location form indicates neutralized
in trailer 274V and discharged to tank 11. No records of amount of
caustic added or pre-discharge analysis except amount of Ni appar-
ently reduced from >134 to <50 ppm.
pH 1, normality 0.8. Disposal Location form indicates neutralized
in trailer 756 and discharged to tank 13. No records of amount of
caustic added or pre-discharge analysis except amount of Ni appar-
ently reduced from >134 to <50 ppm.
pH 1, normality 0.8. Disposal Location form indicates neutralized
in trailer 40929 and discharged to tank 11. No records of amount
of caustic added or pre-discharge analysis, except amount of Ni
apparently reduced from >134 to <50 ppm.
pH 3, normality 0.05. Disposal Location form indicates acid neu- •
tralized in trailer 116AV and discharged to Pond 103. No records
of amount of caustic added or pre-discharge analysis.
pH 0, normality 0.4. Disposal Location form indicates acid neu-
tralized in trailer 116AV and discharged to pond 103. No records
of amounts of caustic added or pre-discharge analysis.
pH 5, normality 0.4. Disposal Location form indicates 40 gallons
of NaOH added from 215A which reduced Ni from 985 to less than 134
ppm (according to spot test) before discharge to pond 103.
pH 1, normality 0.3. Disposal Location form indicates acid neu-
tralized in trailer 116AV and discharged to pond 103. No records
of amount of caustic added or pre-disposal analysis.
pH 4, normality 0.4. Disposal Location form indicates 20 gallons
of NaOH added to the acid in trailer 115AV before discharge to pond
103. No record of any pre-discharge analysis.
pH 4.8, normality 0.3. Disposal Location form indicates 55 pounds
of Na2S2Os added to waste to reduce Cr from 910 ppm. No record of
any post-treatment/pre-discharge analysis.
pH 9, normality 0.1. Disposal Location form indicates 50 pounds of
Na2S added to waste which reduced Ni concentration from 201 to less
than 134 (according to spot test) before discharge to pond 105.
pH 0.9, normality 0.4. Disposal Location form indicates acid neu-
tralized in trailer and discharged to pond 105. No records of
amount of caustic added or any post-treatment/pre-discharge
analysis.
Formaldehyde 88 ppm. Tank Treatment Processing Record indicates
30 gallons of H202 from tank 241 was added to the W. F. Landi
trailer an hour before discharge to pond 103. A discharge sample
was retained for lab analysis by "J. W."
50% NaOH from tank 215A was added to truck trailer 142V to neu-
tralize acid before discharging to pond 103.
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86
Portions of the facility's surface impoundments have been modified or closed
without DHS being notified, as required by ISO Section I, Condition 4(c) or
the closure plan and 22 CAC, Article 26, respectively. Finally, IT has not
handled powdered waste at the facility, as required by ISO, Section II,
Condition 10 to prevent wind dispersal.
Land Disposal Restrict!'ons/Ignitable Waste
IT has improperly placed restricted waste, as identified in 22 CAC,
Article 15, and ignitable waste in surface impoundments at Vine Hill. As
shown in Table 9, IT has improperly put waste with a pH less than 2, hexa-
valent chromium, cyanide and halogenated compounds of concentrations greater
than 500 mg/L, 1,000 mg/L and 1,000 mg/L, respectively, into the impoundments.
State regulations, 22 CAC, Title 15 §66900 prohibit land disposal of waste
with concentrations greater than and pH less than these levels. Records
also show that liquid, manifested as flammable and having an HCVP of greater
than 500 ppm* was also disposed of in the surface impoundments. State and
Federal regulations; 22 CAC, Article 26 §67317 and 40 CFR 265.229, respec-
tively, do not allow such disposal unless the waste is "treated, rendered
or mixed before or immediately after placement in the impoundment so that
the resulting waste no longer meets the definition of ignitable waste and
this activity be documented". The only mixing that occurs during off-
loading is that associated with gravity discharge, and no documentation of
immediate treatment/mixing exists.
Freeboard Ponds
IT has not maintained freeboard** levels in the hazardous waste surface
impoundments at levels equal to or greater than the levels required by the
California Regional Water Quality Control Board Order No. 78-76 [Appendix A];
ISO, Section XII, Condition 1; 22 CAC 26 §67310(a) and 40 CFR 265.222(a)
and cited in the 1983 and 1985 facility inspection plans.
* Based on I2"s use of HCVP of 500 ppm hexane equivalents to corre-
late with 140° F. (60° C.) (see Waste Analysis section of this report).
** As defined in 40 CFR 260.10
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Table 9
IGNITABLE* AND RESTRICTED** WASTES
IMPROPERLY PLACED IN SURFACE IMPOUNDMENTS
Manifest
Number
84970031
84168209
84927388
84060081
84017091
84467694
83087216
83087215
83495074
84053210
83495129
83077136
* As
** As
Date
Received
09/25/85
08/21/85
08/15/85
07/17/85
04/01/85
02/04/85
02/02/84
02/02/84
05/22/84
12/11/84
06/03/84
04/12/84
identified in 22
identified and re
Waste
Description
5,000 gallons of flammable
liquid discharged to pond
103
1,600 gallons acidic liquid
discharged to pond 103
5,040 gallons of mixed sol-
vents discharged to pond 105
5,000 gallons of waste
arsenical liquid
600 gallons of flammable
liquid discharged to pond
103
2,872 gallons of hazardous
waste liquid discharged to
pond 105
5,000 gallons of mixed sol-
vents discharged to pond
102A
5,000 gallons of nixed sol-
vents discharged to pond
102A
5,040 gallons of corrosive
liquid discharged to pond
103
4,500 gallons of waste
acid discharged to pond
103
5,040 gallons of corrosive
liquid discharged to
pond 103
4,500 gallons of alkaline
cyanide to pond 103
CAC Article 26 § 673 1 7
sstricted in 22 CAC Article 15 §
Remarks
HCVP 1300 ppm (IT claims
an HCVP >500 indicates a
flashpoint <60° C.)
pH 1.6
HCVP 1200 ppm
Halogenated 0.9%
Arsenic 1000 ppm
HCVP 8000 ppm
HCVP 4200 ppm
HCVP 640 ppm
HCVP 580 ppm
pH 1.3
pH 1.4
Cr+6 670 ppm
CN~ 4700 ppm
66900
Limit
Flashpoint <60° C.
pH <2.0
(effective 01/01/84)
Flashpoint <60° C.
Halogenated organic
compounds >1000 ppm
Arsenic <500 ppm
(effective 01/01/84)
Flashpoint <60° C.
Flashpoint <60° C.
Flashpoint <60° C.
Flashpoint <60° C.
pH <2.0
pH <2.0
Cr+6 >500 ppm
(effective 01/01/84)
CN~ >1000 ppm
(effective 06/01/83)
CO
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Historically, pond freeboard requirements were established at or greater
than 2 feet by the California Regional Water Quality Control Board (CRWQCB)
Waste Discharge Requirements Order Number 78-76 dated September 19, 1978.
Although IT requested a waiver from the requirement for 2 feet of freeboard
in August 1984, it was never granted by DHS or EPA.
The IT Operations Plan, approved by DHS, required that surface impound-
ments be operated with a minimum of 2.0 feet of freeboard and that free-
board be inspected each operating day. Although Pond 103 apparently has
additional freeboard requirements, since IT reports that it is used as second-
ary containment for portions of the tank farm, the freeboard inspection
form used to report freeboard inspection results specifies 2 feet of free-
board as the limit for all surface impoundments.
Daily and weekly inspection reports from about March 5, 1983 to March 14,
1986 were reviewed to determine compliance with the freeboard requirement.
Although NEIC requested review of all records for this period, daily inspec-
tion reports were available for only 1,014 out of the 1,106 days of the
period reviewed (about 92%). Below is a summary of the results of the records
review for adequacy of freeboard. Also included is the summary of the records
which showed inadequate freeboard but did not report remedial action taken
to correct the problems.
Number of Number of Days Number of Days Freeboard
Inspection Freeboard Inadequate With No Record
Year Reports Reviewed Inadequate* of Remedial Action Taken
1983
1984
1985
1986
Total
265
319
357
71
1012
84 (32%)
106 (33%)
34 (10%)
8 (11%)
232 (23%)
62 (74%)
90 (85%)
22 (65%)
3 (38%)
177 (76%)
Reported Jess than 2 feet of freeboard
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89
Below is a summary of ponds designated on the daily inspection reports
as needing remedial action. Unfortunately, inspection records often did
not specify which pond(s) needed remedial action.
Impoundment
Designation
100
101
102A
1028
103
104
105
106
Not specific
Totals
Year
1983
3
1
8
12
8
3
13
9
52
109
1984
0
4
16
3
15
2
7
5
69
121
1985
0
1
1
N/A**
18
7
12
2
4
45
1986
1*
2
2
N/A
0
1
5
1
1
13
Total
4
8
27
15
41
13
37
17
126
288
* This impoundment had inadequate freeboard on March 11, 1986, as
observed by the NEIC inspectors. IT either did not inspect the
impoundment or record the inspection results on the daily inspec-
tion records, as required.
** Not applicable - 102B was taken out of service in late 1984.
Weekly inspection reports were available for 150 out of 156 weeks
between March 7, 1983 and March 14, 1986 (about 96%). Below is a summary
of the results of the records review for adequacy of freeboard using the
weekly inspection reports. The number of weeks when inadequate freeboard
was reported but no remedial action was recorded is also presented.
Year
1983
1984
1985
1986
Total
No. of
Inspections
41
49
51
9
150
No. Inspections
Freeboard Inadequate
18 (44%).
14 (29%)
5 (10%)
3 (33%)
40 (27%)
No. Inspections
Freeboard Inadequate
With No Indication of
Action Taken
18 (100%)
13 (93%)
4 (80%)
0 (0%)
35 (88%)
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90
Inadequate freeboard at the Vine Hill surface impoundments has been a
recurring problem. State and Federal inspections of Vine Hill, on Novem-
ber 11, 1983, February 8, 1984 and April 12 to 13, 1984, showed that at
least 2 feet of freeboard was not being maintained in one or more impound-
ments at the facility. This inadequacy problem was cited in State letters
dated October 1983, August 20, 1984 and November 30, 1984 and a February
1985 complaint.
Freeboard Markers
All of the surface impoundments at Vine Hill did not have freeboard
measurement devices during the NEIC inspection in March. IT reported that
the devices had been removed from impoundments 101 and 104 during dike
reconstruction in February. No reconstruction activity was observed during
the NEIC inspection. The freeboard markers on these two units were replaced
by March 19, 1986. However, impoundment 100 also does not have an accurate
freeboard measurement device. According to IT, a rod-type marker was pre-
viously used but the 2-foot-level mark is no longer visible. Freeboard is
currently estimated by the position of the automatic float; however, because
of the range of float movement, an accurate measurement of 2 feet of free-
board is not possible. IT had no plans to install an accurate measurement
device in this impoundment.
Protective Cover
The Vine Hill surface impoundment dikes did not all have protective
cover to minimize wind and water erosion, as required by ISO Section XII
Condition (2); 22 CAC, Article 26 § 67311 and 40 CFR 265.223. The internal
sides of the impoundments had no protective covering and many areas showed
evidence of erosion. Specifically, erosion channels were visible on the
southeast side of impoundment 102A on March 6, 1986 and on the northeast
side of impoundment 103 on March 7, 1986. Also, erosion has apparently
leveled some of the west dike of impoundment 100 leaving a gradually slop-
ing side. Because the interior walls are basically native soil, there are
also numerous areas where the sides have apparently slumped into the
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91
impoundments. However, because of the irregular shape of the impoundment
sides, it is difficult to specifically identify these areas.
An April 12 to 13, 1984 EPA inspection also reported that Vine Hill did
not have proper protective covering on facility dikes. Vine Hill was sub-
sequently cited for this in a September 27, 1984 EPA complaint. Erosion of
the dikes of surface impoundments at Vine Hill was also noted during a
November 11, 1983 DHS inspection.
Erosion of the internal sides of the impoundments is aggravated by the
fact that some liquid waste is unloaded to the unit by allowing liquids to
flow along the dike. This was observed during the initial offloading* of
waste to the southeast side of pond 102A and discharge of the centrate from
the centrifuge operation to pond 106 on March 10, 1986. The March 13, 1983
facility Operations Plan (p. 41) requires all pond discharges to be sub-
surface releases.
Surface Impoundment Modification/Closure
As discussed earlier, the Vine Hill facility has reduced the size of
at least two surface impoundments and filled one completely since November
1980. The status of these filled areas is somewhat unclear. If they are
considered to be partial unit/facility closures, then IT did not follow its
DHS-approved Closure Plan (March 14, 1983 Operations Plan) for surface
impoundment closure, 22 CAC, Title 26 §67288 and 40 CFR 265.258/264.258.
Liquids were not removed and sludges not stabilized in impoundments 102A
and 101 prior to filling in the selected portions, as required by the facil-
ity Closure Plan. Also, IT has not demonstrated to DHS that nonliquid haz-
ardous waste or the contaminated subsoil remaining** does not pose a sig-
nificant hazard, as required by 22 CAC, Title 26 §67288(b). Finally, IT
* The hose was later taken all the way to the impoundment to accomplish
subsurface discharge.
** IT could not provide any analytical data to NEIC to demonstrate that
all contaminated material had been removed from these units prior to
filling.
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92
did not remove or make all reasonable efforts to remove or decontaminate
contaminated sludges/subsoil, etc. of impoundments 101 and 102A prior to
filling in portions of these units, as required by 40 CFR 265.258, effectively
leaving the waste in place.
If not considered partial facility/unit closure, these changes must be
considered to be "substantial modifications" to the facility and thus not
allowed by Section I, Condition 4(c) of the ISO. The filling of 102B may be
allowed as IT notified CRWQCB in September 1984 that a "change of service"
was planned for this unit [Appendix I]. However, rather than being con-
verted to secondary containment as indicated in the notification, it was
filled with compacted material, covered with gravel and was in use as a
parking area during the NEIC inspection. Although CRWQCB was notified of
the change for 102B, DHS may not have been, as required by Section II, Con-
dition 6(i) of the HWFP.
In any case, IT did not comply with Section II Condition 6(1) of their
HWFP for the modifications to 101 and 102A. The HWFP requires IT to give
notice to the DHS of any planned physical alteration or additions to the
facility.
Management of Powdered Waste
IT was not disposing of powdered waste as required by ISO Section II,
Condition 10 to prevent wind dispersal. At about 8:30 a.m. on March 21,
1986, an IT employee was observed emptying small containers of hazardous
waste into the center of the north side of surface impoundment 102A. Among
the waste disposed were at least two containers of dry powdered substances
which were blown by the wind across the impoundment and possibly to the
northeast pond dike. IT indicated that these were predisposal and pre-
acceptance samples which were no longer needed and were being dumped into
102A. Precautions should be taken so that these dry waste are properly
disposed of and not blown around. IT indicated powdered waste is not nor-
mally disposed of at Vine Hill.
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93
Tanks
In general, IT was not operating its hazardous waste storage and
treatment tanks as required under Section IV, Condition 3 of the HWFP; 22
CAC, Article 25 and 40 CFR 264, Subpart J. All tanks do not have adequate
secondary containment. Vine Hill has used at least two tanks at the adja-
cent IT oil reprocessing facility for hazardous waste handling and has not
notified DHS of this activity. IT has not followed the Operations Plan or
the regulations in placement of waste incompatible with construction mate-
rial in the tanks. Required tank certifications were not submitted to DHS
in a timely manner and were incomplete and inaccurate. IT has not man-
aged reactive and ignitable waste in tanks to prevent uncontrolled reaction/
ignition. Specifics are given below.
Secondary Containment
All storage/treatment tanks at Vine Hill do not have adequate second-
ary containment, as required by 22 CAC, Article 25 §67251(b). As indicated
earlier in this report, tanks 23 and 24 do not have secondary containment
meeting the stated requirements. The area immediately surrounding these
adjacent tanks consists of porous gravel and soil. IT claims that surface
impoundment 103 and the containment area for tanks 15 through 22 are adequate
for secondary containment of these units. However, these "designated" areas
do not meet the requirements of the California regulations. Material leaked
from tanks 23 and 24 would flow over porous gravel/soil to reach these
reported containment areas. Impoundment 103 is over 100 feet from tank 24
and the containment area for tanks 15 through 22 is more than 15 feet from
tank 23. Furthermore, leaked material would have to flow northwest over
the main facility roadway to reach impoundment 103. Finally, leaked material
from tank 23 or 24 would not only flow toward these "designated" containment
areas but would also spread north over the process access roadway and west
to impoundment 100. A leak from either of these units could prevent access
to the nitrogen storage tank and other portions of the treatment facility.
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94
During a February 8, 1984 DHS inspection, it was also reported that
tanks 23 and 24 did not have secondary containment and were behind their
compliance schedule (which apparently required completion of secondary con-
tainment on these tanks by November 1983). IT has yet to provide proper
secondary containment.
In addition to tanks 23 and 24, tank 61 also does not have adequate
secondary containment. The containment system consisted of a porous.soil/
gravel/base and berm of varying heights estimated to contain less than 3%
of total tank capcity. State regulation 22 CAC, 25 §65251(b)(3) requires
secondary containment to be nonporous with a capacity sufficient to contain
a 24-hour, 25-year storm plus 10% of the volume of the tank or 100% of the
tank volume, whichever is greater.
Finally, the concrete containment areas for tanks 11 through 21 had
expansion joints and/or cracks and, thus, do not meet the requirements of 22
CAC, 25 §67251(b)(l) which requires the base to be free of cracks or gaps.
The NEIC inspection of the tank farm area on March 7, 1986 showed that there
were expansion joints in the base concrete between tanks 11 and 13, 15 and
17, and 19 and 21. Cracks in the north berm were found between tanks 15
and 18.
Tank 61/Tank 33
Vine Hill has been using tank 61 at the IT oil reprocessing facility
[Figure 3] for receipt and storage of hazardous waste without notifying DHS
(or EPA) of its use, as required by HWFP Section II, Condition 6(i). Table 10
shows use of Tank 61 as identified through review of manifests, Disposal
Location forms and Tank Treatment Processing records. However, because IT
did not always maintain a separate record .of the use of tank 61 and the
Treatment Processing records that were reviewed were incomplete, the tank
was probably used more extensively than indicated in the table. Regulatory
agencies have apparently not been notified of the use of this tank for
hazardous waste handling at Vine Hill. Neither the March 14, 1983 facility
Operations Plan or the Vine Hill RCRA Part B permit application (including
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95
Table 10
RECORD OF USE OF TANK 61 FOR HAZARDOUS WASTE STORAGE
Date
Manifest
Number
Remarks
05/17/84 83009930 2,000 gallons of flammable liquid unloaded into tank 61
06/12/84 "Too Many" 32,008 gallons from tank 61 to tank 14
06/29/84 83567616 4,500 gallons of Ni waste treated with Na2S, 4,500 gallons discharged to tank 61
on 09/30/84
07/18/84 83322275 2,520 gallons of Ni waste treated with Na2S in tank 11; 2,500 gallons discharged
to tank 61 on 07/19/84
11/05/84 83483778 880 gallons of caustic treated with H202 in tank 16 and discharged to tank 61
83643943 4,900 gallons of sulfide treated with H202 and discharged to tank 61
02/08/85 4161779 4,477 gallons of flammable waste treated with Na2S2Os in tank to reduce Cr+6
4,500 gallons discharged to tank 61 with an HCVP >10,000 ppm; IT considers
an HCVP >500 ppm to be ignitable.
02/26/85 84525159 770 gallons of Ni waste, treated with NaOH and Na2S in tank 16 to reduce Ni
levels; 6,000 gallons discharged to tank 61 with a pH of 13 making it corrosive
waste
02/28/85 84525160 1,700 gallons of Ni waste, treated with NaOH and Na2S in tank 61 to reduce Ni
levels; 2,000 gallons discharged to tank 61
03/06/85 84469955 4,777 gallons of formaldehyde waste treated with H202 in tank 16; 444 bbls*
pumped to tank 61 on 03/07/85
84085550 5,040 gallons of formaldehyde waste treated with H202 in tank 16; 444 bbls
pumped to tank 61 on 03/07/85
84085551 5,216 gallons of formaldehyde waste treated with H202 in tank 16; 444 bbls
pumped to tank 61 on 03/07/85
04/22/85 Not listed 5,000 gallons from tank 61 to tank 24 (steam stripping treatment tank)
05/13/85 84265286 4,091 gallons of formaldehyde waste treated with acid, H202 and FeS04 in tank 13;
15,000 gallons pumped to tank 61 on 05/14/85
84024700 5,000 gallons of formaldehyde waste treated with acid, H202 and FeS04 in tank 13;
15,000 gallons pumped to tank 61 on 05/14/85
CA-85-49 2,824 gallons of formaldehyde waste treated with acid, H202 and FeS04 in tank 13;
15,000 gallons pumped to tank 61 on 05/14/85
06/08/85 84062291 5,040 gallons of sulfide waste treated with H202 in tank 16; 10,080 gallons
discharged to tank 61 on 06/10/85 with a pH of 13 making it a corrosive waste
84062290 5,040 gallons of sulfide waste treated with H202 in tank 16; 10,080 gallons
discharged to tank 61 on 06/10/85 with a pH of 13 making it a corrosive waste
06/15/85 Not listed 53,055 gallons from tank 61 to tank 24
06/21/85 84104219 4,200 gallons of formaldehyde waste treated with NaOH, FeS04 and H202 in tank
13; 15,000 gallons discharged to tank 61 on 07/01/85
84357114 4,620 gallons of formaldehyde waste treated with NaOH, FeS04 and H202 in tank
13; 15,000 gallons discharged to tank 61 on 07/01/85
84163526 1,625 gallons of phenol waste treated with NaOH, FeS04 and H202 in tank 13;
15,000 gallons discharged to tank 61 on 07/01/85
06/24/85 84265368 5,200 gallons of formaldehyde waste treated with NaOH, FeS04 and H202 in tank
13; 15,000 gallons discharged to tank 61 on 07/01/85
06/27/85 84163541 88 gallons of formaldehyde waste treated with FeSO4 and H202 in tank 13;
15,000 gallons discharged to tank 61 on 07/01/85
06/25/85 84199507 5,460 gallons treated Cr+6 waste treated with NaOH in tank 14; 2,000 gallons
discharged to tank 61
84306255 4,800 gallons treated Cr+6 waste treated with NaOH in tank 14; 2,000 gallons
discharged to tank 61
06/17/85 "Several" 156,953 gallons from tank 61 to tank 24
08/01/85 00729 4,800 gallons of sulfide waste, treated with FeS04 and H202; 6,000 gallons dis-
charged to tank 61 on 08/02/85
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96
Table 10 (cont.)
RECORD OF USE OF TANK 61 FOR HAZARDOUS WASTE STORAGE
Date
08/20/85
09/19/85
10/12/85
10/14/85
10/15/85
Manifest
Number
84181771
84867223
Tank 5
rinse
84967510
84967533
"Too many"
Remarks
5,040 gallons of sulfide waste treated with NaOH; 268 bbls discharged to tank 61
8499661
4,500 gallons of H2S waste; 9,000 gallons discharged to tank 61 without any
treatment
4,500 gallons of H2S waste; 9,000 gallons discharged to tank 61 without any
treatment
3,358 gallons of formaldehyde waste treated with H202 and NaOH; 200 bbls dis-
charged to tank 61 on 10/14/85
5,156 gallons of formaldehyde waste treated with H202 and NaOH; 200 bbls dis-
charged to tank 61 on 10/14/85
4,100 bbls from tank 61 to tank 24
bbls - barrels
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97
April 1985 Completeness Check) reported the use of this tank at Vine Hill.*
In fact, the April 1985 site plan submitted with the RCRA Part B Completeness
Check showed tank 61 outside of the facility boundary. It is not known
when tank 61 was first used for hazardous waste handling; however, because
it was not reported in the Operations Plan, its use was probably initiated
sometime in late 1983 or early 1984. IT is required to notify DHS of any
physical alterations or additions to the permitted facility by HWFP
Section II, Condition 6(i).
Tank 61 does not meet the buffer zone standards for tanks used for
ignitable hazardous waste, as required by HWFP Section IV, Condition 3
(f)(2); 22 CAC, Article 25 § 67261(b) and 40 CFR 264.198(b). As indicated
by Table 9, tank 61 has been used to receive/store ignitable** waste. The
HWFP and State and Federal regulations all require that tanks used for stor-
age of ignitable material meet the National Fire Protection Association
codes for buffer zone standards (minimum distance from property lines/
buildings, etc.). Because tank 61 is within about 20 feet of the IT
property line, it does not meet the appropriate buffer zone standard and,
thus, is not allowed to be used for ignitable (or reactive) waste.
IT does not inspect or record inspections of tank 61, as required by
Section IV, Condition 3(d) of the HWFP; 22 CAC, Article 25 §67254 and 40
CFR 264.194. During IT's March 7, 1986 daily inspection, accompanied by
NEIC, the inspector never went near the portion of the facility in which
tank 61 is located, even though the inspector indicated he had a set route
and was very familiar with all aspects pf the daily inspection procedure.
Tank 61 is not mentioned in any inspection report for the last 3 years.
As indicated in the inspection section of this report, IT does not
conduct daily waste level determinations on this tank, as required by HWFP
* The RCRA Part B application also did not have complete information
on tank 23.
** Ignitability of the material could not be verified by IT acceptance
data because IT does not conduct approved ignitability testing on waste
receipts (see Waste Analysis section). However, the waste was judged
to be ignitable by evaluation of all available information.
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98
Section IV, Condition 3(d)(3). In fact, tank 61 is not even printed on the
preprinted tank status form. Tank 61 is also not represented on the tank
status board (which keeps track of waste loads/processing in tanks) in the
operations building.
Finally, the tank certification for this unit [Appendix E] inaccur-
ately describes its use as "storage of hydrocarbon materials associated
with oil reclaim processing" and its location as IT Oil, Vine Hill. More
importantly, the certification indicates the tank is not used for hazardous
waste. However, records indicate that the tank has been used to receive
and store hazardous waste not associated with oil reclamation.
Tank 33 was also used on at least one occasion to accept a portion of
a load of waste corrosive liquid (oil/waste/sulfides) on May 1, 1985 (mani-
fest number 84035578). As with tank 61, tank 33 is not included in the
Operation Plan, no certification was submitted to DHS, there is no second-
ary containment for this unit, tank inspection and waste levels are not
recorded by Vine Hill and DHS was never notified of the use of this unit.
Management of Incompatible and Reactive Waste in Tanks
IT placed waste into tanks which was incompatible with tank construc-
tion material and could potentially cause enhanced corrosion and premature
shell failure contrary to the requirements of HWFP Section IV, Condition 3
(b)(2); 22 CAC, Article 25 §67252(a) and 40 CFR 264.192(a). IT has also
not followed their March 14, 1983 Operations Plan (p. 46) which states that
acid waste with normalities greater than 1.0 are unloaded into tanks 1 and
2 for storage. Table 11 shows that acids have been placed in tanks con-
structed of mild steel with no protective coating to prevent enhanced cor-
rosion. IT indicated that such tanks are prepared with alkaline material
prior to addition of acids. However, records are not always properly com-
pleted to show this and, in at least one case, tank 24 pH was less than 7
(normality or buffer capacity unknown) when it received a load of acid of
pH 2.6 and 4.4 normality. In another example, 5,460 gallons of acidic waste
(pH 2) was unloaded to tank 12 (unlined) On October 7, 1985. There are no
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99
Table 11
SELECTED UNLOADING LOCATIONS OF ACID WASTES WITH NORMALITIES GREATER THAN 1
Manifest
Number
83174601
83562501
088-143371
83623316
84294297
83488356
83496418
84452325
84168209
Date
Received
05/19/84
06/06/84
06/07/84*
07/23/84
08/09/85
04/24/84
11/16/84
12/11/84
08/21/85
Waste
Description
1,800 gallons of
waste acid
4,800 gallons of
waste H2S04
4,800 gallons of
waste H2S04
1,500 gallons of
waste corrosive
liquid according to
manifest. 3,000
gallons of H2S04/HN03
according to Disposal
Location form
1,675 gallons of
waste corrosive
liquid
3,000 gallons of HF,
Aqua Regia, arsenic
5,040 gallons of
waste corrosive
liquid
4,620 gallons of
ZnC12 corrosive
1,600 gallons of
acid waste
pH Normality
TANKS
1 1.6
2.6 4.4
1 2
0.5 3.0
0.28 3.7
PONDS
2.1 Not recorded
2.1 1.9
4.7 1.2
1.6 2.7
Unloading
Station
Tank 11
Tank 24
Tank 14
Tank 15
Tank 13
Pond 103
Pond 105
Pond 105
Pond 103
Remarks
No record of this material in tank
11, Ni = 3,000 ppm
The Tank Treatment Processing Record
for tank 24 batch #8 (06/11/84 to
06/21/84) does not list any acid
additions or manifest 83562501
No record of this material in tank
14
No record of this material in tank
15
No record of this material in tank
13
Disposal Location form instructions
state "Dump Slowly"
Prior to replacement of tank 14 with new lined tank
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100
processing records to determine whether the tank was prepared with alkali
to protect the steel lining.
Table 11 also presents examples of waste loads of acid with normali-
ties greater than 1.0 which were not unloaded into tanks 1 and 2 as speci-
fied in the Operations Plan.
Tank Certification
IT did not meet the compliance schedule in its March 14, 1983 Opera-
tions Plan for having all of the facility's tanks certified by January 2,
1984. Also, IT is not conducting the periodic tank testing and inspections
required and recommended in the tank certifications to ensure that Section IV,
Condition 3(a)(2) of the HWFP is met. Finally, the certifications that
were submitted were incomplete and inaccurate.
Tank certifications at IT were not completed until April 1984 and sub-
mitted to DHS in May 1984. This was more than 3 months after the Operations
Plan scheduled completion date of January 2, 1984. Also, the certification
for tank 61 was not submitted to DHS with the rest of the certifications.
In fact, it was not in any DHS Vine Hill files reviewed by NEIC. Certifica-
tion dates and tank restrictions are shown in Table 12.
IT is not conducting the required/recommended tank monitoring specified
in the tank certification. Table 11 lists the various required and recom-
mended tank monitoring necessary to ensure proper tank integrity. IT could
provide no records on the semiannual ultrasonic shell thickness testing
required by the tank certificate on tanks 13 and 15 after April 3, 1985.
To remain certified for use, these required tests must be completed. Also,
IT could not provide specific records of the recommended annual thickness
testing of tank 11 and the recommended inspections of the patches on the
top of tank 18.
The tank certifications, submitted to DHS on May 1, 1984, were not
complete or totally accurate. No certification was submitted for tank 61
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Table 12
IT TANK CERTIFICATION INFORMATION*
Tank
Number
1
2
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
61*
Certification/
Test Date
04/27/84
11/27/84
04/27/84
04/27/84
04/27/84
04/03/85
Replacement tank
certified 02/08/85
04/27/84
04/03/85
Replacement tank
certified 04/03/85
04/27/84
04/27/84
04/27/84
04/27/84
04/27/84
04/27/84
Replacement tank
certified 09/04/85
04/27/84
04/27/84
08/25/83
Restrictions
Add four stiffener rings around tank circumference or restrict liquid
level to 4 feet. Modify concrete saddles to provide additional support
area
Add four stiffener rings around tank circumference or restrict liquid
level to 6 feet. Modify concrete saddles to provide additional support
area
Wall thin, annual thickness testing recommended
Monthly inspection required for patched holes in top of tank
Walls very thin, annual thickness testing required
Walls very thin, serai-annual thickness testing required
None
None
Walls very thin, semi-annual thickness testing required
None
None
Monthly inspection required for patched holes in top of tank
None
None, but top thin
None
None
Liquid level restricted to 22 feet without base anchorage
Rewelding recommended. Liquid level restricted to 27 feet (sp. grav. ,
1.2) and 32 feet (sp. grav., 1.0)
None. Improper for hazardous waste to be stored in this tank
For storage of hydrocarbon materials associated with oil reclaim
processing
Tank 61 certification was not provided to DBS.
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102
and the certification for tank 25 incorrectly states the diameter as 25
feet when the unit is actually 15 feet in diameter.*
Tank Explosions
IT did not handle ignitable and reactive waste in such a manner as to
prevent ignition and reaction, as required by Section IV, Condition 3
(f)(l)(b) of the HWFP; 22 CAC, Article 25, §67261(a) and 40 CFR 264.198(a).
On December 6, 1983, there was an explosion in tank 23 and on February 29,
1984, an explosion in tank 19. Because these incidences were investigated
by EPA, Region IX and the DHS and cited in an EPA complaint against IT
(Docket No. RCRA-09-84-0054, September 27, 1984), they will not be discussed
further here.
Incinerator
IT either has not conducted or maintained records for proper waste
analysis of material that has been incinerated in the Phase II incinerator,
as required by ISO Section XI, Condition (2), 22 CAC, Article 30 §67461 and
40 CFR 265.341. The dynamic nature of tank 25 (incinerator feed tank) pre-
cludes Vine Hill from knowing the actual waste constituents incinerated at
any given time and, thus, steady state incinerator conditions. Also, IT
does not directly monitor and record waste feed rates, as these are deter-
mined by feed tank level measurements.
Vine Hill does not maintain operating records for the small (Phase I)
fume gas incinerator as they believe it is not regulated under RCRA. Records
are maintained for the large (Phase II) liquid waste/fume gas unit and,
thus, records review was limited to this large unit.
Vine Hill does not have records showing analysis results for all waste
incinerated for all of the constituents (heating valve, sulfur, halogenated
As reported in the facility RCRA Part B permit application and as
estimated visually during the NEIC inspection.
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103
compounds, lead and mercury) required by CAC, Title 22, Article 30, §67461;
40 CFR 265.341, and the facility Interim Status Document, Section XI,
Condition (2). Review of waste analysis results provided by IT for March
1983 through March 1986, showed that, while heating valve and sulfur content
were normally analyzed for, the other constituents were not always determined
as required. A summary of the results of this record review is shown in
Table 13.
As the table shows, records for only six waste samples (taken in June
and July) were provided for 1983 even though DHS reported that the inciner-
ator was operating in mid-February 1983. IT could provide no Incinerator
Logs prior to 1984 to verify incinerator activities in 1983, even though
these documents were requested by NEIC.
IT does not have records to show that all of the waste which was even-
tually incinerated has been analyzed or the results recorded as required.
Unfortunately, one cannot identify specific cases where a particular waste
placed in tank 22 was eventually pumped to tank 25 and incinerated because
IT does not maintain the proper records to track all waste to incineration
(see Waste Tracking discussion). However, review and comparison of the
Incinerator Logs, which show when tank 25 was loaded, and records of waste
analysis indicates that not all waste which has been incinerated has been
sampled and analyzed as required. For instance, the last record of waste
analysis for incinerator feed for 1984 was dated October 30. The next record
of analysis is dated February 6, 1985. Incinerator Logs show that more
than 40,000 gallons of waste was pumped to tank 25 between October 30, 1984
and February 6, 1985. Although it is unclear which tank* was actually sampled
and analyzed on October 30, the maximum volume of waste represented by
that sample is about 18,000 gallons [the capacity of tank 22, the largest
Although most incinerator feed comes to tank 25 from tank 22, IT
apparently also used tanks 26 and 27, in 1984 and 1985. Thus, the
waste sample could come from any of the four tanks associated with the
incinerator.
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Table 13
SUMMARY OF INCINERATOR WASTE FEED ANALYSIS RECORDS REVIEW
Year
. No. Analysis
Records for Year
No. Records Reporting Results for Listed Parameters (% of total)
Heating Value
Floriole and/or
Sulfur Halogenated Chloride
Lead
Mercury
1983
1984
1985
1986
6
38
29
2
6 (100%)
37 (97%)
22 (76%)
2 (100%)
0 (0%)
38 (100%)
22 (76%)
2 (100%)
0 (0%)
0 (0%)
6 (21%)
0 (0%)
6*
4 (11%)
19 (66%)
2 (100%)
6 (100%)
3 (8%)
22 (76%)
2 (100%)
0 (0%)
2 (5%)
17 (59%)
2 (100%)
Bromide only
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105
of the four possible tanks sampled (Table 5)]. Thus, there were at least
22,000 gallons of waste incinerated in this time period without any analyses
being conducted/recorded.
IT records show most of the waste samples for incinerator feed analysis
were taken from tank 22, the feed tank to tank 25. Waste is pumped from
tank 22 to tank 25 in batches of from less than 600 gallons to greater than
3,500 gallons (depending on available capacity in tank 25 when loading
begins). Because the waste analyzed is from tank 22 and not tank 25 (the
incinerator feed tank), IT does not know the identity of the actual constit-
uents in the waste being incinerated after mixing in T-25.
Because of the dynamic nature of tanks 22 and 25, the only certain way
to properly identify the required waste constituents in the incinerator
feed would be to obtain and analyze a representative sample from tank 25
each time it was loaded. Below is a comparison, by year, of the number of
waste analyses conducted and number of times tank 25 received waste.
Date*
1984
1985
1986**
Number of
Analysis
Records
38
29
2
Number
of Tank 25
Loadings
71
69
5
* 1983 is not shown here because IT
could provide no records of
incinerator/tanfc 25 activity for
1983.
** Through January 1986
As indicated, IT does not have records specifically showing waste
characteristics for each load pumped to tank 25 for eventual incineration.
Based on incinerator records, the average incinerator waste feed is
estimated to be 35 to 40 gallons per hour, well below the 250-gallon per
hour capacity reported in the April 4, 1985 RCRA Part A permit application.
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106
Liquid waste has been incinerated at temperatures ranging from less than
1350° F. to over 1850° F. It is not unusual for incinerator temperatures
to rise or fall by more than 100° F. during a 1-hour period.
Centrifuge
IT, Vine Hill is not following its March 1985 Centrifuge Operations
Plan in operating the onsite centrifuge, as required by HWFP Section II,
Condition 5. Also, IT did not notify DHS of the use of the centrifuge until
well after it had begun processing waste, as required by HWFP Section II,
Condition 6(i). Finally, the waste shipping manifests used to transport
centrifuge solids to the nearby Panoche (Benicia) landfill do not always
accurately describe the waste source, as required by 22 CAC, Article 6.
There was only one record (March 25, 1985) of the results of the sludge
sampling and analysis program required prior to material processing, as
stated in the Operations Plan (page 8-2). This analysis must include "pre-
disposal" analysis performed on a representative sample of the material to
be processed which is to include analysis for HCVP, cyanide, phenol, heavy
metals, hydrogen sulfide, pH, PCBs and volumetric solids content. If the
Operations Plan had been followed, as required, a record of the above
described analyses should have been prepared and maintained by Vine Hill,
at least each time the centrifuge began processing sludge from a different
impoundment. However, as indicated previously, only one record of any
analyses could be provided and, as shown below, the centrifuge operation
has been routinely switched between impoundments 105 and 106 (based on
review of records November 21 through December 18, 1985).
Date
(1985)
11/20
11/22
12/09
12/18
Pond Number
of Centrifuge
Operation
105
106
105
106
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107
Also, the project sample log (actually called Centrifuge Field Analysis
Log)* is not filled out completely, or daily, as required by the Operations
Plan (p. 8-2). The Operations Plan states that information required on the
log will be recorded at intervals as determined prior to sludge processing.
The log indicates that this interval is daily and that samples are to be
run one per hour during normal operating conditions. NEIC reviewed the
records provided by IT regarding centrifuge operations from the period of
time from October 7, 1985 to January 29, 1986. Of the 23 days that the
centrifuge was operating, there were no field analysis logs for 6 days (26%)
and 16 of the 17 logs that were present were incomplete. These were most
often inadequate because polymer flow rate and percent cake solids were not
recorded. Furthermore, IT could produce no centrifuge operations records
for the time period before September 10, 1984 even though DHS reported that
the unit was present and operating during a February 1984 inspection.
IT did not properly notify DHS of the centrifuge operation as required
by Section II Condition 6(i) of the HWFP. During a February 24, 1984 facil-
ity inspection of Vine Hill, DHS noted that the centrifuge was operating
and they had not been properly notified. IT did not submit an Operations
Plan for the centrifuge operation until September 17, 1984 and the plan
(after being amended) was not approved by DHS until March 1985. The Vine
Hill HWFP [Section II, Condition 6(i)] requires IT to notify DHS "as soon
as possible, of any planned physical alterations or additions to the permitted
facility". Vine Hill was cited for noncompliance with the HWFP for use of
the centrifuge in a February 21, 1985 DHS complaint (No. 269037).
Finally, the Operations Plan submitted to DHS inaccurately reports
that "the centrifuge drive motor is a fixed speed 1800 RPM motor". In fact,
the centrifuge has a variable speed unit which can go as high as 2500 rpms.
The unit was operating at 1437 rpms according to the meter during the NEIC
inspection on March 7, 1986.
The sample log shown in the Operations Plan is not actually used.
Information is recorded on what IT calls the Centrifuge Field Analysis
Log.
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108
Prior Release Document
The Prior Release Document submitted to EPA, Region IX pursuant to
Section 3004(u) of RCRA and the Part B permitting process, is incomplete.
The document does not identify all of the currently active and inactive
waste handling units of Vine Hill that were not included in the RCRA Part B
application, as required.
The submittal does not include tanks 61 and 23, two tanks currently
used to store hazardous waste but not included in the RCRA Part B applica-
tion. The document does not identify three inactive tanks: tank 3 (acid
storage), tank 4 and tank 31 (cyanide treatment) which were used but are
currently inactive (and not addressed in the RCRA Part B permit application).
The document also does not discuss surface impoundment 102B and the arm of
impoundment 101 (known as Charlie's Alley), which was filled in 1981 and is
not identified on current facility maps/diagrams and not addressed in the
Part B application. It is important that these units, as well as the newly
acquired "Acme Ponds", be addressed so that the Vine Hill facility can be
properly and completely evaluated by Region IX as part of the RCRA Part B
permitting process.
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APPENDICES
A CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD ORDER NO. 78-76,
SAN FRANCISCO BAY REGION
B VINE HILL INTERIM STATUS DOCUMENT
C VINE HILL HAZARDOUS WASTE FACILITY PERMIT (EFFECTIVE SEPTEMBER 26,
1983)
D A SUMMARY DESCRIPTION OF THE OPERATING PROCEDURES AND DESIGN
FACTORS TO PROTECT IGNITABLE AND REACTIVE WASTE - FEBRUARY 6,
1986 IT SUBMITTAL TO EPA REGION IX IN RESPONSE TO EPA COMPLAINT
E IT MEMO REGARDING WASTE TREATMENT IN TANK TRUCKS
F TANK 61 CERTIFICATION
G FIGURE FROM FEBRUARY 6, 1985 IT SUBMITTAL TO EPA REGARDING TRANSFER
OF WASTE FROM VINE HILL TO BAKER
H WASTE TRACKING AT IT, VINE HILL
I SEPTEMBER 10, 1984 LETTER FROM IT TO CRWQCB NOTIFYING OF THE CHANGE
OF SERVICE OF IMPOUNDMENT 102B
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APPENDIX A
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
ORDER NO. 78-76, SAN FRANCISCO BAY REGION
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A-l
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
SAN FRANCISCO BAY REGION
•
ORDER NO. 78-76
WASTE DISCHARGE REQUIREMENTS FOR:
IT OIL CORPORATION AND
IT ENVIRONMENTAL CORPORATION
VINE HILL AND BAKER
CLASS I DISPOSAL SITES
MARTINEZ, CONTRA COSTA COUNTY
The California Regional Water Quality Control Board, San Francisco Bay Region,
(hereinafter called the Board)-finds that: A
• 4
ft
1. The Regional Board adopted Waste Discharge Requirements Order
No. 71-56, on July 22, 1971 on, Industrial Tank, Inc. and its
subsidiary San Pablo Oil Recovery Company (now known as IT
Environmental Corporation and IT Oil Corporation respectively)
for their Class I Disposal Site near Vine Hill in Contra Costa
County. On August 26, 1971, the Board adopted requirements on
Industrial Tank, Inc. for its Class I disposal site known as
the Baker site, also in Contra Costa County. Both IT Oil
Corporation and IT Environmental Corporation will hereinafter
be jointly known as the discharger, and this Order applies to
both the Vine Hill and .Baker sites.
2. The discharger currently disposes Group 1 wastes on two Class-I
sites which it owns. The Vine Hill and Baker sites are located
approximately one quarter mile apart in low lieing area east of
the City of Martinez in Contra Costa County. The Vine Hill site
is located east of Interstate 680 at the end of Arthur Road.
The Baker site is located directly south of the confluence of
Pacheco and Walnut Creek Flood Control Channels. The locations
of the sites are shown on Attachment A, which is incorporated
herein and made a part of this Order.
3. The Vine Hill site covers approximately 21 acres on which the
industrial waste treatment facilities, several retention ponds
and the IT Oil Corporation facilities are located. The site is
underlain by a considerable thickness of impermeable siity clay
deposits with discontinuous peat and sand lenses. Limited amounts
of very low quality groundwater exists within three to five feet
of the ground surface. There is no known useable groundwater
immediately under the site.
-1-
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A-2
4. The Baker site is a 130 acre site which currently has a total
of five ponds used for waste evaporation, biodegradation of
industrial solid wastes, and contaminated storm runoff storage
as shown on Attachment A. The site is underlain by one to
four feet of baymud fill (siity, clayey sands) underlain by
several feet of low permeability silty and sandy clays with
thin organic peat lenses. Poor quality groundwater exists at
shallow depths. No known useable groundwater exists imnediately
below site.
5. The discharger handles approximately 68 million gallons per year
of liquid wastes received mainly from petroleum refineries, and
steel, chemical and semi-conductor industries. All liquid wastes
are received at the Vine Hill site where they are subjected to
one or more treatment process such as neutralization, solvent
recovery, oil recovery, cynide destruction, denitrification or
incineration. Treated wastes are pumped to the Baker site ponds
in the form of dilute aqueous solutions for solar evaporation, or
treated industrial wastewater solids for biodegradation.
6. These landfill sites, subsequent to modifications required to comply
with this Order, will meet the criteria contained in the California
Administrative Code, Title 23, Chapter 3, Subchapter 15, for
classification as a Class I disposal site suitable to receive
Group 1, Group 2, and Group 3 wastes.
7. The beneficial uses of Walnut Creek and Pacheco Creek which
could be affected by this disposal site arc:
a) Recreation
b) Fish migration habitat
c) Habitat and resting area for waterfoul and migratory birds
d) Industrial Water supply
e) Esthetic enjoyment
f) Navigation
8. Land within 1000 feet of these sites is used for residences,
pasture, refuse disposal, industrial and transportation uses.
9. The Board adopted a Water Quality Control Plan for the San Francisco
Bay Basin, in April 1975, and this Order implements the water quality
objectives stated in that plan.
10. This order authorizes the continued operation of two privately
owned Class I solid waste disposal sites. The Order will not have
a significant effect on the environment pursuant to the California
Environmental Quality Control Act and is exempt as provided in
Section 15101, Title 14, California Administrative Code.
11. The Board has notified the discharger and interested agencies
and persons of its intent to prescribe waste discharge require-
ments for the discharge and has provided them with an opportunity
for a public hearing and an opportunity to submit .their
written views and recommendations.
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A-3
12. The Board, in a public meeting heard and considered all comments
pertaining to the discharge.
IT IS HEREBY ORDERED, that IT Environmental Corporation and IT Oil Cor-
poration and IT Oil Corporation or any other persons that shall own the
land or operate this disposal site shall comply with the following for
the Vine Hill and Baker Sites:
A. Prohibition
The discharge of any waste or polluted runoff from the disposal
areas to the surface waters or groundwaters of the State is prohibited.
B. Waste Disposal Specifications A
»
1. The treatment or disposal of wastes shall not create a nuisance as
defined in Section 13050 (m) of the California Water Code.
2. Waste materials shall be confined to the disposal sites as shown
on Attachment A at all times and shall not be placed in any
position where they can be carried from the disposal sites and
discharged into waters of the State.
3. A minimum of two feet of freeboard shall be maintained in all
ponds throughout the year.
4. Any water which has contacted waste material shall be contained
in the designated disposal sites as shown on Attachment A, unless
other disposition is approved by the Board.
5. The discharger shall remove and relocate any wastes which are
discharged at this site in violation of these requirements.
C. Leachate and Drainage Specifications
1. The disposal area shall be protected at all times from any
washout or erosion of wastes or from any threat of inundation.
2. Leachate or seepage volumes contained by liquid control barriers
or subdrains shall be maintained below a volume equal to 75 percent
of the total storage capacity of the barrier or subdrain.
3. The exterior faces of disposal area barriers shall be protected
from erosion or from actions of rodents to maintain the effective-
ness of the barrier.
4. Vertical or lateral movement of wastes or leachate from the
disposal areas as shown on Attachment A shall be prevented by an
impermeable dike or barrier surrounding these areas. This
dike shall be keyed into impermeable natural substrata and
shall provide a minimum of five feet of material with a per-
meability not to exceed 1 x 10 cm/sec or equivalent.
-3-
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A-4 . . ;
5. The following group 1 wastes shall not be disposed at the
disposal areas except upon approval of the Regional Board's
Executive Officer.
a. Pesticides, Herbicides or defoliants
b. Poly-chlorinated-biphenols
6. Useablc groundwaters shall not be degraded as a result of
disposal operation.
D. Provisions
1. The discharger shall comply with all sections of this Order
except C.I and C.4,. immediately upon its adoption. A
«
•
2. The discharger shall submit a report by December I, 1978 which
presents engineering data and analysis assuring that the existing
facilities are meeting or are capable of meeting specifications
C.I and C.4. of compliance. If compliance is not currently being
achieved, plans shall be submitted by January 30, 1979 for
achieving compliance. In any case, specifications C.I, and C.4
shall be complied with no later than November 1, 1979. All reports
and plans described above shall be prepared by a registered civil
engineer or a certified engineer geologist.
3. The discharger shall file with this Regional Board a report
describing the maximum capacity of the two disposal sites for
handling wastes, based on the solar evaporation rate, including
the treatment of the group 1 wastes. This report shall be
submitted no later than December 1, 1978.
4. The discharger shall file a written report within 90 days after
the total quantity of wastes discharged at this site equals
75 percent of the reported capacity of the site. The report
shall contain a schedule for studies, design and other steps
needed to provide additional capacity, or the total quantity dis-
charged shall be limited to the reported capacity.
5. The discharger shall maintain a copy of the Order at the sites or
office so as to be available at all times to site operating
personnel.
6. The discharger shall file with this Board a report of any material
change or proposed change in the character, location or quantity of
this waste discharge. For the purpose of these requirements, this
includes any proposed change in the boundaries, contours or
ownership of the disposal areas.
7. The discharger shall file with the Board technical reports on
self-monitoring work performed according to the detailed specifications
contained in the existing Monitoring and Reporting Program-which has
been directed by the Executive Officer.
-4-
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A-5
8. In the event of any change tn control or ownership of land or
waste discharge facilities presently owned or controlled by
the discharger, the discharger shall notify the succeeding
owner or operator of the existence of this Order by a letter, a
copy of which shall be forwarded to this Board.
9. This Board considers the property owner to have a continuing
responsibility for correcting any problem which may arise in the
future as a result of this waste discharge during subsequent use
of the land for other purposes.
10. In the event of any incident whereby the discharger is unable to
comply with any of the conditions of this Order, the discharger
shall notify the Executive Officer by telephone as soon as he or
his agents have knowledge of the incident. A written report shall
be filed within one.week of the telephone notification. TJie written
report shall include pertinent information explaining reasons for
the non-compliance and shall indicate what steps were taken to
correct the problem and the dates thereof, and what steps are be-
ing taken to prevent the problem from recurring.
11. Six (6) months prior to discontinuing the use of either site for
waste disposal the discharger shall submit a technical report to
the Board describing the methods and controls to be used to assure
protection of the quality of surface (and groundwaters) of the
area during final operations and with any proposed subsequent use
of the land. This report shall be prepared by or under the supervision
a registered engineer or a certified engineering geologist. The
method used to close the site and maintain protection of the quality
of surface (and groundwater) shall comply with waste discharge
requirements established by the regional board.
12. The discharger shall permit the Regional Board:
(a) Entry upon premises on which waste ponds are located or in
which any required records are kept,
(b) Access to copy any records required to be kept under terms
and conditions of this order,
(c) Inspection of monitoring equipment or records, and
(d) Sampling of any discharge.
13. This Board's Waste Discharge Requirements Resolution #417, Order
Nos. 71-56, 71-60 and 71-59 are_hereby rescinded.
I Fred H. Dierker, Executive Officer, do hereby certify that the foregoing is a
full, true, and correct copy of an Order adopted by the California Regional
Water Quality Control Board, San Francisco Bay Region, on September 19, 1978.
FRED H. DIERKER
Executive Officer
Attachment
Map A
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PROPERTY
BOUNDARY
VINE Hi. SITE *
KVAVOKAVION i-STORACE-
N PONDS
STATK OF CALirOMNIA
REGIONAL WATCH QUALITY CONTROL ROARS
SAN FRANCISCO BAY KKCMON
I 1
OIL
LOCATION OF CLASS I DISPOSAL SITE
MARTINEZ, CONTRA COSTA COUNTY
ATTACHMENT A ORDER NO: 78-77
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APPENDIX B
VINE HILL INTERIM STATUS DOCUMENT
-------
^o/fc/fx-y^-^'
L-i! OF HEALTH SWVICES
• Ml1
Facility: IT Corporation-Vine Hill
Facility
East End of Arthur Road
Contra Costa County
Martinez, CA 94553
Operator: IT Corporation
336 West Anaheim Street
Wilmington, CA 90744
vr
INTERIM STATUS DOCUMENT
Number: CAD 000094771
Effective Date: April 6, 1981
Pursuant to Section 25200.5 of the California Health and Safety Code,
this Interim Status Document is hereby granted to IT Corporation subject to
the conditions set forth in Attachment A which by this reference is
incorporated herein.
Harvey {/Collins, Ph.D., Chief
Environmental Health Branch
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B-2
ATTACHMENT A
Interim Status Document
IT Corporation-Vine Hill Facility
East End of Arthur Road
Contra Costa County
Martinez, CA 94553
GENERAL CONDITIONS
*
1. Identification and general responsibilities of operator.
IT Corporation, hereinafter called the operator and/or owner, shall
comply with the provisions of the California Health and Safety
Code, including Chapter 6.5 of Division 20, and with the Minimum
Standards for Management of Hazardous and Extremely Hazardous
Wastes (Chapter. 30, Division 4, Title 22 of the California Adminis-
trative Code). The following requirements set forth in Chapter 30,
Division 4, Title 22, California Administrative • Code, should be
particularly noted:
(a) The owner or operator shall ensure that the operation of the
facility will not imperil public health and safety, wildlife,
domestic livestock, or the environment.
(b) The owner or operator shall allow the California State Depart-
ment of Health Services or the local health agency to inspect
the facility, take samples of wastes, and inspect pertinent
records.
(c) The owner or operator shall maintain the qualified personnel and
the equipment necessary to provide for the safe operation of the
facility.
(d) The owner or operator shall notify the California State Depart-
ment of Health Services of a proposed -change in ownership of the
facility, in the method of operation of the facility, or of pro-
posed closure of the facility 30 days prior to such event.
(e) The operator shall report to the California State Department of
Health Services, within 24 hours after occurrence, all accidents
involving hazardous wastes which resulted in, or could have
resulted in, a hazard to public health and safety, wildlife,
domestic livestock, or to the environment.
2. Records.
The owner or operator shall file this Interim Status Document at
the facility and at his place of business.
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B-3
J. Operation plan.
Unless be has already done so, the owner or operator shall submit to
the California State Department of Health Services within six months
of the effective date of this document, an operation plan in accord-
ance with Section 66376, Title 22 of the California Administrative
Code.
4. Prohibited acts.
The owner or operator shall not do any of the following acts:
(a) Treat, store, or dispose of hazardous wastes which are not
identified.
(b) Employ processes not described in the application.
(c) Hake substantial modifications or additions to the facility.
5. Limitation.
The owner or operator shall comply with the conditions of this docu-
ment and with any new or modified conditions which the California
State Department of Health Services deems necessary to protect public
health or the environment. A new interim status condition or a
modification of an existing interim status condition shall become
effective on the date that written notice of such change is received
by the owner or operator.
NOTE: Unless explicitly stated otherwise, all cross references to items in
this Interim Status Document shall refer only to items occurring
within the same Part. All Parts are identified by Roman numerals.
The items set forth in each Part shall apply to the owner, operator,
and/or facility in addition to the items .set forth in any preceding
and/or following Part of this document.
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B-4
SPECIAL CONDITIONS
1. Storage of wastes.
(a) Hazardous waste shall not be stored at the facility for longer
than one year without written approval from the California
State Department of Health Services.
(b) If a hazardous waste is stored at the facility longer than one
year, the owner or operator shall pay to the California State
Department of Health Services a fee, as if the waste had been
disposed of on land, in accordance with Article 8, Chapter 30,
Division 4, Title 22 of the California Administrative Code.
The fee shall be paid in the 13th month of storage.
(c) Hazardous waste shall be stored in a secure enclosure such as
a building, room or fenced area, which shall prevent unauthor-
ized persons from gaining access to the waste and in a manner
that will prevent spills. A caution sign shall be posted and
visible from any direction of access or view of hazardous waste
stored in such enclosure. Wording of caution signs shall be
in English, "Caution-Hazardous Waste Storage Area-Unauthorized
Persons Keep Out", and Spanish, "Cuidado! Zona de Residues
Peligrosos. Prohibida la Entrada a Personas No Autorizadas".
(d) Each hazardous waste storage area shall have a continuous base
that is impervious to the waste to be stored and shall be
designed and constructed so that any surface water runoff or
spills can be contained.
2. Storage in tanks.
(a) Each hazardous waste storage tank situated above ground shall
have a spill confinement structure (e.g., dike or trough) capa-
ble of holding the entire contents of the tank plus sufficient
freeboard.
(b) Hazardous waste storage tanks shall be constructed of materials
which are compatible with the wastes to be contained or shall
be protected by liners which are compatible with those wastes.
(c) Prior to use, hazardous waste storage tanks and their appurte-
nances shall be certified by an engineer registered in California
to be structurally sound and of adequate construction for the
intended use.
(d) Each hazardous waste storage tank and storage area shall be
individually marked with the internationally recognized hazard
-------
identification system placards developed by the National Fiit-
Prevention Association (NFPA).
(e) Valves on hazardous waste storage tanks shall be kept locked
when the facility is unattended.
3. Storage in ponds.
(a) The following hazardous wastes shall not be stored in open storage
ponds:
(1) Extremely hazardous wastes as defined in Sections 66064 and
66685, Title 22, California Administrative Code, unless
specifically approved by a written permit from the California
State Department of Health Services;
(2) Flammable wastes as defined in Section 66072, Title 22,
California Administrative Code; and
(3) Wastes such as organic solvents or sludges containing vola-
tile, toxic substances in excess of 10 percent by weight.
•(b) Hazardous sludges, concentrates, and residues removed from a
storage pond for subsequent disposal shall be properly handled,
transported, and disposed of as hazardous wastes.
(c) Physical barriers or other devices shall be used as necessary
during waterfowl migration periods to deter migratory waterfowl
from using storage ponds.
4. Storage in containers.
(a) Containers used for storing hazardous waste shall be in a condi-
tion such that the containers can be safely transported, handled
or moved.
(b) Areas used for storing containers of hazardous waste shall be
widely separated, or physical•barriers shall be provided to
ensure that commingling of incompatible hazardous wastes cannot
occur if a container on one pad ruptures.
(c) A label shall be maintained on all containers in which hazardous
wastes are stored for 90 days or more and records for the storage
of all hazardous wastes shall be maintained pursuant to Section
66545, Title 22 of the California Administrative Code. Labels
shall include the following information:
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B-6
(1) Composition and physical state of the waste;
(2) Special safety recommendations and precautions for handling
the waste;
(3) Statement or statements which call attention to the partic-
ular hazardous properties of the waste;
(4) Amount of waste and name and address of the person produc-
ing the waste; and
(5) Date of acceptance at the storage facility.
(d) Empty containers contaminated with hazardous materials shall be
stored, handled, processed and disposed of as hazardous wastes.
5. Transfer of wastes.
(a) Hazardous wastes shall not be permanently disposed of at the
facility.
(b) All equipment, pipes, and lines used at the facility to handle,
transfer, pump, or store hazardous wastes shall be maintained
in a manner that prevents the leaking and spilling of hazardous
wastes.
6. Treatment of wastes.
If incompatible wastes are mixed for purposes of treatment, the owner
or operator shall control the mixing process in a manner which pre-
vents hazards to health and safety of the public or employees or haz-
ards to domestic livestock or wildlife.
7. Incineration of wastes.
The facility shall be operated to minimize the release of all harm-
ful and obnoxious gases. The facility shall comply with all appli-
cable air emission and air quality standards and requirements.
8. Disposal in ponds.
i
(a) The following hazardous wastes shall not be deposited in open
disposal ponds:
(1) Extremely hazardous wastes as defined in Sections 66064
and 66685, Title 22, California Administrative Code, unless
specifically approved by a written permit from the California
State Department of Health Services;
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B-7
6
(2) Flammable wastes and water-reactive wastes as defined in
Sections 66072 and 66236, respectively, Title 22 of the
California Administrative Code; and
(3) Wastes such as organic solvents or sludges containing vola-
tile, toxic substances in excess of 10 percent by weight.
(b) Hazardous sludges, concentrates, and residues removed from a
pond for disposal elsewhere shall be properly handled, trans-
ported, and disposed of as hazardous wastes.
(c) Physical barriers or other devices shall be used during water-
fowl migration periods to deter migratory waterfowl from using
evaporation ponds.
9. Recycling.
(a) The mixing or blending of potentially incompatible materials
and wastes for purposes of recovering resources, neutralizing
wastes, or detoxifying wastes shall be carried out under con-
trolled conditions to ensure that violent reactions, extreme
heat, or fire do not occur and that toxic or flammable gases
and vapors are not discharged into the atmosphere.
^
(b) If requested by the California State Department of Health Services
in accordance with Article 12, Chapter 30, Division 4, Title 22,
California Administrative Code, the owner or operator shall sub-
mit a written statement justifying having not recycled a waste
which the Department has determined to be recyclable.
10. Management of powdered wastes.
To prevent hazardous waste from being blown by the wind, hazardous
waste in the form of powder, dust or a fine solid shall be handled,
treated, stored and disposed of in covered containers or, if the
waste is not water reactive, shall be wetted as a slurry.
11. Management of asbestos wastes.
Asbestos-containing wastes shall be disposed of in accordance with
the following instructions:
(a) Wastes received in sealed, nonreturnable containers shall be
handled, disposed of, and covered without opening, breaking, or
rupturing the containers.
(b) Wetted wastes received in bulk shall not be allowed to dry to
such a state that airborne asbestos fibers would result.
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B-8
(c) Dry wastes received in bulk shall be thoroughly wetted to prevent
the blowing of asbestos fibers.
(d) All asbestos-containing wastes shall be covered with at least six
inches of compacted soil or nonhazardous solid waste within 24
hours after receipt.
12. Wastes prohibited.
Hazardous wastes described below shall not be handled at the facility:
(a) Extremely hazardous wastes as defined in Sections 66064 and 66685,
_. .Title 22, California Administrative Code, unless specifically
approved by a written permit from the California State Depart-
ment of Health Services.
(b) Flammable wastes and water-reactive wastes as defined in Sections
66072 and 66236, respectively, Title 22 of the California Admin-
istrative Code.
(c) Burning wastes.
**
(d) Forbidden and Class A explosives as defined in Sections 173.51
and 173.53, Title 49, Code of Federal Regulations.
13. Management of incompatible wastes.
Each of the following categories of incompatible hazardous wastes
shall be adequately separated during all handling, storage, and dis-
posal operations:
(a) Alkalies and cyanides.
*
(b) Acids.
(c) Toxic wastes, pesticides and flammable vastes.
(d) Strong oxidizers.
14. Management of pesticide wastes.
The operator shall store, handle, treat and dispose of emptied pesti-
cide containers in accordance with the requirements of Chapter 30,
Division 4, Title 22 of the California Administrative Code, and Arti-
cle 10, Group 3, Subchapter 3, Chapter 4, Title 3 of the California
Administrative Code.
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B-9
8
15. Nonpotable water supply.
If an onsite water supply is used for controlling dust and fires.
cleaning equipment or other purposes, and does not meet all h^.ilih
standards for drinking water, all faucets or taps connected to that
supply shall be clearly labeled in English, "Polluted-Not Safe For
Hunan Use", and Spanish, "Peligro, Contamination, No Usar".
16. Public water supply.
If a public water supply is used at the facility, the service con-
nection shall be protected from contamination as specified in Sec-
tion 7604, Title 17 of the California Administrative Code.
17. Fencing.
The perimeter of the hazardous waste area of tha facility shall be
secured by a well-maintained fence, capable of preventing the intru-
sion of livestock and of discouraging entry by unauthorized persons.
If the entire facility is appropriately fenced, if the general pub-
lic does not have access to the hazardous waste area, and if the haz-
ardous waste area is posted with warning signs as described elsewhere
in this document, no additional fence shall be required around the
hazardous area unless the absence of such a fence could result in 3
hazard to health, safety, or the environment.
fe
18. Operation at night.
When the facility is operated during hours of darkness, the operator
shall provide sufficient lighting to ensure safe, effective management
of hazardous wastes.
19. Warning signs.
Signs indicating that the facility, or the hazardous waste area of
the facility, contains hazardous waste shall be placed on the perime-
ter fence at locations where it is anticipated that hunters and other
trespassers may enter the facility such as at trails, major drainages,
and ridges. Wording of the signs shall be in English, "Caution-
Hazardous Waste Area-Unauthorized Persons Keep Out", and Spanish,
"Cuidado! Zona de Residues Peligrosos. Prohibida la Entrada a Per-
sonas No Autorizadas".
20. Telephone or radio communications.
A telephone or radio for summoning aid in the event of an emergency
shall be in workable condition and available for immediate use by
personnel working in the hazardous waste area of the facility.
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B-10
21. Safety showers.
The owner or operator shall provide to personnel working in the haz-
ardous waste area of the facility adequate numbers of safety showers.
The safety showers shall be in workable condition and available fur
immediate use.
22. Eyewashes.
The owner or operator shall provide to personnel working in the
hazardous waste area of the facility adequate numbers of eyewashes.
The eyewashes shall be in workable condition and available for
immediate use.
23. First-aid kit.
The owner or operator shall provide to personnel working in the
hazardous waste area of the facility adequate numbers of industrial-
type first-aid kits. The kits shall be maintained and available for
immediate use.
24. Protective clothing.
The owner or operator shall provide to personnel working in the
hazardous waste area of the facility adequate numbers of the fol-
lowing National Institute of Occupational Safety and Health (NIOSH)
approved equipment if appropriate:
(a) Protective head gear and face masks.
(b) Chemically resistant apparel and gloves.
*
(c) Self-contained breathing apparatus and respirators with the
approved cartridges.
25. Warning alarm system.
If at any time there is a sole employee on the premises, the employee
shall have immediate access to an alarm or other communication device
capable of summoning external emergency assistance.
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III. SAFEtY, EQUIPMENT, AND EMERGENCY RESPONSE
|. Identification number.
The facility owner or operator shall have an identification number
issued by the U.S. Environmental Protection Agency (EPA).
2. Notices.
(a) If the owner or operator has arranged to receive hazardous
waste from a foreign source, he shall notify the California
State Department of Health Services in writing at least four
weeks in advance of the date that the waste is expected to ar-
rive at the facility. Notice of subsequent shipments of the
same waste from the same foreign source is not required.
(b) Before transferring ownership or operation of the facility
during its operating life or during the post-closure care
period, the owner or operator shall notify the new owner or
operator in writing of the conditions of this document.
3. Analysis of waste.
(a) (1) Before the owner or operator treats, stores, or disposes
of a particular type of hazardous waste for the first time,
he shall obtain a detailed chemical and physical analysis
of a representative sample of the waste. At a minimum,
this analysis shall contain all the information which must
be known to treat, store, or disposa of the waste in
accordance with the conditions of this document.
(2) The analysis may include data developed for other purposes,
and existing published or documented data on the hazardous
waste or on waste generated from similar processes.
(3) The analysis shall be repeated as necessary to ensure that
It Is accurate and up-to-date. At a minimum, the analysis
must be repeated when the owner or operator is notified,
or has reason to believe, that the process or operation
generating the hazardous waste has changed.
(b) Upon the effective date of this document, the owner or operator
shall follow a written waste analysis plan which describes the
procedures which will be used to comply with Item 3 (a). The
plan shall be subject to approval by the California State
Department of Health Services and shall be kept at the facility.
At a minimum, the plan shall specify:
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B-12 11
(I) The parameters for which each hazardous waste will be
analyzed and the rationale for the selection of these
parameters;
(2) The test methods which will be used to test for these
parameters;
(3) The sampling method which will be used to obtain a repre-
sentative sample of the waste to be analyzed. A represen-
tative sample may be obtained using either:
(!) One of the sampling methods described in Appendix I,
Part 261, Title 40, Code of Federal Regulations; or
(it) An equivalent sampling method approved by the California
State Department of Health Services.
(4) The frequency with which the initial analysis of the waste
will be reviewed or repeated to ensure that the analysis
Is accurate and up->to*
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B-13
12
(e) Upon the effective date of this document, a sign with the
legend, "Caution - Hazardous Waste Area - Unauthorized
Persons Keep Out," shall be posted at each entrance to the
•ctlve portion of the facility, and at other locations, in
sufficient numbers to be seen from any approach to this
active portion. The legend shall be written in Engligh
•nd Spanish, "Cuidado! Zona Oe Residuous Peligrosos.
Prohibida La Entrada A Personas No Autorizadas", and shall
be legible from a distance of at least 25 feet. Existing
signs with a legend other than "Caution - Hazardous Waste
Area - Unauthorized Persons Keep Out" may be used if the
legend on the sign indicates that only authorized personnel
are allowed to enter the active portion, and that entry
onto the active portion can be dangerous.
5. Inspections.
(a) The owner or operator shall inspect the facility for malfunctions
and deterioration, operator errors, and discharges which may be
causing—or.may lead to—release of hazardous waste constituents
to the environment or a threat to human health. The owner or
operator shall conduct these inspections often enough to identify
problems in time to correct them before they harm human health
or the environment.
(b) (1) The owner or operator shall follow a written schedule for
inspecting all monitoring equipment, safety and emergency
equipment, security devices, and operating and structural
equipment (such as dikes and sump pumps) that are important
to preventing, detecting, or responding to environmental
or human health hazards.
(2) The schedule shall be subject to approval by the California
State Department of Health Services.
(3) He shall keep this schedule at the facility.
(A) The schedule shall identify the types of problems (e.g.,
malfunctions or deterioration) which are to be looked for
during the inspection (e.g., inoperative sump pump, leaking
fitting, eroding dike, etc.).
(5) The frequency of inspection may vary for the items on the
schedule. However, it shall be based on the rate of
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B-14
13
possible deterioration of the equipment and the probability
of «n environmental or human health incident if the deteri-
oration or malfunction or any operator error goes undetected
between inspections. Areas subject to spills, such as
loading and unloading areas shall be inspected daily when
In use. At a minimum, the inspection schedule shall include
the items and frequencies called for elsewhere in this doc-
ument.
(c) The owner or operator shall remedy any deterioration or malfunc-
tion of equipment or structures which the inspection reveals on
a schedule which shall be subject to approval by the California
State Department of Health Services and which shall ensure that
the problem does not lead to an environmental or human health
hazard. Where a hazard is imminent or has already occurred,
remedial action shall be taken immediately.
(d) The owner or operator shall record inspections in an inspection
log or summary. He shall keep these records for at least three
years from the date of inspection. At a minimum, these records
shall Include the date and time of the inspection, the name of
the Inspector, a notation of the observations made, and the date
and nature of any repairs or other remedial actions.
w
6. Personnel training.
(a) (I) Facility personnel shall successfully complete a program
of classroom instruction or on-the-job training that teaches
them to perform their duties in a way that ensures the
facility's compliance with the conditions of this document.
The owner or operator shall ensure that this program in-
cludes all the elements described under Item 6 \a)(3).
(2) This program shall be directed by a person trained in haz-
ardous waste management procedures, and shall include instruc-
tion which teaches facility personnel hazardous waste management
procedures (including contingency plan implementation) rele-
vant to the positions in which they are employed.
(3) At a minimum, the training program shall be designed to
ensure that facility personnel are able to respond effectively
to emergencies by familiarizing them with emergency proce-
dures, emergency equipment, and emergency systems, including
where applicable:
(I) Procedures for using, inspecting, repairing, and re-
placing facility emergency and monitoring equipment;
(ii) Key parameters for automatic waste feed cut-off
systems;
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8-15
(III) Communications or alarm systems;
(Iv) Response to fires or explosions;
(v) Response to ground-water contamination Incidents;
and
(vi) Shutdown of operations.
(b) Facility personnel shall have successfully completed the
program required in Item 6 (a) by the effective date of this
document or within six months after the date of their employment
or assignment to a facility, or to a new position at a facility,
whichever is later. Employees hired after the effective date of
this document shall not work in unsupervised positions until they
have completed the training requirements of Item 6 (a).
(c) Facility personnel shall take part in an annual review of the
Initial training required in Item 6 (a).
(d) The owner or operator shall maintain the following documents
and records at the facility:
(1) The job title for each position at the facility related
to hazardous waste management, and the name of the employee
fit ling each job.
(2) A written job description for each position listed under
Item 6 (d)(l). This description may be consistent in its
degree of specificity with descriptions for other similar
positions in the same company location or bargaining unit,
but shall include the requisite skill, education, or other
qualifications, and duties of facility personnel assigned
to each position;
(3) A written description of the type and amount of both intro-
ductory and continuing training that will be given to each
person filling a position listed under Item 6 (d) (l); and
(4) Records that document that the training or job experience
required under Items 6 (a), (b), and (c) has been given to,
and completed by, facility personnel*
(e) Training records on current personnel as required in Item 6 (d) *»
shall be kept until closure of the facility. .Training records
on former employees shall be kept for at least three years from
the date the employee last worked at the facility. Personnel
training records may accompany personnel transferred within the
same company.
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B-16
15
7. Ignitable, reactive, or Incompatible wastes.
*(a) The owner or operator shall take precautions to prevent acci-
dental ignition or reaction of ignitable or reactive waste.
This waste shall be separated and protected from sources of
Ignition or reaction. While Ignitable or reactive waste is
being handled, the owner or operator shall confine smoking jnd
open flame to specially designated locations. "No Smoking"
signs shall be conspicuously placed wherever there is a hazard
from ignitable or reactive waste.
(b) The treatment, storage, or disposal of ignitable or reactive
waste, and the mixture or commingling of incompatible wastes,
or Incompatible wastes and materials shall be conducted so
that it does not:
(1) Generate extreme heat or pressure, fire or explosion, or
violent reaction;
(2) Produce uncontrolled toxic mists, fumes, dusts, or gases In
sufficient quantities to threaten human health;
(3) Produce uncontrolled flammable fumes or gases in sufficient
quantities to pose .a risk of fire or explosions;
(4) Damage the structural integrity of the device or facility
containing the waste; or
(5) Through other 1 ike means threaten human health or the envi-
ronment.
8. Maintenance and operation of facility.
The facility shall be maintained and operated to minimize the possi-
bility of a fire, explosion, or any unplanned sudden or non-sudden
release of hazardous waste or hazardous waste constituents to air,
soil, or surface water which could threaten human health or the
environment.
9. Testing and maintenance of equipment.
All facility communications or alarm systems, fire protection equip-
ment, spill control equipment, and decontamination equipment, where
required, shall be tested and maintained as necessary to ensure its
' proper operation in time of emergency.
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8-17
16
10. Required aisle space.
The owner or operator shall maintain aisle space as needed to allow
"the unobstructed movement of personnel, fire protection equipment,
Spill control equipment, and decontamination equipment to any area
of facility operation in an emergency.
It. Arrangements with local authorities.
(a) Upon the effective date of this document, the owner or operator
shall attempt to make the following arrangements, as appropriate
for the type of waste handled at the facility and the potential
need for the services of these organizations:
(1) Arrangements to familiarize police, fire departments, and
emergency response teams with the layout of the facility,
properties of hazardous waste handled at the facility and
associated hazards, places where facility personnel would
normally be working, entrances to roads inside the facility,
and possible evacuation routes;
(2) Where more than one police and fire department might respond
to an emergency, agreements designating primary emergency
authority to a.specific police and a specific fire depart-
ment, and agreements with any others to provide support to
the primary emergency authority;
(3) Agreements with State emergency response teams, emergency
response contractors, and equipment suppliers; and
(k) Arrangements to familiarize local hospitals with the prop-
erties of hazardous waste handled at the facility and the
types of injuries or illnesses which could result from
fires, explosions, or releases at the facility.
(b) Where State or local authorities decline to enter into such
arrangements, the owner or operator shall document the refusal
In the operating record.
12. Purpose and implementation of contingency plan.
(a) Upon the effective date of this document, the owner or operator
Shall have a contingency plan for the facility. The contingency
plan shall be subject to approval by the California State
Department of Health Services and shall be designed to minimize
hazards to human health or the environment from fires, explo-
sions, or any unplanned sudden or non-sudden release of hazardous
waste or hazardous waste constituents to air, soil, or surface
water.
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17
(b) Th« provisions of the plan shall be carried out Immediately
wherever there is a fire, explosion, or release of hazardous
waste or hazardous waste constituents which could threaten
human health or the environment.
13. Content of contingency plan.
(a) The contingency plan shall describe the actions facility
personnel shall take to comply with Items 12' and 17 (n re-
sponse to fires, explosions, or any unplanned sudden or non-
sudden release of hazardous waste or hazardous waste
constituents to air, soil, or surface water at the facility.
(b) If the owner or operator has already prepared some other
emergency or contingency plan, he need only amend that plan
to incorporate hazardous waste management provisions thac
are sufficient to comply with the conditions of this document.
(c) The plan shall describe arrangements agreed to by local
police departments, fire departments, hospitals, contractors,
and State and local emergency response teams to coordinate
emergency services pursuant to Item 13-
(d) The plan shall list names, addresses, and phone numbers
(office and home) of all persons qualified to act as
emergency coordinator (see Item 18), and this list shall be
kept up to date. Where more than one person is listed, one
shall be named as primary emerqency coordinator and others
shall be listed in the order in which they will assume re-
sponsibility as alternates.
(e) The plan shall include a list of all emergency equipment at
the facility (such as fire extinguishing systems, spill control
equipment, communications and alarm systems (internal and
external), and decontamination equipment), where this equip-
ment is required. This list shall be kept up to date. In
addition, the plan shall include the location and a physical
description of each item on the list, and a brief outline of
Its capabilities.
(f) The plan shall include an evacuation plan for facility personnel
where there is a possibility that evacuation could be necessary.
This plan shall describe signal(s) to be used to begin evacu-
ation routes, and alternate evacuation routes (in cases where
the primary routes could be blocked by releases of hazardous
wastes or fires).
Ik. Copies of contingency plan.
A copy of the contingency plan and all revisions to the plan shall
be:
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(•) Maintained at the facility; and
%(b) Submitted to the California State Department of Health
Services and to all local police departments, fire
departments, hospitals, and State and local emergency
response teams that may be called upon to provide emergency
services.
15. Amendment of contingency plan.
The contingency plan shall be reviewed, and immediately amended,
If necessary, whenever:
(a) Applicable regulations are revised;
(b) The plan fails in an emergency;
(c) The list of emergency coordinators changes; or
(d) The list of emergency equipment changes.
16. Emergency coordinator.
At all times, there shall be at least one employee either on the
facility premises or on call-(i.e., available to respond to an
emergency by reaching the facility within a short period of time)
with the responsibility for coordinating all emergency response
measures. This emergency coordinator shall be thoroughly familiar
with all aspects of the facility's contingency plan, all operations
and activities at the facility, the location and characteristics of
waste handled, the location of all records within the facility, and
the facility layout. In addition, this person shall have the
authority to commit the resources needed to carry out the contingency
plan.
17. Emergency procedures.
(a) Whenever there is an imminent or actual emergency situation,
the emergency coordinator (or his designee when the emergency
coordinator is on call) shall:
(1) Immediately activate Internal facility alarms or communica-
tion systems, where applicable, to notify all facility
personnel;
(2) Immediately notify appropriate State or local agencies with
designated response roles if their help is needed; and
(3) Notify the California State Department of Health Services
by telephone or telegraph within 2k hours of occurrence.
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B-20
1.0
(b) Whenever there Is a release, fire, or explosion, the emergency
coordinator shall immediately identify the character, exact
source, amount, and areal extent of any released materials.
This may be done by observation or review of facility records or
manifests and, tf necessary, by chemical analysis.
(c) Concurrently, the emergency coordinator shall assess possible
hazards to human health or the environment that may result
from the release, fire, or explosion. This assessment shall
consider both direct and indirect effects of the release, fire,
or explosion (e.g., the effects of any toxic, irritating, or
asphyxiating gases that are generated, or the effects of any
hazardous surface water run-offs from water or chemical agents
used to control fire and heat-induced explosions).
(d) If the emergency coordinator determines that the facility
has had a release, fire, or explosion which could threaten
human health, or the environment, outside the facility, the
findings shall be reported as follows:
(1) The emergency coordinator shall immediately notify
either the government official designated as the on-scene
coordinator for that geographical area (in the applicable
regional contingency plan under Part 1510, Title 40,
Code of Federal Regulations), or the National Response
Center (using their 24-hour toll free number: 800/424-8302)
The report shall include:
(I) Name and telephone number of reporter;
(II) Name and address of facility;
(til) Time and type of incident (e.g., release, fire);
(Iv) Name and quantity of material(s) involved, to the ex-
tent known;
(v) The extent of injuries, if any; and
(vi) The possible hazards to human health, or the environ-
ment, outside the facility.
(2) If his assessment indicates that evacuation of local areas
may be advisable, appropriate local authorities shall be
notified immediately. The .emergency coordinator shall be
available to help appropriate officials decide whether
local areas should be evacuated.
(e) During an emergency the emergency coordinator shall take all
reasonable measures necessary to-ensure that fires, explosions
and releases do not occur, recur, or spread to other hazardous
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B-21
20
waste at the facility. These measures shall include, where
applicable, stopping processes and operations, collecting and
containing released waste, and removing or isolating containers.
(f) If the facility stops operations in response to a fire, explosion
or release, the emergency coordinator shall monitor for leaks,
pressure buildup, gas generation, or ruptures in valves, pipes,
or other equipment, wherever this is appropriate.
(g) Immediately after an emergency, the emergency coordinator shall
provide for treating, storing, or disposing of recovered waste,
contaminated soil or surface water, or any other material that
results from a release, fire, or explosion at the facility.
(h) The emergency coordinator shall ensure that, in the affected
area(s) of the facility:
(I) No waste that may be incompatible with the released material
Is treated, stored, or disposed of until cleanup procedures
are completed; and
(2) AH emergency equipment listed in the contingency plan is
cleaned and fit for its intended use before operations are
resumed. i
(I) The owner or operator shall notify the California State
Department of Health Services and local authorities, that the
facility is in compliance with Item 17 (h) before operations
are resumed in the affected area(s) of the facility.
(j) The owner or operator shall note in the operating record the
time, date, and details of any incident that requires imple-
menting the contingency plan.. Within 30 days after the incident,
he shall submit a written report on the incident to the
California State Department of Health Services. The report
shall include:
(1) Name, address, and telephone number of the owner or
operator;
(2) Name, address, and telephone number of the facility;
(3) Date, time, and type of incident (e.g., fire, explosion);
(*•) Name and quantity of material(s) involved;
(5) The extent of injuries. If any;
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B-22 21
(6) An assessment of actual or potential hazards to human
health or the environment, where this is applicable; and
(7) Estimated quantity and disposition of recovered material
that resulted from the incident.
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B-23
22
IV. RECORDKEEPING
1. Operating record.
(a) The owner or operator shall keep a written operating record
at the facility.
(b) The following information shall be recorded, as it becomes
available, and maintained in the operating record until
closure of the facility:
(1) A description and the quantity of each hazardous
~ • waste received, and the method(s) and date(s) of
Its treatment, storage, or disposal at the facility;
(2) The location of each hazardous waste within the
facility and the quantity at each location. This
Information shall include cross-references to
specific manifest document numbers, if the waste
was accompanied by a manifest;
(3) Records and results of waste analyses and trial tests
performed;
(4) Summary reports and details of all incidents that
require implementing the contingency plan;
(5) Records and results of inspections (except these
data need be kept only three years);
(6) Monitoring, testing or analytical data where required; and
(7) All closure cost estimates.
2. Availability, retention, and disposition of records.
(a) All records including plans, required in this document shall be
furnished upon request, and made available at all reasonable
1 times for inspection, by any officer, employee, or respresenta-
tlve of the California State Department of Health Services who
Is duly designated by the Director!
(b) The retention period for'all records'required in this document
Is extended automatically during the courseof any unresolved
enforcement action regarding the facility or as requested by
the California State Department of Health Services;
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23
(c) A copy of records of waste disposal locations and quantities
In Item 1 (b)(2) shall be submitted to the California
State Department of Health Services and local land author!ty
upon closure of the facility*
3. Annual report.
The owner or operator shall prepare and submit a single copy of an
annual report to the California State Department of Health Services
by March 1 of each year beginning March 1, 1982. The annual report
shall cover facility activities during the previous calendar year and
shall include the following information:
*
(a) The EPA identification number, name, and address of the
facility;
(b) The calendar year covered by the report;
(c) A description and the quantity of each hazardous waste the
facility received during the year;
(d) The method of treatment, storage, or disposal for each
hazardous waste;
t«
(e) Monitoring data where required;
(f) The most recent closure cost estimate;
(g) The certification signed by the owner or operator of the
facility or his authorized representative.
4. Additional reports.
In addition to submitting the annual report required in Item 3,
the owner or operator shall also report to the California State
Department of Health Servicesi
(a) Releases, fires, and explosions;
(b) Ground-water contamination and monitoring data;
(c) Facility closure.
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.-25
V. CLOSURE
1. Closure.
The owner or operator shall close his facility In a manner that:
(a) minimizes the need for further maintenance, and (b) controls,
minimizes or eliminates, to the extent necessary to protect human
health and the environment, post-closure escape of hazardous waste,
hazardous waste constituents, leachate, contaminated rainfall, or
waste decomposition products to the ground water, or surface waters,
or to the atmosphere.
2. Closure plan and amendment of plan.
(a) The owner or operator shall have a written closure plan,
This plan shall be subject to approval by the California
Regional Water Quality Control Board and shall be kept at
the facility. This plan shall identify the steps necessary
to close the facility completely at any point during its
Intended life and at the end of its intended life. The
closure plan shall include, at least:
(1) A description of how and when the facility will be parti-
ally closed, if applicable, and ultimately closed. The
description shall identify the maximum extent of the
operation which will be unclosed during the life of the
facility, and how Item 1 and other applicable conditions
of this document will be met;
(2) An estimate of the maximum inventory of wastes in storage
or in treatment at any given time during the life of the
facility;
(3) A description of the steps needed to decontaminate facility
equipment during closure; and
A schedule for final closure which shall include, as a
minimum, the anticipated date when wastes will no longer
be received, the date when completion of final closure
(s anticipated, and intervening milestone dates which
will allow tracking of the progress of closure. (For
example, the expected date for completing treatment or
disposal of waste inventory shall be included, as must the
planned date for removing any residual wastes from storage
facilities and treatment processes.)
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23
(t) Th« owner or oper4tor may amend his closure plan at any time
during the active life of the facility. (The active life of
the facility is that period during which wastes are periodi-
cally received.) The owner or operator shall amend his plan
any time changes in operating plans or facility design affect
the closure plan.
(c) The owner or operator shall submit his closure plan to the
California Regional Water Quality Control Board at least 180
days before the date he expects to begin closure. The
California Regional Water Quality Control Board will modify,
approve, or disapprove the plan within 90 days of receipt and
after providing the owner or operator and the affected public
(through a newspaper notice) the opportunity to submit written
comments.
3. Time allowed for closure.
(a) Within 90 days after receiving the final volume of hazardous
wastes, the owner or operator shall treat all hazardous
wastes in storage or in treatment, or remove them from the
site, or dispose of them on-site, in accordance with the
approved closure plan.
<«
(b) The owner or operator shall complete closure activities in
accordance with the approved closure plan and within six
months after receiving the final volume of wastes. The
California Regional Water Quality Control Board may approve
a longer closure period under I tern 2 (c) if the owner or
operator can demonstrate that: (1) the required or planned
closure activities will, of necessity, take him longer than
six months to complete, and (2) that he has taken a)! steps
to eliminate any significant threat to human health and the
environment from the unclosed but inactive facility.
k. Disposal or decontamination of equipment.
When closure is completed, all faci1ity'equipment and structures
shall have been properly disposed of, or decontaminated by removing
all hazardous waste and residues.
5. Certification of closure.
When closure is completed, the owner or operator shall submit to
the California Regional Water Quality Control Board certification
both by the owner or operator and by an independent registered
professional engineer that the facility has been closed in accor-
dance with the specifications in the approved closure plan.
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B-27
2G
VI. FINANCIAL RESPONSIBILITY
1. Cost estimate for facility closure.
(a) The owner or operator shall have a written estimate of the
cost of closing the facility in accordance with the applicable
closure requirements of this document. The owner or operator
shall keep this estimate, and all subsequent estimates, at the
facility. The estimate shall equal the cost of closure at the
point in the facility's operating life when the extent and
manner of its operation would make closure the most expensive,
as indicated by its closure plan.
(b) The owner or operator shall prepare a new closure cost estimate
whenever a change in the closure plan affects the cost of
closure:
(c) On each anniversary of the effective date of this document,
the owner or operator shall adjust the latest closure cost
estimate using an inflation factor derived from the annual
Implicit Price Deflator for Gross National Product as published
by the U.S. Department of Commerce in its Survey of Current
Business. The inflation factor shall be calculated by dividing
the latest published annual Deflator by the Deflator for the
previous year. The result is the inflation factor. The adjusted
closure cost estimate shall equal the latest closure cost esti-
mate (see Item l(b)) times the inflation factor.
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27
VH. OFF-SITE FACILITY
1. Analysis of waste.
(•) The owner or operator shall follow a written waste analysis
plan which shall be subject to approval by the California
State Department of Health Services and which shall specify
the waste analyses that hazardous waste generators have agreed
to supply.
(b) The waste analysis plan required in Item 1 (a) shall also
specify the procedures which will be used to inspect and, if
necessary, analyze each movement of hazardous waste received
at the facility to ensure that it matches the identity of the
waste designated on the accompanying manifest. At a minimum,
the plan must describe:
(1) The procedures which will be used to determine the
Identity of each movement of waste managed at the
facility; and
(2) The sampling method which will be used to obtain a
representative sample of the waste to be identified, If
the identification method includes sampling.
(c) Before the owner or operator treats, stores, or disposes of
a particular type of hazardous waste for the first time, he
shall obtain a detailed chemical and physical analysis of a
representative sample of the waste. At a minimum, this
analysis shall contain all the information which must be
known to treat, store, or dispose of the waste in accordance
with the conditions of this document.
(d) The analysis shall be repeated as necessary to ensure that
it is accurate and up-to-date. At a minimum, the analysis
must be repeated when the results of the inspection required
in Item 1(e) indicate that the hazardous waste received at
the facility does not match the waste designated on the
accompanying manifest.
(e) The owner or operator shall inspect and, tf necessary,analyze
each hazardous waste movement received at the facility to
determine whether it matches the identity of the waste specified
on the accompanying manifest.
2. Use of manifest.
The owner or operator, or his agent, shall:
(a) Require that a manifest be completed for all hazardous waste
accepted.
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28
(b) Inspect wastes before accepting them to ensure that the
delivered waste has essentially the same general properties
as Identified by the generator on the manifest;
(c) Complete the appropriate section of the manifest.
(d) Sign and date each copy of the manifest to certify that the
hazardous waste covered by the manifest was received;
(e) Note any significant discrepancies in the manifest on each copy
of the manifest; .
(f) Immediately give the transporter at least one copy of the
signed manifest;
(g) Send legible copies of all completed hazardous waste manifests
to the California State Department of Health Services on a
monthly basis in conformance with Section 66550, Title 22,
California Administrative Code;
(h) Within 30 days after delivery, send a copy-of the manifest
to the generator; and
(I) Retain at the facility a copy of each manifest for at least
three years from the date of delivery.
3. Manifest discrepancies.
Upon discovering a significant discrepancy between the quantity or
type of hazardous waste designated on the manifest and the quantity
or type of hazardous waste a facility actually receives, the owner
or operator shall attempt to reconcile the discrepancy with the waste
generator or transporter (e.g., with telephone conversations).
Significant discrepancies in quantity are: (1) for bulk waste,
variations greater than 10 percent in weight, and (2) for batch
waste, any variation in piece count, sucn as a discrepancy or one
drum in a truckload. Significant discrepancies in type are obvious
differences which can be discovered by inspection or waste analysis
such as waste solvent substituted for waste acid, or toxic constit-
uents not reported on the manifest. If the facility can accept the
waste after Its actual identity is revealed, the owner or operator
may accept the waste. If the facility cannot accept the waste,
the owner or operator shall Immediately notify the California State
Department of Health Services of that fact, identify the transporter
and generator of the waste, and refuse to accept the waste. If
the owner or operator can accept the waste, he shall note, on the
copy of the manifest which he submits to the California State
Department of Health Services and on the copy which he retains,
how the discrepancy was resolved. If the discrepancy Is not
resolved within 15 days after receiving the waste, the owner or
operator shall immediately submit to the California State Depart-
ment of Health Services a letter describing the discrepancy and
attempts to reconcile it, and a copy of the manifest at issue.
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29
k. Annual report.
'The owner or operator shall prepare an annual report (as described
elsewhere in this document) which shall include:
(a) The EPA identification number of each hazardous waste generator
from which the facility received a hazardous waste during the
year; for imported shipments, the report shall give the name
and address of the foreign generator; and
(b) A description and the quantity of each hazardous waste, which
the facility received during the year, listed by EPA identi-
fication number of each generator.
•
5. Unmanifested waste report.
»
If the facility accepts for treatment, storage, or disposal any
hazardous waste from an off-site source without an accompanying
manifest, and if the waste is not excluded from the manifest require-
ment, then the owner or operator shall prepare and submit a single
copy of a report to the California State Department of Health Services
within 15 days after receiving the waste. The report shall include
the following information:
*•
(a) The EPA Identification number, name, and address of the
facility;
(b) The date the facility received the waste;
(c) The EPA identification number, name, and address of the
generator and the transporter, if available;
(d) A description and the quantity of each unmanifested haz-
ardous waste the facility received;
*
(e) The method of treatment, storage, or disposal for each
hazardous waste;
(f) The certification signed by the owner or operator of the
facility or his authorized representative; and
(g) A brief explanation of why the waste was unmanifested, if
known.
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B-31
VIII. GROUND-WATER MONITORING ^°
I. Ground-water monitoring.
<«) Effective November 19, 1981, the owner or operator shall Implement
• ground-water monitoring program which is capable of determining
the facility's impact on the quality of ground water in the upper-
most aquifer underlying the facility. A ground-water monitoring
system shall be part of the ground-water monitoring program. The
ground-water monitoring system shall be capable of yielding ground-
water samples for analysis, and shall consist of:
(1) Monitoring welIs (at least one) installed hydraulically
upgradient (i.e., in the direction of increasing static
head) from the limit of the waste management area.
Their number, locations, and depths shall be sufficient
to yield ground-water samples that are:
(I) Representative of background ground-water quality
In the uppermost aquifer near the facility; and
(I!) Not affected by the facility; and-
(2) Monitoring wells (at least three) installed hydraulically
downgradient (i.e., in the direction of decreasing static
head) at the limit pf the waste management area. Their
number, locations, and depths shall ensure that they
Immediately detect any statistically significant amounts
of hazardous waste or hazardous waste constituents that
migrate from the waste management area to the uppermost
aquifer.
(b) All monitoring wells shall be cased in a manner that maintains
the integrity of t^a •monitoring well bore hole. This casing
shall be screened or perforated, and packed w.ith gravel or
sand where necessary, to enable sample collection at depths
where appropriate aquifer flow zones exist. The annular space
(i.e., the space between the bore hole and well casing) above the
sampling depth shall be sealed with a suitable material (e.g.,
cement grout or bentonite slurry) to. prevent contamination of
samples and the ground water.
*
2. Sampling and analysis.
*
(a) The owner or operator shall obtain and analyze samples from the
Installed groundwater monitoring system. The owner or operator
shall follow a ground-water sampling and analysis plan. The plan
shall be subject to approval by the California State Department
of Health Services and shall be kept at the facility. The plan
shall include procedures and techniques for:
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8-32
(1) Sample collect Ion;
(2) Sample preservation and shipment;
(3) Analytical procedures; and
CO Chain of custody control.
(b) The owner or operator shall determine the concentration or value
of the following parameters in ground-water samples in accord-
ance with Item 2(c) and (d) :
(1) Parameters characterizing the suitability of the ground
water as a drinking water supply as specified by EPA
In Appendix III, Part 265, Title 40, Code of Federal
Regulations.
(2) Parameters establishing ground-water quality:
(I) Chloride
(U) Iron
(ill) Manganese
(Iv) Phenols
(v) Sodium
(vl) Sulfate
(3) Parameters used as indicators of ground-water contamination:
(0 PH
(U) Specific Conductance
(I? I) Total Organic Carbon
(iv) Total Organic Halogen
(c) (1) For all monitoring wells, the owner or operator shall
establish initial background concentrations or values of
all parameters specified in Item 2 (b-). This shall be done
quarterly for one year.
(2) For each of the indicator parameters specified in Item 2
(b)(3)» at least four replicate measurements shall be
obtained for each sample and the initial background
arithmetic mean and variance shall be determined by pooling
the replicate measurements for the respective parameter
concentrations or values in samples obtained from upgradient
wells during the first year/
(d) After the first year, all monitoring wells shall be sampled and
the samples analyzed with the following frequencies:
(1) Samples collected to establish ground-water quality shall be
obtained and analyzed for the parameters specified in
Item 2(b)(2) at least annually.
(2) Samples collected to indicate ground-water contamination
shall be obtained and analyzed for the parameters specified
In Item 2(b) (3) at least semi -annually.
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32
(e) Elevation of the ground-water surface at each monitoring
well shall be determined each time a sample Is obtained.
• «
3. Preparation, evaluation, and response.
(a) By November 19, 1981, the owner or operator shall prepare
an outline of a ground-water quality assessment program.
The outline shall describe a more comprehensive ground-
water monitoring program (than that described in Items
1 and 2) capable of determining:
(1) Whether hazardous waste or hazardous waste contituents-
have entered the ground water.
(2) The rate and extent of migration of hazardous waste or
hazardous waste constituents in the ground water; and
•
(3) The concentrations of hazardous waste or hazardous waste
constituents in the ground water.
(b) For each indicator parameter specified in I tern 2(b)(3), the
owner or operator shall calculate the arithmetic mean and
variance, based on at least four replicate measurements on
each sample, for each well monitored in accordance with
Item 2(d)(2), and compare these results with its initial
background arithmetic mean. The comparison shall consider
Individually each of the wells in the monitoring system, and
shall use the Student's t-test at the 0.01 level of significance
to determine statistically significant increases (and decreases,
In the case of pH) over initial background.
(c) (l) If the comparisons for the upgradient wells made under
Item 3(b) show a significant increase (or pH decrease),
the owner or operator shall submit this information in
accordance with I tern A(a)(2)(ii).
(2) If the comparisons for downgradient wells made under Item 3
(b) show a significant increase (or pH decrease), the
owner or operator shall immediately obtain additional ground-
water samples from those downgradient wells where a significant
difference was detected, split the samples in two, and obtain
analyses of all additional samples to determine whether the
significant difference was a result of laboratory error.
(d) (1) If the analyses performed under Item 3(c)(2) confirm the
significant increase (or pH decrease), the owner or operator
shall provide written notice to the California Regional Water
Quality Control Board within seven days of the date of such
confirmation, that the facility may be affecting ground-water
qua 1 i ty.
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33
(2) Within 15 days after the notification under Item 3(d)(l),
the owner or operator shat! develop and submit to the
California Regional Water Quality Control Board for approval
a specific plan, based on the outline required under Item 3(a)
and certified by a qualified geologist or geotechnical engineer,
for a ground-water quality assessment program at the facility.
(3) The plan to be submitted under Item 3(d)(2) shall specify:
(I) The number, location, and depth of wells;
0?) Sampling and analytical methods for those hazardous
wastes or hazardous waste constituents in the facility;
(III) Evaluation procedures, including any use of previously
qathered ground-water quality information; and
(Iv) A schedule of implementation.
(4) The owner or operator shall implement the ground-water quality
assessment plan which satisfies Item 3(d)(3), and, at a
minimum, determine:
(?) The rate and extent of migration of the hazardous waste
or hazardous waste constituents In the ground water; and
(il) The concentrations of the hazardous waste or hazardous
waste constituents in the ground water.
(5) The owner or operator shall make the first determination under
Item 3(d)(M as soon as technically feasible, and, within 15
days after that determination, submit to the California
Regional Water Quality Control Board a written report containing
an assessment of the ground-water quality.
(6) If the owner or operator determines, based on the results of
the first determination under Item 3(d)(M, that no hazardous
waste or hazardous waste constituents from the facility have
entered the ground water, the indicator evaluation program
described in Item 2 and Item 3(b) shall be reinstated. When
the owner or operator reinstates the indicator evaluation
program he shall notify the California Regional Water Quality
Control Board in the report submitted under Item 3(d)(5)>
(7) If the owner or operator determines, based on the first determi-
nation under Item 3(d)CO, that hazardous waste or hazardous
waste constituents from the facility have entered the ground
water, then:
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B-35
(0 The determinations, required under Item 3(d)(4) shall
continue to be made on a quarterly basis until final
closure of the facility, if the ground-water quality
assessment plan was implemented prior to final
closure of the facility; or
(H) The determinations required under Item 3(.d) (A) , may
cease to be made if the ground-water quality assessment
plan was implemented during the post-closure care
period.
(e) Any ground-water quality assessment to satisfy the require-
ments of Item 3(d)CO which is initiated prior to final
closure of the facility shall be completed and reported
In accordance with Item 3(d)(5).
(f) Unless the ground water is monitored to satisfy Item 3(d)(M,
at least annually the owner or operator shall evaluate the
data on ground-water surface elevations obtained under I tern
2(e) to determine whether the requirements under Item 1 (a)
for locating the monitoring wells continues to be satisfied.
If the evaluation shows that Item 1(a) is no longer satisfied,
the owner or operator shall immediately modify the number,
location, or depth of the monitoring wells to bring the
ground-water monitoring system into compliance with this
cond i t i on .
4. Recordkeeping and reporting.
(a) Unless the ground water is monitored to satisfy the requirements
of Item 3(d)(iO, the owner or operator shall:
(1) Keep records of the analyses required in Item 2(c) and
(d) , the associated ground-water surface elevations required
in Item 2(e), and the evaluations required in Item 3(b)
throughout the active life of the facility; and
(2) Report the following ground-water monitoring information
to the California Regional Water Quality Control Board:
(!) During the first year when initial background
concentrations are being established for the
facility: Concentrations or values of the
parameters listed in (tern 2(b)(l) for each
ground-water monitoring well within 15 days
after completing each quarterly analysis. The
owner or operator shal 1 . separately Identify for
each monitoring well any parameters whose
concentration or value has been found to exceed
the maximum contaminant levels specified by EPA
In Appendix HI, Part 265, Title 40, Code of
Federal Regulations.
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B-36
35
»
(II) Annually: Concentrations or values of the
parameters listed in Item 2(b)(3) for each
ground-water monitoring well, along with
the required evaluations for these parameters
under Item 3(b). The owner or operator shall
separately identify any significant differences
from initial background found In the upgradient
wells, in accordance with Item 3(c)(l).
During the active life of the facility, this
Information shall be submitted as part of the
annual report required elsewhere.
in this document.
(Hi) As a part of the annual report required
elsewhere in this document: Results of
the evaluation of ground-water surface elevations
under Item 3(0, and a description of the response
to that evaluation, where applicable.
(b) If the ground water is monitored to satisfy Item 3(d)(M,
the owner or operator shall:
(1) Keep records of the analyses and evaluations specified
In the plan, which satisfies Item 3(d)(3). throughout
the active life of the facility; and
(Z) Annually, until final closure of the facility, submit to
the California Regional Water Quality Control Board a
report containing the results of his ground-water quality
assessment program which includes, but is not limited to,
the calculated (or measured) rate of migration of hazard-
ous waste or hazardous waste constituents in the ground
water during the reporting period. This report shall be
submitted as part of the annual report required
elsewhere in this document.
5. Waiver
The foregoing conditions may be waived if the owner or operator
can demonstrate in writing to the satisfaction of the California
Regional Water Quality Control Board that there is a low potential
for migration of hazardous waste or hazardous waste constituents
from the facility via the uppermost aquifer to water supply wells
or to surface water.
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36
IX. DISPOSAL SITE
1. Operating record *
The owner or operator shall maintain in the written operating
record at his facility the following information until closure
of the facility:
(a) The location and quantity of each hazardous waste
: recorded on a map or diagram of each cell or disposal
area; and
(b) All post-closure cost estimates.
2. Annual report.
The owner or operator shall include in his annuaj report to the
.California State Department of Health Services by March 1 of
each year except 1931 the most recent post-closure cost estimate.
3. Recordkeeping and reporting.
v+
(a) Unless the owner or operator has implemented a satisfactory
ground-water quality assessment plan as specified elsewhere
in this document, he shall keep records of required analyses
of monitoring samples and associated ground-water surface
elevations, as well.as required evaluations throughout the
post-closure care period.
(b) If the ground water is monitored in accordance with a
satisfactory ground-water quality assessment plan, the
owner or operator shall keep records of analyses and
elevations specified in the plan throughout the post-
closure care period.
k. Post-closure care and use of property; period of care.
(a) Post-closure care shall consist of at least:
(1) Ground-water monitoring and reporting; and
(2) Maintenance of monitoring and waste containment systems.
(b) The California Regional Water Quality Control Board may require
maintenance of any or all of the security conditions in Item 4,
Part III of this document during the post-closure period, when:
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B-38
37
(1) Wastes may remain exposed after completion of
closure; or
• %
(2) Short term, incidental access by the public or
domestic livestock may pose a hazard to human health.
(c) Post-closure use of the property on or in which hazardous
waste remains after closure shall never be allowed to
disturb the integrity of the final cover, liner(s), or
any other components of any containment system, or the
function of the facility's monitoring systems, unless the
owner or operator can demonstrate to the California
Regional Water Quality Control Board either in the post-
closure plan or by petition, that the disturbance:
(1) Is necessary to the proposed use of the property,
and will not increase the potential hazard to human
health or the environment; or
(2) Is necessary to reduce a threat to human health or
the environment.
(d) The owner or operator shall provide . •
post-closure care in accordance with the approved post-closure
plan for at least 30 years after the date of completing closure.
However, the owner or operator may petition the California
Regional Water Quality Control Board to allow some or all of
the requirements for post-closure cars to be discontinued or
altered before the end of the 30-year period. The petition
shall include evidence demonstrating the secure nature of the
facility that makes continuing the specified post-closure
requirement(s) unnecessary (e.g., no detected leaks and none
likely to occur, characteristics of the waste, application of
advanced technology, or alternative disposal, treatment, or
re-use techniques ). Alternately, the California Regional
Water Quality Control Board may require the owner or operator
to continue one or more of the post-closure care and maintenance
requirements contained in the facility's post-closure plan for
a specified period of time. The California Regional Water
Quality Control Board may do this if they find there has been
noncomp 1iance with any applicable standards or requirements,
or that such continuation is necessary to protect human health
or the environment. At the end of the specified period of time,
the California Regional Water Quality Control Board will
determine whether to continue or terminate post-closure care
and maintenance at the facility. The owner or operator may
petition the California Regional Water Quality Control Board
for an extensTon or reduction of the post-closure care period
based on cause. These petitions will be considered by the
California Regional Water Quality Control Board at the time
the post-closure plan is submitted and at five-year intervals
after the completion of closure. •
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38
5. Post-closure plan; amendment of ptan.
(a) The owner or operator shall have a written pose-closure
plan. He shall keep this plan at the facility. This
plan shall identify the activities which will be carried
on after final closure and the frequency of those
activities. The post-closure plan shall include at least:
(1) Ground-water monitoring activities and frequencies
as specified elsewhere in this document for the post-
closure period; and
(2) Maintenance activities and frequencies to ensure:
(l) the integrity of the cap and final cover or other
containment structures as specified elsewhere in this
document, and (2) the function of the facility's
monitoring equipment.
(b) The owner or operator may amend his post-closure plan at
any time during the active life of the disposal facility or
during the post-closure care period. The owner or operator
shall amend his plan any time changes in operating plans or
facilities design affect his post-closure plan.
(c) The owner or operator shall submit his post-closure plan to
the California Regional Water Quality Control Board at least
180 days before the date he expects to begin closure. The
California Regional Water Quality Control Board will modify
or approve the plan within 90 days of receipt and after
providing the owner or operator and the affected public
(through a newspaper notice) the opportunity to submit
written comments. The plan may be modified to include
security equipment maintenance under I tern Mb). Any
amendments to the plan under Item 5(b) which occur after
approval of the plan shall also be approved by the California
Regional Water Quality Control Board before they may be
Implemented.
6. Notice to local land authority.
Within 90 days after closure is completed, the owner or operator
shall submit to the local land authority and to the California
Regional Water Quality Control Board a survey plat indicating the
location and dimensions of landfill cells or other disposal areas
with respect to permanently surveyed benchmarks. This plat shall
be prepared and certified by a professional land surveyor. The
plat filed with the local land authority shall contain a note,
prominently displayed, which states the owner's or operator's
obligation to restrict disturbance of the site as specified in
Item Me). In addition, the owner or operator shall submit to the
California Regional Water Quality Control Board, and to the local
land authority a record of the type, location, and quantity of
hazardous wastes disposed of within each cell or area of the facility.
For wastes disposed of before the effective date of this document,
the owner or operator shall identify the type, location, and quantity
of the wastes to the best of his knowledge and in accordance with any
records he has kept.
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B-40
7. Notice In deed to property.
..The owner of the property on which the facility is located shall
record, in accordance with California law, a notation on the
deed to the facility property—or on some other Instrument which is
normally examined during title search—that will in perpetuity
notify any potential purchaser of the property that: (1) the land
has been used to manage hazardous waste, and (2) its use is
restricted under Item Me).
8. Cost estimate for post-closure monitoring and maintenance.
(a) The owner or operator shall have a written estimate of the
annual cost of post-closure monitoring and maintenance of
the facility. The owner or operator shall keep this estimate,
and all subsequent estimates required in this Item, at the
facility.
(b) The owner or operator shall prepare a new annual post-
closure cost estimate whenever a change In the post-closure
plan affects the cost of post-closure care. The latest
post-closure cost estimate is calculated by multiplying the
latest annual post-closure cost estimate by 30.
(c) Annually during the operating life of the facility, the owner
or operator shall adjust the latest post-closure cost estimate
using the inflation factor calculated as described elsewhere
In this document. The adjusted post-closure cost estimate
shall equal the latest post-closure cost estimate times the
Inflation factor.
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10
TANKS
1. Operation.
(a) Treatment or storage of hazardous waste in tanks shall comply
with Item 7 (b), Part III of this document.
(b) Hazardous waste or treatment reagents shall not be placed in
a tank if they could cause the tank or its inner liner to
rupture, leak, corrode, or otherwise fail before the end of
its intended life.
(c) Uncovered tanks shall be operated to ensure at least 60 centi-
meters (2 feet) of freeboard, or the tank shall be equipped
with a containment structure (e.g., dike or trench), a drainage
control system, or a diversion structure (e.g., standby tank)
with a capacity that equals or exceeds the volume of the top
60 centimeters (2 feet) of the tank.
(d) If hazardous waste is continuously fed into a tank, the tank
shall be equipped With a means to stop this inflow (e.g., a
waste feed-cutoff system or by-pass system to a stand-by tank).
2. Analysis of waste and trial tests.
(a) If a tank is to be used for:
(1) Chemically treating or storing a hazardous waste which is
substantially different from waste previously treated or
stored in that tank; or
(2) Chemically treating hazardous waste with a substantially
different process than any previously used in that tank;
the owner or operator shall before treating or storing
the different waste or using the different process:
(I) Conduct waste analyses and trial, treatment or storage
tests (e.g., bench scale or pilot plant scale tests)
to document that this proposed treatment or storage
will comply with Items J(a) and (b); or
(ii) Obtain written information on similar storage or
treatment of similar waste under similar operating
conditions to document that this proposed treatment
or storage will comply with Items 1 (a) and (b).
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3. Inspections.
(•) The owner or operator of * tank must inspect, if applicable:
(I) Discharge control equipment (e.g., waste feed cut-off
systems, and drainage systems), at least once each operating
day, to ensure that it is in good working order;
(2) Data gathered from monitoring equipment (e.g., pressure and
temperature gauges), at least once each operating day, to
ensure that the tank is being operated according to its
design;
(3) The level of waste in the tank, at least once each operating
day, to ensure compliance with Item 1 (c);
(k) The construction materials of the tank, at least weekly,
to detect corrosion or leaking of fixtures or seams; and
(5) The construction materials of, and the area immediately
surrounding, discharge confinement structures (e.g., dikes),
at least weekly, to detect erosion or obvious signs of
leakage (e.g., wet spots or dead vegetation).
k. Closure.
»«
At closure, ail hazardous waste and hazardous waste residues shall
be removed from tanks, discharge control equipment, and discharge
confinement structures.
5. Ignitable or reactive waste.
(a) Ignitable or reactive waste shall not be placed in a tank,
unless:
(1) The waste is treated, rendered, or mixed before or immedi-
ately after placement in the tank so that the resulting
waste, mixture, or dissolution of material is no longer
Ignitable or reactive and Item 7 (b), Part III of this
document is complied with; or
(2) The waste is stored or treated in such-a way that It is
protected from any material or conditions which may cause
the waste to ignite or react; or
(3) The tank is used solely for emergencies.
(b) If the owner or operator treats or stores ignitable or reactive
waste in covered tanks, he shall comply with the National Fire
Protection Association's (NFPA's) buffer zone requirements for
tanks, contained in Tables 2-1 through 2-6 of the "Flammable and
Combustible Code—1977".
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42
6. Incompatible Wastes.
••(a) Incompatible wastes, or incompatible wastes and materials,
shall not be placed in the same tank, unless Item 7 (b),
Part III of this document is complied with.
(b) Hazardous waste shall not be placed in an unwashed tank which
previously held an incompatible waste or material.
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43
XI. THERMAL TREAT)ȣN~ IN INCINERATORS
I. Operation.
Before adding hazardous waste, the owner or operator shall bring
his incinerator to steady state (normal) conditions of operation--
Including steady state operating temperature and air flow— using
auxiliary fuel or other means.
2. Analysis of waste.
The owner or operator shall sufficiently analyze any waste wnich he
has not previously burned in his incinerator re enable him to
establish steadv state (normal) operating :ond:t'cns 'including
waste »nc auxiliary fuel feed and air flow) and to determine the
type of pollutants wnich night be emitted. At a minimum, che analysis
shall oe ".ermine:
.(a) Heating value of the waste;
(b) Halogen content and sulfur content in the weste; and
(c) Concentrations in the waste of lead and mercury, unless the
owner or operator has documented proof tnat the elenert is not
present.
3- Monitoring and inspections.
(a) The owner or operator shall conduct, as a minimum, the following
men f tor ing and irsoect/ons when incinerating hazardous wastes:
(!) Existing instruments (e.g., those measuring *ascs feed,
auxiliary fuel feed, air flow, incinerator tempera tur«,
scruober flow, scruboer pK, and relevant I eve? controls)
wh,rch relate to combustion and emission control srail be
monitored at least every 15 minutes. Aoproor'at* correc-
tions to ma:ntain steady state combustion canci* or*, snail
be made immediately either automatically or by cne operator.
(2) The stack emissions shall be observed visually at least
hourly for nomal appearance (color and opacity)- The
operator shall t mediately (take any indicated oeertt-'ng
corrections necessary to return visible emissions to
their normal appearance. . '
(3) The complete incinerator and associated equipment
valves, conveyors, pipes, etc.) shall be inspected a:
dally for leaks, spills, and fugitive emissions, and all
emergency shutdown controls and system alarms shall be
to ensure proper operation.
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k. Closure.
B-45
1-1
At closure, the owner or operator shall remove all hazardous
taste and hazardous waste resicues (including, but not limited
to.ash, scrubber waters, and scrubber sludges) from the inciner-
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B-46
45
SURFACE IMPOUNDMENTS
1. Freeboard
The surface impoundments) shall maintain enough freeboard (at least
60 centimeters (2 feet)) to prevent any overtopping of the dike by
overfilling, wave action, or a storm.
2. Dikes
All earthen dikes shall have a protective cover, such as grass, shale,
or rock, to minimize wind and water, erosion and to preserve their
structural integrity.
3. Analysis of waste
(a) Whenever a surface impoundment is to be used for:
•
(l) Chemically treating a hazardous waste which is substantially
— different jFrom waste previously treated in that impoundment;
or
\f
(2) Chemically treating hazardous weste with a substantially
different process than any previously used in that
Impoundment; the owner or operator shall, before treating
the different waste or using the different process:
(I) Conduct waste analyses and trial treatment tests
(e.g., bench scale or pilot plant scale tests); or
(ii) Obtain documented information on similar treatment of
similar waste under similar operating conditions; to
show that this treatment wil.l comply with Item 7(b),
Part III of this document.
4. Inspections
(a) The owner or operator shall inspect:
(1) The freeboard level at least once each operating day to
ensure compliance with Item 1; and
(2) The surface impoundment, including dikes and vegetation
surrounding the dikes,at least once a week to detect any
leaks, deterioration, or failures in the impoundment.
5. Closure and post-closure
(a) At closure, the owner or operator may elect to remove from the
impoundment:
(1) Standing liquids;
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B-47
1G
(2) Waste and waste residues;
• *
* (3) The liner, If any; and
CO Underlying and surrounding contaminated soil.
(b) . If the owner or operator removes all the impoundment materials
listed in Item 5(a), or can demonstrate that none of the
materials listed in Item 5(a) remaining at any stage of removal
are hazardous wastes, the impoundment is not further subject
to the requirements of this document.
»
(cj If the owner or operator does not remove all the impoundment
materials listed in Item 5(a) or does not make the demonstration
In Item 5(b), he shall close the Impoundment and provide pose-closure
care as specified elsewhere in this document. *lf necessary
to support the final cover specified in the approved closure
plan, the owner or operator shall treat remaining liquids,
residues, and soils by removal of liquids, drying, or other means.
6. ,lgnftable or reactive wastes
(a) Ignitable or reactive waste shall not be placed in a surface
Impoundment, unless:
(1) The waste is treated, rendered, or mixed before or immediately
after placement in the impoundment so that:
(0 The resulting waste, mixture, or dissolution of
material no longer meets the definition of ignitable
or reactive waste; and
(ii) The requirements of Item 7(b), Part III pf this document
are met; or
•
(2) The surface impoundment is used solely for emergencies.
7. Incompatible wastes
Incompatible wastes, or incompatible wastes and materials, shall not
be placed in the same surface impoundment, unless the requirements of
Item 7(b), Part III of this document are met.
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47
XTM STORAGE OF CONTAINERS
I. Condition.
If a container holding hazardous waste is not in good condition, or
If It begins to teak, the owner or operator shall transfer the haz-
ardous waste from this container to a container that is in good
condition, or manage the waste in some other way that complies with
the conditions of this document.
2. Compatibility of waste.
The owner or operator shall use a container made of or lined with
materials which will not react with, and are otherwise compatible
with, the hazardous waste to be stored, so that the ability of the
container to contain the waste is not impaired.
3. Management.
(a) A container holding hazardous waste shall remain closed during
storage, except when it is necessary to add or remove waste.
(b) A container holding hazardous waste shall not be opened,
handled, or stored in a manner which might rupture the
container or cause it to leak.
k. Inspections.
The owner or operator shall inspect areas where containers are stored,
at least weekly, looking for leaks and for deterioration caused by
corrosion or other factors.
5. Ignitable or reactive waste.
Containers holding ignitable or reactive waste shall be situated at
least 15 meters (50 feet) from the property line of the facility.
6. Incompatible wastes.
(a) Incompatible wastes, or incompatible wastes and materials,
shall not be placed in the same container, unless the require-
ments of Item 7 (b). Part III of this document are met.
(b) Hazardous waste shall not be placed in an unwashed container
that previously held an incompatible waste or material unless
the requirements of Item 7 (b), Part 111 of this document are
met.
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APPENDIX C
VINE HILL HAZARDOUS WASTE FACILITY PERMIT
(EFFECTIVE SEPTEMBER 26, 1983)
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C-l
STAft OF CAUFORNIA—HEALTH AND WElFkRE AGENCY
GEORGE DEUKMEJIAN. Oovorror
DEPARTMENT OF HEALTH SERVICES
714/744 P STREET
SACRAMENTO. CA 9J814
CERTIFIED COPY
SI
Facility: IT Corporation
Vine Hill Facility
986 Waterbird Way
Martinez, CA 94533
Operator: IT Corporation
336 West Anaheim Street
Wilmington, CA 90744
GNATURE DATE '
)
) Hazardous Waste Facility Permit
)
) Number: CAD 00009^771
! Effective Date: SEP 2 6 1983
) Expiration Date:$£p 2 6 1988
)
)
)
)
)
)
)
Pursuant to Section 25200 of the California Health and Safety.. Code, this
Hazardous Waste Facility Permit is hereby granted to IT Corporation Vine
Hill Facility subject to the conditions set forth in Attachment A which
by this reference is incorporated herein.
Richard P. Wilcoxon, Chiof
Toxic Substances Control Division
/
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C-2
ATTAO-UvENT A
Hazardous Waste Facility Permit
IT Corporation Vine Hill Facility
986 Waterbird Way
Martinez, CA 94553
I. DESCRIPTION OF FACILITY
1. Ownership, Operations, and Location
IT Corporation, hereinafter called the owner and/or operator has applied to
the California State Department of Health Services for a permit authorizing
the operation of a hazardous waste facility located at 986 Waterbird Way,
Martinez, Contra Costa County. The facility operations involve storage,
treatment, and disposal of hazardous wastes. The facility consists of 28
tanks, with a total capacity of approximately 1 million gallons, used for
the storage and treatment of wastes. There are 8 surface impoundments,
with an approximate capacity of 32 million gallons, used for storage,
treatment, and disposal of wastes. Wastes are also stored in containers.
The facility also has an incinerator for certain types of waste. Accordingly,
the California State Department of Health Services has jurisdiction to issue
a permit authorizing the operation of the facility subject to the following
terms and conditions.
Conditions in this permit will apply to general was te% handling procedures
and to wastes stored and/or treated in tanks and containers. Storage,
treatment, and disposal of wastes in surface impoundments and in the
incinerator will be addressed in future amendments to this permit. .
2. Compliance with California Environmental Quality Act
This project involves the continued operation of an existing facility with
only minor alterations, and is therefore exempt from the California
Environmental Quality Act pursuant to the Section 15101, Title 14, California
Administative Code.
II. GENERAL CONDITIONS
1. Effect of Permit
The owner or operator is permitted to store, treat, and dispose hazardous
wastes in accordance with the conditions of this permit. Any treatment,
storage or disposal of hazardous wastes not authorized in this permit is
prohibited. Compliance with this permit constitutes compliance, for purposes
of enforcement, with the provisions of the California Health and Safety
Code, including Chapter 6.5, Division 20, and with the minimum Standards
for Management of Hazardous and Extremely Hazardous Wastes (Chapter
30, Division 4, Title 22, California Administrative Code). Issuance of this
permit does not convey property rights of any sort or any exclusive privilege,
nor does it authorize any injury to persons or property, any invasion of
other private rights, or any infringement of federal, state, or local law or
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C-3
regulations. Compliance with the terms of this permit does not constitute
a defense to any action brought under any other law governing protection
of public health or the environment for any imminent and substantial
endangerment to human health or the environment.
2. Permit Actions
This permit may be modified, revoked and reissued, or terminated for cause
as specified in Sections 122.15, 122.16, and 122.17, Title 40, Code of Federal
Regulations (CFR), or at the discretion of the California State Department
of Health Services in order to protect public health or the environment. A
new facility permit condition or a modification of an existing facility permit
condition shall become effective on the date that written notice of such
change is received by the owner or operator. The filing of a request for
a permit modification, revocation and reissuance, or terminntion or tin;
modification of planned changes or anticipated noncompliance on any part
of the owner or operator does not stay the applicability or enforceability
of any permit condition.
3. Need t£ Halt £T Reduce Activity
It shall not be a defense for the owner or operator in an enforcement action
that it would have been necessary to halt or reduce the permitted activity
in order to maintain compliance with the conditions of this permit.
4. Severability
The provisions of this permit are severable, ;ind if any provision of this
permit or the application of any provision of this permit to any circumstance
is held invalid, the application of such provision to other circumstances and
the remainder of this permit shall not be affected thereby.
5. Operation Plan
The owner or operator must submit to the California State Department of
Health Services an operation plan. By the issuance of this permit, this
operation plan, dated March 14, 1983, and its amendments, is hereby
approved. The plan shall be maintained at the facility at all times until
closure is completed. This operation plan and any subsequent revisions
thereof, subject to the approval of the California State Department of
Health Services, are by this 'reference made part of this permit. Specific
sections of the operation plan are referenced elsewhere in this permit.
6. General Responsibilities o_f_ Operator
(a) Compliance
The owner or operator shall comply with all conditions of this permit,
except to the extent and for the duration such noncompliance is
authorized by an emergency permit. Any permit noncompliance
constitutes grounds for enforcement action, permit termination,
revocation and reissuance, modification, or for denial of a permit
renewal application.
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(b) Keapplication
If the owner or operator wishes to continue an activity regulated by
this permit after the expiration date of this permit, the owner or
operator must submit a completed application for a new permit at
least 180 days before this permit expires.
(c) Permit Expiration
This permit and all conditions therein will remain in effect beyond
the permit expiration or termination date if the owner or operator
has submitted a timely, completed application and, through no fault
of the owner or operator, the California State Department of Health
Services has not issued a new permit.
(d) Mitigation
The owner or operator shall take all reasonable steps to minimize or
correct any adver1' impact on the environment resulting from non-
compliance with t permit.
(e) Operations and Maintenance
The owner or operator shall at all times properly operate and maintain
all facilities of treatment and control (and related appurtenances)
which are installed or used by the owner or operator to achieve
compliance with the conditions of this permit. Proper operation and
maintenance includes effective performance, adequate funding, ade-
quate operator staffing and training, and adequate laboratory and
process controls, including appropriate quality assurance procedures.
This provision requires the operation of back-up or auxiliary facility
or similar systems only when necessary to achieve compliance with
the conditions of the permit.
(f) Submittal of_ Requested Information
The owner or operator shall furnish to .the California State Department
of Health Services, within a reasonable time, any relevant information
which the California State Department of Health Services may request
to determine whether cause exists for modifying, revoking, and
reissuing, terminating this permit, or to determine compliance with
this permit. The owner or operator shall also furnish to the California
State Department of Health Services,'upon request, copies of records
required to be kept by this permit.
(g) Inspection and Entry
The owner or operator shall allow authorized representatives of the
California State Department of Health Services or the local health
agency, upon the presentation of credentials and other documents as
may be required by law to:
(1) Enter at reasonable times upon the owner's or operator's premises
- 3 -
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C-5
where a regulated facility or activity is located or conducted,
or where records must be kept under the conditions of this permit;
(2) Have access to and copy, at reasonable times, any records th.it
must be kept under the conditions of this permit;
(3) Inspect at reasonable times any facilities, equipment (including
monitoring and control equipment), practices, or operations
regulated or required under this permit; and
(4) Sample or monitor, at reasonable times, for the purposes of
assuring permit compliance or, as otherwise authorized by law,
any substances or parameters at any location.
(h) Monitoring and Records
(1) Samples and measurements taken for the purpose of monitoring
shall be representative of the monitored activity. The method
used to obtain a representative sample of the waste to be analyzed
must be the appropriate method from Appendix 1 of 40 CFR
Part 261. Laboratory methods must be those specified in the
approved operation plan.
(2) The owner or operator shall retain records of all monitoring
information, including all calibration and maintenance records
and all original strip chart recordings for continuous monitoring
instrumentation, copies of all reports and records required by
this permit, and records of all data use.d to complete the
application for this permit for a period of "at least three years
from the date of the sample, measurement, report, or record.
These periods may be extended by request of the regional
administrator at any time and are automatically extended during
the course of any unresolved enforcement action regarding this
facility.
(3) Records of monitoring information shall include:
(i) The date, exact place, and time of sampling or measure-
ments;
(ii) The individual(s) who performed the sampling or measure-
ments;
(iii) The date(s) analyses were performed;
(iv) The individual(s) who performed the analyses;
(v) The analytical techniques or methods used; and
(vi) The results of such analyses.
(i) Planned Changes
The owner or operator shall give notice to the California State
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Department of Health Services, as soon as possible, of any planned
physical alterations or additions to the permitted facility.
(j) Anticipated Noncompliance
The owner or operator shall give advance notice to the California
State Department of Health Services of any planned changes in the
permitted facility or activity which may result in noncompliance with
permit requirements.
(k) 24-Hour Reporting
The owner or operator shall report to the California State Department
of Health Services any noncompliance which may enrianqer health or
the environment. Any information shall be provided verbally within
24 hours from the time the owner or operator becomes aware of the
circumstances. The following shall be included as information which
must be reported verbally within 24 hours:
(1) Information concerning release of any hazardous waste that may
cause an endangerment to public drinking water supplies.
(2) Any information of a release or discharge of hazardous waste,
or of a fire or explosion from the facility, which could threaten
the environment or human health outside the facility. The
description of the occurrence and its cause shall include:
(i) Name, address, and telephone number of the owner or
operator;
(ii) Name, address, and telephone number of facility;
(iii) Date, time and type of incident;
(iv) Name and quantity of material(s) involved;
(v) The extent of injuries, if any;
(vt) An nssessment of actual or potential hazard to the
environment and human health outside the facility, where
this is applicable; and
(vii) Estimated quantity and disposition of recovered material
that resulted from the incident.
A written submission shall also be provided within five days of
the time the owner or operator becomes aware of the cir-
cumstances. The written submission shall contain a description
of the noncompliance and its cause; the periods of noncompliance
(including exact dates and times), and if the noncompliance has
not' been corrected, the anticipated time it is expected to
continue; and steps taken or planned to reduce, eliminate, and
prevent reoccurrence of the noncompliance.
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The owner or operator need not comply with the 5-day written
requirement if the California State Department of Health Services
waives that requirement and the owner or operator submits a
written report within 15 days of the time the owner or operator
becomes aware of the circumstances.
(1) Other Noncompliance
The owner or operator shall report all other instances of noncompliance
not otherwise required to be reported at the time monitoring or other
reports are submitted. The reports shall contain the information listed
in II.6 (k) above.
(m) dther Information
Where the owner or operator becomes aware that he failed to submit
any relevant facts in the permit application or submitted incorrect
information in a permit application or any report submitted to tho
California State Department of Health Services, the owner or operator
shall promptly submit such facts or information.
(n) Air Pollution Permits
The owner or operator shall obtain a permit to operate from the Bay
Area Air Quality Management District to the extent required by district
rules, and shall comply with the conditions and restrictions of that
permit.
7. Signatory Requirement *• -
All reports or other information requested by the California State Department
of Health Services shall be signed by the owner or operator or the
corporations' principal executive officer or, at least, the level of vice
president. The person signing the document shall make the following
certification:
"I certify under penalty of perjury, that I have
oersonally examined and am familiar with the
information submitted in this document and all
attachments and that, based on my inquiry of those
individuals immediately'responsible for obtaining the
information, I believe that the information is true,
accurate, and complete. I am aware that there are
significant penalties for submitting false information,
including the possibility of fine and imprisonment."
8. Certification of Construction
The owner or operator may not commence treatment, storage, or transfer
of hazardous wastes in a modified portion of the facility until:
(a) The owner or operator has submitted to the California State Department
of Health Services by certified mail or hand delivery a letter signed
by the owner or operator and an appropriate engineer registered in
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California stating that the facility has been constructed in compliance
with the permit; and
(b) (1) The California State Department of Health Services has inspected
the constructed facility and finds it is in compliance with the
conditions of the permit; or
(2) The California State Department of Health Services has either
waived the inspection or has not within 15 days notified the
owner or operator of his or her intent to inspect.
9. Transfer £f Permit
This permit may be transferred to a new owner or operator only if it is
modified or revoked and reissued pursuant to Sectign 122.15 (b) (2) or 122.17
(d), Title 40, CFR. The owner or operator shall notify the California State
Department of Health Services of a proposed change in ownership of the
facility at least 30 days prior to the date of the transfer. Furthermore,
before transferring ownership or operation of this facility during its operating
life, the owner or operator shall notify the new owner or operator in writing
of the requirements of this permit and the permitting process. A copy of
this notification shall be submitted to the California State Department of
Health Services.
10. Compliance Schedules
Reports of compliance or noncompliance with, or any reports on, interim
and final requirements contained in any compliance schedule of this permit
shall be submitted no later than 14 days following eacti scheduled date.
11. Records
(a) The owner or operator shall maintain at his place of business and at
the facility, until closure is completed and certified by an independent
registered engineer in California so as to be available at all times to
operating personnel, the following documents and amendments, revisions
and modifications to these documents^
(1) Waste Analysis Plan
(2) Contingency Plan
(3) Closure Plan
(4) Personnel Training Documents and Records
(5) Cost Estimate for Facility Closure
(6) Operating Record
(7) Inspection Schedules
All amendments, revisions, and modifications to any plan or cost
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estimates required by this permit shall be subject to the approval of
the California State Department of Health Services.
(b) The owner or operator shall maintain a copy of this permit at his
place of business and at the facility so as to be available at all times
to operating personnel.
12. Surface Impoundments and Incinerator
Conditions contained in Interim Status Document Number CAD GOOD 94771,
issued to the owner/operator by the California State Department of Health
Services on April 6, 1981, which apply to this facility's surface impoundments
and incinerator will remain in effect until this permit is amended to include
the surface impoundments and incinerator.
13. References and Terminology
All parts in this permit are identified by Roman numerals. The items set
forth in each part shall apply to the owner, operators, and/or facility in
addition to the items set forth in any proceeding and/or'following part of
this permit. Unless explicitly stated otherwise, all cross reference to items
in this permit shall refer only to items occuring within the same part.
III. SPECIAL CONDITIONS
1. Hazardous Waste List
The owner or operator shall maintain current, the list of hazardous wastes
that can be accepted by the facility presented in the approved operation
plan. Additions to the list must first be approved by the California State
Department of Health Services.
2. Wastes Prohibited
Hazardous wastes described below shall not be handled at the facility:
(a) Extremely hazardous wastes as defined in Sections 66064 and 66685,
Title 22, California Administrative Code, unless specifically approved
by a written permit from the. California State Department of Health
Services.
(b) Forbidden and Class A explosives as defined in Section 173.51 and
173.53, Title 49, CFR.
(c) Any hazardous waste not listed in the approved-operation plan.
3. Maintenance and Operation of Facility
The facility shall be maintained and operated to minimize the possibility
of a fire, explosion, or any unplanned sudden or nonsudden release of
hazardous waste or hazardous waste constituents to air, soil, or surface
water which could threaten human health or the environment.
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4. Transfer of^ Wastes
All equipment, pipes, and lines used at the facility to handle, transfer,
pump, or store hazardous wastes shall be maintained in a manner that
prevents the leaking and spilling of hazardous waste;;.
5. Operation at_ Night
When the facility is operated during hours of darkness, the owner or operator
shall provide sufficient lighting to ensure safe, effective management of
hazardous wastes.
6. Required Notice
(a) If the owner or operator has arranged to receive hazardous waste from
a foreign source, he shall notify the California State Department of
Health Services in writing at least four weeks in advance of the date
that the waste is expected to arrive at the facility. Notice of
subseguent shipments of the same waste from the same foreign source
is not required.
(b) When the owner or operator receives hazardous waste from an off-site
source, he must inform the generator in writing that he has the
appropriate permit(s) for, and will accept, the waste the generator is
shipping. The owner or operator shall keep a copy of this written
notice as part of the operating record.
7. Analysis of^ Waste
(a) Upon the effective date of this permit, the owner or operator shall
follow the written waste analysis plan as described in the approved
operation plan.
(b) Before the owner or operator treats or stores or disposes of a particular
type of hazardous waste for the first time, he shall obtain a detailed
chemical and physical analysis of a representative sample of the waste.
At a minimum, this analysis shall contain all the information which
must be known to treat or store the waste in accordance with the
conditions of this permit.
(c) The analysis may include data developed for other purposes, and existing
published pr documented data on the hazardous waste or on waste
generated from similar processes.
(d) The analysis shall be repeated, as necessary, to ensure that it is
accurate and up-to-date. At a minimum, the analysis must be repeated
when the owner or operator is notified or has reason to believe that
the process operation generating the hazardous waste has changed.
(e) The owner or operator shall verify its waste analysis as part of the
quality assurance program. The quality assurance program will be in
accordance with current U.S. Environmental Protection Agency (EPA)
practices (test methods for evaluating solid waste: physical/chemical
methods SW-B46 dated July 1982) or equivalent methods approved by
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the California State Department of Health Services; and nt a minimum
ensure that the owner/operator maintain proper functional instruments,
uses approved sampling and analytical methods, assures UK: v.-ilidity of
sampling and analytical procedures, and performs correct calculations.
8. Security
(a) The perimeter of the hazardous waste area of the facility shall be
secured by a well-maintained fence capable of preventing the intrusion
of livestock and of discouraging entry by unauthorized persons.
(b) The owner or operator shall maintain the following to control entry
at all times to the active portion of the facility:
(1) A 24-hour surveillance system which continuously monitors and
controls entry; or
(2) An artificial and/or natural barrier which completely surrounds
the active portion of the facility and which has a means to
control entry, at all times, through the gates or other entrances
to the active portion of the facility.
.(c) Signs indicating that the facility, or the hazardous waste area of the
facility, contains hazardous waste shall be placed on the perimeter
fence and at locations where it is anticipated that hunters and other
trespassers may enter the facility.
Wording of the signs shall be in tnglish, "Cautmn-Ha^ardous Wastu
Area-Unauthorized Persons Keep Out", and Spanish,-"Cuidado! Zona de
Residues Peligrosos. Prohibida la Entrada a Personas No Autorizadas."
Signs shall be legible from a distance of 25 feet.
9. Inspections
(a) The owner or operator shall inspect the facility for malfunctions and
deterioration, operator errors, and discharges which may be causing
--or may lead to -- release of hazardous waste constituents to the
environment or a threat to human health. The owner or operator shall
conduct these inspections often enough to identify problems in time
to correct them before they harm human health or the environment.
(b) (1) The owner or operator shall follow the written schedule for
inspecting all monitoring equipment, safety and emergency
equipment, security devices, and operating and structural
equipment (such as dikes • and pumps) that are important to
preventing, detecting, or responding to environmental or human
health hazards as described in the approved operation plan.
(2) He shall keep this schedule at the facility.
(c) The owner or operator shall remedy any deterioration or malfunction
of equipment or structures which the inspection reveals on the schedule
as described in the approved operation plan and which shall ensure
that the problem does not lead to an environmental or human health
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hazard. Where a hazard is imminent or has nlnvuly ocmrrivl, rumr-duil
action shall be taken irninediately.
(d) The owner or operator shall record inspections in ;in in::pi'cl.ion lotj in-
summary and shall keep these records for at least three years from
the date of inspection.
10. Personnel Training
(a) Facility personnel shall successfully complete the program of classroom
instruction or on-the-job training as described in the approved operation
plan.
(b) This program shall be directed by a person trained in hazardous waste
management procedures.
(c) Facility personnel shall have successfully completed the program
required in Item 10 (a) by the effective date of this permit or within
six months after the date of their employment or assignment to a
facility or to a new position at the facility whichever is later.
Employees hired after the effective date of this permit shall not work
in unsupervised positions until they have completed the training
requirements of Item 10 (a).
(d) Facility personnel shall take part in an annual review of the initial
training required in Item 10 (a).
(e) The owner or operator shall maintain the following documents and
records at the facility:
(1) The job title for each position at the facility related to hazardous
waste management and the name of the employee filling each
job;
(2) A written job description for' each position listed under Item 10
(s) (1). This description may be consistent in its degree of
specificity with descriptions for other similar positions in the
same company location or bargaining unit but shall include the
requisite skill, education, or other qualifications and duties of
facility personnel assigned to each position;
(3) A written description of the type .and amount of both introductory
and continuing training that will be given to each person filling
a position listed under Item 10 (e) (I); and
(4) Records that document that the training or job experience
required under Items 10 (a), (b), (c), and (d) has been given to
and completed by facility personnel.
(f) Training records on current personnel as required in Itpm 10 (e) (4)
shall be kept until closure of the facility. Training records on former
employees shall be kept for at least three years from the date the
employee last worked at the facility. Personnel training records may
accompany personnel transferred within the same company.
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11. Management of_ iqnitable, Reactive, or Incompatible Wastes
(a) The owner or operator shall take precautions to prevent accidental
ignition or reaction of ignitable or reactive wastes. This waste shall
be separated and protected from sources of ignition or reaction. While
ignitable or reactive waste is being handled, the owner or operator
shall confine smoking and open flame to specially designated locations.
"No Smoking" signs shall be conspicuously placed wherever there is a
hazard from ignitable or reactive waste.
(b) The treatment, storage, or ;posal of ignitable or reactive waste, and
the mixture or commingling of incompatible wastes, or incompatible
wastes and materials shall be conducted so that it does not:
(1) Generate extreme heat or pressure, fire or explosion, or violent
reaction;
(2) Produce uncontrolled toxic mists, fumes, dusts, or gases in
sufficient quantities to threaten human health or the environment;
(3) Produce uncontrolled flammable fumes or gases in sufficient
quantities to pose a risk of fire or explosions;
(4) Damage the structural integrity of the device or facility
containing the waste; or
(5) Through other like means threaten human health or the en-
vironment.
«
(c) When required to comply with Items 11 (a) and (b), Part III of this
permit, the owner or operator must document that compliance.. This
documentation may be based on references to published scientific or
engineering literature, data from trial tests, waste analyses, or the
results of the treatment of similar wastes by similar treatment
processes and under similar operating conditions.
(d) The following incompatible hazardous waste groups shall be adequately
separated from each other during all handling and storage operations:
(1) Alkalies and cyanides;
(2) Acids;
(3) Strong oxidizers;
(4) Toxic wastes, pesticides, and flammable wastes.
12. Location Standards
(a) The owner or operator shall not store hazardous wastes within 61
meters (200 feet) of a fault which has had displacement in the last
11,000 years. (New facilities or modification to existing facilities
only.)
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(b) The owner or operator shall ensure that the facility is designed,
constructed, operated, and maintained to prevent washout of any
hazardous waste by a 100-year flood or that the wastes can be removed
safely, before flood waters reach the facility, to a location where the
wastes will not be vulnerable to flood waters.
13. Required Equipment
i
(a) Upon the effective date of this permit, the owner or operator shall
have available at the facility all required safety and emergency
equipment as described in the approved operations plan.
'b) The facility water supply system shall be capable of providing water
in adequate volume and pressure to maintain water hose streams.
(c) Owner or operator shall maintain access to communication or alarm
system specified in the approved operation plan.
14. Testing and' Maintenance £f Equipment
All facility communications or alarm systems, fire protection equipment,
spill control equipment, and decontamination equipment shall be tested and
maintained as necessary to ensure its proper operation in time of emergency.
15. Required A hie Space
The owner or operator shall maintain aisle space as needed to allow the
unobstructed movement of personnel, fire protection equipment, spill control
equipment, and decontamination equipment.
16. Arrangements v.'ith Local Authorities
(a"! Upon the effective date of this permit, all emergency response
arrangements made by the facility with local authorities as described
in the approved operation plan shall have been effected.
(b) If local authorities refuse to enter into preparedness and prevention
arrangements with the owner or operator, the owner or operator shall
document this refusal in the operating record.
17. Contingency Plan
(a) Maintenance
Upon the effective date of this- permit, the owner or operator shall
, follow the contingency plan described in the approved operation plan.
(b) Distribution
A copy of the contingency plan and all revisions to the plan shall be:
(1) Maintained at the facility; and
(2) Submitted to all local police departments, fire departments,
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hospitals, and state and local emergency response teams that
may be called upon to provide emergency services.
(c) Implementation
The provisions of the contingency plan shall be carried out immediately
wherever there is a fire, explosion, or release of hazardous waste or
hazardous waste constituents which could threaten human health or
the environment.
(d) Amendment o_f_ Contingency Plan
The contingency plan shall be reviewed and immediately amended, if
necessary, whenever:
(1) Applicable regulations are revised;
(2) The plan fails in an emergency;
(3) Whenever the permit is revised;
(4) The list of emergency coordinators changes; or
(5) The list of emergency equipment changes; and
(6) The owner or operator shall submit to the California State
Department of Health Services within 30 days any proposed
amendments to the contingency plan.
(e) Emergency Coordinator
At all times there shall be at least one employee either on the facility
premises or on call (i.e., available to respond to an emergency by
. reaching the facility within n short period of time) with the re-
sponsibility for coordinating all emergency response measures. This
emergency coordinator shall be thoroughly familiar with all aspects of
the facility's contingency plan, all operations and activities at the
facility, the location and characteristics of waste handled, the location
of all records within the facility, and the facility layout. In addition,
this person shall have the authority to commit the resources needed
to carry out the contingency plan.
(f) Emergency Procedures
(1) Whenever there is an imminent or actual emergency situation,
the emergency coordinator (or his designee when the emergency
coordinator is on call) shall follow the procedures of the
contingency plan as described in the approved operation plan.
(2) The owner or operator shall notify the California State
Department of Health Services and local authorities that the
cleanup procedures are complete and all emergency equipment
listed in the contingency plan is clean and fit for its intended
use before operations are resumed.
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(3) The owner or operator shall note in the operating record the
time, date, and details of any incident that required implementimj
the contingency plan.
(4) The owner or operator shall report each incident to the California
State Department of Health Services in accordance with the
24-hour reporting requirement contained in II.6 (k) of this permit.
18. Manifest System
(a) The owner or operator shall:
(1) Require that a manifest be completed for all hazardous waste
accepted;
(2) Inspect wastes before accepting them to ensure that the delivered
waste has essentially the same general properties as identfied by
the generator on the manifest;
(3) Complete the appropriate section of the manifest;
(4) Sign and date each copy of the manifest to certify that the
hazardous waste covered by the manifest was received;
(5) Note any significant discrepancies in the manifest on each copy
of the manifest;
(6) Immediately give the transporter at least one copy of the signed
manifest; ' ~
(7) Send legible copies of all completed hazardous waste manifests
to the California State Department of Health Services on a
monthly basis in conformance with Section 66550, Title 22,
California Administrative Code;
(8) Within 30 days after delivery, send a copy of the manifest to
the generator;
(9) Retain at the facility a copy of each manifest for at least three
years from the date of delivery.
(10) Submit to the California State Department of Health Services
by the last day of each month information on the hazardous
waste delivered to him during the previous month consisting of
a legible copy of the completed manifest for each load of
hazardous wastes accepted, and a report that summarizes the
numbers of loads of hazardous wastes received;
(b) Manifest Discrepancies
(1) Upon discovering a significant discrepancy between the quantity
or type of hazardous waste designated on the manifest and the
quantity or type of hazardous waste the facility actually receives,
the owner or operator shall attempt to reconcile the discrepancy
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with the waste generator or transporter (e.g., with telephone
conversations). Significant discrepancies in quantity are:
(i) For bul'< waste, variations greater than ten percent in
weight; and
(ii) For batch waste, any variation in piece count such as a
discrepancy of one drum in a truckload.
(2) Significant discrepancies in type are obvious differences which
can be discovered by inspection or waste analysis such as waste
solvent substituted for waste acid or toxic constituents not
reported on the manifest. If the facility can accept the waste
after its actual identity is revealed, the owner or operator may
accept the waste.
If the facility cannot accept the waste, the owner or operator
shall immediately notify the California State Department of
Health Services of that fact, identify the transporter and
generator of the waste, and refuse to accept the waste. If the
owner or operator can accept the waste, he shall note on the
copy of the manifest which he submits to the California State
Department of Health Services and on the copy which he retains
how the discrepancy was resolved. If the discrepancy is not
resolved within 15 days after receiving the waste, the owner or
operator shall immediately submit to the California State Depart-
ment of Health Services a letter describing the discrepancy and
attempts to reconcile it and a copy of th£ manifest at issue.
(c) Unmanifested Wastes
If the facility receives for treatment or storage, any hazardous waste
from an off-site source without nn accompanying manifest, and a
manifest is prepared on the spot after load verification, waste analysis,
etc., to comply with 18 (a) (1), the owner or operator shall prepare
ami submit a single copy of a report to the California State Department
of Health Services within 15 days after receiving the waste. If the
facility rejects an unrnanifested load, the same reporting requirement
shall apply.
The report shall include the following information:
(1) The EPA identification number, name, and address of the facility;
(2) The date the facility received/rejected the waste;
(3) The EPA indentification number, name, and address of the
generator and the transporter, if available;
(4) The description and quantity of each unmanifested hazardous
waste the facility received/rejected;
(5) The method of treatment, storage, or disposal for each hazardous
waste;
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(6) The certification signed by the owner or operator of the facility
or his authorized representative; and
(7) A brief explanation of why the waste was unmanifested, if known.
19. Recordkeeping and Reporting
(a) Availability, Retention, and Disposition of Records
(1) All records including plans, required in this permit shall be
furnished upon request, and made available at all reasonable times
for inspection, by any officer, employee, or representative of the
California State Department of Health Services.
(2) The retention period for all records required in this permit is
extended automatically during the course of any unresolved
enforcement action regarding the facility or as requested by the
California State Department of Health Services.
(b) Operating Record
(1) The owner or operator shall keep a written operating record at
the facility.
The following information shall be recorded, as it becomes
available, and maintained in the operating record until closure
of the facility:
(i) A description and the quantity of each hazardous waste
received, and the method(s) and date(s) of its treatment or
storage at the facility;
(ii) The location of each hazardous waste within the facility
and the quantity at each location. This information shall
include cross-references to specific manifest document
numbers, if the waste was accompanied by a manifest;
(iii) Records and results of waste analyses and trial tests
performed;
(iv) Summary reports and details of all incidents that require
implementing the contingency plan;
(v) Records and results of inspections (except these data need
be kept only three years);
(vi) Required monitoring, testing, or analytical data; and
(vii) All closure cost estimates.
(c) Annual Report
The owner or operator shall prepare and submit a single copy of an
annual report to the California State Department of Health Services
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by March 1 of each year beginning March 1, 1984. The .innual report
shall cover facility activities during the previous calendar year and
shall include the following information:
(1) The EPA identification number, name and address of the facility;
(2) The calendar year covered by the report; .
(3) The EPA or California State Department of Health Services
identification number of each hazardous waste generator from
which the facility received a hazardous waste during the year;
for imported shipments, the report shall give the name and address
of the foreign generator; and
(4) The description quantity and method of treatment, storage, and
disposal of each hazardous waste the facility received during the
year, listed by EPA or California State Department of Health
Services identification number of each generator.
(d) Additional Reports
In addition to submitting the annual report required in Item 19 (c),
the owner or operator shall also report to the California State
Department of Health Services:
(1) Releases, fires, and explosions; and
(2) Facility closure.
20. Closure
(a) Closure Plan and Amendment £f_ Plan
(1) The owner or operator shall comply with the closure plan as
described in the approved operation plan.
(2) The owner or operator may amend his closure plan at any time
during the active life of the facility. (The active life of the
facility is that period during which wastes are periodically
received.) The owner or operator shall amend his plan any time
changes in operating plans or facility design affect the closure
plan.
(3) The owner or operator shall submit to the California State
Department of Health Services within 30 days any proposed
amendments made to the closure plan.
(4) The owner or operator shall notify the California State Depart-
ment of Health Services at least 180 days before the date he
expects to begin closure.
(b) Time Allowed for Closure
(1) Within 90 days after receiving the final volume of hazardous
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C-20
wastes, the owner or operator shall treat all hazardous wastes
in storage or in treatment or remove them from the site in
accordance with the approved closure plan.
(2) The owner or operator shall complete closure activities in
accordance with the approved closure plan and within six months
after receiving the final volume of wastes.
(c) Disposal or Decontamination of_ Equipment
When closure is completed, all facility equipment and structures shall
have been properly disposed of or decontaminated by removing all
hazardous waste and residues.
(d) Certification of Closure
When closure is completed, the owner or operator shall submit to the
California State Department of Health Services certification both by
the owner or operator and by an independent engineer registered in
California that the facility has been closed in accordance with the
specifications in the approved closure plan.
21. Financial Responsibility
(a) Cost Estimate for Facility Closure
(1) The owner or operator shall have a written estimate of the cost
of closing the facility in accordance with the applicable closure
requirements of this permit. The owner or operator shall keep
this estimate, and all subsequent estimates, at the facility. The
estimate shall equal the cost of closure at the point in the
facility's operating life when the extent and manner of its
operation would make closure the most expensive as indicated
by its closure plan.
(2) The owner or operator shall prepare a new closure cost estimate
whenever a change in the closure, plan affects the cost of closure.
(3) On each anniversary of the effective date of this permit, the
owner or operator shall adjust the latest closure cost estimate
using an inflation'factor derived from the annual Implicit Price
Deflator for Gross National Produce as published by the U.S.
Department of Commerce in' its SURVEY OF CURRENT
BUSINESS. The inflation factor shall be calculated by dividing
the latest published annual Deflator by the Deflator for the
previous year. The result is the inflation factor.
The adjusted closure cost estimate shall equal the latest closure
cost estimate times the inflation factor.
(4) The adjusted closure cost estimate shall be submitted to the
California State Department of Health Services as part of the
annual report required in III 19 (c).
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(b) Financial Assurance for Facility Closure
The permittee shall demonstrate continuous compliance with 40 CFR
264.143 and .145 or where applicable with 40 CFR 264.145, .149, .150,
and .151 by providing documentation of financial assurance in at least
the amount of the cost estimates required by permit condition III 21
(a).
(c) An owner or operator who fulfills the requirements of III 21 (b) by
obtaining a letter of credit, surety bond, or insurance policy will be
deemed to be without the required financial assurance in the event
of a bankruptcy, insolvency, or a suspension or revocation of the license
or charter of the issuing institution. The owner or operator must
establish other financial assurance within 60 days of such events.
(d) The owner or operator shall comply with all other financial res-
ponsibility and facility closure requirements of the California State
Department of Health Services when enacted.
IV. STORAGE OF WASTES
1. General Conditions
(a) Hazardous waste shall not be stored at the facility for longer than
one year without written approval from the California State Department
of Health Services.
(b) If a hazardous waste is stored at the facility longer than one year,
the owner or operator shall submit to the California State Board of
Equilization fees due and payable in con form an ce with Chapters 1-8,
Part 22, Division 2, Revenue and Taxation Code and with Article 8,
Chapter 30, Division 4, Title 22, California Administrative Code.
2. Storage m Containers
(a) Conditions
%
\1) Containers used for storing hazardous waste shall be in a condition
such that the containers can be safely transported, handled, or
moved.
(2) If a container holding hazardous waste is not in good condition,
or if it begins to leak, the owner or operator shall transfer the
hazardous waste from this container to a container that is in
good condition, or manage' the waste in some other way that
complies with the conditions of this permit.
(b) Compatibility of Waste
(1) The. owner or operator shall use a container made of or lined
with materials which will not react with, and are otherwise
compatible with, the hazardous waste to be stored, so that the
ability of the container to contain the waste is not impaired.
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'2) Areas used for storing containers of hazardous waste shall be
widely separated, or physical barriers shall be provided to ensure
that commingling of incompatible hazardous wastes cannot occur
if a container ruptures.
'cl Management
'T! Containers holding hazardous wastes shall be stored only in the
area designated in the approved operation plan.
'2) A container holding hazardous waste shall remain closed during
storage, except when it is necessary to add or remove waste.
^3) A container holding hazardous waste shall not be opened, handled,
or stored in a manner which might rupture the container or cause
it to leak.
(4) A label shall be maintained on all containers in which hazardous
wastes are stored for 90 days or more and records for the storage
of all hazardous wastes shall he maintained pursuant to Section
66545, Title 22 of the California Administrative Code. Labels
shall include the following information:
(P Composition and physical state of the waste;
(ii) Special safety recommendations and precautions for handling
the waste;
(iiO Statement or statements which call-attention to the
particular hazardous properties of the waste;
'iv) Amount of waste and name and address of the person
producing the waste; and
(v^ Date of acceptance at the storage facility.
•*>} Empty containers contaminated with hazardous materials shall be
stored, handled, and processed as hazardous wastes.
(6) The total number of containers storing hazardous waste in a
storage area shaH not exceed the design capacity at any one
time.
(dl Inspections
The owner or operator shall inspect areas where containers are stored
in accordance with the written inspection schedule of the approved
operation plan.
fe) Containment
The owner or operator shall provide a spill containment system in
accordance with the approved operation plan. Specifically, each
hazardous waste storage area shall have a continuous base that is
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C-23
impervious to the waste stored and shall be designed and constructed
so that any surface water runoff or spills can be contained, and surface
water runon can be excluded. The containment system shall have
sufficient capacity to contain ten percent of the volume of containers
or the volume of the largest container, whichever is greater.
(f) Iqnitable p_r Reactive Waste
Containers holding ignitable or reactive waste shall be situated at
least 15 meters (50 feet) from the property line of the facility.
(g) Incompatible Waste
(1) Incompatible wastes, or incompatible wastes and materials, shall
not be placed in the name container, unions the riM]uirrmont.s of
Item 11 (b), Part III of this permit are met.
(2) Hazardous waste shall not be placed in an unwashed container
that previously held an incompatible waste or material unless the
requirements on Item 11 (b), Part III of this' permit are met.
(3) A storage container holding a hazardous waste that is incompatible
with any waste or material stored nearby in other containers,
shall be separated from the other materials or protected from
them by means of a berm.
(h) Closure
The owner or operator shall close the container storage area in
compliance with the approved closure plan.
3. Storage m Tanks
(a) Design of_ Tanks
(1) The owner or operator shall construct all tanks in accordance
with the approved operation plan.
(2) The owner or operator shall maintain the minimum shell thickness
specified in the approved operation plan at all times to ensure
sufficient shell strength.
(3) Prior to use, new, replacement, and repaired hazardous waste
storage tanks and their appurtenances shall be certified by an
engineer registered in California to be structurally sound and of
adequate construction for the intended use.
(4) Each hazardous waste storage tank and storage area shall be
individually marked with the internationally recognized hazard
identification system placards developed by the National Fire
Prevention Association or the tanks and storage areas may be
marked with U.S. Department of Transportation placards in
appropriate locations as recommended by the local fire authority.
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(5) The total volume of hazardous wastes stored in tanks shall not
exceed the design capacity at any one time.
(b) Operation
(1) Storage of hazardous waste in tanks shall comply with Items 11
(b), Part III of this permit.
(2) Hazardous wastes shall not be placed in a tank if they could
cause the tank or its inner liner to rupture, leak, corrode, or
otherwise fail before the end of its intended life.
(,3) Uncovered tanks shall be operated to ensure at least 60
centimeters (2 feet) of freeboard.
(4) Valves on hazardous waste storage tanks shall be kept locked
when the facility is unattended.
(c) Analysis of_ Waste and Trial Tests
If a tank is to be used for storing a hazardous waste which is
substantially different from waste previously stored in the tank, the
owner or operator shall:
(1) Conduct waste analyses and trial treatment or storage tests (e.g.,
bench scale or pilot plant scale tests) to document that this
proposed treatment or storage will comply with Items 3 (b) (1)
and (2); or
(2) Obtain written information on similar storage or treatment of
similar waste under similar operating conditions to document that
this proposed treatment or storage will comply with Items 3 (b)
(1) and (2).
(d) Inspections
In accordance with the written inspection schedule in the approved
operation plan, the owner or operator shall inspect:
(1) Discharge control equipment, at least once each operating day,
to ensure that it is in good working order;
(2) Data gathered from monitoring equipment, at least once each
operating day, to ensure that the tank is being operated according
to its design;
(3) The level of waste in the tank, at least once each operating day,
to ensure compliance with Item 3 (b) (3);
(4) The construction materials of the tank, at least weekly, to detect
corrosion or leaking of fixtures or seams;
(5) The shell thickness of all tanks to determine extent of corrosion.
If excessive corrosion has occurred (readings indicate a difference
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of ten percent over readings taken before waste was first placed
in the tank), the tank shall be emptied, cleaned, inspected, and
corrective actions undertaken; and
(6) The construction materials of, and the area immediately sur-
rounding, discharge confinement structures, at least weekly, to
detect obvious signs of leakage.
(e) Closure
At closure, all hazardous waste and hazardous waste residues shall be
removed from tanks, discharge control equipment, and discharge
confinement structures in accordance with the approved closure plan.
(f) Iqnitable or Reactive Waste
(1) Ignitable or reactive waste shall not be placed in a tank, unless:
(a) The waste is treated, rendered, or mixed before or
immediately after placement in the tank so that the
resulting waste, mixture, or dissolution of material is no
longer ignitable or reactive and Item 11 (b), Part III of this
permit is complied with; or
(b) The waste is stored in such a way that it is protected from
any material or condition which may cause the waste to
ignite or react; or
(c) The tank is used solely for emergencies.-
(2) If the owner or operator stores ignitable or reactive waste in
covered tanks, he shall comply with the National Fire Protection
Association's buffer zone requirements for tanks, contained in
Tables 2-1 through 2-6 of the Tlammable and Combustible
Code-197 7".
(g) Incompatible Wastes
(1) Incompatible wastes, or incompatible wastes and materials, shall
not be placed in the same tank, unless Item 11 (b), Part III of
this permit is conrtplied with.
(2) Hazardous waste shall not be pla'ced in an unwashed tank which
previously held an incompatible waste or material.
V. TREATMENT OF HAZARDOUS WASTE
1. Operation
(a) Chemical or physical treatment of hazardous waste shall comply with
Item 11 (b), Part III of this permit.
(b) Hazardous wastes or treatment reagents shall not be placed in the
treatment process or equipment if they could cause the treatment
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process of equipment to rupture, leak, corrode, or otherwise fail before
the end of its intended life.
2. Analysis £f Waste
(a) Whenever:
i (1) A hazardous waste which is substantially different from waste
previously treated in a treatment process or equipment at the
facility is to be treated in that process or equipment; or
(2) A substantially different process than any previously usod at the
facility is to be used to treat hazardous wastes chemically, the
owner or operator shall, before treating the different waste or
using the different process or equipment:
(i) Conduct waste analyses and trial treatment tests (e.g.,
bench scale or pilot plant scale tests); or
(ii) Obtain documented information on simHar treatment of
similar waste under similar operating conditions;
1 to show that this proposed treatment will meet all applicable
requirements of Item 1 (a) and (b).
3. Inspections
, (a) In accordance with the written inspection schedule of the approved
operation plan, the owner or operator shall inspect?
j (1) Treatment process equipment, at least once each operating day,
' to ensure that it is in good working order;
(2) Process and operations monitoring equipment, at least once each
operating day, to ensure that the treatment process or jquipment
is being operated according to its design;
(3) The construction materials of the treatment process or equipment,
at least weekly, to detect corrosion or leaking of fixtures or
seams; and
(4) The construction materials of, and the area immediately sur-
rounding discharge confinement 'structures, at least weekly, to
detect obvious signs of leakage.
4. Closure
! At closure, all hazardous waste and hazardous waste residues shall be
removed from treatment processes and equipment, discharge control equip-
' ment, and discharge confinement structures in accordance with the approved
closure plan.
-------
C-27
5. I qn it able or_ Reactive Waste
(a) Iqpitableor reactive waste shall not be placed in a treatment process
or equipment unless:
(1) The waste is treated, rendered, or mixed before or immediately
after placement in the treatment process or. equipment so that
the resulting waste, mixture, or dissolution of material no lonrjor
meets the definition of ignitable or reactive waste, and the
requirements of Item 11 (b), Part III of this permit are met; or
(2) The waste is treated in such a way that it is protected from
any material or conditions which may cause the waste to ignite
or react.
6. Incompatible Wastes
(a) Incompatible wastes, or incompatible wastes and materials, shall not
be placed in the same treatment process or equipment, unless the
requirements of Item 11 (b), Part III of this permit- are met.
(b) Hazardous waste shall not be placed in unwashed treatment equipment
which previously held an incompatible waste or material, unless the
requirements of Item 11 (b), Part III of this permit are met.
7. Recycling
(a) The mixing and blending of potentially incompatible materials and
wastes for purposes of recovering resources, neutralizing wastes, or
detoxifying wastes shall be carried out under controlled conditions to
ensure that violent reactions, extreme heat, or fire do not occgr and
that toxic or flammable gases and vapors are not released into the
atmosphere.
(b) If requested by the California State Department of Health Services in
accordance with Article 12, Chapter 30, Division 4, Title 22, California
Administrative Code, the owner or operator shall submit a written
statement justifying having not recycled a waste which the Department
has determined to be recyclable.
-------
APPENDIX D
A SUMMARY DESCRIPTION OF THE OPERATING
PROCEDURES AND DESIGN FACTORS TO PROTECT
IGNITABLE AND REACTIVE WASTE
-------
EE3
EXHIBIT 13
D-l
IT CORPORATION
A SUMMARY DESCRIPTION OF THE
OPERATING PROCEDURES AND DESIGN FACTORS
TO PROTECT IGNITABLE AND REACTIVE WASTE
Ignitable and reactive components are looked for during the predisposal truck
receiving analytical process. When such components are identified, the fol-
lowing procedures are used to prevent ignition and/or uncontrolled reaction of
such waste.
Ignitable Wastes
1. Waste containing ignitable components at concentrations sufficiently high
to allow for ignition are designated to a receiving tank.
2. A grounding clip is attached to the truck and the contents are off-loaded
through a submerged discharge line to prevent static build up.
3. The tank is connected via a flame arrestor to the vent system header which
conveys displaced fumes through a second flame arrestor on the main
header and thence through a high velocity section to the incinerator.
These all serve to prevent flame propagation from the incinerator or
between tanks.
4. Ignitable wastes are processed in most cases by the following methods. The
liquid phase of ignitable waste may be used as incinerator fuel after clean
up, blending and analysis. If concentrations are too low for use directly
as a fuel, the ignitable wastes are stripped from the aqueous phase and
conveyed through the vent system to the incinerator.
5. Outside ignition sources are limited by the existence of designated smok-
ing areas, posted "No Smoking" signs and a strictly enforced burn permit
policy (for welding, burning, grinding, etc.).
6. To avoid spontaneous combustion or other uncontrolled reactions, compati-
bility tests are run where conditions or waste stream components indicate
the possibility of an exothermic reaction.
Reactive Wastes
1. In cases where uncontrolled reactions might be expected, a compatibility
test is run between the contents of the receiving tank and the waste
itself. Where the components of the waste indicate a potential risk of
an exothermic reaction with treating reagents, a treatability test will
be accomplished in order to determine the A T and thus the appropriate
feed rates for the batch.
Regional Oftice
IT Corporation • 4575 Pacheco Boulevard • Martinez. Calilornia 94553 • 415-228-5100
-------
D-2 ITCOWORATIOM
2. In the case of waste designated to ponds, a daily monitoring of pH is
accomplished and recorded in order to assure safe mixing of weakly acidic
and basic loads. In situations where other classes of reactions (oxida-
tion/reduction, etc.) involving reactive chemicals might be expected, com-
patibility tests are run on a fresh pond sample and the suspect waste.
3. Cyanide wastes are treated separately from all other waste in a contain-
ment area restricted to neutral and alkaline waste. No acid lines are
incorporated in the containment area. Cyanide wastes are checked for AT
values when high concentrations are present. The tank is vented to the
large incinerator which must be running in order to treat waste.
4. Sulfide wastes are likewise treated in a tank located in the neutral to
alkaline containment area. Acid lines are not connected to this system.
This treatment requires that the large incinerator be running to handle
any fumes generated in the oxidation process.
-------
APPENDIX E
IT MEMO REGARDING WASTE TREATMENT IN TANK TRUCKS
-------
E-l
:?CC-.i.-O3AT!ON
To:
BAR3ATLV ACKER
January 23, 1985
From:
Jill "E
Subject.
STI TREATMENT ..N TR
To confirm our earlier conversations on the decision issued by
our Environmental Specialises, it is the understanding than the treat-
ment of Bastes in.- "transporting vehicles would be prohibited at the Vine
Hill Facility with the following two (2) exception conditions:
(1) To protect che ir.ce.qricv of che vehicle liner or
co procect the integrity of che construction mat-
solids content
The ^dditiop. jf Hydrogen Peroxice (Purcr.ased ^roduct/'HTU^) -'or
the -urpos* of eliminating the odor or ti.^ potential for~odcr
development would be allowed.
In .'.edition, at all ti~es under both exception conditions, labor-
atory beiica scale wasce/ch^-ical nixing analysi.-: T.USC be perforr.ad to
cetemir.e j.r.y potential reaction (s) ^foanin-c;, heat generation, fu^ir.^',
ecc.). Ir. cases whcra rel_tivaly nincr reactions are observed, additic;.
of ;rea:r.^.-.c chemicals co was ess contained in transporting vehicles would
:•-•.-. allowed. In the event: the Laboratory ber.cr. scale test yields a sig-
nificant • •'' rr.ajor acverso reaction, the treatment of the waste • ir. the
transporti.'.:: vehicle would :io_c be allowed a.-d acceptable-, alter-.-.aca
::.cchcds y.: /.andlinu or disp'.:"J:."n^ of c'.ie vasti. r.'.usc be detirr.ir.a-d . Vri_-
:^n doc-.::..enta:ior. of the ;^e.-f ormance, limitir..; factor conditions and
*'>!ierveu/.ixpectad .'oactio:''. s; .':.usc be eniered under the "Comment.;1' secti-n
OL: the Jis~jsai Locacior. "orm.
-------
E-2
In -ttempting to follow intent a.v_ exception conditions, we are
nroposin.'i -n extension o-~ the limitation in Case ••! for your review.
••.'e are repeatedly faced with acidic waste streams containing dissolvec
metals above the regulated restriction limits. The currant treatment
method used at the Vine Hill Facility for the removal of dissolved \"i,
As, ?b, Cd, rig, 5i and Tl frora aqueous vastes is precipitation as. a
~ccal sulfide. The precipitation treatment procedure generally occurs
in Tanks 12, 14 and 16 vhich ^re mild steel tanks. Since our intent
is to precipitate the restricted netsls as metal sulfides and not metal
hydroxides, and in airer.oting to include the TSD facility's concerns
for proceccion of tank liner or construction nacerial with those of the
transporters, x^e propose che addition of Sodiun Hydroxide (Purchased
Product/XaOH) for p.-i adjustment prior to off-loading for these waste
streams. This would greatly reduce che potential of corrosive action
on the trciacT.ent tank construction materials and orovide an additional
-aans of assuring tank integrity.
As the receipt of acidic wastes containing metals constitutes a
fairly consistent and re-occurring volume, our concerns for ensuring
tank integrity in the most cost effective yet safety .conscious manner
while still following the intent of the exceptions conditions, are sub-
stantial, please review this proposal and inform ma of whether the
I.v.'ironr.intal Affairs decision can be extended to cover the TSD facilif
and not only the transporter.
JF/pcg
Wence-l ?ells
Ed oc
-------
APPENDIX F
TANK 61 CERTIFICATION
-------
F-l
IT CORPORATION
TANK TESTING AND HAZARDOUS WASTE
TANK CERTIFICATION •
LOCATION; IT Oil Vine Hill ; DATE; August 25. 1983
TANK NO.; 61 NAME/SERVICE; Storage
A. DESCRIPTION
1. TYPE OF TANK: ABOVE GROUND X BURIED
2. THIS TANK IS IS NOT X USED FOR HAZARDOUS WASTES.
3. CONFIGURATION: VERTICAL/CYLINDRICAL X HORIZONTAL/CYLINDRICAL
RECTANGULAR OTHER
DESCRIBE OTHER:_
DIMENSIONS:- DIAMETER 49 FT. HEIGHT 35 FT.
LENGTH FT. WIDTH FT.
OTHER INFORMATION; Central roof support.
4. OPERATING CONDITIONS:
MAX NORMAL MIN
PRESSURE PSLA: Atmosphere '
TEMPERATUREt °C: Ambient
5. AGITATION: YES NO X
IF YES, DESCRIBE TYPE:
-------
F-2
TANK TESTING AND HAZARDOUS WASTE
TANK CERTIFICATION
(CONTINUED)
TANK NO. 61
6. CHEMICAL CONSTITUENTS:
CHEMICAL NAME CONCENTRATION UNITS
£g -
•
SUSPENDED SOLIDS WC. I
Hydrocarbon Fuels 100 Z
7. EXPLANATION OP TANK USE AND OPERATION: Used for storage of hydrocarbon
materials associated with oil reclaim processing. Tank may contain residual
water and/or sludge which separates from stored hydrocarbons.
-------
F-3
TANK TESTING AND HAZARDOUS WASTE
TANK CERTIFICATION
(CONTINUED)
TANK NO. 61
B. TESTING RESULTS . . ,
THIS TANK WAS:
PRESSURE TESTED
ULTRASONICALLI TESTED X
THE COMPLETE TESTING RESULTS ARE ATTACHED. A BRIEF SUMMARY OF THE TEST
AND RESULTS IS:
See Figures 1 through 5 for ultrasonic teat data. Slight thinning above the
midpoint of the tank wall is apparent. Mechanical strength of the tank was
checked by a registered mechanical engineer. Results are presented in item 1
of Attachment 1.
Seismic stability of the tank was also checked. Since the tank was constructed
prior to 1982, codes in effect prior to 1982 apply.
AS DETERMINED BY TESTING, REPAIRS TO THE TANK WERE WERE NOT
REQUIRED.
C. INSPECTION
A VISUAL INSPECTION OF THE TANK WAS X WAS NOT MADE. THE
RESULTS OF THE INSPECTION ARE SUMMARIZED AS FOLLOWS:
Slight pitting of tank bottom and roof support. Inspection conducted
June 28, 1983.
-------
F-4
TANK TESTING AND HAZARDOUS WASTE
TANK CERTIFICATION
(CONTINUED)
TANK NO. 61
PHOTOGRAPHS, IF ANT, TAKEN DURING THE INSPECTION ARE ATTACHED.
D. REPAIRS
AS DETERMINED B7 THE TESTING AND INSPECTION, REPAIRS WERE WERE
NOT X REQUIRED. IF REPAIRS WERE MADE A DESCRIPTION OF THESE REPAIRS
AND SUBSEQUENT TESTING AND INSPECTING IS AS FOLLOWS:
-------
F-5
TANK TESTING AND HAZARDOUS WASTE
TANK CERTIFICATION
(CONTINUED)
TANK NO. 61
PHOTOGRAPHS, IF ANY, TAKEN DURING THE INSPECTION ARE ATTACHED.
D. REPAIRS
AS DETERMINED BY THE TESTING AND INSPECTION. REPAIRS WERE WERE
NOT X REQUIRED. IF REPAIRS WERE MADE A DESCRIPTION OF THESE REPAIRS
AND SUBSEQUENT TESTING AND INSPECTING IS AS FOLLOWS:
-------
F-6
TANK TESTING AND HAZARDOUS WASTE
TANK CERTIFICATION
(CONTINUED)
TANK NO. 61
E. RECOMMENDATIONS AND REQUIREMENTS .
1. IT IS RECOMMENDED THAT MODIFICATIONS BE MADE NOT BE MADEj X
IN THE OPERATION, CONSTRUCTION AND/OR MAINTENANCE OF THIS TANK.
THESE CHANGES, WHICH ARE NOT REQUIRED FOR TANK CERTIFICATION, ARE
SUMMARIZED AS FOLLOWS:
•
None required.
2. IT IS REQUIRED THAI MODIFICATIONS BE MADE NOT BE MADE X IN
THE OPERATION, CONSTRUCTION AND/OR MAINTENANCE OF THIS TANK. THESE
CHANGES, WHICH ARE REQUIRED FOR TANK CERTIFICATION, ARE SUMMARIZED AS
FOLLOWS:
None required.
-------
F-7
TANK TESTING AND HAZARDOUS WASTE
TANK CERTIFICATION
(CONTINUED)
TANK NO. 61
THE ABOVE REQUIREMENTS HAVE BEEN FULFILLED AS A CONDITION OF TANK •
CERTIFICATION.
F. CERTIFICATION
I, HEREBY APPROVE THE DESIGN AND CONSTRUCTION OF THIS TANK FOR ITS
INTENDED USE. I MAKE THIS CERTIFICATION BASED UPON MY KNOWLEDGE
OF THE TANK CONSTRUCTION, CONDITION, AND" THE PERTINENT OPERATING
PARAMETERS WHICH INDICATE THE TANK IS BEING USED IN ACCORDANCE
WITH GOOD ENGINEERING PRACTICES. THIS CERTIFICATION MEETS THE
REQUIREMENTS OF IT CORPORATION STANDARD PROCEDURES.
J. W. Schweizer—v,
PRINTED NAME,OF REGISTERED ENGINEER
DATE August '25,' 1983 •,
SIGNATURE Of REGISTERED ENGINEER
IJECISTRATION NO. 'Che3961 -'STATE CA
-------
F-8
ASHCRAFT
CONSULTANTS
71 5 Hamilton Drive
Pleasant Hill, CA 94523
(415)934-1957
August 8f 1983
At the request of IT Envlroscience, three vessel types
were checked for suitability in their present service
and seismic zone location. The results are dl cussed .
below.
1.
3.
Tank No. 6l - **9f diameter by 35' high. Weight
of contents: 86 #/ cu. ft. This tank is O.K. if
designed In accordance old U3C, but would require
anchorage if it conforms to the 1982 UBC.
Tanks #1 through #6 - 6.5' diameter by 26' OAL
Weight of contents: 11.5 #/ gallon. These tanks
are structurally capable of performing their In-
tended service, and appear adequate selscically,
although the exact design of the saddles vas not
observed by ASHCRAFT CONSULTANTS.
Tanks #7 and #8 - 13 » diameter by 22 • nig:.. Weight
of contents: 11.5 #/ gallon. These tanks will con-
tain the liquids, but will require anchorage to
resist seismic forces. A possible solution would
be to weld 3"xl/U-* straps 5 2* o.c. to sice of
tanks and bolt to existing adequate concrete found*
ation with concrete anchor (expansion type) bolts.
Foundation must be adequate to resist uplift.
Wllllan C. Ashcraft
-------
24' M.H.
TANK BOTTOM
nvnoMinci
IT OIL-TANK 61
ULTRASONIC THICKNESS TEST DATA — 6/29/83
DESIGNED BY >
DRAWN BY « JW8H
PROJECT NO'
SCALE
FIGURE
1
DATE > 8124)16%
-------
LADDER
ROOF
IT OIL-TANK 61
ULTRASONIC THICKNESS TEST DATA - 6/28/83
FIGURE
DESIGNED BY >
DRAWN BY ' & TKurff
-------
DENT
-.320
WEST ELEVATION
nrmosoiooi
IT OIL—TANK 61
ULTRASONIC THICKNESS TEST DATA — 6/28/83
DESIGNED BY
DRAWN BY'JN65l00LP
FIGURE
-------
.357
2* NOZ.
24* M.H.
EAST ELEVATION
FQ
IT OIL - TANK 61
ULTRASONIC THICKNESS TEST DATA — 6/28/83
FIGURE
DESIGNED BY >
DRAWN BY i
-------
.359
.196 &
0.170
.149®
®.203
.121©
®J2t4
.278®
®.2B6
.272®
®.269
.294®
®.286
.297®
®.291
.360®
®.361
.366®
ffi.344
Q
8'N.
GRADE
REINFORCEMENT
SOUTH ELEVATION
HTIB08CI1IC1
IT OIL — TANK 61
ULTRASONIC THICKNESS TEST DATA — 6/28/83
DESIGNED BY *
DRAWN BY' JN<9£IBGU?
1/fl!
* .
DATE •
FIGURE
-------
APPENDIX G
FIGURE FROM FEBRUARY 6, 1985 IT SUBMITTAL TO EPA
REGARDING TRANSFER OF WASTE FROM VINE HILL TO BAKER
-------
G-l
11
(T D
OZ
CD
!«
Q
Waste Analysis Plan
Vine Hill Tanks
Vine Hill
Impoundments
Pond Transfer
Analysis
Baker Impoundments
TankOfschargt
Sampling and
Analysis
Description(TDSAD)
Waste Flow and Analysis Procedures
Baker Disposal Facility
PREPARED FOR
« 1984 IT CORPORATION
ALL COPYRIGHTS RESERVED
IT CORPORATION
FIG. HEM
... Creating a Safer Tomorrow
Do Not Sc«l« Thit Drawing
-------
APPENDIX H
WASTE TRACKING AT IT, VINE HILL
-------
H-l
Appendix H
WASTE TRACKING AT IT, VINE HILL
' (1983 MANIFESTS)
Manifest
Number
83007889
8201950
83085960
8209837
83085946
8278675
83086186
8270097
83085960
8201989
8233813
83047439
8201984
8275080
82028317
8234963
Waste Date Received
Description at IT
340 gallons of HF
440 gallons of solvent
38,400 pounds of
ammonia solution
2,000 gallons of
solvent
35,900 pounds of
ammonia solution
4,620 gallons of
corrosive liquid
(pH 13)
2,958 gallons of haz-
ardous waste sludge
5,040 gallons of
corrosive liquid
38,600 pounds of
ammonia solution
3,780 gallons of
corrosive liquid
3,000 gallons of
paint waste
4,600 gallons of
corrosive liquid
4,830 gallons of
alkaline solution
(pH 1.5)
3,020 gallons of haz-
ardous waste liquid
4,800 gallons of HF
and H2S04
05/26/83
05/09/83
05/30/83
05/16/83
05/31/83
05/19/85
05/27/83
05/17/83
05/31/83
05/12/83
05/20/83
05/24/83
05/09/83
05/25/83
05/05/83
05/25/83
Unloading
Station
Tank 2
Tank 12
Tank 12
Tank 20
Pond 102A
Pond 102B
Pond 102B
Pond 102B
Pond 102B
Pond 103
Pond 103
Pond 103
Pond 103
Pond 103
Pond 103
Remarks
IT did not provide any 1983 Tank Pro-
cessing Records
IT did not provide any 1983 Tank Pro-
cessing Records
IT did not provide any 1983 Tank Pro-
cessing Records
IT did not provide any 1983 Tank Pro-
cessing Records
Manifest indicated metals at 5,000 ppm
but waste not analyzed for metals at
IT
Manifest indicated lead chloride at
2,000 to 3,000 ppm but waste not ana-
lyzed for metals at IT
pH 13
pH 1 waste unloaded directly to pond
in violation of 22 CAC, 15 § 66900(c).
Manifest indicated mercury in paint
but waste not analyzed for metals at
IT
pH 12
pH 1.5 waste unloaded directly to pond
in violation of 22 CAC, 15 § 66900(c).
pH 3
IT provided no information regarding
this manifest
-------
H-2
Appendix H (cent.)
WASTE TRACKING AT IT, VINE HILL
(1984 MANIFESTS)
Manifest
Number
088-143385
83562518
83485225
83007841
83134948
Waste
Description
2,000 gallons of
H2SO«
250 gallons of HF
4,680 gallons of
corrosive
425 gallons of HF
4,800 gallons of HF
Date Received
at IT
05/15/84
05/22/84
05/23/84
05/18/84
05/24/84
Unloading
Station
Tank 1
Tank 1
Tank 1
Tank 1
Tank 1
Remarks
No record of this material in tank 1
No record of this material in tank 1
No record of this material in tank 1
No record of this material in tank 1
No record of this material in tank 1
and HjSO«
83427323 3,000 gallons of HCL
83392460 119 gallons of
flammable liquid
83529261 4,620 gallons of
waste oil
83483382 40,360 pounds of
corrosive liquid
83562529 1,524 gallons of
CN solution
83574539 119 gallons of ZnCN
sludge
83134344 2,846 gallons of
solvent
83009929 1,243 gallons of
flammable liquid
83009930 2,000 gallons of
flammable liquid
83060464 5,000 gallons of
corrosive liquid
83438634 5,000 gallons of haz-
ardous waste liquid
83518033 4,620 gallons of
corrosive liquid
8254038 3,438 gallons of haz-
ardous waste liquid
83562472 900 gallons of haz-
ardous waste liquid
83566737 200 gallons of
corrosive liquid
8266434 5,203 gallons of
corrosive liquid
83562482 4,825 gallons of haz-
ardous waste liquid
83590701 500 gallons of
chromium acid
83562530 395 gallons of
corrosive liquid
08/11/84
Tank 2
05/08/84
08/03/84
05/29/84
05/16/84
05/25/84
05/01/84
05/17/84
05/17/84
05/18/84
05/23/84
05/23/84
05/01/84
05/07/84
05/08/84
05/07/84
05/23/84
05/09/84
05/16/84
Tank 11
Tank 11
Tank 13
Tank 15
Tank 15
Tank 19
Tank 26
Tank 61
Pond 102A
Pond 102B
Pond 102B
Pond 102B
Pond 102B
Pond 103
Pond 103
Pond 103
Pond 103
Pond 103
Combined with three other waste
streams in tank 2, treated with
Na2Sj.05 on 08/13/84. 8,260 out of
13,060 gallons in tank 2 discharged
to tank 13 on 08/14/84. No record
of other 4,800 gallons remaining In
tank 2
No record of this material in tank 11
No record of this material in tank 11
No record of this material in tank 13
No record of this material in tank 15
Combined with other CN waste. Treated
with H202 and FeS02. 9,080 gallons
discharged 06/13/84 to unspecified
location
No Tank Processing Records for Tank 19
for any 1984 dates
No Tank Processing Records for Tank 19
for any 1984 dates
No Tank Processing Records for Tank 19
for any 1984 dates
pH 13
pH 12.7
pH 13.5
-------
H-3
Appendix H (1984 cont.)
Manifest
Nunber
83487022
8254040
83562499
83566618
83208936
83574378
83344537
83344578
83488290
83004494
Waste Date Received
Description at IT
37,620 pounds of
arsenic mixture
3,000 gallons of
paint sludge
731 gallons of haz-
ardous waste liquid
2,500 gallons of
paint waste
5,000 gallons of
solvent
322 gallons of
solvent
4,855 gallons of HF
773 gallons of
solvent
4,500 gallons of HF
1,855 gallons of
hypochlorite
05/31/84
05/31/84
05/16/84
05/22/84
05/23/84
05/05/84
05/30/84
05/30/84
05/29/84
05/08/84
Unloading
Station Remarks
Pond 103
Pond 103
Pond 103
Pond 103
Pond 103
Pond 103
Pond 103
Pond 103
Pond 103
Baker pH 12.4
Pond A5
-------
H-4
Appendix H (cont.)
WASTE TRACKING AT IT, VINE HILL
(1985 MANIFESTS)
Itanifest
Number
Wast*
Description
Date Received
at IT
Unloading
Station*
Remarks
84312633 4,800 gallons of 03/04/85 Tank 1
HF and H2S04 acid
84163389 2,600 gallons of HF 05/01/85 Tank 1
acid
84330911 3,120 gallons of HF 05/01/85 Tank 1
acid
84035586 4,611 gallons of 05/02/85 Tank 1
corrosive liquid
84312669 4,800 gallons of HF 05/02/85 Tank 1
and H2S04
84312671 4,800 gallons of HF 05/07/85 Tank 1
and H2S04
84121857 4,100 gallons of 05/09/85 Tank 1
HF acid
84164655 3,820 gallons of 05/13/85 Tank 1
waste acid
84407787 4,840 gallons of 05/13/85 Tank 1
HF acid
84563959 1,205 gallons of 05/20/85 Tank 1
HF acid
84121855 4,400 gallons of
HF acid
84312674 4,800 gallons of
HF and H2SO« acid
84566486 4,500 gallons of
HF acid
84312677 4,600 gallons of HF
and H2S04 acid
84192146 1,549 gallons of
waste acid
84121853 4,242 gallons of 05/30/85 Tank 1
HF acid
84041225 3,820 gallons of 05/03/85 Tank 2
corrosive liquid
84198920 1,650 gallons of 05/09/85 Tank 2
waste acid
84180863 1,456 gallons of 05/09/85 Tank 2
waste acid
05/21/85
05/23/85
05/24/85
05/29/85
05/30/85
Tank 1
Tank 1
Tank 1
Tank 1
Tank 1
No record of this Material in tank 1
No record of this uterial in tank 1
No record of this material in tank 1
Combined with other waste. Cr+6
treated with Na,$i05; 14,611 gallons
discharged to tank 24 on 05/03/85;
no record of this material on tank
24 Treatment Processing Records.
No record of this material in tank 1
No record of this Material in tank 1
No record of this Material in tank 1
No record of this material in tank 1
No record of this Material in tank 1
Combined with other waste. Cr+«
treated with Na2S205. 182 barrels
discharged on 05/20/85 to tank 14
for acid neutralization (pH of dis-
charged material 1). No record of
this material in tank 14.
No record of this material in tank 1
No record of this material in tank 1
No record of this material in tank 1
No record of this Material in tank 1
Combined with other waste. Cr+*
treated with NajS205. 9,628 gallons
discharged to tank 13 for N1 treat-
ment on 06/01/85. Treated with NaOH
and NajS in tank 13. 10,500 gallons
discharged to pond 103 on 06/03/85.
No record of this material in tank 1
Treated with Na2S205 in tank 2. 3,820
gallons of pH 1 waste discharged to
tank 24 on 05/06/85. Combined with
other waste and treated with NaOH
and steam in tank 24. Treatment
record ends 05/09/85. Discharge
information missing.
Combined with other waste and treated
with Na2S20$ to reduce Cr+6 in tank
2. 9,670 gallons (pH 2, Pb 530 ppm,
Ni 780 ppm) discharged to tanks 13
and 14 on 05/10/85. Tank 13 records
show 4,000 gallons froM tank 2 on
05/10/85. No record of this waste
in tank 14.
Combined with other waste and treated
with Na2S205 to reduce Cr+* in tank
2. 9,670 gallons (pH 2, Pb 530 ppm,
Ni 780 ppm) discharged to tanks 13
and 14 on 05/10/85. Tank 13 records
show 4,000 gallons from tank 2 on
05/10/85. No record of this waste
in tank 14.
-------
H-5
Appendix H (1985 cent.)
Manifest
Nuinber
84312672
84190471
84330912
84312673
84120303
8419049S
84380474
84312594
84041404
84265268
84041409
84041417
84346982
84265310
84265307
84442167
84265324
84041474
84453353
84035577
84035565
84265244
84056820
84265247
84198917
84163630
84314689
84265249
84312537
84265259
84265267
Waste Date Received
Description at IT
4,800 gallons of HF
and H2S04 acid
1,650 gallons of
waste acid
3,000 gallons of
HF acid
4,800 gallons of HF
and H2S04
2,200 gallons of
HF acid
1,600 gallons of 05
flaimable liquid
2,300 gallons of
H2S04 and ammonia
4,991 gallons of haz-
ardous waste liquid
4,987 gallons of flam-
mable/corrosive
liquid
5,000 gallons of haz-
ardous waste liquid
5,303 gallons of flam-
mable/corrosive
liquid
5,003 gallons of flam-
mable/corrosive
liquid
4,200 gallons of
flammable liquid
5,000 gallons of
waste solvent
5,078 gallons of haz-
ardous waste liquid
1,000 gallons of haz-
ardous waste liquid
3,000 gallons of haz-
ardous waste liquid
5,090 gallons of flam-
mable/corrosive
liquid
4,820 gallons of
waste acid
4,594 gallons of
waste acid
5,574 gallons of flam-
mable/corrosive
liquid
4,926 gallons of haz-
ardous waste liquid
2,775 gallons of haz-
ardous waste liquid
5,317 gallons of haz-
ardous waste liquid
5,460 gallons of haz-
ardous waste liquid
4,200 gallons of
flammable liquid
3,000 gallons of
paint sludge
4,900 gallons of haz-
ardous waste liquid
5,000 gallons of haz-
ardous waste liquid
5,000 gallons of haz-
ardous waste liquid
5,000 gallons of haz-
ardous waste liquid
05/13/85
05/14/85
05/14/85
05/17/85
05/29/85
or 06/03/85
05/13/85
05/13/85
05/13/85
05/13/85
05/14/85
05/15/85
05/20/85
05/21/85
05/22/85
05/23/85
05/23/85
05/24/85
05/01/85
05/01/85
05/01/85
05/02/85
05/03/85
05/03/85
05/06/85
05/06/85
05/06/85
05/06/85
05/08/85
05/08/85
05/09/85
Unloading
Station*
Tank 2
Tank 2
Tank 2
Tank 2
Tank 2
Tank 11
Tank 11
Tank 11
Tank 11
Tank 11
Tank 11
Tank 11
Tank 11
Tank 11
Tank 11
Tank 11
Tank 11
Tank 11
Tank 12
Tank 12
Tank 12
Tank 12
Tank 12
Tank 12
Tank 12
Tank 12
Tank 12
Tank 12
Tank 12
Tank 12
Tank 12
Remarks
No record of this material in tank 2
No record of this material in tank 2
No record of this material in tank 2
No record of this material in tank 2
No record of this material in tank 2
No Tank Processing Records for this
tank in May or June 1985
No Tank Processing Records for this
tank in May 1985
No Tank Processing Records for this
tank in May 1985
No Tank Processing Records for this
tank in May 1985
No Tank Processing Records for this
tank in May 1985
No Tank Processing Records for this
tank in May 1985
No Tank Processing Records for this
tank in May 1985
No Tank Processing Records for this
tank in May 1985
No Tank Processing Records for this
tank in May 1985
No Tank Processing Records for this
tank in May 1985
No Tank Processing Records for this
tank in May 1985
No Tank Processing Records for this
tank in May 1985
No Tank Processing Records for this
tank in May 1985
No record of this material in tank 12
No record of this material in tank 12
No record of this material in tank 12
No record of this material in tank 12
No record of this material in tank 12
No record of this material in tank 12
No record of this material in tank 12
No record of this material in tank 12
No record of this material in tank 12
No record of this material in tank 12
No record of this material in tank 12
No record of this material in tank 12
No record of this material in tank 12
-------
H-6
Appendix H (1985 cont.)
Manifest
(tutor
84265285
84041403
84041408
84265319
84265311
84346983
84265308
84041475
84265328
84312544
84265327
84347009
84265326
84265286
84312542
84312538
84163504
84186809
84041463
84163524
Wast* Date Received
Description at IT
2,281 gallons of haz-
ardous waste liquid
4,869 gallons of flam-
mable/corrosive
liquid
5,290 gallons of flam-
mable/corrosive
liquid
5,000 gallons of haz-
ardous waste liquid
4,926 gallons of haz-
ardous waste liquid
4,200 gallons of
flammable liquid
5,000 gallons of haz-
ardous waste liquid
4,794 gallons of flam-
mable/corrosive
liquid
5,000 gallons of haz-
ardous waste liquid
5,000 gallons of haz-
ardous waste liquid
5,000 gallons of haz-
ardous waste liquid
4,200 gallons of
flammable liquid
5,000 gallons of haz-
ardous
4,091 gallons of haz-
ardous waste liquid
4,623 gallons of haz-
ardous waste liquid
5,000 gallons of haz-
ardous waste liquid
2,000 gallons of haz-
ardous waste liquid
1,650 gallons of
waste acid
5,079 gallons of
corrosive liquid
5,000 gallons of
ammonium thiosulfate
05/10/85
05/13/85
05/14/85
05/17/85
05/20/85
05/21/85
05/23/85
05/24/85
05/29/85
05/30/85
05/30/85
05/31/85
05/31/85
05/10/85
05/24/85
05/10/85
05/14/85
05/20/85
05/23/85
05/21/85
Unloading
Station*
Tank 12
Tank 12
Tank 12
Tank 12
Tank 12
Tank 12 (80%)
Tank 20 (20*)
Tank 12
Tank 12
Tank 12 (75X)
Tank 19 (25X)
Tank 12
Tank 12
Tank 12
Tank 12
Tank 13
Tank 13
Tank 14
Tank 14
Tank 14
Tank 14
Tank 15
Remarks
No record of this material in tank 12
No record of this material in tank 12
No record of this Material in tank 12
No record of this material in tank 12
No record of this material in tank 12
No record of this material in tank 12
No Tank Processing Records for this
tank in May 1985
No record of this material in tank 12
No record of this material in tank 12
No record of this material in tank 12
No Tank Processing Records for this
tank in May 1985
No record of this material in tank 12
No record of this material in tank 12
No record of this material in tank 12
No record of this material in tank 12
Combined with other waste and treated
with acid, H202 and FeSO« in tank
13. 15,000 gallons discharged to
tank 61 on 05/14/85. No record of
this material in tank 61.
Treated with H202 in tank 13. 4,623
gallons discharged to pond on
05/28/85.
Combined with other waste and treated
with H202 in tank 14. 7,600 gallons
discharged to pond 103 on 05/13/85
Combined with other waste and treated
with H202, acid and FeS04 in tank
14. 316 barrels (13,272 gallons)
discharged to tank 24 on 05/17/85.
Combined with other waste and
treated with steam in tank 24.
7,969 barrels (334,698 gallons) dis-
charged to Baker Pond A4 on
05/22/85.
Combined with other waste and treated
with NaOH and Na2S in Tank 14.
6,000 gallons discharged to pond 103
on 05/20/85.
Combined with other waste and treated
with H202 and FeSO« in tank 14.
14,879 gallons discharged to tank 24
on 05/24/85. No record of this
material on Tank Processing Records
for tank 24.
Combined with other waste and treated
with FeS04, NaOH and H202 in tank
15. 250 gallons discharged to pond
103 on 05/3V85. Fate of remaining
material unknown.
-------
H-7
Appendix H (1985 cont.)
Manifest
Niofcer
84265254
84265245
84405923
84265258
84312662
84017097
84405768
84163489
Waste Date Received
Description at IT
4,583 gallons of haz-
ardous waste liquid
5,400 gallons of haz-
ardous waste liquid
5,000 gallons of
flammable liquid
4,828 gallons of haz-
ardous waste liquid
1,700 gallons of
waste solvent
109 gallons of
flammable liquid
459 gallons of
flammable liquid
400 gallons of
HF acid
05/01/85
05/05/85
05/06/85
05/07/85
05/13/85
05/20/85
05/07/85
05/01/85
Unloading
Station*
Tank 18
Tank 18
Tank 18
Tank 18
Tank 19
Tank 19
Tank 20
Tank 24
Remarks
No record of this material in tank 18
No record of this material in tank 18
No record of this material in tank 18
4,000 gallons pumped from tank 18 to
tank 13 on 05/09/85. No record of
this material in tank 13.
No Tank Processing Records for this
tank in May 1985
No Tank Processing Records for this
tank in May 1985
No Tank Processing Records for this
tank in May 1985
Information from Tank Treatment Pro-
cessing Record dated 04/30/85 indi-
cating waste combined with other
waste and treated with Na2S, NaOH
and steam in Tank 24. Treatment
record ends 05/09/85. Discharge
information missing.
According to Treatment/Disposal Location form
-------
H-8
Appendix H (cont.)
WASTE TRACKING AT IT VINE HILL
(1986 MANIFESTS)
Manifest
Number
84093402
84876872
00240
Waste
Descriptions
5,040 gallons of
•ethyl ene chloride/
phenol solution
4, HO gallons of
fl amiable liquid
3,940 gallons of HN03
Date Received
at IT
01/29/86
01/08/86
01/29/86
Unloading
Station
Tank 11
Tank 11
Tank 13
Remarks
No Tank Processing records for tank 11 for any
1986 dates. Tank Status records indicate Material
in tank 11 discharged by 2/3/86.
No Tank Processing record for Tank 11 for any 1986
dates. Tank Status records indicate Material in
tank 11 probably discharged by 1/9 or 1/13/86.
Combined with NaOH and pH 7 waste. Treated with
84947289
84380919
84363877
84632873
4,000 gallons of
Cr+6 solution
4,000 gallon of CN
solution
2,000 gallons of
acetone solution
1,200 gallons of
waste solvent
84093451
846519848
5,040 gallons of
acetaldehyde solution
500 gallons of
acetone solution
84357153 4,600 gallons of
Xylol (pH 1.7)
84093436 5,040 gallons of
trichloroethane
solution
84093416 5,000 gallons of
methylene chloride
solution
84313843 650 gallons of waste
oil (pH 1.6)
84877087 4,764 gallons of
corrosive liquid
NaOH and S = (for Ni). Discharged 17,800 gallons
to pond 103 on 1/30/86, according to Tank Process-
ing record. Discharge Information on TPR* does
not natch information of T.P. Operations Status
sheets.
01/28/86 Tank 14 Treated with waste acid and Na2S2Os. Tank Pro-
cessing record indicates discharged to pond 103 on
1/28/86. T.P. Operations Status sheet does not
agree with TPR discharge information.
01/28/86 Tank 15 Treated.1/29 through 2/22 with HC03, H202 and
Na2S2Os. 16,800 gallons pumped to tank 23 on
2/24/86. No records for tank 23 on 2/24/86. No
further analysis of N1. Tank Status record indi-
cates discharge of 1'5" between 1/30 and 1/31/86.
No record of where this material went.
01/14/86 Tank 16 No Tank Processing record for tank 16 for that
date. Tank Status record does not indicate
receipt of material into tank 16.
01/30/86 Tank 16/19 Aqueous phase (85X or 1,020 gallons) to tank 16,
but Tank Processing record for tank 16 for 1/30/86
does not list this manifest. Non-polar solvent
phase (15X or 180 gallons) to tank 19, but no Tank
Processing records for tank 19 for any 1986 dates.
01/06/86 Tank 18 No Tank Processing records for tank 18 for any
1986 dates. Tank Status records do not show
receipt of this material.
01/30/86 Tank 19 No Tank Processing records for tank 19 for any
1986 dates. Tank 19 is usually a receiving/
storage tank for waste prior to steam stripping
in tank 24.
01/31/86 Tank 20 No Tank Processing records for tank 20 for any
(NaOH added 1986 dates. Tank 20 usually a receiving and stor-
to protect age tank for waste to be steam stripped in tank
integrity of 24. Tank Status records indicate material in tank
tank) 20 discharged by 2/3/86.
01/20/86 Tank 20 No Tank Processing records for Tank 20 for any
1986 dates. Tank Status Records do not show
receipt of this material.
01/03/86 Tank 20 No Tank Processing records for tank 20 for any
1986 dates
01/13/86 Tank 21 (20 No Tank Processing records for tank 21 for any
gallons of 1986 dates. Tank 21 usually a receiving and stor-
caustic added) age tank for waste to be stem stripped in tank
24. Tank Status records indicate material in tank
21 probably discharged by 1/14/86.
01/30/86 Pond 105 Pond 10S pumped to pond 106 on 1/30/86 and 2/2/86.
Pond 106 pumped to Baker almost continuously.
TPR - Ttnk Practising Rtcord
-------
APPENDIX I
SEPTEMBER 10, 1984 LETTER FROM IT TO CRWQCB NOTIFYING
OF THE CHANGE OF SERVICE OF IMPOUNDMENT 1028
-------
Attachment *2 _ M
Received-Martinez
SEP 1 7 1984
IT CORPORATION __ Environmental Affairs
September 10, 1984
Mr. Roger James
Executive Officer
California Regional Water
Quality Control Board
San Francisco Bay Region
1111 Jackson Street, Rm. 6040
Oakland, CA 94607 '
Dear Mr. James:
This letter is to inform you of a change in service of Pond 102B at IT
Corporation's Vine Hill facility. Pond 102B is being converted to act as
secondary containment for anticipated modernization of the treatment
operations.
If you or your staff should have any questions or comments regarding this
change in service, please do not hesitate to contact Mr. Mark Posson at
(415) 228-5100 on extension 298.
Sincerely,
OavT-d't. Bauer
Vice President Environmental Affairs
DLB/er
Corporate Office
IT Corporation • 23456 Hawthorne Boulevard • Box 2995 • Torrance. California 9O5O9 • 213-378-9933
------- |