NEIC
EPA-33012-90-019
ENVIRONMENTAL AUDIT
JEFFERSON PROVING GROUND
Madison, Indiana
Apnl 1990
National Enforcement Investigations Center, Denver
G.S. Environmental Protection Agency
Office of Enforcement
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT AND COMPLIANCE MONITORING
EPA-330/2-90-019
ENVIRONMENTAL AUDIT
JEFFERSON PROVING GROUND
Madison, Indiana
April 1990
Richard Ida
Eugene Lubieniecki
Alan Peckham
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Denver, Colorado
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CONTENTS
EXECUTIVE SUMMARY
INTRODUCTION 1
OBJECTIVES 1
BACKGROUND 2
SUMMARY OF FINDINGS 6
RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) 7
CLEAN AIR ACT (CAA) 9
National Emission Standards for Hazardous Air Pollutants
(NESHAP) - Asbestos Removal/Renovation Projects 10
TOXIC SUBSTANCES CONTROL ACT (TSCA) 10
CLEAN WATER ACT (CWA) 10
Waste water Treatment Plant Operations 11
Oil SpiU Prevention 12
SAFE DRINKING WATER ACT (SDWA) 12
FEDERAL INSECTICIDE FUNGICIDE AND RODENTICIDE
ACT (FIFRA) 13
SITE EVALUATION 13
Hydrogeology 13
Solid Waste Management Units 14
TECHNICAL REPORT
INVESTIGATIVE PROCEDURES 20
FACILITY OPERATIONS 23
AUDIT FINDINGS 24
RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) 24
Waste Identification 25
Required Plans 27
Inspections 27
Personnel Training 28
Biennial Reports 29
Land Disposal Restrictions 29
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CONTENTS (cont.)
CLEAN AIR ACT (CAA) '29
Open Burning/Open Detonation of Explosives/Propellants 29
Incinerators 30
Boilers 32
Degreasing Operations 32
Asbestos Removal and Renovation Projects 32
TOXIC SUBSTANCES CONTROL ACT (TSCA) 33
CLEAN WATER ACT (CWA) 35
Wastewater Treatment 35
Oil Spill Prevention 39
SAFE DRINKING WATER ACT (SDWA) 42
FEDERAL INSECTICIDE FUNGICIDE AND RODENTICIDE
ACT (FIFRA) 44
SITE EVALUATION 44
Hydrogeology 44
Solid Waste Management Units (SWMUs) 49
REFERENCES
APPENDICES
A OPENING CONFERENCE PARTICIPANTS
B TSCA INSPECTION FORMS
C PELRON A&B MATERIAL AND SAFETY DATA SHEET
D HAZARDOUS WASTE MANIFESTS 87-0395/87001 AND 87-1419/88008
E TELEPHONE CONVERSATION RECORD DATED OCTOBER 7, 1987
F ASBESTOS EXPOSURE ASSESSMENT
G ASBESTOS DISPOSAL PERMIT
H INVENTORY OF TRANSFORMERS AND PCB CONTENT
I PCB QUARTERLY INSPECTION REPORT
J JPG RESTRICTED AREAS MAP
11
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CONTENTS (cont.)
FIGURES
1 Site Location Map 3
2 Support Facilities, South of Firing Line 5
3 Groundwater and Soil Gas Sampling Sites 47
4 Groundwater Monitoring Well Locations for DU Area 48
5 Solid Waste Management Unit Locations 55
6 Solid Waste Management Unit Locations - Enlarged View of
Southern Tip 56
TABLES
1 SWMUs Requiring No Further Investigation 15
2 Solid Waste Management Units Requiring Further Study 16
3 PCB Transformer and Capacitor Locations 34
4 JPG Underground Fuel Storage Tanks 40
5 JPG Underground Storage Tanks Pressure Tested 43
6 JPG Solid Waste Management Units 51
7 EPIC Solid Waste Management Units 53
8 NEIC Solid Waste Management Units 54
in
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EXECUTIVE SUMMARY
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INTRODUCTION
The National Enforcement Investigations Center (NEIC), in August
1989, conducted a multi-media environmental audit of the U.S. Army
Jefferson Proving Ground, Madison, Indiana. This audit was requested by
the Environmental Review Branch, Planning and Management Division,
EPA Region V (Region V) in support of Region V's environmental review of
military installations proposed for closure. The Defense Secretary's
Commission on Base Closure and Realignment issued its report (December
1988) recommending the closure and/or realignment of military bases
nationwide. There are three facilities in Region V which have been
proposed for closure: (1) Fort Sheridan, Illinois; (2) Chanute Air Force
Base, Illinois; and (3) Jefferson Proving Ground (JPG), Indiana. The
results of the NEIC environmental audit at JPG are presented in this
report.
OBJECTIVES
The objectives of the NEIC audit were:
• Determine the compliance status of the JPG operations with
the applicable environmental laws, regulations, permits,
consent decrees, and other related requirements and
conditions. Specifically, NEIC evaluated compliance with the
following:
Resource Conservation and Recovery Act (RCRA) and
Indiana Administrative Code (IAC) Title 320
Clean Air Act (CAA) and LAC Title 326
Toxic Substances Control Act (TSCA)
Clean Water Act (CWA) and LAC Title 330
Safe Drinking Water Act (SDWA)
Federal Insecticide, Fungicide, and Rodenticide Act
(FIFRA)
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• Evaluate the environmental studies and assessments (e.g.,
preliminary assessments, RCRA facility assessment)
conducted at JPG to identify solid waste management units
(SWMUs), and identify areas requiring further study
To accomplish these objectives, NEIC personnel reviewed and
evaluated data from Region V and JPG files, and conducted an on-site
inspection. The on-site inspection was conducted from August 22 through
August 26, 1989 and included:
• Visually inspecting RCRA storage areas, on-site wastewater
treatment plant, incinerators, storage tanks, maintenance
facilities, etc.
• Inspecting and evaluating potential solid waste management
units (SWMUs) identified in previous studies and identifying
new SWMUs
• Reviewing and evaluating selected facility records for the past
3 years including, permits, manifests, inspection records,
facility operating records, polychlorinated biphenyl (PCB)
records, and pesticide use records
• Obtaining copies of selected documents for more in-depth
review at NEIC
BACKGROUND
JPG is located on U.S. Highway 421 approximately 6 miles north of
Madison, Indiana, in portions of Jefferson, Jennings, and Ripley Counties
[Figure 1]. JPG employs approximately 385 people (380 civilian and
5 military). The facility occupies approximately 55,300 acres with
480 structures, 177 miles of roads, and 48 miles of boundary fenceline. The
facility is generally rectangular in shape, about 19 miles north-south, and
5 miles east-west.
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NEBRASKA
VERSAILLES
60
. VERNON
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CW MARICN
^PROVING
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JENNIES C
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SOUHCO: USATMAMA. !
FIGURE 1
LOCATION OF JEFFERSON PROVING
GROUND, MADISON, IN
Prepared for
U.S. Army Toxic and Hazardous
Materials Agency
Ab«rdt«n Proving Ground, Mar/land
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JPG is a Department of Defense (DOD) owned munitions testing
facility operated under the command of the U.S. Army Test and Evaluation
Command (TECOM), Aberdeen Proving Ground, Maryland. The primary
mission of JPG is to plan, conduct, and report the results of production
acceptance tests, reconditioning tests, surveillance tests, and other studies
of ammunition and weapon systems including components of these
systems.
JPG has ordnance test ranges up to 23,000 meters in length,
134 permanent test complexes, 268 gun positions, 50 impact fields equipped
with observation towers or bunkers, and 7 ammunition assembly areas.
Test ranges, impact areas, and buffer zones are located in the 51,700 acres
north of the firing line. The JPG support facilities are located in buildings
south of the firing line [Figure 2] and include: artillery and ammunition
storage areas; a weather station; instrumentation calibration and repair
shops; radar facilities; and photographic laboratories, paint shops, and
vehicle and weapons maintenance areas.
Air contamination stationary sources include incinerators, boilers,
and open burning/open detonation of propellants and explosives. Sanitary
and some industrial wastewater generated at JPG is treated in the on-site
wastewater treatment plant (WWTP). Discharge from the 0.28-million-
gallon-per-day (mgd) hydraulic capacity trickling filter plant is to Harberts
Creek. Wastewater treatment operations and effluent quality are regulated
by the National Pollutant Discharge Elimination System (NPDES) Permit
No. IN 0024210. Hazardous and toxic wastes generated by JPG include
solvents and paint wastes, polychlorinated biphenyls (PCBs), asbestos, and
pesticides. Management of these wastes is regulated by RCRA, TSCA,
CAA, and FIFRA, respectively.
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Ammunition
Processing
Firing Line
Extends from East
to West Boundaries
Industrial
Ammunition
Processing
Ammunition
Disassembly
Figure 2
SUPPORT FACILITIES
SOUTH OF FIRING LINE
Jefferson Proving Ground
Madison Indiana
Source: His lory of JPG
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SUMMARY OF FINDINGS
JPG compliance with applicable regulations and permits and the
NEIC evaluation of previous environmental studies identifying solid waste
management units are summarized below. The summarized findings are
discussed in detail in the "Audit Findings" section of this report.
JPG was not in compliance with the requirements of the Resource
Conservation and Recovery Act, Toxic Substances Control Act, Clean Water
Act, and the Safe Drinking Water Act. The facility was found to be in
compliance with provisions of the Clean Air Act and the Federal
Insecticide, Fungicide, and Rodenticide Act.
Major environmental concerns at JPG include: collection and
disposal of unexploded ordnance; contamination of target areas by explosive
residues and low-level radioactive penetrators; herbicide residues along
roadways and in impact areas; and potential soil, surface water, and
groundwater contamination from on-site activities, including past spent
solvent disposal practices.
Previous environmental assessment studies have been completed by
the U.S. Army Toxic and Hazardous Materials Agency (USATHAMA) and
the U.S. Army Environmental Hygiene Agency (USAEHA) to assess past
use and disposal of toxic and hazardous materials and their potential to
migrate off-site. Regional geologic and hydrologic characteristics of the
area have been described in various reports. However, there has been
insufficient information in these reports to define the hydrologic
characteristics for specific sites within JPG. The solid waste management
units (SWMU) were also identified in these reports and limited sampling
and analysis was recommended for the Gate 19 Landfill and the solvent
disposal areas. However, the reports did not provide enough information to
determine if additional SWMUs should be studied. The SWMUs requiring
further study, including new SWMUs identified during the NEIC
investigation are summarized in the Site Evaluation section of this report.
Some of the sites need to be better defined and located, and others need
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further study to determine the potential for release of hazardous materials
to the environment.
RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
JPG generates and stores hazardous waste, as defined in 40 CFR
261/329, IAC, 3-3-3.* JPG is an interim status facility (RCRA Part B Permit
Application was submitted November 1988) and is subject to the
management requirements of 40 CFR 265/329 IAC 3-3-3. The following
deficiencies in the JPG hazardous waste management program were
identified during the NEIC investigation. The left column cites the
applicable Federal/State regulation and the right column describes the
corresponding deficiency.
40 CFR 262.117 JPG has not identified a solid waste generated on-
329 IAC 3-7-2 site as a hazardous waste. A polyurethane foam,
referred to as Pelron A&B and used to replace
explosive powder in munitions testing, is periodi-
cally contaminated with methylene chloride (the
solvent used to clean the Pelron A&B handling
equipment). The foam itself is reportedly not a
hazardous waste, but when mixed with the spent
methylene chloride (hazardous waste number
F002, as listed in 40 CFR 261.31), this waste foam
becomes a hazardous waste. JPG is handling this
hazardous waste as a nonhazardous waste.
Subsequently, waste handling does not meet the
following RCRA requirements: Improper accu-
mulation [40 CFR 262.34(a)(2)/IAC 3-9-5], storage
in incompatible containers [40 CFR 265.173(a)/IAC
323-4(a)], unpermitted landfilling [40 CFR 265
Subpart N/IAC 3-28], and unpermitted incinera-
tion [40 CFR 265 Subpart 0/IAC 3-29] and
improper disposal of a land disposal restricted
waste [40 CFR 268]. Furthermore, JPG has not
included methylene chloride or incineration and
landfill disposal of spent methylene chloride in the
RCRA Part A permit application submitted with
the Part B application in November 1988 [required
by 40 CFR 270.13].
Reference to Title 40 Code of Federal Regulations (CFR) Part 261 and Title 329,
Indiana Administrative Code (IAC), Article 3-3-3.
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40CFR265.13(bV
329 IAC 3-41-40))
40CFR265.15/
329 IAC 3-41-6(b)
40CFR265.16(d)(3V
329 IAC 3-41-7(d)
40 CFR 265.927
329 IAC 3-20-3
40CFR265.112(aV
329 IAC 3-46-3(a)
40 CFR 265.1747
329 IAC 3-23-4
40 CFR 265.1747
329 LAC 3-23-5
40CFR265.16(dX3)/
329 IAC 3-41-7(dX2)
40CFR265.16(dX4y
329 LAC 3-41-7(dX3)
40 CFR 265.75X
329 IAC 3-44-6
Prior to 1988, JPG did not have a facility waste
analysis plan, inspection, training plan,
groundwater sampling and analysis plan, or a
closure plan. These plans were first prepared as
part of the November 1, 1988 RCRA Part B permit
application.
Containers of hazardous waste were not stored
properly. Four drums of hazardous waste stored
in building 305 could not be properly inspected
without being moved because other containers
prevented complete visual inspection.
Weekly inspection records for building 305 are not
complete. The time of inspection is not recorded
and, prior to October 1987, the inspection records
did not contain the name of the inspector. Also,
there were no inspection records for the 55-gallon
drum of waste 1,1,1-trichloroethane stored in the
southwest corner of building 211. This waste was
generated in building 506 and the drum had an
accumulation start date of "6/17/88." Building 211
is not a JPG designated hazardous waste storage
area.
Training records on file at JPG do not contain the
job descriptions for Kaushik Joshi, environmental
engineer responsible for environmental compli-
ance at JPG or Greg Gatewood, environmental
engineer technician.
Training records on file at JPG do not contain
documentation describing the training/job experi-
ence for Kaushik Joshi or Greg Gatewood.
JPG has not prepared nor submitted biennial
reports identifying facility hazardous waste man-
agement activities to the Regional Administrator.
An annual report identifying hazardous waste
activity is sent to JPG Headquarters, U.S. Army
Test and Evaluation Command. Aberdeen Proving
Grounds (TECOM).
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40 CFR 265.917 The groundwater monitoring system for the Gate
329 IAC 3-20-2 19 Landfill was deficient in the following areas:
Upgradient and downgradient moni-
toring well locations have not been
designated.
The uppermost aquifer has not been
defined.
Monitoring wells are not screened or
perforated and packed with sand at
appropriate depths to collect samples
where aquifer flow zones exist.
40 CFR 268.7(a)(l) A land banned restricted hazardous waste, 1,1,1-
trichloroethane, was shipped for off-site manage-
ment on March 17, 1987 (manifest No. 87-03957
87001) and December 4, 1987 (manifest 87-14197
88008) without the required land ban notifications.
CLEAN AIR ACT (CAA)
The major air emission sources at JPG include open burning/open
detonation of explosives, oil-fired boilers, combustible waste incinerators,
degreasing operations, and open burning of combustible wastes. Air
pollutant emission sources are regulated under Title 326 of the Indiana
Administrative Code (IAC).
The NEIC audit found no areas of noncompliance with the State Air
Pollution Control regulations. Variances from the open burning
requirements of 326 IAC 4-1 were granted by the Indiana Department of
Environmental Management, Office of Air Management, and approved by
the Air Pollution Control Board.
The boilers in building 103 and the incinerators located in buildings
333 and 185 are not required to be permitted due to their small size and
estimated emissions. JPG does not use solvents or volatile organic
compounds (VOC) in sufficient amounts to be regulated by the State VOC
regulation, 326 IAC 8.
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10
National Emission Standards for Hazardous Air Pollutants CNESHAP1 -
Asbestos Removal/Renovation Projects
Asbestos removal projects are regulated by NESHAP, 40 CFR 61,
which has been adopted by reference in the State rule 325 IAC 14-2. No
deficiencies were found with the JPG asbestos removal program. Asbestos
materials are wetted, bagged, and disposed of in the State permitted, on-
site, Gate 19 Landfill. Air monitoring at the asbestos removal project site is
done after the project is completed.
TOXIC SUBSTANCES CONTROL ACT (TSCA)
Polychlorinated biphenyl (PCB) Items are subject to the requirements
of 40 CFR 761. The NEIC investigation found the following deficiencies with
the JPG PCB program:
40 CFR 761.40 Building 102 and the Pyranol* capacitors located
in building 102 were not properly marked with a
PCB Mark (illustrated in 40 CFR 761.45).
40 CFR 761.180 Annual documents for the calendar years of 1987
and 1988 were not prepared.
40 CFR 761.180 PCB item disposal records and annual inventories
for the past 5 years were not available for review.
CLEAN WATER ACT (CWA)
Wastewater treatment operations and effluent quality are regulated
by the National Pollutant Discharge Elimination System (NPDES) Permit
No. IN 0024210. Oil spill prevention procedures are regulated by 40 CFR
112. NEIC identified the following deficiencies with JPG wastewater
handling and spill prevention procedures.
A trade name for listed PCB dielectric fluid liquid.
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11
Wastewater Treatment Plant Operations
NPDES Permit-
Part I.A
NPDES Permit
Attachment A
NPDES Permit,
Part B.5
330.1 IAC 5-2-1
NPDES permit,
Part II A.8
Wastewater discharges do not always meet
NPDES permit effluent limitations. Discharge
monitoring reports (DMRs) submitted to EPA and
the State of Indiana show that WWTP effluent for
outfall 001 exceeded weekly maximum limitations
for total suspended solids (TSS) concentration and
loading (pounds per day) on 17 and 18 days
respectively, between June 1988 and June 1989.
Fecal coliform counts exceeded limits on 1 day
during this time.
JPG discharged bypassed (untreated) wastewater
almost 100 times from June 1, 1988 to June 30,
1989. Although untreated wastewater is combined
with plant effluent prior to monitoring, bypassing
is not allowed by the permit.
The analytical techniques and/or methods used to
analyze wastewater samples for self-monitoring
purposes are not recorded on laboratory bench
sheets or internal laboratory reports from which
the DMRs are prepared.
JPG does not have, and has not applied for, a
domestic sewage sludge land application permit.
Dried sewage sludge generated in the on-site
wastewater treatment plant has routinely
been applied to facility property. The sludge was
stockpiled on the ground at the on-site WWTP
during the NEIC investigation.
Wastewater treatment plant sludge has not been
disposed of in such a manner as to prevent entry
of those wastes (or runoff from the wastes) into
navigable waters or their tributaries. Sludge has
been applied to the land at JPG and was stockpiled
on-site near the WWTP and Harberts Creek
during the NEIC investigation. Sludge
application/storage areas are not protected from
runoff.
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Oil Soill Prevention
12
40 CFR 112.7(0)
40 CFR 112.7(e)(l)(ii)
40 CFR 112.3(a)
Potential oil spill sites at underground storage
tank locations, including buildings 602, 103 and
118, do not have, at a minimum, secondary con-
tainment. Although current spill control struc-
tures (grading, berms, and flap valves) may
contain the spilled material in the general spill
area, some material would soak into unprotected
soils.
Flapper drain valves are used to protect surface
drainage systems at many potential spill loca-
tions, contrary to SPCC guidelines. The flapper
valve located in the drainage southwest of
building 103 was open due to trapped debris.
JPG has not fully implemented the January 1988
SPCC plan. Tank facilities are not inspected daily
nor are piping systems hydrostatically tested twice
a year, as required by item 6.6 of the plan. In fact,
only a single hydrostatic test was conducted (1984).
Testing equipment has reportedly been purchased
by JPG but not yet used. Also, personnel in areas
with underground storage tanks (including
buildings 602, 103, and 118) have not had SPCC
plan training, as required by item 4.5 of SPCC
plan.
SAFE DRINKING WATER ACT (SDWA)
The JPG drinking water supply, servicing 13 family housing units
and a daily combined resident and working population of 450 people, is
provided by the City of Madison, Indiana. Drinking water supply
management is regulated by 40 CFR 141. The following deficiency was
noted.
40 CFR 141.21
Sampling results have shown zero residual
chlorine levels at different JPG locations. The
City of Madison has found residual chlorine levels
of 0.1 mg/L to 0.4 mg/L at the fenceline of JPG.
JPG and the City of Madison have not notified the
State when chlorine levels fell below 0.2 mg/L, as
required.
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FEDERAL INSECTICIDE. FUNGICIDE. AND RODENTICIDE ACT
(FIFRA)
The pest management program includes the control of household
and nuisance pests, weeds, and a land sterilization program. Approxi-
mately 600 acres of impact fields are maintained clear of all vegetation
mainly for personnel safety during unexploded ordnance recovery opera-
tions. The facility was found to be in compliance with the FIFRA
regulatory requirements.
SITE EVALUATION
Hvdrogeologv
The geologic and hydrologic characteristics in the vicinity of JPG
have been described in the referenced studies. However, there has been
insufficient information in these studies to identify the uppermost
aquifer(s) or conclude whether streams flowing across JPG are gaining or
losing water to the underlying bedrock aquifers. To better understand
facility geologic and hydrologic characteristics, surface water monitoring
can be conducted to determine seasonal flow variations and the
groundwater recharge rate. Groundwater gradients, directions, and flow
rates and potential paths of pollutant migration should be determined
across the entire facility.
Marble Creek, Middle Fork Creek, and Harberts Creek rise within
the boundary of JPG. Otter Creek, Little Otter Creek, Graham Creek, and
Big Creek have their headwaters to the north and east of JPG, cross the
facility from northeast to southwest and ultimately discharge into the Ohio
River. To determine seasonal flow variations, creek stream flows should be
gauged in each creek as they enter the facility (north and east facility
perimeters) and along the western perimeter where they each leave the
facility. Surface water quality monitoring at each gauging station should
be conducted to identify contaminants entering the facility from off-site
sources and leaving the facility via surface runoff. This, along with on-site
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14
source identification (SWMUs), will help in locating areas needing further
investigation or remediation.
Solid Waste Management Units
The Solid Waste Management Units (SWMUs) at JPG were initially
identified during the Initial Installation Assessment (IIA) (facility records
review) conducted in March 1980. An update of the IIA was completed in
July 1986 and the final report was issued in January 1988. The SWMUs
identified during these studies were given alpha-numeric numbers (e.g.,
JPG-001).
As part of the U.S. Army Toxic and Hazardous Materials Agency
(USATHAMA) Re-look Program, the USEPA, Environmental Photographic
Interpretation Center (EPIC) in Warrenton, Virginia, was requested to
provide an analysis of historical aerial photos. The EPIC aerial imagery
analysis provided a summary of possible past disposal areas at JPG and
were designated as EPIC sites (possible SWMUs). The EPIC and JPG
SWMUs were discussed in the Final Report of the Groundwater
Contamination Survey, No. 38-26-0306-89, August 8 through 12, 1988 and
May 15 through 18, 1989.
During the NEIC inspection, the previously identified SWMUs were
inspected, locations were verified, and additional information obtained.
Some of the JPG and EPIC SWMUs were confirmed to be the same area.
Additional SWMUs were identified during the NEIC inspection; these were
given NEIC numbers. JPG, EPIC, and NEIC SWMUs are discussed in
more detail in the solid waste management section of this report.
Based on inspection observations and interviews, the following
SWMUs in Table 1 require no further investigation.
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15
Table 1
SWMUs REQUIRING NO FURTHER INVESTIGATION
Jefferson Proving Ground
Madison, Indiana
SWMU
Description
Location
JPG-002
JPG-012
JPG-026
(EPIC-01)
EPIC-07
EPIC-11
Water Quality Laboratory
Indoor Firing Range
Abandoned Landfill
Trenches
Open storage area
Building 177
Building 295
East of Little Otter Dam
2.5 Jines Impact Area
Southwest of Shun Pike and
Woodfill Road intersection
The remaining SWMUs require further study to determine the past
activity at each SWMU and the potential for release of hazardous
substances to the environment. If further information is not available,
sampling and analysis are recommended to determine if releases have
occurred. Table 2 is a summary of the SWMUs requiring further study. A
sampling and analysis plan should be developed according to RCRA
Facility Assessment guidance and, at a minimum, should include the
items listed in the Table 2 comments.
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Table 2
SOLID WASTE MANAGEMENT UNITS REQUIRING FURTHER STUDY
Jefferson Proving Ground
Madison, Indiana
SWMU
JPG-001
JPG-003
JPG-004
(EPIC-17)
JPG-005
(EPIC-17)
JPG-006
jpaoo?
(EPIC-16)
JPG-009
JPG-010
JPG-011
JPG-013
JPG-014
Description
Incinerator
Wastewater treatment plant
Explosive burning area
Abandoned landfill
Open burning area (metal pan burning
area)
Abandoned runway, storage area, and burn
areas
Red lead disposal area
Photographic laboratory
Incinerator
Munition demilitarization area
Past burning ground
Location
Building 185
Building 177
North of southern landfill (JPG-005)
South of Engineers Road and east of Paper
Mill Road
East of Shun Pike, southeast portion of JPG,
Lee Field
Abandoned runway
Unknown, possibly near building 108 and
146
Building 208
Building 333
West of Morgan Road (formerly west and
north of Firing Line Road)
South of Gate 19 Landfill
Commenls
Analyze ash for heavy metals, dioxins,
PCBs, at a minimum
Sample Harberts Creek sediment and
sludge drying bed
Specific location not identified. Locate site
and sample soil
Determine if hazardous constituents are
being released or have been released
Sample soil
Sample soils, run-off areas around storage
and burn areas
Locate disposal sites and sample soil
Locate sewer traps and sample trapped
sediment
Analyze ash for heavy metals and dioxins
and PCBs
Locate site and sample soil
Locate and sample soil. Monitor old rock
quarry for contaminanted discharge
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Table 2 (cont.)
SOLID WASTE MANAGEMENT UNITS REQUIRING FURTHER STUDY
Jefferson Proving Ground
Madison, Indiana
SWMU
JPG-015
(EPIC-8)
jpG-oi6
JPG-017
JPG-018
JPG-019
(EPIC-5)
JPG-020
(EPIC-5)
JPG-021
JPG-022
(EPIC4)
JPG-023
(Southeast
portion of
EPIC-3)
JPG-024,
JPG-U25
(EI'IC-2)
Description
Gate 19 Landfill
Ordnance disposal site (Morgan Road)
Landfill ("B" Road inert ammo dump)
Abandoned well disposal site
Munition test pond, asphalt lined
Macadam test pond
Abandoned well disposal site
Open burning area
Demolition/burning area (Shonk Farm)
Abandoned Landfill
Location
Southwest portion of JPG, near gate 19, west
plant boundary
Located south of "C" Road, just northwest of
an intersection of an access road and
Morgan Road
Eastern perimeter of JPG 4.5 impact
"AVCO Alley"
NW corner "G" Road and Center Recovery
Road
Southwest of 16-C impact range
Southwest of 16-C impact range
Northwest corner "I" Road and Cottrell
Road intersection
Southwest corner of 1600-east impact area,
just east of Cottrell Road
North of Graham Creek and west of
Bombfleld Road
North of "K" Road and west of Northeast
Exit Road
Comments
Re-evaluate groundwater monitoring
wells; additional downgradient wells
required
Sample water and sediment
Sample soil
Sample well water, plug, and abandon well,
as required
Sample drainage culvert sediment
Sample water and sediment
Sample well water, plug, and abondon well,
as required
Sample soil
Sample soil and Graham Creek sediment
in area
Determine past activity, sample soil
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Table 2 (cont.)
SOLID WASTE MANAGEMENT UNITS REQUIRING FURTHER STUDY
Jefferson Proving Ground
Madison, Indiana
SWMU
JPG-027/028
/029
JPG-030
JPG-031
JPO032.033
JPGr034
JPG-035
JPG-036
EPIC-06
EPIC09
EPIC- 10
EPIC 12
EPIC- 13
EPIC- 14
EPIC- 15
Description
Solvent pit
Fire training pit
Metal working shop
Not identified
Weapons maintenance workshop
Equipment maintenance shop
Hazardous waste storage building
4.5 Mortar Impact Range (MIR)
Trenches
Open storage area
Open storage area
Active dump/landfill
Disposal area
Open storage area
Location
Building 602, 617, and 279
Adjacent to abandon runway
Building 105
Unknown
Building 227/shed 11
Building 186
Building 305
Eastern perimeter of JPG north end of York
Road 4.5 MIR
Northwest of railroad tracks intersection
and Woodfill Road
North of building 186
South of EPIC 11
West of building 333
East of Paper Mill Road and north of
railroad tracks
South of railroad switching yard and east of
Paper Mill Road
Comments
Remove contaminated soils, install
groundwater monitoring wells down-
gradient
Sample soils
Sample soils beneath wood floor if and
when building is demolished
Identify locations
Sample soils around shed 11
Sample sludge in oil/water separator
Sample soils of possible spill areas
Investigate past disposal practices and
sample soils
Investigate past disposal practices and
sample soils
Sample soils
Investigate past spills and sample soils
Determine if hazardous substances were
disposed of at site
Sample soils
Sample noiln
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Table 2 (cont.)
SOLID WASTE MANAGEMENT UNITS REQUIRING FURTHER STUDY
Jefferson Proving Ground
Madison, Indiana
SWMU
NEIC-01
NEIC-02
NEIC-03
NEIC-04
NEIC-05
NEIC-06
NEIC-07
NEIC-08
NEIC-09
NEIC-10
NEIC-11
NEIC-12
Description
Unexploded ordnance (UXO) areas
Wastewater treatment plant sludge
disposal area
Underground fuel storage tanks
Roadways north of firing line
Chemical impregnation plant
Herbicide application areas
Oil/water separators
Locomotive maintenance pit
Open burning area
Open burning area
Sandblasting area
Depleted Uranium (DU) area
Location
Areas throughout the facility
Clay bank south of old incinerator near
building 185 and other disposal areas
Facility wide
Facility wide
Location unknown, possibly building 127
Impact areas and roadways
Building 186 and building 110
Building 211
"Z" zone gator mine field test area
Northeast corner of "Z" zone
Building 136
Delta Impact area
Comments
Clean-up of areas will be determined by
final land use decisions
Locate past sludge disposal areas and
sample soils
Test for leaks
Sample roadways sprayed with waste oil for
PCBs
Locate area and sample soil where spills
have occurred
Sample soils
Identify all facility oil/water separators,
clean, and sample sludge
Clean and sample sludge
Sample soils
Sample soils
Sample soils
Identify uppermost aquifer and character-
ize hydrogeological conditions
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TECHNICAL REPORT
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20
INVESTIGATIVE PROCEDURES
The NEIC audit of the Jefferson Proving Ground facility included:
• Collecting and reviewing background data and reports from
Region V and JPG files
• Meeting with Region V staff from the Regional
Administrator's Office, the Environmental Review Branch,
and the Federal Facility Coordinator's Office
• Conducting an on-site facility inspection
The on-site facility inspection took place on August 22 through 26,
1989. Upon arrival at the site an in-briefing was held for Colonel Dennis
O'Brien, the Commanding Officer of the Jefferson Proving Ground and
other facility personnel [Appendix A]. Credentials of all EPA
representatives were presented to Colonel O'Brien and Kaushik Joshi, the
Environmental Coordinator for JPG. Mr. Joshi also signed and received a
copy of a TSCA Notice of Inspection [Appendix B] and a TSCA Inspection
Confidentiality Notice [Appendix B] with an explanation of the Agency's
TSCA Confidential Business Information policy and procedures. JPG
provided EPA personnel with a short safety training session and a brief
slide presentation of facility operations.
After the in-briefing, the inspection proceeded with Mr. Joshi and a
discussion of document control procedures. All documents received from
JPG were logged in a Document Control Log (DCL) by NEIC. The DCL was
used to prepare a Receipt for Samples and Documents [Appendix B].
A log of photographs taken during the inspection was also
maintained. A copy of the photo log was given to Kaushik Joshi at the
completion of the inspection. A copy of the photo log and prints were sent to
the Environmental Review Branch, Region V.
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21
During the course of the investigation, the following documents were
requested and reviewed:
• Permits and correspondence for air emission sources
• List and description of all hazardous waste storage areas
NPDES Permit and Discharge Monitoring Reports (DMRs)
Inspection Procedures and Reports
Installation Spill Contingency Plan and Incident Reports
• Closure Plans
• Annual and Biennial Reports to Regulatory Agencies
• Training Plans and Training Records for selected JPG
personnel
• Regulatory Correspondence Files for the past 5 years
• Pest Management Plan
• Permit files
• PCB Inventory and Inspection Reports
• Hazardous Waste Manifests for the past 3 years
• Groundwater Monitoring Reports and Sampling Results
• Analytical data from various on-site sampling activities
During the review of these documents, selected documents were
copied for a detailed review at NEIC. The document control log contains an
itemized list of copied documents. Generally, the most recent 3 years of
records were requested and reviewed (1986, 1987, and 1988). However,
annual documents, PCB documents, pesticide documents, groundwater
monitoring documents, and environmental studies for earlier years were
reviewed as well.
In addition to the document review, other inspection activities
included:
• Inspecting the solid waste management units (SWMUs)
identified in previous studies
• Accompanying and observing JPG personnel during PCB
inspections
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22
• Inspecting JPG support facilities to identify additional solid
waste management units
• Visually inspecting RCRA storage areas, the on-site WWTP,
incinerators, boilers, maintenance facilities, storage tanks,
etc.
At the end of the on-site inspection, an out-briefing was held and
preliminary inspection observations were discussed with JPG personnel.
Colonel O'Brien and Mr. Joshi were asked if they wished to declare any of
the information or documents received to be TSCA-CBI. None of the
documents received were declared to be TSCA-CBI. A TSCA Declaration of
Confidential Business Information form [Appendix B] and a TSCA Receipt
for Samples and Documents form [Appendix B] were completed for all
documents received during the inspection. Kaushik Joshi signed and
received a copy of both forms.
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23
FACILITY OPERATIONS
JPG is a Department of Defense (DOD) owned munitions testing
facility operated under the command of the U.S. Army Test and Evaluation
Command (TECOM), Aberdeen Proving Ground, Maryland. The primary
mission of the JPG is to plan, conduct, and report the results of production
acceptance tests, reconditioning tests, surveillance tests, and other studies
of ammunition and weapon systems including system components.
JPG has ordnance test ranges up to 23,000 meters in length,
134 permanent test complexes, 268 gun positions, 50 impact fields equipped
with observation towers or bunkers, and 7 ammunition assembly areas.
Most of the test ranges, impact areas, and buffer zones are located in the
51,700 acres north of the firing line. The JPG support facilities are located
in buildings south of the firing line and include: artillery and ammunition
storage areas; a weather station; a wastewater treatment plant; vehicle and
weapons maintenance areas; and extensive instrumentation repair and
calibration shops, radar facilities, and photographic laboratories.
Industrial operations at JPG include maintenance of transportation
equipment and weapons; repair/building/modification of small arms
weapon systems; the disassembly of munitions for test purposes; inert load-
ing and cleaning of munitions; maintenance of electrical calibration
facility; and an instrumentation division where electronic equipment is
designed, fabricated, maintained, and calibrated. A photography labora-
tory processes motion, still, and X-ray films.
Sanitary and some industrial wastewater generated at JPG is treated
in the on-site wastewater treatment plant (WWTP). Discharge from the
0.28-million-gallon-per-day (mgd) hydraulic capacity trickling filter plant is
to Harberts Creek. Wastewater treatment operations and effluent quality
are regulated by the NPDES Permit No. IN 0024210. Hazardous and toxic
wastes generated by JPG include solvents and paint wastes, PCBs,
asbestos, and pesticides.
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24
AUDIT FINDINGS
RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
The Jefferson Proving Ground (JPG) facility generates, stores, and
disposes of hazardous waste, as defined in 40 CFR 26I/Title 329, Indiana
Administrative Code (IAC) 3-3-3. JPG was operating under interim status
during the NEIC investigation and was, thus, subject to the waste
management requirements of 40 CFR 265/329, IAC. The facility submitted
a RCRA Part B Permit Application in November 1988. The permit
application was undergoing Region V review at the time of the NEIC
investigation.
Hazardous wastes generated at JPG include waste propellants and
explosives; spent methylene chloride contaminated polyurethane "filler
material" (Pelron A&B); paint waste and spent thinner (normally mineral
spirits, xylene, or "Stripeze"); spent 1,1,1-trichloroethane; and spent
Stoddard solvent. Hazardous wastes generated in buildings 105 (Stoddard
solvent), 136 (paint sludge/thinner), 186 (Stoddard solvent), 211 (methylene
chloride contaminated Pelron A&B), 227 (Stoddard solvent, paint sludge),
and 506 (1,1,1-trichloroethane) are accumulated within, or near, the
generating building until removed for storage in building 305 (designated
on-site hazardous waste storage building). The satellite accumulation
areas vary from designated areas within each building (105, 136, 506) to
designated areas immediately outside of the building (186 and 211) to a
nearby storage shed (227).
Waste propellants (RCRA reactive wastes) are burned on-site at the
open burning (OB) area in the southeast portion of the facility. Propellants
are spread in steel burn pans and ignited. Ash from the burn pans is
periodically removed and analyzed for RCRA characteristics. The ash has
recently been EP Toxic for lead. The lead probably originated from the
"lacing jackets" surrounding the powder load. Lacing jackets consist of
silk collars lined with lead foil that enhance gun tube lubrication and
cooling during firing. Other sources of lead may be the lead azide and other
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25
lead compounds present in the powders. The EP Toxic ash was in storage
in building 305 during the NEIC investigations.
Waste explosives are destroyed at the open detonation/open burning
(OD/OB) area located in the north central portion of the facility and referred
to as "Shonk Farm." Small arms munitions and items such as grenades
are burned in a large steel "burn cage" at this location (the steel mesh helps
contain metal fragments). Larger munitions are often buried prior to
detonation or detonated on the surface of the ground.
Methylene chloride contaminated polyurethane foam waste
(Pelron A&B) has been burned in on-site incinerators and buried in on-site
landfills. Paint and spent solvent wastes generated on-site are disposed of
off-site through Defense Reutilization and Marketing Service (DRMS)
contractor (the on-site DRMS office reportedly does not handle hazardous
wastes).
Pentachlorophenol (PCP) treated wood boxes are stored outside on the
JPG abandoned airport runway. Most of the boxes are eventually crushed
and disposed of off-site. However, some PCP contaminated wood may have
been burned with other scrap wood in an adjacent waste material pile
(wood, fibre and steel drums, paper, plastic, etc).
Additional description of JPG waste management practices and
treatment and disposal locations is presented in the section of this report
discussing solid waste management units.
The NEIC investigation identified the following problems regarding
the management of hazardous wastes at JPG.
Waste Identification
JPG has not properly identified a solid waste generated on-site as a
hazardous waste, as required by 40 CFR 262.11/329 IAC 3-7-2. A
polyurethane foam, Pelron A&B [Appendix C], used in munitions testing to
replace explosive powder, is periodically contaminated with spent
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26
methylene chloride (RCRA waste code F002), the solvent used to clean the
Pelron A&B handling equipment. According to manufacturer information
[Appendix C], the foam itself is reportedly not a hazardous waste.
However, the foam becomes a hazardous waste when mixed with the spent
methylene chloride according to 40 CFR 261.3(2)7329 IAC 3-3-3.
JPG has handled this material as nonhazardous, apparently based
on the assumption that the methylene chloride is highly volatile and will
evaporate prior to disposal. The waste has not been analyzed to determine
the presence or absence of residual methylene chloride (the waste has only
been analyzed for EP Toxicity and corrosivity).
Storage and disposal of this waste material is not in compliance with
the requirements of 40 CFR 262, 265, and 268. For instance, the 25-gallon
fibre drums used to contain the waste are marked as "Non-hazardous"
rather than hazardous. More than 55 gallons of the waste have been
accumulated at a satellite accumulation area at building 211, in
noncompliance with 40 CFR 262.34(c)(l)/329 IAC 3-9-5 (the drums did not
have accumulation start dates so this area would not be identified as a
90-day accumulation area in compliance with 40 CFR 262/329 IAC 3-9-5).
JPG has not stored the spent methylene chloride in compatible containers,
as required by 40 CFR 265.172/329 IAC 3-23-3. Spent methylene chloride
(volume estimated to be between a couple of ounces to a quart per 25-gallon
drum) is either poured directly on the waste foam present in a 25-gallon
fibre drum or placed in a disposable drinking cup and then thrown into the
drum. The methylene chloride can easily soak into the fibre drum and seep
or evaporate out. Also, containers of methylene chloride contaminated
Pelron A&B, stored on the second floor of building 185, are not kept closed,
as required by 40 CFR 265.173(a)/329 IAC 3-23-4(a).
Methylene chloride contaminated Pelron A&B has been disposed of in
the on-site landfill (dates unknown). The on-site landfill is not permitted to
receive hazardous waste and was not reported on the facility RCRA Part A
permit application and, therefore, is not an authorized interim status
hazardous waste disposal site. Also, the landfill does not meet the landfill
requirements of 40 CFR 265 Subpart N/329 LAG 3-Rule 28. Additionally,
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27
methylene chloride is a land disposal restricted waste and, according to
40 CFR 268, must not be landfilled unless it meets the appropriate
treatment standards (because the waste was never analyzed for methylene
chloride residual, the concentration of the solvent in the waste is
unknown). Methylene chloride contaminated Pelron A&B has been
incinerated on-site in incinerators that do not meet the requirements of
40 CFR 265 Subpart 0/329 IAC 3-Rule 29.
Required Plans
Prior to 1988, JPG did not have a facility waste analysis plan [40 CFR
265.13(b)/329 IAC 3-41-4(b)], a groundwater sampling and analysis plan
[40 CFR 265.92/329 IAC 3-20-3], an inspection plan [40 CFR 265.15(b)(D], a
training plan [40 CFR 265.16(d)(3)/329 IAC 3-41-7(d)], groundwater
sampling and analysis plan [40 CFR 265.92/329 IAC 3], or a closure plan
[40 CFR 265.16.110/329 IAC 3-46-3(a)]. These plans were apparently first
prepared as part of the November 1, 1988 facility RCRA Part B permit
application.
Inspections
Hazardous waste containers were not stored to allow for complete
visual inspection without being moved, as required by 329 IAC 3-23-4. Four
drums of hazardous waste were stored between the building 305 wall and
other containers and could not be completely inspected. Also, the lighting
in the building was not sufficient to allow for easy visual inspection of
stored containers.
Weekly inspection records for building 305 do not contain all the
information required by 40 CFR 265.15(d). The time of inspection is not
recorded. Prior to October 1987, the records did not contain the name of the
inspector.
Also, there were no inspection records, as required by 40 CFR
265.174/265.15(d), for building 211 where a 55-gallon drum of waste 1,1,1-
trichloroethane (generated in building 506 with an accumulation date of
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28
"6/17/88") was stored in the southwest corner of this building. JPG
personnel stated that this was not a designated hazardous waste
accumulation or storage area. The drum had been moved from building
506 to 211 "one or two days" before the NEIC inspection because the on-site
Defense Reutilization Materials Office (DRMO) would not accept the drum
for disposal* and the building 211 forklift had been used to move the drum
initially.
Because the drum was in storage in building 506 for greater than 90
days, building 506 must be considered a storage area. JPG must modify the
RCRA Part B application to include the unit, or submit a closure plan
under 40 CFR 265 in order to return to generator status for this building
once closure is complete.
Personnel Training
Training records on file at JPG do not contain the job descriptions for
the JPG environmental engineer (Kaushik Joshi) or the environmental
engineer technician (Greg Gatewood) responsible for environmental
compliance at JPG, as required by 40 CFR 265.16(d)(2)/329 IAC 3-41-7(d)(2).
The only job description in the training file was one for "munitions
technician."
Training records on file at JPG do not contain documentation
describing the training/job experience for Kaushik Joshi or Greg Gatewood,
as required by 40 CFR 265.16(d)(4)/329 IAC 3-41-7(d)(3). Kaushik Joshi
indicated he had obtained proper training but apparently did not have the
records in the file. Greg Gatewood had been employed at JPG for less than
1 year at the time of the NEIC audit.
The drum was taken directly to the on-site DRMO which refused to accept the
material. By agreement, hazardous waste generated by JPG is disposed of by an off-
site DRMO. The drum should have been taken to building 305 for on-site storage.
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29
Biennial Reports
JPG has not prepared nor submitted biennial reports identifying
facility hazardous waste management activities to the Regional
Administrator/State of Indiana, as required by 40 CFR 265.75/329 IAC
3-44-6. Semiannual reports identifying hazardous waste activity at JPG are
prepared and sent to JPG Headquarters, U.S. Army, TECOM, Aberdeen
Proving Grounds. JPG personnel did not know whether Headquarters
used this information to prepare and submit the required biennial report to
EPA. However, if biennial reports are filed by JPG Headquarters, JPG is
not provided a copy.
Land Disposal Restrictions
JPG generates land disposal restricted (land ban) hazardous wastes,
including 1,1,1-trichloroethane and methylene chloride. One 55-gallon
drum of waste, 1,1,1-trichloroethane was shipped for off-site management
on March 17, 1987 (manifest No. 87-0395/87001, Appendix D), and one
shipped on December 4, 1987 (manifest 87-1419/88008, Appendix D) without
the required land ban notifications [40 CFR 268.7(aXD]. The manifest for a
shipment of waste 1,1,1-trichloroethane on November 29, 1988 did include
the required land ban notification.
CLEAN AIR ACT (CAA)
The major air emission sources at JPG include open burning/open
detonation of explosives and propellants, oil-fired boilers, combustible waste
incinerators, degreasing operations, and open burning of combustible
wastes. Air pollutant emission sources are regulated under Title 326,
Indiana Administrative Code (IAC).
Open Burning/Open Detonation of Explosives/Propellants
The Indiana Department of Environmental Management, Office of
Air Management granted JPG two variances from the open burning
requirements of 326 Indiana Administrative Code (IAC) Article 4-1. The
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30
variance, APC-4310, was granted on December 27, 1988 (expires on
January 1, 1990) and allows for the controlled burning of unserviceable
artillery propellants, explosives, and natural growth such as fire breaks.
The second variance, FT-2161, was granted on March 2, 1989 (expires on
March 1, 1990) and allows the open burning of minimal amounts of fuel oil
and scrap wood for fire training purposes.
The open burning area for propellants is located just east of Shun
Pike Road in the southeast portion of JPG. The propellants are burned in
metal pans. The variance allows a maximum of 4,000 pounds per day to be
burned. During the last 5 years, an average of 60,000 pounds per year of
propellants were burned. About 90,000 pounds were burned in 1988. This
area has been identified as solid waste management unit (SWMU) JPG-006.
The open detonation/open burning (OD/OB) area (Shonk Farm) is
located in the north central portion of the installation, north of Graham
Creek and west of Bombfield Road. The OD/OB area covers several acres
where munitions are detonated in open pits and small munitions
(grenades, small caliber shells, fuses, etc.) are burned in a 25-foot by 6-foot
burn cage. This area has been identified as SWMU JPG-023.
The fire training pit is located adjacent to the abandoned airport
runway. Wood debris soaked with diesel fuel and other petroleum products
are ignited and burned in an unlined 20-foot by 10-foot by 2-foot deep pit.
This area has been designated JPG-031. Located nearby on the abandoned
west runway are piles of wood debris, railroad ties, etc. that are also burned
periodically. These areas have been designated JPG-007 and JPG-008.
Incinerators
JPG has two combustible waste incinerators located in buildings 333
and 185. Both incinerators have been registered with the State Department
of Environmental Management. The incinerators are not currently
required to have permits to operate due to their small size and estimated
emissions. However, any change in operation which may result in a
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31
change in emissions, exceeding those specified in 325 IAC 2-1.1-1 must be
submitted to the Air Pollution Control Board.
Building 333 Incinerator
The incinerator is a Pilbrico Model 489 multiple chambered
incinerator equipped with a No. 2 fuel oil fired afterburner. The unit was
installed in 1973 and is designed to burn 1,000 pounds of waste per hour.
The stack is 25 feet tall and 3 feet in diameter. The incinerator has not been
stack tested to determine compliance with the particulate emission
requirements of 325 IAC 4-2. The incinerator was not operating at the time
of the inspection. JPG personnel stated that the incinerator is now only
used to burn classified papers.
JPG personnel stated that the incinerator has only been used five or
six times in the past year. The latest burn was on August 17, 1989 when
waste photographic film from building 311 was incinerated.
Building 185 Incinerator
The incinerator in building 185 is a single chambered incinerator
and was fueled with No. 2 fuel oil. The unit is no longer used and the fuel
lines have been disconnected. The building is now used to store chlorine
bottles for the wastewater treatment plant. Also stored in the building were
30 25-gallon fibre drums of Pelron A&B wastes contaminated with
methylene chloride.
Pelron A&B is an inert filler used to manufacture inert ammunition
rounds in building 211. Methylene chloride is the solvent used to clean and
remove the waste Pelron from the ammunition loading equipment. The
waste Pelron and methylene chloride is collected in 25-gallon fibre drums
for disposal. In October 1987, the Indiana Air Management, Enforcement
Branch, Plan Review and Permit Office was contacted to determine if JPG
was required to obtain a permit to incinerate the subject waste. According
to a JPG telephone conversation record [Appendix E], Mr. Frank Profit
responded that the generation rate is below the regulated amount,
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32
therefore, JPG is exempted from the regulatory requirement to obtain a
permit. He further stated that there is no notification, recordkeeping, or
reporting requirements of the Air Pollution Control Regulations that would
be applicable to JPG. Classification of this waste is discussed in the RCRA
findings section of this report.
Test burns of the Pelron wastes were conducted in February and
March of 1988, in the building 333 incinerator, but proved to be
unsuccessful. The temperature in the primary chamber could not be
raised high enough to incinerate the waste. In May and again in August
1988, 30 to 40 drums of the wastes were incinerated in the building 185
incinerator. Initially, the waste was incinerated successfully, but problems
were later encountered with plugging of the firing chamber and the ash
removal system. Incineration was abandoned as a disposal method for the
Pelron waste. Since then, the Pelron waste continues to be stored in
building 185.
Boilers
JPG has three small No. 2 fuel oil boilers located in building 103 for
space heating. Two of the boilers are rated at 700 horsepower (hp) each and
the third is rated at 300 hp. None of these units require a Permit to Operate.
The fuel oil is stored in four 25,000-gallon underground storage tanks. The
boilers use propane, stored in two 300-gallon storage tanks, for initial
start-up.
Degreasing Operations
JPG does not use volatile organic compounds (VOC) in amounts
large enough to be regulated by the State VOC regulation, 326 IAC 8.
Asbestos Removal and Renovation Projects
The emission standard for asbestos removal projects is found in the
National Emission Standards for Hazardous Air Pollutants (NESHAP),
40 CFR Part 61, adopted by reference in the State rule 325 LAG 14-2. JPG
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33
conducted an asbestos exposure assessment [Appendix F] and identified
areas for asbestos removal. JPG currently has five trained and EPA
certified personnel to conduct asbestos removal projects. Asbestos
materials are wetted, bagged, and disposed of in the State permitted on-site,
Gate 19 Landfill. The State permit and conditions for asbestos disposal are
included in Appendix G. No asbestos removal projects were active during
the NEIC investigation. The asbestos disposal area in the Gate 19 Landfill
was inspected and found to be covered, as required by 40 CFR 61.156(c)(l).
There was one instance in 1988 when the State was not notified prior to
asbestos removal in building 311. JPG removed asbestos insulated pipe
from building 311 on August 3, 1988 and disposed of the asbestos on
August 5, 1988. The late notification was sent on August 17, 1988 in
violation of 316 LAC 14-2 which requires notification of an asbestos removal
project at least 1 day prior to the project start date.
TOXIC SUBSTANCES CONTROL ACT (TSCA)
JPG has PCS items at the facility that are subject to management
and recordkeeping requirements of 40 CFR 761.
An inventory of PCB items was prepared by JPG in 1980 and testing
for PCB content was conducted in 1982. The latest inventory (date
unknown) of transformers and PCB content is contained in Appendix H.
Table 3 contains a listing of the PCB transformers and capacitors at JPG.
The PCB transformers are inspected quarterly by Buildings Maintenance
branch and the quarterly reports are prepared by the Branch Chief.
Quarterly Reports from January, 1987 thru April, 1989 are contained in
Appendix I. JPG notified the City of Madison fire department of all PCB
transformers and their location on February 5, 1986.
NEIC inspected the PCB transformers identified in Table 3. No leaks
were observed from any of the PCB equipment at the time of the inspection.
All the PCB transformers and building entrances were properly marked.
However, it was noted that building 45 contains three Weaver 25 KVA
transformers. Only two of the transformers are listed as PCB transformers,
Serial Nos. 16735 and 16737. The third Weaver transformer which appears
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Table 3
PCB TRANSFORMER AND CAPACITOR LOCATIONS
Jefferson Proving Ground
Madison, Indiana
Transformer
House No.
104
45
45
504
5O4
504
542
Capacitor
102 Substation
102 Substation
Manufacturer
Westinghouse
Weaver Electric
Weaver Electric
General Electric
General Electric
General Electric
Uptegraff
Size (KVA)
25
25
25
50
50
50
25
Serial No.
572292
16735
16737
B395368
B395369
B395389
24008
PCB Content
(ppm)
1072
907
777
640
627
1648
741
General Electric
General Electric
180KVAR
180KVAR
EK247
—
Pyranol
Pyranol
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35
to be identical to the other two, is not marked as a PCB transformer. The
transformer should be retested for PCB content.
Building 102 contains two 180KVAR General Electric capacitors
banks (serial number EK247). Each bank contains 12 single 15KVAR
Pyranol* capacitors containing 1.4 gallons of liquid each. The capacitor
banks and the building entrance were not marked with PCB marks, as
required by 40 CFR 761.40.
The annual PCB documents required by 40 CFR 761.180 have not been
prepared for the calendar years of 1987 and 1988. The annual document for
calendar year 1986 was submitted to the Regional Administrator on July 15,
1987. PCB item disposal records and an annual inventory were not
available for review during the inspection, as required by 40 CFR 761.180.
PCB items for disposal are stored in building 305 awaiting transfer
and disposal by DRMS. At the time of the inspection, the following items
were in storage for disposal; two 5-gallon containers of PCB liquid, and one
General Electric 5 KVA transformer Serial No. 6693246, PCB content 274
ppm. The items were placed in storage on August 16, 1989 and were
properly marked. The items were placed in metal pans for secondary
containment.
CLEAN WATER ACT
Wastewater Treatment
Sanitary, and some industrial wastewater (wastewater from photo
developing - about 200 gallons per day, and boiler blowdown - about 300 gal-
lons per day) generated at JPG are treated in the on-site wastewater treat-
ment plant (WWTP). The WWTP has a hydraulic capacity of about
0.28 million gallons per day (mgd). Treatment consists of primary
sedimentation/sludge digestion (Imhoff tank), trickling filtration, sec-
Pyranol is a listed PCB dielectric fluid trade name.
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36
ondary filtration, chlorination (summer only) and pressure filtration.
After flow monitoring, discharge is to Harberts Creek.
Effluent quality is regulated by National Pollutant Discharge
Elimination System (NPDES) permit No. IN 0024210 (expired July 31, 1989)
but in effect until a new permit is issued). Laboratory analysis required by
the NPDES permit is conducted on-site at the WWTP.
Sludge from the Imhoff tank is dried in an on-site sludge drying bed.
Dried sludge has been applied to numerous areas of the facility, including a
clay bank south of building 185. Sludge was stockpiled near the WWTP
during the NEIC investigation. The sludge will be removed once the facility
decides on a disposal location.
Sludge analysis in September 1983 showed EP toxicity (RCRA) for
heavy metals to be below detectable levels except for silver. The silver
content was 2.49 mg/L, which is below the 5 mg/L minimum to be
considered a RCRA-regulated waste. Silver comes from wastewater
discharged from the on-site photographic laboratory.
The JPG wastewater treatment/collection system receives large
quantities of stormwater from sewer infiltration and flow into low lying
manholes. WWTP influent flows greater than about 0.28 mgd (the
hydraulic capacity of the plant) are bypassed. The bypassed (untreated)
wastewater joins treated effluent prior to effluent monitoring. At times,
this combined flow exceeds NPDES permit effluent limitations for total
suspended solids.
JPG and the State of Indiana entered into a Consent Decree/Final
Order (Case No. B-805) in 1983, most recently modified March 14, 1986,
addressing the infiltration/bypassing problem and requiring JPG to meet
permit requirements by December 31, 1986. In July 1986, JPG requested a
permit modification. A revised permit which identified outfall 002 as a
"prohibited" stormwater bypass discharge point was issued October 28, 1987
(expired July 31, 1989 but in effect until a new permit is issued). The permit
required reporting of all bypassing incidences.
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37
Wastewater treatment operations and procedures at JPG were
evaluated for compliance with NPDES permit procedures. The following
section describes findings of the wastewater treatment investigation.
Effluent Limitations/Bypassing
JPG has discharged wastewater that does not meet the effluent
limitations required by NPDES Permit Part LA. Discharge Monitoring
Reports (DMRs) submitted to EPA and the State of Indiana show that
WWTP effluent exceeded weekly maximum limitations for total suspended
solids (TSS) concentration (15 milligrams per liter) on 17 days from June 1,
1988 to June 30, 1989. Effluent exceeded TSS quantity limitations (50 pounds
per day) on 18 days during the same time period. Fecal Coliform limits
(weekly geometric mean of 400 colonies per 1,000 milliliters) were also
exceeded on one occasion during the time period.
TSS exceedences are generally caused by stormwater infiltration.
Numerous remedial projects have failed to reduce the wastewater inflow
rate to treatable levels. The latest project, replacement of about 28,000 of the
52,000 feet of sewer line, was about 95% complete during the NEIC
investigation. Manholes were not all sealed and other finishing work was
not completed. The total effectiveness of the sewer replacement project will
not be known until the project is complete, sometime in the spring of 1990.
JPG personnel believe that when completed, the most recent sewer
system upgrades will reduce stormwater flow to the WWTP to below the
hydraulic capacity of the plant and allow for full treatment.
Attachment A of the JPG NPDES permit prohibits the discharge of
untreated (bypassed) wastewater. Wastewater bypassed the JPG WWTP
almost 100 times from June 1, 1988 to June 30, 1989, mainly due to
stormwater infiltration problems.
Wastewater was bypassing the wastewater treatment plant during
the NEIC investigation on August 24, following heavy rain. Fine clay
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38
material observed in the primary clarifier indicated that stormwater was
still infiltrating the sewer system.
Recordkeeping
The analytical techniques or methods used to analyze wastewater
samples for self-monitoring are not recorded on laboratory bench sheets or
internal laboratory reports from which the DMRs are prepared, as required
by NPDES Permit, Part B.5. Laboratory notes were reviewed and none
identified analytical techniques or methods used in wastewater analysis.
Analytical Procedures
The thermometer used for fecal coliform incubation is calibrated in
1 °C increments. The temperature requirement for fecal coliform is 44.5
±0.2 °C, therefore, a thermometer reading at least 0.2 °C increments is
necessary for appropriate temperature determination.
Sludge Handling
JPG has not applied for a domestic sewage sludge land application
permit required by Indiana Code 330.1 IAC 5-2-1. Dried sewage sludge
generated in the on-site wastewater treatment plant ("about two dump
truck loads per year") has routinely been applied to facility property as well
as given away for off-site use. During the NEIC investigation, dried sludge
was stockpiled on the ground at the WWTP. JPG is investigating disposal
alternatives for the material.
Dried wastewater treatment sludge has not been disposed of in such
a manner as to prevent entry of the sludge (or runoff from the sludge) into
navigable waters or their tributaries as required by NPDES permit, Part II
A.8. Sludge applied to the land at numerous locations and currently
stockpiled on-site at the WWTP is not contained or protected from
precipitation. Therefore, sludge or sludge constituents could enter on-site
drainages, such as Harberts Creek (located just south of the WWTP area
where sludge was stockpiled).
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39
Oil Spill Prevention
JPG stores fuel oil and gasoline in underground tanks [Table 4] and,
therefore, must follow the provisions of 40 CFR 112 for prevention of oil
pollution. JPG has prepared a Spill Prevention, Control and Countermea-
sures (SPCC) Plan (January 1988) that addresses oil spill prevention and
response. JPG has implemented a plan to remove inactive underground
storage tanks. At the time of the NEIC investigation, seven tanks had been
removed, including those associated with buildings 617, 303, and 310. A
discussion of the findings of the evaluation of JPG oil spill control
procedures follows.
Secondar C
Fuel loading and unloading facilities associated with underground
storage tank locations, including those at buildings 602, 103 and 118, do not
have, at a minimum, oil spill preventive systems (secondary containment)
required by 40 CFR 112.7(c). Although current spill control structures
(grading, partial containment berms, and flap valves) may contain the
spilled material in the general spill area, some material would soak into
unprotected soils. In fact, a spill from the building 103 area earlier in 1989
(reported to EPA), although retained in the adjacent surface drainage
channel, required removal and disposal of oil contaminated soil.
Flapper drain valves are used to protect surface drainage systems
serving potential spill areas contrary to SPCC guidelines in 40 CFR
112.7(e)(lXii). The flapper valve for the surface drainage system south of
building 103 was not completely closed because debris had partially blocked
the flap. Oil spilled into this drainage system may be released through the
valve. The flapper valve for the surface drainage adjacent to the south of
building 602 was open during the NEIC inspection on August 24, 1989.
Liquid in the drainage did not appear to be flowing (although rain had
fallen the previous day) and, thus, the valve should have been closed.
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Table 4
JPG UNDERGROUND FUEL STORAGE TANKS*
Jefferson Proving Ground
Madison, Indiana
Location
Capacity
(gallon)
Installed
Fuel Type
Material
Underground Storage Tanks in Active Use (September 1987)
B-602
B-617
B-103
B-333
B-530
B-156
B-184
B-118
B-236
B-125
B-313
B-481
B488
B-33
B-127
B-325
B-189
B-211
B-149
B-322
B-281
B-23
B-21
B-17
B-15
B-ll
1,000
25,000
25,000
25,000
25,000
25,000
550
10,000
4,000
1,000
300
12,000
12,000
12,000
25,000
1,000
1,000
1,000
1,000
1,000
500
1,000
1,000
1,000
500
500
500
500
1,000
500
500
500
500
500
500
**
**
1941
1941
1952
1952
1985
1975
1978
1983
1968
1942
1942
1942
1942
1942
1943
1941
1941
1941
**
**
1941
1953
1953
1953
1942
**
1942
1942
**
**
**
**
**
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Diesel fuel number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Unleaded gas
Unleaded gas
Diesel fuel
Fuel oil number 2
Leaded gas
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
steel
steel
steel
steel
steel
steel
steel
steel
steel
steel
steel
steel
steel
steel
steel
steel
steel
steel
**
**
**
**
**
**
**
**
**
**
**
**
**
**
**
**
**
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Table 4 (cont.)
JPG UNDERGROUND FUEL STORAGE TANKS*
Jefferson Proving Ground
Madison, Indiana
Location
Capacity
(gallon)
Installed
Fuel Type
Material
Underground Storage Tanks in Active Use (September 1987)
B-7
B-3
B-l
B-2
B-8
B-12
B-16
B-20
B-510
B-266
B-265
500
500
500
500
500
500
500
500
500
500
500
**
**
**
**
**
**
**
**
1941
1941
1941
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
**
**
**
**
**
**
**
**
**
**
**
Underground Storage Tanks Temporarily Out of Service (September 1987)
B-602
B-617
B-310
Airport
B-118
25,000
25,000
25,000
25,000
25,000
25,000
25,000
1,000
1952
1952
1952
1952
1941
1941
1941
1952
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
steel
steel
steel
steel
steel
steel
steel
steel
Underground Storage Tanks Permanently Out of Service (September 1987)
B-118
B-291
625
550
550
14,000
14,000
1943
1943
1943
1943
1943
Kerosene (registered with state)
White gas (registered)
Fuel oil number 1 (registered)
B-291's tanks not registered
with state
steel
steel
steel
steel
steel
* As listed in the JPG January 1988, JPG Spill Prevention Control and Countermeasure
Plan
* * Unknown at current time
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42
SPCC Plan
JPG has not fully implemented the facility January 1988 SPCC plan,
as required by 40 CFR 112.3(a). Tank facilities are not inspected daily nor
are piping systems hydro statically tested biannually, as required by item 6.6
of the plan. Some tanks were pressure tested in 1984 and 1986 [Table 5].
JPG has purchased testing equipment, but the equipment has not yet been
used. Tank facilities are reportedly only routinely inspected during tank
loading.
JPG personnel working in potential spill areas (areas with under-
ground storage tanks, including buildings 602, 103, and 118) have not had
SPCC plan training, as required by item 4.5 of the plan. The SPCC plan has
been disseminated to each appropriate building but building personnel have
not been formally trained. Fire department personnel have received SPCC
training (item 4.5 of SPCC plan).
SAFE DRINKING WATER ACT (SDWA)
The JPG community water supply, provided by the City of Madison,
Indiana, services 13 family housing units and a daily resident and working
population of 450 people. JPG has approximately 112,000 linear feet of water
distribution lines and daily consumption is approximately 40,000 gallons.
Sampling for coliform and residual chlorine is done by the City of
Madison at the JPG fenceline. JPG samples its water supply for coliform
twice weekly with a Millipore Hach Kit. The water is sampled for residual
chlorine five times per week using DPD tablets or orthotolidine. JPG
personnel reported that sampling results have shown zero residual
chlorine at different locations, but the City reports residual chlorine levels
of 0.1 mg/L to 0.4 mg/L. As required by 40 CFR 141.21, when residual
chlorine levels fall below 0.2 mg/L, the levels shall be reported to the State
within 48 hours. No notifications have been made to the State.
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Table 5
JPG UNDERGROUND STORAGE TANKS PRESSURE TESTED
Jefferson Proving Ground
Madison, Indiana
Location
Capacity
(gallon)
Installed
Fuel Type
Date Tested
Underground Storage Tanks Pressure Tested
B-333
B-310
Airport
B-602
B-617
B-118
B-103
10,000
25,000
25,000
25,000
1,000
25,000
12,000
12,000
12,000
25,000
1,000
25,000
25,000
25,000
25,000
1975
1941
1941
1941
-
-
1942
1942
1942
1952
1952
1941
1941
1952
1952
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Unleaded gas
Unleaded gas
Diesel fuel number 2
Fuel oil number 2
Leaded gas
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
Fuel oil number 2
06/08/84
06/11784
06/11784
06/12/84
06/18/84
06/19/84
06/22/84
03/11786
06/13/86
06/26/84
06/21784
06/29/84
07/02/84
07/03/84
07/06/84
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44
FEDERAL INSECTICIDE. FUNGICIDE. AND RODENTICIDE ACT
(FIFRA)
The Directorate of Engineering and Housing is responsible for the
pest management program at JPG. Pesticides and herbicides are applied
by a certified applicator. The pest control facility is located in building 204.
Application equipment includes a 400-gallon tank-equipped armored
personnel carrier, 300-gallon tank-equipped trailer, 50-gallon tank-
equipped tractor, and two 1-gallon sprayers. The pest control program
includes the control of household and nuisance pests, weeds, and a land
sterilization program. Approximately 600 acres of impact fields are
maintained clear of all vegetation, mainly for observation of munitions
impact during testing and personnel safety during unexploded ordnance
(UXO) recovery operations.
Building 204 was inspected for compliance with the FIFRA
requirements. The building had adequate spill protection, ventilation,
personnel protection, safety shower, eye wash, clothing and change area,
and appropriate signs. The mixing area sink drained to a tank for recovery
and future use.
Application records (daily use records and monthly command
reports) are kept at building 204. The facility inventory of pesticides is
prepared monthly and sent to the Environmental Engineer, Fire
Department, Health Clinic, and the Safety Supervisor. The training
records were up to date with the handler Certification due to expire on
March 2, 1991. The facility was found to be in compliance with the
regulatory requirements of FIFEA.
SITE EVALUATION
Hydrogeologv
The geologic and hydrologic characteristics of the JPG vicinity have
been described most recently in the Remedial Investigation - Jefferson
Proving Ground - Technical Report A011, prepared by Environmental
-------
Sciences and Engineering, Inc., for the U.S. Army Toxic and Hazardous
Materials Agency (USATHAMA), June 1989. The hydrogeological
information presented in this report is general and seems to accurately
describe the regional hydrogeology. However, the information is not
specific for JPG and cannot be assumed to be applicable to JPG or to specific
sites within JPG. Therefore, JPG is not in compliance with 40 CFR 265.91
and270.14(cX2).
According to the report, JPG is underlain by unconsolidated glacial
deposits near the surface (0 to 50 feet thick) and bedrock consisting of
dolomite, limestone, sandstone, and shale. The glacial deposits have been
dissected by erosion along the major creeks which flow across the facility
generally in an east-northeast to west-southwest direction. Several of these
drainages intersect shallow bedrock. A map and accompanying text
concerning bedrock lineaments and fracture traces7 at JPG indicate that
surface drainage patterns are, at least in part, controlled by these bedrock
features and that there has been some dissolution of limestone and dolomite
in the area. This is further evidenced on the topographic map by the pres-
ence of sink holes (karst topography) near Graham Creek and "Shonk
Farm." Therefore, it is concluded that surface streams and bedrock
aquifers are hydraulically interconnected. There is insufficient informa-
tion, however, to conclude whether the streams flowing across JPG are
gaining water from or losing water to the underlying bedrock aquifers.
Stream flow characteristics and hydraulic head differences between the
streams and underlying aquifers undoubtedly differ from place to place and
seasonally throughout JPG.
Marble Creek, Middle Fork Creek, and Harberts Creek rise within
the boundary of JPG. Headwaters of Otter Creek, Little Otter Creek,
Graham Creek, and Big Creek are to the north and east of JPG, and flow
across the facility from northeast to southwest, ultimately discharging into
the Ohio River.
To determine seasonal hydrogeological variations and to identify any
contaminants that are entering/leaving the facility, stream flow rates and
water quality should be monitored at facility boundaries. Groundwater
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46
sampling should include analysis for metals, herbicides, and explosive
residues.
Groundwater gradients, directions, and rates of groundwater
movement and potential paths of pollutant migration should be determined
across the facility. The uppermost aquifer(s) should be defined and the
vertical hydraulic head distribution between aquifers should be determined
at all solid waste management units where groundwater contamination
may occur. Upgradient and downgradient groundwater quality should be
monitored for metals, herbicides, and explosive residues to determine if the
facility is contributing contaminants to the groundwater and if
contaminants are migrating off-site. Herbicide analyses should include the
phenoxy-acetic acid herbicides as well as 2,4-D, 2,4,5-T, dioxins and furans.
Specific knowledge of local directions and rates of groundwater
movement is limited to three small areas which have been separately
investigated. These include the depleted uranium (DU) area, (also known
as the Delta Impact Area) which covers approximately 2 square miles; the
Gate 19 Landfill, about 20 acres; and the building 279 solvent disposal area,
about 1 acre [Figure 3].
The regional groundwater gradient is indicated to be in a west to
southwesterly direction, ultimately discharging along the Ohio River.
However, JPG reports indicate that groundwater gradients are to the west
northwest and south southeast, respectively, at the Gate 19 Landfill and the
building 279 solvent disposal area. JPG had no explanation for these
discrepancies.
Eleven groundwater monitoring wells have been installed in
conjunction with investigations of the DU area [Figure 4]. No rationale for
selecting these well site locations is presented in the USATHAMA Report,
and no hydrogeologic and groundwater flow interpretations are provided
based on data derived from these wells. Several of these well locations are
not adequate for monitoring because they are located too far from the DU
area and are neither up-gradient nor down-gradient but are divergent from
-------
M^4^c t
-f ^<:
E.AS INVESTIGATED
.
Groundu/ater
G.t. 19 Landfill
Dtpl«t«d Unnium An
Bulldlna 279
Dtpl«t«d Utll
Building 279
Soil Gat Sampling
Building 602
Building 617
Building 279
DELTATIMPAOT A R E A
J ™ ~" ~ - "^^:—Tr*
3 , —,
• |<3»«« 19 i - I
.;• - Ltndllll , JN5 (L
\ ,'.' ' l'
!n/!I^A ' P\K^ - I -I' X- •/
'es_£QjW_v_,.«. y- • --.- -\_-M(N-^X^ • ...:_ : :-,sc _ • /
~—•" / ' y^- ^ \ ' ^ -«.i ' /
* . . Blda~'"f1x.^ fT*5—rV_C~^> S. Bldg I
6Q« ' JM6i7 .^ . / l ""^^^X^^jL^^I^K^J.!
FIGURE 3
GROUNDWATER AND SOIL GAS SAMPLING SITES
J«H«rion Proving Ground
Midlion, Indian*
(Sourc«: JPG/US ATH A M A)
-------
p -'.-I. RT.7
H
MW
^
or^).
SJ
V
ixv
CE&
17-
DEPLETED URANIUM
C AREA
vl (37
DELTA IMPACT
AREA
•\ /-•'
J
I
MW6f">
W&4.
tx/
\
\
r®.
^\ L*
•/M
TNS-
'/M:
Firing Ll««
"•ft ! 71
4ri
MW2
f22
-• V
ft5f^
c
50
V^-;i
M
FIGURE 4
MW3
L^>. ks. -I
^«^5
GROUNDWATER MONITORING WELL LOCATIONS ^='1="^ y1^, J
x?==r^/rTs
FOR DEPLETED URANIUM AREA
J«ff«r«on Proving Ground
N Madlaon. Indiana
1 mil*
4
V
\
MW8"
.1,
fce
JWlSURFACE W4.TE*
MWtAONITOR WELL
V« lACXCROUNO^OU
^v
^^
r-4;-r
<-VXJ.)
/-\—' u
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ii
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-------
49
the groundwater gradient presented in the general hydrogeologic
discussion.
Soil gas sampling investigations were conducted at three small
solvent disposal sites adjacent to buildings 602, 617, and 279 to determine
whether volatile organic compounds (VOCs) were present in the soil and
indicate groundwater contamination. VOCs were detected in soil gas
samples from one probe in the vicinity of the building 279 solvent disposal
location. Two samples, 3 days apart, from this probe showed
trichloroethylene concentrations of 394 and 1,000 parts per billion,
respectively. Subsequently, three groundwater monitoring wells were
installed at building 279 and trichloroethylene contamination of the
groundwater was confirmed. Water table contours based on water level
measurements at three different dates indicate groundwater flow to the
south and southeast rather than to the southwest as stated in the general
hydrogeologic discussion of JPG. This further suggests that JPG site
specific hydrogeologic data and interpretation are needed to characterize
groundwater conditions, including seasonal variations, throughout the
facility.
Points of compliance must be designated for any areas of known or
potential groundwater contamination in the vicinity of the various waste
management areas.
Solid Waste Management Units (SWMUs)
The Solid Waste Management Units (SWMUs) at JPG were initially
identified during the Initial Installation Assessment (IIA) (facility records
review) conducted in March 1980 (USATHAMA, 1980). Additional studies
were conducted to update and re-evaluate previous studies due to changes
in environmental laws and the discovery of environmental problems. An
update of the IIA was completed in July 1986 and the final report was
issued in January 1988. The SWMUs identified during these studies were
given alpha-numeric numbers (e.g., JPG-001).
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50
As part of the USATHAMA Re-look Program, the USEPA, Envi-
ronmental Photographic Interpretation Center (EPIC) in Warrenton,
Virginia, was requested to provide an analysis of historical aerial photos.
The EPIC aerial imagery analysis provided a summary of possible past
contamination areas at JPG and were designated as EPIC sites (e.g., EPIC-
01). The EPIC and JPG SWMUs were discussed in the Final Report of the
Groundwater Contamination Survey, No. 38-26-0306-89, August 8 through
12, 1988 and May 15 through 18, 1989.
During the NEIC inspection, the previously identified SWMUs were
inspected, locations were verified and additional information obtained.
Some of the JPG and EPIC SWMUs were confirmed to be the same.
Additional SWMUs were identified during the NEIC inspection; these were
given NEIC numbers. JPG, EPIC, and NEIC SWMUs are listed in
Tables 6, 7, and 8, and are individually discussed below. Figures 5 and 6
show the approximate locations of the SWMUs. The discussion for each
SWMU consists of two sections: (DA short summary of information/
recommendations provided in past reports, and (2) additional observations/
information obtained during the NEIC investigation, including a statement
regarding the need for additional study.
The "JPG" designated SWMUs are discussed first, followed by
additional units identified by the EPIC survey and then the "new" areas
identified during the NEIC investigation. Some information presented in
the "Summary of Past Studies" sections is inconsistent due to conflicting
information provided in the source documents. Where appropriate, the
original document and page number is referenced in brackets to identify
the source of the information (e.g., [1-38] refers to reference 1, page 38;
references are cited at the end of the report).
Very little written information, such as specific disposal records,
was available at JPG regarding activities at the majority of the SWMUs.
Most information was obtained through discussions with facility personnel
or direct observation.
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Table 6
51
JPG SOLID WASTE MANAGEMENT UNITS
Jefferson Proving Ground
Madison, Indiana
SWMU
JPG-001
JPG-002
JPG-003
JPG-004
(EPIC-17)
JPG-005
JPG-006
JPG-007
(EPIC-16)
JPG-008
(EPIC-16)
JPG-009
JPG-010
JPG-011
JPG-012
JPG-013
JPG-014
JPG-015
(EPIC-8)
JPG-016
JPG-017
JPG-018
Description
Incinerator
WWTP water quality laboratory
Wastewater treatment plant
Explosive burning area
Abandoned landfill
Open burning area (metal pan burning
area)
Abandoned runway, storage area
Storage and burn areas
Red lead disposal area
Photographic laboratory
Incinerator
Indoor firing range
Munition demilitarization area
Past burning ground
Gate 19 Landfill
Ordnance disposal site (Morgan Road)
Landfill ("B" Road inert ammo dump)
Abandoned well disposal site
Location
Building 185
Building 177
Building 177
North of southern landfill (JPG-005)
South of Engineers Road and east of Paper
Mill Road
East of Shun Pike, southeast portion of JPG,
Lee Field
Abandoned runway
Abandoned runway
Unknown, possibly near building 108 and
146
Building 208
Building 333
Building 295
West of Morgan Road (formerly west and
north of Firing Line Road)
South of Gate 19 Landfill
Southwest portion of JPG, near gate 19, west
plant boundary
Located south of "C" Road, just northwest of
an intersection of an access road and
Morgan Road
Eastern perimeter of JPG 4.5 impact
"AVCO Alley"
NW corner "G" Road and Center Recovery
Road
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Table 6 (cont.)
JPG SOLID WASTE MANAGEMENT UNITS
Jefferson Proving Ground
Madison, Indiana
SWMU
JPG-019
(EPIC-5)
JPG-020
(EPIC-5)
JPG-021
JPG-022
(EPIC-4)
JPG-023
(Southeast
portion of
EPIC-3)
JPG-024,
JPG-025
(EPIC-2)
JPG-026
(EPIC-1)
JPG-027
JPG-028
JPG-029
JPG-030
JPG-031
JPG-032, 033
JPG-034
JPG-035
JPG-036
Description
Munition test pond, asphalt lined
Macadam test pond
Abandoned well disposal site
Open burning area
Demolition/burning area (Shonk Farm)
Abandoned Landfill
Abandoned landfill
Solvent pit
Solvent pit
Solvent pit
Fire training pit
Metal working shop
Not identified
Weapons maintenance workshop
Equipment maintenance shop
Hazardous waste storage building
Location
Southwest of 16-C impact range
Southwest of 16-C impact range
Northwest corner "I" Road and Cottreil
Road intersection
Southwest corner of 1600-east impact area,
just east of Cottreil Road
North of Graham Creek and west of
Bombfield Road
North of "K" Road and west of Northeast
Exit Road
East of Little Otter Dam
Building 602
Building 617
Building 279
Adjacent to abandon runway
Building 105
Unknown
Building 227
Building 186
Building 305
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53
Table 7
EPIC SOLID WASTE MANAGEMENT UNITS
Jefferson Proving Ground
Madison, Indiana
SWMU
EPIC-01
EPIC-02
EPIC-03
EPIC-04
EPIC-05
EPIC-06
EPIC-07
EPIC-08
EPIC-09
EPIC- 10
EPIC-11
EPIC-12
EPIC- 13
EPIC- 14
EPIC- 15
EPIC-16
EPIC- 17
Description
Abandoned landfill (JPG-026)
Abandoned landfills (JPG-024 and 025)
Demolition/burning area [identified
boundaries includes "Shonk Farm"
(JPG-023)]
Dry Creek Bed open burning area
Munitions, Macadam test ponds (JPG-019
and 020)
4.5 Mortar Impact Range (MIR)
Trenches
Gate 19 Landfill (JPG-014 and 015)
Trenches
Open storage area
Open storage area
Open storage area
Active dump/landfill
Disposal area
Open storage area
Abandoned runways (JPG-007, 008, 030
and 036)
Abandoned landfill (JPG-004 and 005)
Location
East of Little Otter Dam
North of "K" Road and west of Northeast
Exit Road
North of Graham Creek and west of
Bombfield Road
North end of 16E Impact area east of Cottrel
Road
Southwest of 16C Impact area
Eastern perimeter of JPG north end of York
Road 4.5 MIR
2.5 Jines impact area east side of Jinestown
Road
West perimeter Road at Gate 19
Northwest of railroad tracks intersection
and Woodfill Road
North of building 186
Southwest of Shun Pike and Woodfill
Roads
South of EPIC 11
West of building 333
East of Paper Mill Road and north of
railroad tracks
South of railroad switching yard and east of
Paper Mill Road
West of Paper Mill Road between
Engineers Road and Woodfill Road
East of Paper Mill Road south of Engineers
Road
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Table 8
NEIC SOLED WASTE MANAGEMENT UNITS
Jefferson Proving Ground
Madison, Indiana
SWMU
NEIC-01
NEIC-02
NEIC-03
NEIC-04
NEIC-05
NEIC-06
NEIC-07
NEIC-08
NEIC-09
NEIC- 10
NEIC-11
NEIC- 12
Description
Unexploded ordnance (UXO) areas
Wastewater treatment plant
sludge disposal areas
Underground fuel storage tanks
Roadways north of firing line
Chemical impregnation plant
Herbicide application areas
Oil/water separators
Locomotive maintenance pit
Open burning area
Open burning area
Sandblasting area
Depleted Uranium (DU) area
Location
Areas throughout the facility north of
firing positions at firing line road
Clay bank south of old incinerator,
near building 185 and other sludge
disposal areas.
Facility wide
Facility wide
Location unknown, possibly building
127
Impact areas and roadways
Building 186 and building 110
Building 211
"Z" zone gator mine field test area
Northeast corner of "Z" zone
Building 136
Delta Impact area
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United States Army
Jefferson Proving Ground
Madison, Indiana
Figure 5
SOLID WASTE MANAGEMENT
UNIT LOCATIONS
Other Areas Not On Map
1 Unexploded Ordnance (UXO) Areoa
3 Underground Fuel Storage Tanks
4 All Roadways North of Firing Line
6 Herbicide Application Areas
Perimeter, Roads
« JPC SolM Wo*U Manogwnmt Unltt
»• EPIC SolM Wat* Managvn«nt Unit*
oe NBC Solid Wa*t* Uonofl«n«it Unto
npoct Ar*a«
Wotv
See Enlarged View
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Middle Fork Creek
7JINES
~l
United States Army
Jefferson Proving Ground
Madison, Indiana
Figure 6
SOLID WASTE MANAGEMENT
UNIT LOCATIONS
Enlarged View of Southern Tip
Perimeter, Roads
i« JPG SoHd Wait* UanogOTiant Unite
oe EPIC Solid Wart* Uanog«n«nt Unit*
OB NBC Solid Wart* Uanag«n«it Unit*
Impact Araae
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57
JPG Solid Waste Management Units (SWMUs)*
JPG 001 Building 185 Incinerator
Snm.in.ary of Past Studies
The incinerator is a Morse-Boulger, six-burner, single-chamber unit
without an afterburner. The incinerator is no longer active and the build-
ing is used for storing fertilizer and tools [3-C-2]. The building 185
incinerator was used to burn paper products and small amounts of
ammunition between 1941 and 1978 [1-38]. No further investigation was
recommended [3-C-2].
Investigation Observations
The building 185 incinerator is located in the southwest corner of
JPG just west of the wastewater treatment plant (WWTP) and south of
Engineers Road. The incinerator was used in 1988 to test burn waste
polyurethane foam "Pelron A&B" contaminated with methylene chloride.
This polyurethane foam is used as an inert filler to replace explosives in
munitions when testing "inert" shells. Methylene chloride is used to clean
the polyurethane mixing/loading machine and associated equipment. The
incinerator was inactive during the NEIC investigation and, because the
polyurethane test burn was unsuccessful, JPG has no current plans for
further use.
During the NEIC investigation, open containers of waste
polyurethane contaminated with methylene chloride and full/empty
containers of chlorine gas for the nearby wastewater treatment plant
(WWTP) were stored in building 185.
The ash from the incinerator should be analyzed for heavy metals,
dioxins and polychlorinated biphenyls (PCBs) and disposed of properly. If
SWMUs identified in the IIA, IIA Update, and/or the Groundwater Contamination
Survey
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58
the incinerator remains inactive and all the ash is removed, there would be
no need for additional investigation of this SWMU.
JPG 002 - Water Quality Laboratory
Summary of Past Studies
A water quality laboratory has been operational at the WWTP since
the 1960s. Analyses performed include settleable solids, pH, biochemical
oxygen demand, total suspended solids, fecal coliform, and residual
chlorine [1-17].
Investigation Observations
The WWTP laboratory, located adjacent to the WWTP in the
southwest corner of JPG is currently active. Minor quantities of laboratory
wastes, including cleaning detergent and residual sample waste from the
water quality analyses, should not cause water quality problems. Based on
current information, no further investigation of this unit is warranted.
JPG 003 - Building 177 Wastewater Treatment Plant
Summary of Past Studies
The building 177 Wastewater Treatment Plant consists of an effluent
settling pond, tertiary filtering system, and a percolation/trickling filter
system (75 feet in diameter). Influent is nonindustrial sanitary waste
fluids and solids. The waste is nontoxic human solid waste with very little
other material. Treated wastewater is discharged to Harberts Creek.
Sludge from the drying area is regularly tested for EP Toxic heavy metals
and, if not contaminated, disposed of in the Gate 19 Landfill (JPG-015). The
plant, although over 40 years old, appears to be maintained well and
operates properly [3-C-4]. In 1984, biological die-off of the trickling filter
was linked to discharge of photo laboratory developing chemicals [2-3-7].
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59
Investigation Observations
The building 177 WWTP is located in the southwest corner of the
installation, just south of Engineers Road. The treatment system, in order
of unit processes, consists of head works (wet well and pumps), Imhoff
tank, trickling filter, clarifier, chlorinator, and pressure filtration unit.
Discharge is to Harberts Creek. Sludge from the Imhoff tank is dryed in a
sludge drying bed located at the WWTP. Some dryed sludge was stored on
the ground just east of the drying beds during the NEIC investigation.
WWTP influent consists of sanitary sewage, stormwater infiltration
and industrial wastewater including spent photographic chemicals and
rinses from building 208, boiler blowdown and water from at least one
oil/water separator (building 186). Prior to 1980, photographic processing
chemicals contained cyanide and silver. Silver generated from
photographic processing was not recovered from spent solutions prior to
1967.
The WWTP has experienced infrequent partial die-off of trickling
filter microorganisms since the 1970s. A partial die-off occurred the week
prior to the NEIC investigation, reportedly due to: (1) a power outage
(wastewater must be pumped from an influent wet well to the Imhoff tank),
and/or (2) discharge of chemicals from the photographic laboratory.
Because the two events occurred simultaneously, the specific cause of the
die-off had not been determined.
While the WWTP itself does not require further investigation as a
SWMU, two associated areas should be investigated: the sludge drying bed
and the sediment in Harberts Creek at the wastewater discharge point.
The drying bed, consisting of concrete walls and presumably sand floors
(as-built diagrams were not available), received sludge from the Imhoff
tank (all sludge is circulated back to this tank for digestion and removal).
The area under the bed may be contaminated with sludge constituents,
including silver and cyanides. Samples of material present beneath the bed
should be analyzed for heavy metals and cyanide. Harberts Creek sediment
downstream from the WWTP discharge point (NPDES, outfall number 001)
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60
may be contaminated with cyanides and heavy metals (specifically silver)
from past discharges. The sediment should be sampled and analyzed for
heavy metals, cyanide, and PCBs.
JPG 0041 EPIC 17 • Explosive Burning Area
Summary of Past Studies
Approximately 2 acres located just north of the "older" or "southern"
landfill (JPG 005) were used in the mid-1970s to burn explosive
contaminated waste [1-38] and fuses [3-C-6]. Waste products from explosive
burns or products from incomplete combustion include TNT, DNT, and
heavy metals [3-C-6]. The area is currently overgrown with vegetation and
not in use [3-C-6]. Past studies recommend that the soils be sampled at
1-foot and 5-foot depths for EP Toxic heavy metals (RCRA characteristic)
and explosive residues [3-C-7].
Investigation Observations
The specific location of this SWMU could not be identified and thus
the area was not inspected. The area should be located by JPG personnel
and soil samples taken and analyzed for heavy metals and explosives
residue (such as DNT and TNT).
JPG 0051 EPIC 17 Abandoned Landfill
Summary of Past Studies
The "older" or "southern" landfill (JPG-5) was used from 1941 until
1970. Material disposed of within this unit included all film refuse from
photo processing [1-36]. The area is totally overgrown and barely
discernable [3-C-9]. The area may also have been used as a burning
area [4].
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61
Investigation Observation
This unit is located just south of Engineers road and east of Paper
Mill Road in the south central portion of the facility. Acetate based waste
photographic film disposed of in this area probably contained silver and
possibly cyanides. Pesticide containers, ash from the incineration of small
arms ammunition (22,000 kilograms per year - [1-38]) and paint wastes
were probably also disposed of in this unit because this is the only landfill
identified as being in operation between 1941 and the early 1960s. A sign
located at the landfill reading "Closed Deliver Combustible Waste to Bldg
333 Post Incinerator," suggests that, prior to closure, combustible material
was also disposed of in this landfill.
A soil and groundwater sampling program should be developed to
identify the hydrogeologic characteristics of the area and determine if
hazardous substances are present/migrating from this unit. Sample
analysis should include heavy metals, solvents, and cyanide.
JPG 006 - Open Burning Area
Summary of Past Studies
This active powder burning area is located in the southeast corner of
the installation and has been used since the early 1950s to burn explosive
waste and materials contaminated with explosives residues. Area used to
burn waste explosives and propellants, most commonly nitroguanadine
[3-C-29]. Discolored gravel observed in the area is evidence of past releases
[5-D-32]. Surface soil sampling revealed that soils are contaminated locally
with metals, lead, and 2,4-DNT. Past studies recommend soil sampling at
1- and 5-foot intervals for metals and the following explosive residues: 2,4-
DNT, 2,6-DNT, HMX, and TNT [3-C-30].
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62
Investigation Observations
This area, correctly identified as JPG 006 in the original IIA [1] and
the IIA Update [2], is incorrectly identified as JPG 022 in documents [3],
and [5] (documents [3] and [5] do not identify/discuss a JPG 006).
This burning area is located just east of Shun Pike Road in the
southeast portion of JPG. Propellants (powders) are currently burned in
metal pans, as approved by the State of Indiana. The burn pans are covered
when not in use, although each of the four pans has a drain (with plug) to
allow for release of accumulated liquid. Standard operating procedures
allows up to 500 pounds of propellant per pan per burn with a maximum
allowance of 8,000 pounds per day. During the last 5 years, an average of
about 60,000 pounds per year of powder was burned. About 90,000 pounds of
powders were burned in 1988.
Ash from each burn is currently allowed to accumulate within the
pans until enough is accumulated to justify cleaning. The ash has been
found to be EP Toxic for lead, reportedly due to the presence of lead foil in
"lacing jackets" placed around the propellant load for gun tube lubrication
and cooling. EP Toxic ash has been stored in building 305 (hazardous waste
storage building) awaiting off-site disposal. None of the ash has reportedly
been disposed of.
Prior to October 1986, powder was burned in this area on gravel
placed over the soil. Discolored gravel in the area is evidence of past
burning activity. Herbicides have been used extensively in the area to
remove vegetation.
Further investigation of this area is required. Gravel/soil in the area
should be sampled and analyzed for residue propellant (such as DNT and
TNT), heavy metals, and herbicides.
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63
JPG 007/JPG 008/EPIC 16 - Abandoned Runway Storage I Burning
Area
Summary of Past Studies
JPG 007 is the used wood stockpile, located on the abandoned
runway. The area has been used for storage of waste wood since about 1975
[3-C-ll]. Burning Area JPG 008 is also located on the old airport runway
and was used to burn unidentified refuse but apparently not explosive
waste. Pentachlorophenol (PCP) treated wood is also stored in this area.
The PCP wood pile ignited from a lightning strike and some of the wood
was partially incinerated. Dioxin, and other residues of burning may be
present in this area. Debris will be disposed of off-site as approved by the
State Department of Environmental Management. After removal of the
material, the area should be sampled for residue PCP and dioxin [3-C-13].
The EPIC 16 site includes the total runway area used to store scrap metal,
wooden targets, and other nonhazardous materials.
Investigation Observations
The west runway areas have been routinely used to store and burn
various materials. There is limited control as to what is stored and burned
in this area. Two major waste piles were present during the investigation.
The largest pile (presumably JPG 007) contained wood, including
munitions boxes labelled "P" (indicating that they had been treated with a
3.5% pentachlorophenol solution), fibre drums, plastic, and railroad ties.
According to JPG environmental personnel, PCP contaminated wood is
supposed to be placed in the other nearby storage pile (presumably JPG
008). The PCP contaminated wood is reportedly crushed and disposed of off-
site. About 400 cubic yards of PCP contaminated wood is disposed of off-site
yearly. Ash and other evidence indicated that the large waste pile (JPG 007)
is periodically burned.
Other areas of the runway have been used for storage of various
materials, as evidenced by the EPIC photographs. Runoff from the various
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64
burning/storage areas on the runway may have carried hazardous
substances into the surrounding soils and groundwater.
Aircraft maintenance and refueling areas are often discovered to be
sources of soil and groundwater contamination, as a result of the use of
degreasing agents and aviation fuel spills and leaks. Historic aircraft
maintenance areas and refueling/fuel storage areas should be investigated
via soil gas sampling for volatile organic constituents and, if found,
appropriate remedial actions should be undertaken.
The abandoned runway area used for storage and burning warrants
further investigation. Residue beneath the two storage piles should be
sampled and analyzed for PCP, heavy metals and dioxins.
Additionally, soil adjacent to the burning/storage areas of the
runway, as identified on EPIC photograph 22, dated 1980, should be
sampled for heavy metals, PCP, PCBs, and pesticides. The impoundment
identified on EPIC photograph 22 should also be further investigated to
determine past use. Liquid/sediment from the impoundment and/or
surrounding area may require sampling and analysis based on additional
study findings.
JPG 009 - Red Lead Disposal Area
Summary of Past Studies
This area was used in 1957 to dispose of red lead and barium sulfate
[1-37].
Investigation Observations
The exact location of this area is unknown. JPG personnel believe
the location to be near building 108 but they did not know the exact area.
The red lead and barium may have been waste from the inert munitions
loading process conducted in building 211. Red lead was also used as a
paint pigment until about 1986.
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65
The exact location of this disposal area should be identified and soil
samples taken to determine whether lead or barium is present in the area.
If these materials are present, groundwater should be sampled to identify
contaminant migration.
JPG 010 - Building 208
Summary of Past Studies
Building 208 contains the main photographic laboratory at JPG.
Prior to 1970, the laboratory was located in building 115. Approximately
170 gallons per day of spent photographic chemicals are discharged to the
sanitary sewer system and treated at the WWTP. Chemicals sent to the
sewer include used fixers and developers [1-16]. Since 1967, silver has been
recovered from the processing solutions before discharge to the WWTP.
Prior to March 1980, when the use of biodegradable chemicals began,
cyanides and bleaches were utilized and discharged to the WWTP [1-17].
All waste toners and developers are currently diluted at least 20:1 when
discharging to the sewer [3-C-16].
Investigation Observations
Operations in building 208 involve development of color and black and
white photographs. Silver is recovered from spent photo developing
solution by two parallel recovery units. About 20 pounds of silver was
recovered in the 2 months preceding the NEIC investigation. Following
silver recovery, the used toners and developers are discharged directly to
the concrete floor drains. There is no liquid waste storage in building 208.
Flow valves control flow rate of wastes to the drains.
The building 208 drain sewer system should be investigated to
determine whether sewer traps exist. If traps are found, material captured
in the traps should be sampled for silver and cyanides. Also, building
operators should take additional measures to prevent the undiluted
discharge of photographic chemicals to the WWTP (as occurred on about
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66
August 10, 1989, when a valve was inadvertently left open) and ensure that
the silver recovery unit is properly operated and maintained.
JPG Oil - Building 333 Incinerator
Summary of Past Studies
The building 333 incinerator is a fuel oil fired single chamber unit
with afterburner. Solid wastes, consisting mainly of paper products, have
been incinerated in this unit since 1978. A mixture of polyurethane and
iron oxide has been incinerated with the paper products. The ash is
routinely tested for contaminants. The ash is then put into fibre drums and
taken to the construction debris (Gate 19) landfill [3-C-19].
Investigation Observations
The building 333 incinerator is used to burn paper materials. The
incinerator was used in 1988 to test burn waste polyurethane (Pelron A&B)
inert filler contaminated with methylene chloride from the production of
"inert" shells. Waste film negatives were burned in the incinerator on
August 19, 1989. Ash samples from these burns were taken by JPG and
will be analyzed for RCRA characteristics. The incinerator was inactive
during the NEIC investigation and, because the polyurethane test burn was
unsuccessful, JPG has no current plans for additional polyurethane burns.
The facility only recently initiated ash sampling and analysis and no
analytical data was available during the NEIC inspection.
The ash from the incinerator should be analyzed for heavy metals,
dioxins, and PCBs prior to disposal. If the ash is found to be nonhazardous,
no additional investigation of this SWMU is required.
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67
JPG 012 - Indoor Firing Range
Summary of Past Studies
An indoor training range for small arms firing is located in building
295 [1-25].
Investigation Observations
The indoor firing range is inactive. Residues removed from the
building should be analyzed for heavy metals prior to disposal. Additional
investigation of the firing range is not warranted.
JPG 013 - Demilitarization Area
Summary of Past Studies
Explosive charges from thousands of shells were burned in the area
from 1945 to 1950 [1-38]. The area is located west of Morgan Road (formerly
West Stockade Road) and north of Firing Line Road.
Investigation Observations
No additional information was found regarding this unit. The exact
location of this area should be identified and the soil sampled and analyzed
for heavy metals and explosive residues. Analytical results will determine
what additional study, if any, is warranted.
JPG 014 - Burning Ground
Summary of Past Studies
This burning area was used in the early 1970s to burn refuse [1-38].
The area is located just south of the Gate 19 Landfill (JPG-15) and was used
between the 1950s and 1970s for burning of construction debris and propel-
lants. Also, the area was reported to have received tetrachloroethylene and
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68
paint waste (probably including lead pigment). Aerial photos show liquid
filled trenches and mounded material [3-C-21].
Investigation Observations
This area, adjacent to the Gate 19 Landfill and currently overgrown
with vegetation, warrants further investigation. Hydrogeologic character-
istics of the area should be identified and groundwater monitored to identify
any contamination.
Existing wells, installed to monitor groundwater at the Gate 19
Landfill, are not sufficient to monitor The Burning Ground (JPG 014). Soil
sampling and additional groundwater investigation is needed. Results of
this work should be integrated with information from wells at the Gate 19
Landfill. A pond, possibly an inundated old rock quarry, southwest of JPG
sites 014 and 015, appears to be a groundwater discharge area and should
be monitored for possible evidence of contaminant migration from JPG 014
and JPG 015 (Gate 19 Landfill).
JPG 0151 EPIC 8 - Gate 19 Landfill
Summary of Past Studies
The Gate 19 Landfill was used from the early 1970s (1960 according to
[2-3-1]) to present. Material disposed of in this unit included empty
pesticide containers, incinerator ash [1-36], polyurethane/methylene
chloride waste and red lead [1-37]. The landfill was also used to burn
unidentified refuse [1-38]. Between 1,000 and 10,000 gallons of
trichloroethylene were disposed of at the site [2-3-1]. The landfill presently
only receives construction debris and double-bagged asbestos.
Investigation Observations
This currently active landfill is located in the southwest portion of the
facility near the west plant boundary. Because of the proximity of the
landfill to the facility boundary, materials placed in the landfill have the
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potential to migrate off-site. Samples of groundwater from three
monitoring wells contained bis 2-ethylhexyl phthalate and the sample from
one well contained acetone [6-2-10]. Additional downgradient wells are
required. Current well spacing is not adequate to assure detection of
downgradient migration of contaminants. Also, several wells are screened
below the water table so contaminants at or near the water table would not
be detected. Additional or replacement wells should be installed and
constructed to intercept possible groundwater contaminants moving at or
near the water table.
JPG 016 - Ordnance Disposal Site
Summary of Past Studies
This ordnance disposal site is an excavation about 5.5 feet by 18 feet by
3 feet deep located west of Morgan Road and north of C Road that was used
in the late 1940s to dump munitions recovered during cleanup operations at
the JPG ranges. The area was never backfilled. In March 1980, the
excavation was filled with water but unexploded ordnance (UXO) were
visible protruding from the ground and water at the east end of the site
[1-37]. Although an addendum to the initial IIA indicated that this site
should be "covered and filled," no action had been taken as of December 19,
1986. The January 1987 IIA update states that "the corroding shells located
at the site reportedly do not contain explosives and are not considered
hazardous" [2-2-3].
Investigation Observations
The site is actually located south of C Road, just northwest of the
intersection of a small access road and Morgan Road. The pit is still filled
with liquid and numerous submerged and partially submerged corroding
munitions. Facility personnel said that the impoundment had been
drained around 1980 and some of the munitions were detonated. The
munitions were found to be "inert" (i.e. not containing explosives).
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70
This pond should be drained and the munitions checked for the
presence of explosives. Water/sediment should be sampled for heavy
metals if the munitions are found to be inert. If the munitions are
explosive, the water/sediment should also be analyzed for residual
explosives.
JPG 017 - Landfill
Summary of Past Studies
This landfill was used from the early 1960s to the present for burial of
inert metal parts, primarily from small munitions [1-37]. Munitions
buried here were reportedly "inert" [2-3-10]. The landfill operated from the
1960s to 1981 for burial of inert metal from firing range activities [3-C-27].
Investigation Observations
This inactive landfill is located on the eastern side of the facility in
the northern portion of the 4.5 Mortar Impact Range (MIR). According to
facility personnel, the area was used to dispose of inert ammunition
recovered from the impact areas. Inert munitions were placed in relatively
small, shallow holes and buried. Several depressions in the ground
remain and munitions are visible.
Lead and other heavy metals and possibly explosives may be present
in this area. The visible munitions should be checked for the presence of
explosives. If explosives are found, the area soil should be sampled for
heavy metals and explosives residue. If explosives are not found, the soil
should be analyzed for heavy metals. The results of soil sample analysis
will determine if groundwater studies are necessary.
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71
JPG 018/JPG 021 • Abandoned Well Disposal Sites
of Past Studies
A well (JPG 018) was reportedly used in the 1950s to dispose of 100 to
200 "riot grenades" [1-37]. An on-site cistern (JPG 21) was reportedly used
to dispose of fuses in 1957 [1-37].
Investigation Observations
The JPG 018 well is a hand dug well about 3 feet in diameter with
standing water 6 to 10 feet below land surface. The walls are lined with
limestone. There was no visual evidence of contamination. The JPG 021
"cistern" was not inspected because the area is reportedly contaminated
with explosive "bomblets." The cistern was probably an old, hand-dug well
constructed for water supply by early residents of the area prior to the
establishment of JPG.
Water in all open wells discovered at JPG should be investigated for
the presence of hazardous substances. This would include sampling and
analysis of well water for heavy metals and explosive residues. If the wells
do not contain such substances, they should be abandoned/plugged
according to State of Indiana well abandonment requirements. If the
sampling and analysis indicates contamination of the wellwater, the wells
should be thoroughly cleaned and retested before abandonment.
JPG 019 1 EPIC 5 - Munition Test Pond
Summary of Past Studies
The Munitions Test Pond may still contain projectiles and cartridge
cases. Although the pond was cleaned out in the mid-1950s, "an
interviewee noted that some material may still lie in the pond" [1-37]. This
unit was used pre-1972 to late 1970s [2-3-10].
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72
Investigation Observations
The Munitions Test Pond was identified as an asphalt lined
impoundment located southwest of the 16 C impact range and was
estimated to cover about 1 acre. The pond was used to test fuses but is
currently inactive and was drained between 1978 and 1980. No munitions
were found. The pond remains empty and the drain valve is open. There is
some dark colored residue on the asphalt liner. The impoundment is no
longer used for testing or other facility activity. The residue in the drainage
culvert should be sampled for metals and herbicides.
The name of this unit may have been confused with JPG 020, the
Macadam Test Pond. Both ponds are located in the same general area.
However, JPG 019, Munitions Test Pond is lined with asphalt, also referred
to as macadam, while JPG 020 is not lined. It is reasonable that the
asphalt/macadam pond (JPG 019) should be called Macadam Test Pond
rather than JPG 020 which only has a "natural" bottom.
JPG 0201 EPIC 5 Macadam Test Pond
Summary of Past Studies
The Macadam Test Pond "was reported to be contaminated with
unexploded ordnance and the herbicide Ureabor" [1-37]. The unit was used
from pre-1972 to late 1970s [2-3-10].
Investigation Observations
The Macadam Test Pond, located southwest of the 16 C impact range
is an unlined man-made surface impoundment. The pond was reportedly
used to test fuses but is currently inactive. Munitions, some of which may
contain explosives may be present in the pond. Runoff from the 16 C impact
range probably carried herbicides, used to clear vegetation from the impact
area, into the pond.
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Discharge from this pond flows to a tributary of Little Graham Creek.
The outfall is not monitored for water quality. At the discharge, an
erosional gully (estimated about 15 feet deep) extends about 100 yards
northwest and then southward to Little Graham Creek. The pond outfall
culvert is washed out and the underlying embankment is eroding. A
section of corrugated galvanized culvert pipe was observed about 100 yards
downstream of the pond. One JPG interviewee said that the pond level has
been declining recently, undoubtedly due to the washout and subsequent
erosion in the vicinity of the outfall.
Further investigation of this unit is required to determine if UXO is
present in the pond to determine if the water and sediment is contaminated
with explosive residues, lead, and herbicides.
JPG 021
(See JPG 018)
JPG 0221 EPIC 4 - Dry Creek Bed Open Burning Area
Summary of Past Studies
The Dry Creek-Bed Burning Area was used to burn explosives
residues (dates not given) [1-38] and powders prior to 1980 [2-3-9].
Investigation Observations
JPG 022 is improperly identified in documents [3] and [5] as the active
burning area located in the southeast portion of the facility. [The IIA (1)
and IIA Update (2) identify the current burning area as JPG 006.]
JPG 022/EPIC 4, as identified in the IIA and Updated IIA, is located
near the southwest corner of the 16E impact area, just east of Cottrell Road.
The site was only viewed from Cottrell Road because of the presence of
active "bomblets" in the area. The impact area has been heavily worked
(graded and cleared of vegetation) and there was no sign of burning activity
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visible from the road. As is the case with all JPG active impact areas, this
area is periodically graded and treated with herbicides using armored
equipment.
This area warrants further investigation to include soil sampling for
residue explosives/propellants, heavy metals, and herbicides.
JPG 023 / Southeast Portion of EPIC 3 - Demolition Burning Area
Summary of Past Studies
This demolition/burning area, located in the north central portion of
the installation, was used from the 1950s to present to dispose of test
material considered defective and/or ammunition which has been
recovered from the ranges [1-38]. No powder was burned at the site [2-3-9].
Unexploded ordnance, fuses, primers, and grenades are burned in a 5-foot
by 25-foot by 6-foot cage. Demolition/burning residue includes metals,
explosives and propellants. "Small amounts" of lead and explosives were
found in the soil [3-C-32].
Investigation Observations
This demolition/burning area, referred to as the open detonation/
open burning (OD/OB) area or "Shonk Farm," encompasses several acres
north of Graham Creek and west of Bombfield Road. Munitions are often
buried in pits prior to detonation. The burn cage is used to burn small
munitions (grenades, small shells, etc.). The area was reportedly used as
an aircraft bombing range during World War II. Several depressions were
present in the area as a result of detonations. Numerous metal fragments
were visible in the soil over the entire area.
In addition to depressions attributed to detonations of ordnance, other
depressions appear to be characteristic of karst (sink holes) development
(subsurface solution of carbonate bedrock by groundwater percolation)
resulting in surface subsidence. A JPG interviewee stated that, following
heavy rains, he had noticed muddy springs discharging into Graham
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Creek a few hundred yards southeast of this area. These observations are
indicative of rapid local movement of groundwater along solution openings
in the bedrock.
Lack of vegetation in the area indicates heavy use of herbicides. Soil
samples taken by JPG in January 1989 were reportedly not RCRA reactive
or EP toxic.
Ground surface scars identified by EPIC (Site 3) northwest of the OD
area, are probably due to "bogg discing" to clear vegetation.
Hydrogeological characterization of this area is required and should
include definition of groundwater flow patterns in the bedrock. Additional
soil samples should be taken and analyzed for explosive residues, heavy
metals, and herbicides. If hazardous substances are found in the soils,
groundwater and/or Graham Creek water should be monitored upgradient
and down-gradient of Shonk Farm for heavy metals, herbicides, and
explosive residues.
JPG 024, JPG 0251 EPIC 2 - Abandoned Landfill
Summary of Past Studies
These two landfills, located in the same general location north of K
Road, were used for construction debris, putrescibles, paper and nontoxic
household waste [3-C-35, 3-C-37], and sanitary waste from the Old Timbers
Lodge [3-C-35]. No hazardous wastes were disposed of in these areas [2-3-9].
This may have been a possible burn area from 1955 to 1961 [4].
Investigation Observations
The general area of these landfills has been used for several activities
and two distinct landfill areas (JPG 024 and JPG 025) could not be
identified. The presence of "used target material" and what appeared to be
an old camera stand suggest that the area may also have been used as an
impact and/or gun implacement area. Two large surface depressions filled
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with water, which may be the identified landfills, were located in the area.
Scrap wood and electrical equipment (fuse box and cable) were also present.
Very little is known about area activities and further investigation is
warranted. Facility personnel should be interviewed regarding impact/gun
implacement activities and soils in the depressions should be sampled for
RCRA characteristics and heavy metals.
JPG 0261 EPIC 1 - Abandoned Landfill
Summary of Past Studies
The landfill was used for about 2 years prior to 1980 for construction
debris, sanitary waste and waste from campers [3-C-39]. The area has been
underwater since flooded by Old Timbers Lake, formed by Little Otter Dam
in 1980 [2-3-9]. There has been no known hazardous waste disposal in this
area [3-C-39].
Investigation Observations
The area is located immediately east of Little Otter Dam, built in the
mid-1980s. The EPIC aerial photo may identify a borrow area associated
with construction activity or tree clearing for the reservoir rather than, or
concurrent with, disposal activity.
There is no evidence that hazardous substances were disposed of in
this area. The area has been flooded by Old Timbers Lake since the mid-
1980s. No further investigation of this area is warranted at this time.
JPG 027/ JPG 0281 JPG 029 - Solvent Disposal Areas
Summary of Past Studies
These three solvent disposal pits are located immediately adjacent to
buildings 602 (JPG 027), 617 (JPG 028) and 279 (JPG 029). The 3-foot-
diameter, 3-foot-deep pits, filled with crushed rock, were used from about
1970 to 1980 to dispose of waste solvents/degreasers, including TCE and
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other unknown solvents and degreasers [3-C-41 to 3-C-46], [2-3-3]. Four to
five hundred gallons of TCE were reportedly disposed of in these pits.
The USATHAMA report prepared by Environmental Science and
Engineering, Inc., [6], recommends that the contaminated soils near these
solvent disposal areas be removed or remediated and that initially three
shallow wells should be installed around each site to determine
groundwater gradients.
Investigation Observations
The three pits are located as follows: JPG 027 at the northeast corner
of building 602, JPG 028 along the southwest side of building 617 and JPG
029 at the northeast corner of building 279. Soil-gas testing detected volatile
organic carbon (VOC) contamination at all three of these locations.
Three groundwater monitoring wells were installed around the
building 279 solvent disposal area and VOCs were detected in groundwater
samples from one of the wells (MW15). The groundwater gradient was
south to southeast rather than southwest, as indicated for the general
regional flow description.
No groundwater monitoring wells have been installed at either the
building 602 or building 617 solvent disposal sites and no soil removal or
remediation work was evident at any of these three sites.
Further investigation is needed to define the extent of migration of
chlorinated and unchlorinated organic solvents disposed of in the solvent
disposal areas and to better define the local groundwater gradients
including seasonal variations. Dr. Glenn Thompson, of Tracer Research
Corporation, developed the soil gas sampling methods used for detecting
groundwater contamination. He has stated (personal communication) that
the infiltration of fresh water through the soil from the surface may flush
VOCs from the soil and mask groundwater contamination with a layer of
fresh water at the surface of the saturated portion of an aquifer. Also,
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climatic conditions common at JPG impede detection of subsurface volatile
organics.
Therefore, it is also recommended that drilling and groundwater
sampling and analysis be done around the building 602 and 617 solvent
disposal sites to determine the fate of solvents which reportedly were
disposed of at these locations. Groundwater monitoring is required because
soil gas testing results do not measure contaminant concentrations in
groundwater but are only indications. Groundwater monitoring should
include determining the local groundwater gradients and sampling of
groundwater from at least one downgradient well for JPG 027 and 028
(buildings 602 and 617). The groundwater should be sampled and analyzed
for solvents, including TCE.
JPG 030 - Fire Training Pit
Summary of Past Studies
The fire training pit, approximately 20 feet by 10 feet by 2 feet deep
was used for fire training from the 1970s to present. Wood debris is soaked
with used diesel fuel and other petroleum, oil and lubricants (POL) and
ignited in the unlined pit [3-C-47]. POL burned in the pit may have
contained various materials including heavy metals and solvents.
Recommend that soils at 1- and 5-foot depths be sampled and analyzed for
heavy metals, volatile and semi-volatile organics, and PCBs. If
contamination is detected, the groundwater should be monitored [3-C-48].
Investigation Observations
The fire training pit, located adjacent to the abandoned runway,
contained standing water during the investigation. The soil in and around
the pit was stained black from POL. Soil in and around the pit should be
sampled for heavy metals, solvents, semi-volatile organics, and PCBs. If
hazardous substances are identified, groundwater wells should be installed
to characterize area hydrogeology, determine if contamination has reached
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the groundwater, and determine the extent of any groundwater
contamination and the possible need for remediation.
JPG 031 - Building 105, Metal Working Division
Summary of Past Studies
Building 105, the facility metal working shop, is a large warehouse/
industrial type building. Metal workers use cutting oil, cooling fluids and
naphthalenic oils in metal cutting, fabrication, and refurbishing large gun
tubes. Waste fluids are stored in 55-gallon drums prior to removal and
final off-site disposal [3-C-50].
Investigation Observations
Cutting fluids/oils currently used in building 105 are water based.
Stoddard solvent is periodically used "as needed" to degrease metal parts in
a cleaning pan. Used solvent is temporarily stored (satellite accumulation)
inside the building until removed for storage (building 305) and off-site
disposal. Hydraulic oils used in transmissions/drives and hydraulics of
building machinery are periodically changed. Used oil is drummed and
accumulated until sent for storage and off-site disposal. Hydraulic oil from
15 machines has been analyzed and found to contain no PCBs.
Building 105 has a typical industrial wood block type floor. The type
of subflooring, if any, is unknown; however, floors of this type were
frequently laid directly on the soil without subffooring. As is normally the
case, the floor is blackened from years of use and spills. Spilled material
not absorbed into the wooden floor may reach the soil below, causing
contamination. Contamination would not be expected to spread rapidly
because the area is protected from precipitation. Study of the soil beneath
the wood floor and materials absorbed into the wood floor itself may be
warranted, especially if the building is ever demolished.
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JPG 032 and JPG 033 - Unknown
These two units were not identified in any documents reviewed by
NEIC and JPG personnel did not know the identity or location of these
areas. These two areas should be identified and further study conducted to
determine if they require remedial action.
JPG 034 - Building 227, Weapons Maintenance Workshop
of Past Studies
Building 227 is a large brick warehouse used for repairing and
refurbishing gun tubes and other weapons and weapon parts. Waste
solvent and oil are accumulated outdoors in a parking lot. The practice of
mixing waste oil with spent solvent is common according to site personnel.
When waste drums are full, the Defense Reutilization and Marketing Office
(DRMO) contractor picks up the drums for off-site disposal. Minor spillage
exists due to sloppy handling of drums [3-C-53].
Investigation Observations
Waste materials generated in building 227, including Stoddard
solvent used for degreasing, waste oil, lubricants and paint waste, are
stored in a shed located about 35 yards northeast of the building. The shed,
labelled "Shed 11," has a roof and three walls. Some paint waste is stored
in a can just south of the shed.
Although wastes are generated in building 227, the concrete floor
would prevent most spilled material from reaching the outside
environment. Therefore, no further investigation of this building is
warranted. However, the area where the wastes are stored, including
Shed 11, requires additional investigation. Soil samples should be taken
from areas around the shed and analyzed for solvents, heavy metals, and
semi-volatile constituents. If contamination is present, the extent of
contamination should be determined by excavation and additional
sampling and analysis.
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JPG 035 - Building 186, Equipment Maintenance Shop
Summary of Past Studies
Building 186 is the vehicle maintenance facility. Used oils and
Stoddard solvent are stored in 55-gallon drums in the outside parking lot.
The practice of mixing waste oil with spent solvent is common according to
personnel at the site. When the waste drums are full, the DRMO contractor
picks up the drums for proper disposal. There is no spill containment berm
at the site [5-D-62].
Investigation Observations
Building 186 is the facility vehicle maintenance shop. Activities in
building 186 generate waste diesel fuel, oil, Stoddard solvent, ethylene glycol
(anti-freeze), and lead-acid batteries. All waste materials are reportedly
disposed of off-site through DRMO contractors (except for a quantity of
waste fuel oil used for fire training).
Liquid waste is accumulated in 55-gallon drums just west of building
186 prior to removal to building 305 for storage until pickup and off-site
removal by the DRMO contractor. The drum accumulation area has a
partially bermed concrete base which directs drainage to an oil/water
separator. The separator is part of the building sanitary/floor drain
collection system. Liquid from the oil-water separator drains to the on-site
wastewater treatment plant. The building 186 oil/water separator was last
cleaned in late 1987 or early 1988. About one drum of sludge waste was
removed from the separator and disposed of in the Gate 19 Landfill.
Used oil generated in building 186 is stored in a 1,000-gallon
underground storage tank prior to off-site disposal. Fifty-five gallon drums
are used for additional storage when the tank is full.
The drum accumulation area does not require further investigation.
However, the building 186 1,000-gallon underground waste oil storage tank
and associated piping should be leak tested. If found to be tight, no further
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action would be necessary. Further investigation of soil contamination
would be necessary if the tank/piping was leaking. The oil/water separator
should be periodically cleaned. Sludge removed should be analyzed for
hazardous wastes and disposed of accordingly.
JPG 036 • Building 305, Hazardous Waste Storage
Summary of Past Studies
Building 305, a concrete floored building about 25 feet long and 30 feet
wide, is used to store waste materials awaiting removal by DRMO
contractors. Waste material in the building includes spent Stoddard
solvent, PCB-contaminated oil and electrical transformers, asbestos, copper
slats, scrap propellant, and bagged ash residue from open burning of waste
propellant. The exterior doors do not have secondary containment to
contain spilled material [5-D-65].
Investigation Observations
Building 305 is the facility hazardous waste and PCB storage area.
The building has a concrete floor. Waste (in drums and transformers) is
stored in metal trays. The trays provide secondary containment for any
material spilled from the drums. Because wastes are stored in metal trays,
there is only minimal potential for contamination from materials stored in
this building. Contamination could occur during loading and removal of
materials from the building.
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EPIC Solid Waste Management Units (SWMUs)*
EPIC 06 - Impoundments
Summary of EPIC Survey
Impoundments and pits with debris noted in the area from before
1960 to at least 1980 [4],
Investigation Observations
Documents [3] and [5] inaccurately identify this site as JPG 017. In
fact, EPIC 06 is located northeast of JPG 017 at the 4.5 MIR. Part of the area
identified as EPIC 06 on the aerial photograph is the defoliated impact area.
The area was used as an impact area by JPG and a JPG contractor,
"AVCO." The total area was not inspected due to the possible presence of
unexploded ordnance. Further investigation of this area to identify possible
disposal activities is warranted. Soil sampling and analysis may be
required based on results of additional investigation.
EPIC 07 - Trenches
Summary of EPIC Survey
EPIC's aerial photo interpretation of this site indicates the presence
of possible disposal trenches from 1968 to 1980. Some trenches have
standing liquid [4].
Investigation Observations
The area identified as EPIC 07 is the "2.5 Jines" impact area located
about 1.5 miles north of Firing Line Road and just east of Jinestown Road.
The trenches are scars created by direct fire impact from horizontal firing
of munitions and subsequent erosion. There is no evidence of hazardous
SWMUs identified solely by EPIC
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waste handling in this area other than those materials associated with
munitions explosives/propellants. No additional investigation of this area
is required beyond that which will be required for all facility impact areas
(unexploded ordnance, herbicides, etc. - see later discussion).
EPIC 09 - Trenches
Summary of EPIC Survey
Trenches identified from pre-1949 to 1955. The area was revegetated
by 1960/1961 [4].
Investigation Observations
The identified "trenches" were located just northwest of the
intersection of two railroad tracks and Woodfill Road. Vegetation in the
general area appears to be stressed. This may have been a borrow area
where topsoil was removed for roadbed or railroad bed construction.
The area warrants further investigation to identify specific activities.
Soil sampling and analysis may be required depending on the results of
additional study.
EPIC 10 • Open Storage Area
Summary of EPIC Survey
Equipment, storage tanks for liquids, and other materials have been
stored in this area prior to 1949 and at least into 1980 [4].
Investigation Observations
This area, located north of building 186 (facility vehicle maintenance
building), has been used to store various equipment and vehicles, including
the pesticide application vehicle. The white objects in the EPIC
photographs may have been "conditioning units" used to test the stability of
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munitions under various environmental conditions. These units have
since been removed. Heavy equipment is still stored in the area.
Because the area does not have an impervious base, spilled materials
would enter the soil and possibly contaminate the groundwater. Soil
samples of the area should be taken and analyzed for solvents, semi-volatile
organics and pesticides. If the soil is contaminated, the area groundwater
should be investigated and monitored for the identified contaminants.
EPIC 11 • Open Storage Area
Summary of EPIC Survey
Debris, wooden crates, and tanks for liquid storage have been located
adjacent to the railroad tracks from before 1955 to at least 1980 [4].
Investigation Observations
The area identified by EPIC is located just southwest of the
intersection of Shun Pike and Woodfill Roads and is currently used for
privately owned vehicle parking. There is no evidence that hazardous
materials were ever handled in this area. Based on available information,
no further investigation is warranted.
EPIC 12 - Open Storage Area
Summary of EPIC Survey
Area was used for open storage from before 1955 to at least 1980 [4].
Investigation Observations
This area, located just south of EPIC 11, is a fenced storage area
where miscellaneous supplies (sheet metal, pipes, etc.) are stored prior to
facility use. While there was no evidence of the storage of liquids at this
location, further investigation to identify materials stored is warranted.
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Based on the results of further study, soil sampling and analysis may be
required.
EPIC 13 - Dump
Summary of Epic Survey
This area is a possible dump containing trenches with possible
debris. The area was used at least from 1955 to sometime before 1972 [4].
Investigation Observations
This area, located just west of building 333, is an active disposal
facility for miscellaneous debris, including tree trimmings, plastic bags,
sawdust, and wood beams. The material was not covered during the NEIC
investigation. The area should be further investigated to identify all
possible materials disposed of. If hazardous materials were disposed of,
soil and possible groundwater monitoring would be warranted. Any
hazardous wastes identified should be removed and disposed of
appropriately.
EPIC 14 - Disposal Area
Summary of EPIC Survey
This area was identified as a disposal area used prior to 1949 to
sometime before 1968. "Mounded material" is noted at the site [4].
Investigation Observations
The area identified by EPIC is located east of Paper Mill Road and
north of the railroad tracks and was reportedly used for storage of used
materials awaiting salvage or sale. The area is overgrown with vegetation
but apparently had a gravel surface. The soil should be sampled and
analyzed to determine if solvents, semi-volatile organics, and pesticides
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have contaminated the soil. If contamination is identified, groundwater
monitoring may be required.
EPIC 15 - Open Storage Area
Summary of EPIC Survey
This open storage area was used prior to 1949 to at least 1980 for
storage. Mounded materials and ground stains were noted [4].
Investigation Observations
This storage area, located south of the railroad switching yard and
east of Paper Mill Road, is the current DRMO storage area. Items no
longer useful to JPG are turned over to DRMO for salvage sale or disposal.
The items are stored in this open, fenced area prior to removal off-site. The
ground in this area consisted of gravel and patches of cracked asphalt.
While hazardous wastes, waste oils, and PCB items are currently
stored in building 305, such materials may have been located in the DRMO
storage area in the past. Soil from the storage area should be sampled and
analyzed for solvents, semi-volatile organics, heavy metals, PCBs, and
pesticides. Groundwater sampling and analysis may be necessary
depending on the findings of the soil sampling/analysis.
NEIC Solid Waste Management Units (SWMUs)*
NEIC 01 - Unexploded Ordnance (UXO) Areas
UXOs are present in many areas north of the firing positions [1-38]
and, according to facility personnel, UXOs have been recovered from areas
south of the firing line. While some recovery and detonation of UXOs
occurred on the ranges prior to the 1950s, live ammunition that do not
explode during testing are not recovered and remain in the area.
SWMUs identified during the NEIC inspection
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Furthermore, although munitions are targeted to impact one of the
approximately 52 test and impact areas at the facility, errant rounds can
fall anywhere north of the firing range. Over 29 million rounds of
ammunition have been fired at JPG since 1941. This includes three unex-
ploded 500-pound bombs dropped in 1942-43 by the Army Air Corps near the
northern boundary of the facility. (An "extensive search" failed to recover
these bombs.)
JPG has developed a facility map [Appendix J] used to show areas
that are thought to be safe for recreational activity (hunting) due to the
suspected absence of unexploded ordnance or depleted uranium. Because
of the long history of testing activity at the facility, lack of complete records
of all past activities, and the fact that munitions do not always land in the
intended target area; there is some uncertainty regarding "safe" and
"unsafe" areas at the facility. Even areas south of the firing line may have
been used for munitions testing (gator mines are currently tested in this
area). The map [Appendix J] is the facility's best collective effort to identify
"safe" areas. Any discussion regarding facility clean-up must address the
areas thought to contain unexploded ordnance.
NEIC 02 - Wastewater Treatment Plant Sludge Disposal Area
The original IIA [1-33] stated that WWTP sludge was disposed of on a
"clay bank" south of the old incinerator (presumably the building 185
incinerator located just west of the WWTP). Sludge was also disposed of on
fields on-site. Currently, sludge is stockpiled just east of the sludge drying
beds until a decision is made regarding a proper disposal location.
WWTP sludge, especially that produced prior to silver recovery in
1967, may contain hazardous substances, including silver and cyanides
from photographic processing (as described above), that may leach into the
area surface/groundwater. The specific sludge disposal location on the clay
bank should be identified and soils sampled and analyzed for silver and
cyanide. If the soil is contaminated, area groundwater should be
monitored to identify groundwater hydrology, the presence of groundwater
contamination and extent of contamination, if any.
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While other plant locations were reportedly used for land application
of WWTP sludge, the quantity disposed of at each is thought to be very
small.
NEIC 03 - Underground Storage Tanks
JPG has various underground petroleum storage tanks. These units
and the associated piping have not been routinely leak tested. Thus, there
is the possibility that leaks from some of these units may have
contaminated soils and ground water. Table 1, taken from the facility Spill
Prevention Control and Counter-measure (SPCC) Plan, lists an inventory of
storage tanks (some tanks have reportedly been removed since this inven-
tory was compiled). Remaining underground tanks and associated piping,
whether active or inactive, should be leak tested. If leakage is indicated, the
area surrounding the tank/piping should be investigated to determine the
extent of soil/groundwater contamination.
NEIC 04 • Roadways North of the Firing Line
Roadways north of the firing line are not paved and "waste oils" were
routinely sprayed on the roads for dust control [1-34]. The specific identity
or source of this "waste oil" is unknown, but the material was presumably
generated on-site and may have contained spent solvents and PCBs.
Roadway oiling stopped in August 1979 [1-34].
Representative samples from roadways north of the firing line that
were in use prior to August 1979 should be taken and analyzed for solvents,
semivolatile organics, herbicides, and PCBs. Follow-up investigation will
depend on analytical results.
NEIC 05 - Chemical Impregnation Plant
A chemical impregnation plant, apparently a type of laundry facility,
was operated by the US Army Reserve to train for chemical
decontamination. Although no mixing or processing of solutions was
reportedly conducted, "XXCC3 impregnate" (11 89-pound drums in March
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1980) and "STB Bleach Decontaminate" (6 50-pound drums in March 1980)
were stored in the area. The drums were reportedly in poor/leaking
condition when inspected in March 1980 [1-25].
The location of this facility was not identified in the previous study
documents. Building 127 is a possible location. The specific location of this
facility should be determined and the area inspected to determine if the
activity has resulted in soil and groundwater contamination.
NEIC 06 - Herbicide Application Areas
Areas around JPG housing, impact ranges, railroad right-of-ways,
and perimeter fences may be contaminated with pesticides including DDT,
lindane, dieldrin, calcium cyanide dust, 2,4-D, 2,4,5-T, lead arsenate
powder, and Ureabor. Herbicide 2,4,5-D was used extensively during the
1950s and 1960s. This herbicide contains 2,3,7,8-tetrachlorodibenzo-p-dioxin
(TCDD) [1-30].
Impact area 22,000, Middle Fork Creek, and Vernon Fork (near Blue
Hole) were monitored in 1983 and found to be contaminated with the
herbicide Bromacil [2-2-3].
Soils from areas sprayed with herbicides should be sampled and
analyzed for herbicides and herbicide residues. Additional study may be
required based on the findings of this soil sampling.
NEIC 07 - Facility Oil I Water Separators
JPG has at least two oil/water separators associated with facility
maintenance activities; building 186 and building 110. The building 186
unit was discussed previously as part of JPG 035. The building 110
separator is located north of the building, just west of the paved driveway.
All facility oil/water separators should be identified and cleaned. The units
should then be inspected to determine if materials may have leaked from
the units and contaminated the surrounding soils.
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NEIC 08 • Building 216 "Locomotive Maintenance Pit"
Building 216 was apparently used for locomotive maintenance when
JPG operated its own railroad. There is a pit in the floor of the building
which may have been used as part of this maintenance. The pit was
covered with wood beams during the NEIC investigation and was not
inspected. This pit should be cleaned out, if necessary, and inspected to
determine if any material leaked from the unit into the surrounding soil.
NEIC 09 - "Z" Zone "Gator Mine" Test Area
JPG tests "gator mines" in an area in the southeast portion of the
facility. The mines are placed in sand pits surrounded by concrete and
plywood and detonated. Because the mines contain lithium power cells,
some lithium may be present in the sand pits following detonation. The
sand in the pits should be analyzed to determine if residual lithium is
present and leaching into the soil below the pits.
NEIC 10 - Active "Gator Mine" Open Burning Area
This area, located in the northeast corner of the gator mine test area
is used for disposal of gator mine testing debris. This area was also used at
one time as an MIR. Soil samples should be taken and analyzed for
herbicides and herbicide residue, explosives residue, heavy metals, and
lithium.
NEIC 11 - Building 136 Sandblasting Area
An area west of building 136 was used for sandblasting large objects
in preparation for painting. A portion of the area is not covered with
asphalt. Because red lead is known to have been present in paints used at
JPG (other heavy metals may have also been used), heavy metals may now
be present in the soil in the sandblasting area. The soil should be sampled
to determine the presence of heavy metals.
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NEIC 12 - Depleted Uranium (DU) Area (Delta Impact Area)
The DU area covers about 2 square miles, Sections 9 and 16, T.5N.,
R.10E., in the south central part of JPG between about 3,000 and
7,500 meters north of the firing line and between Wonju Road on the east
and Morgan Road on the west. Until 1984, tungsten alloy armor piercing
ammunition was fired into this area. When supplies of tungsten became
unreliable in 1984, a depleted uranium alloy was substituted. Depleted
uranium is principally U-238 depleted in the fissionable U-235 radionuclide.
Since 1984 about 50,000 kilograms of DU rounds are believed to have over
shot the area. Other rounds may have missed the area on either side.
Soil, stream sediment, surface water in both Big Creek, which
traverses this area, and Middle Fork Creek, south of the area and ground-
water from 11 monitoring wells are sampled semiannually. Monitoring
locations represent both presumed upgradient and downgradient areas, but
spacing is not sufficient to assure detection of contaminant migration in the
subsurface. The hydrogeological characterization has not been made to
determine the uppermost aquifer, groundwater gradients, flow direction
and rates, or potential pathways for pollutant migration. This work is
needed as a basis for establishing an adequate groundwater monitoring
system for the DU area. Some DU monitoring wells are so far from the DU
area that their usefulness is doubtful [Figure 4].
-------
REFERENCES
1. Initial Installation Assessment at Jefferson Proving Ground
(August 1980), U.S. Army Toxic and Hazardous Materials Agency,
USATHAMA, Aberdeen Proving Ground, Maryland.
2. Update of the Initial Installation Assessment of Jefferson Proving
Ground (January 1987), AMXTH-lR-A-176(u), U.S. Army Toxic and
Hazardous Materials Agency (USATHAMA), Aberdeen Proving
Ground, Maryland.
3. The Interim Final Report, Groundwater Contamination Survey No.
38-26-0306-89 (August 1988), Report for the Jefferson Proving Ground.
4. USEPA EPIC, Installation Assessment Re-look Program, Jefferson
Proving Ground, Indiana, June 1986.
5. Final Report, Ground-water Contamination Survey No. 36-26-0306-89,
Evaluation of Solid Waste Management Units, Jefferson Proving
Ground, Indiana, August 8 through 12, 1988 and May 15 through 18,
1989.
6. Remedial Investigation at Jefferson Proving Ground - Technical
Report A011: Prepared for USATHAMA by Environmental Science
and Engineering Inc., June 1989.
7. Greeman, Theodore K., 1981, Lineaments and Fracture Traces,
Jennings County and Jefferson Proving Ground, Indiana; U.S. Geol.
Survey, Open-File Report 81-1120 - Prepared in cooperation with the
Indiana Dept. Nat. Res. and U.S. Army, Jefferson Proving Ground.
-------
APPENDICES
A OPENING CONFERENCE PARTICIPANTS
B TSCA INSPECTION FORMS
C PELRON A&B MATERIAL AND SAFETY DATA SHEET
D HAZARDOUS WASTE MANIFESTS 87-0395/87001 AND 87-1419/88008
E TELEPHONE CONVERSATION RECORD DATED OCTOBER 7, 1989
F ASBESTOS EXPOSURE ASSESSMENT
G ASBESTOS DISPOSAL PERMIT
H INVENTORY OF TRANSFORMERS AND PCB CONTENT
I PCB QUARTERLY INSPECTION REPORT
J JPG RESTRICTED AREAS MAP
-------
APPENDIX A
OPENING CONFERENCE PARTICIPANTS
-------
Appendix A
LIST OF PARTICIPANTS
Opening Conference
JPG Environmental Audit
August 22 through 25, 1989
JPG
Colonel Dennis O'Brien; Commanding Officer
Robert Hudson; Technical Director
Thomas Roller; Deputy Director, Directorate of Materiel Testing
James Fritsche; Director, Directorate of Engineering & Housing
Kaushik Joshi, Environmental Coordinator
EPA. NEIC
Richard Ida; Chemical Engineer
Eugene Lubieniecki; Environmental Engineer
Alan Peckham; Hydrologist
-------
APPENDIX B
TSCA INSPECTION FORMS
-------
Appendix B
WASHINGTON. 00 20WO
TOXIC SUBSTANCES CONTROL ACT
NOTICE OF INSPECTION
For*
INVESTIGATION IDENTIFICATION
DATE
INSPECTOR NO DAILY SEQ. NO.
2. TIME
3. FIRM NAME
iRVlAODFIESS
^
REASON FOR INSPECTION
Under the authority of Section 11 of the Toxic Substances Control Act :
For the purpose of inspecting (including taking samples, photograpns, statements, and other inspector ac: •, t es'
ment, facility, or other premises in which chemical substances or mixtures or articles containing same are 'nanu'sc
essed or stored, or held before or after their distribution m commerce (including records, files, papers, processes, c
facilities) and any conveyance being used to transport chemical substances, mixtures, or articles containing same •
with their distribution in commerce (including records, files, papers, processes, controls, and facilities) bearing on
requirements of the Act applicable to the chemical substances, mixtures, or articles within or associated with such
conveyance have been complied with.
In addition, this inspection extends to (Check appropriate blocks)'.
G A. Financial data EJo. Personnel data
whetier "."e
prerr, ses 3r
G B. Sales data
G C. Pricing data
E. Research data
The nature and extent of inspection of such data specified in A through E above is as follows;
RECIPIENT SIG
NAME
DATE SIGNED
TITLE
DATE SIGNED
EPA Form 7740-3 (12-82)
INSPECTION FILE
-------
US ENVIRONMENTAL PROTECTION AGENCY
^^ V^Bf^k JL WASHINGTON, DC 2O460
^••^•^•^VA TOXIC SUBSTANCES CONTROL ACT
^^™l •* TSCA INSPECTION CONFIDENTIALITY NOTICE
1 INVESTIGATION IDENTIFICATION
DAT- / \ INSPECTOR NO j OA I L Y SEG.. NO,
3 -\SPECTOP NAME
5 NSPECT3R ADCFE3S
.f 'J- A-..* 0.
'"\ :^ •-, -> •"*> '^ L A~ ' "~
-r- «' 2 ^ J. — 7
Pivo-'5/2- C- C' ..fC 1 -?J> —
2. FIRM NAME
Form AQcfiveQ
QMS No ^070gf
Eioires 3-3! am\
-'--' §
4, r iRM ADDRESS
,/ j /-'~^y i£~f=i.-.L,,_~ /x. .-.
,:,x.,...- §
/^ V i) / J ,«- - A- -^ - /•)• 'C -"^~ x
""Jif
S. CHIEF EXECUTIVE OFFiCEH NAME |ji
•
TO ASSERT A CONFIDENTIAL BUSINESS INFORMATION CLAIM
It is possible that EPA will receive public requests for release of the
information obtained during inspection of the facility above. Such
requests will be handled by EPA in accordance with provisions of the
Freedom of Information Act IFOIA), 5 USC 552; EPA regulations
issued thereunder, 40 CFR Part 2; and the Toxic Substances Control
Act (TSCA), Section 14. EPA is required to make inspection data
available in response to FOIA requests unless the Administrator of th«
Agency determines that the data contain information entitled to confi-
dential treatment or may be withheld from release under other excep-
tions of FOIA.
Any or all the informa; on collected by EPA during the inspection may
be claimed confidential if it relates to trade secrets or commercial or
financial matters that you consider to be confidential bunnesi infor-
mation. If you assert a C8I claim, EPA will disclose the information
only to the extent, and by means of the procedures set forth in the
regulations (cited above) governing EPA's treatment of confidential
business information. Among other things, the regulations require that
EPA notify you in advance of publicly disclosing any information
you nave claimed as confidential business information.
A confidential business information (CBI) claim may b« auerted at any
t'me. You may assert a CBI claim onor to, during, or after the infor-
mation is collected. The declaration form was developed by the Agency
to assist you m asserting 3 CBI claim. If it is more convenient for you to
assert a CBI claim on your own stationery or by marking the individual
documents or samples "TSCA confidential busmesj information," it is
not necessary for you to use this form. The inspector will be glad to
answer any questions you may have regarding the Agency's CBI
procedures.
While you may claim any collected information or sample at confiden-
tial business information, such claims are unlikely to tw upheld if they
are challenged unless the information meet! the following criteria:
1, Your company has taken meatures to protect the confi-
dentiality of the information, and it intendi to continue
to take such measures.
I
The information is not, and has not been, reasonably oo|
without your company's consent by other persons loth
governmental bodies) by use of legitimate means (otn'f
discovery based on showing of special need in a |uaic,;
quasi-iudicial proceeding),
The information is not publicly available elsewhere. 1}
Disclosure of the information would cause substantial
harm to your company's competitive position.
3.
4.
At the completion of the inspection, you will be given a receio
documents, samples, and other materials collected. At that time,
may make claims that some or all of the information u confide
business information.
If you are not authorized by your company to assert a C8I da
notice will be sent by certified mail, along with the receipt for c
ments, sample*, and other materials to the Chief Executive Off
your firm within 2 days of this date. The Chief Executive Offio
return a statement specifying any information which should
confidential treatment.
The statement from the Chief Executive Officer should be ad1
to:
1
and mailed by regittered, return-receipt requested mail within 7 t
dar days of receipt of this Notice. Claims may be made an
after the inspection, but inspection data will not be entered
special security system for TSCA confidential business mfoi
until an official confidentiality claim is made. The data will be nai
under the agency's routine security system unless and until a cia
made. I
TO BE COMPLETED BY FACILITY OFFICIAL RECEIVING THIS NOTICE:
1 have received and read the notice
n T '
SIGNATURE / / ]/\ I /
NAVE
K/^SH K N- J^5Hl
TITLE
b- N Vi RON MEYJ T AL bfV(5- 1 Af' £;"£;"£
DATE SIGNED
*"7 "^ t 1 1 j» C fj
4L. *1 11 *J*»4 l^ 1
If there is no one on the premises of the facility who is authorized to <
bunneji confidentiality claimi for the firm, a copy of this Notice and
inspection materials will be sent to the company's chief executive off!
there is another company official who should also receive this inform!
please designate below.
NAME 1
1
TITLE
A bo ft ESS
EPA Form 7740-4 (12-82)
INSPEC1
-------
SEPA
US ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, OC 20*«0
TOXIC SUBSTANCES CONTROL ACT
RECEIPT FOR SAMPLES AND DOCUMENTS
Forr, Approved.
OMB No 207CKJC07
Approval expires 3-3' -38
1. INVESTIGATION IDENTIFICATION
DATE
INSPECTOR NO.
DAILY SEQ. NO.
PIRM ADDRESS
^ /"-*-
y'
The documents and samples of chemical substances and/or mixtures described below were collected m connection with :he
administration and enforcement of the Toxic Substances Control Act.
NO.
RECEIPT OF THE DOCUMENT(S) AND/OR SAMPLE(S) DESCRIBED IS HEREBY ACKNOWLEDGED:
DESCRIPTION
/
OPTIONAL:
DUPLICATE
SAMPLES: REQUESTED AND PROVIDED D NOT REQUESTED
INSPECTOR
RECIPIENT SIGNATURE
NAM
rur
NAME
DATE SIGNED
TTTUE
DATE SIGNED
EPA Form 7740-1 (12-82)
-------
_ ^^^ US ENVIRONMENTAL PROTECTION AGENCY
^^^ l^aMl^aaK^li WASHINGTON, DC 20*«0
^8"5af t^Sl^^V TOXIC SUBSTANCES CONTROL ACT
DECLARATION OF CONFIDENTIAL BUSINESS INFORMATION
1 INVESTIGATION IDENTIFICATION
DATE INSPECTOR NO. DAILY SEQ. NO.
3 NSPECTOR ADDRESS
2. FIRM NAME
4 FIRM ADDRESS <£•*=,=./?'
/v /C .;> / j 0 A_' ^I/^t)/^!*-'
Form Aooroved
OMB \o ;o 70
Empires 331 ..|
« ^ ;-|
'..*/
- -.1
\FORMATION D£SIGV.ATED AS CONFIDENTIAL BUSINESS INFORMATION
NO ' DESCRIPTION |
ACKNOWLEDGEMENT BY CLAIMANT
The undersigned acknowledge that the information described above is designated at Confidential Business Information under Section 14(c) of
Toxic Substances Control Act. The undersigned further acknowledges that he/she is authorized to make such claims for his/her firm.
The undersigned understands that challenges to confidentiality claims may be made, and that claims are not likely to be upheld unlea the r
mation meets the following guidelines: (1) The company has taken measures to protect the confidentiality of the information and it intend
continue to take such measures; (2) The information is not, and has not been reasonably attainable without the company's consent by o
persons (other than governmental bodies) by usa of legitimate means (other than discovery based on a showing of special need in a judicii
quasi-judicial proceeding); (3) The information is not publicly available elsewhere; and (4) Disclosure of the information would cause substai
harm to the company's competitive position.
NSPECTOR
CLAIMANT SIGNATURE
NAME
E/
NAME
N
TlYLE
DATE SIGNED
TITLE
DATE SIGNED
•7 ^ At !/"• ''
Z.J n<-f-, L
EPA Form 7740-2 (12-82)
INSPEC1
-------
ENVWONM6NTAL PROTECTION AGENCY
Offic* of Entonamint and Comptanc* MonMoring
RECEIPT FOR SAMPLES AND DOCUMENTS
HUT* o* Facility
/ s.
PflOJ. NO.
Ux*0on
7
RECEIPT OF THE DOCUMENT(S) ANO/OFI SAMPtE(S) DESCRIBeD IS HEREBY ACKNOWLEDGED:
NO.
DHSCRIPTKJN
Hi
00
TO
TTTVE
DATE
y
OATEStQNEO
mucirr muiTiN* orrict: I
N 12527
-------
APPENDIX C
PELRON A&B MATERIAL AND SAFETY DATA SHEET
-------
Appendix C
the urethane chemicals people
April 15, 1987
Mr. Aavshik Joshi
Environmental Coordinator
Jefferson Proving Ground
Department of The Army
Madison, In. 47250
Dear Mr. Joshi,
Enclosed please find the Material Safety Data Sheet and
Technical Bulletin for Perlon 2012 Part B.
The polyols used are of the following general structure:
1) Sucrose type C.A.S. No.9049-71-2
CH2(OC3H6)OH
H
Hx(C3H6°
CH2(OC3H6)OH
(OC3H6)OH
0(C3H6C)H H
7847 West 47th Strwt. P.O. Box 6 Lyonv Illinois 60534 312/442 9100
-------
the urethane chemicals people
PELF»N
7847 We* 47th Sftti. Lyons. Illinotx 60534 312/242-3166. 312/442.9100
2) Glycerine type C.A.S. No. 25791-96-2
rt /^ It rt T T
2^ w w f\ n /^ w n
3 6
r\c u nu
—w^in>-vn
CH0-OC,H,OH
/ Jo
I hope Chis information is sufficient. If not please
contact us.
Sincerel
FloPelletier
President
Enclosure
FP/cc
-------
the specialty chemicals people
PELR$N
PELRON CORPORATION
7847 West 47th Street
P.O. Box 6
Lyons, Illinois 60534
312/442-9100
technical bulletin
ELASTOMER 2012
ELASTOMER 2012 is a two component polyurethane resin system de-
signed to perform as an inert ballistic filler.
RESIN PROPERTIES;
The Part A is a polymeric isocyanate and may be purchased from
Mobay, Upjohn or ICI. This product should be kept dry and stored
between 60°F and 90°F. The viscosity is 100 to 2SO cps at 90°F.
The Part B is the resin-catalyst fraction and must be well mixed
before using. It should be stored between 60°F and 90°F- The
viscosity is 40,000 to 50,000 cps at 77°F. The specific gravity
is 2.20 to 2.30 at 77°F.
METHOD OF USE:
To produce the inert filler the ratio should be 20 parts of Part A
to 80 parts of Part B. Bring both Part A and Part B to approximately
80°F.
The A and B components are combined and mixed by machine or by hand:
Hand mixing should proceed for 80-90 seconds to assure a good mix.
PRECAUTIONS:
In handling this material, the user should employ sufficient ventil-
ation to prevent breathing any of the vapors given off from the
material itself or produced during the foaming process. The user
should also avoid allowing it to contact the skin.
NOTE: Th« information given above is based on typical laboratory data
and believed to be accurate. However, Pelron Corporation can in
no way guarantee that the user will reproduce them exactly.
060382jm
-------
Material Safety Data Sheet
May be used to comply with
OSHA's Hazard Communication Standard.
29 CFR 1910.1200. Standard must be
consulted for specific requirements.
U.S. Department of Labor
Occupational Safety and Health Administration
(Non-Mandatory Form)
Form Approved
OMB No. 1218-0072
IDENTITY (As Used on La&et and List)
PELRON 2012 Pare A Aromatic Isocyana
Note: Blank spaces »nt not permitted. # *ny *em a not apptca&e. or n,
e information is avaia&e, fft« space must be marked to indicate irta
Section I
Manufacturer's Name
PELRON CORPORATION
Address (Number, Szreef, City. Slate, and ZIP Code)
7847 W. 47th Street
P.O. BOX 6
LYONS, IL 60534
Emergency Tetepnone Number
800-424-9300
Telephone Number tor Information
312-442-9100
Date Prepared
Signature o( Preparer (optional)
Section II — Hazardous Ingredients/Identity Information
Hazardous Components (Specific Chemical Identity; Common Name(s)) OSHA P€L
ACGIH TLV
Other limits
Recommended
4,4 D i p he ny Lme r_ ha n Diisocyanate
. 02ppm
about 5
Higher oligomers of HDI-CAS #9016-87-9
NoC Established
about 5
Phenyl Isocvana te
Not established
Tracg
Section III — Physical/Chemical Chafacteristics
Boding Point
Vapor Pressure (mm Hg.)
Less than
406F at
10 mroHg at
Vapor Density (AIR - 1)
SmmHg
77F
8.5 (MD
Specific Gravity (HjO - 1)
Meting Port
; (Butyl Acetate - 1)
1.24
Below
at 77tj
32F
Solubfity in Water
Reacts slowly with water to liberate CO- gas
Appearance and Odor
Dark brown liquid, slightly musty odor
Section IV — Fire and Explosion Hazard Data
Rash Point
(Method
Used)
90F
P
ensky-Ma
rt in
CC
Flammable
Limits
LEL
US.
\
Extinguishing Media
Dry chemical (e.g. mo no ammo n i urn phosphate), high expansi on chemical foam
ecial fire Fighting Procedures
ull emergency quipment with self-contained breathing apparatus should b
"b~yEire t ight er s. A~ttemperatures great-er than <»OOF, polymeric MD1 can
polymerize and decompose which can cause pressure build up in closed conJ
Jntatol Fr» *nd &miaaian K«r«rrl« *
Unusual Fire and Explosion Hazards
SEE ABOVE
(Reproduce locally)
OSHA l74,SepU
-------
Se' - — Reactivity Data
SI. "*ty
Unstable
Slabte
XX
Conditions to Avoid
Incompatibility (Materials to Avoid)
Water, amines, strong bases
alcohols. Will cause some corrosion to copper
Hazardous Decomposition or Byproducts
By high heat ana fire;
, ,. .. , alloys.
carbon monoxide, oxides of nitrogen, traces of HCN,MD
Hazardous
Polymerization
May Occur
Wifl Not Occur
XX
Conditions to Avoid May occur, if, in contact, with moisture
or other material which react with isocyanates.
o r
Section VI — Health Hazard Data
Routes) of Entry.
Inhalation?
LC50 (4 hrO
Skin?
Ingest ion?
LD50
Health Hazards (Acute tnd Chronic)
Inhalation above .OZppm can produce irritation or mucous membranes in the
rcspi ratory tract. Skin-MDI reacts with skin protein and tissue moisture
can cause localized irritation.as well as discoloration. Eyes-liquid, v a
or aerosols are irritating and may cause tearing.
tn irritation and some corrosive action in mouth.
Cvcinooenotv. NTP7 (ARC Monooraons?
and
o r s
Ingestion-cou1d result
in
OSHA Regulated?
Signs and Symptoms ot Exposure
Mecfica! Conditions
Generally Aggravated by Exposure
Emergency and First Aid Procedures
EYE AND SKIN CONTACT; flush/rinse area exposed thoroughly. Wash contaminated
clothing before reuse. Ingestion-DO NOT INDUCE VOMITING. CONSULT PHYSICIAN
Section VII — Precautions for Safe Handling and Use
Steps to Be Taken in Case Material Is Released or Spiled
Cover the spill with sawdust,
or other absorbent material. Pour decontaminat
solution over spill area and allow to react cor at least 10 minutes. Collect
material in open containers and add further amounts of decontamination soluti o
Remove containers to a safe place, cover loosely and allow to stand 24-48 hour
Waste Disposal Method
Waste must be disposed of in accordance with federal, state and
1 oca 1
regu 1 a-
t ions. Incineration Ts che preferred method. Handle emp ty containers with c a
t If'h't
o*s
ontainers to prevent moisture contamination. Do not
reseal if contamination is suspected. Avoid contact with skin and eyes
Other Precautions
Section VIII — Control Measures
Respiratory Protection (Specty Type)
Air supplied respirator
Ventilation
^e*-"* XXXX
Mechanical (Genera?
Special
Other
Protective Gloves 6y» Prelection
natural rubber or polyvinyl alcohol. Chemical goggles or face
shield
Other Protective.Clothing or Equipment
Sjftety showers and eyewash stations should be available.
Work/Hygienic Practices "
Pege2
-------
I"
Occupational Safety and Health Administration
SHEET
OMB No. «4.|UJ»;
I •« I %w«*li*l
Required under USOL Safety and Health Regulations (or Ship Repairing,
Shipbuilding, and Shipbrcaking (29 CFR 1915. 191G. 1917)
SECTION I
MANUFACTURER'S NAME
PELRON CORPORATION
EMERGENCY TELEPHONE NO.
312-44 2-91 00
AOOAESS (Numbtr. Slrttl, Ctljr. Suit, tnd UP Code)
7B47 W. 47th Street Lyons. flllngls 6D534
CHEMICAL NAME AND SYNONYMS
TRADE NAME AND SYNONYMS
PELRON 2020'PART'S
CHEMICAL FAMILY
Polyethar Polyol Mixture
FORMULA
SECTION II - HAZARDOUS INGREDIENTS
PAINTS. PRESERVATIVES. & SOLVENTS
PIGMENTS
CATALYST
VEHICLE
SOLVENTS
ADDITIVES
OTHERS organic Amlne
X
i .:
TLV
(Unitfl
ALLOYS AND METALLIC COATINGS
BASE METAL
ALLOYS
METALLIC COATINOS
FILLER METAL
PLUS COATING OR CORE FLUX
OTHERS
HAZARDOUS MIXTURES OP OTHER LIQUIDS. SOLIDS. OR GASES
•
' * •
X
X
TLV
(Unilil
TLV
(Unilil
SECTION III • PHYSICAL DATA
BOILING POINT (V.)
VAPOR PRESSURE (mm H».»
VAPOR DENSITY (AIR-II
SOLUBILITY IN WATER
450°F
.002
1 .01
>o 1 ua b 1 a
SPECIFIC GRAVITY (H,O-1J
PERCENT. VOLATILE
BY VOLUME (%)
EVAPORATION RATE
i. , -1)
i .ni
0
N.A.
APPEARANCE ANOOOOR Ambftr ,,-„,,, «w««t nlld odnr
SECTION IV - FIRE AND
FLASH POINT (Method UMd) 7Q(\9f
EXTINGUISHING MEDIA
SPECIAL FIRE FIGHTING
EXPLOSION HAZARD DATA
1 FLAMMABLE LIMITS «-•' U(l
•
water. €0^. anv chemical ext 1 nau 1 sh 1 no. tvoe
PROCEDURES 7
Standard
UNUSUAL FIRE AND EXPLOSION HAZARDS .„._
NONE
PAGE (1)
(Continued on
i
revert* (id ' form OSHA-2<
R««. Mty 71
-------
SECTION V - HEALTH HAZARD DATA
THRESHOLD LIMIT VALUE
Non-toxic
OVEREXPOSURE
Possible sensitivity If sensitive to organic amines
EMERGENCY AND FIRST AID PROCEDURES
1naestI on-Induce voml11nq
Inhalation oxygen Eye Contact-water flush Skin contact-water flush
SECTION VI - REACTIVITY DATA
STABILITY y
S-
NSTABLE CON
tABLE X
OITIONS TO AVOIO
INCOMPATABILITY (Mtttrillt IO frotf/ .
. copper or -brass
HAZARDOUS DECOMPOSITION PRODUCTS
*
HAZARDOUS
POLYMERIZATION
MAY OCCUR
WILL NOT OCCUR
CONDITIONS TO AVOIO
X
SECTION VII - SPILL OR LEAK PROCEDURES
STEPS TO BE TAKEN IN CASE MATERIAL IS RELEASED OR SPILLED
water flush
WASTE DISPOSAL METHOD
standard removal techniques
SECTION VIII .
SPECIAL PROTECTION INFORMATION
RESPIRATORY PROTECTION (Sptdfy lyftf
not required
VENTILATION
LOCAL EXHAUST
f oca 1
exhaust adeauate
MECHANICAL (Ctnertl)
PROTECTIVE OLOVES
Not reaulred-
SPECIAL
OTHER
EVE PROTECTION ... . ,
safety f lasses
with eye
OTHER PROTECTIVE EQUIPMENT
shields
SECTION IX • SPECIAL PRECAUTIONS
PRECAUTIONS TO BE TAKEN IN
storage conta
OTHCH PRECAUTIONS
1 ners
NONE
HANDLING AND STORING . . j
standard handling techniques and
• i
•
• •(
.
PAGE (2)
Form OSHA-20 •;';>_..__.
-------
APPENDIX D
HAZARDOUS WASTE MANIFESTS 87-0395/87001 AND 87-1419/88008
-------
*3i".^ i e. OF" [J3(H5lANA
OEPAHTVENT Of ENVIRONMENTAL CKJAUTY
HAZARDOUS WASTE DIVISION
T.O. UOX 4-4307
BATON HOWIE. LOUISIANA 70804
Please print at type tform afuqned for us* on tint t12-ottchi i
Delivery Number - 11
REUSE/RECYCLE
Appendix D
form Agorovfd OMS No 20SOOO39 f to/res 9-30 S3
I
a
E
H
E
A
A
T
0
ft
UNIFORM HAZARDOUS ' Generator s US EPA iO No Man,t«.
WASTE MANIFEST IN5210020454 i . , , i^^^l
Jefferson Proving Ground
Madison, Indiana 47250-5100
« cener,,or, Phon, , 606 ,293-3405 / 3436
5 ransoorter I Comoany Name b US EPA 10 Numoer
Underwood Industries (TND980711741 i i i
7 ransoorter 2 Company Name i US EPA 10 Numoer
| 1 'iilll II
9 Des-gnjieo Facility Name and Site Aoaress 10 US EPA 10 Numo«
HESCO
Hwy. 1112
Crowley, Louisiana 70526 iLAD07i94640i95 ,
1 1 US DOT Oescnotion /Including Proper Shipping Hime. Hitird C/tss. ind IO Numturl
3 Waste Oil, n.o.s. NA 1270
(Used Motor Oil) Combustible liquid
b Waste 1,1,1-Trichloroethane ORM-A UN 2831
c.
d.
IT
I |
1 2. Contj
No
toll 12.
,
1 1
1 I
2. Pa^« 1 intorrn^doo n rre snaae: Jf*js
•4 not required Dv (-eae''«i
Of 1 law
A. Siat*> M^niieru DcC4xn«ni Nunio+f
87-0395
B- State Generator s iO
C. State Tranaooner t 0
D Transooner s Ptwe 615-894-3795
£. Siate Transporter f 10
F. Transooner I Ptxxve
G- State Facility i 10
H. Fsolitv S Ptwne
(318) 783-2624
liners ' 3 ' 4
Total ' Unit ''
Type Quantity Wt Vo Waste No.^
v^vkr-r,«/- N/A vRfv
bl^Al&Lri?1^ 6 . "-•&
JWIV^L. p°?ii
J M , . ,_ .'"^
1 ii - --i4£y
K. Handkng Code* tor Wane* Listed Aoove ;- j i;
\.
'C * ',
1 S Special Handling Instructions and Additional Information
IF SPILLED !N LOUISIANA CONTACT LOPS -HAZARDOUS MATERIAL UNIT 504-925-6553. IF UNABLE TO DELIVER RETURN
TO GENERATOR. WEAR GOGGLES, GLOVES & OTHER PROTECTIVE EQUIPMENT WHEN HANDLING MATERIAL
15 GENERATOR'S CERTIFICATION: 1 hereoy declare mat me contents erf this consignment are fully and accurately described above by
proper ship-ding name and are classified, packed, marted. and labeled, and are in all respects in Draper condition for transport by higtiway ^_
according to aoo'icaoie international and national government regulations.
If 1 am a large quantity generator. 1 certify that 1 have a program in place to reduce the volume and toxicitv of waste generated to the degree I have determined to be
economically practicable and that I have selected the practicable method of treatment, storage, or disposal currently available to me wnicn minimizes tn« p\\\1\%~1
1 7 Transporter t Acknowledgement of Receiot of Materials ' ' ~^~
^r'ma*1 Tyimil Name **^ > Signa^iu*^^^**^ * / _^ /J Month Osy *esr
ISfransponer 2 Acknowledgement of Receipt of Materials
Printed/Typed Name Signature Month On test
1 1 1
'9 Discrepancy Indication Space
20 facility Owner or Ooerator Certification of receipt of hazardous materials covered Oy this manifest encepi as noted m Hem 19
Printed/Typed Name ^ . Signature
N Month 3*v fca'
Horn S7HO-2.: (Kcv. 6/»(>) Cri«i ml -HA), I'.rccn-licncrator's 2nd. Yd l
v r, Hii\k-Tr»n«|iorti-r,
, t JEO Kk'-l n'n-
-------
Appendix D
^ii~WRf»» ri^j.*-*rv»*>^*
WASTE MANIFEST
' GeoeKHar1! US EPA 10 No.
»Tcoi noon/i =.A
N52100204,54
Mo*,•(<*r -f-a :T<.fff Lr»J'j Contract Number: DLA-200-87-D-0012
p£/nC- &~DGr./-7£ *•&*& Delivery Order Number: 51
16 GENERATOR'S CERTIFICATION: I hereby deetare mot the camem at m» coniignmem are My and accurately described above by proper ihwpwg name and are ooiud.d p
marked, and labeled, and are irt otf reipecn M proper ctf»di«ioi( for trampon by highway according to applicable international and national govemmemol regutortont.
If I am a large gwontrfy generator. I cemty tKot I hove O program in pioce to reduce the volume and toiKrty of wafte q
and (Kat I have veteded the prajctKOVe ineiltjij »i tiegtyienl, storage, or dnpoul* currenrty availobte
Oft. if I am a imaM quantify ge:
ottord.
bod f vfwr* t
nnred/Typed Nome / \
VJO,
1 regutortom. M
to be economically D'lj
hwmon heoffh and rh« «r)vM
t>«tjl «Jo4eot« w me and ihi
yy/
1 7
c*ip1 of Mot»nol»
Sigogture
Day
I 8 Traniponer 2 Acknowtedgemem o< Rcctipt of Malenoli
nted/Typed Nome
ILAcitT
19 Ducreponcy IndKOtion Space
20. Facility Owner or Operator: Certification of recetpt of Hazardous material* covered by f
ept as not«d i
Signature
ORIGINAL-RETURN TO GENERATOR
-------
APPENDIX E
TELEPHONE CONVERSATION RECORD DATED OCTOBER 7, 1989
-------
Appendix E
TELEPHONE OR VERBAL CONVERSATION RECORD
Fof ui* of fHli form, «•« AR 340-15; *• proponent apcncr li TH« Adjutant G.n.ral'i OHIc«.
Of. T t
October 7 1987
luajcCT Of COHV £«IA TlOM
Regulatory Exemption of Incineration of Excess Chemical Waste Generated from Bldg. 211-
Inert Processing WorK^hoo
»C««ON C AL LCD
PCRSON CA l_LIN«
Kaushik N. Joshi
P£B»ON CALLED
John Doss, Frank Profit
INCOMI KG CALL
A OOR III
orricc
OUTGOING CALL
O'^ICC
DEH-Environmental Engineer
AOORCIJ
Indiana Department of Environ-
mental Management
(812) 273-7285
•»HONC NUM8EK AND EXTCNIION
(317) 232-8427
IUMMART OF CONVCRIATIO*
1. Mr. Joshi called the Air Management, Enforcement Br., Plan Review & Permit Office t
inquire if Jefferson Proving Ground is required to obtain a regulatory permit to
incinerate the subject chemical waste.
2. The waste consists of two chemicals, part A chemical and part B chemical. These
chemicals are mixed in 20 percent/80 percent respectively to form filler material to
manufacture inert rounds. The generation amount is approximately two 25-gallon fiber
drums every month. The chemical part A is polymeric isocyonate and part B is polyether
polyol mixture. Incineration is the preferred disposal method.
3. Mr. Frank Profit responded to K.N. Joshi's inquiry. He stated that the generation
rate of the waste is below the lower end of the regulated amount. Therefore, JPG is
exempted from the regulatory requirement to obtain the permit. He further stated that
there are no notification, recordkeeping or reporting requirements that would be
applicable to JPG.
4. Therefore, JPG will follow the following incineration procedure:
a. Collect the excess part A and part B chemicals in only 25 gal fiber drums.
b. Store temporarily in Bldg^ 305 flw storage.
c. Incinerate periodically, using the on-site incinerator located in Bldg. 333.
The afterburner shall be operated during the incineration operation.
d. The waste and the 25 gal.fiber drum together will be incinerated. The drum
should not be opened. This is to prevent any exposure to these chemicals.
The date and approximate amount of the waste incinerated will be documented for
JPG records. Enclosed please find the "Material Safety, Data Sheets"(MSDS) of the part
A and part B chemicals.
KAUSHIK N. JOSHI
Environmental Engineer
n A FOR* 7 R 1
L//VAPM44 / *J I REPLACES COITION Of I FC« M WHICH WILL BC UfCO.
CF: J. Fritsche, T. Quiggle, M. Turner, Dale Padgett, Terry Walker
-------
APPENDIX F
ASBESTOS EXPOSURE ASSESSMENT
-------
01/01/90
INSPECTION FOR ASBESTOS EXPOSURE ASSESSMENT
BULK 5W1PLIN6
POLARIZED LIGHT MICROSCOPY RESULTS
Appendix F
LOCAHON
B100 Upstairs,Beige paperboard
8100 upstrs.,0rown'sn fiberglas
B100 ceiling tile (net* conf.rn)
BlOO, Entrance (1) transite (2)
B100, Entrance wall transited)
BlOO, Roo-f Shingle
BlOO, Room 11, Insulation
BlOO, Upstairs, Brown Board
BlOO, Upstairs, Sreen Board
BlOO, Upstairs, White Sypsu*
BlOO, Uostairs,Black Paperboard
BlOO, Upstairs,Black'sh Fibrgls
BlOO, (DA Attic,piping insul'n.
BlOO, il)BCon-f.Rra.,4"pip.cor.ins
BlOO,(1)6 roos 8B,4"pip.insui'n
BlOO,(2)A Attic,3"old pip. ins.
BlOO,(2)8 Con*. Ra,4"pip. ins.
BlOO, (2)6 Ra 8B,4'pioe.insurn
BlOO,(3)8 Attic, Floor insul'n
BlOO,(4)A Attic.3'new Pip.ins.
B100,Upstairs,Nhite-Gray Sypsua
BlOO,upstairs cant.rm,insul'n
B103,Insulation, Heating Plant
B112, Basement, Piping Insul'n
B112, Basement. Piping Insul'n
B112, Basenent, Piping Insul'n
B112,Attic,Ins.Mat.for Ceiling
B112,Attic, Ins.Mat. •for Ceiling
B112,Attic,Ins.Mat.for Ceiling
B112,Attic,Ins.flat.•for Ceiling
8112,Attic,!ns.Hat.for Ceiling
B114, Duct Insulation (1)
8115,(2)C Attic,8' Pipe. Ins.
B115,(3)C Attic,Corr.4"pip.ins.
B115,(4)C Attic,Floor Ins.Shngl
8115,(5)C Attic,Floor Insul'n
BUS,Attic,White Floor Insul'n
BUS,grab sapl.st*** timntl gas
B125,(1)D Door insul'n Accoust.
B144 3 1/2* insul'n Mctian. r«.
B144 5' insul'n MChanical root
6144 8* insul'n nechanical root
6144 ceiling plaster board
B144 Mil tile sprayed-on white
B144, Perforated hail Tile
B148
6149,Downspout dust (1) DwiSpt.
B149,Downspout dust (2) Dwnspt.
9186, Roof Siding
702, Container Coating
\
DATE
DATE
RECEIVED
LAB/CSL
NUMBER
PURCHASE
ORDER
NUHBER
12/16/88
12/16/88
04/11/88
/ /
/ /
03/10/88
09/07/87
12/16/88
12/16/88
12/16/88
12/16/88
12/16/88
/ /
/ /
/ /
/ /
/ /
/ /
/ /
/ /
12/16/88
/ /
09/18/87
06/03/87
06/03/87
06/03/87
06/03/87
06/03/87
06/03/87
06/03/87
06/03/87
04/11/88
/ /
/ /
/ /
/ /
/ /
07/20/87
/ /
04/11/88
04/11/88
04/11/88
04/11/88
04/11/88
04/11/88
/ /
12/16/88
12/16/88
/ /
/ /
12/19/88
12/19/88
04/11/88
09/07/88
09/07/88
03/10/88
12/02/87
12/19/88
12/19/88
12/19/88
12/19/88
12/19/88
12/15/87
12/15/87
12/15/87
12/15/87
12/15/87
12/15/87
12/15/87
12/15/87
12/19/88
12/15/87
12/02/87
07/21/87
07/21/87
07/21/87
07/21/87
07/21/87
07/21/87
07/21/87
07/21/87
04/11/88
12/15/87
12/15/87
12/15/87
12/15/87
12/15/87
OS/13/87
12/15/87
04/11/86
04/11/88
04/11/88
04/11/88
04/11/88
04/11/88
12/05/88
12/19/88
12/19/88
12/05/88
12/05/88
45761-05
45761-03
41684-1
44072-2
44072-1
40691-1
A 271
45761-09
45761-08
45761-07
45761-06
45761-01
A 278
A 282
A 296
A 279
A 283
A 297
A 280
A 281
45761-10
A 298
A 270
A 210
A 211
A 209
A 206
A 207
A 204
A 208
A 205
41684-7
A 283
A 286
A 287
A 288
A 284
A 226
A 289
41684-6
41684-9
41684-10
41684-3
41684-4
41684-2
45546-2
45761-03
45761-04
45546-1
45546-5
PC
PC
PC
PC
PC
PC
PC
PC
PC
10038
10051
10051
10051
•0051
•0051
•0051
•0051
•0051
W52HZB7365
PC
PC
PC
PC
PC
PC
PC
PC
PC
PC
PC
PC
PC
PC
PC
PC
•00.38
•0299
•0299
•0299
•0299
•0299
•0299
•0299
•0299
•0051
•0051
•0051
•0051
•0051
•0319
•0051
TYPE OF
ASBESTOS
FIBERS
none
Chrysotiie
none
Chrysotile
Chrysotile
Chrysotile
Chrysotile
none
none
none
none
none
Aaosite
Chrysotile
Chrysotile
NA (paper)
Anosite
Chrysotile
Aaosite
Chrysotile
none
Asbestos
Chrysotile
Asbes.tos-X
Asbestos-X (Chrys)
Asbestos-X (Chrys)
Asbestos-X
Asbestos-X
Asbestos-X
Asbestos-X
Asbestos-X
none
Aaosite
Chrysotile
Chrysotile
Chrysotile
NA mineral Wool)
Asbtstos-X(Chrys)
NA
Aaosite
Aaosite
Aaosite
none
none
none
Chrysotile
Chrysotile
none
Chrysotile
none
cE.!C-Ti3E
Qf :c;F:--c
1- I K> - -
nore
T-:
nore
5- 1/.
5- I:1'.'
25- TO"
20- :•:'•:
none
nore
none
none
none
45-507.
30-401/.
30- *0'/,
none
30-40X
25-30X
3-57.
15-207.
none
none
40-507.
none
10-157.
40-501/:
none
none
none
none
none
none
20-307.
15-207.
20-302
35-407.
30-40X
none
25-30X
25-307.
20-257.
none
none
none
2-3Z
10-157.
none
25-307.
none
-------
Pace >to.
Gl/01'80
INSPECTION FOR ASBESTOS EXPOSURE ASSESSMENT
BULK SAMPLING
POLARIZED LIGHT MICROSCOPY RESULTS
B202, Container Coating (1)
B202, Ins. Pice, attic over brkra.
B311 3" insulation (large rooai)
8311 3" insulation (snail rood)
B311 5' insulation (wash basin)
B311 8" insulation (near basin)
B6(2,!U£ Boiler bcdy,Surt. ins
Bt/2. '2'E ?oii.3cjy,Siir + ace ins
BiO;. ;3;E 12upipir,q insulation
B6'J2. i4>E 4"pip, insui'n icorr)
BtC2,Bciiet- trnt. Body insui'n
B602, Boiler +rnt,BcJy insui'n
Bi02,Bciier •frnt,Re*;-actO': Ceilin? insui'n tile
B617. '21C Boil.Bcay,Surtace ins
Die Timoe" LOC-J? Roo- Pact' ing
DATE
04/05/88
04/11/88
04/11/88
04/11/88
04/11/88
/ /
/ /
/ /
/ /
04/22/88
04/22/88
04/22/88
04/22/88
04/22/88
05/21/87
05/21/87
05/21/87
/ /
/ /
/ /
DATE
RECEIVED
12/05/88
04/05/88
04/11/88
04/11/88
04/11/88
04/11/88
12/15/87
12/15/87
12/15/87
12/15/87
04/22/88
04/22/88
04/22/88
04/22/88
04/22/88
06/08/87
06/08/87
06/08/87
12/15/87
12/15/87
12/05/88
LAB/CSL
NUMBER
45546-4
41084-1
41684-13
41684-11
41684-12
41684-5
A 290
A 291
A 292
A 293
41882-3
41882-2
41882-5
41882-1
41882-4
A 192
A 191
A 193
A 294
A 295
45546-3
PURCHASE
ORDER
NUMBER
PC
PC
PC
PC
PC
PC
PC
PC
PC
10051
10051
*0051
10051
10267
10267
10267
10051
10051
T^PE OF
ASBESTOS
FIBERS
none
Chrysotile
Chrysotile
Chry,(A«o <17.)
Chrys, (aio 5-107.)
Chrysotile
NA (Mineral Wool)
Chrysotile
Afflosite
Chrysotile
Anosite
Dirysotile
Chrysotile
Chrysotile
Chrysotile
Asbestos-7.
Asbestos-'/.
Asbestos-X (Chrys)
NAdiin.wool.papr)
Chrysotile
Chrysotile
GFf
Fit
4
*""i
2('-l
25-3(
norl
5-1
20-3(
25-ji
3-51
10-"
5-7V
10-1
25-1
none
none
40-5J
4d-l
'•
-------
APPENDIX G
ASBESTOS DISPOSAL PERMIT
-------
DEPARTMENT OP THE ARMY
U-S. ARMY JEFFERSON PROVING GROUND
MADISON, INDIANA 47230.5100
November 21, 1988
- TO
ATTHTTION Of
Directorate of Engineering and Housing
SUBJECT: Renewal of Approval to Dispose of Asbestos
Indiana Department of Environmental Management
Solid and Hazardous Waste Management
Solid Waste Management Branch
ATTN: Asbestos Disposal Renewal (George Oliver)
105 South Meridian Street
P.O. Box 6015
Indianapolis, Indiana 46206-6015
Dear Mr. Poe:
U. S. Army Jefferson Proving Ground (JPG) , disposes of
asbestos, which is removed from JPG buildings, in our
state-approved, Gate 19 solid fill site. We hereby request the
State of Indiana to renew the approval to continue the asbestos
disposal operation until April 1, 1989. JPG will request the
renewal of the solid fill site operating permit and asbestos
disposal permit in April 1989 for the next two years.
Enclosed please find the State permit to operate the solid
fill site, and the fill-site map, indicating the proposed
asbestos disposal location cells.
If you have any questions regarding this renewal request,
please contact Mr. K. N. Joshi, Environmental Engineer at (812)
273-7285.
•**.
n
Sincerely, ^
07
*
James A. Fritsche, P. E.
Director, Engineering and Housing
Enclosures
Dispel
-------
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
NANCY A. A<\ALOLEY, Commission!'
»
105 South Meridian Str>
P.O. Box 601
Indianapolis 46206-60!
Telephone 317-232-8603
Office of Solid And Hazardous Waste Management
Special Waste Disposal Approval
Case No. so763
The following State Permitted Sanitary Landfill
Jefferson Proving Ground Solid Fill Site
U.S. Army
Jefferson Proving Ground
Madison, IN 47250-5100
is authorized by the Indiana Department of Enuironmental
Management, Office of Solid and Hazardous Waste Manageme|
to dispose of:
asbestos waste
from the following generator:
U.S. Army, Jefferson Proving Ground
Madison, IN 47250-5100
This approual shall enpire on December 31, 1939
Special conditions that apply to this approual are indicated
on the reuerse side.
Bruce H, Pal in, Acting Date
Assistant Commissioner for
Solid and Hazardous Waste
Management
-------
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
NANCY A. /^\ALOLEY, Commissioner
105 South Meridian Street
P.O. Box 6015
Indianapolis 46206-6015
Telephone 317-232-8603
ASBESTOS DISPOSAL CONDITIONS
Case No. go 7O
SPECIAL CONDITIONS THAT ARE REQUIRED FOR DISPOSAL OF THIS WASTE INCLUDE:
1. Asbestos shall be covered Immediately with soil or solid waste to
prevent airborne release.
2. All asbestos shall be sufficiently wetted to prevent airborne
release during disposal operations.
3. There shall be no direct physical contact between asbestos material
and heavy equipment during disposal/cover operations.
4. Each container shall be labeled: "Caution - Contains Asbestos - Avoid
Opening or Breaking Container. Breathing Asbestos is Hazardous to
Your Health".
5. Appropriate protective clothing should be used during handling
and disposal to ensure proper protection from exposure to the
material, especially from Inhalation.
6. Translte siding and panels containing asbestos shall be wrapped and
sealed in at least six (6) mil elastic..
Jr
I2ji/
Reviewer/Date Section Chief/Date Brancti Chief/Date
-------
APPENDIX H
INVENTORY OF TRANSFORMERS AND PCB CONTENT
-------
Appendix H
NAME
Westinghouse
Westinghouse
Westinghouse
Weaver Else.
Weaver Elec.
Weaver Elec.
Weaver Elec.
Weaver Elec.
Weaver Elec.
Uptegraf f
Uptegraf f
Uptegraf f
Uptegraf f
Uptegraf f
Uptegraf f
Westinghouse
General Elec.
Westinghouse
Kuhlman
Kuhlman
Kuhlman
Uptegraff
Balteau Stand.
Balteau Stand.
Balteau Stand.
Westinghouse
Westinghouse
Westinghouse
KVA
100
100
100
25
25
25
25
25
25
10
10
10
15
15
15
25
25
25
25
25
25
15
667
667
667
333
333
333
CYC
60
60
60-
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
TRANSFORMERS
LOCATION SERIAL V
B-100
B-100
B-100
TH 45
TH 45
TH 45
TH 46
TH 46
TH 46
B-47
B-47
B-47
B-48
B-48
B-48
Fac. 49
Fac. 49
Fac. 49
B-101
B-101
B-101
B-102
B-102 A
B-102 A
B-102 A
B-102
B-102
B-102 •
6725916
6725913
6725915
16737
16736
16735
16748
16752
16748
20861
20858
20859
20844
20849
20851
3005482
9284791
3005441
4626071003
4626071002
4626071001
20835
PNL-0779
PNL-0780
6800261
85A262022
85A240659
85A240658
/x. / & * T
-------
NAME
Westinghouse
Wes tinghouse
Westinghouse
L'ptegraff
Uptegraf f
Uptegraf f
Wes tinghouse
Westinghouse
Westinghouse
Uptegraf f
Uptegraf f
Uptegraf f
Uptegraf f
General Elec.
General Elec.
General Elec.
Westinghouse
Westinghouse
Westinghouse
Uptegraf f
Uptegraf f
Uptegraf f
Westinghouse
Westinghouse
Westinghouse
General Elec.
Westinghouse
Uptegraff
Westinghouse
PAD MOUNT
KVA
25
25
25
50
50
50
75
75
75
25
25
25
5
15
15
15
50
50
50
5
5
5
50
50
50
10
25
25
25
112.5
CYC
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
LOCATION
B-104
B-104
B-104
B-107
B-107
B-107
B-113
B-113
B-113
B-129
B-129
B129
B-133
B-136
B-136
B-136
B-137
B-137
B-137
B-139
B-139
B-139
TH 143
TH 143
TH 143
B-148
B-162
TH 162
B-162
Sewage Plaat
SERIAL •'/
68AD2494
572292
68AC8453
20802
20803
20801
71AF12034
71AD5031
71AF10199
20830
20812
23718
21087
B589035
B589037
B589038
71AJ8912
71AJ8913
71AJ8914
21083
21Q88
22266
6400491
6402836
6402844
95G336
6446314
20827
6448408
S800690N
GALLONS
17
17
17
27
27
27
43
43
43
16
16
16
5
12
12
12
50
50
50
5
5
5
26
26
26
Dry Type
17
16
17
60
PCB
ND
1072 & 1024
ND
6
6
ND
ND
ND
18
ND
81
33
ND
4
12
27
ND
ND & 10
ND
ND
ND
54
5
8
9
0
ND
ND
ND
ND
Paee 2 of
-------
. - - ..;.. uiu LOCATION SERIAL if
Square "D"
General Elec.
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Centeral Lrous
Centeral Lrous
Centeral Lrous
General Elec.
General Elec.
General Elec.
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
General Elec.
General Elec.
General Elec.
Centeral Lrous
Centeral Lrous
Centeral Lrous
RTE
RTE
RTE
Weaver
Weaver
Weaver
General Elec.
General Elec.
Weaver
Standard
Standard
Standard
Howard Elec.
Howard Elec.
30
25
25
25
25
25
25
37.5
37.5
37.5
25
25
25
25
25
25
25
25
37.5
37.5
37.5
37.5
37.5
37.5
25
25
25
37.5
37.5
37.5
25
25
25
75
75
75
25
25
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
GALLONS PCB NOTES
Sewage Plant 3349-171212-024'Dry
B-186
B-186
B-186
B-203
B-203
B-203
B-206
B-206
B-206
B-210
B-210
B-210
B-213
B-213
B-214
B-214
B-214
B-215
B-215
B-215
B-217
B-217
B-217
B-218
B-218
B-218
B-228
B-228
B-228
B-229
B-229
B-229
B-233
B-233
B-233
B-264
B-264
6880588
20806
20817
20829
20807
20825
184834
184835
184837
L138261Y73AA
L140308Y73AA
L138266Y73AA
20804
20813
20819
20814
20822
(inside)B703367
(inside)B769898
(inside)B703370
184832
184836
184838
821083179
821079443
821083180
16729
16731
16738
L395795Y74AA
L396798Y74AA
16753
85201
85199
85200
34529-2083
34532-2083
17
16
16
16
16
16
43
43
43
15
15
15
16
16
16
16
16
26
26
26
43
43
43
16
16
16
26
26
26
12
12
16
58
58
58
16
16
0
486
ND
ND
ND
ND
ND
15
ND & 10
ND
ND
ND
ND
ND
ND
ND
ND
ND
399
252
385
ND
ND
ND
ND
ND
ND
ND
ND
59 & 78
ND
ND
12
78
74
47
ND
ND
Page
of
-------
NAME
KVA
CYC
LOCATION
SERIAL
GALLONS
PCB
Howard Elec. 25 60
Howard Elec. 25 60
Howard Elec. 25 60
Howard Elec. 25 60
General Elec. 25 60
General Elec. 25 60
General Elec. 25 60
Line Material 25 60
Line Material 25 60
Line Material 25 60
Howard Elec. 25 60
Howard Elec. 25 60
Howard Elec. 25 60
Magnetic 25 60
Magnetic 25 60
Magnetic 25 60
Uptegraff 10 60
Uptegraff 7.5 60
Uptegraff 7.5 60
Uptegraff 7.5 60
Westinghouse 25 60
Uptegraff 25 60
Uptegraff 25 60
Uptegraff 25 60
Uptegraff 25 60
Uptegraff 25 60
Uptegraff 25 60
Uptegraff 25 60
Uptegraff 5 60
Uptegraff 5 60
Westinghouse 25 60
Westinghouse 25 60
Westinghouse 25 60
McGraw-Edison 15 60
McGraw-Edison 15 60
McGraw-Edison 15 60
General Elec. 5 60
Howard Elec. 25 60
Howard Elec. 25 60
B-264 3A527-2083
B-267 34535-2083
B-267 34533-2083
B267 34531-2083
B-280 B435371
B-280 B435358
B-280 B437026
B-2S7 282587
B-287 282508
B-287 282496
D Pos 34530-2083
D Pos 34528-2083
D Pos 73969-4383
J Pos HE13595
J Pos HE13596
J Pos HE 13597
B-302 17111KK
B-305(storage)21067
B-305(storage)21070
B-305(storage)21066
B-305 6448404
B-309 20824
B-309 20815
B-309 20808
B-295(storage)20826
B-295(storage)20823
B-295(storage)20920
B-321
B-321
B-321
B-329
B-329
B-329
B-333
B-333
B-333
B-488(pole)
500 Center
500 Center
21077
21079
21175
6448402
6446395
6446341
72ZN107013
72ZN107009
72ZN107005
9347593
86164-4983
34534-2083
16
16
16
16
17
17
17
20.5
20.5
20.5
16
16
16
16
16
16
8
8.5
8.5
8.5
17
16
16
16
16
16
16
5
5
5
17
17
17
12
12
12
5
16
16
ND
ND
ND
ND
317
312
96
ND
ND
39 & 38
ND
ND
ND
ND
ND
ND
ND
9
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
17
13
164
ND
ND
408
ND
ND
Pa,
nf
-------
NAME
KVA
CYC
LOCATION
SERIAL if
GALLONS
PCB
MOTES
Howard Elec.
RTE
RTE
RTE
General Elec.
General Elec.
General Elec.
Uptegraf f
Uptegraf f
Optegraf f
Centeral Lrous
Moloney
Moloney
Moloney
General Elec.
Uptegraf f
Moloney
Westinghouse
Westinghouse
Westinghouse
Uptegraff
Westinghouse
Westinghouse
Westinghouse
Allis Chambers
Allis Chambers
Allis Chambers
General Elec.
Kuhlman
Uptegraff
Uptegraff
Uptegraff
Kuhlman
Kuhlman
Kuhlman
Magnetic Elec.
Magnetic Elec.
Magnetic Elec.
25
15
15
15
50
50
50
7.5
7.5
7.5
10
50
50
50
25
25
25
50
50
50
7.5
50
50
50
10
10
10
37.5
10
15
15
15
25
25
25
25
25
25
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
500 Center
B-501
B-501
B-501
B-504
B-504
B-504
B-508
B-508
B-508
B-518
B-534
B-534
B-534
B-542
B-542
B-542
B-600
B-600
B-600
600 Tower
B-602
B-602
B-602
M-603
M-603
M-603
B-605
B-605
B-609("F")
B-609("F")
B-609("F")
B-609("F")
B-609("F")
B-609("F")
B-609("F")
B-609("F")
B-609("F")
73930-4383
781122361
781122360
781122359
B395368
B395369
B395389
21063
21064
21065
18484
705959
705966
705965
E426471-62P
24008
672939
6034300
6034259
6034320
21067
6025294
6023566
6025295
211869
211769
211798
6571967 '
944280
20841
20845
20832
4626911-003
4626911-002
4626911-001
HG06201
HG06199
HG06200
16
12
12
12
26
26
26
8.5
8.5
8.5
16
26
26
26
15
20
17
26
26
26
8.5
12
12
12
8
8
8
26
8
12
12
12
16
16
16
16
16
16
ND
ND
ND
ND
640
627
1648
ND
ND
ND
ND
ND
ND
ND
161
.^
741 /
53
ND
ND
13 & ND
9
ND
12
ND
ND
ND
ND
152 & 162
246
ND
ND
ND
ND
ND
ND
ND
ND
ND
Page
of 8
-------
NAME
KVA
CYC
LOCATION
SERIAL
GALLONS
PCB
Wes tiaghouse
Westinghouse
Westinghouse
Wes tinghouse
'Westinghouse
Westinghouse
General Elec.
General Elec.
General Elec.
Westinghouse
Kuhlman
General Elec.
General Elec.
Uptegraf f
Maloney
Allis Chambers
Howard In.
Howard In.
Howard In.
Howard Elec.
Howard Elec.
Howard Elec.
Allis Chambers
Westinghouse
Allis Chambers
Uptegraf f
Line Material
Maloney
General Elec.
Westinghouse
Westinghouse
Uptegraff
Uptegraff
Westinghouse
Uptegraff
Westinghouse
Uptegraff
Uptegraff
Uptegraff
50
50
50
50
50
50
50
50
50
5
37.5
25
15
10
3
5
25
25
25
25
25
25
3
10
5
15
15
3
15
25
10
5
15
10
15
10
15
10
15
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
B-612
B-612
B-612
B-617
B-617
B-617
"A" Pos
"A" Pos
"A" Pos
B-700
2100W
Gate 1
Gate 3
Gate 8
Gate 19
Gate 19
Gator Mine
Gator Mine
Gator Mine
"Y" Pos
"Y" Pos
"Y" Pos
Old Timbers
Old Timbers
Old Timbers
"Z" Pos
Truck Insp.
B-295(storage)
K. Lake
K. Lake
W. Signal
Hyde Pond
N.W. Exit
K. Rd B Hive
K. Rd
Drop Tower
E. Pt Camp
Old Timbers
Old Timbers
6034287
6034294
6034331
6034302
6034298
6034301
J105343Y69A
J108247Y69A
J108248Y69A
6453127
C27398
E816498-61R
J138772Y69A
20862
701224
2572532
73971-4383
29392-2584
29390-1584
73974-4383
73972-4383
73973-4383
1664260
6482323
2572490
20840
271608
701223
J138773Y69A
59B11892
2808326
21075
20838
6500923
20846
2727435
20836
20860
20865
26
26
26
26
26
26
26
26
26
5
26
17
11
8
3.5
5
16
16
16
16
16
16
3.5
8
5
12
12
3.5
11
30
8
5
12
8
12
8
12
8.5
8.5
20
ND
12
ND
ND
ND
ND
ND
ND
59
ND
11
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
30
ND
ND
28
26
ND
18
280
ND
ND
27
ND
364 & 347
ND
ND
ND
Page
-------
NAME
KVA
CYC
LOCATION
SERIAL
GALLONS
PCB
•;OT-
Uptegraff
Magnetic Trans
Westinghouse
Westinghouse
Moloney
Allis Chambers
Westinghouse
Kuhlman
Uptegraff
Westinghouse
RTE
IJptegraf f
General Elec.
Westinghouse
Westinghouse
General Elec.
Westinghouse
Uptegraff
Weaver
Westinghouse
Westinghouse
Westinghouse
H.K. Porter
Magnetic Elec.
Magnetic Elec.
Magnetic Elec.
Magnetic Elec.
Westinghouse
Westinghouse
Westinghouse
Westinghouse
RTE
Kuhlman
Kuhlman
Westinghouse
Uptegraff
15
10
5
5
3
5
5
5
5
25
10
5
5
5
5
10
10
5
25
167
167
167
10
10
10
10
10
10
50
50
50
5
37.5
37.5
50
5
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
Emerg. Landing20854
C Rd & Jines
Jines Rd
Jines Rd
Jines Rd
Jines Rd
Jines Rd
Jines Rd
Jines Rd
Jines Rd
Jines Rd
Jines Rd
Jines Rd
Jines Rd
Jines Rd
Jines Rd
Jines Rd
HE11667
6057303
6057304
701225
2572503
6055934
825700
21081
6448404
821094729
21086
6041205
6057300
6057301
L564305Y70
6482307
B-295(storage)21080
Pole Shun Pikel6747
TR. Bank
TR. Bank
TR. Bank(B711
Gator Mine
"J" 1000M
"J" 2000M
"J" 3000M
"J" 4000M
Tower 542
B295 storage
B295 storage
B295 storage
B295 storage
B295 storage
B314 storage
B315 storage
B295 storage
82A490346
82A490347
)82A490348
5501044
4F00392
HF00394
HF00391
HF00393
2718789
6034255
6034223
6034271
841144452
C27410
C27405
59B11669
21080
12
8
5
5
3.5
5
5
5
5
17
8
5
5
5
5
8
8
5
16
65
65
65
8
8
8
8
8
8
26
26
26
3
28
28
26
4 3/4
ND
ND
ND
ND
ND
ND
ND
84
ND
ND
ND
ND
ND
30
6
ND
32
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
219
ND
ND
ND
ND
ND
ND
ND
ND
Page
of
-------
KVA CYC LOCATION SERIAL # GALLONS PCS
Line Material 75 60 B295 storage 1655423 43 ND
Line Material 75 60 B295 storage 1610727 43 ND
Line Material 75 60 B295 storage 1610715 43 ND
Vantran 15 60 B295 storage 3219 12 ND
Vantran 15 60 B295 storage 3229 12 ND
Vantran 15 60 B295 storage 3222 12 ND
Page fl of_a_
-------
July 15, 1987
Directorate of Engineering & Housing
United States Environmental Protection Agency, Region 5
ATTN: Scott Cooper
PCB Control Section (5S-P&TSB-7)
230 So0fth Dearborn Street
Chicago, Illinois 60604
Dear Mr. Cooper t
This is in response to the U.S. SPA1* February 1966 inspection of the
Jefferson Proving Ground's handling of it* Polychlorinated Biphanyl* (PCB)
items. JPG has developed. the following information to eliminate the defieien- -
cies as outlined by Mr. Daniel Papcka, Environmental Engineer, In his report.
PCB AHNUAL DOCUMENTS
Enclosed please find our record* on PCB disposals for 1984 through 1986,
quarterly inspections for 1982 through 1987, and annual inventories of trans-
formers and oil switches for 1986 and 1987 • Ve hay* reviewed all the information
that ve have on records regarding PCB items and are submitting in compliance with -
U.S. EPA TSCA 40 CFR 761 requirement*.
The PCB disposal records include the disposed data, total quantity In
gallons, PCB concentration and EVA (Kilo Volt Amperes). Aa transit storage
locations before their disposal are JPG Building* 305 and 502. HM PCB item*
are submitted with completed documentation including their PCB ppa concentration
to the on site Defense Reutilisation and Marketing Office (DEMO) for their for-
warding to a licensed transport contractor. Since thi* inspection, we hart
started record keeping of the removal data. The 1986 and 1987 inventory record*
on the in-service item* include information on EVA (Kilo Volt A«peres), PCB ppm
concentration, and PCB quantities in kilogram*. Ve have maintained the disposal
records for three years, quarterly inspections records for six yaars, and inven-
tories for two year*. Ve have not b«*n able to locate the la*t five year* fecords for
all these three items. But, now on, JPG will Maintain th**e record* for at least '
five year*. Our list of t ran* formers i* kept on a oalandar year basis. We alio
have compiled a lilt of capacitor* that we have on JPG and sinoa thay era in a
sealed form and can not be sampled and analyzed for PCI, ppm, we qomida* then
PCB item*. Ve have marked with label* all tha locations that st*ra PCB> H*aia.
'
\J
*.*•
''J V-
-------
-2-
f
JPG cleaned the spilled oil drops from the Uptegraff PCB transformer,
serial number 24008, (741) ppo at Building 542 with cotton cloth and stored
the cotton cloth with the oil spill in our Building 305. This cisan-up vaj
conducted in accordance with the method as suggested by the inspector,
Mr. Daniel Papcke, U.S. EPA. We will dispose of the cloth materials through
the DRKO Office. We will also take a sample (glass wool dampened with H-Hexane)
of the cleaned area and analyze (GC) for PCB.
Please call Mr. Kaushik N. Joshi, Environmental Engineer, at (812) 273-7285
if you have questions or need additional information. Be is the point of contact
for all the environmental matters including PCB cod asbestos.
Sincerely,
Enclosures • Richard M. Mabry
1. PCB Disposals Colonel, Ordnance Corp*
2. Quarterly Inspections Coenaading
3. 1986 Inventory
4. 1987 Inventory
5. List of PCB & Non-PCB Capacitors
6. Polychlorinated Biphenyls Analysis
-------
PCB DISPOSALS
DATE
1/31/86
1/31/86
1/31/86
1/31/86
10/15/85
10/15/85
10/15/85
10/15/85
9/8/85
9/24/84
7/25/84
7/25/84
7/25/84
7/25/84
7/25/84
7/25/84
PCB ITEM
Transformer
SER. if
6800259
Portable tank
Transformer
85 Gal Drum
Transformer
Transformer
Transformer
Transformer
PCB Oil
Transformer
Capacitor
Capacitor
Transformer
Transformer
Transformer
PCB Fluid
Parts
Overpack
6850602
7661357
6800260
6800261
1642704
J412151
J412141
2718789
21069
TOTAL QUANTITY
9700
355
500
500
300
350
9700
9700
23
80
120
250
200
165
75
KVA
667
5
10
667
667
5
100
100
5
10
6.5
PCB
A3
104,639
1999
83
80
82
500
500
1-9
219
9
67
-------
MFG.
Westingfaouse
Westinghouse
Westinghouse
Westinghouse
Kuhlman
Kuhlman
RTE
Line Material
Line Material
Line Material
Line Material
Line Material
Weaver
Weaver
Weaver
Weaver
Weaver
Weaver
GE
X-Ray M/C
PCB Oil
PCB Oil
GE
Line Material Co.
Moloney
Moloney
Moloney
SER. #
59B11669
6034255 '
6034353
6034271
C27405
C27410
841144452
280152
280156
1610727
1610715
1655428
16734
16733
16732
16740
16730
16739
M1010020
4926647
271612
706596-
706600
706593
STORAGE
314
502
502
502
304
502
502
502
502
502
502
502
108A
108A
108A
108A
108A
108A
305
305
305
305
305
305
502
502
502
TYPE
Transformer
Transformer
Transformer
Transformer
Transformer
Transformer
Transformer
Transformer
Transformer
Transformer
Transformer
Transformer
Transformer
Transformer
Transformer
Transformer
Transformer
Transformer
Capacitor
Capacitor
PCB Oil
PCB Oil
Regulator
Transformer
Transformer
Transformer
Transformer
-2-
-------
QUARTERLY INSPECTIONS
V •*
'
DATE TRANSFORMER HOUSE KVA
4/3/87
4/3/87
4/3/87
4/3/87
4/3/87
4/3/87
4/3/87
1/13/87
1/13/87
1/13/87
1/13/87
1/13/87
1/13/87
1/13/87
10/22/86
10/22/86
10/22/86
10/22/86
10/22/86
10/22/86
10/22/86
7/30/86
7/30/86
7/30/86
7/30/86
7/30/86
7/30/86
7/30/86
4/18/86
A/18/86
4/18/86
104
45
45
504
504
504
542
104
45
45
504
504
504
542
104
45
45
504
504
504
542
104
45
45
504
504
504
542
104
45
45
25
25
25
50
50
50
25
25
25
25
50
50
50
25
25
25
25
50
, 50
50
25
25
25
25
50
50
50
25
25
25
25
MFC
Westinghouse
Weaver
Weaver
GE
GE
GE
Uptegraff
Westinghouse
Weaver
Weaver
GE
GE
GE
Uptegraff
Westinghouse
Weaver
Weaver
GE
GE
GE
Uptegraff
Westinghouse
Weaver
Weaver
GE
GE
GE
Uptegraff
Westinghouse
Weaver
Weaver
SER #
572292
16735
16737
• B395368
B395369
B395389
24008
572292
16735
16737
B395368
B395369
B395389
24008
572292
16735
16737
B395368
B395369
B395389
24008
572292
16735
16737
B395368
B395369
B395389
24008
572292
16735
16737
PCB TYPE OF DEFICI^
1072
907
777
640
627
1648
741
1072
907
777
640
627
1648
741
1072
907
777
640
627
1648
741
1072
907
777
640
627
1648
741
1072
907
777
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
-------
DATE TRANSFORMER HOUSE
KVA
MFC
SER
PCB TYPE OF DEI
A/18/86
4/18/86
4/18/86
4/18/86
1/23/86
1/23/86
1/23/86
1/23/86
1/23/86
1/23/86
1/23/86
10/28/85
10/28/85
10/28/85
10/28/85
10/28/85
10/28/85
7/23/85
7/23/85
7/23/85
7/23/85
7/23/85
7/23/85
4/17/85
4/17/85
4/17/85
4/17/85
4/17/85
4/17/85
1/29/85
1/29/85
1/29/85
1/29/85
504
504
504
542
104
45
45
504
504
504
542
104
45
45
504
504
504
104
45
45
504
504
504
104
45
45
504
504
504
104
45
45
504
50
50
50
75
25
25
25
50
50
50
25
25
25
25
50
50
50
25
25
25
50
'50
50
75
25
25
50
50
50
25
25
25
50
GE
GE
GE
Uptegraff
Westinghouse
Weaver
Weaver
GE
GE
GE
Uptegraff
Westinghouse
Weaver
Weaver
GE
GE
GE
Westinghouse
Weaver
Weaver
GE
GE
GE
Westinghouse
Weaver
Weaver
GE
GE
GE
Westinghouse
Weaver
Weaver
GE
B395368
B395369
B395389
24008
572292
16735
' 16737
B395368
B395369
B395389
24008
572292
16735
16737
B395368
B395369
B395389
572292
16735
16737
B395368
B395369
B395389
572292
16735
16737
B395368
B395369
B395389
572292
16735
16737
B395368
640
627
1648
741
1072
907
777
640
627
1648
741
1072
907
777
640
627
1648
1072
907
777
640
627
1648
1072
907
777
640
627
1648
1072
907
777
640
None
None
None
None
None
None
None
Slight Oil
tightened a
observing.
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
-2-
-------
QUARTERLY INSPECTIONS (Cont'd)
DATE
1/29/85
1/29/85
10/31/84
10/31/84
10/31/84
10/31/84
10/31/84
10/31/84
8/7/84
8/7/84
8/7/84
8/7/84
8/7/84
8/7/84
8/7/84
8/7/84
8/7/84
4/3/84
4/3/84
4/3/84
4/3/84
4/3/84
4/3/84
4/3/84
4/3/84
4/3/84
1/30/84
1/30/84
1/30/84
12/2/83
12/2/83
12/2/83
TRANSFORMER HOUSE
504
504
104
45
45
504
504
504
542
104
45
45
Pole, O.T.
Pole, Tower #8
504
504
504
542
104
45
45
Pole, O.T.
Pole, Tower #8
504
504
504
542
321
113
542
321
113
KVA
50
50
25
25
25
50
50
50
25
25
25
25
50
50
50
25
25
25
25
50
50
50
MFC
GE
GE
Westinghouse
Weaver
Weaver
GE
GE
GE
Uptegraff
Westinghouse
Weaver
Weaver
GE
GE
GE
GE
GE
Uptegraff
Westinghouse
Weaver
Weaver
GE
GE
GE
GE
GE
SER 0
B395369
B395389
572292
16735
'16737
• B395368
B395369
B395389
24008
572292
16735
16737
7661357
6850602
B395368
B395369
B395389
24008
572292
16735
16737
7661357
6850602
B395368
B345369
B395389
PCB
627
1648
1072
907
111
640
627
1648
741
1072
907
111
640
627
1648
741
1072
907
111
640
627
1648
TYPE OF DEFICIENT
None
None
None
None
None
None
None
None
Removed Gauge &
Plugged
None
None
None
Changed Transformer
Changed Transformer
None
None
None
Seep in gauge
None
None
None
None
None
None
None
None
Seep in gauge
Seep in Oil Switch
Seep in Oil Switch
Seep in Gauge
Seep in Oil Switch
Seep in Oil Switch
-3-
-------
QUARTERLY INSPECTIONS (Cont'd)
DATE TRANSFORMER HOUSE KVA MFG
8/1/83
8/1/83
8/1/83
A/6/83
4/6/83
A/6/83
1/27/83
1/27/83
1/27/83
10/27/82
10/27/82
10/27/82
10/27/82
10/27/82
7/26/82
7/26/82
7/26/82
A/13/82
A/13/82
A/13/82
542
321
113
542
321
113
542
321
113
542
321
113
Tower #666 on Jinestown Rd.
500 Center
542
321
113
542
301
113
SER if PCB TYPE OF DEF
Seep in Gau;
Seep in Oil
Seep in Oil
1
Seep in Gaug
Seep in Oil
Seep in Oil
Seep in Gauj
Seep in Oil
Seep in Oil
Seep in Gaug
Seep in Oil
Seep in Oil
No oil in Tr
Hole in Tran
was replaced
Seep in Gaug
Seep in Oil
Seep in Oil
Seep in Gaug
Seep in Oil
Seep in Oil
1/26/82
All transformers were checked and no leaks were found.
-A-'
-------
1986 INVENTORY
Transformer House/
Station/Pole if
38
45
46
' 47
y
49
101
's-102
/104
^107
113
X
129
Location
West Side Bldg #100
Family Housing
Family Housing, East
Family Housing, West
Family Housing, East
Family Housing, West
Meridian Street by
Heating Plant
Station Lines
Between Bldg #106
& Bldg #108
South Side of Bldg 105
Northwest of Bldg #115
On Meridian Street
Artillery & Niblo
Road
Type
Ser *
KVA
PCB
Westinghouse
Westinghouse
Westinghouse
Weaver
Weaver
Weaver
Weaver
Weaver
Weaver
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
G.E.
Westinghouse
Kuhlman
Kuhlman
Kuhlman
Uptegraff
Westinghouse
Westinghouse
Westinghouse
Uptegraff
Uptegraff
Uptegraff
G.E.
G.E.
G.E.
Uptegraff
Uptegraff
Uptegraff
6725916
6775913
6775915
16736
16735
10737
16748
16752
16746
20861
20858
20859
20844
20849
20851
9284791
3005482
4676071002
4626071001
4626071003
20835
68AD2494
572292
68AC8453
20802
20803
20801
B703367
B769898
B703370
20830
20812
23718
100
100
100
25
25
25
25
25
25
10
10
10
15
15
15
25
25
25
25
25
15
25
25
25
50
50
50
25
25
25
25
25
25
92
96
131
178
907
777
200
ND
ND
ND
ND
ND
ND
ND
ND
128
58
ND
ND
ND
ND
*
1072
ND
6
6
ND
399
252
385
ND
81
33
J 133
Water Tower
Uptegraff
21087
ND
-------
Transformer House/
Station/Pole #
/127
139
1A3
162
179
203
206
210
213
214
217
218
228
229
Dry Type
Location
Be'tween Main Front Road
& Woodfill Road, West
of Artillery road
Paper Mill & Infantry
Road
North of Bldg 0100
Meridian Street
North of Bldg #144
Sewage Disposal Plant
Main Front Road, West
of Meridian Street
Bldg #212 & #241,
Woodfill Road
Mainfront Road at
K Position
Bldg #231, West of
Woodfill Road
K & L Positions North
of Woodfill Road
Bldg #215 & #219
Woodfill Road
Bldg #295 West of
Paper Mill
Main Front Road, East
of Wonju Road
West End of Bldg #227
Ser #
KVA
fc fc
Westinghouse
Westinghouse
Westinghouse
Uptegraff
Uptegraff
Uptegraff
Westinghouse
Westinghouse
Westinghouse
Uptegraff
Westinghouse
Westinghouse
Pad Mount
Square D
Uptegraff
Uptegraff
Uptegraff
Central Lrous
Central Lrous
Central Lrous
71AJ8912
71AJ8913
71AJ8914
21083
21088
22266
6400491
6402836
6402844
20827
6448408
6446314
50
50
50
5
5
5
50
50
50
25
25
25
S80D690N 30
3349-17212-024 30
20829
20807
20825
184834
184835
184837
G.E. L14308Y73AA
G.E. L138261Y73AA
G.E. L138266Y73AA
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Central Lrous
Central Lrous
Central Lrous
RTE
RTE
RTE
Weaver
Weaver
Weaver
20804
20813
20805
20819
20814
20822
184832
184836
184838
821079443
821083179
821083180
16729
16731
16738
Weaver 16753
G.E. L395795Y74AA
G.E. L396798Y74AA
25
25
25
37.5
37.5
37.5
25
25
25
25
25
25
25
25
25
37.5
37.5
37.5
25
25
25
37.5
37.5
37.5
325
325
325
-------
Transformer House/
Station/Pole t
233
264
267
280
287
287A
295X
297E
309
312
321
329
481
504
Location
Between Main Front Road
& Woodfill Road, East
of Paper Mill Road
N Position Between
Woodfill & Stockade
Road
Bldg #295, West of
Paper Mill Road
South of G Position
& West of Paper Mill
Road
J Position, North of
Main Front Road
J Position
West of Paper Mill
Road Between Woodfill
& Stockade Road
D & E Positions, North
of Main Front Road
Between Ordnance Road
& Bomb Assembly Road
at Airport
i
B.O.Q. & Bldg 311 on
Ordnance Drive
Bldg 322 & M-320 on
Bomb Assembly Road
Bldg 331, South of
Woodfill Road
M Bldg
Bldg 534 North Side
Niblo Road
Type
Ser
KVA
PCB
Standard
Standard
Standard
Howard
Howard
Howard
Howard
Howard
Howard
G.E.
G.E.
G.E.
85201
85199
85200
34527-2083
34532-2083
34529-2083
34535-2083
34533-2083
34531-2083
B435371
B435358
B437026
Line Material 282587
Line Material 282508
Line Material 282496
Magnetic
Magnetic
Magnetic
G.E.
G.E.
G.E.
Howard
Howard
Howard
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
13595
13596
13597
B435371
B435358
B437026
34528-2083
345969-4383
34530-2083
20824
20815
20808
20823
20826
20820
21077
21079
21175
Westinghouse 6448402
Westinghouse 6446395
Westinghouse 6446341
75
75
75
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
5
5
5
25
25
25
78
74
4 7
*
*
*
*
*
*
317
312
96
ND
ND
38
*
*
*
317
312
96
*
*
*
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
17
13
Von Iron Elec 8443233
G.E.
G.E.
G.E.
B395368
B395369
B395389
15
50
50
50
640
627
1648
-------
Transformer House/
Station/Pole if
508
518
5A2
609
123
129
135 & 135-A
141
305
315
Location
East of Loading Plant
Road on Niblo Road
Igloo Area on Niblo
Road
0 Position, North of
Woodfill Road
F Position, North of
Main Front Road
Type
Ser 9
KVA
Bldg 333
Bldg 602
Main Front Road
Bldg 600
East of Wainright
£oad, North of Woodfill
Road
Access Road, North of
Woodfill Road
Gator Mine Position,
East of Shun Pike
Magazine 501, West
North of Woodfill Road
Gator Mine
Uptegraff 21063
Uptegraff 21064
Uptegraff 21065
Central Lrous 1848-4
G.E. E426471-62P
Maloney 672939
Uptegraff ~ 24008
Uptegraff 20832
Uptegraff 20845
Uptegraff 20841
Kuhlman 4626911003
Kuhlman 4626911007
Kuhlman 4626911001
McGraw-Edison 72ZN107013
McGraw-Edison 72ZN107009
McGraw-Edison 72ZN107005
Westinghouse 6025294
Westinghouse 6023566
Westinghouse 6025295
Allis Chalmers 211869
Allis Chalmers 211798
Allis Chalmeis 211769
7.5
7.5
7.5
10
25
25
25
15
15
15
25
25
25
15
15
15
15
15
15
310
310
310
Westinghouse 6034320 50
Westinghouse 6034259 50
Westinghouse 6034300 50
G.E. J105343Y69A
G.E. J108247Y69A
G.E. J108248Y69A
Westinghouse 6034298
Westinghouse 6034301
Westinghouse 6034302
Howard 73973-4383
Howard 73974-4383
Howard 73972-4383
RTE 761122359
RTE 781122361
RTE 781122364
50
50
50
50
50
50
25
25
25
15
15
15
Westinghouse 6034301 10
Westinghouse 6034294 10
Westinghouse 6034287 10
-------
Transformer House/
Station/Pole ?
Pole at 500 Center
Single Pole #1
18
68
71
84
128
137
138
139
149
225
262
306
322
500
516
513
550
554
556
Location
Magazine 612
Bldg 457, North of
Mine Field Road
500 Center
Gate 22
Shu Pike, South of
Ordnance Drive
Krueger Lake
Krueger Lake
Main Gate
Bldg 602 & 603
Bldg 600, North
Bldg 605, East
Bldg 605, East
West Perimeter &
Main Front Road
D Road, East of
West Perimeter
F Road, North,
Tower 670
Hydes Pond
Bldg 194
Jinestown Road
Jinestown Road
Jinestown Road
Jinestown Road
Jinestown Road
Jinestown Road
Type
Ser I
KVA
PCB
Westinghouse 6034331
Westinghouse 6034294
Westinghouse 6034287
Howard 29392-1584
Howard 29390-1584
Howard 73971-4383
Howard Elec 34534-2083
Howard Elec 73970-4383
Howard Elec 86164-4983
Howard 71151-4183
Maloney 701223
Westinghouse 59B11892
G.E. J138773Y69A
G.E. E81649861R
Uptegraff 2107r
Uptegraff 21067
G.E. 10909
G.E. 6571967
Maloney 710224
Westinghouse 3043017
G.E. 6482607
Uptegraff 21075
Line Material 271608
G.E. 6041205
G.E. 6057303
G.E. 6057304
50
50
50
25
25
25
325
325
325
10
3
25
15
25
5
7.5
10
37.5
3
5
10
5
15
5
10
10
12
nD
20
*
*
*
*
*
*
*
26
18
*
11
17
9
*
*
ND
*
*
ND
28
*
*
ND
ND
Westinghouse 6448404 10 ND
RTE 821094729 10 *
Westinghouse 6057300 5 30
-------
Ration/Pole #
561
102A
Location
Jinestown Road
Main Substation
Type Ser 9 KVA
Westinghouse 6055934 5
Balteau PNL0779 667
Balteau PNL0780 667
Balteau PNL0770 667
Westinghouse 85A240659 333
Westinghouse 85A240658 333
Westinghouse 85A262022 333
Jinestown Road
West of Gate 03
C Road on East
Perimeter
Old Timbers Drive
Bldg 488, South of K
Road
K Road, East of Shape
Charge Road
K Road at 21,000
Center
H Road
Shape Charge Road
I Road at First
Mortar Position
Gate 9
K Road & Old Timbers
Drive
Old Timbers Drive
F Road, North, Tower 668
Bldg 771, at Shun Pike
Road
K Road
K Road
K Road, North of Drop
Tower
K Road
Emergency Land Field
Road
G.E.
G.E.
"6057301
G.E.
G.E.
Kuhlman
9347593
6693246
5
J138772Y69A 10
10
C27398 37.5
Kuhlman 825700 5
Kuhlman 944281 10
Allis Chalmers 1664265 5
Allis Chalmers 2572532 5
Allis Chalmers 1664260 3
Allis Chalmers 2572490 5
Maloney 701225 3
Weaver 16747 25
Westinghouse 6500923 10
Westinghouse 2718789 10
Westinghouse 2727435 10
Westinghouse 2808326 5
Uptegraff 20854 15
-------
Station/Pole 9 Location
North West Exit Road
Machine Gun Road at Old
Timbers Lodge
Old Timbers Lodge
Old Timbers Lake Dam
K Road
I Road at Second Mortar
Position
Gate 8 Pond
Bldg 474
K Road, South of Tower
480
K Road
K Road
Dry Type Bldg 1A8
Platform Bank at Bldg 711
Pad Mount .. Bldg 534 Complex
Transformers
Type
Uptegraff
Uptegraf f
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
G.E.
Westinghouse
Westinghouse
Westinghouse
Maloney
Maloney
Maloney
Ser f
20838
20865
20864
20860
20839
21081
20862
20836
20857
20837
20855
95G336
82A490347
82A490348
82A490346
705959
705966
705965
KVA
15
10
10
10
15
5
10
15
10
15
10
10
167
167
167
50
50
50
PCS
ND
ND
ND
ND
ND
ND
ND
*
ND
ND
*
*
*
*
*
ND
ND
ND
-------
I/
• MAKE
_. Westinghouse
Wescinghouse
Wescinghouse
Weaver Elec.
•> f Weaver Elec.
' - Jf Weaver Elec.
Vf>
&
O7 * Weaver Elec.
\ \ Weaver ELec.
0* Weaver Elec.
UpCegraff
UpCegraff
UpCegraff
UpCegraff
UpCegraff
UpCegraff
Wescinghouse
General ElecCric
Wescinghouse
Kuh Iman
Kuh Iman
Kuh Iman
UpCegraff
BalCeau Scandard
BalCeau Scandard
BalCeau Scandard
Eestinghouse
WesCinghous e
WesCinghouse
Wescinghouse
Wescinghouse
WesCinghoase
UpCegraff
UpCegraff
UpCegraff
Wescinghouse
Wescinghouse
Wescinghouse
UpCegraff
UpCegraff
UpCegraff
UpCegraff
General Elec.
General Elec.
/-,_-_- 1 r- -I .
KVA
100
190
100
25
25
25
25
25
25
10
10
10
15
15
15
25
25
25
25
25
25
15
667
667
667
333
333
333
25
25
25
50
50
50
75
75
75
25
25
25
5
15
15
1987 INVENTORY
CYC L6CATION
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
69
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
B-100
B-100
100
TH 45
TH 45
TH 45
TH 46
TH46
TH46
B-47
B-47
B-47
B-48
B-48
B-48
Fae. 49
Fac. 49
Fac. 49
B-101
B-101
B-101
B-102
B-102A
B-102A
B-102A
B-102
B-102
B-102
- B-104
B-104
B-104
B-107
B-107
B-107
B-113
B-113
B-113
B-129
B-129
B-129
B-133
B-136
B-136
SERIAL # CAPACITY
6723916
6725913
6725915
16737
16736
16735
16748
16752
16746
20861
20858
20859
20844
20849
20851
3005441
9284791
3005482
4626071003
4626071002
4626071001
20835
PNL-0779
PNL-0780
6800261
85A262022
85A240659
85A240658
68AD2494
572292
68AC8453
20802
20803
20801
--- 71AFL2034
... -71AF10199
- 71AD5031.-
20812J
20830
23718
21087
B589035
8589037
Tl C Q A A 1 0
52
52
52
17
17
17
17
17
17
8
8
8
12
12
12
17
17
17
(6
16
16
12
17
17
17
27
27
27
43
43-.
4.3
16
16
\c
5
12
12
. x^
-------
Wescinghouse
Westinghouse
Westinghouse
Uptegraff
Uptegraff
Uptegraff
Wescinghouse
Westinghouse
Wescinghouse
General Elec.
Westinghouse
Uptegraff
Westinghouse
PAD Mount
Square "D"
General Elec.
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
CenteraJ. Lrous
Centeral Lrous
Centeral Lrous
General Elec.
General Elec.
General Elec.
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
General Elec..
General Elec.
General Elec.
Centeral Lrous
CenteralLrous
Centeral Lrous
RTE
RTE
RTE
Heaver
.Weaver
weaver
50
50
50
5
5
5
50
50
50
10
60
60
60
60
60
60
60
60
60
60
25
25
25
112.5
30
25
25
25
25
25
25
37.5
37.5
37.5
25
25
25
25
25
25
25
25
25
37.5
37.5
37.5
37.5
37.5
37.5
25
25
25
m
37.5
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
B-137
B-137
B-137
g-139
B-139
B-139
TH 143
TH 143
TH 143
B-148
B-162
B-162
B-162
Sewage Plant
Sewage Plant
B-186
B-186
B-186
B-203
B-203
B-203
B-206
B-206
B-206
B-210
B-210
B-210
B-213
B-213
B-213
B-214
B-214
B-214
B-215(instde)
B-215(inside)
B-215(inside)
B-217
B-217
B-217
B-218
B-218
B-218
B-228
B-228
B-228
71AJ8912 SO
7LAJ8918 SO
7LAJ8914 5J_
21083 5
21088 c
22266 5
6400491 Zo
6402836 24
6402844 Zt
95G336
6446314 17
20827 PKY ^r*3
6448408 17
S800690N
3349-171212-024
6880858
20806
20817
20829
20807
20825
184834
184835
184837
17
\6
\6
16
16
16
43
43
43
L138261Y73AA 1 5
L140308Y73AA 15
L138266Y72AA (5
20804
20813
20805
20819
20814
20822
B703367
B769898
B703370
184832
184836
1S4838
•
821083179
'821079443
821083180
16729
16731
16738
16
16
16
16
16
43
43
26
26
-------
General Elec.
Weaver
Standard
Standard
Standard
Weatinghouse
Westinghouse
WesCinghouse
Howard
Howard
Howard
Hovard
Howard
Howard
General Elec,
General Elec.
General Elec.
Line Material
LineMacerial
Line Material
Howard
Howard
Howard
Magnetic
Magnetic
Magnetic
General Elec.
General Elec.
General Elec.
Uptegraff
Westinghouse
t
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Uptegraff
Westinghouse
Westinghouse
Westinghouse
i._*
25
23
75
75
75
50
50 HE
50
25
25
25
25
25
25
•25
25
25
25
25
25
25
25
25
25
25
25
25
25
25
ou
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
10
25
25
25
25
25
25
25
5
5
5
25
25
25
60
60
60
60
60
60
60
60
60
60
60
60
60
60
B-229
B-229
B-133
B-233
B-233
B-236
B-236
B-236
B-264
B-264
B-264
B-267
B-267
B-267
B-280
B-280
B-280
B-287
B-287
B-287
B pos
D pos
D pos
J pos
J pos
J pos
TH 295X
TH 295X
TH 295X
B-302
B-305
B-309
B-399
B-309
B-312
B-312
B-312
B-321
B-321
B-321
B-329
B-329
B-329
/<+/\
L396798Y74A
16753
85201
85199
85200
71AJ8912
71AJ89UJ
7LAJ8914
34529-2083
34532-2083
34527-2983
34535-2083
34533-2083
34531.-2083
B435371
B435358
B437026
282587
282508
282496
34530-2083
34528-2083
73969-4383
HE13595
HE13596
HE13597
B435371 .
B435485
B437026 A
17111KK
6448404
20824
20824
20808
20826
j 20823
,20820
•\ 21077
21079 "
21175
i
6448402
6446395
6446341
-------
McGraw- Edison
McGraw-Edison
McGraw- Edison
VanTran Else.
General Elec.
Howard
Howard
Howard
RTE
RTE
RTE
General Elec.
General glee.
General Elec,.
Uptegraff
Uptegraff
Uptegraff
Centeral Lrous
Holoney
Moloney
Moloney
General Elec.
Uptegraff
Molonejr
Westinghouse
Westinghouse
Westinghouse
Uptegraff
Westinghouse
Westinghouse
Westinghouse
Allis Chambers
Allis Chambers
Allis Chambers
General Elec.
Kuhlman
Uptegraff
Uptegraff
Uptegraff
Kuhlraan
Kuhlman
Kuhlman
Magnetic
ttfRIEfc
15
15
15
15
5
25
25
25
15
15
15
50
50
50
7.5
7.5
7.5
10
50
50
50
25
25
25
50
50
50
7.5
15
15
15
10
10
10
37.5
10
15
15
15
25
25
25
25
25
25
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
B-333
B-333
B-333
B-481
B-488
500 Cen.
500 cen.
500 cen.
B-501
B-501
B-501
B-504
B-504
B-504
B-508
B-508
B-508
B-518
B-534
B-534
B-534
B-542
B-542
B-542
B-600
B-600
B-600
72ZNL07013 (2
72ZN107009 12
72ZN107005 12
84V3233
9347593 ^
86164-4983
34534-2083
73930-4383
781122361
781122360
781122359
B395368 26
B395369 26
B395389 26
21063 Q.5
21064 35
21065 85
1848-4 16
705959 26
705966 2.6
705965 26
E-426471-62P 15
24008 20
672939 17
6034300 2 6
6034259 26
6034320 26
600Tower
B-602
B-602
B-602
M-603
M-603
M-603
B-605
B-605
B-609
B-609
B-699
B-609
B-609
B-609
B-609
B-609
B-609
21067
3-5
6025294 12.
6023566 12
6025295 12
211869
211798
211769
6571967
944280
8
8
8
26
20841
20845
20832
4626911-003
4626911-002
4626911-001
HG06201
HG06199
HG06200
(6
\6
16
-------
MAKE
Westinghouse
Westinghouse
Wescinghouse
Wescinghouse
Westinghouse
WesCtnghouse
General Elec,
General Elec.
General Elec.
Wescinghouse
Kuhlman
General Elec.
General Elec.
UpCegraff
Moloney
Allis Chambers
Wescinghouse
Wescinghouse
Wescinghouse
Howard
Howard
Howard
Allis Chambers
Wescinghouse
Allis Chambers
UpCegraff
UpCegraff
UpCegraff
General Elec.
UpCegraff
Line Macerial
Moloney
General Elec.
Wescinghouse
Wescinghouse
UpCegraff
UpCegraff
General E ec.
UpCegraff
Uptegraf f
KVA
50
50
50
50
50
50
50
50
50
3
37.5
25
10
10
3
5
10
10
10
25
25
25
3
10
5
10
10
15
10
15
15
3
15
25
5
15
15
10
5
15
CTC
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
LOCATION
B-612
B-612
B-612
B-617
B-617
B-617
"A"
"A"
"A"
B-700
21,000 west
Gate 1
Gate 3
Gate 8
Gate 19
Gate 9
Gator Mine
Gator Mine
GAtor Mine
llyH
i«Y«
tryit
Old Tim.
Old Tim.
Old Tim,
Old Tim/
Old Tim.
Old Tim. Hill
Old Tim. Drive
VZ"
Truck Inspec.
Shun Pike
K. Lake
K. Lake
W. Signal
W. Signal
W. Signal
W. Signal
Hyde Pond
N.W. Exit
SERIAL i? C.A
6034287 2\
6034294 2L
6034331 2\
6034302 Z,
6034298 2,
6034301 2j
J105343Y69A
J108247Y69A
J108248Y69A
6453127
C27398
E816498-61R
J138772Y69A
20862
701224
2572532
6034301 3
6034294 rt
6034287
73974-4383
73972-4383
73973-4383
1664260
6482323
2572490
20860
20865
20836
7661357
20840
271608
701223
J138i773Y69A
59B1J1892
- 1 -
I
2808326
20839
20837
6693246
21075
20838
-------
MAKE
KVA
CYC
LOCATION
SERIAL it
Westinghouse
Standard
Uptegraff
Uptegraff
Westinghouse
Uptegraff
Uptegraff
Kuhlman
Uptegraff
Magnetic Trans.
General Elec.
General Elec.
Moloney
Allis Chambers
Westinghouse
Kuhlman
Uptegraff
Westinghouse
RTE
Uptegraff
General Elec.
Westinghouse
Westinghouse
General Elec.
Uptegraff
Westinghouse
Uptegraff
Weaver
Westinghouse
Westinghouse
Westinghouse
H.K. Porter •
Magnetic
Magnetic
Magnetic
Magnetic
Westinghouse
Uptegraff
General Elec.
Westinghouse
General Elec.
Allis Chambers
10
10
.15
10
10
15
15
10
10
10
10
-10
3
5
5
5
5
25
10
5
5
5
5
10
10
10
5
25
' 167
167
167
10
10
10
10
10
10
5
10
5
10
5
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
f.r\
B Rd. B-Hive
K Rd. B-Hive
K Rd.
K Rd.
Drop Tower
E. Pt.Camp
Emer. Landing
Shape Charge
480 Tower
C Rd. & Jines
Jines
Jines
Jines
Jines
Jines
Jines
Jines
Jines
Jines
Jines
Jines
Jines
J
-------
MAKE
KVA
CYC
LOCATION
SERIAL
Howard
Line Material
tfestingaouse
Kihlman
Line Material
RTE
Westinghouse
Westinghouse
Westinghouse
Kuhlman
Line Material
Line Material
Line Material
Line Material
Line Material
Moloney
Moloney
Weaver
Weaver
Weaver
Weaver
Weaver
Weaver
General Elec.
Maloney
Maloney
Maloney
10 60
15 60
STORAG E ( TRANS FORMERS )
50
37.5
15
5
50
50
• 50
37.5
10
10
75
75
75
200
200
50
50
50
37.5
37,5
37.5
DRY TYPE
10 60
• BAD MOUNT1 TRANSFORMER'
50
50
50
Gate 22
B-194
B-314
B-314
B-305
B-502
B-502
B-502
B-502
B-502
B-502
B-502
B-502
B-502
B-502
B-108A
B-108A
B-108A
B-108A
B-108A
B-108A
B-108A
B-108A
B-148
B-534
B-534
B-534
B-534
71151-4183
271608
59B11669
C27405
2711612
841144452
6034255
6034323
6034271
C27410
280152
280156
1610727
1610715
1655428
706600
706596
16734
16733
16732
16740
16730
16739
95G336
Complex
705959
705966
705965
-------
APPENDIX I
PCB QUARTERLY INSPECTION REPORT
-------
Appendix I
DISPOSITION FORM
for UM o< ttiit form, M* AR 34O-1S: tti« proponent
it TAGO.
IEFERENCE OR OFFICE SYMBOL
STEJP-EH-B (420-81c)
SUBJECT
Quarterly Inspection of Transformers
//THRU
TO:
V-^>V^R0^
C, Bldgs,Gnds /& Utils C, Bldgs. Br,
Dir, Engineering and
Environmental Engineer
DATE
10 April 1989
CMT 1
All transformers on post have been visually inspected in the past quarter.
There were no deficiencies found in transformers containing above 500 PPM
of PCBs. Transformers were inspected by Tyrus Bayne on 10 April 1989.
Transformer House No. KVA
MFG.
Container PPM Type of Deficiency
104
45
45
504
504
504
542
25
25
25
50
50
50
25
Westinghouse
Weaver
Weaver
GE
GE
GE
Uptegraff
572292
16735
16737
B395368
B395369
B395389
24008
1072
907
177
640
627
1648
741
None
None
None
None
None
None
None
CAPACITORS
102 Substation - OK, no leaks.
CLEO E. ROSEBEI _
C, Buildings Branch
^^
EBERg?
AUG SO
PREVIOUS EDITIONS WILL BE USED
-------
DISPOSITION FORM
For UM of ttiit form, M* AR 34O-16: th« proponent
it TAGO.
REFERENCE OR OFFICE SYMBOL
STEJP-EH-B (420-Slc)
SUBJECT
Quarterly Inspection of Transformers
TO
//THRU:
TO:
FROM
C, Bldgs,Gnds & Utils C, Bldgs. Br.
Dir, Engineering and HousingT^l
Environmental Engineer
DATE
17 October 1988
CM!
All transformers on post have been visually inspected in the past quartet
There were no deficiencies found in transformers containing above 500 ppi;
of PCBs. Transformers were inspected by Tyrus Bayne on 17 October 1988. /
Transformer House No. KVA
MFG.
Container PPM Type of Deficiei-
104
45
45
504
504
504
542
25
25
25
50
50
50
25
Westinghouse 572292
Weaver 16735
Weaver 16737
GE B395368
GE B395369
GE B395389
Uptegraff 24008
None
None
None
None
None
None
None
CAPACITORS
102 Substation - OK, no leaks.
CLEO E. ROSEBERRY
C, Buildings Branch
MFORM
AUG 80
2496
PREVIOUS EDITIONS WILL BE USED
GPO : 1987
-------
DISPOSITION FORM
For UM of thu form, M« AR 34O-15. th« proponent i^ncy n TAGO
REFERENCE OR OFFICE SYMBOL
STEJP-EH-B (420-Slc)
SUBJECT
Quarterly
^**>?77
Inspection of Transformers
TO
//THRU:
TO:
C, Bldgs,Gnds & UtllsK/C, Bldgs. Br.
Dir, Engineering and Housingrtr
Environmental Engineer
DATE
21 July 1988
CMT 1
All transformers on post have been visually inspected in the past quarter.
There were no deficiencies found in transformers containing above 500 PPM
of PCBs. Transformers were inspected by Tyrus Bayne on 20 July 1988.
Transformer House No. KVA
MFG.
Container PPM Type of Deficiency
104
45
45
504
504
504
542
25
25
25
50
50
50
25
Westinghouse 572292 1072
Weaver 16735 907
Weaver 16737 777
GE B395368 640
GE B395369 627
GE B395389 1648
Uptegraff 24008 741
None
None
None
None
None
None
None
CAPACITORS
102 Substation - OK, no leaks.
Q
CLEO E. ROSEBERRY
C, Buildings Branch
K
FORM
AUG SO
2496
PREVIOUS EDITIONS WILL BE USED
GPO
1987
-------
DISPOSITION FORM
UM at ttirt t
-------
DISPOSITION FORM
fv uw of ttm form. «M AR 34O 15. ih. orooon^ru .g.ocv n TAGO
REFERENCE OR OFFICE SYMBOL
STEJP-EH-B (420-81c)
SUBJECT
Quarterly Inspection of Transformers
TO
C, Bldgs, Gnds & Utils ' ™2* c > Buildings Br
Dir, Engineering & Housing
Environmental Engineer
OATE 15 Jan 88
CMT 1
All transformers on post have been visually inspected in the past quarter. There were no
deficiencies found in transformers containing above 500 PPM of PCBs. Transformers were
inspected by Tyrus Bayne on 14 January 1988.
Transformer House No.
104
45
45
504
504
504
542
KVA
25
25
25
50
50
50
25
MFG.
Westinghouse
Weaver
Weaver
GE
GE
GE
Uptegraf f
Container
572292
16735
16737
B395368
B395369
B395389
24008
PPM
1072
907
777
640
627
1648
741
Type of Deficiency
None
None
None
None
None
None
None
CAPACITORS
102 Substation - OK, no leaks.
-,
RRV^
CLEO E. ROSEBERR
C, Buildings Branch
DA
2496
PREVIOUS EDITIONS WILL BE USED
GPO 1087 0
-------
DISPOSITION FORM
For UM at ttMt form. «•• AR 340-15 tti« proponent agency n TAGO.
REFERENCE OR OFFICE SYMBOL
STEJP-EH-B (420-81c)
SUBJECT
Quarterly Inspection of Transformers
THRU
TO
Dir , Engineering & Housing"
Environmental Engineer
C, Buildings Br
DATE
20 Oct 87
cv
All transformers on post have been visually inspected in the past quarter. There were r
deficiencies found in transformers containing above 500 PPM of PCBs. Transformers were
inspected by Tyrus Bayne on 20 October 1987.
Transformer House No. KVA
104 25
45 25
45 25
504 50
504 50
504 50
542 25
102 Substation - OK, no leaks.
MFG.
Westinghouse
Weaver
Weaver
GE
GE
GE
Uptegraff
Container
572292
16735
16737
B395368
B395369
B395389
24008
PPM
1072
907
777
640
627
1648
741
CAPACITORS
CLEO E. ROSEBERR-i
C, Buildings Branch
Type of Deficie
None
None
None
None
None
None
None
1AQC
FniTinw* wu i
-------
DISPOSITION FORM
For \n» o1 t«>i form, «*• AR 34O-15: iti« orooon«nt «q»fiey ii TAGO.
REFERENCE OR OFFICE SYMBOL
STEJP-EH-B
f Buildings Branch
DATE
Dir, Engr &
TO Environmental Engineer
14 July 87
CMT
1^3
1. Bldg. 102 contains 2 ea. 180 KVAR Capacitor Banks, consisting of 24 single Pyranol
Capacitor Units, General Electric Cat. #13F122, each rated 15 KVAR, 2400 volts, single
phase, 60 cycles, having internal discharge resistor. Prints dated 8/14/50. Each
capacitor contains 1.4 gal. liquid.
2. We have 3 ea. 100 KVAR Capacitors mounted on the outside of Bldg. 102. These capacitors
are General Electric, Non-PCB filled. Ea. Capacitor contains 1.8 Gal. liquid.
3. These units are checked and documented quarterly.
CLEO E. ROSEBERR'C
C, Buildings Branch
-------
^POSITION FORM
For uw of ttti* farm. tf» AR 34O-1S. tti« proponent a^ncy •» TAGO.
OR OFFICE SYMBOL
S.^JP-EH-B
SUBJECT
Quarterly Inspection of Transformers
THRU: rv
f TT4"i
.Dii-f Dng
H
Foranan, Buildings Br
DATE
22 Oc± 86
TO:
Environmental Engineer
All transformers on post have been visually inspected in the past quarter. There were
deficiencies found in transformers containing above 500 PPM of PCBs. Transformers were
inspected by Phillip Morris on 22 October 1986.
Transformer House No
104
45
45
504
504
504
542
MFG.
Westinghouse
Weaver
Weaver
GE
GE
GE
Uptegraff
572292
16735
16737
B395368
B395369
B395389
24008^2
Type of Deficienc
None
None
None
None
None
None
None
G
.._,&-
CLEO E.
Forsnan, Buildings Branch
HA FORM
PREVIOUS EDITIONS
* USGPC 1M6-
-------
DISPOSITION FORM
for «•• a« tr)l« form. «•• AR 34O-1B: »• pfooooant «^ncy x TAGO
REFERENCE OR OFFICE SYMBOL
UP-EH-B
SUBJECT
Quarterly Inspection of Transformers
^ THRU: C, Bldgs, Gnds & Utils
Dir, Engr & Housing
TO: Environmental Engineer
FROM
Foreman, Buildings Br
OAT6
22 Oct 86
CMT 1
All transformers on post have been visually inspected in the past quarter. There "were no
deficiencies found in transformers containing above 500 PPM of PCBs. Transformers were
inspected by Phillip Morris on 22 October 1986.
Transformer House No
104
45
45
504
504
504
542
MFG.
Westinghouse
Weaver
Weaver
GE
GE
GE
Uptegraff
572292
16735
16737
B395368
B395369
B395389
Type of Deficiencies
None
None
None
None
None
None
None
E. FDSEBERRY
Foreman, Buildings Branch
I
FORM 14 OC
PREVIOUS EDITIONS WILL BE USED
-------
DISPOSITION FORM
For ISM at tfiit form. M* A Ft HO- IS: ttt« orooon«m agtncy 1* TAGO.
REFERENCE OH OFFICE SYMBOL
STEJP-EH-
SUBJECT
Quarterly Inspection of Transformers
T/ty THRU: -Piri nf Png-in^Hng -infl*ifljV- Frmn, Bldgs. Br OATi 30 July 86
C, Bldgs, Gnds, and Util £>**-
TO: Environmental Engineer u>\^
All transformers on post have been visually inspected in the past quarter. There were no
deficiencies found in transformers containing above 500 PPM of PCBs. Transformers
were inspected by Gary Kinman & John 3nith. on 29 & 30 July 1986.
Transformer House No. MFG. Container Type of Deficiencj
104 Westinghouse 572292 None
45 Weaver 16735 None
45 Weaver 16737 None
504 GE B395368 None
504 GE B395369 None
504 GE B395389 None
542 Uptegraff 24008 None
CLEO E. PDSEBERPY
Foreman, Buildings Branch
- 'I0!
DA #
-------
DISPOSITION FORM
For in* of thi» form, «•• AR 34O-16. th« proponent
it TAGO.
REFERENCE OR OFFICE SYMBOL
SUBJECT
Quarterly Inspection of Transformers
T? THRU:
TO:
FROM Frran, Maint & Repair
18 Apr 86
CMT 1
Envirormental Engineer
1. All transformers on post have been visually inspected in the past quarter. There
were no deficiencies found in transformers containing above 500 PPM of PCBs. Transformers
were inspected by William Mauk on 4/17/86.
Transformer House No.
104
45
45
504
504
504
542
Mfg.
Vtestinghouse
Weaver
Weaver
GE
GE
GE
Uptegraff
Container
572292
16735
16737
B395368
B395369
B395389
24008
Type of Deficiencies
None
None
None
None
None
None
None
CLEO E.
Foreman, Maint & Repair Section
1A FORM
IK AUG 80
2496
PREVIOUS EDITIONS WILL BE USED
GPO I 1984 0 - 455-151
-------
DISPOSITION FORM
O< m>l form. «*• AR 34O-13; th« 0rooon«nt a^ncy It TAGO.
For
REFERENCE OR OFFICE SYMBOL
STEJP-EH-B (420-81c)
,1T
SUBJECT
Quarterly Inspection of Transformers
pi rlg
Dir, Engineering & Housing
TO Environmental Engineer
Buildings Branch
DATE
9 July 1987
All transformers on post have been visually inspected in the past quarter. There were
deficiencies found in transformers containing above 500 PPM of PCBs. Transformers were
inspected by Phillip Morris on 7 July 1987. '/
Transformer House No. KVA
104 25
45 25
45 25
504 50
504 50
504 50
542 25
MFG.
Westinghouse
Weaver
Weaver
GE
GE
GE
Uptegraff
Container
572292
16735
16737
B395368
B395369
B395389
24008
PPM Type of
1072
907
777
640
627"
1648
741
None
None
None
None
None
None
None
102 Substation - OK, no leaks.
Capacitors
CLEO E. ROSEBERRY
C, Buildings Branch
-------
DISPOSITION FORM
For UM of This form. ••• AR 34O-15; tt>« proponent K>r
-------
DISPOSITION FORM
•« rhu form. «•• AM J4O-1S; th« proeciwt *^ncv r» TAGO.
far
«tFr-BNCE On OFFICt SYMBOL
STEJP-EH-B
SUBJECT
Quarterly Inspection of Transformers
19 THRU: -Cr Bldgs, Grids
Dir,- Encjt
TO: Environmental Engineer
Is '•"*«>* Foranan, Buildings Br
OATI
7 January 1987
All transformers on post have been visually inspected in the past quarter. There were
deficiencies found in transformers containing above 500 PPM of PCBs. Transformers were
inspected by Phillip Morris on 7 January 1987.
Transformer House No. KVA MFG.
104
45
45
504
504
504
542
25 Westinghouse
25 Weaver
25 Weaver
50 GE
50 GE
50 GE
25 Uptegraff
Container
572292
16735
16737
B395368
B395369
B395389
24008
PPM
1072
907
777
640
627
1648
741
Type of Defic
None
None
None
None
None
None
None
CLEO E.
Foreman, Buildings Br.
DA
FORM
AUG 10
2496
PREVIOUS COITIONS WILL 81 U3BO
• U1O.PO.
-------
APPENDIX J
JPG RESTRICTED AREAS MAP
-------
OLD TIMBERS LAKE
HYOES
POND
Appendix J
N9w Morion
OLD TIMBERS LOOGE
GATE 8 POND
600S Lr£
-"* (No
I | Controlled Area
1 (General Hunting)
|| || || n Controlled Hunting An
PI! I !i!l (Small Game, Gameblr'
a D««r Hunting with c
bow only)
—~~ Paitable Roadt
----- Trails a Flrebrealu •
/ OO -Area Numb*-
>
*7 ( ) Hunters per Area
Tared Rang. MOTES
.AST
PSllMtTIR ' • to *h* •'•nt of an emergency
DIAL 13.
2.Hunting with a.2 2 caliber rifle
tooth of th« Firing Line b
PROHIBITED.
3. Area* 30 a 32 are CLOSED
to raccoon hinting.
4 Areae 55,56,59,50,82,33,59
70,71, and 72 are open only to
JPG employees, post rtjJderri
and their quettfj A/eoi 6s, 70,7i,
and 72 are opinto bow hunting
only .
5. All ptirjorthel will observe 'h
pealed spied Unit].
HUNTING & FISHING MAP
1988-89
JEFFERSON PRCVING GROUND
Madison, Indiana 47250
SUBMITTED
G.
a
Madlton
NO.
'27
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