UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT AND COMPLIANCE MONITORING
EPA -330/2-88-024
RCRA COMPLIANCE INVESTIGATION
CASMALIA RESOURCES, LTD.
Casmalia, California
February 1988
Sally Arnold
Jon Dion
Margo Dusenbury
Barbara Hughes
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Denver, Colorado
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CONTENTS
EXECUTIVE SUMMARY
INTRODUCTION 1
SUMMARY OF FINDINGS AND CONCLUSIONS 8
WASTE MANAGEMENT PRACTICES 8
Laboratory Procedures 8
Waste Acceptance Procedures 8
Waste Analysis Plan (WAP) Evaluation 9
Waste Management Units 11
INTERIM STATUS STANDARDS/DIRECTOR'S ORDER 12
Security 12
Facility Inspection Records 12
Manifest System/Operating Record 13
Biennial Report 14
LAND DISPOSAL RESTRICTIONS 14
PART B WASTE ANALYSIS PLAN 14
TECHNICAL REPORT
INVESTIGATION METHODS 15
FACILITY DESCRIPTION AND OPERATIONS 17
WASTE ACCEPTANCE PROCEDURES/
WASTE ANALYSIS PLAN 19
Waste Acceptance Procedures 19
Waste Analysis Plan 27
WASTE MANAGEMENT UNITS 31
Landfills 31
Surface Impoundments 37
Wet-Air-Oxidation 56
Neutralization System 61
pact Treatment Unit 61
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CONTENTS (cent.)
FINDINGS 65
WASTE MANAGEMENT PRACTICES..,. 65
Laboratory Procedures 65
Waste Acceptance Procedures.. 66
Waste Analysis Plan (WAP) Evaluation 72
Waste Management Units 76
INTERIM STATUS STANDARDS/DIRECTOR'S ORDER 80
Security 80
Facility Inspection Records 81
Manifest System/Operating Record 84
Biennial Report 88
LAND DISPOSAL RESTRICTIONS 88
PART B WASTE ANALYSIS PLAN 94
REFERENCES
APPENDICES
A STATE OF CALIFORNIA, DEPARTMENT OF HEALTH SERVICES ADMIN-
ISTRATIVE ORDER HWCA-84/85-006, SEPTEMBER 26, 1986
3 FACILITY PERMITS
C CASMALIA RESOURCES WASTE ANALYSIS PLAN, JANUARY 1983
D RCRA WASTE CODE DEFINITIONS
E CONSENT AGREEMENT AND FINAL ORDER (DOCKET NO. RCRA-09-
84-0026)
F OPERATING RECORD DATA SHEETS
G LAND DISPOSAL RESTRICTIONS (LDR) INSPECTION CHECKLIST
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CONTENTS (cont.)
FIGURES
1 Casmalia Resources, Facility Location Map 3
2 Casmalia Resources, Facility Plan 6
3 Surface Impoundment Systems at Casmalia Resources 45
4 Wet-Air-Oxidation Unit Site Plan 58
5 Wet-Air-Oxidation Unit Process Diagram 60
6 Schematic Diagram of PACT System ....64
TABLES
1 Summary of Waste Received 18
2 Waste Disposed in RCRA Landfills at Casmalia Resources 19
3 Casmalia Resources Analytical Laboratory Methods 24
4 The Limits on Liquid Waste Disposed in Surface Impoundments
at Casmalia Resources 28
5 Beginning Operation Dates of Casmalia Landfills 32.
6 Description of Casmalia Landfills and Wastes Received 33-
7 Description of Casmalia Surface Impoundments and Waste
Received 38
8 Categories of Surface impoundments (Ponds) at Casmalia
Resources 43
9 Surface Impoundments and Surface Impoundment Systems at
Casmalia Resources 44
10 Percent Aqueous Liquids Treated with Hydrogen Peroxide 54
11 Wastes Accepted for Treatment in the Wet-Air-Oxidation and
Neutralization System Treatment Units 57
1 2 Wet-Air-Oxidation Unit Equipment List 59
13 Maximum Concentration Limits for Waste Treated in the
Neutralization System 62
14 Bulk Liquid Waste Loads Accepted by Casmalia Resources from
Northrop Corporation (1983-1987) for Disposal in Surface
Impoundments 69
15 Waste Loads Accepted by Casmalia Resources for Treatment in the
Neutralization System 73
16 Sample of Manifests with Inadequately Characterized Waste
Streams.. 90
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EXECUTIVE SUMMARY
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INTRODUCTION
The National Enforcement Investigations Center (NEIC), at the request of
the Toxics and Waste Management Division, EPA Region IX, conducted an
investigation of the Casmalia Resources hazardous waste treatment, storage
and disposal facility near Casmalia, California. The objectives of the
investigation were to: (1) Evaluate hazardous waste management practices
including waste analysis, tracking, and disposition; (2) assess compliance with
those parts of the RCRA* Interim Status Standards regulations (40 CFR 265),
and the September 26, 1986 California Department of Health Services (DHS)
Director's Order [Appendix A] that apply to waste management; (3) assess
compliance with the November 8, 1986 solvent/dioxin land disposal ban (40
CFR 268); and (4) review the Casmalia Resources' revised Part B (40 CFR
264) waste analysis plan to determine if it is adequate for the facility.
To accomplish these objectives NEIC personnel;
Reviewed and evaluated relevant records and documents from
EPA Region IX files
Interviewed Region IX and California Department of Health
Services personnel familiar with the facility
Conducted a presurvey visit to the facility on April 24, 1987
Conducted an on-site investigation of Casmalia Resources
between May 19 and May 29,1987
The on-site investigation included: (1) A review of selected waste
identification, tracking and disposal records and facility inspection records;
(2) an evaluation of the on-site laboratory including methods for waste
characterization and acceptance; (3) an inspection of waste disposal and
treatment units; and (4) an evaluation of waste handling operations.
Resource Conservation and Recovery Act
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Casmalia Resources owns and operates a commercial hazardous waste
treatment, storage and disposal facility in an unincorporated area in the
northwest part of Santa Barbara County, California. The active facility covers
about 250 acres in the central portion of a 5,000-acre parcel of Company-
owned land, and is located about 10 miles southwest of the city of Santa Maria
and 2 miles north of the unincorporated community of Casmalia [Figure 1].
Casmalia Resources began operation in 1972 under the State of
California Regional Water Quality Control Board Waste Discharge
Requirements as a Class f site for oil field waste disposal. At that time the
facility had 15 surface impoundments and one landfill on a 61-acre site.
In 1976, the Waste Discharge Requirements were amended to allow for a
118 acre expansion of the facility to the east and north bringing the total site
acreage to 179. The facility was also issued a Conditional Use Permit (CUP) by
the Santa Barbara County Planning Commission in 1976.
In 1978, EPA issued the facility a Toxic Substances Control Act (TSCA)
Approval for a polychlorinated biphenyl compounds (PCBs) landfill. The PCB
landfill was later expanded under new EPA orders in 1979 and 1980. The
California Department of Health Services (DHS), acting under the authority of
the California Health and Safety Code, issued a State Hazardous Waste Facility
Permit to the facility in 1979.
From 1980 to the present, the facility has operated under RCRA interim
status. In 1980, State Waste Discharge Requirements were amended again to
allow an expansion of 75 acres to the west. This expansion, which added five
surface impoundments and one landfill, brought the facility to its current size of
254 acres. The amendment also prohibited the discharge of surface waters
from the facility site. A Zimpro® wet-air-oxidation (WAO) treatment process was
added in 1982 under an addendum to the Hazardous Waste Facility Permit
Class l sites are designated to receive hazardous wastes.
Zimpro is a registered trademark and appears hereafter without ®.
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166
SANTA MARIA
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CASMALIA
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Figure 1
Casmalia Resources, Facility Location Map
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issued by DHS. In 1986, DHS again amended the State Permit to include an
in-tank neutralization system (NS). The current list of permits is contained in
Appendix B.
The RCRA Part B Permit Application was requested by EPA in January
1983. The first application was received at EPA in July 1983. After reviewing
the application the Agency issued the facility a first Notice of Deficiency (NOD)
in April 1984 under a warning letter. A second Part B Permit Application,
incorporating changes resulting from the NOD and a consent agreement
resulting from a December 1983 EPA inspection, was received in November
1984. A second NOD, which included DHS comments, was issued in March
1986 under another warning letter. The Company was in the process of
revising the Part B to address the second NOD at the time of the NEIC
inspection.
In February 1986, DHS initiated a hearing and investigation of Casmalia
Resources. The hearing was held June 12 and 13, 1986 and the investigation
continued until January 1987. The purpose of the hearing and investigation
was to determine whether sufficient evidence exists to support a determination
that Casmalia Resources "may present an imminent and substantial
endangerment to health and the environment". Based on the evidence
obtained from the investigation, DHS concluded that the operation of the facility
did not present an imminent and substantial endangerment to health and the
environment.1
Casmalia Resources has been the subject of County, State and EPA
enforcement actions. In 1985, Santa Barbara County claimed Casmalia
Resources violated the CUP by expanding beyond the 1976 boundaries. An
agreement between the County and the facility, which began in January 1986,
redefined the total acreage of the site, limited truck traffic to an average of 65
trucks per day, terminated use of the PCB landfill and certain surface
impoundments, and limited use of a portion of the facility known as "RCRA
Canyon." In April 1987, the County mandated that the facility cease using the
WAO treatment system because of alleged violations of air emission standards
and permit issues. The County also announced new requirements for
groundwater and air monitoring.
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Santa Barbara County has also prohibited the construction of permanent
structures and restricted the use of temporary structures on-site, as a condition
of the CUP. The current available workspace is not sufficient to accommodate
office and laboratory space requirements of the facility. As a result, Casmaiia
Resources maintains supplemental office space in Santa Maria.
State enforcement action began in December 1984 when the DHS
issued a Complaint in response to a State General Operating Requirements
Inspection. As a result, a Director's Order was drafted in June of 1985 which
required the facility to fund a $626,000 interagency air study, conduct
groundwater assessment studies, take measures to reduce odors, and make
operational changes in the management of its waste handling units. The Order
was held pending an agreement with Casmaiia Resources to fund the
interagency study and was finally issued in September 1986.
In November 1985, a DHS Directive required the facility to cease
accepting liquid hazardous waste except inorganic acids and bases and
organics to be treated in the WAO unit. The Directive, which became effective
December 21, 1985, also required the facility to begin treating surface
impoundments suspected of causing odors.
In February 1986, DHS began an Enhanced Surveillance Program at the
facility. The Program calls for DHS inspectors to be on-site daily to monitor
compliance with State and federal regulations.
EPA enforcement action consists of a RCRA Section 3008(a) Complaint
against Casmaiia Resources in May 1984 for groundwater monitoring violations
documented during a December 1983 EPA inspection. The Complaint resulted
in a September 1984 Consent Agreement carrying a $35,000 fine.
At the time of the NEIC inspection, Casmaiia Resources was using
landfills and surface impoundments for the disposal of hazardous and
nonhazardous waste. Surface impoundments were also being used to treat
waste and collect and manage large volumes of liquids from surface
runon/runoff [Figure 2].
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WATER TAWCt
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Figure 2
PLOT PLAN, CASMAL1A RESOURCES
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Of a total of six landfills, four were active RCRA landfills, one was an
inactive RCRA landfill that had not undergone closure, and one was an inactive
landfill for disposal of polychlorinated biphenyls (PCBs). The four active
landfills were segregated by waste type into the categories of caustics/cyanides,
acids, solvents/pesticides and metals/metal sludges. Of a total of 41 surface
impoundments, two had been clean-closed and two were receiving direct
discharges of liquid RCRA waste. The remaining surface impoundments were:
(1) Receiving indirect discharges of liquid waste together with runon/runoff via a
liquid management transfer system, (2) receiving only surface runon/runoff and
no liquid waste, (3) full or nearly full of sludges, or (4) not in use.
As of July 13, 1987, Casmaiia Resources discontinued accepting
inorganic liquid hazardous waste streams except those designated for
treatment in the neutralization system. Acceptance of all other liquids was
discontinued following the December 1985 DHS directive. This action was
initiated in response to the California Toxic Pits Cleanup Act which became
effective in 1988. Since the inspection, Casmaiia Resources decided not to
restart the WAO. Instead the unit will undergo closure.
Treatment operations at the facility included the Zimpro wet-air-oxidation
system, the neutralization system, the oil recovery system and hydrogen
peroxide and aeration and evaporation treatment in the surface impoundments.
The WAO was designed to treat aqueous cyanide, sulfide, pesticide, solvent still
bottoms and other organic wastewaters. As mentioned above, the system has
been shut down and will undergo closure. The NS is designed to treat bulk
acid, alkaline and heavy metal liquid waste. The waste oil recovery system
treats waste with the potential for oil recovery with industrial demulsifier
chemicals to separate the oil from water and solids. It was not in operation
because of the low market price for waste oil. Hydrogen peroxide and aeration
treatment is used on some of the surface impoundments to control odors. The
facility was considering installing an additional treatment unit - a powdered
activated carbon treatment (PACT® ) system for the treatment of industrial
wastewaters.
®PACT is a registered trademark and appears hereafter without ®.
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SUMMARY OF FINDINGS AND CONCLUSIONS
Casmalia Resources treats, stores and disposes of hazardous waste as
defined and regulated by RCRA. The NEIC inspection of Casmalia Resources
determined that waste management practices were not meeting all RCRA and
the State of California Director's Order requirements. The findings are
summarized below.
WASTE MANAGEMENT PRACTICES
Laboratory Procedures
Waste characterization and waste confirmation data generated in the on-
site laboratory may be unreliable because no protocols were being followed to
ensure representative sampling prior to testing, as required by 40 CFR
265.13(a)(1).
The results recorded for specific parameters may be unreliable because
of inadequate quality control procedures or because of the use of analytical
techniques that were not equivalent to those listed in 40 CFR 261, Appendix III.
Waste Acceptance Procedures
An inspection of the records indicated that Casmalia Resources failed to
obtain a detailed chemical and physical analysis of hazardous waste accepted
for treatment or disposal, as required by 40 CFR 265.13(a)(1). Examination of
the facility files indicates that, in most cases, no information was recorded for
waste streams prior to arrival at the facility and no testing or insufficient testing
was conducted when waste were accepted at the facility for treatment or
disposal.
The records did not indicate that Casmalia Resources inspected and, if
necessary, analyzed each hazardous waste shipment received at the facility to
determine whether it matched the identity of the waste specified on the
accompanying manifest, as required by 40 CFR 265.13(a)(4). Specific waste
files for bulk and containerized solid waste accepted by the facility for disposal
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did not contain the results of the inspections and/or analyses. Liquid waste
were accepted for treatment in the WAO and NS based on confirmation tests
that were compared to treatment process limitations. The test results were not
compared to the waste description listed on the manifest nor to the results
generated during waste characterization to determine if the waste being
accepted for treatment matched the waste that the facility had previously agreed
to accept.
Casmalia Resources did not always follow the facility waste analysis plan
[Appendix C] for managing waste, as required by 40 CFR 265.13(b). The
records show that the facility treated and/or disposed of bulk liquid waste
without the information required by the plan, and disposed of liquid waste
outside the limitations cited in the plan. Solid waste were also accepted for
disposal without the information required by the plan.
Casmalia Resources has failed to maintain the results of waste analyses
and tests, as required by 40 CFR 265.73(b)(3). There are no Visual Inspection
Forms for bulk solid waste accepted prior to 1987. There are no records of the
visual checks done on containerized solid waste, although these checks were
observed during the inspection. An audit of specific waste files of liquid waste
showed no test results or incomplete results.
The records show that the facility accepted ignitable and reactive waste
but do not demonstrate that these waste were handled in accordance with 40
CFR 265.17 governing the precautions that must be taken with ignitable and
reactive waste.
Waste Analysis Plan (WAP) Evaluation
The interim status WAP evaluated has an effective date of January 1983.
The California DHS has required Casmalia Resources to submit revisions to the
WAP but these revisions have not yet been approved by DHS and are not part
of the 1983 WAP.
The WAP does not list all the parameters for which waste accepted for
treatment and disposal will be analyzed, as required by 40 CFR 265.13(b)(1).
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The WAP does not define the visual inspection parameters for solid waste
accepted for disposal nor all the parameters of analysis for liquid waste
accepted for treatment at the facility.
The WAP does not list all the test methods that will be used to analyze
waste accepted for treatment and/or disposal, as required by 40 CFR
265.13(b)(2). Liquid waste were analyzed for parameters using methods that
were not cited in the WAP. The WAP lists no analytical methods for solid waste.
The WAP does not contain sampling methods to ensure the taking of a
representative sample of the waste to be analyzed, as required by 40 CFR
265.13(b)(3).
The WAP does not address the frequency with which the initial analysis
of the waste will be reviewed or repeated to ensure that the analysis is up to
date, as required by 40 CFR 265.13(b)(4).
The WAP does not specify the procedures that will be used to check all
waste being received at the facility to determine if it matches the waste listed on
the manifest, as required by 40 CFR 265.13(c). Waste is accepted for treatment
in the WAO or NS without reviewing the test data to determine if the waste
matches the waste listed on the manifest.
The WAP contains test methods that do not comply with regulatory
requirements. The Inductively Coupled Plasma methods listed for arsenic,
selenium and mercury are not equivalent to methods in 40 CFR 261,
Appendix III.
The WAP does not address the necessary protocols to ensure that
ignitable and reactive waste are handled in accordance with 40 CFR 265.17.
The WAP should describe procedures that would ensure ignitable and reactive
waste are kept separated from sources of combustion or reaction. The testing of
liquids discharged directly to surface impoundments for sulfide and cyanide
only when the pH is greater than 9, is inadequate.
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Sections of the WAP discussing waste rejection criteria for bulk liquid
waste are unclear. There are conflicts between rejection criteria, acceptance
tests and surface impoundment limitations.
The WAP does not contain the quality control procedures that will be
used to verify analytical results. Laboratory quality control procedures are
essential for demonstrating the validity of test results.
Waste Management Units
The landfills are not subject to RCRA double liner requirements (40 CFR
265.301) because they were constructed and in operation prior to May 8, 1985.
The Company plans double-liner installations for any extensions of existing
landfills occurring since that date.
During the NEIC inspection, the surface impoundments met the general
operating requirements for minimum freeboard measurement (40 CFR
265.222). Freeboard markers required by the Director's Order were present in
all RCRA regulated surface impoundments except Ponds 14 and P, which were
empty. A minimum of 2 feet of freeboard was maintained in each
impoundment.
The surface impoundment system was not in compliance with RCRA
regulations for containment systems (40 CFR 265.223). Earthen dikes on
surface impoundments (ponds) 1, 5, 14, 16, 19, B, C, D, E, J, L, M, and P did not
have sufficient protective cover to minimize wind and water erosion and
preserve structural integrity. In addition, slope failure and deep erosion
channels were observed on ponds A-2, A-3, A, B, C, D, L, M and 10.
Concerns about spraying hazardous constituents into the air were raised
by local citizens during the inspection. NEIC personnel looked for and did not
detect evidence of spraying.
Because the WAO unit and the NS were not in operation at the time of
the inspection, compliance with RCRA regulations for general operating
requirements (40 CFR 265.373 and 265.401) could not be determined. Since
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the inspection, the WAO has been taken out of service permanently and will
undergo closure and the NS has begun operating.
INTERIM STATUS STANDARDS/DIRECTOR'S ORDER
Security
The perimeter fence did not have the required number of warning signs
during the first of two perimeter inspections by NEIC personnel. The site
perimeter fencing was found to be in compliance with RCRA security
regulations (40 CFR 265.14) and the Director's Order during the second
inspection.
Facility Inspection Records
The facility inspection records for the period covered by the Director's
Order (October 1986 to May 1987) were reviewed. Inspection records for
security, surface impoundments, landfills and treatment units did not meet
RCRA regulations for general inspection requirements (40 CFR 265.15) and the
requirements of Director's Order. The most significant deficiencies in the
inspection records were missing records, where inspections either were not
conducted or the results were not recorded, and incompletely or incorrectly
completed records. The following summary addresses the records by category.
In the security records file, 4 of the required 32 (12%) records could not
be found. The available records contained all required data.
For the period October 1986 to March 1987, 106 of the required 125
(85%) records in the surface impoundment freeboard inspection file couid not
be found, and none of the available records contained all the required data.
However, from April 1987 to the time of the inspection, the freeboard file was
100% complete and contained all required data. One of the 32 (3%) required
surface impoundment dike inspection records could not be found, but ail
available records were complete.
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Two of the 166 (1%) required leachate well inspection records could not
be found and 7 (4%) of the available records were deficient. Three of the 32
(9%) landfill runon/off inspection records could not be found, but the available
records contained all required data.
In the Zimpro inspection file, 24 of 476 (5%) records could not be found,
and 424 (89%) of the available records did not contain all the required data.
The records were incomplete because the required daily process inspections
(40 CFR 265.377) were done weekly. The records also contained some
inconsistencies caused by operators interpreting the forms differently, but were
otherwise complete and did indicate problems that were corrected.
Manifest System/Operating Record
Casmalia Resources does not maintain a copy of manifests for 3 years
at the facility, as required by RCRA regulations (40 CFR 265.71). Manifests for
3 years are maintained but stored off-site at the Santa Maria office because of
a lack of space at the facility.
Significant manifest discrepancies for the quantity of waste designated
are not handled according to RCRA regulations (40 CFR 265.72). No attempt
is made to resolve significant quantity discrepancies with the generator or
transporter and the Regional Administrator is not notified of discrepancies.
Instead, the generator learns of the discrepancy when billed for the correct
quantity. Casmalia Resources does reject waste when significant manifest
discrepancies in waste type are found and cannot be resolved with the
generator.
Casmalia Resources does not keep a complete written operating record
at the facility, as required by RCRA regulations [40 CFR 265.73(a)]; however,
records are available on-site through a computer terminal and printer. The
computerized operating record contains required [40 CFR 265.73(b)(1) and (2)]
waste handling and disposal data except EPA Hazardous Waste Numbers
(HWN). About 15% (12 of 79) of the files reviewed did not have HWNs. The
record also contains 9 to 18% (35 of 404 and 532 of 3,032) waste location
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inconsistencies where waste appeared to be disposed in the wrong landfill or
the wrong landfill location or waste code was entered in the record.
The facility does not maintain a complete written record of all waste
transferred from one unit to another, as required by the Director's Order. The
facility also does not maintain a landfill waste location map, as required by
40 CFR 265.73(b)(2).
Biennial Report
The biennial report failed to list the waste received by EPA Hazardous
Waste Numbers and provide the method of treatment and/or disposal for each
type of waste, as required by RCRA regulations (40 CFR 265.75). The 1985
report, due March 1, 1986, was submitted March 18, 1986.
LAND DISPOSAL RESTRICTIONS
Casmalia Resources is not in compliance with RCRA land disposal
restrictions [40 CFR 268.7(c)]. The facility accepts waste which are restricted
and fall under the National Capacity Variance but, in most cases, has no
records of notices from the generators that the waste are exempt from land
disposal restrictions.
PART B WASTE ANALYSIS PLAN
The 1987 proposed Part B waste analysis plan contains no provision for
ensuring that the generators will submit a representative sample for analysis
and no indication of how often a waste will undergo analysis to ensure the
analysis is accurate and up to date. The plan does not include all the analytical
methods used by off-site laboratories for analysis of waste prior to arrival at the
site. The plan does not address how waste directed to the drum loading dock
will be analyzed by the laboratory. Other more specific concerns are discussed
in the "Findings" section of this report.
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TECHNICAL REPORT
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INVESTIGATION METHODS
The NEIC investigation of Casmalia Resources consisted of:
(1) Collecting and reviewing facility background information from EPA
Region IX files, (2) interviewing Region IX and California DHS personnel, and
(3) conducting a presurvey visit and an on-site inspection of the facility.
The facility background information was collected the week of April 20,
1987 in the EPA Region IX office. Copies of appropriate documents were
obtained for review and use on-site and arrangements were made with the
Region to obtain additional documents from the facility and Regional files.
Region IX and DHS personnel were interviewed to acquire additional
information about facility operations and history.
The presurvey visit was conducted April 24, 1987. It included a brief
overview of facility operations, record systems and waste management units.
The on-site inspection was conducted between May 19 and May 29, 1987. It
included: (1) A review of selected records concerning facility inspections as
well as waste shipments, tracking, treatment and disposal; (2) an evaluation of
laboratory and waste identification and handling procedures and facility
operations; and (3) an inspection of waste disposal and treatment units, and site
security provisions. The on-site inspection also included unannounced visits to
the facility after normal business hours, interviews with facility management and
operating personnel, and records research at the corporate office in Santa
Maria, California.
During the laboratory inspection, operating and analytical data records
were audited and analytical equipment was examined. Site records (including
Waste Characterization Forms, telephone memos relating to waste
characterization, manifests, weigh tickets, location papers, Drum Load
Worksheets, analytical test results and raw test data) were reviewed.
To expedite the on-site inspection, selected documents were copied and
taken to NEIC offices in Denver for further evaluation. Each group of documents
copied at the facility was assigned a unique identifying number and listed in a
document file. A log of photographs taken during the inspection was also
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maintained. A copy of the document file and the photograph log was given to
Casmalia Resources personnel at the completion of the on-site inspection.
The NEIC records review was generally limited to the period from
October 1986 to May 1987 because many of the waste tracking and inspection
records kept by Casmalia Resources were mandated by the September 26,
1986 Director's Order, However, laboratory records and shipping manifests
were reviewed as far back as 1980.
Casmalia Resources keeps waste tracking records on a computer data
base. These records were accessed directly by NEIC personnel to track
individual manifests. In addition, Casmalia Resources personnel provided data
on waste disposal by unit (solvents/pesticides and caustics/cyanides and
metals/metal sludges landfills, Zimpro wet-air-oxidation, Neutralization System
and the surface impoundments) and by type of waste. Hard copies of manifests
with waste location data and the waste load rejection file were also reviewed as
well as laboratory analysis reports, inspection records and other available-
documents. Hard copies of manifests were cross-checked against computer
entries.
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FACILITY DESCRIPTION AND OPERATIONS
Casmaiia Resources operates an off-site hazardous waste treatment,
storage and disposal facility in the northwest portion of Santa Barbara County,
California. The facility is located 4 miles from the Pacific Ocean, 10 miles
southwest of the city of Santa Maria and 16 miles northwest of the city of
Lompoc [Figure 1J.
Owned and operated by Hunter Resources of Santa Barbara, the facility
covers about 250 acres in the central portion of a 5,000-acre land holding. The
land holding is in a range of hills known as the Casmaiia Hills and is bounded
by Vandenberg Air Force Base on the west, the community of Casmaiia on the
south, and the Santa Maria Valley to the north.
Land uses in the area of the facility are largely cattle grazing and limited
dry farming. There are also several oil well fields to the east. The nearest
residences are several ranch homes about 1.5 miles southeast, one ranch
house about 1.9 miles northeast and the community of Casmaiia about 2 miles
southeast of the facility.
The climate of the area is characterized by short, mild winters and dry,
warm summers. Most precipitation falls during the months of November through
April and usually ranges from 10 to 15 inches, but can vary from a low of 5 to a
high of 30 inches.
Casmaiia Resources is a hazardous waste treatment, storage and
disposal facility that has used the following RCRA waste management facilities;
Wet-air-oxidation - treatment and storage of aqueous waste
Neutralization system - treatment and storage of liquid waste
Surface impoundments - treatment and disposal of liquid waste
Landfills - disposal of solid waste
The facility has received a wide spectrum of chemical and manufacturing
process waste, including solvents, pesticides, alkalines, acids, cyanides, resins,
phenols, laboratory waste and heavy metals. Major industries served include
the following:
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Oil refineries
Aerospace
Chemical manufacturing
Federal, state and local government agencies
• Automobile
Electronics
Utilities
Pharmaceuticals
* Food processing
National defense
Photography and photocopying
Since 1985, the percentage of solid hazardous waste received at the
facility increased while the percentage of liquid hazardous waste received
decreased [Table 1]. The total amount of waste received has dropped from
450,000 tons per year in 1985 and 220,000 tons per year in 1986 to a projected
rate of about 70,000 tons per year for 1987. This change in the type and
amount of waste received was primarily the result of restrictions placed on the
facility by regulatory agencies.
Table 1
SUMMARY OF WASTE RECEIVED
(1985 to March 1987)
Waste
Received
1985 1986
March 1987
Hazardous vs. Nonhazardous Waste (tons}
Hazardous
39,6421 (88%) 193,725 (88%)
16,510 (98%)
Nonhazardous
5,3641 (12%) 25,852 (12%)
362 (2%)
Total
45,1542 (100%) 219,577 (100%)
16,872 (100%)
Liauid vs. Solid Waste (tons)
Liquid
291,469 (64%) 70,155 (32%)
3,033 (18%)
Solid
160,073 (36%) 149,421 (68%)
13,838 (82%)
Total
451,542 (100%) 219,576 (100%)
16,871 (100%)
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19
WASTE ACCEPTANCE PROCEDURES/WASTE ANALYSIS PLAN
Waste Acceptance Procedures
Casmalia Resources accepts bulk solid waste, containerized solid waste,
and bulk liquid waste. The solid waste is disposed in four RCRA landfills
[Table 2] with each landfill allocated for a different category of waste. At the
time of the inspection, liquid waste were discharged directly into surface
impoundments. The NS was not operating, and the WAO unit was no longer
receiving waste. Prior to April 1987, the facility was receiving liquid waste from
treatment in the Zimpro WAO unit.
Table 2
WASTE DISPOSED IN RCRA LANDFILLS AT
CASMALIA RESOURCES
Heavy
Solvent/
Acid
Metals
Pesticide
Caustics
Landfill
Landfill
Landfill
Landfill
Inorganic/organic
Inorganics
Pesticides
Caustics
acids
Heavy metals
Oil
Sulfides
Lab pack acids
Sludge
Paint
Cyanides
Oxidizers
Petroleum
Lab pack
Lab pack
waste
caustics,
inorganics
Lab pack
sulfides,
organics
cyanides
Waste acceptance procedures for an off-site facility can be divided into
characterization of the waste prior to its arrival at the facility and confirmation of
the identity of the waste upon arrival at the facility. The waste characterization
and confirmation procedures used by Casmalia Resources in handling waste
are dependent on whether the waste is a solid or liquid and on whether the
waste is treated prior to disposal.
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20
Waste St^am Characterization
Casmalia Resources reportedly gathers information about RCRA waste
from generators prior to the arrival of the waste at the facility for disposal. The
information is generally not recorded for solid waste and liquid waste destined
for direct disposal in surface impoundments. According to site personnel, no
waste characterization tests are done in the on-site laboratory for solid waste,
waste destined for direct disposal into surface impoundments and WAO waste.
Surface impoundment liquids, in May 1987, could include weak acids and
bases, inorganic contaminated wastewaters and inorganic brines. These
liquids also included organic-contaminated waste waters until December 1985.
Generators wishing to have waste evaluated for treatment in the WAO
unit submit a completed Waste Characterization Form to Casmalia Resources.
The Waste Characterization Form gives a general description of the waste and
the process producing the waste and lists known components and known
physical characteristics of the waste. If Casmalia Resources decides that the
waste is amenable to the WAO treatment based on the information gathered,
two 1-liter samples of the waste are taken by Casmalia Resources personnel or
by the generator and the waste is assigned a four-digit waste code. One of the
samples is sent to Zimpro in Wisconsin for testing and one is kept at Casmalia
Resources as a backup, Zimpro notifies Casmalia if the waste is acceptable for
treatment on the basis of the test results. If the waste is acceptable, Casmalia
Resources notifies the generator to make an appointment to deliver the waste.
Waste accepted for WAO evaluation testing include waste waters contaminated
with cyanides, sulfides, phenols, chlorinated aiiphatic compounds, pesticides
and other oxidizable organics. Solvents and oils are not accepted for
evaluation.
Generators wishing to have waste evaluated for treatment in the
Neutralization System also submit a completed Waste Characterization Form to
Casmaiia Resources. If Casmalia Resources technical personnel decide that
the waste is a candidate for treatment in the neutralization unit, then the waste is
assigned a waste code and a 1-liter sample is tested in the facility laboratory.
Casmalia Resources notifies the generator to make an appointment to deliver
the waste if the waste is determined to be acceptable based on the test results.
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21
The neutralization system is designed to neutralize acid and alkaline waste
streams and to remove heavy metals from those streams.
Waste Load Confirmation
When a truck arrives at the gate, the security guard has the transporter
sign in. The truck then proceeds to the scale where the waste transporter
presents a manifest to the clerk. The clerk checks the manifest and completes a
weigh ticket showing the date, manifest number, transporter, generator, and the
signature of the clerk receiving the waste. Each waste load that passes through
the weigh station is checked for radiation with a gamma counter (equipped with
an audible alarm) that is positioned above the truck scale. If the alarm sounds,
then the waste is checked with a Geiger counter. The load is refused if it
registers on the Geiger counter.
For a solid load, an analyst in the laboratory receives the manifest,
documents* from the generator accompanying the waste, and the weigh ticket
from the clerk. The analyst determines the characteristics of the waste from the
information listed on the manifest and the documents sent by the generator
because there is usually no recorded analytical information and solid loads are
not routinely tested upon arrival at the facility. If the analyst has not received
enough information to characterize the waste, he may contact the generator.
Based on the information gathered on the waste, the analyst decides if the
waste is within the operating protocols of the facility, and what landfill the waste
should be sent to if it is accepted. The analyst indicates that a waste has been
accepted by writing the landfill code for the load on the reverse side of a copy of
the manifest which is then called a location paper. When the truck arrives at the
designated landfill, a facility operator checks the location paper to ensure that
the load is being delivered to the proper unit. When the waste is discharged,
the coordinates of the disposal location are written on the location paper. NEIC
personnel observed bulk solid loads being inspected at the weigh station using
the Visual Inspection Form in the waste analysis plan and again by field
personnel as the waste was being unloaded at the landfill.
Documents may include, but may not be limited to, handwritten inventories of lab packs,
waste descriptions and material safety data sheets.
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22
For a containerized load, a laboratory analyst also reviews the manifest
and generator documents to determine if the waste within a container is
compatible and if the liquid volume within a container exceeds the capacity of
the absorbent in the drum. If the waste within a drum is incompatible, the drum
is rejected. If the drum holds insufficient absorbent, the facility can repack the
container. Containerized solid waste loads are sent to the loading dock where
they are divided and sent to more than one disposal location if the waste is
dissimilar. The containers of dissimilar waste are separated by the forklift or
loader operator according to the disposal designation on the marked copy of
the manifest or location paper. Field personnel complete Drum Load
Worksheets showing generator, manifest number, drum identification number,
drum size and landfill location of the containers. NE1C observed containerized
loads being inspected at the drum loading dock where the containers were
opened and checked against the manifest and examined for free liquids and
fullness. About 10% of the containers in several loads were seen being
checked.
The information on the location paper is entered into the facility computer
system. The location papers are filed separately from the copy of the manifest
and kept in the facility files for an unspecified time. Manifest discrepancies are
documented on the location paper. Bulk load discrepancies are noted when
the truck is weighed and containerized load discrepancies are noted at the
drum loading dock. Location papers with documented discrepancies are set
aside and mailed to DHS every month. An indication that a solid load was
refused also appears on the location paper and/or the Drum Load Worksheet.
In addition, a separate record of rejected loads is maintained by the facility.
NEiC did not observe the acceptance of liquid waste during the
inspection. According to Casmalia Resources technical personnel, liquids
destined for surface impoundments are sampled by the truck drivers using
COLIWASAs (column liquid waste sampler) and labeled sample containers
supplied by Casmalia Resources. The labeled sample, the manifest and the
weigh ticket are taken to the laboratory where the analyst attaches a Laboratory
Analysis Data Form to the manifest and the weigh ticket. According to
laboratory personnel, the sample is tested for pH, ignitability using OVA and
flash point if the OVA is greater than 500 ppm, for halogenated organics, for
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23
sulfide and cyanide if the pH is greater than 9, for settleable solids, odor, phase
distribution, and pond compatibility. The analytical methods used at Casmalia
Resources are listed in Table 3. The analytical results are compared to the
information listed on the manifest by the generator or the results added to the
manifest by the analyst after consultation with the generator. Information
gathered on surface impoundment liquids (those destined for disposal in the
surface impoundments), prior to its arrival at the facility, is not routinely
recorded. If the analyst is satisfied that the waste has been characterized, then
the information is used to determine if the waste is within the operating
protocols of the facility and where the waste will be discharged. The disposal
location for surface impoundment liquids is recorded on the manifest.
According to the technical personnel, generators of WAO liquid waste
made appointments with Casmalia Resources prior to delivery of the waste.
When the transporter arrived at the facility, the weigh clerk checked the manifest
and completed the Waste Receipt/Processing Record showing the generator,
transporter, the waste code assigned during evaluation testing, the waste name
and type, and the manifest and weigh ticket numbers. A sample taken from the
load by the driver was analyzed in the on-site laboratory for pH, specific gravity,
and a waste-specific component. The test results were recorded on the Waste
Receipt/Processing Record. The acceptance test results were compared to the
tests performed on the waste prior to its arrival at the facility to determine if the
waste matches what was previously analyzed. The criteria for rejecting a load
were not based on differences between the acceptance test results and waste
characterization results but on the WAO treatment limitations. If a waste was
accepted, a copy of the Waste Receipt/Processing Record, showing the test
results, was sent to the WAO unit where treatment processing information such
as the storage tank, processing date, and the unit log book pages were
recorded.
According to the technical personnel, when a transporter of NS liquid
waste arrives at the facility, the weigh clerk checks the manifest and completes
the Waste Receipt Form showing the generator, transporter, Casmalia
Resources waste code, waste name, and the manifest and weigh ticket
numbers. A sample is taken from the load by the driver and analyzed in the on-
site laboratory for pH, hexavalent chromium, specific gravity, and acid/base
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24
Table 3
CASMAL1A RESOURCES ANALYTICAL LABORATORY METHODS
Analysis
Description
Reference Method
SW-846' EPA-6Q0-4-79-02Q2 APHA5
Other
Acid/Alkaline
normality
Arsenic
Barium
Boron
Biochemical
oxygen
demand
Cadmium
Calcium
Chemical
oxygen
demand
Chloride
Chromium
Chromium
(hexavalent)
Color
{qualitative)
Conductance
(specific)
Copper
Cyanide
(qualitative)
Cyanide (free)
Cyanide
(total)
Flashpoint
Fluoride
Free liquids
Halogenated
organics
(qualitative)
Halogenated
organics
(quantitative)
Hydrogen
cyanide
Titration to phenolphthalein
endpoint
Inductively coupled plasma
Inductively coupled plasma
Atomic Absorption 7080
(direct aspiration)
Inductively coupled plasma
Incubation, manometric
Inductively coupled plasma
Atomic absorption 7130
(direct aspiration)
Inductively coupled plasma
Atomic absorption
(direct aspiration)
Closed reflux, colorimetric
Ion selective electrode
Inductively coupled plasma
Atomic absorption 7190
(direct aspiration)
Colorimetric (1,5-diphenyl- 7196
carbazide
Atomic absorption 7197
(chelation-extraction)
Sensory
Electrode
Inductively coupled plasma
Atomic absorption 7210
(direct aspiration)
Chloramine-T, pyridine-
barfcituric acid
Colorimetric
Colorimetric after distillation
Pensky Martin (closed cup) 1010
Colorimetric (SPADNS)
Ion selective electrode
Paint filter test 9095
Copper halide flame test
(Beilstein)
Packed column GC/MS 8250
Capillary column GC/MS 8270
Detector tube
200.7
200.7
208.1
200.7
200.7
213.1
200.7
215.1
508C
200.7
218.1
218.4
120.1
200.7
220.1
335.2
340.1
3402.
305
305
303C
305
305
303A
305
303A
305
303A
321 B
3038
205
305
303A
41 2J
4128
413C
413B
516
4
4
7
p. 83
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25
Table 3 (cont.)
Analysis
Description
Reference Method
SW-8461 EPA-600-4-79-0202 APHA3
Other
Hydrogen
sulfide
Iron
Lead
Magnesium
Mercaptans
Mercury
Methane
Nickel
Organics
Oxidation/
reduction
potential
Oxygen
(dissolved)
PCBs
(qualitative)
Pesticides
organochlorine
chlorinated
phenoxy acid
Organophosphate
pH
Phenols
Radioactivity
Selenium
Silver
Solids
Specific gravity
Sulfide
(qualitative)
Portable gold foil detector
detector tube
Inductively coupled plasma
Atomic absorption
(direct aspiration)
Inductively coupled plasma
Atomic absorption 7420
(direct aspiration)
Inductively coupled plasma
Atomic absorption
(direct aspiration)
Detector tube
Inductively coupled plasma
colorimetric (dithizone)
Detctor tube
Inductively coupled plasma
Atomic absorption 7520
(direct aspiration)
Packed column GC/MS 8250
Capillary column GC/MS 8270
Volatile solvents-distillation
Electrode
Membrane electrode
Gas chromatography 8080
Gas chromatography 8080
(electron capture detector)
Gas chromatography 8140
(flame thermionic detector)
Electronic pH meter 9040
Colorimetric (4-aminoantipyrine)
Portable beta-gamma Geiger
counter
Area monitor with scintillation
gamma probe
Inductively coupled plasma
Inductively coupled plasma
Atomic absorption
(direct aspiration)
Total (gravimetric)
Total dissolved (gravimetric)
Total suspended (gravimetric)
Fixed and volatile (gravimetric)
Settleable (Imhoff cone)
Hydrometer
Lead acetate test paper
200.7
236.1
200.7
239.1
200.7
242.1
200.7
200.7
249.1
360.1
150.1
420.1
200.7
200.7
160.3
160.1
160.2
160.4
160.5
305
303A
305
303A
305
303A
305
3208
305
303A
516
9
10
421 F
509A
509B
423
510C
305
305
209A
209B
209C
209D
209E
427
11
12
13
14
p. 213
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26
Table 3 (cont.)
Analysis
Description
SW-846'
Reference Method
EPA-600-4-79-0202 APHA3
Other
Sulfide
(quantitative)
Sulfur Dioxide
Thallium
Total
hydrocarbons
Water
reactivity
Zinc
Colorimetric (methylene blue)
ion selective electrode
Detector tube
Inductively coupled plasma
Atomic absorption 7840
(direct aspiration)
Foxboro organic vapor analyzer
Addition to water
Inductively coupled plasma
Atomic absorption 7950
(direct aspiration)
376.2
200.7
279.1
200.7
289.1
427C
305
303A
305
303A
15
16
17
18
1 U.S. Environmental Protection Agency, "Test Methods for Evaluating Solid Waste: Physical/Chemical Methods", SW-
846, Second Edition, July 1982.
2 U.S. Environmental Protection Agency, "Methods for Chemical Analysis of Water and Wastes', EPA-600/4-7Q-020;
EPA, Cincinnati, OH, revised March 1983.
3 American Public Health Association (APHA), "Standard Method for the Examination of Water and Wastewater"; 16th
Edition, APHA, Washington, D.C., 1985.
4 Hach Chemical Co., "Wastewater Analysis Handbook"; Hach Chemical, Loveland, CO, 1978.
5 Orion Research, "Instruction Manual: Chloride Electrode"; Orion Research, 1982.
6 American Society of Testing Materials, "Petroleum Products and Lubricants {1); 056-01600"; Method D93-80, ASTM,
23, 39, 1981.
7 Feigl, Fritz, Soot Tests in Organic Analysis. Elsevier Publishing Co., 1960
8 Draeger Tube, Hydrogen Cyanide, Instruction Manual
9 Jerome Instrument Corp., Cold Film Hydrogen Sulfide Analyzer, Model 621, Instruction Manual
10 Oraeger Tube, Hydrogen Sulfide, Instruction Manual
11 Draeger Tube, Mercaptans, Instruction Manual
12 Draeger Tube, Methane, Instruction Manual
13 American Society of Testing Materials, "Petroleum Products and Lubricants (1): D56-D1600"; Method D-86-78, ASTM.
23, 8, 1981.
14 Jungreis, Ervin, Soot Test Analysis; Clinical. Environmental. Forensic and Geotechnicai Application. Wiley-
Interscience Publications, New York, 1985.
15 Orion Research, "Instruction Manual: Sulfide Electrode"; Orion Research, 1980.
16 Draeger Tube, Sulfur Dioxide, Instruction Manual.
17 Foxboro Co., OVA 128 Century Organic Vapor Analyzer, Instruction Manual
18 State of California, Division of Occupational Safety and Health, Department of Industrial Relations; "HAZCA T: A
System of Field Identification and Classification of Commonly Spilled Materials"; September 1986.
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27
strength. The test results are recorded on the Waste Receipt Form and
compared to tests performed on the waste prior to its arrival at the facility.
Again, rejection of a load is based on the treatment limitations not on
differences between waste characterization and waste confirmation test results.
If a waste is accepted, a copy of the form showing the acceptance test results is
sent to the neutralization unit. When the waste arrives at the treatment unit, the
compatibility of the waste with treatment tank contents is determined and
recorded on the Waste Receipt Form. Treatment processing information is also
recorded on the form at the unit.
Waste Analysis Plan
This section describes the content of the facility interim status Waste
Analysis Plan (WAP), required by 40 CFR 265.13, with respect to the testing of
waste streams (Waste Stream Characterization) and the acceptance of
individual waste loads (Waste Load Confirmation) for treatment and/or disposal
at Casmalia Resources. Company officials indicated that the waste analysis'
program in use at the facility during interim status became effective in January
1983. NEIC personnel used the written interim status WAP provided by the
Company to evaluate compliance of the facility with waste analysis
requirements. An evaluation of the 1983 WAP is in the "Findings" section of this
report.
According to the WAP, Casmalia Resources can accept bulk and
containerized solids waste contaminated with acid, caustic, oxidizers, sulfide,
cyanide, heavy metals, solvents (unless subject to land disposal restrictions),
pesticides, oils and/or petroleum products. The WAP also says the facility can
accept bulk liquids containing acid, caustic, sulfide, cyanide, heavy metals,
phenols, hydrocarbons and/or pesticides. The only liquids that could be
discharged directiy to surface impoundments without prior treatment, at the time
of the NEIC inspection, were those containing inorganic compounds, including
weak acids and bases and/or inorganic brines. These waste must conform to
the limits in Table 4.
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Table 4
THE LIMITS ON LIQUID WASTE DISPOSED IN
SURFACE IMPOUNDMENTS AT CASMALIA
RESOURCES
Organic content, less than 1% (volume/volume)
pH, greater than 2
Total arsenic (As), less than 500 milligrams/liter (mg/L)
Total cadmium (Cd), less than 100 mg/L
Total hexavalent chromium (Cr-VI), less than 500 mg/L
Total lead (Pb), less than 500 mg/L
Total mercury (Hg), less than 20 mg/L
Total nickel (Ni), less than 134 mg/L
Total selenium (Se), less than 100 mg/L
Total thallium (Tl), less than 130 mg/L
Total cyanide, less than 100 mg/L
Halogenated organics, less than 1,000 mg/kg
PCBs, non-detectable
Sulfides, less than 400 mg/L
Phenols, less than 5,000 mg/L
Ammonia, less than 10%, (weight/volume)
Waste Stream Characterization
The WAP states that information about each RCRA waste stream will be
gathered from the generator prior to the arrival of the waste on-site. The type of
information gathered includes the chemical and physical characteristics of the
waste. The information may be obtained by telephone, by personal contact, on
a Waste Characterization Form, or in a waste analysis report. If more
information is required, the WAP indicates that the Company will request a
sample of the waste for analysis. The WAP does not address the testing of solid
waste {bulk or containerized) prior to its arrival at the facility.
Procedures described in the WAP for testing liquid waste vary depending
upon the anticipated destination of the liquids on-site. The WAP states that
liquids destined for direct discharge to surface impoundments will be tested for;
pH; acid/base strength, if the pH is less than 2 or greater than 12; ignitability;
presence of hydrocarbons, using an Organic Vapor Analyzer (OVA); flash point,
if the OVA results are greater than 500 parts per million (ppm); halogenated
organics; sulfide and cyanide, if the pH is greater than 9; radioactivity;
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29
appearance; color; odor and compatibility with the disposal pond. The
analytical methods listed in the WAP are shown in Table 3.
The WAP states that liquid waste that are a candidate for WAO treatment
are assigned a Casmalia Resources waste code and are tested by Zimpro in
Wisconsin for pH, chemical oxygen demand (COD), dissolved organic carbon
(DOC), soluble fluoride, ash, solids and waste-specific components such as
sulfide, cyanide, phenols, chlorinated hydrocarbons and pesticides. If tests
indicate that a waste contains oxidizable components, then an aliquot of the
waste will be run through a laboratory bench-scale version of the WAO
treatment. If the results of the small scale treatment indicate that the waste is
suitable for treatment, then the waste may be delivered to Casmalia Resources
for treatment and disposal.
According to the 1983 WAP, a liquid waste stream that is proposed for
NS treatment is assigned a Casmalia Resources waste code and tested at the
facility for flash point, settleable solids, pH, chromium (total, hexavalent), nickel,
cadmium, lead, arsenic, mercury, selenium, thallium, specific gravity, acid/base
strength, sulfide and cyanide. If test results indicate that the waste is a good
candidate for the neutralization treatment, then the waste is processed through
a laboratory-scale version of the treatment in the on-site laboratory. If a waste
stream is determined to be suitable for NS treatment, then it may be delivered to
Casmalia Resources for treatment and disposal.
Waste Load Confirmation
The WAP states that upon delivery, all waste received at the facility must
be accompanied by a manifest showing the generator, transporter, waste name,
State and federal waste codes, waste description and special handling
instructions. The WAP also states that bulk and containerized solid waste
typically will not be sampled, but that bulk solids will be checked visually using
a Waste Confirmation Visual Checks form. This form, once completed, shows
the date, manifest number, weigh ticket number, generator, transporter, free
liquids check, visual check, and land disposal restricted waste check. The WAP
states that generators are required to supply sufficient physical and chemical
information on the manifest (or accompanying documents) to enable the facility,
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30
after inspection, to accept or reject the load. According to the WAP, facility field
personnel will open approximately 10% of the containers (which include lab
packs), check for free standing liquids, and determine if the appearance of the
waste matches the description on the manifest. If free standing liquid is present,
the facility has the option to refuse the container or to add absorbent.
The WAP states that lab packs must be accompanied by a detailed
inventory specifying the name and quantity of each chemical contained in the
overpack container. Generators are required to package lab packs in
conformance with the requirements of 40 CFR 264.316. This regulation
prescribes that inside containers must be non-leaking, inside containers must
not react dangerously with waste, inside containers must be overpacked in
DOT-specification metal containers filled with sufficient absorbent to absorb all
of the liquid contents of the inside container; the outer metal container must be
full after packing with inside containers and absorbent, and the absorbent must
not be capable of reacting dangerously with the contents of the inside
containers. The WAP states that lab packs containing incompatible wastes or'
containing reactive wastes (other than cyanide or sulfide bearing wastes) will
not be accepted for disposal. According to the WAP only those materials that
can be disposed in a single landfill may be packed within a single drum.
According to the WAP, bulk liquids arriving on-site will be sampled,
labeled and tested in the facility laboratory prior to being accepted and
assigned a disposal unit. Bulk liquids will be sampled and tested for pH,
acid/base strength (if pH is less than 2 or greater than 12), ignitability,
halogenated organics, sulfide and cyanide (if pH is less than 9), radioactivity,
appearance, color, odor and compatibility with the disposal pond.
Liquid waste arriving for WAO treatment will be tested for specific gravity
and COD. Liquid waste arriving for NS treatment will be tested for specific
gravity, hexavalent chromium and acid/base strength.
The WAP states that the neutralization effluent will be stored in tanks until
the effluent is analyzed and the results indicate that the effluent components are
not restricted from land disposal. The dewatered sludge from the NS unit will
be tested for liquids prior to disposal in the heavy metals landfill.
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WASTE MANAGEMENT UNITS
As indicated above, Casmalia Resources operates a number of different
disposal, treatment and storage units for hazardous and nonhazardous waste.
The waste management units described in this section include 6 landfills, 41
surface impoundments and 2 treatment systems. Hazardous waste treatment
units include the Zimpro wet-air-oxidation system and the neutralization system.
A powdered activated carbon treatment (PACT) system may be installed for
treatment of bulk liquid waste. Hazardous waste storage units consist of six
steel tanks for waste treated by the Zimpro unit and eight fiberglass tanks used
for storage in the neutralization system.
Landfills
At the time of the NEIC inspection, Casmalia Resources was operating
four RCRA landfills. The landfills were segregated according to waste
compatibility and named for the category of waste each received:
(1) Caustics/cyanides, (2) acids, (3) solvents/pesticides and (4) metals/metal
sludges. A fifth landfill, called the RCRA canyon landfill, was not actively
receiving waste but has previously received hazardous waste and is slated to
receive hazardous waste in the future. The RCRA canyon landfill will contain
segregated cells for the above waste categories. A sixth landfill for
polychlorinated biphenyls (RGBs), regulated by the Toxic Substances Control
Act (TSCA), was not receiving waste. According to Company officials, both the
RCRA canyon and the PCB landfills had halted operation pending an
agreement between Casmalia Resources and Santa Barbara County regarding
the CUP on that section of the facility. The following descriptive information was
derived from information provided by Casmalia Resources in the form of reports,
submittals to EPA, and interviews with Company personnel.2'3
Each landfill is situated within the upper watersheds of individual natural
canyons. The landfills are constructed directly upon the Sisquoc Formation of
unweathered diatomaceous shale and claystone; a formation reported to be
continuous across the site, of varying thickness and low permeability.
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The existing landfills were constructed prior to regulatory requirements
for engineered landfills. As a result, no engineering plans or specifications
were prepared for the five RCRA landfills. These five landfills are unlined.
Company records indicate the PCB landfill is constructed according to TSCA
specifications.
Each of the landfill areas has been designed with bypass drainage
systems to prevent surface water entry (runon) to the landfill and to convey
direct precipitation away from the landfill (runoff). The runon control system
comprises ditches, terraces, and evaporation pads. The runoff control systems
consist of sloping the active areas of the each landfill so that direct precipitation
drains to runoff ponds.
The approximate dates that each landfill began receiving waste are in
Table 5. At the time of the NEIC inspection, there was no recent determination
of remaining landfill capacities. Each landfill was equipped with surveyed grid
markers used to locate waste within the landfill. These markers were intact and
visible. Specific waste accepted in each landfill are listed by EPA waste code in
Table 6.* All codes are defined in Appendix D.
Table 5
BEGINNING OPERATION DATES OF
CASMAL1A RESOURCES LANDFILLS
Landfill
Date
PCB
Caustics
Solvents/Pesticides
December 9, 1978
July 30, 1979
September 9, 1979
November 1, 1979
July 8, 1980
Metals
Acids
RCRA
NA*
Not available
Information on wastes received in each landfill is from Draft Table 2-13, compiled by Casmalia
Resources as part of the proposed Part B application. The waste listed represent waste
types that have actually been placed in the landfills.
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Table 6
DESCRIPTION OF CASMALIA LANDFILLS AND WASTES RECEIVED"
Unit Name
Remaining
Capacity
Cu. Yd."
Approximate
Suflace Area
Acres
Wastes Accepted*"
(EPA Waste Code)
landfills
Solvents/Pesticices
713,076
10,6
Heavy Metals
590,547
5.4
Caustics
Acids
RCRA
PCB
338,958
212,339
2,100,000
60,370
4.5
2.5
12.2
3.9
D002, D012-D017
K013-K020, K022-
K099, K101-K105.
P020, P022-P024,
P060, P062, P066
P085, P088, P089,
P116, P118.P123,
U028, U030, U031
U055-UQ64, U066
U114, U116-U122,
U159, U161-U174,
U203, U206-U211
U233, U235-U240,
F001 -F005.F024, F028, K001, K009-K011
K043, K048-K052, K073, K083-K087. K093-
P001-P005, P007, P008, P014, P016-P018,
P026-P028, P034, P036-P051, P054, P056-
, P067, P069-P072, P075, P077, P082, P084,
, P092-P094, P097, P101-P103, P108-P111.
U001-U005, U007-U012, U014-U022. U024-
, U034-U039, U041, U042, U044, U046-U053,
U085, U087-U095, U097, U101-U103, U105-
U124-U132, U136-U144, U146-U150, U152-
U176-U188, U190-U194, U196. U197, U200-
U213, U214, U218-U223, U225-U228, U23Q-
U242-U244, U247-U248
D001, D002, D004-D011, F006, F019, K002-K008, K021, K028,
K061, K062, K069, K071, K073, K084, K086, K101, K102, K106,
P0O6, P010-P012, P015, P036, P038, P068, P087, P092, P103,
P110, P113-P115, P119, P120, U032, U136, U144-146, U151,
U204, U205, U214-217, U249
D002-D011, F006-FQ09, F011, F012, P013, P021, P029, PG30,
P074, P098, P099, P104, P106, P107, P121.U110, U167, U168,
U194, U205, K060, K086
D002, D004-D011, F00B, P115, U087, U123, U134, U145, U204
All of the above, separated into compatible groups as above
Non-FiCRA wastes
General
Description
Landfill for solvents, pesticides and other
organic solid wastes
Landfill for heavy metals and other inor-
ganic solid wastes
Landfill for caustics, sulfide and other
inorganics solid wastes
Landfill for acids and other inorganic
solid wastes
Landfill for all of above categories of
solid wastes will be separated into com-
patible cells
Landfill for PCB-contaminated solids
TSCA permitted
Source: Draft Table 2-1, compiled by Casmalia Resources as part of Part B application for a RCRA permit. Waste codes listed represent wastes actually received fay the
time of the NEIC inspection.
Based on June 1985 topographic survey at Casmalia Resources facility. Reduced by wastes added between July 1985 and December 1986 and filling the landfills above
the levels of the surrounding ridgetops.
Casmalia Resources personnel stated that wastes affected by the land disposal restriction? of the Federal Hazardous and Solid Waste Amendments (HSWA) of 1984 have
not been accepted for landfill disposal after dates specified by the HSWA or EPA.
CO
CO
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34
Landfill waste are placed in horizontal layers (lifts) and covered with soil.
(The native cover material is obtained from on-site locations). Coordinates of
waste locations are surveyed two to three times per day. Each lift is covered
with 1 foot of soil and compacted by earth moving equipment.
Causfics/Cvanide Landfill
Caustic, sulfide, and other inorganic waste is buried in the
Caustics/Cyanide landfill. Drummed and bulk waste is commingled. The
Caustics/Cyanide landfill has a surface area of about 4.5 acres.
The primary runon controls for this unit drain along the upper road to
Pads 10E, 10A, and ultimately to Pond 19 [Figure 2], The secondary runon
control drains along the lower terraces to both the west and the east. The
western secondary drainage goes first to Pad 10E, then Pad 10A, and finally to
Pond 19. The eastern drainage flows to Pad 10C, across Pad 10B, then to
Pond 19.
Runoff to the west flows to Pad 10A then to Pond 19. Runoff to the east
flows directly to Pond 19. The fate of fluids entering Pond 19 is discussed in the
section entitled "Surface Impoundments."
Solvents/Pesticides Landfill
Solvents, pesticides and other organic waste is buried in the Soivents/-
Pesticides landfill. Drummed and bulk waste are segregated into two burial
areas. The approximate surface area of the Solvents/Pesticides landfill is 10.6
acres.
The runon controls for this unit drain along the upper road to the east to
Pads 10G and 10F and to Pond 22; and to the west to drainages to Ponds C,
L, Pad 4A and Pond 2.
Runoff from the west side of the Solvent/Pesticides landfill is diverted to
Pond R and drained to Pad 9B, then to Pad 9A, and Pond 6. Runoff from the
east side of the landfill is diverted to Pad 9B, then Pad 9A, and Pond 6. The
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35
fate of fluids in Pond 6 is discussed in the section of this report called "Surface
Impoundments".
Metals Landfill
Heavy metals and other inorganic solid waste are buried in the metals
landfill. Containerized and bulk waste are commingled. The surface area of the
metals landfill is approximately 5.4 acres.
Primary runon control is along the road on the north side of the metals
landfill. The drainage along this road is banked to the north and goes to Pad
10E, then to Pad 10A and Pond 19. The secondary runon control drains to
Pond 22.
Runoff to the west flows to Pad 9B, then to Pad 9A and Pond 6. Runoff to
the east flows to Pad 10A, then to Pond 19.
Acids Landfill
Acids and other inorganic waste are buried in the Acids landfill. Bulk and
containerized waste are commingled. The surface area of the Acids landfill is
about 2.5 acres.
The runon bench on the north side of the Acids landfill wraps around to
the west. Drainage along this route channels to Pond 19.
Runoff along the south side of the Acids landfill drains to Pond 6. The
runoff along the north side drains to Pond 19.
Leachate Collection
According to a May 1987 report2 on existing landfills, leachate controls
for the landfill areas are designed to prevent leachate from escaping off-site.
The report lists four components composing the overall system: (1)The
Sisquoc Formation, (2) the leachate/runoff collection ponds, (3) subsurface
barriers constructed at the Solvents/Pesticides and PCB landfills and
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36
(4) subsurface environmental barrier dams constructed in the lower elevations
of the site. The Sisquoc Formation of shale and claystone is intended to
prevent vertical migration of liquids; the ponds and subsurface barriers are
intended to prevent lateral migration. Liquid circulation between the ponds is
discussed in the section of this report on surface impoundments.
The Solvent/Pesticide landfill is underlain by the Sisquoc Formation.
This landfill is the only RCRA landfill with a designed leachate collection
system. The system consists of an adobe clay barrier at the toe of the landfill
(the southern, lowermost end) and a leachate collection well. The clay barrier is
nominally 8 to 12 feet wide and is keyed into bedrock about 50 feet deep at the
deepest point. The barrier is compacted to 95% relative compaction in
accordance with ASTM D1557-70.
The leachate collection well, located on the south side of the barrier,
consists of 10-inch perforated casing set approximately 50 feet deep. The well
is equipped with a level probe, a surface pump, and an hour meter for daily
monitoring of leachate levels. The pump is activated by the fluid level, and
leachate is pumped at a rate of 6 gallons per minute (gpm) to Pond M. The hour
meter records the amount of time that the pump operates each day, thereby
providing the Company with daily information on the volume pumped. Upon
entering Pond M, the leachate begins circulating between waste management
units in the liquid management/evaporation system.
The leachate collection at the Solvents/Pesticides landfill has been in
operation since 1985. The Company has been recording the associated
pumping volumes since January 1987.
Environmental barriers have been constructed in the lower elevations of
the site at the southern perimeter south of Pond 13 and the perimeter south of
the A-series ponds. These compacted clay dams are intended to prevent
downstream subsurface flow off-site. The barriers are keyed into bedrock and
are equipped with leachate collection galleries and pumping wells.
The leachate collection well B-5 is located immediately south of Pond 13
between the pond and the clay barrier. The well is equipped with a timer and a
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37
cubic foot pumpage gauge with recorder. Fluid levels and pumping volumes
are recorded daily. Leachate from this system is pumped to Pond 13,
According to Company officials, leachate from this well is analyzed monthly.
Leachate collection wells C-5, C-5E, and C-5W penetrate the rock mantle
of the leachate collection gallery south of the A-series ponds and upgradient
from the environmental clay barrier. The 8- to 12-foot-wide barrier is about 100
feet deep and penetrates bedrock for about 8 feet. Well C-5, the center well, is
about 95 feet deep and is the deepest of the three wells. The wells are
connected at depth by a 6-inch pipe running the length of the rock mantle. This
configuration enables one pump in C-5 to pump the entire system at once. C-5
is equipped with a fluid level indicator and a pumping gauge. Fluid levels
activate the pump and pumped volumes are recorded daily. Leachate is
pumped from C-5 to Pond A-3. Leachate from the C wells is analyzed monthly.
Surface Impoundments
The Casmalia facility has a total of 41 unlined surface impoundments'
that either contain or have contained liquid RCRA waste and/or surface runoff
and 15 evaporation pads. These units are used collectively to manage and
treat large volumes of liquid waste and surface runoff (the California Regional
Water Quality Control Board allows no discharge of liquids across facility
boundaries, so all liquids must be managed on-site'). The primary function of
each pond, together with the RCRA waste received, is shown in Table 7.
Casmalia Resources manages the large liquid volumes via a complex
system of liquid waste transfers between waste management units. Liquids are
transferred either by pumping (uphill) or by gravity flow. The objectives of
transferring the liquids include:
1. Liquid reduction by enhanced evaporation using multiple ponds
and evaporation pads to increase surface area.
Individual surface impoundments will be called "pond" hereafter to conform with the site
names (e.g., "Pond J").
Order Number 80-43
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38
Table 7
DESCRIPTION OF CASMALiA SURFACE IMPOUNDMENTS AND WASTES RECEIVED3
Deisgn
Capacity
Waste Accepted^
Unit
(million
Dimensions
General
Name
gallons)
(acres)
(EPA Waste Code)
Description
Surface Imooundments
Pond 1 c
4.2
1.0
No direct waste discharges
Runoff control/evaporation
Pond 2C
4.3
1.7
No direct waste discharges
Runoff control/evaporation
Pond 3C
8.8
2.3
No direct waste discharges
Runoff control/evaporation/aeration
Pond 4C
8.0
1.9
No direct waste discharges
Runoff control/evapo rat ion/a e rat io n
Pond 5
2.4
0.9
No direct waste discharges
Runoff control evaporation
Pond 6C
8.1
2.2
No direct waste discharges
Runoff control/evaporation/aeration
Pond 8C
9.6
1.9
No direct waste discharges
Runoff control/evaporation
Pond 9C
2.7
1.7
No direct waste discharges
Runoff control/evaporation
Pond 10c
9,2
1.8
No direct waste discharges
Runoff control/evaporation/aeration
Pond 11
13.1
2.7
No direct waste discharges
Runoff control/evaporation
Pond 12
3.5
1.3
No direct waste discharges
Runoff control/evaporation
Pond 13
6.2
1.5
No direct waste discharges
Reserve capacity/evaporation
Pond 14
1.9
0.8
No direct waste discharges
Inactive/scheduled for closure
Pond 15^
0.6
0.1
No direct waste discharges
Runoff control/evaporation
Pond 16
<0.1
0.2
Collection of tank truck washouts
Collection of tank truck washouts
Pond 17C
1.4
0.5
No direct waste discharges
Runoff control/evaporation
Pond 19c
7.4
1.6
No direct waste discharges
Runoff control/evaporation aeration
Pond 20C
1.4
0.6
No direct waste discharges
Runoff control/evaporation
Pond 22C
3.0
0.6
No direct waste discharges
Runoff control/evaporation
Pond 23C
0.8
0.8
No direct waste discharges
Runoff control/evaporation
Pond A-1
14.7
2.5
No direct waste discharges
Runoff control/evaporation
Pond A-2
15.4
2.2
No direct waste discharges
Runoff control/evaporation
Pond A-3
14.3
2.3
No direct waste discharges
Runoff control/evaporation
Pond A-4
16.8
2.2
No direct waste discharges
Runoff control/evaporation
Pond A-5
14.6
2.2
No direct waste discharges
Runoff control/evaporation
Pond A-6
2.7
0.9
No direct waste discharges
Runoff control/evaporation
Pond D
<0.1
0.2
Collection of tank truck washouts
Collection of tank truck washouts
Pond LC
1.2
0.8
No direct waste discharges
Runoff control/evaporation
Pond MC
3.3
2.3
No direct waste discharges
Gravity separation of oil, water, solids
Pond P
2.2
0.6
No direct waste discharges
Inactive/scheduled for closure
Pond R
0.3
0.2
No direct waste discharges
Runoff control/evaporation
Pond S
3.0
1,0
No direct waste discharges
Gravity separation of oil, water, solids
Pond T
-
2.3
Non-RCRA solids
Dewatering/stabilization
Pond V
0.9
0,6
No direct waste discharges
Gravity separation of oil, water, solids
Sludges 2d
1.0
0.7
Nonhazardous bulk liquids
Dewatering/stabilization
Pond Ae
1.25
0.4"
D001, D004-D017, K009-K011,
Acceptance of bulk liquid wastes
K013-K027, K029.K030, K048-
K052, K060, K083, K085-K087,
K093-K096, K098, K099, K103-
K105, P001-P0Q5, P007, P008,
P014, P016-P018, P020, P022-
P024, P026-P028, P034, P037,
P039-P051, P054, P056-P060,
P062, P066, P067, P069-P072,
P075, P077, P082, P084, P085,
P088, P089, P093, P094, P097,
P101, P102, P108, P109, P111,
-------
Table 7 (cont.)
39
Design
Capacity
Unit (million Dimensions Waste Accepted*3 General
Name gallons) (acres) (EPA Waste Code) Description
Pond A (cont.)
Pond B© 2.70 0.4
Pond Ce 5.30 0.8
P116, P118, P123, U001-U005,
U0C7, U012, U014-U028, U030,
U031, U034-U039, U041, U042,
U044, U049-U053, U055-U064,
U066-U085, U087-U095, U097,
U101-U114, U116-U132, U137-
U143, U147-U150, U152-U159,
U161-U174, U176-U188, U190-
U194, U196, U197, U200-U203,
U206-U211, U213, U218-U223,
U225-U228, U234-U240, U242-
U244.U247, U248
D001, D004-D017, K009-K011,
K013-K027, K029, K030, K048-
K052, K060, K083, K085-K087,
K093-K096, K098, K099, K103-
K105, P001-P005, P007, P008,
P014, P016-P018, P020, P022-
P024, P026-P028, P034, P037,
P039-P051, P054, P056-P060,
P062, P066, P067, P069-P072,
P07S, P077, P082, P084, P085,
P088, P089, P093, P094, P097,
P101, P102, P108, P109, P111,
P116, P118, P123, U001-U005,
U007-U012, U014-U028, U030,
U031, U034-U039, U041, U042,
U044, U049-U053, U055-U064,
U066-U085, U087-U095, U097,
U1Q1-U114, U116-U132, U137-
11143,11147-11150, U152-U159,
U161-U174, U176-U188, U190-
U194, U196, U197, U200-U203,
U206-U211, U213, U218-U223,
U225-U228, U234-U240, U242-
U244,U247, U248
D001, D004-D017, K009-K011,
K013-K027, K029, K030.K048-
K052, K060, K083, K085-K087,
K093-K096, K098, K099, K103-
K105, P001-P005, P007.P008,
P014, P016-P018, P020, P022-
P024, P026-P028, P034, P037,
P039-P051, P054.P056-P060.
P062, P066, P067, P069-P072,
P075, P077, P082, P084, P085,
P088.P089, P093, P094, P097,
PI 01 r P102, P108, P109, P111,
P116, P118, P123, U001-U005,
U007-U012, U014-U028, U030,
U031.U034-7039, U041 U042,
Acceptance of bulk liquids
Acceptance of bulk liquid wastes
-------
Table 7 (cont.)
40
Design
Capacity
Unit (million Dimensions Waste Accepted*5 General
Name gallons) (acres) (EPA Waste Code) Description
Pond C (con!.)
Pond 18 5.40 1.8
Pond E 2,40 0.8
Pond J 2.35 0.8
U044.U049-U053.U055-U064,
UQ66-U085, U087-U095-U097,
U101-U114, U116-U132, U137-
U143, U147-150, U152-U159,
U161-U174, U176-U188, U190-
U194, U196, U197, U200-U203,
U206-U211, U213.U218-U223,
U225-U228, U234-U240, U242-
U244, U247, U248
D001, D002, D004-D017, K001-
K006, K008-K011, K013-K027,
K029, K030, K048-K052, K060-
K062, K083-K087, K093-K096,
K098, K099, K100-K105, P001-
P005, P007, POOS, P010-P012,
P014, P016-P108, P020, P022-
P024, P026-P028, P034, P037,
P039-P051, P054, P056-P060,
P062, P066, P067, P069-P072,
P075.P077 P082, P084, P085,
P088, P089, P093.P094, P097,
P101, P102, P018, P109, P111,
P113-P116, P118-P120, P123,
U001-U005, U007-U012, U014-
U028, U030-U032, U034-U039,
U041, U042,U044,U049-U053,
U055-U064, U066-U085, U087-
U095, U097, U101-U114.U116-
U132, U134, U136-U159, U161-
U174, U176-U188, U190-U194,
U196, U197, U200-U211, U213-
U223, U225-U228, U234-U240,
U242-U244, U247, U248, U249
D002, D004-D017, K001-K006,
K008, K021, K060-K062, K084,
KQ8S, K100-K102, P010-P012,
P113-P115, P119, P120.U032,
U123, U134, U136, U144-U146,
U151, U204, U205, U214-U217,
U249
D002, D004-D017, K001-K006,
K008, K021, K060-K062, K084,
K086.K100-K102, P010-P012,
P113-P115, P119, P120, U032,
U123, U134, U136, U144-U146,
U151, U204.U205, U214-U217,
U249
Acceptance of bulk liquid wastes
Acceptance of bulk liquid wastes
Acceptance of bulk liquid wastes
-------
Table 7 (cont.)
Design
Capacity
Waste Acceptedb
Unit
(million
Dimensions
General
Name
gallons)
(acres)
(EPA Waste Code)
Description
Pad 1-A
1.0
1.6
No direct waste discharges
Evaporation
Pad 4-A
0.8
1.2
No direct waste discharges
Evaporation
Pad 7-A
0.6
1.0
No direct waste discharges
Evaporation
Pad 8-A
0.1
0.2
No direct waste discharges
Evaporation
Pad 8-B
0.3
0.4
No direct waste discharges
Evaporation
Pad 8-C
0.1
0.2
No direct waste discharges
Evaporation
Pad 9-A
0.7
1.1
No direct waste discharges
Evaporation
Pad 9-B
0.6
0.9
No direct waste discharges
Evaporation
Pad 10-A
0.3
0.5
No direct waste discharges
Evaporation
Pad 10-B
0.2
0.3
No direct waste discharges
Evaporation
Pad 10-C
0.8
1.3
No direct waste discharges
Evaporation
Pad 10-E
0.6
0.9
No direct waste discharges
Evaporation
Pad 10-F
0.3
0.5
No direct waste discharges
Evaporation
Pad 10-G
0.7
1.1
No direct waste discharges
Evaporation
Pad 18
1.0
1.6
No direct waste discharges
Evaporation
a Source: Draft Table 2-1, compiled by Casmalia Resources for the Part 8 application (or a RCRA Hazardous
Facility Permit. Waste listed for Ponds A and 18 are proposed waste streams. At the time of the NEIC
inspection, Pond A had not received RCRA waste. Pond 18 had received only leachate containing heavy
metals and organics from a hazardous waste cleanup operation,
b Waste from specific sources (K series} should be disposed of by surface impoundment only if
concentrations of hazardous constituents are below State and Federal limits for surface impoundment.
Materials defined as acutely hazardous (P series) or toxic (U series) would be disposed of by surface
impoundment only if present in contaminated water resulting from a spill cleanup and only if present at
concentrations below State and Federal limits for surface impoundment. See waste analysis plan
(Section 4.0) for a listing of these limits,
c These ponds typically receive liquid transfers either directly or indirectly from ponds or treatment units
which do receive RCRA hazardous waste,
d Non-RCRA unit
e Ponds A, B and C are scheduled for closure and have not received waste since December 21, 1985.
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42
2. Maintaining liquid levels that are low enough to both meet
freeboard requirements in individual units and provide overall
capacity to contain incidental storrr,water runoff.
3. Treatment of liquids containing hazardous constituents by pond
aeration and/or contact with hydrogen peroxide.
Most of the ponds at the facility either are or have been active in the
transfer of liquids. Only a few of the ponds have received direct discharges of
hazardous waste, and others are used either to treat liquids or simply to
hold/convey liquids being transferred in the evaporative process [Table 8].
Consequently, the pond descriptions presented in this section include the role
of each pond in the liquid management system. The same is true for the
evaporation pads.
The evaporation pads are graded soil surfaces over which aqueous
liquids are distributed to supplement natural evaporative processes. The pads
are used in sequence with one or more ponds as liquids are transferred
between units. Fluids that do not evaporate on a pad flow by gravity to another
waste management unit (either another pad or a pond). The pads are
considered by the Company and by EPA to be extensions of surface
impoundments for regulatory purposes.'
Casmalia Resources uses several combinations of surface
impoundments and evaporation pads to create flow cycles they call surface
impoundment systems. Ten surface impoundment systems {SI-1 through
$1-10), involving one or more ponds and pads, and in one case a leachate
collection system, were shown in documents provided by the Company to NEIC
personnel [Table 9]. These systems are shown in Figure 3.
Not all of the 10 surface impoundment systems are fully contained,
isolated systems. Liquids are transferred between individual units within a
system, but may also be transferred out of one system to another for additional
U.S. EPA Consent Agreement and Final Order, Docket No. RCRA 09-84-0026,
September 21, 1984 [Appendix E]
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43
Table 8
CATEGORIES OF SURFACE IMPOUNDMENTS (PONDS) AT CASMALIA
RESOURCES
Category*
Unit*
Impoundments that have received direct
discharges of liquid waste classified as
hazardous by 40 CFR Part 261 (RCRA-
hazardous).
Impoundments that have received direct
discharges only of liquid waste not clas-
sified as hazardous by 40 CFR Part 261.
Impoundments that have received surface
runoff and indirect discharges of liquid
waste via waste transfers between units.
Impoundments that have not received
liquid waste via direct discharges or
waste transfers but which have or may
receive surface runoff.
Ponds B, C, D, E, J, P, 14, 16, 18
Ponds A, T, Sludges 2
Ponds J, L, M, R, S, T, V, 1,2, 3,
4,5,6,0,9,10,11,12,15,17,
19,20,22, A-1.A-2, A-3, A-4
Ponds A-5, A-6, 13, 23, West
Canyon Catch Basin
Categories were chosen by NEIC personnel to facilitate identifying the present and past
functions of each unit.
Ponds P and 14 have been cleaned out and are scheduled for closure. Pond 13
receives liquids pumped from leachate well B-5. Pond 1$ is an old truck washout
retention pond; Pond D is the current washout pond.
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44
Table 9
SURFACE IMPOUNDMENTS AND SURFACE IMPOUNDMENT
SYSTEMS AT CASMALIA RESOURCES
Surface
Impoundment
System
SI-1
SI-2
SI-3
SI-4
SI-5
SI-6
Si-7
SI-8
Surface
Impoundment
Pond A-1
Pond A-2
Pond A-3
Pond A-4
Pond A-6
Pad 1 -A
Pond A-5
Pond 1
Pond 15
Pond 17
Pond 18
Pad 18
Pond 2
Pond E
Pond J
Pond L
Pad 4A
Pond 3
Pond 4
Pond 9
Pond 13
Pond 5
Pond 8
Pond 10
Pad 7A
Pond 11
Pond 12
Pond 20
Pad 8A
Pad 8B*
Pad 8C*
Surface
Impoundment
System
SI-9
S-10
WA"
Surface
Impoundment
Pond 6
Pad 9A
Pad 9B
Pond 19
Pond 22
Pad 10A
Pad 10B
Pad 10C
Pad 10E
Pad 10F
Pad 10G
Pond A
Pond B
Pond C
Pond D
Pond J
Pond M
Pond P***
Pond R#"
Pond S
Pond T
Pond V
Pond 14*"
Pond 16
Pond 23
Catch Basin
Sludges 2
* Never used
" Not applicable. Ponds listed here were not included by the Company in any Surface
Impoundment System
*'* These ponds were empty during the NEIC inspection.
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46
circulation, evaporation and treatment, or to accommodate an excess of liquids
during a wet period. The various possible flow configurations are also
described in this section.
In addition to those units included in the surface impoundment systems, a
number of ponds are involved in water/waste transfers that do not involve a
cycle early in the transfer sequence, or in some cases, at all. For example,
liquids from ponds outside the cycle which receive direct waste discharges may
flow to another unit, and then another unit, before finally entering a surface
impoundment system. Ultimately, aqueous liquids that are transferred pass
through one or more surface impoundment systems. Some ponds that contain
only runoff, are filled with sludges or are no longer active, are not involved in
liquids transfers.
Surface Impoundment System 1 (SI-1)
Surface impoundment System 1 is made up of evaporation Pad 1 A,
ponds A-1, A-2, A-3, A-4, and A-6. (Together with pond A-5, these ponds are
commoniy known as the "A-series.") SI-1 is located at the southwestern corner
of the active facility. The ponds in SI-1 contain runoff water and wash water for
"over-the-rcad" vehicles. Some of the water is used for irrigation and dust
control (pumped from A-3).
With the exception of A-6, these ponds are hydraulically connected to
one another. Pond A-6 is isolated and holds runoff water. Water has circulated
between A-1, A-2, and A-3 in the past, but was not circulating at the time of the
NEIC inspection.
Pond A-1 receives washout water from cleaning trucks that have not
contained hazardous waste. Pond A-1 also is plumbed to receive overflow from
Pond 1, located in Si-3. (Pond 1 receives overflow from Pond 18, which
received direct discharges of hazardous waste from the Stringfellow hazardous
waste cleanup site. The hydraulic connection between Pond 1 and A-1 has
resulted in hazardous waste entering the flow cycle in SI-1.) At the time of the
NEIC inspection, Company personnel said A-1 had not received liquids from
Pond 1 for about a year and a half.
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47
Pond A-4 is plumbed to receive runoff water from Pond A-5, outside SI-1,
via overflow piping. From A-5, liquids flow to A-4, then to A-3, A-1, A-2, and
back to A-3, Leachate pumped out of leachate collection welt C-5 flows into
A-3,
Historically, SI-1 received hazardous waste that flowed from Ponds D
and J (which received direct waste discharges), to Pond 2, Pond 1 and finally to
A-1.
Surface Impoundment System 2 (SI-2), as shown in Company
documents, consists only of Pond A-5, located north of SI-1. Pond A-5 receives
surface runoff and can receive overflow from the West Canyon Catch Basin
located north of it in the RCRA canyon landfill. Pond A-5 provides scrubber
water for the Zimpro Wet Air Oxidation treatment system. Over a year and a half
prior to the NEIC inspection, liquids treated by the Zimpro system went into A-5.
Surface Impoundment System 3 (SI-3), located immediately east of SI-1,
consists of Ponds 1,15, 17, and 18, and evaporation Pad 18. At the time of the
NEIC inspection, this system was being used only for water balance purposes.
Overflow liquids from Pond 18 can be pumped to Ponds 15 and 17 and to
evaporation Pad 3A, where they cease to circulate. Liquids can also flow by
gravity from Pond 18 to Pond 1. As mentioned, Pond 18 historically received
direct discharges of hazardous waste originating from the cleanup of the
Stringfellow acid pits.
3M
Surface Impoundment System 4 (SI-4) consists of Ponds E, J, L, 2, and
evaporation Pad 4A. This system is located immediately east of SI-3. At the
time of the NEIC inspection, Ponds E and J were receiving direct discharges of
weak acidic and alkaline liquids mixed together. Most of these types of liquids
were going into Pond J. Before the Zimpro unit was shut down in April 1987,
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48
liquids treated by wet air oxidation were put into Pond E. Both ponds E arid J
used to receive stronger acids and alkalines separately. Both Ponds can
overflow (via piping) to Pond 2; Pond E flows into Pond J, which flows into
Pond 2,
Liquids and residue from a RCRA truck washout rack enter SI-4 via
Pond D, which is located north and outside of SI-4. Pond D contains much of
the residue from the washout. Liquids (mostly water) from the washout
operation are piped across Pond D to Pond L, evaporation Pad 4A, then to
Pond 2. Liquids from Pond 2 may flow to Pond 1 (in SI-3), as mentioned, or
be pumped to Pond 4, which is in SI-5. Liquids from Pond 2 may also be
pumped to Pond 3 (in SI-5) or to Pond 10 (in SI-7) for aeration.
3k5
Surface Impoundment System 5 (SI-5) is located in the southern part of
the facility, east of SI-4, and consists of Ponds 3, 4, and 9. Pond 4 is equipped
with Ramco® aerators. Pond 3 is equipped with floating AERO II® aerators.
Pond 9 is oil covered. Aqueous liquids from Pond 4 and 9 pass through a
hydrogen peroxide treatment system prior to exiting SI-5. As mentioned,
Ponds 3 and 4 may receive overflow from Pond 2.
Some treated liquids from Pond 9 flow to Pond 3, then to Pond 4 and to
Pond 10 (located east of SI-5 in SI-7). From Pond 10, the liquids are pumped
with a diesel pump either to Pond 19 (in SI-10) or to Pond 6 (SI-9). From
Pond 19, the liquids flow by gravity to Pond 6, then to Pond 8 (SI-7), and back
to Pond 10.
Surface Impoundment System 6 (SI-6) is located at the lowest elevation
and southernmost portion of the facility, directly south of SI-5. SI-6 consists only
of Pond 13. Pond 13 receives liquids pumped from leachate collection well B-5.
If the water level in Pond 13 gets too high, the water is pumped uphill to SI-5.
®
Ramco and AERO II are registered trademarks and appears hereafter without the ®.
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49
SI-7
Surface Impoundment System 7 (SI-7) is located east of SI-5 and
consists of Ponds 5, 8, and 10, and evaporation Pad 7A. Pond 10 is equipped
with floating AERO II aerators. As mentioned previously, Pond 10 may receive
overflow from Pond 2 (SI-4) and Pond 4 (SI-5).
Liquids from Pond 10 may be pumped to evaporation Pad 7A and flow by
gravity to Pond 8 and back to Pond 10. In a wet year, liquids from Pond 10 may
also be pumped to Pond 5, where they cease circulating, or to Pond 20, in SI-8.
SI-8
Surface Impoundment System 8 (SI-8) is located east of SI-7 in the
southeastern corner of the facility. SI-8 consists of Ponds 11, 12, 20, and
evaporation Pads 8A, 8B, and 8C. Pads 8B and 8C were never put into service.
The flow cycle in SI-8 is used during a wet year when the volume of liquids that
has to be managed is high.
Liquids entering SI-8 from Pond 10 can be pumped to Pond 20 from
which they flow by gravity to Pond 12, Pond 11 and back to Pond 10. Surface
runoff flows from evaporation Pad 8A to Pond 20.
SI-9
Surface Impoundment System 9 (SI-9) is located north of SI-7 and
consists of Pond 6 and evaporation Pads 9A and 9B. Pond 6 is equipped with
Ramco aerators and two pneumatic pumps for pumping liquids to the two
evaporation pads. Liquids from Pond 6 can go from Pond 6 to any of six other
waste management units:
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50
Gravity flow to Pond 8 then to Pond 10 (SI-7)
Pumped to SI-10 to evaporation Pad 10C, piped across Pad 10B,
and gravity flow to Pond 19
Pumped to SI-10 to evaporation Pad 10E, gravity flow through a
pipe across Pad 10A, to Pond 19
Pumped to SI-10 to Pond 22, pumped to evaporation Pads 10G
and 10F, gravity flow to Pond 22 and to Pond 19.
Pumped to evaporation Pad 9B, gravity flow to Pad 9A and Pond 6
Pumped to evaporation Pad 9A, gravity flow to Pond 6.
Liquids in Pond 19 can be siphoned back to Pond 6. Pond 6 receives some
runoff from the Acids landfill.
SMJ2
Surface Impoundment System 10 (SI-10) is located north of SI-9 and
consists of Ponds 19 and 22, and evaporation Pads 10A, 10B, 10C, 10E, 10F,
and 10G. Pond 19 is equipped with Ramco aerators. Pond 19 receives
overflow from Pond 22 and liquids from Pond 6 (SI-9) as described above. Any
liquids that flow across the evaporation Pads in SI-10 flow by gravity to
Pond 19. As mentioned, overflow from Pond 19 goes to Pond 6.
Ppnd A
Pond A received direct discharges of non-RCRA oilfield waste until
December 1985 and was oil-covered during the NEIC inspection. Pond A
never received RCRA waste. Liquids from Pond A flow by gravity to Pond S,
then to Pond V. From Pond V, the aqueous liquids are siphoned to Pond 9 in
SI-5, where they begin circulating and undergoing treatment.
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51
Ppntjg 9 and Q
Ponds B and C have received direct discharges of hazardous waste
listed in Table 7. Each was oil covered at the time of the NEIC inspection.
Company personnel stated that they no longer receive RCRA waste.
Ponds B and C received direct discharges of organic-contaminated
wastewaters until December 1985. Aqueous liquids from these ponds are
pumped to Pond M for gravity separation then flow by gravity to Pond 9 in SI-5
for subsequent treatment with hydrogen peroxide. From Pond 9 the liquids are
pumped to other ponds as described for subsequent aeration and evaporation.
Pond D
The description of Pond D was included in the discussion of SI-4.
PpndP
Pond P was used for acid treatment prior to releasing liquids to other
ponds for evaporation. At the time of the NEIC inspection, Pond P had been
cleaned out and scraped, but had not undergone formal closure. Contaminated
sludges from Pond P had been removed to spread and dry, then landfilled.
Pond R
Pond R is used for runoff containment and can drain to Pads 9B and 9A
and to Pond 6. Pond R received non-RCRA waste but did not receive RCRA
waste. This unit was empty during the NEIC inspection.
Pond S
In addition to receiving liquids from Pond A, Pond S received drainage
from the overflow of oil recovery tanks. The overflow was mostly water with
some oil. During the NEIC inspection, Pond S was oil covered. Pond S has not
received RCRA waste.
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52
PondT
Company officials stated that Pond T was not used as a surface
impoundment for hazardous waste, but instead was used for dewatering drilling
muds, oil, sludges, and some non-RCRA material. During the NEIC inspection,
Pond T was filled with solid material.
Pond V
Pond V was used as an intermediate pond in the transferring of aqueous
liquids originating in Pond A through Pond S and V to Pond 9 and SI-5. Pond V
has not received RCRA waste.
Pond 14
Pond 14 was used simultaneously with Pond P. Pond 14 was used as
an alkaline treatment pond prior to releasing treated RCRA waste to other
ponds for evaporation. At the time of the NEIC inspection, Pond 14 had been
cleaned out and scraped, but had not undergone formal closure. Contaminated
sludges had been removed to spread and dry, then landfilled.
Pond 16
Pond 16 is an old washout rack retention pond, which received washout
water and residue from RCRA waste transporters. This pond never received
any direct waste discharges other than truck washout liquids and residue and
has never been cleaned out. At the time of the NEIC inspection, Pond 16 was
being used only for cleaning heavy equipment from the facility.
Pond 19
As discussed in the section on SI-10, Pond 19 receives runoff and
overflow from numerous sources and is hydraulically connected to SI-9 and
SI-7. Pond 19 does not receive direct waste discharges of any kind, but does
receive runoff from the Heavy Metals landfill and runon and runoff from the
Caustics/Cyanide and Acids landfills.
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53
Pond 22
Pond 22, located in SI-10, receives secondary runon water from the
Heavy Metals landfill. As mentioned previously, any overflow from Pond 22
goes to Pond 19.
Pond 23
Pond 23 is located south of and downgradient from the PCB landfill.
Pond 23 was constructed in the winter of 1982-83 as a runoff control pond and
is strictly for water management. This pond is not hydraulically connected to
any other pond and has never received any waste.
West Canvon Catch Basin
The West Canyon Catch Basin, located in the lower elevations of the
RCRA landfill, was constructed strictly for water management. This unit has not
received waste either by direct discharge or by waste transfer. Overflow from
the "Catch Basin" flows by gravity to A-5.
Sludges 2
Sludges 2, located near the northeastern perimeter of the active facility,
received sewage sludges and grease material but no RCRA waste.
Treatment in Surface Impoundments
Casmalia Resources treats hazardous waste in surface impoundments
using evaporation (for liquid reduction), aeration and chemical additives.
Evaporation is enhanced by liquid waste transfers between ponds and
evaporation pads as previously described. Distribution of liquids across
evaporation pads is via perforated PVC pipe and gravity flow.
Casmalia Resources uses aeration devices in Ponds 3, 4, 6, 10, and 19
to reduce sulfide odors believed by the Company to be caused by sulfate-
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54
producing anaerobic bacteria. Floating AERO II surface aerators equipped with
20 horsepower electric motors are set up in Ponds 3 and 10. According to
Company personnel, these aerators are most effective at shallow depths and
are used to force circulation within the ponds. Ponds 4, 6, and 19 have
mechanical Ramco aerators equipped with 7.5 horsepower electric motors.
These aerators sit on the bottom of the pond and aerate the entire water column
from top to bottom.
Chemical Treatment
A 50% solution of hydrogen peroxide (H2O2) has been used to treat
industrial/oilfield waste contained in aqueous liquids from Ponds A, B, C, M, 3,
4, and 9 [Table 10]. At the time of the NEIC inspection, the hydrogen peroxide
treatment system was set up to treat liquids from Ponds M and 9, but was not
operating because the liquid levels on-site were so low that it was difficult to get
at the aqueous phase to pump it to the separator.
Table 10
PERCENT OF AQUEOUS LIQUIDS
TREATED WITH HYDROGEN PEROXIDE'
Pond Percent
A, B, and C 70-95%
M 50%
3 100%
4 100%
9 50%
* Approximated verbally by Company personnel
Raw wastewater is pumped into an oil separator, where it passes through
excelsior,* baffles and a filter. The aqueous phase is pumped at a rate of 90 to
100 gallons per minute as a 50% solution of hydrogen peroxide is injected in-
line. The rate of injection is controlled by a flow sensor. The combined liquids
then pass through a gravity-feed static mixer and into two retention tanks, where
Wood shavings
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55
they have 1 hour of contact time with the hydrogen peroxide. From the retention
tanks, the treated liquids are transferred to aerated Ponds 3 or 10.
The two hydrogen peroxide storage tanks are stainless steel, skid-
mounted tanks and have 14,000-gaiIon and 11,200-gallon capacities. The two
contact tanks are made of polyethylene plastic and hold 3,500 gallons each.
The oil from the separator is picked up with vacuum trucks and put into
Pond M. The used excelsior is landfilied in the Solvents/Pesticides Landfill.
At the time of the NEiC inspection, Casmalia Resources was drying pond
sludges in place and had no designated drying area. The Company was
investigating methods for closing a number of ponds, including what to do with
the sludges. Options included drying the sludges in place and removal. In the
cases of Ponds P and 14, sludges had been dried in place, analyzed and
buried in the appropriate landfill.
Casmalia Resources has an oil recovery process which was not running
during the NEIC inspection reportedly because oil prices were down. The
process had not been operating for about a year. Company personnel stated
that when it was operating, the oil recovered came from non-RCRA Pond A,
which contained crude oil and water.
The oil was skimmed from the surface of the pond with a Brill oil skimmer
and transferred to an oil separator tank. In the tank, the oil (mixed with some
water) was preheated to 175 to 200 °F. and injected with a silicone emulsifier to
separate the water. Water from the process was channeled down a ditch to
Pond S, where it entered the liquids transfer system. Oil was stored in tanks
until it could be shipped or used to build on-site roads.
Two tanks were used in the oil separation process, A small, 200-barrei
(8,400 gallons) tank was used to separate the oil. A larger, 1,000-barrel
(42,000 gallons) tank was used for oil storage. Both contained oil in storage at
the time of the inspection.
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56
Wet-Air-Oxidation
The WAO unit is designed to treat the following aqueous waste: Cyanide
waste, phenolic waste, sulfide waste, pesticides, solvent still-bottoms
wastewaters, general organic wastewaters, and spent carbon/biomass waste
from the proposed PACT unit. Table 11 contains a list of the waste accepted for
treatment listed by EPA waste code. The list comes from a draft report and may
not be complete, but it was the most current information available at the time of
the inspection.
The WAO system has six storage tanks for incoming waste, and unit
equipment consisting of high pressure pumps, feed heat exchanger, air
compressors, hot oil heat exchanger, reactor, cooler and oxidized liquor pumps.
Figure 4 shows a plan view of the WAO unit and storage tanks.
The tanks are segregated by a series of impermeable dikes designed to
hold the entire contents of the tanks 'in case of a spill or leak. The four tanks
east of the WAO are used to store alkaline/organic wastewater. The tanks are
connected to granular activated carbon adsorption beds to control hydrocarbon
vapors that may vent during filling or normal breathing. The other two tanks are
used to store acidic/organic wastewater and are connected to a carbon
absorption bed also. Each of the six tanks is constructed of carbon steel and
has a 15,000-gallon capacity.
The WAO unit equipment is described in Table 12. Most of the unit
equipment is mounted on two prefabricated skids and located in a metal
building. The primary fabrication material for equipment exposed to process
fluids is titanium. The unit has a nominal operating capacity of 10 gpm and is
designed for continuous operation.
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57
Table 11
WASTE ACCEPTED FOR TREATMENT IN THE WET-AIR-OXIDATION AND
NEUTRALIZATION SYSTEM TREATMENT UNITS
Unit
Design
Capacity
(gpm)
Waste Accepted
(EPA Waste Code*)
Wet Air Oxidation
10
Neutralization
40
D001-D017, F007-F012, K009-K011,
K013-K020, K022-K027, K029, K030,
K032, K033, K035, K036, K038, K042,
K043, K047, K060, K086, K093-K099,
K103-K105, P001-P005, P007, P008,
P013, P014, P016-P018, P020-P024,
P026-P030, P034, P037, P039-P051,
P054, P056-P060, P062, P066-P072,
P074, P075, P077, P082, P084, P085,
P088, P089, P093, P094, P097-P099,
P101, P102, P104, P106, P108, P109,
P111, P116, P118, P121, P123.U001-
U005, U007-U012, U014-U028, U030,
U031, U034-U039, U041, U042, U044,
U046-U053, U055-U064, U066-U095,
U097-U099, U101-U114, U116-U133,
U136-U144, U147-U150, U152-U159,
U161-U174, U176-U194, U196, U197,
U200-U203, U206-U211, U214.U218-
U223, U225-U228, U234-U240, U242-
U244, U247, U248
D002, D004-D017, K001-K006, K008,
K021, K060-K062, K084, K086, K100-
K102, P010-P012, P113-P115, P119,
P120, U032, U123, U134, U136, U144-
U146, U151, U204, U205, U214-U217,
U249
See Appendix D for definition of codes
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MIQ
I ol
•v<3
Figure 4
WET-AIR-OXI OATION UNIT SITE PLAN
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59
Table 12
WET-AIR-OXIDATION UNIT EQUIPMENT LIST
Equipment
Number*
Equipment Name
Equipment Description
P-1, A, B, C, D
High pressure pump
Diaphragm pump at 10 HP,
2.5 gpm
C-1A & B
Air compressor
75 HP, 95 SCFM
HX-1
Feed heat exchanger
Double pipe titanium tubes,
titanium shell, ASME coded
HX-2
Hot oil heat exchanger
Double pipe titanium tubes,
carbon steel shell (ASME
coded)
HX-3
Cooler
Double pipe titanium tubes,
carbon steel shell (ASME
coded)
RX-1
Reactor
600 gal. titanium ciadded on
carbon steel (ASME coded
pressure vessel)
P-2A, P-2B
Oxidized liquor pumps
Magnetically coupled centri-
fugal 3/4 HP, 10 gpm
Refer to Figure 5
The WAO process operation is as follows. The wastewater to be treated
is drawn from the storage tanks and raised to system pressure by high pressure
pumps. High pressure air is injected into the wastewater stream from the
process air compressors and the air/wastewater mixture is heated by passing
through a series of heat exchangers. The heated mixture then enters the reactor
where an exothermic oxidation reaction takes place. The oxidation reaction
takes place in the water phase and is contained in a sealed environment.
The hot oxidized mixture is then cooled by passing through a heat
exchanger and the process cooler. The cooled mixture is reduced to
atmospheric pressure and the vapors and wastewater are separated. The
treated wastewater is discharged to Pond E and the vapors are treated by a
two-stage scrubber followed by a carbon absorption unit. The treated vapors
are then vented through a stack to the atmosphere. Figure 5 shows the flow of
wastewater through the WAO process.
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P- 1*. B. C. ft 0
High
Pxnuia
Pump
HX- I
F« «d
Htol
I ichor>g»i
CIA a IB
Ail
Compittior
and Motor
HX - 2
Hoi Oil
H«o1
E achanftr
RX-I
Rtaclar
Hoi Oil
Ballit
HX- 3
Cool«f
p-za a a
O.ldli.d
Liquor
P u m p t
SC-I
Scrubbtf
Sipor olof
sc-z
Sciubbtr
ADS-1
Cot bon
Adiorptio
Unii
(
HX-
«C-
IC-t
orr qai vapor
IflCATMtMI
HOI OIL SYSTCM
rn0M material tnAHsrtn
AND SIOHAGE
TO OISCMAROC AREA
Figure 5
WET-AIR-OXIDATION UNIT PROCESS DIAGRAM
CTj
O
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61
Neutralization System
The recently constructed NS is designed to treat acid, alkaline and heavy
metal containing liquid waste. Waste accepted for treatment in the NS must fall
within the parameters in Table 13. Table 11 contains a list of waste expected to
be treated by EPA waste codes. This list is also in draft form, but was the most
current information available at the time of the inspection. No organic
contaminated waste, California extremely hazardous waste, or waste containing
metal complexing agents, complexed metals or noxious odors are accepted.
Bulk liquid waste is unloaded from tank trucks into storage tanks prior to
treatment. Six 10,000-gallon tanks (three for acid waste and three for alkaline
waste) with separate secondary containment for acid and alkaline tanks are
available for storage.
Treatment is conducted in a computer-controlled continuous flow module
in which the acid and alkaline waste is neutralized and heavy metals
precipitated. Ferrous chloride is added to the process to reduce hexavalent
chromium to trivalent chromium which precipitates from solution. Precipitated
solids are removed from the liquid by centrifugaticn. The dewatered solids are
then landfilled in the heavy metals landfill. The neutralized liquid waste is
discharged into two 20,000-gal'on tanks and then into Pond E surface
impoundment. The unit has a nominal operating capacity of 40 gpm.
PACT Treatment Unit
The proposed powdered activated carbon treatment (PACT) system is a
Zimpro unit that uses a combination of activated carbon and biological
organisms to treat industrial wastewater. The unit is designed to operate
24 hours per day, 7 days per week and treat from 1,000 to 5,000 gallons of
industrial waste water per day.
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Table 13
MAXIMUM CONCENTRATION LIMITS FOR WASTE
TREATED IN THE NEUTRALIZATION SYSTEM
Maximum
Compounds
Concentration
Total chromium
10% (w/w)•
Chromium (VI)
10% (w/w)
Total cadmium
10% (w/w)
Total lead
10% (w/w)
Total nickel
10% (w/w)
Total mercury
20 ppm
Total arsenic
500 ppm
Total selenium
100 ppm
Total thallium
130 ppm
Hydrochloric acid
40% (w/w)
Sulfuric acid
40% (w/w)
Nitric acid
40% (w/w)
Chromic acid
20% (w/w)
Hydrofluoric, fluoboric acids
5% (w/w)
Mixed acids
40% (w/w as sulfuric)
Oils
None
Solvents, organics
1% (v/v)**
Ammonia
10% (w/w)
Sulfide
400 ppm
Tetraethyi lead
200 ppm
Settteable solids
25% (v/v)
PCBs
None
Radioactive constituents
None
Weight/weight
Volume/volume
-------
ACID Figure 6
OR NaOH
POLYELECTROLYTE
pH
CONTROL
NUTRIENTS
115 VAC
115 VAC
115 VAC f*
'FEED
PUMP
FEED FROM
BAKER TANKS
AERATION
TANK
INSTRUMENT
AIR
CLARIFIER
pH
PROBE
BLOWER
460
RECYCLE fl-L-j, f ;
PUMP
TO WAO FEED TANK
EFFLUENT TO
EVAPORATION
POND
TRANSFER
-n PUMP
WASTE
SLUDGE
INSTRUMENT AIR
DRAIN to
EVAPORATION
PQNO i
SCHEMATIC DIAGRAM OF PACT SYSTEM
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65
FINDINGS
WASTE MANAGEMENT PRACTICES
Laboratory Procedures
The on-site laboratory inspection revealed problems that adversely affect
the quality of analytical results generated. Waste characterization and waste
confirmation data generated in the on-site laboratory may be unreliable
because no protocols were in place to ensure the taking of representative
samples prior to testing. The results recorded for pH, ignitability, radioactivity,
acid/base strength, sulfide, cyanide and COD may be unreliable because of
inadequate quality control procedures. The results reported for specific
elemental constituents and halogenated compounds may be unreliable
because of inappropriate analytical techniques. Reliable results are essential
in characterizing waste and in confirming the identity of waste prior to treatment
and disposal.
Casmalia Resources does not follow written protocols to ensure the
taking of representative samples prior to analysis, as required by 40 CFR
265.13(a)(1). No quality control procedures are applied to tests done at the
facility. There are no maintenance or calibration logs kept for most instruments
and tests. For example, there is no documentation that the pH meter, the
Organic Vapor Analyzer (OVA), the flash point apparatus, the Geiger counter, or
the solutions used to determine acid/base strength were standardized. There
are no records to demonstrate that the OVA method of determining ignitability is
comparable to flash point testing. The test strips used in the spot tests for
sulfide and cyanide were not routinely tested for efficacy. In determining COD
and hexavalent chromium using colorimetric methods, the analyst relied upon
the calibration tables that came with the test kits. It is customary to generate
calibration tables using in-house reagents and standards or at a minimum
confirm the values in the kit calibration tables using in-house reagents and
standards. The results of these tests may be unreliable and may have led to the
acceptance of waste outside the operating protocols of the facility.
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66
The techniques used for determining three elemental constituents were
inappropriate and inadequate. The digestion procedure and the instrumental
method used for mercury, arsenic, and selenium were not equivalent to the
methods listed in 40 CFR 261, Appendix III. Mercury should have been
digested in a closed container and analyzed using Cold Vapor Atomic
Absorption, instead it was digested in an open beaker and analyzed using
Flame Atomic Absorption (AA) or Inductively Coupled Plasma (ICP). Arsenic
and selenium should have been digested in accordance with the procedures for
analysis by Gaseous Hydride AA or Graphite Furnace AA instead of by ICP.
The sample preparation technique used in the determination of
halogenated organic compounds was inappropriate and may have resulted in
the facility accepting waste that exceeded the limit of 1,000 mg/Kg for these
compounds. The compounds being determined were volatiles and could have
been lost prior to quantitation as a result of using an extraction technique that
required the sample to be measured onto filter paper and rinsed with solvent in
the open air. The EPA recommended sample preparation technique for
volatiles is purge and trap.
Waste Acceptance Procedures
Casmalia Resources was not in compliance with RCRA regulations for
general waste analysis (40 CFR 265.13) because the Company failed to:
(1) Obtain a detailed chemical and physical analysis for all waste prior to
treatment and/or disposal, (2) determine if each waste received at the facility
matched the identity of the waste specified on the manifest, and (3) always
follow the 1983 Waste Analysis Plan for managing waste. Casmalia Resources
was also not in compliance with RCRA regulations requiring the Company
maintain a written operating record (40 CFR 265.73). The operating record did
not contain the results of all waste analyses and tests. The record also failed to
demonstrate that lab packs and ignitable and reactive waste accepted at the
facility were handled according to RCRA regulations (40 CFR 265.316 and 40
CFR 265.17).
NEIC requested access to waste analysis records (including telephone
memos, Waste Characterization Forms, manifests, weigh tickets, location
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67
papers, Drum Load Worksheets, test results and raw data records) for the three
main categories of waste received at Casmaiia Resources from 1980 to May
1987. The three main categories are:
1. Containerized Solid
2. Bulk So'id
3. Bulk Liquid
The containerized solid waste includes waste in drums and lab packs.
Bulk liquid waste includes liquids received for treatment in the WAO or the NS
as well as liquids discharged to surface impoundments without prior treatment.
The waste stream records were stored alphabetically by generator and
separated according to whether the waste was bulk solid, drum, lab pack,
liquids destined for surface impoundments, WAO or NS waste.
From 1984 to 1986, the waste files of bulk solid waste, accepted by
Casmaiia Resources for disposal, did not contain the results of inspections or
analyses. The only documents found in these files were the manifests and the
location papers. Two loads received May 4, 1987 {manifest numbers 86064813
and 86110154) showed completed Waste Confirmation Visual Check forms.
The waste on manifest number 86064813 showed analytical results of tests
done on the waste prior to its arrival at Casmaiia Resources. No information
was recorded on the other waste prior to its arrival at the facility. The current
WAP states that information will be gathered on the waste prior to its arrival at
the facility and that bulk solid loads will be inspected visually once they arrive at
the facility.
Review of the waste files for containerized solid waste, accepted by
Casmaiia Resources for disposal, shows no records that the facility inspected or
analyzed waste loads to comply with the requirements of the current WAP or
RCRA regulations. The facility has no record of information obtained on the
waste prior to its arrival at the site, though the current WAP states that such
information will be gathered. Although NEIC personnel observed containers
being checked during the inspection, there are no records to demonstrate that
facility personnel opened 10% of the containers to check for free standing liquid
and fullness or to determine if the waste in the container matched the waste on
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the manifest, as required by the current WAP, The files show no record that lab
packs were inspected to determine if the requirements of the WAP and 40 CFR
265.316 were met. The only documents located for containerized waste were
manifests, location papers and Drum Load Worksheets. The Drum Load
Worksheets showed rejected containers but did not indicate how many in a
given load were checked.
An audit of waste files of liquids destined for surface impoundments
(accepted by Casmalia Resources from Northrop Corporation from 1983 to
1987) indicates that the facility did no testing or insufficient testing on waste to
comply with RCRA regulations or its 1983 WAP [Table 14], There were no
records of analyses done (except for one waste stream, manifest number
84021645, 02/28/86, item 10, Table 14) to characterize the waste streams prior
to arrival at the site.
The files show no testing or insufficient testing by Casmalia Resources
for surface impoundment liquid waste accepted at the facility for disposal. At a
minimum, the liquid waste should have been tested for pH, acid/base strength
(if pH <2 or >12) OVA and/or flash point, halogenated organics, sulfide and
cyanide (if pH > 9), radioactivity, appearance, color, odor, and compatibility with
the disposal pond during acceptance testing. None of the waste listed in
Table 14 showed results for radioactivity check, compatibility testing or the
recording of appearance and color. Items 1 through 5, 8, 20 and 21 in the table
showed none of the results for the tests required by the current WAP for waste
confirmation. In the case of waste in items 20 through 22, positive results were
recorded for component spot tests, but the components were not quantitated, as
required by the current WAP.
The files show that ignitable waste was accepted (items 11 through 15, .
Table 14), but there are no records that indicate the waste was handled in
accordance with 40 CFR 265.17(a). The disposal locations for surface
impoundment liquids were not recorded in the waste stream files, so no
assessment could be made as to whether the facility is following the
precautions cited in 40 CFR 265.17 governing the handling of reactive waste.
For example, the files could have shown that the waste was disposed in an
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Table 14 (corn.)
Testine
Weigh
Waste Confirmation
Manifest
Ticket
Date
Waste
Recorded/
Item
Number
Number
Received
Contents Listed on Manifest
Char a
Required*
Requiredc
Comment
17
84014008
51869
06/29/85
Nitric, sulfuric, hydrofluoric acids
No
2/9
1-3, 5,9-13
1.3,4
18
84014143
55819
08/10/85
Nitric, sulfuric, hydrofluoric acids
No
2/9
1-3, 5,9-13
1.3,4
19
84021389
36954
01/11/85
Oil, water, machine coolant
No
219
1,3, 5, 6, 9-13
1,5
20
83085471
17326
02/27/84
Sodium hydroxide, sodium polysulfide,
No
018
1, 3, 5, 9-13
1,6
21
83085486
16888
02/17/84
Sodium hydroxide, sodium polysulfide,
No
0/8
1, 3, 5, 9-13
1,6
22
84021412
38701
01/30/85
Oil, water trichloroethane
No
219
1, 3, 5, 6, 9-13
1,6
a Indicates whether waste stream characterization was recorded prior to arrival of waste on-site,
b Total number of tests recorded of acceptance tests required by WAP
c ' Waste Confirmation Tests (on-site waste load acceptance tests) Comments
1.
pH
1.
Insufficient testing
2.
Acid!base strength (if pll <2 or ph >12)
2.
Ignitable waste
3.
Ignitability - OVA
3.
Methods not cited in WAP
4.
Ignitability - Flash point (if OVA >500 ppm)
4.
pH <2
5.
Halogenated or games - Beilsiein
J.
Halogenated organks >1000 mglkg
6.
Halogenated organks - GC (if Beilsiein = positive)
6.
Sulfide!cyanide positive or Beilsiein positive
7.
Sulfide!cyanide - spot test (if pH >9)
8.
Sulfide!cyanide - quantitative analysis (if spot test = positive)
9.
Radioactivity
10.
Appearance
11.
Color
12.
Odor
13.
Compatibility with disposal pond
O
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An audit of the waste stream files for liquid waste accepted January to
April 1987 for treatment in the neutralization system shows that not all of the
testing required by the current WAP was done. Before agreeing to accept waste
for treatment in the NS, the waste stream should have been tested for flash
point, settleable soiids, pH, elements in the Caiifornia List, specific gravity,
acid/base strength, and sulfide and cyanide. Of the three waste load files
reviewed, none showed test results for all the required tests. The files for waste
in items 1 and 2 in Table 15 showed no test results for flash point; the file for the
waste in item 3 showed no result for settteable solids. Waste loads accepted by
the facility should have been tested for pH, hexavalent chromium, specific
gravity, acid/base strength, and compatibility with waste previously transferred
to the treatment storage tanks. The file for the waste in item 2 showed no
results for hexavalent chromium and no compatibility testing. The presence of
hexavalent chromium at levels greater than 10% (weight/weight) is cause for
rejecting a waste because high levels of hexavalent chromium have a negative
effect on the efficiency of the treatment. The facility is required by RCRA
regulations to take precautions to prevent the unsafe commingling of
incompatible waste (40 CFR 265.17).
Waste Analysis Plan fWAP^ Evaluation
The interim status WAP has an effective date of January 1983. The
California DHS has required Casmalia Resources to submit revisions to the
WAP but these revisions have not yet been approved by DHS and are not part
of the 1983 WAP.
Sections of the WAP, discussing waste stream characterization and
waste load confirmation, are inadequate and unclear. The WAP does not
adequately define the parameters for which all waste loads will be analyzed nor
does it adequately describe the sampling and test methods that will be used in
the analyses, as required by 40 CFR 265.13(b). The 1983 WAP does not define
the visual inspection parameters for solid waste. The criteria that define waste
as suitable for treatment in the WAO and NS units are not stated. The analytical
methods listed in the WAP do not include all of the methods used by the facility
in characterizing and confirming waste and include some methods that are not
equivalent to the methods cited in 40 CFR 261, Appendix III. The WAP does
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Table 15
WASTE LOADS ACCEPTED BY CASMALIA RESOURCES FOR TREATMENT IN TOE NEUTRALIZATION SYSTEM
Weigh Casmalia Testing
Waste Manifest Ticket Date Waste Code Waste Characterization Waste Confirmation
Load Number Number Received Number Generator 1 2 3 4 5 6 7 1 2 3 4 5
1 86082119 85779 01/26/87 3019-1 Draft Systems () x x x x x () xxxxx
2 86105307 89789 04/28/87 3076-1 International () x xxxxx x () x x ()
Light Metals
3 84846962 89545 04/22/87 3093-1 Teledyne x () xxxxx xxxxx
1. Flash point
2. Settleable solids
3. pH
4. Cr (III, VI), Ni, Cd
Pb, /is, Hg, Se, Tl
5. Specific gravity
6. Acid!base strength
7. Sulfide! cyanide
x - Present
() - Not present
Waste Confirmation
1. pH
2. Cr (VI)
3. Specific gravity
4. Acid/base strength
5. Compatibility
CO
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riot address protocols to comply with 40 CFR 265.17 for handling ignitable and
reactive waste. Sections of the WAP discussing waste rejection criteria are
unclear. The WAP does not address the quality control procedures that will be
used to verify the analytical results generated in testing.
The WAP does not define the visual inspection parameters for bulk and
containerized solid waste. The visual inspection could be defined in terms of
physical consistency, size, color, odor and/or phase distribution.
The WAP fails to cite the parameters that define when a waste is
"suitable" for treatment by WAO or the NS. The WAP states the determination is
based on the test results and bench scale processing results, but the
parameters are not defined.
The methods listed in Table 2-1 in the WAP do not include methods used
by generators or Zimpro in producing test data, methods for analyzing specific
acids in waste (used by Casmalia Resources during acceptance testing of some
waste), methods for analyzing the gases generated during WAO treatment, or
sample preparation techniques for elemental and organic constituents. The
sample preparation techniques are an integral part of the analyses and should
be cited in the methods. Analytical methods for solid waste are not addressed
in the WAP.
The WAP does not contain the sampling methods which will be used to
obtain a representative sample of waste to be analyzed. One of the sampling
methods described in Appendix I of 40 CFR 261, or an equivalent method, is
recommended.
The WAP does not address the frequency with which the initial analyses
of waste will be reviewed or repeated. RCRA regulations require review of the
initial analysis to ensure that the analysis is current.
The WAP does not address checking the waste being received for
treatment in the WAO or NS to determine if it matches the waste listed on the
manifest, as required by RCRA regulations. The test results obtained after the
waste arrives at the facility are used for determining pricing and processing
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alternatives. The WAP could outline the procedures that will be followed in
case there are major differences between the acceptance test results and the
results recorded during waste characterization testing for a waste the facility
agreed to accept for treatment.
The ICP methods listed for arsenic, selenium and mercury in the WAP
are not equivalent to RCRA regulatory methods. Arsenic and selenium should
be analyzed using Hydride or Furnace AA and mercury should be analyzed
using Cold Vapor AA.
The testing of liquids destined for direct discharge to surface
impoundments for sulfide and cyanide, only when the pH of the waste is greater
than 9 (as required by the WAP), is inadequate. Casmalia Resources
personnel (responsible for sampling and analyzing waste) knew little about the
characteristics of the waste prior to its delivery at the facility because testing
information generally was not recorded. It is potentially dangerous for the
facility to assume that sulfide and cyanide will not be present when the pH value
is less than 9.
The WAP does not address the procedures that will be followed to
comply with the requirements of 40 CFR 265.17 governing the precautions that
must be taken with ignitable and reactive waste. The WAP should describe
procedures that would ensure ignitable and reactive waste are kept separate
and protected from sources of ignition or reaction.
Sections of the WAP discussing the acceptability of liquid waste are
unclear. Discrepancies exist between the rejection criteria for bulk liquids, the
acceptance tests done on surface impoundment liquids, and the site limitations
on liquids disposed in surface impoundments. These lists should be
coordinated so that the parameters that are under site limitations are analyzed
at the time of acceptance and have defined waste rejection criteria. For
example, the parameter ammonia, listed in the site limitations, is not listed in the
acceptance tests nor in the rejection criteria. The heavy metals listed in the
rejection criteria and the site limitations are not listed in the acceptance tests.
The WAP requires that neutralization system waste be analyzed for organics
prior to arrival at the facility, but not at the time of acceptance. Liquids should be
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checked upon acceptance because levels of organics greater than 1% are
restricted by the treatment process. The compatibility testing listed in the
rejection criteria for WAO liquids is not addressed in the text of the WAP.
The WAP does not address the quality control procedures that will be
used to verify test results. Laboratory quality control procedures are essential
for demonstrating the validity of test results.
Waste Management Units
Landfills
The runon/runoff control systems appeared to meet the requirements of
40 CFR 265.302, based on observations of the condition of the system made in
the field by NEIC personnel and calculations provided by the Company in the
"Existing Landfills" report dated May 1987. The runon/runoff control systems
appeared to be well maintained and unobstructed. Water was conveyed'
around and/or away from the landfills via graded roadways, ditches and
drainages to liquid waste management units. The calculations demonstrated
that the system described could handle water volume resulting from a 24-hour,
25-year storm, as required. Surface impoundments used as collection facilities
for runon and runoff control systems were below freeboard requirements at the
time of the NEIC inspection and were managed to accommodate large volumes
of liquids. NEIC personnel observed that waste placed in the landfills were
covered with soil soon after being deposited to minimize wind dispersal of
potentially harmful waste constituents.
Casmalia Resources was able to locate waste loads within the landfill
and recorded waste locations, as required by 40 CFR 265.309. The Company
surveyed waste locations in each landfill at least two to three times per day
using clearly visible surveyed grid markers and taking two ranges and an
elevation to locate subcells of waste. Coordinates of waste locations were
recorded on the backs of location papers given to the transporter after waste
acceptance and presented to the pit operator at the discharge point.
Coordinates were later logged into a computerized data file.
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The absence of a Company protocol for determining and verifying waste
characteristics of solid loads prior to and during acceptance has resulted in the
Company accepting waste loads at the weigh station that are inappropriate for
the designated landfill. NEIC personnel observed that, at the landfill, a more
thorough visual check of each waste load is done by the pit operator prior to
final acceptance.
The pit operators were responsible for inspecting manifests of incoming
waste loads, inspecting the waste and supervising waste discharge and burial.
The pit operators inspected each load as it was discharged to ensure that the
load matched that described on the manifest. If a discrepancy existed, that load
was subject to refusal at the discretion of the pit operator and/or Casmalia
Resources management (the pit operator remains in radio contact with the
office). For example, NEIC personnel observed the pit operator rejecting one
load of bulk solid waste that contained prohibited free liquids near the bottom of
the load.
Examples of discrepancies between the manifest and the waste load that
the pit operator looked for included, but were not limited to:
Presence of prohibited free liquids in solid waste loads (as
explained above)
Presence of waste types restricted from disposal in the designated
landfill (e.g., acids are not accepted in the Heavy Metals landfill
and are redirected to the Acids landfill; loads of mixed waste types
must be segregated to the extent possible or refused)
Disagreement between the description of the waste on the
manifest and the appearance of the waste. Obvious discrepancies
are either rejected or brought to the attention of the generator by
telephone prior to burial, depending on the circumstances. Once
any questions about the waste load are resolved with the
generator by Casmalia Resources management, the ioad may
either be accepted or rejected.
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In some cases, Casmalia Resources may require special handling of
waste from certain generators if prior loads have caused problems. NEIC
personnel observed one transporter removing all 5-gallon or larger containers
from his load because a prior load from the generator had included containers
of materia! not approved for that landfill. When questioned, the site assistant
manager stated that Casmalia Resources now requires loads from that
generator to be "hand-checked" by the transporter prior to acceptance in the
landfill. Company personnel stated that some contracts have had to be
cancelled because of "bad" (not as described) waste loads.
Surface Impoundments
All earthen dikes did not have a protective cover such as grass, shale or
rock to minimize wind and water erosion to preserve structural integrity, as
required by both 40 CFR 265.223 and the Director's Order. Deficient protective
cover was observed at Ponds 1, 5, 14, 16, 19, B, C, D, E, J, L, M, and P.* The
Director's Order specifically addresses cover requirements for Ponds 1, S, and
M. Slope failure and deep erosion channels were observed on the earthen
dikes at Ponds A-2, A-3, A, B, C, D, L, M and 10.
Freeboard markers required by the Director's Order were present in all
RCRA-regulated surface impoundments except Ponds 14 and P, which were
empty. All but one marker were readable and showed greater than 2 feet of
freeboard in each pond, as required by 40 CFR 265.222. The marker on Pond
D could not be read because accumulated sludges obscured the 2-foot mark.
During the inspection, the Company excavated the sludges from around the
marker, and the resulting fluid levels were below the 2-foot requirement.
Concerns about spraying hazardous constituents into the air were raised
by local citizens during the inspection. NEIC personnel looked for and did not
detect evidence of spraying. Neither the necessary plumbing nor spray nozzles
were evident in the vicinity of the surface impoundments or the evaporation
pads. Liquids transferred to evaporation pads were distributed by gravity flow
Ponds P and 14 had been cleared out and did not contain wastes.
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via both solid and perforated PVC pipe and were allowed to flow across the
pads.
At the time of the NEIC inspection, liquids levels in most of the ponds
were low, and the volume of waste transfers for liquid waste management
purposes was reduced. As mentioned, the hydrogen peroxide treatment system
was not operating because low liquid levels made getting at the aqueous phase
of liquids in the ponds difficult. Regulatory restrictions on the land disposal of
certain hazardous waste, together with restrictions imposed by Santa Barbara
County on liquid waste treatment, have resulted in lower liquid waste volumes
being accepted for disposal. Furthermore, this area of California was
experiencing a dry period. The Company stated that several ponds were slated
for closure, and Company contractors were on-site gathering data to determine
closure alternatives.
During the inspection, NEIC personnel noticed mild petroleum-like odors
in the vicinity of Ponds A, B and C. The odors were not detected further and
downwind from (about 100 yards) these ponds. Mild acid-like odors were
noticeable within the Acids landfill but not several hundred feet downwind from
the landfill. No other odors were noticeable near or downwind from RCRA
waste management units.
Treatment Units
The Zimpro wet-air-oxidation unit which began operation in April 1983
was shut down by order of Santa Barbara County in April 1987. The County
ordered the shutdown because: (1) Atmospheric emissions periodically
exceeded 320 ppm total hydrocarbons (THC), (2) treatment rates periodically
exceeded the permit limitations of 10 gpm, and (3) the facility failed to report all
breakdowns (any condition that results in emissions greater than 320 ppm THC)
in writing within the allowed 7 days.
The Company maintains that the 320 ppm THC limit, which cannot be
exceeded, was originally intended to have a time limit (e.g., 320 ppm THC not to
be exceeded for 1 hour in any 24-hour period) and is unduly restrictive. Excess
THC emissions were averaging about seven incidents per month in the last
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months of operation. The Company also considers the 10 gpm treatment rate
unduly restrictive because it is a nominal design operating rate and the unit
operates more efficiently at higher rates for some waste.
Prior to shutdown in April, the Zimpro unit experienced a significant
malfunction that resulted in a release of white smoke or fumes to the
atmosphere and a temporary shutdown. According to a facility report on the
incident, this malfunction may have been caused by an accumulation of iodine
in the carbon adsorption unit. A final determination of cause was not made
because the unit was ordered out of operation by the County.
The NEIC evaluation of the unit operation and records indicated a
possible problem with stratification of the waste in the storage tanks. Because
the WAO process parameters are dependent upon the amount of organic
material in the waste, the storage tanks are equipped with pumps capable of
mixing tank contents to obtain a homogenous mixture. However, waste mixing
is not complete and process fluctuations can occur as the organic content of the
waste varies. Such fluctuations make the unit more susceptible to incomplete
treatment and/or excessive operating temperatures and emissions.
INTERIM STATUS STANDARDS/DIRECTOR'S ORDER
Security
The site perimeter fencing was inspected on May 20 and 28 and found in
compliance with RCRA security regulations (40 CFR 265.14) during the latter
inspection. The fencing lacked sufficient warning signs to be in compliance at
the time of the May 20 inspection; however, additional signs were placed on the
northwest side of the facility prior to the May 28 inspection to bring the total to 10
signs including one in the area of pond 13 which satisfied the requirements of
both RCRA regulations and the Director's Order. The facility security also
includes maintaining control over entry with a 24-hour guard at the entrance as
required by RCRA regulations.
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Facility Inspection Records
Inspection records for security, surface impoundments, landfills and
treatment units were reviewed for completeness and compliance with 40 CFR
265.15 and the Director's Order. At a minimum the records were checked for:
Date and time of inspection
Name of the inspector
Notation of observations made
Date and nature of any repairs or remedial actions
Except for the WAO unit, the records were reviewed for the period
October 1986 to May 1987. WAO records were reviewed for a longer period of
time because these records were not addressed in the September 26, 1986
Director's Order and are subject to a 3-year holding time [40 CFR 265.15(d)],
The inspection records were organized chronologically and kept at the
on-site facility office. Most of the inspection record forms were developed by
contractors and contained the required information, but provided little space for
documenting observations and the nature of repairs or remedial action.
The most significant deficiencies in the inspection record were missing
records where inspections were either not conducted or the results not
recorded, and incompletely or incorrectly completed records. Specifics of the
inspection records review are discussed below.
Security
The security records were checked for the period of October 1986 to the
middle of May 1987 (32 weeks). The facility inspection schedule required a
weekly check of the perimeter fencing.
Four of the 32 required weekly checks were missing, resulting in a file
that was 12% incomplete. One of the missing weekly checks occurred after the
only week which had two security checks - an indication that the date on one of
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the inspection forms may have been in error. The available records contained
all required data.
Surface Impoundments
The surface impoundments records were checked from October 1986 to
the middle of May 1987. RCRA regulations (40 CFR 265.226) and the Director's
Order called for a daily freeboard inspection and a weekly dike inspection.
Below is a summary of the freeboard and dike inspection records. In
April 1987, the facility began using a new freeboard inspection form that called
for daily inspection and provided for all required information. The summary
shows no missing of deficient records when this new form was used. Those
records indicated as deficient failed to include the time of inspection.
Number of
Number of
Number of
Records
Records
Deficient
Required
in Files
Records
Freeboard Insoection
10/01/86 to 03/31/87
125
19 (15%)
19 (100%)
04/01/87 to 05/19/87
34
34 (100%)
0 (0%)
Dike Inspection
10/01/86 to 05/13/87
32
31 (97%)
0 (0%)
RCRA regulations (40 CFR 265.226) require a freeboard inspection
every operating day. In this case an operating day was any day that the facility
accepted hazardous waste.
Landfills
The landfill records were checked from October 1986 to the middle of
May 1987. The facility inspection schedule includes a daily inspection of the
level in the solvents/pesticides leachate monitoring well (to comply with the
Director's Order) and a weekly check of runon and runoff controls.
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Below is a summary of the monitoring well and runon/runoff inspection
records. Two of the missing runon/runoff weekly checks occurred after weeks
which had two checks. This indicates that the date on the forms may have been
in error and the records could be considered deficient or missing. The available
records did contain all required data.
Number of Number of Number of
Records Records Deficient
Required in Files Records
Well Inspection
10/01/86 to 05/26/87 166 164 (99%) 7 (4%)
Runon/Runoff Inspection
10/01/86 to 05/15/87 32 29 (91%) 0(0%)
Treatment Units
The WAO thermal treatment unit records were checked from January
1986 until April 1987 when the unit was taken out of operation. RCRA
regulations (40 CFR 265.377) require: (1) Instruments related to process and
emission control be monitored every 15 minutes, (2) stack opacity be observed
hourly and (3) process equipment and emergency shutdown controls be
inspected daily.
The WAO process instruments (temperatures, pressures, flow rates, etc.)
are monitored continuously by the unit operator. The stack opacity is monitored
hourly along with a continuous emission monitoring device that measures total
hydrocarbons (THC). No records of opacity monitoring are kept, but process
and THC readings are recorded hourly. The facility inspection schedule does
include a daily check of the emergency alarm system but does not include a
complete process equipment inspection, as required by RCRA regulations.
Twenty-four of the 476 (5%) required inspection records could not be
found. Those records covered the periods September 30, 1986 to October 12,
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1986; November 16, 1986 to November 29, 1986; and December 23, 1986 to
January 4, 1987 when, according to facility personnel, the unit was mostly in
operation.
The inspection forms contained more observation and repair/remedial
action comments than other facility inspection forms, but also contained some
inconsistencies caused by the operators interpreting the forms differently. The
forms did indicate that problems with the unit were corrected.
The neutralization system inspection forms were checked and found to
be in conformance with RCRA regulations (40 CFR 265.403) but no inspection
records were available because the unit was not in full commercial production.
Manifest System/Operating Record
Casmalia Resources does not maintain a copy of manifests for 3 years at
the facility, as required by RCRA regulations (40 CFR 265.71). Manifests are
stored off-site at the Santa Maria office because of a shortage of office space at
the facility. During the inspection, manifests from January 1984 to March 1986
were brought to the facility from the Santa Maria office and made available.
Manifests from April 1986 to the time of the inspection were available in the
Santa Maria office.
The Company does not follow RCRA regulations for handling significant
manifest discrepancies in quantity (40 CFR 265.72). No attempt is made to
resolve discrepancies with the generator or transporter by phone and the
Regional Administrator is not notified of any discrepancies. Rather, the facility
notifies the California DHS of all manifests discrepancies every month. The
generator learns of the discrepancy when billed. As discussed in the Landfill
section above, significant discrepancies in waste type are resolved with the
generator by phone or the load may be rejected.
The following operating records were checked for compliance with RCRA
regulations (40 CFR 265.73) and the Director's Order:
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Description and quantity of hazardous waste received
~ Methods and dates of waste treatment or disposal
Location and quantity of each waste cross-referenced to a man-
ifest number and recorded on a map
• Summary reports of incidents that require implementation of the
contingency plan
Casmalia Resources does not keep a complete written operating record
at the facility, as required by RCRA regulations (40 CFR 265.73). Most waste
tracking records are kept off-site at the Santa Maria office; however, the facility
does have a computer terminal and printer on-site that can produce written
copies of waste tracking records.
The Casmalia Resources computer waste tracking program has data
fields available for waste descriptions, quantities, methods and dates of
treatment or disposal, and location cross-referenced to manifest number
[Appendix F]; however, the Company does not maintain a landfill waste location
map, as required by RCRA regulations (40 CFR 265.309).
The computer waste tracking program files were reviewed for the period
October 1986 to May 1987. Both hard copies and computer entries were
checked for accuracy and adherence to Appendix I (40 CFR 265) requirements.
The most significant deficiency in the files is the lack of correlation between
Hazardous Waste Numbers (HWN) and the landfill where the waste was buried.
For example some waste coded D004 (EP toxicity for arsenic) were shown to
have been in the Solvents/Pesticides landfill instead of the Heavy Metal landfill.
Whether this represented improper disposal or computer coding errors is
unknown.
To assess the correlation between HWNs and landfill disposal location,
two types of computer data runs were made: (1) A list of all the landfills and the
waste (by HWNs) disposed of in the respective landfill, and (2) a list of several
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HWNs and the disposal location for the waste. Below is a summary of these
comparisons.
Total Number
Number of
of Records
Records
Landfill
Dates
Checked
Inconsistent (%)
Caustic
02/09 to 02/13/87
46
6
(13)
Solvent
02/09 to 02/20/87
283
17
(6)
Metals
02/09 to 02/10/87
25
9
(36)
Acid
02/09 to 02/19/87
a_
(6)
Total
404
35
(9)
HWN
D001
01/12 to 01/16/87
02/16 to 02/20/87
232
32
(14)
03/09 to 03/13/87
D002
01/01 to 05/26/87
2,m
500
(18)
Total
3,032
532
(18)
Another deficiency in the files was missing EPA HWNs. A manual check
of the files showed about 15% of the files failed to list an HWN. Although EPA
HWNs are often not provided by the generators, Casmalia Resources laboratory
personnel assign a number from information on the manifest. The HWNs were
listed as missing when the manifests provided enough data about the waste to
indicate it was a listed waste (40 CFR 261) but no HWN was provided. Because
some of the manifests contained only California hazardous or nonhazardous
waste data, the number of files requiring an HWN was less than the number of
files reviewed. The files showed improvement after the first of 1987 when the
facility began emphasizing the use of HWNs. Finally, the files showed the WAO
unit coded as T04 instead of the more descriptive code, T13. Below is a
summary of missing HWNs.
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Number
Number
of Files
Number
of Files
Requiring
of Files
Month
Reviewed
HWN
with HWN
Oct.
10
10
2
Nov.
11
8
4
Dec.
8
8
8
1987
Jan.
20
14
14
Feb.
10
9
9
Mar.
10
10
10
Apr.
10
10
10
May
m
1Q
m
Total
89
79
67
In addition to the RCRA requirements for waste tracking, the Director's.
Order requires the facility to maintain a written record which describes the
location and quantity of all waste moved or transferred from one waste
management unit to another within the facility. The Company maintains a daily
"Liquid Transfer Log" that provides for the requirements of the Director's Order;
however, the log is incomplete because the section for listing the total quantity
of waste transferred has been left blank. The Company may be able to
complete the log because all the information needed to calculate total waste
transferred is known, but the log, in its present state, fails to meet the
requirements of the Order. The solid waste transfer record did not meet the
requirements of the Order because it failed to identify waste or record where
waste was transferred.
The facility files contained about 15 incident reports; however, the only
one that required implementation of the contingency plan occurred in August
1983. Most of the other incidents including a more recent one involving the
WAO unit were reported to EPA and/or DHS,
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Biennial Report
The 1985 biennial report was reviewed for compliance with RCRA
regulations (40 CFR 265.75). The report appeared to be compiled from the
computer data base and contained most of the required information for over
5,500 generators.
The following deficiencies were noted: (1)The report was submitted
March 19, 1986, 18 days after the RCRA deadline of March 1; (2) the report did
not list the waste received by EPA identification number, instead California
waste identification codes were used; and (3) the report failed to show the
method of treatment and/or disposal for each waste type, instead the amount of
waste going to each treatment and disposal unit was listed.
LAND DISPOSAL RESTRICTIONS
Effective November 8, 1986, Sections 3004 and 3005 of RCRA
prohibited the land disposal of RCRA hazardous spent solvent waste F001-
F005. At the time of the inspection, several exemptions to the land disposal ban
were available to treatment, storage and disposal facilities meeting certain
requirements. These exemptions include the following. F001-F005 waste, with
solvent concentrations either initially or treated to be less than or equal to the
Best Demonstrated Available Technology (BDAT) standards when analyzed by
the Toxic Characteristic Leaching Procedure (TCLP), are exempt. The National
Capacity Variance allows land disposal facilities to dispose of specific waste
exempted from the land disposal ban until 1988 if the new landfills or surface
impoundments or expansions of landfills or surface impoundments were in
compliance with the minimum technological requirements under 40 CFR
268.5(h)(2). Facilities could also apply for a case-by-case extension of the
November 8, 1986 deadline if certain conditions were met. A no-migration
petition may be submitted for individual waste and disposal units meeting
stringent requirements.
None of the surface impoundments or landfills being utilized for the
disposal of waste at Casmalia Resources certified to contain less than 1 %
F001-F005 are new or expanded, so 40 CFR 268.5(h)(2) (minimum
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technological requirements) does not apply. None of the surface
impoundments or landfills on-site are double-lined. The Company has not
applied for a case- by -case extension. A no-migration petition has not been
submitted.
Casmalia Resources accepts waste which are restricted and fall under
the National Capacity Variance, specifically those which contain less than 1%
total F001-F005 solvent constituents. Pursuant to 40 CFR 268.7(c), any land
disposal facility accepting such waste must have records of notices from
generators that their waste is exempt from the land disposal restrictions. Some
manifests had handwritten or typed statements that waste contained less than
1% F-series solvents, but did not state that the waste was exempt from land
disposal restrictions. In most cases, there were no supporting data. It was
impossible to tell who had written or typed the statements in many cases.
Examples of such manifests are summarized in Table 16.
Computer printouts of F001-F005 waste, accepted from November 8,
1986 until the inspection date, were obtained. The Waste Analysis Plan in use
at the time of the inspection was reviewed to ensure that provisions were made
for land disposal restrictions (see Waste Analysis Plan section). About 75% of
the manifests corresponding to the printouts were reviewed for more information
about the waste streams accepted for disposal. A printout of waste described
as California waste codes 211-214 was also obtained, and those with a
corresponding EPA waste code of D001 were targeted. The Region IX Land
Disposal Restrictions (LDR) inspection checklist [Appendix G] was also used to
check for compliance.
Many of the manifests had waste streams coded as F-series solvents.
Some had a hand written or typed statement that the materials were virgin,
unspent, off-specification, exceeded shelf-life, etc. If the solvents were not used
or spent, they were actually P- or U-series waste. The statements were
sometimes added to the manifests by Casmalia Resources personnel after a
phone contact with the generator. Some of the waste streams labeled as F001-
F005 were actually corrosive non-RCRA regulated, etc., according to the DOT
description. It was not possible to ascertain what the proper waste codes were
without contacting each generator during the inspection.
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Table 16
SAMPLE OF MANIFESTS WITH INADEQUATELY CHARACTERIZED WASTE STREAMS
Uniform Hazardous
Waste Manifest RCRA/California Waste
Generator Number(s) Provided on Location Paper Comments
Haynes Generating Station
L.A. Dept. of Water and Power
680 Westminster Ave.
Long Beach, CA
CAD000633248
84772415
Empty solvent cans, last contained 1,1,1-trichloroethane,
residue (in roltoff bin)
Visual confirmation form attached, not
completed; disposed of in solvent
landfill
Trexlor Compressor, Inc.
8808 E. Compton Blvd.
Paramount, CA
CAD981 631575
86375216
Oil and water 40%, absorbent 60% F001/222
No waste analysis file found for this
company; no certification found; dis-
posed of in solvent landfill
Los Angeles County
Sheriff Department
11515 S. Colima
Whittier, CA
CAD072781032
86513400
Lab pack, 2 5-gal. cans petroleum distillate (new
material) F0Q2/551
Lab pack (new material), 1 5-gal. can petroleum
distillate, 1 5-petroleum ether, 21-gal. containers
alcohol F002/551
No waste analysis file found for this
facility; no certification found; dis-
posed of in solvent landfill
Olin Hunt Specialty
Products, Inc.
4265 Charier St.
Los Angeles, CA
CAD009552944
85029854
Lab packs (off-spec, surplus organics) 12% formal-
dehyde, 4% methanol, 3% aluminum sulfate, 24%
ammonium thiocyanate F005/131
No waste analysis file found for this
facility; disposed of in solvent landfill
Deutch Co.
Municipal Airport Rd.
Oceanside, CA
CAD009630708
87087529
Waste carbon tetrachloride; outdated virgin material
F001/141
Appears to be miscoded (may be
U211); no certification; disposed of
in solvent landfill
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Table 16 (cont.)
Generator
Harvey's Hotel arid Casino
P.O. Box 128
Stateline, NV
NV0981677305
Uniform Hazardous
Waste Manifest
Numbers)
RCRA/Califomia Waste
Provided on Location Paper
84824323
Diatomaceous earth with less than 1 % perchloro-
ethylene from dry cleaning recovery still F001/351
Comments
No waste analysis file found for this
generator; may be SQG; disposed
of in solvent landfill
Continental Polymers, Inc.
2225 E. Del Amo Blvd.
Compton, CA
DAD030866933
86322415
Mixture of methyl methacrylate ethyl acrylate, steryl
alcohol, stearic acid F001/352
F001/352
No waste analysis file found for this
generator; disposed of in solvent
landfill
County of San Francisco
CAD103717336
Sargent Industries
2533 E. 56th St.
Huntington Park, CA
CAD009577768
Arrow Automotive
Aviation Way
Santa Maria, CA
CAX000062836
Pacific Gas & Elect. Co.
Diablo Canyon Power Plant
Box 56
Avila Beach, CA
CAD077966349
86563023
86563027
85029643
84534806
84534807
86333805
Lab pack containing 2 pints waste carbon tetrachloride;
virgin material F001/331
Lab packs containing virgin isopropanol.photo receptor
polish, silicone fuser oil Xerox, developer, toner, fixer,
absorber and rinse water F001/551
Contaminated soil, approximately 2% oil.trichloroethane
less than 8,000 ppm
F001/211; waste solids, water, waste oil, waste chlor-
inated solvent (solvent content less than 1% per
generator)
Five drums adhesives and absorbent F003/F005/281
F003/F005/281
No waste analysis file found; may be
SQG; disposed of in solvent landfill
No analysis of rinse water; disposed of
solvent landfill
No waste analysis file found on this
company; no waste confirmation
found, no generator certification;
disposed of in solvent landfill
Waste analysis file shows past liquid
loads containing trichloroethylene; no
waste analysis on these drums; dis-
posed of in solvent landfill
Waste analysis file shows past liquid
loads of light industrial liquid less than
10% organic; no analysis on this load;
disposed of in solvent landfill
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Table 16 (cont.)
Uniform Hazardous
Waste Manifest RCRA/California Waste
Generator Number(s) Provided on Location Paper Comments
AAD Disposal
2306 E. 38th St.
Vernon, CA
CAD981414386
AAD Dist. & Dry Cleaning
Service, Inc.
2306 E. 38th St.
Vernon, CA
CAD981397417
86159049
86123721
86123747
86364878
Paper contaminated with less than 1% perchloroethylene,
byproduct of recycled dry cleaning filters F002/351
Waste perchloroethylene solids; byproducts of recycled
dry cleaning waste with less than 1% perchloroethylene
F002/351 (roiloff bin)
No waste analysis file found for this
company; visual waste confirmation
form accompanied 86123721; dis-
posed of in solvent landfill
Waste analysis attached to 86123747;
visual confirmation form completed;
disposed of in solvent landfill
Aerojet General Corporation
Sacramento, CA
CAD000030494
AiResearch Mfg. Col
2525 W. 190th St.
Torrance, Ca
CAD071896336
84692289
84692240
84692226
84692228
84079447
Solid waste and empty containers contaminated with
various chemicals (extensive list) F002/F005/513
200 lbs. phenyene diamine-meta, 120 gal. resin
F001/343
Visual waste confirmation sheet
attached, but not completed; gener-
ator certification on 84692240 only;
84692289 and 84692240 sent to
solvent landfill; 84692226 and
84692228 sent to heavy metals
landfill
No waste analysis file found; disposed
of in solvent landfill
AiResearch Mfg. Co.
20225 S. Western Ave.
Torrance,CA
CAT080010663
84079542
Cement, 1,1,1-trichloroethane F001/331
Note attached - check generator state-
ment on back of white copy; disposed
of in solvent landfill
Hughes Aircraft Co.
6155 El Camino Real
San Diego,CA 92008
CAD084239987
86493498
Virgin residues in original containers F001/331; 1 drum
virgin residue in original container F002/331
List attached to manifest explaining
drum contents; disposed of in solvent
landfill
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Table 16 (cont.)
Generator
Uniform Hazardous
Waste Manifest
Number(s)
RCRA/Caiifornia Waste
Provided on Location Paper
Comments
City of Santa Monica
2500 Michigan Ave.
Santa Monica, CA
CAD981461254
Oil Process Company
5756 Alba Street
Los Angeles, CA
CAD050806850
Electronics Materials Corp.
939 N. Vernon Ave.
Azusa, CA
CAD980814131
85029856
85029781
84637074
Gasoline, 1% F001/611
Filter cake F001/171; F001<1000 ppm per
generator
Aluminum fines and vermiculite F002/411
No waste analysis file found for this
generator; no certification found;
disposed of in solvent landfill
No waste analysis file found for this
generator; disposed of in heavy
metals landfill
No waste analysis, no solvents men-
tioned on the manifest; no certification,
disposed of in heavy metals landfill
VQ
GJ
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An attempt was made to compare EPA waste codes assigned to waste
streams consistently disposed of by generators before and after the land
disposal ban. The comparison was difficult because EPA waste codes were not
utilized before the land disposal ban, and often the only record of a given waste
stream was a manifest showing the DOT description and a California waste
code.*
The acceptance procedure for lab packs is to check the manifests and
any other descriptive papers provided and to reject any drums which are
indicated to include containers of F001-F005 waste. The drums which pass this
paper inspection are sent to the drum loading dock, where about 10% are
visually spot checked to see if the waste appeared to match the manifest
description. A check of the drumload worksheets indicated several instances of
lab packs which were rejected based on the spot check.
The facility does not accept treated F001-F005 waste. Therefore, the
TCLP test is not utilized by the on-site laboratory nor is such an analysis
requested of generators prior to waste acceptance. The records review did not
reveal any instances of generators certifying their waste to be less than BOAT
standards.
The WAO unit was occasionally used to treat waste streams containing
low percentages of some U- or P-Jisted solvents. F-series solvents are not
accepted for treatment because there is no sump or retention capacity to test the
treated effluent to ensure that it meets BDAT standards.
PART B WASTE ANALYSIS PLAN
In January 1.987, Casmaiia Resources submitted a revised, proposed
Part B waste analysis plan (WAP) to DHS and Region IX. The WAP was
submitted in response to the March 1986 EPA Notice of Deficiency (NOD) and
Warning Letter referred to in the Introduction.
California waste codes do not correlate directly to EPA waste codes, so in the absence of
proper waste characterization information, the appropriate EPA waste code couid not
always be identified.
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NEIC has the following comments on the revised Part B WAP.
Additional concerns are outlined in a Notice of Deficiency issued by EPA,
December 31, 1987, to which Casmalia Resources was scheduled to respond
by January 22, 1988.
The revision of the proposed WAP is more complex than the 1983 interim
status WAP. For example, the proposed WAP contains 49 decision flowcharts
which laboratory personnel will use to determine the disposition of any waste
arriving at the facility. The 1983 plan has two. A system of checks and
verification should be considered to assure adherence to the decision
flowcharts.
The Part B WAP does not address how containerized solids will be
accepted. The facility accepts waste at two locations, the drum loading dock for
containerized solids and the weigh station for all other waste. The laboratory
analytical records and computer terminal are all located at the weigh station.
Additional specific concerns include the following:
There is no place on the Waste Characterization Form
[Figure 4-1]* for the generator to describe how the sample was
taken. Without this information the Company does not know if the
sample is representative of the waste.
There is no place on the Waste Stream Prescreening form
[Figure 4-29]" for the EPA hazardous waste number (HWN). The
analysis done by the facility may indicate a different HWN than that
listed by the generator on the Waste Characterization Form. The
HWN should also be included on the Waste Confirmation
Analyses form [Figure 4-58].*
These figures are from the Part B Waste Analysis Plan.
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The WAP does not address the mechanism for comparing the
results of the Waste Confirmation Analysis [Figure 4-58]* and the
Waste Confirmation Visual Checks [Figure 4-37]* with the
expected results listed in the Waste Stream Prescreening
[Figure 4-29].*
The proposed WAP needs to require generators to certify that
restricted waste do not exceed the limits set forth in 40 CFR 268.
The plan should also require generators to certify that no restricted
waste is in laboratory packs.
The proposed WAP does not state how often waste is subject to
testing for cases when the generator has not notified the facility of
a change in the waste.
The analytical methods listed in the proposed plan do not include
all the methods used by off-site laboratories to analyze waste for
treatment in the WAO unit. The plan fails to cite the criteria that
define when a waste is "suitable" for treatment by WAO or NS.
The plan states that the determination is based on the pre-
acceptance tests and bench scale processing results, but the
criteria are not defined.
The statement "depending upon the results of other confirmation
analysis" is used frequently in the flow charts. It leaves a question
as what other confirmation analyses may be needed.
These figures are from the Part B Waste Analysis Plan,
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REFERENCES
1. Report of Investigation and Decision, Health and Safety Code, Section
25149, State of California Health and Welfare Agency, Department of
Heaith Services, January 21, 1987.
2. "Existing Landfills: Design and Operating Information Casmaiia
Resources Hazardous Waste Management Facility Casmaiia, California,
EPA I.D. No. CAD 020748125", Woodward-Clyde Consultants, May
1987; submitted by Casmaiia Resources.
3.
Table 2-1. Description of Waste Management Units, Casmaiia
Resources, DRAFT, no date; submitted to NEIC August 17, 1987.
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APPENDICES
A STATE OF CALIFORNIA, DEPARTMENT OF HEALTH SERVICES
ADMINISTRATIVE ORDER HWCA-84/85-006, SEPTEMBER 26, 1986
B FACILITY PERMITS
C CASMALIA RESOURCES WASTE ANALYSIS PLAN, JANUARY 1983
D RCRA WASTE CODE DEFINITIONS
E CONSENT AGREEMENT AND FINAL ORDER (DOCKET NO. RCRA-09-
84-0026)
F OPERATING RECORD DATA SHEETS
G LAND DISPOSAL RESTRICTIONS (LDR) INSPECTION CHECKLIST
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APPENDIX A
STATE OF CALIFORNIA, DEPARTMENT OF HEALTH SERVICES
ADMINISTRATIVE ORDER HWCA-84/85-006, SEPTEMBER 26, 1986
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A-l
Appendix A
STATE OF CALIFORNIA
HEALTH AND WELFARE AGENCY
DEPARTMENT OF HEALTH SERVICES
In the Matter of
Docket No. HWCA-84/85-006
CASMALIA RESOURCES, LTD.)
)
STIPULATION TO ORDER SPECIFYING
SCHEDULE FOR COMPLIANCE
OR CORRECTION
Respondent
Health & Safety Code
Section 25187
Casmalia Resources, Ltd., (Respondent) and the Department of
Health Services (Department) stipulate to the following items
regarding Administrative Order HWCA-84/85-006 as amended July
1986 (Order).
1. Respondent does not admit any fact or violation alleged
in the Order.
2. Respondent knowingly and intelligently agrees to waive
any right to a hearing prior to the issuance of the Order.
Respondent stipulates to the Department's jurisdiction to issue
the order and to enforce it in any court of competent
jurisdiction.
3. Respondent, in a desire to cooperate to the fullest
practical extent with the Department and to avoid the cost and
disruption attendant to litigation, agrees to comply with all
paragraphs in the Compliance Order in the July 1986 amendment to
the Order.
4. In lieu of the civil penalties of $100,000 assessed in
the original Order Respondent agreed to provide and has provided
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A-2
the County of Santa Barbara with §500,000 for the purpose of
hiring a contractor to perform the Interagency Air Study and
agreed to perform additional air monitoring, valued at $126,000,
using a mobile van in accordance with the Department's instruc-
tions. The first phase of mobile van monitoring has been
completed.( Respondent now agrees to pay the Department $52,000
for fixed air monitoring in lieu of the remaining phase of mobile
van monitoring. The payment shall be made within fifteen days of
the effective date of the Order.
5. The Department agrees to accept Respondent's compliance
with paragraphs 5 and 6 of Part I of the Compliance Order (as
amended July 1986) in lieu of civil penalties for the violations
alleged in the July 1986 amendment to the original Order on
condition that Respondent complies with all provisions of this
Stipulation and the Order.
Director
Department of Health Services
Date
-C /9FC
By Hunter Resources, Inc., its
General Partner
By Ken Hunter, President
-2
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A-3
STATE OF CALIFORNIA
HEALTH AND WELFARE AGENCY
DEPARTMENT OF HEALTH SERVICES
-In the Matter of: )
)
CASMALIA RESOURCES, LTD.)
' - • )
)
)
)
)
)
Respondent
Docket No. HWCA-84/85-006
AMENDMENT TO
DETERMINATION OF VIOLATION
AND COMPLIANCE ORDER
Health & Safety Code
Section 25187
INTRODUCTION
1. This administrative action amends the "Determination of
Violation, Compliance Order and Notice of Right to Request a
Hearing ("Order"), Docket No. HWCA-84/85-006, dated December 17,
»
1984. This amendment is issued pursuant to Section 25187 of the
Health and Safety Code. The complainant is the State Department
of Health Services ("Department") and the Respondent is Casmalia
Resources, Ltd., ("Respondent").
2. The Department has determined, on the basis of new
information available to it since the previous Order, that
• ' t
Respondent has violated certain provisions of the California
Hazardous Waste Control Act ("Act") (Health and Safety Code
Sections 25100 et seg.) and of the rules, regulations and
requirements issued or promulgated pursuant thereto.
/ / /
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II
JURISDICTION
1. The allegations in paragraphs 1, 2, 3# and 4 of Part II
of the original Order are incorporated herein by this reference
as if fully set forth.
'
III
FINDINGS OF FACT
1. The Department conducted a hazardous waste facility
inspection at Respondent's premises on December 12, 1985.
Respondent's facility is located on NTU Road, in northwestern
Santa Barbara County, approximately 2 miles north of Casaalia,
California. The inspection disclosed the following at
Respondent * s facility:
(a) The freeboard level was less than two feet in the
surface impoundments known as Pond 1, Pond V, Pond L and
Pond M;
»
(b) Respondent did not maintain a record of daily
inspection^ of the freeboard level of its surface
4 *
impoundmentsj ' >
(c) Earthen dikes used as a containment system for the
surface impoundments known as Pond 1, Pond S, and Pond M
showed signs of deterioration and erosion and were not
protected with cover to minimize erosion and to preserve
their structural integrity?
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(d) Respondent has not updated its closure plan to
reflect improvements and changes in its operation including
the cessation of spray evaporation and the remedial
treatment of pond liquids for odors.
2. The Department has conducted daily hazardous waste
facility inspections at the Respondent's premises beginning
4 f •
February 27, 1986. These inspections disclosed the following at
the Respondent's facility;
.*(a) On April 9f 10, 11, 14, 15, 17, 21, 23, 28 and 30,
leachate was observed on the ground surface immediately
upgradient of the containment structure located at the base
of the pesticide/solvent landfill. Respondent has failed to
make notations on an inspection log regarding the nature of
the repairs made or remedial measures taken with respect to
this landfill. The remedial measures taken by the
Respondent were insufficient.
3. The Department, the U. S, Environmental Protection
Agency and the Regional Water Quality Control Board conducted an
inspection and evaluation of Respondent's ground water monitoring
program on October 21st through 30th, and November 18th through
21st, 1985. The inspection report disclosed the following at
Respondent's facility: '
(a) Samples taken from Respondent's ground., water
monitoring wells C1B, C6B and Cph indicated a statistically
significant pH increase in comparison to the initial
background arithmetic mean;
/ / /
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(b) Samples taken from Respondent's ground water
monitoring wells A1B, C4M, B5 and A2B . indicated a
statistically significant increase in total organic halogens
(TOX) in comparison to the initial background mean;
(c) Samples taken from Respondent's ground water
monitoring. wells C6B, C1B, C2M, WS4, A2M, C4M, A2B and CpH
indicated the presence of tetrahydrofuran;
(d) Samples taken from Respondent's ground water
monitoring well B3B indicated the presence of
dichloroethane;
(e) Samples taken from Respondent's gallery collection
well C5 indicated the presence of phthalate.
4. Additional work will be necessary before it can be
ietermined whether the source of these contaminants is from well
construction materials and methods, sampling and analysis errors,
sr ground water contamination attributable to the facility.
IV
VIOLATIONS OF LAW
Based on .the foregoing Findings of Fact the Department
alleges that Respondent has violated the Act as tollows:
1. Respondent has violated Section 25159.6 of the_ Health
and Safety Code and 40 CFR 265.222 by failing to maintain two
feet of freeboard in the surface impoundments known as Pond 1,
Pond V, Pond L and Pond H and Respondent has violated Section
25159.6 of the Health and Safety Code and 40 CFR 265.15 (c) and
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40 CFR 265.226 (a) (1) by failing to correct the insufficient
freeboard and ensure compliance with 40 CFR 265.222 at the same
surface impoundments j
2. Respondent has violated Section 25159.6 of the Health
-and Safety Code and 40 CFR 265.15 (d) and Section 67104(d) of
Title 22 of the California Administrative Code by failing to
record daily inspections of the freeboard level of each surface
impoundment and failing to make notations regarding the nature of
the repairs made or remedial measures taken with respect to
leachate from the pesticide/solvent landfill in an inspection log
or summary;
3. Respondent has violated Section 25159.6 of the Health
and Safety Code and 40 CFR 265.223 by failing to provide
protective cover to minimize erosion on the earthen dikes of the
surface impoundments known as Pond 1, Pond S and Pond M;
4. Respondent has violated Section 25159.6 of the Health
and Safety Code and 40 CFR 265.15 (c) and Section 67104(c) of ;
Title 22 of the California Administrative Code by failing to
remedy the deterioration of the earthen dikes at the surface
impoundments known as Pond 1, Fond S and Pond M and the leachate
from the pesticide/solvent landfill on a schedule which ensures
that the problem does not lead to an environmental or human
health hazard; and
5. Respondent has violated Section 25159.6 of the Health
and Safety Code and 40 CFR 265.112 (b) and Section 67212 (c) of
Title 22 of the California Administrative Code "by failing to
amend its closure plan to reflect improvements and changes in its
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operating plans including the cessation of spray evaporation and
the remedial treatment of pond liquids for odors.
COMPLIANCE ORDER
I
SCHEDULE OF COMPLIANCE
This Compliance Order amends and supersedes the provisions of the
Compliance Order dated December 17, 1984. Respondent is hereby
ordered to comply with the following schedule of compliance,
1. Beginning immediately and at all times in the future
Respondent shall maintain no less than two feet of freeboard in
all surface impoundments including those known as Pond 1, Pond V,
Pond L and Pond M. On or before September 30, 1986 Respondent
shall install permanent 'markers at all surface impoundments at
the facility. These markers shall be calibrated and clearly
marked so that facility personnel and government inspectors can
immediately determine the remaining freeboard at each pond by
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means of visual inspection at the pond without the need to refer
to additional data to calibrate the markers. The markers shall
be maintained as necessary to meet the requirement of this
paragraph. '
2. Respondent shall inspect the freeboard level qf each
surface impoundment daily, and shall inspect surface impoundment
dikes for leaks, deterioration and failures at least once weekly.
Respondent shall record the results of each inspection daily in
an inspection log or summary and shall also record daily the date
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and nature of any repairs or other remedial actions taken in such
log or summary.
3. On or before October 30, 1986 Respondent shall remedy
the deterioration of and provide protective cover (such as grass,
-shale or rock) on the earthen dikes of all surface impoundments
including those known as Pond 1, Pond S and Pond H. Respondent
I t
shall thereafter maintain such cover in a manner which prevents
deterioration of the dikes.
4. On or before October 1, 1986 Respondent shall submit to
the Department for review an amended closure plan and closure
cost estimate which reflects all changes in its operating plans
prior to August 15, 1986. On or before November 1, 1986
Respondent shall incorporate into the closure plan and estimate
any comments by the Department and adjust its financial
assurances for closure, if necessary.
5. On or before September 30, 1986 Respondent shall submit
to the Department for review and approval amendments to its
Outline of Groundwater Quality Assessment Program dated August 6,
1984. The amendments shall incorporate appropriate investigatory
responses to the findings of the EPA Groundwater Task Force
Report (July 1986) and shall include procedures to determine the
source of the substances described in paragraph '3 of Part III of
this Order. Within 30 days of receipt of written approval^of the
outline by the Department, Respondent shall submit to the
Department for approval a program based on the amendments to the
Outline. Upon receipt of written approval of the program
Respondent shall immediately implement the program as approved.
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6. a. Respondent shall perform a complete hydrogeological
characterization of the facility (site characterization) and,
unless waived in writing by the Department as provided in
subparagraph (b) of this paragraph, Respondent shall install: (l)
¦an upgraded ground water monitoring system (upgraded well
system); and (2) an unsaturated zone monitoring system based on
the results of this site characterization. The site
characterization, upgraded well system and unsaturated zone
monitoring" system shall be completed in accordance with plans
submitted to and approved by the Department. The site
characterization, upgraded well system and unsaturated zone
monitoring system may be completed in accordance with the
workplans and schedules submitted in response to the March 1986
Notice of Deficiency on the Part B permit application from the
U. S. Environmental Protection Agency provided that (1) such
workplans and schedules have been approved in writing by the
Department; and (2) such workplans and schedules address the
following tasks to the satisfaction of the Department:
(1) All existing monitoring wells are evaluated for
redevelopment or replacement based on the results of the
ground watet assessment program performed under paragraph 5
of this Part and the site characterizatibn; '
(2) Procedures are developed, approved and implemented
which provide statistical methods for evaluation of heavy
metal background concentrations and for determining the
statistical significance of concentration differences among
analytical results for all wells sampled. The procedures
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established shall also take into consideration the results
of the evaluation of existing wells for redevelopment or
replacement described in (1), as well as procedures for
sampling and analysis described in (3) of this paragraph;
(3) An updated Sampling and Analysis Plan which identifies
the procedures currently being used by the facility is
submitted for review and approval;
(4) The degree of hydraulic continuity between the facility
and .nearby ground water basins is investigated;
(5) The effect of the surface impoundments on local
hydrology is investigated;
(6) The effectiveness of the barrier dams in impeding
ground water flow is investigated; and
(7) Additional statistical methods are developed, approved
and implemented to determine when statistically significant
differences occur between background water quality and
downgradient water quality at the facility. .
b. Pursuant to Section 67180 (d) of Title 22 of the California
Administrative Code, the Department may waive the requirements to
install an upgraded well system and an unsaturated zone
monitoring system provided that Respondent demonstrates to the
satisfaction of the Department that hazardous' waste will not
migrate from the facility. Alternatively, the Department may
grant a variance from the requirement to install an unsaturated
zone monitoring system pursuant to Section 67188 (d) if
Respondent demonstrates to the satisfaction of the Department
that an unsaturated zone monitoring system is not needed to
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protect public health or the environment and the other
requirements of that subsection are net. Any waiver or variance
by the Department shall be in writing. Nothing in this paragraph
is intended or shall be construed to limit the authority of the
"State or Regional Water Quality Control Boards to require or
enforce any monitoring systems pursuant to the Porter Cologne
Water Quality Control Act (Section 13000 et. seq., of the Water
Code) and the regulations adopted under that Act.
7. On or before September 30, 1986, Respondent shall
submit to the Department for approval a report of corrective
action taken since April 30, 1986 to remedy the presence of
excess leachate from the pesticide/solvent landfill as described
in paragraph 2 of the Findings of Fact. This plan shall include
a description of the corrective measures taken and a monitoring
program which will ensure that, if excess leachate collects
again, immediate corrective action will be taken to remedy it.
Upon written approval by the Department Respondent shall
implement the measures described and additional measures, if any,
specified by the Department. Respondent shall not dispose of
#
leachate to the landfill.
8. On or.* before September 19, 1986, Respondent shall
submit to the Department for approval a waste analysis plan for
all liquids which will be placed in the surface impoundments
•known as Ponds E and J. The plan shall be sufficent to ensure
that liquids placed in these ponds are appropriately segregated
and meet the requirements of the Department's December 23, 1985
directive. On or before November 15, 1986 Respondent shall
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submit to the Department for approval a waste analysis plan for
all other hazardous wastes received at the facility. Upon
approval of each plan by the Department, Respondent shall
implement the plan as approved.
9. On or before September 30, 1986, Respondent shall
submit a plan and schedule for the sampling and analyses of all
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liquid wastes in surface impoundments which Respondent intends to
spread onto the land, for the purposes of dust control or
evaporation. Upon approval of the plan by the Department
Respondent shall implement the plan as approved.
10. Commencing on or before September 30, 1986 and
continuing thereafter Respondent shall maintain a written
operating record for the disposal, storage and treatment of all
wastes that describes the location and quantity of all wastes
received. Such information shall be directly cross-referenced to
specific manifest numbers in accordance with 40 CFR 265.73 for
all hazardous wastesi In addition, on or before November 15,
1986 Respondent shall maintain a written operating record which
describes the location and quantity of all wastes moved or
transferred from one waste management unit to another within the
facility.
11. On or before September 30, 198-6 Respondent shall
improve the fencing around the facility including the area of
Pond 13 and shall post the perimeter of the facility with at
least five more signs meeting the requirements of Title 22 of the
California Administrative Code Section 67103 (c). At least one of
these signs shall be placed in the area of Pond 13. The fencing
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shall be sufficient to prevent unknowing entry and minimize the
possibility for the unauthorized entry of persons or livestock
onto the active portion of the facility.
12. On or before November 1, 1986 Respondent shall submit
_to the Department a plan and schedule for improving the design,
construction, operation and maintenance of the facility's run on
control system. The plan shall ensure that the run on control
system is, at ail times of the year, capable of preventing flow
on to the* active portion of the landfill during peak discharge
from at least a 24 hour 25 year storm. Upon approval of the plan
by the Department Respondent shall implement it as approved.
II
CIVIL PENALTIES
1. Section 25188 of the Health and Safety Code provides
that any person subject to a schedule for compliance issued
pursuant to Section 25187 of the Health and Safety ^Code, who does
not comply with that schedule shall be subject to a civil penalty
of not more than twenty five thousand dollars (§25,000) for each
day of noncompliance.
• ' f
III
GENERAL PROVISIONS
1. Project Coordinator. Within five calendar days of the
effective date of this Order, Respondent shall submit to the
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Department in writing the name and address of a Project
Coordinator whose responsibilities will be to receive all
notices, comments, approvals and other communications from the
Department to Respondent.
2. Project Engineer/Geologist. The work performed
pursuant to this Order shall be under the direction and
supervision of a qualified professional engineer or a certified
geologist with expertise in hydrogeology. The name and address
of the Project Engineer or Geologist chosen by Respondent shall
be submitted to the Department for approval within five calendar
days of the effective date of this Order.
3. Summary Reports. Respondent shall submit Summary
Reports of its activities under the provisions of this Order in
accordance with the approved schedules and workplans described
under paragraph 6 of 'this Schedule of Compliance and, in
addition, any supplemental reports of its activities as may be
requested by the Department from time to time. Supplemental
reports shall be submitted within fifteen (15) days of the date
of the Department's request.
4. Incorporation of Documents. All plans, schedules,
reports, specifications, and other documents required or
submitted by Respondent pursuant to this Order are, upon written
approval by the Department, incorporated in this Order and shall
i>e implemented by Respondent as approved. Any noncompliance with
such documents shall be a noncompliance with this Order.
Ill
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5. Submittals and Approvals. All submittals and
notifications from Respondent required by this Order shall be
sent simultaneously to:
Mr. Angelo Bellomo, Chief
Southern California Section
Toxic Substances Control Division
107 S. Broadway, Room 7011
, Los Angeles, CA 90012
Kenneth R. Jones, Executive Officer
Regional Water Quality Control Board
Central Coast Region
1102-A Laurel Lane
San Luis Obispo, CA 93401
Philip L. Bobel, Chief
RCRA Programs Branch
U. S. Environmental Protection Agency
Region IX
215 Fremont Street
San Francisco, CA 94105
Dr. Lawrence Hart M.D., Health Officer
Santa Barbara County
300 N. San Antonio Rd.
Santa Barbara,' CA 93110
All approvals and decisions of the Department made regarding
such submittals and notifications shall be communicated to
Respondent in writing by the Section Chief or his designee. No
informal advice, guidance, suggestions or .comments by the
Department regarding reports, plans, specifications, schedules or
any other writing prepared or submitted by or for Respondent
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shall be construed to relieve Respondent of its obligation to
obtain such formal approvals as may be required herein.
6. The Department Review and Approval. If"after review of
any report, plan, schedule, remedial action plan or other
document which Respondent submits for the Department approval
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pursuant to this Order, the Department determines that the
document is not satisfactory and cannot be approved, the
Department may take the following actions;
(a) Hake modifications to the submitted document as
deemed,necessary by the Department to protect public health
and safety or the environment, and approve the document as
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modified? and/or
(b) Return the submitted document to Respondent with
recommended changes. Within a time period specified by the
Department, Respondent shall submit a revised document
incorporating the recommended changes to the Department for
approval. All such approvals by the Department shall be in
writing.
7. Modifications. Respondent may by written request seek
modification, termination or revision of this Order or any
portion of this Order or any program or plan submitted pursuant
to this Order at any time. This Order and any applicable
program, plan, or schedule may be modified, terminated or revised
I
by mutual written agreement of the parties at any time. In
addition, the Department reserves the right to* take additional
enforcement actidn including issuing new or additional Orders as
provided by law. Any modification to .this rOrder shall be
effective upon issuance and deemed Incorporated in this Order.
8. Time Periods. Unless otherwise specified, time periods
begin from the effective date of this Order and "days" means
calendar days. The effective date of this Order is the date of
signature by the Department.
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9. Extension Requests. If, for any reason, Respondent is
unable to perform any activity or submit any document within the
time required under this Order, Respondent may request, in
writing an extension of the time specified. The extension
-request shall include a justification for the delay. All such
requests shall be in advance of the date on which the activity or
document is due.
10. Extension Approvals. If the Department is convinced
that good *cause exists for an extension as set forth in paragraph
9. it will grant the request and specify in writing a new
schedule. Respondent shall comply with the new schedule.
11. Site Access. the Department and/or its authorized
representatives shall have the authority to enter and move freely
about all property at the Facility at all reasonable times for
the purposes of, inter- alia: inspecting records, operations
logs, sampling and analytic data, and contracts related to this
Order; reviewing the progress of Respondent in carrying out the
terms of this Order; conducting such tests as the Department may
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deem necessary; and verifying the data submitted to the
Department by Respondent. Nothing in this para'graph is intended
or shall be construed to limit in any way the right of entry or
inspection that the Department or any other -agency may otherwise
have under law. Department employees and authorized
-representatives will observe reasonable procedures for site
safety developed by the site from time to time.
12. Sampling, Data and Document Availability. Respondent
shall permit the Department and/or its authorized representatives
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to inspect and copy all sampling, testing, monitoring or other
data generated by Respondent or on Respondent's behalf in any way
pertaining to work undertaken pursuant to this Order. Respondent
shall allow duplicate samples to be taken by the Department
and/or its authorized representatives, of any samples collected
by Respondent pursuant to this Order. Respondent shall maintain
a central' depository of the data, reports, and other documents
prepared pursuant to this Order. All data, reports and other
documents .shall be preserved by Respondent for a minimum of six
years after the conclusion of all activities under this Order.
If the Department requests that some or all of these documents be
preserved for a longer period of time, Respondent shall either
comply with that request or deliver the documents to the
Department or permit the Department to copy the documents prior
to destruction.' Respondent shall notify the Department in
writing at least six months prior to destroying any documents
prepared pursuant to this Order.
j 13. Cost Recovery. Failure or refusal of Respondent to
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comply with this Order may make Respondent liable for any
government costs incurred, including those payable from the
Hazardous Substance Account or the Hazardous Substance Cleanup
Fund for any remedial action at the site, .as. provided in Section
25360 of the Health and Safety Code and other applicable
provisions of law. These costs include the Department's direct
costs and the Department's administrative overhead costs in an
amount equal to 10 percent of the reasonable .cost actually
incurred, or five hundred dollars ($500), whichever is greater.
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14. Additional Enforcement Actions. By issuance of this
Order, the Department does not waive any further enforcement
actions.
15. Compliance with Applicable Laws. Respondent shall
carry out this Order in compliance with all applicable local,
State, and Federal requirements, including, but not limited to,
requirements to obtain permits and to assure worker safety.
16* Government Liabilities. The State of California shall
not be liable for any injuries or damages to persons or property
resulting from acts or omissions by Respondent, its officers,
directors, employees, agents, receivers, trustees, sucessors, or
of any persons, including but not limited to, firms,
corporations, subsidiaries, contractors, or consultants- in
carrying out activities pursuant to this Order, nor shall the
State of California be held as party to any contract entered into
by Respondent or its agents in carrying out activities pursuant
to this Order.
: 17. Reservation of Rights. Nothing in this Order is
: f
intended or shall be construed to limit or preclude the
Department from taking any other action authorized by law to
protect the public health and welfare or the environment and
recovering the costs thereof.
18. Severability. The requirements of this Order are
severable, and Respondent shall comply with each and every
provision hereof notwithstanding the effectiveness of any other
provision.
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19- Parties Bound. This Order applies to and is binding
upon Respondent, its owner, operator, and thier successors and
assigns.
It is so ordered this day of
, 1986
<
/
Kenneth W. Kizer, M. IX , M.P.H.
Director
Department of Health Services
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APPENDIX B
FACILITY PERMITS
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:EDERAL PERMITS
Appendix B
Section I,
Section II.
STATE PERMITS
Section I.
Section IA.
Section IB.
Section II.
Section III.
Section IV.
COUNTY PERMITS
Section I
Sect ion 11.
Sect ion III.
Section IV.
Section V.
Section VI.
Environmental Protection Agency:
Hazardous Waste Permit - RCRA
Environmental Protection Agency:
PCB Disposal Permit
California Department of Health Services:
Hazardous Waste Facility Permit
California Department of Health Services:
Hazardous Waste Facility Permit -
Modification for Operation of Zimpro Unit
California Department of Health Services:
Hazardous Waste Facility Permit -
Modification for Operation of Ac id/A1ka1ine
Treatment System
Cali fornia Department of Health Services:
Negative Declaration - lirapro WAO Unit
California Water Resources Control Board:
Waste Discharge Permit
California Sol id Waste Management Board:
Solid Waste Facility Permit
Santa Barbara County Air Pollution Control:
Oil Recovery Permit
Santa Barbara County Air Pollution Control:
Zimpro WAO Unit Permit
Santa Barbara County Health Care Services:
Small Water Systems Permit
County of Santa Barbara
County Dump Permit
County of Santa Barbara
Conditional Use Permits and subsequent County/
Casmalia Resources Agreement
County of Santa Barbara
Negative Declaration - Existing Facility
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APPENDIX C
CASMALIA RESOURCES WASTE ANALYSIS PLAN, JANUARY 1983
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APPENDIX C
C-l
Casmalia
Resources
April 10; 1987
Jane Diamond
U.S. Environmental Protection Agency
Region IX
215 Framont Street, T-2-4
San Francisco, CA 94105
Dear Ms, Diamond:
The enclosed Waste Analysis Plan is being submitted in response to fir. Jeff Zelikson's April 1,
1987 request for the plan currently in use at our facility.
This plan represents the procedures that are presently being used at our facility to comply with
the requirements of 40 CFR 265.13. As mentioned in Mr. Zelikson's letter, we have submitted
proposed Waste Analysis Plans as part of our Part B permit application in November, 1984 and
January, 1987, The latter Waste Analysis Plan submittal was in response to N.O.D, comments ^
received on the November, 1984 submittal.
The most recent Part B Waste Analysis Plan draft submittal is currently being reviewed by the
permitting groups at EPA and California Department of Health Services (DHS). We are working
with these EPA and DHS personnel according to a defined schedule for our entire RCRA Part B
permit application.
We realize that, according to the most recent RCRA guidelines, our Waste Analysis Plan will
require upgrading. In working with the agencies on the approval of our draft Part B Waste
Analysis Plan, we hope to bring our waste analysis program logically and efficiently to the level
of effectiveness acceptable to the regulatory agencies, In discussions with Mark Kemiya,
previously the coordinator of our Part B permit application program, it was indicated that,
following regulatory approval of each section of our Part B application, an implementation
schedule for the approved programs would be decided upon. It is our anticipation that this will
be the case for the upgrading of our Waste Analysis Plan.
If you have any questions regarding the enclosed Waste Analysis Plan, please contact me at the
address below or at (80S)-922-4006.
Sincerely
Patrick J. Canney /
Director of Technical Services
124 W. Carmen Lane. Suite A
Santa Maria. CA 93454
305/922-4006
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C-2
Ms. Jane Diamond 2 f- "11 10, 1987
cc: Steven Lavlnger, DHS
Kenneth Hunter, Jr.
James McBride
Jon Carroll
Clifford Ivey
Nllo L1g1
Wes Lasseter
Don Zardenetta
Chris Rossi
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C-3
CASH ALIA RESOURCES
WASTE ANALYSIS PLAN
TABLE OF CONTENTS
Section Paoe
1.0 PRESCREENING 1
1.1 Prescreening Analyses 4
Wet Air Oxidation Prescreening 4
Neutralization System Prescreening 6
1.2 Acceptability !0
1.3 Shipments With No Advanced Notice 11
2.0 CONFIRMATION 11
2.1 Bulk Liquid Wastes 11
2.2 Bulk and Containerized Solid Wastes 25
2.3 Rejection Criteria 32
3.0 LABORATORY ANALYSES PERFORMED IN SUPPORT OF SITE OPERATIONS 32
3.1 Surface Impoundments 33
3.2 Landfills 33
3.3 Neutralization System 34
3.4 Wet Air Oxidation 36
3.6 Dust Control/Evaporation Water 36
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C-4
CASMALIA RESOURCES
WASTE ANALYSIS PLAN
LIST OF FIGURES
Figure Earn
1-1 Waste Characterization Form 7
1-2 Prescreening Potential Wastes For CasmaMa Resources Wet Air Oxidation 5
1 -3 Wet Air Oxidation Prescreenlng Tests 7
1-4 Prescreening Potential Wastes for Casmalia Resources Neutralization System 8
1-5 Neutralization System Prescreening Tests 9
2-1 California Hazardous Waste Manifest 12
2-2 Sample Label 13
2-3 Laboratory Analysts Data Form 21
2-4 Neutralization System Waste Receiving Form 22
2-5 Wet Air Oxidation Waste Receiving/Processing Form 23
2-6 Waste Refusal Form 24
2-7 Bulk Solid Shipment Visual Inspection Form 26
3-1 Neutralization System Operational Analysis Form 35
3-2 Neutralization System Dewatered Sol ids Analysis 37
3-3 Wet Air Oxidation Operational Analyses Form 36
-------
C-5
CASMALIA RESOURCES
WASTE ANALYSIS PLAN
LIST OF TABLES
Tgfle _ Page.
2-1 Casmalla Resources Analytical Laboratory Methods 17
2-2 Maximum Lab Pack Liquid Volumes 27
2-3 Waste Rejection Criteria 29
-------
WASTE ANALYSIS PLAN
The Waste Analysis Plan at Casmalla Resources Is designed to meet the regulatory
requirements of 40 CFR 270.14 (b)(3) and 40 CFR 264.13 so as to assure the successful and
safe operation of the facility. Its purpose Is to obtain sufficient Information to properly treat
or dispose of all waste shipments accepted at the facility.
The Waste Analysis Plan consists of waste prescreening and shipment confirmation
steps, The prescreening step consists of the notification by the generator of his intent to dispose
of wastes at Casmalla Resources and the development of waste characterization information.
Waste confirmation consists of ensuring that the content of a waste shipment conforms to that
described on the uniform hazardous waste manifest, waste characterization form, or other
description of the waste.
1.0 PRESCREENING
In an effort to assure that all RCRA wastes received at the facility can be successfully
treated or disposed of, a prescreening process Is Included as the first step in the Waste Analysis
Plan. A generator or transporter generally makes a telephone or personal contact with facility
personnel or submits a Waste Characterization Form (WCF)(Figure 1 -1), waste analysis
report, or a sample for consideration before sending the first shipment of RCRA waste to the
facility. In telephone or personal contact situations the physical and chemical characteristics of
the waste are discussed with Casmalla Resources personnel. If more Information is required,
the Casmalla Resources representative will ask that a WCF, detailed chemical analysis, or
sample of the waste be sent to Casmalla Resources for review or analysis.
Casmalla Resources is in the process of developing a system of waste acceptance based
upon the WCF. The WCF provides specific Information about the volume and physical/chemical
characteristics of the waste. The form provides detailed chemical information specifically
relating to the Ignltabllity, reactivity, toxicity and/or corrosivlty of the waste stream. Other
-------
j
C-7
Zp
ap
I Owniic
WAfTK CHARACTKRIZATtOM fORU
P*1A. &di MUST b»OB«p»rt»<»fldWi taw aoBdmpwrW by Wor» wMJ«w«b»eof««jt»»oiof
fraaftntflt or tfh^oaa?.
W«aM OMMnler Company Nam*
Contact
Ganamtinc FacINy A4dr»aa
city
Tranaportaf Company Na/na
Contact
Addraia
CKy
Ganaral D««cnp<>oo oI Waal*
Pnooat* Gkafvawllng Watt*
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Calom* WaaM CaMgory No
Wast* la Ba OaWad in 8ufc 0«v*n« OOme
la Wuh or Art Any of ta Componanta Contidarad {For any Kam etwdnd. kiamity compcnar** ra«poo»**a in nam taction)
Canoaf Suapaa Aflanl Coowlwa Oiidiiar Radioact
-------
C-8
Information, such as whether the waste material Is flammable, explosive, an oxidizer, poison,
radioactive, and/or an etiological agent, 1s also requested.
Casmalla Resources generally accepts three categories of hazardous wastes; bulk solids
(e.g., solid wastes transported In open bed roll-off or dump trucks); containerized solids (e.g.,
solids In barrels, fiber drums, cans, cartons, sacks, and bags); and bulk liquids (e.g., liquids
transported In tank trucks). All solid waste streams which have been approved for acceptance
are disposed of In one of five landfills. Four of these landfills are for RCRA solid wastes (the
acids, caustics, heavy metals, and solvent/pesticides solid waste landfills). The fifth landfill,
the PCB landfill, Is not regulated under RCRA and consequently will not be discussed further in
this section.
Aqueous RCRA waste streams accepted at Casmalla Resources are either: 1) treated by
wet air oxidation; 2) treated by neutralization/metals removal; or 3) placed Into surface
impoundments.
The decision as to which hazardous waste management unit will be used for a particular
waste stream is made by Casmalla Resources' technical staff and is based upon compatibility
considerations as well as treatability test results for the WAO and neutralization systems.
Solid wastes accepted in the acids landfill include materials contaminated with inorganic
and organic acids as well as lab packed acids. Solid wastes accepted In the caustics landfill
include alkaline inorganic and organic contaminated materials as well as lab packs containing
alkaline materials. In addition, sulfide and cyanide containing solids and lab packs are placed in
the caustics landfill because of their compatibility with alkaline materials. Inorganic solid
wastes, including heavy metals, Inorganic sludges, and oxidizers as well as lab packs containing
these materials are accepted In the heavy metals landfill Care 1s taken not to place organic
materials In the heavy metals landfill because of the presence of oxidizers. Solids contaminated
with organic materials such as solvents (unless banned by HSWA), pesticides, oils, paints, or
petroleum products and lab packs containing these materials are placed in the solvent/pesticides
landfill.
Aqueous bulk liquid wastes accepted for wet air oxidation processing include wastewaters
contaminated with cyanides, sulfides, phenols, chlorinated aliphatic compounds, certain
-------
C-9
pesticides, and other oxldlzable organics. Non-water mlsclble organic streams such as solvents
and oils are not treated In the wet air oxidation.
Bulk liquids accepted for treatment In the neutralization system Include acids and
alkalies as well as heavy metal containing acid, alkaline, and neutral wastewaters.
A limited number of bulk liquid wastes are currently accepted for surface impoundment.
As described below, these include weak acids, alkalies, neutral Inorganic contaminated
wastewaters, neutralized inorganic acids and alkalies, and various inorganic brines.
i-i Pre?cr99ninoAnalyse
Waste stream samples sent for prescreem'ng, other than wet air oxidation (WAO) or
neutralization system candidate wastes, are analyzed for parameters discussed in Section 2.0 .
CONFIRMATION.
Wet Air Oxidation Prescreenlna The prescreening process for wastes which appear to
be candidates for WAO is Illustrated in Figure 1 -2. Candidate wastes for WAO are those
containing oxldlzable constituents such e$: cyanides, sulfides, phenols, chlorinated aliphatic
compounds, certain pesticides, end other oxldlzable organics, A two-liter sample of candidate
wastes Is shipped by the generator to Casmalla Resources. One liter of the candidate waste is
then sent to Zlmprc, inc., Rothschild, Wl, manufacturer and operator of the wet air oxidation
unit. Analyses performed on the candidate waste sample Include: chemical oxygen demand
(COD), dissolved organic carbon (DOC), total solids, total ash, soluble fluoride, and specific
components to be oxidized.
If the waste appears to be a suitable candidate for WAO treatment, bench-scale wet air
oxidation Is performed on a sample of the waste stream. Following this oxidation, the offges Is
analyzed for: oxygen, nitrogen, carbon monoxide, carbon dioxide, methane, and total
hydrocarbons. The oxidized liquid is analyzed for: COD, DOC, total solids and ash, pH, soluble
fluoride and chloride, and the specific component to be oxidized. Corrosion rates are also
observed In the bench-scale testing to ensure materials of construction compatibility.
-------
C-10
CamSdate Waste
No
It Waste Suitable for
Bench ScalePretcreening ?
Yes
No
Is Waste Suitable for Processing
in Casmafia Resource* WAO Unit ?
Deivw Was la 13 Sit* lor Treatment
Laboratory Autodave Oxidation
Oflgas AnaJyut:
Ofc .Nj ,CO, COz ,ToWH*<*t>artan, CM 4
Oxkizad WiM Anatytic
COO. DOC, Total Solid*, Ash, pH, Soluble
Fluoride, and Chloride, Specific Component
(Cyantia, Phenols, Sulfide, CWorinatad
Aiphat>c Compounds, Pesticide*)
Ship Two Liter Sample la Catmaka Retouree*
Laboratory tor Watts Arwtfy tit:
COO, DOC, Total Solids, Ash, pH, Soluble
Fluoride. Specific Components (Cyanide,
Phenols, Sulfide, Chlorinated Aliphatic
Compound*, Pesticides).
Figure 1-2 PRESCREENING POTENTIAL WASTES FOR
CASMAllA RESOURCES WET AIR OXIDATION
-------
C-ll
Data generated in the prescreenlng of waste streams for the WAO system are recorded in
the format shown in Figure 1 -3 and are thus entered into the operating record
If, based upon bench-scale WAO testing and analyses, the waste stream is suitable for
WAO treatment, arrangements are made with the generator for delivery of the waste to Casmalia
Resources for treatment
Neutralization System Prescreenlng The neutralization system Is used to neutralize acid
and alkaline waste streams and to remove heavy metals from acid, alkaline, and neutral waste
streams. Neutralization system prescreenlng tests are performed on samples of waste streams
which are considered acid or alkaline or which contain heavy metals restricted from land
disposal by the RCRA Hazardous and Solid Waste Amendments of 1984 (HSWA) or state
regulations. The prescreenlng process for wastes which appear to be candidates for the
neutralization system 1s Illustrated in Figure 1 -4.
If, based on WCF and other Information, a waste stream appears to be a candidate for
neutralization and/or metals removal treatment, a one-liter sample is sent to the Casmalia
Resourecs laboratory for analysis and testing. Analyses are performed for the following: pH,
settleablesolids,chromium, hexavalentchromium, nickel,cadmium, lead, arsenic, mercury,
selenium, thallium, specific gravity, sulfide, cyanide, and acid or alkaline strength. Based upon
these analyses a decision Is made whether to proceed with further testing.
If 8 waste stream appears to be a good candidate for neutralization treatment, a
laboratory study Involving neutralization, metals precipitation, and solids removal is
performed on a sample of the waste stream. During this study, observations are made
concerning the formation of heat and gases or other reactions. The supernatant following solids
removal Is analyzed for the following: pH, settleable solids, chromium, hexavalent chromium,
nickel, cadmium, lead, arsenic, mercury, selenium, and thallium.
Depending upon thess analyses the waste may be determined suitable for processing in
the neutralization system. If so, arrangements would be made with the generator for delivery of
the waste stream for treatment. Data generated in the prescreenlng of waste streams for the
neutralization system are recorded on the form shown in Figure 1 - 5 and are thus entered into
the operating record.
-------
CASUAL IA RESOURCES
WET AIR OXIDATION PRESCREENIN6 TESTS
Generator: ,
Generator Location:
Casmalla Resources Waste Acceptance Number:
Waste Description:
Wet Air Oxidation Test Results:
Oxidized Percent
Rgw Waste Product Reduction
Oxidation Temperature, °C -
Time at Temperature, min.
COD, g/1
02 Used, g/1
iAOD.g/1
DOC, mg/1
pH __
Total Solids, g/1
Total Ash, g/1
Soluble Chloride, mg/1
Soluble Fluoride, mg/1
Specific Gravity
0ffgesCH4, ppm
Offgas THC, ppm
Specific Components:
Sample No.
(1) Autoclave Oxygen Demand: For raw waste = 02 used by 320 °C/90 min,/catalyzed oxidation
For oxldalzed product = 02 used + residual COD
Figure 1-3. WET AIR OXIDATION PRESCREENING TESTS
-------
C -13
Canddais Wat*
Ship Orw-U*r Sample to Casmatia Ftotouroat
Laboratory tor Analysis and Totting
Analyt* for.
pH, SeWeabte Solids, Cr. Cr (VI). Nl. Cd, Pb,
At, Hg, So, 71, Sp®af>c Gravity, Aad'AIkaline
Scraogih, Sulfide, Cyanide, Flashpoint
No
It Watts Suitable lor
Laboratory Preserve ning 7
Yet
Laboratory NeutrafaatiOfVMeialt Removal Test*
Product Tatting:
Heat. Gas Generation, Other Reactions; So&ds
Production; Supernatant pH, SettfeaWa Solids,
Cr, Cf(V\). Ni, Cd, Pb, As, Hg, Se. 71
la Waits Suitable tor Prooeaaing ?
Defivwr Waste to SH» lor Treatment
Figure 1-4 PRESCREENING POTENTIAL WASTES FOR
CASMALIA RESOURCES NEUTRALIZATION SYSTEM
8
-------
CASUAL IA RESOURCES
NEUTRALIZATION SYSTEM PRESCREENIN6 TESTS
Generator: , , , , ,
Casmalia Resources Waste Acceptance No
Waste Description:
Neutralization / Precipitation Test Results:
Sample Pretreatment; ,
Treated Supernatant
Initial Diluted Original Basis
pH
% Settleable Solids
Cr(VI), mg/1
Total Cr, mg/1
Ni, mg/1
Cd, mg/1
Pb, mg/1
As, mg/1
Hg, mg/1
Se, mg/1
Tl, mg/1
Specific Gravity
Normality, eq/1
X Acid or Base
Acid or Base Name
Sulfide: Cbal. ¦ •
Quant,, mg/1
Cyanide: Qua!
Quant., mg/1
Temperature Rise, deg. F.
Flashpoint, deg. F.
Other Analyses: _______
Other Observations (phase changes, gas generation, etc J:
-------
C-15
Acceptability of waste streams for treatment or disposal 1s based upon the waste
rejection criteria discussed in Section 2.3. Wastes will be approved for acceptance unless one
of the criteria listed in Table 2-3 , which forces rejection, Is present or exceeded.
Bulk liquid wastes may be accepted for treatment by neutralization/metals removal or
wet air oxidation as discussed above. Bulk liquid wastes may also be accepted for surface
impoundment. Because of various state restrictions, the only bulk liquid wastes currently
directly surface Impounded at Casmalia Resources include inorganic acid or alkaline wastes,
neutralized inorganic acid or alkaline wastes, or Inorganic brines. These wastes must conform
to the following limitations:
• Organic content, less than 1 percent (v/v)
• pH, greater than 2
• Total arsenic (As), less than 500 mg/1
• Total cadmium (Cd), less than 100 mg/1
• Total hexavalent chromium (Cr-VI), less than 500 mg/1
• Total lead (Pb), less than 500 mg/1
• Total mercury (Hg), less than 20 mg/1
• Total nickel (Ni), less than 134 mg/1
• Total selenium (Se), less than 100 mg/1
• Total thallium (Tl), less than 130 mg/1
• Total cyanide, less than 100 mg/1
• Halogenated organlcs, less than 1000 mg/kg
• PCBs, non-detectable
• Sulfides, less then 400 mg/1
• Phenols, less than 5000 mg/1
• Ammonia, less than 10 SI, (w/v)
-------
C-16
1-3 Shipments With No Advanced Notice
Hazardous waste transporters often bring waste shipments to the site without advance
notification. That is, the generator or transporter has not discussed the waste stream with
Casmalia Resources personnel or submitted a WCF, waste analysis, or sample for prescreemng
as described above. In these cases, the analyses discussed in Section 2.0, CONFIRMATION,
and/or a review of analyses or waste descriptions provided by the generator are performed such
that the wastes* physical and chemical characteristics are known sufficiently to safely treat or
dispose of the waste. If information concerning the waste shipment is incomplete, the generator
may be contacted by telephone for additional information or the shipment may be rejected. The
shipment will also be rejected if, in the analysis of the waste shipment or review of
accompanying documentation (uniform hazardous waste manifest and attachments), any of the
rejection criteria listed in Table 2-3 are exceeded.
2.0 CONFIRMATION
The waste confirmation step consists of ensuring that a waste shipment conforms to the
description on the uniform hazardous waste manifest and to previous or accompanying waste
descriptions or analyses (including the WCF).
Upon arrival of a waste shipment at the Casmalia site, the transporter is required to
provide a copy of the uniform hazardous waste manifest which describes each waste stream.
Figure 2-1 shows the uniform hazardous waste manifest used In California, information
required on the manifest includes details concerning the generator, transporter, designated TSD
facility, waste name (DOT), shipment method, waste quantity, California and EPA waste code
numbers, additional waste descriptions, special handling instructions, and generator's
certification statements.
2.1 Bulk Liould Wastes
All bulk liquid RCRA waste shipments are sampled using a column liquid waste sampler
(C0L1WASA). Samples are placed In 1 OOO-ml wide mouth glass bottles. A sample label as
shown in Figure 2-2 Is affixed to the sample bottle for identification.
-------
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V^^Casmatia
^¦i Resources
WASTE SAMPLE
Sample * __ date:
WASTE DESCRIPTION
GENERATOR'
TRANSPORTER.
TICKET#- MANIFEST#:
ANALYZE FOR' ,
P. O. BOX E, CASMALIA, CA 83429
(805) 937-0449
Figure 2-2. Sample Label
13
-------
C -19
Liquid waste samples are analyzed in Casmalla Resources' site laboratory for (he
following fingerprint parameters:
pH
Titration (if pH greater than 12 or less than 2, except WAO approved
wastes)
Vapor space total hydrocarbons (THCX except WAO approved wastes)
Beilsteins test for halogenated organics (if vapor THC greater than 500
ppm)
Gas chromatographic analysis for halogenated organics (if Beilsteins test
positive)
Flashpoint (if vapor space THC greater than 500 ppm)
Sulfide and cyanide qualitative tests (if pH greater than 9)
Cyanide quantitative analysis (if qualitative test positive, except WAO)
Sulfide quantitative analysis (if qualitative test positive, except WAO)
Compatibility test with pond or tank contents (for wastes to be surface
impounded or treated in the neutralization system)
Radioactivity (all waste loads screened by area radiation detector at
scales; positive radiation levels above background confirmed with
hand held Geiger counter)
Appearance, color, odor
pH pH analyses are performed on liquid wastes to determine if they are acidic or basic
in nature. High or low pH indicates potential for corrosiviiy. In addition, certain reactive
compounds, such as sulfides and cyanides, are frequently present in alkaline waste materials.
Titration Titrations are performed on liquid wastes with pH values greater than 12 or
less than 2 to determine the strength of the acid or alkaline components. This information is of
particular importance for wastes to be treated in the neutralization system.
Vaoor Soace Total Hydrocarbons (THC) THC levels are measured In the vapor space
above liquid waste samples to determine whether the waste may contain volatile organics. High
vapor space THC levels may indicate that the liquid is potentially flammable or contains
chlorinated hydrocarbons.
-------
C-20
Bel Isle ins Test The Beilstelns test is used to determine the presence or absence of
halogenated organlcs, Many halogenated organic compounds are toxic, carcinogenic, or
environmentally persistent. Waste streams are analyzed for halogenated organlcs since state
and federal regulations restrict their land disposal.
Gas Chromatographic (GC) Analysis 6C analyses are performed on bulk liquid wastes if
the presence of halogenated organlcs is suspected. The GC analyses are used to quantify the
levels of halogenated organlcs present and to identify volatile organlcs in the waste which may
indicate that the waste is banned from land disposal by HSWA.
Flashpoint Flashpoint tests are performed on liquid wastes with vapor space THC levels
over 500 ppm to determine whether the waste is classified as flammable. If the flashpoint is
less than 140 deg. f, the waste Is considered flammable.
Sulfide Sulfide containing materials can generate toxic hydrogen sulfide gas (H2S) when
placed in contact with acids. Sulfide analyses are performed to reduce potential harm to human
health and the environment during handling and processing of the waste stream.
Cvanide Cyanide containing materials can be extremely toxic especially when contacted
with acids which can cause the generation of hydrogen cyanide gas (HCN), Cyanide analyses are
performed to reduce the potential to human health and the environment during handling and
processing of the waste stream,
Compatibility Waste shipments received for neutralization system treatment and
surface impoundment are tested for compatibility with the material in the storage tank(s) or
surface impoundment into which the shipment is to be placed, in this test a sample of the waste
shipment Is mixed with 0 sample of the storage tank or surface Impoundment contents.
Observations are made regarding temperature rise, gas or solids formation, phase separation,
and any other Indications of non-compatibility. If the waste shipment Is incompatible with
materials 1n all appropriate and available storage tanks or surface Impoundments, the waste Is
rejected.
1 c
-------
C-21
Radioactivity Radiation levels above background can be present in certain industrial
wastes because of the use of radioactive nuclides and in other materials through natural
concentration processes. Health hazards can result through direct contact or proximity to
radioactive sources or through ingestion of radioactive materials. A11 vehicles entering the
facility are checked for radioactivity by a continuously operated area radiation monitor. A hand
held Geiger counter Is used for verification if the continuous monitor's alarm 1s activated.
Additional analyses performed on wastes delivered for processing in the neutralization
system include: specific gravity, hexavalent chromium, and acid or base normality. These tests
are performed to determine pricing and processing alternatives. Hexavalent chromium and acid
normality analyses are bases for rejection if the hexavalent chromium is greater than 10
percent (w/w) and/or if acid or strength Is greater than the following:
Additional analyses performed on waste shipments delivered for WAO processing Include;
specific gravity and chemical oxygen demand (COD). These analyses are performed to aid in
selecting processing conditions.
The Casmalia Resources site laboratory has the capability of performing the above
analyses as well as others listed in Table 2-1. Information accompanying the waste shipment
(uniform hazardous waste manifest, laboratory analyses, etc.) as well as analytical results
obtained in Casmalia Resources' laboratory are used to determine whether a waste can be
received and where it will be placed on site if accepted. Analyses are recorded on the form
shown In Figure 2-3 and are filed at the facility. Forms used for neutralization and WAO
system confirmation/receiving Information are shown In Figures 2-4 end 2-5, respectively,
tf a waste shipment is refused, a waste refusal report (Figure 2-6) is completed. A copy of this
report is filed with the California Department of Health Services (DHS) Toxic Substances
Control Division, Los Annales f*
hydrochloric acid
32 % (w/w)
sulfuric acid
Nitric acid
Chromic acid
40 %
40 %
20 %
5 %
hydroflouric, flouboric acids
mixed acids
40 % (as sulfuric)
-------
C-22
TajjlB 2-1. CASMALIA RESOURCES ANALYTICAL LABORATORY METHODS
Analysts
Mtrthud
.Description
SW-846 (1)
EPA-600-
4-79-
020(2) APHA (3)
Other
Acid/Alkaline
Normality:
Titration to Phenolphthaleln Endpolnt
Arsenic*.
Barium:
Boron:
Biochemical
Oxygen Demand:
Cadmium:
Calcium:
Chemical Oxygen
Demand:
Chloride:
Chromium:
Chromium:
(hexavalent)
Color:
(qualitative)
Conductance:
(specific)
Copper:
Cyanide:
(qualitative)
Cyanide:
(free)
Inductively Coupled Plasma
Inductively Coupled Plasma
Atom ic Absorption (direct aspiration) 7080
inductively Coupled Plasma
Incubation, Manometric
Inductively Coupled Plasma
Atomic Absorption (direct aspiration) 7130
Inductively Coupled Plasma
Atomic Absorption (direct aspiration)
Closed Reflux, Colorimetric
Ion Selective Electrode
Inductively Coupled Plasma
Atomic Absorption (direct aspiration) 7190
Colorlmetrlc (1,5-diphenylcarbazlde) 7196
Atomic Absorption (chelation-extractlon) 7197
Sensory
Electrode
Inductively Coupled Plasma
Atomic Absorption (direct aspiration)
Chloramine-T, Pyrldine-barbiturlc acid
Color imetric
7210
200.7
200.7
208.1
200.7
200.7
213.1
200.7
215.1
508C
200.7
218.1
218.4
20.
200,7
220.1
305
305
303C
305
305
303A
305
303A
305
303A
312B
303B
205
305
303A
412J
(4)
(4)
(5)
(4)
Cyanide:
(total)
Color imetric after Distillation
335.2
412B
(4)
-------
T*ble 2-1. CASUAL IA RESOURCES ANALYTICAL LABORATORY METHODS
C-23
Reference Method
Analysts
Description
EPA-600-
4-79-
SW-846 (1) 020(2) APHA (3) Oth^r
Flashpoint
Fluoride;
Free Liquids
Halogenated
Organics;
(qualitative)
Halogenated
Organ les;
(quantitative)
Hydrogen
Cyanide;
Hydrogen
Sulfide;
Iron:
Lead:
Magnesium:
Mercaptans:
Mercury:
Methane:
Nickel:
Organ les:
Oxidation/
Reduction
Potential
Pensky Martin (closed cup)
Colorlmetrlc (SPADNS)
Ion Selective Electrode
Paint Filter Test
Copper Hallde Flame Test (Beilstein)
Pecked Column GC/MS
Capillary Column GC/MS
1010
9095
8250
8270
Detector T ube
Portab'e Gold Foil Detector
Detector Tuhj
Inductively Coupled Plasma
Atcmlc Absorption (direct aspiration)
'nductlvely Coupled Plasma
Atomic Absorption (direct aspiration)
Inductively Coupled Plasma
Atomic Absorption (direct aspiration)
Detector T ube
Inductively Coupled Plasma
Colorlmetrlc (dithtzone)
Detector Tube
Inductively Coupled Plasma
Atomic Absorption (direct aspiration)
Packed Column GC/MS
Capillary Column GC/MS
Volatile Solvents-Distillation
Electrode
7420
7520
8250
8270
340,1
340 2
200.7
236.1
200.7
239.1
200.7
242.1
200.7
200.7
249.1
413C
413B
516
305
303A
305
303A
305
303A
305
3208
305
303A
516
(6)
(7)
p.83
(8)
(9)
( 10)
(U)
(12)
(13)
-------
C- 24
Table 2-1. C/vSMALIA RESOURCES ANALYTICAL LABORATORY METHODS
Rcfcrwcg flgttwd
Analysis,,,
Description
Membrane Electrode
Gas Chromatography
Oxygen:
(dissolved)
PCBs:
(qualitative)
Pesticides: Gas Chromatography
Organochlorine, (electron capture detector)
Chlorinated
Phencxy Acid
Organophos-
phate
pH:
Phenols:
Radioactivity:
EPA-600-
4-79-
SW-846(1) 020(2)
8080
808C
Gas Chromatography
(flame thermionic detector)
Electronic pH Meter
Colorlmetrlc (4-aminoantipyrine)
8140
9040
Portable Beta-Gamma Geiger Counter
Area Monitor with Scintillation Gamma Probe
360.
150.1
420.1
APHA (3) Other
42 IF
509A
5098
423
510C
Selenium:
Silver:
Solids:
Specific Gravity:
Sulfide:
(qualitative)
Sulfide:
(quantitative)
Sulfur Dioxide:
Thallium:
Total Hydro-
carbons
inductively Coupled Plasma 200.7
Inductively Coupled Plasma 200.7
Atom ic Absorption (direct aspiration) 7760 272.1
Total (gravimetric) 160.3
Total Dissolved (gravimetric) 160.1
Total Suspended (gravimetric) 160.2
Fixed and Volatile (gravimetric) 160.4
Settleable (Imhoff cone) 160.5
Hydrometer
Lead Acetate Test Paper
Colorlmetrlc (methylene blue) 376.2
Ion Selective Electrode
Detector Tube
inductively Coupled Plasma 200.7
Atomic Absorption (direct aspiration) 7840 279,1
Foxboro Organic Vapor Analyzer
305
305
303A
209A
209B
209C
209D
209E
427
427C
(14)
p.213
(15)
(16)
305
303A
(17)
-------
Table 2-1. CASMALIA RESOURCES ANALYTICAL LABORATORY METHODS
C-25
Reference Method
Analysis
Water
Reactivity:
Description
Addition to Water
EPA-600-
4-79-
SW-846 ( 1) 020(2) APHA(3) Other
( 18)
Zinc;
Inductively Coupled Plasma
Atomic Absorption (direct aspiration) 7950
200.7
289.1
305
303A
(1) U.S. Environmental Protection Agency, "Test Methods for Evaluating Solid Waste*. Physical/Chemical
Methods", SW-846, Second Edition, July, 1982.
<
(2) U.S. Environmental Protection Agency, "Methods for Chemical Analysis of Water and Wastes", EPA-
600/4-79-020; EPA, Cincinnati, OH, Revised March, 1983.
(3) American Public Health Association (APHA), "Standard Methods for the Examination of Water and
Wastewater"; 16th Edition, APHA, Washington, D.C., 1985
(4) Hach Chemical Co., "Was tew aster Analysis Handbook"; Hach Chemical Co., Loveland, CO, 1978.
(5) Orion Research, "Instruction Manual: Chloride Electrode"; Orion Research, 1982.
(6) American Society of Testing Materials, "Petroleum Products and Lubricants (1); D56-D1600"; Method
D93-80.ASTM.2i. 39, 1981.
(7) Feiol, Fritz, Soot Tests 1n Organic Analysis. Elsevier Publishing Co.. I960
(8) Draeger Tube, Hydrogen Cyanide, Instruction Manual
(9) Jerome Instrument Corp., Gold Film Hydrogen Sulfide Analyzer, Model 621, Instruction Manual.
{10) Draeger Tube, Hydrogen Sulfide, Instruction Manual
(11) Drager Tube, Mercaptans, Instruction Manual
(12) Draeger Tube, Methane, Instruction Manual
(13) American Society of Testing Materials, "Petroleum Products and Lubricants (1): D56-D1600";
Method D-86-78, ASTM,££, 8, 1981.
(14) Jungrels, Ervln. Soot Test Analysis: Clinical. Environmental. Forensic. andOeochemlca! Applications.
Wiley-interscience Publications, New York, 1985.
(15) Orion Research, "Instruction Manual: Sulfide Electrode"; Orion Research, 1980.
(16) Draeger Tube, Sulfur Dioxide, Instruction Manual.
(17) Foxboro Co., OVA 128 Century Organic Vapor Analyzer, Instruction Manual.
(18) State of California, Division of Occupational Safety and Health, Department of Industrial Relations;
"HAZCAT: A System of Field Identification and Classification of Commonly Spilled Materials";
September, 1986.
-------
C-26
Date
Manifest #
Ticket # _
Generator
City _____
TESTED:
pH
CN/Sul
VOA
BeiIstein
G. C. Analysis
Flashpoint
Distillation
Phenols
Odor
% Solids
Analyst
Accepted Price
Impoundment
Refused due to
Treatment
K.A.N.
S.G.
Quan
OTHER:
COMMENTS
Normal ity
% as acid
I as base
Figure 2-3. Laboratory Analysis Data Form
01
-------
CASH ALIA NEUTRALIZATION SYSTEM
WASTE RECEIVIN6 FORM
C-27
Generator:
Generator Location:
Casmalla Resources Waste Acceptance No.
Waste Name:
Load Number:
Date Received:
Ticket No
Manifest No. _
Transporter:
Gross Weight:
Tare Weight;
Net Weight:
It)
,1b
.lb
Lab Analysis (In addition to routine confirmation analyses): Initials:
pH
Specific Gravity
Cr (VI), ppm
Other:
Acid / Base Normality, eq/1
Percent Add / Base
.As:.
Compatibility Test:
Mixed with Sample from Tank No. _
Observations:
Temperature, deg. F, Before:
Gas Formation:
Solids Formation:
Phase Separation:
Com ments:
Initials:
After:
Discharged to: Tank No
Initial Volume, gal. _____
Initial Temperature, deg. F.
Processing Record:
initials:
final Volume, gal.
Final Temperature, deg. F.
Date Processed:
log book page:
Comments:
Figure 2-4. NEUTRALIZATION SYSTEM WASTE RECEIVING FORM
-------
C-28
WET AIR OXIDATION PROCESS
WASTE RECEIPT/P RQCESSI HO RECQR&
Generator:
Generator Location:
Gasmalia Resources Waste Acceptance No
Waste Name: toad Number:
Type of Waste: Cyanide Sulflde/liercaptan Pesticide
Phenolic Solvent Still Bottom General Organic
Date Received: Transporter: _
TIcket No Gross Weight: lb
Manifest No. Tare Weight: lb
Net Weight: ' lb
Lab Analysis (in addition to routine confirmation analyses): initials:
pH COD.g/l
Specific Gravity
Other:
Discharged to: Tank No Initials:
Inital Volume: Final Volume: _____
Processing Record:
Date Processed: Log book page; Comments:
Figure 2-5. WET AIR OXIDATION WASTE RFmviKirs/DDnrrccmo
-------
C-29
WASTF REFUSAL REPORT
Date:
i
Time:
Transporter:
License Plate Number: Tractor:
Trailer:
Generator:
Waste Description: (See attached manifest copy)
Description of waste sampling procedures and sample preservation if load
was sampled:
Tests performed:
Reason(s) for rejection of load:
Figure 2-6. WASTE REFUSAL FORM
OA
-------
C-30
2.2 Bulk and Containerized Solid Wastes
Bulk and containerized solid waste shipments (Including lab packs) are not typically
sampled. Bulk solid shipments are visually Inspected for the Items listed on the form shown in
Figure 2-1. Completed Inspection forms are filed In the facility's Santa Maria office.
Casmalia Resources requires generators to provide sufficient physical/chemical
information concerning bulk or containerized solid waste shipments for acceptance decisions and
safe handling and disposal. Physical/chemical Information supplied by the generator on the
uniform hazardous waste manifest or attachments to the manifest are reviewed by Casmalia
Resources' technical staff, if, based upon this review, the waste shipment (or Individual
containers on a containerized shipment) contains materials which cannot be accepted, the
shipment (or individual container) is refused.
For each lab pack container shipped to the facility, the generator 1s required to supply a
detailed inventory specifying the name and quantity of each chemical substance contained within
the overpack container. Generators are required to package lab packs in conformance with the
requirements of 40 CFR 264.316. Hazardous waste must be packaged 1n non-leaking inside
containers. The inside containers must be of a material that win not react dangerously with, be
decomposed by, or be ignited by the contained waste. Inside containers must be over packed in an
open head DOT-speciflcation metal shipping container of no more than 416-liter (110 gallon)
capacity and surrounded by, at a minimum, a sufficient quantity of absorbent material to
completely absorb all of the liquid contents of the inside containers. Table 2-2 lists maximum
liquid volumes found to be acceptable for various outside container sizes, assuming the
remainder of the container 1s filled with absorbent material. The metal outer container must be
at least 90 percent full after packing with Inside containers and ebsorbant material. The
absorbent material must not be capable of reacting dangerously with, being decomposed by, or
being ignited by the contents of the Inside containers, e.g., vermlculite must not be used with
hydroflourlc acid, sawdust must not be used with oxidizing acids. Reactive wastes, other than
cyanide or sulflde-bearlng wastes, are not accepted for disposal.
Lab packs containing Incompatible materials are not accepted for disposal. In addition,
only those materials acceptable in a single landfill may be packed within a single drum, if the
-------
CASMALIA RESOURCES
WASTE CONFIRMATION
VISUAL CHECKS
Dote: Manifest No Ticket No.
Generator:
Transporter:
Shipment Method:
Yacuum Tank 0 Dump Truck 0 Rolloff Bin(s) 0 Other
Containerized; Flatbed 0 Van 0 Pickup 0 nthfir
Labels & Placards: Match Manifest 0 Do Hot Match Manifest 0
Free Standing Liquids: Present 0 Absent 0
Appearance: Matches WCF, Manifest 0 Does Not Match WCF, Manifest 0
Visible Restricted Waste: Present ~ Absent D
Irregularities. Other Comments:
Visual Inspection OK ~
Rejected 0
Checked By:
Figure 2-7. BULK SOLID SHIPMENT VISUAL INSPECTION FORM
-------
C-32
Table 2-2. MAXIMUM LAB PACK LIQUID VOLUMES
Maximum
Drum Size Liquid Volume
85.0 Gal Ion
30.0
Gal Ion
80.0 Gallon
29.0
Gallon
75.0 Gallon
27.0
Gal Ion
70.0 Gallon
25.0
Gal Ion
65.0 Gallon
24.0
Gal Ion
60.0 Gallon
22.0
Gallon
55.0 Gallon
20.0
Gallon
50.0 Gallon
18.0
Gallon
45.0 Gallon
16.0
Gallon
40.0 Gallon
15.0
Gallon
35.0 Gal Ion
13.0
Gallon
30.0 Gallon
11.0
Gallon
25.0 Gallon
9.0
Gallon
20.0 Gallon
7,0
Gal Ion
15.0 Gallon
5.0
Gal Ion
10.0 Gallon
3.5
Gallon
5.0 Gallon
2.0
Gal Ion
27
-------
C-33
lab pack contains a material which Is not compatible In the landfill being considered, another
landfill 1s considered or the lab pack is rejected.
If Insufficient Information concerning the physical /chemical characteristics of any
waste shipment is provided, Casmalla Resources' technical personnel may contact the generator
or transporter for additional information. If satisfactory additional information is provided, it
will be added to the manifest along with the name of the person providing the information.
Alternatively, waste shipments with insufficient physical/chemical information may simply be
refused, especially If attempts to gain more Information have been unsuccessful. As with
refusals of bulk liquid wastes, a refusal report is completed for bulk and containerized solid
waste shipments which are refused.
For bulk and containerized solid waste shipments which can be accepted, the
physical/chemical information provided by the generator Is used by the technical staff to
determine in which landfill the waste will be placed. Photocopies of manifests are coded by the
technical staff to indicate where bulk solid shipments or Individual containers on containerized
solids shipments are to be placed. These "location papers" are given to the transporter who
proceeds to a specific landfill or loading dock as Instructed by the welghmaster on duty. The
transporter gives the location papers to Casmalla Resources field personnel in the landfill area.
For bulk solids loads the Casmalla Resources personnel direct the driver to the proper area of
the designated landfill. For containerized solids the Casmalla Resources field personnel match
each container to the listed containers on the location papers generated by the technical staff,
thus ensuring that the Individual containers screened by the technical staff can be identified on
the shipment and that the correct number of containers is received.
The Casmalla Resources field personnel open approximately 10 percent of the containers
to check for free standing liquids and determine whether the appearance of the waste matches the
descriptions on the uniform hazardous waste manifest or attachments. Containers are checked
for free standing liquids by stabbing the contents with a 3/4-inch diameter PVC pipe. If free
liquids are observed draining from the pipe, free standing liquids are considered present. The
"paint filter test" Is used In some cases to confirm the presence of free liquids. Containers with
free standing liquids may, at the option of Casmalla Resources' field personnel, be refused or
"solidified" with absorbent material. If drums to be refused are leaking, they are over packed in
recovery drums with absorbent material prior to leaving the facility.
-------
C-34
Table 2-3 WASTE REJECTION CRITERIA
Parameter or Observation
Bulk Solids:
Free Liquids
(Paint filter test)
Segregation or
waste mixture
California Extremely
Hazardous waste
Organic peroxides
Explosives
Pyrophoric
materials
Pressurized gas
cylinders
Empty tanks,
drums, vessels
Radioactivity
Water reactive
Picric acid
Wastes restricted from
land disposal by HSWA
Absorbed bulk
liquids
Odors
Hazardous waste
manifest
Rtlectifffi Criteria
Presence
(failure of paint filter test)
incompatible
No Extremely Hazardous
Permit
Presence; WCF, manifest, or analyses
Presence; WCF, manifest, or analyses
Presence; WCF, manifest, or analyses
Presence; WCF. manifest, visual
observation
Not cut up, crushed,
or filled
Above background
Presence; WCF. manifest, or analyses
Presence; WCF, manifest, or analyses
Presence; WCF, manifest, or analyses
Presence; WCF, manifest, or analyses
Too odorous
improperly or insufficiently
completed
-------
Table 2-3. WASTE REJECTION CRITERIA
Parameter or Observation
Re lection Criteria
Containerized Solids:
Free Liquids
(Paint niter test)
Segregation or
waste mixture
Presence
(Failure of paint filter test)
Incompatible
California Extremely
Hazardous waste
No Extremely Hazardous
Permit
Organic peroxides
Explosives
Pyrophoric
materials
Pressurized gas
cylinders
Radioactivity
Water reactive
Ptcric acid
Wastes restricted from
land disposal by HSWA
Container void space
Hazardous waste
manifest
lab pack packaging
Presence; WCf, manifest, or analyses
Presence; WCF, manifest, or analyses
Presence; WCF, manifest, or analyses
Presence; WCF, manifest, visual
observation
Above background
Presence; WCF, manifest, or analyses
(unless strong acid/base)
Presence; WCF, manifest, or analyses
Presence; WCF, manifest, or analyses
Less than 90 8 full.
Improperly or insufficiently
completed
Improper Inside container. Non-metal
outside container. Outside container
over 1 <0 gallons. Too much liquid per
container. Incompatible absorbent.
Incompatible combination of wastes.
Insufficient Information.
Container labellm
IrwtrfflHunl * rannnt h« matrHori
-------
C-36
mie 2-3. WASTE REJECTION CRITERIA
Parameter or Observation
Bulk Liquids:
pH
Cyanide
Sulfide
Flashpoint
Water Reactivity
Heavy Metals
HalcxjenataJ Organlcs
PCBs
Phenols
RadloaciUvlty
Compatibility with WAO
or neutralization storage
t«* contents
Relwtton Criteria
l 2 (unless approved for Neutralization)
System or WAO)
i tOO ppm (unless approved for WAO)
i 400 ppm (unless approved for WAO)
<
i 140 deg. F. for Neutralization System
* 140 deg. F, and > 10 8 volatile
solvents for Surface Impoundment
Presence; WCF, manifest, or analyses
(unless strong acid/base approved for
Neutralization System or WAO)
1500 ppm As
i 100 ppm Cd
1500 ppm CrtVI)
1500 ppm Pb (unless approved for
120 ppm Hg Neutralization System
i 134 ppm Ni
1 100 ppm Se
2 130 ppm T1
2 1000 ppm (unless approved for WAO)
Presence; WCF, manifest, or analyses
2 5000 ppm (unless approved for WAO)
Presence; WCF, manifest, or analyses
Smoke, gas, fumes, fire, or other violent
reaction; excessive heat not explained
by strong acid or base
31
-------
C-37
2.3 Rejection Criteria
Criteria for the rejection of a waste stream or waste shipment are listed In Table 2-3.
A waste stream may be determined to be unacceptable at the prescreening stage based upon
Information supplied by the generator or upon data developed in prescreening analyses. In this
case, the waste stream is not approved for delivery and waste shipment to the site should not
occur.
A waste shipment may be rejected at the site based upon confirmation analysis results or
upon information listed on the manifest or accompanying the manifest. As indicated in Table
2-3, an improperly or insufficiently completed manifest may also lead to rejection of a waste
shipment. This criterion includes such items as: Improper or insufficient generator or
transporter information, Improper or Insufficient waste description, wrong waste code
number, incorrect designated facility, etc. In cases in which the manifest appears to be
improperly completed, attempts may be made to contact the generator or transporter to resolve
the problem. The manifest may be corrected per the authority of the generator or transporter.
The modifications made to the manifest and the name of the Individual representing the generator
or transporter who has authorized the modifications are listed on the manifest under Item 15,
Special Handling Instructions and Additional Information or Item 19, Discrepancy Indication
Space.
As discussed previously, If a waste shipment is rejected at the disposal site, a waste
refusal report (Figure 2-6) Is completed and placed In the operating record. A copy of the
waste refusal report is sent to the California Department of Health Services, Toxic Substances
Control Division.
3.0 LABORATORY ANALYSES PERFORMED IN SUPPORT OF SITE OPERATIONS
In addition to the prescreening and confirmation analyses described in Sections l .0 and
2.0, respectively, the site laboratory performs various analyses in support of site operations.
These analyses include specialized non-routine surveys of hazardous waste management units,
monitoring of treatment process performance, and monitoring performed at the directives of
local agencies. These analyses are described below.
-------
C-38
3.1 Surface Impoundments
The site laboratory Is equipped to perform a wide variety of analyses on surface
Impoundment waters. These analyses Include those described above for the prescreenlng end
confirmation of wastes as well as the following:
dissolved oxygen
temperature
oxidation-reduction potential
total, dissolved, and suspended solids and ash
specific conductance
Analyses of surface impoundment water are performed to assess the condition of the
impoundments (aerobic, anaerobic, etc.) and to identify contaminants present which might be of
concern. Casmalta Resources, from time to time, is directed to perform such analyses by local
or state agencies.
Air quality in the vicinity of the surface impoundments can be assessed through the
following analyses;
total hydrocarbons
methane
hydrogen sulfide
sulfur dioxide
hydrogen cyanide
mer cap tans
3.2 Landfills
Landfill leachates may, from time to time or at the direction of local or state agencies, be
analyzed for any of the parameters listed for prescreenlng and confirmation analyses of waste as
well as those paramters listed above for the analysis of surface impoundment watsr, Air quality
in individual landfill areas can be assessed by analysis for the parameters listed above for
surface impoundment air quality.
-------
C-39
3.3 Neutralization System
In addition to the analyses discussed previously regarding the prescreening and
confirmation of waste streams for the neutralization system, certain other analyses are
performed to support the operation of this system.
Prior to the processing of Individual acid or alkaline storage tank contents, the acid or
alkaline strength of the waste is measured. These analyses are required to set operating
conditions for the treatment system. The data form used in these analyses and entered into the
operating record is shown in Figure 3-1.
Liquid effluent from the neutralization system Is stored in tanks until analyses of the .
effluent have verified that the treated liquid can be discharged to surface Impoundments.
Analyses are performed for pH and the following metals to determine whether the liquid is
restricted from land disposal by HSWA or state restrictions:
arsenic
cadmium
chromium (V!)
lead
mercury
nickel
selenium
thallium
These data are also entered on the form shown in Figure 3-1.
The neutralization system generates a solid sludge through dewaterlng of precipitated
metal hydroxides. Each bin of dewatered sludge is tested for free liquids prior to landfilllng. If
the sludge contains free liquids, the liquids are solidified using approved solidification
procedures and the sludge Is re-tested for free liquids. Sludges which have passed the free
liquids test are landfilled in the heavy metals landfill. As with ell landfllled waste shipments at
Casmalla Resources, three dimensional burial coordinates are recorded prior to burial. The
-------
C-40
CAS n All A RESOURCES
NEUTRALIZATION SYSTEM
TANK ANALYSIS
Date: _____ Time:
Tank Area;
Acid ~
Alkaline Q
LimeO
Reducing Agent ~
•EffluentQ
Diversion^
Tank No.
~~~
~~~
t-ilD
T-IFCQ
T-1EO
T-2EO
t-idq
Lab Analysis:
pH
Specific Gravity
Normality, eq/1
Acid Strength, es H2SCM, x
Base Strength, as NaOH, %
Settleable Solids, % (v/v)
Or (VI), mg/1
Total Cr, mg/1
N1, mg/1
Cd, mg/1
Pb, mg/1
As, mg/1
Hg, mg/1
Se, mg/1
Tl, mg/1
Other:
J
* Composite Sample of Effluent Tank input
Figure 3-1. NEUTRALIZATION SYSTEM OPERATIONAL ANALYSES FORM
-------
C-41
data form shown Sn Figure 3-2 Is used to enter the free liquids and burial coordinate
information into the operating record for each bin of dewatered sludge generated by the
neutralization system.
3.4 Wet Air Oxidation
In addition to the analyses discussed previously for the prescreening and confirmation of
waste streams for the wet air oxidation system, Casmalta Resources is In the process of
developing a program for monitoring the efficiency of the process.
On a daily basis at random times the liquid feed and effluent of the wet air oxidation
system will be sampled. Chemical oxygen demand (COD) and phi analyses as well as analyses for
the contaminants present in the waste being treated, e.g. cyanide, sulfide, etc., are performed on
these samples, information concerning the waste being processed and operating conditions at the
time of sampling is collected. Analytical data and processing information are recorded on the
data form shown in Figure 3-3 and are thus entered into the operating record.
3.6 Dust Control I Evaporation Water
Elimination of rainwater runoff and received wastewaters Is accomplished through
evaporation directly from pond and evaporation pad surfaces, the use of emitters for
irrigation/evaporation on certain embankments, and through spreading of water on site roads
for dust control and evaporation. Water spread on site roads for dust control and evaporation is
taken from pond A-3. Water is pumped to irrigation/evaporation emitters from pond 18 and
gallery wells B5 and C5. Water Is distributed to evaporation pads from ponds 6, 10, and 18.
In order to assess the potential for volatilization of organic materials during evaporation
of water on site, analyses are performed on water from the above source ponds. (Water pumped
to emitters from gallery wells B5 and C5 are not included since these wells are sampled in
Casmalla Resources' groundwater monitoring program and have been shown to be of consistent
high quality). On a bi-monthly basis, samples are taken from pons A-3,6, 10, and 18. These
samples are taken in septum vials suitable for analysis of purgeable organics and are
refrigerated during shipment and storage. Analyses for purgeable priority pollutants and other
volatile organic compounds are performed by an outside laboratory.
nc
-------
C-42
CASMALIA RESOURCES
NEUTRALIZATION SYSTEM
DEWATERED SOLIDS DISPOSAL
Date:
Time:
Free Liquids Test: Pass Fall Solidification Agent Added, lb
(If free liquids)
Cubic Yards:
Landfill Placement:
Landfill Name or Code:
Burial Coordinates:
Location Post No. _____ Distance, ft
Location Post No. Distance, ft
Location Post No. Elevation, °
Figure 3-2. NEUTRALIZATION SYSTEM DEWATERED SOLIDS ANALYSIS
37
-------
e-43
WET AIR OXIDATION FFED/EFFLUEHT ANALYSIS
Date:
Waste Processed:
Generator
Waste Type:
Waste Code Number:
Storage Tank Number:
Operating Conditions:
Flow, gpm: Waste Dilution Water
Air. scfm;
Reactor Temperature, degrees F.:
Reactor Pressure, psig:
Offgas Oxygen Concentration, percent:
Offgas Total Hydrocarbon (THC) concentration, ppm:
Percent
Rsductlon
COD, g/l .
pH ___
Total Cyanide, mg/1
Sulfide, mg/1
Other:
Liquid Analyses:
Product
Efi&l Product Undiluted Basts
Figure 3-3. WET AIR OXIDATION OPERATIONAL ANALYSES FORM
-------
APPENDIX D
RCRA WASTE CODE DEFINITIONS
-------
Appendix D
f EPA hazardous
~ No.
G
FG-3U-
FQQ2...
Ha tduJous
The following spent halogonajod scfcwnfs usikJ jo tfoyrtfasjr.g: Ttfiracflk)/c>tjEft>d<3r>6.
Jnchkyoathylene. methyfeJRd cMon-ds. t.U-ifscnloroetfwki. carDen lotrachicxxte.
ami cWoAfietwj Huc*ocart>cn3, ail sp«nl jcfvoiii mKttuo3.'b«om.is uu*4 (ft o^r^s-
log conmww>fl, Exifor* use, a lotii of u-*% com 01 mom jby voiuffHi) of on* or
more oi the tbovu Jtato^yostud suJvwihs or iIujsj so^voncs iisitfiJ m F002. FOO<
and F005, and aitll bottoms ifom ifta /oco.uiy of in«S6 spdm joN*nia and sp«>nt
soJvem mixtures.
Tho foik)Mrtng spent ha5oQMfW>?od sofvarus, Ti»nocWor<>tjtf»yl«iTOi, myihytarwi chtond#.
cnctitofooirjyiQ.'w. ij.l-t/icnftircoiriijihi. cfctoiofcufuunu. i.1.2-uichk^o-i.2.2trif!wtntina. and
ail spenl solera /w*!ufot>U
-------
40 CFR Ch. I (7-1-B6 Edition)
Hazardous waste
ol# «»• »<*> »' "Wo >'( Ilio aiiova n0-»-lMloonnJi8d jolwnta 2lT,Vi
SKSS^ewsaSS®
The lollowng nen (mio-mnuid solvonte Ciosols and c/ssvtlc «rw
muobamo'io; all :.po«,i a'l-,.m mi*iurt»/blai*te oMUmiing. bolore uM J^Lf^
Mini's" CI™ ™OoT»n?TO58b°r ni;n'h4!oee,,al0<,
Cirr01 ,lwie 5I»m' ^ ^ ,wl bo,,oma ,,om
^atagaggarsss^
s:c=.:T!™rr;::r'.^
Mlvents listed in root. ro<32 Of F004- and stilt h.in™ f »ob«W» <* thosa
ihBM irtmnt «nt,„ ™ bt"' Mttoois from lha raccrvwv ol
*P®m SOW"!! SHU spam sofcom miituru* ^
IPkE=1S.S;
2jnc-*tumfnom fiolirig on cmbon stool; (S) cteanltM/atonofna "
«*¦« -—*-•
"°m ,h° co.Bng of au™x,m
9, "°m »,0C"°M^8 oper.Oon. .
^ztzu:z Z%7™Tnng "m 9,9CU^
M"",0nS -""V** op-oon, ,
°SS «"om m8lal h08' I
Spern cyanide solutions from sali bain not clejmJdn ^ ,
oporitjona. ^ cleaning from motel heat beating (
°CS2 r ^i:rr,i~fla5 ^ - *»*« <**.«*«» — <
^cto^SSw! .bUI lim',6d to- (S5,mrt<"» resWuo., heavy .re, um ,
S 0ln "ra »»«**««> °» ct.terin.M allpftafc
eroc»sser7nii#^Sr Cor,iE6fl1 irom 0,10 *° rc constituents.
[46 FR 4817, Jan. 16, 198J. as amended at 46 FR 27471, May 20, 1981; 49 FR 5312, Feb. 10,
1084; 49 FR 37070, Sept. 21, 1984 ; 50 FR 665, Jan. 4, 10aS; Si; FR 2000, Jan. 14, 1985; 50 FR
53319, Dec. 31, 1985; 51 FR 2702, Jan. 21. 1986; SI FR 6541, Feb. 25, 19801
Effective Date Note: At 51 FR 6541, Feb. 25, 1900. In i 201.31, waste streams "F002" and
"FQQ5" In the subgroup "Generic" were revised, effective August 25, 1086. For the conven-
ience of the user, the superseded text Is set forth as follows'
8 261.31 Hazardous waste* from non-specific source*.
» • • • ¦
industry and EPA haz&rdous
waste No.
HaMidou9 waste
H&2a/d
code
m
nw
GorKNlc
F002
F005-
The fol'owr.^ spunt tialogcnuUiti soI^uoim -ibylnne, methylene chloride.
U»c*i!oroelfiylotie, t.KMfcW«foeOuiriu, ». 1.2-U>ichk*t>-1,2.2-tnltuy-
oeiliane. cxlfKXdtotikxiJbciizctie, nnd U«litorcj 1 tucfortiei/xaw, aU spent solvent
nialujes^teiids coi!lai{Ki>g. before use, a tuLa! of tun percent or more (by vaiumo)
of of* or mo.
Wastowstar trealmonl sludge from the production of iron blue pigmonts
Oven residue from tto) pioduciroo of chrorno oxid« gmnn pigtnenlt
OistiHatjon bottoms from lhe production ol acofalt'ohyrfe tfwn eihyter»«.. —
Distillation side cuts from the production of Atelefciub^io from elhyteng.... —
Bottom stream from the wastewater shipper in the pioduction at acry'onitrite —
Bottom stream from the acetonilrife column in lfn» production ol scryfonitnle.,.. —
Bottoms from Lhe acelOfHtnki pui'dk,3lkm colunin in tlio p^oducbon ol acrySonjWIe,...,^.
ei.?t» t »tr.m "¦ - - "irttinr» r*- j cfrfnit***
(T)
m
m
(T)
CI)
m
m
m
m
m
(R. T)
IB. I)
m
m
-------
61.32
40 CFR CH. I (7-1-86 Edition)
iuy a/<| £PA hazardous
waste No.
Hazardous waste
Ho^„sjt,';!l "o,n mo pu"'icauon coiumn •"•>»p^uclron o,
' "COky on0' *">'» «»' «•». n.l„,„n In air.yl cWwi,to p,oduciion
<* «*•« -^*X=T3S£2"
-• 't^n. "CW <* "* ^ in vinyl ctiloridB
. f(w«l n.!St..o..» cniaiysi »uste |,Dm lluo/o«n«lhflnos pioduclion
" ivt uT , /f" '""" >'"hlucNon °' Pfo'WlMroio,™ i,om a,™
' ' n,'<"ill ,w'" U"1 l''tM"rfo" 01 P'«tw»'lc OMl,yd,i,/o ham naplnhaiune
- k,n STZ TpKx,ur""on °' ph,hofc
' L® J, ™ 9?''" s Iron ol Pl.iholic anli^kfo lion, orthoxylnna
¦' &*z ees r- :,c r"'T";on oi >«» »*>¦
s,".r; ' r »«¦ »«"*°» o7b,,,„„„B
t <¦' '¦mllty oihyl I
,*".71,1 'o'uena disccyanaia pioduclion
' wlLw " ' '' ,aaC'Cr U,e P"*"""" ol 1.1,1-tnclilor-j
JV45I8 fconiMho p.«;.jci st,.-,,,, stt:ppo, in II.q production ol 1.1,1-WchJorootfMne
" h» "130 1,5 Jn',h" ^^"0" °< l.'.l-l'ichltKoelliana
... HOO£ ends ten, „M-y ends column I,on, U,o production
" °adS "°m 1,10 COmt,i™d producfon 01 utcfi'w=>elhy1aoe
Distillation bottoms from n.uJino production . J
" '"sWuos '«>¦« oxlrr.cl.on from tha production olarils™. 1
- ^r=ss,,on'n - - ~~^zttsss\ \
' Ew,*! MShWa!"'S lhp ol dinilrotoluene via nidation of lolueno /
-rtna via H^rw ol'^Io*'o® C°'Umn *" U'0 p,oduction °' Wuai.odia. (
- - —on (
o^l^il^8"^"""8 h 1,19 «»¦*¦«¦« 01 **»"«*"*» f
~ °< —• r
^r
~9vi7,0::;Lr,r.M„r,0B33 sc,ubt,°'in '"8 °f "**»U
sXoo^ir'18''8 dib'omhie in ** producu°n
«««""•«"ihe 8,hf!on# n
S^r.a*rX^d IX rn^uSlid "" P"K0M Cr,,0rtO® pTOduCt,on' whor<' o
-01 -^ U
Watluwaim Uaatn.onl ,W„, Uom Iha morcu^ call ptoceaa In chlorine production (T
By producl sain cfinoraied in thn ptoduclion ol MSMA oml cacodyllc add
w"::: °r u:tt ?*»uom me ¦><
?£ZZ o^:ZoWi,°' "0m m" CW0"naton 01 ^lop.n^die™, in Uk,'
F»lo^nl '""" 'hB 'ill,al,0n ho»achl°'0^ctaP«ntad«,» In Iho producUon ol
V°Xmda^PP<" t"Kha'C8 "°m 'h8 cn,ordiule chtorinator Production ol
Sm'^T T"TT 6lU^,fl9, es"B,alod lh0 Pioduclion ol coosoie
W««^l , . 'Kl«nwilon fllsllllnllon In Iho p«ion :::z:
Xx"o a,ton 01 dlulh),lPhosPho'Odi|hlolc acid In Iho producUon oil
."""I™"' ili"!B° hom 11,8 P'Od'^iton ol phcaiu
1.0.1. mm production or io«,,,ha,K.
J P™5®" wAs.nwaipr (rom prcluclon ol loxoiilwno I
Environmental Protection Agency
§261.33
tndusliy ax»d EPA hazaidous
wasto No.
Hazardous wasla
KCM2
K043
K098
Explosives:
K044
K045
K048
K047
Potiotoum rofirBog:
KQ40
K049
KOSO
K05I
K052
Iron and steel:
K061
K062 -
Secondary toad:
K069
K100
Va!os frorn INi chsiiilaiton of tatracMofobenzeoe m lh«
pfoduction of 2.4.5-T.
2,6-DichkHOpfwnol wasto Irom Iho pfoduciion r»f 2.4-D
Unlroalod wastewater Irom tlio ptoducUon ol 2.4 D
Wastewater teal/nont slixiges from (ho manutacHiring and processing ol explosives -
Spent carbon t/orn the Ueatmont oJ wastpwalw r:cotaimng explosives
Wastowator t/catrn&nt slutigus Iium tt»e ntanul-iciuni^. formulation and loading of
lead-hasod initiating coihikajikJs
Pink/rod wato» ffunj TNT cjf>OfHiimJi ...
Dissotved cii fkjtnlkjn (PAP) Hour ftom ttm poiJo'-ium relining r>duatry
Slop otl eiriuJsion solids f/o«n U»e peirotnuni (el/.iiiuj industry
Hoat exci^aoger burKjlo clearsig sludge ftom the jiobcloum relining industry...
API sepaialor sfudge from Uie pot/oloutn wlimng irnluslry
Tank bottoms (leaded) from the potioleuni miming industry
Emission cont/ol dust/sludge from the piimaiy production of steel in elecltic
furnaces.
Spent pickle liquor garxwntod by steel TinisNng operations ol plants lhat produce ken
Of steel.
Emission control dust/sludge from secondary toad smelting
Waste leaching solution from acid leaching of emission control dust/sludge from
secondary lead smelting.
Wastewater Ueatment shidfles generated do/mg the production ol veterinary pharma~
ceuticafs from arsentc or Ofgan^arsenic compounds.
Oisliilalion lar residues from Iho distillation of aniiine-based compounds in the
production of veterinary pharmaceuticals from arsonic or ocga/>o-aiaatiic com-
pounds.
Residue from the use of activated cartoon for decok^rzaUon in the production of
veterinary pharmaceuticals from arseruc or organoar >en»c compounds.
Solvent wasbea and sludges, caustic washes arnl sludges, or water washes and
6ludga3 from cleanirvg tubs and equipment uuxJ in Uio formulation of ink from
ptgmcnt3, driera, scaps, and stabilizers containing cb/unium aruJ load.
Ammonia afill Krne sluilge from coking operatiens
Decanter tank tar sludge from cokjng operations
[46 PR 4618, Jan. 16, 1981, as amended at 46 PR 27476 27477, May 20, 1981; 49 PR 37070.
Sept. 21. 1884; 50 PR 42942. Oct. 23. 1985; 51 PR 5330. Feb. 13. 1880; 51 FR 1D322. May 28.
1D80]
Effective Date Note At 51 PR 5330, Feb. 13, 1086, In 5 261.32. waste streams "K117,
K118, and K136" In the subgroup "Organic Chemicals" were added, effective August 13.
1988.
C3
I
LO
-------
Sub* lanes
P023...
PQ02...
PO 57...
P058..
POSd...
P001..
POOZ
P003
P070.......
PQU4
POOS
POOS
POO 7
PQOQ
PD09
Pi 19
P010
PQl,?
PO It
Ron
P012.
P038.„.
PQ54
POi3...
P024
P077
PQ28...
PU43 „
PQI4.
P0?8
TOPS..
POfS..
P017...
poia...
P02I...
PI 23,...
Pf03..„
PQ22...
P022...
POS5....
Acotaldahytfe, chioro-
Attrtaiimto. N.firoinoWoKoniiimvn-
AcelainkJe, Z-(Iuorp-
Acauc add. ducro-, lodtum salt
Acaumkte ^ N-t^ihytau-.
twmo>-l)o»y)lhk>-, OHjlhyl «»ter
3-{»lplia-Acotoi>1l>«ni)lH-ti>-
BemoneiWoJ
Deiuyf chloride
BtfryfMum dual
Bistehforomethyf)
Siomoaceloos
Qiuc'nd
Calcium cyonkkt
Camphona, oclacftforo-
Gartmmlmk^osoienoJc acid
Coibon bisulfide
Caifcon d«suifnJ«
Ga/boiiyi rJiioficJa
Environmental Protection Agency
§261.33
Subs tar* 8
wasla No
Substance
CMocine cyanide
Pi 12 .
MRlham©. lel/^iitro-
ChkxoacolaJdohyda
FH8
Mattmnethtoi. Uichkxo-
p^-Chlcxoamljrwj
P059
4.7-M«U«no-lH-todeoe. !,4.5.8.7,B.e-hep-
l-{oO)foroplM)ny1)lhi(Xvaa
Sachkxo-3a,4.7,7a-t«tfaliycUs>-
3*ChloeIhyl-1{meUTyJttiioj-2-bMtanon0. Q.
P076
N.uogonU!) oxide
[(rralhylamino)ca/t>OOyil oxinm
Pi) 78
Wilrus«n(IVj o*kJe
0.0-Dimalhyl O-p-nitfopheffy* pho*pl>CKO-
P081
NiUogiycenne (H)
IMosla
PQ02
M Nilrosodirrveiftyiamine
DmteiftylniVosarrtne
P084
NNit/odcmelhylvinylam«r>e
alpha, alpha-Oin^thytphoncthyiamine
POSO
S-Nwtx>'nene-2,3-difnethanoI. 1.4.5.8.7.7-bex-
4,6-Dinit/oo-aosol and aalUi
AChSoro. cyclic iuiltte
4,S-DirHtio-OHryciohe*y1phefwJ
Pons
Ociamnmyfpyiophosprxxamjde
2,4Dinitropf>enoi
P087...
i.mi>iuw o>»da
Oinosob
POO 7
Osunwm loyo/nJa
0ipl»sphoraroide, octajnethyf-
POOO...
7-0*abkyclot2.2.1 ] hoptane-2.3-dkiart>oxyfk:
Disufloton
acid
2,4-Ditf*ot*urat
P089
Pa/alWoft
DitWopyroprieaplioric acid, totraeihyl esiar
P034,
Phenol. 2-cycfot>e*yM.&--
Emkjlhali
P047
PharKJi, 2r4-diniWo-6-nrrVthyi-
Endrin
P020
rimool. 2,4-di/Mtf{>-6-(l-rrwthylpfopyl>'
Epinephrine
PQOB
Phenol, 2.4.$-!/HMt/o-t ajfWKMfcun saii |f\)
Ethanamir>e, 1,1-dnTTethy1-2-pteriyi-
P036
Pfiflnyl dich|{xoar««»e
Etheiianine, N-meUiyi*N-nit*oao-
P092....
PheriylmerctirK: aceialQ
Ethyl cyanide
P093.,
N-Phen^thiour®tt
Ethytenlmine
P0V4... .
1 fjoraio
Famphur
P0S5. ..
Phosgono
Fluorine
pygo
PhQSphifMJ
Ruofoacelamtcte
PO41
Ph03p>h6fic acid, dtelhyt p-rjt/ophenyf Miar
Fiuoroacolic ackJ. aodSum salt
m44
Phosph<»Q-erx>Q,erKk>
P094 ...
Phoapho?oihtolc add. 0.O-<56ihy1 S-
1.4:5,ft-difi>Qlhanonaphihalene
fathyi{h»o)motf»yl vttiw
1.2.3.4.10.10- Hexachtof 0-6, ? -epoxy-
POSfi
Phosphocotliioca acid, O.O-dkjtTryl 0-(p-rtrtn>-
1,4,4a.5,6,7.8,8a-octal lydio-ondo.axo-
phenyJ| eater
t,4:5.&Kiein0UtfnoAaphthalena
P040...
Phosph<5fotfuo4c sod, O.OKffelhyl O- pytazSnyf
{^3.4.10.10-Hexachkxo-1,4,44,5,8,0a-
vstrn
hoxfll*ydio1,4;5.&-€odb, endo-dimeth- an-
P097
PlK39iphoroU»iotc acid. O.Ocfimelhyl O-CHttf*
Ofiaphthaterm
mQthylamino)-ai)lforiyl}phany()aator
!^.3.4JQ,lG-He*aehk*Q 1,4.48,5.8,8a-
Pi 10.
Rum&arwi. tetiaethyf-
bexshytko-1,4:5,B-orxto,oxo-
P098
PoNislwm cyanWs
durwitltanonaphlhelone
P0S9
Poiassium aiKar cyaruda
Haxachtorotexahycko-exo.exo*
P07O
Pmpqnal. 2-methyt-2'(me1hyiiNoK 0-
dirnclhancmaphU ia)omi
Umeihyl8rnirK3>cartxjnyI3o3Jma
Hexaolhyl lot/aplsosphalB
PI01
Pfopanerwrrlla
HycJraJiftecafbotlHaamide
P027
P/apflnoruSiila, 3-ctikxo*
HytUa/irw. moiPiyi-
P0S9
P/op^nomUile. 2-hydroiry-2-methyl
Mydfocyor»c ackJ
POBJ
t.?.3-P/cpflr>enk)l, Ulrnl/ata- |A)
Mydrogon cyorudet
P0I7
2-P/opanor>a, l-bronio-
Hydrogen pfK»ph>c)e
P102
PmpatQii aicohof
isocyantc ackl. nwlfiyl aster
P003
2Pfopenai
3{2H)-[soiui/o5on«, 5-{afninomQthy1j-
P005
2 P/oport l-ol
Mwounty, {acQiaio-0}pbonyV
P067
l.2-P*apylenimrn©
Mercu»y fu?mmal6 (R.T)
PI 02
2-Propyn-i-ol
-------
.33
T'U5
40 CFR Ch. I (7-1-86 Edition)
Sutelanco
HiXtardous
Wa&ie No.
Subslanc®
PyiKli-w, (Sj3.|I-mi>M,j« „(11|
ryroji'wplioic aad, »l«aolii>l «Mtu
Sc.fiiKXi/ya
cyiftido
Sod»i*m a/ide
Sod ;um cyanitfu
Stionbum su/Wu
Slr)c(uiii}iiN 10 ouo. uekS soils
S:iy,.f«i»|,n.iQ-ona. 2,3.dimumo*y.
Slrjrclmiiio gn,) suns
Sulfuric sex). UcalliumUl salt
laciaolhyidiilwjpy.optwsphato
Tairaelhyl load
T 01# aoJh^pyrypr>osphai&
Tooanii/onwuiano jn)
T«irg(>hospl!oric aod, hstamyl oslor
Thaflic ox.da
Thal)ium(iii) oiide
T?ial!l
Vanadium ponlOMda
VanadiumsV) o »s««< jij
, * Ac«,ic «od. load sail
• : Ac#lic 8C«. tholiiuot(l) sail
— Acoton# it)
...j AceloJiibslo fl.Jj
UM8 3
a;^,, Mnl c„>l]ons
UM" Aceloph.no...
.V??f 2-Acwylamirofluofflrw
¦j"! Acalyl chJooda (C.R.T)
umr Aeiylamido
m0B I Acrylic acid (II
Atryloniirile
U,S0 *'•"»»• 3-Cp-biscz-c)!lofoamynefnifKJJ
J phony?*, (.-
2-A,nTO.|.m,ifl>iU,a!0n8
<-Am>no-|.Iii8it>>»|>WuarM
"OH I AllMJpgJe
UQ}? I Arjilina (!,T)
Aurami na
^'5 j AzascKinn
UOJO 1
UJS7 .
U9T6...
toni»|2-.3':3,4)i>)«,otoSI,z.aJinrt0i8^,M(0(W
b-aflimo-e-fdamrrocarbonyl) 0*yjmalhrtl.
.H?'? 3.«-8eniecfidirj«
11017 Sataal chloride
,7?!? Benilaj#nihi«cene
!,ianatof2n<*te*«ytic «W anhydride
».2-B«™«r(adica(bo*ylte acid, (ts{a(2.a!fw(-
htkxylj) estfir
U-BaoisnadicarboxyJlc acid, dibuiyl e-jtor
(.J-BBnranedicarbo^llc acid, die%l oiler
.J.BamanadicartxB.ylic acld. rtrn.u,»| mtar
!,2Ueii/.snov'h-afbo*yfic at-id, di^-octyl »•»©,
Sor>;ong, l,2-Ui|rl«iotJioxy*4'pfopiHirN
U028...
U0G9
U06B
UI02.
LTIO?
U07D
U071
U0 7 2
uoi;
U223
U239
U?0» ....
il\2f
UI»H ...
tir;?o, l,2-mothyIonfldiOifY'4 ptopyl-
U0S5
Bon/Qrtc, (I-iiwIliytoEriylJ- (l|
U169
Beniatio, rrflfo- (IJ)
Uli3„,
Benzene. p«niachfo3
U19?
p-Bofuoquirvooe
U023
BeruoUkrhlOftdo {C.PI.T)
UOSO
1,2- BenzpNinanilv erve
U085m.„„
2.r-Bioxkarw {t.T)
U021
0J'-BiphenyJM.4'-diamtf*«
U073
{I.J"-8ipii8nyJJ-4,4'-dtcmift.-), 3.3' lilculco-
U0ft1
(l.T-BipixirylJ^^'-dianiifio, 3,3'-dinidlhox^
U0D5
(1,1'*B;ph«oyl)-4,4"-diamirja. 3,3'-tfimoifiyl-
U024
Bls{2 ctitoroothoxy) meiiian©
U02?
Bis(2-cltlQrotso^opy)J etNw
U244
Bis(d-
1-Bu!ao6rtwi0, N-bySyl-N-ailroso-
U035.
ButarxHC fiCKf, 4-[Bis(2-cWoto©!hyI|arrMno}
beruene-
U031
1«8ulanol (•)
U15B
2-Bulaf>ona (t.T)
U160
2-Biitsnono peroxidi p,T>
U053,—
2-BulonaJ
UQ?4
2-Butom? 1.4-didilofCh (t,T)
U031
n-Butyl aichohd {IJ
UI36..,.,
Cacodylk: ackJ
U032
Calcium chtomaia
U238
Ceibsrmc acid, eihy! esler
Ut?8.
Cartjsrrrfc acid, mothylmuoscv-, elhyl esiw
U176
Ca/banmdo, N-eihy}-N-nif?oso-
U177-
CaibairodB, N-matfzyl-N-ftiiro&o-
U219
Carbatriid«. Ihio-
U097
Caiban>oyi cftoids. dimotiiyl-
U215
Cartxjrwc acid, rt'ihalflumjl) sail
U158
Ca/txjnoehtcndk: arid, mettiyl eater (i,T)
U033„
Caiboa o>rylluof>do (H.T)
U2! 1
Carbon fel/achkirtdd
U033
Ca/bonyl fluorkie (R,T)
U034
QiforaJ
U03S....,
Chlwambucii
UU38
Ch'otda/io. iechrWcal
U026
Chlomaphazino
U037
CNotobenzana
U039.,
4-CWcwomcrosol
LHJ4 J
l-€h?ofO-2,3-0po*yp*Oj3arse
U042
2-CWoro«ifiy1 vwyi slhor
UQ44
ChhxoJonn
U0«J8_
Chioromothyf mathyi athar
U04 7
bolfiChtofoiwphUialoou
U049
o-CHoiophonol
U049
4-CMofo-o lolurdba, hyd»ochlo»fda
U032
Chrofrwc add, calcium sail
UOSO...
Clirvsona
UU51
Cteosola
U0S2
Dosals
U0S2
Oasylic ^cid
§261.33
Ha^anlCHis
Waste No-
Subslarx:a
UUS5
Cu«ne»H2 (1)
U24ft . .
(.y<'ir*4fifr» tnotntdo
1119/
1.4 CycruhoracJieoedioAa
U0S6
CycMiaxane (i)
U057
Cy«.loiie*2H-
cyc)ybuta[c,d]'penislan-2-<7oe
U062.............
OoRaio
U133
Dmimnd (0,7)
U22I
Diamsf*>lG!u©ne
U063
Oibeoz i a,h lanthracana
U063
1.2:5.0C^t>€n2anlhracaf>a
U0&4
1.2; 7,8-Drt>ef»2opy rma
U0S4 .
rVHrMTj-f BiJpyriainjtt
U'«i9 .
i i* lJMomo-3-chtofopfopa/»e
U0S9
l pmriafaia
U062
X (2.3 Dk^iiOfoaHyl) dKaopropytlftoaubamate
110 70
o DictikKoberi2eoe
U171
in-DiciiJorobe azano
U072
p 0*uU\otohetuQm
imn..
3.3' D"«Wo»ofe>en2»dir>®
IJ074
1 4 DcWoro-2-tKJtan© (l,T)
UQ75
Dicttforodifiuofomelhana
UI92
3.5D«cMofO-N-«Son«
U090
Ohydrosalrole
U09I
3.3' DimathoxytxjnzkJiria
U0D2
L'jrnaihylafniiie (IJ
UU93
D^ntHhyianHnoaiofcoruene
U094
7,l2-Oi«>ayjyib0raEa Ia»ihraceoe
U095
3,3"-0»ntt€U»yJt>«ru»din«
U096
aif^ia.aipita-Dimcihylbonr^hyd/opefcnude
U097
Dimaihylca/bamoyi chlofkie
U098
1. f -Dimothylbydr aiine
UQS9
1.2-Dimolhy!hydra2Me
UIOI
24 OiiTialhylphenol
U102
Ounofhyl pJttfiafala
UI03
Dimolhyl swffala q
UJ05
2,4-OfMirolo!ueo«> $
UfOG
2.fiD.-rJiUoiuJu*jn» (_n
1*10?
Ci •» ocfyi phihalala
UMJl>
t .4 f)iox^ne
UIU9
1,2- [ Hphonylhytirazin#
una
uni.
(Ji-M pirpyiniUo«anr«r>a
UM1 . .
Ftr»ni,af (I)
UtM
iiih.-UHtiriino. N olhyl-N nit/oso-
l H n\ >
% ll.lf.rt 1 > ftMrWV.
-------
a> m
[S
III1
ill -
c 75 c 'c
®5 5 o
.» » 3 o> ¦$
w w o !fi J ^
?1
JC T5
o C
? OJ-
664
i/i v> V}
W CV
iSoocooc
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APPENDIX E
CONSENT AGREEMENT AND FINAL ORDER
(DOCKET NO. RCRA-09-84-0026)
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E-l
Appendix E
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
218 Framont Straat
San Franciaco, Ca. 9410S
CERTIFIED MAIL P429564704
RETURN RECEIPT REQUESTED
2 1 SEP 1984
Refer toi CADG20748125
Kenneth Hunter, Jr., President
Hunter Resources, Inc.
539 San Ysidro Road
P.O. Box 5275
Santa Barbara, CA 93108
Re: Consent Agreement and Pinal Order
Docket RCRA-09-84-0026
Dear Mr. Hunteri
Encloaed ie your copy of the executed Consent Agreement
and Pinal Order which contains the terras of the settlement
reached with William D. wick of the Office of Regional Counsel.
If you have any questions regarding the rules, regulations
and statutes governing your operations which are implemented
by the Agency, please feel free to call us.
Enclosure
ccs Angelo Bellomo, DOHS-Los Angeles
Richard Wilcoxon, DOHS-HQ
Gil Jensen, DOHS-HQ
John Adams, SWRCB
Ken Jones, Central Coast RWQCB
Fred Fudacz, Nossaman, Guthner, Knox & Elliott
Sincerely yours,
Barr# Seraydari
Director
Toxics & Waste Management Division
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION 9
In the Hatter of
HUNTER RESOURCES, INC.,
Respondent.
Docket No. RCRA-09-84-0026
CONSENT AGREEMENT
AND
PINAL ORDER
This administrative proceeding for the assessment of a
civil penalty was initiated pursuant to Section 3008(a) of the
Resource Conservation and Recovery Act (RCRA), as amended
142 USC 6928(a)] and the Consolidated Rules of Practice Gov-
erning the Administrative Assessment of Penalties and the
20 'Revocation or Suspension of Permits, 40 CFR Part 22. The actions
j!
21 ij were instituted by a Determination of Violation, Compliance
M
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2'A
order and Notice of Opportunity to Request a Hearing issued
\
i
ion May 11, 1984 (Complaint), which charged Hunter Resources,
21 Inc. with violation of RCRA Sections 3004 and 3006 (42 USC
25
6924 and 6826]i 40 CFR Part 265, regulations published by the
20' Administrator, United States Environmental Protection Agency,
27
28
to implement those RCRA sections? ands Section 25159.6 of the
Health and Safety Code, State of California, at the facility
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*nown as Casmalia, Disposal, located at NTU Road, Santa Barbara,
California, EPA ID Number CAD020748125 (the "Facility"),
-Junter Resources, Inc. is the general partner o£ Casmalia
Disposal, a California Limited Partnership, which is the operator
5f the Facility. Hunter Resources and Casmalia Disposal are
referred to jointly herein as "Respondent", The Complainant
is the United States Environmental Protection Agency, Region 9
EPA).
II
Complainant alleges and Respondent agrees, for purposes of
.his Consent order only, that the EPA Regional Administrator
as jurisdiction of the subject matter of the action set out
n the Complaint and over the parties thereto, pursuant to
ection 3008 of RCRA [42 USC 6928] and 40 CFR 22.04(a) and
2.37.
Ill
Complainant and Respondent desire to expeditiously resolve
his matter, and therefore for the purposes of this Consent
greement and order, Respondent neither admits nor denies the
actual allegations set forth in the Complaint. Respondent
grees to waive any right to a hearing, and consents to the
ayment of the penalty as assessed hereunder and to the iss-
uance of this Consent Agreement and Final Order without ad-
1
ud ication.
// 1
// 1
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IV
Respondent agrees to sample by August 6, 1984, seven (7)
existing monitoring wells (A2M, B3M, C1B, C2M, C4M, C6B, and
DIM) and four monitoring wells to be installed (A1M2, A2B, B3B,
and DIB). Respondent also agrees to conduct additional samplings
of the eleven (11) wells by September 17,• 1984 , October 17, 1984 ,
and November 16, 1984. The selected individual wells to be
sampled during these last three (3) sampling runs may be changed
following discussion and approval from EPA, but the total
number of wells shall remain at eleven (11), unless EPA approves
in writing a fewer number of wells. If additional wells are
installed, additional monthly sampling and analysis shall be
conducted for such new wells to obtain a total of four (4)
nonthly samples. Groundwater samples shall be analyzed for
all RCRA-required parameters in accordance with 40 CFR 265.92.
Analysis results shall be submitted to EPA within forty-five
(45) days of sample collection. A minimum of four copies of
the analysis results shall be submitted to EPA.
V
Respondent agrees to comply with the following requirements
Df 40 CFR part 265 by the dates specified belowi
Submit an amended ground water sampling
and analysis plan which complies
with 40 CFR 265.92(a) 8/6/84
Submit an amended outline of a ground water quality assessment
program wich complies
with 40 CFR 265.93(a) 8/6/84
f / /
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VI
Respondent asserts that natural evaporation from the free
liquid surfaces o£ all existing liquid impoundments within the
Facility is not adequate for dewatering all liquid wastes
received at the Facility plus runoff from incident precipitation
on the Facility, and that procedures for -enhancing evaporation
are required for continued operation of the Facility with no
liquid discharge across Facility boundaries. Respondent further
asserts that on a volumetric basis runoff from precipitation
on the site is a major component of the liquid requiring evapora-
tion disposal. The Respondent has and will continue to supple-
ment natural evaporative processes within the Facility boundaries
by two procedures, as follows;
Injecting water into the near surface atmosphere in
l!
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15'.,' the form of small droplets.
lf,!| -- By systematic wetting of ground surface by spraying
17 through a series of fixed-position spray nozzles,
18|'! Respondent agrees to take the following measures with re~
II
19'Jspect to the systems utilized for enhancing evaporation by
a
20 spraying procedures:
j f
21 jlA, Respondent shall utilize only ground surface areas, for
i j
221[ supplementing natural site evaporative processes, which
i:
2«'{'; are presently established as spray areas, i.e. areas which
21'| presently are or have been used for the purpose. Nine
2fi!; areas, as outlined on the attached Figure 1, are now or
20
27
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have been used for this purpose, four of these areas are
associated with impoundments that are subdivided into
five, four, three, and three cells, or ponds, respectively.
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Respondent shall operate the spray evaporation waste man-
agement system as one or more surface Impoundments. Re-
spondent shall construct and/or maintain drainage channels
and berras to direct the runoff to the impoundment, and
shall relocate and/or install pumps and pipelines as re-
quired. Runoff channels shall be constructed to control
erosion. Be ruts and channels shall be constructed and
maintained as required to prevent run-on to spray wetted
areas by runoff from precipitation on other areas.
Respondent shall take all reasonable precautions to main-
tain containment, and shall not operate the spray evapor-
ation system when wind drift of the spray liquid will fall
outside the prescribed limits of the system*
Respondent shall prepare construction and operation plans
for the spray system. The construction plan shall detail
the modifications required to make the system consistent
with the criteria outlined in B above, and the operating
plan shall include procedures which will be followed with
respect to maintaining required freeboard in impoundments,
control wind drift of sprayed liquid, and other such para-
meters as are required for safe and effective operation
of the Facility. The plan shall include schedules for
implementation of the remedial work required for the
system, system closure plans, and a water balance insuring
minimization of the required spray area. The plan for
the system shall be submitted to the Complainant on or
before November 30, 1984. All remedial work for the
system shall be completed within a time frame mutually
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E-7
agreed to by Respondent and Complainant, but not later
than January 16, 1985, unless Respondent requests and EPA
grants an extension for good cause,
Until completion of work specified in D above, all liquid
federal Superfund waste shall be disposed only within
Pond 18 and its associated spray management area, a spray
waste management unit constructed and operated as a surface
impoundment.
Respondent and Complainant agree that should the volume of
liquid waste or any other condition at the facility indi-
cate that strict compliance with Paragraph VI(E5 above
would cause a violation of other permit conditions or
regulations applicable to the facility or create a danger
to public health and safety, Respondent shall have the
right to move or dewater such waste to or in other areas
of the facility not included within the spray evaporation
waste management unit described in VI(E) above, as neces-
sary to alleviate the threat of such violation or danger.
Respondent shall submit a complete permit application, ex-
cept for the groundwater plan and hydrogeologic information,
by November 30, 1984. . Respondent shall submit the ground-
water plan and hydrogeologic information by January 16, 1985.
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. VII
In the event complainant determines that Respondent has
failed to accomplish the tasks set forth under Articles IV, V
or VI in either the prescribed mannner or within the prescribed
time, Complainant shall notify Respondent of such determination
by written notice delivered to Respondent- by certified mail,
return receipt requested, describing the deficiencies in Respon-
dent's performance so that Respondent can take corrective
action. Respondent shall have twenty consecutive days from the
receipt of such notice to certify that the corrective action
required by Articles IV, V, and VI has been accomplished, but
i
that period may be extended by Complainant if it determines
that additional time is warranted under the circumstances. In
,the event Respondent tails to certify either that (1) the tasks
li>: which Complainant has found deficient have been accomplished
1 (>j within the time allowed, or (2) that work has commenced and
i
171 satisfactory progress is being made toward completion of such
[i
1HI|tasks, or in the event that Complainant determines that Respon-
lo|;dent * s performance remains deficient after receipt of the
i
20;icertification, then Complainant shall take such legal action
i ]
21 Sdeemed appropriate in the circumstances including but not
|t
22]: limited to such penalties as may be assessed under section
II
2,*i :3008 of RCRA 142 use 6928], The remedies set forth herein are
s l
2-t'' not exclusive and are in addition to the remedies which Com-
«i
2;i|jplainant or Respondent may have either in law or equity,
20:!///
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1 i ... VIII
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In lieu of the civil penalty of $50,000 assessed pursuant to
the Complaint filed under the docket number shown in the caption
above, and without any admission or acknowledgement of the tactual
or legal contentions in the Complaint, Respondent hereby consents
to the assessment of a civil penalty in the amount of $35,000.
IX
All submissions under this Consent Agreement and Final order
shall be sent to:
Phil Bobel
Chief, Toxics & Waste Programs Branch
EPA Region 9
215 Fremont Street
San Francisco, CA 94105
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Complainant and Respondent consent to entry of this Consent
Agreement and Final Order without further notice.
Respondent
Hunter Resources, Inc.
Date Complainant /
Harry Seraydarian
Director, Toxics & Waste
Management Division
EPA, Region 9
It is HEREBY ORDERED that this Consent Agreement and
Final Order (Docket No. RCRA-09-84-0026} shall be entered
and shall become effective immediately.
Qy LaJ uui_
Date JUDITH B. AYKES
Regional Administrator, EPA
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E-11
CERTIFICATION OF SERVICE
I hereby certify that the original of the foregoing
Consent Agreement and Final Order, Docket No,
PCRA -09-84-0026, was filed with the Regional Hearing
Clerk, Region 9, and that a copy was sent certified mail,
return receipt requested, to;
Kenneth Hunter, Jr., president
Hunter Resources, Inc.
539 San Ysidro Road
P. O, Box 5275
Santa Barbara, CA 93108
A copy was also sent First Claee Hail to?
Honorable J. F. Greene
Administrative Law Judge {A-l10)
U * S. Environmental Protection Agency
401 M Street, S. W
Room 3706, Waterside Mall
Washington, D. C, 20460
Date
! * ^ — —.,, _
te Management Division
Toxic
Region 9
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APPENDIX F
OPERATING RECORD DATA SHEETS
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Appendix F
CASMALIA RESOURCES
Hazardous Waste Management Entry
M a 11 i f e s t Header
DATE;
F-l
6/12/07
Manifest Number :
Generator No- 10737
E.P.A. No. CAD9Q1383A23
U.S. Pipe and
P.O. Box 707
11 a t e T a
"ranspor
"ranspor
/a It
x Number
ter i. 00738
ter 2 00000
. TSDF
Foundry Co.
Union City
HAHQ36016590
I. T. Hart insz
Di sposa t Date
Ticket No.
Adjustment (Y/N)
Veh/Con ta i tier
CA 94537
F'Lag in Customer F i Le T
E.P.A. No.
E.P.A * No.
N
050587
0090138
No.
CAB0000831
;hd KEYS
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4.
Add Manifest
Change Manifest
Change Header
Clear Screen
;e CMD keys
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F-2
State ID No.
CASHALIA RESOURCES
Hazardous Waste Management Entry
Manifest Detail
084854955
DATE: 6/12/07
Total Quantity
Unit Ut/Volume
No. of Containers
Container Type
Watite Category
EF'A Waste Cat.
Disposal Method
Locati on
Location Marker 1
D istance
Location Marker 2
D i stance
Elevation Marker
Degrees
Tax Code
Disposal Date: 05058?
00001700
Y
000
571
D008
03
L3
53
274
70
351
53
11
(2 dec.>
1.
2.
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5.
6 .
9.
Add Deta i I
Change Deta i I
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Next Deta iI
De lete Deta i 1
Ma i n Screen
Adjustment
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F-3
CA8MALIA RESOURCES DATE: 6/12/87
Hazardous Waste Management Entry
Manifest Header
Manifest Number: 086064813
Generator No. 13492
E . P . A . No. CAD981404205
Kings County HeaLth Dept
330 Campus Drive
Vei l/Con t a i ner
Hanford CA 93230
EXEMPT F Lag in Customer File T
07749 Kern Backhoe Service, Inc. E. P. A. No
00000 E.P.A. No
Adjustment (Y/N): N
Disposal Date 050587
Ticket No. 0090144
State Tax Number
Transporter 1
Transporter 2
/a It.TSDF
No.
CAD082189911
CMD KEYS 1. Add Manifest
2. Change Manifest
3. Change Header
4. Clear Screen
Use CMD keys (CMD 2 to Update)
5. Change/Delete Detail 9. End Input
6. Delete Manifest
7. Confirm Delete
8. Add Deta i L
else make changes and press Enter.
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F-4
CASMALIA RESOURCES
Hazardous Waste Management Entry
Han i fest Deta i t
State 10 No. 086064813
DATE: 6/12/87
Tota L Quant i ty
Unit Wt/Volume
No. of Containers
Container Type
Waste Category
EPA Waste Cat.
Disposal Method
Loca t i on
00002000 <2 dec.)
Y
000
Loca t i on Mar ker 1
D i stance
Location Marker 2
Di stance
E Leva t i on Mar ker
Degrees
Tax Code
Disposal Date: 05058?
03
L2
5.1
138
60
413
60
10
Cubic Yards
611 Cont am i via ted so i
Land f i I I.
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APPENDIX G
LAND DISPOSAL RESTRICTIONS (LDR) INSPECTION CHECKLIST
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Appendix G
6-1
3/16/87
Facility Name Casm&\\a"Resources
ID#
Date ^V.y \«\ --a.^ I
LAND DISPOSAL RESTRICTIONS (IDR) INSPECTION CHECKLIST
Yes No Comment
1. Are any FOOl thru F005 wastes handled by the
facility? (If no, proceed to #9 if a California
facility; otherwise, do not complete the rest of y,
the LDR checklist)
2. Have any FOOl thru POOS wastes been land
disposed (including non-containerized storage on
land) since 11/8/86?
If no, move on to question #6.
3. If yes, give waste code and process code
(e.g., D81, TQ2) and answer remainder of checklist
4. If post-11/8/86 land disposal has occurred, is
a certification statement (§268.7) available to
verify that the LDR requirements have been met in
one of the following ways:
A. Waste disposed meets the applicable treatment
standards (§268.41)?
B. Waste is exempt from the LDRs via:
i. No migration petition (§268.6)?
ii. BDAT variance (§268.44)?
iii. Case-by-case extension (§268.5)?
iv. National alternative capacity variance
(i.e., waste is from a SQG or waste is
less than 1% total solvent) (§268.30)?
v. RCRA Corrective Action waste (cleanup
waste pursuant to a §3008(h) order)
(§268.30)?
vi. CERCLA waste (waste from a CERCLA 104
or 106 response action) (§268.30)?
(Exemptions iii - vi expire 11/8/88)
C. Waste is being treated in a surface impoundment
\ cnpoonA s
5. If F001 thru F005 waste is being treated in a
surface impoundment:
A. i. Does the facility's operating record
contain procedures and a schedule for
removing the restricted waste (or residues
fron the treatment which do not meet
BDAT) within one year of their entry
into the impoundment, as specified in
§268.4 (§264.13 and §265.13)?
ii. What is the next scheduled date for
removal of any residues?
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Facility Name , C/t^xmV>,Q."Resources
ID# rAT>tVLOf4.ftM.g
Date vrxcvy w
IDR CHECKLIST—Page 2
B. Does the surface impoundment meet the
minimum technology requirements under §3004{o)
of HSWk (§268.4)? (To be answered during
pre-inspection review)
6. If P001 thru F005 wastes or treatment residues are
i. shipped off-site, for all shipments after
11/8/86 was a notice and certification sent to
the TSD specifying the applicable BOAT standard
or LDR variance and other information required
by §268.7?
ii. managed on-site, does the operating record
contain the notice and certification required
by §268.7 (§264.73 and §265.73)?
7. For each shipment of restricted waste received
fron offsite after 11/8/86, does the facility's
operating record contain the generator's notice
and certification required in §268.7 (§264.73
and §265.73)?
8. Has the waste analysis plan been revised to
incorporate the requirements of Part 268
(§264.13 and §265.13)?
For California facilities only:
9. Have any wastes restricted by California
state law (Calif, waste codes in the 700 or
800 series) been land disposed?
If so, give waste and handling process codes:
Waste
Handling Process
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