Document L9eRNRB7jdzJQqeemN2mKxd

PRC Engineering Suite 600 303 East Wacker Drive Chicago, IL 60601 312-938-0300 TWX 910-2215112 Cable CONTOWENG prc Planning Research Corporation October 30, 1986 Ms. Melissa Guise DOW CHEMICAL, U.S.A. Louisiana Division P.O. Box 150 Plaquemine, LA 70765-0150 Dear Ms. Guise: In accordance with your request, we are sending you a copy of the documents that you submitted to us on August 27, 1986. Thank you for your cooperation in our LOIS Inspection. Sincerely, PRC Environmental Management, Inc. Shin Ahn SA/klb Enclosure DO 143904 CONFIDENTIAL DOW CHEMICAL U.S.A August 27, 1986 FEDERAL EXPRESS LOUISIANA DIVISION P. O. BOX 180 PLAQUEMINE, LOUISIANA 70766-0180 604 38B-S000 PRC Engineering 303 East Wecker Drive Suite 600 Chicago, Illinois 60601 PRC ENVIRONMENTAL MANAGEMENT. INC. r; o p iqp Dear Mr. Ahn and Ms. Yanada: On August 25, 1986, PRC Engineering, contractors for the EPA Region VI, conducted a "lost interim status inspection" at the Louisiana Division of Dow Chemical. Below is a list of additional information which was requested. This information is included in the referenced attachments: 1. Louisiana Division RCRA Hazardous Waste Permit (Attachment 1) 2. Louisiana Division RCRA Hazardous Waste Financial Responsibility (Attachment 2) 3. Potentiometric Maps for Chlorinated Polyethylene Surface Impoundment (Attachment 3) 4. 1985 RCRA Compliance Inspection conducted by PRC Engineering (Attachment 4) 5. Operating and Process Information on RCRA Units (Attachment 5) 6. Solid Waste Management Units Map (Attachment 6) 7. Subsurface Water Control Map (Attachment 7) 8. Operating Logs for RCRA Facilities (currently being compiled. Will be sent later. If you have any questions regarding this information or need additional information, please do not hesitate to contact us. Sincerely, Melissa Guise Environmental Services Attachments sb Charles Goldsmith Environmental Services AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY DO 143905 CONFIDENTIAL LOUISIANA DIVISION RCRA HAZARDOUS WASTE PERMIT ATTACHMENT 1 00 143906 CONFIDENTIAL ! DOW CHEMICAL U.S.A. October 30, 1965 PUAQUEMINE LOOIBIANA DIVISION op. box ibo LOUISIANA 707#t-0160 so see-booo CERTIFIED MAIL RETURN RECEIPT REQUESTED Mr. Glenn A. Miller, Aden;nistrator Hazardous Waste Division Office of Solid and Hazardous Waste Louisiana Department of Environmental P. 0. Box lJt307 Bator, Rouge, Louisiana 7080^ Quality PART I HAZARDOUS WASTE PERMIT APPLICATION UPDATE DOW CHEMICAL U.S.A., LOUISIANA DIVISION, PLAQUEMINE PLANT SITE LADOOS187080 Dear Mr. Miller: We are submitting several revisions to our Part I Permit Application. The revisions primarily are made to update the Part 1 to be consistent with Part II (original and deficiency correction) material submitted. Five sets of revisions are submitted in addition to the set attached to this letter. Tne additional sets are provided as replacement pages for the Part I/Part II Hazardous Waste Permit Application, Volume 1-B, E>libit A. The revisions are explained below. Revised pages are submitted as noted. 1. Section A. Item 9 The list of Louisiana Solid Waste Management Interim Permits is updated. A revised additional information page for the referenced item is included. 2. Section B, I tern 2C Explanations of revisions now submitted are listed. Previous explanations also are corrected. A revised Page B1 and an additional information Page B1 are submi tted. AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY DO 143907 CONFIDENTIAL Mr. Glenn Miller LDEQ October 30, 196b Page 2 3. Section B. Item 3 For the Solvents Plant Tanks (SOP), the process design capacity has been corrected from 82,000 gallons to 67,000 gallons. This capacity figure is consistent with the capacities of the seven tanks covered by the Part II Permit Application in Volume V, Chapter 11. A previous Part I revision had indicated changes in tanks designated as hazaraous waste storage units; Section B, I tern 3 had not been corrected. For the Environmental Operations Plant, a new hazardous waste storage tank is to be permitted and is include: in Part II correc tions submitted October 14, 1986. The process design capacity is thus revised from 64,000 gallons to 74,050 gallons. When available, photographs of the new tank will be submitted. A revised Page B2 is included. 4. Section C, Item 2A The total number of tanks (S02) is revised from 13 to 14. A revised Page Cl is included. If you have questions regarding any submitted material, please contact Carole Tuttle at 3&9-6054. Sincerely, lerry p. Martin environmental Control Manager sb Attachment D0 143908 CONFIDENTIAL. >: w.: j Wfau t K>v: Oitr.JCXl V.S.B., LOVUIK.N tiv^jor; iadodiwobo 3ter 9.tmttino Envi ronmenttl Pirrjtf Louisiana Xu ardour Vert* Manager* r,t lntt rir Ft rcit No. GD-2 34-12 , Our.* 17 . 19U New CD - 33 - 31 Lcuiti tr.e So]lie vac 1 K aneocre r.t * * lr.te ric Permit No. IP-0175?, July IE / 1585 Ir.tt: ric Pc rri t No. IP-0214, October 4,, 1984 Lc u i t i tr. t Id i tr_i t j or, s Ft rri tt Pcrrit No. Pet* 44 134 1D It 3 207 435 <3t 437 455 534 535 53C 553 554 E>U E3D 30717 3199* 1251 12ED-0 1574* 175T 1E3E7 32/70 11/72 4/73 4/73 e/n 4/75 4/75 4/75 5/75 12/75 12/75 12/75 2/7t 2/7t 12/7t 10/77 12/7E t/75 9/79 11/75 7/El S/E2 4/53 1E75 1574 imd 5/E3 9/3 1195 (Ml) 4/E4 Sec Later Modifications **RFv':SED 10/30/65 n eM Solvents Poly B - Sumer Poly P - Train 3 Clycol 3 CPI CK? - Heat Bscovcry Vinyl 3 - Waste Beat toilti Poly fc - Train 4 Vinyl 13 DcvanolE Ethanol trines CPE Ot 11 Sc rvi ct LEO 113 - Naphtha CracXer/fcen! power 13 - Turbines 100/200 Cotl Gasification Pilot Plant Clycol l/LKC 11/Vinyl 13 Central Waste Incinerators Poly C Clycol 1 Power 13 - Turbints 300/400 Cotl Slurry Preparation Ftcil: Poly B/CMP/Dowanols/Glycol 1 Tar.V. Bubbles Synfuels Project Power 13 - Turbines 300/400 CXoiif icetior.) Central Waste incinerators DO 143909 CONFIDENTIAL. i-xr. ] Aivucvno:. s^r; jol j- i--r-i--i--i--i-T--t--1--i--r i-- L D* 3.L HJED- 1 L p j 006167060 t:k~ o sorsejon: aptlicati:* Flkr* a X ir the appropriate box tr. A or B bc;c* (mar* on* be* er'.',> u mdjc.au *r,ether m.;* li the ii rst applicatior. yo,, art rimnir< lor your Jari3jf. cr s-ie^ueM app: ica: jo-.. ;r ttus- is your first a^Dcallor ars; yo. aliad;. Cxv your far;j::.i DA J.I. Ninoer. or i! tr:* is- a suifceq-jer.t application w.ter your fa liny* Da j.t Nj-twr ir. ji" 1 utxt..................... A. FIR?: AIVJCATID (Place v "X belot aod provide the appropriate dite, > ** tir^ Fac;3it> (cc^lete lt beloa) Pr^iOf the date (>-r.. mo.. da>) operatior beffar, or the date constnartior cax*r,p*c. "Tr,TT"/TKr f 11 He Facility icaxlnt- itar belc** Pi7-lOr thf date (yr. , me., day? operatior begs.' cr it erpe-rtec t; beftr y> 1C Uk-i E. S-JBSHJOT-T APT-JCATIJ- (Flare an: T btic*. ' Facility hat 3r.ienc Statt* Facility has a State Ptxu Facility has a tOsA or State Part 11 Penut C. RIMSKF. (Place a* "X beloa, or enter "KA j. | X | Peisior tc Part 3 | >; | Re-is; or tc Pi.--. 3 3 Briefly prp.-ide ar explatatior of the re.-j.stor.. Set. Attachment Itoes tfc-u ret sior. constitute i ma^or nod; f lean or. to the per Attended 4/15/85 *Revisec 10/30/85 B3 13 * DO 143910 CONFIDENTIAL rAF.7 : ;l::;.?icn section e ETA l.D. N'JKrEf LA.D0061670eC DOW CHEMICAL U.S.A., LOUISIANA DIVISION C. Briefly provide an explanation cf the revision. Section A, Iter. 9 Section E, Iter. *3 ^ Section C, Iter. 2A Section E, Iter. 3 Section C, Iter. 2 A - Se rtior. E , Iter. 9 Section Z, Iter. 3 Section E, Iter 3 `Section E, Iter 3 'Section E, Iter 3 -`Section C, Iter. 2 A `Section A, Iter. 9 Updated. Revised to indicate that two additional tanks at the Solvents Plant are designated as hazardous waste storage units and one tank is removed from hazardous waste storage designation upon reevaluation of the contents. Revised to include a proposed hazardous waste landfill. revised tc include additional property acquisitions. Container storage caracity has been recvalusted The process design capacity of the seven Solvents Plant storage tanks is corrected. R VI sed tc indicate that one additional new hazardous waste sto race ten): at the Environmental (Operations Plant is to be permitted. The existing environmental permits list (solid waste) is uj date d. Amended 4/15/61 * he vised lC/30/ei El DO 143911 CONFIDENTIAL I 3 WOii CCDC - Erter Uv cx*5* Inr tlw liat of process CQOo *m v< that bev **rr 'process it br uwc at thr fas i lit\. Ter. liner. ar prc* iOrc I or r tenng ooom ]! k rr lirx- a.~ !:, arte r thr aoe*:*) jr thr apace proiflrc If a procev r,)) br ua*e that i* nri ire)uOe jr. thr lr, of cook brio, thrr Oescribr tlw process (including ata Orsgtr. capacitv) ir the apace proidae a- tbr fore (ltr 3-C) DutaTU n COFUm** 17T> 3 (ata*- in line* brio); foeil tty ha* far tiorap tar**, orw- ta.v car hole 20C gallon an: thr other car hole 40C gallon*: Thi fcilit\ a lac ha* a- tr,cmi rstor that car belt to to I: gallons per hotr. wcas; oca wny Eti CAPA- m won: im: of iCASJi W.C1SS ODl BCOSi DCS10- CAPAOlTt AtCV-~ i*n or uiASiTi sc: ea c TO 3 <.e D to:- X E S02 74,030* G Solvents TC'X Solvents Tanks TO 2 sc: 2.6 D 57,000* G S04 1,910,00C C- S04 1,800,0DC G fla n Vinyl 11 to: Vinyl 11 Tanks TO 3 so: 1.5 D 62,200 C- T02 1,500,00< u DEO 0 A for adAltlcnal [--------- ****** or for describing other processes (code `TW ). For eact process Kterec brt include design capacity. NWLF Er;v. Op. Container de: SCI 5 IOC,000 A G E-60 HVTLF DEO 46.5 A 4. EESDUPTIO' OF RA2AJOOUS 1AETE a. pA Bf7_irrty 1ASTE yjfiDv - Efcter the four-^ligit omOer fret. LHW?., AppeniiN A ler each hiZiJTtou* waste yo- eill handle. AMENDED 10/12/84 AMENDED 4/15/65 REVISED 10/30/65 B2 00 143912 confidential 'i i i i i i i i i i i D'A ID NO. 1 A t> C C t 1 F 7 0 k C 1. Date- of Application _64___ / 5 / 21 Year Month Day 2. Activities conducted which require a TSD permit A. STORAGE PROCESS PROCESS CODE Container Tank Surface 1 rp our. dme n t SOI 02 04 NUMBER OE UNITS 1 14 2 |b. treatment PROCESS Incinerator Incinerator Surface Impoundment PROCESS CODE HANDLING CODE NUMBER OF UNITS TO 3 T07 TO 3 TOS TOO T44 1 2 1 REVISED 10/30/85 Cl DO 143913 CONFIDENTIAL DOW CHEMICAL U.S.A. October 15, 19M CERTIFIED KAIL RETURN RECEIPT REQUESTED iouTM > B. O. BOX 1B0 BLAQUCMINC. LOUISIANA 707SS-0150 BOA 3BB-B000 Mr. Glenn A. Miller, Administrator Hazardous Haste Division Louisiana Department of Environmental Quality P. 0. Box 44066 Baton Rouge, Louisiana 70804 AMENDMENT OF PART I, HAZARDOUS WASTE PERMIT APPLICATION DOW CHEMICAL U.S.A., LOUISIANA DIVISION EPA I.D. No. LAD008187080 Dear Mr. Miller: He are submitting amendments to our Part 1 Permit Application dated May 21, 1984. The amendments are submitted to correct eater well designa tions on the Section A map, to denote and account for a function change of a storage tank and to list an additional waste. The amendments are made in accordance with LBWR 3.2K). The amendments are explained below. Amended pages are submitted as noted. 1. Section A, Item 10, Map The drinicing water well identified on the map as 109 (WBR 109) is designated as plugged and abandoned on Louisiana Department of Transportation and Development (LDOTD) listings of 5/31/84. Inspection by Dow personnel confirms that the well has been abandoned. Hell 109 should be deleted from the map. The well noted as 138 (IB 138) is indicated, on the same LDOTD listings as abandoned. AN OP DO 1.43914 CONFIDENTIAL Hr. Glenn Hiller Page 2 October 15, 1984 2. Section B, Itan 3 Process Code This section is amended to reflect that one tank formerly used to store feed to a thermal oxidizer has changed function. The tank is now a storage unit for feed to a heat recovery unit. An amended Page B2 is submitted. 3. Section C, Item 2A Storage (Activities which *squire a TSD Permit) According to the amendment explained in No. 2 above, the number of tanks used for the storage of hazardous waste is changed from 13 to 12. An amended Page Cl is submitted. 4. Section B, Iten 4 This section is amended to add EPA Hazardous Haste No. P024 to our list. This waste number was added to the LHWR 24.1a) with the Duly 20, 1984 amendments. An amended Page B5 is submitted. Please contact us if you have questions. Sincerely, Carole K. Tuttle Environmental Specialist Attachment DO 14391S CONFIDENTIAL EET 0 8 1 e 7 0 e 0 3. PIOTSS CCCC - the code Ins the list of process code* attached that best describes each process to be tasd at the facility, tm lines are provided for entering codes. If sore lines ere needed, alter the oode(s) in the space provided. If a process will be taed that is not included in the list of codes beloe, then describe the process (including its desgin capscitv) in the space provided on tbe tom (luu 3-C) SiAlffU TOR caemnc TTSM 3 (shewn In llnas below): A facility has no storage tanks, one tank can bold 300 gallons and the other can hold 400 gallons: Ite facility also has an in cinerator that can burn t? to 20 gallons per bow. process an PROCESS IS1O' CAPACITY AltXKT (KIT or MEASURE process are process asia; capacity AMOUNT trr OF MEASURE SOS 600 C TO 3 4.6 D 703 30 E S02 64,000 G T03 02 2.6 D 82,000 G S04 1,910,00( S04 1,600,001 G G TO 3 1.5 D S02 45,000 G TQ2 1,500,001 D80 0 U A *P-~ tor process codes or for rtea-rtblng other processes (code TW"). for meb process altered here include design capacity. D80 SOI 12 180,000 A G 4. DESaaPTIW or BAZAKOUS CASHS A. IPA BAZAfSOOS BASTE KIMBEP - toter tbe fouTHliglt mntaer Iran UWR, Appendix A lor each haxardca* waste you will handle. AMENDED 10/12/84 62 DO 143916 CONFIDENTIAL 4. D>A HUJUOOtS ASTI 1C. tenter cede) D001 . ErrwriD AWIUL guANrm of usn c. tun or ttusua (enter code) o. noassxs l. mass croc (enter) 2. FKX2SS tCCTumo (tf cede u cot entered In 1X1)) SOI S02 T03 < l T 000 DO 02 D001 D003 F024 40 1000 Included with above SOI S02 T03 T 000 Included with above T S02 T03 (Dhotocapv this pace before caroletinc if needed for additional wastes) AMENDED 10/12/84 B5 00 143917 CONFIDENTIAL " I * 1 I "I 'I I I I l""T 'I ERA ID NO. npocemoei 1. Date of Application 84 / 5 / 21 Tear Month Day 2. Activities conducted which require a TSD permit . STORAGE PROCESS PROCESS CODE Container Tank Surface Impoundment SOI S02 S04 NUMBER OF UNITS 1 12 2 . TREATMENT PROCESS Incinerator Incinerator Surface Impoundment PROCESS CODE HANDLING CODE NUMBER Or UNITS TO 3 TO7 TO3 TO6 T02 T44 1 2 1 AMENDED 10/12/8 Cl DO 143918 CONFIDENTIAL DOW CHEMICAL U.S.A. May 21, 1964 CERTIFIED MAIL RETURN RECEIPT REQUESTED LOUISIANA DIVISION P. O. SOX ISO PLAOUEMINE. LOUISIANA 707S6-O160 S04 3 000 Mr. Gerald D. Healy, Jr. Administrator, Hazardous Haste Division Louisiana Department of Environmental Quality P. 0. Box 44066 Baton Rouge, Louisiana 70804 PART I PERMIT APPLICATION DOW CHEMICAL U.S.A., LOUISIANA DIVISION - LAD008187080 Dear Mr. Healy*. We submit, with this letter. Part I of the Dow Chemical U.S.A., Louisiana Division Permit Application for units which treat, store or dispose of hazardous waste. We have responded to each item according to our understanding of information required. Contact us if you have questions regarding the responses. Sincerely, jy B. Martin ironaental Control Manager sb DO 143919 CONFIDENTIAL LOUISIANA DIVISION RCRA HAZARDOUS WASTE FINANCIAL RESPONSIBILITY ATTACHMENT 2 D0 143920 CONFIDENTIAL a % THE DOW CHEMICAL COMPANY 2030 Willard H. Dow Center April 28, 1986 MIDLAND MICHIGAN 48674 ENVIRONMENTAL' CONTROL37' * * * Joy A. Bartholomew Deputy Secretary Department of Environmental Quality Post Office Box 44066 Baton Rouge, LA 70804 MAY 11986 Ms. Bartholomew: Attached is the documentation in support of the use of the financial test to demonstrate financial responsibility for liability coverage and closure and post-closure care as specified in Chapter 20 of the Louisiana Hazardous Waste Management Plan (HWMP). These documents reflect several changes from our prior submission due to following recent events: 1) The incorporation of the Health and Consumer Products Department as Dow Consumer Products, Inc., a subsidiary of The Dow Chemical Company; 2) The merging of the Oyster Creek Division into Texas Operations; and 3) The revision of closure and post-closure cost estimates, due to changes in unit operations within the facilities and to new regulatory requirements. These are denoted by an asterisk (*) in the letter from Mr. Falla. Any questions concerning the attached documents should be directed to: Byron R. Crary 2030 Willard H.Dow Center Midland, MI 48674 (517) 636-2638 / Environmental Law/Section Legal Department' Attachments DO 143921 CONFIDENTIAL Secretary Louisiana Department of Environmental Quality P. O. Bent Lt*066 Baton Rouge, LA 70SOL Dear Madam: I am the chief financial officer of The tv*.' Midland, Michigan 48640 This letter is in support of tne use of tne financial test to demonstrate financial responsibility for lability coverage and closure and post-closure care* 1 2 3 as specified in Chapter 20 of the Louisiana hazardous Uaste Regulations (LHWRf. The owner or operator identified above is the owner or operator of the following facilities for which liability coverage is being demonstrated through the financial test specified in Chapter 20 of the LHU'R. See Exhibit LA The owner or operator identified above is the owner or operator of the following facilities in states other than Louisiana for which liability coverage is being demon strated through a test equivalent or substantially equivalent to the financial test specified in Chapter 20 of the LHWR. See Exhibit Federal 1. The owner or operator identified above owns or operates the following facilities for which financial assurance for closure or post-closure care is demonstrated through the financial test specified in Chapter 20 of the LHWR. The current closure and/or post-closure cost estimates covered by the test are shown for each facility: See Exhibit 1 2. The owner or operator identified above guarantees, through the corporate guarantee specified in Chapter 20 of the LHU'R, the closure and post-closure care of the following facilities owned or operated by its subsidiaries. The current cost estimates for the closure or post-closure care so guaranteed are shown for each facility: See Exhibit 7 3. In States other than Louisiana, this owner or operator is demonstrating financial assurance for the closure or post-closure care of the following facilities througr. the use of a tesi equivalent or substantially equivalent to the financial test specified in Chapter 20 of the LHWR. The current closure and/or post-closure cost estimates covered by such a test are shown for each facility: See Exhibit 3 L. The owner or operator identified above owns or operates the following hazardous waste management facilities for which financial assurance for closure or, if a disposal facility, post-closure care, is not demonstrated either to the U-S- Environmental Protection Agency or to a State through the financial test or any other financial assurance mechanism in Chapter 20 of the LHWR or equivalent or substantially equivalent State mechanisms. The current closure and/or post-closure cost estimates not covered by such financial assurance are shown for each facility: See Exhibit L DO 143922 CONFIDENTIAL 00 143923 CONFIDENTIAL PART B.r'CLOSURE OR POST-CLOSURE CARE AND LIABILITY COVERAGE ALTERNATIVE I i. Sum of current closure and post-closure cost estimates (total of all cos: estimates listed above) _ ,,-- $ 95.5 .2 Amount of annual aggregate liability coverage to be demonstrated: $ 15 M 3. Sum of lines 1 and 2: $ 110-5 M 4. * 5. * 6. * 7. * 8. 9. * 10. * 11. 12. 13. 14. 15. 16. 17. IS. 19. Total liabilities (if any portion of your closure or post-closure cost estimates is included in your total liabilities, you may deduct that portion from this line and add that amount to lines 5 and 6): $ 7,038 M Tangible net worth: $ 4,133 M Net worth: $ 4,792 M Current assets: $ 4,324 M Current liabilities: $ 2,975 M Net working capital (line 7 minus line S): $ 1,349 M ' The sum of net income plus depreciation, depletion, and amortization: 1,035 M Total assets in U.S. (required only if less than 9095 of assets are located in the U.S.) 6,197 M Is line 5 at least $10 million? Is line 5 at least 6 times line 3? Is line 9 at least 6 times line 3? Are at least 90% of assets located in the LLSJ? Is line 11 at least 6 times line 3? Is line 4 divided by line 6 less than 2.0? Is line 10 divided by line 4 greater than 0.1? Is line 7 divided by line 8 greater than 1.5? YES X X X X X X . NO X X, tr This owner or operator is _ required to file a Form 10K with the Securities and Exchange Commission (SEC) for the latest fiscal year. The fiscal year of this owner or operator ends on December 31 # The fi!Mir(lt for the following items marked with an asterisk" are cerived from this owner's or operator's independently audited, year-end financial statements for the latest comDle- ted year, ended December 31, 1985 ^ DO 143924 CONFIDENTIAL I hereby certify that the wording__of this letter is identical to the wording specified in Section 20.l9g)^as-'Tuch regulations were constituted on the date shown immediately below. (Signature) (Name) (Title) (Date) Laue^c7 Falla Financial Vice President April 23, 1986 DO 143925 CONFIDENTIAL DO-tIBIT LA List of Louisiana facilities for \xhich liability assurance is being demcnstrated through the financial test frcm Louisiana Hazardous Waste Regulat ions Sudden Insurance Nonsudden Insurance Facility Address EPA IDii The Dow Chemical Company p`' Box 150 Plaquemine, LA 70765 LAD008187080 $ 5M 5 10 M Faci1itv Address EPA ijy/ Faci1ity Address EPA IDS'/ Greatest Arount of Insurance for any 1 facility $_____ s 15 D0 143926 CONFIDENTIAL t tr EXHIBIT FEDERAL List here, the facilities not in Louisiana with liability assurance being demonstrated through a financial test substantially equal to the Louisiana financial test. Faci 1ity Address EPA IDff Allyn's Point Plant Route 12 Gales Ferry, CT 06335 CTD001159730 Sudden Insurance 2M Nonsudden Insurance 6M Faci1ity Address EPA IDII The Dow Chemical Company North Haven Lab 410 Sackett Point Rd. North Haven, CT 06473 CTD000635896 2M 6M FaciIity Address EPA IDit Dalton Plant 1468 Prosser Drive, S.E. Dalton, GA 30720 GAD045929643 2M 6M Faci1ity Address EPA IDff Joliet Plant P-O. Box 368 Joliet, IL 60434 JLD093154599 2M 6K Facility Address Ludington Plant S. Madison and Seventh Xu&ingron, MI 49431 EPA ID* MID006016919 2M 6M Creates! Total of Sudden and Nonsudden $ sm Enter on line 1 or line 2 of Part A or ParT.B respectively, of financial liability version the greater nuTfcer of Exhibit LA or EXHIBIT FEDERAL. Do not enter the sun of LA and Federal. DO 143927 CONFIDENTIAL EXHIBIT FEDERAL (Continued) Sudden Insurance Facility Address EPA ID# Midland Plant 628 Bldg. Midland, MI 48640 MID000724724 2M Facility Address EPA ID# Salzburg Landfill Salzburg & Waldo Roads Midland, Ml 48640 MID908617435 2M Facility Address epa mi Merrell Dow Pharmaceuticals Inc. 2111 . Galbraith Road Cincinnati, OH 45215 2M OHD004254702 Facility Address EPA ID# Findlay Plant P.0- Box 708 Findlay, OH 45840 OHD005053624 2M Facility Address epa mi Hanging Rock Old 52 Highway Ironton, OH 45638 OHD039128913 2M Facility Address EPA mi Granville R&D P.0. Box 515 Granville, OH 43023 OHD081287294 2M Nonsudden Insurance 6M 6M 6M 6M 6M 6M DO 143928 CONFIDENTIAL. EXHIBIT FEDERAL (Continued) Facility Address EPA ID// Dow Consumer Products, Inc. 5859 W. 96 Street Indianapolis, IN 46268 IND000195545 Sudden Insurance 2M Facility Address epa mi Magnolia Plant P.0. Box 520 Magnolia, AR 71753 ARD041580762 2M Facility Address epa mi Russellville Plant P.0. Box 1048 Russellville, AR 72801 ARD051965416 2M Facility Address epa mi LaPorte Facility P.O. Box 687 LaPorte, TX 77571 TXD000017756 2M Facility Address EPA ID// Texas Operations B-1226 Freeport, TX 77541 TXD008092793 2M Facility Address epa mi Riverside Plant P.O. Box 387 Pevely, MO 63070 MOD001829852 2M Facility Address EPA ID// Alaska Ave. Facility 530 Alaska Ave. Torrance, CA 90503 CAD990862864 2M Nonsudden Insurance 6M 6M 6M 6M 6M 6M 6M 00 143929 CONFIDENTIAL EXHIBIT FEDERAL (Continued) Facility Address EPA ID# Torrance Plant 305 Crenshaw Blvd. Torrance, CA 90503 CAD009547050 Facility Address epa mi Pittsburg Plant P.0. Box 1398 Pittsburg, CA 94565 CAL076528678 Sudden Insurance 2M 2M Nonsudden Insurance 6M 6M DO 143930 CONFIDENTIAL EXHIBIT I List of Facilities in Louisiana for which financial Assurance is being demonstrated through the Louisiana financial test for Louisiana Hazardous Waste Regulations. Faci 1 ity Address EPA ID'/ The Dow Chemical Company Louisiana Division P.0. Box 150 Plaquemine, LA 70765 LAD008187080 Closure Cost 3,696* M Post Closure Cost 379 m Faci1ity Address EPA I D/I Facility Address EPA ID/ Subtotal Closure and Post Closure Costs Total Closure and Post Closure Cost $ 3*696 m $ 379 m $ 4,075 m DO 143931 CONFIDENTIAL i EXHIBIT 2 List of Facilities for which financial assurance is being demonstrated through the cor porate guarantee. Closure Cost Post Closure Cost Faci1ity Address EPA in'/ Faci1ity Address EPA ID# NONE Faci1ity Address EPA ID# Faci1ity Address EPA ID# Subtotal %5 ^ Total Closure and Post Closure Costs $ Note: Photo copy this page if there are more facilities than can be listed here DO 143932 CONFIDENTIAL t t * EXHIBIT 3 List of Facilities outside of Louisiana for which closure post closure financial assur ance is being demonstrated a financial test substantially equivilant to the Louisiana financial test. Faci1ity Address EPA IDif Allyn's Point Plant Route 12 Gales Perry, CT 06335 CTD001159730 Closure Cost 26,091* Post Closure Cost Fac i 1ity Address EPA ID// Dalton Plant 1466 Prosser Drive, s.E. Dalton, GA 30720 GAD045929643 7,508 Faci1ity Address EPA ID// Joliet Plant P.O. Box 368 Joliet, IL 60434 ILD093154599 66,606 Faci1ity Address EPA iat Ludington Plant S. .Madison and Seventh Ludington, MX 49431 MID006016919 4,500* Faci1ity Address EPA ID// North Haven Lah 410 Eachett Point North Haven, CT 06473 CTD000635896 12,231 FaciIity Address EPA ID// LaPorte Facility P.O. Box 687 LaPorte, TX 77571 TXD000017756 Subtotals Closure and Post Closure Costs Total Closure and Post Closure Costs 3,839,019 15,867,354 DO 14393"3 CONFIDENTIAL $ $$ $ EXHIBIT 3 List of Facilities outside of Louisiana for which closure post closure financial assur ance is being demonstrated a financial test substantially equivilant to the Louisiana financial test. Faci1ity Address EPA IDif Midland Plant 628 Bldg. Midland, MI 48640 MID000724724 Closure Cost 38,724,538* Post Closur Cost 15,830,772* Faci1ity Address EPA ID1/ Salzburg Landfill Salzburg Waldo Roads Midland, MI 48640 KID980617435 1,018,265 931,830* Faci1ity Address EPA ID# Merrell Dow Pharmaceuticals, Inc. 2110 E- Galbraith Road Cincinnati, OH 45212 OHD004254702 Faci1ity Address EPA ID# Findlay Plant P-O. Box 708 Findlay, OH 45840 OKD005053624 64,442 39,782* Faci1ity Acdress EPA ID# Hanging Rock Old 52 Highway Ironton, OH 45638 OHD03912891'3 Faci1ity Address EPA ID# Granville, RD PD..-Box 515 ______ Granville, OH 43023 OHD081287294 Subtotals Closure and Post Closure Costs' Total Closure and Post Closure Costs 22,614 5,279* DO 143934 CONFIDENTIAl *$ S rr- EXHIBIT 3 List of Facilities outside of Louisiana for which closure post closure financial assur* ance is being demonstrated a financial test substantially equivilant to the Louisiana financial test. Faci1ity Address EPA ID# Dow Consumer Products, Inc. 5859 W. 96 Street Indianapolis, IN 46268 IND000195545 Closure Cost 68 264 post Closur Cost FaciIity Address epa i d# Magnolia Plant P.O. Box 520 Magnolia, AR 71753 ARD041580762 67 278 Faci1ity Address epa id# Russellville Plant P.O. Box 1048 Russellville, AR 72801 ARD051965416 44,900* Faci1ity Address EPA ID# Texas Operations B-1226 Freeport, TX 77541 TXD008092793 5,836,905* 352,872* Faci1ity Address epa id# Riverside Plant P.O. Box 387 Pevely, MO 60370 MOD001829852 Faci1ity Address EPA ID# -- _ .. . - 65,151 DO 143935 CONFIDENTIAL Subtotals Closure and Post Closure Costs Total Closure and Post Closure Costs $$ $ EXHIBIT 3 List of Facilities outside of Louisiana for which closure post closure financial assur ance is feeing demonstrated a financial test substantially equivilant to the Louisiana financial test. Facility Address EPA IQ? Torrance Plant 305 Crenshaw Blvd. Torrance, CA 90503 CAD009547050 Closure Cost .... . 45,627* Post Closure Cost Faci1ity Address epa icy/ Pittsburg, CA 94565 CAD076528676 6 924 000 i'548'oo Faci1ity Address EPA IQZ Alaska Avenue Facility 530 Alaska Ave. Torrance, CA 90503 CAD990662B64 ^2 501* ' Faci1ity Address EPA IDn Faci1ity Address EPA IDft Faci1ity Address epa icy/ Subtotals Closure end Post Closure Costs Ttal Closure and Post Closure Costs DO 143936 CONF1 DFN"T 1AL $ 56.895.501 $ 34.530,325 -r-vo 1 i fr EXHIBIT 4 List of Facilities for vtfiich no financial assurance is being demonstrated. Closure Cost Post Closure Cost Faci1ity Address EPA IDff NONE Faci1ity Address EPA IEV/ Subtotals Closure and Post Closure Costs Total of Closure and Post Closure Costs $$ $ DO 143937 CONFIDENTIAL. POTENTIOMETRIC MAPS FOR THE CHLORINATED POLYETHYLENE SURFACE IMPOUNDMENT ATTACHMENT 3 DO 143938 CONFIDENTIAL DO 14393*9 C O N F ID E N T IA L DO 1 4 3 9 4 0 C O N F ID E N T IA L 1//" ' -- ' /" -- ...................... ' ' * A MW-3 (NC3) .... - - ---- EXHIBIT 3 1 1985 RCRA COMPLIANCE INSPECTION CONDUCTED BY PRC ENGINEERING ATTACHMENT 4 OO 143941 CONFIDENTIAL DOW CHEMICAL U.S.A. October 1, 1985 CERTIFIED MAIL RETURN RECEIPT REQUESTED LOUISIANA DIVISION P. O BOX ISO PLAQUiMINE. LOUISIANA 7O7SS-O1S0 boa iis-sooo Mr. Glenn A. Miller Office of Solid and Hazardous Waste Department of Environmental Quality P. 0. Box 44307 Baton Rouge, Louisiana 70604 RESPONSE TO JUNE 25, 1985 RCRA GROUNDWATER INSPECTION REPORT RECEIVED SEPTEMBER 12, 1965 DOW CHEMICAL U.S.A., LOUISIANA DIVISION Dear Mr. Miller: On June 25, 1985, PRC Engineering (authorized by the U.S. Environmental Protection Agency, Region VI) and the Louisiana Department of Environmental Quality conducted a RCRA groundwater monitoring compliance inspection at Dow Chemical U.S.A., Plaquemine, Louisiana. On September 12, 1985, Dow received a copy of the report which PRC Engineers generated from that inspection. Attached please find Dow's comments on that report. Should you have any questions regarding these comments, please do not hesitate to contact Melissa Guise (504)389-1899. Sincerely, Jerry Martin Environmental Services Manager Attachment sb DO 143942 CONFIDENTIAL The following pages contain Dow's comments to the report which PRC Engineers generated from the RCRA groundwater monitoring compliance inspec tion of the Dow Chemical Plaquemine plant. General comments were made with regard to the text of the report, as well as specific comments in response to the sections of the report on conclusion/recommendations and apparent deficiences/apparent violations. DO 143943 CONFIDENTIAL ) GENERAL COMMENTS OK THE TEXT OF THE PPC REPORT General C ent #1 On Page 8 of the PRC report, the statement is made that the Northwest Landfill is diked and equipped with a sump to collect surface runoff which is routed to Bayou Bourbeaux. When the landfill was initially opened sur face, runoff was in fact collected and routed to Bayou Bourbeaux. However, for the past approximately two years, the surface runoff collected at the Northwest Landfill has been routed to the Division cooling water canal system and discharged through a proposed NPDES Internal Outfall #3001. General Comment 2 On Page 12 under the section of hydrogeology, the statement is made that two zones (shallow and deep pervious zones) are known to be hydraulically interconnected based on results of hydrogeologic study of a proposed land fill site (Guise, Dow, February, 1985). Potentiometric level collected in both the shallow and the deep pervious zones indicate similar groundwater flow directions. This would indicate a possible hydraulic connection between these two zones in the area where the measurements were taken. General Co--ent #3 Under the section entitled S.2 Sampling Methods and Equipment, Page 27, it is noted that three newly installed wells did not have elevations established at the time of the inspection. The surveying of those eleva tions and location coordinates have been completed and that information is included in Table 1. General Comment #4 Several errors were noted on Table 3 monitor well details. The screen setting below the land surface (-ft) is incorrect for the following wells: UNI, UN2, and DN4. UNI should be 44.0 - 47.0 feet bis, UN2 should be 40.0 to 45.0 feet bis,and DN4 should be 40.0 to 45*0 feet bis. DO 1.43944 CONFIDENTIAL Groundwater Inspection Report Comments Page 2 Well * DA 5 DA 6 NBU DN6 NB3 (reshot) Table 1 Elevation to Datum Feet Mean Sea Level 22.61 23-22 23-09 19-33 23.^0 Dow Location Coordinate Bn 4 H8.20N 182 4 81. ME 83 4 52. IJON 180 4 35.26E 87 4 52.0UN 192 4 08.58E 106 4 B5.01N 117 4 01.60E 92 4 51.72N 187 4 99.03E Please note on NB3> the elevation to reference datum was initially reported to the Louisiana Department of Environmental Quality as 23.69 ft (mean sea level). This measurement was made prior to installation of the well wizzard pumps. When the pump was installed, the reference datum was altered slightly. This, however, does not change the general direction of groundwater flow in this area. DO 143945 CONFIDENTIAL Groundwater Inspection Report Comments Page 3 COMMENTS ON CONCLUSION AND RECOMMENDATIONS OF THE PRC REPORT PRC Recommendation #1 As was discussed with facility personnel, a standardized procedure for water level measurement should be implemented at the Dow facility. The presence of the dedicated pumping system in each well may influence water level mesurements. Tnese water level measurements are crucial due to the low hydrualic gradients encountered in this area. If water levels are not measured accurately, actual flow directions cannot be established. Dow's Cogent The dedicated pumping system that Dow is currently using in all of the monitoring wells consist of a bladder pump suspended in the well by two Teflon* tubes. The Teflon* tubes are attached to a well cap. In order to take a depth-to-water measurement, the top well cap is removed. Dow has marked the tubing connectig the pump to the well cap so the same length of tubing is pulled from the well each time a measurement is taken. PRC Reco--endatlon 42 The wells near the Chlorine Plant may be influenced by the brine water that is in the series of impoundments. No monitoring data was seen for well NB3 (the upgradient well), but if this well is being influenced by the impound ment contents, further investigation and installation of wells may be necessary. This point vas raised by an LDEQ employee who is familiar with the facility and was not brought out in any of the documents obtained the in any of the documents obtained by the inspection team. Dow's CoMepts Salt is present in the shallow soils around the Chlorine Plant Surface Impoundment. Dow is currently reviewing this situation, and will con tinue communication with the Louisiana Department of Environmental Quality. DO 143946 CONFIDENTIAL Groundwater Inspection Report Consents Page 4 PRC BecoendatloD The numerous ditches carrying wastewtaer to the NPDES discharge point which are known to influence groundwater flow in the shallow zone (Guise, February 1985) may contribute contaminants to the shallow zone. Depending on the exact nature of the influence exerted by the canal system (details were not included in Dow materials obtained by the inspection team), it is possible for the canal to be a recharge source for the shallow pervious zone. Further investigation of this question may be warranted to determine if material transported in the canal system is entering the shallow per vious zone. Dow's Comment The potentiometric data collected from the monitoring wells at the Chlorine and Chlor-Alkali II Surface Impoundments indicate a hydraulic connection between this zone and the shallow cooling water canal system present in the Division. The cooling water canal system is monitored and all discharges go through a permitted NPDES discharge point. Dow has monitoring wells downgradient of all of the hazardous waste facili ties which require groundwater monitoring. This shallow zone is not a source of drinking water and Dow feels further investigation is not warranted. PRC Recoroendation #4 The presence of one deep and three shallow monitoring wells downgradient of the Northwest Landfill may be insufficient to accurately detect any con tamination released from that facility. Although Dow maintains that only cell No. 3 contains hazardous waste, some investigation may be necessary to substantiate this claim. Dov's Cogent Dow is currently proposing to install two additional downgradient moni toring wells at the Northwest Landfill. Exhibit 1 of this document shows the location of the existing wells -at the Northwest Landfill and the location of the two proposed wells. Pilot soil borings will be drilled prior to the installation of these wells to define the stra tigraphy of this area. All existing monitoring wells at the Northwest Landfill are screened between 40 to 50 feet below the land surface with the exception of one well (NN5) which is screened at approximately 110 feet below the land surface. DO 143947 CONFIDENTIAL Groundwater Inspection Report Comments Page 5 The silt zone between Jjo to 50 feet below the land surface will pro bably be the zone in which the two proposed wells will be screened. However, as mentioned above, pilot soil borings will be drilled and the stratigraphy described prior to the installation of these wells to ensure that the first continuous pervious zone is screened. DO 143948 CONFIDENTIAL 'Groundwater Inspection Report Comments Page 6 COMMENTS ON APPARENT DEFICIENCIES IN SAMPLING PROCEDURES AND THE GROUNDWATER MONITORING SYSTEM AT DOW CHEMICAL Apparent Deficiency #1 Slumping of annular space material was noted around well casings which may indicate a defective annular space sealing procedure. Dow's Coment It was noted during the groundwater compliance inspection that slumping of the annular space had occurred in three wells DN6, NB1, and NB2. During the normal process of backfilling any soil boring or the annular space of a well, some natural consolidation occurs because the hydrostatic head of the column of cement/bentonite and its density causes the cement/bentonite to flow into the pervious zones, resulting in a slumping of the cement in the borehole or annular space of the well. When this occurs, Dow will top these borings/wells off with cement/bentonite to ensure a good seal to the land surface. Prior to adding additional backfill to the wells sited above, (NB1, NB2, and DN6) Dow will test the integrity of one of these wells by con ducting a pressure test. The results of the pressure test will be reported to the Louisiana Department of Environmental Quality. Apparent Deficiency #2 Monitoring wells constructed with glued Joints may contribute to elevated trace organic l-evels in the groundwater and/or -falsely add trace organics to groundwater samples. Dow's Consent As noted in the PRC report, Dow is aware of the face PVC pipe with cemented Joints can impact the quality of groundwater samples collected from these wells. Dow conducted a study on this problem in the early part of 19B3. Dow concluded from the study that trace organics were originating from the PVC well casings and Dow pas observed trace organic levels decrease over time. Dow no longer uses PVC as a material of construction for monitoring wells. A recently installed monitoring wells have been constructed of polyethylene casing and stainless steel screens. DO 143949 CONFIDENTIAL Groundwater Inspection Report Comments Page 7 APPARENT VIOLATIONS IN SAMPLING PROCEDURES AS" THE GROUNDWATER MONITORING SYSTEM AT DOW CHEMICAL Apparent Violation #1 Calculations made to determine the mean and variance for upgradient wells (also downgradient wells; however, these are not required) were done incorrectly. Therefore, the calculations for t# and tc are incorrect. [Section 365.93(b)3 Dow's Comment For reasons cited in other correspondence with the Louisiana Department of Environmental Quality, Dow feels that statistical analysis of groundwater data using the prescribed Behrens-Fisher Student's t-test results in a high percentage of false positives. Below is a recap of Dow's current procedure for statistical analysis and explanation why this procedure is used: A. The four replicate samples for each parameter, for each well, are averaged together prior to proceeding with the calculations in order to minimize the effect of analytical variability. For example, past data history shows that there is a greater variation in quarterly data (i.e. cylindrical seasonal data) than in the four replicate samples taken at the same time and analyzed on the same analyzer. If an N * 16 is utilized (one year's data Including individual replicates) then the small analytical variation when input into the statistical equations, will result in lower standard deviation and variance, Wb, and Wffi values which increases the t* value and lowers the tc value. According to the regulations, if the t# is less than tc, then it is concluded that most likely there has not been a change in this parameter. Bowever, by using Ns 16, ta is increased, tc is decreased resulting in a larger number of false positives. D0 143950 CONFIDENTIAL Groundwater Inspection Report Comments Page 8 B. Four quarters of the replicates samples were averaged together for the compliance point well. The reason Dow uses four quarters of data for the compliance point well is to allow for seasonal variations. The major concern is cyclic seasonal changes in groundwater quality which may be mistaken for contamination par ticularly for the indicator parameters (pH, specific conductance, TOC, TOX). For example, pH in shallow aquifers can change with dissolved carbon dioxide content in groundwater. Specific conduc tance can be influenced by fluctuating wet and dry seasons. In addition to seasonal variation, groundwater quality is also controlled by numerous other factors. The mineralogy and microbial nature of the medium through which the water flow mode, mixing of water of different quality, and reuid3nce time of groundwater can also influence groundwater quality and result in quality fluctuations. For the reasons cited above, Dow feels that uncontrolled variation will be minimized thus minimizing the chances for false positives. Apparent Violation #2 Dow collected background data beginning in the fourth quarter of 19B2 and continuing through the fourth quarter of 1984. In some cases (e.g., groundwater quality parameters), data is incomplete. Background data is required to be established for all monitoring wells quarterly for one year. [Section 265.92(c)] Dow's Coepent According to Dow's records, all Background data for all wells, except the recently -installed wells at the Chlorine and Chlor-Alkali II sur face impoundment, is complete. Not all background data for all parame ters was collected during the same time period. The reason for this is as the hazardous waste regulations have changed over the years so have the parameters to be analyzed. Therefore, not all background data for all parameters were collected during the same time period. DO 143951 CONFIDENTIAL Groundwater Inspection Report Comments Page 9 Apparent Violation #3 Dow does not have the required number of wells correctly located around the CPE surface impoundments as prescribed in the regulations. At least three downgradient wells are required and due to changing groundwater flow direc tions during the summer, only two wells are truly downgradient of the CPE impoundment throughout the year. [265.91(a)(2)] Dow's Coment The monitoring well network at the CPE surface impoundment consists of four wells NCI, NC2, NC3, and NC^J. The-groundwater flow direction as determined by the current groundwater monitoring network at the CPE surface impoundment appears to shift slightly throughout the year. A total reversal of flow has not been observed, but rather a shift from a predominantly westerly direction to a periodic flow in a southwesterly direction. The groundwater flow direction is in a westerly direction (Dow coordinates) approximately ten months out of the year. During this time, wells NCI and NC2 function as downgradient wells. Periodically, the groundwater flow direction has been observed to shift slightly to the southwest. During this time, wells NCI and NC2 function as downgradient wells. NC3 is located such that in the event the groundwater flow direction shifts slightly to the north then NC3 will func tion as a downgradient well. HG :sb 10/85 GW-1965 DO 143952 CONFIDENTIAL rviiini-r DO 1 4 3 9 5 3 C O N F ID E N T IA L DOW CHEMICAL U.S.A December b, 1905 CERTIFIED MAIL RETURN RECEIPT REQUESTED LOUISIANA DIVISION P. O, BOX 1(0 riAQUEMINt LOUISIANA 7066-0160 604 366-6000 Mr. Glenn A. Miller Office of Solid and Hazardous Waste Department of Environmental Quality P. 0. Box 1*4307 Baton Rouge, Louisiana 70801* FOLLOW-UP ON DEFICIENCIES SITED IN PRC REPORT DOW CHEMICAL U.S.A., LOUISIANA DIVISION Dear Mr. Miller: In November, 1985, Dow Chemical installed two additional groundwater monitoring wells at the Northwest Landfill. Prior to well installation, two pilot soil borings were drilled to define the stratigraphy. Logs for these soil borings are included in Attachment 1. It was determined from the pilot soil borings that the first continuous pervious zone suited for groundwater monitoring occurred between 40 to 50 feet below the land surface. (This is the 2one currently being monitored at the Northwest Landfill.) Well loca tions and well completion diagrams are included in Attachment 2. It was noted during the groundwater compliance inspection that slumping of the backfill had occurred in the annular space of three of Dow's groundwater monitoring wells. To test the integrity of these wells, Dow has proposed to conduct a pressure test on one of the wells. In order to conduct this test, a well packer must be used. Dow is currently waiting on delivery of this packer. Should you have any questions regarding information discussed above, please do not hesitate to contact Melissa Guise (504)389-1899. .Sincerely, Vayn^ Turner Environmental Services Manager sb DO 143954 CONFIDENTIAL ATTACHMENT 1 DO 143955 CONFIDENTIAL f'------------------------------------------PROJECT Northwest Landi.ll -- NATES LOCATION Louisiana Division of Dow Cnemical Company DRILLING COMPANY Barrington Drilling ELEVATION (NATURAL GRADE) ________________ Company________________ 1 riul DATt :i;::/EE TECHNIC UN Y.c APPBOytC pace 1 O' 2 0*1 AutHtP WASH I0*[C a ~* r I a O' to 6* E ' to 5.2 * Water initially entered borehole at 6 feet. Water level at 25 inches after a 15 minute observation period. if ,j*n, *n m <nn IUfMTTl S Brd7vWBr (WT, L(VA rf.wt 0 Erown Sandy SILT or nun* - 5- Brown and tan Silty CLAYS with sandy silt pockets becoming brown clay. Medium: light brown to gray CLAYS with ferrous nodules with silty clay layer at 7'. - 10* - 15- 20- Brown and gray Silty CLAYS with silt pockets becoming gray and brown CLAYS Medium gray CLAYS with organic material and ferrous nodules. -- with root hair. -- with silty clay pocket -- stiff fractures. -- with wood pieces. -- with calcerous nodules. --r-- to CN ___ L - . - 30 - - 35 - 40 -- slickensided. -- trace chells no fractures. -- with silty clay pocket, -- with shell layer and 4" peat layer. DO 1439S6 CONFIDENTIAL PROJECT Northwest, ~u.it,>.,! COORDINATES LOCATION Louisiana Division of Dow Chesi cal Company elevation DRILLING COMPANY Barrington Drilling Co. (NATURAL GRADE) ff DT AUCfMl ** 5 E 2*: : DN" 0*f 11/12/65 technician ^-C APPROVED PAGE 2 o' 2 f t AfTi 7n"wI1fnnWrrii~ir "co5rrWw - 40" ,r - 45 - - 50- - 55- u rn.wi Mxamoit' rnuru* Gray Silty CLAYS with silt seams, wood pieces and root hair. -- with calcerous nodules and clay lense. -- with Sandy silt lenses and clay pockets. i -- becoming gray CLAYS. Medium gray CLAYS with wood pieces and organic mate rial. -- with silty clay pockets and calcerous Bottom of boring 52 feet. Grouted Full Depth. - 60- - 65 - ----- -P---- 0 1 - 75 80 DO 143957 CONFIDENTIAL ; rc.-:' northwest Landfi... lOt AT ION Louisiana Division of Dow Chemical Company DRILLING COMPANY Barrington Drilling ELEVATION (NATURAL GRADE) fi=uSar. | Dt AUCfUJt WAS- I0*ED *pI A. c to a* e* to S2* S t - Water initially entered borehole at 8 feet* Water level at after a 10 irdnute observation period. boring FILE _ D*Tt 11/j/EE technician KC- APPROVED .f\^ PAGE 1 e" 2 inches o- I f IJlfTi PT W (TV) tm(nmr,r* ho** Tun #rT fvCDVTVn wm u rr,u i d* rnwtuv Brown Sandy SILTS becoming Clayey SILTS with ferrous nodules and root hairs. - 5' Brown and gray CLAVE with ferrous nodules with silty clay pocket at the top. - io- 15- with root hairs, with organic material. with silty clay pocket. -- with silty clay lense. - 20- 25 - 30- 35 - - 40 -- becoming stiff, greenish gray with fractures, carcerous nodules, and roots. -- with wood and organic material. -- gray with no fractures. -- grayish brown -- with shell layer at 35 feet becoming brown carbonaceous clay. -- stiff gray with calcerous nodules and fractures. 00 143958 CONFIDENTIAL- ATTACHMENT 2 DO 143960 CONFIDENTIAL  **! *<* 6 rr Lr * nD DO 1 4 3 9 6 1 C O N F ID E N T IA L ' GROUND ... -. _ . . _ r> v'A7 lON '". LL ntf-vH.', G ?nprati*rd M rotigrophy and Water Level G - n r r r t lijr d Gfr tl I ig ro p h y <jnd W o trf L e v e l /;^enr.^ ,i >r `if:;; V >1:1 OFFICT Of SOl-ll) AM) HAZARDOUS W AS'TF OciODer 15. 19E5 J()H\ KOI ASMS) AM SI Ck!1 AT' William H. Taylor, Jr.. Chief Enforcement Section (6AW-HE). Region VI C.S. Environmental Protection Agency 1201 Eim Street Dallas. Text' 75270 Attention: Linde Thompson. Enforcement Section Deer Mr. Taylor: Re: E.P.A. contract 6E-Q1-7037, PRC Engineers Dow Chemical, U.S.A. (LAD00E187080) Dow Chemical was furnisned a copy of the PRC report on September 12, 1985 for tneir review and comment. We have enclosed Dow's response and intentions as concerns PRC's findings, and met with their representatives in late September to discuss this metter. Louisiana finds that: * Testing of several 'worst case" well annuiuses is in order, and should resolve tne integrity question relating to visible suDsidence c: grout around me casing. * Dew's proposal tc install aoditional wells around the nortnwest landfill snoulc correct any detection hiatus that may exist arounc tms facility. Since Louisiana is planning fn tne not too distant tuture to allow operators to use site-specific indicators in heu oi statistical evaluations c-i the standard indicators, we would prefer not to pursue the validity of Dow's current statistical protocol at this V,e will require Dow's monitoring wells to meet all integrity standards, wherever tpphcsole. and will follow up on PRC's recommendations for additional monitoring wei.s insure that an adequate detection program exists ercund me landfill area. pjtii.-e advise if you lee) that other ections mav be warrantee. GluMLMLujn: Sbiinncceepp<eiv, // -/,/ i //' "utOKGPV.; vf HAMER, 11 '*Cttr - Actmg'ntimimsiraior Ground Vtaicr Protection uivisio; OO 143964 CONFIDENTIAL UNITED STATES ENVIRONMENTAL PROTECTION AGENC' REGION VI 1201 ELM STREET Dallas Texas 72?o August 29, 19E5 l-k *\<sc Hr. Glenn Killer, Administrator Hazaroous Waste Division Louisiana Department of Environmental Ouality Office of Solid and Hazardous Waste Post Office Box 94307 Baton Rouge, Louisiana 7DS0 ; i ir* *- 'w ENvi^fARn`^7 O Enclosed are copies of the craft final reports of the RCRA groundwater monitoring compliance inspections for the Dow Chemical U.S.A. Plant, Pleouemine, Louisiana and the Ethyl Corporation Plant, Baton Rouge, Louisiana. The reports are currently being reviewed by members of my staff, and it is requested tnet your staff review them and provide consents as soon as possible to Linda Thompson at (214) 767-2949. Sincerely yours, Wiiiioim n, icvihi , u i . , Chief Enforcement Section (6AW-HE) Enclosure D0 143965 CONFIDENTIAL OPERATING AND PROCESS INFORMATION ON RCRA UNITS ATTACHMENT 5 DO 143966 CONFIDENTIAL Chapter it - CA II Plant Page 2 4.9J) (continued) ^9 j) 8) Prevent accidental ignition or reaction of ignitable, reac tive, or incompatible wastes as required to demonstrate compliance with 9.9; RESPONSE Not applicable. This facility is a surface impoundment that is considered hazardous only due to corrosivity. This surface impoundment does not receive ignitable, reactive or incom patible waste and is not subject to the requirements of 4.9J)8) or 9.9* The flow into this surface impoundment con sists of dedicated or similar streams that do not pose an ignitable, reactive or incompatibility hazard. A Division-wide response pertaining to ignitable and reactive concerns was addressed in the General Volume I-A, 9.9a) and 9.9b). Compliance with this Division-wide program is required by Dow guidelines. ' 4.9t) 7) Operations plan, including: a) Classification and estimated quantities of wastes to be handled; RESPONSE The liquid waste that is stored in this surface impound ment is hazardous only due to corrosivity (sodium hydroxide), which is identified with EPA I.D. Number D002. This surface impoundment is utilized as a storage facility and it normally receives a monthly flow of 12,510 tons liquid waste. 4.9t)7) b) Methods and processes utilized: Facility capacity for each disposal method; Detailed description of each process or method; Storage and disposal procedures^ Plans for receipt, checking, processing, segregation of incompatible wastes, and odor control; and Life of each facility based on projected use; DO 143967 CONFIDENTIAL Chapter 4 - CA II Plant Page 3 H.9t)7)b) (continued) A.9t)7)b) Describe recordkeeping procedures, types of records to be kept, and use of the records by management to control the operation; and Monitoring and recording of incoming wastes; RESPONSE Capacity - The maximum capacity of this surface impound ment is 1.9MM gallons, for the storage of liquid waste which is hazardous due to corrosivity (EPA I.D. D002). Process Description - This impoundment is used infre quently, and mainly during plant upsets to prevent the plant discharge from containing any appreciable amounts of unneutralized caustic. The impoundment is kept at a mini mum level, usually between 7 and 10J. The liquid waste stored in this impoundment contains a typical composition of 1.21 sodium hydroxide. During normal operation, this impoundment is kept in a stand-by mode by the computer which controls the plant's ecology system. During this normal operation, all of the plant wastewater is discharged directly into the plant's two pH monitoring and control stations. This station adds hydrochloric acid to neutralize the effluent to an accep table range (typically 6 - 9 pH). This effluent is then discharged through the plant's N?DES-permitted Internal .Outfall 003A and ultimately to the final Division Outfall 021 Plans for Receipt, Checking. Processing - This surface impoundment receives process wastewater only from the CA II Plant through a system of pipes. This impoundment receives dedicated process streams which are essentially uniform in chemical composition. No incompatible wastes enter this impoundment and there are no offensive odors. The ultimate treated effluent from this system is moni tored for pH on a continuous basis. Life of Facility - This facility is projected to operate until the year 2030. Recordkeeping Procedures _ Types of records and record keeping procedures can be found by referencing 9.5b) in this volume. In addition, the whole operation is computer controlled. All the variables are either continuously DO 143968 CONFIDENTIAL Chapter 4 - CA II Plant Page 4.9t)7)b) (continued) 4.9t)7)b) PESPONSE (continued) displayed or can be displayed on command on a CRT computer screen. All alarms are logged automatically by the com puter including time on, time acknowledged and time off. In addition, an operations log exists in the control center for logging all unusual plant conditions, or any other information. The ecology engineer reviews the control center log, the computer alarm log, the computer display, and the CRT display at least once a day. Since the operation is computer controlled, it is normally necessary only to check for malfunctions and deviations from specified conditions. Incoming Waste - To monitor and control incoming waste, only one pipeline is connected to this surface impound ment. The flow entering or exiting the impoundment must flow through this pipe. A separate flow meter is utilized for each of these flows. The flow meter readings are stored in the computer memory and totalized. The instantaneous or totalized flow for the day or the month can be retrived at any moment. The impoundment level is continuously monitored and the difference in level is also a measure of the amounts of wastes received and/or discharged. Outfall 021 which has the pH limits of 6 - 9 pH based on continuous on-line measurement. The NPDES Permit number is LA0003301. When a high pH is detected in the CA II Plant Outfall trench (003A), or when a known high alkaline discharge occurs, the plant's effluent flow is diverted to the hazardous waste surface impoundment by either an automatic computer control or by manual operator activation until the plant upset has been brought under control. During these upset conditions, the surface impoundment is used to store the excess alkalinity to prevent a pH noncompliance of the NPDES Permit. DO 143969 CONFIDENTIAL Chapter 4 - CA II Plant Page 5 4.9j)7)b) (continued) 4.9j)7)b) RESPONSE (continued) When the plant is back to a normal operating condition, the operator signals the computer to start the flow out of the impoundment into the plant's ecology system at a reduced flow rate of approximately 50 gallons per minute. If the pH in the outfall trench remains within specified limits, the flow is gradually increased. If the pH goes beyond the specified range, the flow is decreased or the operation stopped depending on the severity of the deviation. The computer finds the optimum flow rate that would maintain the specified pH range, and the operation proceeds until the impoundment level is less than 101. At this point, the impoundment returns to the normal stand-by mode. H.12 (2nd) Specific Part II information requirements for surface impoundments. Except as otherwise provided in 1.3d) and 9.1 and 3*3b) and c), owners and operators of facilities that store, treat or dispose of hazardous waste in surface impoundments must provide the following additional information: a) A list of the hazardous wastes placed or to be placed in each surface impoundment^ RESPONSE Only one hazardous waste is placed in the impoundment as described in $9*10, Waste Analysis Plan, in this volume. This waste is a wastewater stream which is hazardous only because of the characteristic of corrosivity (D002). The hazardous waste flows to the impoundment via pipeline. The source of the waste is always the same. DO 143970 CONFIDENTIAL Chapter 4 - Chlorine Plant Page 2 *.9j)8) (continued) I *.9j)8) RESPONSE (continued) A Division-wide response pertaining to ignitable and reactive concerns was addressed in the General Volume I-A, 9*9a) and 9.9b). Compliance with this Division-wide program is required by Dow guidelines. 4.9t) 7) Operations plan, including: a) Classification and estimated quantities of wastes to be handled; RESPONSE The liquid waste that is stored in this surface impound ment is hazardous only due to corrosivity (sodium hydroxide), which is identified with EPA I.D. Number D002. This surface impoundment is utilized as a storage facility and it normally receives a monthly flow of 30650 tons liquid waste. Under normal operating conditions, approxi mately one-half of the flow from the surface impoundment is recycled back for product (sodium hydroxide) recovery. Jll-9t>7> b) Methods and processes utilized: Facility capacity for each disposal method; Detailed description of each process or method; Storage and disposal procedures: Plans for receipt, checking, processing, segregation of incompatible wastes, and odor control; and Life of each facility based on projected use; DO 143971 CONFIDENTIAL Chapter k - Chlorine Plant Page 3 4.9t)7)b) (continued) 4.9t)7)b) Describe recordkeeping procedures, types of records to be kept, and use of the records by management to control the operation; and Monitoring and recording of incoming wastes; RESPONSE This surface impoundment is utilized for the storage of a solution of sodium hydroxide in water. The capacity of this impoundment is 1.6 MM gallons. Process Description - The Chlorine Plant surface impound ment functions as a holding pond for alkaline process streams. The caustic comes primarily from chlorine scrubber bottoms. Approximately half of the impoundment alkaline water is normally recycled back through one of two sections of the process. If the caustic concentration is high enough, the pond water is recycled back through the chlorine scrub bers. Also, to further utilize the caustic, the pond water can be recycled back through the brine treating system. The portion of impoundment contents which is not recycled becomes process wastewater. The wastewater is pumped from the pond at a controlled rate into a Chlorine Plant canal treatment system. The alkaline wastewater in this system is neutralized and then discharged through the Division's NPDES-permitted Outfall 021 which has the pH limits of 6 9, based on a continuous on-line measurement. The NPDES Permit number is LAD003301, Plans for Receipt. Checking. Processing - This surface impoundment receives process wastewater only from the Chlorine Plant through a piping system. This impoundment receives dedicated process streams which are essentially uniform in chemical composition. No incompatible wastes enter this impoundment and there are no offensive odors. The ultimate treated effluent from this system is moni tored for pH on a continuous basis. Life of Facility - This facility is projected to operate until November, 1986. DO 143972 CONFIDENTIAL Chapter 4 - Chlorine Plant Page 4 4.9t)7b) (continued) 4.9t)7)b) RESPONSE (continued) Recordkeeping Procedures - The analysis of the pond is logged daily. The data is used to determine when to recycle pond contents and when to discharge to the NPDES system. Daily events are logged on a sheet provided for records. Log sheets are reviewed by management on a routine basis. Additional detail on the types and record keeping procedures can be found by referencing 9-5b). Incoming Waste - The flows entering this impoundment is of consistent composition, based on process knowledge. The level of the impoundment is monitored on a daily basis. 4.12 (2nd) Specific Part II information requirements for surface impoundments. Except as otherwise provided in 1.3d) and 9.1 and SSB.3b) and c), owners and operators of facilities that store, treat or dispose of hazardous waste in surface impoundments must provide the following additional information: a) A list of the hazardous wastes placed or to be placed in each surface impoundment; RESPONSE The Chlorine Plant surface impoundment contains only hazardous wastes which are hazardous because of the characteristic of corrosivity. The wastes are all generated in the Chlorine Plant and the presence of sodium hydroxide in the waste streams causes the pH to be greater than 12.5 and thus a hazardous waste*. These wastes enter the surface impoundment via pipelines. The Waste Analysis Plan, 9.10, is also responsive to this section. DO 143973 CONFIDENTIAL. 4 v_ ^ Chapter 4 - CPE Plant Page 2 4.93)8) (continued) ) 4.93)8) RESPONSE (continued) A Division-wide response pertaining to ignitable and reactive concerns was addressed in the General Volume I-A, 9.9a) and 9.9b). Compliance with this Division-wide program is required by Dow guidelines. 4.9t) 7) Operations plan, including: a) Classification and estimated quantities of wastes to be handled; RESPONSE The liquid waste that flows through this surface impound ment is hazardous only due to corrosivity, which is iden tified by EPA I.D. number D002. Based on 1984 flows, the flow through this surface impoundment averaged 2.2 MGD (million gallons per day). 4.9t)7) b) Methods and processes utilized: Facility capacity for each disposal method; Detailed description of each process cr method; Storage and disposal procedures: Plans for receipt, checking, processing, segregation of incompatible wastes, and odor control; and Life of each facility based on pro3eoted use; Describe recordkeeping procedures, types of records to be kept, and use of the records by management to control the operation; and Monitoring and recording of incoming wastes; L DO 143974 CONFIDENTIAL Chapter 4 - CPE Plant Page 3 4.9t)7) (continued) 4.907) RESPONSE Facility Capacity - This surface impoundment is not a disposal facility, but it is part of an NPDES treatment system to remove non-hazardous suspended solids in the effluent prior to discharge. The storage capacity of this impoundment is approximately 450,000 gallons. Process Description - Process wastewater containing hydrochloric acid (HC1) is generated during the production of chlorinated polyethylene (CPE) at this plant. In addi tion to the HC1, this stream also contains non-hazardous suspended solids, which are composed of polyethylene and chlorinated polyethylene particles. This process wastewater stream passes through the 100* x 75' x 8' deep surface impoundment which reduces the velo city of this stream, allowing the non-hazardous suspended solids to settle to the bottom. The remaining effluent stream is discharged through the CPE Plant's NPDES-permitted Outfall 001 prior to its ulti mate discharge through the Division's Final Outfall 021. At this point, the pH is continuously monitored and must be neutralized to a 6 - 9 pH range to be in compliance. The NPDES Permit number is LA0003301. Plans for Waste Receipt. Checking. Processing Waste - This surface impoundment receives process wastewater only from the CPE Plant through an internal trench system. This impoundment receives dedicated process streams which are essentially uniform in chemical composition. No incom patible wastes enter this impoundment and there are no offensive odors. The ultimate treated effluent from this system is monitored for pH on a continuous basis. Life of Facility - This facility is projected to operate until November, 1988, DO 143975 CONFIDENTIAL. Chapter A - CPE Plant Page 4 l<.9t)7b) (continued) M.9t)7)b) RESPONSE (continued? Recordkeeping Procedures - This impoundment is inspected daily and operation records are completed weekly. These records are routinely reviewed to ensure proper operation of the surface impoundment. Additional details on recordkeeping can be found by referencing 9.5b) in this volume. Incoming Waste - The incoming process wastewater to this surface impoundment is continuously monitored for pH. This impoundment receives dedicated process streams which are essentially uniform in chemical composition. The flow entering this impoundment equals to effluent flow from the impoundment which is monitored continuously. A.12 (2nd) Specific Part II information requirements for surface impoundments. Except as otherwise provided in l.3d) and 9.1 and 3.3b) and c), owners and operators of facilities that store, treat or dispose of hazardous waste in surface impoundments must provide the following additional information: a) A list of the hazardous wastes placed or to be placed in each surface impoundment; RESPONSE The CPE Plant surface impoundment contains only hazardous wastes which are hazardous because of the characteristic of corrosivity. The wastes are all generated in the CPE Plant and the presence of hydrochloric acid or caustic in the waste streams causes the pH to be either less than 2.0 or greater than 12.5 and thus a hazar dous waste. These wastes enter the surface impoundment via a plant trench. Paragraph 9.70, "Waste Analysis Plan, is also responsive to this section. DO 143976 CONFIDENTIAL Page 5 l it.9t)7)b) (continued) Revision #2 October lii, 1985 D.9t)7)b) RESPONSE (continued) Incoming Waste - Each truck load of incinerator ash is logged in at the landfill office, and these records become part of the NWLF records. U.16 Specific Part II information requirements for landfills. Except as otherwise provided in 1.3d), 9.1, and 3.3b) and 3.3c), owners and operators of facilities that dispose of hazardous waste in landfills must provide the following additional information: a) A list of the hazardous wastes placed or to be placed in each landfill or landfill cell; RESPONSE Northwest Landfill first started receiving hazardous waste in 1981. From 1981 to 1981), several wastes were reported as being hazardous under the DNR reporting rules and under the protective reporting policy. Under present Louisiana Hazardous Waste Regulations, the only hazardous waste landfilled is 1-200 Incinerator ash. J1.I6 b) Detailed plans and an engineering report describing how the land fill is or will be designed, constructed, operated and maintained to comply with the requirements of 11),2. This submission must address the following items as specified in 1i).2: 1) Tne liner system and leachate collection and removal system; RESPONSE See 1l).2a)1) and I4.2a)2) of this permit volume. AJ. 16b) 2) Control of run-on; RESPONSE See 11). 2e) of this volume Chapter 4 - NWLF Page 4 4.9t)7)b) (continued) ) Revision #1 October Hi, 1985 ii. 9t)7)b) RESPONSE (continued? Detailed Description - The landfilling of hazardous waste at the NWLF is conducted in two stages. Stage 1 disposal takes place in a series of cells that have the dimensions 12' x 15' x 2' (LxWxD). After a cell is filled, it is compacted and covered with 6" of dirt. Stage 2 disposal is accomplished by placing the material in two-foot lifts above the Stage 1 cells. When filled, this two-foot lift will be covered with approximately six inches of dirt. Ditches and slopes will be maintained to allow rapid runoff of rainwater from the landfill to our collection system. This rainwater is then discharged through a proposed NPDES-permitted Internal Outfall 3001. The NPDES Permit number is LA0003301. Plans for Receipt, Checking, and Processing Waste - Each truck load of incinerator ash will be logged and recorded prior to landfilling. Since incinerator ash is the only hazardous waste that is currently landfilled, processing plans and the segregation of incompatible waste do not apply. The incinerator ash does not create any odor problems. Life of Facility - Closure of this facility is expected to start by the end of 2005. Recordkeeping Procedures - A map showing the exact loca tion and dimensions and contents of each cell is main tained in the 'Environmental Operations 8010 Building. Additionally, each landfill load is logged in at the land fill. office. All landfill area inspections are conducted at the frequencies so designated in 9.5 and the results recorded. All of this information will become a permanent part of the NWLF records, and is subject to routine reviews. DO 143978 CONFIDENTIAL Chapter 4 - NWLF Page 3 4.9 (continued) 4.9t) 7) Operations plan, including: a) Classification and estimated quantities of wastes to be handled; RESPONSE Currently, the primary hazardous waste that is landfilled in the NWLF is incinerator ash from the rotary kiln incinera tor (1-200). It is not considered a Category I or II waste (LHWR, Chapter 24) but it is considered hazardous by definition. The yearly estimated quantity of incinerator ash to be landfilled is approximately 3,000 cu yds. 4.9t)7) b) Methods and processes utilized: Facility capacity for each disposal method; Detailed description of each process or method; Storage and disposal procedures: Plans for receipt, checking, processing, segregation of incompatible wastes, and odor control; and Life of each facility based on projected use; Describe recordkeeping procedures, types or records to be kept, and use of the records by management to control the operation; and Monitoring and recording of incoming wastes; RESPONSE Capacity - Landfilling is the only disposal method that is utilized on this site. The remaining useable life of the NWLF is estimated to be three to six years. DO 143979 CONFIDENTIAL Revision #1 October 14, 1985 EXHIBIT 7 TABLE 2 CLOSURE SCHEDULE NORTHWEST LANDFILL (NWLF) Event Remove Sump and Light Pole Grade Install Clay Cap and Dike Install PVC Liner Install Drainage Net Install Geotextile Filter Install Seeded Top Soil Days After Closure Initiated 10 20 30 55 75 85 90 DO 1A3980 CONFIDENTI AL Revision #1 October 14, 1985 EXHIBIT 9 SU.2b) CALCULATION OF THE TRANSMISSIVITY OF THE PERVIOUS ZONE (HO - 50 FEET BELOW THE LAND SURFACE) NORTHWEST LANDFILL (NWLF) Transmissivity = T = Kb K = coefficient of permeability b = aquifer thickness K vertical s 1.72 x 10"6 cm/sec to 2.59 x 10'6 cm/sec Assume - horizontal permiability equals 10 times the vertical. K horizontal = 1.72 x 10"5 cm/sec to 2.59 x 10-^ cm/sec K horizontal = .36 gal/day/ft2 to .55 gal/day/ft2 T s .36 gal/day/ft2 x 10 ft = 3.60 gal/day/ft T = .55 gal/day/ft2 x 10 ft s 5.50 gal/day/ft 00 143981 CONFIDENTIAL CHAPTER 11 TANKS VINYL II PLANT 11.1 Applicability -- The regulations in this Chapter apply to owners and operators of facilities that use tanks to treat or store hazardous waste, except as specified in 1.3d). RESPONSE Dow acknowledges this section. 11.2 Design and operating requirements a) Tanks must have sufficient shell strength (and closed tanks must have pressure controls such as vents) to assure that they do not collapse or'rupture. The Administrative Authority will review the design of the tanks, including the foundation, structural support, seams, and pressure controls. The Administrative Authority shall require that a minimum shell thickness be main tained at all times to ensure sufficient shell strength. Factors to be considered in establishing minimum thickness include the width and height of materials of construction of the tank, and the specific gravity of the waste which will be placed in the tank. In reviewing the design of the tank and establishing a minimum thickness, the Administrative Authority shall rely upon appropriate industrial design standards and other available information. RESPONSE The hazardous waste handling equipment in the Vinyl II Plant is comprised of two vertical storage vessels. The two tanks are designated T-JJOO and T-*I10. The tanks are capable of storing ^9,300 gallons and 375 gallons of organic waste materials, respectively. The waste materials handled in the storage tanks are produced in the Vinyl II Plant. No waste is received from other facilities. DO 143982 CONFIDENTIAL Chapter 11 - Vinyl II Plant Page 2 11.2)a) (continued) Revision #1 August 14, 1985 11.2a) RESPONSE (continued? Tank T-400 is a storage tank for feed to the Vinyl II Plant ther mal oxidizing unit. The feed streams to T-400 are heavy ends from the distillation of ethylene dichloride in ethylene dich loride production, and heavy ends from the distillation of vinyl chloride in vinyl chloride monomer production. The composition of the "heavies" mixture in T-400 is typically 15* EDC, 30* Btriehloroethane, 15* trichloroethylene and 15* tetrachlorothane, with carbonaceous organics comprising the remainder. The mixture's specific gravity averages 1.5. The flow of hazardous waste material through T-400 is typically 1200 - 1500 lb/hour. Tank T-410 is a small receiver for waste materials generated by the plant's quality control lab. The lab waste materials are liquids from reagents, wet analysis and residual liquids from sample bottles. The composition of the mixture of waste material in T-410 is typically 50* EDC, 20* water, 10* chloroform, with methanol, pyridine, and B-trichloroethane comprising the remainder. The mixture's specific gravity averages 1.5. The tank contents (approximately 375 gallons) are fed usually once per month into the thermal oxidizer at a rate of 800 - 900 lb/hour. Tank T-400 was designated in accordance wtih API 650 code. The tank is fabricated of SA-283, Grade C, carbon steel with a ten sile strength of 12650 psi at metal temperatures of -20F to 650"F. Exhibit 16 is an engineering type drawing for T-400 that provides additional data on the design and fabrication of the tank. The original design thickness of the shell, top head, and cone bottom was 0.250 inches. The latest (1984) thickness measure ments are shown in Exhibits 19 and 24. Tank T-400 thickness measurements indicate the vessel has a calculated service of 32 years based on 5.8 mils/year corrosion rate, and a minimum allowable thickness of 0.1875 inches. Tank T-410 is a 375 gallon, cylindrical shaped tank, that was field designed and fabricated in Vinyl II Plant's maintenance shop. The tank shell and bottom are fabricated of one-half inch thick carbon steel plate. The tank's lid is made of one-quarter inch thick carbon steel plate. Exhibit 17. an engineering sketch of the tank, contains additional design and fabrication details including the nozzle schedule. OO 143983 CONFIDENTIAL CHAPTER 11 TANKS ENVIRONMENTAL OPERATIONS (1-200) Revision #1 October 14, 1985 ii.i Applicability -- The regulations in this Chapter apply to owners and operators of facilities that use tanks to treat or store hazardous waste, except as specified in Sl.Bd). RESPONSE Dow acknowledges this section. 11.2 Design and operating requirements a) Tanks must have sufficient shell strength (and closed tanks must have pressure controls such as vents) to assure that they do not collapse or rupture. The Administrative Authority will review the design of the tanks, including the foundation, structural support, seams, and pressure controls. The Administrative Authority shall require that a minimum shell thickness be main tained at all times to ensure sufficient shell strength. Factors to be considered in establishing minimum thickness include the width and height of materials of construction of the tank, and the specific gravity of the waste which will be placed in the tank. In reviewing the design of the tank and establishing a minimum thickness, the Administrative Authority shall rely upon appropriate industrial design standards and other available information. RESPONSE The Tank Farm at the Louisiana Division's Environmental Operations facility contains five covered vertical storage vessels. These tanks provide storage for waste materials generated internally by Louisiana -Division manufacturing plants, plus some Dow off-site generators. Four tanks, T-130, T-135, T-250, and T-255 have a holding capacity of approximately 20,000 gallons each. The fifth tank, T-401, has a capacity of 11,300 gallons. Tank T-130 is dedicated storage for organic contaminated waste waters; Tank T-135 for slop oils/suspended solids; Tank T-250 for lubricating oils/Dowanol* tars; Tank T-255 for flam mable liquids. Specific gravities of the materials handled range from 0.6 to 1.25. Tank T-401 is associated with a slurry feed system and stores materials with a gravity that ranges between 1.0 to 1.5. TRADEMARK OF THE DOW CHEMICAL COMPANY DO 143984 CONFIDENTIAL Chapter 11 - Environmental Operations Page 2 11.2a) (continued) Revision #2 October 1^4, 1965 11.2a) RESPONSE (continued) All five tanks were designed in accordance with API Code #650. The shells and heads of each tank are fabricated of SA-285, Grade C carbon steel with a minimum tensive strength of 13,750 psi. Exhibits 32 through ^5 are engineering type drawings of storage vessels, T-130, T--135, T-250, and T-255, that include design data concerning nozzle locations and schedules, dimensional measure ment data and other tank design criteria. Exhibits 36 and ^7 provide additional information concerning tank noz2le service. The original design thickness of each tank was 0.3125 inches (shell), and head thicknesses of 0.250 inches (T-130), 0.3125 inches (T-135, T-250, T-255). Most recent thickness measurements taken in 1985 are shown in Exhibit 38. This exhibit also lists other physical characteristic data for each vessel. Design criteria for Tank T-401 is provided in Exhibits 1 through 7, Cycle 2, Volume X-E. The locations, schedules and sizes of nozzles for this vessel are shown on Exhibits 1 and 2 of the above exhibits. The original shell and head design thickness for this tank is 0.375 inches. Because this tank is new, thickness measurements and corrosion rate data are not available in Exhibit 38. Exhibits 8, 9, and 10. Cycle 2, Volume X-E are vendor drawings of T-*)01 storage vessel showing nozzle locations and schedules, dimensional measurement data and other tank design criteria. Exhibit 39 lists appropriate operating type data including specific gravities for the materials in each tank. The specific gravities shown are for current waste materials. These values will vary based on the mix of waste materials being processed. The liquid level in T-130, T-135, T-250., and T-255 is alarmed at 851 of the straight side measurement (approximately 20 feet), and approximately 18 feet for T-1401 Tank. Redundant high level instruments in each tank provide back-up alarms at two to three feet below roof height. DO 143985 CONFIDENTIAL CHAPTER 11 TANKS SOLVENTS PLANT ) 11.1 Applicability -- The regulations in this Chapter apply to owners and operators of facilities that use tanks to treat or store hazardous waste, except as specified in 1.3d). RESPONSE Dow acknowledges this section. 11.2 Design and operating requirements a) Tanks must have sufficient shell strength (and closed tanks must have pressure controls such as vdnts) to assure that they do not collapse or rupture. The Administrative Authority will review the design of the tanks, including the foundation, structural support, seams, and pressure controls. The Administrative Authority shall require that a minimum shell thickness be main tained at all times to ensure sufficient shell strength. Factors to be considered in establishing minimum thickness include the width and height of materials of construction of the tank, and the specific gravity of the waste which will be placed in the tank. In reviewing the design of the tank and establishing a minimum thickness, the Administrative Authority shall rely upon appropriate industrial design standards and other available information. RESPONSE The hazardous waste handling equipment in the Louisiana Division's Solvents manufacturing plant is comprised of seven storage vessels. The seven tanks are designated D-13, D-15, D-92A, V-201, D-700, D-701, and T-1001, The seven tanks are capable of storing 833,231 pounds of organic waste material. The waste materials being stored in these vessels are mainly heavy ends from the distillation of ethylene dichloride, vinyl chloride, carbon tetrachloride, perehloroethylene and trichloropropene. Constituents of these waste materials are primarily chlorinated aliphatic hydrocarbon compounds. Exhibit 31 contains engineering type drawings for each of the seven vessels. Tanks D-13 and D-15 are horizontal storage vessels fabricated from 00 143986 CONFIDENTIAL Chapter 11 - Solvents Plant Page 2 11.Pa) (continued) ) 11.2a) RESPONSE (continued) Monel, Alloy 400 steel and SA-285, Grade C, carbon steel, respectively. The tanks are utilized as storage vessels for chlorinated waste by-products from the per-tet process. The main components in the feed stream to these tanks are hexachlorobenzene, hexachlorobutadiene, hexachloroethylene, and perchloroethylene. The organic wastes in these tanks are pumped continuously to the Solvents Plant's thermal oxidizer (TOX) for high temperature oxidation to gaseous products. Tank 92-A is a horizontal, batch-operated storage vessel fabri cated from SA-285, Grade C, carbon steel. This vessel receives small quantities of organic wastes collected in drums during equipment clean-up, and organic liquids that accumulate in the process vent header system knockout pot. The contents of this storage tank are batch transferred to D-701, the heavies feed tank. Tanks T-1001 and V-201 are batch-operated, organic storage vessels fabricated from SA-285, Grade C, carbon steel. T-1001 is a ver tical tank, and V-201 is a horizontal tank. T-1001 receives the condensed overhead stream from the organics stripper column. Stripper overhead composition is typically 95* water and 5* orga nics. The organic phase in T-1001 is batch transferred to 0-701, and the lower density water layer gravity flows to V-201. In addition to the water phase from T-1001, V-201 receives all liquids (mainly rainwater) collected by the process area sumps. V-201's water phase containing trace organics is recycled back to the organic stripper column, and the heavier organic layer is batch transferred to D-701. Tank D-700 is a vertical storage vessel -fabricated Trom Monel, ATToy 400 steel. This vessel receives "heavy ends" from the pro duction of ethylene dichloride and propylene dichloride, and "heavies" from the production of methyl chloride and trichloropropene. The contents of this tank are batch transferred to D-701, the heavies feed tank. Tank D-701 is a vertical piece of Kynar* lined pipe that func tions as a surge controlling unit to dampen the effect of multiple feeds to the thermal oxidizer. D-701 receives waste organics from V-201, T-1001, D-700, and "heavy ends" from the distillation of vinyl chloride. D-701 is continuously fed by centrifugal pump to the TOX unit. Exhibit 32 provides simplified process flow diagrams for each of the hazardous waste storage tank systems. DO 143*987 CONFIDENTIAL * US.G.P.O-1994-446^14 P Olfl 564 433 v> RECEIPT FOR CERTIFIED MAIL NO INSURANCE COVERAGE PROVIDED NOT FOR INTERNATIONAL MAIL (See Reverse) Postage (j MM- $ Certified Fee Special Delivery Fee Restricted Delivery Fee Return Receipt Showing to whom and Date Delivered Return receipt showing to whom, Date, and Address of Delivery TOTAL Postage and Fees S Postmark or Date 3l ' / SELw<R;u~1omplite items 1,2,3 and 4. ) Put your address In tha "RETURN TO" apace on the reverie aide. (Mure to do thit will prevent thl* card from 8 being returned^ you. The return receipt fee will provide you the nameffi the*pterton delivered to and the date of delivery. For additional teei the following aervicei are available. Consult odrivnatter for fees and check box(ei) for *ervicej>) ^quested. 1. S'bhow tjswhom, data end address of delivery. 2. Restricted Defivery, -------------- O___ _ __ -------- ----------------------- 3. aytiiccllee Adctdorreeststed ttoo. ftp - M ,,/l 1 1 * .. MM* 4- Type of svii Rspistered Insured IJ'TTertified COD Express Mail Article Number Always obtain signature of addressee or agent and PATE OELIVERFD 6. Signature -ytydressee X 6. Signexir^C Agent X* 7. Date o^Qelivery __ 8. Addressee's Address (ONLY ifrequested and fee 30 3 *C tfc- PS Form 3800, Feb. 1982 DO 143988 CONFIDENTIAL ) DOW CHEMICAL U.S.A September 4, 1986 CERTIFIED MAIL RETURN RECEIPT REQUESTED LOUISIANA DIVISION P, o. SOX ISO PLAOUEMINE. LOUISIANA 707BB-01B0 BOA 9SB-B000 Mr. Shin Ahn PRC Engineering 303 East Wecker Drive Suite 600 Chicago, Illinois 60601 HAZARDOUS WASTE OPERATING LOGS DOW CHEMICAL U.S.A., LOUISIANA DIVISION Dear Mr. Ahn: Enclosed with this letter is the information you requested. Each Dow hazardous waste facility has its own method of keeping track of their waste disposal activity. Appendix I shows the type of system used by our Chlorinated Polyethylene Plant when disposing of waste at our solid waste land fill Appendix II shows the disposal logs used to document disposal at our hazardous waste landfill (Northwest Landfill). As you can see from these log sheets the primary material being disposed of at this faci lity is incinerator ash. Appendix III shows the information taken from Dow's 1986 Hazardous Waste Disposal Tax Returns, This is one of the mechanisms that is used to keep track of our surface impoundment treatment/storage pro cesses. If you have any questions pertaining to this information, please feel free to call me at 504-389-6407. Sincerely, Charles Goldsmith Environmental Services Enclosure sb AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY DO 143989 CONFIDENTIAL UoUTTRR(ONMENIAL OPERATIONS DUMP OF DATA FROM PILLING SYSTEM FILES. DATES: 7- 1-86 THRU 7-31-86 DAY REF WASTE ACNT DEST TRUCK 07/10/86 32 IS 238 5 ovr z TYPE ticket UNIT 0 07-AUG-EG GROSS 24000.0 CHARGE 24000.0 % DO 143990 CONFIDENTIAL f` ( AUSTRALIA POINT LANDFILL X__ NORTHWEST LANDFILL DISPOSAL LOG OPERATOR: DATE: niom.L ( LOAD DUMBER 1 2 3 H 5 6 7 8 9 10 11 12 13 in 15 16 17 DRIVER/OPERATOR vi!,r TRUCK NUMBER PLANT OR BLOCK NO. f9i- -V/' MATERIAL // ) / ( DISPOSITION (CELL //) WEIGHT Ufa COW ENTS f .- o o ZM Q - z-Mt r 00 < \ AUSTRALIA POINT LANDFILL x NORTHWEST LANDFILL ('{ DISPOSAL LOG OPERATOR: DATE: U( ( / n * v> - Y LOAD I UMBER DRIVER/OPERATOR TRUCK NUMBER PLANT OR BLOCK NO. 1 /' f * \ 2 3 14 5 6 7 8 9 10 11 12 13 1M 15 16 17 MATERIAL t t DISPOSITION (CELL it) Vo WEIGHT COMMENTS r --------------------------------------------------------------------------------- " o z-n om z H- X r DO 1 4 3 9 9 2 If ___ AUSTRALIA POINT LANDFILL A NORTHWEST LANDFILL ft ( DISPOSAL LOG OPERATOR: DATE: a (. / LOAD NUMBER DRIVER/OPERATOR TRUCK NUMBER PLANT OR BLOCK NO. MATERIAL DISPOSITION (CELL #) WEIGHT 1 7: . v 2/ 3 7 -4. / if 7T4- -V >, M. / 5 .. i7h^,46 4..- 7 A 8 9 T.>- T10 - -.4, 11 7./ J 12 13 in 15 16 17 C /6 f l 4; 7 /' A, /,. rr 1, . .<. 1,. /1, rv//v. h v i ( r //'X'/ </ 44 -T-. ^ U? , 1. TP 4-7' /L 77' h/i -,? 4 SC(. <.C6 UO c (V 'i L ,1... SJ,x A IV /I :// ...L'\Lc V.lv fC -.i- s<*' / / ,/, *4 -/x IKf- M < . A'J1v *> .y ' v bvi V* XT 7 M7 T TJ 4Vf /rv/c- c/ 7 ^ 4/4 S Z7n o.SJV 0 r q c` AX' /'3.X /- '17c /c'X 'i(, (( / COMMENTS 0 00 U M"H j-* m co HZ vvO> *--( CO fI> ( AUSTRALIA POINT LANDFILL x NORTHWEST LANDFILL (( ( DISPOSAL LOG OPERATOR: / 3DATE: . ' * - 5 -OAD UMBER 1 2 3 4 5 6 7 8 9 0 1 2 3 4 5 6 7 DRIVER/OPERATOR Hi t Icol. Hit k*. TRUCK NUMBER PLANT OR BLOCK NO. MATERIAL CP ^ f 1 (vy 5 L $ J-oS fr - Ck s L *<i ^ DISPOSITION (CELL #) WEIGHT SM 'b VL SB'JO Cf 0<0 0 * 4// if >-'J COMMENTS 00 143994 C O N FID EN TIAL p ___ AUSTRALIA POINT LANDFILL * NORTHWEST LANDFILL r(( DISPOSAL LOG LOAD NUMBER DRIVER/OPERATOR TRUCK NUMBER PLANT OR BLOCK NO. MATERIAL 1 2 /a / 'r 3 it 5 J-r 6 y 7 8 9 10 11 12 13 U 15 16 17 7.52, 7^z S' &if77* cw rp c.w r/P a**- Gl-j/2-- 8 Ob rx'rp !\A? * ' DISPOSITION (CELL #) WEIGHT 3^0 33 o 370 r6N'0 WfO JJO 1090 d?<XS0> COWENTS -- DO 1 4 3 9 9 5 C O N FID EN TIAL AUSTRALIA POINT LANDFILL x NORTHWEST LANDFILL ft. DISPOSAL LOG OPERATOR DATE: A- LJJ, / -lo -a iE N T T A L `'r' APPENDIX III 1986 HAZARDOUS WASTE DISPOSAL TAX RETURNS (FILED 7/14/86) SURFACE IMPOUNDMENT 1ST QRT 2ND QRT. 3RD QRT. 4TH QRT, CHLORINE PLANT CHLORINATED POLYETHYLENE PLANT CHLOR-ALKALI II PLANT 787.09 2979.38 101.40 41*9.94 2661.72 413.90 422.44 2304.41 115.10 213.01 2157.32 532.80 TOTAL TREATED (TONS) 3867.87 3525.56 2841.95 2903.13 YEARLY TOTAL (TONS) 13138.51 WASTE TYPE D002 CG:sb 9/3/86 DO 143997 CONFIDENTIAL ) DOW CHEMICAL U.S.A August 27, 1986 FEDERAL EXPRESS LOUISIANA DIVISION P. O. BOX ISO PLAQUEMINE, LOUISIANA 707SS-O1B0 BOA 38B-BOOO PRC Engineering 303 East Wecker Drive Suite 600 Chicago, Illinois 60601 Dear Mr. Ahn and Ms. Yanada: On August 25, 1986, PRC Engineering, contractors for the EPA Region VI, conducted a "lost interim status inspection" at the Louisiana Division of Dow Chemical. Below is a list of additional information which was requested. This information is included in the referenced attachments: 1. Louisiana Division RCRA Hazardous Waste Permit (Attachment 1) 2. Louisiana Division RCRA Hazardous Waste Financial Responsibility (Attachment 2) 3. Potentiometric Maps for Chlorinated Polyethylene Surface Impoundment (Attachment 3) 1985 RCRA Compliance Inspection conducted by PRC Engineering (Attachment If) 5. Operating and Process Information on RCRA Units (Attachment 5) 6. Solid Waste Management Units Map (Attachment 6) 7. Subsurface Water Control Map (Attachment 7) 8. Operating Logs for RCRA Facilities (currently being compiled. Will be sent later. If you have any questions regarding this information or need additional information, please do not hesitate to contact us. Sincerely, Melissa Guise Environmental Services Attachments sb Charles Goldsmith Environmental Services AN OPERATING UNIT OP THE DOW CHEMICAL COMPANY DO 143998 CONFIDENTIAL. ) DO 143999 CONFIDENTIAL Facility Name: EPA I.D. No: Inspection Dates: lnspector(s): Facility Representative(s): INSPECTION CHECKLIST LOIS INSPECTIONS - REGION VI Enforcement Officer: Completed .__________ .__________ ___________ ______ ___________ ___________ __________ Item General Information Executive Summary Summary Report List of Documents Hazardous Waste Land Disposal Uni: Description SWMU Description Organization Chart Facility Drawing(s) Section A B C D E F DO 144000 CONFIDENTIAL. GENERAL INFORMATION Facility EPA I.D. Number: ___________ Facility State I.D. Number (Describe): Facility Name: ____________________________ Facility Primary Contact (Name and Title): Facility Mailing Address: (Street) (Citv) (State) Facility Location: (Street) (Citv) (State) Other Faciliry Contacts: Name: TeleDhone: Name: Teleohone: Name: Teleohone: Name: TeleDhone: (Zio) (Countv) (ZiD) Title: Responsibility: Title: Responsibility: Title: Responsibility: Title: Responsibility: A-l * DO 144001 CONFIDENTIAL EXECUTIVE SUMMARY DO 14400? CONFIDENTIAL. EPA I.D. Number SUMMARY REPORT Facility Name: HAZARDOUS WASTE NOTIFICATION STATUS Original Submitted fj No /^Yes Date t\^o, 8>, DOCUMENT ___________ Amendment(s) iJ No j% Yes jowj. rvcjt.. w-~ ojtxci \ -L^XC Describe Amendments: 'iv Add Date(s) of'i ^ 'Otd-C r Ut Ca Original Submitted Changes "''t l-.'ccuAf -*-:e o\ is _0. PART A APPLICATION STATUS /_/ No /% Yes Date poo s, U No Yes Date(s) C1C.4 is Approved Changes During Interim Status Describe Changes: fj No fj Yes Date(s) /J? Undetermined - r> ^c,c\- Submitted Certified Groundwater Certified Financial LOIS CERTIFICATION fj No /7Yes Date /7no O Yes fj No /7Yes U Partial C-l DO 144003 CONFIDENTIAL EPA I.D. Number LOIS VERIFICATION Groundwater Monitoring System: Waiver Approved )p No U Yes Date ___________ Last CME Conducted Ciooi\QCifTC'^/e^- Enforcement Action Outstanding as of November 8, 1985 GWM System Adequate U None /^Yes yj. No f__ /_/ Yes IJ Unknown U No /p Yes Date/ Agency ___________ Date ____________ Issued Judged bv lJ Unknown Inadequacies: _______ DOCUMENT Financial C/PC Assurance Mechanism: ^' Effective Period: Sudden Liability Non-Sudden Liability Financial Adequate IJ No OcA /"No /7n0 /7No /^ Yes Amount Closure: 2>. U>4'o M Postclosure: iTS. N\ IyYes / / Variance v ^ /o7ft -- /^A Yes / / Variance Document Document U Yes Judeed bv . Inadequacies: Pan B Application Date of Call In Date of Submittal NOD Sent OS* \S , ^>4 fl-, ftarL-x , s, v\<xr\dL ofevjkA, /_/ No IJ Yes Date(s) _____________ _________ Complete fj No 4/X Yes Deficiencies as of November 8, 1985: Date -vW \M( Cck ih, \^e>5 C-2 DO 144004 CONFIDENTIAL Name of Unit: Unit _ of __ of Section E Submitted for Approval Approved Implementing on Schedule? Certified Closed by P.E, Name of Unit: Unit _ of _ of Section E Submitted for Approval Approved Implementing on Schedule? Certified Closed by P.E. Name of Unit: Unit _ of _ of Section E Submitted for Approval Approved Implementing on Schedule? Certified Closed by P.E. Name of Unit: Unit _ of _ of Section E Submitted for Approval Approved Implementing on Schedule? Certified Closed by P.E. EPA I.D. Number CLOSURE PLAN /7no /7n0 U No /7no U Yes /7 Yes O Yes U Yes Date Date Date /7no /7 No U No /7no /7 Yes /7 Yes ij Yes /7 Yes Date Date Date /7no U No /7no /7 No fj Yes U Yes U Yes /7 Yes Date Date Date /7no /7ycs U No U No /7no U Yes /7 Yes fj Yes Date Date Date C*3 DO 144005 CONFIDENTIAL. EPA I.D. Number 5. Name of Unit: CLOSURE PLAN (Continued) Unit __ of __ of Section E Submitted for Approval Approved Implementing on Schedule? Certified Closed by P.E. 6. Name of Unit: /7no /7no O No ij No /7 Yes (J Yes /7 Yes /7Yes Date Date Date Unit _ of __ of Section E Submitted for Approval Approved Implementing on Schedule? /7no /7no /7 No /7 Yes ij Yes /7 Yes Date Date Certified Closed by P.E. /7no /7 Yes Date C-4 DO 144006 confidential. 1 EPA I.D. Number RCRA ACTIVITIES AS OF NOVEMBER 8, 1985 Generator Transporter Storage in tanks Storage in containers Treatment Other Than Land Disposal Codes: /JT01 Comments: S IJ No )f( No /7no /7no U No T03 'V /7Ycs /^sVes /^Yes IJ T04 Accumulation time <90 days X Container X. Tank C-5 oo 144007 CONFIDENTIAL. EPA I.D. Number RCRA ACTIVITIES AS OF NOVEMBER 8, 1985 (Continued) Land Disposal Codes: Comments: U D80 ^D8l U D83 /_/T02^ /7S03 /JSOA /JTQS fj T04 UIC (D79) Exemptions-1 No /_/ No TJ Yes ^Yes Elementary Neutralization Unit Recycle t/J7 No IJ No fj Yes $ Yes Units: Units: Small Quantity Generator fp No O Yes Units: Other Exemption Comments: CLlos? \rrC a r\ \ c- > <. /jf No /7 Yes Units: (UOlL^ f >0.QjV\ n--CT ____ _,,uUg____ v y :u^x? LVL\>_o cjc S-Lj.'cL v L.OfCj) 0J> 7, F' ^"^20^0 on ^ nexae - ?\ 0-- -- ^ C*6 DO 144008 CONFIDENTIAL ) EPA I.D. Number LIST OF DOCUMENTS 1. Title_____________________________________________ ____________________________ Author ______________________________________________________________________ Date Number of Pages Reviewed_____ Copied Subject Relevance 2. Title_________________________________________________________________________ Author______________________________________________________________________ Date Number of Pages Reviewed_____ Copied Subject Relevance 3. Title_________________________________________________________________________ Author Date Number of Pages Subject Relevance Reviewed______ Copied 4. Title____________________________________________________ Author____________________________________________ _________ ________________ Date Number of Pages Reviewed_____ Copied Subject Relevance D-l DO 144009 CONFIDENTIAL. EPA I.D. Number LIST OF DOCUMENTS (Continued) Title Author________________________________ _________________________ _ Date Number of Pages Reviewed Subject Relevance Copied Title_____________ Author__________ Date_____________ Subject Relevance Number of Pages__________ Reviewed ____ Copied Title_____________ Author__________ Date ._____________ Subject Relevance Number of Pages__________ Reviewed______ Copied Title_____________ Author__________ Date_____________ Subject Relevance Number of Pages__________ Reviewed______ Copied D-2 qO 144010 CONFIDENTIAL ) EPA I.D. Number LIST OF DOCUMENTS (Continued) 9. Title_________________________________________________________________________ Author______________________________________________________________________ Date Number of Pages Reviewed_____ Copied Subject Relevance 10. Title_________________________________________________________________________ Author _____________________________________________________________________ Date Number of Pages Reviewed_____ Copied Subject Relevance 11. Title___________________________________________________________ Author______________________________________________ Date Number of Pages Subject Relevance Reviewed_____ Copied 12. Title____________________________________________________________________ Author ________________________________________ ____________________________ Date ,, Number of Pages Reviewed_____ Copied Subject Relevance D-3 DO 144011 CONFIDENTIAL EPA I.D. Number USE SEPARATE SHEET FOR EACH UNIT HAZARDOUS WASTE LAND DISPOSAL UNIT DESCRIPTION Unit No. I of 1. Facilities Name of Unit: LjOla 2. Purpose/Mode of Operation: iXo-*-. ______________________ , pr (> ___ -- 3. Process Code: 31 ' ^ '_________________________________________________ 4. Design Capacity: 6, . QQO ^ ^- X i.. r " (Cite Verification) Volume-v _____ ~ Rate___________________ ______ Depth of unit ^ |o\S' Depth to groundwater to\s, S . M /A 5. Date of Existence: jj uX se^ c1 ' 2\- - X L o .. --, '- (Cite Verification) tg^-- Dates of Last Hazardous and/or Nonhazardous Waste Addition: :................................................................................................ ... ..................... ............ n (Cite Verification) .PCgr oJcvo^ Clh lor\ AC, GOU * Ml)w/w ___^ rs-oofrl^ . .ivL'U 7 0 7. Closure Plan Submittal Date: K ^>ri \ ^ \ ^ fcS>___ 8. Hazardous Waste Code(s) Handled: rj^-\ -i- * f\Q \ck'& (_ro t, C <.( ia \ZjlL>Ts 3. Cj (Cite Verification) Describe: .Ax^.-fr -Cto-vs JrxA y: ~ \ vil/u\ H. O'vQ f----- CKx.-- Ci. C\ v~yq joe. cx. cnriSL 3S= --1 3^ ___ * > ... ~ E-l DO 144012 CONFIDENTIAL EPA I.D. Number____________ Unit No.of 9. Non-hazardous Waste Handled:______ gjLA-X._____________________... ._________ n Lc ;jlQ rV>'Q> Cx ^ "1^ 10. Provide Narrative of History of Operation Since 11-19-80; Cite References: (Y>0 ` \^SO _______ 11. Field Observations: E-2 QO 144013 CONFIDENTIAL V. ) EPA I.D. Number USE SEPARATE SHEET FOR EACH UNIT SWMU DESCRIPTION Unit No.of 1. Name of Unit:______________ 2. Purpose/Associated Processes: 3. Type/Amount of Waste Received: 4. Field Observation: F-l DO 144014 CONFIDENTIAL I I USE SEPARATE SHEET FOR EACH UNIT EPA l.D. Number HAZARDOUS WASTE LAND DISPOSAL UNIT DESCRIPTION Uni: No. _J___ of l 1. Facilities Name of Unit: Purpose/Mode of Operation: -Lt__ ^i>. _______________________________________ Wei? uDoAu ^ v-. "2, oui cC s ^ lA-o^g.-v ^ ^ 1>J Process Code: S (3M______S\ carrycxg sSorCc-O^ \^P Design Capacity: 5* d DA I cLcm-a ~^QjO 1 4 rq (Cite Verification) ____________ Volume \QQ' V ^ % ' < 81 ~ Rate L ^ 7^\ 1 cAdwt vo^o Myvou." z' Depth of unit ______ ________ Depth to ground water L - M V O-XcA to - e>' (cM^p uog\ i .AHigT^ c Oo jLX.r\er 5. Date of Existence: ____________ SVXkLtO-O ' *A (Cite Verification) oQecoj*c\o <CCOCcLc> (oLirV-nCaA ceP^^ Daies of Last Hazardous and/or Nonhazardous Waste Addition: cy cya'ycL ______________________ _______ .______________ r ~T (Cite Verification) on<3.rOL-fcA n y iOCnrrLcs_________________________ ______________________ \ A Closure Plan Submittal Date: A(^S\ VS v l^6^T s. Hazardous Waste Cods(s) Handled: TA CD ~L Qqt f o la (a -g,______ (Cite Verification) Describe: ---------------------------------------- ri'terocfcvrv a lODo* jOVedc^L/ E-l DO 144015 CONFIDENTIAL j EPA I.D. Number Unit No. of 9. Non-hazardous Waste Handled: _ QVAor \ c\oX5Uzk^ T^xjnaM^a^L------- 10. Provide Narrative of History of Operation Since 11-19-80; Cite References: 11. Field Observations: E-2 00 144016 CONFIDENTIAL J EPA I.D. Number_______ USE SEPARATE SHEET FOR EACH UNIT HAZARDOUS WASTE LAND DISPOSAL UNIT DESCRIPTION Unit No. 1 of 1 1. Facilities Name of Unit; QIaAcv ; r\<_________________________________ 2. Purpose/Mode of Operation: SAcx'c.c*- SO'-f 3. Process Code: A. Design Capacity: ) (g AA (Cite Verification) _________________________ Volume 1 X Z-tS ' V l 1 Rate_______*^/Y io _________ Depth of unit_____ 5< 1________________ Depth to ground water *5- 1 Ini'S_______ 5. Date of Existence: \C\G? O irV'-laA ^ o-AjUJ PLflJLQ^J (Cite Verification) . - -V' Qgn-C-A > \ryMQ-^ \S \oT > P _ - (A-cl?!: Qg.ro^.. - <L,______ 3 q, _Z_ ______ --------- ----- ---------------------- . Dates of Last Hazardous and/or Nonhazardous Waste Addition: c b\nv -- (Cite Verification) ___________________________________________________________ 7. Closure Plan Submittal Date: V'S | \S 8. Hazardous Waste Code(s) Handled: Od2> _____________ (Cite Verification) Describe: ______________________ ____ GoaC< _A-L\^ PO JUCtC^CsXx oJJJjv Vl-El CzJLO-LC CO-U- .] DO 144017 CONFIDENTIAL i 9. Non-hazardous Waste Handled: C\ EPA I.D. Number____________ Unit No. of 10. Provide Narrative of History of Operation Since 13-19-80; Cite References: r opiA ______________________________________________________________ 11. Field Observations: DO 144018 E-2 CONFIDENTIAL u* EPA I.D. Number USE SEPARATE SHEET FOR EACH UNIT HAZARDOUS WASTE LAND DISPOSAL UNIT DESCRIPTION Unit No. I of _J____ 1. Facilities Name of Unit: ON iC~_______________________________________ Purpose/Mode of Operation: VVxA- Process Code: 5- ... .lyvat^a...- Design Capacity:______\ . S 7 (Cite Verification) Volume____ X \\L> Q>" X ' <V Ra _____________ lS(S. b Actn ImoAxu Depth of unit_______________________________ Depth to ground water 5--.V V-i\*a______ Date of Existence: _____________ (Cite Verification) Ac^cp Eania rr^rx A \_________Q_______l y"< & \rvVxl CQPu^ H 6. Dates of Last Hazardous and/or Nonhazardous Waste Addition: cn r..o* a \ O (Cite Verification) Closure Plan Submittal Date: (K^>[ > \ ( S t iSftlo . Hazardous Waste Code(s) Handled: (Cite Verification) Describe: ___ E*1 DO 14401^ CONFIDENTIAL I EPA l.D. Number Unit No. of 9. Non-hazardous Waste Handled: C\Of^ _________ _ ___o ^Quo^-,\cn ^ uA____XL,;------------------------------------------------------ une H^rvuL ^ CP. (ev^^Cvcg-gX. _XA.^er . ^ .(izocWiXz CC>\\g.C*3on -^\N-\ ___________________________________________ 10. Provide Narrative of History of Operation Since 11-19*80; Cite References:11 ooa.o? co*i^ 11. Field Observations: E-2 DO 144020 CONFIDENTIAL  EPA PRELIKINART ASSESSMENT AND SITE INVESTIGATION July 1 and 2, 1986 AGENDA Environmental Operations Plant EC-1 & EC-2 UNOX/Clarifiers System Northwest Landfill Cells #1 and t2 Australia Point Landfill Solvents Plant Tank Storage Shot Pond Light Hydrocarbons I. II, III Plants LHC III Surface Impoundment LHC II Surface Impoundment API Separator Cell Service Plant Impoundment 50 Asbestos Wash Area DO 144021 CONFIDENTIAL Polyethylene B Plant Surface Impoundment Closure Cellulose Plant Surface Impoundment Closure Methocel Characterization Coal Slurry Production Plant Surface Impoundment Closure Tank Car Cleaning Products/Waste Managed Release Controls Vinyl II Plant Surface Impoundment Status Temporary Storage Facilities Site Inspections CG :sb 6/30/86 DO 144022 CONFIDENTIAL SOLID WASTE MANAGEMENT UNIT: Surface Impoundment (EC-1) FACILITY (BLOCK#): Environmental Operations (Block 60) USE: Storage of division'^ wastewater (non-hazardous) for treatment STATUS: In operation, no closu. e planned. This facility is currently operating under Interim Permit No. IP-0175-A. MATERIALS OF CONSTRUCTION: A single chlorinated poly ethylene liner DIMENSIONS: 660 at 660' x 7* (LxVxD) CAPACITY: 19 MM Gallons CONTENTS (QUANTITY/VOLUME): 3 pccxk.. mw E, Wastewater containing traces of biodegradable waste from production facilities ^C.au.ie-o^cc. HAZARDOUS WASTE/CONSTITUENTS: Non-hazardous DISPOSAL DATES: 1978 - Present OTHER COMMENTS: This facility has two monitoring wells thBt are used in conjunction with a leachate collection system to detect releases. 3 v-oexx-ci \ DO 144023 CONFIDENTIAL. SOLID WASTE MANAGEMENT UNIT: Auxiliary Tank (EC-2) FACILITY (ELOCK #): Environmental Operations (BIock 60) USE: Storage of Division's non-hazardous wastewater for treatment STATUS: In operation, no closure planned MATERIALS OF CONSTRUCTION: Concrete lined DIMENSIONS: 500' x 500' x 7' (LxWxD) CAPACITY: 11 MM gallons CONTENTS (QUANTITY/VOLUME): Wastewater containing traces of biodegradable waste from production f acilities HAZARDOUS WASTE/CONSTITUENTS: Non-hazardous DISPOSAL DATES: 198U - Present OTHER COMMENTS: This facility is used for wastewater treatment equalization prior to its treatment. CG: sb 6/30/86 DO 144024 CONFIDENTIAL SOLID WASTE MANAGEMENT UNIT: UNOX/Clarifieri System FACILITY (BLOCK#): Environmental Operations (Block 80) USE: Wastewater Treatment (Biological Oxidation) Unit STATUS: In operation, MATERIALS OF CONSTRUCTION: Concrete DIMENSIONS: (LxWxD) Clarifier - 130' Diameter; 13' Side Wall Depth UNOX Reactor - 12 Compartments # m x k1' x 12' D VOLUME: 1.85 MM Gallons (UNOX) 1.50 MM Gallons (Clarifiers) CONTENTS (QUANTITY/VOLUME): Wastewater containing biological mass HAZARDOUS WASTE/CONSTITUENTS: Non-hazardous DISPOSAL DATES: 1976 - Present DO 144025 CONFIDENTIAL SOLID WASTE MANAGEMENT UNIT: Inactive landfill FACILITY (BLOCK#): Northwest Landfill (Cell #1 and #2) USE: Disposal of non-hazardous waste STATUS: Inactive, closed and capped with clay MATERIALS OF CONSTRUCTION: Earthen DIMENSIONS: Cell 1 (9 acres, 12'deep) (LxWxD) Cell 2 (A* acres, 10'deep) CAPACITY: Cell 1 - H,70U,H80 ft3 Cell 2 - 1 ,7^2,400 ft3 CONTENTS (QUANTITY/VOLUME): See cooments HAZARDOUS WASTE/CONSTITUENTS: Non-hazardous DISPOSAL DATES: 1975 - 1981 OTHER COMMENTS: These two landfill cells contain no hazar dous waste. Six wells are used for groundwater oonltoring. WASTE LANDFILLED AT NORTHWEST LANDFILL CHLORINATED POLYETHYLENE METHOCEL*/CELLULOSE PULP CARBON ASBESTOS CONTAMINATED CELLS COAL EMPTY CONTAMINATED DRUMS I - ANTIFREEZE ALUMINA MISCELLANEOUS PLASTICS TRADEMARK OF THE DOW CHEMICAL COMPANY D0 14402fc CONFIDENTIAL I SOLID WASTE MANAGEMENT UNIT: Active Landfill FACILITY (BLOCK#): Australia Point Landfill USE: Disposal of construction materials, non-hazardous water Insoluble materials (l.e. steel, brick, concrete, asphalt roofing, lumber, plastic, etc.) STATUS: Partially closed, complete closure expected In 1985 MATERIALS OF CONSTRUCTION: Earthen DIMENSIONS: 19 seres (LxWxD) CONTENTS (QUANTITY/VOLUME): Construction materials and miseellaneous solid (non-hazardous) waste HAZARDOUS WASTE/CONSTITUENTS: Non-hazardous DISPOSAL DATES: 1961-Present OTHER COMMENTS: Surface water monitoring is planned after closure. Closure is being conducted under Closure Compliance Order. DO 144027 CONFIDENTIAL CLOSURE PLAN SUBMITTED FOR APPROVAL CLEARING a GRUBBING OF ADJACENT PROPERTY CONTRACT LET FOR CLOSURE ELEMENTS PHASE I CLOSURE ELEMENTS' 1. SURFACE SILTS REMOVED FROM BORROW AREAS a SPREAD OVER UPPER TIER AS BUFFER 2 BUFFER SILTS GRAOED ANO SLOPED 3. REMOVE CLAYS AND ADDITIONAL SILTS ANO STOCKPILE ON UPPER TIER FOR DRYING 4. SPREAD AND COMPACT CLAY BARRIER ON UPPER TIER 3 ADD LOAM AND SEED 6.KEY-IN TRENCH CONSTRUCTED PHASE TL CLOSURE ELEMENTS 1. APPLY BUFFER SILTS ON LOWER TIER 2. APPLY CLAY BARRIER ANO SLOPE 3. APPLY COVER LOAM ANO VEGETATE 4 LEACHATE COLLECTION DITCH CONSTRUCTED AUG SEPT 1984 OCT - 1 >-------- NOV ----< DEC JAN FEB MAR 1909 APR MAY JUN JUL ---------4 i ........ -- b o ' cr <7> tn ~~ O "_J " *1 U" CM O Z-J D -> -> O VU - X- u wl 1 --1 FIGURE <0 r FIGURE 9 DOW CHEMICAL LOUISIANA DIVISION CLOSURE SCHEDULE AUSTRALIA POINT LANDFILL >. AUSTRALIA POIM LANDFILL 6/25/8U 1/12/8^ 7/25/85 11/6/85 11/26/85 12/3/85 3/31/86 Closure Compliance Order Issued - Closure Date 6/25/85 Closure Date Shown In Closure Plant - June 25, 1985 Closure Compliance Order Requested for December 31, 1965 Closure Compliance Order Issued - Closure Date 12/31/85 Authority to Begin Construction Block 80 SWLF Closure Date Extension Requested for 5/15/86 Closure Date Extension Requested for 8/30/86 Enforcement Order Received - Closure Date 8/30/86 Four Tasks Renain 1. Install buffer zone soil and final clay cap in remaining disposal zone and complete final key-in of clay cover. 2. Place final topsoil cover over remaining clay cap. 3. Install remaining vent system. H. Install final fence and collection sump and seed final cover. CG :sb 6/30/86 DO 144029 CONFIDENTIAL SOLID WASTE MANAGEMENT UNIT: Tank Storage D-15. V-201, D-13, D-92A, D-701, T-1001, D-700 FACILITY (BLOCK#): Solvents Plant (Block 16) USE: Storage vessels for chlorinated waste by-products from the perchloroethylene-carbon tetrachloride manufacturlng process prior to incineration STATUS: In operation HATERALS OF CONSTRUCTION: Monel, Alloy *00 steel, SA-285, Grade C, or Carbon Steel DIMENSIONS: (Diameter x Height) D-13 D-92A D-700 T-1001 6'x12* 3'x7' 7'xll' 1 2 ' x 15 ' D-15 V-201 D-701 12'x2*' 12'x*0' 8"x20' CAPACITY: 833,831 lbs of organic waste material CONTENTS (QUANTITY/VOLUME): C>Hc>: ,,\c H Heavy ends from the distilla tion of ethylene dlchloride, vinyl chloride, carbon tetra chloride, perchloroethylene and trichloropropene (K019, K020) HAZARDOUS WASTE/CONSTITUENTS: Hazardous Waste OTHER COMMENTS: By placing heavy emphasis on the prevention and early detection of leaks through pre ventive maintenance type programs, a daily inspection program, and logging of tank levels every two hours, the release of hazardous liquid waste material from the containment area is prevented. DO 144030 CONFIDENTIAL SOLVENTS PLANT \ Unit: Shot Pond Use: Facility drainage from diked storage area. Drainage from these areas is contained by curbing. The ground is sloped toward collection sump. All drainage is inspected prior to removal. Status: Operational, no closure planned. Materials of Construction: Concrete Dimensions: 40 x 10 (L x W x D) Capacity: 12,000 gallons Contents: Rainwater Disposal Dates: 1982(?) - Date CG: sb 6/27/86 OO 144031 CONFIDENTIAL SOLID WASTE MANAGEMENT UNIT: Surface Impoundment FACILITY (BLOCK#): Light Hydrocarbons III (Block 58) USE: Collection of rainwater runoff STATUS: Impoundment will be closed in January, 1986 MATERIALS OF CONSTRUCTION: Earthen bottom with chlorinated polyethylene lined sides DIMENSIONS: 26V x 112' x 7' (LxWxD) CAPACITY: 1.2 MM Gallons CONTENTS (QUANTITY/VOLUME): Rainwater runoff HAZARDOUS WASTE/CONSTITUENTS: Non-Hazardous DISPOSAL DATES: 1979 - 1986 OTHER COMMENTS: The impoundment contains rainwater runoff from the process area. DO 144032 CONFIDENTIAL LIGHT HTDROCARBON III SURFACE IMPOUNDMENT Purposes of Closure: 1. Environmental upgrade. 2. Further purification of block wastewater prior to division canal discharge. Closure Procedures: 1. Drain the impoundment and allow it to dry out (approximately 3 to ^ weeks). 2. Inspect for contamination. 3. Remove any contaminated soil. 4. Contaminated soil will be incinerated at Environmental Operations rotary kiln. 5. Site is leveled and backfilled with clay. Closure Completed - May 23. 1986 Note: Rainwater impoundment was replaced with above ground storage tanks. CG: sb 6/30/66 DO 144033 CONFIDENTIAL SOLID WASTE MANAGEMENT UNIT: Surface lapoundsent (31) FACILITY (BLOCK#): Light Hydrocarbon I/II (Block 39) USE: Secondary settling pond to resovt suspended solids froo waste stress prior to discharge. (Outfall No. 007, Perait No. 0003301) STATUS: Closure planned for 12/85 as indicated in closure plan subcitted in response to Closure Conpllance Order, No. C-0620 MATERIALS OF CONSTRUCTION: Chlorinated polyethylene lined levee with earthen bottots (cl ay-perBeabl11ty 1 x 10-7 cm/sec.) DIMENSIONS: 91' x 128' x 7* Deep (LxVxD) CAPACITY: 609,889 Gallons CONTENTS (QUANTITY/VOLUME): Water with trace amounts of suspended solids and hydrocar bons such as oil, grease, and benzene. HAZARDOUS WASTE/CONSTITUENTS: Water with trace amounts of hazardous constituent such as benzene. DISPOSAL DATES: 1977 - 12/85 Closure scheduled for 12/85 DO 144034 CONFIDENTIAL W/\ ccM curr'icJ'i. ifjTrcfC'fJ 04rK (jC 5y-_'rr< Fo/J 0/{- Aa;d OPrPS(L P`ES'O'JP L- TO oVTALL DO 1 4 4 0 3 5 C O N FID EN TIAL SOLID WASTE MANAGEMENT UNIT: Surface lapoundment (SO) FACILITY (BLOCK#): Cell Service (Block 56) USE: Stonge of water use for recycling. STATUS: Closed under Closure Compliance Order No. C-0599 MATERIALS OF CONSTRUCTION: A single chlorinated poly ethylene liner DIMENSIONS: (LxWxD) 110' x 110* x 6' CAPACITY: 5*3,120 Gallons CONTENTS (GUANTITY/VOLUHE): Water and asbestos (152,000 gallons/week) HAZARDOUS WASTE/CONSTITUENTS: Non-hazardous DISPOSAL DATES: 1977 - 1985 OTHER COMMENTS: This impoundment was closed in July of 1985* DO 144036 CONFIDENTIAL CLOSURE PROCEDURE CELL SERVICE PLAN? SURFACE IMPOUNDMENT Ts sk Pump impoundment water to Wastewater Treatment Plant Remove asbestos sludge and CPE liner from impoundment and place on concrete for dewatering Asbestos sludge/CPE liner allowed tc drain off free water Take soil samples from impoundment for analysis Excavate soil, leachate piping and sump from impoundment Soil, leachate piping, and sump material to solid waste landfill Fill former impoundment with silty clay, compact, level to grade, and seed with grass Certification of closure DEQ notified of completed closure CG:sb 6/27/86 DO 144037 CONFIDENTIAL ASBESTOS WASH AREA ANODE REMOVAL CG :sb 6/27/86 00 144038 CONFIDENTIAL J SOLID WASTE MANAGEMENT UNIT: Surface Impoundment (a) FACILITY (BLOCK#): Polyethylene B (Block 9) USE: Two adjacent impoundments (primary and secondary) are used for polymer settling prior to NFDES water discharge. STATUS: Closure schedule for January, 1986. MATERIALS OF CONSTRUCTION: Earthen DIMENSIONS: Impoundment 1 - 71' x 3?' x 10f (LxVxD) Impoundment 2 - x 7 V x 10' CAPACITY: 169,968 Gallons (Impoundment 1) 2^3,581 Gallons (Impoundment 2) CONTENTS (QUANTITY/VOLUHE): Primarily water, with trace amounts or polyethylene powder, and catalyst residue (titanium and magnesium oxides) HAZARDOUS WASTE/CONST1TUENTS: Non-hazardous DISPOSAL DATES: August, 1962 - 1986 OTHER COMMENTS: These surface impoundments contain only non-hazerdous wastes. DO 144039 confidential. ) POLYETHYLENE B SURFACE IMPOUNDMENT CLOSURE Closure Completed*. November, 198S No soil or sludge was removed from the impoundment bottom. Soil samples were collected of which the analysis showed no effects from surface impoundment. CG:sb 6/3C/86 QQ 14^04-0 CONFIDENTIAL SOLID WASTE MANAGEMENT UNIT: Surface Impoundment (s) FACILITY (BLOCK#): Cellulose (Block *5) USE: Primary and secondary holding ponds STATUS: Both impoundments were closed under Closure Compliance Order No. C-0576 MATERIALS OF CONSTRUCTION: Earthen (Both) DIMENSIONS: Impoundment 1 - 7*)' x 90* x fc' (LxVxD) Impoundment 2 - 105' x 150' x 8' CAPACITY: 201,987 Gallons (Impoundment 1) 9*42,606 Gallons (Impoundment 2) CONTENTS (QUANTITY/VOLUME): Brine water containing Methocel* HAZARDOUS WASTE/CONSTITUENTS: Non-hazardous DISPOSAL DATES: 1976 - 1985 OTHER COMMENTS: These surface impoundments contained only non-hazardous wastes. All wastes were removed and incinerated. TRADEMARK OF THE DOW CHEMICAL COMPANY DO 144041 CONFIDENTIAL CLOSURE SCHEDULE BLOCK M5 - SURFACE IMPOUNDMENTS 26 i 27 CELLULOSE PLANT 1,500 yd3 process solid waste material placed in 30 gallon packs. This material was disposed of via incineration. Resulting ash disposed of at Northwest Landfill. Contaminated soil down to six inches beneath the bottom and sides of the impoundment was excavated and landfilled at Australia Point Landfill. Composition of contaminated soil 2-55 methylcellulose products. Impoundment backfilled wtih levee material and silty clay. June 27, 1985 DEQ notified of closure. CG:sb 6/27/86 DO 144042 CONFIDENTIAL MATERIAL SAFETY DATA SHEET PAGE: I DOW CHEMICAL U.S.A. MIDLAND MICHIGAN AB6A0 EMERGENCY PHONE: E> 1 7 -1> 3 >-M A 0 0 EFFECTIVE DATE: 02 FEB 83 PRODUCT CODE: 53971 PRODUCT NAME: METHDCEL R) J75MS HYDROXYPROPYL METHYICELLULOSE MSD: 0058 INGREDIENTS (TYPICAL VALUES-NOT SPECIFICATIONS) methoxyl HYDROXYLPROPOXYL 18.520 23-32 SECTION 1 PHYSICAL DATA BOILING POINT! NOT APPLICABLE VAP PRESS: NOT APPLICABLE VAP DENSITY (AIR=1): NOT APPLIC. SOL. IN WATER: SEE SECT. 8 sp. gravity: not applicable X VOLATILE BY VOLI NOT APPLICABLE PEARANCE AND ODOR: WHITE TO SLIGHTLY OFF-WHITE FREE FLOWING POWDER. SECTION 2 FIRE AND EXPLOSION HAZARD DATA flash point: n/a, method used: -------- FLAMMABLE LIMITS lfl: not deter, ufl: not deter. EXTINGUISHING MEDIA! WATER FOG. SPECIAL fire fighting equipment and hazards: MINIMUM EXPLOSIVE DUST CONCENTRATION IS 0.03 OZ/CU FT. SIMILAR TO FLOJR OR GRAIN DUSTS! KEEP CLOUDS OF SUCH DUST AWAY FROM POSSIBLE IGNITION SOURCES. SECTION 3 REACTIVITY DATA stability: avoid DUST CLOUDS or LAYERS. incompatibility: oxidizing material. HAZARDOUS DECOMPOSITION PRODUCTS! -------- hazardous polymerization: WILL NOT OCCUR. SECTION A SPILL* LEAK* AND DISPOSAL PROCEDURES DO 144043 CONFIDENTIAL TIDN TO TAKE FOR SPILLS: SWEEP UP - USE IF POSSIBLE* OR DISCARD. DISPOSAL METHOD: PREFERABLE METHOD WOULD BE TO BURY. CAN BE BURNED UNDER CAREFULLY CONTROLLED CONDITIONS TO ELIMINATE DUST EXPLOSIONS. (CONTINUED ON PAGE 2 ) 0<5w tHtMICAL U.S.A. MIDLAND MICHIGAN AfcfeAO [KLHLNCT 5 1 7-fcJG-44L l EFFECTIVE DA 7 C: PJ FEB 83 ) DUC T (CONT*D>: METHOCEL (R) J75MS HYDR0XYPROPYL METHYLCELLULOSE PRODUCT COTF: 53971 MS D: 0058 SECTION 5 HEALTH HAZARD DATA eye: mechanical injury only. skin contact: mechanical injury only. SKIN ABSORPTION: NOT ABSORBED - LOW IN HAZARD. ingestion: very low acute and chronic oral toxicity; lD5p = >10 g/kg rats. inhalation: DOW INDUSTRIAL HYGIENE GUIDE IS 10 MG/M3 FOR NUISANCE PJST effect. SYSTEMIC & OTHER EFFECTS: NONE KNOWN. SECTION 6 FIRST AID EYES: IRRIGATION of THE eye IMMEDIATELY WITH WATER FOR FIVE MINUTES IS GOOD SAFETY PRACTICE- skin: wash off in flowing water. gestion: no effect expected. inhalation: remove to fresh air if effects occur. note to physician: eyes: mechanical injury only, skin: mechanical injury only, respiratory: nuisance dust, oral: very low in toxicity, systemic: injury is unlikely. SECTION 7 special HANDLING INFORMATION ventilation: recommend control of dust to SUGGESTED GUIDE. RESPIRATORY PROTECTION: NONE NORMALLY NEEDED. IF REQUIRED* USE AN APPROVED DUSTRESPIRATOR. PROTECTIVE CLOTHING: NONEREQUIRED. EYE PROTECTION: NOT NORMALLY NECESSARY. SAFETY G-ASSES WITHOUT SIDE SHIELDS. SECTION 8 SPECIAL PRECAUTIONS AND ADDITIONAL INFORMATION ^ M oz LU oz oo PRECAUTIONS TO BE TAKEN IN HANDLING AND STORAGE: USE REASONABLE CAUTION AND PERSONAL CLEANLINESS. CELLULOSE ETHERS ARE WATER-SOLUBLE POLYMERS WHICH FORM AGUEOUS DISPERSIONS BY SWELLING AND BY SUCCESSFUL HYDRATION OF THEIR STRUCTURAL LAYERS. THERE IS NO SHARP SOLUBILITY LIMIT, CAUTION*. UNDER CERTAIN CONDITIONS A FINE DUST OF THIS MATERIAL IN AIR MAY CAUSE A DUST EXPLOSION WHEN EXPOSED TO HEAT* SPARKS* AND *';S;AL-CA*[-' DO*/ CHEMICAL U.S.A. MIDLAND MICHIGAN lT t - - IT PAGE ! 3 EMERGENCY PHOLl: M7-63fe-A A 00 EFFECTIVE DATE: C2 FCr 83 DUCT (CONTD>: METHOCEL (R) J75MS HYDROXYPR OPYL METHYLCELLULOSE r^ODUCT COPE: 51971 MSP; 0 0 58 SECTION 8 SPECIAL PRECAUTIONS AND ADDITIONAL INFORMATION (CONTINUED) PRECAUTIONS TO BE TAKEN IN HANDLING AND STORAGE*. (CONTINUED) open flame. ADDITIONAL INFORMATION! 0? FEB 83 REVISIONS: SECTIONS ? AND P. LAST (R) INDICATES A TRADEMARK OF THE DOW CHEMICAL COMPANY THE INFORMATION HEREIN IS GIVEN IN GOOD FAITH. BUT NO WARRANTY. EXPRESSED OR IMPLIED. IS MADE. CONSULT THE DOW CHEMICAL COMPANY FOR FURTHER INFORMATION. RAGE DO 144045 CONFIDENTIAL SOLID WASTE MANAGEMENT UNIT: Surface Impoundaent (37) FACILITY (BLOCK#): Coal Slurry Production Plant (Block 70) USE: Settling pond for rainwater runoff froa coal pile. STATUS: Closure is scheduled for August 1965, awaiting a Closure Cotrpliance Order froB the DepartBent of Envlronmental Quality. This facility is presently operating under Interim Permit No. IP-0175-A. MATERIALS OF CONSTRUCTION: Earthen {3* levee) DIMENSIONS: 100' x *0' x H Deep (LxVxD) CAPACITY: 213,000 Gallons CONTENTS (QUANTITY/VOLUME): Rainwater runoff from eosl storage pile HAZARDOUS WASTE/CONSTITUENTS: Coal particles are not hazardous DISPOSAL DATES: 1981 - 6/85 (Estimated) OTHER COMMENTS: This surface impoundment only contains nonhazardous materials. qO 144046 CONFIDENTIAL CLOSURE PROCEDURE COAL SLURRY PLANT SURFACE IMPOUNDMENT Task Pump impoundment water tc Wastewater Treatment Plant's outfall Sludge dewatering Sludge removal and landfill Pipe installation and concrete work Fill impoundment with silty clay, compact and level to grade Install new sump cover and backfill Certification of closure DEQ notified of completed closure CG: sb 6/27/86 DO 144047 CONFIDENTIAL 0 VINIL II PLANT Unit: Rainwater Pond Use: Pond #1 - Rainwater Pond (Emergency Containment for Vinyl Spills) Pond 2 - Rainwater Collection (Pit H30) Status: Operational; No Closure Planned Materials of Construction: Concrete Capacity Pond #1: Pond #2: Approximately 1MM Gallons (Pit L30) Contents: Rainwater Disposal Dates: 1977 - Present CG: sb 6/86 DO 144048 CONFIDENTIAL CG: sb 6/30/86 TEMPORARY STORAGE FACILITIES POLYETHYLENE C AS&7L CA II CHLORINE CAUSTIC CPE ENVIRONMENTAL OPERATIONS GLYCOL I GLYCOL II LHC II LHC III LUBRICATION METHANES POLY A POLY E SOLVENTS VINYL II EDC I MAINTENANCE TECH (FAE SHOP) DO 144049 CONFIDENTIAL. (J `* NWLF Groundwater Monitor Summary ') 1961 installed 5 groundwater monitor wells. Part II response - need more wells. 1986 installed 3 more wells. CPE Groundwater Monitor Summary 1981 installed site-specific wells. Part II response question direction of groundwater and need for shallower wells. 1965 Annual report proposed installing 3 shallow wells. Chlorine Installed perimeter groundwater system around Division to monitor groundwater. 19&4 state requires site-specific wells. These wells installed in 1985. CA II Installed perimeter groundwater system around Division to monitor groundwater. 1984 state requires site-specific wells. These wells installed in 1983. Overall Philosophy of Groundwater Monitoring NWLF - 1981 wells installed CPE - Wells installed 1961 Perimeter wells installed 1982 Administration Order 1984 - Chlorine wells 1985 CA II wells 1984 - 1985 CG :sb 6/86 DO 144050 CONFIDENTIAL EPA I.D- Number USE SEPARATE SHEET FOR EACH UNIT HAZARDOUS WASTE LAND DISPOSAL UNIT DESCRIPTION Unit No. of J. Facilities Name of Unit: __________________________________ ,,____________ _ 2. Purpose/Mode of Operation:_____________________________________ __________ 3. Process Code:___________________________________________________ _ 4 Design Capacity:______________________________________________ _____________ (Cite Verification) Volume Rate_____________________________________________________ Depth of unit____________________________________________________ _______ Depth io ground water____________________________________________ _____ 5. Date of Existence:_________________________________________________ ___ (Cite Verification) ________________________________________________ _______ fc. Dates of Last Hazardous and/or Nonhazardous Waste Addition: (Cite Verification) ______________________________________________ 1. Closure Plan Submittal Date: __ . Hazardous Waste Code(s) Handled: (Cite Verification) Describe: __ E*1 DO 144051 CONFIDENTIAL. 9. Non-hazardous Waste Handled: ) EPA l.P. Number______________ Unit No. of JO. Provide Narrative of History of Operation Since 11-19-80; Cite References: JJ. Field Observations: E* DO 144052 CONFIDENTIAL EPA l.D. Number USE SEPARATE SHEET FOR EACH UNIT HAZARDOUS WASTE LAND DISPOSAL UNIT DESCRIPTION Unit No. of 1. Facilities Name of Unit:________________ ______________ _____________________ 2. Purpose/Mode of Operation:____________________________ ;___________________ 3. Process Code:________________________________________________________________ A, Design Capacity:__________________________________________________________ __ (Cite Verification) ________________________________________________________ V olume_______________________________________________________________________ Rate __________________________________________________________________________ Depth of unit Depth to ground water______________ ;_______________________________________ 5. Date of Existence: ________________________________________________________ (Cite Verification) ________________________________________________________ 6. Dates of Last Hazardous and/or Nonhazardous Waste Addition: (Cite Verification) _________________________________________ __ Closure Plan Submittal Date: __ 8. Hazardous Waste Code(s) Handled: (Cite Verification) Describe: __ E-J D0 144053 CONFIDENTIAL 9. Non*hazardou$ Waste Handled: ) EPA l.D. Number____________ _ Unit No. of 10. Provide Narrative of History of Operation Since 11*19*80; Cite References: 11. Field Observations: E-2 DO 144054 CONFIDENTIAL EPA l.D. Number USE SEPARATE SHEET FOR EACH UNIT HAZARDOUS WASTE LAND DISPOSAL UNIT DESCRIPTION Unit No. of 1. Facilities Name of Unit:___________________________ _______________________ 2. Purpose/Mode of Operation: ._____________________________________ ;_________ 3. Process Code:________________________________________________________________ A. Design Capacity:_____________________________________________________________ (Cite Verification) Volume_______________________________________________________________________ Rate _________________________________________________________________________ Depth of unit________________________________________________________________ Depth to ground water 5. Date of Existence: ________________________________________________ (Cite Verification) ________________________________________________________ 6. Dates of Last Hazardous and/or Nonhazardous Waste Addition: (Cite Verification) ____________________________________ 1. Closure Plan Submittal Date: __ 8. Hazardous Waste Code(s) Handled: (Cite Verification) Describe: __ DO 144055 E-l confidential 9. Non-hazardous Waste Handled: EPA l.D. Number____________ Unit No. of ]0. Provide Narrative of History of Operation Since 11*19-80; Cite References: 11. Field Observations: E-2 DO 144056 CONFIDENTIAL EPA l.D. Number USE SEPARATE SHEET FOR EACH UNIT HAZARDOUS WASTE LAND DISPOSAL UNIT DESCRIPTION Unit No. of 1. Facilities Name of Unit:______________ _____________________________________ 2. Purpose/Mode of Operation:____________________________ __________' 3. . Process Code:________________________________________________________________ A. Design Capacity:____________________________________________________________ (Cite Verification) ________________________________________________________ Volume Rate_________________________________________________________________________ Depth of unit________________________________________________________________ Depth to ground water______________________________________________________ 5. Date of Existence: ________________________________________________________ (Cite Verification) _________________;_______________________________________ 6. Dates of Last Hazardous and/or Nonhazardous Waste Addition: (Cite Verification) ______________________________________________ 7. Closure Plan Submittal Date: __ 8. Hazardous W;aste Code(s) Handled: (Cite Verification) Describe: ___ 144057 E-l CNFTD5NTrAI. 9. Non-hazardous Waste Handled: ) EPA I.D. Number___________ _ Unit No. of 10. Provide Narrative of History of Operation Since 11*19*80; Cite References: 11. Field Observations: E-2 DO l*40* confidential EPA l.D. Number USE SEPARATE SHEET FOR EACH UNIT S_WMU DESCRIPTION Unit No.______of_______ 1. Name of Unit: 2. Purpose/Associated Processes: 3. Type/Amount of Waste Received: 4. Field Observation: DO 144059 F-3 CONFIDENTIAL till EPA I.D. Number USE SEPARATE SHEET FOR EACH UNIT SWMU DESCRIPTION Unit No.of 1. Name of Unit:_______________ 2. Purpose/Associated Processes: Type/Amount of Waste Received: 4. Field Observation: DO 144060 CONFIDENTIAL F-l O) EPA l.D. Number USE SEPARATE SHEET FOR EACH UNIT SWMU DESCRIPTION Unit No.of 1. Name of Unit:_______________ 2. Purpose/Associated Processes: Type/Amount of Waste Received: A, Field Observation: DO 144061 F*1 CONFIDENTIAL EPA I.D. Number USE SEPARATE SHEET FOR EACH UNIT SWMU DESCRIPTION Unit No.of J. Name of Unit:________________ 2. Purpose/Associated Processes: 3. Type/Amount of Waste Received: A, Field Observation: DO 144062 F-J CONFIDENTIAL EPA I.D. Number USE SEPARATE SHEET FOR EACH UNIT SWMU DESCRIPTION Unit No.______of______ 1. Name of Unit:_______________ 2. Purpose/Associated Processes: 3. Type/Amouni of Waste Received: A. Field Observation: DO 144063 F-l CONFIDENTIAL. I EPA l.D. Number USE SEPARATE SHEET FOR EACH UNIT SWMU DESCRIPTION Unit No.______of______ 1, Name of Unit:_______________ 2. Purpose/Associated Processes: 3. Type/Amount of Waste Received: A. Field Observation: F-] DO 144064 CONFIDENTIAL t. EPA l.D. Number USE SEPARATE SHEET FOR EACH UNIT SWMU DESCRIPTION Unit No.of 1. Name of Unit: 2. Purpose/Associated Processes: 3. Type/Amount of Waste Received: A. Field Observation: DO 144065 F-l CONFIDENTIAL ) EPA I.D. Number USE SEPARATE SHEET FOR EACH UNIT SWMU DESCRIPTION Unit No.of 1. Name of Unit:_______________ 2, Purpose/Associated Processes: 3. Type/Amount of Waste Received: A. Field Observation: DO 144066 F-l CONFIDENTIAL I EPA l.D. Number USE SEPARATE SHEET FOR EACH UNIT SWMU DESCRIPTION Unit No.of 1. Name of Unit:_______________ 2. Purpose/Associated Processes: Typc/Amoum of Waste Received: A. Field Observation: DO 144067 F-l CONFIDENTIAL Of EPA l.D. Number USE SEPARATE SHEET FOR EACH UNIT SWMU DESCRIPTION Unit No.of 1. Name of Unit:_______________ 2. Purpose/Associated Processes: 3. Type/Amount of Waste Received: A. Field Observation: DO 144068 F-l CONFIDENTIAL EPA I.D. Number USE SEPARATE SHEET FOR EACH UNIT SWMU DESCRIPTION Unit No.of 1. Name of Unit:_______________ 2. Purpose/Associated Processes: 3. Type/Amount of Waste Received: A, Field Observation: DO 144069 F-l CONFIDENTIAL EPA I.D. Number USE SEPARATE SHEET FOR EACH UNIT SWMU DESCRIPTION Unit No.of 1. Name of Unit:_______________ 2. Purposc/Associated Processes: 3. Type/Amount of Waste Received: A. Field Observation: F*1 DO 144070 CONFIDENTIAL EPA I.D. Number USE SEPARATE SHEET FOR EACH UNIT SWMU DESCRIPTION Unit No.of 1. Name of Unit:_______________ 2. Purpose/Associated Processes: 3. Typc/Amount of Waste Received: A. Field Observation; F-l DO 144071 CONFIDENTIAL. EPA I.D. Number USE SEPARATE SHEET FOR EACH UNIT ?WMV PESCBJrriPK Unit No.______of______ 1. Name of Unit:_______________ 2. Purpose/Associated Processes: 3. Type/Amount of Waste Received: 4. Field Observation: DO 144072 F-l CONFIDENTIAL EPA I.D. Number USE SEPARATE SHEET FOR EACH UNIT SWMU DESCRIPTION Unit No.of 1. Name of Unit:_______________ 2. Purpose/Associated Processes: 3. Type/Amount of Waste Received: A. Field Observation: DO 144073 CONFIDENTIAL F-l USE SEPARATE SHEET FOR EACH UNIT EPA I.D. Number SWMU DESCRIPTION Unit No. of 1. Name of Unit:_______________ 2. Purpose/Associated Processes: 3. Type/Amount of Waste Received: 4. Field Observation: DO 144074 CONFIDENTIAL F-l EPA I.D. Number USE SEPARATE SHEET FOR EACH UNIT WMU DESCRIPTION Unit No.of 1. Name of Unit:_______________ 2. Purpose/Associated Processes: 3. Type/Amount of Waste Received: 4. Field Observation: 44075 DO * dehtial F-l CONFl EPA I.D. Number USE SEPARATE SHEET FOR EACH UNIT SWMU DESCRIPTION Unit No.of 1. Name of Unit:_______________ 2. Purpose/Associated Processes: Type/Amount of Waste Received: A. Field Observation: 00 144076 CONFIDENTIAL. F-I EPA I.D. Number USE SEPARATE SHEET FOR EACH UNIT SWMU DESCRIPTION Unit No.of 1. Name of Unit:_______________ 2. Purpose/Associated Processes: 3. Type/Amount of Waste Received: A. Field Observation: D0 144077 CONFIDENTIAL F-I EPA l.D. NumbcT USE SEPARATE SHEET FOR EACH UNIT SWMU DESCRIPTION Unit No.of 1. Name of Unit: 2. Purpose/Associated Processes: 3. Type/Amount of Waste Received: A. Field Observation: DO 144078 F-l CONFIDENTIAL \ 'M. .1 EPA I.D. Number USE SEPARATE SHEET FOR EACH UNIT SWMU DESCRIPTION Unit No.of 1. Name of Unit:________________ 2. Purpose/Associated Processes: 3. Type/Amouni of Waste Received: 4. Field Observation: DO 144079 CONFIDENTIAL F*1 USE SEPARATE SHEET FOR EACH UNIT EPA I.D. Number SWMU DESCRIPTION Unit No.of 1. Name of Unit:_______________ 2. Purpost/Associated Processes: 3. Type/Amount of Waste Received: A. Field Observation: DO 144080 CONFIDENTIAL EPA I.D. Number USE SEPARATE SHEET FOR EACH UNIT SWMU DESCRIPTION Unit No.______of_______ 1. Name of Unit:_______________ 2. Purpose/Associated Processes: 3. Type/Amount of Waste Received: Field Observation: DO 144081 F-l CONFIDENTIAL EPA I.D. Number USE SEPARATE SHEET FOR EACH UNIT SWMU DESCRIPTION Unit No.______of______ 1. Name of Uni::_______________ 2. Purpose/Associated Processes: 3. Type/Amount of Waste Received: A. Field Observation: F-l 0Q 144082 CONFIDENTIAL USE SEPARATE SHEET FOR EACH UNIT SWMU DESCRIPTION Unit No.______of______ 1. Name of Unit:_______________ 2. Purpose/Associated Processes: 3. Type/Amount of Waste Received: A. Field Observation: DO 144083 F-l CONFIDENTIAL