Document YjZVBjY4Nby4vZ1NG3vyqx0R8

AR226-2534 UNITED STATES EMVIBOH-IBOTAL PROTECTION AGENCY REVISED DRAFT PERMIT FOR CORRECTIVE ACTION UNDER THE HAZARDOUS AND SOLID WftSTE AMBCMENIS OF 1984 Permittee s Permit autilber; E. I. du font de :feTnours & Company WVD 04 587 5291 Facility; E. I du Pont de Nemours & Ccirpany Parkersburg, West Virginia This permit is issued by the United States Environmental Protection Agency (EPA) under authority of the Solid Haste Disposal Act, eonnonly referred to as the Resource Conservation and Recovery Act of 1976, (RCRA) as amended by the Hazardous and Solid Waste Amendments of 1984 (HSWA) 42 U.S.C. S6901 et, jsq. and BPA regulations, to B. I. du Pent de ttomours & Company (hereaf^r called the Benaitfee), to operate a hazardous waste management facility located on Du&ont Road in Parkersburg, West Virginia, at latitude 39- 16' 12" North and longitude 81" 40' 09" West. III The Permittee rnust comply with all terns and conditions of this penait. This peBtnib consists of the conditions contained herein (Parts I, 11, and attachm&nts), and the applicable regulations contained in 40 CFR Parts 124, 260 through 264, 268, and 270 as specified in the pecnit. Applicable provisions include those which are in effect on the date of issuance of this permit (gee 40 CFR S270.32(c. This permit is based on the assunption that the information prwided.by the asnnittee is accurate. Further, this permit is based in part on the provisions of Sections 206, 212, and 224 o( BSW& which amend Sections 3004 and 3005 of WSA. In particular, Section 206 requires corrective action for all releases of hazardous waste or hazardous constituents from, any solid waste iaanagenant unit at a treatment, storage, or disposal facility seeking a permit, regardless of the time at which waste was placed in such unit. Section 212 provides authority to review and amend the pannit at any tins. Any inaccuracies found in the submitted information may be grounds for tha termination, modifcation or the revocation and reissuanoe of this penult (see 40 CTR 270.41, 270.42, 53 Federal Begi.ster 37912, 37936-37942 (Septeniber~28, 1988), and S270.43) and enforcement action* The Pennittee must inform EPA of any deviation from or changes in the autaaittad information which would affect the Bennittee's ability to ceniply witli the applicable statutes, regulations, or permit conditions* _____i this permit is effective as of and shall remain in effect until , unless revoked ahcTreissued, tentinated or modified in accordance with 40 OPR 270.41, 270.42, 53 Federal Baqisteg 37912, 37936 - 37942 (Septenter 28, 1988), or 270.43, or continued in accordance with 40 0?R S270.51(a). CF020276 EID182693 pwn- sTftNDftBD CONDITIONS A. EFFECT OP PEBMIT 'nils peradfe authorizes only the management of hazardous waste exposssly described in this permit and does not authorize any other management of hazardous waste. The full BCTA permit is comprisad of EPA's portion, which addresses the provisions of the Hazardous and Solid Waste Amendments of 1884, and the ifest Virginia Department of Natural ftssources' portion, which addresses the provisions of RCRA, for which the State of teat Virginia is authorized. Tha State of West Virginia is authorized to administer and enforce its program corresponding to any Federal self-inplenenting statutory provisions that were in effect on October 29, 1984, and the Federal regulatory program promulgated up to October 29, 1984, as wall as the technical < aronctenb issued on November 21, 1984 (49 PR 46094), and the amended interim status standards for landfills issued on April 23, 1985 (50 PR it 16044-48). This portion of the permit, which addresses the Hazardous and Solid Waste Amendmsnts of 1984, will be enfocoed by EPA. Issuance of this permit does not eonvey property rights of any sort or any exclusive privilege; nor does authorize any injury to persons or property, or invasion of other private rights, or any infringement of State or local laws or regulations (40 CFR S$270.30(g) and 270.4(b) and (c)). Qaqpllance with the tanas of this permit goes not constitute a defense to any action brought undee Section 7003 of TOSA (42 (SC S6973), Section 106(a) of the Coraprehensivie Ehvtroranental Response, Condensation, and Liability Act of 1980, as amended, (42 UBC S9606(a)) (QOOTaonly known as CEKCIA), or any other law governing protection of public health or the environment. Nothing contained herein shall in any way be deemed to waive the BBtinittee's obligation to eonply with 40 CER Fart 270, Subpart C, and applicable regulations set forth at 40 OFR Part 124. B. PEWIT ACTIONS this peeait may b modified, revoked and reissued, or terminated for cause as specified in 40 CFR SS270.41, 270.42, 53 Federal aagiatag 37912, 37936 37942 (SepteBteeir 28 1988), and 270.43. 'ttie "filing oBa request for a pesnitt modification^ revocation and reissuanoe, oe termination or the notification of planned eliangas <x anticipated nanocnplianee on the part of the Bttanittfl9 doas n&t stay the applicability or enforeeability of any e^nrit condition (40 CFR S270.30(t)). teview of any application for a permit renewal ahall consider inprovewnts in the state of control and BBaaurennt technology, as well as changes in applicable regulations and laws* C. PEBMIT COHDITIONS Pursuant too Section 3005(c)(3) of 3A, this pennit contains those was and oonditions debemiined neoessary to protect human health and the envirorengnt (40 CFR S270.32(b)'(2)). CF020277 EID182694 D. SBVEKftBlLlTY The provisions of this permit are severable, and if any provision of tthls permit or the application of any provision of this permit to any circum stance ia held invalid, the application of such provision to other circum stances and the remainder of this permit shall not be affected thereby (40 CE-R Sl24.l6(a)(2)). E. DEFINITIONS For the purpose of this permit? terms used herein shall have the same meaning as those set forth in Title 40 of the Code of Federal Regulations (40 CFR Pacts 260 through 264, 268 and 270), unless this permit specif ically states otherwise. Sftiere teens are not otherwise defined? the meaning associated with such terms shall be as defined by a standard dictionary reference or the generally accepted scientific or industrial meaning of the terms. The following definitions also apply to this permit* 1. Regional Administrator - Regional Administrator of the United States Environmental Protection Agency for the (lid-Atlantic Segion (Region III), his designee or authorized representative. 2. Director Director of the West Virginia Department of Natural itesQurces, Division of Waste Management, his/her designee or authorized representative. 3. Release - any spilling, leaking, panping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dunping, or disposing into the environment. 4. Solid Waste Management Unit any discernible unit at a facility , seeking a BCBA permit foam which hazardous waste or hazardous consti tuents might migrate, irrespective of whether the unit was intended for the management of solid and/or hazardous waste. I.I. 5. Facility - all contiguous prcperty under the control of the owner or operator at which the units subject to permitting are located (except for permit eondition where tha definition of "Eaciiity" in 40 CFR S260.10 shall apply). F. REPOSIS, mrsFiciatws AND SUBMISSIONS TO 'THE RBGIOMAL WMISIWSM. Ml reports, notifications or other submissions which are required by this pendt to be sent or given to the Regional Administrator or EPA should be sent Certified Mail or given toi BCBA Programs Branch (3BW50) III EPA Region 841 Cheatnut Building Philadelphia, Pennsylvania 19107 CF020278 EID182695 G. SIOBCTORX REQUlBBnS AH reports or other information sutanitted to the Regional Administrator or Director shall be signed and certified as required by 40 CBR SS270.11(b) and 270.30(10. H. DOCUMENTS TO BE MAIWnmffiD AT THE FACILITX SITE The Permittee shall maintain at the facility all doeuronts required fcy this permit and anendments, revisions and modifications to these documents. The Psontttee shall maintain at the facility a written operatic record that complies with all the rsquirsnwts of 40 CTH 264.73. I. DUTIES AND REQOIBfiHEMlB 11 l^ty to Cenply. The Permittee shall comply with all conditions of this peanit, except to the extent and for the duration such nonecnplianc^ is authorized by an emergency permit. Any other permit noncenpUanee constitutes a violation of fCSA and is grounds for enforcement action, permit termination, tsvocation and raissuance, or modification, oc for denial of a permit renewal application. (40 CEK S27Q.30(a)) 2' Qjty to Beagply. If the Peaaittee wishes to continue an activity regulated by this peanit after the expiration date of this peanit, the Permittee miist sutnilt a complete application for a new permit afc least 180 days before this permit @3^ires. (40 CES SS270.10(h) and 270.30(b)) 3. Pecmit^ EjtpiratiQn'and Oohtinuateion. Pursuant to 40 CFR 270.50, thia peHttit shall be effective for^i fixed tenn not to exceed ten years. Pursuant to 40 CFR S270.51, this permit and all conditions herein will remain in effect beyond tha peasdt's expiration date if the BBrroiftta has submitted a timely and ec(Bplete application (see 40 OFR 5270.10 and SS270.14 - 270.29) and through no fault of the Permittee, the Regional Aetministrator or Director has not issued a new permit under 40 CFR S124.15. 4* Need to Salt or geduceActivity tet a tefense. it shall not be a defense for the Penalttee in an enforcement action (Aat it would have been neoeasary to halt or redues the penreitted activity in order to maintain eaBpllance with the eondltiona of this permit* (40 CER S270.30(e 5. Pufey'fco Mitigate. In the event oC notieomelianoe with this permit, ldie Penttifefeee shall 'take all reasonable steps' to minimize releases to the etwinMBBent, and shall carry cut such measures as are reasonable to prevent significant adverse impacts on human health or the environBBnt. (40 CE-R $270.30(d)) 6. Proper Operation and'rtaintenance. The Permittee shall at all tinies pi-operiy operate ana maintain an facilities and systems of treatment, aonltoring, and control (and related appurtenances) which are installed CF020279 EID182696 or used by the Permittee to achieve compliance with the conditions of this permifc, Proper operation and maintenance includes effective performance, adequate funding, adequate operator staffing and training, and adequate laboratory and process controls, including appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems when necesary to maintain ocropliance with the conditions of the permit. (40 CPR 270.30(e)> 7. Duty to Provide Information. the Permittee shall furnish, within the specified tune, any relevant information which the Regional Adminis trator or Director may request to determine whether cause exists (or laodirying, revoking and reissuing, or tenainating this permit, or to determine canpUance with this permit. The Permittee shall also furnish to the Segional Administrator or Director, upon request, copies of records required to be kept by this permit. (40 GPR SS270.30(h) and 264.74(a)) i 8. Inspection' arid' Enfeey. Pursuant to 40 QPR S270.30(i), the Permittee shall allow the Regional Administrator or Director, or an authorized representative, upon th presentation o( credentials and other documents as may be required by law, tot a. Enter at reasonable tines upon the Penaittee's premises where a regulated facility or activity Is located or conducted, QE where , records must be kept under the conditions of this permit; b. Have access to and copy, at reasonable tines, any records that must be kept under the conditions or this permit c. inspect at reasonable times any facilities, equipBent (including monitoring and control equipment), practices, car operations regulated or required under this penult; and d. Sample or ncnitor, at reasonable tiroes, for the purpose of assuring permit compliance or as otherwise authorized by BCBA, ary substances or parameters at any location. 9. telitoginia'ana'teoopas. Pursuant to 40 CE-R S270.30(j), the Pgionittee shall comply with the following requlrementa. tw| a. Samples and measurwents taken for the purpose of monitoring shall be representative of the monitored activity. All saspling and analysis shall he o adequate quality, scientifically valid, of known pEecialen and accuracy, and of acceptable eampletenesa, EepEessnfcativeneas and eoi^arability. Laboratory analysis of samples Bust be perfoCTied using an appropriate method for testing th parameter (s) of interest taking into account the sanples' matrix. Use of the test methods found In the Agency publication, Methods for Evaluating golid fetsfe, gnvsieal^gianieal ftetnoga, riiii=ff4^7"ahair 'be' usedTSc's the ESteBtieily test ad ten analytical methods used to determine the EP toxieity test analytea (40 CFR CF020280 EID1826&7 S261.24); the Free Liquids Tast (Method 909S) used to determine if free liquid is a caqponent of a waste 93 a specif Ie requirement for bulk and eontainerized wastes (40 CFR 264.213 and $265.2l3(d)); and the chemical analysis of wastes for hazardous wast indiwration permits (40 CFR S270.62(b)(2)(i)(C)). b. The Pennifcttee shall retain records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, copies of all reports and records required by this permit, the certification required by S264.73(b)(9) of this chapter, and records of all data used to caiplete the application (or this pemife tor a period of at least three (3) years froa the date o( the sample, measurement, report, certification or application. These periods nay be extended by request of the tegional Adminis trator or Director ate any tune and axe automatically extended during ' the course of any unresolved enfioroanent action regarding this facility. The Permittee shall maintain records from all ground-water monitoring wells and associated ground-water surfaee elevations, for the active life of the facility, and foe disposal facilities for the pciat-closura eare period as wail. c. Records of ifonitoring information shall specify: (1) The date, exact place, and tina of sampling or measurements; (2) The individual (a) Mho perfonaed the saffpling or measuFerenta? (3) The date(s) analyses were performed; (4) The individual(s) who perfoiad the analyses; (5) Ihe analytical techniques or methods used; and (6) Ihe results of such analyses* 10. Heporting Planned Changea and Anticipated ttoGgggaplianoe. The Pannittee shall give notice to the Regional Administrator and Director, at least 30 days prior to any plannad physical alterations or additions to the pennittoad facility* The Permittaa shall give the Regional Adminis trator and Director at least 45 days advance notice of any planned changes in tee pecmitfeed facility or activity which nay result in nonccopliance with permit irequirensnts,, (40 CFR SS270.30<1) (1) and (2)) 11. Transfer of Penait. In aeoocdanoB with 40 CfSL S270.30(l)(3), this permit is not transferable to any person* except after notice to the tegional Mminiatrator and Director. The Regional Administrator or Qicector may requirs modification or revocation and re issuance of the peonit to identify the new Bannifeteo and inoorporata such other require[nta as may bd necessary under KCRA (40 CFR $270.40). CF020281 EID182698 At least 30 days prior to transferring ownership or operation of the facility during its operating life, the Permittee shall notify the new owner or operator in writing of the requirements of 40 CFR Parts 264 and 270, and at the same time shall send a copy o sudh notice to the Regional Atednistrator and Director. I2* Twenty-four Hour Sepoctinq. Pursuant bo 40 CFR 270.30(1X6)? the Pecmttee shall report to the the Regional Administrator and Director any nonconplianee which may endanger health or the eiwironnent. Information shall be provided orally as soon as possible, but no later than twenty-four (24) hours from the time the Permittee becores aware of the circumstances. This report shall include the following? a. Information concerning release of any hazardous wast or hazardous constituent that nay cause an endangennent to public drinking water supplies. b. Any information of a release or discharge of hazardous waste, ' hazardous constituent or of a (Ire or explosion from the facility, which could threaten the environment oc human health outside the facility. The description of the occurrence and its cause ahall includes (1) Name, address, and telephone nunber of the owner or operator? (2) Nane, address, and telephone number of the facility? (3) Date, tire, and type o incident; (4) Name and quantity at material (a) involved? (5) The extent of injuries, if any; (6) An assessment of actual or potential hazards to the environment and hunan health outside the facility, where tehts ts applicable; and (7) Estiaated. quantity and disposition of recovered material that resulted ercm the incident. c. A written autanlasion ahall also be provided to the Regional Admin istrator and Director within five (5) days of the tine the Permittee becomes awajre of the ciccumstancaa. The written submission shall contain a description of the nonGaRpUanca and its cause; the period of nonconipliance including exact dates and times, and If the nonoonpliance has not been corrected, the anticipated time it is expected to continue? and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the nonconEllianoft, The Permittee need not ocniply with the five (5) day written notice requirement if the Regional Atoinlstratoc and Director waive that requirement and th Penaittfie sutanits a written report within fifteen (15) days of the tiro the Permittee becones aware of the circumstances.. CB-020282 BID182699 13. iroiediate Reporting of Releases* In accordance with the requirements of 40 CFR 264.56(d)(l) and (2), if the facility's sswscgency coor dinator determines that the facility has had a release, fire, or eiqplosion which could threaten hunan health, or the environment, outside the facility, he must report his findings as follows; If a. his assessment indicates that evacuation of local areas may be advisable, he must immediately notify appropriate local authorities. He must be available to help appropriate officials decide whether local areas should be evacuated? and b. He must iinnediately notify either the government official desig nated as the orii-scene coordinator for that geographical area, (in the applicable regional contingency plan under 40 CFR Part 1510) or the National Response Center (800/424-8802). The report must contain the infoaaation required under 40 CPR S264.56(d)(2)(i) through (vi). 14. Other Noncaicliance. Tha Permittee shall report all other instances of noncaqpliance not otherwise required to be reported above, at the time monitoring reports are submitted. The reports shall contain the Information listed in pemit condition 1.1.12. (40 CFR $270.30(1} (10)) i 15. Other Infognation* Whenever the Pemitfeee becomes aware that it (ailed to w6nit~any relevant facts in the permit application, or submitted incorrect infoemation in a permit application oc in any report to the Regional aaroinistrator or Director, the Petmittee shall notify the Regional administrator <se Director of such failure within 7 days. The Pemittee shall submit the cocipect or additional information to the Regional Administrator or Director no later than 14 days of becoming aware of the deficiency. (40 CFR S270.30(l)(ll)) 16. CcBpliance Schedule. Reports o compliance or noncoopliance with, or any progress reports on, interim and final requirements contained in any compliance schedule of this permit shall be subsaitted no later than fourteen (14) daya following each schedule date. (40 CFR 270.30(l)(5)) 17. Biennial Report, pia-suant to 40 CCTI S270.30(l)(9), a report must be submitted to the Regional Administrator or Director, as appropriate, covering facility activities by March 1 of odd numbered calendar years. The report shall contain the information required in 40 CfR 264.75. 18. Exand Disposal Restriction. All activities of the Permittee which involve the land disposal of hazardous waste are subject to the Land Disposal Bestriction (HCBA Sections 3004 (b)--(ra)). CF020283 EID182700 PART II SPECIFIC CONDITIONS A. CORRECTIVE ACTION POR CONTINUING RELEASES Section 3004(u) of BORA, (Section 206 of HSWA) and regulations promul gated as 40 CFR S264.101r require corrective action as necessary to protect human health and the environment for all releases of hazardous waste or hazardous constituents crom any solid waste management unit, regardless of when wastes were placed in the unit, (or all permits issued after ttovember 8, 1984. This permit inquires the PBrmitte to conduct a Verification Investi gation (VI) and, if necessary, a RCRA Facility Investigation (RFI) for sus pected releases from specific solid waste managem8nt units (SW<Ute) at the facility, and a Corrective Measure Study. The Itennitfcee may, at any stage of the investigation, peopose corroetivs measures Cor the reinediation of releases of hazardous waste or hazardous constituents, '[he Permittee Bust show to BPA's satisfaction that the subsurface conditions and contaminant plume have been adequately characterized and the proposed corrective measures will adequately remove, contain, or treat the released hazardous waste or hazardous constituents. Initiation or pursuit of such a demonstration by the Itetiaittae shall not postpone or stay the requirements of this pennit. Approval of such a demonstration by BPA shall allow the B?tinittee to dispense with certain stages of the investigation, as identified in BPA's approval of the denonafer-ation. The permit shall be modified according to permit condition II. F. prior to inplementation of corrective measures. If This pennit requires the Pennittes to oonduet a VI for six solid waste management units (SWMte)t DuPant (toad Landfill (unit A-l), Kiver Bank Landfill (unit A-3), Anaerobic Digestion Etonds (Unit B-4), Etolyaeetal Products Incinerator (unit C-6). Injection Hells (unit F-ll), and Burning Ground (unit H-13). The VI plan must be capable of enabling DuBont to determine if a release of hazardous waste or hazardous constituents has occurred or is likely to occur from these units. The VI plan must also provide sufficient information Cor EPA to determina a RCBA Facility investigation (HPI) is warranted. Xn addition, this pennit provides for additional investigation and the selection of corrective action measures, should they b Eequiisad, Failuw to submit the required information or falsification of any submitted infosaation is grounds for termination of this permit (40 CFR 270.43). All inftaMation submitted must be certified as required by 40 CTR S2?0*ll(d). If BPA finda that further studies and/or corrective action measures are warranted beyond what is specified herein, EPA will propose a major permit modification and follow appropriate procedures required under BCRA which include a public coeaent period and a public hearing, if requested* -9- CF020284 EID182701 B* VERIFICATION INVESTIGATION (VI) 1. Within 45 calendar days of the effective date of this permit, the Permittee shall submit to SPA and the (test Virginia Department of Natural Resources (WVCNR) a VI Work Plan. the VI work Plan shall include the following information; a. TEhe VI Mbrk Plan shall be designed to accomplish the following objectives* (1) Investigate the release of hazardous waste or hazardous constituents from all SWMUs. The Investigation shall include units A-l, A-3y B-4, C-6, F-ll, H-13 (Burning Grounds) and any other Stlu known or suspected by the Permittee to be releasing hazardous waste or hazardous constituents. SKMU identifications are those used in the Bemltfcee's June 5, 1985 CTW information submifetal. (2) Characterize ths eotbustion products released during burning of polyaeetal products in unit C-6. (3) Determine the need Cor further investigation and/or urpleiasntatien of interim measures at the facility. b. VI Saapltng Plan (1) The Permittee shall submit a VI Sampling Plan that includes, as a minimum^ the following sampling and analysis work; (a) For Units A-l (DuBont toad Landfill) and A-3 (River Bank Landfill)s (i) Soil and ground-water samples are to be obtained t?on areas downgradient of or through the units where contamination is most likely to be detected. Upgradienb or background gaecples should also be obtained. (ii) All surface seepage/leachata flows shall be analyzed. If surface seepage/leachate cannot be detected, subsurface leachatee ahall be collected fron several locations within each landfill. (iii) Existing monitoring wells shall be evaluated to determine their capability to adequately represent releases faofa the landfills. A smniaacy oC available Bonitoring data shall be presented. (b) For ttoit B-4 (Anaarobic Digestion Bonds); (i) Soil and ground-water samples are to be obtained frcia areas downgradient of the unit where contam ination is most likely to be detected, itigradient or background aanplea should also be obtained. 10 - CE'020285 BXD182702 Bie sampling analysis should be coordinated/incorp- orated with the analysis of Unit A-3 (River Bank Landfill.), dug to the close proximity of the unit. (c) For Unit C-6 (Etolyacetal Product Incinerator); Characterize the air emissions celeased from the inciner ator process to identify any hazardous constituents. (d) For Onit P-ll (Injection (fells)i (i) A description shall be provided of the nature o the problems encountered with injection well #1 and the ceworking that was performed. (il) Existing monitoring wells shall be evaluated to deteCTilne their capability to adequately represent releases from the injection veils. A sunnary o available monitoring data shall be presented, (e) For Unit H-13 (Burning Grounds)! Ground-water samples are to be obtained Eran the perimeter of the building constructed over the Eonaer Burning Grounds from areas roost likely to detect contamination* (2) Sie VI Sampling Plan shall provide foe the analyses identified in Attachment 1 and any other hazardous constituent that is known or suspected to have been released from ?6 unit. (3) The VI Sampling Plan shall include the following information. (a) Background - The Permittee shall identify current and historical site information which might have a bearing on the prcfiosed sampling and data collection effort. (b) Map@ - The Bgnnifetee shall include all pertinent locations on maps and shall locate all sanpling points. (c) Rationale for sample locations and number of sanples. The Pasnittee shall! (1) Identify the specific sanpling points for each SMMU foe each potentially affected envrioranental media. (ii) Identify the population at possible sampling loca tions and explain now these were narrowed, down to specific sampling points, (d) unit-specific downgradient ground-water sampling points must be identified for each SIMJ. Ihese may be existing monitoring wells, new ncnitoring wells installed -11- CF020286 EID182703 specifically downgradient to the unit, or a method appropriate for one-time sanpling of the groundwater. Tha Permittee nay elect to replace the groundwatec investigation with a soil gag investigation if the hazardous constituents of concern can be readily detected by soil gas analysis techniques. (@) Soil sanpling points - Soil sanples shall be obtained from che path of the seepage/leaehate flow and from any other area likely to show contamination trom releases. c. Quality assurance/Quality Control The Bsnnittee shall submit a Quality Assurance Plan, Sample Collection Methods and Procedures Plan, to describe the sampling and the analytical protocols which will be used. They should be based on the ERA guidance listed in Attachment 2. i d. Ocmnmity Relations Plan Prepare a fact sheet describing the scope and objectives of the field activities. This fact sheet shall be mailed to all persons on the facility mailing list to be supplied by ERA and to the appropriate units of State and local govemnants at least ten business days prior to caanencenient of the field activities. i e. Safety Plan The Etennittee shall prepare a safety plan for each sampling activity. The Benaittee shall consult appropriate guidance such as Standard Operating Safety Guides, USEPA, July 1988 (SOSG) and 061% regulations at 29 CFR 1910 that explains how to develop a peeper ait safety plan. While EBA may comment on the safety plan, ERA will not approve or disapprove the plan. 2. Verification Investigation <VI) Iteport a* The Report is to contain all data organized in a logical sequence and include sunmaries of all findings, problems encountered during the investigation, actions taken to oonrect toe problen, and copies of daily reports. Inspections reports, laboratory/ monitoring data, etc. the report shall contain eonclusicna and reoonmendations. "Bie selected oecanmendaticns ghall be adequately justified. Possible reccninendations include but are not limited tot (1) No further action required, -12- QV0202B-) EID182'704 (2) Continue monitoring where analytical results .indicate that a threat may exist in the future? (3) Conduct a RPl to characterize the rate and extent of releases? and (4) Plan and inrlenent interim measures at the facility. See permit condition II.C. b. The criteria to be used to determine the need foe further action shall be described. 3. Within 1.80 calendar days of EPA's approval of the VI tork Plan, tha Permittee shall execute the Plan and submit the VI Report toe EPA's approval. The Permittee shall also submit the VI Report to WVCMR. 4. Within 45 calendar days of the effective date of this permit/ the Permittee shall submit to EPA and WVENR the following available inforaiation for existing ground-watsr monitoring wells; a. A description, nap, and sampling schedule of all existing well locations, including a survey of each well's surface reference point and the elevation of the casing top; b. Size and depth of wlla; , c. Description of well intake design, including screen slot size and length, filter pack materials and method of filter-pack emplacement? d. Type of well casing and screen materials. @, Methods used to seal the well from the surface and prevent downward migration of contaminants through the well annulus? t. Description of the tnethods OE procedures used to develop the w@!U? and g. (^ound-watesr elevation in aach well. C. IMTCTOM (ffiASuB^ 1. If, at aw tlal8 during the term of this permit, the Permittee discovers that releases o hazardous waste or hazardous constituents are affecting or will affeet target populations or sensitive envlronnents the Pemittee shall i -13- CF020288 EID182705 a. Submit the following information concerning the release; (1) Souree(s), amount(s) and location(s); (2) Ihe concentration (s) of hazardous waste or hazardous constituents and, if known, the background level o each hazardous waste or hazardous constituent; (3) The known or expected pathway through which the contamination is migrating or (nay migrate? and the extent, rate, and direction o contamination; and estimated quantities and/or volumes released; and (4) The projected fate and transport, to the extent known. b. Without doing either a risk assessment or an endangeonent assessment, identify the followings (1) the current and potential exposure pathway(s) (e.g., air, fire/explosion, groundwater, surface water, contact, ingestion)s (2) the location and demographics of populations potentially at risk Iron exposure! (3) the potential effects of human exposure (short-and long- tenn effects)? (4) tins nature of past and potential human exposure. c. Identify potential environmental exposure and threats ass (1) the media that have been and may be contaminated (e.g., grounctwater, air, surface water); (2) the likely short-term and long-teaa threats and effects on the environment. d. An outline of proposed Interim measures to tenporarily or peiaianantly arrest the release and which would expected ^o b9 a necessary eonponent of the final, remedy. 2. TtWh determines that a high priority release frgm a SWU posing a threat to human health or the environment has occurred or is feaninent, the Penaittes nay be required to implement interim measures. Such a requirement may result in a permit modification. -14- CF020289 EID182706 D. BCRA FACILITX IllVfiSTIQATION (BFI) II 1. Within 90 calendar days of receipt of SPA'S approval of a Verifi cation Investigation Report reconroending a RCRA Facility Investi gation (KPI), the Permittee shall submit to EPA and MVCMR, for EPA approval, a KFI Work Plan for the identified solid waste nanagenent units. The Permittee may perform the RET in stages i the Permittee requests permission to do so and demonstrates to EPA's satisfaction that conducting the RPI in stages will expedite the process or otherwise augment protection of human health and the environment. The plan nust be approved by EPA in accordance with condition .E. of this pemit. This plan shall meet the objectives and requirements specified in II.D.2 below. 3. The specifications foe any ?1 Plan required by this permit are the followings a. The RFI objectives; (1) Olaracterize the nature, extent, and rate of migration of releases from the SNMU(s) into ground water, soil or any other media identified? (2) Detemine the criteria for and scope of sorrective measures; and (3) Provide a detailed geologic and hydssgeologio character ization of the area surrounding and underlying the Smu(s). b. RFI Work Plan provisionss (1) The afl Work Plan shall identify the corrective measure (s) expected to be appropriate* (2) me RFI Work Plan shall include provisions for obtaining the following; (a) local geologic characteristics for the area surrounding the unit which adequately describe the local subsurface geologic conditions including stratigraphy (soil and uneonsolidated sediment cover, bedrock, structural features, and formation's origins) and surficial Geology (undifferentiated alluvial deposits)? (b) A description of the regional hydrog@ol.oglc characteristics in the vicinity, including s - regional hydrogeologie clow patterns; and - areas of recharge and discharge; (c) At analysis of any topographic or geonorphie feature that might influence the ground-wtber flow system? 15 Cf020290 EID182707 (d) Classification and description of the hydrogeologic properties of all the hydrogeologic units found at the facility (i.e., the aquifers and any intervening saturated and unsaturated units), including? - hydraulic conductivity^ porosity? - textur, uniformity, lithology? and - an interpretation of hydraulic interconnections between saturated zones; (e) Using a topographic map as a base, and at least two perpendicular geologic cross sections foe the unit and the surrounding area to describe the extent (depth, thickness, lateral extent) of all hydrogeologic units, an identification of; - sand and gravel deposits in unconsolidated deposits; - zones of significant fracturing or channeling in consolidated deposits; i - zones of higher or lower permeability that might direct or restrict the flow of contaminants? - perched aquifers; and the uppennost aquifer and aquifers hydraulically interconnected beneath the unit; (f) A description of water level or fluid pressure monitoring includings , - water level contour maps and vertical gradient sections; - water level contour map uaing data from all ground-water monitoring wells at the facility} - well or piezometer hydrographs - an interpretation of the flow system, including the vertical and horizontal oonponents of flow; and - an interpretation of any change in hydraulic gradients ; (g) A description of manmacte influences that may affect the hydrogeology of the site, identifying? - local water supply and production w$Ua with an approximate schedule of punping; and - manmade hydraulic stmctureg (e.g., pipelines, french drains, ditches)? (h) A gimaary of all surface water hydrology (water quality data, classification, eanmercial and/or recreational use); and (1) A Bbalth Asseaaaent containing the following s - identification of the potential health effects (toxic, carcinogenic, isutagenic, or teratcgenic effects) of known contaminants fron the solid waste management unit; and - identification of any potential environmental effects of known contaminant (s) front the solid waste management unit. 16 CB'020291 SID182708 (3) the RFI Work Plan shall also include a Sanpling and Analysis Plan for each unit(s) to meet the requirements o this permit (see peenib conditions II,D.3, Il.D.4, and II. D. 5.). BPA and DNR reserve the right to require that split or duplicate sanples be taken. Where such split or duplicate samples are taken and analyzed, EPA and WVENR will provide the results to the Permittee Eoc evaluation in the RFI. (4) the ?1 Work Plan shall identify the criteria to be used to determine if further action is necessary to protect human health and the environment. Options include but are not necessarily limited to; (a) Continued monitoring; ... ,.(b).,. Corrective Measures. Study? or ,,. (e) No further action required. (5) When developing BFI Plans and Reports the Peanlttee shall consider the BCRA guidance documents in affect at the tiro the plans and reports are peepaced and shall consult with EPA to determine the appropriate sections of the guidance to be used. (6) When releases from more than one SWU may overlap, the individual SiWte nay be ccBtoined into a study area. Ihe RFI investigation then may be conducted for the study area provided that the scope of the investigation is adequate to evaluate the extent of contamination of all hazardous waste and hazardous constituents identified in the verification sanpling for all SKMUs in the group. 3. Ground-Water Monitoring Bequiranents - the Pemiittse shall submit a monitoring plan consisting o( the following* a. A ground-watar monitoring well network which shall inset the following requirements: (1) The downgradient wells nust be capable of iianediately . detecting any statistically significant amounts of hazardous waste or hazardous constituents that might migrate team each solid waste management unit into the ground water; (2) 'Bie monitoring system must be designed to operate foe a period ot 30 years? (3) Downgradient wells must monitor both the perched water zone and the water table aquifer due to the probable hydraulic connection between the zones; and 17 CF0202&2 EID182709 (4) The plan shall provide a description of the monitoring . wells. When developing this information, the Permittee shall refer to the Technical Enforcement Guidance Cocument (EPA), September 19867~to determine methods and materials that are acceptable to BPA. The information provided shall includes (a) Description and nap of well locations, a proposal Eor a survey of each well's surface reference point and the elevation of the top of its casing,' (b) Size and estimated depth of each well; (c) Description of well intake design, including screen- slot size and length, filter pack materials, and method of filter pack einplacerasnt; (d) . Type of well casing and screen materials. The selection of well materials shall be made in light of the parameters to be monitored and the nature of the leachate that could potentially migrate from the unit. The well materials selected shall minimize the potential of absorption and desorption of constituents froni/lnto the samples; and shall maintain their integrity for the expected life of the system; (e) Description of, methods used to seal the well from the surface and prevent downward migration of contaminants through the wall annulus? and () Description of the methods and procedures used to develop the well. b. The ?ennittee shall select a Sampling Program and conduct sanpling and analysis activities capable of yielding repre sentative samples of ground water. The Sampling Program shall include a list of parameters capable of detecting leakage o hazardous waste or hazardous constituents Into ground water. Tha paraneters shall be representative of hazardous constituents at least as mobile as the most mobile hazardous constituents that could reasonably be derived front th8 waste, and should be chosen after considering! (1) The types, quantities, and concentrations of hazardous constituents in waste managed at the SW1U and hazardous constituents which nay b@ released to the ground water from process areas located uimediately adjacent to SHHUs; 18 CF020293 EID182710 (2)- The mobility, stability, and persistence oC hazardouss constituents or their react ion products in the unsaturated zone beneath the waste management area; (3) the concentration of and the natural variation, Hnown or suspected, of the proposed TOnitoring parametecs in background media; and The List must include the basis Cor selecting each proposed Indicator parameter, including any-analysis oc calculations performed. The basis Eoc selection shall, where possible, include chemical analysis of the unit's waste and/or leachate as appropriate. The list shall also include pacameters to characterize the specific chemistry of ground water at the site including, but not limited to, the major anions and cations that make up the bulk of dissolved solids in water (i.e., chloride, iron, manganese, sodium, sulfate, calcium, magnesium, potassium, nitrate, phosphate, silicate and amnonia). c. The Permittee shall submit a Sampling and Analysis Plan which includes the following (1) Field Sarapling Procedures including the following; (a) tfell evacuation procedures including volume to be evacuated prior to sampling and handling procedures for purged well water; (b) Sample withdrawal techniques (Sampling equipment and materials (tubing, rope, puips, etc.) shall be selected to yield representative sanples in light of paranieters being monitored. The sampling protocol will include field measurement of pH and temperature for each sample); (c) Sample handling and preservation techniques; (d) Procedures for decontaminating gampling equipment between sacpling events including disposal ot deoontaminaticn wastes; (e) Olain of custody procedures to be used for all phases of sample management? () Conditions under which san^ling should/should not occur, e.g, weather; and 19 CF020294 BID182711 . (g) Docuronfcation to include sampling data and time, location and description of site, sampling location and depth, sanpling conditions, weather conditions ambient and sample temperature, sample appearance, decontamination procedures, sample preservation procedure, equipment calibration, etc. (2) Standard Operating Procedures include the following: (a) Procedures for replicate sanpling and trip blanks; and (b) Chain of custody Eonas, shipment, security, tc. (3) Quality Assurance Plan, Sample Collection Methods and Procedures Plan, to describe the sampling and the analytical protocols which will be used (based on the BPA guidance listed in Attachment 2) f (4) Procedures for performing a comparison of upgradient and downgradient ground water to determine whether contamination has occurred. The procedures should includet (a) A proposed method (statistical or otherwise) to ccropare upgradient and downgradient well water that provides a reasonable balance between the probability of falsely identifying and failing to identify contamination; (b) Background to be determined at each sampling event consistent with applicable requirements contained in the West Virginia Hazardous Waste Management Regulations; and (c) A proposed method of data organization and presentst ion. d The Permittee shall submit a time schedule in accordance with which the Permittee shall install the ground-water monitoring well network, take the first round of samples, and gutnut a report. 4. Soil Sampling BBquirment3 - Any soil sailing plan shall include a description of the procedures the Pennittee proposes to use to gather data sufficient to characterize the vertical and herisontal nature, rate of movement, and extent at releases of hazardous waste or hazardous constituents into the soil. At a ininiroro this description shall include the following! 20 CB'020295 EID182712 a. The proposed number and locations of borings and/or other soil sampling techniques to obtain background soil quality, and a justification showing how the network will give representative indications of background soil characteristics; b. The proposed number and location of borings and/or other soil sampling techniques in relation to each SWtO, and a justifi cation showing how the proposed network will produce data which is adequate to give a reliable indication of soil characteristics; c. The proposed depth for each boring and/or other soil sampling technique and a justification for choosing the depth; d. The proposed procedures Cor conducting each boring and/or other soil sanpling techniques and a justification showing how die proposed procedures will provide a representative sanple of soil, based on available information on the geologic characteristics of the site and the parameters for which each saiiple is to be analyzed? e. The proposed sanpling frequency and a justification Eoe the frequency proposed? . The proposed sampling plan shall include, at a minimum, procedures for the following (1) sample collection? (2) sample collection frequency; (3) sample preservation and shipment (i.e., sample contain ers, sample preservation); (4) analytical procedures (i.e., analytical methods, labo ratory selection); (5) chain o custody; and (6) field and laboratory quality assurance/quality control protocols which shall confocm to EPA approved practices; g. Proposed laboratory analytical techniques and chain of cus~ tody procedures which shall conform to EPA approved methods; and h. Proposed procedures fior pcoviding split or duplicate samples to the EPA. 21 CF020296 EID182713 5 Surface water Sampling Requirements - Any surface water sampling plan shall include an evaluation o the surface water bodies in the vicinity of the facility that could potentially be affected by releases fron the SlWJs being investigated. At a minimum, the IteBttittee shall provide the following information; a. Description of the temporal and permanent surface water bodies including; (1) For lakes and estuaries; location, elevation, surface area, inflow, outflow, depth, temperature stratification, and volume; (2) For impoundments location, elevation, surface area, inflow, depth, volume, freeboard, construction, and purpose; (3) For streams, ditches, and channelsi location, eleva tion, flow, velocity, depth, width, seasonal fluctua tions, and flooding tendencies (i.e., 100-year stom event)? and (4) Drainage patterns. b. Description of the ehainistry of the background surface water and sediments* This includes but is'not limited to deter mining the pH, total dissolved solida, total suspended solids, biochemical oxygen demand, alkalinity, total organic halogen, conductivity, dissolved oxygen profiles, nutrients (calcium, magnesium, potassium, chloride, sulfate, anronia, nitrate, nitrite, phosphate), chemical oxygen demand, total organic carbon, specific contaminant concentrations, etee. c. Description of sediment characteristics including: (1) Deposition area; (2) Ihielutesa profile? and (3) Physical and chemical parameters (e.g., grain size, denatty, organic carbon content, ion exchange capacity, pB, etc*)* d. Characterization of the contamination in surface water bodiea and sediment that result fron contaminant releases. At a minima, the Permittee shall provide the following infOBBiationt (1) A description of the horizontal and vertical extent Qt any inniiscible or dissolved contamination by hazardous waste or hazardous constituents origin ating jEEcro the SfMUs, and the extent of contamination in underlying sediments? 22 cy0202&7 EID182714 (2) ' The horizontal and vertical direction of contaminant movement; (3) The contaminant velocity? (4) An evaluation of the physical, biological and chemical factors influencing contaminant movement? (5) An extrapolation of future contaminant movement? and (5) A description of the chemistry of the contaminated sur face waters and sediments. This includes detannining the pH, total dissolved solids, and specific contaminant concentrations, as identified in previous investigations. e. A description of the procedures the PeEinifctee proposes to use to gather data sufficient to characterize the vertical and horizontal nature, rate and extent of releases of hazar dous waste or hazardous constituents released fron SWUs into surface water bodies and associated sediments. At a minimum, this description shall include the following! (1) Ihe proposed number and location of surface water tran sacts and sediment sampling points, and a justification showing how the proposed networH will produce data which is adequate to determine surface water and sediment quality? (2) Bhe proposed depth of sediment sampling points and a justification for choosing the depth? (3) The proposed design for each surface water transect and a justification showing how the proposed design will provide a representative sample of surface water based on the hydraulic characteristics of the surface water body and the paramaters being analyzed; (4) The proposed sampling frequency and the length of the sampling period and a justification for them? (5) Proposed laboratory analytical techniques and chain of custody procedures which conform to EPA approved methods? (6) A description of the sampling procedures ineludlngs aa) sample collection; bb) saaple collection frequency? 23 CB-020298 BID182715 cc) sanple preservation and shipment (i.e., sample containets, sanple preservation); dd) analytical procedures (i.e., analytical methods, laboratory selection)? ee) chain of custody? and ) field and laboratory quality assuranca/qualiby control protocols which shall confocm with EPA approved practices. (7) Proposed procedures foe providing split sanples to the EPA and WVDNR; and (8) Proposed field screening techniques for volabiles (OVA and/or HNu) or metals (portable XRF). if 6. within 180 calendar days of receipt of BPA's approval of the RPI ifork Plan, the Permittee shall inplement the plan and submit a RFI Report to EPA for approval, the inplenientatton time taay extend beyond 180 days a staged RPI is approved by EPA, in which case, the RFI shall be inplemented in accordance with a schedule approved by EPA, If a Corrective Measures Study is reconmended, the permittee shall include in the RPI Report, a detailed study plan and a time schedule for completing the study. The Corrective Measure Study is intended to identify, screen and develop the altemative(3) for removal, containment, treatment and/or other remediation of the hazardous waste or hazardous constituent release (s) from a SWUis). 7. Corrective Measures Study Report - upon receipt of EPA's approval of a ?1 Report reconroBnding a Corrective Measures Study, the Pecmittee shall submit a Corrective Heasures Study Report to BPA and WVOBt according to the approved schedule. Upon EPA's II approval of the Corrective tteasureg Study teport, the penult shall be modified according to permit condition .F. for the selected corrective measure alternative, 24 CF02029S EID182716 B. SUBMISSIONS TO AJ3EMCY AMD DISPUTE aESOLUTIOH 1. The Permittee shall submit to the Regional Administrator at least three copies of any subroifetal required by ERA'S portion of this permit. All aubniittals shall be signed and certified pursuant to 40 CFR S270.30(k) and 270.11. 2. All plans, reports, schedules, and other submissions required by the terms of EPA's portion of this permit are, upon approval by the Regional Administrator, incorporated into this pecmit. Any noncompliance with such approved studies, schedules, plans, reports, or other submissions shall be deemed noncanpliance with this permit. In the event o unforeseen circumstances beyond the control o the Permittee which could not be overcome by due diligence, the Itermittee may request a change, subject to Regional Administrator approval, in the previously approved plans, reports, schedules or other submissions. This request may result in a modification of the permit. 3. In the event of EPA disapproval in whole or in part of any plan, schedule, report or other submission required by this permit, the Regional Administrator shall specify any deficiencies in writing. The Psnriittee shall modify the plan, schedule, report or other submission to correct the deficiencies within thirty (30) days from receipt of disapproval by the Regional Administrator, The modified plan, schedule, report or other submission shall be submitted to SPA in writing for review. Should the Permittee take exception to all or part of EPA's disapproval, the Permittee shall submit to the Regional Adninistrator a written statement of grounds for the exception within fifteen (15) days from receipt of EPA's disapproval. Itepresentatives of EKA and tha Pannittee may confer in person or by telephone In an attempt to resolve any disagreement. In the event that resolution is not reached within forty-five (45) days frcm receipt of disapproval by the Regional Administratoi:, the Etenifctee shall revise the plan, schedule, report or other submission as required by EPA and resulanit the revised plan, schedule, report o? other aubnission by the date required by EPA. The Permittee, upon submission o the revised plan, report, schedule or other submission shall state whether or not it agrees in whole or in part with the revised plan, schedule, report or other submission. In the event of any disagreement, the permit shall be modified in accordance with 40 OPR S270.41. F. PEBMIT MQDIFIOO'lOH The Regional administrator will Modify the permit in accordance with 40 CFR 270.41 and Section 3005{c) of BORA in the event that investigations required in this jsermit, or any other infor mation available to the Regional administrator, identify solid waste management units that require corrective measures. financial assurance by the Permittee is required if corrective measures are necessary (40 CFR S264.101(b). This paragraph does not limit the Regional Administrator's authority bo otherwise modify this permit in accordance with 40 CPR Part 270, Subpart D. 25 CF020300 EID182717 G. CERTIFICATION o HASTE MINXMIZATIOH The Permittee' shall maintain a certification at the facility containing the information required by 40 CFR S264.73(b)(9). H. RECOKDKEEPIMG AMD ReFOBTING The Permittee shall maintain a written operating record at bhg Eacility in accordance with 40 CFR Pact 264, Subpart E. I. CLOSURE AaO i-lOrriPlCMTOH REQUIREMENTS 1. Closure a. When the Permittee plans to replace or eliminate solid waste management units currently in use identified in Attachment I, the subject units shall be closed in a manner thats <1) Minimizes the need for further maintenance? and (2) Eliminates post-closure escape of hazardous waste or hazardous constituents* b. Upon conflation of such closure, the Permittee shall maintain a record of the closure activity in the facility operating record. 2. Required (toticss a. One year after the effective date of this permit and annually thereafter, the Permittee shall place in the facility operating record a description of all releases of hazardous waste or hazardous constituents fron any solid waste management units. Ml such releases shall be reported to EPA on a quarterly basis, initiating with the effective date of this permit. 26 CF020301 EID182718 PART III - INCINERATOR OPERATIONS 1. The Permittee shall control the total feed of hazardous metals below. to the hazardous waste incinerator The allowable feed rates apply to as specified tha combined total of all incinerator feeds, regardless of whether they are specifically regulated as RCRA hazardous wastes, and to all chemical forms of the listed metals. Metal Antimony Barium Lead Maximal Feed Rate (pounds per hour) 0-031 5.2 0.0094 Mercury Silver Thallium 0.031 0.31 0.031 2. i-or the following metals OQH, the four metals shall be set such that; maximim feed rata of all n 5 i.o where; w, = the actual feed rate of the ith metal constituent A, = the allowable feed rate of the ith constituent (specified below) n = the number of these aetals present in the total incinerator feed 27 CF020302 EID182719 JgSXal. Arsenic Beryllium cadaiiuB chromium Maximum Feed Rate fpounda par hour) 0.00024 0.00044 0.00058 0.000087 3. The total feed rate to chemical form shall net the incinerator of exceed 0.26 pounds chlorine in any per hour. 4. Within SO Permittee days after the affective date f shall aubmit to EPA for approval this permit, the management the feed plan that is limitations sufficient apecified to a detailed vasta ensure compliance with include, but is not United to; above* This plan shall a. waste sampling and analysis techniques and frequencies, b. management prseedures, including quality control methods, to ensure that constituent feed rates listed above not be exceeded at any time, and will c. record keeping pz-aetices. DATE SIGNED STEPHEN R. WASSERSU8, DIRECTOR HAZARDOUS WASTE MANAGEMENT DIVISION 28 CF020303 EID182720 MTOCHMBNT 1 aLmCH. RBQUIRBTOg TOR YEROTCCTION DiVESTIQftiriCK CB-020304 EID182721 AMManCaL BBOTREMOTOS TOR TOTS A-l, A-3, B-4, H,13 asfoasaittcs , vommES & SEMTWIACTUS Wi.i?DGUS ^NSTir.aiT ^cttwn/ A^eni: hriua Cagniiui Chroaiin (.fid .la-eury NickBl ititfllu* Siiyc Cyid taMnatiti) INWEWCS CftSMO. *40~%-0 ^o-sg-z 7440-39-3 744('43-9 744<-47-5 743^?2-1 '43-'7.6 7440-02-0 7792-49-2 7440-2.4 P.' an: t^ ^i3E+1 1EO 2B) eo SO 1E-1 3EO tf+1 <0 tf-Z FOt. Harea 9/1 SU66ESTES 'CTHOO ^-: 16-2 3-2 1E-! 16-2 16-2 2E-3 S-2 2-2 2E-! W-2 S010is 7C-11 / aOlOtS) ''W(f a0l0 SOlOtj) 'liKi.. 4010(*) 7l?li; eOlOls; 'n\ i; 7470 6010 6010(1) 7?WfN) &0t0( miw) 9010 * Prateieal QuaititaUon Iiiroits CF020305 BID 3.82722 HAZARDOUcaSNsnrueNT VOLATII.ES4 SEMlVOLAriLSS CfiSNO. PS1.I % 11. 9 ^ iCBtane &7-44-1 flcrelein 107-02-9 ^i",lflnitrtl9 107-13-1 A>thracBn fiwsene Ben:aCa]<ntriraetn* 120-t2-7 71.43-2 5A-5S-3 aensatWIuoranthenc 20S-99-2 BenzsCkK tuoruithBfli 267-1)8-9 SefisoCalpyrgM BtS!;-chlorotthflxy wttnn *syn. OichloroBBthaxyeth SisC-enlBroethyl) ether syn. Dichloroathyl ather Bi*(2-<til9Poisaprapyl) thtr *syn. Olclilaroisopiwyl ethec BisC-tthylhexyl) phttiktt *iyn, Oiathylhexyl phthilitB 50-32-9 :11'?M lll-4-4 l08-60*( n7-91-7 BrixKXjicfilorwthant 75-27-4 Braiafcrit *syn. TpibrMwethant 4-Broiophgnyl ptignyl ethtr Butyl benzyl phthalite Carbon disulfjde Carbon ttrichlarid 73-23-2 101-5S-! wQ^QQ^ 75-15-0 56-23-5 p-Chloroanilint io&-?-g ' Chlor'otHiUHr IOB-W'7 p-Chloro-t-crtsol 59-SO-7 Chloroethane Hyn.* Ethyl chlapid* OilorediduDroMthMt 7MO-3 74-97-S ChleniW A7-6&-! 2-Chttirgniiphthilw 2-Oilaraphenol Oit^sBni 91-^-7 %--9 218-01-9 iD-Cresol a-Ccesgl IOW9-4 95-48-7 p-Crol Bitin?Ci,h3anthfKgo Di-fl-butyl phthilite 104-44-5 S-7(h3 84-74-2 o-Dichlorotiautii^ 95-50-1 iH-Oichlarobenziiw 541-73-1 B-Diehlartibinung 106-4A-7 3,3'-DiehlarQbi!idin DichtorsdifluoroMthur 91-M-l 73-71-8 1.1-6icftlor<thaiw 75-34-3 1.2-Dichloitxtlwr nyn* Ethylent diehlociite l.t-Dichloraithylft 107-06-2 75-35-4 traM-t,2-Biehlor(Uiylw ISA-AM 2.4-0jc(ilorort>tnel 120-83-2 1.2-Dichloropro(nn 78-87-5 cis"l.3-flidilaniropw t raifl, 3-Oi cli iBrapfdptir Diethyl phth*l*t 2,4-Dithylpmn(il Dimthyl phthilitt 100&1-01-5 100&1-02-A 84-66-2 105-97-9 l!l-ll'3 IE-1 5E-! SEI % -1 X -3 3E-1 36-1 36-1 36-1 3E-1 3E-1 36-1 3E-t SE-3 5E-3 3E-1 36-1 5E-3 3E-3 31-1 5E-3 3E-! 16'2 S-3 SE-3 3E-1 31-1 3E- 3E5ESE- 3E3E1E-2 5E-3 . SE-3 tEO SM 5E-3 SE-3 5E-3 SE-3 3E-1 SE-3 IE-2 16-2 36-1 3E-1 3E-1 pa. MTER 3/1 SU6fiE57a/ tCTHOD 1S-1 SE-3 5E-! 16-2 SE-? 1E-2 1E-2 1E-2 1E-2 1E-2 1E-2 16-2 16-2 %-3 6-3 1E2 1E-2 5E-I S-3 IC-2 5E-S IE-2 1E-2 56-! 5E-3 1E-2 16-2 ie-2 16-2 1E-2 16-2 16-2 16-2 1E.2 5E-3 5E-3 2E-2 SE-5 3E-3 5E-3 5E-3 5E-3 1E-2 5E-3 1E-2 16-2 1E-2 1E-2 1E-2 8;4<) 924i) 9240 9270 8290 i32W) am 8270 am 3276 8270 8270 8270 B270 8260 (8240) 826D (8240) 8270 8270 8240 S240 8270 3260 (8240) 8270 8240 82AO (82401 8260 9270 8270 3270 8270 8270 8270 8270 8270 B260 (8270 8260 (8Z70) 9260 (9270) 9270 9260 (8240> 8260 (9240) 8260 (8240) K60 (8240) 9260 (8240) 8270 8260 (8240) 9240 8240 8370 1270 8270 CB-020306 EID182723 HAZARDOUCSONSTITUENT VOLAT1LE&S SB1IVOLATILSS MS NO. POL SOIL 9/fe9 4.ir0tmtro-g-ersei 2,4-Dini;r3>hBflS! 2,4-0initfal3lue<ie la-Dinitrctoluene Di-fl-actyl phthaiata thylbBn:en Fluoranthene PoMialdahyda Fariilic acid HflxachloroBenane HexaehlMtitutMisne HexachIar-ocyclflpentaQiene Hexachloroethane IftdBflBl,;J-cd3pyrwe Math/I bFomde *syn. 8rooiettiin Methyl cMoridt ^n.* Oilflrattthw HBthy[i chloritH *syn. Oiehlgi-flMthini tethyl ethyl kttw tyn. 3-lutinont Htthyt isofiutyl kgtBie *syn.* 4-flthyl-2-pen!;ansne Hthyl mthacryltf Hthylie chlorid syn Diehlgrarthini ffaphthilen* B-NitrB*nUine Hi^rdswzfm o-NitPBphtngI N-HitreM!)iphenylMln N-Nitrotetfi-n-ppoeylain PaitiEhlorophOTol Phoantlirfl Pheflol Pyrfn* l',l,l,2-Tttr>chlorgthr l,1.2.2-TtPKt)la-othant Tetriclilorotthylar Toluifr l,2.4-Trichlorobn;en 1.1.1-TrletitBrflttlwe 1.1.2-Tnehlorotthw TpiehlBrothyli TrjehlBrofluopgirthw TnehloPW*phthalttT 2,4,S-Trichl8reh(not 2,'.6-Trichlgro|*Hi8l Vinyl ehlwid* 534-52-1 51-28-5 1Z1-14-2 a0o-2l>-2 tt7-84-i5 tOO-41-4 206-44-f) 50-WH3 64-1B-& 118-74-1 87'&8-3 77-47-4 &7-72-1 193-39-5 74-C-? 74-B7-! 75-0<?-2 7M3-3 108-10-1 80-62-6 75-OT-2 H-20-! 10H1-A 98-SS-3 101M2-7 86-30-A 621-64-7 B7-BA-5 83-0t-8 10MS-2 129-00-0 &30-206 Tf-M-'S 127-IM 109-8B-3 120'12-t 71-^-6 79-00-3 79-OM 75-A9-4 l!2t-6M W-93^ 38-0&-2 7M1-4 5EO 2EO 36-1 3E-1 .3E*l 5E-3 3-1 5E-1 2E-t SE-i ^3 !S-l 3E-1 3E-1 16-2 1-2 56-3 1E-1 1E-1 36-2 5E-3 SE-l 10 3E-1 .160 %-1 1E-1 m 36-1 3E"t S-1 SE-3 56-3 56-3 SE-3 16-2 a-3 56-3 SE-3 SE-3 31-1 20 46-1 IE-2 pa, HATER ^/t aJGSESTED METHOD S-2 SE-2 IE-2 tE-2 1E-2 %-; 1E-2 IE-2 2E-1 1E-2 SE-3 IE-2 1E-2 IE-2 16-2 1S-2 SE-3 16-1 1E-1 36-2 S-3 ie-2 26-2 1E-2 S-2 IE-2 ie-z 9E-2 1E-2 16-2 IE-2 6-5 5E-3 5E-3 56-3 1E-2 SE-3 SE-l 5E-3 5E-3 1E-2 56-2 !6-2 1E-2 9270 3270 8270 8270 8:79 8260 i8:^) 8270 8S15 3015 S270 1240 (81201 B270 8270 8270 8260 (8240> B2AO19240) 8Z40 , B240 8240 8240 8240 8270 8270 8270 8270 270 6270 9270 8270 270 8270 8260 (9240) 9260 (8240) 8260 (3240) 9260 (9240) 8260 (8270) 8260 (8240) 9260 (8240) 8260 (8240> 8260 (82M) 8270 8270 8270 8240 CP020307 EID182724 aNMaTICM. BBQOIKBIENTS FOR UNIT C-6 TOUCTn<ES & SanVOLBTOaS HAZARDOUS CONSTITUENT Acrolein Acrylonitrile Benzene Bis(2-ekhylhexyl) "'-S1^501 phthalate 0-Ctesol p-Cresol Diethyl phthalate 2,4-Dinitrotoluene Ethylbenzene Mefchyl ethyl Itetone Naphthalene *syn. p-Nitrophenol vheao]- Tsluen Xylana (total) *syn. Diethylhexyl 2-Butanone phthalate ^g (,Q ..g^ g., o 107:13-1 71-43-2 117-81-7 108-39-.4 95-48-7 106-44-5 12814--1646^-22 100:41^4 78-93-3 91-23 3 133-02^7 108-95-2 138-88-3 1330-20-7 CB-020308 BID182725 HnaoMaw 2 QA / QC GomaNcs CF020309 EID182726 Attachment 2 U.S. EPA, September, Chemical ^teffixjs 3^ 1986. Tgst Methods Edition^Office o fog gyaluafeing Solid ^oild Wastes? H^ieaX/ ?55-00l-00000-f Washington, D.C. 20460. Waste. EPA/SW-84S.iJl:to. U.S. EPA, Assurance Dgeeniber 29, 1980* Qildglin^ayi^ gBecificaltigng^ Project, Plans. Office oe fog Pgepaging^iality WS-Q05/SJQ Nf IS ?83-170514 Monitoring Syatet Washington, D.C. 20460. arri Quality Assurance. U.S. BPA, May, 1978 (Beviged May 19861. Enfoccaaent dnd Coroplianee MEtCJblieie^; ang gTOcedmya. oefice of Center,-- EBft> - 330/9 - 78-00M1sn- itRorDin8gn.vrN, aCtoiolcnwaaldEa n8&02r(2W5.ht Ihv3tigafcioro S^i^I^ ^M& U.S. SPA, March, 1987. ^blaeA Develcgnente Data Quality Objectivea foe HaMdiaJl BeaBonae Aetiyitiea. Pgreeaai. (SMER carecfeive Nb. 933570-7B.' ^IvB^iiBMil^^ "ol Qassgancy wl Office of Waaee PEOgraM BnforoeniBnt. ^aatdtai asaponae and Wahington* D.C. 20460* CF020310 EID182727 PACT SEiEgr FOR HAZARDOUS WASTE MAtlAGEMEOT FACILITY PERMIT I. E. du Ibnt de (fetnours & Company - Parkersburg Plant WVD 04 587 5291 This Eact sheet has been developed for EPA's portion of the draft Resource Conservation and Recovery Act (BCRA) permit which EPA and the State of West Virginia intend to issue to E. X. du Font de Nencurs & Company (Permittee), Parkersburg plant, for its hazardous waste management facility located on DuPont Boad in Parkersburg, Wast Virginia 26102. The gull HCRA permit is comprised of EpA's pennit, which addresses the provisions of the Hazardous and Solid Waste Amendments o 1984 (HSUA), and the State of West Virginia's permit, which addresses that portion of BCBA for which the State of West Virginia is authorized. This fact sheet was prepared in accordance with the requirements of 40 CPU 124.8. the draft pennit for which conments are now being solicited is a revised draft permit. The original draft pennit was proposed by public notice on tloveaber 20, 1985, in anticipation of the issuance of a TCRA, operating pennifc by the State of West Virginia. The state permit was delayed? therefore, EPA did nob issue a final permit at that time. The draft permit has been revised to incorporate more specific and directed investigation requirements, additional information provided by the permittee regarding the solid waste management units, and limits on the emission of certain metals and hydrogen chloride from the hazardous waste incinerator. A. PtJKPOSE OP THE PERMITTING PROCESS The purpose of the permitting process is to afford the Environmental Protection Agency (EPA), other governmental agencies, and interested citizens the opportunity to evaluate the ability of the Bermittee bo coiqply with the applicable hazardous waste management regyiren>snts promulgated umiter the Resource Conservation and Eecovery Act (BOA), as amended by the Hazardous and Solid Waste Amendments of 1984 (HSMA), 42 U.S.C. 6901-6987. EPA ig required to prepare a draft pennit which sets forth in ons concise document all the applicable requirements with which the Agency intends to require the ^srmlttee ' to comply during the ten-year duration of the peCTiit. Tha public is given fiarty-flve (45) days to review and ooninsnt on the draft peEmit conditions prior to EPA taking any final action on EPA's draft permit. B. tTOgaDoa^ ICR BEacaiNG A FIMM. DECISION Section 7004(b) of aCRA and 40 CFR 124.10 require that the public be given forty-five (45) days to ociiinent on each draft permit prepared under the teaouree Conservation and Recovery Act. The conroent period will begin on August 18, 1989 and will airi on October 2, 1989. Any person interested in connienting on this draft pennit must do so within this forty-five (45) day conment period. CB'020311 BID182728 A public hearing has been tentatively scheduled foe 6 EM on October 5, 1989 at the City of Parkecsburg Municipal Building, city Council Chambers, 2nd Floor, Second and Avery Streets, Barkersburg, West Virginia, This hearing will be held if, and only if, a hearing is requested in writing by October 2, 1989. EPA will determine by October 2, 1989 if a public hearing will be held* After October 2, 1989, any interested party may contact Ms. Maureen Essenthier at the BPA address below or call (215) 597-9287 to find out if a public hearing will be held as tentatively scheduled* All persons wishing bo comment on any of the permit conditions III, should submit fcheic comments in writing to the Environmsntal Protection Agency (fiEA), Region 841 Chestnut Building, Philadelphia, Pennsylvania 19107, Attentions Ms. Maureen Essenthier, General States Pecreits Section (3HH52). Conroents must include all reasonably available references, factual grounds and supporting material. Mhen making a determination regarding the 'Issuance' of 'this draft permit to the E. I. du Kmt de Remours & Company, BPA will consider all written ccninents received during the ccnrent period, oral and written statements received during the public hearing (if held), the requireiTnts of the applicable hazardous waste regulations of 40 CE-R Parts 124, 260-264, 268, and 270, the Agency's permitting policies, and HSWA. When EPA makes a final permit decision to Issue, deny or modify this draft permit, notice will be given ^o the applicant and each person who submitted written coianents or requested notice of the final decision. The final DeEmit decision shall becone effective thirty (303 days after the service of notice of the decision unless a later date is specified or review is requested under 40 CPR 5124.19. Sii If no coBaaents request a change in this draft permit, the final permit shall become effective iiroediately upon issuance. Contact person for the E. I. du Boot de Nemours S Corapany Parkersburg Plant draft pennit is; III f^. llaureen Bssanthier (3HW52) U.S. Environmental Brofcection Agency Region 841 Chestnut Building Htiiladelphia Pennsylvania 19107 215-597-9287 C. HAZAaPOOg AMP SOUDjffiSTE AMEtPfflCTS Continuing Releases at Permitted Facilities Background As part of the RCKA permit, BPA regulates solid waste management units (SWiUs) subject to the corrective action provision of HSHA. The State of West Virginia has not been delegated authority under HSMA to regulate these units. 'A solid waste management unit is any active or inactive unit at the facility firom which hazardous waste -2- CF020312 E1D182729 or hazardous constituents might migrate, irrespective o when waste was placed In the unit or whether the unit was intended for the management of solid and/or hazardous waste. One of the most important provisions o the Hazardous and solid Waste Amendments of 1984 (HSMA) is the requirement or corrective action for continuing ceieaaes. This provision is established in Section 3004(u) of IOA (Section 206 of HSWO implemented as regulation 40 CFR 264.101, 50 Fed. Reg. 28747 (July 15, 1985), Section 3004(u) provides as follows: "Standards promulgated under this section shall require, and a permit issued after the date of enactfnent of the Hazardous and Solid Waste Amendments of 1984 by the Administrator or a State shall require, corrective action for all releases of hazardous waste or constituents from any solid waste managenent unit at a treatment, storage, or disposal facility seeking a permit under this subtitle, regardless of the time at which waste was placed in such unit. Pennies issued under Section 3005 [of RCBAl shall contain schedules of compliance for such corrective action (where such corrective action cannot be oanpleted prior to issuance o the pennit) and assurances of financial responsi bility for completing such corrective action.1* The intent of Congress in establishing this permit require ment was to correct a perceived shortcoming in th@ existing statute and RORA regulations, which allowed permits to be Issued to facilities at which environmental contamination was occurring or had occurred, without the peEmit addressing Chat contamination. All permit applicants must now (a) identify all solid waste management units (SWMUs) at the facility, (b) identify any releases that have occurred or are occurring (con those units, (c) take appropriate corrective action to cleanup those releases, and (d) demonstrate financial assurance for those corrective actions. The provision on continuing releases was effective on the date of enactment of HSWA (Moveaber 8, 1984). Thus, a peraiu.t issued after that date must address this provision* The basic standard for imposing corrective action at the DuBontParkocsburg plant is protection of human health and the environment. The permit will address corrective action when there is or has been a probable release at the facility that posea a threat to human health and tha enviromaent. A substantial threat to human health and the enviroranent la assumed if there is a release or likelihood of a release from a solid waste management unit at the DuBont-Parkersburg plant into the air, surface water? giound water, or soil. Implementation The process of implementing Section 3004(u) of BOiA cakes place in three stages, with each stage consisting of several specific steps, as followst CF020313 EID182730 1. KCBA Facility Assessment* a. Submission of solid waste management unit information by applicant. b. Evaluation o solid waste management unit Information submitted by applicant to determine the possibility or extent of releases. c. Iterfotmance o Site Investigation. 2. f?CBA Facility Investigation and Corrective Measures Study. a. Limited investigation by owner/operator to identify or verify releases. b. BORA Facility Investigation/ i necessary, by owner/operator to characterize nature, extent, and rate of migration of the release. c. Development of a proposed program of corrective measures, if necessary. 3. Corrective Measures ImpleroBntatlora. a. Establishing the program for corrective measures* b. Dennonstratelon of financial assurance. c. Conducting corrective measures. The BCRA Facility Assessment has been ccropleted. Solid waste management unit information was developed through Dutont's permit applications and information submitted regarding solid waste management units at the facility, h site inspection was conducted by EPA representatives on August 30, 1985. The revised draft penult contains conditions recjuiring OuPont to perform further investigations at several SMMUs. As these activities are cccpleted, EPA will evaluate Cha results and determine i< further action is warranted. If corrective measures are warranted, EPA will propose a major permit modification and follow appropriate procedures, which include a public notice period and, possibly, a public hearing. Other Bpgyisiona A number of other provisions in HSWA became effective Woveribar 8, 1984. Provisions concerning the standards Cor owners and operators of hazardous waste managernsnt facilities and provisions concerning general permit conditions were promul gated as final regulations on July 15, 1985 (50 Fed. Reg, 28742). Two provisions, in addition to that pertaining to corrective action for continuing releases, apply to this draft permit. -4- CB-020314 EID182731 tt provision in Section 3005(c)(3) of RCBA (Section 212 of HSMA), inplemented at 40 CTR 270.32(b)(2), authorizes EPA oc the State to establish any term or condition in the permit determined necessary to protect human health and the environment (see Bennit Condition I.e.). In conjunction with teat requirement, emission limits for certain metals have bean established for the facility's hazardous waste incinerator (see Permit Condition III.). Section 3005(h) of RCRA (Section 224 of HSMA) requires that, as of Septetnber 1, 1985, permittees of hazardous waste management facilities located on the premises of the generator must certify that certain waste minimization practices have been established. This requiremant has been incorporated into the regulation concerning the Operating Seeord of the facility (40 CFR S264.73(b)(8). Regulation 40 CTR 270.30(j)<2) was revised to clarify that this operating standard must be a condition of the permit, (see Sennit Condition II.H.) D. FACnjTY DESCRIPTTOM 1. General The DuBont facility is located in Wood County, five miles west of Parkersburg, West Virginia. Ihe facility haa been operating since 1948. Th aite consists of approximately 700 acres of bottom land located on the West Virginia side of the Ohio River. Ihe Ohio River Corns the north and west boundaries. The DuFbnt facility la a polyiaec products manufacturing facility involved in the production of nylon, polyvinyl butyral, acrylic resins, fluoTOpolyraers, and polyacetals. The Sfest Virginia Department of natural Resources (ENR) issued a permit to du Font on January 5, 1987 for the management o hazardous waste. Thia permit is toe die operation or one container storage area and two storage tanks. 'Ihe West Virginia Air Pollution Control Commission issued a permifc for the operation of the polyaeetal organlcs incinerator on September 30, 1988. 2. Solid Waste Management Ohitg BIA itegien Ill's portion of the permit will regulate solid waste management units subject to corrective action. The Sfcate of West Virginia has not been delegated authority bo regulate these untta iBider HSWA. 'these solid waste management units are active and inactive units at the facility from which hazardous waste or hazardous constituents might migrate. Irrespective of when waste was placed in the unit or whether the unit was intended for the management of solid or hazardous waste. III, EPA, Region has conpleted a preliminary evaluation baaed ons (1) information supplied by the applicant in Its correspondence dated June 5, 1985, and August 30, 1985, (2) BCRA pesniit application and related correspondence, (3) site visit conducted August 30, 1985, (4) sit visit report and assessment report prepared by -5- CF020315 EID182732 I. A. Keamey Management Consultants, and (5) July 6, 1985 meeting between representatives of du Etont and EPA. Sixteen solid waste management units were identified at the facility (see figure I)/ six of which will require investigations for possible releases of hazardous waste or hazardous constituents (a) tfeits Bequiginq Verification ^Investigation with Sampling Based on available information, EPA has determined that releases have or may have occurred from six solid waste raanageraent units. A-l - CUEtont Road Landfill; This active landfill has been the principal disposal site or non-hazardous solid wastes generated at the facility since its development in 1964. DuEbnt has Indicated that small quantities of ash resulting ran the Incineration of plastics with barium, cadmium, selenium and chromium containing pigments were disposed until 1980, when the EP toxicity test indicated that the wastes were hazardous. The landfill is unlined. EPA is requiring that DuPont conduct additional investigations of this unit. A-3 - River Bank Landfilli This inactive landfill was the principal land disposal site for solid wastes generated by the plant during its first fifteen years of operation. According to information submitted by DuBont, the waste disposed in the unit included powerhouse wastes, plastics and rubble. Because this unit was operated during the period before any wastewater treatment, incineration, oc other nodern disposal facilities were installed on site, it is possible that unknown quantities of manufacturing wastes were disposed in this unit; including raw materials, intermediates, products or wastes associated with the manufacture of nylon, acrylic resin, acetal cesin, tetraflouroethylene, or polyvinyl butyral sheeting. The unlined landfill is located on the bank of the Ohio River. EPA is requiring that CuEtant conduct additional investigations of the unit. B-4 - Anaecgbic Digestion Bondst These closed units consisted of three surface impoundroahts that received an aqueous waste stream from the tetraflouroethylsne manufacturing process. The waste stream contained trace amounts of hazardous constituents. The unit experienced subsurface releases, prior to installation of clay and bentonita liners, EPA is requiring that Du Pent conduct adUltlonal investigations of this unit since subsurface releases have been experienced in the past and degradation of the bentonite liner was possible from the surfaetantes treated in the unit. The investigations should be conducted In conjunction with the River Bank Landfill (Unit A-3) due to the eloae proximity of the units. C-6 - Epiyacetal Products Incjineratoc: This active unit consists of two open Eicebrick-Hneo, pits, In which polyaoetal polymer is burned. No analysis has been provided on the combustion products. EPA has detecnitned that additional information is needed to characterize the products of the open burning process. -6- CF020316 EID182733 ^11 - Injection Wells, No. .1 & 28 TWO deep injection wells were used for the disposal of plant hydrochloric acid wastes. Well No. 1 started operating in 1969 and was plugged in 1976. Well No. 2 started operating in 1972 and was plugged in 1980. Operation of the wells pre-dated the Underground Injection Control program under the Safe Drinking Water Act, although the wells had state permits. Information submitted by DuBont indicates that vfell cfo. i experienced problems which required reworking the casings. No infor mation was provided it.icating the possibility of releases above the injection zone resulting fron this problem. EPA is requiring additional information for both wells. H-13 - Burning Groundsi Prior to 1965, open burning of, plant trash and organic liquids was conducted in this area. The liquid wastes included acrylic monomer slurries, ink slurries, tetraflouroethylene high boilers? as well as other solvents used at the plant during that period. A building has been constructed over the site. Open burning created the potential Cor contamination of aquifers. Ho gross contamination has been reported by CuPont, but no nonifcoring has been conducted* BPA is requiring additional investigation of this unit in conjunction with other units In the area. (b) Units Not KeouiringRemedial Investigation A-2 " Ogngti^ticmJLandftlls This active landfill is used for the disposal of soil from excavation work, and brick and concrete from demolished buildings and broken pavement. DuBont representatives have indicated that no paint, solvents oc asbestos-containing wastes have ever been disposed in the unit. Since there is !Y> indication that hazardous wastes or wastes with hazardous constituents are or have ewe been disposed there, EPA has detaEmined that a remedial investigation is not needed for this unit. C-5 - Polyacetal Qpganica Incinerators: This unit consisted of two incinerators. Oneincinerator still exists and is in use. The Permittee has received an operating permit fa-on the Vfest Virginia Mr Pollution Control Gaomission Cor this unit. 'Hie second incinerator, which was dismantled In 1984, was used to back up the active incinerator. it The dismantled incinerator was rarely used, and Duttent has indicated that no spills or releases occurred when was in operation* The feed tanks were the same as those included in Duibnt's ROSA Part B Desalt application. EPA has detemined that a remedial investigation is not needed foe this unit. C-*7 " IneiHeratoca Up. 1 &_2. 'These two active units are used for the incineration o plant trash and waste plastics. Ihe inciner ators are operated under a Meat Virginia Mr Bsllution Control Bandit. These incinerators ace both high temperature processes (approximately 1400'^) and the combustion products are expected to be primarily carbon dioxide and water. EPA has determined that a remedial inves tigation is not required. CF020317 EID182734 D-8 > Waatewater Treatment Plant: This is a 3 million gallon per day activated sludge waste water treafanent facility. Waste streams are puaiied to the unit via overhead lines. All tanks in the unit are steel and are above ground, the site inspection found thafc all tanks were in good condition and appeared to be well maintained. With the exception o the eiarifiers, all tanks are equipped with leak detection wells. EPA has determined that a remedial investigation is not needed Cor the units. S-9 - jlementaryjteutraligation/^fasteL^cid and Calcium Chloride; This wit consists or two wood and cutober-lined steel tanks"(for the neutralization of waste hydrochloric acid with limestone, two plastic-lined cement clarification tanks, and associated piping. The pH of the waste is adjusted in the unit, and neutralized wastes are discharged to an MPDES - peonitted outfall. The tanks are in good condition. Spillage from overfilling is monitored by an audible alarm system. The neutralization o hydrochloric acid produces carbon dioxide gas, which is vented in the neutralization tank through the open top. Volatile ocganlcs that acconpany the waste stream may be emitted, but have not been confirmed. EPA has determined that a remedial investigation is not needed (or this unit. P-10 - Elenentary NautralizatiCTi/te'ExGnan^. Unite t This unit neutralizes aiT acid"stream proauced^by the generation of the plant's powerhouse ion exchange unit. the streams are collected in an acid-proof brick-lined simp which is covered by a metal plate. Th equalization tank is open-topped and constructed of stainless steel, and sits on a concrete foundation with open space under the tank for leak detection, the equalization, tank is equipped with an audible alarm system to protect against overflow. The waste stream than goes to a pH adjustment tank made of fibercagt. After pH adjustment, the waste ia discharged to an NFDBS-permitted outfall. All tanks and plumbing are at ground level and appear to be in good condition. EPA has determined that a remedial investigation is not needed for this unit. It 6-U '-'JajBardou.s 'Wwt@ 'Storages 'Qlia unit was included in the RCR& Part B application." Ig, tnarefore, a regulated unlt and is included in the RCRA operating peotu.t. ft-13' -'DaBao 'Baaini 'Bus inactive unit is located on the rlvwr""B5nli and was used frail 1954 to 1973 to dispose of hexainethylene diamine/ carbon black slurry fron cleaning filters in nylon produc- feion. DijiiBthylformanide-based ink was also poured into a trench to the east of this unit and allowed to biodegrade. the unit is conpletely owened and vegetated. Based on the wastes in the unit, reported by Du Bont, EPA has detemiined that sc remedial Investigation is not needed for this unit. -8- CS-020318 BID182735 3- Incinerator Conditions Section 3005(c)(3) of the Resouroe Conservation and Recovery Act ("RCTA" or "the Act"h as amended, 42 U.S.C. 6923, charges BPA with a statutory obligation to ensure that all BCRA permits contain conditions that are sufficient to protect human health and the environment. This "omnibus'' authority is codified at 40 CFR 270,32(b)(2). EPA is currently developing risk-based regulations oc the control of ten toxic metals and hydrogen chloride (HCl), This action was proraptad by studies which indicate that, in seme instances, existing RCBA performance standards for hazardous waste incinerators are not fully protective of human health with respect to metals and HCl. In support of the regulations, BPA hag developed a draft tech nical manual titled 'Guidance on Metals and Hydrogen Chloride Controls for Hazardous Waste Incinerators'1 (EEA, Office of Solid Waste, March 1989). This document provides the permit welter with a simpli fied methodology for detetntlning acceptable waste constituent teed rates. Using the Tier I screening procedure contained in that document, and conservative air pollution control efficiency estimates, EPA has determined waste feed concentrations for each metal and HCl which would ensure protection of huaan health. The assumptions used to obtain these values are documented in the administrative record. Because neither existing HCRA performange standards (40 CFR Part 264, Subpart 0) nor the state-issued permit designed to met those standards can ensure conpliance with acceptable risk-based constituent waste feed rabes for metals and HCl, BPA is establishing III acceptable waste feed limitations in this portion of the BCRA permit pursuant to its omnibus authority. The constituent feed rates specified in Bart of this permit were determined using site- specific data and the Tier I screening procedure referenced above* This procedure is know to be conservative (i.e., it may provide an unnecessarily large margin of safety), but BKA~believ@s it is the beat one available, given existing infoCTiateion. ttowever, more site-specific information may indicate that higher waste feed concen trations adequately protect hunan health and the environment* Site-specific information might include actual air pollution control equipnent efficiencies), aah partitioning data (i.e*, percentage of each meteal 'whieh leaves the incinerator in the ootFom ash versus the fly ash), meteorological data, or refined air dispersion models. M further infoBBation becomes available and if it indicates that' SOB* adjustiasnts to the proposed feed limits are appropriate, BPA will make those changes in the final permit, EPA will review any additional information to determine whether operating parameters other than those listed in this permit are capable of neeting the following requirements s -9" CE'020319 EID182736 I* For noncarcinogenic metals and HC1, exposure to the most exposed- individual (MEX) shall not exceed the Reference Air Concentration (BAG) tot any compound. The RAC Is the ambient air concentration at which the Agency has determined that no adverse human health effects occur. 2. For carcinogenic metals, exposure to the t'lEI shall not exceed an incremental lifetime cancer risk of 1 x 10~3 (eg. 1 in 100,000). The applicable RACs for noncarcinogens are listed in Appendix 1, Table 1-3, of the metals guidance document. Incremental lifetime cancer risk is calculated using "unit risk" values (also listed in Appendix I, Table 1-2). "Unit risk" is defined as the incremental risk to an individual exposed for a lifetime to an-bient air containing one microgram of the compound per cubic meter of air* This action is consistent .with. jiafctonal .policy established in a memorandum"from Sylvia K. lawrance, Director, Office of Solid Waste, U. S. EPA to the Hazardous Waste Division Directors in each of the EPA Itegional Offices (February 27, 1989). It is also supported by the decision issued in RCRA Appeal Ho. 87-12 In the Matter of Chemical Waste Management, Inc., RCKA Bannit Ms. AID 000 622 464. In this decision, the EPA Administrator directed EPA, Region IV, to consider regulating matals emissions under the omnibus provision to protect human health and the environment and to prcmote uniformity throughout the program. The Order states, in part; Of course, penult writers are not required to incorporate all proposed regulations tnbo every permit under the oniinibus provision. Reconsideration is warranted hare, however, because (1) the Agency recognizes the potential risks posed by PICs and metals emissions; (2) the forthconing guidance will iceconinend that permit writers consider including controls for these emissions immediately under BPA'a omnibus authority? and (3) the Region's primary reason for refusing to consider imposing the requested standards was the absence of existing regulations (rather than the absence o any risk to public health or th environment)." III Because Region has determined that metals and HC1 emissions, i not properly conbrollad, pose an unreasonable risk to human health, and that aanpliance with existing regulatory standards ia not sufficient to ensure attainment of constituent-specific risk-based standards, EPA is using its omnibus authority in this porteicd o the full RCBA permit to ensure protection of human health and the envizorraent. -10- CB'020320 EID182737 PEKMIT OKG&NIZATIOM Ihe permit is divided into the parts as outlined below. Part yiiukllblllll Ttop^c -H[l.imS[ll^B I Standard Conditions II Specific Conditions III Incinerator Bnission Limits III Part I contains general conditions which apply to all hazardous waste facilities. Part XI contains conditions which pertain Specifi cally to solid waste management units at the DuPont-Packersburg facility. Part contains emission limits for the facility's hazardous waste incinerator. SIKMARY OF TEE PEBMIT COMDmOMS this section of the fact sheet provides a summary of the conditions in this draft permit. PART I SiaNEftRD CONDITICNS Part I of the peonit sets forth the standard conditions that are applicable to ail hazardous waste management facilities. Unless otherwise specified* all citations refer to the regulations as codified in Title 40 of the Code of Federal Regulations (40 CTR). Permit Condition I-A I.B subject Effect of Itennit Peianit Actiona I.C Beffldt Conditions I.D Sewrability Requiganant S270.4 S270.30(g) S270.30(f) 5270.41 5270.42 5270.43 S270.32(bH2) $212 of HSWA (3005(c)(3) Of BCRft. S124.16(a) -11- CF020321 EID182738 I.E I.P I.G I.H I.I I.I.I 1.1.2 1.1.3 1.1.4 1.1.5 1.1.6 1.1.7 I.E. 8 1.1.9 1.1.10 1*1. U 1.1.12 1.1.13 Definitions Reports, Notifications, and Submissions to the Regional Mninistrator Parts 260-264 Part 268 Part 270 Signatory Requirements Documents to bs Maintained at the Facility Site 270.11 270,30(k) 264.73 Cutiea and Requirements Duty to Comply CUty to Baapply PeiCMit B^iratioin and Continuation ' Need to Halt or Iteduce Activity Not a Defense S270.30(a) 270.l0(h) 270.30(b) 270.51 5270*50 5270.30(e) Duty to Mitigate Beeper Operation and Maintenance S270.30(d) S270.30(e) EUiy to Prcwida Infonnation 270.30 (h) 264.74<a) InsEieetion and Bitry $270.30(1) Monitoring and Records 270.30(j) Baporting Planned Changes S270.30(1)<1) and (2) and anticipated Monconpliance Tranafer of Permit Twenty-fan? Hour Reporting Iinnediate Sporting of Releases $270.40 270.30(1)(3) 270.30(1)(6) S264.56(d)(l) and (2) -12- CF020322 EID18273& 1.1.14 1.1.15 1.1.16 i.i.n 1.1.18 Other Noncompliance Otter Information OctBpUance Schedule Biennial Report Land Disposal Restriction 270.30(1)(10) 270.30(1)(11) 270.30(1)(5) 264.75 270.30 (1)(9) S3004(b)-(m) of BCRA PAST II SPECIFIC CONDITIONS II Part of the permit sets forth the specific conditions with <^ich the Becmittee nust conply. All provisions required by this part are authorized by Sections 206, 212, and 224 o tBWAy which amends Sections 3004 and 3005 of ROSA, and 40 CFR Section 264.101. gennit Condition II.A Correct iw Action for Continuing Releases II.B n.c n.D II.B Verification Investigation interim Measures JSA Facility Investigation Submissions to Agency and Dispute Resolutions II.p 1I.<3 H*B II.I PMaBttt Modification Certification of Waste Minimization EecoEdkeeping and Reporting Closure and Notification Raquiremsnts I I I PACT IMCIMERMOR EMISSION LIMITS III Fart of the pennit sets forth conditiona for the contEoJl of ten toxic metals and hydrogen chloride from the hazardous waste incinerator. These provisions fall within thtt "onnibus" authority of Section 3005(c)(3) oC BGRA. -13- CF020323 EID182740 CS-020324 EID182741