Document mD8JKKvknBaLbxEva7ZZ56v0
HAZARDOUS WASTE
S
DOW CHEMICAL USA, LOUISIANA DIVISION WEST BATON ROUGE AND IBERVILLE PARISHES
Louisiana Highway 1 Plaquemine, Louisiana 70765
LAD008187080
I. PERMIT PREAMBLE
This permit is issued to Dow chemical USA, Louisiana Division, hereinafter referred to as the Permittee, by the Louisiana Department of Environmental Quality (LDEQ) under authority of the Louisiana Hazardous Waste Control Law. R.S. 30:1131 et seq., and the regulations adopted thereunder and by the U.S. Environmental Protection Agency under the authority of the 1984 Hazardous and Solid Waste Amendments to RCRA (HSWA).
For the purposes of this permit, "administrative authority" shall mean the Secretary of the Department of Environmental Quality, or his/her designee or, in the case of HSWA provisions (Section IX) for which the State is not authorized, the U.S. Environmental Protection Agency' _ shall be the administrative authority.
This permit is based on information submitted in the permit application, and all subsequent amendments, and on the applicant's certification that such information is accurate and that all facilities were or will be constructed and operated as specified in the application.
This permit is conditioned upon full compliance with all applicable provisions of the Louisiana Hazardous Waste Control Law.
All definitions contained in this permit shall have the meaning as defined in Louisiana Administrative Code (LAC) unless otherwise stated herein.
1
DO 143579 00NFTDFNTTA1
I
'ADEQUATE INADEQUATE|COMMENT
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
II. A.
C.
GENERAL PERMIT CONDITIONS
DURATION OF PERMIT
This permit is effective as of the date indicated on the accompanying signature page and shall remain in effect for a period of ten (10) years from the effective date, unless suspended, modified, revoked and reissued or terminated for just cause.
EFFECT OF PERMIT
The Permittee is allowed to store, treat, or dispose of hazardous waste in accordance with the conditions of this permit. Any storage, treatment or disposal of hazardous T .sate not authorized by statute, regulation or this permit is prohibited. Compliance with this permit constitutes compliance, for purposes of enforcement, with Subtitle C of RCRA and Part VII of the Louisiana Environmental Quality Act (Act). However, compliance with the terms of this permit does not constitute a defense to any order issued or any action brought under Section 3013 or Section 7003 or RCRA, or under Section 106(a) of the Comprehensive' Environmental Response, Compensation, and Liability Act of 1980 (42 U.S.C. 9606 (a)).
Issuance of this permit does not convey property rights of any sort or any exclusive privilege; nor does it authorize any injury to persons or property, any invasion of other private rights, or any infringement of State or local law or regulations.
PERMIT ACTIONS
Any inaccuracies found in the permit application may be cause for revocation or modification of this permit. The Permittee must inform
2
AO 143530 C0NFTD5NTIAI f
'ADEQUATE INADEQUATE|COMMENT
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
the administrative authority of any deviation from, or changes in, or inaccuracies in the information in the permit application.
The administrative authority may
also suspend, modify, revoke and
reissue, or terminate for cause as
specified in 40 CFR 270.41, 270.42,
270.43 or LAC 33:V.309.F or 323.
The administrative authority may
modify the permit when the standards
or regulations on which the permit
was based have been changed by
promulgation of amended standards or
regulations, or by judicial decision
after the permit was issued. The
filing of a request for permit
modification,
revocation
and
reissuance, or termination or the
notification of planned changes or
anticipated noncompliance on the
part of the Permittee does not stay
the applicability or enforceability
of any permit condition.
D. SEVERABILITY
The conditions of this permit are severable and if any provision of
this permit or the application of any provision of this permit to anyv circumstance is held invalid, the'` application of such provision to other circumstances) `-and the
remainder of this permit, shall-not be affected thereby.
DUTIES AND REQUIREMENTS
1. Duty to Comply.
The Permittee shall comply with all conditions of this permit, except to the extent and for the duration such noncompliance may be authorized by an emergency permit.
Any permit noncompliance, other than noncompliance authorized by an emergency permit (LAC
3
DO 143531 CONFIDENTIAL
I "ADEQUATE INADEQUATE I COMMENT
oO>
>-
33:V.70l),
constitutes
a
OS
=<5 z
violation of the LAC and the Act and is grounds for
< enforcement action which may
include permit termination,
HW
permit
revocation
and
reissuance,
permit
utu
modification, or denial of a permit renewal application.
.u
z o
2 Duty to Reapplv.
u 0tcuo-
z
If the Permittee wishes to continue an activity regulated by this permit after the
expiration date of this permit,
Hxato--.1
CL
the Permittee must reapply for the permit as required by the LAC.
tu
z
Xtu
3. Permit Extension.
O' This permit and all conditions -<4 herein will remain in effect CL beyond the permit's expiration
date until the administrative oo authority issues a final
decision on the re-application,
provided the Permittee has
submitted a timely, complete
new permit application as
provided in LAC 33:V.303.N. V
4. Need to Halt or Reduce Activity Not a Defense. *" _
It shall not be a defense for the Permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit.
4
00 14353? OONFTDENTTA!
1
'ADEQUATE INADEQUATE|COMMENT
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
5. Duty tQ.Mitigate.
The Permittee shall immediately take all reasonable steps to minimize
or correct any adverse impact on the environment resulting
from noncompliance with this permit.
Proper
Operation
Maintenance.
and
The Permittee shall at all times properly operate
and maintain all facilities
and systems of treatment
and control
(and related appurtenances) that are installed
or used by the Permittee to achieve compliance with the conditions of this permit.
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
5
DO 143533 CONFIDENTIAL
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
'ADEQUATE INADEQUATE I COMMENT
or similar systems only when necessary to achieve compliance with the conditions of the permit.
7. Duty to Provide Information.
The Permittee shall furnish to the administrative authority, within a reasonable time, any information which the administrative authority may request to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit, or to determine compliance with this
permit.
The Permittee shall also furnish to the administrative authority, upon request, copies of records required by this
permit.
8. Inspection and Entry.
The Permittee shall allow the administrative authority or an authorized representative, upon the presentation of credentials and other documents as may be required by law, to:
a) Enter upon the-Permittee1 s
premises where a regulated
activity is located or
conducted,
or where
records must be maintained
under the conditions of
this permit;
b) Have access to and copy, at reasonable times, any records that must be maintained under the conditions of this permit;
c) Inspect, at reasonable
times, any facilities,
equipment
(including
monitoring and control
6
DO 14353^
`ADEQUATE INADEQUATE ICOMMENT
PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
equipment), practices, or operations regulated or required under this
permit; and
d) Sample or monitor, at
reasonable times, for the
purposes of assuring
permit compliance or as
otherwise authorized by
the
administrative
authority any substances
or parameters at any
location.
9. Monitoring and Records.
a) Samples and measurements
taken for the purpose of
monitoring
shall
be
representative of the
monitored activity. The
method used to obtain a
representative sample of
* *
the waste to be analyzed must be the appropriate
S method from Appendix I of
40 CFR Part 261.
Laboratory methods must be
those specified in Test
Methods for Evaluating
Solid
HflBtBf Physical/Chemical/
Methods. SW-846, 1982, as
revised; Standard Methods
for__ tfcg__ Examination of
Water.... and ' Wastewater.
Sixteenth Edition, 1985,
as revised; Manual of
ground____ Water . Quality
Sampling Procedures. 1981,
EPA-600/2-81-160 ,
as
revised; Procedures Manual
for_____ Ground
Water
Monitoring at Solid Waste
Disposal Facilities. 1977,
EPA-53O/SW-611,
as
revised; or an equivalent
method as specified in the
attached Waste Analysis
Plan (Attachment I).
7
00 143535 OONF TDFNTTAl.
i
PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
I j'adequate! INADEQUATE i COMMENT
b) Records of monitoring information shall include:
i) The date, exact place, and time of sampling or measurements;
ii) The individual(s) who performed the sampling or measurements;
iii) The date(s) analyses were performed;
iv) The individual(s) who performed the analysis;
v) The analytical techniques or methods used; and
(vi) The results of such analyses.
DO 1 43536 CONFIDENTIAL
1
j 'ADEQUATE! INADEQUATE ICOMMEN'
PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
10. Retention _of_ Records.
The Permittee shall maintain records from all ground vater monitoring wells and associated ground water surface elevations for the active life of the facility and for the post-closure care period.
The Permittee shall retain records of all other monitoring information,
including all calibration
and maintenance records
and all original strip
chart
recordings
of
continuous monitoring
instrumentation,
_ and copies of all reports
S and records required by
this permit, for a period
of at least three (3)
years from the date of the
sample,
measurement,
report or record except ,
where otherwise required
by this permit, or by
order o-f
the
administrative authority.
The Permittee shall, for
the life of the permit,
maintain records of all
data used to complete the
application for this
permit and
any
supplemental information
submitted under
the
Hazardous Waste program of
Louisiana. These periods
may be extended by request
of the administrative
authority at any time and
are automatically extended
during the course of any
9
j DO 143537 CONFIDENTIAL
j 'ADEQUATE j INADEQUATE! COMMEJ.
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
unresolved
enforcement
action regarding this
facility.
11. Notices of Planned Physical Facility Changes.
The Permittee shall give notice to the administrative authority, as soon as possible, of any planned physical alterations or additions to the permitted facility,
in accordance with LAC 33:V.309.L.1.
12. Physical Facility after Modi f_i c a t 1 on or ' Construction.
For a new facility, the permittee may not treat, store, or dispose of hazardous waste; and for a facility being modified, the permittee may not treat, store, or dispose of hazardous waste in the modified portion of the facility until:
a) The
Permittee
has
submitted., to
the
administrative authority,
by certified mail or -hand
delivery, a letter signed
by the permittee and a
registered professional
engineer stating that the
facility
has
been
constructed or modified in
compliance
with
the
permit; and
b) The
administrative
authority has inspected
the modified facility and
finds it is in compliance
with the conditions of the
permit and issues an order
to proceed. The permittee
10
DO 143538 C0NFTD5NTIA!
'ADEQUATE INADEQUATE|COMMENT
PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
may
then
commence
treatment and storage of
hazardous waste.
13. Anticipated Noncomollance.
The Permittee shall give advance notice to the
administrative authority of any planned changes in the permitted facility or activity that may result in noncompliance with permit requirements.
14. Transfer of Permits.
This permit may be
transferred to a new owner
or operator only if it is
modified or revoked and
reissued pursuant to LAC
33:V.309.L.4,
321.B,
321.C.4, and 1531. Before
transferring ownership or
1 operation of the facility during the post-closure
care period, the Permittee
shall notify the new owner
or operator in writing of
all the requirements of
the LAC.
15. Compliance Schedules.
Reports of compliance or
noncompliance with, or any
progress reports on,
interim
and
final
requirements contained in
any compliance schedule of
this permit shall be
submitted no later than
fourteen
(14)
days
following each schedule
date.
16. Noncompliance Reporting.
The Permittee shall report
orally within twenty-four
(24)
hours
any
11
DO 143S39 CONFIDENTIAL
'ADEQUATE INADEQUATE (COMMENT
PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
noncompliance with the
permit that may endanger
human health or the
environment, except where
more
immediate
notification is required
by LAC 33:V.I Chapter 39
the
"Notification
Regulations and Procedures
for Unauthorized
Discharges" dated November
19, 1985 as amended.
This report shall include the following:
a) Information concerning the release of any hazardous waste that may endanger public drinking water supplies; and
b) Information concerning the release or discharge of any hazardous waste, or of a fire or explosion at the facility, that could
threaten the environment or human health outside the facility.
The description of the, occurrence and its cause shall include:i)
i) Name, address, and telephone number of the owner or operator;
ii) Name, address, and telephone number of the facility;
iii) Date,
12
DO 1.43540 CONFIDENTIAL
I "ADEQUATE INADEQUATE I COMMENT
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
time,
type of incident;
iv) Name
and quantity of materials involved;
v) The extent of injuries, if any;
vi) An assessment of actual or
potential hazard to the
environment and human
health
outside
the
facility, where this is
applicable; and
vii) Estimated quantity
and disposition
recovered material
resulted
from
incident.
of that the
17. Follow-up Written Report of Noncompliance.
The Permittee
shall
provide a written,
submission within five
(5) days after the time
the Permittee becomes
. aware of any noncompliance
which may endanger human
health or the environment.
However,
where more
immediate submission is
required by the
"Notification Regulations
and
Procedures
for
Unauthorized Discharges"
dated November 19, 1985,
the report shall be
submitted in accordance
with those regulations.
The written submission
shall
contain
a
13
DO 1,43541.
C. ONFTDFNTTAI.. I
`ADEQUATE INADEQUATE COMMENT
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
description
of
noncompliance and
the
its cause;
the
periods
of
noncompliance (including
exact dates and
times);
whether the noncompliance has been corrected;
and
if not,
the
anticipated time it is
expected to continue;
and steps taken or planned to reduce, eliminate, and prevent recurrence of the noncompliance.
The Permittee need not
comply with the five (5)
day
written
notice
requirement if the
administrative authority
waives the requirement and
the Permittee submits a
written report within,
fifteen (15) days after
the time the Permittee
becomes aware of the
circumstances
18. Other Noncompliance.
The Permittee shall report all other instances of noncompliance not otherwise required to be reported above, at the time required monitoring reports are submitted. The reports shall contain the information listed in Section II..16 above.
19 Other Information.
14
00 14354?
I CONFTDFNTTAI.
"ADEQUATE INADEQUATE COMMEN
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
Whenever the Permittee
becomes aware that it failed to submit any relevant facts in the permit application, or that it submitted incorrect information in a permit application, or in any report to the administrative authority, the Permittee shall promptly submit such facts or information.
20. Signatory. Requirement
All applications, reports
or other information
submitted to
the
administrative authority
shall be signed and
certified according to LAC
33:V.507, 509, 511 and
513.
21. ssh.ed.uie_ gf_camp,U&n<z^i
a) The
proposed
leak
detection system for the
Northwest Landfill, as
approved by
the
administrative authority^,
(Enclosure) shall be'
installed within one-
hundred (180) -days after
issuance of this permit
and
will be identified as LD2, and LD-3.
All wells must
be
maintained so that surface
infiltration is prohibited
and
ground water samples are
generated with a water
quality of five (5) or
less
nephelometric
turbidity units (N.T.U.).
15
00 143543 CONFIDENTIAL
I
I
'ADEQUATE INADEQUATE I COMMENT
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
If turbidity in ground
water
samples
are
attributable to natural
hydrogeological conditions
peculiar to the screened
zone, and a water clarify
of five (5) units is not
achievable, the Permittee
must demonstrate to the
satisfaction of the
administrative authority
that turbidity of the
water samples will not
compromise the validity of
the analyses.
b) The Permittee must have an approved assessment plan for the chloride plume in the Chlorine Plant area on file with the administrative authority within sixty (60) days after the issuance of this permit, and
implement a corrective action or mitigation program within sixty (60)
days after conclusion of the assessment phase, administrative authority, as required by LAC:33.V.105JI.
c) Within thirty-(30) days of the effective date of this permit, the Permittee shall resubmit the Waste Analysis Plan (WAP) with Exhibits 45, 4, NWLF-1 and NWLF-1.
The exhibits must list the specific SW-846 methods to be used or
the permittee shall
petition
the
administrative authority
as required by
LAC:33:V.105H.
This
16
DO 143544 CONFIDENTIAL
"ADEQUATE INADEQUATEICOMMENT
DOW, PLAQLfEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
resubmitted Waste Analysis Plan must receive approval from the administrative authority before being incorporated in the Permit as Attachment 1.
In addition# this Waste
Analysis Plan shall be
revised to include a list
of the waste which will
not be
sampled and
analyzed.
Reasons for omitting these wastes from sampling and analysis must be given.
d) The Permittee shall adhere to the conditions and recording of incinerator monitoring as continued in Attachment 10 "Compliance
Schedule for Incinerator Monitoring."
22. Updated Documents To Be
Submitted
Prior To
Operation.
a) Within thirty (30) days of the effective date of this:, permit, the Permittee' shall submit updated financial liability coverage documents.
b) Within forty-five (45)
days of the effective date
of this
permit# the
Permittee shall submit
documentation of
acceptance or denial of
arrangements with local
authorities.
23. Documents To Be Maintained at Facility Site
a) The
Permittee
shall
maintain at the facility,
until closure is completed
17
00 143545
C0NFTDENTIAI I
I
'ADEQUATE INADEQUATEjCOMMEN'
PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
and certified by an
independent
registered
professional engineer, the
following documents and
amendments, revisions, and
modifications to these
documents. Any revision
or changes shall be
submitted with the annual
report.
i) Waste
analysis
plan
submitted in accordance
with LAC 33 :V. 1519 (see
Attachment 1).
ii) ccontingency Plan submitted in accordance with LAC 33 :V. 1513 (see Attachment 3).
iii) Closure plan submitted in
accordance
with
LAC
33:V.3511 (see Attachment
5) .
*
S iv) Any post-closure care requirements that may be
required initially or
through permit
modifications
in
accordance
with
LAC,
33:V.3523.
v) Cost estimate for facility
closure care submitted in
accordance
with
LAC
33:V.3705 (see Attachment
6) .
vi) Any post-closure cost
estimate that may be
required initially or
through permit
modifications
in
accordance
with
LAC
33:V.3709.
vii) Training plan and the training records required by LAC 33 :V. 1515 (see Attachment 2).
18
DO 143546 CONFIDENTIAL
I
- a&>
!i
1
`ADEQUATE INADEQUATE COMMENT
>
e<t
viii)
Operating
record
z required by LAC
3 3:V . l5 2 9
and
2115. D), and detailed
H in Attachment 7. wJCO ix) Inspection schedules
developed in accordance D with LAC 33SV.517.G and
zo 1509.B (see Attachment 8).
tj b) All proposed amendments.
oCO.
z
revisions
and
modifications to any plan
H
H
or cost estimates required by this permit shall be
a: submitted to the CDL3. administrative authority
U for approval.
Z
3 24. Annual Report.
O<*3' An annual report must be
submitted covering all
sOo
hazardous waste units and their activities during
the previous calendar year
as required by LAC
33:V.1529.D.
25. Manifest
The Permittee, shall report manifest discrepancy reports and -unmanifested waste as per LAC
33:V.309.L.8 and 9.
26. Emissions.
Emissions
from
any
hazardous waste facility
must not violate the
Louisiana Air Quality
Regulations.
i
27. Waste Discharaes.
Waste discharges from any hazardous waste facility must not violate the
19
DO 143547 CONFTDFNTIAI...
! II
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
I 'ADEQUATE INADEQUATEiCOMMENT
Louisiana Water Quality Regulations,
28. Non-Llsted Hazardous Waste facilities.
This permit is issued for
those hazardous waste
facilities listed in
Section IV (Permitted
Facilities).
If the
Permittee determines that
an unpermitted hazardous
waste facility exists, the
permittee must immediately
notify the administrative
authority in accordance
with Section II.E.19 of
the
General
Permit
Conditions.
29. Confidentiality.
Information submitted in the permit application as "Confidential" shall be acted upon according to LAC 33.-V.319.
30. Compliance With Land Disposal Restrictions
The Permittee shall comply with those LaRd disposal
restrictions set forth in La. R.S. 30:1141:1 an<Tall
regulations promulgated thereunder.
20
DO 1.43548
i CONFIDENTIAL
`ADEQUATE INADEQUATE j COMMENT
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
III. GENERAL CONDITIONS
FACILITY
A. DESIGN AND OPERATION OF ALL FACILITIES
1. The
Permittee
shall
maintain and operate all
facilities to minimize the
possibility of a fire,
explosion,
or any
unauthorized sudden or
non-sudden release of
hazardous
waste
or
hazardous waste
constituents to air, soil,
or water that could
threaten human health or
the environment.
2. The Permittee may receive only those off-site wastes which are listed in Attachment 1, Exhibit 1-Z and
which are generated:
by other Dow Chemical USA subsidiaries or,
by a company in which / Dow Chemical USA owns
a minimum of fifty percent (50%) of the voting stock or,'
- by any governmental
entity
and
as
approved by the
a d ministra tiv e
authority or,
When a Dow Chemical
USA product was
spilled while in
transit to a customer
and
becomes
a
hazardous waste (as
defined in LAC
33:V.109) or,
21
DO 143549 CONFTDFNTTAI.
PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
`ADEQUATE INADEQUATE ICOMMEJ
- hazardous waste from
CERCLA corrective
actions where Dow
Chemical USA is a
Potential ly
Responsible
Party
(PRP).
B. GENERAL WASTE ANALYSIS
The Permittee shall follow the procedures described in the Waste Analysis Plan (Attachment 1) and furnish the following updated
information.
1. The Permittee shall review ,, the waste analysis plan annually and
report to the
administrative authority
within thirty (30) days
after such review whether
any revision is required
to stay abreast of changes
in EPA methods and/or
State
regulatory
provisions.
The Permittee shall make, all necessary revisions within thirty (30) days following its report.
2. Annually, the Permittee
shall submit a report,
certified as provided for
in LAC 33:V. 513, reviewing
and
evaluating the
performance
of the
laboratory QA/QC program.
3. The Permittee shall at a
minimum annually
recharacterize
all
hazardous waste streams
shipped offsite or
treated and disposed of onsite.
DO 143550 CONFIDENTIAL
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
'ADEQUATE INADEQUATE I COMMENT
This recharacterization shall provide a means of detecting changes in concentrations of chemical constituents, appearance of new constituents or variations in physical properties.
This recharacterization shall include laboratory analyses for components of the waste.
The results of this recharacterization shall
be summarized in the Permittee1 s Annual Report.
C. SECURITY
The Permittee shall comply
with
the
security
provisions of LAC 33:V.513
as specified in Attachment
9.
D. GENERAL
INSPECTION
REQUIREMENTS
The Permittee shall follow the inspection schedule in Attachment 10.
j '
The Permittee'shall remedy any deterioration . or malfunction discovered by an inspection as required by LAC 33:V.1509.C. Records of inspections shall be kept as required by LAC 33:V.1509.D.
The inspection schedule
shall
include
the
regulatory requirements of
LAC 33:V.1905, 2109, and
3119.
E. PERSONNEL TRAINING
23
DO 140551 i OONFTDFNTTAl
'ADEQUATE INADEQUATE I COMMENT
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
The Permittee shall conduct personnel training as required by LAC 33 :V. 1515. A. This training program shall follow the outline in Attachment 2.
The Permittee shall maintain all training documents and records as required by LAC 33:V.1515 D.
F. GENERAL REQUIREMENTS FOR IGNITABLE, REACTIVE, OR I NCOMPATIBLE WASTE
The Permittee shall take precautions as required by LAC 33:V.1517 to prevent accidental ignition or reaction of ignitable or reactive wastes.
G. LOCATION STANDARDS
1. The
Permittee
has
furnished evidence that it
is in compliance with
seismic standards as
required by LAC
33 :V. 517. T.2
2. The Permittee __ shall not
place any hazardous waste
unit on any portion of the
property that lies within
the 100 year floodplain
(as identified - in the
Flood Insurance Rating
Map) unless such areas are
raised above this flood
level or other means
(e.g.,
levees)
are
provided to protect such
areas from washouts,
overtopping by wave
action, soil erosion or
other effects of such a
flood as required by LAC
33:V.1503.B.3.
24
DO 14355? CONFIDENTIAL
I
ADEQUATE INADEQUATE!COMMENT
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
Such site improvements shall be certified by
licensed professional engineers and approved by LDEQ prior to any hazardous waste and/or hazardous waste facilities being placed thereon.
H. PRECIPITATION RUN ON AND RUN OFF
The Permittee must provide
for the containment and
treatment of run-on and
run-off resulting from a
rainfall of at least
twelve
(12)
inches,
occurring during a period
of twenty-four hours in
conformity with locally
available records of a
twenty-four (24) hour
rainfall as per LAC
33.-V.1503.B.2.
I. HURRICANE EVENTS
The Permittee shall initiate those applicable port ions of the Contingency Plan during a' hurricane as well as appropriate* ,, actions required by LAC 33:V. 1597, 1509, and 1511.
J. PREPAREDNESS PREVENTION
AND
1. Required Equipment
At a minimum, the Permittee shall install
and maintain the equipment set forth in the Contingency Plan, Attachment 4, as required by LAC 33:V.1511.C.
25
DO 143553 OONFIOFNTTaI.
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
`ADEQUATE INADEQUATE!COMMENT
2. nesting and Maintenance of Equipment The Permittee shall test and maintain the equipment specified in the above permit condition to insure its proper operation in time of emergency.
3. Access to Communications or Alarm Systems The Permittee shall maintain access to the communications or alarm system as required by LAC 33:V.1511.E.l and 1511.E.2.
4. Required Aisle Space At a minimum, the Permittee shall maintain adequate aisle space as required by LAC 33:V.1511.F.
26
00 143554 C0N5TDFNTIAI
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
`ADEQUATE INADEQUATE I COMMENT
5. Arrangements with Local Authorities
The
Permittee
shall
document in the annual
report
that
the
requirements of LAC
33:V. 1511.G have been met.
This documentation shall
include those state and
Local agencies present and
those facilities and
operations covered.
Documentation of annual
written
renewal
of
arrangements with state
and Local agencies shall
also be included in this
report.
'
K. Contingency Plan
1. Implementation of Plan
The
Permittee shall
immediately carry out the
provisions of the
Contingency Plan,
Attachment 4, and follow
the emergency procedures
described by LAC.
33: V. 1513 .F whenever there
is a fire, explosion, or
release of hazardous waste
or hazardous
waste
constituents that threaten
or could threaten human
health or the environment.
2. copies of Plan
The Permittee shall comply
with the requirements of LAC 33:V.1513.C.
3. Amendments to Plan
The Permittee shall review and immediately amend, if necessary, the Contingency
27
I
00 143555 CONFTDFNTTAl
`ADEQUATE INADEQUATE ICOMME
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
Plan, as required by LAC 33 : V. 1513 .D.
4. Emergency Coordinator
The Permittee shall comply with the requirements of LAC 33iV.l513.E concerning the emergency coordinator.
L. MANIFEST SYSTEM
Use of the Manifest System
The Permittee shall comply
with
the
manifest
requirements of LAC 33:V.
Chapter 9.
M. RECORDKEEPING REPORTING
AND
1. Operating Record
The' Permittee
shall
maintain a written
operating record at the
facility in accordance
with LAC 33:V.1529.A,
1529.B,
1529.C. ,
and
Attachment 7.
2. Annual Report
*
The Permittee'sliall comply with the annual report requirements of LAC 33:V.1529.D.
N. CLOSURE/POST-CLOSURE
1. The closure plan shall include the following responses by the Permittee to LAC 33 :V. 1915, 2117, 2521, 3503, 3505, 3507, 3509, 3511, 3513 and 3515.
a) Closure
Plan. The
Permittee shall close the
facility in accordance
28
i
i DO 14355ft ' CONFTDFNTTAL.
1
'ADEQUATE INADEQUATE ICOMMEN
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
with the closure plan, Attachment 5.
b) Amendment to Closure
Plan. The Permittee shall
amend the closure plan
where
necessary,
in
accordance with 3511.C.
Any modification shall be
subject to LAC 33:V.321.
c) N o t_i f Icatl Q.n_ of Closure. The Permittee shall notify the Regional Administrator at least 180 days prior to the date he expects to begin closure.
d) Time . Allowed- _ F_or -
closure. After receiving
the final volume of
hazardous waste, the
Permittee shall treat or
remove from the site all
hazardous waste
in
accordance with
the
schedule specified in the
closure plan. Attachment
5. After receiving the
final volume of hazardous
waste, the Permittee shall
complete 'closure.,
activities in accordance '
with
the
schedule
specified in"the closure
plan, Attachment 5.
e) Disposal
or
Decontamination
of
Equipment. The Permittee
shall decontaminate
(and/or) dispose of all
facility equipment in
accordance
with
the
closure plan. Attachment
5.
f) Cert_if.l_cat.lon of Closure. The Permittee shall certify that the facility has been closed in accordance with the
29
DO 143557 CONFIDENTIAL
I
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
`ADEQUATE INADEQUATE ICOMMEN'
specifications in the closure plan as required by LAC 33:V.3517.
9) Inventory at Closure. The
Permittee
shall
be
responsible for closure
cost based upon the
following maximum
permitted
facility
inventories:
30
DO 143558 i CONFIDENTIAL
rang
T-400 T-410 D-13 D-15 D-92A D-700 D-701 T-749 V-201 T-130 T-135
T-250 T-255 T-401 SU-130 SU-265
(1) TANKS (14) AND SUMPS (2)3
SERVICE
Organic Waste Organic Waste Organic Waste Organic Waste Organic Waste Organzic Waste Organic Waste Organic Waste Organic Waste Organic Waste Water Slop Oils/Suspended
Solids Waste Lubricating Oils Flammable Liquids Slurry Feed Secondary Containment Secondary Containment
MAXIMUM PERMITTED CAPACITY GALLONS
vinyl Plant Vinyl Plant Solvents Plant Solvent Plant Solvent Plant Solvent Plant Solvent Plant Solvent Plant Solvent Plant Environmental Operations Environmental Operations
#>*
Environmental Operations Environmental Operations Environmental Operations Environmental Operations Environmental Operations
49,300 375
2,500 20,000
370 2,800
50 12,000 32,000 20,000
20,000 20,000 20,000 11,300 17,000 22,000
CONTAINER STORAGE
1 2 3 4 5
(2) CONTAINER STORAGE (5)
SQUARE FOOTAGE
MAXIMUM VOLUME OF 45 SALLCff J-ACKS
1,400 2,100 4,000 1,500 7,750
11,700 18,000 - 27,000 13,500 -5-8.500
TOTAL VOLUMES
128,700
MAXIMUM LARGE CONTAINER GALLONS
;20,000 JL2_i_0LQ 40,000
(3) IMPOUNDMENT (1)
IMPOUNDMENT
LOCATION
i) Chlor-Alkali II Block 35
MAXIMUM PERMITTED CAPACITY GALLONS
2,000,000
31
DO 143559 CONFTDENTTAl
(4) INCINERATORS (3)
i) Solvents Plant (Liquid Injection) Incinerator
ii)
Vinyl II Plant (Liquid
Injection)
Incinerator
iii)
Environmental Operations (Rptary-Kiln) Incinerator
(5) LANDFILLS (2)
i) Northwest Landfill (NWLF)
78.5 acre feet
ii) Block 80 POST-CLOSURE
81.2 acre feet
The Post-Closure Plan shall include responses by the
Permittee to LAC 33:V.2521, LAC 33:V, Chapter 35
Subchapter B and is designated as Attachment, 5. I
a) Inventory of Post-Closure
1
The Permittee shall be responsible for post-closure cost for the following permitted facilities.
(1) IMPOUNDMENT (1)
IMPOUNDMENT
LOCATION
MAXIMUM PERMITTED CAPACITY GALLONS
Chlor-Alkali II
Block 35
2,000 ,000
(2) LANDFILLS (2)
i) Northwest Landfill (NWLF) 78.5 acre f et
ii) Block 80
81.2 acre feet
b) Amendments to Post-Closure Plan
The Permittee shall amend the Post-Closure Plan when necessary, in accordance with LAC 33:V.3523.D. Any modifications shall be subject to LAC 33:V.321.
32
143560 CONFIDENTIAL
t
"ADEQUATE INADEQUATE I COMMENT
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
0. COST ESTIMATE FOR FACILITY CLOSURE/POST-CLOSURE
1. The Permittee's must maintain cost estimate for closure of all facilities as required by LAC 33:V.3705.A. (Attachment
6)
2. The
Permittee
shall
maintain and adjust the
closure cost estimate for
inflation, as specified in
LAC 33:V.3705.B, 3705.C,
and
for
other
circumstances
that
increase the cost of
closure.
3. The Permittee must adjust
the closure cost estimate
within thirty (30) days
after approval by the
administrative authority
of any request to modify
the closure plan in
accordance
with
LAC
33:V.3705.C.
The
Permittee shall consider
the impact
of any,/
inventory and/or process
changes on . -the closure
cost estimate. ~
4. The closure cost estimate must equal the cost of closure at the point in the facility's operating life when the extent and manner of its operation
would make closure the most expensive.
The closure cost estimate shall be based on the maximum permitted inventory of each facility as specified in Section III.0.7 of this permit.
33
DO 143561 CONFTDFNTT Al
'ADEQUATE!INADEQUATE ICOMME
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
5. Th
Permittee's post
closure cost estimate of
all facilities as required
by LAC 33 :V. 3709. A is
included in Attachment 6.
6. The Permittee
shall
maintain and adjust the
post closure cost estimate
for inflation,
as
specified in LAC
33:V.3709.B.
7. The Permittee must adjust the post-closure cost estimate within thirty (30) days after approval by the administrative ,, authority of any request to modify the Post-Closure Plan in accordance with LAC 33:V.3709.C.
The Permittee shall consider the impact of any inventory and/or process changes on the post closure cost estimate.
8. The post-closure cost
estimate must equal the
annual post-closure cost./
multiplied by the number
of years in- the post
closure
period
as
specified ` in 'LAC
33:V.3521.A.
9. Any closure/pos.t-closure modifications are subject to LAC 33.-V.321.
P. FINANCIAL ASSURANCE FOR FACILITY CLOSURE1
1. Financial assurance, as
required by LAC 33:V.3707
must be established sixty
(60) days prior to the
date on which waste is
first
received
for
treatment, storage, or
34
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
'AD EQUATE I NAD EQUATE! COMMEN"
disposal. The Permittee
must
also
increase
financial assurance for
closure when required by
LAC 33:V.3705.B, and
3705.C.
2. The Permittee shall have
financial assurance for post-closure as required by LAC 33:V.3709. The financial assurance for post-closure shall be established sixty (60) days prior to the date on which any hazardous waste is first received for treatment# storage, or ,, disposal.
Q. LIABILITY REQUIREMENTS
1. The Permittee shall have
and maintain liability
coverage for non-sudden
accidental occurrences as
specified in the LAC
33:V.3715 in the amounts
of $5,000,000 per
occurrence and $10,000,000
annual
aggregate,
exclusive of legal defense ' j
costs.
Upon
acceptance
of
certification ' of 'the
surface
impoundment
closures,
the
administrative authority
may consider revisions to
the liability coverage
requirements as required
by LAC 33:V. Chapter 37.
R. INCAPACITY OF THE PERMITTEE
The Permittee shall comply
With
LAC
33sV.3717
whenever bankruptcy is
initiated for Permittee
or its institutions
DO 143563 CONFTDFNTIAt
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
`ADEQUATE INADEQUATE<COMMENT
providing financial assurance. If insurance is used for compliance with LAC 33 :V. 3715, the Permittee shall immediately notify the administrative authority if the insurance company is placed in receivership.
I 36 lI
DO 143564 CONFIDENTIAL
IV. PERMITTED FACILITIES
The following facilities are permitted to be used in hazardous waste service:
A. TANKS (14) AND SUMPS (2)
TANK
SERVICE
LOCATION
MAXIMUM PERMITTED CAPACITY GALLONS
T-400 T-410 D-13 D-15 D-92A D-7Q0 D-701 T-749 V-201 T-130 T-135
T-250 T-255 T-401 SU-130 SU-265
Organic Waste Organic Waste Organic Waste Organic Waste Organic Waste Organic Waste Organic Waste Organic Waste Organic Waste Organic Waste Water Slop Oils/Suspended
Solids
Waste Lubricating Oils Flammable Liquids Slurry Feed Secondary Containment Secondary Containment
Vinyl Plant
49,300
Vinyl Plant
375
Solvents Plant
2,500
Solvent Plant
20,000
Solvent Plant
370
Solvent Plant
2,800
Solvent Plant
50
Solvent Plant
12,000
Solvent Plant
32,000
Environmental Operations20,ooo
Environmental Operations
20,000
Environmental operations2 0,000
Environmental 0perations20,ooo
Environmental Operationsll,300
Environmental 0perationsl7,000
Environmental Operations22,ooo
B. CONTAINER STORAGE (5)
The following container storage areas are permitt d to store hazardous waste in properly labeled and sealed containers which have been specified for this service and are compatible with the waste being stored.
The location of this facility is in the Environmental Operations (1-200) area of the production complex adjacent to the incinerator.
The container storage is to be conducted in one (1) covered area and four (4) outside curbed areas as indicated below:
37
DO "14 3565 CONFIDENTIAL
CONTAINER STORAGE AREA
SQUARE FOOTAGE
1 1,400
2 2,100 3 4,000 4 1,500 5 7,750
TOTAL VOLUMES
C. IMPOUNDMENTS (1)
MAXIMUM VOLUME OF 45 GALLON PACKS
11,700 18,000 27,000 13,500 .SflcgQg
128,700
MAXIMUM LARGE CONTAINER EALLQNS
20,000 i !20.000
40,000
The Permittee is allowed to utilize the following impoundment for storing hazardous waste until their closure as outlined in the attached closure plan (Attachment 5).
IMPOUNDMENT
LOCATION
MAXIMUM PERMITTED CAPACITY GALLONS
1. Chlor-Alkali II
Block 35
2,0p0,000 i
Prior to closure the Permittee will not place any
hazardous waste in these impoundments which are
incompatible, reactive, or ignitable as required by LAC
33:V.2913, 2915 and 1517.
38
DO 143566 CONFIDENTIAL
I
"ADEQUATE INADEQUATE ICOMMEN
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
D. INCINERATORS (3)
The Permittee is allowed to.utilize and operate three (3) incinerators to burn hazardous waste stored either in ' the tanks permitted under IV.A. or the container storage areas listed under IV.B.
1. Solvents Plant (Liquid - Injection) Incinerator
2. Vinyl II Plant (Liquid - Injection) Incinerator3
3. Environmental Operations (Rotary-Kiln) Incinerator
E. LANDFILLS (2)
1- Northwest Landfill (NWLF)
38
DO 143567 CONFTDFNTTAl.
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
'ADEQUATE INADEQUATE IC0MME
The Permittee is allowed to operate an existing landfill designated as the Northwest Landfill (NWLF) until the remaining reserve capacity has been utilized. Upon cessation of operations it will be closed according to the closure plan (Attachment 5).
The Northwest Landfill shall only be
utilized to dispose of Environmental
Operations
recovered
incinerator
particulate, ash, and on-site generated
asbestos.
This landfill is constructed in two (2)
sections.
Maximum capacity is
approximately nine 78.5 acre feet
(127,000 cubic yards). It will not be
expanded to include any additional area.
,
Post-closure care shall be according to the plan included as Attachment 5.
2. Block 80 Landfill
The Permittee will be allowed to construct a landfill in their Block 80 Environmental Operations facility.
It will be in an area some 440 feet wide and 600 feet long and is to ultimately.' contain approximately no more than 131,000 cubic yards (81.2 acre feet) of fill material.
The Block 80 Landfill shall only be
utilized to dispose of Environmental
Operations
recovered
incinerator
particulate and ash.
39
i
I
DO 143568
CONFIDENTIAL
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
'ADEQUATE INADEQUATE I COMMENT
V. PERMIT CONDITIONS APPLICABLE TO PERMITTED FACILITIES
A. TANKS (14)
1. CONDITIONS
a) The conditions related to treatment and/or storage of hazardous waste shall be limited to those tanks listed under Part IV, Permitted Facilities, together with all associated piping, pumps, instruments, containments, and vent controls.
b) The permittee shall have and maintain, or provide secondary containment for all
tanks (14) in accordance with LAC 33:V.1907.
c) The Permittee shall store ignitable, reactive, or incompatible wastes only in accordance with LAC 33:V.1517, 1917, and 1919.
.2 OPERATION AND MAINTENANCE OF EXISTING
TANKS
a) The Permittee will maintain the existing
permitted tanks according to the design
code specified for each tank as listed in
Table 1.
.
DO 143569 CONFIDENTIAL
TANK
TYPE
T-400
T-410 D-13 D-15
D-92A D-700 D-701
T-749 V-201 T-130 T-135 T-250 T-255 T-401 Sump 130 Sump 265
Horizontal Horizontal Vertical Vertical Horizontal Horizontal Vertical Vertical Vertical Vertical Vertical In Ground In Ground
TABLE 1
SERVICE AREA
Vinyl Plant Vinyl Plant Horizontal Solvents Plant Solvent Plant Solvent Plant Solvent Plant Solvent Plant Solvent Plant Solvent Plant Environmenta1 Operations Environmental Operations Environmental Operations Environmental Operations Environmental Operations Environmental Operations Environmental Operations
CAPACITY GALLONS
49,300 375
2,500 20,000
370 2,800
50 12,000 32,000 ' 20,000 20,000 20,000 20,000 . 11,300 ; 17,ooo 22,000
b) The Permittee will maintain the shell thickness of
the permitted tanks according to the following Table 2 and not exceed the listed operating conditions.
DESIGN CODE
API-650 Field Fabricated ASME-Sec. 8-Div. 1 ASME-Sec. 8-Div. 1 ASME-Sec. 8-Div. 1 ASME-Sec. 8-Div. 1 Plastic Lined Pipe ASME-Sec. 8-Div. 1 ASME-Sec. 8-Div. 1 API-650 API-650 API-650 API-650 API-650
DO 1 4 3 5 7 0
CONFTDFNTT
<x
TANK
MAXIMUM PERMITTED ' CAPACITY GALLONS
DESIGN SHELL THICKNESS finches)
T-400 T-410 D-13 D-15 D-92A D-700 D-701 T-749 V-201 T--130 T-135 T--250 T-255 T-401
SU 130 SU 265
49,300 375
2,500 20,000
370 2,800
50 12,000 32,000 20,000 20,000 20,000 20,000 11,300
17,000 22,000
,0.25 0.50 0.1875
20,000
0.500 0.3125 Teflon Lined 1.000 0.500 0.3125 0.3125 0.3125 0.3125 0.375
In Ground Tank In Ground Tank
TABLE 2
PRESSURE RATING PSI & TEMP OF
PERMITTED MINIMUM SHELL THICKNESS finches)
ATMS 0 150 ATMS @150 50 PSI % 230 121 PSI @ 230 100 PSI @ 100 75 PSI @ 100 150 PSI @ 100 75 PSI @ 100 25 PSI @ 100 . ATMS @ 200; ATMS @ 200 ATMS @200 ATMS @200 ATMS @ 100
.1875 .1875 .1875 .1875 .1875 .1875 .1875 .1875 . 1875 .1875 .1875 .1875 .1875 .1875
I `ADEQUATE INADEQUATE I COMMENT
O<7k>
oc r<s
<
CHO
uUJ u sOUHu--ci oto*
UJ
O'
<
CL
co
c) Tank Inspection and Testing and Maintenance
f
(1) The Permittee shall inspect while the facility is in operation-,- -all tanks, piping, valves, vent controls, .and associated instrumentation at least daily to detect any exterior signs of corrosion, cracks, or leaks as required by LAC 33:V.1911.
Such inspections shall be duly logged in the operating record and any equipment failures, and resulting leaks or spills described fully in the annual report.
(2) The Permittee's results of the most recent ultrasonic or equivalent tests for existing hazardous waste storage tanks (Attachment 8) indicates they meet the requirements of the specified permitted wall thicknesses as required by the
42
00 143572 CONFTDFNTTAi
DOW, PLAQUEMINE PERHTT INSPECTION CHECKLIST JANUARY, 1990
I
'ADEQUATE INADEQUATE ICOMMEN
design specifications (API or ASME) under which they were built.
Such information shall be updated biennially and made a part of this permit as Attachment 8.
(3) The Permittee will conform, where applicable, to the appropriate sections of the API Code 510 (latest edition) for maintenance inspection, rating, repair, and alteration of all pressure vessels and tanks (API Code 510) and atmospheric and/or low pressure storage vessels and tanks (Chapter XIII of the API Code). Such codes establish the procedures for repairing sections tanks, nozzles or other openings and are specifically detailed in the above listed API Codes.
i
(4) If any shell thickness measurements for arpas of the tank as defined in Section V. .2.C)(2) or (3) (above) are less than those listed in Table 2 of this Permit Section such tank or vessel shall be removed from service and emptied of hazardous waste.
The tank or vessel shall be repaired or replaced as described in Section V.A.2.C)(3) (above) or equivalent before service can be re-established for, hazardous waste.
d) Operation of All Tanks
(1) The Permittee shall prepare daily log sheets to record, where applicable, the following operating and inspection information for all tanks and related vessels.
i) All monitored information including
temperatures,
pressures,
levels, and
pump flows into and out of these tanks.
43
D0 143573 CONFTDENTTAl
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
`ADEQUATE INADEQUATE | COMME:
ii) Overfilling controls to ensure they are in working order.
iv) Routine inspection of levels for those tanks not having control devices.
(2) The Permittee will prepare daily log sheets to record, where applicable the following inspection information for all tanks and related vessels.
44
DO 143574 CONFTDFNTT Al
I 'ADEQUATE INADEQUATE I COMMENT
CmTl
>0<
i) The results of visible inspection of all tanks and associated piping, valves, fittings, instruments, and vent control
< and relief systems.
Hto
ii) This log shall also include inspection of the containment areas for leaks or spills
-J as well as the dikes of containment walls
Utu for structural integrity.
(3) Hazardous waste storage tanks shall be
Mo covered and shall not be vented directly
UHW a.
to
to the atmosphere if the tanks are used to store, or if a possibility exists that they may be used to store, volatile or
malodorous waste.
tseue.
a.
(4) The Permittee shall not store wastes which are incompatible with the tank
zw
materials of construction which would cause accelerated rates of corrosion as
w evidenced by frequent maintenance and
=3 O'
repair. Such evidence must be corrected
< as required by LAC 33:V.1909.
a.
e) Operation of Ancillary Facilities
oo
The Permittee must conform to the
following permit conditions for Sumps 130
and 265.
(1) The Permittee must report the results of./ a leak test, and internal inspection as prescribed by LAC 33:V.1903.3.5.b).
(2) The Permittee must respond to any 16aks or spills as required by LAC 33:V.1913.
(3) Any spilled material or material trapped in sumps that is a hazardous waste or that will be disposed of as a hazardous waste must be cleaned up in a timely manner as required by LAC 33:V.1505.C.3.
f) Closure
The Permittee shall close all tanks in accordance with Section III.N. of this permit and the Closure/Post-Closure Plan, Attachment 5.
45
^D 143575 C0NFTdfnttal
l
'AD EQUATE I NAD EQUATE! COMME
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
B. CONTAINER STORAGE
1. Requirements for Containers
a) The storage of containers containing hazardous waste will be on pallets and
shall not be more than the equivalent of two (2) fifty five gallon drums in height
and no more than the equivalent of four (4) fifty five (55) drums per tier on the pallet and conform to LAC 33:V.2109.B. and 1511.F.
b) The Permittee must maintain the conditions of all containers in accordance with LAC 33:V.2103.
c) The Permittee must use containers which are compatible with the waste as required by LAC 33:V.2105.
d) The Permittee must manage the containers in accordance with LAC 33:V.2107.
2. Requirements for Container Storage Area
a) The Permittee will remove any spilled or leaked waste and accumulated stormwater in a timely manner to prevent area and potential ground water contamination per, LAC 33:V.2111.B.5. and 6.
All discharges from the - five (5) container storage areas shall be through a NPDES permitted outfall.
b) The Permittee must maintain those records and documents required by LAC 33iV,1515 for the implementation of the Contingency Plan for the five (5) container storage areas.
c) The Permittee must inspect, at least weekly, the containment areas in accordance with LAC 33:V.2109 and 1509.
Results of such inspections must be placed in the operating log and any incidence involving leaking containers
46
DO 143576 CONFIDFNTIAl
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
`ADEQUATE INADEQUATE iCOMMEl'
and spilled materials detailed in the annual report.
3. General Requirements
a) The Permittee must insure that all personnel receive initial and continued training to insure compliance with LAC 33:V.1515.
b) The Permittee must control and report all point source discharges according to LAC 33.-V.1505.
c) The Permittee must assure compliance with LAC 33:V. 1517 and 2115 with respects to ignitable, reactive, or incompatible waste.
d) The Permittee must assure compliance with respect to LAC 33:V.1525 which relates to emergency response.
c. IMPOUNDMENTS
Even though the Permittee was issued a closure permit for the Chlor-Alkali II impoundment it is anticipated that will be utilized as an operating facility at the time of issuance of the draft permit. Therefore, the following conditions are included in this draft permit for , operation of this facility prior to actual closure or until . no further hazardous waste is placed in'it.
1. The operating volume of the Chlor-Alkali II impoundment has been set forth in Section IV,C.
.2 The Permittee shall endeavor to keep the
operating levels of this impoundment at as practical a minimum as possible. At no time will the level of this impoundment exceed two (2) feet of freeboard measured at the lowest point of the containment dikes.
Maintenance of this minimum level shall be by routine inspections,
47
DO 143577 C.ONFTDENTTAl
I
'ADEQUATE INADEQUATE I COMMENT ooo>
>fl
the results of which shall be placed in an inspection (operating) log once daily.
<
< Any major diversion from normal
*"5
operations and levels
shall be
incorporated in the annual report.
CO
pS An accurate and readable gauge shall be j within this impoundment to indicate the
freeboard level.
3. The Permittee shall further limit the
UaEw.w
impoundment level when necessary to prevent overtopping as a result of normal or abnormal operations, and severe wind
and resulting potential wave action.
H-4 cz
4. The Permittee shall maintain no less than
coucu
two (2) pumps in working order for continuous removal of waste waters from the impoundment.
=w> O' <
The routine inspections of these pumps, piping and instrumentation shall be
& documented an inspection log sheets.
oo
5. The integrity of surroundingimpoundment dikes shall be examined according to the
inspection schedule and comments recorded
in the operating record.
6. The Permittee shall close the Chlor- , Alkali IX impoundment as set forth in the*' closure plan.
7. The Permittee shall not place ignitable or reactive waste in this surface impoundment.
D. INCINERATORS
1. General Requirements Which Apply To All Three (3) Incinerators
The Permittee shall operate and maintain each of the three (3) permitted incinerators to meet the following performance standards.
a) The Permittee will operate each of the three (3) incinerators to achieve minimum destructive and removal efficiencies
48
00 1.435 78 CONFI DENT T A!
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
'ADEQUATE INADEQUATE ICOMMEN'
(DRE) of 99.99% for each principal
organic hazardous constituent (POHC) as
defined in Table I of LAC 33:V. Chapter
31 and other components listed in LAC
33 :V. Chapter 49.
DRE shall be
determined by using the method specified
in LAC 33:V.3111.A.1.
b) The Permittee will control hydrogen chloride (HCl) emissions such that the rate of emission from each stack is no greater than the larger of either four (4) pounds per hour or one percent (1%) of the HCl in the stack gas prior to entering any pollution control equipment.
c) The Permittee will operate each of the three (3) incinerators such that each individual exhaust stacks will not emit particulate matter in excess of 0.08 grains per dry standard cubic foot in accordance with the formula specified in LAC 33:V.3111.A.3.
d) Compliance
with
the
operating
requirements specified in this permit
will be regarded as compliance with
V.D.l.a), b), and c) . However, any
evidence of non-compliance with these
performance standards may be grounds for
revocation, modification or reissuance of
this permit pursuant to LAC 33:V.323.
e) The Permittee shall not incinerate wastes which are infectious, radioactive, F020, F021, F022, F023, F026, F-027 (dioxin listed wastes), explosives, or PCBs in concentrations greater than 50 ppm. Wastes containing PCB's in concentrations greater than 50 ppm shall not be incinerated unless a TSCA permit has been obtained for the incinerator.
f) Any hazardous waste which exhibits the characteristic of not being homogenous or stratifies or separates into phases under noncirculating conditions must be fed or direct burned in the incinerator complex and/or kiln where applicable, only under the following conditions:
49
A43B79
DO CONF tdfhttai
!
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
'ADEQUATE INADEQUATE I COMMENT
(1) It must be fed through only one (1) Identifiable injection nozzle.
(2) Total direct burn feed shall not exceed 4% by weight of the total combustion gases calculated in lbs./hr.
(3) The waste analysis plan shall include
approved test methods other than those
specified in SW-846 for establishing the
conditions
and
limits
for
characterization as to homogeneity, or
being capable of stratifying or
separating into phases under nonflow or
static conditions.
g) The Permittee shall inspect and, if necessary, analyze each hazardous waste movement received from off-site at the facility to determine whether it matches the identify of the waste specified on the accompanying manifest or shipping paper.
2. Solvents Plant Incinerator
a) Operating Conditions
(1) The hazardous wastes incinerated in the Solvents Incinerator shall be limited to wastes generated in Block 16 (The Solvents Production Block) and wastes , generated in other production units' generating chlorinated tars and residues. Transport and handling of such tars and residues shall comply with - LAC
33:V.1319.C and 1527.D.
(2) All feed to this incinerator, vents and any auxiliary fuels shall be tested, measured, and recorded as required by LAC 33:V.1529 and the Waste Analysis Plan, Attachment 1.
(3) The maximum waste feed rate to the incinerator shall be 8,700 lb/hr.4
(4) The maximum heat input to the incinerator shall be 23,500,000 BTU/HR, including vent gases and auxiliary fuel.
50
ii DO 143580 CONFIDENTIAL
j 'ADEQUATE INADEQUATE I COMMENT
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
(5) The waste feed to the incinerator shall contain no more than 7,200 lb/hr pounds per hour of total halogen.
() The waste feed to the incinerator shall contain no more than 100 lb/hr bromine.
(7) The waste feed to the incinerator shall
contain no more than 1.65 pounds per hour of ash.
(8) The viscosity of the hazardous waste feed shall be maintained by preheat and steam/air pressure to insure proper atomization through the burner nozzles.
(9) The Permittee shall not incinerate any listed waste (Table 1-LAC 33:V. Chapters 31 or 49) in concentrations greater than 100 ppm with a heat of combustion less than that of carbon tetrachloride (.24 Kcal/gr. or 432 BTU/lb).
(10)
The incinerator shall operate at steady
state within permitted combustion
temperatures and air flow prior to
introduction of hazardous waste. No fuel
except natural gas commercial fuel oil,
or waste derived liquid fuels
specifically approved by LDEQ for the
Permittee shall be used in the start-up
or shut-down of the incinerator.
*
(11)
All mass flow rates and parameters which are calculated from flow rates and an analysis, including heat release rate, total halogen, bromine, and ash, shall be determined hourly, and each excursion shall be documented in the operating record.
b) Process Conditions
(1) The minimum instantaneous cut-off temperature in the combustion zone shall be a minimum of 1080C (1,976F). Incineration of hazardous waste is prohibited in the Solvents incinerator below 1080C (1,976F).2
(2) The maximum combustion air flow rate shall not exceed 25,300 lb/hr. This flow
51
00 143581 CONFTDFNTTAI.
'ADEQUATE INADEQUATE IC0MMEN
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
rate and the heat release rate shall be an Indicator of the combustion gas flow. The combustion air flow rate shall be continuously monitored, the data extracted at one (1) minute intervals computer stored, and printed hourly with the average valves.
(3} The combustion gas concentration of carbon monoxide (CO) as continuously measured in the stack outlet shall be controlled as follows:
CO Limit
If CO average concentration exceeds 100
ppm for any sixty (60) minute period. This average concentration shall be based on a continuously monitored rolling average updated each succeeding minute.
This rolling average shall continuously corrected to 7% Oj.
be
COcorrected CO measured X A4_ 21-% 02
CO Levels are on a Dry Stack Gas Basis.
Waste
feeds
must be
cut-off
instantaneously if the limit is exceeded.
Waste feed may be resumed only wheb'
permitted operating conditions (steady
state) are reached. (See iv..below).
(4) If the CO concentration exceeds ' the limits described in V.D.2.b)iii), the
Permittee may not resume incineration of hazardous waste until the incinerator has been brought back to permitted operating temperature and CO concentration conditions.
These permitted conditions shall be evidenced by maintaining a time weighted average CO level not to exceed 100 ppm for an average period of not less than ten (10) minutes at a temperature higher than cut-off combustion zone temperature.
(5) The concentration of oxygen (0_) in the combustion gases shall not be less than
52
00 14058?
CONFIDENTIAL
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
I
'ADEQUATE j INADEQUATE ICOMME
2% on a dry basis. At any time the 0concentration falls below this value, all
hazardous waste feed shall be immediately cut-off.
The hazardous waste feed shall not be reintroduced until the O- concentration has been increased to 2% *on a dry basis in the stack.
The CO must be at levels indicated in V.D.2.b)iii) above.
(6) The Permittee shall monitor the steam/air pressure used for atomizing the hazardous waste feeds.
Monitored results shall be recorded. In the event of the loss of steam/air pressure below 40 psi for any feed nozzle the hazardous waste feed for the affected nozzle shall be immediately cut off and not reintroduced until this pressure has been re-established at the above pressure.
(7) The hazardous waste feed through each burner gun and the atomizing steam rate shall be such that proper atomization shall be maintained.
c) Equipment Testing
The Permittee shall test .the following waste feed cut-off systems at a minimum of once per month, and
record in the operating record. The vent control feed system may be tested for cut-off response through control valve movement or any other check to determine its operational capability in the event of an emergency.
(1) Hazardous waste feeds and vents low
combustion temperature cut-off.
(See
V.B.2.b)i).2
(2) Hazardous waste feeds and vents high CO cut-off.
53
DO 1.43583 CONFIDENTIAL
'ADEQUATE INADEQUATE I COMME
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
(3) Hazardous waste feeds and vents cut-offs for low 02-
(4) Hazardous waste feeds and vents low primary and secondary scrubber flow cut off.
(5) Hazardous waste feeds and vents cut-offs for a temperature exitincr the secondary scrubber greater than 190"? (87.8C).
(6) Hazardous waste feeds and vents cut-offs for a loss of combustion air.
d) Automatic Shutdown Conditions
The hazardous waste feed to the incinerator shall stop immediately whenever:
(1) There is a loss of power to the combustion air blower.
(2) There is a loss of power to the exhaust blower.
(3) There is a power outage.
(4) There is a loss of instrument air.
5) There is a loss of atomization steam
(6) There is a loss of primary scrubber water.
(7) There is a loss of secondary scrubber water.
(8) The temperature exiting the secondary scrubber exceeds 190F (87.8C).
(9) There is a loss of caustic (NaOH) flow to the secondary scrubber.
(10) The combustion air flow rate exceeds 25,300 lb/hr.
(11) The combustion temperature drops below 1080C (1,976F).
(12) The CO concentration exceeds the limits described in V.D.2.b)iii).
54
QO 143584
r.ONF T DENT I AL
'ADEQUATE INADEQUATE I COMM
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
(13) The o2 concentration drops below 2%.
e) The date, cause, and remedial action for each cut-off activation shall be documented in the operating record.
f) Monitoring Conditions
(1) Carbon monoxide (CO) at a point in the system downstream of the combustion zone and prior to release to the atmosphere shall be continuously monitored,
the data extracted at one (1) minute intervals,
computer stored,
and printed hourly with average values.
(2) The combustion gas temperature exiting the combustion chamber shall be continuously monitored,
the data extracted at one (1) minute intervals,
computer stored,
and printed hourly with average values.
The accuracy of the measurement shall be + 3%.
(3) The indicator of combustion gas velocity, as measured by combustion air and heat release rate shall be continuously monitored,
the data extracted at one (1) minute intervals,
computer stored,
and printed hourly with average values.
(4) The Permittee shall correlate combustion air flow with combustion zone gas velocity (residence time). This air flow shall be continuously monitored,
55
DO 143585
CONFTDFNTT Al
DOW, Pl.AQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
`ADEQUATE I INADEQUATE |COMMENT
the data extracted at one (1) minute intervals,
computer stored,
and converted to combustion zone gas velocity and
printed on an hourly basis with average values.
(5) The hazardous waste feed rates shall be continuously monitored,
the data extracted at one (1) minute intervals,
computer stored, and
printed hourly with average values.
(6) The oxygen (0,) concentration in the stack gas shall be continuously monitored,
the data extracted at one (1) minute intervals,
computer stored,
and printed hourly with average values.
(7) The Permittee shall
./
utilize the
information obtained by additional flow
meters, temperature, pressure-gauges and
electrical measurements as needed- to
operate in compliance with the
performance standards of LAC 33:V.3111.8
(8) The
Permittee
shall
demonstrate
compliance with Performance
Specifications 3 and 4 of 40 CFR Part 60,
Appendix B for the CO and 0, continuous
monitors.
g) Calibration Requirements
The monitoring system equipment shall be calibrated in accordance with the facility and instrument operating procedure.
DO 143586 CONFTDFNTTAL
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
I 'ADEQUATE I NAD EQUATE 1C0MMEN'
The Permittee shall calibrate the carbon monoxide (CO) and oxygen (0-) analyzers at a minimum of once each day.
The Permittee shall install redundant HC1 Scrubber System pH monitors and calibrate once per month or when the pH difference between the two is greater than one (1) pH unit.
h) Inspection Requirements
(1) The incinerator and associated equipment (pumps, valves, conveyors, pipes, etc.) must be subjected to thorough visual inspection, at least daily, while the facility is in operation, for leaks, spills, fugitive emissions, and signs of tampering.
(2) This monitoring and inspection data must be recorded and placed in the operating record.
(3) Upon request by the administrative authority, sampling and analysis of the waste and exhaust emissions must be conducted to verify that the operating requirements established in the permit achieve the performance standards of LAC 33SV.3111.
i) Special Conditions
(1) Operations Manual
The Permittee shall compile and keep current an operations manual covering all aspects of the Permittee's treatment, storage and incineration facility.
(2) Facility Manning and Operations
The Permittee shall staff the incinerator operations with sufficiently trained technical personnel to insure that the incinerator and all related facilities are operated to minimize any impact on human health, the environment, and safety considerations.
57
Ii
DO 143587 CONFIDENT I At
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
'ADEQUATE INADEQUATE!COMMEN
In addition supervision shall provide written instructions to achieve the
performance standards set forth under V.D.l and 2.
j) Shutdown Causes
The Permittee shall compile a list monthly of any hazardous waste shutdowns due to the following:
(1) A trip of any of the automatic waste feed cut-offs.
(2) Power failure.
(3) Equipment malfunction.
(4) Improper operation.
(5) Unknown or unexplainable shutdowns.
k) Adequate Mixing of Wastes
Prior to feeding sludge or liquid
hazardous wastes into the incinerator the
wastes in the feed tanks shall be uniform
and consistent to insure proper
incinerator operation.
Adequate
analytical data must be easily accessible
to control room operators to calculate
all inlet loadings and flow rates.
58
00 1,43588 CONFIDENTIAL
'ADEQUATE INADEQUATE ICOMMEN
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
1) Closure
At closure the owner or operator must remove all hazardous waste residue (including and not limited to ash, scrubberwaters, and scrubber sludges, from the incinerator site).
3. Vinyl II Plant Incinerator
a) Operating Conditions
(1) The hazardous wastes to be incinerated shall be limited to the wastes generated in Block 66 having a heat of combustion greater than or equal to carbon tetrachloride (.24 Kcal/gr. or 432 BTU/lb).
(2) All feed to this incinerator, vents and any auxiliary fuels shall be tested, measured, and recorded as required by LAC 33 ,*V. 1529 and the Waste Analysis Plan, Attachment 1.
(3) The heat input to incinerator including vents and auxiliary fuel shall be limited to the two (2) conditions listed below.
Nonhazardous fuel must be utilized to
bring the temperature to condition 2 from
1 and
t
operating conditions stabilized prior to substituting hazardous waste - for fuel. Operating conditions will- not - be interpretive between these two (2) conditions.
Condition I
Maximum Waste Feed Rate
4,134 lbs/hr
Maximum Heat Release Rate
(including vent gas and
auxiliary fuels)
21,700,000 BTU/hr
Maximum Combustion Air Flow rate SCFM
3,714 SCFM 1,125C (2,057F)
CpnsUtloj IX 5,659 Ibs/hr
26,900,000 ETU/hr
59
DO i43589
CONFTDFNTIAl.
I
`AD EQUATE I NAD EQUATE I COMMENT
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
(4) The waste feed to the incinerator shall contain no more than 4,250 pounds per hour of total halogen.
(5) The waste feed to the incinerator shall contain no more than eighty-four (84) pounds per hour bromine.
(6) The waste feed to the incinerator shall contain no more than ninety-two (92) pounds per hour ash.
(7) The viscosity of the hazardous waste feed shall be maintained by preheat and steam if necessary to insure proper atomization through the burner nozzles.
(8) The Permittee shall not incinerate any listed waste (Table I-LAC 33:V. Chapters 31 or 49 in concentrations greater than 100 ppm with a heat of combustion less than that of carbon tetrachloride (.24 Kcal/gr. or 432 BTU/lb).
(9) The incinerator shall operate at steady state within permitted combustion temperatures and air flow prior to introduction of hazardous waste.
No fuel except natural gas, commercial fuels, nonhazardous off gasses or waste
derived nonhazardous liquid fuels ' specifically approved by LDEQ for the Permittee shall be used in..the start-up or shutdown of the incinerator.
(10) All mass flow rates and parameters which are calculated from flow rates and an analysis, including heat release rate, total halogen, bromine, and ash, shall be determined hourly
and each excursion shall be documented in the operating record.
b) Process Conditions
(l) The
minimum
cut-off
combustion
temperature in the combustion zone shall
be 1125c (2,057F). During any start up
hazardous waste may not be incinerated
60
DO 143590 CONFIDENTIAL
"ADEQUATE INADEQUATE!COMMENT
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
until this temperature is achieved in the combustion zone.
(2) The maximum combustion air flow rate
shall not exceed 3,714 SCFM during condition 1 and 3,823 SCFM during condition 2.
This flow rate shall be the indicator of combustion gas velocity. The combustion air flow rate shall be continuously monitored and recorded.
(3) The combustion gas concentration of carbon monoxide (CO) as continuously measured in the stack outlet shall be controlled as follows:
CO Limit
If CO average concentration exceeds 100 ppm for any sixty (60) minute period. This average concentration shall be based on a continuously monitored rolling average updated each succeeding minute.
This rolling
average shall be
continuously corrected to 7% 02.
COcorrected = CO measured X 14 21-% 02
!
CO Levels are on a Dry Stack Gas Basis.'
Waste
feeds
must be- cut-off
instantaneously if the limit is exceeded.
Waste feed may be resumed only when
permitted operating conditions (steady
state) are reached. (See iv below).4
(4) If the CO concentration exceed the limits describe in V.D.3.b)iii) the Permittee may not resume incineration of hazardous waste until the incinerator has been brought back to permitted operating temperature and CO concentration conditions. These permitted conditions shall be evidenced by maintaining a time weighted average CO level not to exceed 100 ppm for an average period of not less than ten (10) minutes at a temperature
61
DO 143591 CONFIDENT! Al
DOW, PI.AQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
'ADEQUATE INADEQUATE I COMMENT
higher than the cut-off combustion zone temperature.
(5) The concentration of oxygen (0_) in the combustion gases shall not be less than 2% on a dry basis. At any time the Oconcentration falls below this value, all hazardous waste feed shall be immediately cut-off. The hazardous waste feed shall not be reintroduced until the 02 concentration has been increased to 2% on a dry basis in the stack. The CO must be at levels indicated in V.D.2.b)iii) above.
(6) The Permittee shall monitor the steam and/or air used for atomizing the hazardous waste feeds. Monitored results shall be recorded. In the event of loss of steam pressure/air pressure below 40 psi for any feed the hazardous waste feed for the affected nozzle shall be immediately cut-off and not reintroduced until this pressure has been re established at the above pressure.
(7) The hazardous waste feed through each burner gun and atomizing steam rate shall be such that adequate atomization shall be maintained.
c) Equipment Testing
t.
The Permittee shall test te following waste feed cut-off systems- and the corresponding alarms at a minimum of once per month and
record in the operating record. The vent control feed system may be tested for cut-off response through control value movement or any other check to determine its operational capability in the event of an emergency situation.
(1) Hazardous waste feeds and vents low combustion temperature cut-off.2
(2) Hazardous waste feeds and vents high CO cut-off.
00 14359? CONFIDENTIAL.
DO ,W PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
`ADEQUATE INADEQUATE!C0MME>
(3) Hazardous waste feeds and vents cut-offs for low Oj.
(4) Hazardous waste feeds and vents low primary and secondary scrubber water flow cut-off.
(5} Hazardous waste feeds and vents cut-offs for a temperature exiting the final scrubber greater than 190F (87.8C).
6} Hazardous waste feeds and vents cut-offs for a loss of combustion air.
(7) Hazardous waste feeds and vents cut-off
for a quench drum exiting temperature of 260F (126.7C).
d) Automatic Shutdown Conditions
The hazardous waste feed o the incinerator shall stop immediately whenever:
(1) There is a loss of power to the combustion air.
(2) There is a loss of power outage.
(3) There is a loss of instrument air.
(4) There is a loss of atomization steam/airf.*
(5) There is a loss of primary scrubber water.
(6) There is a loss of scrubber water flow to the venturi scrubbers.
(7) The temperature exiting the final stack scrubber exceeds 190F (87.8C).
(8) There is a loss of caustic flow to the final stack scrubber.
(9) The discharge pressure from
combustion air blower falls below inches of water.
the 30
(10) The combustion temperature drops below 1125C (2,057F).
00 143593 conftdenttai
I `ADEQUATE INADEQUATEICOMME
DO ,W PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
(11) The concentration of CO in the combustion gases exceed the limits described in V.D.3,b)iii).
(12) The concentration of oxygen in the combustion gases drops below 2%.
(13) The combustion air flow exceeds 3,714
SCFM during Condition 1 and 3,823 SCFM during Condition 2.
e) The data, cause, and remedial action for each waste feed cut-off activation shall be documented in the operating record.
f) Monitoring Conditions
(1) Carbon monoxide (CO) at a point in the system downstream of the combustion zone and prior to release to the atmosphere shall be continuously monitored,
the data extracted at one (l) minute intervals,
computer stored,
and printed hourly with average values.
(2) The combustion gas temperature exiting
the incinerator shall be continuously
monitored,f
vi
the data extracted at one, (1) minute intervals,
computer stored,
and printed hourly with average values.
The accuracy of the instrument shall be 3%.
(3) The indicator of combustion gas velocity,
as measured by combustion air and heat release rate shall be continuously monitored,
the data extracted at one (1) minute intervals,
computer stored,
64
DO 143594 CONFIDE NTT Al
'ADEQUATE INADEQUATE ICOMMENT
DO ,W PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
and printed hourly with average values.
(4) The Permittee shall correlate combustion air flow with combustion zone gas velocity (residence time). This air flow shall be continuously monitored,
the data extracted at one (1) minute intervals,
computer stored,
and printed hourly with average values.
(5) The hazardous waste feed rates shall be continuously monitored
the data extracted at one minute intervals,
computer stored,
and printed hourly with average valves.
(6) The oxygen (02) concentration in the stack gas shall be continuously monitored,
the data extracted at one (1) minute intervals,
computer stored,
and printed hourly with average values.
(7) The Permittee shall utilize the
information obtained be additional flow meters, temperature, pressure gauges and electrical measurements as needed to operate in compliance with the performance standards of LAC 33:V.3111 and other requirements described herein.
(8) The
Permittee
shall
demonstrate
compliance with performance
specifications 3 and 4 of 40 CFR Part 60,
Appendix B for the CO and 02 continuous
monitors.
g) Calibration Requirements
65
`n ^43595 ooN^^tTAl;
'ADEQUATE INADEQUATE!COMMES
DO ,W PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
The monitoring system equipment shall be calibrated in accordance with the facility and instrument operating procedure.
The Permittee shall calibrate the carbon monoxide (CO) and oxygen (0-) analyzers at a minimum of once each day. .
The Permittee shall install redundant HCl Scrubber System pH monitors and calibrate once per month or when the pH difference between the two is greater than one (1) pH unit.
h) Inspection Requirements
(1) The incinerator and associated equipment (pumps, valves, conveyors, pipes, etc.) must be subjected to thorough visual inspection, at least daily, while the facility is in operation, for leaks, spills, fugitive emissions, and signs of tampering.
(2) This monitoring and inspection data must be recorded and placed in the operating record.3
(3) Upon request by the administrative authority, sampling and analysis of the waste and exhaust emissions must be conducted to verify that the operating requirements established in. the permit achieve the performance standards of LAC 33:V.3111.
i) Special Conditions
(1) Operations Manual
The Permittee shall compile and keep current an operations manual covering all aspects of the Permittee's treatment, storage and incineration facility.
(2) Facility Manning and Operations
The Permittee shall staff the incinerator operations with sufficient trained and technical personnel to insure that the incinerator and all related facilities
66
i
(
DO 1.43596 CONFIDENTIAL
`ADEQUATE INADEQUATE! COMME.'
DO ,W PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
are operated to minimize any impact on human health, the environment and safety considerations.
In addition supervision shall provide written instructions to achieve the performance standards set forth under V.D.l and 3.
j) Shutdown Causes
The Permittee shall compile a list monthly of any hazardous waste shutdowns due to the following:
(1) A trip of any of the automatic waste feed cut-offs.
(2) Power failure.
(3) Equipment malfunction.
(4) Improper operation.
(5) Unknown or unexplainable shutdowns.
k) Adequate Mixing of Wastes
Prior to feeding sludge or liquid
hazardous wastes into the incinerator the
wastes in the feed tanks shall be uniform
and consistent to insure proper,
incinerator operation.
'1
Adequate analytical data must be easily accessible to the control room operators to calculate permitted inlet loadings and flow rates.
l) Closure
At closure the owner or operator must remove all hazardous waste residue (including and not limited to ash, scrubberwaters, and scrubber sludges, from the incinerator site).
4. Environmental Operations (Rotary Kiln) Incinerator
a) Operating Conditions
67
DO 143597 CONFIDENTIAL
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
'ADEQUATE INADEQUATEtCOMME
(1) All feed to this incinerator/ vents and any auxiliary fuels shall be tested, measured, and recorded as required by LAC 33:V.1529 and the Waste Analysis Plan, Attachment 1.
(2) The maximum waste feed rate to the incinerator shall be 13,638 lb/hr.
(3) The maximum heat input shall be 82,500,000 BTU/HR, including vent gases and auxiliary fuels.
(4) The waste feed shall contain no more than 1,519 pounds per hour of total chlorine.
(5) The waste feed shall contain no more than 27.6 lb/hr bromine.
(6) The waste feed shall contain no more than fifty (50) Ib/hr fluorine.
(7) The liquid waste feed shall contain no more than 1,110 lb/hr ash.
(8) The viscosity of the hazardous waste feed shall be maintained by preheat and steam to insure proper atomization through the burner nozzles.
(9) The Permittee shall not incinerate any* listed waste (Table I-LAC 33:V. Chapters 31 or 49) in concentrations,,greater than 100 ppm with a heat of combustion less than that of carbon tetrachloride t*24 Kcal/gr. or 432 BTU/lb).
(10) The incinerator shall operate at a steady state within permitted combustion temperature and other specified operating parameters prior to introduction of hazardous waste. Only nonhazardous waste fuels such natural gas, commercial fuels, trash, or waste derived fuels specifically approved by the LDEQ shall be used in the startup or shutdown of the incinerator.
(11) All mass flow rates and parameters which are calculated from flow rates and an analysis? including heat release rate,
D0 143598
CONFinFNTIAt
'ADEQUATE INADEQUATE ICOMME
DO ,W PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
total halogen, bromine, and ash shall be determined hourly and
each excursion shall be documented in the operating record.
b) Process Conditions
(1) The minimum combustion temperature in the combustion zone of the secondary combustion chamber shall be 1615F (879.4C). The hazardous waste feed shall be cut-off immediately if it falls below this value. When operating the kiln the minimum exit temperature shall be 1060F (571C). The temperature of
the kiln shall be 1060F (571C) prior to
the incineration of waste.
(2) The maximum dry stack gas flow rate shall not exceed 27,579 dscfm.
(3) The combustion gas concentration of carbon monoxide (CO) as continuously measured in the stack outlet shall be controlled as follows:
CO Limit
If CO average concentration exceeds 100 ppm for any sixty (60) minute period. This average concentration shall be based, on a continuously monitored rolling average updated each succeeding minute.
This rolling average shall - be continuously corrected to 7% Oj.
COcorrected - CO measured X 24 21-% 02
CO Levels are on a Dry stack Gas Basis.
Waste feeds
must be cut-off
instantaneously if the limit is exceeded.
Waste feed may be resumed only when
permitted operating conditions (steady
state) are reached. (See iv below).4
(4) If the CO concentration exceed the limits described in V.D.4.b)iii) the Permittee may not resume incineration of hazardous
69
i
DO 143599 CONFIDENTIAL
,`ADEQUATE INADEQUATE I COMMENT i
DO ,W PLAQUE-MINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
waste until the incinerator has been brought back to normal operating temperature and CO concentration conditions. These normal conditions shall be evidenced by maintaining a time weighted average CO level not to exceed 100 ppm for an average period of not less than ten (10) minutes.
(5) The concentration of oxygen (02) in the combustion gases shall not be less than 2% on a dry basis. At any time the O. concentration falls below this value, all hazardous waste feed shall be immediately
cut-off.
The hazardous waste feed shall not be
reintroduced until the 02 concentration has been increased to 2% on a dry basis in the stack. The CO must bo at levels indicated in V.D.4.b)iii) above.
(6) The Permittee shall monitor the steam
and/or air used for atomizing the
hazardous waste feeds. Monitored results
shall be recorded. In the event of the
loss of steam pressure below 8 psi
for the sludge nozzle and 15 psi for
the other liquid nozzles the hazardous
waste feed shall be immediately cut-off i
to the nozzle at which the pressure has dropped below the specific cutoff psi and'
t
not reintroduced until this pressure has
been re-established at. .. the above
pressure.
(7) The hazardous waste feed through each burner gun and atomizing steam rate shall be such that proper atomization shall be maintained.9
(9) The maximum rotational speed of the kiln shall be limited to the manufactures recommendation of no more than 20 revolutions per hour (2 minutes per revolution) while burning hazardous waste.
c) Equipment Testing
The Permittee shall test the following waste feed cut-off systems at a minimum
70
00 143600 CONFIDENTIAL
'ADEQUATE INADEQUATE!COMMENT
DOW, PLAQUEMINE PERMIT INSPECTION CIIECKUST JANUARY, 1990
of once per month and record in the operating record. Any vent control feed systems being fed to this incinerator may be tested for cut-off response through control value movement or any other check to determine its operational capability in the event of an emergency.
(1) Hazardous waste feeds and any vents for low temperature cut-off.
(2) Hazardous waste feeds and any vents for high CO cut-off.
(3) Hazardous waste feeds and any vents for cut-off for low 02.
(4) Hazardous waste feeds and any vents cut off for a loss of quench water flow and a maximum temperature of 225F (107C) for the combustion gases exiting tha quench dm.
(5) Hazardous waste feeds cut-offs for a pressure in the kiln greater than a minus 0.05 inches of water.
() Hazardous waste feeds cut-offs when the pH water from the final stage of the ionizing wet scrubber falls below 6.0 for five (5) minutes.
(7) Hazardous waste feeds cut-off for a loss of current to the discharge, electrodes or a loss of more than one (1) stage of the ionizing wet scrubber (IWS).'
(8) Hazardous waste feeds cut-offs for a loss of combustion air to any affected burner guns.
Automatic Shutdown Conditions
d) The hazardous waste feed to the incinerator shall stop immediately whenever:
(1) There is a loss of power to the combustion air.2
(2) There is a loss of power outage.
71
!i
DO 143601 CONFIDENTIAL
'ADEQUATE INADEQUATE1C0MMEN
> (3) There is a loss of instrument air. c z (4) There is a loss of atomization steam
<
(5) There is a loss of scrubber water.
CHO (6) The temperature exiting the quench drum CUJJ exceeds 225P (107C).
(7) There is a loss of negative pressure (minus 0.05 inches of water) in the kiln.
Hutu CCZOl,
(8) There is a loss of one (1) stage of the three (3) stages in the IWS except for
the backwash of one (1) stage.
H XCLU-*
O-
(9) The pH of the final scrubber solution falls below 6.0 for more than five (5) minutes.
LU
(10) There is a loss of scrubber water to the
u: exhaust IWS. Scrubber water flow shall
O' be maintained at interim conditions
<
cu
through backwashing as prescribed by the manufacturer.
sa (11) No packs of hazardous waste will be feed if the kiln ceases rotation as indicated by a control room monitor of the motor drive amps.
(12) The bypass dump stack opens, regardless' of the reason.
(13) The combustion temperature in the secondary combustion chamber drops below 1615F (879.4C).
(14) The temperature in the kiln drops below 1060F (571C).
(15) The concentrations of CO in the combustion gases exceeds the limits described in V.D.4.b)iii.
(16) The concentration of oxygen in the combustion gases drops below 2%.
(17) The saturated combustion gas flow exceeds 36,500 ACFM.
72
DO 14360? CONFIDFNT T Al
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
"ADEQUATE j INADEQUATE!COMMENT
e) The data, cause, and remedial action shall be documented for each waste feed cut-off activation in the operating record. The Permittee shall report in writing to the administrative authority if there are more than thirty (30) permit required waste feed cut-offs per month. This report shall include cause and remedial actions taken.
f) Monitoring Conditions
(1) Carbon monoxide (CO) at a point in the system downstream of the combustion zone and prior to release to the atmosphere shall be continuously monitored,
the data extracted every minute,
computer stored, and
printed hourly with average values.
(2) The combustion gas temperature exiting the incinerator shall be continuously monitored,
the data extracted every minute,
computer stored, and
printed hourly with average values. ThetV accuracy of the measurement shall be +'
3%.
(3) The correlation of fan speed and/or motor loading shall be the indicator of combustion gas velocity. This indicator shall be continuously monitored,
the data extracted at one (1) minute intervals,
computer stored,
printed hourly with average values, and reported as combustion gas velocity.4
(4) The hazardous waste feed rates shall be continuously monitored,
73
I 'ADEQUATE INADEQUATE ICOMMEN
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
the data extracted at one (1) minute intervals,
computer stored,
printed hourly with average values.
(5) The oxygen (0,) content of the stack gas shall be continuously monitored,
the data extracted at one (1) minute intervals,
computer stored, and
printed hourly with average values.
(6) The Permittee shall utilize the information obtained by additional flow meters, temperature, pressure gauges and electrical measurements as needed to operate in compliance with the performance standards of LAC 33:V.3111 and other requirements described herein.
(7) The
Permittee
shall
demonstrate
compliance with performance
specifications 3 and 4 of 40 CFR Part 60,
Appendix B for the CO and 0- continuous
monitors.
g) Calibration Requirements
The monitoring system equipment shall be calibrated in accordance 'with the
facility and instrument ` operating procedure. The Permittee shall calibrate
the carbon monoxide (CO) and oxygen (02) analyzers at a minimum of once each day.
The Permittee shall install redundant HCl Scrubber System pH monitors and calibrate once per month or when the pH difference between the two is greater than one (1) pH unit.
h) Inspection Requirements
(1) The incinerator and associated equipment (pumps, valves, conveyors, pipes, etc.) must be subjected to thorough visual inspection, at least daily, while the
74
DO r.o^
1 00
DOW, PI.AQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
4
!
'ADEQUATE INADEQUATE1C0MM1
facility is in operation, for leaks, spills, fugitive emissions, and signs of tampering.
(2) This monitoring and inspection data must be recorded and placed in the operating record.
(3) Upon request by the administrative authority, sampling and analysis of the waste and exhaust emissions must be conducted to verify that the operating requirements established in the permit achieve the performance standards of LAC 33:V.3111.
i) Special Conditions
(1) Operations Manual
The Permittee shall compile and keep current an operations manual covering all aspects of the Dow treatment, storage and Incineration facility.
(2) Facility Manning and Operation
The Permittee shall staff the incinerator operations with sufficient trained and technical personnel to insure that the incinerator and all related facilities are operated to minimize any impact on/ human health, the environment, and safety considerations.
In addition supervision shall provide written instructions to achieve the performance standards set forth under V.D.l and 4.
I
75
00 143605 CONFTDFNTTAL
l
'ADEQUATE INADEQUATE ICOMMEN
DO ,W PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
j) Shutdown Causes
The Permittee shall compile a list
monthly of any hazardous waste shutdowns due to the following:
(1) A trip of any of the automatic waste feed cut-offs.
(2) Power failure.
(3) Equipment malfunction.
(4) Improper operation.
(5) Unknown or unexplainable shutdowns.
(6) Adequate Mixing of Wastes
Prior to feeding sludge or liquid hazardous wastes into the incinerator the wastes in the feed tanks shall be uniform
and consistent to insure proper incinerator operation.
Adequate analytical data must be easily
accessible to the control room operators to calculate permitted inlet loadings and flow rates.
1} Closure
V
At closure the owner or operator must remove all hazardous waste residue (including and not limited to ash, scrubberwaters, and scrubber sludges, from the incinerator site).
E. LANDFILLS
1. General Design, Requirements
Construction and
a) The construction and operation of the landfills must comply with this permit, the Department of Environmental Quality Rules and Regulations as set forth in LAC 33:V.517 and. Chapter 25 and be in accordance with plans and specification for design, construction and operations approved herein.
76
DO 143606 CONFTDENTTAl
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
, `ADEQUATE:INADEQUATE ICOMME
S1
i
b) Any variance from or modification of the
approved plans and specifications for the design, construction and operation of the landfills and the terms and conditions of this permit is not allowed without the prior written approval from the Department Environmental Quality.
*
77 |-)0 143607
CONFTDFNTT Al I
'ADEQUATE INADEQUATE!COMMENT
PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
2. General Operating Conditions
The Permittee shall operate and maintain the two (2) permitted landfills to meet the following performance standards:
a) Run-off of storm water shall be managed to conform with LAC 33:V.2503.
Collected material must be properly disposed.
In addition the collected run-off shall be discharged through the NPDES outfall. Any incidences of run-off not collected and controlled shall be reported and made a part of the annual report.
b) The run-on control dikes to prevent any flow onto the active portion of the landfills.
Any incidences of run-on entering the containment areas shall be reported and made a part of the annual report.
s c) All collection and holding facilities (sumps and tanks) associated with the run-on and run-off control systems must be emptied expeditiously to maintain the design capacity of the system as required by LAC 33:V.2503.E. For those facilities - I exempted under the 90-day exemption rule, the administrative authority interprets empty as requiring these facilities be rinsed after the contents are emptie'd to insure a minimum of residual contaminants.
d) if the landfill contains any particulate matter which may be subject to wind dispersal, the owner or operator must
cover or otherwise manage the landfill to control wind dispersal.
Wetting of the landfill for control of
particulate matter is not allowed unless
the landfill is equipped with a leachate
collection system equivalent to LAC
33:V.2503.A. 2 .
pursuant to
LAC
33:V.2503.F.
78
DO 143608 CONFIDENTIAL
'ADEQUATE INADEQUATE!COMMENT
DON, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
After each deposition of hazardous waste within the landfill it shall be topped with a cover material to insure minimum
wind dispersal as required by LAC 33:V,2503.F.
The Northwest Landfill shall only be
utilized to dispose of Environmental
Operations
recovered
incinerator
particulate and ash meeting the
requirements of LAC 33:V.1517, 2513,
2515, and 2517, and onsite generated
waste asbestos.
Disposal of asbestos must be in
accordance with OSHA regulations and LAC
33:V.III.2599. The Block 80 Landfill
shall only be utilized to dispose of
Environmental
Operations
recovered
incinerator particulate and ash.
f) While in operation, each landfill must be inspected weekly and after storms to detect evidence of any of the requirements under LAC 33:V.2507.C.
g) The Permittee must maintain operating records as required by LAC 33:V.2509.
h) Closure and post-closure care shall be in conformity with LAC 33 :V.2521 and the
closure and Post-Closure Plan Attachment. 5.
i) The receiving and monitoring' of wastes into the landfills shall be perforaed according to LAC 33:V. 1527.A, B, C, and D.
3 . Northwest Hazardous Waste Landfill Design
The Permittee shall comply with the following minimum requirements for the landfill as specified in LAC 33:V, Chapters 5, 15, and 25. All design must comply with attached drawings Exhibit 1 and 2.
The facility is an unlined landfill relying on in situ clays for protection of the ground water. The landfill is composed of two (2) cells designated as
79
DO 143609 CONFIDENTIAL
`ADEQUATE INADEQUATE IC0MMEN
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
Cell "A" and Cell "B". Cell "A" is rhombohedral in shape with the dimensions Of: 277.5' x 305.0' x 282.5' X 305.0. Cell "B" is adjacent to and west of Cell "A". Cell "B" is roughly trapezoidal in shape with the dimensions of: 604' x 300* X 268* X 308*.
b) Each cell is surrounded by a permanent exterior recompacted silt levee with side slopes of 3:1 and an average crown elevation of 26' NGVD.
c) Cell "A" contains a leachate collection sump and pump structure that is common to both cells. The sump is located at Stas. 109 + 51.19N and 112 + 71.22E and connected to Cell "B" by a 12" PVC (SCH.40) pipe. The bottom of both cells is provided with a 2% slope toward the common sump. Leachate collection in Cell "B" is assisted by a central ditch leading to the sump. Elevation of the sump is 19.23' NGVD and the elevation of the twelve (12) inch collection pipe in Cell "B" has an inverse elevation of 15.0'.
d) The final elevation of this landfill shall be 45 NGVD.
4. Block 80 Hazardous Waste Landfill Design,
a) All design must comply with attached drawings Exhibit 2A, 3, (3),-4 (4), 5, Figure 2.1 (2), 2.2, (2), 2.5, 2.6, 2.7, 2.8, 4.1, 4.2, 11.1 and 11.7.
b) The bottom liner must be constructed of recompacted clay or clayey soils having a minimum thickness of three (3) feet. The recompacted liner shall have a field hydraulic conductivity of 1' x 10-7 cm/sec or less. The bottom clay liner must be keyed into the recompacted clay exterior dike constructed to the same criteria as the bottom liner. The crown of the exterior dike system is not to exceed thirty-two (32) feet NGVD. The slope of the bottom liner to the centrally located leak detection sump shall be no less than two percent (2%).
80
DO 143610 CONFIDENTIAL
`ADEQUATE INADEQUATE!CQMN
BOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
A continuous, sixty (60) mil thick
H.D.F.E. membrane with an underlying
geotextile must be placed upon the
recompacted clay bottom liner.
The
H.D.P.E. membrane and geotextile
components must cover the entire bottom
clay liner and extend up slope to at
least the center line of the exterior
dike.
d) A leak detection, collection and removal system consisting of a geotextile overlain by two (2) courses of drainage geonet and covered with a geotextile must be incorporated. The composite leak detection system shall cover the entire bottom of the landfill and extend up slope to at least to the centerline of
the exterior dike. The composite leak detection shall be overlain by eighteen (18) inches of clean sand in the bottom portion of the landfill. The entire leak detection collection and removal system shall drain to the centrally located leak detection sump.
e) The landfill must employ a primary, recompacted clay or clayey soil liner
having a minimum thickness of two and one
half (2?) feet thickness, placement must
be upon the leak detection, collection'
and removal composite.
The primary
recompacted clay liner shall,have a field
hydraulic conductivity of 1 x-10-7 cm/sec
or less. The slope of the primary'clay
liner to the centrally located runoff
collection sump shall be no less than two
percent (2%).
A continuous eighty (80) mil H.D.F.E. membrane must be incorporated with an underlying geotextile placed upon the primary, recompacted clay liner. The eighty (80) mil H.D.P.E. membrane and underlying geotextile shall cover the entire primary clay liner and extend up slope to at least centerline of the exterior dike. The H.D.P.E. liner must have a minimum slope of two percent (2%) towards the sump.
81
00 143611
^onftdfnttai.
'ADEQUATE INADEQUATEICOMME
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
g) A leachate collection and removal system consisting of two (2) courses of geonet overlain by a geotextile must be incorporated. The bottom portion of the composite leachate collection and removal system shall be covered with one (1) foot of clean sand. The composite leachate collection and removal system must cover the entire eighty (80) mil H.D.P.E. membrane and extend up slope to at least the centerline of the exterior dike. The leachate collection and removal composite must drain to the centrally located leachate collection sump.
h) The exterior perimeter dike of the landfill is to be constructed with side slopes no greater than three to one (3:1). The crown of this dike is to be provided with an anchor trench capable of retaining all geomembranes, geonets and geotextiles in such a manner as to prevent pull-out from waste placement and subsurface settlement forces.
i) The vertical riser pipes from the leak detection and leachate collection systems are to be forty-eight (48) inch diameter, H.D.P.E. piping. The H.D.P.E. pipes are to be compatible with the H.D.P.E. membrane materials so as to facilitate welding of the two materials together*, The concrete support plates for the leachate collection and leak detection system shall be reinforced.~ Portland cement concrete formed in a five (5) feet by five (5) feet areal extents and of sufficient thickness to support the vertical, H.D.P.E. riser pipes..
j) The final closure cap shall consist of two (2) feet of compacted clay, sixty (60) mil H.P.D.E. liner, geotextile, two (2) courses of tensar drain, one (1) foot of clay and finally one (1) foot of top soil. The final height shall be no greater than 64 feet msl in the center.
5. Materials specifications:
a) All clay and/or clayey soils used in the construction of the bottom recompacted
82
DO 140612 CONFIDENTIAL
DO ,W PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
oo&
'ADEQUATE INADEQUATE I COMMENT
clay liner, recompacted clay primary liner and the exterior dike system shall conform to the following standards:
(1) In Place Density 95% of Standard Proctor (ASTM D698)
(2) Moisture content at the time of
compaction shall be 0 to 2% above optimune moisture content as determined by ASTM D698.
(3) Atterberg Limits
i) Liquid Limit 35% (min) ASTM - D-423
ii) Plastic Limit 15% (min) ASTM - D-424
(4) Field Permeability 1 x 10 - 7 cm/sec Double Ring Infiltrometer.
(5) Sieve Analysis ASTM - D-422
i) Percent retained on the number 40-15 (maximum)
ii) Percent retained on the number 200 - 25 (maximum)
(6) Clod Size - Not to exceed 3" diameter prior to compaction.
b) Geotextiles shall be a woven or non-woven needle punched fabric consisting only of long chain polymeric polyethylene, polyester, polyamid or polyvinylidenechloride formed into a stable network of filaments such that the filaments retain their relative position to each other. The textile shall be inert to the soils, geonets, geomembranes and chemical
constituents of the leachate and conform to the following physical properties:
(1) Grab Strength, wet: - D-1682
lbs. (min) ASTM
(2) Water Permeability: 0.30 cm/sec (min)
(3) Burst Strength: 750 psi (min) ASTM - D751
83
DO 143613 CONFIDENTIAL
I
PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
t `adequate: INADEQUATE ICOMMEN (4) Unaffected by mildew, water or saltwater c) High density polyethylene geomembranes shall conform to the following:
I
l '
DO 143614 CONFIDENTIAL
Gauge (nominal) Thickness, mils minimum
Specific Gravity (minimum) Carbon Content
ASTM D1593 Paragraph 8.1.3
ASTM D792
Method A
Minimum Tensile Properties (each direction)
ASTM D638
Tensile Strength Yield (lb/in width)
Tensile Strength at Break (lb/in width)
Elongation at Yield (percent)
Elongation at Break
Modulus of Elasticity (lb/sq in)
Tear Resistance (lb, minimum) ASTM D1004 Die C
Low Temperature, F
ASTM 'D746 Procedure B'
Dimensional Stability (each direction, percent change minimum)
ASTM D1204 212F,,15 min
Resistance to Soil Burial (percent change maximum in
original value)
ASTM D3083 (as modified in Appendix A)
Tensile Strength Yield
Tensile Strength at Break
Elongation at Yield
Elongation at Break
84
80 60 72 54 0.930 3%
120 120
10 500 80,000
40 -40
+3
10 10 10 10
00 143615 CONFIDENTIAL
Modulus of Elasticity
10
Environmental Stress Crack ASTM D1693
(minimum, hours)
(as modified in
Appendix A)
Factory and Field Seam Requirements
500
Bonded Seam Strength (factory seam, breaking factor, ppi width)
ASTM D3083 (as modified in Appendix A)
108
Peel Adhesion (lb/in minimum)
Dead Load
ASTM D413 (as modified in
Appendix A)
ftb**
Room Temperature 73F
See Appendix A
Pass
Elevated Temperature 158F 25% Bonded Seam Load
See Appendix A
Pass
Resistance to Soil Burial
ASTM D3083 (as modified in Appendix A)
ftb** -20
Peel Adhesion
Bonded Seam Strength (percent change maximum in original value)
V-..'
Factory bonded seam strength is the responsibility of the fabricator.
**FTB - Film Tearing Bond
d)
Property Polymer Specific
Gravity
The geonets to be used as a components of the
leak detection, collection and removal system and the leachate collection and removal system
shall be a polymer mesh structure composed of polyethylene with a stabilizer to prevent
degradation of the physical properties of the geonets due to ultraviolet exposure. The
geonets shall conform to the following specifications:
ASTM
Unit
Qualifier Values
D1505
-------
Minimum 0.92
85
DO 143616 CONFIDENT! Al
Polymer Melt Index Carbon Black Content Nominal Thickness Property
D1238 D4218 (1) ASTM
g/io min % mm
Minimum 0.2 Minimum 2.2
51 Qualifier Values
Aperture Size
mm
7i
Mass Per Unit Area (1) g/m2(oz/sq yd)
670 (20)
Nominal Trans missivity (2)
(1) m2/s (gpm/ft) Minimum 5 X 10-4 (2.5)
Nominal Conductivity(3)
m/s (cm/s)
Minimum 0.1 (10)
Compressive Stress Limit (4)
KPa (psf)
Minimum 300 (6,000)
Tensile Strength
(1) Notes:
kN/m (lb/in) Minimum 4 (23)
(1) Use tentative methods being prepared by ASTM Committee D35 on Geotextiles and Related Products.
(2) The nominal transmissivity is the transmissivity of a net measured using
water at 20C (68F)4.:, with a gradient of one, under a compressive stress of lOkPa (200 psf), between two steel plates.
(3) The nominal conductivity is obtained by
dividing the nominal transmissivity by the
nominal thickness (i.e. the thickness of the net measured between two steel plates under a compressive stress of 10 kPa, i.e. 200 psf).
(4) Value of the compressive stress at which
the hydraulic transmissivity is 25% of the nominal transmissivity.
(5) MD machine direction.
e) The sand to be used as a component of the leachate collection and removal system and the
86
DO 143617 CONFTDFNTTAL
'ADEQUATE INADEQUATE!COMMEN"
COli
>ec*
<
leak detection, collection ard removcil system shall conform to the followiiig sped fication:
"<5 ASTM
Si02 content, percent
95 (minimum)
C-295
t/3
Percent passing the No. 4 Sieve 100
D-422
uUJ
Percent passing the No. 200
15 (m4nimum)
Coefficient of Uniformity (CO)
3 (mc.ximum)
fuCCV-UU)
Organics and Percent Deleterious Material
0.25 (maximum) i) AASHTO 21
3CU--E1
Cl
f) Any and all materials not conforming to the specifications, as stated herein, can
LzU
not be used in the construction of the landfill. Furthermore, any materials
W found to be deficient after placement or
ZO<3'
use, shall be removed and replaced with materials conforming to the
D. specifications.
ca 5. Quality Control/Quality Assurance
The following is the minimum quality assurance and quality control (QC/QA) procedures to be used and documented for the construction of the Block 8Q/ hazardous waste landfill:
a) Surveying - A permanent benchmark shall be established and protected in ' the immediate vicinity of the landfill site.
The surveying should be on fifty (50) foot grid. The permanent benchmark shall be used as control for the initial and all subsequent surveying performed relevant to the landfill. All field log books shall be made a part of the permanent files of the facility and
contain the following:
(1) Surveyor's full name and Louisiana registration number.2
(2) Date and reason for survey
DO 143618 CONFIDENTIAL
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
'ADEQUATE INADEQUATE'COMMENT
(3) Reference or book number and description of field book content.
(4) Surveyed control must be used for, but
not limited to, verification of the following:
i) Location of the exterior dike system and
general confiner of the Block 80 hazardous waste landfill;
ii) Excavation
associated
with
construction of the landfill.
the
iii) Thickness of the recompacted clay liners to be constructed as a part of the lining
systems used in the construction of the landfill.
iv) Height and slope of the exterior dike system.
v) Location and elevation of the leachate collection and leak detection sumps and associated riser pipes.
vi) Location of sites for QA/QC testing,
i.e., density and permeability testing of the recompacted clay liner. Areas of
sampling for destructive testing of the geomembranes, geonets and geotextiles used in the lining systems for this landfill.
vii) Location of repairs to lining,systems.
viii)
Preparation of the "as built' plans.
b) The following is the minimum QA/QC
sampling and testing to be performed for the construction of the recompacted clay liners to be used in the construction of the landfill:
(1) Classification tests:
i) Atterberg Limits (ASTM D-4318) shall be determined on the clay soils delivered to the site at the frequency of one (1) per 1000 cubic yards.
88 DO 143619
CONFIDENT!M
!
'ADEQUATE j INADEQUATE I C0MME.`
PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
ii) Percent Passing the No. 200 (ASTM D-698) on delivered clay soils at the frequency of one (1) per 1000 cubic yards.
(2) Recompacted Clay Liner Placement:
i) During periods of active placement and compaction of the clay soils, the field moisture content of the clay soils is to be determined at a minimum of two (2) times daily.
ii) The clay soils shall be continuously visually inspected for clod seye (eight (8) inch minimum), roots, sticks or other extraneous materials.
iii) In-place density of the recompacted clay soils shall be not less than one (1) test per 6000 square feet per lift. Areas failing the density requirements shall be scarified, recompacted and tested until the area meets specification requirements.
iv) Atterberg Limits and percent passing the No. 2000 sieve are to be performed on twenty-five percent (25%) of the areas where density testing is accomplished.
v) Laboratory permeability tests (falling head) shall be performed on a minimum of two (2) core samples obtained at every' 20th site of in-place density testing or six (6) per lift which ever 'generates the most tests. Areas failing permeability requirements shall be scarified, recompacted and tested until the area meets specification requirements.
vi) A new density compaction curve shall be developed after each forty (40) field density tests.
vii) All penetrations into the recompacted clay liner for sampling and testing are to be repaired in such a manner as to preserve the integrity of the liner.
c) The following is the minimum QA/QC sampling and testing to be performed for
89
DO 1.436?0 CONFIDENTIAL
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
'ADEQUATE jINADEQUATE!C0MMEN7
the construction of the recompacted clay exterior dike system of the landfill.
(1) Classification tests: These tests and frequency of testing shall be the same as stated for the recompacted clay liners. 1C., B.6.b. 1)i) & B.6.b.l)ii).
(2) Recompacted clay soils for exterior dike system:
i) Field Moisture Content - same as B.6.b.2) i).
ii) Visual Inspection of Soils - same as B.6.b.2)ii)
iii) In-place density of the recompacted clay of the dike system shall be one (1) per 200 lunar feet of constructed dike per lift.
iv) Atterberg Limits and Percent Passure the No. 200 Sieve - same as B.6.b.2)iv).
v) Laboratory Permeability Tests - same as B.6.b.2)v).
vi) The new density compaction curve - same as B.6.b.2)vi). However, if the dike system construction is simultaneous to the recompacted clay liner construction; the same derived density curve may apply ' to both efforts.
vii) Penetration of the dike soils - same as B.6,b.2)vii).
d) The following is the minimum QA/QC sampling and testing to be performed for the construction and installation of the high density polyethylene liners for the landfill.
(1) Verification: upon delivery of the rolled membrane material, the rolls are to be inspected to verify the materials conformance to specifications, i.e. make, type, thickness, weight, roll number, etc.
90
00 1.43621 CONFTDFNTTAL.
'ADEQUATE INADEQUATE ICOMMEN
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
Samples that are 12" x 12" shall be
obtained from each shipment In accordance With ASTM D-4354.
Each sample must be identified and marked with all applicable data and stored at the field laboratory.
A similar sample shall be submitted to the main laboratory. After testing and verification of conformance, the roll tag shall be marked as pass of fail. Failing rolls must be removed from the active
area construction.
(2) Roll testing: thefollowing is
the
minimum testing to be performed on all
rolls of geomembrane delivered:
i) Thickness of each roll shall be
determined using a calibrated micrometer
read to 0.001 inch. If a failure of the
thickness requirement is detected, the
inspector shall immediately recheck the
thickness ata minimum of
five (5)
additional points. The roll shall pass
if the initial failure was less than ten
percent (10%) of the specified thickness
and the average of the six (6) tests
meets thickness requirements.
ii) The density (ASTM D-1505)
of the
delivered material shall be determined ort
fifty percent (50%) of the samples.
iii) Volatile loss (ASTM D-1203)' shall, be determined on twenty percent (20%) of the samples.
(3) Membrane Placement and Seaming:
i) Prior to panel placement the surface of the area shall be inspected for conformance to specification requirement.
ii) Membrane panel overlap shall be measured at ten (10) foot (maximum) intervals along the entire length of the contact area.
iii) One-hundred percent (100%) of the area to be seamed shall be visually inspected for
91
00 143A22 CONFIDENTIAL
`ADEQUATE INADEQUATEIC0MMEN
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
proper preparation (grinding, etc.) prior to the seaming process.
iv) Prior to the start of, and at the end of each day of seaming, test seams shall be executed on similar scrap membrane material. Test seams are required for each seaming device used.
All test seams shall be subjected to shear and peel testing (ASTM D-413, Method A or D-816, Method B). Failure of test seams will require that the failing equipment not be used until a satisfactory seam can be executed. Should failing seam test data not be available prior to the use of the failing device in the field seaming process, the seam(s) executed by the failing equipment shall be sampled at one-hundred (100) foot intervals for retesting of shear and peel. Any failure of these samples will require replacement of the entire seam with an approved seaming device.
v) Seam Testing: All field seams shall be tested along their entire length by use vacuum box. The procedure shall conform to ASTM D-4437, paragraph 7.3. Additionally,
samples of the seamed area shall be obtained every 500 feet of seam and' tested for peal and shear.
All sampled areas shall patched, repaired and vacuum tested. All failing seams are to be replaced and successfully tested.
vi) All areas of destructive sampling and patching and areas of seam replacement are to be accurately documented and located on the "as-built" plans.
e) The minimum QA/QC testing and documentation for the geotextiles to be used in the construction of the lining systems for the landfill are as follows:
(l) Verification: upon delivery of the rolled geotextiles, the rolls are to be
92
DO 143623 confidential
DOW, PI.AQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
ADEQUATE INADEQUATE'COMME.'
inspected to verify the materials conformance to specifications.
(2) Testing: 12" by 12" samples of each roll are to be obtained and tested for breaking load and elongation (ASTM D-
1682) and fabric testing (ASTM D-851).
(3) Placement and seaming: The geotextiles shall be placed in such a manner that a
textile seam does not coincide with a membrane seam.The textile shall be
joined in such a manner as not to allow any gaps between textile panels. The use of adhesives is strictly prohibited.
f) The minimum QA/QC testing for the geonets to be used in the lining systems for the landfill are as follows:
(1) Verification - same as listed for geotextiles.
(2) Testing shall conform to the tested
methods listed in the specifications for geonets.
g) All QA/QC sampling and testing is to be
documented in detail and made a part of the permanent files of the facility. At
a minimum contain:
this
documentation
must V'
(1) Name of inspector, sampler, tester or
installer.
(2) Date and time.
(3) Purpose of inspection, sample, test.
(4) Material sampled, or item inspected and/or tested.
(5) Location of sample and/or test.
(6) Test data.
7) Response(s) to failing inspection and/or test.
qO 1436?4 CONFIDENTIAL
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
'ADEQUATE INADEQUATE!COMMEN
(8) Any other information or data that will accurately document all QA/QC activities conducted at the facility.
(9) Final exceptance of all QA/QC work performed shall be certified by a qualified third party QA/QC engineer.
h) Written certification of conformance to the LAC 33 :v. 2503 will be required for: both recompacted clay liners, both geomembranes, anchor systems for membranes, textiles and nets and the exterior dike system.
01 0 143675r CONFIDENTIAL
'ADEQUATE INADEQUATE1C0MME
DOW, PLAQUF.MINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
VI. GROUND WATER PROTECTION
A. APPLICABILITY
The regulations of LAC 33:V. Chapters 5, 15, 31, 33, and 35 Louisiana's Water Control Law, R.S., 30:1096D of the Environmental Quality Act, R.S., 30:1051 et seg., and the provisions of this section shall apply to ground water protection programs at Dow Chemical, located in Plaquemine, Louisiana. All requirements and conditions of this section must be satisfied and shall apply during the life of the facilities, which include compliance, closure, and post closure care periods. The facilities are identified as the Northwest Landfill and the Block 80 Landfill.
B. REQUIRED PROGRAMS
The Permittee must continue to conduct detection monitoring from the existing system's established during interim status, as outlined in Sections VI., H., I., and J., herein, and as located on Figures 1 and 2, attached.
The Permittee must have an approved assessment plan for the chloride plume in the Chlorine Plant on file with the administrative authority within sixty (60) days of the issuance of this permit.
All wells and leachate detection points must be monitored, unless exempted from the program at a later date by the administrative authority.
C. GROUND WATER PROTECTION STANDARD
1. The Permittee must comply with conditions specified in this permit that are designed to insure that hazardous waste and hazardous waste constituents (see Section VI.D.) do not exceed the concentration limits (see Section VI.D.) in the uppermost permeable zones underlying the waste management areas beyond or below the points of compliance (see Section VI.E.) during the compliance
95
DO 143676 CONFIDENTIAL
'ADEQUATE INADEQUATE! COMMEN
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
period (see Section VI.F.).
The
protection standard does not exempt the
Permittee from required corrective
actions regarding contamination detected
by wells not assigned as ground water
compliance points.
2. The Permittee must utilize and maintain the present ground water monitoring system illustrated by Figures 1 and 2, consisting of upgradient Wells UN-1 and UN-2 for the Northwest Landfill and UH-1 for the Block 80 Landfill.
Downgradient wells are hereby specified as DN-3, DN-4, NN-5, DN-6, DN-7, and DN8 for the Northwest Landfill and DH-2, DH-3, and DH-4 for the Block 80 Landfill.
The proposed leak detection system for the Northwest Landfill, as approved by the administrative authority (Enclosure) shall be installed within one-hundred eighty (180) days after issuance of this permit and will be identified as LD-1, LD-2, and LD-3.
All wells must be maintained so that surface infiltration is prohibited and ground water samples are generated with a water quality of five (5) or less nephelometric turbidity units (N.T.U.). If turbidity in ground water samples is* attributable to natural hydrogeological conditions peculiar to the screened zone, and a water clarity of five (.5) units is not achievable, the Permittee must
demonstrate to the satisfaction of the administrative authority that turbidity of the water samples will not compromise the validity of the analyses.
3. The Permittee must adhere to the sampling and analysis plan outlined below:
a) All wells must be sampled semiannually (after the hazardous constituent background has been established), as required under Section VI.C.3.e., and the test results submitted to the administrative authority within fifteen
96
DO 143627
fflNFT
T 41
1 'ADEQUATE INADEQUATE I COMMENT
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
(15) days from completion of all analyses and analytical review by the Permittee.
b) All wells must be measured for total
depth (for wells with in-place pumps which prohibit total depth measurement, total depth must be measured annually) and depth to water on the same day and prior to purging.
Measurements must be to the nearest .01 foot, and
the values must be recorded in the field notebook, see Section VI.C.3.g) and reproduced and submitted in the Ground water Annual Report in accordance with LAC 33:V.1529.D.
If ten percent (10%) of the screened interval is blocked by sediments, the well must be redeveloped prior to the next required sampling event.
c) Each well must be purged by evacuation to dryness or by removing a minimum of three (3) casing volumes.
The well must be sampled immediately upon purging and/or when sufficient water for sampling has recharged the well. Purging and sampling methods must be consistent throughout the life of the facility. *'
d) Samples must be withdrawn using dedicated
or adequately cleaned equipment for each
well. No equipment or method may be used
that will chemically alter or influence
the sample. Sampling devices other than
bailers must be approved ` by the
administrative authority prior to use in
monitoring or corrective action programs.
Care must be taken to avoid placing clean
sampling equipment on the ground or on
any contaminated surface.
Sampling
methods and equipment must be consistent
throughout the life of the facility.
e) Sample preservation, handling and containerization must meet the specifications of the LAC and Test Methods for Evaluating Solid Waste
97
' I
i
DO 143628 CONFIDENTIAL
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
'ADEQUATE INADEQUATE!COMMEN
Physical/Chemical Methods 3rd Ed. (EPA SW-846), 1986, as revised, or an
equivalent substitute as approved by the administrative authority. Containers, preservation, and analytical limits are listed below:
TABLE 3A
Northwest Landfill
Parameter
Preservation Method Detection
Container Type Method
Limit, PPM
Mercury
Plastic
Filtered (.45
micron) Acidify to pH >2 with HN03
.0002
Chromium
Plastic
Filtered (.45 micron) Acidify to pH >2 with hno3
.010
Benzene
Glass
Zero Headspac|e Cool to 4C
.005
Carbon Tetra - Glass chloride
Zero Headspac Cool to 4C
.005
Perchloroethylene
Glass
Zero Headspace Cool to 4C
.005
Hexachlorobutadiene
Glass
Cool to 4C
table 3A (continued)
.010
Northwest Landfill
Parameter
Hexachloroethane
Preservation Container Type Method
Glass
Cool to 4 C
Detection PPM
.010
Hexachlorobenzene
Glass
Cool to 4 C
.010
pH
Glass/Plastic Field Measurement
N/A
Specific
Glass/Plastic Field Measurement
N/A
98
DO 143679 CONFTDFNTT AL,
Conductance
Parameter Arsenic Barium Cadmium Chromium Selenium
TABLE 3B
Block 80 Landfill
Preservation Method Detection
gontainer Type Method
Limit. PPM
Plastic
Filtered (.45 micron) Acidify to pH >2 with HN03
.010
Plastic
Filtered (.45
micron) Acidify to pH >2 with HN03
.200
Plastic
Filtered (.45 micron) Acidify to pH >2 with HN03
.005
Plastic
Filtered (.45 micron) Acidify to pH >2 with HN03
.010
Plastic
Filtered (.45 micron) Acidify to pH >2 with HN03
.005
99
DO 1,43630 CONFIDENTIAL
TABLE 3B (continued) Block. 80 Landfill
Parajnet^r Antimony
Lead
Mercury
Manganese
Copper
Zinc
Iron
Chloride P** Specific
Conductance
Preservation Method Detection
Container Type Method
Limit. PPM
Plastic
Filtered (.45 micron)
Acidify to pH >2 with HN03
.060
Plastic
Filtered (.45 micron) Acidify to pH >2 with HN03
.005
Plastic
Filtered (.45 micron) Acidify to pH
>2 with hno3
.0002
Plastic
Filtered (.45 micron) Acidify to pH
>2 with HN03
.015
Plastic
Filtered (.45 micron) Acidify to pH >2 with HN03
.025
Plastic
Filtered (745 micron) .Acidify to pH >2 with HN03
.020
Plastic
Filtered (.45 micron) Acidify to pH >2 with HN03
.100
Glass/Plastic Cool to 4C
0.1
Glass/Plastic Field Measurement Glass/Plastic Field Measurement
N/A N/A
Analytical methods equivalent to SW-846 (or analyses for parameters not listed in
100
DO 143631 CONFIDENTTAl
I 'ADEQUATE INADEQUATE!COMMENT
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
SW-846) must be approved by the administrative authority prior to implementation.
g) A chain of custody protocol must be employed that will allow for the tracing of possession and handling of samples
from the time of collection through laboratory analysis.
All sample containers must be labeled to prevent mis-identification, have proper
seals, and indicate the test parameters required.
h) An up-to-date field log book must be kept at the site which documents for each sample the well identification number, measured total well depth,
water level,
water color (visual),
well evacuation procedures and equipment,
sample withdrawal equipment,
procedures
and
date,
time, sample identification numbers,
v';
field measurements (pH*' specific conductance, etc.) and methods,
name of collector,
field observations,
calculations of the standing water volume in the well, and the
total volume evacuated.
4. The Leachate Monitoring Systems which include one (1) collection system for the Block 80 Landfill and two (2) detection systems for the Block 80 and Northwest Landfills must be maintained such that a
101
I
DO 1.4363? CONFIDENTIAL
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
'ADEQUATE INADEQUATE!C0MMEN
method to secur samples from an accessible surface location is provided in good working order at all times.
The collection system for the Block 80 Landfill must contain self-activating pumps which are capable of keeping the cell virtually free of leachate at all times.
The leachate collection system for the Block 80 Landfill shall be sampled semi annually for the constituents listed in Table 4B and annually for Volatile and Base Neutral compounds (Methods 624 and 625) .
The leachate detection system for the Block 80 Landfill shall be sampled semi annually for the constituents listed in Table 4B and annually for Volatile and Base Neutral compounds (Methods 624 and 625). The leachate detection points LD1, LD-2, and LD-3 shall be sampled semi annually for Volatile and Base Neutral compounds for the first three (3) years after issuance of this permit and annually, thereafter.
All analytical results must be submitted semi-annually.
Gallons of leachate removed must be reported with the semi-annual report.
102
DO 143633 CONFIDENTIAL
'ADEQUATE INADEQUATE I COMMENT
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
D. HAZARDOUS CONSTITUENTS, PARAMETERS AND CONCENTRATION LIN ITS
The hazardous constituents and concentration limits to which the protection standard of LAC 33:V.3305 apply are:
Constituents
Concentration! Limit, PPM
Benzene Carbon Tetrachloride
Perchloroethylene Hexachlorobutadiene Hexachloroethane
Hexachlorobenzene Arsenic Barium Cadmium Chromium Selenium
Antimony Lead Mercury Manganese Copper
Zinc Iron
Chloride
. 00,5 .00)5 .005 . oiJo .Olio
.010
.2
1.0
.01
.03 .01 .06 .0E
.002
1.0
1.0
5.0 25 250
The Permittee shall institute corrective actions in all areas where ground water has been affected by hazardous waste constituents or parameters exceeding the assigned concentration limits, and in other areas which may be discovered to exceed these limits in' the future.
!
The Permittee shall notify the administrative authority in accordance with Section VI.I. of this permit within seven (7) days after confirmation of the presence of any constituent equal to or exceeding the concentration limits authorized above.
E. POINT OF COMPLIANCE
The point of compliance at which the ground water protection standard of LAC 33:V.3305.A applies, and at which monitoring must be conducted is the vertical interval intercepted by the well screens identified by numbers UN-1, UN-2, DN-3, DN-4, NN-5, DN-6, DN-7, and DN-8 for the Northwest Landfill and
103
00 143A34 CONFTDFNTTAI
'ADEQUATE INADEQUATE! C0MMEI
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
numbers UH-1, DH-2, DH-3, and DH-4 for
the Block 80 Landfill.
When
contamination is detected in the existing
compliance zone, then the next vertical
permeable zone must also be monitored
during the compliance period. In the
event that there are no suitable
permeable zones for monitoring below the
lower limits of contamination that are
discovered,
the Permittee must
demonstrate, to the satisfaction of the
administrative authority, that soil
types, textures, and conditions for
thirty (30) vertical feet below the lower
extent of contamination would prohibit
the downward migration of contaminants.
The demonstration must include a certified geotechnical report on lithology, contaminant behavior, and conclusive analytical soil investigations for at least thirty (30) feet below the lowest limit of contamination.
The horizontal limit of compliance shall be the surface following an imaginary line connecting the risers of the above referenced detection monitoring wells.
Ground water quality at each monitoring
well identified above shall be determined semiannually, unless contamination has been detected, then monitoring must be' conducted quarterly.
F. COMPLIANCE PERIOD
The compliance period during which the ground water protection standard of LAC 33:V.3305 applies is the active life of the regulated units, and ends when clean closure is achieved or, after a corrective action program has been implemented, and the Permittee has demonstrated that the corrective action has been effective and the ground water protection standard of LAC 33:V.3305 has not been exceeded for a period of three
(3) consecutive years.
The Permittee shall determine ground water quality in the uppermost permeable
104
DO 143635 CONFIDENTIAL
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
'ADEQUATE INADEQUATE!COMMENT
zone throughout the active life of the facility plus thirty (30) years for any post-closure care monitoring, or as required by the administrative authority.
G. GENERAL REQUIREMENTS
1. The Permittee's ground water monitoring system for the previously identified hazardous waste management facilities shall consist of wells identified on Figures 1 and 2 which are monitoring wells UN-1, UN-2, DN-3, DN-4, NN-5, DN6, DN-7, and DN-8 and leak detection points LD-1, LD-2, and LD-3 for the Northwest Landfill and wells UH-1, DH-2, DH-3 and DH-4 for the Block 80 Landfill, unless exempted in the future by the administrative authority.
2. Upgradient wells UN-1, UN-2, and UH-1 must always yield ground water samples from the uppermost water bearing zone that are representative of ground water that has not been affected by possible leakage from the waste management units. Downgradient wells DN-3, DN-4, NN-5, DN6, DN-7, DN-8, DH-2, DH-3, and DH-4 must yield ground water samples from the uppermost water bearing zone that represent the quality of ground water beneath the facilities that reach points of compliance. Sampling points LD-1, LD- 2, and LD-3 must be utilized in the leak detection system as provided in Section VI.C.4.
3. The Permittee must maintain the structural and mechanical integrity of all wells and provide protection from accidental damage and surface infiltration and implement a monitoring well inspection schedule.
4. The Permittee must conform to the sampling and analysis requirements listed elsewhere herein and as required by LAC 33:V.3305.C. A ground water surface potentiometric map must be prepared each time ground water is sampled.
105
DO 1.43636 CONFIDENTIAL
'ADEQUATE INADEQUATE!COMMENT
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
5. The Permittee must use the statistical procedure outlined in LAC 33:V.3315 (Cochran's Approximation to the BehrensFisher Students' t-test) in determining whether background values or concentrations have been exceeded for the parameters identified in Section VI.H., herein. The Permittee shall be allowed to propose an equivalent statistical method, with supporting documentation, which must be approved by the administrative authority prior to implementation.
6. The Permittee must also graphically represent the values of pH and specific conductance for each sampling episode. The graphic interpretations of data must be submitted with the analytical results in the annual report and should be utilized in concert in all evaluations pertaining to facility impact on ground water.
7. Records of all sampling and analytical work must be maintained at the plant site during the life of the facilities, including post-closure care periods.
8. An annual ground water report must be submitted each year no later than March 1, as required by LAC 33 :V. 1529. This report shall summarize all ground water activities for the preceding calendar year including an evaluation of the monitoring strategy in relation to, the direction of ground water flow and locations of wells associated with the facilities. Applicable calculations must also include ground water and contaminant migration flow rates and statistical comparisons, and other information as regards corrective actions required by this permit.
H. DETECTION MONITORING PROGRAM
I. The Permittee must utilize the existing ground water detection monitoring system as required by LAC 33:V.3315 to obtain samples that provide a reliable indication of the presence of hazardous
106
DO 1436.37 CONFIDENTIAL
'ADEQUATE INADEQUATE'COMMEN
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
wastes or constituents in ground water when compared to background values.
The system shall be sampled semiannually
for the detection program.
Within
fifteen (15) days after completing the
analytical work and review of analyses
and computations, the Permittee shall
submit a report to the administrative
authority containing the test results,
the statistical comparative data, and
ground water potentiometric maps for that
sampling event. Copies of the field log
book notes and chain of custody where
appropriate, and a list of the parameters
that were statistically significant or
exceeded drinking water standards must
also be forwarded for review by the
administrative authority.
3. The sampling and analysis program outlined in Section VI.C.3. must be
utilized for ground water sampling.
4. If the Permittee determines that there
are statistically or otherwise
significant changes in parameters,
constituent measurements,
or
concentrations in any monitoring well,
the Permittee must notify the
administrative authority of this finding
in writing within seven (7) days after
receipt and evaluation of the analytical.'
results. The notification must identify
those parameters that hare shown the
significant changes. The Permittee must
also immediately resample within thirty
(30) days to confirm the findings. If
the resampling effort confirms that an
impact to ground water has occurred, the
Permittee must submit an application for
a permit modification to the
administrative authority within ninety
(90) days from the date of the resampling
effort. The application must include a
plan certified by a geologist or
geotechnical engineer for a ground water
quality assessment and search for
additional
hazardous
wastes
or
constituents that could reasonably be
expected to be associated with facility
operations as listed in Table 1, LAC
107
HO 143638
CONFIDENTIAL
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
'ADEQUATE INADEQUATE ICOMME
33 :V. Chapter 31 as amended and shall Include the identification and evaluation of all compounds appearing on the analytical chromatograph. The plan must also incorporate schedules for the institution of compliance monitoring programs and corrective actions, as applicable, to meet requirements of LAC 33:V. Chapter 33.
5. If the Permittee determines that the ground water protection standard of Section VI. D is being exceeded in any monitoring well, he may demonstrate within thirty (30) days of the determination that a source other than a regulated unit caused the increase or that the increase resulted from an error in sampling, analysis, or evaluation. The Permittee must investigate and correct all confirmed ground water contamination problems at the direction of the administrative authority and as stipulated under Section VI.0. of this permit, regardless of the source of contamination.
6. Upon determination that the detection monitoring program no longer satisfies the requirements of this Chapter, the Permittee shall submit an application for a permit modification ' to the administrative authority within ninety (90) days.
I. COMPLIANCE MONITORING
The Permittee shall establish a compliance monitoring program in accordance with LAC 33:V.3319 whenever hazardous constituents are confirmed in any monitor well.
1. The Permittee shall determine the concentration of each hazardous constituent listed in VI.D. at least quarterly during compliance monitoring periods until this requirement is terminated in writing by the administrative authority.
108
DO 143639 CONFIDENTIAL.
f
'ADEQUATE INADEQUATE I COMMEh
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
2. If the Permittee determines, pursuant to LAC 3;V. 3319.H that the ground water protection standard is being exceeded at any monitoring well at the point of compliance, he must:
a) Notify the administrative authority of this finding in writing within seven (7) days. The notification must indicate which concentration limits have been exceeded; and
b) Submit, to the administrative authority, an application for a permit modification to establish or modify corrective action programs meeting the requirements of LAC 33:V.3321 within 180 days, or within ninety (90) days if an engineering feasibility study has been previously submitted to the administrative authority under LAC 33:V.3317.H.5. The application must include the following information:
(1) A detailed description and schedule for corrective actions that will achieve compliance with the ground water protection standard specified in the permit under LAC 33:V.3319.A; and
(2) Certified geotechnical plans for a ground water monitoring program that will demonstrate the effectiveness of the corrective action. Such a ground water' monitoring program may be based on a compliance monitoring program developed to meet the requirements of this permit, except that the Permittee will be required to monitor as frequently as necessary by the administrative authority in order to generate sufficient data for demonstrating the effectiveness of the corrective actions.
(3) A plan to extend the compliance points both vertically and horizontally, unless this requirement is terminated in writing by the administrative authority.
3. The Permittee shall evaluate all compliance monitoring wells identified in Section VI.E., herein, for the presence of all constituents listed in Table 1 LAC
109
DO 143640 CONFIDENTIAL
'ADEQUATE INADEQUATE!COMMENT
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
33 :V. Chapter 31, for which there are reliable test methods and that may be expected to be associated with facility operations, on an annual basis. The Permittee shall also be required to identify, quantify, evaluate, and report all compounds appearing on the sample analytical chromatographs, that are detected at the method detection limits of the equipment and that may represent fugitive compounds associated with facility operations, regardless of whether or not the substances are identified in Table 1, LAC 33:V. Chapter 31 and the results must be included in the annual report.
J. CORRECTIVE ACTION PROGRAM
1. The owner or operator must conduct a corrective action program to remove or treat in place any hazardous constituents in the ground water that exceed concentration limits between the compliance point and the downgradient facility property boundary.
2. The Permittee must implement the assessment plan for the chloride plume in the Chlorine Plant area on file with the administrative authority within sixty (60) days after the issuance of this permit and implement a corrective action ' or mitigation program within sixty (60) days after conclusion of th'e assessment phase.
3. Additionally, and in accordance with the authority of R.S., 30:1096D of the Louisiana's Water Control Law and the Environmental Quality Act, R.S., 30:1051 et seq., as a condition of this permit, the Permittee must notify the administrative authority upon learning of the discharge of any waste or substance into the ground waters of the State at the Dow Chemical plant site. As a result of such discharges to ground waters the Permittee shall:
a) Notify the administrative authority of the nature and circumstances of the
110
DO 143641. CONFIDENTIAL
DOW, PLAQUEMTNE PERMIT INSPECTION CHECKLIST JANUARY, 1990
`ADEQUATE! INADEQUATE!COMMEN'
discharge within seven (7) days of discovery.
b) Submit adequate plans and schedules, certified by a qualified geologist or geotechnical engineer to evaluate the extent of the discharge and need for corrective actions within ninety (90) days from the notification in Section VI.J.3.a.) above.
C) Submit a schedule and plans for corrective actions as directed by the administrative authority, within sixty (60) days from completion of the ground water evaluation in Section VI.J.3.b.) above.
K. ABANDONMENT OF MONITORING WELLS
The Permittee shall provide for the sealing of any vertical migration path resulting from exploratory borings and/or monitoring programs as provided in LAC 33:V.3323 or follow abandonment procedures as directed by the administrative authority.
Ill
I
DO 14064?
CONFIDENTIAL
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
'ADEQUATE | INADEQUATE! COMMENT
Mr. Michael Nevill Environmental Services Manager Dow Chemical, USA Post Office Box 150 Plaquemine, Louisiana 70765-0150
RE: Proposed Installation of Leak Detection Points Northwest Landfill (LAD008187080)
Dear Mr. Nevill: The Department hereby approves of the
proposed locations of the shallow leak detection wells at the Northwest Landfill, as discussed with Ms. Elizabeth Simpson on December 1, 1987.
If you have any questions, please call the Ground Water Protection Division at (504) 342-8950.
00 143643 CONFIDENTIAL
`ADEQUATE INADEQUATE ICOMMEN
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
VII.
SPECIAL CONDITIONS PURSUANT TO THE 1984 HAZARDOUS AND SOLID WASTE AMENDMENTS OF RCRA
A.SPECIFIC CONDITIONS
1. Permitted Process Units.
2. Waste Minimization.
The Permittee shall certify (Attachment A) annually by October 1, for the previous
year ending August 31, that:
a) the Permittee has a
program in place to reduce the volume and toxicity of all hazardous wastes that are generated by the Permittee's facility's
operation to the degree determined to be economically practicable, and
b) the proposed method of treatment, storage, or
disposal is that practicable method currently available to the Permittee which minimizes the present and future threat to human health and the environment.
The certification is to be
included in the operating record.
3. Dust Suppression.
As stated in 40 CFR 266.23(b), the Permittee shall not use waste or used oil or other
material, which is contaminated with dioxin or any other hazardous waste (other than a waste identified solely on the basis of ignitability), for dust suppression or road treatment.
4. Solid Waste Management Units.
1
DO 143644
CONFIDFNTIAL
i il
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
The Permittee shall immediately
notify the administrative
authority of any release of
hazardous waste or hazardous
constituents that may have
occurred from any Solid Waste
Management Unit (SWMU) at the
facility regardless of when the
release occurred or may have
occurred, and regardless of
when the waste was place in any
unit. Release occurring from
any SWMU will constitute
grounds for a major permit
modification as necessary to
incorporate into the permit
appropriate corrective action,
or other actions as deemed
necessary by the administrative
authority. Pursuant to such
permit
modification,
the
Permittee shall then take
timely corrective action for
such releases. Also, if the
Permittee becomes aware of any
SWMU not addressed in the RCRA
facility
assessment,
the
Permittee must:
a) immediately notify the administrative authority, and
b) submit within- ^forty-five
(45) days of becoming
aware of a solid waste
management unit,
sufficient information to
conduct a RCRA facility
assessment of the solid
waste management unit to
determine if there has
been or is currently a
release from the unit.
The Permittee is to
contact the administrative
authority for guidance
regarding the required
information to be
submitted.
Based upon
this information, the
administrative authority
f 'adequate; inadequate icomme:
PLAQUEHINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
will modify the permit accordingly.
5. Definitions.
a) Release - any spilling,
leaking, pumping,
emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment.
b) Solid waste management
unit - "any discernible
solid waste unit at a RCRA
facility from which
hazardous wastes or
constituents might '
migrate, irrespective of
whether the unit was
intended for the
management of solid and/or
hazardous waste" (USEPA,
1986) .
The SWMUs
* definition includes
S container storage units;
tanks;
surface
impoundments; waste piles;
land treatment units;
landfills; incinerators;
underground injection, I
wells; physical, chemical
and biological treatment
units; recycling units;
and areas contaminated by
routine, systematic, and
deliberate discharges from
process areas.
B. SURFACE
IMPOUNDMENT
CONDITIONS
SPECIFIC
1. Closure.
After November 8, 1988, the
Permittee shall not place
hazardous and/or non-hazardous
waste
in any
surface
impoundment.
The Permittee
shall close the all surface
impoundment in accordance with
the Closure Plan conditions in
the RCRA permit. The Permittee
DO 1.436.46 CONFIDENTIAL
'ADEQUATE INADEQUATE! COMMENT
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
shall notify the administrative authority in writing of the intent to close the said surface impoundment no later than 30 days prior to the last volume of waste received in the surface impoundment.
2.Specific Waste Ban.
The Permittee shall not place any hazardous waste restricted by 40 CFR 268 into the surface impoundment unless:
a) the waste meets treatment standards specified in 40 CFR 268.40, .41, .42 or .43?
b) a variance from the treatment standards has been granted pursuant to 40 CFR 268.44;
c) a petition has been granted for a case-by-case extension to the effective date, pursuant to 40 CFR 268.5;
d) a "no-migration" petition , has been granted pursuant' to 40 CFR 268.6; or
e) the surface impoundment is exempt under 40 CFR 268.4.
C. CORRECTIVE ACTION CONDITIONS FOR RELEASES AT SOLID WASTE MANAGEMENT UNITS
1. Assessment/Analvsis Plan.
The administrative authority has determined that additional solid waste management units exist at the facility which receive, have received, or have the potential for receiving hazardous waste and/or hazardous constituents. These additional solid waste management units, included in
DO 1,4364 7 confidential.
i
t `ADEQUATE INADEQUATE IC0MMEN1
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
Section Vix.c.l.a., have been
identified as having the potential to release hazardous waste or constituents to the air, soil, surface water, or ground water but for which a release is unconfirmed. The
Permittee shall submit to the
administrative authority an assessment/analysis plan that
will describe the methods and provide a schedule (if necessary) that the Permittee will use to clearly confirm the presence or absence of a release.
a) An assessment/analysis plan, as described in Section VII.C.1., shall be submitted for each of the following units within sixty (60) days after the effective date of this
permit.
It should be noted that only SWMU's with suspected releases or information deficiencies were listed in Section Vll.C.l.a. and the list did not contain of any RCRA unit regulated under the __ permitting process (but'does include exempted units).
b) Any revisions to the plans shall be as specified by the administrative authority and resubmitted by the dates specified by
the administrative authority.
c) After the plans have been
revised to the
administrative authority' s
satisfaction,
the
Permittee shall implement
the plans and submit
documentation to verify
the presence or absence of
releases according to the
DO 143648
I 'ADEQUATE INADEQUATE!COMMEN'
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
schedule specified by the administrative authority.
d) If the Permittee becomes
aware of any additional
solid waste management
unit(s)
that have
potential to release
hazardous waste or
hazardous waste
constituents other than
those identified and
addressed during the RCRA
Facility Assessment
process the Permittee
must:
(1) Immediately notify the administrative authority.
(2) Submit within sixty
(60)
days of
becoming aware of any
additional
solid
waste management
units
an
assessment/analysis
plan in accordance
with Section VII. c. 1.
(3) Comply with Section,
VII.C.2.
upon
discovery of a
release.' -
2 Remedial Investigation Plan.
For each unit from which a release has been determined, a Remedial Investigation Plan that describes the methods and schedules the Permittee will use for defining the nature and extent of contamination from releases of all hazardous wastes or hazardous
constituents to the air, soil, surface waters, ground waters,
and/or subsurface gas shall be submitted to the administrative authority within sixty (60) days of submittal of the
DO 143049 OONrtDFNTTA!
'ADEQUATE INADEQUATE ICOMMEN'
PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
documentation required Section VII.c.l.c.
by
a) At the time of submission
of the plan required by
Section VII.C.2., all
available information
regarding the release and
information regarding an
assessment of the release
shall also be submitted.
The Permittee shall
contact the administrative
authority in writing for
guidance regarding the
required information to be
submitted. Based on this
information,
the
administrative authority
will modify this permit as
necessary pursuant to CFR
Part 270.41.
b) A Remedial Investigation
Plan outlining the methods
and schedules that the
3: Permittee will use to
S determine the nature and
extent of contamination
from hazardous waste or
hazardous constituents in
the air, soil, and surface
water shall be submitted
for each of the following'
solid waste_ management
units within*'sixty (60)
days after the effective
date of this permit.
c) Any revisions to the Plans shall be as specified by the administrative authority and resubmitted by the dates specified by the administrative authority. The Permittee shall also submit
additional information on ground water monitoring and/or perform additional
ground water monitoring as specified by the administrative authority.
DO 143650 CONFIDENTIAL
'ADEQUATE INADEQUATE I COMMENT
DOW, PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
d) After the Remedial
Investigation Plans have
been revised to the
administrative authority s
satisfaction,
the
Permittee shall implement
the Plans according to the
schedules specified by the
administrative authority.
3. Corrective Action Plan.
Within ninety (90) days of completion of the remedial investigation done in accordance with Section VII.c.2., the Permittee shall submit for approval to the administrative authority a corrective action plan which outlines the corrective actions, if any, to be taken at each unit. The plans must include a description of the proposed corrective measures and the methodology's effectiveness in relationship to the hazardous waste or hazardous constituents, a schedule of implementation, and a cost estimate for the corrective action at each unit.
v'
All data should be summarized and presented in an appropriate format.
a) Any revisions to the corrective action plans shall be as specified by the administrative authority and resubmitted by the dates specified by the administrative authority.
4. SCHEDULES OF COMPLIANCE
All plans shall contain time schedules for completion including interim milestones.
The time between interim milestones shall not exceed one year.
DO 143651 CONFIDENT! A!
'ADEQUATE INADEQUATE ICOMME
PLAQUEMINE PERMIT INSPECTION CHECKLIST JANUARY, 1990
If the time necessary for
completion of any interim activity is more than one year and is not readily divisible
into stages for completion, the schedule shall specify interim dates for the submission of reports of progress toward completion of the interim requirements.
Reports of compliance or noncompliance with, or any
progress reports on, interim and final requirements contained in any compliance schedule of this permit shall be submitted no later than fourteen (14) days following each schedule dates as required by 40 CFR Section 270.30(1) (5) .
5. PERMIT MODIFICATION
This permit will be modified
s pursuant to 40 CFR Section 270.41 to incorporate the Corrective Action Plans
developed under Section Vll.c.3 and financial assurance for corrective action as required
under 40 CFR Section 264.101, (Amendments to 40 CFR, July 15,`; 1985, 50 Federal Register 28747) .
TABLE 3 WASTE STREAM COMPOSITIONS
EPA WASTE NUMBER F024
ANALY
sisa
Carbon Tetrachlor ide - 1035% Dichloropr opane -30-
, , -50%
112 Trichloroe thane - 530%
DO 143652 CONFTDFNTTAL
Tetrachlor oethane 5-30%
Miscellane ous -0-1%
K019
1,2Dichloroet hane - 1050%
1,1,2-Trichloroethane - 10-50% Tetrachloroethane - 5-50% Penta - 0.5-5%
Chloroethane - 0-2%
K030
Hexachloroethane - 10-40%
K0X6
Hexachlorobutadiene - 5-20% Hexachloroberizene - 30-70% Perchloroethylene - 5-20%
K073
Liquid Chlorine - 30-70% Carbon Tetrachloride - 30-70% Hexachloroethane - 0-0%
Hexachlorobutadiene - 0-0. 1%
a Method 5030 (GC) - SW846
Do 143653 CONFTDFNTJAI.
3 Vinyl IX
TABLE 4
T--400
1.2- Dichloroethanea Carbon Tetrachloride 1,1-Dichloroethane chloroform Trichloroethylene Ethyl Chloride Vinyl chloride 1.1.2- Trichloroethane Pentachloroethane Chlorinated Propenes Chlorinated Butenes Tetrachloroethane Chlorobenzene Vinylidene Chloride trans-Dichloroethylene cis-Oichloroethylene Carbon (NVM) & Unknown HC1 NAiit1rogen
T-420 15%
mm
30% 7%
15% 15%
2% 1.5%
14.5% *--
.1%
irm
60% 13% 3.5% 1.3% 0.3% 1.2% 5.0%
mm
______
m*
-- --
--15.7%
--
Mm
.1%
3ENIS
5% 7% 2% 32%
----
35% 0.5%
__
MM
WM
MM
MM
0.5% 12% 6%
LAB K&sjE
50% 15%
5%
40%
5% 5% 5% 5%
Mm 30%
M M 30% 10%
1%
.l%e
l%e .l%e
DO 143654 CONFIDENTIAL
ea^e
Ae : note.
Same aHacA-ww..e*uu.1As
^>ro o A
a vo
hav>t r\o4 tee. r\.
inelu.cjLecL IrL
+ h',
cof^
"TLl.V^k^O us iCbrTJ
DO 143655 CONFTDFNTTAt