Document remNyDBgqO1gDv1BD3EdqZwwG

'f Qorr\tf\en<, ^ \\& August 31, 1988 Project No. 435248 P, 0. Box 605 Westlake, Louisiana 70669 Dear Mr. Taylor: Enclosed herewith Is a revised draft of the Source Determination Report. This draft Incorporates Conoco/Vista's conments on the first draft and is organized differently from the first draft. Additional conments are requested. The terminology used to label the high risk areas need to be standardized between the various Ground Water Quality Assessment Reports. Also some assistance Is needed in delineating the various facilities within the high risk areas. The figures will be drafted upon completion of the text. Concentration zone maps are preferred over Isoconcentration maps for delineating the subsurface contamination areas since data from different sampling events were used. Please call me if you have any comments or questions. Very truTy yours. W. Howard Johnson Hydrogeologist Enclosure WHJ:cag 0 CON/WOJOTAYLO VW 00000833 3 1150 LeBlanc Road Port Allen. LA 70767 (504) 344-8530 SOURCE DETERMINATION 1.0 INTRODUCTION As part of the Phase III Groundwater Quality Assessment at the Vista Chemical Complex, IT Corporation (IT) has prepared this source determination report. This report is generally a correlation of the areas within the plant identified as potential sources of chlorinated hydrocarbons with the distribution of EDC contaminated water in the 10-foot, 25-foot, and 50-foot sands which underlie the plant. In July, 1986 Vista Chemical presented a report to the Louisiana Department of Environmental Quality (LDEQ) summarizing the known leaks, spills, and releases of hazardous materials or hazardous wastes with potential for impacting groundwater. The plant facilities which have been identified as potential sources can be grouped into the following high risk areas: Waste Management Area I, Waste Management Area II, Product Storage Area, and Secondary Wastewater Treatm a Area. These areas are identified on Figure 1 and encompass portions of the plant's processIngx^Yacilities, waste management facilities, loading/unloading fac111t1ea,>and storage facilities. 2.0 SUBSURFACE CDC DISTRIBUTION Figures 2, 3, and 4 illustrate the distribution of EDC in the 10-foot, 25foot, jand 50-foot sands. These EDC distribution maps were developed primarily from the data obtained during the July/August 1987 and January/February 1988 sampling events. However, data from other more limited sampling events were also Incorporated. The direction and rate of EDC movement through the subsurface will be addressed In the Rate and Extent Report. WV 000003334 1 The 10-foot sand is a silty sand to sandy silt of variable thickness and occurs in a zone from about five feet to 15 feet below land surface. This unit occurs on the northern half and along the western boundary of the Vista plant. Figure 2. Two areas of relatively high EDC concentrations (>100 ppm) have been identified in the 10-foot sand. These areas coincide with Waste Management Area I and Waste Management Area II. The 25-foot sand is a silty sand to sandy silt occurring in a zone between 17 and 25 feet below ground surface. The thickness varies from 1 foot on the western boundary to about 14 feet at the Secondary Wastewater Treatment Area. This unit pinches out to the north. Figure 3. Two areas of high EDC concentration (>100 ppm) are present in the 25-foot sand centered at Waste Management Area II and at the Product Storage Area. These highr'concentratian areas are coalescing north of the chemical storage to form a sjingle elongate area. Another area of lower EDC concentration (<100 ppm) is located beneath the Secondary Wastewater Treatment Area. The 50-foot sand is a fine grained sand with thicknesses up to 15 feet and occurs at depths between 55 and 70 feet below land surface. This sand unit occurs in a northeast/southwest oriented band beneath the plant. Figure 4. A small area of high EDC d^acentration (>100 ppm) is located within the 50-foot sand beneath the easterrf side of the ProtAss Storage Area. V 3.0 EOC SOURCE AREAS 3.1 WASTE MANAGEMENT AREA I Waste Management Area I Is located on the northern edge of the VCM plant. Figure 1. WMAI Is composed of the following facilities. Copper Neutralization Pit area Acid Neutralization Pits, and Wooden Vent Line and Stack. The Copper Pit Area, sometimes referred to as the rock weathering area, occupies the large northern portion of WMAI. Table 1 contains a listing of VVV 000008335 2 the hazardous material spill events between 1970 and 1979. In general the area surrounding the Copper Pit was where spent limestone rocks and solids from T-500 were placed. The T-500 basin collected liquid EOC from the process prior to the construction of the T-l and T-2 settling basins. The original Copper Neutralization Pit was constructed without a liner. The treatment of soluble copper originating from the hydroblasting of oxychlorination reactors occurred in this pit. Rinsate from the hydroblasting was drained to the center trench of Block One in the main process area. Liquid from the trench was pumped to the pit. Other equipment containing EOC which was rinsed or discharged to grade at the Block One trench was also pumped to the Copper Pit. The original Copper Pit was replaced in 1979 by a concret^ lined basin referred to now as the Copper Pond. Waste is put into the pond only during plant turnarounds. Waste in the pond was sampled^by Vista/Conoco following the April 1987 turnaround. No EOC was detected irrthe sample. The Acid Neutralization Pits are lo/ated on the southern portion of WMAI. These pits were used to treat loi# pH wastes from the incinerator. No rchlorinated hydrocarbon 1 events have been documented in this area. The Wooden Vent Line and Stack are located on the northeastern portion of WMAI. Ouiffng its operation, condensate of EDC and heavier chlorinated vent constituenp'Mn a low pH liquid discharged to grade through leaks and unsealed joints. The wooden vent line lead to an unlined concrete sump at the base of the stack. The base failed in the late 1970's allwiyg some condensed liquids to go to grade. The sump was replaced and upgradwfc* Some additional leaks & were also possible from the wrapped joints on the vitrified line which drained, the sump to the In-plant sewer system. Currently the wooden vent line and stack are unused. ^ 3.2 WASTE MANAGEMENT AREA II Waste Management Area II is located near the center of the VCM Plant, Figure 1. WMAII is composed of the following facilities: VVV 000008336 3 Process Area and Wastewater Treatment Area (C-500). a Table 2 gives the spill history for the/Process Area. Block one, the main processing area, was started up in Jaryary 1968. From startup until 0SHA_EDC exposure requirements went into' place, pumps, piping, and other equIpment'Cere cleared of EDC by discharging the liquid to grade. \ Sample purges were also discharged to grade. The center trenches of each block are used to collect A ^ EDC and other spills which occur through daily operation, plant turnarounds, and the hydroblasting of oxychlorination reactors. These trenches -have yV- V- repeatedly cracked.and a large section of trench was replaced in late 1984. X ,,\0 Table 3 lists the spill history for the Wastewater TreatmenWArea (C-500). This facility is located on the northern third of WMAII. It consists of three pits or basins along with the associated pumps and piping. The T-500 pit was constructed with the original plant. The facilitv^as constructed of concrete with acid brick interior lining with an intermediate spray on liner. The T500 pit received EDC continuously EMior to construction of the settling basins. The T-l and T-2 settlinc^3sins are constructed of concrete with an acid brick liner separated by a sprjay on liner. These facilities, primarily T-2, receive process wastewater. EDC collects in the bottom and is removed for rnprorionnlfg J C&COiJQX&A r&rwkrvdukaom paces'? * 3.3 PRODUCT STORAGE AREA "' The Product Storage Area, Figure 1, is located In the west-central portion of the VCM plant. The Product Storage Area Includes the following facilities: Main Plant Product Storage Tank Car Loading Rack, and Heavy Ends Truck Loading Area. VVV 000008337 The Main Plant Product Storage constituents the large central portion of the Product Storage Area. Table 4 lists the spill history for the Main Plant Product Storage Area. Several of the storage tanks have developed leaks and were repaired or replaced. Many of the leaks were discovered when EDC was observed flowing along the tanks base or bubbling in the soil. Several other spills have resulted through leaks in the product storage pipes and pumps and accidental spills during sampling and other daily plant operations. The Tank Car Load' Rack is located at the railroad tracks on the south side of the Product Storage Area. Table 5 lists the spill history for this facility. EOC and light ends spills at the Tank Car Load Rack resulted from piping leaks, tank car leaks, and sampling spills. Table 6 lists the chlorinated hydrocarbon spill history for the Heavy Ends Truck Loading Area. This facility is located along the eastern boundary of the Product Storage Area. Spills at this facility occurree>jJ^prom trailer leaks, trailer overflows, and sampling spills. 3.4 SECONDARY WASTEWATER TREATMENT AREA The Secondary Wastewater Treatment Area is located) on the southern half of the VCM Plant, east of Turtle Pond, Figure* 1. This facility receives and treats wastewater from the VCM Plant and theAta Chemical Plant. Table 7 lists the chlorinated hydrocarbon spill history for this facility. Prior to March, 1972, in the area now oc^^ed by the North and South Sludge Ponds, wastewater was discharged into the {old waste effluent area or "borrow pit". This was an fjunlined pito which wastewater containing 2,000-3,000 ppm EDC was.discharged. Table 8. V Conoco/Vista conducted an impoundment assessment In 1987 where sludge samples were collected from the various ponds and lagoons which comprise this facility. The highest detected EOC concentration was located In the West Equalization Basin, 2,270 ppb. The West Equalization Basin receives wastewater from the VCM process facilities, steam stripper bottoms and rainwater runoff. The West Equalization Basin discharges to the ASU Basin and then to the LCVCM Rearatlon Basin. No EDC was detected In sludge samples from the latter basins indicating that the treatment process Is removing the EDC. Wastewater from the Vista Chemical Plant is discharged to the North and South Lagoons. An EOC concentration of 71 ppb was detected in a sludge sample from the north lagoon. A South Lagoon sludge sample contained less than 2 ppb of EDC. yyy 000008338 5 4.0 CONCLUSIONS The four high risk EDC source areas correspond with the areas identified in the 10-foot and 25-foot sands which have relatively high concentrations of EDC (>100 ppm), except at the Secondary Treatment Plant where no EDC concentrations over 100 ppm have been detected. A review of the chlorinated hydrocarbon spill history reveals that the largest volume of EDC was released in the period between plant startup in 1968 and the implementation of OSHA EDC exposure requirements in 1979. Since that time plant operational procedures have been upgraded, additional waste treatment facilities have been installed, and a more vigilant leak detection and plant maintenance program has been initiated. At present the only EDC releases occur from accidental spills 1 during product transfer operations and possible/from undetectetf^leaks in the * plants wastewater sewer system. ;! Certain facilities within each of the high rikk' EDC source areas can be identified as the primary origin for EDC found in the subsurface sand units. This determination can be based on/Yhe spill history, the amount of EDC released, and the location of the merest EDC concentration beneath the EDC source areas. In some situations the type and relative amount of chemical constituents identified^! groundwater samples will indicate a particular facility. However, spills from different sources can combine in the subsurfac&^-apd chemical constituents can fractionate or degrade in the subsurfaca. 7 The most likely source of EDC in the 10-foot sand at Waste Management Area I is the original Copper Pit which has since been closed and the wooden vent line and stack which is no longer in use. These two facilities processed and leaked more EDC than the other facilities in WMAI. Also, the highest EOC concentration (9,221.9 ppm) was detected in monitor well VA-1 which is nearest to these facilities. At Waste* Management Area II EDC spills were relatively large and frequent during the period between 1968 and 1980 from the plant processing facility. The processing facility probably contributed the largest amount of EDC to the 10-foot and 25-foot sands. However, the high concentration of EDC In monitor VVV 000008339 6 wells VA-1Q (1,739.92 ppm), VCM-4 (1,319.4 ppm), and VCM-6 (7,430 ppm) which are completed in the 10-foot sand adjacent to Wastewater Treatment Area (C500) would indicate that facility as the most likely EDC source. Monitor well VB-2 was located between the Processing and Wastewater Treatment Facilities and monitored the 25-foot sand. EOC concentrations as high as 3,177.5 ppm were detected in this well. VB-2 was plugged and abandoned in May, 1986 due to concern about the integrity of the wells annular seal. VB-2 was replaced with VB-4. VB-4 is located near the southeast corner of WMAII approximately 200 feet southeast of VB-2. EDC concentrations of 2,231.15 ppm have been detected in VB-4. The EDC detected in the 10-foot and 25-foot sand probably originated from both the Processing and Wastewater Treatment facilities. The implication that the Wastewater Treatment facility is the primary source of EDC as inferred from the water quality data is probably an -tfrftlfact of the well placement. At the Product Storage Area the large spililllss flrrodm the Main Plant Product Storage Tanks contributed the most EDC to the 29-foot sand. An analysis of phase EDC collected from monitor well yfERB-2 was inconclusive as to the origin of EDC, Appendix A. As mentioned earmer subsurface mixing, fractionation, and degradation obscures chemical signature of the original source. The presence of EDC in the 25-foot sand at the Secondary Wastewater Treatment Area probabT)j originated in the Old Waste Effluent Area. The current wastewaterjt^featment facility appears to be adequately treating and degrading the EDC sent there from the VCM Plant and the Vista Chemical Plant. CON/SOURCE-OET VVV 0000083*0 7 /" VVV 000008341 TABLE 1 MISCELLANEOUS AREAS CHLORINATED HY0R0CAR80N SPILL HISTORY COPPER PIT AREA type of eventoate(S)equipment/location Pumping of Wash. Water to Earthen Copper Pit (7) 8/72-0/79 Copper Pit/Copper Pit Area Disposal of Contaminated Soii North of C-5O0 Stack Unknown None/Copper Pit Area Copper Pit Pumped to Grade 7-13-77 Copper Pit/Copper Pit Area no, of eventsvolume 9 (t) (8) (M I (1) NOTES: (1) Volume cannot be reasonably catcu or estimated. (7) A new concrete basip-wes installed in August, 1979. (S) Cannot be accurat letermined. CON/SOURCE-TBS wv 000008342 TABLE 2 PROCESSING AREAS CHLORINATED HYDROCARBON SPILL HISTORY TYPE OP EVENT DATE(S) EQUlPMENT/lOCATIQN Underground Closed 1978 - 1986 Process Sewer Leaks Closed Process Sewer/ Process Area Spills, Leaks, Release to Grade 1970* - 1966 All Processing Equipment/ Process Area NO, OF EVENTS (6) (7) VOLUME 1) (1) NOTES: () Records prior to 2*18-70 are unavailable. (!) Volume cannot be reasonably calculated or estimated. (6) Number of events cannot be accurately determined ((fprStitdimi ated to be 2-4). (7) Due to the fact that the entire processing area is paved and contains a spill collection system (trenches to a coiAined sump T-2), emphasis was not directed toward providing a detailed l istin^jT'spi 11 events in this area. 0 CON/SOURCE-TBS VVV 000008343 TABLE 3 WASTE MANAGEMENT AREAS CHLORINATED HYDROCARBON SPILL HISTORY WASTEWATER TREATMENT AREA TYPE OF EVENT Piping Leaks Pump Seal Leaks Pump Clearing Repairs to T-l Pit Repairs to T-2 Pit Repairs to T-500 Pit DATE(S) EOUIPMENT/IOCATION 1970* - 1986 EDC Piping/C-500 Wastewater Treatment Area 1970* - 1986 1970* - 1986 P-604/C-500 Wastewater Treatment Area P-604/C-500 Wastewater Treatment Area 10-31-73 T-l Pit/C-500 Wastewater Treatment Area 6-27-83 T-2 Pit/C-500 Wastewater TreatmmnV Area 1979 T-500 Pit/C/500 Wastewater % Treatment Area NO. OF EVENTS 22 22 VOLUME (2) (I) (1) 10 gals. (4) <U (D (1) NOTES: (*) Records prior to *70 are unavailidle. (1 foiume cannot De reasonably calculated or estimated* (2) These are calculated or estimated volumes released to grade prior to remedial action. The amount which was not recovered through remedial action and potentially affected groundwater is unknown.4 (4) Estimated to be 5 gallons release to ground per event. CON/SOURCE-TBS VVV 000008344 TABLE 4 STORAGE AREAS CHLORINATED HYDROCARBON SPILL HISTORY MAIN PLANT PROOUCT STORAGE TYPE OF EVENTOATE(S)QUI PMENT/LOCAT I ONNO. OF EVENTSV0LUME<2) Storage Tank Bottom Leaks 3-01-79 I I-17-79 T-451/Dke Area T-450/Dike Area (1) (t) 9-03-85 T-405/Dike Area l .5-15 gals. 1-22-86 T-450/Dike Area >475 gals. Storage Tank Overflow Heavy Ends Trailer Overt low Transfer Piping Leaks Pump Seal Leaks Samp Iing 12-28-75 T-402/Dike Area 1-03-86 T-405/Dike Area 1970* - 1986 T-402,405,450,451,452 453,460 Piping/Dike Area and Piperack 1970* - 1986 P-402,405,45C^I51 ,452, 453,460/Outjffde Oike Area n1970* ^ 190 P-402,405,450,451,452 453,460,5-460,461/ Outside Oike Area (U 1\075 gals.(3) 4 5 15 (1) 145 3700 (1) 925 gals. (5) Storage Tank Cleaning V 1970* - 1986 T-402,405,450,451 ,452, 453,460/Dike Area Pump Clearing 1970* - 1986 P-402,405,450,451,452, 453,460/Outside Oike Area Hose Spill 1-16-86 Hose Spill/Inside Dike Area 30 145 (1) 725 gals. (4) 2 gals. (3) NOTES: (*) Records prior to 2-18-70 are unavailable. (1) Volume cannot be reasonably calculated or estimated. (2) These are calculated or estimated volumes released to grade prior to remedial action. .The amount which was not recovered through remedial action and potentially affected groundwater is unknown. (3) Remedial action included disposing all free liquid and removing top layer of contam inated soil. VVV 000008345 (4) Estimated to be 5 gallons release to ground per event. (5) Estimated to be 1 quart release to ground per event. GON/souRcc-res TABLE 5 LOAD ING/UNLOAOING AREAS CHLORINATED HYDROCARBON SPILL HISTORY TANK CAR LOAD ING RACK TYPE OF EVENTDATE (S)EQUI PMENT/LOCAT lONNO. OF EVENTSVOLUME(2) Piping Leaks Sampiing Tank Car Leaks 1970* - 1986 Light Ends 4 EDC Loading Lines/Tank Car Loading Rack 1970* - 1986 EDC 4 LE Railcars/Tank Car Loading Rack 1970* - 1986 EDC 4 LE Railcars/Tank Car Loading Rack 112 (I) 28 gals.(5) (D NOTES: (*) Records prior to 2-18-70 are unavailable. (1) volume cannot be reasonably calculated or estimated. (2) These are calculated or estimatedI /ooM>6TrUies released to grade prior to remedial action. The amount Nhich was not recoveredthrough remedial action and potentially affected groundwater is unkknncojin. (5) Estimated to be I [qualrt release to ground per event. con/source-tbs 0000093*6 TABLE 6 LOAD ING/UNLOADING AREAS CHLORINATED HYOROCARBON SPILL HISTORY HEAVY ENDS TRUCK LOADING AREA TYPE OF EVENTOATE(S)EQUIPMENT/LOCATI ON NO. OF EVENTSVOLUME Heavy Ends Trailer Overt * i l (Discharge occurred in Storage Tank Dike Area - Refer to Table l-A) Heavy Ends Trailer Leak 1970* - 1986 Tars TraiIer/Heavy Ends Truck Loading Area 2 (1) Clean Tars TraiIer 1970* - 1986 Tars Trailer/Heavy Ends Truck Loading Area (6) (1) Samp Iing 1970* - 1986 Tars Trailer/Heavy Ends Truck Loading Area (6) (I) NOTES: () Records prior to 2-18-70 are unavai/a\le. (1) Volume cannot be reasonably calculated or estimated. j^'(6) Number of events t be accurately determined. CON/SOURCE-TBS VVV 000008347 TABLE 7 WASTE MANAGEMENT AREAS CHLORINATED HYDROCARBON SPILL HISTORY SECONDARY WASTEWATER TREATMENT AREA TYPE OP EVENT West Equalization Basin leak DATE<S) Unknown (prior to 12/82) EQUIPMENT/LOCATION West Basin/Secondary Wastewater Treatment Area NO. OF EVENTS 1 VOLUME' O) NOTES: (U volume cannot De reasonably calculated or estimated. (2) These are calculated or estimated volumes released to grade prior td rented el action, The amount which was not recovered through remedial action and potentially affected groundwater is unknown. CON/SOURCE-TBS VVV 000008348 TYPE OF EVENT Wastewarer to Old Waste Ef f luent Area^* TABLE 0 MISCELLANEOUS AREAS CHLORINATED HYDROCARBON SPILL HISTORY OLD WASTE EFFLUENT AREA DATE(S) 3/68-3/72 EQU1PMENT/LOCAT ION Wastewater Effluent Area NO. OF EVENTS (10) VOLUME (1) NOTES: (1) Volume cannot be reasonably calculated or estimated. (9) Prior to the installation of the activated sludge unit 9* the LCVCM Plant wastewater discharged to an area c "borrow pit" which was located where the LCCP r Typically 2000-3000 ppm EDC prior to sf^ ___ (10) Continuous during the identified period. A ^ (J)' *y in March, 1972, 'ed to as the located today, ly, 197!. f* V CON/SOURCE-TBS VVV 000008349 VVV 000009350 - vw 000008352 j-URWH f.l'tOfO &T ,- I |p)\yiNQ 4k "Wawn 773m77 *orpinfrctwkEFOno*rv NUMfllR VVV 000003355 Vista Cherrwco! Conpony lak* ChaH*s VCM Plont VCM Plant Rd. P.O. Box 605 Wjtioker Louisiana 70469 Phon* (318) 494-5000 May 11, 1988 Mr. Gary Wojnowsiti Process Engineering-Environmental Conoco Inc. P.O. Box 1267 Ponca City, OK 74603 VIST RE: Analysis of groundwater from well TFRB-2 Dear Gary: ase EEC sample found in VVV 000008356 Spcclra-Physlcs Sjrccha Physics 14. ill f 09C80G0Q0 AAA i SC & ! 6 *CC +Z **S I > > 9i >j i! *S ** *i 9; 9| 9 1i 8 'St61 `Si* 96 `*f 4" bex 9 ** _r 8f g'i T? A---- et 0 > ) ) > J > ) > > > ) > ) > ) y } } 3 3 > ) 9 9 9 1 f * 1. ** 6. t NPUT OVERPAHQE AT P Ta 12. 14 (. u 381PP0G p r le i cc cc ANALVST: METHOO 1. PUN tf HAMS CQMC PT 0*.5:;2 INDEX -5 CH "fl* F5 1. BPEB BC PF 1 2 'u 4 3 a7 c< 9 9 tf ia > ii 12 13 V EDC 13 (# IS v 1? u 13 13 c# 29 ' (# 21 a. aoi a. 9. 923 a* 9. 133 9. 991 9. 992 9. 9. 90S 9. 0, 992 9. 948 99. 277 9. 9. 213 9. 978 9. 991 9. 9, 939 9. 991 i. 32 266 91 2. 79 AO 91 4. 48 1*9 92 4. 3!*! 13339 92 4. A3 127 03 5. 27 77486 02 3. 43 439 93 r. 47 989 92 7. 38 293 92 9. 94 3293 91 4. 8 227 01 19. 994 91 19. !*4 26981 91 12. 13 33693119 99 12. 49 97 03 12. 69 119269 96 12. 84 44934 97 13. 7S 284 91 13. 92 346 91 14. 11 21661 91 14. 7S 649 91 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. VVV 000008361 i ; 22 9* 13. 44 143 91 1. 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