P.O. Box 788 Heppner, OR (541)

Transcription

1 P.O. Box 788 Heppner, OR (541) November 2009 Mr. Richard Duval OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY 256 East Hurlburt, Suite 105 Hermiston, Oregon SUBJECT: TECHNICAL REPORT ON PERMIT MODIFICATION REQUEST UMCDF CLOS(2) TO THE UMATILLA CHEMICAL AGENT DISPOSAL FACILITY Dear Mr. Duval: Morrow County is submitting these public comments on Permit Modification Request (PMR) UMCDF CLOS(2) prepared by Umatilla Chemical Agent Disposal Facility (UMCDF). These comments were prepared by Tetra Tech as technical representatives of Morrow County. We trust that you will find this report useful and informative. Please contact me at (541) if you have any questions. Sincerely, Casey Beard, CSEPP PM Morrow County Enclosure cc: Mike Baker, Tetra Tech File PMR UMCDF CLOS(2) ODEQ transmittal letter.doc

2 UMATILLA CHEMICAL AGENT DISPOSAL FACILITY TECHNICAL REVIEW COMMENTS ON PERMIT MODIFICATION REQUEST UMCDF CLOS(2) MORROW COUNTY TECHNICAL ASSISTANCE Prepared for Morrow County P.O. Box 788 Heppner, OR Contract No. : Task No. : I Date Prepared : November 24, 2009 Morrow County Project Officer : Casey Beard, CSEPP PM Telephone No. : (541) Tetra Tech Project Manager : Mike Baker Telephone No. : (509)

3 1.0 INTRODUCTION Tetra Tech, prepared this report to present the findings of its review of Permit Modification Request (PMR) UMCDF CLOS(2), prepared by the Washington Demilitarization Company (WDC) for the U.S. Army Chemical Materials Agency Umatilla Chemical Agent Disposal Facility (UMCDF) Field Office and submitted to the Oregon Department of Environmental Quality (DEQ). 2.0 GENERAL COMMENTS 1. Relocation of the Closure Plan to Attachment 8 The relocation of the Closure Plan to Attachment 8 is consistent with previous Permit construction, and offers a more accessible read of the closure plan. However, the attachment is not a verbatim move of the Closure Plan. While the intent of the changes appears to be present in the Permit Modification Request, a table of changes between Section I and Attachment 8 would clarify the intent of the modification request. Expand on Appendix A of the PMR to include changes between Section I and Attachment Use of Variant Decontamination Approaches The UMCDF Closure Plan sections which describe the closure of the hazardous waste management units (HWMU) at the facility provide insufficient detail regarding decontamination techniques to be used. The text indicates selection of decontamination techniques for specific areas and equipment, whether they are thermal, chemical, or mechanical, are yet to be determined, based on the environmental conditions resulting in the contamination, the level of contamination, the type and configuration of the material to be decontaminated, and prior knowledge from proven decontamination operations. This language suggests a trial and error approach to the selection of decontamination techniques for equipment and buildings at the UMCDF. At this point sufficient information should exist to choose and describe the appropriate decontamination technique if not the operating procedures to be implemented. UMCDF CLOS (2) technical review report FINAL.docx

4 The Closure Plan should be revised to provide more detail and specifics of the decontamination techniques that will be used in each HWMU for each item or item type to be decontaminated. Indicate in the PMR what the approaches for decontamination will be, and how they serve to protect human health and the environment of the surrounding community. 3. Closure of the Hazardous Waste Management Units (HWMU) The UMCDF Closure Plan sections which describe the closure of the hazardous waste management units (HWMU) at the facility provide insufficient detail regarding the disposition of equipment and materials generated from dismantlement or demolition activities. First, the language used is very inconsistent. In some instances the closure plan states that a specific waste will be sampled and analyzed in accordance with the Waste Analysis Plan (WAP) and then disposed of as hazardous waste (pg. 92 of 146). On page 100 it states a waste will be characterized through sampling or process knowledge, if appropriate, and shipped off site to an approved hazardous waste treatment, storage, and disposal facility (TSDF). On page 116 it is unclear whether the filter carbon will be managed as hazardous waste and states that filter carbon will have been removed and managed in accordance with the WAP. On page 122 it states that a waste may be shipped to a hazardous waste TSDF in accordance with the WAP. Second, the plan includes recycling as option for steel. No details are provided on limitations on the type of recycling that will be performed. Provide a clear and succinct Table which identifies the anticipated wastes streams from each activity and whether the material will be manifested as hazardous waste. In addition, indicate if the waste will be characterized in accordance with the WAP and possibly disposed of as either hazardous waste or solid waste. Items and materials that will be recycled rather than disposed of at a hazardous waste TSDF should be identified in the plan. If the recycled items are available for reuse as opposed to a destructive recycling (i.e. high temperature smelting) more aggressive sampling should be required. 4. Surface Water Control Fact Sheets for HWMUs and Other Areas contained in Appendix A UMCDF Closure Campaign Sampling and Analysis Plan and Appendix E URS Closure Campaign Site Assessment Report have small figures or drawings showing the location and layout of each operating unit. These drawings are deficient in that no information is provided showing the direction of surface flow and the location of sumps, drains, trenches, or other containment and control structures. This information is critical to UMCDF CLOS (2) technical review report FINAL.docx

5 evaluating confirmatory sample locations, and identifying potential areas where contaminants would concentrate and pose an increased risk for surface or subsurface contamination. The figures should be revised to indicate the direction of surface flow in each area and the location of sumps, drains, trenches, or other containment and control structures. 5. Storm Drainage from the UMCDF Treatment Area At the very top of page the text states that drainage from the UMCDF treatment areas flows to existing UMCD drainage courses. Immediately below the text states that storm water is directed to a storm water retention basin 500 feet to the east. Storm water originating in the treatment area has the potential to contain hazardous constituents resulting from facility operations. This potential is evident in Appendix C or the SAP where fact sheet OA-26 provides a minimum of 29 samples to address this potential in adjacent areas. Evaluate sampling and closure requirements for the storm water retention basin and pipes or drainages that may lead to the structure. Evaluate the regulatory status of the retention basin, (e.g. potential waste water treatment unit status or interim status) and the potential RCRA status of the pipes or drainage structures up-gradient and down-gradient of the basin. Indicate accordingly on maps/drawings. 6. Agent-Free Confirmation prior to Thermal Demolition Activities The Closure Plan does not provided detailed information on how potentially agent contaminated piping systems will be cut and capped. If the physical removal and/or neutralization of residual agent is incomplete and thermal cutting is used, there exists the potential for agent vaporization. The Closure Plan should be revised to provide more detail and specifics for decontamination techniques and demolition methods that will be used for piping systems and similar equipment. UMCDF CLOS (2) technical review report FINAL.docx

6 7. Dust Control Measures The Closure Plan states for several of the HWMUs that proven dust control measures will be implemented during the demolition process, as appropriate. Details of how dust will be monitored to determine if dust control is appropriate and what methods will be used to control dust are not provided. Because of the history of contamination and chemical agent at UMCDF, dust control measures should be provided for all demolition and mechanical decontamination activities. Dust control measures need to be described. In addition, to ensure and document that closure activities are conducted in a manner protective of the surrounding communities and the environment, the Permittee should be required to conduct perimeter air monitoring for dust and Constituents of Concern (COCs) during all decontamination and demolition activities. 8. Inappropriate Standard Representation The J-Block Closure Plan, Section inappropriately represents the debris treatment standard for land disposal restrictions (LDR) compliance as a closure performance standard. The wipe sampling described in Section 3.0 is the basis for the closure determination. Section inappropriately proposes wipe sampling of a porous material for contaminants deposited in a vapor form. The closure plan should be modified to eliminate the debris treatment standard as a closure performance standard. Instead of wipe samples, the concrete surfaces should be scarified to remove material for the samples. UMCDF CLOS (2) technical review report FINAL.docx

7 3.0 SPECIFIC COMMENTS 1. PMR, Description of Permit Modification Request, page 3, minor editorial. The final non-bullet paragraph on page 3 indicates that three appendices are attached to the Closure Plan. The bulleted section attached to the paragraph lists four appendices. Indicate that four appendices are attached. 2. PMR, Attachment 8 Closure Plan Section 1.0, page 1 of 146 The bullet using a landfill as an example of the process for closure schedule development is confusing and irrelevant. Utilize an example relevant to the closure at hand. 3. PMR, Attachment 8 Closure Plan, Section 2.7, pages 5-7 of 146. The text indicates storm water drainage from within the double fenced boundaries of the UMCDF is collected in a geotextile-lined collection basin located to the northeast. Text also indicates storm drainage from within the UMCDF treatment unit area is directed eastward to existing UMCD drainage courses. The treatment and/or discharge/disposal of the water in the collection basin is not described. This discrepancy should be clarified. It is not clear whether existing UMCD drainage courses means natural drainage features. In addition, the treatment and/or discharge/disposal of the water in the collection basin should be described. Figures should be revised or added to show surface drainage pathways, features, and controls. UMCDF CLOS (2) technical review report FINAL.docx

8 4. PMR, Attachment 8 Closure Plan, Section 2.8, Regional and Local Geology, page 7 of 146. By the title of this section, this section doesn t seem the appropriate place to describe brine processing and the assessment of spills and releases. Mention is made that storm water is diverted to a storm water detention pond 500 ft east of the UMCDF. It is not clear if this is the same collection basin described in Section 2.7. Treatment and discharge of the collected storm water is not described, nor is reference to other sections provided. Consider relocating the description of the brine processing and the assessment of spills and releases. Indicate whether the collection basin described in this section is the same as in Section 2.7. As with comment 3, clarify the storm water collection, detention, and treatment system. The treatment and/or discharge/disposal of the water in the detention pond should be described. Figures should be revised or added to show surface drainage pathways, features, and controls. 5. PMR, Attachment 8 Closure Plan, Section , page 15 of 146. This section indicates polychlorinated biphenyl (PCB)-contaminated wastes from UMCD were thermally treated in the Deactivation Furnace (DFS). It is also noted that after PCB waste destruction was completed in the DFS, the UMCDF decontaminated the equipment, areas, systems, and buildings, with the result that no more PCBs remain at the UMCDF. A report on the result to EPA is mentioned, but not referenced. Because of the history of PCB waste handling and processing at the facility, PCBs should be included as a COC in the closure process. The report to EPA should be referenced. 6. PMR, Attachment 8 Closure Plan, Section 3.5, Underground Storage Tanks, page 19 of 146. This section gives the requirement from Oregon Administrative Rules (OAR) (5) and OAR that a site assessment will be performed to measure for potential contamination near the location of the USTs. The following is one of the requirements that must be met for sampling and analysis: soil samples must be collected from the native soils located no more than two feet beneath the bottom of the tank pit in areas where contamination is most likely to be found. The plan UMCDF CLOS (2) technical review report FINAL.docx

9 does not identify and describe such locations, including drains, sumps and trenches, where soils samples should be targeted. The plan should identify and describe locations where contamination is most likely to be found, including drains, sumps and trenches, where soils samples should be targeted. The Sampling and Analysis Plan (SAP) should be referenced where judgmental sample locations are described. Drawings, including topology, would be beneficial. 7. PMR, Attachment 8 Closure Plan, Section 3.9, Area of UMCDF Stack Air Dispersion, page 20 of 146. This section indicates that surrounding soils where air dispersion modeling has indicated deposition potentially resulting in levels of hazardous constituents above background levels will be sampled. The SAP Appendix B contains a fact sheet showing the location of the deposition area. However, no information is presented or referenced in the Closure Plan to show what air dispersion modeling has been done and what parameters and assumptions are used to form the basis for determining the deposition area. The plan should provide the basis for determining the deposition area. The air dispersion and deposition model inputs and results should be included. 8. PMR, Attachment 8 Closure Plan, Section 4.3.2, Management of Spills, page 27 of 146. This section states that there is no evidence of any major releases of contaminants to the groundwater, the underlying soils, or the uppermost aquifer based on the results of the site assessments and spill histories. This is misleading since it does not also mention that sampling and analysis of groundwater and underlying soils has not been performed. The absence of evidence should not be construed as the absence of contamination. Clarification should be provided that based on spill histories and visual inspection, major releases of contaminants to the groundwater, the underlying soils, or the uppermost aquifer are not suspected, however no confirmatory sampling of groundwater and underlying soils has been performed to verify that these media are uncontaminated. The need for post-closure care of soils and groundwater will be determined through confirmatory sampling during closure. UMCDF CLOS (2) technical review report FINAL.docx

10 9. PMR, Attachment 8 Closure Plan, Section 4.3.2, Management of Spills, page 28 of 146. The plan provides that during closure the UMCDF will conduct confirmatory sampling in those areas where spills have occurred. No information is provided or referenced to confirm that confirmatory sampling will be conducted at the location of spills and releases. The plan should specify that confirmatory samples will be taken at the point of the spills and in associated sumps and drains. 10. PMR, Attachment 8 Closure Plan, Section 23.4, page 130 of 146. The plan states that proven dust control measures will be implemented during the demolition process, as appropriate. Details of how dust will be monitored to determine if dust control is appropriate and what methods will be used to control dust are not provided. Because of the history of contamination and chemical agent at UMCDF, dust control measures should be provided for all demolition and mechanical decontamination activities. Dust control measures need to be described. 11. PMR, Sampling and Analysis Plan, Section 1.0, Introduction, page 2. The text states the SAP does not address waste characterization sampling and analysis. It should be stated that waste characterization sampling and analysis for wastes generated during closure will be addressed under the existing Waste Analysis Plan, and a reference should be provided. UMCDF CLOS (2) technical review report FINAL.docx

11 12. PMR, Sampling and Analysis Plan, Section 3.1.1, Constituents of Concern (COC), page 8. The plan does not list PCBs as a COC, which are known to have been processed at UMCDF, nor other hazardous substances such as asbestos or lead paint as potential COCs. If any of these hazardous substances have been or are present at the facility, they need to be included as COCs. 13. PMR, Sampling and Analysis Plan, Section 3.1.3, Decision Making Approach, page 10. This section states that If the current RL is greater than the statistically derived background concentrations and the contract laboratory cannot achieve the statistically derived background concentrations, then consult with DEQ to determine the AL. It is apparent that laboratory capability existed in 1997 when the baseline sampling was done that had demonstrated reporting limits (RLs) needed to achieve the statistically derived background concentrations. Justification should be included for the absence of a requirement to secure another laboratory with the ability to meet an RL equal to or lower than the statistically derived background concentrations. If this capability did not exist when baseline sampling was done, and the background concentrations are based solely on statistical analyses, this approach should be more thoroughly illustrated. 14. PMR, Sampling and Analysis Plan, Appendix A, Fact Sheets for HWMUs MDB HWMUs, page A- 13 to A-16. The fact sheets for closure confirmation soil sampling show sample locations for surface soil after removal of structures and slabs. The sampling is at 29 unbiased locations shown on a grid. No judgmental samples are provided to target areas or locations where contaminants would be most likely to be released to the environment. The plan should provide judgmental samples that are preselected and target biased sample locations based on where there were sumps, drains, tanks, etc. where the likelihood of a release to the soils is UMCDF CLOS (2) technical review report FINAL.docx

12 greatest. These should be done by coring through concrete or pavement (before structures and slabs are removed), to identify whether contaminants exist in the sub-soils prior to disturbance. 15. PMR, Sampling and Analysis Plan, Appendix A, Fact Sheets for HWMUs, PAS HWMU Fact Sheet, page A-20. The sample location coordinate table, labels the sample locations as Judgmental Sample Locations whereas they appear to be unbiased locations. The table of coordinates should be corrected. 16. PMR, Sampling and Analysis Plan, Appendix B, Fact Sheets for Other Areas, Bulk Chemical Loading Station and Brine Transfer Loadout Station Fact Sheet, page B-1. The fact sheet specifies that one judgmental sample will be taken at a sump location; however the drawing in the fact sheet appears to show more than one sump. A judgmental sample should be taken at the location of each sump, not just one as indicated. 17. PMR, Sampling and Analysis Plan, Appendix B, Fact Sheets for Other Area Sites, Lower Parking Lot Fact Sheet, page B-5. This sheet discusses obtaining four judgmental soil samples. This area is unpaved and there is a history of spills. Due to the nature of use at a parking lot, it seems likely that many spills could go unreported. It is appropriate that a number of unbiased soil samples also be collected across the parking lot area in addition to judgmental samples at locations of visible staining and discoloration. UMCDF CLOS (2) technical review report FINAL.docx

13 18. PMR, Sampling and Analysis Plan, Appendix B, Fact Sheets for Other Area Sites, Waste Transfer Area Fact Sheet, page B-9. This sheet discusses obtaining a limited number of judgmental soil samples only. Because of the large area involved and the nature of the operations that occurred in the Waste Transfer Area, it is appropriate that a number of unbiased soil samples also be collected in addition to judgmental samples. 19. PMR, Sampling and Analysis Plan, Appendix B, Fact Sheets for Other Area Sites, Breezeway Fact Sheet, page B-32. It is stated that ash spills are suspected to have been released to the environment at this site, yet only 29 unbiased samples are proposed for this area. Likely locations where ash was spilled should be sampled using judgmental samples, for example where the waste incineration containers (WICs) were stored. These should be in addition to the unbiased samples designated for this area. 20. PMR, Sampling and Analysis Plan, Appendix B, Fact Sheets for Other Area Sites, Maintenance Area North of the CHB Fact Sheet, page B-41. Three judgmental soil samples are designated for this large gravel covered area with spill history. The sample locations are selected based on equal distances to represent each section of the area. It would be more appropriate to select known spill locations or stained areas for the judgmental samples, and also perform unbiased sampling of the entire area to confirm no residual contamination. UMCDF CLOS (2) technical review report FINAL.docx

14 21. PMR, Sampling and Analysis Plan, Appendix B, Fact Sheets for Other Area Sites, Brine Reduction Area Pollution Abatement System Area Fact Sheet, page B-62. This area had multiple spills, yet only 29 unbiased samples are proposed for this area. This area warrants additional soil samples targeted to likely spill areas and spill concentration areas such as edges of pavement and run-off points. Likely locations where spills occurred should be sampled using judgmental samples. These should be in addition to the unbiased samples designated for this area. 22. PMR, Sampling and Analysis Plan, Appendix B, Fact Sheets for Other Area Sites, Upper Parking Lot Fact Sheet, page B-109. This fact sheet discusses obtaining four judgmental soil samples. This area is unpaved and there is a history of spills. Due to the nature of use as a parking lot, it seems likely that many spills could go unreported. It is appropriate that a number of unbiased soil samples also be collected across the parking lot area in addition to judgmental samples at locations of visible staining and discoloration. 23. PMR, Sampling and Analysis Plan, Appendix B, Fact Sheets for Other Area Sites, Area of Air Deposition Fact Sheet, page B-116. The plan indicates that 29 unbiased locations will be sampled to cover the Area of Air Deposition, an area of nearly two square miles. No justification is presented to show why the low density of soil sampling locations is sufficient to adequately characterize the modeled air deposition zone. Justification should be provided to show why a larger number of samples are not appropriate for the large surface area, and why samples are not targeted with a higher density biased toward higher deposition zones and drainage features within the total deposition area as would be shown by deposition model output isopleths and topographic maps. UMCDF CLOS (2) technical review report FINAL.docx

15 24. PMR, Fact Sheets in Appendices B, C, and D to Appendix E URS Closure Campaign Site Assessment Report. Fact Sheets for HWMUs and Other Areas contained in Appendix A UMCDF Closure Campaign Sampling and Analysis Plan and Appendix E URS Closure Campaign Site Assessment Report have small figures or drawings showing the location and layout of each operating unit. These drawings are deficient in that no information is provided showing the direction of surface flow and the location of sumps, drains, trenches, or other containment and control structures. This information is critical to evaluating confirmatory sample locations, and identifying potential areas where contaminants would concentrate and pose an increased risk for surface or subsurface contamination. The figures should be revised to indicate the direction of surface flow in each area and the location of sumps, drains, trenches, or other containment and control structures. 25. PMR, J-Block Closure Plan, Section 3.2.2, Floor, Wall, and Ceiling Surfaces Stratum, page 49. The plan indicates for sampling of igloo floor, wall and ceiling surfaces that only the bottom 6.6 ft (2 meters) on either side of the arched ceiling consist of concrete surfaces that need to be wipe sampled and that any contamination that is found is likely to have penetrated the surfaces from a vapor state. It is unclear why the arched ceiling surface itself is not included in the sampling grid for interior surfaces. It would appear that the entire ceiling surface would also be subject to exposure to vapors if vapors had been present, and therefore could also have been penetrated by vapors. The arched ceiling surfaces should be included in the wipe sampling to be conducted in the storage igloos. 4.0 CONCLUSIONS AND RECOMMENDATIONS It is recommended the PMR be revised to address the identified deficiencies. The Amended Closure Plan should not be approved by the DEQ until the recommendations above are incorporated into the Closure Plan. UMCDF CLOS (2) technical review report FINAL.docx