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Module 3: Sources Exercise. Objectives of the Sources Exercise. Selecting source type Determining containment for each pathway Identifying substances associated with a source Determining source hazardous waste quantity. What are the HRS Source Types?. What is a source?

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Module 3: Sources Exercise


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    1. Module 3:Sources Exercise

    2. Objectives of the Sources Exercise • Selecting source type • Determining containment for each pathway • Identifying substances associated with a source • Determining source hazardous waste quantity

    3. What are the HRS Source Types? • What is a source? • A source is an area where a hazardous substance has been deposited, stored, disposed or placed • Soils that became contaminated as the result of hazardous substance migration • What are the HRS source types • Landfills, surface impoundments, buried/backfilledsurface impoundments, drums, tanks, non-drum containers, land farms, land treatment areas, contaminated soil, other

    4. LPQ Facility – Background Information (continued) Located on County Route 220 just north and west of the intersection with County Route 228 at Lake White and 1.6 miles west of the city limits of Waverly in Pike County, Ohio. Pike County is characterized by a cool temperate climate. Summers are warm and humid with daily temperatures reaching 80°F or higher. Daily high temperatures during winter are 25°F to 35°F. Annual precipitation for the area is 40.5 inches and the 2-year, 24-hour rainfall is 2.7 inches.

    5. LPQ Facility – Background Information (continued) LPQ property covers 14 acres of relatively flat terrain. Site slopes from slightly over 600 feet mean sea level (MSL) in the west to about 580 feet MSL along its eastern border with Wintergreen Run, a minimal perennial stream. An unnamed intermittent tributary of Wintergreen Run borders the northern side of the site. Hills rise sharply to the west and north.

    6. LPQ Facility – Background Information (continued) • One wetland exists on the LPQ property • Between the evaporation pond and Wintergreen Run • Extends into the intermittent creek along the northeastern edge of the property • On-site drainage system empties into this wetland • Is identified on the national wetlands inventory maps • A second wetland is downstream of the facility, on both sides of Wintergreen run. • No frontage along Lake White • Separated from the Lake by a raised gravel walking/biking trail that encompasses all of Lake White and is maintained as part of the Lake White State Park

    7. LPQ Facility – Background Information (continued) • On-site facilities include • A small metal casting foundry • A milling shop • A plastics casting shop • An electroplating shop • A soldering and welding shop • A paint shop and • An engine rebuilding and maintenance facility for its fleet of trucks • The foundry has been closed since 1978

    8. LPQ Facility – Background Information (continued) • Five identified sources at the site: • Large evaporation pond (now backfilled) • Existing waste pile on the facility property • Former waste pile in a current residential area adjacent to the site • Two areas of contaminated soil • One on the facility property • One in the residential area • Drainage ditches run around the facility waste pile and evaporation pond and through one of the areas of contaminated soil and empty into a wetland at the mouth of the intermittent stream.

    9. LPQ Facility – Background Information (continued) Founded in 1919 for the manufacture of race car parts for the owner, LouAnne Penelope Quickstep (LPQ). Expanded as a parts manufacturer with the American automobile industry. Foundry abandoned in 1978 when new air pollution regulations were enforced. Company has increasingly relied on plastic casted parts for last 20 years, phasing out the metal casted parts. In the 1970s, the company consolidated all of its operations at this Ohio facility.

    10. LPQ Facility – Background Information • Currently in Chapter 11 bankruptcy reorganization • Currently a minimum of four individuals at the facility during the day: • Two general maintenance workers • Maintain the physical plant • Do the yard work • Former general manager/owner of the company • Secretary/clerk • No RCRA permit application ever filed • Owner has no intent or money to fund any remedial actions

    11. LPQ Facility – Background Information

    12. Source Characterization – LPQ Facility • What sources are located at the LPQ facility? • Evaporation pond • Existing waste pile (on facility property) • Former waste pile (on residential area adjacent to site) • Contaminated soil (on facility property) • Contaminated soil (on residential area adjacent to site)

    13. Source 1 Characterization – Evaporation Pond (continued) • What is the appropriate source type for Source 1 – evaporation pond? • Use page 42 of the HRS Guidance Manual to determine source types

    14. Source 1 Characterization – Evaporation Pond (continued) Are the source’s location and boundaries adequately described in the text and figures?

    15. Source 1 Characterization – Evaporation Pond (continued) • Location • Depicted on the site layout map but called Evaporation Pond instead of a surface impoundment. • Boundaries • 600 feet long • 115 feet wide • Depth not provided • Length and width are provided on Figure, not depth

    16. Source 1 Characterization – Evaporation Pond (continued) • Evaluating containment – Is Source 1 adequately contained to prevent releases to groundwater? • Using information from the SI report, we know…. • RCRA permit did not mention a liner • Groundwater sampling results indicate PCE in MW-3S located immediately downgradient of Source 1 • Soil sample (Soil-8) contained chromium, lead, DCE and PCE • Release is source-specific, solvents disposed of in Source 1

    17. Source 1 Characterization – Evaporation Pond (continued) Using HRS Table 3-2, we know…

    18. Source 1 Characterization – Evaporation Pond (continued) • Containment factor value for Source 1 = 10 • What supporting evidence would you like to have should this factor value be contested? • Well documented sampling data including adequate QA/QC • Photo documentation showing the surface impoundment was constructed with no liner

    19. Source 1 Characterization – Evaporation Pond (continued) • Hazardous substances attributable to Source 1 • Using HRS Section 2.2.2, what hazardous substances can be associated with this source and what is your evidence?

    20. Source 1 Characterization – Evaporation Pond (continued) • Possible hazardous substances: • PCE – Attributable based on manufacturer’s information and sample results from Soil-8 • DCE – Attributable based on being a breakdown product of PCE • Should provide a reference like the ATSDR Toxicological profile for PCE to document this • Chromium – Attributable as a constituent in foundry sand and also used in metal plating operations • Lead – Attributable as a constituent in foundry sand • Benzene – Attributable based on manufacture’s information

    21. Source 1 Characterization – Evaporation Pond – Tier A • Is there enough information to evaluate the evaporation pond under Tier A? • Yes • No • There is not enough information to adequately determine Tier A for the evaporation pond • No mass of CERCLA hazardous substances in the source • No concentration data • Tier A = 0

    22. Source 1 Characterization – Evaporation Pond – Tier B (continued) • 1980 to 1986 LPQ purchased Disolv-O-Grease • Mass of 10 pounds per gallon • Purchased Disolv-O-Grease at a rate of about 10 gallons per week for about 50 weeks each year • During this 7-year period, LPQ generated about 200 gallons of waste that contained Disolv-O-Grease • Is there enough information to evaluate the evaporation pond under Tier B? • Yes • No

    23. Source 1 Characterization – Evaporation Pond – Tier B (continued) • Yes there is and here is how you do it: • 200 gal/week for 7 years • 190 gal = water, 10 gal = waste • 190 gal x 8.34 lbs/gal = 1,584.6 lbs • 10 gal x 10 lbs/gal = 100 lbs • 1,584.6 lbs + 100 lbs = 1,684.6 lbs • 1,684.6 lbs / 200 gal = 8.42 lbs/gal = average mass of wastestream • 200 gal/wk x 8.42 lbs/gal x 50 wks/yr x 7 yrs = 589,400 lbs

    24. Source 1 Characterization – Evaporation Pond – Tier B Use HRS Table 2-5 to determine appropriate factor 589,400 lbs / 5,000 lbs = 117.88 Tier B = 117.88

    25. Source 1 Characterization – Evaporation Pond – Tier C (continued) • Is there enough information to evaluate the evaporation pond under Tier C? • Yes • No • What do we know… • Length = 600 feet • Width = 115 feet • Depth unknown but can use a conservative estimate of 1 foot

    26. Source 1 Characterization – Evaporation Pond – Tier C • Yes there is and here is how you do it: • 600 ft x 115 ft x 1 ft = 69,000 ft3 • 69,000 ft3 / 27 ft3/yd3 = 2,555.56 yd3 • Use HRS Table 2-5 to determine appropriate factor • 2,555.56 yd3 / 2.5 yd3 = 1,022.22 • Tier C = 1,022.22

    27. Source 1 Characterization – Evaporation Pond – Tier D (continued) • Is there enough information to evaluate the evaporation pond under Tier D? • Yes • No • What do we know… • Length = 600 feet • Width = 115 feet

    28. Source 1 Characterization – Evaporation Pond – Tier D • Yes there is and here is how you do it: • 600 ft x 115 ft = 69,000 ft2 • Use HRS Table 2-5 to determine the appropriate factor • 69,000 ft2 / 13 ft2 = 5,307.69 • Tier D = 5,307.69

    29. Source 1 Characterization – Evaporation Pond – Hazardous Waste Quantity • Select the highest hazardous waste quantity from the four tiers and assign it as the source hazardous waste quantity • Tier A = 0 • Tier B = 117.88 • Tier C = 1,022.22 • Tier D = 5,307.69 • Source hazardous waste quantity for the evaporation pond is 5,307.69 (Tier D)

    30. Source 2 Characterization – Contaminated Soil on Facility (continued) An area of discolored soil lies along the drainage ditch to the east of the parking lot, extending from the drainage tile under the driveway down into the intermittent creek. At the drainage tile, the soil was stained orange, which faded to green as distance from the drain increased. The bottom of the intermittent creek below the point of intersection with the ditch to the point of intersection with Wintergreen Run was also stained orange, and no vegetation was visible on the rocks and gravel, in contrast with about 100 feet above the intersection.

    31. Source 2 Characterization – Contaminated Soil on Facility (continued) • The concrete base of the building on the other side of the driveway was also stained and eroded, and a broken pipe leading to the drainage tile extended from the building wall. • This portion of the building formerly contained the metal plating operation. • The drainage pipe was observed inside the building to be connected to the floor drains for the electroplating baths.

    32. Source 2 Characterization – Contaminated Soil on Facility • What is the appropriate source type for Source 2 – contaminated soil located on the facility property? • Use page 42 of the HRS Guidance Manual to determine source type (continued)

    33. Source 2 Characterization – Contaminated Soil on Facility

    34. Source 2 Characterization – Contaminated Soil on Facility (continued) Are the source’s location and boundaries adequately described in the text and figures?

    35. Source 2 Characterization – Contaminated Soil on Facility (continued) • Location • The area of contaminated soil is not specifically labeled on the site layout map, however, soil samples are labeled on the map which indicate the location of the contaminated soil • Boundaries • 12 to 20 feet wide • 300 feet long

    36. Source 2 Characterization – Contaminated Soil on Facility (continued) • Evaluating containment – Is Source 2 adequately contained to prevent releases to groundwater? • Using information from the SI report, we know… • Soil samples Soil-5 and Soil-6 contained concentrations of chromium, lead, and zinc in the surface soils • Stained soils were also observed in this area • Using HRS Table 3-2, we know…

    37. Source 2 Characterization – Contaminated Soil on Facility (continued) Using HRS Table 3-2, we know…

    38. Source 2 Characterization – Contaminated Soil on Facility (continued) • Containment factor value for Source 2 = 10 • What supporting evidence would you like to have should this factor value be contested? • Well documented sampling data with adequate QA/QC • Photographic documentation showing the stained soil • Possible hazardous substances: • Chromium – Attributable as a constituent of foundry sand and also used in metal plating operations • Lead – Attributable as a constituent of foundry sand • PCB – Used in automobile parts manufacturing

    39. Source 2 Characterization – Contaminated Soil on Facility (continued) • Is there enough information to evaluate the facility contaminated soil under Tier A? • Yes • No • No concentration data • Tier A = 0

    40. Source 2 Characterization – Contaminated Soil on Facility (continued) • Is there enough information to evaluate the facility contaminated soil under Tier B? • Yes • No • Mass of wastestream unknown • Tier B = 0

    41. Source 2 Characterization – Contaminated Soil on Facility (continued) • Is there enough information to evaluate the facility contaminated soil under Tier C? • Yes • No • What do we know… • Length = 300 feet • Width = 12 feet • Depth unknown but stained soil is at the surface, typically about 6 inches deep

    42. Source 2 Characterization – Contaminated Soil on Facility (continued) • Yes there is and here is how you do it: • 12 ft x 300 ft x 0.5 ft = 1,800 ft3 • 1,800 ft3 ÷ 27 ft3/yd3 = 66.67 yd3 • Use HRS Table 2-5 to determine appropriate factor

    43. Source 2 Characterization – Contaminated Soil on Facility (continued) • HRS Table 2-5: • 66.67 yd3 / 2,500 yd3 = 0.0267 • Tier C = 0.0267

    44. Source 2 Characterization – Contaminated Soil on Facility (continued) • Is there enough information to evaluate the facility contaminated soil under Tier D? • Yes • No • What do we know… • Length = 300 feet • Width = 12 feet

    45. Source 2 Characterization – Contaminated Soil on Facility (continued) • Yes there is and here is how you do it: • 300 ft x 12 ft = 3,600 ft2 • Use HRS Table 2-5 to determine the appropriate factor • 3,600 ft2 / 34,000 ft2 = 0.1059 • Tier D = 0.1059

    46. Source 2 Characterization – Contaminated Soil on Facility • Select the highest hazardous waste quantity from the four tiers and assign it as the source hazardous waste quantity • Tier A = 0 • Tier B = 0 • Tier C = 0.0267 • Tier D = 0.1059 • Source hazardous waste quantity for the contaminated soil on the facility is 0.1059 (Tier D)

    47. Source 3 • Based on a review of aerial photographs, and verified during discussions with the two maintenance workers at LPQ during the initial site investigation, the EPA learned that LPQ once used the area immediately north of the facility as a storage area. • During the SI field effort, it was noted that this area was now the location of six residences: • Three homes and three trailers • In walking through this area, the following was also observed: • A waste area consisting of a pile of rusty barrels and other packaging near the end of the local dirt road • Several areas did not support vegetation, especially along the drainage swales originating at the pile and running along the dirt road

    48. Source 3 Characterization – Residential Soil (continued) • Based on these observations, EPA decided to undertake a focused SI to sample this area • Collection of six additional soil samples • Waste area was no longer present when the field team returned to the site but an additional soil sample was taken at the former waste area location. • The contaminated soil in the residential area is 800 feet by 10 feet

    49. Source 3 Characterization – Residential Soil