October 29, l990

II. INTRODUCTION

The 1984 Hazardous and Solid Waste Amendments (HSWA) to the Resource Conservation and Recovery Act (RCRA) authorized EPA to require corrective action for releases of hazardous wastes and/or hazardous constituents from solid waste management units (SWMUs) and other Areas of Concern (AOCs) at all operating, closed, or closing RCRA-regulated facilities. The intention of this authority is to address previously unregulated releases to air, surface water, soil and ground water, and generation of subsurface gas. The first phase of the corrective action program, as established by EPA, is the development of a RCRA Facility Assessment (RFA). The RFA includes a Preliminary Review (PR) of all available relevant documents, a Visual Site Inspection (VSI) and, if appropriate, a Sampling Visit (SV).

This chapter provides a summary of the PR and VSI activities, facility history, waste management practices and the environmental and demographic setting for the City of Longwood Department of Public Works. The SWMUs and AOCs are described in Chapter III. Tables categorizing the units are presented in Chapter IV. Chapter V presents suggestions for a sampling strategy for those units requiring Phase II sampling. The references used in this report are listed in Chapter VI. Appendix A is the VSI log book and Appendix B presents the photographs documenting the physical condition of the SWMUs. A summary of Laboratory Analyses performed on the drums removed from the Waste Drum Landfill (SWMU 1) appears in Appendix C. Appendix D contains a copy of the Hazardous Waste Complaint Response dated October 28, 1988.

Preliminary Review and VSI

All available EPA Region IV and Florida Department of Environmental Regulation (FDER) RCRA files concerning the Longwood Public Works Department facility were examined during August 1990 file searches. The EPA Region IV file search was conducted by L. Griffin of A. T. Kearney and the state FDER file search by K. McCreanor of the Earth Technology Corporation. Information concerning waste generation, treatment, storage, and/or disposal were used to formulate a tentative list of past and present SWMUs and AOCs. This list assisted in planning the VSI and identifying additional information which should be gathered on‑site.

The VSI was conducted on September 14, 1990, by an EPA contractor team (Ms. Lili Griffin and Ms. Molly O'Neill of A. T. Kearney), Mr. Harry Desai of EPA Region IV, and Mr. Bob Snyder of FDER.

The VSI kickoff meeting began at approximately 9:00 a.m. Ms. Griffin presented a brief summary of the objectives and purpose for conducting the VSI. Then the facility representative, Mr. Richard Kornbluh, addressed specific questions raised by the contractor representatives.

After the meeting, the VSI team inspected the maintenance yard facilities, and adjacent contiguous properties east and northwest of the maintenance yard facility. Weather conditions were sunny, with temperatures approaching 85°F. After viewing the facility, arrangements were made to reassemble for a 1:30 p.m. closeout meeting at the City Administrator's office. When the City Administrator was unable to attend the closeout meeting, the closeout meeting was held with the Public Works Director, Mr. Richard Kornbluh and the Purchasing Director, Ms. Rhonda Ledford. At approximately 2:30 p.m., the inspection team left the Longwood facility.

Facility History, Regulatory History, and Waste Management Practices

1. Facility History

The City of Longwood is a political subdivision of the State of Florida that owns and operates a Public Works storage yard on properties located on 175 and 180 East Warren Avenue, Longwood, Section 32, Township 20 South, Range East, Latitude 28^o 42' 00" North, Longitude 81^o 27' 34" West, in Seminole County, Florida (Reference 22). The facility is located approximately 15 miles north of the City of Orlando as shown in Figure II-1 on the following page. The Longwood Department of Public Works is an agency of the City of Longwood established to serve the public interest through the coordination of public utility, transportation and engineering efforts. The Department of Public Works employs approximately 40 people. Waste generation from the Department of Public Works includes those activities resulting from pesticide control, and maintenance work on city vehicles, municipal sewer and water facilities, and roads.

According to facility personnel, the Public Works Department's activities began in the early 1950s. During the 1950s, the Public Work's activities were limited to property parcels 95,96,97,100,100 1/2, 101, 101 1/2, 102, 102 1/2 103, and 103 1/2 as shown in Figure II-2. These parcels are the location of the water treatment plant and Maintenance Services Fleet Shop and have the address of 175 East Warren Street. The water treatment plant was built on parcels 101-103 1/2 in 1972. In the late 1970's, Parcel 18 (located across East Warren Street from the water treatment

Figure II-1

Facility Location Map

(Reference: 79)

Figure II-2

Facility Parcel Map

(Reference: 66)

plant) was purchased. This parcel is the location of the public works offices and storage sheds, and Parks and Recreation shed. The public works offices were built in approximately 1988. The Parks and Recreation shed was built in approximately 1987. In 1989, Parcel 19, immediately west of Parcel 18, was purchased. This lot is used for storage of miscellaneous piping, earthen materials, and the location for a new premanufactured steel storage building purchased in 1989 to be used for pesticide storage (Reference 62).

2. Regulatory History

On October 26, 1988, the FDER received a complaint of improper disposal of chemicals by the Longwood Public Works Department. A site inspection conducted by a representative of the Department in October concluded that approximately nine drums had been buried on-site. The drum burial had taken place on Sunday, October 23, 1988. Excavation of the site, which took place December 20, 21 and 22, 1988, located sixteen containers of waste material. Subsequent analyses of the contents of the sixteen containers found at least eight containers held hazardous wastes (Reference 22). The FDER alleged that the Longwood Public Works Department created a hazardous waste land disposal unit (landfill) which therefore was classified as a large-quantity generator and a disposal facility as defined in 40 CFR Section 260.10 and Florida Administrative Code (F.A.C.) Rule 17-30.020. Therefore, the unit is subject to 40 CFR regulations 262, 264, and 265 regulations and permitting requirements of 17-30 F.A.C. (Reference 12).

On October 26, 1988, FDER conducted an inspection to determine if the Longwood Public Works Department was in compliance with Standards for Generators and Transporters of Hazardous Waste and Owners and Operators of Hazardous Waste Facilities. The facility was classified as a generator and a land disposal unit.

On March 9, 1989, the Department issued the Longwood Public Works Department a Class I Warning Notice (OWN-HW-89-00104), which alleged Class I violations of hazardous waste laws, documented during the Department's October 28,30 and November 1, 1989 RCRA hazardous waste compliance inspection. The Longwood Public Works Department was cited for the following violations:

a) Failure to determine whether the contents of sixteen drums should be classified as hazardous waste.

b) Failure to notify EPA of hazardous waste activities.

c) Failure to segregate incompatible wastes during disposal.

d) Failure to train employees to perform job duties in compliance with hazardous waste regulations.

e) Failure to make arrangements with local authorities as required in 40 CFR 264.37(a), 265.37(a).

f) Failure to develop a hazardous waste emergency contingency plan.

g) Operating a hazardous waste landfill without a permit.

h) Improper disposal of seven 55 gallon drums of hazardous waste and one 30 gallon drum of hazardous waste.

The violations were incorporated into a Consent Order which was signed by the City of Longwood Commission on July 3, 1989. The Consent Order outlined the following:

a) Resolve the violations of Warning Notice OWN-HW-89-0104.

b) Submit Notification of Hazardous Activity as proof that the Longwood Public Works Department has applied for an EPA Hazardous Waste Identification Number.

c) Proof that incompatible wastes are segregated.

d) Familiarize police and fire and local hospitals with hazardous waste activities.

e) Develop a Contingency Plan.

f) Provide shipping manifest for drums removed from the pit.

g) Documentation of method used to remove remaining drums and waste piles from excavation.

h) Pay $25,000 in civil penalties.

i) Outline a detection monitoring program established in accordance with 40 CFR Parts 264.97 and 264.98 of Subpart F.

j) Provide a compliance schedule for the detection monitoring plan to be made a part of the Consent Order.

k) In the event that ground-water contamination is detected, the Longwood Public Works Department must achieve compliance with Subpart F of 40 CFR.

l) The Longwood Public Works Department shall submit a RCRA closure permit application.

m) In the event that the Department determines that the land disposal unit cannot be clean-closed in accordance with the RCRA closure permit, the Longwood Public Works Department is to modify the RCRA permit application to apply for a RCRA post-closure permit (Reference 35).

A RCRA compliance inspection conducted a year after the removal of the drums from the Waste Drum Landfill (SWMU 1) was made on December 12, 1989. In that inspection, the facility was found by the Department to be a TSD and Conditionally Exempt Small Quantity Generator in compliance with the rules of the State of Florida, Chapter 17-730, Part III Standards for Generators and Transporters of Hazardous Waste and Owners and Operators of Hazardous Waste Facilities (Reference 46).

Currently, all requirements of the Consent Order have been submitted to the Department. The first submittal of the RCRA Closure Permit Application was received in May 1990 by the Department. The application was resubmitted in August 1990 and is currently under review by the Department. The Detection Monitoring Program has been submitted and is currently under review. A Site-Specific Quality Assurance Plan (SSQAP) is also under review by the Department.

Other permits which the Longwood Public Works Department hold include a Stormwater Discharge permit which was issued on June 30, 1987 (Reference 75). This permit was required as part of the construction of the public works office building. The permit requires stormwater retention swales and a basin to manage additional rainwater runoff from building structures on the site. In November, 1989, the stormwater swale and retention basin areas were found inundated with debris and overgrown with weeds and therefore out of compliance with the Stormwater Discharge Permit (Reference 73). The site was reinspected later on December 18, 1989 and found to be in compliance.

The Longwood Public Works Department holds a general permit for the construction of a sewage lift station which was installed in November, 1989. Previously, the site owned two septic tanks located at the Public Works Building and the Vehicle Maintenance Yard. These septic tanks were abandoned under the direction of the Seminole County Health Department because the units were within 200 feet of a public water supply. The sewage lift station pumps sanitary wastes from the Public Works properties to the city sewage system.

The Public Works Department has received two separate telephone complaints which were logged in by FDER on October 26, and 31, 1988, which allege that illegal dumping of concrete in the percolation ponds occurred on non-contiguous property at the Skylark Treatment Plant. This treatment plant was closed on August 7, 1988 and is now the location of Candyland City Park on Grant Street. The city's other sewage treatment plant, the Columbus Harbor was also closed at the same time. The Department inspected both sewage treatment plants in October, 1988. The report prepared by Department representatives stated that evidence of dumping of cement and "partially liquid" material were noted at the location of the Skylark Treatment Plant. No evidence of dumping at the Columbus Harbor plant was noted except for an unmarked black 55-gallon poly drum which was located in one of the cells of the treatment plant. The Department was told by the former City Engineer, Charles Hassler, that the drum was for treatment chemicals for the plant (Reference 6).

3. Waste Management

Information regarding past disposal practices prior to the discovery of the waste drum landfill is incomplete. This is primarily due to a turnover of Public Works Department staff involved in past waste management since the illegal Waste Drum Landfill (SWMU 1) was discovered.

Waste Generation

An examination of the variety of activities performed for the City of Longwood reveals that the facility can generate a wide variety of operations and maintenance related wastes. The largest volume of wastes are those generated from the Public Works Department construction/demolition activities. To a lesser extent wastes are generated from vehicle maintenance, road maintenance, sign shop, mosquito spraying activities, and Parks and Recreation activities (Reference 62). According to facility personnel, Public Works activities do not include maintenance of electrical utilities. Maintenance of all city electrical systems is performed by Florida Power.

Public Works Department construction/demolition activities produce waste debris such as piping (PVC, wrought iron, reinforced concrete), valves, motors, pumps, soil, concrete, fencing, and lumber. Some of the waste construction debris (e.g., piping and valving) is reused according to facility personnel. Debris which cannot be reused is hauled off to the Seminole County landfill. Scrap metal which can be collected from the waste construction debris is reportedly hauled off to a scrap metal yard, periodically. At the VSI, a newly procured scrap metal dumpster was observed located next to the Vehicle Maintenance Fleet Shop (Reference 62).

Vehicle Maintenance Fleet Shop waste streams consist of waste oils, used tires, spent batteries, and mineral spirits (D001) generated from vehicle maintenance and the Former Parts Cleaner Unit (SWMU 6). In the past, spent mineral spirits generated from the Former Parts Cleaner Unit (SWMU 6) and waste oils were mixed in 55-gallon drums and stored outside of the shop. Currently, waste oils are collected in a Waste Oil Collection Unit and Tank (SWMU 8) which was installed in 1989 and held for recycling. Two Safety-Kleen parts washers (SWMUs 7A and 7B) have replaced the Former Parts Washer Unit (SWMU 6). Used batteries and tires are returned to battery and tire suppliers. An asbestos fibers collection unit was observed in the Vehicle Maintenance Fleet Shop for the collection of asbestos fibers from asbestos-lined brakes. The unit was new and had reportedly not been used at the time of the VSI (See Photo 1.17). If a time came where the unit would be used, it was reported that the asbestos fibers were to be flushed to the sanitary sewer (Reference 62).

Road maintenance activities consist of labeling road signs, road-striping, road pothole repair, base work for road construction. In the past, the Public Works Department owned a road paint striping machine. In the last couple of years, the use of paint for striping has largely been discontinued in preference for prefabricated tapes. The road paint striping machine was sold. The vehicle was stored near the tool shed located behind the Vehicle Maintenance Fleet Shop when it was in use. Signs are also produced using prefabricated tapes in place of paints which were used in the past (Reference 62).

The Public Works Department has been responsible for Longwood's mosquito spraying program since the Department of Public Work's was founded in the 1950s. According to facility personnel, Malathion^TM may have been used for the last ten years. The types of pesticides which were used prior to Malathion^TM is not known. The Public Works Department owns one pesticide fogger which is attached to a vehicle used for mosquito spraying. The vehicle is reportedly parked on Parcel 18. The pesticides are reportedly always consumed in use and never emptied from the fogger or rinsed out. Pesticides are stored in a Pesticide Storage Shed (AOC A) which was received from the Health and Rehabilitative Services Department in approximately 1987. The shed has been used for storing paint, gasoline, grass seed, Malathion ^TM, an emulsifiable concentrate containing methoxychlor used in the formulation of Malathion ^TM, Rodeo^TM and Roundup^TM (weed killers) (Reference 82). A strong skunk-like odor (probably Malathion^TM) prevented the VSI team from entering the shed. Therefore, the contents of the shed could not be verified. Staining was noted in the shed and two 55-gallon drums of Malathion^TM owned by Public Works Department were noted as not being stored in this shed but across the street at the Parks and Recreation Shed (Reference 62). In addition, FDER inspectors in 1988 found a 55-gallon drum of Malathion^TM placed in the open sun in one of the sand/gravel/lime rock holding bins adjacent to the Waste Drum Landfill (SWMU 1) (Reference 6). Based on the practice of storing 55-gallon drums of Malathion^TM in the open sun and particularly the condition of 5-gallon containers observed at the Parks and Recreation Shed, the normal shelf-life for this pesticide is probably not being achieved (Reference 82).[1] Facility personnel stated that the new premanufactured shed observed on Parcel 19 was procured to replace the existing shed because of lack of ventilation in the latter.

Smaller quantities of commercial chemical product wastes (e.g., fertilizers, paints, solvents, herbicides, and pesticides) are generated from Parks and Recreation activities. A representative from Parks and Recreation was not at the VSI to discuss waste management practices. At the time of the VSI, five-gallon containers of Malathion^TM, an organo-phosphate pesticide, and a fluid containing cacodylic acid (possibly a herbicide), unidentified 5-gallon containers containing liquids, and miscellaneous paint cans (approximately 30) were observed lying on the ground in the open sun (References 62 and 82). According to Public Works Department personnel, the waste cans were probably moved out from the Parks and Recreation shed to make room for a vehicle (Reference 62). FDER inspectors identified the same types of wastes inside the shed in inspections approximately two years ago (Reference 6).

Waste Management Practices

Vehicle maintenance shop wastes are currently picked up by recyclers or exchanged to suppliers for new supplies. The Public Works Department has contracted with GSX, a permitted treatment storage disposal contractor, to take wastes which cannot be recycled. At the time of the VSI, drums of anti-freeze, diesel fuels contaminated with water, grease contaminated with dirt, and spent kerosene from the Former Parts Washer Unit (SWMU 6) were awaiting pickup by GSX at the Hazardous Waste Drum Accumulation Area (SWMU 9)(Reference 62).

Prior to 1988, wastes were accumulated in drums in and around the Public Works Department facility. No particular area was designated for storage of waste materials at the facility. It is not known how wastes were disposed of prior to 1988 except that many of these wastes generated at the facility were disposed in the Waste Drum Landfill (SWMU 1). According to facility personnel, the wastes that went into the illegal landfill in 1988 had been accumulating for as many as eight years (Reference 62).

Waste management has been inadequate based on FDER inspections conducted in October and November, 1988 and the VSI conducted in September, 1990 (References 6 and 8). Inspection reports document paint spills on the ground, rusted containers, and missing labels. The November, 1988 inspection report documented that a 55-gallon polyethylene drum was observed tipped on its side and leaking to the ground. When the Waste Drum Landfill (SWMU 1) was reported, the complainant alleged that operators were observed pouring out the contents of drums onto the ground (Reference 1). The former City Engineer and Director of Public Works reported that eight drums were emptied of rainwater prior to their disposal (Reference 6). Since only one of the sixteen drums was found to be empty, whether it was rainwater that was poured to the ground or not is a concern. During the VSI, information on where drums were emptied was not known by facility representatives.

Wastes disposed in the landfill consisted of waste oils (possibly from the vehicle maintenance fleet shop), ignitable wastes (possibly kerosene from the Former Parts Washer (SWMU 6)), and drums of road-striping paint. The yellow striping-paint was reportedly bought approximately 10 years ago from a government surplus outlet and was stored inside and outside of the tool shed located next to the Vehicle Maintenance Fleet Shop. Eventually, the paint became unusable and therefore became a waste material.

Environmental and Demographic Setting

1. Meteorology

The City of Longwood Public Works facility is located in Seminole County, Florida. Seminole County is located in central Florida between the Gulf of Mexico and the Atlantic Ocean. The climate, ranging from temperate to subtropical, is controlled by the latitude, proximity to the Atlantic Ocean and Gulf of Mexico, and numerous lakes (Reference 81).

July and August are the warmest months of the year with an average daily maximum temperature between 91 and 92 degrees Fahrenheit and an average daily minimum temperature between 71 and 72 degrees. Once or twice a year, the temperature may reach 100 degrees or higher. The average daily maximum temperature in the winter is about 72 degrees, and the average minimum temperature is about 50 degrees (Reference 83).

Most years have a rainy season and a dry season. Based on record from 1951 to 1980 period, more than one half (27 inches) of the precipitation for the average year (47.8

inches) occurs in the summer, between June and September. This is a result of thunderstorms, which occur in half of all summer days. Prevailing wind directions are generally from the north during winter months and from the south during summer months as shown in Figure II-3 on the following page. The windiest months are February and March with mean speeds of 9.8 and 10.0 mph (Reference 81).

2. Floodplain and Surface Waters

Seminole County is located in the central or midpeninsular zone of Florida. It consists of alternating ridges and valleys with abundant lakes located on both landforms. The City of Longwood is located on the Osceola Plain which is a broad, flat area of low local relief and is generally between 60 and 70 feet in elevation. The facility, which is located roughly in the western part of the county, varies from approximately 68 to 73 feet above sea‑level (Reference 67).

Drainage on the Public Works property Parcel 18 is from northeast to southwest to a Stormwater Retention Basin (SWMU 13) as shown on the topographic map given in Figure II-4. Drainage on the remaining parcels is to the northeast. There is no municipal stormwater collection system for the area. Countless shallow lakes, and man-made stormwater management systems manage local stormwater runoff. The closest surface waters are that of East Lake and Lake Jane which are approximately one-third and two-thirds of a mile away from the facility, respectively, in addition to some low spots to the northeast (Reference 83). The Public Works property is approximately one-third of a mile outside the projected 100‑year flood plain (Reference 67).

3. Soils and Geology

Seminole County is underlain by a thick sequence of limestone and dolostones, upon which a relatively thin section of clastics (sand, silt, shell material, and clay was deposited (Reference 83). The clastic material is referred to as undifferentiated surficial clastics because the deposits have not been studied adequately to formally name them. In some areas, mainly to the west and south of the county, the shelly material is absent. Underlying the clastics is the Hawthorne Group which varies from 0 to 130 feet in thickness and consists of sand, silt, clay, and

Figure II-3

Wind Rose

(Reference 79)

Figure II-4

Facility Topographic Map

(Reference 79)

some limestone or dolostone beds. Black to amber grains of phosphate are very common and are intermixed throughout the lithologies. In addition, these lithologies are typically intermixed with each other. Very few pure, single-lithology beds are in the Hawthorne Group.

Underlying the Hawthorne Group is the Ocala Limestone Formation which varies from 1 to 130 feet. This group consists of loose to moderately well cemented masses of very small to large microfossils with some dolostone. Underlying the Ocala is the Avon Park Limestone Formation which is approximately 300 to 350 feet thick. It consists mostly of hard, brown dolostone and some tan, granular limestone. Generally, the lower half of the formation is hard dolostone, which contains many caverns and fractures. The upper half consists of cream to tan, granular limestone interbedded with very fine-grained, hard to soft dolostone. The limestone is composed of a mixture of very small, cone-shaped microfossils that are usually loose to poorly cemented or friable (Reference 83).

The Soil Survey of Seminole County indicates that the dominant soil series at the facility is of the Tavares-Millhopper fine sands. These soils are nearly level to sloping and are moderately well drained. Generally, this series consists of about 58 percent Tavares soil and about 40 percent Millhopper soil and similiar soils. Typically, the Millhopper soil has a surface layer of dark gray fine sand about 7 inches thick followed by a 50-inch layer of pale brown fine sand, with a white fine sand in the lower part. A gray to pale brown fine sand subsoil extends 80 inches or more. The Millhopper soil has a surface layer of dark gray fine sand about 7 inches thick. The subsurface layer consists of pale brown and gray sandy loam extending to about 50 inches (Reference 83).

The surficial soils in this area have a seasonal high water table at a depth of 36 to 60 inches for up to six months. The permeability of the Tavares soil is rapid or very rapid. The permeability of Millhopper soil is rapid in the surface and subsurface layers and moderately slow in the subsoil. The soils are poorly suited to sewage lagoons, trench sanitary landfills, and shallow excavations (Reference 83).

Site-specific boring logs from two reports: the Detection Monitoring Plan prepared by International Environmental Services, Inc. and a Subsurface Soils Investigation prepared by American Testing Laboratories, Inc. were reviewed (References 67 and 77).

The Detection Monitoring Plan is required under the Consent Order for the closure of the Waste Drum Landfill (SWMU 1). The plan incorporates 40 CFR Regulations 264.97 and 264.98 of Subpart F. Boring logs for 15 monitoring wells taken in the winter of January, 1990 are shown in Figure II-5. Thirteen of the wells were logged at 15.5 to 16 foot depths. Two deep wells were installed at 27 and 43 feet. The geologic cross-sections based on these logs are shown in Figures II-6, II-7 and II-8. The first twelve feet (144 inches) are described as brown-gray sandy clay. The next

fifteen to eighteen feet (180-216 inches) are described as brown-gray clayey sand with the sand content increasing with depth. At 27-33 feet below the surface, a dense blue-green clay layer was found. Based on two borings, this clay layer was found to be six to eight inches thick. Directly below the blue-gray clay was an unconsolidated sandy clay. Ground water was found from four to six feet below the ground surface (Reference 67).

In April, 1987, a subsurface soils investigation was prepared by American Testing Laboratories, Inc. for the proposed Public Works office on Parcel 18. A 20-foot boring was taken at the site of the proposed Public Works office. The soils encountered were described as follows:

0'- 1.0' Light gray sandy clay

1.0'- 5.0' Dark gray fine sand

5.0' - 7.0' Light gray sandy clay

7.0' - 11.0' Light brown to orange clayey fine sand

11.0' - 19.0' Light brown moderately silty fine sand

19.0' - 20.0' Light brown to orange slightly silty cemented sand

In addition, a field permeability test was performed in the proposed retention pond area. The field permeability test ranged from 1.3 x 10^-5 ft/min to 6.9 x 10^-4 ft/min which is considered to be a slow drainage rate for fine sands and sandy clay. The ground-water table was encountered at depths of 4.5 to 5.0 feet. It was stated in the report that fluctuations in the ground-water level would be anticipated depending on rainfall and site drainage conditions. Anticipated high wet season water table was estimated as 3.0 feet below the existing ground surface in the retention basin area (Reference 77).

4. Ground Water

In Seminole County, ground water occurs under nonartesian and artesian conditions. The base of the nonartesian aquifer is at the top of the clay and clayey sand and shells that comprise confining beds that overlie the Floridan aquifer. In most of the county, the base of the artesian aquifer is 20 to 60 feet below land surface.

Water from wells in the nonartesian aquifer is very soft (hardness less than 25 mg/l), relatively low in dissolved solids concentration (100 mg/l), and has a pH less than 7, indicating that the water is mildly corrosive where the

Figure II-5

Monitoring Well Locations at Waste

Drum Landfill (SWMU 1)

(Reference 67)

Figure II-6

Cross-Section Reference Map for Figures II-7 and II-8

(Reference 67)

Figure II-7

Facility Geologic Cross-Section A-A'

(Reference 67)

Figures II-8

Facility Geologic Cross-Section B-B'

(Reference 67)

nonartesian water table is above the potentiometric surface of the Floridan aquifer. The nonartesian aquifer is recharged by local rainfall.

Water leaves the nonartesian aquifer by seepage to lakes, ditches, and streams; by evapotranspiration where the water table is near land surface; and, by pumpage. In addition, water can leave the nonartesian aquifer by seepage through confining beds which are semi-permeable, thin or breached by sinkholes. Seepage to the Floridan from the nonartesian occurs only when the potentiometric surface of the Floridan aquifer is below the nonartesian water table. The city well log for the water plant indicates that the static water level is at 32 feet (Reference 76). The water level from boring logs taken around the facility documents the nonartesian aquifer at 4-7 feet (Reference 79). Therefore, the nonartesian aquifer could provide some recharge to the Floridan depending on the degree of interconnectedness between the two aquifers. When the city well is pumping, recharge would be accelerated from the nonartesian to the Floridan. The extent of the city wells effect on local ground water is not known at this time but is included as part of the Detection Monitoring Plan. Ground water flow direction is described as flowing to the northeast, as shown in Figure II-9 (Reference 79). Ground water flow direction will be confirmed as part of the Detection Monitoring Plan (Reference 79).

The nonartesian aquifer generally yields less than 20 gallons per minute and is used for some lawn irrigation and domestic use in rural areas where public water supplies do not exist.

5. Receptors

The facility is zoned as industrial surrounded by residential to the south and east, commercial to the west, and industrial to the north as shown in Figure II-10 on the following page. The general public is not permitted access to the facility. According to facility personnel, the public works facility was formerly the location of a saw mill.

According to facility representatives, the population of Longwood is approximately 16,000 people.

Three wells supply water to the City of Longwood. One of these wells is located on facility property. The well has a capacity of 2.6 million gallons per day (mgd) and services 5000 billing connections which includes service to both businesses and residential homes.

Based on information received from Seminole County staff geologists, it was verified that irrigation wells and some domestic wells would likely be found in the areas adjacent

Figure II-9

Ground Water Flow Direction in Proximity

of Waste Drum Landfill (SWMU 1)

(Reference: 67)

Figure II-10

Land Use Map

(Reference: 67)

to the Public Works facility. Small two-inch wells which are exempt from permitting requirements are frequently installed for heat pumps, small commercial establishments, convenience stores, and for lawn irrigation. In addition, wells were probably installed in the area prior to the 1970s which were not recorded. Therefore, identification of domestic wells in the vicinity of the facility would require a house-to-house survey of the area.

III. SWMU AND AOC DESCRIPTIONS

This chapter presents detailed descriptions and release assessments of each solid waste management unit identified during the PR and VSI. The descriptions encompass physical and functional characteristics, dates of operation, wastes managed and release controls. The release assessments encompass history of releases and conclusions regarding the release potential to soil/ground water, surface water, air, and the potential to generate subsurface gas. The locations of the SWMUs and AOCs are presented in Figure III-1 on the following page.

Figure III-1

SWMU and AOC Location Map

(Reference 79)

SWMU DATA SHEET

Page 1 of 3

SWMU NUMBER: 1 PHOTO NUMBER: 1-10

NAME: Waste Drum Landfill

TYPE OF UNIT: Landfill

PERIOD OF OPERATION: October 23, 1988 to December 20-22, 1988.

PHYSICAL DESCRIPTION AND CONDITION:

The unit is an unlined earthen landfill approximately 20 feet by 20 feet located on the south-central section of the maintenance yard, and bounded by Bay, Warren, and Myrtle Streets (See Figure II-1). The unit was created in October 23, 1988 when drums which accumulated at the Former Waste Drum Accumulation Area (SWMU 2) were disposed in this unit. The drums were stacked in an excavation pit at a depth of approximately 11 feet and backfilled with the original excavated soils. On October 31, the unit was discovered during an investigation of a complaint alleging illegal dumping. On December 20-22, all drums were removed from the unit, analyzed for EP-Toxicity Metals, Corrosivity, Ignitability, Volatiles (Halogenated and Aromatic), Pesticides, and Herbicides. During the removal, air releases occured from a fuming 55-gallon drum of acid which was removed from the landfill. Eight of the sixteen drums were manifested to a permitted hazardous waste treatment, storage, or disposal facility as hazardous waste under waste codes D001, D002, D007, and D008. The remaining drums and loose soils excavated from the landfill (approximately 40 cubic yards) were found to be exempt as hazardous waste and disposed by Resource Recovery of America.

At the time of the VSI, the unit was observed to be covered with a plastic sheet over the excavation pit to prevent rainwater and stormwater runoff from entering the excavation pit. The plastic was anchored by piles of sand and rock. Drums of soil and groundwater removed as a result of monitoring well installations were noted at the time. According to the RCRA Part B Closure Application, the contents of the drums will be determined and proper disposal will be arranged.

The Longwood Public Works Department has submitted a RCRA closure permit application for this unit to close the disposal site under 40 CFR 264 requirements as part of the execution of the Consent Order.

SWMU DATA SHEET

Page 2 of 3

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The landfilled wastes were associated with road and vehicle maintenance operations for the City of Longwood. The sixteen drums consisted of one drum believed to be dried up soap powder, three drums containing a mixture of waste oils, hydrocarbons, and water, one empty drum, three drums containing wet and dry yellow road-striping paint,one drum containing muriatic acid, two drums containing solvents, one drum with yellow paint chips in a clear solution, three drums containing soils, and an unknown drum which had a pH of 12.5 and which crystallized upon neutralization. It is not known if the three drums containing soils contained liquid wastes. Although, because these particular drums were described as being destroyed and having sides torn open, any fluids would have leaked out of those drums and soils may have entered the drums when they were disposed in the landfill or in their removal thereof.

Laboratory analyses showed that the drums contained constituents including priority toxic pollutants such as Methylene Chloride, Tetrachloroethene, 1,1,-trichloroethane, Benzene, Ethylbenzene, Toluene, 1,1-Dichloroethane, 1,2 Dichloroethane, 1,1-Dichloroethene, 1,1,2,2-Tetrachloroethane, Trichlorethene, Lead, and Chromium; carcinogens which include Chromium, Methylene Chloride, Tetrachloroethene, 1,1,2,2-Tetrachloroethane, Benzene, and Trichloroethene; ignitables composed of volatile organic compounds; corrosives composed of strong acids and bases; and EP Toxic metals including Lead and Chromium. A summary of laboratory analyses performed on the drums is provided in Appendix C.

RELEASE PATHWAYS: Air ( L ) Surface Water ( L ) Soil (H) Ground Water ( H ) Subsurface Gas ( L )

HISTORY AND/OR EVIDENCE OF RELEASE(s):

Three of the eight drums identified as containing hazardous wastes were open or severely damaged. If hazardous wastes were in these drums, their contents were released to the soils and possibly to the perched aquifer which has been documented in the summer months to be from 3 to 4 feet. The unit is currently a RCRA-regulated unit for which a RCRA closure permit has been sought which includes sampling and analysis for ground water, soils, surface water and a ground water monitoring program.

RECOMMENDATION: No Further Action ( )

RFA Phase II Sampling ( )

RFI Necessary ( )

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REFERENCES: 11,20,64,67,62,77,79

COMMENTS: This unit is currently undergoing closure activities under the requirements of the FDER's RCRA Closure Permitting Program.

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SWMU NUMBER: 2 PHOTO NUMBER: 1-7, 1-9

NAME: Former Waste Drum Accumulation Area

TYPE OF UNIT: Accumulation Area

PERIOD OF OPERATION: According to facility representatives, the unit was constructed approximately three years ago as part of the Parks and Recreation shed.

PHYSICAL DESCRIPTION AND CONDITION:

The unit consists of a concrete pad approximately 15 feet by 12 feet in area, located next to the Parks and Recreation shed. The unit is located in the central south end of the facility. It is stated that this unit managed the sixteen drums which were disposed of in the Waste Drum Landfill (SWMU 1). The drums were brought to this unit from various locations around the Public Works facility prior to their disposal to the Waste Drum Landfill (SWMU 1). According to facility personnel, the drums were stored there for approximately a week. On October 23, 1988 drums were removed from this area and disposed of in the Waste Drum Landfill (SWMU 1). The unit has also been used for parking vehicles and storing various other materials.

At the time of the VSI, the unit contained empty rusted drums and a heating oil tank with approximately 4 inches of what appeared to be heating oil. According to facility personnel, the unit has managed fertilizer and product drums. The concrete pad was observed to be in good condition at the time of the VSI with minimal staining and cracking. The unit's intended use is apparently for parking vehicles and therefore has no containment features to prevent spillage from being released to adjacent soils. This unit was observed to be approximately a foot from the side slopes of the Stormwater Retention Basin (SWMU 13)

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

According to facility personnel, the unit most likely managed all possible waste streams (including pesticides) which have accumulated over the life of the facility. A FDER November 1, 1988 inspection report provided in Appendix D observed the following materials at this unit:

o One 5-gallon container of EP-90^TM. This container was empty and stored upside down with its top open.

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o Four 5-gallon containers of material that had only corrosive labels on them.

o One 5-gallon container of Lux Office Machine Cleaner Concentrate No 12A.

This unit had been the storage area for the drums that were buried in the Waste Drum Landfill (SWMU 1). Refer to 'Wastes and/or Hazardous Constituents Managed' under SWMU 1 for a description of hazardous constituents which have been managed by this unit.

RELEASE PATHWAYS: Air (L) Surface Water ( L-M ) Soil (H )

Ground Water ( M ) Subsurface Gas ( L )

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No information on releases was reported or found in the available file material. Releases are suspected due to poor housekeeping practices.

RECOMMENDATION: No Further Action ( )

RFA Phase II Sampling ( X )

RFI Necessary ( )

REFERENCES: 64,67,62,79

COMMENTS: Releases are suspected due to poor housekeeping practices.

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SWMU NUMBER: 3A, 3B, 3C PHOTO NUMBER: 1-12

NAME: Parks and Recreation Accumulation Areas

TYPE OF UNIT: Indoor and Outdoor Accumulation Areas

PERIOD OF OPERATION: The Parks and Recreation shed was constructed in 1986. Waste accumulation areas inside the shed were first observed in 1988 by FDER inspection personnel. At the time of the VSI in September 1990, a waste accumulation area was observed outside of the shed. Therefore, the waste accumulation areas 3C and 3D could have been in use from 1986-1988 and 3A from 1988-1990. Information on the period of operation of 3B was not known.

PHYSICAL DESCRIPTION AND CONDITION:

These units consist of undefined accumulation areas inside and outside of the Parks and Recreation Shed. The Parks and Recreation shed is located in the south-east corner of the site. The shed is an open-walled shed with an interior concrete base slab.

The areas are not identifiable by a specific size, as the wastes appear to be stored randomly on grassed areas out of convenience. The sizes fluctuate as wastes are moved from one place to another. The wastes originated from day-to-day Parks and Recreation operations.

During the inspection, two accumulation areas, 3A and 3B, were identified. A review of file material of previous inspector's reports indicated that other areas not identified during this inspection were previously used. Two additional areas, 3C and 3D, were identified based on this review. The three units identified are described as follows:

3A This unit was observed during the VSI. The unit consists of an open grassy area, approximately 8 feet long by 5 feet wide, which was accumulating rusted paint cans, pesticides, and herbicides from Parks and Recreation operations. The wastes were stored in one and five-gallon commercial containers. Facility personnel indicated that the waste containers may have been moved outside of the shed to obtain vehicle access.

3B This unit is a black and white steel drum stored on a wooden pallet with two other drums of Malathion^TM. The unit was located inside on the south end of the Parks and Recreation Shed. The drum is included as

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a unit because facility personnel did not know if the drum was waste material or product.

3C This unit was observed in an FDER inspection on November 1, 1988. The unit consists of an accumulation area located on the left front corner of the shed. Paints, fire ant killer, and PVC cement were being stored at this unit.

3D This unit was observed in an FDER inspection on November 1, 1988. The unit consists of an accumulation area located ont the right front corner of the shed. Paints, primers, and unknown materials were being stored in this unit.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

SWMU 3A

The unit manages waste paints, fertilizers, pesticides, and various other commercial chemical products. During the VSI, the following wastes were observed:

o Lixclean^TM - 5-gallon metal container, at least one-hallf full.

o Malathion^TM - Plastic container, at least one-half full..

o Spotkill^TM - Bluee plastic container, at least one-quarter full. A peeling label on the container indicted that sodium cacodylate, and dimethyl arsenic acid were ingredients. The label contained the words, " Store out of sunlight."

o Unknown - TTwo unlabeled 5-gallon plastic containers.

o Paint - Approximately 30, 1-gallon empty or nearly empty paint cans.

o EP-90^TM - Emptyy rusted-out metal container. Further description of the contents could not be determined from weathered labels.

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SWMU 3B

The drum was unlabeled and full of an unknown liquid material. Facility personnel did not know whether the material was waste or product material.

SWMUs 3C and 3D

A complete description of wastes managed by this unit is given in the FDER November 1, 1988 inspection report provided in Appendix D.

RELEASE PATHWAYS:

3A Air (L) Surface Water ( M ) Soil ( M )

Ground Water ( M ) Subsurface Gas ( L )

3B Air (L) Surface Water ( M ) Soil ( M )

Ground Water ( M ) Subsurface Gas ( L )

3C Air (L) Surface Water ( M ) Soil ( L )

Ground Water ( L ) Subsurface Gas ( L )

3D Air (L) Surface Water ( M ) Soil ( L )

Ground Water ( L ) Subsurface Gas ( L )

HISTORY AND/OR EVIDENCE OF RELEASE(s):

During the VSI, spillage was observed from paint cans and some paint staining was observed on the grassy area from unit 3A. No information on other releases from this unit or units 3B, 3C, or 3D was reported or found in the available file material.

RECOMMENDATION: No Further Action ( )

RFA Phase II Sampling ( X )

RFI Necessary ( )

REFERENCES: 62

COMMENTS: It is suggested that the facility determine whether the drum (SWMU 3B) contains product or waste, label it, and store it accordingly.

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SWMU NUMBER: 4 PHOTO NUMBER: 1-1

NAME: Vehicle Wash Rack

TYPE OF UNIT: Vehicle Wash Rack

PERIOD OF OPERATION: 1982 to Present

PHYSICAL DESCRIPTION AND CONDITION:

The unit is located in the south-west section of the facility behind the Public Works offices. The unit is a concrete pad approximately 14 feet long by 10 feet wide. The unit is used for vehicle washdown. A hose is located to the south for a high pressure washdowns. According to facility personnel, 1-ton trucks, front-end loaders, backhoes, and pickup trucks are washed in this area. Decontamination of equipment used in the excavation of drums from the Waste Drum Landfill (SWMU 1) was not performed at this unit. Vehicle residues accumulate on the surface of the concrete pad or washoff onto the surrounding ground. No drains collect the rinsewaters according to facility personnel.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit manages vehicle wash rinsewater and sediments, which may contain oil, gasoline, and grease residues. Mild biodegradable domestic detergents are used as soap.

RELEASE PATHWAYS: Air (L) Surface Water (L) Soil ( L-M )

Ground Water (L) Subsurface Gas (L)

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No information on releases was reported or found in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 62, 69

COMMENTS: None.

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SWMU NUMBER: 5A, 5B, 5C PHOTO NUMBER: 1,2,3,4,15

NAME: Construction/Demolition Debris Staging Areas

TYPE OF UNIT: Solid Waste Accumulation Areas

PERIOD OF OPERATION:

Exact start-up dates for use of the accumulation areas are not known due to the fluctuation in numbers of accumulation areas and volume. The area where these units are located are on Parcels 18 and 19. Parcel 18 was purchased in the late 1970s. Parcel 19 was recently purchased.

PHYSICAL DESCRIPTION AND CONDITION:

The units consist of many areas within the facilities boundaries where miscellaneous construction/demolition debris is stored. Waste handled by these units originate from day-to-day Public Works Department maintenance operations. During the inspection, it was evident that other areas may have been previously used to accumulate construction/demolition debris as the wastes appeared to be stored randomly on grassed areas. According to facility personnel, the units are not identifiable by a specific size because the facility is used as a layover area until wastes can be hauled to the local landfill, sold, reused or picked up for scrap metal reclamation. The sizes fluctuate as wastes are moved from one place to another. The units identified during this inspection include:

5A The unit consists of an area located in the south-west corner of Parcel 18 and included a 1,000-gallon tank approximately 11 feet long with a diameter of approximately 4 feet. The tank was observed on the ground on the southwest corner of Parcel 18. The tank appeared to have been at one time an underground unit based on the outward appearance of the exterior which was soiled and badly rusted. According to facility personnel, the tank was previously located at the old Longwood City Police Department for refueling vehicles. The tank had a petroleum product odor and was observed to contain about 2-3 inches of fluid. Given by the intensity of odor, it contained water and gasoline residues in solution. The area around the tank is vegetated with some piping stored to the west.

5B The area south of the Vehicle Wash Rack (SWMU 4) where demolition debris (e.g., concrete, fencing, and steel piping) were accumulating.

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5C The area located on the north sides of Parcels 18 and 19 where a rusted drum was placed. The drum bottom was completely rusted through. Facility representatives did not know what had been in the drum.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The units manage construction and demolition debris including: piping; concrete; empty drums; wood products; and fencing.

RELEASE PATHWAYS: Air (L) Surface Water (L) Soil ( L )

Ground Water (L) Subsurface Gas (L)

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No information on releases was reported or found in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 62

COMMENTS: It was not clear as to which materials were reusable. A system for identifying reusable or reclaimed materials did not appear in use. It is suggested that the tank located at SWMU 5A be removed from the facility to discourage improper usage.

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SWMU NUMBER: 6 PHOTO NUMBER: 1-20

NAME: Former Parts Cleaner Unit

TYPE OF UNIT: Parts Washer

PERIOD OF OPERATION: 1980 to 1989

PHYSICAL DESCRIPTION AND CONDITION:

The unit consists of a steel parts washer tub with lid approximately 3 feet wide, 4 feet long, and 2 feet deep. The parts washer tub has a steel tray approximately 5 inches from the bottom of the unit. The unit, used as a vehicle parts washer, was formerly located within the Vehicle Maintenance Fleet Shop and is no longer used for parts washing. The kerosene was removed from the unit in December 1989. Spent kerosene from the unit was observed to be drummed and stored at the Hazardous Waste Drum Accumulation Area (SWMU 9). According to facility personnel, wastes generated from this unit are drummed twice a year and stored nearby. At the time of the VSI, this unit was observed to be in good condition.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit formerly managed kerosene which was used as a vehicle parts washer. The unit held twelve gallons which were replaced roughly twice a year.

RELEASE PATHWAYS: Air (L) Surface Water (L) Soil (L)

Ground Water (L) Subsurface Gas (L)

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No information on releases was reported or found in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 62, 69

COMMENTS: None.

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SWMU NUMBER: 7A, 7B PHOTO NUMBER: 1-17, 1-19

NAME: Safety-Kleen Units (2)

TYPE OF UNIT: Parts Washers

PERIOD OF OPERATION: December 1989 to present

PHYSICAL DESCRIPTION AND CONDITION:

These units are parts cleaner stations consisting of a wash-sink and solvent storage drum. Two units are used: one inside the Fleet Services Garage, and the other inside the Fleet Services Heavy Equipment Maintenance Area. The drums located under the unit are removed under contract with Safety-Kleen Corporation who utilize their own transportation equipment. Safety-Kleen replaces the spent solvents with clean solvents every two months or as needed. The contaminated solvents are collected in a drum located underneath the sink. The units are approximately 1.5 feet wide by 2 feet long, by 3.5 feet high and are made of steel. At the time of the VSI, these units were observed to be in good condition.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The units manage approximately 50 gallons of Safety Kleen solvents consisting of mineral spirits. The spent solvent is replaced with clean solvents every other month.

RELEASE PATHWAYS: Air (L) Surface Water (L) Soil (L)

Ground Water (L) Subsurface Gas (L)

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No information on releases was reported or found in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 62, 69

COMMENTS: None.

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SWMU NUMBER: 8 PHOTO NUMBER: 1-18, 1-21

NAME: Waste Oil Collection Unit and Tank

TYPE OF UNIT: Waste oil collection system

PERIOD OF OPERATION: 1979 to present

PHYSICAL DESCRIPTION AND CONDITION:

The unit consists of a waste oil collection unit located inside the Vehicle Maintenance Fleet Shop. The collection unit is piped to a 500-gallon tank located outside. The unit is used for collection of waste oils from vehicles. The indoor collection unit is approximately 2 feet long, 2 feet wide, and 1 foot deep. Parts are placed on a grate upon which waste oils are allowed to drain. The waste oil is then pumped from the collection unit into the tank.

The waste oil tank is an above-ground 500-gallon tank made of steel. The tank is approximately 6 feet long by 4 feet wide. The outside of the tank showed some spillage from adding oil to the inlet of the tank. The tank is located on a concrete pad. The tank's contents are picked up by a private recycling contractor.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit manages waste oils from vehicle maintenance operations. Waste oil is picked up approximately once a month by private recycling contractor.

RELEASE PATHWAYS: Air (L) Surface Water (L) Soil (L)

Ground Water (L) Subsurface Gas (L)

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No information on releases was reported or found in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 47, 62, 69

COMMENTS: None.

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SWMU NUMBER: 9 PHOTO NUMBER: No Photograph

NAME: Hazardous Waste Drum Accumulation Area

TYPE OF UNIT: Drum Accumulation Area

PERIOD OF OPERATION: August 1990 to present

PHYSICAL DESCRIPTION AND CONDITION:

This unit consists of an outdoor concrete pad located in back of the pesticide storage shed. The unit is used to store hazardous wastes generated from the Longwood Public Works Department. The accumulation area is approximately 4-feet wide by 8-feet long. The drums are transported off-site by a permitted treatment, storage, and disposal contractor, GSX, as needed. During the inspection, the 55-gallon drums presently being stored had a plastic sheeting covering the lids of each drum. Facility personnel indicated that this area will become inactive in October 1990. This unit has no containment structures to prevent spillage to the adjacent soils.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

This unit manages 55- and 30-gallon drums of diesel fuel contaminated with water, kerosene, antifreeze, and grease contaminated with dirt.

RELEASE PATHWAYS: Air (L) Surface Water (L) Soil ( L )

Ground Water (L) Subsurface Gas (L)

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No information of releases was reported or found in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 62, 69

COMMENTS: None

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SWMU NUMBER: 10 PHOTO NUMBER: 1-24

NAME: Abandoned Waste Oil Drum

TYPE OF UNIT: Closed-lid Drum

PERIOD OF OPERATION: Unknown

PHYSICAL DESCRIPTION AND CONDITION:

The unit is located in the north-west corner of the facility approximately 6 feet from Warren Avenue. The unit consists of an open grassed area which was managing an abandoned drum contained waste oil. Facility personnel did not know how long the drum had been there. The drum showed signs of rusting. Facility personnel indicated that the contents of the drum would be emptied to the Waste Oil Collection Unit and Tank (SWMU 8).

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit manages a 55-gallon drum of waste oil.

RELEASE PATHWAYS: Air (L) Surface Water (L) Soil (L)

Ground Water (L) Subsurface Gas (L)

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No information on releases was reported or found in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 62

COMMENTS: The drum was full and rusting.

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SWMU NUMBER: 11 PHOTO NUMBER: 1-23

NAME: Scrap Metal Dumpster

TYPE OF UNIT: Dumpster

PERIOD OF OPERATION: August 1990 to present

PHYSICAL DESCRIPTION AND CONDITION:

This unit is an open-topped, steel dumpster located west of the Heavy Equipment Service Area. The dumpster is approximately 4.5 feet wide, 6 feet long, and 3 feet tall. The unit is located on the soil. Metal scraps too large for the dumpster are stored just north of the dumpster. During the VSI, the dumpster showed signs of rusting on the inside walls. The scrap metal is collected by a scrap metal recycler as needed.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit manages scrap metal which is ultimately transported off-site. Wastes are transported off-site on an as needed basis.

RELEASE PATHWAYS: Air (L) Surface Water (L) Soil (L)

Ground Water (L) Subsurface Gas (L)

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No information on releases was reported or found in the file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 62, 69

COMMENTS: None.

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SWMU NUMBER: 12 PHOTO NUMBER: 1-11

NAME: General Refuse Dumpster

TYPE OF UNIT: Outdoor open-topped dumpster

PERIOD OF OPERATION:

The start-up date could not be determined through the facility personnel or the available file material. However, it is possible that this unit may have been active since the late 1970s when the property was purchased. The unit is currently active.

PHYSICAL DESCRIPTION AND CONDITION:

The unit is an open-topped steel, roll-off box located in the north-east of the Waste Drum Landfill (SWMU 1). The unit is approximately 30 feet long, 6 feet wide, and 7 feet tall. The unit rests on a gravel base. The unit is made of steel and is emptied bi-weekly. During the VSI the unit appeared to be in good condition. No release controls were reported or observed.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit reportedly manages general domestic refuse from the Public Works Facility. During the VSI, tree limbs, and other dead vegetation were observed in the dumpster.

RELEASE PATHWAYS: Air (L) Surface Water (L) Soil (L)

Ground Water (L) Subsurface Gas (L)

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No information on releases was reported or identified from the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 62, 69

COMMENTS: None.

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SWMU NUMBER: 13 PHOTO NUMBER: 1-5,1-6

NAME: Stormwater Retention Basin

TYPE OF UNIT: Stormwater Management Unit

PERIOD OF OPERATION: The unit was constructed in approximately 1987 and is currently in use.

PHYSICAL DESCRIPTION AND CONDITION:

This unit is comprised of a grass-lined stormwater retention basin. The unit is approximately 6-feet wide and 40-feet long. No ditches from the unit convey flow from the site. The unit is to be maintained under a Stormwater Discharge Permit. The basin is located in the south end of the facility and is bounded by the Former Waste Drum Accumulation Area (SWMU 2) to the east and Construction/Demolition Debris Staging Area (SWMU 5A) to the west. This unit manages stormwater runoff and sediments from the Parcel 18. The unit is to be maintained under a Stormwater Discharge Permit.

At the time of the VSI, this unit was observed to be receiving sediments from the sand, gravel, and lime rock storage bins located immediately adjacent to the unit. Soil sampling is suggested to determine whether a release has occurred from this unit in relation to either the Waste Drum Landfill (SWMU 1), the Former Waste Drum Accumulation Area (SWMU 2), or the Parks and Recreation Accumulation Areas (SWMU 3).

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit manages stormwater runoff, and sediments from Parcel 18 of the Public Works Facility.

RELEASE PATHWAYS: Air (L) Surface Water (L) Soil (M)

Ground Water (M) Subsurface Gas (L)

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No information on releases was reported or identified from the available file material. However, releases are suspected due to the proximity to other waste management units and the history of poor housekeeping.

RECOMMENDATION: No Further Action ( )

RFA Phase II Sampling ( X )

RFI Necessary ( )

REFERENCES: 62, 72

COMMENTS: None.

AOC DATA SHEET

AOC LETTER: A

NAME: Pesticide Storage Shed

PHYSICAL DESCRIPTION AND CONDITION:

The AOC consists of a wood shed used to store pesticides. The shed is approximately 9 feet long, 6 feet wide , and 8 feet high. The shed was originally purchased in approximately 1987 from the Health and Rehabilitation Services Department to store paints. The shed has contained miscellaneous products including gasoline, grass, seed, paint, Malathion^TM, Round-Up^TM (wet weed killer), Rodeo^TM (dry week killer), and methoxychlor for the formulation of Malathion^TM. There was no ventilation in the shed. Entry by the VSI Field team was stopped due to the strong skunk-like odor emitted from the shed. Staining was observed from the doorway.

The shed is scheduled to be inactivated shortly because a new pre-manufactured storage unit has been recently obtained. It is suggested that when all the pesticides are transferred to the new storage unit, this shed be clean-closed.

RELEASE PATHWAYS: Air (M-H) Surface Water (L) Soil (L)

Ground Water (L) Subsurface Gas (L)

REFERENCE: 62

1.1 View facing west of the Vehicle Wash Rack (SWMU 4) used to wash maintenance and transport vehicles. Construction/Demolition Debris Staging Area (SWMU 5B) were observed to the south of the unit.

1.2 View facing west of one of the three Construction/ Demolition Debris Staging Areas (SWMU 5B). This unit is located south of the Vehicle Wash Rack (SWMU 4).

1.3 View of an abandoned gas fuel tank as part of the Construction/Demolition Debris Staging Area (SWMU 5A) located in the south-west corner of the facility. The tank was resting on the ground and was overgrown with vegetation.

1.4 View facing north of the abandoned gas fuel tank (SWMU 5A). The piping to the west is reportedly being reclaimed for city utility work.

1.5 View facing east of the Stormwater Retention Basin (SWMU 13). Visible in the left of the photograph is the fence surrounding the Waste Drum Landfill (SWMU 1). In the background is the Parks and Recreation shed where SWMUs 2 and 3 are located.

1.6 View of north side of the Stormwater Retention Basin (SWMU 13). Stockpiled materials (e.g., lime rock, sand, gravel) were observed to be washing into the unit.

1.7 View facing south of the Former Waste Drum Accumulation Area (SWMU 2). The unit was managing empty 55-gallon drums and a 100-gallon tank containing approximately 3 inches of oil.

1.8 View facing north of the drums containing soil and ground water obtained from the installation of monitoring wells. The drums were sealed with lids at the time of the VSI and were removed only to document their contents as spoil materials.

1.9 View of the rod used to identify the amount of waste material inside a 100-gallon tank found in the Former Waste Drum Accumulation Area (SWMU 2).

1.10 View facing south of the Waste Drum Landfill (SWMU 1). The site was fenced and covered with a plastic sheeting.

1.11 View facing east of the General Refuse Dumpster (SWMU 12). The dumpster rests on a concrete pad located east of the Waste Drum Landfill (SWMU 1).

1.12 View facing north of one of the Parks and Recreation Accumulation Areas (SWMU 3). Note the spilled paint, and debris (e.g. wood, metal) found next to the unit.

1.13 View of the Parks and Recreation Unidentified Drum (SWMU 3B) located in the Parks and Recreation Shed.

1.14 View of the new pre-manufactured storage unit which will be used to store pesticide products. The facility is located on Parcel 19.

1.15 View facing east of one of the Construction/ Demolition Debris Staging Areas (SWMU 5C). Concrete, empty drums, piping, and wood are stored at this location.

1.16 View of one of the Safety Kleen Units (SWMU 7A) stored at the Vehicle Maintenance Fleet Shop.

1.17 View of the Asbestos Fibers Collection Unit and Safety Kleen Unit (SWMU 7A) found inside the Vehicle Maintenance Fleet Shop. According to facility personnel, the Asbestos Fibers Collection Unit has recently been purchased and had never been used.

1.18 View inside the Vehicle Maintenance Fleet Shop of the indoor collection container of the Waste Oil Collection Unit (SWMU 8). The unit receives waste oils which are then pumped into a 500-gallon tank located outside the building.

1.19 View of the second Safety Kleen Unit (SWMU 7B) located inside the Heavy Machinery Shop. Note staining on concrete floor beneath the unit.

1.20 View of the Former Parts Cleaner Unit (SWMU 6) inside the Heavy Machinery Storage Area. The unit was observed to be empty and cleaned.

1.21 View facing south of the tank of the Waste Oil Collection Unit and Tank (SWMU 8). This tank is piped to the waste oil collection unit inside the Vehicle Maintenance Fleet Shop (See photo 1.18). Staining was noted on the west end of the tank.

1.22 View facing north of the Pesticide Storage Shed (AOC A). The Hazardous Waste Drum Accumulation Area (SWMU 9) is located immediately behind this shed.

1.23 View facing east of the Scrap Metal Dumpster (SWMU 11). The unit was rusty and worn. Scrap metal was noted being stored outside the dumpster.

1.24 View facing west of the Abandoned Waste Oil Drum (SWMU 10). The unit had been lying on the ground with other debris and it showed signs of rusting.

[1] The normal shelf life for Malathion^TM is one and a half years when the product is stored at temperatures less than 77-86 degrees Fahrenheit (25-30^o Centigrade) (Reference 82).