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, description of facility operations, waste generation, regulatory history, past and present waste management practices, release history, and the environmental and demographic setting for the University of South Alabama. The SWMUs and AOCs are described in Chapter III. A summary of the SWMUs and AOCs is presented in Chapter IV. Chapter V presents suggestions for a sampling strategy for those units where Phase II sampling is the suggested further action. The references used in this report are listed in Chapter VI. Appendices A and B are the VSI log book and photographic log which document the physical condition of the SWMUs. Appendix C is a list of pesticides used at USA.

A. File Search and VSI

Available EPA Region IV and Alabama Department of Environmental Management (ADEM) RCRA, CERCLA, Air, and water files concerning the USA facility were examined during August 1990 file searches. The EPA Region IV file search was conducted by C. Nardiello of A. T. Kearney and the state ADEM file search by E. Gray of Harding Lawson Associates. 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 20 and 21, 1990, by an EPA contractor team (Ms. P. Davol and Ms. L. Griffin of A.T. Kearney), a USEPA Region IV representative (Ms. E. Ketcham), and two ADEM representatives (Mr. M. Behel and Mr. T. Garret). Participants from USA included: Dr. J. Vacik (Director of Environmental Safety), Ms. A. Foster (Environmental Control Technician), Mr. S. Hammack (Assistant Administrator), Mr. B. Callender (Business Manager of the Office of Vice President Business Affairs), and Mr. W. Robinson (Assistant to the Dean of the College of Medicine) (Reference 103).

The VSI kickoff meeting began at approximately 8:00 a.m. Dr. Vacik presented a brief summary of hazardous waste management practices at USA, and then he and other participants responded to specific information needs.

After the meeting, the VSI team reviewed the current TSD Building (SWMUs 12-19), Basic Medical Science Building 6 (SWMUs 22,23,24), Central Utilities Building 22 (SWMUs 25 and 26), Underground Waste Oil Tank (SWMU 30), and other product USTs (AOC A). Weather conditions were generally calm and sunny, with temperatures approaching 85°F. At approximately 5:00 p.m., the VSI team left the USA campus.

The VSI continued the following day. Conditions were again calm, sunny, and warm (80°F). Following a meeting and a review of the facility map, other potential SWMUs were identified and investigated. These included a tour of the Art Complex at Building 9 (SWMU 6), Chemistry Building 43 (SWMU 10), Laboratory of Molecular Biology Building 33 (SWMU 8), and The Cancer Center/Clinical Building 34 (SWMUs 20 and 21). The closeout meeting began at 12:30 p.m. The VSI team left USA campus at approximately 2:00 p.m. on September 21, 1990.

B. Facility History, Process Description and Wastes Generated

USA is primarily an academic and research facility with undergraduate and graduate programs in Nursing, Education, Arts and Sciences, Computer and Information Sciences, Continuing Education, College of Medicine, Engineering, Business, and Allied Health. The University Public Affairs Office estimates that the University's activities involve approximately 20% research, 20% health care, and 60% instruction (Reference 104 and 105).

The limits of USA's property boundaries is outlined on the USGS map of Mobile, Alabama, as shown in Figure I‑1. The University owns approximately 1000 acres within USGS quadrangles 16, 17, and 21. The facility is located west of downtown Mobile, Alabama bounded by University Boulevard to the east, Old Shell Road to the south, Cody Road to the west, and mixed residential and commercial to the north. The facility coordinates are latitude N 30 ^o 41' 45", longitude W 88^o 10' 30" (Reference 51).

Figure II-1

University of South Alabama Property Boundaries

on USGS Topographic Map

(Drawn by Facility Representatives at the VSI)

(Source: Reference 107)

SCALE 1:24,000

Before the founding of USA in 1963, the property owned by USA was used for farmland and timber (Reference 104 and 105). A portion of USA's property within quadrangle sixteen was previously owned by the Mobile County School Board, which under law, designated all quadrangles "16" as land designated for education (References 104 and 105). Currently the facility is surrounded by residential areas, with some small businesses. USA maintains a combined graduate and undergraduate student population of approximately 12,000 (References 104 and 105).

Due to various teaching, research, and clinical activities on campus, the facility generates a wide variety of wastes including Ignitable, Corrosive, Reactive, Biological, Toxic, F‑solvent waste streams (halogenated and non-halogenated), and commercial chemical products (P- and U-listed wastes). To some extent, the volume and composition of the some of these wastes depends on the nature of the research underway at USA. Currently, funding is granted for research for the study of AIDs, Crutchfeld Jachobs, Typhus, Legionella, and Lymphoma (G.P.) (References 104 and 105). Non-research generated wastes include the health care facilities, general operations (i.e., physical plant, grounds and maintenance operations), and from teaching laboratories and buildings. All hazardous wastes are ultimately transported to the main campus site for handling in the permitted container storage building. USA's policy is to recover, and recycle to the extent possible prior to declaring materials a waste (Reference 29).

C. Past and Present Waste Management Practices

1. Waste Generation

The USA facility has generated medical and laboratory wastes since its inception in 1963. Waste generation at USA includes activities from the USA research laboratories, medical care facilities, support operations, and off-site generators. The types of wastes generated from these sources include general refuse, hazardous chemicals, medical/pathological, nonhazardous chemicals, radioactive, mixed. Of these four waste generators, the majority of waste generation at USA occurs from the research laboratories. USA wastes are received or packaged in small containers ranging from 0.001 kilograms to 200 kilograms (Reference 70). Approximately 30,000 pounds per year of waste material are generated each year for off-site disposal (Reference 119). Approximately 40% of that amount is received from off-site generators (Reference 112).

Due to the large number of individual generators at USA, specific wastes and quantities are extremely diverse (Reference 29). Wastes are generated by some 100 research laboratories, chemical repositories, and support facilities which are constantly changing (Reference 119). Many different chemicals are in use or stored at USA facilities. Any of these may be discarded. Some could be described by more than one EPA hazardous waste code (Reference 119).

During the years from USA's inception from 1963 to 1973, wastes were reportedly generated from only two buildings: the Life Sciences, and Administration Building (Reference 107). Ten years later five buildings containing labs were added. To date, ten buildings with laboratories exist at USA (Reference 107). Buildings which have been designated for chemical, and infectious waste accumulation areas and the types of wastes generated from them are shown in Table 1.

USA's RCRA Part A Permit Application lists approximately 150 different EPA Hazardous Waste Numbers. The wastes fall into several categories, including D, F, P, and U wastes. The wastes include 26 "P" and 112 "U" listings with EPA and Alabama Hazardous Waste Numbers; solvents and solvent mixtures numbered F001 to F005; wastes that exhibit the characteristics of ignitability, corrosivity, reactivity or EP Toxicity (D001 - D009, and D011); pathological wastes; and numerous unlisted, non-characteristic hazardous wastes (Reference 86). In addition, USA handles mixed wastes (specifically scintillation-fluids). It is anticipated that solvent (toluene) based fluids will gradually be phased out, according to University policy, resulting in reduced generation of flammable/radioactive "mixed" wastes (Reference 104 and 105).

A review of USA's 1989 generator report indicates that pathological waste at approximately 5400 pounds is the largest quantity of waste handled by USA. The next largest waste streams include corrosive chemical wastes (D002), chromium wastes (D007), non-halogenated wastes (F005), chemical N.O.S (Not Otherwise Specified), xylene (U239), halogenated solvents (F003), formaldehyde (U122), toluene (U220), and acetone (U002). Corrosive chemicals are primarily produced from photographic processing units used in various buildings of USA's campus (Reference 107). Much of the corrosive wastes are neutralized and disposed to the sanitary sewer. The large quantity of chromium wastes were reportedly a one time occurrence in 1989 when the Brookley Campus discovered off-spec boiler descaler product which had been abandoned (Reference 118). Waste solvents are generated from use of High Performance Liquid Chromatography (HPLC) units from the Life Sciences Building

TABLE II-1

LIST OF CHEMICAL AND PATHOLOGICAL

WASTE ACCUMULATION AREAS LOCATED IN USA BUILDINGS

Example of

Building Description Types of Wastes Generated

Administration Bldg. 1 Photoprocessing

Instructional Lab Bldg. 2 Chemical

Life Science Bldg. 5 HPLC[1]

Medical Science Bldg. 6 Chemical

University Center Bldg. 18 Photoprocessing,

newspaper inks

Art Studio and Complex Bldg. 19 Photoprocessing, paints, solvents, metal etchings

Central Utilities Bldg. 22 Waste oils, mineral spirits sludge, cleaners, waxes

Laboratory of Molecular Scintillation fluids, Biology Bldg. 33 thidium bromide, HPLC, methyl alcohol, toluene

Cancer Clinic Bldg 34 Photoprocessing,

chemical

Chemistry Bldg. 43 Chemical

Computer Center Bldg. 45 Circuit board etchings,

MEK, acids

(Reference 107). Instructional labs generated corrosives, halogenated, and nonhalogenated solvents as part of waste

segregation practices (Reference 107). Xylene still bottoms (F003) wastes are generated from off-site and on-site medical care facilities in the process of producing slides of tissue sections in Pathology (Reference 107). Formaldehyde (U122) is used in specimen preservation and ultimately treated at USA by oxidation and disposed of to the sanitary sewer as stipulated in their Part B permit application (Reference 107). Toluene is generated as a result of scintillation usage from the Laboratory of Molecular Biology. The remaining wastes are generated in small quantities usually less than five gallons or 20 pounds in size (Reference 86). Treatment in 1989 included solvent recovery of xylene (U239) wastes of approximately 340 lbs of material, chemical treatment (primarily D002 wastes) of approximately 7000 lbs of material, biological incineration of 5400 lbs of material, and thermal treatment (or burning) of 615 lbs (Reference 112).

Support operations generate wastes which include general refuse (e.g., waste paper, cardboard, and cafeteria wastes), "maintenance shop" wastes (e.g., vehicle waste oils, mineral spirits sludges, and waste paints), demolition wastes (e.g, asbestos and PCBs), and landscaping wastes (e.g, pesticides and herbicides) (References 104 and 105).

According to facility personnel, a policy for waste minimization which includes laboratory micronization has been implemented and is in its preliminary stage to reduce waste streams generated at USA (References 104 and 105). In addition, in so far as is possible, recovery of solvents, reclaiming laboratory chemicals and recycling (e.g., silver, lead) are performed prior to declaring materials a waste (Reference 29).

2. Waste Management

Waste management at USA has included on-site treatment (T04) in laboratories (SWMUs 13,15,21) on-site disposal to the Sanitary Sewer System (SWMU 35), on-site incineration at the Pathological Incinerator (SWMU 25), on-site recycling (SWMU 22), off-site landfill disposal, and pickup and off-site disposal by a private contractor (Reference 104 and 105). Currently all of these disposal alternatives are being used.

Currently, wastes are treated in laboratories (SWMU 21), distilled (SWMU 15), neutralized (SWMU 13) and disposed of to the Sanitary Sewer System (SWMU 35), evaporated (SWMU 18), incinerated (SWMU 25), stored (SWMU 12, and 21), or manifested off-site to a permitted Treatment Storage Disposal Facility (TSDF). Treatment is performed in both the permitted TSD facility (SWMUs 13,15,18) and at the Storage and Treatment lab in Room 364, Assay/Chemistry Lab, of the Cancer Center/Clinical Science Building 34 (SWMU 21). Nonhazardous and chemical wastes which have been rendered nonhazardous by treatment are disposed to the Sanitary Sewer System (SWMU 35). Controlled Hazardous Substances (CHS) are either evaporated at the TSD Building Waste Evaporation Area (SWMU 18) or shipped off-site to be detonated at a permitted facility (References 104 and 105). Solvents are reclaimed in the TSD Building Distillation Unit (SWMU 15).

Incineration (SWMU 25) is used for the disposal of pathological, radioactive, mixed (chemical/radioactive), and mixtures thereof (e.g., pathological/radioactive mixtures and pathological/radioactive/chemical mixtures) (Reference 119).

Pathological wastes (i.e., animal bedding, animal carcasses) are burned in the on-site Pathological Incinerator (SWMU 25) of which approximately 100 tons per year are pathological (References 104, 107, and 118). USA's pathological wastes from medical care facilities are picked up by Browning Ferris Industries (BFI) which operate under a weekly pickup and disposal contract. USA's research generated pathological wastes are sent to a pathological incinerator located off-site on USA's Medical Center Campus (Reference 118).

According to radiation safety personnel, disposal of long-lived radioactive wastes are allowed in their existing permit but these wastes have not been used at USA (References 104 and 105). Waste mixtures containing Carbon-14 and/or Tritium (containing no pathological material) with an average of less than 0.05 microcuries per milliliter are considered non-radioactive and are handled by Environmental Safety as a chemical waste. Wastes containing isotopes other than Carbon-14 or Tritium or having radioactive concentrations above the 0.05 microcurie per milliliter concentration level or containing pathological agents are managed by the Radiation Safety Department under their license with the Department of Public Health of the State of Alabama (Reference 120).

Radioactive containing mixtures which are handled by the Radiation Safety Department as described above are either disposed of to the Sanitary Sewer System (SWMU 35) or incinerated in the Pathological Incinerator (SWMU 25) (Reference 118). One Curie of radioactive waste (containing no pathological or chemical wastes) is permitted to be disposed of in the Sanitary Sewer System (SWMU 35) according to Section C.303(d) of the Alabama Regulations for the Control of Radiation (Reference 120). In August 1988 through August 1989, approximately 400 microcuries per year of these wastes were disposed directly to the Sanitary Sewer System (SWMU 35). One-hundred microcuries of that amount required storage to allow for decay of radiation levels prior to discharge to the sewer (Reference 107).

Radioactive wastes containing pathological and/or chemical hazards are incinerated in the Pathological Incinerator (SWMU 25). Approximately 40 cubic feet or 8.3 uCi per year of radiological wastes, and 24-36 gallons per year of mixed wastes are incinerated in the Pathological Incinerator (SWMU 25) (Reference 104 and 107). Prior to the 1979 amendment to the Radiation Material License, radioactive contaminated wastes were shipped for off-site disposal (Reference 120).

Chemicals wastes which by their nature or through treatment (SWMU 13) to make then less hazardous are separated by hazard class and stored until pick‑up by a licensed hazardous waste transporter can be arranged (Reference 29).

Disposal practices which have been discontinued include on-site storage at the Former Storage Area in Room 313 of the Cancer Center/Clinical Science Building 34 (SWMU 20), and the Former Storage Area in the Loading Dock Area of the Basic Medical Science Building 6 (SWMU 22). USA's Certification of RCRA closure for these units was received by ADEM in July 17, 1987 (Reference 66,67). Distillation using the TSD Building Distillation Unit (SWMU 15) of scintillation solvents was discontinued in September 1989. On-site incineration at the Pathological Incinerator (SWMU 25) of waste solvents (i.e, toluene from scintillation vials) was discontinued in approximately 1985 (Reference 116). Prior to 1979, liquid or aqueous chemical wastes were disposed from laboratory facilities to the Sanitary Sewer System (SWMU 35) (References 104 and 105). Solid chemical wastes were stored for prolonged periods and/or shipped to the local landfill (References 104 and 105).

In 1982, the university completed a total campus survey of PCB containing transformers and voltage switches. The survey revealed that the University owned some 83 transformers and 6 high voltage switches which were oil filled (Reference 5). According to facility personnel at the VSI, PCBs have been freed or decommissioned from electrical equipment. PCB-containing equipment were placed on trays and immediately transported along with the trays for removal by General Electric (References 104 and 105). USA had one incidence where a transformer leaked onto its concrete pad. According to facility personnel, the leak was cleaned up and the transformer was repaired. Soil samples were taken adjacent to the concrete pad to determine if a release to the soil had occurred. There were no PCBs detected in the soil (References 104 and 105).

In 1982 plans for a new TSD Building and a radioactive animal burial site (to be located 100 feet off the existing Laboratory of Molecular Biology) were drawn up and submitted to ADEM (Reference 5). The TSD Building began operation in 1985 to 1986 (Reference 118). A license for the radioactive burial site was obtained through the Alabama Public Health Department, but the unit was never constructed (Reference 107). In addition, USA incorporated plans for an explosion pot in their TSD building which was never constructed because regulations covering such units had not been promulgated (Reference 18). However, during the construction of the TSD Building, an area for detonation activities was built with heavily reinforced walls for possible future approval and use (Reference 20).

USA owns and maintains twelve operating underground storage tanks which contain diesel, gasoline, and one containing waste oil. Installation dates range from approximately 1968 to 1984 (6-22 years old) (Reference 110). Two unused underground storage tanks were located at the old maintenance building (now the location of the Art Complex). These tanks were removed approximately seven to eight years ago (References 104 and 105).

In 1985, an Industrial Waste Survey for a Municipal Pretreatment Permit was performed in 1985 (Reference 109). Approximately seven manhole locations were selected for monitoring for Biological Oxygen Demand (BOD), Chemical Oxygen Demand (COD), Total Organic Carbon (TOC), Total Suspended Solids (TSS), pH, and phosphorus. Manhole locations were selected from lines immediately downstream from buildings in which laboratory work was conducted. Based on the constituents monitored, it was determined that USA did not need a Municipal Pretreatment Permit (References 104 and 105).

In 1985, the TSD Building (SWMUs 12-19) was constructed to provide a central area for waste management. This building has served as the focus of USA waste management activity. This building is used for sorting, packing, shipping, sample analysis, storage, treatment (T04), and disposal of nonhazardous wastes to the sanitary sewer system. Wastes to be stored at the facility are picked up in a truck designed specifically for hauling and handling hazardous materials. The truck is equipped with fire extinguishers, bronze spark proof tools, spill sprays, etc (Reference 70). The facility maintains a computer system for recording and tracking manifests, inventory, disposed inventory and undisposed inventory (Reference 70).

USA has recently began management of asbestos monitoring. Studies to sample air quality for asbestos has been contracted to Enviro Chem Corp. in Mobile, Alabama. Removal and disposal is performed by contractors (References 104 and 105).

The University maintains east and west cooling towers on the campus. Biocide and descaler chemicals are used in the operations and are discharged as blowdown to Three-Mile Creek.

The facility has had difficulties locating licensed hazardous waste disposal companies who will receive wastes such as osmium tetroxide, batteries, and picric acids. Approximately every one to two times a year, licensed hazardous waste transporters pick up waste for off‑site disposal. The facility does not utilize a hazardous waste broker to arrange for off‑site disposal of wastes (Reference 119).

D. Regulatory History

USA has numerous permits, including RCRA, NPDES, Air, and for pesticide application. Regulatory status information for RCRA was available in the file material. Information regarding the status of the remaining permits was obtained during the VSI.

On November 19, 1980, USA filed a Part A permit application for USA's College of Medicine to receive interim status for container storage (S01), a storage tank (S02), a Pathological Incinerator (SWMU 25) (T03), and other treatment (T04) (Reference 1). In a RCRA interim‑status inspection performed by ADEM on January 12, 1982, USA was informed that the College of Medicine and the University could not be treated separately and they should adopt a consolidated approach to hazardous waste management for the entire University and that "the University is long overdue in establishing a workable hazardous waste management program" (Reference 4).

On September 24, 1982, a revised Part A permit application for USA was submitted to ADEM (Reference 6). The application included a container storage area (S01), a storage tank (S02), incinerator treatment (T03), and other treatment (T04). In conjunction with the revised Part A application, two ammendments to that application were requested by USA to add PCBs to their application and to include a proposed TSD Building for radioactive and hazardous wastes (Reference 5). Other ammendments to the Part A were requested in March and September, 1983 to add Phosgene (P095), 1,2-diphenylhydrazine (U109), and N-phenylthiourea (P-093) (References 9 and 11).

In January 1983, USA was issued a Compliance Order and Consent Agreement by the USEPA Region IV for failure to notify EPA of hazardous waste activities under RCRA 3010 and for failure to file a timely permit application (Reference 8). Therefore, the facility had not achieved interim status under RCRA Section 3005. The Final Order allowed USA to continue to operate as long as compliance with interim status requirements were met.

On May 30, 1983, USEPA called USA to submit a Part B permit application. On December 22, 1983, USEPA received USA's first Part B permit application. The Part B permit application included a container storage area (S01), a storage tank (S02), incinerator treatment (T03), and other treatment (T04) for three USA campuses. In addition, the permit called for closure of existing storage facilities (SWMUs 20 and 22) which had been operating under interim status in place of permitting for a new TSD Building. When the application was reviewed and it was found that the wastes included were from three distinct, non-contiguous campuses, separate EPA I.D. Numbers were issued and separate notifications were requested. Notifications were submitted for the University (EPA I.D. No. ALD 079 474 037) as a generator and a TSD, the Medical Center Campus (EPA I.D. No. ALD 980 839 492) as a generator, and the Brookley Campus as a Conditionally Exempt Small Quantity Generator.

The Part B permit application review process involved four Notice of Deficiencies and two grants for extensions. Further requests by USA for extensions were denied (Reference 23). The issuance of the permit was delayed for over a 26 month period from May 30, 1983 through July 26, 1985 (Reference 93).

In April 1984, USA proposed a change to their RCRA status, during the review of the Part B permit application, to detonate explosive or highly reactive materials (i.e., peroxide containing ether, vinyl lithium, butyl lithium). USA proposed, for safety reasons, to use their own facilities rather than transporting the material to an approved disposal facility (Reference 17). The request for explosive detonation was not granted because regulations covering it had not been promulgated (References 18 and 20). As a result, USA submitted a revised Part B permit application in August 8, 1984 which deleted reference to an explosion pot (T04) from the application. In addition, ADEM informed USA that incineration of biohazardous waste in the Pathological Incinerator (SWMU 25) did not require a RCRA permit and therefore was not included in the Part B permit application. In addition, ADEM informed USA that the incinerator may not be used to burn hazardous wastes (Reference 13).

The file material during 1985 document regulatory history concerning variances and petitions to have an incinerator classified as a boiler in order to have the unit permitted for burning hazardous wastes (References 41, 43, 49, 54, 55, 56, 57, 58, 61). It was later found at the VSI, that the unit was located off-site on the Medical Center Campus (EPA I.D. No. ALD 980839492) (References 104 and 105).

A CERCLA Preliminary Assessment Inspection was conducted at USA on November 24-25, 1984. Under the Alabama RCRA 3012 Site Ranking Scheme, the University of South Alabama was confirmed to require no further action (Reference 27).

On December 31, 1984, the USA was notified that the requirements of the Hazardous and Solid Waste Act (HSWA) Amendments of 1984, specifically Section 3004(u), applied to the Part B permit application currently under review (Reference 31). USA submitted notification of an underground waste oil storage tank in response to the information request (Reference 33). On May 14, 1985 a RCRA Facility Management Strategy inspection was performed (Reference 39). In this review, the Pathological Incinerator (SWMU 25) was identified as utilizing waste solvents as auxiliary fuel and therefore would require a permit under the new definition of Solid Waste under HSWA. On June 18, 1985, ADEM notified USA that both the existing pathological incineratoor and the proposed new incinerator located off-site on the Hospital Campus would fall under RCRA starting July 5, 1985, if USA burned hazardous waste as fuel (Reference 43).

On September 12, 1985 a Hazardous Waste Facility Permit for the University of South Alabama was issued (Reference 51). The permit was issued for a container storage area (S01), and for a treatment tank (T04). Amendment to the Part B permit application to include the Pathological Incinerator (SWMU 25) was not required (Reference 49). Under EPA's direction a Part B permit application was not required for the Pathological Incinerator (SWMU 25) until November 8, 1986 before which the unit could operate under interim status (Reference 49). USA decided to forego the Part B permit application process and discontinue the practice of burning spent solvents (i.e., xylene and toluene) in the Pathological Incinerator (SWMU 25) (Reference 43 and 55).

On April 29, 1986, USA prepared a notification listing of all Underground Storage Tanks for ADEM. Twelve tanks for storage of diesel, gasoline, and one for waste oil with installation dates of approximately 1968 to 1984 were identified in the notification (Reference 110).

USA has had a number of violations noted in RCRA storage permit inspections (References 62,63,65,68,70,71,73,77). During the period of 1986 to 1988, the facility had violations for improper labeling, drum storage, security precautions, manifesting forms, soil erosion management, inspection forms. On March 3, 1988, USA was found in violation for accepting wastes from a generator (Spring Hills Campus) which was not listed in the permit and treatment violations of Alabama Hazardous Waste Management Act (AHWMA) Section 22-30-12(c) and 40 C.F.R. 260.10 for evaporation of solvents without a permit (Reference 73). Because USA held both USEPA and ADEM permits under which Subpart X rules had been effective with USEPA, the violation was later absolved.[2]

In May, 1989, USA met with ADEM to discuss permit modifications (Reference 80). USA indicated that their current permit had certain requirements that were above the requirements of the regulations (i.e., storing containers on pallets and recording DOT numbers on computer inventory records). In addition, USA had Subpart X units (40 CFR Part 264) which were not in the current Hazardous Waste Facility (HWF) permit which they had received a violation for in an inspection which took place on March 3, 1988 (Reference 79). The issuance of a permit for the Subpart X units was denied because Part 264 regulations covering open burning had not yet been promulgated. Since ADEM had included the Subpart X units (T04) on the Part A permit application submitted with the Part B permit application on December 21, 1983, notification requirements had been met and would allow for review by ADEM when Subpart X regulations become effective in October 1989 and resources become available (Reference 82). As a result, USA choose not to modify their current HWF permit (Reference 83).

On October 4, 1989, USA received notification that ADEM had received authorization for all permitting and related activities of the base RCRA program. Where permits were simultaneously or jointly issued by the State and EPA prior to state authorization, EPA transferred the administration of non-HWSA permits to Alabama (Reference 84).

On February 7, 1990, a joint USEPA and ADEM inspection was conducted to address Land Disposal Restrictions Rules (LDRR), RCRA permit, and HSWA requirements at USA. LDRR violations noted by USEPA included improper identification of scintillation fluid as a U-listed rather than a F-solvent waste restricted from land disposal, no land disposal restriction information included with shipments of restricted wastes transported from the Medical Center Campus (Reference 86). Permit violations included items regarding general waste analysis, general inspection requirements, personnel training, waste identification, and solid waste units. Other non-permit related violations included incomplete manifest documentation, misidentification of waste materials, misidentification of land disposal restricted wastes, and no land disposal restriction information included with any of the manifests.

USA recently applied for permit modifications to include TCLP waste codes, and Subpart X units which include evaporation in the TSD Building and in a laboratory hood (Reference 115). USA can currently operate Subpart X units under interim status until September 1992 (Reference 117). Modifications to the permit to include Subpart X units is being delayed until TCLP rules become effective in November, 1990 (Reference 115).

USA received a NPDES permit (No. AL-0049344) in the 1980s for discharge of east and west cooling tower blowdown through two outfalls 001, and 002 to Three-Mile Creek (Reference 116). Nine other outfalls exist on the USA campus but receive stormwater only and are therefore not monitored under the existing NPDES permit. During the 1980's, the NPDES permit monitored for zinc, chromium, residual chlorine, temperature, and pH (Reference 116). In USA's most recent permit issued on April 10, 1989, monthly monitoring is for chlorine residual, and temperature. Residual chlorine monitoring is to be performed on a daily basis during or after shock chlorination (Reference 52). According to facility personnel, a residual chlorine violation occurred but it was found that the chlorine residual resulted from the chlorination operations of the county municipal waterworks (References 104 and 105).

An Industrial Waste Survey for a Municipal Pretreatment Permit was submitted in August 25, 1983. USA supplied monitoring and analyses for Biological Oxygen Demand (BOD), Chemical Oxygen Demand (COD), Total Organic Carbon (TOC), Total Suspended Solids (TSS), pH, and phosphorus (Reference 109). According to facility personnel at the VSI, ADEM determined that USA did not need a Municipal Pretreatment Permit based on the results of the monitoring analyses which were submitted (References 104 and 105).

The University Radiation Safety and Animal Sciences Departments maintain an air permit (No. 503-9875-0001) and a Radioactive Material License No. 584. for the Pathological Incinerator (SWMU 25) (Reference 116). The Pathological Incinerator (SWMU 25) received an air permit by ADEM prior to its construction in the 1970s and includes particulate monitoring. In 1979, the Pathological Incinerator (SWMU 25) Radioactive Material License was modified under authorization of the Alabama State Board of Health to incinerate radiological material (Reference 120). Prior to that time, radioactive wastes were disposed of off-site. Under the modification, USA is required to perform Beta-Gamma surveys of the incinerator and its ash for radioactivity (Reference 120).

Pesticide application certificates issued by the State of Alabama are held by the landscape group and golf course manager (Reference 107).

E. Release History

According to facility personnel, there have been no releases to the environment of hazardous wastes and/or hazardous constituents from solid waste management units (References 104, 105, 33). All releases have been contained either within a building (i.e, laboratories, TSD Building, Former Storage areas (SWMUs 20,22)) or contained on concrete.

Two releases within the TSD Building have been documented since its inception in 1985. One occurred on April 21, 1988 when a defective container of chromic acid leaked onto the floor (References 73,75, and 76). The other release occurred in 1989, when an explosive reaction occurred when the TSD facility was flooded. Both were contained in the TSD Building (References 104 and 105).

USA had one incidence where a transformer leaked onto its concrete pad. According to facility personnel, the leak was cleaned up and the transformer was repaired. Soil samples were taken adjacent to the concrete pad to determine if a release to the soil had occurred. There were no PCBs detected in the soil (References 104 and 105).

F. Environmental and Demographic Setting

1. Location and Surrounding Land Use

The facility is located in a predominantly residential area, with some commercial areas (e.g, shopping centers) within a mile radius (Reference 29). The population in the surrounding area is predominantly students which is approximately 12,000 (undergraduate and graduates combined).

Prior to 1952, Three Mile Creek supplied water to the Mobile area (Reference 101). Due to increased urbanization in the Three Mile Creek drainage basin, the water supply was changed to draw from the Big Creek drainage basin located further west of Mobile and which drains west toward Mississippi (Reference 102). Currently, Three Mile Creek is used for fish hatcheries and for recreational usage (References 104 and 105).

Approximately 60 recorded wells are located within one mile of USA property. Wells located on USA within quandrangle 16 consist of two industrial wells owned by Bayou Concrete; three irrigation wells owned by USA, Mr. Thompson, and Harvey Mintz; one domestic well at Ridge Field Est.; and a public well owned by the Mobile County Country Club (References 95 and 96).

2. Climate and Meteorology

The University of South Alabama is located in Mobile County, Alabama. Mobile County is located in the southwestern corner of Alabama between Mississippi, the Gulf of Mexico and Mobile Bay. The climate, ranging from temperate to subtropical, is controlled by the latitude, and the Gulf of Mexico (Reference 94).

July and August are the warmest months of the year with an average daily minimum and maximum temperatures of 73 and 91 degrees Fahrenheit. Once or twice a year, the temperature may reach 99 degrees or higher. In the winter, the average daily minimum and maximum temperatures are 42 and 63 degrees Fahrenheit (Reference 94).

Most years have a rainy season and a dry season. Based on record from 1951 to 1975 period, more than one half (36 inches) of the precipitation for the average year (64

inches) occur between April 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. The windiest month is February with an average windspeed of 11 mph (Reference 94).

3. Surface Drainage and Topography

Mobile is located in the Southern Pine Hills region of the East Gulf Coastal Plain section of the Coastal Plain Physiographic province (Reference 7). This area is mainly low hills with narrow to broad gently sloping ridgetops, moderately steep slopes and many narrow well-defined drainageways. The area is drained mostly by small streams that are part of the Mobile River drainage system which flows into Mobile Bay (Reference 94).

The topography of the USA facility is characterized by well-defined stream valleys of Three Mile and Twelve Mile Creeks which drain to Mobile Bay. A 220-foot ridge divides the site in a northeasterly direction. Surface drainage consists of overland flow and by collection in USA's Stormwater Management System (SWMU 36) which carries stormwater from parking lots, buildings and other areas through underground piping and surface swales to outfalls located at Three Mile and Twelve Mile Creeks. Surface drainage on the northwestern side of the ridge drains through stormwater outfalls 001-009 and overland flow to Three Mile Creek at elevation 110 feet and through stormwater outfalls 010 and 011 and overland flow to the southeastern side of the ridge to Twelve Mile Creek at elevation 130 feet. Three Mile Creek is located on USA's property. Twelve Mile Creek is located adjacent to USA's southeast boundary (Reference 29).

According to USA's Part B permit application, USA's buildings are outside of the projected 100‑year flood plain elevation of 130 feet (Reference 67). An examination of the USGS map and campus map indicates that the SWMUs 27-31, and 33 located in the Grounds Maintenance and Vehicle Maintenance Buildings are located within the 130 foot contour interval. The TSD Building which is the location of the SWMUs 12-19 is located outside of the contour interval of 130 feet but according to facility personnel, this building flooded in 1989 during a hurricane (References 67, 104, and 105).

4. Soils and Geology

In Mobile County, stratta outcroppings in the area are capped by the sand, gravel, and lenticular white to variegated clay of the Citronelle formation of Pliocene or early Pleistocene age. The Citronelle formation is underlain unconformably by beds of fine to coarse sand and fine to coarse gravel, and lenses of clay. The estuarine Miocene deposits which extend below the bottoms of the deepest water wells, probably to a depth of 1300 to 1400 feet, consist of gray dense clay, sandy clay, fine argillaceous sand, and medium to coarse sand, with a gravelly sand about 300 feet thick at the base. Clay makes up the greater part of the Miocene deposits penetrated by water wells. The sand and clay beds are highly lenticular, and it has not been possible to make correlations of water bearing beds from one well to another. The Miocene deposits have a regional dip slightly west of south in Mobile County (Reference 100).

The Soil Survey of Mobile County indicates that the dominant soil series are the Benndale-Urban and Troup-Urban land complexes. The Benndale soils consist of 0-11 inches of sandy loam over loam, sandy loam, or fine sandy loam to a depth of 72 inches. Permeability of the Benndale soils are 0.6 to 2.0 inches per hour. The Troup soils consist of 0-69 inches of loamy sand with permeability of 6-20 inches per hour and 69-89 inches of sandy clay loam or sandy loam having permeability of 0.6 to 2.0 inches per hour. Both of these soils are nearly level to sloping (0 to 8 percent slopes) and are well drained. The Urban land part of these land complexes are unidentifiable soils due to cover by roads, buildings, parking lots and other structures (Reference 94).

The only available site-specific soil information comes from two subsurface investigations for construction of two proposed structures. Two soil borings at depths of 41.5 and 61.5 feet were taken adjacent to the Laboratory of Molecular Biology for the proposed TSD Building (Reference 7). The other investigation was for three soil borings at depths of 21.5 feet adjacent to the student union for a proposed food service/multipurpose facility (Reference 114). The soils encountered at the location of the TSD Facility for the investigated depth of 21.5 feet, consisted of two to six feet of silty sands, six to 15-feet of silty clayey sands, and 15-21.5 feet of sand with a small amount of silt. Groundwater was not encountered in these borings. The soils encountered at the food service/multipurpose facility for the investigated depths of 41.5 and 61.5 feet, consisted of 40-60 feet of sands with varying amounts of sand and clay. Water level measurements showed the water table at 38 and 57 feet below the existing ground surface. The apparent discrepancy was attributed to a perched aquifer due to the presence of a clay aquiclude in one of the borings.

5. Ground Water and Hydrogeology

In Mobile County, ground water occurs in alluvial and Miocene-Pleistocene undifferentiated aquifers. The alluvial aquifer consists of alluvial deposits of sand and coarse gravel located on top of beds comprised of sand and blue-clay-shale. The wells completed in this alluvium are generally shallow ranging from 50-150 feet and yield more than 10 gallons per minute. Where present, the alluvial aquifer is hydraulically linked to the Miocene-Pleistocene aquifer (Reference 98).

Due to the absense of a significant aquiclude separating the Miocene Series undifferentiated and the Citronelle Formation of Pliocene and Pleistocene Series, the Miocene-Pleistocene aquifer is considered one aquifer (Reference 98). The aquifer consists of sand, water bearing units between confining beds which result in nonartesian or artesian conditions. The beds of sand and gravel which make up the upper Citronelle Formation are highly permeable and supply large volumes of ground water to the streams, many of which have cut their channels entirely through the Citronelle Formation to bed themselves in clays of the underlying Miocene sediments (Reference 101). Wells completed in this unit range from 40-1100 feet deep and yield up to 700 gpm. The use of this aquifer for drinking water is sometimes limited due to high chloride and iron concentrations (Reference 98).

Two borings taken in November 1982 at the TSD Building document the water table at 38 and 57 feet below grade. The variation in adjacent water levels were attributed to the highly lenticular clay beds which are suspected to exist at this facility (References 7 and 100).

Based on information on recorded wells within the USGS quadrangle 16 which makes up much of what USA owns, water levels varied from 40-90 feet (Reference 95 and 96). Pumping rates varied from 50 to 125 gpm. All wells were withdrawing from the Miocene-Pleistocene undifferentiated aquifer (Reference 95).

This chapter presents detailed descriptions and release assessments of each Solid Waste Management Unit and Areas of Concern listed below. 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. Release potential for each SWMU is given a "L", "M", or "H" release potential for air, surface water, soil, ground water, and subsurface gas. The meaning of these designations used to identify release pathways is as follows: L = Low minimal potential for release; M = Moderate potential for release; H = High potential for release due to evidence that suggests that release(s) have occurred

SWMU

No. Description

1-11 Chemical Waste Accumulation Areas

12 TSD Building Container Storage Bays

13 TSD Building Neutralization/Treatment Tank

14 TSD Building Emergency FRP Holding Tank and Ancillary Piping

15 TSD Building Distillation Unit

16 TSD Building Bottle Crusher

17 TSD Building Vehicle Entrance and Trench Drain

18 TSD Building Waste Evaporation Area

19 TSD Building Waste Battery Storage Area

20 Former Storage Area in Room 313 of the Cancer Center/Clinical Building 34

21 Storage and Treatment Lab in Room 364, Assay/Chemistry Lab, of the Cancer Center/Clinical Science Building 34

22 Former Storage Area in the Loading Dock Area of the Basic Medical Sciences Building 6

23A-E Pathological Waste Accumulation Areas

24 Pathological Waste Cold Box

25 Pathological Incinerator

26 Ash Drum Storage Area

27 Grounds Maintenance Drummed Waste Accumulation Area

28 Vehicle Maintenance Drummed Waste Accumulation Area

29 Oil/Water Separator

30 Underground Waste Oil Storage Tank

31-32 Parts Cleaning Dip Tanks

33 Pesticide Rinsate Area

34 General Refuse Dumpsters

35 Sanitary Sewer System

36 Stormwater Management System

AOC A Underground Storage Tanks

The locations of the SWMUs 1-33 are presented in Figure III-1 on the following page. SWMUs 34-36 are units which have locations around the facility or exist as underground piping. SWMUs 12-19 which are located within USA's TSD Building are shown in Figure III-2.

Figure III-1

Location of SWMUs 1-33 on

University of South Alabama Campus Map

(Source: Reference 29)

Figure III-2

Location of SWMUs 12-19 in TSD Building

(Source: Reference 29)

SWMU DATA SHEET

Page 1 of 2

SWMU NUMBER: 1-11 PHOTO NUMBER: 3-5,3-6,3-11

NAME: Chemical Waste Accumulation Areas

TYPE OF UNIT: Waste Accumulation Areas

PERIOD OF OPERATION:

These units are located in buildings which have been used for teaching, research and health care since USA's inception in 1963. According to facility personnel, it is probable that these units began accumulating wastes when the buildings became active. The units are currently active.

PHYSICAL DESCRIPTION AND CONDITION:

The units consist of those areas inside buildings at USA which accumulate chemical wastes as shown in Table III-1. The accumulation areas consist of storage cabinets, laboratory hoods, or designated container areas within buildings where wastes are stored prior to being transported to USA's Treatment Storage Disposal (TSD) Building. The units manage containers including original manufacturer's containers, five-gallon high density polyethylene (PE) square cans with PE screw caps, five-gallon round safety cans with pressure relief and flame arresters, 55-gallon steel barrels, 33-gallon fiber board drums (for dry materials), and fiber board drums lined with PE or biohazard bags (for dry materials).

Wastes are generated and accumulated as a result of the teaching, research and health care activities performed in these buildings. At the time of the VSI, SWMUs 1,6,8, and 10 were observed. Some staining was observed at the Arts Complex Accumulation Area (SWMU 6). At the Chemistry Building Accumulation Area (SWMU 10) it was noted that a bottle within a storage cabinet there had been stored greater than 90 days.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The units are used to collect any of the hazardous wastes generated at USA which include approximately 150 different EPA Hazardous Waste Numbers. The wastes fall into several categories, including D, F, P, and U wastes. The wastes include 26 "P" and 112 "U" listings with EPA and Alabama Hazardous Waste Numbers; solvents and solvent mixtures numbered F001 to F005; wastes that exhibit the characteristics of ignitability, corrosivity, reactivity or EP Toxicity (D001 - D009 and D011); pathological wastes; and numerous unlisted, non-characteristic hazardous wastes (Reference 86). In addition, USA handles mixed wastes (specifically scintillation-fluids).

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

Ground Water ( L ) Subsurface Gas ( L )

Table III-1

LIST OF CHEMICAL WASTE ACCUMULATION AREAS (SWMUs 1-11)

SWMU Bldg.

No. No. Building Description

1 1 Administration Building

2 2 Instructional Lab

3 5 Life Science Building

4 6 Medical Science Building

5 18 University Center

6 19 Art Studio and Complex

7 22 Central Utilities

8 33 Laboratory of Molecular Biology

9 34 Cancer Clinic

10 43 Chemistry

11 45 Computer Center

SWMU DATA SHEET

Page 2 of 2

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases was observed during the RFA or identified in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 104,105

COMMENTS: None

SWMU DATA SHEET

Page 1 of 2

SWMU NUMBER: 12 PHOTO NUMBER:1-1 through 1-4,

1-14 through 1-16,

1-21 through 1-24

NAME: TSD Building Container Storage Bays

TYPE OF UNIT: Waste Storage Areas

PERIOD OF OPERATION:

The unit became active in 1985-86 when the TSD Building was completed and is currently active (References 104 and 105).

PHYSICAL DESCRIPTION AND CONDITION:

This unit consists of a RCRA permitted, 1000-gallon capacity, hazardous waste storage area located within the TSD Building. The unit receives wastes from the Chemical Waste Accumulation Areas (SWMUs 1-11) and Pathological Waste Accumulation Areas (SWMUs 23A-E). The storage area consists of four areas separated by 4-inch solid block walls to allow for separation of liquid waste classes, a cabinet for storage of solid wastes, and a room for flammables. Liquid wastes including acids, caustics, and poisons are stored on the treated lumber shelves which are separated by about four feet wide concrete block walls on three sides. Highly flammable wastes are stored in the separate room with a door. Solid wastes including oxidizers, heavy metals and wastes, not otherwise specified (N.O.S), are stored on separate shelves in the metal cabinet. Other wastes are stored on an elevated platform in the main area of the building (referred to as the "barrel storage area" for storing five-gallon containers are greater). All spills or leakage from containers is designed to flow to a central floor drain inside the main floor curbs and can be washed or flow into the TSD Building Emergency FRP Holding Tank and Ancillary Piping (SWMU 14). The TSD building, in which the unit is located, has 12-inch dikes at entrance ways for a 4500-gallon spill capacity. At the time of the VSI, the storage bays and containment features appeared in good condition.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit is permitted to handle wastes listed in the facility's Hazardous Waste Permit. The application lists approximately 150 different EPA Hazardous Waste Numbers. The wastes fall into several categories, including D, F, P, and U wastes. The wastes include 26 "P" and 112 "U" listings with EPA and Alabama Hazardous Waste Numbers; solvents and solvent mixtures numbered F001 to F005; wastes that exhibit the characteristics of ignitability, corrosivity, reactivity or EP Toxicity (D001 - D009 and D011); pathological wastes; and numerous unlisted, non-characteristic hazardous wastes

SWMU DATA SHEET

Page 2 of 2

(Reference 86). In addition, USA handles mixed wastes (specifically scintillation fluids). Containers employed for the storage of wastes include original manufacturer's containers, five-gallon high density polyethylene square (PE) cans with PE screw caps, five-gallon round safety cans with pressure relief and flame arresters, 55-gallon steel barrels, 33-gallon fiber board drums (for dry materials), fiber board drums lined with PE or biohazard bags (for dry materials).

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

Ground Water ( L ) Subsurface Gas ( L )

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases was observed during the RFA or identified in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 29,51,86,104,105

COMMENTS: None

SWMU DATA SHEET

Page 1 of 2

SWMU NUMBER: 13 PHOTO NUMBER: 1-7,1-8,1-9

NAME: TSD Building Neutralization/Treatment Tank

TYPE OF UNIT: Reaction Vessel

PERIOD OF OPERATION:

The unit became active in 1985-86 when the TSD Building was completed and is currently active (References 104 and 105).

PHYSICAL DESCRIPTION AND CONDITION:

This unit consists of a RCRA permitted, 300-gallon per hour capacity, 300-gallon, open topped, stainless steel tank located in the TSD Building. The unit measures 3 feet high, 3.8 feet in diameter, and is supported by stainless steel legs approximately six-inches off the concrete floor. The tank drain valve and piping is designed for gravity flow to the Sanitary Sewer System (SWMU 25) or to the TSD Building Emergency FRP Holding Tank and Ancillary Piping (SWMU 14). An overflow line drains to the TSD Building Emergency FRP Holding Tank. The unit can also receive wastes pumped from the TSD Building Emergency FRP Holding Tank and Ancillary Piping (SWMU 25). The unit is used to perform "Other Treatment" (T04) in accordance with USA's RCRA permit. Acids, bases, formaldehyde, and other reactions are performed to render a compound, which is otherwise hazardous, nonhazardous. The unit is within a four-inch curbed area with a floor drain which discharges to the TSD Building Emergency FRP Holding Tank and Ancillary Piping (SWMU 14). The unit's wall thickness is inspected and measured routinely for deterioration. According to facility personnel, the unit is not operated during unloading times. At the time of the VSI, the unit appeared to be in good condition. A mixer was secured to the top of the tank for mixing the wastes and additives.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

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

Ground Water ( L ) Subsurface Gas ( L )

SWMU DATA SHEET

Page 2 of 2

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases was observed during the RFA or identified in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 5,29,51,104,105

COMMENTS: Continue compliance with requirements of Hazardous Waste Permit. It should be noted that the Hazardous Waste Permit indicates that the unit is to have a hinged lid. No hinged lid was observed at the time of the VSI. Compliance with this requirement of the permit is suggested to prevent possible spills from the unit into the immediately adjacent (less than a foot away) TSD Building Vehicle Entrance and Trench Drain (SWMU 17).

SWMU DATA SHEET

Page 1 of 2

SWMU NUMBER: 14 PHOTO NUMBER: 1-11, 1-12,

1-13, 1-18

NAME: TSD Building Emergency FRP Holding Tanks and Ancillary Piping

TYPE OF UNIT: Spill Containment Tank

PERIOD OF OPERATION:

The unit became active in 1985-86 when the TSD Building was completed and is currently active (References 104 and 105).

PHYSICAL DESCRIPTION AND CONDITION:

The unit consists of a 250-gallon-fiberglass reinforced polyethylene (FRP) tank and ancillary PVC piping which is installed in a pit, constructed below the grade of the TSD Building. The unit is designed to collect all spills or leakage from drains located throughout the TSD Building and from safety showers and a safety eye wash. Drains to this unit from the building floor are always left in the open position except when the unit is discharging wastes from the TSD Building Neutralization/Treatment Tank (SWMU 13) to the Sanitary Sewer System (SWMU 25). According to facility personnel, suitable limits have been set with the ADEM water quality section, the city and the county of Mobile previously when a complete study was undertaken by the ADEM along with the local sewage treatment plant.

The tank is equipped with an air pressure driven pump which is used to pump the tank's contents to either the TSD Building Neutralization/Treatment Tank (SWMU 13) or to drums or other containers for storage. As an extra precaution, the pump is designed to pump from the tank's pit in case of spillage or tank failure. The tank is vented to the roof of the TSD Building. The tank does not require a permit because storage is for less than 90 days. An operating record is kept to indicate that no waste is stored for over 90 days. Weekly inspections for deterioration are performed on the tank, underfloor pump, and underfloor drains are required in the Hazardous Waste Permit.

At the time of the VSI, the tank and PVC piping appeared in good condition. Valves were not constructed of chemical resistant PVC material and therefore showed signs of rust and deterioration. The below grade pit in which the tank is located also appeared in good condition.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit handles any waste material spills from the TSD Building and therefore may handle any of the wastes listed in the facility's Hazardous Waste Permit. The application lists approximately 150 different EPA Hazardous Waste Numbers. The wastes fall into several categories, including D, F, P, and U wastes. The wastes include 26

SWMU DATA SHEET

Page 2 of 2

"P" and 112 "U" listings with EPA and Alabama Hazardous Waste Numbers; solvents and solvent mixtures numbered F001 to F005; wastes that exhibit the characteristics of ignitability, corrosivity, reactivity or EP Toxicity (D001 - D009 and D011); pathological wastes; and numerous unlisted, non-characteristic hazardous wastes (Reference 86). In addition, USA handles mixed wastes (specifically scintillation fluids).

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

Ground Water ( L ) Subsurface Gas ( L )

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases was observed during the RFA or identified in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 5,24,29,51,104,105

COMMENTS: Suggest replacement of existing valving due to evidence of excessive rust and deterioration with corrosive and chemical resistant valves to meet requirements of Hazardous Waste Permit.

SWMU DATA SHEET

Page 1 of 1

SWMU NUMBER: 15 PHOTO NUMBER: No Photograph

NAME: TSD Building Distillation Unit

TYPE OF UNIT: Waste Treatment Unit

PERIOD OF OPERATION:

The unit became active in 1985-86 when the TSD Building was completed and is currently active (References 104 and 105).

PHYSICAL DESCRIPTION AND CONDITION:

The unit consists of a heating chamber, a water‑cooled condenser, and a vapor vent to the exterior of the building. Use of this unit for scintillation solvents was discontinued in September 1989 when the use of recycled solvents for the Pathological Incinerator (SWMU 25) was discontinued.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit has managed solvents including scintillation fluids, and xylene.

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

Ground Water ( L ) Subsurface Gas ( L )

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases was observed during the RFA or identified in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 104,105,116

COMMENTS: None

SWMU DATA SHEET

Page 1 of 1

SWMU NUMBER: 16 PHOTO NUMBER: 1-19

NAME: TSD Building Bottle Crusher

TYPE OF UNIT: Waste Treatment Unit

PERIOD OF OPERATION:

The unit became active in 1985-86 when the TSD Building was completed and is currently active (References 104 and 105).

PHYSICAL DESCRIPTION AND CONDITION:

The unit consists of an explosion proof bottle crusher unit which fits on a 55-gallon barrel mount. The crusher unit must be placed in position by a crane. One-gallon glass jugs are placed in the unit and crushed. The glass remains on a grate while the fluid drains to the drum. The glass is allowed to dry and is disposed in a General Refuse Dumpster (SWMU 34). Prior to September 1989, the unit was used to crush scintillation vials. The scintillation fluids were then transferred to either the TSD Building Distillation Unit (SWMU 15), the Pathological Incinerator (SWMU 25), or for storage at the TSD Building Storage Bays (SWMU 12). Currently, the unit is used for crushing bottles.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit has managed scintillation fluids, toluene, and xylene.

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

Ground Water ( L ) Subsurface Gas ( L )

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases was observed during the RFA or identified in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 5,104,105

COMMENTS: None

SWMU DATA SHEET

Page 1 of 1

SWMU NUMBER: 17 PHOTO NUMBER: 1-6,1-17

NAME: TSD Building Vehicle Entrance and Trench Drain

TYPE OF UNIT: Vehicle Entrance and Stormwater Trench Drain

PERIOD OF OPERATION:

The unit became active in 1985-86 when the TSD Building was completed and is currently active (References 104 and 105).

PHYSICAL DESCRIPTION AND CONDITION:

The unit consists of an approximately five-foot by 30-foot concrete loading entry way and an approximately nine-inch by 25 foot trench drain system. The trench drain is routed to a grassy "low area". The trench drain is intended to remove excess stormwater and avoid run-on. The trench drain is located approximately six inches away from the TSD Building Neutralization/Treatment Tank (SWMU 13) when the garage door is open. According to facility personnel, the unit is used only as an entryway. Unloading or loading of transport vehicles is not permitted in the entryway but are to occur inside the facility.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit manages stormwater runoff from the entryway ramp, approximately a six-inch by 25-foot area.

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

Ground Water ( H ) Subsurface Gas ( L )

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases was observed during the RFA or identified in the available file material.

RECOMMENDATION: No Further Action ( )

RFA Phase II Sampling ( X )

RFI Necessary ( )

REFERENCES: 24,104,105,107

COMMENTS: Due to observations at the time of the VSI, that the TSD Building Neutralization/Treatment Tank has no lid to prevent splashing during the mixer's operation and the close proximity to the trench drain, RCRA Phase II sampling is suggested at the trench drain discharge. If the results of sampling indicate that the operation of this unit in close proximity to the trench drain system is causing releases of hazardous wastes or hazardous constituents, redesign of this unit is recommended.

SWMU DATA SHEET

Page 1 of 1

SWMU NUMBER: 18 PHOTO NUMBER: 1-10

NAME: TSD Building Waste Evaporation Area

TYPE OF UNIT: Outdoor Interim Status Subpart X Unit

PERIOD OF OPERATION:

The unit became active in 1985-86 when the TSD Building was completed and is currently active (References 104 and 105).

PHYSICAL DESCRIPTION AND CONDITION:

The unit consists of a seven-foot four-inch by seven-foot waste explosive holding area constructed of eight-inch thick concrete walls on two sides. The area does not have a roof to prevent rainwater from entering the area. An access doorway is built into one of the two eight-inch thick concrete walls. The unit is used for evaporation of volatile waste materials. The area is curbed with approximately one foot high dikes and has a floor drain which discharges accumulated rainwater or spills to the TSD Building Emergency FRP Holding Tank (SWMU 14). The unit is currently under Subpart X interim status and is awaiting permit approval by ADEM.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit manages volatile wastes including freon, and explosives (e.g., neopentane).

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

Ground Water ( L ) Subsurface Gas ( L )

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases were observed during the VSI or identified in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 104,105,115

COMMENTS: None

SWMU DATA SHEET

Page 1 of 1

SWMU NUMBER: 19 PHOTO NUMBER: 1-25

NAME: TSD Building Waste Battery Storage Area

TYPE OF UNIT: Indoor Storage Area

PERIOD OF OPERATION:

The unit became active in 1985-86 when the TSD Building was completed and is currently active (References 104 and 105).

PHYSICAL DESCRIPTION AND CONDITION:

The unit consists of an approximate four-foot square area located indoors in the waste analysis area of the TSD Building. The unit manages spent batteries. The current inventory resulted from a battery replacement program which was instituted on April 25, 1990. The facility will ultimately ship the material off-site for disposal.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit manages spent nickel-cadmium, and mercury batteries.

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

Ground Water ( L ) Subsurface Gas ( L )

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases was observed during the RFA or identified in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 104,105,119

COMMENTS: None

SWMU DATA SHEET

Page 1 of 1

SWMU NUMBER: 20 PHOTO NUMBER: 2-35

NAME: Former Storage Area in Room 313 of the Cancer Center/Clinical Building 34

TYPE OF UNIT: Former Storage Area

PERIOD OF OPERATION:

The unit became active in approximately 1979 until 1985-86 when the TSD Building was completed (References 104 and 105). Certification of RCRA closure for this unit was received in July 17, 1987.

PHYSICAL DESCRIPTION AND CONDITION:

The unit consists of a room located in the Cancer Center/Clinical Building 34 which was formerly used for storage of waste materials from Chemical Waste Accumulation Areas (SWMUs 1-11) prior to the completion of the TSD Building in 1985-86. The room consisted of a fire cabinet in a utility chase which was used to store waste materials including mercury, explosives, and picric acid. Currently, the unit is a Chemical Accumulation Area (SWMU 9).

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit received wastes from the University, Brookley, and Hospital Campuses. The Springs Hill Campus had not been purchased during this unit's use. The unit has managed hazardous waste materials including mercury, explosives, picric acid, and shock-sensitive chemicals (e.g., ethers).

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

Ground Water ( L ) Subsurface Gas ( L )

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases was observed during the RFA or identified in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 66,67,104,105

COMMENTS: None

SWMU DATA SHEET

Page 1 of 2

SWMU NUMBER: 21 PHOTO NUMBER: 2-32,2-33,2-34

NAME: Storage and Treatment Lab in Room 364, Assay/Chemistry Lab, of the Cancer Center/Clinical Science Building 34

TYPE OF UNIT: Bench-Scale Laboratory Treatment Area

PERIOD OF OPERATION:

The unit became active in approximately 1979 and is currently active (References 104 and 105).

PHYSICAL DESCRIPTION AND CONDITION:

The unit consists of a room located in the Cancer Center/Clinical Building 34 which is used for storage and bench-scale laboratory treatment of waste materials from Chemical Waste Accumulation Areas (SWMUs 1-11). Storage in the room consists of an approximately 6-foot square storage area and storage refrigerator. Treatment (T04) is performed on waste materials in this room to render them either less hazardous or nonhazardous. At the time of the VSI, nitrosoguanidine, thiophosgene, mercury, alumin T-butoxide, potassium tertiary butoxide, potassium tertiary butyl alidolite were stored. Currently, the unit is now a Chemical Accumulation Area (SWMU 9).

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

Containers employed for the storage of wastes include original manufacturer's containers, five-gallon high density polyethylene (PE) square cans with PE screw caps, five-gallon round safety cans with pressure relief and flame arresters, 55-gallon steel barrels, 33-gallon fiber board drums (for dry materials), fiber board drums lined with PE or biohazard bags (for dry materials).

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

Ground Water ( L ) Subsurface Gas ( L )

SWMU DATA SHEET

Page 2 of 2

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases was observed during the RFA or identified in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 104,105

COMMENTS: None

SWMU DATA SHEET

Page 1 of 1

SWMU NUMBER: 22 PHOTO NUMBER: 2-16,2-18

NAME: Former Storage Area in the Loading Dock Area of the Basic Medical Science Building 6

TYPE OF UNIT: Former Storage Area

PERIOD OF OPERATION:

The unit became active in approximately 1979 until 1985-86 when the TSD Building was completed (References 104 and 105). Certification of RCRA closure for this unit was received in July 17, 1987.

PHYSICAL DESCRIPTION AND CONDITION:

The unit consists of a 10-foot by 12-foot concrete pad secured by an approximately eight-foot high fence located in the loading dock area of the Basic Science Building 6. The unit was formerly used for storage of hazardous waste materials from Chemical Waste Accumulation Areas (SWMUs 1-11) prior to the completion of the TSD Building in 1985-86. Hazardous wastes were formerly stored in three cabinets for chlorinated, corrosives, flammables, and acids. The unit currently only stores radioactive waste containers.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit received wastes from the University, Brookley, and Hospital Campuses. The Springs Hill Campus had not been purchased during this unit's use. The unit has managed hazardous wastes including chlorinated, corrosives, flammables, and acids.

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

Ground Water ( L ) Subsurface Gas ( L )

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases was observed during the RFA or identified in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 104,105

COMMENTS: None

SWMU DATA SHEET

Page 1 of 2

SWMU NUMBER: 23 PHOTO NUMBER: 2-19,2-25

NAME: Pathological Waste Accumulation Areas

TYPE OF UNIT: Accumulation Area

PERIOD OF OPERATION:

PHYSICAL DESCRIPTION AND CONDITION:

The units consist of those areas associated with specific buildings at USA which accumulate pathological wastes in rooms and loading platforms, as shown in Table III-2. Pathological wastes are generated and accumulated as a result of teaching, research and health care activities performed in these buildings. The generators are responsible for initial identification and segregation of pathological wastes from other waste streams, use of proper containers and proper packaging and labeling of containers designed for pathological wastes. Pathological wastes are treated by incineration at the Pathological Incinerator (SWMU 25) or picked up by Browning Ferris Industries (BFI) for off-site disposal. Occasionally, pathological wastes are temporarily stored at the Pathological Waste Cold Box (SWMU 24).

Containers employed for the storage of pathological wastes include plastic bags marked with the pathological warning symbol, five-gallon high density red pails, and 30-gallon red trash cans with lids. Those containers to be picked up by BFI are marked with BFI labels accordingly.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The units manage pathological wastes. Examples of pathological wastes are: potentially contaminated animal bedding, animal carcasses, clinical specimens, anatomic wastes, surgical and autopsy wastes, disposable clothing, towels, sorbent liners, etc., potentially contaminated with anti-neoplastic drugs, syringes, needles and other sharps, and semi-solid media containing toxic or carcinogenic material.

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

Ground Water ( L ) Subsurface Gas ( L )

Table III-2

LIST OF PATHOLOGICAL WASTE ACCUMULATION AREAS (SWMUs 23A-23E)

SWMU Bldg.

No. No. Building Description

23A 5 Life Sciences Building

23B 6 Medical Sciences Building

23C 33 Lab of Molecular Biology

23D 34 Cancer Clinic

23E 41 Health Services Lab

SWMU DATA SHEET

Page 2 of 2

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases was observed during the RFA or identified in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 104,105

COMMENTS: None

SWMU DATA SHEET

Page 1 of 2

SWMU NUMBER: 24 PHOTO NUMBER: 2-24

NAME: Pathological Waste Cold Box

TYPE OF UNIT: Pathological Waste Storage Unit

PERIOD OF OPERATION:

Date of startup was not available. The unit is currently active.

PHYSICAL DESCRIPTION AND CONDITION:

The unit is a prefabricated refrigerated unit used for temporary storage of pathological wastes. The pathological wastes have been sealed in plastic bags and then packaged in cardboard boxes with the pathological waste warning labels. The unit is used for temporary storage from the Pathological Accumulation Areas (SWMUs 23 A-E) prior to transfer to the Pathological Incinerator (SWMU 25). The unit is self-contained and located inside a building. At the time of the VSI, pathological wastes were contained in plastic bags contained in plastic roll carts inside the unit.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

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

Ground Water ( L ) Subsurface Gas ( L )

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases was observed during the RFA or identified in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

SWMU DATA SHEET

Page 2 of 2

REFERENCES: 104,105

COMMENTS: None

SWMU DATA SHEET

Page 1 of 2

SWMU NUMBER: 25 PHOTO NUMBER: 1-36,2-1,

2-2,2-3,2-5

NAME: Pathological Incinerator

TYPE OF UNIT: Incinerator

PERIOD OF OPERATION:

The unit was installed in October 1977 and is currently active (References 104 and 105).

PHYSICAL DESCRIPTION AND CONDITION:

The unit is an incinerator and supporting ancillary equipment. The unit incinerates wastes received from Pathological Accumulation Areas (SWMUs 1-11), USA's TSD Building, and from the Radiation Safety Department. The unit consists of a primary ignition chamber and a secondary combustion chamber. The combustion chamber is direct fed and cylindrical in shape. The ash is manually removed by maintenance personnel once a week and drummed for storage at the Ash Drum Storage Area (SWMU 26).

The unit is an Ecology Enterprises, Inc. Model No. 750 incinerator. Warranty information provided by Ecology Enterprises rates the unit's destruction capacity of Type 4 pathological waste at 625 pounds per hour. In addition, the incinerator is capable of burning to a sterile ash, waste types 0,1,2,3, and 4 as classified by the Incinerator Institute of America. Primary waste is Type 4 pathological Medical School animal remains consisting primarily of dogs, cats, rabbits, rats, etc., and occasionally whole carcass remains such as calves or pigs weighing up to 500 pounds each. Types 0,1,2, and 3 consists of primarily of Medical School trash, rubbish, and refuse such as, but not limited to pound bedding and laboratory wastes consisting of cornhusks, corn cobs, paper, plastic bags, soiled surgical dressings, petri dishes, garbage, floor sweepings, vegetable wastes, and other common Medical School type wastes.

Waste air emissions are regulated by an Alabama Board of Health Permit. Inspections are performed to limit visible emissions.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit currently treats pathological, mixed, and radioactive wastes. Prior to 1979, the unit only treated pathological wastes. In 1979, USA's NRC Materials License (19-00296-10) was modified to include incineration of radioactive materials.

Examples of pathological wastes are: potentially contaminated animal bedding, animal carcasses, clinical specimens, anatomic wastes, surgical and autopsy wastes, disposable clothing, towels, sorbent

SWMU DATA SHEET

Page 2 of 2

liners, etc., potentially contaminated with anti-neoplastic drugs, syringes, needles and other sharps, and semi-solid media containing toxic or carcinogenic material. Currently, approximately two tons per year of pathological wastes is incinerated.

Mixed wastes include those containing isotopes, other than Carbon-14 or Tritium or having radioactive concentrations above the 0.05 microcurie per milliliter concentration level, or containing pathological agents are incinerated. Currently, approximately 24-36 gallons per year of mixed waste and approximately 40 cubic feet or 8.3 microcuries per year of radiological wastes are incinerated in this unit.

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

Ground Water ( L ) Subsurface Gas ( L )

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases were observed at the time of the VSI or identified in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 104,105,107,120

COMMENTS: Continue compliance with the Alabama Board of Health Permit.

SWMU DATA SHEET

Page 1 of 2

SWMU NUMBER: 26 PHOTO NUMBER: 1-34,1-35,

1-37,2-4

NAME: Ash Drum Accumulation Area

TYPE OF UNIT: Waste Accumulation Area

PERIOD OF OPERATION:

The unit became active when the pathological incinerator (SWMU 25) was installed in October 1977 and is currently active (References 104 and 105).

PHYSICAL DESCRIPTION AND CONDITION:

This unit consists of a storage area approximately 40 feet by 15 feet located adjacent to the Central Utilities Building. The unit is used for the storage of drummed ash, removed from the Pathological Incinerator (SWMU 25), until pickup and disposal to the county landfill with normal refuse and garbage. The drums are scanned for radioactivity in accordance with the USA's NRC Material License prior to landfill disposal. According to the USA's NRC Material License, incinerator ash residues may be disposed of as ordinary waste provided appropriate surveys are made to determine that concentrations of licensed material appearing in the ash residues do not exceed the concentrations (in terms of microcuries per gram). At the time of the VSI, twenty-nine 55-gallon drums with lids were placed directly on the ground. The drums were observed to be rusted during the VSI. One drum with its lid on was observed on its side. None of its contents had spilled onto the ground.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit manages drummed incinerator ash, ash residues, and radioactivity residues. According to facility personnel, the ash material has exceeded maximum microcuries per gram levels at times due to high concentrations of Carbon-14 found in carcass bones. The ash from the unit was analyzed for silver, lead, cadmium, and chromium and found to contain these constituents. The concentrations of these metals were below regulatory limits of 5 ppm for silver, lead, and chromium and 1 ppm for cadmium (Reference 32).

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

Ground Water ( M ) Subsurface Gas ( L )

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases was observed during the RFA or identified in the available file material.

SWMU DATA SHEET

Page 2 of 2

RECOMMENDATION: No Further Action ( )

RFA Phase II Sampling ( X )

RFI Necessary ( )

REFERENCES: 104,105

COMMENTS: Suggest inside storage of incinerator ash to prevent runoff of ash residues.

SWMU DATA SHEET

Page 1 of 1

SWMU NUMBER: 27 PHOTO NUMBER: 3-2,3-4

NAME: Grounds Maintenance Drummed Waste Oil Accumulation Area

TYPE OF UNIT: Waste Accumulation Area

PERIOD OF OPERATION:

The date of startup for this unit is approximately 1986. The unit is currently active (References 104 and 105).

PHYSICAL DESCRIPTION AND CONDITION:

The unit is a three-foot by two-foot accumulation area for 55-gallon steel drums containing waste oils. The drums are stored on a concrete surface just outside the Grounds Maintenance Building. When the drums become full, the waste oil is transferred to the Underground Waste Oil Storage Tank (SWMU 30). Waste oil is generated from oil changing operations of lawn mowers and tractors. At the time of the VSI, two 55-gallon waste drums were stored at this unit. The drums are stored on a concrete surface.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit manages waste oils from motor vehicles which may contain hazardous constituents of petroleum, hydrocarbons, and heavy metals.

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

Ground Water ( L ) Subsurface Gas ( L )

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases was reported during the RFA or identified in the available file material. During the VSI, minor staining was observed on the concrete surface. No evidence of releases to surrounding soils was noted.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 104,105

COMMENTS: None

SWMU DATA SHEET

Page 1 of 1

SWMU NUMBER: 28 PHOTO NUMBER: 2-7

NAME: Vehicle Maintenance Drummed Mineral Spirits Waste Accumulation Area

TYPE OF UNIT: Waste Accumulation Area

PERIOD OF OPERATION:

The date of startup for this unit is approximately 1986. The unit is currently active (References 104 and 105).

PHYSICAL DESCRIPTION AND CONDITION:

The unit is a three-foot by six-foot accumulation area for 55-gallon steel drums containing waste mineral spirits. The drums are stored on a concrete surface just outside of the Vehicle Maintenance Building. The waste mineral spirits poured into the drums are reclaimed after a period of time when settlement of solids occurs. The sludge is collected periodically as a waste and transferred to the TSD Building. Mineral spirits are generated from vehicle maintenance and paint shop operations. At the time of the VSI, four 55-gallon waste drums were stored at this unit. The drums are stored on a concrete surface.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit manages waste mineral spirits which may contain hazardous constituents of petroleum hydrocarbons and heavy metals.

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

Ground Water ( L ) Subsurface Gas ( L )

HISTORY AND/OR EVIDENCE OF RELEASE(s):

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 104,105

COMMENTS: None

SWMU DATA SHEET

Page 1 of 1

SWMU NUMBER: 29 PHOTO NUMBER: 2-9,2-10,

2-11,3-1

NAME: Oil/Water Separator and Ancillary Drainage Trench

TYPE OF UNIT: Runoff Oil Collection Unit

PERIOD OF OPERATION:

The date of startup for this unit is approximately 1982. The unit is currently active (References 104 and 105).

PHYSICAL DESCRIPTION AND CONDITION:

The unit consists of an oil/water separator and ancillary drainage trench. The oil/water separator is located outside and adjacent to the Vehicle Maintenance Shop and is approximately six-feet by four-feet by ten-feet. The trench drain is located inside and along the length of the building and is approximately 12 inches wide by 50 feet long by eight inches deep. The waste oil is reportedly removed every seven months with pails and transferred to the Underground Waste Oil Storage Tank (SWMU 30). At the time of the VSI, the oil/water separator appeared in need of maintenance and was missing an underflow gate.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit manages waste oils which may contain hazardous constituents of petroleum hydrocarbons and heavy metals.

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

Ground Water ( * ) Subsurface Gas ( L )

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases was reported during the RFA or identified in the available file material.

RECOMMENDATION: No Further Action ( ** )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 104,105

COMMENTS: * The potential for release to soil and ground water is dependent on the integrity of the unit.

** Integrity testing is suggested.

SWMU DATA SHEET

Page 1 of 1

SWMU NUMBER: 30 PHOTO NUMBER: 2-8

NAME: Underground Waste Oil Storage Tank

TYPE OF UNIT: Underground Tank

PERIOD OF OPERATION:

The date of startup for this unit is December 1982. The unit is currently active (References 104 and 105).

PHYSICAL DESCRIPTION AND CONDITION:

The unit consists of an underground 550-gallon waste oil storage tank located outside of the Vehicle Maintenance Shop. The tank is steel with bituminous coating, strapped to a concrete pad and set in a bed of clean sand and backfilled. The unit is covered over by a concrete surface. A fill and emptying pipe marks the unit's location on the concrete surface. The unit is used for collection of waste oils from vehicles, mowers, and tractors. At the time of the VSI, minor staining was noted adjacent to the fill and emptying pipe on the concrete. The tank's contents are picked up by a private recycling contractor every 24 months.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit manages waste oils from vehicle and grounds maintenance operations which may contain hazardous constituents of petroleum hydrocarbons and heavy metals.

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

Ground Water ( * ) Subsurface Gas ( L )

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases was reported during the RFA or identified in the available file material.

RECOMMENDATION: No Further Action ( ** )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 104,105

COMMENTS: * The potential for release to soil and ground water is dependent on the integrity of the unit.

** Integrity testing is suggested.

SWMU DATA SHEET

Page 1 of 1

SWMU NUMBERs: 31-32 PHOTO NUMBER: 2-6

NAME: Parts Cleaning Dip Tanks

TYPE OF UNIT: Parts Washer

PERIOD OF OPERATION:

The date of startup for the units is approximately 1982. The units are currently active (References 104 and 105).

PHYSICAL DESCRIPTION AND CONDITION:

The units consist of parts cleaning dip tanks with lids consisting of a wash sink and solvent collection drum. Solvents are recycled from the drum to the wash sink. The sludge from the drum is removed approximately one to two years and transferred to the TSD Building for off-site disposal. The units are located on concrete surfaces inside the Central Utilities, and Maintenance Buildings.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit manages waste mineral spirits which may contain hazardous constituents of petroleum hydrocarbons and heavy metals.

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

Ground Water (L) Subsurface Gas (L)

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases was reported during the RFA or identified in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 104,105

COMMENTS: None

SWMU DATA SHEET

Page 1 of 1

SWMU NUMBER: 33 PHOTO NUMBER: 2-13,2-14

NAME: Pesticide Rinsate Area

TYPE OF UNIT: Open Disposal Area

PERIOD OF OPERATION:

The date of startup for this unit is approximately 1986. The unit is currently active (References 104 and 105).

PHYSICAL DESCRIPTION AND CONDITION:

The unit consists of an approximately 10-foot by 10-foot open grassy area immediately adjacent to the Grounds Maintenance Building. The unit was used as an area where pesticides and herbicides were rinsed out from containers. At the time of the VSI, it was noted that the unit lacked vegetation and had spots of bare soil. Facility personnel indicated that the lack of vegetation could be due to steam cleaning that takes place at the area.

It was reported by facility personnel at the VSI, that Grounds Maintenance was previously between the Chemistry and Central Utilities buildings and possible other locations. Some pesticides were stored in a blue warehouse. Information regarding operations at these locations was not available due to turnover in staff.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit has managed pesticides and herbicides. Appendix C lists an inventory of pesticide usage at the University of South Alabama.

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

Ground Water ( H ) Subsurface Gas ( L )

HISTORY AND/OR EVIDENCE OF RELEASE(s):

Releases were reported to occur directly to the ground.

RECOMMENDATION: No Further Action ( )

RFA Phase II Sampling ( X )

RFI Necessary ( )

REFERENCES: 104,105

COMMENTS: None

SWMU DATA SHEET

Page 1 of 1

SWMU NUMBER: 34 PHOTO NUMBER: 1-27

NAME: General Refuse Dumpsters

TYPE OF UNIT: Dumpsters

PERIOD OF OPERATION:

The startup dates are unknown. The dumpsters are currently active.

PHYSICAL DESCRIPTION AND CONDITION:

The dumpsters are located as needed throughout the facility. The metal dumpsters manage general solid waste (trash) which is generated from USA activities. The dumpsters are located in loading areas on concrete or soil surfaces accessible to hauling trucks. The one dumpster, observed appeared to be in good condition at the time of the VSI. The unit is a steel box with lid located in the northwest side of the Laboratory of Molecular Biology, Building 32. The unit has a capacity of approximately 40 cubic yards and was placed on the ground. The unit is emptied routinely and taken to the city municipal landfill.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit reportedly manages general domestic refuse from the University of South Alabama. During the VSI, autoclaved animal bedding in plastic bags 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 evidence of releases was observed during the RFA or identified in the available file material.

RECOMMENDATION: No Further Action ( X )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 104,105

COMMENTS: None

SWMU DATA SHEET

Page 1 of 2

SWMU NUMBER: 35 PHOTO NUMBER: 1-26,2-21

NAME: Sanitary Sewer System

TYPE OF UNIT: Sanitary Sewer System

PERIOD OF OPERATION:

The unit has managed sanitary sewage and process wastes since 1963 to the present date.

PHYSICAL DESCRIPTION AND CONDITION:

The unit is located throughout the facility as underground piping which conveys sanitary sewage and process wastes. The system flows to the Mobile County Sewage Treatment Plant. The location of the main sewer lines on USA's campus are given as Figure III-3. A 20-inch intercepting sewer enters the campus from the Hillsdale Area and exits along University Boulevard.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

Since the inception of USA in 1963, the unit has managed sanitary wastes and process waters. Based on a 1983 survey, process waters from non-contact cooling water and from washing of lab glassware, hoods, and the like constitute approximately 3% of the total wastewaters managed by the system. Starting in the 1970s, spent low level radioactive wastes were disposed to this unit from Radiation Safety Facilities. The system receives photographic waste chemicals (i.e, Kodak E6 Color, Dektal, Kodalift, Kodak Ektaprint 2, Anitec) which may contain silver (D011), including waste fixer chemicals (D003). Detergents along with other residues were received from the animal cage washer systems.

An Industrial Waste Survey for a Municipal Pretreatment Permit was performed in 1985. Approximately seven manhole locations were selected for monitoring for Biochemical Oxygen Demand (BOD), Chemical Oxygen Demand (COD), Total Organic Carbon (TOC), Total Suspended Solids (TSS), pH, and phosphorus. Manhole locations (shown in Figure V-2) were selected from lines immediately downstream from buildings in which laboratory work was conducted. Based on the constituents monitored, it was determined that USA did not need a Municipal Pretreatment Permit.

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

Ground Water ( * ) Subsurface Gas ( * )

Figure III-3

Locations of Main Sewer Lines on USA's Campus

and Manhole Locations under Municipal Pretreatment Monitoring

(Source: Reference 109)

SWMU DATA SHEET

Page 2 of 2

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases were identified in the available file material. Because the unit is below grade, the integrity of the unit could not be verified during the VSI.

RECOMMENDATION: No Further Action ( ** )

RFA Phase II Sampling ( )

RFI Necessary ( )

REFERENCES: 104,105,109

COMMENTS: * The potential for release to soil, ground water, and of subsurface gas is dependent on the integrity of the unit.

** Integrity testing is suggested.

SWMU DATA SHEET

Page _1_ of _2_

SWMU NUMBER: 36 PHOTO NUMBER: 3-7,3-8,3-9

NAME: Stormwater Management System

TYPE OF UNIT: Stormwater Management Unit

PERIOD OF OPERATION:

The unit has managed stormwater and process wastes since 1963 to the present date.

PHYSICAL DESCRIPTION AND CONDITION:

The unit consists of open ditches, lined waterways, stormwater grates and underground stormwater piping which discharge stormwater runoff to Three Mile and Twelve Mile Creeks. There are eleven outfalls numbered 001 through 011 which discharge stormwater runoff from the campus. Outfalls numbered 001 through 009 discharge to Three Mile Creek. Outfalls 010 and 011 discharge to Twelve Mile Creek. Outfalls 001 and 002 discharge stormwater and process water from the east and west cooling tower blowdown under a NPDES permit. Outfall 005 contains a small man-made pond from which stormwater overflow is discharged. The remaining outfalls discharge stormwater runoff from campus buildings, parking lots, and other areas within their subcatchments. At the time of the VSI, outfalls 001, 002, and 005 were observed. Outfalls 001, and 002 were observed to be heavily vegetated and discharging to a low wetland area in Three Mile Creek. Fish were observed in the pond which discharges to Outfall 005.

WASTES AND/OR HAZARDOUS CONSTITUENTS MANAGED:

The unit manages stormwater runoff, sediments, and may contain hazardous constituents from runoff from the facility.

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

Ground Water (*) Subsurface Gas (L)

HISTORY AND/OR EVIDENCE OF RELEASE(s):

No evidence of releases was observed or identified from the available file material.

RECOMMENDATION: No Further Action ( )

RFA Phase II Sampling (** )

RFI Necessary ( )

REFERENCES: 104,105,110

SWMU DATA SHEET

Page 2 of 2

COMMENTS: * The potential for release to soil and ground water is dependent on the integrity of the unit.

** Integrity testing is suggested.

AOC DATA SHEET

AOC LETTER: A

NAME: Underground Storage Tanks

PHYSICAL DESCRIPTION AND CONDITION:

The AOC consists of product underground storage tanks (USTs) located throughout the facility. The tanks are constructed of Schedule 40 black iron with an outside bituminous coating. All tanks were set in a bed of clean sand and strapped to a concrete pad. The tanks are located at various locations on the campus and manage gasoline and diesel fuels used in the operations at the facility. The size, capacity, location, and age of the tanks is provided as Table III-3. It is not known whether tank integrity tests have been performed. This AOC has been included in this report because of the tank age (up to 19 years old). It is possible that some of the steel tanks may be corroded. According to facility personnel, two of the tanks listed as being located at the Old Maintenance Yard were removed approximately two years ago. The oldest tank (listed as 16 years old under Dec. 1984 condition) located at the Library has also been removed. No documented releases from the USTs were found in the available file material or reported by facility representatives during the VSI.

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

Ground Water ( * ) Subsurface Gas ( L )

REFERENCE: 104,105,110

PHOTOGRAPHS: 1-33, 2-12

COMMENTS: * The potential for release to soil and ground water is dependent on the integrity of the unit. Integrity testing is suggested for all tanks greater than 10 years old

Table III-3

Inventory of Storage Tanks on USA (Main Campus)

(Reference 110)

VI. REFERENCES

1. Part A permit application, University of South Alabama, November 19, 1980.

2. Letter from William Pipas, University of South Alabama Executive Director of Development, to EPA Region IV RCRA Activities, Re: Forwarding of Facility Drawing required under V. of Part A permit application, November 19, 1980.

3. Memorandum from Bernard E. Cox Jr., State of Alabama Dept. of Public Health, to Files, Re: Need for Consolidation of College of Medicine and University RCRA Activities, July 14, 1981.

4. Letter from Bernard E. Cox, Jr. Chief, ADEM Industrial and Hazardous Waste Section, to Dr. James Vacik, College of Medicine and William Pipas, University of South Alabama Executive Director of Development, Re: Need to Consolidate College of Medicine into University Part A permit application, February 3, 1982.

5. Letter from Dr. James Vacik, University Director of Environmental Safety, to Mike Smith, ADEM Division of Solid and Hazardous Waste, Re: Amendment to Interim Status Part A, September 24, 1982.

6. Letter from Bernard E. Cox, Jr. Chief, ADEM Industrial and Hazardous Waste Section, to Dr. James Vacik, University Director of Environmental Safety, Re: Suggestion to Pursue a Part B Permit Application, October 19, 1982.

7. Letter from Arthur L. Radcliffe and William H. Brenner of Southern Earth Sciences, Inc. to Mr. William Pipas, University of South Alabama Executive Director of Development, Re: Report of Subsurface Investigation for Potential Radioactive Waste Disposal Site, November 4, 1982.

8. Letter from Thomas W. Devine, Director Air and Waste Management Division, USEPA, to Mr. W.S. Pipas, University of South Alabama Executive Director of Development, Re: Compliance Order and Consent Agreement, January 31, 1983.

9. Letter from Dr. James Vacik, Director of Environmental Safety, to Ms. Beverly Spagg, USEPA - Region IV, Re: Part A Amendment, March 22, 1983.

10. Letter from Thomas W. Devine, Director Air and Waste Management Division, USEPA, to Mr. W.S. Pipas, University of South Alabama Executive Director of Development, Re: Compliance Order and Consent Agreement, June 2, 1983.

11. Letter from Dr. James Vacik, Director of Environmental Safety, to Ms. Beverly Spagg, USEPA - Region IV, Re: Part A Amendment, September 29, 1983.

12. Specifications for Solid Waste Incinerator & Heat Recovery System for the University of South Alabama Medical Center, Associated Engineering Company, January 1984.

13. Letter from Harold W. Taylor, Jr., ADEM - Industrial and Hazardous Waste Section, to Dr. James Vacik, Director of Environmental Safety, Re: Application of Federal and State Regulations to University of South Alabama, March 1, 1984.

14. Letter from Harold W. Taylor, Jr., ADEM - Industrial and Hazardous Waste Section, to Mr. James H. Scarbrough, USEPA Region IV Chief Residuals Management, Re: Submittal of Part B permit application to USEPA, March 1, 1984.

15. Letter from James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, to William Pipas, University of South Alabama Executive Director of Development, Re: Review of RCRA Part B Permit Application Submitted December 1983, March 16, 1984.

16. Record of Communication from Daniel Cooper, ADEM, to John Harvanek, USEPA Region IV, Re: Conference call regarding University of South Alabama options presented by Consultant, Betz, Converse and Murdock, April 3, 1984.

17. Letter from Dr. James Vacik, Director of Environmental Safety, to James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, Re: Request for Extension for Response to NOD of March 16, 1984.

18. Letter from James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, to Mr. William Pipas, University of South Alabama Executive Director of Development, Re: Clarification of Regulatory Interpretation, April 19, 1984.

19. Letter from Beverly Spagg, USEPA Region IV, to Mr. Jeter, Re: Status of University of South Alabama Part B Permit Application, April 26, 1984.

20. Letter from James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, to Mr. William Pipas, University of South Alabama Executive Director of Development, Re: Followup to April 30, 1984 Meeting, May 4, 1984.

21. Part A Permit Application, University of South Alabama Medical Center, May 21, 1984.

22. Letter from James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, to Mr. William Pipas, University of South Alabama Executive Director of Development, Re: Review of Revision 1 of RCRA Part B Permit Application, July 18, 1984.

23. Letter from Doyle M. Dillard, University of South Alabama Vice President, Finance and Business Affairs, to Mr. Charles Jeter, USEPA Region IV Administrator, Re: Review of RCRA Part B Permit Application, July 23, 1984.

24. Letter from James P. Vacik, Ph.D., Director of Environmental Safety, to James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, Re: Answers to Comments Received on Part B Permit Application, August 10, 1984.

25. Letter from James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, to Doyle Dillard, University of South Alabama Vice President of Finance and Business Affairs, Re: Request for Extension of Part B Permit Application, 2nd Revision Due Date, August 10, 1984.

26. Part A Permit Application, University of South Alabama, August 8, 1984.

27. Potential Hazardous Waste Site Preliminary Assessment, University of South Alabama, September 24, 1984.

28. Letter from James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, to Mr. William Pipas, University of South Alabama Executive Director of Development, Re: Review of Revision 2 of RCRA Part B Permit Application, November 13, 1984.

29. RCRA Part B Permit Application, University of South Alabama, December 5, 1984.

30. Letter from James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, to Mr. William Pipas, University of South Alabama Executive Director of Development, Re: RCRA Part B Permit Application, December 10, 1984.

31. Letter from James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, to Mr. William Pipas, University of South Alabama Executive Director of Development, Re: RCRA Part B Permit Application, December 31, 1984.

32. Letter from James Vacik, University of South Alabama Emergency Coordinator and Director of Environmental Safety, to Jack Horvanek, USEPA Region IV, Re: Copy of Ash Assay, January 24, 1985.

33. Information Regarding Potential Releases from Solid Waste Management Units, University of South Alabama, No Date.

34. Letter from James Vacik, Ph.D., University of South Alabama Director of Environmental Safety, to James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, Re: Submittals to RCRA Part B Permit Application, February 21, 1985.

35. Letter from James Vacik, University of South Alabama Emergency Coordinator and Director of Environmental Safety, to James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, Re: Submittals to RCRA Part B Permit Application, February 25, 1985.

36. Letter from James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, to Mr. William Pipas, University of South Alabama Executive Director of Development, Re: Notification to Revise RCRA Part B Permit Application to Incorporate HWSA Program, March 5, 1985.

37. Telephone Log from Unsigned to Jim Vacik, Re: LUST and HWSA Requirements, March 12, 1985.

38. Letter from James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, to Mr. William Pipas, University of South Alabama Executive Director of Development, Re: Review of Revision 3 of RCRA Part B Permit Application, April 29, 1985.

39. Form for RCRA Facility Management Strategy, University of South Alabama, May 14, 1985.

40. Letter from James Vacik, University of South Alabama Emergency Coordinator and Director of Environmental Safety, to James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, Re: Part B Permit Application Equipment Change and Variance Request, June 14, 1985.

41. Letter from James Vacik, University of South Alabama Emergency Coordinator and Director of Environmental Safety, to James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, Re: Pathological Incinerator Operational Procedure Variance Request, June 14, 1985.

42. Letter from Herb Miller, USEPA Region IV GA/FL Unit, WES, to Beverly A. Spagg, Chief AL/MS Unit, WES, Re: Comments to Waste Analysis Plan, June 26, 1985.

43. Letter from James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, to Mr. William Pipas, University of South Alabama Executive Director of Development, Re: Bio-hazardous Incinerator, June 18, 1985.

44. Letter from USEPA Region IV to Mr. William Pipas, University of South Alabama, Re: Requirements of HWSA on Land Disposal Units, June 28, 1985.

45. Letter from James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, to Mr. William Pipas, University of South Alabama Executive Director of Development, Re: Application for RCRA Permit for Container Storage, July 12, 1985.

46. Letter from James Vacik, University of South Alabama Emergency Coordinator and Director of Environmental Safety, to Mr. Jack Harvanek, USEPA Region IV Residuals Management Branch, Re: Response to 4th Revision to RCRA Part B Permit Application, July 16, 1985.

47. Letter from Bernard E. Cox, Jr., ADEM Chief Hazardous Waste Branch Land Division, to Mr. William Pipas, University of South Alabama Executive Director of Development, Re: Review of RCRA Part B Permit Application, July 22, 1985.

48. Public Notice No. RCRA-85-AL-004 for the University of South Alabama, Re: Issuance of Permits for the Existing Hazardous Waste Storage Facility, July 26, 1985.

49. Letter from James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, to Mr. William Pipas, University of South Alabama Executive Director of Development, Re: Incinerator Status Determination, August 14, 1985.

50. Notification for Underground Storage Tanks , University of South Alabama, April 29, 1986.

51. Hazardous Waste Facility Permit, University of South Alabama, September 12, 1985.

52. Letter from James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, to Thomas W. Devine, USEPA Region IV Director Waste Management Division, Re: Hazardous Waste Storage Permit, September 17, 1985.

53. Letter from Thomas W. Devine, USEPA Region IV Director Waste Management Division, to Mr. William Pipas, University of South Alabama Executive Director of Development, Re: Hazardous Waste Storage Permit, September 18, 1985.

54. Letter from James Vacik, University of South Alabama Emergency Coordinator and Director of Environmental Safety, to James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, Re: Incinerator Status Determination, November 1, 1985.

55. Letter from John E. Deal Jr., ADEM, to Bernard E. Cox, Jr., ADEM, Re: Tour of Incinerator/Boiler System, November 5, 1985.

56. Letter from James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, to J. Winston Porter, USEPA Region IV Assistant Administrator for Solid Waste and Emergency Response, November 22, 1985.

57. Letter from Jack W. McGraw, USEPA Headquarters, to Thomas Devine, USEPA Region IV Director, Air and Hazardous Materials Division, Re: Petition to Classify a Heat Recovery Unit as a Boiler, January 3, 1986.

58. Letter from Bernard E. Cox Jr. Chief Hazardous Waste Branch, to Mr. William Pipas, University of South Alabama Executive Director of Development, Re: Incinerator/Boiler Status, January 15, 1986.

59. Letter from Bernard E. Cox, Jr., ADEM Hazardous Waste Branch Land Division, to Mr. William Pipas, University of South Alabama Executive Director of Development, Re: Discrepancy in EPA Identification Numbers, March 6, 1986.

60. Letter from Bernard E. Cox, Jr., ADEM Hazardous Waste Branch Land Division, to Dr. James P. Vacik, University of South Alabama Emergency Coordinator and Director of Environmental Safety, Re: Discrepancy in EPA Identification Numbers, April 11, 1986.

61. Letter from James H. Scarbrough, USEPA Region IV Chief Residuals Management Branch, to Mr. William Pipas, University of South Alabama Executive Director of Development, Re: Incinerator Status Determination, June 27, 1986.

62. General Site Inspection Checklist, University of South Alabama, August 15, 1986.

63. Letter from ADEM to Dr. James Vacik, University of South Alabama Emergency Coordinator and Director of Environmental Safety, Re: Violations of Hazardous Waste Storage Permit, August 27, 1986.

64. Letter from James W. Neal, ADEM Chief Compliance Section Hazardous Waste Branch, to Bernard E. Cox, Jr., Chief Hazardous Waste Branch, Re: Visit to University of South Alabama, June 16, 1987.

65. Letter from Daniel E. Cooper, ADEM Chief Land Division, to Mr. William Pipas, University of South Alabama Executive Director of Development, Re: Notice of Violations, June 19, 1987.

66. Engineer's Certification of RCRA Closure for Loading Dock in Medical Sciences Building University of South Alabama, July 17, 1987.

67. Engineer's Certification of RCRA Closure for Storage Room 313 Cancer Center Clinic Building University of South Alabama, July 17, 1987.

68. Letter from Mr. William Pipas, University of South Alabama Executive Director Operations and University Facilities, to Mr. Daniel E. Cooper, Chief Land Division, Re: Notice of Violation, July 17, 1987.

69. Letter from Bernard E. Cox, Jr., ADEM Chief Hazardous Waste Branch Land Division, to Mr. William Pipas, University of South Alabama Executive Director Operations of University Facilities, Re: Notice of Violation, August 21, 1987.

70. RCRA Inspection Report, University of South Alabama, August 26, 1987.

71. Letter from Bernard E. Cox, Jr., ADEM Chief Hazardous Waste Management Waste Branch Land Division, to Mr. William Pipas, University of South Alabama Executive Director Operations and University Facilities, Re: Warning Letter, October 9, 1987.

72. Facility Specific Checklist, University of South Alabama, March 2, 1988.

73. RCRA Inspection Report, University of South Alabama, March 2, 1988.

74. Letter from Mike C. Smith, ADEM Pollution Control Specialist, Industrial and Hazardous Waste Section Land Program, to Mr. William Pipas, University of South Alabama Executive Director Operations and University Facilities, Re: Compliance with Federal and State Interim Status Standards, March 11, 1988.

75. Letter from Mark Behel, ADEM Technical Services Section Hazardous Waste Branch, to Bernard E. Cox, Jr., ADEM Chief Hazardous Waste Branch Land Division, Re: Site Visit, April 26, 1988.

76. Letter from James P. Vacik, Ph.D., University of South Alabama Director of Environmental Safety, to Robert W. Barr, ADEM Hazardous Waste Branch Land Division, Re: University of South Alabama Comments to Compliance Inspection Report, May 31, 1988.

77. Letter from Alicia A. Finch, ADEM Hazardous Waste Branch Compliance Section, to Bernard E. Cox, Jr., ADEM Hazardous Waste Branch, Land Division, Re: Trip Report, March 23, 1989.

78. Letter from James H. Scarbrough, P.E., USEPA Region IV Chief RCRA Branch Waste Management Division, to James Vacik, University of South Alabama Emergency Coordinator and Director of Environmental Safety, Re: Copy of Trip Report, April 14, 1989.

79. Letter from Terri Tobin, USEPA Region IV Waste Compliance Section South Unit, to Allan B. Antley, USEPA Region IV Waste Compliance Section South Unit, Re: February 22, 1989 Inspection at University of South Alabama, April 14, 1989.

80. Letter from Bernard E. Cox, Jr., ADEM Chief Hazardous Waste Branch Land Division, to Dr. James P. Vascik(sic), Director of Environmental Safety, Re: Meeting Concerning Permit Modification, May 31, 1989.

81. Letter from James Vacik Ph.D., University of South Alabama Emergency Coordinator and Director of Environmental Safety, to Bernard E. Cox, Jr., ADEM Chief Hazardous Waste Branch Land Division, Re: Meeting Concerning Permit Modification, June 9, 1989.

82. Letter from Bernard E. Cox, Jr., ADEM Chief Hazardous Waste Branch Land Division, to Dr. James P. Vascik(sic), Director of Environmental Safety, Re: Letter Dated June 9, 1989, June 26, 1989.

83. Letter from James Vacik, University of South Alabama Emergency Coordinator and Director of Environmental Safety, to Mr. Mark Behel, ADEM Hazardous Waste Branch Land Division, Re: B.E. Cox's Letter of 6/26/89 and out prior meeting of 5/24/89, September 29, 1989.

84. Letter from Sue R. Robertson, ADEM Chief Land Division, to Mr. James P. Vascik(sic), University of South Alabama Emergency Coordinator and Director of Environmental Safety, Re: Permitting Authority of ADEM and USEPA, October 4, 1989.

85. CEI Inspection, University of South Alabama, February 7, 1990.

86. Letter from Patrick M. Tobin, USEPA Region IV Director Waste Management Division, to Dr. James P. Vacik, University of South Alabama Emergency Coordinator and Director of Environmental Safety, Re: Copy of Trip Report for RCRA Performed on February 7, 1990, March 14, 1990.

87. Letter from James Vacik, University of South Alabama Emergency Coordinator and Director of Environmental Safety, to James H. Scarbrough, P.E., USEPA Region IV Chief RCRA Branch Waste Management Division, April 20, 1990.

88. Letter from University of South Alabama, to Sue R. Robertson, ADEM Chief Land Division, Re: NOV Under Hazardous Waste Facility Permit, May 16, 1990.

89. Telephone Conversation Record from Mark H. Behel, ADEM Hazardous Waste Branch, to James Vacik, University of South Alabama Emergency Coordinator and Director of Environmental Safety, Re: Letter Dated 5-16-90 Concerning Permit Modification, May 21, 1990.

90. Letter from Wm. Gerald Hardy, ADEM Chief RCRA Technical Services Branch Land Division, to Ms. Beverly Foster, USEPA Region IV AL/MS Unit, Re: Permit Modification, June 11, 1990.

91. Facility Specific Checklist, University of South Alabama, No Date.

92. EPA Region IV Form for RCRA Facility Management Strategy, No Date.

93. Chronology of Permit Actions, University of South Alabama, No Date.

94. Soil Survey of Mobile County, Alabama, United States Department of Agriculture, Soil Conservation Service, May 1980.

95. Selected Wells and Springs in Southwestern Alabama, Geological Survey of Alabama, April 25, 1987.

96. Map 201B, Selected Wells and Springs in Southwestern Alabama, by Blakeney Gillet, Victor M. Shamburger, and James D. Moore, Geological Survey of Alabama, No Date.

97. Map 121 Water Availability in Mobile County, Alabama, Geological Survey of Alabama, 1972.

98. Ground-Water Resources of the Lower Tombigbee-Mobile River Corridor, Geological Survey of Alabama, Circular 115, January 11, 1984.

99. Publications of the Geological Survey of Alabama and State Oil and Gas Board, Geological Survey of Alabama, June 1990.

100. Ground-Water Investigations in the Mobile Area, Alabama, Geological Survey of Alabama, 1947.

101. Surface Water in Southwestern Alabama, Geological Survey of Alabama, Bulletin 84, February 10, 1966.

102. History of Water Supply of the Mobile Area, Alabama, Geological Survey of Alabama, Circular 92, October 19, 1973.

103. Visual Site Inspection Attendance List, September 20 and 21, 1990, September 20 and 21, 1990.

104. VSI Log Book, Log 1 of 2, September 20 and 21, 1990.

105. VSI Log Book, Log 2 of 2, September 20 and 21, 1990.

106. VSI Photographs, September 20 and 21, 1990.

107. Information Needs from VSI Notification Letter, No Date.

108. Standard Warranty for EEI Model #750 Incinerator, Ecology Enterprises Inc., January 4, 1982.

109. Letter from William S. Pipas, University of South Alabama Executive Director Development and Operations, to Mr. John von Sprecker, Superintendent Mobile Water Service System, Re: NPDES Permit Application, August 25, 1983.

110. Letter from James P. Vacik, University of South Alabama Director Environmental Safety, to Sonja S. Massey, ADEM Industrial Branch Water Division, Re: Letter of 1/10/85 and NPDES Permit, April 19, 1985.

111. ADEM NPDES Permit for the University of South Alabama, Issued April 10, 1989.

112. Letter from James Vacik, University of South Alabama Emergency Coordinator and Director of Environmental Safety, to Office of Management and Budget Paperwork Reduction Project, Re: Request for Revisions to OMB Form No. 2050-0024 Exp. 3-32-92, February 23, 1990.

113. Conversation Record from Phebe Davol, A.T. Kearney, to Dr. James P. Vacik, University of South Alabama Emergency Coordinator and Director of Environmental Safety, Re: Information Needs Requested at VSI, October 29, 1990.

114. Information Needs Received from Dr. James Vacik, November 1, 1990.

115. Conversation Record from Lili Griffin, A.T.Kearney, to Mr. Mark Behel, ADEM, Re: Status of USA Permit, November 2, 1990.

116. Conversation Record from Lili Griffin, A.T.Kearney, to Dr. Vacik, University of South Alabama, Re: Information Needs Concerning Regulatory History, November 8, 1990.

117. Conversation Record from Lili Griffin, A.T.Kearney, to Mr. Mark Behel, ADEM, Re: Status of Subpart X Units at USA, November 8, 1990.

118. Conversation Record from Lili Griffin, A.T.Kearney, to Dr. Vacik, University of South Alabama, Re: Information Needs Concerning Waste Management Practices and Regulatory History, November 8, 1990.

119. Conversation Record from Lili Griffin, A.T.Kearney, to Dr. Vacik, University of South Alabama, Re: Information Needs Concerning Waste Management Practices, November 8, 1990.

120. Fax from Dr. Vacik, University of South Alabama, to Lili Griffin, A. T. Kearney, Re: Air Permit, Radiation Material License, and MSDS Sheets on Cooling Tower Blowdown, November 9, 1990.

[1] <High Performance Liquid Chromatography

[2] Federal Subpart X rules were promulgated in December, 1987. State Subpart X rules became effective in August 1989 (Reference 115).