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HomeMy WebLinkAboutDSHW-2024-005813Permittee: BP Products North America, Inc. Attachment I Post-Closure Care and Monitoring Plan Closed Hazardous Waste Management Facility Salt Lake City, Utah EPA ID No. UTD000826370 April 2024 TABLES Table 1Monitoring Well Construction Detail and Sampling Rationale Table 2Summary of Parameters and Analytical Methods Table 3Designated Responsible Personnel Table 4Job Qualifications/Descriptions Table 5Post-Closure Cost Estimate FIGURESFigure 1 Site Location MapFigure 2 Arial Photo Figure 3 Monitoring Well NetworkFigure 4 GW and S Wells Groundwater Contours and Flow DirectionsFigure 5 TN Wells Groundwater Contours and Flow DirectionsFigure 6 WQ Wells Groundwater Contours and Flow DirectionsFigure 7 Schematic Diagram of Post-Closure Detection Monitoring WellFigure 8 Report Decision Flow Chart APPENDICES Certification of Closure Affidavit Notice to Deed and Closure Survey Plat Post-Closure Monitoring and Inspection Checklists Post-Closure Groundwater Detection Monitoring Plan Contingency Plan for Post-Closure Care and Monitoring Introduction General This Post-Closure Care and Monitoring Plan describes a program for post-closure care and monitoring of the closed surface impoundments at BP Products North America, Inc.'s (BP) Closed Hazardous Waste Management Facility (CHWMF). The CHWMF is a former refinery waste containment facility that consisted offour surface impoundments and two evaporation pond areas.The facility consists of approximately 87 acres and is located in northern Salt Lake City, Utah.A site location map is provided as Figure 1 and a site layoutmap is shown on Figure 2. Prior to 1991, this facility was known as Amoco Oil Company's (Amoco) “Remote Hazardous WasteManagement Facility” (RHWMF) with the same U.S. Environmental Protection Agency (EPA) Identification Number (UTD 000826370).In 2003, Amoco's name was changed to BP Products North America, Inc. in a revised version of the Post Closure Careand Monitoring Plan. This Post-Closure Care and Monitoring Plan accompanies and is incorporated by reference into the CHWMF Post-Closure Permit for the facility.Included in this document are descriptions of post-closure program elements including training, groundwater monitoring, inspections and maintenance, and reporting.The Groundwater Detection Monitoring Plan, the Contingency Plan, and post-closure monitoring and inspection checklists are components of this revisedplan and are contained in the appendices to this document.The appendices specifically address issues pertinent to post-closure care and monitoring at the CHWMF.The CHWMF Post-Closure Permit describes these and all other actions that are required for thefacility.The current Post-Closure Permit was renewed in 1997 and is valid for ten years. The CHWMF was certified closed on July 29, 1991, and activities at the CHWMF have since entered the post-closure period.The post-closure care period continues with the requirements of the post-closure permit. A copy of the certification of closure for the facility is attached as Appendix A. BP owns the land occupied by the CHWMF and the land up to 1,000 feet north of the CHWMF.Access to theproperty is limited to authorized BP personnel and contractors by entrance through a locked gate located near the southern property boundary.Vehicular traffic on the final capped areas, which overlie the wastes, is limited to authorized personnel in the performance of required maintenance or monitoring activities.Post­ closure use of the area in which hazardous wastes remain after closure shall be open space and BP will not allow disturbance of the integrity of the final cover, slurry wall, or any other components of the containment system, or the function of the facility's monitoring systems, unless the Utah Division of Waste Management and Radiation Control (UDWMRC) finds that the disturbance: Is necessary to the proposed use of the property, and will not increase the potential hazard to human health or the environment; and/or Is necessary to reduce a threat to human health or the environment The property owned by BP containing the CHWMF was purchased as three separate parcels, one in 1960,and two in 1963.A 29.69-acre parcel was purchased from the Salt Lake City Corporation in 1960; 27.60 acres and 29.68 acres were purchased in 1963 from the Portland Cement Association and the Snow Estate, respectively.In December 1984, an instrument was added to the deed for each property acknowledging the presence of hazardous waste on the properties.On October 25, 1991, a revised Affidavit Notice to Deed and Closure Survey Plat were delivered to the SaltLake County Recorder for recording as required by the Post-Closure Permit.As instructed by the CountyRecorder's office, an original survey plat was delivered to the County Surveyor's office, so it could be properlyfiled with land records.Written verification was also provided to the Utah Solid and Hazardous WasteCommittee and EPA Region VIII that these two instruments were filed.A copy of the Deed and Plat are attached in Appendix B. Location of Records Since there are no structures at the CHWMF to house documents pertaining to the post-closure period, all plans, records and reports generated during the post-closure period will be at the location specified in Table 3 of Attachment I. Copies of the post-closure permit, post-closure care and monitoring plan. Groundwater Level and Quality Monitoring Groundwater level and quality monitoring will be performed on an annual basis, unless the post-closure permit is modified for the groundwater monitoring. In accordance withrequirements of the Post-Closure Permit, BP must notify the Directorof the Utah Division of Waste Management and Radiation Control (the Director) in writing at least seven calendar days in advance of any sampling event.All groundwater level measurements must be made within a 24-hour period.All groundwater samples for each sampling event must be collected within a 48-hourperiod. Groundwater Level Monitoring Monitoring of water levels around the containment system will be performed annually during the post-closureperiodat the well locations listed in Table 1 - Monitoring Wells Construction Details and Sampling Rationale. The locations of the wells are shown on Figure 3. Monitoring wells and a stream gauge in the adjacent Northwest Drain Canal (NWDC) will be used to measurewater levels: Monitoring wells (GW-series, S-series, TN-series, and WQ-series wells that are screened at different depths) will be used to monitorpressures and water quality as required by the Post-Closure Permit, in the aquifer referenced in Table 1. Figures 4, 5 and 6 show the groundwater level contours and flow directions for GW and S wells, TN wells, and WQ Wells, respectively, based on the groundwater level measurements conducted in September 2020. Stream gauge SG-2300 will also be monitored since the NWDC is interconnected with andinfluences groundwater flow in the shallow aquifer. The purpose of the water level monitoring system is to determine groundwater flow direction.  BP must submit, at least annually, a potentiometric map indicating the groundwater surface elevation, groundwater flow direction and an evaluation and determination that a minimum of three, point of compliance wells are downgradient of the facility. If the findings of the hydrogeological evaluation indicate conditions have changed, then changes in the monitoring program or a demonstration that the changes are temporary,will be presented to the Director in the annual report. BP shall initiate appropriate permit modification as needed to meet the requirements of the applicable permit conditions. Hazardous Constituent Groundwater Detection Monitoring The point-of-compliance for hazardous constituent monitoring defined in the Post-Closure Permit is the vertical plane at the hydraulically downgradient limit of the waste management area.This corresponds with the northern and western limits of the slurry wall as shown on Figures 2 and 3.A schematic diagram of the detection monitoring wells is shown on Figure 7. Groundwater samples will be obtained using the methods detailed in the Post-Closure Groundwater Detection Monitoring Plan (Appendix D to this document).Groundwater samples will be obtained from compliance point monitoring wells WQ-1 through WQ-5in year 2020 and 2024, and GW-1 through 5 annually) and the upgradient monitoring well (S-16) annually to year 2024. Following the 2024 monitoring event, BP may petition inwriting for theDirector’s approval to cease monitoring at WQ-series well and reducing monitoring from annually to every five years if the data supports this decision. In the case of a loss of sample integrity (i.e., breakage, loss) during any monitoring and sampling event, resampling must take place within 21 days of notification of the loss with prior notice to the UDWMRC. Samples will be analyzed and reported for the full suite of analytes including the nine volatile organic constituents,total arsenic, total barium, total cadmium, total chromium, total iron, total lead, and total seleniumas listed in the table belowand in Table 2 using USEPA method 8260D, as referenced under Permit Table IV-1 or the most current approved USEPA alternate method. . The volatile organic constituents selected for detection monitoring are not present at detectable concentrations in upgradient monitoring well S-16. The concentration limit for any of the volatile organic constituents is established for the purpose of assessing a potential release from the waste containment system through the slurry wall. The laboratory reporting limits must be below the concentration limits performed by certified analytical laboratories. Totalchromium is also a detection monitoring parameter.Chromium is a naturally occurring constituent of soils but was found in the wastes contained within the CHWMF at concentrations above background soils. Theconcentration limit for total chromium is set at 100micrograms per liter (µg/I), consistent with the value in Table 1 - Maximum Concentration of Constituents for Groundwater Protection in accordance with R315-264-94 of Utah Admin. Code. The concentration limits for the parameters of interest are: DetectionMonitoringParameter ConcentrationLimit(µg/I) 1,1Dichloroethane 5 1,1Dichloroethylene 5 Chloroform 5 1,1,1Trichloroethane 5 CarbonTetrachloride 5 Benzene 5 Toluene 5 Ethylbenzene 5 Xylene(total) 5 Total Chromium 100 Total Arsenic 10 Total Barium 2000 Total Cadmium 5 Total Selenium 50 Total Iron 300 The results of the analyses must be evaluated to determine if there is a statistically significant increase over the backgroundvalues for each organic parameter and whether chromiumexceeds the Maximum Contaminant Level each time groundwater quality is determined at the compliance point. The statistical test is a two-step process. After each sampling event, the reported values obtained at each compliance well with the concentration limit will be compared. If a reported value is less than the concentration limit stated above, then there has not been a statistically significant increase over background. If the reported value is greater than the concentration limit, then the following steps will be followed in order to determine if a statistical increase has occurred.Any sample reported by the laboratory to have a concentration which exceeds the concentration limit of a detection monitoring parameter will be resampled.If the resample confirms the exceedance of the concentration limit, then a statistically significant increase over background will have been determined.If the resample does not confirm an exceedance of the concentration limit, then a statistically significant increase over background will not have been determined. The Director must be notified within seven (7) days of an exceedance of the concentration limit after receiving resampled results. BP must determine whether there is a statistical increase in the detectionmonitoring parameters within sixty (60) days after completion of sampling.If a statistically significant increase is determined, BP must comply with the requirements of Permit ConditionIV.I.1 in Part B Module 4, which includes notifying the Director within seven (7) days.If BP wishes to make a demonstration that the increase was due to an error in sampling, analysis, or another error, the Director must be notified of the intent to make a demonstration within seven (7) days. In addition, samples from each compliance well and the upgradient well will be analyzed in the field for pH,temperature, and specific conductance.These additional parameters are measured for informational purposes only. Inspections and Maintenance Regularly scheduled routine maintenance activities will be performed either on a semi-annually or an annual basis as specified below.Maintenance requirements identified during the semi-annually inspections will be addressed as specified below.A summary of inspection and maintenance activities conducted each year will be presented in annual reports. A summary of inspections to be performed during the post-closure period and their frequency are presented below.The inspection forms included in Appendix C detail the observations to be made during each inspection. Type of Inspection Frequency Security Inspection Semi-annually Cover Inspection Semi-annually Groundwater Level Monitoring Annually Groundwater Monitoring and Evaluation Annually Monitoring Well Integrity Annually Sediment Accumulation in Wells Annually Security Inspection The semi-annually security inspections consist of verifying the integrity of the fence around the perimeter, proper posting of warning signs (every 300 feet along the fence), and proper locks on the gates.Holes in the fence or missing locks will be repaired or replaced immediately.Missing or unreadable warning signs will be replaced within thirty (30) days.Security inspection observations and findings will be recorded on Form AMR-21 (Appendix C). Cover Inspection The cover over the wastes will be monitored semi-annually during the post-closure period and maintained as necessary to preserve its integrity.Cover inspection observations and findings will be recorded on Form AMR-22 (Appendix C). Detailed cover inspections will include the following: Inspections to identify trees or shrubs initiating growth on the cover.Any deep rooting species identified will be removed during regularly scheduled maintenance activities. Inspection for holes or erosion through the cover.If an area larger than 10 square feet which partially penetrates the cover is identified, it will be repaired during regularly scheduled maintenance. Any depressions and/or ponded water identified on the cover will be repaired during regularly scheduled maintenance. Any seepage observed emanating through the cover will be investigated and repaired after the cause has been identified. The cover area will be inspected for signs of the presence of burrowing animals.If burrows are identified and are large enough to suggest the presence of animals larger than mice or voles (such as ground squirrels, fox, badger), positive steps will be taken to remove these animals from the CHWMFarea.Action will depend upon specific circumstances but might include trapping or poisoning.Advicefrom the U.S. Fish and Wildlife Service's Salt Lake City Animal Damage Control office will be sought regarding recommended methods. The gas vent risers will be inspected for damage or cracks.Damaged risers will be repaired during routine maintenance activities. The 18-inch diameter pipes used to convey runoff from the evaporation ponds area to the south drainage canal will be inspected each quarter.The valves will be checked for working order and debris found in the pipes will be removed. Groundwater Level Monitoring Groundwater elevations will be measured annually at the locations listed in Table 1 and recorded on FormAMR-14 (Appendix C).Groundwater levels and flow directions will be evaluated, and actions will be taken as described in Section 2.1. Monitor Well Integrity Testing Surface Seals All monitoring wells listed in Table 1 will be checked annually to ensure that the surface seals are sufficient to prevent surface water from entering the wells and affecting water level elevations. The results of monitoringwell integrity testing will be recorded on Form AMR-15 (Appendix C). As part of the permit modification, Section B of this form has been deleted as well response tests will no longer be performed. Monitoring well surface seals will be checked by visual inspection.Those wells which show visual signs of faulty seals will be tested by placing a 12 to 20-inch diameter tube on the ground surface concentric about the well casing, filling it with 6 inches of water, and monitoring the water level in the well for 15 minutes.Wells which exhibit an increased water level of more than one inch during the testing period will be resealed and retested. Sediment Accumulation in Wells All monitoring wells listed in Table 1 will be checked annually for sediment accumulation.The results of sediment accumulation checks will be recorded on Form AMR-16 (Appendix C).Those which exhibit 2 feet or more of sediment will be evaluated for maintenance to remove the sediment. Responses to Inspection Results There are two basic types of responses envisioned as a result of failing to meet inspection criteria: Immediate Response - for situations in which prompt action is required to prevent potential exposure to, or release of hazardous waste or hazardous constituents to the environment. Appropriate actionswill be initiated within 48 hours of notification. Reporting Responses - for situations where maintenance is required but there is no imminent danger of potential release of hazardous waste or hazardous constituents to the environment. Situations during the post-closure period in which immediate responses are required are those when: Site security has been breached, or Groundwater quality monitoring results indicate there may have been a release of hazardousconstituents from the closed facility. Events requiring immediate response will trigger initiation of the Contingency Plan (Appendix E) and the reporting requirements. Inspection findings which require only reporting responses, such as sediment accumulation in wells, cover defects, inadequate surface seals, and unresponsive monitor wells, will receive prompt attention (i.e., repair or replacement within 60days of the inspection).Maintenance repairs and routine maintenance will be documented and reported with the other items included in the annual report to UDWMRC. Listed in the table below are the responses that will be required for each of the items on the indicated checklists. Checklist Item Response Required Action Annual Groundwater Level Monitoring (Form AMR-14) Groundwater flow directionindicates that fewer than three water quality monitoring wells are downgradient Annual Report Evaluate cause and recommend action Annual Monitoring Well Integrity Tests (Form AMR-15) Surface seals for monitoringwells are inadequate Annual Report Schedule for maintenance Annual Monitoring Well Sediment Inspections (Form AMR-16) Sediment accumulation in excess of limit Annual Report Schedule for maintenance Semi-annually Cover Inspection (Form AMR-21) Breaks in security fence Immediate Repair Damaged or missing gate lock Immediate Replace Any inspections which identify a problem requiring an immediate response will culminate with a written reportto the UDWMRC within seven (7) days of identifying the problem.The report will contain a description of theproblem, the corrective action taken, the period over which the problem existed, and the effect on the CHWMF site.More immediate and frequent reporting to governmental agencies will be initiated if a sample from a compliance point monitoring well exhibits a concentration of a constituent in excess of the groundwater protection standard.Details are provided in the Contingency Plan for Post-Closure Care and Monitoring (Appendix E).A flow chart (Figure 8) summarizes how the results of post-closure inspections will be handled. Personnel and Training Personnel Personnel involved in hazardous waste management at the facility during post-closure will be the Facility Coordinator (FC), the Alternate Facility Coordinator (AFC) and the Facility Inspector (Fl) or Alternate Facility Inspector (AFI). The FC and AFC are members of BP management, or their designated representatives, who have had yearsof work experience and are familiar with the facility and the Post-Closure Permit and the Post-Closure Care and Monitoring Plan.They are qualified to performall closure inspection and monitoring activities and to direct any activities described in the Contingency Plan. No person will be allowed to perform any maintenance, repair, or contingency response activity except under the supervision of the FC or AFC. The Fl and AFI are also experienced and familiar with the facility and have had field experience in inspection and groundwater monitoring activities. The personnel designated as the FC, AFC, Fl, and AFI are identified in Table 3and jobdescriptions/qualificationsfor these positions are presented in Table 4.If there are changes in personnel, BP will submit a Class I permit modification. Training Plan Annual training will consist of a review of: Post-Closure Permit Post-Closure Care and Monitoring Plan, including: Post-Closure Groundwater Detection Monitoring Plan Contingency Plan for Post-Closure Care and Monitoring Potential maintenance operations. The following specific topics will also be covered during training: Groundwater level monitoring requirements Groundwater quality monitoring requirements Inspection and reporting requirements Maintenance requirements Contingency Plan Security Pertinent BP procedures and Occupational Safety and Health Administration Health and Safety Regulations General requirements of the Post-Closure Permit for the CHWMF. Training Schedule The FC will conduct formal training in a classroom with the AFC and FIs annually.On or before July 1 of each year, the FC, AFC, Fl, and AFI will sign the Annual Training Certification Form (Form AMR-41) verifying completion of annual training.A copy of AMR-41 is included with the forms in Appendix C.This personnel training will meet the requirements of R315-264-16 of Utah Admin. Code. In the event of a change in personnel and a new person is assigned as the FC, AFC, FI, or AFI, that person willreceive the above-described training prior to performing any activities relating to the facility.The newly assigned person will sign a statement attesting to their training and qualifications to verify that they are trained.All signed statements verifying training sessions will become part of the operating record and will be maintained in the document repository at the location specified in Table 3 of Attachment I until the end of the post-closure period. Contingency Plan The Contingency Plan for Post-Closure Care and Monitoring is attached as Appendix E. The purpose of theplan is to describe response personnel, response activities, and procedures when and if contingencies arise during the post-closure period.Contingency Plan actions or activities will be invoked when any inspection deficiency requires response classified as "immediate" as described in Section 3.4. No contingencies or lists of equipment have been developed for the threat of fire, explosions, or similar sudden releases of hazardous constituents because there is no likelihood of the waste material or hazardous constituents causing an explosion or fire.The waste materials disposed at the CHWMF were stabilized withcement and soil into a non-flammable, solid mass that will not support combustion, and are isolated beneath a 3-foot thick engineered clay cap. Reporting Requirements Two types of reports will be submitted to UDWMRC during the post-closure period.Any inspections whichidentify a problem requiring an immediate response will culminate with a written report to the UDWMRC, as described in Section 3.0 and in the Contingency Plan.On or before April 15 of each year an annual report will be submitted to UDWMRC summarizing the events of the previous calendar year at the CHWMF.The annual reportwill include a description of the following: A summary of routine inspections and maintenance performed A summary of any inspection items that initiated the Contingency Plan and a brief description of howthe problem was corrected A summary of groundwater level monitoring data collected and an evaluation of groundwater flowdirections A summary of groundwater quality data obtained from the groundwater detection monitoring system A revision of estimated post-closure costs. Post-Closure Cost Estimate The costs for operation and maintenance of the CHWMF during the post-closure period aresummarized in Table 5.Note that the costs in Table 5are based on groundwater monitoring conducted on a semi-annual basis, not annual as is being proposed in this updated plan.Assuming UDWMRC approves this plan, the costs for operation and maintenance of the CHWMF will be revised and an updated estimate included in the annual report, which is due on April 15,each year. The permit requires that the post-closure cost estimate be revised on an annual basis to account for inflationand other conditions.A revised cost estimate will be included in each subsequent annual report. The instrument for financial assurance was previously forwarded to UDWMRC prior to closure.Assuming no major changes in post-closure operation and maintenance requirements, the total amountrequired for financial assurance will decrease each year during the post-closure period. Closure Certification Affidavit Notice to Deed and Closure Survey Plat Post-Closure Monitoring and Inspection Checklists Post-Closure Groundwater Detection Monitoring Plan Contingency Plan for Post-Closure Care and Monitoring