6/23/11 - ADMINISTRATIVE ORDER ON CONSENT UNDER RCRA 3013(a).
ORDER REQUIRES:
- RESPONDENT SHALL SUBMIT TO EPA A SAMPLING AND ANALYSIS WORKPLAN WITHIN 90 DAYS. THE WORKPLAN FOR ASSESSMENT MUST INCLUDE THE FOLLOWING:
a. PROCESS WATER SAMPLES FROM THE SULFURIC ACID PLANT, DISCHARGE WATER FROM SULFURIC ACID PLANT PROCESSES, DISCHARGES FROM PRODUCT SPILLS WITHIN AND AROUND THE SULFURIC ACID PLANT, AND DISCHARGE WATERS FROM MAINTENANCE ACTIVITIES WITHIN AND AROUND THE SULFURIC ACID PLANT, INCLUDING BUT NOT LIMITED TO WATER FROM BOILERS AND COOLING TOWERS BLOWDOWNS.
b. A SEDIMENT AND/OR SOIL, AS APPROPRIATE, SAMPLING AND ANALYSIS SECTION TO COLLECT AND ANALYZE REPRESENTATIVE SEDIMENT AND/OR SOIL SAMPLES TO DETERMINE THE NATURE AND EXTENT OF POTENTIAL CONTAMINATION, BOTH VERTICALLY AND HORIZONTALLY. AREAS OF SAMPLING SHALL INCLUDE THE MOSAIC OPERATIONS, STORMWATER AND NON-PROCESS WATER DITCHES AND PONDS, AND DITCHES ASSOCIATED WITH THE NPDES OUTFALL. THE WORKPLAN SHALL ALSO INCLUDE SAMPLING IN AREAS OF DISCHARGES WITHIN AND AROUND THE SULFURIC ACID PLANT FROM PRODUCT SPILLS, RAILCAR CLEANING OPERATIONS, AND DISCHARGE WATERS FROM MAINTENANCE ACTIVITIES AND DEMINERALIZATION UNITS REGENERATION. THE WORKPLAN MUST DEFINE THE NUMBER, LOCATION, AND DEPTH OF THE SAMPLES, AND THE PARAMETERS FOR ANALYSIS.
c. A SURFACE WATER (INCLUDING RUNOFF) SAMPLING AND ANALYSIS SECTION TO DETERMINE THE NATURE AND EXTENT OF ANY CONTAMINATED SURFACE WATER FLOWING FROM THE PORTIONS OF THE FACILIT