ecology and environment, inc. CLOVERLEAF BUILDING 3, 6405 METCALF, OVERLAND PARK, KANSAS 66202, TEL. International Specialists in the Environment Site: ^W»Sfhnm id #: jfiDocatasazi Break: _______ _ S loQ^koaei MEMORANDUM RECEIVED I'd lae TO: Paul Doherty, EPA/DP0 PREP SECTION FROM: Scott Bradford, E & E/TAT THRU: Joe Chandler, E & E/TATI^?^~<C— DATE: June 1, 1989 SUBJECT: Vork Plan for Site Sampling of DeNova Industries, Alton, IA TDD # T-07-8905-022 PAN # TIA0199SAA Activity # ITX01 INTRODUCTION The Ecology and Environment, Inc., Technical Assistance Team (E & E/TAT), vas tasked by the Region VII United States Environmental Protection Agency (EPA) through TDD#T-07-8905-002 to develop and implement a site sampling vork plan for the Interchem/DeNova Industries in Alton, Iova. The purpose of this sample plan is to provide analytical data on the extent of pesticide contamination for proposed removal funded actions at the DeNova facility. The preliminary site investigation conducted in April 1989, indicated pesticide contamination on site, however, sample collection in that preliminary investigation only defined the existence of pesticides, not the extent of contamination. This vork plan will propose a complete sampling methodology, which will include soil, wipe, and drum sampling that vill provide the analytical results required to determine if a removal is required. SITE DESCRIPTION AND BACKGROUND INFORMATION DeNova Industries, Inc., site is located at 10th Street between 1st and 2nd Avenue in Alton, IoUa. The site consists of an office area on 10th Street, finished goods, rav material storage area, and bulk storage tanks (all north of the office area), four storage sheds, liquid storage facilities and concrete pad to the east along railroad tracks (across 1st Ave.), and a concrete pad used for toxaphene storage to the south. DeNova Industries came into existence on December 4, 1987 and is not associated vith the three previous companies that occupied the site: Silak, Interchem, and VHB specialities, although all were involved vith 30306893 Superfund recycled paper
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ecology and environment, inc.CLOVERLEAF BUILDING 3, 6405 METCALF, OVERLAND PARK, KANSAS 66202, TEL.
International Specialists in the Environment
Site: ^W»Sfhnm
id #: jfiDocatasazi
Break: _______ _
S loQ^koaei
■ ■
MEMORANDUMRECEIVED
I'd lae
TO: Paul Doherty, EPA/DP0 PREP SECTIONFROM: Scott Bradford, E & E/TAT
THRU:Joe Chandler, E & E/TATI^?^~<C—
DATE: June 1, 1989
SUBJECT: Vork Plan for Site Sampling of DeNova Industries, Alton, IA TDD # T-07-8905-022PAN # TIA0199SAAActivity # ITX01
INTRODUCTION
The Ecology and Environment, Inc., Technical Assistance Team (E & E/TAT), vas tasked by the Region VII United States Environmental Protection Agency (EPA) through TDD#T-07-8905-002 to develop and implement a site sampling vork plan for the Interchem/DeNova Industries in Alton, Iova. The purpose of this sample plan is to provide analytical data on the extent of pesticide contamination for proposed removal funded actions at the DeNova facility. The preliminary site investigation conducted in April 1989, indicated pesticide contamination on site, however, sample collection in that preliminary investigation only defined the existence of pesticides, not the extent of
contamination. This vork plan will propose a complete sampling methodology, which will include soil, wipe, and drum sampling that vill provide the analytical results required to determine if a removal is required.
SITE DESCRIPTION AND BACKGROUND INFORMATION
DeNova Industries, Inc., site is located at 10th Street between 1st and 2nd Avenue in Alton, IoUa. The site consists of an office area on 10th Street, finished goods, rav material storage area, and bulk storage tanks (all north of the office area), four storage sheds, liquid storage facilities and concrete pad to the east along railroad tracks (across 1st Ave.), and a concrete pad used for toxaphene storage to the south. DeNova Industries came into existence on December 4, 1987 and is not associated vith the three previous companies that occupied the site: Silak, Interchem, and VHB specialities, although all were involved vith
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pesticide formulation. DeNova Industries is presently out of business because of financial liability, with Mr. Mike Evan the court-appointed receiver for the property. DeNova Industries produced only dry pesticides under labels vith the folloving company names: Durvet,
Chem-Tech, Bloskas and Associates, Salsbury Labs, and International Multifoods. Silak, Interchem, and VHB specialities produced liquid and
dry pesticides, which included the formulation of pesticide products using the following chemicals: zineb, rotenone, methoxychlor, resmethrin, malathion, captan, pyrethrin, pentachloronitrobenzene, strychnine, piperonyl butoxide, diphacinone, saturn, MGK326 repellent,
xylene, MGK264, toxaphene, and lindane. When VHB Specialities sold the company to DeNova in December 1987, a large amount of waste material and product remained on site. Most of this material is confined in drums secured behind a fence, although unsecured storage exists throughout the facility.
In June 1981, the FIT and the Iowa Department of Environmental Quality made an investigation of the then Interchem company at the request of Congressman Berkeley Bedell. Mr. Bedell received a letter from concerned citizens regarding a rtputrid" odor from the Interchem (Silak) facility. The citizens also expressed concern about a fire at that facility five years earlier and what they called an "extremely high rate of cancer". The investigation revealed 2-3 gallons of dimethoate dissolved in cyclohexanone, which was spilled near the drum cleaning and crushing area. Lime was used to cover the spill which neutralized the dimethoate by base hydrolysis, therefore, reducing the hazards to the public. It was recommended that Mr. Pottebaum, President of Interchem, review his hazardous substance handling procedures and emphasize safety to his employees when handling product.
In April and August 1983, joint inspections were made by the EPA and the Iowa Department of Water, Air and Vdste Management (IDVAWM) to determine the facilities compliance with Chapter 900-141 (455B) of the Iowa Administrative Code, and 40 CFR pa brts 262 through 265, and 122 through 124. This was following a toxaphene spill that occurred on a concrete pad south of the office area. The inspection determined that the toxaphene storage tank had been triple rinsed and all toxaphene removed from its exterior. Soil and other debris from the toxaphene spill in excess of 100 kg was stored on-site, and that additional cleanup measures may be required. Soil samples taken from the toxaphene spill area contained up to 110,000 ppm. Samples analyzed after cleanup yielded readings of 5500 ppm toxaphene. In November 1983, the second cleanup action reduced levels to 120 ppm in soil and 120,000 ppm in concrete cracks. One hundred twenty six barrels of soil were removed. EPA and IDVAVM sent Interchem a letter requiring additional work to be completed and to come into compliance with interim Status regulations.
In June 1984, the U.S. EPA conducted a compliance evaluation inspection at Interchem to determine compliance with RCRA interim status regulations. Nine 55 gallon drums of xylene and toxaphene waste had been on site since August of 1983, indicating that Interchem may require
a RCRA interim status storage permit. Various other containers vere identified to contain waste products. No records vere being kept per regulation for storage facilities.
In July of 1984, Interchem was instructed to develop a closure plan. This was developed by Hickok and Associates. On March 3, 1987,
RCRA Inspectors made an inspection of the VHB Specialities (Interchem) facilities. They noted the condition of stored drums, general refuse, baghouse dust collection, product tanks, and spill mitigation procedures. No hazardous vaste had been removed from the site. All vaste was being stored behind a fence inside the warehouse. A list of all waste within the fenced area vas obtained, however, the storage arrangement did not allow a check for properly labeled and dated containers. Due to the way vaste vas stored, a violation vas issued citing 40 CFR 265.35. Interchem vas cited for failing to provide interim status records including: no vaste analysis plan; no inspection schedule; no personnel training or training documents; no contingency plan or emergency procedures; and no financial assurances.
On March 30, 1989, RCRA visited DeNova Industries (formally Interchem) along vith ARTX/TOPE and IDA (Iova Department of Agriculture) representatives. The purpose of the visit vas to note the current conditions of the facility, check on facility location, and determine current ovnership of the company and property. General order of the facility vas good, although product vas spilled on the floor and none Of
the barrels were on pallets. Closure of the hazardous vaste storage area vas to be handled by VHB Specialities. Several drums vere stored outside of the controlled area and contained a gray povder, and no varning signs existed on the fence. Mr. Detloff, Manager of DeNova Industries, stated that he vas not sure if the labels on drums indicated the actual contents. DeNova vas repackaging some material to make the area neater. Aatrum previously stored at the facility had been removed by Helena Chemical Company, Memphis, Tennessee. A number of sheds on the east side of the facility contained approximately 150 empty drums, some in a deteriorated condition. A number of storage tanks on-site vere also assessed and proved to be empty.
On April 13, 1989, at the request of the RADM Office, Roy Crossland, and Bob Viggans, EPA/EP&R, visited DeNova Industries to inspect current conditions of the facilities vaste storage area, and to verify if the fence around the material vas still intact. The area of a reported toxaphene spill had a partially fallen wood and vlre fence surrounding a concrete pad. This fence vas reconstructed and one grab soil sample taken from north of the concrete pad. Three tanks adjacent to the facility vere inspected, as veil as, the aboveground liquid storage tanks east of First Avenue. No determination vas made if the tanks vere empty. The storage sheds north of the liquid storage tanks contained approximately 200 empty drums of various sizes. On the south end, inside an old red shed, a number of broken fiber drums could be
found vith spillage. The hazardous vaste storage area located along the south vail inside the metal storage building appeared to be in good
condition. A four foot high fence vas placed around the material and marked vith warning signs. Fifteen fiber drums labeled as waste sat outside the fence and several drums inside the fence were leaking. Eleven grab samples taken from the DeNova Site indicated evidence of pesticide contamination. Grab samples were collected from the bulk tank area, storage shed, and toxaphene spill area. Three wipe samples were collected inside the finished goods and raw material storage area. In the raw material storage area, results indicated various pesticide contamination of up to 1,600 ppm Lindane and smaller concentrations of Other products.
GENERAL SAMPLE PLAN
SOIL - Samples at the DeNova site will consist of approximately 15 surface soil samples. A composite sample will be taken from each section to 2^ depth. Sections are planned to be plotted to include the areas around the concrete pad south of the office area; on the west side of the liquid storage tank, the red shed, and sheds 13, 14, 15; and the area surrounding the bulk tanks and adjacent to the concrete driveway. For future reference wooden stakes will bemused to mark the corners of the sections that will not exceed 5,300 ftZ in area. Each Section will
be flagged using a 10 ft. x 10 ft. sample grid.
In addition to the 15 soil section samples, between 5 and 10 grab samples will be collected from discrete soil areas that exhibit visible evidence of staining.
All surface soil samples will be collected with stainless steel spoons, and composited in aluminum pie pans. Samples will then be placed in 8 ounce glass jars. One background soil sample will be collected from a 0-2" depth at a point designated upon site inspection. The background soil sample will be collected, processed, and packaged in
the same manner as-the on-site soil samples.
Sampling will be conducted on sludge from the septic system (if appropriate) and drains inside he DeNova property to determine if contamination has migrated off-site. These will be grab samples collected with a stainless steel spoon, or wipe samples if sediment is not accessible.
DEPTH SAMPLING
Ten depth soil samples will be taken using a slambar and plastic tubing from areas of suspected contamination and near storage areas. Samples will consist of soil core ranging from 0-8" and 8" - 16". The slambar will be decontaminated after each sample to prevent cross contamination.
WIPE - A total of 15 wipe Samples will be collected at the DeNova site. Areas that will be sampled include the office area; finished goods storage area, hazardous waste storage area, raw material storage
area, liquid process shop, concrete drive, blending and packaging areas, and various equipment inside the furnished goods area. Each vipe sample will be collected from a 2500 cmz area using a 4 x 4 inch sterile gauze
saturated vith hexane and placed in a glass jar. Each sample vill be designated upon site Inspection and documented on field sheets, site log book and final site sample map.
One blank vipe sample (QA/QC) vill also be collected and packaged in the same manner as the other vipe samples.
DRUM - Drum sampling Vill be limited to unlabelled containers and random sampling of marked drums. For every 10 drums that have labels Indicating like material, one vill be sampled on a random choosing. Drums of solid material vill be sampled vith a stainless steel spoon and placed in an 8 ounce jar. Liquid samples vill be collected using a glass thieving rod and plabed in 8 ounce jars. A composite mixture vill be taken of the entire drum.
DUPLICATE - Duplicate samples vill be taken from 10 - 15X of soil and drum samples for QA/QC analysis.
DOCUMENTATION
Sampling activity vill be thoroughly documented to provide a record Of the sample collection procedures, sampling location and chain-of-custody procedures. The documentation vill consist of field sheets, sample tags, chain-of-custody records, field logbook and photographic record.
SAMPLE SUMMARY
A total of 15 surface soil section samples, 10 surface grab samples, 15 interior vipe samples, and random drum sampling vill be conducted on the DeNova site. One soil background and a field blank vill also be collected. Samples collected at DeNova Industries vill be screened for pesticide contamination by the EPA laboratory and retained for QA/QC analysis. The sample series number (activity number) for this field investigation is ITX01. Sampling is anticipated to occur in early June 1989.
OTHER ON-SITE ACTIVITIES
Vhile on-site, the TAT vill conduct an inventory of vaste containing drums in the hazardous vaste storage area and storage sheds. The inventory should note the contents of each drum, and vhat condition the container is in. Leaking drums vill be overpacked if possible. A survey vill be made of the liquid storage and bulk storage tanks to determine if any contents remain in those areas. Sampling of these areas vill be on an as needed basis. Condition of storage facilities vill also be documented.
II
DECONTAMINATION AND SITE SAFETY
Level C outer protective clothing vill be necessary to ensure adequate site safety. Level C vill be vom by TAT members vhile obtaining the on-site soil, wipe, and concrete samples. Level B respiratory protection must be vorn vhen sampling liquid drums. Level C protection, including Racal respirators, vill be vorn at all times in high-dust areas. Level D protection may be used vhen flagging exterior grids.
Decontamination vill consist of a soap and vater vash and deionized vater final rinse. Vash vater vill be disposed of on-site in knovn contaminated areas. Disposable equipment, clothing and respirator cartridges vill be placed in large plastic bags and carried back to Kansas City for storage and ultimate disposal. Decontamination vill be accomplished on-site in designated decontamination areas*
Depth samples, QA/QC samples, vater supplies, building drain and septic tank if not on city sever system.
ATTACHMENTS
Site Map Location MapHazardous Vaste Inventory
N
J
UunJSuo
1st. Ave.
A | |
A a ■ | A A e A
1
4
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■4-+-4- -t- -t-
Three sets of R. R. Tracks
Hap of InterChem/DeNova Pesticide Co.Alton* IowaInvestgation by Roy Crossland & Bob Wiggans EPA/ENSV/BP&R. April 13-14, 1989
11th Street
STATUS
Hazardous Waste Inventory
PRODUCT. AICOMMON NAME
USE CLASSTQXICIT*
iRaonTetrochlorvinphos Insecticide 111 Reg. for use
Co-Ral Couxnaphos Insecticide 111 Reg. for use
Ectiban Permethrin Discontinued in 1985
Malathion Malathion Insecticide 111 Reg. for use
Captan Captan Fungicide 111 Reg. for use
Rotenone Rotenone Insecticide 111 Reg. for use
Maneb Maneb Fungicide 111 Reg. for use
Dithane Maneb Fungicide 111 Reg. for use
Sevin Carbary1 Insecticide 111 Reg. for use
Diazol Diazinon Insecticide lll&ll Reg.for use
Methoxychlor Methoxychlor Insecticide 111 Reg. for use
^Hfelt&^ various trees Insecticide 111 Reg.for use
^^Diphacinone Diphacinone
Rat Beit
Rodenticide 11 Reg. for use
Marlate Methoxychlor Insecticide 111 Reg. for use
Xylene Xylol . Solvent 11 Xe». for ue.
TS3S3 -SSSS. Moventoerum for scabies on cattle and sheep and emergency use for army worms# cutworms# and grasshoppers.)
Lindane Lindane[Marketed under Special Local
Insecticide Need(SLN))
11 Restricted
Trichlorfon Trichlorfon Insecticide 11 Reg.for use
Fyrethrins PyrethumInsecticide 111 Reg. for use
Plparonyl Butoxide^ BynerBei>t
Dimethoate Dimethoate
111 Reg. for use
Insecticide-Acaricide 11 Reg for use
1
Fungicide Reg. for useTerrazan• Pentachloronitrobenzene
Bromanide (No information available)
ptock-Tox (No information available)
Ban-Tox ( No information available)
Mala-Tox Maiathion Insecticide 111 Reg for use
Strychnine Strychnine Poison 1 Restricted
use(All above ground use canceled* below ground use only)
DPM (No information available)
Dipel Bacillus thuringiensis Microbal Insecticide 111 Reg for use
