[APPENDIX D- STORM WATER MANAGEMENT PLAN …November 12, 2015 CO001908.0002 Subject: Appendix D – Storm Water Management Plan Addendum No. 2-Revised On behalf of the Malone Cooperating

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MEMO

To:

Bob PiniewskiCopies:

June Yi Brian Moore

From:

Tim Wippold, P.E.

Date: ARCADIS Project No.:

November 12, 2015 CO001908.0002

Subject:

Appendix D – Storm Water Management Plan Addendum No. 2-Revised

On behalf of the Malone Cooperating Parties (MCP), ARCADIS U.S., Inc. (ARCADIS) developed the attached Storm Water Management Plan Addendum 2 (addendum) to be included in Appendix D of the March 2014 Storm Water Management Plan located in Appendix M of the General RDRA Work Plan (ENTACT 2014, Revision A) for supplemental controls and practices to be implemented during the Phase Two remedial action at the Malone Service Company Superfund Site in Texas City, Texas (Site). The intent of this addendum is to provide additional information regarding the strategy for the management of storm water on the site.

ARCADIS U.S., Inc.

2929 Briarpark Drive

Suite 300

Houston

Texas 77042

Tel 713.953.4800

Fax 713.977.4620

*500019145**500019145*500019145500019145

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Table 1Response to EPA/TCEQ CommentsStormwater Management Plan Addendum No. 2

Malone Service Company Superfund SiteTexas City, Galveston County, Texas

1

Comment No.

ReferenceAgency Comment MCP Response

TCEQ Comments 1 General Comments There are references to other terms and/or documents such as

Categories 2 and 3 (pp. 2/6, 3/6), Tables 2 and 3 (pp. 2/6, 3/6) and runoff flow/drainage across the facility (p 3/6).

Comment Acknowledged. Responses located below.

1.A. General Contact Water (Page 2/6). There appears to be various terms that may all relate to contaminated water contact water. There is a list of “three sources of contaminated water” (paragraph 1), a reference to “three types of contact water” (noted just below the list), and “contact storm water” and Categories 2 and 3 (last paragraph in this section). Are items #2 and #3 (from the numbered list) correlative to the terms Categories 2 and 3? Please clarify and revise accordingly.

Yes, items #2 and #3 correlate with Category 2 and 3. Addendum #2 will be revised to reflect the comment.

1.B.1 General PENDING: The TCEQ Stormwater and Pretreatment Team are currently reviewing Tables 2 and 3 because new methods and MALs for some pollutants became effective July 2014. Please advise if the existing footnotes to Tables 2 and 3 remain applicable. Any revisions will need to be communicated to the TCEQ Stormwater and Pretreatment Team.

Table 2 Footnotes remain applicable. Table 3 Footnote “Prior to RA Only:” will be deleted and replaced with “For Contact Water”. Footnotes will be revised according to TCEQ e-mail comments sent on 9/3/2015 .

1.B.2 General Since Tables 2 and 3 are important enough to cite in this Addendum, it is recommended that Tables 2 and 3 (i.e., the Tables currently under review by the TCEQ) be included in Addendum No. 2. The reader should have these Tables readily available for rapid reference.

Comment Acknowledged. Revised Tables 2 and 3 will be added to the Addendum No. 2.

Table 2 Specific Table 2: Discharge Limits for Storm Water (dated March 11, 2014, Revision 1). There are no changes/revisions required for Table 2 (attached).

Comment Acknowledged.

Table 3 Specific Table 3: VOC & SVOC Parameters (dated March 11, 2014, Revision 1). Based on the review conducted by the TCEQ Stormwater and Pretreatment Team, the following corrections/revisions are necessary (refer to Table 3, attached), which show the corrections/notation (in red).

- Cyanide/Daily Maximum (ug/L): change from 420 to 1200

- Dichloroethane, 1,2- Daily Maximum (ug/L): change from

Revisions to Table 3 will be made per TCEQ comment.

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500 to 574

- ADD the following FOOTNOTE/REFERENCE at the end of Table 3, Page 2:

“Method and MALs are found in the TCEQ’s Procedures to Implement the Texas Surface Water Quality Standards, June 2010”

“Daily maximum values are found in 40 CFR 414.101, Subpart J – Direct Discharge Point Sources That Do Not Use End-of-Pipe Biological Treatment”

1.C.1 Specific Item #1 (Page 3/6 revised). Reference is made to runoff flow across the site, drainage ditches, a sump thence discharge off-site to Campbell’s Bayou. Please include a site drainage/discharge point reference map.

A Figure showing the site drainage/discharge point will be added.

1.C.2.a Specific C.2. Item #2/Paragraph 2 (Page 3/6).

Sentence 1 (revised document): The revised sentence differs from the original draft document and does not show the strike out of the phrase “…than the non-contact stormwater.” Please verify.

The sentence will be revised to read: “The removal of uncontaminated groundwater from the borrow area is expected to be an ongoing process throughout the Remedial Action.”

1.C.2.b Specific Reference is made to the statement, “If the concentrations are below 85% of the Table 3 levels, then sampling and analysis for Table 3 parameters will cease.” Question: Sampling and analysis for Table 3 parameters will cease for how long? What is a minimum Table 3 sampling and analysis frequency? What circumstance(s) would trigger the re-sampling of Table 3 parameters?

For Non-Contact Borrow Pit Area water, Table 3 parameters will be sampled quarterly and Table 2 will be sampled monthly. The reference to “If the concentrations are below 85%” will be removed. The sampling frequency discussed above will be added to Table 3 footnotes.

1.C.2.c Specific Reference is made to non-contact water with potentially elevated TSS levels and subsequent Table 2 COD exceedances. Please indicate the sampling/analysis frequency for TSS and COD levels (Table 2), over time, to verify compliance prior to discharge.

Table 2 will be sampled monthly and Table 3 will be sampled quarterly to verify compliance for non-contact water discharged from the borrow pit area. The sampling frequency discussed above will be added to Table 2 and 3 footnotes.

There are three categories (sources) of water being managed under this stormwater management plan (not including the extracted groundwater). These categories are described below.

Site Borrow Pit Area Water: This water will include storm water collected within the excavation area of the borrow pit and uncontaminated groundwater flowing into the borrow pit. This Site Borrow Area Water will be sampled quarterly for Table 3 and

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monthly for Table 2. To date, Site Borrow Area Water analysis has showed no discharge criteria exceedances and no elevated TSS. TSS analysis was performed by the MCP for information purposes, but it is not a discharge criteria listed in Table 2 or 3.

Site Non-Contact Water: Per the EPA and TCEQ approved ENTACT SWMP Revision 1, dated 3/11/14, page 5, “The second category is “Non-Contact Water”, which is defined as storm water that originates from areas of the site that are not in contact with known waste streams (previously defined as Non-Specified Areas). Non-contact storm water will continue to runoff flow across the Site, collect in the existing drainage ditches and laterals for conveyance to a discharge collection sump for ultimate discharge off site to Campbell’s Bayou”.

Discharge of Non-Contact water without analysis has been previously approved, is consistent with past operating regulations and is essential to the quick removal of accumulated water to resume Remedial Action activities and avoid lengthy schedule delays associated with sampling and waiting for analysis results.

Site Contact Water: The majority of contact water will be disposed through on-site deep well injection. Though highly unlikely, contact stormwater with no visible oil can be analyzed for Tables 2 and 3 to determine if discharge to Swan Lake is acceptable. In no event will contact storm water be discharged from the site if the concentration of any one constituent for the sample exceeds the Daily Maximum.

2. Specific WDW PTS Operational Assumptions (Pages 3/6-4/6, revised). In paragraph 1, reference is made to “existing permits”. Are there any existing permits in-place? If not, please briefly cite the regulatory controls that apply to the design/operation of WDW-73 and WDW-138.

Due to the site’s CERCLA designation there are no existing permits in place, though both injection wells are operated under the historical permitting parameters (i.e. maximum injection pressure, maximum injection volumes, pH, specific gravity, annual testing). The operation of the injection wells will be conducted under EPA’s Explanation of Significant Difference (ESD) which is currently being prepared for approval. Prior to the ESD, the wells will operate under EPA’s Emergency Authority.

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3. Specific Use of Storm Events for Remedial Action Planning and Design (Page 4/6). For my reference and information only, how did the recent storm events this past May – June 2015 rank against the planning/evaluation criteria discussed in paragraph 1/Attachment 1?

Fortunately, over the period in question, the Site only received minor rainfall as in comparison to the general Houston area and satisfactory freeboard levels were maintained.

4. Specific Best Management Practices (Page 5/6; 4th bullet). Reference is made to the additional BMPs, such as a temporary cover (e.g., spray-on cover over waste) to minimize contact stormwater. The TCEQ concurs with the interim cover BMP provision; however, does the MCP have an SOP or protocol defined for the placement of an interim cover over the active area, a performance standard (e.g., for a spray-on cover or other type of cover) and criteria for application (e.g., 24 hours prior to predicted storm event)?

The MCP will be conducting a field pilot study to test 3 different spray application products ability to prevent or minimize contact stormwater. Once the pilot study is completed a product will be selected and an SOP for application prepared and provided to EPA and TCEQ.

5. Specific Summary (Page 6/6; paragraph 2). Reference is made to the situation when all contact water cannot be disposed through the WDW PTS, the heavily and lightly impacted storm water may be discharged. Please clarify, does this statement mean that the various categories of contact water will be blended to achieve the allowable discharge limit(s)? If so, is additional sampling and analysis anticipated in order to verify that the discharge limits are not exceeded? Please explain, because this circumstance appears to be last option/contingency for the accumulated contact water prior to discharge.

In a worst case scenario, the potential to blend with non-contact storm water with contact water may be explored to meet discharge criterion. No contact water will be discharged to Swan lake without analysis meeting the approved discharge limits.

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Storm Water Management Plan Addendum No. 2-Revised

Introduction

The Malone Cooperating Parties (MCP) developed this Addendum #2 to the March 2014 Storm Water Management Plan (SWMP) (ENTACT 2013) and Addendum #1 (ENTACT 2014) for supplemental controls and practices to be implemented during the Phase Two Remedial Action at the Malone Service Company Superfund Site (Site) in Texas City, Texas. The intent of the addendum is to identify Best Management Practices (BMPs) that, when implemented, will minimize contact storm water requiring treatment and maximize the beneficial use of the two recently rehabilitated Waste Disposal Wells (WDWs) at the site. Actual implementation of any individual BMP will be determined in the field based on actual or anticipated conditions.

The BMPs discussed below are supplemental to those discussed in the SWMP (ENTACT 2014) and in general have been designed to achieve the following:

Normalize the operation of the WDWs through equalization so it operates more consistently over an extended period.

Assure the optimal injectivity of the injection wells through the installation of a WDW Pre-Treatment System (PTS). This system is known collectively as the WDW PTS.

Minimize potential delay in the active remediation sequencing (i.e., pump water out of active areas as soon as possible to allow those areas to dry so the Contractor can resume remediation activities).

Minimize time that precipitation will be in contact with impacted materials by using storage impoundments (i.e., remove precipitation that may pond in areas such as the landfill or sludge areas as soon as possible).

Install a temporary cover, such as, a spray-on cover over wastes in open areas of the landfill to minimize the volume of impacted stormwater.

Sequence construction activities and implement diversion measures in a manner that minimizes the impacted surface area exposed (and therefore minimizes the volume of impacted stormwater).

Continue to use existing stormwater management tools that promote evaporation or infiltration without collection.

To develop these additional strategic BMPs and provide a basis for the size of the equalization impoundment, the MCPs reviewed the SWMP (ENTACT 2014), climatological data for the Texas City/Galveston area, site topographic features, and the overall storm water management strategy. The MCP also considered other factors, including the fact that both WDWs were rehabilitated to improve the effectiveness and capacity of the injection well system for disposal of impacted groundwater and contact storm water, and the relatively short timeframe of the overall project.

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Overall Storm Water Management Strategy

As detailed in the SWMP (ENTACT 2014), two categories of water have been established at the Site. The first category, “Contact Water,” is water that comes in contact with known waste materials. The second category, “Non-Contact Water,” is water that originates from areas of the site that are not in contact with known waste streams. The following paragraphs describe the general strategy for each category.

Contact Water

As part of the Phase Two remedial activities, portions of the Site are scheduled to be excavated and capped to address contaminated soils. Excavated soils will be placed in an onsite landfill and capped. Sludge at the Site will be solidified and also be placed in the onsite landfill and capped. The landfill will be constructed simultaneously with the work in a series of progressive steps. During the course of this Phase Two work, three sources of contaminated water that will require management/treatment and disposal are anticipated to be produced from the Site as categorized below:

1. Groundwater dewatering water: In order to produce a dry and safe work area for solidification the groundwater table will be drawn down through dewatering points installed within the previously constructed slurry wall boundary surrounding the Sludge Pond and Oil Pit.

2. Heavily impacted storm water: This water is assumed to be ponded water and storm water that has come into contact with exposed, unsolidified or incompletely solidified impacted soil materials at the excavation and stabilization working areas.

3. Lightly impacted water: This water is assumed to be storm water that has come into contact with exposed, solidified impacted soil materials at the landfilling areas on-site.

All three types of contact water are anticipated to be disposed of through the WDWs and have been characterized through bench-scale testing.

In the unlikely event that the WDWs are unable to dispose of all the contact water, the contact storm water, Categories 2 and 3, may be discharged only after sampling as per the existing Storm Water Management Plan. If at any point the sample results indicate the constituents are present above the levels shown in Tables 2 and 3, respectively, the water will be stored in the stormwater impoundment for eventual disposal through the WDWs. Revised Tables 2 and 3 discussing sampling frequencies are attached to this Addendum.

Non-Contact Water

Non-contact storm water can be divided into the following two categories:

1. Water within the Phase Two Remedial Action working area that has been separated from contaminated material to the maximum extent practicable utilizing BMPs.

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The generation and need for discharge of non-contact water from the Phase Two Remedial Action working area will generally occur after large rainfall events. As a result, the need to discharge this water will be sporadic. As discussed in the current approved SWMP (ENTACT March 2014 Revision 1), non-contact storm water will continue to runoff flow across the site, collect in the existing drainage ditches and laterals for conveyance to a discharge collection sump for ultimate discharge off site to Campbell’s Bayou. Erosion and sedimentation controls will be in place prior to disturbing the soil surface, to preclude sediment transport off site. A figure has been attached to display the drainage ditches and discharge point.

2. Borrow Pit Area Water: Water that is removed from the borrow area to the east of the Phase Two Remedial Action working area. The origin of this non-contact water can be either storm water collecting within the excavation of the borrow pit or uncontaminated groundwater flowing into the borrow pit excavation. This water will be pumped over the levee and discharged into Swan Lake.If needed to mitigate erosion, an energy dissipator will be installed at the discharge point.

The removal of uncontaminated groundwater from the borrow area is expected to be an ongoing process throughout the Remedial Action As a result, upon initiating discharge, the water will be sampled monthly for the parameters in Tables 2 and sampled quarterly for Table 3 prior to the discharge event. This non-contact water could potentially have a high Total Suspended Solids (TSS) content since the ground surface will be disturbed. This could result in the Chemical Oxygen Demand (COD) level in Table 2 to be exceeded. Should the COD level exceed Table 2 levels, this water will be pumped through a trailer-mounted bag filter for solids removal and then resampled for COD. Should the COD levels be within the limits of Table 2, the water will be discharged into Swan Lake.

WDW PTS Operational Assumptions

The WDW PTS will be designed and operated such that WDW injectant can comply with the existing permits and regulatory controls established for WDW-73 and WDW-138. In addition, the WDW PTS will reduce the solids content of the injected waters, thereby protecting the injectivity of the wells. The current regulatory limits for the each WDW are as follows:

• pH of injected waste stream shall not be less than 4.5 nor greater than 12.0

• The density of injected fluids specific gravity shall not be below 1.0 or exceed 1.07

• Maximum rate of injection shall not exceed 200 gpm for each WDW

• Maximum permissible volumetric injection rate at WDW-138 is 4,320,000 gallons per month (100 gpm over 30.4 days)

• Maximum permissible volumetric injection rate at WDW-73 is 3,240,000 gallons per month (75 gpm over 30.4 days)

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• Operating surface injection pressure shall not exceed 1300 psig for WDW-73 and 1100 psig for WDW-138 and must maintain an annulus pressure at a minimum of 100 psi over the injection pressure.

Additionally, the EPA has approved and the Record of Decision (ROD) for the Site indicates that impacted water from the Site associated with groundwater dewatering and storm water management is allowed to be disposed of via the on-site WDWs.

Use of Storm Events for Remedial Action Planning and Design

The objective of the PTS is to adequately pre-treat and inject the contact water into the WDWs at a rate that will help minimize construction delays for the proposed earthwork, stabilization and landfill activities. The PTS has been evaluated based on several storm event scenarios (i.e. 2-year, 5-year, 25-year and 100-year storm events), landfill coverage (i.e. 0%, 25%, 50% and 75%) and storm water impoundment size [i.e. 4 million gallons (MG), 6MG and 8MG] to balance construction delay costs vs. treatment system costs. The evaluation is presented in Attachment 1. The system selected will minimize downtime to the extent practicable. However, unusual storm events (e.g. 100 year storm) may result in construction delays.

Based upon the evaluation, the MCP will install a WDW PTS which can handle flow of up to 400 gpm, utilize temporary spray on cover lines to minimize stormwater contact with impacted materials as necessary, and to construct a 6 MG storm water impoundment at the Site.

WDW PTS Process Overview

Treatment processes have been preliminarily identified to achieve the treatment system objectives and regulatory compliance at the operating conditions. Attachment 2 contains a contact water management flow chart.

Preliminary dewatering modeling was performed for the area within the slurry wall that encloses the stabilization areas. The modeling produced an estimate of the total extractable volume of groundwater, initial dewatering flow rate, duration of significant dewatering, and prediction of the time frame at which the expected dewatering rate should begin to diminish. The modeling estimated that dewatering will take approximately 5 months to complete (excluding some leakage through the slurry wall), with an expected flow rate of approximately 75 gpm for the first 2 months. Current modeling shows a dramatic decline in flow rate after this initial period; between 90 and 120 days after initialization of dewatering activities, the flow rate is expected to approach 5 gpm or less. As a result, during the first 60 days of dewatering, the API 100 separator is dedicated to the higher flows from the dewatering wells. During this time, the heavily impacted contact water from the in-situ solidification (ISS) area will be routed to one of the two chambers of the 6 million gallon impoundment. However, after the decline in dewatering water production, the heavily impacted contact water from the ISS area can also be routed directly to the Unit 100 API separator.

Attachment 3 contains the process flow diagram. Prior to treatment, the influent to the WDW PTS will be stored in either the Unit 100 API separator or the 6 MG impoundment for equalization and storage. A plan view of the impoundment is shown in Attachment 4.

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The treatment process will be designed for a maximum flow rate of 400 GPM and will be designed to remove solids (dissolved and suspended) to maintain a specific gravity below 1.07 and amend high pH conditions to meet regulatory requirements. To reduce the potential for WDW fouling due to precipitation, pH is anticipated to be adjusted to near neutral (approximately 7.5). These criteria will be met by the addition of coagulants and flocculants to promote solids removal and hydrochloric acid to lower pH. After coagulant and flocculant addition, process water will pass through a clarifier for solids separation. Settled solids will be drawn from the bottom of the clarifier, thickened, and transported to the stabilization working areas for stabilization and then placement within the on-site landfill. Following solids separation, the pH of the process water will be adjusted to neutral level via gaseous hydrochloric acid addition. After that, the process water will go through bag filter to capture additional solids in water stream. Finally, the WDW PTS will discharge its treated effluent to the Unit 1200 API separator, which will store the pretreated process water prior to injection into the WDWs.

Best Management Practices

The SWMP (ENTACT 2014) includes the following BMPs which are currently planned to be implemented at the site:

• Good housekeeping program

• Employee training

• Periodic site inspections

• Proper discharge of storm water

In addition to these BMPs, the following additional BMPs were identified as potentially beneficial during the Phase Two RA. If implemented, the following BMPs will reduce the potential volume of contact storm water being generated:

Provide means for collection of precipitation from unused portions of the completed landfill cell when that portion of the cell will not be placed in service for a significant period of time.

Install a permanent cover when possible over portions of the landfill when a sufficient area has been brought to final grade.

Install a temporary cover, such as, a spray-on cover over wastes in open areas of the landfill before a permanent cover is placed.

Sequence activities in a manner that minimizes the impacted surface area exposed through strategic construction sequencing, including sequencing filling and construction in the landfill to minimize the potential contact area to be exposed.

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Optimize current discharge volumes at permitted injection wells WDW#73 and WDW#138 to accommodate both dewatering water disposal and supplemental contact water disposal.

Diversion Measures

Water diversion measures are used to improve water quality by keeping contact water separate from clean areas with noncontact water. The landfill will be constructed in four distinct phases. Separating each phase will be an interphase berm as shown in Attachments 5 and 6. The purpose of these interphase berms are to separate a phase of the landfill where waste is being placed from an adjacent phase of the landfill that still has not received waste material. As a result, this will result in segregation of contact water from non-contact water.

During solidified sludge placement, materials will be placed in a manner that minimizes the accumulation of storm water by controlling grade and allowing contact storm water to drain towards the sumps and laterals installed during the RCRA cell construction or towards localized sumps to facilitate removal. Prior to anticipated precipitation events, solidified sludge located within the cell will be compacted utilizing a smooth-drum roller to minimize infiltration and areas where water can accumulate.

Additionally, the use of sand bags or water-filled barriers will provide a temporary/ portable dam or barrier that can be positioned to contain or divert the movement of storm water. These barriers will be installed adjacent to, and upgradient and downgradient of remediation areas. Collection sump areas must be constructed within the containment area to pump contact water to the treatment system or injection wells. Protected outlets/discharge areas or similar collection sump areas will be planned in advanced to control noncontact water.

Summary

The generation of contact water will be minimized by the implementation of BMPs and by diversion. It is intended that all contact water be disposed of through the WDWs. The WDW PTS is designed to protect the injectivity of the wells. It is sized to manage a reasonable storm (5-year storm event), minimizing downtime for Site RD/RA operations. Effectiveness will vary with injection rates achieved, landfill cover area to minimize contact stormwater. A 6 million gallon water impoundment will be constructed for temporary storage of water.

In the event that all contact water cannot be disposed through the WDW PTS, then the heavily and lightly impacted storm water will be sampled and, after verification of meeting the discharge criteria, discharged according the existing Storm Water Management Plan.

Non-contact water will be discharged to Swan Lake as needed. Borrow Pit Area water will be analyzed monthly for Table 2 parameters and quarterly for Table 3 parameters.

Reference

ENTACT. 2014. Stormwater Management Plan.

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Table 2: Discharge Limits for Storm Water Parameter Daily Maximum

(mg/L) Sample Frequency Sample

Type

Oil & Grease 15 Once in each unit prior to discharge Grab

pHBetween 6-9

standard units Once in each unit prior to discharge Grab

COD 150 Once in each unit prior to discharge Grab Visible Oil Sheen None Once in each unit prior to discharge Grab Arsenic, total 0.3 Once in each unit prior to discharge Grab Barium, total 4.0 Once in each unit prior to discharge Grab Cadmium, total 0.3 Once in each unit prior to discharge Grab Chromium, total 5.0 Once in each unit prior to discharge Grab Copper, total 2.0 Once in each unit prior to discharge Grab Lead, total 1.5 Once in each unit prior to discharge Grab Manganese, total 3.0 Once in each unit prior to discharge Grab

Mercury, total 0.01 Once in each unit prior to discharge Grab

Nickel, total 3.0 Once in each unit prior to discharge Grab Selenium, total 0.3 Once in each unit prior to discharge Grab Silver, total 0.2 Once in each unit prior to discharge Grab Zinc, total 6.0 Once in each unit prior to discharge Grab The water discharged shall not contain floating solids, visible oil, or visible foam in other than trace amounts. Samples for metals analyses will not be filtered. Non-Contact Water:

1. No analysis is needed prior to discharge to Campbell’s Bayou 2. If contact water mixes with non-contact water Table 3 parameters will be sampled

Borrow Pit Area Water: 1. Borrow Pit Area Water will be analyzed monthly and results compared to Tables 2 prior to

discharge to Campbell’s Bayou 2. Borrow Pit Area Water will be analyzed quarterly and results compared to Table 3 prior to

discharge to Campbell’s Bayou Contact Water:

1. Contact Water analysis not required prior to injection. 2. Contact Water shall be analyzed and results compared to Tables 2 and 3 prior to any

discharge event to Campbell’s Bayou 3. If the concentrations of Table 3 parameters are below 85% of the Table 3 levels, then

sampling and analysis for Table 3 parameters will cease for 3 months for that stream of water.

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Table 3: VOC & SVOC Parameters

Constituent CAS No. MethodDaily Maximum

( g/L)MAL ( g/L)

Cyanide 57-12-5 335.3 1200 20 Acrylonitrile 107-13-1 624 232 50 Benzene 71-43-2 624 134 10 Carbon tetrachloride 56-23-5 624 380 10 Chlorobenzene 108-90-7 624 380 10 Chloroethane (ethyl chloride) 75-00-3 624 295 10 Chloroform 67-66-3 624 325 10 Chloromethane 74-87-3 624 295 20 Dichlorobenzene, 1,2- 95-50-1 624 794 10 Dichlorobenzene, 1,3- 541-73-1 624 380 10 Dichlorobenzene, 1,4- 106-46-7 624 380 10 Dichloroethane, 1,1- 75-34-3 624 59 10 Dichloroethane, 1,2- 107-06-2 624 574 10 Dichloroethylene, 1,1- 75-35-4 624 60 10 Dichloroethylene, trans-1,2 156-60-5 624 66 10 Dichloropropane, 1,2- 78-87-5 624 794 10 Dichloropropene, cis 1,3- 10061-01-5 624 794 10 Dichloropropene, trans 1,3- 10061-02-6 624 794 10 Ethyl benzene 100-41-4 624 380 10 Methylene chloride (dichloromethane) 75-09-2 624 170 20 Tetrachloroethylene 127-18-4 624 164 20 Toluene 108-88-3 624 74 10 Trichlorobenzene, 1,2,4- 120-82-1 624 794 5Trichloroethane, 1,1,1- 71-55-6 624 59 10 Trichloroethane, 1,1,2- 79-00-5 624 127 10 Trichloroethylene 79-01-6 624 69 10 Vinyl chloride 75-01-4 624 172 10 Acenaphthene 83-32-9 625 47 10 Acenaphthylene 208-96-8 625 47 10 Anthracene 120-12-7 625 47 10Benzo(a)anthracene 56-55-3 625 47 10Benzo(a)pyrene 50-32-8 625 48 10 Benzo(b)fluoranthene 205-99-2 625 48 10

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( g/L)MAL ( g/L)

Benzo(k)fluoranthene 207-08-9 625 47 10 Bis (2-ethylhexyl) phthalate 117-81-7 625 258 10 Chrysene 218-01-9 625 47 10 Diethyl phthalate 84-66-2 625 113 10 Dimethyl phenol, 2,4- 105-67-9 625 47 10 Dimethylphthalate 131-11-3 625 47 10 Di-n-butyl phthalate 84-74-2 625 43 10 Dinitro-2-methylphenol, 4,6- (dinitro-o-cresol, 4, 6-)

534-52-1 625 277 NA

Dinitrophenol, 2,4- 51-28-5 625 4,291 50 Fluoranthene 206-44-0 625 54 10 Fluorene 86-73-7 625 47 10 Hexachlorobenzene 118-74-1 625 794 10 Hexachlorobutadiene 87-68-3 625 380 10 Hexachloroethane 67-72-1 625 794 20 Naphthalene 91-20-3 625 47 10 Nitrobenzene 98-95-3 625 6,402 10 Nitrophenol, 2- 88-75-5 625 231 20 Nitrophenol, 4- 100-02-7 625 576 50 Phenanthrene 85-01-8 625 47 10 Phenol 108-95-2 625 47 10 Pyrene 129-00-0 625 48 10

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( g/L)MAL ( g/L)

-MAL – Minimum Analytical Limit -Methods for the Chemical Analysis of Water and Wastes, 40 CFR 136 -In no event will storm water be discharged from a unit if the concentration of any one constituent for the sample from the unit exceeds the Daily Maximum. -Method and MALs are found in the TCEQ’s Procedures to Implement the Texas Surface Water Quality Standards, June 2010 -Daily maximum values are found in 40 CFR 414.101, Subpart J – Direct Discharge Point Sources That Do Not Use End-of-Pipe Biological Treatment” Non-Contact Water:

1. No analysis is needed for discharge to Campbell’s Bayou 2. If contact water mixes with non-contact water Table 3 parameters will be sampled

Borrow Pit Area Water: 1. Table 2 will be analyzed monthly prior to discharge to Campbell’s Bayou 3. Table 3 will be analyzed quarterly prior to discharge to Campbell’s Bayou

Contact Water:1. Contact Water analysis not required prior to injection. 2. Contact Water shall be analyzed and results compared to Tables 2 and 3 prior to any

discharge event to Campbell’s Bayou 3. If the concentrations of Table 3 parameters are below 85% of the Table 3 levels, then

sampling and analysis for Table 3 parameters will cease for 3 months for that stream of water.

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Attachment - Estimated Downtime EvaluationBasis of DesignMalone Superfund Site, Texas City, Texas

AssumptionsAreasLandfill (SF) 1,306,800 Sludge Pit (SF) 200,000 Oil Pit (SF) 38,000 In-situ Stabilization Working Area (SF) 78,000

Flow rate into WDWs (gpm)140 assuming 80% efficiency of WDWs (full efficiency of 175 gpm)

Groundwater dewatering rate (from within Slurry Wall) (gpm)10 assuming an average dewatering rate of 10 gpm during landfill work

Storage capacity (gal)7,000,000 6MG Impoundment plus approximately 1MG of API 100 storage capacity

6MG Impoundment and PTS

Average Month a Avg Month% Landfill

Cover

Landfill Stormwater Capture Volume

(gal)

100% Stabilization Working Area + Sludge/Oil Pit Areas Stormwater

Capture Volume b

(gal)

Total Stormwater (Landfill + Stabilization Working Area +

Sludge/Oil Pit Areas) Capture Volume (gal)

Downtime - (equal to operating WDW injection

at 140 gpm 24 hr/day)3.61-inches 0% 2,940,809 711,123 3,651,933 0.0

25% 2,205,607 711,123 2,916,730 0.0

50% 1,470,405 711,123 2,181,528 0.0

75% 735,202 711,123 1,446,326 0.0

Optimistic 2 yr storm% Landfill

Cover


(gal)


Capture Volume b

(gal)




at 140 gpm 24 hr/day)5.5-inches 0% 4,480,457 1,083,429 5,563,886 0.0

25% 3,360,343 1,083,429 4,443,772 0.0

50% 2,240,229 1,083,429 3,323,657 0.0

75% 1,120,114 1,083,429 2,203,543 0.0

Most Likely 5 yr storm% Landfill

Cover


(gal)


Capture Volume b

(gal)





25% 4,398,995 1,418,307 5,817,301 0.0

50% 2,932,663 1,418,307 4,350,970 0.0

75% 1,466,332 1,418,307 2,884,638 0.0

Reasonable Worst Case 25 yr storm

% Landfill Cover


(gal)


Capture Volume b

(gal)





25% 6,293,006 2,028,966 8,321,973 7.1

50% 4,195,337 2,028,966 6,224,304 0.0

75% 2,097,669 2,028,966 4,126,635 0.0

100-yr Storm 100 yr storm% Landfill

Cover


(gal)


Capture Volume b

(gal)





25% 8,248,115 2,659,325 10,907,440 20.9

50% 5,498,743 2,659,325 8,158,068 6.2

75% 2,749,372 2,659,325 5,408,696 0.0

Notes:gpm - gallon per minuteMG - million gallonsSF - square feetWDW - waste disposal wella. Average month rainfall data was calcuated based upon the average annual rainfall data (Jan, Feb through Dec), which were averaged from NOAA's past 30 years rainfall data.b. 100% of the in-situ stabilization (ISS) working area and sludge/oil pit areas is assumed for calculating stormwater capture volume within the slurry wall.

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011670

Heavily Impacted Contact Water (HICW) – During approx.1st two months of dewatering?

(Yes or No)

Groundwater Dewatering Water

Lightly Impacted Contact Water (LICW)

Send to API 100

Is there an upcoming event so that the

impoundment needs to be pumped down?

Is there additional storage capacity in

API 100?

Send to LICW Compartment in Impoundment

Send to PTS

Store water in Impoundment

Send to HICW Compartment in Impoundment

Send water to API 1200 for WDWs Injection

Store Water in API 100

Are the WDWs exceeding their permitted flow

limits?

Does the water meet permit limitations?

No

Yes

Yes

No

Yes

No

No

Yes

Yes

Recirculation Back to PTS Influent

No

Water Management Flow Chart

011671

011672

EXTENT OF PRE-TREATMENT SYSTEM WITH A CAPACITY OFMAX. FLOW OF 400 GPM

FIGURE

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MALONE SERVICE COMPANY SUPERFUND SITETEXAS CITY, TEXASPHASE 2 RD/RA

011673

011674

011675

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011676

011677

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011678

011679

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UHER SYSTEM DElAILS II

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Documents

[APPENDIX D- STORM WATER MANAGEMENT PLAN …November 12, 2015 CO001908.0002 Subject: Appendix D – Storm Water Management Plan Addendum No. 2-Revised On behalf of the Malone Cooperating