memorandum ckmhiu. to: margaret guerierro/u.s. epa · cvo65594.cv.fr condition of the tanks and...

M E M O R A N D U M

l i a U O O U U 4 8

CKMHIU.

TO: Margaret Guerierro/U.S. EPA

COPIES: Michael McCann/CH2M HILLJoseph Danko/CH2M HILLBob Binda/CH2M HILLNan Leeman/MDNRBeth O'Brien/MDNR

FROM: Paul Boersma/CH2M HILL

DATE: February 18, 1991

SUBJECT: Tank Removal at the Thomas Solvent Raymond Road Site

PROJECT: CVO65594.CV.FR

INTRODUCTION

From January 7 to January 18, 1991, 21 underground storage tanks were excavated,decontaminated, and removed from the Thomas Solvent Raymond Road source area.This technical memorandum summarizes the work that was completed as part of thatfield effort.

PROJECT PERSONNEL

The tank removal was managed by CH2M HILL. CH2M HILL personnel included:

Mike McCann—Site ManagerPaul Boersma—Construction ManagerBob Binda—Site Safety OfficerDave Shekoski—Air Sampling Management

Terra Vac, Inc., was the subcontractor for the tank removal, and City EnvironmentalContracting conducted the work for Terra Vac. Tom Nolan of Terra Vac directedthe tank removal. Allison Albee and Neal Rubin, also of Terra Vac, directed sitesafety for the subcontractors.

M E M O R A N D U MFebruary 18, 1991CVO65594.CV.FR

OVERVIEW OF THE TANK REMOVAL

The field crew mobilized on Monday, January 7. Tank 1 was removed January 8;tanks 2 through 5 were removed on January 9; tanks 6 through 9 on January 10;tanks 14 through 18 on January 11; tanks 10 through 13 on January 14; and tanks 19through 21 on January 15. The rest of the second week was spent decontaminatingthe tanks and hauling them offsite to a scrap yard for cutting and disposal. Figure 1shows the location of each tank as recorded in the field during the tank removal.

The tanks were removed according to the following procedure:

• The tanks were purged for a few hours with the vapor extraction systemto volatilize remaining liquids and to remove organic vapors. Mosttanks were initially purged by Terra Vac during December.

• An excavation was made to the depth where the cover soil was removedand explosimeter and organic vapor readings could be obtained.Explosimeter readings did not exceed 10 percent of the lower explosivelimit in any of the tanks. Tanks with higher concentrations of organicvapors (more than 100 ppm) were purged again with the vaporextraction system just before removal.

• The tanks were pulled from the ground and moved onto or near thedecontamination pad. The number of each tank was painted onto it.

• ,Holes were cut in both ends of each tank to allow visual inspection ofthe interior. The exteriors and interiors of the tanks were washed witha steam cleaner until they were free of soil. Rinse water from insidethe tanks was vacuumed out with the vapor extraction system.

• The tanks were placed on a flatbed trailer and hauled to a scrap yardwhere they were cut for scrap metal.

Once the tanks were removed, the site was graded to restore the ground contoursaround the site. One hundred and twenty cubic yards of sand was imported to thesite to restore the proper grade.

A photographic record was made of all aspects of the tank removal.


FINDINGS DURING THE TANK REMOVAL

Based on previous field work, it was suspected that additional tanks were presentnear tank 1 and just east of the monitoring building. Tank 1 was rotated almost 90°from what was shown on historical site records. The rotation of tank 1 may have ledto the assumption that there was an additional tank buried adjacent to tank 1. Theactual position of tank 1 is shown in Figure 1. Two exploratory trenches wereexcavated between the monitoring building and tank 14, but no other tanks werefound.

The dimensions of each tank were recorded after removal. The actual dimensions ofthe tanks corresponded to the tank volumes as listed in the site records.

During the excavation of tanks 1, 2, and 3, the HOPE piping and electrical conduit toextraction wells 5 and 7 were severed. The electrical conduit to extraction well 6 wasalso damaged and possibly severed. The groundwater extraction system was offduring the tank excavation, and extraction wells 5, 6, and 7 will remain off until theHDPE piping and electrical conduit are repaired.

Abandoned concrete footings were encountered during the excavation of tanks 14, 16,17, and 18. The footings were removed, washed with the steam cleaner, andstockpiled on the west side of the decontamination pad. The concrete will bedisposed of once a decision is made regarding its appropriate disposal.

Tank 21 was partially buried under the SVE process building. About 3 feet of thenortheast corner of the building was undermined during the tank removal, but nostructural damage to the building occurred. The bottom of tank 21 was covered withscale, rust, and possibly some residual sludge. As the material was removed, theorganic vapors near the material measured 300 ppm; thus a decision was made by theconstruction manager to drum the material for disposal. The material filled one anda half 55-gallon drums. The other tanks were relatively free of sludge, scale, or otherloose material.

Based on the thickness of the steel and the rivet construction, tank 1 appeared to bedesigned as an aboveground storage tank.


CONDITION OF THE TANKS AND SOIL

All tanks were visually inspected for holes or other damage after they were removedfrom the ground. Holes or other damage were not observed on any of the tanks.However, it should be noted that overall pitting of the tanks was observed, andsmaller holes could easily go undetected by visual inspection.

The soil underneath each tank was visually inspected. In some excavations, thebackhoe brought up a bucket of soil from the bottom of a pit so that it could bechecked with an HNu or OVA. Visible soil contamination was not noted around orunder any of the tanks, nor were organic vapors detected with the HNu or OVA.Most excavations ranged in depth from 10 to 12 feet. During excavation of tanks 1,2, 19, 20, and 21, the depth of excavation was 12 to 15 feet.

DISMANTLING THE SVE SYSTEM

Much of the existing vapor extraction system had to be dismantled before the tankswere excavated. Figure 1 presents the vapor extraction wells and header piping thatremained after the tank removal work. Vapor extraction wells 17, 18, and 20 werepartially destroyed during the tank removal, but can probably be salvaged. Othervapor extraction wells were completely destroyed. Five hundred twenty-four feet ofvapor extraction header piping was also removed. The electrical service bringingpower to the catalytic oxidation unit had to be dismantled to remove tanks 19, 20,and 21. Temporary service was installed to supply power to the catox unit.

AIR SAMPLING DURING TANK EXCAVATION

Because of the potential for a VOC release to the atmosphere, air monitoring wasconducted throughout the tank removal and tank washing activities. An airmonitoring plan was designed and implemented that included hourly sampling aroundthe perimeter fence using an OVA and daily sampling with tenax tubes. Carbonmolecular sieve (CMS) tubes were also used once a week. The tenax and CMS tubeswere located at the upwind and downwind fence line positions and were calibrated tocollect a continuous sample of air during each day. These samples were used toassess whether MDNR air quality action limits were being surpassed. Robert Teoh ofthe MDNR Air Quality Division reviewed the sampling plan before sampling beganand visited the site twice during the tank removal to observe air monitoring activities.


At no time were any organic vapors detected with the OVA at the fence line. BothCH2M HILL and Terra Vac monitored breathing zone concentrations at the edge ofthe excavation. No detections of organic vapors were made in the breathing zone.

The analytical results from the tenax and CMS tubes showed that most VOCconcentrations did not exceed their action limits. In some cases, tetrachloroetheneand trichloroethene exceeded the action limits, but the MDNR felt that the releaseswere sufficiently low that no additional VOC control measures were required duringtank removal. Air samples collected between the body shop to the south of the siteand the site itself indicated that the body shop may have been responsible for someof the VOC detections. Table 1 summarizes the analytical results for the air samples.More thorough documentation of air sampling activities and results is presented in aseparate technical memorandum.

During tank purging, Terra Vac sampled the emissions from the catalytic oxidationunit and did not detect any VOCs.

CERTIFICATION OF TANK DESTRUCTION

All tanks were taken to the Schupan and Sons Scrap Yard in Kalamazoo, Michigan.Attachment A presents the certificates of destruction for each of the 21 storage tanks.On January 16, Bob Binda of CH2M HILL followed the tanks to the scrap yard toobserve and photograph their handling. These photographs are included as part ofthe photographic log.

SUMMARY OF ACTIVITIES

All 21 tanks were removed from the ground as planned, cleaned, and disposed ofoffsite as scrap metal. No additional tanks were found during the excavation. Thesite soil appeared free of visible contamination. VOC releases were minimized to theMDNR's satisfaction.

Remaining work as part of this effort includes disposing of the concrete, disposing ofthe drummed material, fixing the HDPE piping and electrical conduit associated withextraction wells 5, 6, and 7, and reinstalling the SVE system. These activities areexpected to be completed by the end of February. The SVE system is expected to beoperating by February 15.

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FIGURE 1UNDERGROUND STORAGE TANKS AND REMAINING SVE SYSTEM

AT THOMAS SOLVENT RAYMOND ROAD SITEVERONA WELL FIELD

BATTLE CREEK, MICHIGAN

Thomas Solvents - Raymond Road Air Sampling ResultsBattle Creek, MlAll are Tenax results except where notedReported as ug/m3

TABLE 1

MDNRTenax Air ActionConstituents Level1,1-Dichloroethene1,1-Dichloroethanetrans-1 ,2-DichloroethenChloroform 0.041,2-Dichloroethane 0.092-Butanone(MEK)1,1,1-TrichloroethaneCarbon Tetrachloride 0.04Trichloroethene 0.6Benzene 0.144-Methyl-2-PentanoneTetrachloroethene 1.7TolueneEthylbenzeneXylene (mixed)Methylene chloride (f,g) 1Vinyl chloride (f) 0.4

Day 11-8-91

Upwind Downwind(a,b)

-----

0.85 1.581.42 1.870.65

0.641.71 2.591.990.65 4.043.27 4.460.67 0.942.56 4.28n/a n/an/a n/a

Day 21-9-91

Upwind Downwind(a)

---

0.14--

3.06{h) 1.47(h)0.9

-6.04 2.22

-

0.29 0.2811.15 3.562.01 0.749.76 3.26

13.64 24.12-

Day 31-10-91

Upwind Downwind Residence(a)

---

0.14 0.23 0.18.

-0.86 1.17 0.90.67

-1.51 2.24 3.55.

0.16 1.23(d) 0.240.22 4.57 4.20.44 0.76 0.681.92 3.93 2.1n/a n/a n/an/a n/a n/a

Day 41-11-91

Upwind Downwind(a)

---

0.14 0.18

--

1.25 4.290.27

4.362.21 2.85

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0.41 18.623.31 14.510.71 2.553.15 13.05n/a n/an/a n/a

Day 51-14-91

Upwind Downwind(a,c)

Day 61-15-91

Upwind Downwind(a)

-- | -

-0.15

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1.2 3.06

-0.22

-0.572.33

0.72 1.72(e)0.21

3.39 2.9-

1.116.13 7.141.09 1.054.81 5.54

n/a n/an/a n/a

-0.2 1.15

8.49 3.22-

0.26 4.5722.63 9.055.09 1.74

24.89 8.49n/a n/an/a n/a

a. Sum of the Front lube and back lube

b. Duplicate sample taken. The average concentration is reported.

c. A downwind duplicate was taken, however one lube broke during analysis. Only the primary sample tube results are reported, except where otherwise noted.

d. Front lube 0.43; back tube 0.80

e. Primary sample tube had none detected. Duplicate results are reported, though back tube loading (if any) is unknown.

I. CMS only

g. Trip blank contamination, data questionable.

h. CMS value reported

SCHUPAN & SONS INC.2619 MILLER RD., P.O. BOX 2408KALAMAZOO, Ml 49003(616) 382-0000FAX (616) 382-4309

SCRAP METALPROCESSORS & BROKERS

January 21, 1991

Mr. Robert E. BindaCH2M HillP.O. Box 8748Boise, Idaho 83707

Dear Mr. Binda:

We have received 22 tanks from Terra Vac as of January 17, 1991

All tanks will be cut up and disposed of properly.

Joe fforiecutter/ Operations Manager

JB/ga

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memorandum ckmhiu. to: margaret guerierro/u.s. epa · cvo65594.cv.fr condition of the tanks and...

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