AliG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 8 1989 REGION II MdW DATE: SUBXCT: FROM: TO: AUG 0 9 1! Preliminary Assessment, Removal Site Evaluation, and Funding Authorization Request for a CERCLA Removal Action at the Virgin Island Chemical Company, Inc. Site, St. Croix, U.S. Virgin Islands - ACTION MEMORANDUM Douglas R. Kodama, On-Scene Coordinator Response and Prevention Branch ytr^ii^fll^ William J. Muszynski, P.E. Acting Regional Administrator 'rHRU:QiVtephen D. Luftig, DirectorQDy/vxS^^*-^^ ^ Emergency and Remedial Response Division I. EXECUTIVE SUMMARY On January 23, 1989. Mr. George Pavlou, Associate Director for Enforcement Programs, formally requested 'that the Response and Prevention Branch conduct a removal evaluation at the Virgin Island Chemical Company site in St. Croix, U.S. Virgin Islands. A preliminary assessrent, site inspection and removal site evaluation were conducted on January 31 and February 1, 1989. Unstable and reactive hazardous materials are present in a building and on the grounds at this inactive chemical plant. Unknown contaminants are migrating off-site into the adjacent soil and potentially the ground water. Hazardous substances present include chlorine and hydrogen chloride, both of which are contained in extremely deteriorated cylinders, sodium metal a water-reactive material posing a threat of fire and potassium cyanide. Other reactive materials include diisobutyl aluminum hydride (a pyrophoric liquid), phosphorus pentoxide, sodium borohydride, sodium hydride and ethyl ether (potentially shock- sensitive) . Five businesses are adjacent to the facility and the St. Croix Prison at Golden Grove is located approximately one-quarter mile downwind from the site. An air release or fire at this chemical plant could adversely affect the prison, businesses and area residents. The proposed removal action will address all above ground containerized materials and is expected to take eight to ten months to complete. The estimated project ceiling is $1,840,000 of which $1,262,000 is for mitigation contracting. 200001 SDMS Document REGION il FORM 1320-1 (9/85) 115534 -2- II. BACKGROUND A. Site Setting/Description The Virgin Island Chemical Company (VIChem) is located on Plot 13Q of Estate Bethlehem Middle Works off of the Melvin Evans Highway (Route 66) in St. Croix, U.S. Virgin Islands. Located on the south side of the island near the western end of St. Croix (Figure 1), the 3.5 acre site has a gently rolling topography ranging in elevation from 10 to 30 feet above sea level. The site is bordered on the north by an intermittent stream which originates on the north side of the island and discharges to the Caribbean Sea. Runoff from the site enters this unnamed intermittent stream. The Caribbean climate is typical of the Neotropics. Temperatures vary from 70°-95° Fahrenheit with a relative humidity in excess of 60%. Winds are fairly constant at 10-20 miles per hour and are generally from the eastern quadrant as they pass over the Caribbean Sea. Seasonal rains in winter and summer are common. Hurricanes and tropical storms may occur at any time during the year, but are more likely during the summer and fall. The surrounding area is predominantly commercial with five businesses adjacent to the site. Downwind, approximately one- quarter mile northwest of the site is the St. Croix Prison at Golden Grove (Figure 1). Several residences are located one- third mile north of the site at Upper Bethlehem and three- quarters of a mile northwest of the site at Golden Grove. South of the site (upwind) is one residence within one-tenth of a mile, a quarry, the Melvin Evans Highway and the Alexander Hamilton Airport. The site property is currently owned by the Charles H. Steffey Holding Corporation. This landowner originally leased the land on a 30 year lease to Houston Chemical Industries on May 1, 1969. On March 20, 1972, Houston Chemical assigned the lease to Caribe Chemical Company, Inc. (subsequently known as Pierrel America, Inc.). On June 30, 1978, Pierrel America assigned the ground lease to Cooper Laboratories, Inc.. On July 21, 1978, Cooper Laboratories incorporated Island Chemical Company as its subsidiary to assume its production activities at the facility. On October 30, 1979, Cooper Laboratories assigned the lease to its subsidiary. Island Chemical Company. On November 1, 1979, Cooper Laboratories sold all of the stock of Island Chemical Company to the predecessor of Berlex Laboratories, Inc. (a subsidiary of Schering-Berlin Inc.). On September 14, 1984, Berlex sold Island Chemical Company assets and assigned the lease to Virgin Island Chemical Company (VIChem). VIChem is currently inactive and attempting to sell company assets and reassign the lease. 200002 -3- Prior to 1980, it is believed that the facility was used for the manufacture of pharmaceutical chemicals, primarily phenacetin, ethoxyquin and quinidine. Berlex reportedly used this facility to make quinidine gluconate used for the production of quinine. Quinine is an antimalarial medicine and flavoring in carbonated beverages. VIChem produced benzyl acetate by reacting benzyl chloride with acetic acid. Benzyl acetate is used in perfumes, flavorings, resins, lacquers, polishes, printing inks and varnish removers. In 1985, VIChem also began producing benzyl salicylate which is used as a perfume fixative, solvent for synthetic musk, sun-screening lotions and soap odorant. In 1984, U.S. Resources and Chemicals, Inc. began leasing a portion, of the facility from VIChem, and shortly thereafter started an alcohol dehydration operation. U.S. Resources transferred the lease and operation to VIAG Fuels, Inc. (VIAG). VIAG currently owns the alcohol dehySration process equipment and is presently inactive. According to Dav.^d Weston, President of VIAG, there is an oral agreement between Chase Manhattan Bank (VIChem's mortgage bank), VIChem and VIAG in which VIAG currently provides site security. Also on-site at the present time is the St. Croix Security Kennels (SCSK). Dog kennels for 20 to 30 guard and attack dogs are present and the Secretary/Treasurer for SCSK lives on-site in a trailer. B. Quantity and Types of Substances Present The VIChem process facility was set up for batch and semi- continuoup chemical manufacture. The process area, east of the maintenance and utility building (Figure 2) consists of two open- bay reactor areas and a centrifuge/dryer building. The six reactors are either glass-lined or stainless steel and are agitated, jacketed and have overhead condenser systems. Four of these reactors are also equipped with distillation columns. The centrifuge/dryer building contains various centrifuges, dryers, filters and grinding equipment. During the January 1989 preliminary assessment, inspection of accessible areas of the reactors and the centrifuge/dryer building revealed that they were empty of raw materials and product. West of the main building is the tank farm which contains fourteen 8000 gallon tanks. Four of these tanks contain ethanol and one tank contains diesel fuel owned by VIAG and used to fuel their alcohol dehydration process. The remaining tanks in the tank farm are empty. The main building and warehouse (areas 1,3,4,5 and 6 on Figure 3) contain approximately 400 drums (drum inventory. Table 2). Two hundred of these drums are labeled ethyl alcohol and half of these are empty. The condition of the ethyl alcohol drums varies from fairly sound to extremely deteriorated. Some of the other materials in the warehouse which are in deteriorated or leaking 200003 -4- containers include a cylinder of chlorine, one cylinder of hydrogen chloride, one unlabeled bulging drum, two drums with unknown contents in which a reaction has taken place causing the lids to come off and dispersing a white crystalline material, one drum of sulfamic acid which is broken and is leaking its contents. The deterioration of these containers has been accelerated by leaks in the warehouse roof, causing portions of the warehouse floor to be flooded after it rains. The accumulation of rain water on the floor allows spilled materials to mix and is eventually discharged to the ground cast of the warehouse near the septic tank. The majority of the remaining drums contain flammable, poisonous, combustible or corrosive materials. Although some of these drums are in poor condition, they have not yet been severely impacted by rain water frora the leaking roof. The two laboratories within the main building (areas 11,15,18 and 22 on Figure 3) contain over 800 laboratory reagent containers (lab inventory. Table 1). Some of the more dangerous materials within the labs are: sodium metal (water-reactive), ethyl ether (formation of shock-sensitive peroxides), diisobutyl aluminum hydride (air-reactive), potassiun cyanide stored near acids (hydrogen cyanide air release), phosphorus pentoxide (water-reactive), sodium hydride (water-reactive), sodium borohydride (water-reactive), and approximately 75 unknown materials in reagent-size containers. At the time of EPA's removal site inspection on February 1, 1989, the water from the leaking warehouse roof had not affected the lab areas. According to the June 1978 "Quinidine Sourcing Project" written for Cooper Laboratories and attached as Exhibit B to Civil Action No. 88-1346-Y "Certification of Michael C. Chester", both di- isobutyl aluminum hydride and sodium metal were necessary for converting cinchona bark into quinidine gluconate. According to Exhibit C of this document. Cooper Laboratories experimented with this process from November 1978 to October 1979. Table 3 lists materials on-site which are CERCLA hazardous substances and the statutory source for this designation. Table 4 lists toxicological effects of some of the compounds found at the site. C. National Priorities List Designation This site is not on the National Priorities List, it has not been submitted for ranking. 200004 -5- III. THREAT A. Threat of Exposure to the Public and the Environment Five categories of threats exist at this site: threat of fire/ explosion, threat of direct contact, threat of an air release from the deteriorated hydrogen chloride and chlorine cylinders, the multiple threats posed by the leaking roof in the warehouse, and the improper storage of reactive hazardous materials at this inactive facility. Neither of the two companies presently operating at the site (SCSK, VIAG) have qualified personnel to safely handle or monitor hazardous materials stored at the facility. The threat of exposure through direct contact, ingestion or inhalation exists for personnel employed by these companies. All personnel have free access to the labs and warehouse area. Tampering with some of the reactive materials or materials in deteriorated containers could result in serious injury or death. Incompatible materials are stored in close proximity in the laboratories and the warehouse. In addition, the potential for adverse reactions is real and will continue to increase as the chemicals age in a hot and humid climate and are subject to persistent winds laden with saline moisture from the Caribbean Sea and rain water from the leaking warehouse roof. At least three examples of reactions taking place are evident in the drum storage area. These consist of one bulging drum and two drums in which an unknown crystalline material has exerted enough pressure to push open the drum lids and dispersed this material to the surrounding floor (photo #16) . An unknown lab reagent has leaked its contents within one of the reagent storage closets (photo n o and ni) . During a fire, explosion or air release from VIChem, nearby residences, businesses, the St. Croix prison and people using the Melvin Evans Highway could be severely impacted by toxic-laden smoke or plume. There are three fire departments on St. Croix which would respond to a fire at this facility. Although they have a number of self contained breathing apparatus, the required OSHA training is limited for qualified responders to hazardous material incidents. In addition, there is another exposure pathway for direct contact and ingestion. Groundwater contamination by chloroform has been well documented by EPA for potable wells in the immediate vicinity of the VIChem facility. The March 13, 1986 RCRA Enforcement investigation, conducted by the Surveillance and Monitoring Branch, revealed chloroform contamination in the on-site production well. During March and November 1988, the Response and Prevention Branch conducted well sampling and 200005 -6- analyses at the nearby Fairplains wells. These wells are located between VIChem and the St. Croix prison and are a major source of drinking water on the island. Chloroform contamination was found in Fairplains wells number 6, 8 and 9 in concentrations ranging from 11 ug/l to 75 ug/l (ug/l=micrograms per liter). The Virgin Island Port Authority (VIPA) well number 2 is located approximately one-half mile west of the site and was also contaminated with chloroform at a concentration of 11 ug/l. During the March 1986 RCRA Enforcement investigation, the inspectors observed four empty 55 gallon drums of chloroform. During the Response and Prevention Branch's site investigation in January 1989, one 55 gallon drum and one four liter bottle of chloroform were observed. There are no other known chemical industries in the Upper Bethlehem/Golden Grove area. B. Evidence of Extent of Release The warehouse area of the main building contains several drums which have leaked or are presently leaking. A 55 gallon fiber drum of sulfamic acid has been extremely deteriorated by the flooding of the warehouse floor from the leaking roof (photo 1117) . Two unlabeled drums show signs of an uncontrolled reaction and have dispersed some of their contents to the surrounding warehouse floor (photo #16). Bags of tartaric acid have deteriorated and released some of the acid to the floor as well (photo #21). Several unlabeled drums are in such poor condition that any material in them has already been released (photo #19). There may be other releases which have occurred which are not as obvious as those presented in the photodocumentation. Air monitoring in the warehouse area during the initial entry in January 1989 revealed minor elevated readings on the organic vapor analyzer (1 to 2 units above background). No other elevated air monitoring readings were observed. Leaks in the warehouse roof have allowed for the mixing of spills in the warehouse and their subsequent release to the environment. As the rain water accumulates on the warehouse floor it eventually reaches a point where the water flows out of the east side of the warehouse (areas 2 and 4, Figure 3) and is discharged to the soil adjacent to this area of the warehouse. Investigations conducted by the Surveillance and Monitoring Branch (SMB) in 1985 and 1986 revealed that process waste water from the facility was discharged into the intermittent stream adjacent to the site. Analyses of sediments from this creek bed downstream from the discharge point showed that contamination consisted of xylene, di-n-octyl phthalate, 1,4-dichlorobenzene, 1,2-dichlorobenzene, napthalene, fluorene, phenanthrene, aliphatic and aromatic hydrocarbons, arsenic, beryllium, chromium, copper, lead, nickel, antimony, and zinc. The on-site production well had detectable levels of arsenic, beryllium, 200005 -7- cadmium, chromium, copper, mercury, antimony, and zinc in addition to the previously mentioned chloroform contamination. There are four possible sources for the contamination listed above. 1) A 17,000 gallon underground concrete pit used to contain production wastewater and sludges. This pit was abandoned and sealed with concrete in 1985. 2) The former wastewater drainage line leading from the process water pit to tlie intermittent stream was constructed of welded 55 gallon drums. This pipeline was excavated and replaced when it was discovered that numerous leaks and punctures had allowed wastewater to contaminate the surrounding soil. 3) Soil contamination as a result of leakage from a broken drainage line originating at a laboratory drain. 4) Spills associated with material transfer and tank or- process line leakage. C. Previous Actions to Abate Threat As part of the sales contract with VIChem, Berlex (Island Chemical Company) was required to clean up any contamination present at the site. Berlex hired Enviro-Sciences, Inc. (ESI) of Denville, NJ, to survey the site and certify it as environmentally clean. ESI's sampling survey disclosed four . areas of contamination. Two areas within the tank farm were 1 found to be contaminated, primarily with toluene. This \ contamination was thought to be from process or transfer spills.i The other two areas, underneath the concrete loading dock and a / nearby trench were contaminated primarily with pyridine. This / contamination is believed to be from the leaking laboratory v drain. The quantity of contaminants was estimated at 12 5 pounds, of toluene and 120 pounds of pyridine. | ESI recommended on-site treatment of the contaminated soil. The toluene contaminated soil was to be placed in a drying oven equipped with carbon filters, so that emission rates did not exceed the 200 ppm Threshold Limit Value (TLV) for toluene. The pyridine contaminated soil was to be treated by cutting the concrete pad and tilling the soil every two to three days and allowing the soil to aerate. A structure was to be built over the area to prevent soil saturation from rainfall. During SMB's September 1986 investigation these two on-site treatment procedures were confirmed, however some discrepancies were noted from the process outlined above. The drying oven was employed for the volatilization of toluene from the soil, but the charcoal filters to absorb the volatilized material were not observed. The contaminated soil was tilled and aerated using a backhoe and then covered with a large synthetic liner. No permanent structure had been built to prevent future saturation of the soil from rainfall. The synthetic liner was not owned by Berlex but was rented. During RPB's January 1989 investigation 200007 -8- this area was covered by concrete and a new loading dock had been built. It is adjacent to the dog kennel area and trailer used for living quarters by the kennel operator. In addition, on October 10, 1985, SMB was informed by Dr. A.L. Kyles, Vice President, Enviro-Sciences, that 192 55 gallon drums of waste were removed by Berlex for disposal. This material consisted of process pit water and sludge, drums and soil from the wastewater drainage line, one 55 gallon drum of water/toluene, and toluene contaminated soil. No copies of manifests were received to confirm these shipments. At the time (1985) an additional 33 drums of waste belonging to Berlex were staged on site awaiting sample analyses and disposal. Data on the sampling performed by Berlex was never received by SMB to confirm the clean up by Berlex. Also, the re-routing of existing laboratory discharges to a self-contained unit was not observed. When Region II became aware of chloroform contamination in the public wells in St. Croix a health evaluation was conducted. According to the Agency for Toxic Substances and Disease Registry (ATSDR), chloroform is a B-2 carcinogen and has been shown to be a carcinogen in animals but not in humans. The Maximum Contaminant Level (MCL) for chloroform is 100 parts per billion (ppb). If other halogenated organics were present along with the chloroform, the 100 ppb MCL would be for all halogenated organics present. Chloroform contamination ranged from 11 to 75 ppb and no other contaminants were detected. Since the MCL was not exceeded, a CERCLA/SARA response was not initiated. D. Current Actions to Abate Threat The threat of direct contact to the general public is currently being limited by a perimeter chain link fence and site security maintained by VIAG and SCSK. There is evidence that at times the guard dogs are allowed to roam through the yard of the facility. In a letter dated March 1, 1989, to Region II's New York/ Caribbean Compliance Branch, Fred Schubert, President of VIChem, informed EPA that during his February 21-23, 1989 site visit "a small amount of non-contaminated rain water was swept out of the warehouse floor, the floors of the warehouse were swept and all sweepings were collected in an open head drum which was covered and remains on the site and a single five gallon pail of a laboratory solvent was placed in a second open head drum which was covered and remains on the site". No sampling/analyses were conducted to verify if the rain water or floor sweepings were contaminated. The type of laboratory solvent overpacked is unknown. Mr. Schubert also stated "non-chemical waste (empty boxes, waste paper, etc.) was removed from the site". Cans of paint were staged in one location outdoors. 200008 -9- IV. ENFORCEMENT Berlex Laboratories, Inc. has submitted a work plan to EPA for the performance of environmental sampling at the site. The work plan is being finalized, after which it is expected that Berlex will implement the work called for by the work plan, pursuant to an Administrative Order to be issued by EPA. On March 13, 1989, Notice Letters were sent to the following Potentially Responsible Parties (PRPs): Berlex Laboratories, Inc., Island Chemical Company, Inc., CHS Holding Corporation, Virgin Island Chemical Company, and VIAG Fuels, Inc.. None of these PRPs indicated that they were willing to conduct or finance a drum removal or other appropriate CERCLA response. VIChem has indicated that it would not object to or obstruct EPA's performance of the removal action described herein. EPA will also seek VIAG's and SCSK's agreement to not operate or have personnel (or dogs) on-site during working hours of the removal action or if conditions at the site (stability) warrant evacuating the site of non-essential personnel. It may be desirable to have SCSK maintain site security during interim periods when EPA has temporarily demobilized for analytical and transportation/disposal coordination. The dog kennel is a very effective deterrent for potential trespassers or vandals. Further, EPA will seek to ensure that VIAG properly removes its numerous paint cans and two drums of water treatment chemicals at the site. Four of the tanks currently contain ethanol. VIAG does not own this ethanol; however, they intend to buy this material when their company becomes fully operational. Enforcement Programs will seek assurances from VIAG that VIAG intends to buy the ethanol from the current owner of this alcohol, Ethanol Corp. of Birmingham, Alabama, and that VIAG will take responsibility for this material by using and storing it properly. This action will generate a cost savings to the Region in that 40,000 gallons of product will not have to be disposed of or recycled by EPA. The tanks appear sound and should provide continued safe storage of the ethanol. V. PROPOSED PROJECT AND COSTS A. Objective of the Project The overall objective of this removal action will be to reduce the threat of fire, explosion, air release and direct contact. The scope of this response will be to continue site security, stabilize reactive, leaking or weakened containers, and dispose of above ground containerized materials and resample public wells contaminated with chloroform. 200009 -10- For the purposes of planning, this response will be divided into three phases. The first phase of the project will involve activities at the site which reduce the most immediate potential for fire/explosion or air release and stabilize leaking and weakened containers. A security service will be provided during those times of the removal action when work is not being performed at the site. The activities and actions of the first phase are listed below. Phase 1: 1) Stabilize, detonate/treat, or recycle air-reactive, water- reactive and shock-sensitive materials, and the deteriorated cylinders. 2) Sample and overpack or transfer to new drums all other containerized materials. 3) Contact potential recyclers in the Caribbean area (USVI and Puerto Rico) and coordinate recycling of usable product if possible and appropriate. Recyclers outside the Caribbean area may not be considered. This is due to the possibility of a recycler rejecting a product. If this were to occur with a United States mainland recycler, the cost of transportation from and back to the site would far exceed any potential cost savings to be realized through recycling. 4) Segregate materials by hazard class, and separate incompati- ble materials. Relocate and stage all overpacked containers in an area of the warehouse where they will not be impacted by rain water from the leaking roof. If dry warehouse space is limited, overpacked drums will be placed on pallets and covered with waterproof tarps. 5} Conduct sampling of the Fairplains and VIPA wells and analyze for chloroform contamination. EPA will not make capital improvements to the main building by repairing the leaking warehouse roof. All sound and usable tanks will be left on site. Except for the 40,000 gallons of ethyl alcohol discussed previously, the contents of other tanks will be disposed of. Any on-site treatment or detonation (on- or off-site) will be fully coordinated with the St. Croix Local Emergency Planning Committee (LEPC) and U.S. Virgin Islands Emergiency Response Commission (VIERC). If these commissions are not established or fully functional Isy this time, these actions will be coordinated with the Virgin Islands Department of Planning and Natural Resources (DPNR) and appropriate emergency management agencies. 200010 -11- Phase 2; 1) Continue recycling efforts. 2) Conduct verification analyses for known materials and waste characterization for unknown materials or labeled materials which may have been tampered with. 3) Conduct disposal analyses for bulked unknown samples. 4) Based on this analytical information, coordinate the transportation and off-site disposal of all remaining materials. Phase 3: i) Continue recycling efforts. 2) Package and label containers for transportation to the pre- arranged disposal facility. 3) Site demobilization and discontinue site security. Use of disposal facilities in Puerto Rico will be considered. However, these facilities may not be in compliance with appropriate RCRA regulations. Due to the fact that transportation for off-site disposal will be by water carrier, all drums leaving the site will be overpacked or in new drums. Materials will not be bulked in tanks or sealed roll-off containers in order to avert the possibility of an adverse reaction occurring during transportation. The increase in cost due to this action will outweigh the risks associated with a mode of transportation which will take a relatively long period of time during which mixing by wave action on the ship and heat from the tropical environment persists. B. Project Estimated Costs The following synopsis of the estimated costs is based on information obtained from several sources. The ERCS cost data is based on the OSC's copy of the ERCS contract. Several OSCs and OSC Reports were consulted for on-site treatment cost estimates and typical costs for field purchases, rental equipment and other items while working in the Caribbean. This is the first drum removal conducted in the U.S. Virgin Islands by Region II. Delays from the weather (rain storms, heat stress), supply and equipment deliveries, and other logistical complications are expected. Consequently, the ERCS contingency factor has been increased to 30%. 200011 -12- O.H. Materials will be the ERCS contractor for this removal, since they are the only Region II ERCS contractor to service the Caribbean area. REMOVAL PROJECT CEILING COSTS EXTRAMURAL COSTS ERCS Cleanup Contractor $971,000 30% Contingency Factor $291,300 Rounded Mitigation Contracting Total $1,262,000 TAT Costs $105,000 Subtotal Extramural Costs $1,367,000 20% Contingency of Extramural Costs $273,400 Total Extramural Costs $1,64 0,4 00 INTRAMURAL COSTS Direct Costs $50,000 Indirect Costs $150,000 TOTAL PROJECT CEILING $1,840,400 ROUNDED TOTAL PROJECT CEILING $1,84 0,000 C. Project Schedule Approximately one month prior to the anticipated start date, the OSC and Response Manager from O. H. Materials will visit the site and review the scope of work, and develop strategies and a work plan. This will be necessary to determine which equipment and supplies will have to be shipped from the mainland. Mobilization of equipment will take two weeks and mobilization of personnel will take two days. The first phase should take approximately three weeks. Analytical, transportation and disposal coordination will be the most time-consuming phase and may take six to eight months. After all disposal approvals have been obtained, the final phase for packaging, labeling and off- site shipment is anticipated to take three weeks. 200012 -13- All disposal activities will be conducted in accordance with CERCLA's off-site disposal policy and other applicable or relevant and appropriate regulations. VI. RECOMMENDATIONS Conditions at the VIChem site meet the criteria for a removal action under 40 CFR 300.65(b)(2) of the November 20, 1985 National Oil and Hazardous Substances Contingency Plan (NCP). These criteria are: 1) Actual or potential exposure to hazardous substances or pollutants or contaminants by nearby populations, animals or food chain (Section 300.65(b)(2)(i)); 2) Actual or potential contamination of drinking water supplies or sensitive ecosystems (Section 300.65(b)(2)(ii)); 3) Hazardous substances or pollutants or contaminants in drums, barrels, tanks or other bulk storage containers, that may pose a threat of release (Section 300.65(b)(2)(iii)); 4) Weather conditions that may cause hazardous substances or pollutants or contaminants to migrate or be released (Section 300.65(b)(2)(V)); 5) Threat of fire or explosion (Section 300.65(b)(2)(vi)); A removal action addressing containerized surface contaminants, pollutants and hazardous substances is consistent with Section 104(b)(2) of CERCLA as'amended by SliRA, in that this response will contribute to the efficient performance of long term remedial actions planned for this site. The funds requested to initiate and complete this removal action will come from the Removal Advice of Allowance for Fiscal Years 1989 and 1990. Obligation of the necessary funds to complete this removal will occur in the first quarter of FY 1990. This action is in accordance with OSWER Directives 9360.0-18 and 9200.3-05. I, therefore, recommend your approval of this request for a removal action under CERCLA as amended by SARA for the Virgin Island Chemical Company site. The estimated project ceiling for this removal is $1,840,000 of which $1,262,000 is for mitigation contracting. 200013 -14- Your authority to approve these project funds is pursuant to Assistant Administrator J. Winston Porter's May 25, 1988, redelegation memorandum. Delegation Number R-14-1-A. APPROVED: (A.y:Cc^tyi.J^^^)^/.^^ J? DATE: urce Cun.sulianu. Int.. and En^mnmentaJ Toxitolowy ImemaiiomJ. Inc. TATPM MENTZEL FIGURE 1 SITE LOCATION VI CHEM SITE ST. CROIX US VI 200016 200017 FIGURE 3 \ 29 28 27 26 25 Virgin Island Chemical Company Main Building Inventory Zones Dog Kennels Loading Dock Concrete Surface 24 23 22 cr> o i- _j o CO 18. Lob 15 14 11 10 21 20 19 17 16 13 12 8 7 Warehouse 5 00 iH O O O W f / 3 . S / TABLE 1 Laboratory Reagent Inventory CHEMICAL NAME 1,3-dinitrobenzene 1-butanol 1-chlorobutane 1-propanol 18-Crown-6 99% 2,2-oxydiethanol 2,6-diinethoxybenzoic acid99% 2,6-ditertiarybutyl p-cresol 2-hydroxybenzyl alcohol 99% 2-hydroxyethyl ether 2-methyl-l-butanol 99% 2-methylbutyl amine 3,3-diinethoxy benzidene 3-hydroxybenzoin acid 4-chloroben2ene sulfonamide 4-hydroxy 4niethyl 2pentanone 4-hydroxybenzoic acid 4-ffiethylben2o phenone 97% 9-hydroxyflourene Acetic acid Acetone Acetonitrile Alkalinity C,D,E,G Aluminum Chloride Aluminum chloride Ammonium acetate Ammonium acetate Ammonixim acetate purified Ammonium hydroxide Ammonixim persulfate Ammonium persulfate Aimonium thiocyanate Amyl alcohol Arsenic trioxide Barium chloride Barium chloride Barium chloride Barium hydroxide Benzaldehyde Benzene Benzhydrol Benzoic acid Benzoin Benzoin 98% COMPANY QTY STATE Aldrich Chemical J.T.Baker Chemical MCB J.T.Baker Chemical Aldrich Chemical Kodak Aldrich Chemical Biesterfeld Aldrich Chemical Aldrich Chemical Aldrich Chemical American Laboratorie Kodak Aldrich Chemical Aldrich Chemical Aldrich Chemical Aldrich Chemical Aldrich Chemical Aldrich Chemical MCB Fisher Scientific Supelco Mogul Corporation Mallinckrodt Witco Chemical Fluka Aldrich Chemical Jarchem Industries Sargent Welch Scient J.T.Baker Chemical J.T.Baker Chemical Fisher Scientific Mallinckrodt Fisher Scientific Drew Chemical Mallinckrodt Fisher Scientific Fisher Scientific J.T.Baker Chemical Tenneco Oil Kodak Mobay Chemical Fluka Aldrich Chemical I S S S 100 500 4 500 25 1 25 500 25 1 10 15 100 100 100 500 50 50 g ml L ml g kg g g g kg g g g g g g g g 2X25 g 2X5 4 lb L 1 box 4X2 1 500 1 2 250 500 2.5 500 500 1 oz lb g kg kg g ml kg g g pt 2xll3g 1 500 1 1 500 qt g lb lb ml 2xlgal 100 1 2x1 g lb. kg 4x500g « « = solid liquid liquid liquid solid liquid solid solid liquid liquid liquid liquid solid solid solid liquid solid solid solid liquid liquid liquid liquid solid solid solid solid solid liquid solid solid liquid liquid solid liquid solid solid solid liquid liquid solid solid solid solid 200019 07/14/89 TABLE 1 Laboratory Reagent Inventory CHEMICAL NAME COMPANY QTY STATE Benzophenone Benzophenone • Benzophenone Benzophenone 99+% Benzoyl chloride Benzyl acetate 99% Benzyl alcohol Benzyl benzoate Benzyl chloride Benzyl chloride Benzyl cinnamate 98% Benzyl ether Benzyltriethylammoni\imchlori Bismuth subnitrate Bromine Bromophenol blue Brucine sulfate Buffer solution pH 10.00 Buffer solution pH 4.00 Buffer solution pH 7.00 CAO-3 BHT Calcium sulfate anhydrous Cello-Seal Chloride F Chlorodiphenyl methane 98% Chloroform Chromotropic acid Na salt Cinnamaldehyde Citric acid anhydrous Citricacidtrisodiumdihydrate Cobalt chloride Color standard 4 Congo red Copper metal Cupric sulfate Cupric sulfate DPD #1,2,3 Reagents Dibenzo 18-Crown-6 98% Dibenzoyl tartaric acid Dichloroethane 99% Dichlorophenyl methane 99% Dichlorotoluene 99% Diethylene glycol Diisobutyl aluminum hydride Diphenylmethane 99% Aldrich Chemical 500 g solid H&S Chemical 1 bag solid Upjohn 500 g solid Aldrich Chemical 50 g solid Mobay Chemical 1 lb solid Aldrich Chemical 100 g liquid Mallinckrodt 1 pt liquid Aldrich Chemical 100 g liquid .unknown 4 oz liquid Velsicol 500 g liquid Aldrich Chemical 100 g solid Aldrich Chemical 1 kg liquid Aldrich Chemical 25 g solid MCB 1 lb solid Fisher Scientific 113 g liquid Fisher Scientific 5 g solid Fisher Scientific 1 oz solid Fisher Chemical 500 ml liquid Fisher Scientific 500 ml liquid Fisher Chemical 500 ml liquid Sherwin Williams 1 bag solid W.A.Hammond Drierite 4x5 lb solid Fisher Scientific 25 g liquid Mogul Corporation 3 oz liquid Aldrich Chemical 100 g solid Fisher Scientific 4 L liquid Fisher Scientific 25 g solid unknown 2x1 kg liquid J.T.Baker Chemical 500 g solid Aldrich Chemical 1 kg solid Fisher Scientific 2x1 lb solid un)cnown 1 oz liquid Fisher Scientific 25 g solid Fisher Scientific 500 g solid Fisher Scientific 500 g solid Mallinckrodt 500 g solid Taylor Chemical 3x1 oz liquid Aldrich Chemical 50 g solid Knoll Fine Chemicals 1 kg solid Aldrich Chemical i kg liquid Aldrich Chemical 25 g solid Aldrich Chemical lOO g solid Fisher Scientific i qt liquid Texas Acres 4 cyl gas Aldrich Chemical 500 g liquid 200020 07/14/89 TABLE 1 Laboratory Reagent Inventory CHEMICAL NAME COMPANY QTY STATE Diphenylthiocarbazone Eosin Y Ether anhydrous Ethoxyguin Ethyl acetate Ethyl acetate Ethyl benzene Ethyl ether 99% Ferric ammonium sulfate Ferric chloride Ferric chloride Ferric chloride anhydrous Ferric chloride anhydrous Ferrous ammonixim sulfate Formic acid Glacial acetic acid Hydrazine sulfate Hydrazine sulfate Hydrochloric acid Hydrochloric acid Hydroxylamine hydrochloride Hydroxylamine hydrochloride Iodine Iron chloride anhydrous Isoamyl alcohol Isobutyl alcohol Lead acetate Lead nitrate Lithium perchlorate Magnesium sulfate Medical oxygen Mercuric chloride Mercuric oxide Mesityl oxide Methanol Methenamine Methyl alcohol Methyl orange . Methyl red Monochlorobenzene N-methylaniline Na salt of ME salicylate Niacin N.F. Nitric acid concentrated Nitrobenzene Fisher Scientific Aldrich Chemical Fisher Scientific unknown Aldrich Chemical MCB Dupont Fisher Scientific Fisher Scientific unknown Fisher Chemical Pennwalt Corporation Kodak Fisher Chemical unknown Fisher Chemical Fisher Scientific Fisher Scientific MCB Fisher Chemical Fisher Scientific MCB Fisher Scientific BASF Fisher Scientific J.T.Baker Chemical MCB Fisher Scientific Aldrich Chemical Fisher Scientific MSA Fisher Scientific Fisher Scientific Aldrich Chemical Fisher Scientific Fisher Scientific Mallinc)crodt Fisher Scientific Fisher Scientific PPG Industries Kodak Sattra Chemical Nepera Chemical J.T.Baker Chemical Fisher Scientific 25 g 25 g 4 qt 4 oz 5 gal 5xlgal 1 qt 6x500g 500 g 100 ml 1 lb 5x500g 500 g 1 lb 200 g 5 lb 4 OZ 100 g 2X6 lb 3x1 L 1 kg 4 OZ 500 g 500 g 500 ml 500 ml 1 lb 100 g 500 g 500 g 1 cyl 2xl00g 500 g 100 g 4 L 500 g 1 gal 113 g 2x10 g 10 oz 1 kg 1 bag 250 g 2x8 lb 1 gt solid solid liquid liquid liquid liquid liquid liqiud solid liquid solid solid solid solid liquid liquid solid solid liquid liquid solid solid solid solid liquid liquid solid solid solid solid gas solid solid solid liquid solid liquid solid liquid liquid solid solid liquid liquid 200021 07/14/89 TABLE 1 Laboratory Reagent Inventory CHEMICAL NAME COMPANY QTY STATE Non aqueous buffer soln. Nutrizyme Oil #3 Paraffin oil Paraformaldehyde Paraformaldehyde prills 91% Perchloric acid Phenol red Phenopthalein Phenylhydrazine Phenylhydraz inehydrochloride Phosphorous pentoxide Piperazine Potassium bromide Potassixim butoxide Potassium chloride Potassium cyanate Potassium cyanide Potassium dichromate Potassium ferrocyanide Potassium hydroxide Potassium hydroxide Potassium iodide Potassium iodide Potassium periodate Potassium platinate Potassixim sulfate Potassium sulfate Potassium sulfate Potassium thiocyanate Resorcinol Salicylaldehyde 99+% Salicylic acid Salicylic acid Salicylic acid sodium salt Sicapent Silica gel dessicant Silver nitrate Silver nitrate Sodixim Chloride Sodium acetate Sodium acetate anhydrous Sodium acetate anhydrous Sodium amide Sodium benzoate Beckman Instruments Merck Frich Oil Fisher Scientific MCB Celanese Chemical MCB Fisher Scientific Fisher Scientific Fisher Scientific Fisher Scientific Fisher Scientific MCB Fisher Scientific Callery Chemical Beckman Instruments Fisher Scientific Fisher Scientific Fisher Scientific Fisher Scientific Mallinckrodt Fisher Scientific Drew Chemical Fisher Scientific Fisher Scientific Varlacold Chemical Indiana Army Ammo Plant Aldrich Chemical unknown Fisher Scientific Koppers Aldrich Chemical Aldrich Chemical Aceto Chemical Aldrich Chemical MCB Davison Chemical J.T.Baker Chemical Sargent Welch Scientific Fisher Scientific Sattra Chemical Niacet Corporation CDF Chimie Noth America Farchan Research Lab Sattra Chemical 1 2 5 < 1 1 1 2x8 5 1 4X4 2 1 100 pt oz ?al gt qt lb lb g oz oz lb lb g 5x500g 50 2X6 1 500 500 3 2X1 500 1 g oz lb g g kg lb g gt 2x500g 100 5 250 500 50 500 g g g g g g 3 bags 100 100 500 100 2.8 2x1 1 30 500 g g g g L qt oz g g 3 bags 250 g" 2x500g 500 1 t g )ag liquid solid liquid liquid liquid solid liquid solid solid lic[uid solid solid solid solid solid solid solid solid solid solid solid solid liquid solid solid solid solid solid solid solid solid liquid solid solid solid solid solid solid solid solid solid solid solid solid solid 200022 07/14/89 TABLE 1 Laboratory Reagent Inventory CHEMICAL NAME COMPANY QTY STATE Sodium benzoate Sodixim benzoate Sodium benzoatie Sodium borohydride Sodium carbonate Sodium carbonate anhydrous Sodium chlorate Sodium dichromate Sodium formate Sodium hydride Sodixim hydroxide Sodium metal Sodium nitrite Sodixim nitro ferricyanide Sodium sulfate Sodixim tartrate Sodium tartrate Sodium thiosulfate Succinic anhydride Succinic anhydride Sulfamic acid Sulfanilic acid Sulfite 0,P,Q Sulfuric acid Tetraphenolboron sodium 99% Thiopene Total alkylinity indicator Tributyl borate Trichloroethylene Triethyl borate 97% Triethylenediamine Uranyl acetate Weedox C/B. 250 herbicide Xylene Zinc chloride Zinc chloride anhydrous p-chlorobenzene sulfonamide p-naptholbenzein p-toluenesulfonicmonohydrate pH indicator A 2 Miscellaneous unknowns z Miscellaneous unknowns Dastech International Ishihara Corporation Pfizer Fisher Scientific Fisher Scientific Mallinckrodt Hooker Chemical Fisher Scientific unknown Thiokol/Ventron Division Mallinckrodt RMI Fisher Scientific MCB Fisher Scientific J.T.Baker Chemical Fisher Scientific Fisher Scientific MCB Aldrich Chemical Fisher Scientific H&S Chemical Mogul Corporation J.T.Baker Chemical Aldrich Chemical Kodak Drew Chemical Aldrich Chemical Mallinckrodt Aldrich Chemical Air Products unknown Southern Mill Creek Prod. Fisher Scientific Fisher Scientific Mineral Research H&S Chemical Fisher Scientific Aldrich Chemical Mogul Corporation on site lab glassware on site one oz bottles 1 bag 250 g 100 lb 4x25 g 1 kg 1 lb 1 box 10 kg 5 lb 1 lb 500 g 2 boxs 2x500g 4 oz 500 g 2 OZ 6xll3g 2x1 lb 6x250g 2x1 kg 500 g 1 bag 3x2 oz 10 lb 25 g 100 g 1 qt 750 g 1 pt 100 g 250 g 500 g 2x5gal 5x1 L 500 g 1 lb 2 bags 25 g 500 g 2 oz 280bot 238bot solid solid solid solid solid solid solid solid solid solid solid solid solid solid solid solid solid solid solid solid solid solid liquid liquid solid liquid liquid liquid liquid liquid solid solid liquid liquid solid solid solid solid solid liquid misc. liquid 200023 Page No. 07/14/89 TABLE 2 Chemical Name Company Drum Inventory Qty State Cond Dates Acetone Acetylene Activated carbon All-weather patch material Amersite 2 Ashland MeOH Benzyl acetate Benzyl chloride Chlorine Chloroform Crofox Crystal Clear floor finish Degreaser Drewtrol 8500 Ethyl alcohol Filteraid Glacial acetic acid Glycol Humisorb Hydrochloric acid Hydrogen chloride Insulation (asbestos??) Insulation fiberglass Lubricating oil Lubricating oil Magnesium sulfate trihydrate Methanol Methanol Methyl isobutyl carbinol Methyl isobutyl ketone Ashland Chemical VI Gas Calgon Corporation Revere Chemical Valley Freight Syst. AThland Chemical Island Chemical Velsicol Corporation VI Gas unknown Cerfact T,aboratories Cerfact Laboratories unknown Valley Freight Syst. unknown unknown Celanese Chemical Island Chemical Culligan Certified Laboratory VI Gas unknown unknown Texaco Texaco Tomita Pharmaceutica Ashland Chemical unknown 'Van Waters & Rogers Ashland Chemical 55 G 2 cyl 30 bag 55 G 55 G 5 • G 21X55G 28X55G 1 cyl 55 G 55 G 2x20 G 55 G 55 G 115X55 10X30G 13X55G 20x55G 30 G 55 G 1 cyl 13 box 7 box 2x10 G 5X55 G 6x25kg 5x55 G 3X55 G 12X55G 55 G liquid good gas good solid good solid fair liquid fair liquid good liquid fair liquid fair gas poor liquid good liquid poor liquid good liquid good liquid poor liquid poor solid poor liquid good liquid poor 1984 solid fair . liquid poor gas poor solid good solid good liquid good liquid good solid fair liquid good liquid fair liquid good 1984 liquid good o o o CN Page No. 07/14/89 TABLE 2 Drum Inventory Chemical Name Company Qty State Cond Dates # Micro media filter sheets Oxygen Oxygen Paints Paints Paints Paints Para-phenetidin Pentosin Potassium acetate Potassium sulfate Powdered filter media Propane Purafil II Quinine sulfate Rinseline injector fluid Rout Salicylic acid Salt Soda ash Sodium acetate anhydrous Sodium acetate anhydrous Sodium bicarbonate Sodium hexa-meta phosphate Sodium hydroxide Sodium hydroxide Spent toluene/acetone Sterling salt crystals Sulfamic acid Tartaric acid ^hinner Ertel Engineering VI Gas Santa Maria Gases unknown unknown International Paint International Paint unknown Deutsche Pentosin Jarchem Industries unknown Ionics unknown unknown Kimafarma Bob Chamber Ltd. Cerfact Laboratories Rhone-Poulenc unknown Allied Chemical unknown Jarchem Industries Stauffer Chemical FMC Mantek Manuel del Valle Inc unknown unknown Dupont Pfizer Chemical unknown ^ ^ 18 box 3 cyl 1 cyl 44x5 6 53x1 G 97x5 G 21X1 ti 55 G 20 L 8X100# 50 bag 2 boxs 4 cyl 15X10G 20 G 55 G 20 G 27drum 2x30 G 15x100 50 lb 200 lb 8xl00# 200 lb 55 G 12X55G 2x55 G 50 lb 400 lb 15X100 6X1 G solid good gas good gas good liquid fair liquid fair liquid fair liquid fair liquid fair 1983 liquid fair solid good solid good solid good gas good solid good liquid good liquid good solid poor solid good solid good solid poor solid good solid poor solid poor solid good liquid poor liquid good liquid fair solid poor solid poor solid poor liquid fair in Toxic by inhalation. Ingestion, or dermal contact F- Carcinogenic G- Teratogenic H» Mutagenic I» Central nervous system effects 200030 '"^y Photo iH. Virgin Island Cliemical Company Alcohol deliydratlon apparatus 200031 Photo S2. Dog kennel operating on s i t e y y ^ : y i y y y z z ^ i z y y Z ' ' :^'z^^Z^:l,Z^^^-'?':' E^r'-^Z .:yy^^^AfEz^-- Photo {13. Maintenance building IL r j . - r ^ j y ^ Plioto nil. View of tank.q, main building, and alcohol dehydration unit 200032 Photo tf5. Main building office area 23 zzm Eiim >yzzimz^ •; • • •'• - ' ^ v ; v . ; « * , : j ; Photo {6. Area 22 lab in the main building 200033 Photo 111. Virgin Island Cliemical Company Sodium metal in area 18 Photo t s . Area 18 cliemical and glassware storage 200034 Photo 119. Incompatable storage of lab reagents Photo i l O . Incompatable and leaking storage of lab reagents 200035 Photo H i . Incompatable and leaking storage of lab reagents Photo ^12. Incompatable storage of lab reagents 200036 Photo //13. Paint cans in area 1 Plioto j?lA, Cylinder of chlorine 200037 y.zyt0tirm0.^ Photo //15. Drums in area 4; note water on the floor Photo H G . Drum contents undergoing a reaction 200038 Piioto itl7. Virgin Island Chemical Company Drums and debris in area 5 Photo SIS. Drums In area 5 200039 Photo //19. Deteriorating drums in area 6 I'Azy 200040 Photo l!'20. Drums and floor contamination in area 5 Pho to //21. Deteriorating bags in area 6 Photo //22. Drums in area 6 200041 *. Photo -'21. Deteriorating bags in area 6 Photo #22. Drums in area 6 200042