site reconnaissance visits for april 5, 13 and 28, 2011 at the scorpio … · 2020. 11. 28. ·...
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14 Wall Street, Suite 1702 New York, New York 10005 Tel. 212-785-9123 Fax. 212-227-1692
May 23, 2011 Mr. Adalberto Bosque Remedial Project Manager U.S. Environmental Protection Agency Caribbean Environmental Protection Division Centro Europa Building, Suite 417 1492 Poncé de Leon Avenue San Juan, Puerto Rico 00907‐4127 PROJECT: RAC 2 Contract No.: EP‐W‐09‐002
Work Assignment No.: 016‐RICO‐02HA DOC. CONTROL: 3320‐016‐00869 SUBJECT: Site Reconnaissance Notes: April 5, 13, and 28, 2011 Scorpio Recycling, Inc. Remedial Investigation/Feasibility Study Toa Baja, Puerto Rico Dear Mr. Bosque: This letter provides a summary of the conditions observed by Mr. Jose Reyes, CDM Field Technician, during site reconnaissance performed at the Scorpio Recycling, Inc. (SRI) site on April 5, 13, and 28, 2011. Photos of the SRI facilities taken during the subject visits are included as Attachments A, B and C.
April 5, 2011 ‐ Site Observations Operations: Five people were picking through scrap; Mrs. Gloria Rodriguez, Mr. Manuel Figueroa
and three laborers. Southern Area: No active work observed; no change apparent since prior visit, with one large vine‐
covered soil pile and one tire pile. Northern Area: Four soil piles, four large scrap piles, ponding of water along an interior road and
near the bases of the piles. Central Area: Piles are mostly composed of tires with scrap material in various proportions, some
puddles were observed along the interior dirt roads. Northern Access Road: Up to two feet of soil/sediment has accumulated within approximately 20
feet of the access road as a result of a metal obstruction. CDM awaiting access to background locations to continue OU2 soil sampling.
April 13, 2011 ‐ Site Observations Operations: Five people were working, including Mrs. Gloria Rodriguez, Mr. Manuel Figueroa and
three laborers. Mrs. Rodriguez communicated that her group recently submitted to the property owner’s attorneys a proposal for the processing of tires. The proposal includes the creation of a platform along the Aluminum Pit, the use of water accumulated in the pit, and reuse of the water throughout the process. Sediments will be collected separately and will be disposed at the facility.
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Mr. Adalberto Bosque May 25, 2011 Page 2
Clean tires would be stored in the warehouse. Her group plans to start clearing the warehouse while waiting for approval.
Equipment: Digger. Other: Mrs. Rodriguez communicated that her group is willing to share photographs and
information documenting their activities performed at the SRI site upon request. April 28, 2011 ‐ Site Observations Operations: Five people picking through scrap, segregating material: Mrs. Gloria Rodriguez, Mr.
Manuel Figueroa and three laborers. Equipment at the Site: Digger, Bobcat and Track Excavator Southern Area: No active work observed; no change apparent since prior visit with one large vine‐
covered soil pile and one tire pile. Key Observation: Apparently some new material has been brought to the facility Northern Area: Four soil piles, four large scrap piles, ponding of water along an interior road and
near the bases of the piles. Central Area: Piles are mostly composed of tires with scrap material in various proportions, some
puddles were observed along the interior dirt roads. New clearing in the area suggest that displacement and/or removal of material had occurred at these areas.
Northern Access Road: Up to 2 feet of soil/sediment has accumulated within approximately 20 feet of the access road as a result of a metal obstruction.
Monitoring Wells: Both wells in good condition. Other: The Warehouse has been cleared. Key Issues in Moving the RI Forward SRI remains partially operational. It is apparent that new material has been discarded at the facility.
Current conditions within the Northern Area would not support implementation of the proposed subsurface investigation.
Site Clearing: The Northern Area is not clear and some previously cleared portions now contain scrap and are the location of ongoing work at the property. Areas determined to be 'cleared' by SRI should be free and clear of waste, scrap, and other metallic debris protruding through, visible within, or otherwise identifiable near the surface, such that surveys and subsurface investigations can be efficiently and safely performed. Surveys are to include (1) situation of a grid to establish soil sampling locations and (2) a subsurface geophysical survey to investigate the presence of materials including large objects which may contain waste or inhibit subsurface exploration and establish the location of buried utilities. Performing the surveys before the site is appropriately cleared will generate less informative data, result in additional mobilization costs of surveyors and equipment, potentially damage downhole equipment, and potentially impact subsurface conditions.
Eliminate potential recontamination: Via enforcement, such that no portion of the site that is cleared and/or investigated is re‐inhabited by scrap/waste/operations.
Establish site controls: It is critical to project safety and execution that (1) PRP establish operational practices and physical controls at SRI to eliminate potential migration of contaminants offsite or to areas investigated to date, and (2) PRP eliminate further damage to existing site wells and any other project‐related installations due to SRI operations.
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Mr. Adalberto Bosque May 25, 2011 Page 3 Information Sharing: CDM respectfully requests that SRI share the following: (a) site Utility Plans to
support clearance activities for the subsurface investigation, (b) any updates to PRP's schedule for clearing remaining areas and (b) an explanation of how PRP will control the site perimeter with respect to potential contaminant migration.
Schedule CDM and EPA will continue periodic site visits to assess the progress of clearing activities. If you have any questions concerning the notes for the site visit, please contact me at your earliest convenience at (787) 722‐5410. Very truly yours, CDM FEDERAL PROGRAMS CORPORATION
Brendan MacDonald, P.E., LEED AP® RAC 2 Site Manager Enclosure
cc: M. Valentino, CDM RAC 2 Document Control
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A
Attachment A Photographs April 5, 2011
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Former Loading and Aluminum Sorting Area
Looking W
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Clearing of the Aluminum Pit
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Operations at Central Area
Looking E
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Maintenance Shop Area
Looking E
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Behind the Mechanic Shop
Looking E
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Drop‐Off and Torch Cutting Area
Looking E
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M i t Sh d C t l AMaintenance Shop and Central Area
Looking W
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Work Shop Storage
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Clearing in Warehouse
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C t l A M dCentral Area Mounds
Looking E
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A l th W i h St tiArea along the Weigh Station
Looking E
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Monitoring Well Areas/Conditions
MW‐4A on left, MW‐1 on right
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Sorting and storage area
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Several places with oil spills remain
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Northern Accessway
Looking N
y
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A
Attachment B Photographs April 13, 2011
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Loading Area and Former Aluminum Sorting Area
Looking E
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Apparently some new material has been dropped off at the site near the Scale Area
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Operations Behind Maintenance Area
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Maintenance Area
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Central Operations Area
Looking E
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Drop Off and torch Metal Cutting Area
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D b i t id th N th E tDebris outside the Northern Entrance
Looking S
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E i t ki t th SitEquipment working at the Site
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Cleared Warehouse
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Central Area / Northern Scrap Mounds
Looking E
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A l th W i h St tiArea along the Weigh Station
Looking W
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Monitoring Wells: Area / Conditions
MW‐1 on left (under tires); MW‐4A to the right
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Material segregation apparently occurring
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Former Central Area Crusher/Shear buried at the Central Area
Looking E
/
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Northern Accessway / Entrance Looking S
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A
Attachment C Photographs April 28, 2011
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Loading / Former Aluminum Sorting Area
Looking N
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Clearing of Aluminum Pit
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Operations at Central Area
Looking N
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Mechanic Shop Area
Looking E
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Behind the Maintenance Shop Area
Looking E
R2-0001268
Drop Off and Metal Cutting AreaDrop Off and Metal Cutting Area
Looking E
R2-0001269
Scale Area
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Cleared WarehouseCleared Warehouse
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Central Area Scrap Mounds
Looking E
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A l th W i h St tiArea along the Weigh Station
Looking E
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Monitoring Wells: Local Area / Conditions
MW‐4A to left, MW‐1 on right (under tires)
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Sorting and Storage
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Several places with oil spills remain
R2-0001276
Former Crusher/Shear Buried at the Central Area
Looking E
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Northern Accessway / Entrance Looking N
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