14 Wall Street, Suite 1702 New York, New York 10005 Tel. 212-785-9123 Fax. 212-227-1692
October 12, 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: 3320‐016‐01074 SUBJECT: Site Reconnaissance: August 19, and October 7, 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 CDM at the Scorpio Recycling, Inc. (SRI) site on August 19, and October 7, 2011 during site reconnaissance. Photos taken during the visit are included as Attachments A and B.
August 19, 2011 ‐ Site Observations Attendee: Jose Reyes (CDM Field Technician) Operations: Four people (Mr. Manuel Figueroa, Gloria Rodriguez and two labors) were observed
working at the facility picking through scrap. Mr. Figueroa informed CDM that they continue to separate tires from their rims and store them (without decontamination) in the former Aluminum and Copper Brass Building.
Equipment at the Site: Bob Cat, Digger and a Track Excavator that appears to be damaged. Southern Area: No active work observed; no change apparent since prior visit with one large vine‐
covered soil pile and one tire pile. Observation: Some apparent new material was observed inside a warehouse on site. Northern Area: Four soil piles, four large scrap piles, ponding of water along an interior road and
near the base of several piles. A subcontracted surveyor marked the Northern Area grid locations; five locations of the grid are
pending location due to restricted access to these locations. Central Area: Piles are mostly composed of tires with scrap material in various proportions. Some
puddles were observed along the interior dirt roads. New clearings 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.
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Monitoring Wells: Both MW‐1 and MW‐4A were in good condition, yet MW‐1 was covered with mud. SRI’s subcontractor blocked and locked the northern access to avoid the entrance of trespassers.
Accessible Onsite Structures: Areas appear cleaner and with less trash/debris than in the past, except for the unused structure in the Southern Area which remains filled with assorted trash/debris.
October 7, 2011 ‐ Site Observations Attendee: Jose Reyes (CDM Field Technician) Operations: Three people (Mr. Manuel Figueroa and two labors) were observed working at the
facility picking through scrap. Mr. Figueroa informed CDM that they continue to separate tires from their rims and store them (without decontamination) in the former Aluminum and Copper Brass Building.
Equipment at the Site: One Digger and a Track Excavator that appears to be damaged. Southern Area: No active work observed; no change apparent since prior visit with one large vine‐
covered soil pile and one tire pile. Observation: Most of the piles are becoming vegetated. Northern Area: No change. Central Area: No change. 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, and dense vegetation has begun to cover this main accessway.
Monitoring Wells: MW‐4A and MW‐1 remain in good condition. Accessible Onsite Structures: No change. Key Issues in Moving the RI Forward Current conditions within the Northern Area would not support implementation of the proposed
subsurface investigation. Therefore, CDM and EPA have established an alternative approach for completing the field investigation, including the excavation of test pits at each boring site to confirm the absence of utilities. Shallow soil samples will be collected while the excavation is open. Composite characterization samples will be collected from within the soil/scrap stockpiles to characterize material expected to be removed during remedial action and inform the feasibility study.
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 that (1) PRP establish 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. Any plan developed/implemented by SRI to control the site perimeter with respect to potential contaminant migration should be provided to CDM.
Schedule CDM and EPA expect to begin final field investigation activities by October 31, 2011.
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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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