ML20217Q641

Responds to Requesting Mod to Ref Order on Consent.Amend 9 to Order,Authorizing Most Changes Requested Enclosed

ML20217Q641
Person / Time
Site:	05000054
Issue date:	02/10/1998
From:	Youngberg B NEW YORK, STATE OF
To:	Mcgovern J CINTICHEM, INC.
References
NUDOCS 9803120320
Download: ML20217Q641 (5)

Text

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g New Yerk State Dep:rtm:nt cf Envir:nm:ntal C:n;;rvatirn Division of Solid & Hazardous Materials Bureau of Pesticides & Radiation 50 Wolf Road, Albany, New York 12233-7255 518-485-8981 FAX 518-485-8390 John P. Cahill Commissioner February 10,1998

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I Mr. J. J. McGovern Plant Manager / President Cintichem, Inc.

P.O. Box 816 Tuxedo, New York 10987

Dear Mr. McGovern:

Re: Order on Consent Case #D200059005 This responds to your January 9,1998 letter requesting a modification to tl : above-referenced Order on Consent. You have requested that the Order be amended to ddete the requirement for sampling groundwater at monitoring wells 1s, 8s, 8d, 9s, 9d,11,12,13s, 13d,14s,14d,16,17s,17d,18s,18d,19s, and 19d. In your letter, you also requested that the Order be amended to delete the requirement for gamma spectroscopy analysis of samples i

from the remaining wells. During our telephone conversation on January 27,1998, you also I

asked that gamma spectroscopy analyses for all water samples be ended.

We have reviewed the information you submitted and the monitoring data from this site

i. im the past six years. Based on that review, we concur that monitoring in many wells may l

be suspended and that gamma spectroscopy analysis is no longer appropriate for most samples.

l Enclosed is an amendment to the Order on Consent authorizing most of the changes you requested. Please note that gamma spectroscopy analyses must continue for samples from the water treatment plant intake (S-13) and the discharge to the 001 outfall. In your letter, you j

did not refer to monitoring wells 10 and 15. The enclosed modification continues to require sampling of those two wells. Your letter contained contradictory statements regarding monitoring well 14D. Based on our review of the data, monitoring is not necessary at that well, and the enclosed modification does not require it.

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l 9803120320 980210 R

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o Mr'. McG6vern Page 2 If you have any questions, please call me.

Sincerely, Barbara Youn rg Supervisor, Radiation Section Bureau of Pesticides & Radiation Enclosure cc w/ enc.:

D. Orlando, NRC T. Michaels, NRC T. Dragoun, NRC D. Christian, DEE J. Kelleher, DOW

e.. :

STATE OF NEW YORK DEPARTMENT OF ENVIRONMENTAL CONSERVATION -

In the Matter of Violations of the Environmental Conservation Law ("ECL"), Articles 3,17,19 and Parts 201,380,703,750 ORDER ON CONSENT.

757 of Title 6 of the Official Compilation of Codes Rules and Case #D200059005 Regulations of the State of New York ("6 NYCRR") by:

Amendment No. 9 CINTICHEM, INC., and Hoffman-La Roche, Inc.,

Respondents.

In accordance with Paragraph XXVI of the January 1995 Order on Consent, Paragraphs V and VI of the Order on Consent are amended to read,

..(A) Retention pond (1) Releases from the retention pond to the 001 outfall shall be' on a batch-release basis. A water sample shall be collected prior

. to each batch release. The water may be released prior to sample analysis. If more than one sample is collected in one calendar day, the samples.may be composited for analysis. The samples shall be analyzed for strontium-90 within 15 working days of the day the sample was collected.

(2) In the event of heavy ainfall or surface run-off entering the retention pond, water may be continuously pumped from the retention pond to the 001 outfall if this is necessary to preserve the integrity of the pond. In that case, the retention pond shall be sampled every four hours.

If more than nne sample is collected in one calendar day, the samples may be composited for analysis. The samples shall be analyzed for strontium-90 within 15 working days of the day the sample was collected.

(3) Strontium-90 detected in releases from the retention pond shall be considered waste water subject to the limits set in Paragraph IV(C) of this Order, Page 1 of 3

(B) S-7 Runoff Cintichem may allow surface water runoff from S-7 to flow into the reservoir in accordann with the following:

(1) Cintichem shall collect weekly grab samples of the water released from S-7 and analyze the samples for strontium-90.

(2) Up to two weekly samples may be composited for strontium-90 analysis.

(3) Strontium-90 analyses shall be completed within 15 business days of the date the last sample in the composite was collected.

1 (4) Respondents shall collect a monthly grab sample at S-7 and analyze those wnples for the thirteen priority pollutant metals (i.e., antimony, arsenic, beryllium, cadmium, chromium, copper, lead, mercury, nickel, selenium, silver, thallium, and zine).

VI. Monitoring of Ground and Surface Water Respondents shall sample ground and surface water on the site and analyze samples for radioactivity as follows:

(A) S-4 (1) The water in S-4 shall be sampled (prior to treatment by ion exchange) and analyzed for strontium-90. Respondents shall sample and analyze the S-4 water weekly, unless the concentration of strontium-90 in S-4 exceeds 5 E-7 pCi/ml. In that case, S-4 shall be sampled and analyzed for strontium-90 daily until the concentration of strontium-90 has been.

less than or equal to 5 E-7 Ci/ml for thirty consecutive days.

(B)

S-13 The intake to the water treatment plant (S-13) shall be sampled and analyzed for gamma-emitters and strontium-90 on a weekly basis.

(C) S-1, S-3, S-18 and Monitoring Wells S-1, S-3, S-18, and monitoring wells ID,2S,2D,3S,4,5,6,7,10, and 15 shall be sampled and the samples analyzed to determine the concentration of strontium-90. The lower i

limits of detection of the strontium-90 analyses shall be in accordance with Paragraph VII of this Order. The frequency of sampling and analysis for each surface water sampling point and monitoring well shall be based on the highest results obtained from that sampling point or well either (1) during the previous thirty days or (2) in the last required sample (whichever occurred 1

more recently), according to this schedule:

Page 2 of 3 A

e Analysis Highest strontium-90 Concentration, Previous Frequency 30 Days Quarterly (minimum frequency)

Monthly

> 1 % EC W

_ eekly

> 10 % EC Daily

> EC (D) Additional Sampling and Analysis In the event that strontium-90 or gamma emitters are detected in a monitoring well or sampling point on site or in the Indian Kill Reservoir at a concentration equal to or greater than 10% (ten percent) of the EC, the Department may designate other wells to be sampled and analyzed for strontium-9/' end/or gamma emitters at increased frequencies. The frequencies shall be determined by th Department.

/'

f Paul J. Merges, Ph.D.

Chief, Bureau of Pesticides & Radiation Division of Solid & Hazardous Materials 1/d!T Date:

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