central roig sugar mills superfund site

C E N T R A L R O I G S U G A R M I L L S

S U P E R F U N D S I T E

Y a b u c o a , P u e r t o R i c o

W o r k P l a n

Prepared for:

Puerto Rico Land Authority (PRLA)

Environmental Protect ion Agency (EPA)

Prepared by:

Riclem Environmental Corp. (REC)

October 2014

CONFIDENTIALITY NOTE: This communicat ion contains information belonging to RICLEM Environmental Corp. and w hich is

confident ia l and/or legally privileged. The information is intended only for the use of the individual or entity named above. I f you are

not the intended recipient; you are hereby not ified that any disclosure, copying, distribut ion or the taking of any act ion in reliance on

the contents of said information is strict ly prohibited. I f you have received this communicat ion by error, please delete it from your

computer and not ify us immediately.

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Puerto Rico Land Authority Page i

WORK PLAN October 2014

Central Roig, Yabucoa, PR Rev. 2

TABLEOFCONTENTS LIST OF TABLES ............................................................................................................................................ iii

APPENDICES ................................................................................................................................................... iv

1 GENERAL ................................................................................................................................................. 1

1.1 Introduction .......................................................................................................................................... 1

1.2 Site Description .................................................................................................................................... 2

1.3 Scope of Work ..................................................................................................................................... 3

2 SITE ORGANIZATION AND RESPONSABILITIES ............................................................................. 4

2.1.1 Roles and Responsibilities ............................................................................................................ 4

2.1.2 Certification and Training Requirements ..................................................................................... 8

2.2 Project management ............................................................................................................................. 8

2.2.1 Work Hours .................................................................................................................................. 9

2.2.2 Work Schedule ............................................................................................................................. 9

3 SAFETY ................................................................................................................................................... 11

3.1 Site Access Control ............................................................................................................................ 11

3.2 Work Zones ........................................................................................................................................ 11

3.3 Personal Protective Equipment .......................................................................................................... 13

3.3.1 Project Specific PPE ................................................................................................................... 14

3.4 Emergency Procedures ...................................................................................................................... 16

4 SITE ACTIVITIES ................................................................................................................................... 16

4.1 Mobilization ....................................................................................................................................... 17

4.2 Sampling of unknown chemicals ....................................................................................................... 18

4.3 Characterization of Used oil in Building 2 lubricating pits ............................................................... 19

4.4 Characterization of Ash piles located in Building 6. ......................................................................... 20

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4.5 Sampling of suspected Asbestos-containing materials (SACM) ....................................................... 21

4.6 Sample Collection and Analysis ........................................................................................................ 23

4.6.1 Sample Containers and Sample Identification ........................................................................... 24

4.6.2 Sample Custody and transportation ............................................................................................ 24

4.6.3 Sample Analysis ......................................................................................................................... 25

4.7 Waste staging and handling ............................................................................................................... 27

4.8 Waste Transportation and Disposal ................................................................................................... 28

5 DECONTAMINATION PROCEDURES ................................................................................................ 29

6 AIR SURVEILLANCE ............................................................................................................................ 29

6.1 Dust Control ....................................................................................................................................... 30

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LISTOFTABLES Table 1 PPE Selection for the Exclusion Zones per Task ................................................................................ 14

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APPENDICES

Appendix A Administrative Order For a Removal Action

Appendix B Site Map

Appendix C Personnel Certifications

Appendix D Site Specific Health and Safety Plan (SSHP)

Appendix E Sampling and Analysis Plan (SAP)

Appendix F Transportation and Disposal Plan (TDP)

Appendix G Bridge Security, Inc. Company Information

Appendix H Asbestos‐Specific Work Plan; including Asbestos‐Specific Health and Safety Section

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Puerto Rico Land Authority Page 1 of 30

Work Plan October 2014


1 GENERAL

1.1 Introduction

Riclem Environmental Corp. (REC) has been contracted by the Puerto Rico Land Authority (PRLA) for

carrying out the activities associated with the Administrative Order for a Removal Action CERCLA-02-

2014-2026 at PR-3 Km. 13.1 Bo Aguacate in Yabucoa, PR. (Appendix A) This Work Plan (WP)

provides procedures and requirements for field activities to be performed as per scope of work (Section

1.3) during the Central Roig Sugar Mills Superfund Site Project in order to ensure the health and safety

of all employees, visitors and surrounding communities, as well as, to comply with all State, EPA and

OSHA requirements.

The objective of this WP is to:

provide an overview of all components required to perform all project’s activities in compliance

with State, EPA and OSHA requirements as per scope of work (Section 1.3);

describe organizational structure and personnel responsibilities;

establish clear lines of communication;

ensure safe working conditions by performing hazard assessments of all project phases (task by

task – waste inventorying, sampling, segregation, characterization, decontamination procedures,

transportation, disposal, etc.) and implementing controls, establishing mitigation responses,

personal protection measures and emergency procedures.

This plan has been developed to conform to OSHA requirements of 29 CFR 1910.120, Resource

Conservation and Recovery Act (RCRA), Department of Transportation (DOT) for hazardous

substances and other applicable federal, state, and local regulations.

The following additional plans have been submitted as attachments:

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Specific Site Health and Safety Plan (SSHP) - This plan includes delineation of work zones,

personnel monitoring requirements, decontamination procedures, personnel qualification, on-site

work protocols in compliance with OSHA, contingency planning, air surveillance program,

emergency procedures, emergency contacts, routes and information to nearest hospital.

Sampling and Analysis Plan with Quality Assurance/Quality Control – This plan includes all

sampling and analysis work protocols in compliance with EPA policy and guidelines, quality

assurance, quality control, data validation and chain of custody procedures.

Transportation and Disposal Plan – This plan includes all procedures for the proper

transportation and disposing of all hazardous substances, identification of the proposed disposal

facilities for all waste streams (Id numbers), waste profile information, facility acceptance

documentation, analytical characterization of each waste stream, and disposal facility

inspections and permit status

1.2 SiteDescription

The Site is located at Yabucoa, Puerto Rico in a large agricultural area bordered by the Puerto Rico

Central mountain chain to the north, south and west, and the Atlantic Ocean to the east. The Central

Roig facility was operated as a sugar cane refinery for more than 80 years but ceased operations and

was abandoned in 2001. The Site currently includes approximately 16 structures of various sizes used

for storage of sugar, equipment/machinery parts, and machinery, as well as for the operation of a sugar

cane processing line. The structures include a small laboratory building which is located adjacent to

the main building complex and contains many containers of hazardous chemicals. This building is

located along the east side of Building 1 and north of Building 5. Refer to Appendix B for a Site Map.

On February 23, 2012, an EPA On-Scene Coordinator (OSC) performed an inspection of the site.

During this inspection, EPA discovered suspect asbestos-containing material (SACM) on facility floors

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and pipes and in boiler room areas, as well as unsecured laboratory chemicals throughout many

portions of one of the Site buildings. On February 4, 2014 EPA OSCs inspected the facility to assess

and document Site environmental conditions. Additional containers (40) of chemicals containing

hazardous substances within the former maintenance building (Building 8) were identified. During the

same inspection, in Building 8 the OSCs observed five (5) 55-gallon plastic drums of Busan 1016

pesticide which, according to the manufacturers material safety data sheet, is considered to be a

characteristic waste under the Resource Conservation and Recovery Act (RCRA). In addition, large

amounts of oil within reservoirs beneath the sugar cane processing equipment were observed within

Building 2.

Based on this information, EPA issued an Administrative Order for a removal action to the

Respondent, Puerto Rico Land Authority (PRLA) to provide Site security, remove the abandoned

laboratory chemicals, pesticides, and loose asbestos-containing materials and characterized used oil in

Building 2 and three (3) ash piles located at Building 6. Refer to Appendix B for Site map.

1.3 ScopeofWork

The following Work Plan (WP) relates exclusively to the following activities:

removal and disposal of drums/containers from all facility buildings;

characterization of used oil in Building 2 lubricating pits and two (2) above ground storage

tanks (AGST) and disposal of oil found to contain CERCLA hazardous substances; cleaning of

these two AGST after oil removal.

Proper abatement, handling and disposal of all asbestos-containing materials, exclusively

asbestos-containing roofing materials present on former building floors, on ground surfaces and

comingled with demolition debris.

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2 SITEORGANIZATIONANDRESPONSABILITIES

The purpose of this section is to identify the roles and responsibilities of each organization and

personnel working on this Project, so as to establish a clear chain of command and line of

communication.

2.1.1 RolesandResponsibilities

The following list contains detailed information regarding the responsibilities of each of the participating organizations.

Andrew Confortini – Environmental Protection Agency On-Scene Coordinator (EPA

OSC), evaluate and approve the sampling plan; in addition, he will conduct oversight

of the implementation of the Administrative Order for a Removal Action. The EPA

OSC, or his authorized representative, has the authority to halt, conduct, or direct any

work required by the Administrative Order for a Removal Action, or to direct any

other response action undertaken by EPA or Respondents at the Site consistent with

the Administrative Order for a Removal Action.

Juan Rojas – Puerto Rico Land Authority General Manager – Responsible for

approving signing waste manifests, coordinating meetings and conference calls with

EPA authorized representatives.

Víctor Pagán – Riclem Environmental Corp. Project Manager. Responsible for

overseeing all projects’ operations including planning, directing and preparing of the

project’s schedules for the environmental project activities. He will supervise and

coordinate activities during the Project. He must ensure that Project activities meet

approved Safety and Security Plan descriptions and will notify personnel of changes

in protection level when the Health and Safety Manager Alternate so deems

necessary. Daily conference call with PRLA General Manager and EPA OSC to

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discuss daily project status (work performed and work to be performed next working

day)

Victor Pagán – Riclem Environmental Corp. Health and Safety Manger. Responsible

for the evaluation and approval of the Safety and Security Plan. He must ensure that

Project activities meet approved Safety and Security Plan descriptions.

Juan Hernández – Riclem Environmental Corp. Health and Safety Manger, Alternate.

He must ensure that Project activities meet approved Safety and Security Plan

descriptions.

Juan Hernández – Riclem Environmental Corp. Project General Supervisor. In

charge of implementing the Sampling Plan. Moreover, he will supervise sampling,

field activities and mobile laboratory operations. He must ensure that project activities

meet approved Sampling and Analysis Plan descriptions. Implement Air Surveillance

Program, daily calibration of equipment and serve as the Emergency Coordinator

throughout the project.

Jorge Rivera – Riclem Environmental Corp. Project Used Oil Supervisor. In charge

of supervising sampling, field and disposal activities relating to used oil. He must

ensure that project activities meet approved Sampling and Analysis Plan descriptions.

The supervisor receives directions from Riclem Project Manager and/or Riclem

Project General Supervisor. Submit daily field activity reports to the Project General

Supervisor.

Javier Medina – Central Industrial Services, Inc. Project Asbestos Sampling

Supervisor. In charge of supervising sampling, field and disposal activities relating to

asbestos containing materials. He must ensure that project activities meet approved

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Sampling and Analysis Plan descriptions. Submit daily field activity reports to the

Project General Supervisor. All asbestos field technicians are licensed by the

Environmental Quality Board. Experienced supervising Class I and II Asbestos

Activities in compliance with NESHAP.

Javier Rivera – Riclem Environmental Corp. Project Ash Supervisor. In charge of

supervising sampling, field and disposal activities relating to ash. He must ensure

that project activities meet approved Sampling and Analysis Plan descriptions. The

supervisor receives directions from Riclem Project Manager and/or Riclem Project

Field General Supervisor. Submit daily field activity reports to the Project General

Supervisor.

Julio A. Rodríguez – Environics Project Hazardous Substances Supervisor. In charge

of supervising sampling, field and disposal activities relating to Hazardous Wastes.

He must ensure that project activities meet approved Sampling and Analysis Plan

descriptions. The supervisor receives directions from Riclem Project Manager and/or

Riclem Project Field Laboratory Manager. Submit daily field activity reports to the

Project General Supervisor.

Juan Santos, José Rivera, Javier Rivera - Riclem Environmental Corp. Vacuum

Operator, Drivers . Responsible for transferring used oil to tank trucks, movement of

heavy equipment and non-hazardous waste transportation.

Jossie Martínez - Environics Driver. Responsible for hazardous waste transportation.

Juan Santos Serrano, Enrique Santos Maldonado, José Santiago, Carlos Cartagena

Vázquez, Manuel Santos Marrero, Luis Torres Núñez, Alexis Rivera, Alexis Collazo

Maldonado, Jimmy Mateo Matos, Braulio Mateo Matos, Marcos Colón Rivera, Javier

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Rivera Martínez, Javier Rivera Clemente, José Rivera, Javier Rivera Martínez, Javier

Rivera Clemente, José Rivera Martínez, Javier Rivera Clemente, José Rivera

Clemente- Riclem Environmental Corp. Field Technician. Responsible for chemical

Inventorying, sampling, segregating, lab packing/over packing unknown chemicals,

transferring used oil to tank trucks, drum handling, staging and transportation of non-

hazardous material.

Antonio Rodrígues Rivera, Auriel Martínez Segarra, José A Veléz Sánchez, Pedro

Casiano Rodríguez, Freddie Pacheco Vargas, Wilson Santiago Torres - Central

Industrial Services, Inc. Asbestos Field Technicians. Responsible for sampling,

packaging, handling, and disposing of asbestos-containing materials. All asbestos

field technicians are licensed by the Environmental Quality Board.

Julio A. Rogríguez, Jossie Martínez, Ernesto Cuascut, Julio D. Rodríguez, Ezequel

González, Raymond Ríos Ortíz, Luis A. Ruíz Torres - Environics Field Technicians.

Responsible for handling, transportation and disposal of hazardous material.

José Irizarry, Wilma Ocacio – Riclem Environmental Corp. Environmental

Technician. Responsible for sampling activities.

María Pagán – Riclem Environmental Corp. Mobile Laboratory Supervisor.

Responsible for mobile laboratory sample management and HAZCAT analysis.

Receives directions from Riclem Project Manager and/or General Project Supervisor

Submit daily field activity reports to the Project General Supervisor.

The line of communication will flow from Riclem Project Manager to PRLA General Manager to

EPA OSC and vice versa.

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2.1.2 CertificationandTrainingRequirements

All employees working on-site who are exposed to potentially hazardous substances, health hazards,

or safety hazards and their supervisors and management responsible for the site shall receive training

before they are permitted to engage in site activities. Employees will not be permitted to participate in

or supervise field activities until they have received appropriate training for their job function and

responsibility.

All working personnel on this Project must have completed the following trainings: OSHA 40-hr

Hazardous Waste Operations, Emergency Response HAZWOPER and 8 hours Refresher Course 29

CFR 1910.120. All project activities performed must in compliance with what has been established in

this Work Plan (WP) and in the Site Specific Health and Safety Plan (SSHP), Sampling and Analysis

Plan (SAP), Transportation and Disposal Plan (TDP) and Asbestos-Specific Work Plan (AWP) after

approval by Environmental Protection Agency (EPA). (Appendix D, Appendix E, Appendix F and

Appendix H). For all asbestos-specific matters, refer to Appendix H.

2.2 Projectmanagement

Riclem Project Manager is principally responsible for planning, coordinating, monitoring and

controlling project activities, as well as, project management activities. Project management activities

include, but are not limited to:

Providing updates to the Respondent’s representative and/or Project Coordinator.

o Prepare weekly project progress reports to satisfy the requirements of paragraphs 64 of

the EPA Administrative Order for a Removal Action. All reports will be submitted to

the Respondent’s representative electronically. The purpose of these reports is to

update the Respondent’s representative of project progress and overall program status

and to provide a schedule of the actions which will be performed the following week.

The Respondent’s representative and/or Project Coordinator is responsible to deliver

this update to the EPA OSC.

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Daily Updates - Daily conference call with PRLA General Manager and EPA OSC to

discuss daily project status (work performed and work to be performed next working

day)

Daily Logs – Each supervisor will generate a daily log of work performed. This document

should include daily performed activities, test performed, weather conditions, material and

equipment used, Truck ID, incidents, delays, corrective actions, etc. Daily logs should be

submitted to the Project General Supervisor.

Preparing a Final Report to satisfy requirements of paragraphs 65 of the EPA Administrative

Order for a Removal Action.

2.2.1 WorkHours

Riclem Environmental Corp. proposes a six day working schedule from Monday through Friday

from 7 am to 6pm and Saturdays from 8 am to 5 pm. Please note that the daily schedule will be

modified and updated on a daily basis and are dependent on weather conditions and daylight

illumination.

2.2.2 WorkSchedule

The schedule for implementing the Site Activities (Section 4) is estimated to be 6 weeks after

approval of plans by the EPA. Please note that the work schedule will be modified and updated on a

daily basis and are dependent on weather conditions and daylight illumination. Additionally,

Asbestos work activities are dependent on work permit approval by the Environmental Quality Board

(EQB) which will be petition as an emergency. Although 6 weeks have been estimate to complete

field work additional time may be necessary to complete waste disposal activities. Below estimate

timeframe:

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3 SAFETY

3.1 SiteAccessControl

Only Authorized personnel will have access to the Site. Any evidence of unauthorized entry should be

noted in the Tailgate Safety Meeting Log (SSHP Appendix D), and the Site Manager shall be

immediately notified. Prior to entry to the site, all visitors must receive a Site-specific orientation

briefing including latest tailgate safety information.

Starting the first day of mobilization, Bridge Security, Inc. will provide effective site security 24/7 and

will aid in preventing the following:

Exposure of unauthorized, unprotected people to Site hazards;

Increased hazards from vandals;

Interfaces with safe working procedures; and

Site visitors, as well as site personnel, will be required to sign a Daily Site Sign-In/Sign-Out

Log (SSHP Appendix F)

Refer to Appendix G Company Information.

3.2 WorkZones

The site must be controlled to ensure that all site personnel, visitors, and general public are not at a

high risk of exposure to site hazards. After crew mobilization to the Site, a three zones approach in

controlling site activities will be implemented in this project per scope of work (Section 1.3). These

zones consist of the Exclusion Zone, Contamination Reduction Zone, and Support Zone. Movement of

personnel and equipment between these zones and onto the site will be strictly regulated through

access control points. The objective of implementing these work zones is two-folded; to prevent

possible exposure of hazardous materials to unprotected site personnel during project activities; 2) to

prevent removal or migration of contaminants from and within the site during different field activities

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(i.e. asbestos abatement, oil characterization, etc.). Refer to SSHP Section 2.7. REC will provide Site

safety by clearly marking work zones, and areas near roadways with lights, tape and/or barricades.

List of Support Zone Activities

The Command Post supervises all field operations and field teams. Maintains communications,

including emergency lines of communication. In this area will be kept the recordkeeping, including:

Accident reports;

Chain-of-custody records;

Daily logs;

Manifest directories and orders;

Personnel training records;

Site maps;

Up-to-date site Health and Safety Plan.

In this area will be:

Provided access to up-to-date safety and health manuals and other reference materials.

Interfacing with the public: government agencies, medical personnel, and other interested

parties.

Monitoring work schedules and weather changes.

Maintaining site security.

Sanitary facilities.

In the Support Zone will be established the Medical Station First-aid administration, including:

Medical emergency response, First Aid Kit

Medical monitoring activities.

An Equipment and Supply Center with:

Supply, maintenance, and repair of communications, respiratory, and sampling equipment.

Replacement of expendable supplies.

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Storage of monitoring equipment and supplies. Storage may be here or in an onsite field

laboratory.

The Administration of this project:

Interface with Company home office and the Central Roig Management.

Maintenance of emergency telephone numbers, evacuation route maps, and vehicle keys.

Coordinates with transporters, disposal sites, and appropriate federal, state, and local

regulatory agencies.

Mobile Laboratory

Coordination and processing of HAZCAT Samples.

Coordination with outside laboratory for sample collection and/or pickup.

Copies of the sampling procedures should be available for quick reference in the laboratory.

Chain-of-custody files will be kept in the Command Post.

Maintenance and storage of laboratory notebooks in designated locations in the laboratory

while in use, and in the Command Post when not in use.

3.3 PersonalProtectiveEquipment

OSHA 29 CFR 1910.132 Personal Protective Equipment (PPE) Standards, requires the employer to

determine the appropriate personal protective equipment for each hazard encounter at a site assessment,

response and/or work activities. In this section are describe the four (4) levels of PPE used. The levels of

protection to be utilized by site personnel during the site project activities will be clearly defined in

SSHP Section 4.6, Site Specific PPE. The HSO will have authority to upgrade or downgrade these levels

of protection as deemed necessary or prudent.

PPE will be selected to protect workers from the hazards they are likely to encounter as identified in the

hazard assessment. Selection of equipment is based on an evaluation of the performance characteristics

of the PPE relative to the requirements and limitations of the site, manufacturer recommendations, the

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task-specific conditions and duration, and the hazards and potential hazards identified at the site. Ideally,

the chosen material(s) must resist permeation, degradation, and penetration by the respective chemicals.

Respirators must be worn during work operations that involve unknown exposures, during operations

that requires entry into tanks or close vessels and during emergencies. Refer to the Asbestos-Specific

Work Plan (AWP) (Appendix H) for Safety measures and PPE requirements specific for those

activities.

3.3.1 ProjectSpecificPPE

All personnel working at the Exclusion and Contamination Reduction Zone during the different

activities per project main four tanks will use Level C of personal protection.

Table 1 PPE Selection for the Exclusion Zones per Task

Task Activity PPE Level

Removal and Disposal of unknown chemicals from all facility buildings

Inventorying, Sampling, Segregating, Lab packing/over packing A B C D, other ___ Mod.

Characterization and Disposal of used oil in Building 2 lubricating pits and

two (2) AGST

Transferring Oil to Tank Trucks and Tanks, Sampling A B C D, other ___ Mod.

Cleaning of two (2) AGST after used oil removal

Confined Space Entry; cleaning, wiping and removing all residual liquid/sludge from the tanks

A B C D, other ___ Mod.

Characterization and Disposal of three (3) ash piles

Sampling, packaging A B C D, other ___ Mod.

abatement, handling and disposal of all asbestos-containing materials

Sampling, packaging A B C D, other ___ Mod.

The following equipment constitutes Level B protection:

Wear Full-face-piece, pressure-demand, SCBA supplied-air respirator or an airline with

supplied air respirator. (SSHP Appendix I)

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Chemical-resistant clothing (coveralls) made of ammonia-impervious materials. Tychem®

SL, F, Responder® or TK (>8 hrs. breakthrough for ammonium hydroxide in less than 30%

solution).

Chemical-resistant gloves. Inner nitrile gloves and outer butyl rubber, neoprene or Viton (>8

hrs. breakthrough for ammonium hydroxide in less than 30% solution).

Chemical resistant safety boots and boots cover.

Hard hat.

Two-way radio communications.

Optional: cooling system.

In addition, all openings will be securely taped to further reduce the possibility of skin

contact.

The following equipment constitutes Level C protection:

Wear Full-face-piece air purifying respirator with NIOSH certified cartridge for organic vapors

and particulates; (Refer to Appendix E)

Chemical-resistant clothing (coveralls) made of impervious materials. Tychem® SL, F,

Responder® or TK (>8 hrs. breakthrough for ammonium hydroxide in less than 30% solution).

Chemical-resistant gloves. Inner nitrile gloves and outer butyl rubber, neoprene or Viton (>8

hrs. breakthrough for ammonium hydroxide in less than 30% solution).

Chemical resistant safety boots and boots cover.

Hard Hat

Two-way radio communication

Optional: escape SCBA

Personnel outside in the Support Zone will use a Level D protection. The following equipment constitutes a Level D Protection PPE:

Basic uniform /coveralls.

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Safety boots.

Gloves.

Eye protection: safety glasses or chemical splash goggles.

Hard Hat

Reflective Vest

Optional: escape SCBA, face-shield.

Refer to SSHP Section 4 for more information.

3.4 EmergencyProcedures

Emergency response is required in order to tend to unplanned incidents requiring immediate attention.

Riclem Environmental Corp (REC) will respond to an emergency as quickly as possible. In order to

maintain contact between workers and the various operations that may be occurring on site, workers at

the site will use several different forms of communication. The method of communication to be used

on site will be determined by such factors as, site and working conditions, as well as the current

operations. It will be the responsibility of the Site HSO in coordination with the Central Roig Project

Manager, to determine the most appropriate form of communication. Hand signals, Buddy System,

two-way radio devices, air horns will be use during project activities. Contingency Planning

Procedures like contacting local fire/police and nearby hospital, as well as, Emergency Contact

Numbers, Emergency Notification and Response are detailed in SSHP Section 8.

4 SITEACTIVITIES

Strong safety awareness will be kept during all project activities. Daily safety meetings will be

performed in order to review existing procedures and serve as a mechanism to update personnel on new

Site conditions and requirements. (SSHP Section 2.5.2) The levels of protection to be utilized by site

personnel during the site project activities is clearly defined in SSHP Section 4.6, Site Specific PPE. All

employees must wear appropriate PPE to perform field activities. REC technicians will perform air

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monitoring to detect and quantify any volatile organic compounds (VOCs) in the work site and to ensure

that all personnel are adequately protected from potential organic vapors hazards. (Refer to Section 6)

4.1 Mobilization

Riclem Environmental Corp. will mobilize the crew to the Site with the following equipment:

Quantity Description

2 6,000 gallon storage tanks

1 4,000 gallon vacuum truck

1 3,000 gallon vacuum truck

200’ 3-inch suction hose

2 Hazmat Emergency Response pick-up vehicles

2 Storage Van Containers for tools and material storage

3 Towing Vehicles

1 Non-potable water tank to control dust in unpaved roads

1 Digger

1 Finger

1 Excavator

1 Loader

3 Roll off vehicles

6 20 yards Van Container

1 30 yards Container

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4.2 Samplingofunknownchemicalscurrentlylocatedintheformerlaboratory,Building8and/oranyotherfacilitybuilding;

Before sampling activities, information will be gathered by inventorying chemicals.

Information gathered will include but is not limited to:

Labels or markings

Container material and size (glass, 1L, etc.)

Manufacturer’s information

Appearance (deteriorated, bulging, leaking, etc.)

Conditions (containers with unbroken security seal, close with broken seal, unsealed,

uncovered, broken, etc.)

Physical / visible description (stratified layers, colors, matrix, etc.)

Once the above information has been evaluated, containers will be segregated into the following three

categories:

1. Category #1 - containers with unbroken security seal and labels.

2. Category #2 – possible unknown; close containers with a broken security seal but with

labels.

3. Category #3 - unknown containers; unsealed, uncovered, broken, deteriorated containers

with or without labels.

After container segregation into these three categories, project activities will be performed as follows:

1. Category #1: Research SDS. Lab pack same and/or compatible materials.

2. Category #2: Research possible SDS. Collect (1) sample from each container for Hazcat

analysis and RCI, TCLP Metals, TCLP VOC, TCLP SVOC, TCLP Pest/Herb as needed.

Lab pack same and/or compatible materials, if applicable, based on analytical data.

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3. Category #3: Collect (1) sample from each container for Hazcat analysis and Full TCLP

and PCB’s. Lab pack same and/or compatible materials, if applicable, based on analytical

data.

After samples have been collected, where applicable as detailed above, and analytical data and/or

SDS have been evaluated from each category; technicians will prepare lab packs by properly classify

hazardous waste in accordance with US Department of Transportation (DOT) and Environmental

Protection Agency (EPA) regulations.

HAZCAT analytical results will be used to classify samples and segregate waste into different

categories, including auto-reactives, water reactives, heavy metals, oxidizers, etc. Category #2 will be

characterized under RCRA for disposable as applicable and Category #3 chemicals would need full

characterization under RCRA for disposal in the USA to include full TCLP and PCB.

Analytical results will be compared to limits found on SAP Section 5.1.5 and wastes will be

classified as hazardous or non-hazardous for proper transportation and disposal, as well as, to meet

final destination waste facility requirements.

4.3 CharacterizationofUsedoilinBuilding2lubricatingpitsandtwo(2)AboveGroundStorageTanks(AGST)

Used oil will be characterize and dispose of according to results classification as Hazardous or Non-

Hazardous per Section SAP Section 5.2.4. If results are above 40 CFR 279.11 limits, additional

analyses may be run as needed (TAL, TCL Pest/Herb & PCBs). A composite sample per area will be

analyzed for Full TCLP to determine waste characterization and disposal requirements.

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Used oil found in Building 2 lubricating pits and two (2) ASGT will be transfer by negative pressure

to tank trucks using industrial 3” suction hose. Two (2) 6,000 gallon storage tanks will be available at

the site. One (1) representative sample will be collected from each tank. Sufficient sample will be

collected to perform off-site characterization as per 40 CFR 279.11 Refer to SAP Section 7 for

Sample Management Collection Procedures.

The following analyses are required Heavy Metals, Flash Point, Total halogens and Total PCBs.

Analytical results will be compared to limits found on SAP Section 5.2.4, if results are above these

limits, additional analyses may be run as needed (TAL, TCL Pest/Herb & PCBs), a composite sample

per area will be analyzed for Full TCLP. Based on analytical results, wastes will be classified as

hazardous or non-hazardous for proper transportation and disposal, as well as, to meet final

destination waste facility requirements.

4.4 Cleaningoftwo(2)AGST

Tank cleaning activities will be performed as per API Publication “Cleaning Petroleum Storage

Tanks”. Initially, an external inspection of the tanks and visual assessment of the immediate area will

be conducted. REC’s employees must request a confined space entry permit which will be issued by

the site HSO only to trained personnel with proper qualifications after work area inspection. All

permit-required procedures and testing will be in place for the duration of the entry. Refer to SSHP

Appendix L for Confined Space Entry Permit Form. Work area should be free of flammable materials;

sources of ignitions will be controlled in, around and on the tanks. Tanks will be degassed and

periodical testing for flammable vapor will be conducted throughout the work activities. Tanks will be

opened for entry and all residual liquids/sludge will be removed. Degreaser and water will be applied

at 4,000 to 5,000 psi. Wash water and residual liquids/sludge will be suctioned and transferred to tanks

trucks. Sampling and analysis will follow as per Section 4.3. Samples will be analyzed for 40 CFR

279.11 requirements, TAL, TCL Pesticides, Herbicides and PCBs, and Full-TCLP, as needed to

determine waste characterization and disposal requirements. Analytical results will be compared to

limits found on SAP Section 5.2.4 and wastes will be classified as hazardous or non-hazardous for

proper transportation and disposal, as well as, to meet final destination waste facility requirements.

R2-000368




4.5 SamplingofsuspectedAsbestos‐containingmaterials(SACM),exclusivelyasbestos‐containingroofingmaterialspresentonformerbuildingfloors,ongroundsurfacesandcomingledwithdemolitiondebris.

Scope of work: sampling of suspected Asbestos containing materials (SACM), exclusively SACM

roofing materials present on former building floors, on ground surfaces and comingled with

demolition debris for disposal. Based on analysis, suspected Asbestos containing materials will be

dispose of according to results classification as Hazardous or Non-Hazardous per SAP Section 5.4.4;

Samples will be collected per area to be able to determine asbestos concentration, if any, and for

those confirmed asbestos containing materials, waste will be dispose of according to results

classification.

In order to assess Central Roig current conditions and propose an asbestos National Emission

Standards for Hazardous Air Pollutants (NESHAP) compliant procedure to abate, remove and

dispose of SACM, a RICLEM and Central Industrial Services, Inc. (RICLEM’s Asbestos

subcontractor) representatives conducted a field visit to the Site. Assessment was made specifically

for those areas with asbestos-containing roofing materials found on former building floors, on ground

surfaces and comingled with demolition debris.

A separate document with all Asbestos proposed work will be submitted to the Environmental

Quality Board (EQB) for a work permit approval. An Asbestos-Specific Work Plan (AWP) prepared

by Analytical Environmental Services Intl. (AESI) has been included in Appendix H. Work Covered

in this AWP will be performed by Central Industrial Services, Inc (CIS) and its sub-contractor

Analytical Environmental Services Intl. (AESI) and includes; handling of decontamination, packing,

disposal and the incidental procedures and equipment required to protect workers, employees and by

passers, or all, from contact with airborne asbestos fibers that may be generated from the sealants on

roof metals scrap panels laying on the floors. The roof-sealants were classified by EPA as ACM and

they are further classified as Category I, miscellaneous, non-friable ACM. Specifically, the work

covered is for non-friable asbestos containing sealants on metal panels and assumed ACM debris that

R2-000369




might have been peeled off the panels, all located on the concrete pads of buildings/building

footprints identified as 5, 6, 9, 11 and 12, as well as on the soil of the exterior adjacent open areas.

Work shall be performed in accordance with 29 CFR 1926.1101, 40 CFR 61-SUBP ART A; 40 CFR

61-SUBPART M, ASHARA (Asbestos School Hazard and Reduction Act), Rule 422 and the

Regulation for the Control of atmospheric pollution and the requirements specified in the AWP

(Appendix H).

The site shall be prepared for cleaning and for protection of the public. Barricades shall be erected

and approved warning signs as per OSHA requirements shall be set at each structure entrance to

control accessibility only to pre-qualified personnel, supervisor, inspector, and the Industrial

Hygienist. All materials are to be maintained wet during the project.

The work will be performed in two phases. A general description of the two phases is presented

below. Detailed description of the work is shown in the AWP Section 12 (Appendix H):

Phase I (Refer to Page 46-47 of the AES Work Plan)

Overview: Phase I will focus on addressing those roofing panels which contain ACM that are located

upon concrete floors.

Phase I will include the following tasks:

Decontamination, packing and temporary storage on site of the metal corrugated panels

with asbestos containing sealants present on the concrete pads inside the five metal

structures, outside on the foot prints of the demolished structures and outside on the soil

surfaces.

Gross clean up the concrete pads inside the buildings using mechanical means followed by

HEP A vacuuming and wet techniques.

Performance of visual examination followed by collection of air clearance samples.

R2-000370




Phase II (Refer to Page 47-48 of the AES Work Plan)

Overview: Phase II will focus on addressing those roofing panels which contain ACM that are

located upon open soil adjacent to the concrete floor slabs.

Phase II will include the following tasks:

Controlled trimming of vegetation in the open area adjacent to the structures assuming

ACM-contaminated and disposal as ACM.

Removal of 1/2-inch of top soil surface assuming soil is ACM-contaminated.

Performance of visual examination followed by soil sampling on a grid block pattern.

During and upon completion of these two phases, all temporary stored ACM must be appropriately

disposed of (Refer to Appendix H AWP Section 14 for more information).

4.6 SampleCollectionandAnalysis

All samples protocols and sampling quality assurance (QA) procedures are as specified in the SW-846

Test Methods for Evaluation of Solid Waste and American Society for Testing and Materials (ASTM)

methods. (SAP Appendix D)

These sampling protocols will ensure that throughout this project:

All samples collected are representative of the media being sampled.

Proper sampling, preservation, sample handling and quality control techniques are observed.

Proper record keeping and good documentation practices are followed (i.e. identification of

samples, COC documentation, field records)

In general, liquid samples will be collected using a coliwasa, or bailer. Soil samples will be collected

with scoops, hand augers, trowels or trier. As sampling equipment construction materials can affect

analytical results, only materials that will not contaminate samples will be use and decontamination

R2-000371




protocols will be strictly followed as to avoid sample cross-contamination. Refer to SAP Appendix D

for Sampling Methods.

Samples will be collected for analyzed for RCI, TCLP Metals, TCLP VOC’s, TCLP SVOC’s, TCLP

Pest/Herb, PCBs, Total Metals, and Asbestos, as needed.

4.6.1 SampleContainersandSampleIdentification

Pre-cleaned containers and zip-lock bags will be provided by the laboratory. Refer to SAP Section

8.1 for sample containers, preservation and hold times information per parameter of interest. Unique

tracking numbers will be assigned to each container or waste pile that is sampled, starting with

location of the sample (example use “FL”, “B8”, “B6” for chemicals found in the former laboratory,

Building 8 and Building 6, respectively). The identification code will end with an increasing three

digit number starting at “001” that identified the number of samples being collected. A marking

and/or label will be attached to the outermost surface of each container or, will be posted at each

waste pile. The unique tracking number on the container will be legible and faced in an outward

direction. The tracking number will be recorded on the sample container, sample tracking and chain

of custody form (SAP Appendix E).

4.6.2 SampleCustodyandtransportation

All sample containers will be labeled as described on SAP Sections 5.1.4.1, 5.2.3.1, 5.3.3.1. Labels

should be properly filled with the necessary information (SAP Appendix F) as described on SAP

Section 7.2 before sampling event.

Sample containers will be sealed once samples have been collected and placed on a cooler filled with

ice. Samples must be kept at 4°C, until delivered to the laboratory. Samples should be delivered to

the laboratory with the appropriate Chain of Custody properly filled. (SAP Appendix G)

R2-000372




The Chain of Custody Form should include the following information:

Laboratory Information (Address, Telephone)

Chain of Custody Control Number

Project Name and Location

Client’s Representative on Project

Laboratory’s Representative on Project

Project Identification Number

Project Description

Name and signature of person in charge of Project

Sample Identification

Duplicate Field Sample Identification

Rush Sample Identification

Preservatives

Container number and type

Sample Description

Sample Matrix

Sample Type (grab or composite)

Date and Time of sample collection

Parameters to be analyzed

Date and time, name and signature of person authorized for simple transportation outside Project location (Chain of Custody transference)

Date and time, name and signature of person receiving and transporting samples from Project location to laboratory facilities (Chain of Custody Transference)

Date and time, name and signature of person receiving simple at laboratory location (Chain of Custody Transference)

4.6.3 SampleAnalysis

A trailer will be available 24/7 on site during project duration to facilitate and speed up field and

sampling activities. Initial field characterization of unknown chemicals will consists of eight

HAZCAT Test. Sample testing will consist on the following tests:

pH

Ignitability

R2-000373




Oxidizer screen

Cyanide screen

Sulfide screen

Water miscibility

Water reactivity

Physical description

All equipment used will be calibrated and decontaminated according to the manufacturer’s

specifications on a daily basis and recorded in a field calibration log. Field test will be used to

classify samples into different categories, including auto-reactives, water reactives, metals, oxidizers,

etc.

The contents of each unknown container will be visually inspected noting the volume of waste

contained, color, stratified layers, and waste general characteristics. HAZCAT analytical test will be

perform on the field at the mobile laboratory facility. Field test data will be record using a

Laboratory Information Management System (LIMS) Software. Refer to Section SAP 3.3.2 for more

information.

Characterization for Used Oil and Waste Disposal Samples will be sent to the following laboratory:

Sanco Laboratories, Inc. P.O. Box 10359 Caparra Station, San Juan, Puerto Rico, 00922

Samples will be collected for analyzed for RCI, TCLP Metals, TCLP VOC’s, TCLP SVOC’s, TCLP

Pest/Herb, PCBs, Total Metals, Asbestos, as needed. Refer to SAP Section 9 Parameters, CAS

Numbers, Analytical Method, units and MDLs information and to Appendix H for Analytical Methods.

R2-000374




4.7 Wastestagingandhandling

Riclem Environmental will characterize hazardous materials in accordance with RCRA regulations as

per EPA methods (RCI, TCLP VOCs, TCLP SVOCs, TCLP Pest/Herb) and used oil as per 40 CFR

279.11. Waste profiles will be generated base on the analytical results from these analyses. After

samples have been collected, where applicable as detailed above, and analytical data and/or SDS have

been evaluated from each category; technicians will prepare lab packs by properly classify hazardous

waste in accordance with US Department of Transportation (DOT) and Environmental Protection

Agency (EPA) regulations. Lab packs will be moved to the drum staging area (habilitated area in one

of the Central Roig’s Buildings) and placed in compatible groups for example: oxidizers in one area,

high VOCs containing substances in another, etc. The drum number on the container will be legible

and faced in an outward direction. All containers will be staged on-site in a secured location and

protected from the elements to prevent accidental release.

R2-000375




4.8 WasteTransportationandDisposal

All hazardous waste generated at the Site will be disposed at an approved Treatment, Storage, Disposal

Facility (TSDF) in the US. Packaging and transportation will comply with DOT regulations. All non-

hazardous waste will be handled by Ponce Landfill in Puerto Rico. Hazardous waste transportation by

land will be performed by AquaClean and/or Environix. Transporters that are moving regulated

wastes on public roads, highways and waterways, are regulated by the EPA RCRA Subtitle C (40 CFR

Part 263) and by the Department of Transportation (DOT) standards (49 CFR Parts 171-179). These

transporter regulations are integrated. Regulatory Requirements for Transporters:

Because AquaClean and Evironix are located in PR, they must also have a waste transportation permit

from the Environmental Quality Board (EQB). Without this ID number, the transporter is forbidden

from transporting hazardous waste. AquaClean and Evironix EQB Transportation ID # HW-77 and

HW-89. For hazardous materials whose final destination facilities are located in the US, sea

containers will be transported by Crowley (EPA ID: FLD085092146-1163, FLR000054221-3001)

PRLA General Manager will review each manifest for approval and signature before any material is

transported off-site. Waste will not be removed from site without PRLA General Manager

authorization and proper notification to the EPA OSC. Hazardous waste material will be manifested

as a RCRA hazardous waste shipment and disposed as a hazardous waste in an approved facility in

accordance to all the federal and state regulations. Upon receiving the waste, the transporter will sign

and date the manifest to acknowledge receipt and return a copy to the generator before leaving the

generator’s property. A copy of the manifest will accompany the shipment of the waste at all times.

Once the transporter has accepted the waste, the transporter is required to deliver the entire quantity of

waste to the next designated transporter or to the designated facility. Upon turning the waste over to

another transporter or to the designated facility, the transporter will have the manifest signed and dated

by the recipient. All transporters will keep a signed copy of the manifest for three years from the date

the initial transporter accepted the waste. Copy of the manifest will be send to PRLA Project

Coordinator and/or authorize representative for the record of the Project.

R2-000376




REC will provide all certificates of destructions and/or certificate of disposal for all materials

disposed from the Site to the PRLA General Manager within the time frame the law allows the Final

Disposal Facility to produce these documents. Copies will be included in the Final Report. Refer to

The Transportation and Waste Disposal Plan for more detailed information.

5 DECONTAMINATIONPROCEDURES

Decontamination is the process of physically removing or neutralizing contaminants that have

accumulated on personnel and equipment. This process is critical to health and safety at hazardous

material response sites. Decontamination protects end users from hazardous substances that may

contaminate and eventually permeate the protective clothing, respiratory equipment, tools, vehicles, and

other equipment used in the vicinity of the chemical hazard; it protects all plant or site personnel by

minimizing the transfer of harmful materials into clean areas; it helps prevent mixing of incompatible

chemicals; and it protects the community by preventing uncontrolled transportation of contaminants

from the site.

Decontamination procedures will be communicated to all employees and will be implemented before

any employee or equipment may enter areas on-site where a potential for exposure to hazardous

substances exists. Decontamination procedures will be monitored by the HSO to determine their

effectiveness. If procedures are determined to be ineffective, this Plan will be modified to correct any

deficiencies. Refer to SSHP Section 5 for PPE Decontamination Procedures and SAP Section 8.4 for

sampling equipment decontamination.

6 AIRSURVEILLANCE

During the project activities in the field, an air surveillance program will be implemented to detect and

quantify any volatile organic compounds (VOCs) in the work site and to ensure that all personnel are

R2-000377




adequately protected from potential organic vapors hazards. This program shall consist of air

monitoring, utilizing direct reading instruments capable of providing real-time indications of air

contaminant. Because the field activities will be conducted in open areas, there will be no expectation

of oxygen deficient/enriched atmospheres, and there is no need for evaluation for potentially radioactive

materials. Additionally, an Asbestos specific air monitoring will be conducted for such activities to

ensure that works are not exposed to airborne asbestos concentrations in excess of the permissible

exposure limits (PELs). Detailed information about the Asbestos-specific program is included in a

separate document that will be submitted to the Environmental Quality Board (EQB) for work permit

approval.

The Site HSO, shall be responsible for ensuring site and employee monitoring is conducted in an

appropriate manner, (i.e., following standard industrial hygiene protocols), and that air

monitoring/sampling procedures shall be conducted at a frequency sufficient to ensure accurate

assessments of site conditions, and the effectiveness of work practices, engineering controls, and/or

PPE. The Site HSO will ensure a daily, on-site log is maintained of all air monitoring/sampling results.

(SSAP Appendix K).

6.1 DustControl

Controlling haul road fugitive dust is important for employee safety, equipment maintenance, as well

as protecting the air quality of the area. During project activities a non-potable tank truck will be used

to spray water to unpaved roads for dust control. Riclem Environmental Corp. will perform daily

visible emissions checks on all active haul roads at the beginning shifts. Haul truck drivers will also

observe for visible emissions during the shift and report by radio as needed.

R2-000378

Puerto Rico Land Authority



Appendix

R2-000379




Appendix A Administrative Order For a Removal Action

R2-000380

3. EPA has notified the Puerto Rico Environmental Quality Board

(“EQB”) of this Order pursuant to Section 106(a) of CERCLA, 42 U.S.C.

§ 9606(a)

II. PARTIES BOUND

4. This Order shall apply to and be binding upon Respondent and its

directors, officials, employees, agents, successors and assigns. No

change in the status or control of Respondent shall alter

Respondent’s responsibilities under this Order.

5. Until EPA notifies Respondent under Paragraph 97 that the Work

has been completed, Respondent shall provide a copy of this Order to

any successors before a controlling interest in Respondent’s assets

or property rights are transferred to the successor.

III. DEFINITIONS

6. Unless otherwise expressly provided herein, terms used in this

Order which are defined in CERCLA or in regulations promulgated under

CERCLA shall have the meaning assigned to them in CERCLA or its

implementing regulations. Whenever terms listed below are used in

this Order or in an attachment to this Order, the following

definitions shall apply:

a. “Day” means a calendar day unless otherwise expressly

stated. “Working Day” shall mean a day other than a Saturday, Sunday,

or Federal holiday. In computing any period of time under this Order,

where t’ne last day would fall on a Saturday, Sunday, or Federal

holiday, the period shall run until the close of business on the next

working day.

b. “Effective Date” means the date specified in Paragraph 98.

c. “Hazardous substance” shall have the meaning provided in

Section 101(14) of CERCLA, 42 U.S.C. § 9601(14).

d. “Party” or “Parties” means EPA and/or Respondent.

e. “Respondent” shall the Puerto Rico Land Authority.

= er:

sIte, including 132 acres, which is the locatton of the former Central

Roig Sugar Cane Refinery, located at La Central Street in Yabucoa,

Puerto Rico. A Site map is attached hereto as Appendix A.

111 “l4-

R2-000381

(3) any “solid waste” Under Section 1004(27) of the Resource

Conservation and Recovery Act (“RCRA”) 42 § 6903(27). and (4)

(3) above

any mixture containing any of the constituent noted in (1), (2), or

h. “Work” means all work and Other activities that Respondent

is reguir to perform pursuant to this Order.

IV. FINDINGS OFFA

7. The Site is located in the middle of the Yabucon Valley in Puerto

Rico, a large agricul51 area, and is bordered by the Puerto Rico

Central mountain chain to the north, South and west, and the Atlantic

Ocean to the east. The Central Roig facility is located less than one

mile north of the urban area of the municipality of Yabucoa

8. The Site was operated as a sugar cane refinery for more than soyears The Site currently include5 aPproximately 16 structures of

various sizes used for the storage of sugar, eguipmen/i

parts, and machinery, as well as for the operation of a sugar cane

Processing line. The structures include a small laboratory building

which is located adjac to the main building complex and contains

many containers (ranging up to 1 liter in Size) of hazardous

chemicals These chemicals were stored there as a result of actions to

collect and Secure containers found through0 the Site. This

building is located along the east Side of Building 1 and north of

Building 5. A Site map is attached hereto as Appendix A. The Central

Roig facility ceased oPeration and was abandoned in 2001, leaving

behind many laboratory chemicals.

9. The Central Roig sugar refinery was acguir by Respondent in the

l97o and Respondent was in charge of the operation until February of

l99, when the Property was transferred to Compania Natriz de la

Septeer 1996.Central Roig, Inc. (also known as Los Colon05) under Public Law 189 of

10. Pursuant to a iudgmen of the Superior Court of Humacao the Site

July of 2012.

was conveyed back to the Puerto Rico Land Authority (Re5pordent) in

i. 1. (Do err- an El. UT) —s CQCrl,c

so f Durj hj5 inspc100 LEA

discovered Suspect asbestoscoy.material (“sACM” on facility

floors and Pipes and i0 boiler room areas. In addition, several large

Petroleum oil spills were discovered, as well as unsecured laboratorj

chemic5l5 trlroughout many portions of one of the Site buildings

R2-000382

12. On March 6, 2012, an EPA OSC issued a Field Notice of Federal

Interest (‘FNFI”) to Los Colonos under the authority of CERCLA,

seeking its performance of a removal action to clean up the SACM and

abandoned laboratory chemicals. The EPA OSC issued a separate FNFI to

Los Colonos on March 6, 2012, under the authority of Section 311 of

the Clean Water Act, 33 U.S.C. § 1321, seeking the cleanup of the

petroleum oil spill at the Central Roig facility.

13. The abandoned laboratory chemicals were inventoried on March 7,

2012. There were approximately 60 containers (ranging up to 1 liter in

size), both with and without labels, of chemicals containing hazardous

substances including:

Ammonium hydroxide;

Chloroform;

Formaldehyde;

Lead subacetate;

Silver nitrate; and

Sodium hydroxide.

14. Los Colonos complied with the removal of the ongoing petroleum

oil spill detected in 2012 but failed to remove the abandoned

laboratory chemicals or SACM.

15. On January 9, 2013, an EPA OSC issued a FNFI under CERCLA to

Respondent requesting that Respondent report to EPA by January 14,

2013 those removal activities which it has performed to mitigate the

release or threat of release of hazardous substances from the

unsecured containers of laboratory chemicals.

16. On June 18, 2013, an additional oil spill was discovered at the

Site by an EPA OSC. The source of the spill was two tanks which

stored number 6 oil that was used by the sugar mill operators to run

the facility boiler system. The bottom of one of the tanks had failed

and the material had leaked into an earthen culvert. The EPA OSC

requested Respondent to immediately abate, remove and dispose of the

oil.

17. At EPA’s request, Respondent voluntarily provided a Work Plan

including a Quality Assurance Project Plan (“QAPP”) and Health and

Safety Plan to the EPA OSC for review on June 25, 2013. The QAPP was

not appropriate for approval by EPA.

18. Since submission of the QAPP, but without approval of the QAPP,

Respondent has excavated oil- contaminated soil and removed

approximately 3000 gallons of oil and oily water.

19. In approximately November of 2013, PRLA contracted for demolition

of structures at the Site in order to salvage steel for sale. The EPA

4

R2-000383

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 2

xIN THE MATTER OF THE

CENTRAL ROIG SUGAR MILLS

SUPERFUND SITE


Respondent.

Proceeding under Section 106(a) of : Index Numberthe Comprehensive Environmental : CERCLA—02—2014—2026

Response, Compensation, and Liability

Act of 1980, as amended, 42 U.S.C.

§ 9606(a)

x

ADMINISTRATIVE ORDER FOR A

REMOVAL ACTION

I. JURISDICTION AND GENERAL PROVISIONS

1. This administrative order (“Order”) is issued to the Puerto RicoLand Authority, (hereinafter, “Respondent”) by the United StatesEnvironmental Protection Agency (“EPA”), Region 2, and requiresRespondent to perform a removal action in connection with the CentralRoig Sugar Mills Superfund (Site (the “Site”), Yabucoa, Puerto Rico.

2. This Order is issued to Respondent by EPA pursuant to theauthority vested in the President of the United States under Section106(a) of the Comprehensive Environmental Response, Compensation, and

Liability Act of 1980, as amended (“CERCLA”), 42 U.S.C. § 9606(a),anci deleeated te t.he Adx.ini.stratox. of EPA on January 23, 1987, byExecutive Order No.. 1.2580 (52 Federal Reglst:er 2926, Osnuary 29,1987). ihis authority was further delegated to the EPA RegionalAdministrators by EPA Delegation Nos. 14-14—A and 14-14-B and no theDirector of the Emergency and Remedial Response Division in Region 2by Begional Delegation P—1200, dated November 23, 2004.

R2-000384

OSC directed PRLA to cease the demolition while EPA assessed the

situation.

20. On February 4, 2014, EPA OSCs inspected the facility to assessand document current Site environmental conditions. The two dayinspection identified 40 additional containers (ranging up to 1 literin size) of chemicals containing hazardous substances within theformer maintenance building (Building 8)

21. During the same inspection, in Building 8 the OSC5 observed five55—gallon plastic drums of Busan 1016 pesticide which, according tothe manufacturers material safety data sheet, is considered to be acharacteristic waste under the Resource Conservation and Recovery Act.Evidence of leakage and/or spills of oil was observed upon the floorof this building. In addition, large amounts of oil within reservoirs

beneath the sugar cane processing equipment were observed withinBuilding 2.

22. On February 10, 2014, pursuant to EPA direction, ten bulk sampleswere collected from the Site for asbestos analysis. Seven sampleswere taken of roofing tar/mastic used to seal joints within thecorrugated roofing of recently demolished structures. Three sampleswere of various pipe insulation materials observed within the formermaintenance building. Of the mastic/tar samples, all contained

chrysotile asbestos ranging from 2 to 10% and thus are consideredasbestos—containing material (“ACM”) . No asbestos fibers were foundwithin the insulation material sampled within the maintenancebuilding.

23. in addition to the asbestos sampling, EPA directed the collectionof 5 samples for polychlorinated biphenyl (“PCB”) analysis. Three ofthe samples were obtained from the floor of Building 8 and two fromthe lubricating oil sumps within Building 2. None of the samplescontained PCBs.

24. The chemicals identified in Paragraphs 13 and 22 above, with theexception of the petroleum, as well as asbestos in ACM identified inparagraph 22 are all “hazardous substances” under Section 101(14) ofCERCLA, 42 U.S.C. § 9601(14).

25. E.xpcsnre to certain of the chemical ident I fled caragrap .hs 13,21. and 22 c cause damage the skin, eyes, upper respiratory tract,nervous system, kidneys, lungs and reproductive system, and can causediscoloration of the skin and other organs, as well as breathingproblems. Inhalation of asbestos fibers may lead to fibrotic lungdisease (asbestosis), leurai plaques and cancer of the lung, pleura,

R2-000385

26. By electronic mail message dated June 17, 2014, counsel for the

PRLA informed EPA counsel that PRLA was cancelling its security

contract and would not provide security to the Site after June 30,

2014.

27. The Site is not secure and vagrants have been observed there on

multiple occasions by EPA. The presence of vagrants at the Site

exacerbates the situation and increases the threat of release of

hazardous substances.

28. The Central Roig facility constitutes a “facility” within the

meaning of Section 101(9) of CERCLA, 42 U.S.C. § 9601(9).

29. Respondent, an entity of the Puerto Rico government, is a

“person” within the meaning of Section 101(21) of CERCLA, 42 U.S.C. §

9601(21). Respondent is an owner or operator of the Site, and is

accordingly a potentially responsible party for the Site and is liable

pursuant to CERCLA Section 107(a), 42 U.S.C. §9607(a).

30. The presence of abandoned laboratory and drummed chemicals

containing hazardous substances as well as unsecured ACM constitutes

a “release” or threat of “release” of hazardous substances into the

environment, as the term “release” is defined in Section 101(22) of

CERCLA, 42 U.S.C. § 9601(22).

V. DETERMINATIONS

31. The conditions present at the Site constitute a threat to public

health, welfare, or the environment based upon factors set forth in

Section 300.415(b) (2) of the National Oil and Hazardous Substances

Pollution Contingency Plan (“NCP”) . These factors include, but are

not limited to, the following conditions:

a. Actual or potential exposure to nearby human populations,

animals or the food chain from hazardous substances or

pollutants or contaminants;

b. Hazardous substances or pollutants or contaminants in drums,

barrels, pails, or other bulk storage containers that may pose

a threat of release; and

c. Threat of fire or explosion.

32. The actual or threatened release of hazardous substances from the

Site may present an imminent and substantial endangerment to the

public health, welfare, or the environment within the meaning of

Section 106(a) of CERCLA, 42 U.S.C. §9606(a).

6

R2-000386

33. The actions required by this Order are necessary to protect thepublic health or welfare or the environment, are in the publicinterest, and are consistent with CERCLA and the NCP.

VI. ORDER

34. Based upon the foregoing Findings of Fact, Conclusions of Law,Determinations, and other information available to EPA, includinginformation concerning Respondent’s removal of potentially

contaminated equipment and Respondent’s preparations for demolition ofthe potentially contaminated buildings, it is hereby ordered thatRespondent shall undertake a removal action at the Site in accordancewith this Order to provide Site security, remove the abandonedlaboratory chemicals, pesticides, and loose asbestos—containingmaterials, and characterize waste oil in Building 2, as described inmore detail below. Such removal action shall include, but is notlimited to, the mobilization, sampling, assessment, decontamination,staging, and disposal as described herein. All activities specifiedbelow shall be initiated and completed as soon as possible even thoughmaximum time periods for their completion are specified herein. Withregard to the Work contemplated by this Order, Respondent shall ceaseand desist from implementing any such Work until approved by EPApursuant to this Order.

A. Designation of Contractor and Designated

Project Coordinator

35. Within five (5) days after the effective date of this Order,Respondent shall select a coordinator, to be known as the DesignatedProject Coordinator, and submit the name, address, qualifications andtelephone number of the Designated Project Coordinator to EPA. TheDesignated Project Coordinator shall be responsible on behalf ofRespondent for oversight of the implementation of this Order. TheDesignated Project Coordinator shall not be an attorney engaged in thepractice of law. He or she shall have the technical expertisesufficient to adequately oversee all aspects of the Work contemplatedby this Order. The Designated Project Coordinator shall beknowledgeable at all times about all matters relating to the Workbeing performed under this Order.

36, Selection of the Designate d Prcclect. Coordinator shall be subjecta5provai b SPA iting. if EPA disapproves a proposed

Designated Project Coordinator, Respondent shall propose a differentperson and notify EPA of that person’s name, address, telephone numberand qualifications within five (5) days following EPA’s disapproval.Respondent nay change its Designated Project Coordinator provided thatEPA has received vs tten notice at least five (5) da.ys pr.ior to thedesired chance. All. changes of the Designated Psrhect Ccordi,.natorsnail be sub ieee cc EPA approval.

R2-000387

37. EPA correspondence related to this Order will be sent to the

Designated Project Coordinator on behalf of Respondent. To the extent

possible, the Designated Project Coordinator shall be present on—Site

or readily available for EPA to contact during all Working Days and be

retained by Respondent at all times until EPA issues a notice of

completion of the Work. Notice by EPA in writing to the Designated

Project Coordinator shall be deemed notice to Respondent for all

matters relating to the Work under this Order and shall be deemed

effective upon receipt.

38. All activities required of Respondent under the terms of this

Order shall be performed only by well-qualified persons possessing all

necessary permits, licenses, and other authorizations required by

Federal, Commonwealth of Puerto Rico (“Commonwealth”) and/or local

governments consistent with Section 121 of CERCLA, 42 U.S.C. § 9621,

and all Work conducted pursuant to this Order shall be performed in

accordance with prevailing professional standards.

39. Respondent shall retain at least one contractor to perform the

Work. Respondent shall notify EPA of the name and qualifications of a

proposed contractor within fourteen (14) days of the effective date of

this Order. Respondent shall also notify EPA of the name and

qualifications of any other contractor or subcontractor proposed to

perform Work under this Order at least five (5) days prior to

commencement of such Work.

40. EPA retains the right to disapprove of any, or all, of the

contractors and/or subcontractors proposed by Respondent to conduct

the Work. If EPA disapproves in writing of any of Respondent’s

proposed contractors to conduct the Work, Respondent shall propose a

different contractor within seven (7) days of receipt of EPA’s

disapproval.

41. Respondent shall provide a copy of this Order to each contractor

and subcontractor approved and retained to perform the Work required

by this Order. Respondent shall include in all contracts or

subcontracts entered into for Work required under this Order

provisions stating that such contractors or subcontractors, including

their agents and employees, shall perform activities required by such

contracts or subcontracts in compliance with this Order and all

applicable laws and regulations. Respondent shall be responsible for

ensuring that its contractors and subcontractors perform the Work

contemplated herein in accordance with this Order.

p

R2-000388

B. Description of Work

42. As initially discussed in Paragraph 34 above, Respondent shall

perform a removal action at the Site in accordance with this Order,

CERCLA, the NCP, EPA’s relevant guidance documents and other

applicable Federal and Commonwealth laws and regulations. Respondent

shall perform, at a minimum, all actions necessary to implement the

Work herein. The actions to be implemented with respect to the Site

shall include, but may not be limited to the following items:

a. providing security to the Site to prevent vandalism and/ortrespassing from the Effective Dateof this Order until completion of

all the tasks specified in subparagraphs b. through d.;

b. removal and disposal of all containers of chemicals currently

located within the former laboratory and Building 8 (former

maintenance building);

c. characterization of waste oil in Building 2 lubricating pits

and disposal of oil found to contain CERCLA hazardous substances;and

d. proper abatement, handling and disposal of all asbestos—containing

materials, including asbestos—containing roofing materials present on

former building floors, on ground surfaces and comingled with

demolition debris.

Any demolition, scrapping or salvaging of building materials which

Respondent wishes to undertake at the Site may not be done except with

the approval of EPA.

43. Within thirty (30) days of the Effective Date of this Order

Respondent shall submit to EPA for review and approval detailed a Site

Operating Plans (“SOP”) for the Work. The SOP shall be submitted inaccordance with this Order, CERCLA, the NCP, EPA’s relevant guidance

documents and other applicable Federal and Commonwealth laws and

regulations. The SOP shall include the following:

a. Site-specific Work Plan;

c. Site Health and Safety Plan for the planned work;

d. Quality Assurance Project Plan, which shall include a plan for

R2-000389

f. Green Strategy Plan for implementing the Work. The Green

Strategy Plan should follow EPA Region 2’s Clean and Green Policy

which may be found at:

http://www.epa.gov/regiono2/superfund/green remediation/policy.htmi.

44. The Site—specific Work Plan shall discuss the proper

characterization, staging, handling, sampling and analysis, and

disposal of all materials containing hazardous substances, pollutants

or contaminants at the Site, and at a minimum, address the following:

a. Proposed time line for the completion of all work activities

and all other requirements of this Order. The schedule shall provide

for completion of all field work no later than twelve (12) months from

the date of approval of the SOP(s)

b. Procedures for characterization of building contents and

demolition debris for reuse/recycling or disposal and documentation of

procedures used to previously perform such characterization.

c. Procedures for preventing the release of hazardous substances

to the environment during staging, handling, sampling and disposal.

d. A plan for providing Site security including, but not limited

to, measures to be taken to keep unauthorized personnel from entering

restricted work areas and the Site for the duration of the cleanup.

45. The Transportation and Disposal Plan shall outline procedures for

the proper transporting and disposing of all hazardous substances,

pollutants and contaminants, hazardous waste and any solid waste

generated during the Work. The Transportation and Disposal Plan will

include the identification of the proposed disposal facilities for all

waste streams and include waste profile information, facility

acceptance documentation, and analytical characterization of each

waste stream. In addition the Plan will include the following

information to be determined and documented by Respondent:

a. the transporter and disposal identification numbers for each

proposed transporter and disposal company;

b. the most recent six-month Commonwealth or EPA regulatory

inspection results of each disposal facility;

c. documentation of the current permit status of proposed

transporters and disposal facilities; and

d. the date of the most recent Commonwealth or EPA regulatory

inspection of each proposed disposal company, and any special

provisions or conditions attached to the disposal permits as a result

of the most recent inspection.

10

R2-000390

After permitted disposal facilities have been identified all wastes

shall be Properly manifested and shipped Off-Site via permitted

transporters All final signed manifests, bills of lading and

certificates of destruction for such disposal shall be provided by

Respondent to the On Scene Coordinator (“OSC”) identified in Paragraph

57, along with the monthly reports.

46. The Health and Safety Plan shall ensure the protection of the

public health and safety during performance of On—Site work under this

Order. This plan shall be prepared in accordance with the “EPA

Standard Operating Safety Guide” (PUB 9285.1-03 PB 92-963414, June

1992) . ifl addition, the plan shall comply with all currently

applicable Occupational Safety and Health Administration (“OSHA”)

regulations found at 29 C.F.p Part 1910. The plan shall also include

contingency planning. Respondent shall incorporate all changes to the

plan required by EPA and shall implement the plan throughout the

duration of the removal action. The Site Health and Safety Plan, at a

minimum, shall address the following:

a. Delineation of the work Zones;

b. Personnel monitoring requireme5 paying particular attention to

monitoring specific job functions in compliance with OSHA

requirements;

c. Personal protective equipment requireme0t5and upgrade thresholds

based on real-time air monitoring;

d. Demonstration that all personnel, including subcontractor

Personnel, have current certifications as per applicable OSHA

regulations;

C. Decontamination procedures for personnel and equipment exiting

any exclusion zone; and

f. Compliance with OSHA requireme5 for Health and Safety Plans.

If performance of any of the Work required by this Order requires

alteration of the Health and Safety Plan, Respondent shall submit to

EPA for review and approval proposed amendments to the Health and

Safety Plan.

47 The Quality ASsurance Project Plan (“QAPO”) shall provide for the

following:

a. All sampling and analyses performed pursuant to this Order shall

0 r oaJ

u.rance, c.Tu5.Jr v contrcJ, data valjdtj5 and cbs inc.i custody

roce0u Respondent shall incerpnr5te these orocecres in

accordance wrh the Uniform Federal Policy for Implemeitj00 QualiFy

R2-000391

Systems (UFP-QS), EPA-505—F_03_ool, March 2005; Uniform Federal Policy

for Quality Assurance Project Plans (UFP—QAPp), Parts 1, 2, and 3,

EPA—5Q5—B_04_900A B, and C, March 2005 or newer; and other guidance

documents referenced in the aforementioned guidance documents.

Subsequent amendments to the above, upon notification by EPA to

Respondent of such amendments, shall apply only to procedures

conducted after such notification

b. If performance of any of the Work required by this Order requires

alteration of the QAPP, Respondent shall submit to EPA for review and

approval proposed amendments to the QAPP.

c. Respondent shall conduct the appropriate level of data

verification/validation and provide the specified data deliverables as

provided in the EPA-approved QAPP.

d. The QAPP shall require that any laboratory utilized by Respondent

is certified for the matrix/analyses which are to be conducted for any

Work performed pursuant to this Order, by one of the following

accreditation/certification programs: USEPA Contract Laboratory

Program (“CLP”), National Environmental Laboratory Accreditation

Program (“NELAP”), American Association for Laboratory Accreditation

(“A2LA”), or a certification issued by a program conducted by a state,

or commonwealth and acceptable to EPA, for the analytic services to be

provided. The QAPp shall requir Respondent to submit laboratory

certificates from such accreditation programs that are valid at the

time samples are analyzed. If a specific analytical service is

unavailable from a certified laboratory, EPA may, within its

discretion, approve Respondent’s utilization of a laboratory that is

not certified. EPA approval shall be based on Respondent’s submittal

of a written request, submittal of the laboratory quality assurance

plan, and the laboratory’s demonstration of capability through the

analysis of Performance Evaluation samples for the constituents of

concern.

e. In its contract(s) with laboratories utilized for the analyses of

samples, Respondent shall require granting access to EPA personnel and

authorized representatives of the EPA to the laboratories for the

purpose of ensuring the accuracy of laboratory results related to the

Site.

f. The QAPP will provide for electronic submittal of sampling data

in accordance with EPA Region 2 policies, guidelines, and formats.

The Region 2 Electronic Data Deliverable (“EDD”) is a standardized

format for all electronic submittals to EPA Region 2. The most recent

EDD Guidance and Requirements can be found at:

/superfund/mehtrn

48. The QAPP shall include detailed procedures, methods and sampling

parameters to be implemented to sample and analyze the contaminants

12

R2-000392

found in lubricating pits, Site soils and containers that are required

for off-Site transport and disposal, and to insure proper staging of

containerized materials into compatible waste groups for disposal.The QAPP for Phase II will also include detailed procedures, methods,

and sampling parameters to be utilized for post—excavation sampling of

soil in the areas of excavation to document the completion of the

waste and contaminated soil removal. The QAPP will also contain

detailed procedures and methods to evaluate the extent of soil and

groundwater contamination on-Site beyond the excavation area and will

inclLde maps depicting proposed sampling locations. Appropriate

sampling and analysis methods (e.g., sample frequency, compositingtechniques, etc.), as necessary shall be utilized for the properdisposal of contaminated soil and containers.

49. The Community Air Monitoring Plan (“CA1P”) shall provide for the

following:

a. Work zone air monitoring;

b. Perimeter air monitoring;

c. Community air monitoring;

d. Particulate monitoring, response levels and actions; and

e. Dust Control.

50. Upon request by EPA, Respondent shall allow EPA or its authorized

representatives to take split and/or duplicate samples of any samplescollected by Respondent while performing Work under this Order.Respondent shall notify EPA not less than seven (7) days in advance ofany sample collection activity. EPA shall have the right to take anyadditional samples that it deems necessary.

51. EPA either will approve the SOP or will require modifications

thereto pursuant to Section VII (Plans and Reports Requiring EPAApproval), below. Upon its approval by EPA, the SOP shall be deemedto be incorporated into and an enforceable part of this Order.

52. Within ten (10) days after EPA’s approval of a SOP, Respondentshall commence the Work described in the EPAapproved SOP, ResoondentOhall fli 1pemer 2 E ocroced SOP i a000rOarce

terms and schedu±e therein ann ifl accordance with this Order. All Workrequirements of this Order shall be completed within nine (9) monthsof the approval of the SOP.

53. Respon•dent f p p of the names and addresses of all

or rrcsafeo eJ u,esc:cnc1en: on rm toe Sloe. Pesconoent shaL provine

R2-000393

such notification to EPA for approval at least five (5) days prior to

off—Site shipment of such Wastes.

54. At the time of completion of all field activities required by

this Order, demobilization shall include sampling if deemed necessary

by EPA, and proper disposal or decontamination of protective clothing,

remaining laboratory samples taken pursuant to this Order, and any

equipment or structures constructed to facilitate the cleanup.

Respondent shall insure that the Site is restored to its original

condition.

55. Respondent shall conduct the Work required hereunder in

accordance with CERCLA, the NCP, as well as applicable provisions of

the following guidance documents, and of other guidance documents

referenced in the following guidance documents: EPA Region 2’s Clean

and Green Policy, cited above, and Guide to Management of

Investigation-Derived Wastes OSWER Publication 9345.3-O3FS, January

1992), as they may be amended or modified by EPA.

C. On—Scene Coordinator, Other Personnel, and

Modifications to EPA—Approved Work Plan

56. All activities required of Respondent under the terms of this

Order shall be performed only by qualified persons possessing all

necessary permits, licenses, and other authorizations required by the

federal government, and the Commonwealth, and all work conducted

pursuant to this Order shall be performed in accordance with

prevailing professional standards.

57. The EPA OSC for the Site will be: Andrew Confortini, Removal

Action Branch, Emergency and Remedial Response Division, U.S.

Environmental Protection Agency, Region II, 2890 Woodbridge Avenue,

Building 209 (MS—211), Edison, New Jersey 08837, telephone number 732—

906—6827. EPA will notify Respondent’s Project Coordinator if EPA

designates a different OSC for this Site.

58. EPA, including the OSC, or his/her authorized representative,

will conduct oversight of the implementation of this Order. The OSC

shall have the authority vested in an OSC by the NCP. The OSC shall

have the authority to halt, conduct, or direct any Work required by

this Order, or to direct any other response action undertaken by EPA

or Respondent at the Site consistent with this Order. Absence of the

CSC from the Site shall not be cause for stoppage of Work unless

specifically directed by the OSC.

59. As appropriate during the course of implementation of the actions

required of Respondent pursuant to this Order, Respondent or its

consultants or contractors, acting through the Designated Facility

Coordinator, may confer with EPA concerning the required actions.

Based upon new circumstances or new information not in the possession

14

R2-000394

of EPA on the effective date of this Order, the Designat Facility

Coordinator may request, in writing, EPA approval of modification(s)

to the EPA-approved Work Plan. Only modifications approved by EPA in

writing shall be deemed effective Upon approval by EPA, such

modifications shall be deemed incorporated in this Order and shall be

implemented by Respondent

U. Plans and Reports Requiring EPA Approval

60. If EPA disapproves or otherwise requires any modifications to any

plan, report or other item required to be submitted to EPA for

approval pursuant to this Order, Respondent shall have fourteen (14)

days from the receipt of notice of such disapproval or the required

modifications to correct any deficiencies and resubmit the plan,

report, or other written document to EPA for approval, unless a

shorter or longer period is specified in the notice. Any notice of

disapproval will include an explanation of why the plan, report, or

other item is being disapproved Respondent shall address each of the

comments and resubmit the plan, report, or other item with the

required changes within the time Stated above. At such time as EPA

determines that the plan, report, or other item is acceptable, EPA

will transmit to Respondent a written statement to that effect.

61. If any plan, report, or other item required to be submitted to EPA

for approval pursuant to this Order is disapproved by EPA, even after

being resubmitted following Respondents receipt of EPA’S cogen5 on

the initial submittal, Respondent shall be deemed to be out of

compliance with this Order. If any resubmitted plan, report, or other

item, or portion thereof, is disapproved by EPA, EPA may again direct

Respondent to make the necessary modifications thereto, and/or EPA may

amend or develop the item(s) and recover the costs of doing so from

Respondent Respondent shall implement any such item(s) as amended or

developed by EPA.

62. EPA shall be the final arbiter in any dispute regarding the

sufficiency or acceptability of all documents submitted and all

activities performed pursuant to this Order. EPA may modify those

docuents and/or perform or require the performance of additional work

unilaterally.

63, All plans, reports and other suhmjtta±3 required to be submitted

to EPA pursa1t to t.hi. artier, coon approv5 by EPA, sha.ii deteed t.o

be incorporated in and an enforceable part of this Order.

Durj the irncjemtri-t, of this Order. RCSqodeyt shajj trovide

E.P w.i. th cr4 tton rroo reDor s every seven 7) days. The firsf

1tc: ail be suomitted cithit sele11 7 a/s of the

effe(t 1 of this Order, Such r000rts sha] fully desc ibe all

R2-000395

actions and activities undertaken pursuant to this Order. Such

progress reports shall, among other things, (a) describe the actions

taken toward achieving compliance with this Order during the previous

week, (b) include all results of sampling and tests and all other data

received by Respondent after the most recent progress report submitted

to EPA, Cc) describe all actions which are scheduled for the next week,

(d) provide other information relating to the progress of Work as is

customary in the industry, (e) and include information regarding

percentage of completion, all delays encountered or anticipated that

may affect the future schedule for completion of the Work required

hereunder, and a description of all efforts made to mitigate those

delays or anticipated delays.

65. Within thirty (30) days after completion of the Work required by

the SOP(s), Respondent shall submit for EPA review and approval a Final

Report summarizing the actions taken to comply with this Order. The

Final Report shall include:

a. A synopsis of all Work performed under this Order;

b. A detailed description of all EPA—approved modifications to

the SOP which occurred during Respondent’s performance of

the Work required under this Order;

c. A listing of quantities and types of materials removed from

the Site or handled on—Site;

d. A discussion of removal and disposal options considered for

those materials;

e. A listing of the ultimate destination of those materials;

f. A presentation of the analytical results of all sampling and

analyses performed, including QAPP data and chain of custody

records;

g. Accompanying appendices containing all relevant

documentation generated during the Work (e.g. manifests,

bills of lading, invoices, bills, contracts, certificates of

destruction and permits);

Ar. accounting of expenses incurred by Respondent in

performing the Work; and

i. The following certification signed by a person who

supervised or directed the preparation of the Final Report:

“I certify that the informatron contained in and

accompanying this document is true, accurate, an complete.”

R2-000396

66. EPA either will approve the Final Report or will require

modifications thereto pursuant to Section D., above.

67. The Final Report and other documents submitted by Respondent to

EPA which purport to document Respondent’s compliance with the terms of

this Order shall be signed by a responsible official of Respondent or

by the Designated Facility Coordinator. For purposes of this

paragraph, a responsible official is an official who is the Executive

Director or Deputy Director.

68. The Work Plan, the Final Report, and other documents required to

be submitted to EPA under this Order shall be sent to the following

addressees:

1 electronic copy to:

U.S. Environmental Protection Agency

290 Broadway, 19th Floor

New York, NY 10007—1866

Attn: Carol Berns

Berns . carol@epa. gov

1 hard copy to:

U.S. Environmental Protection Agency

2890 Woodbridge Avenue

Building 209(MS—211)

Edison, New Jersey 08837

Attn: Andrew Confortini

Confortini . andrew@epa . gov

2 copies (1 hard copy and 1 electronic copy) to:

Weldin Ortiz Franco

Environmental Emergencies Response Area

Puerto Rico Environmental Quality Board

P.O. Box 11488

San Juan, Puerto Rico 00910

[email protected]

69. During the implementation of the requirements of this Order,Respondent and its contractor(s) and subcontractors shall be availablefor such conferences with EPA and inspections by EPA or its authorizedrepresenl.atives as EPA may determine are necessary to adequatelyoversee the Work being carried cut or to be carried out by Respondent,inciuOing inspections at tne Site and at latoratorses where anaiytica±work is being done hereunder.

R2-000397

70. Respondent and its employees, agents, contractor(s) and

consultant(s) shall cooperate with EPA in its efforts to oversee

Respondent’s implementation of this Order.

H. community Relations

71. Respondent shall cooperate with EPA in Providing information

relating to the Work required hereunder to the public. As requested by

EPA, the Respondent shall participate in the preparation of all

appropriate information disseminated to the public; participate in

public meetings which may be held or sponsored by EPA to explain

activities at or concerning the Site; and provide a suitable location

for public meetings, as needed.

I. Access to Property and Information

72. EPA, EQS and their designat representatives, including, but not

limited to, employees, agents, contractor(s) and consultant(s) thereof,

shall be permitted to observe the Work carried out pursuant to this

Order. Respondent shall at all times permit EPA, EQS and their

designated representatives full access to and freedom of movement at

the Site and any other premises where Work under this Order is to be

performed for purposes of inspecting or observing Respondent!s progress

in implementing the requirem5 of this Order, verifying the

information submitted to EPA by Respondent, conducting investigations

relating to contamination at the Site, or for any other purpose EPA

determines to be reasonably related to EPA oversight of the

implementation of this Order.

73. In the event that action under this Order is to be performed in

areas owned by or in Possession of a person other than Respondent,

Respondent shall use its best efforts to obtain access agreements from

such persons within three (3) Working Days of the effective date of

this Order for purposes of implementing the requirem5 of this Order.

Such agreemen shall provide access not only for Respondent, but also

for EPA and its designated representatives or agents, as well as EQB

and its designat representatives or agents. Such agreemenf5 shall

specify that Respondent is not EPA’s representative with respect to

liability associated with Site activities. If such access agreeme5

are not obtained by Respondent within the time period specified herein,

Pespond(nt Shall immedjae1’ notify EPA of its failure to obtain access

and shall include in that notification a summary of the steps

Respondent has taken to attempt to obtain access. Subject to the

United States’ non—reviewable discretion, EPA may use its legal

authorities to obtain access for Respondent, may perform those response

actions with EPA contract055 at the Property in question, or may

terminate the Order if Respondent cannot obtain access agreement5 If

EPA performs those tasks or activities with EPA contractors and does

not terminate the Order, Respondent shall perform all other activities

R2-000398

not requiring access to that property. Respondent shall integrate the

results of any such tasks undertaken by EPA into its reports and

deliverables.

74. Upon request, Respondent shall provide EPA with access to all

records and documentation related to the conditions at the Site,

hazardous substances found at or released from the Site, and the

actions conducted pursuant to this Order except for those items, if

any, subject to the attorney—client or work product privilege. All

data, information and records created, maintained, or received by

Respondent or its contractor(s) or consultant(s) in connection with

implementation of the Work under this Order, including, but not

limited to, contractual documents, invoices, receipts, work orders

and disposal records shall, without delay, be made available to EPA

upon request, subject to the same privileges specified above in this

paragraph. EPA shall be permitted to copy all such documents.

Respondent shall submit to EPA upon receipt the results of all

sampling or tests and all other technical data generated by

Respondent or its contractor(s), or on the Respondent’s behalf, in

connection with the implementation of this Order.

75. Notwithstanding any other provision of this Order, EPA hereby

retains all of its information gathering, access, and inspection

authority under CERCLA, RCRA, and any other applicable statutes or

regulations.

J. Record Retention, Documentation, Availability

of Information

76. Respondent shall preserve all documents and information relating

to Work performed under this Order, or relating to Waste materials

found on or released from the Site, for six years after completion of

the Work required by this Order. At the end of the six year period,

Respondent shall notify EPA at least thirty (30) days before any such

document or information is destroyed that such documents and

information are available for inspection. Upon request, Respondent

shall provide EPA with the originals or copies of such documents and

information.

77. All ‘documents submitted by Respondent to EPA in the course of

.o.ciemenoing this Order shall be available to the public unless

7

addition, 1 PA may release all such documents to EQB, and EQs may make

those documents available to the public unless Respondent conforms to

applicable Commonwealth law and regulations regarding

confidentiality. Respondent shall not assert a claim of privilege or

a orifidentialia ‘ regardino any mcnito.ring or hydroqeologic data, any

informatIon specified under Section 104(e) (7) (F) of CERCLA, or any

other chemical, scientifIc or engineering data relating to the Work.

per formed he under.

R2-000399

K.iteShipmet

78. All hazardous SubstancesPollutants or contaminant removed

from the Site pursuant to this Order for Off_Site treatment Storage,

or disposal shall be treated, Stored, or disposed of i0 compliance

with: (a) Sectio0 l2l(d) (3) of CEECLA 42 U.S.C § 962l(d) (3); (b)

Section 300.449 of the NCP; (c) RCRA; (d) the Toxic Substances

Control Act, 15 U.S.C § 260i, et seq.; and (e) all other applicable

federal and Commonwealth requir005

9. If hazardoussubstances from the Site are to be Shipped outside

of the CommonwealthRespondent Shall provide prior notification of

such Waste Shipments in accordance with the EPA Memorandum entitled

Notification of Out_of_State Shipments of Superfund Site Wastes”

(OSWER Directive330.2o7 Septeer 14, 1989)

. At least five (5)

Working Days prior to such Waste Shipme05 Respondent shall notify

the environmental agency of the accepting state of the following. (a)

the name and location of the facility to which the Wastes are to be

Shipped; (b) the type and quantity of Waste to be Shipped; (c) the

expected schedule for the Waste Shipments; (d) the method of

transportation and name of transporter; and (e) the treatment and/or

disposal method of the Waste Streams.

80. Certificates of destruction must be provided to EPA upon

Respondentr receipt of Such These certificates must be included in

the weekly progress reports and in the Final Report.

L.iancewithOth

81. All actions reguirpursuant to this Order shall be performed

in accordance with all applicableComonwea1th and federal laws and

regult005except as provided in CERCLA § 12l(e) (1), 42

§962l(e)(1), and 40 CFR § 300.4l5(j) In accordance with 40 CRE

§3OQ.4l5() all °°Site actions requirpursuant to this Order

shall, to the extent practicable as determined by EPA, considering

the exigeflc05 of the situati0, attain applicable or relevant and

appropriate reguire005(‘ARARS”) under federal environmental or

Commonwealthenvironmental or facility siting laws See “Superfund

Removal Procedures: Guidance on the Consideration of ARAR5 During

Removal Act1005 F(0SWrDirective No. 936o.3_02, August 1991).

82. Except as provided in Section l21(e) (1) of CEECLA 42 U.S.0

§9621(e) (1), and the NCp, no permit shell be required for any portion

of the Work reguirhereunder that is conducted entirely °Site

Where any Portion of the Work requj5 a federal or Commonwealth

permit or approval, Respondent shall submit timely applications and

shall take all Other actions necessary to obtain and to comply with

all such permits or approvals. This Order is not, nor shall it be

20

R2-000400

Construed to be, a permit issued pursuant to any federal or

Commonwealth statute or regulation

N. Emergencyponseand NOtifjcajoflRl

83. Upon the occurrence of any event during performa of the Work

required hereunder which, pursuant to Section 103 of CERCLA, 42

U.S.C. §9603, requires reporting to the National Response Center

(telephone nuer (800) 424-8802), Respondent shall also immediately

orally notify the Chief of the Removal Action Branch of the Emergency

and Remedial Response Division of EPA, Region II, at (732) 321-6658,

or the EPA Region 2 Emergency 24—hour Hot Line at (732) 548-8730, of

the incident or Site conditions Respondent shall also submit a

written report to EPA within seven (7) days after the onset of such

an event, setting forth the events that occurred and the measures

taken or to be taken, if any, to mitigate any release or endangerm0

caused or threatened by the release and to prevent the reoccurrence

of such a release. The reporting requireme5 of this paragraph are

in addition to, not in lieu of, reporting under CERCLA Section 103,

42 U.S.C. §9603, and Section 304 of the Emergency Planning and

Community Right_To_0Act of 1986, 42 U.S.C. §11004.

84. In the event of any action or occurrence during Respondentis

performance of the requiremef5 of this Order which causes or

threatens to cause a release of a hazardous Substance or which may

present an immediate threat to public health or welfare or the

environment, Respondent shall immediately take all appropriate action

to prevent, abate, or minimize the threat and shall immediately

notify EPA as provided in the Preceding paragraph Respondent shall

take such action in accordance with applicable provisions of this

Order including, but not limited to, the Health and Safety Plan. In

the event that EPA determines that (a) the activities performed

pursuant to this Order, (b) signifj0 changes in conditions at the

Site, or (c) emergency circumstances occurring at the Site pose a

threat to human health or the environment, EPA may direct Respondent

to stop further implementation of any actions pursuant to this Order

or to take Other and further actions reasonably necessary to abate

the threat.

85. Nothing in the Preceding paragraph shall be deemed to limit any

autfcrit of the Unite Stts to take, direct, or order all

to oroz:ct numa heajtt and th envjrc1e or to

prevent, abate, ormjnjrciize an actuat or threaLened release of

hazardous subsCanoes on, at, or from the Site.

R2-000401

N. Modifications

86. No informal advice, guidance, suggestio0, or comment by EPA

regarding reports, plans, specifications schedules, or any other

writing submitted by Respondent shall relieve Respondent of its

obligation to obtain such formal approval as may be required by this

Order and to comply with all requiremet of this Order.

0. Delay in Performance

87. Any delay in performance of the Work under this Order that, in

EPA’s judgment, is not Properly justified by Respondent under the

terms of the paragraph below, shall be considered a violation of this

Order. Any delay in performance of this Order shall not affect

Respondents obligatio5 to perform all obligations fully under the

terms and conditions of this Order.

88. Respondent shall notify EPA of any delay or anticipated delay in

Performing any requirem of this Order. Such notification shall be

made by telephone to EPA! OSC as Soon as Respondent knows that a

delay might occur. Respondent shall adopt all reasonable measures to

avoid or minimize any such delay. Within two (2) days after

notifying EPA by telephone, Respondent shall provide written

notification fully describing the nature of the delay, any

justificat0 for the delay, any reason why Respondent should not be

held Strictly accountable for failing to comply with any relevant

requireme5 of this Order, the measures planned and taken to

minimize the delay, and a schedule for implementing the measures that

have been or will be taken to mitigate the effect of the delay.

Increased cost or expense associated with the implementation of the

activities called for in this Order is not a justificaj0 for any

delay in performance

P. Enforcement and Reserva onof Rights

89. Notwithstanding any other provision of this Order, failure of

Respondent to comply with any provision of this Order may give rise

to an allegation by EPA that Respondent may be subject to civil

penalties of up to thirty-seven thousand five hundred dollars

($37,500) per violation per day, as provided in Section 106(b) (1) of

CERCLA, 42 U.S.C. § 9606(b) (1), and the Debt Collection and

Improvement Act of 1996, see Civil Monetary Penalty Inflation

Adjustme0 Rule, 40 C.F.R. Part 19. EPA may also allege that

Ees000dent also may be subject to punitive damages in an amount at

least equal to but not more than three times the amount of any costs

incurred by the United States as a result of such failure to comply

with this Order, as provided in Section lO7(c) (3) of CERCLA, 42

U.S.C. § 9607(c) (3). Should Respondent violate this Order or any

portion thereof, EPA may carry out the required actions unilatera1iy,

Ursart to Section 104 of CEPOLA, 42 U.S.C. § 9604, and/or may seek

judic±,] enforcpmett of this Order pursant to Section 106 of CEROLA,

42 U.s.C. § 9606. Nothing herein shall limit the power and authority

R2-000402

of EPA or the United States to take, direct or order all actions

flCCessary to protect public health welfare or the environment or

prevent abate or minimize an actual or threatened release of

hazardous substancesPollutants or contaminant or hazardous or

solid waste on, at, or from the Site Further, flothing herein shall

prevent EPA from seeking legal or equita relief to enforce the

terms of this Order, from taking Other legal or equitabaction as

t deems appropriate, or from requiringRespondent in the future to

perform additiona1 activities pursuant to CEECLA or any other

applicable law. EPA reserves the right to bring an action again5

Respondent under Section 107 of CEECLA 42 U.S.C. § 9607, for

recovery of any response costs incurred by the United States related

to this Order or the Sit5

Q. aim

90. By issuance of this Order, the United States and EPA assume no

liability for injur05 or damages to persons or Property resulting

from any acts or omissions of Respondent or Respondent,s employees,

agents,contractors, or consultants in carrying out any action or

activity pursuant to this Order. The United States or EPA shall not

be held out as or deemed a Party to any contract entered into by

Respondent or is directors, Officers, employees, agents,successors

representativesassigns,

contractors, or consultants in carrying out

actions pursuant to this Order.

91. Nothing in this Order constitutes or shall be construed as a

satisfaction of or release from any claim or cause of action again

Respondent or any person not a Party to this Order for any liability

that Respondent or Other persons may have under CEECLA, Other

statutes, or the coon law, including but not limited to any claims

of the United States for injunctrelief, costs, damages, and

interest under Sections 1O6(a) and 107 of CERCLA, 42 U.S.C §

9606(a) and 9607. Nothing herein shall constitute a finding that

Respondent is the only responsible Party with respect to the release

and threatened release of hazardous substances at and from the Site.

92. Nothing in this Order shall affect any right, claim, interest,

partiesdefense, or cause of action of any Party hereto with respect to third

93. Nothing in this Order shall be construed to

preauthorizationunder Section 111(a) (2) of CEECLA 42 U.S.C.

§Ooji (ai (2, and •Q OPs § .300.7O0(j

F. insurance

4. At least two (2) days prior to commencing any Work at the Site,

shall submit to EPA certifjrt that Pondet or its

no n,racc..5 a.nd Sbcorta hav accr or

tc -r

or.

which , result front the a(;j Vitae5 to

to

R2-000403

conducted by or on behalf of Respondent pursuant to this Order.Respondent shall ensure that such insurance or indemnification ismaintained for the duration of the Work required by this Order.

S. Financial Assurance

95. Respondent shall demonstrate its ability to complete the Workrequired by this Order and to pay all claims that arise from theperformance of the Work by obtaining and presenting to EPA withinfourteen (14) days of the effective date of this Order one of thefollowing: (1) a performance bond; (2) a letter of credit; (3) aguarantee by a third party; or (4) internal financial information toallow EPA to determine that Respondent has sufficient assets toperform the Work. Respondent shall demonstrate financial assurancein an amount no less than $250,000, which is the estimated cost ofthe Work to be performed by Respondent under this Order. If EPAdetermines that the financial assurances submitted by Respondentpursuant to this paragraph are inadequate, Respondent shall, withinfourteen (14) days after receipt of notice of EPA’s determination,obtain and present to EPA for approval additional financialassurances meeting the requirements of this paragraph. In addition,if at any time EPA notifies Respondent that the anticipated cost ofcompleting the Work has increased, then, within 30 days of suchnotification, Respondent shall obtain and present to EPA for approvala revised form of financial assurance (otherwise acceptable underthis Section) that reflects such cost increase. Respondent’sinability to demonstrate financial ability to complete the Work shallin no way excuse performance of any activities required under thisOrder.

T. Termination and Satisfaction

96. Upon a determination by EPA (following its receipt of the Final

Report referred to in paragraph 65 above) that the Work requiredpursuant to this Order has been fully carried out in accordance withthis Order, EPA will so notify Respondent in writing.

U. Opportunity to Confer, Effective Date

97. This Order shall be effective five (5) days after receipt byRespondent, unless a conference is timely requested pursuant toparagraph 99 below. If such a conference is timely requested, this

Order shall become effective one (1) day following the date the

conference is held, unless the effective date is modified by EPA.

All times for performance of ordered activities shall be calculated

from this effective date.

98. Respondent may, within three (3) days after receipt of this

Order, request a conference with EPA to discuss this Order. If

requested, the conference shall occur within five (5) days of

Respondent’s request for a conference. The conference may be held in

person or by telephone or videoconference.

24

R2-000404

If a Conference is held, Respondent may present any

information argume05 or comments regardingthis Order This

conference is not an evidentiary hearing and does not COnstitute a

Proceeding to challenge this Order It does not give Respondent a

right to seek review of this Order or to seek resolution of

potential liability and no official stenogrpjrecord of the

Conference wilj be made. At any conference held pursuant to

Respondents, regue5 Respondents may appear in person or by an

attorney or other representative.

100. A reque5 for a conference must be made by telephone to Carol

Bern5, Assistant RegionCounsel, Office of Region

Counsel, EPA

Region 2, telephone (212) 6373177 followed by writtenconfirmation

faxed that day to Ms. Berns at (212) 6373lQ4

V.eofIntet

101. Respondent shall provide not later than three (3) days after

the effective date of this Order, written notice to EPA stating

whether it will comply with the terms of this Order. If Respondent

does not uneguivocal1ycomit to perform the work requir by this

Order, EPA shall deem that Respondent has violated this Order and

has failed or refused to comply with this Order Respondent,

written notice shall describe, Using facts that exist on or prior to

the effective date of this Order, any “sufficient cause” defenses

asserted by Respondent Under Sections l06(b) and l07(c) (3) of

CEROLA Respondent,swritten flOtice shall be sent to Carol Bern5,

Assistant Regio0 Counsel 0ffice of RegionCounsel, EPA Region

2, 290 Broadway l7t floor, New York, New York l00Q7l866 The

absence of a response by EPA to the notice requir by this

assertions.Paragrp shall not be deemed to be an acceptance of Respondent,s

U. S IRoNMENT PROTECTION AGENCY

/ 1.

/.1 .•

..

.,..—

‘Walter S. Mugd

Division Director

Emergen and Remedial ResponseDIVision

S. onviro1. Ager.oy n 2

/

‘5suae

R2-000405

R2-000406

tftpi’II

I:

11

Jir—.

1.V•44—

‘74,

‘4

1v.

S

hi

R2-000407

R2-000408




Appendix B Site Map

R2-000409

Central RoigMunicipio de Yabucoa

Fecha: 1/16/2014

Preparado en ArcMap por Mayra Torres Rivera

.1:1,500

R2-000410

12

11

10

9

8

7

6

5

2

1 3 4

Lab




Appendix C Personnel Certifications

R2-000411

R2-000412

R2-000413

R2-000414

R2-000415

R2-000416

R2-000417

R2-000418

R2-000419

R2-000420

R2-000421

R2-000422

R2-000423

R2-000424

R2-000425

R2-000426

R2-000427

R2-000428

R2-000429

R2-000430

R2-000431

R2-000432

R2-000433

R2-000434

R2-000435

R2-000436

R2-000437

R2-000438

R2-000439

R2-000440

R2-000441

R2-000442

R2-000443

R2-000444

R2-000445

R2-000446

R2-000447

R2-000448

R2-000449

R2-000450

R2-000451

R2-000452

R2-000453

R2-000454

R2-000455

R2-000456

R2-000457

R2-000458

R2-000459

R2-000460

R2-000461

R2-000462

R2-000463

R2-000464

R2-000465

R2-000466

R2-000467

R2-000468

R2-000469

R2-000470

R2-000471

R2-000472

R2-000473

R2-000474

R2-000475

R2-000476

R2-000477

R2-000478

R2-000479

R2-000480

R2-000481

R2-000482

R2-000483

R2-000484

R2-000485

R2-000486

R2-000487

R2-000488

R2-000489

R2-000490

R2-000491

R2-000492

R2-000493

R2-000494

R2-000495

R2-000496

R2-000497

R2-000498

R2-000499

R2-000500

R2-000501

R2-000502

R2-000503

R2-000504

R2-000505

R2-000506

R2-000507

R2-000508

R2-000509

R2-000510

R2-000511

R2-000512

R2-000513

R2-000514

R2-000515

R2-000516

R2-000517

R2-000518

R2-000519

R2-000520

R2-000521

R2-000522

R2-000523

R2-000524

R2-000525

R2-000526

R2-000527

R2-000528

R2-000529

R2-000530

R2-000531

R2-000532

R2-000533

R2-000534

R2-000535

R2-000536

R2-000537

R2-000538

R2-000539

R2-000540

R2-000541

R2-000542

R2-000543

R2-000544

R2-000545

R2-000546

R2-000547

R2-000548

R2-000549

R2-000550

R2-000551

R2-000552

R2-000553

R2-000554

R2-000555

R2-000556

R2-000557

R2-000558

Maria Pagan Has diligently and with merit completed training in

HAZWOPER 8-Hour Refresher

On 12/04/2013 from the USF OTI Education Center.

R2-000559

R2-000560

R2-000561

R2-000562

R2-000563

R2-000564

R2-000565

R2-000566

R2-000567

R2-000568

R2-000569

R2-000570

R2-000571

R2-000572

R2-000573

R2-000574

R2-000575

R2-000576

R2-000577

R2-000578

R2-000579

R2-000580

R2-000581

R2-000582

R2-000583




Appendix D Site Specific Health and Safety Plan (SSHP)

R2-000584




Appendix E Sampling and Analysis Plan (SAP)

R2-000585




Appendix F Transportation and Disposal Plan (TDP)

R2-000586




Appendix G Bridge Security, Inc. Company Information

R2-000587

R2-000588




Appendix H Asbestos-Specific Work Plan and Health and

Safety Section

R2-000589

central roig sugar mills superfund site

Documents