Teknor Apex Tennessee Company Tnd054876834 Post-Closure Plan Tnhw-183

TEKNOR APEX TENNESSEE COMPANY TND054876834 POST-CLOSURE PLAN TNHW-183

EPA ID NUMBER: TND054876834 POST-CLOSURE PLAN: TNHW-183

TABLE OF CONTENTS

Page No. I. STANDARD CONDITIONS

A. EFFECT OF PLAN I-1 B. SEVERABILITY I-1 C. DEFINITIONS I-2 D. GENERAL DUTIES AND REQUIREMENTS I-6 E. CONFIDENTIAL INFORMATION I-12 F. DOCUMENTS TO BE MAINTAINED AT THE FACILITY I-12 G. ANNUAL MAINTENANCE FEES I-13 H. REQUIRED NOTICE FOR OWNERSHIP TRANSFER I-13 I. ORDER OF PRECEDENCE I-13 J. PLAN STRUCTURE I-14

II. GENERAL FACILITY CONDITIONS

A. SECURITY II-1 B. GENERAL INSPECTION REQUIREMENTS II-1 C. PERSONNEL TRAINING II-2 D. FINANCIAL REQUIREMENTS FOR POST-CLOSURE II-2 E. FINANCIAL REQUIREMENTS FOR CORRECTIVE ACTION II-6 F. RECORDKEEPING AND REPORTING II-9 G. LAND DISPOSAL RESTRICTIONS II-10 H. ORGANIC AIR EMISSION STANDARDS II-10 I. RESTRICTION ON OWNERSHIP OF THE FACILITY II-10

III. SPECIFIC CONDITIONS FOR POST-CLOSURE CARE

A. UNIT IDENTIFICATION III-1 B. POST-CLOSURE CARE III-1 C. POST-CLOSURE CARE AND USE OF PROPERTY III-1 D. INSPECTIONS III-2 E. POST-CLOSURE PERMIT MODIFICATIONS III-2 F. NOTICES AND CERTIFCATIONS III-2

IV. SPECIFIC CONDITIONS FOR GROUNDWATER MONITORING

A. MAINTENANCE OF GROUNDWATER MONITORING SYSTEMS IV-1 B. ELEVATION OF THE GROUNDWATER SURFACE IV-2 C. SAMPLING PROCEDURES IV-2 D. ANALYTICAL PROCEDURES IV-2 E. GROUNDWATER PROTECTION STANDARD IV-3

TABLE OF CONTENTS (Continued)

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F. DETECTION MONITORING DATA EVALUATION AND RESPONSE IV-3 G. REPORTING, RECORDKEEPING AND RESPONSE IV-6 H. ASSURANCE OF COMPLIANCE IV-6

V. SPECIFIC CONDITIONS FOR CORRECTIVE ACTION

A. APPLICABILITY V-1 B. NOTIFICATION AND ASSESSMENT REQUIREMENTS FOR NEWLY IDENTIFIED SWMUs AND AOCs V-2 C. NOTIFICATION REQUIREMENTS FOR NEWLY DISCOVERED RELEASES FROM SWMUs OR AOCs V-3 D. CONFIRMATORY SAMPLING (CS) V-3 E. RCRA FACILITY INVESTIGATION (RFI) V-4 F. INTERIM MEASURES (IM) V-7 G. CORRECTIVE MEASURES STUDY (CMS) V-9 H. REMEDY APPROVAL AND PERMIT MODIFICATION V-10 I. REMEDY IMPLEMENTATION V-10 J. INSTITUTIONAL CONTROLS (ICs) V-11 K. COMPLETION OF CORRECTIVE ACTION V-11 L. MODIFICATION OF THE CORRECTIVE ACTION COMPLIANCE SCHEDULE V-12 M. WORK PLAN AND REPORT REQUIREMENTS V-12 N. APPROVAL / DISAPPROVAL OF SUBMISSIONS V-13 O. DISPUTE RESOLUTION V-13

ATTACHMENT

ATTACHMENT 1 FACILITY DESCRIPTION A1

ATTACHMENT 2 SECURITY A2

ATTACHMENT 3 INSPECTIONS A3

ATTACHMENT 4 POST-CLOSURE CARE PLAN A4

ATTACHMENT 5 GROUNDWATER MONITORING A5

ATTACHMENT 6 SOLID WASTE MANAGEMENT UNITS AND AREAS OF CONCERN A6

ATTACHMENT 7 METHODOLOGY FOR MONITORING WELL ABANDONMENT AND CLOSURE A7

Facility: Teknor Apex Tennessee Company Owner/Operator: Teknor Apex EPA ID Number: TND054876834 Plan Number: TNHW-183

I. STANDARD CONDITIONS

A. EFFECT OF PLAN

The facility is required to perform post-closure care and monitoring in accordance with the conditions of this plan. The facility is also required to conduct corrective action for any release of hazardous waste or hazardous constituents in accordance with the conditions of this plan. Any receipt or handling of hazardous waste not authorized in this plan is prohibited, unless such management is not subject to a plan as set forth at Rule 0400-12-01- .07(1)(b), is operating under interim status as set forth in Rule 0400-12-01-.07(3)(a), or is subject to a separate hazardous waste management plan issued by the Tennessee Department of Environment and Conservation (Department).

Compliance with this plan during its term constitutes compliance, for the purposes of enforcement, with the Tennessee Hazardous Waste Management Act of 1977, as amended, as it applies to the plan activities, except for those requirements not included in the plan which: (1) become effective by statute or (2) are promulgated under Rule 0400-12-01-.10 restricting the placement of hazardous waste in or on the land. However, this plan may be modified, revoked and reissued, or terminated during its term for cause as set forth in this plan and Paragraph (9) of Rule 0400-12-01-.07.

Issuance of this plan does not authorize any injury to persons or property or invasion of other private rights, or any infringement of other State or local laws or regulations. This plan does not convey any property rights of any sort or any exclusive privilege.

Compliance with the terms of this plan does not constitute a defense to any Order issued or any action brought under Section 3013 or Section 7003 of the Resource Conservation and Recovery Act of 1976 as amended (42 U.S.C.A. 6901 et seq., commonly referred to as RCRA), Sections 104, 106(a) and 107 of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42 U.S.C.A. 9601 et seq., commonly known as CERCLA), Sections 68-212-206(a), 207, and 215(c) of the Tennessee Hazardous Waste Management Act of 1983, as amended, or any other law providing for protection of public health or the environment.

B. SEVERABILITY

The provisions of this plan are severable, and if any provision of this plan or the application of any provision of this plan to any circumstance is held invalid, the application of such provision to other circumstances and the remainder of this plan shall not be affected thereby.

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C. DEFINITIONS

For the purpose of this plan, terms used herein shall have the same meaning as those in Rules 0400-12-01-.01, 0400-12-01-.02, 0400-12-01-.06, 0400-12-01-.07, and 0400-12-01- .10 unless this plan specifically provides otherwise. Where terms are not defined in the regulations or the plan, the meaning associated with such terms shall be as defined by applicable U.S. Environmental Protection Agency (EPA) guidelines or publications. Otherwise, the generally accepted scientific or industrial meaning of the term or the standard dictionary reference shall apply.

1. “Act” means the Tennessee Hazardous Waste Management Act, as amended [Tennessee Code Annotated (T.C.A.) 68-212-101 et seq.].

2. “Annual” means a period not to exceed 365 days.

3. "Area of concern" or “AOC” means any area having a probable release of a hazardous waste or hazardous constituent that is not from a solid waste management unit and is determined by the Commissioner to pose a current or potential threat to human health or the environment. Such areas of concern may require investigations and remedial action as required by this plan in order to ensure adequate protection of human health and the environment.

4. “Area of contamination” is a discrete contiguous area of generally dispersed contamination that can be considered a solid waste management unit. Because an area of contamination is equated to a solid waste management unit, consolidation and/or in situ treatment of hazardous wastes within that area do not create a new point of hazardous waste generation. An area of contamination allows wastes to be consolidated or treated in situ within the area of contamination without triggering land disposal restrictions (LDRs) or minimum technology requirements.

5. “Commissioner” means the Commissioner of the Tennessee Department of Environment and Conservation (formerly the Tennessee Department of Health and Environment) or his authorized representative.

6. “Corrective action” shall be defined as all activities, including activities conducted beyond the facility boundary, that are proposed or implemented to facilitate assessment, monitoring, and active or passive remediation of releases of hazardous waste or hazardous constituents to soil, groundwater, surface water, or the atmosphere associated with solid waste management units and/or areas of concern and/or areas of contamination located at the facility or off-site, as required by Rule 0400-12-01-.06(6)(k) and (l), or as otherwise required and specified by this plan.

7. A "corrective action management unit" or “CAMU” means an area within a facility that is used only for managing remediation wastes for implementing corrective action or cleanup at the facility.

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8. "Corrective measures" include all corrective action necessary to protect human health and the environment for all releases of hazardous waste or hazardous constituents from any solid waste management unit at the facility, regardless of the time at which the waste was placed in the unit, as required under Rule 0400-12-01- .06(6)(l). Corrective measures may address releases to air, soil, sediment, surface water or groundwater.

9. “Department” means the Tennessee Department of Environment and Conservation (formerly Tennessee Department of Health and Environment).

10. "Division Director" or “Director” means the Director of the Division of Solid Waste Management of the Department, or a designee. This person also serves as the Technical Secretary to the Board, and functions as the chief of staff to both the Commissioner and the Board in matters relating to these rules and their implementation.

11. "Extent of contamination" is defined as the horizontal and vertical area in which the concentrations of hazardous constituents in the environmental media are above detection limits or background concentrations indicative of the region, whichever is appropriate as determined by the Commissioner.

12. "Facility" means:

a. All contiguous land, and structures, other appurtenances, and improvements on the land, used for treating, storing, or disposing of hazardous waste, or for managing hazardous secondary materials prior to reclamation. A facility may consist of several treatment, storage, or disposal operational units (e.g., one or more landfills, surface impoundments or combination of them).

b. For the purposes of implementing corrective action under Rule 0400-12-01- .06(6)(l), all contiguous property under the control of the owner or operator seeking a plan under the Tennessee Hazardous Waste Management Act, T.C.A. 68-212-101 et seq. This definition also applies to facilities implementing corrective action under T.C.A. 68-212-111.

c. Notwithstanding part 2 of this definition, a remediation waste management site is not a facility that is subject to Rule 0400-12-01-.06(6)(I) but is subject to corrective action requirements if the site is located within such a facility.

13. “Hazardous waste” means a hazardous waste as defined in Rule 0400-12-01- .02(1)(c).

14. “Hazardous waste constituent” means a constituent that caused the Board to list the hazardous waste in Rule 0400-12-01-.02(4), or a constituent listed in Table 1 of Rule 0400-12-01-.02(3)(e).

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15. “Institutional controls” (ICs) are non-engineered instruments, such as administrative and legal controls, that help minimize the potential for human exposure to contamination and/or protect the integrity of the corrective measures.

16. "Interim measures" (IM) are actions necessary to minimize or prevent the further migration of contaminants and limit actual or potential human and environmental exposure to contaminants while long-term corrective action remedies are evaluated and, if necessary, implemented.

17. "Land disposal" when used in respect to a specified hazardous waste, shall be deemed to include, but not limited to any placement of such hazardous waste in a landfill, surface impoundment, waste pile, injection well, land treatment facility, salt dome formation, salt bed formation, or underground mine or cave.

18. "Landfill" includes any disposal facility or part of a facility where hazardous waste is placed in or on the land and which is not a pile, a land treatment facility, a surface impoundment, an underground injection well, a salt dome formation, a salt bed formation, an underground mine, a cave or a corrective action management unit.

19. “Monthly” means recurring by the end of the same day of the following month, but no later than the last day of the following month (e.g., if an action required to be conducted monthly is taken on the 3rd of a month, then the action must be taken again by midnight ending the 3rd of the following month).

20. "Point of compliance" refers to the vertical surface located at the hydraulically downgradient limit of the waste management area that extends down into the uppermost aquifer underlying the regulated unit.

21. “Point of exposure” refers to a point in place and time that an organism can come in contact (ingestion, inhalation or dermal contact) with a hazardous constituent. Facilities are usually evaluated for human health and environmental concerns. Environmental is synonymous with the term ecological, which includes all plants and animals, except humans.

22. “Registered engineer” or “registered professional engineer” refers to a person authorized to perform engineering in Tennessee pursuant to Tennessee Code Annotated, Title 62, Chapter 2.

23. "Release" includes any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping or disposing into the environment of any hazardous waste or hazardous constituents.

24. “Remedy construction” shall mean the event when the State or the EPA acknowledges in writing that the hazardous waste facility has completed construction of a facility’s remedy that was designed to achieve long-term protection of human health and the environment and that the remedy is fully

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functional as designed, whether or not final cleanup levels or other requirements have been achieved. Remedy construction may be site-wide or pertain only to specific areas of the facility.

25. “Remedy decision” shall mean the event by which the Department or the EPA formally selects a remedy designed to meet hazardous waste corrective action long- term goals of protection of human health and the environment. A remedy decision may be site-wide or pertain only to specific areas of the facility.

26. "Remediation waste" means all solid and hazardous wastes, all media (including groundwater, surface water, soil and sediment), and debris that are managed for implementing cleanup.

27. "Screening levels" are health-based concentrations of hazardous constituents determined to be indicators for the protection of human health and/or the environment.

28. "Solid waste" means a waste as defined in Rule 0400-12-01-.02(1)(b).

29. A "solid waste management unit" (SWMU) includes any unit that has been used for the treatment, storage or disposal of solid waste at any time, irrespective of whether the unit is or ever was intended for the management of solid waste. Plan or interim status hazardous waste management units are also solid waste management units. Solid waste management units include areas that have been contaminated by routine and systematic releases of hazardous waste or hazardous constituents, excluding one-time accidental spills that are immediately remediated and cannot be linked to solid waste management activities, e.g., product or process spills.

30. A “statement of basis” is a document that describes the process the Department uses under the Tennessee Hazardous Waste Management Act to select measures for containing or cleaning up contamination at a hazardous waste management facility. Specific information in the statement of basis typically includes: description and environmental setting of the facility, names and concentrations of contaminants detected at the facility and associated exposure pathways, selected remedy, innovative technologies considered in determining the remedy, and public involvement requirements under the corrective action.

31. "Surface impoundment" or "impoundment" includes any facility or part of a facility which is a natural topographic depression, man-made excavation or diked area formed primarily of earthen materials, although it may be lined with man-made materials, which is designed to hold an accumulation of liquid wastes or wastes containing free liquids, and which is not an injection well. Examples of surface impoundments are holding, storage, settling and aeration pits, ponds and lagoons.

32. A "temporary unit" (TU) includes any temporary tanks and/or container storage areas used solely for treatment or storage of hazardous remediation wastes during

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specific remediation activities. Designated by the Commissioner, such units must conform to specific standards and may only be in operation for the period of time as specified in this plan.

33. A "unit" includes, but is not limited to, any landfill, surface impoundment, waste pile, land treatment unit, incinerator, injection well, tank, container storage area, septic tank, drain field, wastewater treatment unit, elementary neutralization unit, transfer station or recycling unit.

D. GENERAL DUTIES AND REQUIREMENTS

1. Duty to Comply: The facility shall comply with all conditions of this plan, except that the facility need not comply with the conditions of the plan to the extent and for the duration such noncompliance is authorized in an emergency permit. Any plan noncompliance, except under the terms of an emergency permit, constitutes a violation of the Act and is grounds for enforcement action; for plan termination, revocation and reissuance, or modification.

2. Duty to Reapply: If the facility wishes to continue an activity regulated by this plan after the expiration date of this plan, the facility must apply for and obtain a new plan. The facility must submit a new application at least 180 days before the expiration date of the effective plan, unless permission for a later date has been granted by the Commissioner. The Commissioner shall not grant permission for applications to be submitted later than the expiration date of the existing plan.

3. Need to Halt or Reduce Activity Not a Defense: It shall not be a defense for the facility in an enforcement action that it would have been necessary to halt or reduce the plan activity in order to maintain compliance with the conditions of this plan.

4. Duty to Mitigate: In the event of noncompliance with the plan, the facility shall take all reasonable steps to minimize releases to the environment, and shall carry out such measures as are reasonable to prevent significant adverse impacts on human health or the environment.

5. Proper Operation and Maintenance: The facility shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the facility to achieve compliance with the conditions of this plan. Proper operation and maintenance includes effective performance, adequate funding, adequate operator staffing and training, and adequate laboratory and process controls, including appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems only when necessary to achieve compliance with the conditions of the plan.

6. Plan Actions: This plan may be modified, revoked and reissued, or terminated for cause as specified in Rule 0400-12-01-.07(9)(c). The filing of a request by the

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facility for a plan modification, revocation and reissuance, or termination, or a notification of planned changes under Subparagraph I.D.11(a) or anticipated noncompliance under Subparagraph I.D.11(b) does not stay any existing plan condition.

7. Duty to Provide Information: The facility shall furnish to the Commissioner, within a reasonable time, any relevant information which the Commissioner may request to determine whether cause exists for modifying, revoking and reissuing, or terminating this plan, or to determine compliance with this plan. The facility shall also furnish to the Commissioner, upon request, copies of records required to be kept by this plan.

8. Inspection and Entry: The facility shall allow the Commissioner, or any authorized representative, upon presentation of credentials and other documents as may be required by law, to:

(a) Enter, at reasonable times, upon the facility's premises where a regulated unit(s) or activity is located or conducted, or where records must be kept under the conditions of this plan;

(b) Have access to and copy, at reasonable times, any records that must be kept under the conditions of this plan;

(c) Inspect, at reasonable times, any facilities, equipment (including monitoring and control equipment), practices, or operations regulated or required under this plan;

(d) Sample or monitor, at reasonable times, for the purposes of assuring plan compliance or as otherwise authorized by the Act, any substances or parameters at any location; and

(e) Make photographs for the purpose of documenting items of compliance or noncompliance at waste management units or, where appropriate to protect legitimate proprietary interests, make such photographs for him or her.

9. Monitoring and Records

(a) Samples and measurements taken for the purpose of monitoring shall be representative of the monitored activity. The facility shall perform all monitoring in accordance with the methods described in this plan, including the attachments. If not specified elsewhere in this plan, the methods used to obtain, pack, mark, label and ship a representative waste or media sample to be analyzed must be the appropriate methods from Appendix I of Rule 0400- 12-01-.02(5) and the EPA Region 4 Science and Ecosystem Support Division’s Field Branches Quality System and Technical Procedures (most

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recent version), or an equivalent method approved by the Commissioner. Media include soil, sediment, water, waste water and tissue. If not specified elsewhere in this plan, the type and size of containers for each parameter, the methods of preservation, holding times and other sample preparation requirements used to prepare and preserve representative samples to be analyzed must be the appropriate methods from EPA Region 4 Science and Ecosystem Support Division’s Laboratory Operations and Quality Assurance Manual (most recent version),

If not specified elsewhere in this plan, the methods used to handle and manage samples and other types of evidence after their collection and during delivery to the laboratory must be the appropriate methods from EPA Region 4 Science and Ecosystem Support Division’s Field Branches Quality System and Technical Procedures Sample and Evidence Management Operating Procedure (most recent version), or an equivalent method approved by the Commissioner. Methods for the collection and handling of air, gas or vapor samples must receive prior approval by the Commissioner. If not specified elsewhere in this plan, laboratory methods must be those specified in the most recent edition of Test Methods for Evaluating Solid Waste: Physical/ Chemical Methods, SW-846, or an equivalent method approved by the Commissioner.

(b) As provided for under Rule 0400-12-01-.06, the facility shall retain at the facility or other appropriate location as approved by the Commissioner, records of all monitoring information required under the terms of this plan and applicable monitoring and record keeping required for applicable requirements of Rules 0400-12-01-.01, .02, .06, .09, and .10; including all calibration and maintenance records, records of all data used to prepare documents required by this plan, copies of all reports and records required by this plan, the certification required by Rule 0400-12-01-.06(5)(d)2(ix), and records of all data used to complete the application for this plan for a period of at least three years from the date of the sample, measurement, report, certification or application, or until corrective action is completed, whichever date is later. As a generator of hazardous waste, the facility shall retain a copy of all notices, certifications, demonstrations, waste analysis data, and other documentation produced pursuant to Rule 0400-12-01-.10 for at least three years from the date that the waste which is the subject of such documentation was last sent for on-site or off-site treatment, storage, or disposal, or until corrective action is completed, whichever date is later. The facility shall maintain records from all groundwater monitoring wells and associated groundwater surface elevations, for the active life of the facility, and, for disposal facilities, for the post-closure care period as well. These periods may be extended by request of the Commissioner at any time and are automatically extended during the course of any unresolved enforcement action regarding this facility.

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(i) The date, exact place, and time of sampling or measurements;

(ii) The individual(s) who performed the sampling or measurements;

(iii) The date(s) analyses were performed;

(iv) The individual(s) who performed the analyses;

(v) The analytical techniques or methods used; and

(vi) The results of such analyses.

10. Signatory Requirement: All applications, reports, or information submitted to the Commissioner shall be signed and certified. All signatures and certifications shall satisfy the requirements of Rule 0400-12-01-.07(2)(a).

11. Reporting Requirements

(a) Planned changes: The facility shall give written notice to the Commissioner as soon as possible of any planned physical alterations or additions to the plan facility SWMUs and AOCs requiring institutional/ administrative controls, including facility-initiated Interim Measures under Subparagraph V.F.1(b) or other activities that impact known or suspected contamination at or from SWMUs or AOCs, including areas off-site from the facility. The notice shall include at a minimum, a summary of the planned change, the reason for the planned change, a discussion of the impact(s) the planned change will have on the ability to investigate contamination at or from the SWMU or AOC, and a discussion of the impact(s) the planned change will have on the contamination.

(b) Anticipated noncompliance: The facility shall give advance notice to the Commissioner as soon as possible of any planned changes in the plan facility or activity which may result in noncompliance with plan requirements.

(c) Transfers: This plan is not transferable to any person except after notice to the Commissioner. The Commissioner may require modification or revocation and reissuance of the plan to change the name of the facility and incorporate such other requirements as may be necessary under the Act. (See Rule 0400-12-01-.07(9)(b); in some cases, modification or revocation and reissuance is mandatory.)

(d) Monitoring reports: Monitoring results shall be reported at the intervals specified elsewhere in this plan.

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(e) Compliance schedules: Reports of compliance or noncompliance with, or any progress reports on, interim and final requirements contained in any compliance schedule of this plan shall be submitted no later than 14 days following each schedule date. Submission of a required item according to the schedule constitutes notification of compliance.

(f) Twenty-four hour reporting:

(i) The facility shall report to the Commissioner any noncompliance or any imminent or existing hazard from a release of hazardous waste or hazardous constituent which may endanger health or the environment orally within 24 hours from the time the facility becomes aware of the circumstances, including but not limited to:

(I) Information concerning release of any hazardous waste or hazardous constituent that may cause an endangerment to public drinking water supplies.

(II) Any information of a release or discharge of hazardous waste or hazardous constituent, or of a fire or explosion from the hazardous waste management facility, which could threaten the environment or human health outside the facility.

(ii) The description of the occurrence and the cause shall include:

(I) Name, address, and telephone number of the owner or operator;

(II) Name, address, and telephone number of the facility;

(III) Date, time, and type of incident;

(IV) Name and quantity of material(s) involved;

(V) The extent of injuries, if any;

(VI) An assessment of actual or potential hazards to the environment and human health outside the facility, where applicable; and

(VII) Estimated quantity and disposition of recovered material that resulted from the incident.

(iii) A written submission shall also be provided to the Commissioner within five days of the time the facility becomes aware of the circumstances. The written submission shall contain a description of

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the noncompliance and its cause; the period of noncompliance including exact dates and times, and if the noncompliance has not been corrected, the anticipated time it is expected to continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance. The Commissioner may waive the five-day written notice requirement in favor of a written report within 15 days.

(g) Annual report: An annual report must be submitted to the Commissioner covering facility activities during the previous calendar year, including those specified in Paragraph II.F.2.

(h) Other noncompliance: The facility shall report to the Commissioner all instances of noncompliance not reported under Subparagraphs I.D.11(d), (e), and (f) above, at the time monitoring reports are submitted. The reports shall contain the information listed in Subparagraph I.D.11(f) as appropriate.

(i) Other information: Where the facility becomes aware that it failed to submit any relevant facts in a plan application, or submitted incorrect information in a plan application or in any report to the Commissioner, it shall promptly submit such facts or information. In addition, upon request, the facility shall furnish to the Commissioner any information related to compliance with this plan.

12. Information Repository: The Commissioner may require the facility to establish and maintain an information repository at any time, based on the factors set forth in Rule 0400-12-01-.07(7)(e)4(v)(III) The information repository will be governed by the provisions in items Rule 0400-12-01-.07(7)(e)4(v)(III) through (VI).

13. Continuation of Expiring Plan: When the facility has made timely and sufficient application for a new plan, the existing plan does not expire until the Commissioner has made a final determination on issuance or denial and, in case the application is denied, or the terms of the new plan are limited, until the last day for seeking review of the Commissioner's order or a later date fixed by order of the reviewing court.

14. Obligation for Corrective Action: Pursuant to the requirements of SECTION V, SPECIFIC CONDITIONS FOR CORRECTIVE ACTION, the facility is required to select and implement corrective actions as necessary to protect human health and the environment for all releases of hazardous waste or constituents from any solid waste management unit at the facility, regardless of the time at which waste was placed in such unit. The facility is required to continue this plan for any period necessary to comply with the corrective action requirements of this plan.

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E. CONFIDENTIAL INFORMATION

In accordance with Rules 0400-12-01-.01(7) and .07(1)(h), the facility may assert a claim of confidentiality when submitting any proprietary information required by this plan.

F. DOCUMENTS TO BE MAINTAINED AT THE FACILITY

The facility shall maintain at the facility, or other location as approved by the Commissioner, until corrective action is completed and certified by a qualified Professional Engineer, the following documents and the amendments, revisions and modifications to these documents:

1. A copy of this plan and all modifications;

2. Personnel training documents and records required by this plan, except that training records on former employees are not required to be kept for more than three years from the date the employee last worked at the facility. Personnel training records may accompany personnel transferred within the same company;

3. All corrective action work plans, reports and other documents as specified by the Commissioner and SECTION V, SPECIFIC CONDITIONS FOR CORRECTIVE ACTION, and the attachments to this plan;

4. Operating and other applicable administrative records as required by this plan and Chapter 0400-12-01;

5. Monitoring information in accordance with Subparagraph I.D.9(b) and IV;

6. Inspection records in accordance with Paragraph II.B.3, except that inspection records need only be kept for three years after the date of the inspection; and

7. A copy of the current post-closure cost estimate, and if Subsection II.E is applicable, the current corrective action cost estimate.

G. ANNUAL MAINTENANCE FEES

The facility shall submit to the Commissioner annual maintenance fees as required by Rule 0400-12-01-.08(4)(b)6, by March 1 for activities performed the previous year. Interest and penalties will accrue for all late payments.

H. REQUIRED NOTICE FOR OWNERSHIP TRANSFER

Before transferring ownership or operation of a facility during its operating life, or of a disposal facility during the post-closure care period, the facility must notify the new owner or operator in writing of the requirements of this plan and Rule 0400-12-01-.07 and .08.

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However, the facility's failure to notify the new owner or operator of the requirements of this plan condition in no way relieves the new owner or operator of his obligation to comply with all applicable requirements.

I. ORDER OF PRECEDENCE

In the event of any inconsistency between the plan conditions and the material contained in any attachment to this plan, the plan conditions shall take precedence.

J. PLAN STRUCTURE

This plan is organized, numbered, and referenced according to the following outline form:

I. Section

A. Subsection

1. Paragraph

(a) Subparagraph

(i) Part

(I) Subpart

(A) Item

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EPA ID Number: TND054876834 Plan Number: TNHW-183

II. GENERAL FACILITY CONDITIONS

A. SECURITY

1. The facility shall prevent the unknowing entry, and minimize the possibility for the unauthorized entry, of persons or livestock onto the active portions of the facility. The facility shall provide and maintain appropriate site security measures to minimize the threat of exposure to hazardous waste or hazardous constituents in accordance with this subsection and ATTACHMENT 2, SECURITY.

2. The facility shall post signs on or near fencing with the legend, “DANGER– UNAUTHORIZED PERSONNEL KEEP OUT" or other appropriate legend in sufficient numbers to be seen from any reasonable approach to the active facility. The legend must be written in English and in any other language predominant in the area surrounding the facility, and must be legible from a distance of at least 25 feet. To avoid the threat of exposure, signs or other means of notification shall be installed at all SWMUs and AOCs to identify required institutional controls.

B. GENERAL INSPECTION REQUIREMENTS

1. Inspections: The facility shall inspect the facility for malfunctions and deterioration, operator errors, and discharges which may be causing or may lead to (1) release of hazardous constituents to the environment or (2) a threat to human health. The facility shall inspect each listed item on the inspection form(s) in ATTACHMENT 3, INSPECTIONS. The inspection type and frequency shall be in accordance with ATTACHMENT 3.

2. Remedies: The facility shall remedy any deterioration or malfunction of equipment or structures which the inspection reveals, on a schedule which ensures that the problem will not lead to an environmental or human health hazard. When a hazard is imminent or has already occurred, remedial action shall be taken immediately.

3. Inspection Records: The facility shall record inspections in an inspection log or summary. The facility shall keep these records for at least three years from the date of inspection. At a minimum, these records shall include the date and time of the inspection, the name of the inspector, a notation of the observations made, and the date and nature of any repairs or other remedial actions. The facility may change the format and content of the inspection form(s) in ATTACHMENT 3, as deemed necessary to provide the information he needs to properly manage the facility. Any deletion of information from such form(s), however, must be approved in advance, in writing, by the Commissioner as a modification to this plan.

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C. PERSONNEL TRAINING

The facility shall comply with all the applicable personnel training and documentation requirements of Rule 0400-12-01-.06(2)(g) including, but not limited to:

1. The facility shall ensure that facility personnel and contractors that serve to meet the requirements of this plan successfully complete a program of classroom instruction and/or on the job training that teaches them to perform their specific duties in a way that assures the facility’s compliance with this plan and the applicable portions of Rule 0400-12-01-.06(2)(g) associated with a post-closure plan. The facility shall ensure that the training program is directed by a person(s) trained in hazardous waste management procedures and shall include instruction which teaches facility personnel the hazardous waste management procedures relevant to the positions in which they are employed. Appropriate training shall also be provided for personnel involved with corrective action investigation and remediation activities, and for any additional plan-specific requirements in the attachments to this plan.

2. Retention of Training Records: Training records on current personnel shall be kept until closure of the facility; training records on former employees shall be kept for at least three years from the date the employee last worked at the facility. Personnel training records may accompany personnel transferred within the same company.

D. FINANCIAL REQUIREMENTS FOR POST-CLOSURE CARE

1. Cost Estimate for Post-Closure Care: The facility shall have a detailed written estimate, in current dollars, of the annual cost of post-closure monitoring and maintenance of the facility in accordance with the requirements of Rule 0400-12- 01-.06(8)(e). The estimate shall include the cost of maintaining site security and for performing all plan-required inspections. For maintenance and/or repair activities not covered as part of the annual maintenance cost, the estimate shall also include the capital cost for making the anticipated long-term repairs throughout the post-closure period.

(a) The post-closure cost estimate shall be based on the costs to the facility of hiring a third party to conduct post-closure care activities. A third party is a party who is neither a parent nor a subsidiary of the facility.

(b) The post-closure cost estimate shall be calculated by multiplying the annual post-closure cost estimate by 30 years of post-closure care as required under Rule 0400-12-01-.06(7)(h) and as specified in Paragraph III.B.1.

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2. Post-Closure Cost Adjustments

(a) During the active life of the facility, the facility shall adjust the post- closure cost estimate for inflation within 60 days prior to the anniversary date of the establishment of the financial instrument(s) used to comply with Paragraph II.D.5. If the facility is using the financial test or corporate guarantee, the post-closure cost estimate shall be updated for inflation within 30 days after the close of the firm's fiscal year and before the submission of updated information to the Division Director as specified at Rule 0400-12-01-.06(8)(g)8(v). The adjustment may be made by recalculating the post-closure cost estimate in current dollars or by using an inflation factor derived from the most recent Implicit Price Deflator for Gross National Product published by the U.S. Department of Commerce in its Survey of Current Business, as specified in Parts II.D.2(a)(i) and (ii) below. The inflation factor is the result of dividing the latest published annual Deflator by the Deflator for the previous year.

(i) The first adjustment is made by multiplying the post-closure cost estimate by the inflation factor. The result is the adjusted post- closure cost estimate.

(ii) Subsequent adjustments are made by multiplying the latest adjusted post-closure cost estimate by the latest inflation factor.

(b) During the active life of the facility, the facility shall revise the post- closure cost estimate within 30 days after the Commissioner has approved the request to modify the Post-Closure Plan, if the change in the Post- Closure Plan increases the cost of post-closure care. The revised post- closure cost estimate shall be adjusted for inflation as specified in Subparagraph II.D.2(a).

3. Maintenance of the Post-Closure Cost Estimate: The facility shall keep the following at the facility during the operating life of the facility: the latest post- closure cost estimate prepared in accordance with Paragraph II.D.1 and Subparagraph II.D.2(b), and, when this estimate has been adjusted in accordance with Subparagraph II.D.2(a), the latest adjusted post-closure cost estimate. Such post-closure cost estimates must be itemized and address all post-closure security, inspection, monitoring and maintenance activities.

4. Submission of the Revised Post-Closure Cost Estimate: Within 30 days of the date the post-closure cost estimate is revised, the facility shall submit the latest post-closure cost estimate to the Commissioner.

5. Financial Assurance for Post-Closure: The facility shall file and maintain with the Division Director financial assurance for post-closure of the facility in accordance with the requirements of Rule 0400-12-01-.06(8).

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(a) The facility shall choose from the financial assurance mechanisms as specified in Rule 0400-12-01-.06(8)(g).

(b) The facility shall file and maintain financial assurance in an amount at least equal to the current post-closure cost estimate.

(i) Whenever the current post-closure cost estimate increases to an amount greater than the amount of financial assurance currently filed with the Division Director, the facility shall, within 60 days after the increase, file additional financial assurance at least equal to this increase.

(ii) Whenever the current post-closure cost estimate decreases, and upon the written request of the facility, the Division Director shall, provided he or she validates the decrease, reduce the amount of financial assurance required for the facility to the amount of the current post-closure cost estimate. Upon such occurrence, the Division Director shall, as appropriate considering the financial assurance mechanism(s) on file, either cause to be released to the facility cash or collateral equal to this reduction or allow the facility to substitute for the mechanism(s) on file a new mechanism(s) in the reduced amount.

(iii) Unless the Director approves an alternative amount that is based on a revised cost estimate, financial assurance shall be maintained as an annually inflation-adjusted, 30-year balance.

(c) The financial assurance shall be maintained until the Commissioner releases the facility from the requirements of this Paragraph (II.D.5), as specified in this Subparagraph [II.D.5(c)], or until the Commissioner orders forfeiture of the financial assurance as provided in Subparagraph II.D.5(d) below.

(i) Financial assurance will normally be released in the form(s) it was submitted. However, where such release involves an amount equal to only a portion of the funds assured by a financial assurance mechanism, the Commissioner shall, as appropriate considering the type of mechanism involved, either cause to be released to the facility cash or collateral equal to that amount or allow the facility to substitute for the mechanism on file a new mechanism(s) reduced by that amount.

(d) The Commissioner may order that any financial assurance filed by the facility pursuant to this Paragraph (II.D.5) be forfeited to the State if the Commissioner determines that the facility has failed to perform post-

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closure care in accordance with ATTACHMENT 4, the approved Post- Closure Plan. Any such forfeiture action shall follow the procedures provided in Paragraph II.D.7 below.

6. Alternate Financial Assurance: The facility may substitute alternate financial assurance meeting the requirements of Paragraph II.D.5 above for the financial assurance already filed with the Division Director. However, the existing financial assurance shall not be released by the Commissioner until the substitute financial assurance has been received and approved by him or her.

7. Procedures for Forfeiture of Financial Assurance

(a) Upon his or her determination that the facility has failed to perform post- closure care in accordance with ATTACHMENT 4, the approved Post- Closure Plan when required to do so, the Division Director shall cause a notice of non-compliance to be served upon the facility. Such notice shall be hand delivered or forwarded by certified mail. The notice of noncompliance shall specify in what respects the facility has failed to perform as required, and shall establish a schedule of compliance leading to compliance with the plan and other plan requirements as soon as possible.

(b) If the Division Director determines that the facility has failed to perform as specified in the notice of non-compliance, or as specified in any subsequent compliance agreement that may have been reached by the facility and the Division Director, the Division Director shall cause a notice of show cause meeting to be served upon the facility. Such notice shall be signed by the Division Director and either hand-delivered or forwarded by certified mail to the facility. The notice of show cause meeting shall establish the date, time, and location of a meeting scheduled to provide the facility with the opportunity to show cause why the Division Director should not pursue forfeiture of the financial assurance filed to guarantee such performance.

(c) If no mutual compliance agreement is reached at the show cause meeting, or upon the Division Director's determination that the facility has failed to perform as specified in such agreement that was reached, the Division Director shall request the Commissioner to order forfeiture of the financial assurance filed to guarantee such performance.

(d) The Commissioner shall order forfeiture of the financial assurance upon his or her validation of the Division Director's determinations and upon his or her determination that the procedures of Subparagraphs II.D.7(a), (b) and (c) have been followed. The Commissioner may however, at his or her discretion, provide opportunity for the facility to be heard before issuing such order. Upon issuance, a copy of the order shall be hand delivered or forwarded by certified mail to the facility. Any such order issued by the

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Commissioner shall become effective 30 days after receipt by the facility unless it is appealed to the Board as provided in T.C.A. Section 68-212- 113.

(e) If necessary, upon the effective date of the order of forfeiture, the Commissioner shall give notice to the State Attorney General who shall collect the forfeiture.

(f) All forfeited funds shall be deposited in a special account within the Tennessee Environmental Protection Fund for use by the Commissioner as set forth in T.C.A. Sections 68-212-108(c)(6) and 68-203-101 et seq.

8. Incapacity of the Facility, Guarantors, or Financial Institutions

(a) The facility shall notify the Division Director, by certified mail, of the commencement of a voluntary or involuntary proceeding under Title 11 (Bankruptcy), U.S. Code, naming the facility (owner or operator) as debtor, within 10 days after commencement of the proceeding. A guarantor of a corporate guarantee as specified at Rule 0400-12-01- .06(8)(g)8, shall make such a notification if he is named as debtor, as required under the terms of the corporate guarantee (Rule 0400-12-01- .06(8)(p)8).

(b) The facility who fulfills the requirements of Paragraphs II.D.5 or II.E.2 by obtaining a trust fund, surety bond, letter of credit, or insurance policy will be deemed to be without the required financial assurance in the event of bankruptcy of the trustee or issuing institution, or a suspension or revocation of the authority of the trustee institution to act as trustee or of the institution issuing the surety bond, letter of credit, or insurance policy to issue such instruments. The facility shall establish other financial assurance within 60 days after such an event.

E. FINANCIAL REQUIREMENTS FOR CORRECTIVE ACTION

If the facility is required to implement a corrective action remedy in accordance with Subsection V.I, the facility shall demonstrate continuous compliance with Rules 0400-12- 01-.06(6)(a)1(ii) and .06(6)(l) as follows.

1. Cost Estimate for Corrective Action: Pursuant to the corrective measures study report required by Subsection V.G, the facility shall submit a cost estimate for corrective action following the guidelines provided in ATTACHMENT 6.3, Paragraph V.E.5. The facility shall adjust the cost estimate as part of any modification request for changes to the approved remedy or as required by the Commissioner.

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2. Financial Assurance for Corrective Action

(a) The facility shall file and maintain corrective action financial assurance with the Division Director in an amount at least equal to the current cost estimate for completion of the final remedy for the facility. As specified in Subsection V.I.2, the facility shall provide financial assurance after remedy selection and plan modification. However, the Commissioner may notify and require the facility to provide financial assurance for corrective action at any time during the term of this plan.

(b) The mechanisms and procedures for complying with the corrective action financial assurance requirements shall be in a manner consistent with Rules 0400-12-01-.06(8)(g) through (p). References to regulatory requirements for “closure and/or post-closure care” shall be replaced with the phrase “closure, post-closure care, and/or corrective action” or other language as approved by the Commissioner.

(c) Unless the Director approves an alternative amount that is based on a revised cost estimate, financial assurance shall be maintained as an annually inflation-adjusted, thirty-year rolling balance.

(d) The requirements in Subparagraphs II.D.8(a) and (b), which detail the procedures to follow concerning the financial incapacity of the facility, guarantors, or financial institutions, shall also apply to the corrective action financial assurance.

3. Procedures for Forfeiture of Financial Assurance

(a) Upon his or her determination that the facility has failed to perform corrective action in accordance with ATTACHMENT 6.5, the approved Corrective Action Remedies, when required to do so, the Division Director shall cause a notice of non-compliance to be served upon the facility. Such notice shall be hand delivered or forwarded by certified mail. The notice of non-compliance shall specify in what respects the facility has failed to perform as required, and shall establish a schedule of compliance leading to compliance with the plan and other plan requirements as soon as possible.

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meeting shall establish the date, time, and location of a meeting scheduled to provide the facility with the opportunity to show cause why the Division Director should not pursue forfeiture of the financial assurance filed to guarantee such performance.

(c) If no mutual compliance agreement is reached at the show cause meeting, or upon the Division Director's determination that the facility has failed to perform as specified in such agreement that was reached, the Division Director shall request the Commissioner order forfeiture of the financial assurance filed to guarantee such performance.

(d) The Commissioner shall order forfeiture of the financial assurance upon his or her validation of the Division Director's determinations and upon his or her determination that the procedures of Subparagraphs II.D.3(a), (b) and (c) have been followed. The Commissioner may however, at his or her discretion, provide opportunity for the facility to be heard before issuing such order. Upon issuance, a copy of the order shall be hand delivered or forwarded by certified mail to the facility. Any such order issued by the Commissioner shall become effective 30 days after receipt by the facility unless it is appealed to the Board as provided in T.C.A. Section 68-212- 113.

(e) If necessary, upon the effective date of the order of forfeiture, the Commissioner shall give notice to the State Attorney General who shall collect the forfeiture.

4. Incapacity of the Facility, Guarantors, or Financial Institutions

(a) The facility shall notify the Division Director, by certified mail, of the commencement of a voluntary or involuntary proceeding under Title 11 (Bankruptcy), U.S. Code, naming the facility (owner or operator) as debtor, within ten (10) days after commencement of the proceeding. A guarantor of a corporate guarantee as specified at Rule 0400-12-01- .06(8)(g)8, shall make such a notification if he is named as debtor, as required under the terms of the corporate guarantee (Rule 0400-12-01- .06(8)(p)8).

(b) The facility who fulfills the requirements of Paragraph II.D.2 by obtaining a trust fund, surety bond, letter of credit, or insurance policy will be deemed to be without the required financial assurance in the event of bankruptcy of the trustee or issuing institution, or a suspension or revocation of the authority of the trustee institution to act as trustee or of

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the institution issuing the surety bond, letter of credit, or insurance policy to issue such instruments. The facility shall establish other financial assurance within 60 days after such an event.

F. RECORDKEEPING AND REPORTING

1. Operating Record: The facility shall keep a written operating record at the facility throughout the post-closure care and corrective action periods as follows:

(a) Records and results of inspections required by Paragraph II.B.3, except these data need to be kept only three years;

(b) Monitoring, testing or analytical data, and corrective action work plans and reports where required by SECTION IV, SPECIFIC CONDITIONS FOR GROUNDWATER MONITORING, and SECTION V, SPECIFIC CONDITIONS FOR CORRECTIVE ACTION; and

2. Annual Report: The facility shall prepare and submit a single copy of an annual report to the Commissioner by March 1 of each year.

(a) Annual reports shall be submitted on forms provided by the Department and in accordance with the instructions accompanying the form. However, no forms are provided by the Department for groundwater information.

(b) The annual report shall cover facility activities during the previous calendar year and shall include the following information:

(i) The EPA identification number, name, and address of the facility;

(ii) The calendar year covered by the report;

(iii) The groundwater monitoring results, inclusive of the analytical results and any statistical analyses, as specified in SECTION IV, SPECIFIC CONDITIONS FOR GROUNDWATER MONITORING;

(iv) The most recent post-closure cost estimate; and

(v) The certification signed by the facility or his authorized representative.

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G. LAND DISPOSAL RESTRICTIONS

1. Rule 0400-12-01-.10 identifies hazardous wastes that are prohibited from land disposal and defines those limited circumstances under which an otherwise prohibited waste may continue to be placed in a land treatment, storage or disposal unit. The facility shall comply with all applicable requirements of Rule 0400-12-01-.10. Where the facility has applied for an extension, waiver or variance under Rule 0400-12-01-.10, the facility shall comply with all applicable restrictions of Rule 0400-12-01-.10 pending final approval of such application.

2. A restricted waste identified in Rule 0400-12-01-.10(2) may not be placed in a land disposal unit without further treatment unless the requirements of Rule 0400-12-01- .10(2) and/or Rule 0400-12-01-.10(3) are met.

3. The storage of hazardous waste restricted from land disposal under Rule 0400-12- 01-.10 is prohibited unless the requirements of Rule 0400-12-01-.10(4) are met.

H. ORGANIC AIR EMISSION STANDARDS

Prior to constructing or installing any equipment with process vents subject to the requirements of Rule 0400-12-01-.06(30) or installing any additional equipment subject to the requirements of Rule 0400-12-01-.06(31) or units subject to Rule 0400-12-01- .06(32), the facility shall supply the specific Part B Application information required pursuant to Rules 0400-12-01-.07(5)(b)10, 11, and 13, as applicable, and shall obtain a plan modification in accordance with the requirements of Rule 0400-12-01-.07(9).

I. RESTRICTION ON OWNERSHIP OF THE FACILITY

No person who has been convicted of any felony or has been convicted of a misdemeanor for the unlawful storage, treatment, or disposal of hazardous waste may, at any time, be the legal or beneficial owner of ten percent (10%) or more of the stock of the facility.

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EPA ID Number: TND054876834 Plan Number: TNHW-183

III. SPECIFIC CONDITIONS FOR POST-CLOSURE CARE

A. UNIT IDENTIFICATION

Located in ATTACHMENT 4 is ATTACHMENT 4.1, Post-Closure Plan, which details the waste in the unit and provides details of the closure of the landfill under Tankfarm #1 (TF- 1). In ATTACHMENT 4.1 is Figure 1, the Site Layout Map and Figure 2, the Monitoring Well Location Map. Also located in ATTACHMENT 4, is ATTACHMENT 4.2, Land Use Restrictions.

B. POST-CLOSURE CARE

As specified in this section and in ATTACHMENT 4, the facility shall provide post-closure care for the landfill. Additionally, the facility shall comply with the groundwater monitoring requirements as described in Section IV, SPECIFIC CONDITIONS FOR GROUNDWATER MONITORING and ATTACHMENT 5.

C. POST-CLOSURE CARE AND USE OF PROPERTY

As specified in this subsection, the facility shall provide post-closure care for the HWMU, which includes requirements for groundwater monitoring.

1. Rule 0400-12-01-.06(7)(h)1(i) requires the facility to perform post-closure care for 30 years after the date of certification of closure of the landfill. However, pursuant to Rule 0400-12-01-.06(7)(h)1(ii)(II), the Commissioner may extend the post-closure care period, if he finds that the extended period is necessary to protect human health and the environment. The Commissioner has extended the post-closure care period for the landfill as long as a potential for threat to human health by exposure to contaminants exists at the site. In accordance with Subsection II.D, the facility will maintain 30 years of financial assurance for the post-closure care period.

Pursuant to Rule 0400-12-01-.06(7)(h)1(ii)(I), upon application and demonstration by the facility that a reduced post-closure care period is sufficiently protective of human health and the environment, the Commissioner may shorten the assigned perpetual post-closure care period. Any change to the post-closure period will require a plan modification in accordance with Rule 0400-12-01- .07(9).

2. The facility shall comply with all the maintenance requirements as specified in ATTACHMENT 4, and as follows:

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(a) Maintain the integrity and effectiveness of the final cover, including making repairs to the cap, as necessary, to correct the effects of settling, subsidence, cracking, etc.

(b) Prevent run-on and run-off from eroding or otherwise damaging the final cover and the soil areas at the perimeter.

3. The facility shall comply with all security requirements as specified in Subsection II.A and ATTACHMENT 2, SECURITY.

D. INSPECTIONS

The facility shall comply with all inspection requirements as specified in Subsection II.B and ATTACHMENT 3, INSPECTIONS.

E. POST-CLOSURE PLAN MODIFICATIONS

1. In accordance with the applicable requirements of Rule 0400-12-01-.07(9), the facility must request a plan modification to authorize a change in the approved Post- Closure Care Plan. The written request must include four hard copies and one electronic copy of the amended Post-Closure Care Plan for approval by the Commissioner.

2. The facility must submit a written request for a plan modification at least 60 days prior to the proposed change in unit design or operation or no later than 60 days after an unexpected event has occurred which has affected the Post-Closure Care Plan.

F. NOTICES AND CERTIFICATIONS

1. Copies of the Certification of Closure, the Notice of Hazardous Waste Management Unit and the Certification of Filing Deed Notification shall be maintained in the facility operating record. A copy of the recorded deed restriction is included as Figure 4-2, Land Use Restrictions, in ATTACHMENT 4, POST-CLOSURE CARE PLAN.

2. No later than 60 days after completion of the post-closure care period, the owner must submit to the Commissioner, by registered mail, at least four copies of a certification that the post-closure care period was performed in accordance with the specifications in ATTACHMENT 4. The certification must be signed by the owner or operator and a qualified Professional Engineer. Until released from the financial assurance requirements for post-closure care under Rule 0400-12-01-.06(8)(f)4, the owner or operator must furnish documentation supporting the qualified Professional Engineer’s certification to the Commissioner upon request.

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EPA ID Number: TND054876834 Plan Number: TNHW-183

IV. SPECIFIC CONDITIONS FOR GROUNDWATER MONITORING

The facility shall maintain a groundwater monitoring system, perform sampling and analysis, and evaluate the groundwater analytical data as specified in this section and ATTACHMENT 5.

A. MAINTENANCE OF GROUNDWATER MONITORING SYSTEMS

1. As specified in this subsection and the monitoring well construction details in Figure 5-4, Monitoring Well Construction diagram, of ATTACHMENT 5, the facility shall maintain a groundwater monitoring system of four monitoring wells, MW-1, MW-2, MW-3, and MW-4a which complies with the requirements of this section, ATTACHMENT 5, GROUNDWATER MONITORING, and Rule 0400- 12-01-.06(6)(h). The well locations and the post-closure unit it monitors are depicted on Figure 1-2, Site Plan, in ATTACHMENT 1, FACILITY DESCRIPTION.

2. To ensure monitoring well integrity and security, and to verify that all the monitoring wells identified in Paragraph IV.A.1 are maintained in good condition, the facility shall perform inspections of the wells at least annually. The facility shall complete and sign the Inspection Log for Tank Farm #1 (TF-1) and AOC A, Figure 3-2, ATTACHMENT 3 at the time of the inspection.

3. At such time that closure is necessary, the facility shall close the wells that are identified in Paragraph IV.A.1 in accordance with ATTACHMENT 7, METHODOLOGY FOR MONITORING WELL ABANDONMENT AND CLOSURE; or the well decommissioning procedures detailed in the most recent version of the EPA, Region 4, Science and Ecosystem Support Division’s (SESD) Field Branches Quality System and Technical Procedures; or other equivalent method that has been approved by the Commissioner.

The method chosen for well decommissioning (abandonment) must be protective of human health and the environment and in compliance of state and local requirements. The Commissioner shall be notified, in writing, 30 calendar days prior to implementing well closure procedures. No well shall be closed unless prior written approval is granted. The facility shall submit written certification of the completion of closure action to the Commissioner within 30 days of completing the abandonment procedures.

B. ELEVATION OF THE GROUNDWATER SURFACE

Prior to sampling/evacuating the wells identified in Paragraph IV.A.1, the facility shall measure the depth to the static water level and determine the groundwater surface elevation

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each time the monitoring wells are sampled per Subsection IV.C. The depth to the static water level in these wells will be measured using the procedures described in ATTACHMENT 5, GROUNDWATER MONITORING, or a technically equivalent procedure that meets the applicable requirements specified in the most recent version of the USEPA, Region 4, SESD’s Field Branches Quality System and Technical Procedures.

The water depth information shall be recorded on the Groundwater Monitoring Sample Field Log form found in ATTACHMENT 5.

C. SAMPLING PROCEDURES

The facility shall sample the groundwater monitoring locations listed in ATTACHMENT 1, Figure 1-2, Site Plan, by using the procedures referenced below, or other technically equivalent procedures that meet the applicable requirements specified in the most recent version of the EPA Region 4’s Field Branches Quality System and Technical Procedures.

1. Samples shall be collected on an annual basis using the techniques and procedures described in ATTACHMENT 5. Samples will be collected for the parameter in ATTACHMENT 5, Figure 5-6, Groundwater Protection Standard.

2. All samples shall be preserved using the techniques, procedures, type and size of containers for each parameter as described in ATTACHMENT 5.

3. All samples shall be prepared, labeled, sealed and shipped to the laboratory using the techniques and procedures described in ATTACHMENT 5, and sample container label in Figure 5-2.

4. Samples shall be tracked and controlled using the chain-of-custody procedures described in ATTACHMENT 5. To verify that sample integrity was maintained throughout the field collection and shipping process, the facility shall complete and sign a Chain-of-Custody Worksheet in Figure 5-3.

D. ANALYTICAL PROCEDURES

The hazardous constituent that requires groundwater monitoring by the facility is listed in ATTACHMENT 5, Figure 5-6, Groundwater Protection Standard. To ensure that quality data is acquired from chemical analyses of the samples collected in accordance with Subsection IV.D, laboratory handling and analyses of those samples shall comply with the following laboratory procedures.

1. The laboratory shall analyze the samples using the methods specified in the most recent edition of Test Methods for Evaluating Solid Waste: Physical/Chemical Methods, SW-846. The applicable methods at the time of plan issuance are listed in ATTACHMENT 5.

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2. Analysis of groundwater samples shall comply with the method practical quantification limits as listed in ATTACHMENT 5.

E. GROUNDWATER PROTECTION STANDARD

1. The facility shall monitor the point of compliance (POC) wells in accordance with subsection IV.A, Sampling Procedures and IV.B, Analytical procedures and shall maintain those records and submit reports in accordance with subsection IV.F, Reporting, Recordkeeping and Response.

2. A list of the hazardous constituents that require monitoring by the facility, including their groundwater concentration limits at the point of compliance, is provided in ATTACHMENT 5.

F. DETECTION MONITORING DATA EVALUATION AND RESPONSE

The facility shall compare the concentration of the hazardous constituent in each point of compliance groundwater monitoring well to the groundwater protection standard for the hazardous constituent listed in Attachment 5. If no analyte in a groundwater sample collected from any well is above the Groundwater Protection Standard, no statistical analysis will be completed. If a sample from a well is determined to contain an analyte at a concentration exceeding the Groundwater Protection Standard, the facility shall resample and analyze that well for the constituent in ATTACHMENT 5.

If the concentration exceeds the groundwater protection standard for the hazardous constituent in any monitoring well, the facility shall resample the affected well(s), collecting three samples per week for four weeks.

Within 75 days after the last groundwater sample is collected, the facility shall calculate the mean (x), the standard deviation (S), and the 99% lower confidence limit (LCL) for each exceeding hazardous constituent as per EPA guidance EPA 530/R-09-007, “Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities-Unified Guidance,” March 2009.

In calculating the mean, standard deviation, and lower confidence, the facility shall substitute one-half the Practical Quantification Limit (PQL) for a hazardous constituent reported by the laboratory for any hazardous constituent measurement reported as below detection limit or not detected.

The facility shall compare the lower confidence limit for each exceeding hazardous constituent to the groundwater protection standard in ATTACHMENT 5. If the lower confidence limit exceeds the groundwater protection standard, the facility must:

1. Notify the Division Director of this finding in writing within seven days. The notification must include the analytical data, the statistical evaluation, and other information from the samplings, including the concentration limit exceeded;

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2. Immediately sample the groundwater in all monitoring wells and determine whether constituents in the list of Appendix IX, Rule 0400-12-01-.06(57)(i), are present, and if so, in what concentration. However, the Commissioner, on a discretionary basis, may allow sampling for a site-specific subset of constituents from the Appendix IX list and other representative/related waste constituents;

3. For any Appendix IX compounds found in the analysis pursuant to Paragraph IV.B, the owner or operator may resample within one month or at an alternative site-specific schedule approved by the Commissioner and repeat the analysis for those compounds detected. If the results of the second analysis confirm the initial results, then these constituents will form the basis for compliance monitoring. If the owner or operator does not resample for the compounds in Paragraph IV.B, the hazardous constituents found during this initial appendix IX analysis will form the basis for compliance monitoring;

4. Within 90 days, submit to the Division Director an application for a plan modification to establish a compliance monitoring program meeting the requirements of Rule 0400-12-01-.06(6)(j). The application must include the following information:

(a) An identification of the concentration of any Appendix IX constituent detected in the ground water at each monitoring well at the compliance point;

(b) Any proposed changes to the groundwater monitoring system at the facility necessary to meet the requirements of Rule 0400-12-01-.06(6)(j);

(c) Any proposed additions or changes to the monitoring frequency, sampling and analysis procedures or methods, or statistical methods used at the facility necessary to meet the requirements of Rule 0400-12-01-.06(6)(j);

(d) For each hazardous constituent detected at the compliance point, a proposed concentration limit under Rule 0400-12-01-.06(6)(e)1(i) or (ii), or a notice of intent to seek an alternate concentration limit under Rule 0400-12-01-.06(6)(e)2; and (e) 5 Within 180 days, submit to the Division Director:

(a) All data necessary to justify an alternate concentration limit sought under Rule 0400-12-01-.06(6)(e)2; and

(b) An engineering feasibility plan for a corrective action program necessary to meet the requirement of Rule 0400-12-01-.06(6)(k), unless:

(i) All hazardous constituents identified under Paragraph IV.B.2 are listed in Table 1 of Rule 0400-12-01-.06(6)(e) and their

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concentrations do not exceed the respective values given in that table; or

(ii) The owner or operator has sought an alternate concentration limit under Rule 0400-12-01-.06(6)(e)2 for every hazardous constituent identified under Paragraph IV.B.

6. Pursuant to this subsection, if the facility determines that there is an exceedance of the groundwater protection standard at any monitoring well at the compliance point, the facility may demonstrate that a source other than a regulated unit caused the contamination or that the detection is an artifact caused by an error in sampling, analysis, or statistical evaluation or natural variation in the ground water. The facility may make a demonstration under this paragraph in addition to, or in lieu of, submitting a plan modification application under Paragraph IV.E.4; however, the facility is not relieved of the requirement to submit a plan modification application within the time specified in Paragraph IV.E.4 unless the demonstration made under this paragraph successfully shows that a source other than a regulated unit caused the increase, or that the increase resulted from error in sampling, analysis, or evaluation. In making a demonstration under this paragraph, the owner or operator must:

(a) Notify the Division Director in writing within seven days of determining that there is an exceedance of the groundwater protection standard at the compliance point that he intends to make a demonstration under this paragraph;

(b) Within 90 days, submit a report to the Division Director which demonstrates that a source other than a regulated unit caused the contamination or that the contamination resulted from error in sampling, analysis, or evaluation;

(c) Within 90 days, submit to the Division Director an application for a plan modification to make any appropriate changes to the detection monitoring program at the facility; and

(d) Continue to monitor in accordance with the detection monitoring program established under this section.

G. REPORTING, RECORDKEEPING AND RESPONSE

1. All information and data obtained pursuant to this section shall be maintained in the facility’s operating record as required by Rule 0400-12-01-.06(5)(d)2(vi).

2. The facility shall submit to the Director, by March 1 of the following year, all monitoring, sampling, testing, analytical data, and data evaluation obtained pursuant to this section.

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3. If after the resampling and analysis per Subsection IV.E, the concentration of any analyte is still above the Groundwater Protection Standard listed in ATTACHMENT 5, the facility shall notify the Division Director of this finding in writing within seven days and comply with all the other requirements as specified in plan Subsection IV.E.

H. ASSURANCE OF COMPLIANCE

The Facility shall assure the Commissioner that groundwater monitoring necessary to achieve compliance with the groundwater protection standard are taken during the term of the plan. If the facility determines that the groundwater monitoring in this plan no longer satisfies the requirements of Rule 0400-12-01-.06(6)(k), he shall, within 90 days, submit an application for a plan modification to make any appropriate changes to the program which will satisfy Rule 0400-12-01-.06(6).

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EPA ID Number: TND054876834 Plan Number: TNHW-183

V. SPECIFIC CONDITIONS FOR CORRECTIVE ACTION

A. APPLICABILITY

The conditions of this section apply to:

1. The solid waste management units (SWMUs) and areas of concern (AOCs) identified in ATTACHMENT 6.1, Table 6.1-1, which require no further action under the corrective action conditions of this plan at this time;

2. The SWMUs and AOCs identified in ATTACHMENT 6.1, Table 6.1-2, which require confirmatory sampling;

3. The SWMUs and AOCs identified in ATTACHMENT 6.1, Table 6.1-3, which require a RCRA Facility Investigation;

4. The SWMUs and AOCs identified in ATTACHMENT 6.1, Table 6.1-4, which require interim measures;

5. The SWMUs and AOCs identified in ATTACHMENT 6.1, Table 6.1-5, which require a corrective measures study;

6. The SWMUs and AOCs identified in ATTACHMENT 6.1, Table 6.1-6, which require implementation of the corrective action remedy;

7. The SWMUs and AOCs identified in ATTACHMENT 6.1, Table 6.1-7, which are being addressed under another program;

8. Any additional SWMUs or AOCs discovered during the course of groundwater monitoring, field investigations, environmental audits, or other means. As used in this section of the plan, the terms "discover,” “discovery,” or “discovered" refer to the date on which the facility either, (1) visually observes evidence of a new SWMU or AOC, (2) visually observes evidence of a previously unidentified release of hazardous constituents to the environment, or (3) receives information which suggests the presence of a new release of hazardous waste or hazardous constituents to the environment; and

9. Contamination that has migrated and/or is migrating beyond the facility boundary. The facility shall implement corrective actions beyond the facility boundary where necessary to protect human health and the environment, unless the facility demonstrates to the satisfaction of the Commissioner that, despite the facility's best efforts, as determined by the Commissioner, the facility was unable to obtain

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the necessary permission to undertake such actions. The facility is not relieved of all responsibility to clean up a release that has migrated beyond the facility boundary where off-site access is denied. On-site measures to address such releases will be determined on a case-by-case basis. Assurances of financial responsibility for completion of such off-site corrective action will be required.

B. NOTIFICATION AND ASSESSMENT REQUIREMENTS FOR NEWLY IDENTIFIED SWMUs AND AOCs

1. The facility shall notify the Commissioner in writing, within 15 calendar days of discovery, of any suspected new AOC as discovered under Paragraph IV.A.8. The notification shall include, at a minimum, the location of the AOC and all available information pertaining to the nature of the release (e.g., media affected, hazardous constituents released, magnitude of release, etc.). The Commissioner may conduct, or require the facility to conduct, further assessment (i.e., confirmatory sampling) in order to determine the status of the suspected AOC. The Commissioner will notify the facility in writing of the final determination as to the status of the suspected AOC. If the Commissioner determines that further investigation or other corrective action of an AOC is required, the fscility shall modify the plan in accordance with Rule 0400-12-01-.07(9).

2. The facility shall notify the Commissioner in writing, within 15 calendar days of discovery, of any additional SWMU as discovered under Paragraph IV.A.8.

3. The facility shall prepare and submit to the Commissioner, within 90 calendar days of notification, a SWMU Assessment Report (SAR) for each SWMU identified under Paragraph IV.B.2. At a minimum, the SAR shall provide the following information:

(a) Location of unit(s) on a topographic map of appropriate scale such as required under Rule 0400-12-01-.07(5)(a)1(xix);

(b) Designation of type and function of unit(s);

(d) Dates that the unit(s) was operated;

(e) Specification of all wastes that have been managed at/in the unit(s) to the extent available. Include any available data on hazardous constituents in the wastes; and

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(f) All available information pertaining to any release of hazardous waste or hazardous constituents from such unit(s) with any available information and analytical results for air, soil, sediment, surface water and groundwater.

4. Based on the results of the SAR, the Commissioner shall determine the need for further investigations at the SWMUs covered in the SAR. If the Commissioner determines that such investigations are needed, the facility shall be required to prepare a plan for such investigations as outlined in Subparagraph IV.D.1 or Paragraph IV.E.1(a).

C. NOTIFICATION REQUIREMENTS FOR NEWLY DISCOVERED RELEASES FROM SWMUs OR AOCs

1. The facility shall notify the Commissioner, in writing, of any newly discovered release(s) of hazardous waste or hazardous constituents discovered during the course of groundwater monitoring, field investigations, environmental audits, or other means, within 15 calendar days of discovery. Such newly discovered releases may be from SWMUs or AOCs identified in Paragraph V.A.1 or SWMUs or AOCs identified in Paragraph V.A.8 for which further investigation under Paragraph V.B.4 was not required.

2. If the Commissioner determines that further investigation of the SWMUs or AOCs is needed, the facility shall be required to prepare a plan for such investigations as outlined in Subparagraph V.E.1(a).

D. CONFIRMATORY SAMPLING (CS)

1. Upon notification by the Commissioner, the facility shall prepare and submit a Confirmatory Sampling (CS) Work Plan for suspected AOCs per Paragraph V.B.1 or newly identified SWMUs per Paragraph V.B.4. The work plan shall be submitted within 45 calendar days of notification by the Commissioner that a CS Work Plan is required. The CS Work Plan shall include schedules of implementation and completion of specific actions necessary to determine whether a release has occurred. It should also address applicable requirements and affected media. In order to partly or wholly satisfy the CS requirement, previously existing data may be submitted with the work plan for the Commissioner's consideration.

2. The CS Work Plan must be approved by the Commissioner, in writing, prior to implementation. The Commissioner shall specify the start date of the CS Work Plan schedule in the letter approving the CS Work Plan. If the Commissioner disapproves the CS Work Plan, the Commissioner shall (1) notify the facility in writing of the CS Work Plan's deficiencies and specify a due date for submission of a revised CS Work Plan, (2) revise the CS Work Plan and notify the facility of the revisions, or (3) conditionally approve the CS Work Plan and notify the facility of the amended conditions.

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3. The facility shall implement the confirmatory sampling in accordance with the approved CS Work Plan.

4. The facility shall prepare and submit to the Commissioner in accordance with the schedule in the approved CS Work Plan, a CS Report identifying all SWMUs or AOCs that have released hazardous waste or hazardous constituents into the environment. The CS Report shall include all data, including raw data and a summary and analysis of the data, which supports the above determination. If submission of the CS Report coincides with submission of the RFI Report, then the CS Report and the RFI Report may be combined into one submission.

5. Based on the results of the CS Report, the Commissioner shall determine the need for further investigations at the SWMUs or AOCs covered in the CS Report. If the Commissioner determines that such investigations are needed, the facility shall be required to prepare a plan for such investigations as outlined in Subparagraph V.E.1(a). The Commissioner will notify the facility of any no further action decision.

E. RCRA FACILITY INVESTIGATION (RFI)

1. RFI Work Plan(s)

(a) The facility shall prepare and submit to the Commissioner, within 90 calendar days of notification by the Commissioner, an RFI Work Plan for those units identified under Paragraph V.B.4, Paragraph V.C.2, or Paragraph V.D.5. The RFI Work Plan(s) shall be developed to meet the requirements of Subparagraph V.E.1(b).

(b) The RFI Work Plan(s) shall meet the requirements specified in ATTACHMENT 6.2, unless otherwise directed by the Commissioner. The RFI Work Plan(s) shall include schedules of implementation and completion of specific actions necessary to determine the nature and extent of contamination and the potential pathways of contaminant releases to the air, soil, surface water, and groundwater. The facility must provide sufficient justification and associated documentation that a release is not probable or has already been characterized if a unit or a media/pathway associated with a unit (groundwater, surface water, soil, subsurface gas, or air) is not included in the RFI Work Plan(s). Such deletions of a unit, media or pathway from the RFI(s) are subject to the review by the Commissioner. The facility shall provide sufficient written justification for any omissions or deviations from the minimum requirements of ATTACHMENT 6.2. Such omissions or deviations are subject to the approval of the Commissioner. In addition, the scope of the RFI Work Plan(s) shall include all investigations necessary to ensure compliance with Rule 0400-12-01-.06(6)(l)3.

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(c) The RFI Work Plan(s) must be approved by the Commissioner, in writing, prior to implementation. The Commissioner shall specify the start date of the RFI Work Plan schedule in the letter approving the RFI Work Plan(s). If the Commissioner disapproves the RFI Work Plan(s), the Commissioner shall either (1) notify the facility in writing of the RFI Work Plan's deficiencies and specify a due date for submission of a revised RFI Work Plan, (2) revise the RFI Work Plan and notify the facility of the revisions and the start date of the schedule within the approved RFI Work Plan, or (3) conditionally approve the RFI Work Plan and notify the facility of the conditions.

2. RFI Implementation

The facility shall implement the RFI(s), as outlined in ATTACHMENT 6.2, in accordance with the approved RFI Work Plan(s). The facility shall notify the Commissioner at least 20 days prior to any sampling activity.

3. RFI Reports

(a) The facility shall prepare and submit to the Commissioner Draft and Final RFI Report(s) for the investigations conducted pursuant to the RFI Work Plan(s) submitted under Paragraph V.E.1. The Draft RFI Report(s) shall be submitted to the Commissioner for review in accordance with the schedule in the approved RFI Work Plan(s). The Final RFI Report(s) shall be submitted to the Commissioner within 30 calendar days of receipt of the Commissioner's final comments on the Draft RFI Report. The RFI Report(s) shall include an analysis and summary of all required investigations of SWMUs and AOCs and their results. The summary shall describe the type and extent of contamination at the facility, including sources and migration pathways, identify all hazardous constituents present in all media, and describe the actual or potential receptors. The RFI Report(s) shall also describe the extent of contamination (qualitative/quantitative) in relation to background levels indicative of the area. If the RFI Report is a summary of only the initial phase investigatory work or based on current investigations and further investigation is necessary, then an Interim RFI Report summarizing the initial phase investigation shall be submitted incorporating a work plan for the final phase investigatory actions required based on the initial findings. The report shall include a work plan for the final phase investigatory actions required based on the initial findings. Approval of the final phase work plan shall be carried out in accordance with Subparagraph V.E.1(c). The objective of this task shall be to ensure that the investigation data are sufficient in quality (e.g., quality assurance procedures have been followed) and quantity to describe the nature and extent of contamination, potential threat to human health and/or the environment, and to support a Corrective Measures Study, if necessary.

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(b) The facility shall submit to the Commissioner, along with the Interim and Final RFI Report(s), Screening Levels based on the latest EPA guidance or as otherwise directed by the Commissioner for each of the Hazardous Constituents reported in Subparagraph V.E.3(a).

(c) The Commissioner will review the RFI Report(s), including the screening levels described in Subparagraph V.E.3(b). The Commissioner shall notify the facility of the need for further investigative action if necessary and, if appropriate at this moment of the investigation, inform the facility, if not already notified, of the need for a Corrective Measures Study to meet the requirements of Subsection V.G and Rule 0400-12-01-.06(6)(l). The Commissioner will notify the facility of any no further action decision. Any further investigative action required by the Commissioner shall be prepared and submitted in accordance with a schedule specified by the Commissioner and approved in accordance with Subparagraph V.E.1(c).

(d) If the time required to conduct the RFI(s) is greater than 180 calendar days, the facility shall provide the Commissioner with quarterly RFI Progress Reports (90-day intervals) beginning 90 calendar days from the start date specified by the Commissioner in the RFI Work Plan approval letter. The RFI Progress Reports shall contain the following information at a minimum:

(i) A description of the portion of the RFI completed;

(ii) Summaries of findings;

(iii) Summaries of any deviations from the approved RFI Work Plan during the reporting period;

(iv) Summaries of any significant contacts with local community public interest groups or State government;

(v) Summaries of any problems or potential problems encountered during the reporting period;

(vi) Actions taken to rectify problems;

(vii) Changes in relevant personnel;

(viii) Projected work for the next reporting period; and

(ix) Copies of daily reports, inspection reports, data, etc.

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F. INTERIM MEASURES (IM)

1. IM Work Plan

(a) The Commissioner may require Interim Measures (IMs) if they are necessary to protect human health and the environment (considering specific site conditions and Tennessee Regulations).

Upon notification by the Commissioner, the facility shall prepare and submit an IM Work Plan for any SWMU or AOC for which the Commissioner determines the IM is necessary. IMs are necessary in order to minimize or prevent the further migration of contaminants and to limit actual or potential human and environmental exposure to contaminants while long-term corrective action remedies are evaluated and, if necessary, implemented. The IM Work Plan shall be submitted within 30 calendar days of such notification and shall include the elements listed in Subparagraph V.F.1(c). Such interim measures may be conducted concurrently with investigations required under the terms of this plan. Units having an approved IM Work Plan shall comply with Paragraph V.F.2 and beyond to govern implementation of the IM requirements for the unit(s).

(b) The facility may initiate an IM at a SWMU or AOC by submitting the appropriate notification pursuant to Subparagraph I.D.11(a). The Commissioner will process facility-initiated an IM by either conditionally approving the IM or imposing an IM Work Plan per Subparagraph V.F.1(a). Facility-initiated IM shall be considered conditionally approved unless the Commissioner specifically imposes an IM Work Plan within 30 calendar days of receipt of notification of the facility-initiated IM. The scope and success of facility-initiated IM conditionally approved per Subparagraph V.F.1(b) shall be subject to subsequent in-depth review by the Commissioner. The Commissioner will either comment on or approve the facility-initiated IM. Facility-initiated IM must follow the progress and final reporting requirements in Paragraph V.F.3.

(c) The IM Work Plan shall ensure that the interim measures are designed to mitigate any current or potential threat(s) to human health or the environment and are consistent with and integrated into any long-term solution at the facility. The IM Work Plan shall include: the interim measures objectives, procedures for implementation (including any designs, plans, or specifications), and schedules for implementation.

(d) The IM Work Plan imposed under Subparagraph V.F.1(a) must be approved by the Commissioner, in writing, prior to implementation. The Commissioner shall specify the start date of the IM Work Plan schedule in the letter approving the IM Work Plan. If the Commissioner disapproves the IM Work Plan, the Commissioner shall either (1) notify the facility in

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writing of the IM Work Plan's deficiencies and specify a due date for submission of a revised IM Work Plan, (2) revise the IM Work Plan and notify the facility of the revisions and the start date of the schedule within the approved IM Work Plan, or (3) conditionally approve the IM Work Plan and notify the facility of the amended conditions.

2. IM Implementation

(a) The facility shall implement interim measures imposed under Subparagraph V.F.1(a) in accordance with the approved IM Work Plan.

(b) The facility shall give notice to the Commissioner as soon as possible of any planned changes, reductions, or additions to the IM Work Plan imposed under Subparagraph V.F.1(a) or initiated by the facility under Subparagraph V.F.1(b).

(c) Final approval of corrective action required under Rule 0400-12-01- .06(6)(l), which is achieved through IMs, shall be in accordance with Rule 0400-12-01-.07(9)(c)5(iii) and Subsection V.H as a plan modification.

3. IM Reports

(a) If the time required for completion of interim measures imposed under Subparagraph V.F.1(a) or implemented under Subparagraph V.F.1(b) is greater than one year, the facility shall provide the Commissioner with progress reports at the intervals specified in the approved Work Plan or semi-annually for facility-initiated interim measures. The IM Progress Reports shall contain the following information at a minimum:

(i) A description of the portion of the interim measures completed;

(ii) Summaries of findings;

(iii) Summaries of any deviations from the IM Work Plan during the reporting period;

(iv) Summaries of any problems or potential problems encountered during the reporting period; and

(v) Projected work for the next reporting period.

(b) The facility shall prepare and submit an Interim Measures (IM) Report to the Commissioner, within 90 calendar days of completion of interim measures conducted under Subsection V.F. The IM Report shall contain the following information at a minimum:

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(i) A description of interim measures implemented;

(ii) Summaries of results;

(iii) Summaries of all problems encountered;

(iv) Summaries of accomplishments and/or effectiveness of interim measures; and

(v) Copies of all relevant laboratory/monitoring data, etc. in accordance with Paragraph I.D.9.

G. CORRECTIVE MEASURES STUDIES (CMS)

1. The facility shall prepare and submit to the Commissioner a CMS for those SWMUs and AOCs where hazardous constituents exist at concentrations exceeding those appropriate for the protection of human health and the environment. The CMS shall be developed to meet the requirements of Paragraph V.G.2. The facility may seek approval from the Commissioner for concurrent RFI/CMS. The CMS may be performed concurrent with the RFI process if the Commissioner determines that sufficient investigative details are available to allow concurrent action.

2. The CMS shall meet the requirements of ATTACHMENT 6.3 of this plan at a minimum. The CMS shall include schedules of implementation and the completion of specific actions necessary to complete a CMS. The facility must provide sufficient justification and/or documentation for any unit deleted from the CMS. Such deletion of a unit is subject to the approval of the Commissioner. The scope of the CMS shall include all investigations necessary to ensure compliance with the Act and Rules 0400-12-01-.06(6)(l), .06(22)(c), and .07(8)(b)2(ii). The facility shall implement corrective actions beyond the facility boundary, as set forth in Paragraph V.A.9.

3. The facility shall submit the draft CMS no later than 90 calendar days of notification by the Commissioner that a CMS is required.

4. The Commissioner shall either approve or disapprove, in writing, the CMS. If the Commissioner disapproves the CMS, the Commissioner shall (1) notify the facility in writing of the CMS’s deficiencies and specify a due date for submission of a revised CMS, or (2) revise the CMS and notify the facility of the revisions, or (3) conditionally approve the CMS and notify the facility of the amended conditions. This modified CMS becomes the approved CMS.

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H. REMEDY APPROVAL AND PLAN MODIFICATION

1. A remedy decision shall be selected from the remedial alternatives evaluated in the CMS. It will be based at a minimum on protection of human health and the environment, as per specific site conditions and existing regulations and reflected in a statement of basis. The selected remedy may include any IM implemented to date.

2. Pursuant to 0400-12-01-.07(9)(c), a plan modification will be initiated by the Commissioner after recommendation of a remedy under Paragraph V.H.1. As part of the public notification during the modification process, all relevant supporting documentation for the proposed remedy, including the statement of basis, will be made available for public review and comment. The statement of basis will be prepared utilizing EPA’s “Guidance on RCRA Corrective Action Decision Documents” (EPA/540/G-91/011) as a reference. This modification will serve to incorporate a final remedy, including a CAMU if necessary, and CMS remedy implementation schedules into this plan. The plan modification shall include a schedule and date for remedy construction.

3. Following the public comment period, the Commissioner may approve the CMS and select a final corrective measure(s) or require the facility to revise the CMS and/or perform an additional CMS.

4. The Commissioner will notify the facility of the final corrective measure(s) selected by the Department in the Final Decision and Response to Comments. The notification will include the Commissioner’s reasons for selecting the corrective measure(s).

5. Upon the effective date of the plan modification approving the selected remedy, the facility shall implement the approved remedy per the CMS remedy implementation schedule. The facility shall submit Corrective Measures Implementation and Effectiveness Reports to the Commissioner annually.

I. REMEDY IMPLEMENTATION

1. The facility shall implement a corrective action remedy for the SWMUs and AOCs identified in ATTACHMENT 6.1, Table 6.1-6, in accordance with the requirements and schedules in ATTACHMENT 6.5, Corrective Action Remedies,

2. Within 60 calendar days of the effective date of this plan or plan modification for remedy approval in accordance with Subsection V.H., the facility shall demonstrate financial assurance for completing the corrective action remedies as described in ATTACHMENT 6-5. The facility shall provide the assurance in accordance with Paragraph II.D.2.

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J. INSTITUTIONAL CONTROLS (ICs)

1. The facility must consider institutional or other appropriate non-engineering controls for protection of human health and the environment from contamination left in place at any SWMU or AOC. Among the institutional controls (ICs) to be considered is a “Notice of Land Use Restriction” pursuant to T.C.A. 68-212-225.

2. ICs may be used to protect the corrective measures implemented at the facility if this plan is terminated at the completion of corrective action. ICs should be implemented prior to termination of this plan.

3. ICs that are approved as part of the final remedy shall survive the termination of this plan.

4. ICs may be placed upon the facility or on any specifically identified area at or near a SWMU or AOC. ICs may restrict the use of the property covered by such ICs to commercial and/or industrial land use, as those terms are currently defined, or may be defined in the future, by zoning ordinance(s) of the city, county or any other local governmental entity with jurisdiction and authority to regulate the land use at the property.

K. COMPLETION OF CORRECTIVE ACTION

1. The corrective action shall be considered complete when the Commissioner determines that compliance with the media cleanup standards and the cleanup objectives has been achieved, and that all actions required to control the source(s) of contamination have been satisfied.

2. Corrective action shall be considered complete with or without controls in place where the facility has satisfied all obligations under Rules 0400-12-01- .06(6)(a)1(ii) and .06(6)(l).

3. Upon completion of the corrective action for the entire facility, or for a portion of the facility, or for any off-site contamination, the facility shall submit to the Commissioner, by registered mail, a request for termination of the corrective action schedule of compliance according to the procedures for Class 3 modifications in Rule 0400-12-01-.07(9)(c). The request shall include a certification that the corrective measures have been completed in accordance with the requirements of this plan.

4. When, upon receipt of the certification, and in consideration of public comments and any other relevant information, the Commissioner determines that the corrective measures have been completed in accordance with the terms and conditions of this plan and the requirements for completion, the Commissioner shall terminate this plan or modify the plan to terminate the Corrective Action Schedule of Compliance for SWMUs and AOCs that require no further action at this time. Upon termination of the plan or modification of the plan for completion V-11

of corrective action at the entire facility, the Commissioner shall release the facility from the financial assurance requirements of this plan.

L. MODIFICATION OF THE CORRECTIVE ACTION COMPLIANCE SCHEDULE

1. If at any time the Commissioner determines that modification of the Corrective Action Compliance Schedule is necessary, the Commissioner may initiate a modification to the Corrective Action Compliance Schedule. All corrective action schedules specified in this plan section are summarized in ATTACHMENT 6.4.

2. Modifications that are initiated and finalized by the Commissioner will be in accordance with the applicable provisions of Rule 0400-12-01-.07(9). The facility may also request a plan modification in accordance with Rule 0400-12-01-.07(9) to change the Corrective Action Compliance Schedule.

M. WORK PLAN AND REPORT REQUIREMENTS

l. All work plans and schedules shall be subject to approval by the Commissioner prior to implementation to assure that such work plans and schedules are consistent with the requirements of this plan and with applicable regulations. The facility shall revise all submissions and schedules as specified by the Commissioner. Upon approval the facility shall implement all work plans and schedules as written.

2. All work plans and reports shall be submitted in accordance with the approved schedule. Extensions of the due date for submissions may be granted by the Commissioner based on the facility's demonstration that sufficient justification for the extension exists.

3. Unless notified by a separate letter that additional hard copies are necessary, only two (2) hard copies and one (1) electronic copy of all reports and plans shall be provided by the facility to the Commissioner. Submittals shall be addressed in care of the Division Director, as follows:

Director Division of Solid Waste Management William R. Snodgrass Tennessee Tower 312 Rosa L. Parks Avenue, 14th Floor Nashville, TN 37243

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The facility shall also submit (1) hard copy to the Environmental Field Office at the following address:

Field Office Manager Division of Solid Waste Management TDEC Jackson Environmental Field Office 1625 Hollywood Drive Jackson, TN 38305

4. If the facility at any time determines that the SAR information required under Subsection V.B, the CS Work Plan under Subsection V.D, RFI Work Plan(s) required under Subsection V.E no longer satisfy the requirements of Tennessee Hazardous Waste Management Regulations, Rule 0400-12-01-.06(6)(l) or this plan for prior or continuing releases of hazardous waste or hazardous constituents from SWMUs and/or AOCs, the facility shall submit an amended Work Plan(s) to the Commissioner within 90 calendar days of such determination.

N. APPROVAL / DISAPPROVAL OF SUBMISSIONS

The Commissioner will review the work plans, reports, schedules, and other documents (submissions) that require the Commissioner's approval in accordance with the conditions of this plan. The Commissioner will notify the facility in writing of any submission that is disapproved and the basis therefore. Subsection V.O shall apply only to submissions that have been disapproved and revised by the Commissioner, or that have been disapproved by the Commissioner, then revised and resubmitted by the facility, and again disapproved by the Commissioner.

O. DISPUTE RESOLUTION

The Commissioner and the facility shall use their best effort to resolve any disputes concerning submissions hereunder and the proper application of statutory or regulatory provisions informally and in good faith. If a disagreement cannot be resolved informally, the parties jointly or individually may pursue the matter formally by requesting a Declaratory Order by the Tennessee Underground Storage Tanks and Solid Waste Disposal Control Board in a contested case hearing under T.C.A. 4-5-223.

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EPA ID Number: TND054876834 Plan Number: TNHW-183

ATTACHMENT 1 FACILITY DESCRIPTION

Teknor Apex-Tennessee Company, (Teknor Apex) was constructed in 1972 by Teknor Apex Company for the compounding of polyvinyl chloride, (PVC), plastics, the manufacture of garden hose, and the production of specialty organic chemicals. The Teknor Apex property consists of approximately 122 acres and is located at 751 Dupree Street, Brownsville, Haywood County, Tennessee Figure 1-1, Vicinity Map. Tank Farm #1 (TF-1) is located behind the Teknor Apex manufacturing building, near the center of the Teknor Apex property Figure 1-2, Site Plan and covers the contaminated soil that makes up the hazardous waste post-closure landfill.

The upgraded containment/cap area for TF-1 consists of a reinforced geosynthetic clay liner, which is overlain by 6 inches of gravel and 6 inches of concrete. Concentrations of DEHP exceeding US EPA Regional Screening Levels (RSLs) were identified in soil beneath TF-1 during preliminary investigative activities that were conducted in 2007 and 2008 by Teknor Apex, as part of developing the strategy to upgrade TF-1.

A1-1

ATTACHMENT 1 Figure 1-1 Vicinity Map 0 2,000 4,000 Area of Feet Detail ¯

TN Tractor !(

Cannon, H. !( Wright, B. Hopper,!( Powell, B. Mike !( !( Chilcutt, Johnson, D. Todd !( !(

Miller, D. !( Teknor Apex !( Taylor, O. !(

Property BoundaryChesnutt,!( G. Stanley, H. !( !( Gibson, J.

Chambers, O.J./Beaning, C. !(

1 Mile Property Buffer Holt, T. !(

Legend

FIGURE 1-1 Environmental Resources VICINITY MAP Management WITHIN 1 MILE OF FACILITY Teknor Apex DESIGN: B. Cherry DRAWN: EFC CHKD.: . 751 Dupree Street DATE: 9/2/2015 SCALE: AS SHOWN REVISION: 0 Brownsville, Haywood County, Tennessee W.O.NO.: K:\GIS\Teknor_Apex\BrownsvilleTN\MXD\0297951_WatWells1mi.mxd

ATTACHMENT 1 Figure 1-2 Site Plan 362 378 362 372 390 380 388 360 388 374 340 382 386 358 384 384

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394 410 414 392 412 410 380 390 1,000 Foot Buffer 382 384 408 384 388 400 406 394 400 382 400 380 392 402 388 412 386 404 396 388 398 400 390 398 402 410 404 402 LEGEND: Design: Drawn: TITLE: Land Use EFC 1-2 B. Cherry Environmental Resources Management FIGURE !. SITE PLAN Monitoring Wells Tank Farm #1 Agricultural ¯ CityCentre Four Checked: Checked: Teknor Apex Ground Surface Elevation USDHS FEMA 100-Yr Flood Tennessee 840 West Sam Houston Parkway North Commercial/Industrial Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, . . 751 Dupree Street Contour (2 Foot Interval; USGS Plain Suite 600 and the GIS User Community Area of 0 200 NED 1/3 Arc Second) Residential Esri, HERE, DeLorme, MapmyIndia, © OpenStreetMap contributors Houston, Texas 77024 Brownsville, Haywood County, Tennessee Detail Date: Revision: Drainages Esri, HERE, DeLorme, TomTom, MapmyIndia, © OpenStreetMap contributors, and the GIS user community Feet 9/28/2015 USGS 7.5' Quadrangle, Sunnyhill, TN (35089E2) 1983. 0 K:\GIS\Teknor_Apex\BrownsvilleTN\MXD\0297951_topoContours_Lrg_w_landuse_general.mxd,9/28/2015 4:30:33 PM EPA ID Number: TND054876834 Plan Number: TNHW-183

ATTACHMENT - 2 SECURITY

As shown in Figure 2-1, Fence and Gate Location Map, access to the land disposal unit (TF-1) is controlled by two access gates which are guarded at all times. The entire facility, including TF-1 and AOC-A, is encompassed by a 6-foot chain link fence that is topped with strands of barbed wire. The warning signs as shown in Figure 2-2, Photo of Warning Sign, for TF-1 have been posted in clear sight of TF-1,

Access to TF-1 is controlled by berms surrounding the tank farm, and a concrete floor protects TF-1 from infiltration of water during periods of precipitation. Waste has been left in place under the Tank Farm floor.

The Corrective Action Unit, AOC-A has a sign, Figure 2-3, Sign for AOC A Landfarm, which states that digging is by permit only. A contact person and the contact persons telephone number is listed on the sign.

A2-1

ATTACHMENT 2 Figure 2-1 Fence and Gate Location Map

ATTACHMENT 2 Figure 2-2 Photo of Warning Sign FIGURE 2-2 Environmental Resources PHOTO OF WARNING SIGN Management WITHIN 1 MILE OF FACILITY Teknor Apex DESIGN: B. Cherry DRAWN: EFC CHKD.: . 751 Dupree Street DATE: 9/2/2015 SCALE: AS SHOWN REVISION: 0 Brownsville, Haywood County, Tennessee W.O.NO.: K:\GIS\Teknor_Apex\BrownsvilleTN\MXD\0297951_WatWells1mi.mxd

ATTACHMENT 2 Figure 2-3 Sign for AOC-A Landfarm

EPA ID Number: TND054876834 Plan Number: TNHW-183

ATTACHMENT 3 INSPECTIONS

The monitoring wells, Area of Concern A (AOC-A), and Tank Farm #1, (TF-1) containment system will be inspected on a monthly and semi-annual schedule, and after significant storm events. Figure 3-1, Items and Schedule shows the schedule for the monitoring wells, TF-1 containment system, and site security for the monitoring wells, containment system and AOC-A.

An inspection log, Figure 3-2, Teknor Apex Inspection Log for the monitoring wells, containment system, (TF-1), and AOC A will be used to record the inspection results. If inspections reveal that non-emergency maintenance is needed, it will be completed as soon as possible to preclude further damage and reduce the need for emergency repairs. If a problem is imminent or has already occurred during the course of an inspection or any time between inspections, remedial actions will be taken immediately, but no later than within 24 hours of discovery.

If cracking in the concrete floor of the (TF-1) containment system is observed during the inspection, the inspector will report the condition immediately. A qualified technician will fill the crack with a blended latex emulsion (Quickrete® Gray Concrete Crack Seal or equivalent) specifically designed to adhere to concrete surfaces. The latex emulsion will prevent the movement of water through the cracked concrete and into the subsurface.

After an inspection, log sheets will be filed and records of inspection will be maintained at the facility.

A3-1

ATTACHMENT 3 Figure 3-1 Inspection Items and Schedule

ATTACHMENT 3 Figure 3-2 Inspection Log

EPA ID Number: TND054876834 Plan Number: TNHW-183

ATTACHMENT 4 POST-CLOSURE CARE PLAN

ATTACHMENT 4.1, Post-Closure Care Plan, includes the Sampling and Analysis Plan for Long-Term Groundwater Monitoring. The purpose of this plan is to ensure that the land disposal unit will be maintained and monitored after closure to safeguard against any endangerment to either human health or the environment.

Post-closure care of the former land disposal unit includes the following activities:

• Groundwater monitoring of the facility conducted in accordance with the approved monitoring program in ATTACHMENT 5, GROUNDWATER MONITORING.

• Inspection of the former disposal unit conducted quarterly and after significant storm events, to include inspection of the final cover system, the site drainage system, monitoring wells, and the surveyed benchmarks in ATTACHMENT 3, INSPECTIONS. The Land Use Restriction by the property owner, the Industrial Board of the City of Brownsville, is included as ATTACHMENT 4.2, Land Use Restriction.

A4-1

ATTACHMENT 4 Figure 4-1 Post-Closure Care Plan

ATTACHMENT 4 Figure 4-2 Land Use Restrictions

EPA ID Number: TND054876834 Plan Number: TNHW-183

ATTACHMENT 5 - GROUNDWATER MONITORING PLAN

Analytical results from groundwater sampling conducted since 2008 shows that contamination from a Di(2-ethylhexyl)phthalate (DEHP) release has not reached the underlying aquifers. Because a release was known to have occurred, a detection monitoring program has been established at Tank Farm #1 (TF-1), which consists of a network of four monitoring wells.

The Teknor Apex facility is located in the Gulf Coast Plains of West Tennessee, which is relatively flat and dominated by alluvial deposits and unconsolidated sands and clay of Cretaceous and Eocene age. Stratigraphic units in western Tennessee typically dip to the west towards the Mississippi River at 15-30 feet/mile.

The Teknor Apex facility, in particular, is located in Quaternary Loess deposits. This stratigraphic unit consists primarily of sandy silt. The loess deposits can be up to 100 feet thick near the Mississippi River and generally thin eastwards. The Loess deposits are generally underlain by the Grenada formation, which is a reliable water-bearing formation consisting of well-sorted sands.

DEHP is the only constituent in the Detection Monitoring Program. DEHP tends to adsorb to soil and sediments and is relatively stable in the unsaturated zone. US EPA SW-846 Method 8270C is the analytical method used for the detection of DEHP. ATTACHMENT 5.6, Groundwater Protection Standard for DEHP is the Maximum Contamination Level (MCL) of 6 parts per billion. Excluding the initial sampling event conducted in November and December 2008, sampling results have consistently been non-detect for DEHP.

Semi-annual sampling and annual reporting has been conducted at TF-1 for MW-1, MW-2, and MW-3 since 2009 and MW-4A since 2015. Since 2016, sampling and reporting has been conducted for the four monitoring wells on an annual basis. The groundwater monitoring is conducted in accordance with the Sampling and Analysis Plan, ATTACHMENT 5.1.

The monitoring wells are purged of a minimum of three well volumes prior to sample collection using a submersible pump and/or Teflon bailer. The pump is decontaminated with an alconox solution wash and distilled water rinse prior to sampling.

A YSI Multiprobe (or similar) is used to monitor temperature, pH, dissolved oxygen, conductivity, oxidation reduction potential, and turbidity. Water quality parameters are measured and recorded following the removal of each well volume. Samples are collected after removal of the third well volume and water quality parameters have stabilized.

Groundwater samples are transferred directly from polyethylene sample tubing into new, laboratory-supplied sample containers and placed on ice in a cooler. The US EPA SW-846 Method 8270C is the analytical method used for the detection of DEHP. The Sampling Container Label is provided as ATTACHMENT 5.2. The Chain of Custody Form is

A5-1 provided as ATTACHMENT 5.3. Monitoring Well Construction Diagrams are shown in ATTACHMENT 5.4. The Groundwater Monitoring Well Location Map is shown in ATTACHMENT 5.5.

A5-2

ATTACHMENT 5-1 Sampling and Analysis Plan

ATTACHMENT 5.1 Sampling and Analysis Plan Teknor Apex – Tennessee Company Brownsville, TN EPA ID Number TND054876834

May 2017

www.erm.com

The business of sustainability Presented on behalf of Teknor Apex Tennessee Company

Teknor Apex Tennessee Company Brownsville, TN Sampling and Analysis Plan

EPA ID Number TND05476834

May 2017

Jackson Spain Tennessee Registered Professional Geologist

Ben George Project Manager

Phil D. Patey Partner-in-Charge

Environmental Resources Management 5000 Meridian Blvd. Suite 300 Franklin, TN 37067 (615) 656-7100

1.0 INTRODUCTION ...... 1 1.1 RESPONSIBLE AGENCY ...... 1 2.0 BACKGROUND ...... 1 2.1 SITE LOCATION ...... 1 2.2 GEOLOGIC SETTING...... 1 2.3 HISTORICAL SITE OPERATIONS ...... 1 2.4 TF-1 CLOSURE ...... 2 2.5 TF-1 GROUNDWATER MONITORING WELL INSTALLATION ...... 2 2.6 TDEC REGULATORY INVOLVEMENT ...... 2 3.0 DATA QUALITY OBJECTIVES ...... 3 4.0 FIELD ASSESSMENT/SAMPLING METHODOLOGY ...... 4 4.1 SAMPLING ...... 4 4.2 ANALYTICAL PROCEDURES ...... 4 4.3 EQUIPMENT DECONTAMINATION PROCEDURES ...... 5 5.0 SAMPLE DOCUMENTATION AND SHIPMENT ...... 6 5.1 FIELD RECORDS ...... 6 5.2 LABELING ...... 7 5.3 CHAIN-OF-CUSTODY ...... 7 5.3.1 Packaging ...... 7 6.0 MAXIMUM CONTAMINANT LEVEL EXCEEDANCES ...... 9 7.0 INVESTIGATION DERIVED WASTE ...... 10 8.0 REPORTING ...... 11

ERM i 13.2 ATTACHMENT 5.1 SAMPLING AND ANALYSIS PLANMay 2017

List of Figures

Figure 1 Site Layout Map Figure 2 Groundwater Monitoring Well Location Map

List of Appendices

Appendix A Quality Assurance Project Plan (QAPP)

ERM ii 13.2 ATTACHMENT 5.1 SAMPLING AND ANALYSIS PLANMay 2017

1.0 INTRODUCTION

Environmental Resources Management (ERM) has prepared this Sampling and Analysis Plan for (SAP) for Tank Farm 1 (TF-1) at the Teknor Apex Tennessee Company (Teknor) facility located at 751 Dupree Street in Brownsville, Tennessee (the “Site”).

This SAP outlines specific sampling and analysis protocols to be followed in order to properly monitor the TF-1 groundwater monitoring wells for the presence of bis-2- ethylhexlphthalate (DEHP).

1.1 RESPONSIBLE AGENCY

Teknor will implement this SAP under the guidance of the Tennessee Department of Environment and Conservation, Division of Solid Waste Management (TDEC-DSWM). BACKGROUND

1.2 SITE LOCATION

The Teknor property consists of approximately 122 acres located at 751 Dupree Street, Brownsville, Haywood County, Tennessee. TF-1 is located east of the main manufacturing building approximately 800-ft east of Dupree Street and 650-ft north of the southern property boundary. A Site Layout Map is provided as Figure 1.

1.3 GEOLOGIC SETTING

The Teknor facility is located in the Gulf Coast Plains of West Tennessee, which is relatively flat and dominated by alluvial deposits and unconsolidated sands and clay of Cretaceous and Eocene age. Stratigraphic units in western Tennessee typically dip to the west towards the Mississippi River at 15 to 30 feet/mile.

The Teknor facility, in particular, is located in Quaternary Loess deposits. This stratigraphic unit consists primarily of sandy silt. The loess deposits can be up to 100 feet thick near the Mississippi River and generally thin eastwards. The Loess deposits are generally underlain by the Grenada formation, which is a reliable water-bearing formation consisting of well-sorted sands.

1.4 HISTORICAL SITE OPERATIONS

The manufacturing facility was constructed in 1972 by Teknor Apex Company for the compounding of PVC plastics, the manufacture of garden hose, and the production of specialty organic chemicals. The facility now operates as Teknor Apex Tennessee Company, and is actively engaged in the same manufacturing processes.

1.5 TF-1 CLOSURE

In 2007, Teknor voluntarily requested TDEC-DSWM oversight for the closure of subsurface impacted soils beneath TF-1. The project involved the capping of TF-1, which was originally constructed in approximately 1973. Teknor removed approximately 1 to 2 feet of surface stone and soil from TF-1 in an effort to prepare the unit for a surface cap. The surface cap was designed to prevent direct contact with soil and minimize infiltration of surface water in the area.

1.6 TF-1 GROUNDWATER MONITORING WELL INSTALLATION

Permanent groundwater monitoring wells were installed surrounding TF-1 as part of the closure plan. Wells MW-1, MW-2, and MW-3 were installed in November 2008. MW-1 was installed immediately south of TF-1; MW-2 was installed immediately northwest of TF-1; and MW-3 was installed immediately east of TF-1. A fourth monitoring well, MW- 4A, was installed approximately 125 feet southwest of TF-1 (i.e., down-gradient) in August 2015. The monitoring wells are constructed of 2-inch diameter stainless steel casing with a 10-foot section of 0.010-inch slotted well screen. The monitoring well locations and the TF-1 boundary are presented on Figure 2.

1.7 TDEC REGULATORY INVOLVEMENT

Teknor voluntarily entered into the Corrective Action Program to request oversight for the closure of subsurface impacted soils at TF-1.

2.0 DATA QUALITY OBJECTIVES

Information relating to project-specific personnel, data quality objectives, sample control procedures, analytical protocols, and field and laboratory QA/QC is presented in the Quality Assurance Project Plan (QAPP), which is included as Appendix A.

3.0 FIELD ASSESSMENT/SAMPLING METHODOLOGY

The following sections provide details regarding the methods to be used for the collection of groundwater samples at TF-1.

3.1 SAMPLING

Groundwater samples will be collected on an annual basis from permanent groundwater monitoring wells MW-1, MW-2, MW-3, and MW-4A surrounding TF-1. The annual sampling event will be conducted in the fourth calendar quarter of each year. Upon arrival to the Site, each well will be visually inspected, unlocked, and uncapped. Once uncapped, each well will be left for approximately 15 minutes to allow for water level equilibration in the instance that the cap maintained pressure within the well.

Following water level stabilization and prior to initiating sampling, a groundwater elevation survey of the four monitoring wells will be conducted to enable preparation of a potentiometric surface map. Groundwater samples will then be collected using an electric submersible pump. Samples will be collected after a minimum of three well volumes has been purged and water quality parameters (pH, conductivity, oxidation reduction potential (ORP), temperature, and dissolved oxygen (DO)), have stabilized.

Field procedures associated with these sampling events will be conducted in accordance with the US EPA Science and Ecosystem Support Division (SESD) Guidance Document for Groundwater Sampling, dated 2017 or the most recent version.

Following collection, each sample container will be labeled and placed on ice in a cooler pending transport to the laboratory.

3.2 ANALYTICAL PROCEDURES

Groundwater and quality control samples will be submitted via overnight courier under Chain-of-Custody protocol to SGS-Accutest Laboratories in Orlando, Florida. All samples will be analyzed for DEHP by US EPA SW-846, Method 8270C. Samples to be analyzed for DEHP have a holding time of 14 days. The laboratory’s method quantitation limit ranged between 0.48 to 0.56 µg/L in the 2015 and 2016 samples. The analytical data will be screened against the US EPA Maximum Contaminant Level (MCL) and the Regional Screening Level for Tap Water. A standard turn-around-time of ten business days will be used for the analytical procedures.

As specified in the Quality Assurance Project Plan, samples will also be collected for laboratory analysis, as follows: • Duplicates: One per sampling event; • Equipment Rinsate Blank: One per sampling event; and

• Matrix Spike/Matrix Spike Duplicate: One per sampling event, lab will complete internal MS/MSD. The Equipment Rinsate blank will be collected following decontamination of the submersible pump. The sample will be collected by pumping de-ionized water through the pump and new polyethylene sample tubing into clean, laboratory-supplied, amber, unpreserved, 1 liter bottles. Two 1 liter bottles are required per sample. Once collected, the sample bottles will be labeled and then placed on ice in a cooler to await transport.

3.3 EQUIPMENT DECONTAMINATION PROCEDURES

Prior to initiating sampling at a new well location, the submersible pump will be decontaminated. Decontamination procedures include thoroughly scrubbing the exterior of the submersible pump with an alconox/distilled water mixture followed by pumping the same mixture through the pump and then rinsing with distilled water. New polyethylene sample tubing will be used at each well location.

4.0 SAMPLE DOCUMENTATION AND SHIPMENT

4.1 FIELD RECORDS

The field documentation requirements include records of all observations made during sampling or decontamination that could affect the quality of a sample. The documentation for each sample will be entered in a bound field notebook with consecutively numbered pages. Field entries will be complete and accurate enough to allow reconstruction of all field activities. All entries will be legible, written in blue or black ink, and signed on each page by the individual making the entries. Only factual and objective language will be used.

At a minimum, the following information will be recorded during the collection of each sample:

• Sample location and description; • Groundwater monitoring well ID; • Sampler’s name(s); • Date and Time of each sample collection; • Designation of sample as composite or grab; • Type of sample (e.g., groundwater); • Type of sampling equipment used to collect each sample; • Field observations related to sample analysis or integrity (e.g., weather conditions, noticeable odor, color, etc.); • Preliminary sample descriptions (e.g., for water: clear water with ammonia-like odor); • Sample preservations; • Shipping arrangements (overnight air bill number or courier name); and • Name(s) of recipient laboratory.

In addition to the sampling information listed above, the following specific information will also be recorded in the field logbook for each day of sampling:

• Team members present and their responsibilities; • Time of arrival/entry on Site and time of Site departure; • Other personnel on Site; • Summary of any Site meetings or discussions with contractors, agency personnel, Site personnel, etc.; • Deviations from work plan procedures; • Changes in personnel and responsibilities with reasons for the changes; and • Levels of safety protection.

4.2 LABELING

All samples collected will be labeled in a clear and precise way for proper identification in the field and for tracking in the laboratory. The samples will have pre-assigned, identifiable, and unique numbers. At a minimum, the sample labels will contain the following information:

• Client; • Site; • Sampling location (monitoring well ID); • Date and time of collection; • Analytical parameter; and • Method of preservation, if applicable.

An example of a Sample Label has been provided in ATTACHMENT 5.2.

4.3 CHAIN-OF-CUSTODY

Chain-of-custody forms are used to document sample collection and shipment to laboratories for analysis. All sample shipments for analyses will be accompanied by a chain-of-custody form. A representative copy of the Chain-of-Custody form to be used for this project is provided in ATTACHMENT 5.3.

The chain-of-custody form will identify the contents of each shipment and maintain the custodial integrity of the samples. Generally, a sample is considered to be in someone’s custody if it is either in someone’s physical possession, in someone’s view, locked up, or kept in a secured area that is restricted to authorized personnel. Until the samples are shipped or delivered to a laboratory, the custody of the samples will be the responsibility of the ERM sampling team leader. The sampling team leader or designee will sign the chain-of-custody form in the “relinquished by” box and note date, time, and air bill number.

The sample numbers for all rinsate samples, reference samples, laboratory QC samples, and duplicates will be documented on the chain-of-custody form. The original form will be left with the laboratory analyzing the samples.

The shipping containers, in which the samples are stored, will be sealed with self- adhesive custody seals any time the samples are not in someone’s possession or view before shipping. All custody seals will be signed and dated.

4.3.1 Packaging

All samples will be packed so as to avoid breakage and prevent cross-contamination, according to the following procedures:

1. The bottom of the cooler will be lined with bubble wrap to prevent breakage;

2. All sample bottles will be placed in bubble wrap bags and then placed in heavy duty zip lock bags; 3. Sample bottles will be placed inside a large plastic bag within the cooler and packed tightly to prohibit movement while in transport; 4. A temperature blank will be included in each sample cooler; 5. Ice will be placed inside the large plastic bag inside the cooler to chill the samples to 4ºC (+/-2ºC); 6. The cooler will be sealed with tape and custody seals so that the cooler cannot be opened without breaking the seal.

5.0 MAXIMUM CONTAMINANT LEVEL EXCEEDANCES

In the event that the laboratory analytical results indicate that the concentration of DEHP exceeds the current US EPA MCL, the following activities will be conducted:

• Additional groundwater sample data will be collected at a frequency up to four times in one calendar year following the exceedance;

• The supplemental data will be reviewed by Teknor and provided to TDEC following each supplemental sampling event; and

• The installation and sampling of additional monitoring wells downgradient of TF-1 up to the property boundary, or the point of compliance, will be considered.

The point of compliance for the Site has been identified as the property boundary. The property boundary is shown on Figure 2-1, which is provided in the Post Closure Application.

6.0 INVESTIGATION DERIVED WASTE

Investigative-Derived Waste (IDW) generated during this investigation could include, but is not limited to, purge water generated prior to sample collection; disposable personal protective equipment (PPE), and decontamination fluid from cleaning PPE and sampling equipment.

Purge water and water from decontamination procedures will be treated by the on-Site wastewater treatment facilities. Disposable sampling equipment and PPE will be disposed of on-Site as domestic trash.

7.0 REPORTING

A report, including all analytical data, sampling locations, conclusions, and recommendations, will be submitted to TDEC-DSWM approximately 30 business days following receipt of the analytical data. Data obtained from sampling and analysis procedures will be summarized in tables and copies of the laboratory analytical reports will be provided. Several formats may be used to present sampling results graphically. Forms completed during the investigation will be included in appendices of the report. Accumulated data and analytical results will be interpreted to develop proper conclusions and recommendations.

Appendix A

Quality Assurance Project Plan (QAPP)

QUALITY ASSURANCE PROJECT PLAN

For

Sampling and Analysis of Groundwater

Teknor Apex - Tennessee Company

751 Dupree Avenue

Brownsville, Tennessee

This Quality Assurance Project Plan (QAPP) was prepared to supplement the Sampling and Analysis Plan for Long Term Monitoring for the Teknor Apex Tennessee Company facility, located at 751 Dupree Avenue in Brownsville, Tennessee. The QAPP presents project-specific personnel, data quality objectives, sample control procedures, analytical protocols, and field and laboratory quality assurance/quality control (QA/QC).

A-1 1.0 PROJECT ORGANIZATION

The Project Manager will coordinate all personnel and project activities. The Project Manager will provide technical assistance as needed and will have the ultimate responsibility for project performance and data quality. The Quality Assurance Officer (QAO) is responsible for project QA/QC and will evaluate the project data and verify proper performance and compliance with the QAPP. The QAO will be responsible for adherence to all QA/QC, as defined in this QAPP.

All of the designated technical team members are experienced professionals who possess the degree of specialization and technical competence required to effectively and efficiently perform the required work.

The certified laboratory will perform analysis of samples and will adhere to the requirements outlined in this QAPP and the laboratory’s Quality Assurance Plan.

A-2 2.0 DATA QUALITY OBJECTIVES

The general quality assurance objectives of this project are to assess and document the precision, accuracy, representativeness, completeness, and comparability of all sampling and analyses performed. Quality criteria are set herein to assure suitability for intended use of data obtained during the project and to meet goals established by the USEPA. The following sections discuss in detail data quality assurance criteria specific to this project and its goals. To facilitate in understanding of how these objectives will be achieved, each of these criteria are defined below.

2.1 PRECISION

Precision is a measure or estimate of the reproducibility of measurements and methods. It is defined for quantitative data as the variability of a group of values compared with their average value. Duplication of activities is generally the method by which precision is assessed. For purposes of assessing precision of the measurement systems (sampling events and analysis) to be used in this project, duplicate samples (both from the field and within the laboratory) will be obtained and analyzed along with the investigative samples. The precision of the method for organic compounds will be expressed in terms of the relative percent difference (RPD) for matrix spike recoveries calculated as follows:

(RMS-RMSD) RPD = x 100 (RMS + RMSD)/2

Where RPD, RMS, and RMSD are relative percent difference, matrix spike recovery, and matrix spike duplicate recovery, respectively.

2.2 ACCURACY

The determination of measurement accuracy requires knowledge of the true or accepted value for the signal being measured. The laboratory analysis accuracy will be evaluated employing laboratory control sample (LCS) analyses. Accuracy may be calculated in terms of bias as follows:

Bias = X - T

100 (X – T) % Bias = T

A-3 Where: X = average observed value of measurement T = “true” value

Accuracy may also be calculated in terms of the recovery of spiked samples as in the case of LCS for this program.

100 X % Recovery = T

Additionally, blanks will be used to evaluate whether laboratory or field procedures represent a possible source of contamination in the field samples. Unmonitored contamination can allow false positive results to be reported and treated as true sample components when in fact they are not. This type of error will adversely affect the reported results accuracy. Several blank types (field blanks, method blanks, and laboratory analytical blanks) will be used throughout this project.

2.3 REPRESENTATIVENESS

Representativeness expresses the degree to which data accurately and precisely represent a characteristic of a population, parameter variations at a sampling point, a process condition, or an environmental condition. Representativeness is a qualitative parameter, which is dependent upon the proper design of the sampling program and proper laboratory protocol. The sampling approach was designed to provide data representative of the Site conditions. During development of this approach, consideration was given to current and past Site activities, existing analytical data, and physical setting. Representativeness will be satisfied by ensuring that the Groundwater Monitoring Plan, the QAPP, and USEPA protocols are followed, proper sampling techniques are used, proper analytical procedures are followed, and holding times of the samples are not exceeded by the laboratory.

2.4 COMPLETENESS

Completeness is a measure of the amount of valid data obtained from a measurement system compared to the amount expected to be obtained under correct normal conditions. The completeness goal for field measurements will be greater than 90 percent. Completeness goals of field measurements reflect the ability to resample immediately (i.e., prior to declaring well stability) and obtaining samples for subsequent analysis. Laboratory analysis for this project will have a completeness goal of greater than 95 percent.

A-4 Completeness will be calculated by dividing the number of valid results by the number of possible individual analyte results, expressed as a percentage.

2.5 COMPARABILITY

Comparability is the degree to which one data set can be compared to another. The objective of this QAPP is to produce a high level of comparability between data sets. The use of standard methods for sampling and analysis (USEPA protocols), reporting data in standard units, and using standard and comprehensive reporting formats will optimize the potential for high levels of data comparability.

2.6 FIELD QC SAMPLE OBJECTIVES AND COLLECTION FREQUENCY

Primary measurements for field (and laboratory) QA/QC are derived from matrix spike/matrix spike duplicate samples, duplicate samples, field blanks, and rinsate blanks collected in the field. The types of QA samples that will be utilized during AOC-A Work Plan implementation are discussed in Table 1, which summarizes the frequency at which these samples will be collected.

Table 1 QC Sample Collection Frequency

Quality Control Sample Frequency of Collection

Duplicates One per sampling event

Rinsate Blanks One per sampling event

Matrix Spike/Matrix Spike One per sampling event Duplicate

2.6.1 Duplicates

A duplicate is an identical sample collected from the same location, at the same time, under identical conditions as the original. Duplicate samples, including the matrix spike/matrix spike duplicate, are analyzed along with the original to ascertain procedural precision and inherent source variability.

A-5 2.6.2 Rinsate Blanks

For non-disposable sampling equipment, rinsate (or equipment) blanks are collected by retaining rinsate from sampling equipment. The equipment is rinsed with deionized water after sampling and full decontamination procedures have been completed.

A-6 3.0 SAMPLE CONTROL AND FIELD RECORDS

Sample chain-of-custody procedures begin at the time the sample is containerized and labeled, and continue through transport, sample receipt, preparation, analysis, and storage, data generation and reporting, and sample disposal. Record of sample custody will be maintained in the field records, project file(s), and laboratory records. A chain-of-custody form will be used for transferring sample shipment to the laboratory. Upon transfer of custody, the form will be signed by a member of the sampling team, who will note the date and time the samples were relinquished to the laboratory.

All chain-of-custody forms received by the laboratory will be signed and dated by the laboratory sample custodian and returned as part of the data reporting package. The analytical laboratory will carry the chain-of-custody through the laboratory during the analytical process. The following information will be recorded on each chain- of-custody form: • Site name and location; • Date and time of sample collection; • Type of analysis to be performed; • Preservation; • Sample identification number; and • Project number (if applicable).

Sample Packaging

All samples must be packed so as to avoid breakage and prevent cross-contamination, according to the following procedures: 1. Select a cooler in good condition. Seal the drain plug on the inside and outside of the cooler with tape to prevent leakage. 2. In order to prevent breakage while packaging samples, either: • Wrap samples in bubble wrap or other suitable packaging materials, and seal around the containers with tape. Protective wrap is not required for plastic containers, but take care when packing the coolers so that the containers do not directly touch each other; or

A-7 • Place two to four inches of inert packaging material on the bottom of the cooler. Place the bagged containers inside the cooler so the bottles do not touch each other. Place cooling material (e.g., bagged ice, blue ice) around and between the samples. Completely fill any remaining space with additional inert packaging material such as vermiculite or cellulose insulation.

3. Include a temperature blank or strip in each sample cooler. 4. Place a trip blank in each cooler containing volatile organic compounds (VOCs). 5. Place ice (or Blue Ice) inside the cooler to chill the samples to 4ºC (+/-2ºC). 6. Seal the cooler with tape and custody seals so that the cooler cannot be opened without breaking the seal.

A-8 4.0 ANALYTICAL PROCEDURES

The parameters being measured, analytical methods to be employed, and anticipated sample containers and preservatives are presented in the following Table. Samples will be analyzed in accordance with Test Methods for Evaluation of Solid Waste (Physical/Chemical Methods), (SW-846), USEPA Office of Solid Waste and Emergency Response, Third Edition, December 1996 or other TDEC-approved methods.

Table 2 Analytical Methods Sample EPA Analytical Holding Analysis Matrix Container Preservation Method Time Size/Type SW-846, 1 Liter amber DEHP Water Method 8270 glass None 14 days

A-9 5.0 LABORATORY QUALITY ASSURANCE/QUALITY CONTROL

Internal quality control procedures for the laboratory analytical methods are specified in the SW-846 and EPA methods. These specifications include the type of QC checks required which include: method blanks, reagent/preparation blanks, matrix spike and matrix spike duplicates, calibration standards, internal standards, surrogate standards, the specific calibration check standards, laboratory duplicate/replicate analysis. Field duplicates and field QC blanks will be collected and analyzed to assess precision and bias. The laboratory that is selected to perform the analyses will have a QC program to ensure the reliability and validity of the analyses performed.

All data obtained will be properly recorded. Any samples analyzed in nonconformance with the QC criteria will be reanalyzed by the laboratory, if sufficient volume is available. It is expected that sufficient volumes/weights of samples will be collected to allow for reanalysis, when necessary.

A-10 6.0 DATA REDUCTION, VALIDATION, AND REPORTING

The laboratory procedures for data reduction, validation, and reporting are to be included in the laboratory QAP. Data reduction, validation, and reporting by the laboratory will meet the criteria needed to facilitate internal data validation. Internal QC checks and data validation procedures are described below.

Field Data Package

The field data, including field records and measurements obtained at the Site by the sampling personnel will be reviewed for completeness and accuracy by conducting the following: • A review of field data on sampling logs for completeness. • Verification that sample rinsate blanks and trip blanks were properly prepared, identified, and analyzed. • Check on field analyses for equipment calibration and condition. • Review of chain-of-custody forms for proper completion, signatures of field personnel and the laboratory sample custodian, and dates.

Analytical Data Package

The analytical data package will be validated by the project QA officer or designee. The validation steps will be performed by applying, where applicable, the USEPA Contract Laboratory Program National Functional Guidelines for Organic and Inorganic Data Review, and EPA Precision and Accuracy statements for the analytical methods employed. The analytical data package validation procedure includes, but is not limited to, review of the items outlined below.

Data Validation Procedures

Comparison of sampling, sample extraction, and analysis dates to check that samples were extracted and/or analyzed within the proper holding times. • Review analytical methods and required detection limits to verify agreement with the QAPP and the laboratory contract. • Review field and laboratory blanks to evaluate possible contamination sources. The preparation techniques and

A-11 frequencies, and the analytical results (if appropriate) will be considered. • Evaluate blanks (equipment rinsate blanks, field blanks, reagent blanks, method blanks, and extraction blanks) to confirm that contaminants were not detected at the specified detection limits.

6.1 DATA QUALIFICATION

The data will be qualified by the project QA officer (or designee) based upon the level of reportables and the results of evaluating the field and analytical data packages. The possible data qualifiers are outlined below:

R/UR flag: One or more QC parameters grossly exceed control limits; unusable data, may not be used for any purpose.

J flag: Estimated value; one or more QC parameters were outside control limits or the value was detected below the laboratory’s quantitation limit.

U flag: Undetected; the analyte was analyzed for but not detected or the analyte was found in an associated blank but at a concentration less than five times (10 for common laboratory contaminants) the quantitation limit.

UJ flag: Undetected and estimated; the analyte was analyzed but not detected and the quantitation limit is estimated because one or more QC parameters were outside control limits.

D flag: Diluted result; the compound was reanalyzed at a secondary dilution factor. The “D” flag will remain on the value to alert the data user that the value from a secondary dilution was used.

As with laboratory data validation, the qualification of data is based on specifically defined criteria. Samples are evaluated by matrix against the specific class criteria and qualified accordingly. Samples for which analytical data are unacceptable must be replaced by supplemental sampling, until data completeness goals for the sample/matrix are met.

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ATTACHMENT 5-1 Appendix A Quality Assurance Project Plan (QAPP)

ATTACHMENT 5-2 Sampling Container Label

ATTACHMENT 5-3 Chain of Custody Form

ATTACHMENT 5-4 Monitoring Well Construction diagrams

ATTACHMENT 5-5 Groundwater Monitoring Well Location Map

ATTACHMENT 5.6

Groundwater Protection Standard

Constituent MCL

Di(2-ethylhexyl)phthalate (DEHP) 6.0 ppb

ATTACHMENT 5-6 Groundwater Protection Standard EPA ID Number: TND054876834 Plan Number: TNHW-183

ATTACHMENT 6 - SOLID WASTE MANAGEMENT UNITS AND AREAS OF CONCERN

ATTACHMENT 6 consists of five separate sections as follows:

6.1 SUMMARY TABLES OF REQUIREMENTS FOR SWMUS AND AOCS

6.2 RCRA FACILITY INVESTIGATION (RFI) OUTLINE

6.3 CORRECTIVE MEASURES STUDY (CMS) OUTLINE

6.4 CORRECTIVE ACTION SCHEDULE OF COMPLIANCE

6.5 CORRECTIVE ACTION REMEDIES

Figure 6.1 SWMU Location Map

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ATTACHMENT 6.1 SUMMARY TABLES OF REQUIREMENTS FOR SWMUS AND AOCS

SWMU-2 Railcar Oils are conveyed to and from railcars during the 1971 to present Loading/Unloading loading/unloading process. Any materials spilled – Track 3 during unloading would be captured by a spill pan located under the railcar. The pan drains through a concrete channel located north of the pan, into Track #4’s 30,000-gallon concrete sump. No waste managed. SWMU-3 Railcar Oils are conveyed to and from railcars during the 1971 to present Loading/Unloading loading/unloading process. If a railcar were to leak or – Track 4 rupture, the liquid would be captured by the catch pans located on the track. These pans would channel the liquid flow to an underground pipe that drains into the containment area. No waste managed. SWMU-4 Railcar Oils are conveyed to and from railcars during the 1991 to present Loading/Unloading loading/unloading process. If a railcar were to leak or – Track 5 rupture, the liquid would be captured by the catch pans located on the track. These pans would channel the liquid flow to an underground pipe that drains into the containment area. No waste managed. SWMU-5 Tank Farm 2 & 3 Most of the tanks in these tank farms store liquid 1978 to present plasticizers or alcohols. Tank Farm 2 – In the event of a tank leak or rupture, the entire contents of the tank can be contained within the dirt berm of the tank farm. Tank Farm 3 – Drains allow liquids to feed by gravity into a 10,000-gallon sump located in the farm. Any spill would be contained within the dirt berm. No waste managed. SWMU-6 Fuel Oil Tanks There are two 50,000-gallon carbon steel (CS) fuel oil 1971 to present storage tanks. Each storage tank has a steel containment wall surrounding the tank. If there were a spill, this wall would serve as secondary containment. No waste managed.

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Table 6.1-1 List of solid waste management units (SWMUs) and areas of concern (AOCs) that require no further action (NFA) under the corrective action conditions at this time SWMU/ SWMU/AOC Dates of Unit Comment and Basis for NFA AOC Name Operation SWMU-7 Storm There are two 50,000-gallon carbon steel (CS) storm 1997 to present water tanks water tanks. The area around the tanks is graded such that it drains to the wastewater treatment area and is contained. Contaminated storm water and process waste water is managed SWMU-8 Rolloff Storage – Process-generated press cake from filter presses in the 1991 to present Track 5 chemical manufacturing area is stored in an open top rolloff container prior to offsite disposal. Press-generated filter press cake waste is managed.

SWMU-9 Wastewater Plant – Filterpress solids generated by the wastewater treatment 2000 to present Rolloff for process are stored in open top roll-off containers prior to Filterpress Solids offsite disposal.

SWMU-10 Storm This concrete basin is used to contain contaminated 1971 to present water Retention stormwater during rain events. Once the rain event has Basin stopped, the stormwater is pumped to the stormwater storage tanks prior to being fed to the onsite wastewater treatment system. SWMU-11 Hazardous Waste Satellite accumulation area for the hazardous waste 1992 to present Area stream. This is a mixed solvent waste stream generated by the onsite analytical lab associated with the chemicals plant, and consists of a 55-gallon drum storage with pallet containment. The area is paved and is located outside. The area is sloped to a concrete containment basin. SWMU-12 Maintenance Waste Accumulation area for used oil from throughout the plant. 1971 to present Oil Area The oil is typically transferred from drums to a storage tank. The material is sold for reprocessing. The paved storage area is located outside and is sloped to a concrete containment basin. SWMU-13 Nylon Waste Area Accumulation area for waste material from the nylon 1985 to present process. This waste stream contains caprolactam. The material is stored in totes and is placed in the containment area. The totes are removed from the containment area and are transferred to a vacuum truck that transports the material for off-site disposal. SWMU-14 Nylon Extruder Accumulation area for materials that are condensed from 2007 to present Exhaust Area the nylon extruder exhaust stack. This waste stream contains caprolactam. The paved storage area is located outside and secondary containment is provided by a 6” curb that surrounds the area. Released material would flow to a sump contained in the containment area.

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Table 6.1-2 List of solid waste management units (SWMUs) and areas of concern (AOCs) that require Confirmatory Sampling (CS)

As of Plan issuance, there are no units identified that require Confirmatory Sampling in accordance with the Specific Conditions For Corrective Action section of this attachment.

Table 6.1-3 List of solid waste management units (SWMUs) and areas of concern (AOCs) that require a RCRA Facility Investigation (RFI)

As of Plan issuance, there are no units identified that require RCRA Facility Investigation in accordance with the Specific Conditions For Corrective Action section of this attachment.

Table 6.1-4 List of solid waste management units (SWMUs) and areas of concern (AOCs) that require implementation of Interim Measures (IM) SWMU/A Dates of SWMU/ AOC Unit Comments OC Name Operation AOC-A Landfarm Outside treatment area for soil generated during the 2009 to present Area remediation of Tank Farm 1. Stormwater is collected and pumped to containment prior to being treated in the wastewater treatment system. Interim Measures was approved on May 6, 2019 for the use of BOS 200 as a soil amendment to enhance degradation of the DEHP. To determine effectiveness of the remediation, samples of the soil were to be collected approximately nine months after implementation of the IM at AOC-A.

Table 6.1-5 List of solid waste management units (SWMUs) and areas of concern (AOCs) that require a Corrective Measures Study (CMS)

As of Plan issuance, there are no units identified that require a Corrective Measures Study in accordance with the Specific Conditions For Corrective Action section of this attachment.

Table 6.1-6 List of solid waste management units (SWMUs) and areas of concern (AOCs) that require implementation of a Corrective Action Remedy As of Plan issuance, there are no units identified that require a Corrective Action Remedy in accordance with the Specific Conditions For Corrective Action section of this attachment.

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Table 6.1-7 List of solid waste management units (SWMUs) and areas of concern (AOCs) that are being addressed by another program SWMU/A Dates of SWMU/ AOC Unit Comments OC Name Operation SWMU-15 Tank Farm Landfill under Tank Farm 1 contains soil contaminated with 1973 to present 1 Hazardous Bis(2-ethylhexyl)phthalate (DEHP) from sumps that Waste collected spills that leaked into soil underlying the tank farm Landfill during loading and unloading. An attempt to clean up the contamination under the site failed, resulting in a Post- Closure Unit regulated by this Post-Closure Plan

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ATTACHMENT 6.2 RCRA FACILITY INVESTIGATION (RFI) OUTLINE

The purpose of the RCRA Facility Investigation portion of the RCRA corrective action process is to evaluate the nature and extent of releases of hazardous wastes and/or hazardous constituents and to gather necessary data to support the Corrective Measures Study (CMS) and/or Interim Measures. Planning for the investigation is best accomplished through a logical progression of tasks:

• Gather information on the source of the release(s) to the environment (Source Characterization); • Gather information on the physical aspects of the environment and surrounding receptors which will affect the migration and fate of the release and identification of exposure pathways for both humans and non-human members of the environment (Environmental Setting); and • Use the Source Characterization and Environmental Setting to develop a conceptual model of the release which will be used to plan and conduct a program to define the nature, rate and extent of the release (Sampling and Analysis Plan). An RFI Work Plan and RFI Report are generally required elements of the RCRA corrective action process. The requirements for a full, detailed RFI are listed in this attachment. The Tennessee Department of Environment and Conservation (the Department) recognizes that each facility is unique. Therefore, the scope and requirements of the RFI shall be focused to fit the complexity of the site-specific situation. The work plan requirements listed in this attachment in no way limit the site-specific opportunities for the facility. For example, the RFI may be implemented in phases. Relevant information contained in previously developed documents, such as a RCRA Part B Plan application, may be referenced as appropriate, but must be summarized in either the RFI Work Plan or the RFI Report. In addition, the Department understands that Risk Assessments are becoming more widely utilized to place characterization information into context and to aid in determining remedial solutions. If a Risk Assessment is expected to be performed in the future, note that the U.S. Environmental Protection Agency (EPA) Region 4, has developed a series of Risk Bulletins to provide the facility and their contractors with the general format and process the Department expects a Risk Assessment to follow. Additionally, EPA has developed guidance for the use of generic regional screening levels (RSLs) for most hazardous constituents of concern to enable simple risk evaluations through comparisons with the actual release concentration measured in the soil or water at the facility solid waste management units (SWMUs) and areas of concern (AOCs). These generic RSLs are conservative health-based concentrations of hazardous constituents determined to be risk indicators for the protection of human health or the environment. The most current User’s Guide and Table of Regional Screening Levels can be found at the EPA Region 3 web site: epa.gov/reg3hwmd/risk/human/rb-concentration_table/index.htm. EPA Region 4 recommends

A6-6 use of these generic RSLs as guidance for both Superfund and RCRA sites. For several frequently detected industrial contaminants (lead, arsenic, PAHs, PCBs, dioxins, etc.), EPA has also developed risk-based cleanup levels for both residential and industrial land use scenarios. approach may be appropriate in the following types of situations, among others: facilities where removal remedies have been proposed by the owner/operator, facilities with straightforward remedial solutions or where presumptive remedies can be applied, facilities where few remedial options are available, and facilities where the remedy is phased. TDEC will determine on a case- by-case basis if a concurrent RFI/CMS is appropriate. Because of the unique data collection requirements necessary for a remedial solution which includes natural attenuation of contaminants in groundwater, if natural attenuation is expected to be part of the remedial solution, then the Sampling and Analysis Plan should be crafted to include monitoring of specific water quality parameters unique to natural attenuation (e.g., nitrites/nitrates, ferrous iron, sulfides, dissolved oxygen, methane, hydrogen, etc.).

I. RFI WORK PLAN REQUIREMENTS - ELEMENTS OF THE RFI WORK PLAN

The RFI Work Plan shall include, at a minimum, the following elements:

A. Introduction - Summary of any relevant existing assessment data

The facility shall describe the purpose or objective of the RFI Work Plan and provide a summary of any existing environmental data which is relevant to the investigation. The summary should provide the following items, at a minimum:

1. Land ownership history;

2. Facility operating dates;

3. Facility’s product(s);

4. Raw materials used in facility operations and wastes generated;

5. Nature and extent of any known contamination; and

6. Summary of any ongoing Interim Measures and past assessments.

B. Environmental Setting

The facility shall provide information on the environmental setting at the facility. The facility shall characterize the Environmental Setting as it relates to identified sources, pathways and areas of releases of hazardous constituents from Solid Waste Management Units (SWMUs) and/or Areas of Concern (AOCs). Data gaps pertinent to characterization of releases shall be identified and provisions made in subsection I.E of this attachment to obtain the relevant information to fill the data gap. The Environmental Setting shall cover the following items, at a minimum:

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1. Hydrogeology

The facility shall provide a summary of the hydrogeologic conditions at the facility. This discussion shall include, but not be limited to, the following information:

a. A description of the regional and facility specific geologic and hydrogeologic characteristics affecting ground-water flow beneath the facility, including:

i) Regional and facility specific stratigraphy: description of strata including strike and dip, identification of stratigraphic contacts;

ii) Structural geology: description of local and regional structural features (e.g., folding, faulting, tilting, jointing, metamorphic foliation, etc.);

iii) Depositional history;

iv) Regional and facility specific ground-water flow patterns (porous media, fracture media, karst media); and

v) Identification and characterization of areas and amounts of recharge and discharge (springs in karst terrane, base level streams and rivers).

b. An analysis of any topographic features that might influence the ground-water flow system (e.g., sinkholes and sinking streams in karst terranes).

c. Based on any existing field data, tests (e.g., pump tests, tracer tests), and cores, a representative and accurate classification and description of the hydrogeologic units which may be part of the migration pathways at the facility (i.e., the aquifers and any intervening saturated and unsaturated units), including:

i) Hydraulic conductivity and porosity (total and effective), groundwater flow velocity and groundwater basin discharge;

ii) Lithology, grain size, sorting, and cementation;

iii) An interpretation of hydraulic interconnections between saturated zones (i.e., aquifers) and surface waters; and

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iv) The attenuation capacity and mechanisms of the natural earth materials (e.g., ion exchange capacity, organic carbon content, mineral content, etc.).

d. Based on data obtained from groundwater monitoring wells and piezometers installed upgradient, water wells and/or springs downgradient of the potential contaminant source, a representative description of water level or fluid pressure monitoring including:

i) Water level contour and/or potentiometric maps, including seasonal variations;

ii) Hydrologic cross sections showing gradients;

iii) The flow system, including the vertical and horizontal components of flow; and

iv) Any temporal changes in hydraulic gradients, for example, due to tidal or seasonal influences and for karst terrane, storm flow.

e. A description of man-made influences that may affect the hydrology of the site, identifying:

i) Local water supply and production wells with an approximate schedule of pumping; and

ii) Man-made hydraulic structures (pipelines, french drains, ditches, roofs, runways, parking lots, etc.).

2. Soils

The facility shall provide an explanation of the soil and rock units above the water table in the vicinity of contaminant release(s). This summary may include, but not be limited to, the following types of information as appropriate:

a. Surface soil distribution;

b. Soil profile, including ASTM classification of soils;

c. Transects of soil stratigraphy;

d. Hydraulic conductivity (saturated and unsaturated);

e. Relative permeability;

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f. Bulk density;

g. Porosity;

h. Soil sorption capacity;

i. Cation exchange capacity (CEC);

j. Soil organic content;

k. Soil pH;

l. Particle size distribution;

m. Depth of water table;

n. Moisture content;

o. Effect of stratification on unsaturated flow;

p. Infiltration;

q. Evapotranspiration;

r. Storage capacity;

s. Vertical flow rate; and

t. Mineral content.

3. Surface Water and Sediment

The facility shall provide a description of the surface water bodies in the vicinity of the facility. This summary may include, but not be limited to, the following activities and information:

a. Description of the temporal and permanent surface water bodies including:

i) For lakes and estuaries: location, elevation, surface area, inflow, outflow, depth, temperature stratification, and volume;

ii) For impoundments: location, elevation, surface area, depth, volume, freeboard, and construction and purpose;

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iii) For streams, ditches, and channels: location, elevation, flow, velocity, depth, width, seasonal fluctuations, flooding tendencies (i.e., 100 year event), discharge point(s), and general contents;

iv) Drainage patterns; and

v) Evapotranspiration.

b. Description of the chemistry of the natural surface water and sediments. This includes determining the pH, total dissolved solids, total suspended solids, biological oxygen demand, alkalinity, conductivity, dissolved oxygen profiles, nutrients, chemical oxygen demand, total organic carbon, specific contaminant concentrations, etc.

c. Description of sediment characteristics including:

i) Deposition area;

ii) Thickness profile; and

iii) Physical and chemical parameters (e.g., grain size, density, organic carbon content, ion exchange capacity, pH, etc.)

4. Air

The facility shall provide information characterizing the climate in the vicinity of the facility. Such information may include, but not limited to:

a. A description of the following parameters:

i) Annual and monthly rainfall averages;

ii) Monthly temperature averages and extremes;

iii) Wind speed and direction;

iv) Relative humidity/dew point;

v) Atmospheric pressure;

vi) Evaporation data;

vii) Development of inversions; and

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viii) Climate extremes that have been known to occur in the vicinity of the facility, including frequency of occurrence (i.e., Hurricanes).

b. A description of topographic and man-made features which affect air flow and emission patterns, including:

i) Ridges, hills or mountain areas;

ii) Canyons or valleys;

iii) Surface water bodies, e.g., rivers, lakes, or bays; and

iv) Buildings.

C. Source Characterization

For those sources from which releases of hazardous constituents have been detected, the facility shall provide analytical data to completely characterize the wastes and the areas where wastes have been placed, to the degree that is possible without undue safety risks, including: type; quantity; physical form; disposition (containment or nature of deposits); and facility characteristics affecting release (e.g., facility security, and engineering barriers). Data gaps on source characterization shall be identified and provisions made in subsection I.E of this attachment to obtain the relevant information to fill the data gap. This summary shall include quantification of the following specific characteristics at each source area:

1. Unit/Disposal Area Characteristics:

a. Location of unit/disposal area;

b. Type of unit/disposal area;

c. Design features;

d. Operating practices (past and present);

e. Period of operation;

f. Age of unit/disposal area;

g. General physical conditions; and

h. Method used to close the unit/disposal area.

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2. Waste Characteristics:

a. Type of wastes placed in the unit:

i) Hazardous classification (e.g., flammable, reactive, corrosive, oxidizing or reducing agent);

ii) Quantity; and

iii) Chemical composition.

b. Physical and chemical characteristics such as:

i) Physical form (solid, liquid, gas);

ii) Physical description (e.g., powder, oily sludge);

iii) Temperature;

iv) pH;

v) General chemical class (e.g., acid, base, solvent);

vi) Molecular weight;

vii) Density;

viii) Boiling point;

ix) Viscosity;

x) Solubility in water;

xi) Cohesiveness of the waste; and

xii) Vapor pressure.

c. Migration and dispersal characteristics of the waste such as:

i) Sorption capability;

ii) Biodegradability, bioconcentration, and biotransformation;

iii) Photodegradation rates;

iv) Hydrolysis rates; and

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v) Chemical transformations.

D. Potential Receptors

The facility shall provide data describing the human populations and environmental systems that are susceptible to contaminant exposure from the facility. Data gaps pertinent to receptor analysis shall be identified and provisions made in subsection I.E of this attachment to obtain the relevant information to fill the data gap. The following characteristics shall be identified at a minimum:

1. Current local uses and planned future uses of groundwater:

a. Type of use (e.g., drinking water source: municipal or residential, agricultural, domestic/non-potable, and industrial); and

b. Location of groundwater users to include withdrawal and discharge wells and springs within one mile of the impacted area.

The above information should also indicate the aquifer or hydrogeologic unit used and/or impacted for each item.

2. Current local uses and planned future uses of surface waters directly impacted by the facility:

a. Domestic and municipal (e.g., potable and lawn/gardening watering);

b. Recreational (e.g., swimming, fishing);

c. Agricultural;

d. Industrial; and

e. Environmental (e.g., fish and wildlife propagation).

3. Human use of or access to the facility and adjacent lands, including but not limited to:

a. Recreation;

b. Hunting;

c. Residential;

d. Commercial; and

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e. Relationship of population locations and prevailing wind direction.

4. A general description of the biota in surface water bodies on, adjacent to, or affected by the facility.

5. A general description of the ecology within the area adjacent to the facility.

6. A general demographic profile of the people who use and have access to the facility and adjacent land, including, but not limited to: age; sex; and sensitive subgroups.

7. A description of any known or documented endangered or threatened species near the facility.

E. Sampling and Analysis Plan(s) for Characterization of Releases of Hazardous Waste/Hazardous Constituents

The facility shall prepare a plan to document all monitoring procedures necessary to characterize the extent, fate and transport of releases (i.e., identify sample locations, sample procedures and sample analysis to be performed during the investigation to characterize the environmental setting, source, and releases of hazardous constituents, so as to ensure that all information and data are valid and properly documented). The sampling strategy and procedures shall be in accordance with the most recent version of Environmental Protection Agency, Region 4, SESD’s Field Branches Quality System and Technical Procedures, which can be found online at www.epa.gov/region4/sesd/fbqstp, or an equivalent method approved by the Commissioner.

The Sampling and Analysis Plan must specifically discuss the following unless a particular procedure in the Field Branches Quality System and Technical Procedure is directly referenced:

1. Sampling Strategy

a. Selecting appropriate sampling locations, depths, etc.;

b. Obtaining all necessary ancillary data;

c. Determining conditions under which sampling should be conducted;

d. Determining which media are to be sampled (e.g., groundwater, air, soil, sediment, subsurface gas);

e. Determining which parameters are to be measured and where;

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f. Selecting the frequency of sampling and length of sampling period; and

g. Selecting the types of samples (e.g., composite vs. grab) and number of samples to be collected.

2. Sampling Procedures

a. Documenting field sampling operations and procedures, including:

i) Documentation of procedures for preparation of reagents or supplies which become an integral part of the sample (e.g., filters, preservatives, and absorbing reagents);

ii) Procedures and forms for recording the exact location and specific considerations associated with sample acquisition;

iii) Documentation of specific sample preservation method;

iv) Calibration of field instruments;

v) Submission of appropriate blanks (e.g., field, equipment, trip, etc.);

vi) Potential interferences present at the facility;

vii) Construction materials and techniques, associated with monitoring wells and piezometers;

viii) Field equipment listing and sampling containers;

ix) Sampling order; and

x) Decontamination procedures.

b. Selecting appropriate sample containers;

c. Sampling preservation; and

d. Chain-of-custody, including:

i) Standardized field tracking reporting forms to establish sample custody in the field prior to shipment;

ii) Pre-prepared sample labels containing all information necessary for effective sample tracking; and

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iii) Chain-of-custody seals for sample containers and shipping coolers.

3. Sample Analysis

Sample analysis shall be conducted in accordance with the most recent edition of Test Methods for Evaluating Solid Waste - Physical/Chemical Methods, SW-846 or an alternate Department-approved method. The sample analysis section of the Sampling and Analysis Plan shall specify the following:

a. Chain-of-custody procedures, including:

i) Identification of a responsible party to act as sampling custodian at the laboratory facility authorized to sign for incoming field samples, obtain documents of shipment, and verify the data entered onto the sample custody records;

ii) Provision for a laboratory sample custody log consisting of serially numbered standard lab tracking report sheets; and

iii) Specification of laboratory sample custody procedures for sample handling, storage, and dispersement for analysis.

b. Sample storage (e.g., maximum holding times for constituents);

c. Sample preparation methods;

d. Analytical Procedures, including:

i) Scope and application of the procedure;

ii) Sample matrix;

iii) Potential interferences;

iv) Precision and accuracy of the methodology; and

v) Method Detection Limits; and

vi) Practical Quantitative Limits

e. Calibration procedures and frequency;

f. Data reduction, validation and reporting;

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g. Internal quality control checks, laboratory performance and systems audits and frequency, including:

i) Method blank(s);

ii) Laboratory control sample(s);

iii) Calibration check sample(s);

iv) Replicate sample(s);

v) Matrix spiked sample(s);

vi) "Blind" quality control sample(s);

vii) Control charts;

viii) Surrogate samples;

ix) Zero and span gases; and

x) Reagent quality control checks.

h. External quality control checks by the Department, including:

i) Spikes and blanks at sampling events for which the Department or its technical representative provides oversight; and

ii) The equivalent of a Contract Laboratory Program CLP data package for samples split with the Department or for which the Department specifically requests the package.

i. Preventive maintenance procedures and schedules;

j. Corrective action (for laboratory problems); and

k. Turnaround time.

F. Data Management Plan

The facility shall develop and initiate a Data Management Plan to document and track investigation data and results. This plan shall identify and set up data documentation materials and procedures, project file requirements, and project-related progress reporting procedures and documents. The plan shall also

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1. Data Record

The data record shall include the following:

a. Unique sample or field measurement code;

b. Sampling or field measurement location and sample or measurement type;

c. Sampling or field measurement raw data;

d. Laboratory analysis ID number;

e. Property or component measures; and

f. Result of analysis (e.g. concentration, data qualifiers).

2. Tabular Displays

The following data shall be presented in tabular displays:

a. Unsorted (raw) data;

b. Results for each medium or for each constituent monitored;

c. Data reduction for statistical analysis, as appropriate;

d. Sorting of data by potential stratification factors (e.g., location, soil layer, topography); and

e. Summary data.

3. Graphical Displays

The following data shall be presented in graphical formats (e.g., bar graphs, line graphs, area or plan maps, isopleth plots, cross-sectional plots or transects, three dimensional graphs, etc.):

a. Display sampling location and sampling grid;

b. Indicate boundaries of sampling area and area where more data are required;

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c. Display geographical extent of contamination, both horizontally and vertically;

d. Illustrate changes in concentration in relation to distances from the source, time, depth or other parameters; and

e. Indicate features affecting intermedia transport and show potential receptors.

G. Project Management Plan - Schedule of Implementation

The facility shall prepare a Project Management Plan which will cover qualifications of personnel categories and the management control structure for the project. The facility shall also provide a schedule for completing the planned RFI activities. The schedule shall be as specific as possible (i.e., it should indicate the number of days/weeks/months required for each major work plan task).

II. RFI REPORT REQUIREMENTS - ELEMENTS OF THE RFI REPORT

The RFI Report shall include, at a minimum, the following elements:

A. Introduction

The facility shall describe the purpose of the RFI Work Plan and provide a summary description of the project.

B. Environmental Setting

The facility shall describe the Environmental Setting in and around the facility. The RFI Work Plan should contain some, if not all, of the information on the Environmental Setting. Any information collected during work plan implementation which clarifies or improves understanding of the Environmental Setting should be provided in this section.

C. Source Characterization

The facility shall summarize the sources of contamination and nature of releases identified at the facility. The RCRA Facility Assessment and the RFI Work Plan should contain some, if not all, of the information on Source Characterization. Any information collected during work plan implementation or obtained from the sources (e.g., voluntarily or from other Environmental Programs) which directly addresses Source Characterization should be provided in this section.

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D. Sampling and Analysis Results

The facility shall present data results obtained pursuant to the RFI Work Plan. The facility shall identify any work plan proposals which were not completed and explain why such actions were not finished. The facility shall also present its analysis/interpretation of how the sampling data meet the RFI objective and how the sampling data fits or modifies the contaminant conceptual model. For all analytical data, the facility shall discuss the results of data quality/data review.

E. Data Quality Assurance/Data Quality Data Review The facility shall perform a Quality Assurance/Quality Control data review on all data in the RFI. The Quality Assurance/Quality Control data review shall be in accordance with the U.S. EPA Contract Laboratory Program National Functional Guidelines for Inorganic Data Review (EPA-540/R94-013) and the U.S. EPA Contract Laboratory Program National Functional Guidelines for Organic Data Review (EPA-540/R94-012). The data review shall address at least the following: 1. Holding times; 2. Blanks; 3. Laboratory Control Samples; 4. Field Duplicates; 5. Surrogate Recoveries; 6. Matrix Spike/Matrix Spike Duplicates; and 7. Data Assessment - Data Usability. F. Conclusions

The facility shall summarize the major conclusions reached after analysis of the environmental setting, source characterization, sampling and analysis results and data quality. Any data gaps needed to complete characterization of the scope and extent of the releases from SWMUs and/or AOCs or to refine further the contaminant conceptual model, shall be identified and recommendations made in the Recommendations section of the report.

G. Recommendations

The facility shall provide its recommendations on what, if any, further action is needed to complete the characterization of release(s) from SWMUs and/or AOCs.

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H. Work Plan for Additional Investigations

If further investigations are determined to be needed to complete the objective of the RFI, then the facility shall provide a work plan to complete characterization of the release(s).

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ATTACHMENT 6.3 CORRECTIVE MEASURES STUDY (CMS) OUTLINE

The purpose of the CMS portion of the hazardous waste (RCRA) corrective action process is to identify and evaluate potential remedial alternatives for the releases of hazardous constituents that have been identified at the facility through the RCRA Facility Investigation or other investigations that need further evaluation. The scope and requirements of the CMS are balanced with the expeditious initiation of remedies and rapid restoration of contaminated media. The scope and requirements of the CMS should be focused to fit the complexity of the site-specific situation. It is anticipated that with sites with complex environmental problems, it may be necessary to evaluate a number of technologies and corrective measure alternatives. For other facilities, however, the evaluation of a single corrective measure alternative may be adequate. Therefore, a streamlined or focused approach to the CMS may be initiated. Information gathered during any stabilizations or interim measures will be used to augment the CMS and in cases where corrective action goals are met, may be a substitute for the final CMS.

The requirements for a full, detailed CMS are listed below. The Tennessee Department Environment and Conservation (TDEC) has the flexibility not to require sections of the study, where site-specific situations indicate that all requirements are not necessary. Additionally, TDEC may require additional studies besides these discussed in order to support the CMS. The detail of a CMS may vary based upon the complexity of the site, on-going Interim Measures, established presumptive remedies, etc. However, the CMS Report should include at least the following elements:

I. CMS INTRODUCTION/PURPOSE

The facility shall describe the purpose of the CMS Report and provide a summary description of the project.

II. DESCRIPTION OF CURRENT SITUATION

The facility shall submit a summary and an update to the information describing the current situation at the facility and the known nature and extent of the contamination as documented by the RFI Report. This discussion should concentrate on those issues which could significantly affect the evaluation and selection of the corrective measures alternative(s). The facility shall provide an update to information presented in the RFI regarding previous response activities and interim measures which have or are being implemented at the facility. The facility shall also make a facility-specific statement of the purpose for the response, based on the results of the RFI. The statement of purpose should identify the actual or potential exposure pathways that should be addressed by corrective measures.

III. ESTABLISHMENT OF PROPOSED CLEANUP STANDARDS

The facility shall describe the proposed media cleanup standards and point of compliance. The standards must be background, promulgated federal and state standards or risk-derived standards. If media cleanup standards are not proposed, then TDEC will

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unilaterally propose setting media cleanup standards to either background, promulgated federal and state standards, or the most conservative risk-derived standards.

IV. IDENTIFICATION, SCREENING AND DEVELOPMENT OF TECHNOLOGIES

A. Identification: List and briefly describe potentially applicable technologies for each affected media that may be used to achieve the corrective action objectives. Include a table that summarizes the available technologies.

The facility should consider innovative treatment technologies, especially in situations where there are a limited number of applicable corrective measure technologies.

B. Screening: The facility shall screen the corrective measure technologies to eliminate those that may prove infeasible to implement, that rely on technologies unlikely to perform satisfactorily or reliably, or that do not achieve the corrective measure objective within a reasonable time period. This screening process focuses on eliminating those technologies which have severe limitations for a given set of waste and site-specific conditions. The screening step may also eliminate technologies based on inherent technology limitations. Site, waste, and technology characteristics which are used to screen inapplicable technologies are described in more detail below:

1. Site Characteristics: Site data should be reviewed to identify conditions that may limit or promote the use of certain technologies. Technologies whose use is clearly precluded by site characteristics should be eliminated from further consideration.

2. Waste Characteristics: Identification of waste characteristics that limit the effectiveness or feasibility of technologies is an important part of the screening process. Technologies clearly limited by these waste characteristics should be eliminated from consideration. Waste characteristics particularly affect the feasibility of in-situ methods, direct treatment methods, and land disposal (on/off-site).

3. Technology Limitations: During the screening process, the level of technology development, performance record, and inherent construction, operation and maintenance problems should be identified for each technology considered. Technologies that are unreliable, perform poorly, or are not fully demonstrated may be eliminated in the screening process. For example, certain treatment methods have been developed to a point where they can be implemented in the field without extensive technology transfer or development.

C. Corrective Measure Development: The facility shall assemble the technologies that pass the screening step into specific alternatives that have the potential to meet the corrective action objectives for each media. Options for addressing less complex sites could be relatively straight-forward and may only require A6-24

evaluation of a single or limited number of alternatives. Each alternative may consist of an individual technology or a combination used in sequence (i.e., treatment train). Different alternatives may be considered for separate areas of the facility, as appropriate. List and briefly describe each corrective measure alternative.

V. EVALUATION OF FINAL CORRECTIVE MEASURE ALTERNATIVES

In evaluating the selected alternatives (i.e., those that passed through the screening step, including those situations when only one remedy is being proposed), the facility shall prepare and submit information that documents that each remedy will meet specific cleanup criteria. Using the guidance below, The facility shall provide detailed documentation of how all selected alternatives will comply with each of the following standards:

A. Protect Human Health and the Environment

Corrective action remedies must be protective of human health and the environment. Remedies may include those measures that are needed to be protective, but are not directly related to media cleanup, source control or management of wastes. An example would be a requirement to provide alternative drinking water supplies in order to prevent exposures to releases from an aquifer used for drinking water purposes. Therefore, the facility shall provide a discussion of any short term remedies necessary to meet this standard, as well as discuss how the corrective measures alternative(s) meet this standard.

B. Attain Media Cleanup Standards

Remedies will be required to attain media cleanup standards. As part of the necessary information for satisfying this requirement, the facility shall address whether the potential remedy will achieve the remediation objectives. An estimate of the time frame necessary to achieve the goals shall be included. Contingent remedies may be proposed if there is doubt if the initial remedy will be successful (e.g., contingent remedies to innovative technologies).

C. Control of Sources of Releases

The facility shall address the issue of whether source control measures are necessary, and if so, the type of actions that would be appropriate. Any source control measure proposed should include a discussion on how well the method is anticipated to work given the particular situation at the facility and the known track record of the specific technology.

D. Comply with any Applicable Standards for Management of Wastes

The facility shall include a discussion of how the specific waste management activities will be conducted in compliance with all applicable state and federal regulations [e.g., closure requirements, Land Disposal Restrictions (LDRs)]. A6-25

E. Other Factors

There are six general factors that will be considered as appropriate by TDEC in selecting/approving a remedy that meets the four standards listed above. The six decision factors and examples of the types of information to include in the CMS alternative evaluation are:

1. Long-term reliability and effectiveness: The facility may consider whether the technology, or combination of technologies, have been used effectively under analogous site conditions, whether failure of any one technology in the alternative would have any immediate impact on receptors, and whether the alternative would have the flexibility to deal with uncontrollable changes at the site. Operation and maintenance requirements include the frequency and complexity of necessary operation and maintenance. In addition, each corrective measure alternative should be evaluated in terms of the projected useful life of the overall alternative and of its component technologies. Useful life is defined as the length of time the target level of effectiveness can be maintained.

2. Reduction in the toxicity, mobility or volume of wastes: As a general goal, remedies will be preferred that employ techniques that are capable of eliminating or substantially reducing the potential for the wastes in SWMUs and/or contaminated media at the facility to cause future environmental releases. Estimates of how the corrective measure alternative will reduce toxicity, mobility and or volume of the waste is required and may be accomplished through a comparison of initial site conditions to expected post-corrective measures conditions.

3. Short-term effectiveness: The facility shall evaluate each corrective measure alternative for short-term effectiveness. Possible factors to consider are fire, explosion, exposure to hazardous constituents and potential threats associated with the treatment, excavation, transportation and re-disposal or containment of the waste material.

4. Implementability: Information to consider when assessing implementability include:

a. The administrative activities needed to implement the corrective measure alternative (e.g. permits, rights of way, etc.) and the length of time these activities will take;

b. The constructability, time for implementation, and time for beneficial results;

c. The availability of adequate off-site treatment, storage capacity, disposal services, needed technical services and materials; and

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d. The availability of prospective technologies for each corrective measure alternative.

5. Cost: The facility shall develop an estimate of the cost of each corrective measure alternative (and for each phase or segment of the alternative). The cost estimate shall include both capital and operation and maintenance costs. The capital costs shall include, but are not limited to, costs for: engineering, site preparation, construction, materials, labor, sampling and analysis, waste management and disposal, permitting, health and safety measures, etc. The operation and maintenance costs shall include labor, training, sampling and analysis, site security, inspections, maintenance materials, utilities, waste disposal and/or treatment, etc. The corrective action cost estimate shall be based on the costs to Teknor Apex of hiring a third party to conduct corrective action activities and shall include all direct costs and also all indirect costs, including contingencies. A third party is a party who is neither a parent nor a subsidiary of Teknor Apex. Costs shall be calculated as the net present value of the capital and operation and maintenance costs.

6. Community Acceptance: Keep interested members of the public informed of all corrective action activities taking place at the facility. Evaluate remedies based on the degree to which they are acceptable to the interested community.

VI. CORRECTIVE MEASURES JUSTIFICATION AND RECOMMENDATION

The facility shall justify and recommend in the CMS Report a corrective measure alternative for consideration by TDEC. Such a recommendation should include a description and supporting rationale for the preferred alternative that is consistent with the corrective action standards and remedy selection decision factors discussed above. In addition, this recommendation shall include summary tables which allow the alternative or alternatives to be understood easily. Trade-offs among health risks, environmental effects, and other pertinent factors shall be highlighted. The Commissioner will select the corrective measure alternative or alternatives to be implemented based on the results presented in the CMS Report.

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ATTACHMENT 6.4 CORRECTIVE ACTION SCHEDULE OF COMPLIANCE

Schedule of Compliance Due Date

Notification of Newly Identified SWMUs Within 15 calendar days of discovery and AOCs: Paragraph V.B.1 and V.B.2

SWMU Assessment Report: Within 90 calendar days of notification of newly Paragraph V.B.3 identified SWMU

Notification for Newly Discovered Within 15 calendar days of discovery Releases from SWMUs or AOCs: Paragraph V.C.1

Confirmatory Sampling Work Plan for Within 45 calendar days of notification by the suspected AOCs identified under Commissioner Paragraph V.B.1 or SWMUs identified under Paragraph V.B.4 or Paragraph V.D.1

Implementation of Confirmatory As specified by Commissioner in the CS Work Plan Sampling: Paragraph V.D.3 approval letter

Confirmatory Sampling Report: In accordance with the schedule in the approved CS Paragraph V.D.4 Work Plan

RFI Work Plan for those units identified Within 90 calendar days after receipt of notification under Paragraphs V.B.4, V.C.2, or by the Commissioner which SWMUs or AOCs V.D.5: Subparagraph V.E.1(a) require additional investigation.

Notify to implement RFI Sampling: At least 20 days prior to any RFI sampling activity Paragraph V.E.2

Draft RFI Report: In accordance with the schedule in the approved RFI Subparagraph V.E.3(a) Work Plan

Final RFI Report: Within 30 calendar days after receipt of Subparagraph V.E.3(a) Commissioner’s final comments on Draft RFI Report

RFI Progress Reports: Quarterly, beginning 90 calendar days from the start Subparagraph II.E.3(d) date specified by the Commissioner*

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Schedule of Compliance Due Date

Interim Measures Work Plan: Within 30 calendar days of notification by the Subparagraph V.F.1(a) Commissioner

Interim Measures Report: Within 90 calendar days of completion of Interim Subparagraph V.F.3(b) Measures

Interim Measures Progress Reports: In accordance with the approved Interim Measures Subparagraph V.F.3(a) Work Plan ** or semi-annually for Facility-initiated IM

CMS Work Plan: Within 90 calendar days of notification by the Paragraph V.G.1 Commissioner that a CMS is required

Implementation of CMS Work Plan: No later than 15 calendar days after receipt of the Paragraph V.G.2 Commissioner’s approval of Plan

Draft CMS Report: In acco rdance with the schedule in the approved Paragraph V.G.3 CMS Work Plan

Final CMS Report: Within 30 calendar days of the Commissioner's final Paragraph V.G.4 comments on Draft CMS Report

Noncompliance/Imminent Hazard Oral within 24 hours and written within five Report: Subparagraph I.D.8(e) calendar days of becoming aware of the hazardous circumstances

The above reports must be signed and certified in accordance with Tennessee Hazardous Waste Management Rules 0400-12-01-.07(2)(a)7 through 10.

* This applies to Work Plan execution that requires more than one hundred eighty (180) calendar days.

** This applies to Work Plan execution that requires more than one year.

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ATTACHMENT 6.5 CORRECTIVE ACTION REMEDIES

ATTACHMENT, 6.5 is reserved. At the time of issuance of this Plan, there are 14 SWMUs, SWMU-1 through SWMU-14, that have been determined by a RCRA Facility Assessment to be No Further Actions. One SWMU, SWMU-15, is regulated by this Plan and one AOC, AOC-A, will require remediation through an Interim Measures. Interim Measures will continue until the contaminated soil is remediated to below relevant action levels. Once remediation is complete and soil contamination is below relevant action levels, the facility will modify the Plan with the results of the Interim Measures. If the Interim Measures is successful AOC-A will become No Further Action. If the Interim Measures is unsuccessful then AOC-A will be regulated as a landfill.

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ATTACHMENT 6-1 SWMU and AOC Location MAP

EPA ID Number: TND054876834 Plan Number: TN HWM-183

ATTACHMENT 7 - METHODOLOGY FOR MONITORING WELL ABANDONMENT AND CLOSURE

ATTACHMENT 7.1, The Well Plugging and Abandonment Plan documents the procedures and health and safety requirements necessary to plug and abandon the four monitoring wells surrounding the Post-Closure Landfill.

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ATTACHMENT 7-1 Well Abandonment Plan

ATTACHMENT 7.1 Well Plugging and Abandonment Plan

Teknor Apex Tennessee Company Brownsville, TN EPA ID Number: TND054876834

May 2017

www.erm.com

The business of sustainability Presented on behalf of Teknor Apex – Tennessee Company

Teknor Apex – Tennessee Company Brownsville, TN Well Plugging and Abandonment Plan Tank Farm 1

EPA ID Number TND05476834

May 2017

Jackson Spain Tennessee Registered Professional Geologist

Ben George Project Manager

Phil D. Patey Partner-in-Charge

Environmental Resources Management 5000 Meridian Blvd. Suite 300 Franklin, TN 37067 (615) 656-7100

1.0 INTRODUCTION ...... 2 1.1 SITE LOCATION ...... 2 1.2 BACKGROUND ...... 2 1.3 GEOLOGIC SETTING ...... 2 1.4 HISTORICAL SITE OPERATIONS ...... 3 2.0 FIELD PROCEDURES ...... 4 2.1 WELL ABANDONMENT ...... 4 2.2 RESIDUALS MANAGEMENT...... 4 3.0 REPORTING ...... 5 4.0 HEALTH AND SAFETY ...... 6

1.0 INTRODUCTION

Environmental Resources Management (ERM) has prepared this Well Plugging and Abandonment Plan for groundwater monitoring wells for the Post-Closure Landfill..

This Well Plugging and Abandonment Plan documents the procedures and health and safety requirements necessary to plug and abandon the four monitoring wells.

1.1 SITE LOCATION

The Teknor property consists of approximately 122 acres located at 751 Dupree Street, Brownsville, Haywood County, Tennessee. The Post-Closure Landfill is located east of the main manufacturing building approximately 800-ft east of Dupree Street and 650-ft north of the southern property boundary.

1.2 BACKGROUND

Permanent groundwater monitoring wells were installed surrounding the Post- Closure Landfill. Monitoring wells MW-1, MW-2, and MW-3 were installed in November 2008. MW-1 was installed immediately south of the Post-Closure Landfill; MW-2 was installed immediately northwest of the Post-Closure Landfill; and MW-3 was installed immediately east of the Post-Closure Landfill. A fourth monitoring well, MW-4A, was installed approximately 125-ft southwest of the Post-Closure Landfill (i.e., down-gradient) in August 2015.

The monitoring wells are constructed of 2-inch diameter stainless steel casing with a 10-foot section of 0.010-inch slotted well screen.

1.3 GEOLOGIC SETTING

1.4 HISTORICAL SITE OPERATIONS

2.0 FIELD PROCEDURES

2.1 WELL ABANDONMENT

The wells will be plugged and abandoned in accordance with applicable federal and state regulations. The Division of Solid Waste Management recognizes the well Abandonment Procedures in the EPA SESD Guidance for the Design and Installation of Monitoring wells at:

https://www.epa.gov/sites/production/files/2016- 01/documents/design_and_installation_of_monitoring_wells.pdf

The wells will be abandoned by implementing the following procedures:

• All wells at the Site are flush mount wells. Prior to plugging, the steel manhole cover will be removed and the casing shall be cut off a minimum of six inches below ground level.

• The monitoring well casing shall be filled from bottom to top with a grout mixture consisting of Portland cement and 4%-6% powdered bentonite. A grout density of 13.5 to 14.1 lbs/gal shall be used. The grout shall be placed using a tremie pipe.

• The manhole vault will be filled with concrete and resurfaced to match the surrounding surface.

2.2 RESIDUALS MANAGEMENT

All well-head materials will be removed from the site and disposed of in accordance with applicable federal, state and local regulations.

3.0 REPORTING

In the event one or more monitoring wells at the Teknor facility are to be abandoned, ERM will notify the TDEC of the schedule for field activities at least 30 days prior to mobilization. A Monitoring Well Abandonment Report will be submitted to the TDEC within 30 days of plugging and abandoning the well(s).

4.0 HEALTH AND SAFETY

Well plugging and abandonment activities will be implemented in accordance with the Site-Specific Health and Safety Plan. It is ERM’s policy to conduct all activities in a manner that protects the health and safety of the public and protect personnel. Work will be in accordance with applicable federal, state, and local regulations, including the U.S. Department of Labor, Occupational Safety and Health Administration (OSHA), and the requirements of 29 CFR 1910.