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GOLDMAN ANTONETTI FERRAIUOLI <fe AXTMAYER ATTORNEYS AND COUNSELORS AT LAW POST OFFICE BOX 13486 SAN JUAN. PUERTO RICO OO9O8-3486 VICENTEJ ANTONETTI JOSE E ARRARAS ALVARO C CIFUENTES- JOSE A AXTMAYER* JOSE A CEPEOA RODRIGUEZ BLAS R FERRAIUOLI ROBERTO MONTALVO LUIS F ANTONETTI RICARDO MUNI7" LEONARDO ANORADE LUGO JORGE L MARTINEZ EUGENIC C ROMERO LUIS D ORTIZ ABREU GREGORY T USERA" FRANCISCO A BESOSA" FRANCIS TORRES CARLOS A RODRIGUEZ VIDAL" DANILOM EBOU THELMA RIVERA LABOY JORGE SEGUROLA JUAN H SAAVEDRA CASTRO* COUNMI. MAX GOLDMAN* SANTURCE OFFICE 409 INSURANCE CENTER BUILDING 7O1 PONCE DE LEON AVENUE SANTURCE. PUERTO RICO OO9O7 TELEPHONE (8O9) 721 2424 TELECOPIER (8O9) 721 1796 TELECOPIER (UTK3ATION) (8O9) 722 6571 HATO REV OFFICE SUITE 1420 BANCO POPULAR CENTER HATO REY PUERTO RICO OO918 TELEPHONE (8O9) 759 8OOO TELECOPIER (8O9) 765 8O97 RAMON L VELASCO JORGE F FREYRE— CARLOS F RAMIREZ OE ARELLANO KARIN G DIAZ-TORO FRANCISCO J GARCIA EDGARDO COLON APRARAS JOSE M LORIE VELASCO BRAUUO GARCIA JIMENEZ WILMER J CAMACHO HOWARD PRAVDA MARlA OE LOUROES RODRIGUEZ ROSA M CRUZ-NIEMIEC MIGUEL J ROORIGUEZ MARXUACH CARLOS E COLON FRANC ESC HI MARlA ELENA ORTIZ IVETTE GONZALEZ BUITRAGO p m THI mtfVMLi or COLUMW* '"f>L$O AOMTPTtD M » April 29, 1991 3 "7 V-", '' '^ O^ 7^ • "vi ' • ••rj ••' Ms. Kathleen Callahan, Director . : "•"•' • Emergency and Remedial Response Division •-''•. o U.S. Environmental Protection Agency u' 26 Federal Plaza New York, New York 10278 RE: Request for Information under 42 U.S.C. §9604 Concerning Potential Releases of Hazardous Substance at the ESSO Tutu Service Station in St. Thomas, U.S.V.I. Dear Ms. Callahan: This constitutes ESSO Standard Oil S.A. Limited's ("Esso") response to the Request for Information under 42 U.S.C. §9604 sent by the U.S. Environmental Protection Agency (EPA) on April 4, 1991. Esso was granted an extension until today, April 29, 1991, to submit this response to EPA. This response has been prepared pursuant to all the informa- tion that is and has been made available to Esso until this date. Please note that there are certain documents pertaining to inventories of products handled at the Esso Tutu Service Station by Mr. Daniel Bayard that have not been made available to Esso for the preparation of these responses. Once we are provided with these documents by Mr. Bayard, or if any other pertinent information or document is obtained, we will immediately supplement Esso's response to the Request for Information, if necessary. 24 SO *64492* 64492 GOLDMAN ANTONBTTI FERRAIUOLJ <fe AXTMAYBR -2- REOUEST NO. 1 Here, or are, any hazardous substances ever used, stored, generated, disposed or otherwise handled at the facility, including but not limited to 1,1,1, trichloroethane, trichloroethylene ("TCE"), 1,2 trans-dichloroethylene ("DCE"), tetra-chloroethylene ("PCE"), and methyl-ethyl-ketone ("MEK")? Identify each hazardous substance by providing the name, composition and source of origin of each substance. RESPONSE NO. 1 ESSO has no specific knowledge regarding the use, storage, generation, disposal or handling of hazardous substances at the ESSO Tutu Service Station (hereinafter referred to as "ETSS11). The ETSS, although now owned and operated by ESSO Virgin Islands, Inc., was operated under a lease from 1970 until 1971 by Mr. Robert Dunn, from 1971 until 1978 by Mr. Daniel Bayard, Sr., and from 1978 until 1990 by Mr. Daniel Bayard, Jr. The whereabouts of Mr. Dunn are un- known and Mr. Bayard, Sr., was deceased in 1978, therefore ESSO has been unable to obtain any information and/or documents from the two (2) first operators of the ETSS to prepare this response. As such, Esso has never used, stored, generated, disposed or otherwise handled hazardous substances at the ETSS. We know of no ESSO product that had been marketed at the ETSS which contained the materials specifically listed in the Request No. l. Notwithstand- ing the above, and in attention to a request by EPA dated May 18, 1988, to provide Material Safety Data Sheets (MSDS) of all the cleaning products and solvents used at the ETSS from 1987 on, EPA was provided on August 17, 1988 a copy of the MSDS of the engine cleaner used at the ETSS by Mr. Daniel Bayard in his auto mechanic shop. Copy of the pertinent MSDS, as well as corresponding cover letter, is attached herewith as part of this response. As operator and lessee of the service station from 1978 until 1990, Mr. Bayard is the person with specific knowledge of the materials, including hazardous substances, that may have been used, stored, generated, or handled at the ETSS. According to Mr. Bayard, engine cleaning or degreasing was not a service provided at the ETSS mechanic shop. During the very few occasions in which he recalls that an engine cleaner was used, the particular car was driven to a facility having a steam or pressure cleaning system where the cleaner and the engine grease was removed. i"f OO3 248.1 GOLDMAN ANTONETTI FKRRAIUOLI <fe AXTMAYBR -3- Analytical results of samples obtained by EPA on August 17, 1987 from the oil and water separator at the ETSS showed the presence of certain chlorinated compounds which are listed as hazardous substances. However, ESSO has no specific knowledge regarding the origin, composition or nature of these hazardous substances which were included in EPA's sampling results. Inventory records of Mr. Bayard's operations at the ETSS have not been made available to Esso yet. Once these records are provided and analyzed, ESSO will supplement these responses accordingly. REQUEST MO. 2 For each hazardous substance identified above, please provide an annual summary describing how each such substance was treated, handled, transported, stored and/or disposed of by the facility. Please attach any manifests, invoices and other documentation which relate to the treatment, handling, transportation, storage and/or disposal of each such substance. If you are unable to provide a copy of any such document, please describe the document and explain why it cannot be provided. RESPONSE MO. 2 Esso has no document in its possession which relates to the treatment, handling, transportation, storage and/or disposal of such substances. Please refer to Response No. 1. REQUEST NO. 3 Are, or were, auto mechanic repairs, including oil changes, performed at the ESSO facility? Please describe what type of repairs were performed, if any, and the frequency of such repairs. RESPONSE NO. 3 To the best of our knowledge and belief, Mr. Daniel Bayard, Jr., as lessee of the ETSS conducted auto mechanic repairs and oil changes at the facility. However, ESSO has no specific information with respect to the type of repairs that were performed at the ETSS or the frequency of oil changes performed by Mr. Daniel Bayard. Mr. Bayard has informed ESSO that oil changes were performed at a frequency of 2 to 4 per day. Light mechanical repairs were also performed at the ETSS such as general tune-ups, brakes repairs, and other miscellaneous small repairs, at a frequency of 4 to 6 per day. 248:. GOLDMAN ANTONBTTI FERRAIUOLJ <fe AXTMAYBR -4- REOUEST NO. 4 If the answer to Question 3 above is yes, were any hazardous substances or hazardous wastes generated, treated, stored, disposed of or otherwise handled in the process? Please attach any mani- fests, invoices, and other documentation which relates to this question. If you are unable to provide a copy of any such document, please describe the document and explain why it cannot be provided. RESPONSE MO. 4 ESSO has no specific knowledge of, nor documents which relate to, any hazardous substances or hazardous waste being generated, treated, stored, disposed of or otherwise handled at the ETSS. REQUEST HO. 5 If the answer to Question 3 above is yes, please list and/or describe what kinds of solvents were used. In addition, please describe where and how these solvents were stored at the facility prior to their use, and all disposal practices regarding these solvents. Please attach any manifests, invoices and other docu- mentation which relate to this question. If you are unable to provide a copy of any such document, please describe the document and explain why it cannot be provided. RESPONSE MO. 5 According to the information provided by Mr. Daniel Bayard, engine cleaners and brake cleaners in spray cans were sold at the ETSS. The engine cleaner used at the station's mechanics shop is described in the MSDS attached hereto. The use of these products at the station's mechanics shop did not generate any waste. The spray cans, once empty, were disposed of in the waste basket. We know of no ESSO solvent products that have been marketed at the ETSS. Besides, from the MSDS attached hereto, Esso has no other document which relates to this question. REQUEST NO. 6 If oil changes were conducted at the facility, please give an annual summary explaining how the used oil was disposed of, the quantity disposed of per month and any and all analysis of this used oil. Please provide all appropriate documentation. If any such document is not available, please describe the document and explain why it cannot be provided. GOLDMAN ANTONETTI FBRRAIUOLJ <fe AXTMAYKR -5- RE8PON8B NO. 6 Used oil handling, management and storage practices were con- ducted at the ETSS by Mr. Daniel Bayard who is the person with specific knowledge of those practices. ESSO has knowledge of the common practice of service station operation in the U.S. Virgin Islands to provide the used oil generated at the stations' mechan- ics shops for energy recovery to the Water and Power Authority of the Virgin Islands until such time that the regulations applicable to such operation became effective. ESSO is also aware of off-site disposal by Safety Kleen Envirosystems Company, Inc., of the used oil generated at the service station in the U.S. Virgin Islands, which may include the ETS" According to Mr. Bayard, approximately 75 gallons of used oil were generated at the service station as a result of oil changes. The used oil was removed by gravity into a 5 gallon storage cart with a capture funnel on top. The used oil was then stored at a 2,000 gallon storage tank located at the ETSS. Subsequently, the used oil was removed by the local government (V.I. Department of Energy) for usage at the WAPA power plant. The used oil was also removed and transported off-site for disposal by Safety Kleen Envirosystems, Inc. Mr. Bayard maintains that he has no records of the instances in which the used oil was removed and transported off-site. Nor are there records of analysis, if any, of the used oils. REQUEST NO. 7 Please describe the structure and location of each oil and water separator at the facility, as well as explain the use of each such unit. Include separators which have been removed and/or shut down. Please attach a diagram or drawing of these units, the dates of their use and their location. RESPONSE NO. 7 The only oil and water separator ever operated at the ETSS was constructed in 1986 by EDACO (Eugenio de Arce), an independent contractor. The separator is made of reinforced concrete with a steel cover, and has three (3) compartments designed to separate oils, greases and sludges from the water. A diagram illustrating the location of the separator at the ETSS is attached herewith. The separator is presently out of use since all mechanic shop activities were discontinued in 1990. O03 2484 GOLDMAN ANTONBTTI F*ERRAIUOLI <fe AXTMAYER -6- REQUEST NO. 8 Is there, or has there ever been, any means by which fluids or sludge can escape or be discharged from any oil and water separator (i.e., an open overflow valve or pipe) that presently exists or existed at the facility? RESPONSE NO. 8 In 1986 a pipe was constructed by EDACO to connect the water phase of the separator into a sewer line located in the parking lot of the Four Winds Shopping Center behind the ETSS. Pursuant to the information provided by Mr. Eugenio de Arce of EDACO and Mr. Daniel Bayard, liquids from the oil/water separator were not discharged through this connection as the pipe was immediately eliminated and capped by EDACO. The oil and water separator is designed, constructed and operated to prevent the escape or release of the substances which are stored therein. According to information provided by Mr. Daniel Bayard, there has never been an overflow of liquids at the oil/water separator. The oil from the separator was transferred manually into a used oil storage tank located at the premises and the water was also transferred manually and discharged into the sanitary line. REQUEST NO. 9 If the answer to Question 8 above is yes, has there ever been such a discharge or release? If so, please explain all the details surrounding such a release and submit any related documentation, including analysis. If a document is not available, please describe the document and explain why it cannot be provided. RESPONSE NO. 9 To the best of our knowledge and pursuant to the information provided by Mr. Daniel Bayard and Mr. Eugenio de Arce from EDACO, none. RESPONSE NO. 10 By what means could hazardous substances such as PCE and TCE enter an oil and water separator at the ESSO facility? Please be specific, and explain all possible means. TUT OO:3 2485 GOLDMAN ANTONETTI FERRAIUOLI <fe AXTMAYBR -7- RE8PON8E HO. 10 ESSO has no specific knowledge on the means by which PCE and TCE could have entered the oil and water separator at the ETSS. REQUEST MO. 11 Does, or did, the facility conduct periodic sampling to deter- mine whether hazardous substances have entered the oil and water separators? If so, how often, and on what occasions. Please attach any such analysis. RESPONSE NO. 11 ESSO has not sampled periodically the oil and water separator to determine whether hazardous substances have entered such unit. REQUEST NO. 12 Have the oil and water separators been periodically cleaned out or emptied, either completely or partially? If so, how often and on what occasions. RESPONSE MO. 12 The oil and water separator was cleaned and emptied by Mr. Daniel Bayard almost on a daily basis, pursuant to the procedure referred to in Response No. 8. REQUEST MO. 13 If the answer to Question 12, above is yes, please explain how the removed liquids and/or sludges are handled and disposed of? Please include any sampling procedures and relevant documentation such as analysis, and manifests. If a document is not available, please describe the document and explain why it cannot be provided. RESPONSE NO. 13 Refer to Responses Nos. 6 and 8. Esso has no document in its possession which relates to this question. REQUEST NO. 14 Were, or are, any products (including solvents containing 1, 1,1, trichloroethane, TCE, DCE, PCE and MEK) ever used, stored, generated, disposed or otherwise handled at the facility? If so, identify these products, and explain how were they used, stored 2486 GOLDMAN ANTONBTTI FERRAIUOLJ <fe AXTMAYER -8- and/or disposed of? Please provide any related documents, if a document is not available, please describe the document and explain why it cannot be provided. RESPONSE MO. 14 Not to our knowledge. Refer to Response No. 1. Pursuant to the instructions included in EPA's Request for Information, nor have attached to these responses a "Certification of Answers to Request for Information" duly signed by Ms. Ana Gloria Ramos, Esso's Safety, Industrial Hygiene and Environmental Protection Advisor. Should you have any further question or need any information regarding the matters referred to in these responses, do not hesitate to contact us. Cordially yours, Francis Torres Enclosures cc Amy Chester, Esq. Jose L. Blanco Ana Gloria Ramos Otto Bustelo, Esq. Jose Cepeda-Rodrlguez, Esq. OO3 2487 CENTER PARKIN6 I1 -- —— ___i_: . ' = ? ' : - :"'',.*?.-. .''„:>;/. >.&''' ,••!. fit'-. 1' ,,A' CERTIFICATION OF ANSWERS TO REQUEST FOR INFORMATION Commonwealth of Puerto Rico City of San Juan_________ I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document (response to EPA Request for Information) and all documents submitted herewith, and that based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the submitted information is true, accurate, and complete, and that all documents submitted herewith are complete and authentic unless otherwise indicated. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment. SIGNATURE Ana Gloria Ramos NAME (Print or Type) Safety, Industrial Hygiene and Environmental Protection Advisor JOB TITLE NOTARY PUBLIC Sworn to before me this 29th ' of April . 0 rCENTC J. ANTONETTI x._x<OBERTO MONTALVO JORGE L. MARTI'NEZ ALVARO C.CIFUENTES LUIS r. ANTONETTI RICARDO MUfilZ LEONARDO ANORAOE JOSE A.CEPEDA-ROORI'GUEZ EUGENIO C. ROMERO LUIS D. ORTIZ ABREU COUNSEL MAX GOLDMAN LAW OFFICES GOLDMAN & ANTONETTI INSURANCE CENTER 7OI PONCE DE LEON AVENUE POST OFFICE BOX 13486 SANTUHCE, PUEHTO Rico OO0O8-3486 TELEPHONE: (8O9) 721-3424 CABLE: RIGOSA TELEX: RCA-azszaao* TELECOPIER: 000-721-1706 FANNY AUZ-PATINO CARLOS A. ROORI'GUEZ-VIOAL CORALINA RIVERA THELMA RIVERA-LABOY JORGE SEGUROLA RAM6N L.VELASCO FRANCIS TORRES-FERN/JNDEZ KARIN G. OIAZ-TORO FRANCISCO J. CARCIA EOGAROO COL6N-ARRARAS josf. M. LORIE'-VELASCO MANUEL A. SILVA-ROSAS Ref. 092.007 September 22, 1988 Caroline Kwan Site Compliance Branch U.S. Environmental Protection Agency Region II - Room 737 Federal Plaza New York, N.Y. 10278 Re: Request for Information Under 42 USC 9604, 42 USC 6927, 42, USC 6991(d) Tutu Esso Car Care Center, US Virgin Islands Dear Ms. Kwan: This confirms our telephone conversation of September 22, 1988 regarding the Material Safety Data Sheet (MSDS) of an engine degreaser which was recently provided to us by Mr. Thomas Gutshall, Operation Manager for the Esso Tutu Car Care Center. The enclosed MSDS was provided to us in response to our request to Mr. Daniel Bayard, the service station operator, to ascertain whether other degreasers, having different constituents than the one already reported to EPA in response to the above referred Request for Information, have been used over the years in the Esso Tutu Service Station. The attached MSDS is provided the supplement the response provided by Esso to the Request for Information of reference. Should you have any questions document do' not hesitate to contact us. regarding the attached Cordially yours, Attachment cc: Eng. Ana G. Jose Font Greg Rhymer r , ' * ' * Francis Torres-Fernandez Ramos TUT 003 249O SENT BYiEZCH MEMPHIS TRAFFIC - 9-19-88 11:4CWM ; , ' •' ••'-* " » i UMIM &IGCI rim 9017578443- CCITT Q3;« SECTION I — PRODUCT IDENTIFICATION MASTER CHEMICAL CORPORATION 1900 EXETER ROAD GERMANTOWN, TM - 38138 901-755-5555 • • • ' • • ' " PRODUCT TRADE NAME Oft BRAND NAME EHm.MASTBt EMCMI MCREASER ^^k . MM <• * * * . . ^ _ * . t OTHER PRODUCT DESCRIPTION OR IDENTIFICATION ' __ PETimLHJX HYDROCARBOH FTUKIION SECTION II — IAZAROOyi INORgQIgNTS INGREDIENT CHEMICAL NAME TYPE OP HAZARD*® APPROXMATc WEIGHT % -TLV VALUE Omen iOAK/J * T INFORMATION NO. 1 FUEL OIL ( KEROSENE ) yHBOSTIOl N/A EYE/SKIH IRRIT NOW-IOMIC SURFACTANT KYE/SRIK 2.93 K/A SECTION III — PHYSICAL DATA BOtUNQ POINT A 101.3 kPa fTAOmtn Hat U Not 176 Ns. U Not Appfc«W» WPOR MAXIMUM VOLATU8 Yvs. AIR • 1 130 orirt 2 Hetvfar An 9 1.0 EVAPORATION RATE ilnth i7 % (Wtbht MOOONJZED WATER »10*C/50*PV - 1-10% B > 10% w %byWt. APPEARANCE AND OOOR NAZI » TKAM WIT •nd of tpriy y rMltfiM) tV »- FIRE AND EXPLOSION -HAZARD DATA NotAopiotblt FlAMMABLEUMfTS IN AIR (IW «R ___ (Vol. % A iO«C/68 *n Not A L6L-UEL * E2$T1NGUISHING MEDIA: U Not Appfieibl* (w« Mttium tMk>w B15*C/1,600*F) Water Fog Jp stmdtrd FOMI D SpwW AtoohoVStaM* Fo«n DrvChMnleal L SPECIAL RRERGHTINQ PROCEDURES: KMP conttfnm oool. UM «qulpfMnt or ahWolna rtquirtd to protect p«nonn«i •oain«t ourMtng. njpturtng, or venting oontaton. UNUSUAL RRE AND EXPLOSION HAZARDS: At •(•vttod'twnptnAjrM (ovw S4*O/130"P). oonMncni may v«nt, ruptura, or burst. Alto M« Stctton VI. *• AdcfftKxwl Note* or Ccmmtnfc from Motion* *bov*: (->03 2491 5!, T E' r : ET 01 l MEfiPh IS TRnFF 1C ; 9- i 9-88 11: 41PM ; 9317578441^ 63; 8 3 ^fev'-.si^-:.-:->'^S^:::.-1 SECTIONWfrU.>H VALUE fTU/1: HAZARD DATA •••* _ TOVERlXPOSURE: ETJET IERITATIOH SXUfsDRYZNd, DCFATTIHC, IRRITATION, DEKXATITIS~ INHALATION! AKCSTKESIA, HEADACHE,' DIZZINESS, NAUSEA, UPPER RESPIRATORY IRRITATION. ANO RRST AIO PROCEDURES: M unconscious, ramow vtatim to (nth «* «na c»fl • physician, it oott«n in ayM, fiuah knmatfatofy with largo amounts of water. JJ contains eartfial Mmifagf'—if unconsctou* from InhalaUon, do not gtv« aoV«oalo-typ« drugs. Q_ _____ SECTION VI — REACTIVITY DATA CHEMICAL STABUJTY; B STABLE U UNSTABLE • OONOmONS TOAVOtt): tNCOMPATlBIUTY (Materials to avoid!: LJ Nont wfth oommon matarte HA2AROOOS OeopMPOSinON PROOyCTS (FRXR t^rrtr^. 13 Cart>on Morwdd« Q PfK»Q«nt D HyoYxjfluortg AoW D Hydrochloric Acid HAZARDOUS POLYMERIZATION: B Wl not occur May Occur • OondWona to avoM: ON VIII .- LEAK AND OISPOSAL PROCEDURES STEPS TO 86.TAKEN IF Ramova tenrtten sourcas AINERS ARE LEAKING OR LARGE AMOUNTSAR8 RCtfiASEO: td AvoW DT««th- Q Avoid sWn ooniact with li«iid. 0 _______. ______ WASTE DISPOSAL METHOD: Do not punotura or Indnwata contain**. Givs •mpty. laaldng. or fwfl gontaln«rs to a dtsposst service «omppod to aafsly handto and dtePOM of prsssurttad oontalrKfi. SECTION Wit — SPECIAL PROTECTION INFORMATION RESPIRATORY PROTECTION (SpMtfy typo): U Not AppCc»W«. VENTILATION LOCAL EXHAUST (Hoods, Fan*, oto.}: O Not vJno*a funny tw-~ ^ — U*Not ftoqulrad Should ba on white scravtnp. (o ramoy» aolvant vapor, Not AppRcabte PROTECTIVE GLOVES: (2 Not ' U Vinyl D Pdyatnylana wMssoravtvi. PROTECTJON: G Not App**cmWo Waar QoQQlM whte apraylng. PROTECTIVE EQUH Oo not waar dotnino toskad by spray. i • S TO B6 TAKEN O IN HANDLING AND ST — SPECIAL PRECAUTIONS ORAQE: D DO not atom Mfnpwaturas oouU cotrrwr$ riAKKABLt. corrms DMDIR PUSSORE. DO HOT OKLY AREAS. AVOID STRAYINC X«0 EYES OR OK KEEP OUT 0? REACH OP CHILDREN 1 1 > or Commarua (ram sacttons abova: ZNTCMTZOKAL MISUSE OR USE OP PRODUCT IN A KAMKER OTHER THAN THAT CONSISTENT WITH LABELING IS A VIOLATION OP FEDERAL LAW. O03 2492