fl*sror.o' PROPERTIES, LLC Office: (904) 632-0073 Fax: (904) 356-4972 April 15,2015 Mr. Richard Tedder, P.E. Director Solid Waste Management Section Division of Waste Management Florida Department of Environmental Protection 2600 Blair Stone Road Tallahassee, Florida 32399 RE: Keystone Storage Pad - B Agremax Beneficial Use Plan Dear Rich Attached please find a report entitled "Keystone Storage Pad - B Agremax Beneficial Use Plan". This report describes a proposed construction project of an approximately four (4J acre storage pad using Agremax coal ash. It is important to note that 1) The storage pad is being constructed on an industrial site which is deed restricted for industrial use only. 2) The proposed location ofthe storage pad satisfies all coal ash location standards as referenced in DEP's March 2011 guidance letter to JEA. 3) The storage pad willbe used for storage of large piles of bulk commodities such as pet coke, gypsum, and limestone. Storage of this material creates a significant "cap" over most of the four (4) acre storage pad. 4) Construction of the storage pad has been well-designed so as to assure protection of human health and the environment. Overall, this project appears to have allof the positive attributes of a coalash beneficial use project. Hopefully DEP will conclude that use of Agremax coal ash for this specific project satisfies the state's industrial byproducts exemption requirements. l9l5 Wigmore Street Jacksonville, Florida 32206 KEYSTONE STORAGE PAD - B AGREMAX BENEFICIAL USE PLAN KEYSTONE PROPERTIES, LLC 1915 Wigmore Street Jacksonville, FL 32206 Duval County, Florida Prepared by: Southem Monitoring and Environmental Atlanta and Jacksonville DATE: APRIL 2015 Table of Contents Section I Introduction to Site, Project Objectives, Agremax 1.1 1.2 1.3 1.4 Project Objectives History of Agremax Why Use Agremax Florida Department of Environmental Protection Background on Beneficial Use Program Section 2 Section 3 Section 4 Section 5 Section 6 Keystone Site Location and History 2.1 2.2 2.3 2.4 Location History Brownfields Status Land Use Status/Restrictions Characteristics of Agremax 3.1 Physical / Chemical Properties of Agremax 3.2 Comparison of Agremax to Gommonly Used Materials of Similar Application Potential Beneficial Use Scenarios for Agremax Potential Beneficial Use for Applications of Agremax Applications of Agremax Used in Various Locations 4.1 4.2 Storage Pad - B Location Standards and Permitting 5.1 Storage Pad - B Location Standards 5.2 Storage Pad - B Permitting Proposed Gonstruction Activities l Procedures 6.1 Proposed Construction Activities / Procedures Section 7 Final Use of Storage Pad - B 7.1 Final Use of Storage Pad - B Section 8 Appendices and Supporting Documentation 8.1 AES Amended Sampling Protocol 8.2 Agremax April 2014 TCLP Results 8.3 Agremax June 2014 TCLP Results 8.4 Site Vicinity Map 8.5 Site Aerial Map 8.6 Site Quad Map 8.7 Agremax MaterialSafety Data Sheet (AES) 8.8 Agremax Oxide Content (SGS Report) 8.9 OverallSite Plan 8.10 Site Plan 8.11 Sections (+15-15x3.19pm) KS SPad-B ffDBH) Section 1 Introduction To Site, Project Objectives, Agremax KS (TDBH) SEGTION 1: Introduction to Site, Project Objectivesn Agremax Keystone Properties, LLC is headquartered in Jacksonville, Florida and has been developed as a major waterfront marine terminal along the St. Johns River. The property is more specifically located at 1915 Wigmore Street, Jacksonville, Florida 32256 and was the forner Jefferson Smurfit paper mill site. Keystone originally owned approximately 70 acres along the St. Johns River and then purchased approximately 38 acres from Jaxport on/or about March 2010 which is depicted in the total property area shown below. ..., KEYSTONI Atp]ex, 70 Ac. ;tr:t:1rrt, :tut'tr:r': : :,l , ,l:,i' .tM? Approx. 38 Ac. ''1,, ,l: r,tr'ar'rr:t ra:a:ri::.j '..::,. ,,, ,-1, .. iilr. The Keystone terminal provides varied land use space to other companies, as well as its own customers. The terminal is a major point of import and export of raw materials including coal, pet coke, fly ash, limestone, and wood chips. Vulcan Materials is a major tenant at the terminal and imports various types of stone for use throughout north Florida. (4-1s-15)(3.19pm) KS SPad-B FDBH) Storage Pad-B Expansion Area (4 Ac +/-) Located at Top Right of Map 1.1 Project Objectives Land Use Need: Keystone requires construction of a new storage pad at it's Jacksonville facility. This new (four) 4 acre pad is designed to be constructed using Agremax coal ash. The pad will be used for storage of various aggregates such as limestone, pet coke, gypsum, etc. Agremax coal ash will be delivered to the Keystone site via carrier vessel (ship), offloaded at the Keystone bulkhead and immediately placed down for use in construction of the storage pad, hereinafter referred to as Storage Pad - B. A short haul road from the Keystone bulkhead to the newly constructed Storage Pad - B will also be constructed using Agremax. The new storage pad will consist of 4.A2 acres, and the haul road will consist of 0.29 acres, resulting in a total project acreage of 4.31 acres. (+15-15)(3.19pm) Ks sPad-B FDBH) Beneficial Use of Materials: Beneficial use refers to the use of materials that provide a functional benefit, that is, where the use of material replaces the use of an alternative material and conserves natural resources that would otherwise be obtained through extraction or other processes to obtain virgin materials. Conservation of Enerqv: The beneficial use reduces waste, conserves energy and recycles materials, to the extent practicable and disposes of, or treats waste responsibly. Human Health and Environment: Protecting human health and the environment is an important Keystone objective, while acting as responsible stewards of the environment, and maintaining the maximum standard of Keystone prformance. Keystone is committed to not creating adverse impacts to adjacent property owners and protecting the important St. Johns River. FDEP Permit Compliance: By virtue of environmental permits thus granted, Keystone strives to remain in compliance with federal, state and City of Jacksonville environmental laws and regulations. 1.2 History of Agremax AES Corporation began developing AES Puerto Rico, LP (AES) in 1993. In November 2002 it opened its plant in Guayama, where it generates and distributes electricity through a 21-year contract with the Electric Power Authority. AES is the first power plant in Puerto Rico whose source of energy is coal mineral. lt is worth noting that a plant listed as zero liquid discharge, has since recycled up to six million gallons of effluent treatment at the regional plant in Guayama, which then evaporates into the cooling process. In related effort to a cogeneration process, AES supplies steam to the neighboring Chevron Phillips Puerto Rico Core Inc. which uses AES technology coal clean, known as coalfluidized bed boilers (also known as CFB). This allows the plant to process coal in a manner consistent with the protection of the environment while generating electricity economically and reliably. The combination technologies makes the Guayama plant one of the world's cleanest power plants. (a-1s15)(3.19pm) KS SPad-B ( DBH) of advanced The proprietary business of AES is to provide reliable power at the lowest cost to Puerto Rico while protecting natural resources. AES has created one of the largest private investments in the history of Puerto Rico and built the Guayama plant as one of the cleanest plants in the world. The ptant operates and implements cutting edge technology to produce over fifteen percent (15Yo) of the energy consumed in Puerto Rico. AES currently operates an approximate 454 megawatt coal-fired cogeneration facili$ at its Guayama, Puerto Rico location for the generation and sale of steam and electricity and produces coal combustion products, including Agremax, as a byproduct of its stearn and electricity generation operations. {.3 Why Use Agremax Agremax is an innovative alternative to reserving virgin natural resources, while making use of entirely recycled materials. The use of Agremax reduces construction costs and more importantly helps to conserve the environment, while protecting natural resources. Agremax, as a byproduct of combustion coal, has suitable beneficial use qualities for purposes of various civil engineering and construction applications that include some of the following: Final top surfaces for roads, parking lots, laydown yards and industrial or commercial applications, either alone or with stone (such as granite or limestone) or asphalt milling rolled into the top surface. Compacted as a base course for civil applications in accordance with the Florida Department of Transportation (or other suitable states), where the base course will be covered with a friction surface such as asphalt or concrete. Used in a process for the stabilization of soils. Soil stabilization can be defined as a means of permanently altering soil to increase its strength and bearing capacity and decrease its water sensitivity and volume change potential. Agremax use for the Keystone Storage Pad-B Expansion Area (4 ac +/.): (+15-15X3.1gpm) KS SPad-B IIDBH) As related to this particular beneficial use application, the use of Agremax will eliminate the need for expensive borrow materials which would otherwise be needed to fill an approximate four (4) acre storage requirement. The use of Agremax will expedite construction by improving sub-grade conditions as the material is quickly compacted and becomes extremely stable. The use of Agremax will provide a long term storage pad that will physically support storage of numerous types of aggregate and the associated heavy equipment used to constantly rnove the aggregate materials. 1.4 Florida Department of Environmental Protection Background on Beneficial Use Program In 2003, the Florida Department of Environmental Protection (FDEP) drafted a letter conceming the use of certain wastes. One of the specific waste streams discussed in this letter is wasteto-energy (U\trE) ash. Common applications for the use of this and other waste streams were: 1) structural fill; 2) in roads and sub-bases; 3) as soil amendments; and 4) in the manufacturing of soil cement, Portland cement, bricks or aggregate. While there are statutory and rule provisions that apply to the use of WTE ash and other waste, FDEP's rules generally do not specify what sort of information is required from applicants for beneficial use proposals and how these beneficial use decisions should be made by the FDEP. ln the letter, the FDEP discusses Part lV of Chapter 403, Florida Statue (F.S.), known as the Solid Waste Management Act. The statute includes provisions that allow and encourage the safe use of waste products. The statute also exempts certain solid waste disposal activities from the requirement to obtain a permit. Section 403.7045(1), F.S., exempts from regulation as solid waste, both recovered materials (defined to include only metal, paper, glass, plastic, textile or rubber materials) and industrial byproducts (not defined by statute, but interpreted to include most other materials which can actually be recycled) if the following requirements are met: 1. A majority of the materials are demonstrated to be sold, used, or recycled within one year; (4-15-15)(3.19pm) Ks SPad-B fiDBH) 2. The materials are not managed so as to pose a threat of contamination in excess of applicable department standards and criteria, or to cause significant threat to public health, and; The materials are not hazardous wastes. In addition to the above, additional guidance concerning use of coal ash was provided to the Jacksonville Electric Authority (JEA) by Florida DEP in a Florida DEP Guidance Letter to JEA dated March 29,2011. Florida's WTE plants produce about 1.5 million tons of ash residue each year, most of which is disposed in lined landfills. Section 403.7045(5), F.S., gives the FDEP authority to establish criteria and guidelines for recycling this material provided "no significant threat to public health will result and that applicable FDEP standards and criteria will not be violated". Beneficial use decisions are also evaluated on a case-by-case basis. The FDEP's guidelines for the use of WTE ash (FDEP, 2001) and RSM (FDEP, 1998) have not been adopted by rule and are not mandatory. After reviewing the FDEP's letter and Florida Statutes, Keystone's consultants communicated with the FDEP concerning the use of Agremax and coal ash in general under these statutes and the FDEP policies. In recent years, the FDEP has found that the use of coal ash and related materials has sometimes been problematic in terms of environmentally related issues. Most of the difficulties associated with the use of these materials appear to have been the result of improper and poorly executed application of the material. After thorough discussions with the FDEP, it was determined that certain criteria and precautions must be followed during application of these types of materials, including Agremax. Based on the FDEP's letter and Part lV of Chapter 403 F.S., Keystone requested AES's TCLP sampling plan for their coal ash material (Agremax) generated at the Guayama, Puerto Rico power plant. Keystone also requested TCLP sampling results for Agremax. After reviewing AES's sampling plan, Keystone requested revisions to the plan, so as to assure adequate sampling for proving the materialto be non-hazardous, per FDEP requirements. (4-1$1sX3-19pm) KS SPad-B (IDBH) A copy of the amended AES sampling plan, that includes these revisions, is attached within this plan. (See Section 8, Appendix 8.1). Also attached is April2014 (see section 8, Appendix 8.2) and June 2014 TcLp sampting data (see section g, Appendix 8.3) of the material, demonstrating it's compliance as a non-hazardous material. It should be noted that AES has routinely and continually conducted TCLP sampling of Agremax for many years, as part of AES' materials management program and landfill disposal requirements and as part of the beneficial use of Agremax in Puerto Rico and the United States. This routine and continual sampling has continued to demonstrate the non-hazardous nature of the material. End Section (a-15-15)(3.19pm) KS SPad-B CrDBH) 1 Section 2 Keystone Site Location and History KS (TDBH) SECTION 2: 2.1 Site Location and History Location The physical address for the facility is 1915 Wigmore Street, Jacksonville, Duval County, Florida. The facility is located on the west bank of the St. Johns River in the industrialized center of Jacksonville, Florida. (See Section 8, Appendix 8.4 and 8.5). The facility consists of approximately 110acres of land, situated on both sides of Wigmore Street. The main parcel (Keystone Property), on which proposed kilns are to be situated, is comprised of approximately a second parcel of approximately 10 acres is located across Wigmore Street from the main parcel. The Keystone Property had been used as a kraft linerboard mill and 100 acres, and manufacturing facility from 1938 until 2006. A chain-linked fence is located along the southern, western, and northern boundaries of the Site so as to restrict the Site from public access. JEA's power plant primari$ borders the southern vicinity. A mixture of both commercial and residential properties sunound the westem and northwestern boundaries. Residential housing is located approximately 1,500 feet southwest of the developed portion of the Site. The St. Johns River, which runs along the northeastern and eastern boundaries, serves as a natural barrier for the Site. (See Section 8, Appendix 8.6). 2.2 History The southem portion of the Keystone Property was developed in 1919 by American Agricultural Chemical Company, which produced agricultural products and fertilizer. The American Petroleum Company owned the northem portion. During that time, it was also leased to Mexican Oil Company. The American Petroleum Company property was operated as a bulk petroleum storage facility until the mid-1 950s. In 1938, the National Container Corporation purchased the property from the American Agricultural Chemical Company and began boxboard paper manufacturing. When Owens lllinois Corporation purchased the National Container Company site in 1956, the adjacent American Petroleum property was also acquired. In 1965, the mill was acquired by Alton (4-15-15)(3.1spm) KS SPad-B ODBH) Boxboard Company. Modemization of the facilities in 1975 included the addition of an industrial wastewater treatment system. From 1975 forward, process wastewater was treated prior to discharge to the St. John's River. Prior to 1975, process water was sent to the wetlands area at the northwestem end of the property. The process water, including dilute black liquor and other various liquids associated with paper-making activities, was released into a serpentine ditch, where solids settled and remaining water flowed into the St. John's River. In 1979, the Jefferson Smurfit Group Limited initiated the acquisition of Alton Box Board stock. In 1980, the company name was changed from Alton Box Board Company to Alton Packaging Corporation. The completed purchase of all outstanding stock in 1981 allowed the company to become a subsidiary of Jefferson Smurfit Corporation. In 1986, the name was changed to the Jefferson Smurfit Corporation. On November25, 1991, an above-ground storage tank containing black liquor sutfered a rupture, releasing approximately two million gallons. One-fourth of the release went into the river before it could be contained. The remainder either seeped into the ground or was recovered, processed, and recycled into the plant process. The soils that were impacted were removed and placed in on-site storage cells located in a section of the solid waste management area (SWMA). The on-site storage cells were created by excavating rectangular holes approximately ten feet deep. Polyethylene sheeting was then placed in the excavation (seams not welded) to restrict contact between existing soils and recent fill. ln May 1993, the impacted soils were removed from the cells and transported to the Pecan Row Landfill in Valdosta, Georgia. This activity was completed in July 1993. Also in 1993, the 7.83 acre parcel was bought and added to the contiguous property area. This area was formerly residential. As a result of the black liquor spill, the Florida Department of Environmental Regulation and the Jefferson Smurfit Corporation executed an Administrative Consent Order on March 10, 1992. The consent order provided a requirement to develop a groundwater monitoring program for the black liquor spill area and for the landfill. The monitoring program has been conducted since that time. A former SWMA is located in the western portion of the facility and is approximately ten acres in size. The existence of this SWMA led the U.S. Environmental Protection Agency (EPA) to designate the property as a Comprehensive Environmental Response, Compensation, and (+15-15x3.19pm) KS SPad-B fiDBH) Liability Inventory System (CERCLIS) hazardous waste site in 1979 (EPA lD No. FLD006328793). The site is still currently listed in EPA's CERCLIS Hazardous Waste Site List. This area was grouped into two zones based on the waste product stored. Surface water drainage flows through the wetlands to the river on the west side of the SWMA and toward a ditch leading to the river on the east side of the SWMA. EPA conducted preliminary assessments in 1979 and 1985, followed by a site inspection in 1986 with samples analyzed for volatile organic compounds (VOC's), semivolatile organic compounds (SVOC's), polychlorinated biphenyls (PCB's), pesticides, and inorganics. The results of these investigations indicated the presence of naphthalene (up to 4l0micrograms per kilogram (Ug/kg), 2-methylnaphthalene (up to 630 pg/kg), and PCB Aroclor-1254 (up to 160 Ug/kg) in surface soil samples. Sub-surface soil sampling indicated the presence of phenanthrene (up to 1,200 pg/kg), phenol (up to 3,800 pg/kg), fluoranthene (up to 690 pg/kg), pyrene (up to 540 pg/kg), 4,4-dichlorodiphenyltrichloroethane (DDT) (up to 7.5 pg/kg), and PCB Aroclor-1254 (up to 100 pg/kg). Minor concentrations of inorganics were also observed. Groundwater sample results did not detect significant VOC or SVOC concentrations, but PCB Aroclor-1254 was noted in a downgradient well at 1.7 micrograms per liter (pg/L). Minor concentrations of inorganics were also observed. Semi-annual groundwater sampling has been conducted for VOC's, inorganics, turbidity, ammonia, nitrates, chloride, sulfates, pH, and total dissolved solids (TDS) at the SWMA from 1998 to the present, with pH, chloride, iron, sodium, and TDS exceeding Florida surface water quality standards. VOC's have not been detected. After searching for several years for a port site to conduct its shipping operations, Keystone Properties, LLC, purchased 70 acres of the former Jefferson Smurfit paper mill from Jax Maritime in early 2006. Shortly after acquiring this property from Jax Maritime, the Jacksonville Port Authority filed an eminent domain action against Keystone Properties to take the property. Following a three year court case, Keystone Properties was able to retain title of its property and proceed with redevelopment. Over the next four years, Keystone Properties has rapidly transformed the Site into a modern bulk commodities handling facility. (a-15-15)(3.19pm) KS SPad-B [DBH) 2,3 Brownfields Status Shortly after purchasing the property in early 2006, Keystone Properties initiated negotiations with the FDEP conceming the desirabili$ of having the property designated as a brownfields site pursuant to the State of Florida Brownfields Program. Negotiations between Keystone and the FDEP were complicated by the ongoing eminent domain action taken by the Jacksonville Port Authority. Effective in 2007, Keystone Properties, LLC entered into agreement with the State of Florida Department of Environmental Protection as set forth in the Brownfield Site Rehabilitation Agreement, also refened to as Brownfield Site lD# 160001008. 2.4 Land Use Status/Restrictions The subject property is designated as industrial per the City of Jacksonville 20 Year Long Range Comprehensive Plan. Additionally, the property is zoned Industrial Waterfront per the City of Jacksonville Zoning Ordinance. Finally, a Deed Restriction has been placed on the property, limiting future use of the property to industrial. End Section 2 (4-15-15X3.1gpm) KS SPad-B FDBH) KS (TDBH) Section 3 Characteristics of Agremax SEGTION 3.1 3: Characteristics of Agremax Physical / Chemical Properties of Agremax Coaf-fired power plants produce millions of tons of coal ash per year. About 4oolo is beneficially used in a variety of applications and about 60% is managed in storage and disposal sites. Coal ash is the mineral matter that is collected after the coal is combusted, along with some unburned carbon. The solids collected from the fumace and removed from the flue gas after the coal is combusted are collectively referred to as coal combustion products and can be broadly categorized as coal ash and flue gas desulfurization solids. The physical and chemical properties of coal ash are determined by reactions that occur during the high-temperature combustion of the coal and cooling of the flue gas. There are basically two types of ash that make up coal ash; fly ash and bottom ash (bottom ash also known as bed ash). Phvsical Properties of Flv Ash: Fly ash refers to the light weight particles that travel with the flue gas as it exits the fumace and moves away from the high-temperature combustion zone, Fly ash particles are composed mainly of amorphous or glassy aluminosilicates. Fly ash particles are typically spherical in shape, either solid or with vesicles. A small percentage are thin-walled hollow particles called cenospheres. The particles are fine-grained, typically silt- sized, ranging from 1 to 100 microns in diameter, with median particle diameters of 20 to 25 microns. Fly ash is usually tan to dark gray in color. Typical Photo of Fly Ash (4-15-15)(3.19pm) KS SPad-B fiDBH) Phvsical Properties of Bottom Ash: Bottom ash consists of heavier particles that fall to the bottom of the furnace system. Bottom ash is also composed primarily of amorphous or glassy aluminosilicate materials derived from the melted mineral phases. Most bottom ash is produced in dry-bottom boilers, where the ash cools in a dry state. Bottom ash is coarser than fly ash, with a sandy texture and particles ranging in size from about 0.1 mm to 50 mm in diameter. Bottom ash from dry-bottom boibrs is generally dull-black and porous in appearance. lt typically has the consistency of course-sand to gravel and has a higher carbon content than fly ash. The properties of bottom ash makes it useful for a variety of construction applications. Typical Photo of Bottom Ash Chemical Properties of Aoremax Coal Ash: The chemical composition of Agremax coal ash is determined primarily by the chemistry of the source coal and the combustion process. The chemical composition of the ash can change as power plants change fuels or add new air emissions controls to prevent releases to the atmosphere. lt is not combustible or explosive. Agremax is produced by blending the fly ash and bed ash at an 80/20%o ratio.The subsequent material is metered by computer control to a pug mill. The pug mill blends the materials and begins aggregation of the product. This step is both a mechanical and chemical binding process. 25 -30o/o water by weight is added to hydrate materials. (a-1$15)(3.19pm) KS SPad-B (TDBH) The resulting Agremax is dropped from the production belt and then placed into the stock pile where it cures for a least two (2) weeks. Common chemical properties found in Agremax are as follow: Molecular Formula IUPAC Id Ghemical Aluminum oxide Al2o3 Galcium oxide CaO lron oxide FezOg Magnesium oxide Mgo 3.58 oicm3 40.30 g/mol Silicon dioxide sio2 2.65 q/cm" 60.08 glmol Sodium oxide NazO Sulfur trioxide SO. Titanium dioxide Tio2 Note: Density Molar Mass 3.95 101.96 g/mol Formula o/cm3 3.34 o/cm3 5.24 o/cm3 2.27 o/cm3 1.92 o/cm3 4.23 q/cm" 56.08 g/mol 159.69 g/mol Melting Point Boiling Point 3,762"F 5,391"F Q.977"C\ e.072"c\ 4,735"F (2613"C) 2,851"F (1,566'C) 5,'t65"F 5,162'F {2850"C) 3,609"F (1.987'C) 6,512'F f2.852'C) 2,912"F {1.600"c) 2,070'F {1,132"C) 13.600"c'l 80.07 g/mol 62.4"F (16.9"C) 113"F (45"C) 79.87 glmol 3,349"F (1.843'C) (2,972"C) 61.98 g/mol 4,046"F (2.230"C\ 3,542"F (1,950"C) 5,382'F IUPAC represents the International Union of Pure and Applied Chemistry. The IUPAC is the recognized authority for chemical standards of nomenclature, measurements and atomic mass values. AES has produced a Material Safety Data Sheet (MSDS) which states the product and company information, composition / information on ingredients, hazard identification, first aid / explosion / fire fighting measures, accidental release measures, handling and storage, exposure controls i personal protection, physical and chemical properties, stability and reactivity, toxicological and ecological information, disposal considerations, transportation measures, fire information, and regulatory information. (See Section E, Appendix 8.7). Also included within this plan is the SGS North America Analysis Report which demonstrates the oxide materials of oxide contents of Fly Ash, Bed Ash, and Agremax with the percent composition. (See Section 8, Appendix 8.8). (4-15-15x3.19pm) KS SPad-B CIDBH) Also attached is April 2014 (See Section 8, Appendix 8.2) and June 2014 TCLP sampling data (See Section 8, Appendix 8.3) of the material, demonstrating it's compliance as a non- hazardous material. It should be noted that AES has routinely and continually conducted TCLP sampling of Agremax for many years, as part of AES' materials management program and landfill disposal requirements and as part of the beneficial use of Agremax in Puerto Rico and the United States. This routine and continual sampling has continued to demonstrate the non-hazardous nature of the material. In summary, Agremax coal ash is proposed to be used in this construction application as a fill material, soil stabilization and as a measure to conserve natural resources in lieu of mining borrow fill. In addition, it is not considered a hazardous waste according to standards of the Florida Department of Environmental Protection. 3.2 Comparison of Agremax to Commonly Used Materials of Similar Application Agremax is an innovative alternative to reserving virgin natural resources, while making use of entirely recycled materials. The use of Agremax is expected to reduce construction costs and more importantly, help to protect the environment. Agremax has the ability to be utilized in replacement of, or used as an enhancing product in lieu of similar materials such as Portland cement, crushed concrete, limestone or asphalt and in this particular application, will eliminate the need of mining borrow flll. lt has qualities as a byproduct to potentially have less environmental impact than the previous materials listed. In this particular civil engineering application, Agremax will be installed as an alternative to eliminate the need for expensive borrow materials which would othenrise be needed to fill an approximate four (4) acre storage requirement. Since, per DEP regulations, the circulating fluidized bed byproduct is non-hazardous, the current application shall contribute toward the conservation of natural resources. End Section 3 (4-15-1sx3.19pm) KS SPad-B IIDBH) Section 4 Potential Beneficial Use Scenarios for Agremax KS (T DBH) sEcrloN 4.1 4: Potential Beneficial use scenarios for Agremax Potential Beneficial Use Applications of Agremax Beneficial use for applications that are similar to the material characteristics of Agremax have been used with success as listed below: . Hydrated material used as road base (blended roadbase) and road aggregate (temporary and permanent types), e r o o . . r o 4.2 Railroad beds, Parking lots, laydown yards and equipment pad construction, Generalbasematerial, Finished surface material for roads, driveways and patios, Solid waste closure, landfill closure, soil stabilization for contaminated sites, Soilstabilization, Flowable fill (for excavation backfill, pipelines, etc.) and, Neutralization of highly acidic phosphate mine waste water. Applications of Agremax Used in Various Locations Beneficial use applications include, but are not limited to, the following typical uses in puerto Rico: o . . Project Name: Highway Exit Ramp #713 and consists of a highway roadway cross section of 3'Asphalt, 3.75' Black base, 5" Mogolla base and 24" Agremax suFbase. Project Name: Highway #706 and consists of a secondary roadway cross section of 1" Asphalt, 5" Mogolla base and 20" Agremax sub-base. Project Name: Highway #7711 and consists of a rural, unpaved roadway cross section of 4" Mogolla base and 12'Agremax sub-base. . Project Name: Selectos Supermarket and consists of a shopping center parking lot cross section of 3'Asphalt, 10" Mogolla base and 24'Agremax sub-base. (4-1 5-1 5)(3. I 9pm) KS SPad-B TIDBH) Carrasquillo Associates of Puerto Rico conducted field testing in January 2011 at the above listed projects and concluded the following in-place CBR strength of Agremax sub-base and additional comments: a Agremax exceeded a CBR strength of 40 percent, a Demonstrated a much greater than expected quality of a typical sub-base, a Exceeded CBR values previously reported based on testing performed under laboratory conditions. Agremax fell within the higher range of values for A-2-4 soils, . . Agremax was comparable to higher quality A-1-a soils, Agremax demonstrated no evidence of severe distress or any conditions affecting the use and performance of any of the pavements tested, o Minor distress that was observed in field testing was limited to the asphalt wear surface layer and/or the Mogolla base layer, . . Minor distress that was observed was not indicative of the Agremax sub-base and, Agremax sub-base exhibited excellent performance. Beneficial use applications include, but are not limited to, the following typical uses in the United States: Project Name: Millard Water Tank, Mobile, Alabama and consists of using Agremax as a sub-base for fill and soil stabilization. Project Name: GT Omni Port, Port Arthur, Texas and consists of using Agremax as a sub-base for railroad and soil stabilization. End Section 4 (4-15-15X3.1gpm) KS SPad-B ODBH) Section 5 Storage Pad (4-1s-15)(3.19pm) KS SPad-B fiDBH) - B Location Standards and Permitting SEGTION 5: Storage Pad-B Location Standards 5.1 Storage Pad - B Location Standards The proposed location of Storage Pad-B was dictated by the site facility longrange plan as well as by specific criteria for the environmentally safe use of Agremax. In selecting the location for the pad, Keystone has taken great care to assure that AES standards for use of Agremax are adhered to, as well as adherance to Florida DEP guidance for use of coal ash. The location of the Storage Pad - B adheres to the following site location standards: 1. The storage pad is not being constructed on residential or commercial property. As may be seen in Section 8, Appendix 8.9, Sht. C-1, the nearest residential or commercial land use is approximately 1,500 feet from the storage pad. The storage pad is not being constructed within 25 feet of a wetland as defined in Rule 62-UA, F.A.C. As may be seen in Section 8, Appendix 8.9, Sht. C-1, the closest wetland as defined above is approximately 1,350 feet from the storage pad. 3. The storage pad is not being constructed so as to come into contact with surface water bodies. As may be seen in Section 8, Appendix 8.9, Sht. C-1, the closest surface water body is the St. Johns River which is approximately 185 feet from the storage pad. Stormwater permitting proposed for the pad will assure there are no environmental impacts to the river. 4. The storage pad is not being constructed within 500 feet of surface waters that routinely flood outside their banks, Section 8, Appendix 8.9, Sht. C-1. The estimated seasonal high water level (SHWL) at WCF-1 is designation and location is at the edge of Storage Piles 1 and 2. 9.0. The boring This estimated SHWL is 5 ft. below the bottom of the proposed Agremax. The SHWL test boring was performed in September 2014. (See Section 8, Appendix 8.10, Sht. C-2). The proposed 4.0 storage pad shall have concrete structure inlets and round concrete pipe positioned to capture and convey stormwater to proposed Pond-2. The stormwater collection system shall provide adequate water quality per the FDEP regulations. Pond- (4-15-15x3.19pm) KS sPad-B (IDBH) 2 will be directly connected to Pond-l and then discharge through the control structure designated outfalldischarge point (See Section 8, Appendix 8.10, Sht. C-2). 7. The proposed 4.0 acre storage pad shall have a general top elevation of 19.5. This elevation has been determined based on existing ground elevations of 14.0 +t-. The Agremax fill shall be placed in a 5 ft. depth and then have a 6" stone cap. The volume of the proposed storage pad is estimated to be 32,267 cubic yards. The proposed access road will lead from the existing haul road at apprOximate elevation 10.5 and climb in elevation until it reaches the storage pad top elevation of 19.5. The Agremax fill under the proposed access road will have a minimum thickness of 1 ft at the existing haul road and gain thickness to a 5 ft. depth at the connecting point of the storage pad. The volume of the access road is estimated to be 833 cubic yards. (See Section 8, Appendix 8.11, Sht. C-3). The bottom elevation of the storgage pad (Agremax) is approximately 5 feet above the seasonal high water table. (See Section 8, Appendix 8.11, Sht. C-3), The storage pad is not being constructed within one-half mile of the nearest potable water well. 5.2 Storage Pad - B Permitting The Keystone facility operates under a series of focal, state, and federal permits and permissions including those of the U.S. Army Corps of Engineers, U.S. Department of Homeland Security, Florida DEP, The St. Johns River Water Management District, and the City of Jacksonville. Prior to installation of the storage pad, all existing facility permits will be reviewed to determine if there is need for modifications of existing permits. lt is anticipated that the existing facility stormwater permit will be modified in order to accornmodate the new storage pad. End Section 5 (4-1s-ls)(3.19pm) KS SPad-B ODBH) Section 6 Proposed Construction Activities I Procedures KS (TDBH) sEGTloN 6: Proposed construction Activities / Procedures 6.1 Proposed Gonstruction Activities / Procedures Site Location: fn late 2014, directive had been given to Keystone staff and consultant(s) and sub-consultant(s) to prepare for expansion of the facility storage capability to include installation of a new storage pad of approximately four (4) acres. See map below. Storage Pad-B Expansion Area (4 Ac +/-) Located at Top Right of Map Construction ActiviW Planninq: In 2015, Keystone staff and consultant(s) and sub-consultant(s) actively began preparation for construction procedures and construction sequence that will include but not be limited to the following: (+15-15)(3.19pm) KS SPad-B fiDBH) Pre-shipment Samplins: Prior to the Agremax being loaded onto the carrier vessel, the Agremax will be sampled by AES in accordance with the amended sampling plan as provided in Section 8, Appendix 8.1. The results will be reviewed and approved by Keystone prior to shipment of the Agremax to Keystone. Gonstruction Procedures: 1. As soon as Agremax is taken from the ship and to the proposed Storage Pad-B, it shall be placed and compacted in the subject construction area as quickly as possible, 2. Agremax shall not be stockpiled at the construction area, 3. All necessary measures shall be taken to avoid fugitive dust from the unloading and placement of Agremax and to avoid impacts to stormwater during placement of the Agremax, 4. Agremax shall be installed in layers of less than 1 foot in depth. Moisture shall be applied to the Agremax after the completion of each layer, Agremax shall be compacted at the conclusion of each day of application utilizing a roller or similar machinery, It should be noted that Keystone has all necessary installation equipment available at the property including heavy loaders, bulldozers, and rollers. Construction Seouence 1. Site preparation, 2. Canier vessel arrival date, confirm amount of cargo material and confirmation of pre-delivery sampling results 3. Unloading of Agremax material, 4. Transporting Agremax materialto the new Storage Pad - B, 5. Laydown of Agremax material, 6. Compaction and capping surface, 7. Finalize the unloading of the carrier vessel. (4-1s-15X3.1gpm) KS SPad-B IrDBH) A detailed description of the planning and construction activities is presented below. 1. Site area data acquisition: a. Survey task: Keystone staff shall coordinate with R.E. Holland Surueyors and request a topographical survey of the existing ground conditions in the subject area. The existing survey shall be compared to the proposed grading and confirm an estimated volume needed to provide the necessary amount of Agremax fill material needed to complete the proposed expansion. b. Autocad drawing task: Southern Monitoring and Environmental (SME) will give directive to staff senior designer to prepare at a minimum, 1) a plan view sheet depicting the new Storage Pad - B, and 2) a cross section sheet depicting the proposed flll area that shows existing grade, proposed base, Agremax fill, proposed upper base and proposed top surface. 2. Site preoaration: a. Prior to the arrival of the carrier vessel, the subject area shall be prepared to form a base course for the deposit of Agremax material. 3. Carrier ship arrival date, amount of caroo material and pre-deliverv testinq: a. The designated carrier vessel shall be the "Mississippi Enterprise' that shall transport the Agremax coal ash material under an American flag from AES Puerto Rico to the Jacksonville Keystone facility. b. The canier vessel shall be transporting approximately 33,100 short tons of Agremax coal ash material. c. Pre-delivery sampling of material shall be performed by AES prior to loading in Puerto Rico. This sampling shall consist of an (a-15-15)(3.19pm) KS SPad-B (IDBH) independent third party reasonably acceptable to Keystone. Sample results will be reviewed and confirmed by Keystone prior to loading of the carrier vessel in Puerto Rico. 4. Unloadinq of Aqremax material: a. The unloading of Agremax material shall be performed by stevedores which shall be provided by Keystone. It shall be anticipated that unloading of the carrier vessel shall achieve an unloading rate of approximately six thousand (6,000) short tons per twenty four (24) hour period. c. The carrier vessel shall provide the use of three (3) on deck cranes with clam shell unloading devices. d. As material is unloaded from the carrier vessel, it will be deposited into large steel bins situated on the bulkhead. Front end loaders shall load materialfrom the large steel bins to dump trucks. L Caution shall be exercised to limit fugitive dust. g. AES staff and Keystone staff shall observe and monitor unloading procedures at alltimes. 5. Transoortinq Aoremax materialto the new Storaoe Pad - B: After the material is loaded into the dump trucks, the trucks shall follow a designated haul road path that leads from the bulkhead in a easterly direction. The trucks shall follow the haul road path to the north end of the new Storage Pad - B. (+15-15X3.19pm) KS SPad-B ffDBH) c. Keystone staff will provide continuous laydown of water, by means of a water truck vehicle, in order to limit fugitive dust and initiate the hardening of the Agremax material. 6. Lavdown of Aoremax material: Once trucks deposit material to the new Storage Pad - B, a dozer will push material into the fill area and continue at a rate comparable to the haul effort. b. As material reaches an approximate level consistent with the plan intent of the approved grading design, RE Holland surveyors will be requested to survey and stake the proposed finished grade elevation across the fill area. 7. Compaction, qnd Cappino Surfece: a. As material is being deposited, a vibratory roller and bulldozer shall endeavor to provide continuous compaction efforts to achieve desirable surfaces at alltimes. b. After the estimated proposed elevation is achieved, the vibratory roller and bulldozer shall provide final efforts consistent with top surface expectations. c. Once the Agremax surface elevation expectation is met, clean stone or gravel, as a final cap, shall be installed to an approximate depth of 6 inches. 8. Creation of temoorarv storaoe: lf the proposed expansion area reaches a maximum level of storage, a temporary storage area shall be designated to handle the excess material. Temporary storage area shall be determined by Keystone staff as construction and canier vessel unloading progresses. (4-1$.1 s)(3. 19pm) KS SPad-B CIDBH) the c. Any excess rnaterial shall be used as beneficial use or shall be disposed of at an appropriate solid waste landfill, within ninety (90) days of arrival of the material at the construction area. lt is not anticipated that there will be any excess material. L Finalize the unloadino of the carrier vessel: a. Monitoring and observation of the carrier vessel unloading progress will continue at alltimes. b. Keystone staff will at all times provide necessary services to aid in the process and progress. c. Keystone staff will coordinate with all support staff to be present for observation of the final unloading of the carrier vessel. End Section 6 (4-1$15X3.19pm) KS SPad-B FDBH) SECTION 7 Final Use Of Storage Pad - KS (T DBH) Section 7: Final Use of Storage Pad-B 7.1 Final Use Of Storage Pad - B Once construction is achieved, the new Storage Pad - B will be available for use on an immediate basis. The new Storage Pad - B will be used to store a variety of bulk commodities including limestone, gypsum, pet coke, and related commodities. Storage of bulk commodities is shown on the drawings in Section 8, Appendices 8.9, 8.10 and 8.11 of this plan. As may be seen on the referenced drawings, the stored commodities are placed in large piles on the new storage pad and serve as a large "cap" over most of the new storage pad. Once these commodities are placed on the pad, the commodities are then, over time, shipped out to various customers. However, past operational practice indicates that the subject piles of commodities are never completely depleted; thus, the "cap' over the Agremax always remains in place. End Section 7 (a-15-15)(3,19pm) KS SPad-B ODBH) Section 8 Appendices and Supporting Documentation KS (T DBH) 30 Appendix 8.1 AES Amended Sampling Protocol KS (TDBH) 37 Title: Agremax , Fly Ash and Bed Ash flAr,$ Reviewed by: Carlos Gonzalez Doc #: soP-ccP-002 Sampling Procedure Area: CCP Area Prepared by: Eitel Figueroa AES Puerto Rico Guavama- PR Effective Datq05-21-14 teview Date:06-l 8-l 5 Supersedes:4- I 3-l 4 Page: I of6 Rev #: 2 Title: Agremax, Fly Ash and Bed Ash Sampling Procedure Approvals: Signature Date Reviewed by: HectorAvila Environmental Coordinator Reviewed by: Carlos Gonzalez CCP Team Leader Assistant Plant Manager: Ron Rodrique Engineering Manager: Ramiro fuvera Distribution List: 1. CCP Area 2. Control Room 3. Plant Manager Office ,8 Title: Agremax , Fly Ash and Bed Ash finrs Reviewed by: Carlos Gonzalez Doc #: soP-ccP-002 Samoline Procedure Prepared by: Eitel Fieueroa AES Puerto Rico Guayam4 PR Page: 2 Effective Date:05-2 l -l 4 (eview Date:06- I 8- l5 Area: CCP Area Suoersedes:4-l 3- l4 of6 Rev #: 2 Table of Contents 1. Purpose 2. Scope 3. Responsibilities........ 4. Definition 4.1. Grab Sample............. 4.2. Composite Sampling. 5. Personal Protection Equipment (PPE)..... 6. Sample Process.... 6.1. Sampling Techniques- Stock Pi1e.......... 6.2. Sampling Techniques *Conveyor Belts 7. Sample Area and Frequency 8. Composite Sample Procedure 8.1. Aggregate Pi1e.......... 8.2. Fly and Bed Ash Tank 9. Labeling of Sample 10. Sample Receipt and Storage.............. .........3 ............3 ......3 ......3 ................3 .........,......3 ........4 ..........4 .....................4 .....................4 ..........' 5 ........5 ................5 ..............6 ........6 ...........6 3? Title: Agremax, Fly Ash and Bed Ash Sampline Procedure flaF": 1. Reviewed by: Carlos Gonzalez Doc #: soP-ccP-002 Pnpared by: Eitel Fisueroa Effective Date:05-2 Area: CCP Area -l AES Puerto Rico Guavama. PR 4 leview Date:06-18-15 Supersedes:4- l 3- I 4 Page: 3 of6 Rev #: 2 Purnose The purpose of this Standard Operating Procedure (SOP) is to provide a standardized procedure for the preparation of samples for different analysis. Specifically, the samples are obtained to perform TCLP and SPLP analysis to verifu that Agremax, Fly ash and Bed ash are not hazardous based on RCRA limits. This procedure will be used by AES Puerto Rico LP employees and contractors/subcontractors supporting soil or other solid media according AESPR QA/QC Plan. 2. Scone This procedure establishes a step by step routine procedure to collect CCP samples for laboratory analysis. Proper sample collection technique will improve the accuracy of results and will help avoid cross contamination. 3. Responsibilities The Coal Combustion Products Team Leader, CCP Project Engineer, CCP operator, or subcontractor is responsible for overseeing sample preparation activities. The CCP Team Leader is also responsible for checking all the sampling work performed and veriffing that the work satisfies the specific tasks outlined by the SOP. It is the responsibility of the CCP Team Leader/ CCP Engineer to communicate with the laboratory personnel regarding specific collection objectives. The CCP operator/contractor or designated person is responsible of preparing the samples and adhering to the applicable task outlined in this procedure and to take all the required samples according AESPR QA/QC plan. 4. Definition 4.1. Grab Sample Is just what it sounds like; all of the testing material that is collected at one time. As such, a grab sample reflects performance only at the point in time that the sample collected, and then only if the sample was properly collected. was 4.2. Composite sampling Consist of a collection of numerous individual samples taken at regular intervals over a period of time. This usually takes 24 hours. The material being sampled is collected in a common container over the sampling period. The analysis of this material collected over a period of time will therefore represent the average performance of a wastewater treatment plant during the collection period. 4.3 Vessel loading sampling When Agremax is to be shipped to US and Florida customers, the sample frequency shall be taken to correspond to no more than 3000 ton intervals loaded. Sampling procedures shall be conducted in accordance with Florida DEP QA Rule 62-160 F.A.C. (Should there be any inconsistency or inaccuracy govem). in the protocol, the subject QA Rule shall 4e Title: Agremax, Fly Ash and Bed Ash Doc #; soP-ccP-002 Sampline Procedure Reviewed by: Carlos Gonzalez Effective Date:05-2 Area: AES Puerto Rico 6uayama, PR Prepared by: Eitel Fieueroa CCP Area I- Page: 4 of 6 4 teview Date:06-18-15 Supersedes:4-l 3-l 4 Rev #: a To make the composite of 3000 tons, a sample should be taken at 1000 ton intervals. Each sample should be swept from the belt or from the hold depending on safety TCLP analysis. (The labs will "rush" the samples through upon request). Every sample shall be sent to the laboratory for immediate analysis with a "rush" request included. 5. Personal Protection Equipment (PPE) 5.1. Safety Glasses 5.2. Hard Hat 5.3. Safety Shoes 5.4. Rubber Gloves 6. Sample Process 6.1. Sampling Techniques- Stock Pile 6.1 .I . 6.1.2. Do not rake back or disturb the material before sampling. Sample it just like it is. Push the shovel straight in at about 9Ooand as far as it will go. 6.1.3. Remove the shovel carefully to minimize spilling material offof 6.1.4. Material spilled offthe shovel is coarser than that which is left the shovel blade. on the shovel and distorts test results. SIDE YIEW , EE{NSOIDI$Ir DO}-OT S^STiPI.EIT tr-\ OrlOSIIE ,/ E SIDE 6.2. Sampling Techniques -Conveyor Belts 6.2.1. Stopped Level Belts 4t Title: Agremax , Fly Ash and Bed Ash ffinss Sampling Procedure Prepared by: soP-ccP-002 Reviewed by: Carlos Gonzalez 6.2.2. To sample a level Doc #: Area: Eitel Fisueroa Effective Datq05-21-14 CCP Area AES Puerto Rico Guayama, PR Page:5 (eview Date:06-18-15 Supersedes:4-l 3-i of6 Rev#: 2 4 stopped belt simply remove all of the material from a cross section. mNo'Et'L / 7. Sample Area and Frequency 7.1. When taking the sample, the Manufactured Aggegate (Agremax) Pug mill mixer should be in service. The operator shall obtain one sample (5009 recipient) as soon as the system starts operation. 7.2. Representative Sample (Agremax): A third of a 5 gallon bucket shall be obtained every two weeks according ASTM D 75 of the final product of the Aggregate pile. After the representative sample is taken, composite samples shall be deposited in to the bottle (500e). 7.3. Representative Sample (Fly Ash and Bed Ash) of 5 gallons shall be obtained every two weeks according ASTM D 75 in the bin 500 of the AES Puerto Rico, LP Plant. After representative samples of the weekly composites samples shall be deposited in to the boftle (5009). 8. Composite Sample Procedure 8.1. Aggregate Pile - 10 sub-samples each from each side of pile; mix-well in bucket and remove gallon and ship to lab, See below sampling schematic. Take 5 l- A. Sampling Well Mixed Piles: $---r Corrrposite lvlixWell Pl.rce in [raq; adcl ice-pr.rE5; ship to lZrtr +L fl*m Title: Agremax, Fly Ash and Bed fuh Reviewed by: Carlos Gonzalez Doc #: soP-ccP-002 Sampling Procedure Prepared by: Eitel Fisueroa AES Puerto Rico Guavama. PR Page: 6 Effective Date:05-2 I -l 4 leview Date:06-18-15 Area: CCP tuea of6 Rev #: Supersedes:4-l 3-14 2 8.2. FIy and Bed Ash Tank Take 5 - 10 sub-samples each from the tanks during the month; mix-well in bucket and remove a 5009 recipient of the sample and ship it to the laboratory. 9. LabelinsofSamule Sample shall be properly labeled on the recipient with permanent marker and clearly identified as follow: Name of Employee Name ofMaterial Date and Hour Time Frame Represented Test to be performed 10.Samole Receint and Storase All samples will be assigned a "sample Identification Name" prior to preparatory laboratory receipt of samples. Samples will be delivered to the laboratory designated with a proper Chain-of-Custody documents and seals. Upon receipt of samples by the preparatory laboratory, the chain-of-custody documents will be signed and copies must be retained with other preparatory documentation. Upon receipt of samples, samples will log and stored based on either the original Sample Identification Name. 4j Appendix 8.2 Agremax April 2014 TCLP Results KS (TDBH) ,{ffi, BECKTON EIWIRONMENTAT LABORATORIES. INC, REPORT OF ANALYSIS ATTENTION: Mr.HActorAvila COMPANY: DATE: Aprit 11,2014 AES puerto Rico - Guayama CONTRACT: AES-Guayama SAMPLE IDENTIF CAT ON: SAMPLER: MATRIX: BEO ASH GIienT Sotid SAMPLE WTIVOL: _ZL(g/mL)_g_ LAB. SAMPLE ID: LAB. FILE ID; BEL-1401289 1401285 o4na14 ANALYST: DATE DATE DATE DATE BTR (Metals) Hs (Hs) SAMPLED: RECEIVED: EXTRACTED: ANALYZED: o4t0a14 utur14 (fcLP) Mn7n4 (Metqls) 04/09/14 (Hg) MAXIMUM CONCENTRANON OF CONTAMINANTS FOR CHARACTERISTTC OF TCLP TONCITY METALS (SW 846 601OCn4?OA' D0(X Arsenic Barium Cadmium Ghromlum D(X)5 D008 D007 D008 D009 D010 Lead Cerlifrcation and release of the 5.0 0.001 0.001 0.001 0.001 100.0 1.0 0.00012 0.014 <0.001 (MDL)'The minimum concentraition [ffictoliiimil that the value is above 261tl. Manage/s Designee. Sample 0.00'l 0.568 <0.00'l 0.064 0.011 Meroury Selenium Silver DO11 <0.001 0.00005 0.002 0.001 5.0 5.0 o.2 1.0 5.0 of a substrance that can be measured and reported with g9% confrdence ofAnalysis has been authorized by the Laboratory Manager or the ple submitted, Lcda. Laboratory Director Chemist License 2370 Allachmant: THE NELAC CERTIFIED ANALYSES MEETALL REOUIREMENTS OF NELAC STANDARDS. OUR SERVICE DEPAFTMENT FOR THE CUFRENT L ST OF CEFTflF ED ANALYSES. CERTIFIED BYTHE STATE OF FLORTDA DEPARTMENTOF HEALTH AND REHABILITATION SEtrICES FOR ENVIRONMENTAL TESTING REiEI ie2vrLr-ASrFEEr.rd?:Fl'El"il': ri:T="f.?'5iffi :lrnr.FA,(oe4a41.73rg 4'5 EECKTON ENVINONITEilTAL IJ,BORATORIES 192 Villa Strcct . Poncc, PR 00?:10-48?5 CHAIN rer.7E?.841-?373 . pa.{ Far zrz.sar-r3ii -?3t3 'yfs PROYECTNO SAMPLE LOCAT ION/CLTENT t General Envrronrrnnl: AcidiE Ammooia as N PC Alkolrniry I Bicarbonate Bromide Chlorine, Res Chlonde coD Conductiritylohos/m( Dissolvcd Orygco ( Hardncss vss Y-zTE pc ( BODS Moistorc ?6 Nltriac O,l+Glcosc Phenol Phosphorus, Toral Sctl Sohds mg/L Sulfale CONTROLNO i L7 4472 SamplingWitness; Color(ADMtl ) ) ) ( 'f#\t 4,.*',-*- 6"*rt D SAMPLE DATE I REVISIO,T- 2009 OF CUSTODY RECORD Color(R{o) Cyanide Fluonde lodrde Nltrate Nrtralc + Nilrirc pH, S.U Phosphate, Onho Sctr Solads rnul, Softds, Total .Sulhdc Su.factant TSS SulIih TDS Tcmperaturc,.C TOC Asbestos Turbidtt_c TVS Carbonatc Date/Time: TKN Total Nitrogcn 2. Metalsl Aluminum (Al) Ckomiurn lron Mantancc Nickcl Srher Zinc Bonum Antrmory Cadmium Coppcr Lesd Mercury (Cr) (Fit (Mn) (Nr) (.agt Sclcnium Ttn Arscnrc Boon (Z'nl (Ba) (Sb) Beryllium Bismuth (8t Calcium Cobalr Chromium, VI (CrVl) ( Magnesium (MS) ( Po'.ssium (K) Date/Time: (Cd) (Cu, Received by: (Pb) (Hgl (Sc) (Sn} Matrix (As) air ( ) water ( ) liquid( ) soil ( ) oil ( ) mixed( ) (B) (Be) (Ca) (Co) Molybdcnum {Mo} Silicon ( ( Sodjum (Na) Thallium (Tl) ( Vanadium (V) ( studge( ) sotid Ip) orher (l) Speci$: (SD Stsondum (S4 Tilanium Lithium (Ti) (L0 I. Cool,<6oC 6. Sodium Hydroxide(NaOH) 3. RCRA./Harardous uzsrcs IgnMbiliry (Flash ) Conosility 2. Sulfuric Acid (H.SO.) Rcactiviry (Cl.l & TCLP 3.Nitric Acid(HNO3),pH<2 g.AscorbicAcid Pt.)( S) ( ) RCRAMctals (+l Organics-BNA ( ') Organics-PesUHcrb Organics-V0A TOX 4. Spccific Organics Phenols GC Voluilcs Scmi-Volitilcs (BNA) ( PCB} Only TPt{418.1 TTO TPH 8(lI5 Lhdanc Pcsticidcs/PC8's Herbicidcs BTEX TTO & Droxin 5. Microbiology Fecal Coliform Toul Coliform pH<2 (HCl) Thiosulfate T. Zinc Aectate 4. Hydrochloric acid 9. FAS 5. Sodium l0.Other Sample type legend: composite samples xx time: Sampling Equipment: I day ( ) Automatic Sampler ( ) 2 days ( ) Sample Pick Up ( ) 3days ( ) 5days ( ) Turnaround = Note: Originat nomd tumaround time is ren ( l0) norking dals; addilional charges appl,v for rush orden 4lt BECKTON ETWIRONMENTAL LABORATORIES,INC. REPORT OF ANALYSIS ATTENTION: Mr..HecrorAvih GOMPANY: DATE: April11,2014 AES Puerto Rico - Guayama CONTRAGT: AES-Guayama SAMPLE IDENTIFICATION: . MATRIX: SAMPLER: FLYASH Ctient Solid ANALYST: ffi Hs LAB. SAIT,IIPLE ID: LAB. FILE ID: , SAMPLE WTNOL:'.-25 (g/mL)_g_ DATE DATE DATE DATE (Metals) (Hg) , SAMPLED: RECEIVED: EXTRACTED: ANALYZED: BEL-1401290 uo12sa urcu14 unu14 o4tun4 ocLP) 04107t14 (Metals) 04/09/14 (Hg) MN(MUM CONCENTRATION OF CONTAMINANTS FOR CHARACTERISTIC OF TCLP TOXICITY BEL-'I'Ot290 EPA HAZA,RryUS WASTE NUMBER CONTAMINANT RESULTS (mgll! METTIf,D DETECTION LIMIT (mSrL) REGULATORY LEVEL (mgrl) METALS (SW 846 6010Cr470A) D004 D005 D006 D007 D008 D009 D010 D01'l Arsenic Barium Cadmium Chromium Lead Mercury Selenium Silver <0.001 1.30 <0.001 0.087 0.014 0.00008 0.081 <0.ff)l 0.001 0.001 0.001 0.001 0.001 5.0 100.0 1.0 5.0 5.0 o,2 0.00005 0.002 0.00'l 1.0 5.0 Method Detectjon Limit (MDL)-The minimum concentration of a Eubstanc€ hat can be measured and reported with that tie value is above zero Certification and release of 990,6 confidence ol Analysis has been authorized by the Laboratory Manager or the ole submifted. Managels Designee. Laboratory Director Chemist License 2370 Attachment: Chain of Cuslody Record (l) g-TL,tSlltttl@rr THE NELACCEh loFl ALL REeutREMENrs oF NELAc srANDARbs. REFERouRsEBvrcEoEPARrMENrFoRrHEcuiiEr,rilrdi6i'c'enr?T#;tfi L'isli;. cEFfrlFlED BYrHE srArEoF FLoHIDA DEPAFTMENidI*ttl.lplflglqeloruGnvri?s ron ENvTRoNMENTALTESTfNG r e2 vtLLA srFEEr.'il?:fi'[i?:l':lu,iyHf?r.titr?.i.r, . FAx (7Bn 84, -7s1s 4l BEe KT(}.Y Ei\ivIRO.\- ITENTA L r.A BORATORIES 'i:,';H:fi:i, ;]i;J;ff#il' PROYECTNO "o*fi e5 t Fn,-W d,g- ?- SAMPLE LOCATIONrcLIENT ID SAMFLE DATE Gcncral Environmenol: ( Ammonia as ( Acadaty N BOI).5 Chlonde coD rc rc vss Alhohnity ( Bicarbonate Bromrde ( Chloilnc, ( Color(ADMI) Color(Pt4o) Conducnvrty fmioy'or ( Drssolvcd Oxygcn oi6 Res. Nitrutc Niratc + Nitrite Phenol pH, S.U. Phosphorus, Toral Phosphuc, Ordro ScttSoti& mg/L S€tr Soltids mUL Sulfate Solids, Toral Sullite Sultidc TDS TcmF€nturc, TOC Asb.saos Surfactont TSS € TKN Turbidrty ws Csrbonate Toul Nilrogcn 2. Mcrals: Aluminum (Al) Chromium (C0 Cadmium (Cd) (Cu) Sclenium (Se) (Sn) Coppcr Leod (Pb) Mcrcury (le) (Fc) Mangonesc (Mn) Nickel Srlver Zinc Boriunr (Ni) (Ag) (Zn) (Ba) Antimony Trn Arscnic Boron (Sb) Bcryllium Calcium Cobalt (Bi) Chrorniurq VI (CrVt) Magncsium (Mg) (Na) (Tl) 3 Silicon (Sr) (S0 Lithirrm (Tr) (L0 Pt.)( ) Conosivity S) ) TCLP ( oo !cne.u1{s, Organics-BNA ( TOx ( Volaulcs Pcstrcides/PCB's Hcrbicrdcs BTEX fiO & Dioxin Organics-PcstlHerb ( ( ( ( Presenative Codes = PC Cool,<6oC 3. Nitric Acid (HNe), 5. Sodium ( Scmi-Volitilcs(BNA) ( PCB's Onty I TTO TPH 8OI5 Lindane Coliform ( Total Coliform 6. Sodium Hy&oxide(NaOH) 7. Zinc Acetate S.AscorbicAcid l0.Other Sample type legend: composite ( ) ( ) 3days ( ) Sdays ( ) 5 Microbiotogy Fccal Thiosulfate TPt{4lE ( pH<2 pH<2 2. Sulfuric Acid (HrSO,) O4anrcs.VOA PhenolsGC 4. Specific Orgmics Specify: l. RCRA/Hazardous $astc! lgnitability (Flash Rcactivity (CN & air ( ) warer ( ) sludge( ) liquid ( ) soil ( ) solid V) oil ( ) mixed( ) orher (tl (8) (Be) (Cal (Co) Slrsntiurn Trtanium Vanadrum (V) Date/Time: Received by: fAs) Molybdcnum (Mo) por"ssium (K) Sodium Thallium tvolzT9 L7 4477 SamplingWitness; lodide Orl+GEss. Bismuth BEL. NO CONTROLNO Cyamdc Fluoride Hardncss lrnn f :30 w^ TIME -,t4 I Moisturc Natrirc REVTSION 2009 cHArN oF cusroDyRrcoRr) I day 2 days Comments: Note: Original samples xx Automatic Sampler ( ) Sample Pick Up ( ) nomlll turnaround time is ten ( 0) norting da1,s; additional chugesapplv for rush orden. 4E BECKTON EIWTRONMENTAL o LABOMTORTES,INC. REPORT OF ANALYSIS ATTENTION: Mr.HdctorAvita GOMPANY: DATE: Aprill'1,2A14 AeS puerto Rico - Guayama CONTRACT; AES-Guayama SAMPT: fDENT F CAT ON: AGREMAX SAMPLER: Ctient MATRIX: Solid SAMPLE WT/VOL: ANALYST: LA8. SAMPLE ID: :Q_(S/mLb* BTR (Metals) E' (Hs) BEL-14012S1 LAB. F]LE ID: 1401291 DATE SAMPLED: DATE RECEIVED: DATE EXTRACTED: DATE ANALYZED: Mnu't4 unz14 an4n4 $cLP) a4n7l14 (Metals) 04/0e/14 (Hg) MN(IMUM CONCENTRATION OF CONTAIIINANTS FOR CHARACTERISTIC OF TCLP TOXICITY BEL-l401291 EPA HAZARDOUS WASTE NUMBER CONTAMINANT RESULTS METHOD DETECTION LIMIT (mgIL) (mgrL) REGULATORY LEVEL (mglL) METAL! (SW 346 6O10Cr47OA) D004 D005 D006 D007 D008 D009 D010 Dot1 Arsenic' <0.001 Barium Cadmium Chromium Lead Mercury Selenium Silver 0.335 <0.00'l 0.034 0.012 <0.00005 0.066 <0.001 0.001 0.001 0.001 0.001 0.001 0.00005 0.002 0,001 5.0 100.0 1.0 5.0 5.0 0.2 1.0 5.0 M;h-od Det#fion limit (MDL)-The minimum concentration of a substance that oan be msasu]ed end report€d with g9% confidence hal the value ls above zerb Certificalion and release of Manage/s Designee. of Analysis has been authorized by the Laboratory Manager or the sample submittad. Lcda. PAGE I OF , THE NELAC ALL REOU]BEMENTS OF NELAC STANDARDS. BEFER OUR SERVICE DEPARTMENT FOF THE CUBRENT LIST OF CEBTIFIEO ANALYSES. CERTIFIEO BY THE STATE OF FLORIDA DEPAHTMENT OF HEALTH AND REHABILITANON SERI/ICES FOR ENVIRONMEMTAL TESTING re2vrLr-AsrREEr.r""'.TFl'ilH': r!:y.'r:?,5t1fr i-'r.r..FAx(zs7)841-7s1s 41 I ECKTOTT.. ENVlROtti$tENTAL LABORTTTORIES i,:li*:!1J$T*,9i.';il' PROYECTNO REvrstoti cHArN oF cusroDy REcoRD 2009 coMP4; / 2 lqr* u SA.VPLE LOCAIION/C'I-IENT ID l. Gencral Envronrncnul Acidiq. PC pc vss SEL. NO. H CO\TROLNO. lrlotz ?l L7 4478 SamplingWitness; Alkahnig Ammonia as N Bicarbonate BOT}5 Bmmide Chloride Chlorine, Rcs coD Color(ADMIy Condrrtivity ;rrnhorto { Disolved Oggen Color(Pt-Co) Cyuridc Hardncss Moisrurc 96 Nitrirc Phosphorus, Tolal ( ( { Phosphatc, Ortho Sctl. Solidc mL{. Solids, Toul mg& Sulfotc Sutfite TDS Tcrnperature, ( Fluoridc lodide Nitratc Nitrste + Nrtriti pH, s.U. Oil+Grcasc Phcnol Sctr Solids 1'Jo TIME 4- Z - - l/ SAMPLEDATE Sulfidc Sufactana TSS € T(rc Date/Time: TKN Asbesaos Turbidity rys Carbunale Total Nrtrogen 2. Metals' Aluminum (Al) Chromium (Cr) lron (Fe) Mangancsc (Mn) (Sb) Bismuth (8,) Chroniulq Vl (CrVI) Magnesiurn (Mg) 1 ( (Pb) Bcryllium (Be) Received b ( Pr)( Rcactivrty (CN & S) ( Silicon (Col Stronrium (Si) (Sr) Lhhium (70 (Li) Titanium ) t,tl ( liquid( ) soit ( ) solid (++ (Ca) MolyMcnum (Mo) 3. RCRA"/Hozardous wastes lgniubility (Flash ) lcqM*F. L€ld Calciurn Cobalt Potassium (K) ( Sodium (Na) ( Thallium (Tl) ( Vanadiurn (V) ( Organics.BNA Coppcr (Cd) (Cu) Mercury (He) ( Selcoium (Sc) ( Tin (Sn) Arscnac (As) Bomn (8) Nrckcl Ni) Srh'cr (Ag) Zinc (Znl Bariunr (Ba) Andmorry Lrale/ I tme: Cadrnium Specify: l. 3. Nitric Acid (HNe), pH<2 5. Sodium Thiosulfate Phenols GC Volatiles Scmi-Volitilcs (BNA) Pcstrcides/PC8's PCBtOnly Hcrbicidcs TPH4IE I BTEX TTO & Droxrn Acid l0.Odrer samples - TTO TPH 80I5 Total Coliform 7.Zinc Acetate 8. Ascorbic Sample type legend: grab composite x samples xx time: Sampling Equipment: I day ( ) Auromaric Sampler ( ) 2 days ( ) Sampte pick Up ( ) 3days ( ) 5days ( ) Turnaround Lrndane 5. Microbiology Fccal Coliform 6. Sodium Hydroxide(NaOH) (HrSe) pHcZ 9. PAS TOX 4. Spccific Organics Cool,<6oC 2. Sulturic Acid Conosivrty TCLP Orgurics-Pcsr/Hcrb Organics-VOA = Note: Original nomal turnuound lirne is ten ( 10) lurking da1.s; additional charges apply for rush orders. 50 Appendix 8.3 Agremax June 2014 TCLP Results KS (T DBH) 5/ BECKTON ENVIRONMENTAL LABORATORIES, INC. REPORT OF ANALYSIS ATTENTION: GOMPANY: Mr. Carlos Gonzdlez AES Puerto Rico - Guayama DATE: June6,2014 CONTMCT: AES - Guayama SAMPLE IDENTIFICATION: #' .3,ooo ToN coMP. Client .' .' ' MATRIX: Sotid SAMPL.ER:,' : SAMPLEWTMOL: :25 (S/mL)_g_ lD: lD: LAB. SAMPLE BEL-14O2378 LAB. FILE 'l401g7g Cfi01t14 DATESAMPLED: DATEREGEIVED: ANALYST: DATE DATE BTR (Metals) HS (Hs) EXTRACTED: ANALYZED: 06n2n4 06/03/14 ffCLp) O6tOStI4 (Metits) 06/05/14 (Hg) TIA)(MUM CONCENTRATION oF CONTAi.IINANTS FOR CHARACfERISTICOF TCLP TOXCITY BEL-I'O2378 EPA HAZARDOUS WASTE NUMBER CONTAtt[INANT RESULTS METHOD DETECTION LIMIT (mdL) {mgtL} REGULATORY LEVEL (mg/L) METALS (SW 846 6010Cfl470A1 ' D004 D@5 D006 Ansenic Barium <0.001 0.001 5.0 cadnitdn 0.070 0.001 100.0 D007 Chromium Lead Mercury Selenium Silver s0.001 D008 D009 D010 D011 0.034 ' 0.004 <0.(xn05 o.124 <0.001 0.001' 0.00005 1.0 5.0 5.0 0.2 0^002 0.001 5.0 0.001 0.001 1.0 l*ffigt-(MDL).Theminimumconcen ralionofesubetanc€ hatcanbemeasuredandreport€dwithg9%confic enca lhat lhe value is above zerc. Certification and release of ManAger's llesigneo of Analysis has been adthorizeO ple submitted. ty qe Labordtory Manager br the Laboratory Director Chemist Llcense 2370 AttaChment: Chain of CuBlocly Record (1) THE NEI.AC CERTIFIEDANAI-YSES MEETALI REQUIFEMENTS OF NELAC STANDARDS. REFER OUB SERI/ICE DEPARITMENT FOR THE CURRENT LI T OF CERTIFIED ANALYSES. GEFTIFIED BY THE srATE oF FLORIDA DEPAFf,MENT oF HEALTH nNo iexnerlnATloN SERVtcEs FoH ENvTRoNMENTALTEsnNc re2vrLLASrREEr.t"J""=:il'il%13l,iyT3.:?r59ffi:?-'rrrr.FAx(7sns41-zsrs 5z- BECKTON ENVIRONMENTAL LAEORATORIES 't,:;iji:H;#1]j};:::i:;ll' ,. l. Ocncra! Entimnrncntal: cHArN oF cusroDy REcoRD JooD Alkalinity Ammonia ss N Bicarborate Bromide Chlorinc. Rcs, BOD.5 Chloride coD Color(ADMI) Conductiviry pnhodm ( Color(R€o) Oxygcn V To'U vss PC Acidity Dissolved REV STON 2009 ( Moisture % PC lodidc Nitrate Nitrite Nirrate + Nifitc pH, S.U. Phosphaq Onho Sen. Solids rnUL Solids, Totol Sulfidc Oil+Grcase Phenol Phosphonrs, Total Scn Solids mg/L Sulf!tc Sulfite TDS S!rfactant Tcmpcraturc, oC TOC Asbcstos TSS TVS Carbonale TKN Relinquished by: Tulbidity Total Nitrogcn 2. Mctolsi Cadmium Aluminum (Al) Chromium (C0 Coppcr (Cu) (Pb) Mcrcury Mangancsc (Mn) (Ba) (Sb) Bismuth (Bi) Strontium (Sr) Lithium (LD Tilanism (Tl) Vonodium (V) 3. RCRA/Hazardous wosles lgnirability (Flash R Rcactivily (CN & S) RCRA Mctols r& Organics-BNA TOX water ( ) sludge( ) soil () solid(,? mixed( ) other (') ( liquid ( oit ( Specify: Preservative Codes: PC (T0 6. Sodium Hydroxide(NaOH) 2. Sulfuric Acid (H'SO.) Conosivity pH<2 7. Zinc Acetate TCLP l_ .' Orgonics-Pest/Herb Organics-VOA PhenolsGC ( , Semi-volirilcs (BNA) ( ) PCB's Only ) TPH 4r8.r TTO TPH 8OI5 Lindanc ) ) air l. Cool,<6'C .x) () 5. Microbiology Fecal Coliform (Co) Silicon (Na) Hcrbicides BTEX TTO & Dioxin . (Cs) Molybdcnum (Mo) (S0 Potassium (K) 4. Specific Orgonics Volatiles Pesticides/PCB's (As) (B) (Bc) Calcium Cobalt ( Matrix (Sn) Eerytlium Chromium, Vl (CrVI) ( Ma8nesium (Mg) ( Sodium Thalliun (Se) Tin Arsenic Boron (Ag) (Zn) Date/lime: (He) Sclcnium (Ni) Date/Time: Received bv: (Cd) (Fc) Antimony 176843 Cyanidc Fluoridc Hardness Nickel Silver Znc Barium CONTROLNO. C Total Coliform (HCl) Thiosulfate 4. Hydrochloric acid 9. FAS 5. Sodium l0.Other Sample type legend: composite Turnaround time: = ( ) ( ) 3days ( ) 5days ( ) I day 2 days Note: Original samples xI Sampling Equipment: . Automatic Sampler ( ( Sample Pick Up , {*h- i tk normal turnalound time is ten (10) rorking days; addilional chuges apply for rush orders. 5A BECKTON EI\TVIRONMENTAL LABORATORIES,INC. REPORT OF ANALYSIS ATTENTION: COMPANY; DATE: June6,.2014 . Mr. Cados GonzAlez AES Pueilo Rlco - Guayama CONTMCT: AES - Guayama sAMpLE ioennRcrriort SAMPLER: MATRIX: :' ' #2 - 3;oo0 ToN corirp. Client SOIId SAMPLE WTTVOL: je!.(glmL)-g_ ANALYST: BTR (Metals) lJe LAB. SAITIPLE ID: LAB. FILE ID: DATE SAMPIED: DATE RECEI\GD: DATE EXTRACTED: BEL-1402379 1402379 oATEAilALYZED!: 06/05/:lt (Metals) o6nu14 o6nu14 o6nu14 crcLPl 06105/14 ' fig) MAXIMUflI CONCENTRATION OF CONTAMINANTS FOR CHARACTERISTIC OF TCLP TOXICITY EPA HAZARDOUS WASTE NUMBER CONTAMINANT .{mslL} '" D004 D005 0006 D007 D008 D009 D010 DOll M.tlt6d EEL-I40237S RESULTS $ErALs (sw Arsenic Barium Cadrnium Chromium Lead Mercu.ry Selenium Silver D6e;iidiit METHOD DETECTION LIMIT (mstl) REGUTATORY LEVEL (mSrLl 646 6orocn4zoAl <0.001 0.049 <0.001 0.036 0.005 <0.00005 o.112 <0.(X)1 5.0 100.0 0.001 0.001 0.001 0.001 1.0 0.001 0.00005 0.002 0.001 ^ 5.0 5.0 0.2 1.0 5.0 Oaol)-riia minirnum concsnbelion of a subslance that can bE ireasured and reported with 99% confidence lhat lhe value is ebirve'zero. Certification and release of lhe Manage/s Designes. of Analysis has been authorized by the Laboratory Manager or the submitled. , lris M. Ch€vere Attachment Chain of Cuslody Record I OFI THE NEI-AC CERTIFIED ANALYSES MEET ALL REOUIREMENTS OF NELAC STANDARDS. REFER OUR. SERVICE DEPARTMENT FOR TIIE CUR RENT LIST O F CEHTI FI ED ANALYSES. CERTIFIED BY THE STATE OF FLORIDA DEPARTMENT OF HEALTH AND REHABILTTATION SEFVICES FOR ENVIRONMENTALTESTING I CERTIFICATION NUMBER E87556 o ise yt[u STREET. PoNcE, pR ooTso-4o7s .TEL. (787) s41-7izs I Fnx g87] s41-zgta 5+ REVISION BECKTON ENVIRONMEMAL LABORATORIES ' l:,:il1:tr1; ,":"J;'fi,'jlil;lll' PC Acidiry Ammonia as N BOD-5 Chloride Oxygcn Hardncss c/o .Nitritc Oil+Grcase Moisture Phosphorus,Tolll Nirrare + Niriae pH, S.U. Phosphate, Onho Sctt. Solids mUL Solids. Total Sulfidc Surfactant TSS ( € TOC Asbestos TKN Tubidily TVS Cartonate Relinquished by: Total Niuogcn 2. Mctals: Aluminum (All Chronium (Cr) Manganese (Mn) Nickcl Silvcr Zinc Barium Anti.nony (Ba) (Sb) (Ns) (Tl) (V) Datefime: Tin Arsenic Boron (Sn) Bcryllium (B€) (Ca) Matrix air ( ) water ( ) sludge( ) liquid( ) soil ( ) solid qi oil ( ) mixed( ) other ( ) (As) (B) Specify: ( Merols (I) OBrnics-BNA ( ) rox() : T Oryanics-Pest/Herb Orgonics,VOA ( ) Seni-Volitiles (BNA) ( ) PCB's ) ) Only TPH4r*.r TTO TPH 8015 Lindanc Torai coliform 6. Sodium Hydroxide(NaOH) pH<2 7. Zinc Acetate , 8. Ascorbic Acid pH<2 3. Nitric Acid (HNO,), 9. FAS 4. Hydrochloric acid (HCl) 5. SodiumThiosulfate lO.Other TCLP GC Cool,S6"C 2" Sulfuric Acid (HrSOo) Conosivity Phenols 4. Spccific Organics Preservative Codes: PC L J. RCRA/Hazardous wastcs lgnftebility (Flash Pr.)( ) Reoctivity (CN & S) ) RCRA 5. Microbiology Fccal Coliform (Hg) Silicon (Si) Srontium (Sr) 'l'itanium (T1) Lithium (Li) Potassium (K) ( Pcrticidcs/rcB's ( Herbicidcs ( BTEX il ( TTO& Dioxin Mercury Date/Timer Received bv: (co) MolyMenum (Mo) Magncsium .(Mg) Volatilcs Copper (Cd) (Cu) (Pb) Calcium Cobalr (Bi) Chmmium,Vl(CrVl) ( Sodium Cadmium Sclcnium '(Sc) (Ni) (Ag) (Zn) Bismurh Thollium Vrndium SamplingWitness; Date/Time: Relinquished by: Nitrate Sulfate Sulfite Tcmpnturc. REcorD Color (Pt-Co) Cyanidc Fluoride lodide ( ( ( ( ( Sefl Solids mg/L TDS. DY Color(ADMI) Conducrivity pnl0vm ( Dis.solvcd - Bicarbonate Bromide Chlorinc, Res- ( ( sro pc vss Alkalinity, ( ( ( coD c HA I N o F c u 2OO9 Sample type legend: samples grab composite ( ( ( ( x samples xx Tirrnaroundtime: SamplingEquipment: ( I ( day. 2 days 3 days 5 days Note: Original ) ' Automatic Sampter ( ) /) ) Sample Pick Up ( \ I lL,rrtr ) normal ilmaruund time is ten (10) wo*ing days; additional charges apply for rush orders. 55 , BECKTON ENVIRONMEITAL LABORATORIES, rNC. REPORT OF ANALYSIS ATTENTION: COMPANY: ' DATE: June 6.2014 Mr.'Carlos Gonzdlez AES Puerto Rico - Guayama CONTRACT: AES-Guayama SAMPLEIDENTIFICATION: #iT-3,OOOTONCOMP. SAMPLER:. MATRIX: Client Solid SAMPLE WTTVOLj Jl(dmt)_s_ I.AB. SAMPLE ID: LAB. FILED: .: .DATE SAMPLED: DATE RECEIVED: DATE EXTRACTED: ANALYST: BTR Hs (Metals) (Hg) DATEAI{ALYZED: 'BEL-I402380 .'1402380 : 06nu14 o6nafi 06/03/14 OCLP) 06rc5[14 (Metals) 06/05/1a (Hg) ilIAXIMUM CONCENTRATION OF CONTATIIIINANTS FOR CHARACTERISNC OF TCLPTOXICITY METHOD DETECTION LIMIT REGUI-ATORY RESULTS (msrl). (tirgrL) (mgrl) BEL-l402360 . EPA.HAZARDOUS WASTE NUMBER , LEVEL.' METALS (SW 646 60r0cn470Al D004 D005 0000 D007 D008 " D009 0010 D011 Arsenlc -. MetffiEGffi_ Barium Catlmium Chromium Lead Mercury."' Selenium. Silver <0.001 0.098 <0.001 0.029 .0.offi 0.001 0.001 0.001 0.901 5.0 100.0 1.0 5.0 O001:. 5.0 <0.00005 0.104 0.00005 0:002 o2