700888050
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUND-HATER
TASK FORCE
GROUND-WATER EVALUATION Of
WASTE MANAGEMENT Of ILLINOIS, Inc.
ENVIRONMENTAL SANITARY LANDFILL
JOLIET, ILLINOIS
( MAY 1989 )
JOHN J. MCGUIRE
PROJECT COORDINATOR, REGION V
ENVIRONMENTAL SCIENCES DIVISION
CENTRAL DISTRICT OFFICE
Au't'N'Jr
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UPDATE OF THE HAZARDOUS WASTE GROUND-WATER TASK FORCE
EVALUATION OF ENVIRONMENTAL SANITARY LANDFILL, INC.
ELWOOD, ILLINOIS FACILITY
The U.S. EPA's Hazardous Waste Ground-Water Task Force, in
conjunction with the Illinois Environmental Protection Agency
(IEPA), conducted an evaluation of the Environmental Sanitary
Landfill (ESL) hazardous waste disposal facility. ESL was the
48th of 58 hazardous waste treatment, storage, and disposal
facilities to be evaluated by the Task Force. The Task Force
effort is in response to recent concerns as to whether owners
and operators of hazardous waste disposal facilities are
complying with the RCRA ground-water monitoring regulations, and
whether the ground-water monitoring systems in place at the
facilities are capable of detecting contaminant releases from
waste management units. The ESL facility is located in Elwood,
Illinois, which is approximately 3 miles south of Joliet,
Illinois. The on-site field inspection was conducted from March
16 through March 20, 1987.
The purpose of the Task Force evaluation was to determine the
adequacy of the ground-water monitoring system in regard to
federal ground-water monitoring requirements. Specifically, the
objectives of the evaluation at ESL were to:
Determine compliance with 40 CFR Part 265 interim
status ground-water monitoring requirements
Evaluate the ground-water monitoring program
described in the RCRA Part B permit application for
compliance with 40 CFR Part 270.14(c)
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o Determine if hazardous waste constituents have
entered the ground water at the facility
At the time of the inspection, the facility had a total of 41
RCRA ground-water monitoring wells. The number and position of
these RCRA wells were determined from a 1984 supplemental
permit issued by IEPA to modify the previous monitoring network
to provide adequate monitoring of the uppermost aquifer
surrounding the perimeter of waste management activities.
Downgradient monitoring wells G-139 and G-140 have a history of
organic contamination. These two wells were not sampled at the
time of the Task Force inspection because Waste Management
Incorporated (WMI) had installed inflatable packing devices in
the wells. The inflatable packers were installed to prevent
contaminants from reaching the ground-water through the well
casing after an August 25, 1986, borescope inspection of the
wells revealed cracks and red staining below the cracks.. IEPA
issued Supplemental Permit No. L986-221-SP to WMI replace wells
G-139 and G-140. Once the replacement wells have been
installed, developed, and approved by IEPA, wells G-139 and G-
140 may be decommissioned and future sampling efforts can be
concentrated on the replacement wells.
Three replacement wells have been installed at ESL since the
March 1987 inspection. Well R-139 replaces well G-139 and wells
R-40S (shallow) and R-40D (deep) are the well cluster
replacements for well G-140. Subsequent sampling results
indicate a continued problem with organic contaminants in this
vicinity. A list of organic contaminants detected in the
replacement wells in 1987 and from subsequent sampling in 1988
is shown in Table A.
WMI maintains that the source of the hazardous waste or
hazardous waste constituents detected in old well G140 and well
R40D are the result of contaminants moving down through a
cracked casing in former well G140. Though a crack in the
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casing of the former well G140 was documented by videotapes of
borescope investigations, the source of the contamination which
may have entered this casing has not been identified. WMI has
stated, in their August 26, 1986 Assessment Report, that the
exact pattern and source of seepage (into well G140) is not
known. They stated that one possibility was surface water
seeping down from the landfill and stone access road. This
hypothesis still fails to address a source of contamination,
since surface water would only come into contact with clean
soil overlaying a clay cover, and should never come into contact
with hazardous waste or hazardous waste constituents. The clay
cover itself has been described by WMI (in their May 4, 1988
Closure Plan Revision) as consisting of a minimum of 2.5 feet of
compacted fine-textured soil with an average permeability of 2.2
x 10~8 cm/sec. Furthermore, well G140 was protected with a
concrete collar (i.e., concrete apron) and was grouted with
cement/bentonite mixture to prevent infiltration of surface
water runoff into the well. Alternatively, WMI has stated, in
their August 26, 1986 Assessment Report, that gas has also been
detected in the well headspace of G140. They have postulated
that the crack in the well may be the avenue through which gas
entered G140. They further stated that the gas from the
landfills carry liquid with it, that the liquid condenses when
it is exposed to cooler air, and the seeping into G140 (assumed
from borescope investigations) may be this gas condensate. But
again, WMI failed to identify the source of contamination, since
this well was not finished in a landfill, it was located at
least 25 feet south of the edge of the landfill, and it was
isolated from the landfill by a ten foot clay liner of similar
quality to the clay cover described above.
WMI has yet to prove that the small crack in the casing of well
G140 is responsible for introduction of contaminants of the
variety and concentrations that have been so persistent in
groundwater samples from this area. Assuming the cracked casing
did allow contaminants to impact groundwater quality, WMI has
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also failed to identify the source of these contaminants. The
contaminants that have been identified in groundwater samples
from this area thus far are also those that have been identified
in leachate samples from the Area 1 co-disposal landfill.
It is concluded, from review of the data that has been presented
thus far, that the Area 1 co-disposal landfill is the source of
groundwater contamination by hazardous waste or hazardous waste
constituents, and WMI has failed to provide convincing evidence
to the contrary.
WMI submitted a closure plan for its RCRA-regulated hazardous
waste management units at ESL in February 1988. The closure
plan includes the surface impoundments (Ponds 5 and 6),
container storage facility, decant facility, co-disposal
landfill, and drum disposal trenches.
In May 1988, WMI requested that it's Part B Permit application
be withdrawn and in November 1988, IEPA formally granted that
request.
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Well
RU9
R40S
R40S
R40S
R400
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R400
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R400
R40D
R40D
R40D
Sample
Date
05/06/87
08/05/87
11/05/87
02/26/88
05/06/87
05/06/87
05/06/87
05/06/87
05/06/87
05/06/87
05/06/87
05/06/87
05/06/87
05/06/87
05/06/87
05/06/87
05/06/87
05/27/87
07/10/87
07/10/87
07/10/87
07/1 0/87
07/10/87
07/1 0/87
07/10/87
08/05/87
08/05/87
08/05/87
08/05/87
08/05/87
08/05/87
09/1 0/87
09/10/87
09/10/87
09/10/87
09/1 0/87
09/10/87
10/02/87
10/02/87
10/02/87
-10/02/87
1 0/02/87
10/02/87
11/05/87
TABLE A
ORGANIC CONTAMINANTS DETECTED IN REPLACEMENT WELLS
Parameter Cone.
Methylene Chloride 9.4 ug/1
Methylene Chloride 29.0 ug/1
Methylene Chloride 43.0 ug/1
Methylene Chloride 10.2 ug/1
1,1 -01 chloroethane 225.0 ug/1
1,2-Dichloroethane 34.2 ug/1
Methylene Chloride 4.11 ug/1
1,2-Dichloropropane 14.3 ug/1
1,2-trans-Dichloroethylene 254.0 ug/1
Trichloroethylene 13.0 ug/1
Trichloroethylene 14.7 ug/1
Vinyl Chloride 63.6 ug/1
Chromium (total) 178.0 ug/1
Iron 37.5 mg/1
Iron 37.5 mg/1
Hexachlorophene 104.0 ug/1
Kepone 1.39 ug/1
Trichloroethylene 13.0 ug/1
Benzene 5.58 ug/1
1,1-Dichloroethane 216.0 ug/1
1,2-Dichloroethane 25.0 ug/1
1,2-Dichloropropane 15.2 ug/1
1,2-trans-Dichloroethylene 196.0 ug/1
Trichloroethylene 13.1 ug/1
Vinyl Chloride 69.1 ug/1
l,l-D1chloroethane 130.0 ug/1
1,2-01 chloroethane 18.6 ug/1
1,2-Dichloropropane 10.2 ug/1
l,2-trans-D1chloroetnylene 93.5 ug/1
Trichloroethylene 6.38 ug/1
Vinyl Chloride 36.5 ug/1
1,1-Dichloroethane 131.0 ug/1
1,2-Dichloroethane 17.7 ug/1
1,2-Dichloropropane 9.98 ug/1
1,2-trans-Dichloroethylene 84.5 ug/1
Trichloroethylene 8.25 ug/1
Vinyl Chloride 32.1 ug/1
1.1-Dichloroethane 107.0 ug/1
1,2-Dichloroethane 16.2 ug/1
1,2-Dichloropropane 7.94 ug/1
Methylene Chloride 7.6 ug/1
1,2-trans-Dichloroethylene 50.0 ug/1
Vinyl Chloride 24.7 ug/1
Methylene Chloride 18.9 ug/1
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TABLE A (Continued)
ORGANIC CONTAMINANTS DETECTED IN REPLACEMENT WELLS
Well
R40D
R40D •'
R400
R40D
R400
R400
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R400
R400
R40D
R40D
R40D
R40D
R40D
R400
R400
R400
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
Samp! e
Date
02/26/88
02/26/88
02/26/88
02/26/88
02/26/88
02/26/88
02/26/88
06/01 /88
06/01 /88
06/01 /88
06/01 /88
06/01 /88
06/01 /88
06/01 /88
06/01/88
06/01 /88
06/01 /88
06/01 /88
06/22/88
06/22/88
06/22/88
06/22/88
06/22/88
06/22/88
06/22/88
06/22/88
06/22/88
06/22/88
07/21 /88
07/21 /88
07/21/88
07/21 /88
07/21/88
07/21 /88
07/21 /88
07/21 /88
07/21 /88
Parameter
l,l-D1chloroe thane
Methylene Chloride
1 ,2-trans-D1chloroethylene
Vinyl Chloride
1,1-Oichloroethane
Methylene Chloride
1 ,2-trans-D1chloroethylene
Chi oroethane
Dichl orodi fl uoromethane
1,1-Dichloroethane
1,2-Dichloroe thane
1 ,2-D1chloropropane
Methylene Chloride
1 ,2-trans-Dichloroethylene
Trichloroethylene
Tri chl orofl uoromethane
Chi orome thane
Vinyl Chloride
Chl oroe thane
Chloromethane
Di chl orodi f 1 uoromethane
1,1 -Dichl oroethane
1,2-Dichloroe thane
1 ,2-Dichloropropane
Methylene Chloride
1 ,2-trans-Dichloroethylene
Tri chl orofl uoromethane
Vinyl Chloride
Chl oroethane
Dichl orodi fl uoromethane
1,1-Dichloroethane
1 ,2 -Dichl oroethane
1 ,2-Dichloropropane
1 ,2-trans-Dichloroethylene
Trichloroethylene
Trfchl orofl uoromethane
Vinyl Chloride
**
Methylene chloride detected in 6/22/88 field blank at
4.64 ug/1.
Trichojrofluoromethane detected in 6/22/88 field blank
at 10.0 ug/1.
*** Trichlorofl.uoromethane detected in 7/21/88 field blank
at 1.2 ug/1.
Cone.
87.5 ug/1
9.79 ug/1
30.5 ug/1
20.9 ug/1
70.3 ug/1
7.63 ug/1
29.8 ug/1
1.8 ug/1
6.7 ug/1
57.0 ug/1
7.1 ug/1
3.3 ug/1
1.8 ug/1
21.0 ug/1
3.3 ug/1
2.8 ug/1
2.0 ug/1
6.7 ug/1
3.5 ug/1
5.0 ug/1
8.3 ug/1
75.0 ug/1
8.9 ug/1
4.6 ug/1
1.8 ug/1 *
19.0 ug/1
13 ug/1 **
8.3 ug/1
1.8 ug/1
4.7 ug/1
46.0 ug/1
5.8 ug/1
3.0 ug/1
12.0 ug/1
1.0 ug/1
1.7 ug/1***
4.7 ug/1
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUND-WATER
TASK FORCE
GROUND-WATER EVALUATION Of
WASTE MANAGEMENT of ILLINOIS, Inc.
ENVIRONMENTAL SANITARY LANDFILL
JOLIET, ILLINOIS
(MAY 1989)
JOHN J. McGUIRE
PROJECT COORDINATOR, REGION V
ENVIRONMENTAL SCIENCES DIVISION
CENTRAL DISTRICT OFFICE
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TABLE OF ULNHNES
EXECUTIVE SUMMARY
INTRODUCTION 1
SUMMARY OF FINDINGS AND CCNCLUSICNS . . . 8
CCMPLIANCE WITH INTERIM STATUS GROUND-WATER IYCNTTQRING - CHAPTER 35
ILLINOIS ADMINISTRATIVE CODE 725 SUBPART F (40 CFR 265 - SUBPART F) . . 8
Section 725.191 (Section 265.91) Ground-Water Monitoring System .... 9
Section 725.192 (Section 265.92) Sampling and Analysis 12
Section 725.193 (Section 265.93) Preparation, Evaluation, and Response . 13
GROUND-WATER PROGRAM PROPOSED FOR RCRA PERMIT 14
TASK FORCE SAMPLING AND MCNITORING DATA ANALYSIS 14
CONFORMANCE WITH SUPERFUND OFF-SITE POLICY 15
TECHNICAL REPORT
INVESTIGATIVE METHODS 17
RECORDS/TORMENTS REVIEW AND EVALUATION 17
FACILITY INSPECTION 18
LABORATORY EVALUATION 19
WATER LEVEL AND WELL DEPTH MEASUREMENTS 19
GROUND-WATER SAMPLING AND ANALYSIS 20
Purging 26
Sample Collection, Handling and Preservation 27
FACILITY OPERATIONS AND WASTE MANAGEMENT UNITS 31
FACILITY OPERATIONS 31
WASTE MANAGEMENT UNITS 32
RCRA-Regulated Waste Management Units 35
Co-Disposal Landfill 35
Drum Disposal Trenches 37
Container Storage Area 38
Decant Facility 39
Surface Inpoundments 42
Trench. 11 43
Pre-RCRA Waste Management Units 43
Surface impoundments 43
Landfarm 44
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Page
SITE HYDRCGEQLOGY ; 45
STRATIGRAPHY 47
HYDROGEOLOGIC UNITS 50
Monitored Composite Aquifer 51
Silurian Transmissive Zones 52
Cambro-Ordovician Aquifer System 53
GROUND-WATER FLOW DIRECTION AND RATES 53
GROUND-WATER MONITORING DURING INTERIM STATUS 60
REGULATORY REQUIREMENTS 60
GROUND-WATER SAMPLING AND ANALYSIS ELAN 61
SAMPLE ANALYSIS AND DATA QUALITY EVALUATION 62
Inorganic Laboratory 63
Organic Laboratory 65
Radiochemistry Laboratory 66
MONITORING WELLS 67
Well Locations 69
Well Construction 72
GROUND-WATER ASSESSMENT PROGRAM OUTLINE 78
GROUND-WATER ASSESSMENT MONITORING 81
Ground-Water Quality Assessment for tne P-Series Wells 81
Ground-Water Quality Assessment for the G-Series Wells 86
STATUS OF GROUND-WATER MONITORING UNDER INTERIM STATUS 91
GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA. PERMIT 92
MONITORING DATA ANALYSIS FOR INDICATIONS OF WASTE RELEASE 93
REFERENCES 97
Appendices
A GROUND-WATER SAMPLE ANALYSES FOR TASK FORCE INSPECTION OF ESL
»
B EVALUATION OF THE QUALITY CONTROL DATA PERTAINING TO THE ANALYSIS OF
SAMPLES FROM ESL
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LIST CF TABLES
Table Page
1 TASK FORCE SAMPLE CQLLECTICN DESCRIPTION ............... 21
2 ORDER OF SAMPLE COLLECTICN BOTTLE TXPE AND PRESERVATIVE LIST ..... 29
3 WASTE STREAMS ACCEPTED BY raf. ..................... 32
4 QUANTITY CF WASTES RhX/KLVED AT ESL CO-DISPOSAL LANDFILL AND DRUM
DISPOSAL TRENCHES ........................... 36
5 PUMPING TEST RESULTS FRCM AQUIFER WELLS ................ 58
6 MCNITQRING WELL CONSTRUCTION DESCRIPTION ............... 73
7 HISTCRIC IKilL'HD QRQ\NIC CCNEAMINANTS REQUIRING INITIATION OF THE
ASSESSMENT PROGRAM .......................... 89
8 ORGANIC ANALYSES FRCM TASK FORCE SAMPLING ............... 96
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LIST OF FIGURES
Figure Page
i SHE LOCATION MAP 3
2 WASTE MANAGEMENT UNIT AND INTERIM STATUS MHTTORING WELL LOCATIONS . . 5
3 WELLS SAMPLED DURING TASK FORCE INSPECTION 24
4 LOCATION OF CURRENT AND PAST WASTE MANAGEMENT UNITS ENVIRONMENTAL
SANTTARy LANDFILL 34
5 GENERALIZED STRATIGRAFHIC COLUMN OF THE GEOLOGY OF THE CHICAGO REGION . 48
6 GENERALIZED GEOLOGIC CROSS-SECTICN OF THE ESL SITE 49
7 COMPARISON OF WATER LEVELS IN UPPERMOST AQUIFER AND COMPOSITE DEEPER
SILURIAN DOLOMITE TRANSMISSIVE ZONES 55
8 LOCATION MAP OF P-SERIES MONITORING WELLS 68
9 LOCATION MAP OF G-SERIES MCNTTORING WELLS 70
10 TYPICAL CONSTRUCTION FOR THE UPPERMOST AQUIFER MONITORING WELLS .... 74
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EXECUTIVE SUMMARY
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INTRODUCTION
Concerns have recently been raised about whether commercial
hazardous waste treatment, storage, and disposal (TSD) facilit-
ies are in compliance with the ground-water monitoring require-
ments promulgated under the Resource Conservation and Recovery
Act (RCRA). Specifically, the concerns focus on the ability of
existing or proposed ground-water monitoring systems to detect
contaminant releases from waste management units at TSD
facilities. In response to these concerns, the administrator of
the U.S. Environmental Protection Agency (EPA) established a
Hazardous Waste Ground-Water Task Force to evaluate the level of
compliance at TSD facilities and address the causes of noncom-
pliance. The Task Force is comprised of personnel from U.S. EPA
headquarters, including the Office of Solid Waste and Emergency
Response (OSWER), U.S. EPA regional offices, and state regulat-
ory agencies. To determine the compliance status of all
facilities nationwide, the Task Force is conducting an in-depth
facility investigations, including on-site inspections, of 58
facilities. The objectives of these investigations are to:
o Determine compliance with interim status ground-
water monitoring requirements of 40 CFR Part 265 as
promulgated under RCRA or 35 Illinois Administrative
Code (IAC) Part 725 (the state equivalent).
a Regulations promulgated under RCRA address hazardous waste
management facilities' operations, including ground-water
monitoring, to ensure that hazardous waste constituents are not
released to the environment.
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o Evaluate ' the ground-water monitoring program
described in each facility's RCRA Part B permit
application for compliance with 40 CFR Part 270.14(c)
and 35 IAC Part 703.185.
o Determine if the ground water at each facility
contains hazardous waste constituents.
o Verify the quality of the facility's ground-water
monitoring data and evaluate the sampling and
analytical procedures.
o Provide information to assist the agency in determin-
ing, if each inspected TSD facility meets EPA's
ground-water monitoring requirements for waste
management facilities receiving waste from the
response actions conducted under the Comprehensive
Environmental Response, Compensation, and Liability
Act (CERCLA, Public Law 91-510)a.
To address these objectives, each Task Force investigation will
determine if:
o The facility has developed and is following an
adequate ground-water sampling and analysis plan.
o Designated RCRA and/or state-required monitoring
wells are properly located and constructed.
o Required analyses have been conducted on samples from
the designated RCRA monitoring wells.
o The ground-water quality assessment program outline
(or plan, as appropriate) is adequate.
One of the TSD facilities investigated by the Task Force was the
Environmental Sanitary Landfill (ESL) facility, also known as
Waste Management Inc. - Joliet (WMI). The 260-acre site
EPA policy, stated in the November 13, 1897 directive on
"Procedures for Implementation Offsite Response actions"
requires that TSD facilities receiving CERCLA waste be in
compliance with applicable RCRA ground-water monitoring
requirements.
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FIGURE 1
SITE LOCATION MAP
Source: Woodward-Clyde Consultants 1982. Geologic, Geotechnical, and
Hydrogeologic Evaluation of Expansion Area to Chemical Waste Management, Inc.
Joliet, Will County, Illinois, July 1982.
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4
is located southwest of the junction of Laraway and Patterson
Roads in Elwood, Will County, Illinois ( see Figure 1). The Des
Plaines River is 1/2 mile to the northwest, and the City of
Joliet is less than 3 miles to the north. The ESL facility is
owned and operated by Waste Management of Illinois, Inc. (WMI).
The Task Force conducted its on-site inspection of the facility
from March 16 through March 20, 1987. The Central District
Office of EPA Region V's Environmental Services Division
coordinated the inspection activities. Personnel from EPA
Region V RCRA Enforcement and Permit organizations and from the
IEPA participated in the Task Force inspection activities.
WMI acquired the site on February 5, 1973, at which time only a
small portion of the co-disposal landfill had been filled.
Little information is available concerning early landfilling
practices at the site. Prior to 1980, the facility operated
five pre-RCRA waste management units:
o Four surface impoundments (Ponds 1 through 4) that
were used to store industrial and municipal sludges
prior to land treatment.
o A landfarm where the industrial and municipal
sludges were sprayed.
The facility also includes the following six RCRA hazardous
waste management units (see Figure 2):
o Co-disposal landfill
o Drum disposal trenches
o Container storage area
o Decant facility •
o Surface impoundments (Ponds 5 and 6)
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FIGURE 2
WASTE MANAGEMENT UNIT AND INTERIM STATUS
a
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6
The hazardous waste management units at this facility received
RCRA hazardous wastes both in bulk form and in containers for
on-site disposal. The facility also received industrial and
municipal wastes for disposal in the co-disposal landfill.
These wastes included waste considered hazardous under RCRA due
to the characteristics of ignitability, EP toxicity, or
corrosivity, and solvents from non-specific and specific
sources. The facility stopped receiving wastes in Spring of
1984. Since 1984, materials generated from the decommissioning
and closure of several units have been disposed of in the
landfill. The facility was inactive at the time of the Task
Force inspection.
WMI submitted a RCRA Part B permit application on August 29,
1983, and has since received several notices of deficiency
(NODs) from U.S. EPA and IEPA regarding the application. WMI
has submitted revisions to U.S. EPA and IEPA of its RCRA Part B
permit application in response to the NODs.
The site is underlain by approximately 30 feet of glacial
sediments consisting of a till unit over a glacial outwash unit.
These glacial sediments lie atop the lower Paleozoic bedrock
sequence of sedimentary rocks. WMI's consultants have iden-
tified three major hydrologic units beneath the site. The
uppermost portion of the bedrock contains ground water in
fissures, joints, bedding planes, solution cavities, and
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7
crevices. WMI's consultants have determined that the glacial
outwash unit and the weathered and fractured bedrock immediately
beneath the outwash are hydraulically connected and, therefore,
the facility considers this composite unit to be the uppermost
aquifer. The U.S. EPA and IEPA agree with the designation of
this combined unit as the uppermost aquifer. Ground water in
this aquifer flows primarily in a northwest to westerly
direction across the site, toward the Des Plaines River.
An interim status ground-water monitoring system consisting of
41 wells (G-series) have been in place since March 1984 (see
Figure 2). This system consists of four upgradient wells (G-lll
through G-114) and 37 downgradient wells at the limits of the
waste management areas to monitor the uppermost aquifer. This
system replaced the previous system of eight wells (P-series)
which was not considered by IEPA to be adequate to monitor the
ground water in the uppermost aquifer. Five wells are also in
place (GT-series) to monitor the ground water in the glacial
till, overlying the glacial outwash. The Task Force sampled 26
monitoring wells during the March 1987 inspection, including 2
GT series wells. The GT-series well system was sampled and
evaluated to aid in assessment of the adequacy of the RCRA
interim status ground-water monitoring program.
-------
8
SUMMARY OF FINDINGS AND CONCLUSIONS
From March 16 through March 20, 1987, Task Force personnel
investigated the RCRA compliance of the interim status ground-
water monitoring program at the Waste Management of Illinois,
Inc., ESL facility in Elwood, Illinois. The interim status
ground-water monitoring period began in November 1981 when
applicable provisions of the RCRA regulations became effective.
The findings and conclusions presented in this report reflect
conditions existing at the facility in March 1987. Later
actions taken by Illinois EPA (IEPA), U.S. EPA Region V, and ESL
are summarized in the update.
COMPLIANCE WITH INTERIM STATUS GROUND-WATER MONITORING - CHAPTER
35 ILLINOIS ADMINISTRATIVE CODE 725 SUBPART F (40 CFR 265-
SUBPART F)
WMI installed an initial ground-water monitoring system (P-
series wells) in January 1980 at its ESL facility. Six of the
eight P-series wells exhibited significant changes in indicator
parameters in the Spring of 1983, triggering these wells into
ground-water assessment monitoring. The P-series wells were
characterized as being insufficient to adequately monitor the
ground water at the facility. In December 1983, WMI submitted
an application to IEPA to modify the ground-water monitoring
program. IEPA issued a supplemental operating permit to WMI to
modify the ground-water monitoring system.
-------
9
WMI installed the new RCRA ground-water monitoring system in
March 1984. This monitoring system consists of 41 ground-water
monitoring wells (G-lll through G-151) which are screened in the
uppermost aquifer. At this time, WMI also installed five wells
(GT-10 through GT-14) to monitor the glacial till located above
the uppermost aquifer. Figure 2 shows the locations of the
waste management units and the interim status ground-water
monitoring network. Based on the results of the August 1985
sampling event, seven of the G-series wells entered the
assessment monitoring phase.
Section 725.191 (Section 265.91) Ground-Water Monitoring System
The Task Force noted several problems with the ground-water
monitoring system in place at WMI's ESL facility at the time of
the inspection. Two of the downgradient wells (G-139 and G-140)
were unavailable for sampling at the time of the inspection
because inflatable packing devices had been installed in them.
WMI stated that the packers were installed by WMI to prevent
contaminants from reaching ground water through cracked well
casings. Well G-139 and G-140 were scheduled to be sampled by
the Task Force because they were two of the downgradient wells
with a history of detected contamination. Both of these wells
were in the assessment sampling phase. WMI presented Task Force
personnel with a waiver of responsibility for ground-water
contamination resulting from the removal of the inflatable
-------
10
packers. The wells were not sampled because (1) U. S. EPA's
policy is not to sign any waiver of responsibility, (2) there
was no method available to sample the ground water below the
packer, (3) these wells have a well documented history of
contamination, and '(4) of the time constraints of the inspec-
tion. Because of the packers in these wells a period of time,
including the time of the inspection, the quality of the ground
water in an area approximately 600 feet along the southern edge
of the co-disposal landfill was unknown
The Task Force personnel noted that for some of the wells con-
structed prior to 1984, discrepancies existed between field
observations and the sampling plan regarding the construction
material. Not all of these wells were constructed using
Schedule 80 PVC pipe. The Task Force is concerned that some of
the wells have excessive screened intervals. The RCRA Ground-
Water Monitoring Technical Enforcement Guidance Document states
that excessive screen lengths can result in the dilution of
contaminants present in the ground water (U.S. EPA, 1986b).
The use of interval sampling in those wells with excessive
screen lengths could possibly reduce the effect of dilution.
However, in situations such as those existing at ESL, with the
wells located in outwash sediments in excess of 40 feet in
thickness, there is no guarantee that dilution would be
completely eliminated because of mixing and vertical communica-
tion. In addition, because interval sampling does not allow for
-------
11
purging of the wells, it is likely that a'representative sample
of groundwater would not be produced. The Task Force also recom-
mends that well clusters be used for any additional monitoring
wells installed at the ESL facility where the uppermost aquifer
is of great thickness. The Task Force recommends that the con-
taminant dispersion model used by WMI's consultants be evaluated
to assess (1) the assumptions it incorporates and (2) the
conversion of the model results to the lateral monitoring well
spacing used at the site. Several deficiencies in the ground-
water monitoring system were also noted at the time of the Task
Force inspection:
o Wells G-136 and G-137 were discovered to be 3.65 feet
and 4.06 feet shallower, respectively, than when they
were originally installed.
o WMI made no provisions for disposing of the ground
water purged from the monitoring wells before the
samples were taken. If sample analyses suggest that
the ground-water is hazardous, it should be drummed
and disposed of properly.
o All of the well construction and many of the sampling
components are made of PVC plastic that can sorb and
desorb organic constituents. The extensive use of
PVC rather than more inert materials could lead to
biased ground-water sample. The use of other
devices, such as stainless steel and dedicated
sampling equipment, would minimize possible
contamination during withdrawal and ensure samples
that are representative of the aquifer.
o Five glacial till (GT-series) monitoring wells are
situated around the perimeter of the waste management
area. WMI indicated that the purpose of these wells
was to detect any contaminants migrating horizontally
through the till and bypassing the wells monitoring
the uppermost aquifer. The number, location, and
spacing of the glacial till wells is inadequate to
meet the outlined objective.
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12
The Task Force, in their evaluation, identified several
deficiencies in the ground-water monitoring program currently
in use at the ESL facility. In addition several flaws were also
noted in the analytical procedures utilized by the facility. The
Task Force concludes that the ESL facility is not in compliance
with the interim status ground-water monitoring requirements of
111. Adm. Code Part 725 or 40 CFR as. promulgated under RCRA.
Section 725.192 (Section 265.92) Sampling and Analysis
The ground-water sampling and analysis plan contained in ESL's
RCRA Part B permit application does not contain any site-
specific guidelines or information-. Task Force personnel
reviewed two other sampling and analysis plans during the
facility inspection. One was a site specific plan dated
November 1985, and the other was a generalized WMI document
dated September 1986. These two documents should be included in
ESL's RCRA Part B permit application.
WMI uses three off-site laboratories to provide analyses of
ground-water samples taken at the ESL facility. The laborator-
ies used by WMI are Environmental Testing and Certification
(ETC) of Edison, New Jersey; Gulf Coast Laboratories of
University Park, Illinois; and Core Laboratories of Casper,
Wyoming. The Task Force noted two deficiencies in the procedu-
res used by Gulf Coast Laboratories in analyzing samples for
-------
13
cyanide. The Task Force noted two deficiencies in the extrac-
tion procedures used by ETC when analyzing samples for pes-
ticides and PCBs and semi-volatiles. Core Laboratories has
been certified by EPA Region VIII for the analysis of radionucl-
ides. Other observations and recommendations regarding the
laboratories appear in full in the Sample Analysis and Data
Quality Evaluation section of this report.
Section 725.193 (Section 265.93) Preparationf Evaluation, and
Response
At the time of the inspection, the P-series monitoring wells
remained at the site, but they were plugged and awaiting
decommissioning. Some of the G-series wells triggered into the
assessment monitoring phase in August 1985 were still in the
assessment phase. The Task Force noted the following deficien-
cies in the facility's ground-water assessment program outline:
o The facility's "Outline of Ground-Water Quality
Assessment Program" is too vague. The outline lacks
sufficient detail that could be used to determine:
(1) whether hazardous waste or hazardous waste
constituents have entered the ground water; (2) the
rate and extent of migration of hazardous waste or
hazardous waste constituents in the ground water; and
(3) the concentration of hazardous waste or hazardous
waste constituents in the ground water.
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14
GROUND-WATER PROGRAM PROPQfiT;;]? fOR RCRA PERMIT
On June 21, 1986 U.S. EPA Region V issued an administrative
complaint and compliance order to WMI for failing to supply
information required to complete the RCRA Part B. permit
application for the ESL facility. Two areas of concern in the
order are: (1) an. incomplete summary of ground-water monitor-
ing data obtained during interim status, and (2) the lack of a
plan for the description of any plume of contamination that has
entered the ground water from a regulated unit.
TASK FORCE SAMPLING AND MONITORING DATA ANALYSIS
Organic analyses of samples from the ground-water monitoring
wells indicated that a release of hazardous constituents .is
probably occurring at ESL. Several wells recorded levels of
organic constituents greater than the contract required
detection levels (CRDL). These wells included:
G-123 (1,2-trans-dichloroethane - 6 ug/L),
G-129 (vinyl chloride - 10 ug/L and 11 ug/L, duplicate),
G-134 (trans-1,2-dichloroethane 7 19 ug/L,
1,1-dichloroethane - 12 ug/L).
The total lead data was judged to be qualitative, but wells
G-117, G-118, G-137, and G-141 all showed increases in total
-------
15
lead levels over the upgradient wells and above the national
interim primary drinking water standard levels. Twenty-one
wells showed total iron levels above the proposed secondary
drinking water standards levels. Other metals were present in
downgradient wells at levels above those found in the upgradient
wells.
Based on historical sampling data and the TasJc Force sampling
data, the Task Force concludes that the ground-water at the ESL
facility does contain hazardous waste constituents and that the
Area 1 co-disposal landfill is the source of the ground-water
contamination. The Task Force recommends that a thorough and
complete evaluation of the plume of contamination be conducted
by ESL, unless they can clearly demonstrate that the contamina-
tion is from a source other than the regulated units.
CONFORMANCE WITH SUPERFUND OFF-SITE POLICY .
The ESL facility was not accepting hazardous waste generated at
a Superfund cleanup site. The pendency of the administrative
complaint citing ground-water monitoring violations rendered the
facility unacceptable, in accordance with u. S. EPA's Off-Site
Policy, to receive Superfund cleanup waste.
-------
TECHNICAL REPORT
-------
17
INVESTIGATIVE METHODS
The Task Force evaluation of tne ESL facility consisted of:
o Reviewing and evaluating records and documents from
EPA Region V, IEPA, and ESL.
o Conducting an on-site facility inspection from March
16 through March 20, 1987.
o Evaluating the off-site contractor laboratories used
by ESL.
o Determining water level elevations and total depths
in selected wells.
o Sampling and subsequent analysis of ground water from
selected monitoring wells.
RECORDS /DQCuT REVIEW AND EVALUATION
Before conducting the on-site inspection, Task Force personnel
reviewed records and documents from EPA Region V and IEPA
offices, compiled by an EPA contractor. Additional IEPA records
were obtained by Task Force personnel after the inspection. On-
site facility records were reviewed" to verify information
currently in government files and supplement government
information where necessary. Selected documents requiring in-
depth evaluation were copied by the Task Force during the
inspection. Records were reviewed to evaluate facility
operations, identify locations and construction details of waste
management units and monitoring wells, and evaluate ground-water
monitoring activities.
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18
Specific documents and records reviewed and evaluated included
the facility ground-water sampling and analysis plan, an outline
of the ground-water quality assessment program, analytical
results from past ground-water sampling, monitoring well
construction data and logs, site geologic reports, site
operations plans, facility permits, waste management unit design
and operation reports, and operating records showing the general
types and quantities of wastes disposed of at the facility and
the i r loc at ions.
FACILITY INSPECTION
The ESL facility inspection, conducted in March 1987, involved
identifying waste management units (past and present); identify-
ing and assessing waste management operations and pollution
control practices; and verifying the locations, procedures, and
operation of the ground-water monitoring system.
Task Force personnel interviewed company representatives to
identify records and documents of interest, discuss the content
of the documents, and obtain information on (1) facility
operations (past and present); (2) site hydrogeology; (3)
ground-water monitoring system rationale; and (4) the ground-
water sampling and analysis plan.
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19
LABORATORY EVALUATION
The off-site contractor laboratories handling most of ESL's
ground-water samples were evaluated regarding their respective
responsibilities under the ESL ground-water sampling and
analysis plan. Analytical equipment, methods, quality assurance
procedures, and documentation were examined for adequacy.
Laboratory records were inspected for completeness, accuracy,
and compliance with state and federal requirements. The ability
of the laboratories to produce quality data for the required
analyses also was evaluated. A detailed discussion of this
evaluation is presented in the "Sample Analysis and Data Quality
Evaluation" section.
WATER LEVEL AND WELL DEPTH
Water level measurements were made by WMI's sampling contractor
in 44 of the 46 monitoring network wells (wells G-139 and G-140
reportedly were inoperable) on the first full day of the
inspection before the wells were purged for sampling. The
measurements were made at the request of Task Force personnel to
evaluate the facility's procedures. Depth to the water surface
was measured using an electric water level indicator (Slope
Indicator) . The water level indicator consisted of a reel with
a control panel, cable, and sensor. The cable, which was marked
in 1-foot increments, connected the control panel to the sensor.
When the water level sensor made contact with the water surface ,
-------
20
an indicator light and buzzer on the control panel were ac-
tivated. Duplicate measurements were made at several wells to
verify the reproducibility of the results. Additional water
level measurements were made on the wells sampled before purging
and, at a few wells, before sampling. Water Level measurements
for wells sampled during the inspection are presented in Table
1. Table 6 lists the water level measurements for all wells
measured at the time of the inspection.
Because a Well Wizard^R^a had been installed on some wells,
total depth measurements could not be made on those wells.
During the inspection, well-depth measurements were made by
WMI's contractor on eight wells, at the request of Task Force
personnel, for verifying construction records. Facility
personnel stated that, on an annual basis, WMI removes the Well
Wizards and measures the well depths. WMI provided the data
from the most recent measuring event (January 6, 1987).
GROUND-WATER SAMPLING AND ANALYSIS
During the inspection, Task Force personnel collected samples
*
for analysis from 26 .ground-water monitoring wells (see Table l
and Figure 3) to determine if the ground water contains
hazardous waste constituents or other indicators of possible
a Well Wizard is a registered trademark and will be shown
hereafter without the (R).
-------
G112
G113
G11S
G117
G150
G119
G118
G128
G14B
G149
PATE,
03/17/67
03/17/87
03/17/87
03/17/87
03/17/87
03/17/87
03/17/87
03/18/87
03/18/87
03/18/87
21
TABLE 1
TASK FORCE SAMPLE COLLECTION DESCRIPTION
(Page 1 of 3)
PURGE
Depth**
Jim; yo Water
0910- 23.0
1010
0932- 31.5
1032
1117- 34.2
1217
1320- 33.9
1339
1310- 33.7
1400
1432- 31.3
1452
1450- 34.1
1538
0905- 33.6
0955
0912- 27.8
1006
1042- 29.2
1120
purae Vpl •* Remarks***
30 Dedicated well wizard punp;
water did not change during
purging
26 Dedicated well wizard punp;
water clear
30 Dedicated well ulxard pump;
water Initially reddish yellow
but cleared after first 5 gallons
14 PVC bsller; water dark brown
and very cloudy
16.5 Dedicated well wizard pump
10 Dedicated well wizard pump;
water Initially surky, but
cleared
16.4 Dedicated well wizard punp
water clear
12.5 Dedicated well wizard punp;
water Initially cloudy and turbid,
then cleared
24 Dedicated well wizard pump,
water Initially cloudy and turbid,
then cleared
17 Dedicated well wizard pump
1020-
1040
1033-
1046
1217-
1233
1343-
1418
1400-
1418
1457-
1510
1540-
1602
1000-
1110
1008-
1022
1120-
1142
SAMPLING
Method
Dedicated
well wizard
pump
Dedicated
well wizard
Dedicated well
wizard punp
PVC bailer
Dedicated well
wizard
Dedicated well
wizard
Dedicated well
wizard
Dedicated well
. wizard pump
Dedicated well
wizard pump
Dedicated well
wizard pump
Remarks***
Company purged 54 gallons
before sampling well 1150-1225
Company started sampling after
9 gallons purged, ESL sampled
0954-1017
Company did not sample this
well
Company did not sample this
well; turbidity exceeded meter
upper bounds
Company did not sample this
well
Company did not sample this
well
Company did not samp Is this
well
Company took split samples; well
wizard malfunctioned 1024-1032
Company started sampling after
12.5 gallons purged, sampled
0940
Company alternated sampling
with Task force
-------
HOI £*!£
6129 03/18/87
C120 03/18/87
C130 03/18/87
C123 03/18/87
G131 03/18/87
GT12 03/18/87
GT14 03/18/87
GUI 03/19/87
22
TABLE 1
TASK FORCE SAMPLE COUECTIOM DESCRIPTION
(Pagt 2 of 3)
PUBCE
lias
IKS*
1210
1245-
1300
1330-
U04
1415-
1442
1522-
1555
1550-
155S
1615-
IMS
0912-
1107
1610-
1615
Depth"
Jo Wafer furae Vol .• Remark****
3S.5 12 Dedicated well uliard punp;
water Initially aurky, but
cleared
32.1 12 Dedicated well Miiard punp;
water Initially yellowish, then
cleared
36.7 1$ Dedicated well wiiard puap;
water Initially aurky, then
cleared tone
30.2 12.S Dedicated well wiiard puMp;
water Initially reddish and
turbid, then yellowish
37.4 14.J Dedicated well wlsard punp;
water very clear
19.4 4.8 laller. balled to dryness
21 PVC Uller, bailed to dryness,
water turbid and sandy
30.0 20 Dedicated welt wiiard punp;
water Initially surky, then
cleared
Ila*
1213-
125S
1310*
1323
1404-
1435
1445-
1509 .
1610-
1o32
0935-
0945
0905-
0920
1620-
1636
SAMPLING
Method
Dedicated well
wiiard punp
Dedicated well
wizard punp
Dedicated well
wiiard puap
Dedicated well
wiiard pi*p
Dedicated well
uliard punp
PVC boiler
PVC bailer
Teflon
bailer
»«iwrks*«»
Company took VOA samplea
after 11 gallons purged, then
took splits for rest of samples
Company did not sample this
well
Company took VOA simples
after 12.5 gallons purged, then
took splits for rest of samples
Company alternated sampling
with Talk Force
Company took split samples
Company did not take samples
Company did not teke samples
Company started sanpltng In the
morning and finished In the
afternoon
-------
0132
C134
C124
C13S
6125
C137
PATE
eWwUlt
03/19/87
03/19/87
03/19/87
03/19/87
03/19/87
03/19/87
03/20/87
23
TABLE 1
TASK FORCE SAMPLE COLLECTION DESCRIPTION
(Page 3 of 3)
PURGE
Depth**
Time 19 Wstef
0938- 33.8
1017
1100- 34.2
1136
1140- 30.2
1200
1240- 34.3
1314
1350- 30.S
1418
1356- 32.8
1450
0850- 27.9
0930
furae Vol.* Remarks***
16.5 Dedicated well wizard punp;
water Initially murky, then
cleared
13.8 Dedicated well wizard punp;
water milky with white
precipitate, Initial pH • 12
12.S Dedlceted well wizard punp;
water Initially yellowish, but
then cleared
16 Dedicated well wizard punp.
water Inltlelly murky, but then
cleared
IS Dedicated well wizard punp;
water Initially yellowish and
turbid, then cleared
16.8 Dedicated well wizard punp;
water murky then clearing
6.7
list
1017-
1026
1136-
1215
1205-
1222
1314-
1333
1418-
1438
U51-
1505
0955*
1015
A |
SAMPLING
.
Method
Dedicated well
wizard puap
Dedicated well
wizard puap
Dedicated well
wizard punp
Dedicated well
wizard punp
Dedicated well
wizard punp
Dedlceted well
wizard punp
Remarks***
Company took VOA samples
after IS gallona purged, only
took splits for nitrate and
sulphide
Company started sampling after
18 gel Ions purged, only took
splits for nitrate and sulphide
Company took split samples
Company took VOA samples
after 14.5 gallona purged, then
took splits for rest of samples
Company took split samples
Company started sampling after
12.5 gallona purged 1420-1450.
water had pungent odor, water
became milky during Task Force
sampling
Company also sampled this well
G144
* Indicates volune (In gallons) purged before Tesk Force personnel begen sampling. Volume of weter purged prior to company sampling (if different) is recorded
in the remarks column.
'• Depth is measured In feet from the top of the casing to the water surface.
**• The remarks are from Task Force field notebook observations.
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24
FIGURE 3
WELLS SAMPLED DURING TASK FORCE INSPECTION
-------
25
contamination. No surface water or leachate samples were taken.
The sampling results were used in evaluating previous company-
supplied data. The wells selected for sampling were those that
were more likely to show the impact on groundwater by the waste
management activities. These included wells that monitor the
uppermost aquifer and two wells that monitor the glacial till
adjacent to waste management units. The facility analyzed for
40 CFR Part 264 Appendix IX organic constituents for 14 of the
26 wells the Task Force sampled (see Table 1). Samples were
collected according to the following procedures.
WMI's contractor:
o Determined the depth to water using a Slope Indicator
water level meter.
o Calculated the height of the water column from depth-
to-water measurement and total well depth (from
construction records).
o Calculated the volume of water in the casing by
multiplying the height of the water column (in feet)
by a conversion factor (gallons per foot of casing)
to determine the amount of water to be purged from
the well before the facility's samples were taken.
The Task Force calculated the volume to be purged
before its samples were taken using the method
described in the following section on purging.
o Purged the number of well volumes in the well as
indicated in Table 1 before samples were taken.
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26
EPA's contractor:
o Monitored the wellhead for chemical vapors (Photovac
Tip(R)a) and radiation as soon as the inner protec-
tive cap was opened and at intervals during the
sampling.
o Collected sample aliquots for field measurements
(water temperature, pH, specific conductance and
turbidity) and filled sample containers in the order
shown in Table 2. Sample containers were filled
directly from the bailer or pump discharge line.
o Placed the samples in an insulated container contain-
ing ice (ice chest), and shipped the samples to the
laboratories daily under appropriate chain-of-
custody regulations.
Purging
Task Force personnel calculated the volume of water to be purged
from each well using the volume of the sandpack plus the volume
of the water in the casing above the sandpack. In some wells,
purge volumes were less than the customary three well volumes.
In the wells that WMI elected to sample, WMI sampled only after
three full casing volumes had been removed. This difference in
purge volume calculation accounted for the variations in
sampling start time shown Table 1. The wells screened in the
glacial till (GT-series) were purged to dryness the day prior to
sampling.
a Photovac Tip is a registered trademark and will be shown
hereafter without the *R).
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27
During the site reconnaissance, WMI personnel were informed by
the Task Force team, that it would be their responsibility to
properly dispose of the purge water. Purge water from any well
showing strong evidence of contamination was supposed to be
containerized and treated. At the time of the inspection, WMI
had made no provisions to handle the purge water and claimed
that the Task Force members were the generators of the
"wastewater." WMI made the decision that the ground water
showed no strong evidence of contamination and disposed of the
purge water on the ground as per the sampling plan followed at
the facility.
Sample Collectionr Handling and Preservation
During the Task Force inspection, samples were collected from 26
wells using several different methods including dedicated and
nondedicated bailers and dedicated submersible bladder-type
(Well Wizard) pumps (see Table 1). A nondedicated bailer made
of Teflon(R)a was used at Well G-141 after the dedicated Well
Wizard pump malfunctioned. In the wells screened in glacial
till (GT-series) and Well G-117, dedicated PVC bailers were used
for purging and sampling. For the rest of the G-series wells,
dedicated Well Wizard pumps were used for purging and sampling.
a Teflon is a registered trademark and will be shown hereafter
without the **•'.
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28
Representatives of the EPA sampling contractor monitored the
open wellhead for chemical vapors as soon as the inner protec-
tive cap was removed and prior to sampling. The EPA contractor
also took field measurement of pH, specific conductance, and
temperature of the ground water before, during, and after
purging. Field measurements were also performed on some of the
retrieved samples. These field measurements are presented in
Appendix A.
The ESL facility also collected samples from some of the wells
sampled by the Task Force. However, because of differences in
purge volume calculations and sampling procedures, the samples
were not usually considered to be splits of the samples
collected by the Task Force. The facility representatives
filtered all of their samples for inorganic analyses at the
wellhead. The Task Force took filtered and unfiltered samples.
The filtered samples were for metals analyses. In addition,
metals, TOC, phenols, cyanide, nitrate, and ammonia samples were
preserved (see Table 2). All filtering and preserving of
samples were done at a central location. Duplicate samples were
taken at two of the wells (G-117 and G-129). Trip blanks and
field blanks samples were also taken. The sample analyses
results are contained in Appendix A.
At the end of each day, the samples were packaged in coolers and
shipped to the EPA contract laboratories according to applicable
-------
29
TM3LE 2
QF SfifLE OCHU3CTICN
ki 11*1-1 je TXFE AND PRESERVATIVE USD
Parameter
Bottle
Preservative*
1. Volatile organic analysis CVCA)
2. Purgeable organic carbon (POC)
3. Purgeable organic halogens (POX)
4. Extractable organics
5. Pesticide/herbicide
6. Dioxiri
7. Total metals
8. Dissolved metals
9. Total organic carbon (TOG)
10. Total organic halogens (TGK)
11. Phenols
12. Cyanide
13. Anions
14. Sulfate/chloride/fluoride
15. Nitrate/anroonia
2 40-ml VO\ vials
1 40-ml VCA vial
1 40-ml VCA vial
4 or 6 1-L. amber
glass
2 1-L. amber glass
2 1-L. amber glass
1 1-L. plastic
1 1-L. plastic
1 50-ml glass
1 1-L. amber glass
1 1-L. plastic
1 1-L. plastic
1 1-L. plastic
1 1-L. plastic
1 1-L. Dlastic
HN03 to pH <2
HN03 to pH <2
H2SO4 to pH <2
H2SO4 to pH <2
NaOH to pH >10
H2SO1 to PH <2
*A11 samples were iced to 4°C after collection and during shipment to the laboratory
-------
30
Department of Transportation regulations (40 CFR Parts 171-177).
The aqueous samples from the monitoring wells were considered
"environmental" for shipping purposes. A signed chain-of-
custody form, designating the analytical requirements, accom-
panied each sample. This form also indicated the location,
date and time of sampling, sample size and preservatives,
whether the sample was filtered, and the numbers of the custody
seals.
Samples were analyzed by the EPA contractor laboratories for the
parameter groups shown in Table 2.
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31
FACILITY OPERATIONS AND WASTE MANAGEMENT UNITS
FACILITY OPERATIONS
WMI acquired the ESL facility in 1973. There is little informa-
tion available concerning the early landfilling practices at the
site. The facility operated five pre-RCRA waste management
units, four surface impoundments (Ponds 1 through 4) and a
landfarm, which were used for storage and disposal of industrial
and municipal sludges prior to 1980. RCRA hazardous wastes were
disposed of in 10 trenches, and industrial and municipal wastes
were placed in a co-disposal landfill. Other RCRA-regulated
waste management units include a container storage area, two
surface impoundments (Ponds 5 and 6) used for containment of
runoff from the container storage area, and a decant facility.
The ESL facility has not received wastes from off-site sources
since Spring 1984. Some materials generated from the decommis-
sioning and closure of on-site units have been disposed of in
the landfill since 1984. The facility was inactive at the time
of the Task Force inspection. Table 3 summarizes the types of
hazardous wastes that were accepted at the ESL facility.
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TABLE 3
HAZARDOUS WASTE STREAMS ACCEPTED BY ESL
(by EPA Hazardous Waste Number)
D001
D002
D003
D004
D005
D006
D007
D008
D009
D010
F001
F002
F003
F004
F005
F006
F007
F009
F012
F019
K016
K048
K049
K050
K051
K052
K061
K071
K080
K086
K094
U002
U008
U013
U028
U031
U043
U044
U057
U070
U072
U080
U112
U122
U131
U147
U154
U159
U171
U188
U190
U210
U220
U223
U226
U233
U238
U239
U252
POOS
P015
P106
P120
WMI submitted a RCRA Part B permit application to EPA on August
29, 1983, and has since received several notices of deficiency
(NOD) from EPA and IEPA regarding its application for ESL. WMI
has submitted revisions to EPA and IEPA of its RCRA Part B
permit application in response to the NODs.
WASTE MANAGEMENT UNITS
Waste handling units and operations at ESL were evaluated to
identify possible sources and pathways for waste constituents to
enter the ground water. The ESL facility has handled hazardous
waste as defined in 40 CFR *261 and 35 IAC 721 and regulated
under RCRA and IAC regulations.
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33
ESL has used the following RCRA-regulated units for the
treatment, storage, and/or disposal of hazardous waste:
o Co-disposal landfill
o Drum disposal trenches
o Container storage area
o Decant facility
o Surface impoundments (Ponds 5 and 6)
The facility also contains several pre-RCRA waste management
units consisting of:
o Four surface impoundments (Ponds 1 through 4)
o A landfarm
All units have been inactive since the Spring of 1984. Use of
the surface impoundments (Ponds 1 through 4) and the landfarm
was discontinued in 1979. WMI reported that the surface
impoundments (Ponds 1 through 4) were cleaned in 1980. .The
container storage area and decant facility were used in the
early 1980s but have since been decommissioned.
»
Figure 4 shows the locations of current and past treatment,
storage, and disposal facilities. A discussion of the waste
management units at the ESL facility follows.
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34
FIGURE 4
LOCATION OF CURRENT AND PAST WASTE MANAGEMENT UNITS
ENVIRONMENTAL SANITARY LANDFILL
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35
RCRA-Reaulated Waste Management Units
Co-Disposal Landfill
The co-disposal landfill has not been used for disposal of
hazardous waste from off-site sources since early 1984. It has
accepted some internally generated waste since then, such as the
material removed from the container storage area. This clay-
lined unit has been used for the disposal of municipal refuse
and industrial bulk waste. A preliminary EPA report indicates
that several existing trenches and ponds may be covered by the
co-disposal mound (U.S. EPA, 1985). The CERCLA 103 notification
identified organics, inorganics, solvents, pesticides, heavy
metals, bases, municipal waste, and paint and oil wastes as
being disposed of at ESL's co-disposal landfill. Table 4
provides a summary of the wastes received by the ESL facility
for disposal in the co-disposal landfill and the drum disposal
trenches during its last 3 operating years.
WMI claimed that co-disposal landfill was constructed as a clay-
lined disposal unit. Municipal refuse and bulk industrial
wastes were disposed of at the co-disposal landfill by spreading
them uniformly and compacting them an a daily basis.
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36
*
TABLE 4
QUANTITY OF WASTES RECEIVED
AT ESL CO-DISPOSAL LANDFILL AND DRUM DISPOSAL TRENCHES
(By Relative Percent Of Total Volume Of Waste Managed)
1991
198?
D001
DO 02
15004 through DO 11
F001 through F005
F006
F0072
F0172
K061
E094 •
62
IS
2S
85S1
2S
OS
IS
OS
IS
42
12
76S1
6S
6S
IS
OS
4S
IS
4S
IS
40S1
6S
43S
OS
OS
2S
IS
Approximate Volume
Of Waste Received
(Total/Tons/Year)
92,000
60,000
17,000
NOTE: While other F, K, D, and P wastes were accepted into
Areas 1 and 2, the volumes of these individual waste
types are less than 1/2S of the total volume of waste
accepted in a given year. For brevity and because these
wastes account for a very small volume, they have been
omitted from this Table. The percentages in the Table
may not equal 100S because of this omission and due to
rounding.
1 A substantial portion of this percentage is from a one-time
clean-up where soil was contaminated with this waste code.
2 This waste code has subsequently been dropped from the RCRA
list.
Source: Waste Management of Illinois, Inc., 1988. Closure Plan for ESL, received
by U.S. Region V, February 26, 1988.
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The liner for the co-disposal landfill was constructed of native
clay. WMI claimed that the naturally occurring clay of the
area has a hydraulic conductivity ranging from 1 to 8 x 10~8
cm/sec. WMI states that a base of at least 10 feet thick was
maintained in the landfill area. WMI has also indicated that
this unit has a cover consisting of a compacted fine-textured
soil layer that is at least 2.5 feet thick. This soil was also
claimed by WMI to have a in situ hydraulic conductivity of 10~7
cm/sec or less. The clay layer was then overlain by 6 inches of
topsoil and seeded with shallow-rooted grasses for erosion
control.
A gas venting system was installed in 1986 consisting of three
vents located at the northwest corner, southwest corner, and on
the south side. There is a leachate collection system that is
contiguous with the gas venting system.
Drum Disposal Trenches
This disposal area consists of 10 recompacted clay-lined
trenches. The trenches are approximately 15 feet deep. The
trenches were used for the disposal of RCRA-regulated hazardous
wastes (all RCRA wastes with few exceptions; see Tables 3 and
4), that were either "solidified" or in drums. The trenches
were filled with hazardous waste to approximately grade
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38
elevations. Subsequently, three trenches on the west side of
the main haul road were covered by the co-disposal landfill
operation.
WMI has stated that the liners for the trenches were constructed
with a native clay layer with a minimum thickness of ten feet.
The trenches have a leachate collection system that consists of
PVC pipes beneath each trench, installed in a gravel base. WMI
has stated that these trenches were covered by at least 2.5 feet
of recompacted clay, which were then overlain with topsoil and
seeded with shallow rooted grasses.
Container Storage Area
From late 1981 until late 1984, ESL stored containers of
hazardous wastes in an open air, clay-lined area. The unit
measures approximately 330 feet by 200 feet with a very gradual
slope to the northeast corner. The storage area is surrounded
by a 2- to 5-foot-high clay berm. WMI stated that containers
were stored on pallets to elevate them above the soil.
In 1981, U.S. EPA approved an increase in interim status
capacity that allowed ESL to store up to 110,000 gallons of
hazardous wastes in containers. Although the current interim
status container storage capacity is 275,000 gallons, no
containers are currently stored at ESL.
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39
ESL has indicated that most (about 60 percent) of the con-
tainerized wastes managed at this unit were considered hazardous
due to the characteristic of ignitability (DOOl). About 20
percent of the wastes handled at this unit were characterized as
hazardous due to EP toxic metals (D004 through D011), especially
chromium and lead. Wastes considered hazardous due to cor-
rosivity (D002) comprise about 3 percent of the wastes handled
at the unit. Wastes from nonspecific sources, especially F001
through F005, comprised about 16 percent of the wastes managed,
and wastes from ink formulation (K086) comprised 1 percent of
the containerized wastes. Several additional listed hazardous
wastes comprised less than 1 percent of the total volume of
wastes received at the container storage facility. "WMI stated
that no reactive wastes (D003) were recorded as being accepted
at this unit.
In late 1984 and early 1985, soil was excavated from the
container storage area. This material was disposed of in the
RCRA landfill. Soil samples were taken in accordance with the
interim status closure plan.
Decant Facility
ESL operated a pilot decant facility from late 1981 until 1983,
while a permanent decant facility was being constructed. The
permanent decant facility ceased operations in 1984. WMI stated
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40
that both the pilot decant facility and the permanent decant
facility were designed to provide physical treatment of
containerized wastes by a combination of the following steps:
o Removal of liquids from drums
o Liquid phase separation, for subsequent treatment,
recovery, or disposal of the liquid phases
o Stabilization of sludge and selected liquids
The final products of both decant facilities were liquids, which
were sent off-site for recovery, or stabilized wastes, which
were disposed of in the co-disposal landfill on-site. WMI
indicated the stabilization process used kiln dust or a similar
fixing reagent.
The pilot decant facility was located in the container storage
area. The base of this area was compacted clay. The pilot
decant facility consisted of storage tanks, treatment tanks, and
auxiliary equipment (mixer, conveyors, pumps, and piping). in
1983, the pilot plant was disassembled. WMI stated that the
tanks and other equipment were either used in the permanent
decant facility, disposed of in the RCRA landfill at ESL", sent
to another WMI hazardous waste facility to be used, or stored at
ESL for future disposition or use. WMI stated that in late 1984
or early 1985, soil was excavated from the container storage
area, including the area underlying the pilot decant facility,
and that soil samples were taken in accordance with the interim
status closure plan.
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41
In 1983, the permanent decant facility was constructed and began
operating. This facility was located in a 50 foot by 50 foot
metal building with a concrete floor. A concrete diked area,
located outside the building along the south wall, housed two
large storage tanks. All other storage and treatment tanks were
inside the building. Containers were transported from the
storage area and placed on a conveyor system that moved through
the decant facility. The decanted liquid was either solidified
and disposed of on-site or shipped off-site for supplemental
fuel, recovery, or incineration. This facility operated for
approximately 1 year.
The pilot and permanent decant facilities received the same
wastes that were listed as being handled at the container
storage area. The wastes received have been summarized as
approximately 60 percent ignitable wastes (DOOl), 20 percent EP
toxic metals waste (D004 through D011), 3 percent corrosive
wastes, 16 percent wastes from nonspecific sources (especially
F001 through F005), and 1 percent other listed hazardous wastes.
In July 1985, most of the tanks and other equipment in the
permanent decant facility were dismantled. WMI stated that most
of the equipment was decontaminated and shipped to another WMI
facility to be used for hazardous waste storage and treatment.
Some piping and equipment were disposed of in the interim status
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42
landfill at ESL. WMI stated that the floor of the building was
sandblasted, and the spent sand was also disposed of in the
landfill. One 6,000-gallon tank remains in the concrete diked
area south of the decant building.
Surface Impoundments
The RCRA-regulated surface impoundments are Ponds 5 and 6.
These ponds were constructed in the late 1970s using native
clay. WMI stated that the sides and bottoms of the ponds are
surrounded by 20 feet of clay with a hydraulic conductivity less
than 1 x 10~7 cm/sec. Pond 5 has dimensions of 170 feet by 300
feet by 13 feet deep. The internal sides have a slope of 3 to l
(horizontal to vertical) with a minimum freeboard of 2 feet.
Pond 5 has a capacity of approximately 3.3 million gallons.
Pond 6 has dimensions of 190 feet by 310 feet by 13 feet deep.
Similar 3:1 internal side slopes and 2-foot freeboard were used
in the construction of pond 6, which has an approximate capacity
of 4 million gallons.
Ponds 5 and 6 were used to collect rainfall and stormwater
runoff prior to November 19, 1980. In 1982, the ponds were
used to hold runoff from the container handling areas. ESL has
an NPDES permit which allows it to discharge this stormwater to
the Des Plaines River. Ponds 5 and 6 served as storage units
so that the water could be sampled before it is discharged.
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43
In 1985, the ponds were drained and water, and soil samples were
taken. Although the facility did. not have an approved interim
status closure plan and closure of these units were not
certified, WMI stated that an independent professional engineer
certified the procedures. Very little water remains in these
ponds.
Trench 11
Trench 11 was constructed with a compound synthetic liner that
was underlain by an impermeable clay base. The trench was to
have been used for the disposal of hazardous waste, but it has
never been used. The permit for this unit was denied in April
1984.
Pre-RCRA Waste Management Units
Surface Impoundments
The pre-RCRA surface impoundments are Ponds 1 through 4. These
four clay-lined impoundments were used to store industrial and
municipal sludges prior to land* treatment. These impoundments
were used from 1975 until 1979. WMI stated that the wastes
disposed of in the impoundments were nonhazardous, but the
company has not provided any information to document this fact.
The ponds were excavated in 1980.
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44
Two other impoundments are located along the southern border of
the disposal facility. These impoundments were intended for
disposal of solid waste, but they never received any waste
material. They now hold rainwater and runoff from the co-
disposal landfill.
Landfarm
The landfarm is located east of the "future disposal area" and
has also been identified as the "proposed expansion area." Use
of the landfarm was discontinued in 1979. The pre-RCRA
activities involved the landfarming (spraying) of municipal and
industrial sludges, FCC (fluid-cracking catalyst) fines, • API
oily sludges, water and residue from the ponds, and organic
liquids (U.S. EPA, 1985). The facility never notified EPA of
this unit in any CERCLA 103 or solid waste management units
response.
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45
SITE HYDROGEOLOGY
Several investigations have been conducted by WMI's consultants
to define the hydrogeologic setting of the ESL facility. This
section incorporates information obtained from two geologic,
geotechnical, and hydrogeologic evaluations prepared by
Woodward-Clyde Consultants in July 1982 and July 1983, and
boring logs from various boring operations at ESL by Testing
Services Corporation and Woodward-Clyde Consultants. Informa-
tion from the Illinois State Geologic Survey, circulars 460 and
505, was also consulted to provide this discussion of the
geologic and hydrogeologic setting of the ESL facility.
The ESL site is located in Will County, Illinois, on the south
side of the Des Plaines River, south of Joliet. The surface
elevation of the site is, on average, 100 feet above the normal
pool elevation (506 feet) of the Des Plaines River. No
development on the site lies within the flood plain of the
river or any of its tributaries.
The facility is situated in the central portion of the Central
»
Lowland physiographic province. The Central Lowland province is
divided into two sections, the Great Lakes section and the Till
Plains section, based on the surficial features which resulted
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46
from the action of glacial ice and meltwater. The boundary
between the two sections passes to the northwest of the site.
The ESL site is situated in the Till Plain section, which is
characterized by subdued topography, consisting of few lakes and
older Wisconsinian till plains that have been modified by
erosion.
The Sandwich Fault Zone is located approximately 3 miles
southwest of the ESL site. The fault zone consists of a narrow
belt of high angle faults, generally 1/2 to 2 miles wide. Along
most of the zone, the faults are upthrown on the southern side
of the fault. At the southeastern end of the fault zone, in the
vicinity of the ESL facility, the fault 'is downthrown to the
south. At the southeastern end of the fault zone, the total
vertical displacement across the zone is approximately 150 feet.
The faulting affects all of the bedrock units below the
Pleistocene deposits. The faulting is believed to be contem-
poraneous with other Late Paleozoic . deformational events
affecting the eastern craton on North America. "Earthquake
epicenters within the area in historic time show no relationship
to the Sandwich Fault Zone" (Kolata, et al, 1978).
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47
STRATIGRAPHY
The sequence of sedimentary rock units and unconsolidated
sediments present in the region of the ESL site is summarized in
Figure 5. The generalized stratigraphic column shown in Figure
5 indicates the units present in the greater Chicago area in
northeastern Illinois. The stippling indicates units that are
not present at the ESL site. The stratigraphic sequence at the
site consists of approximately 50 feet of unconsolidated
Pleistocene sediments underlain by more than 1,500 feet of
Silurian, Ordovician, and Cambrian sedimentary bedrock, which
lies unconformably atop the Precambrian crystalline basement
rocks. Figure 6 shows a generalized geologic cross-section
through the sedimentary sequence underlying the ESL site that is
relatively flat lying and shows no structural deformation.
The Pleistocene deposits consist of an upper till unit, which
WMl's consultants identified as being the Yorkviile Member of
the Wedron Formation. The unit's thickness varies across the
site but, on average, is at least 20 feet thick and in places
is approximately 50 feet thick. This layer overlies a glacial
outwash unit, which also varies in thickness across the site.
The glacial outwash is absent in the extreme northeast corner of
the site and reaches a maximum thickness of 20 feet in the
extreme southeast corner of the site. Under most of the
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48
FIGURES
GENERALIZED STRATIGRAPHIC COLUMN OF THE
GEOLOGY OF THE CHICAGO REGION
Source: Willman, 1971, Illinois State Geological Survey Circular No. 460.
Note: The stippling indicates units not present at the ESL site.
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49
FIGURE 6
GENERALIZED GEOLOGIC CROSS-SECTION OF THE ESL SITE
l i ii! HI
Source: Woodward-Clyde Consultants, 1982. Geologic Gcotcchnical and
Hydrogcologic Evaluation of Exposure Area to Chemical Waste
Management, Inc., Joliet, Will County, Illinois, July 1982.
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50
hazardous waste management area, the average thickness of the
glacial outwash is 5 feet. In the southeastern corner of the
site, a second till unit is present below the glacial outwash
and above the Silurian bedrock.
HYDRQGEOLOGIC UNITS
In the vicinity of the ESL facility, the WMI consultants
identified several major units, which are potential aquifers.
These units are the Pleistocene age sand and gravel outwash
deposits and the fractured surface of the Joliet Formation,
immediately beneath the outwash deposits; two transmissive zones
within the Silurian age dolomite sequence; and the stratigraphi-
cally lower bedrock aquifer, which consists of the Ordovician
and Cambrian age carbonate and sandstone units. Most of the
water supply wells in the vicinity of the ESL facility draw
water from the Silurian dolomite formations. WMI's consultants
noted that, although the Pleistocene outwash deposits are
capable of providing water, no production wells from this
aquifer were identified within a 2-mile radius of the site. The
City of Joliet, located less than 3 miles northeast of the site,
reportedly draws more than 2.2 million .gallons per day from
wells that are completed in the glacial outwash aquifer. The
glacial outwash at that location, however, occupies a preglacial
bedrock valley that, according to WMI consultants, is not
hydraulically connected to the outwash beneath the ESL site.
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51
For the purpose of ground-water monitoring, the uppermost
aquifer beneath the ESL site has been identified as a composite
zone consisting of the glacial outwash aquifer and the upper 10
to 20 feet of the underlying Silurian dolomite.
Monitored Composite Aquifer
The glacial outwash aquifer consists of a sand and gravel
outwash deposit at or near the base of the Pleistocene units and
on top of the Silurian dolomite bedrock. It is overlain by a
continuous till layer that acts as a confining layer. In the
southeast corner of the site, the dolomite slopes away, and a
second till layer is present between the outwash and the
dolomite. No active water supply wells within a 1-mile radius
of the site are developed in the glacial outwash aquifer (WCC,
1982). WMI consultants found evidence of an abandoned hand dug
well, which was developed in the glacial outwash aquifer. The
water level obtained from the monitoring well screened only in
the glacial outwash correlates with water levels of wells in the
Silurian dolomite. Well pairs, one screened in the dolomite and
the other in the glacial outwash, have equal water levels. This
indicates that the glacial outwash aquifer and the water
contained in the uppermost portion of the Silurian age Joliet
Formation are in relatively complete hydrologic contact.
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52
The water contained in the upper 10 to 20 feet of the Joliet
Formation is located along bedding planes, solution cavities,
fissures, and crevices. This zone of the unit is the most
weathered and relatively more permeable.
Silurian Transmissive Zones
The Silurian dolomite is the uppermost bedrock unit beneath the
Pleistocene glacial deposits. Of the 81 water supply wells
reported in the Illinois State Water Survey records for this
area (within a 2 mile radius and south of the Des P-laines
River), 68 wells draw their water from various zones in the
Silurian dolomite. The ground water in the dolomite occurs in
fissures, joints, bedding planes, solution cavities, and
crevices. The water-yielding zones are irregularly distributed
both vertically and horizontally.
WMI consultants tentatively identified two other transmissive
zones, besides the upper 10 to 20 feet of the Joliet Formation,
within the Silurian dolomite. The first is located within the
Joliet and Kankakee Formations, in the units that form the
contact between the formations. The second transmissive zone
was identified as being in the Edgewood Formation, which is at
the base of the Silurian sequence and just above the Maquoketa
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53
Shale. WMI's consultants estimated that these transmissive
zones lie approximately 100 and 200 feet below the ESL site,
respectively.
Cambro—Ordovician Aquifer System
The Cambro-Ordovician aquifer system consists of a sequence of
hydrologically interconnected units that are separated from the
overlying Silurian aquifer by the low permeability Maquoketa
Shale. The Cambro-Ordovician series consists of sandstone and
dolomite units interbedded with siltstones and shales; the
series is over 1,300 feet thick in the region. The water
bearing units which form the Cambro-Ordovician aquifer are the
Galena and Plattevilie dolomite, Glenwood and St. Peter
sandstones, Prairie Chien Group sandstones and dolomites,
Eminence and Potosi dolomite, Franconia Formation, and Ironton
and Galesville Formation sandstones. The principal water-
yielding units are the Ironton, Galesville, and St. Peter
Formation sandstones (see Figure 5), which provide 80 percent of
the total aquifer capacity.
GROUND-WATER FLOW DIRECTION AND RATES
The uppermost aquifer beneath the ESL site is a composite
aquifer consisting of the hydraulically connected glacial
outwash aquifer and the upper 10 to 20 feet of the underlying
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54
Silurian dolomite. Figure 7 shows a contour map of the ground-
water surface. This map shows that the ground-water surface of
the uppermost aquifer slopes gradually to the northwest, towards
the Des Plaines River. WMI's consultants identified a southwest
to westerly flow component in the southwest portion of the site.
They also identified a bedrock valley south of the site which
influences this portion of the site. WMl's consultants noted an
easterly flow component in the southeastern portion of the site
that may be a seasonal effect. WMI's consultants noted that the
gradient is relatively flat beneath the site, and pumping of
wells from the unit could locally change the direction of the
gradient and the direction of ground-water flow. As a result of
its inspection, the Task Force noted a northerly flow component
in the ground water at the northern portion of the site.
Hydraulic conductivity measurements were made, by WMI's
consultants, on 41 wells (G-series wells) installed in the
uppermost aquifer using both variable head tests and constant
head tests. The hydraulic conductivities measured ranged from a
low of 2.6 x 10~6 cm/sec (G-139) to a high of 2.8 x 10~2 cm/sec
(G-136); most of the values fell in the range of 10~3 to 10~4
cm/sec. Transmissivity values were then calculated for these 40
wells ranged from a low of 7.19 x 10~8 m2/sec (G-139) to more
than 2.16 x 10~3 m2/sec (G-136); values ranged from 2.88 x 10"
5 to more than 1.44 x 10~4 m2/sec. Table 5 shows the hydraulic
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55
conductivity and transmissivity values for all the G-series
monitoring wells.
Available information on the stratigraphy, potent iometric
surface wells screened in the Silurian dolomite, and the packer
(borehole pump) test conducted within the Silurian dolomite
indicate a lack of significant hydrologic interconnection
between the uppermost aquifer and the lower two transmissive
zones within the Silurian dolomite. Figure 7 shows the com-
parison of the water level contour for wells screen in the
uppermost aquifer versus a composite of wells in the deeper
Silurian dolomite transmissive zones. The comparison between
the water level contour sets indicates that the composite of
wells in the deeper Silurian dolomite transmissive zones are
tapping a different water supply than the uppermost aquifer.
The first transmissive zone is approximately 30 feet thick
within the Joliet and Kankakee dolomites. This transmissive
zone is separated from the weathered zone by very dense,
unfractured, low permeability dolomite. The lower transmissive
zone is near the base of the Edgewood Formation and is ap-
proximately 20 to 30 feet thick. The middle and lower transmis-
sive zones are separated by dense, shaly, low permeability
dolomite. The packer (borehole pump) tests confirmed the
existence of the low hydraulically conductive zone of bedrock
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56
FIGURE 7
COMPARISON OF WATER LEVELS IN UPPERMOST AQUIFER
AND COMPOSITE DEEPER SILURIAN DOLOMITE
TRANSMISSIVE ZONES
•%S«»...~-
$.66
WMK tow! contourt in ooiw«in and too of OeotocK wntmt»«w« ion*
Siiunan coiomn* «n«num»w« iofv«»
trom T«t>«« ES-1
w«ll. w«u« 0. f V* G. Jun« 1983 w«» ****
Source: Waste Management of Illinois, 1983. RCRA Part B Permit Application.
Volume II - Groundwatcr Monitoring, September 1983 with revisions, July
1985.
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57
beneath the weathered and fractured dolomite, which separates the
uppermost aquifer from the transmissive zone deeper in the Silurian
dolomite.
The rate of ground-water flow in the uppermost aquifer beneath the
site can be calculated from known or estimated aquifer characteris-
tics. The gradient measured beneath the site ranged from 0.004 to
0.007. The hydraulic conductivity of the uppermost aquifer was
estimated in the range of 10~3 to 10~4 cm/sec (see Table 5). The
effective porosity was estimated to be between 20 to 25 percent.
Using these parameters, WMI consultants estimated the ground-water
flow velocity to be in the range of 2 to 35 feet per year.
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58
TABLE 5
PUMPING TEST RESULTS FROM AQUIFER WELLS
(Page 1 of 2)
Well No.1
G-lll
G-112
G-113
G-114
G-115
G-116
G-117
G-118
G-119
G-120
G-121
G-122
G-123
G-124
G-125
G-126
G-127
G-128
G-129
G-130
G-131
G-132
G-133
G-134
G-135
G-136
G-137
G-138
G-139
G-140
G-141
G-142
G-143
G-144
G-145
G-146
Type of*
Teat
VJL
VJL
VJL
VJL
CJL
CJL
VJL
VJL
CJL
VJL
V.H.
CH.
CH.
CH.
CH.
CH.
CH.
VJL
CH.
CH.
CH.
CH.
CH.
VJL
CH.
CH.
CH.
CH.
V.H.
C.H.
CH.
CH.
V.H.
V.H.
CH.
CH.
Hydraulic3
Conductivity
Kh fem/aee>
2.6 x 10-*
9.0 x 10"*
92 x 10-4
7.6 x 10-*
52 x 10-4
7.8 x 10-4
6.6 x 10-4
1.1 x 10-3
1 .5 x 10-3
2.1 x 10-3
3.7 x 10-4
9.7 x 10-3
22 x lO'3
1 J x lO"3
1.7 x 10-3
5.83 x I0-s
2J x 10-3
9.3 x 10-4
4.8 x 10-*
4.8 x lO'3
1.1 x 10-3
2.0 x lO'3
8.2 x lO'3
1.7 x lO'3
8.0 x 10-4
2.8 x 10'J
1.45 x lO'3
6.1 x lO*3
Length of
Screened Interval
Z6 x
2.4 x ID'3
1.83 x lO'3
2.30 x 10-<
3.6 x 10'«
8.3 x lO'5
1.80 x lO'4
2.6 x lO*4
5
5
20
15
25
25
5
15
15
15
15
10
20
15
20
20
20
20
20
20
20
20
20
5
20
25
25
25
10
25
20
20
15
5
30
20
Calculated4
Transmissivity
T fend/ft^
27.2
9.5
389.7
242.6
273.6
415.2
70.5
351.3
483.0
894.0
118.5
2059.4
954.8
409.4
739.7
1474.6
975.6
394.3
2055.2
2053.9
456.3
866.1
3464.4
178.9
338.4
15,012.5
770.7
3251.6
0.5
1252.0
770.0
97.6
1.16
8.8
114.6
111.0
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59
TABLE 5
PUMPING TEST RESULTS FROM AQUIFER WELLS
(Page 2 of 2)
Hydraulic3 Length of Calculated4
Type of* Conductivity Screened Interval Transmissivity
Well No.1 Test Kh /em/seel Uft) T
G-147 CH. 5.8 x IV4 20 245.4
G-148 CH. 2.0 x 10-* 15 626.7
G-149 V.H. 7.7 x 10-* 5 8.16
G-150 V.H. 9.6 x 10-* 5 10.13
G-151 CH. 7.5 x 10-* 15 2378.3
Notes:
(1) See Figure 2 for monitoring well locations. These wells were designed and installed to
obtain ground-water level measurements and ground-water samples for water quality
testing, not for the determination of the permeability and transmissivity of the screened
interval of the well. As such, the calculated result may not be indicative of actual in-
situ values of transmissivity and permeability. These quantities should be determined
using test methods specifically designed for the purpose of measuring either permeability
and/or transmissivity. The accuracy of these results is judged to be within an order of
magnitude of actual conditions, based on the limitations stated above.
(2) V.H. • Variable head test. After achieving drawdown, the recovery or rise in water level
was monitored over time.
CH. - Constant head test. During pumping, a constant drawdown condition was achieved.
(3) T - Kh x L with units of gallons per day per foot of horizontal width of the geologic
strata penetrated. Kh was calculated based on the C.H. and V.H. equations presented in
Soil Mechanics (1968), by Lambe & Whitman, Pages 284 and 285, Case F.
Where:
Kh - calculated horizontal hydraulic conductivity (cm/sec)
Kh - Ke was assumed for this calculation.
(4) These transmissivity values were calculated from the screen lengths, not the aquifer
thickness, and therefore are low estimates.
Source: Waste Management of Illinois, Inc., 1983. RCRA Part B Permit Application. Volume
II- Groundwater Monitoring, September 1983 with revisions, July 1985.
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60
GROUND-WATER MONITORING DURING INTERIM STATUS
REGULATORY REQUIREMENT?
IEPA administers the RCRA interim status ground-water monitoring
regulations in the State of Illinois. ESL's RCRA ground-water
monitoring system from December 1981 until February 1984
consisted of wells P-l through P-8. In March 1984, ESL received
a supplemental operating permit from IEPA to modify its ground-
water monitoring program. In April 1984, an expanded ground-
water monitoring system was installed. This system consists of
41 G-series wells (G-lll through G-151) that monitor the
uppermost aquifer. Five other wells were also installed at this
time to monitor the glacial till above the uppermost aquifer.
ESL is an interim status facility and has maintained an interim
status ground-water monitoring program since November 1980.
IEPA was notified of significant changes in indicator parameters
for the P-series wells in June 1983. Well P-l showed a
significant decrease in pH, while wells P-l through P-6 all
showed significant increases in specific conductance. On
October 11, 1985, the facility received a compliance inquiry
letter (CIL) from IEPA for failing to implement a ground-water
quality assessment plan citing 35 IAC 725.193(d)(4) (40 CFR
265.93(d)(4)). On March 5, 1986, the facility resolved the
violation cited in the CIL. On November 27, 1985, ESL submitted
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61
statistics showing that seven of the new G-series wells failed
the average replicate test, as shown in the results of the
August 1985 sampling. These wells are G-117 for specific
conductance; wells G-128, G-129, G-131, G-137, and G-140 for pH;
and well G-139 for specific conductance, total organic carbon,
and total organic halogens.
On June 12, 1986, U.S. EPA issued an administrative complaint to
ESL for failing to supply information required to complete the
RCRA Part B application. On December 1, 1986, IEPA sent the
facility another CIL for failing to retest wells that indicated
a statistical change, in violation of 35 IAC 725.193(c)(2) (40
CFR 265.93(c) (2)) , and for failing to determine the rate and
extent of migration of hazardous waste or hazardous waste
constituents, in violation of 35 IAC 725.193(d)(4) (40 CFR
265.93(d) (4)). At the time of the Task Force inspection, WMI
contended that it had completed its assessment program and has
returned to the detection monitoring phase.
GROUND-WATER SAMPLING AND ANALYSIS PLAN
The ESL facility uses two sampling and analysis plans. One is a
site-specific plan titled "Specific Ground-Water Monitoring Plan
for ESL" dated November 1985. The memo indicates that this plan
addresses the analytical methods, parameters, and schedule of
sampling and preservation. " The second plan is titled "WMI
Manual for Ground-Water Sampling" (revised September 1986).
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62
This is a generalized document that addresses sampling procedur-
es. A number of deficiencies were noted in these plans:
o Neither plan identified the procedures that would be
used to check wells for immiscible layers such as low
density (floaters) or high density (sinkers) con-
taminants .
o Neither plan contains documentation of decontamina-
tion procedures used to clean the cable for the
water level indicator equipment.
o Neither plan contains the documentation as to the
quality of water used to prepare blanks. This
information was requested and later supplied by the
facility. It should be included in the site-specific
plan.
o Neither plan includes procedures for using the in-
line filtering equipment of the Well Wizard pumps.
Also needed is the procedure used to clean the
filtering equipment between wells.
o The general plan "WMI Manual for Ground-Water Sam-
pling" requires total organic carbon (TOO to be
filtered. This is an incorrect procedure that will
bias results low.
o The site-specific plan stated that wells installed
before 1984 used schedule 40 PVC pipe. The boring
logs for Well G-139, which was installed in 1983,
shows that schedule 80 pipe was installed.
The facility removed sampling equipment from 21 wells in January
1987, and measured total depth of these wells. The remaining
wells have not had their total depths checked since May 1985.
SAMPLE ANALYSIS AND DATA QUALITY EVALUATION
WMI uses contract laboratories to provide analyses of ground-
water samples taken at the ESL facility. The laboratories used
by ESL are Environmental Testing and Certification (ETC) of
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63
Edison, New Jersey; Gulf Coast Laboratories of University Park,
Illinois; and Core Laboratories of Casper, Wyoming. An EPA
Region V team visited ETC and Gulf Coast Laboratories to
evaluate the laboratories ' operating and analytical procedures
and documentation system. Data for Core Laboratories were
provided by EPA Region VIII.
Inoranic
ESL contracts with Gulf Coast Laboratories to perform analyses
for metals, total organic carbon, total organic halogens, arid
indicator parameters. The laboratory analyzed most metals (Ba,
Cd, Cr, Fe, Na, Ag, Mn, etc.) by inductively coupled plasma-
atomic emission spectroscopy. Graphite furnace atomic absorp-
tion is used to analyze for arsenic, lead, and selenium, and
cold vapor atomic absorption is used to analyze for mercury.
The Task Force laboratory evaluation team had the following
comments, observations, recommendations and noted some deficien-
cies regarding Gulf Coast Laboratories.
o Comment: The.laboratory should be commended for the
excellent documentation of graphite furnace atomic
absorption problems and corrective action report
forms. The analytical corrective action report
addressed the following problems:
1. Duplicate analysis not within control
limits.
2. Low spike recovery.
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64
3. Correlation coefficient does not meet
the acceptance criteria.
4. Severe matrix interference present.
5. Laboratory control sample/blank does not
fall within control limits.
o Comment: An interference check sample is analyzed to
verify inter element and background correction
factors at the beginning and end of the sample run.
Also the acceptance criteria is consistent with EPA
Method 200.7.
o Observation: A high standard and internal quality
control samples are analyzed at a frequency of 10
percent to determine instrument drift. The accep-
tance criteria of + 5 percent of the expected
values or within the established control limits,
whichever is lower, is not observed as mandatory by
EPA Method 200.7 (ICP procedure).
Recommendation: The acceptance criteria of ± 5
percent of the expected values or within the
established control limits, whichever is lower,
should be observed.
o Observation: An external quality control sample is
used for the initial verification of the calibration
standards. The acceptance criteria of ± 5 percent of
the true value listed for the control sample is not
observed as mandatory by EPA Method 2020.7.
Recommendation: The acceptance criteria of + 5
percent of the true value should be observed.
o Observation: The laboratory put a lot of emphasis on
the objective to provide a measure of the accuracy
and precision of analytical methods, but failed to
emphasize continuing assessment of the accuracy and
precision of data generated over time.
Recommendation: The laboratory should maintain a
continuing assessment of the accuracy and precision
of data generated over time.
o Deficiency: The laboratory does not field screen the
ground-water/surface water samples for the presence
of sulfide before analyzing for cyanide.
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65
Recommendation: Since the sample holding time for
cyanide test procedure is only 24 hours when sulfide
is present, the laboratory should screen all cyanide
samples in field with lead acetate paper for sulfide
and analyze the samples that are positive within 24
hours. Please refer to 40 CFR Part 136, dated
October 26, 1984, for further instructions.
o Deficiency: The laboratory does not have a well
documented test procedure for the analysis of cyanide
in water samples.
Recommendation: The laboratory should, as soon as
possible, document the cyanide test procedure. The
test procedure should describe exactly how the
laboratory is performing the cyanide analysis.
o Observation: The laboratory data on total organic
carbon (TOO are hard to evaluate since the instru-
ment outputs (data) are not legible. This is not a
good recordkeeping practice.
Recommendation: The laboratory should look into the
possibilities of acquiring a printer that would print
the sample data legibly so that the TOC data can be
evaluated, if necessary.
ESL contracts with ETC to perform analyses for organic con-
taminants. The Task Force laboratory evaluation team visited
ETC in July 1987 to determine the laboratory's capabilities to
analyze the following organic contaminants: benzene, methylene
chloride, tetrachloroethylene, trichloroethylene, toluene,
1,1,1-trichloroethane, methyl ethyl ketone, xylenes, ethyl
benzene, 1,1-dichloroethane, 1,2-dichloroethane, trichloroflu-
oromethane, and ethyl acetate. The Task Force evaluation of ETC
determined that the overall performance of the laboratory was
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66
acceptable. However, the following deficiencies were noted
during the evaluation:
o Deficiency: The laboratory did not extract pest-
icides and PCBs samples at the pH range specified in
the EPA manual, SW-846, Second Edition (1984). The
audit team was told that the laboratory staff did not
determine the pH of the water samples since the
Sample Field Parameter forms (CC2) have the pH data
on them.
Recommendation: If the laboratory cannot extract
(i.e., sample extraction by liquid-liquid or
continuous extraction technique and concentration of
the extract to 5.0 ml) pesticides and PCBs sample
within 48 hours of collection, the sample should be
adjusted to a pH range of 6.0 to 8.0 with sodium
hydroxide or sulfuric acid, if <=< -BHC, tf -BHC,
endosulfan I and II, and endrin are of interest. All
samples must be extracted within 7 days and complete-
ly analyzed within 30 days of sample collection.
• o Deficiency: The laboratory did not extract the semi-
volatile (acid, base, and neutrals) samples within
14 days of sample collection.
Recommendation: The semivolatile sample extraction
step must be completed (i.e., sample extraction and
concentration of the extract) within 14 days of
sample collection. (Note: The EPA new RCRA Methods
Manual, SW-846, Third Edition 1986, requires the
semivolatile organic samples be extracted within 7
days of sample collection.)
o Comment: Since the Second Edition of SW-846 did not
properly address the sample preservation and holding
time requirements for aromatics in EPA Methods 5030
and 8240, it is advised that the laboratory follow
the sample preservation and holding time requirements
specified in EPA Method 8020 of the RCRA Manual.
Radiochemistrv Laboratory
Core Laboratories has been certified by EPA Region VIII for the
analysis of radionuclides in drinking water since 1980 with
current certification through November 1987. The radionuclides
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67
analyzed by Core Laboratories are gross alpha, gross beta,
Radium-226, Radium-228, and uranium.
MONITORING WELLS
The initial RCRA monitoring system (P-series wells) was
installed in January 1980. The locations of the P-series wells
are shown in Figure 8. These wells were characterized as being
insufficient to adequately monitor ground water at the facility
due to the following reasons:
o Sampling had to be conducted during two or three
separate occasions to obtain enough samples for one
quarterly analysis.
o Several wells were often dry at the sampling time.
o The P-series wells were screened only in the glacial
outwash and did not monitor the upper fractured zone
of the Silurian dolomite to which it is hydraulically
connected.
WMI submitted an application in December 1983 to modify the
ground-water monitoring program. After several revisions to the
application, a supplemental operating permit (1984-16-SP) was
issued to WMI by IEPA.
The installation of the new monitoring wells was completed on
April 2, 1984. The current monitoring system consists of 41
ground-water monitoring wells (G-lll through G-151) and five .
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68
FIGURE 8
LOCATION MAP OF P-SERIES MONITORING WELLS
mi
O
<
o
o
0»
« i
Ul Ul
Ul *
u.
o
z
o
s
5 S
O (A
ft.
^ O
ui 2
c 5
1 ?
u. (0
Source: P.E. LaMorcaux, 1984. Ground-water Quality Assessment for ESL Facility.
Will County, Illinois, July 1984.
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69
glacial till monitoring wells (GT-10 through GT-14). The first
year of quarterly sampling performed to establish initial
background concentrations and values was completed in February
1985.
Well Locations
Four G-series wells are installed hydraulically upgradient from
the limit of the waste management area. Monitoring wells G-lll
through G-114 are located along Patterson Road (see Figure 9).
They are designated as background wells by virtue of their
location upgradient from the facility and away from past waste
management areas. The other 37 G-series wells are installed
hydraulically downgradient at the limits of the waste management
areas and monitor the uppermost aquifer. The locations of these
downgradient wells were determined using the results of the
contaminant dispersion equation and model studies conducted by
WMI consultants.
During the Task Force inspection, members of the Task Force
identified two deficiencies in the well locations:
o Two of the downgradient wells were unavailable for
sampling at the time of the inspection because they
were installed with inflatable packing devices. IEPA
was notified on March 9, 1987, that inflatable
packers had been installed in wells G-139 and G-140.
WMI purportedly installed the packers to prevent
-------
1
1
1
g
i
1
2
2
70
FIGURE 9
LOCATION MAP OF G-SERIES MONITORING WEL
25
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-------
71
contamination of ground water through cracked well
casings, which were discovered during voluntary
borescope investigations. The cracked well casings
were visually verified by IEPA from viewing a
videotape of the borescope investigations. Both
wells were in the assessment phase of monitoring and
were scheduled to be sampled during the Task Force
inspection. WMI presented Task Force personnel with
a waiver of responsibility for ground-water con-
tamination resulting from the removal of the
inflatable packers. The wells were not sampled
because (1) EPA policy is not to sign any waiver of
responsibility, (2) there was no available method to
sample the ground water below the packer, 3) they
have a well documented history of contamination, and
(4) of the time constraints of the inspection.
Therefore, a portion of the perimeter of the waste
management area, longer than 600 feet along the
southern edge of the co-disposal landfill, was
unmonitored for a period of time, including the time
of the Task Force inspection.
o Five GT-series monitoring wells (GT-10 through
GT-14) are situated around the perimeter of the waste
management area, one upgradient (GT-14) and four
downgradient (see Figure 9). The purpose of the
glacial till wells as stated by WMI is to confirm
that no contaminants are migrating horizontally
through the clay till and bypassing the aquifer
monitoring wells. The number of wells and their
associated spacing appears inadequate to meet the
stated objective, because WMI's consultants deter-
mined that a 37-well network was necessary to
adequately monitor the perimeter of the waste
management area in the uppermost aquifer.
The Task Force recommends that the contaminant dispersion model
used by WMI's consultants be evaluated to assess the assumptions
it incorporates and to assess the conversion of the model
results to the lateral monitoring well spacing used at the site.
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72
Well Construction
The modified ground-water monitoring well system consists of a
total of 46 wells, shown in Figure 9. The system consists of 11
wells installed at the site in several phases during 1982 and
1983 and 35 new wells installed in March 1984. The wells
include 2-inch ID and 4-inch ID PVC riser and screen. WMI
indicated that the older 4-inch diameter wells were drilled with
a hollow stem auger, nominal 8-inch diameter boring. The 2-inch
diameter wells were drilled using rotary wash techniques,
nominal 6-inch diameter borings. The 4-inch or 6-inch nominal
diameter borings were advanced into bedrock. WMI stated that
the older wells were installed with Schedule 80 PVC plastic.
WMI stated that all of the joints are threaded with Teflon tape
on the threads. All well screens are No. 10 slot size. Table 6
presents a summary of the monitoring well construction
parameters.
The 41 wells installed in the uppermost aquifer have varying
ranges in screen lengths (see Table 6). WMI indicated that the
length of screen in each well was selected to provide screening
in the entire section of the uppermost aquifer to intercept
water through the aquifer profile. The wells extend 10 feet
into the bedrock to sample water in the fractured and weathered
dolomite of the uppermost aquifer. Figure 10 is a schematic
diagram of the typical construction for the uppermost aquifer
monitoring wells.
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73
TABLE 6
MONITORING WELL CONSTRUCTION DESCRIPTION
D«M
00/10/03
00/11/03
03/29/04
03/30/14
03/24/04
03/34/14
10/14/03
03/30/04
03/70/14
03/21/14
03/21/14
13/07/12
03/23/14
03/23/14
03/3C/04
03/30/14
03/2C/04
03/29/14
03/29/14
03/31/04
03/37/04
03/24/04
03/33/14
10/27/13
03/2C/04
03/33/04
03/31/14
03/37/04
OC/17/13
03/37/04
03/30/04
03/30/04
03/21/04
09/37/03
03/1C/04
03/13/04
03/K/04
03/23/14
04/14/13
04/U/S3
03/21/04
12/04/02
03/20/14
03/2S/I4
01/29/02
03/30/04
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Tot*
O.pt
24
41.1
44.0
31.0
37.0
33.3
34.3
41.0
45.0
47.0
40.0
44.3
33.0
47.0
32.0
S2.0
31.0
37.0
37.0
(1.0
(S.O
C2.0
Cl.S
43.0
C1.3
C2.0
Cl.O
C2.0
41.0
Sf.S
49.0
30.0
42.0
30.0
C3.0
37.0
57. C
51.0
37.0
37. S
sc.o
25.0
21.5
27.0
25.0
1 Scr.*n
h L.noth
S'
S'
4.12'
14.1'
23. 9S'
23. 9S'
S'
14.4'
14.71'
14.71'
1*. 4'
9.4*
13.2'
14.4*
19.12'
19.1'
19. IS'
19.1'
19.1'
19.13'
13.1'
19.2'
19. (1*
S'
19. IS'
23.95*
24.0*
23. f
S'
23.95'
19. 20«
19. 2«'
14.71'
5'
29.57'
19.17'
U.l'
14.37'
v •
5'
14.37'
4.7'
9.4'
9.4«'
4.7'
I»«etb
tr W «t<
314-
12.9'
314*
3JJ'
33.0*
X.l*
314*
33J'
32.T
304*
304*
30.31
304*
31.1'
31.7'
33.9*
3S4*
se.71
37.4'
334*
SI.I'
WJ-
S3«'
334*
334'
NA
NA
10.0-
394*
394'
37.9'
374'
S7J'
ir.a-
374'
39J'
33.7'
34.9'
21.91
19.4'
11.9'
CT14
(* Bollo* st.a
15.0'
Note: Depth to water level measurements were made from the top of the casing.
NA — designates wells that were not available for sampling at the time .
of the inspection.
Source: Waste Management of Illinois, Inc., 1983. RCRA Part B Permit
Application, Volume II - Groundwater Monitoring. September 1983 with
revisions, July 1985.
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74
FIGURE 10
TYPICAL CONSTRUCTION FOR THE UPPERMOST AQUIFER MONITORING WELLS
« INCH OIMCTCI tT t rr. uO«K. STJSi.
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,
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/ rnuftrrr turttn* CBILAB A»»>a»iu-
/A" i rr. OIAMITER TO j rr. oerrw
(•!•;, '( »•". * rr.
'^
\
S /•B~AMMUUtS riLLCO WITH CtMCNT««CMTOM!TK MOU
S /
S /
>
i «
S
s
v • t INCH OIAMCTCI MICMOLC
s
s
• •— •— t i«en ot*MeTei SCHCOULC to *vc
s ACCTOMC MtnCO. STEM* CktAaeO
s
s
s
. / i MMTONfTC rtLLCT SCAL. MINIMUM
s / -a mi T«I«
» /
• f /^^ILTXI P4CX 0^ MAtMCO •Ct.L-6«*OeO
J / tAMO i TO s rtn A«ove TO* or SCICCN
t / (STOCKPILE *MO TEST roc CHCMICAI.
/ ^AAAMCTCBS WIO« TO USC}
<
t IMCM OIAMCTCI fCMCOULe 10 PVC
(t.Ol IKM). fLUt»»COurv.CO. tCKCM-WOIMl
ACXTOMC •AiMCO. STCAM CLCAMCO
/ - / /
/ / /
/ / /
• * !•. »IAMCTH *0«I»«L£ !• •COCOCK
CA* M PLUC OM MTTOH Of VCLL
Source: Waste Management of Illinois, Inc., 1983. RCRA Part B Permit
Application, Volume II - Groundwatcr Monitoring, September 1983 with
revisions, July 1985.
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75
After each borehole was completed, the well screen and pipe were
installed in the boring. Well-graded sand was installed around
the well screen to the top of the bedrock. Then the temporary
casing was removed and water flushed through the casing (from
inside to outside) to clean any mud cake in the outwash zone.
Sand pack was added to the annular space to approximately 2 feet
above the base of the till. A bentonite pellet seal with a
minimum thickness of 2 feet was installed above the sand pack.
Cement-bentonite grout was used to fill the annular space from
the top of the bentonite pellet seal to the ground surface. A
concrete anchor collar, which extended to approximately 3 feet
deep, was cast around the well at the ground surface. A 6-inch
diameter protective steel casing with a hinged cap and provision
for a lock was set in the anchor collar.
The construction of the wells completed in the glacial till
varied somewhat from the uppermost aquifer wells. Borings were
drilled to approximately 25 feet using nominal 8-inch diameter
hollow stem augers. Schedule 80, 4-inch diameter PVC with No.
10 well screen and casing were installed after the augers were
removed. Well-graded sand was installed in the annular space
around the well screen to approximately 2 feet above the top of
the screen. Then a bentonite pellet seal with a minimum
thickness of 1 foot was installed above the sand pack. The
remainder of the glacial till well construction is the same as
that used for the aquifer wells.
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76
Following construction, each-well was developed by continuous
pumping or bailing to remove fines from the well casing and sand
pack. A minimum of three well volumes was removed from each
well.
Total depth measurements could not be made on the aquifer wells
because each was equipped with a dedicated Well Wizard. The
facility representatives remove the Well Wizards on an annual
basis to measure total well depths. WMI provided the total well
depths from the most recent measuring. This data revealed that
well G-136 is 3.65 feet shallower and well G-137 is 4.06 feet
shallower than when originally installed.
The Task Force has raised the concern of potential chemical
interaction between organic chemical contaminants and the PVC
well casing and screen material. Both the RCRA Ground-Water
Monitoring Technical Enforcement Guidance Document (TEGD) (U.S.
EPA, 1986b) and the Illinois State Water Survey Guide to the
Selection of Materials for Monitoring Well Construction and
Ground-Water Sampling, state that well construction and sampling
components made of PVC rather than more inert materials could
lead to. a bias in ground-water samples because of sorption and
desorption of hazardous constituents onto the casing and pump
discharge tubing.
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77
Task Force personnel indicated that for wells constructed prior
to 1984, discrepancies were found between field observations and
the sampling plan regarding the construction material. Not all
of these wells were constructed using Schedule 80 PVC pipe. The
Task Force also noted that the sand pack was not selected based
on site-specific geologic information, but rather based on basic
general procedures.
The Task Force noted that some of the wells have long screened
intervals, in excess of 20 feet. Well construction information
indicates that there is also 2 feet of sand pack above the top
of the screen, so that the effective screened intervals are 2
feet longer than the values given in Table 6. The Task Force
feels that some of these screened intervals are too long. The
TEGD states that excessive screen lengths can result in the
dilution of contaminants present in the ground water (U.S. EPA,
1986b). The Task Force also recommends that well clusters be
used for any additional monitoring wells installed at the ESL
facility where the uppermost aquifer thickness requires that
water would be drawn from the entire thickness.
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78
GROUND-WATER AE-TflNT PROGRAM OUTLINE
State regulations, 35 IAC 725.193 (equivalent to 40 CFR Part
265.93), require a TSD facility to prepare an outline of a
ground-water quality assessment program. This outline must
describe a comprehensive program capable of determining:
o Whether hazardous waste or hazardous waste
constituents have entered the ground water
o The rate and extent of migration of hazardous
waste or hazardous waste constituents in the
ground water and
o The concentrations of hazardous waste or
hazardous waste constituents in the ground water
If analyses conducted under the indicator evaluation program
indicate that the facility may be affecting ground water,
additional samples are to be taken immediately to determine if
the original analytical results were biased by.laboratory error.
If ground-water effects are still suspected, a ground-water
quality assessment program is to be developed based on the
outline and specifying:
o Number, location, and depth of wells
o Sampling and analytical methods for those
hazardous wastes or hazardous waste constituents
in the facility
o Evaluation procedures, including any use of
previously gathered ground-water quality
information
o A schedule of implementation
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79
The "Outline of Ground-Water Quality Assessment Program"
appearing in an undated document entitled "Ground-Water
Monitoring Program for CWM, Inc.., Joliet, Chemical Waste
Management, Inc., Laraway Road, Elwood, Illinois" was determined
by IEPA to be inadequate to meet the requirements of 35 IAC
725.193.
In general, the outline lacks the specificity of detail in
procedures and methodology that should facilitate development of
assessment plans which adequately deal with detected releases.
As a result of this lack of specificity, ground-water quality
assessments which have occurred at the ESL facility have been
characterized by long, drawn-out iterative processes in develop-
ment of acceptable assessment plans and, thereby, contributing
to lengthy but essentially superficial ground-water quality
assessments. Specifically, the deficiencies in the "Outline of
Ground Water Quality Assessment Program" which lead to the
problems discussed above include the following:
o The outline did not stipulate specific criteria
for installing additional downgradient wells and
a predetermined strategy for locating those
wells.
i
o The outline contains insufficient information on
when, why, and under what conditions the number
of cluster wells should be increased.
o The outline did not stipulate conditions under
"which nearby ground-water supplies (such as
private wells) indicator parameters would be
analyzed for in the samples.
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80
o The outline fails to stipulate the conditions
under which downgradient surface waters, which
receive ground-water discharge, would be
sampled, the sampling scheme that would be used,
and what indicator parameters would be analyzed
for in the samples.
o The outline fails to specify the acceptable
conditions under which monitoring wells would be
allowed to return to indicator evaluation
monitoring.
o The outline fails to specify the proposed models
for predicting rate and extent of migration of
pollutants, though modeling is proposed for
evaluating nonattenuating pollutants, attenuat-
ing pollutants, pollutants chemically or
biologically affected in ground water, and
pollutants subject to filtration in ground-water
media. The outline should specify which model
or models are being proposed so that the
adequacy of those models can be reviewed before
they are actually needed. It should also be
specified that modeling would only be used for
interpolation due to lack of confidence with
well system, and because of difficulty in
meeting all the assumptions required in most
ground-water models. Often it is particularly
difficult to meet the assumption of homogeneous
media found in most ground-water models.
Specific models should be proposed, and those
proposals should be either supported by field
data or associated uncertainties should be
identified so that modeling results can be
evaluated in the proper framework.
o The outline should specify in greater detail the
conditions for adjustment of, and the criteria
for determining, the selection of, and the
frequency. The current outline states,
"Increase sampling frequency based upon plume
movement, environment hazard potential, and
probable timing of pollution abatement
measures." The outline fails to state what
conditions of plume movement would trigger
increased sampling frequency and how informa
tion on plume movement will be used to select or
propose alternate sampling frequencies. The
outline fails to evaluate environmental hazard
potential and how would it be used to propose or
alter sampling frequency. The outline also
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81
needs to address the potential hazard to human
health and wildlife and the exposure pathways
that need to be considered.
GROUND-WATER
Ground-water assessment monitoring has been initiated for some
of the wells in both the P- and G-series, as mentioned
previously. The specific details of these ground-water quality
assessment programs are discussed in the following two subsec-
tions.
Ground-Water Quality Assessment for the P-Series Wells
In a June 9, 1983 letter, WMI notified IEPA of significant
changes in indicator parameters for the P-series wells.
Statistically significant changes in ground-water quality were
indicated for wells P-l for pH (decrease) and specific conduc-
tance (SO, well P-2 for SC, well P-3 for pH (decrease) and SC ,
well P-4 for pH (increase), well P-7 for SC, and well P-8 for
SC. The facility's Student's t-test compared the semiannual
sampling results with background quality for each downgradient
well. Statistical comparisons under 35 IAC 725.193 (b) should
have been made between semiannual sampling results and the
initial background quality of the upgradient wells. WMI
subsequently reran its Student's t-test, this time comparing
semiannual sampling results with the- background quality at each
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82
upgradient well (P-4 and P-7) separately. This time, well P-l
showed a significant decrease in pH, while P-series wells (P-l
through P-6) showed significant increases in SC.
WMI submitted a ground-water quality assessment plan to IEPA on
June 24, 1983. That plan was subsequently found deficient by
IEPA reviewers. An iterative process of revising the assessment
plan then began, involving a series of phone conversations and
letters between WMI and IEPA personnel. This iterative process
continued from June 1983 to November 18, 1983. On that date,
WMI submitted a revised ground-water quality assessment plan,
which the facility characterized as better portraying "Phase I
of the plan in context of the overall plan." lEPA's Land
Division Subpart F file includes no record that IEPA approved
the November 18, 1983, revised plan. Nevertheless, this was
apparently the final implemented form of the ground-water
quality assessment plan for the P-series wells assessment. The
revised assessment plan consists mainly of a first determination
(false positive rationale) approach to ground-water quality
assessment. In addition, an "Outline of Assessment of Ground-
Water Quality" was attached to the revised assessment plan to
demonstrate* Phase I activities in the context of the facility's
overall plan. The schedule of implementation indicated that
completion of Phase I and submittal of Phase II of the plan
would be completed by March 1, 1984.
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83
WMI concluded in its Phase I assessment report that additional
sampling and analysis was needed to further assess ground-water
quality in the vicinity of monitoring well P-5. The following
proposals were recommended by WMI for continued assessment in
this area:'
Phase II
A. Obtain samples from P-5 and the two new wells nearest to
it and analyze these samples for indicator parameters
(replicate analyses) and ground-water quality par-
ameters. These analyses should be evaluated both
statistically and qualitatively to determine if samples
from P-5 are representative of the uppermost aquifer, if
the elevated TOX values persist, and if similarly
elevated TOX values are found in the new wells fully
penetrating the uppermost aquifer.
B. If this sampling and analysis does not confirm the
anomalous TOH values, report on the results of the Phase
II assessment, proceed with the decommissioning of P-5,
and resume the detection monitoring program specified by
40 CFR Part 265 Subpart F and 35 IAC Part 725 Subpart F.
Phase III
If the sampling and analysis conducted under the Phase
II assessment described above show the elevated TOH
levels persist and determine those levels to be
.representative of the upper most aquifer, WMl's con-
tractor recommended that the results of Phase II be
reported and that a Phase III assessment be conducted.
Phase III would likely include sampling and analysis of
well P-5 and the two adjacent new wells for volatile
organic compounds. This analysis should allow
definitive conclusions to be made. More detailed
recommendations for Phase III will be prepared at the
conclusion of Phase II, as appropriate.
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34
WMI failed to voluntarily move into Phase II of its assessment.
A CIL, citing 35 IAC 725.193(d)(4), was issued to WMI by IEPA on
October 11, 1985, for failing to implement Phase II of the
ground-water quality assessment plan. This CIL specifically
stated that the results of analyses for wells P-5, G-128, and G-
129 were not evaluated either statistically or qualitatively to
determine if:
o Samples from P-5 were representative of the
uppermost aquifers
o The elevated TOH values persisted
o Similarly elevated TOH values were found in the new
wells (G-128 and G-129) fully penetrating the
uppermost aquifer, as were found in the old well P-5.
At the time of issuance of the October 11, 1985 CIL, WMI had not
moved into Phase II of the assessment regarding well P-5 as
indicated in its July 1984 Phase I assessment report and as
required pursuant to 35 IAC 725.193(d)(4). The first sampling
event in fulfillment of Phase II of the assessment did not occur
until November 25, 1985, almost 1-1/2 years after final
submittal of the Phase I assessment report, and after receipt of
lEPA's October 11, 1985 CIL. WMI implemented Phases II and III
of the assessment based only on an assessment plan outline
rather than a formal assessment plan, detailing the specific
evaluation procedures for Phases II and III, as required under
35 IAC 725.193(d)(3).
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85
On February 18, 1986, IEPA received copies of a February 17,
1986, document entitled "Phase II and III Recommendations to the
Ground-Water Quality Assessment for the ESL Facility, Will
County, Illinois (The P-Series Wells)." The document indicated
that WMI had decided to move into Phases II "and III simul-
taneously. Based upon Phase II report results incorporating two
sampling events (November 25, 1985 and December 27, 1985), WMI
concluded that elevated TOH levels were erratic in P-5, showing
up in the November sample but not in the December sample.
Similarly, WMI also concluded that the results of volatile
organic compound analyses for well P-5 were also erratic since
volatile organics were not present at detectable levels during
the November sampling event, even though the following organics
were detected in the December samples:
Dichlorodifluoromethane 116 ug/L
1,1-Dichloroethane 6.42 ug/L
Vinyl chloride 271 ug/L
Despite these findings, WMI concluded in its February 17, 1986,
document that:
"P-5 should also be decommissioned, along with the
remaining P-Series wells. There are several reasons
for this, based on results of the Phase II and III
investigation.
1. P-5 is not screened in the roc3c/outwash interface.
The purpose of the G-Series wells was to monitor the
outwash and rock portions of the aquifer, because the
P-Series wells were always drying up and a more
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86
representative sample of the aquifer could be
obtained from the G-Series wells.
2. The surrounding G-Series wells are yielding samples
that are accurately representing ground-water
quality in the aquifer near P-5.
3. The erratic elevated TOX and detectable volatile
compounds in P-5, where these parameters are absent
in G-126 and G-127, suggest contamination of P-5,
which is not related to the landfill.
A schedule and method of decommissioning the P-Series
wells will be forwarded to the Agency within 30 days."
IEPA was subsequently notified on March 5, 1987, that the P-
series wells had indeed been decommissioned on March 4, 1987.
Ground-Water Quality Assessment for the G-Series Wells
From the results of the August 1985 sampling event, seven of the
new G-series wells entered the assessment phase. These wells
included G-117 for specific conductance (SO; G-128, G-129,
G-131 and G-137 for pH; G-139 for SC, TOC, and TOX; and G-140
for pH. WMI failed to immediately retest the seven monitoring
wells that showed significant changes in indicator parameters,
as required under 35 IAC, Part 725.193 (c) (2) and 40 CFR Part
265.93 (c)(2). A "Ground-Water Quality Assessment of ESL,
Joliet, Illinois" report submitted to IEPA by WMI on August 25,
1986, contains a statistical re-evaluation of monitoring wells
G-128, G-129, G-131, G-137, and G-140 for pH. Of these, only G-
131 failed the average replicate test the second time. This
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87
second statistical re-evaluation, based on data collected by WMI
during the first quarter 1986, was interpreted by IEPA as their
eventual submittal of results of the resample efforts to comply
with 35 IAC 725.193 (c) (2). As such, IEPA issued a CIL on
December 1, 1986, citing apparent violation of 35 IAC
725.193(c)(2) for failing to retest wells G-117 and G-139 for
SC, and G-139 for TOX and TOC. In addition, the CIL cited
apparent violation of 35 IAC 725.193(d)(4) for failing to
determine rate and extent of migration of hazardous waste or
hazardous waste constituents from well G-131, the only well that
failed the average replicate test for pH the second time. The
results of analyses of parameters contained in 40 CFR Part 261
Appendix VII submitted for the well G-131 assessment detected
the presence of methylene chloride at 3.77 ug/L and methyl ethyl
ketone at 4.2 ug/L, thus subjecting the ESL facility to the
plume description requirements of 35 IAC .725.193(d)(4) . EPA'S
July 16, 1986 complaint had already sought a complete plume
description for all hazardous constituents in the ground water.
WMI's December 12, 1986, response to lEPA's December l, 1986,
CIL adequately resolved the citation of 35 IAC 725.193(c)(2) ,
but the citation for Section 725.193(d)(4) remained unresolved.
A return to compliance letter for Section 725.193{d)(2) was sent
to WMI on December 19, 1987. However, WMI was apparently
unaware that Section 725.193(d)(4) remained outstanding until
this fact was pointed out by IEPA personnel during a February
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88
12, 1987, reconnaissance visit to the ESL facility in prepara-
tion for the March 1987 Task Force inspection.
A response from WMI dated March 13, 1987, further addressed
apparent violation of 35 IAC 725.193(d)(4). This response was
subsequently deemed inadequate to resolve the outstanding
violation, but it did clear up one point of confusion regarding
WMI's eventual ("immediate") resampling effort submitted in its
August 25, 1986, assessment report. WMI's March 13, 1987,
letter to IEPA stated that the second round of statistics had
not been submitted pursuant to the regulatory requirements of 35
IAC 725.193, as had been previously interpreted by IEPA
personnel. As a result of this finding, IEPA concluded that all
seven monitoring wells that originally "triggered" into
assessment during the August 1985 sampling event were subject to
the immediate resample requirements of 35 IAC 725.193(c)(2) ,
and, failing to meet this requirement, all seven wells became
subject to the plume description requirements of 35 IAC
725.193(d)(4). Table 7 shows the detected organic contaminants
reported in the 40 CFR Part 261 Appendix VII test results in
WMI's August 25, 1986, assessment report.
Despite detection of the contaminants listed below, WMI's August
25, 1986, assessment report concluded that monitoring wells G-
117, G-128, G-129, G-131, and G-137 should return to indicator
evaluation monitoring because methylene chloride was detected in
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89
TABLE 7
HISTORIC DETECTED ORGANIC CONTAMINANTS
REQUIRING INITIATION OF THE ASSESSMENT PROGRAM
Well Number Parameter Level (ucr/L)
G-117 ' Methylene Chloride 1.3
G-117 Methyl Ethyl Ketone 2.8
G-128 Methylene Ch-loride 12.4
G-128 Methyl Ethyl Ketone 2.4
G-129 Methylene Chloride 14.2
G-129 Vinyl Chloride 24.3
G-131 Methylene Chloride 3.77
G-131 Methyl Ethyl Ketone 4.2
G-137 Methylene Chloride 3.11
G-139 Benzene . 44.7
G-139 Benzene 10.6
G-139 Benzene 27.3
G-139 Toluene 154.0
G-139 Toluene 41.0
G-139 Toluene 153.0
G-139 Trichloroethylene 11.l
G-139 Trichloroethylene 21.9
G-139 Methylene Chloride 3.61
G-139 Methyl Ethyl Ketone 85.7
G-139 m-xylene 11.1
G-139 o&p-xylenes 53.2
G-139 m&p-cresols 77.8
G-139 1,4-Dichlorobenzene 6.89
G-139 . Phenol 40.5
G-140 Benzene 24.2
G-140 1,1-Dichloroethane 309.0
G-140 1,2-Dichloroethane 45.1
G-140 1,2-trans-Dichloroethylene 603.0
G-140 Methylene Chloride 4.59
G-140 1,2-Dichloropropane 30.4
G-140 Tetrachloroethylene 7.34
G-140 Trichloroethylene 37.1
G-140 Vinyl Chloride 41.2
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90
the QC matrix unspiked sample -(6.79 ug/L) and methyl ethyl
ketone was detected in both the QC blank and QC matrix unspiked
sample (23.8 and 4.31 ug/L, respectively). It should be pointed
out, however, that neither the QC blank or QC matrix unspiked
sample represented the sample control values for the downgradi-
ent wells. Proper sample control values for the test wells
(assessment wells) are represented by the field blanks drawn for
these seven wells. WMI's August 1986 assessment report
indicated that neither methylene chloride nor methyl ethyl
ketone had been detected in the field blanks for these wells.
The only verified external contamination occurred in the QC
samples prepared totally within the laboratory. Nevertheless,
WMI concluded that the absence of methylene chloride or methyl
ethyl ketone in the field blank did not indicate the absence of
methylene chloride or methyl ethyl ketone in the laboratory and
that it considers these contaminants attributable to lab
contamination and not related to the ground water.
WMI failed to address possible reasons for detection of
methylene chloride and methyl ethyl ketone in downgradient well
samples while failing to detect identical contaminants in the
field blank controls, which were prepared and handled in a
manner identical to the downgradient well samples. No further
investigation was proposed by WMI at the time of the inspection.
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• 91
STATUS OF GROUND-WATER MONITORING UNDER INTERIM STATUS
As a result of the Task Force inspection, the following
violations of the RCRA regulations pertaining to ground-water
monitoring were discovered.
1. Pursuant to 35 IAC 725.190(b), except as paragraphs (c)
and (d) provide otherwise, the owner or operator of a
TSD facility must install, operate and maintain a
ground-water monitoring system which meets the require-
ments of Section 725.191 and must comply with Sections
725.192 through 725.194. This ground-water monitoring
program must be carried out during the active life of
the facility and for disposal facilities during the
post-closure care period as well.
ESL is in apparent violation of 35 IAC 725.190 (b) for
the following reasons: At the time of March 1987 CME
(compliance monitoring evaluation) and Task Force
inspections, temporary packing devices had been
installed in monitoring wells G-139 and G-140, and
therefore, the wells did not meet the requirements of
725.191(a)(2). A waiver was prepared by WMI stating
that any ground-water contamination that resulted from
the removal of the packers for sampling purposes would
be the responsibility of the Task Force The Task
Force did not sign the waiver. On this basis, it
appears that the ground-water monitoring system did
not meet the requirements of 725.191(1)(2). Specifi-
cally, a portion of the perimeter of the waste
management boundary consisting of greater than 600 feet
(the distance between monitoring wells G-138 and G-141)
was unavailable for sampling for a period of time,
including the time of the CME and Ground-Water Task
Force inspections. Both wells G-139 and G-140 were
scheduled for sampling during these inspections.
2. Pursuant to 35 IAC 725.193(d)(4), the owner or operator
must implement the ground-water quality assessment plan
which satisfies the requirements of paragraph (d)(3),
and, at a minimum, determine:
A. The rate and extent of migration of the hazardous
waste or hazardous waste constituents in the ground
water; and
-------
92
B. The concentrations of the hazardous waste or
hazardous waste constituents in the ground water.
ESL is in apparent violation of 35 IAC 725.193(d)(4)
for the following reason(s): The rate and extent of
migration of the hazardous waste or hazardous waste
constituents detected during assessment monitoring
have not been determined.
Two additional deficiencies were noted at the time of the Task
Force inspection:
o Discrepancies in total well depths were discovered
when original boring logs were compared with data
from the most recent (January 6, 1987) measuring.
Well G-136 was 3.65 feet shallower and well G-137 was
4.06 feet shallower than when originally installed.
o The facility made no provisions for the disposal of
the ground water purged from the monitoring wells
before the samples were taken. If analysis of the
well water suggest that the water is hazardous, it
should be drummed and disposed of properly.
GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT
EPA Region V requested a Part B permit application from ESL
early in 1983 and received it on September 1, 1983. As a result
of IEPArs and EPA Region V's review of the Part B permit
application, ESL was issued several notices of deficiency (NOD),
and many responses and reviews have been exchanged. On June 21,
1986, EPA issued an administrative complaint and compliance
order to WMI for failing to supply information required to
complete the Part B permit application.
-------
93
The compliance order identified the following information as
necessary to complete the Part B application.
o A complete summary of ground-water monitoring data
obtained during interim status, as required by 35 IAC
703.185U) and 40 CFR 270.14(c) (1) . '
o A plan and implementation schedule for the descrip-
tion of any plumes of contamination that have entered
the. ground water from a regulated unit. The plan
must include the information required by 35 IAC
703.185(b-d) and 40 CFR 270.14(c)(2-4).
o Detailed plans and an engineering report describing a
proposed ground-water corrective action monitoring
program to meet the requirements of 35 IAC 724.200 as
required by 35 IAC 703.185 (e and h) (40 CFR 264.100
as required by 40 CFR 270.14(c)(8).
MONITORING DATA ANALYSIS FOR INDICATIONS OF WASTE RELEASE
This section presents an evaluation of the Task Force monitoring
data regarding indications -of apparent or potential leakage from
the waste management units at the ESL facility. The analytical
results from samples collected by Task 'Force personnel are
presented in Appendix A. Appendix B contains an evaluation of
the quality control data pertaining to the analysis of the Task
Force samples. This evaluation should be considered when
assessing the ground-water analyses.
All positive acetone and methylene chloride results are
considered unusable because these contaminants were also present
in the field and trip blank samples. Table 8 indicates the
-------
94
concentrations of volatile and semivolatile organics found
during the Task Force sampling. Several wells exhibited organic
constituents at levels greater than CRDL. Well G-129 had vinyl
chloride present (10 ug/L and 11 ug/L (duplicate)), well G-123
had 1,2-trans-dichloroethane present (6 ug/L), and well G-134
had trans-1,2-dichloroethane and 1,1-dichloroethane present (19
ug/L and 12 ug/L, respectively).
Two wells showed values exceeding the maximum levels specified
in 40 CFR 265 Appendix III (35 IAC 725 Appendix C) . The wells
affected were G-117 (fluoride at 9.2 mg/L) and GT-14 (Nitrate at
20.0 mg/L).
The total lead data was judged to be qualitative in an evalua-
tion of the quality control data. Wells G-117, G-118, G-137,
and G-141 all showed an increase in total lead over the
upgradient wells and are above the national interim primary
drinking water standards levels. Twenty-one wells showed total
iron levels above the proposed secondary drinking water
standards levels. Total aluminum, calcium, magnesium, man-
ganese, and sodium values for downgradient wells were often
above the values for the upgradient wells. Zinc, vanadium, and
tin were detected in some of the downgradient wells but were not
present in either of the upgradient wells (G-112 and G-113).
-------
95
Wells G-117, G-124, G-134, and G-149 revealed values for total
organic carbon (TOO at least two times greater than the upgradient
wells. Wells G-125, G-131, G-132, G-134, G-137, and G-141 showed
values for purgeable organic carbon 10 times greater than the
upgradient wells.
Further analyses of 12 wells indicated sulfate values at least four
times greater than the values for the upgradient wells. The sample
analyses also indicated that no pesticides or herbicides were
detected in any of the wells.
The analysis of samples collected by the Task Force found a number
of organic compounds in well G-123, G-129, and G134. Based on the
historical sampling data and the Task Force sampling data, the Task
Force concludes that contamination does exist in the ground-water at
the ESL facility.
-------
96
TABLE 8
ORGANIC ANALYSES FRCM TASK FCRCE SAMPLING
Well
Field Blank
G-123
G-129
G-129*
G-131
G-134
G-;44
Vinyl
Chloride
2J
10
11
1,2-Trans 1,1-
Fhenol Dichloroethene Dichloroethane
6J
1J 6
1J
19 12
3J
Benzene
1J
Notes: All concentrations are reported in ug/L.
* Indicates a duplicate sanple.
J Indicates an estimated value. This flag is used either when estimating a concentration for
tentatively identified compounds where a 1:1 response is assumed or when the mass spectral
data indicated the presence of a compound that meets the identification criteria but the
result is less than the specified detection limit but greater than zero.
Source: Task Force ground-water sample analyses. See Appendix B.
-------
97
REFERENCES
Alliance Technologies Corp., 1987. Trip Report on ESL, Joliet, Illinois. April 1,
1987.
Illinois State Water Survey, 1983, Guide to the Selection of Materials for Monitoring
Nell Construction and Groundwater Sampling, August, 1983.
Kblata, D.R., T.C. Buschbach, and J.D. Trevrorgy, 1978. The Sandwich Fault Zone of
Northern Illinois, Illinois State Geological Survey Circular Mb. 505, p. 26.
LaMoreaux, P.E. (PELA), 1984. Ground-Water Quality Assessment for the ESL
Facility, Win County, Illinois, July 1984.
PRC Environmental Management, Inc., 1987. Report to the Hazardous Waste
Ground-Water Task Force, Re: Evaluation of Quality Control Attendant to the
Analysis of Samples from the Chemical Waste Management, Inc., ESL, Joliet,
Illinois, Facility, August 5, 1987.
united States Environmental Protection Agency (U.S. EPA), 1985. Preliminary
report on ESL-Joliet site by Gale Hruska, April 1985.
U.S. EPA, 1986a. Administrative Complaint and Compliance Order issued to WMI
regarding ESL facility, June 21, 1986.
U.S. EPA, 1986b. RCRA Ground-Water Monitoring Technical Enforcement Guidance
Document (TEGD), Office of Solid Waste and Emergency Response, September
1986.
U.S. EPA, 1987. Memorandum fron Maxine Long to John McGuire, U.S. EPA
Region V, Re: Evaluations of Laboratories used by ESL, October 21, 1987.
Waste Management of Illinois, Inc. (WMI), 1983. RORA Part B Permit Application,
Volume II'- Groundwater Monitoring, September 1983 with revisions, July 1985.
WMI, 1988. Closure Plan for ESL, received by U.S. EPA Region V February 26,
1988.
Willman, H.B., 1971. Summary of the Geology of the Chicago Area, Illinois State
Geological Survey Circular No. 460, p. 77.
Woodward-Clyde Consultants (WCC), 1982. Geologic, Geotechnical and Hydrogeologic
Evaluation of Expansion Area to Chemical Waste Management, Inc. - Joliet,
Will County, Illinois, July 1982.
WCC, 1983, Geologic, Geotechnical and Hydrogeologic Evaluation and Monitoring
Well Recommendations for the Chemical Waste Management - Joliet Landfill,
Will County, Illinois, July 1983.
-------
APPENDIX A
GROUND-WATER SAMPLE ANALYSES
FOR TASK FORCE 3NSPECTDN OF
-------
TABLE Al-1
COHTRACT REQUIRED DETECTION LIMITS AHD IKSTRUMEMT •
DETECTIOH LIMITS FOR" METALS. IHOHCAHIC, ATO INDICATOR PARAMETERS
Parameter
Metals
Aluminum
Antimony
Arsenic
Barium
L«- 1 > 1 J i uiu
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Hickel
Potassium
Selenium
Silver
Sodium
Tin
Thallium
Vanadium
Zinc
Inorganic and Indicators
Bromide
Chloride
Cyanide
Fluoride
Nitrate-nitrogen
Nitrite-nitrogen
POC
POX
Sulfate
Sulfide
TOC
TOX
Total Phenols
CSDL
200
60
10
200
'j
5
5000
10
50
25
100
5
5000
15
0.2
40
5000
5
10
5000
50
10
50
20
1000
1000
10
1000
300
300
100
5
lO'OO
1000
1000
5
50
IDL
94
5
6
3
2
0.5
6?
6
7
18
23
2
84
4
0.2
23
486
4
5
163
72
6
8
20
50
1000
1000
300
50
20
5
500
1000
1000
5
10
concentrations are in yg/1
Al-2
-------
ALLIANCE
T*cnnoiog«s Corporation
T0« R.J. DeLuca 1 April 1987
FROM* Julianne Howe ^'^
SUBJECT: Trip Report - ESL, JolieC, Illinois
Th« U.S. EPA has established a Hazardous Waste Ground Water Task Force
(HWGWTF) to evaluate the level of ground water monitoring compliance at RCRA
regulated treatment, storage and disposal facilities. In order to perform
this evaluation, the EPA has contracted PRO Environmental Management, Inc. to
provide technical services. PRC has subcontracted to Alliance Technologies
Corporation and Versar, Inc. to conduct sampling and provide technical
assistance to the HWGWTF.
One of the facilities selected for evaluation, Environmental Sanitary Landfill
(ESL) is operated by Waste Management of North America, Inc. and located in
Joliet, Illinois. The 260 acre site is located southwest of the junction of
Laraway and Patterson Roads in Will County, Illinois. There has been no
disposal at the site for several years and the landfill.areas are nov covered
with vegetation. There are 41 monitoring wells at the site. Five have
dedicated PVC bailers and the remainder have dedicated Well Wizard teflon
bladder pumps.
On Monday, March 16, 1987 an opening meeting was held at the ESL facility
between participating HWGWTF team members and facility personnel. Present
we res
John McDonnell, Waste Management of N.A., district engineer
John McGuire, EPA Region V, Field Team Leader
Ken Jennings, EPA Washington
Steve Wynnechenko, EPA Region V, Sampling Team Leader
Ken Liss, EPA, State of Illinois
Jonathan Adenaga, EPA Region V
Gulf Coast Personnel (contractors for waste management of NA)
Julie Hove, Alliance
David Billo, Alliance
Sylvie Olney, Alliance
After a brief introduction, the sampling group left the meeting to begin water
level measurements. These were taken by Gulf Coast personnel and included all
but 2 wells which were covered with plastic. Waste management claims that
these wells, G139 and G140, are damaged and would not allow them to be
sampled. There is some dispute between EPA and the facility on this issue.
On Tuesday, March 17, sampling activities began and continued through friday,
March 20. Tuesday through Thursday two field teams were formed, each
consisting of 2 Gulf Coast personnel, 1 Waste Management representative, 1 or
2 Alliance personnel and 1 EPA sampling coordinator. In accordance with Waste
213 Eurfmcton Road. Bedford. Massachusetts 01730 617-275-9000
-------
ALLIANCE
Tecnnottgies Corporation
Management's policy, only their equipment was used in the wells and their
contractors operated that equipment. The facility collected samples at some
of the veils bat because of differences in sampling procedures, were not
considered splits of the samples collected by Alliance for EFA. The purge
volumes calculated by EPA were based on the sum of the volume of sand filter
pack and the additional standing water in the well casing, whereas the
facility based their purge volumes on 3 well casing volumes. The facility
also filtered all their samples for inorganic analyses at the well head.
Twentyfive veils were sampled during the evaluation quality control measures
included duplicate samples taken at two of the wells, one field blank and one
trip bank. Full sample sets were obtained from all but one well (GT 12).
Table 1 summarizes the sampling data at the ESL project.
Table 2 presents the data from field measurements taken during purging.
-2-
-------
SAMPLING DATA
WELL
C131
CT14
C132
C134
C135
C13?
GUI
C124
C125
CT12
HQB
9
038
048
053
046
031
049
037
044
041
040
SAMPLING
DATE
3/18/87
3/19/87
3/19/87
3/19/87
3/19/87
3/19/87
3/19/87
3/19/87
3/19/87
3/20/87
CASING
DIAMETER
2"
4"
2"
4"
2"
2"
2"
2"
2"
4"
TOTAL
DEPTH
65.0
15.0
62.0
45.0
61.5
•61.0
49.0
47.0
52.0
27.0
DEPTH
TO 1120
37.4
33.8
34.2
34.3
32.8
30.0
30.2
30.5
19.4
VOLUME
PURGED
14.5
pbCC
16.5
13.8
16
16.8
20
12.5
15
pbCC
TURUIDITY
(NTU) COMMENTS
4.0
MOO
47
14
32
41
50
8.9
22
MOO
I P & T aomple
Partial Set
5 Extractable
2 P & T
I POC
1 POX
broken
•
Orfcnnlce
1 Diiiolved Hctala
C144
T»
FU
027
050
029
3/20/87
3/13/87
3/19/87
4"
N/A
N/A
30.0
N/A
N/A
27.9
N/A
N/A
6.7
N/A
N/A
62
N/A
N/A
1 Cyanide
1 TOG
Trip Blank
Field Blank at
C125
pbCC - Purged by Gulf Coaat when Alliance personnel were not present.
-------
WELL
t
cm
OT14
C132
C134
CI35
C137
GUI
C124
ens'
CT12
0144
TR
FB
IK)B
*
038
048
053
046
031
049
037
044
041
040
02?
050
029
SAMPLING
DATE
3/18/87
3/19/87
3/19/87
3/19/87
3/19/87
3/19/87
3/19/87
3/19/87
3/19/87
3/20/87
3/20/87
3/13/87
3/19/87
CASING
DIAMETER
2"
4"
2"
4"
2"
2"
2"
2"
2"
4"
4"
N/A
N/A
SAMPLING DATA
TOTAL
DEPTH
65.0
15.0
62.0
45.0
61.5
'61.0
49.0
47.0
52.0
27.0
30.0
N/A
N/A
DEPTH
TO 1120
37.4
33.8
34.2
34.3
32.8
30.0
30,2
30. 5
19.4
27.9
N/A
N/A
VOLUME
PURGED
14.5
pbCC
16.5
13.8
16
16.8
20
12.5
15
pbCC
6.7
N/A
N/A
TURBIDITY
(NTU) COMMENTS
4.0
MOO
47
14
32 1 F & T aa«ple broken
41
50
a. 9
22
MOO Partial Set
5 Extractabl* Organic*
2 P & T
1 POC
1 POX
1 Dlatolved Hetala
1 Cyanide
1 TOG
62
N/A Trip Blank
N/A Field Blank at C125
pbCC - Purged by Gulf Coaat vlien Alliance personnel were not present.
-------
TADI.E 2 CON'T
FIELD MEASUREMENTS
WELL 1
DATE
cm
3/19/87*
CI34
3/19/87
cm
3/19/8?
C137
3/19/87
cm
3/17/87
cm
3/17/87
C1SO
3/17/87
CUB
3/17/87
IN SITU
t
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
4
1
2
3
4
5
1
2
3
4
1
2
3'
4
TIHE
09.36
09i50
10.04
10.58
11,13
Ili30
12.35
12.47
13.00
13.55
14,10
14.40
10,25
10.45
11.15
11,35
12.00
12.13
12,30
13.08
13.29
13.52
14,16
14.33
15,04
15,34
16.00
GALLONS
PURGED
0.5
8.3
15.5
1
7
13
O.S
8 •
IS
0
10
16
0
9
16
AS
pll
7.2
7.3
7.1
11.8
8.6
7.4
7.1
7.1
7.0
7.6
7.1
7.1
7.09
7.10
7.S
7.2
6.9
6.6
6.B
6.65
6.85
7.2
6.9
6.9
6.9
6.85
6.75
6.7
6.7
CONDUCTIVITY
(ualioi/cn)
1240
1240
122S
2000
780
860
92S
910
92S
960
. 940
970
1600
1595
1420
1440
1660
1740
1780
1700
1740
1120
1150
1160
1140
1800
1860
1830
1930
TEMP
<°c)
11.3
11.4
11.1
12.
12.
12.
11.
11.
11.
11.
11.
11.
10.4
9.5
10.9
11.0
10.8
11.8
11.5
11.5
11.4
11.1
11.4
11.6
11.6
11.0
11.6
11.5
11.4
-------
TABLE 2
wri.i. t
DATE
C112
3/17/87
-
CU7
3/17/87
CII9
3/17/87
C128
3/18/87
C129
3/18/87
CI30
3/18/B7
•
C131
3/18/87
IN SITU
t
1
2
3
4
1
2
3
1
2
3
1
2
3
4
5
1
2
3
1
2
3
1
2
3
4
TIME
09.10
09.40
09i57
lOilS
13i20
13.30
13i40
14i3S
14.43
14.48
08.50
08.55
09.05
09.20
09.50
11.47
11.52
11.59
13.20
13.42
13.55
15.20
15.40
PI ELI
GALLONS
I'URCED
0
18
24
28 '
3
7
1
7
9
0.5
3.5
5
I
12.5
0.5
6.5
11
4
8.5
13
0
8.5
10
14
) MEASUREMENTS
pll
7.7
.5
.5
.5
.2
.1
.0
t .2
.2
.1
11.5
11.8
9.7
9.0
8.8
7.7
7.3
7.2
6.8
6.6
6.6
8.4
6.5
6.7
6.4
•
CONDUCTIVITY
(umlioi/cn)
660
620
640
640
2000
1800
1800
1575
1580
1575
• 4300
2200
1150
1380
1420
19SO
1575
1530
1230
1150
1130
790
990
1000
1000
TEMP
<°C)
11.2
11.1
11.2
11.2
11.
11.
11.
11.
11.
11.
11.0
11.1
11.0
11.0
11.1
11.6
11.6
11.5
11.6
11.7
11.5
11.0
11.2
11.1
11.2
-------
SAMPLING DATA
WEM.
1
C113
CHS
C150
CII2
C117
C117
C119
CUB
cua
C149
C120
CI23
C12B
C129
C129
MQB
t
047
039
032
056
033
04 5
043
034
030
052
042
055
036
051
035
SAMPLING
DATE
3/17/87
3/17/87
3/17/87
3/17/B7
3/17/87
3/17/87
3/17/87
3/17/87
3/18/87
3/18/87
3/18/87
3/18/87
3/18787
3/18/87
3/18/87
CASING
DIAMETER
2"
2"
4 1/4"
4"
4"
N/A
2"
2"
2"
4 1/4"
2"
2"
2"
2"
N/A
TOTAL
DEPTH
46.0'
57.0'
37.5'
48.8*
34. S1
N/A
45.0'
48.0*
51.0'
37.0'
47.0*
53.0'
57.0'
57.0'
N/A
DEPTH
TO 1120
31.5'
34.2'
33.7'
23.0'
33.9'
N/A
31.3'
34.1*
27.8'
29.2'
32.1'
30.2'
33.6'
35.5'
N/A
. VOLUME
PURGED
(GALLONS)
26
30
16.5
30
. 1
U/A
10
16.4
24
17
12
12.5
12.5
12
N/A
TURBIDITY
(NTU) COMMENTS
2.0
1.4
2.6
7.0
>100 Matrix spike (all but
Dloxln).
N/A Duplicate
7.4 Matrix aplke Dloxln
only
2.5
16
4.1
11
52
46
6.9
N/A Duplicate & Matrix
_ • •_ .
aplka
C130
028
3/18/87
2"
61.0'
36.7'
IS
15
-------
TADI.F. 2 CON'T
FIELD MEASUREMENTS
WELL *
DATE
C132
3/19/87'
C134
3/19/87
C135
3/19/87
C137
3/19/87
cm
3/17/87
ens
3/17/87
C150
3/17/87
cue
3/17/87
IN SITU
t
1
2
3
I
2
3
1
2
3
1
2
3
1
2
3
4
1
2
3
4
5
1
2
3
4
1
2
3
4
TIME
09.36
09iSO
10i04
10i58
Ilil3
11.30
12.35
12.47
13.00
13.55
14,10
14.40
10.25
10.45
11.15
11.35
12.00
12,13
12.30
13.08
13.29
13,52
Uil6
14,33
15.04
15,34
16.00
GALLONS
PURGED
O.S
8.3
15.5
1
7
13
0.5
8 •
IS
0
10
16
0
9
16
AS
pll
7.2
7.3
7.1
11.8
8.6
7.4
7.1
7.1
7.0
7.6
7.1
7.1
7.09
7.10
7.5
7.2
6.9
6.8
6.8
6.65
6.85
7.2
6.9
6.9
6.9
6.R5
6.75
6.7
6.7
CONDUCTIVITY
(u»lio«/c«)
1240
1240
1225
2000
780
860
925
910
925
960
. 940
970
1600
1595
1420
1440
1660
1740
1780
1700
1740
1120
1150
1160
1140
1800
1860
1830
1930
TEMP
<°c)
11.3
11.4
U.I
12.6
12.6
12.6
11.8
11.8
11.7
11.6
11.9
11.9
10.4
9.5
10.9
11.0
10.8
11.8
11.5
11.5
11.4
11.1
11.4
11.6
11.6
11.0
11.6
11.5
11.4
-------
FIELD MEASUREMENTS
WELL i
DATE
CUB
3/18/87
C149
3/18/87
C120
3/18/87
C123
3/18/87
GUI
3/19/87
CI24
3/19/87
C12S
3/19/87
t
IN SITU
i
I
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4*
1
2
3
4
1
2
3
4
TIME
09llO
09i29
lOiOO
10il9
10i39
10.57
11.11
11.39
I2i43
12.52
13.02
13.19
14.15
14.30
14,39
15.05
9.09
9.38
10.33
16il5
11.38
11.45
11.55
12.19
13.47
13.58
14.07
14.32
GALLONS
PURGED
0
10
24
AS
0
10
16
30
0
$.5
11.5
AS
0
9.5
14
AS
0
5
16
19
0
5
9.5
AS
0
6.5
12.0
AS
pll
7.3
7.1
7.1
7.1
7.15
.2
.1
.2
.0
.9
.0
.9
7.25
7.1
7.1
7.05
7.6*
7.0
7.1
6.8
7.3
7.9
7.2
7.2
7.3
7.0
6.9
6.9
CONDUCTIVITY
(U«|.O»/CM)
1050
1030
1050
1055
2500
2800
2600
2200
1770
1800
1780
1770
1460
1470
1460
1460
1180
1080
1170
1040
1290
1250
1300
1225
1070
1040
1260
1220
TEMP
(°c>
9.0
10.5
10.5
10.2
10.0
10.7
10.9
10.7
10.7
11.1
11.0
10.9
10.2
10.9
11.1
11.1
10.6
11.5
11.9
12.2
11.4
11.5
11.5
11.6
11.5
11.9
11.9
11.8
-------
WELL *
DATE
G144
3/20/87
CT12
3/20/87
IN SITU
t
I
2
3
4
BS
TIKE
08i48
09*04
09i30
10il5
09 • 40
FIELD
GALLONS
PURGED
0
3.5
6.9
AS
MEASUREMENTS
pH
7.0
7.0
7.0
7.0
7.4
\
CONDUCTIVITY
(umhos/ca)
1790
1625
1S40
1420
990
TEMP
<°c)
11.8
11.9
12.0
12.1
12.1
* • pH mtttr r«calibr«ttd «fttr thl« rtading
BS - Before Stapling
AS - After Stapling
-------
APPENDIX A
SWLE MW25ES
FOR IftSK FCRCE mSFECHCN CF
-------
APPENDIX 2
SUMMARY OF CONCENTRATIOHS FOR COMPOUNDS FOUND
IH GROUND-WATER AND SAMPLING
BLANK SAMPLES AT SITE NO. 48; ESL, JOI.1ET. 1L
The following table lists the concentrations for compounds analyzed for
and found in samples at the site. Table A2-I is generated by listing
all compounds detected and all tentatively identified compounds reported
on the organic Fora I. Part B. All tentatively identified compounds
with * spectral purity greater than 850 are identified by name and
purity in the table. Those with a purity of less than 850 are labeled.
unknown.
Ml concentrations are reported in yg/L.
A2-1
-------
TABLE KEY
A value without a flag indicates a result above the contract
required detection limit (CKDL).
J Indicates an estimated value. This flag is used either when
estimating a concentration for tentatively identified compounds
where a 1:1 response is assumed or when the mass spectral data
indicated the presence of a compound that meets the identification
criteria but the result is less than the specified detection limit
but greater than zero. If the limit of detection is 10 yg and a
concentration of 3 vg is calculated, then report as 3J.
B This flag is used when the analyte is found in the blank as well as
a sample. It indicates possible/probable blank contamination and
•warns the data user to take appropriate action.
GU * ground-water
SW » surface-water
low and medium are indicators of concentration.
A2-2
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APPENDIX B
EVALUATION CF THE CjQRLPI? GQORCL
HEE3AINING 10 THE ANALYSIS CF SAMPLES ERQM
-------
MEMORANDUM
DATE: August 5, 1987
SUBJECT: Evaluation of Quality Control Attendant to the Analysis of Samples
from the Chemical Waste Management, Inc., ESL, Joliet, Illinois,
Facility
FROM: Ken Partymiller, Chemist
PRC Environmental Management Inc.
THRU: Paul H. Friedman, Chemist*
TO: HWGWTF: Richard Steimle, HWGWTF*
Gareth Pearson (EPA 8231)*
Maxine Long, Region V
Ken Jennings, HWGWTF
John McGuire, Region V
This memo summarizes the evaluation of the quality control data generated by
the Hazardous Waste Ground-Water Task Force (HWGWTF) contract analytical
laboratories (1). This evaluation and subsequent conclusions pertain to the data
from the Chemical Waste Management, Inc., Environmental Sanitary Landfill, Joliet,
Illinois sampling effort by the Hazardous Waste Ground-Water Task Force.
The objective of this evaluation is to give users, of the analytical data a more
precise understanding of the limitations of the data as well as their appropriate use.
A second objective is to identify weaknesses in the data generation process for
correction. This correction may act on future analyses at this or other sites.
The evaluation was carried out on information provided in the accompanying
quality control reports (2-5) which contain raw data, statistically transformed data,
and graphically transformed data.
The evaluation process consisted of three steps. Step one consisted of
generation uf a package which presented the results of quality control procedures,
including the generation of data quality indicators, synopses of statistical indicators,
and the results of technical qualifier inspections. A report on the results of the
performance evaluation standards analyzed by the laboratory was also generated.
Step two was an independent examination of the quality control package and the
performance evaluation sample results by members of the Data Evaluation
Committee. This was followed by a meeting (teleconference) of the Data Evaluation
Committee to discuss the foregoing data and data presentations. These discussions
were to come to a consensus, if possible, concerning the appropriate use of the data
within the context of the HWGWTF objectives. The discussions were also to detect
and discuss specific or general inadequacies of the data and to determine if these
are correctable or inherent in the analytical process.
* HWGWTF Data Evaluation Committee Member
-------
Preface
The data user should review the pertinent materials contained in the
accompanying reports (2-5). Questions generated in the interpretation of these data
relative to sampling and analysis should be referred to Rich Steimle of the
Hazardous Waste Ground-Water Task Force.
L Sit* Overview
The Chemical Waste Management, Inc. Joliet Environmental Sanitary Landfill
(ESL) facility is located in Joliet, Illinois just outside the Joliet prison and along
the banks of the Oes Plaines River. The facility is presently closed as a result of
contaminated ground water. The geology consists of a till layer or layers with an
interspersed outwash sand layer overlying Silurian carbonate formations. There are
three series of wells at the facility. The wells are designated "P", "G", and T* and
are categorized chronologically. The "P" series of wells were the first wells at the
facility. They were poorly developed and are no longer used. The "G" series of
wells are the present monitoring wells into the outwash sand and dolomite layers
and they are supplemented by a "T" series of wells into the till layer. The facility
has accepted all types of wastes. Contaminants detected in the past include smaller
aliphatic organics.
Twenty-nine field samples were collected at this facility. The samples included
a field blank (MQB029), a trip blank (MQB050), and two pairs of duplicate samples
(well G117, samples MQB033 and MQB045 and well GI29, samples MQB035 and
MQB051) as well as twenty-three'other field samples. All samples were designated
as low concentration ground-water samples. All samples were analyzed for all
HWGWTF Phase 3 analytes.
II. Evaluation of Quality Control Data and Analytical Data
1.0 Metals
1.1 Metals OC Evaluation
Total and dissolved metal spike recoveries were calculated for twenty-four
metals spiked into two samples (MQB033 and 035). Twenty-one total metal average
spike recoveries from these samples were within the data quality objectives (DQOs)
for this Program. The total cadmium, lead, and thallium average spike recoveries
were outside the DQO with values of 770, 152, and 73 percent, respectively. One of
the total iron spike recoveries and one of the total magnesium spike recoveries
were not calculated because the sample results were greater than four times the
amount of spike added. Six individual total metal spike recoveries were also outside
DQO. This information is listed in Tables 3-la and 3-2a of Reference 2 as well as
in the following Sections.
Twenty-four dissolved metals were also spiked into two samples (MQB004 and
012). Twenty of the twenty-four dissolved metal average spike recoveries were
within the data quality objectives (DQOs) for this Program. Dissolved cadmium and
lead average spike recoveries were outside DQO with values of 147 and 126 percent.
Both of the dissolved calcium and dissolved magnesium and one of the dissolved
sodium spike recoveries were not calculated because the sample results were greater
than four times the amount of spike added. Three individual dissolved metal spike
recoveries from these samples were also outside DQO. These samples and results
are listed in Tables 3-1 b and 3-2b of Reference 2 as well as in the following
Sections.
-------
The calculable average relative percent differences (RPDs) for all metallic
analytes, with the exception of total arsenic, were within Program DQOs. RPDs
were not calculated for about two-thirds of the metal analytes because the
concentrations of many of the metals in the field samples used for the RPD
determination were less than the contract required detection limit (CRDL) and thus
were not required, or in some cases, not possible to be calculated.
Required metal analyte analyses were performed on all samples submitted to
the laboratory.
No sample contamination involving the metallic analytes was reported in the
laboratory blanks. Sampling blank contamination was found in the field blank and
will be discussed below.
1.2 Furnace Metals
The quality control results for the graphite furnace metals (antimony, arsenic,
cadmium, lead, selenium, and thallium) were generally acceptable.
The total cadmium, lead, and thallium matrix spike recoveries for spiked sample
MQB033 were outside DQO with values of 800, 224, and 71 percent, respectively.
The total arsenic and cadmium and the dissolved cadmium and lead matrix spike
recoveries for spiked sample MQB03S were outside DQO with values of 65, 740, 176,
and 129 percent, respectively. As a trend, results for analytes with high spike
recoveries should be considered to be biased high and results for analytes with low.
spike recoveries should be considered to be biased low. All results for total
arsenic, total thallium, and dissolved lead should be considered semi-quantitative
unless otherwise qualified. The non-detccts for total and dissolved cadmium and
total lead results should be considered quantitative unless otherwise qualified. All
positive results for these analytes should be considered qualitative.
The correlation coefficients for the method of standard addition (MSA)
determination of total arsenic in samples MQB027, 043, and 046 were below DQO.
The correlation coefficients for the MSA determination of dissolved arsenic in
samples MQB031, 032, 035, 037, 038, and 053 were also below DQO. The total
arsenic result for sample MQB027 and the dissolved arsenic results for samples
MQB032, 037, and 038 should be considered unusable. All other results for the
samples/analytes mentioned in this paragraph should be considered qualitative.
An MSA determination should have been performed on dissolved arsenic in
sample MQB027. Results for dissolved arsenic in this sample should be considered
qualitative.
The duplicate RPD value for total arsenic in sample MQB033 was above DQO.
Total arsenic results should be considered semi-quantitative unless otherwise
qualified.
Continuing calibration verifications (CCVs) for total antimony in samples
MQB027, 029, 041, and 050, dissolved cadmium in samples MQB027, 029, 037, 040,
041, 044, and 050, total selenium in samples MQB027, 029. 032, 039, 041, 047, 050,
and 056, and dissolved selenium in samples MQB030, 034, 043, 045, and 052 were
outside DQO limits. The samples preceding the poor CCV were rerun but the CCV
was not. Results for these samples should be considered semi-quantitative.
-------
It should be noted that in several of the samples the dissolved arsenic results
were greater than the total arsenic results. The HWGWTF does not normally
require a dissolved metals analysis because EPA does not have a standardized
procedure for separating dissolved from total metals.
All dissolved antimony and thallium and total cadmium results should be
considered quantitative. Total antimony, lead, and selenium, and dissolved arsenic,
cadmium, and selenium results should be considered quantitative with exceptions.
All total thallium and dissolved lead results should be considered semi-quantitative.
Total arsenic results, with exceptions, should also be considered semi-quantitative.
Total antimony results for samples MQB027, 029, 041, and 050, dissolved cadmium
results for samples MQB027, 029, 037, 040, 041, 044, and 050, total selenium results
for samples MQB027, 029, 032, 039. 041, 047, 050, and 056, and dissolved selenium
results for samples MQB030, 034, 043, 045, and 052 should also be considered semi-
quantitative. Total arsenic results for samples MQB043 and 046, dissolved arsenic
results for sample MQB027, 031, 035, and 053, and total lead results for samples
MQB033, 034, 037, 045, 048, and 049 should be considered qualitative. Total arsenic
results for sample MQB027, dissolved arsenic results for sample MQB032, 037, and
038, and total lead results for samples MQB028 and 035 should not be used. The
usability of all graphite furnace analytes is summarized in Section 4.0 and 4.1 at the
end of this Report.
1.3 TCP Metals
The matrix spike recoveries for total aluminum and dissolved tin in sample
MQB033 were outside DQO with recoveries of 61 and 73 percent, respectively.
Trends of low spike recoveries indicate a low bias in the data. All results for
these analytes should be considered semi-quantitative.
The low level (twice CRDL) linear range check for all dissolved beryllium,
chromium, cobalt, copper, nickel, silver, vanadium, and zinc results and certain of
the results for total beryllium, chromium, cobalt, copper, nickel, silver, vanadium,
and zinc exhibited low recoveries. See Section B5 of Reference 3 for a detailed
listing of analysis dates, samples affected, and biases. The low level linear range
check is an analysis of a solution with elemental concentrations near the detection
limit. The range check analysis shows the accuracy which can be expected by the
method for results near the detection limits. The accuracy reported for these
metals at these levels is not unexpected.
Dissolved calcium, iron, magnesium, manganese, and sodium and total chromium
contamination were found in the field blank (sample MQB029) at concentrations of
125,000, 1610, 71, 72,500. 9870, and 11 ug/L, respectively. CRDLs for these analytes
are 5000, 100, 15, 5000, 5000, and 10 ug/L, respectively. Due to this contamination,
all positive results greater than 10 times the level of contamination and all negative
results should be considered quantitative. All positive results between 5 and 10
times the highest level of contamination should be considered qualitative and all
other results should not be used. Due to the high level of analytes found in this
sample there is a possibility that this sample was a mislabelcd field sample rather
than a blank.
The internal control standard used for the ICP interference check solution
should have an established mean and standard deviation before being used as an
internal control standard.
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It should be noted that in several of the samples the dissolved aluminum,
sodium, and iron results were greater than the total metal results. As a result the
total and dissolved aluminum results for samples MQB028, 034, 035, 042, 043, 052,
and 055 and the total and dissolved sodium results for sample MQB028 should be
considered semi-quantitative. The total and dissolved sodium results for sample
MQB028 and the total and dissolved iron results for sample MQB044 should not be
used.
All total barium, beryllium, calcium, cobalt, copper, magnesium, manganese,
nickel, potassium, silver, tin, vanadium, and zinc results should be considered
quantitative. All dissolved barium, beryllium, chromium, cobalt, copper, nickel,
potassium, silver, vanadium, and zinc results should be considered quantitative.
Total chromium, iron, and sodium and dissolved aluminum results, all with
exceptions, should be considered quantitative. Dissolved calcium results for samples
MQB029 and 050, dissolved iron results for samples MQB029, 033, 034, 040, 041, 045,
050, 052, and 056, dissolved magnesium results for samples MQB029, 041, and 050,
dissolved manganese results for samples MQB029, 041, 048, and 050, and dissolved
sodium results for samples MQB029, 033, 045, 050, and 052 should also be considered
quantitative. All total aluminum and dissolved tin results should be considered
semi-quantitative. Dissolved aluminum results for samples MQB028, 034, 035, 042,
043, 052, and 055, total iron results for sample MQB044, and total sodium results for
samples MQB028 and 047 should also be considered semi-quantitative. Dissolved
sodium results for sample MQB047 should be considered qualitative. The dissolved
metal results for calcium, iron, magnesium, manganese, and sodium, all with
exceptions listed above, and the total chromium results for samples MQB031, 033,
037, and 052 should not be used. The usability of all total and dissolved ICP. metal
analytes is summarized in Section 4.2 and 4.3 at the end of this Report.
1.4 Mercury
AH mercury results should be considered quantitative with an acceptable
probability of false negatives.
2.0 Inorganic and Indicator Analvtes
2.1 Inorganic and Indicator Analvte OC Evaluation
The average spike recoveries of all of the inorganic and indicator analytes,
except for chloride, were within the accuracy DQOs. Accuracy DQOs have not been
established for the bromide, fluoride, nitrite nitrogen, and sulfide matrix spikes.
Average RPDs for all inorganic and indicator analytes were within Program •
DQOs. The RPDs were not calculated if either one or both of the duplicate values
were less than the CRDL. Precision DQOs have not been established for bromide,
fluoride, nitrite nitrogen, and sulfide.
Requested analyses were performed on all samples for the inorganic and
indicator analytes.
No laboratory blank contamination was reported for any inorganic or indicator
analyte. TOX contamination was found in the field blank at a concentration of 6
ug/L. The TOX CRDL is 5 ug/L.
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It should be noted that in several of the samples the dissolved aluminum,
sodium, and iron results were greater than the total metal results. As a result the
total and dissolved aluminum results for samples MQB028, 034, 035, 042, 043, 022,
and 055 and the total and dissolved sodium results for sample MQB028 should be
considered semi-quantitative. The total and dissolved sodium results for sample
MQB028 and the total and dissolved iron results for sample MQB044 should not be
used.
All total barium, beryllium, calcium, cobalt, copper, magnesium, manganese,
nickel, potassium, silver, tin, vanadium, and zinc results should* be considered
quantitative. AH dissolved barium, beryllium, chromium, cobalt, copper, nickel,
potassium, silver, vanadium, and zinc results should be considered quantitative.
Total chromium, iron, and sodium and dissolved aluminum results, all with
exceptions, should be considered quantitative. Dissolved calcium results for samples
MQB029 and 050, dissolved iron results for samples MQB029, 033, 034, 040, 041, 045,
050, 052, and 056, dissolved magnesium results for samples MQB029, 041, and 050,
dissolved manganese results for samples MQB029, 041, 048, and 050, and dissolved
sodium results for samples MQB029, 033, 045, 050, and 052 should also be considered
quantitative. All total aluminum and dissolved tin results should be considered
semi-quantitative. Dissolved aluminum results for samples MQB028, 034, 035, 042,
043, 052, and 055, total iron results for sample MQB044, and total sodium results for
samples MQB028 and 047 should also be considered semi-quantitative. Dissolved
sodium results for sample MQB047 should be considered qualitative. The dissolved
metal results for calcium, iron, magnesium, manganese, and sodium, all with
exceptions listed above, and the total chromium results for samples MQB031, 033,
037, and 052 should not be used. The usability of all total and dissolved ICP metal
analytes is summarized in Section 4.2 and 4.3 at the end of this Report.
1.4 Mercury
All mercury results should be considered quantitative with an acceptable
probability of false negatives.
2.0 Inorganic and Indicator Analvtes
2.1 Inorganic and Indicator Analvte OC Evaluation
The average spike recoveries of all of the inorganic and indicator analytes,
except for chloride, were within the accuracy DQOs. Accuracy DQOs have not been
established for the bromide, fluoride, nitrite nitrogen, and sulfide matrix spikes.
Average RPDs for all inorganic and indicator analytes were within Program
DQOs. The RPDs were not calculated if either one or both of the duplicate values
were less than the CRDL. Precision DQOs have not been established for bromide,
fluoride, nitrite nitrogen, and sulfide.
Requested analyses were performed on all samples for the inorganic and
indicator analytes.
No laboratory blank contamination was reported for any inorganic or indicator
analyte. TOX contamination was found in the field blank at a concentration of 6
ug/L. The TOX CRDL is 5 ug/L.
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23. Inorganic and Indicator Analvte Data
All results for cyanide, bromide, fluoride, sulfate, sulfide, total phenols, TOC,
and POX should be considered quantitative with an acceptable probability of false
negatives. The laboratory erroneously listed the instrument report date for the ion
chromatography analytes (bromide, chloride, fluoride, nitrate and nitrite nitrogen,
and sulfate as 3/18/87 rather than 3/24/87.
The spike recovery for chloride from sample MQ6035 was outside DQO with a
value of 114 percent. All chloride results should be considered semi-quantitative.
The holding times for the nitrate and nitrite nitrogen determinations ranged
from 3 to 5 days from receipt of the samples which is longer than the recommended
48 hour holding time for unpreserved samples. All nitrate and nitrite nitrogen
results should be considered semi-quantitative.
Calibration verification standards for POC were not analyzed. A POC spike
solution was run during the analytical batch but the "true" value of the spike was
not provided by the laboratory. EPA needs to supply the inorganic laboratory with
a POC calibration verification solution. Until then, the instrument calibration can
not be assessed. The POC results should be considered qualitative.
TOX contamination was found in the field blank (MQB029) at a concentration
of 6 ug/L. The TOX CRDL is 5 ug/L. Due to this contamination, all positive TOX
results five times the higher concentration or less should not be used, all TOX
results between five and ten times the higher of the concentrations should be
considered qualitative, and all results ten times the level of contamination or
greater, as well as all negative results, should be considered quantitative.
Therefore, TOX results for samples MQB028, 029, 030. 031, 032, 034, 035, 037, 038,
039, 040, 041, 044, 049, 050, and 053 should be considered quantitative and all other
TOX results should not be used. Results for TOX in field duplicate sample pair
MQB033/045 were in poor agreement. The comparative precision of field duplicate
results is not used in the usability evaluation of sample results. It is not possible
to determine the source of this imprecision. The poor precision may be reflective
of actual sample to sample variation rather than analytical precision.
3.0 Qrganics and Pesticides
3.1 Organic OC Evaluation
All matrix spike average recoveries were within established Program DQOs for
accuracy. Individual matrix spike recoveries which were outside the accuracy DQO
will be discussed in the appropriate Sections below.
All surrogate spike average recoveries, with the exception of the organo-
phospnorous herbicide surrogates which were neither required nor analyzed, were
within DQOs for accuracy. No accuracy DQO has been set for the 2,4-DB
chloroherbicide surrogate. Individual surrogate spike recoveries which were outside
the accuracy DQO will be discussed in the appropriate Sections below.
All reported matrix spike/matrix spike duplicate average RPDs. with the
exception of pcntachlorophcnol, were within Program DQOs for precision. Individual
matrix spike RPDs which were outside the precision DQO will be discussed in the
appropriate Sections below.
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All average surrogate spike RPDs were within DQOs for precision. No
surrogate standard was used or required for the organo-phosphorous herbicide
analysis. 2,4-DB was used as a chloroherbicide surrogate.
Requested analyses were performed on all samples submitted to the laboratory.
Laboratory (method) and sampling blank contamination was reported for
organics and is discussed in Reference 4 as well as the appropriate Sections below.
Detection limits for the organic fractions are summarized in Reference 4 as
well as the appropriate Sections below.
3.2 Volatile^
Acetone contamination was found in sampling blanks MQB029 and 050 at
concentrations of 2 and 11 ug/L. Additionally, acetone contamination was found in
laboratory (method) blanks MB-1, MB-3, MB-4, and MB-6 at concentrations of 1 to
5 ug/L. The acetone CRDL is 10 ug/L. The source of this contamination is
probably in the analytical laboratory. AH positive acetone results should not be
used due to this blank contamination.
Methylene chloride contamination was found in sampling blanks MQB029 and
050 at concentrations of 7 and 18 ug/L. Additionally, laboratory (method) blanks
MB-2 through MB-6 contained methylene chloride contamination. This common
laboratory contaminant was present at concentrations of 1 to 14 ug/L. The
methylene chloride CRDL is 5 ug/L. All positive methylene chloride results should
not be used due to this blank contamination.
The analytical laboratory continues to fail to use the contract specified
primary ion for the analysis of chloroethane on the Finnigan OWA instrument.
They claim that there is an interference with vinyl chloride and therefore they use
a secondary ion. The detection limit should not have been affected.
There was no quantitation report included for the additional (Appendix IX)
volatile compounds. The laboratory accidentally destroyed the magnetic tape with
this information. According to the laboratory, no Appendix IX compounds were
present in the sample.
Estimated method detection limits were CRDL for all samples. All positive
acetone and methylene chloride results should not be used due to sampling and
laboratory (method) blank contamination. The probability of false negative results
is acceptable. The volatile results should be considered quantitative.
3.3 Semivolatiles
The analytical laboratory exceeded the semivolatilc 40 day holding time
between extraction and analysis for eight of the semivolatile samples (MQB046, 048,
049, 050, 051, 052, 053, and 055). Holding times for these samples ranged from 4 to
30 days in excess of the permitted 40 day holding time between extraction and
analysis.
The acid matrix spike and matrix spike duplicate recoveries for 4-nitrophenol
were outside DQO.
The RPD for the matrix spike/matrix spike duplicate recoveries for N-
nitrosodi-n-propylaminc and pcntachlorophcnol were above DQO.
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The semivolatile laboratory (method) blanks contained a variety of compounds
including bis(2-ethylhexyl)phthalate (2 ug/L), 5-methyl-2-hexanone (10 ug/L), di-n-
butylphthalate (1 ug/L), and four unknowns (10 to 20 ug/L). The bis(2-
cthylhexyl)phthalate and di-n-butylphthalate CRDLs are 10 ug/L. Bis(2-
ethylhexyl)phthalate was also found in the trip blank at a concentration of 3 ug/L.
No positive bis(2-ethylhexyl)phthalate results should be used. Phenol was found in
the field blank at a concentration of 6 ug/L. No positive phenol or di-n-
butylphthalate results were reported in any other field samples.
An unknown semivolatile compound was detected but not confirmed or reported
as a tentatively identified compound (TIC) at the approximate retention time of 2-
hexanone in many of the samples. The laboratory claims that they are not required
to report compounds which elute before the first surrogate compound and that the
TIC probably represents an artifact from the extraction.
Due to a dilution factor of 2.0 for all samples, the estimated detection limits
for the semivolatiles were approximately twice the CRDL. The semivolatile data are
acceptable and the results should be considered semi-quantitative with exceptions.
Results for samples MQB049, 053 and 055, with the exception of the positive bis(2-
ethyihexyl)phthalate and phenol results, should be considered unreliable. All
positive bis(2-ethylhexyl)phthalate and phenol results, with the exception of the
phenol result for sample MQB029, should not be used due to laboratory and/or
sampling blank contamination.
3.4 Pesticides
The pesticide determinations were conducted on three different analytical
systems. On two of these systems the retention time of kepone falls within the
retention time window of endosulfan sulfate. Additionally, kepone carryover was
observed in one of these systems for pesticide standard EVALA.
The percent difference for the dibutylchlorendate retention time shift was
above DQO for several capillary column analyses (sample MQB037 and standard
AR1660). This was not judged to affect the data usability.
No pesticides were detected. The estimated method detection limits for all
pesticides analyses is the CRDL. The pesticides results should be considered
quantitative.
3.5 Herbicides
The herbicides for which the laboratory analyzed include only 2,4-D, 2,4,5-T,
2,4,5-TP, chlorobcnzilate, phorate, disulfoton, parathion, and famphur.
^ surrogates were included for the organo-phosphorous herbicides. 2,4-DB
was included as a surrogate in some of the chloroherbicide samples but was not
used with all of the samples. Surrogate recovery was poor for the first extraction.
A second extraction was performed and surrogate recoveries ranged from 85 to 120
percent.
The quality of the chlorohcrbicide chromatograms was not sufficient to allow
the tentative identification and confirmation of these compounds. Contamination
was observed in the method blanks and samples which was within the retention time
windows of the target analytcs. The electron capture detector settings were not
sufficiently sensitive.
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The chlorobenzilate recoveries from matrix spike and matrix spike duplicate
sample MQB047 were 8 and 22 percent, respectively, with an average RPD of 93
percent. No DQO limits have been established for chlorobenzilate.
No herbicides were detected. The organo-phosphorous herbicide results should
be considered qualitative due to the lack of surrogates. The estimated method
detection limits were the CRDL for the organo-phosphorous herbicides. The
chloroherbicide results should be considered unreliable due to blank contamination
and the absence of surrogate analyses.
3.6 Dioxins and Dibenzofurans
Dioxin and dibenzofuran spike recovery from the spiked samples ranged from
76 to 114 percent which is considered to be acceptable accuracy. No performance
evaluation standard was required or evaluated for dioxins and dibenzofurans.
Analytes were not detected in the laboratory duplicate samples so laboratory
precision could not be evaluated. Required dioxin/dibenzofuran analyses were
performed on all samples submitted to the laboratory. No dioxin or dibenzofuran
compounds were detected in the field samples and no contamination was found in
the laboratory (method) or field blanks.
Two of the spiked samples (MQ8035 and 043) were field samples. Neither of
these samples was analyzed prior to spiking. It is impossible to verify that low
levels of target analytes were not present in these samples. Sample MQB035 was
one-half of a field duplicate sample and no target analytes were found in its
duplicate. False negatives are a possibility in sample MQB043.
Due to a method modification supplied to the laboratory by the U.S. EPA
Sample Management Office, the column performance check solution was not analyzed
by the laboratory.
The percent valley between the internal standard (carbon-13 labeled 2,3,7,8-
TCDD) and the recovery standard (carbon-13 labeled 1,2,3,4-TCDD) was above DQO
for two standard analyses.
Samples MQB020, 033, 034, 042, 045D (duplicate), 051, 052, 056 and blank
CC*123597 did not meet the DQO requirement for resolution of the percent valley
being less than or equal to 25 percent.
Chlorinated organics which might be considered to indicate the possible
presence of chlorinated dioxins and dibenzof urans were not detected in the sampling
and analysis at this facility.
The dioxin and dibenzofuran results should be considered to be semi-
quantitative. The probability of false negative results is acceptable. Dioxin and
dibenzofuran detection limits should be considered to be the normal method
detection limits.
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III. Data Usability Summary
4.0 Graphite Furnace Metals. Total (Section 1.2)
Quantitative: all cadmium results; antimony, lead, and selenium results with
exceptions
Semi-quantitative: all thallium results; arsenic results with exceptions; antimony
results for samples MQB027, 029, 041, and 050; selenium results
for samples MQB027, 029, 032, 039, 041, 047, 050, and 056
Qualitative: arsenic results for samples MQB043 and 046; lead results for
samples MQB033, 034, 037. 045, 048, and 049
Unusable: arsenic results for sample MQB027; lead results for samples
MQB028 and 035
4.1 Graphite Furnace Metals. Dissolved (Section 1.2)
Quantitative: all antimony and thallium results; arsenic, cadmium, and
selenium results with exceptions
Semi-quantitative: all lead results; cadmium results for samples MQB027. 029, 037,
040, 041, 044, and 050
Qualitative: arsenic results for samples MQB027, 031, 035, and MQB053
Unusable: arsenic results for samples MQB032, 037, and 038
4.2 TCP Metals. Total (Section 1.3)
Quantitative: all barium, beryllium, calcium, cobalt, copper, magnesium,
manganese, nickel, potassium, silver, tin, vanadium, and zinc
results; chromium, iron, and sodium results with exceptions
Semi-quantitative: all aluminum results; iron results for sample MQB044; sodium
results for samples MQB028 and 047
Unusable: chromium results for samples MQB031, 033, 037, and 052
4.3 TCP Metals. Dissolved (Section 1.3)
Quantitative: all barium, beryllium, chromium, cobalt, nickel, potassium,
silver, vanadium, and zinc results; calcium results for samples
MQB029 and 050; iron results for samples MQB029, 033, 034,
040, 041, 045, 050, 052, and 056; magnesium results for samples
MQB029, 041, and 050; manganese results for samples MQB029,
041, 048, and 050; sodium results for samples MQB029, 033 045
050, and 052
Semi-quantitative: all tin results; aluminum results for samples MQB028, 034 035
042, 043, 052, and 055
Qualitative: sodium results for sample MQB047
Unusable: calcium, iron, magnesium, manganese, and sodium results with
exceptions
4.4 Mercury (Section 1.4)
Quantitative: all mercury results
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4.5 Inorganic and Indicator Analvfes (Section
Quantitative: all cyanide, bromide, fluoride, sulfate, sulfide, total phenols,
TOC, and POX results; TOX results for samples MQB028, 029,
030, 031, 032, 034, 035, 037, 038, 039, 040, 041, 044, 049, 050,
and 053
Semi-quantitative: all chloride and nitrate and nitrite nitrogen results
Qualitative: all POC results
Unusable: TOX results with exceptions
4.6 Organic* (Section 3.2 through 3.5)
Quantitative: volatile results with exceptions; all pesticides results
Semi-quantitative: semivolatile results with exceptions
Qualitative: all organo-phosphorous herbicide results
Unreliable: semivolatile results for samples MQB049, 053, and 055;
all chloroherbicide results
Unusable: all positive acetone and methylene chloride (volatiles) results;
all positive phenol (a semivolatile) results except for sample
MQB029; all positive bis(2-ethylhexyl)phthalate (a semivolatile)
results
•
4.7 Dioxins and Dibenzofurans (Section 3.6)
Semi-quantitative: all dioxin and dibenzofuran results
IV. References
1. Organic Analyses: EMSI
• 4765 Calle Quetzal
Camarillo, CA 93010
Inorganic and Indicator Analyses:
Centec Laboratories
P.O. Box 956
2160 Industrial Drive
Salem, VA 24153
(703) 387-3995
Dioxin/Dibenzofuran Analyses:
CompuChem Laboratories, Inc.
P.O. Box 12652
3308 Chapel Hill/Nelson Highway
Research Triangle Park, NC 27709
(919) 549-8263
2. Draft Assessment of the Usability of the Data Generated for Case I-2363HQ,
Site 48, ESL, Joliet, IL, 6/17/87, Prepared by Lockheed Engineering and
Management Services Company, Inc., for the US EPA Hazardous Waste Ground-
Water Task Force.
3. Draft Inorganic Data Usability Audit Report, for Case I-2363HQ, ESL, Joiict,
IL, Prepared by Laboratory Performance Monitoring Group, Lockheed
Engineering and Management Services Co., Las Vegas, Nevada, for US EPA,
EMSL/Las Vegas, 6/15/87.
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