October 1986 EPA-700/8-87-00 1
Hazardous Waste Ground-Water
Task Force
Evaluation of
Texas Ecologists, Inc.
Robstown, Texas
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
^
(*oi^
TEXAS WATER COMMISSION
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
r REGION VI
•> 12O1 ELM STREET
DALLAS, TEXAS 7527O
September 30,1986
UPDATE OF THE HAZARDOUS WASTE GROUND-WATER TASK FORCE
EVALUATION OF TEXAS ECOLOGIST, INC.,
ROBSTOWN, TEXAS FACILITY
The Hazardous Waste Ground-Water Task Force (Task Force) of the
Environmental Protection Agency in conjunction with the Texas Water
Commission (TWC) conducted an evaluation of the ground-water monitoring
program at the Texas Ecologists, Inc., Robstown, TX (TECO) hazardous
waste treatment storage, and disposal facility. The on-site field inspection
was conducted over a two-week period from February 4, 1986-to February
14, 1986. TECO is one of over 50 facilities that are to be evaluated by the
Task Force.
The purpose of the Task Force evaluations is to determine the adequacy
of ground-water monitoring programs at land dispo-sal facilities in regard
to applicable State and Federal ground-water monitoring requirements.
The evaluation focused on (1) determining if the facility was in compliance
with applicable regulatory requirements and policy, (2) determining if
hazardous constituents were present in the ground water beyond the known
plume of contamination, and (3) providing information to assist EPA in
determining if the facility meets the EPA requirements for facilities receiving
wastes from response actions conducted under the Federal Superfund program.
Prior to the Ground-Water Task Force evaluation the Texas Water Commission
had been monitoring TECO under a 1981 Compliance Agreement for the
corrective action of a known plume of contamination resulting from pre-RCRA
activities. ' •
-------
Permi t:
The TWC has prepared draft documents to address the ground-water
monitoring requirements of 40 CFR 264 and Subpart F. Those sections of
40 CFR which require compliance monitoring (40 CFR 264.£9) and corrective
action (40 CFR 264.100 and 101) are specified in the state rules (Texas
Administrative Code) for inclusion in a separate document entitled a
"Compliance Plan". The draft permit contains provisions for detection
monitoring (40 CFR 264.98) at the point of compliance along the west,
south, east and part of the north site perimeters. The proposed point of
compliance well system is located to allow for the proposed expansion of
operations on the east side of the county drainage ditch. The draft
compliance plan contains provisions for corrective action to be conducted
between the point of compliance and the down-gradient, facility-property
boundary, and also in the site interior, and provisions for compliance
monitoring to be performed along the north-east portion of the point of
compliance (Figure U-l). The TWC rules on permit issuance (31 TAG 305.401)
require that the draft compliance plan be subjected to the same public
notice, public hearing and final determination actions concurrently with
the draft RCRA permit. The two documents, thus jointly issued, will
constitute the RCRA permit.
Subsequent to the inspection, the draft permit and compliance plan
were completed by April, 1986, using revised applications submitted by
TECO on December 19, 1985. TECO submitted final revisions to the
applications on July 3, 1986, in response to discussion with TWC staff.
Substantial changes in the applications included:
1) Results of geotechnical evaluation for the undeveloped portion
of the site west of the county drainage ditch. TWC staff
initially considered this area to be inadequately characterized
for construciton of addition landfill trenches.
II
-------
Point of Compliance subject to CP-50052-OO1
•»_«_ Area of Corrective Action subject to CP-50O52-O01
poc 6 I poc 8 poc 9 poc 10
Figure U-l Monitoring well system proposed within TECO Permit. TECO Waste Management Area Boundary and
Point of Compliance follows line of poc prefixed wells. Supplemental wells system is prefixed
by ss. Upgradient monitoring welXs are prefixed by ug.
-------
2) The ground-water treatment system was transferred from the
compliance plan application, where it was considered a non-
hazardous component, to the landfill permit application for
inclusion as hazardous waste storage and treatment components.
The influent from the recovery trench was found to contain
arsenic in excess of EP Toxicity levels ( >5 mg/1); hence, the
80,000 gallon equalization tank was receiving hazardous waste.
All tankage downstream in the treatment system to the arsenic
removal process are now considered to be hazardous units.
3) The compliance plan application contained the results of a computer
simulation of simultaneous recovery of contaminated ground water
and recharge of treated ground water in the north-east portion of
the site. Several different combinations of pumpage and
recharge rates were evaluated. The study predicted that 11.6
gallons per minute (gpm) pumped from the recovery system and
5 gpm recharged through a series of 8 wells bracketing the recovery
trench would prevent spreading of the plume of contamination.
The draft compliance plan and draft permit were modified to include
the July 3, 1986 revisions to the applications and comments by TECO to the
extent considered acceptable to the TWC staff (Item 1 rejected; Items
2 and 3 accepted). The final drafts were transmitted to the Chief Clerk,
Texas Water Commission, on August 1, 1986. TECO was provided with
instructions to publish a notice of opportunity for public hearing on their
applications in early September 1986. The start of the public hearing
has been set to begin at 9:00 AM on October 28, 1986 at the State University
of Corpus Christi, Corpus Christi, Texas. A hearings examiner will
listen to testimony from all parties named to the hearing, make findings
of fact and present a recommendation for issuance or denial to the three-
member Texas Water Commission. The Commissioners have final issuing
authority for the state-delegated permitting functions of RCRA. The U.S.
EPA will then complete actions under federal authority for a final RCRA
permit.
Ill
-------
Based on findings presented in the Ground-Water Task Force Report
the EPA Region VI RCRA Permits staff is recommending several revisions
to the draft permit. These changes will be presented as comments during
the public notice period. A summary of these comments are listed below:
1. Trench 17/18 (AKA Old Mixing Basin) was identified as a source of
contamination in a 1982 ground-water assessment study and included at that
time within the TOC plume of contamination boundary. Presently W-17 is
the sole recovery well in the southern extremities of the plume of contam-
ination. Based on GWTF sampling data a more vigorous recovery program is
warranted in this area. Permit conditions are being developed for the
Permit/Compliance Plan that would require an assessment of the current
plume of contamination based on Appendix VIII constituents. This includes
a plan for expanding the current recovery system in this area and developing
alternative corrective action measures (ie., a new recovery trench drain
in this area and/or increased number of recovery wells).
2. A study conducted by TECO on the depth of Pre-RCRA trenches 1-14
found several trenches to have penetrated the native clay which constituted
the sole liner system used for these trenches. Further, sampling conducted
by the Task Force found wells adjacent and among these units to be contam-
inated with several organic and inorganic compounds. It will be requested
by the Regional permitting staff that an assessment of this contamination
be added to the Permit/Compliance Plan. The assessment at a minimum
will address the source of contamination, extent, and recommendations for
corrective action.
3. Monitoring wells W-6 and 001 showed elevated concentrations of
organic and inorganic compounds. Because these wells are west and
upgradient of the currently identified TOC plume of contamination the
source of the contaminants detected needs to be addressed. TWC will
instruct TECO to submit an assessment plan for this area. EPA Regional
permitting staff will also request that the assessment be included as
part of the Permit/Compliance Plan.
IV
-------
4. Monitoring wells installed prior to 1980 (approximately half of the
total number of wells on-site) lacked detailed well construction and/or
lithologic logs. Though records of well construction logs improved after
1980, many of the monitoring wells installed during interim status also
lack ..etailed information. Depending on plan future usage these wells
will either be replaced or plugged. All future monitoring wells installed
will meet TEGD standards, as specified in the permit. TECO will be
notified of this through the permitting process.
5. The Task Force is recommending that TECO begin using either bailers
constructed of inert materials or gas displacment pumps for sampling.
6. The draft permit requires future trenches to not exceed a depth which
is two-feet a*bove the mean high water table. Regional EPA permitting
staff are suggesting a minimum of 5-feet above mean high water table
elevations.
Waste Units:
TECO representatives met with the Region VI Permitting staff on January
21,1985 to discuss the construction design of a landfill unit (Trench 36)
and were appraised of the requirements to meet the specifications set out
in the minimum technologies requirements (MTR), Section 3004 (o) of RCRA,
42 U.S.C. §6924 (o).
TECO submitted the final Trench 36 design plans on February 20,
1985, which showed that there was no leachate collection system between
the liners which extend up the sidewalls. TECO advised EPA on July
31,1985, and November 8, 1985, that it disposed hazardous waste in Trench
36 which failed to provide for a leachate collection system cited above.
EPA, therefore, found that TECO violated Section 3015(b)(l) of RCRA,
42 U.S.C. §6936(b)(l"), by disposing of hazardous waste after May 8, 1985,
-------
in a landfill unit which failed to meet MTR. A Complaint, Compliance
Order, and Notice of Opportunity for Hearing were issued to TECO on January
10,1986 for the above violation. The Order is currently being negotiated
between legal counsels of TECO and EPA.
The Regional EPA office is requesting that TWC add a disclaimer into
the permit which describes that upon resolution of the agreement between
EPA and TECO, the permit will be modified as appropriate.
Operations:
* During the inspection a method of stabilizing ground-water treatment
plant sludge was under study. The draft permit authorizes the use of an
enlarged capacity cement mixer than what was originally proposed for the
sludge solidification. The use of a filter press as was once considered by
TECO, was never formally submitted to TWC and therefore was not placed in
the draft permit.
* The TECO septic system vertical drain field is being re-eva*luated by
TWC to determine the impact on the ground water.
Monitoring and Site Characterization:
* Sizable sand lenses have been identified downgradient of the plume
of contamination between wells P-12 and P-13. TWC, as part of the GWTF,
will require TECO to conduct aditional monitoring in this area and to
determine if these sand lenses could form a vertical migration pathway.
* TECO has installed eight new piezometers in the western portion of
the facility in an attempt to better characterize the flow regimes in
this area. These new wells were installed during Spring 1986. Figure
U-2
VI
-------
-='; l
Booac a»
O
O
in
l
e.
u
j_i
o
o
•i—i
J3
^
W
CJ
c
E
O
u
u-i
O
Jj
c
o
o
I
CN
L.-I
o
o
u
0
JJ
4J
u
o
3
tn
c
O
JJ
o
i-l
o
u
14-1
0
c
a
-------
* Due to the varying levels of contamination indicated by the Task
Force sampling data, TWC, as part of the GWTF, will require TECO to initiate
compliance plan monitoring with expanded list of parameters immediately.
This will be included as part of the assessment to TECO.
* TWC will require TECO to conduct an assessment of the low levels
of contamination detected in monitoring wells OB-2 and E-48 located north
of the boundaries of the plume of contamination. This will be done as
part of the earlier described assessment.
VII
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUND-WATER TASK FORCE
GROUND-WATER MONITORING EVALUATION
TEXAS ECOLOGISTS, INC., ROBSTOWN, TEXAS
SEPTEMBER 1986
DEBORAH A. VAUGHN-WRIGHT
RCRA HYDROLOGIST
US EPA REGION VI, DALLAS, TEXAS
-------
CONTENTS
EXECUTIVE SUMMARY Page
Introduction 2
Summary of Findings and Conclusions 6
TECHNICAL REPORT
Investigation Methods 14
Records/Documents 14
Facility Inspection 15
Laboratory Evaluation 15
Ground-water and Leachate Sampling and Analysis 15
Background 21
' History of Facility 21
Adjacent. Land Use 24
Waste Management Units 27
Non-Interim Status Regulated Waste Management Units 31
Interim Status Regulated Waste Managment Units 33
Post November 8, 1985 Waste Management Units 42
Facility Operations 43
Waste Characterization 43
Waste Compatibility 46
Disposal Operations 46
Waste Location 48
Sump/Leachate Monitoring 48
Septic System ; 48
Inspections 49
Future Operations 50
Site Hydrogeology 51
Local Physiography 51
Local Geology 53
Local Hydrology 55
Ground-Water Monitoring Program 58
Regulatory Requirements 58
Pre-Compl iance Agreement Monitoring 58
Compliance Agreement Monitoring 64
Special Studies 72
Ground-Water Recovery System 78
Trench Drain 81
Recovery System 81
Recharge System 85
-------
Paqe
TECO Sample Collection and Handling Procedures 88
Sampl ing 88
Documentaion 91
TECO Sample Analysis and Data Quality Evaluation 92
Laboratory Evaluations 94
Ground-Water Monitoring Program Proposed for Final Permit.. 103
Evaluation of Ground-Water Task Force Sample Data 106
References 110
FIGURES
Number Description
1 TECO Location Map 23
2 Adjacent Landowners "25
3 January 1975, TECO Site Plan 32
4 Schematic Flow Chart of Waste Acceptance
Procedures 44
5 Local Geologic Map 52
6 Plan and Cross-Sectional Views of Trenches 1,2,
3,4,5,7,8,9,10, and 12 75
7 Plan and Cross-Sectional Views of Trenches 1,2,
3,4,5,7,8,9,10, Ind 12 76
8 Plan and Cross-Sectional views of Trenches 6, 13,
and 14 77
9 Cross Section of Trench Drain 82
10 Eductor System Detail 83
11 Typical Eductor 84
12 Recharge Wells (Pits) 86
13 Recharge Well Cross Section 87
14 Extent of Contamination 109
-------
TABLES
Number Description Page
1 Task Force Samp'e Collection and Well/'.eachate
Location Description 18
2 Preferred Order of Sample Collection, Bottle Type
and Preservative 20
3 Wells within a two mile radius 26
4 Solid Waste Management Units at TECO 28
5 .- Comparative Evaluation of the Minimum Technology
Requirements (MTR) and TECO Trench 36 40
6 State and Federal Counterparts Interim Status
Regul at i ons 59
7 Monitoring wells, Eductor Wells, Recharge Wells,
and Borings at TECO 68
D-l Sample Parameters and Testing Methods D-3
D-2 Field Measurements conducted for GWTF Samples.... D-4
D-3 Summary of Concentrations for Hazardous Substances
List of Compounds, Indicator Parameters and Metals "
Found in Ground-Water Samples at the Texas Ecologists,
Inc. Facility, Robstown, TX D-5
ATTACHMENTS
A 1972 Permit A-l
B Compliance Agreement B-l
C Facility Plan showing present and future
disposal areas, and current monitoring
system C-l
D Analytical Techniques and Results for
Task Force Samples D-l
E Examples of Montly Ground-Water
Recovery Reports Submitted by TECO to
TWC E-l
-------
EXECUTIVE SUMMARY
-------
INTRODUCTION
Concerns have recently been raised by Congress and the public about
whether commercial hazardous waste treatment, storage and disposal
facilities (TSDF's) are complying with the ground-wacer monitoring requirements
promulgated under the Resource Conservation and Recovery Act (RCRA).* The
ability of existing or proposed ground-water monitoring systems to detect
contaminant releases from waste management units has been questioned.
The Administrator of the Environmental Protection Agency (EPA)
established a Hazardous Waste Grpund-water Task Force (Task Force) to
evaluate the level of compliance with ground-water monitoring requirements
at commercial off-site TSD facilities and to address the cause of any
noncompl iance. The Task Force for this facility was comprised of personnel
from the EPA Office of Solid Waste and Emergency Response (OSWER), Regional
office, and the State regulatory agency.
Currently, 62 TSD facilities are scheduled for compliance inspections
of their ground-water monitoring systems. NEIC coordinated and led
the first inspection in each of the nine EPA regions having commercial
TSD facilities. The Texas Ecologists, Inc. (TECO) facility at Robstown,
Texas is the third facility inspected in Region VI and the subject of
this project report. It was a regional-lead inspection.
Regulations promulgated under RCRA address hazardous waste management
facility operations, including ground-water monitoring, to ensure that
hazardous waste constituents are not released to the environment.
-------
The principal objective of the inspection at TECO was to determine
compliance with the requirements of 40 CFR Parts 264, 265, Subpart F
Ground-water Monitoring and Hazardous and Solid Waste Amendments (HSWA)
of 1984. The TECO facility may, in the future, receive waste from
Superfund sites where response actions are being conducted under the
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA-P.L. 96510). Specific land disposal units for Superfund wastes
must be in compliance with the Part 265 ground-water monitoring requirements
**. Finally, the ground-water monitoring described in the RCRA Part B
permit application for the TECO facility was evaluated for compliance
with Part 270.14(c).
Specific objectives of the investigation were to determine if:
1. The ground-water monitoring system can immediately detect any sta-
tistically significant amounts of hazardous waste or hazardous
waste constituents that migrate from the waste management area to
the uppermost aquifer underlying the facility.
2. Designated RCRA monitoring wells are properly located and constructed
3. TECO is following an adequate ground-water sampling and analysis
plan.
4. Required analyses have been conducted on samples from the designated
alternate detection well system.
5. The ground-water recovery system is adequate, and capable of
containing the contamination plume.
6. Recordkeeping and reporting procedures for ground-water monitoring
are adequate.
7. Characterization of the vertical and horizontal strata under
of the site is adequate.
8. Analytical Laboratories utilized by the facility are adequate
for conducting required ground-water analyses.
** EPA policy, stated in May 6,1985 memorandum from Jack McGraw on
"Procedures for Planning and Implementing Off-site Response", requires
that TSDFs receiving CERCLA waste be in compliance with applicable
RCRA ground-water monitoring requirements.
-------
The objectives were accomplished by conducting a Reconnaissance
Inspection and a Full Field Inspection. The Preliminary Reconnaissance
Inspection was conducted January 23, 1986 at the Texas Ecologists, Inc.,
Robstown, Texas facility. This inspection gave the Task Force the opportunity
to familiarize themselves with the facility, meet representatives of the
facility and to inform these representatives of the types of samples to be
collected, and what information/records they would need to have available
for the full field inspection.
Examples of the types of information requested of TECO for the Task
Force inspection included:
1. Past activities and uses, including identification of prior
releases of hazardous materials, at units that have received or
are receiving wastes.
2. Types and volumes of waste received and disposal locations.
3. Man-made barriers to the release of hazardous waste constituents.
4. Site and local geology including cross-sections, drill logs, and
poteritiometric maps.
5. Ground-water hydrology including flow directions, rates, pathways
(natural and man-made) and hydraulic relationships between aquifers.
6. Monitoring well locations and construction.
7. Sampling plan, chemical parameters, and chain-of-
custody control, collection procedures (including handling) and
equipment.
8. Analysis plan, procedures, data management, and QA/QC
controls of the laboratory (ies).
9. All the existing water quality data from ground-water monitoring.
10. Extent of ground-water contamination resulting from previous
operations at the site.
11. Current and planned corrective actions.
The full Ground-water Task Force Inspection at the Texas Ecologists,
Inc., (TECO) facility began Tuesday, February 4, 1986 and ended Friday,
February 14, 1986.
-------
Inspection Participants
EPA Headquarters: Roy Murphy (Safety Officer)
Joan Middleton
EPA Region VI:
Deborah A. Vaughn-Wright (Regional Team Leader)
Julie Wanslow (Document Control Officer)
David Wineman (Environmental Services Division)
EPA Contractor:
Versan Inc:
Darcy J. Higgins (Monitoring Specialist Leader)
Mark McElroy
Alicia Fleitas
John Hatcher
Texas Ecologists, Inc.:
William Jones (Facility Manager)
Patrick Seager (Manager - Regulatory Compliance)
Charles Mansfield (Chemical Operations Officer) .
Randall Underwood (Professional Engineer)
Howard A. "Tony" Woods (Chemical Safety Officer)
Gilbert Avalos (Laboratory Technician)
Ernest Gazda (Scale House Clerk)
Rick Retterer (Environmental Well Technician)
Texas Water Commission:
Paul Lewi s
Eric Adidas
John Dalton
Mary Ambrose
Acknowlegdements are given to Paul Lewis, Geologist, with the Texas
Water Commission in the preparation of this report.
-------
SUMMARY OF FINDINGS AND CONCLUSIONS
The findings and conclusions presented in this report reflect conditions
existing at the facility in February 1986. Actions taken by the state, EPA
Region VI and TECO subsequent to February are summarized in the accompanying
update.
Texas Ecologists, Inc. Robstown, TX facility is not a typical Task
Force site in that corrective action was initiated prior to 1980 and their
RCRA permit is already in final draft form. Task Force personnel investigated
the ground-water programs from prior to November 1980 to the present due to
the early initiation of their corrective action-; The TECO program(s)
are a composite of detection, assessment monitoring, and corrective action
being conducted simultaneously. The Task Force therefore began its evaluation
with the incontestable knowledge that the ground water beneath the site was
contaminated.
Findings and conclusions, specific to selected ground-water program
requirements and facility operations are summarized below.
Waste Management Units:
Early management units (trenches 1 through 14) were constructed in
native clay soils with little or no compacted clay liner. The first fourteen
trenches have the potential for being a continual source of contamination,
as the base of at least some of these trenches penetrated the native clay.
Trench 17/18, or the old mixing basin, was identified as a source of
contamination during a ground-water assessment study of contamination found in
monitoring well W-17 by TECO in 1982. The remedial action chosen was to cap
the trench and to leave the contaminated soils and wastes in place. Trench
17/18 is still a source of contamination as is evident from continual
elevated levels of contamination found in wells monitoring this area.
-------
Field quality assurance records for the percent of theoretical maximum
density conducted during construction of many trenches were reviewed. It
was found that even though several samples failed there was no evidence of
retesting or correction of the problem. This was not common, but it does
raise the question as to trench integrity in some trenches.
Site Characterization:
TECO has conducted several studies in an attempt to characterize the
hydrogeology of the site. First as required under the Compliance Agreement,
then second as part of the Part B Permit Application. Several areas were
found which still require further detail.
A. Monitoring well recharge rates experienced during the inspection
were actually very different from those reported. There are
several possible explanations:
1*. The data presented "is based on textbook values for the type
sediments and not actual field calculations;
2. The well hydraulics have changed due to siltation or failure
of the casing or gravel packs since initial calculations; and
3. Improper tests or test methods were used. Permeabilities
presented were based on a bailing test. Quality of a bailing
test is determined by the computed aquifer thickness. Because
many TECO wells have a sand pack that exceeds their screen length
and the aquifer thickness, this could affect bailing test results.
Therefore the bailing tests conducted in the past by TECO could
be inaccurate.
B. Ground-water flow diagrams presented in the Compliance Plan of December
1985 are not supportable. There are not enough data points
to support patterns of flow present in the western and southern areas.
-------
C. Sizable sand lenses have been identified in the Second Clay
downgradient of the plume between wells P-13 and P-12. A
sand lens in this area could form a vertical migration pathway
to the Second Sand if not monitored adequately. Additional
monitoring should be conducted in this zone.
Monitoring Well Construction:
Wells installed prior to 1980 often lack lithologic logs and/or well
construction diagrams. Records that are availabe show wells with screens
and gravel packs of unacceptable lengths, drilling fluids being used,, and
PVC pipe jointed with glue. Further, during the inspection several of
these wells indicated substantial siltation which is indicative of an
inadequate gravel pack. Generally all wells installed to prior 1980 do not
meet current EPA standards for monitoring well construction. Those wells
that are to be used as part of the monitoring system for the RCRA Permit
which have the above mentioned problems need to be replaced.
• V
Monitoring wells installed after 1980 and as part of the 1981 Compliance
Agreement had more detailed lithologic and well construction details recorded.
The wells still contain much of the same problems however, in the areas of
excessive screen and sand pack lengths. Construction materials used did improve
with time. As with the pre-1980 wells these wells should also be closely
re-evaluated and rep.laced if inadequately constructed prior to integration
into the RCRA permit monitoring system.
Ground-Water Monitoring Systems:
The ground-water monitoring program at TECO is considered an alternative
monitoring system. The system consists of compliance point wells for the
plume of contamination, background wells, wells designated as being outside
the area of contamination, wells considered inside the area of contamina-
tion, and point of compliance wells for the facility waste management area.
-------
Ninety-three wells are monitored on a monthly basis for pH, chemical oxygen
demand, total organic carbon, specific conductivity, water level odor and
appearance. The location and parameters selected for these wells are based
on the TECO designated boundaries of the plume of contamination and the
requirements for monitoring specified in the 1981 Compliance Agreement.
TECO has complied with the 1981 Compliance Agreement and has installed and
monitored the wells as specified.
The Task Force feels that even though TECO was granted alternative
monitoring program status and was compliant with the 1981 Compliance Agreement
an assessment/detection monitoring program for the waste management areas
seperate of the compliance monitoring conducted for the identified plume of
contamination must be initiated based on investigation results. Essentially,
due to two upgradient areas (southeastern and western portion of the facility)
units 35, 36, 37, and 28 are not sufficiently monitored. A release from
these units would not be immediately detected.
»
Sample Collection and Handling: '
TECO has dedicated PVC bailers to sample the monitoring wells. It was
found that these bailers were modified by the facility and equipped with a
PVC filter to prevent silt from clogging the bottom valve. This attachment
was often glued onto the bailer then secured with a metal bolts.
Equipment of this type is not adequate for detection or assessment
sampling purposes. PVC should be used only for purging. The Task Force
recommends the use of bailers constructed of inert materials with bottom
release valves or gas displacement pumps so as to prevent agitation of the
sample which could in turn cause volatization of the sample. Sampling
handling, preservation, documentation, and shipping methods observed
followed EPA standards.
-------
Laboratory and Sample Data Quality Evaluation:
TECO utilizes three laboratories on a regular basis: (1) on-site laboratory,
(2) U.S. Ecology Central Conorate Laboratory, and (3) Jordon Laboratory. There
are other laboratories usec, on a special contract basis. The Task Force
evaluated the U.S. Ecology Central Corporate Lab. because they analyze the
monthly water samples and Radian Laboratories at Austin because they analyzed
the splits collected by TECO from the Task Force.
The U.S. Ecology Central Corporate Laboratory was found to have several
minor deficiencies relating to holding times (pH, and TDS) and methodologies
(TDS.COD, and TOC) However, in general, the laboratory appears to be provid-
ing acceptable quality data.
The implementation of the U.S.Ecology Central Corporate Laboratory
Ground-Water Analysis Plan would initiate a quality assurance program that
would in turn strengthen the quality of data. The ground-water analysis
plan should be implemented.
Radian Corporation in Austin, TX was also evaluated. The Task Force
found that Radian met the requirements of their contract with Texas Ecologists
and the data producad under this contract is of acceptable quality.
The quality control specified in the contract should have been more explicit.
Ground-Water Recovery System:
The ground-water recovery system at TECO consists of three areas of
operation, 1) the trench drain, 2) recharge pits/wells, and 3) recovery wells.
The system is designed to curtail a plume of contamination based on TOC
values that formed as a result of releases from closed surface impoundments
and the capped mixing basin.
10
-------
A review of the recovery system found that it should be able to curtail
further movement of the TOC plume of contamination. Potentiometric maps of
the area over the years have shown that a cone of depression is forming and
that wells lying outside of the plume have had a decrease in TOC values.
Questions still remains on whether the system will achieve the required
results within a time frame to be detailed in the permit and if the current
system is adequate in addressing the Appendix VIII constituents found
within the boundaries of the current plume of contamination and elsewhere
on the TECO facility during the Task Force sampling.
Task Force Sample Data
Sample data collected during the February 1986 Task Force inspection
confirms the presence of extensive contamination in the area of the closed
surface impoundments and capped old mixing basin. Contamination detected
in monitoring well W-21, wh.ich monitors both trench U/18 (old mixing
basin) area and a portion of the original 14 trenches, was quite extensive.
Sixteen organic compounds of substantial levels, six inorganic constituents
above Primary Drinking Water Standards, and elevated indicator parameters
were detected. This would indicate a need for expanding the current ground-
water recovery system in this area.
Various levels of contamination were found in areas of the TECO facility
which had not previously been addressed by the 1981 Compliance Aggreement.
This newly detected contamination was found in three areas:
1. Monitoring wells W-6 and 001 which are west and upgradient of
the plume of contamination, yet downgradient of the western
trenches, contained elevated concentrations of organic and
inorganic compounds.
2. Six wells adjacent to the first fourteen trenches were sampled
and all contained various levels of contamination indicating
a release(s) stemming from these trenches.
11
-------
3. Low levels of metals and several indicator parameters were
detected north and downgradient of the plume of contamination.
The presence of this contamination indicates the need of assessment
north of the plume and further monitoring downgradient.
12
-------
TECHNICAL REPORT
-------
Investigation Methods
The Task Force investigation of the Texas Ecologist, Inc. facility
consisted of:
0 Reviewing and evaluating records and documents from EPA
Region VI, Texas Water Commission, and Texas Ecologists,
Inc.
0 Conducting a reconnaissance inspection January 23, 1986
and a full-facility inspection February 4 through
14, 1986.
0 -Evaluating on-site and off-site analytical laboratories.
0 Sampling and analyzing data from selected ground-water
monitoring wells and leachate collection sumps.
Records/Documents Review:
Records and documents from EPA Region VI and TWC offices, compiled
by an EPA contractor, were reviewed prior to and during the on-site inspec-
tion. Additional TWC records were copied and reviewed by Task Force per-
sonnel concurrently with the reconnaissance inspection. On-site facility
records were reviewed to verify information currently in Government f,iles
and to supplement Government information where necessary. Selected documents
requiring in-depth evaluation were requested from the facility by the Task
Force during the inspection. These documents were provided by TECO upon
request. Records were reviewed to obtain information on operations,
construction details of waste management units and the ground-water
monitoring program.
Specific documents and records that were reviewed included the
ground-water sampling and analysis plan(s), the RCRA Part B Application,
analytical results from past ground-water sampling, monitoring well
construction data and logs, site geologic reports, site operational
plans, facility permits, designs of waste management units, and position
descriptions and qualifications of selected personnel and operating
records showing the general types, quantities and locations of wastes
disposed at the facility.
14
-------
Task Force Inspection:
The inspection conducted in February 1986 included identifying waste
management unit^ (past and present), waste management operations, pollution
control practices, surface drainage routes, and verifying the location of
ground-water monitoring wells and leachate collection sumps.
Company representatives were interviewed to identify records and
documents of interest, discuss the contents of the documents, and
explain (1) facility operations (past and present), (2) site hydrogeology,
(3) the ground-water monitoring system, (4) the ground-water sampling
and analysis plan, and (5) laboratory procedures for obtaining data on
ground-water quality.
Laboratory Evaluations:
The on-site and off-site laboratory facilities handling ground-water
samples were evaluated regarding their respective responsibilities under
the TECO ground-water sampling and analysis plan. Analytical equipment
and methods, quality assurance procedures and records were examined for
adequacy. Laboratory records were inspected for completeness, accuracy
and compliance with State and Federal requirements. The ability of each
laboratory to produce quality data for the required analysis was also
evaluated.
Ground-Water and Leachate Sampling and Analysis:
During the inspection Task Force personnel collectd samples for
analysis from 22 ground-water-monitoring wells and 3 leachate collection
sumps (Table 1) to determine if the ground-water contains hazardous waste
constituents and to verify previous sampling data.
15
-------
Sampling locations were selected based on past monitoring records, well
logs, and hydrogeologic reports. The leachate sumps were selected based
on proximity to units of interest and wells being sampled.
All samples were collected by EPA contractor personnel with splits of
selected samples being provided to the facility and State. The wells
were sampled with 2-inch teflon bailers with teflon coated stainless
steel cable. Three wells required the use of submersible pumps for
purging, both TECO and EPA owned pumps were used. Samples were collected
from the wells using the following protocol:
1) EPA contractor personnel monitored open well head for
chemical vapors and radiation.
2) EPA contractors, accompanied by TECO personnel, determined
depth to ground water and total depth using an interface
probe.
3) EPA contractor personnel calculated height of water column.
4) EPA contractor personnel calculated three casing volumes.
5) EPA contractor personnel purged the calculated three casing
volumes. Rapidly recharging wells were purged for three
full casing volumes, whereas slower wells were purged to
dryness once. Purge water and excess sample water we're
placed in drums, then disposed in pond 26.
6) Samples were collected with a bottom filling teflon bailer
supplied by the EPA contractors.
7) A sample aliquot was collected and field
measurements (water temperature, pH, specific conductance)
taken.
8) EPA contractor using alternating method filled sample containers
in the order shown in Table 2.
9} Samples were then placed on ice in an insulated container
and taken to the EPA staging area.
When sampling was completed at each well, the samples were taken to
the EPA staging area. Turbidity measurements were taken and one of the
two sample aliqoats was filtered for metals analysis. Metals, TOC,
phenols, cyanide, nitrate and ammonia samples were preserved, (Table 2).
16
-------
The monitoring well samples were packaged and shipped to two EPA
contract laboratories as environmental samples in accordance with Department
of Transportation (DOT) regulation (40 CFR Parts 171-177).
Leachate samples were all collected and shipped the same day to
prevent possble cross contamination through handling with other well samples
and shipping. These samples were crisidered medium hazard concentration
and were shipped according to DOT regulations. All EPA contractor
personnel wore full-face respirators and protective clothing. TECO personnel
assisting in leachate sample collection wore half-face respirators and
tyvecks®. Plastic sheeting was laid around each sampling point in order to
prevent area contamination in case of spillage. Spillage at Sump 33
did occur when the connecting hose from the sump pump to the sampling
valve became disconnected due to high pressure build up in the lines.
The liquid and contaminated soil were placed in a drum for disposal and
the National Spill Response Center was notified.
Three field blanks for each analytical parameter group (e.g.,
vo.latiles, organics, metals) were prepared near monitoring wells
p-8, 001, and W-21 so as to represent field conditions. One
equipment blank was prepared by running distilled, deionized water
through the apparatus used to filter metals. One set of trip blanks
for each parameter group was also prepared. The blanks were submitted
to the EPA lab as samples with no distinguishing labeling or markings.
Samples were analyzed by EPA contractor laboratories (Centec, Salem,
WA for inorganics; Compu/Chem, Research Triangle Park, N.C. for organics)
for the parameters shown in Table 2. An analysis of the sample results
will follow.
Registered trademark of E.I. DuPont de Nemours and Co.
17
-------
Table 1
TASK FORCE SAMPLE COLLECTION AND WELL/LEACHATE LOCATION DESCRIPTION
Well
P8
P7
Wl
P2
P4
P5
W16
W15
W21
1
W6
P9
E3
E48
001
P12A
P13
E36
Samp!
Date
2/6
.
2/6
2/6
2/7
2/7
2/7
2/8
2/8
2/8
2/8
2/10
2/10
2/10
2/11
2/10
2/11
2/11
2/11
2/12
ing
Time
1516- *
1730-2000
1640-1755
1303- *
1215-1415
1707-
0945
1100-1200
1150-1245
1630-1735
1330-1500
1430-1530
1125-1221
1353-1517
1630-
0858
1540-1620
1310-1425
1515-1615
Remarks
Slight chemical odor, slightly
turbid; EPA bailer lost in well
Very turbid - difficult to filter
Clear to cloudy water; no apron
present at wellhead
Outer casing does not extend below
apron, inner casing broken
Turbid; due to lack of volume
sampling took two days;VOAs thru
Dioxins sampled 2/7; metals thru
SO^/CL" sampled 2/8; loose casing
Rusty screws in dedicated bailer
Sampled before full recharge
Yellowish brown-green color;
strong chemical odor; 3ppm on OVA
reading of water sample
QA/QC Duplicate
Dark brown-black color; strong
sewage odor.
No apron at wellhead
Due to lack of volume collected
VOAs thru Pesticides 2/10,
collected remainder 2/11
Slightly silty
Facility bailer used for purging
only, left in well during recovery
Black to clear color as well was
sampled; slight odor
Location/Description
East of Trench 6
Designated upgradient well;
south of facility
Upgradient of old trench area;East of
Trench 13
So. of Trench 36 and 37; East of drain-
age canal
Downgradient; South of Trench 28
Downgradient; south of Trench 29
Upgradient; west of active trenches
Upgradient; west of active trenches
Southwest of Trench 8
West of Plume
Crossgradient of Trench 1 and 2
NE of Trench 21; inside '85 plume
boundary
NE of '85 plume boundary
Downgradient of Trench 36
South edge of North ground-water mound
North of "85 plume boundary
Deep upgradient well
* Ending times were not recorded
18
-------
Table 1 (continued)
Well
Sampling
Date
Time
Remarks
Location/Description
E41
El 4
OB 2
P6
W2
LEACHATE WELLS
S33
2/12 1415-1518
2/12 0910-1018
2/12 0933-1120
S16
SI
2/13
2/13
2/14
2/14
2/14
1030-1145
1115-1220
1120-1219
1236-1304
0852-1026
Purged with 2 5/8 inch submersible
pump; no apron
Purged with 4 inch Jacuzzi sub-
mersible pump
Used facility bailer to purge,
bailer left in well during recov-
ery period; apron cracked
Slightly silty; animal burrow
under apron .
No apron;
Moderately clear then turned green
to black, 400 ml beakers used as
intermediate containers for VOAs;
2-1 liter beaker used for other
parameters
Color brown; OVA 60-80 ppm in
casing, 14-18 ppm in sample; 2-1
liter beaker used as intermediate
container
Oily smell, viscose dark oily
brown
North of '85 plume boundary
East of Trench 40
Near northern facility boundary
Southwest of Trench 15
East end of Trench 33
Trench 16
NW end of Trench 1
-------
Table 2
PREFERRED ORDER OF SAMPLE COLECTION,
BOTTLE TYPE AND PRESERVATIVE LIST
Parameter
Bottle
Preservative
1. Volatile Organic Analysis (VOA)
Purge and Trap
Direct Inject
2. Purgable Organic Carbons (POC)
3. Purgable Organic Halogens (POX)
4. Extractable Organics
5. Pesticide/Herbicide
6. Dibenzofuran/Dioxin
7. Total Metals
8. Dissloved Metals
9. Total Organic Carbon (TOC)
10. Total Organic Halogens (TOX)
11. Phenols
12. Cyanide
13. Sulfate/Chloride
14. Nitrate/Ammonia
2 - 60-ml VOA vials
2 - 60-ml VOA vials
1 - 60-ml VOA vial
1 - 60-ml VOA vial
4 - 1-qt. amber glass
1- 1-qt. amber glass
1-qt. amber glass
1-qt. plastic
1-qt. plastic
4-oz. glass
1-qt. amber glass
1-qt.amber glass
1-qt. plastic
1-qt. plastic
1-qt. plastic
HN03
HN03
H2S04
NaOH
20
-------
BACKGROUND
HISTORY OF FACILITY:
Texas Ecologists, Inc. operates a 240-acre Class I Industrial Solid Waste
Management facility located approximately !/2 mile south of FM Road 892 and
one mile east of the intersection of FM Road 892 and FM Road 2826, approximately
3.5 miles south of Robstown, Nueces County, Texas. (Figure 1)
Permit #39023 was issued by the Texas Water Quality Board under the
authority of Article 4477-7, Vernon's Texas Civil Statues, and Texas Water
Quality Board Order 71-0820-18 on July 19, 1972 after public notice and
hearings, in Austin on February 29, 1972. (Attachment A)
Initial operations as specified in the registration were to include:
1. reclamation and salvage of oils and other hydrocarbons; 2. Incineration
of oils, solvents, hydrocarbons, grease and other combustible liquids;
3. chemical treatment of acids, caustic, and other chemical solutions; and
4. modified landfill of solid wastes and solids and sludges resulting from the
treatment process. Only incineration has never been conducted at this
facility. TECO was classified as a Class I landfill which could accept
oils, solvents, and other hydrocarbons; acids, caustics, and other chemical
solutions including those containing heavy metals; mud-water-oil mixtures;
and other solids and semi-solid wastes. No site characterization or
ground-water monitoring was required under this original permit.
The Texas Solid Waste Disposal Act of 1977 when passed required ground-water
monitoring and site characterization, therefore under this new act ground-water
monitoring began at TECO. Between 1977 and 1980 a new permit was drafted
and public hearings were held. However, due to the passage of RCRA, it was
decided by TWC to table the new permit in favor of issuing another permit
under the new Federal Act.
21
-------
During the installation of the first series of qround-water monitoring wells
in late 1977, contamination was detected and through subsequent studies a plume
was identified within the boundaries of the facility. The source of the plume was
determined to be either from a breach in the liner of pond 2 or the Old Mixing
Basin.
A Compliance Agreement between TECO and TWC was entered on February
26, 1981 in recognition of the need for further investigation and approp-
riate corrective action (Attachment B). The 1981 Compliance Agreement
required that pond 2 and the other ponds 1, 3, and 4 be drained, cleaned,
and then capped. The mixing basin, which was also a suspected source, was
also capped.
TECO initiated ground-water assessment and developed a ground-water
recovery system under the guidance of TWC. The recovery system was
basically designed to capture the plume.
It was evident by December 1981, the recovery system was not developing
the desired cone of depression sufficient to capture the contamination
plume. Therefore in order to increase the rate of ground-water recovery
and aid in abatement, a trench drain (4x4x520 ft.) was installed across
former ponds #2, 3, and 4. All recovered ground water was pumped to an
80,000 gallon equalization tank for temporary storage prior to treatment
by an activated sludge system and secondary filtration, and then finally
for disposal into evaporation Pond 26.
Current operations consist of the disposal for hazardous wastes,
recovery, and treatment of contaminated ground water, and compliance
point monitoring. During the inspection TECO was operating under RCRA
Interim Status Authorization (EPA I.D. # TXD069452360), TWC registration
(# 39023), and a 1981 Compliance Agreement with TWC. A draft RCRA Hazardous
22
L
-------
Figure 1 Location of Texas Ecologists, Inc.,
near Robstown, Texas.
-------
Waste Permit, # HW50052, has been prepared with public review pending.
The latest revised Part B Permit Application was submitted November 8,
1985 and a Ground-water Compliance Plan Application was submitted December
1985.
Adjacent Land Use:
Land adjacent to the TECO facility is currently being used for agricultural
purposes and sparsely populated residential dwellings and oil and gas field
development. A small oil and gas field is located 0.5-mile east of the site.
Further, several wells were drilled, plugged, and abandoned in 1959 - 66
on site. The nearest house is located at the northeast corner of the
site, and is owned and leased by TECO. Other residences are located a
quarter mile or more around the site. Figure 2 is a location map of the
facility showing the site and adjacent landowners.
The TECO facility is located approximately four-miles south of Robstown,
which is the only major population center near the facility. A conservative
estimate of the population surrounding the facility in a three-mile radius would
be 200 individuals. (This figure does not include the Robstown population).
Table 3 is a partial list of drinking and irrigation wells within a two
mile radius of the facility. Twenty-seven local wells were analyzed by
the Texas Water Commission in July 1979 and tested for ion balance, total
dissolved solids, pH, total organic carbon, Ec, and iron. Further bacteriological
data was collected, and field data recorded on odor, taste, appearance,
pH, Ec, temperature and dissolved oxygen. The ground-water data collected
did not indicate any contamination at that time. Since 1979 there have
been no other testing of residential or irrigation wells around TECO,
except for a private well for drinking water belonging to W.A. Aldrich,
which was sampled per his request in 1981. That test showed no detectable
change from the earlier test conducted in 1979 and was evaluated as not
contaminated.
24
-------
6S
FIGURE
ADJACE
1. Ken
Rob
2. Eve1
Rte
x67 Rod
3. Van
103
Rob
P.O
Boe
5. Fay
Rte
Rob
6. W?fl
Rte
Wiof0 |
!!465
Cor
8. Wi-1
Rte
Cor
9. J.T
Rte
Rob
10. Hir
318
Rob
11. Ken
Rte
Rob
69 63
2
JT LANDOWNERS
leth Ahlrich
EG ? ...
;town, TX 78380
lyn L.Humphries
.2, Box 26
stown, TX 78380
lie B.Mattiza Mayo
E.Ligustrum St.
;town, TX 78380
.H. A. Miller, Jr. " ~"
.Box 252
-ne, TX 78006
; McCrary Salyer
.3, Box 268
stown, TX 78380
Ahlrich
2, Box 22
Uown, TX 78380
3 Calvin St.
3US Christi, TX 78411 '
iam C. Bersen
2, Box 591-A
jus Christi, TX 78410
^Kircher , Jr ,
3, Box 127-A
town, TX 78380
rti Welty
Kiss! ing
town.TX 78380
eth Ahlrich
2
town, TX 78380
"a
7O
V
1
.
2
r.f.
11
6/
60
+
*,7
,o
3
i
1 •
4
TECO
6
7
/.I •""
^
r~ri
^
5 '
*
4.
. .
58
68
•
9
" 8
10
63
•
•
62
.•
•
— ..- - __ -_ _ _
Taken From: U.S.G.S. Topograph
Driscoll East, Tex
1\ minute, 1975
i
66 j
h"
°
66
•^
•'
6J
ic Quadrangle
is
i '-
1 i.
<4>
I
,
-------
TABLE 3
Wells within a 2 mile radius of the TECO Robstown, Texas facility
Well #
201
203
204
205
301
302
501
3a
3b
Owner
Coastal Transmission
G.B.Humphries
R.L. Cooper
Ransom
A.Merritt
E.O. Miller
W.R.Schneider
A.P.Johnson
D.L.Kircher
W.A.Aldrich
Kennith Aldrich
Kennith Aldrich
Walt Talley
Mrs. Routh
K.Busenlehher
R. Cardwell
R. Gonzales
W. Grote
M.L. Rauch
D. Saenz
D. Salyer
B. Schneider
H.W. Schneider
Date Completed
1958
1920
1943
1945
1965
1960
1945
1969
1977
1956
1976
1952
<1940
1984
1972
1966
1973
1956
1975
1960
1965
1952
Depth (ft)
500
170
242
322
368
8026
325
271
387
345
300
325
350-400
350-400
439
385
369
345
298
367
377
359
360
1 Water Use * |
Drinking/Industrial
Unknown
Drinking
Drinking
Drinking **
oil test
Drinking/Yard Irrigation
Drinking
Drinking
Drinking
Drinking
Drinking
Yard Irrigation ***
Yard Irrigation ***
Wi ndmi 1 1
,
Location
2 mile south of TEC
1/2 mile West of TE
1/2 mile West of TE
1 1/2 mile West of
1 mile South of TEC
1 mile Northeast of
* All wells are set in the Gulf Coast Aquifer
** Sand at 240' contain more total solids than 360'
*** Reported saline and not suitable for drinking
sand
26
-------
WASTE MANAGEMENT UNITS
The TECO facility handles hazardous waste as defined in the Texas
Administrative Code (TAG) Section 335 and is regulated by the Texas
Water Commission and EPA. Waste handling units and operations were
identified to aide in evaluating where waste constituents handled at TECO may
enter the ground water.
TECO currently uses the following management units/areas for the
treatment, storage, and/or disposal of hazardous wastes:
0 Landfills - disposal
0 Surface Impoundments - storage and treatment
0 Tanks - water treatment
0 Drum Storage Areas - container storage.
Past operations have also included experimental waste disposal by
"Terra Gator ®", experimental heavy-oil land farming, and multiple surface
impoundments for the storage of bulk-Viquid oily wastes.
A discussion of waste management units related to ground-water
monitoring at the TECO facility follows. These discussions are divided
into three time frames:
(1) Units operated and closed prior to when RCRA/TAC
interim status regulations were enacted
in November 1980.
(2) Units in operation between November 1980 and
November 1985 which are subject to RCRA/TAC interim
status requirements.
(3) Units that fall under Minimum Technology Requirements
as set by HSWA.
Table 4 lists the solid waste management units at TECO.
Terra Gator is a registered trade name.
27
-------
Table 4
Solid Waste Manegement Units at Texas Ecologists, Inc.
UNIT NAME
LANDFILL TRENCH #1
2
3
4
5
6
7
8
9/10
11
12
13/14
15
16
20
RCRA
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
STATUS
Closed
11
ii
H
ii
M
H
H
n
n
M
n
n
n
ii
DATE
Pre '80
n
n
n
n
n
n
ii
••
n
n
n
n
n
n
CAPACITY *
18667 CY
23333 CY
23333 CY
32667 CY
32667 CY
32400 CY
19833 CY
19833 CY
54833 CY
22166 CY
22166 CY
34800 CY
34833 CY
34833 CY
99667 CY
RELEASE
Unknown
n
n
n
n
n
n
n
n
n
n
"
n
n
n
WHEN
WHERE
COMMENTS
Trenches lined with
native clay. Release
potential high to GW.
No specific release
has been verified from
these units.
n
n
n
n
n
n
-
n
n
n
H
23/24
No
100267 CY
28
-------
Table 4 continued
UNIT NAME
Landfill Trench 25
32
30
34
31
27
33
19
28
35
36
37
SURFACE IMPOUNDMENT
#1
2
3
RCRA
No
t Yes
Yes
t Yes
t Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
t Yes
STATUS
CLOSED
ii
M
n
ii
n
n
M
n
n
Active
Under
Constructic
Closed
n
n
DATE
n
1/81
1/83
1/81
3/82
8/82
4/83
2/84
1/83
85
-
)n
11/79
8/82
3/82
CAPACITY *
82867 CY
88500 CY
87400 CY
81700. CY
68400 CY
88200 CY
74100 CY
93916 CY
81900 CY
76533 CY
-
_
2.01MM Gal .
3.40MM Gal.
1.84MM Gal.
RELEASE
n
n
n
n
Unkown
ii
n
M
n
n
n
_
Yes
Yes
Yes
WHEN
75-77
75-77
75-77
WHERE
GW
GW
GW
COMMENTS
n
Trenches lined with
compacted native clay.
No specific release
^as been verified.
Tranches have leachate
collection system.
n
n
n
(Trench located over
old impoundments 2,3,
& 4)
SAME AS #32
n
Double lined with clay
and synthetic; however
sides do not meet MTR
Liner meets MTR
Contaminants detected
1977 during monitoring
well installation
29
-------
Table 4 continued
UNIT NAME
Surface Impoundment 4
new 3
26
30
Mixing Area
(AKA Trench 17/18)
Storage Tank M-l
Tanks M-2 thru M-6
RCRA
t Yes
Yes
Yes
No
No
Yes
Yes
STATUS
ii
H
Active
Closed
Closed
Active
Active
DATE
3/82
6/85
M
7/80
Pre '80
CAPACITY *
3.60MM Gal.
4.3MM Gal.
7.30MM Gal.
3.10MM Gal.
Unknown
80000 Gal .
20000 Gal.ea
RELEASE
Yes
Unknown
Unknown
Unknown
Yes
NO
NO
WHEN
75-77
'77 ?
WHERE
GW
GW
COMMENTS
old impoundments.
Lined with synthetic
and clay
Bulk liquids mixed
silty sand by backhoe
stores ground water
prior to treatment
treated
water storage tanks
Capacity figures represent total volume of trench, waste utilization is approximately 35%
Gal.: Gallons
CY.: Cubic Yards
t Units closed prior to November 8, 1980 are termed pre-RCRA units. However, units closed between November 8, 1980
and July 26, 1982 are termed non-RCRA-regulated Solid Waste Management Units that are RCRA regulated but not
subject to 40 CFR §264.100 Subpart F.
30
-------
Pre-Interim Status Regulated Waste Management Units:
Waste management units and activities operated before November
19,1980, which are not subject to the TAG interim status ground-water
monitoring requirements, are potential sources for release of hazardous
waste constituents to ground water.
Between 1972 and November 1980 nineteen landfill trenches, two surface
impoundments, and one mixing trench were activated, used, and removed
from service. The hatched portion of Attachment C shows the location of
these units.
The first fourteen trenches used at TECO for waste disposal
were rectangular cells constructed in native clayey soils.Though early
design drawings indicated clay liners were to be installed, with the
possible exception of trench 1, the first fourteen trenches had no
liner or leachate systems installed. Each trench, though never surveyed,
is believed to be 15-feet in depth, 100 feet wide and 225 feet long.
Various correspondance reviewed in the TWC files indicate trench depths
anywhere from 9 to 17 feet.
These early trenches hold a full range of wastes (as defined by 40 CFR
261, with the exception of reactive wastes) including drummed liquids and
solidified liquids/sludges. The drums were disposed on their sides in
layers five deep with fill dirt between each layer.
These trenches were completed in a 'leap frog1 fashion. Excavated
soils were stored adjacent to the active trench and were often used
either as fill or as an absorbent mix for liquid/sludge. Figure 3 is a
drawing of the facility dated January 1975. It illustrates trench
development and usage. Each trench was closed with a clay cap 18 to 24
inches thick and seeded for vegetation.
31
-------
LAK1PFILU
FUTURE
FIGURE 3 January 9,1975 Texas Ecologists, Inc. Site Plan
Approximately- 1"=150'
From: 1975 Robstown System Expansion Engineering Drawings
-------
The next series of trenches were constructed with a compacted clay liner
of reportedly 10~? cm/sec permeability due to encountering water during
the construction of trench
All wastes placed in trenches, were segregated into three chemically
compatible cells. The compatibility groups are:
A B C
Oxidizers Bases Organic Solvents
Inorganic Acids Reducers Organic Acids
Cyanides Aldehydes
Heavy Metals Alcohols
Pesticides General Organics
Inerts
Saturated Hydrocarbons
Unsaturated Hydrocarbons
Depending on the waste types and quantities received trenches may
contain more wastes of one group than another. Each compatibility
cell within a trench was segregated by a three-foot wall of clay.
%
Trench 33 was used as an experimental trench for the disposal of
liquid wastes to assure stabilization in the soil as well as minimize
odor emissions. The experimental process utilized a tractor equiped
with a 3,000-gallon tank, vacuum and pressure capabilities and subsurface
injectors to mix liquid with soil at a depth of 17-inches. The system
was referred to as a "Terra Gator".
Initial usage of the system took place between September 1980 and
January 1981, at which time a demonstration was held for TWC and TACB
district representatives. Reaction by Texas regulatory authorities was
favorable because the system appeared to control odor emissions.
Problems soon developed with the soil load capacity and with the
presence of excessive liquids accumulating in the leachate collection
33
-------
system. It was calculated that at one point 8-feet of liquid existed in
the liner/leachate system. The Terra Gator was therefore judged by TWC
to be an ineffective method of liquid waste disposal and constituted a
potential release mechenism to the ground water. TECO was then ordered
to cease using the Terra Gator in 1982.
Mixing trench 17/18 was an open trench used solely for mixing liquid
or sludge wastes with sands and clays prior to disposal. Exact dates
of operation are unknown. However, it is believed to have been filled
with contaminated material and closed between 1978 and 1980. A release
of contaminants has been attributed to trench 17/18. The assessment
study conducted-is decribed later in this report.
Pond #1 was the first of the four original surface impoundments and
was closed in November 1978. The pond was used solely for overflow from
pond 2. Closure was performed by evaporation of liquids; the clay liner
was then removed to then active trench #25, and the depression backfilled.
It is not known .if any analytical tests were performed to assure complete
removal of hazardous constituents.
Pond 30 was developed as a result of a 1978 hurricane. Trench 30
was half-full with wastes when a hurricane flooded the site area. The
remaining west half was converted into a pond, a divider wall constructed
and the last half of trench 30 was capped. Liquids received were contaminated
storm waters and water transferred from pond 2 which had been treated by
the Calgon Unit®. Use of the pond continued until July 1980. Even though
not in active use after that time, the pond remained open with liquid
until pond #26 was completed. Therefore pond 30 is considered a RCRA
unit.
Calgon is a registered trademark
34
-------
As part of the Compliance Agreement (Attachment B) pond #30 was
closed and the liquids transferred to the new pond 26. Liquids were
transferred in 1982 and by fall 1983, the clay liner removed and deposited
in trench #19. The leachate collection system was rebuilt along with the
barrier between the trench and pond portions. The remaining half was
never utilized for waste disposal but was backfilled with clean soil. A
final clay cap was installed over the entire Trench/Pond 30 area in
December 1983.
Interim Status Regulated Waste Management Units:
Nine landfill trenches were activated between November 1980 and
November 1985. They were trenches 32, 34, 31, 27, 28, 30, 33, 19, and
35. Even though they all only used compacted clay as the primary liner
material , trench construction techniques and design appear to have
progressively improved with time. The trenches typically have been 600
feet long, 200 feet wide, and a maximum 25-feet deep (5-feet above
historical high ground-water table), and have a base of three feet of compacted
clay as a liner.
Compacted clay diversion dikes were constructed around each trench
while it was active to prevent the run on of surface water and to prevent the
run off of potentially contaminated waters.
Trench floors and leachate collection systems were graded towards
the low end of the trench where a sump area was constructed. Leachate
collection systems have typically consisted of twelve inches of sand
with a drain field of four-inch PVC pipe connected to a 1000 gallon
reservoir pipe and riser pipe.
The trenches were capped with a final backfill over the wastes and
a compacted clay cap. Prior to 1983 final caps were sloped to drain
in a sheet pattern. Caps constructed since that time are graded to a
center crown with a slope to either side. Eighteen inches of uncompacted
soil covers the clay cap to support vegetation.
35
-------
Ponds 1,2,3, and 4 were the original surface Impoundments planned by
the facility to handle bulk liquids, oily wastes, storm-water runoff,
and spill disposal. Pond 2 was the first surface impoundment constructed
in 1973. Ponds 3 and 4 were later built to receive excess from pond
#2. Finally in 1977-78, pond 1 was constructed to receive runoff from
pond #2. Only pond #1 was closed prior to November 1980.
1978 was the peak period of the ponds being used as waste handling
areas. Pond 3 was being used as the primary receiving pond, where
oily wastes were skimmed off and recycled whenever possible. Liquid
from pond 3 was then transferred to .either pond 2 or 4 for evaporation.
Pond 1 was only used for overflow from pond 2.
All four ponds were approximately 10-12 feet deep with compacted clay
on the sides and floor. Cells were sloped 2:1 on north-south walls and
4:1 on east-west walls.
»
The ponds were dredged periodically, with the removed sludges
deposited in the active landfill trenches. It is this periodic dredging
that TECO alleges to have caused a breach in the liner of pond 2 in 1975, and
resulted in the ground-water contamination and cause for corrective
action.
The initial steps in the corrective action were to drain the contents
of pond 2 into ponds 1 and pond 4, and to cease receiving new wastes into
ponds 1, 3, and 4. The old clay liner of pond 2 was excavated and a
new liner installed, with the sole purpose to be a retention basin for
recovered ground water and rain water. The excavation from these ponds
was placed in trenches 23/24. The ponds were backfilled with sandy soil,
then capped "with three feet of clay.
Pond 2 was the last of the original ponds to be comoletely closed.
As a result of the TWC Compliance Agreement all recovered ground water
and contaminated surface runoff that had been stored there was piped to
pond 26. It was then excavated to twenty-five feet (like ponds 3 and
36
L-
-------
4). Excavated material was removed to an active trench, then the area
was backfilled and capped with 3-feet of clay. Once ponds 2, 3, and 4
were closed the area was denoted at trench 19. No further wastes were
placed in this area.
New Pond 3 was constructed and designed as part of the compliance
agreement with TWC. According to item two of the agreement, "only recov-
ered ground water that in the opinion of TECO presents no potential for
causing odors or that has been treated by activated carbon absorption may
be stored or disposed of in pond 3".
The pond was built in 1980 with a clay liner with underdrain and used
until 1983. Even though it was not active after 1983 the pond was kept
open as an overflow pond for the treatment system. During this period of
inactivity the liquids evaporated and cracks appeared in its clay liner.
Therefore in early 1985 the liner was judged inadequate; a new clay liner
was installed, with the original liner removed and placed in trenches 35
and 36 during June 1985. Current plans for the pond are'to convert it to
trench 21 and use it for waste disposal following the closure of trench
37. Presently, this trench does not meet minimum technology requirements
for the liner and will need to be retrofitted prior to activation.
Pond 26 was developed as part of the Compliance Agreement between the
Texas Water Commission (TWC) and the facility. According to the agreement
TECO was to "... construct pond 26 and pond 3 in accordance with the
plans and specification submitted to TDWR on January 20, 1981. Pond 26
shall be completed by April 15, 1981. Subsequent to the completion of
pond 26, TECO shall transfer water from existing water impoundment ponds
2, 3, and 30 into pond 26."
Construction of the pond began in early 1981 and was completed in
November 1981. During the initial liner integrity test a leak was detect-
ed and the pond taken out of service. All liquids were removed until the
leak was repaired, whereupon the pond was placed back in full service in
37
-------
Jan-Feb 1982. This was roughly nine months past the original completion
date set in the compliance agreement. Reasons for the delay varied from
1) inclement weather, 2) poor quality of off-site clays being used in
construction, to 3) difficulties involving the synthetic liner to be
used.
Pond 26 was originally intended to be used as a trench and had been
excavated to approximately 25 ft. In order to be used as a pond the
bottom was backfilled with a clay soil and compacted to 90% standard
proctor density. Two feet of compacted clay was placed above the fill
at 11.5 feet above the ground-water table. This clay is compacted to 95%
standard proctor density and forms the base of the leachate detection
system. Four-inch diameter perforated ABS pipe laterals wrapped with
filter fabric, and placed in one foot of sand are connected to a single
pipe leading to a sump and a riser. This design serves the dual purpose
of detection and removal of any liquids which penetrates the overlying
liners.
The primary clay liner (or secondary clay'containment system) is
approximately three and a half (3.5) feet of clay soil compacted to at
least 95% standard proctor density. The clay-floor liner is graded to
one corner (SW) for drainage. Side-clay liners are thicker than 3.5 feet
due to excavation techniques. The sides have an average heiqht of 12
feet with 2:1 side slopes.
Overlying the clay liner is a 60 mil high density polyethylene (HOPE)
synthetic membrane. The membrane (or primary containment system) is
designed to withstand operational stress and the affects of ultra violet
radiation from the sun. The synthetic liner covers the floor and sides
of the pond, and is anchored into a trench on the crest of the outer clay
dike. '
The compacted clay outer dike is approximately 3.5 feet high, is
5-foot wide at crest and has 2:1 side slopes. Current usage of pond 26
38
-------
Is as an evaporation pond for recovered ground water, and contaminated
storm water. Natural evaporation is enhanced by the use of a spray
evaporation system. This spray system consists of nozzles and trickle
pipes supplied by a pump.
Post-November 8,1985 Units:
Trench 36 was the first trench to be completed and activated after
the.enactment of the Hazardous and Solid Waste Ammendments of 1984 (HSWA).
Table 5 is a comparative evaluation of the Minimum Technology Requirements
(MTR) as set forth under HSWA and TECO trench 36 (also known as cell 36).
It is evident from the table that the major difference is that Trench #36
does not have a sidewall leachate collection system and therefore does not
meet MTR. TWC inspected TECO in April 1985 and observed the construction
of Trench #36. The lowermost liner was being prepared for installation
during this inspection. Hazardous waste disposal commenced on June 8,1985,
one month after the May 8,1985 deadline for requiring a facility to meet
MTR for any new land disposal unit. Therefore, trench 36 is in violation
of Section 3004(0)(1)(A) and Section 3015 (b) of RCRA;
This issue is currently under negotiation between EPA Region VI '
Regional Council and TECO.
Trench 37 was under construction during the Task Force inspection,
at which time the basal compacted clay liner was being installed.
Construction specifications for this new trench were reviewed and were
evaluated to meet MTR for land disposal trench design. Full construction
diagrams and descriptions are included in the Part B Permit Aplication,
Volume IV (B), Engineering and Construction Manual.
39
-------
Table 5
Comparative Evaluation of the Minimum Technology
Requirements (MTR) and TECO Trench #36
Statutory Interpretation
Trench 36 Design
Bottom Liner System
The bottom liner must consist of
36 inches of recompacted soil
with a permeability no greater
than 1 x 10"7 cm/sec.
Unit sidewalls should not exceed
a maximum slope of 3.1
The bottom liner must
underlay the entire unit.
Cell 36 contains a composite
liner system. The bottom
liner consists of 36 inches
recompacted soil with a perme
ability of 1 x 10-7 cm/sec or-
less. This is overlain with a
Flexible Membrane Liner with a
thickness of 80 mils.
Cell 36 sidewalls are nearly
vertical.
The composite liner system
underlays the entire unit
dimensions, including the
sidewalls.
Secondary Leachate Collection/Detection System
Must consist of 30 cm (12 ") of
poorly sorted drainage material
with a hydraulic conductivity of
1 x 10~2 cm/sec. This system must
contain perforated pipe, compatible
with the waste leachate, with a
Cell 36 contains a lower drainage
member consisting of 12" of
poorly sorted sand with a
hydraulic conductivity of 1 x 10*3
cm/sec. 4-inch perforated
drainage pipes are located
with this sand
40
-------
Table 5 (continued)
diameter and spacing sufficent
enough to rapidly transmit liquids,
A slope of 2% is required
to promote a gradient sufficent
enough to remove liquids.
Similar to the bottom liner, this
system must be located completely
up the sidewalls of the-unit.
member at 25 ft spacing intervals.
The 4-in pipes are centered between
2% slopes and are sloping at
0.5% into a 12—inch reservior
pipe.
This secondary drainage system
does not extend up the unit
sidewalls.
This unit must have an associated sump
pump which will adequately remove all
liquids.
The reservior pipe slopes at
0.5% into a 10 inch primary riser
and is connected to a 2 ft sand
sump.
Primary Liner System
The upper FML should be located
above the secondary drainage
system and cover the entire
the unit including sidewalls. This
liner must be waste compatible and,
at a minimum, 30 mils thick.
However, if exposed for extended
periods of time to the atmosphere,
the liner must be at least 45 mils.
Cell 36 design includes a upper
FML of 80 mils in thickness and
an associated "1 foot clay liner.
The clay liner is located between
the FML and the lower leachate
collection system. Neither the
FML or clay liner extend up the
unit sidewalls.
No filter material is utilized
below the clay liner. Possible
clogging of the lower leachate
collection system by fines may
take place. The clay unit will
also retard the time it takes to
detect leaks in the upper FML.
41
-------
Table 5 (continued)
Primary Leachate Collection/Detection System
As with the secondary leachate Collection/
Dectection System, this system must consist
of 1 foot of coarse grained drainage material
with a permeability of 1 x 10~2cm/sec.
Cell 36 utilizes 12 in. of
sand as drainage material with
a permeability of 1 x 10~2cm/sec.
The recommended drainage pipe should consist
of 6 inch diameter pipe which is chemically
resistant to leachate. The recommended
separation distance is 50 to 100 feet
between pipes with an associated 2%
slope. Other diameter pipes at different
spacing intervals can be used, if it is
shown, by mathematical calculations, that
the hydraulic head of collected
leachate will not exceed 1 foot.
An associated filter media above
this drainage member should be
utilized to prevent clogging
"of the system by fines
Located within this drainage membe
are 4-in. ARS perforated drainage
pipes with a separation distance
of 25-feet.
The slopes between pipes are 2%
and are themselves sloping 0.5%
into a 12-in. ABS reservior
pipe. Cell 36 utilizes a geo-
textile filter fabric between
the pipes and drainage materials
which may affect the system
performance.
The unit design does not include
an overlying filter media to preve
clogging of the drainage systen b^
fines.
The drainage member does not
extend up the unit sidewalls.
42
-------
Facility Operations
Waste Characterization:
TECO requires that all waste generators utilizing its facility supply a
physical and chemical analysis of a representative sample of each waste
stream before authorizing disposal The corporate office provides a new computer
printout of all technical, analytical, administrative, and previous disposal
information when scheduling a waste shipments to the facility. The printout
is reviewed on the corporate level with no shipment being accepted without the
approval of the corporate technical review committee.
Facility-generated wastes such as motor oil, rags, shop wastes,etc.
require no special analyses and are disposed on site. Large volumes of
special wastes such as surface impoundment liquid or leachate do require
analysis to determine proper handling and disposal methods. Because, as
of May 1985, TECO no longer accepted or disposed of bulk liquids at'
their facility, facility generated bulk liquids are transported to an
approved disposal site. Currently they are using the Chemical WastB
Management, Corpus Christi, Texas, injection well.
Whenever a waste shipment arrives at the facility the waste material is
inspected by the Chemical Safety officer, assistant facility
manager or laboratory technician. The procedures for waste acceptance as
observed during the inspection are:
1) Driver registers at gate and is issued a visitor's badge, hard hat
and 1/2 face respirator.
43
-------
Unresolved
Lead Denied
Waste does not
meet description
Request for Disposal
(Submitted by Customer)
I
Information Reviewed by
Technical Review Team
Situation
Resolved
Load Accepted
Approval
Customer Notified
I
Waste Shipment
Scheduled With Site
Waste Arrival
__(!) Sample Taken for
In-depth Verfication
(2) Visual Verfication
I
Waste Accepted by
Site CSO
_Additional
provided
information
Acceptance Denied
"Waste unacceptable
Waste outside our
criteria
Bulk Shipment
Solids
Waste Off-Loaded
in Designated Trench
Area
Containerized Shipment (Solids Only)
Liquid
Waste off-loaded a
portion at a time in
mixing area. Mixed
with site soil/absorbent
until all free liquids
are gone. Then absorbed
liquid placed in designated
trench area for final
disposal
Wa.ste off-loaded by fork!ift
or front end loader and
containers placed in designate
disposal area.
Six inches of soil cover
placed over waste at the
end of day.
Figure 4 - Schematic of waste acceptance procedure
44
-------
2) Accompanying manifests are given to TECO representative and checked
against computer printout for corporate approval , technical and
analytical information, EPA waste code, Texas waste number and
expiration date.
3) Any discrepancies are noted and the corporate office notified.
Random sampling of 10% of the waste is performed to verify contents.
If shipment consists of drummed wastes, all drums are opened to verify
solidification, but only 10% are sampled.
a) Two man teams sample waste wearing tyvecks®, respirator,
hardhat, face shield and nitrile gloves.
b) A random composite sample is tested for pH, density, water
reactivity, and a paint filter test for sludge.
c) If one anomalous drum is found then all drums are tested
individually.
d) A density test is performed for bulk loads.
e) Laboratory technician completes lab analysis form.
4) A Work Order Log Book is maintained and includes work order number,
customer name, date work order is completed, and date verification,
analysis is received. When applicable waste samples are shipped
via UPS to corporate lab in Louisville, KT for detailed verfication
of waste content. The work order provides TECO personnel with a
check-off and data recording form for all waste shipments received.
5) Volume of waste is verified against manifest. If a volume
discrepancy of more than 10% is discovered it is noted on the
work order and the corporate office notified.
6) When the waste has been accepted the waste stream number, waste
category, trench number, trench cell, disposal date, manifest
number, quantity, and disposal location is to be recorded on the
work order form.
Figure 4 is a schematic flow chart of the waste acceptance procedure.
45
-------
Waste Compatibility:
All wastes are segregated within the trenches based on compatibilities.
The three cell system described in the section on Waste Management
Units is designed to ensure that incompatible materials do not come
into contact.
The following wastes are not accepted.
0 Liquids with boiling point above or equal to 100°F.
0 Pyrophorics
0 Cyanide or Sulfide compounds with 10% CN~ or 5% S~(except in lab packs)
0 Etiologic Agents
0 Explosives
0 Gas Cylinders
0 PCB materials as defined by TSCA (c/o CFR 261)
0 Peroxides (organic)
0 Radioactive materials
0 RCRA reactive materials
0 Liquids with pH > 12.5 or < 2.0 -
0 Solids with a 1% solution pH > 12.5 or < 2.0
0 Containerized liquids (except in lab packs).
0 Absorbed liquids in bulk.
Disposal Operations:
The Chenical Safety Officer designates waste disposal areas within the
appropriate trenches. No wastes are to be placed in direct contact
with the synthetic membrane liners, and clean soil is to placed where
needed to prevent potential reactions.
Drums are disposed in an upright position in the trench cell. Each
container (except for lab packs) is punctured to create 2-one-inch
holes near the bottom and 2-one-inch holes along the side midway. No
drums are placed closer than one foot to the synthetic membrane liner.
46
L.
-------
Whenever bulk solid wastes are being disposed the transport
vehicle is taken to the trench and unloaded there. Supposedly only
materials that can be unloaded without dust or producing odors beyond
the active trench area are accepted. During the inspection it was
observed that certain waste loads did omit odors beyond the trench. When
these odors were discovered, the Chemical Safety Officer ordered the
trench operators to place more cover on the waste for odor control.
Historically, state and local agencies have received numerous complaints
by local residents concerning odor problems. A minimum of six inches of
cover is placed following waste disposal. Similar to drummed wastes,
bulk solids are not to be placed within one foot of the synthetic liner
wall.
No absorbed bulk or containerized liquids waste have been accepted
since May 1985. Generators of liquid wastes must provide proof that
the liquids have been solidified and are maintained in their least
solute and/or toxic form.
Bulk or containerized wastes will sometimes arrive on site containing
free liquids. These liquids are stabilized/solidified using kiln
dust, fly ash, port!and cement or lime.
Bulk solids and solidified liquid ignitable wastes are placed into a
container prior to disposal in a landfill trench. The type of container
used was not specified.
Liquid/sludge waste when generated from the ground-water treatment
plant will be disposed on site. The initial volume of accumulated
sludge from the system will be stabilized with portland cement in a cement
mixer. Future volumes will be dewatered using a filter press prior to
disposal. Both techniques were still under study by TWC at the time of the
inspection.
47
-------
Waste Location:
TECO maintains records of a system of cells, with coordinates within a
ten-foot tolerance, within trenches surveyed within a one foot tolerance,
and the contents of each cell. Past experiences where TWC requested that
unacceptable drummed waste be removed has found this system to be adequate.
Sump/Leachate Monitoring:
An adequate leachate detection system at a facility such as TECO is
important because contaminants detected here are the precursors of
contaminants to be found in the ground water If not handled promptly and
correctly.
Leachate is measured and withdrawn daily from all trench sumps. The
leachate is collected in a portable tank, then transferred to a vacuum
truck. The leachate is handled as a hazardous waste and is manifested to
a bulk liquid hazardous waste disposal facility.
Septic System:
A question arose during the inspection regarding the septic system at
TECO because several of their ground-water reports stated that sewage wastes
are disposed in the upper aquifer. Both the facility manager and
Nueces County Health Department were questioned on this issue. It was
established that in special cases where low permeability clays are present
and a horizontal lateral field proves ineffective, permission for an
alternate vertical absorption bed is granted by the Texas State and
County Health Departments.
48
-------
This permission was granted by the demonstration that the sand
underlying the surficial clay was either dry or below a certain dryness
point before a county health inspector. This was apparently accomplished
and then vertical absorption beds were installed. The exact depth of
these lines is unknown but is believed to be between 33 to 40 ft. depending
on space and soil conditions. No vertical system is permitted within 300
ft. of a water well.
The TECO vertical septic system drain field should be classified as
an industrial drain well of the UIC Class V well scheme.
Inspections:
TECO maintains several inspection log records for various aspects of
the facility. Depending on the topic these logs are maintained on a daily,
weekly, or monthly basis. Several of the records were reviewed during the
Task Force inspection. It was found that up-to-date entries were not always
present and time gaps between entries existed.
An example of a time gap was seen in the Tank Farm Inspection Record.
This inspection log was begun April 1, 1985, however there were no entries
for the 80,000 gallon recovered water storage tank until January 10,1986
when a leak was detected. This type of gap in the inspection log could
either indicate that the seals and tank was not inspected until that time
or no notations were made until a leak was detected. Further, there were
no subsequent comments regarding the repair of the tank. The following
inspection on January 13,1986 recorded the tank freeboard but did not
mention the leak or any repairs.
There were other leaks noted for the Clarifier and Fast unit tanks
within the Water Treatment System on November 8,1985 and December 3,1985.
No subsequent entries mentioned further leakage or corrective action for
the leaks initially found.
49
-------
Future Operations:
The TECO facility accepts about 657,000 cubic feet of wastes per
year with plans on increasing this to 1,210,000 cubic feet per year.
An estimated ~4,500,000 cubic feet capacity remains. Current land use
rate is estimated to be 25% to 33% waste with 75% to 67% backfill.
Using these figures, they have a future waste handling capacity of
31,185,000 cubic feet and an expected life span at the facility of 25 years.
Attachment C illustrates current and proposed cell locations. Following
the completion of Trench 36 TECO plans to begin using new Trench 37
and/or Pcnd 3 which' is to be converted to Trench 21. Future expansion
plans call for the construction of 15 new trenches.
The expansion plan also shows future disposal in the recovery well
area. This would indicate that once the contamination plume is fully
recovered and background quality is established, disposal trenches will
be constructed there.
50
-------
SITE HYDROGEOLOGY
Several investigations have been conducted by Texas Ecologists, Inc.
consultants to define the hydrogeologic netting of the Robstown facility.
The various reports were presented duri ig the Task Force insp :tion and reviewed,
Local Physiography:
The site is located in the Gulf Coastal Plain physiographic province,
(Figure 5). The area is characterized by low relief with an average site
elevation of 65 feet above mean .-sea level (MSL). Regional slope is
toward the southeast at about three feet per mile. Original topography
of the site followed the regional trend, however, this has been modified
by the construction of landfills, dikes, capping of landfill cells, and
stockpiling of soils.
Regional drainage is generally perpendicular to the coast. Storm-
water runoff drains to a north-south trending county-maintained drainage
ditch, which bisects the site, thence to Petronila Creek about 7.5 miles
to the south and eventually to Buffin Bay. *
The facility is constructed on Victoria Series Soils. This soil
series consists of dark gray to nearly black, moderately crumbly, calcareous
clay and sandy clay. The soil is characterized by its very high shrink-swell
capacity. Surface soils will dry and form desiccation cracks nearly
every summer, however, the subsoil can absorb and store much water in a
short period of time during heavy rains in the fall.
* It should be noted that rainfall flowing to active trench areas is
collected and placed in pond 26. Runoff from non-contaminated areas is
directed towards the county drainage ditch. Local residents near the
TECO facility have complained to authorities that contaminated water is
being diverted to this ditch. No evidence of this fact was found during
the inspection. TWC is evaluating the need for a stormwater discharge.
51
-------
EXPLANATION
Beoumonl Cloy
Cloy intrrbfdded with mtdium lo
line jontj Yield? jmoll lo moderolf
qoonhliei o' I'esh lo moderolfly
saline water
Lissie Formolion
Cloy, sondy dOy, sond, ond grovel
Generolly yields smoll lo lorge
qvionMie's ol desh to
saline water
Goliod Sand
Sond or sonds'one mlerbedded
with cloy ond g'Ove! E«1enslve
deposils ol caliche ot the outcrop
Yields smoll lo large quantifies ol
. Iresh lo slightly saline water
ar_
UJ
Geologic contact
lOMiiti Dashed where oppronmole
Geology of Nueces ond San Palricio Counties and Adjocenl Areas
Figure 5 Site Area Geologic Map
From: Texas Water Development Board Report 73, "Groundwater Resources of Nueces and San Patrlcio Counties, Texas", 1968.
-------
County drainage ditches were developed in the area to assist in the removal
of excess water from the clay soils. Local residents supplied descriptive
information to the Task Force on the degree of cracking that occurs in
the shallow soils. It was reported that they had observed during their
long time farming and living experience in the area that the soil cracks
can be several hundred feet long and tens of feet in depth.
Soil permeability* ranges from 0.10 to 0.20-inches per hour at the
surface to 0.01 to 0.05 inches per hour at five feet in depth. Natural
soil pH is 8.0 to 8.9. The soils have a poor suitability rating for
septic tank disposal systems due to their low permeability and high shrink-
swell potential. A chemical and physical analysis of the soils shows
that 52 to 59 percent of the soil is made up of clay less than 0.002 mm.
The nitrogen and carbon-nitrogen ratios decrease with depth, but the
estimated salt content, electrical conductivity, and calcium carbonate
equivalents increase with depth.
Local .Geology:
The TECO site is underlain by Pleistocene fluvial deltaic sediments
which are divisible into two mappable units of the Beaumont Formation:
1) Distributary and fluvial sands and silts with levee and
crevasse splay deposits; and
2) Interdistributary mud, including bay, flood basin and
abandoned channel facies.
* Soil permeabilities based on values from the Soil Conservation Service
and represent the rate water moves through a specific soil horizon.
53
-------
The distributary channel deposits form an elongate branching pattern
oriented in an east-southeast trend towards the coast. Regionally, these
deposits are mapped as the Beaumont Formation which consists mostly of
clay, silt, sand, and gravel with concretions and massive accumulations
of caliche** (CaCOs) and concretions of iron oxides and iron-manganese-
oxides in zones of weathering. The thickness of che formation' is approximately
100 feet.
The Lissie and Goliad Sand Formations underlie the Beaumont, with
the Lissie Formation at around 460 feet and the Goliad below. These two
formations are not exposed in the site vicinity, but do outcrop roughly
20 miles northeast of the site. Due to the similarities of all three
formations in their environments of deposition and lithology, distinction
between them is difficult.
A generalized stratigraphy underlying the site consists of the
following horizons:
Horizon I Description | Thickness | Permeabilities
Surficial Clay
First Sand
Second Clay
Second Sand
Tan and gray clay to sandy
clay, with sand lenses and
caliche.
Tan silty sand with clay
lenses. Variable fines con-
tent yields clayey to silty to
clean sands
Tan, gray, and brown clay,
sandy clay, and clayey sand
with sand lenses to 15 ft.
thick; caliche; slickensides *
Tan sand with clay layers;
Few borings penetrate this
zone; Fully saturated
15 feet
10 to 40 feet
10-7 cm/s
3.6 x ID'3 to
3.3 x 10 ~5 cm/s
15 to 35 feet
25 to 53 feet
** Caliche is sediment which has been cemented by porous calcium carbonate.
* Slickensides - pedo.logical features that are produced by dessication and
differential movement.
54
-------
Cross sections prepared by TECO consultants lack adequate well
control to give any great detail. Cross-section interpretations prepared
by TWC have more well control. Both TECO and TWC cross sections are shown
in Attachment C. They show that sand lenses in the Second Clay are
sizable and that the Second Clay thins to as little as five feet above
and below a thick (12 foot) sand lens in the east-west cross section.
The north-south cross section reveals complicated sand body geometry which
is suggestive of a channel deposit. This feature, and a similarily
shaped clay deposit in the east-west section, if continuous, would define
a structure with a northeast trend within the first sand, and delineate a
preferential path for ground-water flow.
Local Hydrogeology:
The major aquifer for ground-water development is the Gulf Coast
Aquifer which yields potable water from a depth of about 350 feet. This
aquifer is used by adjacent landowners for both drinking and irrigation,
and by TECO for production and irrigation.
Ground water occurs beneath the facility at a depth of about 30-feet
below the land surface. The first water-bearing sand unit contains water
of variable salinity in a saturated interval of 15 feet, (referred to as
the First Sand). The Second Clay horizon from about 10 to 25 feet thick
separates the first sand unit from the second water bearing sand unit.
Teco monitors these two shallow saturated sands beneath the site.
Contamination of the First Sand has been attributed to previous site
disposal practices and is discussed later in the report. Studies have
been conducted to define the extent of contamination, which appears to be
confined to the First Sand.
Ground water is encountered under unconfined or water-table conditions
in the First Sand which is primary the monitored zone. Recharge occurs through
surface infiltration at areas where the overlying Surficial Clay is
thinner than the normally observed 15-feet. Three recharge zones have
been identified at the site. The first is in the southeast corner of the
55
-------
TECO property where the clay thins to 12 to 18 feet. The second Is along
the western side of the property where a thinning clay structure extends
towards the center of the site. Finally, the third area is a man-made
recharge mound resulting from the county drainage ditch which runs north-south
across the site, and produces a radial pattern of flow away from the ditch.
Through various tests performed by Texas Ecologists and their
consultants, calculated permeabilities have been determined to range
between 3.8 x 10-4 cm/sec to 1.2 x 10-5 cm/sec. Velocities for this same
horizon (First Sand) were shown to range between 1.6 x 10-1 ft./yr. to
7.2 x 10-2 ft./yr.
Water level data for the First Sand are plotted and contoured monthly
for the TECO monthly Ground-Water Compliance Agreement Report which is
sent to TWC. Attachement E contains copies of reports for February 1986
and February 1982
Due to recharge areas on site a "saddle" occurs near the covered
mixtng basin at the center of the site. Flow, therefore is split into
both northerly and southerly directions. Ground-water gradients (based on a
1985 TWC report) range from 0.0059 ft./ft. in the southeast corner of the
site to nearly flat in the "saddle". A cone of depression is being
formed by the pumpage of recovery wells and the recovery trench drain. A
series of recharge wells in the northeast corner may be creating a slight
ground-water mound and further impeding the natural flow to the north-northeast
The steepest gradient on site, 0.0322 ft./ft., is associated with the
recharge mound and recovery cone.
Vertical downward gradients are implied from the unconfined First Sand to
the semi-confined Second Sand by water level differences. For example at
monitoring well E-35 (completed in Second Sand) a difference of at least one
foot was observed, and at well E-38 (completed in Second Sand) a difference
of 5.82 feet was observed.
56
-------
Equilibrium is closest at E-41 where the difference is about 1.1 foot.
This area also contains a sand lens within the confining layer or clay
that may be a potential contaminant pathway for vertical migration. The
Part B Permit Application for TECO contends that these two sands are not
connected, based on extended pumping at monitoring well E-40 and water
level observations in adjacent deep wells and shallow wells. No supporting
data was presented to verify this fact. Ground-water flow rates in the
First Sand were calculated by TWC to range from 0.5 ft./yr. to 18.9 ft./yr
outside the area of pumpage, and 85.5 ft./yr. at the steepest side of the
cone of depression. This contrasts very sharply with natural flow rates
and the rates calculated by TECO.
57
-------
GROUND-WATER MONITORING PROGRAM
The following is an evaluation of the monitoring program and how it has
evolved over the years until the time of the Task Force inspection. This
section discusses the following topics:
0 Regulatory requirements
0 Monitoring Wells (construction and placement)
0 Development of the Compliance Agreement and Corrective Action Program
0 Special studies pertaining to ground water and waste units
Regulatory Requirements:
State regulations for interim status facilities are contained in Title 31
of the TAC Section 335, subchapter E through T, which became effective on
November 19,1980. The State ground-water monitoring requirements (Subchapter
I) are nearly identical to RCRA interim status requirements contained in Title
40 of the Code of Federal Regulations Part 265 (40 CFR Part 265), Subpart F;
there are no substantial differences. Equivalent regulations are shov/n in
Table 5.
As a result of a contamination plume being discovered at TECO prior to
November 1980 TECO petitioned for and has followed an Alternate Ground-Water
Monitoring Program rather than the standard Interim Status Monitoring Program
as set forth under 40 CFR Part 265 Subpart F. The current monitoring network,
sampling parameters, frequency, and reporting guidlines are specified in the
February 1981 Compliance Agreement, (Attachment B).
Pre-Compliance Agreement Monitoring:
Prior to November 1980, when RCRA came into effect, and February 1981,
when the currrent compliance agreement was initiated, Texas Ecologists operated
58
-------
TABLE 5
Interim Status Regulations -
Corresponding State and Federal
Subpart
Title *
Appl icabil ity
Ground-Water
Monitoring System
Sampling and
Analysis
Preparation, Evaluation
and Response
Reporting and
Recordkeeping
TAG
(Title 31)
335.191
335.192
335.193
335.194
335.195
RCRA
Regulation
(40 CFR Part)
265.90
265.91
265.92
265.93
265.94
* Subpart titles arc the same in both the State and-RCRA regulations,
** TAC regulation number as of February 1986.
59
-------
under the July 1972 Certificate of Registration for an Industrial Solid Waste
Management Site. The permit application was submitted January 1972 and contained
the logs of two soil borings drilled to a depth of 40 feet below ground level.
The borings indicated a surficial clay layer approximately 15 feet thick under-
lain by approximately 15 to 20 feet of tan silty, clayey sand. The early
permit did not contain any ground-water monitoring or site characterization
requirements, so no further site studies were conducted at this time.
As the site expanded, three additional borings were made in November 1974 to
confirm the initial two borings. While drilling these borings ground water was
encountered at 39 feet below ground surface. Once again, no monitoring wells
were constructed from these borings because of a lack of specific permit requirements.
When the facility again found the need to expand in 1977, four exploratory
soil borings were made to the west of the then active trenches and surface
impoundments. Trinity Testing Laboratories, Inc. conducted the study which
reported a general description of 4.0 feet of dark gray fatty clay; 6.5 to 10.5
feet of tan fatty clay; overlying tan clayey fine sand. Coefficients of permea-
bility for the fine sands underlying the clays could exceed 1 x lO"? cm/sec.
Ground water was encountered at three of the four borings at a depth of 39.0
feet. No monitoring wells were constructed from these borings. Soil tests
from these 4 borings showed subsurface contamination had occured, and the
results were reported to TWC.
Based on the contamination found, between 1977 and 1980, seventy-six
wells and borings were made, during 11 seperate episodes at the facility, in a
progressive manner as based on data retrieved from each previous drilling
episode. Each episode (performed at the request of TWC) of drilling was aimed at
further defining the plume of contamination and the its source. Even though not
performed under any enforceable order, well installation and subsequent studies
were designed at developing a corrective action for the contamination plume.
60
-------
TWC instructed TECO to install five ground-water monitoring wells around
the active portion of the site after being notified of the subsurface contamination
found in the soil borings. This initial set of wells, called the D series,
were dry and were soon replaced with five new wells during November 1977.
Ground-water monitoring wells W-l through W-c were installed in the northeast
section of the facility, north of the then active surface impoundments, ponds
#1 through 4.
These wells were constructed with 4 inch PVC pipe. Type of coupling used
was not recorded on the well construction logs, therefore they could have been
threaded or glued. A PVC cap was shown to be in place at the base and top
of the well. Five feet of screen is at the bottom of the well,(screen size is
also unknown). A coarse grade filter sand was used as a packing from the
base of the screen to the upper clay, ranging from 29 to 35 feet. Overlying
the sand pack was a two-foot clay seal, followed by 11 to 13 feet of concrete
grout. A 4'x4'x6" concrete apron was poured around the well surface. Initial
testing of these first four wells found high concentrations of TOC in wells
W-3 and W-4, as compared to background values for the area.
As a result of the elevated TOC found in the wells W-3 and W-4, TWC
requested further study of the contamination, which included further soil
borings, monitoring wells and confirmatory sampling. During the period between
December 1977 and June 1978, TECO conducted an additional ten soil borings and
installed nine new monitoring wells north of the surface impoundments.
Samples from all of these borings except three had an amber color and an
"organic" odor. Monitoring wells B-l, B-2, and B-3 were installed in February
1978. Wells B-l and B-2 were reported to be dry and well B-3 showed no contamination,
The lithologic logs for these wells were not available, only a very general
construction diagram was provided. Confirmatory sampling was conducted in
February 1978 and again in June 1978. Elevated levels of TOC were once again
found in wells W-3 and W-4, with W-4 having a high of 8,330 ppm. This initial
study of the contamination indentified surface impoundment pond #2 as the
most likely source of contamination.
61
-------
Some of the borings were coverted to wells in April - May 1978 (i.e.,
W-6, W-7, and W-10 through W-13). These wells were placed to monitor the
ground water west of the impoundments and upgradient of any active trenches.
The wells are constructed in a similar manner as the earlier V series
wells, using 4-inch PVC casing with 5-feet of slotted screen at the base. The
major difference is the coarse-grade filter sand extends past the in-situ sand
into the upper clays, whereas the earlier W series wells indicated a clay
seal was placed at the contact. A situation like this will allow soil particles to
easily migrate through the sand packing and cause siltation in the' well, in
contradition to 40 CFR 265.91 (c).
Following the installation of these new wells and the confirmatory sampling
it was decided by TWC that a ground-water recovery program should be initiated.
A pump was installed in well W-4 in June 1978. Prior to this point all
monitoring well activity had been aimed at characterizing the contanination
plume. Following the initiation of pumping TOC decreased from 8,000 ppm to
6000 ppm.
Wells W-4A, W-48, and W-4C were installed in August 1978, north of W-4.
No lithologic logs or well-specific construction diagrams were available, only
a general well construction diagram was presented. All three of these wells
are in the contamination plume.
During April 1979 seventeen exploratory borings were made in the
area north of the ponds to determine the northern boundary of the contamination
plume and to characterize the northern lithologies. No monitoring wells were
constructed as a result of these borings.
Based on the findings of the seventeen exploratory borings, the X
and P series monitoring wells were installed". Wells X-l through X-4, P -1
through P6, and P-8 through P-15 were installed May 1979. Well P-7 was comp-
leted July 1979. No lithologic logs were presented for these wells and the
well completion diagrams that were submitted are very general and do not provide
good detail.
62
-------
The wells were apparently constructed using 4-inch PVC pipe with the
screen covering the entire thickness of the First Sand. Neither the type of packing
used around the screen nor the screen size was specified. Above the screen are
two "packers" of unspecified type. These packers were apparently placed at the
sand/clay contact. Immediately above the packers the well was ;routed with
bentonite pellets. The type of grouting used above the pellets is also not
specified. Notes from the Task Force field inspection do indicate a 4'x4'x6"
apron around most of these wells.
The lateral extent of the contamination plume had been fairly well
established by August 1979, and it .-was decided by TWC that a more extensive
ground-water recovery system was needed. Pumps were installed at wells X-l
and X-3, within the plume boundary, in addition to well W-4. During November-
December 1979 wells P-7A, P-11A, P-12A, X-1A, X-5, and X-6 were installed.
The construction diagrams shows 4-inch PVC casings were installed with 15 feet
of 8 gauge well screen. The screen was set at the base of the first sand/second
clay contact. Filter sand (-40 + 60 screen) was used as a packing around the
screen plus 2 feet above. The sand packing was followed with bentonite pellets
then concrete grout to the surface. The lithologic logs have very general
descriptions but do indicate the same clay-sand-clay sequence as was detected
in earlier wells. Correspondence from the drilling company indicates that
drilling fluid was used to advance these holes, which could have affected
early well recharge and analytical results, if not developed adequately prior
to sampling. This could have also chemically biased early sampling results.
Soon after their installation, wells X-1A and X-6 were also placed on line
as part of the recovery system to improve ground-water recovery.
Well W-17 was constructed April 1980, in an attempt to delineate the
southern extent of the contamination plume. Lithologic logs were available, but
no construction log for the well could be found.
63
-------
Monitoring well X-2A was installed June 1980 adjacent to X-2. Being
constructed approximately 6 feet deeper,its base is set in clay rather than
silty sand as with X-2.
The E-series wells (E-l through E-11) were installed in October 1980.
Wells E-2 through E-10 were positioned across the north end of the site between
the known contaminated wells (W-4 series) and the ponds. E-ll was placed at
Pond #2 northeast corner and E-l was placed approximately 150 feet north of the
line of wells (E-2 through 10).
Each well was constructed of 4-inch O.D. schedule 80, threaded, PVC pipe and
15 feet of 4-inch O.D. schedule 80, threaded PVC, pipe with 0.015-inch slotted
openings as the screen. Clemtex No. 2 sand was used to pack the well from the
bottom to the base of the first clay. The remainder of the well was grouted
with-bentonite pellets (one foot) then cemented. Odors and the appearance of water
were noted on the logs. There is no evidence that a comparative grain size
t
analysis was tonducted between the native soils, sand pack, and screen slots.
Wells OB-2 and OB-3 were installed in December 1980. These two wells
were slightly deeper than the earlier wells and are located along the northern
property boundary. The same construction materials were used for this well as
for the early E series wells. The major difference is that the screen and sand
packing extends the entire length of the first sand (approximately 45 ft).
Compliance Agreement Monitoring:
A Compliance Agreement was issued to TECO for review, in December 1980.
This was revised, and a new Compliance Agreement was issued on February 9,
1981 and signed by TECO on February 26, 1981. (Attachment B ) The Agreement
addressed the following four items:
1) An accelerated ground-water recovery program.
2) Specifications for new pond construction and facility certification.
3) "Deep Zone" ground-water monitoring.
64
-------
4) Additional subsurface investigations in the area of trenches 1-14. *
Between April and June 1981, thirty ground-water monitoring wells were
installed. Twenty-three were shallow (50.6-feet depth average) and seven were
deep (100-feet each).
The shallow monitoring wells constructed at this time were wells E-12
through E-34. Seventeen of these wells were equipped with recovery pumps -and
added to the system as directed in the Compliance Agreement. The lithologic
logs and construction diagrams are very generalized and do not indicate
specific construction details. No construction diagrams are available for
the deep wells. **
Contamination was detected in monitoring well W-17,in 1981. W-17 was
thought to be south and outside of the contamination plume, therefore, when
contamination appeared in ground-water data an assessment of the cause was
ordered by TWC, May 1982. This assessment was in addition to the regular
monitoring and subsurface investigations outlined in the February 81 Complaince
Agreement. Monitoring wells W-18 through W-21 are a result of this assessment,
(results of this assessment are discussed further in this chapter).
Wells W-18 through W-21 were installed to monitor the first sand, or upper
aquifer, with their base depth being the top of the second clay. The wells
were constructed of 4-inch I.P., schedule 40,threaded PVC pipe with a screen of
4-inch I.D., schedule 40 PVC, and .020 inch slotted openings. Fifteen feet of
screen with a sand filter pack constitute the bottom portion of the well. The
sand filter appears to extend approximately 5 feet above the screen portion.
Overlying the the filter sand is one foot of bentonite pellets and above the
pellets to the ground surface is a cement-bentonite grout. No specifications
were available for the cement bentonite grout.
* Construction details of the new pond are discussed earlier under the section on
Waste Management Units. This section discusses the item from the agreement or
events directly resulting from it pertaining to ground water.
** It should be noted that the history of wells given in the closure plan
states these wells were installed August 1981. However, the lithologic logs
indicate April-June 1981.
65
-------
Wells E-44 through E-49 were installed February 1983. The wells have 10
feet of screen, but other than that they are identical in construction to wells
W 18-21. These wells were the last to be installed as part of the recovery/
corrective action program as established under the February 1981 Compliance
Agreement.
Six exploratory borings were made of the old Mixing Basin or Trench 17/18
area in March 1983. No wells were developed from these borings. These borings
were part of the 1982 assessment phase for contamination detected in W-17.
Monitoring well P-16 was installed May 1983. No construction log was
available.
The last two borings or wells to be made at the site are wells W-14 and
001. W 14 was installed to replace dry well W-13 and 001 was installed to
replace well P-3 which had been destroyed.
Design of the wells encountered at TECO are not in adherance of 40 CFR
265.91-(c)
As of February 1986 the recovery and compliance monitoring system as
proposed in the TECO Compliance Plan, consisted of the following network of
wells (the below listed designations of wells are not those proposed by TECO
for the final permit:
Recovery Wells
Background well
E-9
W-4
E-7
E-6A
X-1A
X-5
E-20
E-18
E-17
E-l
E-16
X-2A
X-3
E-15 '
E-13
E-12
P-ll
E-19
W-17
FD-2
P-7
Plume Characterization Wells
E-33 FD-2 W-4A
66
-------
Monitoring Wells Monitoring Wells
(Outside Area of Contamination) (Inside Area of Contamination)
E-34 E-25
W-3 W-20
X-6 E-4
W-4A W-4B
W-4C E-ll
E-31
Compliance Point Wells
E-5 W-5
E-2 E-ll
E-22
E-32
E-23
E-22
E-10
P-12
P-13
E-39
E-40
E-35
E-37
E-2
E-24
W-19
W-18
W-21
Deep Wells
E-41
E-42
E-36
E-38
All compliance point, background, deep wells, wells outside, and wells
inside the plume arc sampled on a monthly basis for pH, chemical oxygen demand,
total organic carbon, specific .conductivity, water level, odor, and appearance
with the exception of the recovery wells. Attachment E is an example of several
monthly and yearly reports that were submitted by TECO to TWC. Recovery wells
are sampled for these same parameters on a quarterly basis due to the difficulty
in removing and replacing the pump systems. A more detailed analysis of the quality
of the data is included later in the report.
67
-------
Table 7
List of Wells and Borings
ID NO.
1
2
3
4
5
D-l
D-2
D-3
D-4
D-5
W-l
W-2
W-3
W-4
W-5
B-l
B-2
B-3
W-6"
W-7
W-10
W-ll
W-12
W-4A
W-4B
W-4C
W-13
X-l
X-2
X-3
X-4
1
2
3
4
5
6
7
8
9
10
11
12
13
Date
Installed
'71
'71
11-13-74
11-13-74
11-13-74
77
77
77
77
77
11-10-77
11-10-77
11-10-77
11-9-77
11-11-77
2-20-78
2-20-78
2-20-78
4-6-78
4-6-78
5-2-78
5-2-78
5-5-78
8-24-78
8-24-78
8-24-78
5-5-78
5-9-79
5-9-79
5-8-79
5-9-79
4-13-79
4-19-79
4-19-79
. 4-19-79
4-20-79
4-20-79
4-20-79
4-23-79
4-23-79
4-24-79
4-24-79
4-24-79
4-25-79
Surface
Elevation
65.51
64.61
66.55
68.51
66.11
67.5
66.7
64.31
65.01
65.51
64.91
64.91
67.21
67.31
67.21
65.21
67.01
67.21
67.61
67.31
Total
Depth
40
40
45.5
45.0
50.5
61.0
55.5
40.1
.40.0
'40.0
55.0
55.0
47.3
44.9
44.9
35.0
35.0
35.0
55.2
41.0
46.0
46.0
42.0
55.0
50.5
50.5
50.5
50.5
35.5
50.0
50.0
50.0
50.5
35.5
50.5
45.5
Depth
to
Screen
No logs
No logs
No logs
No logs
No logs
No logs
No logs
37.2
38.4
41.1
45.4
48.6
34.9
35.4
unknown
unknown
unknown
unknown
unknown
29.0
29.0
29.0
unknown
14.0
13.0
14.0
14.0
Depth
to
Sand Pack
or Data
or Data
or Data
or Data
or Data
or Data
or Data
' 13.0
14.0
13.5
15.0
12.51
3.0
3.0
•8.0
7.0
8.0
8.5
8.0
unknown
unknown
unknown
unknown
15.0
14.0
15.0
15.0
Depthe to
water
Encountered
27.34
35.67
32.70
35.89
33.96
39.20
38.90
29.98
34.63
35.08-
34.36
33.51
8.0
8.0
8.0
34.2
34.0
37.0
46.0
30.0
35.0
37.0
33.0
35.0
Comments
Test Boring
Test Boring
Test Boring
Test Boring
Test Boring
Dry
Dry
Dry
Dry
Dry
Recovery
Well
Complaince
Point
Destroyed
!
Recovery
Well
Test Boring
Test Boring
Test Boring
Test Boring
Test Boring
Test Boring
Test Boring
Test Boring
Test Boring
Test Boring
Test Boring
Test Boring
33.0 |Test Boring
1 1
-------
Table 7 (continued)
ID NO.
14
15
16
17
P-l
P-2
P-3
P-4
P-5
P-6
P-8
P-9
P-10
P-ll
P-12
P-13
P-14
P-15
P-7
P-7A
P-11A
P-12A
X-1A
X-5
X-6
C-l
C-2
C-3
C-4
W-17
X-2A
E-l
E-2
E-3
E-4
E-5
E-6
E-7
E-8
E-9
E-10
E-ll
Date
Installed
4-25-79
4-26-79
4-26-79
4-26-79
5-9-79
5-21-79
5-21-79
5-21-79
5-21-79
5-2-79
5-2-79
5-2-79
5-2-79
5-8-79
5-9-79
5-9-79
5-8-79
5-8-79
7-19-79
11-30-79
11-30-79
11-29-79
11-29-79
11-30-79
11-29-79
1-2-80
1-2-80
1-2-80
1-2-80
4- -80
6-4-80
10-8-81
10-2-81
10-2-81
10-2-81
• 10-1-81
10-3-80
10-7-80
10-7-80
10-7-80
10-6-80
10-3-80
Surface
Elevation
. 64.61 .
63.21
64.11
62.91
62.91
65.81
68.81
66.91
67.21
67.21
67.51
67.11
65.31
62.91
62.7
67.5
67.8
66.5
67.1
71.0
67.6
66.95
66.90
71.4
70.6
70.4
70.2
70.3
67.4
67.3
67.5
67.4
70.1
Total
Depth
45.5
45.5
45.5
45.5
44.0
44.0
44.0
45.0
46.0
42.0
45.0
42.0
46.0
42.0
38.0
43.0
44.0
45.0
49.0
37.0
48.0
47.0
51.5
42.0
50.0
25.5
25.5
25.5
25.5
48.0
52.5
44.0
50.0
51.0
50.0
- 47.0
50.0
47.0
39.5
45.0
50.0
45.0
Depth
to
Screen
18.0
12.0
13.0
12.0
12.0
12.0
14.0
14.0
14.0
15.0
16.0
14.0
14.0
12.0
7.0
22.0
33.0
32.0
46.0
27.0
35.0
31.0
35.0
29.0
35.0
36.0
35.0
34.0
35.0
32.0
25.0
30.0
25.0
30.0
Depth
to
Sand Pack
19.0
13.0
14.0
13.0
13.0
13.0
15.0
15.0
15.0
16.0
17.0
15.0
15.0
13.0
8.0
20.0
31.0
30.0
44.0
25.0
33.0
29.0
33.0
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
Depth to
Water
Encountered
34.0
37.0
a
Comments
Test Boring
Test Boring
Test Boring
Background
Well
Recovery
Well
Recovery
Well
Test Boring
Test Boring
Test Boring
Test Boring
Recovery
Well
Recovery
Well
Recovery
Well
Compl iance
Point
Compl iance
Poi nt
Recovery
Well
Recovery
Well
| Compliance
| Point
1
-------
Table 7 (continued)
ID NO.
W-8
W-9
OB-2
OB-3
E-12
E-13
E-14
E-15
E-16
E-17
E-18
E-19
E-20
E-21
E-22
E-23
E-24
E-25
E-26
E-27
E-28
E-29
E-30
E-31
E-32
E-33
E-34
W-18
W-19
W-20
W-21
E-44
E-45
E-46
E-47
E-48
E-49
Date
Installed
4-6-78
4-7-78
12-11-80
12-10-80
4-6-81
4-7-81
4-8-81
4-8-81
4-9-81
4-9-81
4-9-81
4-7-81
4-10-81
4-10-81
6-19-81
6-21-81
6-15-81
6-16-81
6-18-81
6-18-81
6-22-81
6-23-81
6-24-81
6-13-81
6-18-81
6-16-81
6-15-81
9-28-82
10-1-82
9-29-82
9-30-82
2-29-83
2-27-83
2-23-83
2-22-83
2-22-83
2-23-83
Surface
Elevation
67.6
67.3
67.1
66.8
66.9
66.9
67.2
67.2
67.1
66.9
67.0
69.4
70.1
68.7
69.4
68.6
69.6
71.8
72.0
72.0
71.8
71.4
68.8
68.0
66.0
68.0
Total
Depth
80.0
69.5
55.0
64.5
55.0
55.0
52.0
52.0
52.5
54.5
47.0
55.5
47.5
42.0
45.0
45.0
45.0
45.0
50.0
45.0
45.0
45.0
45.0
50.0
45.0
45.5
50.5
41.2
39.0
45.0
44.3
44.0
43.0
45.0
45.0
44.5
45.0
Depth
to
Screen
10
10
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
26.2
24.0
30.0
29.3
34.0
33.0
35.0
34.0
34.5
35.0
Depth
to
Sand Pack
10
10
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
unknown
24.0
22.0
28.0
27.0
32.0
33.0
33.0
32.0
32.5
33.0
Depth to
Water
Encountered
40.0
39.0
29.1'
31.0'
35.5
35.5
36.5
36.5
37.5
36.5
Comments
Boring
Boring
Recovery
well
Recovery
Well •
Recovery
Well
Recovery
Well
Recoveery
Well
Recovery
Well
Recovery
Well
Compliance
Point
Well
Destroyed
Well
Destroyed
Well
Destroyed
-------
Table 7 (continued)
ID NO.
W-14
001
W-.5
W-16
E-35
E-36
E-37
E-38
E-39
E-40
E-41
E-3A
E-6A '
E-42
E-43
P-16
SB-1
SB-2
SB-3
SB-4
SB-5
SB-6
R-l
R-2
R-3
R-4
R-5
R-6
R-7
R-8
R-9
R-10
R-ll
R-12
TB-1
TB-2
TB-3
TB-4
E6A
FD2
FD1
Date
Installed
7-22-85
1-1-85
2-5-80
2-5-80
5-19-81
5-11-81
5-28-81
5-21-81
6-13-81
6-8-81
5-21-81
3-10-83
3-15-83
5-20-82
3-17-33
3-18-83
3-21-83
\
3-22-83
3-24-83
6-6-81
6-7-81
6-6-81
6-6-81
Surface
Elevation
unknown
unknown
6°. 7
63.1
66.6
63.4
62.7
62.7
67.2
65.4
67.6
70.7
70.3
Total
Depth
45.0
45.0
50.5
50.5
100.0
100.0
100.0
101.0
100.0
100.0
100.0
75
74.5
40.0
45.0
45.0
45.0
45.0
45.0
40.0
21.5
24.5
23.5
23.5
Depth
to
Screen
unknown
unknown
33.0
30.5
unknown
unknown
unknown
unknown
unknown
unknown
unknown
20.0
No logs or data
Depth
to
Sand Pack
unknown
unknown
21.0
28.5
unknown
unknown
unknown
unknown
unknown
unknown
unknown
Chemical
Odor
Chemical
Odor
Chemical
Odor
Chemical
Odor
Chemical
Odor
Chemical
Odor
French Drain Risers
French Drain Risers
Depth to
Water
Encountered
33. 0'
36.0'
36. 0'
36.0'
1 1
1 1
Comments
Test Boring
Test Boring
Test Boring
Test Boring!
Test Boring
Test Boring
Recharge
Well
n
n
n
ii
n
n
n
ii
ii
n
Test Boring
Test Boring
Test Boring
Recovery
Well
Recovery
Well
Recovery
Well
-------
Special Studies:
A Gamma Ray Log Study was conducted during January 1980 of Trenches 1
through 14. Because very little information was retained during
the construction of these trenches, TWC requested the study to determine the
types of underlying soils, the depth of the trenches., and their total volumes.
Four core holes were drilled in the undisturbed sediments outside the
landfill trench limits of the landfill trenches at the northeast (C-4), northwest (C-l)
southeast (C-3), and southwest (C-2) corners. Fourteen "trench holes", TR-1
through TR-14 were made, in the trenchs themselves.
Lithologic and moisture content logs were presented of the core holes with
their gamma ray logs. All four core holes showed clays and sandy clays (moisture
content 16-22%) down to 13 to 17 feet. This was underlain by a silty sand
(moisture content 3-8%) that was encountered'through the total depth. Core
hole C-3 did show a slightly more gradual change from a sandy clay (20% M.C.)
to c.lay sand (11-12% M.C.), then silty sand (5%). These core holes were later
cased with 8 inch steel casing and are now being used as leachate collection
points.
The gamma ray logs for most of the trenches show a clay at the bottom
of the trench. However, gamma ray logs for trenches 1, 4, 6, and 11 all showed
sandy clays at the bottom. The cover letter to the report states that this
sandy clay is impermeable. This is highly unlikely as a comparison of the
moisture content percentages would indicate a more permeable material than the
clay above. Therefore, these four trenches could be a source of possible
releases to the ground water due to the sandy clay bottom.
Another special study was the 1982-83 Assessment of Contamination detected in
Monitoring Hell W-17. Early in 1982, TWC requested TECO to initiate a "Ground-
water Quality Assessment Plan" to identify the source of contamination detected
in well W-17. TECO submitted the plan on July 21, 1982 and on August 9,1982 it
was approved by TWC. The Assessment Plan consisted of two phases. Phase I
involved installation of four new wells around W-17. Phase II involved 1) gas
72
-------
chromatography/mass spectrometry (GC/MS) of the W-17 contamination with that
found in the northern end of the site, 2) analysis and (GC/MS) of liquid found
in trenches 1-14 sumps, and 3) analysis of ground-water velocity in the
vicinity of W-17.
TECO reported to TWC by December 1982 that the source of contamination was
not ponds 1, 2, 3 or 4 as with the plume of contamination in the north. They
had determined ttvat the contamination came from trench 17/18, the old mixing
basin. As described in the section on waste management units the old mixing
basin was an open trench where bulk liquids were pre-mixed with on-site silty
sand using a backhoe. The trench was unlined with only in situ clay as a base.
Phase I of the assessment determined that given the reach of the backhoe and
the depth of the in situ clay, the clay could easily have.been breached in
several places. Furthermore, during the time of operation when the silty sand
was being used as an absorbant, sand could have been mixed with liquids beyond
the field capacity.
TECO met with TWC to discuss the final results of the W-17 assessment a'nd
corrective action alternatives. The final determination was that the old
mixing basin was the source of the contamination found in W-17 as proven by various
tests and samples. The corrective action mutually agreed upon was to leave the
waste in place and to upgrade the cap. The reasoning for this was that TECO
felt that fluid migration from the old mixing basin had run its course and
presented minimal future impact to ground water. No data of this fact
was located in any file review. As a result of this assessment, monitoring
well W-17 was equipped with a pump and incorporated with the other recovery
wells.
Due to inconclusive data presented in the 1980 Gamma Ray Study, TWC requested
in the 1981 Compliance Agreement for TECO to prepare a report indicating
whether or not landfill trenches 1 through 14 Inclusive are underlain by a
minimum of 3 ft of clay rich soil below the bottoms of the trenches as determined
in the Gamma Ray Log Study.
73
-------
The Compliance Agreement specified that the program be composed of four soil
borings sampled for soil specimens and laboratory testing for physical properties.
This study was to be completed 120 days after February 26, 1981 or by June 25
1981. The borings were completed on time and logs were submitted with the June
25, 1981 ground-water recovery report. However, the formal report was not
submitted until March 1982.
The four soil test borings varied in depth from 21.5 to 24.5 feet. Clay
material was encountered to 3.5 ft in depth. This reflects.fill material
and the cap. Below this clay cap the boring encountered natural sandy clay and
moderate plasticity clay. Below this clay was a very dense, silty, fine sand.
Borings were terminated at this point after it was determined that these sands
correlated with others encountered on site.
Compared to the Gamma Ray Log Study this second study showed in situ clay
below trenches 1 through 10, with possibly less than 3 feet below trenches 4, 8, 9,
and 10. Figure 6, 7, and 8 are drawings from the report showing a cross section
of the trenchs and the relationship between the depth of the excation and the
base of clay.
74
-------
UD
C
-I
o
o
to
rt)
o
PLAN VIEW
OT»-«
o
3
ro
(D
3
O
3-
rc
OJ
oo
j
V*4 tn tvn •»
na'.r <•' ( i nt
-------
Y
O
Note •• Reduced
FIGUPE-I
Figure 7 Cross Section and Planar View of Trenches 1,2,3,4,5,7,
8,9,10,11, and 12
-------
UJ
Note: Reduced drawing
FIGURE-3
Figure 8 Cross Section and Planar Viwe of Trenches 6, 13, and 14
-------
GROUND-HATER RECOVERY SYSTEM
The preceeding section dealt with the ground-water monitoring program, and
the evolution of the monitoring system into a ground-water recovery and
compliance monitoring system. These elements constitute a corrective action
program as currently foiljwed per the Compliant Agreement. This section
will briefly describe specific aspects of the recovery system and how
effectively it is working.
The recovery system at TECO was designed to: (1) recover contaminated ground
water in the upper aquifer; (2) form a cone of depression that would impede
any further movement of contamination; (3) form a recharge mound north
(downgradient) of the plume in the upper aquifer that would prevent the migration of
contaminants off site; and (4) treat recovered ground water which is discharged
into an evaporation pond.
The system has three key components as follows:
1. A 500-foot Trench Drain
2.' Twenty recovery wells and twenty-six monitoring wells
3. Twelve recharge wells/pits
Ground-water recovery began in June 1978 with the installation of a
submersible pump in monitoring well W-4. Soon after pumping began the TOC
value dropped to 6,000 ppm which was still high for the area, but it did
show that ground-water recovery was feasible. Through mutual agrement
between TWC and TECO it was decided that further ground-water recovery was
necessary so as to form a cone of depression that would retard the movement
of the plume of contamination. Therefore, in August 1979 pumps were installed
in wells X-l and X-3 to provide better recovery. Still the plume was not
decreasing in size at a rate satisfactory with TWC and two more pumps were
added in wells X-1A and X-6.
78
-------
The ground-water recovery program was initially conducted by informal
agreements between TECO and TWC. However, there was no definitive evidence
that adequate recovery was taking place. Therefore, on April 3, 1980 the
Executive Director of the Texas Water Commission instructed TECO to implement
and maintain the facilities as set forth in their corrective action plan,
until such time as all contaminated ground water was recovered and properly
treated. This was the first formal instruction from TWC to TECO for any
corrective action or ground-water recovery program.
TECO was also required by the April 3,1980 Directive to submit a monthly
progress report on the recovery project to the state which contained:
a. The total volume of ground water recovered during the preceeding
month;
b. Analysis of samples from all recovery and ground-water monitoring
wells surrounding the contaminated area. These analyses at a
minimum would report total organic carbon, chemical oxygen demand,
specific conductivity, and pH;
c. Water level measurements accurate to + or - 0.1 feet from all
recovery and ground-water monitoring wells at the facility,
reported in above mean sea level;
d. Water level measurements shown on a potentiometric map of the
shallow contaminated zone.
TECO was also notified that their progress in completing the recovery project,
as reflected by the concentration of contaminants in the recovered ground water
and the surrounding monitor wells, was to be reviewed seniannually, and if
remediation was not reflected by the date submitted, the state would require
additional measures to recover the contaminated ground water.
79
-------
TECO (as a result of this directive) retained Law Engineering Testing Co.,
Houston, TX to develop an effective long-term ground-water recovery system.
Law submitted a report that recommended 34 wells to be pumped to cause a
cone of depression within the identified plum" so as to stop the spread.
It further recommended a ground-water recovery rate of 1,000,000 t~ 5,000,000
gallons per year.
The need for formal action was realized by TWC_and a draft compliance
agreement was negotiated and signed by both TWC and TECO on February 26,1981.
As a result of this compliance agreement additional wells were installed
and activated as recovery wells. TWC reevaluated the system in
December 1981 to determine if it was performing as anticipated. It was
determined that ground-water contours were being affected, but not enough to
form the needed cone of depression.
During 1981, the system pumped slightly under 1,000,000 gallons in the
first six months operating only during normal working hours, (Monday through
Friday, Sam to 5pm). It was determined that the yield of-the saturated
zone was too low for the continous pumping needed to form a cone of depression.
Therefore, TECO proposed in March 1982 modifications to the recovery '
system that would induce a larger cone of depression and an increased recovery
rate. The modifications included a trench drain, changing the recovery
pumps to eductor pumps, and installing recharge pits north of the plume.
The trench drain was installed in stages during June and August 1982,
eductors were added in March 1983, and the recharge pits installed in mid-
1985. All system components were activated as they were completed.
,A review of the overall system has found the plan, construction, and
maintenance to be satisfactory. One aspect which will keep it from achieving
its full potential however, is the lack of storage space for the treated
water. Because the current treatment system is not able to remove contaminants
from the ground water to the level that meets TWC specifications the water is
diverted to Pond 26 rather tha reinjected into the recharge pits north of the
plume.
80
-------
Trench Drain:
A Trench Drain (referred to as a French Drain in all TECO reports and
correspondance) was installed along the long axis of the contaminant plume
in .he area of the-old surface impoundment ponds 2, 3, and 4, ( also known
as trench 19). The trench drain consists of a 4 x 4 foot gravel drain
surrounded by a geotextile fabric with a primary sump (FD-2) at the north,
or downgradient end, and an alternate sump (FD-1) at the south, or upgradient
end, (Figure 9), and is approximately 500 ft long. Data and potentiometric
contour maps support the evidence that the trench drain is functioning as
desired.
Recovery Well System:
Eighteen eductor and two sumersible pump equipped wells located within
the plume of contamination form the recovery well system. Wells with the
highest levels of TOC were selected to be equipped with eductors. Four of
the five original eductor wells (X-5, W-4, E-9,-and E-20) are still in the
system. E-10, the fifth well, was deactivated because the TOC level dropped
to 11 mg/1. Nine wells that originally had submersible pumps were equipped
with educators (X-1A, X-2A, E-7, E-6A, E-19, E-18, E-17, E-16, and E-15).
Five monitoring wells were also added to the system (E-l, E-13, E-12, X-3,
and P-ll) Figures 11 illustrates a cross section of an eductor well.
Two recovery wells are still maintained with submersible pumps (FD-2
and W-17). FD-2 is actually not a monitoring well, but a sump riser for the
Trench Drain.
Figure 10 illustrates the eductor recovery well system.. Simply described,
water is pumped from wells i.n the contamination plume to an 80,000 gallon
storage tank, treated in the water treatment system, then finally sent to
the evaporation pond (pond 26).
The current recovery well system is focused on the recovery of the known
81
-------
ALTERNATE
RECOVERY
WELL
RECOVERY
WELL
UNDERLYING CLAY (AQUICLUOE)
FILTER FABRIC
OPEN GRADED GRAVEL
SECTION A-A
Figure 9
MUNCH INIAIN INSTALLATION
(NOT TO SCALE)
Cross Section of Trench Drain installed at TECO facility
From: December 1985, TECO Ground-Water Compliance Flan, Vol. II, Section 9-1
-------
SUPPLY
WELL HEAD SEAL
WELL CASE
EDUCTOR BODY
TREATMENT SYSTEM
EQUALIZATION BASIN
60,000 ^ALT/™
Q
STORAGE
EDUCTOR SYSTEM DETAIL
RETURN
GRADE
Figure 10 Eductor System Detail
From: December 1985, TECO Compliance Plan, Vol. I, Section 3-4
-------
RETURN' HEADER
SUPPLY HEADER
SCREEN
WELL CAS INS
A!O SCREEN
EDDY
r FCOT VALVE
TYPJCAL TWO PIPE EDUCTOR
Figure 11 Cross Section of Typical Eductor Pump
From: December 1985, TECO Compliance Plan, Vol. I, Section 3-4
-------
TOC plume of contamination. Appendix VIII constituents identified within
this area and elsewhere on site (discussed later in this report) indicate a
need for an expanded recovery system and and assessment of a plume of cont-
amination based on Appendix VIII constituents.
Recharge System:
The recharge system is designed to form a ground-water mound in the upper
aquifer that will reverse the natural ground-water gradient and impede
plume migration off the TECO property. Twelve recharge pits have been
installed north of the contamination plume for this purpose.
Each recharge pit consists of a 12 x 12 foot trench dug into the upper
sand below the surficial clay. An 8-inch PVC pipe which is slotted at the
base is placed in the center of each trench. The trench is lined with a
geotextile fabric to prevent siltation. Surrounding the slotted pipe the
pit is filled with gravel. A surficial cap of compacted clay is designed to
prevent the entrance of surface water. A constant recharge is provided by
a manifold system from a central storage tank, (figure 10 and 11). The
TECO Compliance Plan Application specifies for recovered ground water from
the treatment plant to be used for injection. Presently water from the
treatment plant does not meet acceptable levels for injection. These
levels have been set at Primary Drinking Water Standards.
Most potentiometric maps produced by TECO (Attachment E) have shown a
positive change in ground-water contours since early 1985 when the full
system began operation. Thus indicating that a recharge mound has been
formed along the downgradient edge of the contamination plume.
Even though the recharge system does appear to be affective some concerns
still remain. The Task Force has questioned whether pumping of the deep
sand at E-40 will induce contaminants to migrate vertically from the
surficial aquifer.
85
-------
b
j
so
To
COMPACTED
CLAY
«»
, ^ ff CrtJ AT\
— D O'wO. *fv
PVC
V
To
GRAVEL
CLAY
.SAND
^FILTER FABRIC
Recharge pits are to be constructed as follows:
(a) A pit three (3) feet wide and twelve (12)
feet long is to be constructed to below
the surficial clay (approximately 17 feet);
(b) Drainage fabric should be placed in the
bottom of the pit;
(c) An eight (8) inch schedule 40 PVC PIPE
should be placed in the center of the pit;
(d) The last three feet of the pipe should be
•lotted;
(e) Gravel backfill to three (3) feet deep;
'(f) Cover with drainage fabric;
(g) Backfill remaining hole with clay (compacted)
Figure 13 Cross Section of Recharge Wells (Pits)
From: December 1985, TECO Ground-Water
Compliance Plan, Vol. II, Section 5-1
Description
JtVISJONS
EXISTING
RECHARGE PITS
D«t«:
12/16/85
Sc*le:
N.T.S.
[^Ecology
US Ecology, Inc.
•200 Shelbyville Road
Suite 3)9
UxjJlVillt, ICY 40222
I Dr
-------
E-40
Rll RIO R9
E-19
E-39
T
900 GAL. TANK
PLAN
500 GAL. TANK
FUDAT SWITCH
LINE
REINJECTION PIT
ELEVATION
Figure 12 Recharge Wells (Pits)
From: December 1985, TECO Ground-
Water Compliance Plan, Vol. II,
Section 5-1
Desrnnt ion
bv A-rrovi]
REVISIONS
EXISTING
RECHARGE PITS
Drawn By:
Checked »f.
12/16/85
US Ecology, Inc.
9200 SheJtyvjJlt f)o«d
Suite 319
U>ultvillt. KY 4022;
-------
TECO SAMPLE COLLECTION AND HANDLING PROCEDURES
An important portion of any ground-water monitoring program
is how en owner/operator collects, handles, ships, and analyzes water
samples. Field and laborato.y methods used can easily affect sample analyses
and poor methodologies could alter the true picture of the quality of the
ground water beneath a facility.
The Task Force reviewed the sampling manual from the Part B application
submitted by TECO, procedures described in their ground-water compliance
plan, and observed techniques used by the field and laboratory technicians.
Due to the length and detail of the written sampling plan only the major
points and areas of deficiency will be covered.
Sampling:
During the inspection,.samples were collected from 22 monitoring wells
and 3 leachate collection sumps for analysis by EPA contractor laboratories
as described in the section on Investigation Methods. Splits for all
samples collected were provided for TECO and selected split samples were
provided for TWC.
TECO sampling and laboratory personnel receive on-the-job training by
the Safety Coordinator who oversees sampling operations. The TECO sampling
team is comprised of an "Environmental Well Technician" and one of two
laboratory technicians who assist in in situ testing and sample packaging.
Through observations and questioning of TECO personnel ,it was observed that
there were some differences between written and actual sampling procedures.
The procedures are as follows:
1. The first step is to measure the depth to water using a
weighted steel tape. The tape is decontaminated with distilled
water between wells. It is not clear in the sample plan as to
88
-------
what material the steel tape is constructed, how the tape is
weighted, and how decontaminated. However, distilled water
alone is not sufficient decontamination if hydrocarbons are
suspected.
2. Total depth to bottom of the well is not always measured each
time a sample is collected as indicated in the Sampling Plan.
The volume of water in the casing is determined using the
depth to, water measurement, total well depth, and casing diameter.
The total depth usually is derived from the total casing length
presented in the well construction records.
3. TECO uses dedicated bailers to purge and sample their
shallow ground-water monitoring wells. During the inspection it
was noted that modified four-inch PVC bailers were being used.
The bailers were glue jointed with metal screws and had a PVC
screen extension, for filtering sediment, attached to the bottom
valve. Wells which were not being sampled as part of their _,
monthly monitoring program, do not have dedicated bailers.
PVC bailers of this type are adequate for purging purposes
only. Sampling equipment should be constructed of inert material,
such as Teflon ® (stainless steel, though inert, is not recommended
due to the natural salinity of the upper aquifer) and be constructed
with bottom release valves so as to prevent sample agitiation.
Furthermore, bailers with glued joints should not be left in the
water but instead suspended above the static water level.
Nylon and polyethylene line are being used to raise and lower
the bailer. These materials are not recommended because it may
not be possible to thoroughly decontaminate them, they tend to shred
89
-------
with usage, and the materials may react with ground-water contaminants.
Recommended materials include "Teflon"coated wire, single strand
stainless steel wire, or a monofilament.
4. The purge volume is computed by multiplying the total volume
by three. Three well volumes are removed prior to sampling.
Those wells which have slow recharge rates are normally evacuated
once to dryness. The sampling plan does not define what a low
yielding well is, nor does it give any time span for determining
such.
5. Purge water is collected in 55 and/or 85-gallon drums, then
dumped in Pond 26.
6. Though not observed actually collecting a sample, TECO well and
laboratory technicians were questioned and they explained how the samples
are collected. .
a. The dedicated bailer is lowered into the well using dedicated
line.
b. As the bailer is being removed line is coiled in a
bucket on the ground.
c. The bailer is then emptied by inversion directly into
the sample jars.
d. All sampling containers are filled to overflowing with
volatiles being filled first.
7. Prior to December 1985 all samples were placed in an ice chest
with ice, and then taken to the on-site laboratory for pH,
temperature, and conductivity testing. This was an unacceptable
practice which was changed by the Chemical Safety Officer. The
well technician now takes these measurements at the wellhead.
8. When the well technician collects samples, each bottle is
appropriately labeled, sample appearance and odor noted, and
90
-------
all pertinent well data recorded.
Documentation:
Samples are returned to the on-site laboratory where they are
preserved, and sealed with a U.S.Ecology Custody Seal. Samples to be shipped
to the U.S.Ecology Central Laboratory in Louisville, Kentucky are accompanied
by their own Chain-of-Custody form and a Laboratory Request Form in an ice
chest packed with dry ice and having a custody seal on the ice chest.
Samples to be analyzed at local contract laboratories within
driving distance are preserved and packaged the same way. However, no outside
custody seal is placed on the ice chests because they remain in
the custody of the Environmental Well Technician until they reach the lab.
The Environmental Well Technician and on-site laboratory technician
when interviewed understood the corporate -sampling plan and appeared to be
following the plan. No deficiencies were noted in the procedure for
documentation and handling of the samples.
The maintenance area used for pump/bailer storage was inspected. It was
noted that extra dedicated bailers were stored with line on hooks on the wall.
Submersible pumps were stored upright, and unprotected with their
bottoms on the floor. The maintenance area, though set aside from the other
shop area, is arranged in such a manner that outside contamination could
enter the area, and the area did not appear to be free of dirt and grease.
This practice promotes the cross-contamination of equipment.
The shortcomings noted above could impede TECO from meeting full
compliance with 40 CFR 265.90.
91
-------
TECO SAMPLE ANALYSIS AND DATA QUALITY EVALUATION
This section provides an evaluation of the quality of monitoring data
presented by TECO and their analytical procedures. Analytical procedures
for ground-water samples and data quality were evaluated through laboratory
inspections and the- review of documents containing the required monitoring
data.
TECO utilizes three laboratories on a regular basis: (1) On-site laboratory,
(2) U.S.Ecology Central Corporate Laboratory, Louisville, KT, and (3) Jordon
Laboratory, Corpus Christi, TX,. These laboratories were evaluated for
their operating and analytical procedures, internal data reports, raw data,
and quality control records. Also, key laboratory personnel were interviewed
and analytical equipment inspected.
Other laboratories have been used for special sample analyses such
as Environmental Testing and Certification, (ETC) Edison N.J., and Radian
Laboratories, Austin, TX. ETC performed the July 1985 analysis of Appendix
VIII constituents on four ETC'-environmental monitoring wells the results of
which are in the 1985 Compliance Plan, Volume lit. Radian Laboratories,
Austin, TX performed the analysis of split samples collected during the
Task Force Inspection, and were subject to a laboratory evaluation by the
Task Force.
As of the time of the Task Force Inspection TECO was conducting monthly
monitoring of the compliance point wells, background wells, deep wells,
wells outside and wells inside the plume. As specified in the 1981 Compliance
Agreement, these wells are analyzed monthly for pH, chemical oxygen demand,
total organic carbon and specific conductivity. Due to TECO operating
under the Compliance Agreement and an Alternative Monitoring Program sampling
procedures and parameters as specified under 40 CFR 265.92 have never been
conducted.
92
-------
Four monitoring wells (P-7, W-4A, FD-2, and E-33) were analyzed for
full Appendix VIII constituents in June/July 1985. The resulting data were
presented in the Proposed Compliance Plan. Based on that sample analysis,
p-~ameters for quarterly samp!ing, were selected and proposed in the Compliance
Plan.
Five compliance point monitoring wells and the background well are to be
analyzed quarterly for:
arsenic
phenol
o-cresol
M & P cresol
benzene
methylene chloride
dimethyl phenol
methyl ethyl ketone
iron
toluene
chloroform
nickel
carbon disulfide
chlorobenzene
tetrachloroethylene
1,1,1 tetrachloroethylene
carbon tetrachloride
al urninum
Annually the compliance point and background wells are to be analyzed for all
Appendix VIII constituents to determine whether additional hazardous constituents
are present in the uppermost aquifer.
The proposed quarterly or annual sampling described above will be
conducted once the proposed Compliance Plan and Permit are subjected to
Public Hearing opportunity and has been issued by TWC. This sampling
should commence with the issuance of the permit and approval of the compl-
iance plan application.
93
-------
Laboratory Evaluations:
The purpose of the inspection was to determine the quality of the
self-monitoring program and assess the reliability of the data reported
by the facility for 40 CFR Parts 265.92 and 265.94. The off-site
corporate laboratory, U.S. Ecology Central Laboratory, Louisville,
Kentucky, (USECO) which conducts analyses of ground water for the
Robstown facility was evaluated on August 6, 1986. Samples collected
for analysis under Subpart F Ground-water Monitoring are currently
analyzed by both onsite and off-site laboratories.
The laboratory portion of the inspection included:
0 Reviewing the analytical methods for pH, specific conductance,
total dissolved solids (TDS), total organic carbon (TOC), and
chemical oxygen demand (COD).
0 Determining whether the procedures are followed and reported in
a way that is proper and consistent with 40 CFR Parts 265.92 (a)
and 136, Guidelines Establishing Test Procedures for the Analysis
of Pollutants, Federal Register, October 24, 1984 and June 30,
1986.
0 Reviewing the chain-of-custody procedures.
0 Assessing the sample handling, preservation and holding time
techniques.
0 Reviewing the records for completeness,, accuracy and compliance
with the State and Federal requirements.
0 Evaluating the quality assurance program.
0 Assessing the adequacy of the facilities and equipment.
1. Personnel :
Six analysts are responsible for the RCRA ground-water analyses and
have from one to twenty-one years of analytical experience. Five of
94
-------
the analysts have college degrees and the sixth has twenty-one years
of experience. The analysts appeared to be very competent and
adequately trained to conduct the ground-water monitoring analyses.
2. Facilities and equipment:
The laboratory had ample space which included sufficient bench space
for processing samples; storage space for chemicals and glassware, and
portable instrumentation; and open floor space for large equipment
such as refrigerators and incubators. The laboratory was equipped
with sophisticated instrumentation that could be used for more
complex analyses such as trace metals, cyanides, volatile and
extractable organic compounds. The lab equipment was modern and
appeared to be in excellent working condition.
3. Sample Containers, Preservatives Techniques and Holding Times:
The facility has generally followed the EPA guidelines for sample
containers and preservatives for all parameters since March 1986.
There were some holding time deficiencies for TDS during May and August,
1986. Prior to 1982, TECO used Jordan Laboratories, Corpus Christi,
Texas to conduct the analyses. USECO in 1982 began conducting the
analyses of the indicator parameters as stipulated in the Compliance
Agreement with the Texas Water Commission. Samples that required
preservation, were not preserved, but were shipped via Federal Express
overnight in a cooler with dry ice. Samples for pH analysis were
analyzed on site by TECO, but were conducted off site by USECO from
1982 to January 1, 1986. During the transition phase from January 1986
through March 1986, some sample containers for TOC/COD samples had
wax-paper liners in the caps. If there was any contamination, the data
would be expected to have a positive bias. The corporate laboratory
did not flag these data in the report to TECO or the regulatory agencies,
95
-------
a. pH: Samples for pH analysis from 1982 to January 1986 did not
meet the required holding time.
Regulatory Requirement: The holding time for pH analysis is
fifteen (15) minutes or less. See Table II, Required Containers,
Preservation Techniqi.s, and Holding Times, Federal Register,
October 26, 1984.
b. TDS: Samples collected during May and July 1986, were not analyzed
within the required holding time.
Regulatory Requirement: Samples for TDS analysis must be analyzed
within seven (7) days of collection. See Table II, Required
Containers, Preservation Techniques, and Holding Times, Federal
Register, October 26, 1984 and January 5, 1985.
c. Suggestion: Data that do not meet stated quality assurance guidance
such as TOC/COD analyses, should be noted in the report to the user.
4. Chain of Custody: The facility has adequate chain-of-custody procedures
and documentation for the disposition of samples.
5. Methodology:
The methods in use for the RCRA self-monitoring program were generally
in accordance with 40 CFR Part 265.92(a) for all parameters. Deficiencies
were noted for the TDS, COD and TOC procedures.
The following observations were made during the evaluation:
a. TDS: The sample volume filtered provides an amount of residue in the
weighing dish in excess of 200 mg in some cases. Periodically
the lab recycles samples through the drying steps to check proper
drying conditions.
Regulatory Requirement: Because excessive residue in the dish may
form a water-trapping crust, limit the sample to no more than 200 mg
residue. See Method 209B, Standard Methods; or Method 160.1,
5.3, EPA Methods.
96
-------
b. COD: Several of the monitoring wells are located in a saline
aquifer with chlorides in excess of 2000mg/L. The laboratory
uses a modification of approved Method 410.3, High Level COD for
Saline Waters. An equivalent amount of mercuric sulfate
(10 mg/mg CD is added to the sample aliquot to remove any
positive interference from chlorides that can be quantitatively
oxidized by the dichromate. The amount of mercuric sulfate added
is based on the conductivity of the sample. The mercuric sulfate
is mixed with the sample in a separate beaker and an aliquot is
removed for analysis. Because a precipitate can occur, any suspended
solids present may be trapped and removed from suspension.
Resuspension of the particulate matter would be necessary to
obtain a representative sample.
Regulatory Requirement: The approved method requires preparing a
standard curve of COD versus mg/L chloride, to correct for the positive
chloride interfence. See Method 410.3, 7.7 EPA Methods. Also, a
representative sample aliquot must be taken for analysis.
c. TOC: Samples from some of the wells in the contaminated zone contain
particulate matter. The particulate matter (mainly clay particles)
is allowed to settle, and the supernatant is removed for analysis.
This modification could yield a fraction that would be defined as
something less than the total organic carbon. The laboratory uses
the acidification/purging method to remove the inorganic carbon
(C02).
The form of carbon measured and reported would be the dissolved
nonvolatile organic carbon (DNPOC). The purgeable organic carbon
(POC) would not be measured.
Regulatory Requirement: The laboratory should use a homogeneous
sample aliquot for analysis and define the data submitted to the
regulatory agencies. See Method 505, lb and 4b, Standard Methods;
or Method 415.1, 3.1 and 5.2, EPA Methods.
d. Specific Conductance: Calibration standards are used daily, but
are not always documented in the lab log.
97
-------
Regulatory Requirement: Calibration standards must be documented
daily and preferably in the chronological order as analyzed.
6. Quality Assurance and Data Documentation:
»-
USECO had the Waste analysis Plan (Analytical and Quality Assurance
Chapters) available for inspection. The quality assurance guidelines
as stated in the Plan have not been fully implemented. The USECO
laboratory has established a quality assurance program that consists
of duplicates, spikes and reference standards to verify the quality
of data for each parameter analyzed. These quality control measures
are used to establish precision and accuracy control limits for some
of the ground-water analyses. Instrument calibration records, except
specific conductance, are maintained and temperatures of regulated
devices are checked. Raw data calculations, gravimetric weighings,
absorbance readings and TOC instrument performance checks are documented
and maintained on file as required in the State and Federal requirements.
Daily operating conditions and quality control practices are easily
reconstructed.
Some additional quality assurance suggestions that would strengthen
the quality of data produced are:
a. Continue the quality assurance program that consists of
duplicates, spikes and reference standards to verify the
quality of data for each parameter analyzed. Use these
data to establish precision and accuracy control limits for
all the ground-water analyses.
b. Conduct and document routine checks of the analytical balances
with class "S" or equivalent weights in the milligram weight
ranges encountered in the gravimetric tests, or when weighing
primary standards.
c. Verify spectrophotometric calibration curves each day of use
with a blank and at least one standard at mid-range of the
calibration curve. Daily checks should agree within +/-10 percent
98
-------
of the original curve or a new curve must be prepared. Verification
data should be recorded and maintained with the appropriate
sample data.
d. Check drying ovens and digester block temperatures each day of
use. The temperatures should be recorded on the bench sheets or
in a logbook in order to document maintenance of required temperatures.
7. Performance Evaluation Data:
The USECO Laboratory has not participated in any EPA evaluation studies.
CONCLUSION
Based on the overall findings the laboratory appears to be providing
acceptable quality data for specific conductance. The holding time
deficiency noted for pH could cause the reliability of the data to be
highly questionable from 1982 to January 1986. Considering the high
mineral content of the samples., the holding time and methodology defic-
iencies noted for TDS would probably be very minor and would not cause
the reliability of the data to be questionable. The deficiency noted
for the COD procedure could cause the reliability of some of the data
to be questionable. The chloride interference, if not corrected, would
bias the data on the high side. Data from samples outside the saline
zone (less than 2000mg/L chloride) would not be questionable. The
deficiency noted for TOC could cause the reliability of some of the
data to have a negative bias. Generally, the samples containing partic-
ulate matter are from the contaminated area and loss of any POC would
probably be minor.
The laboratory Ground-Water Analysis Plan should be implemented.
The Quality Assurance program as outline in the plan would strengthen
the quality of data produced.
The laboratory is conducting the analyses on a monthly frequency
as required in the Compliance Agreement. Parameters stipulated
99
-------
in 40 CFR Part 265.92 (b)(l) Appendix III, 265.92 (b)(2) and 265.92
(b)(3)(iv), Total Organic Halogen (TOX) are not analyzed. However, the
TOX would not be a reliable test in the presence of high chlorides.
USECO has the capability to conduct analyses as required in parts 265.92,
265.94 and some of the Appendix VIII compounds.
Radian is under contract to Texas Ecol09i'sts, Inc. (TECO) to
perform service on split samples collected during the Task Force inspection.
An on-site evaluation of the Radian Corporation was conducted from
August 6 through August 8, 1986, Austin, Texas. Metals Analyses were
performed by Radian Analytical Services and the organic analyses by the
Analytical Chemistry Department.
1. Personnel
The qualifications of the key personnel are given in Section 4.0 of
Appendix 1 (Analysis for RCRA Appendix VIII Compounds. Statement of
Qualifications). The laboratories are appropriately staffed to perform
the analytical services that were requested.
•2. Facilities and Equipment
The laboratories within the Radian Corporation complex in Austin are
modern and are equipped with the analytical instrumentation required
to perform the requested analyses.
3. Laboratory Administration, Methodology, and Quality Assurance
During an entrance briefing, the organizational structure of Radian
and the qualifications of the professional staff were presented.
Following this briefing, an overall tour was made of the analytical
laboratories during which the evaluators were shown the facilities and
reviewed the analytical capabilities of the company.
Several sample numbers were chosen at random from among those that had
been assigned to samples submitted by TECO. The chain of events
100
-------
taken from receipt of sample through analysis to data reporting was
followed throughout the laboratory.
The chain-of-custody forms were examined and were found to be in order.
Radian's system of samp"^ control was reviewed; the samples are assigned
a control number upon receipt, the number is logged into a computer,
and the sample is prepared for analysis in a central laboratory.
Security in the Radian laboratory complex is very strict, and when
stored, the samples are kept in locked refrigerators within locked
rooms.
The sample train was followed from the sample preparation laboratory
to each analytical area where the analytical methodology was reviewed,
the raw data was examined, and the quality assurance data were examined.
At each point, the analytical methodology and the instrumentation used
were discussed with both the analysts and the supervisors. The preventive
maintenance was reviewed and the maintenance logs were examined for
each class of instrument; these were found to be suitable and adequate.
.••
The laboratories were well equipped to meet the analytical requirements
of the project; e.g. organic analyses were performed on gas chromatoqraphs
and gas chromotographs/mass spectrometers, trace metals on atonic
absorption spectrophotometers and inductively coupled plasma (ICP)
spectrometers, and other inorganic analyses on ion chromatographs and
automated analyzers such as the Technician Auto Analyzer. Following
the analysis of the samples, the analytical results are sent to the
project manager who reviews and assembles these results and prepares a
report.
4. Findings
The laboratories are modern, are well equipped with analytical
instrumentation, and are staffed with well qualified analysts. However,
while the laboratory may well have met the terms of its contractual
commitment with respect to quality assurance, the following were found to
be somewhat short of expectations:
101
-------
(a) Radian Analytical Services does not maintain quality control charts
routinely but rather determines whether acceptance limits have been met
on control samples. Quality control charts have several advantages
over control acceptance limits; these, among others, include: 1) control
values may be trending either positively or negatively toward unacceptable
limits and this trend may be spotted and the trouble corrected before the
values reach these unacceptable limts; and 2) if the control values
become consistently above or below the previously established mean, the
analytical system should be examined. These are difficult to detect
when viewing ranges of acceptable limits alone.
(b) Duplicate spikes are not run on a routine basis. Minimally
duplicates and matrix spikes must be analyzed with each run, but it is
highly recommended that duplicate spikes be used. One advantage of dupli-
cate spikes is the following. If a particular analyte is present in
below detection quantities, a duplicate may not be meaningful. However,
by utilizing a duplicate spike, the analyst will have real numbers against
which to make a comparison.
(c) Within the Analytical Chemistry Department, spikes are run with
each 20 samples regardless of the time span in which these samples are^
analyzed. Blanks, standards, and controls should, at a minimum, be run
with each batch of sample's and should the batch contain more than 20
samples the controls should be run then on the prescribed basis.
5. Recommedations and Conclusions
Future contracts written for environmental measurements such as
these, should at a minimum, contain the quality assurance measures in addition
to those that may already be written into the contract.
It appears that Radian met the requirements of their contract with
Texas Ecologists and that the data produced under this contract is of
acceptable quality.
102
-------
GROUND-WATER MONITORING PROGRAM PROPOSED FOR FINAL PERMIT
Volume IV(C) of Texas Ecologists Chemical Operations Program, Engineering
and Construction Manual, submitted as part of thei,% Part B Permit Application
in November 1985 describes a revised ground-water monitoring program which -
TECO wishes to execute within the final permit. The proposed monitoring
system plan was reviewed during the inspection. Comments concerning the
plan were made to TECO representatives at that time.
Essentially the proposed plan consists of a detection monitoring system
to be installed in the upper aquifer and operated :in conjunction with the
ongoing ground-water recovery system. The upper aquifer as defined by TECO
is the upper sand and lower aquifers that are hydraulically
interconnected within the boundaries of the facility. This definition agrees with
the one set by the Texas Water Commission for the first aquifer to be
monitored.
The detection monitoring system will consist of upgradient and point
of compliance wells screened through the entire thickness of the saturated
portion of the upper sand plus a minimum of five feet above the saturated
zone.
The plan calls for installation and certification of the detection
monitoring system within six months of permit issuance. During the
inspection the point was raised that the detection monitoring system needs
to be in place prior to permit issuance or clearly written into the permit
with a schedule for completion.
The system will consist of many of the present monitoring wells and
new wells to be installed approximately 200 feet apart along the southern
boundary and northwestern corner boundary, 400 feet apart along the western
side, and approximately 600 feet apart along the eastern boundary. The Task
Force recommends that wells be installed in the second sand at a closer
spacing along the eastern boundany. The eastern side of the facility is
103
-------
upgradient for the shallow aquifer, however the flow in the Second Sand
appears to be in an easterly direction. Deeper wells at a closer spacing
are needed to monitor this second aquife".
There is also a'supplemental ground-water monitoring system proposed
which will consist of existing wells within the interior areas of the
facility. (First Sand - 001, P6, P4, W2, W7, E24 and E32; Second Sand-
E35, E36, E37, E38, E39, and E41). Four new wells will be installed in
the Second Sand,two will be adjacent to W-16 and W-15 and two evenly spaced
between E36 and E38.
Except for the spacing along the eastern side of the facility the Task
Force judged the proposed monitoring system to be adequate for detection
monitoring needs of the facility. The majority of the comments from the
Task Force were raised concerning well design and construction techniques.
Some of the points were:
1. Use of Schedule 40 or 80 PVC rigid pipe for well construction
was questioned. A more inert material is recommeded for well
construction due to potential reaction between organic contaminants
and PVC. It was recommended by the Task Force that a
more inert material (ie:Teflon ®) be used below the high water table
level and PVC above that point);
2. The plan states the use of 0.01-inch slot size for the screen
because experience indicated it prevented silt and sand
intrusion . During the inspection a great majority of the
wells were observed to contain silt intrusion. A number of reasons
could have caused this, but it was recommeded that the use of
0.01 inch sl-ot screen be re-evaluated based on a comparison between
the gradations of native soils and the chosen sand pack.
Teflon - registered trademark of E.I. DuPont Neimurs
104
-------
3. A filter pack Is to be placed a minimum of three feet above
the screen. The Task Force recommends that the three feet be
a maximum instead. It was also recommended that the filter
pack be tremnied rather than placed by gravity.
4. A number of wells on site have been damaged by vechicles. It
was recommended that "Bumper Guards" be set around the
aprons of the new wells to prevent further damage.
5. Finally, it was proposed development of the new wells would be
developed by bailing and pressurized air. This method is
adequate, but a preferred method of "Surge Block and Pumping"
was proposed by the Task Force. Proper development of a
monitoring well is vital to consolidate the sand pack, remove
drilling fluids or fines, and effect the greatest efficiency for
well recharge.
6. TECO initially submitted to the Task Force a table of recharge
rates. These rates were found to be in error by orders of
magnitude.
Task force recommends that further hydro!ogical testing
be conducted and a new recharge rates be established.
7. The proposed plan did not specify what parameters were to be
analyzed. This needs to be clearly stated prior to initiation.
As with the proposed Compliance Plan the proposed detection monitoring
plan is subject to Public Hearing opportunity and approval by TWC. This monitoring
should commence with the issuance of the permit.
-------
EVALUATION OF GROUND-WATER TASK FORCE SAMPLE DATA
This section presents an analysis of data collected during
the inspection. Analytical results from and methods used on samples collected
are presented in Attachment D.
Task Force personnel entered this inspection with the full knowledge
that a plume of organic contamination (Figure 14) existed and that TWC and TECO
had entered into a Compliance Ageement to correct the problem. The Task force
focused their sampling efforts not in re-establishing known contamination
but in determining if the on-going corrective action was effective and if
hazardous constituents had migrated to other areas of the site. Table 2 is
a list of parameter tested and Table D-l is a list of compounds found in
the ground-water samples.
Data results as expected showed elevated levels of contaminants
in the immediate area of the plume of contamination and the trench leachate
collection ^sumps.
Well P-8, as shown in figure 14 was considered as part of the plume^ in
1984 but not in 1985, because its TOC level had dropped. However, the Task
Force feels it is still contaminated due to the elevated levels of cadmium
and selenium, and the presence of six volatile organics.
Immediately to the east of P-8 is well £-36. This is a deep well (100
ft.) and supposedly upgradient. The presence of 1.9 ppm TOX, 0.038 ppm
phenol, 1.6 ppm POC and 3.2 ppm TOC raises the question of whether a vertical
pathway exists to the lower aquifer in this area or if contaminants
from the abandoned oil wells on site have influenced this second aquifer.
The other deep well sampled (E-41) contained 0.015 phenols and much the
same metals but at lower concentrations.
106
-------
No specific organic compounds were detected in the upgradient wells
P-7, W-16, and W-15. However, several metals were detected in each
well. Arsenic, chromium, and mercury detected in well P-7 are of particular
concern because they are at or near the Primary Drinking Water Standards
(PDWS). The remainder of the contaminants found in P-7, W-16, and W-15
could be attributed to background readings or off-site influences from
agricultural activities.
Two wells of particular interest to the evaluation were OB-2 and E-48.
These two wells .are to the north and downgradient of the plume, and
northeast of the recharge wells. E-48 contained fifteen metals, only
one of which (cadmium, 16ppb) was above PDWS. OB-2 contained seventeen
metals, none of which registered above PDWS. Both wells had detectable
concentrations of POX, TOC, TOX, total phenols, and other indicator
parameters. The presence of these metals and indicator parameters indicates
that low levels of contamination exist beyond the demarcation of the plume
of contamination.
Monitoring well 001, which is immediately downgradient of trench 36,
contained three volatile organics, sixteen metals, and five indicator e
parameters. None of the concentrations detected were above Primary Drinking
Water Standards. Their presence does indicate 'low level contamination
in that area.
Six wells ( P-9,P-8, W-l, P-6, W-2, and W-21) adjacent to the first
fourteen trenches were sampled to determine if the trenches were a source
of contamination. W-21 was the second most contaminated well encountered
during this inspection, (E-3 was first), indicating direct contamination
from either these unlined trenches or the old mixing basin. All of the
other wells showed varying levels of contamination indicating that these
trenches are a source of contamination to the ground water and that the
recovery operation for the mixing basin needs expansion.
107
-------
Monitoring well W-6 contained seven organic compounds (trichlorethene,
1,1-Dichloroethene, 1,2-Dichloroethane, trichlorofi uoromethane, methylene
chloride, 1,1,1-Trichloroethane, and 1,1,2-Trichloroethane), manganese
above PDWS, and total phenols. This clearly indicates ground-water
contamination has occured in this area. Due to the fact that the well is
located upgradient of the currently identified TOC plume of contamination
but yet downgradient of the western most trenches there has apparently been
a release o.f contaminants not previously identified.
108
-------
Figure 14 Extent of Contamination; from TECO December 1985 Compliance Plan, Attachment 3-1
October 1985 Plume Boundaries
October 1984 Plume Boundaries
-------
REFERENCES
1) Environmental Protection Agency, "Draft - Ground-Water Monitoring
Technical Enforcem;nt Document", August 1985
2) Texas Ecologists, Inc., "Groundwater Compliance Plan Application",
December 19,1985
3) Texas Ecologists, Inc., "Engineering and Construction Manual, Chemical
Operations Program ", November 8,1985
4) Texas Ecologists, Inc., "Facility Operations Manual, Chemical
Operations Program", November 8,1985
5) Texas Ecologists, Inc., "Sampling Manual, Chemical Operations Program",
November 8, 1985
6) U.S.Department of Agriculture, "Soil Survey, Nueces County, Texas",
Soil Conservation Service, June 1965
t
7) National Enforcement Investigations Center, "Ground-Water Monitoring
Evaluation, Rollins Environmental Services (TX), Inc., Deer Park,
TX", Denver:Environmental Protection Agency, July 1986
8) Mr. Kennith Aldrich, Multiple telephone conversations from
Mr.Aldrich regarding the Texas Ecologists, Inc. facility and
neighboring rural residences, July and August 1986.
110
-------
Attacment A
1972 Permit
-------
uwbcr
TEXAS HATER DUALITY BOARD
P. O. Box 13246, Capitol Station
Austin, Texas 78711
" Permit Number W*? . FOR AH IHDUSTRIA1 SOLID
WASTE MANAGEMENT SITE issued under provision of Article
4477-7, Vernon's Texas Civil Statutes, and Texas Water
Quality, Board Order Ho. 71-0820-18."
teaistrant Site Owner
lame; • ••
tddress:
Name:
TEXAS ECOLOCISTS, INC jl Address-
r. 0. BM M?
T«M TUM
TEXAS ECOLOGISTS, INC.
p. o. a«« MT
*•*•<>••. TUM 7UM
Tize & Location of Site; This 240 acre site is located approximately 4 miles
south of Robstown, Texas in Nueces County and 3 miles east of State Highway 16.
n»e site is fronted by a payed county road on the east.
riassification of Site; Class Z
• e
vaste Management Methods Used at the Site; 1) Reclamation and salvage of oils
and other hydrocarbons; 2) Incineration of oils, solvents, hydrocarbons, greases
and other combustible liquids; 3} Chemical treatment of acids, caustics, and oth
rhemical solutions; 4) Modified landfill of solid wastes and solids and sludges
resulting from the treatment process.
Description of Waste Materials that •will be Managed at the Site; Oils, solvents
and other hydrocarbons; acids, caustics, and other chemical solutions including
those containing heavy metals; mud-water-oil mixtures; and other solid and semi-
solid wastes.
Standard Provisions; Acceptance of this certificate constitutes an acknowledge-
ment that .the registrant will comply with all of the terms, provisions, conditic
limitations, and restrictions embodied in this certificate, and with the rules,
regulations, and orders of the Board, and the laws of the State of Texas.
The legal description, as submitted in the application, is hereby made a part of
this Certificate of Registration.
Upon final closing of the-facility," the applicant shall be responsible for the
proper maintenance of the facility for a period of at least one year.
Special Provisions;
e
1. All incineration devices and waste storage facilities must meet Texas Air
Control Board standards for odors and emissions.
2. The Preliminary Certificate of Registration tor an industrial solid waste
management site issued lor this site on April 11, 1972 is hereby superseded
this Certificate of Registration £20306.
3. Disposal of wastes may not begin until the relevant facilities have been
completed and inspected for completeness by the Texas Water Quality Board.
*
4. Authorization is contingent upon the company's execution of a performance
bond to the Texas'Water Quality Board in the amount of $20,000.00; said
bond to be.used by the Water Quality Board if needed to properly close out
the site in the event of abandonment by the company prior to proper closing
A-2
-------
:ERTIFICATE or REGISTRATION TOR AN INDUSTRIAL SOLID WASTE MANAGEMENT SITE
fjxas Ecologists, Inc. (#20506)
Page 2
5. At such tin* as earth work construction eonsnenees upon the site, a ditch sh
be dug on the southern most boundary of the 240 acre site in order to drain
surface runoff from the site into the large drainage ditch crossing the
western portion of the site.
This certificate will be valid until cancelled or revoked by the Executive
Director.
Issued this 19th day of July 1972.
/ \Sxec6iive Direc^ftr
A-3,
-------
ATTACHMENT B
Compliance Agreement
-------
COMPLIANCE AGREEMENT
THIS COMPLIANCE AGREEMENT IS ISSUED TO TEXAS ECOLOGISTS, INC. (TECO),
SOLID WASTE PERMIT NO. 39023, ROBSTOWN, TEXAS, AND REPRESENTS A DETER-
MINATION THAT FORMAL ENFORCEMENT ACTION UNDER SECTION 26.123, TEXAS
WATER CODE, AS AMENDED WILL RE WITHHELD SO LONG AS TEXAS ECOLOCISTS,
INC., COMPLIES WITH THE COMPLIANCE SCHEDULE SET FORTH BELOW. THIS COM-
PLIANCE -AGREEMENT SUPERSEDES THE DIRECTIVES FROM THE EXECUTIVE DIRECTOR
DATED APRIL 3, 1980 AND DECEMBER 12, 1980,
1. Texas Ecologists, Inc., shall-
a. Construct and operate the ground water recovery system
as described and in .iccordance with the schedule contain-
ed In the proposal dated September 30, *1980 submitted
to the Texas Department of Water Resources (TDWR) October
1, 1980, Attachment A, (with the exception that pond con-
struction shall be accomplished by April 15, 1981) and
in accordance with the Law Project #710012, prepared by
Law Engineering Testing Company, Attachment B. A plot
plan showing the location of each pumping well and obser-
vation well installed during each phase of this project
I
District 12 office; nnd
shall be submitted to the Executive Director and TDWR
TECO shall construct Pond No. 26 and Pond No. 3 In accor-
dance with the plans and specifications submitted to TDWR
on January 20, 1981. Pond No. 26 shall be completed by
April 15, 1981. Subsequent to the completion of Pond No.
26, TECO shall transfer water from existing water impound-
ment Ponds No.'s 2, 3 and 30 into new Pond No. 26.
B-2
-------
c. Prior to placement of liquids in Pond No. 26, TECO shall
submit certification in writing that all facility compo-
nents have been constructed in accordance with specifica-
tions set forth in the proposal presented Co TDWR on
January 20, 1981, except as modified below.
Liners shall be constructed of clay-rich soils exhibiting
the following physical properties:
Liquid Limit _> 30
Plasticity index ^ 15
7o passing No. 200 sieve _> 30
Coefficient of permeability _< 1 x 10" cm/sec
Soil linprs to be constructed shall be compacted in lifts
not less than six (6) inches thick nor greater than nine
(9) inches, and scarified to a minimum depth of two (2)
inches prior to placement of the following lift. All
compaction will be to 95% Standard Proctor density at or
slightly above optimum moisture content.
Certification shall be prepared and sealed by a profes-
sional engineer with current registration pursuant to
the Texas Engineering Practice Act. Required certifica-
tion shall be in the following form:
This is to certify that the following facilities
have been completed and that construction of said
facilities has been in accordance with plans sub-
mitted to TDWR on January 20, 1981 and in compliance
with the Compliance Agreement dated February 9 ,
1981.
(description of facility components)
Certification that Pond No. 3 has been constructed in
accordance with plans submitted to TDWR on January 20,
B-3
-------
1981 and meets the above specifications will also be si/' -
mitted to TDWR prior to utilization of the pond.
2. Only recovered ground water that in the opinion of TECO pre-
sents no potential for causing odors or that has been treated
by activated carbon absorption may be stored or disposed of
in Pond No. 3. TECO may store/dispose of recovered ground
water in other ponds on-site.
3. TECO shall submit a monthly progress report to the Executive
Director which contains:
a. The total volume of ground water recovered from each well
during the preceeding month;
b. Analyses of samples from all recovery wells and ground
water monitoring wells located on TECO's property in the
vicinity of the contaminated area. T^hese analyses shall,
at a minimum, report the concentration of Total Organic
Carbon, Chemical Oxygen Demand, Total Dissolved Solids,
pH, odor and appearance; and
c. Water level measurements accurate to -»_ 0.1 foot from all
recovery and ground water monitoring wells at this facili-
ty, reported in feet above mean sea level. The water
level measurements shall be reported in tabular form and
on an isopiestic map of the shallow contaminated zone
In the vicinity of TECO.
The first monthly progress report shall be submitted 30
days from the date of acceptance of this Compliance
Agreement.
4. TECO shall submit a report annually to the Executive Director
which evaluates the performance of the ground water recovery
system. The first report shall be submitted one year from
.B-4
-------
the date of acceptance of this Compliance Agreement. If this
report reveals that the ground water recovery system is not
functioning to adequately contain all contaminants on-site
or that cleanup is not being effected, the Executive Director
may require the Company to develop and implement additional
corrective measures. Additionally, should the monthly water
level measurements taken after installation of. the recovery
well system shown in in Attachments A and B indicate that the
ground water recovery system is not functioning adequately
to effect a "cone of depression" in the piezometric surface
in the contaminated area, the Executive Director may also
require the company to develop and implement additional cor-
rective measures.
5. Within sixtv clays> of Che il.Hc of acceptance- of this Agreement ,
TECO shall install a minimum of nine (9) ground water monitor-
ing wells in addition to those described in Provision No. 1.
a. Two wells shall be located in the immediate vicinity
(within 10 feet* of the locations of Borings No. 2 and
No. 3 drilled April 19, 1979.
These wells shall be completed through the total thick-
ness of the silty sand, clayey sand zone shown on the
logs of Borings No. 2 and No. 3 to exist below the depth
of fourteen (14) feet below surface.
b. Seven wells shall be located at or near the following
site coordinates:
N2325, E2980
N2325, E4860
N1075, E2980
N1125, E4775
B-5
-------
N3540, E4860
N3540, E2980
N3540, E4150
These .wells shall be completed through the total thick-
ness of and screened through the total saturated thick-
ness of the first permeable water zone .below the clay
strata which exists at depths of 35 to 50 feet below sur-
face.
c. Samples from these wells will be collected on a monthly
basis and analyzed for Total Organic Carbon, Chemical
Oxygen Demand, Total Dissolved Solids, pH, odor, and ap-
pearance. Water level measurements in each well should
also be reported. Results of analyses.from the Initial
sampling shall be submitted to TDWR within ninety days of
the date of acceptance of this Agreement. Subsequent
analyses will be submitted with the monthly progress re-
port (Provision No. 3 above).
d. Logs for each of the nine monitor wells shall be submit-
ted to the Executive Director within thirty days of well
completion.
6. Within sixty days of the date of acceptance of this Agreement,
TECO shall submit to the Executive Director cementing affida-
vits or other certification that surface casing in each of
the three abandoned oil wells at the eastern border of the
site (Nora Schulze No. 1, 2, and 3) is cemented through the
entire thickness of fresh water bearing sediments (surface
to 1,000 feet depth).
7. A copy of all reports required by this Agreement shall be
submitted to the TDWR District 12 office.
8. Within 120 days of acceptance of this Compliance Agreement
by TECO, TECO shall complete the program set forth below and
B-6
-------
submit to TDWR a report indicating whether or not landfill
trenches 1 through 14 inclusive are underlain by a minimum
of 3 feet of clay rich soil below the bottoms of the trenches
as determined in the report entitled "Gamma Ray Log Study,
Texas Ecologists, Inc., Robstown Disposal System, Robstown,
Texas" prepared by Moody's of Dayton, February, 1980.
This program will be composed of four soil borings sampled
for soil specimens and laboratory testing for physical proper-
ties of those specimens. Testing shall, at a minimum, deter-
mine the liquid limit, plasticity index, and percent passing
No. 200 sieve of each sample collected. The borings will
be made at the following locations:
Two soil borings near just outside the western margin
of the Trench 1-14 area and located at 'the approximate
site coordinates of N2265, E3925 and N1908, E3921.
<
Two soil borings within the Trench 1-14 area but outside
of trench boundaries and located at the approximate site
coordinates of N2262, E4302 and N1711, E4300.
9. Within 365 days of the date of acceptance of this Agreement,
TECO shall complete the excavation and removal of all sludges
and contaminated soil from Pond 3-4. TECO shall take all
measures necessary to minimize odors associated with this
operation.
10. In the event the Company foresees It will not conclude one
or more of the obligations set forth within the applicable
deadline, the Executive Director may, upon application by the
Company, extend the deadlines for a reasonable time provided
the Company demonstrates it has used due diligence to accom-
plish the obligations of the Agreement.
-
-------
11. The president or other authorized official of the Company
shall sign this Compliance Directive, if accepted, and in any
case this Directive shall be returned within 20 days of the
date of approval by the Executive Director.
THIS COMPLIANCE AGREEMENT DOES NOT CONSTITUTE A WAIVER OR MODIFICATION
OF ANY APPLICABLE REQUIREMENT AND IN THE EVENT LEGAL ACTION IS INITI-
ATED, THE TEXAS DEPARTMENT OF WATER RESOURCES MAY SEEK CIVIL PENALTIES
OR OTHER RELIEF FOR ALL VIOLATIONS, INCLUDING THOSE WHICH OCCURRED PRIOR
TO THE ISSUANCE OF THIS AGREEMENT. SIGNING OF THIS AGREEMENT DOEg NOT
CONSTITUTE ANY ADMISSION OR ACCEPTANCE OF LIABILITY BY THE COMPANY NOR
DOES THE COMPANY ADMIT THAT IT HAS VIOLATED ANY STATUES OF THE STATE
OR RULES OF THE TEXAS DEPARTMENT OF WATER RESOURCES.
Approved this 9th day of February , 19H1 .
Harvey Davi Sx/"fcxecuti ve Director
Texas Department of Water Resources
Approved this 26th day of February , 1981
S. V. Wright, Jr.
Vice President, Ope
PS F.rolnqy, INt .
("Signature and/Titlelof Officer)
Texas Ecolofcisni, Inc.
B-8
-------
ATTACHMENT C
Facility Maps and Cross Sections
-------
Attachment C Contents
C-l West TECO Facility Plan
C-l Center TECO Facility Plan
C-l East TECO Facility Plan
C-2 Cross-section Locations
C-3 Cross-section A-A'
C-4 Cross-section B-B'
C-5 Cross-section C-C1
C-6 Cross-section West-East
C-7. Cross-section South-North
D-8 Location of Task Force Sample Points
-------
-------
Figure C-l center-TECO Facility Plan
From: TECO Site Development Plan, 1984
B-l
OB-3
E-42
,£-40
P-13
E-12
R-7
2 . X-2A .E_n E-18
E-15 £-16
E-l
X-4
W-4BE-20
W-4A1
- • Vi-4 E-9
-------
Figure C-l west - TECO Facility Plan
From: TECO Site Development Plan, 1984
•»>* IliS J
t'J • «• *••/#-- f--.
5 **/, *" ***» i **'. ** % * ** *t
ft-' ':«' __ »*jf ~p "^ ' r'
FUTURE -DISPOSAL"
>v "L. • ** '„ ~ /-« *f * . «" ' ,/
\.»j\M9 -' """ ~ u4iC_X f
(i?M ' 1x2*0 , I
T1tEMOt *• *
-------
I.
1.400 -
N
A
MUM
mM
• ITC
CflDSS SECTION
l«t» INOIWtlinMa TKTNM
COMPANY
K» HWVCII T10011.T2-K
rtoom 9
Attachment C - 2
Cross-section loca'ions; A- A1, B-B1, C-C1 prepared by TECO consultants, Law Engineering;
W-E and N-S cross sections prepared by Paul Lewis, TWC
-------
Elevation Above Sea JLevel : (feet)
o o
)OO O O O O •—' CN
-, ' v^ m "-3" rn cs *—>o i i
I I I I I I I I I I
CO
r
i
I f
MI ^*
hi
lil
s u
1 f
i u
-------
Elevation Above Sea Level (feet)
o o o o o o o
^1 "1 "1 "1 '1 ^ 1
o o
3 I I
I I I
CT> U-l :
w
&
e
o
I
t-3
c
OJ
o
TO
-------
i
Elevation Atrove Sea "Level (feet)
• I 1 • 1 lit
feft *^
r rl ^ ' °'
1 ro j
oo O
CM
r-
1
r . . =
,*
^
r * £
1 '
> '<••"> i w
to
a
r-
re
tc
>
01
>
-
c
re
f
"
>>
CB
J
^H
O
^
•o
c
CO
CO
•o
c
CO
CO
1— 1
o
CO
O
-c
c
CO
c
CO
H
g
1 •
\
\
4-1
U-l
a^
(
4J
U-l
t —
*^
CO
U
T)
e
CO
CO
/ c
^ cd
^
CO
n ^
•a °
C / C
co U?
W 0 K.
. *1 9.
r>^ CQ
,H TJ
•H CO
CO CO C
CO
C ^> /j
co 10
H M C
• 9 .«
•• •
C AJ
H
i ^4
-H ?
z i tit1
i
c
u
Cl
i
C
n
c
u
! r
M M
5 *""
«f
| r
J kl
•^ 2
©1
«
1 f
1
• 1
a>
o
re
-------
to
re
Attachment
West East Cross section
Horizontal scale 1"=300'
Vertical Scale 1"=10'
from 1985 TWC Compliance Monitoring Evali
-------
J=
4-J
o
Attachment C -
7 South - North Cross section
Horizontal Scale 1"=300'
Vertical Scale 1"=10'
From 1985 Compliance Monitoring Evaluation prepared ;
TWC.
-------
Figure C-8
Location of Task Force Sample Points
-------
ATTACHMENT D
Analytical Techniques and Results for Task Force Samples
Texas Ecologists, Inc., Robstown, Texas
-------
ATTACHMENT D
Analytical Techniques and Results for Task Force Samples
Texas Ecologists, Inc., Robstown, Tx
The following discusses analytical techniques, methods, and results for
water and leachate samples collected by the Task Force at the Texas Ecologists,
Inc. facility near Robstown, TX. Water sample analysis and results are discussed
in the first section; the second section addresses the leachate analysis and results.
Field measurements on water samples, including conductance, pH and turbidity,
were made by the EPA sampling contractor at the time of sampling. No field
measurements were made on the leachate samples. Laboratory analyses results
were obtained from two EPA Contractor Laboratories (CL) participating in the
Contract Laboratory Program (CLP). One CL analyzed the samples for organic
compounds while the other analyzed for metals and other parameters.
Standard quality control measures were taken including: (1) the analysis of
field and laboratory blanks to allow distinction of possible'contamination due
to sample handling, (2) analyses of laboratory spiked samples and performance
evaluation samples, and (3) analyses of laboratory duplicates and field triplicates
to estimate precision. The performance evaluation samples were samples of
known analytic concentrations prepared by the EPA Environmental Monitoring
Systems Laboratory, Cincinnati, Ohio.
Table D-l provides a summary by parameter, of the analytical techniques used
and the reference methods for the sample analysis. The D-2 is a summary of
field measurements collected, and Table D-3 provides a summary of concentrations
for hazardous substances, indicator parameters, and metals found in GWTF samples
collected at TECO.
-------
Parameter
fable D-l
Sample Preparation and Analysis Techniques and Methods
Preparation Technique Analysis Technique
Method Reference
Specific Organic Constituents
Volatiles
Semi-volatiles
Pesticides/PCB
Herbicides
Purge and trap
Direct injection
Methylene chloride extraction
Methylene chloride/hexane
extraction
Diethyl ether extraction/
methylation
Gas Chromatography with Electron Capture Detection CLP Method (a)
Gas Chromatography - Mass Spectroscopy or CLP Method
Gas Chromatography with Flame lonization Detection CLP Method
Gas Chromatography - Mass Spectroscopy CLP Method
Gas Chromatography with Electron Capture Detection CLP Method
Gas Chromatography with Electron Capture Detection Method 8150 (b)
Elemntal Consistuents
Mercury Wet digestion for dissolved Cold Vapor Atomic Absorption Sepctroscopy
and total
As, Pb, Se and TI Acid digestion for total
Other Elements Acid digestion for total
Furnance Atomic Absorption Spectroscopy
Inductively Coupled Plasma Emission Spectroscopy
Field Measurements
Conductance None
pH None
Turbidity None
Non-specific Organic Parameters
POX None
TOX Carbon absorption
POC None
NPOC Acidify and purge
Electrometric,
Potentiometry
Nephelometric
Wheatstone Bridge
General
Ammonia
Chloride
Nitrate
Sulfate
Cyanide
Phenol
Constituents
Particulates settled
Particulated settled
Particulates settled
Particulates settled
Manual
Manual
distillation
distillation"
Purgable combusted, Microcoulometry
Carbon combusted, Microcoulometry
Purgable combusted, Non-dispersive Infrared
Liquid combusted, Non-dispersive Infrared
Phenol ate Colorimetry of supernatant
Mercuric Precipitation Titration of supernatant
Brucine Sulfate Colorimetry of supernatant
Barium Sulfate Trubidimetry of supernatant
Pyridine Barbituric Acid Colorimetry
Ferricyanide 4-Aminoantipyrine Colorimetry
a) Contract Laboratory Program, IFB methods.
b) Test Methods for Evaluating Solid Wastes, SW-846.
c) Methods for Chemical Analysis of Water and Wastes, EPA-600/479-020.
CLP Method
CLP Method
CLP Method
Method 120.1 (c)
Method 150.1 (c)
No reference
EPA 600/4-84-008
Method 9020 (b)
No reference
Method 415.1 (c)
Method 350.1 (c)
Method 9252 (b)
Method 9200 (b)
Method 9038 (b)
CLP Method
Method 420.1 (c)
-------
TABLE D-2
Summary of Field Measurements
on Task Force Monitoring Well Samples
SAMPLE
NUMBER
461
462
464
465
466
467
469
470
471
472
473
474
475
477
478
479
480
481
482
484 -
485
486
WELL
LOCATION
Wl
P8
P-7
P-4
P-2
001
P-5
W-15
W-16
W-2
W-21
E-3
W-6
P-9
E-48
P-13
P-12A
E-14
OB-2
E-14
E-36
P-6
TURBITITY
NTU
146
49.0
152
29.5
22.7
118
7.18
1.72
6.8
15.36
61.8
40.7
1.45
14.0
6.25
11.4
6.51
3.23
36.0
12.3
44.1
125.7
TEMPERATURE
°C
23
24
20
26
28
15
28
20
21
20
12
11
19
15
19
16
21
14
18
19
12
17
CONDUCTIVITY
umhos
10,000
24,000
800
1,700
6,000
15,000
18,000
12,000
2,400
2,300
1,000
12,000
70,000
19,000
8,000
12,000
17,000
17,000
6,000
6,000
4,100
3,200
PH
6.9
7.0
8.0
8.0
7.2
7.3
7.5
6.8
7.7
7.0
6.6
6.1
7.0
7.1
7.3
7.1
6.8
7.2
7.5
7.7
7.6
7.2-
-------
Table 0-3 Summary of Concentrations for Hazardous
Substances List of Compounds, Indicator
Parameters and Metals Found in Ground-Water
Samples at TECO.
Parameters
Al umi num
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Sodium
Thallium
Tin
Zinc
TOC
TOX
POC
POX
Total Phenols
Nitrate
Sulfate
Chloride
EPA SAMPLE LOCATION (ppm)
W21
8.460
.176
ND
.102
.007
.035
ND
7.150
.47
279.000
12.900
ND
ND
15.400
.005
6,450.
.001
.045
.054
13
17
17.
41
.096
2.320
2470.
9800.
E3
5.110
.132
.170
.080
.011
.062
.093
65.7
.300
377.
30.5
.002
.095
19.7
ND
5340.
ND
.142
.128
48.
28.5
1.8
2.95
.oe^
ND
ND
ND
W-6
ND •
ND
.017
.151
ND
.016
ND
.155
ND
133.
.054
.0006
ND
21.00
.001
1550.
ND.
.042
.018
2.40
1.73
.890
2.81
.028
2.32
245
3220
P-9
15.7
.196
.757
.107
.012
.059
ND
8.590
.293
483
.083
ND
ND
32.6
.006
6830.
.001
.042
.079
6.000
1.580
.220
1.270
ND
.540
2340.
11,900.
E-48
2.33
ND
.0074
.066
.016
.020
.022
2.33
.009
66.7
.086
ND
ND
11.0
ND
2800
ND
.106
.187
4.400
.161
ND
.020
.038
2.100
1,260.
4,660.
P13
.773
.186
.099
.041
.007
.036
ND
.898
ND
264
.161
.0026
ND
31.1
.001
5560
.002
.122
.040
4.000
ND
ND
ND
.048
1.940
1780.
6940.
P12A
1.50
.126
.015
.075
.006
.034
ND
1.51
.013
278.
.036
ND
ND
19.3
.001
4490
.002
.069
.103
1.90
.225
ND
.125
.018
1.740
1560
6310
E14
.215
.104
.076
.038
ND
.036
ND
.308
.105
300.
.005
ND
ND
25.2
.002
6,090.
.001
.099
.053
1.10
ND
ND
.035
.020
1.32
2040.
10,300.
OB2
17.0
.063
.024
.472
.008
.029
.027
10.6
.0083
62.90
.259
ND
ND
19.0
ND
1910.
.120
.098
ND
1.80
ND
ND
.028
.036
1.160
730
3870.
-------
(Continued)
Table D-3 Summary of Concentrations for Hazardous
Substances List of Compounds, Indicator
Parameters and Metals Found in Ground-Water
Samples at TECO.
Parameters
Al umi num
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Sodium
Thallium
Tin
Zinc
TOC
TOX
POC
POX
Total Phenols
Nitrate
Sulfate
Chloride
EPA SAMPLE LOCATION (ppm)
Wl
3.3
.154
ND
.10
ND
.004
817.0
.03
ND
2.23
ND
161.0
.256
.002
ND
22.0
.003
3120.0
.001
.085
.065
6.3
.34
ND
.14
.019
1.32
2960
3110
P8
7.87
.157
ND
.070
ND
.163
337.0
.018
ND
4.42
.017
100.0
.143
.0008
ND
16.7
.026
3640
.001
.058
.036
6.0
.98
ND
.898
ND
.440
2750
2990
P7
85.6
.156
.056
.30
.002
.008
178.0
.070
ND
57.1
.016
17.6
.433
.001
ND
17.9
ND
294.0
ND
.073
.159
1.2
.025
ND
ND
.027
2.1
142.0
77.1
P4^
5.8
ND
.0556
.031
ND
ND
25.5
ND
ND
3.07
ND
ND
4.74
.032
ND
3.15
.001
489.0
ND
ND
.018
ND
.026
ND
ND
ND
1.36
490.0
103.0
P2
3.48
ND
ND
.045
ND
ND
143.0
.013
ND
2.03
ND
23.1
.025
.0005
ND
10.8
.001
1870.0
ND
ND
.056
1.6
.103
ND
ND
ND
2.2
480.0
2000.0
001
1.12
.115
.019
.06
ND
.006
1040.0
.036
ND
.741
.015
153.0
.023"
ND
ND
24.4
.008
4950
.001
ND
.017
ND
ND
ND
.029
.022
1.14
2.020
7250
P5
1.03
ND
ND
.128
ND
ND
79.3
ND
ND
.63
ND
10.8
.035
.0005
ND
6.2
ND
331.0
ND
ND
ND
ND
.060
ND
ND
.038
.750
215.0
776.0
W15
.068
.066
ND
.040
ND
.004
777.0
.020
ND
.230
ND
118.0
.007
ND
ND
22.6
.013
3200.0
ND
.051
.026
2.3
.049
ND
ND
ND
1.6
1160.0
4670.0
W16
.255
ND
ND
0.174
ND
ND
94.0
ND
ND
.141
ND
n.6
NC
ND
ND
12.2
.005
677.0
ND
ND
.015
2.1
.024
ND
ND
.012
1.5
104.0
930.0
-------
(Continued) Table D-3 Summary of Concentrations for Hazardous
Substances List of Compounds, Indicator
Parameters and Metals Found in Ground-Water
Samples at TECO.
Parameters
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Sodium
Thallium
Tin
Zinc
TOC
TOX
POC
POX
Total Phenols
Nitrate
Sulfate
Chloride
Cyanide
EPA SAMPLE LOCATION (ppm)
E41
.257
ND
ND
.024
NO
.005
ND
ND
.351
.008
62.0
.011
ND
ND
9.770
ND
1970.
ND
.090
.31
ND
ND
ND
ND
.015
.800
.820
2510.
ND
E36
2.290
ND
ND
.091
ND
.004
.010
ND
.005
1.540
28.3
.048
ND
ND
13.70
ND
1470.
ND
.106
.057
ND
.162
.220
.017
.038 *
.320
650.
1950.
ND
P6
5.65
.060
.0112
.070
ND
ND
.016
.022
4.30
.006
15.7
.056
.0002
ND
10.0
ND
880.
ND
.090
.081 '
3.20
3.83
1.600
7.630
.010
1.240
400.
808.
ND
W2
ND
.190
ND
.034
ND
.005
.033
ND
.162
ND
316.
.054
ND
ND
21.3
ND
7150.
ND
.104
.035
1.90
1.90
ND
.053
.010
1.40
2120.
11,200.
ND
S33
1.500
ND
.866
ND
ND
.020
.325
.135
13.0
.0126
194.
5.610
ND
.835
34.0
.0375
2150
ND
.299
.120
320.
27.2
14.0
39.0
9.8
ND
1550.
3540.
.0425
S16
14.10
.778
5.470
.265
ND
.085
7.650
.100
2090
.005
605
50.80
.060
.255
210
.046
13,400.
ND
.720
.990
22,000
1380.
580.
3.00
2120.
1.160
2920.
14,400.
.0875
-------
(Continued)
Table D-3 Summary of Concentrations for Hazardous
Substances List of Compounds, Indicator
Parameters and Metals Found in Ground-Water
Samples at TECO.
Parameters
Chloroform
Carbon tetrachloride
Trichlorethene
1 , 1-Di chl oroethene
1 , 2-Di chl oroethane
Tetrachl oroethene
Trichlorofluorome thane
Methylene chloride
Acetone
1 ,2-Di chl oropropane
Benzene
4-Methyl -2-pentanone
Toluene
Chlorobenzene
Total Xylenes
Phenol
1 , 2-Di chl orobenzene
N-Ni troso-di propyl ami ne
1 , 1 , 1-Tri chl oroethane
1 , 1 , 2-Tri chl oroethane
2,4, 5-T
2 -Methyl phenol
4-Methyl phenol
Dicamba
Bi s ( 2-ethyl hexyl )phthal ate
Aroclor-1260
Dichloroprop
EPA SAMPLE LOCATION (
Wl
9.4
48
84
PB
32
340
15
400
16
20
001
20
7
15
*
W21
1200
2700
490
5800
300
5000
900
310
2100
560
1400
3400
340
37
22
31
E3
3500
1000
160
290
240
330
58
180
180
550
26
98
110
W6
300
3000
210
170
100
1300
1200
P9
300
690
450
220
E48
30
P13
5.0
pb)
P12A
100
61
E14
38
OB2
33
E41
6.0
68
Pb
310
5800
400
3000
200
9
10
34
W2
48
5.9
5.9
-------
ATTACHMENT E
Examples of Monthly and Annual Ground water Recovery Report
-------
~ ff - ^S -
Texas Ecologists, inc.
/. r . • s,
*
March 15, 1982
Mr. Harvey Davis
Executive Director
Texas Department of Water Resources
Stephen F. Austin Building
1700 North Congress
Austin, Texas 78705
Dear Mr. Davis:
Attached is the February, 1982 Groundwater Recovery Report for Texas
Ecologists, Inc.
Please note the absence of 'elevation water level1 reading for well
£-35. This is due to road construction around the well area. E-35
elevation water level reading will be included in the March report.
Should you have any questions, please do not hesitate to call. .
Sincerely.
US ECOLOGY, INC.
_ /"> •-
David R. Fetter
Corporate Chemical Operations Officer
inn
Attachments
cc: Mr. Paul Kutchinski
Mr. Russell Lewis
or'
WK<^
E-2
-------
T E C O Gro J ' /ater Data
Dated:
.-14
'-15
1-1
1-2
»-3 :
,-4 ;
»-4A ;
f-4B
r-4c
Ph
7.57
7.40
7.61
8.11
7.40
7.44
7.80
7.96
7.47
7.10
7.49
7.33
7.37
7.36
7.25
7.34
7.24
7.33
7.67
. 7.59
d 7-13
JP
2 6.60
5e.28
-«6.95
6.53
COD
63
42
26
3
30
32
2
3
48
96
11
67
65
101
49
20
51
34
87
136
1,480
9,180
8.030
2.360
15.200
T O C
2
1
1
1
4
8
1
1
9
4
1
8
6
23
6
6
7
7
7
3
538
3,780
3.350
820
5.830
T D S
15.500
9,160
11,000
1,730
8,990
5,290
1,100
599
9.550
29,300
2,010
23.200
25,200
20.200
22,800
25,300
17,700
10,300
12,400
24,100
19.500
22,100
21,000
17.600
27.400
C O N D
21.900
14,200
16,000
2.580
12.800
8.210
1.780
979
13.400
37.300
3,320
31.400
34.900
27,800
30,400
34,500
24,700
15,100
17,200
32.800
25.600
26,100
24,500
__23j300
27,800
ELEVATION
WATER LEVEL
34.25
34.61
35.56
35.58
36.88
37.53
40.99
41.65
37.52
38.81
40.81
35.33
34.72
35.45
34.73
34.76
35.55
36.78
39.30
37.07
36.66
•w
Pump
36.56
36.93
37.24
ODOR
Nn
Sewage
No
Chemical
No
Slightly rhem
No
No
No
No
No
No
No
Nn
No
No
No
No
No
No
Chemical
Chemical
Chemical
£hemj.cal
Chemical
APPEARANCE
Turbid
Turbid
Turbid
Brownish
.iMi-bid
Turbid
Clear
Clear
Silt-y
Silt-y
Turbid <-,
i
Clear ho Tnrhirl ^
Clpar 1-n Turhirl
'"'Ifiar
Clear to Turbid
Silty
Turbid and Silty
Turbid and Siltv
Sliqhtlv Turbid
Slightly Turbid
Liaht Green
Liqht Brown
Brownish
Turbid
Brownish
lone
7fl . 960
-------
•
T E C O Groi jater Data
Dated:
•TELL
NUMBER
W-5
W-6
W-7
W-10
W-ll
W-12
W-13
W-15
W-16
W-17
X-1A
X-2
X-2A
X-3
X-4
X-5
X-6
E-l
E-2
E-3 ;
E-3A
E-4
E-5
E-6
Ph
7.34
7.45
7.60
7.71
7.67
7.68
7.70
7.32
7.12
7.16
7.83
6.77
6.72
7.32
7.09
7.84
7.11
6.95
"•6.92
»6.t7
e»
5&.50
3C
S|.68
3
7.05
COD
169
35
50
12
3
3
8
26
3
442
2,520
579
568
64
7,990
6,010
2,750
191
964
1,480
4,170
1.120
2,840
T O C
41
1
2
2
2
2
4
2
2
164
752
183
189
11
3,080
2,220
832
22
292
528
1,270
340
940
T D S
19,100
10,000
13^900
616
615
424
365
11,300
979
14,100
16,400
20,900
20,500
22,500
23jOOO
15.400
16,300
14,000
18.500
15,600
17.900
21.600
14,300
C O N D
25,600
14 , 200
18,600
962
928
500
490
15,700
1.360
20,400
21,300
28,000
26^,700
30j_100
27,700
_l9jLlQO__
22,900
20*000
25.300
20J800
^23^500
29.700
20^100
ELEVATION
WATER LEVEL
36.33
37.38
37.12
40.17
?9.83
38.58
35.05
35.65
36.83
36.98
Pump
35.08
Pump
34.63
Pump
Pump
34.37
35.18
35.28
31*43
Punp
35.70
35.47
ODOR
Slight Chem.
No
No
No
No
No
No
No
No
Sliqht Chem
Chemical
Stronq Chemical
Chemical
No
Sewaqe and Chem
Chemical
Stronq Cheux
Chemical
Them! cal
Chemical
Chemical
Turhid Blank
Chemical
APPEARANCE
Yellowish
Clear
Clear
Sliqhtly Turbid
Sliqhtly Turbid
SliqhtlY Trubid
Sliqhtlv Turbid
Clear
Clear
Turbid
Turbid and Silty T
UJ
Black
Light Amber
Silty and Turbid
Black .
Turhid Yellow
Black and Silhy
Turhifi and Rlark
Tjirhid and Rlflr-lt
i
Tan Color '
Turhid '
!
Tiirhid Blank ..
-2-
-------
'T
T E C O Gro' /ater Data
Dated:
WELL
NUMBER
E-6A
E-7
E-8
E-9
E-10
E-ll
E-12
E-13
E-14
E-15
E-16
E-17
E-18
E-19
E-20
E-21
E-22
E-23
E-24
E-25
E-26
E-27
E-28
E-29 I
'E-30 |
E-31 5
Ph
6.83
7.14
6.63
7.36
6.85
7.42
7.27
7.48
6.73
6.78
6.88
6.77
7.08
6.73
6.98
7.09
6.91
7.31
7.11
7.12
6.80
7.05
7.02
6.87
( 6.96
COD
3,250
1,590
8,320
432
1,180
49
106
98
179
882
497
1,890
291
9,020
2,040
167
150
7
1,680
1,710
1,500
5,370
3,890
6,070
2,070
T O C
1,110
450
3,080
170
418
4
25
4
4
253
146
683
94
3,600
751
57
. 42
3
642
584
536
1,990
1,390
2,250
732
T D S
14,900
8,980
23,100
7,420
10,400
13,300
22,500
20,500
20,900
19,100
19,800
19,800
20,200
23,800
18,800
9,630
19,200
4,730
19,900
18,300
17,200
15,000
11,700
14.BOO
10,700
C O N D
20,400
13,00
29,500
11,800
10,400
18,300
30,200
27,500
27,500
25,400
26,300
26.900
26.800
27.900
25,500
14,300
26,000
7,240
25,800
23,900
22,800
20^000
16, 1OO
_I9_iBO°
15,200
ELEVATION
WATER LEVEL
Pump
Pump
Pump
Pump
36.73
33.45
33.62
34.53
Pump
Pump
Pump
Pump
Pump
Pump
36.82
38.53
38.02
36.55
Pump
Pump
Pump
Pump
Pump
If-.RI
Pump
ODOR
Chemical
Chemical
Chemical
Chemical
Stronq Chem
No
Sliqht Chem
No
Chemical
Chemical
Chemical
Phpmir-a]
rhP|ni fal
rhpmical
Strong Chem
Strong Chem
Slight Chem
No
Slight Chem
Sliqht Chem
Slight Chem
Chemical
Chemical
Chemical
Chemical
APPEARANCE
TUrbid
Black
Brown-Oranae
Turbid
Turbid-Silty
Clear
Clear
Clear
Turbid
Turbid (Sliaht)
Turbid (Slight)
Li'jht Ambar
•Put-hid
^
hlAr-fc LT>
Black ^
Clear
Clear
Slightly Turbid
Yellow
Oranqe
Yellow
Turbid Yellow
Dark Yellow
Turbid
Yellow
-------
T E C O Gro
later Data
Dated:
4ELL
DUMBER
B-32
E-33
E-34
E-35
E-36
E-37
E-38
E-39
E-40
E-41
OB- 2
OB- 3
»•
1 C
Ph
7.12
7.17
7.11
7.65
9.69
10.1
7.81
7.87
10.9
7.51
7.36
7.35
I
s
COD
58
8,140
319
38
21
53
92
8
45
62
27
34
T O C
12
1,880
94
2
4
4
3
1
3
4
4
3
T D S
9,750
18,500
11,400
8,840
4,140
12,100
13,000
3,610
4,720
11,800
15,500
16,900
C 0 N D
14,200
24,700
16,700
12,300
6,610
17,900
17,900
5,950
7,780
16,500
21,200
22,500
ELEVATION
WATER LEVEL
36.75
Pump
36.12
32.48
33.08
32,. 55
32.33
32.83
33.72
32.70
33. 4fl
-
ODOR
None
Chemical
Chemical
No
No
to
ko
to
to
to
No
No
APPEARANCL
Turbid
Turbid Yellow
^ight Yellow
Slight Turbid
:lear
Clear
Clear
rlear
Turbid
Clear
Clear
Clear, Silty
-4-
-------
m
i
Future landfills \
-K-
1982
February Potentiometric Map for TECO
-------
1982 February Potentio.etric Map for TECO detailing the Northeast quadrant.
F-S
J
-------
Texas Ecologists, Inc
P 0 Box 307
RoDstown, Texas 78380
512-387-3518
Texas Ecologists
A Subsidnry of US Ecology Inc
Mr. Larry Soward August 20, 1986
Texas Water Commission
1700 North Congress Avenue
Austin, Texas 78711
Dear Mr. Soward:
Enclosed is the July, 1986 Groundwater Recovery Report for Texas
Ecologists, Inc.
The elevations on the attached contour map were taken over a two
day period in order to get the most accurate elevation reading for
the facility. Contours are also taken at time of sampling, and
as a result may be slightly different then those shown on the *
contour map.
Should you have any questions, please contact this office.
Sincerely,
Charles W. Mansfield
Chemical Operations Officer
CWM:lmj
cc: Messrs. Chip Volz
Paul Lewis
Enclosures
E-9
-------
I
ti
-------
JLHUUIUAAkJI
E-ll
------- |