December 1987
Hazardous Waste G
Task Force
Evaluation of
Boston Industrial Pro
Hohenwald, Tenness
United States Envir
Tennessee Depart
-------
-------
GROUND WATER MONITORING EVALUATION
BOSTON INDUSTRIAL PRODUCTS
HOHENWALD, TENNESSEE
UPDATE
The Hazardous Waste Ground Water Task Force evaluated the Boston
Industrial Products (BIP) facility in Hohenwald, Tennessee, during the week of
May 11, 1987, for compliance with the 40 CFR Part 265, Subpart F regulations.
Several deficiencies pertaining to the RCRA ground water monitoring system
were noted during the evaluation. S. E. Matthews, project coordinator for
the evaluation, compiled a report that detailed these deficiencies and
summarized the results from water quality samples collected from the RCRA
monitoring wells at the facility.
This update chronicles activities at BIP following the Task Force
evaluation and any actions taken by the Tennessee Department of Health and
Environment (TDHE) and EPA Region IV regarding RCRA ground water monitoring at
the facility.
In May 1987, TDHE requested that BIP perform accelerated sampling, with
four sampling events taking place at two-month intervals. Samples collected
during the Task Force evaluation would constitute the first sampling period.
The second sampling episode was conducted in July. Elevated levels of lead
and chromium were detected in well 5. Trichloroer.hylene was detected in well
3.
In July 1987, TDHE performed a RCRA Facility Assessment at BIP. The
report concluded that there were fewer solid waste management units at the
facility than the Task Force had determined. Comments from EPA Region IV on
these findings were submitted to TDHE in November.
In September 1987, BIP consultants prepared a report for TDHE documenting
permeability tests performed at the site. Hydraulic conductivities were
calculated to range from 1.6 X 10 cm/sec to 2.1 X 10 "7 cm/sec. Well
construction logs for holes 5 and 5A were also included in the report.
As of November 1987, TDHE was developing an administrative order against
BIP that would conclude that the" present ground water monitoring system is
inadequate. The order would require that additional hydrogeologic information
be obtained and for additional wells to be installed. No penalty was to be
assessed.
To date, EPA Region IV has taken no enforcement action against the
facility.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUND WATER TASK FORCE
GROUND WATER MONITORING EVALUATION
BOSTON INDUSTRIAL PRODUCTS
HOHENWALD, TENNESSEE
DECEMBER 1987
Sharon E. Matthews
Project Coordinator
Environmental Services Division
Region IV
US - EPA
-------
EXECUTIVE SUMMARY Page
INTRODUCTION 1
Background 2
SUMMARY OF FINDINGS AND CONCLUSIONS 2
COMPLIANCE WITH INTERIM STATUS REQUIREMENTS 2
265.90 Applicability 3
265.91 Ground Water Monitoring System 3
265.92 Sampling and Analysis 3
265.93 Preparation, Evaluation and Response 4
265.94 Recordkeeping and Reporting 4
TECHNICAL REPORT
INVESTIGATIVE METHODS 6
Records/Documents Review and Evaluation 6
Facility Inspection 6
Laboratory Evaluation 6
Ground Water Sampling and Handling 6
WASTE MANAGEMENT UNITS 7
Surface Impoundment and Overflow Ponds Description.... 7
Solid Waste Management Units 7
GEOLOGY/HYDROLOGY 9
Geology 9
Hydrology : 10
Adequacy of the Hydrogeologic Characterization 11
GROUND WATER MONITORING PROGRAM DURING INTERIM STATUS... 11
Regulatory Requirements 11
Monitoring Well Data 12
Ground Water Sampling 14
Boston Industrial Sampling and Handling Procedures.... 15
TASK FORCE SAMPLING AND HANDLING PROCEDURES 16
LABORATORY EVALUATION 18
MONITORING DATA ANALYSIS 21
REFERENCES
APPENDICES
A - Task Force Analytical Results
B - Monitoring Well Logs
C - Boston Industrial's Sampling and Analysis Procedures
D - Compliance History
-------
TABLE OF CONTENTS (CONT)
FIGURES
1 - Facility Location Map
2 - Block Flow Diagram of the Water System
3 - Facility Map with Well Locations
4 - Location of Potential Solid Waste Management Units
5 - Geologic Section Through the Monitoring Wells
TABLES
1 - Monitoring Well Construction Data
2 - RCRA Ground Water Monitoring Parameters
3 - Sample Collection Data
A - Task Force Field Measurements
5 - Order of Sample Collection, Bottle Type, and
Preservative List
6 - Task Force Analytical Data Summary -
7 - Parameters Evaluated During the Laboratory Inspection
-------
GROUND WATER MONITORING COMPLIANCE EVALUATION
BOSTON INDUSTRIAL PRODUCTS
HOHENWALD, TENNESSEE
ESD PROJECT No. 87E-125
EXECUTIVE SUMMARY
INTRODUCTION
Task Force Effort
Operations at hazardous waste treatment, storage, and disposal (TSD)
facilities are regulated by the Resource Conservation and Recovery Act.
Regulations promulgated pursuant to RCRA (40 CFR Parts 260 through 265,
effective on November 19, 1980 and subsequently modified) address hazardous
waste site operations including monitoring of ground water to ensure that
hazardous waste constituents could be immediately detected if released to the
environment. The regulations for TSD facilities are implemented (for EPA
administered programs) through the hazardous waste permit program outlined in
40 CFR Part 270.
The Administrator of the. Environmental Protection Agency (EPA)
established a Hazardous Waste Ground Water -Task Force to evaluate the level of
compliance with ground water monitoring-requirements at commercial off-site
and selected on-site TSD facilities and address the cause of non-compliance.
The Task Force comprises personnel from an EPA Headquarters core team,
Regional Offices and the States.
There were eight Task Force evaluations conducted in Region IV during
FY-86 and FY-87. Evaluations were conducted at the Region's two off-site
facilities. Six evaluations were conducted at private, on-site facilities.
The evaluation at Boston Industrial Products (BIP) was the sixth private on-
site investigation in Region IV and was conducted the week of May 11, 1987.
Objectives of the Evaluation
The objective of the inspection at BIP was to determine compliance of the
ground water monitoring system with the requirements of 40 CFR Part 265,
Subpart F - Ground Water Monitoring; to determine compliance with related
requirements of the Part 265 interim status regulations and the State's
counterpart regulations; to evaluate the ground water monitoring system
described in the RCRA Part B permit application, Part 270.14(c) and potential
compliance with Part 264. Recent Amendments to RCRA require that facilities
seeking a RCRA permit must also address solid waste management units at the
facilities, therefore, ground water monitoring wells associated with any solid
waste management units at the facility were also to be evaluated.
The BIP evaluation was coordinated by the Region IV US-EPA, Environmental
Services Division and included participation by the EPA Headquarters Core
Team, Region IV EPA Waste Management Division and the Tennessee Department of
-------
-2-
Health and Environment (TDHE). In general, the evaluation involved a review of
State, Federal and facility records, a facility inspection, a laboratory
evaluation and ground water sampling and analysis of the monitoring wells.
BACKGROUND
Locale/Facility Operations
Boston Industrial Products, Inc. in Hohenwald, Tennessee is a part of
the Dana Corporation (see Figure 1 for location). The facility produces a
variety of industrial products, including fire and chemical hose. The rubber
formulae are blended and mixed to meet specifications. Many variations of
hoses are produced by varying the rubber content, thickness and reinforcement
materials. Lead is used in the vulcanization of large rubber hoses. The lead
is stripped from the hose and is reclaimed for reuse or sale. Water used to
cool and set rubber hoses is discharged into a recirculation pond and recycled
(Figure 2). This water contains lead which settles to the bottom of the pond
and becomes part of the sediment.Sediment in the pond was found to contain 36
ppm lead by the EP Toxicity test, thus characterizing it as D008, a
characteristic hazardous waste under 40 CFR 261. The State of Tennessee and
US-EPA consider this pond as a hazardous waste surface impoundment.
In the past, excess water in the recirculation pond was pumped into two
30-foot by 50-foot ponds known as the east and west overflow impoundments.
This practice is no longer utilized and these ponds have been abandoned. The
facility did have interim status: TND004045605. In November 1985, the facility
certified compliance with applicable financial assurance requirements,. In
December 1985, the State issued a NOV to the facility for failing to file and
maintain with the State liability' coverage as required under Tennessee
Regulations 1200-1-11-.05(8). Later that month, TDHE and EPA inspected the
facility and observed that it was continuing to store and dispose of
hazardous waste in its surface impoundment. On December 31, 1985, TDHE
notified the facility that interim status was terminated and its application
for a final operation permit for the surface impoundment had been denied.
In January 1986, BIP informed TDHE that there was a typographical error
in the financial statement that made it appear that the facility did not have
enough state liability coverage. The question of loss of interim status is
still under discussion.
SUMMARY OF FINDINGS AND CONCLUSIONS
COMPLIANCE WITH INTERIM STATUS REQUIREMENTS
The Task Force investigated the interim status ground water monitoring
program implemented by BIP. The consensus opinion of the Task Force was that
this program is not fully in compliance with 40 CFR Part 265 Subpart F and
Tennessee Regulations Rule 1200-1-11-.05(6) . The following is a more detailed
summary of the inspection findings and conclusions.
-------
-3-
265.90 Applicability
According to this section of the regulations, an owner/operator of a land
disposal facility must implement a ground water monitoring "capable of
determining the facility's impact on the quality of the ground water in the
uppermost aquifer underlying the facility...". This program was to be
implemented by November 1981.
At the time of the Task Force inspection, BIP had not fully defined the
hydrology and geology of the site; had not documented flow directions and
gradients and noted any deviations from the norm; and had not defined the
vertical and lateral extent of confining units.
265.91 Ground Water Monitoring System
According to these regulations, an owner/operator must install a ground
water monitoring system that is capable of yielding samples for analysis; have
a sufficient number, location and depth of background monitoring wells that
are not affected by the facility and yield background quality in the uppermost
aquifer; and have a sufficient number, location, and depth of downgradient
wells to immediately detect any statistically significant amounts of hazardous
waste or hazardous waste constituents that migrate from the waste management
area to the uppermost aquifer. The monitoring wells must be adequately
constructed to obtain representative samples of the uppermost aquifer.
Wells GWM-1 through 6 were installed in April-October 1985. The well
system is not adequate to meet the 265.91 requirements because:
water-quality data indicate that background well GWM-1 had been
impacted by the facility;
method of well construction and well construction materials
may not enable representative ground water samples to be
collected from the wells;
not enough site-specific information is available to determine
if the downgradient wells are sufficient to immediately detect possible
ground water contamination.
265.92 Sampling and Analysis
This section of the regulations requires an owner/operator to obtain and
analyze samples from the RCRA monitoring system and to develop a sampling and
analysis plan (SAP) that should include procedures and techniques for:
a. sample collection
b. sample preservation and shipment
c. analytical procedures, and
d. chain-of-custody control.
Sampling procedures were not adequate because the electric water level
recorder was not sensitive enough to detect the low conductivity of the water
level in the well. The nitrogen gas displacement pump used for purging and
sampling aerated the samples so as to drive off volatile organics. It appears
that not enough water was removed from the wells prior to purging.
-------
-4-
It is the contention of the Task Force that the sampling and analysis plan
available for review at the time of the inspection was not sufficient to
satisfy the regulations. The SAP lacked information such as:
The specific analytical procedures which are utilized for each
parameter to be tested;
Examples of chain-of-custody records or sample analysis
request sheets were included in the SAP; and Quality
Assurance/ Quality Control procedures.
265.93 Preparation, Evaluation and Response
BIP had not performed a student's T-test at the time of the Task Force
evaluation. Only three quarters of analytical data were available for review.
A ground water quality assessment plan had not been prepared for this
facility.
265.94 Recordkeeping and Reporting
This section of the regulations requires an owner/operator to keep any
information regarding the ground water monitoring system on-site, and to
submit specific information to the proper authorities by specific dates. The
Task Force found that data pertinent to the ground water monitoring system was
kept on-site and was available for review. Submittals of ground water
monitoring data to the State and Federal agencies appears to be within the
time constraints posed by the 265.94 regulations. However, parameters thac
exceeded the NIPDWS were not identified in reports to TDHE or EPA.
-------
-6-
TECHNICAL REPORT
INVESTIGATIVE METHODS
The Task Force evaluation of BIP consisted of:
- A review and evaluation of records and documents from
EPA Region IV, TDHE and BIP.
- A facility on-site inspection conducted May 12-14, 1987.
- An off-site analytical laboratory evaluation.
- Sampling, analysis and evaluation of the ground
water monitoring system at the surface impoundment.
Records/Documents Review and Evaluation
Records and documents from EPA Region IV and the TDHE offices, compiled
by an EPA contractor (PRC), were reviewed prior to the on-site inspection.
During the inspection, the Task Force met with Mr. Stan Able, Plant Engineer
for BIP,and Fred Fischer and Phyllis Carman, geologic consultants for BIP.
Facility Inspection
The facility inspection included identification of waste management
units, identification and assessment of waste management operations and
pollution control practices and verification of location of ground water
monitoring wells.
Company representatives were interviewed to identify records and
documents of interest, answer questions about the documents and explain
(1) facility operations (past and present), (2) site hydrogeclogy, (3) ground
water monitoring system rationale, (4) the ground water sampling and analysis
plan and (5) laboratory procedures for obtaining data on ground water quality.
Laboratory Evaluation
The off-site laboratory facility handling the ground water samples was
evaluated regarding its respective responsibilities under the BIP ground
water sampling and analysis plan. Analytical equipment and methods, quality
assurance procedures and documentation were examined for adequacy.
Laboratory records were inspected for compliance with State and Federal
requirements. The ability of the laboratory to produce quality data for the
required analyses was evaluated. The evaluation results are discussed in a
later section of this report.
Ground Water Sampling and Handling
Sampling Locations
Water samples were collected from wells GWM-1, 2, 3, and 4. The selection
of these wells for sampling was based on location to provide areal coverage
both up and down gradient at the surface "impoundment. The locations are
identified in Figure 3.
-------
-7-
Samples were taken by the EPA contractor Versar and sent to EPA contract
laboratories for analysis. BIP requested and received split samples for all
the wells. EPA Region IV and TDHE declined to split samples for independent
analysis.
WASTE MANAGEMENT UNITS
Surface Impoundment and Emergency Overflow Ponds Description
According to facility reports, the surface impoundment is 100 feet by 175
feet and has a 14 foot depth at the center. The pond is clay lined and was
constructed about 1966. It contains approximately 1,000,000 gallons of water
and an estimated 650 cubic yards of material. The pond sediment is classified
as a hazardous waste (D008) because of the lead content. The pond is
susceptible to contamination from dyes and solvents from the flammable liquid
room and also functions as an emergency oil containment unit.
In 1983, samples of the sediment in the pond were analyzed and determined
to exceed the limits of lead according to the E.P. Toxicity procedures.
Discussions were held with TDHE to determine if the pond should be classified
as an impoundment. TDHE allowed the facility to perform a financial analysis
to determine if closure of the pond would be recommended. It was determined
that the pond was an integral part of the process and should not be closed.
TDHE then required the submittal of a ground water monitoring plan. The plan
was submitted and a ground water monitoring system installed April-October
1985.
The surface impoundment berm has had some seepage of the contents since
the early 1980's, if not earlier. The impoundment has also had overflow
problems, usually caused by heavy rainfall over a short period of time. Two
smaller emergency ponds were constructed in 1982 east of the impoundment to
collect any overflow. These ponds were approximately 50 feet long and 30 feet
wide with an average depth of 10 feet. These ponds were abandoned in 1984 and
were drained of any overflow. These ponds may be considered by EPA as regulated
units because they received hazardous waste from the surface impoundment.
Water and sediment samples taken from the seepage at the surface
impoundment have shown high lead values. Some of the lead may be a result from
the overflow and/or a result of water leaching through hazardous sludge in the
bottom of the impoundment.
Solid Waste Management Units
There are several units on site that are possible solid waste management
units (See Figure 4). Descriptions are as follows:
- Non-hazardous waste landfill (closed portion): Reportedly accepted discarded
wood, industrial hose and carbon black. However, at least two fires occurred
here, one of which burned solvents such as toluene, according to a PA/SI
performed by Tennessee's 3012 program on May 30, 1984.
-------
-8-
- Non-hazardous waste landfill (active portion): Contains discarded wood,
industrial hoses and carbon black from manufacturing processes; is permitted
by TDHE. A pool of standing liquid was noted during the Task Force inspection.
Gas bubbles would rise to the surface and break, leaving an oil slick on the
water in this pool.
- Container storage area: Contains drums of hazardous and non-hazardous waste
such as reclaimed waste lead oxide, toluene, MEK, waste oil, naptha, gasoline,
fuel oil and iso-cyanate foam containing menochlorobenzene. Black oily
material was noted on the ground around the drums during the Task Force
inspection.
- Storage tank facilities: According to facility records, these tanks are:
No.3 underground toluol (toluene?)
4 aboveground alcohol
5 aboveground MEK
6 aboveground floor cleaner
7 aboveground DDP
8 underground naptha (empty)
9 aboveground fuel oil
10 aboveground verisol
11 underground lubricating oil
12 aboveground waste oil
13 aboveground gasoline
15 abovegrour.d process oil
16 aboveground lubricants
17 aboveground lubricants/day tank
18 aboveground hydraulic oil
19 aboveground hydraulic oil
- Drainage ditches: There are plant drainage ditches on site, one of which
drains into the Hinson Hollow tributary. Water and sediment samples have shown
the presence of metals and volatile organic compounds.
- Surface impoundment overflows and berm seepage: The berm surrounding the
surface impoundment has overflowed'in the past and has shown leakage through
the berm. Water and sediment samples have shown metals and volatile organic
compounds. During the Task Force inspection, an oily black material was noted
on the north bank with some dead vegetation.
- Fires: The surface impoundment has been set on fire in the past (date
unknown) to burn off oil floating on the surface. The closed landfill has had
at least two fires in the past (dates unknown). One fire burned for three
months. Solvents were reportedly burned during one of the fires.
The facility should be required to submit information on the above-
mentioned units that would allow the Agency to determine whether or not these
are actually regulated units.
-------
-9-
GEOLOGY/HYDROLOGY
At the time of the Task Force inspection, boreholes were being installed
to determine the depth and thickness of a confining unit underlying the site.
Work was being performed by F.T. Fischer and Associates, GEOTECH Engineering
Company and Phyllis Garman of Barcon, Inc. These consultants are sub-
contracted by Alley, Young and Baumgartner, Inc., consulting engineers
retained by BIP in 1980-81.
The following is a summary of geologic and hydrologic information derived
from USGS, TDHE and BIP consultant reports.
Geology--
The site is located on the northeastern edge of a broad plateau in an area
of the Western Highland Rim that is highly dissected by steep natural
drainageways and stream valleys. The facility and waste management area are on
a highland ridge that forms a surface-drainage divide between East Fork Cane
Creek and Indian Creek.
The RCRA impoundment is a triangular reservoir constructed at the head of
a steep drainageway and is maintained with an earthen berm about 20 feet tall.
Material for constructing the berm came from on site. The berm has an
established grass cover but has leaked. The leaks indicate probable erosion
within the berm and have caused local conduits to develop. Surface water is
diverted from entering the pond on the south and east by a drainage ditch cut
around the perimeter. That ditch is deeply eroded (10 to 20 feet) in its
northern reaches.
Run-off water coming from the land on the western side of the impoundment
has cut an erosion ditch along the northern side of a hazardous chemicals
storage area. Leachate has been observed discharging from soils beneath the
concrete pad and flowing into the large impoundment via the erosion ditch.
Sediment analysis from this ditch showed high concentrations of lead and
chromium.
Two smaller impoundments are on the hill which rises from the east side on
the drainageway that contains the RCRA impoundment. These smaller ponds are
rectangular-shaped and interconnected. The water they receive was pumped
through a hose from the RCRA impoundment when there was a danger of overflow.
Soil excavated to construct the ponds was mounded along their northern
perimeter. This soil mound contributed the only significant amount of surface
run-off to the overflow ponds. Drainage on the hill where they are located
appears to be good, dividing toward a natural drainageway on the east and to
the previously-mentioned drainage ditch on the west. Slopes are gentle on the
hill-top but moderate to steep on the sides. Total relief on site is about 30
feet.
According to the Geologic Map of Kimmins Quadrangle (Marcher and Barnes,
1965), the site is underlain by the St. Louis and Warsaw Limestones. Both
units are deeply weathered to a sandy clay soil with blocks and nodules of
chert, some of which contain fossil coral and bryozoans. Site observation
shows the Tuscaloosa Gravel to be present as well. The geologic map shows that
this unit, which consists of large, rounded chert gravels in a sandy or
-------
-10-
tripolitic clay matrix, is present on many ridges in Kimmins Quadrangle,
though unmapped. The Tuscaloosa is well exposed in the eroded drainage ditch
mentioned before.
About 60 feet below the St. Louis residuum is the Ft. Payne Formation - a
cherty and silty limestone underlain by shale. Total thickness is about 300
feet. The Lower Mississippian-age Ft. Payne is predominately a calcareous
silica-stone that weathers to a cobbly and clayey residuum. The soils consist
of red to tan, brown silty clays with numerous chert nodules ranging in size
from gravel to boulders. The chert locally comprises up to 50 percent of the
soil matrix. Drilling at the site was often slow and difficult due to the high
silica chert content. Residual soils developed from the Ft. Payne are
typically thin. The Ft. Payne is unconformably overlain by the Tuscaloosa.
No structural deformities are mapped in the geologic formations of the
Kimmins Quadrangle. Bedrock jointing and solution features probably have
caused some minor, localized deformation in the region.
A geologic section through the RCRA monitoring wells, prepared by BIP
consultants is included as Figure 5.
Hydrology--
Surface drainage from the RCRA impoundment and overflow ponds is directed
northward by way of a man-made diversion ditch and a natural drainageway.
These drainage waters enter a northward-trending stream valley called Hinson
Hollow. The topographic quadrangle map shows the stream head for Hins'on Hollow
originating about 200 feet east of the BIP property line in a natural
drainageway. Topography suggests that a ground water divide, as well as a
drainage divide, may exist between the impoundment,overflow ponds, and stream
head.
Two aquifers are recognized at the site - the upper aquifer and the
production well aquifer (consultant's terminology). The upper or water-table
aquifer, occurs in residuum of the Ft. Payne Formation at depths of 25 to 45
feet. Direction of groundwater flow appears to be east-northeast. Based upon
field permeability tests, hydraulic conductivities range from 1.6 x 10-4 cm/s
to 8.8 x 10-4 cm/s.
The production well aquifer is much deeper than the Ft. Payne Formation.
The only information about this lower zone is from the facility's water supply
wells. The screened zone of water supply well No. 3 is over 200 feet below
land surface and water level is usually 110 feet lower than the water level in
the upper aquifer.
A pump test was performed in Fall 1985. The No. 3 production well was
pumped at 250 gallons gpm for 24 hours. Data collected during the pumping test
indicated no interconnection between the upper aquifer and the production well
aquifer. However, EPA and TDHE contend that the results are invalid because
the pumping test performed was inappropriate for the site's hydrologic
conditions, and not enough well construction data was available for the No. 3
well.
-------
-11-
Adequacy of the Hydrogeologic Characterization
The major sources of hydrogeologic information pertaining to BIP are the
facility RCRA Part B, the facility ground water monitoring reports, monitoring
well logs for the surface impoundment and borings done in the general area,
and from USGS and TDHE reports. Collectively, these sources address the
hydrogeology in both a general and site-specific manner. However, it is the
consensus opinion of the Task Force that at the time of the inspection, BIP
had not fully characterized the hydrogeology of the site, and that the
following steps should be taken to resolve the hydrogeologic issues:
1. Install additional borings for defining the vertical and lateral extent
of confining units. Delineate continuity, thickness, porosity,
permeability, etc.
2. Prepare a stratigraphic section across the site that would delineate
the water table, hydrogeologic units, perched zones, aquitards, etc.
3. Define the hydrologic characteristics of the uppermost and underlying
aquifers across the site. Determine the flow rate,interconnection, etc.
4. Delineate any recharge/discharge zones to the uppermost aquifer.
Determine if any ground water divides exist across the site.
5. Determine the potentiometric surface across the site and define the
.presence and magnitude of vertical gradients. Note any variability in
ground water flow direction.
GROUND WATER MONITORING PROGRAM DURING INTERIM STATUS
Ground water monitoring at the BIP facility has been conducted under the
State interim1 status regulations. The following is an evaluation of the
monitoring program between November 1981, when the ground water monitoring
provisions of the RCRA became effective, and May 1987 when the Task Force
investigation was conducted. A summary of the compliance history for this
facility has been included as Appendix D of this report.
Regulatory Requirements
Ground water monitoring at this site is now regulated by the Rules
Governing Hazardous Waste Management in Tennessee, which are basically the
equivalent of 40 CFR Part 265, Subpart F.
The State of Tennessee received Final Authorization to administer the RCRA
hazardous waste program on February 5, 1985. At that time, the State
regulations became enforceable in lieu of the Federal regulations. The State
interim status ground water monitoring requirements are found at Tennessee
Regulations Rule 1200-1-11-.05(6).
-------
-12-
MONITORING WELL DATA
Surface Impoundment
Alley, Young and Baumgartner, Inc. filed for a waiver from the ground
water monitoring requirements in October 1983. The consultant's contention
was that the clayey nature of the soils would prevent any ground water
migration. In February 1984, TDHE denied the waiver on the basis that the
gravelly nature of the geologic formation underlying the site could be
permeable to infiltration waters. The facility was then directed to submit a
ground water monitoring plan. After several NOV's, Commission Orders and
discussions between TDHE, EPA Region IV and the facility, a ground water
monitoring system was installed in 1985.Four ground water monitoring wells
were installed in April-October 1985. GWM-1 served as the upgradient well,
and GWM-2, 3, and 4 were the downgradient wells (See Figure 3 for locations).
A report on the "Well Installation and Geohydrologic Testing" was issued
in November 1985 detailing the results. According to the report, four borings
were converted to observation wells after drilling was completed by inserting
1.5-inch schedule 40 PVC pipe with 10 or 20-foot lengths of 0.010 inch slotted
well screen at the bottom of the hole. The annular spaces were filled with
sand 1 to 17 1/2 feet above the top of the screen. A 2-foot seal of bentonite
was placed on top of the sand and the remainder of the annulus was backfilled
to ground surface with a cement/bentonite mixture. Protective steel casings
with locking caps were placed over the well casings and grouted in place.
Nitrogen gas pumping systems were dedicated for each well. In March 1986, TDHE
requested that these pumps be removed because the samples collected with this
method might not be representative or accurate. At the time of the Task Force
evaluation, these pumps were still in place. Table 1 is a summary of well
construction data. Well logs are included in this report as Appendix B.
TDHE informed BIP in March 1986 that the wells were not constructed as per
the approved plan of April 1985. The sand packs which should extend no more
than 2 feet above the screen, were extended 1 to 17 1/2 feet higher than the
top of the screen. Also nitrogen gas pumping systems agitated the water column
so much as to drive off volatile organic compounds during sampling.
Ground water sampling began in'November 1985. Soon after, GWM-2 went dry
and eventually wells 3 and 4 also stopped yielding enough water for sampling
purposes. TDHE sited BIP with a NOV in October 1986 and requested more
hydrogeologic data be obtained to determine what measures were needed to
correct the situation. Consultants for BIP stated that the lack of water and
low yield in the wells was because of the drought conditions at that time. The
consultant's contention was that the wells yielded enough water for sampling
during normal environmental conditions and would yield sufficient water again
as soon as precipitation began to recharge the aquifer. Because of the drought
conditions, BIP did not think it appropriate to drill any additional or deeper
wells. A waiver on the time limitations (four quarterly samples taken within
one year) was requested on the basis that no precipitation recharge to the
aquifer precluded the possibility of contaminant migration.
In December 1986, TDHE responded to the waiver request by stating that it
may be justified provided the existence of an adequate confining layer could
be proven by borings and permeability tests. At the time of the Task Force
-------
-13-
inspection, borings were being drilled to determine the hydrogeologic
characteristics of the 'hard pan' layer underlying the site. Drilling was
difficult due to cherty nodules in the hole.
During the course of the Task Force inspection, it was discovered that all
wells contained substantial amounts of water. Because of the low conductivity
of the water and the small diameter of the well bore, the water level probe
utilized by the BIP sampling team could not read the water-level. The
sensitivity of the probe was not enough to read the low conductivity of the
ground water at the site (20 to 40 umhos/cm at 25 C).
The facility has been directed to remove the nitrogen gas systems in the
wells and use bailers to collect samples on an accelerated schedule.
After reviewing the monitoring well data for the surface impoundment, some
deficiencies were noted. The following is a summary of the deficiencies:
1. Sand packs are not intended to extend more than 2 feet above the
screen in a monitoring well. Sand packs in the BIP wells range from 1 to 17
1/2 feet above the screen. This may allow for a dilution factor that could
bias the water quality sampling results.
2. PVC is not recommended when organics are a contaminant. Teflon or
stainless steel might be more appropriate well construction materials.
3. The diariietey of the wells (1 1/2 inch) held the water level probe
tightly against the borehole. This, along with the probe's insensitivity to
low conductivities gave the impression that there was little or no water in
the well. It is recommended that future wells be no less than 2-inch diameter
and a more sensitive water level probe be used at the site.
Because of the erroneous water-level readings, a seasonal potentiometric
map has not been prepared for this site. Task Force water level measurements
indicated that GWM-1 is the upgradient well. However, there is not enough
information available to determine if the downgradient wells are sufficient to
immediately detect possible ground water contamination. Past water quality
analyses indicate that upgradient well GWM-1 may have been impacted by the
facility.
Production Wells
Three water supply wells exist on the BIP property, designated No. 1, 2
and 3. BIP consultants report them all as 225 feet deep with static water
levels of 160-180 feet below ground surface. Yield in No. 1 (6" diameter) was
reportedly 70-100 gpm. Yields in No. 2 and No. 3 (10" diameter) are reported
to be 300 gpm. Well No. 1 is not operational. All three are cased in steel.
Wells 2 and 3 have stainless steel screens in the lower 30-40 feet. All are
backfilled with sand and puddled clay and protected from surface water by a
6'X 6'concrete slab. These wells were installed in 1960.
Water samples were taken from well No.3 in 1981. The drinking water
standards"were met or exceeded for lead, mercury and selenium. TDHE sampled
wells 2 and 3 in November 1983 for metals. No parameter exceeded the drinking
water standards for either well.
-------
-14-
In October-November 1985, production well 3 was utilized in a 24-hour
pumping test to determine if there was interconnection between the upper and
lower aquifers. Results indicated that no connection existed between the
aquifers. TDHE and EPA contend that the results were invalid because the
pumping test performed was inappropriate for the site's hydrogeologic
conditions and that there was not enough data available on well construction
for well No.3.
Ground Water Sampling
The facility began their quarterly RCRA ground water monitoring program in
November 1985. Quarterly analyses were subsequently taken in February and May
1986. The facility did not sample for all of the 40 CFR Part 265.92 (b)(l)(2)
and (3) parameters during those three quarters (See Table 2). The facility did
not analyze for TOX - total organic halogen until May 1986 and did not take
the required replicates. The facility did not sample for nitrate until May
1986. Radium was not sampled for during these three sampling episodes.
During the first year of sampling, the NIPDWS for chromium and mercury were
met or exceeded in one or more of the monitoring wells, including the
upgradient well.
GWM-2 was dry and could not be sampled during February or May. The fourth
quarter sampling of October 1986 was not conducted due to an inadequate amount
of water in wells GWM-2, 3, and 4.
In October 1986, TDHE issued a Notice of Violation pertaining to the
ground water monitoring system. The major violations cited were as follows:
1. The wells were not constructed as per the approved plans.
2. Samples were not collected as per the approved sampling
and analysis plan in that the wells were not properly purged and
samples were aerated during sampling.
3. The system failed to provide one upgradient and three
downgradient wells capable of yielding ground water
samples. GWM-2 was dry since February 1986 and GWM-3
and 4 were extremely low 'yielding. Not enough information
was available to define a continuous confining layer underlying
the site.
4. Parameters that exceeded the NIPDWS were not separately
identified in a report to the Commissioner.
The facility was directed by TDHE to submit an adequate ground water
monitoring plan within 30 days. In late October, BIP consultants answered the
NOV, stating that lack of precipitation was the reason for little or no water
in the downgradient wells. The consultants did not consider drilling
additional wells because of the drought conditions, and requested a waiver on
the time limitations (four quarterly samples within one year). TDHE responded
by saying the waiver may be justified provided the existence of an adequate
confining layer could be proven by borings and permeability tests. At the time
of the Task Force inspection, borings and permeability tests were being
conducted to determine this information.
-------
-15-
It appears from all available historical water quality data the
contamination of the ground water has occurred at BIP. The Task Force
recommends that an assessment program be instituted to determine the
horizontal and vertical extent of the contaminant plume(s).
BOSTON INDUSTRIAL PRODUCTS SAMPLING AND HANDLING PROCEDURES
During the inspection, samples were collected from four wells for analysis
by the EPA contract laboratory. After The Task Force sampling, the facility
went through their sampling procedures at the upgradient well. The Task Force
observed the sample collection and handling procedures.
Samples are collected by Alley, Young and Baumgartner, Inc. personnel
which are consultants to BIP. The sampling personnel closely followed the
protocol established in the "Sampling and Analytical Procedures" prepared by
Alley, Young and Baumgartner, Inc. A copy is included as Appendix C in this
report.
The following is a summary of the sampling protocol followed by the
sampling personnel:
a. Water levels are measured using a current water level
indicator with probe. All measurements are recorded.
b. Wells are to be purged 1 1/2 to 3 well volumes using che
dedicated sampling device in .each well.
c. Connect air hose from the portable air tank to the air
line on the well. Regulate flow to produce a steady
even flow of water. Measure the flow rate and calculate
volume of water to be purged. Depressurize the well and
measure the water level.
d. Samples will be collected as soon as the well recharges by
means of the dedicated sampling device. Flow
should be regulated to produce a steady, even flow
to prevent aeration of the sample.
e. Collect each sample for organic analysis first.
f. Each well will have its own dedicated hose of Tygon or
equal material to prevent cross contamination. Each
hose will have a removable cap to prevent dirt from
entering the hose. Hose shall be flushed with deionized
water.
Some comments on the sampling protocol used by BIP are:
1. Gloves should be worn during sampling and should be
changed at each well.
-------
-16-
2. The water level indicator was hot sensitive enough to
read the low conductivity water. A more sensitive meter
is recommended.
3. The nitrogen gas displacement pump is a very awkward
procedure to use in the field with one person and may
be a possible source of contamination. The samples were
aerated so badly that all volatiles could be driven off.
Teflon bailers or bladder pumps are recommended for taking samples.
4. The Task Force recommends that wells be purged from 3 to 5
well volumes or to dryness. The purging procedure now used for the
BIP wells may not be sufficient to remove all standing water.
5. VGA's were collected in a plastic bottle then poured
into the VGA bottle. VGA samples should be collected
directly into the VGA bottle to prevent aeration.
6. Equipment was rinsed with deionized water then wiped with
a paper towel. Sampling equipment was carried in the back of an open
pick-up. Sampling equipment should be wrapped in aluminum foil
and not left exposed in the back of the pick-up.
In summary, the procedures utilized for ground water sampling at BIP are
not adequate. The RCRA ground water sampling and analysis plan (SAP) is also
not adequate to meet the requirements of 40 CFR Part 265.92 (a). These
requirements state that the SAP must contain procedures and techniques for:
1. Sample collection
2. Sample preservation and shipment
3. Analytical procedures, and
4. Chain-of-custody control.
The SAP does not include a specific analytical procedure for each
parameter or constituent which is analyzed or measured. Merely referencing EPA
600/4-79-020, latest edition, is not sufficient. Examples of the chain-of-
custody records and sample analysis request sheets should be included in the
SAP. The SAP should also discuss the Laboratory Quality Assurance/Quality
Control (QA/QC) program that will be used in the field and lab. There is no
reference to any measurements made in the field, such as pH, specific
conductivity, temperature, etc. There is no mention that field, trip or
equipment blanks are taken for QA/QC purposes. The SAP should include all of
this information in order to comply with all regulatory requirements.
TASK FORCE SAMPLE COLLECTION AND HANDLING PROCEDURES
This section describes the well evacuation and ground water sampling
procedures followed by Task Force personnel during the May 1987 site
inspection. Samples were collected by an EPA contractor (Versar) to determine
if the ground water contains hazardous waste constituents or other indicators
of contamination.
-------
-17-
Water samples were collected from wells GWM-1, 2, 3, and 4 at the surface
impoundment (See Tables 3 and 4). The selection of these wells was based on
location to provide areal coverage both up and down gradient at the RCRA unit.
Trip blanks were poured by Versar prior the the trip to the site. Field and
equipment blanks were poured at the site during sampling. A duplicate was
.taken from well GWM-2 for QA/QC control.
All sample bottles and preservatives were provided by an EPA contractor
laboratory (I-Chem). Samples were collected by the EPA sampling contractor
using the following protocol:
a. Total depth of the wells is determined by using a stainless
steel tape with a weighted bottom piece. Water level is
determined by using a Watermarker water level indicator.
b. Height and volume of water column is calculated.
c. Calculate three well volumes.
d. Purge three well volumes or to dryness using a pre-cleaned
Teflon bailer.
e. Upon initial opening of the well, the EPA sampling
contractor monitors the open well for chemical vapors using an OVA.
f. Collect sample aliquot and make field measurements.
g. Fill VOA vials first, then fill the remaining sample
containers in the order shown in Table 5.
h. Immediately place samples on ice in an insulated container
after filling the bottles.
The first step in the ground water well sampling procedure was to measure
the depth from a reference point at the well head. At BIP, that reference is a
known elevation at at the top of the well casing. The EPA sampling contractor
used a Watermarker water level to measure the depth of water. The tape was
rinsed with hexane applied on a Kimwipe, then rinsed with organic free HPLC
water. Water level measurements were made to within 0.01 foot.
The volume of water to be purged was then calculated. The column volume of
a well is the volume of standing water in the well and is calculated using the
depth-to-water measurement, total well depth (determined in the field with a
well sounder) and casing radius.
For purposes of the Task Force, the column volume is multiplied by three
to compute the purge volume. In all cases, standard field measurements
(temperature, pH, specific conductivity) were taken intermittently prior to
sampling.
The wells were purged by the EPA sampling contractor using a pre-cleaned
Teflon bailer that was lowered into the well with Teflon-coated stainless
steel cable. The purge water was evacuated into a 5-gallon bucket. The
facility then disposed of the purge water into the water treatment system.
Before sampling, chemical vapor readings were taken from the wells. All
readings were noted as less than 1.0 ppm.
Samples for metals were preserved in the field. Samples were packaged and
shipped to the EPA Contract Laboratory on a daily basis. All samples were
-------
-18-
shipped according to applicable Department of Transportation regulations (40
CFR Part 171-177). All water samples from the monitoring wells were considered
"environmental" for shipping purposes.
LABORATORY EVALUATION
The off-site contract laboratory facility, Specialized Assays (SA),
Nashville, Tennessee, that conducts the analytical analyses for the Subpart F
Ground-Water Monitoring samples-for BIP, Hohenwald, Tennessee, was evaluated
on November 2, 1987. The laboratory is a subcontractor for the consulting
engineering firm Alley, Young & Baumgartner, Inc. (AYB), Brentwood, Tennessee.
Specialized Assays contracts the fecal coliform analyses out to Middle
Tennessee Laboratories, Nashville, Tennessee, and ths radiological analyses
out to Controls for Environmental Pollution, Inc.(CEP), Santa Fe, New Mexico.
These laboratories were not visited during the inspection. The SA laboratory
was evaluated for its ability to produce quality data for those parameters
required by Part 265.92(b)(1),(2),(3), and by the Tennessee Department of
Health and Environment. See Table 7 for the parameters evaluated during the
inspection at the contract laboratory.
Analytical equipment, sample handling, holding time, preservation
techniques, methods and quality assurance procedures were examined for
adequacy. Laboratory records were reviewed for completeness, accuracy and
compliance with State and Federal requirements.
Ground-Water Sampling and Analysis Plan
The documents reviewed during the inspection were:
1. "Generic Quality Assurance Plan," SA, June 1986.
2. "Statement of Qualifications," SA.
The sample containers prepared by SA were prelabeled for the required
parameters and shipped to the AYB. Premeasured preservatives for each sample
were shipped in the sampling bottles or in small vials. The sample containers
and preservatives meet the EPA requirements. SA periodically checks the
sample preservation, where pH adjustment is required, after the samples arrive
in the laboratory.
Sample containers, preservatives, and holding times were consistent with
EPA requirements, except for the fecal coliform and radiological analyses.
The samples for fecal coliform analyses did not meet the 6-hour holding time
requirement, and the radiological samples were preserved after arriving at
CEP. See Table II-1, Test Methods for Evaluating Solid Waste - Physical/
Chemical Methods. SW-846 (3rd Edition, 1986).
Field measurements (pH and temperature) conducted by AYB personnel were
not observed by the laboratory auditor. Specific conductance was conducted on
a single grab sample in the laboratory. Based on the requirements for
detection monitoring (Part 265.93), the owner/operator must collect a
sufficient volume of ground water to allow for. the analysis of four separate
replicates. The laboratory method used by SA was an approved method.
-------
-19-
However, the specific conductance meter was not calibrated daily against a
standard of known value, and the cell constant at 25° C had not been
determined previously.
Regulatory Requirement: The cell constant must be determined prior to
measuring the sample conductance, and the specific conductance meter/electrode
system must be calibrated daily against a fresh standard that is near the
expected sample conductance. See Method 9050, SW-846; Method 150, Standard
Methods for the Examination of Water and Wastes (Standard Methods), 16th
Edition (1985); or Method 150, Methods for Chemical Analysis of Wastes and
Wastewater (EPA Methods), EPA-600/4-79-020, and all current revisions.
Samples for dissolved metals were not filtered on-site by AYB, but were
shipped to the laboratory for filtration.
Regulatory Requirement: Samples for dissolved metals must be filtered
on-site, preserved with HNOo to pH <2, and stored in dark bottles if silver
analysis is conducted. See Table II-l, SW-846.
Laboratory Sample Analysis
If TOG samples cannot be analyzed immediately, preservation by lowering
the sample pH to less than two (<2) is required. AYB was preserving the
samples to meet this requirement to retard any biological action during
shipping and prior to analysis. The inorganic carbon constituents are
normally removed by lowering the sample pk,.followed by purging with an inert
gas, prior to measuring the TOG. This technique, used for total organic
carbon (TOG) samples preserved with t^SO/ would cause volatiles to be
stripped from the sample during the sample preparation step to removed
inorganic carbon (C02) prior to measurement of the organic carbon. The method
detection limit for TOG (approximately 1 mg/L) is at least one to two orders
of magnitude above the concentration of the volatile organic components of the
TOG. However, these volatiles should be detected in the VOA analysis.
Therefore, the emphasis on organic contamination should be placed on the VOA
results instead of the TOG data.
Samples for phenol analysis were preserved with HoSO- to pH <2 and were
analyzed by Method 510, Standard Methods. The contract laboratory did not
raise the sample aliquot pH to 4 prior to the distillation step, and the color
development was conducted at pH 7.0. This practice may result in data biased
low for this parameter.
Regulatory Requirement: The approved procedures, (Method 420.1, Standard
Methods for the Examination of Water and Wastewater, 14th Edition (1975);
Method 9065, SW-846; and Footnote 25, 40 CFR Part 136, Guidelines
Establishing Test Procedures for the Analysis of Pollutants. Federal Register,
June 30, 1986) require that the sample pH be raised to approximately 4 prior
to distillation and color development at pH 10.
Nitrate analyses were conducted by a non-approved specific ion electrode
method. The method performance below 10 mg/L was poor and appeared to produce
data, that were questionable .
-------
-20-
Regulatory Requirement: An approved method such as Method 9200, SW-846;
Method 353.3, EPA Methods; or Method 418C, Standard Methods, should be used.
Samples for oil and grease were collected in glass quart jars and
analyzed by Method 503A, Standard Methods. The analysis was conducted on a
500 ml aliquot which could cause a negative bias.
Regulatory Requirement: Collect a representative sample in a wide-mouth
glass bottle for oil and grease determination and do not subdivide in the
laboratory. See Method 503, Standards Methods, or Method 413.1, EPA Methods.
Aqueous samples for mercury analysis were not carried through the heated
potassium persulfate digestion step. This could cause a negative bias if
organic-mercurials were present.
Regulatory Requirement:
Aqueous samples must be digested with potassium persulfate and heated for
2 hours in a water bath at 95°C. See Method 7470, SW-846, Method 245.1, EPA
Methods; or Method 303F, Standard Methods.
Organic analyses for volatile organics, base-neutral/acids and pesticides
were conducted by the Contract Laboratory Protocol (CLP) or by Methods 608,
624 and 625, EPA Methods. GC/MS system performance checks were acceptable,
except for the July sampling event. The GC/MS system was not calibrated every
12 hours as required in the quality assurance requirements in these methods.
The deviation would not have a major impact on the July data reported, as the
samples analyzed after the 12 hours were field and trip blanks and no
contaminants were detected.
Quality Assurance and Data Documentation
The SA laboratory has established a formal quality assurance (QA) program
that consists of a QA plan, standard operating procedures (SOP) and includes
the use of duplicates, spikes, and reference standards to verify the quality
of data for each parameter analyzed. Instrument calibration and maintenance
records were maintained, and temperatures of regulated devices were checked
and documented. All raw data, quality control records and calculations were
documented and maintained on file as required. Method detection limits (MDL)
were determined according to procedures in EPA's 40 CFR Part 136, Appendix B.
When matrix interferences or some other problem prevents the routine reporting
of MDLs, the laboratory reports a Practical Quantitation Limit (PQL), which is
proper protocol as stipulated in the guidelines for EPA's Contract Laboratory
Program for reporting data with sample matrix interferences.
Summary
Based on the overall findings, the contract laboratory has the capability
to provide acceptable quality data for the ground-water monitoring program.
Laboratory filtration of samples for dissolved metals could cause biased data
for the dissolved parameters listed in Table 7. The deficiencies noted for
specific conductance, phenol, nitrate, mercury, and .oil and grease could cause
the"results to be questionable and subsequent failure of the Student's t Test.
The deficiencies noted for fecal coliform holding time and radiological
-------
-21-
preservation would cause the data to be questionable. The deficiencies noted
for TOG and organics would have no major impact on data quality.
All other analytical data for parameters listed in Table 7 would be
acceptable for the Subpart F, .Ground-Water Monitoring.
MONITORING DATA ANALYSIS
Inorganic Elements/Compounds
The contract laboratory data indicated that fifteen elements and
compounds were detected in samples collected from the monitoring wells at BIP.
None of the parameters analyzed for exceeded the National Interim Primary
Drinking Water Regulation limits. The Secondary Drinking Water Regulation
limit of 50 ug/1 was exceeded in well 1 (860 ug/1) and well 3 (600 ug/1).
Lead concentrations ranged from not detected in well 4 to 26 ug/1 in well 1.
Analytical data for zinc and chromium is suspect or unusable because of
laboratory error.
POC. POH. Chlorinated Compounds
The majority of this analytical data is considered suspect or unusable
because the analytical results could not be verified, or holding times were
exceeded or because of laboratory error.
Extractable Organic Compounds
The majority of the contract laboratory data was not usable because of
laboratory error. Resampling and reanalysis are necessary for verification.
Purgeable Organic Compounds
Again, as with the extractable data, the majority of the purgeable data
was not usable. Blank contamination was a factor. Most actual values given
are estimated. Any further discussion of the results would be pointless.
-------
REFERENCES
Civil Litigation Report: Prepared by US-EPA Region IV ORC for the Department
of Justice, April 1986.
Pump Test Results: Prepared by Gannon Geologic Consulting for Boston
Industrial Products, December 1985.
Well Installation and Geohydrologic Testing: Prepared by Geotek Engineering
Company for Boston Industrial Products, November 1985.
Waste Stream Inspection Report for the Dana-Boston Industrial Plant; prepared
by US-EPA Region IV, ESD, July 1985,
Revisions to Boston Industrial Product's Part B Application: February 1985.
Part B Application: Prepared by Alley, Young and Baumgartner, Inc. for Boston
Industrial Products, September 1984.
Letter from Alley, Young and Baumgartner, Inc. to the Tennessee Division of
Solid Waste Management regarding production wells at the Boston Industrial
Products Plant.
Geologic Map of Kimmins Quadrangle: Marcher and Barnes, 1965.
-------
Figure 1
Facility Location Map
Boston Industrial Products
Hohenwald, Tennessee
-------
Group I - Equipment
water - boiler,
grade hose/
that runs off
vulcanizer
etc.
\<2> MA in
well
for food
Group II - Equipment that requires
chilled water - extruder cooling
troughs, mill drums, slab
cooli ng, etc.
Group III - Equipment that uses
cool water - vulcanizer wash water,
heat zone temperature controllers
on extruder barrels, air
compressor cooling, lead press
and lead extruder cooling
streams, etc.
Group IV - Facilities and equipment
supplied by City of Hohenwald
municipal water supply - plant
personnel wash basins and shower
rooms, laboratory wash basins.
Figure 2
New Water System
Boston Industrial Products
Hohenwald, Tennessee
-------
B All
Line
-j-
ItaMHMF
BOSTON
INDUSTRIAL
PRODUCTS
v
\
f
1
;t_J-
-9SO
GMW 1
^ -fi od uc lion
well K2
product ion
wolJ » 3
P^OPCRTY
VP r f1ow
pon J s
GMW
55Q.
910.
I
M.ir.irrt oils
w ii ! t o S.
-ti u r f n cc,,^^
M i mpoun (Imp u
I ( c 1 o s o (1)
11W 3
Approxjmatc
Landfill1
ca t i 01
nESIOENTIAO
'920
*o
\o
\o
Figure 3
Facility Map witli Well Locations
Boston Industrial Products
Hohenwald, Tennessee
-------
30STOS IXDl'STRIAL PRODUCTS
LECZSP
1. Pond-approx.l,000,000 gal.
2. Flamaable liquid aix rooa.
3. Toluol storage tank-4000 gal.
4. Alcohol storage' tank-1500 gal.
5. HEK storage cank-500 gal.
6. Floor cleaner storage tank-2500 gal.
7. DDP storage tanlc-500 gal.
8. Naptha storage tank-3000 gal.
9. No.2 fuel oil storage tanks-:330000 gal.
10. Verisol storage tank-250 gal.
Oil drua storage-55 gal. druas
Oil and Hazardous drua storage-55 gal.drums.
Gasoline tank-1000 gal.
Gasoline dispenser.
Process oil storage tanks4312000 gal. each.
Drua storage-55 gal. druns.
Process oil day tanks-431300 gal. total.
Hydraulic oil storage-500 gal.
Figure 4
Location of Potential Solid Waste Management Units
Boston Industrial Products
Hohenuald, Tennessee
-------
"TO*
-rss-
u
o
ca
<
TIJ-
rm-
^ DOMINANTLY GRAVEL
SAND
CLAY
CHERT
VERTICAL SCALE: 1' 10*
HORIZONTAL SCALE: 1 100
Figure 5
Geologic Section Through
the RCRA Monitoring Wells
Boston Industrial Products
Hohenwald, Tennessee
-------
MONITORING WELL CONSTRUCTION DATA
Well
Number
Gradient
Date
Drilled
Total Depth
Drilled
(ft)
Well Casing/ Screened Sand Pack Elevation
Depth Screen Interval Amount above relative
(ft) Material (ft) Length top of csg to MSL
GWM-1
GWM-2
GWM-3
up
down
Apr '85 75.5
Apr-Oct
'85
down Oct '85
103.0
35.1
75.5
85.0
35.0
li"- PVC/
0.010" PVC
55.3-75.3
65-85
25-35
30
37.5
15
10
17.5
962.96 .
961.50
942.45
GWM-4
down Oct "85
57.0
54.0
34-54
21
929.60
-------
TABLE 2
RCRA GROUND WATER MONITORING PARAMETERS
*Category 1 **Category 2 ***Category 3
Arsenic Chloride pH
Barium Iron Specific
Cadmium Manganese Conductance
Chromium Phenols TOG
Fluoride Sodium TOX
Lead Sulfate
Mercury
Nitrate (as N)
Selenium
Silver
Endrin
Lindane
Me thoxychlor
Toxaphene
2 ,4-D
2,4,5-TP Silvex
Radium
Gross Alpha
Gross Be ta
Turbidity
Coliform Bacter-ia
*EFA Interim Primary Drinking Water Standards
**Ground Water Quality Parameters
***Ground Water Contamination Indicator Parameters
All parameters listed above are to be monitored quarterly for
one year to establish background concentrations for each
parameter. Four replicate measurements are to be taken for
Category 3 parameters for the upgradient well during each
sampling event for this'period. After the first year,
Category 3 parameters are to be monitored semi - annually, and
Category 2 parameters are to be monitored annually.
-------
TABLE 3
SAMPLE COLLECTION DATA
Traffic
No.
KQ981
MQ982
MQ983
MQ984
MQ985
MQ986
MQ987
MQ989
Sample
Point Date
GWM-1 5-12-87
GWM-2 5-13-87
GWM-2 5-13-87
dup .
GWM-3 5-13-87
GWM-4 5-13-87
field 5-13-87
blank
equipment 5-13-87
blank
trip 5-09-87
blank
Parameter
Time Sampled
1315 VOA,POC,POX,
Extrac table
organics ,
Total and
Dis solved
Metals
0930
0930
1300
1425
1650
1630
1030
-------
TABLE 4
FIELD MEASUREMENTS
Well Date Water Level
Number Sampled (in ft from
top of csg)
GWM-1 5-12-87 51.71
GWM-2 5-13-87 57.19.
GWM-3 5-13-87 21.49
GWM-4 5-13-87 37.0
Total Depth Gallons Time
of well Purged
(in feet)
75.63 3.0 1227
1248
1536
84.82 5.0 1621
0916
0932
35.53 5.5 10A'3
1124
53.98 6.5 1335
1414
5
5
5
5
4
5
5
5
4
4
pH
.78
.75
.48
.71
.98
.04
.39
.21
.6
.12
Temp.
°C
18
18
21
18
20
18
19
19
18
19
.7
.4
.3
.5
.0
.0
.0
.0
.0
.0
Specific
Cond.
(umhos)
45
45
38
52.
35.
34.
56.
33.
34.
28.
.4
.0
.0
0
4
6
5
9
6
2
OVA Turbidity Remarks
(ppm) NTU
well not locked;
, n 10Q inner casing coated
1 . U loo
with orange clay;
pulled inner casing
out and sampled
with Teflon bailer.
purged 5-12-87;
sampled 5-13-87;
1.0 19 pulled inner casing;
out and sampled
with Teflon bailer.
1.0 18 pulled inner casing
out and sampled
with Teflon bailer.
1.0 15 pulled inner casing
out and sampled
with Teflon bailer.
-------
TABLE 5
ORDER OF SAMPLE COLLECTION,
BOTTLE TYPE AND PRESERVATIVE LIST
Parameter Bottle Preservative
Volatile Organic Analysis (VOA) 2 40-ml VOA vials
Purgeable Organic Carbon (POC) 1 40-ml VOA vial
Purgeable Organic Halogens (POX) 1 40-ml VOA vial
Extractable Organics 3 1-liter amber glass
Total Metals 1 1-liter plastic HN03
Dissolved Metals 1 1-liter plastic HNO
-------
PAGE
5,17444. TBL
TABLE 6
HHGHTF ANALYTICAL DATA SUMMARY
BOSTON INDUSTRIAL PRODUCTS
HOHENHALD, TENNESSEE
HELL 1 HELL 2 HELL 2 HELL 3 HELL 4 Field Equip. Trip
(dup.) Blank Blank Blank
05/12/87 05/13/87 05/13/87 05/13/87 05/13/07 05/13/87 05/13/87 05/03/87
INORGANIC ELEMENT/COMPOUND
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
SILVER
E'ORQN
BARIUM
CADMIUM
COPPER
MOLYBDENUM
NICKEL
LEAD
STRONTIUM
TELLURIUM
TITANIUM
YTTRIUM
ZINC
ZIRCONIUM
MERCURY
ALUMINUM
MANGANESE
CALCIUM
MAGNESIUM
IRON
SODIUM
CHROMIUM, HEXAVALENT
POTASSIUM
GENERAL ORGANIC PARAMETERS
FURGEABLE ORGANIC CARBON
PURGEABLE ORGANIC HALOGEN
SELECTED CHLORINATED COMPOUNDS
2,4-D
2, 4, 5-1 P
2,4,5-T
CHLOROBENZILATE
EURACTABLE ORGANIC COMPOUNDS
DI-N-BUTYLFHTHALATE
NA
74
1
11
NA
98
26
NA
NA
NA
NA
98
NA
2100
B60
MG/L
6.4
0.56
15J
3.8
UG/L
NA
MG/L
0.70
MG/L
0.04
UG/L
NA
UG/L
l.OUR
0.1UR
0.1UR
l.OUR
UG/L
NA
~
NA
5
NA
NA
NA
NA
26
NA
170
6
MG/L
0.85
0.22
0.77J
5.1
UG/L
NA
MS/L
MG/L
0.02
UG/L
NA
UG/L
l.OUR
0.1UR
0.1UR
l.OUR
UG/L
__
NA
NA
NA
NA
NA
NA
23
NA
~
130
5
MG/L
0.86
0.23
0.53J
5.1
UG/L
NA
MG/L
MG/L
0.05
UG/L
NA
UG/L
l.OUR
0.1UR
0.1UR
l.OUR
UG/L
__
5
NA
34
~
NA
10
NA
NA
NA
NA
44
NA
0.8JII
1100
600
MG/L
4.4
0.68
6.9J
6.0
UG/L
NA
MG/L
0.72
MG/L
0.03
UG/L
NA
UG/L
l.OUR
0.1UR
0. 1UR
l.OUR
UG/L
2JK
5
NA
NA
NA
NA
NA
NA
NA
0.7JN
82
9
MG/L
0.77
0.33
0.42J
5.0
UG/L
NA
MG/L
--
MG/L
0.03
UG/L
NA
UG/L
l.OUR
0.1UR
0.1UR
l.OUR
UG/L
.._
6
NA
--
NA
--
NA
NA
NA
NA
~
NA
MG/L
--
0.05J
0.20
UG/L
NA
M6/L
MG/L
0.02
UG/L
NA
UG/L
l.OUR
0.1UR
0.1UR
l.OUR
UG/L
-.-
._
NA
--
9
NA
~
NA
NA
NA
NA
--
NA
69
--
MG/L
0.06J
0.23
U6/L
NA
HG/L
HS/L
0.06
UG/L
11
UG/L
l.OUR
0. 1UR
0.1UR
l.OUR
UG/L
NA
~
--
NA
--
NA
NA
NA
NA
NA
NA
~-
MG/L
--
~
UG/L
NA
MG/L
MG/L
0.06
UG/L
34
UG/L
l.OUR
0.1UR
0.1UR
l.OUR
UG/L
-------
PAGE
SM7444.TBL
TABLE 6
HHGHTF ANALYTICAL DATA SUMMARY
BOSTON INDUSTRIAL PRODUCTS
HOHENHALD, TENNESSEE
WELL 1 HELL 2
05/12/87 05/13/87
HELL 2
(dup.)
05/13/87
HELL 3 HELL 4
05/13/87 05/13/87
Field Equip. Trip
Blank Blank Blank
05/13/87 05/13/87 05/03/87
-EXTRACTABLE ORGANIC COMPOUNDS
PHENOL
2,6-DICHLOROPHENOL
3,3'-DlHETHYLBENZIDINE
DI-N-PROPYLNITROSAMINE
DIBENZO(A,E)PYRENE
DIBENZO(A,H)PYR£NE
DIBENZO(A,J)PYRENE
METHAPYRILENE
N-NITROSODI-N-BUTYLAMINE
PURGEABLE ORGANIC COMPOUNDS
METHYL ETHYL KETONE
TRANS-1.2-DICHLQROETHENE
CHLOROFORM
TRICHLOROETHENE(TRICHLOROETHYLENE)
TOLUENE
ACROLEIN
ACRYLONITRILE
ISOBUTYL ALCOHOL
1,4-DIOXANE
CROTONALDEHYDE
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
U6/L
10UR
100UR
10UR
10UR
10UR
10UR
SOUR
10UR
10UR
100UR
10UR
10UR
10UR
10UR
SOUR
10UR
10UR
100UR
10UR
10UR
10UR
10UR
SOUR
10UR
~
10UR
IOOUR
10UR
10UR
10UR
10UR
SOUR
10UR
10UR
IOOUR
10UR
10UR
10UR
10UR
SOUR
10UR
~
10UR
IOOUR
10UR
10UR
10UR
10UR
SOUR
10UR
6J
10UR
IOOUR
10UR
10UR
10UR
10UR
SOUR
10UR
--
10UR
IOOUR
10UR
10UR
10UR
10UR
SOUR
10UR
UG/L
10UR
UG/L
10UR
UN
UG/L
10UR
UG/L
10UR
5
UG/L
10UR
7
UG/L
10UR
U
UG/L
260J
UG/L
320J
4JN
8JN
SOUR
130J
SOUR
~
SOUR
5000UR
SOUR
SOUR
5000UR
SOUR
__
SOUR
5000UR
SOUR
SOUR
SOO'OUR
SOUR
SOUR
5000UR
SOUR
300UR 300UR
30000UR 30000UR
300UR 300UR
ttl*timtlHtliIffimmm*itilttfimiitfftiiiffit*fifimit
"FOOTNOTES***
NA - NOT ANALYZED
J - ESTIMATED VALUE
N - PRESUMPTIVE EVIDENCE OF PRESENCE OF MATERIAL
-- - MATERIAL HAS ANALYZED FOR BUT NOT DETECTED
U - MATERIAL HAS ANALYZED FOR BUT NOT DETECTED. THE NUMBER IS THE MINIMUM QUANTITATION LIMIT
R - QUALITY CONTROL INDICATES THAT DATA ARE UNUSEABLE, COMPOUND HAY OR HAY NOT BE PRESENT
RESAMPLING AND REANALYSIS IS NECESSARY FOR VERIFICATION, THE VALUE IS THAT REPORTED BY THE LABORATORY
-------
Table 7
Parameters Characterizing the Suitability of the Ground-Water
as a Drinking Water Supply
Appendix III
Arsenic Endrin
Barium . Lindane
Cadmium Methoxychlor
Chromium Toxaphene
Fluoride 2,4-D
Lead 2,4,5-TP (Silvex)
Mercury Gross Alpha
Nitrate (as N) Gross Beta
Selenium Fecal Coliforms
Silver Gross Alpha
Parameters Establishing Ground-Water Quality
Chloride Iron
Manganese Sodium
Phenols Sulfate
Nickel
Parameters Used As Indicators of Ground-Water Contamination
Specific Conductance Total Organic Halogen
pH Total Organic Carbon
Parameters Required by
Tennessee Department of Health and Environment
Trichloroethylene Toluene
2-Butanone Oil & Grease
Dissolved Metals
Iron Manganese
Sodium Sodium
Arsenic Barium
Cadmium Chromium
Lead Mercury
Selenium Silver
Nickel
-------
APPENDIX A
Task Force Analytical Results
Boston Industrial Products
Hohenwald, Tennessee
Due to size, the raw data is not included in this
report. A copy of the data can be requested from:
EPA, Region IV
Residuals Management Branch
Waste Compliance Section
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404) 347-7603
-------
8321 OAK RIDGE HIGHWAY KNOXVILLE, TN 37931 615/690-0128
GEOTEK
ENGINEERING COMPANY
OBSERVATION WELL INSTALLATION DATA
n.i.- 3-1-35
Ohi rviHon Well Ho *
mining M.ttxjct Air Rotary
DHtllrvj Fluid: Water
Obter*«t!on Wall Screen: 1-5-in
M«ihod of Development Surged
STRATIGRAPHY
Soli Type Depth
Clay, Sandv 0.0 '-4.0'
Sand, Clavev 4.0 '-8.0'
Clay, Sandy 8.0'-42.0'
Gravel 4Z.O'-45.Cf
Sand & Cherc 45.0'-65.0'
Clay, Sandy 65.0'-75.5'
WATER LEVEL
READINGS
Depth *
Dele Below Well Head Elev«Uon
10-22-85 56.2'
10-23-85 55. I1
10-24-85 55.3'
10-29-85 55.5'
10-30-85 55.4'
10-31-85 55.4'
fnntflf-M by Ronald Rav ._. ... .
-,!_ Others
. Schedule 40 PVC, 0.010-in. slotted.
with formation water, approximately one hour.
Stlckup
w/Well Head
tcu *=»<(({ ?^
)ii) f*z.))))^&
n n \t i MI
1 S -In I D
PVC Riser
Cement
BwitooJts Oeil >
8tnd Filter >
Obeervallon
Well Screen
3.
* '
J N
0
b.[
y
(t
;.'-
.'..
".".'
::
'.C
'o
J's
?
v-*
Elev.* P*otf>
(1.2M
0.0'
43.3'
45.3'
55.3^
75.3'
Command:
- >| 0.4' L
*Elevatior.s are not presently available.
DOCKET NO.
-------
Monitoring Well #1 - Boston Industrial Products, Hohenwald, TN
Interval(feet) Description
0-4
\J-
5-
10-
15
20-
25
30
40-
45
SO-
_)VJ
55
60-
70-
75-
" ~^_[
'.TT^T.v
-. i^c r '.
s
~5~^ ~
. : __z^'
-^7.2
ys^-"
:^H-
.- rT^r_
^Ei
* .-"^
fc-x V^\
~^~i.
i%P.^
>TT:!>
OT7r
""» ^V " *
* ^i * ^
* jS. * * ' *
£^ ^* *
^^
A.
-^S
T^-t-T
' O&. Q'
. -~_ ~%
A - A
4 u
6-8
8-15
15 - 23
23 - 25
25 - 30
30 - 35
- 35-42
42 - 45
50 - 55
55 - 65
65 - 75.5
Total dep
Clay, sandy, medium to coarse to very coarse grained
quartz sand, subangular to subrounded, with scattered
larger subrounded chert grains and rounded pebbles of
chert & quartz; poorly sorted; slightly moist to dry;
brown to more reddish-browntat 3 feet.
Sand, clayey; coarse-grained, subangular, with sub-
rounded pebbles of chert & quartz; poorly sorted;
slightly moist to dry; reddish-brown.
Sand, clayey; coarse-grained to very coarse grained,
subangular to subrounded, poorly sorted; slightly
moist to dry; yellowish-brown to brownish-red.
Clay, sandy; medium- to coarse-grained quartz sand, sub-
rounded, with few subangular, scattered chert pebbles;
poorly sorted; slightly moist; yellowish-brown to reddish-
brown.
Same, with scattered subrounded chert & quartz pebbles,
poorly sorted; slightly moist; reddish-brown.
Same, but yellowish-brown.
Clay, sandy; medium-grained quartz & chert sand, sub-
angular to subrounded, with scattered larger subrounded
chert & quartz pebbles; poorly sorted; moist; brown.
Same, more clayey at 33-35 feet.
.Same.
.bur, brown to' yellowish-brown.
Gravel, chert & quartz, subangular to subrounded, with
matrix of medium- to coarse-grained quartz sand; poorly
sorted; wet; ye]lowish-brown; WATER at 45 feet.
Sand, clayey, very fine grained, subrounded, with some
scattered coarser grains of chert & quartz, subrounded,
medium-sorted, wet; yellowish-brown.
Sand, very clayey; and bedded chert; sand, medium-grained,
subangular, medium-sorted; yellowish-brown; wet. Very
tough to drill; auger coupling broke.
Chert, bedded, with mixed sandy clay, sand fine- to medium-
grained, subrounded, medium-sorted; yellowish-brown; very
wet. Very little return; tough to drill.
Clay, sandy, fine- to medium-grained, subrounded, medium-
sorted; with angular chert cobbles; yellowish-brown;
Clay somewhat plastic.
Water level after drilling complete & day after =29.9 feet
DOCKET NO.
-------
8321 OAK RIDGE HIGHWAY KNOXVILLE, TN 37931 615/690-0128
GEOTEK
ENGINEERING COMPANY
OBSERVATION WELL INSTALLATION DATA
Ds!«:
9-25-85
ObitrviHon WelfNo": 2
'Drilling M»tho|
*Elevations are not presently availabl
(1.2')
0.0'
45.5'
47.5'
65.0'
85.0'
^B^W_^M^^
85.0'
DOCKET NO.
-------
Monitoring Well #2 - Boston Industrial Products, Hohenwald, TO
Interval(feet) Description
0 - 9 Clay, sandy, (fill) medium- to coarse-grained quartz,
with scattered subrounded quartz pebbles, poorly sorted;
yellowish-brown with some iron staining.
(Using water to drill)
9-20 Gravel, clayey; quartz & chert, subrounded to s'ubangular,
poorly sorted, white to yellow, and brown to reddish-brown.
20 - 35 Gravel, clayey; chert, from very coarse grains to pebbles,
subrounded to subangular; poorly sorted; pebbles white to
brown in yellowish-brown matrix.
(Set 34 feet of 6" ID PVC casing to stabilize side walls
of drill hole).
35 - 55 Clay, sandy, with V to 1" diameter chert & quartz gravel,
well-rounded; poorly sorted; very friable; sand, fine- to
medium-grained; yellowish-brown; gravel, very light gray,
reddish-brown, & light bluish gray.
55-59 ' Sand, clayey, fine- to coarse-grained quartz & chert;
yellowish-brown; with coarse chert gravel, angular, poorly
sorted; reddish-brown to light bluish gray.
(Kan in-situ permeability test on 35- to 59-foot interval.
results = 2.1 X 10~7cm/sec).
59 - 69.5 Chert, silty, sandy, mixed with tight clay; medium- to
coarse-grained to very coarse grained with scattered pebbles:
.angular; poorly sorted; gray, bright red, & bright yellow.
(Using air rotary; very little return-& very difficult to
drill). WATER at approx. 1.5 gprn.
69.5- 74 Same, with some iron cementation. Water decreased at 73-74
feet.
(Drilling fluids did not "mix" in pond water & appeared to
be denser (sank to bottom)).
74 - 79 Same, but not as cherty; less water.
79 - 83.5 Same, with higher percentage of clay and silt. Hard to
drill (chert) at 81 and 83 feet. Water at approx.0.5gpm.
83.5- 95 Clay, cherty; with quartz & chert gravel, well rounded,
partially devitrified, some with iron streaks; light- to
medium-gray, brown, & yellowish-brown.
Water circulating at approx. 4.5gpm.
95 - 103 Same, with smaller pieces returned. Water circulation poor.
DOCKET NO.
-------
8321 OAK RIDGE HIGHWAY KNOXVILLE, TN 37931 615/690-0128
GEOTEK
ENGINEERING COMPANY
OBSERVATION WELL JNSTALLATION DATA
10-7-85
ObitrtiHonWslINo: L
Drilling Wtthoi Air Rotary
Inalilied by:
Inspected by:
Tom Huffaker
Others
Drilling Fluid:
None
Obnrvttlon W«I! Scnerr
Mtlhod of D«v«lopm«nt
1.5-in. Schedule 40 PVC, 0.010-in. slotted.
Surged with formation water, approximately one hour.
*
EI«v.
Stlckur
STRATIGRAPHY
-
Soil Typ« Depth
w/Chert & Silt 0 . 0 ' - 9 . 5 '
9.5'-15.Q'
15.0 '-20.0'
20,0'-35.0'
' Clay
; -lay and Chert
' -lay w/Chert & Silt
, Clay w/Chert .
WATER LEVEL
READINGS
Otptft
Below Well HeadElavtUon
10-22-85 28.2'
10-23-85 28.1'
10-24-85 25.9'
10-29-85 26.1'
10-30-85 26.2'
10-31-85 26.4'
w/ Well Head
MSSttpsi
Low Permeability
Rir-tfll!
1 . «Hn.l.D.
PVC nievr
Cement
Pfln^ FIHftr ^
Obtervallon
rr oil ocrttn
bc
*
0
S
Q
}9
$
i°-
i[
^
y
'
:;':'.
:
«* *
*.**
V'';
T-*
;.;_
'-C
.»
0
* "
>C
3;
1
y U
5?
'b1
'c
Ol
£
y
/
y*
'
'
.
:
:.
>j 0.4'
*Elevations are not presently available.
(UAH
0.0'
18.0'
20.0'
25.0'
35.0'
35.0'
-------
Length cored
Ft
* . Recovery
Fl
% Recovery
Drilling Time.
mm.
I % Drill Water
Return
ROD %
J'
3 '0
,1, ,
i
[
c
i
o.
D
1 1
^
1
Cv.
C
1
s?
U-~/
r
c
j
J
h
fe
L
1
^
r\
-«
3
*rr
j
>
0)
r>
D.
0
) fj
R
a
TO
cn
0
tU
\
1
1_
a
CO
CO
O|
-_.
to
c
1
i
I
C
i
1
1
3
ih
1
1
t
t
1
w
*o
<*s
Q
3
M
fD
Hi
g
P
fn
CO
Ol
«
O
CO
p
5
Cl
(/>
H
H
rt
^
O
fD
1
0
j
1
1
(J
i*
1
1
j
j
1
C
i
J
j
l
I
C
c
.
r
0
3
1
I
to1
c
1
1
0
I
J
c
1
T-
D
1
I
to
1
T"
vi
1
tJ
c
1
pr
n
1
td
fO
to
01
«
O
cn
O
H
"
tX
i
T
1
r
t
i
'
tv
« t
J,
)
J
1
~r
tx
r
1
'T
>
0
1
tv
)
,ll
t2!
fll
to
o
*
o
Ol
o
CJ
"
(r
Type4
No
Blows per
Drive
w
3
n
n
6'
N-Valuo
5 m - °
GRAPH
ro
IN
C/)
^
fD
f)
*O
f)
Q
a
fD
^
P
fn>
to
cn
»
H
H
J3
C/)
H-
M
rt
O
1 '
,P>
^
g
H-
rn
T3
(*)
(*)
^3
0)
6J
p
P
fri)
to
0
"
H
P
j-j
f/1
rt
O
PJ
l<
^
[j*
ft)
ft)
rt
o* O
3 w
o n
n
w T3
§1
CX _
~ w
D O
0 0
- 3
co \
P t \
ro H
cf *
oq
5
D^
ro
p
§
a
CD
4
r*
o
to
g
CD
u
Tl
fD
rT
-o
*^
K
H>
H,
M
ft
n
*
PT
f-H
S
M-
[/)
O CO O H CD .3
- 0 W -< o H-*
O -< l/> "O -i
c 5 5 ro 5
£ <£> 0 0(0
m !? !ji CD ?
ST ID 0> O
< C CL Z
0) 3 3
*~^
o
o
CO
M
CD fD
If
h-1
jO
M ^
-~~- fD
u>
M-
-; O O IQ
S. 0 D.
5 3 |
n. 5" *°
~ » 3
0 Q. c
O
Q)
Q.
r
o>
Q.
h-l
?
30
Jl
1 C/)
rji -T
COro
fD
\D
o
272QNOLE
1GEOT
A ENGINEER
~ FR| 7
o ^ w
o r\ F
D ' r-
2. m
i :!.
'...
* J'*
(/5
;' ''. i
. F
* r*
.' m
' --4
' .- m
z
. \ z
: rn
w
. m
m
. ' .to
^i
M
' '. ' !-*
| ^
cn
' -H3
to
' in
'o>
. '. ' - 0>
. . oo
!2
. .
; ' .
.
. ' '. '
' * . '. .
% '
-------
P . ... Ml. *J . . . I _
Length cored
1 Fl
[ ., . Recovery
Fl
% Recovery
Drilling Time,
mm.
( % Drill Water
Return
ROD",.
t
i
y u
i
t-
3 'O <>> -1
1
_L_
i
i
,
i
1
_,
"^
ID
^v
M
to
^
CO
Ol
o
00
1
t-
o\ i
1
~E
i
O
r>
X
n
2:
inv
K>
1
1
U
SJ
1
D
s?.
fl)
rt
?0
(D
a
Pr-
f-^
s
o
s*
*v^
t/1
t '
H
§
o.
O
rr
0)
rt
j,^
r
L
1
1-
1
&
I-
1
1
1
V
1
A
»
1
_i
25
CO
o
(
o
en
^
U
l>
11
^ » LJ 10 -< 11
1
1
1
1
1
1
1
i
1
i
1
1
r
1
i
> U> CD
it.
1
i
^
ft
1
-t
4
-J
O
3^
y
i
a
n
D
~ji
0)
o
CO
^i
fD
*
0
T.
O
13
i
a
o
7]
13
b
R
j.
P
a.
0
I
^_i
<^
o
^
en
cr
*Q
^
Q*
1
i
i
i
T"
T1
1
CO
CO
0
Oi
o
-1 O> '
1
1
1
1
T
1
T
-r
1
7
n *» u> i
1
1
i
[3
O
D*
(D
^-t
UJ.
O
1
rr
cJ
Pr>
rr
M
p
0
0
i i
P
i
1
T
1
1
CO
CO
o
o
o
T
.
1
1
1
I
r°
°-
rt
s
rt
**4
n
33
o
cr
fD
(-f
Tvpe' w
3
T3
No
Blows per 6"
Drive
N-Value
o
3 S z ^
-* I
GRAPH
> 0
o o
* ^
§1
? o
5 o
IO
o o
^ _,
-> o
J> r>
0 *
3
0
X
O
rn
o
O
e»
o
01
*-»
(V
M
00
Ol
T1
5
a
0)
<
fj
P
M>
e-
fD
C-,
*
po
*
M
3
p.
M
H
3
a
*
D
r-
o
o
to
o
3
o_
m
o
3
CD O
O U ^
-i (/> 1
5 5
Q (£>
cr c
CO 01
D CD
c a.
3
u
en
CD ra
0 C
n h
3 r
Q
"") vj '
D ZJ
3 =
D 3
(O
W ^^
«-# .
fD d
a c
a
c
(/»
Jr
H
<
a
T>
o^
CD
O
^
3
a
T}
-
3
T)
33
5
f~)
a
H
t-
0)
T
a
o.
u
B
s
n
[1
D
3
3i
rt
-"
_i
Products
CD
O
3
ID
z
Q
c.
a
OJ
fD
h
"f
v
1
0
C
C/
3-
fD
2.
)-
o
1
o
fD
M
><
1
cm
R
tt)
aumgartn
0)
3
j
3
4
o
n
A
o"
Z . N \
\ \ \
\ \ N
- v
! v
a
CO
0
ID
O
D3
O
(O
t
'N^
yAjv^SJ
s
sQ-p
3J."»I m
5R1Z
OJ»M
0^^ p
0 'r-
2 ., rn
"D ' ' 3
5 '' o
5 >
K . D
*
' : 2
Sj-
.''. x
F
.."' ' *"
,: ^
. m.
.' 2
' -2
m
to
m
.m
' 'w
; ,.-lv
MA>
, *
' j ' '~~*
^
.' i5
.en
«j>
o>
00
' '.' ~*
". '
-------
8321 OAK RIDGE HIGHWAY KNOXVILLE, TN 37931 615/690-0128
GEOTEK
ENGINEERING COMPANY
OBSERVATION WELL INSTALLATiON DATA
Ditt:
10-9-85
ObitrvtHon Well Ho :
lnatn!!«d by:
ln«o«ct»g Fluid: _
Air Rotary
None
Obitrvtllon Well Scr»«rr
1.5-in. Schedule 40 PVC, 0.010-in. slotted.
M.lhod of D.vtlopmint Surged with formation vater. approximately one hour.
Eltv.*
Stlckuc
STRATIGRAPHY
Soli Typ«
D»p(h
Clay w/Silt & Chert 0.0'-1.5'
: :hert w/Silty Sand 1.5'-23.0'
Sandstone with
23.0'-29.5'
^y w/Chert
WATER LEVEL
READINGS
Dtpth .
Dtl» Below Well Head ElevtUon
42.7'
10-29-85
10-30-85
10-31-85
42.8'
42.9'
w/Well Head
m^fSy^
Low Permeability
5-in.l.D.
=>VC RIsw .
dement
nd FIHor >
bt«rvallon
^11 Scrttn
i
3.
*
ft
^
Q
?6
*
\
§
^
/
/
L^
»*B"
;.
/
.V.
*."
:';:'
.*.*.
C
.
0
* '
>c
^
s
g ll
§
^
!
^
,/
;*'
Comnenti:
- 9\ 0.4' L
I |
*Elevations are not presently available.
d.2')
0.0'
31.O1
33.0'
34.0'
54.0'
-------
2720 NOLENSVILLE ROAD . NASHVILLE, TENNESSEE 37211 (615)256-6891
112
ENGINEERING COMPANY
Job No.
Client _.
Project .
84-1569
Log Of Boring
Alley, Young and Baumgartner
Boston Industrial Products
Boring No
Sheet _! of I
Location of Boring.
Water Level
Time
Date
Type of Bonng Roller/Afrjg B-53
Casing used Size JLL_ Drilling mud used
Bonng begun
Ground Elevation.
Boring completed
referred to.
Field Party Huffaker. Jr. & Lewis
Datu
Rock Data
o
o
6
u
o>
c
0
_J
I
1
i
Recovery
Ft
% Recovery
o
E
ft
Q
r% Drill Water
i ' Return
.0
a
o
EC
Soil Data
Sample
0)
5 °
> ^
N
N
N
N
400.0
405.0
410.0
415.0
i
(o
&
«1 C
5 Q
o
CO
11
38
z.
50/14"
38
.
27
29
50/1
3"
1"
25
507
2"
DEPTH
IN
FEET
' /-
-* ~
<-
~
r
I ^Xl
^^
9~
"In"
J. *J j
r^ i
£-±_J ~
J, ** _
J
"^
-
~-^>- -
n5 _
71 ' ~
-
n6 _
n
}. 1 " -
GRAPH
r n -i
Description of soil or rock
& notes on drilling operation
Red k brown clav w/silt and chert
Spoon refusal (? 1.4"
-
.
Chert w/tan sand & silt
DOCKET NO. _ ' Je< ^eis
-------
2720 NOLENSV1LLE ROAD NASHVILLE, TENNESSEE 37211 (615) 256-6891
GEOTEK
ENGINEERING COMPANY
U2
Job No.
Client _
Project .
84-1569
Log Of Boring
Alley, Young and Baumgartner
Boston Industrial Products
A_Date_12l~h§%heet_2_o< A
Location of Eonng.
Water Level
Time
Date
Boring No _,
Type of Boring Roller/Aiy,g B-D.
Casing used Size _JL_ Drilling mud used
Boring begun
Ground Elevation.
Boring completed .
referred to.
Daturr
Field Party:
Huffaker. Jr. & Lewis,
i Rock Data
o
u
£ ul
O)
c
_J
Recovery
Ft
t
% Recovery
4)
|
*~ c
o =
c c
Q
9)
l!
Z 4)
o"
o
o
c
Soil Data
Sample
'a
>- -7
> "*
N
N
N
420.0
425.0
430.0
io
J a
o
CO
o
"n
Z
DEPTH
IN
FEET
O "
"o i
lp 2 -
^^
- ^
"
h
j f."
...
5"
j
j
2c
"I
'
-
12
-
~3^^~
731 .
- -
13
-
13
73 J
-
^3
3-
36 ^
e
O Q
f .. « -
GRAPH
00
Description of soil or rock
& notes on drilling operation
No recovery on sample due to
fall in
22' to 22.9' layer of chert
Maroon sandstone w/ chert k chert-
stone conglamorate
Cnert w/tan sand K silt
No recovery on samole due to
fall in
Red & tan clay w/chert t silt
fM/rr MO rS~^^-^3, .
Lixtl NU. ^ -^"""
-------
2720 NOLENSVILLE ROAD NASHVILLE. TENNESSEE 37211 (615) 256-6891
GSOTiBC
ENGINEERING COMPANY
Job No
Client _
'reject .
84-1569
Log Of Boring
Alley, Young and Baumgartner
Boston Industrial Products
6or:ng No
Date 10-9-85 sheet 3 of
Location of Eonng.
Water Level
Time
Date
Type of Rnr,ngRoller/AirR,g B-53
Casing used Size _§!!_ Drilling mud used
Boring begun _
Ground Elevation.
. Boring completed
referred to.
Field Party Huifaker, Jr. k Lewis
.Oat
Roc* Deu
o
0
6
u
£ ^
Ol
c
01
_j
/
[
Recovery
Fl
>.
o
>
o
u
V
cc
J?
^
o
E
f I
Q
5
ec ,-
5 5
o
Q =
,O
o1
"^ " i
i?
Q
O
~-
r- ^ ""
^5 * _
_. n
rs 3 _
p5. .
c
\°J /
r y-
,^\ -
X
u , \
5 ' -
, g
-D
| Q
O -
i
Description of soil Of rocK
& notes on drilling operation
Red k tan clay w/silt and chert
Bag sarrrole
.
Hole fell in to 54'
Bae sample
End of boring L- 57'
^fY^T vn b-'53-^«f
^wvr. _ t «T>.'. -. ......K^t
-------
Wellhead is protected with an outer steel casing, i2-inch
diameter, that extends a irdnirrura of 10 inches into .the ce-
ment grout apron. The number of each well will be per-
manently painted on the side of the well casing.
Each well has a 1/12 inch CFVC interior water dis-
charge pipe.
The FVC casing is threaded and installed with teflon
sealing tape at each joint.
' The top of the casing has been constructed in such a
manner that it can be kept locked at all times except during
sampling. The keys to the leeks and the sealing device are
kept by a designated employee of Boston Industrial Products.
Well designations shall be clearly marked on the
^
casing for easy identification.
All drilling equipment was washed with water from on-
site hydrants between drill holes.
All wellhead elevations were surveyed to determine
elevations to MSL.
C. Sairoling Procedures
Under 1200-1-11-.05 (6) of the Tennessee Solid Waste
Regulations, the' minimum of four (4) wells will be sampled
according to EPA 530/SW-611. All samples will be collected
by Boston Industrial Products personnel or their agents.
-------
TlT^y
The samples will be preserved'as described, in "Methods for
Chemical -Analysis of Water and. Wastes", EPA-6900/4-79-020,
and delivered to a qualified laboratory for analysis. It is
recommenced that the collection, delivery, and analysis of
the sanples be perfonred by a qualified engineering firm to
clarify the chain of custody of the samples. If the sanples
are to be collected by Boston Industrial Products, the pro-
cedures described herein will be followed:
1. The water levels shall be measured and recorded and
the base elevations determined. -/in instrument type
current meter water level indicator shall be used by
lowering the probe down the 1/2 inch water discharge
pipe. (Meters are available from various suppliers
such as Branard Bellman of Atlanta, GA) Water le/els
will be recorded immediately.
2. It shall be required to evacuate one and one-half to
three times the volume of water in the well to obtain
fr- ;h groumwater. The well volume will equal 0.367
gallons of water per foot) x (the depth of the well-
the depth of the water level in feet). Evacuation
will be accomplished using the dedicated sampling
device in each well.
a. Connect air hose from the portable air tank to
-------
the air line, on the well. Regulate the flew to
produce a steady, even, flew of water frcm the
discharge.
b. Measure the flew rate and e/acuate the well 1-
1/2 to 3 tines the volume of water in the well.
c. Depressurize the well and measure the water
level.
3. Samples shall be collected as scon as the well is suf-
ficiently recharged.
a. Water sampling shall be accomplished in the same
iranner as water evacuation. Regulate the flew
to produce a steady, even flew of water. The
water flew rate shall be slew enough to prevent
any aeration frcm occurring.
b. Samples for organic analysis shall be collected
first.
c. Each well will have its own dedicated hose of
Tygcn or equal material to insure no cross con-
tamination occurs. Each hose will have a rerrcv-
able cap to minimize the entrance of dirt into
the hose between sampling occasions. Before
each sampling, the portion of the hose project-
\
ing above the well cap shall be flushed with
-------
deionized water.
The physical, chemical and bacteriological integrity
of the sample mist be iraintained fron the time of sam-
pling to the time of testing in order to keep any
changes at a minimum. The tiirs between sampling and
testing will be kept at the absolute minimum.
D. Analysis and Handling of Samples
The following general methods are to be employed:
Metals - Glass container, NMO-j to pK <2, cool to 4°C
Nitrate - Glass - Cool to 4°C
Coliforms - Sterile Glass - Cool, NA^SnCb
Radiological - Glass or Plastic - HNOo to cH <2
Organics - Glass, Teflon Cap, Cool, no air gap
pH - on-site, cccl and check in lab
Phenols - Glass - tinted, cool to 4°C, N2S04 to pfi <2
T.O.C. -- Glass - Cool to 4°C, H2|SO4 to pH <2
Specific Conductance - Glass - Cool to 4°C
Fluoride - Glass, cool to 4°C
Sulfate - Glass, cool to 4°C
All samples are to be in the laboratory within 24
hours of collection. The samples are shipped using courier
service companies directly.
Sample labels are necessary to prevent mididentifica-
-------
tion of samples. Gummed paper labels or tags are adequate.
The label inust include at least the following infonraticn:
Name of Collector
Dace ana Time of Collection
Place of Collection
Collector's Sample Nurrber, which uniquely identifies
the sanple
Sample seals are used to preserve the integrity of the
sample from the time it is collected until it is opened in
the laboratory. Gummed paper seals can be used as official
sample seals. The paper seal must carry inforrration such as:
Collector's name
Date and Time of bampling
Collector's sample number (This number must be identi-
cal with the number of the sample label.)
The seal must be attached in such a way that it is
necessary to break it in order to open the sample container.
To establish the documentation necessary to trace
sample possession frcm the time of collection, a chain of
custody record will he filled out and accompany every
sample.
The sample will be delivered to the laboratory for
analysis as soon as practical - usually the same day as the
11
-------
sampling. The sample will be accompanied by the chain of
custody record. The sample will be delivered to the person
in the laboratory authorized to receive samples.
When the sample is shipped to the laboratory, it will
be packaged in a proper shipping container to avoid leakage
and/or breakage. A cardboard box that will provide at least
10 cm (4 in.) of tight packing around the sample container
will be used. Acceptable packing materials include sawdust,
crumpled newspaper, vermiculite, polyurethane chips, etc.
Samples that require refrigeration will be packed with
reusable plastic packs or can of frozen freezing gels in
molded polyurethane boxes with sturdy fiberboard protective
case. The boxes will be taped closed-with irasking tape or
fiber plastic tape.
All packages will be accompanied by a sample analysis
sheet and chain of custody record. Complete address of the
sender and the receiving laboratory must legibly appear on
each package. When sent'by mail, register the package with
return receipt requested. When sent by common carrier, ob-
tain a copy of the bill of lading. Post office receipts and
bill of lading copies may be used as part of the chain of
custody documentation.
Samples will be refrigerated and preserved as required
12 W>'
-------
Parameter
by SW 846.
E. Sampling Program
1. Interim First Year Sampling - Background
The parameters to be analyzed for during the first
year are shewn in Exhibit No. 4. The analysis proce-
dures are to follow EPA 600/4-79-020, latest edition.
2. Second Year and Continuing Monitoring Samples
The following parameters have been selected for
monitoring.
Analytical Method Detectabilitv
Nurrber/Year
325.3
236.2
243.2
420.1
273.1
375.4
150.1
-ance 1230.1
irbon 415.
239.1
1 n*g
0.001 mg/1-
0.0002 mg/1
0.005 mg/1
'0.015 mg/1
1.0 mg/1
1 mg/1
0.1 mg/1
T_
1
l'
1
1
1
2
2
2
2
Chloride.
Iron
" Manganese
Phenols
Sodium
Sulfate
PH
Specific Cond
Total Organic
Lead
Total Organic Halogen
*Frcm EPA 600/4-79-020 (latest edition) (SW 846)
a. At the end of the first 6 month monitoring fol-
13
-------
T\
.'
lowing the first year background monitoring, and
after each applicable 6 irionth monitoring period
thereafter, Boston Industrial Products will com-
pare the results from the initial background
data to each 6 month data according to F, Proce-
dure for Statistically Evaluating Groundwater
Monitoring Data.
3. Procedures for Establishing Background Quality
Background .
Background quality will be established by sam-
pling all upgradient wells according to the interim
first year procedure. Once the data on the sairpling
has been collected, background data comparison will be
prepared as per Rule 1200-1-11-.05(6)(c)3.
4. Proposed Ccnpliance Point
The point of compliance is proposed to be the
toe of the levee'of the surface irtpoundment. This
point must comply with 1200-1-11-06 (8)F.
F. Procedure for Statistically Evaluating Groundwater
ivonitoring Data
1. Procedure
Step One - Frcm the background, data obtained for each
well (as per Rule 1200-1-11-.05 (6) (c)3), for each
14
-------
parameter to be compared, calculate the background
arithmetic mean (X3) am variance (VB) as follows:
XB
VB = .
NB
i =
(X,
1
2
where x^ is an individual ireasurement in a set -con-
taining Nuj measurements. For at least the parameters
pH, specific conductance, and total organic carbon;
the nurrber of measurements N^ will equal or exceed 16
since at least 4 replicate measurements of each of at
least 4 samples (quarterly) must be obtained, for es-
tablishing background. For other indicator
parameters, NB will equal or exceed 4 based on the
miniinum four quarterly measurements.
step Two - For each parameter for each well, calculate
t using the equation
15
-------
t -
X -
(N-I)V
N + N - 2
N +
(N) (N,
where X, V, amd N are identified, as follows:
a. For the parameters pH, specific conductance, and
tocal organic carbon, the subsequent periodic
monitoring required by Rule 12QO-1-11-.05(6)(c)4
will result in at least 4 rneasurer£mts of the
parameter. For these parameters and any others
for which a number of measurements (N) are
obtained, the arithmetic mean (X] and variance
(V) shall be calculated as per Step One above.
b. For those indicator parameters for which only a
single measurement (X) is obtained in subsequent
periodic sampling and analysis, X = X, V = O,
and N = 1.
NOTE: If X is equal to or (except for pH) less than
XB, then no deterioration of grouncwater quality
with regard to that parameter can have occurred
and no further statistical analysis of that
16
A
-------
parameter is necessary.
Step Three - Compare the calculated t - statistic frcm
Step Two above to the appropriate t - statistic value
frcm Table 1. For pH the value frcm the "Two-tailed
t" column of Table 1 shall be used since both in-
creases and decreases of that parameter are of
concern. For the other parameters, the values from
the "One-tailed t" column shall be used since only in-
creases of those parameters are of concern. If the
calculated value of t exceeds the value of t found in
the' table, a statistically significant difference .in
the parameter for that well has occurred.
2. Interpretation of Results
The occurrence of a statistically significant
increase in a parameter value (or pH decrease) for a
well indicates a possible problem which needs further
evaluation. in particular, the results for that well
need to be correlated with similar results from the
other wells in the monitoring system. The spatial and
depth distribution of the wells must be considered in
relationship to the indicated grcundwater zone(s) of
contamination, groundwater flow rates and flow
directions, and the locations of possible sources of
17
-------
G.
contamination (including, of course, the facility) .
The entire groundwater monitoring system .must be
considered before a determination can be made that a
facility is contaminating grcundwater.
Procedure for Annual Determination of Uppermost
Aouifer Flow Rate and Direction
Annually Boston Industrial Products will determine the
direction and velocity of the groundwater. The following
procedures will be used.
(a) The groundwater elevation from each well will be
determined.
(b) Using 'the elevations from (a), the gradient will be
calculated.
(c) Once the gradient is determined, Darcy's calculation for
velocity (VD + KE) will be used, where K = hydraulic conduc-
tivity and I is the gradient. it is understood VD is ap-
proximately one-half of the intervoid velocity.
H. Procedure to be Implemented if a Significant Increase
in Any Parameter is Identified at Monitoring Well
If the statistical analyses of data fron a detection
well-sampling event shows a significant increase (or pH
decrease) in a downgradient well, Boston Industrial Products
will irrmediately resanple those downgradient wells where a
18
-------
significant difference was detected, split the sample into
two portions and obtain analyses of all additional samples
to determine whether the significant difference was a
laboratory error.
If the analyses confirm the significant increase (or
pH decrease) Boston Industrial Products will provide written
notice to the Commissioner of the Tennessee Department of
Health and Environment within seven days of the date of such
confirmation, that the facility may be. affecting the
groundwater quality.
Within 15 days after notifying the Connissioner of the
affected groundwater quality, Boston Industrial Products
will develop and submit to the Commissioner a specific
groundwater assessment plan, an outline of which is con-
tained in Appendix A.
I. Grcundwater Deporting Procedures
If the groundwater' is being monitored using the
original indicator evaluation program, Boston Industrial
Products will evaluate the data on the elevations obtained
when sampling each well and at least annually, determine
whether the requirements to have at least one (1) upgradient
well and three (3) dcwngradient wells are being satisfied.
If the evaluation shews that the location requirement is no
-------
longer satisfied, Bos.ton Industrial Products will im-
mediately modify, with the approval of a Department Staff
geologist, the nurrber, location, or depth of the rronitoring
wells to bring the grcuncwater monitoring system into com-
pliance with this requirement.
1. The following records will be kept:
Analyses required quarterly during the first
year (primary drinking water standards, parameters es-
tablishing groundwater quality, and parameters used as
indicators of groundwater contamination) ;
Analyses required after the first year, as
follows:
Annually: record the results of"the parameters estab-
lishing groundwater quality; and
Every six months: record the results of the
parameters used as indicators of groundwater
contamination.
Record the elevation of the groundwater surface
at each well each time a sample is obtained.
2. The following groundwater information will be
reported:
During the first year, when initial background
concentrations are being established for the facility
20
-------
for each groundwa'ter monitoring well, the results will
be submitted to the commissioner within 15 days after
completing each quarterly analysis. Each well will be
identified for any parameters listed in the primary
drinking standards.
3. An annual report for each well will be submitted
providing the following information:
- The results of analyses for the parameters es-
tablishing groundwater quality;
- The results of the parameters used as indicators
of grcundwater ccntsoination;
- The elevation of the groundwater surface each
time a sample is obtained; and an evaluation of
well placement as per ;05(6) (d) (6) .
- The results for each time the "Procedure for
Statistically Evaluating Groundwater Monitoring
Data" is used to determine if any well exhibits
groundwater contamination;
-miy significant differences from initial background
found in the upgradient wells will be noted.
4. The cormissicn will be notified within 15 days of any
parameter exceeding the primary drinking water
standards.
21
-------
Compliance History
RCRA ground water monitoring at the site is regulated by the Tennessee
equivalent regulations to 40 CFR Part 265, Subpart F. The compliance history
for BIP regarding ground water monitoring has been extensive. The following is
a summary, in chronological order, of the correspondence, reports, etc. that
were available for review for the Task Force's use. This should not be
interpreted as a complete record.
11-07-80: BIP files the Part A for the facility.
12-07-81: BIP consultants submit the landfill operation manual and
closure drawings for review.
01-04-82: BIP responds to a non-notifer letter.
01-18-82: BIP notifies TDHE that they are a generator/storage facility.
09-14-82: TDHE conducts a hazardous waste generator inspection.
09-15-82: TDHE issues a "Notice of Violation" (NOV) to correct
deficiencies noted during the 9-14-82 inspection.
10-25-82: BIP notifies TDHE that all 30-day violations are corrected.
11-03-82: TDHE and BIP hold a compliance review meeting to discuss
the E P Toxicity results from the.surface impoundment.
11-05-82: TDHE issues a permit to operate the industrial solid waste
landfill- BIP must post a performance bond.
11-05-82: TDHE requests a ground water monitoring program within 120 days.
11-30-82: TDHE performs a follow-up inspection - all generator
standard violations are corrected, but no ground water monitoring
system is in place.
12-08-82: BIP notifies TDHE of an. overflow at the surface impoundment.
12-08-82: BIP is advised that all violations noted during the 9-14-82
inspection are corrected.
12-16-82: Part A is revised.
12-21-82: Results from the overflow samples show oil, grease and
lead concentrations.
01-07-83: BIP is informed that the surface impoundment can be
used because of the revised Part A.
04-05-83: BIP consultants prepare a report to determine the
feasibility of closing the surface impoundment.
-------
- D-2 -
08-19-83: TDHE conducts a TSDF inspection at BIP - several
violations are noted, including the lack of a ground
water monitoring system.
08-26-83: TDHE issues a "Notice of Non-Compliance". BIP is given
30 days to correct violations noted during the 8-19-83
inspection.
09-02-83: BIP consultants prepare a status report regarding ground
water monitoring.
10-20-83: TDHE "Major Facilities Status Sheet".
10-24-83: BIP consultants prepare a "Request for Waiver for Ground
Water Monitoring Requirements".
11-10-83: TDHE conducts a follow-up inspection - some violations
have been corrected but no ground water monitoring
system is in place.
11-17-83: TDHE informs BIP that all 8-19-83 violations have been .
corrected and that the waiver from ground water
monitoring requirements is under review.
11-83: BIP consultants prepare a Waste Analysis Plan.
11-30-83: TDHE collects water and sediment samples from the surface
impoundment.
12-09-83: TDHE study plan for sampling at BIP.
12-21-83: TDHE cannot approve the waiver because of insufficient information.
01-12-84: BIP consultants respond to the 12-21-83 letter.
01-17-84: TDHE requests a meeting to discuss the waiver.
01-24-84: The TDHE sampling results indicate that the impoundment's
water and sediment are hazardous.
02-08-84: TDHE issues a NOV to BIP for ground water monitoring
deficiencies and denies the waiver. TDHE believes that
contamination already exists at the site. A ground
water monitoring plan is due 3-30-84.
03-07-84: TDHE conducts a TSDF inspection - generator/storage
violations noted.
03-08-84: TDHE issues a "Notice of Non-Compliance" for violations
noted during the 3-7-84 inspection.
03-30-84: BIP submits a ground water monitoring plan to TDHE for review.
-------
- D-3 -
04-11-84: TDHE requests the Part B.
04-12-84: TDHE reviews the ground water monitoring plan and finds
it inadequate.
04-13-84: EPA requests the Part B.
04-30-84: BIP submits a revised ground water monitoring plan for review.
05-01-84: TDHE issues a "Notice of Non-Compliance" for an
inadequate ground water monitoring plan.
05-10-84: TDHE performs a site investigation at BIP.
05-17-84: TDHE requests a show-cause meeting.
05-19-84: TDHE conducts a follow-up inspection.
05-21-84: TDHE inspection report notes all violations have been corrected.
05-25-84: BIP wants to analyze for lead instead of TOX.
06-06-84: TDHE collects water and sediment samples from the impoundment.
06-13-84: A show-cause meeting is held to discuss the ground water
monitoring system.
06-26-84: Sampling results from the overflow ponds do not
exhibit the characteristics of a hazardous waste.
07-03-84: EPA responds to questions from BIP on how to complete
the Part B.
07-03-84: TDHE informs BIP that enforcement will continue.
07-17-84: EPA informs BIP the Part B is due by 10-13-84.
07-20-84: BIP updates their hazardous waste notification.
08-06-84: TDHE requests ground water monitoring action be added
to the Commissioner's Order against BIP.
08-09-84: TDHE conducts an inspection and notes the dam is leaking.
08-14-84: TDHE issues a "Notice of Non-Compliance" for violations
noted during the 8-9-84 inspection.
08-31-84: TDHE requests enforcement action against BIP.
09-12-84: TDHE informs BIP that the ground water monitoring plan
is adequate if certain conditions are met.
09-14-84: EPA Waste Engineering Section requests enforcement
action against BIP for ground water monitoring violations.
-------
- D-4 -
09-20-84: Results from the TDHE 6-6-84 sampling indicate the
impoundment exceeds the limit for E P Toxicity.
09-28-84: TDHE issues a "Notice of Deficiency" (NOD) for their
financial assurance.
10-84: BIP submits the Part B to TDHE and EPA for review.
10-84: BIP submits a revised ground water monitoring plan.
10-02-84: TDHE conducts a follow-up inspection.
10-03-84: BIP consultants respond to the TDHE 9-12-84 letter
requesting a ground water monitoring plan.
10-04-84: TDHE informs BIP that the dam was still leaking during
the 10-2-84 inspection.
10-19-84: TDHE informs BIP that the financial assurance appears
to meet the requirements.
10-30-84: TDHE approves the BIP ground water monitoring plan if
certain conditions are met.
10-30-84: TDHE denies the request to substitute lead for TOX.
11-19-84: TDHE conducts sampling for the E P Toxicity test.
11-28-84: TDHE issues comments on the Part B deficiencies.
12-18-84: EPA WES requests EPA ESD sample at BIP.
12-19-84: BIP advises EPA that as of 12-31-84 they will merge into
the parent DANA Corporation.
12-20-84: EPA issues comments on the Part B deficiencies.
12-21-84: EPA requests BIP to answer the 3004(u) questionnaire.
01-03-85: TDHE issues a NOD to BIP for Part B deficiencies.
01-10-85: Dingle ground water survey.
01-18-85: BIP requests an extension for the Part B revisions due date.
01-21-85: EPA ESD prepares study plan for a RCRA waste sampling
investigation at BIP.
01-28-85: TDHE denies the request for Part B extension.
02-85: BIP submits the Part B revisions.
02-01-85: EPA denies the request for Part B extension.
-------
- D-5 -
02-21-85: EPA informs BIP of the Hazardous and Solid Waste
Amendments of 1984.
02-27-85: BIP wants to delay well drilling until 4-85; TDHE concurs.
BIP will try to clean-close the impoundment.
03-11-85: TDHE conducts a hazardous waste inspection at BIP.
03-12-85: EPA advises BIP that the Agency had not received a
response to the 3004(u) questionnaire.
03-20-85: TDHE issues a NOV for violations noted during the
3-11-85 inspection.
04-01-85: TDHE visits BIP to monitor well installations. It is
noted that the cooling pond has no freeboard and is
being siphoned to the overflow ponds.
04-02-85: TDHE returns to BIP and notes the cooling pond has freeboard.
04-11-85: TDHE denies approval of using glued joints in the
monitoring wells - threaded joints must be used.
04-16-85: EPA summarizes the 1984 HSWA and how they will affect BIP.
04-16-85: EPA ESD collects samples from the effluent to the pond
and the liquid leaking through the berm - samples
contained chlorobenzene and toluene.
05-15-85: EPA prepares an updated Dingle ground water survey
questionnaire.
05-26-85: BIP consultants request a meeting with TDHE to clarify
requirements for implementing the groundwater monitoring program.
06-20-85: TDHE and EPA meet with BIP to discuss the ground water
monitoring program.
06-21-85: EPA prepares a "Complaint: and Compliance Order" for
ground water monitoring violations at BIP.
06-24-85: TDHE issues a "Commissioner's Order and Assessment of
Civil Penalty and Damages" to BIP for ground water
monitoring violations. The penalty was $7724.00 and
damages were $5941.12.
06-25-85: EPA advises TDHE on current methodology recommended for
ground water monitoring.
07-26-85: EPA ESD issues report on the waste stream inspection
conducted 4-85.
07-31-85: TDHE issues a "Tentative Decision to Deny a Permit" to BIP.
09-23-85: EPA updates the Dingle ground water survey. :
-------
- D-6 -
10-03-85: TDHE notifies EPA of the tentative decision to deny the
permit for BIP.
10-21-85: TDHE summarizes the information available for the BIP landfill.
10-31-85: BIP consultants prepare a status report on the ground
water monitoring program at the site.
11-85: BIP consultants submit the "Well Installation and
Geohydrologic Testing" report.
11-08-85: BIP certifies compliance with all applicable state ground
water monitoring and financial responsibility requirements.
11-12-85: TDHE notifies EPA of the tentative decision to deny the
permit for BIP.
11-13-85: TDHE responds to BIP's questions on ground water
monitoring requirements.
12-06-85: TDHE issues a NOV to BIP for failure to comply with
the.State Financial requirements.
12-10-85: TDHE and EPA perform a LOIS inspection at BIP. The
inspections shows that the surface impoundment is
still in-vise.
12-11-85: BIP consultants submit the pump-test results. The data
indicates no interconnection between aquifers.
12-31-85: TDHE issues the notification to terminate interim status
and denial of a permit for BIP.
01-86: The EPA Region IV Office of Regional Counsel prepares a
Litigation Report for enforcement of BIP's loss of interim status
01-07-86: BIP submits revised financial responsibility and liability
coverage to TDHE to correct the financial requirement violation.
01-20-86: BIP submits ground water monitoring data to TDHE for
review. It is noted that there is a high concentration
of oil and grease in wells 3 and 4.
01-23-86: TDHE conducts an inspection at BIP to determine surface
and ground water sources that might be affected by the facility.
01-29-86: BIP responds to TDHE's intent to terminate interim status.
02-20-86: TDHE responds to BIP's 1-29-86 letter.
02-20-86: EPA submits their comments on the BIP Part B to TDHE.
03-04-86: EPA discusses the ground water monitoring system with
BIP consultants. .
-------
- D-7 -
03-05-86: TDHE advises BIP that the groundwater monitoring system
in place is not adequate for monitoring purposes.
03-31-86: BIP submits closure/post-closure cost estimates and the
Annual Report.
04-04-86: EPA submits the civil litigation report to the Department
of Justice for review.
04-17-86: EPA submits the BIP Facility Management Plan to TDHE
for review.
04-25-86: BIP attorneys request a meeting with EPA arid DOJ.
06-06-86: TDHE and BIP meet to discuss the ground water monitoring system.
06-10-86: EPA requests that the Task Force perform an evaluation at BIP.
06-25-86: TDHE requests more information on the ground water
monitoring system at BIP.
07-15-86: BIP consultants respond to the TDHE 6-25-86 letter.
07-25-86: TDHE performs a comprehensive ground water monitoring
inspection and notes violations.
10-01-86: TDHE issues a NOV for violations noted during the
7-25-86 inspection.
10-06-86: BIP responds to the NOV.
10-16-86: BIP consultants submit water level data indicating
little or no water in the RCRA monitoring wells.
10-20-86: BIP consultants respond to the 10-1-86 NOV.
10-29-86: TDHE and EPA advise BIP on methodology for a pump test
10-31-86: BIP responds to the 10-86 NOV.
11-04-86: TDHE conducts a follow-up inspection at BIP.
12-01-86: TDHE issues a second NOV for violations not corrected
from the 10-86 NOV.
01-09-87: BIP responds to the second NOV.
03-27-87: TDHE directs BIP to determine the depth and thickness
of the confining layer underlying the site.
03-30-87: BIP informs TDHE that a boring program is underway.
04-06-87: EPA informs BIP that the Task Force inspection will be
the week of 5-11-87.
-------
-------
------- |