EPA-330/2-88-042
Hazardous Waste Ground-Water
Task Force
Evaluation of
Acme Fill Corporation
Martinez, California
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
CALIFORNIA DEPARTMENT OF HEALTH SERVICES
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
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,*>
\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
,* WASHINGTON, O.C. 20460
July 18,1988
,r UPDATE OF THE HAZARDOUS WASTE GROUND-WATER TASK FORCE
:«) EVALUATION OF THE ACME FILL CORPORATION, MARTINEZ, CALIFORNIA
ft The Hazardous Waste Ground-Water Task Force (Task Force)
-! of the United States Environmental Protection Agency (EPA) in
conjunction with the California Department of Health Services
(DOHS) and the Regional Water Quality Control Board (RWQCB)
conducted an evaluation of the ground-water monitoring program
at the Acme Fill Corporation (Acme) hazardous waste disposal
facility, Martinez, California. The onsite field investigation
was conducted over a ten day period from June 2 through 12,
1987. The Acme facility is one of 58 hazardous waste
treatment, storage and disposal facilities (TSDFs) evaluated by
the Task Force. The Task Force effort came about in light of
concerns as to whether operators of hazardous waste TSDFs are
complying with the State and Federal ground-water monitoring
requirements.
The objectives of the Task Force evaluation were to:
- Determine the facility's compliance with the interim
status ground-water monitoring requirements of 40 CFR
Part 265 and the equivalent State requirements;
- Evaluate the ground-water monitoring program described
in the RCRA Part B permit application for compliance
with 40 CFR Part 270.14 (c) and the equivalent State
requirements, if applicable;
- Determine if the ground water at the facility contains
hazardous waste or hazardous waste constituents;
- Provide information to assist the Agency in determining
if the TSDF meets EPA ground-water monitoring require-
ments for waste management facilities receiving waste
from response actions conducted under the Comprehensive
Environmental Response, Compensation and Liability
Act (CERCLA), as amended.
The Task Force prepared the accompanying evaluation
report, which revealed a number of deficiencies in the ground-
water monitoring program at the Acme facility, as well as
numerous violations of other RCRA requirements. The Executive
Summary of the report discusses the findings related to the
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objectives of the investigation. In summary: 1) the facility
was not in compliance with the interim status ground-water
monitoring requirements; 2) the monitoring program submitted
with the Part B permit application was inadequate; 3) the
ground-water samples from onsite wells contain hazardous waste
constituents and 4) the facility was not in compliance with the
ground-water monitoring requirements for the CERCLA offsite
policy.
This update provides information on ground-water related
activities by Acme, as well as measures taken by EPA Region IX
and State agencies (DOHS and RWQCB) to bring the facility into
compliance with RCRA and other State regulations since the Task
Force inspection.
On July 23, 1987, Acme entered into an administrative
consent order and judicial consent order with the California
DOHS regarding the North Parcel. These two orders addressed
violations which were observed by EPA Region IX and referred to
DOHS for enforcement follow-up.
The administrative consent order (No. HWCA 86/87-005)
required Acme to submit closure and post-closure plans and
implement an approved closure plan. Acme submitted a closure
plan in August of 1987 and a revised plan in March 1988. DOHS
and EPA are currently reviewing the proposal. The plan went to
public hearing on June 9, 1988. Approval of the closure plan,
by DOHS and EPA, is anticipated by September 1988.
The judicial consent order placed Acme on a compliance
schedule to address deficiencies identified by the Task Force
inspection as well as other RCRA violations noted by the Task
Force the State and the Region. The order addresses: 1) the
ground-water monitoring program, 2) the run-off management
control system, 3) the leachate control system, 4) the
contingency plan and 5) security measures. Acme was also
prohibited from receiving additional hazardous waste, and from
disposing of bulk liquids into the landfill. To date, Acme has
complied with the schedule for submission of documents
specified in the consent order.
Acme has submitted a workplan as required by the consent
order, to correct deficiencies in the ground-water monitoring
program. DOHS is reviewing the work plan and coordinating the
regulatory agencies' response. DOHS must approve the plan
before it is implemented.
In addition to the submittal of documents required by the
administrative and judicial consent orders, Acme also agreed to
cease acceptance of hazardous wastes, and to ensure that only
non-hazardous wastes were accepted. A DOHS inspection on
August 11 1987 revealed that Acme had accepted asbestos wastes
(a California hazardous waste, although not a RCRA hazardous
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waste). The California Attorney General's office is currently
pursuing a resolution of this issue.
This update completes the Task Force evaluation of the
Acme Fill Corporation, Martinez, California.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT AND COMPLIANCE MONITORING
EPA-330/2-88-042
HAZARDOUS WASTE GROUND-WATER
TASK FORCE EVALUATION
ACME FILL CORPORATION
Martinez, California
July 1988
Karen Johnson
Project Coordinator
National Enforcement Investigations Center
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CONTENTS
EXECUTIVE SUMMARY
INTRODUCTION 1
SUMMARY OF FINDINGS AND CONCLUSIONS ...6
GROUND-WATER MONITORING DURING INTERIM STATUS 6
Ground-Water Sampling and Analysis Plan 7
Sampling and Analysis Procedures 7
Monitoring Well Network 9
Assessment Program Outline and Plan 11
GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA
PERMIT 13
TASK FORCE SAMPLING AND MONITORING DATA EVALUATION 14
COMPLIANCE WITH CERCLA OFFSITE POLICY 1 4
TECHNICAL REPORT
INVESTIGATIVE METHODS 15
RECORDS/DOCUMENTS REVIEW AND EVALUATION 1 5
FACILITY INSPECTION 16
LABORATORY EVALUATION 16
WATER LEVEL MEASUREMENTS AND SAMPLE COLLECTION 1 7
FACILITY DESCRIPTION AND OPERATIONS 31
INTERIM STATUS REGULATED WASTE MANAGEMENT UNITS 31
North Parcel Landfill 31
Surface Impoundment on North Parcel 41
Injection Well 42
Tanks 43
Class I Surface Impoundments
(Currently Owned by IT Corporation) 44
NONINTERIM STATUS REGULATED WASTE MANAGEMENT UNITS 44
East Parcel Landfill 44
South Parcel Landfill 45
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CONTENTS (cont.)
FACILITY OPERATIONS 46
Waste Characterization Procedures 47
Waste Analysis Plan • 48
Landfill Operations 51
Unauthorized Disposal 52
Infectious Waste 56
SITE HYDROGEOLOGY 58
HYDROLOGIC UNITS 59
Structural Geology 59
Stratigraphic Units 61
GROUND-WATER FLOW DIRECTIONS AND RATES 66
GROUND-WATER MONITORING PROGRAM UNDER INTERIM STATUS 70
FEDERAL AND STATE REGULATORY HISTORY 70
REGULATORY REQUIREMENTS 74
GROUND-WATER MONITORING PROGRAM - NOVEMBER 1981
THROUGH MAY 1985 76
Sampling Program 77
Monitoring Well Location, Number and Construction 79
GROUND-WATER MONITORING PROGRAM - MAY 1985
THROUGH JUNE 1987 82
Sampling and Analysis Plan 83
Monitoring Well Location, Number and Construction 85
ACME SAMPLE COLLECTION AND HANDLING PROCEDURES.: 92
Water Level Measurements 92
Purging Procedures 93
Sampling Methods 9!j
Shipment and Chain-of-Custody Control 97
GROUND-WATER QUALITY ASSESSMENT PROGRAM OUTLINE
AND PROGRAM 97
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CONTENTS (cont.)
SAMPLE ANALYSIS AND DATA QUALITY ASSESSMENT ; 102
INITIAL YEAR OF MONITORING 103
MONITORING IN 1987 111
GROUND-WATER MONITORING PROGRAM PROPOSED FOR
RCRA PERMIT 112
EVALUATION OF MONITORING DATA FOR INDICATIONS OF
WASTE RELEASE 115
VOLATILE ORGANIC SAMPLING RESULTS 115
INORGANIC SAMPLING RESULTS 117
RESULTS OF INDICATOR PARAMETERS 119
REFERENCES
APPENDICES
A ANALYTICAL DATA AND METHODS
B DRAGER TUBE DATA
C PROCEDURES FOR OPERATING ISCO WATER LEVEL RECORDERS
D OCTOBER 1, 1986 INSPECTION REPORT
E COMPARISON OF STATE AND FEDERAL MONITORING
REQUIREMENTS
FIGURES
1 Site Map - Acme Landfill 2
2 Task Force Sampling Locations 19
3 Wells Monitored With ISCO Meters 27
4 Tidal and ISCO Meter Fluxes 30
5 Acme Hazardous Waste Management Units 33
6 Leachate Monitoring Wells in the North Parcel Hazardous Waste
Management Area 39
7 Site Location Map 60
8 Leachate Levels - June 7,1985 64
9 Leachate Levels - January 13,1986 65
10 Generalized Piezometric Contour of Water Levels from the Wells
Completed in Peat - June 1987 68
in
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CONTENTS (cont.)
FIGURES (cont.)
11 Generalized Piezometric Contour of Water Levels from the
Wells Completed in Silty Clay -June 1987 69
12 Self-Monitoring Program Monitoring Well Network for the
North Parcel 80
13 Acme ISD/RCRA Monitoring Well Network 87
14 Proposed Point of Compliance 113
TABLES
1 Water Level Elevations 18
2 Purging Record 22
3 Sampling Record 23
4 Order of Sample Collection, Bottle Type and Preservative List 24
5 ISCO Meter Verification 28
6 California Hazardous Waste Management Unit Classifications 32
7 Leachate Levels in Acme Wells 40
8 Waste Streams Disposed at Acme : 49
9 Waste Accepted at Acme from Cordis Dow 53
10 Chronology of Regulatory History of Acme Landfill 71
11 State and Federal Counterparts for Interim Status Ground-Water
Monitoring Regulations 75
1 2 Designated Locations/Depths of Self-Monitoring Program Wells
as Described in the Acme Waste Discharge Requirements 81
1 3 Acme Sample Order, Bottle Type and Preservation Methods 96
14 Selected Volatile Organic Constituents Present in Task Force
Samples 116
15 Selected Inorganic Constituents Present in Task Force Samples 118
16 Selected Results of Indicator Parameters for Task Force Samples 120
IV
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EXECUTIVE SUMMARY
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INTRODUCTION
Concerns have been raised about whether commercial and onsite
hazardous waste treatment, storage and disposal facilities (TSDFs) are
complying with the ground-water monitoring requirements promulgated under
the Resource Conservation and Recovery Act (RCRA), and amended by the
Hazardous and Solid Waste Amendments of 1984 (HSWA).* In question is the
ability of existing or proposed ground-water monitoring systems to detect
contaminant releases from waste management units at these facilities. The
Administrator of the Environmental Protection Agency (EPA) established a
Hazardous Waste Ground-Water Task Force (Task Force) to evaluate these
systems and determine current compliance. The Task Force comprises
personnel from the EPA Office of Solid Waste and Emergency Response, Office
of Enforcement and Compliance Monitoring, National Enforcement
Investigations Center (NEIC), Regional Offices and State regulatory agencies.
During the summer of 1987, the Task Force investigated the Acme Fill
Corporation (Acme), located near Martinez, California [Figure 1]. The onsite
inspection was conducted from June 2 through 12, 1987 and was coordinated
by NEIC personnel. The objectives of this investigation are similar to those for
other Task Force investigations, namely:
Determine compliance with interim status ground-water monitoring
requirements of 40 CFR Part 265, as promulgated under RCRA, and
the equivalent California regulations, as appropriate
Evaluate the ground-water monitoring program described in the
RCRA Part B permit application, submitted by the facility, for
compliance with 40 CFR Part 270.14(c)
Determine if the ground water at the facility contains hazardous
waste or hazardous waste constituents
Regulations promulgated under RCRA address hazardous waste management facility
operations, including ground-water monitoring, to ensure that hazardous waste
constituents are not released to the environment.
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NORTH
PARCEL
PROPERTY BOUNDARY
Acme Class I
Surface Impoundment*
(Currently owned by IT Corp
LEGEND
Hazardous Wast
Management A r
N on-Hazardous
Waste M a n a 3 e m
Areas
TO CONCORD
1000
2000
3000
SCALE IN FEET
FIGURE 1
SITE MAP-ACME LANDFILL
Martinez, California
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Provide information to assist the Agency in determining if the TSDF
meets EPA ground-water monitoring requirements for waste
management facilities receiving waste from response actions
conducted under the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA).*
During the inspection, Task Force personnel evaluated compliance with
interim status ground-water monitoring requirements of 40 CFR Part 265 and
California equivalent regulations (Title 22 Article 22 of the California Hazardous
Waste Management Regulations). The adequacy of the ground-water sampling
and analysis plan, monitoring well construction and location, analysis of
samples taken from the interim status monitoring wells and ground-water quality
assessment program outline and plan were evaluated. Information was also
obtained on present and past solid waste management units to aid in
evaluating the well network and interpreting ground-water monitoring data. The
evaluation involved: (1) review of State, Federal and facility records, (2) facility
and laboratory inspections and (3) collection and analysis of both water level
measurements and samples from ground-water monitoring wells.
Acme (EPA ID No. CAD041835695) has been used to dispose of
municipal and industrial waste since 1949. The waste management units
regulated by RCRA include a landfill (125-acre North Parcel, operated from
1980 to present), four surface impoundments (currently owned by IT
Corporation), a leachate impoundment (in the North Parcel), an injection well
(in the North Parcel) and two leachate storage tanks (in the North Parcel). Two
additional landfills are used for nonhazardous waste disposal (East and South
Parcels) and are not RCRA regulated. The leachate impoundment (operated
1981 to May 1986 in the North Parcel), the injection well (operated Spring 1985
to January 1986) and the two leachate storage tanks (operated mid-1986 to
present) were never reported on the facility RCRA Part A or Part B
applications, yet were in operation after November 1980 without interim status.
None of these units underwent formal RCRA closure, nor were ground-water
monitoring systems installed to detect releases from the units. The East and
South Parcels (nonhazardous waste management areas) have ground-water
monitoring systems.
Policy stated in May 1985 memorandum from Jack W. McGraw on "Procedures for Planning
and Implementing Off site Response", requires that TSDFs receiving CERCLA waste be in
compliance with applicable RCRA ground-water requirements.
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DRAFT 7/13/88 4
Interim authorization was delegated to the California Department of
Health Services (DOHS) on June 4, 1981. Under the EPA delegated program,
DOHS further contracted portions of the State equivalent RCRA program to the
State Water Resources Control Board (SWRCB) and the California Regional
Water Quality Control Board (RWQCB). On January 31, 1986, the responsi-
bility for the RCRA interim status program reverted back to EPA Region IX
because the State failed to achieve Final Authorization for the RCRA program
by that date, as required by RCRA Section 3006(c)(1). At the time of the Task
Force inspection, the facility was required to comply with both Federal RCRA
requirements and State Health Department hazardous waste regulations.
DOHS is continuing to pursue Final Authorization for the RCRA program.
Between November 1981 and November 1982, no ground-water
monitoring, pursuant to DOHS interim status document (ISD) requirements,*
was conducted at Acme. On November 17, 1982, 1 year after the required date
for implementation of the ground-water monitoring program, Acme requested a
waiver of the ISD requirements from the RWQCB.
RWQCB approved the waiver on March 4, 1983 on the grounds that the
existing self-monitoring program at Acme, under RWQCB Waste Discharge
Requirements (Order 76-37), was "more appropriate" than the ISD
requirements. The existing self-monitoring program did require ground-water
monitoring but did not require numerous provisions of the ISD program, namely:
(1) Designated upgradient and downgradient monitoring wells, (2) numerous
inorganic and organic sampling parameters, (3) statistical analysis of quarterly
monitoring data to determine if there had been a release of hazardous waste or
hazardous waste constituents and (4) ground-water quality assessment outline
or program. Following guidance from EPA, RWQCB rescinded the waiver and
required Acme to initiate ISD ground-water monitoring in May 1985.
The facility submitted a ground-water monitoring program plan to
RWQCB in May 1985 and a revised plan in August 1985. Two quarters of
The Interim Status Document (ISD) was issued to existing waste management facilities, like
Acme, as interim status permits under the Health and Safety Code, Division 20, Article 5.5,
and were essentially ec ivalent to the Federal RCRA program. The ISD permit is the
process used to adopt .nd enforce the Federal RCRA requirements at interim status
facilities.
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DRAFT 7/13/88 5
monitoring were completed using the August plan. The program was further
revised in February 1986. The current RCRA-equivalent monitoring well
network consists of 26 wells around the North Parcel. These wells are sampled
quarterly for interim status parameters. The facility identifies the first quarter of
1986 as the beginning of interim status detection monitoring. All the wells in the
North Parcel were completed and sampled in 1985; however, all the remaining
facility wells (34 additional non-RCRA/ISD wells around the South and East
parcels) were not completed. At the time of the Task Force inspection six
quarters of interim status ground-water monitoring data had been collected.
Acme submitted a RCRA Part B app!:cation to EPA Region IX in August
1983 for operation of the North Parcel landfill. California was never delegated
authority to issue RCRA permits; therefore, review and issuance of a Part B
permit has always been the responsibility of EPA. The Agency never completed
the permit review because the facility reported that RCRA hazardous wastes (as
defined in 40 CFR Part 261) had not been received since 1984. Task Force
review of manifests indicates that RCRA wastes from offsite sources have been
disposed of at the facility, at least until August 1985, and hazardous waste
leachate was disposed of onsite until May 1986. The Task Force has, therefore,
reviewed facility compliance with both ISD/RCRA interim status and RCRA Part
B permit ground-water monitoring requirements.
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DRAFT 7/13/88 6
SUMMARY OF FINDINGS AND CONCLUSIONS
The findings and conclusions presented reflect conditions existing at the
facility in June 1987. Actions taken by the State, EPA Region IX and Acme
subsequent to June are summarized in the accompanying update.
GROUND-WATER MONITORING DURING INTERIM STATUS
Task Force personnel evaluated the interim status ground-water
monitoring program at Acme for the period between November 1981, when
RCRA and applicable provisions of the RCRA-equivalent California Health and
Safety Code became effective, and June 1987. The evaluation revealed that no
RCRA equivalent interim status ground-water monitoring (ISO) program was
implemented at Acme until the first quarter of 1986. The RWQCB approved a
waiver request from Acme and substituted an alternative "self-monitoring
program" in lieu of the ISD program which was effective between March 1983
and May 1985. The self-monitoring program, however, was not equivalent to
the ISD (RCRA equivalent program).
The Task Force evaluated facility implementation of both the RWQCB
self-monitoring and ISD monitoring programs and determined the implemen-
tation by Acme to be inadequate. The self-monitoring program was not
appropriate as an alternative monitoring program because a waiver may only
be approved if a low potential for migration of hazardous wastes can be
demonstrated [ISD Section VIII (5)]. The waiver request was not granted
under this provision. Acme was not in full compliance with the self-monitoring
program requirements. The self-monitoring program is discussed further in the
Technical Report.
Program components of the interim status equivalent program
(implemented by Acme under the ISD in 1986), including the ground-water
sampling and analysis plan and procedures, monitoring well network and
assessment program outline and plan, did not comply with State or Federal
RCRA requirements. Compliance with the ISD is discussed in the following
sections.
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DRAFT 7/13/88 7
Ground-Water Sampling and Analysis Plan
The ISO ground-water sampling and analysis plans submitted in August
1985 and revised in February 1986 are inadequate and do not comply with the
ISO requirements in Section VIII (2)(a-c) or equivalent RCRA requirements in 40
CFR Part 265.92. The plans do not adequately detail the procedures followed
for sample collection, sample preservation and shipment or analytical
procedures. The forms presented for chain-of-custody control were adequate.
The August 1985 plan did not include information regarding:
(a) methods and equipment for collection of samples, (b) procedures to
measure total well depth, (c) accuracy of water level measurements, (d) method
of determining purge volume, (e) calibrations and decontamination of field
meters, (f) equipment and procedures for filtering samples, (g) procedures for
collection and disposal of purge water, (h) procedures for preservation of
samples, (i) a complete list of parameters, (j) a list of analytical methods or (k) a
quality assurance/quality control program.
The February 1986 plan, although significantly more detailed than the
August plan, still did not include details regarding: (a) methods and equipment
for collection of purge and excess sample water, (b) method of determining
purge volume, (c) calibration and decontamination of field meters, (d) equip-
ment and procedures for filtering of samples, (e) a complete list of parameters or
(f) a list of analytical methods. The plan also did not contain a sampling
schedule, which is necessary because monitoring frequencies and parameter
requirements change after the first year. Without these items, the sampling plan
is deficient.
Sampling and Analysis Procedures
The contractor personnel for Acme, Harding Lawson Associates (HLA),*
conducting the interim status sampling, did not follow the sampling and analysis
procedures submitted in the August 1985 and February 1986 plans and,
HLA provides Acme with hydrogeologic consulting, as well as, sampling and assistance with
other aspects of RCRA compliance (e.g., sampling plans, permit applications, assessment
outlines).
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8
therefore, did not comply with ISO requirements [Section VIII (2)(a)] or 40 CFR
Part 265.92(c). In addition to not following the prepared sampling and analysis
plan, the procedures used by HLA were inadequate. The contractor did not
make the required water level measurements, use the sampling equipment
specified or record field measurements. The plan required the total well depth
to be measured quarterly and recorded to the nearest 0.01 foot. Sampling
records indicate that the depths used to determine purge volumes are those
from construction records rather than quarterly field measurements; therefore,
sufficient purge volumes may not be extracted during purging. The depths
recorded in construction records vary significantly from the current well depths
and drilling logs, as demonstrated'during the Task Force inspection. During the
inspection, 23 of the 26 interim status wells were measured and found to vary
significantly from the depths used by HLA (between 10.54 feet shallower to 6.42
feet deeper). The depths used by HLA were also recorded to the nearest 0.5
foot rather than the 0.01 foot required by the plan.
The facility does not use the equipment specified in the plan for purging
wells. Conductivity, pH and temperature measurements taken in the field were
also not recorded. The plan requires these measurements to be recorded on
field data sheets.
Samples, collected for total metals analyses, are filtered in the field and
then preserved with nitric acid to a pH < 2. The plan does not indicate that any
samples will be filtered, and most metals are reported in analytical reports as
total metals concentrations. If samples are filtered they must be reported as
dissolved metals concentrations, instead of total concentrations, as currently
reported by HLA.
The two methods used by the facility for disposal of purge water are
inappropriate. Purge water for the majority of wells sampled is discharged from
a bucket or pump directly to the ground adjacent to the well. Because this water
may contain hazardous waste or hazardous waste constituents, it needs to be
disposed of in a more environmentally sound manner. Water purged from wells
along the southern border (IT Vine Hill property boundary) is collected in drums,
but then the water from the drums is poured into the North Parcel hazardous
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waste trenches, a violation of 265.314(b)*and (f)." Split samples given to
Acme by the Task Force during the inspection were also disposed in the
hazardous waste trenches, in the bottles provided, without being analyzed.
Task Force personnel inspected the laboratories contracted by Acme,
which conduct the interim status analyses for ground-water samples. The
inspection revealed analytical biases due to improper sample handling,
improper analytical procedures and inadequate quality control methods for the
majority of the parameters. The results of the laboratory evaluation are
discussed further in the Technical Report.
Monitoring Well Network
The monitoring well construction procedures specified in the ground-
water monitoring program were adequate; however, these procedures were not
always followed and many discrepancies were discovered in well construction
records. The construction records submitted to the State/EPA were often
incomplete or inaccurate, when compared to field drilling records, as follows:
No construction records for nine wells.
Drilling depths on construction records do not match field records
for five wells.
Construction diagrams are inaccurate or incomplete regarding
completion techniques (i.e., silt traps, cave-ins, hole size, cement
volumes, etc.) for 21 wells.
Sieve analyses were not performed for any of the monitoring
wells, as required in the plan; therefore, the sand pack and screen
size selections may be inadequate.
Geologic descriptions were edited by HLA for 23 wells, and vary
significantly from the drilling records for 9 of the wells. The
descriptions, as edited, do not include important details available
in the drilling logs. Some formation names were changed (e.g.,
did not include peat zones, or silty sands were called silty clays).
Effective May 8, 1985, the placement of bulk or noncontainerized liquid hazardous waste
or hazardous waste containing free liquids in any landfill is prohibited [265.314(b)].
Effective the same date, placement of any liquid which is not a hazardous waste in a landfill
is prohibited without authorization [265.314(f)].
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10
Additional construction problems were identified during the Task Force
sampling, and include:
Surface cement seals, installed around the wellhead to dr?;n
surface water away, were broken or missing at four wens
(MW115, MW120, MW124 and G25).
Locking well caps, to prevent unauthorized access and surface
contamination, were missing at four well's (MW102, MW104,
MW119andG25).
Surface casing was overflowing, indicating either inadequate
cement seals or broken casing, at four wells (MW116, MW125,
G15andG20).
Turbid samples were collected, suggesting deficiencies in the well
construction and/or inadequate well development, at four wells
(MW115, MW117, MW119 and G20).
No abandonment records were available for three abandoned
wells (G4, G6 and G14). Improperly abandoned wells can be
conduits for migration of leachate into completion zones.
The uppermost aquifer and the hydrogeologic units that need to be mon-
itored at the facility have not been adequately identified by Acme. Therefore,
adequacy of the well locations (vertical and areal) cannot be verified because
the ground-water flow zones, and the direction and rate of ground-water flow
have not been defined. The facility designated upgradient/background well G6
is not adequate because it is completed into the bedrock rather than the uncon-
solidated formations, collectively identified by Acme as the uppermost aquifer
(bay mud).
Under 40 CFR Part 265.91 (a), the facility is required to further charac-
terize water-bearing formations and determine the degree of interconnection,
hydraulic gradients, flow directions and flow rates in the uppermost aquifer and
any interconnected aquifers in order to adequately locate monitoring wells.
Acme has not completed an adequate characterization.
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Assessment Program Qutline and Plan
An outline for a ground-water quality assessment program was required
by the DOHS-issued ISO [Section VIII (3)] and 40 CFR Part 265.93, by
November 19, 1981. Acme did not prepare the outline before the ground-water
monitoring waiver was requested in 1982. After the waiver was rescinded in
1985, Acme did not prepare the assessment outline, as required. A report titled,
"Comprehensive Ground-Water Monitoring Evaluation - FY85-86," was
prepared by RWQCB and was sent to Acme on April 23, 1986, along with a
cover letter. The cover letter delineated several areas of noncompliance, one
being the lack of a ground-water assessment outline. Acme was requested to
have a schedule for resolving the deficiencies by May 23, 1986.
Acme had not submitted an outline at the time of the Task Force
inspection. The first outline was submitted in August 1987. The outline is
required to describe a more comprehensive ground-water monitoring program
capable of determining:
Which hazardous waste or hazardous waste constituents have
entered the ground water
The rate and extent of migration of hazardous waste or hazardous
waste constituents in the ground water
The concentration of hazardous waste or hazardous waste con-
stituents in the ground water
The August 1987 outline does not comply with the State or EPA
regulations because:
It does not address how the facility will verify that all contaminants
have been identified in the plume.
It does not address how the rate and extent of contamination would
be determined, other than by review of existing data.
It does not address how data triggering assessment would be
evaluated to confirm apparent contamination.
It was submitted to RWQCB for approval in August 1987, more than
5 years late.
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Samples collected by Acme, under the RWQCB approved self-monitoring
program (1983) contained elevated levels of total dissolved solids (TDS), total
organic carbon (TOC), chlorides and conductivity when compared to the
designated upgradient well (G6). (This well was first designated as an
upgradient well in the Part B application, submitted in August 1983.) Volatile
organics (including tetrahydrofuran, trichloroethylene and methylene chloride)
and various heavy metals were also detected in several of the wells as early as
1983.
The facility had completed six quarters of interim status monitoring at the
time of the Task Force inspection. No statistical analysis has ever been per-
formed by the facility, as required by the ISO [Section VIII (3)(b-d)] and 40 CFR
Part 265.93(b-d). A Task Force analysis of the data showed that at the end of
the fifth quarter of monitoring (March 1987), had the facility performed the
required statistical analysis, a statistically significant increase (or decrease for
pH) would have been identified for several indicator parameters. All down-
gradient wells, 25 total, showed statistically significant increases (0.01 level of
significance) in conductivity. Wells MW115 and G25 had an increase and
decrease in pH, respectively, and 23 wells had significant increases in TOC.
Total organic halide (TOX) data was not evaluated by the Task Force due to
questioned validity of data because of high chloride concentrations in ground
water beneath the site.
Based on the starting date for the interim status monitoring program,
Acme should have initiated an assessment program, at a minimum in March
1987, at the end of the fifth quarter of interim status monitoring. The assessment
program plan must specify:
The number, location and depths of wells
Sampling and analytical methods for those hazardous wastes or
hazardous waste constituents at the facility
Evaluation procedures, including any use of previously gathered
ground-water quality information
A schedule of implementation
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13
Acme has never submitted an assessment program plan. The
implementation of the assessment program must be in accordance with
provisions and time tables specified in 40 CFR Part 265.93(d) and CAC*
Title 22, Section 67194(a).
GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT
The ground-water monitoring portion of the RCRA Part B permit
application, submitted to EPA Region IX on August 2, 1983 by Acme, does not
comply with the requirements of 40 CFR Part 270.14(c)." The facility detected
hazardous waste constituents in August 1982 (cadmium and lead), in wells at
the point of compliance, at concentrations above the EPA-designated maximum
contaminant levels [40 CFR. Part 264.94]. Since heavy metals and volatile
organics were detected at the point of compliance, before submission of the
RCRA permit application, the application should have proposed a compliance
monitoring system and submitted an engineering plan for a corrective action
program [40 CFR 270.14(c)(7)] or adequate hydrogeologic characterization
[40 CFR 270.14(c)(2)].
The permit application does not describe the plume of contamination
[270.14(c)(4)], or the hazardous waste constituents in the plume [270.14(c)(8)].
The application also does not include the engineering plan required in 40 CFR
Part 270.14(c)(7), which requires a feasibility plan for a corrective action
program under 40 CFR Part 264.100.
The proposed detection monitoring program was not adequate because
it did not characterize the hydrogeology, ground-water flow direction or rates,
and proposed the use of inadequate existing self-monitoring wells in the
system.
The California Administrative Code (CAC) was revised effective January 1, 1988, and
renamed the California Code of Regulations (OCR). However, at the time of the Task Force
investigation, the CAC was in effect and is cited as such throughout this report.
The State of California was never granted authorization to issue RCRA land disposal
permits; therefore. Federal requirements are cited here.
-------
DRAFT 7/13/88 14
TASK FORCE SAMPLING AND MONITORING DATA EVALUATION
Results of the Task Force sampling and monitoring data evaluation
indicate that the landfill is leaking hazardous waste constituents to the ground
water.
Analysis of samples collected from the facility ground-water monitoring
wells shows that volatile organics, metals, inorganics (e.g., 864 and Cl) and
indicator parameters (TOC, TOX, pH, conductivity), as defined in 40 CFR Part
265.92(b)(3) are present in the designated downgradient wells at levels greater
than those found in the designated upgradient well (G6). Furthermore, most of
the constituents found in the wells were also found in the landfill leachate
sampled from well NPGR5. The volatile organic and metals analyses of
ground-water samples collected by the Task Force verify the data collected by
HLA; however, several additional constituents were identified.
COMPLIANCE WITH CERCLA OFFSITE POLICY
The EPA offsite policy requires that any treatment, storage or disposal
facility (TSDF) used for land disposal of waste from CERCLA response actions
must be in compliance with the applicable technical requirements of RCRA.
Interim Status facilities must have an adequate ground-water monitoring
program to assess whether the facility has had a significant impact on ground-
water quality. The Acme facility has not complied with the technical ground-
water monitoring requirements for waste management facilities.
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TECHNICAL REPORT
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15
INVESTIGATIVE METHODS
The Task Force evaluation of Acme consisted of:
Reviewing and evaluating records and documents from EPA
Region IX, California Department of Health Services (DOHS),
Regional Water Quality Control Board (RWQCB), State Water
Resources Control Board (SWRCB), and Acme
Conducting an onsite facility inspection June 2 through June 12,
1987
Evaluating two offsite contractor laboratories
Determining water level elevations in selected wells
Sampling and subsequent analysis of ground water from selected
wells
RECORDS/DOCUMENTS REVIEW AND EVALUATION
Records and documents from EPA Region IX and California State offices
were reviewed prior to the onsite inspection. Additional state records were
obtained by Task Force personnel during the onsite inspection. Facility records
were reviewed to verify information currently in Government files and to sup-
plement Government information where necessary. Selected documents
requiring further evaluation were copied by Task Force personnel during the
inspection. Records were reviewed to obtain information about facility opera-
tions, location and construction of waste management units and monitoring
wells, and ground-water monitoring activities.
Specific documents and records that were requested and reviewed, if
available, included the ground-water sampling and analysis plan, ground-water
quality assessment program outline, analytical results from past ground-water
sampling, monitoring well construction data and logs, site geologic reports, site
operation plans, facility permits, unit design and operation reports, selected
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16
personnel position descriptions and qualifications (those related to the required
ground-water monitoring), and operation records showing the general types
and quantities of wastes disposed of at the facility and their disposal locations.
FACILITY INSPECTION
A facility inspection was conducted to identify waste management units
(past and present), to observe current waste management operations and
pollution control practices, and to verify the location of ground-water monitoring
wells and leachate collection sumps.
Company representatives supplied records and documents, answered
questions about the information and explained: (1).past and present facility
operations, (2) site hydrogeology, (3) the ground-water monitoring system and
(4) the ground-water sampling and analysis plan. Ground-water samples are
collected and analyzed by offsite contractors for Acme. Harding Lawson
Associates (HLA) collects ground-water samples and Curtis and Tompkins Ltd.
laboratories performs requested analyses. Personnel from HLA demonstrated
sampling techniques and were questioned regarding sample collection,
handling, analysis and document control. HLA personnel also provide
hydrogeologic consulting and other services to Acme.
LABORATORY EVALUATION
The Curtis and Tompkins Ltd. laboratories in San Francisco and Los
Angeles, California analyzed the majority of ground-water parameters for Acme
during the interim status ground-water monitoring period (January 1986 through
June 1987) evaluated by the Task Force. The laboratories were evaluated
between June 2 and 11, 1987 to determine their ability to produce valid data.
Analytical equipment and methods and quality assurance procedures were
examined for adequacy. Laboratory records were inspected for completeness,
accuracy and compliance with State and Federal requirements. The results of
the evaluation are discussed in the "Sample Analysis and Data Quality
Assessment" section of this report.
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17
WATER LEVF1 MEASUREMENTS AND SAMPLE COLLECTION
Sampling activities during the investigation included the following:
Measuring total depth and water levels in 33 Acme-designated
RCRA interim status monitoring wells
Collecting ground-water samples from nine monitoring wells and a
leachate sample from a former injection well
Recording water levels in three monitoring wells continuously for
approximately 48 hours
Task Force personnel measured water levels and total depth in 33
monitoring wells surrounding the North and East Parcel landfills [Table 1] to
verify past Acme data. Wells adjacent to the Acme facility on the IT Vine Hill*
property were measured at approximately the same time in order to compare
water levels. All water levels were taken as close to low tidal phase as feasible
in order to minimize tidal effects, if any, on the wells. Additional water level
measurements were made on the wells sampled prior to purging the wells.
Samples were collected to determine if the ground water contains
hazardous waste or h? ^rdous waste constituents. Wells sampled were
chosen for the proximity ,o hazardous waste management areas, depth of
completion or historically containing hazardous waste constituents, when
sampled by Acme [Figure 2]. Wells screened at different depths and geologic
formations were chosen to sample a variety of horizons within the
Acme-designated uppermost aquifer. Five of the wells (MW104, MW115,
MW116, MW117 and G20) were drilled to depths of less than 40 feet and
completed predominantly in a silty clay formation. One well, MW119, was
drilled to a depth of 41 feet and completed in peat. Two wells, MW126 and
The Acme property shares a common border with another hazardous waste disposal facility,
International Technology (IT) Vine Hill and Baker properties. A Task Force inspection of the
IT facilities took place during the same time frame as the Acme inspection.
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18
Table 1
WATER LEVEL ELEVATIONS
Top of Casing
Elevation*
Well No. 5/18/87 (2)
MW101 16.18
MW102 26.35
MW103 22.33
MW104 13.43
MW105 10.15
MW106 5.64
MW107 3.80
. \V108 8.84
MW109 8.22
MW110 7.19
MW111 7.92
IMW113 5.62
MW114 16.09
MW115 20.05
MW116 17.12
MW117 11.18
MW118 13.10
MW119 19.10
MW120 4.61
MW121 5.88
MW122 3.48
MW123 2.61
MW124 10.36
MW125
MW126
MW128 13.15
G6A 36.14
G14 3.60
G15 9.23
G18 4.10
G19 4.38
G20 ' 5.66
G24 13.16
G25 9.85
G30 4.54
G31 6.07
G32 5.69
Top of Casing
Elevation
(2,4)
16.11
21.75
22.49
13.34
10.12
6.39
3.71
8.71
8.63
7.84
8.09
5.70
11.77
20.29
17.47
11.39
13.37
14.50
4.63
5.82
3.41
2.57
10.75 '
.
6.63
.
.
3.58
4.01
4.11
4.36
5.90
13.45
10.21
4.48
6.02
5.9
Most recent measurement used by
Water Level Total Well Water Table
Elevations (1)
8.25
6.73
15.97
8.28
6.38
0.10
5.02
7.54
3.51
3.84
2.72
4.36
4.43
4.97
2.12
6.2
1.43
4.82
4.46
4.48
5.71
6.43
4.04
-
2.88
5.72
29.26
.
.
5.69
1.57
3.28
11.03
4.78
0.23
1.43
1.03
Task Force personnel
Depth (1) Elevations (2)
14.89
42.42
30.45
21.67
16.44
19.05
18.29
20.46
20.49
20.48
.
18.45
35.25
37.54
36.95
26.59
26.02
41.29
16.10
16.65
16.83
15.51
23.06
-
69.45
65.5
36.44
-
.
19.04
18.56
17.70
20.88
15.35
98.69
33.75
40.20
7.93
19.62
6.36
5.15
3.77
5.54
-1.22
1.30
4.71
3.35
5.20
1.26
11.66
15.08
15.00
4.98
11.67
14.28
0.15
1.40
-2.23
-3.82
6.32
-
- '
7.43
6.88
-
-
-1.59
2.81
2.38
2.13
5.07
4.31
4.64
4.66
Date
06/03/87
06/03/87
06/03/87
06/03/87
06/03/87
06/03/87
06/03/87
06/03/87
06/03/87
06/03/87
06/02/87
06/03/87
06/03/87
06/03/87
06/03/87
06/02/87 .
06/02/87
06/02/87
06/03/87
06/03/87
06/03/87
06/03/87
06/03/87
-
06/03/87
06/02/87
06/03/87
-
-
06/03/87
06/03/87
06/03/87
06/03/87
06/03/87
06/03/87
06/03/87
06/03/87
Time
(3)
0945
1000
1035
1055
1115
1105
1140
1025
1155
1120
1230
1350
1420
1410
1440
1520
1455
1405
1515
1740
1715
1640
1430
-
1345
1435
0825
-
-
1525
1445
1400
1455
1400
1600
1555
1540
Screened
Interval
(5)
S/C
PT/C
PT/C
S/C
C
PT/C
C
c
PT
PT/C
S/C
C
PT
C
C
PT/C
PT
PT
C
C
C
C
PT/C
C
C
PT/C
SS/SH
PT/C
PT/C/S
C
C
C
c
c
S/G/C
s
S/G
1 Measurement recorded in feet below the top of the surface casing
2 Elevations recorded
in feet above/below mean sea level
3 Rounded to nearest 5 minutes
4 Elevations reported
Plan; Acme Landfill"
5 Geologic units S/C •
and shale units, S/G
in 02/04/86 Harding Lawson Associates report titled
sand and silty
clay units, PT/C • peat
- sand and gravel units, S/G/C • sand,
"Implementation of Ground-Water
and sitty clay units, C - silty
gravel, and silty
clay units
clay, PT - peat,
SS/SH -
Monitoring
sandstone
-------
MW107
MW109
1W 1 2 3
MW1 22
QMW112
QMW113
MW126
G2°
NORTH PARCEL
EAST PARCEL
Gl^
G31 OO
O MW12JL-
LEGEND
Property Boundary
• Waste Management Area
Monitoring wells
G6A
O Water Levels Only
Q Water Levels and Samples
Z\ Leachate Well Sampled ^ o
r 1 vj U K t Z
I Upgra d lent We 11 -
water level and sample TASK FORCE SAMPLING
Q. MW121
5n
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20
MW128 were drilled to depths of approximately 65 feet and completed in peat
and clay, respectively. The final well chosen was G6 (formerly G6A), the
facility-designated upgradient well. One leachate monitoring well, NPGR5, was
also sampled to characterize constituents in the leachate.
All samples were collected by an EPA contractor, Versar, Inc.,
Springfield, Virginia and sent either to NEIC (contract funds were not available
for analysis of some wells) or contractor laboratories for analysis. Analytical
data and methods, which were used by the Task Force for Acme samples, are
presented in Appendix A. Duplicate volatile organic samples and split samples
of other parameters were offered to Acme. Samples were accepted by the
facility the first day of sampling and declined thereafter. The split and replicate
samples provided to Acme for wells G6A, MW119, a field blank and a trip blank
were later discovered to have been disposed of in Acme's "winter" hazardous
waste disposal trench. Both EPA Region IX and California declined split
samples.
None of the Acme-designated RCRA wells were equipped with pumps,
therefore, the EPA contractor supplied purging and sampling equipment for
each well sampled. Sample collection procedures were as follows:*
1. Acme contractor personnel unlocked the wellhead.
2. The open wellhead was checked for chemical vapors
[PhotovacTIP® and organic vapor analyzer (OVA®)] and
radiation.**
3. The depth to ground-water was measured using an oil/water sonic
Interface Probe (Moisture Control Co., Inc. Model B2220-3)
[Table 1] and recorded to the nearest 0.01 feet.
Unless specified, the EPA contractors conducted the work.
Photovac TIP and OVA are registered trademarks and appear hereafter without ®.
Using Ludlum Survey meter model M44-9
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21
4. The Interface Probe was lowered through the water column until
the bottom of the well was reached, and the total depth was
recorded to the nearest .01 foot.
5. The Interface Probe was retrieved from the well bore. The cable
and probe were decontaminated after each use with a pesticide-
grade hexane wipe, followed by a distilled water rinse and wiped
dry.
6. The well was relocked. The water levels were taken at selected
wells on the first 2 days of the inspection and then the wells were
locked until they were sampled later in the inspection.
7. When a well was ready to be sampled, HLA personnel reopened
the wellhead.
8. Water level measurements were made before purging, as
discussed in steps 3 and 5 above.
9. Water-column volumes were calculated using the height of the
water column and the well casing radius.
10. Three water-column volumes were purged using equipment
specified in Table 2 and the purge water was collected in a
4-gallon plastic bucket (marked in quarts). Purge water was either
poured on the ground at a distance from the well (if the well
historically showed no contaminants) or stored in barrels for facility
disposal (if historically containing contaminants), as per facility
procedures.
11. A sample aliquot was collected at the beginning, middle and end
of the purge for temperature, specific conductance and pH
measurements. Table 3 presents information on sample
collection.
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Table 2
PURGING RECORD
Well No.
MW104
MW115
MW116
MW117
MW119
MW126
MW128
G20
G6A
lop of Surface
Total Well Casing Elevation Water Level
Depth (1) (2.4) Elevations (1)
21.67 13.43 8.63
36.95 20.05 4.02
36.95 17.12 1.04
26.59 11.18 4.85
41.29 19.10 4.37
69.45 - 2.85
65.50 13.15 5.75
17.70 5.66 1.82
36.44 36.14 29.26
Total Volume of
Water Purged
(Gallons)
20
26
26.25
18
30
128
1.20
21
4.5
Date
06/09/87
06/08/87
06/08/87
06/05/87
06/04/87
06/08/87
06/04/87
06/08/87
06/03/87
Time (3)
0820-0915
0820-0945
0755-0905
1430-1445
0955-1030
1240-1450
1435-1610
1000-1045
0855-0930
Methods/Remarks
Teflon bailer, well purged dry
green, slight sulphur odor
Teflon bailer, well purged dry
Teflon bailer, well purged dry
yellow, silty purge water
Keck pump, well purged dry
yellow odoriferous purge water
Keck pump, well purged dry
Keck pump
Keck pump
Teflon bailer, well purged dry
yellow/brown purge water
Teflon bailer, well purged dry
1 Measurements recorded by Task Force personnel in feet below the top of the surface casing.
2 Elevations recorded in feet above mean sea level
3 Rounded to nearest 5 minutes
4 Top of casing elevation as recorded by Harding Lawson Associates on 05/18/87
INJ
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23
Table 3
SAMPLING RECORD
Well No.
MW104
Field
Blank
MW115
MW116
MW117
MW119
Field
Blank
MW126
MW128
G20
G6A
NPGR5
Eqp.
Blank
Eqp.
Blank
Trip
Blank
Date
06/09/87
06/09/87
06/08/87
06/08/87
06/08/87
06/08/87
06/08/87
06/09/87
06/04/87
06/05/87
06/04/87
06/08/87
06/04/87
06/08/87
06/03/87
06/04/87
06/05/87
06/04/87
06/05/87
05/27/87
Time(1)
1055-1125
0810-0825
1130-1150
1550-1605
1045-1100
1620-1645
1515-1520
0945-1015
1245-1335
0810-1020
0855-1000
1520-1535
1615-1655
1235-1325
1550-1630
0820-0855
1015-1120
1215
1530
0900
Sample No.
MQB417
MQB418
MQB413
MQB412
MQB415
MQB405
MQB406
MQB407
MQB404
MQB416
MQB409
MQB414
MQB402
MQB410
MQB408
MQB411
MQB401
Methods/Remarks
Teflon bailer
Field blank poured at MW104
Teflon bailer
Teflon bailer
Teflon bailer, sample very black and
sediment filled, bailer oily
Teflon bailer, triplicate sample,
sample very green/black
Field blank poured at M W1 1 9
Teflon bailer
Teflon bailer, matrix spike, sample
has yellow tinge
Teflon bailer, sample is yellow but
not turbid
Teflon bailer
Teflon bailer
Equipment blank, through the
Keck pump
Equipment blank, through a Teflon
bailer
Prepared at contract lab
Sent into field
Rounded to nearest 5 minutes
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24
12. Sample containers were filled in the order specified in
Table 4 using dedicated Teflon® bailers. All samples
collected from the monitoring wells were filled directly from
the Teflon bailers. Split samples were collected by filling
one-third of each sample bottle for Acme and Task Force,
respectively, from the bailer until each bottle was filled. If
the volume in the bailer could not fill one-third of each
bottle, the bailer was divided equally between the bottles.
Table 4
ORDER OF SAMPLE COLLECTION,
BOTTLE TYPE AND PRESERVATIVE LIST
Parameter
Bottle
Preservative*
Volatile organic analysis (VOA)
purge and trap
Purgeable organic carbon (POC)
Purgeable organic halogens (POX)
Extractable organics
Dioxin/Furans
Total metals
Total organic carbon (TOC)
Total organic halogens (TOX)
Phenol
Cyanide
Anions
Sulfides
2 60-ml VOA vials
2 60-ml VOA vials
2 60-ml VOA vials
6 1-qt. amber glass
2 1-qt. amber glass
1 1-qt. plastic
1 4-oz. glass
1-qt. amber glass
1-qt. amber glass
1-qt. plastic
1-qt. plastic
1-qt. plastic
HNOa
H2SO4
CuSO4
NaOH
All samples were stored on ice immediately after collection and during transport to the
analytical laboratories.
13. Samples were placed on ice in an insulated cooler.
14. Samples were taken to a staging area immediately after collection,
where the samples were preserved [Table 4].
® Teflon is a registered trademark and appears hereafter without ®.
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25
The order of sample aliquot collection was modified when slow recharge
prevented collection of all aliquots at one time. In these cases (wells MW115,
MW116, MW117, MW119, and G6) organic samples were collected within
2 hours following purging; the remaining aliquots were collected as soon as
recharge had provided a sufficient volume of water.
The EPA contractor prepared field blanks for each analytical parameter
group (e.g., volatiles, organics and metals) twice during the investigation (near
wells MW104 and MW119) by pouring distilled, deionized water into sample
containers. Two equipment blanks were poured, one through a laboratory
cleaned Teflon bailer and the other through the Keck pump. The pump
equipment blank was taken to verify the field decontamination. One trip blank
for each parameter group was also prepared during the inspection and
submitted to the laboratory. The blanks were submitted with no distinguishing
labeling or marking to identify them as blanks.
In addition to the blank samples, matrix spike and triplicate samples were
taken for analytical quality assurance/quality control purposes. One laboratory
matrix spike sample, which consisted of two duplicate VOA vials and two 1-liter
amber glass bottles, was collected at well MW128. A laboratory triplicate of all
parameter groups was collected at well MW119.
During collection of all samples, Task Force personnel complied with
safety procedures contained in EPA 1440-Occupational Health and Safety
Manual (1986 edition); Agency orders and applicable provisions of the
NIOSH/OSHA/USCG/EPA Occupational Safety and Health Guidance Manual
for Hazardous Waste Site Activities. OVA and/or HNU photoionization readings
above background in the breathing zone were encountered at wells MW110,
MW115, MW117, MW118, MW119, MW126 and MW128 during water level
measurements or sampling; therefore, sampling personnel wore respiratory
protection. These wells are thought to have had methane present since the
OVA readings were higher than the HNU readings. Drager® tubes for vinyl
chloride (0.5/a) were used when HNU readings were above background
® Drager is a registered trademark and will be shown hereafter without ®.
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26
(MW115, MW118 and NPGR5) in the breathing zone. The Drager tube
readings for these wells were <0.5, <0.5 and >3 parts per million (ppm), respec-
tively. Personnel sampling NPGR5 wore self-contained breathing apparatus,
because respirator cartridges break through at 1 ppm of vinyl chloride and the
threshold limit value is 5 ppm. The vinyl chloride Drager tubes have sensitivi-
ties to numerous chlorinated hydrocarbons [Appendix B]. Vinyl chloride was
not detected in any of the samples analyzed; however, other chlorinated hydro-
carbons were detected.
At the end of each day, Task Force samples were packaged and shipped
according to applicable U.S. Department of Transportation (DOT) regulations
(49 CFR Parts 171-177) to either the two EPA contract laboratories or the NEIC
laboratory. Acme personnel were given receipts for all samples collected. EPA
chain-of-custody procedures were followed during the handling, transfer and
shipping of all samples.
Following collection of all ground-water samples, Versar installed ISCO®
meters to continuously record the water levels in each of the three monitoring
wells chosen [Figure 3]. These wells were chosen for their proximity to the
East Parcel dikes along Pacheco Creek and represented the highest potential
for detection of tidal influences, if present. The procedures listed in Appendix C
were followed when assembling, calibrating and operating the ISCO water level
meters. The ISCO meters were all shown to be accurate through repetitive
water level measurements using the Interface Probe [Table 5].
® ISCO is a registered trademark for Instrumentation Specialties Company and will be shown
hereafter without .
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/
MW123
MW1 22
NORTH PARCEL
EAST PARCEL
MW12 1
FIGURE 3
WELLS MONITORED WITH
ISCO METERS
SCALE IN FEET
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28
Table 5
ISCO METER VERIFICATION
Date
6/11
6/11
6/11
6/12
6/9
6/10
6/10
6/11
6/11
6/11
6/12
6/9
6/10
6/10
6/11
6/11
6/11
6/12
Time
Well
0759
1308
1606
0820
Well
1652
0930
1430
0820
1313
1611
0805
Well
1621
0919
1448
0842
1319
1616
0748
ISCO
Display
(ft.)
MW121
1.512
1.493
1.511
*
MW122
1.499
1.607
1.578
1.698
1.660
1.642
1.731
MW123
1.501
1.621
1.655
1.764*
1.777
1.790
*
Water
Level
(ft.)
4.33
4 3.9
5.41
5.4
5.3
5.26
5.41
5.47
5.13
5.03
ISCO meter stopped functioning due to low power
source, battery replaced.
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29
The ISCO meters recorded water level fluctuations for a 2- to 3-day
period and showed regular sine wave fluctuations (particularly in wells MW121
and MW122); however, the sine waves [Figure 4] were not in sequence with
the tidal changes. IT performed a tidal study in 1975 and determined that wells
completed in the upper bay mud showed tidal fluctuations which closely
correlated to the tidal phases. The length of time the Acme wells were
monitored during the Task Force investigation was too short to draw any
significant conclusions regarding tidal influences.
The facility personnel could not provide a pumping schedule for the
onsite leachate wells, and stated that the wells pump automatically when the
leachate level reaches a specific level in the sumps. Water level fluctuations of
up to two-tenths of a foot were observed in well MW122. The cause of these
fluctuations and their effects on water levels across the facility must be
determined to adequately interpret water level data obtained during quarterly
monitoring. Pumping wells and/or tides may significantly affect water levels and
define when water levels should be taken during quarterly monitoring to
determine hydraulic gradients.
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FIGURE 4
TIDAL AND ISCO METER FLUXES
30
t 5
Tidal Fluxes
1200
6/9
.5
2400 \ 1 2 0 0
2400 \ 1 ioo
\ (*/ I 1
Date/TU me
Well MW1 2 1
2400 \ 1 2" 0 0 2400
1/12
3 • 4
'J
75
"* . 3 •
1200 2400 1200 2400 1200 2400
6/9 6/1° Date/TiS/e11
1200 2400
6/12
Well MW122
. 6
-3
•» . 5 .
a
o -4 •
'J
i.a
^ -^
1200 2400 1200 2400 1200 2400 1200 240C
6/9 6/10 _ .-.6/11 6/12
Date/Time
.5
O •*
'J
Well MW1 23
_1_
_i_
1200
6/9
2400
1200 2400 1200
6/10 6/11
Date/Time
2400
•*•*««
1200
6/12
2400
* Battery Stopped
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31
FACILITY DESCRIPTION AND OPERATIONS
The Acme landfill is a California Class 11-1 [Table 6] disposal facility that
currently receives designated wastes, as defined in Title 22 of the California
Administrative Code (CAC). In addition to the RWQCB approved designated
wastes, Acme also disposes of asbestos, municipal waste, construction waste
and infectious waste.
Waste handling units and operations were identified during the Task
Force inspection to determine whether hazardous waste or hazardous waste
constituents handled at Acme might enter the ground water. At the time of the
Task Force inspection, Acme was using two above-ground storage tanks for the
storage of RCRA hazardous waste leachate. The tanks are not included on the
Part A or Part B permit applications, and, therefore, did not have interim status.
Past operations included disposal of RCRA hazardous wastes in landfills,
surface impoundments and an injection well. Figure 5 shows the location of all
known past and present Acme storage and disposal units. A discussion of
waste management units related to groundwater monitoring at the Acme site
follows. This discussion is divided into two major areas: (1) Units subject to
RCRA/ISD interim status regulations and (2) units not subject to RCRA/ISD
interim status regulations but which may have released contaminants to the
ground water.
INTERIM STATUS REGULATED WASTE MANAGEMENT UNITS
North Parcel Landfill
The North Parcel [Figure 5] was first used in 1949. It is bounded on the
west by the Diablo Range, on the north by the Southern Pacific Railroad tracks
and Waterfront Road, and on the south and east by Pacheco Slough. Waste
loads were dumped directly on the ground surface (top of bay mud) and burned.
In the late 1950s the practice of open burning ceased and the unengineered
landfill was created when municipal and demolition wastes were co-disposed
with industrial wastes. As before, no liner was constructed and wastes were
disposed of by area filling, directly on the bay mud and on top of existing fill.
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Table 6
CALIFORNIA HAZARDOUS WASTE MANAGEMENT UNIT
CLASSIFICATIONS*
Classes of Waste
Management Units Description
Parti
Class I Accepts hazardous and State designated** wastes
Underlain by materials 1x1 Q/7 permeability
Includes sites formerly classified as Class I and
Class 11-1
Class II Accepts designated wastes as long as they are
adequately contained
Underlain by a liner or materials of 1x10'6
permeability
Nonhazardous wastes as long as they do not render
designated wastes hazardous
Class III Accepts nonhazardous wastes
Dewatered sewage or water treatment sludge but
must have leachate collection and removal
Groups of Wastes
(pre-1984 name) Description
Part II
Group I Hazardous waste
Group II Designated wastes**
Group III Nonhazardous solid waste - municipal refuse
Summarized from CAC Title 23, Chapter 3, Section 2522, revised 1984.
Designated waste is nonhazardous waste which consist of pollutants which, under
ambient environmental conditions, could be released at concentrations in excess
of applicable water quality objectives or which could cause degradation of waters of
the State, or hazardous waste which has been granted a variance under Section
66301 of Title 22 (CAC Title 23, Chapters, Section 2522).
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Leachate Sump
Surface Impoundment
(Leachate)
Le^chate Sum
Leackate ftterage
Taak I
Leachate Obcertloa veil/
Injection Well /
NPGR5 /
NORTH PARCEL
EAST PARCEL
/
LEGEND
Hazardous Wa«t«
Management Area
FIGURE
ACME HAZARDOUS WASTE MANAGEMENT UNITS
Approximate Location
mpoundmento
(Currently operated by IT Corp.)
soo
1000
SCAIE IN FEET
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34
Hazardous and nonhazardous wastes were commingled and compacted
at the working face. During that time period, the wastes were not always
covered at the end of the day. The lack of cover allows percolation of rainfall
into the landfill which causes leachate generation and compromises the
structural integrity of the landfill.
In the 1960's and early 1970's, area filling and co-disposal of municipal
and industrial wastes continued. By 1975 the fill height was approaching 40
feet. At that time, the landfill was estimated, by HLA, to be receiving 1,100 tons
per day of refuse from commercial haulers, 150 tons per day of various refinery
wastes, and an unspecified amount from the general public.
Studies were performed by HLA in 1973 and 1975 in order to obtain a
permit to operate a Class 11-1 landfill. Borings were drilled through the bay mud
to obtain information about the subsurface. At least five of the borings were
drilled through the existing North Parcel and were backfilled with pea gravel. A
20-foot length of perforated PVC was installed near the surface of each so that
ground-water samples could be taken later. This method of well completion has
compromised any natural liner capabilities of the bay mud and could provide a
pathway for vertical contamination from the North Parcel directly to the ground
water.
In December of 1978, a rotational slump failure occurred along the
southeastern slope of the North Parcel [Figure 5]. The exact cause of the failure
was not known. The slump displaced a Contra Costa County Sanitary District
(CCCSD) sewer line 5 to 10 feet and threatened the structural integrity of the
Acme-owned, IT-operated Class I disposal ponds at the toe of the slope. The
toe moved 50 to 75 feet horizontally.
Radial cracks and two large fissures developed in the slumped area, as it
slid toward the wetland. Leachate escaped from the cracks into the wetland.
The area was regraded, compacted and covered with soil. The fissures were
closed and regraded.
The slump could have been caused by the method of construction and
operation of the landfill, since design specifications were not followed. Other
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35
possibilities include differential settlement, structural damage from a potentially
ruptured sewer line, or displacement along the Concord Fault, which runs
underneath the East Parcel.
Acme did not construct the North Parcel according to the HLA design,
which specified that the toe of the fill was to be located at least 50 feet from any
adjacent improvements such as levees or sewer lines to accommodate
expected settlement. The toe of the fill was placed against the dike of the
IT-operated Class I Ponds and less than 50 feet from the CCCSD sewer line.
Recommended compaction studies were not performed, and the 85% design
compaction rate may not have been achieved. The HLA design of the North
Parcel may have underestimated the time needed for the bay muds to
consolidate and gain strength under the waste loading. The height of the fill
was estimated to be 63 feet at the time of the failure; the design height was only
60 feet. When questioned at that time, Acme representatives said that there
were no known limits on fill height.
The CCCSD sewer line, parallel to the eastern slope of the North Parcel,
was displaced 5 to 10 feet to the east by the slope failure. The sewer line was
ruptured, discharging treated effluent to the adjacent wetlands. To relieve the
pressure on the sewer line, thousands of tons of waste material were moved
from the slide area to the northwest portion of the North Parcel. The CCCSD
repaired the sewer line by re-aligning the pipe and packing bay mud around it.
Acme monitors settlement of the landfill and displacement of nearby soils
with a series of inclinometers. The inclinometers are placed into the bay mud
and are allowed to settle for about 1 month before readings are taken. The
deflections noted are measured in inches. The Waste Discharge Requirements
(Order 84-18) issued on February 6, 1978, required Acme to prepare and
submit quarterly slope stability reports to RWQCB, including both an analysis of
the slope stability data and the data itself.
Acme relies on the natural features of the in-situ bay mud to restrict
vertical migration of leachate. The integrity of the bay mud as a liner is
questionable. The permeability and continuity of the bay mud beneath the
North Parcel is not known because it was covered with fill material when the first
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36
engineering studies were performed. HLA studies have stated that sand lenses
exist in the bay mud and that the bay mud has a maximum permeability of at
least 1 x 10'6 cm/sec. Seepage and ponding observed outside of the clay
barriers, wet areas around ground-water monitoring wells, and water levels
indicative of artesian conditions are evidence that the leachate mound may be
penetrating the bay mud and contaminating the ground water.
This landfill presently occupies about 125 acres and accepts Groups I, II
and III waste [Table 6]. Available documentation indicates that RCRA wastes
were accepted from offsite facilities between 1980 and 1985. The trench
method of landfilling is currently in use. The trenches are excavated into
existing fill, and are in use from 1 to 6 months, depending on the volume of
incoming waste. The trenches are typically 15 feet deep by 12 feet wide by 50
to 600 feet long.
Acme has designated one trench as a "winter trench," because it was
designed with a pad to allow access during wet weather. The remaining
trenches are designated "summer trenches." A truck wash is located at the
winter trench. For years, both hazardous and nonhazardous waste hauling
vehicles have washed their trucks out at this location, allowing contaminated
water to run into the trench. Pursuant to 40 CFR 265.314, bulk liquids are not
to be added to a hazardous waste trench. This practice adds to the leachate
generation in the North Parcel, which in turn increases the potential for vertical
migration of contaminants through the bay mud to the ground water. Excess
liquids can also compromise the structural integrity of the landfill, causing slope
failures.
The North Parcel is filled to a maximum height of approximately 85 feet
above the surface of the bay mud with side slopes from 4:1 to 16:1 (run:rise).
During the years when Group I hazardous wastes were accepted, they made up
approximately 3 to 4% of the total wastes disposed of in the North Parcel,
according to Acme representatives. In addition to the offsite wastes which were
accepted, hazardous waste leachate from the North Parcel was disposed of in
the North Parcel from 1981 to 1986 (see discussion of surface impoundment
and injection well).
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37
Runoff Management System
The North Parcel does not have an adequate runoff collection or storage
system. The volume of runoff from a 24-hour, 25-year storm was calculated by
HLA to be 48.61 acre-feet. Runoff from the North Parcel is diverted through four
channels which flow to the wetlands in the northeast and northwest corners of
the Acme property. There is no storage capacity in the northeast corner. The
northwest corner was used by HLA in calculating the runoff storage capacity. In
a May 28, 1986 HLA letter to EPA, Region IX, the northwest corner lowland was
described as a 5-acre storage pond averaging approximately 3 feet in depth.
During the Task Force investigation, the area in question was inspected and
found not to be an engineered pond, rather it is a relatively flat area with a low
ridge of soil along the northern perimeter. It drains through a culvert along the
northern perimeter into a tidal gate, which opens twice per day with the low
tides, and empties into Walnut Creek. If the level of runoff accumulating in the
northwest corner reached the bottom of the culvert, it would drain directly into
the creek. Acme does not have an NPDES permit for the discharge.
According to a 1973 HLA study, the surface runoff drainage is collected
in a marsh area where it either penetrates to the ground-water supply or leaves
the site through the Southern Pacific Railroad embankment. HLA recom-
mended that the runoff be diverted away from the fill areas, collected in a sump
area, and pumped within 48 hours to prevent contamination. As of the Task
Force investigation, runoff still drained to the wetland (marsh) areas. In the
May 28, 1986 letter to EPA, mentioned above, HLA explained that the runoff
evaporates from the marsh areas (the 1973 HLA report stated that runoff pene-
trated to the ground-water supply in the same marsh areas). The runoff man-
agement system consists of ditches and pipes, which ultimately discharge to
Walnut or Pacheco Creeks. The only storage capacity is the 5-acre lowland
described above, which is classified as a "seasonally ponded wetland,"
according to the 1983 Final Environmental Impact Statement for the Acme
landfill expansion.
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38
Leachate Management System
Leachate control problems have been documented at the North Parcel
since the early 1970s. The landfill was originally constructed without a leachate
management system. Leachate was observed leaking outside the hazardous
waste management area by inspectors during inspections in June, July and
December 1982, January 1983 and October 1984.
Subsurface earthen barriers with above ground dikes were constructed
on the north, east, and the west sides of the landfill in order to restrict lateral
migration of leachate. Engineering reports by HLA indicate that the dikes were
constructed with a minimum thickness of 5 feet of compacted clay and a
maximum permeability of 1 x 10*6 cm/sec. The dikes were to be keyed 2 feet
into the underlv;~g bay mud.
A series of leachate barriers were constructed on the north and east
perimeters of North Parcel between 1979 and 1981. They were constructed of
compacted fill and clay. Dikes were constructed around the remaining portions
of the North parcel, except the southern boundary under a court stipulated
agreement in 1981 and 1982. Subsequent to the construction of the dikes,
leachate levels in the landfill increased markedly. The North Parcel leachate is
currently collected in the two sumps designated as the northeast and northwest
sumps. The sumps consist of 500-gallon perforated metal underground tanks
with riser pipes to facilitate pumping. The leachate is pumped from the two
sumps, through hoses to two 10,000-gallon holding tanks at the crest of the fill.
Eleven leachate monitoring wells have been installed in the North Parcel
[Figure 6]. Representative leachate levels measured in the monitoring wells as
a part of th
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O
NORTH PARCEL
ONPGR2
LEGEND
Property Boundary
Waste Management Area
Leachate Wells
FIGURE 6
LEACHATE MONITORING WELLS IN THE NORTH PARCEL
HAZARDOUS WASTE MANAGEMENT AREA
/
1000
SCALE IN f tt T
CO
UD
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40
Table 7
LEACHATE LEVELS IN ACME VvELLS
Well
Number
NPGR1
NPGR1A
NPGR2
NPGR3A
NPGR4
NPGR5'
NPGR6
NPGR7
NPGR8
NPGR9
NPGR10
Leachate Levels
06/07/85
11.55
-
14.16
14.07
3.49
58.78
8.08
11.75
11.05
-0.04
2.73
09/1 7/85
12.03
-
13.57
15.33
6.34
55.14
8.89
11.70
11.47
0.21
3.14
(ft above MS, L}
01/13/86
13.30
-
14.13
18.63
10.06
49.45
10.27
13.49
12.77
0.85
4.12
08/22/86
-
22.20
13.57
15.41
8.02
32.30
6.71
12.22
12.66
2.20
4.93
Used as an injection well from the spring of 1985 until January 1986.
HLA reports indicate that a leachate barrier on the southern perimeter is
not needed because the leachate mound in the North Parcel is at a higher
elevation than in the IT Class I disposal pond 101 on the south, creating a
gradient toward pond 101. HLA maintains that this gradient precludes the need
for a leachate barrier on the south side of the landfill because no Class I
wastes can migrate toward the Acme property boundary. Acme does not
acknowledge that hazardous wastes may migrate toward IT, creating the need
for a southern leachate barrier.
Gas Collection- System
The North Parcel produces a mixture of gases from waste decomposition,
including methane, carbon dioxide, hydrogen and nitrogen. A gas collection
system is in place in the North Parcel which is operated and maintained by
Getty Synthetic Fuels, Inc. (GSF). The gas is extracted from recovery wells
located throughout the North Parcel, which are interconnected by a collection
pipe system terminating at a processing facility at Acme's front gate. The
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41
capacity of the system is 2 million cubic feet per second (cfs) per day. The
processing facility dehydrates the gas, which is then pumped directly to the
CCCSD sewage treatment plant where it is used as fuel.
Surface Impoundment on North Parcel
Acme operated an unengineered, unlined surface impoundment
[Figure 5], covering an area of approximately 32,000 square feet on top of the
North Parcel starting in 1981. The capacity was estimated, by HLA, to be
718,000 gallons if allowing for 2 feet of freeboard. The impoundment started as
a depression in which rainfall accumulated, and was later used to store and
evaporate/recycle leachate from the North Parcel.
Although the North Parcel leachate is defined as a hazardous waste
under 40 CFR 261.3(c)(2)(i), the surface impoundment was never added to the
RCRA Part A or Part B permit applications. No ground-water monitoring system
within the refuse/fill was installed to detect releases from this waste manage-
ment unit. No closure plan was submitted to EPA for the surface impoundment.
The impoundment was filled in with waste material and never underwent a for-
mal RCRA or CAC closure.
The leachate was collected from the northeast sump (see discussion
under landfill description) using a 4-inch portable pump and was discharged to
the surface impoundment. The frequency of pumping varied depending on the
level of leachate in the collection sump. HLA estimated that 25,000 gallons of
leachate per week (the average pumping rate was estimated at about 75
gallons per minute) were discharged into the impoundment.
On December 11, 1985 and February 20, 1986, EPA inspectors
observed a discharge of leachate from a breach in the dike around the surface
impoundment flowing down across the north face of the landfill into an
unnamed drainage ditch located along the northern property boundary. The
drainage ditch flows in an easterly direction, and is a tributary to Walnut and
Pacheco Creeks and adjacent wetlands. The existence of the surface
impoundment and injection well were not known to EPA before these inspection
dates. EPA requested additional information from Acme in a letter dated
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42
May 8, 1986, in order to determine the regulatory status of the impoundment.
HLA responded to this letter on May 28, 1986.
Pumping of leachate into the impoundment was supposed to be
discontinued in January 1986 at the request of the RWQCB. Leachate was still
added to the impoundment on an "emergency basis" until at least May 1986,
according to HLA. This "emergency basis" was stated by HLA to be whenever
the leachate wells were going to overflow due to artesian conditions.
Acme intended to evaporate the leachate by creating this surface
impoundment. Although some evaporation would have taken place during dry
weather, precipitation would have added to the liquid volume. Because the
impoundment was unlined, the leachate would have percolated back into the
landfill.
Injection Well
In the spring of 1985, Acme began using leachate observation well
NPGR5 to inject North Parcel leachate back into the North Parcel landfill. This
practice was intended to control the levels of leachate in the North Parcel by
^introducing and redistributing leachate, "utilizing the in-place refuse as a
sponge." Although all injection wells (except as related to CERCLA or RCRA
cleanup actions) which discharged into or above underground sources of
drinking water were banned by EPA in December 1984, the pumping was not
discontinued at Acme until January of 1986. This injection well was not
included on the Part A or Part B permit applications, nor was an Underground
Injection Control (DIG) permit obtained. The well was no longer in use, but not
plugged, as of the date of the Task Force investigation.
NPGR5 was originally constructed as a leachate observation well by
drilling a 24-inch borehole to the bottom of the landfill. The borehole was cased
with 4-inch diameter PVC pipe. The casing was perforated from the bottom for
20 to 30 feet, to within 5 feet of the ground surface. The annular space was
backfilled with pea gravel to within 2 to 4 feet of the ground surface. The
remaining annulus was backfilled with a bentonite-soil mixture.
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43
Leachate was pumped from the northwest collection sump to the well,
where it flowed down the well via gravity. The pumping rate was estimated to
be from 50 to 100 gpm. The frequency of pumping was reportedly 4,500 to
35,000 gpd, depending on the levels of leachate in the sump.
Acme installed two 10,000-gallon tanks for the storage of leachate from
the North Parcel hazardous waste landfill in mid-1986. The Part A and Part B
permit applications were not revised to show tank storage at the facility. The
tanks were still in use during the Task Force investigation.
The tanks were disposed of at the landfill from an unidentified source.
One of the tanks had holes rusted through it and other holes from apparent
bullet holes. It was located at the crest of the inactive portion of the North Parcel
and had no secondary containment. The other tank was located near the
northwest sump.
Acme personnel stated that the tanks are currently emptied by IT
Corporation when they become full (about once per month). The hazardous
waste leachate is then taken to the IT Vine Hill facility, via a tank truck, for
disposal. Shipment of this waste began in the spring of 1987. The leachate is
listed incorrectly as RCRA exempt on the manifest. The leachate is a listed
RCRA hazardous waste since it was generated from the disposal of hazardous
wastes [40 CFR 261.3(c)(2)(e)*j. Acme personnel submitted a delisting petition
to EPA for the hazardous waste leachate on December 10, 1986. At the time of
the Task Force inspection, EPA had not made a determination regarding the
delisting petition.
DOHS performed an inspection of Acme on October 1, 1986. Two
leachate wells, NPGR6 and NPGR8, were sampled and analyzed for hazardous
qualities. Various organics were detected, in concentrations up to 400 |ag/L,
including xylene, ethyl benzene, chlorobenzene, toluene, benzene, 1,2,4-
This citation states that any solid waste generated from the treatment, storage or disposal of
a hazardous waste, including any sludge, spill residue, ash, emission control dust or
leachate is a hazardous waste.
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44
trimethyl benzene, and chloroform. The inspection report which includes the
analytical results is included in Appendix D.
Class I Surface Impoundments (Currently Owned bv IT Corporation^
Four unlined surface impoundments, encompassing a 22-acre area,
were used in the 1960s for the disposal of Group I wastes [Figure 5]. Prior to
1960, Acme used the property for disposal of industrial and sanitary wastes.
The land was leased to IT Corporation in 1960 to use in conjunction with their
Vine Hill facility. (The Vine Hill facility was evaluated concurrently by the Task
Force. The findings are under separate cover.) There was an enhanced
potential for vertical migration of contaminants through the bay mud to the
g-ound water since the impoundments were unlined.
In 1970, IT stopped adding wastes to the four surface impoundments. In
1979, RWQCB ordered IT to build a dike around the surface impoundments.
The dikes were constructed jointly by IT and Acme. In 1980, hazardous waste
loads from Acme were temporarily stored in the area due to an RWQCB cease
and desist order against disposal of wastes in the North Parcel. The order was
issued because the earthen dikes were not complete and rainy weather set in.
In an April 23, 1983 letter, DOHS set a deadline of May 30, 1983 for the
submission of a closure plan for those portions of the surface impoundments
located within 2,000 feet of a residential area. At that time, Acme intended to
develop Waste Discharge Requirements acceptable to RWQCB so that wastes
could be added to the ponds. Acme maintained that it was unreasonable for
immediate closure to be required. During the fall of 1985, IT bought the
property from Acme, and the surface impoundments were still in service (no
new wastes, but sludge still remaining) as of the Task Force inspection.
NONINTERIM STATUS REGULATED WASTE MANAGEMENT UNITS
East Parcel Landfill
Acme was granted a Corps of Engineers permit on June 11, 1984 to
construct the Class II-2 East Parcel landfill expansion covering 97.6 acres
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45
including related perimeter levees and interior dikes. The 3-year permit
(extended in 1987 through June 1989) allowed disposal of nonhazardous solid
wastes. The landfill was still in operation as of the Task Force investigation.
In addition to the approvals of household refuse and construction debris
for disposal, the following RWQCB approvals were on file: CCCSD digested
sludge, gasoline contaminated soil, refinery evaporation pond sludge,
diatomaceous earth saturated with vegetable oil, oil contaminated pea gravel,
dried paint containers, and inert balls coated with a thin layer of dried oil.
There is no leachate collection system for the landfill. For this reason, the
permit does not allow disposal of wastes which have less than 50% solids. As
with the North Parcel, no liner was utilized other than the in-situ bay mud.
South Parcel Landfill
The northeastern portion of the 178-acre South Parcel [Figure 5]
contains a 22-acre landfill and borrow pit which started operating in 1981. The
landfill is a Class II-2 facility, used for the disposal of nonhazardous domestic
and commercial wastes. This landfill may have also received some of the
unauthorized shipments of Cordis Dow wastes (see Unauthorized Disposal
section). Disposal of wastes was discontinued in the spring of 1985.
Conflicting information was found regarding the lining under the landfill.
According to one document, a 5-foot-thick compacted clay liner was placed
along the west side of the landfill to an elevation of 20 feet above mean sea
level. However, HLA interviews during the Task Force investigation revealed
that the clay liner may have only been 2 feet thick. The liner was constructed as
the fill progressed.
Subsurface clay leachate barriers were constructed on the east, north
and most of the west of the landfill. Leachate monitoring wells designated
SPGR4-SPGR6 were installed which could later be used for collection.
The South Parcel landfill was designed to be filled to a maximum
elevation of 80 feet with nonhazardous solid wastes. As of the July 1983
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46
closure plan, 400,000 cubic yards of waste had been disposed. The closure
schedule specified that the last receipt of wastes would be in the fall of 1984,
and that the final cover would be constructed in fall of 1985. The last receipt of
wastes was in late 1984, according to HLA. The final cover was not completed
as of the date of the Task Force investigation.
FACILITY OPERATIONS
Improper facility operation can lead to the release of hazardous waste
constituents to ground water. Task Force personnel reviewed records and
facility operations for indications of problems that might lead to waste releases
and to gather information to aid in the interpretation of ground-water monitoring
data in accordance with Task Force objectives.
To either conduct an interim status assessment monitoring program or
complete a RCRA Part B permit application, the owner/operator of a TSD needs
to know the identity and location of wastes in the regulated units. This and other
information must be maintained in the facility operating record. Accordingly, the
operating record, including waste characterization procedures, waste analysis
plan, and tracking records were reviewed to evaluate how well waste
constituents have been identified for incoming waste loads, whether the
disposal locations have been properly recorded, and what disposal procedures
were followed.
Acme submitted a Part A application, dated November 19, 1980. It was
revised on March 19, 1981 and on August 2, 1983. The documents indicated
the following hazardous wastes were handled at the North Parcel:
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47
EPA Hazardous
Waste No. Description
K049 Slop oil emulsion solids from the
petroleum refining industry
D002 Solid waste that exhibits the
characteristic of corrosivity
D008 Solid waste that exhibits the
characteristic of EP Toxicity for lead
P119 & Vanadic acid, ammonium salt,
P120 vanadium pentoxide
Since 1985, waste streams must be approved by the RWQCB prior to
acceptance. After a generator submits analytical data to Acme, an approval
request letter is required to be sent to RWQCB.
Waste Characterization Procedures
Waste characterization before receipt at a TSDF and tracking after
receipt are required under both RCRA and California interim status regulations.
Both are important for determining what constituents could potentially be
released from waste management units. Effective November 19, 1980, Acme
was required, under 40 CFR Part 265.13, to obtain a detailed chemical and
physical analysis of any hazardous waste prior to storage or disposal. The
analysis must be repeated, as necessary, to ensure that it is accurate and up to
date. Each load must be inspected to ensure that the hazardous waste
received matches the manifest waste description. Acme has deviated from
these requirements on numerous occasions.
To determine whether Acme adequately characterizes wastes it receives,
the Task Force reviewed pre-acceptance records and manifests for waste loads
received during the months of March, June and December from 1980 to 1987.
The review of the files revealed that several waste streams had been accepted
with no analysis. Many manifests had analyses rubber stamped onto them, and
those analyses specified a wide range of constituents. One manifest was
lacking any waste description. RCRA hazardous wastes were accepted which
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48
were not specified on the Acme Part A application, which is a violation of
40 CFR 270.71(a)(1). Table 8 is a summary, prepared by HLA, for wastes
accepted at the facility, between 1980 and 1985. (This list is not complete, but
is as reported by HLA.)
HLA explained that the waste characterization consists of an analysis
submitted by the generator which, once accepted by Acme for disposal, is
updated annually. A jar of the waste is then kept at the guard gate for visual
comparison. Acme maintains that they are familiar with most of the waste
streams because they are accepted regularly.
The records review indicated that the paperwork was not always
complete, the waste analysis information was often several years old or non-
existent, analyses were not performed when waste was accepted and no formal
records were kept of waste disposal locations.
Waste Analysis Plan
No waste analysis plan was on file at the site at the time of an RWQCB
inspection in July 1982. A waste analysis plan dated August 1983 was utilized
at Acme during EPA Region IX inspections on December 11, 1985 and
February 20, 1986. The plan did not identify the testing parameters, test
methods or sampling methods. The RWQCB repeatedly cited waste analysis
plan deficiencies.
The current facility waste analysis plan provided to the Task Force by
HLA, was revised after the Part B submission, but is undated (submitted as an
attachment to a May 28, 1986 letter to EPA) and does not comply with RCRA as
follows:
The parameters to be analyzed are not specified in the waste
analysis plan [40 CFR 265.13(b)(1].
Test methods are not specified in the waste analysis plan [40 CFR
265.13(b)(2)J.
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49
Table 8
WASTES STREAMS DISPOSED AT ACME*
Year(s)
Manifest Description Received Waste Analysis
RCRA Wastes
Methylene chloride
Trichloroethane
Tetrahydrofuran
Acetone
Alkaline sludge
Alkaline sludge
Sand blasting waste
Catalyst fines
Alkaline sludge
Sand blasting waste
Catalyst fines
1982
1981, 1982
1981
1981, 1982
1980, 1981
1981, 1982
1981, 1982
1981, 1982
1982-1984
1982
1982
No
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Designated Wastes
Oil 1981-1982 No
Resin waste 1981-1982 No
Ammonium hydroxide 1981 No
Sodium hydroxide 1981 No
Isopropanol 1981-1982 No
Mix of isopropanol benzyl
alcohol and chloroethede (sic) 1982 No
Catalyst fines 1980-1982 Yes
ASD filter cake 1980-1982 No
Tergol filter cake 1980-1982 No
Fly ash 1980-1982 No
Oily waste 1980-1982 No
Asbestos 1980-1982 No
Laboratory refuse 1981-1983 No
Centrifuge waste 1981,1982 No
Catalyst fines 1982-1985 Yes
ASD filter cake 1982-1983,1985 No
Tergol filter cake 1982-1983 No
Fly ash 1982-1985 Yes
Coke Breeze 1983-1985 No
Oily waste 1984 No
Asbestos 1982-1985 No
Centrifuge waste 1982-1983 No
Information from HLA letter dated April 11, 1985
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50
• There is no discussion of how representative samples of wastes
will be selected [40 CFR 265.13(b)(3)].
The current waste analysis plan is not followed, in that some annual
updates of waste stream analyses are not on file. Also, shipments received by
Acme are not all checked at the gate. During the Task Force inspection, Task
Force personnel observed numerous waste loads being driven past the gate
without checking in, and proceeding directly to the North Parcel for disposal in
the hazardous waste trenches. Gate personnel did not know that hazardous
waste shipments had arrived, when questioned by Task Force personnel.
Acme does not have an adequate method of tracking wastes that arrive onsite
for disposal, since each load is not verified before disposal.
Available documentation indicated that the following RCRA hazardous
wastes were accepted between 1980 and 1985 which were not on the Part A
application:
EPA Hazardous
Waste No. Description
U080
U226
&F002
U213
U002
D010
Methylene Chloride
Trichloroethane
Tetrahydrofuran
Acetone
Catalyst fines that exhibit the
characteristic of EP Toxicity for
selenium
D001 Isopropanol
D001 Isopropanol benzl alcohol and
chloroethede [sic]
Of the wastes listed above, only the D010 waste had a waste analysis prior to
acceptance.
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51
Landfill Operations
Acme is open for business 24 hours per day. Waste from the public is
accepted between 8 a.m. and 4 p.m. A guard is posted at the entrance at all
times. During the day shift, an escort is supposed to accompany transporters of
all hazardous/designated waste shipments as they are disposed in the North
Parcel. However, Task Force personnel observed both escorted and
unescorted cfjmping at the North Parcel. After public business hours no such
escort is provided. Waste loads accepted after the escorted workshifts could be
disposed of in unauthorized areas. Manifests from wastes accepted at night are
not always signed by the guard, although he is the one responsible for any
disposal activity while on duty. In the past, State inspectors noted that manifests
from waste loads accepted after hours were not signed until the next day rather
than when the loads were received.
A State inspector once observed two loads of waste disposed on the
morning of an inspection, yet when a records review was performed for that
week only one manifest was found. When questioned, Acme representatives
stated that materials which appear to be hazardous or "hard to control" are
routinely dumped in the North Parcel, and that no records are kept of what the
materials are or where they originated. HLA also pointed out that designated
wastes are not required to be manifested, but they are for recordkeeping
purposes.
The disposal locations of individual waste loads are not recorded. The
system that Acme uses to locate individual loads by manifest is to check the
precipitation records on the dates the loads were accepted. If it was a
particularly rainy day it would be assumed that it was too muddy for any trucks
to access the dry weather or "summer" trench; therefore, the loads on that date
are assumed to have been disposed in the "winter" trench. Historically,
manifests have not always been signed as the load is accepted, so this system
does not appear to be reliable in all cases. The sample splits provided to Acme
by the Task Force were observed disposed in the winter trench during the
investigation. Because the disposal took place on a dry day, it is apparent that
the wet weather criteria is not always followed. Maps with sketches of trench
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52
locations are drawn, but not from survey data, so no horizontal or vertical
coordinates are given.
A water truck is parked at the North Parcel winter trench so that waste
trucks can be rinsed after waste loads are dumped. The water runs into the
hazardous waste trench, which is a violation of 265.314(f), which prohibits the
placement of any liquid which is not a hazardous waste in a RCRA landfill,
effective May 8, 1985.
Unauthorized Disposal
According to HLA personnel, the Cordis Dow Company arranged for
disposal of some reportedly empty drums at the Acme landfill. HLA personnel
conducted a review of the manifests and identified that the drums were later
discovered to be partially to completely full of trichloroethylene and
tetrahydrofuran. They also identified a variety of other wastes that were dis-
posed and were not authorized by the State.
A manifest review by Task Force personnel revealed that such disposal
activity took place from at least January 1979 to July 25, 1982 [Table 9]. No
waste analysis was performed for these wastes prior to acceptance. Disposal
records were not kept except for the manifests, which did show the loads to
contain the wastes listed in Table 8. No statements were written on the
manifests that would indicate empty drums; the volumes of wastes were listed.
The RWQCB inquired about the location of the Cordis Dow wastes, but
Acme stated that the drums which were disposed in 1981 and early 1982 were
crushed and covered with 10 to 30 feet of fill. Acme suggested that the drums
disposed in June and July of 1982 would be more accessible and more likely
intact.
A DOHS letter to Acme dated April 28, 1983 set forth the following:
(1)NPGR2 and NPGR3 were to be monitored quarterly for the disposed
solvents for a minimum of one year whereupon the need for further monitoring
would be evaluated, (2) groundwater monitoring wells G1 through G6 would
also be monitored quarterly for the disposed solvents, and (3) drummed wastes
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53
Table 9
WASTE ACCEPTED AT ACME FROM CORDIS DOW
Waste Identified
from Manifest
Trichloroethane 97-99.5% with
resin .5-3%
Resin waste with water
Oil
Tetrahydrofuran
Sodium hydroxide
Isopropanol
Ammonium hydroxide
Date
07/1 2/82
03/26/82
05/26/82
08/31/81
06/23/81
TOTAL
03/26/82
05/26/82
06/16/81
08/31/81
06/23/81
01/11/82
06/09/82
TOTAL
07/1 2/82
03/26/82
05/26/82
08/31/81
06/23/81
TOTAL
06/23/81
TOTAL
06/23/81
TOTAL
06/09/82
05/26/82
06/16/81
08/31/81
06/23/81
01/11/82
TOTAL
06/16/81
TOTAL
Quantity
(gallons)*
1,150
75
150
110
110
1,595
400
520
935
880
1,265
280
450
4,730
250
165
'55
165
55
690
55
55
55
55
440
55
30
80
15
330
950
8
8
No. of
Drums
21
2
3
2
2
30
8
10
17
16
23
5
9
88
5
3
1
3
1
13
1
1
1
1
8
1
1
2
1
6
19
1
1
Quantities are gallons unless otherwise stated.
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54
Table 9 (cont.)
Waste Identified
from Manifest
Acetone
Methylene chloride
Pump oil
Trichloroethane 65%
Benzl alcohol 35%
Isopropanol 33.3%
Benzl alcohol 33.3%
Chloroethane 33.3%
Skasol with water
Polyurathane [sic], polyglycol,
alfa 1059, solfolane [sic],
propanol wastes
Polyueathane [sic], polyglycol,
Acitone [sic] wastes
Pumo oil. Dolvalvcol, resin, sulfolam
Date
05/26/82
06/16/81
01/11/82
TOTAL
06/09/82
TOTAL
06/16/81
01/11/82
TOTAL
06/09/82
TOTAL
07/1 2/82
06/09/82
TOTAL
05/26/82
TOTAL
01/30/80
12/11/79
3, 08/09/79
Quantity
(gallons)*
200
110
110
420
165
165
440
275
715
850
850
300
440
740
40
40
12,285
(No units)
12,285
(No units)
528,000 Ibs.
No. of
Drums
4
2
2
8
3
3
8
5
13
16
16
6
8
14
1
1
27
27
24
hardner, skasol, polycin, glycerine,
chlor-nu, formaldehyde wastes
Vorite, polycin, hardner, sulfolane, oil,
chlor-nu wastes
Polyurthane [sic], polyglycol, sulfolane,
resin, hardner, vorite, polyglycol E600,
RN2000 wastes
09/13/79
08/15/79
5,060 Ibs.
19,340 Ibs.
23
Quantities are gallons unless otherwise stated.
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55
Table 9 (cont.)
Waste Identified
from Manifest
Polyurathane, polyglycol,
formaldyhyde [sic] wastes
Polyurathane, polyglycol, acid wastes
Polyurathane, polyglycol wastes
Polyurathane, polyglycol wastes
Polyurathane, polyglycol, ammonia,
formaldhyde [sic] wastes
Polyurathane, polyglycol wastes
Sulfolane, glycerine, polyethylene
glycol, solvents, polyurathane wastes
Sulfolane, glycerine, polyurathane,
solvent, acid wastes
Solvents, polyurathane, sulfolane,
glycerine, oil, chlorothane-nu wastes
Solvents, polyurathane,
sulfolane wastes
Sulfoalane [sic], polyurathane,
solvents, polyethylene glycol wastes
Cellulose acetate, polyurathane, acid,
solvents, sulfolane, glycerine,
polyethylene glycol wastes
Polyuranthane [sic], acid, solvents,
sulfolane, glycerine, polyethylene glycol
wastes
Date
04/01/80
05/07/80
05/1 6/80
07/07/80
08/1 3/80
10/09/80
01/04/79
01/05/79
01/15/79
04/11/79
04/1 7/79
04/25/79
05/03/79
Quantity
(gallons)*
12,285 Ibs
12,055 Ibs.
12,285 Ibs.
10,920 Ibs.
12,285 Ibs.
9,240
5,940 Ibs.
5,940 Ibs.
5,720 Ibs.
5,500 Ibs.
63,800
(No units)
No. of
Drums
27
71
27
24
27
22
27
27
24
26
26
25
29
Quantities are gallons unless otherwise stated.
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56
buried in June and July of 1982 were to be uncovered and removed if the
drums were intact and contained any liquids. Tetrahydrofuran and
trichloroethane were detected in leachate monitoring wells in the North Parcel
HLA explained that Acme later attempted to locate the drums, but only
one or two were recovered. The search was eventually abandoned by Acme.
During the Task Force investigation, HLA personnel informed Task Force
members that the drums may have been disposed of in the sanitary landfill. The
South Parcel was the sanitary landfill operating at the time, and was only
permitted to accept nonhazardous waste.
Infectious Waste
Acme is authorized to accept infectious wastes at the facility. Infectious
wastes are regulated under Title 22, Division 4, Chapter 30 of the California
Administrative Code. The Contra Costa County Health Services Department,
Environmental Health Division is authorized to enforce the regulations. Acme
receives infectious wastes which are not autoclaved. The waste is
double-bagged, placed in cardboard boxes and taped.
An Infectious Waste Operation Plan was submitted to the County in 1985.
Incoming infectious waste loads are to be signed into a logbook at the gate and
checked for proper packaging and labeling. The waste is to be disposed either
in a hazardous waste trench or 100 feet away from the public disposal area. If
the waste is placed in a hazardous waste trench it is to be immediately covered
with soil and subsequently with the 6 inches of compacted soil which is required
at the end of the day. If the wastes are placed in a nonhazardous trench they
are to be covered with additional refuse prior to compaction.
The Task Force observed the disposal of a load of infectious waste in a
hazardous waste trench in the North Parcel. The load was not immediately
covered with soil, nor was any compacted soil applied at the end of the day.
The following morning the sealed boxes of infectious waste were crushed with
heavy equipment and sprayed with water.
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57
The plan also states that steam cleaning equipment for decontamination
would be located near the hazardous waste trench. No such equipment was
present during the Task Force investigation.
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58
SITE HYDROGEOLOGY
The Acme facility has. submitted several hydro-geologic reports to State
and EPA Region IX personnel. The most recent was submitted on February 4,
1986 in a document titled "Implementation of Ground-Water Monitoring Plan
Acme Landfill; Martinez, California." The Acme consultant, HLA, reported to
Task Force personnel that this document contains the most recent and accurate
assessment of the site hydrogeology. The following information, unless
otherwise specified, was derived primarily from a DOHS report7 which
evaluates and contradicts the site characterization presented in the
aforementioned HLA report and the hydrogeologic overview presented by the
HLA hydrogeologist during the Task Force inspection.
Conflicting site characterizations, related to both structural geology and
stratigraphy, were identified during review of available documents for
preparation of the Task Force report. DOHS documents take into account
information from a variety of sources, including data from surrounding facilities.
The DOHS documents were determined by Task Force personnel to be more
appropriate to characterize the site than those presented by HLA.
The site hydrogeology, as presented by HLA on behalf of Acme, has not
been adequately characterized for the purpose of monitoring the North Parcel.
The purpose of a hydrogeologic site characterization is to identify the upper-
most aquifer, as defined in 40 CFR Part 260.10, and the direction of ground-
water flow (hydraulic gradient). Both must be characterized to enable develop-
ment of a monitoring well network which complies with the requirements of
40 CFR Part 265.91 [or equivalent in ISD Section VIM (1)] (i.e., monitoring
water quality in the uppermost aquifer, installation of at least one upgradient
well and three downgradient wells and capable of yielding samples for
analysis). The facility has not fully characterized the uppermost aquifer and has
stated that an upward vertical gradient observed at the site results in the widely
varying ground-water elevations observed in the monitoring wells. It is stated
by HLA that because of this condition "it is not possible to establish a horizontal
ground-water gradient and flow direction for the North and East Parcels, nor to
define the upgradient or downgradient wells."2 The facility has not assessed the
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59
effects of landfill loading on pore pressures within the saturated, compressable
younger bay mud and the resultant effects on water levels in monitoring wells.
HYDROLOGIC UNITS
The site is located on the alluvial plain of Pacheco Creek, [Figure 7] .
The plain is bounded by the Diablo Range to the south, east and west, and
Suisun Bay to the north. The site has two structural features, the axis of the
Diablo Anticline and the Concord Fault. The site stratigraphy (from oldest to
youngest) consists of bedrock, older alluvium, older bay mud, regressive sands,
younger bay mud and fill. The following discussions further describe the
structural geology and stratigraphy at the site, and inconsistencies with HLA
interpretations.
Structural Geology
The structural geology in the vicinity of the North Parcel has potential
effects on the degree of fracturing in bedrock formations and associated
influence on both the rate and direction of ground-water movement at the site.
The Diablo Anticline has been mapped (projected) beneath the eastern
boundary of the Acme North Parcel by Dibblee.5 It is reflected in the orientation
of the sandstone and shale beds of the bedrock (Panoche Formation) exposed
near the site. The dip of the bedrock exposed west of the North Parcel is to the
west. The bedrock exposed at the Avon (TOSCO) refinery, across Pacheco
Creek and to the east of Acme, is dipping to the east. Bedrock beneath most of
the North Parcel at Acme would be expected to be southwest dipping, while
bedrock beneath and east of the eastern edge of the North Parcel is expected to
be northeast dipping.
Two subparallel segments of the Concord Fault have been mapped4 as
being within the vicinity of, but not transecting, the North Parcel. The fault is a
north-south trending fault zone which essentially trends subparallel to Pacheco
Creek. The California Division of Mines and Geology has designated the
Concord Fault as active and capable of generating large earthquakes of up to a
magnitude of seven on the open-ended Richter scale. In 1973, two smaller,
-------
'v' iy^Tr^sj^P^?;^ V'^^'1"' * * i \? ' w / •''': ^.
4^jQi!^rtM^ • i .;' £ ' • tV
t»|0u»lf>»nf) i)
• 'S 0 S n »inunu s i .»oir>og d»vi
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61
unnamed faults were mapped, traversing the site by Simms et al.5 These faults
displayed a southwest-northeast trend and occur at the northern and southern
ends of the hill defining the western boundary of the North Parcel. These faults
were not shown in the later Dibblee work and whether these two faults are
present, active or capable of response to an event on the Concord Fault is not
known.
HLA reports that the "approximate traces of the Mount Diablo Anticline
and the Concord Faults have been inferred by Dibblee (1981), but no fault
traces have been observed in the immediate vicinity of the landfill."6 Further
characterization of the effects of both structural features must be made by the
facility to determine the degree of interconnection between stratigraphic units
(discussed at length in the following sections), and effects on ground-water flow.
Stratigraohic Units
The facility has not fully characterized the lithology of the stratigraphic
units, their respective water-bearing capabilities or the degree of interconnec-
tion. The following discussion describes available information and contradic-
tions between State and facility accounts of the site geology.
Bedrock underlying the facility is predominantly sandstone and shale of
the Panoche Formation of Upper Cretaceous Age. Bedrock is exposed at the
surface on the western edge of the site and estimated to be at a depth of about
110 feet beneath the eastern limits of the North Parcel and up to 5 to 600 feet at
the eastern extent of the East Parcel. Where exposed, the bedrock strikes to the
northwest and dips 50 to 70 degrees to the southwest.7 Facility reports
characterized the bedrock as "composed of well indurated (cemented) clean to
silty sand," and of questionable interpretation, include "peat" deposits as part of
the bedrock in geologic cross-sections (Plate 6 - February 1986 report).
Hydraulic properties of the bedrock are not known; however, the
proximity of the site to the Diablo Anticline and Concord Fault, as discussed
above, indicate the possibility that bedrock could be highly fractured,
possessing high secondary hydraulic conductivity. The facility characterizes the
bedrock to be "containing ground-water of poor quality and low yield and is
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62
considered a nonwater-bearing unit."8 The facility does not provide any
documentation of water quality to support this statement.
Overlying the bedrock is a thick alluvial sequence of predominantly
coarse-grained materials referred to as older alluvium. Interbedded within the
coarse-grained deposits are discontinuous lenses of silt and clay. These
materials were deposited during periods of the Pleistocene Age when sea level
was lower and the Diablo range was being uplifted.
According to the facility reports the older alluvium was not encountered in
the immediate area of the landfill.9 Few borings were drilled and sampled to an
appropriate depth. State personnel interpret the sequence of sands and
gravels encountered in Acme borings, G29 and G30, to be the older alluvium.
These borings and those from the International Technology (IT) facility (to the
south), according to State personnel, indicate that the older alluvium thickens to
the east, and is approximately 35 feet thick beneath the North Parcel.
The older bay mud overlies the older alluvium and consists of generally
continuous deposits of semi-consolidated organic clays and silty clays, and
discontinuous deposits of gravelly and sandy clays, silts, sandy silts, silty sands
and peat in various stages of decomposition. The depth to older bay mud is
variable throughout the site due to topographic relief and is estimated to be
between 35 and 50 feet.
Overlying the older bay mud is a series of discontinuous but often
interconnected, regressive sands, which were deposited during a period of
declining sea level. When encountered, these deposits were found at depths of
approximately 25 feet, near the bottom of the younger bay mud. The younger
bay mud, above the regressive sands, consists of mostly clays, silty clays, silts,
peat and discontinuous bodies of silty sand. Within the younger bay mud are
discontinuous deposits of coarser mining detritus, from gold mining during the
mid 1800's, primarily of silt and silty sand.
The facility does not distinguish between the older alluvium, older bay
mud, regressive sands, and younger bay muds, and groups all of the deposits
overlying bedrock into a formation called the bay mud. The facility
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63
characterizes the bay mud as a low permeability soft clay with silt, ranging in
thickness from 0 to greater than 70 feet across the facility and capable of only
low water yields.
Acme has not identified the differences between the aforementioned
formations; this is probably the primary cause of their difficulty identifying
ground-water flow directions. Monitoring wells have been completed through
multiple water-bearing formations, (although all characterized by Acme as the
"bay mud") each with varying composition, grain-size, porosity and permeability.
These formations have different abilities to transmit water, and other properties
which affect water level measurements across the site.
Although trash/fill is not a geologic material, it impacts significantly on the
hydrogeology of the site. The trash is a random arrangement of solid material
with no layers to create perched or artificially high levels of leachate. A daily
cover of soil is supposed to be placed over the trash at the end of the day,
creating individual trash cells, however, the facility has been frequently cited by
State officials for noncompliance with cover requirements. In addition, one of
the methods used to dispose of hazardous wastes in the North Parcel is to
trench into existing trash, therefore interconnecting any trash "cells" that had
been created. The leachate wells are also perforated from the top of the trash to
the top of the younger bay mud, and interconnect the entire height of fill.
Since "cells" cannot be considered to provide any impediment to
leachate migration, the excess hydraulic head represented by the height of
leachate in the landfill creates a leachate mound and causes a driving force for
the migration of leachate radially through the fill and into underlying intercon-
nected geologic materials. While the surface impoundment and injection well
were in operation on top of the fill, large volumes of leachate were pumped
either into or on top of the landfill. The repumping of leachate back into the
landfill and the influence of the topography creates a leachate mound which is
still evident by the level of leachate in the "NPGR" series of monitoring wells
[Figures 8 and 9]. (These plots are computer generated, using limited points, as
indicated.) The leachate collection/dike system also contributes to the leachate
mound.
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\
\
\
*
/
\
\
\
\
o
LEGEND
Property Boundary <
Monitoring Well*
Water Level Contour
measured In feet
above MSL
EAST PARCEL
100
1000
SCALl IN MM
FIGURE 8
LEACHATE LEVELS JUNE 7,1985
measured In feet a h n u a M R i
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\
\
\
\
*
I
\
\
\
LEGEND
Property Boundary .
Monitoring Well*
Water Level Contour
measured In feet
above MSL
EAST PARCEL
too
1000
SCAlf INFff f
FIGURE 9
LEACHATE LEVELS JANUARY 13, 1986
measured in feet above MSL
en
en
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66
The facility has designated the "bay mud" to be the uppermost aquifer for
the RCRA/ISD monitoring program. As previously described, they have not
adequately characterized this bay mud layer to include the multiple formations.
Once the formations are characterized, either by continuously logged borings,
nested piezometers, pump tests, etc., additional evaluation will be necessary to
determine the degree of interconnection between the fill, "bay mud"(and
constituents) and bedrock, to adequately define the uppermost aquifer.
GROUND-WATER FLOW DIRECTIONS AND RATES
The facility has not determined ground-water flow directions or rates for
the North Parcel. As previously quoted, the facility cites an upward vertical
gradient at the site, resulting in varying ground-water elevations and has
reported a finding that it is not possible to establish horizontal ground-water
gradient or flow directions for the North or East Parcels.
Analysis by Task Force personnel of the water levels in wells completed
primarily in the peat zone (older bay mud) yielded pieziometric contours
displayed in Figure 10. This strongly suggests a radial ground-water flow from
the landfill but trending north-northwest toward Suisun Bay. An evaluation of
wells completed primarily in the silty clay (younger bay bud) also demonstrated
radial flow directions [Figure 11]. (These plots were computer generated, using
limited points, as indicated.)
The facility must further characterize individual flow zones as described
in the previous section, and determine the degree of interconnection, hydraulic
gradients, flow directions and flow rates. Few of the existing monitoring wells
are completed in just one formation, as defined by the State, and several
shallow wells (35-foot average depth) have well screens of up to 20 feet in
length. Both of these factors make analysis of water levels, for determination of
hydraulic gradients, difficult. Depth staggered and/or clustered wells, with short
screened intervals may be necessary to define hydraulic gradients and the
degree of interconnection within the uppermost aquifer.
Water levels and constituent concentrations for wells bordering the
Acme/IT Vine Hill property boundary were compared to determine if any
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67
conclusions could be drawn regarding ground-water flow directions and/or the
degree of contaminant migration. The majority of water levels cannot be
compared because the wells are not completed in similar formations. The
remaining data is inconclusive. Additional data is necessary to evaluate the
degree of hydraulic connection.
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. . . MW 109
\
\
\
o
»• .
LEGEND
Property Boundary
Monitoring W«IU
V al«r L«v«l Contour
measured ID feet
above MSL
too
1000
\
\
\
NORTH PARCEL
EAST PARCEL
\
\
FIGURE 10
ICAlt IHMIT
GENERALIZED PIEZOMETRIC CONTOUR OF WATER LEVELS
FROM THE WELLS COMPLETED IN PEAT (JUNE 1987)
en
CO
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/
A.
O
M.w_!07j MW juo.,
NORTH PARCEL
LEGEND
Property Boundary
Monitoring W«1U
Water L«v«l Contour
n«aour«d In f««t
above MSL
FIGURE 11
100
1800
KME IN rill
GENERALIZED PIEZOMETRIC CONTOUR OF WATER LEVELS
FROM THE WELLS COMPLETED IN SILTY C! AY (JUNE 1987)
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GROUND-WATER MONITORING PROGRAM UNDER INTERIM STATUS
FEDERAL AND STATE REGULATORY HISTORY
Both Federal and State regulations are applicable to hazardous waste
management at Acme Fill Corporation. There are two State agencies which
regulate hazardous waste activities in California: The Department of Health
Services (DOHS) and the State Water Resources Control Board (SWRCB).
DOHS was delegated authority to administer a RCRA equivalent State
hazardous waste program.* The SWRCB has never applied for authorization to
implement RCRA but has been granted numerous authorities (e.g., waiver
approval, monitoring analyses review, assessment outline approval, etc.) by
DOHS relating to the implementation of this program. In addition to these
authorities, the SWRCB implements an independent State hazardous/non-
hazardous waste program (CAC Title 23, Chapters, Subchapter 15,
Article 5). The Regional Water Quality Control Board (RWQCB) subcontracts
through SWRCB to assist DOHS (through grant monies) with implementing the
State equivalent RCRA program through inspections and permit applications
review.
Acme began handling waste at their facility in 1949. The regulatory his-
tory of the site began in May 1975 when Acme submitted an application to the
RWQCB to operate a sanitary/hazardous waste landfill. The RWQCB adopted
Waste Discharge Requirements (Order No. 76-37) for the Acme landfill on April
20, 1976. These requirements described waste discharge prohibitions, waste
disposal specifications, and provisions designed to protect the waters of the
State (including ground water). The requirements also involved implementing a
self-monitoring program in order to obtain data and document compliance with
the waste discharge requirement permit. A chronology illustrating the regula-
tory history of Acme is shown in Table 10.
On June 4, 1981, EPA delegated the authority to administer portions of
the Federal RCRA program for existing facilities (interim authorization) to the
California Hazardous Waste Management Regulations: California Administrative Code
(CAC), Title 22; Revised and Recodified May 10, 1979, most recently updated on July 29,
1985
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Table 10
CHRONOLOGY OF REGULATORY HISTORY OF ACME LANDFILL
May 1975
April 20, 1976
February 6, 1978
March 19, 1981
October 23, 1981
November 1.7, 1982
March 4, 1983
August 2, 1983
May 6, 1985
May 28, 1985
August 28, 1985
February 4, 1986
Acme submitted an application to RWQCB to operate a
sanitary/hazardous waste landfill.
Waste Discharge Requirements (Order No. 76-37) were
adopted by Acme.
Updated Waste Discharge Requirements (Order No. 84-
18) were submitted by Acme, which resulted in a
reduction in monitoring parameters for monitoring wells
under self-monitoring program.
Acme submitted RCRA Part A Application.
DOHS issued an Interim Status Document (ISD) permit
to Acme.
Acme requested an ISD ground-water monitoring
program wavier.
The ISD ground-water monitoring program requirements
were waived by RWQCB.
Acme submitted a RCRA Part B Application to EPA.
Acme was ordered by the RWQCB to prepare and
implement an ISD ground-water monitoring program.
Acme submitted a proposal for a ground-water monitor-
ing program.
Acme revised their ground-water monitoring program.
Acme revised the sampling and analysis plan of the
ground-water monitoring program.
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State (DOHS). The California regulations (California Administrative Code -
Title 22) were codified and patterned after the RCRA Part 265 regulations. The
State regulations were not equivalent to the RCRA regulations, though. The
State regulations do not require monitoring the ground-water, except via
RWQCB issued Waste Discharge Requirements. The State program requires
monitoring of the air and of the soil-pore liquid of the naturally unsaturated
zone, instead of the ground water. A Statute was passed by the State [Health
and Safety Code, Division 20, Article 5.5, Section 25159.5 (b)] in 1982 and was
amended several times. The final revision was made in 1987, currently
reading:
"Until the state program is granted final authorization by the
Environmental Protection Agency pursuant to Section 6926 of
Title 42 of the United States Code, all regulations adopted
pursuant to the Resource Conservation and Recovery Act of 1976,
as amended, (42 U.S.C. Sec. 6901 et seq.) shall be deemed to
be the regulations of the department, except that any state statute
or regulation which is more stringent or more extensive than a
federal regulation shall supersede the federal regulation."
The statute places those more stringent RCRA ground-water monitoring
requirements on the State's hazardous waste facilities. In order to duplicate the
RCRA requirements for interim status facilities, the State issued Interim Status
Document (ISD) permits which are equivalent to the RCRA interim status
ground-water monitoring requirements. The DOHS issued an ISD to Acme for
the North Parcel landfill on October 23, 1981. Section VIII of the ISD details the
ground-water monitoring requirements applicable to Acme. These require-
ments are equivalent to the Federal RCRA interim status requirements in 40
CFR Parts 265.90 through 94.
The ISD program required Acme to prepare and implement a ground-
water monitoring program by November 19, 1981. Acme did not implement the
required ground-water monitoring program (i.e., upgradient/downgradient
monitoring wells, sampling and analysis plan, ground-water quality assessment
outline or program plan) by November 19, 1981. On June 15 and July 28, 1982
inspections of the facility, by DOHS personnel, confirmed noncompliance with
the ground-water monitoring provisions of the ISD.
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The ISD program allows the ground-water monitoring program to be
waived if the facility can demonstrate, in writing to the RWQCB, that there is a
low potential for contaminant migration. Acme requested such a waiver on
November 17, 1982 (1 year after the program was required to be implemented)
and was granted the waiver by the RWQCB on March 4, 1983. This waiver was
approved on the grounds that the existing self-monitoring program (for ground
water) under the RWQCB Waste Discharge Requirements was more appropri-
ate than the ISD requirements. However, the existing self-monitoring program
did not require numerous provisions of the ISD program. Acme was ordered by
RWQCB to continue the self-monitoring program specified by the Waste Dis-
charge Requirements, in lieu of the ISD requirements.
Guidance to the DOHS from EPA indicated that the waiver granted to
Acme, by the RWQCB, was inappropriate. In a letter to Acme dated May 6,
1985, the RWQCB rescinded the waiver. Acme was ordered to prepare an
expanded ground-water monitoring program in line with the ISD requirements
and 40 CFR Parts 265.90-94. The first ground-water monitoring program plan
was prepared by Acme and submitted to the RWQCB on May 28, 1985. The
plan was revised on August 28, 1985. Quarterly interim status detection
monitoring under this plan started in October of 1985. The monitoring program
consists of approximately 60 monitoring wells. The 60 wells were drilled to
comply with RCRA and non-RCRA State monitoring programs. The RCRA well
network consists of 26 wells surrounding the North Parcel landfill. These wells
are sampled quarterly for RCRA interim status parameters.
Acme submitted a RCRA Part B Application to EPA for the North Parcel
landfill on August 2, 1983. A final permit had not been granted at the time of the
Task Force inspection. The application was submitted to EPA because DOHS
had not been granted authorization to issue RCRA permits.
The following is an evaluation of the interim status monitoring program
between November 1981, when the ground-water monitoring provisions of the
RCRA regulations (and State equivalent) became effective, and June 1987,
when the Task Force investigation was conducted and addresses:
Regulatory requirements
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74
• Ground-water monitoring program - November 1981 to May 1985
(Self-monitoring program)
Ground-water monitoring program - May 1985 to June 1987
(ISD/RCRA program)
Acme sample collection and handling procedures
Ground-Water Quality Assessment Outline and Program
REGULATORY REQUIREMENTS
The State was granted portions of two phases of RCRA authorization as
indicated below:
June 4, 1981 - DOHS received Interim Authorization for Phase I,
which included 40 CFR Parts 260, 261, 262, 263 and 265. This
granted the State authority to regulate hazardous waste facilities
for waste treatment, storage and disposal during interim status.
January 11, 1983 - DOHS received Interim Authorization for
Phase II, Component A, which granted the authority to write RCRA
permits for treatment and storage of hazardous wastes in tanks,
containers, waste piles and surface impoundments.
February 7, 1985 - DOHS was granted an extension of Interim
Authorization.
On January 31, 1986, the responsibility for the RCRA interim status
hazardous waste program reverted back to EPA Region IX because the State
failed to achieve Final Authorization by that date, as required by RCRA Section
3006(c)(1). Since February 1, 1986, EPA has implemented the RCRA program
for the State of California, including the 1984 Hazardous and Solid Waste
Amendments (HSWA). EPA also implemented the RCRA program before the
State was granted interim authorization, November 19, 1980 through June 3,
1981. The DOHS is continuing to pursue Final RCRA Authorization.
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Hazardous waste management at Acme has been regulated by the State
(DOHS and RWQCB) since May 1975. The State equivalent of the RCRA
program was implemented from June 4, 1981 until January 31, 1986. The
California requirements for interim status ground-water monitoring program are
contained in the California Administrative Code, Title 22, Sections 67191-
67195. These requirements are similar to the RCRA Part 265 Subpart F interim
status requirements but additionally require monitoring of the air and the soil-
pore liquid in the normally unsaturated zone. The regulation counterparts are
shown below in Table 11.
Table 11
STATE AND FEDERAL COUNTERPARTS FOR INTERIM STATUS
GROUND-WATER MONITORING REGULATIONS
California State Regulation RCRA Regulation
Section Title* CAC, Title 22, Article 22 40 CFR Part
Applicability
Ground-Water Monitoring
Sampling and Analyses
Preparation, Evaluation
and Response
Recordkeeping and Reporting
67191
67192
67193
67194
67195
265.90
265.91
265.92
265.93
265.94
Subpart titles are given for RCRA regulations; the State Subparts have similar titles.
Acme is required to comply with both State and Federal hazardous waste
management requirements. This includes the State requirements under
Title 22 (e.g., monitoring of the air and soil-pore liquid of the normally
unsaturated zone), as well as the ground-water monitoring provisions of the ISD
(November 1981 through January 1986) and RCRA (November 1980 to June
1981 and February 1986 to present). Acme has not complied with these
requirements.
The facility has not monitored the air or the soil-pore liquid of the
normally unsaturated zone, as required by Title 22. These two media are to be
monitored for all the hazardous waste constituents disposed at the facility, as
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76
well as indicator parameters [e.g., specific conductance, total organic
compounds (TOC), total organic halides (TOX)j. (See Appendix E for a
detailed comparison of State and Federal monitoring requirements.)
GROUND-WATER MONITORING PROGRAM - NOVEMBER 1981 THROUGH
MAY 1985
Acme did not comply with the ground-water monitoring requirements
specified in the Interim Status Document (issued by DOHS) by November 19,
1981, as required. Acme was in noncompliance with the ISO until
November 17, 1982, when a ground-water monitoring waiver was requested
from RWQCB.
The review and approval of Acme's waiver request was in accordance
with the unofficially delegated authority to RWQCB, under the ISO (although
delegation to RWQCB was not included in the DOHS program approved by
EPA). Therefore, the self-monitoring program has been evaluated by the Task
Force, as a substitute ground-water monitoring program, for the period from
November of 1982 until May of 1985. However, the waiver should not have
been granted since the waiver provision of the ISO [Section Vlll(5)] does not
allow for substitution of alternate monitoring plans; it permits waiver approval,
only if low potential for migration can be proved. The waiver approval by
RWQCB was not in accordance with State (DOHS) and Federal monitoring
requirements.
The self-monitoring program of the Waste Discharge Requirements
issued by RWQCB as Order Number 76-37, on April 20, 1976, required
development of both a sampling program and a monitoring well network. The
subsequent revisions to the Waste Discharge Requirements (including 1981
revision) self-monitoring program did not require numerous provisions of a
RCRA or ISD ground-water monitoring program, including: (1) development of
a monitoring well system including upgradient and downgradient wells,
(2) establishing background data or statistical analysis of monitoring well data
to determine if a significant increase (or decrease for pH) in analytical
parameters had occurred .or (3) preparation of a ground-water quality
assessment outline or program. The program did include monitoring for
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77
parameters deemed by RWQCB to be representative of leachate. Acme's
compliance with the ground-water monitoring portions of the self-monitoring
program, including sampling program and monitoring well location, number and
construction, follows.
Sampling Program
The ground-water monitoring provisions of the self-monitoring program
were originally issued to Acme on April 20, 1976 (Order 76-37) and revised on
February 6, 1978 (Order 84-18). The programs included analytical parameters
and sampling frequency. The original and revised programs specified the
location and approximate depths of ground-water monitoring wells and the
locations of other leachate monitoring points. The original program included
quarterly sampling for 18 inorganic and organic parameters and yearly analysis
for pesticides and chlorinated hydrocarbons. The revised program eliminated
quarterly sampling for all but 10 of the previously required parameters and
specified quarterly analysis for color, chloride, chemical oxygen demand (COD),
total dissolved solids (TDS), nitrate nitrogen (as N), total kjeldahl nitrogen (as
N), conductivity, pH and water level. The parameters were not expanded after
the state RCRA equivalent program became effective or the RWQCB review of
the Acme waiver request, yet the existing self-monitoring program was deemed
to include "more appropriate" parameters for a landfill monitoring program by
RQWCB.
There are inconsistencies in both the substance and implementation of
the self-monitoring program. The program requires the facility to submit an
annual report summarizing "the compliance record and corrective actions taken
or planned which may be needed to bring the discharger into full compliance
with Waste Discharge Requirements";10 however, there are no discharge
requirements or quality standards identified for ground water. The annual
report was also required to summarize ground-water analyses and indicate any
change in the quality of ground water. As mentioned previously, the monitoring
system did not require upgradient or downgradient monitoring wells, and the
facility was never required to determine "background" water quality, to enable a
determination of changes in ground-water quality.
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The annual reports submitted by HLA personnel on behalf of Acme for
monitoring between 1981 and 1985 noted fluctuations in numerous analytical
parameters; however, HLA repeatedly reported in the transmittal letter that
"except for well K1, the-parameters have not changed significantly over the past
year."rr The reports do not define how the "significance" of the fluctuations was
determined, nor does the self-monitoring program require any statistical
analysis of quarterly data to quantify any changes in the quality of ground water.
Chlorinated hydrocarbons and volatile organics were analyzed and
detected in leachate samples in November 1982 and in two wells (G5 and G6)
in June 1983, yet the results were not discussed in the annual report summary
nor were corrective actions discussed. These parameters were not analyzed as
part of the self-monitoring program (yet reported in tables) and were reported,
by HLA, to have been analyzed voluntarily.
Tetrahydrofuran and trichloroethane were detected in both leachate and
ground-water monitoring wells during June, September and December
monitoring in 1983, yet the facility reported that analytical parameters had "not
changed significantly."*2 The volatile organics detected are the same as those
contained in the unauthorized waste loads (Cordis Dow wastes) accepted by
the facility, and should have been acknowledged in the summary of the annual
report. The need for corrective action plans, in compliance with the self-
monitoring requirements should also have been included in the 1984 annual
report. Acme did not perform volatile analysis beyond 1983, after constituents
were detected.
The self-monitoring program also required a variety of records to be
maintained at the facility for each sample collected, including: (1) complete
sampling procedures, (2) method of sample preservation and identification of
reagents used, (3) calculation of results and (4) results of analysis. Acme did
not comply with any of these recordkeeping requirements. The 1983
ground-water monitoring program submitted as part of the RCRA Part B permit
application stated that the facility did not have a document containing sampling
procedures and preservation methods, both of which were required by the self-
monitoring program in 1976.
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Monitoring Well Location. Number and Construction
The self-monitoring program specified the location [Figure 12], number
and approximate depth (to the first available ground water) of each Acme
monitoring well [Table 12]. The program also specified construction standards.
The monitoring system included six ground-water monitoring wells, numbered
G1, K1 (replacement for designated G2), G3, G4, G5 and G6, and an
unspecified number of leachate observation wells. Acme complied with the
required location and number of monitoring wells, but did not fully comply with
specified construction standards.
The self-monitoring program specified that Acme must follow the well
construction standards of the Contra Costa County Health Department
(CCCHD). The CCCHD construction requirements specify that wells be con-
structed in accordance with standards specified in the California Department of
Water Resources Bulletin Number 74 (Bulletin 74).
The CCCHD construction requirements and the self-monitoring program
specify that a permit is required for construction or abandonment of each well
[CCCHD Article 414-4.801 (a)] and upon completion of each well, a log must be
submitted to the county health officer [Article 414-401 (d)]. This apparently was
not complied with since there were no logs available from Acme for the
abandonment of original wells G4 (replaced by well G4A in the second quarter
of 1983) and G6 (replaced by well G6A in the second quarter of 1982 and
renamed to G6), nor were there logs, or construction information for wells K1,
G1,G3,G4A,G4orG5.W
Task Force personnel attempted to locate original well G6 which was
reported, by HLA, to be within 6 feet of the present well location; however, no
evidence was found of the casing or the cement cap required for abandonment
by CCCHD [Article 414-409] and Bulletin 74 [Part III Section 23 E].
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NORTH PARCEL
EAST PARCEL
4
/
LEGEND
Property Boundary
Waste Management Area
Monitoring well*
FIGURE 12
SELF-MONITORING PROGRAM
MONITORING WELL NETWORK FOR THE NORTH PARCEL
500
1 —
1000
SCAIE IN FEET
co
o
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81
Table 12
DESIGNATED LOCATIONS/DEPTHS OF SELF-MONITORING
PROGRAM WELLS' AS DESCRIBED IN THE ACME WASTE
DISCHARGE REQUIREMENTS
(Orders No. 76-37 and 84-18)
Station Description
Gt A well located within 50 feet of the northwesterly corner of the
area I and III, as shown on Attachment "D". The depth shall be to
the first available ground water."
G2 A well located 1,000 feet easterly of well G1, as shown on Attach-
ment "D". The depth shall be to the first available ground water.
G3 A well located 50 feet westerly of the sewer outfall, as shown on
Attachment MDH. The depth shall be to the first available ground
water."
G4 A well located between well No. G18 of International Technology
(IT) and well G3, as shown on Attachment "D". The depth shall be
to the first available ground water."
G5 A well located within 50 feet of the southeasterly corner of area I.
(Same as IT well no. G18).
G6 A well located at southwesterly corner of the site (same as IT well
number G23).
Well locations illustrated on Figure 12.
Required to penetrate and fully perforate the uppermost permeable coarse gram layer such
as sand and/or gravel.
Bulletin 74 also requires wells to be cased so that ihe top of casing is
above any known conditions of flooding by drainage or runoff from surrounding
land. During several quarters of monitoring, wells G1, K1 and G3 were
submerged and quarterly samples were not taken. Uncapped or poorly sealed
wells can be contaminated by surface runoff. Well construction data are not
available for these wells to verify surface grouting, therefore well integrity is
unknown.
None of the self-monitoring wells had construction records available.
These records should include information related to volume of grout or
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82
bentonite used in seals, bit size used in drilling, volume of sand in the sand/
gravel pack, or sieve analysis of surrounding formation materials for
determination of the sand pack and screen slot size, etc.; therefore, compliance
with construction standards cannot be further evaluated.
The only boring log available is for well G6A (renamed G6). It appears
that this well is screened in more than one formation [both silty sandstone
(15 feet), and sandy silty shale (10 feet)], contrary to the requirements of the
self-monitoring program. The hole diameter is also not noted on the log. A total
well diameter of 4 inches greater than the production casing is required
[Bulletin 74 Part II Section 9(B)]. Proper hole diameter is necessary to insure
uniform placement of both the sand/gravel pack and surface grout seals, both of
which are essential for quality water samples.
GROUND-WATER MONITORING PROGRAM - MAY 1985 THROUGH JUNE
1987
On May 6,'1985, the RWQCB rescinded the Acme waiver approval.
Following receipt of guidance from EPA, the RWQCB decided the waiver issued
to Acme was inappropriate under RCRA requirements, and required the facility
to develop an expanded ground-water monitoring program, in accordance with
the previously issued ISO requirements. The facility drilled new monitoring
wells in the summer of 1985 and started sampling for interim status parameters
in October 1985. The facility reported to Task Force personnel that, although all
of the wells surrounding the North Parcel were completed and sampled in 1985,
all of the facility wells were not completed; therefore, the first quarter of interim
status detection monitoring was the first quarter of 1986. At the time of the Task
Force inspection the facility had completed six quarters of monitoring (March,
May, August and November of 1986 and February and May of 1987) and had
reported analytical results for all but the most recent quarter.
Facility compliance with the ground-water monitoring requirements of
RCRA and the equivalent requirements in the ISO, including the sampling and
analysis plan and monitoring well location, number and construction, are
discussed in the following sections.
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Sampling and Analysis Plan
Acme submitted the first sampling and analysis plan in May 1985 and a
revised plan in August 1985. The procedures in the August plan were used for
sample collection in October and December of 1985. The sampling procedures
outlined in the August plan did not include sufficient detail regarding the
general procedures and techniques for sample collection, sample preservation
and shipment or analytical procedures, as required in ISO Section VIII (2)(a-c),
and equivalent requirements in 40 CFR Part 265.92. The forms presented for
chain-of-custody were adequate.
The sampling procedures did not discuss whether dedicated pumps
and/or bailers would be used to purge and sample each well. If a single
pump/bailer is used, decontamination procedures need to be described.
Improper decontamination procedures for reusable sampling and monitoring
equipment can lead to cross-contamination of wells. Contamination of a well,
caused by improperly cleaned equipment, will generate misleading data.
The procedures did not require measurement of the total well depth in
conjunction with the measurement of the static water level. Both measurements
are necessary for determination of the total well volume and associated purge
volumes. The precision of measurements was also not specified. Accurate
water level measurements are necessary to adequately characterize the
ground-water gradient. Measurements taken by Acme were usually recorded to
the nearest one-half foot which is not adequate, particularly, for facilities with
relatively flat water tables. EPA guidance14 recommends water level mea-
surement with a precision of 0.01 foot.
The monitoring plan does not describe methods for determining purge
volumes nor does it include procedures to collect and dispose of purge and
excess sample water. If this water is not properly handled, contaminants can be
introduced into the well(s) and affect sample results.
The sample preservation procedures are referenced rather than listed.
This is inadequate because the referenced sources contain multiple methods
and preservation procedures. The plan does not mention cooling samples until
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84
shipment, nor does it require pH verification in the field for preserved aliquots.
Most analytical methods require samples to be cooled to 4 °C, in addition to any
chemical preservatives.
The analytical methods are neither referenced nor listed. All analytical
methods must be specified to ensure replication of analysis and comparability
of results from one quarter to the next. Different methods can result in different
analytical results.
The plan does not describe a quality assurance/quality control (QA/QC)
program. The failure to require standard operating procedures to ensure
accurate calibration curves, fresh reagents, equipment calibration procedures,
equipment cleaning procedures, etc., can result in erroneous and/or
unreproducible data.
The drinking water parameters are referenced rather than listed in the
plan. All parameters collected must be listed and their sampling frequency
included, to ensure that parameters are all collected at the proper frequency,
since sampling requirements change after the first year of interim status
monitoring.
On February 4, 1986, Acme submitted a report prepared by HLA titled,
"Implementation of Ground-Water Monitoring Plan; Acme Landfill, Martinez,
California." This report is identified by HLA personnel as an update of the
sampling and analysis plan submitted in August 1985, and is the plan followed
at the time of the Task Force inspection.
The sampling and analysis portion of this report is a significant
improvement over the August 1985 plan; however, it is still incomplete. The
plan does not include the method used to determine purge volumes. It does
not include decontamination of the tape used for water level measurements.
Sampling procedures still do not include methods for collection or disposition of
purge water, nor does it include procedures for calibration and decontamination
of field meters (pH meter, conductivity meter and thermometer).
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85
A table is included with the sample preservation procedures; however,
no mention is made of field preservation or verification of pH for acidified
samples. The sample preservation table indicates that several of the metals
(lead, mercury, selenium and silver) are to be filtered and reported as dissolved
concentrations while all other metals are to be reported as total concentrations.
The plan does not explain the purpose of filtering selected metals. The
methods (in the table) used for preservation of the fluoride, pesticide, herbicide
and TOX aliquots are inconsistent with EPA methods. Equipment for filtering
and decontamination of the same is not addressed in the plan.
In addition, the list of analytical parameters is incomplete because it does
not include turbidity, as required by the ISD. The plan also does not specify the
frequency of sample collection except for the water level measurements, taken
on a quarterly basis. A sampling schedule is necessary because monitoring
frequencies and parameter requirements change after the first year.
The February 1986 monitoring plan did not contain a ground-water
quality assessment program outline. The plan did not include requirements for
quadruplicate measurements of indicator parameters or statistical evaluation of
data as required in the August plan [and both the ISD Section Vlll(3) and 40
CFR Part 265.93(a)].
Monitoring Well Location. Number and Construction
The ISD [Section VIII (1)] and RCRA (40 CFR Part 265.91) requirements
are identical regarding the location and number of monitoring wells, and
require:
Monitoring wells (at least one) installed hydraulically upgradient
(i.e., in the direction of increasing static head) from the limit of the
waste management area. Their number, locations and depths must
be sufficient to yield ground-water samples that are:
Representative of background ground-water quality in the
uppermost aquifer near the facility
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86
Not affected by the facility
Monitoring wells (at least three) installed hydraulically down-
gradient (i.e., in the direction of decreasing static head) at the limit of
the waste management area. Their number, locations and depths
must ensure that they 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 facility has not fully complied with these regulatory requirements.
The current monitoring well system around the North Parcel consists of
26 wells [Figure 13] encircling the North Parcel. Well G6 (G6A) is designated by
Acme personnel as the background well and the remaining 25 wells, numbered
MW101 through MW119, MW126 through MW128, G20, G25 and G28 are
designated as downgradient wells. The facility has not fully characterized the
site and cannot verify that the monitoring well network is adequate for this
facility.
As previously discussed in the Hydrogeology section of this report, facility
personnel have not determined the direction of ground-water flow and stated
that it is not possible to establish horizontal hydraulic gradients. Therefore,
facility personnel cannot verify the proper location of the designated upgradient
well as representative of background ground-water quality.
The facility also has not fully characterized the uppermost aquifer;
therefore, additional wells of differing depths may be necessary to adequately
represent the water quality upgradient of the facility. The driller's log of well G6,
the designated upgradient well, indicates that the well is not completed in either
the grey silty clay or the peat zones monitored in the remaining downgradient
wells, or other strata characteristic of the bay mud designated by the facility as
the uppermost aquifer. The well is instead screened in a sandstone formation.
To be an acceptable background well, the well should be screened in the same
formation as the downgradient wells. Well G6 is not acceptable as a back-
ground well. The facility needs to establish a background well.
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MW107
MVV113
MW126
G 2 5 -•*•• G 2 0
NORTH PARCEL
117EAST PARCEL
LEGEND
MW102
Property Boundary
Waste Management
Boundary
Monitoring well
FIGURE 13
ACME ISD/RCRA MONITORING WELL NETWORK
son
SCALE INFEtT
1000
oo
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88
The facility contact from HLA also reported during the Task Force
inspection that well G6 may not be an appropriate background well because it
does not adequately identify contaminants suspected of migrating onsite from
neighboring facilities. This was the reason given for not completing the
statistical analysis required by 265.93(b). . An abandonment plan submitted by
HLA, after completion of the Task Force inspection, also lists well G6 as
proposed for abandonment because of a broken surface casing. In addition,
the leachate levels in the North Parcel are above the water levels in G6 and all
other wells, therefore, suggesting that none of the wells are upgradient. All of
the RCRA wells are within the potential area of influence of the leachate mound.
In order to properly locate upgradient wells, the facility personnel must
fully understand the hydraulic gradients, the extent and degree of inter-
connection in the uppermost aquifer and any effects of leachate mounding.
Once the hydrogeology is understood, the location, number and depths of
upgradient wells may be chosen, which are representative of background
ground-water quality.
The downgradient wells are all at the limit of the waste management unit;
however the vertical and horizontal distribution of the wells is inadequate to
monitor the multiple formations (discussed in the Hydrogeology section) with
varying hydraulic conductivities (e.g., peat, clay, sand, gravel, etc.) in the
uppermost aquifer. Each of the designated wells is hydraulically downgradient
of the leachate mound created by the North Parcel, but may not be capable of
immediately detecting a release of hazardous constituents.
The Acme monitoring wells are described by HLA as being constructed
as follows. Shallow wells were drilled with a 10-inch diameter hollow-stem
auger. The borings were drilled to depths ranging from 15 to 35 feet and were
sampled continuously with a 5-foot long, 21/2-inch diameter split barrel sampler.
A mud-rotary rig was used when peat or mud clogged the auger. When refuse
was encountered above the bay mud, conductor pipe was set through the entire
length of the refuse. Deeper wells (MW125-127) were drilled to depths ranging
from 60 to 75 feet. They were drilled with 8-inch hollow stem augers and/or
mud rotary rigs when difficulty was encountered.
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The wells were constructed with 4-inch diameter Schedule 40, flush-
threaded PVC well casing. No glues or resins were used to connect the casing
lengths. The lower 10 feet (approximately) of the borings were screened with
machine slotted 0.02-inch well screen. Sand packs, designed for the screen,
were placed between the casing and the boring wall, completely covering the
screened section. Bentonite pellets were added above the sand pack and a
cement/bentonite grout was placed from the top of the pellets to ground surface.
All wells were completed above grade and were equipped with a locking steel
cover.
Most wells were developed using an airlift method until several well
volumes were removed. Wells MW117, MW118 and MW119 had an oily
substance on the water and the wells were bailed in order to contain all of the
development water.15
There were numerous discrepancies between the field drilling logs and
the construction records submitted by HLA to the regulatory agencies. Many of
these discrepancies raise significant questions regarding the formations
screened and the integrity of the wells and/or any samples taken from them.
Many field logs were edited by HLA personnel and the records submitted
to EPA/DOHS are inconsistent or inaccurate. The field logs specify the
approximate percentage of peat in the core sample. In some logs a silty clay
formation containing as much as 40% peat has been edited by HLA to read
"minor" peat. In other wells, the same silty clay with 40% peat was reported to
contain "high" peat content. The percentage of peat present has been omitted
from the final construction logs. Many well logs were edited (23) and some
have been altered to be significantly different than the original field logs (9) for
the geologic description.
The field records for well MW125 identified a silty clay zone with 5% peat
at depths between 30 and 50 feet below the surface. The log submitted to
regulatory agencies identify the zone as peat. Another comment on the same
well log identified a zone with interbedded clay zones of 1/4-inch thick. The final
construction log shows interbedded zones of clay 4 inches thick.
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The construction records for numerous wells are either incomplete or
inaccurate. The main types of problems and the wells affected are as follows:
No field construction logs and/or driller's logs - MW112, MW128,
MW132, G6A, G13, G14, G26 and G28 through G32.
Drilling depths in construction records do not match field logs -
MW105, MW114, MW115, MW116 and MW135
Construction records are not complete or are inaccurate when
compared to the field drilling logs as follows:
No mention of the silt trap - MW102, MW114, MW116,
MW126and MW127
No mention of the well cave-in and inability to install a full
length of sand pack around the screen - MW106, MW108,
MW111 and G22
No mention of backfilling the hole in well MW131 (no cement
grout) - or well MW134 (with cement grout)
Borehole sizes differ- MW115, MW133, G15, G16, G17, G18,
G23 and G27
No documentation of the type and/or volume of cement grout
(MW131, MW134 and G17)
Final construction record does not mention the 15 pounds of
"wheat bran" used possibly due to a loss of circulation in
MW115. HLA representatives could not explain the use of
the wheat bran.
No well cover initially installed - MW106, G23, G24, and G27
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No sieve analyses were conducted for any of the wells
constructed; therefore, the filter pack and screen size are
questionable considering the variety of formations screened.
In addition, the construction diagrams submitted do not include the field
comments regarding high OVA readings (MW117, MW118 and MW119), strong
odors of creosote (MW133 and MW136), kerosene (MW101), hydrogen sulfide
(MW106, MW109, MW127), etc., nor do they identify when wells were drilled
through oily zones of up to several feet in length ( MW117, MW118, MW119,
MW133 and MW128). Most of these wells were completed below the zone(s)
where indicators of contaminants were present and migration of contaminants
may not be monitored adequately.
In addition to the problems revealed following review of the drillers logs,
additional potential problems were noted during the course of Task Force field
activities.
Broken or missing surface cement seals around well, potentially
allowing contamination to enter these wells from the surface - G25,
MW115, MW120 and MW124
No locking well cap and the potential for allowing unauthorized
entry or surface contamination - MW102, MW104, MW119, G25
Surface casing c arflowing, indicating either broken surface casing
and/or inadequate cement seal - MW116, MW125, G15 and G20
Samples very turbid, indicating either inadequate development of
the well or inappropriate grain size of the sand pack - MW115,
MW117, MW119andG20
Abnormally high pH, indicating possible cement grout contamina-
tion (or wheat bran contamination) - MW115
Unable to find well, buried in refuse, potential conduit for migration
of leachate -G14
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No abandonment records, therefore, the wells may not be
adequately plugged, creating a potential conduit for migration of
contaminants to the completion zone(s) - G4, G6, and G14
Most wells are completed in several zones of differing hydraulic
conductivities: MW101 through MW108, MW110, MW111, MW113, MW117,
MW124, MW128, G6A, G14, G15, G30, and G32. This would not allow for
adequate monitoring of the uppermost aquifer.
ACME SAMPLE COLLECTION AND HANDLING PROCEDURES
HLA personnel sample the Acme wells for the required interim status
monitoring. The Sampling and Analysis Plan (SAP) submitted in February
1986, is the most recent plan and reflects the current sampling procedures.
Some of the sampling procedures are inadequate and the plan, in several
instances, is not strictly followed, as required by the ISO [Section VIII (2)(a)]
and 40 CFR Part 265.92(a). HLA was requested to demonstrate their sampling
protocol for Task Force personnel. The following is an evaluation of the
sampling procedures used by HLA while sampling well MW111 and their
compliance with the procedures outlined in the February 1986 SAP. The
information was derived from the HLA demonstration, interviews with HLA
personnel and a review of facility field data sheets from sampling during May
1987.
Water Level Measurements
The method used by HLA to measure the static water level and total
depth of the monitoring wells is not accurate and ail of the procedures are not
followed. HLA personnel lower an unweighted metal tape, the end of which is
coated with blue carpenters' chalk, into the well to the approximate water level.
The length lowered is noted relative to a casing reference point (at the top of the
PVC casing) at the surface. The tape is withdrawn to determine the wetted
chalk length. The wetted length is subtracted from the total length lowered, to
determine the depth to water from the surface. According to the February 1986
plan, the total depth of the well is also supposed to be measured with the steel
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tape by extending the tape until the bottom is reached. Both measurements are
supposed to be recorded in the field log to the nearest 0.01 foot.
The use of an unweighted metal tape may not produce accurate or
reproduceable results since the tape can bend in the well. The total depth of
the well was not measured during the HLA demonstration. Review of the field
data sheets from May 1987 indicates that the depths of the wells recorded on
the field sheets is the depth from the construction records rather than the actual
depths. The total depth of the well may not be measured quarterly, as indicated
in the plan. Accurate measurements of both the total depth and water levels are
necessary to calculate purge volumes. Depths in the field notes were also
reported to the nearest one-half foot rather than to the nearest 0.01 foot, as
specified in the plan.
Total depths for the majority of the interim status wells (23 of 26 wells
around the North Parcel) we^e measured during the Task Force inspection, and
found to vary significantly from the depths recorded in the field notes or those
depths used by HLA to determine purge volumes. The differences in the total
depths ranged from 10.54 feet shallower to 6.42 feet greater than the depths
recorded by HLA in the field notes. The differences in total depths affect the
required purge volumes by up to 20 gallons, using the three well volumes
specified in the plan. Therefore, the volumes purged by HLA would not be
adequate for some wells sampled.
The plan does not contain adequate decontamination procedures for the
metal tape. The last several feet of tape are rinsed with municipal water before
reuse. The entire length of the tape entering the well should be properly
decontaminated with anionic detergent and deionized water in order to avoid
cross contamination of wells.
Purging Procedures
The purging methods in the plan are incomplete and the methods
specified are not followed. The plan states that low yielding wells are supposed
to be purged using a hand-operated suction pump or centrifugal pump until dry
and allowed to recover before sampling. High yielding wells are purged of at
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least three well volumes prior to sampling. During water removal, temperature,
pH and conductivity are supposed to be measured and recorded on field
sampling sheets.
Stainless steel bailers are used in low yield wells, as well as centrifugal
pumps; bailers should be added to the equipment referenced in the plan. The
method for determining the purge volume is not included in the plan, nor are the
methods for collection and disposal of purge water.
During the demonstration HLA personnel calculated the volume of water
in the well using a table of conversion factors. The well volume was multiplied
by three, to determine the purge volume. As cited previously, the total depths
were not measured. The table of conversion factors used to determine the
volume should also be included in the plan.
The methods used to measure the volume of purge water collected were
inaccurate and the disposal of the water was not carried out in an
environmentally sound manner. The submersible pump, used during the
demonstration, was allowed to discharge into an uncalibrated bucket during the
purge. While pH, conductivity and temperature were measured the bucket was
overflowing. Therefore, the measurement of the purge volume was inaccurate,
even though volumes to the nearest gallon are recorded on field data sheets.
Purge water from the bucket was discharged directly to the ground
adjacent to the well. Because this water may contain hazardous waste or
hazardous waste constituents, it needs to be disposed of in a more
environmentally sound manner. Task Force personnel were informed by HLA
that purge water collected from wells along the IT Vine Hill border (found to be
contaminated with volatile organics in 1983) was contained in drums and then
properly disposed. When the Task Force collected samples along the IT border
the purge water was contained in drums provided by Acme. The purge water
was then disposed of by Acme. The Task Force discovered, via discussions
with the Acme General Manager, that the purge water was disposed of in the
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hazardous waste trenches, a violation of 265.314(b) and (f).* (Unwanted split
samples provided to the facility during the inspection were also improperly
disposed of in the trenches.)
The plan requires pH, conductivity and temperature measurements,
taken during the purging, to be recorded on the field sampling sheets. These
measurements were not recorded on the May 1987 field sheets or on the sheets
completed during the demonstration for the Task Force.
Sampling Methods
Ground water from high yielding wells is reportedly sampled by HLA
immediately after purging. Low yielding wells are sampled the day after
purging because of insufficient volume, with the exception of the volatile
organics aliquot, which is poured as soon as there is sufficient volume. Water
samples are obtained using a stainless steel bailer. The sample is poured from
the bailer into laboratory prepared sample containers. The sample order, bottle
type and preservation methods are in Table 13.
Pumps (used for purging) and bailers are cleaned between wells by
rinsing the exterior with hot water from a municipal tap. The interiors are rinsed
with anionic detergent and water. The equipment is given a final rinse, exterior
and interior, with water from the municipal supply. The rope attached to the
bailer is changed after each well.
Quality assurance/quality control samples are taken quarterly as follows:
(1) One trip blank provided by a laboratory, (2) field blanks which are 10% of
the samples and (3) one duplicate sample for the North Parcel. Samples are
submitted with coded identification numbers to the lab. The labels contain the
date of sampling, sample collector and job number.
Liquid either hazardous (b) or nonhazardous (f), is not to be disposed of in landfills after
May 8, 1985.
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Table 13
ACME SAMPLE ORDER, BOTTLE TYPE AND PRESERVATION
METHODS
Parameter Bottle Preservative
Volatile Organics
TOG, TOX 8 40-ml VOA vials
Coliform bacteria 8 oz. plastic
Phenols 2 1-pt. amber glass H2SO4 to pH<4
Anions* 1 qt. plastic
Metals 2 1-qt. plastic Filtered, HNOa to pH<2
Pesticides 2 1-qt. amber glass
Radiological 1 gal. plastic
pH and conductivity measurements are taken from the aliquots for anions, metals
and pesticides.
The procedures stated are unacceptable and incomplete. The use of
water from the municipal supply is unacceptable for use in decontaminating
equipment. The municipal water should be tested to determine if there are
contaminants present or deionized water should be used to rinse equipment.
The plan does not specify that preservation or filtering procedures which are
used in the field. The pH, conductance and temperature are measured at the
beginning of sampling and should be stated in the plan. In addition, samples
are reportedly preserved by HLA in the field and the pH of the preserved
sample is verified before shipment to the lab; this should also be added to the
plan. The laboratory evaluation indicated that samples were not filtered or
preserved in the field, as reported by HLA personnel to Task Force field
personnel. Samples should be field preserved.
The plan is not always followed. Despite what the plan requires, HLA
personnel reported that all metal samples are filtered in the field using a .45
micron millipore disposable filter, and then preserved with nitric acid to a pH <2.
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The plan does not indicate that any samples will be filtered, and most metals
are stated to be reported as total metals concentrations. If samples are filtered,
they must be reported as dissolved metals concentrations.
Shipment and Chain-of-Custodv Control
The shipment and chain-of-custody procedures used by HLA are
adequate. Sample containers are placed directly in a ice chest, with ice, and
transported to the analytical laboratory on a daily basis. A chain-of-custody
record accompanies the samples and includes: Sample number, signature of
collector, date and time of collection, sample type, identification of well,
parameters requested for analysis, and signatures and dates of persons
involved in chain-of custody.
GROUND-WATER QUALITY ASSESSMENT PROGRAM OUTLINE AND
PROGRAM
The ISO issued by DOHS on October 23, 1981, (and RCRA 40 CFR Part
265.93), required Acme to prepare, by November 19, 1981, a ground-water
quality assessment program outline. The outline is required to describe a more
comprehensive ground-water monitoring program than the one for routine
interim status monitoring and be capable of determining:
Whether hazardous waste or hazardous waste constituents have
entered the ground water
The rate and extent of migration of hazardous waste or hazardous
waste constituents in the ground water
The concentrations of hazardous waste or hazardous waste con-
stituents in the ground water
A ground-water quality assessment program outline had not been
prepared for the Acme facility at the time of the Task Force inspection.
Personnel from HLA were questioned at length regarding assessment
responsibilities and were unaware of the requirements in both the ISO
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[Section VIII (3)] and 40 CFR Part 265.93. Task Force personnel were told that
an assessment outline would be prepared before their departure from the site.
This, however, did not occur.
The first assessment outline for Acme was submitted by HLA to EPA
Region IX and DOHS on August 21, 1987. The outline was reviewed by Task
Force personnel and found to be inadequate. The outline does not address the
following items:
How data triggering assessment would be evaluated to confirm
apparent contamination
Circumstances under which additional monitoring wells would be
necessary if the initial phase of the program indicates contamination
How volume/concentration of released contaminants would be
determined
How the rate and extent of contaminant migration would be
determined, other than by review of existing data
How the facility would be sure that all potential contaminants were
identified in the plume
How an assessment monitoring plan would be developed and the
projected sampling frequency
Which aquifer(s) would be monitored
Approximate schedules for the time needed to initiate assessment
sampling, analyses, data evaluation and report results
In addition, the document references the use of existing hydrogeologic
data as the source for determination of both rate and extent of migration of
constituents. As mentioned in previous sections, the existing hydrologic
evaluation does not identify ground-water flow directions or the uppermost
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aquifer adequately; therefore, use of this information in an assessment program
is meaningless. The outline should instead indicate how additional
hydrogeologic data would be collected in the event of detection of significant
increases (or decreases for pH) in hazardous waste or hazardous waste
constituents.
The outline also references statistical analysis of well data to determine if
assessment is triggered. However, the most recent site characterization
indicates that well G6 is not monitoring the same saturated intervals as the
downgradient wells and, therefore, is not acceptable as a background well.
Statistical analyses are not truly meaningful until background is established;
however, statistical analysis using the data from the designated well G6 would
have triggered assessment at an early date, and could have led to a more
appropriate well network.
The fifth quarter of interim status detection monitoring was completed in
March 1987. Had facility consultants performed statistical analyses, as required
by 40 CFR Part 265.93(b) (using G6 as the upgradient well), a statistically
significant increase (or decrease for pH) would have been identified for several
indicator parameters. All downgradient wells, 25 total, showed statistically
significant (0.01 level of significance) increases in conductivity. Two wells,
MW115 and G25, had a significant increase or decrease in pH, respectively,
and 23 wells had significant increases in TOC. TOX data was not evaluated
due to the questioned reliability of the data, as described in the Sample
Analysis and Data Quality Assessment section of this report.
Analytical results prepared for Acme contain biases and are probably not
based on comparable methods (a fault of the February 1986 SAP), as
discussed in the Sample Analysis and Data Quality Assessment of this report.
However, comparison of data generated within the same quarter continuously
demonstrate an order of magnitude difference between values reported for the
designated upgradient well G6, and all other designated downgradient wells,
for TOC, TOX and conductivity. A review of ground-water data presented during
the self-monitoring program also indicated statistically significant (0.01 level of
significance) differences between wells.
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The 1983 Part B permit application designated well G6 as the
upgradient well for the self-monitoring program. Prior to that time no
designation was required, or stated. The data generated for the self-monitoring
program from 1981 through 1985 also indicate higher concentrations for
conductivity, TDS, kjeldahl nitrogen, TOC and chlorides for numerous wells
compared to G6. No statistical evaluation was required under the self-
monitoring program. The facility had completed five quarters of analytical
results between November 1981 and November 1982 (when a waiver of the
ISO interim status requirements was requested) and should have performed a
statistical analysis, as required by the ISO. An evaluation of the data generated
under the self-monitoring program (data since 1976) should also have been
conducted by RWQCB as part of the waiver review process.
No statistical evaluation had been conducted by the facility, at the time of
the Task Force inspection, for any data generated either during the self-
monitoring program or RCRA interim status monitoring, a violation of 40 CFR
Part 265.93(b) and Section Vlll(3)(b) of the ISO.
Historical compliance reports and site characterizations, 1981 to present,
have characterized the differences in parameter concentrations across the site
as either "fluctuations...over ranges which have been present in the past"16or
"...differences attributable to the characteristics of bay mud."r7 Volatile
organics, including tetrahydrofuran, trichloroethylene and methylene chloride
were detected in leachate samples as early as November 1982 and in several
monitoring well samples as early as June 1983. These parameters are not
naturally found in bay mud and indicate hazardous waste migration. These and
other volatile organics were among the unauthorized wastes improperly
disposed at the facility (Cordis Dow - refer to Table 9).
Acme personnel have repeatedly ignored the presence of hazardous
waste constituents or indicator parameters in the monitoring wells. The. facility
should have triggered assessment, at a minimum, in March 1987, at the end of
five quarters of ISO monitoring. A program similar to assessment should have
begun (during self-monitoring) as early as August 1982 when heavy metals
were detected, or in June 1983 when volatile organics were detected in several
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wells. A corrective action program, rather than "assessment," would have been
required under the self-monitoring program.
The assessment program plan should be based on the assessment
outline, which as previously discussed was not written until August of 1987, and
must specify:
The number, location, and depth of wells
Sampling and analytical methods for those hazardous wastes or
hazardous waste constituents in the facility
Evaluation procedures, including any use of previously-gathered
ground-water quality information
A schedule of implementation
The implementation of the assessment program must be in accordance
with provisions of 40 CFR Part 265.93(d) and CAC Title 22, Section 67194.
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SAMPLE ANALYSIS AND DATA QUALITY ASSESSMENT
This section provides an evaluation of the quality and completeness of
interim status ground-water monitoring data gathered by Acme Landfill (Acme)
between January 1986 and March 1987. At the time of the laboratory
evaluation, Acme had completed five quarters of detection monitoring under the
current ground-water sampling and analysis plan dated February 4, 1986.
Detection monitoring started in October 1985, but facility personnel chose to
identify the first quarter of 1986 as the official beginning of the initial year of
monitoring. HLA was responsible for sampling and reporting ground-water
monitoring data to Acme during the five quarters of monitoring. Under contract
to HLA, the analytical laboratories of Curtis and Tompkins, Ltd. (CT) have been
primarily responsible for analyzing the samples. Curtis and Tompkins has
laboratories at two locations, one in San Francisco (CTSF) and one in Los
Angeles (CTLA).
CTSF has performed all pH, specific conductance, elemental (metals)
and phenol determinations (except first quarter 1987). CTLA has performed all
anion determinations and during the last quarter of I986, total organic carbon
(TOC), total organic halide (TOX) and fecal coliform determinations. Under
contract to CT, three other laboratories have analyzed Acme ground-water
samples. Reportedly, (according to CTSF personnel) during the first two
quarters of I986, Brown and Caldwell of Emeryville, California performed the
determinations for TOC, TOX and coliform. Brown and Caldwell also analyzed
samples for coliform during the third quarter of I986. Radium, gross alpha and
gross beta determinations were performed by Thermo Analytical/Norcal of
Richmond, California during the second quarter of I986 and by Environmental
Laboratories Incorporated (ELI) of Gulf Port, Mississippi for the last two quarters
of 1986 and the first quarter of 1987. ELI also reportedly analyzed samples for
TOC and TOX during the third quarter of I986.
NEIC chemists conducted laboratory inspections between June 2 and
June 11, I987 at the two CT laboratories. Five quarterly monitoring reports and
associated laboratory records for the RCRA monitoring well network were
reviewed. Laboratory procedures were evaluated and laboratory equipment
was inspected. The examinations revealed problems that could affect the data
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quality. Most of the problems stem from inadequate quality assurance
measures which include inadequate methodology and calibration procedures
and improper sample handling. Improper sample handling has potentially
affected pH, dissolved elemental (metals) and nitrate results. Acme did not
follow the February 1986 sampling and analysis plan (SAP) when handling
samples collected for dissolved elemental constituents. The results reported for
TOX, elemental constituents and radionuclide parameters may be unreliable.
The analytical methods used did not take into account the high dissolved solids
content of the samples. Analytical records for some of the analyses could not
be located. All reported detection limits, with the possible exception of those
associated with radionuclide measurements, are unreliable because of the
manner in which they were calculated or estimated. These inadequacies
adversely affect the reliability of data in establishing background levels and/or
in detecting releases into the ground water. A detailed discussion of these
problems is given in the following sections.
INITIAL YEAR OF MONITORING
RCRA regulations [40 CFR 265.92(c)] require quarterly monitoring of all
wells during the initial year of interim status monitoring to establish background
values. Quarterly monitoring of the upgradient wells must include quadruplicate
measurements of the four parameters used as indicators of ground-water
contamination: TOG, TOX, pH and specific conductance. In March 1986, Acme
initiated quarterly monitoring pursuant to 40 CFR 265.92 for its RCRA/ISD
designated monitoring well network. The network consisted of 25 wells around
the North Parcel, in the first quarter, and 26 wells in succeeding quarters. Well
number G6 was designated as the upgradient well. A review of the data
submitted showed that the indicator parameters were reported at the frequency
specified.
Chain-of-custody procedures used in the laboratory are inadequate.
Frequently the date and time of receipt of samples at CTSF were not noted on
custody sheets. This notation is necessary to show the exact whereabouts of
the samples. The date and time of analyses for coliform and anion
determinations were not recorded. When determining parameters with limited
holding times such as these, it is especially necessary to record the time of
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analysis in order to demonstrate the integrity of reported results. Access to the
samples at CTSF is inadequately restricted; the sample storage area is
accessible to anyone entering the main door of the facility. Laboratory
personnel were not always present to monitor outside access to the sample
storage area, therefore, custody can not be demonstrated.
Reported pH results may be unreliable because recommended holding
times were exceeded. Failure to analyze the samples within holding times may
have resulted in changes in sample pH. EPA currently recommends that pH
measurements be performed in situ or immediately after collection. The
samples from which quadruplicate pH measurements were made were
transported from the site to the laboratory in San Francisco where they were
typically analyzed a day or more after collection. For example, pH
measurements on samples collected November 25, 1986 were not performed
until December 1, I986 (6 days after collection). The February 1986 SAP
specified analyses of pH samples within 2 hours. Thus, the SAP was not
followed. Measurements for pH were also commonly performed on filtered
samples. This practice further reduces the reliability of reported results.
Filtration may degas or otherwise alter constituents in the sample, thereby
affecting pH.
Errors may be present in specific conductance data. For example, fourth
quarter data for two wells, MW117 and MW118, were identical. This is highly
unlikely and probably indicates that either one or both were reported in error.
The average of the data for those two wells was approximately 18,000 which
does not agree with reported data for all oth~r quarters at either well. The other
quarterly data reported for well MW117 ranged from approximately 45,000 to
48,000 jj.mhos/cm. The other data for well MW118 ranged from approximately
50,000 to 60,000 |imhos/cm. Reported chloride results also discount the 18,000
H.mhos/cm values reported. This fourth quarter data for specific conductance
may therefore indicate a measurement error or sample mix up.
The standard TOX method can often achieve a detection limit of between
5 mg/L and 30 mg/L However, the high chloride levels in the site's ground-
water samples would prevent such a detection limit from being achieved. High
chloride levels can cause TOX results to be biased high. Typically 50 mg/L
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chloride could cause an apparent TOX of 1 mg/L Some of the ground-water
samples were found to contain as much as 30,000 mg/L chloride. Such
samples, therefore, show an apparent TOX of 600 mg/L. Furthermore, the high
sodium content of these samples can cause the quartz furnace of the TOX
analyzer to deteriorate resulting in a negative bias .for TOX measurements.
TOX measurements using the standard method and instrumentation for
ground water containing such high levels of dissolved salts can not serve as an
indicator of low level contamination of halogenated organics and, thus, the
reported TOX results are inherently unreliable. POX (purgeable organic halide)
measurements could serve as an indicator of low-level contamination of volatile
halogenated organics, assuming proper care is taken to ensure the quartz
furnace does not deteriorate due to an excessive purge rate introducing sodium
in the furnace.
TOC results reported for the last quarter of 1986 may have been biased
low. These results were obtained by acidifying and purging samples prior to
analysis. The results for this type of analysis are best termed non-purgeable
organic carbon (NPOC), since the purging not only eliminates inorganic carbon
from the measurement but also purgeable organic carbon (POC). TOC can be
defined as the sum of NPOC plus POC. In order to equate NPOC with TOC, the
facility would need to measure POC to establish that it is not a significant
component.
Problems were observed in the TOC data reported. Significant
differences in the data were noted between quarters. Data from the second
quarter of I986 is believed to be high in relation to other quarters. For example,
the reported concentrations for well MW117 for this quarter average 301 mg/L,
while all other quarters range from 69 to 107 mg/L. Similarly for well G6, the
average value reported for the second quarter was 33 mg/L; whereas, values
for other quarters were below 20 mg/L. The nonconforming results observed for
this sampling may be due to systematic error rather than to actual changes in
the concentrations in well samples. Also, some of the replicate data for the
second quarter was noted to be imprecise. For example, the replicates reported
for well G20 were 133, 184, 130 and 170.
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Although samples were spiked to determine TOC recoveries, apparently
no correction was made when recoveries were low. For example, data was
reported for the samples from monitoring well MW109 (384 mg/L average) even
through the spike recovery was 14%. Recoveries for other samples analyzed
on the same date ranged from 75 to 81% which would also be considered low.
Review of laboratory records revealed additional problems related to
sample handling and analyses. Examination of chain-of-custody forms showed
that replication procedures for the four indicator parameters are inappropriate.
Samples were split in the field. Analysis was performed on each of the four field
aliquots rather than from the same aliquot. The regulations specify
quadruplicate measurements on the same sample [40 CFR 265.92(c)(2)] which
implies measurements on the same container or from aliquots of the sample
taken concurrently with the analyses. Thus, the standard deviation obtained
from the pooled results on field aliquots may be greater than that calculated
from aliquots obtained concurrently with the analyses. Higher standard
deviations degrade the ability to statistically assess ground-water contamination
where this is relevant.
In addition to the indicator parameters, the regulations [40 CFR 265.92]
also require the analysis of drinking water and ground-water quality parameters
including certain elemental constituents (metals), herbicides, pesticides and
radionuclides as well as coliform, fluoride, chloride and sulfate. Radionuclide
data was not reported for the first quarter of 1986; however, the required
reporting was completed in the subsequent four quarters. Data for the other
parameters was reported at the frequency specified.
The percent levels of dissolved solids contained in some samples (as
indicated by conductance) caused problems with a number of the analytical
procedures used. Elemental determinations were performed exclusively by
atomic absorption spectroscopy (AA) techniques. Many of these determinations
for elemental constituents are unreliable because of the serious interferences
from dissolved solids present in the ground-water samples. An example of
unreliable data would be the results for arsenic and selenium (quarter one and
two) generated using the furnace technique. The detection limits specified for
ground-water protection can be achieved for samples containing relatively low
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107
amounts of dissolved solids. However, the high chloride concentration in these
samples causes so much molecular background that the analyte atomic
absorption signal cannot be reliably distinguished by the background correction
system of the furnace instrument. Further, ionization interference would have
been severe when the flame AA technique was used for arsenic and selenium
in the other three quarters and for all other metals except sodium during all five
quarters. This ionization interference would have resulted in unreliable data for
these parameters.
The dissolved elemental results may also be unreliable because of the
sample handling procedures used. Filtration and preservation immediately
after sample collection is necessary to preserve the integrity of the dissolved
constituents. The February 1986 SAP stated that filtration and preservation
would be performed in the field. Instead, metals samples from Acme were taken
to the laboratory and reportedly filtered the next morning before preservation
with nitric acid. The filtered sample was reportedly poured back into the original
container. Failure to perform the necessary filtration and preservation
immediately after sample collection may result in changes in the dissolved
elemental concentrations in the sample due to oxidation-reduction reactions
and sorbtion onto the container.
Although metals samples were spiked, resultant recoveries may have
been overestimated because spike levels were too high in relationship to
sample concentration. Under these circumstances low concentration matrix
effects may not be observed. A chemical species present in the sample at low
concentration, which would interact with the analyte of interest, may be
completely consumed by the analyte spiked at high concentration and,
consequently, not interact to bias recoveries. For example, 2.5 milligrams per
liter (mg/L) spike levels were used for chromium, copper and lead, whereas,
sample concentrations were reported at less than 0.05 mg/L. Detection limits
were determined on blanks with little or no dissolved solids. The detection
limits for many of the elemental constituents reported by the laboratory are
therefore likely to be conservative.
Barium is often reported in Acme samples at levels above the maximum
contaminant level (MCL) specified for ground-water protection and is, therefore,
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108
a matter of concern. However, on the basis of accompanying sulfate
concentrations and using approximations for high ionic strength,18 the
calculated barium solubilities are lower than the concentrations reported. This
finding is a further indication that the methods used did not adequately correct
for ionization interferences.
Arsenic was reported at levels in excess of the MCL [50 micrograms per
liter (^ig/L)], e.g., 54 mg/L, for the second quarter of I986, in well MW126;
however, for reasons mentioned below, data may be unreliable. In subsequent
quarters, the laboratory switched from furnace AA to flame AA when analyzing
arsenic and selenium. Flame AA did not achieve the required detection limits
for ground-water protection standards. The different amounts reported or
reported as nondetected between quarters are the result of the change in
methods and stated detection limits. The methods used for arsenic and
selenium were inappropriate during all quarters. The hydride technique, which
separates these elements' from interferences due to dissolved solids, is
recommended for these samples.
The methods used for lead, chromium and cadmium were also
inappropriate. Laboratory records show that the flame AA methods could not
reliably measure concentrations at the MCLs specified for ground-water
protection even in the absence of high dissolved solids.
The procedure used for calibrating the atomic absorption instrument at
CTSF may have contributed to data unreliability. The calibration is reportedly
accomplished using a single calibration standard. This type of calibration does
not verify the functional relationship between concentration and response. In
order to document this relationship, and as an integral part of good quality
control, a multipoint calibration should have been performed at least once
during the time each group of samples were analyzed.
Mercury levels in the samples could have been underestimated. Mercury
was determined exclusively by cold vapor atomic absorption spectroscopy.
This methodology requires a heated digestion of the samples. The digestion
renders mercury species to the divalent ionic form, prior to reduction to the
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109
measureable elemental form for cold vapor atomic absorption spectroscopy.
This heated digestion was not performed for the facility samples.
The methodology used for gross alpha and gross beta measurements
was inappropriate for samples containing high dissolved solids. The use of
such methodology is understandable because standard procedures, including
those referenced in EPA publications, do not reliably measure MCLs for gross
alpha or gross beta in the presence of high amounts of solids. Other
methodology has been suggested for samples with high dissolved solids;'9
however, it would "^ necessary to validate its use on these particular samples.
Some of the reported gross alpha results are significantly above the MCL
of 2 picocuries per liter (pCi/L). For example, gross alpha values of 166 +/- 82
pCi/L were reported for well MW117 and 174 +/- 89 for well G25 during the
second quarter of 1986. Accounting for the confidence intervals (indicated by
+/-), these results infer respective gross alpha values of at least 84 and 85
pCi/L, respectively. If these levels are accurate, they are a matter of concern
because they exceed the MCL; however, the procedures used to obtain these
results were not evaluated. Most of the other results reported are questionable
since the counting errors are frequently of the same magnitude as the values
reported. The same comments are also applicable to gross beta values
reported.
Fluoride and nitrate results may be unreliable. These parameters were
analyzed by Ion Chromatography (1C). Using this method, several weak acids
may be inappropriately measured as fluoride. Thus, fluoride results may be
biased high. Although the laboratory bench sheets do not show the exact times
of analyses, nitrate was reportedly analyzed past the maximum 48-hour holding
time EPA has recommended in similar applications. The excessive holding
time may have resulted in changes in the nitrate concentrations in the samples
and, therefore, produced unreliable data. Nitrite was reported in some samples
and although it may have been present at the time of sampling, it may also be a
result of nitrate degradation through chemical reduction.
The daily calibration of the ion chromatograph used to measure fluoride,
chloride, nitrate and sulfate was inappropriate. Standard analytical practice
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110
recommends daily, multipoint calibration to maximize and document accuracy.
Daily 1C instrument calibrations by the laboratories were based instead, on a
single calibration standard rather than several standards, needed to verify a
functional relationship over a discrete concentration range.
Analytical results reported for phenols during the first three quarters of
1986 and for pesticides and herbicides during all quarters are suspect because
raw data, including essential quality control data, could not be located for
review during the Task Force inspection. In some cases, essential quality
control procedures were reportedly not performed. 40 CFR Part 265.94(a)(1)
requires the maintenance of analytical records. No raw data for phenol
determinations were found for the first and third quarters in any of the sample
files examined. During the first quarter of 1986, the sample files for wells
MW117 and G20 contained some pesticide raw data records, but the quality
control information was incomplete and the detection limits reported were not
verifiable. No raw data records for pesticide determinations could be found for
other samples reviewed for the first quarter, or any subsequent quarters. During
the first quarter of 1986 when herbicide raw data records were located, the
detection limits reported could not be verified and the quality control procedures
were inadequate to support the data.
The pesticide and herbicide data may also be unreliable because the
effects of appreciable suspended solids in some of the samples were not
evaluated. Suspended solids interfere with extraction of pesticides and the
conversion of herbicides to the chemical forms necessary for measurement.
Thus, in order to show that the results reported were reliable, it was necessary
to spike real samples with the analytes of interest and to determine that the
recoveries achieved were satisfactory. Real samples were not spiked with
herbicides in any quarters. The reliability of spike data reported for phenols
during the first three quarters and pesticides during all quarters could not be
determined because, the raw data could not be located.
The February 1986 SAP developed by Acme was not sufficiently detailed
to insure uniform analytical methodology since no methodology was specified.
The SAP-listed incorrect preservation procedures. Acidification to pH less than
2 was specified for fluoride and the pesticides and herbicides. The preservative
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111
specified for TOX samples was sodium sulfate and not sulfite. In comparing the
data from each quarter, it is important to note that three different methodologies
were used to determine phenol concentrations. Each of the methods used
contain inherent biases and, therefore, inhibit the comparison of data from
quarter to quarter. One method for determining phenols should have been
specified in the Acme SAP of 1986, and the same method should have been
used for all quarters.
MONITORING IN 1987
The laboratory findings discussed in the initial year of monitoring are also
applicable to the second year data since most of the methods did not change.
Because 1987 was the second year of monitoring, samples analyzed for each
of the indicator parameters were required (40 CFR 265.92) to be performed in
quadruplicate. This was apparently done; however, as noted before, results
were obtained from separate analyses of field replicates rather than
quadruplicate measurements from the same sample aliquot.
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112
GROUND-WATER MONITORING PROGRAM
PROPOSED FOR RCRA PERMIT
The ground-water monitoring program proposed in the Part B permit
application, submitted to EPA Region IX on August 2, 1983, does not meet the
requirements of 40 CFR Part 270.14 (c).* The ground-water monitoring results
(self-monitoring program) indicated a release of hazardous wastes or
hazardous waste constituents at the proposed point of compliance [Figure 14],
before the submission of the Part B application. The monitoring program
proposed in the permit should have been a compliance monitoring program
instead of a detection monitoring program. The facility has not supplied the
information regarding protection of ground water, as required of an owner of a
landfill, and specified in 40 CFR Parts 270.14(c)(1, 2, 3, 4, 5, 7, and 8). The
ground-water monitoring portion of the Part B permit application is deficient as
follows:
270.14(c)(1) - The facility has not supplied a complete summary of
the ground-water monitoring data obtained during interim status
under 265.90 through 265.94. The application does not include
the self-monitoring program data from the fourth quarter of 1982.
The data submitted with the application is also not complete for the
quarters submitted. The application does not include volatile
organics data for 1982 and 1983, as reported to DOHS and
RWQCB.
270.14(c)(2) - The facility has not adequately characterized the
uppermost aquifer, ground-water flow directions or rates. Acme
personnel characterized the clay zone overlying the uppermost
aquifer; however, the company never characterized the uppermost
aquifer. The facility has not adequately defined ground-water flow
directions. The application states that the ground-water flow
direction is "...most likely to be to the north toward Suisun Bay
and/or to the east toward Walnut Creek."20 There is no discussion
of the rate of ground-water flow.
270.14(c)(3) - The topographic map referenced in the application
(Plate 2) does not show the location of the monitoring wells.
Plate 5 in the application, does show the well locations, waste
management area, property boundary and proposed "point of
compliance." None of the maps provided show any of the
information in 270.14(c)(2) (e.g., uppermost aquifer, direction of
ground-water flow, etc.), as required.
The State of California was never granted authorization to issue RCRA permits; therefore,
Federal requirements are cited.
-------
NORTH PARCEL
EAST PARCEL
LEGEND
Property Boundary
Waste Management Area
Monitoring wella
Proposed Point of
Compliance
G6A
G6 Jl
Proposed V
Monitoring Wells
FIGURE 14
PROPOSED POINT OF COMPLIANCE
500
1000
SCAIE
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114
270.14(c)(4) - The facility has not described the plume of
contamination from the North Parcel, as required. Heavy metals
and volatile organics were detected in several wells. The facility
reported that the results "did not indicate if the facility's present
containment system (dikes) was or was not containing the wastes
onsite. The low levels of metals detected could be the result of
surface contamination from leachate seeps prior to the
construction of the leachate containment barriers."21 The facility
never attempted to characterize a plume nor did they address the
volatile organics detected in leachate samples in November 1982
and February 1983, or in monitoring wells in June, September and
December 1983. The application did not attempt to identify the
concentrations of hazardous wastes in the ground water.
270.14(c)(5) - The application does not include an engineering
report describing the proposed monitoring program (264.97). The
application did not include: information required in 264.99
(compliance monitoring program), background water quality data,
water quality data at the point of compliance, a list of sampling
parameters, sampling and analysis procedures, etc.
270.14(c)(7) - The facility did not submit the information required
for a compliance monitoring program under 264.99, nor did they
include a feasibility study for a corrective action program under
264.100. The application also did not include a description of the
wastes handled, characterization and concentrations of hazardous
wastes in the ground water, etc.
270.14(c)(8) - Hazardous constituents detected in ground water
exceeded the maximum concentrations in 264.94 for cadmium
and lead in August 1982. The limits of detection were not
adequate to determine the presence of endrine, lindane,
methoxychlor or toxaphene at the maximum contaminant levels.
Samples were not analyzed for 2,4-D or 2,4,5-TP. The application
did not address the minimum requirements for a facility detecting
constituents above maximum concentrations (i.e., characterization
of ground water, corrective action program, concentration limits for
constituents, and a description of how the monitoring program will
demonstrate the effectiveness of the corrective action program)..
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115
EVALUATION OF MONITORING DATA FOR
INDICATIONS OF WASTE RELEASE
This section presents an analysis of Task Force and Company
monitoring data regarding indications of waste releases to ground water from
the North Parcel landfill. Field and laboratory analytical results from samples
collected by Task Force personnel are presented in Appendix A, together with
the analytical methods. The Task Force data indicates that hazardous waste
constituents have leaked from the landfill. The designated upgradient well G6
is used for comparison although the well is not considered to be an adequate
background well. Until the uppermost aquifer is fully characterized, however, it
is not certain whether the bedrock is interconnected to the overlying formations,
either naturally or because of Acme drilling activities; therefore, well G6 is used
for comparison.
VOLATILE ORGANIC SAMPLING RESULTS
Volatile organic results from the Task Force samples indicate the pres-
ence of volatile organic compounds at concentrations above the detection limits
in five downgradient wells, and similar constituents in the leachate well NPGR5
[Table 14]. The facility-designated upgradient well (G6) was found to contain
only one volatile organic compound (di-n-butylphthalate) but the concentration
was below the limit of quantitation and is estimated. The Task Force sample
results identified the presence of tetrahydrofuran in the leachate, but did not find
detectable quantities of the compound in the monitoring wells sampled. Acme
data has also shown detectable quantities of this compound in the leachate and
several monitoring wells (G3, G5 and G6). These three wells were not sampled
during the Task Force inspection. The Task Force analyses also identified
numerous volatile and semi-volatile organic compounds, in both leachate and
monitoring wells, which Acme has not identified including: benzene, 1,2-
dichlorobenzene, 1,4-dichlorobenzene, toluene, xylene, ethylbenzene, vinyl
acetate and phenol. Many of the volatile organics identified were present in
Cordis Dow or Shell Oil Company waste loads.
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Table 14
SELECTED VOLATILE ORGANIC CONSTITUENTS PRESENT IN TASK FORCE SAMPLES'
ACME FILL CORPORATION
Martinez, California
Constituent2
Benzene
1 ,2-Dichlorobenzene
1,4-Dichlorobenzene
Toluene
Xylenes
Ethylbenzene
1 ,2,4-Trimethylbenzene
1 ,3,5-Trimethylbenzene
Tetrahydrofuran
Vinyl Acetate
Di-n-Butyl Phthalate
Phenol
1 Wells MW126, MW128
Designated
Upgradient
Well
G6
ND*
ND
ND
ND
ND
ND
ND
ND
ND
ND
2.**
ND
Well
MW104
5.
2.
4.
2.
10.
7.
15.
3.
ND
ND
ND
ND
Well
MW115
3."
ND
ND
13.
ND
ND
ND
ND
ND
84.
ND
100.
and G20 were analyzed but not listed since no volatile
Well
MW116
ND*
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
2.*
Well
MW11
ND
ND
ND
5.
ND
ND
ND
ND
ND
ND
3.*
ND
organic compounds were
Well
7 MW1193
4."
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
detected.
Leachate
Well
NPGR5
2."
2."
17.
7.
7.
6.
5.
2 *.
150.
ND
ND
ND
2 Concentrations are expressed in micrograms per liter (ng/L).
3 Average of results from
Not detected
triplicate samples
Estimated value or below detection limit
-------
117
In the past (since 1982), facility samples have also identified acetone,
methylene chloride and trichloroethylene at detectable quantities, in both
leachate and other monitoring wells which were not sampled during the Task
Force inspection. These constituents were also present in wastes disposed by
Cordis Dow at Acme from 1979 through 1982.
INORGANIC SAMPLING RESULTS
The inorganic data from the Task Force samples also indicate that
hazardous constituents have migrated into the ground water. The total metals
concentrations in the downgradient wells are well above the concentrations
found in the ground water of the bedrock in the facility-designated upgradient
well [Table 15]. In most cases, the concentrations were over an order of
magnitude greater in the downgradient wells (although completed in different
formations) and the leachate well. Some of the metals present in the
downgradient wells exceed current primary drinking water standards (40 CFR
Part 265 Appendix III). For instance, barium was present at 0.39 milligrams per
liter (mg/L) in the upgradient well (G6) but ranged up to 2.9 mg/L in the
downgradient wells. The drinking water standard for barium is 1.0 mg/L Five
wells (MW104, MW115, MW119, MW128 and the leachate well) exceeded this
standard. Downgradient wells exceed maximum contaminant levels for arsenic
(MW117 and MW126) and chromium (MW126) also. Task Force samples were
not analyzed for coliform, but Acme analyses have detected coliform
concentrations in excess of the maximum contaminant level. Acme personnel
stated the high fecal coliform levels must come from leaks in the Contra Costa
County Sewer outfall. However, the facility also received 2,000 tons of sanitary
waste sludge (containing 84% liquids) from the Contra Costa County Sanitary
authority. Acme was ordered by RWQCB to not accept this waste again due to
the high percentage of liquids.
Most of the inorganics present in the designated downgradient wells
were also present in the samples from the leachate well. Many of the
inorganics present in the wells are representative of the types of wastes
accepted for disposal [e.g., iron slag and iron scale (Fe), alkaline sludges (Ca,
Ba, Mg, K and Na)], alum sludge [Al and SO4, boiler fly ash (Ni and V), etc.].
-------
Table 15
SELECTED INORGANIC CONSTITUENTS PRESENT IN TASK FORCE SAMPLES'
ACME FILL CORPORATION
Martinez, California
Constituent
As
Al
Ba
Ca
Fe
Mg
Mn
K
Na
V
Zn
Upgradient
Well
G6
<.010
5.36
.39
111.0
5.22
70.8
.177
5.01
88.
<.015
.059
Well
MW104
.011
<.30
2.37
78.5
10.0
236.0
1.34
528.0
4,360.
0.01
0.17
Well
MW115
<.050
5.60
1.23
2,860.
4.38
195.
0.061
259.
12,800.
0.037
0.045
Well
MW116
<.045
15.7
0.895
482.
20.1
518.
3.01
156.
4,740.
0.095
0.079
Well
MW117
.054
2.38
0.774
720.
14.2
1,860.
.449
246.
10,800.
.024
.031
Well
MW119"
<.010
3.51
1.67
454.
9.34
1,270.
1.52
198.
8,090.
.027
.035
Well
MW126
.155
47.3
0.457
NA*"
81.
922.
NA
357.
3.430.
.19
.19
Well
MW128
<.010
0.132
2.92
392.0
13.0
969.0
.926
73.7
5,260.
<.015
<.011
Well
G20
.007
2.5
0.493
509.
17.0
1,040.
NA
561.
6,750.
0.11
0.069
Leachate
Well
NPGR5
.012
<0.30
2.9
304.
77.
325.0
0.86
821.
2,880.
0.14
0.41
Concentrations are expressed in milligrams per liter (mg/L) and are for total inorganic concentrations.
Average of results of triplicate samples for this well
*** Not analyzed
CO
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119
RESULTS OF INDICATOR PARAMETERS
The interim status monitoring requirements specify sampling of pH,
specific conductance, TOC and TOX as parameters used to indicate ground-
water contamination. The Task Force results for these parameters indicate that
the North Parcel landfill has impacted ground-water quality. Table 16
summarizes the results for the indicator parameters.
The pH of all the wells is approximately the same except for well MW115,
which has a pH of 11.0 units. As discussed in the monitoring well construction
section, this well may be contaminated with cement grout, causing the elevated
pH. The specific conductance values in the designated downgradient wells
indicate a statistically significant (.01 level of significance) increase over the
values measured in the designated upgradient well G6. This data represents
the effect of elevated chlorides and other dissolved solids in the samples.
The TOC results for Task Force samples are reported as purgeable
(POC) and nonpurgable organic carbon (NPOC) instead of total organic carbon.
The designated upgradient well has significantly lower concentrations of POC
(160 mg/L) when compared to the downgradient wells, which have POC con-
centrations of up to 508,000 micrograms per liter (|ig/L) (well MW119).
The analysis of TOX is affected by high chloride concentrations and are
not reliable for the Acme facility [Appendix A]. The purgable organic halide
(POX) analysis is not normally affected by chlorides, however, and is a very
good indicator of ground-water contamination. As was noticed for the other
indicator parameters, the designated upgradient well had a POX concentration
of <5 (ig/L (below the stated detection limit) while most of the downgradient
wells had concentrations several times, to several orders of magnitude higher.
While the absence of measurable compounds in the VOA analyses and lower
results for TOX would at first contradict POX results for MW117 and MW119,
these discrepancies, at least in part, are explainable by the laboratory
procedures used. The detection of specific compounds in the VOA analysis
relies on trapping efficiency (a tenax/silica gel trap was used in this case). The
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Table 16
SELECTED RESULTS OF INDICATOR PARAMETERS FOR TASK FORCE SAMPLES
ACME FILL CORPORATION
Martinez, California
Parameter
PH
Conductance
POC
NPOC
POX
Upgradient
Well
Units G6
Units NA"
umhos/cm 1 ,650.
u,g/l 160.
ng/l 61,000.
M/l <5.
Well
MW104
6.5
20,000.
150.
265.000.
14.
Well
MW115
11.0
46.900.
5.160.
60,000.
90.
Well
MW116
7.0
22.000.
5,300.
42,000.
<5.
Well
MW117
6.7
49.000.
2,460.
77.000.
3.900.
Well
MW119'
6.7
27.600.
12.700.
508,000.
4.500.
Well
MW126
6.5
21,500.
45.
21.000.
20.
Well
MW128
6.8
23,600.
15,520.
60.000.
<5.
Well
G20
6.7
32.000.
54.
50,000.
20.
Leachate
Well
NPGR5
NA
NA
1,850.
670,000.
28.
Sample concentration is the average for a triplicate sample.
NA *= Not analyzed
ro
o
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121
majority of compounds with high vapor pressures such as vinyl chloride, pass
through this column and are thus undetected. The POC and POX methodolo-
gies by comparison used no traps and thus all of the compounds purged would
have been detected. Secondly, the discrepancy between TOX, which should
be as high or higher than POX can potentially be explained through handling
techniques normally employed with the TOX sample. TOX is typically run well
beyond the normal holding time for POC and POX. TOX samples are typically
collected in large mouth sample containers where head space is allowable.
TOX samples are also opened and poured at the time of analysis. All of these
conditions promote the loss of volatile compounds especially the type of light
molecular weight compounds in question here.
-------
REFERENCES
1. Reynolds, Stephen D., "Review of the Geology and Hydrogeology of the
Acme HCRA Landfill," June 1, 1987.
2. Harding Lawson Associates Report, "Implementation of Ground-water
Monitoring Plan Acme Landfill," February 4, 1986, Page 6.
3. Dibblee, Jr., Thomas W., Preliminary Geologic Map of the Port Chicago
Quadrangle, Solano and Contra Costa Counties California, USGS Open
File Report 81-108, 1981.
4. Ibid.
5. Simms, J.D., Fox, Jr. J.K., Barlow, J.A., and Helley, E.J., Preliminary
Geologic Map of Solano County and Parts of Napa, Contra Costa,
Marion, and Volo Counties, California, USGS Misc. Field Studies Map
MF-484, 1973.
6. HLA Report, February 4, 1986, Page 4.
7. Dibblee 1981.
8. HLA Report, February 4, 1986, Page 3.
9. Ibid Page 4.
10. RWQCB "Revised Self-Monitoring Program for Acme Sanitary Landfill,"
Part A, 1978, Page 4;
11. Cited in the 1982, 1983 and 1984 cover letters to the Annual Self-
Monitoring Report.
12. Ibid 1984 report.
13. HLA Report "Revised Groundwater Monitoring Plan Acme Landfill,"
August 27, 1985, Total 1, Page 7.
14. "RCRA Ground-Water Monitoring Technical Enforcement Guidance
Document (TEGD)," September 1986, page 25.
15. HLA Report, February 4, 1986, Pages 7 and 8.
16. Cited in 1982, 1983, 1984 and 1985 Annual Self-Monitoring Reports.
17. HLA Report, February 4, 1986, Page 22.
18. Laitinen, Herbert A., "Chemical Analysis," McGraw-Hill, 1960.
-------
18. Laitinen, Herbert A., "Chemical Analysis," McGraw-Hill, 1960.
19. Whittaker, E.L., "Test Procedure for Gross Alpha Particle Activity in
Drinking Water Inter-laboratory Collaborative Study," October 1985.
20. Acme Fill Part B Application, Section C, Page 28.
21. Ibid, Page 29.
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APPENDICES
'A .
A ANALYTICAL DATA AND METHODS
B DRAGER TUBE DATA
C PROCEDURES FOR OPERATING ISCO WATER LEVEL RECORDERS
D OCTOBER 1,1986 INSPECTION REPORT
E COMPARISON OF STATE AND FEDERAL MONITORING REQUIREMENTS
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APPENDIX A
ANALYTICAL DATA AND METHODS
Table A-1 Sample Preparation, Analytical Techniques and Methods
Table A-2 Organic Results
Table A-3a Organic Limits of Quantitation - NEIC
Table A-3b Organic Limits of Quantitation - Contract Laboratory
Table A-4 Total Metal Results
Table A-5 Field Measurements and General Analytical Parameters
-------
Table A-1
SAMPLE PREPARATION AND ANALYTICAL TECHNIQUES AND METHODS
Acme/Vine Hill
Parameter
PreparationTechnique
AnalysisTechnique
MethodReierence
Specific Organic Constituents
Volatiles
Semi-volatiles
Pesticides/PCB
Herbicides
Dioxins and
Diobenzolurans
Purge and trap
Methylene chloride extraction
Methyiene chloride/hexane extraction
Diethyl ether extraction/methylation
Methylene chloride/hexane extraction
Non-specific Organic Parameters
POX None
TOX Carbon absorption
POC None
NPOC Acidify and purge
Elemental Constituents
Mercury Wet digestion for dissolved and total
As, Pb, Se and Tl Acid digestion for total
Other Elements Acid digestion for total
Field Measurements
Conductance None
pH None
Turbidity None
General Constituents
Nitrate None
Sulfate None
Chloride None
Nitrite None
Bromide None
Fluoride None
Sulfide None
Phenol Automated distillation
Cyanide Manual distillation
Gas Chromatography - Mass Spectroscopy
Gas Chromatography - Mass Spectroscopy
Gas Chromatography with Electron Capture Detection
Gas Chromatography with Electron Capture Detection
Gas Chromatography - Mass Spectroscopy
Purgable combusted, Microcoulometry
Carbon combusted, Microcoulometry
Purgable combusted, Non-dispersive Infrared
UV Persulfate, Non-dispersive Infrared
Cold Vapor Atomic Absorption Spectroscopy
Furnace Atomic Absorption Spectroscopy
Inductively Coupled Plasma Emission Spectroscopy
Electrometric, Wheatstone Bridge
Potentiometry
Nephelometric
Ion Chromatography
Ion Chromatography
Ion Chromatography
Ion Chromatography
Ion Chromatography
Ion Chromatography
lodometric, Titration
Colorimetric, Distillation, Automated 4-AAP
Pyridine Pyrazolone Colorimetry
CLP Method (a)
CLP Method
CLP Method
Method 8150 (b)
Method 8280 (b)
EPA 600/4-84-008
Method 9020 (b)
No reference
Method 415.1 (c)
CLP Method
CLP Method
CLP Method
Method 120.1 (c)
Method 150.1 (c)
No reference
EPA Method 300.0
EPA Method 300.0
EPA Method 300.0
EPAMethod 300.0
EPA Method 300.0
EPA Method 300.0
Method 9030 (b)
Method 9066 (b)
Method 9010 (b)
a Contract Laboratory Program, IFB methods
b Test Methods for Evaluating Solid Wastes. SW-846
c Methods for Chemical Analysis of Water and Wastes, EPA-600/4-79-020
-------
I
ro
Table A-2
SPECIFIC ORGANIC CONSTrTUENTS (a)
Acme Landfill
STATION' MW104<"> MW115 MW116 MW117
SMONO. MQB417 MQB413 MQB412 MQB415
COMPOUND ug/L ug/L ug/L ug/L
Carbon disullide ND d ND ND 3. 0
Benzene 5. 3, 0 ND ND
Chtorobenzene 2. ND ND ND
1.2-Dichtorobenzene 2. ND ND ND
1,4-Dichlorobenzene 4. ND ND ND
Toluene 2. 13. ND 5.
Xylenes 10. ND ND ND
Ethytoenzene 7. ND ND ND
1,2.4-Trimethylbenzene 15. ND ND ND
1.3.5-Trimethylbenzene 3. ND ND ND
Tetrahyrofuran ND ND ND ND
Vinyl acetate ND 84. ND ND
di-n-Butyl phthalate ND MD ND 3. 0
Benzoicacid ND ND ND 4. 0
Phenol ND 100. 2. 0 ND
LOG FACTORS (1)
VOLATILE 1X 1X 1X 1X
SEMIVOLATILE NA g 2X 2X 2X
PESTICIDE NA g IX 1X NA I
DIOXINSANDFURANS NA/) NA g NA g NA g
MW119O
MQB405
ug/L
2. 0
4. e
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
IX
2X
IX
1X
G6
MQB402
ug/L
ND
ND
ND
ND
ND
ND
ND '
ND
ND
ND
ND
ND
2. 0
ND
ND
1X
2X
1X
IX
NPGRS^
MQB410
ug/L
ND
2.
ND
2.
17.
7.
7.
6.
5.
2.
150.
ND
ND
ND
ND
IV
2X
NA
•it A
NA
NA
e
e
e
g
g
h
a) MW126 MW 128, and MW G-20 were analyzed but not listed since no HSL compounds were found.
b) Note- Sample was analyzed at NEIC using Purge and Trap GCMS. SW-846 Methods 5030/8240.
c) Monitoring well 119 was sampled and analyzed in triplicate (MOB405. 406. 407); results were averaged for report.
d) Compound was not detected., ..-•,* • .- ,i™^,
e) Estimated concentration. Compound was detected, but the concentration was below the Limit of Quantitation (LOQ).
f) LOG Factor is the factor that the LOO must be multiplied by to correct the LOQ for dilutions.
g) Sample not analyzed.
h) Analysis not requested.
i) Low volume collected; possibly insufficient sample for pesticide analysis.
-------
H-0
Table A-3a
LIMITS OF QUANTITATION
NEIC ORGANIC RESULTS
Acme Landfill
Martinez, California
Limit Qf
Quantitation
(ug/L)
Volatile Compounds (Purge Trap)
Bromomethane 20.
Chloromethane 30.
Bromodichloromethane 2.
Dibromochloromethane 2.
Bromoform 2.
Chloroform 2.
Carbon tetrachloride 2.
Chloroethane 20.
1,1-Dichloroethane 2.
1,2-Dichloroethane 2.
1,1,1-Trichloroethane 2.
1,1,2-Trichloroethane 2.
1,1,2,2-Tetrachloroethane 2.
1,1-Dichloroethene 2.
trans-1,2-Dichloroethene 2.
Trichloroethene 2.
Tetrachloroethene 2.
Methylene chloride 4.
Vinyl chloride 20.
1,2-Dichloropropane 2.
1,2-Dibromo-3-chlbropropane 2.
Benzene 2.
Chlorobenzene 2.
1,2-Dichlorobenzene 2.
1,3-Dichlorobenzene 2.
1,4-Dichlorobenzene 2.
1,2,3-Trichlorobenzene 2.
1,2,4-Trichlorobenzene 2.
Toluene 2.
Xylenes 2.
Ethylbenzene 2.
n-Propylbenzene 2.
1,2,4-Trimethylbenzene 2.
1,3,5-Trimethylbenzene 2.
2-Butanone 10.
Tetrahydrofuran 2.
Styrene 10.
-------
Table A-3b
LIMITS OF QUANTITATION FOR ORGANIC COMPOUNDS
Acme Landfill
Martinez, California
I
-p>
Volatile Compounds
ug/L
Volatile Compounds
ug/L Semi-Volatile Compounds
ug/L Semi-Volatile Compounds
ug/L
Bromomethane 10.
Dibromomethane 5.
Chloromethane 10.
lodomethane 5.
Bromodichloromethane 5.
Dibromochloromethane 5.
Dibrochlorodifluoromethane 5.
Trichlorofluoromethane 5.
Bromoform 5.
Chloroform 5.
Carbon tetrachloride 5.
Carbon disulfide 5.
Chbroethane 10.
1.2-Dibromoethane 5.
1.1-Dichloroethane 5.
1,2-Dichloroethane 5.
1,1,1-Trichloroethane 5.
1.1,2-Trichloroethane 5.
1.1.1.2-Tetrachloroethane 5.
1,1.2.2-Tetrachloroethane 5.
1,1-Oichloroethene 5.
trans-1,2-Dichloroethene 5.
Trichloroethene 5.
Tetrachloroethene 5.
Methylene chloride 5.
Vinyl chloride 10.
1,2-Dichloropropane 5.
1,2,3-Trichloropropane 5.
1,2-Dibromo-3-chloropropane 5.
3-Chloropropene 5.
trans-1,3-dichloropropene 5.
1.4-Dichloro-2-butena 50.
Benzene 5.
Chbrobenzene 5.
Toluene 5.
Xylenes 5.
Ethylbenzene 5.
2-Methyl-1-propanol 50.
Acetone 10.
2-Butanone 10.
2-Hexanone 10.
4-Methyl-2-pentanone 10.
2-Chloroethyl vinyl ether 10.
Ethyl cyanide 50.
1.4-Dioxane 5.000.
Styrene 5.
Vinyl Acetate 10.
Crotonalydehyde 50.
Semi-Volatile Compounds
Pentachloroethane 10.
Hexachloroethane 10.
1,2-Dibromo-3-chloropropane 10.
Hexachloropropene 10.
trans-4-Dichloro-2-buten« 10.
2-Hexanone 10.
Acetophenone 10.
4-Methyl-2-pentanone 10.
Aniline 10.
4-Chloroaniline 10.
2-Nitroaniline 50.
3-Nitroaniline 50.
4-Nitroaniline 50.
4-Methyl-2-nitroaniline 10.
3,3'-Dichlorobenzidine 20.
3.3'-Dimethylbenzidine 100.
3.3'-Dimethoxybenzidine 10.
Benzyl alcohol 10.
1,2-Dichlorobenzene 10.
1,3-Dichlorobenzene 10.
1,4-Dichlorobenzene 10.
1,2,4-Trichlorobenzene 10.
1,2.4.5-Trichlorobenzene 10.
Pentachlorobenzene 10.
Hexachlorobenzene 10.
Pentachloronitrobenzene 10.
Nitrobenzene 10.
Dinitrobenzene 1,0.
2,4-Dinitrotolulene 10.
2.6-Dinitrotolulene 10.
N-Nitrosodimethylamine 10.
N-Nrtrosodielhylamine 10.
N-Nitrosomethylethylamine 10.
N-Nitrosodiphenylamine and/or
Diphenylamine 10.
N-Nilroso-di-n-butylamine 10.
alpha, alpha-
Dimethylphenethylamine 50.
1-Naphthy famine 10.
2-Naphthylamine 10.
bis(2-Chloroethyl) ether 10.
4-Chlorophenyl phenyl ether 10.
4-Bromophenyl phenyl ether 10.
bis(2-Chloroisopropyl) ether 10.
bis(2-Chloroethoxy) methane 10.
Hexachloroethane 10.
Hexachlorobutadiene 10.
Hexachlorocyclopentadiene 10.
bis(2-Ethylhexyl) phthalate 20.
Butyl benzyl phthalate 10.
di-n-Butyl phthalate 10.
di-n-OctyI phthalate 10.
Diethyl phthalate 10.
Dimethyl phthalate 10.
Acenapthene 10.
Acenapthylene 10.
Anthracene 10.
Benzo(a)anthracene 10.
7.12-Dimethylbenz(a)anthracene 10.
Benzo(b)fluoranlhene and/or
Benzo(k)f luoranthene 10.
Benzo(g,h,i)perylene 10.
Benzojajpyrene 10.
Dibenzo(a,e)pyrene 10. a
Dibenzo(a.h)pyrene 10. a
Dibenzo(a.j)pyrene 10. a
Chrysene 10.
Dibenzo(a,h)anthracene 10.
Dibenzofuran 10.
Fluoranthene 10.
Pyrene 10.
Indeno (1.2,3-c,d)pyrene 10.
Isophorone 10.
Naphthalene 10.
2-Chtoronaphthalene 10.
2-Methylnaphthalene 10.
Phenanthrene 10.
3-Methylcholanthrene 10.
Methapyrilene 50.
5-Nitro-o-toluidine 10.
o-Toluidine 10.
2-Picoline 10.
N-Nilrosopiperidine 10.
Safrole 10.
1,4-Naphoquinone 10.
Pyridine 10.
Methyl Methacrylate 10.
Ethyl Methacrylate 10.
p-Dimethylaminoazobenzene 10.
4-Aminobiphenyl 10.
Pronamide 10.
Isosafrole 10.
N-Nitrosopyrrolidine 10.
Clyclophosamide 10.
Phenacetin 10.
Methyl methane sulfonate 10.
4,4'-Methylene-bis
(2-chloroaniline) 10.
N-Nitrosomorpholine 10.
Benzoic Acid 50.
Phenol 10.
2-Chlorophenol 10.
2.4-Dichlorophenol 10.
2,6-Dichlorophenol 10.
2.4.5-Trichlorophenol 50.
2,4.6-Trichlorophenol 10.
2,3.4.6-Tetrachlorophenol 10.
Pentachlorophenol 50.
4-Chloro-3-methylphenol 10.
nnt ai/ailahlf at tho time* nf analysis
-------
Table A-4
DISSOLVED AND TOTAL METALS ANALYSIS RESULTS
Acme Landfill
Station:
SMO No.:
Element
Al
Sb
As
Ba
Be
Cd
Ca
Or
Co
Cu
Fe
Pb
Mg
Mn
Hg
Ni
K
Se
Ag
9
Na
Tl
Sn
V
Zn
MW104"
MQB417
Dissolved Total
Value. ug/L Value. ug/L
<200. b
<1.3
6.8
2.480.
<3.
<4.
57.800!
<20.
<9.
<10.
4.080.
<40.
227.000.
1470.
<.1
<100.
443,000.
<3.4
<10.
3.720.000.
<300.
NA *
40.
250.
<300.
<3.
11.
2.370.
<2.
<9.
78.500.
<20.
<50.
<30.
10,000.
<100.
236,000.
1340.
<.1
<200.
528,000.
<6.
<8.
4.360,000.
<700.
10.
170.
MW115
MQB413
Dissolved Total
Value. ug/L Value, ug/L
297.
<300. d
<3. d
1.230.
<1.
<25. d
2.810.000.
<9.
<23.
<7.
144.
<25.
181.000. d
5.
<.4
<20.
296.000. c
<25. d
7.
12.400,000.
<10. d
<32.
19.
19.
5.600. c.d
17.
<50.
1.230. c-d
1.
<5. d
2.860.000.
<9.
<23.
12
4.380. c
<25. d
195.000. c
61. c
<.4 d
36.
259.000. c
<25. d
<7.
12.800.000.
<50. d
<32.
37.
45.
MW116
MQB412
Dissolved Total
Value. ug/L Value ug/L
58.
<30. d
27. d
846.
<1.
<2. d
496.000.
<9.
<23.
<7.
65.
12.
474.000. d
2,820.
<.4
<20.
158.000. c
<25. d
<7.
4.370,000.
<10. d
<32.
62.
68.
15.700. c-d
<4.
<45. d
895. c'd
<1
<5. d
482.000.
37.
<23.
25.
20.100. c
<25. d
518.000. c
3,010. c
<.4
67.
156.000. c
<25. d
<7.
4,740,000.
<10.
<32.
95.
79.
a Note: Sample analyzed at NEIC
b Sample concentration is less than (<) the value shown.
c Estimated value; interference present causing possible bias
d Batch spike sample recovery was not within control limits indicating possible bias.
e Not analyzed.
i
CJl
-------
cr>
Table A-4 (Cont.)
SMO No.:
Station:
Element
Al
Sb
As
Ba
Be
r-A
\^j
Ca
Cr
Co
Fe
Pb
Mg
Mn
Hg
Ni
K
Se
Ag
Na
^
Sn
y
Zn
MQB415
MW117
Dissolved Total
Value. ug/L Value. ug/L
122.
<60. b.d
<45. d
785.
<.4 d
504.000.
<23.
<45.
<25.
478.000. d
410.
<.4 d
<20.
259.000. c
<25. d
4,440.00o!
<50. d
<32.
18.
2.380. c.d
<60.
54. ^
774. c.d
<5. d
720.000.
<23.
12.
14.200. c
<25. d
1.860.000. c
449. c
<.4 d
20.
246.000. c
<25. d
m-
10,800,000.
<10. d
<32.
24.
31.
MQB405.
MW
Dissolved
Value, ug/L
145.
<6. d
20. d
1.800.
<2. d
494,000.
11.
<23.
<23.
527.
<20.
1,130.000. d
1.440.
<.4 d
36.
219.000. c
<25. d
^
• 7.330.000.
<10. d
<32.
<23.
84.
406. 407
119*
Total
Value. ug/L
3.510.
<4.
<10.
1.670.
-------
Table A-4 (Cont.)
SMO No.: MQB409
Station: MW 128
Dissolved Total
Element Value. ug/L Value. ug/L
Al
Sb
As
Ba
Be
Cd
Ca
Cr
Co
Cu
Fe
Pb
Mg
Mn
Hg
• »f
Ni
K
Se
Ag
Na
Tl
Sn
v
Zn
a
b
c
d
e
77.
<60. b ,d
15. d
2.700.
<1.
<2
444.000.
<9.
<23.
5,86o!
<20. d
870,000. d
1.020.
<4 d
<20.
82,100. c
<25. d
4,680,000.
<10. d
<32.
32!
132. c.d
<60.
<10.
2.920. c.d
<1.
<5.
392.000.
<9.
<23.
<7.
13.000. c
<25. d
969.000. c
926. c
<4 d
<20.
73.700. c
<20. d
5.260.000.
<50. d
<32.
<15.
<11.
MQB402
MWG6
Dissolved Total
Value. ug/L Value, ug/L
111.
<60. d
<10. d
366.
<1.
<5.
124,000.
<9.
<23.
<7.
<45.
<5.
80.600. d
169.
.3 d
<20.
5.020. c
<5. d
97.100.
<2. d
<32.
<15.
23.
5.360 c.d
<4.
<10. d
390. c.d
<1.
<5. d
111,000.
<9.
<23.
7.
5.220. c
8.3 d
70.800. c
177. c
<2 d
<20.
5.010. c
<5. d
88.000.
<2. d
<32.
<15.
59.
MQB414
MWG203
Dissolved Total
Value, ug/L Value, ug/L
600.
<1.3
19.3
411.
<3.
<4.
513.000.
<20.
<9.
<10.
2.870.
<40.
960,000.
NA
<.1
<100.
357.000.
4.
6.120.000.
<300.
NAe
90.
100.
2.500.
<3.
7.
493.
<2.
<9.
509.000.
<20.
<50.
<30.
17.000.
<100.
1.040.000.
NA
<.1
<200.
561.000.
<8.
<30.
6.750.000.
<700.
NA
110.
69
Note: Sample analyzed at NEIC
Sample concentration is less than (<) the value shown.
Estimated value; interference present causing possible bias
Batch spike sample recovery was not within control limits indicating possible bias.
NA: Not analyzed.
-------
33
CO
Station:
SMO No.:
Table A-4 (Contd.)
NPGR5a
MQB410
Element
Al
Sb
As
Ba
Be
Cd
Ca
Cr
Co
Cu
Fe
Pb
Mg
Mn
Hg
Ni
K
Se
Ag
Na
TI
Sn
V
Zn
Dissolved
Value. ug/L
NA e
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Total
Value. ug/L
<300. c
<3.
12.
2.900.
<2.
<9.
304.000.
20.
<50.
<30.
77.000.
<100.
325.000.
860.
<.1
<200.
821.000.
<8.
<30.
2.880.000.
<700.
NA
140.
410.
Note: Sample concentration is less than X at 99%
confidence.
b Sample concentration is less than (<) the value shown.
c Estimated value; interference present causing pos-
sible bias.
d Batch spike sample recovery was not within control
limits indicating possibe bias.
d Duplicate analysis not within control limits.
e Not analyzed.
-------
Table A-5
GENERAL CONSTITUENT ANALYSIS
Acme Landfill
Station:
SMO No.
Parameter
pH
Conductance
Temperature
Turbidity
POX
TOX
POC
NPOC
Bromide
Chloride
Nitrate
Sulfate
Nitrite
Cyanide
Phenol
Sulfide
Fluoride
Units
Units
umhos/cm
•c
NTU
ug/LCI
ug/LCI
ug/LC
ug/LC
mg/L
mg/LCI-
mg/LN
mg/L S04=
mg/L
ug/L
ug/L
mg/L
mg/LF-
MW 104a
MQB417
Value
6.5
20.000.
16.
52.
14.
NA c
150.
265.000.
<.5
9,200.
<.6
1.6
<.3
NA
NA
NA
NA
MW115
MQB413
Value
11.0
46,900.
21.
72.
90.
335.
5,160.
60,000.
58.
18,800.
<.3
1,380.
<.3
<10.
<50.
290.
32.
MW116
MQB412
Value
7.0
22,000.
20.
116.
<5.
115.
5,300.
42,000.
23.
7,100.
<.3
34.
<.3
<10.
<50.
190.
16.
MW117
MQB415
Value
6.7
49,000.
20.
130.
3,900.
400.
2.460.
77,000.
50.
18,600.
<.3
630.
<.3
NA
<50.
36.
34.
MW119
MQB405,
406, 407
Value6
6.7
27,600.
20.
208.
4,500.
483.
12,700.
508,000.
35.
11,700.
<.3
22.
<.3
20.
<50.
98.
31.
a Note: Sample analyzed at NEIC
b Average of replicate analyses
c NA: Not analyzed
-------
I •
t—»
o
Table A-5 (conld.)
Station:
SMO No.
Parameter
PH
Conductance
Temperature
Turbidity
POX
TOX
POC
NPOC
Bromide
Chloride
Nitrate
Sulfate
Nitrite
Cyanide
Phenol
Sulfide
Fluoride
Units
Units
umhos/cm
•c
NTU
ug/LC
ug/LC
ug/LC
ug/LC
mg/L
mg/LCI-
mg/LN
mg/L SO4=
mg/L
ug/L
ug/L
mg/L
mg/LF-
MW126a
MQB416
Value
6.5
21,500.
20.
122.
20.
NA
45.
21,000.
<.5
8,200.
<.6
600.
<.3
<.3
NA
NA
NA
MW128
MQB409
Value
6.8
23.600.
19.
128.
<5.
NA
15,520.
60,000.
22.
7,300.
<.3
<1.
<.3
<10.
<50.
<1.
17.
G6
MQB402
Value
6.9
1,650.
14.
88.
<5.
74.
160.
61,000.
<1.
153.
0.5
38.
<.3
<10.
<50.
58.
2.
G-20a
MQB414
Value
6.7
32,000.
19.
NA
20.
NA
54.
50,000.
50.
13,000.
<.6
850.
<.3
NA
NA
NA
NA
NPGR5*
MQB419
Value
NA
NA
NA
NA
28.
NA
1.850.
670.000.
<.5
26.
26.
<.6
<.3
NA
NA
NA
NA
a Note: Samples analyzed at NEIC
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APPENDIX B
DRAGER TUBE DATA
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B-l
i DRAGER Tube Vinyl Chloride 0.5/a . (672MH
2 Standard 'inqe of meeeurement 0 5 to 3 ppm vinyl chloride
(20°C. 1013 mbar)
3 Number of ttrokee of the n = 20
ORAGER gee detector pump n =• 5
4 Relative etenderd deviation istoi0%
5 Deeertptlon
Scale tube • double tube (pretube and indicating tube are |0inedtoge»«
with a piece of tubing before testing) • pale grey precieanse i«yv
(pretube). reagent: alkali hydroxide • yellowish brown oxidation layer*
the pretube. reagent: chromate • bluish grey indicating layer (mdicadnf
tube), reagent: bromopnenoi blue • colour change to yellow.
6 Reaction principle
(in the oxidation layer)
CH,-CHCI + Cr»* — HC1
Vinyl chloride Hydrogen chloride
(in the indicating layer)
HCI > Bromophenol blue -» Yellow reaction product
7 Croee-aentltlvlty
Other chlorinated hydrocarbons also react, but the sensitivity o( indicium
is different.
Examples:
. i ppm 1.1 -dichloroethylene Indication 2 ppm
1 ppm chlorobenzene Indication app. 0 5 to 1 ppm
10 ppm perchlorethylene Indication app. 0 S ppm
10 ppm tnchloroelhylene Indication app. 2 ppm
10 ppm chloroform No indication
10 ppm carbon tetrachlonde No indication
10 ppm 1,1.1 -tnchloroethane No indication
Ally! chloride is measured with 15 strokes of the gas detector puma
Indication (i.e. numerical value on scale) multiplied by a factor of 2 give)
ppm ally! chloride (deviation ± 50%).
Dichlorobenzene (ortho and para) is measured with 1 pump strokt
Indication multiplied by a factor of 5 gives ppm dichlorobenzene (deviation
± 50%). Hydrocarbons should have scarcely any effect on the vinyl chlondt
indication; up to the present, the following measurements have been mad*
10 ppm ethylene. no influence, as also 10 ppm butadiene. Acetont,
heptane, methanol had no influence on the indication up to a concentration
of 100 ppm. Chlorine and hydrogen chloride are absorbed m the precleanM
layer (alkali hydroxide) and do not, therefore, interfere.
8 Extension of the rang* of meeeurement
With n - 5 strokes: 1 to 6 ppm vinyl chloride
With n - 20 strokes. 0 25 to 1 5 ppm vinyl chloride
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APPENDIX C
PROCEDURES FOR OPERATING ISCO WATER LEVEL RECORDERS
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C-1
Appendix C
PROCEDURES FOR OPERATING ISCO WATERLEVEL RECORDERS
1. EPA contract personnel assembled the ISCO meters using Model 1870
meters and 1/4-inch ID (inside diameter) stainless steel tubing.
2. The meters were calibrated as follows:
(a) Chart recorder was set to a speed of 4 inches per hour.
(b) The bubbler was adjusted to release one air bubble per second.
(c) The end of the stainless steel tubing was lowered into a graduated
cylinder containing distilled water. The tip of the tubing was moved
up and down in the water column while the LED display on the
ISCO meter was calibrated for depth of immersion.
3. The tubing was lowered into the well to a depth approximately and
11/2 feet below the water surface as indicated by the ISCO calibrated
display (1.500).
4. The date, time and ISCO display were recorded on the strip chart.
5. The water level was verified with the Interface Probe and recorded. The
probe was decontaminated according to the same procedures identified
previously.
6. The wellhead was sealed with a plastic bag around both the well and the
ISCO meter and taped. The tape was signed by the EPA contractor to
verify security between water level measurements.
7. Steps 4, 5 and 6 above were repeated two times daily to verify the
accuracy of the ISCO meters [Table 5].
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APPENDIX D
OCTOBER 1,1986 INSPECTION REPORT
'' ' ''5" *'"' ' ''-""* ': ' '•»<•";!
<:• ' /". ''..^s
. '. ,-*.' T .; .f «.,. ,; ••.,-, .
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U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, It 60604-3590
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U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, IL 60604-3590
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