r* UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
r^ AUGUST 3, 1988
-fe. UPDATE OF THE HAZARDOUS WASTE GROUND-WATER TASK FORCE EVALUATION
^ OF U.S. DEPARTMENT OF ENERGY - ROCKY FLATS PLANT
The Hazardous Waste Ground-Water Task Force (Task Force) of
the United States Environmental Agency (EPA) in conjunction with
the Colorado Department of Health (CDH) conducted an evaluation
of the ground-water monitoring program at the U.S. Department of
Energy (DOE) Rocky Flats Plant, Golden Colorado. The onsite
evaluation was conducted from March 31 through April 16, 1987.
The Rocky Flats Plant 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
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 265 and
Part 265 of the Colorado hazardous waste regulations (6 CC
1007-3)
- Evaluate the ground-water monitoring program described in
the RCRA Part B permit application for compliance with 40
CFR 270.14(c) and Part 100.41(c) of the Colorado hazardous
waste regulations (6 CC 1007-3);
- Determine if the ground-water at the facility contains
hazardous waste and/or hazardous constituents.
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The Task Force prepared the accompanying report on its
evaluation, which revealed a number of deficiencies in the
ground-water monitoring well network and program at the Rocky
Flats Plant. EPA Region VIII and CDH personnel had previously
identified many of the deficiencies noted in the Task Force
report. Because of the inadequacy of the monitoring system at
the facility and known releases from the solar evaporation
ponds, a Compliance Agreement between DOE, CDH and EPA was
completed and signed in July 1986. The Agreement required an
alternate ground-water monitoring program [265.90(d)l at the
present landfill and the west spray field. An assessment
ground-water monitoring program [40 CFR 265.93(d)] was required
at the evaporation ponds. The purpose of this update is to
summarize actions taken by EPA, CDH and DOE/Rockwell since the
Task Force evaluation was conducted.
Installations of new wells in 1986 and 1987 were the first
steps in upgrading the Rocky Flats ground-water monitoring
program to meet the requirements of the regulations and the
Compliance Agreement. Although new wells have been installed
and monitoring procedures have been modified, the ground-water
monitoring program at the regulated units is still inadequate.
Evaluation of the ground-water monitoring programs at the
Rocky Flats Plant is ongoing and is being accomplished through
review of DOE/Rockwell submittals and by frequent site
inspections by the regulatory agencies. Since the Task Force
compliance evaluation, reviews of the following documents, which
address ground-water monitoring, were completed by CDH and EPA
Region VIII:
- RCRA Part B Operating Permit Application, November 1986
- RCRA Part B Post-Closure Care Permit Application, November
1986
- Remedial Investigation for the High Priority Sites (881
Hillside), December 1987
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CDH and EPA Region VIII issued a notice of deficiency (NOD)
to the facility in September 1987 for the Operating Permit
Application. A second NOD was issued in January 1988 for the
Post-Closure Care Permit Application. Both NODs addressed
ground-water monitoring program deficiencies, including those
identified during the Task Force evaluation. DOE/Rockwell
resubmitted the Operating Permit Application in December 1987.
The ground-water monitoring section was omitted at the request
of the regulatory agencies. This section is required only in
the Post-Closure Care Permit Application, ^nich is currently
being revised by DOE/Rockwell and is scheduled to be submitted
in September 1988.
Under the Compliance Agreement, the DOE is also required to
investigate all areas of possible contamination. To date,
DOE/Rockwell has implemented investigations at the 881 Hillside
High Priority Area and the 903 Pad, Mound and East Trenches High
Priority Areas. RCRA-quality ground-water monitoring wells were
installed in these areas during 1987.
CDH and EPA recently reviewed work performed in the 881
Hillside, and CDH inspected ground-water sampling operations at
the 881 Hillside in October and November 1987. The review
revealed problems, primarily with sample collection and
analysis, and quality control/quality assurance. CDH and EPA
are requiring DOE/Rockwell to address these problems.
This completes the Hazardous Waste Ground-Water Task Force
evaluation of the Rocky Flats Plant.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUND-WATER TASK FORCE
EPA-330/2-88-051
GROUND-WATER MONITORING EVALUATION
U.S. Department of Energy - Rocky Flats Plant
Golden, Colorado
July 1988
Steven Sisk
Project Coordinator
National Enforcement Investigations Center
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CONTENTS
EXECUTIVE SUMMARY
INTRODUCTION 1
SUMMARY OF FINDINGS AND CONCLUSIONS 5
GROUND-WATER MONITORING DURING INTERIM STATUS 5
Ground-Water Sampling and Analysis Plan 6
Monitoring Well Locations and Construction 7
Sample Collection and Handling Procedures 8
Sample Analysis and Data Quality Evaluation 9
GROUND-WATER MONITORING PROGRAM PROPOSED
FOR RCRA PERMIT 10
TASK FORCE SAMPLING AND DATA EVALUATION 10
TECHNICAL REPORT
INVESTIGATIVE METHODS 13
RECORDS/DOCUMENTS REVIEW 13
FACILITY INSPECTION 14
LABORATORY EVALUATION 14
WATER LEVEL AND WELL DEPTH MEASUREMENTS 14
SAMPLE COLLECTION 16
FACILITY DESCRIPTION 24
GENERAL DESCRIPTION 24
WASTE PRODUCTION 25
Hazardous Waste Generation 25
Radioactive Waste Generation 28
Radioactive Mixed Waste Generation 29
Sanitary Waste Generation 29
Nonhazardous/Nonradioactive Refuse 29
WASTE MANAGEMENT PROCEDURES 29
Hazardous Waste 31
Radioactive Waste 31
Radioactive Mixed Waste 32
WASTE MANAGEMENT AREAS 33
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CONTENTS (cont.)
Units Requiring RCRA Ground-Water Monitoring 47
Solar Evaporation Ponds 47
West Spray Fields 49
Active Landfill 50
SITE HYDROGEOLOGY 52
HYDROGEOLOGIC UNITS 52
GROUND-WATER FLOW, DIRECTIONS AND RATES 58
SURFACE WATER HYDROLOGY 60
GROUND-WATER MONITORING DURING INTERIM STATUS 62
REGULATORY REQUIREMENTS 64
GROUND-WATER SAMPLING AND ANALYSIS PLAN 64
1981 Sampling and Analysis Plan 65
1986 Sampling and Analysis Plan 67
MONITORING WELL NETWORK 68
Number, Location and Construction of Monitoring Wells 68
ROCKWELL SAMPLE COLLECTION AND HANDLING
PROCEDURES 73
Water Level Measurements 73
Purging 74
Sample Collection and Preservation 75
Shipping and Chain-of-Custody 76
SAMPLE ANALYSIS AND DATA QUALITY ASSESSMENT 76
Analyses During Initial Year of Monitoring (1982) 77
Analyses During January 1983 Through December 1985 81
Analyses During 1986 83
Analyses During 1987 83
GROUND-WATER ASSESSMENT PROGRAM OUTLINE 86
GROUND-WATER MONITORING PROGRAM PROPOSED FOR
RCRA PERMIT 88
EVALUATION OF MONITORING DATA FOR INDICATIONS OF
WASTE RELEASE 91
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CONTENTS (Cont.)
EVAPORATION PONDS 91
WEST SPRAY FIELD 93
881 HILLSIDE 95
ACTIVE LANDFILL 97
ORIGINAL LANDFILL 98
REFERENCES
APPENDICES
A MEMORANDUM OF UNDERSTANDING BETWEEN EPA AND DOE F~*"
MANAGEMENT OF HAZARDOUS AND RADIOACTIVE MIXED WASTES
B SUMMARY OF LEAF vs. HODEL DECISION
C ANALYTICAL TECHNIQUES AND RESULTS FOR TASK FORCE
SAMPLES
D DOE GROUND-WATER MONITORING DATA FOR 1986
FIGURES
1 Site Location Map 2
2 Locations for Sampling Stations 11
3 Location Map for Water Level Measurements 15
4 Location Map for Sampling Stations 19
5 Plant Process Areas 26
6 Waste Management Units 46
7 Structure of Denver Basin 53
8 Surficial/Alluvium Geology 54
9 Generalized Geological Cross-Section 56
10 Surface Drainage and Retention Ponds 61
11 Interim Status Monitoring Well Network 69
12 Monitoring Wells in the Vicinity of the Surface Impoundments 94
in
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CONTENTS (Cont.)
TABLES
1 Purging and Sampling Data 17
2 Order of Sample Collection, Bottle Type and Preservative List 22
3 Typical Hazardous Wastes Generated at Rocky Flats 27
4 Typical Mixed Wastes Generated at Rocky Flats 30
5 Summary of Waste Management Units 34
6 Solar Evaporation Dimensions (from March 1987 Closure Plan) 48
7 Ground-Water Monitoring Parameters 89
8 Ground-Water Quality Near the Surface Impoundments 92
9 Ground-Water Quality Near the West Spray Area 95
10 Ground-Water Quality Near 881 Hillside 96
11 Ground-Water Quality Near the Active Landfill 98
12 Ground-Water Quality Near Original Landfill 99
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), as amended.* 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 spring of 1987, the Task Force investigated the U.S.
Department of Energy (DOE) Rocky Flats plant near Golden, Colorado
[Figure 1]. The onsite inspection was conducted from March 31 through
April 16, 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 the interim status ground-water
monitoring requirements of 40 CFR Part 265, as promulgated
under RCRA, and the equivalent Colorado 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) and the equivalent
Colorado regulations, as appropriate.
Determine if the ground water at the facility contains hazardous
constituents
Regulations promulgated under RCRA address hazardous waste management facility
operations, including ground-water monitoring, to ensure that hazardous waste con-
stituents are not released to the environment.
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Superior \b,.
DOE Rocky
J Flats Plant
Legend
Industrial/Business
D Open Space/Agricultural
Urban Residential
D Suburban Residential
(After Rockwell, November 1986)
Figure 1
Location Map Rocky Flats Plant
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The Rocky Flats plant is located on approximately 6,550 acres of
Federally owned land in northern Jefferson County, Colorado, approximately 16
miles northwest of downtown Denver. The plant, constructed in 1951, is
government-owned and contractor-operated (GOCO). Dow Chemical Company
(Dow) began operations in 1952 under the direction of the Atomic Energy
Commission. In 1975, responsibility for the plant was assigned to the Energy
Research and Development Administration, which was succeeded by DOE in
1977. Dow was the prime operating contractor at the facility from 1952 until
1975, when Rockwell International (Rockwell) was awarded the contract.
The major plant structures, including all production buildings, are located
within the plant security area of approximately 400 acres. The security area is
surrounded by a buffer zone of approximately 6,150 acres. Production activities
include fabrication of plutonium, uranium, beryllium and stainless steel
components for nuclear weapons. Other activities include chemical recovery
and purification of recoverable radionuclides, and research and development in
metallurgy, machining, assembly, nondestructive testing, coatings, remote
engineering, chemistry and physics.
Plant operations generate solid/liquid nonhazardous, hazardous,*
radioactive,** mixed radioactive (includes both hazardous and radioactive
components) wastes and polychlorinated biphenyl (PCB) waste material.
These wastes are handled in various ways, depending on the hazardous and/or
radioactive characteristics. Nonhazardous wastes, such as office trash, are
disposed of in an onsite landfill. Hazardous and mixed radioactive wastes are
currently either treated onsite to render them nonhazardous, reused within the
plant, stored onsite, or shipped offsite for recycling, treatment, storage and/or
disposal. Past disposal practices involved substantial onsite disposal of
hazardous and mixed radioactive waste.
Waste management activities at Rocky Flats have historically included
container storage, tank storage and treatment, surface impoundment storage
As defined in 40 CFR 261
Contains source, special nuclear or byproduct materials, as defined in the Atomic Energy
Act
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and treatment, land treatment, landfilling and incineration. Hazardous and
mixed radioactive wastes are currently regulated by the Colorado Department
of Health (CDH), which received final RCRA authorization in November 1984.
Although CDH has been delegated final authorization, it has not been
delegated authority to administer programs mandated in the RCRA Hazardous
and Solid Waste Amendments (HSWA) of 1984.
DOE submitted a RCRA Part B permit application to EPA and CDH in
November 1985 for waste handling operations at the Rocky Flats plant. CDH
personnel determined that the application was not complete because the permit
application did not acknowledge State authority over radioactive mixed wastes,
and subsequently informed DOE that they intended to deny the permit. This
action raised the issue as to what specific wastes/waste handling units were
subject to State and/or EPA requirements, and resulted in negotiations between
DOE, CDH and EPA. The negotiations resulted in a three-party Compliance
Agreement, which was signed on July 31, 1986. As a result of this agreement,
a revised Part B permit application was submitted to both EPA and CDH. The
revised Part B was being reviewed by the regulatory agencies during the Task
Force investigation.
On July 17, 1986 CDH submitted an application to EPA for formal
approval to regulate the hazardous components of radioactive mixed wastes.
CDH was granted the authority to regulate radioactive mixed wastes under
Section 3006 of RCRA (42 U.S.C. Section 6926) on October 24, 1986. DOE
submitted a revised Part B permit application to both EPA and CDH in
November of 1986, which was under review during the Task Force
investigation.
Treated wastewater discharges from the plant are regulated by a
National Pollutant Discharge Elimination System (NPDES) permit (No.
CO0001333) issued by EPA Region VIII. The Permit was issued pursuant to
regulations promulgated under the Clean Water Act.
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SUMMARY OF FINDINGS AND CONCLUSIONS
The findings and conclusions presented in this report reflect conditions
existing at the facility in April 1987. Actions taken by the State, EPA Region VIII
and DOE/Rockwell subsequent to April 1987 are summarized in the
accompanying update.
GROUND-WATER MONITORING DURING INTERIM STATUS
Task Force personnel investigated the interim status ground-water
monitoring program at the Rocky Flats plant for the period between November
1981, when applicable provisions of the RCRA regulations became effective
and April 1987, when the Task Force inspection was conducted. The interim
status monitoring program was administered by EPA from November 1981 until
November 2, 1984, when the CDH was simultaneously delegated interim and
final RCRA authorization. A RCRA-equivalent program was administered by
CDH after receiving authorization.
The Task Force investigation revealed that the principal shortcoming of
the interim status monitoring program was that a detection monitoring program
(rather than an assessment monitoring program) was implemented in 1981.
Although the detection monitoring program had substantial problems, DOE and
Rockwell personnel were aware that the regulated units (evaporation ponds)
had been leaking since the early 1960's. A ground-water quality assessment
program should have been implemented in accordance with 40 CFR 265.93.*
The release from the evaporation ponds was addressed by the July 1986
Compliance Agreement, and an assessment program was implemented in the
fall of 1986, as part of a site-wide geological and hydrological characterization
program.
The Task Force review of the detection monitoring program revealed
numerous instances of noncompliance by DOE/Rockwell with EPA and CDH
regulations. These included problems with the ground-water sampling and
Hereafter, "40 CFR" will be omitted from citations of EPA regulations.
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analysis plan, monitoring well construction and locations, and sample collection
and analysis, as discussed below.
Ground-Water Sampling and Analysis Plan
Under the EPA-administered program, DOE/Rockwell developed a
"Groundwater Monitoring Program Plan." The plan was submitted to EPA
Region VIII in November 1981 and was, ostensibly, followed until mid-1985,
when detection monitoring was suspended. After the Compliance Agreement
was completed in 1986, the first phase of the assessment program plan for the
evaporation ponds was presented in the "Draft Work Plan, Geological and
Hydrological Site Characterization" dated July 21, 1986. Sampling and
analysis procedures were described in a companion document titled "Draft
Project Operations Plan, Geological and Hydrological Site Characterization,"
dated July 25, 1986. Ground-water monitoring procedures in the Draft Project
Operations Plan (POP) superseded those in the 1981 plan.
Procedures in the 1981 plan were evaluated by Task Force personnel for
compliance with RCRA regulations; the Draft POP procedures were evaluated
for adequacy and completeness.
The 1981 plan did not comply with 265.92(a) because many necessary
details regarding sampling and analysis were omitted. Rather than stating
specific sampling and analysis procedures to ensure program consistency, the
monitoring plan cites multiple references, which in turn contain multiple
procedures for sampling and analysis. Neither the plan nor the cited references
contain procedures for: (1) making the required water level measurements;
(2) preserving samples for all required parameters and verifying samples are
properly preserved; (3) analyzing samples for total organic halogen, pesticides
and radionuclides; (4) shipping samples; and (5) chain-of-custody.
The 1981 plan also contained an outline for a ground-water quality
assessment program. The "outline" was, essentially, a recitation of the regula-
tions. It was, therefore, inadequate and did not comply with 265.93(a).
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Although the 1986 POP was better than the 1981 monitoring plan, it was
also incomplete and was being revised during the Task Force investigation.
The plan contained details about sample collection, handling, preservation,
shipping, analysis and chain-of-custody. More detail is needed, however,
regarding procedures for sampling slow-recharging wells, which are common at
the Rocky Flats plant. The POP needs to describe equipment decontamination
procedures, where samples are preserved and by whom, and list the sample
aliquots to be filtered. Also, the shipping procedures description needs to be
expanded beyond just referencing Department of Transportation regulations.
Monitoring Well Locations and Construction
The 1981 monitoring plan designated 17 wells for the interim status
program. The 17 wells were part of a 56-well network installed for other DOE
monitoring programs. Task Force personnel determined that the 17-well
network was inadequate for interim status monitoring and did not meet the
regulatory requirements.
Three of the designated RCRA monitoring wells (5-60, 5-71, and 18-74*)
were "dry" from at least 1975 through mid-1985, when detection monitoring was
suspended. RCRA regulations [265.91 (a)] require that the ground-water
monitoring system must be capable of yielding ground-water samples for
analysis. Thus, these three wells do not comply with the regulatory
requirements and should not have been designated as part of the monitoring
network.
The single designated upgradient well (1-66) is completed in a bedrock
aquifer flow zone and is about 5,000 feet from the evaporation ponds. The
uppermost aquifer at the Rocky Flats Plant includes the Rocky Flats Alluvium,
which overlies the bedrock zone monitored by the upgradient well. The Rocky
Flats Alluvium is monitored by several of the downgradient designated RCRA
wells. RCRA regulations [265.91 (a)(1)] require that the number, locations and
depths of upgradient wells be sufficient to yield ground-water samples that are
Wells are designated by a two-part numbering system, which includes a sequence number
followed by the year the well was installed. For example, the designation 5-60 indicates well
number 5 was installed in 1960.
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8
representative of background ground-water quality in the uppermost aquifer
near the facility. Therefore, the single upgradient well does not comply with the
regulations because the alluvial flow zones are not monitored. Furthermore,
because of the excessive distance to the well from the regulated units, samples
from the well may not be indicative of background ground-water quality.
None of the downgradient wells were installed at the limit of the waste
management area (defined as the waste boundary), as required by RCRA
regulations [265.91(a)(2)]. The closest wells were at least 200 feet from the
evaporation ponds.
The 17 designated RCRA wells were installed between 1960 and 1981.
Construction records are available for only 3 of the 17 wells. Therefore, for 14
of the wells, DOE/Rockwell cannot document whether the wells were cased in a
manner to maintain the integrity of the borehole, as required by 265.91 (c).
Further, the aquifer flow zone(s) monitored by the wells cannot be identified.
In 1986, DOE/Rockwell installed 70 new wells as part of the facility-wide
site characterization program outlined in the Compliance Agreement.
Construction documentation for the new wells is inadequate in some cases, and
contradictory, incomplete or inaccurate in others. The borehole diameter may
not be large enough to install an adequate sandpack in the annulus between
the casing and hole wall. Well construction data should be reviewed, corrected
if in error, and the adequacy of the wells evaluated before they are accepted as
fulfilling the Compliance Agreement or RCRA permitting requirements.
Sample Collection and Handling Procedures
During the inspection, water levels were measured in 38 wells and
samples were collected from 15 monitoring wells and one ground-water sump
(wet well) in order to evaluate DOE/Rockwell sample collection and handling
procedures. At each of the monitoring wells, Rockwell personnel measured the
water level, calculated the purge volume, purged the well, and made field
measurements for pH, specific conductance and water temperature.
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The sample collection and handling procedures followed by Rockwell
personnel are generally acceptable; however, Rockwell personnel were not
following all of the procedures in the sampling and analysis plan and chain-of-
custody procedures had not been implemented. The plan needs to be updated
to include the field procedures actually used. Problems were found with field
measurements for temperature and specific conductance. A noncalibrated
thermometer was being used to measure temperature, and the readings were
used for adjusting the conductance meter. This could result in erroneous
conductance data. Further, the conductance meter was not being properly
calibrated because the standards were found to be 15% to 30% below the true
value.
Sample Analysis and Data Quality Evaluation
Ground-water monitoring data obtained by Rockwell between November
1981 and April 1987 was evaluated for quality and completeness. Most of the
required RCRA analyses [265.92] conducted during this period were performed
by the Rockwell general laboratory in building 881. The general laboratory was
also evaluated during the Task Force inspection.
The evaluation of data and analytical procedures revealed numerous
problems that have or could have affected data quality. Pre-1986 analytical
data for parameters other than pesticides, total organic halogen (TOX) and
phenols are unreliable because of the lack of sample preservation and
protracted holding times. The data collected during the initial year of monitoring
were inadequate to establish the background concentrations or values required
by 265.92(c)(1).
Quadruplicate analyses for pH, specific conductance, TOX and total
organic carbon (TOG) were not made on samples from the upgradient well
during the initial year of sampling, as required by RCRA regulations
,265.92.(c)(2)]. In subsequent years, required quadruplicate analyses were not
made on samples from the downgradient wells.
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10
GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT
In November 1986, a revised Part B permit application was submitted to
EPA and CDH. The Part B proposed a detection monitoring program for a
10-well monitoring network, including four upgradient wells and six
downgradient wells on the point of compliance. The wells were installed in
1986 as part of the site characterization program. The point of compliance is
downgradient from not only the regulated units (closest one is about 5,000 feet),
but also all of the solid waste management units being investigated under the
site characterization program.
The proposed ground-water monitoring program does not comply with
State regulations [264.95 and 100.42(c)(7)] because the point of compliance is
improperly located; it needs to be adjacent to the regulated units (evaporation
ponds, present landfill and west sprayfield). Furthermore, the proposed
detection monitoring program, as defined in 264.98, is inappropriate for the
evaporation ponds because releases have been detected. Rather, a
compliance monitoring program, as defined in 264.99, or a corrective action
program, as defined in 264.100, needs to be proposed. Also, the rationale for
the proposed monitoring parameters is deficient and some improvements in the
sampling and analysis procedures are needed.
TASK FORCE SAMPLING AND DATA EVALUATION
During the inspection, Task Force personnel collected samples from 15
monitoring wells and a wet well to determine if the ground water contained
hazardous constituents* or other indicators of contamination [Figure 2]. The
wells were located near the evaporation ponds, the west spray field, 881
hillside, active landfill and an old landfill near the southwest corner of the
production area. Samples were drawn from the wells by Rockwell and EPA
contractor personnel. Monitoring data from the Task Force samples were
evaluated together with DOE/Rockwell data for indications of waste release.
Hazardous constituents as defined in Appendix VIII of 40 CFR Part 261
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WEST
SPRAY
FIELD
r
40-M
04-88
T
N
PRESENT
LANDFILL
B-M
14-88
EVAPORATION
PONDS
34-86
SECURE AREA BOUNDARY O
43-88
(After Hydro-Search, July 1986)
Legend
• - Bedrock Wells
O * Alluvial Wells
600 0 500 1000
i i i f
APPROXIMATE
SCALE (FT.)
FIGURE 2
LOCATION MAP FOR SAMPLING STATIONS
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12
Task Force and DOE/Rockwell data indicate releases of hazardous
constituents from the evaporation ponds and unspecified sources on the 881
hillside. Task Force data from wells near the evaporation ponds show that four
hazardous constituents (carbon tetrachloride, chloroform, trichloroethane and
trichloroethene) were detected at low concentrations in the wet well. Four
hazardous constituents (carbon tetrachloride, chloroform, trichloroethene and
dichloroethene) were previously detected by Rockwell in well 22-86.
Both Task Force and Company data indicate that organic hazardous
constituents are present in ground water downgradient from the 881 hillside
area, including several chlorinated ethanes and ethenes. Ground-water
contamination in this area had been previously identified by DOE. The extent
and source(s) of the contamination were being investigated by Rockwell during
the Task Force inspection.
The data are inconclusive regarding releases from the west spray field
and the two landfills. Two of the wells sampled (8-86 and 62-86) by Task Force
personnel had elevated pH levels that were inconsistent with other data and
waste disposal information. These levels may be artifacts from well
construction.
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TECHNICAL REPORT
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13
INVESTIGATIVE METHODS
The Task Force evaluation of Rocky Flats consisted of:
Reviewing and evaluating records and documents from EPA
Region VIM, CDH and Rocky Flats
Onsite facility inspection conducted March 31 through April 2 and
April 6 through April 16, 1987
Evaluating the onsite Rockwell general laboratory
Determining water level elevations and total depths in selected
monitoring wells
Sampling and subsequent analysis of ground water from selected
monitoring wells and one wet well
RECORDS/DOCUMENTS REVIEW
Records and documents from EPA Region VIII and CDH offices, compiled
by an EPA contractor, were reviewed prior to the onsite inspection. Onsite
facility records were reviewed to verify information currently in Government files
and supplement Government information where necessary. Selected docu-
ments requiring in-depth evaluation were copied by the Task Force during the
inspection. Records were reviewed to evaluate facility operations, identify loca-
tions and construction details of waste management units and monitoring wells,
and evaluate ground-water monitoring activities.
Specific documents and records reviewed and evaluated included the
ground-water sampling and analysis plan, outline of the ground-water quality
assessment plan, analytical results from past ground-water sampling,
monitoring well construction data and logs, site geologic reports, site operation
plans, facility permits, waste management unit design and operation reports,
and the operating records showing the general types and quantities of waste
disposed of at the facility and the disposal locations.
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14
FACILITY INSPECTION
The onsite facility inspection included identification of waste
management units (past and present); identification and assessment of waste
management operations and pollution control practices; and verification of the
locations, procedures and operation of the ground-water monitoring system.
Rockwell and DOE representatives were interviewed to identify records
and documents of interest, discuss the content of the documents and explain
(1) facility operations (past and present), (2) site hydrogeology, (3) ground-
water monitoring system rationale, and (4) the ground-water sampling and
analysis plan. Monitoring well locations were verified by comparing observed
field locations with current maps.
LABORATORY EVALUATION
The onsite Rockwell general laboratory in building 881 was evaluated
regarding its responsibilities under the ground-water sampling and analysis
plan, and its ability to produce quality data. Analytical equipment and methods,
quality assurance procedures and documentation were examined for
adequacy. Laboratory records were inspected for completeness, accuracy and
compliance with State and Federal requirements.
WATER LEVEL AND WELL DEPTH MEASUREMENTS
Task Force personnel observed Rockwell personnel measuring the water
level and total well depth in 38 wells to verify past water level data and
construction records and to evaluate their procedures [Figure 3]. Duplicate
measurements were made at several wells to verify the reproducibility of the
results. Additional water level measurements were made on the wells sampled
prior to purging and before sampling.
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T
N
W-1O
6-689)
10-06
7-86(0 a-aa
OWE-a
PRESENT
LANDFILL
7-66 OD 16-66
14-B6
18-66 tf)01J-86
&
60-68
64-66
o
SECURE AREA BOUNDARY O
ORIGINAL
LANDFILL
O
67-88
62-86
68-66
(After Hydro-Search, July 1986)
2-81
°05-B6
O1-81
o
12-66
O
37-66
O U-86
O
28-86
39-86 O
Legend
— Water level mea6tir«ment only
—water level measurement and
• ample collected
500 0 500 1000
I | | |
APPROXIMATE
SCALE (FT.)
FIGURE 3
LOCATION MAP FOR WATER LEVEL MEASUREMENTS
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16
SAMPLE COLLECTION
Ground-water samples were collected from 15 monitoring wells and a
wet well" [Table 1 and Figure 4] to determine if the ground-water contains
hazardous constituents. The sampling effort was focused on areas likely to be
affected by waste management activities.
Rockwell personnel measured all the water levels and purged and bailed
samples from most of the wells using their equipment. The wells were purged
using either a Bennett® (furnished by Rockwell) or Johnson-Keck® (furnished
by EPA) submersible pump or Teflon® bailers. The monitoring wells were
sampled using Teflon bailers and the wet well was sampled using a stainless
steel bucket.
Task Force samples were collected in containers provided by an EPA
contractor. Split samples were provided to Rockwell personnel. Containers for
Task Force and Rockwell samples for each parameter group, except volatile
organics (VOAs), were alternately filled in sequence in increments of one-third
of a bottle (or one-half of a bailer per bottle when insufficient water was
available to fill one-third of each bottle). Duplicate VOA samples were collected
in lieu of splits. Samples were collected from each well by the following
procedures:
EPA contractor monitored the open well head for chemical vapors
(with an HNU® meter) and radiation.
Rockwell personnel determined depth to water and total depth
using either a Well Wizard® or an Olympia Actat® (Model 500)
meter.
The wet well serves as a sump for a ground-water collection system downgradient from
surface impoundments previously used for treating hazardous wastes.
Bennett, Johnson-Keck, Teflon, HNU, Well Wizard and Olympia Actat are registered
trademarks and will appear hereafter without ®.
-------
Table 1
PURGING AND SAMPLING DATA
Well
Number
2-71
9-74
8-86
14-86
27-86
30-86
32-86
34-86
43-86
48-86
49-86
Diameter
(inches)
6"
6"
2"
2"
2"
2"
2**
2"
2"
2"
2"
Vol. Calc.
(gallons)
108
53.5
29.5
23.5
15
5.5
33.5
17.5
2.7
75
10
Date
04/09
04/09
04/13
04/15
04/15
04/14
04/14
04/06
04/06
04/07
04/07
Purging
Time
1050-1130
1405-1455
0945-1040
0950-1030
0855-0900
1240-1250
1150-1210
0910-0945
1035-1100
0845-1150
0900-1020
SamDlina*
Method/Comments
Bennett pump, 40 gal.
purged, pumped dry
turbid (tan-green)
Bailer, 17 gal. purged
bailed dry, clear (foamy)
Bailer, 14 gal. purged,
bailed dry, clear
Bailer, 12 gal. purged,
bailed dry, tan-gray
Bennett pump, 2.5 gal.
purged, pumped dry, gray
Bailer, 2.5 gal. purged,
bailed dry, turbid (brown)
Keek-Johnson pump,
14-gal. purged, pumped
turbid (brown)
Bailer, 9.8 gal purged
bailed dry, milky white
Bailer, 2.1 gal purged,
bailed dry, slightly
turbid (tan)
Keek-Johnson pump,
26.5 gal. purged, pumped
dry, clear/opaque
Bailer, very turbid
(red-brown)
Date(s)
04/09
04/10
04/09
04/13
04/14
04/15
04/16
04/15
04/14
04/15
04/16
04/14
04/15
04/16
04/06
04/06
04/07
04/08
04/07
Time(s)
1635-1730
0935-1025
1805-1830
1405-1500
0845-0915
1520-1610
0805-0835
1350-1415
1625-1645
1100-1120
0935-0945
1115-1130
1530-1640
1105-1145
0945-1020
1145-1330
1535-1625
1350-1515
0845-0855
1045-1145
1340-1420
Comments
Organic aliquot collected
Inorganic aliquot collected
Organic aliquot collected
Field blank (RF-1) taken
Organic aliquot collected
Inorganic aliquot collected
Organic aliquot collected
Lab matrix spike taken
Inorganic aliquot collected
Organic aliquot collected
Inorganic aliquot collected
CN, Phenols collected
Field blank (RF-2) taken
Organic aliquot collected
Radionuclides aliquot collected
Inorganic aliquot collected
Radionuclides, and tritium
aliquots collected
Organic aliquot collected H
Inorganic aliquot collected
-------
Table (cont.)
Purging
Well Diameter Vol. Calc.
Number (inches) (gallons) Date Time
54-86 2** 24 04/08 0935-0945
57-86 2** 0.85 04/08 1115-1135
59-86 2" 2.6 04/09 0840-0900
62-86 2" 4.2 04/09 0940-1030
Wet Well
SamDlina*
Method/Comments
Bennett pump, 1 1 gal.
purged, pump dry, clear
Bailer, 0.5 gal purged,
bailed dry, turbid (tan)
Bailer, turbid (brown)
Bailer, 2 gal. purged,
bailed dry
No purge
Date(s)
04/08
04/09
04/10
04/08
04/09
04/10
04/09
04/09
04/10
04/13
Time(s)
1425-1450
0845-0935
1435-1455
0920-1110
1425-1430
1335-1345
0800-0810
1405-1415
0850-1025
1010-1200
1525-1600
0830-0900
1110-1125
0845-1000
Comments
Volatile organic aliquots collected
Ext. Organics aliquots collected
Partial radionuclides aliquot collected
Inorganic aliquot collected
Finish collecting Radionuclide
CN and Anions aliquots collected
Organic aliquot collected
Radionuclides aliquot collected
Phenol, Anions aliquots collected
Lab matrix spike taken
Organic aliquot collected
Partial inorganic aliquot collected
Remaining inorganic aliquot collected
Sampled using stainless steel bucket
Triplicate sample taken
Wells were sampled with teflon bailers; the wet well was sampled with a stainless steel bucket.
Well casings at 2-71 and 9-74 are steel; the other wells sampled have stainless steel casings.
oo
-------
WEST
SPRAY
FIELD
84-88
T
N
ORIGINAL
LANDFILL
PRESENT
LANDFILL
ft-M
14-86
EVAPORATION
PONDS
34-M
SECURE AREA BOUNDARY O
4>-M
881
HILLSIDE 9-74-
69-aa
(After Hydro-Search, July 1986)
Legend
• - Bedrock Wells
O • Alluvial Wells
600 0 500 1000
APPROXIMATE
SCALE (FT.)
FIGURE 4
LOCATION MAP FOR SAMPLING STATIONS
-------
20
Rockwell personnel washed the water level meter probe and the
uncoiled cable using a solution of Alconox® (soap) and water and
then rinsed them with deionized (Dl) water.
Rockwell personnel calculated the height of the water column from
the depth to water measurement and the well depth.
Rockwell personnel computed the water column volume by multi-
plying the water column height (in feet) by a conversion factor
(gallons per foot of casing).
Rockwell personnel washed the Teflon bailers by brushing both
inside and outside with a nylon bristle brush dipped in an Alconox
solution. The wash was followed with a Dl water rinse. If a pump
was used for purging, the pump and the last 3 to 5 feet of tubing
was cleaned (Alconox and water) and rinsed with Dl water prior to
use. The tubing was flushed with approximately 5 gallons of Dl
water after each use.
Rockwell and/or EPA contractor personnel purged three water
column volumes (or evacuated to dryness) using either a Bennett
or Johnson-Keck pump or Teflon bailer. Purge water was
collected in a graduated plastic bucket (approximately 4-gallon
capacity) and disposed of on the ground nearby.
Rockwell personnel collected sample aliquots and measured
water temperature, pH and specific conductance (field parame-
ters) at the beginning of purge and after each casing volume
purged.
After recharge, Rockwell bailed and an EPA contractor poured
sample aliquots for another set of field parameters.
® Alconox is a registered trademark and will appear hereafter without ®.
-------
21
Rockwell and/or EPA contractor personnel drew water from the
well with a Teflon bailer and the EPA contractor filled prelabeled
sample containers in the order shown in Table 2.
Rockwell and EPA collected sample aliquots to measure field
parameters after collection of samples from the well.
The order of sample aliquot collection was modified from that specified in
Table 2 when slow well recharge prevented collection of all aliquots during a
single period. In some cases organics samples were collected immediately
following recharge; the other aliquots were collected during subsequent
sampling periods when recharge was sufficient for sample collection. In some
cases, the less important sample aliquots were not collected.
After sampling each well, EPA contractor personnel took the samples to a
staging area where aliquots for radionuclides, metals, TOC, phenols, cyanide
and sulfides were preserved. The final pH was measured in samples preserved
by acid or base addition.
Quality control/quality assurance samples were also prepared by the
EPA contractor. Field blanks for each analytical parameter group (e.g.,
volatiles, organics and metals) were prepared twice during the investigation
(near wells 9-74 and 32-86) by pouring distilled, deionized water into sample
containers. In addition, one laboratory matrix spike, which consisted of two
duplicate VGA vials and two 1-liter amber glass bottles, was collected per week
(from wells 14-86 and 59-86). One trip blank for each parameter group was
also prepared and submitted during the inspection. An equipment blank was
prepared by pouring distilled, deionized water through one of Rockwell's Teflon
bailers. An additional equipment blank was prepared by pouring distilled,
deionized water in the stainless steel bucket used to sample the wet well. All
blanks were submitted with no distinguishing labeling or markings to identify
them as blanks. A laboratory triplicate of all parameter groups was collected at
the wet well.
-------
22
Table 2
ORDER OF SAMPLE COLLECTION,
BOTTLE TYPE AND PRESERVATIVE LIST
Parameter
Container
Preservative*
Volatile organic analysis (VOA)
Purgeable organic carbon (POC)
Purgeable organic halogens (POX)
Extractable organics
Total organic carbon (TOC)
Total organic halogens (TOX)
Radionuclides
Tritium
Total metals
Dissolved metals
Phenols
Cyanide
Anions
Sulfides
2 40-mL VOA vials
2 40-mL VOA vials
2 40-mL VOA vials
6 1-qt. amber glass
1 4-oz. glass
1 1-qt. amber glass
1 1-gal. plastic container
1 1-qt. plastic container
1 1 -qt. plastic
1 1 -qt. plastic
1 1-qt. amber glass
1 1-qt. plastic
1 1-qt. plastic
1 4-oz. clear glass
H2SO4
HNO3
HNO3
HNO3
H2SO4
NaOH
Zinc acetate
and NaOH
All samples were cooled on ice after collection.
-------
23
At the end of each day, Task Force samples were packaged and shipped
to the two EPA contract laboratories according to applicable Department of
Transportation (DOT) regulations (49 CFR Parts 171 through 177). Rockwell
personnel were given receipts for all samples collected. Chain-of-custody
procedures were followed during the handling, transfer and shipping of all
samples.
-------
24
FACILITY DESCRIPTION
Task Force personnel obtained information on past and present
manufacturing and waste management activities to identify potential sources of
hazardous waste released to the ground water and aid in interpreting ground-
water monitoring data. Information pertaining to many plant processes and
operations is considered by DOE to be Unclassified Controlled Nuclear
Information (UCNI). DOE and Rockwell personnel have recently compiled and
submitted to EPA and CDH, substantial information on the characteristics of
waste streams generated at the facility and all known or suspected onsite
disposal areas. Consequently, only general descriptions of plant processes
and operations are presented in this report in most cases. Specific information
on plant processes and operations at the Rocky Flats plant is available in EPA
Region VIII and CDH offices. Waste handling units, which the State has
identified as "regulated units" [as defined in 264.90(a)(2)], are described in
more detail in this report.
GENERAL DESCRIPTION
The Rocky Flats plant is a GOCO facility, which is part of a nationwide
nuclear weapons research, development and production complex administered
by DOE. As previously discussed, the current prime contractor for DOE at the
Rocky Flats plant is the North American Space Operating Group of Rockwell.
The primary function of the Rocky Flats plant is to fabricate nuclear
weapon components from plutonium, uranium, beryllium and stainless steel.
Process operations include metal fabrication, assembly, chemical recovery and
purification of recyclable transuranic* radionuclides. Other activities include
research and development in metallurgy, machining, nondestructive testing,
coatings, remote engineering, chemistry and physics. Components manufac-
tured at the plant are shipped elsewhere for final assembly.
As used herein, transuranic elements are those having an atomic number greater than that
of uranium and present at concentrations greater than 100 nanoCuries/gram (nd/gram) of
material.
-------
25
All plant production buildings are located in a 384-acre area surrounded
by a security fence [Figure 5]. The plant is divided into separate operational
complexes with buildings in each complex designated with a three-digit
number, of which the first digit designates the area. Production operations are
in the 300, 400, 600, 700, 800 and 900 areas.
WASTE PRODUCTION
This section provides a general description of the types of wastes
generated at the Rocky Flats plant. The November 1986 Part B RCRA permit
application indicates that over 1500 waste streams have been identified at the
plant. More specific information has been submitted to EPA and CDH by the
facility in a "Waste Stream Identification" document dated April 1987.
In general, Rockwell personnel identified five categories of waste
generated at the plant:
1. Hazardous waste (as defined in 40 CFR 261)
2. Radioactive
3. Radioactive mixed
4. Sanitary waste
5. Nonhazardous/nonradioactive solid refuse
Hazardous Waste Generation
Typical hazardous wastes generated at Rocky Flats are shown in
Table 3. Quantity and types vary depending on plant activities.
Trichloroethylene was used at Rocky Flats (degreasing operations) prior to
about 1975, when it was replaced with 1,1,1-trichloroethane.
-------
C\J
(9861 J»
ainBij
009_ - I OOK
««••• I • J * i . I
-,, • - ,i=!;
M- A
-------
27
Table 3
TYPICAL HAZARDOUS WASTES GENERATED AT ROCKY FLATS
Waste
EPA HW Numbers*
Acetone
Carbon tetrachloride
Methylene chloride
Ethanol
Hydrochloric acid
Magnesium
Mercury
Methanol
Nitric acid
Tetrachloroethylene
Phosphoric acid
Sulfuric acid
Silver
Toluene
1,1,1-Trichloroethane
Xylene
Used Oil
Sodium cyanide
Barium cyanide
Sodium nitrate/potassium nitrate
Etchant solution (acid)
Used O&M paint solvents/sludge
Waste/surplus O&M paint
Bromine trifluoride
Chlorine trifuloride
Hydrogen sulfide
Hydrogen chloride
Iodine pentafluoride
Tungsten hexafluoride
Dioctyl phthalate
Electrochemical milling (ECM) sludge
F003.U002
F001, U211
F001.U080
D001, U080
D002, D003
D001
D009, U151
D001, F003, U154
D002, D003
F001
D002, D003
D002, D003
D011
F005, U220
F001, U226
F003, U239
D001
P106
D005
D001
D002, D003, U134
D001
D001
D002, D003
D002, D003
D001, D002, D003
D001, D002, D003,
U135
D002, S003
D003
U028
D007
Listed and defined in Part 261
-------
28
Radioactive Waste Generation
Rocky Flats processes large quantities of plutonium (PU239), depleted
uranium (1)233 anc| u238), americium (Am241) and neptunium (NP237). The
facility has identified three categories of radioactive contaminated waste
generated by this processing:
1. Low level
2. Transuranic
3. Special Category RGBs
Low Level
Low-level radioactive waste contains naturally occurring radioactive
elements such as uranium and thorium and may have transuranics at less than
100 nanoCuries per gram (nCi/g) of material. Examples include plutonium and
depleted uranium contaminated solids (plastic, metal and paper) and liquids
(solvents and oils) some of which have hazardous properties, as defined by
State and Federal regulations.
Transuranic
Transuranic waste contains plutonium or americium at concentrations
greater than 100nCi/g of material. Typical transuranic wastes generated,
include sludges, plastics, rubber and metal equipment, filters, insulation and
combustible material. Some transuranic waste generated at Rocky Flats has
hazardous properties, as defined by State and Federal regulations.
Special Category PCBs
Special Category PCBs are radioactive PCB wastes generated from
cleaning/retrofitting of PCB transformers, decommissioning of PCB capacitors
and cleanup of PCB contaminated debris within the plutonium handling
buildings.
-------
29
Radioactive Mixed Waste Generation
Typical radioactive mixed wastes generated at Rocky Flats are shown in
Table 4.
Sanitary Waste Generation
Sanitary wastes include shower water, janitorial, restroom and cafeteria
wastes. The sanitary system also receives wastes collected from production
cleaning operations (using soap and water), film processing and cooling tower
blowdown. Rockwell personnel also reported that some hazardous wastes are
entering the sanitary system. Studies are being conducted to identify the
source of these wastes. In the past, wastewater from other plant processes
were discharged to the sanitary sewers.
Nonhazardous/Nonradioactive Refuse
Refuse waste includes cardboard packaging, paper, construction rubble,
soils from excavation and such "non-routine" waste as asbestos.
WASTE MANAGEMENT PROCEDURES
Waste management activities at the Rocky Flats plant have varied
through the years. Past waste handling procedures included shallow burial at
numerous locations around the site, discharge to the surface drainage, solar
evaporation, spray irrigation and offsite disposal. Many of the wastes generated
at the plant were probably disposed of using one or several of these methods.
DOE and Rockwell have been studying facility waste management practices in
an attempt to identify areas for remedial action. Some remedial action has
begun at various plant sites. Historically, cleanup activities concentrated on
removing soils/debris contaminated with radioactivity and not necessarily
chemical contamination. Those activities included a plant-wide Radiometric
Study and some cleanup in the 1970's.
-------
30
Table 4
TYPICAL MIXED WASTES GENERATED AT ROCKY FLATS
Specific Mixed Wastes
EPA HW Numbers*
Chromic acid plating bath solution
Coolant/1,1,1 -trichloroethane
Cadmium cyanide
Etchant solution (10% acid)
Fixer (radiographic solution)
Waste acid mixture (HCI, HF, HN03)
lodomethane
Barium chloride
Sodium nitrate/potassium nitrate
Sodium hydroxide
Niobium diselinide
Oil with halogenated solvents
Ox out
Pentachlorophenol
Pyridine
Alkaline sludge from heat exchanger
Su If uric acid
Tetraethyl ammonium perchlorate
Scintillation cocktail
Solar pond sludge
Intercepted pond seepage water
D002, D007
F001, U226
F001, P030
D002, U134
D011
D002
U138
D005
D002, D003
D010
D001, F001, F002
F007
U242
D001, U196, P075
D002
D002
D003
D001, D002, D003,
F003, D005, U220, U239
D007, F001, U226
U044, U228
Listed and defined in Part 261
-------
31
The following is a brief description of how each type of waste is managed
at the Rocky Flats plant. Information on past and present waste management
areas is provided later in this report. More specific information is contained in
the November 1986 Part B permit application on file at both the EPA and CDH
offices.
Hazardous Waste
Aqueous Waste
Aqueous hazardous wastes are sent to buildings 374 and 774, where
they are mixed with other aqueous waste (radioactive and radioactive mixed)
and treated through sedimentation, filtration and evaporation.
Organic Liquids
Organic hazardous waste (such as solvents) and miscellaneous
chemicals are either stored onsite for future treatment or for offsite shipment for
treatment, disposal or reclamation.
Solids
Hazardous waste solids are stored onsite for eventual shipment offsite for
treatment or disposal.
Radioactive Waste
Aqueous Waste
Radioactive aqueous waste is treated onsite in buildings 374 and 774 to
reduce radioactivity by sedimentation, filtration and evaporation. The treated
liquids are used onsite for steam or cooling tower makeup. Some radioactive
aqueous waste was stored in surface impoundments 207A and 207C, prior to
treatment. This practice has reportedly been discontinued. Some radioactive
aqueous waste from laundry operations had been discharged to the onsite
-------
32
sanitary wastewater treatment plant. Process wastewater also went to ponds
A1, A2 and B2 for storage, prior to onsite processing.
Solids generated from the treatment operations in buildings 374 and 774
are stabilized by mixing with cement and stored for eventual shipment for offsite
disposal. Aqueous wastes which cannot be treated onsite are also solidified
and stored for offsite disposal.
Solids
Radioactive waste solids are stored onsite until it is shipped for offsite
disposal. This waste is normally stored in boxes, 55-gallon drums or stabilized
in cement.
Special Category PCB Waste
These wastes are stored onsite, pending a decision by DOE/Rockwell
and EPA on how they will be handled.
Radioactive Mixed Waste
Aqueous Waste
Radioactive-mixed aqueous process wastewater with hazardous waste
properties are sent to buildings 374 and 774, where they are mixed and treated
with the radioactive aqueous waste through sedimentation, filtration and
evaporation.
Organic Liquid
Radioactive-mixed organic liquid waste is stored at the facility prior to
treatment or disposal. Some transuranic wastes are treated onsite.
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33
Solids
Radioactive-mixed waste solids are stored onsite for future treatment or
for offsite treatment/disposal.
Sanitary Waste (with some process wastewater)
Wastewater collected in the facility sanitary system is treated in the onsite
wastewater treatment plant (WWTP). Effluent from the WWTP: (1) has been
discharged (intermittently) to the surface drainage (through an NPDES
permitted discharge), (2) treated in the onsite reverse osmosis (R/O) treatment
facility and used for cooling tower makeup or (3) spray irrigated onsite (east
spray field). Sludge from the WWTP has been disposed of in the onsite landfill
and trenches.
Nonhazardous/Nonradioactive Refuse
This waste material is disposed of at the onsite active landfill.
WASTE MANAGEMENT AREAS
A substantial quantity of information has been compiled by DOE and
Rockwell regarding waste management areas at the facility. Table 5
summarizes much of this information and Figure 6 identifies the approximate
location of each unit. More specific information on each of these units can be
found in EPA and State fifes. The major waste management units are
described below.
-------
Table 5
SUMMARY OF WASTr MANAGEMENT UNITS
Reference
Number*
101
102
103
104
105
106
107
108
109
110
Unit
207 Solar evaporation ponds
Oil sludge pit
Chemical burial
Liquid dumping pit
Out-of-service fuel tanks
105.1 : westernmost tank,
105.2 : easternmost tank
Cooling tower water discharge
Hillside oil leak
Trench T-l
Trench T-2
Trench T-3
Date(s)
Operated
1953 to present
1958
Unknown
Prior to 1961
1958-1976
1977
1958-1976
1954-1962
1954-1968
1954-1968
Materials
Handled
Liquids
30 to 50 drums
oil sludge
(No. 6 fuel)
Unknown Ch«, deals
Unknown liquids/
scrap metal/
empty drums
Asbestos/possible
oil sludge
Cooling tower
cleanout water
No. 6 fuel oil
Depleted uranium
chips/plutonium/
lathe coolant
(hydraulic oil
and carbon
tetrachloride)
Santiary sewage
sludge contami-
nated with
uranium and
Plutonium/
flattened drums
of contaminated
oil
Sanitary sewage
sludge contami-
nated with
uranium and
plutonium/
flattened drums
of contaminated
oil
Activity
Storage/evaporation
Land disposal
Land disposal
Land disposal
Storage
Wastewater
discharge
Storage
Land disposal
Land disposal
Land disposal
Approximate
Dimensions
-
50' x 80'
100' x 80'
50' x 50'
30' x 50'
50' x 350'
50' x 400'
200' x 15' x
5' (deep)
200' -300' x
15'-50'x
5' (deep)
200' -300' x
15'-50' x
5' (deep)
Comments
See text
-
-
-
Waste mixed with concrete
and placed in two out-of-
service tanks
Front bldg. 881 cooling
tower
Fuel oil seeps, possibly
from storage tanks
25,000 kg in 125 drums
Flattened drums contained
uranium and plutonium
contaminated oil
Drums contained uranium
and plutonium contami-
nated oil which was
"burned out"
-------
Table 5 (cont.)
Reference Oate(s) Mate!;!alS
Number* Unit Operated Handled
111 Trenches T-4 to T-ll
111 1 • Trench T-4 1954-1968 Sanitary sewage
sludge/flattened
drums contaminated
with uranium/
plutonium and
uranium contami-
nated asphalt
planking from
solar evapora-
tion ponds
111 2 • Trench T-5 1954-1968 Sanitary sewage
sludge/flattened
drums contaminated
with uranium/
unknown metal
111.3 : Trench T-6 1954-1968 Sanitary sewage
sludge
111 4 • Trench T-7 1954-1968 Sanitary sewage
sludge/flattened
drums contaminated
with uranium
111 5 : Trench T-8 1954-1968 Sanitary sewage
sludge/flattened
drums contaminated
with uranium
111.6 : Trench T-9 1977 Sanitary sewage
sludge/flattened
drums contaminated
with uranium/unknown
metal
111.7 : Trench T-10 1977 Sanitary sewage
sludge/flattened
drums contaminated
with uranium/scrap
metal
111.8 : Trench T-ll 1977 Sanitary sewage
sludae/f lattened
Activity
-
Land disposal
Land disposal
Land disposal
Land disposal
Land disposal
Land disposal
Land disposal
Land disposal
Approximate
Dimensions
-
15'-50'x
200' -300' x
5' (deep)
15'-50'x
200' -300' x
5' (deep)
15'-50'x
200' -300' x
5' (deep)
15'-50'x
200' -300' x
5' (deep)
15'-50'x
200' -300' x
5' (deep)
50'x300'x
5' (deep)
50'x300'x
5' (deep)
50'x300'x
5' (deep)
Comments
Sludge contaminated with
uranium
Sludge contaminated with
uranium
Sludge contaminated with
uranium
Sludge contaminated with
uranium
Sludge contaminated with
uranium
Sludge contaminated with
uranium
Sludge contaminated with
uranium
Sludge contaminated with
uranium
drums contaminated
with uranium/
plutonium and
uranium contaminated
asphalt planking
from solar evap-
oration ponds
LJ
cn
-------
Table 5 (cont.)
Reference
Number* Unit
11? 903 Drum storaae area
Date(s)
Operated
1958-1968
Materials
Handled
Plutonium and
Activity
Storage
Approximate
Dimensions
400'x400'
Comments
Some drums known
laalroH f oc t imatpr
to have
i c, nnn
113 Mound area
114 Present landfill
115 Original landfill
1954-1958
1968 to present
1952-1968
uramum con-
taminated lathe
coolant (hydraulic
oil with carbon
tetrachloride)/
trichloroethylene/
perchloroethylene/
silicone oils/acetone
still bottoms
Urani urn/beryl 1i urn/
plutonium/lathe
coolant/still
bottoms/glass/
concreted dry
wastes
Nonhazardous/
hazardous waste
General plant
wastes/20 kg
depleted uranium
ash/unknown chem-
ical waste
Land disposal
Land disposal
Land disposal
gallons) to soil base,
drums removed, area
asphalt capped
50'xl60'
Drums excavated and
removed in 1970
Over 25
acres
Irregular, may
be over 300'x
650'
See text
116 Multiple solvent spills
116.1 : West loading dock area
116.2 : South loading dock area
Prior to 1979 Unknown solvents Storage
and hydrocarbons
Prior to 1979 Unknown solvents Storage
and hydrocarbons
50'xlOO1 Drums stored on loading
dock thought to have
leaked
30'x50' Drums stored on loading
dock thought to have
leaked
Hi Chemical storage area
117.1 : North Site
117.2 : Middle site
Prior to mid-
1970s
Prior to mid-
1970s
Miscellaneous
"warehouse"
materials
Nonradioactive
chemicals includ-
Storage
Storage
200'x450'
200'x450'
ing acids/oils/
soaps/solvents
Leaks and spills have
occurred in this area
CO
01
-------
Table 5 (cont. )
Reference
Number*
118
117.3 :
Multiple
118.1 :
118.2
Unit
: South site
solvent spi 1 Is
: West of Bldg. 730
(5,000-gallon tank)
: South end of bldg. 776
(several tanks)
Date(s)
Operated
Prior to mid
1970s
Late 1970s,
1981
Late 1970s,
1981
Materials
Handled
Pallets/cargo
containers/
new drums
Carbon tetra-
chloride/
possibly
trichloroethylene
Carbon tetra-
chloride/
Activity
Storage
Storage
Storage
Approximate
Dimensions
200'x450'
50'xl80'
30'x90'
Comments
Leaks and spills during
filling operations at
below grade storage
tank
Leaks from inside (bldg.
776) tanks pumped out-
possibly
trichloroethylene
119 Multiple solvent spills
119.1 : West area
119.2 : East area
1967-1971
1967-1971
Unknown solvents Storage
Unknown solvents Storage
100'x600'
(irregular)
100'x200
Spills and leaks may have
occurred, waste oils
sprayed on area roads
Spills and leaks may have
occurred, waste oils
sprayed on area roads
120 Fiberglassing areas
120.1 : North of bldg. 664
120.2 : West of bldg. 664
121 Original process waste lines
122 Underground concrete tank
(3,000-gallon)
1972-1979 (?)
1972-1979 (?)
1952-1984
1953-1982
Polyester resin/
peroxide catalyst/
unknown solvents
Polyester resin/
peroxide catalyst/
unknown solvents
Process waste-
water
(radioactive/
nonradioactive
compounds)
Process waste-
water (nitrates/
possible
radionuclides)
Fiberglassing of
waste packaging
Fiberglassing of
waste packaging
Transport of wastes
through underground
pipeline
Storage
100'xlOO1
100'xl20'
Throughout
site process
areas (about
27,400 feet
of pipe)
50'xSO'
Materials may have
spilled during activity
Materials may have
spilled during activity
Leaks/breaks have con-
taminated soils will
be closed undtM interim
status
Tank may have leaked
123 Valve Vaults
123.2 : Valve Vault West of Bldg. 707
123.7 : Valve Vault 7
1952-1984
Possible uranium/
solvents/oils/
beryllium/
nitric and
hydrochloric
acids/fluorides
Pipeline
30'x30' Vaults contain valves
controlling waste
lines, vaults have
overflowed with process
wastes
-------
Table 5 (cont.)
Reference
Number*
124
126
Unit
Reactive liquid waste storage tanks
(south side of bldg. 774)
124.1 : 30,000-gallon tank (#60)
124 2 and 125 : 14,000-gal Ion tank (#66)
124.3 : 14,000-gal Ion tank (#67)
Out-of-service process waste tanks
(north of bid. 771)
126.1 : Westernmost tank
Date(s)
Operated
1952 to present
1953 to 1976 (?)
Materials
Handled
Plutonium/
americium/
possibly uran-
ium/nitrates
Unknown process
(20,000 gallons)
126.2 : Easternmost tank
(20,000 gallons)
127 Low-Level radioactive waste leak
128 Oil burn pit No. 1
Activity
Storage
Storage
Unknown
August 1956
Process wastewater
(nitrates/
plutonium)
Waste oil with
depleted uranium
Pipeline
Land disposal
Approximate
Dimensions
30'x50'
50'x50'
20'xlOO'
50'xl50'
Comments
Overflow/spills from
waste storage tanks or
pipelines in late 1970s
and early 1980s
Concrete underground
tanks may have leaked
waste when active,
occasionally fill with
groundwater which is
treated onsite
Pipeline broke and leaked
several times
Oil burned in pit and
covered with soi1
129 Oil leaks from underground tank
(four tanks - 18,000 gal. each)
130 Radioactive site - 800 area site #1
131 Radioactive site - 700 area site #1
(3 areas)
132 Radioactive Site - 700 Area Site #4
(four radioactive waste tanks)
133 Ash pits
1952 to present
1969 to 1972
Fuel oil/1, 1,1-
trichloroethane
Plutonium con-
taminated soil/
asphalt/scrap
metal
Storage
Land disposal
1969-?
Unknown-1982
1952-1968
133.1
133.2
133.3
133.4
133.5
133.6
Ash pit 1-1
Ash pit 1-2
Ash pit 1-3
Ash pit 1-4
Incinerator
Concrete wash pad
Plutonium
Unknown radio-
active compounds
Office wastes/
depleted uranium
chips/metal
Fire
Storage
Land disposal
50'xlOO'
Triangle
550'xllO'x
1080'
100'x180'
30'x350'
50'xlOO'
20'x40'
S'xSO'x
3' deep
(each pit)
wash pad is
40' diameter
Known leaks/spills from
tanks
Shallow burial of con-
taminated debris
Areas contaminated during
1969 fire
Tanks held radioactive
laundry waste and prob-
ably leaked, no longer
used but fill with
groundwater
Incinerator used to burn
"general" wastes and
some depleted uranium.
Ashes placed in pits or
pushed over hill to con-
crete wash pad and into
Woman Creek drainage,
pits currently covered
with fill
CO
CO
-------
Table 5 (cont. )
Reference
Number*
134 Lithium
135 Cooling
136 Cooling
136.1
136.2
136.3
137 Cooling
138 Cooling
Date(s)
Unit Operated
metal destruction site Unknown
tower blowdown Unknown
tower ponds
: Northeast corner of bldg. 460 1963-1969
: West of bldg. 460 1963-1969
: S of Bldg. 460, W. of Bldg. 444 1963-1969
tower blowdown - bldg. 774 Unknown
tower blowdown - bldg. 779 Dec. 1976
Materials
Handled
Lithium metal
Chroma tes/
algicides
Chroma tes/
algicides/
lithium/
possible uranium/
hexavalent
chromium
Chroma tes/
algicides
Chromates/
algicides
Activity
Land disposal
Storage
Land disposal
Land disposal
lithium treatment
Land disposal
lithium treatment
Land Disposal
Land disposal
Approximate
Dimensions
50'
x!50'
IQO'xlBO1
25'
25'
30'
50'
75'
x75'
x75'
xlOO'
x!50'
x75'
Comments
Lithium reacted with
water in shallow trench
covered with soil, area
covered by bldg. 335
Disposal of cooling tower
blowdown
Used to contain and
evaporate cooling tower
water. Also may have
reacted lithium and
disposed of depleted
uranium
Cooling tower blowdown
discharge to ground
400 gallons cooling tower
blowdown spilled
139 Caustic/acid spills
139.1 : Hydroxide tank area
(1 5,400-gallon,
1 6,500 gallon tank)
139.2 : Hydrofluoric acid tanks
(2 1,200-gallon tanks)
140 Reactive metal destruction site
141 Sludge dispersal
142 Retention Ponds (A,B,C-Series)
Unknown Potassium/sodium Storage
hydroxide
Unknown Hydrofluoric acid Storage
1956-1970 Lithium/sodium/ Land disposal
ca1c ium/magnes i urn/
unknown solvents
Prior to 1983 Sanitary sludge/ Storage
radioactive soil
142.1
142.2
142.3
142.4
142.5
142.6
142.7
142.8
142.9
142.10
142.11
A-l pond
A-2 pond
A- 3 pond
A- 4 pond
B-l pond
B-2 pond
B-3 pond
B-4 pond
B-5 pond
: C-l pond
: C-2 pond
1952 to present Nitrates/
Plutonium and
uranium
Storage (surface
impoundments)
25'x250' Leaks/spills from storage
tanks
40'x60' Leaks/spills from storage
tanks
250'x350' Destruction of various
materials including 400-
500 pounds metallic
lithium-residues buried
200'x200' Radioactive sludge dis-
persed by wind from
sanitary drying beds
Varies, These are surface
depending impoundments located on
on season North Walnut Creek (A),
South Walnut Creek (B)
and Woman Creek (C).
Primarily used to retain
surface runoff for
sampling and analysis
prior to release or
reuse. Ponds A-l, B-l,
B-2, B-3, B-4 and C-l
have received various
wastes with nitrates and
low level radioactivity
-------
Table 5 (cont.)
Reference
Number* Unit
143 Old outfall
(Process and/or laundry wastewater)
Date(s)
Operated
Mid 1950s
to 1974
Materials
Handled Activity
Sodium/plutonium Storage
sul fates/nit rates
pi utoni urn/unknown
radioactive
compounds
Approximate
Dimensions
50'x50'
Comments
Process and/or laundry
wastewater discharged
to North Walnut Creek
from bldg. 771. Some
radioactive soil has been
excavated
144
145
146
147
148
149
150
Sewer line break
(Between bldg. 779 and 777)
Sanitary wastewater line leak
(South of bldg 881)
Concrete
146.1
146.2
146.3
146.4
146.5
146.6
process waste
7,500-gallon
7,500-gallon
7,500-gallon
7,500-gallon
3,750-gallon
3,750-gallon
tanks
tank (#31)
tank (#32)
tank (#34W)
tank (#34E)
tank (0130)
tank (#33)
Unknown
January 1981
Late 1950s-1970
Process waste leaks
147.1 : Maas Area
147.2 : Owen Area
Bldg. 123 waste spills
Bldg. 774 effluent pipe
Unknown
Unknown
Prior to 1980
Radioactive liquid leaks
150.1
150.2
150.3
150.4
150.5
150.6
150.7
150.8
Unknown
North of bldg. 771
West of bldg. 771
Between bldg. 771 and 774
East of bldg. 750
West of bldg. 707
South of bldg. 779
South of bldg. 776
Northeast of'bldg. 779
Sanitary/laundry
wastewater
(unknown radio-
active compounds)
Sanitary wastes/
unknown radio-
active compounds
Plutonium/uranium/
acids/caustics/
sodium/potassium
sulfur/nitrates
Unknown process
wastes
Unknown radio-
acitve and
chemical wastes/
nitrates
Unknown radio-
active materials/
acids/caustics
Unknown radio-
active compounds/
1 iquid mixed
wastes/acids/
caustics
Leak
Leak
Storage
Leaks
Spills
Leak
Spills/leaks
20'x50'
20'xl50
75'x75'
30'x250'
60'x60'
200'x200'
20'x550'
50'x450'
70'x250'
100'x140'
120'x180'
150'x250'
100'x200'
100'x500'
80'xl20'
Breaks in a 6' PVC sani-
tary wastewater line
Leakage/overflow from
process aqueous waste
tanks - some contaminated
soil removed. Tanks
removed early 1980s and
southern addition to
bldg. 774 was built over
tank area
Process waste lines from
bldg. 881 have leaked
resulting in soil
contamination
Several small spills out-
side bldg. 123
Effluent pipe from bldg.
774 to 207 solar evap-
oration ponds leaks.
Some contaminated soil
removed. Effluent pipe
out of service
Areas in the 700 area
where liquid process
waste has spilled/
leaked. Includes leaking
ing storage containers,
broken lines and a May
1969 fire in bldg. 776-
777. Radioactive soils
reportedly removed
-£=.
o
-------
Table 5 (cont.)
Reference
Number*
151
152
Unit
Fuel oil tank leak
Fuel oil tank spill
Date(s)
Operated
1981
1952 to present
Materials
Handled
#2 fuel oil
06 fuel oil
Activity
Leak
Spill
Approximate
Dimensions
30'x25'
50' diameter
Comments
200 gallons oil leaked
from tank. Soil removed
1971 - 700 gallons
153 Oil burn pit No. 2
1957/1961-1965 Waste oil/ Land disposal
depleted uranium/
still bottom sands
154 Pallet burn site
155 903 lip area
156 Radioactive soil burial
156.1 : Bldg. 334 parking lot
156.2 : Soil dump area
157 Radioactive site
157.1 : North area
157.2 : South area
158 Radioactive site - bldg. 551
159 Radioactive site - bldg. 559
1965
Unknown
Unknown
1963-1970
Unknown chemical
and radioactive
compounds/wood
pal lets
Plutonium/unknown
mixed wastes
Radioactive
material
Land disposal
Storage
Land disposal
Prior to 1973 Uranium/beryllium/ Spill/leaks
unknown chemicals
(possibly solvents)
Unknown wastes/
uranium
1968 to present Process waste-
waters
Broken process
waste lines
50'x60'
50'xlOO'
700'xl250'
160'x280'
300'x850'
150'x300'
440'x520'
Spills from loading 200'x250'
25'x75'
spilled; 1979 - 400
gallons spilled. Soil
removed
Material from 1083 drums
burned in two trenches,
empty drums buried. Soil/
material to a depth of
about 5 feet removed in
1978
Pallets, presumably with
spilled material, burned;
area "cleaned" in 1970s
Wind/runoff dispersal of
contaminants from 903
area (#112). Some soil
removed/radioactive
contamination remains
PIutoni um-contami nated
soil from around bldg.
774 placed in 156.1 area.
Some soil removed to
156.2 area prior to
construction of bldg.
334 parking lot
Soil around bldgs. 440,
442, 444, 447, 439
thought to be contami-
nated from facility
activities. Some cleanup
of radioactive materials
occurred
Area used to load radio-
active wastes onto rail-
road cars
Several process line
breaks; radioactive soil
removed
-------
Table 5 (cont.)
Reference
Number*
160
Unit
161 Radioactive site - bldg. 664
162 Radioactive site - 700 area Site #2
163 Radioactive site - 700 area Site #3
163.1 : Wash area
163.2 : Buried slab
Date(s)
Operated
Radioactive site - bldg. 444 parking lot Unknown
Unknown
1974
Unknown
Materials
Handled
Plutonium/uranium
waste
Plutonium/uranium
waste
Unknown radio-
active compounts
Unknown Radio-
active compounds/
americium
Activity
Storage
Storage
Spills
Land disposal
Approximate
Dimensions
Comments
480'x580' Leaks from drums/boxes
storing radioactive
wastes; some soil
removed; contamination
believed to remain
200'x250' Leaks from drums/boxes
storing radioactive
wastes; some soil
removed; contamination
believed to remain
50'x2,000' Radioactive spots on 8th
street; paved over
60'xl50' Area used to wash radio-
50'x50' active contaminated
equipment
164
165
166
167
Radioactive site - 800 area site #2
164.1 : Concrete slab
164.2 : Bldg. 886 spills
164.3 : Bldg. 889 storage pad
Triangle area
Trenches
166.1
166.2
166.3
Landfill
167.1
167.2
167.3
Trench A
Trench B
Trench C
spray fields - three sites
North area
Pond area
South area
168
West spray field
1958
1958
1958
1966-1975
Unknown
1968(?) to
present
1977-1985
Uranium/unknown Land disposal
radioactive
compounds
Uranium/unknown Spills
radioactive
compounds
Uranium/unknown Storage
radioactive
compounds
Plutonium contami- Land disposal
nated wastes/acids;
rubble from 1969
fire
Uranium/plutonium
contained sanitary
sludge and unknown
chemicals
Landfill runnoff
collected in
landfill pond
Liquids from
solar evapora-
tion ponds
Land disposal
Land treatment
Land treatment
50'x80' Contaminated concrete
disposal; some concrete
and soil removed
100'x200' Unknown materials may
have infiltrated
beneath bldg. 886
60'x60' Temporary storage of
uranium contaminated
equipment
400'x460'x Leaks from drums (up to
250' 6,000) stored in this
area have contaminated
soil. Some soil removed
Sanitary sludge from
80'x230' treatment plant disposed
80'x230' in trenches A, B and
30'xlOO' possibly C
Liquid from the landfill
200'x200' pond was sprayed onto
300'x300' the land in three areas.
400'x400' Spray irrigation pres-
ently only in pond area
(167.2)
110 acres See text
-P.
r-o
-------
Table 5 (cont.)
Reference
Number*
169
170
171
172
173
174
175
176
177
181
182
Unit
Waste peroxide burial
(one 55-gallon drum)
P.U. & D. storage yard - waste spills
Solvent burning ground
Central Avenue waste spills
Radioactive site - 900 area
(Storage vaults and bldg. 991)
Property Utilization and Disposal
(P.U. & D. ) container storage
facilities
Swinerator and Wai berg (S&W)
bldg. 980 container storage facility
S&W contractor storage yard
Bldg. 885 drum storage area
Bldg. 334 cargo container area
Bldg. 444/453 drum storage area
Date(s)
Operated
Unknown
1974(?) to
present
1960s-1970s
1968
1952 to present
1974-1985
1980 to present
1970-1985
Mid-1950s to
present
1984- 1986
Late 1960s to
1986
Materials
Handled
Hydrogen peroxide
Solvents, metal
shavings with
lathe coolants/
used oils/battery
acids
Unknown solvents
Plutonium con-
taminated oils/
lathe coolant
(70% hydraulic
oil - 30% carbon
tetrachloride)
Uranium/plutonium/
beryllium
Oil with hazardous
constituents/low
level radioactivity
Used oil/xylene
Solvents/oils/
toluene/mineral
spirits
Oils/solvents/
low level
radioactivity
Oils/solvents/
coolants/
possible low level
radioactivity
Oils/solvents/
possible radio-
actives
Activity
Land disposal
Storage
Training
Spills
Storage
Storage
Storage
Storage
Storage
Storage
Storage
Approximate
Dimensions
25'x50'
260'xlOOO'
50'x50'
6000 'x60'
220 'x 340'
60'x60'
25x25'
300'x400'
2 10'x20'
areas
8'x20'
1700 ft.2
(irregular)
Comments
One drum of hydrogen per-
oxide buried in chemical
storage area
Leaks from materials in
storage have contaminated
soi 1
Waste solvents burned on
ground for fire training
Spills on road resulted
during transport of drums
from 903 storage area to
treatment; asphalt seal-
coated
Leaks during storage of
materials
Container and dumpster
storage areas; possible
spills
Spills from containers
Spills from containers
Spills from containers
Drum storage in cargo
container
Spills from containers
183 Gas detoxification area
(Bldg. 952)
1982-1983
Nitrogen oxide/
chloride/hydrogen
sulfide/sulfur
tetrafluoride/
methane/hydrogen
fluoride/ammonia
Treatment
20'x50' Gases detoxified in
bldg.; residual glassware
was rinsed, disposed in
landfill
-------
Table 5 (cont.)
Reference
Number* Unit
184 Bldg. 991 steam cleaning area
Date(s)
Operated
1953-1978
Materials
Handled
Unknown radio-
active compounds
Activity
Land disposal
Approximate
Dimensions
50'xSO'
Comments
Area may have been used
to steam clean radio-
active equipment and
drums; effluent collected
and treated
185 Bldg. 707 solvent spill
186 Process line near valve vault 12
187 Acid leaks
(Bldg. 443/444)
188 Acid leak
(Bldg. 374)
189
190
Multiple acid spills
(Bldg. 881)
Caustic leak
(400 area)
Nov. 19, 1986
Oct. 24, 1986
1970
1983
Unknown
1978
191 Hydrogen peroxide spill
(400 area)
192 Antifreeze discharge
193 Steam condensate leak
(400 area)
194 Steam condensate leak
(700 area)
1981
1980
1979
1979
1,1,1-trichloro- Spill
ethylene
Uranium con- Spill
taminated process
waste/unknown
chemicals
Sulfuric acid Leak
Nitric/ Leak
hydrochloric
acid
Acids Spill
Sodium hydroxide Spill
Hydrogen peroxide Spill
Ethylene glycol Spill
Steam condensate/ Leak
amines
Steam condensate/ Leak
amines
30'x60' Drum leaked about 5
gallons solvent; liquid
collected with sorbent
30x100' Both primary and second-
ary process waste lines
broke and leaked waste.
Some soils removed
1500 gallons acid leaked
from bldg. 443, flowed
eastward, several hundred
gallons spilled north of
bldg. 444
Leaked near east gate of
bdlg. 374
Acid spilled north and
west of bldg. 881
Material released from
steam plant catch basin;
diverted to pond B-l
(South Walnut Creek);
neutralized and pumped to
solar evaporation pond
55-gallon drum ruptured;
liquid confined in hole;
covered with soil
Spilled through bldg. 708
floor drain; diverted to
pond B-l
Steam condensate line
leaked; line out of
service
Leak near bldg. 707;
liquid diverted to pond
B-4
-------
Table 5 (cont.)
Reference
Number* Unit
195 Nickel carbonyl disposal
196 Water treatment plant backwash pond
197 Scrap metal disposal sites
Date(s)
Operated
Unknown
1970s
Pre- 1980s
Materials
Handled
Nickel carbonyl
Aluminum sulfate,
lime, chlorine
Unknown scrap
metal possibly
transformers
Activity
Land disposal
Land disposal
Land disposal
Approximate
Dimensions Comments
Gas vented from bottles
lowered into hole; sev-
eral bottles buried
Backwash disposed in sur-
face impoundment on south
side of bldg. 124; pond
"destroyed" when surface
drainage collection
rerouted.
Metal buried in two loca-
tions southwest of bldg.
559; removed early 1980s
* Reference to Figure 6
-fs.
en
-------
T
N
500
0 500 1000
APPROXIMATE
SCALE (FT.)
fifJi ^—.llsiiu • «"•*
•sai
in*
Q era -|MJ
IM« *U*
14110
(after ch«n & associates. Nov. 86)
MOtCl MACDVC KAfll UWTI 14« tnt IM • 1M INLMMOt,
ta-
ll* k 1»*
J«J
141.1
l«.<
U4J
IJ4J
|> na
114.1
LEGEND
^
LOCATION OF INACTIVE WASTE UNITS
101 WASTE UNIT REFERENCE NUMBER
FIGURE 6
SOLID WASTE MANAGEMENT UNITS AT THE ROCKY FLATS PLANT
-------
47
Units Requiring RCRA Ground-Water Monitoring
These are units requiring ground-water monitoring under State and
Federal hazardous waste regulations at the time of the Task Force investigation
and include:
Solar evaporation ponds
West spray field
Active landfill
Solar Evaporation Ponds
Rocky Flats has used a series of surface impoundments for waste
storage/evaporation. The first pond, constructed in December 1953, was about
100 feet by 200 feet, clay lined and located near 207C pond [Figure 6]. This
pond was reconstructed in 1970 to form the present 207C pond. Impoundments
207A and 207B (a series of three ponds, designated as North, Center and
South) were placed in service in 1956 and 1960, respectively. The 207
impoundments originally were lined with asphalt over wooden planking. These
linings cracked and slumped (resulting in leakage) and were (with the possible
exception of 207C) relined at least once with asphaltic concrete, PETROMAT®,
burlap and asphalt. Pond 207B-South was relined with high density polyethy-
lene of unspecified thickness.
Estimated operating dimensions and capacities for the evaporation
ponds are given in Table 6.
® PETROMA T is a registered trademark and will appear hereafter without ®.
-------
48
Table 6
SOLAR EVAPORATION DIMENSIONS
(from March 1987 Closure Plan)
Pond
Designation
207A
207B - north
207B - center
207B - south
207C
Liquid
Coverage*
(feet)
230 x 505
175x245
175x245
175x245
155x245
Maximum
Depth*
(feet)
7.5
6.5
6.5
5.5
7.0
Maximum
Volume*
(x106 gallons)
5.7
1.7
1.7
1.5
1.2
With 2 feet freeboard
As a result of leakage from these impoundments, six interceptor trenches
were installed in the 1970's in the hillside just north of the units to intercept
leachate prior to any contamination reaching North Walnut Creek. Liquid
collected in the trenches was pumped back to the 207A and B ponds. A french
drain system, which drains to a wet well, was installed in 1980 and 1981 to
replace the trenches (which are no longer used). Liquids collected in the wet
well are currently pumped to the 207B-North and Center ponds.
Historically, the impoundments were used to store/evaporate various
process aqueous wastes including those with low-level radioactivity, high
nitrates, acids and aluminum hydroxide. Other wastes thought to have been
placed in these units include sanitary sewage sludge from the onsite treatment
plant, lithium metal, sodium nitrite, ferric chloride, lithium chloride, tertiary
treated sanitary effluent, ammonium persulfite, hexavalent chromium, cyanide
solution and hydrochloric, nitric and sulfuric acids. Low concentrations of
various solvents used at Rocky Flats may also have been present in aqueous
wastes placed in the impoundments.
Rocky Flats is in the process of closing these surface impoundments.
Solids are being removed from 207A. Ponds 207B-North and Center are
receiving leachate from the french drain collection system. Pond 207B-South
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49
has not been used regularly since 1985/1986 and is for emergency use and
evaporation of liquid from 207A.
The facility has conducted sampling and analysis of liquid/sludge from
the surface impoundments. The results indicate the presence of both
radioactive and hazardous constituents in both liquid and sludge portions of the
surface impoundments.
Between 1977 and October 1985, liquid from 207B-North was sprayed
on the west spray field (see following discussion).
West Spray Field
Rocky Flats spray irrigated liquid from the solar evaporation ponds
(207B-north and center) onto an area west of the process facility [Figure 6]
from 1977* (1982) to October 1985. Although direct application was made on
38.8 acres, DOE/Rockwell documents indicate that about 105 acres were
probably affected due to wind-blown spray, runon and runoff.
Liquid application has been by moving spray irrigation lines mounted on
metal wheels, fixed irrigation lines and impulse cannons. Irrigation occurred
intermittently whenever ponds 207B-North or Center reached storage capacity.
The application rates were reportedly based on internal policy generally based
on nitrate loadings and visual physical effects (erosion, runoff).
Although complete analysis of the constituents present in the irrigated
liquid is not available, some general analyses were made in 1984 and 1985.
Nitrates ranged from below detection limits to over 1,350 parts per million
(ppm), pH ranged from 7.4 to 11.2, gross alpha activity varied between 59 and
323 pCi/L and gross beta between 74 and 163 pCi/L Silver was found at 0.082
ppm and selenium at 0.02 ppm (both above primary drinking water standards of
0.05 ppm and 0.01 ppm, respectively). Organics, such as trichloroethane,
April 1987 Waste Identification and Characterization Study Report indicates 1977 as the
starting date while the facility RCRA Part B permit application Closure Plan cites the starting
date as 1982.
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50
trichloroethene, carbon tetrachloride, chloroform and acetone, have also been
detected in "trace" amounts (1 to 3 ppb).
DOE and Rockwell have been studying contaminant distribution of the
west spray field and have proposed to close the units according to a closure
plan submitted in the November 1986 Part B permit application.
Active Landfill
Use of the present Rocky Flats landfill began in 1968 and is located in
the western end of an unnamed tributary to North alnut Creek, north of the
process facility [Figure 6]. Prior to initial landfilling, the west end of the tributary
was filled with soil (from onsite) to a depth of 5 feet across the width of the
channel and about 20 feet in length. A surface water interceptor ditch was
constructed to divert surface runoff around the landfill. In 1974, a ground-water/
leachate collection system was installed around the base of the landfill (below
the waste level) to intercept and divert ground water flowing toward the waste
and remove any leachate generated within the landfill. Both systems were
reportedly keyed to the underlying bedrock and discharged to the east or west
landfill ponds (since removed).
Since 1981, the landfill has expanded beyond the confines of these
collection systems. Two slurry walls (one north and one south of the landfill)
were installed in 1981 to allow for expansion. The slurry walls, reportedly
keyed into bedrock, are connected to the ground-water/leachate collection
system on the west and extend about 700 feet eastward (the direction of landfill
working face). No leachate has reportedly been collected in the leachate
system.
Over 100,000 cubic yards of waste have been disposed of in the landfill,
which covers more than 25 acres. The November 1986 RCRA Part B permit
application for the Rocky Flats plant indicates that about 330 of the 1,500 waste
streams known to be generated at the facility have been disposed of in the
landfill. Of these, about 240 are considered to be nonhazardous items such as
genera! office trash, empty containers, Kimwipes, rags, dried sludge and
electrical components (wire, batteries, etc.). About 90 of the waste streams are
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51
hazardous or have hazardous constituents. These include: Kimwipes and rags
contaminated with paint, solvents; resins, filters (oil, water, paint, etc.);
containers with acids, caustics and solvents; and metal cuttings and shavings
with hydraulic oil and carbon tetrachloride. A tritium source has also been
identified in the landfill. Daily monitoring of the disposed waste for radioactivity
did not begin until 1973.
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52
SITE HYDROGEOLOGY
The Rocky Flats plant is currently involved in a phased program of
characterizing site geology, hydrogeology and water quality in suspected areas
of contamination. These activities are being conducted under requirements of
both the DOE Comprehensive Environmental Assessment and Response
Program (CEARP) and the July 1986 Compliance Agreement between DOE,
EPA and CDH. Unless otherwise specified, the information presented here is a
summary of that reported in the November 1986 Part B and discussions with
facility personnel and contractors during the Task Force inspection.
HYDROGEOLOGIC UNITS
The plant is on the northwestern flank of the Denver Basin [Figure 7],
which is an asymmetrical syncline with a north-south trending axis. The
syncline has a steep western flank and a more gently dipping eastern flank.
Bedrock strikes from north to south and dips from 5 to 50° to the east in the
vicinity of the plant. The most steeply dipping beds are west of the plant site.
Beneath and east of the plant, dips are relatively constant, at approximately 10°.
Siirficial deposits are primarily the Rocky Flats Alluvium and colluvial materials;
u,.jerlying bedrock includes the Arapahoe, Laramie, Fox Hills and Pierre Shale
Formations.
The Rocky Flats Alluvium, mixed alluvial materials in the valleys and
colluvium (slope wash) [Figure 8] were deposited in alluvial fans at the base of
the Colorado Front Range Mountains. Following deposition, the material was
partially removed by erosion and the resulting drainages were infilled with more
recent sediments. The Rocky Flats Alluvium consists of poorly-sorted sand,
gravel and cobbles. The largest materials are generally cobble-sized, but
occasionally boulders are also present in the sand and gravel matrix. The
alluvium is locally cemented with calcium carbonate. The thickness of the
alluvium ranges from 100 feet, on the west, to less than 11 feet on the eastern
edge of the plant. The alluvial deposits in the drainages comprise reworked
and weathered Rocky Flats Alluvium and weathered bedrock. Colluvial
materials cover most of the slopes between the top of the Rocky Flats Alluvium
and the channel bottoms. These materials are derived from both the Rocky
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53
WYOMING
Gotten Fault
i KANSAS
EXPLANATION
X AX»
FAULT
STRUCTURE CONTOURS OH TOP OF PRECAM8RIAN BASEXCNT
MU9
(After Hydro-Search, July 1986)
Figure 7
Structure of the Denver Basin
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Volley Fill
(After Hydro-Search, July 1986)
Surficial Geology
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55
Flats Alluvium and the bedrock. They are generally fine to medium grained
sands and silts with occasional gravel and boulders. The thickness ranges from
0 to 5 feet.
The underlying bedrock includes about 13,000 feet of sedimentary rock,
deposited as a result of several episodes of mountain building, and several
oceanic transgression and regression cycles. The sedimentary rock overlies
the Precambrian basement [Figure 9].
The Arapahoe Formation underlies the Rocky Flats Aluvium. It consists of
fluvial claystones with interbedded lenticular sandstones and siltstones
deposited following major uplift of the Front Range and downwarp of the Denver
Basin. The claystones are olive grey to dark grey, poorly cemented, silty and
contain up to 15% organic material. The sandstones are light grey to yellowish
grey, very fine to medium grained, with approximately 15% silt and clay. The
siltstones exhibit the same coloration, constituents and sedimentary structures
as the sandstones; however, they consist predominantly of silt-sized particles.
Weathering of the Arapahoe Formation has penetrated to depths ranging
from 10 to 40 feet below the base of the surficial materials. The weathered zone
is slightly fractured and mottled dark yellowish brown and contains iron oxide
concretions. Unweathered bedrock generally occurs between 18 and 60 feet
below ground surface and is also slightly fractured.
The Laramie and Fox Hills Formations contain sandstones, siltstones,
claystones and coals deposited in fluvial-deltaic and lacustrine environments.
The deposition of the Laramie was influenced and then stopped by the
Laramide Orogeny, a major mountain building event that caused the uplift of the
Colorado Front Range of mountains. The Laramie Formation is further divided
into the upper claystone unit consisting of dark olive grey, poorly cemented
claystones and the lower sandstone unit which consists of light to medium grey,
very fine to medium grained, well sorted sandstones.
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WEST
EAST
ROCKY FLATS ALLUVIUM
LARAMIE FORMATION
FOX HILLS
SANDSTONE
VERTICAL EXAQOEnATKN X 4
(After Hydro-Search, July 1986)
Figure 9
Generalized Geologic Cr os s - Se c t \ on
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57
The Fox Hills Formation is a marine sandstone deposited during the
regression of the Cretaceous seaway from the Denver Basin. The sandstones
are olive to light brown, fine-grained, well sorted, quartzose sands with up to
25% rock fragments. The sands are thinly bedded and display laminar or
planar crossbedding. Marine fossils are predominant in the lower portions of
the formation and terrestrial plant fossils are more abundant in the upper
portion. The contact between the Fox Hills and Laramie Formations is
gradational and determined by both the disappearance of marine fossils and
the change in color from light brown to light grey.
The Pierre Shale is an olive grey to dark grey, fossiliferous marine shale.
It consists of more than 5,600 feet of shales and siltstones. The contact between
the Pierre Shale and the Fox Hills Sandstone is gradational and intertongued.
The Rocky Flats Alluvium has been identified as the uppermost aquifer in
the November 1986 Part B and other hydrogeologic reports prepared by
consultants for DOE. These documents also indicate that some units of the
underlying Arapahoe Formation are hydraulically connected to the Rocky Flats
Alluvium. By regulatory definition (Part 260.10), the "uppermost aquifer" means
". . .the geologic formation nearest the natural ground surface that is an
aquifer, as well as lower aquifers that are hydraulically interconnected with this
aquifer within the facility's property boundary."
DOE/Rockwell have not adequately documented whether the "uppermost
aquifer" should include the Arapahoe Formation at the Rocky Flats plant. The
extent of hydraulic connection between the Rocky Flats Alluvium and the
permeable lenticular sandstones of the Arapahoe Formation, which may be
discontinuous, has not been adequately defined near the waste management
areas. For example, the hydrology and extent of sandstones in the Arapahoe
Formation that outcrop beneath the surface impoundments are poorly defined.
These sandstones should be considered as part of the uppermost aquifer for
monitoring purposes if they are hydraulically connected to the Rocky Flats
Alluvium and could provide pathways for migration of releases from the
regulated units.
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58
The extent of hydraulic interconnection between the sandstones of the
Arapahoe Formation and the overlying materials is being studied as part of both
the CEARP and Compliance Agreement activities.
GROUND-WATER FLOW. DIRECTIONS AND RATES
Although the facility has ongoing hydrogeologic studies, the following
information was available regarding ground-water flow. Conflicting information
regarding vertical gradients and hydraulic conductivities makes current
information regarding flow directions and rates suspect. Further drilling and
evaluation of existing and new wells is necessary to adequately characterize
areas of interconnection, direction (i.e., downward or lateral ground-water flow
directions), and the rates of ground-water flow.
Shallow ground-water flow occurs in the Rocky Flats Alluvium and other
alluvial materials under unconfined conditions. The aquifer is recharged by
infiltration of precipitation, irrigation and surface water diversion canals. In
addition, retention ponds in the drainages onsite may recharge the alluvial
aquifer. The alluvial aquifer is dynamic and exhibits large water level changes
in response to precipitation and seasonal variations.
Flow directions in the alluvial aquifer generally follow the topography,
flowing to the east and toward drainages. Flow is also influenced by the
configuration of the top of bedrock. Plant operations, such as dewatering by
foundation drains and heavy irrigation of small areas (spray fields) also modify
ground-water flow in the alluvial aquifer.
Facility studies of the potentiometric conditions in the surface material
identified large areas where there appears to be little or no saturated thickness.
This is due to bedrock nonconformities that either divert ground-water or cause
it to surface and flow over the surface. Other ground-water is lost to the
atmosphere as either evaporation or transpiration. Because of these anomalies
there are large areas of the facility where wells completed through the Rocky
Flats Alluvium are dry.
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59
The rate of ground-water flow in the alluvial aquifer has not been
adequately characterized by DOE or Rockwell. Two 1986 hydrogeologic
reports prepared for DOE/Rockwell* cited hydraulic conductivities and velocities
which vary by several orders of magnitude using data from the same wells.
The hydrogeologic reports characterize a strong downward gradient
between the alluvial and bedrock aquifers; however, data from paired bedrock
and alluvial wells have variable vertical gradients ranging from 0.2 to 1.0.
Additional wells need to be drilled near the regulated waste management units
to further characterize areas of significant downward flow.
Ground-water flow in the bedrock aquifer of the Arapahoe Formation
occurs in lenticular sandstones contained within the claystones. The
sandstones are fine grained, silty and clayey units averaging about 5 feet in
thickness. Recharge to the Arapahoe sandstones occurs where there is direct
contact with the overlying alluvium or leakage through claystones in contact
with the alluvium. The units are discontinuous along the strike (north-south) but
may be continuous in the down-dip direction (east). Ground-water in the
sandstone flows east toward the Platte River.
The hydraulic conductivity of the Arapahoe Formation has been esti-
mated by Rockwell and contractor personnel to range from 1 X 10'7 centimeters
per second (cm/sec) for the claystones to 2 X 10'6 cm/sec for the sandstones.
The rate of ground-water movement through the sandstone has been estimated
by the contractor to be 0.6 feet per year. Wells drilled as part of the CEARP and
Compliance Agreement evaluations should also be tested to determine if these
values are appropriate.
If the Arapahoe Formation is hydraulically connected to the alluvial
aquifer, it should be monitored as part of the uppermost aquifer. The waste
management units are completed into the uppermost aquifer and further study
is necessary to determine their impact on both the alluvial and the bedrock
components of the uppermost aquifer. The extent of the hydraulic connection
The Draft Work Plan (Appendix E-2 in Pan: B permit application) titled, "Geological and
Hydrogeological Data Summary,"pages 14 through 22, dated July 21, 1986, and "Closure
Plan for the West Spray Field," dated November 28, 1986
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60
between the alluvial and bedrock aquifers should be further evaluated to
determine the depth and geologic unit that monitoring wells need to be
completed. Additional work is necessary to characterize ground-water flow in
the uppermost aquifer and to determine the extent of any effects that waste
handling have had on ground-water quality.
SURFACE WATER HYDROLOGY
The direction of surface water flow affects ground-water flow in the Rocky
Flats Alluvium. Three intermittent streams drain the Rocky Flats Plant and flow
generally from west to east [Figure 10], the same direction as ground-water
flow. Ground water recharges the surface seeps and streams in portions of the
property, while surface streams feed ground-water flow in other portions of the
facility. Rock Creek drains the northwestern corner of the facility and flows to
the northeast in the buffer zone to its confluence with Coal Creek. Woman
Creek drains the southern portion of the plant and flows eastward to Standley
Lake. North and South Walnut Creeks and an unnamed tributary drain the
remainder of the site. The three forks of Walnut Creek join in the buffer zone
and flow to Great Western Reservoir approximately 1 mile east.
A series of dams, retention ponds and diversion ditches have been
constructed at the plant to control surface water. A series of 11 retention ponds
are located in the drainages of Walnut and Woman Creeks and are designated
as A, B and C series ponds. These ponds are for surface water run-off control
and spill control. Another retention pond is located on the unnamed tributary of
Walnut Creek, downstream of the present landfill. Following analysis to
determine whether the pond water meets the NPDES permit limitations, the
water is spray irrigated in an area south of the landfill.
The Church and McKay diversion ditches cross the northern portion of
the facility. Both carry water diverted from Coal Creek to the Great Western
Reservoir. A diversion structure has been built in northern Walnut Creek
upstream of the plant to divert McKay ditch out of the drainage. The ditches
parallel each other north of the present landfill and enter Walnut Creek
drainage downstream of the confluence of the north and south forks. There are
also a number of runoff control ditches in the vicinity of the plant.
-------
(After Hydro-Search, July 1986)
Map of Surface Drainage and Retention Ponds
at Rocky Flats Plant
Figure 10
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62
GROUND-WATER MONITORING DURING INTERIM STATUS
Ground-water monitoring at the Rocky Fiats plant has been conducted
under the requirements of State and Federal interim status regulations. The
RCRA program in Colorado was administered by EPA from November 18, 1981
until November 2, 1984, when CDH became authorized. During this time,
however, CDH and EPA had a Memorandum of Understanding, dated
December 21, 1981, which specified that the two parties would enter into a
Cooperative Arrangement for administration of the program in Colorado.
The objective of the Cooperative Arrangement was to transfer authorities
of the Federal RCRA program to the State with a gradual progression of
responsibility, enabling EPA personnel to train and oversee State
implementation until State regulatory authority could be enacted. Colorado
Hazardous Waste Regulations (6 CCR 1007-3) became effective on
November 2, 1984 and CDH was granted final authorization for the RCRA
program (RCRA equivalents to 40 CFR Parts 264, 265 and 270) on the same
day.
DOE challenged the applicability of the Federal RCRA requirements to
DOE facilities operating under the Atomic Energy Act (AEA) of 1954 because of
interpreted inconsistencies of the RCRA regulations with the AEA. On
February 22, 1984, the Secretary of the Department of Energy and the
Administrator of the EPA signed a Memorandum of Understanding [Appendix A]
regarding respective responsibilities for management of hazardous and
radioactive mixed waste.
In this agreement, DOE agreed to require AEA facilities that treat, store or
dispose of hazardous waste or radioactive mixed waste onsite, to comply with
the requirements of 40 CFR Part 265, until EPA issued a Hazardous Waste
Compliance Plan (HWCP - equivalent to a RCRA permit) to the facility. EPA
was required to consult with affected states in issuing an HWCP and concerning
any violations of standards, appropriate remedies and compliance schedules.
In addition, a Federal Court ruling in Tennessee, Legal Environmental
Assistance Foundation (LEAF), Inc. v. Hodel on April 13, 1984 determined that
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63
the RCRA program was not inconsistent with the AEA and required DOE to
comply with RCRA for hazardous waste management [Appendix B].
DOE submitted a ground-water monitoring program plan to EPA Region
VIII on November 19, 1981 for the Rocky Flats plant. The submission stated the
DOE position regarding inconsistencies of the RCRA program with AEA.
However, the letter stated that "...DOE intends to provide an essentially
equivalent program as a matter of interagency cooperation to demonstrate the
existence and adequacy of the Rocky Flats ground-water monitoring program."
The submission of this "essentially equivalent" program plan is consistent
with DOE internal orders dated December 13, 1982 (DOE Order 5480.2 issued
by DOE headquarters) and October 31, 1983 (AL Order 5480.2, subsequently
issued by the Albuquerque Operations Office to the Rocky Flats Plant). The
orders required DOE facilities to establish ground-water monitoring systems, in
accordance with 40 CFR 265, Subpart F, and that these systems be in
compliance with the technical requirements of 40 CFR 260 through 265. This
is also consistent with the 1984 MOU, the LEAF decision, and the way in which
other EPA programs are administered at DOE facilities.
The interim status ground-water monitoring program implemented in
1981, was a "detection monitoring" system. Documents reviewed during the
inspection revealed that the 1960 and 1971 series of wells were drilled to
determine the extent of the migration of contaminants leaking from the solar
impoundments. When an owner or operator knows that ground-water
monitoring for indicator parameters, in accordance with 265.91 and 265.92,
would show statistically significant differences when compared to background
values [265.93(b)]( he may install, operate and maintain an alternate monitoring
system [equivalent to a ground-water quality assessment program, as described
in 265.93(d)(4)]. Although contaminants had been documented in ground water
downgradient from the solar impoundments, DOE proposed a detection
monitoring program for the facility. This action should have only delayed
implementing a ground-water quality assessment program for about 11/2 to
2 years (when the statistical comparison would have been made). However,
the assessment program was not implemented until after the compliance
agreement was signed in 1986.
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64
The following is an evaluation of the interim status ground-water
monitoring program between November of 1981, when the ground-water
monitoring provisions of the RCRA regulations became effective, and April
1987, when the Task Force investigation was conducted. This section
addresses:
Regulatory requirements
Ground-water sampling and analysis plan
Monitoring wells
Sample collection and handling procedures
Sample analysis and data quality assessment
Ground-water Quality Assessment Program Outline
REGULATORY REQUIREMENTS
The RCRA interim status program was administered by EPA from
November 1981 until November 1984, when CDH was delegated final
authorization. Interim status ground-water monitoring requirements under the
EPA program are contained in 40 CFR Part 265, Subpart F. Equivalent
requirements under the CDH program are in Part 265 of the Colorado
Hazardous Waste Regulations. The State regulations are titled and numbered
the same as the Federal counterparts, and are nearly identical to the Federal
regulations. However, there is no provision for receiving a waiver from the
ground-water monitoring requirements under the CDH program.
GROUND-WATER SAMPLING AND ANALYSIS PLAN
Under the EPA-administered program, DOE/Rockwell developed a plan
titled "Groundwater Monitoring Program Plan." The plan was submitted to EPA
Region VIII in November 1981 and was, ostensibly, followed until mid-1985,
when detection monitoring was suspended. After the Compliance Agreement
was completed in 1986, the first phase of the assessment program plan for the
evaporation ponds was included in the "Draft Work Plan, Geological and
Hydrological Site Characterization" (Work Plan) dated July 21, 1986.
Sampling and analysis procedures were described in a companion document
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65
titled "Draft Project Operations Plan, Geological and Hydrological Site
Characterization," dated July 25, 1986. Ground-water monitoring procedures in
the Project Operations Plan (POP) superseded those in the 1981 plan.
Procedures in the 1981 plan were evaluated by Task Force personnel for
compliance with RCRA regulations; the POP procedures were evaluated for
adequacy and completeness.
1981 Sampling and Analysis Plan
The 1981 plan addressed all the requirements in Part 265.92(a). It did
not, however, contain or reference necessary details of the techniques used
and procedures to be followed; therefore, the 1981 plan is inadequate. The
plan was followed during interim status sampling in February, May, August and
December of 1982 (initial year); November and June of 1983; May, June and
August of 1984; and March, April and July of 1985.
The 1981 plan cites a Rockwell sampling manual* and EPA procedures
manuals for sample collection, sample preservation and handling, analytical
procedures and chain-of-custody. The Rockwell sampling manuals are
inadequate for ground-water sampling and the referenced EPA manuals
(EPA-530/SW-611, dated August 1977; and EPA-600/4-79-020, dated March
1979), contain multiple procedures for sample collection, preservation and
analysis, each of which can yield different results. The referenced documents
contain multiple methods for both purging and sampling wells. The cited
references do not include procedures for water level measurements, field
measurements (pH, conductivity and temperature) or quality assurance/duality
control measures (i.e., field and equipment blanks or duplicate samples).
The 1981 sampling and analysis plan stated that the facility sampling
procedures manual (EA-S-3) would be updated to include appropriate ground-
water sampling procedures, but this was not done. The equipment list in
EA-S-3 does not include bailers, or submersible pumps for sampling wells;
Internal procedures manual titled, "Rocky Flats Plant Environmental Analysis and Control
Sampling Procedure - Surface Waters and Ground Water EA-S-3,"updated in 1982, 1984
and 1986 and given new document number EAC-S-3.
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66
rather, it contains equipment primarily for surface water sampling. In addition,
the sampling and analysis plan does not indicate whether sampling equipment
is reused or dedicated to a well, nor does it include decontamination
procedures.
The plan also indicated that sample preservation and shipment
procedures were to be included in an updated EA-S-3 manual, but they were
not included until the 1986 revision. The revised sample preservation section
was to be in accordance with recommendations under sections 6.4 and 6.5 in
EPA 530/SW-611. The referenced sections do not contain preservation
methods for several of the required monitoring parameters including TOX, pes-
ticides and radionuclides. Therefore, the plan does not comply with
265.92(a)(2).
The 1981 plan states that analytical procedures followed for the
ground-water samples are to be in accordance with EPA-600/4-79-020
"Methods for Chemical Analysis of Water and Wastes;" however, this document
does not contain procedures for analysis of pesticides, radionuclides and TOX.
Therefore, not all of the analytical procedures are referenced, as required by
265.92(a)(3). The analytical procedures cited are EPA methods; however, the
referenced document contains multiple procedures for several of the sampled
parameters (e.g., two procedures for both iron and manganese, three for both
chloride and phenol and four for sulfate). Different methods can result in
different analytical biases. To ensure uniform analytical procedures during
required monitoring, the specific methods used need to be listed in the
sampling plan.
Chain-of-custody procedures were also supposed to be incorporated into
a revised EA-S-3 manual. However, revisions in 1982, 1984 and 1986, did not
include chain-of-custody procedures. Rockwell laboratory personnel stated that
chain-of-custody procedures were not used until recently. An updated chain-of-
custody form had been drafted, but had not been put into use by the time of the
Task Force inspection.
The plan specifies that analytical results of the ground-water monitoring
program were to be reported by Rockwell to DOE via the annual report. When
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67
Rockwell personnel were requested to identify the referenced annual reports,
they identified a series of documents titled "Annual Environmental Monitoring
Report." These reports for 1981 through 1986 were reviewed as part of the
inspection. The reports did not comply with 265.94 because they do not contain
the required water level measurements or required analytical results for the
designated RCRA wells [265.94(a)(1)].
1986 Sampling and Analysis Plan
The 1986 sampling and analysis plan (POP) was better than the 1981
sampling plan; however, it was incomplete and was being revised during the
Task Force inspection. The POP contained more detail about sample
collection, handling, shipping and chain-of-custody; however, several important
details were missing. The plan needs to include details about purging and
sample collection including procedures for sampling slowly-recharging wells
and very low yield wells, which are common at the Rocky Flats plant.
The 1986 plan does not specify whether dedicated equipment is used in
the wells. Decontamination of water level instruments and sampling equipment
is mentioned; however, the procedures are not described. The plan states that
all sample bottles will be rinsed with well water before filling. In wells of low
yield, as most of the facility wells are, water is lost in rinsing bottles and a full
complement of samples is not taken. Rinsing bottles may not be appropriate for
several aliquots particularly metals and VOA. According to Rockwell personnel,
sampling bottles are prepared by the laboratory with preservatives prior to
sampling. Rinsing sample containers with sample water in the field may wash
out the preservatives.
Filtering procedures are included in the plan; however, the sample
aliquots to be filtered are not specified. Likewise, the sample preservation
procedures need to indicate where/when samples will be preserved.
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MONITORING WELL NETWORK
The monitoring well network for the interim status "equivalent"
ground-water monitoring program, submitted by DOE to EPA on November 19,
1981 consisted of 17 existing wells [Figure 11]. The wells were drilled as part of
a 56-well ground-water monitoring network established by DOE between 1960
and 1981 for detecting radioactivity.
DOE and Rockwell personnel knew that the solar impoundments leaked
before the detection monitoring program was implemented and had ample data
showing elevated levels of nitrates and total dissolved solids in the wells in the
vicinity of the solar impoundments. Documents reviewed during the inspection
indicate that the 1960 series of wells "were drilled...to check for movement of
materials from the solar evaporation ponds."* This included wells 1-60, 2-60,
3-60, 4-60, 5-60 and 6-60. The 1971 series ".. .were drilled to determine if
significant migration of radioactivity was occurring from the holding ponds"
(includes wells 3-71, 5-71 and 6-71).*
Seventy new wells were installed in 1986 as part of the investigations
specified in the Compliance Agreement. The following is an evaluation of the
1981 well network for compliance with RCRA regulations for a detection
monitoring system. The 1986 well network is evaluated for construction
adequacy.
Number. Location and Construction of Monitoring Wells
1981 Monitoring Well Network
The 1981 monitoring well network fulfilled the minimum requirements for
the number of detection monitoring wells, one upgradient and three
downgradient; however, the locations of these wells were not in compliance
with RCRA requirements [265.91 (a)(1 ) and (2), and (b)].
"An Historical Evaluation of Radiological and Chemical Properties of Water from Hydrologic
Test Wells at Rocky Flats" EA-376-81-231, N.D. Hoffman Environmental Analysis, April 15,
1982, page 1
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Legend
2-81
• Monitoring Well Location
^ Holding Ponds
2 Solar Evaporation Ponds
l Buildings
— •Selected Roads
1-81
3-71
I
1-661
I
I
_L
/ m
wlKSf^^^K^F
06-71 0 1-60
2-60 •**X.
2-66
L 6-60"*
'&R PIT'
*^™Hw
(After Hydro-Search, July 1986)
5-71 e» 3-81
f 17-74
18-74
Scale in feet:
I 1 1
0 500 1000
V-^
^jo«»an
CreeJV
Interim Status Monitoring Well Network
Figure 11
-N-
cn
i-o
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70
The single designated upgradient well (1-66) is completed only in a
bedrock aquifer flow zone and is about 5,000 feet from the evaporation ponds.
The uppermost aquifer at the Rocky Flats Plant includes the Rocky Flats
Alluvium, which overlies the bedrock zone monitored by the upgradient well,
and is monitored by several of the downgradient designated RCRA wells.
RCRA regulations [265.91 (a)(1)] require that the number, locations and depths
of upgradient wells be sufficient to yield ground-water samples that are
representative of background ground-water quality in the uppermost aquifer
near the facility. Therefore, the single upgradient well does not comply with the
regulations because the alluvial flow zones are not monitored. Furthermore,
because of the excessive distance to the well from the regulated units, samples
from the well may not be indicative of background ground-water quality.
The other 16 wells were designated as downgradient wells and ranged
in depth from 7 to 153 feet. The wells were chosen to monitor both the solar
impoundments and the retaining ponds. The solar impoundments were the
only waste management unit designated by DOE/Rockwell as requiring ground-
water monitoring during interim status. The retaining ponds never received
hazardous wastes, according to Rockwell personnel; however, they were used
before 1979, to hold various wastes containing nitrates and low levels of
radioactivity. Only 4 of the 16 wells are near the perimeter of the waste
management area. The 4 wells are located nearly 200 feet from the
impoundments and are not at the limit of the waste management area, as
required by 265.91 (b).
Of the 17 wells included in the interim status program, 3 wells (numbered
5-60, 5-71 and 18-74) were not capable of yielding ground-water samples, as
required by 265.91 (a). These wells were reported to be "dry" during 1975
through 1979, yet were included in the RCRA monitoring program. They were
also dry during interim status monitoring.
Construction records were available for only 3 of the 17 wells in the
interim status monitoring network. Therefore, DOE/Rockwell cannot adequately
document compliance with 265.91 (c), which requires that the wells be cased in
a manner that maintains the integrity of the well bore. In addition, only six of the
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wells have lithologic logs; therefore, the monitored aquifer flow zone(s) is not
known with certainty.
Where construction reports for the interim status wells were available, the
records were not complete. The records include the length of casing and the
casing type, but do not include the screened interval, slot size or specifications
of the gravel or sand pack (i.e., length, volume, grain size, etc.). In addition,
nothing indicates the type or quantity of material used to grout the wells.
A contractor's evaluation of the interim status monitoring well network
reported that "because of poor documentation of well construction, both water
quality and water level data collected from the wells are questionable."* The
contractors recommendation was to plug the existing wells and drill new
monitoring wells.
1986 Monitoring Well Network
The new well network for the site characterization program was
completed in the summer of 1986 and consists of 96 wells. Of the 96 wells, 70
were installed in 1986 and 26 were installed between 1960 and 1982. The 26
older wells were included to provide some continuity with the previous site-wide
monitoring program. The new well network has significant construction
problems.
The 70 new wells were reportedly completed in accordance with
procedures in the Work Plan and POP. The drilling and completion procedures
in the Work Plan and expanded in the POP were generally adequate; however,
they were not always followed. Some of the well construction is suspect
because of conflicting reports on construction methods or poor drilling practices.
The bottom of numerous holes, according to construction diagrams, were not
backfilled with bentonite pellets (wells 7-86, 10-86, 11-86, 17-86, 20-86, 22-86,
25-86, 28-86, 29-86, 35-86, 42-86 and 43-86). These wells may be receiving
water from multiple water-bearing zones. The hole diameter proposed may not
Hydrogeologic Characterization of the Rocky Flats Plant, Golden, Colorado, prepared by
Hydro-Search, Inc., Decembers, 1985, Page 11
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72
be large enough to ensure placement of a proper filter pack, even with
centralizers on the screen (1 inch of filter pack, at most, around the screen). The
grain size analysis performed by the consultant was not included with the
construction information and DOE/Rockwell personnel do not have records of
the results. Therefore, Task Force personnel could not determine whether the
sand/gravel distribution for the screen slot size used was adequate. Several
wells were turbid when sampled by the Task Force, suggesting problems with
either the filter pack or the development of the wells.
Task Force samples from two wells (wells 8-86 and 48-86) were turbid
(milky white) and had elevated pH (samples from both wells had a pH of 11),
suggesting problems with the bentonite seal and/or the cement grout.
Construction records also indicate loss of cement circulation during completion.
Rockwell personnel reported that well 49-86 has similar problems.
Many of the well logs are either incomplete or inaccurate. Numerous
wells do not have completed well diagrams; therefore, DOE/Rockwell personnel
cannot document whether wells comply with the Work Plan. Numerous well
diagrams were also found to be inaccurate when the hydrogeologic contractor
was questioned during the Task Force inspection. Still other wells have
questionable construction, either due to incomplete field notes or contradictory
completion information. For example, completion data for well 12-86 indicates
that, if completed as described, the well is screened 11/2 feet into the bentonite
seal. Well 25-86 has a similar problem, with the recorded well screen
extending from 59 to 82 feet, filter pack from 66 to 83 feet and bentonite seal
from 64 to 66 feet. If accurate, this would indicate that the upper 7 feet of
screen extends through the entire length of the bentonite seal with an additional
5 feet extending into the cement grout. The well may be contaminated with
cement and/or bentonite.
Several wells have screens set at, or very near, the surface (wells 30-86,
38-86, 57-86) and could be contaminated by surface runoff if the cement seals
are inadequate. The construction records for well 38-86 indicate that the
screen extends from the ground surface to a depth of 11 feet. This well could
not have adequate surface seals and could not be adequately protected from
surface contamination if the screened interval is accurate.
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Several of the new wells did npt have locking well caps. Still, other wells
did not have concrete pads around the surface casing. Some of the wells with
surface pads had cracks in the pads. Each of these problems has the potential
to lead to contamination of the monitoring wells.
In summary, many of the new wells also have construction deficiencies.
Well construction data must be reviewed, corrected if in error and the adequacy
of the wells evaluated before they are accepted as fulfilling the Compliance
Agreement requirements.
ROCKWELL SAMPLE COLLECTION AND HANDLING PROCEDURES
During the inspection, water levels were measured in 38 wells and
samples were collected from 15 monitoring wells and 1 wet well, as discussed
in the Investigative Methods section. At each of the monitoring wells sampled,
Rockwell personnel measured the water level, calculated the purge volume,
purged stagnant water, and made field measurements for pH, specific
conductance and water temperature. These procedures were evaluated by the
Task Force.
The evaluation revealed that the sample collection and handling
procedures are generally acceptable; however, some problems were found with
field measurements for water temperature and specific conductance.
Furthermore, Rockwell personnel are not following all the procedures
referenced in the sampling and analysis plan. The sampling and analysis plan
needs to be updated to include the actual field procedures being followed by
Rockwell personnel. The Rockwell sampling procedures are described and
assessed in the following discussion.
Water Level Measurements
At the wellhead, the first step in collecting samples is to measure depth to
water from the top of casing using one of two electronic water level indicators;
an Olympia Actat Model No. 500, with a 500-foot cable, was used in the deeper
wells and a Well Wizard, with a 150-foot cable, was used at the remaining wells.
Both of these indicators consist of a reel with a control panel, cable and sensor.
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74
A two-conductor cable, which is marked in sequential increments (0.5 inch on
the Well Wizard; 5-foot on the Actat), connects the control panels to the sensors.
When the sensor makes contact with the water, an indicator light and/or buzzer
on the control panel are activated.
The cord and sensor are lowered into the casing until the sensor reached
water. The probe is raised and lowered in the well until the exact point of
contact is determined. The cable at the top of the casing is pinched by the
sampler's fingers and the distance from the bottom of his fingers to the next
lower cable marker is measured with a measuring tape. This distance is added
to the cable marker value to determine the depth to water. Following this
measurement, the probe is lowered to the bottom of the well to determine the
total depth for calculation of the water column volume. The probe is then
removed and the cable and the probe are brushed and washed with a nylon
bristle brush dipped in an Alconox and water solution, and rinsed with
deionized water.
Water level measurements were made on 38 monitoring wells before any
sampling activities were initiated. Duplicate water level measurements were
made on four of the wells. At three wells, the duplicate measurements were
identical to the first and differed by only 0.04 feet in the other one. The
reproducibility of the measurements was good and the procedure described
above is acceptable.
Purging
The volume of water in the casing (casing volume) is calculated by
multiplying the height of the water column by a conversion factor. Purge
volumes are then calculated by multiplying the casing volume by three.
Purge water is measured in a graduated plastic bucket. Slowly-
recharging wells are evacuated to dryness, all other wells are purged of three
casing volumes of water before sampling.
In wells where the calculated three-casing volumes is greater than 20
gallons, a Bennett pump is used to evacuate the water. Wells with less than 20
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gallons of water to be purged are bailed with Teflon bailers. The pump and the
last 3 to 5 feet of tubing are thoroughly cleaned (Alconox and water) and rinsed
with deionized water prior to reuse. Approximately 5 gallons of deionized water
are flushed through the tubing after a well has been purged. The bailers are
cleaned thoroughly with Alconox and water and rinsed with deionized water
prior to reuse. New polyethylene rope is cut for each well every time the well is
purged and sampled.
Purge water is disposed of on the ground near the well without being
tested to determine if it contains contaminants. If analytical data from the well
indicate that the water contains hazardous constituents, purge water from
further sampling of the well should be drummed and disposed of properly.
Otherwise, purging procedures are adequate.
Sample Collection and Preservation
After purging, Rockwell personnel remeasure the water level in each well
to determine if it has recharged sufficiently for sample collection. A well is
deemed technically dry by DOE/Rockwell if there is insufficient volume to
complete the volatile organic sample aliquots within 24 hours after the well has
been purged. Immediately before and after sample aliquots are collected, an
aliquot is collected for measuring field parameters including pH, conductivity
and temperature. Although the sampling and analysis plan also includes field
procedures for measuring dissolved oxygen, Rockwell personnel are no longer
making this measurement.
The pH is measured with a Van Waters and Rodgers Scientific Model 47
Mini-pH meter. The meter is calibrated first with a pH 7.0 buffer solution and
then with either 4.0 or 10.0 buffer solution depending on the expected range of
the sample. Conductivity is measured with a Cole Palmer model 1484-10
meter. The conductivity meter is field-calibrated at each well with standards
prepared at the beginning of each day in the Rockwell general laboratory.
According to the 1986 sampling and analysis plan, temperature is to be
measured using a thermometer calibrated weekly against a National Bureau of
Standards certified thermometer in the onsite lab. Temperature discrepancies
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of up to 4 °C were observed between the field measurements made by the EPA
contractor and Rockwell personnel. Investigation revealed that there was no
laboratory record indicating that the field thermometer, used by Rockwell
personnel, had ever been calibrated. Accurate water temperature readings are
essential as they are used to calculate the temperature compensation of the
specific conductivity to 25 °C to meet the reporting requirements.
After sampling at each well, field personnel thoroughly cleaned (Alconox
and water) and rinsed (deionized water) the bailer and placed it in a plastic
garbage bag.
Field personnel maintained a log of sample collection and field measure-
ments (e.g., water levels, pH, conductivity, temperature and calibrations) in a
bound and numbered notebook.
Shipping and Chain-of-Custodv
All sample aliquots were placed in a cooler containing ice and reportedly
delivered to the Rockwell onsite laboratory within 3 hours after collection. EPA
field personnel initiated a sample chain-of-custody form and Rockwell person-
nel ensured proper transfer of the form and samples to laboratory staff.
According to Rockwell personnel, no chain-of-custody procedures were
followed before 1986, even though they were required by RCRA regulations
[265.92(a)(4)].
SAMPLE ANALYSIS AND DATA QUALITY ASSESSMENT
This section provides an evaluation of the quality and completeness of
ground-water monitoring data obtained by Rockwell for the Rocky Flats plant
from November 1981 to the end of April 1987. Most of the sampling and analy-
sis during this period was managed by Rockwell. At the time of the Task Force
inspection, the Rockwell general laboratory in building 881 was responsible for
performing most of the RCRA analyses listed in 265.92 and the 1986 Compli-
ance Agreement. Prior to 1986, the Health Safety and Environmental (HSE)
laboratory, located in building 123, was primarily responsible for analyzing
samples from the RCRA wells. Samples analyzed for pesticides and herbicides
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77
after 1983 and TOX analyzed in 1982 and 1983 were subcontracted. During
the last quarter of 1986, Roy F. Weston, Inc. (Weston), was contracted to collect
and analyze required ground-water samples. All 1987 work reviewed during
this evaluation was performed by the Rockwell general laboratory.
The Rockwell general laboratory was evaluated concurrently with the
onsite Task Force inspection of the facility. During the laboratory evaluation,
operating and analytical procedures, internal data reports, raw data and quality
control records were reviewed and analytical equipment was examined.
A review of ground-water monitoring data and procedures revealed
problems that have or could have affected data quality. Pre-1986 analytical
data for parameters other than pesticides, TOX, phenol (1984 and 1985) are
unreliable because of questionable sample preservation and holding
techniques. All specific conductance results could be biased low because they
were not corrected for the cell constant of the instrument. Also, most pre-1986
data represent concentrations of dissolved rather than total constituents and
may be biased low.
The analytical methods used for cadmium and chromium prior to 1986
would not ordinarily quantitate these metals at the maximum contaminant levels
(MCLs) specified for ground-water protection and are, therefore, inappropriate.
Levels of gross alpha radiation above the MCL of 15 pCi/L were reported for a
number of monitoring wells prior to 1986; however, confidence limits associated
with this data often exceed this level. Levels of selenium as high as 50 times
the MCL of 0.01 milligrams per liter (mg/L) have been reported.
The following is an evaluation of sample analyses and data quality
during the initial year of RCRA monitoring (1982) and three subsequent time
periods (1983 through 1985, 1986 and 1987). These periods reflect changes in
both analytical requirements and laboratories performing the analyses.
Analyses During Initial Year of Monitoring M982)
Under the sampling and analysis plan submitted to EPA in 1981, the
facility was to conduct the analyses specified in 265.92. Quarterly monitoring of
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all wells during the initial year is required to establish background values. The
initial year of monitoring was conducted in 1982. According to the 1981
sampling and analysis plan, quarterly monitoring during the initial year was to
include quadruplicate measurements of the four parameters specified in 265.92
as indicators of ground-water contamination, pH, total organic carbon (TOG),
TOX, and specific conductance on the upgradient well, 1-66. These analyses
were performed, but not in quadruplicate.
Analytical results for RCRA parameters reported during 1982, with few
exceptions, are unreliable because of sample handling and/or analytical
problems. Although total constituent analyses should have been performed,
most samples were filtered, and thus the reported results reflect dissolved
concentrations. The holding times recommended by EPA were frequently
exceeded, and EPA recommended preservation procedures were not followed.
Measurements of pH may contain systematic error due to excessive
holding times, filtration and storage at room temperature. The cited EPA
references in the 1981 sampling and analysis plan recommend a 6-hour
maximum holding time before analysis for pH. Site records indicate that
holding times were much longer than recommended. For example, wells 1-60,
2-60 and 4-60 were sampled on August 18 through August 20, 1982 and not
analyzed for pH until Octobers, 1982. All samples were filtered, which causes
degassing of the sample. This may change the carbonic acid equilibria, which
affects pH. Storage at room temperature for extended periods would allow
reaction of hydrogen ions with other constituents in solution, thus changing the
pH.
Other samples were held for undetermined lengths of time before
filtration occurred. This practice allows the various chemical species in the
sample to redistribute between the solid and liquid phases present prior to
filtration. Consequently, the quantities present at the time of analysis may be
different from those originally present. Once filtered, metals samples were not
preserved. This practice allows metals species to leave solution because of
various phenomena such as sorption and precipitation, thereby yielding results
that do not represent the initial concentrations in the sample and are probably
biased low.
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Sample preservation practices led to other potential problems. EPA
recommends refrigeration at 4 °C for all types of samples except those collected
for radiation and metal parameters. All samples, with the reported exception of
TOX, were unrefrigerated both before and after filtration. Biochemical and
chemical reactions may significantly transform the composition of samples at
higher ambient temperatures. TOC and the other organic parameters including
pesticides and herbicides are particularly vulnerable to sample degradation
under these conditions. Specific conductance is also unreliable for this reason.
TOC data, in some cases, contain large relative errors. TOC was
analyzed by subtracting inorganic carbon from total carbon. This approach is
not reliable for samples where inorganic carbon is substantially greater than the
organic carbon component of a sample. This difference and the resultant data
become statistically unreliable. As an example, on April 28, 1982 a sample
from well 3-66 was analyzed in duplicate. The first analysis measured total
carbon at 42.9 mg/L and inorganic carbon at 36.1 mg/L for a net difference of
6.8 mg/L (TOC). The second analysis measured total carbon at 46.1 mg/L and
inorganic at 36.1 mg/L resulting in a net difference of 10 mg/L. The difference
between 10 and 6.8 mg/L is 3.2 mg/L or 38 percent relative to their average, 8.2
mg/L.
A more reliable method for TOC is to separately determine purgeable
organic carbon (POC) and nonpurgeable organic carbon (NPOC), then add the
results. The long sample holding times at room temperature would have
allowed TOC samples to degrade. For example, TOC analysis on well sample
1-60 collected February 23, 1982 was performed May 28, 1982. The EPA
maximum recommended holding time for TOC was 24 hours in 1982 and is
currently 28 days under refrigerated and acidified conditions. These samples
were neither refrigerated nor acidified and the sample may be expected to
degrade more rapidly than if they had been preserved. In addition, samples
were filtered, therefore the results reported actually represent dissolved organic
carbon (DOC) rather than TOC.
Specific conductance measurements were not corrected for the cell
constant of the instrument. The results obtained may be biased slightly low
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because of this. This relative error is expected to be less than 10% of the
reported values.
Most of the metals samples were analyzed, after digestion, by atomic
absorption spectroscopy (AA) methods, which are accepted by EPA. Arsenic
and selenium concentrations were determined by furnace AA, without prior
digestion of the sample with hydrogen peroxide. This procedure may reduce
measurement sensitivity but probably not to an unacceptable degree. Lead and
silver were determined by Direct Current Emission Spectroscopy (DC E-Spec)
achieving acceptable sensitivity in the sample results. All other metals were
generally determined by flame AA. Flame AA methods do not normally achieve
the detection limits required to reliably monitor MCLs* for the elements cadmium
and chromium and are, therefore, inadequate.
The gross alpha and beta results are also unreliable at the MCLs
specified for ground-wa+er protection. Data such as a gross alpha of 22 +/-
(plus or minus) 60 pCi/L and a gross beta of 19 +/- 47 pCi/L were found in the
bench records for well 1-60 for a sample analyzed October 18, 1982. The
sample results for gross alpha and gross beta are calculated by subtracting a
background count rate from the sample count rate. If the counting times for the
sample and/or background are inadequate, negative sample values may result.
Such was the case for the second, third and fourth quarters of 1982, where
values of -9.9, -14.3 and -14.4 pCi/L, respectively, were reported for well 6-71.
The MCL for gross alpha is 15 pCi/L, thus, the method was unable to reliably
assess contaminants at this level. Gross alpha and beta results are further
qualified because samples were being filtered. Reported data therefore, at best
represents "dissolved" gross alpha and gross beta.
Some of the reported nitrate data for samples collected during the
second quarter may be unreliable. The second quarter result for well 17-74
was 64 mg/L while results from other quarterly sampling were 1.4 mg/L or less.
Corresponding conductivities do not show this variation, which suggests
analytical problems with this parameter.
Maximum contaminant levels as established under the Safe Drinking Water Act and
incorporated into Appendix III of Pan 265.
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Some of the 1982 chloride data appear to be discordant. For instance,
the third quarter result for well 2-60 was 80 mg/L, for the second quarter
371 mg/L, whereas, for the first and fourth quarters, 1,050 mg/L, and 1,050
mg/L, respectively, were reported. Reported concentrations of other anions and
cations, together with the conductivity values, did not indicate a possible
variation of this magnitude.
Except for some of the radionuclide measurements, no assessment of
recovery (spiked samples) and precision was routinely made in the remainder
of the analytical procedures, according to laboratory personnel. These
assessments are essential to validate the quality of reported data.
The 1981 sampling and analysis plan specified that the sample handling
and preservation procedures would be in accordance with sections 6.4 and 6.5
of EPA 530/611. The plan was not followed because those sections in the EPA
document specify refrigeration of some samples at 4 °C, onsite filtration for
dissolved constituents and parameter specific chemical preservation at the time
of sample collection. These procedures were either not performed or were not
performed in a timely manner. The sampling and analysis plan was also not
followed when certain analytical procedures were used. The plan states that
procedures in accordance with "Methods for Chemical Analysis of Water and
Wastes," (EPA-600/4-79-0202, dated March 1979) would be used to analyze
samples. The DC E-Spec method used by Rockwell for lead analysis is not
listed in this publication. Neither are the methods used for TOX, pesticides,
gross alpha, gross beta and radium.
Analyses During January 1983 Through December 1985
Most of the analytical data produced between January 1983 and
December 1985 are unreliable for the same reasons as the data for the initial
year of monitoring. The sample handling and preservation procedures used
during 1983 through 1985 were mostly the same as during 1982, as well as the
problems associated with them.
During this period the indicator parameters, TOC, TOX, pH and specific
conductance were again not analyzed in quadruplicate. TOX was not reported
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after 1983. Analytical results reported for this period represent dissolved
constituents with the possible exception of the TOC, phenols, purgeables,
pesticide, herbicides collected in 1984 and 1985 and TOX in 1983.
Consequently, most data are probably biased low.
Some of the analytical procedures changed, however. Records for at
least one set of lead data for samples collected in September 1983, show the
use of the furnace AA method, which is an acceptable procedure. Generally,
the use of the DC E-Spec method for lead was continued from 1982 through
1985. Samples collected during the period from 1983 through 1985 for fluoride,
chloride, nitrate and sulfate samples reportedly were analyzed by Ion
Chromatography (1C). 1C methods are not presented in the methods manual
referenced in the 1981 sampling and analysis plan ("Methods for Chemical
Analysis of Water and Wastes", EPA 600/4 79 020, March 1979). 1C should
not be used for fluoride analysis without confirmation with potentiometric or
colorimetric procedures. Rockwell laboratory staff raised concerns that because
of high nitrate in some of the samples, which may partially obscure the chloride
peak when 1C is used, that chloride results may not in all cases be accurate.
Sulfate data reported for samples collected in November 1983 and, possibly,
May 1984 appear to be biased low based upon cation/anion balance and
conductivity.
Before 1985, TOC analyses were reportedly performed on aliquots taken
from a composite sample held in a large plastic container. During 1985,
Rockwell began collecting TOC samples in separate containers. However, TOC
samples were reportedly not refrigerated or acid preserved until 1986. This
procedure would probably result in inaccurate data and is not in accordance
with the analytical references cited in the 1981 sampling and analysis plan. In
addition, TOC results from samples collected during 1983 to 1985 were still
being calculated by the difference method previously described.
Before the fourth quarter of 1984, phenol analyses were reportedly
performed on aliquots taken from a composite sample held in a large plastic
container. Composite samples were reportedly not refrigerated after collection,
which is essential for reliable results. Beginning with the fourth quarter of 1984,
phenol samples were collected in separate containers and acid preserved. The
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records do not indicate whether the phenol samples were taken in glass
containers, as specified in the procedures referenced in the 1981 sampling and
analysis plan.
Analyses Purina 1986
Weston sampled the RCRA wells and analyzed all but the radiation
parameters during the last quarter of 1986. The radiation parameters which
included gross alpha, gross beta, americium, plutonium, uranium and tritium
were analyzed by Accu-labs of Arvada, Colorado. Although the Weston
laboratories were not evaluated during the Task Force inspection, data
generated by the laboratory were reviewed.
The thallium determination may be subject to uncorrected spectral
interference. Selenium was reported in a number of wells at levels above the
MCLof 10u.g/L
Analyses Purina 1987
Rockwell resumed monitoring responsibilities in 1987. The sampling,
sample holding and sample analyses procedures used were much improved
over those used previously. Samples were both refrigerated and preserved in
accordance with EPA protocols. Reportedly, samples collected for dissolved
metals were filtered in the field; the other samples were not filtered.
At the time of the Task Force inspection, samples for the first quarter of
1987 had been collected and most analyses were either in progress or
completed. Of the elemental constituents, only mercury and potassium had
been analyzed. Other elemental constituents were to be analyzed by Atomic
Absorption Spectroscopy or Inductively Coupled Argon Plasma Optical
Emission Spectroscopy (ICP), by methods acceptable to EPA. Laboratory
personnel had apparently become aware of the limitations of flame AA for
cadmium and chromium, and more appropriate techniques were being
planned.
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The pH and specific conductance measurements were being performed
in the field, which eliminated the sample degradation problems for these two
parameters, as previously discussed. The procedure used, however, did not
adequately compensate for temperature. Although the field meter had a
temperature compensation dial, it was not adjusted for sample temperature.
Rather than adjusting the dial, Rockwell personnel attempted to alleviate the
need for temperature correction by maintaining calibration standards at a
temperature which would approximate sample temperatures. The procedure
used to do this was unreliable and could produce an error on the order of 0.1
pH unit which is significant when assessing ground-water contamination. The
pH meter is capable of achieving accuracies on the order of 0.01 pH units.
Specific conductance measurements were biased low because the field
meter was incorrectly calibrated. During the onsite Task Force inspection, the
values of the field standards used to set the field conductivity meter were found
to be 15 to 30 % below the true value. Sample measurements during this time
frame are expected to be biased low by about the same percentage.
Reported total dissolved solids (TDS) results may be biased high and
therefore unreliable. The oven used for TDS at the time of the inspection was
not at the correct temperature. The procedure specifies that samples are dried
at 180 degrees Celsius; at the time of inspection samples were being dried at
approximately 150 °C.
Anions were being analyzed by manual methods acceptable to the
Agency. Chloride was analyzed by the mercuric nitrate method; nitrate by the
brucine sulfate method and sulfate by the turbidimetric method. Assessment of
recovery through spiking of samples with known amounts of the respective
analytes is recommended as part of the quality control for these procedures. At
the time of inspection spiking was not being performed.
Cyanide, not required before 1987, was being analyzed potentiometri-
cally, using an Orion selective ion electrode following distillation. Sulfide is a
potential interferent which can eliminate any cyanide present through the
formation of thiocyanate. The presence of sulfide should be checked but was
not. The detection limit reported is not the true detection limit of the method
-------
85
which properly should be calculated statistically. Rather, the laboratory
personnel use the concentration value of the lowest standard which they feel
can be consistently reproduced.
Gross alpha, gross beta and radium results are unreliable at the MCLs
specified for ground-water protection. The reliability of the data is dependent
upon the sample aliquot size and the length of counting times for both the
sample and the background. Background counting times and sample counting
times were too short to provide the necessary reliability. Also, the confidence
limits reported with gross alpha and beta do not appear to account for counting
times, as they should. If this is true, the confidence limits reported represent the
data to be more precise than they actually are.
Gross alpha results for 1987, when compared to earlier results may be
slightly lower because of a change in the calibration standard used. Efficiency
corrections are dependent on the alpha emitting isotope used to calibrate the
measuring instrument. The alpha standard in use was changed from U238 to
Pu239 in 1987. The EPA method prescribes the use of Am241. Results based
on U238 (those prior to 1987) may be as much as twice those based on Am241
after correcting for counting efficiencies. Results based on Pu239 would be
somewhat lower than those based on U238, but still more than those based on
Am241. Results when compared to the specified MCLs should be viewed in this
light as the MCLs consider the EPA method.
Prior to 1986, plutonium, americium and uranium samples were filtered,
and not required. This was no longer the case in 1987.
The isolation procedures used for Pu, Am and U were changed from
electrodeposition to chemical separation. Analyses were, in contrast to those
prior to 1986, performed on total samples using a digestion. Except where
levels were unquantifiable, the actual levels of plutonium, americium and
uranium may be higher than what is reported. Data are uncorrected for the
percentage recovery of the analyte. Recoveries, reportedly, are 70 to 80%, 50
to 70% and 30 to 40%, respectively, for Pu, U and Am. Am243, U232 and Pu242
are used respectively in the Am, U and Pu procedures as internal standards to
determine percent recovery of the other isotopes.
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86
The quality of the volatile organic data for the first monitoring period of
1987 could not be assessed. EPA methods 601 and 602 were referenced as
the procedures used for volatile organic determinations. These methods
prescribe the use of spikes and control samples at a frequency of 10% of total
samples analyzed. These control measures were not performed on the 1987
first quarter samples. The EPA methods also specify that performance records
to document data quality are to be kept. The Rockwell performance records did
not include values obtained for standards and blanks analyzed concurrently
with the samples.
GROUND-WATER QUALITY ASSESSMENT PROGRAM OUTLINE
RCRA interim status regulations [265.93(a)] require a facility to prepare
an outline of a ground-water quality assessment program by November 19,
1981. CDH regulations (same as RCRA citation) also require preparation of an
outline. Both sets of regulations require that the outline describe a more
comprehensive program than the one for routine interim status monitoring and
be capable of determining:
Whether hazardous waste or hazardous constituents have entered
the ground water
The rate and extent of migration of hazardous waste or hazardous
constituents
The concentrations of hazardous waste or hazardous constituents
in the ground water
The "outline" on file at the facility was a section of the 1981 sampling and
analysis plan, previously discussed, which was titled "Groundwater Quality
Assessment Program. The section is, essentially, a recitation of the regulations;
it contains no program outline. Specifically, it does not address:
• Whether or how data triggering assessment would be evaluated to
confirm the apparent contamination
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87
How the apparent source would be determined
Whether or how additional hydrogeologic data would be collected
How the rate and extent of contaminant migration would be
determined
Which aquifer zones would be monitored
How a monitoring plan would be developed and what the
projected sampling frequency would be
Which analyses would be conducted on ground water, surface
water and soil samples to identify contaminants of concern
Analytical methods to be used on samples
How the data would be evaluated to determine if more work is
required or the facility could return to the indicator evaluation
program required by 265.92
Approximate schedules for sampling, analysis, data evaluation
and report preparation
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88
GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT
In November 1985, DOE submitted a RCRA Part B application to both
EPA and CDH, which had been delegated final authorization lor a RCRA
equivalent program in November 1984. As discussed in the introductory
section of this report, the State subsequently issued a Notice of Intent to deny
the permit. In July 1986, a Compliance Agreement (Agreement) between EPA,
CDH and DOE was completed and, as required by the Agreement, a revised
Part B was submitted to EPA and CDH in November 1986.
The point of compliance (POC) identified on Plate E-7 of the Part B is
about 5,400 feet from the solar evaporation ponds and more than 6,000 feet
from the landfill, which are the two closest regulated units. Rockwell personnel
stated that the POC was drawn so as to be downgradient from all solid waste
management units (SWMUs) rather than just the regulated units.
The POC designated in the Part B does not comply with the location
criteria specified in State regulations [264.95], which requires that it be adjacent
to regulated units. If the POC had been properly located (e.g., adjacent to the
solar evaporation pond), the hazardous constituents detected in ground water
would have triggered development of a compliance monitoring program
[100.41 (c)(7)].
The ground-water monitoring program proposed in the revised Part B
does not comply with State regulations [264.95 and 100.41 (c)(7)] because the
point of compliance is improperly located and a detection monitoring program
(264.98) is proposed rather than the required compliance monitoring (264.99)
or corrective action (264.100) program. Also, the rationale for the proposed
monitoring parameters is deficient and some improvements in sampling and
analysis procedures are needed.
The monitoring parameters proposed for the detection monitoring
program are to be based on site characterization work conducted pursuant to
the Agreement (Schedule 3, Task 3.1). Section E-5d of the Part B states that
initially, well samples will be analyzed for the parameters listed in Table 7.
After the first year of monitoring, samples are to be analyzed for the "...same
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89
Table 7
GROUND-WATER MONITORING
PARAMETERS
Indicators
Temperature
pH
Specific conductance
Total dissolved solids (TDS)
Metals
Hazardous substances list metals
Cesium
Molybdenum
Strontium
Anions
Bicarbonate
Carbonate
Chloride
Cyanide
Nitrate
Sulfate
Organics
Hazardous substances list volatiles
Hazardous substances list semivolatiles
Hazardous substances list pesticides/PCBs
Radionuclides
Gross alpha
Gross beta
Uranium 233, 234, 238
Americium 241
Plutonium 239
Tritium
Notes:
1. Temperature, pH and specific conductance
are measured in the field. All other parame-
ters are measured in the laboratory.
2. Samples from the first sampling event will be
analyzed for the complete hazardous sub-
stances list. Later samples will be analyzed
for only those hazardous substances list
compounds detected in the first sampling
period.
3. Analytical methods are presented in
Appendix E-13.
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90
parameters except that analyses will only be made for the hazardous
substances list metals, volatiles, semi-volatiles and pesticides/PCBs that were
detected...". This approach does not comply with State regulations
[100.42(c)(6)], because for a detection monitoring program, the parameters are
to be based on the waste composition, not that of the ground water.
The procedures described in Appendix E-13 of the Part B for sample
collection, preservation, shipment, analysis and chain-of-custody are generally
acceptable; however, some modifications and additional details are necessary.
For example, a footnote on Table 4-1 of Appendix E-13 indicates that all
samples with the exception of volatile organics are to be filtered. Filtering of
samples for organics is unacceptable because of the potential for organic
compounds to become bound to the filter and bias the analytical results. For
other parameters, a rationale for filtering needs to be provided along with
supporting data. Also, samples should be preserved immediately after
collection rather than within the 3 hours specified in the plan. The plan
specifies that sample aliquots for several parameters are preserved by base or
acid addition until a certain pH is achieved, but does not describe procedures
for verifying the pH of the preserved sample.
More details are needed for several sampling procedures included in the
plan. Specific procedures for operating a dedicated bladder pump, and pH and
conductivity meters are presented; however, the brand name and model
number of the equipment are not stated. Calibration procedures are described
for the conductivity meter using "standard solutions"; but, the solutions are not
described. The plan indicates that a photoionization detector will be used to
monitor a well head immediately after opening it, yet no actions are specified in
the event that high vapor concentrations are indicated. Finally, disposal of
purge water is not addressed. EPA guidance (RCRA Ground-Water Monitoring
Technical Enforcement Guidance Document - TEGD) recommends that purge
water be captured for proper disposal if it is found to be hazardous.
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91
EVALUATION OF MONITORING DATA FOR INDICATIONS
OF WASTE RELEASE
This section presents an analysis of Task Force and Rockwell data
regarding indications of waste releases to ground water from various waste
disposal areas.* These include the evaporation ponds, west spray field, 881
hillside, active landfill and the original landfill near the southwestern corner of
the production area at the Rocky Flats plant. Field and laboratory analytical
results from samples collected by Task Force personnel are presented in
Appendix C, together with the analytical methods.
Task Force and DOE/Rockwell data indicate releases of hazardous
constituents from the evaporation ponds and unspecified sources on the 881
hillside." The data are inconclusive regarding releases from the west spray
field and the two landfills. Two of the wells sampled (8-86 and 62-86) had
elevated pH levels that were inconsistent with other data and waste disposal
information. These levels may be artifacts from well construction. Details of
these findings are presented in the following.
EVAPORATION PONDS
As previously indicated, the evaporation ponds were used primarily for
treatment of aqueous wastes containing low-level radioactivity, high nitrates,
acids and aluminum hydroxide. Task Force personnel sampled one alluvial
well (30-86), four bedrock wells (14-86, 27-86, 32-86 and 34-86), and the wet
well for the ground water collection system for indications of waste release.
Selected Task Force data for these wells and an upgradient bedrock well (54-
86) are presented in Table 8.
Task Force data show that four hazardous constituents (carbon
tetrachloride, chloroform, trichloroethane and trichloroethene) were detected at
low concentrations in the wet well. Four hazardous constituents (carbon
Company data reviewed were presented in an "Annual Environmental Monitoring Report"
for the 1986 calendar year.
"Hazardous Constituents" are listed in 40 CFR Pan 261, Appendix VIII.
-------
Table 8
GROUND-WATER QUALITY NEAR THE SURFACE IMPOUNDMENTS
(Selected Parameters)
Well No./
Parameter*
pH (std. units)
Conductance (umho/cm)
TOX (ug/L)
POC (ug/L)
TOC (ug/L)
Carbon tetrachloride (ug/L)
Chloroform (ug/L
1 ,1 ,1 -Trichtoroethane (ug/L)
Trichloroethene (ug/L)
Octanoic acid (ug/L)
Nonanoic acid (ug/L)
Decanoic acid (ug/L)
Dodecanoic acid (ug/L)
Calcium*" (mg/L)
Magnesium*** (mg/L)
Potassium*** (mg/L)
Sodium*** (mg/L)
Chloride (mg/L)
Nitrate (mg/L)
Sulfate (mg/L)
Gross alpha (pCi/L)
Gross beta (pCi/L)
Gross radium (pCi/L)
Radium 228 (pCi/L)
Uranium 234 (pCi/L)
Uranium 235 (pCi/L)
Uranium 238 (pCi/L)
Tritium (pCi/L)
Background
Well
54-86
7.5
755
<5.
36
67,000
99.1
24.4
4.8
36.7
19
<0.3
50
7
8
<2
<2
1.2
0.3
1.5
<200
Wet Well
7.7
3,400
50
21
5,300
8
2E**
9
6
255
66.6
66.9
406
93
460
120
64
59
<2
<2
14.8
3.6
9.9
1,931
14-86
7.7
1,860
6.
44
2,000
133
39.6
6.9
255
94
<0.3
590
3
8
2
<2
0.8
<0.2
0.3
<200
27-86
7.9
1,420
62
10E
50E
10E
30E
48.9
16.1
6.9
236
160
<0.3
250
30-86
7.2
7,150
82
6,600
20E
1,470
333
71.6
1,360
260
2,100
300
155
172
15
9.5
21.4
1.1
13.5
8,811
32-86
8.0
960
<5.
4,300
20E
47.4
12.1
5.1
145
115
1
97
12
23
14
<2
1.1
0.2
0.8
~
34-86
7.2
2,200
<5.
19
3,400
268
83
8.5
259
52
<0.3
910
7
16
3
<2
0.8
<0.2
1.0
<200
Blanks inidcate no data.
E denotes estimated concentration
Dissolved metal concentration
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93
tetrachloride, chloroform, trichloroethene and dichloroethene) were previously
detected by Rockwell in well 22-86.
Task Force data also indicate elevated nitrate, potassium, TOX and
radionuclide concentrations in the wet well and alluvial well 30-86. Company
data for 1986 from wells near the evaporation ponds* [Figure 12] also indicate
elevated concentrations for these parameters [Appendix D], except for TOX for
which no data are presented." The highest nitrate concentration (9,640 mg/L)
was measured by Rockwell in well 30-86. Also, low levels of organics were
detected in Task Force samples from the wet well and bedrock well 27-86.
The background bedrock well (54-86) sample, collected by Task Force
personnel, had a very high TOC concentration (67,000 ng/L). A review of the
raw laboratory data indicates no calculation errors. The high TOC
concentration cannot be explained from available information.
Task Force and Company ground-water monitoring data together with
information on the types of waste discharged to the evaporation ponds strongly
suggest that waste constituents have been released to the underlying soil and
ground water. Past problems with the pond bottoms and related remedial
actions, discussed previously, further support the analytical evidence of
leakage.
WEST SPRAY FIELD
The west spray field was used for disposal of water from the evaporation
ponds. Samples from a bedrock well (48-86) and an alluvial well (49-86) in the
eastern end (downgradient side) of the west spray field were collected by Task
Force personnel. Selected Task Force and Company data for these wells,
alluvial wells 49-86, 50-86 and 51-86, and well 5-82, which is completed in both
the alluvium and bedrock, are presented in Table 9.
These wells include 2-60, 4-60 and 20-86 through 32-86.
Data were reviewed for wells 2-60, 4-60 and wells 20-86 through 32-86, which are near the
evaporation ponds.
-------
33-86
Scale in feet:
• I
0
Legend I
^B Wells completed in bedrock •
C J Wells completed in alluvium •
Wells completed in both bedrock and alluvium ^ ^m ^m ^m ^m ^ ^^
Buildings
Surface impoundments (solar ponds) (After Hydro-Search, November 1986)
Monitoring Wells in the Vicinity of the Surface Impoundments
Figure 12
250
500
-------
95
Table 9
GROUND-WATER QUALITY NEAR THE WEST SPRAY AREA
(Selected Parameters)
Well No./
Parameter
pH (std. units)
Conductance (nmho/cm)
POC (|ig/L)
TOC (ng/L)
Cyclohexanol (ng/L)
Potassium*" (mg/L)
Chloride (mg/L)
Nitrate (mg/L)
Sulfate (mg/L)
Gross alpha (pCi/L)
Gross beta (pCi/L)
Gross radium (pCi/L)
Task
48-86
11
350
1,300
6.3
11
<0.3
18
3
7
<2
Force
49-86
6.3
400
26
2,500
30E"
0.9
20
15
45
43
80
7
Data 1 986
5-82
15.5
55
32.4
77
2
3
49-86
ND
30
14.8
29
Rockwell
50-86
1.5
7.6
37.4
16
Data
51-86
1.1
7.3
18.4
31
Blank indicates no data.
E denotes estimated concentration
Dissolved concentrations are presented
The data suggest a nitrate enrichment of ground water; however, the data
are inconclusive. Well 5-82 appears to have slightly elevated concentrations of
potassium, chloride, nitrate and sulfate, none of which are listed hazardous
constituents. The gross alpha and beta are slightly elevated in well 49-86. The
pH of the sample from well 48-86 is inconsistent with samples collected
elsewhere from bedrock wells and may be a construction artifact.
881 HILLSIDE
Samples were collected by Task Force personnel from five wells
downgradient from the 881 hillside area. Three of the wells were completed in
both the bedrock and alluvium (2-71 and 9-74) and the other two were
completed in bedrock (59-86 and 62-86). Another alluvial well (43-86) near the
hillside and a former drum storage area was also sampled. Selected Task
Force and Company data for these wells are presented in Table 10.
-------
Table 10
GROUND-WATER QUALITY NEAR 881 HILLSIDE
(Selected Parameters)
Well No./
Parameter*
pH (std. units)
Conductance (umho/cm)
POX (ug/L)
TOX (ug/L)
POC (ug/L)
TOG (ug/L)
Tetrachloroethene(ug/L)
Chloroform (ug/L)
1 ,1 ,1-Trichloroethane(ug/L)
Trichloroethene (ug/L)
1 ,2 Dichloroethane (ug/L)
Cyclohexanol (ug/L)
Dodecanoic acid (ug/L)
1,1-Dichloroethene (ug/L)
Gross alpha (pCi/L)
Gross beta (pCi/L)
Gross radium (pCi/L)
Uranium 233, 234 (pCi/L)
Uranium 235 (pCi/L)
Uranium 238 (pCi/L)
Tritium (pCi/L)
2-71
8.0
1,200
8,720
3,400
210
14,000
8
9
5
1
<0.2
0.8
<200
9-74
7.4
1,925
2,000
11.000
9,400
3,500
3,500
7
7
3
8.4
0.7
6.6
<200
Task Fane Data
59-86
7.2
1,340
<5.
17
36
2,900
30E**
12
12
<2
11
0.6
8.5
264
62-86
11.1
460
<5.
9
28
2,200
10E
4
12
<2
3.6
<0.3
2.1
43-86
7.7
600
15
28
2.600
10E
7
16
9
<0.3
<0.3
<0.3
308
1986 Rockwell Data
2-71 9-74
15 4,800
79 5
14,000
4,500 11,000
38
7,200
350 28
1,000 28
30 11
33 8
-20 110
Blank indicates no data.
E denotes estimated concentration.
-------
97
Both Task Force and Company data indicate that organic hazardous
constituents are present in ground water, including several chlorinated ethanes
and ethenes. Ground-water contamination in this area had been previously
identified by DOE. The extent and source(s) of the contamination were being
investigated by Rockwell during the Task Force inspection.
A comparison of Task Force and Rockwell data for radionuclides in
samples from well 2-71 and 9-74 indicates substantial differences. Errors in
Rockwell data are suspected because of analytical problems described in the
section on Sample Analysis and Data Quality Evaluation.
ACTIVE LANDFILL
Samples were collected by the Task Force from one bedrock well (8-86)
downgradient from the active landfill. Selected Task Force and Company data
for this and two other wells adjacent to the active landfill are presented in
Table 11. Bedrock well 9-86 and alluvial well 10-86 are upgradient from the
landfill. The data indicate low-level contamination in the downgradient well
sample, collected by Task Force personnel, by several of the same organic
acids detected in bedrock well 27-86 near the evaporation ponds, including
octanoic, nonanoic, decanoic and dodecanoic acids. None of these
compounds are listed hazardous constituents. Company data for 1986 do not
include any results for these compounds and are not consistent with Task Force
data for other possible indicator compounds such as potassium and nitrate.
Consequently, the evidence for a release of hazardous constituents from the
active landfill is inconclusive.
The high pH of the Task Force sample from well 8-86 is inconsistent with
data from other alluvial wells and is not expected based on the wastes known to
be disposed of in the landfill. The elevated pH may be a well construction
artifact.
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98
Table 11
GROUND-WATER QUALITY NEAR THE ACTIVE LANDFILL
(Selected Parameters)
Task
Force 1986 Rockwell Data
Well No./ Data 8-86 9-86 10-86
Parameter 8-86
pH (std. units) 11
Conductance (nmho/cm) 710
POC (jig/L) 17
TOC (ng/L) 3,400
Diethylene glycol (ng/L) 10E"
Tetraethylene glycol (ng/L) 8E
Octanoic acid (n-g/L) 20 E
Nonanoic acid (|ig/L) 70E
Decanoic acid (|ig/L) 30E
Dodecanoic acid (|ig/L) 90E
Tetradecanoic acid (|ig/L) 20E
Potassium*" (mg/L) 10.8 41.1 3.6 12.9
Nitrate (mg/L) <0.3 41.0 <5.0 <5.0
Sulfate (mg/L) 190 15 17
Gross alpha (pCi/L) <2
Gross beta (pCi/L) 9
Gross radium (pCi/L) 2
* Blank indicates no data.
** E denotes estimated concentrations
*** Dissolved concentrations are presented
ORIGINAL LANDFILL
A sample was collected by Task Force personnel from one alluvial well
(57-86) downgradient from the original landfill. No previous samples had been
collected from the well because it had been dry. During Task Force sampling,
the well yield was very low and samples were only collected for organic,
general constituent and radionuclide analysis. Vapor readings (HNU meter)
from inside the top of the casing were 10 parts per million above background.
However, no organic compounds were identified in the sample. No results
-------
99
were reported for the general constituent sample. The radionuclide results
[Table 12] indicate low concentrations of these constituents.
Table 12
GROUND-WATER QUALITY NEAR
OLD LANDFILL
(Selected Parameters)
Well No./
Parameter 57-86
Gross alpha (pCi/L) 9
Gross beta (pCi/L) 15
Gross radium (pCi/L) 4
Uranium 234 (pCi/L) 6.7
Uranium 235 (pCi/L) 0.5
Uranium 238 (pCi/L) 5.1
The Task Force data are inconclusive regarding indications of releases
from the old landfill.
-------
APPENDICES
A MEMORANDUM OF UNDERSTANDING BETWEEN EPA AND
DOE FOR MANAGEMENT OF HAZARDOUS AND RADIOACTIVE
MIXED WASTES
B SUMMARY OF LEAF vs. MODEL DECISION
C ANALYTICAL TECHNIQUES AND RESULTS FOR TASK FORCE
SAMPLES
D DOE GROUND-WATER MONITORING DATA FOR 1986
-------
APPENDIX A
MEMORANDUM OF UNDERSTANDING BETWEEN EPA AND DOE FOR
MANAGEMENT OF HAZARDOUS AND RADIOACTIVE MIXED WASTES
-------
A-l
ENVIRONMENTAL PROTECTION \GENO DEPARTMENT OF ENERGY
MEMORANDUM OF UNDERST \NDING ON RESPONSIBILITIES FOR
HAZARDOUS \ND RADIOACTIVE MIXED \VASTE MANAGEMENT
(Signed February 22, 1984)
I. PI RPOSF.
\ Rftpiimihiiiitc*
This Memorandum ol I nderstanciing
' MOL ) delineates the jreas of responsi-
b'Htv ••! tne Department of Energy (DOE I
ard '.he Environmental Protection Agencv
(FP\i concerning ongoing hazardous
vv.iste and radioactive mixed waste man-
agement at facilities operated by DOE
iinoer 'ne authontv of the \tomie Energy
\u i \E\! ol" 1954. 42 L SC §201 I ei
M :J This MOL >ets forth procedures to
.-sure '.:MI hazardous waste and radioae-
••ve "nxed waste management are con-
ducted in a manner consistent wun ihe
iMiionai security responsibilities assigned
b\ existing law
B ( iiniptirub/c Pri>frtuu L\luhli\ht.'d
Tins VIOL establishes a hazardous
w.-sie \nd radioactive mixed waste man-
lucmcru program that is comparable to
i';e design and performance criteria, other
:e--!inic.'.i requirements, and recordkeepmg
.nu rerortina requirements ol the regula-
tions .ijupled bv i.P\ to implement the
Retirej Conscrvation ind Recovery \ct.
42 L i C jr>9()| ct ^i'c/ This MOL also
'ddrcs-es coordination with States and
i_i>mmunit\ relations concerning ha/ard-
ius '.v isie and radioactive mixed waste
m.'.nacenienl at \K\ facilities
II. \l THORITN.
\ Sa;/i(,'c'v ,;/n/ h.\Ci.liti\c Orders
Pie authority lor ha/.irdous waste and
'..ilio ^tr.e mixed «,isle management at
Mo'inc l:nerg> \ct lacililies dernes Irom
; \tomic Energy \ct of 1954. 42
L .-s C §:01 1 ft *cq ,
: Txecutive Order i E 0 ) 12088. Octo-
ber 13. 19'8.
.1 F. O I 2146. Jui\ IX. 19'9. and
4 E O I235f>. \prii 2. !9»2
B Rf%ulatian<;
The reaulatory standards for ha/ardous
waste and radioactive mixed waste man-
agement referred to in this MOL are set
lorlh in
1 40 CFR Parts 260 through 266. and
2~0.
2 DOL Order 54X0 2.
.' DOI- Order 5632 1.
4 DOE Order ^35 I. ana
5 DOE Order 5f50 2
III. DUFIMHONS.
\ Ha:tirili>us Uii*ie
Ha/ardous waste means a solid waste
that is determined to be hazardous under
41) CFR Part 26!
B Ha:arili>ti'i ll'iiMc Ltinirhance P'.an
Hazardous waste compliance plan
(IIV^CP) means a dotumeni issued b>
I P\ that prescribes specihc treatment.
storaec. and dispos.il practices for hazard-
ous waste and radioactive mixed waste
managed at an> At" \ faeinu
C Riiihinnlnc \li\cii Hjvfe'
Radioactive mixed waste means hazard-
ous waste containing source, special nucle-
ar, or byproduct materials
i\. s'ropt.
This MOL covers the generation, trans-
portation, treatment, storage, and disposal
of hazardous waste and radioactive mixed
waste at DOE facilities operated uncer the
AE \ This MOL does not address respon-
sibilities for implementing the Compre-
hensive Environmental Response. Com-
pensation and Liability Act iCERCL \)
\. CONFIDENTIAL INFORMATION
AND SECURITY.
A EPA Persc-'.nel
DOE asrees to provide security clear-
ances in accordance with DOE procedures
lor the personnel designated bv EP \ to
perform sue inspections and data analysis
under this MOL
B DOE Document*; and Ini^mtat'.on
1 DOE agrees to give EP \-dssignated
personnel with appropriate securi1.1. clear-
ances access to any information pertinent
to hazardous waste and radioactive mixed
waste manaaement that EP\ needs to
fulfill responsibilities under this MOL
Information includes Restricted Data. Na-
tional Security Information classified un-
der EO 1235o and its predecessors, and
Unclassified Controlled Nuclear
Information
2 EP \ agrees to handle and review
DOE information in accordance w.'.h the
\E\ and DOE Orders, the EP \ Docu-
ment Security Manual, and EO 12356
M. GENERATORS.
\ Standards
For ail generators of hazardous wistcs
or radioactive mixed wastes at \E.\ lacili-
ties, DOE agrees to comply with the re-
quirements ol 40 CFR Part 2h2. Stan-
3-16-8J
Published Sy THE BUREAU OF NATIONAL AFFAIRS INC, Washington. DC 20037
-------
41 2972
FEDERAL LA
Uards Vppi'L. '.'-,0 '.i ( ic:ier it-,^ nl
Hazardous W iste. inc.iuling rccordkcep-
ing and rep irtir _>
B \lniii!:cj;inn a/ StaiuUirds
EP\ and OCR tan iimdifv tncsc stan-
dards by '.greement A hen necessary to
ensure protection t'rom radiological haz-
ards to health and satetv AP.V rnndirica-
uon or standards must continue to provide
protection or human hej.th and the envi-
ronrnent equivalent to rhe level achieved
under 40 rfR P..n >2
\II. T; \YSPORTERS.
\ Stti-.daras
For ail DOE transporters of hazardous
wastes or radioactive waste mixtures gen-
erated a; \E \ facilities. DOE agrees to
compiv «>th the reauirements of 40 CFR
Part 263 Standards Applicable to Trans-
porters ot Hazardous Waste, inciudme
recordkecping. reporting, and cleaning up
transporter spills
B Modification of Standards
EPA and DOE can modify these stan-
dards by agreement when necessary to
ensure protection from radiological haz-
ards to health and safety \ny modifica-
tion of standards must continue to provide
protection of numan health and the envi-
ronment eaur.aient to the level achieved
under 40 CFR Part 263
\ III. TREATMENT. STOR \GE. AND
DISPOSAL F \CILITIESiTSDFsi.
A Standards
I. DOE agrees to reuuire \EA facilities
!,hat treat, store ?r dispose of hazardous
waste or radioacfve mixed waste on sue lo
compiv witn tne requirements of 4Q C£R
P^rt 265. Interim Sta,tu;.J>Unda«is
oVners- and Operators of . Hazardcjis
Waste JTSDFv_. umiL EPA issues an
HWCP to the facility.
_ DOE agrees to require AHA facilities
that treat, -.tore, or depose of hazardous
waste or radioactive waste mixtures on site
:o compi\ wun the requirements of an
HWCP issued b> EPA Anv H\VCP that
[P\ issues will conform to the require-
ments of 40 CFR Part 264, Standards lor
Owners and Operators of Hazardous
Waste TSDFv -nd Part 266 luntitled)
B Modulation ot Standard':
!n\ and DOE can modify the stan-
dards lor TSDFs by agreement when nec-
essar\ to ensure protection from radioioei-
cal hazards ;o health and safety \ny
modilication of standards must continue
10 provide proicxtii>n .>! human heaiih arm
tiic Lhv ,n,nnicnl euuiv aieril to rhe level
..c'neved under 40 C f-R Parts 2M 265
and 2Ar>
C Prix ednrc\ tor l^m/iy a l/ii;ardt,t<\
H',mt. ( ,,»ipiuince Plan (UUCP]
I Wnnin the time specified in a notice
from EPA. DOE agrees to submit a re-
quest for an HWCP that provides ail ,)l
the inlorniation descnoed in Subparts B
and C oi 4() CFR Part 270 The notice
will provide at least ISO davs fur DOE lo
submit the reuuest
2 EP\ agrees to provide to DOE a
drait HWCP that will be available for
review m accordance with Part X of this
MOL Belore any release of information
under P^rt X of ihis MOL. DOE aarees
to review the draft HWCP to ensure that
no classified information is improperly
disclosed
3 EP\ agrees to issue a tinal HW CP to
any \E\ facility that demonstrates that
the lacnuv is complying with the reuuire-
rnents of Part 264 or 266. or will compiv
with these requirements on a mutually
agreed on scnedule.
4 If the regulations that establish the
standards for HWCPs change. EPA will
review the HW'CPs for all AEA facilities
and issue any needed revisions. DOE
agrees to apply these revised standards in
accordance with the provisions of this
MOL
? If DOE program requirements
change. EP\ will review the HWCPs and.
after Consulting with DOE. issue any
needed revisions
IX. COMPLIANCE
\ Inspections
DOf- agrees to allow properly cleared
EP \-designated personnel to perform sue
inspections as provided by 40 CFR
§27030(1)
B Self Itispecnom
DO1 agrees to perform the inspections
required by 40 CFR Part 264. Standards
for Owners and Operators of Hazardous
Waste TSDFs. and submit any required
reports to the appropriate l-'P \ ollice
C K rntcn Compliance Demands
When EP\ determines that an \E \
laciiiu is not in compliance with any stan-
dard in Parts VI. VII. or V||| ot this
MOl . EP\ will issue to an appropriate
official at the \L \ facility a written com-
pliance demand that identities the nature
>i the violation \ written compliance ;lc
iM-d mav be based .-.n a site mspec'.nn
rer iris or an\ other .nfurmation
I) Response to Written Conip,:-n-,i <•
W nhin 30 davs after DOF rece:' •. - .
.vntten compliance demand. DOf '1:!
submit a response to EP\ that idenf»e
i Tne causes of the noncompli :nce T
f DOE believes that a faciiuv is in ,. ••,'.:• i-
ance. DOE's explanation of th.it DC""JI
2 The action 'hat DOE will ta*e ;>
bring the facility into compliance, and
3 The date by which DOE propos,;-, '.o
bring the laciiity into compliance
E Compliance Siheiiitli'^
i \fter consulting with DOE. F.P \ w i,|
develop a compliance schedule that
.dentilies
fi) What DOE must do to bnna *h*
lacihty into compliance, and
'in The time frame in which DOE nu-'
take action
2 DOE agrees to implement the compli-
ance schedule
F Technical Assistance
EP\ agrees lo provide technical advice
and assistance to DOE generators and
TSD facilities as required by E.O 12<>.-i
to help DOE comply with the hazardous
waste and radioactive mixed waste stan-
dards set forth in this .MOL
X. COORDINATION.
A State Relationships
I EPA will consult with affected States
li) Issuing HWCPs under Part Mil of
this MOL/
(11) Considering any proposed modifica-
tions to standards under Parts VI. Ml.
and VIII of this MOL
2 EPA will consult with alTected States
concerning violations of applicable stan-
dards, appropriate remedies, and compli-
ance schedules
B Comnninitv Relations
1 W'nh the assistance of EPV DOF.
will provide notice to any affected commu-
nilv of
(i) The availability of a draft HWCP
or
tn) \nv proposed modifications to stan-
dards under Parts VI. VII. or V [I I of tins
MOL
2 The notice will include
Environment Reporter
-------
EPA/DOE WASTE MANAGEMENT AGREEMENT
A-3.
41 2973
(i) The proposed treatment, storage.
and disposal prjctit.cs for ha/ardous waste
.:r.d r.ioioactive mixed waste management.
i ii i The scnedule for implementing the
practices, and
HID The places where copies of the
draft HVVCP may be reviewed
3 \fter issuing a notice. DOE will
provide
n) \t 'east 45 days for review of a draft
H\\CP or proposed modifications to stan-
dards, and
1111 -\n opportunity for a public meeting
in the atfected community on the dratt
H\\CP or proposed modifications to
standards
4 EP-\ and DOE agree to consider
information and comments received dur-
ing the review period in final decisions
concerning the HWCP or proposed modi-
fications to standards
XI. INCONSISTENT REQUIRE-
MENTS.
DOE agrees to modify any provisions in
DOE Order 54802 or other Orders that
eovern DOE's hazardous waste ana radio-
active mixed waste management that are
inconsistent with this MOL DOE agrees
to remove or modify any provisions in
these Orders for exemptions or waivers
from the standards of 40 CFR Parts 260
throueh 266. or 2^0
\lf. DL RATION AND MODIFICA-
TION OF MOL.
On signing by the Secretary. DOE. and
bv the Administrator, EP\. this MOL
will be in effect until termma'ec; bv mutu-
al written consent of EPA arc DOE EP \
and DOE can modify this MOL b> mutu-
al written consent
XIII. RESOLUTION OF DISAGREE-
MENTS.
DOE and EPA agree to use- the proce-
dures in EO 12088 and EO i:i4f> as
methods for resolving any disagreements
arising under this MOL
Donald Paul Hodel William Ruckeishaus
Secretary Administrator
D-partmentof Environmental
Energy Protection Agency
Date. 2/22/84
3-16-84
Published by THE BUREAU OF NATIONAL AFFAIRS INC . Washington, D C 20037
19
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APPENDIX B
SUMMARY OF LEAF vs. MODEL DECISION
-------
5-84
LITIGATION
P-l
14 ELR 20425
Legal Environmental Assistance Foundation,
Inc. v. Model
No 3-83-562 (E D Tenn Apr 13. 1984)
The court rules that the Department of Energy's (DOE's) Y-
12 nuclear weapons components plant is subject to the provisions
of the Resource Conservation and Recovery Act (RCRA) and that
DOE has violated the Federal Water Pollution Control Act
(FWPCA) by allowing unpermitted discharges of pollutants from
the plant. The court first holds that plaintiff environmental
groups have standing to bring the suit. The court then rules that
RCRA §1006(a), which excludes activities regulated by the
Atomic Energy Act (AEA) from RCRA coverage, does not ex-
clude activities at AEA federal facilities from RCRA if such regu-
lation is consistent with the AEA. AEA §161 does not vest DOE
with exclusive authority to regulate health and safety at facilities
like Y-12. Defendants have presented no evidence that enforcing
RCRA would cause disclosure of data protected under the AEA.
DOE may apply for presidential exemption from RCRA to pro-
tect national security interests under RCRA §6001; absent such an
application, the court should not weigh national security consid-
erations. Thus, the court holds that applying RCRA to Y-12 is
consistent with the AEA. The court also rules that DOE's dis-
charge of pollutants at locations other than those listed in its na-
tional pollutant discharge elimination system permit is in viola-
tion of the FWPCA. The court rejects DOE's argument that
plaintiffs' challenge could only have been brought within 90 days
of the issuance of the permit, ruling that plaintiffs have a cause of
action under FWPCA §505 ,to enforce permit conditions. The
court also rejects DOE's argument that the court should defer to
the Environmental Protection Agency's expertise in determining
whether the permit has been violated. However, the court declines
to enjoin the operation of Y-12 or assess civil penalties, but simply
orders DOE to comply with RCRA and the FWPCA.
Counsel for Plaintiffs
Garry A. Davis
602 S. Gay St., Knoxville TN 37902
(615)637-5172
Dean Hill Rivkin
6608 Crystal Lake Dr., Knoxville TN 37919
(615)974-2331
Counsel for Plaintiff-Intervenor
Frank J. Scanlon, Ass't Attorney General
450 James Robertson Pkwy., Nashville TN 37219
(615)741-1963
Counsel for Defendants
Dean K. Dunsmore
Land and Natural Resources Division
Department of Justice, Washington DC 20530
(202)633-2216
Jimmie Baxter, Ass't U.S. Attorney
P.O. Box 872, Knoxville TN 37901
(615)673-4561
Taylor, J.:
Memorandum
Plaintiffs allege that defendants are in violation of the Re-
source Conservation and Recovery Act [RCRA], 42 U.S.C.
§§6901-6987, and the Clean Water Act [CWA],' 33 U.S.C.
§§1251-1376. Plaintiffs seek declaratory and injunctive relief plus
the imposition of civil penalties. This case is now before the Court
on cross motions for summary judgment.
Defendants are the United States Department of Energy
[DOE] and the Secretary of DOE. Defendants operate the Y-12
Plant in Oak Ridge, Tennessee, pursuant to the Atomic Energy
Act [AEA].2 42 U.S.C. §§2011-2284. Plaintiffs, Legal Environ-
mental Assistance Foundation and Natural Resources Defense
Council, Inc., are non-profit corporations concerned with envi-
1. Also known as the Federal Water Pollution Control Act. See Gaba, Federal
Supervision of Stare Water Quality Standards Under the Clean Water Act, 36
VAND. L. REV 1167, 1168 n.3 (1983).
2. DOE is successor to many functions formerly vested with the Atomic Energy
Commission 42 U.S.C. §§5814, 7151.
ronmental protection. Several members of these organizations re-
side in the Oak Ridge, Tennessee, area and the organizations have
standing to bring this suit. The State of Tennessee intervened as
plaintiff to protect its interest in hazardous waste and water qual-
ity regulation.
The Y-12 Plant consists of approximately 260 buildings lo-
cated on 600 acres. Y-12 is primarily engaged in the fabrication
and assembly of nuclear weapons components. It is an essential
and unique facility in this country's system of nuclear defense. Y-
12 produces a large amount of hazardous wastes containing
chromium, mercury, PCBs, cadmium and other pollutants. Some
of these wastes are leaked or discharged into ground water and the
tributaries of the Clinch River.
The questions before the Court are: 1) Whether the Y-12
Plant is subject to the provisions of the RCRA, and 2) Whether
defendants have violated the CWA by allowing unpermitted dis-
charges of pollution at Y-12.
Resource Conservation and Recovery Act
One purpose of the RCRA is "to promote the protection of
health and the environment ... by ... regulating the treatment,
storage, transportation, and disposal of hazardous wastes which
have adverse effects on health and the environment." 42 U.S.C.
§6902. The RCRA and its accompanying regulations establish a
comprehensive program for the handling of hazardous wastes.
This comprehensive program is applicable to federal facilities. 42
U.S.C. §6961. Nothing in the RCRA, however, "shall be con-
strued to apply to (or to authorize any State, interstate, or local
authority to regulate) any activity or substance which is subject to
the ... Atomic Energy Act of 1954 except to the extent that such
application (or regulation) is not inconsistent with the require-
ments of such [Act]." 42 U.S.C. §6905(a).
Defendants oppose application of the RCRA to Y-12. They
argue that application of the RCRA to Y-12 is inconsistent with
the AEA for three reasons. First, the AEA precludes state regula-
tion of activities of DOE, 42 U.S.C. §2018, but the RCRA sub-
ject^] federal facilities to state regulation. 42 U.S.C. §6961. Sec-
ond, the RCRA gives the United States Environmental Protection
Agency [EPA], state and local authorities the authority to set
standards for waste disposal, 42 U.S.C. §6902, yet the AEA
places that authority with DOE. 42 U.S.C. §2201(i)(3). Third, the
AEA restricts dissemination of restricted data pertaining to
nuclear weapons and materials, 42 U.S.C. §§2014(y), 2274, 2277,
but the RCRA would subject this information to public dis-
closure. 42 U.S.C. §6927.
Section 271 of the AEA, 42 U.S.C. §2018, provides that:
Nothing in this chapter shall be construed to affect the
authority or regulations of any Federal, State, or local
agency with respect to the generation, sale, or transmission
of electric power produced through the use of nuclear facil-
ities licensed by the [Atomic Energy] Commission:
Provided, That this section shall not be deemed to confer
upon any Federal, State, or local agency any authority to
regulate, control, or restrict any activities of the Commis-
sion.
The parties are in disagreement as to whether this section pro-
hibits any state or local regulation of Y-12 or whether it merely
prohibits state and local regulations of electricity. In any event,
plaintiffs assert, and defendants do not deny, that Y-12 is
currently subject to federal, state and local regulations under
several other environmental statutes. See, e.g., National En-
vironmental Policy Act, 42 U.S.C. §§4321-4347; Safe Drinking
Water Act, 42 U.S.C. §§300f to 300J-10; Clean Air Act, 42 U.S.C.
§§7401-7642; Clean Water Act, 33 U.S.C. §§1251-1376; and
Toxic Substances Control Act, 15 U.S.C. §§2601-2629. Ad-
mittedly, none of these other environmental laws contain a
provision limiting its application to consistency with the AEA.
But see 33 U.S.C. §1371(a) (Clean Water Act does not limit in-
consistent regulations of other agencies). The fact that Y-12 is
subject to other state and local environmental regulations,
however, precludes the argument that state and local en-
vironmental regulation of Y-12 is inconsistent with the AEA.
"Federal installations are subject to state regulations only
when and to the extent that congressional authorization is clear
and unambiguous." Environmental Protection Agency v. Cat-
-------
B-2
14 ELR 20426
ENVIRONMENTAL LAW REPORTER
5-&4
iforma ex rel. State Water Resources Control [Board], 426 U.S.
200, 211 [6 ELR 20563] (1976). On the other hand, a court must
give full effect to a statute unless it is in "irreconcilable conflict"
with another statute. Radzanouver v. Touche Ross & Co., 426
U.S. 148, 155 (1976). "(W]hen two statutes are capable of co-exis-
tence, it is the duty of the courts ... to regard each as effective."
Id., quoting Morton v. Mancari, 417 U.S. 535, 551 (1974). The
R ,RA and the AEA are certainly not in irreconcilable conflict.
Congress must have intended that the RCRA be at least partially
applicable to facilities operated pursuant to the AEA. Otherwise
42 U.S.C. §6905(a) would have simply excluded application of the
RCRA to AEA federal facilities. Although defendants have taken
the position that Y-12 is totally excluded from RCRA regulations,
§6905(a) precludes RCRA application only to the extent it is in-
consistent with the AEA. Defendants' position would render
§6905(a) a nullity.
The RCRA provides a comprehensive program for the han-
dling of most hazardous wastes, but expressly excludes regulation
of nuclear wastes. 42 U.S.C. §6903(27). The AEA regulates
nuclear material, regardless of whether it is considered waste. 42
U.S.C. §2014(e), (z), (aa). The Court concludes that the most rea-
sonable reconciliation of the RCRA and the AEA is that AEA fa-
cilities are subject to the RCRA except as to those wastes which
are expressly regulated by the AEA: nuclear and radioactive mate-
rials. Although it could be said this interpretation renders
§6905(a) redundant with §6903(27), the Court believes that these
two sections support one another and firmly evince Congressional
intent as to the application of the RCRA.
Section 161 of the AEA, 42 U.S.C. §2201, provides that:
In the performance of its functions the [Atomic Energy]
Commission is authorized to—
(i) prescribe such regulations or orders as it may deem nec-
essary
(3) to govern any activity authorized pursuant to this chap-
ter, including standards and restrictions governing the
design, location, and operation of facilities used in the con-
duct of such activity, in order to protect health and to mini-
mize danger to life or property.
It does not appear that 42 U.S.C. §2201(i)(3) vests DOE with
exclusive authority to regulate health and safety standards in the
operation of Y-12. Accordingly, the RCRA is not inconsistent
with the AEA m this respect. Cf. Blaber v. United States, 212 F.
Supp. 95 (E.D.N.Y. 1962), aff'd., 332 F.2d 629 (2nd Cir. 1964)
(DOE's authority to prescribe health and safety regulations is
discretionary, not mandatory).
If application of the RCRA to Y-12 would require disclosure
of restricted nuclear material data protected by 42 U.S.C.
§§2014(y), 2274, 2277, this would be inconsistent with the AEA.
The burden is upon defendants, however, to show that such an in-
consistency would result. Nothing the Court says today should be
construed to require disclosure of restricted nuclear material data,
however, defendants have not shown that application of the
RCRA to Y-12 would result in such disclosures. Defendants' con-
elusory statement that such disclosures would be required is un-
supported. The Court can no more assume that the RCRA would
require defendants to disclose restricted nuclear material data
than it could assume that the RCRA would require private busi-
ness to disclose trade secrets. If security of nuclear material data
would conflict with the RCRA, defendants should apply for a
Presidential exemption from the RCRA for Y-12. 42 U.S.C.
§6961. Apparently, defendants have not sought a Presidential
exemption. Where DOE has not applied for a Presidential exemp-
tion, national security considerations should not be considered by
the Court. See United States v. Puerto Rico, 721 F.2d 832, 835 n.4
[14 ELR 20003] (1st Cir. 1983) (interpreting the Clean Water Act,
which has a similar Presidential exemption. 33 U.S.C. §1333(a)).
The Court concludes that application of the RCRA to Y-12
will not be inconsistent with the AEA. The restriction upon the
RCRA found in 42 U.S.C. §6961 merely clarifies the Congres-
sional intent to exclude nuclear wastes from coverage by the
RCRA. The AEA still provides exclusive regulation of nuclear
wastes. Defendants acknowledge that they have neither an EPA
permit, 42 U.S.C. §6925, nor a state permit, 42 U.S.C. §6926, for
the treatment, storage or disposal of hazardous waste. According-
ly, summary judgment for plaintiffs is appropriate for their claim
under the RCRA.
Clean Water Act
The goal of the CWA is to eliminate the discharge of pollu-
tants into navigable waters. 33 U.S.C. §1251. Except as permitted
under certain exceptions, "the discharge of any pollutant by any
person shall be unlawful." 33 U.S.C. §131 l(a). One exception is
granted for discharges allowed by a National Pollutant Discharge
Elimination System [NPDES] permit issued pursuant to 33
U.S.C. §1342. The "discharge of a pollutant" is defined as "any
addition of any pollutant to navigable waters from any point
source." 33 U.S.C. §1362(12). "The term 'point source' means
any discernible, confined and discrete conveyance, including but
not limited to any pipe, ditch, channel, tunnel, conduit, well, dis-
crete fissure, container, rolling stock, concentrated animal feed-
ing operation, or vessel or other floating craft, from which pollu-
tants are or may be discharged." 33 U.S.C. §1362(14). Every
identifiable point that emits pollution is a point source which must
be authorized by a NPDES permit. United Stales v. Eanh
Sciences, Inc., 599 F.2d 368 [9 ELR 20542] (10th Cir. 1979); 40
C.F.R. §122.1(b)(l).
The EPA issued a NPDES permit for Y-12 in 1974 which was
to expire on February 15, 1980. Since DOE made application for a
renewal of this permit more than 180 days before it was to expire,
the 1974 permit is still in effect. 40 C.F.R. §122.10(b)(2) (1979)
(recodified at 40 C.F.R. §122.21(d)(2) [sic] (1983)). This permit
authorizes discharges at four points: Kerr Hollow Quarry, Rogers
Quarry, New Hope Pond and Bear Creek. The parties acknowl-
edge that at one time it was EPA policy to designate the facility
boundary a's the point of discharge, but that this is no longer con-
sistent with the requirements of the CWA. Apparently the 1974
permit conforms with EPA's prior policy.
Plaintiffs claim that defendants are violating the CWA be-
cause they do not have a NPDES permit covering Y-12 discharges
at four other locations: the Oil Landfarm, the S-3 ponds, the
Burial Ground Oil Pond and over 200 discharge pipes into Upper
East Fork Poplar Creek. It seems clear to the Court, and defen-
dants have offered no evidence to the contrary, that these four lo-
cations are point sources that are discharging pollutants into navi-
gable waters. Since this lawsuit was filed, DOE has submitted
NPDES permit applications for many of these point sources.
DOE argues that becuase it has a NPDES permit for Y-12,
any discharge of pollution from Y-12 is not in violation of the
CWA. DOE says that judicial review of the permit may only be by
the appropriate Court of Appeals within ninety days after the per-
mit was issued. 33 U.S.C. §1369(b)(l). Plaintiffs, on the other
hand, claim that they are not challenging the issuance of the 1974
permit. They construe this case as a complaint against the unlaw-
ful discharge of pollutants without a permit, which may be chal-
lenged in a citizen's suit such as this. 33 U.S.C. §1365. The Court
is inclined to agree with plaintiff's characterization of this suit.
The 1974 permit does not purport to allow pollutant discharges at
the Oil Landfarm, S-3 ponds, Burial Ground Oil Pond or Upper
East Fork Poplar Creek. The permit allows pollutant discharges
only in accordance with the limitations and conditions of the per-
mit. Defendants have taken the position that a NPDES permit for
one point source of pollution, allows many other point sources of
pollution unless someone appeals the issuance of the permit. This
position is inconsistent with the remedial purpose of the CWA
and the requirement that any point source of pollutant discharge
be authorized by permit. 40 C.F.R. §122.1(b)(l).
Defendants argue in the alternative that, if the Court deter-
mines that Y-12's NPDES permit does not authorize other pollu-
tion discharges, this Court should defer to the primary jurisdic-
tion of the EPA and dismiss this action.
Primary jurisdiction is a common-law doctrine that en-
ables a court to determine the appropriate timing of its
own exercise of jurisdiction so that an agency sharing con-
current jurisdiction with the court over the subject matter
has time to make its own findings with respect to the claims
and disputes. United States v. Western Pacific R.R., 352
U.S. 59, 64, 77 S. Ct. 161, 165, 1 L. Ed. 2d 126 (1956). Its
-------
B-3
5-84
LITIGATION
14 ELR 20427
objective is to encourage "proper relationships between
courts and administrative agencies charged with particular
regulatory duties." Id. at 63, 77 S. Ct. at 164. Primary jur-
isdiction is appropriately invoked "when a claim is cog-
nizable in a court but adjudication of the claim" requires
the special competence of administrative bodies created by
Congress to regulate the subject matter. Hansen v. Norfolk
& Western Ry., 689 F.2d 707, 710 (7th Cir. 1982).
Illinois Hospital Association v. Illinois Department of Public
Aid, 576 F. Supp. 360 (N.D. 111. 1983). Whether several locations
at Y-12 are point sources for pollution is a question within the
competence of courts. See e.g., United States v. Earth Sciences,
Inc., 599 F.2d 368 [9 ELR 20542] (10th Cir. 1979). Accordingly,
deferral to the EPA would not be appropriate in this case.
Remedy
The Court concludes that defendants are in violation of the
RCRA and the CWA. At this time, however, the Court will im-
pose neither an injunction nor civil penalties upon defendants for
the following reasons:
1. The Y-12 Plant is a unique and essential element of this na-
tion's system of nuclear defense. See Weinberger v. Romero-Bar-
celo, 456 U.S. 305, 310 [12 ELR 20538] (1982).
2. Defendants have already taken and have agreed to take
steps that will reduce environmental harm caused by violations of
the RCRA and the CWA.
It is therefore ORDERED that plaintiffs' motion for sum-
mary judgment be and the same hereby is granted. It is further
ORDERED that defendants' motion for summary judgment be,
and the same hereby is, denied. It is further ORDERED that de-
fendants, with all deliberate speed, file for and seek a permit for
the treatment, storage and disposal of hazardous waste at Y-12.
42 U.S.C. §§6925, 6926. It is further ORDERED that defendants,
with all deliberate speed, file for and seek a NPDES permit for
any discharge of pollutants into Upper East Fork Poplar Creek,
and into Bear Creek from the Burial Ground Oil Pond, the Oil
Landfarm and the S-3 ponds. See Barcelo v. Brown, 478 F. Supp.
646, 798 (D.P.R. 1979), aff'd. sub nom, 456 U.S. 395.
Order
For the reasons stated in a memorandum opinion this day
passed to the Clerk for filing, it is ORDERED that plaintiffs' mo-
tion for summary judgment be, and the same hereby is,
GRANTED. It is further ORDERED that defendants' motion for
summary judgment be, and the same hereby is, DENIED. It is
further ORDERED that defendants, with all deliberate speed, file
for and seek a permit for the treatment, storage or disposal of
hazardous waste at Y-12 pursuant to 42 U.S.C. §6925 or 6926. It
is further ORDERED that defendants, with all deliberate speed,
file for and seek a NPDES permit for any discharge of pollutants
into Upper East Fork Poplar Creek, and into Bear Creek from the
Burial Ground Oil Pond, the Oil Landfarm and the S-3 ponds.
Kean v. Clark
Nos 82-5679.-5752 (3d Cir Mar 21,1984)
In light of the Supreme Court ruling in Secretary of the Inte-
rior v. California, 14 ELR 20129, the circuit court reverses and
remands the district court's ruling requiring consistency determi-
nations under the Coastal Zone Management Act for outer conti-
nental shelf oil and gas lease sales, 13 ELR 20618.
Counsel for Appellants (Cross-Appellees)
Irvin I. Kimmelman, Attorney General; John M. Van Dalen,
Deborah T. Poritz, James J. Ciancia
Richard J. Hughes Justice Complex, CN112, Trenton NJ
08625
(609) 984-6500
Counsel for Appellees (Cross-Appellants)
Nancy B. Firestone, Arthur E. Gowran, Peter R.
Steenland Jr.
Land and Natural Resources Division
Department of Justice, Washington DC 20530
(202)633-2757
Counsel for Amici Curiae
Sarah Chasis, David Keto, David Wirth
Natural Resources Defense Council, Inc.
122 E. 42d St., New York NY 10017
(212)949-0049
Norman C. Gorsuch, Attorney General; Lauri J. Adams
Pouch K, Capitol BIdg., Juneau AK99811
(907) 465-3600
E. Edward Bruce, David K. Flynn, Bobby R. Burchfield
Covington & Burling
P.O. Box 7566, Washington DC 20044
(202) 662-6000
Percuriam (before Gibbons, Garth, and Sloviter, JJ.):
This appeal and cross-appeal raised two issues with regard to
the Coastal Zone Management Act ("CZMA"), 16 U.S.C.
§§1451-1464 (1980). The Secretary of the Interior questioned
whether outer continental shelf oil and gas leasing directly affects
an adjacent state's coastal zone within the meaning of section
307(c)(l)' of the CZMA. The district court ruled against the Secre-
tary of the Interior and held that the lease sale in question did
directly affect New Jersey's coastal zone, thereby triggering the
CZMA's consistency requirements.
The State of New Jersey challenged whether the CZMA, as-
suming it applies to a lease sale, protects the coastal zone of a di-
rectly affected state from economic or social impacts inconsistent
with the state's approved coastal management program. Contrary
to New Jersey's position, the district court ruled that the CZMA
only protects against inconsistent physical impacts to the coastal
zone, and not against inconsistent socio-economic impacts. Prior
to disposition on the merits, all parties agreed that we should
withhold disposition until after the Supreme Court decided Cali-
fornia v. Watt, 683 F.2d 1253 [12 ELR 21084] (9th Cir. 1982),
cert, granted, 51 USLW 3818 (1983), which presented the precise
issue raised by the Secretary of the Interior in the instant appeal.
On January 11, 1984, the Supreme Court decided Clark v.
California, Nos. 82-1326, 82-1327, 82-1511 [14 ELR 20129], and
held, in accordance with the position taken by the Secretary of the
Interior, that the Department of the Interior's sale of oil and gas
leases on the outer continental shelf off the coast of California
was not an activity "directly affecting" the coastal zone under
section 307(c)(l) of the CZMA. Thereafter, counsel in the instant
matter, in response to this court's instruction, filed supplemental
memoranda commenting on the application of the Supreme Court
decision to the issues in Kean v. Clark.
As a result of the responses to the court's inquiry and the con-
sistent position taken by all counsel which the court hereby ap-
proves, we will reverse that part of the district court's judgment
which the Secretary of the Interior challenged by cross-appeal,
(No. 82-5752) and remand to the district court with instructions to
dismiss as moot that aspect of the judgment appealed by the State
of New Jersey (No. 82-5679).
Conant v. United States
No. 83-3325 (11th Cir Feb 27,1984)
The court rules that a claim for damages caused by an alleg-
edly wrongfully issued Army Corps of Engineers dredge and fill
cease and desist order must meet the requirements of the Federal
Tort Claims Act (FTCA), but that a claim for equitable relief may
lie under the Administrative Procedure Act (APA). The court
holds that the district court lacked evidence to support its ruling
that appellant's damage claim was untimely under the FTCA. Fur-
ther, it holds that injunctive relief from Corps' action under §404
of the Federal Water Pollution Control Act is not barred by sov-
ereign immunity, since the APA waives that immunity.
Counsel for Appellant (Pro Se)
Marcus Conant
P.O. Box 30, Gainesville FL 32602
(904)372-4813
1. "Each Federal agency conducting or supporting activities directly affecting
the coastal zone shall conduct or support those activities in a manner which is, to
the maximum extent practicable, consistent with approved state management
programs." 16U.S.C. §1456(c)(l).
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B-4
14 ELR 20428
ENVIRONMENTAL LAW REPORTER
5-84
Counsel for Appellee
Kenneth Sukhia, Ass't U.S. Attorney
110 E. Park Ave., Rm. 100, Tallahassee FL 32301
(904)224-3186
Per curiam (before Hill, Johnson, and Henderson, JJ.):
This lawsuit stems from a June 1981 cease and desist order
issued by the United States Army Corps of Engineers prohibiting
further discharges by Marcus Conant of dredge or fill materials in
the water of the United States at or near the Santa Fe River in Ala-
chua County, Florida. Upon receipt of the cease and desist order,
Conant filed a claim with the Army Corps of Engineers seeking
$300,000 in damages resulting from the issuance of the order.
Notice of final denial of his administrative claim was dated July
13, 1982. The basis for the denial according to the July 13, 1982,
letter was that the claim was "not payable because the applicable
statute (28 U.S.C. 2680(a)) excludes liability for inspection and
enforcement of the Clean Water Act." On January 19, 1983,
Conant filed in the United States District Court for the Northern
District of Florida his pro se complaint seeking monetary dam-
ages and injunctive relief. His complaint alleges that the United
States District Court had jurisdiction over the case pursuant to 28
U.S.C.A. §1331 and that the Corps of Engineers had misapplied
the Clean Water Act of 1977 by issuing the cease and desist order.
He requests that the district court award him $300,000 in com-
pensatory damages, plus an amount in punitive damages to be
determined by the court. He further asked the district court to nul-
lify the cease and desist order and enjoin the Corps from taking
additional action against him. The government moved to dismiss
his complaint on the ground that the court lacked subject matter
jurisdiction in that Conant's claim was barred under 28 U.S.C.A.
§2401 because he did not commence his action within six months
of the date on which the notice of final denial of his administra-
tive claim was mailed.
Finding that Conant had failed to bring his suit within the
six-month period required by Section 2401, the district court dis-
missed his monetary damage claim for lack of jurisdiction. The
district court in a separate order determined that Conant's claim
for injunctive relief was barred by the doctrine of sovereign im-
munity. Accordingly, the court dismissed his entire action with
prejudice.
According to 28 U.S.C.A. §2401, a tort claim against the
United States shall be forever barred unless the action is com-
menced "within six months after the date of mailing, by certified
or registered mail, of notice of final denial of the claim by the
agency to which it was presented." See Carr v. Veterans Adminis-
tration, 522 F.2d 1355, 1357 (5th Cir. 1975).' This court cannot
set aside the district court's finding as to the mailing date of the
final notice unless that finding is clearly erroneous. FED. R. Civ.
P. 52(a). In determining that Conant had failed to file his action
timely, the district court found that the Corps' final notice was
mailed to him on July 13, 1982, and that he filed his claim on
January 19, 1983, more than six months later. The record does
reflect that the letter of the Corps is dated July 13, 1982; however,
there is nothing in the record showing that it was mailed on that
date. Consequently, in the absence of any evidence establishing
the mailing date of the final notice, the district court erred in find-
ing that Conant failed to file his claim for monetary damages
within the six-month period required by Section 2401. This part of
Conant's claim will be remanded to the district court for the pur-
pose of allowing the parties to present evidence as to the "date of
mailing" of the July 13, 1982, letter of the Corps of Engineers.
In considering the disposition by the district court of Con-
ant's claim for injunctive relief against the Corps of Engineers
pursuant to 28 U.S.C.A. §1331, we start with the premise that a
suit for injunctive relief against a federal agency is barred by sov-
ereign immunity unless specifically and explicitly waived. See Lar-
son v. Domestic & Foreign Commerce Corporation, 337 U.S. 682,
686-90 (1949); Petterway v. Veterans Administration Hospital,
495 F.2d 1223, 1225 (5th Cir. 1974). Although Conant character-
izes his claim as one under Section 1331, that section cannot be
construed as a waiver of sovereign immunity. Beale v. Blount, 461
1. The Eleventh Circuit has adopted the case law of the former Fifth Circuit
handed down as of September 30, 1981, which is binding unless and until over-
ruled or modified by this Court en bane. See Bonner v. City of Pnchard, 661
F.2dl206, 1209(llthCir. 1981 Henbane).
F.2d 1133, 1138 (5th Cir. 1972). However, this does not end the
matter since 5 U.S.C.A. §702 provides that a party suffering a
legal wrong or adversely affected or aggrieved because of agency
action is entitled to judicial review of that action and the party's
claim shall not be dismissed on the ground that it is against the
United States. It is clear, therefore, that Section 702 "waives sov-
ereign immunity for actions against federal government agencies,
seeking nonmonetary relief, if the agency conduct is otherwise
subject to judicial review." Sheehan v. Army & Air Force Ex-
change Service, 619 F.2d 1132, 1139 (5th Cir. 1980), rev'd on
other grounds, 456 U.S. 728 (1982).
Title 33 U.S.C.A. §1311 prohibits the discharge of fill mate-
rial into navigable waters unless authorized by 33 U.S.C.A.
§1344. Under Section 1344 the Secretary of the Army is autho-
rized to issue permits for the discharge of fill material into navi-
gable waters. Conant alleges in his complaint, however, that he
was not required to obtain a permit because normal fish farming
on a scale where the fish farming facilities produce less than a
100,000 harvest weight pounds per year are exempted from the
statutory provisions and therefore, since his operation was not
that large, the Corps of Engineers improperly issued him a cease
and desist order. There is no question but that the United States
Army Corps of Engineers is an "agency" within the meaning of
the Administrative Procedure Act, Jaffee v. United States, 592
F.2d 712, 719 (3rd Cir.), cert, denied, 441 U.S. 961 (1979). There-
fore, construing Conant's allegations liberally, which we must
under Haines v. Kerner, 404 U.S. 519 (1972), it is clear that he
states a claim that he suffered a legal wrong because of the Corps
of Engineers' action. Consequently, the district court erred in dis-
missing his claim for injunctive relief as barred by sovereign
immunity.
For the foregoing reasons, the judgments entered in this case
by the district court are REVERSED and the case is REMANDED
for further proceedings.
Massachusetts v. Pace
No 83-3883-G(D. Mass Mar 22,1984)
The Commonwealth of Massachusetts signs a consent agree-
ment to recover over $1.9 million expended for cleanup of the Sil-
resim Chemical Corp. site in Lowell. In the agreement, 231 corpo-
rations agree to pay sums ranging from $16.41 to $287,190.31 in
return for release from civil liability for cleanup of the site. The
agreement also attempts to protect the defendants from suits for
contribution from non-settling joint tortfeasors, and allows de-
fendants credit for sums paid to third parties in independent suits
to recover cleanup costs. The parties do not acknowledge liability
for disposal of materials at the site. An appendix listing settling
parties and amounts is available from ELR (II pp. $2.00, ELR
Order No. C-1321a).
In a separate but identical agreement, the state settles with
four additional corporate defendants. (Full text available from
ELR, 9pp. SI. 75, ELR Order No. C-l321b).
In a similar agreement, the state settles with the Departments
of the Navy and Air Force. The agreement expressly preserves the
rights of recovery of the United States. (Full text available from
ELR, 7pp. $1.50, ELR Order No. C-1321c).
Counsel for Plaintiff
Lee P. Breckenridge, Ass't Attorney General
Environmental Protection Division
One Ashburton PI., Boston MA 02108
(617)727-2265
Counsel for Defendants
John R. Cromer
Hammond, Cromer & Jackson
431 E. Hanna Ave., Indianapolis IN 46227
(317)786-0487
James I. Wyer, General Counsel
American Cyanimide Co., Wayne NJ 07470
(201)831-2000
Edward Arthur Schwartz, General Counsel
Digital Equipment Corp., 111 Powdermill Rd., Maynard
MA 01754
(617)493-5500
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APPENDIX C
ANALYTICAL TECHNIQUES AND RESULTS FOR TASK FORCE SAMPLES
-------
CDM Federal Programs Corporation
C-l
September 2, 1987
Hans Waetjen
Project Officer
U.S. Environmental Protection Agency
401 M Street, Room 2834
Washington, D.C. 20460
PROJECT: EPA CONTRACT NO.: 68-01-7331
DOCUMENT NO.: T014-ROO-EP-BAFX-1
SUBJECT: Final Memorandums for Work Assignment 14
Document Nos. T014-ROO-FR-AXBB-4
TO14-ROO-FR-AYGR-2
Dear Mr. Waetjen:
Please find enclosed the Final Memorandums entitled, "Evaluation of Quality
Control Attendant to the Analysis of Samples from the Rocky Flats Arsenal,
Colorado Facility" and "Evaluation of Quality Control Attendant to the
Analysis of Samples from the Mineral Research, Inc., North Carolina
Facility" as partial fulfillment of the reporting requirements for this
work assignment.
If you have any comments regarding this submittal, please contact Ken
Partymiller of PRC Environmental Management, Inc. at (713) 292-7568 by
September 15, 1987.
Sincerely,
CDM Federal Programs Corporation
Harry P. Butler
Deputy Program Manager
TEM:mhf
Enclosure
cc: Richard Steimle, EPA Primary Contact, HW Ground-Water Task Force, HQ
Paul Friedman, EPA HQ
Ann Whitney, CDM Federal Programs Corporation (letter only)
Bruce Bakaysa (letter only)
Daniel Chow, PRC Environmental Management, Inc., Project Manager
(letter only)
Ken Partymiller, PRC Environmental Management, Inc., Houston
TAH6-67
13135 Lee Jackson Memorial Highway, Suite 200 Fairfax, VA 22033 703968-0900
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C-2
FINAL MEMORANDUM
EVALUATION OF QUALITY CONTROL ATTENDANT
TO THE ANALYSIS OF SAMPLES FROM
THE ROCKY FLATS ARSENAL,
COLORADO FACILITY
Prepared for
U.S. ENVIRCNMENTAL PROTECTION AGENCY
Office of Waste Programs Enforcement
Washington, D.C. 20460
Work Assignment No.
EPA Region
Facility I.D. No.
Contract No.
CDM Federal Programs
Corporation Document No.
Prepared By
Work Assignment Project tlanager
Telephone Number
Primary Contact
Telephone Number
Date Prepared
TAH6-67
14
Headquarters
C07890010526
68-01-7331
T014-ROO-FR-AXBB-4
PRC Environmental
Management, Inc.
Daniel Chow
(312) 856-8700
Rich Steimle
(202) 382-7912
September 2, 1987
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C-3
MEMORANDUM
DATE: August 4, 1987
SUBJECT: Evaluation of Quality Control Attendant to the Analysis of Samples
from the Rocky Flats Arsenal, Colorado. Facility
FROM: Ken Partymiiler, Chemist
PRC Environmental Management, Inc.
TO: HWGWTF: Richard Steimle, HWGWTF*
Paul H. Friedman, Chemist*
Gareth Pearson (EPA 8231)*
Steve Sisk, NEIC
Steve Mangion, Region-I
This memo summarizes the evaluation of the quality control data generated by
the Hazardous Waste Ground-Water Task Force (HWGWTF) contract analytical
laboratories (1). This evaluation and subsequent conclusions pertain to the data
from the Rocky Flats Arsenal, Colorado sampling effort by the Hazardous Waste
Ground-Water Task Force.
The objective of this evaluation is to give users of the analytical data a more
precise understanding of the limitations of the data as well as their appropriate use.
A second objective is to identify weaknesses in the data generation process for
correction. This correction may act on future analyses at this or other sites.
The evaluation was carried out on information provided in the accompanying
quality control reports (2-4) which contain raw data, statistically transformed data,
and graphically transformed data.
The evaluation process consisted of three steps. Step one consisted of
generation of a package which presented the results of quality control procedures,
including the generation of data quality indicators, synopses of statistical indicators,
and the results of technical qualifier inspections. A report on the results of the
performance evaluation standards analyzed by the laboratory was also generated.
Step two was an independent examination of the quality control package and the
performance evaluation sample results by members of the Data Evaluation
Committee. This was followed by a meeting (teleconference) of the Data Evaluation
Committee to discuss the foregoing data and data presentations. These discussions
were to come to a consensus, if possible, concerning the appropriate use of the data
within the context of the HWGWTF objectives. The discussions were also to detect
and discuss specific or general inadequacies of the data and to determine if these
are correctable or inherent in the analytical process.
Preface
The data user should review the pertinent materials contained in the
accompanying reports (2-4). Questions generated in the interpretation of these
data relative to sampling and analysis should be referred to Rich Stcimlc of the
Hazardous Waste Ground-Water Task Force.
HWGWTF Data Evaluation Committee Member
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C-4
I. Site Overview
NTo background information concerning the Rocky Flats facility was made
available to the HWGWTF Data Evaluation Committee teleconference.
Twenty-three field samples were collected at this facility. The samples
included two field blanks (MQA754 and 790), two equipment blanks (MQA753 and
761), a trip blank (MQA763), and a set of triplicate samples (MQA760, 830, and 831)
as well as 15 other field samples. All samples were designated as low concentration
ground-water samples. All samples were analyzed for all HWGWTF Phase 3 analytes
with several exceptions. Samples MQA765 and 793 were not analyzed for pesticides
or herbicides and no samples were analyzed for dioxins and dibenzofurans.
II. Evaluation of Quality Control Data and Analytical Data
1.0 Metals
1.1 Metals OC Evaluation
Total metal spike recoveries were calculated for twenty-four metals spiked into
two samples (MQA755 and 791). Twenty-one total metal average spike recoveries
from these samples were within the data quality objectives (DQOs) for this Program.
The total aluminum, iron, and selenium average spike recoveries were outside the
DQO with values of 149, 140, and 338 percent, respectively. Seven individual total
metal spike recoveries were also outside DQO. This information is listed in Tables
3-la and 3-2a of Reference 2 as well as in the following Sections.
Twenty-four dissolved metals were also spiked into two samples (MQA755 and
791). Twenty-two of the twenty-four dissolved metal average spike recoveries were
within the data quality objectives (DQOs) for this Program. Dissolved chromium and
thallium average spike recoveries were outside DQO with values of 132 and 18
percent. Eight individual dissolved metal spike recoveries from these samples were
also outside DQO. This information is listed in Tables 3-lb and 3-2b of Reference
2 as well as in the following Sections.
The calculable average relative percent differences (RPDs) for all metallic
analytes, with the exception of total chromium, were within Program DQOs. RPDs
were not calculated for about two-thirds of the metal analytes because the
concentrations of many of the metals in the field samples used for the RPD
determination were less than the CRDL and thus were not required, or in some
cases, not possible to be calculated.
Required metal analyte analyses were performed on all samples submitted to
the laboratory.
No sample contamination involving the metallic analytes was reported in the
laboratory blanks. Sampling blank contamination was reported and will be discussed
in the following Sections.
1.2 Furnace Vfctals
The quality control results for the graphite furnace metals (antimony, arsenic,
cadmium, lead, selenium, and thallium) were generally acceptable.
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C-5
The total lead and selenium matrix spike recoveries for spiked sample MQA755
were outside DQO with values of 26 and 675 percent, respectively. The dissolved
cadmium and thallium matrix spike recoveries for spiked sample MQA755 were also
outside DQO with values of 128 and 36 percent, respectively. The total antimony,
lead, and selenium matrix spike recoveries for spiked sample MQA791 were outside
DQO with values of 66, 127, and 0 (no recovery) percent, respectively. The
dissolved selenium and thallium matrix spike recoveries for spiked sample MQA791
were also outside DQO with values of 72 and 0 percent, respectively. All total
antimony and the dissolved cadmium and selenium results should be considered semi-
quantitative. All total selenium and dissolved thallium results should not be used.
All total lead results greater than 6 ug/L qualitative (samples MQA755, 757, 758.
792, 793, and 829) should be considered qualitative and all other total lead results
should not be used.
The correlation coefficient for the. method of standard addition (MSA)
determination of dissolved selenium in sample MQA755D (duplicate sample) was below
DQO. This was considered to have no impact on data usability as the value was
very close to the DQO and the value for sample MQA755 was acceptable and above
DQO.
MSA analyses should have been performed on total antimony in laboratory
control standard =*1. This was considered to have no impact on data usability as no
total antimony was detected in any field samples.
The precision for the duplicate injections of total antimony in spiked sample
MQA791 was above DQO. This was considered to have no impact on data usability.
Several continuing calibration verifications (CCVsj for total and dissolved
thallium were above DQO. The affected samples were rerun but the CCV was not
reanalyzed prior to resuming sample analysis. Total thallium results for samples
MQA755, 756, 758, 759, and 790 and dissolved thallium results for samples MQA754,
761, 762, 764, 792, and 863 were affected and should be considered semi-quantitative
unless further qualified for other reasons.
The dissolved selenium result for sample MQA755 was 49 ug/L while the total
selenium result for the same sample was reported as less than 4 ug/L. Due to this
poor agreement, both of these results should not be used.
All total arsenic and cadmium and dissolved antimony, arsenic, and lead results
should be considered quantitative. Total thallium results should be considered
quantitative with exceptions listed below. All total antimony and dissolved cadmium
results and dissolved selenium results with an exception should be considered semi-
quantitative. Also, total thallium results for samples MQA755, 756, 758, 759, and
790 should also be considered semi-quantitative. Total lead results for samples
MQA755, 757, 758, 792, 793, and 829 should be considered qualitative. All total
selenium and dissolved thallium results, total lead results with exceptions, and the
dissolved selenium result for sample MQA755 should not be used. The usability of
all graphite furnace analytes is summarized in Section 4.0 and 4.1 at the end of this
Report.
1-3 ICP Merals
The matrix spike recoveries for total aluminum and iron and dissolved calcium,
chromium, magnesium, and sodium in sample MQA791 were outside DQO with
recoveries of 191, 160, 72, 166, 74, and 57 percent, respectively. As a rule, the
trend of high spike recoveries indicate a high bias in the data and low recoveries
-------
C-6
indicate a low bias. Chromium results were not affected. Dissolved calcium,
magnesium, and sodium results should be considered semi-quantitative. Total
aluminum and iron results should be considered semi-quantitative with exceptions.
Total aluminum and iron results less than the CRDL should be considered
quantitative and the total aluminum result for sample MQA830 should not be used.
The low level (twice CRDL) linear range checks for all total beryllium,
chromium, cobalt, copper, nickel, vanadium, and zinc results and most'of the results
for dissolved beryllium, chromium, cobalt, copper, manganese, nickel, silver, tin,
vanadium, and zinc exhibited low recoveries. See Section B7 of Reference 3 for a
detailed listing of analysis dates, samples affected, and biases. The low level linear
range check is an analysis of a solution with elemental concentrations near the
detection limit. The range check analysis shows the accuracy which can be
expected by the method for results near the detection limits. The accuracy
reported for these metals at these concentrations is not unexpected.
Total and dissolved zinc contamination were reported in field blank MQA754,
both at concentrations of 26 ug/L. Dissolved zinc contamination was reported in
equipment blank MQA753 and in field blank MQA790 at concentrations of 42 and 28
ug/L. The zinc CRDL is 20 ug/L. As a result of this contamination, total zinc
results for samples MQA753, 754, 755, 757, 761, 790, and 863 and dissolved zinc
results MQA753, 754, 755, 761, 763, and 790 should be considered quantitative. The
total zinc result for sample MQA793 should be considered qualitative. All other
total and dissolved zinc results should not be used.
The duplicate injection RPDs for total chromium and iron in sample MQA755
were greater than DQO. All total chromium and iron results should be considered
semi-quantitative.
The serial dilution RPD results for total magnesium, manganese, and sodium
and dissolved manganese in sample MQA791 were outside DQO. All results for these
analytes should be considered semi-quantitative.
In several of the samples the dissolved results for an analyte were greater
than the total results for the same analyte. This was true for zinc in samples
MQA756, 759, 764, 791, 828, and 829 and for calcium in sample MQA863. Total and
dissolved zinc results for the above samples should not be used while the total and
dissolved calcium results for sample MQA863 should be considered qualitative. The
HWGWTF does not normally require dissolved metal sample determination because
EPA does not have a standardized protocol for subtracting dissolved metals from
total metals.
The analytical laboratory failed to report the mean and the standard deviations
for the interference check sample. This did not impact the data usability.
One of the analytical batches for the dissolved metal analytes included an
initial calibration blank (ICB) and several continuing calibration blanks (CCBs) for
chromium which were outside DQO. Dissolved chromium results for samples
MQA754, 756 through 762, 764, 792, 828 through 831, and 863 should be considered
semi-quantitative with the detection limits increased by a factor of two.
All total barium, beryllium, cobalt, copper, nickel, potassium, silver, tin, and
vanadmm results should be considered quantitative. Dissolved aluminum, barium,
beryllium, cobalt, copper, iron, nickel, potassium, silver, tin, and vanadium results
should be considered quantitative. Total calcium results with an exception,
dissolved chromium results for samples MQA753, 755, 763, 790, 791, and 793, total
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C-7
aluminum results for samples MQA753, 754, 761, and 763. dissolved zinc results for
samples MQA753 through 755, 761, 763, and 790, and total zinc results for samples
MQA753 through 755, 757, 761, 790, and 863 should also be considered quantitative.
All total chromium and iron and total and dissolved magnesium, manganese, and
sodium results should be considered semi-quantitative. Dissolved calcium and
chromium and total aluminum results, all with exceptions, should also be considered
serni-q-uantitative. All calcium results for sample MQA863 and total zinc results for
sample MQ.A793 should be considered qualitative. All zinc results with exceptions
and total aluminum results for sample MQA830 should not be used. The usability of
all total and dissolved ICP metal analytes is summarized in Section 4.2 and 4.3 at
the end of this Report.
1.4 Mercurv
All mercury results should be considered quantitative with an acceptable
probability of false negatives.
2.0 Inorganic and Indicator Analvtes
2.1 Inorganic and Indicator Analvte QC Evaluation
The average spike recoveries of all of the inorganic and indicator analytes
were within the accuracy DQOs. Accuracy DQOs have not ~een established for the
bromide, fluoride, nitrite nitrogen, and sulfide matrix spikes.
The calculable average RPDs for all inorganic and indicator analytes were
within Program DQOs. RPDs were not calculated if either one or both of the
duplicate values were less than the CRDL. Precision DQOs have not been
established for bromide, fluoride, nitrite nitrogen, and sulfide.
Requested analyses were performed on all samples for the inorganic and
indicator analytes.
No laboratory blank contamination was reported for any inorganic or indicator
analyte. POX and/or POC contamination were reported in all of the sampling
blanks and will be discussed below.
2.2 Inorganic and Indicator Analvte Data
All results for cyanide, bromide, chloride, fluoride, sulfate, sulfide, total
phenols, TOC, and TOX should be considered quantitative with an acceptable
probability of false negatives.
The matrix spike recovery of bromide from sample MQA791 was poor with a
value of 56 percent. This sample was diluted by a factor of 50 due to high chloride
suppression. It was not known whether this poor recovery was a dilution error or
a negative interference which was representative of the field samples. As there are
no HWGWTF DQOs for bromide, there was no impact on the usability of the bromide
results although they may be biased low.
The matrix spike result for fluoride from sample MQA"91 was not identified in
the raw data. This sample was diluted by a factor of 50 due to high chloride
suppression. There was no impact on the usability of the fluoride results.
-------
The holding times for the nitrate and nitrite nitrogen determinations ran^ea
from 4 to 14 days from receipt of the samples which is longer than the
recommended 48 hour holding time for unpreserved samples. All nitrate and nitrite
nitrogen results should be considered semi-quantitative.
Calibration verification standards for POC were not analyzed. A POC spike
solution was run during the analytical batch but the "true" value of the spike was
not provided by the laboratory. EPA needs to supply the inorganic laboratory with
a POC calibration verification solution. Until then, the instrument calibration can
not be assessed. Headspace was noticed in the sample vials for samples MQ.A753,
761, and 791. POC contamination was found in all sampling blanks at
concentrations ranging from 22 to 94 ug/L. The POC CRDL is 10 ug/L. The POC
results for samples MQA758, 765, 792, 828, 829, and S64 should be considered
qualitative. All other POC results should not be used due to blank contamination.
POX contamination was found in equipment blank MQA761 and field blank
MQA754 at concentrations of 42 and 17 ug/L. The POX CRDL is 5 ug/L. Due to
the this contamination, all positive POX results five times the higher concentration
or less should not be used, all POX results between five and ten times the higher
of the concentrations should be considered qualitative, and all results ten times the
level of contamination or greater, as well as all negative results, should be
considered quantitative. Therefore, POX results for sample MQA760 should not be
used while all other results should be considered quantitative with the following
exceptions. Headspace was reported in the sample vials for samples MQA753, 763,
790, and 791. Results for these four samples should be considered semi-quantitative.
3.0 Organics and Pesticides
3.1 Organic OC Evaluation
All matrix spike average recoveries were within established Program DQOs for
accuracy. Individual matrix spike recoveries which were outside the accuracy DQO
will be discussed in the appropriate Sections below.
All surrogate spike average recoveries, with the exception of the organo-
phosphorous herbicide surrogates which were neither required nor analyzed, were
within DQOs for accuracy. Individual surrogate spike recoveries which were outside
the accuracy DQO will be discussed in the appropriate Sections below.
All reported matrix spike/matrix spike duplicate average RPDs were within
Program DQOs for precision. Individual matrix spike RPDs which were outside the
precision DQO will be discussed in the appropriate Sections below.
All average surrogate spike RPDs were within DQOs for precision. No
surrogate standard was used or required for the organo-phosphorous herbicide
analysis.
Requested analyses were performed on all samples submitted to the laboratory.
Laboratory (method) and sampling blank contamination was reported for
organics and is discussed in Reference 4 as well as the appropriate Sections below.
Detection limits for the organic fractions arc summarized in Reference 4 as
well as the appropriate Sections below.
-------
C-9
3.2 Volatiles
The analytical laboratory exceeded the volatile holding time of seven days for
twenty of the twenty-three volatile samples. Holding times ranged from 5 to 63
days in excess of the maximum permissible seven day holding time. Volatile results
for all samples except MQA756, 758, and 759 should be considered unreliable.
Volatile results for samples MQA756, 758, and 759 should be considered quantitative.
Acetone contamination was found in laboratory (method) blanks MB-2, MB-4,
MB-5, and MB-6 at concentrations of 2 to 4 ug/L. Acetone contamination was also
found in sampling blanks MQA753 (equipment blank), 761 (equipment blank), 754
(field blank), and 763 (trip blank) at concentrations ranging from 2 to 6 ug/L. The
acetone CRDL is 10 ug/L. The source of this contamination is presumed to be the
analytical laboratory. All positive acetone results should not be used due to this
blank contamination.
Laboratory (method) blanks MB-1, MB-4, and MB-6 contained methylene
chloride contamination at concentrations of 1 to 2 ug/L. Methylene chloride
contamination was also found in sampling blanks MQA754 (field blank), 761
(equipment blank), 763 (trip blank), and 790 (field blank) at concentrations ranging
from 2 to 3 ug/L. The methylene chloride CRDL is 5 ug/L. The source of this
contamination is presumed to be the analytical laboratory. All positive methylene
chloride results should not be used due to this blank contamination.
2-Butanone was found both in laboratory (method) blank MB-5 and sampling
blank MQA754 at concentrations of 2 ug/L. The 2-butanone CRDL is 10 ug/L. All
positive 2-butanone results should not be used due to this blank contamination.
Estimated method detection limits were CRDL for all samples except MQA792
and 864 which were both 100 times CRDL, respectively. A one hundred fold dilution
of these samples was required due to the high concentration of trichloroethene.
The volatile results, with exceptions listed below, should be considered unreliable
due to excessive holding times. Volatile results for samples MQA756, 758, and 759
should be considered quantitative. All positive acetone, methylene chloride, and 2-
butanone results should not be used due to laboratory (method) blank contamination.
The probability of false negative and positive results is unknown due to the lengthy
holding times of the samples.
3.3 Semivolatiles
The analytical laboratory exceeded the semivolatile 40 day holding time
between extraction and analysis for nine of the semivolatile samples. Holding times
ranged from 4 to 20 days in excess of the permitted 40 day holding time from
extraction to analysis. Semivolatile results for these sampl'es should be considered
semi-quantitative.
The surrogate spike recovery of 2-fluorobiphenyl from samples MQA758, 761
and MB-2 was below DQO. This had no affect on data usability.
Three of the semivolatile laboratory (method) blanks, MB-1, MB-2, and MB-3,
contained contamination including several unknown compounds, an unknown
alkylamide, and an unknown alkane at concentrations of 6 and 100 ug/L.
-------
C-10
The relative standard deviation of response factors for the initial calibration
and the percent differences between the initial and continuing calibration response
factors showed significant variation. These values should be individually considered
and may affect data usability.
An unknown semivolatile compound was detected but not reported or confirmed
as a tentatively identified compound in samples MQA753, 754, 755, 756, 757, 758,
759, 761, 762, 763, 764, 765, 790, 791, 792, 793, 830, 831. 863, 864, and MB-1.' This
is approximately the retention time of 2-hexanone but the compound is not 2-
hexanone. According to the laboratory it is an unknown artifact. The presence of
this compound should be addressed by the laboratory.
The presence of a large general ion current from retention index 1200 to 2100
in the chromatogram of sample MQA864 may have hindered the detection of target
analytes.
Due to a dilution factor of two for all samples, the estimated detection limits
for the semivolatiles were approximately twice the CRDL. The semivolatile data are
acceptable and the results should be considered semi-quantitative for all samples.
3.4 Pesticides
No laboratory (method) blank contamination was detected. However, on Form
VIII, dated 5/10/87, MB-3 is denoted as MB-4. This error was corrected on the
method blank sample data sheet.
Heptachlor and aldrin may be present in samples MQA753 and 828 at
concentrations below the CRDL but above the actual laboratory detection limit.
Their presence was not reported due to retention time shifts.
Pesticide analyses were not performed on samples MQA765 and 793.
The dibutylchlorendate retention time shift was outside DQO for aroclor
standard 1016/1260 on the DB-17 column.
An unknown, non-HSL (Hazardous Substance List) compound was present in all
chromatograms run on the DB-17 column at a retention time of about 19.23 minutes.
The corresponding peak was not seen in the chromatograms run on the primary
column.
The estimated method detection limits for all pesticides analyses is the CRDL.
The pesticides results should be considered quantitative.
3.5 Herbicides
The herbicides for which the laboratory analyzed include only 2,4-D, 2,4,5-T,
2,4,5-TP, chlorobenzilate, phorate, disulfoton, parathion, and famphur. Herbicide
analyses were not performed on samples MQA765 and 793.
2,4-DB was used as a surrogate for the chloro-herbicide fraction. No
surrogates were included for the organo-phosphorous herbicides.
The quality of the chloro-herbicides chromatograms was not sufficient to allow
the tentative identification and confirmation of these compounds. Several field
samples were reported to contain chloro-herbicides. However, numerous chloro-
herbicide peaks were observed in the method, field, and trip blank chromatograms.
-------
C-ll
The tentative identification and quantification of chloro-herbicides in all samples
should be considered unreliable due to this blank contamination.
Poor chromatographic quality was observed on the OV-101 column. Peak
tailing and apparent column bleed was observed in both the samples and standards
run on this column.
The organo-phosphorous herbicide results should be considered qualitative due
to the lack of surrogates. The estimated method detection limits were the CRDL
for the organo-phosphorous herbicide analyses with the exception of sample
MQA828. This sample was diluted by a factor of 10 and thus had its detection
limits raised by this same factor.
The chloro-herbicide results should be considered unreliable due to blank
contamination.
III. Data Usability Summary
4.0 Graphite Furnace Metals. Total (Section 1.2)
Quantitative: all arsenic and cadmium results; thallium results with
exceptions
Semi-quantitative: all antimony results; thallium results for samples MQA755 756
758, 759, and 790
Qualitative: lead results for sample MQA755, 757, 758, 792, 793, and 829
Unusable: all selenium results; lead results with exceptions
4.1 Graphite Furnace Metals. Dissolved (Section 1 21
Quantitative: all antimony, arsenic, and lead results
Semi-quantitative: all cadmium results; selenium results with an exception
Unusable: all thallium results; selenium results for sample MQA755
4.2 rCP Metals. Total (Section 1.3)
Quantitative: all barium, beryllium, cobalt, copper, nickel, potassium, silver,
tin, and vanadium results; calcium results with an exception; '
aluminum results for samples MQA753, 754, 761, and 763; zinc
results for samples MQA753, 754, 755, 757, 761, 790, and 863
Semi-quantitative: all chromium, iron, magnesium, manganese, and sodium results;
aluminum results with exceptions
Qualitative: the calcium result for sample MQA863; the zinc result for
sample MQA793
Unusable: zinc results with exceptions; the aluminum result for sample
MQA830
4.3 ICP Metals. Dissolved(Section I /n
Quantitative: all aluminum, barium, beryllium, cobalt, copper, iron, nickel,
potassium, silver, tin, and vanadium results; chromium results
for samples MQA753, 755, 763, 790, 791, and 793; zinc results
for samples MQA753, 754, 755, 761, 763, and 790
Semi-quantitative: all magnesium, manganese, and sodium results; calcium and
chromium results with exceptions
Qualitative: the calcium result for sample MQA863
Unusable: zinc results with exceptions
-------
C-12
4.4 Mercurv (Section 1.4)
Quantitative: ail mercury results
4.5 Inorganic and Indicator Analvtes (Section 2.2)
Quantitative: all cyanide, bromide, chloride, fluoride, sulfate, sulfide, total
phenols, TOC, and TOX; POX results with exceptions
Semi-quantitative: all nitrate and nitrite nitrogen results; POX results for
samples MQA753, 763, 790, and 791
Qualitative: POC results for samples MQA758, 765, 792, 828, 829, and 864
Unusable: POC results with exceptions, the POX result for sample
MQA760
4.6 Oreanics (Sections 3.2 through 3.5)
Quantitative: volatile results for samples MQA756, 758, and 759 with
exceptions listed below; all pesticides results
Semi-quantitative: all semivolatile results
Qualitative: organo-phosphorous herbicide results
Unreliable: volatile results with exceptions; chloro-herbicide results
Unusable: all positive acetone, methylene chloride, and 2-butanone
results
IV. References
1. Organic Analyses: EMSI
4765 Calle Quetzal
Camarillo, CA 93010
Inorganic and Indicator Analyses:
Centec Laboratories
P.O. Box 956
2160 Industrial Drive
Salem, VA 24153
(703) 387-3995
2. Draft Quality Control Data Evaluation Report (Assessment of the Usability of
the Data Generated) for Case K-2363HQ, Site 50, Rocky Flats, CO, 6/30/87,
Prepared by Lockheed Engineering and Management Services Company, Inc., for
the US EPA Hazardous Waste Ground-Water Task Force.
3. Draft Inorganic Data Usability Audit Report, for Case K-2363HQ, Rocky Flats,
CO, Prepared by Laboratory Performance Monitoring Group, Lockheed
Engineering and Management Services Co., Las Vegas, Nevada for US EPA
EMSL/Las Vegas, 7/1/87.
4. Draft Organic Data Usability Audit Report, for Case K-2363HQ, Rocky Flats,
CO, Prepared by Laboratory Performance Monitoring Group, Lockheed
Engineering and Management Services Co., Las Vegas, Nevada, for US EPA
EMSL/Las Vegas, 7/1/87.
-------
C-13
V. Addressees
Gareth Pearson
Quality Assurance Division
LTS EPA Environmental Monitoring Systems Laboratory - Las Vegas
P.O. Box 1198
Las Vegas, Nevada 89114
Richard Steimle
Hazardous Waste Ground-Water Task Force, OSWER (WH-562A)
US Environmental Protection Agency
401 M Street S.W.
Washington, DC 20460
Steve Mangion
US Environmental Protection Agency
JFK Federal Building
Room 2203
Boston, MA 02203
Steve Sisk
US Environmental Protection Agency
NEIC/OECM
Building 53, Box 25227
Denver, CO 80225
Paul Friedman
Room 413-W
Science Policy Branch (PM-220)
US Environmental Protection Agency
401 M Street S.W.
Washington, DC 20460
Sujith Kumar
Laboratory Performance Monitoring Group
Lockheed Engineering and Management Services Company
1051 East Flamingo Drive, Suite 257
Las Vegas, Nevada 89119
Ken Partymiller
PRC EMI/Houston
10716 Whisper Willow Place
The Woodlands, TX 77380
-------
C-14
Appendix C
Specific Analytical Results
Rocky Flats
Golden, Colorado
Table C-l Samnle Preparation, Analytical Techniques, and Methods
Table C-2 Organic Results
Table C-3 Orqanic Limits of Ouantitation
Table C-4 Dissolved and Total Metal Results
Table C-5 Field Measurements and General Analvtical Parameters
Table C-6 Radionuclide Results
Table C-7 Radionuclide Limits of Detection
-------
Table C-l
Sample Preparation and Analysis Techniques and Methods
Rocky Flats Facility, Golden, Colorado
Samples Collected, April 1987
Parameter
Preparation Technique
Analysis Technique
Method Reference
Specific Organic
Volatiles
Semi-volatiles
Pesticides/PCB
Herbicides
Dioxins and
Dibenzofurans
Constituents
Purge and trap
Methylene chloride extraction
Methylene chlonde/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
Sulfate
Chloride
Nitrite
Bromide
Fluoride
Sulfide
Phenol
Cyanide
None
None
None
None
None
None
None
Automated distillation
Manual distillation
Gas Chromatography - Mass Spectroscopy
Gas Chromatography - Mass Spectroscopy
Gas Chromatography with Electron Ca^ ure 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
Colormetric, 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
EPA Method 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
I—»
en
-------
Table C-l (cont'd.)
Sample Preparation and Analysis Techniques and Methods
Rocky Flats Facility, Golden, Colorado
Samples Collected, April 1987
i
01
Parameter
Gross Alpha
Gross Beta
Gross Radium
Radium-228
Cesium-137
Ruthenium-106
Strontium 90
Americium 241
Plutonium 238
Plutonium 239,
Uranium-234
Uranium-235
Uranium-238
Tritium
Preparation Technique
Nitric acid digestion
Nitric acid digestion
Precipitation with barium sulfate
Coprecipitation separation
None
None
None
Multiple Anion separation
Multiple Anion separation
240 Multiple Anion separation
Multiple Anion separation
Multiple Anion separation
Multiple Anion separation
Distillation
Analysis Technique
Scintillation Detector
Scintillation Detector
Scintillation Detector
Proportional Counter
Gamma-ray Spectrometer with Analyzer
Gamma-ray Spectrometer with Analyzer
Gamma-ray Spectrometer with Analyzer
Alpha Spectroscopy
Alpha Spectroscopy
Alpha Spectroscopy
Alpha Spectroscopy
Alpha Spectroscopy
Alpha Spectroscopy
Liquid Scintillation
Spectrometer
Method Reference
EPA Method 900.0
EPA Method 900 .0
EPA Method 900.1
USGS Gamma Method
EPA 901 0
EPA 901.1
ASTM Proposed Method
RSL 304
RSL 304
RSL 304
RSL 304
RSL 304
RSL 304
RSL 302
Based on EPA 906
-------
TABLE C-2
ORGANIC ANALYSIS RESULTS
ROCKY FLATS FACILITY, GOLDEN, COLORADO
SAMPLES COLLECT-1^ APRIL 1987
WELL NUMBER:
SMO NUMBER:
PARAMETER
Tetrachloroethane
Tnchlorofluoronmethane
Chloroform
1 , 1 ,1-Trichloroethane
Tri chlorethene
1 , 1-dlchloroethene
bis (2-Ethylhexyl) phthalate
Diethylene glycol
Tetcaethylene glycol
Octanoic acid
Nonanoic acid
Decanoic acid
Dodecanoic acid
Tetradecanoic acid
Palmitic acid
LOQ FACTORS (c)
VOLATILES
SEMIVOLATILES
PEST/PCBs
02-71
MQA792
ug/L
ND a
ND
210 b
ND
14 ,000
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
09-74
MQA864
ug/L
2000
ND
ND
11,000
9 , 400
3, 500
ND
ND
ND
ND
ND
ND
ND
ND
10 b
08-86
MQA764
ug/L
ND
1 b
ND
ND
ND
ND
ND
10 b
8 b
20 b
70 b
30 b
90 b
20 b
ND
14-86
MQA791
ug/L
ND
ND
ND
ND
ND
ND
3 b
ND
ND
ND
ND
ND
ND
ND
ND
27-86
MQA793
ug/L
ND
ND
ND
ND
ND
ND
ND
ND
ND
10 b
50 b
10 b
30 b
ND
ND
30-86
MQA828
ug/L
1 b
ND
ND
ND
ND
ND
3 b
ND
ND
ND
7 b
ND
20 b
ND
ND
32-86
MQA829
ug/L
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
20 b
ND
ND
100X
2X
IX
100X
2X
IX
IX
2X
IX
IX
2X
IX
IX
2X
NR d
IX
2X
IX
IX
2X
IX
a) Compound was not detected.
b) Estimated concentration. Compound was detected, but the concentration was below the Limit of Quanti tation (LOQ)
c) LOQ Factor is the factor to account for dilutions.
d) Not requested
o
i
-------
TABLE C-2
ORGANICS ANALYSIS RESULTS
ROCKY FLATS FACILITY, GOLDEN, COLORAD
SAMPLES COLLECTED. APRIL 1987
o
I—»
CO
WELL NUMBER
SMO NUMBER.
PARAMETER
Trichlorofluoromethane
Carbon tetrachloride
Chloroform
1,1, 1-Trichloroethene
Trichloroethene
Chrysene
bis(2-Ethylhexyli
Cyclohexanol
Dodecanoic acid
LOQ FACTOR (c)
VOLATILES
SEMIVOLATILES
PEST/PCB'S
34-86
MQA756
ug/L
hane ND a
de ND
ND
ene ND
ND
3 b
phthalate ND
ND
ND
IX
2X
IX
43-86
MQA759
ug/L
ND
4 b
ND
ND
ND
ND
1 b
ND
10 b
IX
2X
IX
48-86
MQA758
ug/L
ND
ND
ND
ND
ND
ND
12
ND
ND
IX
2X
IX
49-86
MQA757
ug/L
ND
ND
ND
ND
ND
ND
ND
30 b
ND
IX
2X
IX
54-86
MQA762
ug/L
1 b
ND
ND
ND
ND
ND
3 b
ND
ND
IX
2X
IX
57-86
MQA765
ug/L
ND
ND
ND
ND
ND
ND
3 b
ND
ND
IX
2X
NR d
59-86
MQA755
ug/L
ND
ND a
ND
ND
ND
ND
ND
30 b
ND
IX
2X
IX
62-86
MQA863
ug/L
ND
ND
ND
ND
ND
ND
ND
ND
10 b
IX
2X
IX
WET WELLi
MQA760 , 8:
831
ug/L
ND
8
2
9
6
ND
ND
ND
ND
IX
2X
IX
!e
30
b
a) Compound was not detected.
b) Estimated concentration. Compound was detected, but the concentration was below (.he Limit of Quant it lation (LOQ)
c) LOQ Factor is the factor to account for dilutions
d) Not requested.
e) Wet well was sampled and analyzed in triplicate results were averaged for report
EPA/NEIC/DENVER
-------
Table C-3
Limits of Quantitation for Organic Compounds
Rocky Flats Facility, Golden, Colorado
Samples Collected: April 1987
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.
Dichlorodifluoromethane 5.
Tnchlorof luoromethane 5.
Bromoform 5 .
Chloroform 5.
Carbon tetrachloride 5.
Carbon disulfide 5.
Chloroethane 10 .
1, 2-Dibromoethane 5,
1, 1-Dichloroethane 5.
1, 2-Dichloroethane 5.
1, 1,1-Trichloroethane 5.
1, 1, 2-Tnchloroethane 5.
1,1,1,2-Tetrachloroethane 5.
1,1,2,2-Tetrachloroethane 5.
1, 1-Dichloroethene 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-butene 50.
Benzene 5 .
Chlorobenzene 5.
Toluene 5 .
Xylenes 5 .
Ethylbenzene 5.
2-Methyl-l-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 5000
Styrene 5
Vinyl Acetate 10
Crotonaldehyde 50
Pentachloroethane 10.
Hexachloroethane 10.
1,2-Dibromo-3-chloropropane 10.
Hexachloropropene 10.
trans-4-dichloro-2-butene 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-Tnchlorobenzene 10.
Pentachlorobenzene 10.
Hexachlorobenzene 10.
Pentachloronitrobenzene 10.
Nitrobenzene 10.
Dinitrobenzene 10.
2,4-Dinitrotoluene 10.
2,6-Dinitrotoluene 10.
N-Nitrosodimethylamine 10.
N-Ni trosodiethylamine 10.
N-Nitrosomethylethylamine 10.
N-Nitrosodiphenylamine and/or
Diphenylamine 10.
N-Nitroso-di-n-butylamine 10.
alpha,alpha-
Dimethylphenethylamine 50.
1-Naphthylamine 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-Chlorethoxy)methane 10.
Hexachloroethane 10
Hexachlorobutadlene 10.
Hexachlorocyclopentadlene 10.
bis(2-Ethylhexyl) phthalate 20
Butyl benzyl phthalate 10.
di-n-Butyl phthalate 10.
di-n-Octyl 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)fluoranthene and/or
Benzo(k)fluoranthene 10.
Benzo(g,h,i)perylene 10.
Benzo(a)pyrene 10.
Dibenzo(a,e)pyrene 10.
Dibenzo(a,h)pyrene 10.
Dibenzo(a,3)pyrene 10.
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-Chloronaphthalene 10.
2-Methylnaphthalene 10
Phenanthrene 10.
3-Methylcholanthrene 10
Methapyrilene 50.
5-Nitro-o-toluidine 10
o-Toluidine 10
2-Picoline 10.
N-Nitrosopiperidine 10.
Safrole 10.
1,4-Naphoquinone 10.
Pyridine 10
Methyl Methacrylate 10.
Ethyl Methacrylate 10.
p-Dimethylaminoazobenzene 10
4-Aminobiphenyl 10
P ronamide 10.
Isosafrole 10.
N-Nitrosopyrrolidine 10
Cyclophosamide 10
Phenacetin 10
Methyl methane sulfonate 10
I
I—t
UD
-------
Table C-3 (cont.)
Limits of Quantitation for Organic Compounds
Rocky Flats Facility, Golden, Colorado
Samples Collected: April 1987
o
i
Semi-Volatile Compounds
ug/L
Chlorinated Pesticides/PCBs ug/L
Organo-phosphate Pesticides ug/L
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.
2-Methylphenol 10.
4-Methylphenol 10.
2,4-Dimethylphenol 10.
4,6-Dinitro-2-methylphenol 50.
2-Nitrophenol 10.
4-Nitrophenol 50.
2 , 4-Dinitrophenol 50.
Cyclohexanol 50.
Diethylene glycol 100.
Tetraethylene glycol 100.
Octanoic acid 100.
Nonanoic acid 100.
Decanoic acid 100.
Dodecanoic acid 100.
Tetradecanoic acid 100.
Palmitic acid 100.
Chysysene 10.
Aldrin
alpha-BHC
beta-BHC
gamma-BHC (Lindane)
delta-BHC
Chlordane
4,4'-ODD
4,4'-DDE
4,4'-DDT
Dieldrin
Endosulfan I
Endosulfan II
Endosulfan sulfate
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide
Toxaphene
Methoxychlor
Endrin ketone
PCB-1016
PCB-1221
PCB-1232
PCB-1242
PCB-1248
PCB-1254
PCB-1260
Kepone
Chlorobenzilate
Isodrin
0 . 05
0. 05
0. 05
0 .05
0. 05
0. 5
0. 1
0. 1
0. 1
0. 1
05
1
2
1
0. 1
0. 05
0. 05
1 .
0. 5
0. 2
0 . 5
0. 5
0. 5
0. 5
0 5
1 .
1
1 .
1 .
0 . 05
Phorate
Disulfoton
Parathion
Famphur
Herbicides
2,4-Dichlorophenoxy
acetic acid
2,4,5-T
2,4,5-TP (Silvex)
Chlorobenzilate
Dioxins/Dibenzofurans
5.
5
5
20.
ug/L
1 .
0 1
0 . 1
1 .
ng/L
TCDD (Tetra)
PeCDD (Penta)
HxCDD (Hexa)
HpCDD (Hepta)
OCDD (Octa)
PeCDF (Penta)
HxCDF (Hexa)
HpCDF (Hepta)
OCDFF (Octa)
10.
10
10.
20.
20.
10
10
20 .
20 .
b
b
b
b
b
b
b
b
b
a) Estimated value; standard not available at the time of analysis.
b) Estimated value for an individual isomer of the compound class; calculated by NEIC using the lowest standard
concentration analyzed by CL.
-------
Well 02-71
SMO NO: MQA792
TABLE C-4
DISSOLVED AND TOTAL METALS ANALYSIS RESULTS
ROCKY FLATS FACILITY, GOLDEN, COLORADO
Well 08-86
SMO NO: MQA764
Well 14-86
SMO NO MQA791
Element
Al
Sb
As
Ba
Be
Cd
Ca
Cr
Co
Cu
Fe
Pb
Mg
Mn
Hg
Nl
K
Se
Ag
Na
Tl
Sn
V
Zn
Dissolved
Value , ug/L
< 44 . a
< 60.
< 10 .
71 .
< 2 .
< 5. b
63,700. b
< 10 .
< 20 .
< 8 .
< 20 .
< 2 .
18,600 b
35. c
< . 2
< 24 .
1 ,560
26 . b
< 5 .
184,000. b
< 100. b
< 38
< 14 .
21
Total
Value,
4, 380
< 60
< 6
104
< 2
< 5
61 , 700
< 10
< 20
15
21, 100
6
19, 000
123
<
< 24
2, 060
30
9
178, 000
< 7
< 38
< 14
83
, ug/L
b
b
d
bd
.2 b
. b
b
. 2
b
b
Dissolved
Value , ug/L
113 .
< 60 .
< 10 .
33 .
< 2 .
< 5 . b
29 , 000 . b
< 10 .
< 20 .
< 8 .
< 20 .
< 5 .
1 , 280 . b
< 5 . c
< . 2
< 24 .
10 ,800 .
5 b
9 8 , 9 ,,o . b
< 10 . b
< 38 .
29 .
37 .
Total
Value , ug/L
84 b
< 60. b
< 6.
17 .
< 2.
. 5
26, 100 .
< 10 . d
< 20 .
9 .
68 . bd
< 5 b
890 . c
< 5 . c
< . 2
< 24 .
9 , 300 .
4 3 b
8 .
86,200 c
< 7
< 38 .
25
< 14 .
D i s solved
Value , ug/L
79 .
< 60 .
< 10
60 .
< 2 .
< . 6 b
133 , 000 . b
< 10 .
< 20 .
< 8 .
< 20 .
< 5 .
39 , 600 . b
164 . c
< . 2
< 24 .
6,870 .
< 5 b
< 5 .
255,000. b
< 100. b
< 38
< 14 .
102 .
Total
Value,
1, 680
< 60.
< 10.
59 .
< 2 .
< 5 .
123 , 000
26
< 20 .
12
2, 540
< 5 .
36, 300
174
< .
32 .
6,210.
< 5
15
213 , 000 .
< 10
< 38 .
15
24
ug/L
b
b
d
bd
b
c
c
2
b
c
a = Sample concentration is less than the number listed at the 99% confidence level
b = Batch spike sample recovery was not within control limits indicating possible bias
c = Estimated value; interference present causing possible bias.
d = Duplicate analysis not within control limits
-------
ro
rx>
Well 27-86
SMO NO: MQA793
TABLE C-4
DISSOLVED AND TOTAL METALS ANALYSIS RESULTS
ROCKY FLATS FACILITY, GOLDEN, COLORADO
Weil 30-86
SMO NO- MQA828
Well 32-86
SMO NO MQA829
Element
Al
Sb
As
Ba
Be
Cd
Ca
Cr
Co
Cu
Fe
Pb
Mg
Mn
Hg
Ni
K
Se
Ag
Na
Tl
Sn
V
Zn
Dissolved
Value , ug/L
78 .
< 3 . a
< 10 .
57 .
< 2 .
< 5. b
48,900. b
< 10 .
< 20 .
47 .
69 .
< 5 .
16 , 100 . b
107 . c
< . 2
216 .
6,910 .
< 4 b
< 5 .
236,000 b
< 100. b
< 38 .
< 14
180
Total
Value , ug/L
4,480. b
< 3 b
< 6 .
67 .
3
. 6
44 , 700
136 d
27 .
914 .
8,120. bd
17 . b
14 , 600 . c
154 c
< . 2
490 .
5, 600 .
< 5 . b
10
204 , 000 . c
< 7
87
22.
204
Dissolved
Value , ug/L
402 .
< 60
< 10 .
292 .
2 .
< 5 . b
1 ,470,000 . b
< 10 .
< 20
17
< 20 .
< 2 .
333,000. b
77 c
< . 2
< 24 .
71 ,600 .
< 5. b
< 5 .
1 , 360,000 . b
< 100. b
< 38 .
14 .
414
Total
Value , ug/L
5, 490 b
< 60. b
< 10.
375
3 .
. 8
1 , 280, 000 .
50 . d
< 20.
21
5,310. bd
< 2. b
296, 000 . c
157 . c
< . 2
29 .
87,600
< 5. b
11
1,310, 000 . c
< 10.
55
22.
24 .
Dissolved
Value , ug/L
252 .
< 60
< 10 .
110 .
< 2 .
< 5 b
47,400. b
< 10
< 20 .
< 8
< 20 .
< 2 .
12 , 100 b
53 c
< . 2
< 24 .
5,120
< 5 b
< 5 .
145 ,000 . b
< 100 . b
< 38
< 14 .
305
Total
Value
8, 090
< 60
< 10
159
< 2
< 5
44, 400
118
< 20
61
9,450
50
11 , 800
143
<
70
5,4-0
< 5
10
127 , 000
< 7
< 38
26 .
1
, ug/L
b
b
d
bd
b
c
c
2
b
c
a = Sample concentration is less than the number listed at the 99% confidence level
b = Batch spike sample recovery was not within control limits indicating possible bias.
c = Estimated value, interference present causing possible bias
d = Duplicate analysis not within control limits.
-------
TABLE C-4
DISSOLVED AND TOTAL METALS ANALYSIS RESULTS
ROCKY FLATS FACILITY, GOLDEN, COLORADO
Element
Al
Sb
As
Ba
Be
Cd
Ca
Cr
Co
Cu
Fe
Pb
Mg
Mn
Hg
Nl
K
Se
Ag
Na
Tl
Sn
V
Zn
Well
SMO NO:
Dissolved
Value , ug/L
74 .
< 60 . a
< 10 .
130 .
< 2 .
< 5 . b
268,000. b
< 10 .
< 20 .
< 8
315 .
< 5 .
83,000. b
117 . c
< .2
< 24 .
8,550.
< 5. b
< 5 .
259,000. b
< 100 b
< 38 .
< 14
301
34-86
MQA756
Total
Value , ug/L
2, 820 b
< 60 . b
< 10.
66 .
< 2.
< 5 .
244, 000
22. d
20.
33 .
4,730 bd
< 5 . b
70,900. c
183 . c
< . 2
< 24
7, 380 .
< 5 b
8 .
214,000 c
< 7 .
< 38 .
< 14.
34
Well
SMO NO
Dissolved
Value , ug/L
< 44 .
< 60
< 6 .
151
< 2 .
< 5 . b
99,400. b
< 10 .
< 20 .
< 8 .
< 20
< 2 .
9 , 090 b
< 5. c
< . 2
< 24 .
1 , 140 .
< 4 b
< 5 .
11 , 200 . b
< 10 b
< 38
< 14 .
62 .
43-86
MQA759
Total
Value , ug/L
3,910. b
< 3 b
< 6 .
129 .
< 2.
< 5
99 , 600 .
62. d
< 20 .
< 8.
6,250. bd
4 7 b
9,590 c
68. c
< . 2
< 24 .
1,800
< 40 . b
10.
10, 700 . c
< 7 .
< 38 .
16
24.
Well
SMO NO
Dissolved
Value , ug/L
83
< 60
< 6 .
41
2 .
< 5 . b
8,930. b
< 10 .
< 20 .
< 8 .
< 20 .
< 2 .
1,530 b
< 5 . c
< . 2
< 24 .
6,330.
< 4 b
6 .
45,400. b
< 10 b
< 38
< 14 .
71
48-86
MQA758
Total
Value,
7 , 440
< 3
< 6
155
< 2
< 5
45,100
< 10
< 20
65
5,430
10
7 , 270
123
<
< 24
6, 390
< 50
< 5
49, 400
< 7
< 38
24 .
103
, ug/L
b
b
d
bd
b
c
c
2
b
c
a = Sample concentration is less than the number listed at the 99% confidence level
b = Batch spike sample recovery was not within control limits indicating possible bias
c = Estimated value; interference present causing possible bias
d = Duplicate analysis not within control limits
i
t\5
OJ
-------
o
I
ro
Well 49-86
SMO NO: MQA757
TABLE C-4
AND TOTAL METALS ANALYSIS RESULTS
ROCKY FLATS FACILITY, GOLDEN, COLORADO
Well 54-86
SMO NO: MQA762
Well 59-86
SMO NO. MQA755
Element
Al
Sb
As
Ba
Be
Cd
Ca
Cr
Co
Cu
Fe
Pb
Mg
Mn
Hg
Nl
K
Se
Ag
Na
Tl
Sn
V
Zn
Dissolved
Value , ug/L
318 .
< 60 . a
< 6
116 .
< 2 .
< 5 . b
31 , 400 b
< 10 .
< 20 .
< 8 .
50
< 2 .
6,990 . b
222 c
< . 2
< 24 .
918 .
< 4 . b
< 5
31 ,800 . b
< 10 . b
< 38
< 14
102 .
Total
Value , ug/L
195,000. b
< 3 b
< 6 .
938 .
12.
< 5 .
55, 700 .
199 . d
62.
213.
196,000. bd
55. b
35,300. c
2,990. c
. 5
139 .
21, 300.
< 50 . b
6.
36, 200 . c
< 7 .
98.
305.
329 .
Dissolved
Value , ug/L
< 44 .
< 60 .
< 6 .
98
< 2 .
< 5. b
99 , 100 . b
< 10 .
< 20 .
< 8 .
< 20
< 2 .
24,400 b
214 . c
< 2
< 24 .
4,760 .
< 4 . b
< 5 .
36 , 700 . b
< 10 . b
< 38 .
< 14
42 .
Total
Value , ug/L
1 , 810 . b
< 3 b
< 6
144 .
< 2
. 6
97, 100.
27 . d
< 20
39 .
3,650. bd
< 5 b
24,400 c
416. c
< . 2
< 24 .
4 , 740 .
< 5. b
8 .
37 , 600 . c
< 7 .
< 38 .
< 14
46.
Dissolved
Value , ug/L
138
< 60 .
< 10 .
93 .
< 2 .
< 5 . b
129 , 000 b
< 10 .
< 20
< 8 .
< 20
5 .
44,200. b
42 c
< 2
33
2 ,400
49 . b
< 5
145,000. b
< 100 . b
< 38 .
< 14
< 14 .
Total
Value
610
< 60
< 10
99
< 2
1
130, 000
26
21
< 8
578
18
44, 800
54
<
86
2, 130
< 4
< 5
147 , 000
< 7
< 38
< 14
< 14
, ug/L
b
b
0
d
bd
b
c
c
. 2
b
c
a = Sample concentration is less than the number listed at the 99% confidence level.
b = Batch spike sample recovery was not within control limits indicating possible bias
c = Estimated value, interference present causing possible bias.
d = Duplicate analysis not within control limits
-------
TABLE C-4
DISSOLVED AND TOTAL METALS ANALYSIS RESULTS
ROCKY FLATS FACILITY, GOLDEN, COLORADO
WELL 62-86
SMO NO: MQA863
WET WELL
SMO NO. MQA760, 830, 831
Element
Al
Sb
As
Ba
Be
Cd
Ca
Cr
Co
Cu
Fe
Pb
Mg
Mn
Hg
Nl
K
Se
Ag
Na
Tl
Sn
V
Zn
Dissolved
Value, ug/L
112 .
< 60 . a
< 6 .
27 .
< 2.
< 5 . b
42, 300 . b
< 10 .
< 20
< 8.
< 20 .
< 2.
4, 750 . b
< 5. c
< . 2
< 24.
12, 300 .
35 . b
< 5
55,500. b
< 10. b
< 38
< 14 .
28 .
Total
Value , ug/L
603 . b
< 3 b
< 10
30 .
< 2 .
< 5 .
32,800 .
< 10 d
< 20 .
< 8
477. bd
< 2 . b
3 , 100 . c
6 . c
< . 2
< 24 .
12, 200 .
29 b
5 .
54,600. c
< 7 .
< 38 .
< 14 .
< 14 .
Di ssolved
Value , ug/L
< 44
< 60 .
< 10.
176.
< 2 .
< 5. b
255,000. b
< 10.
< 20 .
< 8
< 20 .
< 5 .
66, 600 b
< 5 . c
< . 2
< 24.
66, 900.
< 45. b
< 14.
405,000. b
< 100. b
< 38 .
< 14
45 .
Total
Value
87
< 60
< 10
171
< 4
242 , 000
< 10
< 20
< 8
101
< 5
64, 200
6
<
< 24
64, 900
5
8
397 , 000
< 10
< 38
< 15
32
, ug/L
b
b
. 7
. d
bd
b
c
c
. 2
. 1 b
c
a = Sample concentration is less than the number listed at the 99% confidence level
b = Batch spike sample recovery was not within control limits indicating possible bias
c = Estimated value; interference present causing possible bias
d = Duplicate analysis not within control limits.
NOTE
Results for samples MQA765, (MW57-86) and MQA864, (MW 9-74) were not reported
-------
TABLE C-5
FIELD MEASUREMENTS and
GENERAL CONSTITUENT ANALYSIS
ROCKY FLATS FACILITY, GOLDEN, COLORADO
SAMPLES COLLECTED APRIL 1987
i
FX>
cn
STATION.
SMO NO.
PARAMETER
pH
Conductance
Temperature
POX
TOX
POC
TOC
Bromide
Chloride
Nitrate
Sulfate
Nitrite
Cyan ide
Phenol
Sulf ide
Fluoride
UNITS
UNITS
umhos/cm
'C
ug/L Cl
ug/L Cl
ug/L C
ug/L C
mg/L
mg/L Cl-
mg/L N
mg/L S04=
mg/L
ug/L
ug/L
mg/L
mg/L F-
WELL
02-71
MQA792
VALUE
8 .
1200.
9 .
12100.
8720
2600.
3400.
27
160 .
3 6
157.
< . 3
< 10.
< 50.
< 1 .
1 . 1
WELL
09-74
MQA864
VALUE
7 . 4
1925.
10 .
NR a
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
WELL
08-86
MQA764
VALUE
11 .
710.
10 .
< 5 b
< 5
17 .
5500 .
< 1 .
7 . 9
< . 3
190 .
< . 3
< 10.
< 50
< 1 .
1 . 4
WELL
14-86
MQA791
VALUE
7 7
1860 .
12.
< 5 .
6 .
44 .
2000.
< 1 .
94.
< . 3
590 .
< . 3
< 10 .
< 50 .
< 1 .
< 1 .
WELL
27-86
MQA793
VALUE
7 . 9
1420
16 .
< 5
NA
62 .
NA
< 1 .
160.
< 3
250 .
< 3
NA
< 1
< 1 .
1 . 8
WELL
30-86
MQA828
VALUE
7 2
7150.
10
< 5 .
82.
7200
6600
< 1 .
260.
2100
300 .
< 3
< 10
< 100
< 1 .
< 1 .
WELL
32-86
MQA829
VALUE
8.
960
14.
< 5
< 5 .
6400.
4300
< 1 .
115.
1 .
97
< 3
NA
< 1
< 1
1 6
WELL
34-86
MQA756
VALUE
7 . 2
2200.
NA
< 5
< 5
19
3400.
< 1
52.
' . 3
. 0
< 3
< 10
< 50
< 1 .
< 1 .
a) NR - Not reported.
b) Sample concentration is less than (<) the value shown.
-------
TABLE C-5
FIELD MEASUREMENTS and
GENERAL CONSTITUENT ANALYSIS
ROCKY FLATS FACILITY, GOLDEN, COLORADO
SAMPLES COLLECTED: APRIL 1987
STATION:
SMO NO:
PARAMETER
pH
Conductance
Temperature
POX
TOX
POC
TOC
Bromide
Chloride
Nitrate
Sulf ate
Nitrite
Cyanide
Phenol
Sulfide
F luor ide
UNITS
UNITS
umhos/cm
'C
ug/L Cl
ug/L Cl
ug/L C
ug/L C
mg/L
mg/L Cl-
mg/L N
mg/L S04=
mg/L
ug/L
ug/L
mg/L
mg/L F-
WELL
43-86
MQA759
VALUE
7 .7
600 .
12 .
< 5 . a
15 .
28
2600 .
< 1 . b
42
5 5
29 .
< .3
< 10
< 50 .
< 1 .
< 1 .
WELL
48-86
MQA758
VALUE
11 .
350
13 .
< 5 .
9 .
2600 .
1300 .
< 1 .
11 .
< . 3
18 .
< . 3
< 10
< 50 .
< 1 .
< 1 .
WELL
49-86
MQA757
VALUE
6 3
400 .
12
< 5 .
20 .
26 .
2500 .
< 1 .
20 .
15 .
45 .
< . 3
10 .
< 50 .
< 1 .
< 1 .
WELL
54-86
MQA762
VALUE
7 . 5
755 .
12 .
< 5
< 5 .
36 .
67000 .
< 1 .
19 .
< . 3
50 .
< . 3
< 10 .
< 50 .
< 1 .
< 1 .
WELL
57-86
MQA765
VALUE
7 . 2
840
9 .
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
WELL
59-86
MQA755
VALUE
7 . 2
1340
11
< 5 .
17 .
36 .
2900 .
< 1 .
77 .
1 1
166
< . 3
< 10 .
< 50 .
< 1
< 1 .
WELL
62-86
MQA863
VALUE
11.1
460
11 .
< 5
9 .
28
2200 .
< 1 .
25
3 .
53
< . 3
< 10 .
< 50
< 1
1 . 3
WET
WELL
c
VALUE
7 7
3400
8
< 5 .
50 .
21 .
5300
< 1 .
93
460 .
120 .
< . 3
< 10
< 50
< 1
< 1 .
a) NR - Not reported
b) Sample concentration is less than (<) the value shown.
c) Average of three replicate sample analyses, SMO Numbers MQA760, MQA830, and MQA831
o
no
-------
TABLE C-6
RADIONUCLIDE ANALYSIS RESULTS
ROCKY FLATS FACILITY, GOLDEN, COLORADO
SAMPLES COLLECTED. APRIL 1987
I
F\J
CO
WELL NUMBER:
SMO NUMBER:
PARAMETER
Gross Alpha
Gross Beta
Gross Radium
Radium 228
Strontium 90
Uranium 234
Uranium 235
Uran mm 238
Plutonium 239,240
Plutonium 238
Amer i c lum 241
Cesium 137
Ruthenium 106
Tritium
a) Sample activity
02-71
MQA792
ug/L
8 +3
9 +1
5 +2
< 2 <
< 2 <
1.0 +0.3
< 0.2
0.8 +0.3
< 0 . 2 <
< 0 . 2 <
< 0 . 2 <
< 5 <
< 5 <
< 200 <
is less than
Values
09-74
MQA864
ug/L
7 +4
7 +1
3 +1
2
2
8.4 +0.8
0.7 +0.2
6.6 +0.7
0. 2
0 . 2
0 . 2
5
5
200
the value
in pCi/L; statistical van
08-86 14-86
MQA764 MQA791
ug/L ug/L
< 2
9 +1
< 2 b
< 2 b
< 4 b
< 0. 2 b
< 0 2 b
< 0 . 2 b
< 0 2 b
< 0 2 b
< 0. 2 b
< 5
< 5
< 200
shown
3 +2
8 +1
2 +1
< 2
< 2
0.8 +0.2
< 0 . 2
0.3 +0.1
< 0.2
< 0 2
< 0 . 2
< 5
< 5
< 200
ation +/- indicated by +.
30-86 32-86
MQA828 MQA829
ug/L ug/L
155 +44
172 +14
15 +5
9.5
< 3
21.4 +1.6
1.1 +0 3
13 5 +1.2
< 0.3
< 0.3
< 0.4
< 5
< 5
8811 +155 b
12 +5
23+2
14 +7
< 2
< 2
1.1 +0.3
0.2 +0.1
0.8 +0.3
< 0.3
< 0.3
< 0.4
< 5
< 5
NA
34-86
MQA756
ug/L
7 +4
16 +2
3+1
< 2
< 5 b
0.8 +0.4 b
< 0 2 b
1.0 +0 4
< 0 . 2 b
< 0 . 2 b
< 0 . 2 b
< 5
< 5
< 200
43-86
MQA759
ug/L
7 +3
16 +1
9 +4
< 2
< 3
< 0.3
< 0.3
< 0.3
< 0 3
< 0.3
< 0 3
< 5 b
< 5 b
308 +25 b
b) Average of duplicate analyses.
c ) Not analyzed .
Analyzed with all parameters below limits of detection:
No results were reported for Well 27-86, (MQA 793)
Well 10-74, (MQA 790;
-------
TABLE C-6
RADIONUCLIDE ANALYSIS RESULTS
ROCKY FLATS FACILITY, GOLDEN, COLORAD
SAMPLES COLLECTED: APRIL 1987
Values in pCi/L, statistical variation + /- indicated by +
WELL NUMBER.
SMO NUMBER:
PARAMETER
Gross Alpha
Gross Beta
Gross Radium
Radium 228
Strontium 90
Uranium 234
Uranium 23 5
Uranium 238
Plutonium 239 , 240
Plutonium 238
Amer icium 241
Cesium 137
Ruthenium 106
Tritium
48-86
MQA758
ug/L
3 +1
7+1
< 2
< 2
< 2
< 0.2
< 0.2
< 0.2
< 0.2
< 0.2
< 0.2
< 5
< 5
< 200
49-86
MQA757
ug/L
43 +13 b
80 +6 b
7 +1
< 2
< 2
< 0.2
< 0 2
< 0 2
< 0 2
< 0.2
< 0 . 2
< 5
< 5
< 200
t
1
7
8
< 2
< 2
< 2
1
0
1 .
< 0 .
< 0 .
< 0
< 5
< 5
< 2C
34-86
•IQA762
ug/L
+ 3
+ 1
a
.2 +0.3
3+0.2
5 +0.3
2
2
2
)0
57-86
MQA765
ug/L
9 +3
15 +1
4 +2
< 4
< 3
6 7 +1.2
0.5 +0.3
5.1 +1.0
< 0 5
< 0.5
< 0.7
< 5 b
< 5 b
NA c
59-86
MQA755
ug/L
12+4
12 +1
< 2
< 3
< 6
11.6 +1 4
0 6 +0.3
8.5 +1.2
< 0 . 5
< 0.5
< 0.7
< 5
< 5
264 +30
62-86
MQA863
ug/L
4 +2
12 +1
< 2
< 2
< 3
3.6 +0.6
< 0.3
21+05
< 0 3
< 0.3
< 0.4
< 5
< 5
NA
WET WELL
AVE (d)
ug/L
64 +16
59+5
< 2
< 2
< 3
14.8 +1 2
3.6 +0 6
9 9 +1.0
< 0 2
< 0.2
< 0 2
< 5
< 5
1931 + 64
a) Sample acitivity is less than the value shown
b) Average of duplicate analyses.
c) Not analyzed.
d) Average of triplicate analyses: MQA 760, 830 and 831
EPA/NEIC/DENVER
o
I
ro
-------
APPENDIX D
DOE GROUND-WATER MONITORING DATA FOR 1986
-------
D-l
Printed RFP-ENV-86
April 27, 1987
ANNUAL ENVIRONMENTAL MONITORING REPORT
U. S. DEPARTMENT OF ENERGY, ROCKY FLATS PLANT
January Through December 1986
ENVIRONMENTAL MANAGEMENT SECTION
George H. Setlock, Manager
Dorothy L. Barr, Report Coordinator
ROCKWELL INTERNATIONAL
NORTH AMERICAN SPACE OPERATIONS
ROCKY FLATS PLANT
P.O. BOX 464
GOLDEN. COLORADO 80402-0464
Prepared under Contract DE-AC04-76DP03533
for the
Albuquerque Operations Office
U.S. Department of Energy
-------
D-2
Groun dwater Monitoring/ R F P- EN V-86
TABLE 16. Radioactivity Concentrations in Groundwater Monitoring Wells
Station
2-60
4-60
1-71
2-71
6-71
1-74
3-74
9 74
10-74
14-74
16-74
22-74
1-81
2-81
4-81
6-81
7-S1
8-81
9-81
lp-81
3-82
5-82
6-82
7-82
1-86
2-86
3-86
4-86
5-86
6-86
7-86
8-86
9-86
10-86
11-86
12-86
13-86
14-86
15-86
16-86
17-86
18-86
19-R6
20-86
21-86
22-86
23-86
24-86
25-86
26-86
27-86
28-86
29-86
30-86
Gros<. Alpha
( x ] 0~! uCi/mv")'
22: 51
28 : 10
6 : 3
350 : 500
36 : 29
9 - 5
13 - 7
28 : 16
Dr>
Dr\
Dry
13 : 7
22 : 16
43 : 18
Dn
13 : 6
47 - ]7
5 ± 4
4 : 5
"*> ") - "J
10 ± 7
2 ± 3
79 ± 39
Dn
Dry
Dry
1 70 - 8(i
Dn
Dn
Dr>
Dn
NA
NA
NA
NA
82 : 28
Dn
54 : 24
200 ± 80
22 : 20
160: 80
NA
170 ± 240
Dr\
NA
300 : 160
NA
Dry
NA
NA
NA
NA
Dn
NA
Gross Beta
(x 10-' yCr'mO
68 : 44
2' - 9
6 : 3
1000 : 900
2 : 2
3 : 3
10 : 5
2S : 11
12 : 4
32: 12
:~ : 11
8 : 5
24 : 6
2 - 3
4 r 3
22 r 3
17 r 6
•; . -j
110: 30
220 : 40
NA
NA
NA
NA
86 : 12
36 : 12
220 : 50
33 : 21
77 : 40
NA
470 : 130
NA
240 - 60
NA
NA
NA
NA
NA
SA
Plutonium-239 -240
(X 10-' yCi/rm)
-0 05 : 0 06
003:0 46
-001 : OQ7
32 i 3
0 04 : 0 OS
0 03 r 0 10
-016:031
-0 02 : 0 07
0 13 :0 If
005 : 0 32
015:012
002:0 09
-0 06 : 0 09
016:010
-0 03 : 0 04
003 : 0 06
-007 - 0 10
-0 03 : 0 04
005:01'
001 : 0 07
NA
NA
NA
NA
-0 05 : 0 06
-0.04 : 0 07
-0 03 : 0 04
-048 : 067
-0.21 : 0.26
NA
001 : 0 08
NA
0 95 : 0 39
NA
NA
NA
NA
NA
NA
Amencium-24 1
(x 10-* fjCi/mf)
-0 01 ±0 02
0.02 ± 0.06
04 ±0.07
44 ±2.3
005:0 05
004 ± 0.50
-001 ±009
001 ± 0.08
0.05 ± 0 06
001 ± 0 03
-0.06 : 0 08
-0 03 : 0.06
001 i 0.04
0 00 : 0.04
0 04 : 0.04
0 03 ± 0.04
000 - 0.04
005 : 0.05
0 03 : 0.07
0 02 : 0 13
' NA
NA
NA
NA
0 00 - 0.03
0.01 ± 0.03
008 ± 0.21
0 01 i 0.25
-0.03 ± 0.09
NA
0 00 ± 0 1 3
NA
0 12 ± 0.14
NA
NA
NA
NA
NA
NA
L'ramum-233. -234
(x 10'' MCi/mC)
4.4 ±06
30 ± 1
3.9 : 0 5
30 ± 5
16 ± 1
3.2 ±0.7
-0 04 ± 0 1 1
11 ±2
60 ±06
3 3 ± 04
1.3 i 0.3
59 : 0 20
2. 1 t 0 4
32 ±04
0 57 : 0 ]"
0 96 ± 0.24
0 54 ± 0.29
-0 01 : 0.04
40 ±06
70 : 0. '
NA
NA
NA
NA
8.8 : O.S
74 ±0.7
24 ±2
30 ±10
33 ± 1
NA
23 ± 2
NA
24 : 3
NA
NA
NA
NA
NA
NA
Uranium-238
(X 10"' (iCi/mf)
3.4 ±05
93 ±07
25 ±0.4
33 ± S
11 ± 1
2.7 ± 0.7
-0.03 ±008
8.2 ± 1.4
24 ±04
1.8 : 0.3
1.0 ±03
048 : 0 18
2.0 i 0.4
17 ±0.3
0 25 ± 0.11
0.59 ±0.19
0.44 ± 0.27
000± 0.01
37 i r. •
5.0 -- 0.6
NA
NA
NA
NA
7.0 ± 0.7
2,
2.1 :U«
27 ± 1
NA
22 : 2
NA
21 ± 3
NA
N
NA
NA
NA
NA
Tritium
(X 1CT» MCi;mC
670 ±02:
210 ±0.2
250 : 0 2.
-20 ±02^
1500 ± 0.3
260 i 0.23
25r ±022
1! o ±022
70 : 0 22
100 ±022
-20 ±021
-40 ±022
100 : 0 21
0 20 ± 0 22
0 : 0 22
33 : 0 23
140 ± n "'
lou .
NA
NA
NA
NA
- n * "*
-.->
,,
69u : v.' 24
NA
140 : 0 22
NA
580 : 0 23
NA
NA
NA
NA
NA
NA
J- To obtain proper concentration, multiply the numbers in the table b> 10"'
Tor example uranium-233. -234 in well 55-86 is 5 4 x 10''
b NA = Not available.
-------
D-3
RFP-ENV-86/MONITORING DATA: COLLECTION. ANAL YSES, AND EVALUA TION
TABLE 16. Radioactivity Concentrations in Groundwater Monitoring Wells (Continued)
Station
31-86
32-86
33-86
34-86
35-86
16-86
j/'-86
38-86
39-86
40-86
41-86
42-86
43-86
44-86
45-86
46-86
47-86
48-86
49-86
50-86
51-86
52-86
53-86
54-86
55-86
^6-86
57-86
58-86
59-86
61-86
62-86
63-86
64-86
65-86
66-86
67-86
68-86
69-86
-0-86
WS-1
WS-2
Gross Alpha
(X 10-* yCi/m£)
Dry-
Dry
Dry
17 ± 25
25 ± 19
Dry
Dry
Dry
44 ± 21
Dry
140 ± 40
130 ± 70
Dry
NA
200 ± 80
N'A
YAb
NA
NA
NA
N.A
NA
Dry
NA
170± 70
14 ± 11
Dry
Dry
NA
NA
NA
Dry
Dry
29 ± 12
Dry
NA
20 ± 11
200 ± 60
210 t 70
8 ± 5
Dry
Gross Beta
(X 10-* yCi/m»)
35 ± 18
34 ± 10
39 ± 13
94 ± 18
ISO ± 40
NA
140 ± 30
NA
NA
NA
N.A
NA
N.A
NA
NA
130± 30
24 ± 5
N.A
N.A
N.A
21 - 6
NA
27 ± 9
130± 30
170± 30
10 ± 3
Plutoruum-239, -240
(X 10'* MCi/m£)
-005 ± 0.07
-003 ±0.07
0 00 ± 0 09
001 ± 0.08
0 50 ± 0 16
N'A
0 13 x 0 21
N'A
NA
N.A
NA
NA
NA
NA
NA
-005 ±007
0 09 t 0 06
NA
NA
NA
002 r 0 10
NA
-0.02 t 008
-001 ± 0 08
0.07 ±0.11
008 ±0 16
Amencmm-241
(x 10'* jiCi/mt)
0 06 i 0 1 1
-0 01 ± 002
-001 ± 003
-003 ± 0 10
0.07 ± 0.16
NA
003 ± 0 07
NA
NA
NA
NA
NA
NA
NA
NA
-0 02 ± 0 04
00! ) 06
NA
NA
NA
0 01 ±003
NA
0 00 ± 0 03
0 01 ± 0 04
0.04 ± 0.14
0.02 ± 0.04
Uramum-233. -234
(.x 10"* uCtrrui
26 ±04
13 ± 1
37 ±0.4
6.6 ±0.'
98 r 1 1
NA
11 ±1
NA
N.A
NA
N.A
N.A
N.A
NA
NA
54 ±05
1 5 z 0.3
NA
NA
NA
79 ± o •
NA
24 ±04
14 ± 1
9.3 ± 1 0
0 53 ± 0 20
L'rjnium-238
i x 10"* ^Ci/mC)
27 ± 0 4
57 : 0 6
35 ±04
65 ±07
11 ±1
NA
10 ± 1
NA
NA
N.A
NA
NA
NA
NA
N'A
67 ±0.6
1 5 ±03
NA
NA
NA
65 ±0.7
NA
2.2 ± 0.4
11 ± 1
10 ± 1
030 ±0.15
Tritium
( x 1 0"* MCi/mv )
-150 ±022
\4U ± u 23
ISO ±022
130 ±022
210 ± u 23
NA
100 ±022
NA
NA
NA
N.A
NA
NA
NA
N'A
200 ± 0 22
60 ±022
NA
NA
N.A
70 ± 0 23
NA
20 ±021
20 ±021
-60 ± 0 22
-40 ± 0.24
a. To obtain proper concentration, multiply the numbers in the table by 10"' yCi/m£. For example
uraruum-233. -234 in well 55-86 is 5.4 x 10'' ^Ci/mC.
b. N'A = Not Available.
30
-------
D-4
Groundwater Monitoring/RFP-ENV-86
TABLE 1 7. Volatile Organic Concentrations in Groundwater Monitonng Wells
Station
2-60
4-60
1-71
2-7]
6-7]
1-74
3-74
9-74
10-74
14-74
16-74
22-74
1-81
2-81
4-8]
6-81
7-81
8-81
9-81
10-81
3-82
5-82
6-82
7-82
1-86
2-86
3-86
4-86
5-86
6-86
7-86
8-86
9-86
10-86
11-86
12-86
13-86
14-86
15-86
16-86
17-86
18-86
19-86
20-86
21-86
22-86
23-86
24-86
25-86
26-86
27-86
28-86
29-86
30-86
31-86
32-86
33-86
34-86
1 1 DCE
ND
ND
ND
ND
ND
-200
Dn
Dn
Dn
ND
ND
ND
Dn'
ND
ND
ND
ND
ND
ND
ND
ND
Dry
Drv
Dry
ND
Dry
Drv
Dn
Dr\
ND
ND
ND
ND
ND
Dn
ND
ND
ND
ND
Dn
ND
Dn
ND
ND
ND
Dry
ND
ND
ND
ND
Dry
ND
Dry
ND
Drv
ND
1.1 DC A
(pg/C)
ND
ND
ND
N'D
ND
ND
ND
35
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Np
ND
ND
t,l,2 DCE
ND
ND
13
79
ND
38
ND
42
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
36
ND
ND
ND
ND
N'D
ND
ND
ND
CMC 13
(pg/O
10
ND
180
79
24
ND
ND
5
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
147
ND
ND
ND
ND
ND
ND
ND
ND
1.2 DCA
ND
ND
ND
ND
ND
ND
ND
38
ND
N'D
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
MEK
Oig/O
ND
ND
ND
ND
ND
ND
ND
IT
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
N'D
ND
ND
ND
ND
ND
ND
ND
ND
ND
15
ND
ND
ND
ND
ND
ND
1,1.1 TCA
ND
ND
ND
ND
ND
ND
ND
14.000
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
CC14
ND
ND
1.600
ND
14
ND
280
--
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
350
ND
ND
ND
ND
ND
ND
ND
ND
TCE
ND
ND
350
4,500
30
7,000
2.400b
240
11,000
7
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
N'D
410
ND
ND
6
ND
ND
ND
ND
ND
1,1. 2 TCA
ND
ND
ND
ND
ND
ND
ND
91
N'D
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
N'D
ND
ND
ND
ND
ND
ND
ND
ND
ND
PCE
ND
ND
65
15
ND
1 20,000
2 5 000 '
4 >n
4.800
f
c
ND
ND
ND
ND
ND
ND
ND
ND
ND
N'D
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
a. ND = Not Detected.
b. Values determined by resampling.
c NA = Not Available.
-------
D-5
*FP-ENV-86/AfO;V/r0/MVG DA TA: COLLECTION. ANAL YSES. AND EVALUA TION
TABLE 17. Volatile Organic Concentrations in Groundwater Monitonng Wells (Continued)
iution
35-86
36-8b
37-86
38-86
39-86
40-86
41-86
4:-86
43-86
44-86
45-86
46-86
4~-S6
48-86
49-86
50-86
51-86
52-8b
53-86
54-S6
55-86
56-86
5"-86
58-86
59-86
-'-86
62-86
63-86
64-86
65-86
66-66
67-86
68-86
69-86
•>n-S6
HS-1
US- 2
1.1 DCH
UlE/C)
28
Drs
Dr\
Dr>
ND
DM
ND
ND
Dry
ND
ND
ND
ND
NAC
ND
ND
ND
NAb
Dr>
ND
ND
ND
Dn
Dry
ND
NA
ND
Dr>
Dr>
ND
D:>
ND
ND
ND
ND
ND
Dry
1.1 DC A
Uiii/u
54
ND
ND
ND
ND
ND
ND
ND
NA
ND
ND
ND
NA
ND
ND
ND
ND
NA
ND
ND
ND
ND
ND
ND
ND
t,1.2 DCE
infJSI
1.070
ND
ND
53
ND
ND
ND
ND
NA
ND
ND
ND
NA
ND
ND
ND
ND
NA
ND
ND
ND
ND
ND
ND
ND
CHC13
O^g/5)
ND
ND
ND
159
ND
ND
ND
ND
NA
ND
ND
ND
NA
ND
ND
ND
ND
NA
ND
ND
ND
ND
ND
ND
ND
1.2 OCA
Oig'O
ND
ND
ND
ND
ND
ND
ND
ND
NA
ND
ND
ND
NA
ND
ND
ND
ND
NA
ND
ND
ND
ND
ND
ND
ND
MEK
(JJE;«)
ND
ND
ND
ND
ND
ND
ND
ND
NA
ND
ND
ND
NA
ND
ND
ND
ND
NA
ND
ND
ND
ND
ND
ND
ND
1,1.1 TCA
Cug/S)
17
ND
ND
ND
ND
ND
ND
ND
NA
ND
ND
ND
NA
ND
ND
N'D
ND
NA
ND
ND
ND
ND
ND
ND
ND
CC14
(nf "-'
ND
ND
ND
1.560
ND
ND
ND
ND
NA
ND
ND
ND
NA
ND
ND
ND
ND
NA
ND
ND
ND
ND
ND
ND
ND
TCE
Us,o
ND
ND
ND
260
ND
ND
ND
ND
NA
ND
ND
ND
NA
ND
ND
ND
ND
NA
ND
ND
ND
ND
ND
ND
ND
1,1. 2 TCA
(>ig,U
ND
ND
ND
ND
ND
ND
ND
ND
NA
ND
ND
ND
NA
ND
ND
ND
ND
NA
ND
ND
ND
ND
ND
ND
ND
PCE
-------
Sijliun
-2-60
4-60
1-71
2-71
671
1-74
3-74
9-74
10-74
14-74
16-74
22-74
1-81
281
481
6-81
781
8-81
981
1081
3-B2
5-82
6 82
7-82
1-86
2 86
3-86
4-86
5-86
6 86
786
8-86
9-86
10-86
11-86
12-86
13-86
1486
1586
Al
(,uuA)
N0a
ND
Nl)
NO
NO
NO
ND
2.380
Ory
Ory
Ory
NO
NO
NO
Dry
180
NO
ND
ND
680
ND
NO
NO
Ory
Dry
Dry
ND
Dry
Ory
Ory
Dry
380
ND
36,600
8,400
ND
Dry
ND
ND
Sb
G^>
NO
Nl)
NO
NO
Nl)
NO
Nl)
NO
Nl)
NO
NO
NO
NO
Nl)
Nl)
NO
NO
ND
NO
NO
ND
ND
ND
ND
ND
ND
ND
As
°JA)
NO
NO
Nl)
NO
NO
Nl)
Nl)
Nl)
Nl)
Nl)
NO
Nl)
NO
NO
Nl)
Nl)
NO
NO
Nl)
ND
156
NO
ND
NO
NO
NO
NO
i^Vu
NO
Nl)
NO
Nl)
NO
Nl)
Nl)
NO
NO
NO
Nl)
NO
Nl)
Nl)
Nl)
Nl)
2KO
150
290
NO
NO
160
340
170
NO
ND
120
lie
NO
NO
NO
NO
10
9 7
9 7
NO
Nl)
NO
NO
Nl)
NO
80
Nl)
37
40
Nl)
40
NO
Nl)
NO
26
ND
ND
ND
NO
1AHI.I; 18 Metal Concentrations in (iioundwaici Momioi ing Wells
Cil C's Cr Co Cu le I'b Mil llu Mo Ni
IMI'A)
NO
Nl)
Nl)
Nl)
NO
NO
Nl)
NO
Nl)
Nl)
NO
Nl)
NI)
Nl)
NO
Nl)
NO
NO
NO
NO
NO
NO
NO
ND
NO
ND
Nl)
(Vf.lV)
NO
Nl)
NO
Nl)
Nl)
NO
NO
NO
Nl)
NO
ND
Nl)
Nl)
NO
NO
360
NO
NO
Nl)
NO
Nl)
NO
NO
Nl)
ND
ND
NO
(MM
NO
Nl)
Nl)
NO
Nl)
NO
NO
NO
Nl)
NO
NO
Nl)
NO
13
7 5
Nl)
16
NO
22
ND
NO
Nl
NO
NO
ND
(vylv)
52
120
170
1 10
NO
NO
NO
140
Nl)
NO
NO
220
Nl)
Nl)
NO
100
Nl)
Nl)
Nl)
ND
Nl)
NO
NO
NO
ND
NO
65
(ft/*)
NO
Nl)
NO
NO
20
NO
NO
NO
NO
Nl)
NO
Nl)
NO
30
NO
Nl)
20
NO
NO
Nl)
94
ND
24
ND
NO
NO
ND
(nnlv)
480
84
270
54,300
500
NO
NO
1,310
Nl)
ND
220
590
Nl)
Nl)
6
270
NO
Nl)
180
ND
NO
NO
28,2(1'
3,5-
Nl
Nl
C/ipA')
NO
NO
NO
88
Nl)
Nl)
16
NO
NO
NO
Nl)
Nl)
NO
Nl)
NO
Nl)
Nl)
Nl)
16
NO
16
'S
• I
.1)
NO
(MM
410
52
143
800
30
340
Nl)
84
65
NO
570
1,480
520
Nl)
0 22
NO
SO
30
140
38
Nl)
28
634
128
20
42
26
(^A)
NO
1 2
Nl)
0 24
Nl)
Nl)
Nl)
2 3
Nl)
Nl)
NI)
0 K8
Nl)
NO
Nl)
0 7
NO
1 2
NO
0.24
133
NO
(.
N!
Nl.
Nl)
Nl)
<^A)
NO
Nl)
Nl)
192
100
Nl)
Nl)
NO
190
Nl)
NO
NO
Nl)
NO
Nl)
510
NO
NO
NO
NO
NO
Nl)
n
(W-/V)
NO
NO
NO
NO
NO
Nl)
NO
Nl)
Nl)
Nl)
ND
NO
Nl)
Nl)
NO
77
NO
NO
60
NO
10
NO
ND
NO
NO
NO
NO
Sc
(^M
Nl)
19
15
18
Nl)
NO
Nl)
21
17
Nl)
NO
15
3 4
8 1
Nl)
Nl)
1 7
Nl)
Nl)
15
NO
NO
19
ND
NO
NO
NO
(MM
Nl)
14
20
20
Nl)
NO
Nl)
31
14
Nl)
NO
20
NO
Nl)
NI)
Nl)
Nl)
180
NO
Nl)
NO
NO
238
NO
Nl)
NO
ND
Sr
wA>
12,900
1,250
580
570
3,750
H10
160
1 960
I.I 10
Nl)
1.080
350
235
250
350
68
1 10
14
NO
1,580
1,31(1
175
NO
590
828
1,370
1,700
II
. NA = .
Not Avail.
ible.
^.
O
c:
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5-
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X
O
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S
3)
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m
CO
-------
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(IN
i
CIN
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& (1N
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£
CIN
(IN
ON
VN
(IN
ON
ON
VN
it-
ON
ON
(IN
ON
ON
CIN
CIN
CIN
(IN
CIN
VN
VN
CIN
ON
VN
ON
ON
CIN
VN
(IN
CIN
ON
ON 1
ON '
VN
ON
(IN
VN
ON
ON
ON
ON
ON
ON
(IN
f»f
ON
t-K
VN
VN
CIN
VN
ON
CIN
01"
VN
071
ON
ON
fS'l
971
VN
ON
so:
VN
ON
(IN
061
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ON
ON
VN
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il 1
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(IN
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ON
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01
01
VN
VN
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6
VN
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(IN
VN
(IN
(IN
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ON
ON
VN
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ON
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(IN
01
VN
VN
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(IN
VN
9 i
(IN
ON
VN
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S t-
ON
ON
ON
VN
67
ON
ON
VN
ON
6
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(IN
(IN
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(IN
(IN
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(IN
VN
VN
(IN
S96
VN
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ON
ON
VN
(IN
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(IN
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VN
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(IN
(IN
VN
ON
ON
(IN
ON
ON
(IN
(IN
(IN
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ON
ON
VN
VN
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ne
VN
(IN
ON
ON
VN
ON
ON
ON
(IN
ON
VN
ON
ON
ON
VN
ON
(IN
17 0
ON
ON
ON
(IN
ON
ON
ON
1 1
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VN
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119
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VN
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t-S
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VN
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t 1
ON
ON
ON
ON
(IN
ON
ON
71
ON
VN
VN
ON
ON
VN
ON
ON
(IN
VN
(IN
ON
i * M
ON
AS
II 1
VN
ON
181
ON
VN
ON
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7Sc
Ot-8'7
CIN
CIN
CIN
ON
CIN
CIN
8ifr
VN
VN
ON
CIN
VN
ON
CIN
ON
VN
ON
ON
ON
ON
ON
VN
ON
ON
VN
(IN
711
ON
ON
ON
ON
ON
ON
(IN
CIN
(IN
VN
VN
ON
ON
VN
(IN
ON
ON
VN
ON
ON
, . , , . .
(IN
(IN
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VN
(IN
ON
ON
VN
(IN
ON
ON
ON
CIN
CIN
ON
ON
CIN
CIN
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VN
VN
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67
VN
CIN
ON
ON
VN
(IN
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t t\Mrl\
ON
ON
SI
VN
ON
ON
VN
ON
ON
ON
ON
ON
ON
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CIN
CIN
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VN
VN
ON
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VN
CIN
ON
(IN
VN
CIN
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IxMrfl
(IN
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ON
VN
ON
(IN
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VN
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(IN
(IN
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(IN
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VN
VN
ON
ON
VN
ON
ON
CIN
VN
(IN
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i f.i/Srf
ON
ON
ON
VN
9
ON
ON
VN
i
ON
ON
CIN
ON
ON
ON
CIN
ON
ON
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VN
VN
CIN
CIN
VN
ON
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CIN
VN
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1 1
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VN
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ON
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VN
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1 1
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CIN
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VN
VN
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VN
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VN
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VN
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001
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VN
VN
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VN
(IN
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Oil
VN
091
ON
(IN
ON
ON
VN
(IN
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ON
VN
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(IN
(IN
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ON
ON
CIN
ON
CIN
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(IN
VN
VN
ON
ON
VN
CIN
CIN
ON
VN
ON
ON
ON
HS
(IN
VN
ON
(IN
(IN
VN
(IN
ON
ON
ON
ON
ON
(IN
ON
ON
ON
ON
VN
VN
ON
ON
VN
79
ON
ON
VN
ON
ON
ON
Ofi
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VN
ON
061
(IN
VN
(IN
OS!
OHt-
(IN
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(IN
ON
(IN
Oil
VN
VN
ON
019
-0(1
VN
(IN
(IN
0(1
(IN
,|VN
ON
ON
9H-9S
98 S'S
98-t-S
98 -IS
98 7 S
98-1 S"
98 dfr
98-81-
98 it-
98-9C
98 S>
98 ff
98-1 I-
98 7 1-
98-11-
98 -Ofr
98-6f
98-81
98-if
98 9t
98 St
98 -H
98 tt
98 7f
98 It
98 -Ot
98 67
98 8c
98-i7
98 97
98 S" 7
98-fc
98-17
98-77
98 17
98-07
98-61
98 81
98-il
98-91
uoni'K
01
QL
07
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PJ
•Ml
MS
IV
-------
o
CO
Lli 18. Metal Concentialions in Groundwater Monitoring Wells (Continued)
(•„ lc I'l, Mn II,' Mo N, Sc A, S, II V /'•
Al Sb As H.i lie
Al Sn A*. It 1 liC v VI v r> v ' ,
Stanon (f*,V) (ftIV) (ftlV) (filV> (ft,V) G^> (ftIV) ^V) (_f,M ^) ^m 0^> (_ft.K) (f^ (ftlV)
59 86
61 86
62-86
63-86
64-86
65-86
66-86
67-86
68-86
6986
70-86
WS-I
WS-2
230
NA
4,750
Dry
Dry
ND
Dry
ND
ND
110
ND
Nl)
Dry
185
NA
58
78
ND
95
208
ND
ND
Nl)
NA
ND
ND
Nl)
ND
ND
ND
ND
100
NA
130
ND
243
100
160
ND
ND
29
NA
9
10
ND
6
6
7
30
ND
NA
ND
ND
ND
ND
ND
ND
ND
Nl)
NA
ND
ND
ND
ND
Nl)
ND
ND
ND
NA
19
ND
Nl)
ND
Nl)
ND
Nl)
ND
NA
ND
ND
Nl)
ND
Nl)
ND
ND
ND
NA
ND
ND
ND
Nl)
ND
Nl)
Nl)
ND
NA
2,900
103
ND
76
Nl)
Nl)
Nl)
24
NA
Nl)
ND
ND
ND
37
ND
ND
107
NA
52
127
161
1,050
5K
72
70
1 2
NA
0 2K
1 9
Nl)
ND
ND
0 50
ND
ND
NA
ND
ND
ND
Nl)
Nl)
ND
ion
ND
NA
Nl)
ND
Nl)
ND
ND
Nl)
ND
ND
NA
ND
K 9
ND
ND
ND
ND
ND
Nl)
NA
Nl)
Nl)
16
Nl)
Nl)
Nl)
Nl)
1. 1 10
NA
305
6 10
719
1 17
1.190
656
120
Nl)
NA
Nl)
ND
Nl)
Nl)
16
Nl)
Nl>
Nl)
NA
ND
Nl)
ND
Nl)
ND
Nl)
ND
12
NA
21
28
30
ND
5
ND
78
3
c
c
0
OI
-n
T>
m
-------
D-9
RFP-ENV-86M/0.V/r
1 420
210
84.000
Dry
84.000
56.000
73.300
28.200
18.000
22.000
36.200
8.700
Dry
Dry
Dry
88.000
Dry-
Dry
Dry
Dry
91.500
21.100
22.100
77.400
170.000
Dr>
95. 1 00
324.000
142.000
193.000
Dry
148.000
Dry
44 200
5 7.0GO
Dry
224 000
97000
NA
N'A
Dr>
193000
Do
31.100
M jiznesium
(yc/O
270.000
49 000
15.000
12.500
6.000
32 000
14 000
51.000
22.500
ND
41 000
12.500
42.000
5.780
1.480
6.600
3.680
4,130
1.200
32.000
ND
5.250
7.880
24.500
264.000
29.200
61,500
45,500
142.000
45.400
9.960
9.180
80,500
106.000
NA
NA
165.000
7.660
Potassium
GJC/V)
72.400
3.300
1.660
2 200
6.000
3.800
920
2.100
4.100
90
4.250
1 "30
980
ND
5,880
560
ND
1 5 500
ND
2,630
41.100
3.620
12900
6 840
1.920
7920
2.600
6.260
8.800
5.500
8 030
4 04(1
35.000
3 300
NA
NA
38 600
8 350
Sodium
<»^/«
540.000
127.000
11.200
135.000
24 000
106.000
1 5 500
1 16.000
22.400
76
1 1 7 000
4.500
12.000
13,800
15.900
11 000
13.800
23.300
5.100
26.600
177.000
60.700
12.200
112.000
167.000
267 000
88.000
297.000
322.000
232 000
3'. 600
99 700
33 800
338 000
NA
NA
1.440 000
118.000
Bicarbonate
(mg,C)
17
26
37
108
50
62
IS
18
ND
75
108
30
26
4 9
NA
19
10
5b
15
13
ND
220
16
NA
33
13
35
•>-)
53
NA
4 4
:j
NA
41
NA
NA
46
ND
Carbonate
(mg/C)
80
350
240
35
270
250
290
301
250
330
430
210
210
130
NA
21
19
ND
22
330
442
ND
66
NA
420
180
410
450
320
NA
259
340
NA
730
NA
NA
240
199
Chloride
(mg/C)
730
40
17
320
95
23
40
400
57
37
29
10
3 1
8.6
NA
5 7
IS
55
3 3
58
NA
li
4 3
NA
47
160
63
220
140
NA
5 2
37
N'A
77
NA
N'A
430
122
Cyanide
(mg/C)
0014
ND
ND
0 016
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.005
NA
00016
ND
ND
ND
ND
NA
ND
ND
NA
ND
ND
0040
ND
ND
NA
ND
ND
NA
NR^'
NA
NA
ND
ND
Phosphate
tmg/C)
1.4
0.52
1 6
ND
1 3
1 8
1 6
3 7
1 9
2 0
2 3
4 4
1 4
ND
NA
1 3
1.8
0 92
1 5
26
40
1 8
4 4
NA
29
1 5
1 1
ND
2.1
NA
4 7
3
NA
ND
NA
NA
1 3
9 5
Sulfate
(mg/C)
400
91
2">
97
100
37
30
320
22
250
200
ND
9
17
NA
ND
28
77
20
66
NA
15
17
NA
240
310
170
510
330
N'A
56
75
NA
500
NA
NA
100
101
Nitrate
( mg/C)
5060
22 0
199
<5 0
2120
44 8
25.2
91.2
236
<5 0
<5 0
- -»
<5 0
<50
<5 0
<50
74 7
324
<50
5.7
41 0
<50
<50
NA
96
<5 0
243
<5.0
2320
<5 0
<5 0
226
NA
300
NA
NA
9640
602
a. ND = Not Detected
b N A = Not Available
c NR = Not Requested
-------
D-10
Groundwater Monitoring!RFP-ENV-86
TABLE 19 Other Inorganic Concentrations in Groundwater Monitoring Wells (Continued)
StJtion
33-86
34-86
35-86
36-86
3"-S6
38-86
39-86
40-86
41-86
42-86
43-86
44-86
45-86
46-86
4~-86
48-86
49-86
50-86
51-86
52-86
53-86
54-86
55-86
56-86
57-86
58-86
59-86
61-86
62-86
63-86
64-86
65-86
66-86
67-86
68-86
69-86
70-86
WS-1
WS-2
CaLium
Do
388 000
1 70 000
Dry
Do
Dry
1 1 0 000
Dr\
96 900
122.000
Dry
54.500
26,200
13.900
15 400
NA
35.200
30.000
12.300
NA"
Dry
43.300
22.800
26.300
Dry
Do-
ll 2.000
NA
26,200
Dry
Dry
93.100
Dry
49,800
28.500
144 000
42.900
26,000
Dry
Magnesium
30.000
68 000
9570
15,600
11.900
6.470
5.900
1.190
2.230
NA
7.640
5.430
1.920
NA
10.400
4 280
6.210
36,100
NA
3,620
24.200
23.200
7,380
40.400
8680
8.880
Potassium
7.800
2.310
1.780
3,720
1.730
3,600
623
^,200
NDa
NA
ND
1.490
1,070
NA
6.030
4 700
1.600
41,300
NA
44.500
1.840
ND
1.700
54,800
13.700
ND
Sodium Bicarbonate
170 000
182,000
17 300
51,300
13 400
22.000
13.400
31.400
164,000
NA
29 500
12.100
21.400
NA
36.800
8,770
17,800
156,000
NA
62,200
98,300
63,400
56.300
163.000
41,800
8,000
14
61
6
15
27
NR
12
NA
5 4
NA
• o
130
ND
NA
8 8
17
16
30
NA
ND
25
97
31
38
ND
61
Carbonate
400
~20
270
360
350
NR
110
NA
88
NA
45
ND
42
NA
257
76
120
510
NA
200
370
345
210
410
340
38
Chloride
(mi:, i)
47
110
36
34
50
12
6 1
NA
29
NA
30
7 6
7 i
NA
15
7 4
15
92
NA
26
70
35
16
130
13
4.3
Cyanide
img, O
ND
ND
ND
ND
ND
NR
ND
NA
ND
NA
ND
ND
ND
NA
ND
ND
ND
NR
NA
ND
ND
ND
ND
ND
ND
ND
Phosphate
i m si, i )
22
2.6
2.2
12
2 6
NR
4 7
NA
8 7
NA
4 4
20
4.7
NA
4.7
3 3
ND
1.2
NA
2.8
0.9
ND
4.7
2.2
1.2
1.8
Sulfate
(mg/v)
1.000
200
74
100
:.
NR
14
NA
20
NA
29
16
31
\ •
22
15
190
NA
58
220
65
37
320
-;
39
Nitrate
i ma, v)
<5 0
<5.0
<5 0
<5 0
30 2
24 8
<5 0
NA
<5 0
NA
14 S
" " :
<50
<5 0
<5 0
NA
<50
<5 0
<50
55
<5 0
<5 0
23
ND = Not Detected.
NA = Not Available.
NR = Not Requested.
37
-------
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