-------
23
Volatile organic samples collected for analysis by the EPA contract
laboratory were first poured into a 250-mฃ beaker then poured into 50-mฃ
vials (sample containers). At wells equipped with Geomon pumps, all other
sample containers were filled directly from the discharge line. At B-84A
(the well with the -airlift sampler), the sample was initially collected in
a clean 2Js-gallon jug, then split into the respective aliquot containers.
After sampling was completed at a well, EPA contractor personnel took
their samples to a staging area where a turbidity measurement was taken and
one of the two sample aliquots for metals analysis was filtered. In addi-
tion, metals, TOC, phenols, cyanide, nitrate and ammonia samples were pre-
served [Table 3].
Leachate was collected at SLFs 4 through 7 and SLF 10. All leachate sam-
ples were collected on the same day to prevent possible cross-contamination
of well samples through handling and shipping. All personnel involved in
the sampling wore full-face respirators and protective clothing. Plastic
sheeting was laid-around each sampling point in order to prevent area
contamination in the event of spillage. After SCA collected their leachata
sample, the EPA contractor collected the sample for EPA in a 2%-gallon
glass jug. After the leachate sumps were sampled, the 2%-gallon jugs were
taken to an onsite area where the individual sample containers were filled.
Leachate samples were not preserved.
Some of the jugs of leachate sample contained multiple liquid phases.
The EPA contractor could not keep the contents of the jugs mixed while fil-
ling the sample containers and the amount of aqueous and non-aqueous phases
in the containers varied widely. Consequently, chemical concentrations
reported for these samples may not reflect those in the sumps.
At the end of the day, samples were packaged and shipped to the two
EPA contract laboratories or NEIC in accordance with applicable Department
of Transportation (DOT) regulations (40 CFR Parts 171-177). Aqueous
samples from monitoring wells were considered "environmental" and those
from leachate collection system sumps were considered "hazardous" for
shipping purposes.
-------
Each day of sampling, the EPA contractor prepared field blanks for
each analytical parameter group (e.g., volatiles, organics, metals) in a
parking lot on the north side of the east salts area by pouring distilled
deionized water into sample containers. An equipment blank was prepared by
running distilled deionized water through the apparatus used to filter
metals. One set of trip blanks for each parameter group was also prepared
and submitted during the inspection. The blanks were submitted with no
distinguishing labeling or markings.
Samples were analyzed by the EPA contractor laboratories for the param-
eter groups shown on Table 3 minus the groups indicated on Tables 1 and 2.
NEIC received and analyzed replicate samples for two ground-water monitor-
ing wells (2-4 and 8-113).
-------
25
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26
WASTE MANAGEMENT UNITS AND FACILITY OPERATIONS
WASTE MANAGEMENT UNITS
To identify possible sources and pathways for waste constituents
handled at SCA to enter the ground water, waste handling units and opera-
tions were identified. The SCA facility handles both hazardous waste, as
defined in 40 CFR 261 and regulated under RCRA and DEC regulations, and
polychlorinated biphenyl (PCS) waste, as regulated by DEC regulations and
40 CFR Part 761 regulations promulgated under TSCA.
SCA currently uses the following management units/areas for tne treat-
ment, storage and/or disposal of hazardous waste:
Surface impoundments - storage and treatment
Landfills - disposal
Tanks - storage and treatment
Drum storage areas - container storage
Various impoundments, landfills and tank and drum storage areas used
in the past are currently inactive. Past operations also included distilla-
tion for solvent recovery and thermal destruction (incineration).
PCB waste processing and disposal operations include storage, process-
ing (transformer draining and flushing) for disposal, and landfill disposal.
Some stored PCB waste and leachate containing high PCB concentrations are
disposed of offsite.
Figure 4 shows the location of SCA treatment, storage and disposal
facilities. A discussion of waste management units related to interim
status ground-water monitoring at the SCA site follows and is divided into
two major areas: (1) units subject to RCRA interim status requirements
(active after November 1980) and (2) units or areas operated and/or closed
prior to the effective date of RCRA interim status regulations but which
may have released contaminants to the ground water.
-------
27
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Interim Status Regulated Waste Management Units
Surface Impoundments
Surface impoundments, described 1n Table 4, are used at SCA for
hazardous waste treatment, storage and disposal. SCA reported in a March 4,
1985 modification to its RCRA Part A permit application that it has a total
surface impoundment storage capacity of about 163 million gallons; surface
impoundment treatment capacity is reported as 68,500 gallons per day.
Lagoons 1, 2, 5 and 6, Tank 58, the "Salts" storage areas and the faculta-
tive ponds are all surface impoundments subject to the ground-water monitor-
ing requirements of RCRA interim status.
Lagoons 1, 2 and 5
Lagoons 1, 2 and 5 are surface impoundments used to receive and store
aqueous waste prior to treatment in the aqueous wastewater treatment system.
Reduction and oxidation reactions are also conducted in these lagoons on a
batch treatment basis. Lagoon 2 has not received waste'since 1984 because
it was taken out of normal service to store PCB-contaminated sludge removed
from Lagoons 1 and 5. In addition to receiving waste generated offsite,
Lagoon 5 also receives pretreated (oil/water separation) leachate pumped
from the landfills. The general types of waste received in these surface
impoundments since 1980, as reported in DEC weekly reports, are given in
Table 5.
Lagoons 1 and 2 were constructed by excavating about 6 feet below grade
and building berms 10 feet above the original ground surface. Lagoon 5 was
constructed by excavating about 4 feet below the original surface and adding
berms about 6 feet above the original grade. The sides and bottoms of all
three lagoons were originally lined with synthetic liners, reportedly covered
with about 2 feet of compacted clay. A compa ison between the finished
base elevation of these units and the waste liquid and ground-wate. table
surface elevation is shown in Table 6.*
Detailed discussion of the relationship between depth of the waste
management units and the surface of the ground-water taJble is provided
in the May 1935 report, "Groundvater Monitoring Plan, Chemical Waste
Management, Inc., Model City, New York", Colder Associates.
-------
29
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31
Table 5
AQUEOUS WASTE RECEIVED
IN LAGOONS 1, 2 AND 5
Acids
Alkaline paint stripper
Alkaline rinses
Aqueous low TOC
Aqueous polymers
Bases
Combustible 1iquid
Ethylene glycol/water
Ferric chloride solution
Grinding coolant
Hardeners
MCL waste
Phosphoric acid
Tumbler water
Thiosulfate solutions
Non-chlorinated solvents
Waste hexane
Pretreated landfill leachate
Table 6
BASE ELEVATION AND WASTE LIQUID AND
GROUND-WATER TABLE SURFACE ELEVATIONS
LAGOONS 1, 2 AND 5
Lagoon
Number
1
2
5
Estimated Finished
Base Elevation
(feet amsl )*
315
315
316
Reported Liquid
Waste Operating
Elevation (feet amsl)
326
326
323
Estimated Surface
of Ground-water
Table (feet
313
313
315
amsl )
* AJsove aiean sea. level
SCA records indicate that the liners in Lagoons 1 and 2 were replaced
in 1977 and 1982, respectively; the liner in Lagoon 1 was replaced with 40
mil high density polyethylene in 1984. There are no other records of liner
replacement for the units.
Lagoons 1 and 2 originally had leachate detection systems installed
beneath the liners. These consisted of 4-inch perforated pipes which were
packed in coarse sand and drained to individual sumps. SCA facility
-------
32
personnel stated that the detection system under Lagoon 1 no longer exists.
Although the Company indicated belief that this detection system had been
monitored in the past, they could provide no information on monitoring
results.
Lagoon 6
Lagoon 6 is a surface impoundment normally used for flow equalization
of waste feed to the carbon treatment unit of the waste water treatment
system. It also receives supernatant from the "salts" areas (discussed
later). Construction of Lagoon 6 involved excavating about 2 feet below
the ground surface and constructing 10-foot surrounding berms. The sides
and bottom were lined with a Hypalon synthetic 'liner under 2 feet of clay.
Final base elevation of Lagoon 6 is about 315 feet amsl. The ground-water
table surface elevation in this area reportedly averages 315 feet amsl while
the elevati9n of the liquid waste in the lagoon is maintained at about 324
feet amsl.
State inspection records indicate that liner integrity of this impound-
ment was compromised in May 1980. The liner was reportedly repaired by SCA
shortly after the problems were found.
Tank 53
Tank 58 is a 100-foot-diameter circular surface impoundment receiving
effluent from the carbon treatment unit of the wastewater treatment system.
Waste in the unit is aerated with subsurface diffusers. SCA claims to get
high rates of total organic carbon reduction with this biological treatment
unit and reported that a waiver from RCRA ground-water monitoring require-
ments is in preparation for Tank 58. The impoundment is rot seeded with
bioactive material and only operates during the warmer months of the year
when it discharges to Facultative Pond 2 (west pond), the first in a series
of aerated surface impoundments. In cold weather (approximately 4 months
per year), the wastewater bypasses Tank 58 and is discharged directly to
Facultative Pond 2.
-------
33
Tank 58 was constructed by excavating 1 or 2 feet of soil, replacing
it with a sand base and constructing a 100-foot diameter, 8-foot vertical
steel retaining wall. A Hypalon liner was laid down over the sand and
secured to the top of the steel walls. Concrete blocks hold the air diffu-
sers near the bottom of the impoundment. The synthetic liner was replaced
in 1984.
Salts Areas
The salts areas at SCA (East/West Salts, North Salts and Salts
Area 7) are surface impoundments used for dewatering metal hydroxide precip-
itates generated from pH adjustment during onsite aqueous waste treatment.
Decant liquid from these areas is pumped back into the treatment system
through Lagoon 6. The dewatered sludge was used as cover in the landfills.*
All of the salts areas are bermed excavations with compacted clay liners.
There is no liquid collection system at the bottom of any of these units.
Only limited construction information is available for these units and there
are no as-built diagrams.
The relationship between the finished base elevation of the salts areas
units and the average leachate and area ground-water table surface eleva-
tions is shown in Table 7. As shown in the table, all base elevations are
below the water table. Average leachate levels are above the water table
elevations, thereby creating an outward hydraulic gradient across the liner.
Table 7
BASE ELEVATION AND AVERAGE LEACHATE AND GROUND-WATER
TABLE SURFACE ELEVATIONS,. SALTS AREAS
Estimated Finished Reported Average
Base Elevation Leachate Elevation
Salts Area (feet amsl) (feet amsl)*
East/West
North
7
* When
318 328
311 317
311 324
the units were opera tad
Estimated Surface
of Ground-water
Table (feet amsl)
319
316
318
Sludge in the salts areas was found to be contaminated with PCBs and
landfilling of it was halted.
-------
34
The East/West Salts area is basically a single unit, covering about 10
acres. Limited information indicates that the unit's base is 3 to 5 feet
below the original ground surface. The containment bertns rise 13 feet
above the original surface. DEC weekly reports indicate that the East/West
Salts area was used to receive cadmium waste as well as for storage and
dewatering of the waste treatment salts.
The North Salts area is a 2-acre impoundment with 3-foot berms con-
structed above the original ground surface and a base about 9 feet below
the original grade. This area was deactivated in 1984 and the salt sludge
has since been removed; however, the area is not closed, as defined under
RCRA.
Salts Area 7, also referred to as the Emergency Lagoon 7, is about I
acre in area and was constructed by excavating approximately 8 feet below
grade and lining the unit with 2 feet of clay. A 9-foot containment berra
was constructed around this excavation. In addition to receiving sludges
from the aqueous wa^te treatment system, DEC reports indicate that the. unit
ซ
was used to receive additional waste and sludge, as shown in Table 8. This
area was deactivated in 1984 but has not been closed, as defined under RCRA
regulations.
Table 8
WASTE RECEIVED
IN SALTS AREA 7
(Emergency Lagoon 7)
Chromium
Oust with organics
Epoxy organics
Epoxy resins
Industrial sludges
Metal hydroxide sludges
Facultative Ponds
The facultative ponds (1, 2, Fire Pond, 3, 8, and 9) are surface
impoundments used for biological treatment and storage of wastewater dis-
charged from the aqueous waste treatment system. The ponds are normally
-------
35
operated in series with final discharge to the Niagara River through a
pipeline from facultative pond 3, 8 or 9. Mechanical aerators are used
during warm weather to maintain aerobic conditions in the top layers of
these impoundments. During the Task Force investigation, SCA reported that
requests for waivers from the ground-water monitoring requirements for these
units, as allowed by the 1984 RCRA amendments, were being prepared.
A comparison between the finished base elevation of these units and
the reported wastewater and area ground-water table surface elevations is
given in Table 9. As shown in the table, all base elevations are below the
water table. Operating liquid levels are at or above water table eleva-
tions, thereby creating an outward hydraulic gradient across apparently
marginal quality liners, as discussed below.
Table 9
BASE ELEVATIONS AND WASTE LIQUID AND GROUND WATER
TABLE ELEVATIONS, FACULTATIVE PONDS
Facultative
Pond
Designation
1
2
Fire Pond
3
8
9
Estimated
Finished
Base
Elevation
(feet amsl)
304
304
317
304
309
312 to 316
Reported Liquid
Waste Operating
Elevation
(feet arasl)
318
318
327
319
330
328
Estimated Surface
of Ground-Water
Table (feet amsl )
318
318
319
318
318
318
Facultative Ponds 1 and 2 are adjacent units, separated by a low berm
which is inundated at times by pond contents. Pond 2 normally receives
effluent from Tank 58 in the wanner summer months and discharges to Pond 1.
During cold weather, Tank 58 is not used and wastewater is pumped to Pond 2
directly from the carbon treatment column. Wastewater from Pond 1 is pumped
to the Fire Pond for additional biological treatment. Facultative Ponds 1
and 2 were constructed by excavating about 15 feet below grade and building
an approximately 5-foot berm surrounding the excavations. Both units are
reportedly lined with native clay compacted to unspecified permeability.
-------
36
The Fire Pond is a surface impoundment which receives waste from
Facultative Pond 1 and is used for additional biological treatment and
wastewater storage. The impoundment base is about 3 feet.below the original
ground surface with berms rising about 9 feet above the original grade.
The unit is reportedly clay lined and discharges to one of the discharge
facultative ponds (3, 8 or 9).
The discharge facultative ponds, which normally receive wastewater
from the Fire Pond, are used for storage of wastewater prior to discharge.
Some biological activity occurs during storage. During ice-free periods,
the surfaces of the impoundments are aerated with floating aerators.
Facultative Pond 3, a below-grade impoundment, was constructed by exca-
vating about 16 feet below the original ground surface. The unit has com-
pacted clay bottom and sides. Facultative Pond 8 was constructed by exca-
vating 10 feet -below the original grade. A 14-foot dike (built in two
phases) was then constructed above the original ground surface. According
to engineering reports, the bottom and-sides of the excavation consist, of
natural uncompacted clay except for the berms which were reportedly com-
.7
pacted to a permeability of less than 10 cm/sec. Facultative Pond 9 was
constructed by excavating about 5 feet below grade and building a 12-foot
berm above grade. The bottom and sides of the excavation are made up of
natural, uncompacted clay except for the berms which were reportedly <:om-
_7
pacted to a permeability of less than 10 cm/sec.
Landfills
Landfills, referred to as secure landfills or SLFs by SCA and described
in Table 10, are used at SCA for burial of hazardous and PCS waste. SCA
'reported, in a March 4, Ia85 modification to its RCRA Part A application,
that it has 1,600 acre-feet of landfill capacity at the facility. Because
hazardous waste, as defined by RCRA, was disposed of in all SCA landfills
following RCRA enactment, they are subject to the ground-water monitoring
requirements of interim status. Only one landfill area is currently active
at the facility (lla). The other eight are either closed (SLF 1 through
SLF 7) or in the process of being closed (SLF 10). Specific information on
each SLF unit follows.
-------
37
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38
Landfills 1 Through 6
SLF 1 through SLF 6 are currently closed and were originally used as
waste disposal areas between November 1971 and September 1978. Additional
hazardous waste was added in 1982 and 1983 as part of a recapping procedure.
These six adjacent landfill units cover a combined area of about 16 acres
in the southwest portion of the SCA facility. The individual landfills are
separated by common internal berms. Subcells within each landfill, usซd
for waste segregation, are also separated by internal berms.
Available construction information is limited but indicates that the
top of the exterior landfill berms average about IS feet above the original
ground surface. The base of these units ranges between 5 feet (SLF 1) and
17 feet (SLF 2) below the original surface. The bottom and sides of the
units are reportedly lined with 2 feet of compacted clay over some type of
synthetic membrane liner. The soil under the liner is reportedly proof-
rolled native clay. A comparison between base elevations of SLF 1 through
SLF 6 and the surrounding ground-water table is shown in Table 11. As noted
in the table, all bases are below the water table.
Table 11
BASE AND GROUND WATER TABLE
SURFACE ELEVATIONS, SLF 1 THROUGH SLF 6
Landf i 1 1
Designation
1
2
3
4
5
6
Estimated Finished
Base Elevation (feet amsl)
316
303
308
310
310
311
Estimated Surface of
Ground-water Table (feet amsl)
319
319
319-
319
319
319
SLF 1 through SLF 6 were constructed without any leachate collection
or removal systems. Leachate collection drain layers or sloped floors were
also not constructed, although some leachate "observation wells" were built.
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39
In 1981, well after the units were originally deactivated, leachate
removal standpipes were constructed by drilling through the landfills to
within 3 to 5 feet of the original base liners. At least one standpipe was
built in each of the landfill subcells. The leachate detection/removal
system currently consists of 23 vertical standpipes, 17 of which are actively
used to pump leachate out of the units and six of which are used only for
monitoring leachate levels. Leachate from the landfill units is pumped to
an oil/water separator and then to a 20,000-gallon underground holding tank
prior to discharge to Lagoon 5 for treatment in the aqueous waste treatment
system. Light and heavy materials from the oil/water separator are shipped
offsite for incineration.
Each of the six landfills has a separate cap, except for SLF 1 and
SLF 2, which share a single cap. The landfill units were originally capped
with 2 feet of compacted clay. In 1982-1983, additional material, consist-
ing of aqueous waste neutralization salts sludge (metal containing hazard-
ous waste, generated onsite), municipal wastewater treatment plant sludge
and clay, was added to increase the surface slopes of these units. Some of
the original clay cap was removed prior to this addition. A polyvinyl-
chloride (PVC) synthetic membrane, overlain with clay and topsoil, was
placed on this new material to form the final caps. The slope of the final
caps is reported to be about 8%. Surface runoff is collected in swales
between the individual landfill caps and directed to the sides of the land-
fill for surface discharge.
Landfill 7
SLF 7, located in the north central portion of the facility, was used
to dispose of waste from about September 1978 to January 1983. General
waste types received- in SLF 7 from 1980 to January 1983, as reported in DEC
weekly reports, are listed in Table 12.
The original unit was constructed in 1978 by excavating about 25 feet
below the ground surface. Later, in 1981, the unit was expanded vertically
by constructing an exterior containment berm about 8*3 feet above the original
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40
gradซ. Seven individual subcells, separated by internal berms, were
constructed within SLF 7 for waste segregation. The bottom and sides of
SLF 7 are underlain with 2 feet of rolled clay (maximum permeability of
_7
10 cm/sec) overlain with a 30-mil Hypalon liner above which is another 2
.7
feet of compacted clay (maximum permeability of 10 cm/sec). The finished
base elevation of SLF 7 is about 296 feet amsl. The surface of the ground-
water table in the area near SLF 7 is at about 310 feet amsl, 14 feet above
the finished base of the landfill.
Table 12
WASTE RECEIVED IN SLF 7
Acid sludges
Acid solutions
Arsenic waste
Baghouse dust
Barium compounds (I)1*
Benzoic acid
Carbon tetrachloride
Calcium fluoride cake
Caustic solids (I)
Chlorinated solvents
p-Chlorobenzotri f 1 uori de
still bottoms
Coal tar sludge (I)
Corrosive liquid
Cyanide solids
Epoxy 314
Filter cake with organics
Flu dust (I)
Formaldehyde (I)
Halogenated organics
Incinerator ash
Industrial sludge (IV)
Lab chemicals
Mercury sludges
Metal hydroxide sludge (I)
Methylene dianiline
Naphtlralene
Organic polymers
Organic tars
OPC still bottoms
Paint waste
PCB wastes
Phenolic still bottoms
Phenolic resins
Phthalic anhydride
PLC
Plating sludge
Polymer tars
Pyridine tars
Ronnex reactor sludge.(Ill)
Selenium (III)
Sodium chlorate
Sodium oxalate ,
Soil with organics
Spent carbon (IV)
Titanium dioxide
TMAC still bottoms
TPC still bottoms
Trichlorobenzene sulfonate
Vanadium and SK sludge
Waste oil
Waste solvents
WWTP sludge (IV)
Waste solvents
Xylene
Zinc hydroxide sludge
* Numerals in parsnthesas identify disposal subcell.
i
SLF 7 was not constructed with a leachate collection drainage layer;
however, the bottom 1s reportedly sloped (minimum slope of 1%) toward indi-
vidual leachate collection standpipes placed in the subcells. Four of the
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41
seven subcells* (1, 2, 2A, 3 and 4) have individual riser pipes connected
to a common manifold for leachate removal, Subcells 5 and 5A share a
common ri.ser and subcell 4, the halogenated "toxic" subcell, has its own
riser. Leachate is reportedly pumped from all subcelTs, except for subcell
4, by float-activated, submersible pumps, to an underground oil/water
separator, adjacent to SLF 7, for pretreatment prior to final treatment in
SCA's onsite aqueous waste treatment system. Leachate is pumped to the
treatment system through underground pipes. Subcell 4 has a manually
activated pump with its own leachate withdrawal pipe. The operation permit
for Landfill 7 requires that leachate levels in all subcells be maintained
at less than 2 feet above the landfill floor.
The final cap of SLF 7 consists of, in descending order, 6 inches top-
soil, 18 inches uncompacted "clayey" soil, polyvinylchloride (PVC) mem-
.7
brane, and 3 feet compacted clay (maximum permeability 10 cm/sec). The
cover is sloped about 8% for surface runoff.
Land/ill 10
SLF 10, located in the southeastern portion of the active SCA site,
was used to dispose of RCRA hazardous waste and PCS material between August
1982 and December 1984. It is currently being capped for closure. General
waste types received in SLF 10, as reported in DEC weekly reports, are
listed in Table 13.
SLF 10 was constructed by excavating to an average depth of about 27
feet below grade. An exterior berm was built about 14 feet above the orig-
inal ground surface. The base and sides of the unit were lined with 2 feet
_7
of recompacted clay (maximum permeability of 10 cm/sec) overlain by a
30-mil Hypalon liner and 2 additional feet of compacted clay. Internal
berms were constructed of compacted clay to provide five subcells for
SLF 7 originally had five subcells, one each for heavy neta-Zs, pseudo-
metals, flanaaable waste, halogenated (toxics) waste, and general
waste. Subcells 2 and 5 were later split to better accommodate waste
volumes received.
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42
segregation of heavy metal, flammable, pseudometal, halogenated and general
waste. Subcell 4, the halogenated waste subcell that received PCS wastes,
has an additional high-density polyethylene (HOPE) liner directly above the
Hypalon membrane. The finished base elevation of SLF 10 is at an average
elevation of about 300 feet amsl. The surface of the ground-water table of
the area is at an elevation of about 318 feet amsl.
Table 13
WASTE RECEIVED IN SLF 10
Antimony oxide (II)*
Alkaline paint stripper
Ammonium hydroxide
Ammonium persulfate
Calcium arsenate
Arsenic waste
Aromatic hydrocarbon still residue
Asbestos (II)
Baghouse dust
Barium chloride salt
Barium ferrite sludge
Benzaic acid
N-butyl acetate
Cadmi urn
Calcium arsenate
Calcium phosphate
Caustic solids (I)
Cellulose acetate
Chlorotoluene sludge
Chlorinated solvents
Chlorinated still bottoms
p-Chlorobenzotrifluoride
Chrome plating sludge
Creosote coal tar
Oioctyl phthalate
Dowtherm
Diethanolamine
Dye compounds
Epoxy 314
Formaldehyde
4-F1uoro-3-nitroani1ine tars
Glycols
Halogenated organics
Heavy metal sludges
Herbicides
Industrial sludge (I)
Iron sulfate
Lab chemicals
Lead compounds
Lead-chrome pigment
Metal hydroxide sludge
Maleic anhydride
Mercury waste
Methylene chloride bottoms
Methylene dianiline
Naphthalene
Organic solids (III)
Paint sludge (III)
Pesticides
Phenolic still bottoms
PCS solids/soil (IV)
Phenolic resin
Phthalic anhydride (IV)
Pickle liquor
PLC (V, III)
Plating sludge (I)
Polyester resin
Polyglycol filter cake
Polyvinyl acetate emulsions;
Polyurethane (VI)
Polymeric tar
Potassium ferrocyanide
Pyridine tars
Ronnex sludge (III)
Selenium (III)
Sodium chlorate
Sodium oxalate
Spent carbon (IV)
Titanium dioxide
Trichlorooenzene sulfonate
Vanadium and SK sludge
Waste solvents
WWTP sludge
Xylene
Zinc hydroxide sludge
in parentheses identify disposal subcell.
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43
Each subcell has an individual leachate collection and removal system
consisting of lateral, gravel-packed, french drains sloping about 2% in the
same direction as the slope of the floor to the leachate collection line
and a sloped riser pipe. Leachate is pumped to an underground oil/water
separator located adjacent to SLF 10 for pretreatment prior to final treat-
ment at the onsite aqueous waste treatment system. Leachate is pumped to
the treatment system through underground pipes. The State-issued operation
permit for landfill 10 requires that leachate levels in all subcells be
maintained at less than 2 feet above the landfill floor.
At the time of the Task Force evaluation in July, the landfill had
been covered by 3 feet of compacted clay and was in the 1-year "subsidence"
stage of the capping operation. The subsidence stage is provided to observe
and correct any subsidence in the landfill before installing the PVC syn-
thetic membrane and final cover material.
landfill 11
ซ
SLF 11, located on the east side of SLF 7, is the only currently active
landfill. It is operated as a continuous landfill, which means that one
section is operated for disposal while the adjacent section is being con-
structed. When all four sections are completed, the total arซa of SLF 11
will be about 25 acres. General waste types received in SLF lla, as recorded
in DEC weekly reports, are listed in Table 14.
Table 14
WASTE RECEIVED
IN SLF lla
Asbestos
Baghouse dust
Laboratory chemicals
Paint sludge
Plating sludge
Paint stripping salts
Phenolic still bottoms
Phosphoric acid sludge
PLC
Sodium dichromate
Still bottoms
Waste oil sludge
-------
During the Task Force inspection, the initial section, SLF lla, was
receiving waste for disposal while the adjacent section, SLF lib, was under
construction. SCA proposes to build all four sections in the same basic
manner as the initial section; however, a leachate collection system will
be added between two synthetic liner membranes in the three remaining
sections.
SLF lla was constructed by excavating about 14 feet below the original
surface. External berms, about 10 feet above the original grade, were then
built. The bottom and interior sides are lined with 2 feet of recompacted
_7
clay (maximum permeability of 10 cm/sec) overlain with a 40 mil Hypalon
membrane. An 80 mil HOPE liner was placed on top of the Hypalon and was
,7
covered with 1 foot of compacted clay (maximum permeability 10 era/sec).
Four subcells were constructed using internal berms to segregate heavy
metals, general organics, toxic waste and flammable, waste (a pseudometal
subcell.was not constructed in SLF lla but will probably be included in the
future adjacent units). The base elevation of SLF lla is about 305 feet
amsl, while the 'surface of the ground-water table in the area'is estimated
to be about 313 feet amsl.
To enhance leachate collection, a drainage blanket, consisting of a
geotaxtile covered with 1 foot of stone, was placed over the top layer of
the compacted clay. The bottom of each subcell was sloped about 1% toward
collection sumps. The first lift of waste disposed of in SLF lla reportedly
consisted of only drummed waste backfilled with stone to further enhance
leachate collection and removal. Each of the four subcells is constructed
with individual leachate collection and removal systems. Leachate is auto-
matically pumped to an oil/water separator and then to the onsite aqueous
waste treatment plant. The State-issued operation permit for landfill 11
requirej that leachate levels in all subcells be maintained at less than 2
feet above the landfill floor.
Non-Interim Status Regulated Waste Management Units
In addition to the waste management units regulated by RCRA, as
described previously, other units, which were reportedly inactive prior to
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45
November 1980 (effective date of RCRA regulations), are potential sources
of ground-water contamination. These units must be considered when evalu-
ating the facility's ground-water monitoring program and resulting data
because waste constituents from these activities may be detected by the
monitoring system.
On May 20, 1985, SCA submitted to EPA Region II known information per-
taining to past releases of hazardous waste constituents at the Model City
facility. This, along with additional information regarding some of these
units/activities, is discussed below. Some areas, such as the 01 in burn area,
are currently under study for potential environmental releases; future
studies are planned at other areas. These areas are shown in Figure 3.
01 in Burn Area/Drum Disposal Areas
The 01 in burn area, located north and northwest of SLF 7, was used by
01 in in the 1950s for disposal of rocket fuels and related waste material.
Associated with the Burn Area is" a plot of ground di rectly. north of SLF 7
where drums of waste, including lithium and boron salts, were buried.
Another area, southwest of SLF 7, also may have been used for disposal of
drummed waste. The exact boundaries of these areas are unknown.
In late 1981, SCA and 01 in jointly excavated and disposed of about
2,000 cubic yards of contaminated material -from the area northwest of SLF 7
and about 30 drums of waste from the area directly north of SLF 7 in late
1981. In June 1983, while SCA was excavating a trench for monitoring well
Z-4, north of SLF 7 and near the burn area, water having "foul odors" was
encountered about 10 feet below the ground surface. The trench was
backfilled.
In early 1984, SCA met with representatives of the U.S. Army Corps of
Engineers to discuss complete cleanup of these areas. The Corps of Engineers
contracted with a consultant to study the area. The consultant's August
1985 report on areas studied indicates that drums may still be buried at
the sites directly north of SLF 7 and southwest of the landfill. The report
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46
also stated that PCBs were present 1n soil samples from the area northwest
of SLF 7, and PCBs and pesticides were found in the soil of the area directly
north of the landfill (concentrations were not given). Areas sampled also
contained relatively high concentrations of boron, lithium and potassium.
North Drum Storage Area
The currently inactive North Drum Storage Area, located just north of
the closed SLF 7, was used by SCA for storage- and staging of drums prior to
their disposal in SLF 7. The area was not lined and soils from this area
were not excavated following deactivation of the unit. The western portion of
the North Drum Storage Area probably overlapped the 01 in burn-area.
West Drum Storage Area (Storage Area 2)
The West Drum Storage Area, located west of Tank 58, is an approxi-
mately 1.4-acre area used until about 1982 for drum storage. There are
reports of spills and leaks from the stored containers in this unit. State
inspection reports indicate that badly deteriorating and leaking drums were
found on numerous occasions in this area and ponding precipitation threat-
ened to spread hazardous waste from the area. A berm was eventually con-
structed in an attempt to limit the area of release.
During 1983 and 1984, contaminated soil from the area was excavated.
Soil core analyses conducted in mid-1984 indicate that waste constituents,
including methylene chloride and trichloroethylene, remained in the soil.
Currently, surface runoff is accumulated within the excavated area and
"pre-qualified", through sampling and analysis, prior to discharge to the
area's surface drainage system.
Underground Leachate Collection and Storage Tank (20,000 gallons)
SCA uses a 20,000-gallon buried tank, located west of the Fire Pond,
to collect and store leachate pumped from the oil/water separators, prior
to treatment at the onsite aqueous waste treatment facility. A leachate
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47
detection system, consisting of gravel-packed perforated pipe, was
constructed below the tank when the unit was installed. Although liquid
has been collected in the sump for this system, SCA reports that the mate-
rial has not been analyzed for hazardous constituents. SCA pumps the
liquid from the 1eachate system into the tank for eventual treatment.
Liquid from the tank is pumped to Lagoon 5 through buried pipes.
N-ll Sump
The N-ll sump, an unlined excavation located south of Lagoon 6, was
used between 1972 and 1983 to hold waste and washout liquid from the lime
mixing tank of the aqueous waste treatment system. Lime is used in the
system for pH adjustment. The waste placed in the N-ll sump consisted of
metal hydroxide salts with organics. In the fall-of 1984, the sump was
removed by pumping about 6,000 gallons of salt slurry to the salts storage
areas and excavating about 925 cubic yards of soil. A soil core sample was
9
taken after excavation and analyzed for "Teachability" and EP toxicity
(metals). Sample results are included in the May 20, 1985 letter from SCA
to EPA Region II regarding prior releases from hazardous waste management
areas. The excavation was backfilled with "clean" soil.
Tank Farms
SCA operates a series of tank farms for storage of RCRA and PCS waste.
All tanks have containment berms constructed either of soil or concrete.
Leakage from the tanks, waste transfer operations -and drums (reportedly
stored inside the bermed area of at least Tank Farm E) has occurred on num-
erous occasions, as reported in the May 20, 1985 letter to EPA, Region II
on past releases. Furthermore, a tank in Tank Farm E, used to store Pentac
and "C-56", waste reportedly developed a leak. Cleanup began in April 1985
and included excavation to a depth of 20 feet around the tank site. During
this excavation, a drain tile and sand lenses were found which could have
caused the leaked material to migrate away from the area. The tanks in
Tank Farm E were removed in the early 1980's and the area within the berms
was excavated and soil core samples reportedly taken.
-------
48
However, SCA personnel stated that the analysis results of the core samples
were not available.
Tank Farm A, located south of Lagoon 6 and east of Tank 58, was in the
process of being removed during the Task Force site inspection in July 1985.
An excavation in the area where one of the tanks had been removed showed
the presence of black, tar-like soil and strong odors. Excavated soil was
sampled and analyzed by SCA and was being disposed of onsite in SLF lla.
Lagoons 3 and 4
Lagoons 3 and 4, which were located directly east of Lagoon 2, were
used as waste receiving surface impoundments, similar to the currently active
Lagoons 1 and 2, from 1972 to 1977. They were reportedly constructed by
excavating 2 to 6 feet below grade and building berms 7 to 10 feet above
grade. -They were lined with synthetic liners. Following deactivation in
June 1977, all waste material was reportedly removed from these units and
the area regraded. No information was available to determine if soil beneath
these impoundments contained any hazardous waste constituents.
Underground Acid/TNT Lines
Numerous underground pipes, abandoned from previous site operations,
exist below the SCA site. These lines have been implicated in reported
spill incidences such as the January 1978 "green acid spill". In early
1978, the DEC required Chem-Trol to sever and cap or plug all known aba,n-
doned underground lines to prevent materials from leaving the site. SCA
subsequently excavated some of the lines and plugged or capped others that
were found. Despite the work on known underground lines, SCA does not
know whether all 'iave been discovered and cut off.
Liquid Waste Mixing Pit (Stabilization Pit)
The liquid waste mixing pit, referred to as the stabilization pit by
SCA, was located south of SLF 7 and north of the drum storage building. It
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49
was used to mix liquid waste and sludge with stabilizing material, such as
soil, prior to landfill ing. Waste was brought to the pit in either a steel
"roll-off" or dump truck, which was driven into this shallow bertned excava-
tion and mixed with stabilizing materials using a bacSOioe. The pit is no
longer active.
"Syms Pits"
The three "Syms pits", located at the western end of the property
and including the Houghson pit, acid pit and oil pit, are concrete-!ined sur-
face impoundments. These pits were used from 1971 to late 1975 for storage
and/or treatment of liquid waste. The acid and oil impoundments were
reportedly used for acid and oily liquid waste, respectively. The Houghson
pit was used for wastewater containing orgam'cs. These impoundments are
located west of the currently active area of the facility. SCA does not
consider these to be RCRA-regulated units because they are no longer used
for handling hazardous waste.
The bottoms of these impoundments are 4 to 10 feet below the ground
surface. The concrete 'liners' extend about 2 feet above the ground sur-
face. Little other information is available on construction and operation
of these units.
SCA reported that each impoundment was washed with a high pressure
water stream when the impoundments were taken out of service in 1975. All
three impoundments contained accumulated precipitation when observed during
the Task Force inspection. At that time, the Houghson and acid impound-
ments had an oily sheen on the surface of the accumulated water.
Town of Lewiston Salts Area
This salts area, located south of SLFs 1 through part of 4, was used
to store sludge from the onsite aqueous waste treatment facility until
about 1974, when the waste was removed. Little information is available
pertaining to the size and capacity of this unit. Also, it is unknown
whether this unit was clay lined. Currently, this area is swampy and over-
grown with vegetation.
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50
Facultative Pond 4
Facultative Pond 4 is no longer in service. It was used between 1978
and 1980 as a treated wastewater storage surface impoundment. This impound-
ment was essentially a bermed surface depression. Before use as a faculta-
tive pond, part of the area was apparently bermed (3.5 feet high) to prevent
flooding of buildings (now abandoned) in the area. Additional berms (6
feet high) were added to totally enclose the original bermed area and the
resulting "boot-shaped" area was used for wastewater storage. Soil from
the area was reportedly excavated when this area was taken out of service.
Post excavation soil sampling was conducted. Analytical results for these
samples were submitted by SCA to EPA Region II in a May 20, 1985 letter
regarding prior releases from hazardous waste units.
Drum Storage Area No. 1
Drum storage area No. 1 was used for container storage prior to 1980'.
It was apparently a 300' x 150' unlined area. fteco-F4s report incidences of
leaking drums and small spills of unknown waste material. Some spill loca-
tions were reportedly "scraped". It is currently benaed and used to store
truck trailers. Rainwater from the area is collected and reportedly treated
at the onsite aqueous wastewater treatment system. The area will eventually
be excavated for use as part of SLF lid.
FACILITY OPERATIONS
Improper facility operation can result in the release of hazardous
waste constituents to ground water. Task Force personnel reviewed records
of DEC weekly inspections and landfill leachate for indications of opera-
tional problems that might lead to waste releases and information to aid in
interpreting ground-water monitoring data.
To either conduct an interim status assessment monitoring program or
complete a RCRA Part 8 permit application, TSOF personnel need to know the
identity and location of waste constituents in the regulated units. This
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51
Information must be maintained in the operational record for the facility.
Consequently, operational records, including selected waste preacceptance
and tracking records, were reviewed to evaluate how well waste constituents
have been identified in incoming waste and whether the disposal locations
have been properly recorded and reported to DEC.
DEC Onsite Monitoring Reports
The DEC maintains personnel onsite to monitor SCA's daily waste manage-
ment activities. The State personnel prepare weekly reports outlining their
observations and findings. Data generated by their daily inspections include
status of covers on closed landfills, erosion of these units and surface
impoundments, types of waste being placed in the active cells, leachate
pumping volumes, leachate levels and other miscellaneous information. The
reports began in January 1980, nearly 11 months before the RCRA regulations
covering facility operation became effective. A review of these reports
revealed some problems with the integrity of the liners in some of the waste
handling lagoons .and possible movement of leachate through electrical con-
duits of the leachate collection systems in SLF 1 through SLF 6.
The DEC reports indicate that several of the impoundment liners have
been torn or floated to the surface. Lagoon 1 experienced a series of tears
during the first 2 weeks of June 1980. The liner also floated to the surface
during the week of May 8, 1980 probably due to gas accumulation under the
liner. Tears were also found in Lagoon 6 during the week of May 15, 1980
and on November 9, 1984. All problems were reportedly corrected after being
di scovered.
State inspection records for much of 1983 report instances when fluid
was flowing through the electrical conduits of the leachate collection system
of SLF 1 through SLF 6 and accumulating in manholes. Based on odor and
appearance of the liquid, the inspectors felt the fluid resembled leachate.
SCA personnel stated that the fluid migration stopped after the conduits
were relocated above the waste in the landfill.
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52
Landfill Leachate Monitoring
The DEC operating permits for SLF 7, SLF 10 and SLF lla and the general
operating permit (for SLFs 1 through 6) require that leachate levels, when
measured from the lowest level of the landfill cells, do not exceed 2 feet.
This requirement is intended to keep leachate levels below the adjacent
water table so as to maintain an inward hydraulic gradient, thus preventing
outward migration of leachate.
A review of leachate levels in the various landfill sumps for the period
1982-1983, from State inspection reports [Table 15], show that the 2-foot
maximum permitted level is frequently exceeded. Records show that leachate
levels in standpipes in SLFs 1 through 7 have consistently exceeded the
2-foot level. Leachate levels in SLF 10 are generally meeting the 2-foot
level, but there have been exceedences.
The landfill leachate levels given in Table 15, together with estimates
of the elevations of each landfill base and the surface of the surrounding
ground-water table [Table 8] indicate that leachate generated within some
units often exceeded the level of the surrounding ground water. For example,
the base elevation of SLF 1 is estimated to be about 316 feet amsl , while
the surface of the surrounding ground-water table is at about 318 feet amsl.
Leachate accumulations of greater than about 2 feet would create an out-
ward hydraulic gradient (i.e., toward the surrounding ground water). Leach-
ate levels consistently exceeded the 2 foot level for SLF 1 during all of
1982 and 1983 [Table 15]. Similar comparisons show that leachate generated
in SLF 1 through SLF 6, for at least 1982 and 1983, frequently created out-
ward hydraulic gradients. Records also indicate that leachate has, at times,
generated an outward hydraulic gradient in SLF 7.
Waste Characterization and Tracking
Waste characterization before receipt at a TSDF and tracking after
receipt are required under both RCRA and State interim status regulations.
These are important in determining the constituents that could potentially
-------
53
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be rซ1easซd from waste handling units. To determine whether SCA sufficiently
characterizes waste it receives and records the disposal location, a review
of preacceptance and tracking records for 23 waste loads received between
June 1981 and June 1985, was conducted.
The 23 waste loads were systematically selected from summaries sub-
mitted to DEC. About four loads per year from 1981 to 1985 were selected
from June receipts so that the 1985 receipts would be from just before
inspection. Each of the four loads represented a different waste category
including bulk liquids, drummed liquids, bulk solids and drummed solids.
Final selection was based on whether the wastes should have required a
detailed waste analysis during preacceptance testing, such as still bottoms.
The records indicate that, although the paperwork was not always fully
completed, it was sufficient to identify the hazardous waste constituents
in the wastes received and their disposal locations.
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56
SITE HYOROGEOLOGY
Two major investigations have been conducted by SCA consultants to
define the hydrogeologic setting of the Model City facility. The first
investigative report was prepared by Wehran Engineering in 1977, the second
by Golder Associates in 1985. The following information was derived from
those reports unless otherwise noted.
The Model City facility is situated on the Ontario Plain, an-area of
low topographic relief between Lake Ontario to the north and the Niagara
Escarpment to the south. Underlying the site is a 1,000-foot-thick sequence
of red shale, siltstone and sandstone of the Queenston Formation. The
Queenston Formation is overlain by about 30 to 60 feet of unconsolidated
glacial till and glaciolacustrine deposits.
Regionally, ground-water flow is expected to be northward from the
Escarpment toward Lake Ontario. Ground-water supplies are obtained princi-
pally from a fractured zone near the top of the shale and overlying uncon-
sol idated deposits. The remainder of the Queenston Formation is almost
impermeable. Well yields from the fracture zone and overlying deposits are
marginally adequate for domestic needs.
In regard to required ground-water monitoring, the most important geo-
logic units underlying the site are the unconsolidated glacial deposits
because of their potential to transport le'akage from the waste management
units. The hydrogeology of these units has been well defined.
Data from 45 test pits and over 400 borings have been used to charac-
terize the hydrogeology at the SCA facility. Most of the pre-1985 samples
obtained from the test borings were split spoon samples taken at 5-foot
intervals with some undisturbed (Shelby-tube) samples taken in key strata.
In 1985, continuous soil samples were taken from 21 boreholes; disturbed
samples were obtained with split spoon samplers and undisturbed samples
from Shelby-tube samplers. In addition to the geologic logging of the
glacial materials, about 150 field and laboratory permeability tests were
performed.
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57
HYOROGEOLOGIC UNITS
Both consultants to SCA (Wehran and Colder) identified the same prin-
cipal hydrogeologic units [Figure 5]; however, different terms were applied
to them, as follows:
Hydrogeologic Units
Wehran Designation Golder Designation
Zone 1 Upper alluvium
Upper glacial tills
Zone 2 Middle silt till
Glaciolacustrine clay
Zone 3 Glaciolacustrine silt/sand*
Basal red till
Shallow rock
* tfenran interprets this unit as fluvial, rathar than
lacustrine, in origin.
The ground-water monitoring plans for the facility and related regula-
tory documents use the Wehran unit designations. For ease of reference,
those terms will be used elsewhere in this report when addressing the moni-
toring program. However, the Golder unit designations will be used in this
discussion because they represent refined interpretations made from a more
comprehensive data b:ase than that available to the Wehran investigators.
The uppermost 5 to 10 feet of the Queenston shale (shallow rock) is
generally highly weathered and fragmented. Where present, it is hydraul-
ically connected to the overlying glacial deposits. In some places, the
shallow rock is weathered so severely that it is difficult to distinguish
from the overlying Basal Red Till.
The overlying Basal Red Till is nearly continuous and ranges up to
21.5 feet in thickness, with the typical thickness being about 5 feet. Its
distinguishing characteristics are its reddish color and its hard, dry
-------
57
HYDROGEOLOGIC UNITS
Both consultants to SCA (Wehran and Golden) Identified the same prin-
cipal hydrogeologic units [Figure 5]; however, different terms were applied
to them, as follows:
Hydrogeologic Units
Wehran Designation Colder Designation
Zone 1 Upper alluvium
Upper glacial tills
Zone 2 Middle silt till
Glaciolacustrine clay
Zone 3 Glaciolacustrine silt/sand*
Basal red till
Shallow rock
* 5/ซnran interprets this unit as fluvial, rathซr than
lacustrine, in origin.
The ground-water monitoring plans for the facility and related regula-
tory documents use the Wehran unit designations. For ease of reference,
those terms will be used elsewhere in this report when addressing the moni-
toring program. However, the Golder unit designations will be used in this
discussion because they represent refined interpretations made from a more
comprehensfve data base than that available to the Wehran investigators.
The uppermost 5 to 10 feet of the Queenston shale (shallow rock) is
generally highly weathered and fragmented. Where present, it is hydraul-
ically connected to the overlying glacial deposits. In some places, the
shallow rock is weathered so severely that it is difficult to distinguish
from the overlying Basal Red Till.
The overlying Basal Red Till is nearly continuous and ranges up to
21.5 feet in thickness, with the typical thickness being about 5 feet. Its
distinguishing characteristics are its reddish color and its hard, dry
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58
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indurated texture. It appears to be largely derived from the re-working of
the underlying bedrock (Queenston shale).
Overlying the Basal Red Tillj's a 5 to 10-foot-thick varied sequence
of Glaciolacustrine Silt/Sand, the coarsest and most permeable of the
glacial deposits. It consists of brown, poorly sorted, fine to coarse sand
and silt.
Overlying the Glaciolacustrine Silt/Sand unit is the Glaciolacustrine
Clay which ranges from about 2 to 25 feet in thickness. In site boring
logs, it is usually described as: "Very soft to firm, gray to gray-brown
SILTY CLAY, trace fine sand". In the northwestern portion of the site, the
Glaciolacustrine Clay is separated into an upper and lower member by up to
10 feet of silt till (Middle Silt Till). Its distinguishing feature is its
characteristic gray color. A typical description from site boring logs is:
"compact to very dense, gray to gray-brown SILT and coarse to fine SAND,
trace to some fine gravel,"
The Glaciolacustrine Clay is overlain by 15 to 20 feet of silt and
clay tills (Upper Glacial Tills). These tills comprise most of the surface
material at the Model City facility. The silt till is discontinuous
throughout the site and is generally less prevalent in the southern por-
tion. It is typically logged as: "compact to very dense, brown to purple-
brown SILT, and coarse to fine SAND, little fine gravel. Contains occa-
sional discontinuous, wet silt and sand layers".
The clay till is continuous across the site and overlies the silt
till, where present. In the southern half of the site, it directly over-
lies the Glaciolacustrine Clay. The clay till is typically logged as:
"stiff to hard, brown to purple-brown CLAYEY SILT, some coarse to fine
sand, little fine gravel. Non-stratified to faintly laminated. Contains
occasional cobbles and discontinuous, wet sand, gravel and silt layers."
On the surface of the clay till are discontinuous shallow pockets of
fine sand, silt and clay alluvium. This unit is typically laminated and
has a maximum thickness of about 5 feet.
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60
The Glaciolacustrine Silt/Sand (Zone 3) is considered the uppermost
aquifer by Colder and Wehran. It would be the only major pathway for leak-
age from the regulated units except that vertical recharge is restricted by
the overlying Glaciolacustrine Clay and Middle Silt Till (where present).
Further, the Upper Glacial Till unit (Zone 1) contains a free water table
surface and is the first saturated permeable zone beneath the site.
Task Force personnel determined that both Zone 1 and Zone 3 need to be
monitored. Zone 1 is a permeable saturated flow zone and monitoring wells
completed in this zone are essential to ensure immediate detection of any
statistically significant amounts of hazardous waste or hazardous waste
constituents that might migrate from the waste management units.
GROUND-WATER FLOW DIRECTIONS AND RATES
Potentiometric contour maps were presented in the Golder report for
the Upper Glacial Tills (Zone 1) and the Glaciolacustrine Silt/Sand (Zone 3)
based on January 1985 measurements. Golder's -interpretation of the water
level measurements, as illustrated by the contour maps, were confirmed by
Task Force personnel.
The contour map for Zone 1 [Figure 6] suggests that horizontal ground-
water flow is toward the north and northwest, following the slope of the
ground surface. The water table surface is apparently controlled by topog-
raphy and area drainage-features and is locally affected by the facultative
ponds and landfills. Generally, the water table surface is nearly parallel
to the ground surface at a depth of about 3 to 5 feet.
The potentiometric contour map for Zone 3 indicates ground-water flow
to the north and west [Figure 7], but regionally the flow is northward
toward Lake Ontario. Golder attributes the local westwardly component of
flow to an increase in thickness and permeability of Zone 3 in the north-
western portion of the site. In the central portion of the facility where
the closely spaced contour lines indicate a steeper gradient, the thickness
and permeability of the flow zone is. lower than elsewhere.
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51
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The permeability (hydraulic conductivity) of the various geologic
units at the Model City site has been estimated by SCA consultants using
three different methods. These are: (1) laboratory testing of "undis-
turbed" soil samples with the permeability measured primarily in the
vertical direction, (2) in situ recovery tests and (3) indirectly, through
sieve analysis of soil samples. A summary of the permeabilities for the
various formations is presented in Table 16.
Estimated maximum ground-water flow rates [Table 17] were calculated
using gradients and permeabilities of the hydrogeologic units determined by
the SCA consultants. A comparison of the estimated vertical and horizontal
flow rates for Zone 1 suggests that lateral flow is predominant, but is
only marginally greater than the downward component. For the middle :;ilt
till (where present in Zone -2), the data suggest that the lateral f1ow is
greater; however, downward flow In the glaciolacustrine unit is much
greater than the lateral component. The data for Zone 3 are incomplete and
a predominant flow direction is not suggested; however, horizontal .flow is
usually predominant in stratified sandy deposits such as th'ose at the top
of this zone.
. In general, the comparison of vertical and horizontal flow rates sug-
gests that in Zone 1 ground water flows both laterally and, to a lesser
extent, downward to Zone 2. In Zone 2, where the middle silt till is
absent, the flow is primarily downward to Zone 3, then primarily laterally.
Therefore, both Zones 1 and 3 need to be monitored to ensure immediate
detection of leakage from the regulated units.
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64
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GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS
Ground-water monitoring at the SCA Model City facility has been
conducted under both Federal and State interim status regulations. The
following is an evaluation of the monitoring program between November 1981,
when the ground-water monitoring provisions of the RCRA regulations became
effective, and July 1985, when the Task Force investigation was conducted.
This section addresses:
1. Regulatory requirements
2. Ground-water sampling and analysis plan
3. Monitoring wells
4. Sample collection and handling procedures
5. Sample analysis methods and data quality
6. Ground-water quality assessment program (implemented in 1983) and
current outline
REGULATORY-REQUIREMENTS
Regulatory requirements for ground-water monitoring at the Model City
facility are complex and precepts have evolved since 1981 when the RCRA
interim status provisions went into effect. This has resulted in SCA devel-
oping different monitoring well networks for State and EPA programs. The
information presented here is included as a background for subsequent dis-
cussions of those well networks, compliance by SCA with the various monitor-
ing requirements and the assessment program. A timeline of regulatory
events related to ground-water monitoring is presented in Figure 8.
As of July 1985, a four-part regulatory framework controlled the
design, installation and operation of the ground-water monitoring program
at the SCA facility. These were: (1) facility requirements contained in
the New York State Part 360 Regulations [360.8(c)(5)]*; (2) the general
During the Task Force inspection, the State Part 360 regulations were
re-codified with some modification into Part 373 regulations. The
Part 360 regulations are cited in this report because they were the
principal ones in effect during the period of interest.
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67
Figure 8
TIMELINE OF REGULATORY EVENTS RELATED TO GROUND-WATER MONITORING
SCA Model City Facility
EPA Program
DEC Program
November 1981. RCRA ground-
monitoring program initiated
on four-well network
May 1981. General operating
permit issued for Model City
faci1ity
January 1982
March 1982. ,State enacts
revised Part 360 regulations
July 1982. MMCP approved for
facility which included a 33-well
network
September 1982. DEC declares
airlift apparatus unacceptable
which precipitates replacement
sampling devices and new wells
being installed
November 1982. Initial year
of monitoring completed
January 1983
May 1983, SCA notified EPA that
assessment had been triggered.
Plan submitted in June.
August 1983. RCRA Part B
permit application submitted
July 1983. Installed most
Zone 1 MMCP wells
December 1983. New York
received Interim Authorization;
Agreements completed between
SCA, Citizen Intervenors and
MOE
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68
Figure 8 (contd.)
EPA Program
DEC Program
September 1984.
October 1984. SCA submits
assessment program report .
March, April, May 1985.
SCA submits revised-Part B
ground-Water monitoring program
June 1985. EPA issues AO for
assessment program deficiencies
January 1984 - Installed several replace-
ment MMCP wells in Zone 3
March 1984. SCA begins first
year of monitoring on new 41-well
MMCP network
April 1984. Essentially com-
pleted installing MMCP wells
May 1984. Operating permit
issued for SLF 11 that incor-
porated agreements between
SCA, Citizen Intervenors and
MOE; general operating permit
expired"
CWM acquires Model City facility
January 1985
July 1985. Task Force inspection
September 1985. Consent for
assessment program AO completed
I
Under Stats law, the permit remains in effect after expiration until a.
new one is issued. The permit expired in May 1984 and is being revised
by DEC.
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69
operating permit issued by the DEC that became effective May 1, 1981
(No. 2343) and the approved MMCP required by that permit; (3) the operating
permit for SLF 11 (No. 3427), issued by DEC, which incorporates stipula-
tions and agreements between SCA and the Ontario Ministry of the Environ-
ment and the Citizen Intervenors and (4) PCS disposal approvals issued by
EPA Region II under authority of TSCA [40 CFR Part 761. 75(b)(6)].
State Regulations
The New York State Part 360 Facility Requirements (enacted in March
1982) for ground-water monitoring are nearly identical to, but broader in
scope than, the- RCRA Part 265, Subpart F interim status requirements. The
substantive differences are that the State can require ground-water moni-
toring of (1) facilities other than surface impoundments, landfills and
land treatment areas (areas covered by RCRA regulations), (2) water-bearing
zones other than the uppermost aquifer, and (3) separate waste management
components, even if they are within a line circumscribing several units.
Further, PCS wastes are covered by the State hazardous waste disposal regu-
lations; there is no State counterpart to TSCA. Regulation, counterparts
are shown in Table 18.
Table 18
STATE AND FEDERAL COUNTERPART INTERIM STATUS REGULATIONS
New York State RCRA
Subpart Regulation Regulation
Title* (360.f) (40 CFR Part)
Applicability 8(c)(5)(i) 265.90
Ground-water 8(c)(5)(ii) 265.91
Monitoring System
Sampling and 8(c)(5)(iii) 265.92
Analysis
Preparation, 8(c)(5)(iv) 265.93
Evaluation
and Response
Reporting and 8(c)(5)(v) 265.94
Recordkeeping
* Subpart titles are the same in both the State and
RCRA regulations.
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70
General Operating Permit and MMCP
As previously noted, the DEC issued a general facility operating permit
to the Model City facility in 1981. Special Condition 8 of that permit
required SCA to submit an MMCP to the Department for approval. The monitor-
ing program in that plan was to cover "groundwater quality and hydrology
for every water bearing zone beneath the facility. . .". Further, "this
monitoring program shall include locations upstream and downstream of each
separate site operation. . ." and, finally, "the MMCP shall include sampling
schedules, sampling methods, analytical parameters and other pertinent
information". Once approved, the MMCP procedures became, in effect, permit
conditions that must be followed.
When the DEC recetved Interim Authorization in December 1983, the MMCP
became, in effect, the ground-water sampling and analysis plan required by
State regulations. The June 1982 MMCP, approved by the State on July 29,
1982, included the RCRA Part 265, Subpart F ground-water monitoring require-
ments (although not the specific monitoring'well network) and additional
State-required monitoring parameters [Table 19]. It did not, however,
incorporate the ground-water monitoring requirements for PCS disposal
approvals SLFs 7 and 10.
Table 19
ADDITIONAL STATE-REQUIRED GROUND-WATER MONITORING
PARAMETERS LISTED IN JUNE 1982 MMCP
Ammonia Zinc
Copper Total organic-chlorine scan
Cyanide PCBs*
* To be tested for if individual peaks in the
total organic-chlorine scan are greater than
10 ppb or the total of all peaks is greater
than 25 ppb
The environmental monitoring section of the approved MMCP was revised
in July 1984 to include the new SLF 11 State permit requirements and the
EPA PCS disposal approval monitoring requirements for SLFs 7, 10 and 11.
During the Task Force inspection, SCA personnel stated that the revised
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71
MMCP is currently being followed by the facility. Although DEC effected
the revised plan, it was never approved.
Operating Permit for SLF 11
On May 26, 1984, DEC issued an operating permit (No. 3427) for SLF 11.
The permit incorporated, by reference, ground-water monitoring requirements
developed with public participation during the application review process.
The public participants, including the Canadian Ontario Ministry of tne
Environment (MCE) and a group (Citizen Intervenors), comprising members of
Operation Clean, Pollution Probe and Operation Clean-Niagara, had requested
a public hearing on the application. To avoid a potentially protracted
hearing, the MOE and Citizen Intervenors negotiated separate stipulations
and agreements with SCA that included ground-water monitoring around the
new landfill. Those agreements were incorporated into the permit for
SLF 11.
Together, the stipulations and 'agreements require a minimum of .14
Zone 1 trench wells and eight Zone 3 wells to be placed around SLF 11, with
at least five of the Zone 1 wells and three Zone 3 wells to be constructed
around Section A (SLF lla). The wells around SLF lla were to be completed
by April 15, 1984.
Further, the agreements stipulated that the wells were to be monitored
for volatile and organic constituents identified now or in the future in
40 CFR 122, Appendix 0, Table 2 (Organic Toxic Pollutants in Each of Four
Fractions in Analysis by Gas Chromatography/Mass Spectroscopy). Currently,
the referenced table contains 110 organic compounds.
PCS Disposal Approvals
The Model City facility currently has three PCB disposal approvals
(for SLF 7, 10 and 11), each of which requires ground-water monitoring
[Table 20]. Monthly reports are submitted to EPA Region II for ground-water
and other monitoring required by the disposal approvals.
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72
Compliance with the monitoring requirements of the PCS disposal
approvals is not specifically addressed in the following text because those
requirements were incorporated into the revised MMCP and the scope of the
Task Force inspection related, principally, to RCRA requirements.
Table 20
SUMMARY OF PCS DISPOSAL APPROVAL GROUND-WATER MONITORING REQUIREMENTS
Secure Designated Monitoring Monitoring
Landfill "Monitoring Wells Parameters Frequency
SLF 7 B~21a B~22' B~32> PCB' PH- specific Monthly until closure,
8-33 conductance, chlor- then semi annually
inated organics
SLF 10 B-35,bB-43, , PCB, pH, specific B-wells quarterly until
B-113 , B-114 , conductance, volatile closure; Z-wells semi-
1-12, Z-15 chlorinated organics annually until closure;
for post-closure moni-
toring, see disposal
approval
S'LF lla B-32A, B-33A, PCB, pH, specific ' B-wells quarterly
B-115,- B-116, conductance, volatile until closure; Z-wells *
Z-3, Z-19, Z-20, chlorinated organics semiannually until
Z-21, Z-22, Z-23C closure; for post-
closure monitoring,
see disposal approval
a PCS Disposal Approval for SLF 7, condition number 7, requires the sub-
mission of a proposal for installation of a minimum of one additional
downgradient monitoring well (Region II records).
b Wells B-113 and B-114 were designated as a result of Approval Condi-
tion I.A in the PCS Disposal Approval for SLF 10.
c Well no longer exists; it was removed during construction of cell lib
and will reportedly be reinstalled at a new location.
To summarize, as of July 1985, the SCA interim status ground-water
monitoring program was subject to both Federal and State requirements, dis-
posal approvals and permits, and was to be conducted in accordance with the
June 1982 MMCP approved by DEC. Monitoring parameters include those con-
tained in (1) the State counterparts of the RCRA Part 265, Subpart F regula-
tions plus six added by the DEC, (2) 40 CFR Part 122, Appendix D, Table II,
pursuant to the operating permit for SLF 11 and (3) the PCB disposal
approvals.
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73
GROUND-WATER SAMPLING AND ANALYSIS PLAN
Since the effective date of the RCRA ground-water monitoring require-
ments (November 19, 1981), SCA Model City has developed and followed eight
documents composing at least three monitoring plans. Until early 1985, the
plans did not adequately describe sample collection, handling and analysis
procedures and, in some cases, the procedures defined were deficient.
The plan being followed in July 1985, although not a single document,
generally meets the State regulatory requirements for sample collection,
handling, shipment, analysis and chain-of-custody. It specifies, however,
filtering of samples for most parameter analyses, which is unacceptable to
the State and EPA because the resulting data may be biased low.
The following describes each of the plans and discusses the deficiencies.
Plan Under EPA/RCRA Regulations (1981-1983)
fc ป
By November 1981, SCA had developed a monitoring plan, titled "Ground-
water Monitoring Program, Model City, New York Facility, SCA Chemical
Services, Inc., Boston, Massachusetts - Owner and Operator", to meet EPA
requirements. The 18-page plan, provided to Task Force personnel by SCA,
addressed all the Subpart F provisions. A review of the plan and subse-
quent monitoring reports revealed several inconsistencies with the RCRA
regulations.
First, the monitoring well network, described on page 5 of the SCA
plan, included three identified wells (B-35, B-22 and 8-49) and one uniden-
tified downgradient well, all in Zone 3. The unknown well was subsequently
identified in the first quarterly report as B-42 (described below). These
four wells [Figure 9] composed the RCRA-required monitoring network until
December 1983 as indicated by the four quarterly and two subsequent semi-
annual monitoring reports. None of the downgradient wells were at the limit
of the waste management area as required by 265.91(a)(2). Placement of
wells adjacent to the waste management area is essential, not only to satisfy
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74
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-------
75
the regulatory requirement, but to minimize the chance of erroneously
triggering assessment monitoring as a result of detecting chemicals from
pre-RCRA site activities.
The monitoring well locations indicate that the entire site was con-
sidered as one large waste management area pursuant to 265.91(b)(2), in
marked contrast to the four management areas described in the concurrent
MMCP, as discussed below. Further, the number and locations of monitoring
wells were not adequate to ensure immediate detection of statistically sig-
nificant amounts of hazardous wastes or hazardous waste constituents migrat-
ing from the waste management area to the uppermost aquifer, also required
by 265.91(a)(2). For example, if waste constituents were leaking from near
the northern side of SLF 7 or Facultative Ponds 1 and 2 [Figures 7 and 9],
they would not be detected by any of the three downgradient wells, all of
which are in Zone 3.
The monitoring wel1.sampling method was inadequate because it involved
the use of an "air lift apparatus". The parameters used as indicators of
ground-water contamination, including pH, specific conductance, total
organic carbon (TOC), and total organic halogen (TOX) [265.92(b)(3)], are
all sensitive, especially pH, to the vigorous aeration caused by the air
lift apparatus. Concentrations and values can change significantly as a
result of the aeration.
If pH changes occur, change in "specific conductance is likely. If
organics were leaching from the management units, volatiles would likely be
the first to arrive at the monitoring.wells. Volatiles could be easily
stripped from the sampled water by the air lift apparatus and would be
reflected in decreased TOX and, possibly, TOC concentrations.
All methods used f-r analysis are not specified, as required by RCRA
regulations [265.92(a)]. Page 10 of the SCA plan states "Unless otherwise
noted, the [analytical] procedures outlined in the following documents will
be used for the appropriate parameters". The two listed documents are com-
pilations of "standard methods", which together did not contain analytical
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76
procedures for all of the monitoring parameters, such as TOX. Also, citing
general analytical methods is, not acceptable because those methods often
have alternate subparts that can yield significantly different results for
the same sample.
The first quarterly report, dated May 18, 1982, revealed that the
unidentified well, discussed above, was initially B-84 but, midway through
the quarterly monitoring, was changed to B-42. Tables submitted in that
report show some analytical results listed under 8-42 with a footnote indi-
cating that they were actually from a B-84 sample. Well 8-84 is on the
north side of and adjacent to SLF 7 and well B-42 is 2,200 feet southwest
of B-84 near the northeast corner of salts area 7; yet the report presents
the data as if the wells were adjacent or equivalent. Such data do not
adequately establish background concentrations as required by 265.92(c).
In summary, during interim status ground-water monitoring under RCRA,
the Model City facility did not develop an adequate ground-water sampling
and analysis plan, nor did it have properly located or a sufficient number
of monitoring wells. Other problems are described in the section on sample
analysis and data quality.
Plan Under DEC/State Regulations (1984-1985)
Under the State Part 360 regulations, like the Federal counterparts, a
facility must develop and follow a ground-water sampling and analysis plan.
Additionally, the general operating permit for the Model City facility
requires approval of the plan [MMCP] by the DEC. By July 1985, when the
Task Force inspection was conducted, the State-approved plan had been out-
dated and SCA was following a piecemeal "plan" composed of at least five
documents, none of which had been approved by the DEC.
Notwithstanding the lack of approval by DEC, procedures described in
the July 1985 "plan", except for filtering of samples, were judged accept-
able. The piecemeal nature of the plan was not acceptable.
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77
When New York received Interim Authorization on December 27, 1983, the
then-current monitoring plan at the Model City facility (under State regula-
tions and permit) was the June 1982 MMCP. The June 1982 MMCP was approved
(referred to as the approved MMCP) by the DEC following extensive public
participation and an adjudicatory hearing. The approved MMCP was accepted,
at the time, as satisfying State monitoring requirements.
The monitoring well network described in the approved MMCP, however,
was not completed until the summer of 1983 (except for one well); then it
was overhauled. Wells having PVC casings were replaced with wells cased
with stainless steel and new wells were installed adjacent to SLF 11. Fur-
ther, in September 1982, DEC notified SCA that the air-lift devices used
for sample withdrawal were not acceptable. As new wells were constructed,
ฎ
Geomon units (described in the subsection oh Monitoring Wells) were instal-
led. The new wells were completed, except for B-112, by April 1984 (in
accordance with the MOE and Citizen Intervenor agreements).
As a result of these changes, the initial year of monitoring required
by State regulations [360.8(c)(5)(iii)(c)] did not begin until March 1984.
Therefore, the relevant period for assessing the ground-water sampling
analysis plan under the State program was from March 1984 to the time of
inspection (July 1985).
With all the changes to the well network and sample collection devices,
the approved MMCP was partially outdated when the initial year of monitor-
ing began In March 1984. To account for these changes, SCA developed and
followed three other documents during 1984, which superceded the ground-
water monitoring section of the approved MMCP. Only one was a revision to
the MMCP and, according to SCA personnel, it was never approved by DEC.
After CWM acquired SCA in late 1984, sampling and analysis procedures (pre-
sented in three CWM documents*), superceded respective parts of the SCA
documents.
Geomon is A registered trademark and appears hereafter without the ฎ.
Two of these documents were authored by the contractor laboratory (ETC)
for CWM and the other by its parent company, WMI.
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78
In some instances, procedures were implemented before a written plan was
developed. These plans are discussed below.
Between February and October 1984, SCA developed and followed a ground-
water sampling and analysis plan consisting of three SCA documents:
1. Air, Surface Water and Ground-water Monitoring Plan, SCA Chemical
Services Inc., Model City, New York (a revised version of the
monitoring section of the approved MMCP) dated July 1984
2. SCA Quality Assurance Manual for Groundwater Monitoring dated
February 24, 1984
3. Standard Laboratory Methods for SCA Model City dated October
1984
Document 1 above (referred to as the revised MMCP) presented a frame-
work for the State-required monitoring program including a new well network,
a generic monitoring schedule and general monitoring procedures. Program
details for sampling are presented in the Quality Assurance Manual and
analytical methods are presented in the Standard Laboratory Methods volume.
These documents are not referenced in the revised MMCP as being part of the
monitoring plan; however, they were the written plans that were being
followed.
The monitoring well network had changed significantly in the revised
MMCP to include (1) many new wells, some, of which were first and second
generation 'replacements for those identified in the June 1982 MMCP and (2)
a fifth Facility Process Area (FPA V - encompasses SLF 11). The revised
network includes 24 wells in Zone 1 and 19 in Zone 3, as discussed in the
following subsection on monitoring wells.*
A principal problem with the revised MMCP (and the approved MMCP) is
the inadequate monitoring program for the Zone 1 wells. The inadequacy
Of the 19 Zone 3 wells listed in the revised MttCP, one (well B-112)
WAS destroyed in 1983 and never reconstructed.
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79
arises from differing interpretations of the regulation and the precepts
followed when the 1982 MMCP was approved. The revised MMCP (authored by
SCA) states, on page 60, that "because Zone 1 is not an aquifer in the con-
ventional sense, RCRA* requirements for sampling frequencies and parameters
do not apply".
The interpretation, stated in the revised MMCP, poses two problems.
First, the resulting data base for the Zone 1 wells is much less than it
would be if State interim status monitoring requirements were followed.
Secondly, no procedure is clearly indicated by which data comparisons
between upgradient and downgradient wells would be made and assessment
monitoring triggered, if leakage were indicated by the data.** Current
precepts and interpretations of the site hydrogeology and regulatory
requirements by Task Force personnel indicate that Zone 1 should be moni-
tored in accordance with the State interim status requirements (i.e., in
the same manner as Zone 3 wells). .
Sample collection equipment was also changed in the revised MMCP. The
air-lift apparatus was replaced with a gas-driven Geomon sampler unit. The
suitability of this device was "never demonstrated by SCA as indicated in an
October 1984 letter from DEC to EPA [Appendix D].
The SCA Quality Assurance Manual for Groundwater Monitoring is much
more comprehensive than the approved MMCP. It addresses areas such as well
development, purging, sample collection, preservatives, depth-to-water
measurements, field notes, preparation of sample bottles, bottle labeling,
chain-of-custody, sample shipments, personnel training and the sampling
schedule (minus .the starting date). Special sample handling procedures are
described for volatile organics, total organic halides and coliform bacteria.
* The reference to RCRA is a carryover from the approved HWCP. The
reference should be to State requirements.
** No statistical data comparisons for Zone 1 wells have been reported
to the State.
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80
The subjects were covered in moderate detail. Sample bottle labeling
is a potential problem, however, as bottles are marked for each sampling
point only when initially prepared (some bottles are reused; therefore,
they become dedicated to a monitoring point). No additional labeling was
reportedly done as samples were collected. The date, time and sampling
point should be shown on a bottle label each time a sample is collected.
With the large number of sampling points, the potential for exceedance of
holding times and sample mix-ups is greatly increased under the system des-
cribed. Also, no custody seals are mentioned for samples shipped offsite
for analysis.
The document "Standard Laboratory Methods for SCA Model City" was not
completed until October 1984, 7 months after the initial year of monitoring
was begun. Neither the approved nor the revised MMCP listed specific
analytical methods to be used for ground-water samples. Therefore, proce-
dures were implemented before a written plan was developed. An evaluation
of the methods followed is presented in the section on sample analysis and
data.qua!ity.
In July 1985, during the Task Force inspection, the facility ground-
water sampling and analysis plan included unspecified parts of the following
documents:
1. SCA Quality Assurance Plan for Groundwater Monitoring dated
February 24, 1984
2. Revised MMCP dated July 1984
3. WMI Manual for Groundwater Sampling, undated
4. Laboratory Standard Operating Procedures as amended February 21,
1985
5. Data Integration Standard Operating Procedures dated June 10,
1985
This loose amalgamation of documents does not constitute an acceptable plan
for the facility, as required by the operating permit and State regulations
[360.8(c)(5)(iii)(a)]. The contents and relation of these plans are dis-
cussed below.
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81
From December 1984 to July 1985, following acquisition of SCA by CWM,
CWM sampling and analysis procedures were phased in at the Model City Facil-
ity. Again, the MMCP was not amended to reflect the changes made. The -CWM
corporate procedures for sample collection, handling and documentation
(field records and chain-of-custody) are described in the "WMI Manual for
Groundwater Sampling".*
A copy of the WMI Manual for Groundwater Sampling was provided to Task
Force personnel and declared "business confidential" pursuant to 40 CFR
Part 2.203;. consequently, discussion of that document in this report will
be limited.
The WMI Manual for Groundwater Sampling includes 89 pages of narrative
and two appendices. It describes sample collection, handling, field records
and chain-of-custody in great detail; however, the sampling procedures are
not site specific. Omitted are a listing of the designated monitoring net-
work wells, sampling schedules derived from the various regulatory require-
ments, and procedures for operating the Geomon sampling systems. These
items are, however, presented in two SCA documents (revised MMCP and Quality
Assurance Manual) previously discussed.
The "Laboratory Standard Operating Procedures" by ETC is a 509-page
document that describes chain-of-custody, sample collection, analytical
methods and quality assurance. The manual, provided to Task Force person-
nel, was updated October 31, 1984 and amended February 21, 1985. The
amended version includes a description of sample management through the
laboratory and many of the specific instrument operating procedures. A
second manual entitled "Data Integration Standard Operating Procedures,
June 10, 1985," also by ETC, describes procedures for sample management and
data processing to the report stage. This second manual a^o contains
information on quality control procedures and procedures not presented in
the former manual.
WMI (Waste Management, Inc.) is the parent company of CWM.
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82
Detailed methods for chloride, nitrate, sulfate, phenol, sodium, TOX,
TOC, gross alpha and gross beta are not contained in the manuals. Further,
ETC subcontracts analyses and the methods used by the subcontractors are
not included. For example, the metals digestion used by one subcontractor
is not the one contained in the ETC manual. The ETC manual allows clients
to ship samples for dissolved metals analysis to the -lab with a maximum
elapsed time of 48 hours before filtration and preservation. This proce-
dure is inappropriate; however, it is not followed by CWM personnel (filter-
ing is done within 2 hours of sampl-e collection). EPA recommends* filtra-
tion for samples being analyzed for dissolved constituents followed by pre-
servation as soon after sampling as is practical.
MONITORING WELLS
The monitoring well network currently in use at the facility has also
evolved considerably since 1981. Although well construction, in most cases,
is adequate, the current (July 1985) number and locations of monitoring-
wells are not sufficient to ensure immediate detection of leakage from all
of the regulated units. The entire current well network is to be replaced
in the near future with a more comprehensive system (see section "Ground-
water Monitoring Program Proposed for RCRA Permit"). Because the new system
has not been installed, deficiencies of the system being used in July 1985
are discussed below. The following information was obtained from boring
logs and well completion/certification reports unless otherwise noted.
An elevation survey of existing wells, reported to SCA in September
1984, lists 55 wells including 24 in Zone 1 and 31 in Zone 3. Of these,
the revised MMCP monitoring network currently contains 23 in Zone 1 and 18
in Zone 3 [Figure 10]. Zone 1 wells are designated by the letter "Z" and
Zone 3 by the letters "8" or "W".
"Methods for Chemical Analysis of Water and Wastes", EPA-600/4-79-020,
as referenced in 265.92(a)
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83
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Well Construction
The current Zone 1 monitoring wells are constructed in trenches
[Figure 11].* The trenches, in which the wells were installed, were con-
structed with a backhoe and are generally about 20 feet deep, 15 feet long
and 3 feet wide.
The Zone 3 wells were generally constructed in 8-inch diameter bore-
holes using rotary and hollow-stem auger drilling methods. The annular
space (space between the casing and borehole) above the sand pack was filled
with a bentonite-cement grout; in some wells a bentonite-pellet seal was
installed between the sand pack and grout [Table 21].
Monitoring network wells are constructed of 2-inch diameter stainless
steel casing and screens and have locking well-head caps. The screen slot
size is 0.010-inch (10-slot); screen length in Zone 1 wells is 2 feet and
in Zone 3, with three exceptions, is 5 feet. The exceptions are wells
B-49A, B-110 and B-lll, which have screen lengths of 2, 15 and 14 feet,
respectively. Additional well construction details are presented in
Table 21.
During 1984, the monitoring network wells were equipped with dedicated
Geomon samplers [Figure 12], which are positive displacement gas driven
units constructed of Teflon. The Geomon sampler is enveloped in a sand
pack inside the well casing; no details were provided on the vertical loca-
tion of the sampler inlet in each well. During purging and sampling, gas
pressure (from a high pressure nitrogen tank) is applied to a down-the-hole
cylinder, which closes a bottom check valve and forces water up the sam-
pling line. When the pressure is relieved, the check valve opens and
allows ground water to recharge the cylinder. The principal advantage of
the Geomon sampler over the air-lift device is that the sample is not
vigorously aerated during collection.
Well Z-23 was constructed a.3 a shallow version of the Zone 3 wells;
howevert it was removed during the construction of SLF lib.
-------
85
FIGURE 11 TRENCH WELL MONITORING DEVICE FOR ZONE 1
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FIGURE 12 SCHEMATIC OF GEOMON SAMPLING SYSTEM
USED AT MODEL CITY FACILITY
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89
Based on the well logs and completion reports, the Zone 3 monitoring
wells are adequately constructed, completed and, in most instances, devel-
oped. The Zone 1 wells are adequately constructed and completed; develop-
ment information is deficient. Construction-related problems have beซ'.n
noted at some wells; however, the effects are either negligible or could be
remedied through replacement or modification. For example, wells B-34A,
B-35A, B-49A, B-110 and'B-111 have yielded high pH samples (pH 8 to 12)
that were attributed to the bentonite-cement grout. Some of the wells sam-
pled as part of the inspection were excessively turbid indicating either
improper construction (sand pack deficiencies) or development.
Well Locations and Number
The principal problems with the current monitoring well network are
deficiencies in locations and number of wells. Many of the downgradient
wells are not located close enough to the waste management areas nor are
there a sufficient number to .ensure immediate detection of chemicals migrat-
ing from those areas to the uppermost aquifer. State regulations
[360.8(c)(5)(ii)(a) and (b)] require'that downgradient monitoring wells be
installed at the limit of the waste management area. At facilities having
multiple waste management components subject to ground-water monitoring
requirements, such as the Model City facility, the waste management arect is
described by an imaginary line which circumscribes several components.
Accordingly, SCA has divided the site into five "Facility Process
Areas" (FPAs), as previously noted. Under present precepts, the FPA bounda-
ries are too far away from the waste management units to constitute the
circumscribing line, as described in the regulations. At facilities having
only one unit subject to ground-water monitoring requirements, the waste
management area is described by the waste boundary. By analogy, the down-
gradient side of the circumscribing boundary lines at the Model City facil-
ity should be the waste boundaries (with allowance for containment struc-
tures), which is where the wells should be installed.
At FPA I [Figure 10], the designated downgradient Zone 3 wells (revised
MMCP) are W-4A, B-38A and B-lll. Of these, B-38A is not close enough to
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90
the adjacent waste management unit (the fire pond, which is currently used
as a facultative pond). Zone 1 wells, located to detect leakage from FPA I
units, include Z-9, Z-12, Z-13, and Z-14. Of these, Z-14 is not suffi-
ciently close to the adjacent waste management unit. Further, the number
of wells is not sufficient to immediately detect leakage from all or major
portions of the following units:
1. Facultative pond 1
2. Facultative pond 2
3. SLFs 1 through 6
4. Facultative pond 3
At FPA II, the designated downgradient Zone 3 wells are B-21A, 8-49A
and B-112. Of these, only B-49A is downgradient from any of the waste man-
agement units and it is about 100 feet from the nearest unit (north salts
area). Well B-112 was removed during drainage improvement work in 1983 and
currently does not exist. None of the Zone 1 wells, located downgradient
from FPA II units, including 1-6, 2-7, Z~8 and Z-16, are close enough to
the waste management units. The number of wells is not sufficient to imme-
diately detect leakage from all or major portions of the following units:
1. North salts area
2. Lagoons 1, 2, 5 and 6
3. Salts area 7
4. Tank 58
At FPA III, the designated downgradient Zone 3 wells are B-34A, B-43A,
B-113 and 8-114. Of these, only B-113 and B-114 are at the limit of the
waste management area. The three waste management units in this FPA share
common dikes and are essentially one unit so that all have at least one
well located downgradient for leak detection. The average space between
the wells is about 425 feet, which may not ensure immediate detection of
leakage, as suggested by modeling conducted by an SCA consultant* during
Seซ section on "Ground-Water Monitoring Program Proposed for RCRA Permit".
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91
the spring of 1985. Zone 1 wells that could detect leakage from FPA III
units include Z-l, Z-2 and Z-12. Well Z-12 is in FPA I, as previously
noted. Neither Z-l nor Z-2 is at the waste management area boundary; they
are the width of a road (about 50 feet) away.
At FPA IV, which includes only SLF 7, the designated downgradient Zone
3 wells are B-228 and B-84B. Of these, only B-848 is at the limit of tne
waste management area and is clearly downgradient. A potentiometric map of
the glaciolacustrine silt/sand (Zone 3), contained in the March 1985 hydro-
geologic report by Colder Associates, suggests that well B-228 would not be
in the flow path of any Teaks emanating from SLF 7. Further, B-22B is about
125 feet west of the SLF 7 perimeter dike. Zone 1 wells, located to detect
leakage from SLF 7, include Z-3, Z-4, Z-5 and Z-21. All are sufficiently
close to the landfill.
Finally, at FPA V, which includes only SLF lla at present, the desig-
nated downgradient MMCP and operating permit* wells are B-32A, B-115 and
B-116. None are at the limit of the waste management area; the wells are
*
about 50 feet away. The average spacing between the wells is about 350
feet (300 and 400 feet), which may not ensure detection of leakage as sug-.
gested by site modeling conducted by an SCA consultant (discussed in the
RCRA Permit section). There are five Zone 1 wells, near SLF lla, as
required by the permit (Z-3, Z-19, Z-20, Z-21 and Z-22). Wells Z-3, Z-21
and B-32A are so close to SLF 7 that they may not be effective monitors for
leakage from SLF lla. The well network to be constructed in the near future
should allay this problem.
SCA SAMPLE COLLECTION AND HANDLING PROCEDURES
During the inspection, samples were collected from 17 wells for analy-
sis by an EPA contractor laboratory. At each of these wells, SCA personnel
also collected samples using their standard procedures, which were observed
by Task Force personnel. With the exception of filtering of most sample
Includes MOE and Citizen Intarvanor agreements
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92
aliquots and disposal of purge water, the SCA (WMI) procedures for sample
collection, documentation, handling, preserving, shipping and chain-of-
custody were acceptable. The procedures also conformed to those described
in relevant parts of the "WMI Manual for Groundwater Sampling" and the "SCA
Quality Assurance Plan for Groundwater Monitoring", previously discussed
(i.e., Company personnel were following the developed .plan).
The Company has a training program to ensure that the procedures are
properly and uniformly implemented. Model City personnel received 2 days
of sampling training by CWM staff during the spring of 1985. Each CWM and
SCA facility reportedly has staff or contractors dedicated to environmental
monitoring so that only trained people do the work, thereby assuring more
consistency in sampling. The general sampling procedure used at each well
is described in the Investigation Methods section of this report. Some of
the details are described and evaluated here.
At the well head, the first step in the sample collection procedure is
to measure depth to water through the Geomon access port (the surveyed
reference point). Next, the volume of water in the casing is calculated
using the depth to water measurement, total well depth (from construction
records) and casing diameter. Purge volumes are calculated by multiplying
the volume of water in the casing by three.
The volume of water calculation does not involve subtracting the space
occupied by the sand-pack inside the casing around the Geomon sampler.
Therefore, more than three times the volume of water actually inside the
casing were removed, but how much more is not known as no records of the
sand pack, if any were kept, are consulted. The procedure itself is satis-
factory; however, it is not documented in the revised MMCP, Quality Assur-
ance Manual or the corporate monitoring plan. A change in sampling person-
nel could result in different procedures being followed, resulting in dif-
ferent variabilities in the data.
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93
Water purged from the wells is discharged to the ground nearby. This
is not a good practice as the water may contain contaminants and remedial
action or appropriate closure may be required for the affected areas.
Field measurements were being satisfactorily performed for pH, specific
ฎ
conductance and temperature with a Hydac meter. Following purging of each
well at the beginning of sample collection, a small (about 250 m2) plastic
beaker is rinsed three times with water discharged from the well, then
filled for taking the field measurements. Each measurement is repeated
four times with the meter probe rinsed with deionized water and dried with
a disposable laboratory wipe between each reading. The results are recorded
on a field record form (CC-2) provided by the contractor laboratory. The
field meter is calibrated every 4 hours or 10 wells, whichever comes first.
After making the field measurements, samples are collected for analysis
by the SCA contractor laboratories. SCA practice is to fill sample bottles
for "total" type analyses (e.g., total organic carbon and total organic
Halogen) and volatile organics directly from the Geomon teflon discharge
line. Samples for all other analyses, including extractable organics, are
initially pumped into either new 1-gallon amber glass jugs or 1-liter plas-
tic bottles (called "filtration bottles") depending on the analyses to be
conducted. The sample in the filtration bottles is taken to an onsite
laboratory where it is placed in a teflon-lined pressure vessel and run
through a 142 millimeter diameter, 0.45 micron filter, into the appropriate
sample container.. Samples are to be filtered and preserved within 2 hours
of col lection.
Filtering of the samples for organics and metals is unacceptable.
Filtering of sample aliquots for organics analysis contradicts a May 3,
1985 statement by the DEC recording "Policy on Altering Water Samples to be
Analyzed for Organic Compunds" [Appendix E]. Although EPA has no formal
Hydac is a registered trademark hereafter used without the ฎ.
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94
policy on filtering samples for organics and metals, the Agency is on
record as opposing such practice.* The principal objection is that the
results may be biased low.
The sample bottles are all prepared by the principal contractor labor-
atory, ETC, in Edison, New Jersey, to ensure uniform procedures. The bot-
tles are pre-labeled for the required parameters from each sampling point
and shipped to the facility in sealed "shuttles" together with the required
documents for sampling (chain-of-custody and field record sheets - documents
CC-1 and CC-2, respectively). Pre-measured preservatives for each sample
bottle are either shipped in the bottle or in small vials attached to it.
Once the samples are collected, filtered (where done) and preserved,
they are placed in the shuttles, which are insulated containers with fitted
plastic foam inserts for the bottles. Then, "blue ice" packs, frozen in an
onsite freezer, are placed in the shuttles to cool the samples during ship-
ment. After completing and enclosing the sampling documents, the shuttle
is secured with, a numbered plastic seal and shipped to the laboratory.
SAMPLE ANALYSIS AND DATA QUALITY EVALUATION
This section provides an evaluation of the quality of interim status
ground-water monitoring data gathered by SCA between November 1981 and July
1985 when the Task Force inspection was conducted. Analytical procedures
for ground-water samples and data quality were evaluated through laboratory
inspections and review of documents containing the required monitoring data.
The SCA onsite laboratory and two SCA contractor laboratories were eval-
uated in mid-July 1985. The evaluations included 'reviewing laboratory"
June 1985, Memorandum Number 7 by David Friedman, "Notes on RCRA
Methods and QA Activities" and recent Agency decisions on ground-water
analyses conducted by Hooker at Lava Canal in New York
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95
operating and analytical procedures, internal data reports, raw data and
quality control records; interviewing key laboratory personnel; and inspect-
ing analytical equipment.
The inspection revealed that pre-1985 data were often of poor analyti-
cal quality, incomplete and inadequate. Data derived from present (July
1985) laboratory procedures are much improved although some analytical
inadequacies still exist.
Most of the ground-water samples collected between 1981 and early 1985
were analyzed at the SCA onsite laboratory. Radiation analyses were per-
formed by Control for Environmental Pollution, Inc., in New Mexico and fecal
coliform analyses were performed by ACTS Laboratory in New York. Pesticide
and herbicide analyses were performed by the onsite laboratory; the SCA
Research and Development Laboratory in Buffalo, New York; and Ecology and
Environment, Inc., also in Buffalo. The majority of the volatile and semi-
volatile organic analyses were performed by the SCA Research and Development
Laboratory and' Ecology and Environment, Inc. Mead Compuchem -in North
Carolina occasionally performed some organic analyses.
Presently, Environmental Testing and Certification (ETC) Laboratory in
New Jersey is responsible for all ground-water analyses; however, sampling
personnel perform pH, conductance and temperature measurements in the field.
ETC subcontracts metals and other (chloride, sulfate, phenol, etc.) analyses
to General Testing Laboratory in New York and radiation analyses to Core
Laboratories in Wyoming.
Monitoring Under the EPA/RCRA Program (1981-1983)
In November 1981, SCA initiated quarterly monitoring, p rsuant to
265.92(c) on the RCRA well network. As previously noted, the network com-
prised four wells including B-35 (upgradient), B-22, B-42 and B-49. f:our
quarterly monitoring reports, two semiannual reports and associated labora-
tory records were reviewed for this well network. The reports were found
to lack some of the required data and contained biased or suspect data.
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96
RCRA regulations [265.92(c)] require quarterly monitoring for the first
(initial) year of all wells to establish background concentrations or values.
Quarterly monitoring of the upgradient wells must include quadruplicate
measurement of the four parameters used as indications of ground-water con-
tamination (pH, specific conductance, TOC and TOX). After the first year,
each well must be sampled at least semiannually.
All the analyses required during the initial year of monitoring (Novem-
ber 1981 to October 1982) were not performed. TOX data were not obtained
for the first two quarters and no TOX data were reported for the second
semiannual monitoring for the upgradient well. The first quarterly report
contained no data for endrin, lindane, methoxychlor and toxaphene for well
B-35 and most parameters were not determined for B-42. The first semiannual
monitoring report contains no data for any of the drinking water parameters
[265.92(b)(l)]. The first quarterly report contains no data for five'of
the six ground-water quality parameters [Part 265.92(b)(2)] for well B-42
and the first semiannual report contains no data for any of these parameters.
Quadruplicate measurements of the four indicators' parameters for each
sample were often not obtained. For example, in the third quarter, TOC
values ranging from 4 mg/ฃ to 97 mg/ฃ were reported for well B-49 and pH
values of 7.2 to 8.1 were reported for well B-22. Data reported for well
B-22 in the second semi-annual report for pH ranged from 7.47 to 8.27 and
conductance ranged from 1,121 uhmos/cm to 4,313 uhmos/cm. These ranges
were not obtained from replicate analyses of a sample but from analyses of
a number of samples.
Some data were derived from samples collected before or after the mon-
itoring period and from wells other than the designated wells. For example,
data for samples collected on May 11, 1983 and December 9, 1983 are reported
in the semiannual report for the period May 19, 1S33 to November 19, 1983.
This report also contains data for both well B-49 and well B-49A, all
reported as data for well B-49. In the first quarterly report, data for
samples collected from well B-84 are listed with data for well B-42, as
previously noted.
-------
Large variations in parameter concentrations and values were noted in
the SCA ground-water sampling results. Most of this variability is attrib-
uted to sample handling and/or laboratory procedures, rather than actual
changes in ground-water quality. For example, duplicate pH measurements
for a sample collected from upgradient well B-35 on March 11, 1983, were
7.63 amd 7.12. Good duplicate measurements should vary by no more than 0.1
pH units.
Conductance values of 1,210 and 5,550 umhos/cm were reported for the
first and second quarters, respectively, for well B-22. The first and
second quarter chloride concentrations for this well were 1,700 and 1,260
mg/2, respectively. Conductance should be greater than the sum of the major
cation and anion concentrations; in this case, the conductance for the first
quarter sample is less than one of the major anion concentrations.
Similarly, analytical or reporting error is probably the cause of out-
lier sodium values obtained during the second quarter. For example, in
well B-49 samples, sodium 'concentrations for the four quarters were 260,
0.16, 125 ad 190 mg/2, respectively. The second quarter sodium concentra-
tions for all wells were less than 1 mg/ฃ. All of the subsequent SCA data
are consistent with the higher values. For the second semiannual samples,
a sodium concentration of 4,750 mg/2 is reported for well B-49, which is
about twice .the conductance value of 2,400 umhos/cm.
TOC concentrations were determined with a method that was inappropriate
for the organic carbon levels present and the samples analyzed were filtered.
Thus, only dissolved organic carbo.n was determined. The organic carbon was
calculated from the difference between total carbon and inorganic carbon
determinations. When the inorganic carbon makes up most of the total carbon,
the analysis variability becomes a signif'.cant factor and results in large
systematic biases., TOC should have been determined by measuring nonpurgable
organic carbon and purgable organic carbon. Systematic errors are evident
in the data between quarters for a well. For example, the average values
reported for the second and third quarters for well B-35 were 36 mg/2 and
1.5 mg/ฃ, respectively.
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98
The TOX data reported for the third and fourth quarters of the initial
year of monitoring are suspect because of the large differences observed
between quarters. Systematic bias is suggested by the data for wells B-42
and B-49. TOX values of 3.6 ug/2 and 63.6 ug/2, respectively, were reported
for well 'B-42 while <0.1 ug/2 and 110 pg/2 were reported for well 8-49.
Experience indicates that the best detection limit achievable by the TOX
method is about 5 ug/2. The variation in the quadruplicate measurements
made on each of the third and fourth quarter samples for well B-35 indicate
that the detection limit actually achieved in the analyses was about 30
ug/2. The TOX averages for the third and fourth quarters for well B-35 (23
ug/2 and 8.6 ug/2, respectively) and the third quarter for wells B-42 (3.6
ug/2) and 8-49 (<0.1 ug/2) are lower than the detection limit and, there-
fore, unreliable.
State and EPA regulations require analysis of ground-water samples for
total organic Halogen. The analytical method used to measure total organic
Halogen concentrations is called total organic halide (TOX).* During the
"the first year of monitoring, SCA performed an analysis that was called
total organic Halogen (TOH). Although the analytical method has the same
name as the required monitoring parameter, they are different. In the
quarterly reports, TOH results were inappropriately mixed with TOX results.
The TOH analysis method evolved from a screening test for PCBs required
by the State and consisted of analyzing a solvent extract by gas chromatog-
raphy. By contrast, the TOX analysis method involves absorption of organics
on activated carbon, combustion of the activated carbon, and coulometric
titration of the evolved halides. TOH results, therefore, are not equiva-
lent to TOX results and do not satisfy the regulatory monitoring require-
ments for TOX.
Samples collected for the eight metals on the drinking water parameter
list [265, Appendix III] were filtered before analysis, thereby generating
data for dissolved metals instead of total. Drinking water standards are
EPA publication SV-846, "Test Methods for Evaluating Solid Waste,"
July 1982, Method 9020
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99
based, however, on total metals [40 CFR Part 141.23(f)]. Therefore, the
SCA analytical methods are not consistent with those required for drinking
water supplies.
The methods used to determine arsenic, chromium and selenium resulted
in unreliable data. Arsenic and selenium were determined without digestion
by hydride generation atomic absorption spectroscopy. EPA-approved hydride
generation methods require digestion. Chromium was determined with an
inappropriate oxidant in the fuel/oxidant mixture for the flame atomic
absorption spectroscopy analysis. EPA methods specify nitrous oxide/
acetylene while SCA used air/acetylene. The practices cause results to be
biased low.
The flame atomic absorption spectroscopy methods, used by SCA, for
cadmium, chromium and lead did not achieve reliable results near the drink-
ing water limits for these parameters. For example, in 1983, an EPA per-
formance evaluation sample containing 0.38 mg/2 lead was analyzed and a
value of 0.17 mg/2 was obtained. Similarly, in 1982, an ,EPA sample con-
taining 0,70 mg/2 chromium was analyzed and a value of 0.47 mg/2 was
obtained. Detection limits commonly given in SCA laboratory records were
about 0.02 mg/2 to 0,04 mg/2 for cadmium, 0.1 mg/2 to 0.2 mg/2 for chromium
and 0.1 mg/2 to 0.3 mg/2 for lead. The drinking water standards for cad-
mium, chromium and lead are 0.01 mg/2, 0.05 mg/2 and 0.05 mg/2, respectively.
Much of the Gross Alpha and Gross Beta data could not be used to deter-
mine the suitability of the ground water as a drinking water supply. The
confidence intervals reported with the data are frequently larger than the
measured values or render data so imprecise as to preclude meaningful com-
parison with the drinking water limits. The analyses should have had longer
counting periods to obtain better confidence intervals.
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100.
Initial Year of Monitoring Under State Program
(March 1984 Through February 1985)
In March 1984, the first year of monitoring under State regulations
was started. The first three quarterly reports and supporting laboratory
records revealed that data for many of the wells are inadequate for estab-
lishing background levels. The laboratory findings discussed above are
also applicable to these quarterly data, as most of the methods did not
change.
Present Laboratory Procedures (July 1985)
Some inadequacies in the present laboratory procedures were found.
One major inadequacy is that samples for semivolatile organics, pesticides
and herbicides are filtered prior to extraction. This practice may result
in data biased low for these parameters. Similarly, samples are filtered
before metal analyses; thus, dissolved instead of total, metals arfc
determined. .
ETC Method GC/MS-1-002 for base, neutral and acid extractable organics,
pesticides and PCBs is not recommended by the Task Force for analysis of
ground-water samples for pesticides and PCBs. The detection limits achieved
for the pesticides and PCBs by this method are about 50 times higher than
those achieved by gas chromatography-electron capture detector methods.
The flame atomic absorption spectroscopy methods used to determine
cadmium, chromium and lead do not reliably measure levels near the drinking
water limits for these parameters. Detection limits indicated in Company
records were at the drinking water limits. Measurements near the detection
limits are not reliable because of htgh variability. These analyses need
to be performed by furnace atomic absorption spectroscopy.
The analytical procedure for TOC is incomplete because the results
represent only nonpurgable organic carbon. Samples are acidified and purged
with nitrogen gas prior to determination of organic carbon, which results
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101
in the loss of purgable (volatile) organic carbon. Analysis must be made
for purgable and nonpurgable organic carbon and the concentrations summed
to calculate a result for total organic carbon.
ETC performs TOX analyses near an area where samples are extracted
with methylehe chloride. This practice is cautioned against by the instru-
ment manufacturers as the activated carbon used in the TOX analysis is
highly susceptible to contamination by fugitive organic vapors. Data from
ETC activated carbon blanks indicates a detection limit of about 20 ug/Ji
was achieved on samples. TOX analyses need to be performed in an area iso-
lated from the use of solvents. After the Task Force inspection, ETC
reportedly moved the TOX analytical equipment to an area isolated from s,ol-
vent handling.
GROUND-WATER ASSESSMENT PROGRAM AND OUTLINE
Data derived from samples obtained during the initial year of monitor-
ing under RCRA regulations and the first semi-annual samples triggered
assessment monitoring at the Model City facility. SCA submitted an Assess-
ment Plan to EPA, implemented that plan and prepared a report that presented
findings and specified additional necessary work.
During the conduct of the Assessment Program under RCRA, New York
received Interim Authorization. Soon after delegation, SCA began the
initial ye'ar of monitoring on the MMCP wells for which assessment had not
been triggered. Under the State requirements, the assessment program out-
line is contained in the revised MMCP.
The following discussion addresses significant events pertaining to
the Assei^ment Program conducted under RCRA regulations to explain the cur-
rent status and provides an evaluation of the revised MMCP Assessment Pro-
gram Outline.
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102
Assessment Program Under RCRA
During the initial year of monitoring under RCRA (November 1981 -
October 1982), the RCRA regulations [265.92(c)] required the Company to
develop a background database. Background data is derived from samples
taken quarterly for one year (initial year); after the initial year, samples
for indicators of ground-water contamination (indicator parameters) are to
be collected semi-annually. If statistically significant differences
between the background data for indicator parameters from upgradient wells
and subsequent data from downgradient wells are identified and confirmed,
an assessment program is required [265.93].
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103
Assessment monitoring was triggered at the Model City facility by tfte
first semi-annual samples (for the period November 1982 to May 1983) for
the following wells and parameters:
Well Parameters
B-22 Specific conductance and TOX
8-42 pH
B-49 pH
On June 20, 1983, SCA transmitted an Assessment Program Plan to EPA
Region II, which presented a two-phase approach. The objective of the f^rst
phase was to determine or explain the differences in ground-water quality
during the interim status ground-water monitoring program. If hazardous
waste or hazardous constituents (contaminants) were detected, a second-phase
study would be conducted to determine the rate and extent of contaminant
migration and contaminant concentrations, as required by 40 CFR Part
265.93(d)(4).
The Assessment Program Plan stated that the elevated pH and specific
conductance values had been sufficiently explained in a May 6, 1983 letter
to EPA and no further work was planned. The letter attributed the high
values to natural variations in water quality. Although the explanation is
plausible, the poor quality of the data (previously discussed) makes the
conclusion suspect.
The plan focused on verifying the high TOX value in B-22. A new well,
RB-22 was to be constructed and, together with B-22, sampled for volatile
organic priority pollutants. The resulting data would be compared to
similar data from SLF 7 leachate and evaluated.
An Assessment Program Report on Phase 1 studies was submitted to EPA
16 months later, on October 15, 1984. The report stated that samples from
B-22 and RB-22 (designated in the report as B-22A) had unspecified anomalous
pH values; well B-22A was subsequently replaced with B-228. Volatile
organic priority pollutants were not detected in either B-22 or B-22B. The
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104
report further stated that the anomalies in pH data from wells 8-22 and
B-22A would be investigated.
In June 1985, just before the Task Force inspection, Region II issued
a complaint/compliance order to SCA, based on State regulations, for defi-
ciencies in the assessment plan and report. The complaint cited violations
of requirements to:
1. Notify the State Commissioner of the statistical increase of
certain indicator parameters
2. Prepare a plan that specifies (1) the number, location and depth
of wells, (2) sampling and analytical methods, and (3) implemen-
tation schedule
3. Determine the rate and extent of migration
4. Determine the concentration of hazardous waste or hazardous waste
constituents in ground water
5. Submit the assessment report as soon as technically feasible
6. Submit an AnnuaV Report to the State Commissioner containing the
assessment program results
Substantive discussions on the order were not begun until after the
Task Force inspection. A consent agreement addressing the violations noted
in the complaint was completed on September 30, 1985.
MMCP Outline for the Ground-Water Qua!ity.Assessment Program
The outline for the ground-water quality assessment program, presented
in the revised MMCP is incomplete. The outline should describe a more com-
prehensive ground-water monitoring program than the program in place.
One-half page-of narrative in the revised MMCP (page 111-42) presents
the assessment program outline. The narrative states that, initially, the
source of the contamination will be identified and isolated. This will be
accomplished by (1) increasing the parameter analysis specific to the likely
source area, (2) obtaining soil samples in a grid pattern between the source
-------
105
area and contaminated well, (3) placing additional wells to evaluate the
extent of contamination and (4) increasing the sampling frequency.
Further, the revised MMCP states that contamination would likely be
first detected in Zone 1 (which was not defined as the uppermost aquifer by
SCA during the inspection); therefore, initial efforts would be in defining
contamination in that zone. If data suggest contamination in Zone 3, addi-
tional monitoring wells would be installed.
The MMCP outline needs to be revised to include:
1. Whether or how data triggering assessment would be evaluated to
confirm the apparent contamination
2. How the apparent source would be determined
3. Whether or how additional hydrogeologic data would be collected
4. How the rate and extent of contaminant migration would be
determined
5. Which aquifer zones would be monitored
6. How a monitoring plan would be developed and what the projected
sampling frequency would be
7. Which analyses would be conducted on ground-water and soil
samples to identify contaminants of concern
8. Analytical methods to be used on the samples
9. How the data would be evaluated to determine if more work is
required or the facility could return to the indicator evaluation
program
10. Approximate time frames for sampling, analysis, data evaluation
and report preparation
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106
GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT
In August 1983, SCA submitted the ground-water monitoring portion of
the Part B RCRA permit application to EPA Region II; a copy was also pro-
vided to DEC as the State-issued General Operating Permit for the facility
was due to expire the following May.* Through a series of meetings between
EPA, DEC and SCA, the Company was informed of deficiencies in the proposed
program. Among these deficiencies were the following:
1. Number and location of wells inadequate
2. Site hydrogeologic characterization inadequate
3. Compliance boundary not adequately defined
4. Choice of indicator parameters not justified
5. Statistical techniques not acceptable
6. Use of downgradient wells as background wells unacceptable
7. Use of air-lift apparatus unacceptable
8. Geomon devices may not be acceptable, use not adequately
justified
9. Methods for determining ground-water flow rates are unacceptable
10. Sample collection procedures unacceptable
No substantive revisions were made in the Part B ground-water monitor-
ing program until after the CWM takeover in late 1984. In the spring of
1985, SCA submitted the three following documents as a revision to the
Part B application:
1. Hydrogeologic Characterization, Chemical Waste Management, Inc. ,
Model City,, New York Facility, dated March 1985 by Colder
Associates
2. Evaluation of Groundwater Monitoring Data, Chemical Waste Manage-
ment, Model City Facility, dated April 1985 by Golder Associates
3. Groundwater Monitoring Plan, Chemical Waste Management, Inc. ,
Model City, New York Facility, dated May 1985 by Golder Associates
Under State law, the permit remains in effect after e.xpiration until
a new one is issued. The permit expired in May 1984 and is being
revised by DEC.
-------
107
The information presented in these documents is required by RCRA regulations
[Part 270.14(c)(l) through (6)] for a Part B application and the State for
reissuance of the General Operating Permit.
The documents listed above proposed a new ground-water monitoring pro-
gram, including a completely new well network. This program was the princi-
pal subject of the ongoing meetings between DEC, EPA, CWM personnel and
their consultant, Colder Associates, just before the Task Force inspection.
Although final plans had not been made before the end of the Task Force
inspection, there was agreement between the parties on locations and depths
for most of the proposed wells (about 70 new wells will be installed). A
principal area of disagreement, involving the spacing between wells, was
ป
resolved just before the Task Force inspection. Because the issue relates
to many other sites which the Task Force is evaluating, the resolution pro-
cedures will be briefly discussed.
The Company's consultant used recently acquired and historical hydro-
geologic data for the site to -develop computer simulations of several types
of possible leaks to evaluate potential pathways, rates of travel and pro-
jected plumes for different periods after the leak started. Government
modeling experts, consulted about the model used, recommended further sensi-
tivity analyses be conducted before it could be endorsed as a useful tool.
These were done to the Government's satisfaction along with plume projec-
tions for additional time intervals.
Initially, the consultant based well spacings on projected plume
widths at the edge of a waste unit 120 years after a leak started. Govern-
ment personnel opted for a 40-year period based on a 10-year operationa.1
life for the regulated unit fol^wed by a 30-year post-closure monitoring
period. The computer projections were based on man^ conservative assump-
tions about the site, some of which diverge from reality over time (e.g. ,
assuming steady-state conditions during the long periods modeled). Con-
sequently, the computed distances were used as a starting point for deter-
mining well spacings.
-------
108
Final well spacings were determined after considering several factors
including actual time each unit had been in service, types of liners pres-
ent, results of ground-water monitoring to date and natural variations in
site hydrogeology which were not accounted for by the model. Also, allow-
ance was given for internal dikes in a landfill where those dikes inter-
sected the perimeter dike on the downgradient side (spacing was calculated
on the basis of the width of each cell's floor).
Major unresolved issues addressed during the fall of 1985 included:
1. Whether the groundwater beneath the site has been contaminated by
site operations, thereby requiring a compliance monitoring program
instead of the program SCA has proposed for detection monitoring
2. Whether certain regulated units (tank 58 and the facultative ponds)
arซr subject to the RCRA ground-water monitoring requirements
3. Whether any filtering, of sample aliquots will be allowed
4. Which indicator parameters or hazardous waste constituents will
be selected for monitoring
5. Which analytical methods will be used for measuring detection
monitoring indicator parameters
6. What statistical procedure will be used to evaluate the impact of
the regulated units on the ground water
-------
109
MONITORING DATA ANALYSIS FOR INDICATIONS OF WASTE RELEASE
This section presents an analysis of both Task Force and SCA monitoring
data regarding indications of apparent or potential leakage from the waste
management units. Analytical results from and methods used on samples col-
lected by Task Force personnel are presented in Appendix F.
Task Force data indicate the presence of organic hazardous waste con-
stituents in three Zone 1 wells [Table 22}. The compounds are identified
as waste constituents because they are present in leachate in landfills
either near the wells or at the facility. The waste constituents detected
in well Z-3 have been previously detected and confirmed by SCA. Both Taisk
Force and SCA data indicate these compounds are present in leachate in SLF 7
[Appendix F, Tables F-9 and -10], which is adjacent to Z-3.
Table 22
HAZARDOUS WASTE CONSTITUENTS
DETECTED IN SAMPLES FROM MONITORING'WELLS3
Compound Well Z-3 Well Z-ll Well Z-13
1 , 1-Di chl oroethy 1 ene
Trans- 1,2-dichloroethylene
Tri chl oroethy 1 ene
a-BHC
p-BHC
Y-BHC (lindane)
Aroclor 1242 (PCS)
320 'd
130. d
< 0.1
< 0.1
< 0.1
< 0.5
a. Concentrations in ug/2
b Control measures indicate value
< 7.c
< 7.
< 6.
0.29^
0.21*
0.18*
< 0.3
is within
< 7.
< 7.
< 6.
0.23?.
0.40?
0.15*
0.6d
50% to 150%
of actual concentration at 95% confidence
< X denotes sample concentration is less than X at 99%
confidence
Control measures indicate value is within 75% to 125%
of actual concentration at 95% confidence
The 8HC isomers found in wells Z-13 and PCS in well Z-ll have not been
previously detected in those wells; however, the concentrations are very
low (less than one microgram per liter - ug/ฃ). The low concentrations are
well below the detection limits used by the SCA contractor laboratory.
-------
110
Task Force data show that these compounds are also present In leachate
samples collected from SLF 4, which indicates the facility has received
wastes containing these compounds. PCBs have been detected by SCA in the
west salts area, which is adjacent to Z-13.
SCA and Task Force data indicate elevated TOX concentrations (i.e.,
greater than 100 ug/ฃ)* in seven Zone 1 wells [Table 23]. These elevated
TOX concentrations indicate the presence of halogenated (containing
chlorine, bromine or iodine) organic compounds.1 2 Their presence is sig-
nificant because most halogenated organics are suspect of being toxic or
carcinogenic and they rarely occur in nature.3 The compounds composing the
measured TOX were not identified, except for well Z-3, by the standard
methods used on Task Force samples, nor have they been identified by SCA,
whose methods are essentially the same. High concentrations of many halo-
genated organic compounds are present in the leachate [Appendix F, Tables F
9 and 10]. The TOX "indicator" test can detect these compounds at low
'levels, where the analytical- methods used to identify compounds in the
leachate and 'well samples may not be sensitive to them.2 3 4 5 Special or
research-type methods may be required to identify the compounds.
Of the wells where elevated TOX concentrations are indicated, Z-3 is
adjacent to SLF 7 and known to contain hazardous waste constituents.
Leachate levels, base elevation and water table elevations at SLF 7 (see
page 40 and Table 15) indicate periods of outward hydraulic gradient which
The TOX value of 100 ug/2, used as a benchmark for identifying elevated
concentrations, was based on the referenced literature, two data sets
and professional judgment. The first data, set included SCA quarterly
monitoring data collected between March and November 1984 and contains
81 TOX values. Seventy of these are less than 100 ug/ฃ; 11 are greater.
For the 70 zneasureoents, the concentrations range from 10.2 to 95 ug/ฃ
and average 58.4 ug/jU. For the 11 measurements greater than 100 pg/ฃ,
concentrations range from 100 to 797 ug/ฃ and average 271 ug/2. The
11 values are from 7 wells, all of which are in Zone 1. Secondly,
leterature reviewed contained data for samples collected from 22 water
supply wells in the United States. Concentrations ranged from less
than 5 to 85 ug/ฃ, with an average of 18 ug/&.2 The value of 100 ug/ฃ
is, therefore, considered to be conservative benchmark concentration.
-------
Ill
would promote leakage from the landfill. Well Z-6 is near the 01 in Burn
Area and may be reflecting pre-RCRA releases at the site.
Table 23
TOX CONCENTRATIONS IN SELECTED WELLS
(concentrations in pg/2)
Well
2-3
Z-6
Z-8
z-io
Z-ll
Z-12
Z-19
First
Quarter
3-5/84
_c
-
342
408
-
186
-
Second
Quarter
6-8/84
215
-
-
-
134
-
84.4
Third
Quarter
9-11/84
331
100
148
797
-
218
105
s
6/85ฐ
220
-
130
365
96
210
73
Task
Force
278
-
96
-
67
a Quarterly monitoring data from April 1985 report by Golder Associates
titled "Evaluation of Groundwater Monitoring Data, Chemical Waste Man-
agement, Model City Facility".
b The June 1985 data are from a September 24, 1985 letter report to Mr.
Richard M. Walka of EPA Region II from Mr. Johan Bayer of CVM regarding
"Final Groundwater Assessment Seport: SCA Chemical Services Model
City, New York".
c Dash (-) indicates no data reported
Well Z-8 is about 75 feet west of lagoon 6 and salts area 7, both of
which contained liquid hazardous waste and had outward hydraulic gradients,
as discussed in the section on Waste Management Units. The location is
also hydraulically downgradient from the old west drum storage area where
spills have been reported.
Well 10 is adjacent to (or in) the pre-RCRA Town of Lewiston salts
area, which was used to store sludge from the aqueous waste treatment system.
Wells Z-ll and Z-12 are both adjacent to Facultative Pond 3 and across the
street from SLF 10, \.iich are potential srurces of the organic halogen
compounds.
Well Z-19 is at the northwest corner SLF lla. Elevated TOX concentra-
tions were noted before waste disposal began in that landfill. Potential
-------
112
sources of the organic halogens include the 01 in Burn Area, the old north
durm storage area and SLF 7.
Additional work is necessary by SCA to identify the specific halo-
genated organic compounds being detected by the TOX analyses and their
sources. Once these compounds are identified, samples from the other wells
should be analyzed for them as TOX concentrations of less than 100 ug/2 in
current SCA data may represent analytical error, the presence of halogenated
organic compounds or both.
-------
REFERENCES
1. Environmental Protection Agency, Test Methods for Evaluating Solid
Waste, Revision B to SW-846, July 1981.
2. Stevens, Alan A.; Dressman, Ronald C. ; Sorrel!, R. Kent; and Brass,
Herbert J. ; "Tax, is it the Non-Specific Parameter of the Future?",
EPA-600/D-84-169, June 1984.
3. Takahashi , Y. ; Moore, R. T. and Joyce, R. J. ; Measurement of Total
Organic Halides (TOX) and Purgeaole Organic Halides (POX) in Water
Using Carbon Adsorption and Microcoulometric Determination, Chemistry
in Water Reuse, Vol. 2, 1981.
4. Riggin, R. M.; Lucas, S. V.; Lathouse, J.; Jungclaus, G. A. and Wensky,
A. K. , Development and Evaluation of Methods for Total Organic Halide
and PurgeaJble Organic Halide in Wastewater, EPA-600/4-84-008, June
1984.
5. Glaze, William H. ; Peyton, Gary R. and Rawley, Richard, Total Organic
Halogen as Water Quality Parameter: Adsorption/Microcoulometric Method,
Environmental Science & Technology, Vol. 11, No. 7, July 1977.
-------
,
- - !-1N
ป- * ,: rf
>^ ; *?ซ
APPENDICES
A ? SOLID/HAZARDOUS WASTE PERMITS ISSUED FOR MODEL CITY FACILITY
B PCS DISPOSAL APPROVALS ISSUED BY U.S. EPA, REGION II
C AGREEMENTS AND STATE ORDERS RELATING TO SOLID WASTE MANAGEMENT
,D;>i!tSIER.FROM DEC TO EPA ON DEFICIENCIES IN PART B PERMIT APPLICATION
POLICY VNi.'ALTERING SAMPLESi TO BE ANALYZED FOR ORGANIC COMPOUNDS
RESULTS FOR>ASK FORCE SAMPLES
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-------
APPENDIX A
SOLID/HAZARDOUS WASTE PERMITS ISSUED FOR MODEL -CITY FACILITY
-------
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-------
APPENDIX B
PCS'DISPOSAL APPROVALS ISSUED BY U.S. EPA, REGION II
-------
B-'
PCS DISPOSAL APPROVALS ISSUED BY U.S. EPA, REGION II
Issue Date
Expiration Date
Facility Unit
Comments
October 2, 1978
February 6, 1980
June 19, 1981
December 8, 1981
April 27, 1982
June 4, 1982
January 28, 1985
October 2, 1981
April 27, 1985
SLF 7 Operation of unit
SLF 7 Modification of unit
SLF 7 Expansion of unit
SLF 7 Leachate collection
approval
SLF 10 Operation of unit
SLF 10 Leachate collection
approval
SLF Ha Operation of unit
-------
APPENDIX C
AGREEMENTS AND STATE ORDERS RELATING
TO SOLID WASTE MANAGEMENT
-------
C-1
Appendix C
AGREEMENTS AND STATE ORDERS FOR
SCA MODEL CITY FACILITY
Date
File No.
Comments
Wastewater Management
73-94 Cleanup of Four Mile Creek, submittal of
SPCC Plan, penalty payment
Cleanup of releases, penalty payment,
notify DEC of releases
Penalty payment, failure to comply with
76-35
Penalty payment, failure to comply with
76-35
Penalty payment, failure to comply with
76-35
Upgrade of treatment system and other
remedial actions, operation requirements
Modification to above
Modification to File No. 0-0291
Suspension of operation of Facultative
Pond 8, notice of intent to suspend
permit, reopening of NPOES permit hearing
Modification of effluent limits, study to
upgrade treatment system, modified moni-
toring requirements
Modification to File No. 0-0291
August 5, 1974
February 28, 1977 76-35
January 9, 1978 76-35A
April 25, 1978 76-358
July 6, 1978 76-35C
November 13, 1978 0-0291
October 22, 1979*
November 5, 1980 80-86
January 9, 1981
March 31, 1982**
May 24, 1983* 80-76
* Date the order was consented to by SCA
** Agreement between SCA, DEC, towns of Porter and Lewiston and citizen
group
-------
C-2
Appendix C (cont.)
Date
File No.
Comments
Solid Waste Management
76-350 Penalty payment, remedial action outlined
January 16, 1979*
October 17, 1979 79-47
March 6, 1980
January 8, 1981 80-79
April 20, 1982 82-48
May 19, 1982 82-61
June 28, 1982 82-37
January 21, 1983 82-207
June 15, 1983* ' 83-64
December 19, 1983*
December 13, 1983*
February 2, 1984
December 18, 1984 84-140
Penalty payment for the complaint due to
to leachate pumping
Penalty payment for odor complaints
Penalty payment, exceeded leachate level
SLF 7
Penalty payment for discharge of liquid
and odors
Penalty payment for odor complaint
Penalty payment for odor complaint
Same as above and failure to maintain,
freeboard and remedial actions outlined
Failed to meet compliance .dates in Permit
2343, schedule outlined
Agreement with Ontario Ministry of Envi-
ronment regarding ground-water monitoring
system and testing
Agreement with Citizen Intervenors regard-
ing ground-water monitoring and testing,
site operation and site studies
Agreement with Citizen Intervenors regard-
ing site operation, construction and
studies
Penalty payment for manifest discrepan-
cies, remedial actions outlined
* Contains requirements relating to ground-water monitoring
-------
APPENDIX D
LETTER FROM DEC TO EPA ON DEFICIENCIES
IN PART 8 PERMIT APPLICATION
-------
Nซw Yortc Stala Dซpartmซnt of Environmental ConปซrvซtJon
50 Wort Road, Albany, Nซw York 12233-0001
Hซfiry G. Williams
Commiiaionar
; 0 r:?
Mr. James M. Reidy, P.E.
Chief
New York Hazardous Waste Section
U.S. Environmental Protection Agency
Region El
26 Federal Plaza
New York, NY 10273
Dear Mr. Reidy:
Re: Part B Application
Notice of Deficiency (Partial)
SCA Chemical Services
Model City, New York
EPA 1.0. No. NYQ049836674
Volume 12 of the above referenced Part 8 Application has been
reviewed by my staff and has been found to be grossly deficient. That
volume deals with the groundwater protection requirements which are
forth in 40 CFR Part 254, Subpart F.
set
Deficiencies in this application are extensive and major revisions
of the application will be necessary.
It should be noted that DEC staff met with the application on
November 18, 1983 to informally discuss the groundwater monitoring
program at the facility. At that time, the applicant was advised that
there were major deficiencies in the Part 3 application; specifically
in the proposed groundwater monitoring network. On October 15, 1984
the Department received a copy of a draft report "Evaluation of
Hydrogeologic and Monitoring Data, Model City, NY Site." That report
was prepared for SCA by Geoengineering Incorporated. The report was
ostensibly submitted to respond to the concerns which the Department
had expressed during the Novemoer 1983 meeting, but does little to
enhance the adequacy of the Permit Application.
-------
D-2
Mr. James M. Reidy, P.E.
page 2
CC; 5 0*384
It should also be noted that subsequent to the submission of the
Part 3 Application, SCA has modified its groundwater sample collection
procedures. During the past year the company has replaced all of its
former qas-lift monitoring wells with wells that use "Geomon sampling
devices They did so with the acceptance of the NYSOEC, but they have
not as of yet, submitted to the Department the information necessary
to evaluate the adequacy of the sampling device. Said information was
requested in January 1984 and again in September 1984. Furthermore,
after seeing the sampling device in operation during a September 1984
inspection of the facility, DEC staff have misgivings about the devic
potential impacts upon the integrity of groundwater samples.
ce' s
Paul R. Counterman, P.E.
Chief
Bureau of Hazardous Waste Technology
Division of Solid and Hazardous Waste
Enclosure --
cc: w/enc.
- J. Roto!a
W. Pedicino
-------
APPENDIX E
NEW YORK POLICY ON ALTERING SAMPLES TO
BE ANALYZED FOR ORGANIC COMPOUNDS
-------
MtMtV ซ. WKUAHtS, C
<=' **
'MAY 3 1385
TO: Executive Staff, Division Directors, and Regional Directors
FROM: Hank Wil
i
RE: Policy on Altering* Water Samples to be Analyzed for Organic Ccopound
The altering of groundwater samples from wells Involved 1n the
assessment, investigation, remedy, study, construction, monitoring and
other activities at sites throughout the State has been requested of the
Department of Environmental Conservation by some parties responsible for
sites who have opted to perform work through their own consultants and
at their own expense.
The Department's denial on this point has been consistent, since ve
expect that data from altered samples will significantly diminish actual
concentrations of organic compounds. Moreover, the United States
Environmental Protection Agency has forbidden filtration of samples in
which volatile constituents are of interest, since filtration may strip
these constituents from the sample. This directive can be found in
Proposed Samp ling and Analytical Methodologies for Addition to Test
Methods for Evaluating Solid Haste: Physical/Chemical Methods. SM-846,
Second Edition. USEPA, Washington, O.C. 1984.
The Department has denied any request that filtering and centrifuglng
of samples be an acceptable technique; on the other hand, some responsible
parties persistently present arguments 1n support of the demand. There
, arซ a few cases where negotiations have reached an impasse, the resolution
of which ปay be difficult to reach.
.This policy will serve a four-fold purpose:
1) Thซ Department's policy will have been stated officially in
writing.
2) Tht stated policy will provide added impetus to the Department's
present efforts at denying filtration and centrifugatlon of
samples.
3) A responsible party(ies) will be discouraged froa proposing or
attempting filtration or centrifugation of samples.
"Altering" Includes filtering, centrifuging, decanting or any other
treatment or manipulation by which a sample may be disturbed.
-------
E-2
2.
Executive Staff, Division Directors
and Regional Directors
as wtl as any other types of d1 tely t eparmen
ซercisซs its regulatory powers Effec ve <;aซ Jf d for Organ1c
olic on the altering of water samp es ซ ' tft assessmnt,
or any other
es.
Ictivlt? shall not be altered prior to analysis.
-------
APPENDIX F
ANALYTICAL TECHNIQUES AND RESULTS FOR
TASK FORCE SAMPLES, SCA, MODEL CITY
-------
-------
F-l
ANALYTICAL TECHNIQUES AND RESULTS FOR
TASK FORCE SAMPLES, SCA, MODEL CITY
The following discusses analytical techniques, methods and results for
the ground-water and leachate samples collected by the Ground Water Task
Force at SCA, Model City. Ground-water sample analyses and results are
discussed in the first section; the second section addresses the leachate
analyses and results.
GROUND-WATER SAMPLE ANALYSIS RESULTS
Field measurements on ground-water samples, including conductance, pH
and turbidity, were made by the EPA sampling contractor at the time of sam-
pling. Laboratory analysis results were obtained from two EPA contractor
laboratories (CL). participating in the Contract Laboratory Program (CLP).
One CL analyzed the samples for specified organic compounds while the other
analyzed for metals -and other parameters.
_. ft
Standard quality control measures were taken including: (1) the
analysis of field and laboratory blanks to allow determination of possible
contamination due to sample handling, (2) analysis of laboratory spiked
samples and performance evaluation samples to estimate accuracy, (3) analysis
of laboratory duplicates and field triplicates to estimate precision, and
(4-) the review and interpretation of the results of these control measures.
The performance evaluation samples were samples of known analyte concentra-
tions prepared by the EPA Environmental Monitoring Systems Laboratory,
Cincinnati, Ohio. Samples from two wells analyzed by the CL were split
with the NEIC. Organic extracts, prepared by the CL of samples from wells
Z-ll and Z-13, were also analyzed by NEIC to confirm the CL analysis results
for pesticides and PCBs.
Table F-l provides a summary, by parameter, of the analytical techni-
ques used and the reference method for ground-water sample analyses.
-------
Analysis Results
Specific Organic Analysis Results
Table F-2 lists the organic compounds which can be reported with cer-
tainty as being present in the ground-water samples for the identified wells.
The results in Table F-2 are based on the CL analyses plus NEIC confirmation
of the pesticide results and NEIC PCS analysis results for the samples for
Wells Z-ll and 2-13. The identities of the BHC isomers reported in Table
F-2 were confirmed by analysis of the CL base/neutral extract at the NEIC.
The CL analysis results for the BHC isomers are reported. The Aroclor 1242
identification and the amount reported is also based on NEIC analysis of
the base/neutral fraction CL extract after a sulfuric acid cleanup. The
pesticide fraction extract was not available from the CL. NEIC analyses
were performed about 6 months after extraction. The accuracy of each
detectable value, relative to the extract analysis, is footnoted in the
table.
*
Table F-3 contains the limits of quantitation for the analyses for
volatiles, semi-volatiles and pesticides. Based on matrix spike recoveries,
these limits, relative to the sample, can be considered reliable to within
a few parts per billion for the volatiles and to within factors of two to
twegty for the semi-volatiles and pesticides. These limits "apply to all
parameters except for the acid fraction compounds in the samples for Wells
Z-4, Z-9, Z-13, Z-19 and Z-21. The acid fraction compounds for these five
-samples should be considered "not analyzed" because of very low or non-
existent acid surrogate recoveries.
The compounds listed in Table F-3 were not detected above blank levels
in samples other than those found in samples for Wells Z-3, Z-ll and Z-13.
-------
F-3
Metals Analysis Results
The dissolved and total metals results for the SCA Zone I and Zone 3
well samples are reported in Tables F-4 and F-5, respectively. The accuracy
of each detectable value is footnoted in the tables.
Samples for four wells were found to contain notable heavy metal con-
centrations. The total metals analyses for the samples from Wells 8-21A,
B-84A and 8-116 found detectable levels of arsenic, beryllium, chromium,
cobalt, copper and nickel. The sample for Well B-21A contained the highest
concentrations with arsenic at 87 |jg/ฃ, beryllium at 6 ug/2, chromium at
181 ug/2, cobalt at 113 ug/2, copper at 97 ug/2 and nickel at 217 ug/2. In
all three wells, the heavy metals appear to be associated with carbonate or
iron particulates as calcium, magnesium and iron concentrations were much
greater for the total metals analyses over the dissolved metals analyses.
Further, the heavy metals concentrations of the dissolved samples for these
wells were near or below detection limits. Nickel was detected at a con-
centration of 30 ug/2 in both the total 'and dissolved analyses for the
samples for Well Z-19.
No total values are reported for manganese, potassium, silver and thal-
lium because the lower 99% confidence limits for the spike recoveries for
these elements were below zero. Zinc values are not reported because of
contamination due to sample handling. For example, a dissolved zinc con-
centration of 412 ug/2 was found for the sample for Well Z-ll, while the
total zinc concentration was only 8 ug/2.
Total cadmium and lead results for the samples for Wells B-21A and
B-84A are not reported because of severe aluminum and iron interference on
the spectral lines. Similarly, spectral background interference prevented
the analysis of selenium for the Well Z-4 sample and resulted in rather
high detection limits for selenium for Wells B-21A, B-22B, B-35A, B-84A and
B-116 and for thallium for Well B-35A.
-------
F-4
One of the three spike recoveries for total barium was 62% at a spike
level of 4,000 pg/2. However, a recovery of 96% was obtained for a spike
level of 2,000 ug/2 to the same sample for the dissolved barium analyses.
Barium's solubility generally decreases with increasing sulfate concentra-
tion. The spiked sample contained about 1,400 ug/2 sulfate. The difference
in the spike recoveries, indicates that total barium spike level exceeded
the solubility limit while the dissolved barium spike level did not. Since
none barium concentrations in the ground-water samples exceeded 1,000 ug/2,
the low spike recovery is not considered representative of the accuracy
achieved for the analysis.
General Analysis Results
The field measurements for conductance, pH and turbidity and the
results of other analytical testing for Zone 1 and Zone 3 well samples are
reported in Tables F-5 and F-7, respectively. The reliability of detectable
values are footnoted.
The cyanide data are highly- suspect. Initial analysis of the sample
for Well Z-ll in duplicate found cyanide concentrations of about 10 ug/2
and 30 ug/2. Reanalysis of the sample in duplicate a week later found the
cyanide to be nondetectable (less than 6 ug/2). Glassware contamination or
the instability of cyanide could possibly explain this occurrence. The
cause of this occurrence could not be identified.
LEACHATE SAMPLE ANALYSIS RESULTS
No field measurements were made for the leachate samples. All leachate
analyses were performed by NEIC which included most of the standard quality
measures mentioned above.-
The samples received for Sumps 8, 10 and 28 varied widely as to the
amounts of the nonaqueous and aqueous phases in different sample bottles
(see Investigation Metnods section of this report). The nonaqueous liquid
-------
F-5
phase of the different sample bottles ranged on a volume basis from 0% to
35% for Sump 8, from 0% to 70% for Sump 10 and from 0% to 90% for Sump 28.
Table F-8 provides a summary, by parameter, of the analytical tech-
niques used and the reference methods for the leachate sample analyses.
Analysis Results
Specific Organic Analysis Results
Tables F-9 and F-10,.respectively, list volatile organic compounds and
semi-volatile organic compounds that were detected in the leachate samples.
The leachates contained a variety of compounds in significant concentrations
including PCBs, chlorinated benzenes, phenols* aniline and chlorinated and
non-chlorinated solvents.
The s'emi-vol ati 1 e organic samples for Sump 10 and 28 contained both
nonaqueous and aqueous phases. However, the volatile organics sample bot-
tles for these sumps contained only aqueous phases. For the semi-volatile
organic analyses, the nonaqueous and aqueous phases were each analyzed.
Nonaqueous phase concentrations are reported in ug/kg units while the
aqueous phase concentrations are reported in ug/2 units. The nonaqueous
phase Sump 10 sample was high enough in halogenated organics that the den-
sity was 1.24 g/mJl. This phase was found to contain 6.6% PCS. The identi-
fication of Aroclor 1242 in five leachate samples, as opposed to the very
similar Aroclor 1016, cannot be absolutely certain due to the presence of
interfering species.
The base/neutral extract for the Sump 10 sample was analyzed by capil-
lary column gas chromatography with electron capture detection in order to
quantitate the BHC isomer identified in the mass spectroscopy analysis. No
other leachate samples were analyzed for the BHC isomers or other pesticides.
-------
F-6
All organic analyses results should be considered semi-quantitative
(i.e., concentrations are probably reliable to within 10% to 200% of actual
sample concentrations for the semi-volatiles and 50% to 150% for the vola-
tiles). Table F-ll lists the limits of quantitation for compounds determined.
Many compounds given in Table F-ll were not detected in any of the samples
and thus are not listed in Tables F-9 and F-10.
Metals Analysis Results
The metals results for the leachate samples are reported in Table F-12.
High concentrations of heavy metals were found in many of the samples.
These metals included antimony, arsenic, cadmium, chromium, nickel, selenium
and zinc.
Depending on the suspended matter composition, the values reported for
certain elements may not represent "total" concentrations. If the suspended
matter is siliceous then values for aluminum, magnesium, p.otassium, sodium
and titanium are not "total" because the silicate matrix was 'not dissolved.
The heavy metal results would approximate "total" concentrations because
they are usually absorbed and are not incorporated in the silicate matrix.
The accuracy of each detectable value is footnoted in the table. The
accuracy is only that indicated by spike recoveries, variability between
sample containers has not been evaluated.
The two phases for the Sumps 8, 10 and 28 samples were analyzed as
composites. The compositing was based on an estimate of the volume of each
phase.
General Analysis Results
Table F-13 reports the results of other testing. Sumps 8 and 10 were
only analyzed for water content. For the Sump 28 sample only the aqueous
phase was analyzed.
-------
F-7
High concentrations of chloride, sulfate and ammonia were found in a
number of the leachate samples. The bromide levels are high relative to
the chloride levels/ Bromide to chloride ratios of about 1:300 are common
in natural waters.
Rather high Gross Alpha and Gross Beta activity were found for some of
the leachates.
-------
F-8
Table P-1
GROUND-WATER SAMPLE ANALYSIS TECHNIQUES AND METHODS
TOX
?oc
NPCC
Chloride
Nitrate
Sulfate
Ammonia
Cyanide
Phenol
Dissolved and
Total Hg
Dissolved As,
Pb, Se and Tl
Total As,
Se and Tl
Total Pb
Volatiles
Serai-volatiles
Pesticides
PCBs
Analytical Technique
Slectrometric
Potentiometry
Neophelometric
Combustion of purgable fraction,
Microcoulometry Detection
Carbon absorption,, combustion,
Microcouloraetry Detection
Combustion of purgable fraction,
Non-dispersive Infrared Detection
Acidify, Purge, Combustion of liquid,
Non-dispersive Infrared Detection
Mercuric Precipitation Titration
3rucine Sulfate Colorimetry
Barium Sulfate "urbidimetry
"Phenolate Colorimetry
Distillation, Colorimetry
Distillation, Coloricetry
Wet digestion for dissolved and total,
Cold Vapor AAS
Furnace AAS
Acid digestion, "Pomace AAS
Acid digestion, Furnace AAS
Acid digestion, ICAP-QES
For three well samples
Purge and trap GC-MS
"tethylene "hloride extraction, GC-'!S
Hexane extraction, GC-EC
"lethylene chloride extraction, sulfuric
acid cleanup, <77-:3C
Method Reference
No reference
No reference
No reference
EPA 6CO/4-84"ฃC8
Method 9020 (a)
No reference
Method 415.1 (b)
Method 9252 (a)
Method 92CO (a)
Method 903S (a)
Method 350'. 1 (b)
CL? Method (c)
Method 420.1 (a)
CLP Method
CLP Method
CL? Method
\ v
CLP Method
CLP Method
CL? Method
CLP Method
CLP Method
CL? BNA Extract
Method 60S (d)
a - Test Methods for Evaluating Solid Wastes, SVP346.
b - Methods for Chemical Analysis of Water and Wastes, !2>A-6CO/4-79-020.
-------
F-9
Table P-2
D5TECTA3LI 3?iCI?IC ORGANIC ANALYSIS RESULTS
"OR ""HE GROT7IDWATZR SABLES
3CA "ODIL CITY FACILITY
Compound (a) Well Z-l> Well Z-11 Well Z-13
1 ,1-Dichloroethene
trans-1 ,2-Dichloroethene
Trichloroethene
alpha-HHC
beta-3HC
gaima-BHC
Aroclor 12A2
T
320
130
< 0
< 0
< 0
< 0
d
c
c
.1
.1
1
i
.5
< 7
< 7
< 6
0
0
0
< 0
. b
*
.
.29
.21
.18
3
d
d
d
< 7
< 7
< 6
0
0
0
0
ซ
.
.23
.40
.15
.6
d
d
d
c
a - Concentrations in u^/L
b - < X denotes sanple concentration is- less than X at 99f^ confidence.
c - Control measures indicate value is' within 75^ to 125^ of actual
concentration at 5^^ jcnf'.ience.
d - Control measures indicate value is within 5C^ to 150>J of actual
concentration at ?5^ confidence.
-------
F-10
Table F-3
CONTRACT LABORATORY LIMITS.OF QUANT1TATTQN FOR ORGANIC
COMPOUNDS IN SCA GROUND-WATER SAMPLES
.flit Of
Quanti tation
Limit of
Quanti tation
Limi t of
Quantitation
Baaซ/Nซutral Compounds
Acenapnthenet 10
1,2,4-trlchlorobenzenet 10
Hexactllorobenzene 10
Hexachloroethane 10
b-fs(2-Chloroethy1)ether 10
2-Chloronapnthalene 10
1.2-01 eftlorobenzene 10
1,3-01 eftlorobenzene 10
1,4-Olcftloroftenzene 10
2,4-01n1trotoluene 10
2,S-01nitroto!uene 10
1,2-Oiphenylhydrazine* NA*
Fluoranthene 10
4-Ch.lorophenyl phenyl ether 10
4-9romopheny1 phenyl ether 10
biป(2-Chloroisopropy1)ether 10
b1s(2-Cnloroethoxy)mซthane 10
Hexachlorobutadiene 10
Hexachlorocyclopentadiene 20
Isopnorone 10
Naphthalene 10
Nitrobenzene 10
N-nitrosodimetny1 amiie NA
N-nitrosodiphenylamine 40
N-nitrosodi-n-propylamine 10
81s(2-ethylnexyl)phthatate 10
Butylbenzylphthalate 10
Oi-n-butylphthalate 10
01-n-octylp'htnalate 10
01ซtnylphtnalatซ 10
OfiMtnylphthalatt ' 10
Benzo(a)anthracene 10-
8ซnzo
-------
F-ll
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F-12
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Table F-U
N6IC LIMITS OF QUANTITATION FOR ORGANIC
COMPOUNDS IN SCA LEACHATE SAMPLES
To find limits of quantitation for compounds not detected in leachate samples, multiply the
concentration in the table by the factor indicated. Units for nonaqueous phases are ug/kg.
Limits of detection for PCBs were 200 to 500 M5/k.g in samples where no PCBs were detected.
Limit of
Quantitation
Limit of
Quantitation
Mul
ication
Factors
Base/Neutral Compounds
Acenaphthene 20
1,2,4-tricnlorobenzene 1.0
Hexachlorobenzene 20
Hexa.cn loroetfiane 20
bis(2-Chloroซthyl)ether 10
2-Chloronaphthalene 10
1,2-Oichlorobenzene 10
1,3-Qicnlorobenzene 10
1,4-Oicnlorobenzene 10
2,4-Oinitrotoluene 20
2,5-Qinitrotoluene 20
1,2-Oiphenylhydrazine 20
Fluoranthene 8
4-Chloropheny1 fjhenyl ether 10
4-9romophenyI phenyl ether 20
bis(2-Chloroisoprooyl)ether 20
bi s(2-Chloroethoxy )metnane 10
Hexachlorobutadiene 20
Hexachlorocyc!ocentaaiene 20
Isophorone 10
Napnthalene - 3
Nitrobenzene 10
N-nitrosodimethylamine NA*
N-nitrosodipheny1amineฐฐ 10
N-nitrosodi-n-propylamine 20
3is(2-ฃthylhexyl)phthalate 20
Sutylbenzylphthalate 20
Qi-n-butylphthalate 20
Qi-n-octylphthalate 20
Oiethylohthalate 10
OimethyIphthalate 20
Benzo(a)anthracene 20
3enzo(a)pyrene 20
Benzo(b)fluoranthene and/or
8enzo(lt)f luorantnene 20
Chrysene 20
Acenaphthylene 10
Anthracene 10
aenzo(g,h, i)perylene 40
Fluorene 10
Phenarvthrene IQ
OiDenzoCa, h)anthracene 40
Indeno(1.2,3-c,d)pyrenซ 40
Pyrene 10
Benzidine NA
3,3'-Qichlorobenzidine NA
Am 1 ine 20
Benzyl chloride 40
Benzyl alcohol 20
O'Chloroani1ine 20
Oibenzofuran 10
2-Methylnaphthalene 10
4-Ni troam 1 i ne 20
Pentachlorobenzene 20
1.2.4,S-Tetrachlorobenzere 20
1,2 ,3 ,4-Tet,rachlorooenzene 20
Pentachloronitrobenzene 10
2-MetnyInaphthalene 10
Z-Ni traaru 1 me 100
3-Ni troam 1 me 100
Acid Compounds
2,4,6-Trichlorophenol 20
Parachlorometacresol 20
2-Chlorophenol 10
2,4-Oichlorophenol 20
2,4-Oimethylphenol 20
2-Nitropnenol 20
4-Nitrophenol 80
2 ,4-Qinitrophenol 40
4.6-Oinitro-o-cresol 20
Pencachlorophenol .20
Phenol 20
Senzoic acid 100
4-MethyIphenol (p-creso!) 20
2-Methylohenol (o-cresol) 20
2.4 , 5-Trich1orophenol 20
volati1e Compounds .
Benzene 2
Bromodichloromethane 2
Baromoform 2
Bromomethane 4
Carbon fetrachloride 2
Chlorobenzene . 2
Chloroethane 6
Chloroform 5
Chloromethane 12
3ibromoch1oromethane 2
1,1-Oichloroethane 6
L.J-Qichloroethane 4
1,1-Oicnloroethene 4
trans-l,2-0ichloroethene S
1,2-Oicnloropropane 2
Ethyl benzene 2
Methyiene chloride 6
1,1,2.2-Tetrachloroethane 5
Tetrachloraethene 2
Toluene 2
1,1. l-Trichloroethane 2
1.1.2-Tricnloroethane 2
fncnloroethene 4
vinyl chloride 10
Acetone - 100
2-8utanone (ME.O 30
1,2-Oibromomethane (ฃ08) 10
2-Mexanone 20
-------
F-24
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U.S. Environmental Protection Agency
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