April 1986 EPA-330/2-86-OQ3
Hazardous Waste Ground-Water
Task Force
Evaluation of
.Chemical Waste Management, lnc«
Kettleman Hills Facility
Kings County, California
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, It 60604-3590
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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UNITLD STATES ENVIRONMENTAL PROTECTION AGENCY
April 30, 1986
UPDATE OF THE HAZARDOUS WASTE GROUND-WATER TASK FORCE
EVALUATION OF CHEMICAL WASTE MANAGEMENT, INC.
KETTLEMAN HILLS FACILITY
The United State Environmental Protection Agency's Hazardous VJaste
Ground-Water Task Force (HWGWTF) conducted an evaluation of the ground-water
monitoring program at the Chemical Waste Management, Inc. Kettleman Hills
hazardous waste treatment, storage and disposal facility. This facility is
located approximately 3 miles west of Kettleman City, California. The evalua-
tion of the Kettleman Hills facility focused on (1) determining if the facility
was in compliance with applicable Federal and State of California ground-water
regulatory requirements and policy, (2) detemining if hazardous constituents
were present in the ground water, and (3) providing information to assist EPA
in determining if the facility meets EPA requirements for waste management
facilities receiving waste from response actions conducted under the Federal
Superfund program. The onsite field inspection was conducted over a two-week
period from July 29, 1985 to August 6, 1985.
Kettleman Hills is one of 58 facilities that are to be evaluated by the
HWGWTF. The Task Force effort came about in light of the recent concerns by
Congress and the public as to whether operations of hazardous waste treatment,
storage and disposal facilities are complying with the State and Federal
ground-water monitoring regulations.
The results of the chemical analysis of ground-water samples collected
trom existing monitoring wells during the evaluation indicated low levels of
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hazardous constituents in three wells. For one well (K-4) where con tarn inat id-
was previously known, the company has already completed an assessment program
to determine the extent of the cont nination, and is currently operating a
ground-water extraction program. Based upon the available data which indicates
that hazardous wastes have been released into the ground water, EPA has taken
an enforcement action under Section 3013 of the Resource Conservation and
Recovery Act. The company has consented to plan and perform a ground-water
sampling and analysis program to evaluate the full nature and extent of any
contamination that may be present in the other two wells (K-8 and K-13). If
contamination is confirmed to be present, the company will submit a ground-
water quality assessment: program plan.
At the time of-the inspection, the facility had 21 operating ground-water
monitoring wells, as well as an additional 20 assessment and observation wells.
Subsequently, the company installed 10 more monitoring wells and is continuing
to conduct a hydrogeological study of this site. EPA and the State; of Califor-
nia are currently reviewing the work completed to date as part of the hazardous
waste management permitting process and will continue to work with the company
to complete the design of the ground-water monitoring system. As a result,
additional monitoring wells may be required in order to meet RCRA permitting,
requirements.
The Company's corporate sampling plan that was followed for collecting,
handling and preserving samples from the monitoring wells, making field
measurements, shipping and chain of custody, was extensively reviewed and
found to be technically adequate and quite comprehensive. Overall, the
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company's analytical procedures are properly selected and conducted. However,
the Task Force investigation did reveal that the ground-water sampling proce-
dure manuals do not provide detailed methods for some parameters required for
interim status monitoring.
In November 1985, EPA, the California Department of Health Services and
Chemical Waste Management Inc., completed a Consent Agreement and Final. Order
that covered violations of ground-water requirements at Kettleman Hills. The
Consent Agreement required activities which included (1) submission of a
report on site hydrogeology and ground-water quality investigations, (2)
developing and implementing a ground-water monitoring program, and (3) perform-
ing remedial work.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUND-WATER TASK FORCE
EPA-330/2-86-003
GROUND-WATER MONITORING EVALUATION
CHEMICAL WASTE MANAGEMENT, INC,
KETTLEMAN HILLS FACILITY
Kings County, California
April 1986
Steven W. Sisk
Project Coordinator
National Enforcement Investigations Center
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CONTENTS
EXECUTIVE SUMMARY
INTRODUCTION . . . 1
SUMMARY OF FINDINGS AND CONCLUSIONS . . . . ,,,,..,. , . , 7
TECHNICAL REPORT
INVESTIGATION METHODS .................... . . . 11
RECORDS/DOCUMENTS REVIEW ...................... 11
FACILITY INSPECTION .... .....,,.,, 12
LABORATORY EVALUATION .......... 12
GROUND-WATER SAMPLING AND ANALYSIS ................. 12
WASTE MANAGEMENT UNITS AND FACILITY OPERATIONS ........... 18
WASTE MANAGEMENT UNIT CONSTRUCTION . . . . . . . 21
REMEDIAL SITE WORK ..................... ... 22
WASTE CHARACTERIZATION , ....... 24
SITE HYDROGEOLOGY .......................... 26
HYDROGEOLOGIC UNITS . ......... 27
GROUND-WATER FLOW DIRECTIONS AND RATES 29
GROUND-WATER MONITORING ............ 33
GROUND-WATER SAMPLING AND ANALYSIS PLAN 33
CWM SAMPLE COLLECTION AND HANDLING PROCEDURES . 35
Water Level Measurements ...... 36
Purging 37
Sample Collection, Handling, Preservation and
Field Measurements ....................... 38
Shipping and Chain-of-Custody . ........ 4Q
SAMPLE ANALYSIS ........ ... 41
MONITORING WELLS 42
Well Locations .......... 42
Well Construction ......... ... 48
MONITORING DATA ANALYSIS FOR INDICATIONS OF WASTE RELEASE ,.,.,. 55
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CONTENTS (cont.)
REFERENCES
APPENDICES
A CONSENT AGREEMENT
B DESCRIPTION OF STRATIGRAPHIC INTERVALS WITHIN THE SAN JOAQUIN FORMATION
C ANALYTICAL RESULTS FOR TASK FORCE SAMPLES
FIGURES
1 Site Map With Waste Handling/Disposal Units .......... 3
2 Geologic Cross-section ....,.,.,,,,..,....,. 28
3 Wellhead Sampling Apparatus ...,...,,......,,. 44
4 Typical Well Completion ,.,,..,...,.,,...,... 50
5 Typical Well Head Sampling Apparatus ..,.,.,.,..... 51
TABLES
1 Sampling Locations and Descriptions .......... 13
2 Monitoring Wells Initially Selected for Sampling ........ 15
3 Preferred Order of Sampling Collection; Bottle Type
and Preservative List ..................... ^ 17
4 Hazardous Waste Management Units and Waste Types Received . . . .' 19
5 Organic Priority Pollutant Concentrations Beneath Area S-5 ... 23
6 Active Land Treatment/Disposal Units After Completing Site
Remedial Work Required by Consent Agreement ...... ... 24
7 Stratigraphic Intervals of the San Joaquin Formation ...... 30
8 Estimated Hydraulic Conductivities of Geologic Beds
within the San Joaquin Formation ... 32
9 Analytical Parameters, Volumes and Preservatives for
CWM Samples 40
10 Kettleman Hills Facility Wells as of August 1, 1985 . . 43
11 Monitored Zones of Selected Monitoring, Observation and
Assessment Wells ... ............ 46
12 Differences Between Reported Casing Depths and Measured
Depths for Selected Wells ................... 47
13 Company Designated Monitoring Wells ......... 49
14 Sand Pack and Screen Length in Wells Within Reported
Hydrologic Intervals ............. 53
15 Organic Compounds Detected in Ground-Water Samples ....... 56
16 Organic Compounds Detected in Well K-4 by CWM . . . . . . . . . . 57
11
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EXECUTIVE SUMMARY
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INTRODUCTION
Concerns have recently been raised about whether commercial hazardous
waste treatment, storage and disposal facilities (TSDFs) are complying with
the ground-water monitoring requirements promulgated under the Resource
Conservation and Recovery Act (RCRA)*. In question is the ability of
existing or proposed ground-water monitoring systems to detect contaminant
releases from waste management units. To evaluate these systems and deter-
mine the current compliance status, the Administrator of the Environmental
Protection Agency (EPA) established a Hazardous Waste Ground-Water Task
Force (Task Force). The Task Force comprises personnel from the EPA Office
of Solid Waste and Emergency Response (OSWER), National Enforcement Investi-
gations Center (NEIC), Regional Offices and State regulatory agencies. The
Task Force is conducting in-depth onsite investigations of commercial TSDFs
with the following objectives.
Determine compliance with interim status ground-water monitoring
requirements of 40 CFR Part 265 as promulgated under RCRA or the
State equivalent (where the State has received RCRA authorization.),
Evaluate the ground-water monitoring program described in the
facility's RCRA Part B permit application for compliance with
40 CFR Part 270.14(c).
Determine if the ground water at the facility contains hazardous
waste constituents.
Provide information to assist the Agency in determining if the
TSDF meets EPA ground-water requirements for waste management
facilities receiving waste from response actions conducted under
the Comprehensive Environmental Response, Compensation and Liabil-
ity Act (CERCLA, Public Law 91-510).**
* Regulations promulgated under RCRA address hazardous waste management
facility operations, including ground-water monitoring, to ensure that
hazardous waste constituents are not released to the environment.
** EPA policy, stated in a May 6, 1985 memorandum from Jack NcGraw on
"Procedures for Planning and Implementing Offsite Response" requires
that TSDFs receiving CERCLA waste be in compliance with applicable
RCRA ground-water monitoring requirements.
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The first TSDF investigated by the Task Force in EPA Region IX was the
Chemical Waste Management (CWM) Kettleman Hills Facility near Kettleman
City, California [Figure 1]. The facility is located on State; Route 41
about 2,5 miles west of Interstate Highway 5 (1-5), The onsite inspection
was conducted from July 29 through August 6, 1985 and was coordinated by
NEIC personnel.
Until 1984, CWM had a waiver demonstration for the State interim status
ground-water monitoring requirements on file at the Kettleman Hills facility
and had installed no monitoring wells at the site. The RCRA Part B permit
application submitted in August 1983 contained a waiver demonstration,
rather than a proposed monitoring program. Legal action taken by EPA
Region IX regarding the inadequacy of the waiver demonstrations and other
areas of noncompliance resulted in a ground-water monitoring program being
required at the facility, The program was being developed during the Task
Force inspection. Consequently, there was no interim status monitoring
program to evaluate and, as no monitoring program had been proposed in the
Part B, the Task Force was unable to evaluate compliance with 270,14(c).
The Task Force did evaluate monitoring plans, procedures and wells
that would be part of the program proposed to EPA, as required by the
Consent Agreement that resulted from the legal action and State regula-
tions. In general, the investigation involved reviewing State, Federal and
facility records; inspecting monitoring wells and CWM sampling procedures;
and inspecting CWM's contractor laboratory. Samples were collected by Task
Force personnel from monitoring wells for determining if and where contami-
nants are present.
The area surrounding the current CWM hazardous waste management site
is undeveloped except for a few oil production facilities. From the 1920s
through the 1950s, the Kettleman Hills were extensively explored for oil
and gas. Some production is still occurring in the area.
The CWM facility was first developed in the early 1970s by the McKay
Trucking Company (MTC) of nearby Coalinga, California for disposal of
nonhazardous oil field wastes. In March 1975, MTC received a State pernrt
for disposal of oil wastes and drilling fluids on a 60-acre portion of the
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LOCATION MAP
l" » 135 mil**
^ SITE LOCA7JON
KETTLEMAN HILLS FACILITY LOCATION MAP
Figure 1
(from EMCON Associates)
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current active disposal area. In May 1978, MTC applied to the California
Department of Health Services (DOHS) for a hazardous waste facility permit,*
DOHS subsequently issued an operating permit (No, 16-0001-78) on September 12
1978, CWM acquired the facility in April 1979,
The permit issued by DOHS authorized disposal of hazardous wastes at
the Kettleman Hills facility and contained management requirements for land
disposal, surface impoundments and landfills; however, it did riot require
ground-water monitoring.
On November 18, 1980, CWM submitted a RCRA Part A permit application
to EPA and received interim status (EPA identification No. CAT000646117),
allowing operations to continue pending a decision on whether to issue a
permit. In June 1981, EPA granted Interim Authorization to DOHS pursuant.
to Title 40, Code of Federal Regulations, Part 271 (40 CFR Part 271), DOHS
codified State regulations, which were modeled after RCRA Part 265 regula-
tions, into an Interim Status Document (ISO), The ISDs were issued to the
interim status facilities as operating requirements.
The ISO for the CWM facility was issued as a revised permit on Decem-
ber 13, 1982. Five Part A revisions were submitted to the State for approval
between May 1981 (just before the State received Interim Authorization) and
September 1983. These revisions resulted in two addenda to the 1982 permit,
which were issued in February and July 1983, respectively.
In addition to the State requirements and permit, which regulate PCBs
as hazardous waste, PCBs and PCB items are managed at the Kettleman Hills
facility under Federal regulations promulgated under the Toxic Substances
Control Act (TSCA; 40 CFR Part 761) and PCB disposal approvals issued by
EPA Region IX.
California enacted the Hazardous Waste Control Act in 1977,
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An EPA Region IX inspection of the CWM facility on April 13 and 14,
1983 revealed that the Company had not implemented a ground-water monitoring
program and that the Company's demonstration for waiver of the monitoring
requirements on file at the facility was inadequate. The waiver demonstra-
tion was subsequently revised. From March 21 to April 18, 1984, NEIC
conducted a comprehensive RCRA interim status and TSCA inspection of the
facility. The updated waiver demonstration was reviewed and determined to
be inadequate, primarily because it contained no site specific data and CWM
had not conducted investigations necessary to provide adequate technical
support.
EPA Region IX issued an Administrative Order (AO) on July 3, 1984,
which required, in part, the installation of a ground-water monitoring
system. Analysis of samples from newly installed wells revealed hazardous
waste constituents in the ground water. This discovery, plus information
gathered during the NEIC inspection on other RCRA/TSCA compliance deficien-
cies, resulted in a June 5, 1985 amendment to the 1984 AO.
Regarding ground-water monitoring, the amended AO required:
1. Investigation of the site hydrogeology
2. Delineation of the contaminant plume in the area of Well K-4 (in
northwestern area of facility)
3, Identification of the source of toluene identified in water samples
from several of the wells
4. Submission of a sampling and analysis plan
5. Initiation of a ground-water monitoring program
6. Development of a comprehensive ground-water monitoring system
The above-listed activities were in progress during the Task Force
investigation. Field work was being closely monitored by Region IX staff
because investigation plans were being refined to reflect new information
as it became available.
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In November 1985, EPA, DOHS* and CWM completed a Consent Agreement and
Final Order (Consent Agreement) [Appendix A] that addressed the issues
raised in the AO and amended AO, The Consent Agreement outlined activities
required which included: (1) submission of a report, on site hydrogeology
a.,d ground-water quality investigations, (2) developing and implementing a
ground-water monitoring program, and (3) performing remedial work. It also
provided that EPA and DOHS personnel could review, upon request, consul-
tants' driller logs and field notes relating to the facility, which were
not made available to Task Force personnel during the onsite inspection.**
* Participating as an intervenor,
** See paragraph S2a(2) of Consent Agreement,
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SUMMARY OF FINDINGS AND CONCLUSIONS
Task Force personnel conducted the onsite inspection of the Kettleman
Hills facility from July to August 1985, The findings and conclusions pre-
sented in this report reflect conditions existing at the facility in early
August 1985, Actions taken by the State, EPA Region IX and CWM in the
period subsequent to this investigation are summarized in the accompanying
update.
During the Task Force inspection, CWM was in the process of developing
a ground-water monitoring program to meet interim status and Part B RCRA
permit application requirements. Monitoring program proposals were submit-
ted to EPA Region IX and DOHS for these requirements in November 1985,
Previously, the Company had a waiver demonstration on file for interim
status requirements and had submitted one in the Part B. Legal action by
EPA Region IX resulted in a Consent Agreement that required development of
a ground-water monitoring program for the facility,
#
Consequently, the Task Force evaluated the monitoring plans, procedures
and wells that would be part of the required monitoring program. Samples
were collected and analyzed from monitoring wells for determining if and
where contaminants are present,
A corporate sampling plan was being followed by CWM's contractor for
collecting, handling and preserving samples from the monitoring wells,
making field measurements, shipping samples and chain-of-custody. An
undated copy was provided to Task Force personnel during the inspection.
The plan, although not site specific, was comprehensive and was the basis
for the site specific plans submitted in November.
Analytical procedures for ground-water samples were presented in two
manuals prepared by the CWM contractor laboratory. The manuals do not pro-
vide detailed methods for some of the parameters required for interim
status monitoring, including chloride, nitrate, sulfate, phenol, sodium,
total organic halogen, total organic carbon, gross alpha and gross beta.
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Samples were drawn from most wells with submersible centrifugal pumps.
This type of pump has been shown to alter the chemistry of samples collected
with them, principally through degassing effects. Affected parameters
include volatile organics, pH, alkalinity, temperature ind others. The
effect of these pumps on ground-water samples collecteo from the Kettleman
Hills facility wells needs to be further investigated.
During sample collection, aliquots for metals and inorganic parameter
analyses were passed through a disposable in-line filter installed on the
pump discharge sampling tube. The corporate sampling plan specified that,
when collected, other aliquots, including extractable organics, would be
filtered during collection, Although EPA has no formal policy on fi'lterirg
samples for organic and inorganic parameters, the Agency is on record as
opposing such practice,* The principal objection is that the results may
be biased low. Further, filtering samples for the drinking water supply
parameters (Part 265, Appendix III) is inconsistent with procedures required
for drinking water supplies [Part 141.23(f)]. ,
Once samples were drawn, Task Force personnel observed the 'CWM proce-
dures for documentation and chain-of-custody; taking field measurements;
and preserving, packaging and shipping samples. These procedures were
acceptable.
The CWM contract laboratory responsible for analyzing ground-water
samples from the Kettleman Hills facility was inspected in July 1985 as
part of another Task Force inspection. The laboratory was inspected to
determine if priority pollutant** analyses and analyses required by the
RCRA interim status regulations were being properly conductec. These
* 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 Love Canal in New York
** Priority pollutants are defined in the June 7, 1976 Natural Resources
Defense Council (NRDC) vs. Russell Train (USEPA) settlement agreement
listing 126 compounds that are commonly referred to as the "Priority
Pollutants List".
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analyses include those required on samples from the Kettleman Hills facility
by the AO and Consent Agreement, except for one sample, which was analyzed
for Part 261, Appendix VIII parameters.
Some inadequacies in analytical procedures were found at the contractor
laboratory. Analytical methods with lower detection limits need to be used
for pesticides, PCBs, cadmium, chromium and lead. The analytical method
for total organic carbon is inappropriate because volatiles are stripped
from the sample before the organic carbon concentration is measured,
The adequacy of the location and construction of many of the wells
designated by CWM for the monitoring program, required by the amended AO,
could not be determined. Conflicting and incomplete reports on site hydro-
geology have been submitted to EPA, Summary well construction diagrams,
boring logs, geologic cross sections, well deviation surveys and borehole
geophysical logs were inconsistent with one another on points such as
descriptions of geologic units, total well depths and monitored zones.
Summary logs of well construction could not be verified because the Company
did not provide the field records. A provision of the Consent Agreement
provides access to these records by EPA and State personnel.
The information provided indicates that wells constructed in the same
hydrologic zones had wide ranges in lengths of screens and sand packs. As
a result, water levels measured in wells ostensibly monitoring the same
hydrologic unit may not correlate, and predictions of ground-water flow
directions based on these measurements may be erroneous.
Analytical data from samples collected by Task Force personnel from
the monitoring wells indicate the presence of organic hazardous waste
constituents in wells K-4, K-8 and K-13. The compounds identified in well
K-4 were previously detected by CWM and an assessment program is required
by the Consent Agreement to delineate the plume and remove the affected
water. Low levels (less than 5 ug/£) of two organic hazardous waste con-
stituents (carbon disulfide and toluene) were detected in well K-8 and one
(1,1,1-trichloroethane) in well K-13, Results are probably biased low for
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10
wells K-4 and K-8 because submersible centrifugal pumps were used to draw
the samples, The compounds identified in wells K-8 and K-13 had not been
previously reported by CWM. The presence of these compounds needs to be
further investigated.
Under current EPA policy, if an offsite TSDF must be used for land
disposal of waste from a Superfund cleanup of a CERCLA site, that site must
be in compliance with the applicable technical requirements of RCRA. At
the time of the Task Force inspection, no interim status ground-water
monitoring program had been implemented at the Kettleman Hills facility.
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TECHNICAL REPORT
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11
INVESTIGATION METHODS
The Task Force investigation of the CWM Kettleman Hills facility
consisted of;
Reviewing and evaluating records and documents from NEIC, EPA
Region IX, California OOHS and Regional Water Quality Control
Board, and CWM files
Conducting an onsite facility inspection from July 30 through
August 6, 1985
Evaluating the offsite laboratory contracted by CWM for analysis
of ground-water samples
Sampling and analyzing data from selected ground-water monitoring
wel Is
RECORDS/DOCUMENTS REVIEW
Much of the information on waste management units and operation nor-
mally collected during a Task Force inspection was obtained by NEIC for th-e
facility during the RCRA/TSCA compliance investigation in 1.984. NEIC
records were reviewed and the information was updated during the onsite
visit to reflect recent operational changes.
As previously noted, there was no ground-water monitoring program in
place during the 1984 NEIC inspection. Consequently, CWM reports, plans,
logs and records were obtained for the site hydrogeologic investigation,
ground-water monitoring program and well construction.
CWM did not provide the field logs of well construction, as speci-
fically requested by Task Force personnel, because its contractor, EMCON
Associates, reportedly would not release the records for Task Force review.
Rather, only unsubstantiated diagrams that summarized monitored units and
construction details were provided. The November 1985 Consent Agreement
between EPA Region IX, OOHS and CWM (after Task Force data collection was
concluded) provided access to these field logs.
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12
FACILITY INSPECTION
The facility inspection involved identifying the active waste management
units and verifying the location of ground-water monitoring wells,
Company personnel were interviewed to identify records and documents
of interest, discuss the contents of the documents and explain the site
hydrogeology, ground-water monitoring system, ground-water sampling and
analysis plan and field procedures for sample collection.
LABORATORY EVALUATION
The CWM contractor laboratory, Environmental Testing and Certification
(ETC), Inc. of Edison, New Jersey, was evaluated by Task Force personnel
about 2 weeks before the Kettleman Hills inspection as part of another site
investigation. ETC was evaluated for its ability to produce quality data
for those parameters required by Part 265.92 and priority pollutants.*
Analytical equipment and methods and quality assurance procedures were
examined for adequacy. Laboratory records were reviewed for completeness,
accuracy and compliance with State and Federal requirements,
GROUND-WATER SAMPLING AND ANALYSIS
During the onsite inspection, a Task Force contractor collected ground-
water samples from nine monitoring wells [Table 1 and Plate 1]. Those
designated by the prefix letter "K" are tentatively designated by CWM to be
included in the interim status network; wells with the prefix letter "A"
are part of the K-4 assessment program required by the amended AO to address
contaminants found in this well. The wells were sampled to determine if
the ground water contained any waste constituents or other indicators of
Priority pollutants are defined in the June 7, 1976 Natural Resources
Defense Council (NRDC) vs. Russell Train (USEPA) settlement agreement
listing 129 compounds that are commonly referred to as the "Priority
Pollutants List",
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13
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-------
14
contamination not previously detected by CWM. Initially, 10 wells were
selected for sampling, either because hazardous waste constituents were
previously detected in them or the wells were completed in geologic strata
that outcrop beneath waste management units or both [Table 2], Monitoring
well A-l could not be sampled because the Well Wizard bladder pump failed
under the high pressures necessary to operate it at greater-than-designed
depth (>300 feet).
Duplicate volatile organic samples and splits of all others were
declined by CWM personnel; however, their contractor collected some samples
at each well. Details of the CWM sample collection are described in the
Ground-Water Monitoring section. All but one of the wells sampled were
equipped with Grundfos® electric submersible pumps; the one was equipped
®
with a high-pressure Well Wizard bladder pump. The pumps were operated by
the CWM contractor during collection of Task Force samples. Samples were
collected for CWM and the Task Force from the wells by the following
procedure:
I, CWM contractor measured depth to ground water using Slope Indi-
cator water level meter.
2. CWM contractor calculated height of water column from depth to
water measurement and well depth (from construction records).
3. CWM contractor calculated water column volume using height of
water column and well casing radius.
4. CWM contractor purged at least three water column volumes
(measured using a 5-gallon bucket), except at we1! K-4 which was
purged of about 1% water column volumes.
5. After recharge, CWM contractor collected sample aliquots for
field measurements (water temperature, specific conductance, pH)
and volatile organics.
6. CWM contractor installed in-line filter on pump discharge tube.
7. CWM contractor filled sample containers for metals, nitrate and
conventional parameter analyses.
8. CWM contractor removed in-line filter from pump discharge tube.
Grundfos, Well Wizard and Slope Indicator are registered trademarks
and will appear hereafter without ®,
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15
Well
Table 2
MONITORING WELLS INITIALLY SELECTED FOR SAMPLING
KETTLEMAN HILLS FACILITY
Kings County, California*
As ,umed Monitored
Waste Management
Unit(s)
Remarks
A-l
A-2
P-12
P-12
Contaminated assessment well
located along strike from K-4;
not sampled due to pump failure
Assessment well located downdip
from K-4
A-4
K-3
K-4
K-5
K-6
K-8
K-13
K-17
P-12 Assessment well to K-4
B-9 expansion Centrally located near burial
units
P-12 Contaminated monitoring well
P-20, S-5
Upgradient Along
P-10, P-ll Along
P-10, P-ll Along
S-5 Along
and B-
stri ke
stri ke
strike
strike
7
from K-4
from P-10 and P-ll
from P-10 and P-ll
from P-8, B-l, B-6
Selections based upon preliminary hydrogeologic interpreta-
tions by OWN consultants.
-------
16
9, EPA sampling contractor monitored open wellhead for chemical
vapors (HMD ) and radiation,
10. EPA contractor collected sample aliquot and made field measure-
ments (water temperature, specific conductance, pH),
11. EPA contractor filled sample containers in the order listed on
Table 3, Volatile organic samples were first collected in a
250-mi beaker then poured into 60-m£ vials (sample containers).
All other sample containers were filled directly from the dis-
charge line.
12. Samples were placed on ice in an insulated container,*
13. Within 2 hours after sampling was completed at a well, EPA con-
tractor personnel took the samples to a staging area where a
turbidity measurement was made and one of the two sample aliquots
for metals analysis was filtered. In addition, metals, TOC,
phenols, cyanide, nitrate and ammonia samples were preserved
[Table 3].
When NEIC, State and triplicate samples were collected, Step 11 above
was modified. Additional sample containers for each parameter group were
filled .after the initial one for the EPA contract laboratory.
® HNU is a registered trademark and will appear hereafter without ®,
** During sampling of the first few wells, samples were placed on ice
within about 2 hours after collection. Subsequently, they t^ere placed
on ice immediately after collection.
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17
Table 3
PREFERRED ORDER OF SAMPLE COLLECTION,
BOTTLE TYPE AND PRESERVATIVE LIST
Kettleman Hills Facility, California
August 1985
Parameter
Bottle
Preservative
(concentration)
1, Volatile organic analysis (VOA)
Purge and trap
Direct inject
2. Purgeable organic carbon (POC)
3, Purgeable organic halogens (POX)
4. Extractable organics
5. Total metals
6, Dissolved metals
7. Total organic carbon (TOC)
8, Total organic halogens (TOX)
9. Phenols
10. Cyanide
11. Nitrate/ammonia
12, Sulfate/chloride
13, Radionuclides (NEIC only)
2
2
60 ml
60 ml
vials
vials
1 60 ml vial
1 60 ml vial
4 1-qt. amber glass
1-qt, plastic
1-qt. plastic
4-oz. glass
1-qt. amber glass
1-qt. amber glass
1-qt. plastic
1-qt, plastic
l~qt,o plastic
4 1-qt. amber glass
HN03 (95-98%)
HN03 (95-95%)
H2S04 (95-S8%)
H2S04 (95-98%)
NaOH (12N)
H2S04 (95-98%)
Volume added = 5 ml
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18
WASTE MANAGEMENT UNITS AND FACILITY OPERATIONS
The CWM Kettleman Hills facility is a California Class I* treatment,
storage and disposal facility (TSDF) that receives lip-id and solid hazard-
ous and extremely hazardous wastes, The facility also manages polychlori-
nated biphenyl (PCB) waste, pursuant to DOHS regulations and 40 CFR Part
761 regulations promulgated under TSCA, The facility reportedly does not
accept radioactive, explosive or infectious wastes,
CWM owns 1,600 acres of land at the Kettleman Hills location, which
includes an active waste management area of 211 acres [Plate 1], In the
active area, CWM uses the following management units/areas for the treat-
ment storage and/or disposal of hazardous waste:
Surface impoundments - storage and treatment
Landfills - disposal
Tanks - storage and treatment
Drum storage area - container storage
Physical treatment unit - liquid solidification in drums
Various impoundments, landfills, drum storage areas, trenches for waste
solidification and land treatment areas used in the past are currently
inactive. Waste management units and types of wastes placed in them are
listed in Table 4, Surface impoundments are designated by the prefix let-
ter "P", landfills by a "B" and land treatment areas by an "S".
PCB waste processing and disposal operations include storage, proces-
sing for disposal (transformer draining and flushing) and landfill disposal
Some stored PCB wastes are disposed of offsite,
Under the California classification system, to be a Class I site,
there must be no possibility of discharge of pollutant substances to
usable waters. Usable ground water may underlie the site, but only
under extreme cases where natural geological conditions prevent movement
of the wastes to the water and provide protection for the active life
of the site. All waste groups can be received.
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19
fable 4
HAZARDOUS WASTE MANAGEMENT UNITS AND WASTE TYPES RECEIVED
CHEMICAL WASTE MANAGEMENT
Kettlenan H'lls Facility. California
Unit
P- 1
P- 2
P- 3
P- 4
P- 4c
P- 4%
P- 5
P- 6
P- 7
?• 8
P" 9
P-10
p-11
P-L2
P-12A
P-13
P-14
P-15
P-16
P-17
P-lfl
P-19
P-20
B- 1
B- 2
B- 3
B- 4
B- 5
B- 6
B- 7
B- 8
Waste Received
Surftc* Impoundment.
Pesticide wash water
Pesticide wash water
Waste oil
Pesticide wash water and various other wastes
Acid and alkaline solutions, pesticide wastes
Acid solutions, pesticides, phenolic and resin wastes
Drilling >ud and acid solutions
Acids and various other wastes
Acids and various other 'Wastes
Acids and various other wastes
Scrubber wastes, organic liquids, solvents, brines,
heavy iMtal solutions and various other wastes
Pesticide rinse waters, acid and alkaline solutions
and various other wastes
Cyanate solutions from treatment, acid and alkaline
solutions, organic liquids and various other wastes
Corrosives and a wide variety o? other organic and
inorganic wastes
Acid solutions, reactives, laboratory waste che»ica"'S
Pesticide rinse waturs , corrosive alkaline solutions
and various other w,istes
Pesticide rinse waters , heavy meta1 acia and alkaline
solutions, organic solvents and various other wastes
Drilling »uds and scrubber waste, converted to
hazardous waste unit during 1984
Drilling muds, bnriie waste and various other wastes
Drlling muds and various other wastes
Runoff from S-5 and S-6 areas
Acid and alxaline solutions with metals and organics,
metal sludges, ash, untreated process waters and
various other hazardous wastes
Landfills'
Containerized waste solvents, sludges and toxics
Containerized waste solvents, sludges and toxics
Containerized waste solvents, sludges and toxics
Containerized waste solvents, sludges and toxics
Containerized waste solvents, sludges and toxics
Containerized waste solvents, sludges and toxics
Containerized waste solvents, sludges and toxics
Bulk solids of iron oxide hydroxide
UnU Active
Approximate Active Period 7/85
,1
Pre- 11/80 to late 1981.
Pre- 11/80
Late 1980 to Hid- 1983
Pre-11/80 to 8/83
6/83
2/81 to 7/82
3/81
7/81 to '10/83
Pre- 11/80 to 3/83
Pre- 11/80 to 3/83
Pre- 11/80 to 3/84 X2
Pre-11/80 to at least 3/84 X
Pre-11/80 to at least 3/84 X
Pre-11/80 to at least 3/84 X3
3/83 to 8/83
5/83 to at least 3/84 *
12/83 to at least 3/84 X2
1/82 to 11/83 X
3/82 to 12/83 • X
2/81 to 1/83 X
Not deterained X
2/84 to at least 3/84 X
No wastes received as of 4/84
Completed pre-11/80
Cotipleted pre- 11/80
Completed pre-11/80
Completed pre- 11/80
Completed pre- 11/80
Pre-11/80 to 8/83
Completed pre-11/80
Completed ore- 11/60
-------
Table 4 (cont )
Unit
Waste Received
Approximate Active Period
Unit Acti
7/85
Ltndfills* (cont. '.
B- 9
B- 9
(extension)
8- 9
(expansion)
B-10
8-11
B-12
8-L3
B-13
(expansion)
8-14
8-15
B-16
Bulk solids of empty containers, solids
soi Is
contaminated
No Information provided in RCRA Part B application
Bulk and containerized solids and sludges, paint
sludges, waste-water treatment sludges filter
cakes, eapty crushed containers and treated
(solidified) liquid wastes
Containerized reactive and high pH materials
Bulk solids of empty containers, solids, contaminated
soil
Containerized mineral acids
Containerized mineral ac'ds
Empty crushed acid drums and soils contaminated
with acids
PCS solids
Bulk and containerized organic wastes (sludges and
solids), solidified alkaline corrosive wastes and
solids, empty crushed containers, spill cleanup
residues and contaminated soil from spill cleanups
Bulk and containerized PCB-contaminated solids and
sludges
Pre-11/80 to unknown date (records do not
distinguish between 8-9, B-9 extension
and expansion)
Unknown (records do not distinguish frotn
8-9 above)
Late 1983 (?) to at least 3/84 (records
do not distinguish fron B-9 acove)
Completed pre-11/80, possibly reopened
4/82 to 10/83
Coopleted pre-11/80; reopened 11/80 to
4/83
Completed pre-11/80
Pre-11/80 to at least 3/84
3/84 to present (opened during NEIC
investigation)
9/81 to at least 3/84
2/81 to at least 3/84
12/83 to at least 3/84
Land rreatawnt Ar»asl
S- 1 Halogenated, oxygenated and hydrocarbon solvents,
pesticides acid and alkaline solutions and various
other wastes
5- 2 Drilling mud, oily waste and various other wastes
i- 3 Wide variety of wastes, acid and alkaline solutions,
organics, sludges, resins and solvents
Acid and alkaline solutions, solvents, tank bottoms,
organic liquids and various other wastes
Wide variety of wastes, acid and alkaline solutions,
sludges, resins and solvents
Add and alkaline solutions, solvents, tank bottoms,
organic liquids arxJ various other wastes
Pre-11/80 to 11/83
5/81 to 12/83
2/81 to at least 3/84
Pre-11/80 to 11/83
Pre-11/80 to at least 3/84
Pre-11/80 to 11/83
r*c»iv«d and actlv« ptrlod information 11 from facility rfctiving log's obtained durin? th« 1984 XEIC investigation
P-14 »as in cltmnmg eye it during ttt» T«»i Forct inspection.
»«jt» proc»iiin9 »«J occurring in reconstructed southern h*j|f of P-I2
W«jt»-r»c«jr»d in/om»tion from tCEA Part S permit application »ubautt»d S»pt«t>«r 1983
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21
The following describes the construction of these units and site
remedial work recently agreed upon by EPA, DOHS and CWM, which is in prog-
ress. The concluding subsection addresses waste characterization as it,
relates to ground-water monitoring.
WASTE MANAGEMENT UNIT CONSTRUCTION
To identify possible sources and pathways for waste constituents
managed by CWM to enter the ground water, construction information for the
land treatment/disposal units, primarily from the 1983 RCRA Part B permit
application, was reviewed. The following information was derived from that
permit application and information obtained by NEIC during the 1984 inves-
tigation unless otherwise noted,
The surface impoundments used for hazardous liquid waste at the CWM
facility have bases and levees constructed of recompacted clayey soils from
the site. The thicKness of the compacted layer is not presented in the
construction certification reports contained in the Part B. Generally, the
impoundments were designed to contain 5 to 10 feet of liquid with '2 feet of
freeboard. As will be discussed in the Site Hydrogeology section, the
water table is several hundred feet beneath the ground surface at the site.
Therefore, the impounded liquids create an outward hydraulic gradient
across the compacted soil layer that would promote waste release.
Landfills, except for B-14 and B-16, also have bases and embankments
constructed of recompacted site soil and are not equipped for leachate
detection or collection. Landfills B-14 and B-16, which are for disposal
of PCB wastes, were constructed pursuant to TSCA regulations and have low
permeability compacted clay liners, underdrains and leachate detection ard
collection systems. If leachate exists in any of the landfills, it too
would create an outward hydraulic gradient across the compacted soil layer
because ground water is several hundred feet below the bases.
From at least November 1980 (effective date of RCRA regulations) until
about April 1984, several land treatment areas were used for liquid hazard-
ous waste. The land treatment areas were non-lined basin-type areas where
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22
liquid wastes were applied and disced into the soil. At least one of the
areas designated for land treatment (S-3) was used for solidifying wastes
in unlined trenches.
Of the six land treatment areas, only S-3 and S-5 were recognizable
units during the Task Force inspection; however, they were inactive. Area
S-l was removed during the excavation for the landfill B-9 expansion, S~2
was active from May 1981 to December 1983, S-3 was used for waste solidifi-
cation in trenches until about March 1984, S-4 was removed during construc-
tion of P-14 through P-16, S-5 was used until about April 1984 and S-6 was
deactivated by combining a small portion the northern part with S-5 and
constructing P-19 and P-20 in a large portion of the remainder.
In January 1983, CWM collected and analyzed core samples from land
treatment areas S-l, S-5 and S-6. Samples from the 5- to 5.5-foot depth,
taken at several locations within an area, were composited before analysis,
NEIC was provided the results of the core analysis during the 1984 investi-
gation. The data show high concentrations of organic priority pollutants
beneath the S-5 area [Table 5] and lower concentrations beneath S-l and
S-6, indicating some migration of waste constituents toward underlying
ground water.
REMEDIAL SITE WORK
Whether the pollutants have migrated to ground water from the land
treatment or any other units is the subject of investigative reports and
remedial work required by the Consent Agreement.
The Consent Agreement requires that surface impoundments P-9, -14,
-15, -16, -19 and -20 be retrofitted with a double liner system. Under-
lying contaminated soils are to be removed before the liners are installed.
All other impoundments are to be closed in accordance with plans approved
by DOHS. Core samples are to be collected and analyzed from beneath impound-
ments P-9, -12, -12A, -13, -14, -16, -18 and -19 for determining the extent
of residual waste constituents in the soils.
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23
Table 5
ORGANIC PRIORITY POLLUTANT CONCENTRATIONS
BENEATH AREA S-5
AT THE 5- to 5.5-FOOT DEPTH*
Semi-Volatile Priority Pollutant Concentration (|jg/£)
1,2,3-trichlorobenzene 3,000
Naphthalene 17,000
Phenanthrene 59,000
Bi s(e-ethylhexyl)phthalate 32,000
Di-n-butyl phthalate 14,000
Butyl benzyl phthalate 29,000
1,3-dichlorobenzene 6,400
1,4-dichlorobenzene 7,900
1,2-dichlorobenzene 44,000
Acenaphthene 12,000
Fluorene 17,000
Anthracene 12,000
Benz(a) anthracene 9,300
Chrysene 12,000
* Results for sample S in data provided to NEIC by
CWM during the 1984 investigation of the Kettleaan
Hills facility
Inactive landfills are to be closed in accordance with plans submitted
to and approved by DOHS. Landfills B-9 expansion and B-13 expansion will
remain active until filled. New landfill B-19 is to be built with a double
liner system if construction is approved by DOHS and other appropriate
governmental agencies.
The Consent Agreement requires that land treatment areas be closed and
that a core-samp1 ing program be conducted in areas S-3 and S-5 to determine
the vertical extent of waste constituent migration beneath these units.
Areas S-2 and S-3 are to be closed by capping, in accordance with a plan
approved by DOHS. Area S-5 is to be excavated as part of the construction
of B-19, Visually contaminated soil, excavated from the S-5 area, is to be
disposed of in either the B-9 or B-13 expansions or the double-lined portion
of B-19.
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24
After remedial work is completed, the land treatment/disposal units
listed in Table 6 will compose active operations at the Kettleman Hills
faci1ity.
Table 6
ACTIVE LAND TREATMENT/DISPOSAL UNITS AFTER COMPLETING
SITE REMEDIAL WORK REQUIRED BY CONSENT AGREEMENT
Surface Impoundments Landfills Land Treatment Units
P-9 B-9 expansion None
P-14 B-13 expansion
P-15 B-19 (if approved
P-16 for construction)
P-19
P-20
WASTE CHARACTERIZATION
Waste characterization before receipt at a TSDF is required under both
RCRA regulations (265.13) and the revised permit (Section III3) issued by
DOHS for the Kettleman Hills facility. Characterization is important in
identifying the constituents that could potentially be released from waste
handling units. Knowledge of the constituents is necessary to comply with
the RCRA permit standards [264.93(a) and 264.98(a)].
To determine whether CWM sufficiently characterizes the waste it
receives, findings from the 1984 NEIC investigation were reviewed, Based
on this review, CWM was found to have inadequate information on specific
hazardous constituents in each waste management unit. However, the infor-
mation is adequate to identify waste constituents for a facility-wide
detection monitoring program.
Waste characterization information is submitted to CWM as part of a
preacceptance data package. The three-part package consists of a (1)
generator waste material profile sheet, (2) a certification of representa-
tive sample and (3) a special waste analysis report. During the 1984 NEIC
investigation, preacceptance procedures were evaluated, based on a review
-------
25
of data packages for 175 waste loads received during the first and third
weeks of March 1983 and March 1984. Only 125 of the 175 data packages
requested were provided.
Of 37 packages received for 1983 and 88 packages for 1984, 73% and
40%, respectively, contained special analysis reports, which are supposed
to specify the identity and concentrations of hazardous waste constituents.
About 25% of the 125 packages did not contain the generator waste material
profile sheet that presents basic information about the composition of the
waste stream, including the major components.
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26
SITE HYDROGEOLOGY
As discussed previously, limited site-specific hydrogeologic information
was available for the Kettleman Hills facility before 1984, In February
1984, CWM initiated a hydrogeologic investigation as a result of discussions
with EPA Region IX personnel regarding the waiver demonstration. The
hydrogeologic investigation was still in progress during the Task Force
inspection, The following is provided to explain the complexities of the
site hydrogeology, the extent of work done to date and some of the short-
comings of that work,
By July 1985, hydrogeologic data had been collected from at least 41
borings that were subsequently completed as wells. Generally, the borings
were over 300 feet deep. Stratigraphic data were obtained during geologic
logging of the cuttings, from core samples and by geophysical logging of
selected boreholes. Hydrologic data were obtained from packer and pumping
tests conducted in boreholes and wells, and laboratory measurements on core
samples for hydraulic conductivity. The following information was derived
from reports submitted to EPA on the work performed, which include;
Ground Water Assessment Program, dated August 15, 1984
Revised K-4 Assessment Program Well Layout, dated February 6,
1985
Supplemental Monitoring Program (K-4 area), dated February 21,
1985
RCRA Part B Application, additional information requirements
submitted by CWM, November 8, 1985
The Kettleman Hills, in which the CWM facility is located, form a part
of the western edge of the San Joaquin Valley in south central California,
The hills were formed by an upfolding of about 15,000 feet of marine sedi-
mentary deposits some 5 million years ago and comprise three domal struc-
tures known as the North, Middle and South Domes, The CWM facility is on
the western slope of the North Dome. The upfolding also produced faults
perpendicular to the axis of the hills, which have been identified at the
CWM facility. The Part B RCRA permit application for the facility states
-------
27
that hydrogeo "logic site investigations revealed no evidence of Holocene
faulting. Based on the information reviewed, Task Force personnel agree
with this conclusion,
Erosion has exposed these faults and older stru^a along the center of
the domes (anticlines). The facility is underlain by about 2,000 feet of
dipping sedimentary strata of the San Joaquin Formation. These strata dip
uniformly to the west at about 20 to 40° and consist of alternating sequences
of sandstone, siltstone and claystone [Plate 1 and Figure 2],
To the southwest is the Kettleman Plain where the San Joaquin Forma-
tion is overlain by sediments of the Tulare Formation. The Part B applica-
tion for the facility, indicates that the Tulare sediments range up to
5,000 feet in thickness, but are much thinner on the flank of the Kettleman
Hills. The nearest water supply wells (closest one is about 1 irile north-
west of the site) are constructed in the Tulare Formation: however, none is
known to penetrate below the upper horizons.
During deposition of the sedimentary strata underlying the Kettleman
Hills facility, marine seas encroached on the land (transgression), covered
it and deposited sediments, then receded (regression). Nine identifiable
cycles of transgression and regression are present in the Tulare, San
Joaquin and underlying Etchegoin Formations which, with the structural
deformation, create a very complex hydrogeologic setting. The upper portion
of the Tulare Formation is primarily fluvial sandstone and conglomerate.
The lower Tulare and the entire San Joaquin Formation consist of marine and
non-marine sandstone, siltstone, claystone and a few beds of limestone,
The Etchegoin Formation is mostly marine sandstone, siltstone and
conglomerate.
HYDROGEOLOGIC UNITS
Under the RCRA permitting process, the uppermost aquifer and aquifers;
hydraulically interconnected beneath the facility property must be identi-
fied [270.14(c)(2)]. An "aquifer" is defined (260.10) as a "geologic
-------
28
2
\f.
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-------
formation, group of formations, or part of a formation capable of yielding
significant amounts of ground water to wells or springs". The "uppermost
aquifer" is defined as "the geologic formation nearest the natural ground
surface that is an aquifer, as well as lower aquifers that are hydraulic-
ally interconnected with this aquifer within the facility's property
boundary".
The San Joaquin Formation, which underlies the Kettleman Hills facility,
contains numerous water-bearing strata. Some of these strata produce water
at a substantial rate (e.g., greater than 5 gallons per minute). These
water-bearing strata outcrop beneath waste management units. Task Force
personnel consider the entire San Joaquin Formation and any hydraulical ly
interconnected units in the overlying or underlying formations to be the
uppermost aquifer.
CWM, however, reports that the water-saturated beds beneath the Kettle-
man Hills facility do not constitute an aquifer under the regulatory defini-
tion. The Company contends that the dipping stratified geologic structure
precludes identification of an uppermost aquifer and that some of the
clayey strata do not yield enough water (<1 gpm) to be classified as aquifers.
Consultants for CWM have divided the San Joaquin Formation into several
stratigraphic intervals [Table 7 and Plate 1]. Several of these intervals
are named for dominant marine fossils present, primarily bivalves (clams)
or gastropods (snails). By convention, the name of the fossil is underlined.
A description of the intervals is presented in Appendix B.
GROUND-WATER FLOW DIRECTIONS AND RATES
Despite the extensive site investigation by CWM, ground-water flow
beneath and near the facility is still poorly defined. There is insuffi-
cient reliable data on water levels within the hydrologic units to determine
ground-water flow directions and rates. Whether, and to what extent,
hydraulic interconnections exist between saturated permeable units that are
separated by relatively impermeable claystone layers is not reported.
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30
Table i
STRATIGRAPHIC INTERVALS OF THE SAN JOAQUIH FORMATION
KETTLEMAN HILLS FACILITY
F o rraa 11 o n
Interva1
Major Beds
Tulare
Sandstone
San Joapu'n Aci'a Interval
Trachycardi un> Interval
Pecten Interval
Pecten - Mya Interval
My a Sandstone Interval
Neven ta Sandstone
IntervaI
Cascajo Interva!
Claystone
Sandstone
Interbedded claystone and
si 1 tstone
Claystone
Sandstone
Interbedded sandstone and
claystone
Claystone, clayey sandstone
Sandstone
Acila A sandstone
C laystone
Sandstone
Interbedded sandstone and
claystone
Sandstone
Tracnycardium marker bed
Sandstone
Silty sandstone (Pecten B)*
Pecten claystone
Pecten marker bed
InterDedded siltstone and
sandstone
Sandstone (Pecten A)*
Interbedded si 1tstone and
sandstone
Mya B sandstone
Mya A sandstone, Mya marker bea
at base
Interbedded claystone and
si 1tstone
Tuffaceous B sandstone
Claystone
Tuffaceous A sandstone
Interbedded sandstone, siltstone
ana c1aystone
Ne\/er i ta B sandstone
Nevert ta A sandstone
Neverita marker bed
Claystone
Interbedded sandstone, si 1tstone*
and claystone
Claystone
Si 1ty sandstone
Cascajo conglomerate
Etchegoin
Sandstone
Uncertain from informataon provided by
-------
31
Tests for hydraulic conductivity have been run for some, but not all, of
the geologic units at the facility.
The number and location of wells completed by early August 1985 were
not adequate for defining hydraulic gradients and ground-water flow direc-
tions in the major hydrologic units, Some of the principal hydrologic
units (e.g., My a A, which outcrops beneath P-9 and P-19) had no wells
completed in them. Information in CWM hydrogeologic reports shows that-
some wells (e,g,, K-10 and K-18) do not monitor the beds indicated.
Water level elevation data are suspect because the wells are not
straight, Consequently, measured depths to water do not reflect a vertical
distance below the surveyed reference point, as they should. CWM consul-
tants have conducted studies on the wells to obtain correct information on
depths; however, they report that well deviations still cause some error in
water level measurements.
CWM conducted numerous tests to measure the hydraulic conductivity of
the major sandstone units, interbedded zones and claystones. The tests
were conducted both in the field (packer and pumping tests) and in the
laboratory on core samples. The ranges of hydraulic conductivity values
across the site are shown in Table 8. These values represent numerous
hydrologic strata grouped into rock-type categories. CWM concluded that
the laboratory data indicate that hydraulic conductivities measured parallel
to bedding exceed those measured perpendicular to bedding, thereby suggest-
ing preferential flow down dip and along the strike of the inclined beds.
Task Force personnel concur with this conclusion.
-------
32
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-------
33
GROUND-WATER MONITORING
During the Task Force investigation, CWM was in the process of
conducting site hydrogeologic s-udies, installing a well network and moni-
toring ground-water quality in response to the Administrative Order (as
amended) issued by EPA. As previously discussed, a Consent. Agreement
between EPA, DOHS and CWM on required site work was reached in November
1985.
The ground-water monitoring plan, sampling and analysis procedures and
wells used by CWM contractors during the onsite investigation v/ill report-
edly compose principal elements of the final program, Consequently, these
were evaluated during the Task Force investigation and are discussed in
this section.
GROUND-WATER SAMPLING AND ANALYSIS PLAN
Under the November 1985 Consent Agreement, CWM is to submit a report
to EPA that contains, among other things, a site specific ground-water
sampling and analysis plan to be followed whenever samples are taken from
monitoring wells at the facility.
During the Task Force inspection, sampling and analysis plans employed
by CWM and their contractors, which will be used to develop the site specific
plan, included the following documents:
1. "WMI Manual for Groundwater Sampling" prepared for Waste Management,
Inc. (CWM parent company) and a July 1, 1985 addendum
2. Laboratory Standard Operating Procedures, as amended February 21,
1985, by ETC*
3. Data Integration Standard Operating Procedures dated June 10, 1985,
by ETC
Environmental Testing and Certification, Inc. Edison, Aeiv Jersey
-------
34
A copy of the WMI Manual for Groundwater Monitoring 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, received during the TasK
Force inspection (undated), is comprehensive and includes 89 pages of
narrative and two appendices. The manual was the basis for a site specific
ground-water sampling plan submitted to EPA in November 1985, It presents
detailed procedures for collecting, preserving, handling, documenting
(field records and chain-of-custody) and shipping samples, as required by
265.92(a) and Section VIII.2(a) of the revised permit. It also addresses
field measurements for water level, pH, specific conductance and temperature,
personnel training, equipment maintenance and well construction records.
The WMI manual describes two practices that need to be changed for the
Kettleman Hills facility plan. First, the manual prescribes filtering of
sample aliquots, other than those for volatile organics and total-type
analyses (e.g., total organic carbon, total organic halogen, etc.). Although
EPA has no formal policy on filtering samples for organics and inorganics,
the Agency is on record as opposing such practice.* The principal objection
is that the results may be biased low. Further, filtering samples for the
drinking water supply parameters [Part 265, Appendix III] is inconsistent
with analysis of samples required for drinking water supplies [40 CFR Part
141.23(f)].
Secondly, the plan specified purging the well of at least three casing
volumes, which is less than the minimum of five casing volumes required
under recent amendments to the California Hazardous Waste Act [Article 9.5,
§25208.8(1)(7)] for wells monitoring surface impoundments.**
* 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 Love Canal in New York
** These provisions became effective January 1, 1986,
-------
35
The "Laboratory Standard Operating Procedures" by ETC i<> 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 .deludes 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 also contains
information on quality control procedures and procedures not presented in
the former manual.
Detailed methods for chloride, nitrate, sulfate, phenol, sodium, TDK,
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
procedure is not recommended, however, it, is not followed by CWM personnel
(filtering is done at the well head). EPA recommends filtration followed
by preservation as soon after sampling as is practical.1
CWM SAMPLE COLLECTION AND HANDLING PROCEDURES
During the inspection, samples were collected from nine monitoring
wells, as discussed in the Investigation Methods section. At each of the
wells, CWM contractor personnel collected samples using their standard
procedures for measuring water levels, purging, collecting and preserving
samples, making field measurements, shipping samples and chain-of-custody.
CWM has a corporate training program to ensure that its personnel and
contractors properly and uniformly implement the WMI manual procedures.
The training also promotes consistency in sampling. One CWM and three
contractor personnel onsite during the inspection reportedly had received
-------
36
the training program. The CWM sampling procedures conformed to those
described in relevant parts of the WMI manual and are described and assessed
in the following
Water Level Measurements
At the wellhead, the first step in collecting samples is to measure
depth to water using an electric water level indicator (Slope Indicator
Company, Model 51453), The water level indicator consists of a reel with a
control panel, cable and sensor. A two-conductor cable connects the con-
trol panel to the sensor. When the sensor makes contact with water, an
indicator light and buzzer on the control panel are activated. The water
level indicator was mounted on 2-inch x 4-inch boards propped directly over
the well on an aluminum well box and the cord was lowered into the well
through a 1-inch-diameter PVC sounding tube or an access port, if not
equipped with a tube.
The cord, which was marked in sequential 1-foot increments, was lowered
into the well until the probe reached the water. The probe was then slowly
raised and lowered until the exact point at which contact was made was
determined. The cord at the very top of the PVC tube was then pinched by
the CWM sampling contractor and the distance from the bottom of his fingers
to the next higher cord marker was measured with a 1-foot wooden ruler with
1/16-inch subdivisions. Depth to water is calculated by subtracting the
reading made with the ruler from cord marker value,
Water level measurements were made with reference to the top of the
1-inch PVC tube or the access port, which was not the surveyed elevation
point at the well. The top of the casing at each well was the surveyed
point, thereby requiring a correction to be made for the difference between
the PVC pipe and the top of casing elevations when calculating water level
elevations. Task Force personnel requested this information, but it was
not provided.
-------
After measurement, the cord was rewound onto the spool and was rinsed
periodically with deionized (DI) water from the CWM sampling contractor's
laboratory. The probe was also rinsed with DI water after sounding, PVC
gloves were worn by the CWM contractor personnel handling the samples and
samp!ing equipment.
The CWM contractors were consistent in the procedures and care taken
while measuring water levels and cleaning equipment. Although the proce-
dures were consistent and results are reproducible (verified in the field),
the accuracy is suspect because of the wells not being vertical, as dis-
cussed in the Monitoring Wells section.
Purging
The volume of water in the casing is calculated, using the depth to
water measurement, total well depth (from construction records) and casing
diameter, The volume of water in the casing is used to compute purge
volumes by multiplying by three, except where removal of this; quantity of
water is not practicable. This was the case at K-4, where approximately
one and one-half volumes were purged. Purge volumes were measured with a
5-gallon bucket, which was filled from the pump discharge line and emptied
when full. Company personnel were requested to provide a list of wells not
routinely purged of three casing volumes and the approximate purge volumes
for those wells. The requested information was not provided for wells rum-
bered higher than K-17,
Purged water was allowed to run directly onto the ground for all wells
except K-4. This is not a good practice as the water may later be found to
contain contaminants and remedial action or appropriate closure may be
required for the affected area. CWM had previously determined that the
ground water at K-4 contains hazardous waste constituents; therefore, purge
water was poured from the 5-gallon bucket into a large drum. CWM personnel
stated that the K-4 purge water is disposed of in an onsite hazardous waste
management unit. Otherwise, the purging procedures are adequate.
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38
Sample Collection, Handling, Preservation and Field Measurements
Wells sampled during the Task Force site inspection, except K-13, were
fitted with Grundfos stainless steel, submersible impeller pumps powered by
a gasoline generator. The generator was placed down or cross-wind from the
well during sampling to avoid potential contamination by the exhaust. Well
K-13 was equipped with a high-pressure Well Wizard bladder pump, driven by
nitrogen gas and regulated by a high-pressure control box. The wells with
Grundfos pumps discharged through a 1-inch diameter galvanized steel pipe.
During sampling, a gate valve on the purging discharge line is used to
divert flow to a;teflon sampling tube. The Well Wizard discharges at a
rate low enough (~500 ml/minute) so that separate purging and sampling
lines are unnecessary; a single dedicated polypropylene tube is used.
The Grundfos pumps are used to purge and sample the 4-inch diameter
wells because, according to CWM personnel, they are the most practical way
of removing the water considering the volumes required (hundreds of gallons)
and the depth to ground water (several hundred feet), A recent study
indicates that submersible centrifugal pumps, such as the Grundfos, cause
sample alteration as a result of a partial vacuum developed by the impel-
lers.2 Heat produced as a result of friction between the water and impel-
lers can increase the temperature of water passing through the pump.* The
principal effect is degassing of the samples, which may alter levels of
parameters such as volatile organics, pH, alkalinity and others.
During sample collection at wells equipped with the Grundfos pumps,
especially at K-3, many small gas bubbles were observed in the volatile
organic sample vials filled directly from the discharge tube by the CWM
contractor. The sampler had to let the bubbles dissipate for several
minutes before the vial could be sealed with no head space. Foaming was
observed in the pump discharge at well K-8.
Average temperature increases of 14% were reported in the cited
reference.
-------
Whether the Grundfos pumps have significant effects on sample collection
at the Kettleman Hills wells has not been demonstrated in the CWM reports
reviewed by Task Force personnel, The effects need to be studied, documented
and appropriately addressed before the sample collection portion of the
monitoring program is considered for acceptance.
Field measurements were being satisfactorily performed 'For specific
®
conductance, temperature and pH using a Hydac Tester , manufactured by
Cambridge Scientific: Industries, Cambridge, Massachusetts. The meter was
calibrated prior to field measurements for each well with prepared,, iced
standards for conductance and pH. Conductance standards of 250 and 2,600
umho/cm and pH standards of 4, 7 and 10 pH units were used, The meter
probe was rinsed with DI water between standards and before and after
measuring the sample, CWM contractor personnel measured specific conduc-
tivity four times and pH three to four times on the aliquot collected at
each well. The results are recorded on a field record form (CC-2) provided
by the contractor laboratory.
After making the field measurements, samples were collected for analysis
by the CWM contractor laooratory [Table 9], The usual procedure is for CWM
contractor personnel to first fi1! sample bottles for "totaV'-type analyses
(e.g., total organic: carbon and total organic halogen) and volatile organics
directly from the pump discharge line. An in-line filter* is then installed
and all other samples are collected. Samples were preserved "immediately
after collection. The procedures for sample handling (except for filtering),
preservation and field measurements were acceptable.
Hydac Tester is a registered trademark and will hereafter be showv
without ®.
Sample Pro 0.45 micron High Capacity Field Filter manufactured by QED
Environmental Systems, Ann Arbor, Michigan, The filter media is an
acrylic polymer with a polypropylene binder.
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40
Table 9
ANALYTICAL PARAMETERS, VOLUMES AND
PRESERVATIVES FOR CWM SAMPLES
Parameter Container Preservative
Volatile organics 40-in£ glass Sodium thiosulfate
Metals* 1 liter Nitric acid (HN03;.
N03 125-m£ amber glass Sulfuric Acid (H2504)
Conventionals** 1 liter None
* Includes calcium, magnesium, sodium, potassium and iron.
** Includes alkalinity, chloride, sulfate, fluoride and total
dissolved solids
Shipping and Chain-of-Custody
The sample bottles are all prepared by the principal contractor labora-
tory, ETC, in Edison, New Jersey, to ensure uniform procedures, The bottles
are pre-1abeled 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 shipped in small vials attached to it.
Once the samples were collected, filtered (where done) and preserved,
they were placed in the shuttles, which are insulated containers with
fitted plastic foam inserts for the bottles. A signed chain-of-custody
form (CC-1), designating the analytical requirements, accompanied each
sample. This form also indicated the location, date and time of sampling;
the sample size and preservatives; whether the sample was filtered and the
numbers of the custody seals. Then, "blue ice" packs, frozen in an onsite
freezer, were placed in the shuttles to cool the samples during shipment.
After completing and enclosing the sampling documents, the shuttle was
secured with a numbered plastic seal and shipped to the laboratory, The
shipping and chain-of-custody procedures were consistent with those des-
cribed in the corporate ground-water sampling manual and are acceptable.
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41
SAMPLE ANALYSIS
Presently, the ETC laboratory is responsible for all ground-water
monitoring analyses, however, sampling personnel perform pH, conductance
and temperature measurements in the field, The ETC laboratory was inspected
by Task Force personnel during the week of July 15, 1985, as part of another
site investigation. The inspection was conducted to determine if priority
pollutant analyses and analyses required by the interim status RCRA regula-
tions were being properly conducted. These analyses include those done on
samples from the Kettleman Hills facility except for a sample from well K-4
analyzed for the Part 261, Appendix VIII parameters,
Some inadequacies in the present laboratory procedures were found, As
previously discussed, samples for semi-volatile 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 are
determined.
ETC Method GC/MS-1-Q02 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 are not capable of reliably measuring levels
near the drinking water limits for these parameters. Furnace atomic absorp-
tion spectroscopy should be used.
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. This
results in the loss of purgable (volatile) organic carbon. Analyses must
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42
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 methylene 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, TOX analy-
ses should be performed in an area isolated from the use of solvents. At
the recommendation of the inspector, ETC has reportedly moved the TOX
instrument to an isolated area,
f^ONITORING WELLS
At the time of the Task Force inspection, CWM had completed 41 wells.
Of these, 21 were designated as monitoring wells, 4 as assessment wells and
16 as observation wells [Table 10]. The following discussion addresses
location and construction of wells installed by the time of the Task Force
inspection.
Well Locations
The dipping geologic structure and similarity of the stratigraphic
intervals complicate siting of monitoring wells at the facility. Directly
beneath any given waste management unit, the outcropping beds are unsaturated
and remain so for several hundred feet downdip (to the southwest) [Figure 3],
Wells installed to ground water at the limit of the waste management area
(i.e., near the waste boundary), as required by the State permit and RCRA
regulations, would have to penetrate several relatively impermeable zones.
These wells would not immediately (if ever) detect leakage. Consequently,
wells have to be drilled some distance from the waste management units in
order to monitor ground water in the permeable zones that crop out under
them.
The characteristics of the stratigraphic intervals make identification
of the zones targeted for monitoring difficult in borings made downdip from
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43
Table 10
KETTLEMAN HILLS FACILITY WELLS
AS OF AUGUST 1, 1985
Well
Identification
Number
K-l
K-2
K-3
K-3a
K-4
K-4a
K-5
K-5a
K~6
K-8
K-9
K-10
K-lOa
K-I1
K-lla
K-12
K-13
K-14
K-15
K-16
K-16a
K-17
K-17a
K-18
K-19
K-20
K-21
K-22
K-23
K-24
K-25
K-26
K-27
K-28
K-29
K-30
A-l
A-2
A-2a
A-3
A-4
a M denotes
b O denotes
c A denotes
Designation
M3
M
M
ob
M
0
M
0
M
M
M
M
0
M
0
M
M
M
M
M
0
M
0
M
0
M
0
0
M
0
0
0
0
M
0
M
AC
A
0
A
A
a monitoring well.
an observation well,
an assessment well
(part of K-4 assessment
program).
-------
-------
45
the waste units. These difficulties arise especially where the composition
of the strata changes gradually and where interbedded sands, silts and
clays are not readily distinguishable.
To determine if monitoring wel's are in the zone int^'cated by CWM
consultants, data (and the reliability of those data) from selected wells
were evaluated. The data reviewed included well deviation survey results,
geologic cross sections, boring logs, well construction diagrams and bore-1
hole geophysical log:; (natural gamma, spontaneous potential and resistivity),
Data presented on zones monitored by the wells in the various CWM
reports were incomplete, inconsistent and; in some cases, erroneous. The
adequacy of well locations could not be reliably determined. Inconsisten-
cies were found in the monitored zones designated for the wells, as indicated
on Table 11, Where beds are easily identified, CWM has identified the
monitored zone adequately. Where bed definition is difficult, identifica-
tion of the zones monitored is uncertain.
The vertical deoth at which marker beds are encountered in the borings
can sometimes be used to help identify the stratigraphic interval and the
zone targeted for monitoring within it. Nonvertical depth can result in
erroneous determinations. Many of the boreholes drilled for monitoring
wells are not straight; a common result of drilling at depth. CWM consult-
ants conducted a deviation study on the monitoring and assessment wells
(except for K-23) to determine the true vertical depth and a correction
factor to be applied to measured water levels. Knowing the angle of devia-
tion also enables calculation of the true thickness of the stratigraphic
interval monitored by the well. At some wells (e.g., A-2, K-13, K-19,
K-21) deviation surveys were not performed for their full depth [Table 12].
True vertical depths for these wells are unknown because the data are
i ncomplete.
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46
Table 11
MONITORED ZONES OF SELECTED MONITORING,
OBSERVATION AND ASSESSMENT WELLS
Well
Monitored Unit
Identified by Facility
Bed Actually Monitored
A-l
A-2
A-3
A-4
K-i
K-3
Neverita B
Neverita B
Sandstone in interbedded
zone above Neverita B
Sandstone in interbedded
zone below Neverita B
Tuffaceous A
Sandstone between
Tuffaceous A and B
Neverita B
Neverita B, slightly above inter-
bedded zone of K-4
Claystones or clayey interbedded
Neverita B
Insufficient data
Top of Tuffaceous A
Tuffaceous A
K-5
K-6
K-10
K-ll
K-12
K-13
K-17
K-18
K-19
K-24
K-25
a.
Tuffaceous B
Neverita B
Pecten A
Ac i 1 a A
Neverita A
Pecten A
Neverita A
Pecten B
Neverita A
Tuffaceous A
Tuffaceous B
Observation well
Tuffaceous B
Neverita B
Pecten claystone
Acila A sandstone and overlying
claystone and interbedded strata
Neverita A
Completion uncertain, may be in
interbedded strata below Pecten
marker bed
Top of Neverita A and overlying
interbedded zone
Interbedded standstone and clay-
stone including Trachycardi urn
marker bed
Neverita A
Tuffaceous A
Tuffaceous B
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47
Table 12
DIFFERENCES BETWEEN CASING DEPTH AND DEVIATION
SURVEY DEPTHS FOR SELECTED WELLS
Moni
a
b
c
tori ng Wr "" 1
A-2
K-13
K-19
K-21
Casing Depth3 (ft)
484
466°
456
565
Deviation Surve\
Depth
122
445
425
345
From well-construction diagrams submitted November 8,
1985
From a deviation
submitted to EPA
Bottom of inner 3
study conducted in August
November B, 1985
-inch casing
1985 and
Post-deviation study reports were found to be inconsistent. For
example, water-level data "corrected" after the deviation study and submit-
ted to EPA November 8, 1985 indicate K-21 does not deviate. Data from the
deviation study in the same submittal indicate that at a depth of 345 feet,
the drift angle in K-21 is 9 degrees. Inconsistencies were also found in
the deviation data for well K-18 where two companies did surveys and the
results for connected depths differed by 4 feet, This single inconsistency
suggests that the deviation data are suspect.
Geologic cross sections contained in the November 8, 1985 report, sub-
mitted to EPA, do not reflect well depths corrected for borehole deviation
and are unreliable. Bottom elevations shown for some wells (e.g., K-17
K-24, A-4) do not correlate with depths indicated on boring "ogs. The
Pecten sandstone, although discussed in the texts of CWM hydwogeologic
reports, is not identified on any geologic cross-section diagram, well logs
or stratigraphic column. Whether wells were screened in the Pecten sand-
stone could not be confirmed.
Well depths reported in boring logs and construction diagrams were
also found to be inconsistent. For example, the boring log ':ndicates K-13
is drilled to a depth of 478 feet, whereas, the well construction diagram
indicates a depth of 475 feet. These discrepancies indicate that some of
the depth/elevation data for the wells are erroneous,
-------
48
The geophysical data provided the most reliable basis upon which to
judge which geologic units are being monitored. Borehole geophysical data
indicate that numerous thick and thin geologic units beneath the Kettleman
Hills facility exhibit distinctive electric properties. These units are
continuous and can be correlated across the site with confidence, Geophys-
ical logs were run in all of the Company-designated monitoring and assess-
ment wells. The logs were not run the full length of the borehole for
every well (e.g., A-l, A-3, A-4, K~5, K-10 and K-24); therefore, the data
are incomplete.
Well Construction
Construction details for the CWM designated ground-water monitoring
wells are listed on Table 13. The wells were drilled using an air-rotary
drilling method and have polyvinylchloride (PVC) casings, screens and
bottom cap [Figure 4]. The annular space around the casing is sealed with
cement grout over a sand pack that surrounds the well screen. Whether the
*
grout and sand pack were properly installed could not be determined from
the information provided by CWM. The detailed boring and well installation
logs are contained in the field geologist's logbooks, which were not pro-
vided to Task Force personnel during the inspection.
The wellhead assembly consists of a sampling apparatus and a protective
aluminum box with a security lock [Figure 5]. The sampling apparatus con-
sists of a galvanized steel pumpline and discharge line and a Teflon or
polypropylene dedicated sampling tube. Flow from wells equipped with
Grundfos pumps is regulated through the discharge line with a valve during
sampling to relieve pressure on the small-diameter sampling tube.
The condition of the wellhead assembly and security was adequate for
most wells. A newly-drilled well, K~6, was not yet complete or secure,
although casing and pump had been installed. The annular space near the
surface had not been grouted nor haa any secure box been installed.
-------
49
Table 13
COMPANY DESIGNATED MONITORING WELLS
KETTLEMAN HILLS FACILITY
Well
Identi f ication
Number
K-l
K-2
K-3
K-4
K-5
K-6
K-8
K-9
K-10
K-ll
K-12
K-13
K-14
K-15
K-16
K-17
K-18
K-20
K-23
K-28
K-30
A-l
A- 2
A- 3
A-4
Date
Instal led
02/29/84
03/26/84
04/30/84*
05/21/84*
06/14/84*
06/30/S5*
09/11/64*
10/15/84
07/12/64
08/15/84
07/14/85
07/11/84*
07/30-84
08/28/84
07/31/84
09/10/84*
07/20/85*
07/18/85*
Not reported
07/21/85*
01/09/85*
Not reported
Not reported
Not reported
Total
Casi ng
Lengtn
(ft)
428
429
433
313
520
452
464
455
469
459
510
466
598
503
365
435
160
529
675
447
No
369
484
460
502
Screened
Length
(ft)
20
20
50
20
40
30
20
20
10
60
70
20
30
30
70
50
110
50
95
70
Data Provided
30
38
30
10
Screen
Opem ngs
( in)
0.040
0 . 040
0.040
0, 040
0.040
0.013
0.013
0 013
0 040
0.013
0.013
0 013
0 010
0.013
0.040
0.013
0 013
0.013
0 013
0 013
0.013
0, 010
0 010
0 010
Sand Pack
Interval
(ft)
390-428
390-4,;'9
336-4;i3
260-31.3
459-550
412-468
435-464
421-4'bS
439-4S9
335-4i,9
432-S:.0
439-475
535-5:38
455-503
275-3(55
375-440
490-629
462-520
567-678
367-455
331-374
436-500
420-460
482-505
Sana Pack
Length
38
39
97
53
61
56
29
34
30
124
78
36
63
48
90
65
130
58
111
88
43
64
40
23
£>st» Is jast day of boring
-------
50
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z
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, s / , , /•»( AVCTrMUC
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//^7/y_ First wat«r tncounttrtd (390 )
^>VV«dd«d CLAYSTONE and SANDSTONE
. . * *— SANDSTONE
/ / / / /~£— CLAY STONE
Wat to Scolt
TYPICAL WELL COMPLETION
Figure 4
(from EMCON Associates)
-------
5 Long 1/9" |,D.
sampling
Gatt vQtvt
12"- 16" Long 1/8" I. D.
sampling lubt (T«fion)
Sam pi* bottlt
(Siaia or ptantie)
Gammincl
box with lid
Gatt volvt (Brni)
Sourvdtr tub* (pvc;
1/2" Eltctricai
Rtductr bushing
Pump lint
(GaNoniztd
4 PVC W«!l
eating
3* x 3 Concrttt
pod
TYPICAL WELL HEAD SAMPLING APPARATUS
Figure 5
(from EMCON Associates)
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52
Well completion diagrams were provided for each well except K-30, but
detailed logs on the well construction were not provided by CWM, as pre-
viously discussed. These logs should be evaluated before the wells are
accepted by EPA, especially in view of the location problems described,
Sand pack and screen lengths on wells within a monitored unit vary
widely [Table 14] and may be contributing to problems in determining
hydraulic gradients and ground-water flow directions, Within saturated
strata, natural vertical hydraulic (pressure) gradients exist. Generally,
the water level measured in a well represents the average pressure over the
length of the sand pack where the level is above the pack. Where the level
is below the top of the sand pack, the water level in the well represents
the average pressure from the bottom of the pack to the top of saturated
materials within the bed or beds monitored.
Where wells are installed to monitor a single bed or group of beds for
determining gradients and flow directions, they should be at the same depth
within 'the bed and the sand packs should be approximately the same length.
Otherwise, the wells would not be monitoring corresponding pressure gradient
intervals, which could result in erroneous predictions of ground-water flow
directions. When vertical gradients are high or unknown, uniform sand pack
lengths and well depths into the bed are critical factors in the design of
the monitoring well network.
Reports provided to Task Force personnel contain no information on
vertical gradients within monitored beds and intervals, yet screen and sand
pack lengths are not uniform within them. For example, of the six wells
monitoring the Neverita B interval, which includes contaminated well K-4*,
sand pack lengths vary from 43 to 60 feet and screen length varies from 20
to 44 feet. Of the four wells in the Acila A interval, which crops out in
the proposed facility expansion area, sand pack lengths range from 62 to
124 feet and screen lengths range from 46 to 95 feet.
See Table 13,
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53
Table 14
SAND PACK AND SCREEN LENGTH IN WELLS
WITHIN REPORTED HYDROLOGIC INTERVALS
KETTLEMAN HILLS FACILITY*
Well Hydro log ic
Number Interval
K-12
K-12
K-17
K-19
K-28
K-29
K-4
K-6
K-27
A-l
A-2
A-2A
K-l
K-24
K-26
K-2
K-5
K-25
K-10
K-13
K-ll
K-21
K-22
K-23
a
b
Neverita A
Neverita A
Neverita A
Neverita A
Neverita A
Neverita A
Neverita B
Neverita B
Neverita B
Neverita B
Neverita B
Neverita B
Tuffaceous A
Tuffaceous A
Tuffaceous A
Tuffaceous B
Tuffaceous B
Tuffaceous B
Pecten A
Pecten A
Ac i 1 a A
Ac i 1 a A
ACT la A
Acila A
Source: CWN RCRA Part
Requirements, November
Includes four 10- foot
Sand Pack
Length
(ft)
78
90
65
85
88
90
53
56
60
43
64
53
38
51
30
39
61
47
30
36
124
62
100
111
B Application
8, 1986
sections and
Screen Water Level
Length Below top of
(ft) Sand Pack
70
70 Yes
50 yes
70
70
69 Yes
20 Yes
30
35 Yes
30 Yes
38
44
20
40
20
20
40
30
10
20
60 Yes
46
70h
95
, Additional Information
three 10-foot blanks
-------
54
Even if the problems in identifying the zones actually being monitored
by the wells are resolved, the wells may still not yield enough correspond-
ing water level data to determine gradients and flow directions because of
the widely variable sand pack lengths.
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55
MONITORING DATA ANALYSIS FOR INDICATIONS OF WASTE RELEASE
This section presents an analysis of both Task Force and CWM monitoring
data regarding indications of apparent or potential leakage from the waste
management units, Field and laboratory analytical results from samples
collected by Task Force personnel are presented in Appendix C, together
with the analytical methods.
Task Force data indicate the presence of organic hazardous waste
constituents in three wells [Table 15]. The compounds are identified as
waste constituents because receiving logs and limited preacceptance informa-
tion indicate that, except for 2-nitrophenol, they were present in incoming
waste loads,* Most of the waste constituents detected in well K-4 have
been previously detected and confirmed by CWM, as shown on Table 16.
CWM has not previously reported detecting organic compounds in well
K-8. The presence of chemicals in this well is suggested by vapor monitor-
ing at the wellhead with an HNU meter before sampling.** Vapor readings of
5 to 10 ppm were detected at well K-8, whereas none was detected at the
other eight wells. Manufacturer's specifications for the HNU meter report
a high sensitivity to the compounds detected (carbon disulfide and toluene),
CWM also has not previously reported detecting organic compounds in
well K-13. The presence of the compound identified (1,1,1-trichloroethane)
is supported by the purgeable organic halide (POX) data. POX analysis
results indicate the presence of volatile organic compounds contain'1 ng the
halogens chlorine, bromine and/or iodine (e.g., trichloroethane). The POX
concentration is essentially the same as the trichloroethane concentration,
which accounts for that halogenated volatile organic compound,
Zinc concentrations in the monitoring well samples suggest dissolutian
of the galvanized riser pipe in wells equipped with Grundfos pumps. As a
* JRecords obtained during 1984 NEIC investigation
** See Investigation Methods section.
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56
Table 15
ORGANIC COMPOUNDS DETECTED IN GROUND-WATER SAMPLES
Kettleman Hills Facility
Compound Value (a) Value Value
Carbon disulfide
Toluene
1,1,-Trichloroethane
Chlorobenzene
Methylene Chloride
Benzene
1,1-Dichloroethane
Chi oroform
Tetrachloroethene
Total xylenes
Trichloroethene
1,1-Dichloroethene
2-Nitrophenol
BMDL-5
8 BMDL-5
BMDL-5 BMDL-5
670
110
41
49
39
11
13
16
BMDL-5
150
a = Concentrations are reported in ug/'H.
EKDL = Present Below Method Detection Limit, number is
Method Detection Limit
-------
57
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-------
58
result, they may not be representative of ground-water quality. Galvanized
pipes are coated with zinc by hot dipping or electroplating processes to
increase corrosion resistance, However, corrosion products include zinc,
iron and manganese (and trace cadmium).3 The range of zinc concentrations
in samples from wells with galvanized riser pipe is 590 to 18,100 ug/£.
Well K-6, installed just before the Task Force inspection began, had the
lowest concentration; well K-4 had the highest. By contrast, the sample
from well K-13, which is equipped with a teflon pump assembly and a polypro-
pylene riser tube, contained less than detectable concentrations of zinc
(<120 ug/£).
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59
REFERENCES
1, U, S. Environmental Protection Agency, March 1979, "Methods for Chemical
Analysis of Water and Wastes", EPA-60Q/4-79-020, p, METALS-5.
2. Houghton, R, L, and Berger, M. E,, May 1984, "Effects of Well-Casing
Composition ana' Sampling Method on Apparent Quality of Ground Water",
proceedings of the Fourth National Symposium and Exposition on Aquifer
Restoration and Ground-Water Monitoring sponsored by the National Water
Well Association and EPA, pp. 203-213.
3. Barcelona, M. J,, Gibb, J. P, and Miller, R, A., August 1983, Illinois
State Water Survey Report 327: "A Guide to the Selection of Naterinls
for Monitoring Well Construction and Ground-tfater Sampling", Contract
No. EPA CR-809966-01,
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APPENDICES
A CONSENT AGREEMENT
B DESCRIPTION OF STRATIGRAPHIC INTERVALS
C ANALYTICAL RESULTS FOR TASK FORCE SAMPLES
-------
APPENDIX A
CONSENT AGREEMENT
-------
-------
A-l
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION 9
IN RE: ) Docket Nos. RCRA-09-84-0037,
) TSCA-09-84-OOQ9
CHEMICAL WASTE MANAGEMENT, INC.,)
) CONSENT AGREEMENT
Respondent, ) AND FINAL ORDER
I, These actions were instituted by a Determination of
Violation, Compliance Order and Notice of Opportunity to
Request a Hearing issued by the United States Environmental
Protection Agency ("EPA" or "Complainant") on July 3, 1984
("Original RCRA Complaint".) and an Amended Determination of
Violation, Compliance Order and Notice of Opportunity to
Request a Hearing issued on June 6, 1985 ("Amended RCRA
Complaint") under the Resource Conservation and Recovery Act,
("RCRA"), 42 USC §6901 et seq,, and a Complaint and Notice of
Opportunity for Hearing ("TSCA Complaint") issued on June 6,
1985, under the Toxic Substances Control Act ("TSCA") 15 USC
§ 2615.
-------
A-2
II. The Amended RCRA Complaint alleges that Chemical Waste
Management, Inc. ("Respondent") was in violation of Sections
3004, 3005 and 3006 of the Resource Conservation and Recovery
Act ("RCRA"), 42 USC §§6924 and 6926; 40 CFR Part 265,
regulations promulgated by the Administrator, United States
Environmental Protection Agency, to implement those sections of
RCRA, and Sections 25159.6 and 25200.5(b)(3) of the Health and
Safety Code, State of California, at Respondent's facility
located in Kettleman Hills, California, EPA ID Number
CAT000646117 ("the Facility"). The Facility is an existing
hazardous waste management facility as defined in 40 CFR
§^60.10. The State of California, Department of Health
Services ("Intervenor" or "DOHS") is a party to the proceeding
instituted under RCRA. Respondent filed an Answer to the
Amended RCRA Complaint on August 29, 1985 which denied the
allegations of the Amended RCRA Complaint.
III. The TSCA Complaint alleges that Chemical Was'::e
Management, Inc. ("Respondent") was in violation, of Section 15>
of TSCA, 15 USC §2614, and 40 CFR Part 761, regulations
promulgated by the Administrator, United States Environmental
Protection Agency, to implement that section of TSCA at
Respondent's Facility. Respondent filed an Answer to the TSCA
Complaint on July 30, 1985, which denied the allegations of the
TSCA Complaint.
IV. The EPA Regional Administrator has jurisdiction over
the subject matter of the actions commenced pursuant to Section
-2-
-------
A-3
3008 of RCRA, 42 USC §6928, and 40 CFR §§22.04(a) and 22.37,
and Section 16(a) of TSCA, 15 USC 2615(a) and personal
jurisdiction over the parties consenting hereto.
V. In settlement of the above described TSCA and RCRA
actions, Complainant, Respondent and Intervenor have agreed to
the entry of this Consent Agreement and Final Order ("Final
Order") prior to the presentation of any testimony or evidence
and without adjudication of any issue of law or fact, For the
purpose of this Consent Agreement and Final Order, Respondent
neither admits nor denies the specific factual allegations set
forth in the Original RCRA Complaint, Amended RCRA Complaint
and TSCA Complaint. Complainant, Respondent and Intervenor
agree to waive any right to a hearing on the Original RCRA
Complaint, Amended RCRA Complaint and TSCA Complaint and
consent to the issuance of this Final Order without
adjudication. Nothing in this Final Order shall be construed
as an admission by Respondent of any violation or any issue of
law or fact, nor shall this Final Order be used against
Respondent as evidence of any violation or as an admission
against interest, nor shall it prejudice or impair any right,
remedy or defense Respondent may have in any other or future
legal proceeding. This Final Order supersedes the previous
RCRA compliance orders issued on July 3, 1984 and June 6, 1S85.
VI. Except as specified herein, nothing in this Final
Order shall be binding on any agency office, department, or
board of the State of California except the Department of
•3-
-------
A-4
Health Services and any successor agency thereto, It is the
intent of the Parties that nothing in this Final Order is
inconsistent with the provisions of the California
Porter-Cologne Water Quality Control Act and regulations
promulgated thereto.
VII. All days set forth in this agreement shall run
consecutively from the effective date of this Final Order.
VIII. Respondent shall undertake the following tasks
enumerated below:
A. ENVIRONMENTAL AUDIT
Within forty-five (45) days after the effective date
of this Final Order, Respondent shall submit to EPA and DOHS
the scope of work for the services of a third-party consultant
who shall be expert in environmental auditing, auditing
environmental management systems and auditing RCRA and TSCA
waste management operations. The scope of work and consultant
both shall be agreed upon by EPA, DOHS, and Respondent in
writing prior to the consultant commencing the performance of
the professional services as more fully set forth herein
below. The consultant shall be retained and the scope of work
shall be designed to audit waste operations and environmental
management systems at the Facility and in the Respondent's
corporate Environmental Management Department as they affect
RCRA and TSCA compliance at the Facility.
1. Within one year after written agreement upon the scope
of work and the consultant, said third-party consultant shall
-4-
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A-5
submit separate written reports to Respondent regarding RCRA
and TSCA compliance at the Facility, These reports shall:
a. Identify and describe the existing Facility waste
management operations. Identify and describe Respondent's
Environmental Management Department, environmental management
systems, and policies and prevailing practices as they affect
RCRA and TSCA compliance at the Facility,
b, Evaluate such operations, systems, practices and
policies and identify and describe fully the perceived
strengths and any weaknesses in such operations, systems,
practices and policies, to the extent practicable,, regarding
their ability to promote compliance with applicable RCRA and
TSCA requirements. The consultant shall apply its expertise
and judgment to the foregoing data base, utilizing such factors
as the consultant believes to be relevant and necessary to
achieve compliance with RCRA, TSCA, and DOHS regulations
implementing RCRA.
c. Based on the evaluation required in paragraph
A.I,a. and b. above, the consultant shall identify and describe
fully, with supporting rationales, the perceived areas, if any,
where Respondent's waste management operations and
environmental management systems, practices and policies may be
significantly improved to achieve RCRA and TSCA compliance
listing specific options for any improvements at the Facility
in the following specific areas:
-5-
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A-6
x (1) compliance and waste management operation,
staffing, education and experience requirements;
, (2) compliance management, lines of authority,
Respondent's corporate Environmental Management Department and
relationship to the operating facility manager;
- (3) personnel training for individual employees,
compliance obligations and emergency spill response;
v (4) Operations and Maintenance ("0 & M")
procedures for pollution prevention and waste management
equipment;
' (5) evaluation of interim stabilization units
for ability to physically and chemically stabilize liquid
wastes as compared to EPA's draft Statutory Interpretive
Guidance, "Prohibition on the Disposal of Bulk Liquid Hazardous
Waste in Landfills," (May 6, 1985).
- (6) preparation of Quality Assurance and Quality
Control programs for sampling and analysis and for
environmental testing procedures, including Facility
laboratories and contract laboratories for the Facility;
- (7) preparation and review of Incident Reports
with specific recommendations for corrective steps and
preventive O&M, along with reporting procedures for these
recommendations to corporate headquarters.
2. Respondent shall notify EPA upon receipt of said
reports, and within ninety (90) days after receipt of final
reports, Respondent shall submit to EPA and DOHS the portion of
-6-
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A-7
the reports containing findings and recommendations of the
consultant, together with Respondent's evaluation of each
option it has selected for adoption and the reasons for
rejecting other options. The report by Respondent shall set
forth the specific actions the company shall take and a
schedule for implementation of the recommendations adopted by
Respondent.
3, All documents submitted to EPA and DOHS pursuant to
paragraph A are considered to be "voluntarily submitted
information" as defined in 40 C.F.R. §2.201(1) and will be
treated as confidential to the extent authorized by law
including without limitation such protection as is allowed by
TSCA (for the TSCA report) and.RCRA (for the RCRA report).
4. EPA and the State agree that such documents shall not
be used to initiate an enforcement action or as direct evidence
of a violation, but may be used as evidence of the existence of
any violation which may remain uncorrected beyond six months
after the delivery of the Audit Report and as evidence of
knowledge or duration of a violation, provided, however, that
Respondent does not waive any legal rights it may have to
object to the admissibility of such evidence. It is intended
that documents prepared for Respondent pursuant to paragraph A
are not required by law or regulation,
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A-8
B. GROUND WATER MONITORING
1. Hydrogeologic Site Investigation
a. Respondent shall have submitted a Report to EPA
and DOHS by October 31, 1985, which summarizes the re.;u-lts of
the hydrogeologic investigation of the site conducted to date
by the Respondent's independent consultants. The Report shall
present all data received or collected since the August 1985
data submission to EPA. This shall include, but not be limited
to, the following:
1. geophysical logs
2, lithologic logs
3. construction details on all new wells
4. final geologic maps
5, water level readings from all existing
monitoring wells
6. data from packer and pump tests
b. The Report shall also present the results of the
K-4 ground water quality assessment program which meets the
requirements of 40 C.F.R. § 265.93(d). The Report shall
include the following data:
(1) Analytical data from well K-4 for the
constituents listed in 40 CFR Part 261, Append:.!. VIII.
(2) Analytical data from monthly sampling for
three months of wells A-2 and K-4 and two months for
well A-l for all of the parameters specified in the
August 15, 1984, report submitted by Respondent entitled
~ 8 -
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A-9
Groundwater Quality Assessment Program plus all of the 40
CFR Part 261, Appendix VIII parameters detected in well
K-4 .
(3) Results of hydraulic tests of wells A-l,_
A-2, K-4, and wells directly above and below the water
bearing rone of K-4.
(4) Ground water flow rate and direction for the
K-4 water bearing zone in the vicinity of well K-4 based
upon piezometric data obtained from (at least) wells A-l,
A-2, and K-4,
(5) Unless otherwise requested by EPA or DOHS
Respondent shall continue to monitor and assess the K-4
area in accordance with 40 C.F.R, §265.93(d)(7),
»
c. Respondent agrees to supplement the Report to
include analytical data for monthly sampling for three months
for well K-6 and one month for well A-l (for the same
parameters cited in subparagraph B(l)(b)(2) above) to be
performed and submitted to EPA and DOHS in accordance with the
schedule set forth in subparagraph B.2.b.(5)(a)-(c) below.
d. Respondent shall extract ground water from the
K-4 water bearing rone which has elevated levels of chemical
constituents. Any ground water extracted from the K-4 water
bearing zone shall be to discharged only to lined surface
impoundments at the Facility,
e. Within 30 days of the effective date of this
Final Order, the Respondent shall submit to EPA and DOHS a
.9.
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supplemental report which shall present the results of
Respondent's assessment of the source of toluene detected in
various samples extracted from monitoring wells at the
Facility. If the supplemental report does not indicate that
the toluene is due to causes such as well installation, well
sampling, sample analysis, or natural sources, the Respondent
shall develop and initiate an assessment program required by 40
C.F.R. 265.93(d) for determining whether toluene is present in
ground water.
f. The Report shall include a site-specific ground
water sampling and analytical protocol for the Facility. The
sampling protocol shall be used by Respondent and all other
parties whenever samples are taken from monitoring wells at the
*
Facility. The protocol shall include the following items:
(1) Well evacuation procedures that will be
employed for each well. The equipment, purging rate
and purging volume that will be employed for each well
shall be included. To the extent feasible, all wells
must be purged in the same manner. If dewatering is a
problem, then lower purging rates shall be used or
Respondent shall document that inflowing water
cascading down the screen will not be significantly
affected In terms of the concentration of constituents
of concern (e.g. volatile organics). The use of
stabilized pH or specific conductance to indicate
adequate purging volumes shall not be used.
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(2) Sampling equipment that will be employed.
To the extent feasible, each well shall be sampled in
the same manner,
(3) Description of the materials of construction
of the sampling and purging assembly, Such materials
shall not significantly change the concentration of
the constituents of concern,
(4) Sample preservation and handling techniques
including provisions for field titration of samples as
appropriate,
(5) Procedures for decontaminating .sampling
equipment between sampling events,
(6) Procedures for measuring ground water
elevations at each sampling event,
(7) Chain-of-custody procedures to be used for
all phases of sample management,
(8) Laboratory analytical techniques including
quality assurance/quality control procedures and
EPA-approved analytical methods referenced in
subparagraph 2.b(3) below,
g, The Report shall include the details of the types
and formats of ground water quality data that will be submitted
in the future.
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2, Ground Water Monitoring Program,
a. On or before November 8, 1985, Respondent shall
assess and certify its compliance with the requirements of 40
C.F.R. Part 265, Subpart F,
b. Respondent also agrees to complete the following
tasks:
(1) Respondent shall submit by November 8, 1985
a map which identifies the number and location of all
interim status ground water monitoring wells at the
facility.
(2) Respondent shall arrange to make available
for review upon request by EPA and DORS at the offices
of Respondent's consultants driller logs and field
notes relating to the Facility,
(3) Respondent shall take water level
measurements and sample for ground water quality.
Such samples shall be analyzed for the following
parameters utilizing the procedures established by
SW-846:
(a) Volatile organics (Method 8240)
(b) Cyanides (Method 9010)
(c) Parameters required by 40 C.F.R. 255.92(b).
The first round of samples from all monitoring wells
shall be collected no later than November 8, 1985.
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(4) Respondent's first four rounds of sampling
shall include four replicate measurements of the
indicator parameters at upgradient (background) wells,
(5) The sampling and analysis required by
subparagraph B.2,b.(3) shall be repeated according to
the following schedule:
(a) Second round of sampling shall be
completed by December 8, 1985;
(b) Third round of sampling shall be
completed by January 8, 1986;
(c) Fourth round of sampling shall be
completed by February 8, 1986;
(d) First round of semi-annual sampling
shall be completed by March 8, 1986;
(e) Second round of semi-annual and annual
sampling shall be completed by April 8, 1986;
(f) Respondent's semi-annual sampling shall
include four replicate measurements of the
indicator parameters in all wells;
(g) Respondent shall submit the analytical
results of sampling within 60 days of sample
collection.
(h) Respondent shall submit the statistical
evaluations for the first two rounds of
semi-annual sampling within 75 days of sample
collection.
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(6) Thereafter, subsequent sampling and analyses
shall be performed in accordance with 40 C.F.R.
265.92(d) for the parameters set forth in 40 C.F.R.
265. 92(j).
c. Respondent further agrees to install a
groundwater monitoring well for each PCB landfill. The
monitoring wells shall be sited such that they monitor the most
permeable water-bearing zone for B-14 and the Neverita B sand
for B-16 which underly each PCB landfill. To the extent
feasible, the Respondent shall use the site specific RCRA
ground water sampling and analytical protocol for sampling
these wells. Respondent shall take water elevation
measurements and sample for ground water quality quarterly, -and
provide the sampling results to EPA and DQHS within 60 days of
sample collection. Respondent shall analyze for PCBs and any
other constituents found as a result of the analysis required
by subparagraph D.13 below.
C. LIQUID DISPOSAL
1. Respondent asserts that it has not treated or disposed
of waste at the Facility by means of land spreading since Apr:. 1
1984. Respondent shall not treat or dispose of waste through
land treatment at the Facility in the future unless it obtains
a final RCRA permit for such treatment meeting the requirements
of 40 CFR Part 264 and applicable state regulations. Closure
of former land spreading areas S-l through S-6 shall take place
in accordance with Paragraph D of this section.
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2, Respondent asserts that it has not treated or disposed
of waste in unit S-3 since March 15, 1985 and in S-5 since
April 1984, Respondent shall not treat or dispose of waste in
units' S-3 or S-5 in the future except as otherwise provided in
Paragraph D below or unless authorized under interim status or
by a final RCRA permit issued pursuant to 40 CFR Part 264,
3. Respondent asserts that it has been using lined
stabilization bins for the treatment of bulk and containerized
liquid waste at the Facility since May 8, 1985, Respondent
shall not place liquid wastes in trenches at the Facility prior
to stabilization. Respondent shall continue to physically and
chemically stabilize liquid waste, intended for landfill
disposal, in lined stabilization bins, as approved by DOHS
letter of January 17, 1985 or subsequent permit, in accordance
with EPA Draft Statutory Interpretive Guidance, "Prohibition on
the Disposal of Bulk Liquid Hazardous Waste in Landfills,"
(May 6, 1985), Respondent shall confirm the elimination of
free liquids through the use of the paint filter test on a
sample of the waste prior to disposal of the material,
Respondent shall document such stabilization by fully
completing and maintaining its "Stabilization Evaluation Test"
records prior to stabilization for each batch entering the
stabilization bins. Records of the paint filter test and
"Stabilization Evaluation Test" shall be maintained as part of
the facility operating records.
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D. CLOSURE AND SUBSTANTIAL MODIFICATIONS TO FACILITY
1. Respondent shall within 60 days of the effective date
of this Order amend the closure plan for the Facility submitted
to EPA on October 7, 1985, to set forth a closure plan for each
of the following waste management units not previously covered
by said closure plan:
a. P-l through P-20 f, PCS flushing/storage unit
b. B-l through B-16 g. Interim drum storage unit
c. S-l through S-6 h. Interim stabilization
d. Drum decant unit unit
e. Cyanide treatment unit
2. All of the units set forth in subparagraph D.I. shall
be closed with a cover design that meets the requirements of 40
C.F.R. Part 265, Subpart G.
3. Except as set forth herein, Respondent shall
immediately cease discharging waste to waste management units
designated as surface impoundments P-4 1/2, P-4C, P-L2A, P-13 ,
P-18 and landfills B-6, B-8, B-10, B-ll, B-15 and units S-2,
S-3 and S-5, Respondent shall cease discharging waste to
surface impoundment P-12 no later than January 1, 1986. The
closure plan for each of these units shall set forth a schedule
of closure of these units. Respondent shall not commence
closure of a waste management unit without obtaining prior DOHS
approval of the partial closure plan. Units P-18, S-!ii and S~6
(excluding the area of P-19 and P-20) shall be closed upon
closure of B-19. Units P-l, P-2, P-3, P-4, P-4 1/2, F-4C, S-l,
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B-l, B-4, B-5, B-6, B-8, original B-9, B-9 extension, B-1Q,
B-ll and B-15 shall be closed in accordance with the schedule
set forth in Table B. Units P-12, P-12A, P-13, S-2, P-5, and
S-3 shall be closed in accordance with the closure plan for
such units and in accordance with the schedule set forth in
Table B. The closure of units P-12, P-12A, P-13, S-2, P-5, and
S-3 shall not preclude the use of the closed area for future
waste management activities. The parties agree that Respondent
may continue to use the existing interim drum storage unit and
interim stabilization units in their present locations, until
closure of the B-9 expansion. The area of the existing interim
drum storage unit and interim stabilization units shall be
closed and the units shall be relocated upon DOHS approval upon
closure of B-9 expansion.
4.a. Respondent shall submit to EPA and DOHS no later
than the dates specified in column A of Tables A and B a
sampling plan for determining the extent of residual
contamination beneath surface impoundments designated as P-9,
P-12, P-12A, P-13, P-14, P-16, P-18, and P-19. The sampling
plan for these impoundments shall be similar to that set forth
in Attachment A.
b. By December 31, 1985, Respondent shall submit
detailed plans and specifications for P-19 to meet the minimum
technological standards established by EPA's Minimum Technology
Guidance Manual on Double Liner Systems (May 24, 1985) pursuant
to the Hazardous and Solid Waste Amendments of 1984, P-19 is
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approved by DOHS and EPA for operation and retrofit provided
the design, plans and specifications for P-19 conform to the
plans and specifications for P-9 (as modified by Attachment 3)
and further provided *-hat Respondent submits to EPA and DOHS
the sampling results and certification required by
Paragraphs 4.a. and 4.d., respectively.
c. Each of the surface impoundments P-9, P-14, and
P-16, is approved by DOHS and EPA for operation and retrofit in
accordance with Respondent's plans and specifications submitted
to EPA on August 9, 1985 (as modified by Attachment B) upon
submission to EPA and DOHS of the sampling results arid
certification required by Paragraphs 4.a. and 4.d. respectively
d. For P-9, P-14, P-16, and P-19, Respondent, prior
to retrofitting an impoundment, shall submit certification by a
registered engineer or a certified engineering geologist that
the surface impoundment to be retrofitted has a foundation or a
base capable of providing support for the structure and capable
of withstanding hydraulic pressure gradients to prevent failure
due to settlement, compression or uplift.
e. Column A, Submittal of Plans and Specifications
to EPA and DOHS, in Table A, specifies the date by which
Respondent shall submit plans and specifications, including
proposed samplincj plans and construction site safety plans for
units proposed for retrofitting. The construction site safety
plan included for each unit must clearly identify the
procedures which will be used by the Respondent and its
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contractors to insure the health and safety of anyone working
at or having access to the construction site during
retrofitting. Column B, Transfer of Pond Contents, in Table A,
specifies the date by which pond content transfer must be
made. Column C, Result of Sampling Plan to DOHS/EPA, in
Table A, specifies the date by which Respondent shall submit
the results of the sampling plan to DOHS/EPA prior to obtaining
DOHS approval to retrofit as specified in Paragraph 4,-c, of
this section. Column D, Completion of Retrofit, in Table A,
specifies the date by which Respondent shall complete retrofit
of the unit,
5. Respondent shall complete cleanout of Pond P-12 no
later- than March 15, 1986, Respondent shall complete cleanout
of ponds P-13 and P-18 in accordance with Table B not later
than February 1, 1987 and March 1, 1987, respectively. Ponds
P-13 and P-18 may only receive liquid waste contents
transferred from ponds P-12, P-15, and P-19. Prior to
transferring the contents of any pond, Respondent shall conduct
compatibility tests in accordance with Respondent's applicable
Waste Analysis Plan to assure that the transferred pond
contents are compatible with the contents of the pond receiving
the waste and are not restricted hazardous wastes as defined in
Section 25122.7 of the California Health & Safety Code.
6, DOHS will place no restrictions on the transfer of
liquid waste from P-15 (which received restricted waste as
defined by Article 15, Title 22, California Administrative
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Code, Chapter 30), provided that (a) the transferred pond
contents are not restricted wastes as determined by a sampling
program approved by DOHS, and (b) the transfer does not exceed
one million gallons, and (c) the transfer occurs before
April 1, 1986. DOHS hereby grants a variance for surface
impoundment P-15 from those specific provisions of Title 22,
California Administrative Code, Chapter 30, which require that
ponds receiving restricted waste must be cleaned on at least an
annual basis. This variance is conditioned on the adherence by
the Respondent to the schedules established in Table A for unit
P-15.
7. Respondent may continue to operate lined surface
impoundments P-15 and P-20 in accordance with the schedule set.
forth in Table A until November 8, 1988, prior to retrofit as
specified in Table A, unless the structural integrity of the
liner is impaired or the pond is cleaned prior to that date.
8. a. Respondent shall implement the sampling program
developed for units S-3 and S-5 attached to this Final Order as
Attachment A to determine the vertical extent of residual
contamination beneath these units. Respondent shall complete
implementation of the sampling plan for the S-5 unit no later
than October 31, 1985, and shall complete the sampling plan for
unit S-3 no later than November 30, 1985. Respondent shall
submit the results of such sampling plus any pre-existing
sampling data for these units by December 31, 1985. Closure of
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S-3 shall be completed by August 1, 1986 in accordance with
Table B.
b. Respondent shall submit to EPA and DOHS within 30
days of the date of this Final Order detailed plans and
specifications for construction of a double lined landfill to
be located in the area of S-5, S-6 and surface impoundment
P-1.8, which shall be designated as the B-19 landfill. Such
plans and specifications shall meet the criteria of EPA's
Minimum Technology Guidance Manual on Double Liner Systems
(May 24, 1985). EPA and DOHS agree to expedite their review of
the plans and specifications for B-19 and agree to approve the
proposed design and operation of B-19 within 60 days of the
date of receipt of detailed plans and specifications from the
Respondent if such plans comply with the technical criteria of
EPA's minimum Technology Guidance Manual on Double Liner
Systems (May 24, 1985) .
c. Upon receipt of approval of'the B-19 landfill
from DOHS and any other appropriate governmental agencies,
Respondent may proceed with excavation and construction of said
landfill. Significantly contaminated soil has been correlated
with visually contaminated soils in the S-5 sampling plan.
Respondent shall dispose of all visibly contaminated soil
removed from the B-19 area into El-9, B-13, or the double-lined
portion of B-19. All other remaining soil from the B-19 area
may be stockpiled adjacent to the area as designated in the
plans and specifications for B-19. This stockpile area shall
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be bermed to provide for total control and containment of
run-on and run-off as long as the area is used for storage of
soil excavated from the B-19 area, Prior to the use of any
other cover material, the stcckpiled soil removed from the B-.L9
area shall be used as daily cover material in the B-9
expansion, B-13, or the double-lined portion of B-19, or for
foundation material in preparation for final claiy cover of
P-12, P-12A, Pr13, P-5, S-2, and S-3 areas.
d. within thirty (30) days of this Final Order
Respondent shall submit its B-19 plans for EPA and DOHS
approval which plans shall specify the size, height and
location of Phase I of B-19. The parties agree that Respondent
may continue to use the existing B-9 expansion landfill unit
until the Phase I portion of the B-19 landfill begins
operation, subject to the following limitations:
(1) No later than December 15, 1985, Respondent; shall
submit the following with respect to 3-19:
(i) an application to DOHS for a
modification under interim status;
(ii) an application to the Regional Water
Quality Control Board for waste discharge
requi rements;
(iii) an application to Kings County for a
conditional use permit.
(iv) an application to Kings County Air
Pollution Control District for an air permit.
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(2) Except as set forth in paragraph 8,d,(3) and (4)
below, use of the B~9 expansion unit shall be
discontinued either (i) after disposal of waste
in the B-9 expansion has reached the level which
would require the unit to exceed the final
elevation shown on the detailed plans set forth
in Attachment C, taking into account closure and
capping requirements, or (ii) by October 31,
1986, whichever occurs first,
(3) If Respondent determines that B-19 cannot be
operated by the date for discontinuing the B-9
expansion specified in subparagraph 8.d.(2),
Respondent no later than thirty (30) days prior
to such date, shall notify EPA and DOHS, The
notification shall include the reasons B-19
cannot be operated, the reasons waste for B-9
cannot be disposed in any other landfills at the
Facility until B-19 is completed, and a proposed
date by which the use of B-9 Expansion will be
discontinued. Within fifteen (15) days of such
notification, the parties shall meet to consider
the matters raised in Respondent's notification,
and shall modify this Final Order if a
modification is agreed to by the parties. EPA
and DOHS shall not unreasonably refuse to agree
to a modification. If the parties cannot agree
to modify this Final Order, within fifteen (15)
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days of the meeting, Respondent may file a
petition with the Administrative Law Judge
setting forth the matter in dispute and, if sucn
a petition is filed in good faith,, the»
discontinuance of the use of the B-9 expansion
shall be stayed until the Administrative Law
Judge issues his decision and, if action is taken
in U.S. District Court, until the matter is
decided. EPA and DOHS shall have fifteen (15)
days to respond to such petition. In making his
determination, the Administrative Law Judge may
consider any relevant facts relating to the B-9
expansion and B-19. The parties agree that they
will jointly petition the Administrative Law
Judge to issue a decision within thirty (30) days
of the date on which the matter in dispute is
submitted to the Administrative Law Judge. The
parties agree that the decision of the
Administrative Law Judge shall constitute final
agency action ripe for judicial review.
(4) EPA and DOHS further agree that, after the
date for discontinuing the B-9 expansion
specified in subparagraph 8,d,(2), Respondent may
temporarily stockpile hazardous waste within B--9
Expansion until Phase I of the B-19 area is
available and approved for hazardous waste
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disposal. Stockpiled waste shall be placed only
upon an area where a three foot (31) thick
compacted clay liner has been installed. When
B-19 is available and approved for hazardous
waste disposal, all stockpiled waste shall be
removed from B-9 Expansion, as expeditiously as
reasonably possible, and disposed of in the
double-lined portion of B-19, except that any
stockpiled waste which does not exceed the grade
level for the B-9 Expansion as described in
Attachment C need not be removed and Respondent
may close B-9 Expansion to such level. If EPA
and DOHS do not agree to the in-place disposal of
X
material stockpiled above the level shown in
Attachment C, such decision shall be unreviewable
under subparagraph 8.d.(3). In no case shall the
Final Order result in stockpiled waste being
moved off-site.
e. Notwithstanding paragraph D.S.d. above, as soon as
Phase I of the B-19 landfill is available for use, Respondent
shall immediately cease the disposal of commercial waste in the
B-9 expansion landfill and shall promptly close it, in
accordance with its approved partial closure plan for the B-9
expansion landfill, with on-site contaminated soil or clean
soil as appropriate to assure adequate closure of the unit.
Closure shall be completed by the time provided in the closure
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plan. After closure of the B-9 expansion, the parties agree
that this portion of the Facility shall be closed to any waste
disposal.
f. The parties agree that Respondent may continue to use
landfill unit B-13 for the disposal of compatible wastes until
completion of the unit as set forth in the closure plan
submitted to EPA and DOHS on October 7, 1985. Respondent shall
close B-13 in accordance with its approved partial closure plan.
10. Respondent shall submit to EPA and DOHS within 30 days
of the effective date of this Order a revised Part A permit
application which sets forth the design capacity of each of the
following units: P-9, P-10, P-ll, P-14, P-15, P-16, P-19,
P-20, limited B-9 expansion, B-13 and B-19 as authorized by
this Final Order.
11. Future replacement, and expansion of landfills and
surface impoundments which will receive hazardous wastes after
May 8, 1985 must be designed and constructed to meet the
minimum technological requirements in Section 202 of Hazardous
and Solid Waste Amendments 1984.
12. Effective immediately, any proposed increases in
design capacity or changes in processes for the treatment,
storage or disposal of hazardous waste beyond those specified
in Paragraph 10 above, must be submitted in writing to DOHS for
approval, as a revised Part A or Part B permit application,
with a copy to EPA. Respondent must receive written approval
prior to implementing such changes, All proposed increases in
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capacity or changes in processes shall include a demonstration
that the proposed changes do not amount to reconstruction of
the facility as defined in 40 CFR §270.72(e). If this
demonstration cannot be made, Respondent may submit a Part B
permit application for approval. DOHS agrees to expedite its
review and decision on any such permit application,
13. Respondent shall conduct representative sampling of
the liner for PCS landfill B-16 within 90 days of the date of
this Final Order. The sampling shall be limited to those areas
where the liner is exposed such that the sampling device will
not come into contact with PCB waste placed in landfill cells.
Respondent shall analyze for PCBs and priority pollutants.
Results of the analysis shall be submitted to EPA and DOHS
within 90 days of sample collection.
E. WASTE ANALYSIS PLAN
1. Respondent shall follow the procedures set forth in
its Waste Analysis Plan dated February 15, 1985, as revised
August 20, 1985, for all wastes received at the Facility.
Where specified by the Facility Waste Analysis Plan, Respondent
shall assure that all four components of Respondent's
pre-acceptance package (Generator's Waste Profile Sheet;
Certificate of Representative Sample Sheet; Special Waste
Analysis Report; and Special Waste Disposal Decision Sheet) are
fully satisfied prior to acceptance of each applicable incoming
waste stream. Unless approved by EPA and DOHS, all four
components of Respondent's pre-acceptance package required by
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the present Facility Waste Analysis Plan (as revised August 20,
1985) shall be completed and retained until closure of the
Facility and, after retention of paper records for a period of
three years, such records may be maintained on microfiche or
equivalent. Where each of these components of the
pre-acceptance package is not required for a particular waste
stream, Respondent shall assure that all applicable
requirements of the Waste Analysis Plan are met for that waste
stream. Respondent may modify its Waste Analysis Plan provided
such plan remains in compliance with 40 C.F.R. 265.13.
2. Respondent shall perform all analyses required by the
Facility Waste Analysis Plan for each incoming waste load.
Respondent shall conduct PCS analyses on all incoming
manifested PCB-contaminated soils that are to be disposed of in
a non-TSCA approved landfill unit and on all oily liquid wastes
of unknown PCS concentration,
3. Respondent shall continue to follow the Waste Analysis
Plan dated February 15, 1985, as revised August 20, 1.985, until
it is formally amended, revised, or altered by Respondent.
Within fifteen days of any amendment, revision or alteration of
the Facility Waste Analysis Plan, Respondent shall submit: a
copy of the revised Waste Analysis Plan to EPA and DOHS.
F. OPERATING RECORDS
1. a. Within 180 days of the effective date of this
Order, Respondent shall develop and implement a computerized
system for the management of operating records at the
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Facility. The computerized system shall apply to both TSCA
waste and RCRA waste. Upon implementation, Respondent shall
submit a report describing how the system is constructed and
operated. The system shall be capable at a minimum of
recording waste fingerprint analyses, internal waste transfers,
wastes generated at the main truck wash station, waste
generated at the PCS flushing/storage unit, the contents and
the location of wastes deposited within each landfill cell, and
the method, location and date(s) of intermediate and ultimate
treatment, storage or disposal for each hazardous waste
received at the Facility. Each waste shall be cross referenced
to waste manifests and waste profile numbers. Decant shall be
deemed an intermediate treatment. In addition, records of all
waste analyses and trial tests shall also be maintained on
site. The computerized operating record system shall be
applicable to all wastes received at the Facility after
April 1, 1986. In addition to the computerized system, the
Facility's manual recordkeeping shall be maintained. After
retention of paper records for a period of three years, such
records may be maintained on microfiche or equivalent.
b. All operating records required by RCRA shall be
made available as quickly as reasonably possible to State and
Federal inspectors, but no later than 24 hours after the
request.
2. Complainant shall review the Potential Release Report
submitted by Respondent for the Facility dated September 8,
1985. Within 30 days of this Final Order, Complainant shall
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provide Respondent an itemized listing of specific areas where
further information or clarification is required. Respondent
shall transmit a report to EPA and DOHS addressing such items
within 60 days of receipt of Complainant's list. For each ar<,a
outside of existing or previous waste management units listed
in a Part A permit application identified as having received a
deposit of hazardous waste, Respondent shall submit a revised
closure plan within 90 days of the date of this Final Order to
include such area, unless included in the closure plans
identified in subparagraph D.I above,
G. LIQUID DISPOSAL IN LANDFILLS
Effective immediately, Respondent shall fully comply with
the requirements of Sections X.4(a) and X.4(b) of its interim
permit in that Respondent will not place liquid wastes in a
landfill without keeping permanent operating records indicating
that these wastes were treated or stabilized outside the
disposal unit so that free liquids were no longer present. A
paint filter test must be performed and documented upcr. each
stabilization prior to land disposal. Respondent shall fully
complete and retain its 'Stabilization Evaluation Test" records
for each waste batch entering the stabilization units until
closure of the Facility. Such records may be maintained on
microfiche or equivalent after retention of paper records for a
period of three years.
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H, IGKITABLE OR REACTIVE WASTES
Respondent shall fully comply with Section X.6 of its
interim permit by not placing ignitable or reactive wastes in
landfills without indicating in its operating records the
results of analyses required by the Facility Waste Analysis
Plan that these wastes were treated, rendered or mixed to make
them non-ignitable or nonreactive, provided that Respondent may
dispose of ignitable or reactive wastes in accordance with
40 C.F.R. $265.312(b) or 265.316,
I. CLOSURE/POST CLOSURE COST ESTIMATES
Respondent shall submit to EPA and DOHS within 60 days of
the effective date of this Final Order revised closure and post
closure cost estimates in accordance with the revised closure
plans submitted by Respondent pursuant to Paragraph D above.
J. POST CLOSURE GROUND WATER MONITORING
Respondent shall submit to EPA and DOHS within 60 days of
the effective date of this Final Order revised post closure
plans which include ground water monitoring to be conducted
after closure or partial closure of the Facility.
K. EARTHEN DIKES
Respondent shall submit to EPA and DOHS within 60 days of
the effective date of this Final Order a plan to control wind
and water erosion at surface impoundment earthen dikes. The
plan shall be implemented within 60 days of approval.
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L. SURFACE IMPOUNDMENT INCOMPATIBILITY
Effective immediately, CWM shall not discharge new
waste streams into surface impoundments unless prior trial
treatment tests have been conducted in accordance with
Respondent's applicable Waste Analysis Plan which confirm
compatibility of new wastes proposed to be mixed,
M. DRUM DECANT OPERATION PLAN
Effective immediately, Respondent's Drum Decant Operation
Plan shall be maintained at the Facility and shall be made
available upon request to Federal and State inspectors.
N. PART B PERMIT REVISION
Respondent shall submit to EPA and DOHS within 120 days of
the effective date of this Final Order a revision to
Tables TR-1 and TR-2 of the Part B Permit application to
accurately reflect chronologies of the use of all hazardous
waste management units at the site. This revision must be
accompanied by the signatory statement and submitted as a
revision to Respondent's Part B application. This revision
shall be based on the Potential Release Report submitted to EPA
dated September 8, 1985.
0. COMPLIANCE WITH PERMIT REQUIREMENTS
Respondent shall demonstrate compliance with all
applicable requirements of the permits issued to the Facility
by DOHS relating to inspections, site security, and maintenance
of two feet of freeboard and 40 C.F.R. 265.14, 265.15, and
265,222 by submission of inspection logs for the Facility for
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A-33
the period November 15-30, 1985. Respondent shall submit to
EPA and DOHS within 30 days of the effective date of this Final
Order a revised inspection schedule and inspection record for
the Facility.
P, NOTICE
All submissions and notices required by this Final Order
shall be sent to:
EPA:
Chief, Waste Programs Branch
EPA Region 9 (T-2)
215 Fremont Street
San Francisco, CA 94105
DOHS:
Section Chief, Northern California Section
Toxic Substances Control Division
Department of Health Services
4250 Power Inn Road
Sacramento, CA
Respondent:
Vice President
Chemical Waste Management, Inc.
715 Comstock Street
Santa Clara, CA 95054
After December 15, 1985, notice to
Respondent shall be sent to:
Vice President
Chemical Waste Management, Inc.
39899 Balentine Drive
Newark, CA 94560
Q. AGREED CIVIL PENALTY
Respondent hereby consents to the assessment of a civil
penalty in the amount of Two Million One Hundred Three Thousand
Dollars ($2,103,000)
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A-34
Complainant acknowledges EPA is in receipt of partial
payment of $108,250.00 leaving a balance of One Million Nine
Hundred Ninety-four Thousand Seven Hundred and Fifty Dollars
($1,994,750),
Within thirty (30) days of the effective date of this Final
Order, Respondent shall submit a cashier's check or certified
check payable to "Treasurer, United States of America," in the
amount of One Million Nine Hundred Ninety-four Thousand Seven
Hundred and Fifty Dollars ($1,994,750). Payment should be made
by sending the check with cover letter to EPA's lockbox address
at the Mellon Bank in Pittsburgh, Pennsylvania, with a copy to
the Regional Hearing Clerk. The addresses are as follows:
Environmental Protection Agency
Region 9 (Hearing Clerk)
P. 0. Box 360863M
Pittsburg, PA 15251
Regional Hearing Clerk
EPA Region 9
215 Fremont Street
San Francisco, CA 94105
R. Respondent shall pay the sum of One Hundred Ten
Thousand Dollars ($110,000) per year to the California
Department of Health Services or its successor agency for a
period of ten years for the purpose of reimbursing DOHS for its
costs of enforcement and oversight to monitor compliance with
applicable regulations implementing RCRA and/or hazardous waste
enforcement and response training. Such payments shall be made
payable to a special account in the Hazardous Waste Control
Account in the General Fund of the State of California. The
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A-35
first payment shall be made on or before January 1, 1986, The
remaining installments shall be paid annually no later than
January 1 of each subsequent year. Expenditures from this
special account may be subject to approval by the legislature
of the State of California.
S. Respondent's implementation of the soil sampling
(paragraph VIII.D,), environmental audit (paragraph VIII.A.)/
computerized record keeping (paragraph VIH.F.), an^ other
requirements under this Final Order represent a combined
environmental monetary commitment by Respondent of
approximately Seven Hundred Ninety-Seven Thousand Dollars
($797,000).
T. Complainant, Intervenor and Respondent consent to the
*
entry of this Final Order without further notice.
U. For the performance of the requirements specified
hfccein, Respondent shall perform such activities within the
time limits set forth, unless the performance is prevented or
delayed by circumstances which constitute a force majeure. For
the purposes of this Order, a force majeure is defined as any
circumstance arising from causes beyond the reasonable control
of Respondent despite Respondent's due diligence and good faith
efforts. Financial inability of Respondent to comply with
these requirements shall not be considered a force majeure. In
the event of a force majeure, the time for performance of the
activity delayed by the force majeure shall be extended for the
time period of the delay attributable to the force majeure.
-35-
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A-36
The time for performance of any activity dependent on the
delayed activity shall be similarly extended, except to the
extent that such dependent activity can be reasonably
implemented without completion of the delayed activity.
Respondent shall notify EPA and DOHS in writing as soon as
reasonably possible but no later than 30 days after it becomes;
aware of a circumstance which may delay or prevent performance
of an obligation. Such notice shall state the anticipated
length of delay, the cause of the delay, the measures to be
taken by Respondent to prevent or minimize delay, and the
timetable by which those measures will be implemented.
Respondent shall also notify EPA and DOHS in writing of the
fact of a delay in performance within 30 days after it become
aware of such delay and failure to *so notify shall constitute a
waiver of a force majeure defense based on such delay. Failure^
of EPA or DOHS to notify Respondent in writing of any object:.on
to such notice within 30 days after receipt of Respondent's
notice shall constitute a waiver of any objection by DOHS or
EPA, respectively, to a force majeure defense based en the
delay.
In any proceeding where Respondent raises a force majeure
as a defense to performance of a requirement, the burden of
proof shall be on Respondent to prove the existence of force
majeure, its consequences and the reasonableness of the delay
resulting therefrom.
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A-37
If a force majeure completely precludes performance of an
activity or dependent activity rather than merely delaying it,
Respondent, EPA and DOHS shall mutually agree upon a substitute
activity. If the parties have not agreed upon a substitute
activity, the parties reserve all rights they may have to
petition the administrative law judge or United States District
Court to resolve the dispute regarding selection of an
appropriate substitute activity.
This subparagraph T. does not apply to enforcement actions
which are not brought to enforce this Final Order,
V. Covenant Not To Sue
1. In consideration of Respondent's consent to this
Consent Agreement and Final Order, EPA and DOHS hereby covenant
not to initiate or maintain any civil claim or civil cause of
action under the Federal Resources Conservation and Recovery
Act, Federal Toxic Substances Control Act, or California
Hazardous Waste Control Act against Respondent, its parent,
subsidiaries, or present or former directors, officers,
employees, or agents thereof, with respect to the Kettleman
Hills facility based on facts or circumstances known by EPA or
DOHS or their employees as of October 15, 1985.
2. Notwithstanding subparagraph V.I. or any other
provision of this Agreement, EPA and DOHS may take (a) any
action against Respondent regarding surface impoundment P-17;
(b) any action to abate, prevent, or order the abatement of any
condition which now or hereafter may present an imminent and
-37-
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A-38
substantial endangerment; (c) an action under section 3008(h)
of the Resources Conservation and Recovery Act; and/or (d) a
non-penalty action under 3Q08(a)(l), 3013 of RCRA or section
25187 of the Health & Safety Code with respect to facts which
were not previously known by EPA or DOHS and which were newly
discovered by the EPA National Ground Water Monitoring Task
Force inspection of the Facility in August and September, 1985,
provided that Respondent shall be given a reasonable time to
comply with any 3008(a)(l) or 3013 order,
3, Respondent agrees that EPA or DOHS may properly bring
an action to compel compliance with the terms and conditions
contained herein in United States District Court, By signing
this Agreement, Respondent does not prejudice and specifically
preserves any right, remedy or defense it may have with respect
to any action related or unrelated to the subject matter of
this document, provided, however, that in any action brought by
EPA or DOHS to compel compliance with the terms of this Consent
Agreement and Final Order, Respondent shall be limited to the
defenses of force majeure, compliance with this Consent
Agreement and Final Order, physical impossibility, and defenses
under the United States and State of California constitutions.
4. In consideration of consent by EPA and DOHS to the
entry of this Final Order, Respondent agrees as follows:
(a) Within one (1) working day of the effective date
of this Order, EPA, DOHS and Respondent agree to stipulate
to a dismissal of Respondent's action, Chemical Waste
-38-
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A-39
Management, Inc. v. United States of America, et al..
No, C-85-4215 (JPV) (N.D. Cal.) without prejudice,
(b) Respondent agrees to withdraw all of its pending
requests relating to the Kettleman Hills Facility for
information, and appeals of denials of requests for
information, under the Freedom of Information Act,
(c) Respondent waives all claims that all operating
records of the Facility previously submitted by Respondent
to EPA are subject to TSCA Confidential Business
Information claims, except for customer lists or documents
from which customer lists may be compiled. However,
Respondent does not waive confidentiality claims under
other statutes or regulations with respect to such
documents.
5. Except as noted above, this Final Order shall not
operate to release, waive, limit or impair in any way claims,
rights, remedies or defenses of the United States of America
(including EPA), the State of California (including DOHS), or
Respondent, against any person or entity not a party hereto.
6. No agency, office, department, or board of the State
of California is party to the TSCA proceeding, therefore,
notwithstanding subparagraph v.(l), DOHS reserves any rights it
may have to bring an action with respect to PCS disposal at the
Kettleman facility.
W. This Consent Agreement may be modified upon written
approval of all parties hereto.
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A-40
X. This Consent Agreement and Final Order shall apply to
and be binding upon all parties to this Consent Agreement and
Final Order, fheir directors, officers, employees, agents and
all persons or entities acting under or for them. Each
signatory to this Consent Agreement and Final Order certifies
that he/she is fully authorized by the party or parties whom
he/she represents to enter into this Consent Agreement and
Final Order, to execute it on behalf of the party represented
and to legally bind such party,
- 7 - _
Date Respondent '
Chemical Waste Management,
ate Complainant X^
Harry Seraydarian
Director, Tories & Waste
Management Division
EPA, Region 9
Date v Intervenor
California Department of Health
Services
Reed Sato
Deputy Attorney General
Attorney for Intervenor
California Department of Health
Services
IT IS HEREBY ORDERED that this Final Order (Docket
Nos, RCRA-09-84-0037 and TSCA-09-84-0009) be entered. This
Order shall become effective immediately.
Date JJdElTH E. AYR£S
Regional Administrator
Region 9
-40-
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TABLE A
POND RETROFIT
A-41
P-9
Submlttal
of Plans
and Specs
to EPA/DOHS
submitted*
B. Transfer
of Pond
Contents by
N/A
C. Results
of SamplIng
Plan to
DOHS/EPA
P-14
P-15
P-16
P-19
submitted*
9/1/88
submitted*
90 days before
N/A
11/8/88
N/A
To P-9 when
t
N/A
t
120
P-9 completion P-9 completed
Completion of
Retrofit
120 days
fol1ow1ng
receipt of
necessary
approvals
P-20
9/1/88
11/8/88
120 days after
liquid transfer
N/A
* Sampling and safety plans due 15 days after effective date of Order,
t Results of sampling due 60 days after sample collection.
-41-
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A-42
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A-44
ATTACHMENT A
SOIL SAMPLING PLAN
KETTLEMAH HILLS FACILITY
The purpose of s-mpling in this investigation is to document
the character and extent of contaminat-ed soil or bedrock in the
areas beneath P-9, P-14, S-3 and S-5. Additionally, location of
areas which contain little or no contamination will allow for
more efficient planning and sequencing of construction
activities,
Sampling will take place in three parts:
1. Samples taken in trenches dug through disposal areas,
2. Samples taken through the use of a hollow-stem auger
and "U" type sampler in disposal areas, and
3. Samples taken in a boring located off-site so as to
document background levels of compounds.
1.0 Drilling Methodology
Subsurface conditions at the facility are described in
previous reports by Woodring (1940) and Emcon and Associates
(1979 through 1935). The compacted fills consist of cobble size
and smaller material comprising sands, silts and clays. The
fill material is underlain by dipping, interbedded sandstones,
siltstones and claystones. Because of the relatively low
hardness of the materials expected to be encountered underlying'
the site, a hollow-stem auger type drilling procedure was chosen
for the job.
2.0 Sample Locations
2.1 Trench Locations
Shallow backhoe trenches will be dug into the represent
bottom of P-9 and P-14, so as to freshly expose lithologic
units. Two exploratory trenches are proposed in the S-5 area, .
where removal of overburden will make use of a bulldozer or
belly scraper. The trenches are located such that all
stratigraphic units underlying the disposal areas will be
exposed. This exposure is necessary in order to locate
significant strata with the physical characteristics amendable
to contaminant migration. Location of trenches P9T, P14T, S5B
and S5C should make use of available geologic maps to develop a
complete stratigraphic sequence. The trenches will be mapped in
detail, physical samples taken from all units, surveyed with an
O.V.A. or HNu and sampled, using this information, for chemical
-44-
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A-'4 5
analysis. Samples of representative lithotypes will be taken,
with an emphasis on permeable sand units. Samples will also be
taken from an obviously contaminated zone and from colluvium
immediately below the contaminated stratum,
2.2 Boring Locations
Approximately 15 boring are proposed for the S-5 and S-3
areas, two in P-9 and two in P-14. Boring and sampling
locations will be chosen using the following parameters:
• Geology - Information from exploratory trenches, geologic
mapping, and boring data in and around the disposal areas,
• Past Use - Including air photo interpretation of 1978,
1979, 1981 and 1984 discharge and concentrations (ponding)
with consideration of slope of surface activity (discing)
and depth of fill in S-3 and S-5,
• Consultation with site staff - Including confirmation of
past use, facility records and use of topographic maps and
aerial photos from 1978 through 1985 summarizing fill
activities.
Samples will be taken at intervals using the above
information as guidelines.
Areas to be evaluated include:
0 S-5 Area (10 holes)
Areas of ponding and distribution spreading zones
1979-1984
Major transgressive sandstones,
Major claystones with possible secondary permeability.
• S-3 Area (5 holes)
Areas of past use (spreading, solidification)
Major transgressive sandstones
Major claystones
• P-9 Area
Major transgressive sandstone units
Thin coarse-grained sandstones
Claystones
• P-14 Area
Major transgressive sandstones
Claystones
-45-
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A-46
2,3 Off-site Investigation
One or more boring locations will be chosen off-site in
units that are the same or similar to units encountered in the
S-5 and S-3 areas. Each different lithologic unit intercepted
will be sampled for chemical and physical testing. Results
from these analyses will be used as a base or background for
comparison with results obtained from on-site exploratory
borings.
3.0 Procedures
3.1 Boring and Sampling Procedures
Drilling is to be performed using 8-inch O.D. hollow-stem
auger equipment. Representative relatively undisturbed samples
will be obtained by lowering a "U" Type Sampler into the
hollow-stem auger and driving it 18 inches or to refusal (more
than 100 blows for 6") with a 140 pound hammer falling 30
inches. Hammer blow counts will be recorded every 6 inches
over the 18-inch sampling interval. The sampler will be fitted
with three 3-inch stainless steel rings for chemical sampling
or a 6-inch thin-wall ring for physical testing.
Upon retrieval, the sampler is opened and the sampler rings
are separated using clean stainless steel sample knife.
Immediately an O..V.A. reading will be taken and recorded on the
boring log. Two of the three stainless steel rings used for
chemical sampling are then marked, logged and either removed
from the rings at the time, put into glass sample containers
and stored in ice cooled shuttles, or sealed in the 3-inch
rings and stored in ice chests cooled with ice to be removed
later. The six-inch sample ring is marked, logged, sealed in a
plastic bag, put in a plastic container and sealed with
electrical tape until the time of testing. The sampling
equipment will be decontaminated after each sample. Equipment
will be disassembled and washed with a diluted soap solution,
rinsed with de-ionized water, sprayed with raethanol and
air-dried. The sampler will then be re-assembled with clean or
new rings in order to minimize the possibility of contamination
of samples. The hollow-stem auger will be steam-cleaned
between borings.
A geologist will be present during drilling operations to
assist in obtaining relatively undisturbed samples of
sub-surface materials, to maintain a continuous log of the
borings and to make detailed observations of the site
conditions.
-46-
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A-47
3.2 Soil/Bedrock Sampling Procedure in Trenches
Unconsolidated soil samples are to be taken from the walls
of trenches S5B and S5C. These samples will be taken with a
new wooden spoon and deposited directly into a sample
container. The sample containers are then stored in ice
cooler, foam insulated shuttles for shipping.
Samples taken from trench bottoms will be taken with a hand
sampler. The hand sampler will b« fitted with either a 3-inch
ring for chemical sampling or a 3-inch or 6-inch ring for
physical testing. Upon retrieval chemical sample rings are
cleaned on the outside, sealed on both ends with a teflon
membrane, capped on both ends and then sealed with electrical
tape for transport in ice filled containers. Physical samples
are cleaned, sealed in plastic bags, placed in plastic tubes,
capped and sealed with electrical tape.
Chain of custody records will be maintained during the
field program. Chain of custody records will accompany sealed
shuttles upon transfer of samples to the analytical
laboratories.
3.3 Chemical testing
Soil bedrock samples will be analyzed for priority
pollutants, phenols, cyanides and metals.
3.4 Physical Testing
Physical testing will be performed on selected soil samples
representative of the various soil/bedrock types recovered
during sampling activity. The testing will include moisture
and density test; Atterberg limits, grain size distribution,
and permeability tests will also be run on selected samples.
This information will be used for classification of bedrock
lithology, assessing the bedrock permeability, and evaluating
possible contaminant migration. Care will be taken to run
physical tests on samples judged to be equivalent to those
taken for chemical analysis.
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A-48
ATTACHMENT B
Supplemental Technical Criter'a For
Surface Impoundment Retrofit
The design, plans, and specifications for P-9, P-14, P-16,
and P-19 must meet the following supplemental technical
criteria:
1) Submittal of a construction site safety plan which
addresses the provisions of Article 18, 19, 20
(22 CAC, Division 4, Chapter 30) relative to hazardous
conditions which may be encountered during
construction activities. In submitting such a site
safety plan, CWM may make reference to appropriate
information previously submitted to the Department.
2) Resubmittal of plans and specifications showing the
following modifications or clarifications:
(a) Maintenance of 2 feet (2') of freeboard below the
lowest point of the proposed diking system having
double liner protection. CMW may submit a
proposal justifying maintenance of less freeboard
pursuant to the requirements of Section 67281(f),
CAC, and 40 CFR §265.222(b).
-48-
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A-49
(b) Geomembrane which may come into direct contact
with drainage rock shall be protected by a
geotextile fabric.
(c) Specification of the criteria used to select a
particular geotextile fabric (8 oz./sq. yd.) used
in the design.
(d) Specification of the criteria used to select the
four inch (4") drainage/riser pipe and
demonstration that PVC pipe will be compatible
with materials or substances with which it may
come into contact.
(e) Specification of the installation procedures
which will be followed to ensure that the
riser/drainage pipe perforation location in the
geomembrane will be properly sealed/seamed.
(f) Specification of the mechanisms and procedures
which will be used to detect liquids in the
drainage system and to remove liquids from the
drainage system for evaluation and analysis.
(g) Specification of the seaming method to be used on
the georaembrane, including testing criteria to
ensure quality control of the seaming process.
(h) Specification of the criteria to be used to
monitor and control crack length, width, and
depth during the installation of the clay liners,
-49-
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A-50
3) During construction of the '_nit, a tensiometer shall
be available in the field at all times to conduct peel
and shear tests on _r.e ^ecrr.embrane seams as may be
required.
4) The Construction Qualify Assurance program recommenced
by EPA's draft Minimum Technology Requirements
guidance of May 24, 1985 shall be incorporated into
the specifications for surface impoundment retrofits.-
In accordance with these procedures, CWM shall
maintain an up to date single organized file of all
Quality Control (QC) documents generated during
construction. OiM shall maintain this file at the
site for ready inspection by the EPA, the Regional
Water Quality Control Board, the DOHS or their
authorized agents.
5) Prior to the discharge of waste, submit plans and
specifications for incorporation as part of the
Facility Part B application describing the unit in
accordance with the conditions set forth herein, CWM
may revise and submit only those portions of the
Part B application which describe or refer to the
design and operations of this particular unit.
6) Prior to the discharge of waste, submit as-built
drawings to the DOHS substantiating that the unit was
constructed in accordance with submitted plans and
specifications as modified herein and has received
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APPENDIX B
DESCRIPTION OF STRATIGRAPHIC INTERVALS
WITHIN THE SAN JOAQUIN FORMATION
-------
B-l
Appendix B
DESCRIPTION OF STRATIGRAPHIC INTERVALS*
WITHIN THE SAN JOAQUIN FORMATION
Cascajo Interval
The Cascajo interval occurs at the base of the San Joaquin Formation
and extends from the contact with the underlying Etchegoin Formation
to the base of the overlying Neverita A bed. Thick claystones typify
the Cascajo Interval, Portions of this interval are exposed beneath
surface impoundments P-14, P-15, P-16 and P-17, however, the thick
sandstones are absent,
Neverita Interval
The Neverita Interval extends from the base of Neverita A sandstone to
the base of the ove.rlying My a Sandstone Interval. Three thick (20-95
feet) sandstone beds compose the Neveri ta Interval (from lowermost to
uppermost) including the Neverita A, Neverita B and Tuffaceous Sandstone,
The Neverita A sandstone ranges from 65 to 95 feet thick. It outcrops
beneath waste disposal units B~9 expansion (B-l, B-4, B-5, B-6 inclu-
sive), B-7, B-16, P-7 and S-5, The Neverita A includes a thick, poorly
consolidated sand layer and a coarse-grained consolidated sandstone.
The sandstone is generally fine-to medium-grained, clayey and contains
discontinuous silty stringers.
The Neverita B sandstone ranges from 20 to 40 feet thick. It outcrops
beneath B-9 expansion (B-4 inclusive), B-16, P-6, P-8, P-12 and S-5.
It is fine-to medium-grained and has claystone stringers. Above the
Neverita B sandstone is a 120-foot-thick sequence of interbedded strata.
These strata include claystone and sandstone beds ranging from 5 to 40
feet in thickness.
From lowermost to uppermost
-------
B-2
Above the inter-bedded strata is the Tuffaceous Sandstone. It ranges
from 45 to 90 feet in thickness and outcrops beneath the B--9 expansion
area (P-l, P-2, P-4, S-l inclusive), B-15, P-13, P-20, S-3 anc S-6.
Mya Sandstone Interval
The Mya Sandstone Interval overlies the Tuffaceous Sandstone of the
Neverita Interval and is overlain by the Pecten-Mya Interval. It
ranges from 150 to 200 feet in thickness, much of which is claystone,
The lower part, of the Mya Sandstone Interval is predominantly clay-
stone and a clayey interbedded sequence ranging from 100 to 150 feel
thick. This sequence includes two thin, shell-bearing layers contain-
ing casts of My_a (bivalve mollusk), These thin layers are continuous
across the site',
Near the top of the interval is the thick Mya A Sandstone, ranging
from 50 to 100 feet in thickness, This massive sandstone is typically
dark gray, fine-grained, and contains intermittent calcariously
cemented fossi 1 i ferous lenses. It is laterally continuous, across the
site.
Mya A outcrops beneath the B-9 expansion (B-9 and B-10 inclusive), the
B-13 expansion (B-13 inclusive), B-15 and P-19. A second sandstone,
Mya B, occurs on the north end of the site, but does not appear to be
continuous across the site as a separate bed. The consultants to CWM
group the Mya B sandstone as part of the overlying Pecten-Mya Interval,
Pecten-Mya Interval
The Pecten-Mya Interval extends from the top of the Mya A Sandstone of
the Mya Sandstone Interval to the base of the overlying Pecten Marker
Bed. This interval ranges from 200 to 250 feet in thickness.
-------
B-3
Sandstone and interbedded strata dominate the Pecten-Mya Interval,
The interbedded strata consist of siltstones and claystones inter-
fingering with relatively thin (<20 feet) sandstone beds. The thin
sandstones are generally silty, fine-grained and poorly consolidated.
Two thick sandstone beds are described b> the CwW consultant as
slightly silty, very coarse sandstone and silty, very fine sandstone.
The Pecten-Mya Interval includes Pecten A Sandstone and the Mya B Sand-
stone. The sandstones of the Pecten-Mya Interval outcrop beneath the
B-9 expansion (B-9 and B-ll inclusive), P-9, P-10 and P-ll,
Pecten Interval
The Pecten Interval is approximately 150 to 200 feet thick and extends
from the base of the Pecten Marker Bed to the base of the overlying
Trachycardium Marker Bed of the Trachycardi urn Interval. The Pecten
Marker Bed, at the base of the interval, is a fossiliferous bed that
is easily identifiable and aids stratigraphic correlation across the
site. The Pecten Claystone occupies the lower portion of the Pecten
Interval and is 70 to 100 feet thick. It is a silty claystone ranging
from massive to thinly bedded with silty partings and sandstone
stri ngers.
A sandy interbedded sequence overlies the Pecten Claystone. Within
this interbedded sequence are two major sandstone units, including the
Pecten B Sandstone. Sandstones of the Pecten Interval outcrop beneath
the areas proposed for B-17 and B-18. The Trachycardium Marker Bed
overlies the Pecten Interval.
Trachycardi urn Interval
The Trachycardium Interval extends from the base of the Trachycardium
Marker Bed to the base of the overlying Acila A Sandstone of the Acila
Interval. It is about 100 to 150 feet thick. Two major sandstone
beds (10 to 40 feet thick), separated by clayey interbedded zones,
occur in the middle of the interval. Beds in this interval outcrop
beneath the areas proposed for B-17 and B-18.
-------
B-4
ACT la Interval
The Aci 1 a Interval extends from the base of the Aci j_a A sandstone to
the top of the San Joaquin Formation (to the contact with trie overlying
Tulare Form;-ion). It ranges from 450 to 500 feet in thickness. Six
thick sandstones (>20 feet) and numerous interbedded sandstones and
claystones occur in this interval. The thick sandstones are s^lty,
fine-grained, and poorly consolidated,
The poorly consolidated Ac i1 a A sandstone is 30 to 60 feel thick. The
Aci 1 a A and some of the overlying sandstones of the Ac i 1 a Interval
outcrop beneath the areas proposed for B-17 and 8-18,
-------
APPENDIX C
ANALYTICAL RESULTS FOR TASK FORCE SAMPLES
-------
-------
C-l
Appendix C
ANALYTICAL TECHNIQUES AND RESULTS FOR TASK FORCE SAMPLES
KETTLEMAN HILLS FACILITY
INTRODUCTION
The following paragraphs discuss analytical techniques, methods and
results for ground-water samples collected by the Ground-Water Task Force
at the Kettleman Hills facility.
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),
California Analytical Laboratories analyzed the samples for specified organic
compounds while Rocky Mountain Analytical Laboratories analyzed for metals
and other parameters.
Standard quality control measures were taken Including: (1) the analysis
of field and laboratory blanks to allow determination of possible contamina-
tion due to sample handling, (2) analysis of laboratory spiked samples and
performance evaluation samples to estimate accuracy, (3) analysis of labora-
tory 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 concentrations
prepared by the EPA Environmental Monitoring Systems Laboratory, Cincinnati,
Ohio. NEIC and the CL analyzed split samples from well K-4.
Table C-l provides a summary, by parameter, of the analytical techniques
used and the reference methods for the ground-water sample analyses.
Analysis Results
Specific Organic Analysis Results
Table C-2 lists the organic compounds which can be reported as being
present in the ground-water samples for the identified wells. None of the
-------
C-2
organic compounds determined were detected above blank levels in the other
well samples. The compounds reported in the samples for wells K-8 and K-13
were present at concentrations below 5 ug/L which is the limit of quantita-
tion for these compounds, The identifications are supported by mass sped.ra
and there was no indication of the presence of these compounds in either
laboratory or field blanks.
Table C-3 contains the estimated limits of quantitation (LOQs) for the
analyses of the volatiles, semivolatiles and pesticides organic compounds.
These limits can be considered reliable to within a few parts, per billion
for the volatiles and to within factors of two to twenty for the semivola-
ti les and pesticides for most of the samples, The LOQs for the semivolatiles
for the analysis of the well K-7 sample are twice those listed in Table
C-3. Instead of the usual 1000 milliter aliquot, only 500 milliters of the
well K-7 sample was extracted.
Phenol and the chlorinated and methylated phenol derivatives should be
considered to have been "not analyzed" for the well K-4 sample. The CL
surrogate spike recoveries for D5-phonol, fluorophenol and tribromophenol
were very low or zero. NEIC spiked many of the phenolic compounds listed
in Table C-3 and obtained very low or essentially nonexistent recoveries
for D6-phenol, fluorophenol, 4-chloro-3-methylphenol , 2 ,4-dichlorophenol,
2-methylphenol and 2,4-dimethylphenol. NEIC's analyses confirm both the ZL
identification and quantification results reported in Table C-2 for the
well K-4 sample.
Metals Analysis Results
The dissolved and total metals results for the well samples are
reported in Table C-4. The accuracy of each detectable value i's footnoted
in the table.
The dissolved elemental concentrations for many of the samples are
biased high. Mismatching of the calibration standards acid matrix to the
dissolved preserved sample matrix was the cause of bias. Comparison of the
-------
C-3
CL dissolved values to NEIC's for well K-4 and comparison to the CL total
values indicates that the dissolved values could be biased high by as much
as 18%. Many of the samples were diluted prior to analysis because of the
adverse effects of the high dissolved content on the analysis technique.
Detection limits have been increased proportional to the dilutions.
The high dissolved solids of the samples caused uncertainty in the
reliability of detectable results for arsenic, lead, selenium and thallium
because of the inability of the instrumentation to correct for background
spectral interference. Therefore, detection limits were raised to preclude
reporting false positives due to insufficient Instrumental background cor-
rection capability. The inability to correct the spectral background due
to the high solids at times prevented estimation of a detection limit and
the data table indicates that such values were not quantified.
No total values are reported for silver because the lower 99X confi-
dence limits for the spike recoveries for this element was below zero. The
digestion in combination with the sample matrix apparently caused precipita-
tion of the silver. Similarly, a low total barium spike recovery was
obtained. However, this low barium spike recovery was not considered repre-
sentative of the accuracy achieved for the sample analyses. The barium
spike level exceeded the solubility allowed by the sulfate while the unspiked
sample concentration would not. Tin spike recoveries for both the dissolved
and total analyses were between 60 and 70%. No tin was detected and the
tin detection limits have been raised to reflect the low spike recovery.
General Analysis Results
The field measurements and the results of other analytical testing the
well samples are reported in Table C-5. Although analyses were performed
for conductance, TOX and nitrate, the results were determined to be unreli-
able and thus no results are reported. The performance evaluation sample
result and comparison of conductance values to the dissolved solids indicate
the conductance values were unreliable. Large variation in field triplicate
results and the perfomrance evaluation sample result indicate that the TOX
-------
C-4
results were unreliable. Samples collected for nitrate analyses were
perserved with sulfuric acid which is appropriate only when determination
between nitrate and nitrite is not needed. The reliability of the detect-
able va1u>s for the other parameters are footnoted in the table.
-------
C-5
Parameter
Con Tact arice
POC
Chloride
Kit rate
Sulfate
Ammonia
Cyanide
Phenol
Dissolved and
Total Kg
As, ?b, Se
and T.1
Other "Elements
Volatiles
Semi-vclatiles
Pesticides 'PC?
Sample Analysis Techniques and Methods
Analytical Technique
Zlectrometric
Potentiometry
Combustion of pargable fraction,
Microcoulometry Detection
Carbon absorption, combustion,
Microcoulometry Detection
Combustion of purgable fraction,
Non-dispersive Infrared Detection
Acidify, Purge, Combustion of liquid,
Non-dispersive Infrared Detection
Mercuric Precipitation Titration
Brucine Sulfate Colorimetry
Barium Sulfate ^rbidimetry
Phenolate Colorimetry
Distillation, Colorimetry
Distillation, Colorimetry
Wet digestion for dissolved and total,
Cold Vapor AAS
Acid digestion for total, ^mace AAS
Acid digestion for total, ICAP-C^S
Purge and trap GO-MS and direct
injection GO-MS or GC-FLD
Methylene Chloride extraction, GO-**?
Methvlene Chloride extraction, GC-T
Method Reference
No reference
No reference
Method 90?"
No reference
Method
(b.'
Method 9252 (aN
Method 92X ;SL'
Method 90^5 'V
Method 350.' ":
Method 4-2:.' =
CLP vethod
ir "etnoa
71? Method
ILP Method
CLP Method
a" "es*: Methods for Fvaluatine Solid Wastes,
b) Metnods for Chemical Analysis of Water and Wastes, EPA-6CO/4.-"9-02C.
c' Contract Laboratory Progran, I™, methods.
-------
C-6
^able C-2
•ganic Compounds Detected In Ground-Water Samples
••"ettleman Hills Facility
WELL WELL WELL
K-4 K-8 K-1 3
Compound Value (a) Value Valui
Carbon Disulfide
Toluene
1,1,1 -Trichloroethane
Chlorobenzene
Methylene Chloride
Benzene
1 , 1-Dichloroethane
Chloroform
Tetrachloroethene
Total Xylenes
Trichloroethene
1 ,1-Dichloroethene
2-Nitropher.ol
BMDL-5
8 BKDL-5
BMDL-5 BMDL-1
670
110
4.1
49
39
11
13
16
B^L-5
150
a = Concentrations are reported in ug/L.
3?u)L = Present Below "lethod Detection Limit, number is Method
Detection mi
-------
C-7
Table C-3
LIMITS OF QUANTITATIOH FOR ORGANIC COMPOUNDS*
KETTLEMAN MILLS
Kings County. California
Limit of
Quant 1 tat ion
(ug/D
limit of
Quanti titi on
(ug/L)
'- 1 T ' I C
Quant 1 tal
Vclat" 1 t Compounds
BroetotM thane
Chlororoethane
l,2-D1brc»oeth*ne
Bro«odichlorcmiethane
D1BroejocMoro»ethane
Bro«»for«
Cnlorofoni
C«rt>on tetrachloHde
Caroon duulflde
Chloroethane
1 ,i-D1ch1oroethene
i ,2~Dich)oroethari«
i,l.l-THchloro«thar\e
1,1,2-TMchloroethane
1,1 ,2,2-Tetrachloroethane
1 . l-D1chloroethane
trani-l.2~D1chloroethene
Trichloro«th*n«
Tetrachloroethene
Methylene chloride
Vinyl chlbrla*
1 ,2-Dichlort>propahe
l,2-D1bro«o-3-cnloropropane
01 f-l,3-D1chloroprop«r>e
t>-arii-l , 3-Dichloropropent
Bcnzcnt
Chloroctnzt n«
Ethyl b«nzin«
Tolutnt
Xyltno
Acttont
2-Butanon«
2-K«xanont
4-H«lhy l-2-p»ntanone
Acro'nn
Ac-y'onUrl 1«
2-Chloro«thy!v1nyltther
Tttrahyflrof uran
l Compounfls
l,«-D1ox«n«
vinyl acttat*
1C
1C
20
5
5
5
5
5
5
10
5
5
5
5
5
5
5
5
5
5
10
5
20
S
5
5
5
50
20
20
20
500
500
40
NA
100
500
5
40
An ill at
p-CMo-oanl 1 i n*
2-Ni troam 1 1 ne
3-Ni troani 1 i r,t
4-Nitroam 1 me
BenziOint
3,3' -D1chlorop«nztdiD«
Benzyl alcohol
&»nryl chloride
l,2-Dichlorob«nzene
1,3-DichloroPenzene
l,4-Dichlorobeii«ne
1,2 ,*-T*-ieMorobe.nzei-ie
1,2 ,4 , 5-Tetracnl orobenzene
1,2, 3 ,4-Tetrachlorot>enzene
Pentachlorobenzene
Mtxachlorobenzene
Pentachloroni troB«nzene
Nitrobenzene
2,4-Oml trotoluene
2,6-Dim troto'i uena
N-Ni trosodii»ethyla«i1ne
N-N1 trotodipheny lanine
N-N1 trosodipropy la»1ne
Di s(2-ChloPoethyl ) etne>-
4-CMoropheny 1 phenyl ether
4-Broi»opheny 1 phenyl ether
b1s(2-Chloroi»opropyl ) ether
bi s(2-Chloroethoxy) methane
Hexachloroethan*
Hexachlorobutad1e>ne
Hexachlorocyclopentadlene
b1s(2-Ethylhexyl ) phthalate
Butyl benzyl phthalate
di-n-Butylphthalate
di-n-Octylphtnalate
Dletnylphthalate
Dimethylphtha late
Acenaphthene
Acenaphthy !ene
Anthracene
Benzol * )anthracene
Benzo(b)f luoranth«ne ana/or
Benio(k.)f )uoranthene
Benzo(8,h, 1 )perylene
Benzo(a)pyren«
Chry»»ne
Oibenzo(a,h)anthracene
OIBenzof uran
Fluoranthene
Fluorene
InOeno(l,2 ,3-c ,d)pyrerve
Isophorone
Naphthalene
2-Cnloronaphthalene
2-Methylnaphthalene
Phenanthrene
Pyrene
10
100
100
100
100
NA
100
20
10
10
10
10
10
10
10
10
10
10
10
10
10
NA
40
20
10
10
10
10
10
10
10
20
40
1C
10
1C
10
1C
10
10
1C
1C
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
Acid Compounds
Benzole add
Phenol
2-Chlorophenol
2 ,4-Dichlorophenol
Z ,4 ,5-Tri chl oropneno '
2,4 ,6-THchloroph»nol
Pentachlorophenoi
4-CMoro-3-»«thylphenoi
2-M«thylphenol
4-M«thy 1 phenol
2,4-D1*«thy iphsnoi
4,6-D1nitro-3-a»thylpheic '
2-Mtrophenol
4-Ni tropheno*
2,4-Dim trophenol
Pestlcides/PCBs
alpha-BHC
betg-BMC
del ta-BMC
Chlordant
4,4 -DDO
4,4' -DOE
4, 4' -DDT
Oieldri n
Endosulfan
Enxtoiulfan II
Enaosulfan »ulfate
I
Enorin aldehyde
Heptachio'
Meptacrilo' epoxiae
Toxaohene
Metnoxyrhlo--
£ndnn netone
PCB-1016
PCB-1221
PCB-1232
PCB-124^
PCB-1248
PCS- 1254
PCB-126C
10
10
SO
10
5c
20
10
1C
10
5C
1C
50
50
o.os
0 OJ
0 05
0 05
0 05
0 5
D 1
0 1
0 1
0 1
0 05
C 1
0 1
C 1
0 1
C
C
05
05
C 5
0 1
C 5
C 5
1
3am» ccmpoimdt in tr»2lt K-4 and K-~! htvt hiyhtr LiMit* of qutntitMtion tAu-, »/>om, ••« next
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