August 1986 EPA-330/2-86-009
^Hazardous Waste Ground-Water
Task Force
Evaluation of
GSX Services of South Carolina, Inc
Genstar Corporation
Pinewood, South Carolina
g S. Environmental Protection Agency
Region 5, library JPI-12J)
77 West Jackson Boulevard, IZtn
Chicago,"- 60604-3590
&EPA
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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August 6, 1986
UPDATE OF THE HAZARDOUS WASTE GROUND-WATER TASK EVALUATION
OF GSX SERVICES OF SOUTH CAROLINA, INC. FACILITY
The United States Environmental Protection Agency's Hazardous Waste
Ground-Water Task Force ("Task Force"), in conjunction with the South
Carolina Department of Health and Environmental Control (SCDHEC), conducted
an evaluation of the ground-water monitoring program at the GSX Services of
South Carolina, Inc. hazardous waste disposal facility. The onsite field
inspection was conducted over a 2-week period from October 29 through
November 7, 1985. GSX is one of 58 facilities that are being evaluated by
the Task Force. The GSX facility is located approximately 40 miles south-
east of Columbia, South Carolina near the towns of Pinewood and Rimini.
The purpose of the Task Force evaluation was to determine the adequacy
of GSX's ground-water monitoring system in regard to State and Federal
ground-water monitoring requirements. Specifically, the objectives of the
evaluation at GSX were to:
Determine compliance with the State equivalent of 40 CFR Part 265
interim status ground-water monitoring requirements
Evaluate the ground-water monitoring program described in the
facility's RCRA Part B permit application for compliance with the
State equivalent of 40 CFR Part 270.14(c) requirements
Determine if hazardous or hazardous waste constituents have
entered the ground-water at the facility
Provide information to assist EPA in determining if the facility
meets EPA requirements for waste management facilities receiving
waste from Federal Superfund response actions
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Although GSX has completed some aspects of the requisite hydrogeologic
investigation, a number of critical elements are missing. The facility
must provide additional information regarding the local stratigraphy,
hydraulic gradients and hydraulic interconnection of various zones. The
above information must be known before the adequacy of the number, placement
and screened intervals of the wells which make up the GSX ground-water
monitoring system can be affirmed.
On January 16, 1986, GSX submitted the previously omitted section of
its Part B application that addressed the South Carolina State ground-water
monitoring requirements [R.61-79.270.14(c)]. The revised application has
been reviewed by SCDHEC and EPA and was found to be deficient. On July 7,
1986, SCDHEC issued a Notice of Violation and a Notice of Deficiencies to
GSX. GSX is required to respond to this Notice of Deficiencies on or before
August 8, 1986. The Notice of Violation contains a draft administrative
consent order that requires, among other things, that GSX conduct a hydro-
geologic study to fully characterize the uppermost aquifer at the facility.
The analytical results of the ground-water samples collected by the
Task Force show the presence of trace concentrations of nickel in six moni-
toring wells and the French drain. No other hazardous waste constituents
were positively identified in the samples.
In a meeting on June 16, 1986, GSX notified SCDHEC that the presence
of trace amounts of volatile organics (trans 1,2-dichloroethylene at 11 ug/L,
and 1,2-dichloroethane at 10 MS/I-) had been confirmed in samples collected
from an old monitoring system well, 2D. Subsequent sampling of monitoring
wells and piezometers in the area of well 20 has not revealed any organics
in any of the new monitoring system wells. To date, the highest organic
concentrations have been measured in an unused production well (PW-4) that
appears to be upgradient of the regulated units. On June 30, 1986, GSX and
SCDHEC entered into an Administrative Consent Order that governs the imple-
mentation of an expanded ground-water quality assessment program to determine
the rate and extent of the contamination, the source of the contamination,
and remedial action alternatives.
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An expanded assessment plan was submitted to SCOHEC and Region IV EPA
on July 1, 1986 and, as amended July 15, was approved by SCDHEC on July 24,
1986.
The three phase plan has been implemented and interim progress reports
are due on August 29, 1986 and October 15, 1986. A final report is due on
December 15, 1986. Currently, there appears to be no immediate threat to
public health or the environment.
The violations regarding the erosion of the cover for Section I, cell E,
and the grid map problem noted during the Task Force inspection have been
referred to SCDHEC for action.
This completes the Hazardous Waste Ground-Water Task Force evaluation
of the GSX Services of South Carolina, Inc. facility.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUND WATER TASK FORCE
EPA-330/2-86-009
GROUND-WATER MONITORING EVALUATION
GSX SERVICES OF SOUTH CAROLINA, INC.,
GENSTAR CORPORATION
Pinewood, South Carolina
August 1986
Alan E. Peckham
Project Coordinator
National Enforcement Investigations Center
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CONTENTS
EXECUTIVE SUMMARY
INTRODUCTION 1
BACKGROUND 3
SUMMARY OF FINDINGS AND CONCLUSIONS 8
COMPLIANCE WITH INTERIM STATUS GROUND-WATER MONITORING - R.61.79.265
SUBPART F 9
GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS 9
Ground-Water Monitor System 9
Site Hydrogeology 9
Ground-Water Sampling and Analysis Plan 9
Ground-Water Assessment Program 10
GSX Contractor Laboratory Evaluation 10
GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT 10
TASK FORCE SAMPLING AND MONITORING DATA ANALYSIS 11
FACILITY OPERATION 11
COMPLIANCE WITH SUPERFUND OFFSITE POLICY 13
TECHNICAL REPORT
INVESTIGATIVE METHODS 13
RECORDS/DOCUMENTS REVIEW AND EVALUATION 13
FACILITY INSPECTION 14
LABORATORY INSPECTION 14
GROUND-WATER, SURFACE WATER AND LEACHATE SAMPLING
AND ANALYSIS 14
WASTE MANAGEMENT UNITS AND OPERATIONS 16
WASTE MANAGEMENT UNITS 16
Landfills 16
Treatment 22
Storage 23
FACILITY OPERATIONS 23
Leachate Collection 23
Incoming Hazardous Waste Handling 24
Maintenance of Landfill Cover 26
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CONTENTS (cont.)
SITE HYDROGEOLOGY 28
HYDROGEOLOGIC UNITS 28
GROUND-WATER FLOW 30
GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS 33
REGULATORY REQUIREMENTS 33
Permit IWP-145 34
R.61-79 Part 265, Subpart F 34
GROUND-WATER SAMPLING AND ANALYSIS PLAN 38
November 17, 1981 SAP 38
August 25, 1983 SAP 38
October 25, 1985 SAP 38
MONITORING WELLS 39
Well Construction - Old System 39
Well Construction - New System 44
Well Locations .....' 48
GSX SAMPLE COLLECTION AND HANDLING PROCEDURES 48
GROUND-WATER ASSESSMENT PROGRAM AND OUTLINE 49
Section I 49
Section II 50
Ground-Water Assessment Results 50
GROUND-WATER STUDY PLAN 51
GROUND-WATER MONITORING- PROGRAM PROPOSED FOR RCRA PERMIT 52
TASK FORCE SAMPLE COLLECTION AND HANDLING PROCEDURES 52
GSX LABORATORY EVALUATION 59
ONSITE LABORATORY FINDINGS 59
CONTRACTOR LABORATORY FINDINGS ..... 60
MONITORING DATA ANALYSIS FOR INDICATIONS OF WASTE RELEASE 64
REFERENCES
a
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CONTENTS (cont.)
APPENDICES
A TASK FORCE ANALYTICAL RESULTS
B LANDFILL EXCAVATION AND OPERATIONAL PLANS
FIGURES
1 Pinewood Location Map 4
2 Waste Management Areas 5
3 Ground-Water Monitoring Well Locations 29
4 Ground-Water Monitoring Well Location (Old System) 40
5 Ground-Water Monitoring Well Location (New System) 41
6 Typical Well Construction (Old System) 45
7 Typical Well Construction (New System) 47
TABLES
I Industrial Landfill Permit IWP-145 Parameters 35
2 SCDHEC Minimum Analysis 35
3 SCDHEC Comprehensive Analysis 36
4 Proposed Secondary Drinking Water Parameters 36
5 Interim Primary Drinking Water Standards . 37
6 EPA Parameters Establishing Ground-Water Quality 37
7 EPA Parameters Used as Indicators of
Ground-Water Contamination 38
8 Wells Designated for Ground-water Monitoring During
Interim Status at the GSX Facility 42
9 Monitoring Well Construction Data (Old System) 43
10 Monitoring Well Construction Data (New System) 46
11 Statistical Differences for Section II Wells 50
12 Sample Collection Data 53
13 Locations and Receivers of Samples Other Than GSX 54
14 HNU Readings at Leachate Collection Sump 57
15 Order of Sample Collection, Bottle Type and Preservative
List ' 57
16 Location of Field Blanks 58
17 Analytical Procedures 62
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EXECUTIVE SUMMARY
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INTRODUCTION
Concerns have recently been raised about whether hazardous waste
treatment, storage and disposal facilities (TSDFs) are In compliance with
the ground-water monitoring requirements promulgated under the Resource
Conservation and Recovery Act (RCRA)*. Specifically, the concerns focus on
the ability of ground-water monitoring systems to detect contaminant releases
from waste management units at TSDFs. In response to these concerns, the
Administrator of the Environmental Protection Agency (EPA) established a
Hazardous Waste Ground-Water Task Force (Task Force) to evaluate compliance
at TSDFs and address the cause(s) of noncompllance. The Task Force is
comprised of personnel from the EPA Office of Solid Waste and Emergency
Response (OSWER), the National Enforcement Investigations Center (NEIC),
EPA Regional Offices and State regulatory agencies. To determine the
status of compliance, the Task Force is conducting in-depth onsite inves-
tigations of TSDFs.
The objectives of these evaluations are to:
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
or hazardous waste constituents
Regulations promulgated under RCRA address hazardous waste management
facility operations, including ground-water monitoring, to ensure that
hazardous waste constituents are not released to the environment.
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Provide information to assist the Agency in determining if the
TSDF meets EPA ground-water monitoring requirements for waste
management facilities receiving waste from response actions con-
ducted under the Comprehensive Environmental Response, Compensa-
tion and Liability Act (CERCLA, Public Law 91-510)*
To address these objectives, each Task Force evaluation will determine
if:
The facility has developed and is following an adequate ground-
water sampling and analysis plan
Designated RCRA- and/or State-required monitoring wells are prop-
erly located and constructed
Required analyses have been conducted on samples from the desig-
nated RCRA monitoring wells
The ground-water quality assessment program outline (or plan, as
appropriate) is adequate
Recordkeeping and reporting procedures for ground-water monitor-
ing are adequate
The GSX Services of South Carolina-Genstar Corp., Pinewood facility
(GSX) onsite inspection was conducted from October 29 through November 7,
1985. The inspection was coordinated by personnel from NEIC, a field
component of the Office of Enforcement and Compliance Monitoring. In
general, the evaluation involved a review of State, Federal and facility
records, a facility inspection, a laboratory evaluation and ground-water
and landfill leachate sampling and analysis.
EPA policy, stated in the Way 6, 1985 memorandum from Jacfc McGraw on
"Procedures for Planning and Implementing Offsite Sesponse", requires
that TSDF's receiving CERCLA wastes be in compliance with applicable
RCRA ground-water monitoring requirements.
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BACKGROUND
The GSX Pinewood facility is located approximately 40 miles southeast
of Columbia, South Carolina near the towns of Pinewood and Rimini [Figure 1].
The site is bordered by agricultural land and is adjacent to and hydraulically
upgradient of Lake Marion, a major recreational lake. Mining of opaline
claystone and waste disposal are the principal operations conducted at the
site.
The origin of the site is rooted in the discovery of large opaline
claystone deposits in the area. The material, after processing (drying,
crushing and sizing), is commonly known as fuller's earth or, more generic-
ally, "kitty litter". During mining, a surficial sand layer is removed to
expose the claystone. The opaline claystone is underlain by sands, silts
and clays of the Sawdust Landing member of the Rhems formation. The
Sawdust Landing is, in turn, underlain by sands and clays of the Upper Black
Creek Formation, the regional aquifer.
The facility covers approximately 276 acres, of which 25 acres is a
landfill known as Section I, which has undergone partial closure. Part of
the remainder of the site is devoted to the mining and processing of opaline
claystone. The excavations produced by mining are used as landfill areas.
The total landfill area including all of Sections I through IV is 125
acres.
Hazardous waste activities at GSX include the landfill operations, a
drum storage area, drummed and bulk liquid solidification, and burning of
waste oil which is regulated by the State. Two distinct landfill areas are
located at the site [Figure 2]. The oldest, Section I, has five cells
which have undergone partial closure (cells A through E). The operating
area, Section II, has two cells in the process of partial closure (cells A
and B), a cell in operation (cell C), a proposed cell (cell D) and a series
of proposed future cells.
Mining of the claystone began in 1972 by Bennett Mineral Company
(Bennett) under a lease agreement with a local farmer. In July 1977, an
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Figure 1
LOCATION MAP
GSX Services
Pinewood, South Carolina Facility
Scale:
10 20
miles
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application for waste disposal was submitted by Bennett to the South
Carolina Department of Health and Environmental Control (SCDHEC). The
concept was to utilize off-specification fuller's earth as an absorbent,
mix it with waste, and place this mixture in the mined-out excavation to
act as fill material during reclamation of the mined area. A layer of
undisturbed claystone is left in place in the bottom of the excavation to
act as a barrier to downward liquid movement. Since the sides of the
excavation were within the claystone formation it was assumed lateral
movement would also be impeded.
An Industrial Waste Permit (IWP-145) was issued by SCDHEC to Bennett
in November 1977, and disposal of hazardous waste began. Bennett handled a
relatively small amount of waste before the operation was obtained by
Services Corporation of America (SCA) in April 1978. SCA obtained the
lease and began to renovate the Bennett disposal area by digging up the
buried waste and placing it in a newly constructed lined trench. SCDHEC
transferred Permit IWP-145 to SCA in April 1978 and re-issued it in July
1979.
SCDHEC was granted RCRA Phase I interim authorization in February
1981, which allows the State to enforce State-promulgated regulations
(R.61-79.124 through R.61-79.270) in lieu of Federal regulations promulgated
under RCRA (40 CFR Parts 260 through 263 and 265). RCRA activities at the
site have, therefore, been effectively governed by State regulations except
for a 3-month dual Federal-State regulation period (November 1980 through
February 1981).
Phase II, A and B interim authorization was granted in November 1982,
allowing the State to issue RCRA permits for storage in tanks and con-
tainers and for treatment in tanks and by incineration. The State received
final authorization on November 8, 1985 for all aspects of RCRA except for
the 1984 amendments.
A Part B RCRA permit application was submitted on August 25, 1983 by
SCA. Subsequently, several revisions have been submitted as a result of
EPA Region IV and SCDHEC reviews.
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GSX purchased the lease in November 1984, thereby obtaining the site
operations. A provision in the lease will deed the landfill areas to GSX
once disposal operations have ceased and closure is completed.
GSX submitted another revised Part B application on September 6, 1985.
This revised application was reviewed as part of the Task Force evaluation.
On February 25, 1985, EPA Region IV issued a Compliance Order and Con-
sent Agreement (Docket No. 85-11-R) to GSX which outlined a schedule for
implementing a ground-water study program. On April 4, 1985, a Partial
Agreement and Order On Consent (Docket No. 85-11-R) was agreed to by EPA
Region IV and GSX. On January 13, 1986, a final agreement and Order On
Consent was agreed to by EPA, Region IV and GSX.
SCDHEC issued GSX a Notice of Violation (NOV) following a state inspec-
tion on May 3, 1985 for, among other items, allowing leachate to reach
excessive levels in sumps in the Section I landfill. An Administrative
Consent Order (85-64-SW) was agreed to on September 6, 1985, which resolved
all issues in the NOV and required a study to determine if the excessive
leachate levels had damaged the landfill's liner system.
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SUMMARY OF FINDINGS AND CONCLUSIONS
Task Force personnel investigated the interim status ground-water
monitoring program at the GSX Pinewood facility for the period March 1980,
when the applicable provisions of the State regulations became effective,
through November 1985. The investigation revealed the ground-water monitor-
ing program has undergone three changes since 1980.
Two monitoring well systems were replaced by a single new system in
the fall of 1985, as required by the April 4, 1985 Partial Agreement and
Order on Consent between GSX and EPA. This new system will be expanded as
the site expands.
At the time of the Task Force inspecton, the facility Part B submittal
omitted a ground-water monitoring program due to ongoing hydrogeologic
investigations. Thus, at the time of the inspection, the Part B permit
application was not in compliance with the State regulation R.61-79.270.14(c).
Subsequent to the inspection, GSX has submitted a revision to the Part B
application on January 16, 1986 which addresses the R.61-79.270.14(c)
requirements. This revision is presently under review.
The analytical results of ground-water samples collected by the Task
Force during the inspection show the presence of trace concentrations of
nickel in six monitoring wells and the French drain. The source of the
nickel in ground-water samples should be further investigated.
Other than nickel, no hazardous or"hazardous waste constituents were
positively identified as a result of analysis of samples collected by the
Task Force during the inspection.
Under current EPA policy, if an offsite TSDF is 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. Interim
status facilities must have an adequate ground-water monitoring program to
assess whether the facility has had a significant impact on ground-water
quality.
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The findings of the Task Force evaluation, as outlined in this report,
may have a bearing on the ability of the GSX site to further accept CERCLA
cleanup wastes.
COMPLIANCE WITH INTERIM STATUS GROUND-WATER MONITORING - R.61-79.265
SUBPART F
Ground-Water Monitoring System
The monitoring wells installed as part of the two early monitoring
plans were deemed inadequate as they were too few in number, were not
located immediately downgradient of the waste management areas and were
constructed in such a manner that it was not clear which zone(s) were being
monitored.
Some of the new stainless steel ground-water monitoring system wells
installed in the fall of 1985, had not been fully developed at the time of
the field inspection. Data from five of the 20 monitoring wells sampled
during the inspection may be questionable due to lack of full well
development.
Site Hydrogeoloqy
GSX has failed to fully characterize the hydrogeology of the site,
including characterization at the uppermost aquifer beneath the site.
Therefore, GSX has not provided a sufficient Part B application, as required
by South Carolina Hazardous Waste Management Regulation R.61-79.270.14(c)(2).
Whether all of the designated downgradient ground-water monitoring
system wells are immediately downgradient of hazardous waste management
areas depends on the interpretation of water level measurements from which
piezometric surface depictions are drawn. Depending on the selection of
wells from which water level measurements are taken for piezometric surface
depictions, the apparent ground-water flow directions may differ. Until
this issue is resolved in a rigorous manner, the ability of certain down-
gradient wells to immediately detect a release is in doubt.
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Ground-Water Sampling and Analysis Plan
The plan covering the new system was developed in two phases, a draft
in July 1985 and a final in October 1985. This plan corrected many previous
inadequacies, but two remained. These are: (1) no method was identified
for the analysis of total organic halogen (TOX) and (2) more than one
method was identified for the analysis of organic compounds. Only one
analytical method should be specified and followed so that statistical
comparisons of results can be made.
Ground-Water Assessment Program
Sampling of the old ground-water monitoring systems placed the facility
in the assessment phase of the Subpart F requirements [R.61-79.265.93(d)].
The initial assessment report found that no hazardous waste constituents
were identified from samples collected from the old ground-water monitoring
system. Initially, GSX proposed to return to detection monitoring. However,
after discussions with SCDHEC, GSX has decided to remain in an assessment
phase for the remainder of interim status.
GSX Contractor Laboratory Evaluation
The evaluation of GSX's offsite contractor laboratory, Davis and Floyd
of Greenwood, South Carolina, identified the following minor problems: (1)
they do not have statistically defined limits of detection, (2) quality
control for some parameters was incomplete for the samples collected just
before the site visit, due to the rush to get the samples analyzed prior to
the EPA inspection (quality control measures are lacking for several para-
meters), (3) samples for metals analysis should not be filtered as this may
bias the results low. Filtering of samples, as done by GSX, is inconsis-
tent with the methods used to determine the adequacy of ground-water as a
drinking water supply and (4) calibration procedures are inadequate.
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GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT
The ground-water monitoring information provided in the August 25,
1983 Part B application was limited to data from the old nine well System.
Due to the inadequacies in the old system, the requirements [R.61-79.270.14
(c)] could not be adequately addressed. Because of the ongoing modifica-
tion to the ground-water monitoring system, the September 1985 Part B
application omitted ground-water monitoring information. However, the
January 16, 1986 revision to the Part B application utilized the recently
obtained hydrogeologic information to discuss the [R.61-79.270.14(c)]
ground-water monitoring requirements.
TASK FORCE SAMPLING AND MONITORING DATA ANALYSIS
During the inspection, Task Force personnel collected samples from 20
ground-water monitoring wells, three leachate collection sumps and the
surface discharge of a shallow ground-water collection system. The sampl-
ing was done and analyses were made to determine if the ground water con-
tains hazardous or hazardous waste constituents or other indicators of
contamination. The monitoring wells were prepared for sampling by GSX
personnel, then all samples were collected by the Task Force contractor
(VERSAR, Inc.).
Analyses of samples collected by the Task Force do not indicate that
ground-water has been contaminated as a result of waste disposal activities
at the the site; however, the source of trace concentrations of nickel,
found in the French drain and six monitoring well samples, should be further
investigated.
FACILITY OPERATION
For all landfill cells constructed, there is inadequate documentation
describing how the units were constructed and/or closed. No as-built draw-
ings were available to Task Force personnel during the investigation. Con-
struction certifications are available from the contractor who built each
cell, but GSX did not have a complete record of these at the site during
the Task Force inspection.
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Grid location maps for the landfill Section I, cells A and B, were not
drawn correctly. GSX operating personnel used a different numerical/
alphabetical system from what had been originally proposed to designate
grids. The landfill operation records contain the system used by GSX and,
therefore, the maps must be redrawn to correctly identify placement of the
waste.
GSX has failed to adequately maintain the cover material on Section I,
cell E. This failure to control erosion of the cover could enhance liquid
migration from precipitation into the closed cell.
COMPLIANCE WITH SUPERFUND OFFSITE POLICY
Although GSX has completed some aspects of the requisite hydrogeologic
investigation, a number of critical elements are missing. The facility
must provide additional information regarding the local stratigraphy,
hydraulic gradients and hydraulic interconnection of various zones. The
above information must be known before the adequacy of the number, placement
and screened intervals of the wells which make up the GSX ground-water
monitoring system can be affirmed.
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TECHNICAL REPORT
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INVESTIGATIVE METHODS
The Task Force evaluation of the GSX site consisted of:
Review and evaluation of records and documents from EPA Region IV,
SCOHEC and GSX
A facility onsite inspection conducted October 29 through Novem-
ber 7, 1985
Onsite and offsite analytical laboratory evaluations
Sampling and subsequent analysis and data evaluation for selected
site ground-water and leachate monitoring systems and of a shallow
ground-water zone
RECORDS/DOCUMENTS REVIEW AND EVALUATION
Records and documents from EPA Region IV and the SCOHEC offices, com-
piled by an EPA contractor, were reviewed prior to the onsite inspection.
Onsite facility records were reviewed to verify information currently in
Government files and to supplement this information where necessary.
Selected documents requiring in-depth evaluation were copied by the Task
Force during the inspection. Records were reviewed to include evaluation
of facility operations, construction of waste management units, and ground-
water monitoring activities.
Specific documents and records reviewed and evaluated included the
ground-water sampling and analysis plan, outline of a ground-water quality
assessment program, analytical results from past ground-water sampling,
monitoring well construction data and logs, site geologic reports, site
operations plans, facility permits, unit design and operation reports,
selected personnel position descriptions and qualifications (those related
to the required ground-water monitoring) and operating records showing the
general types and quantities of wastes disposed of at the facility and
their locations.
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FACILITY INSPECTION
The facility inspection, conducted October 29 through November 7,
1985, included identification of waste management units, identification and
assessment of waste management operations and pollution control practices
and verification of location of ground-water monitoring wells and leachate
collection systems.
Company representatives were interviewed to identify records and docu-
ments of interest, answer questions about the documents and explain (1)
facility operations (past and present), (2) site hydrogeology, (3) ground-
water monitoring system rationale, (4) the ground-water sampling and analysis
plan and (5) laboratory procedures for obtaining data on ground-water
quality. Because ground-water samples were analyzed by an offsite labora-
tory, personnel from these facilities were also interviewed regarding
sample handling and analysis, and document control.
LABORATORY EVALUATION
The onsite and offsite laboratory facilities handling ground-water
samples were evaluated regarding their respective responsibilities under
the GSX ground-water sampling and analysis plan. Analytical equipment and
methods, quality assurance procedures and documentation were examined for
adequacy. Laboratory records were inspected for completeness, accuracy and
compliance with State and Federal requirements. The ability of each labora-
tory to produce quality data for the required analyses was evaluated.
GROUND-WATER. SURFACE WATER AND LEACHATE SAMPLING AND ANALYSIS
During the onsite inspection, the Task Force collected ground-water
samples from GSX ground-water monitoring wells and leachate samples from
leachate collection sumps in the landfills. A sample was also taken of the
shallow ground water as it flowed out of a pipe from a French drain in
order to characterize ground-water quality in this shallow zone. Samples
were taken by an EPA contractor and sent to EPA contractor laboratories for
analysis. Splits of all samples were provided to GSX. EPA Region IV
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requested and received six sample splits and SCOHEC requested and received
four sample splits for independent analysis. The NEIC received and analyzed
three split samples. Data from sampling analysis were reviewed to further
evaluate the GSX ground-water monitoring program and identify possible con-
taminants in the ground water. Analytical results from the samples col-
lected for the Task Force are presented in Appendix A.
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WASTE MANAGEMENT UNITS AND OPERATIONS
WASTE MANAGEMENT UNITS
This portion of the report describes the design, construction,
operation and management of waste disposal units and waste handling and
disposal practices at the GSX-Pinewood, South Carolina facility. This
discussion is presented here to provide a framework for assessing waste
disposal unit integrity, explain the types and placement of wastes disposed
of at GSX and serve as a reference to assist in evaluating the potential
for ground-water contamination in the event that leakage occurs and threatens
to degrade ground-water quality. Appendix B contains the excavation and
operational plans for landfill Sections I and II.
Landfills
In early 1978 Bennett began waste disposal activities at the site. A
mixture of waste and fuller's earth was placed in excavations produced by
claystone (fuller's earth) mining in the area which is now landfill Section
I. Appendix B, Figure B-l shows the Mingo Mine Excavation Plan. That area
in the excavation, designated as Section I, is the location of landfill
Section I. The mined area was initially quite extensive and portions to
the east of Section I have been graded during construction of roads, berms
drainage ditches and other activities associated with landfill ing opera-
tions. The extreme eastern portion of the excavation is still below the
original surface grade. Soils found on the site served as the construction
material for these activities. An approximately 10-foot-thick layer of
claystone was left intact after mining to serve as a base for the landfill
area with the low point of the landfill floor being approximately 30 feet
below the original surface grade. Cell A of Section I began at the toe of
the northwest slope of the excavation and construction of other cells in
Section I were developed in sequence from cell A through cell E in a south-
easterly direction.
Upon obtaining the property in April 1978, SCA began to renovate the
disposal area, moving the small amount of waste present to one area within
the excavation. One-half of cell A was constructed and the waste moved to
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that area. The other half of cell A was then constructed and disposal by
SCA began in late 1978.
Construction of the base of each cell in Section I remained constant.
After excavation (mining) of the opaline claystone, cell construction was
_7
carried out by placing a 5-foot layer of clay, [permeability of 10 centi-
meters-per-second (cm/sec)], over the residual claystone. The clay was
also extended on the east and west sides of the cell at a slope of 1:3
A
(rise to run). A 0.030-inch (30 mil) thick Hypalon liner was placed over
the clay to cover the base and sides. A 1-foot by 2-foot trench was dug at
or near surface grade on the sides, for anchoring the liner. A 2-foot soil
layer was placed on the liner, also at a 1:3 slope on the sides and base.
As the liner was laid, it was extended beyond where the cell separa-
tion berm would be placed. The berm was constructed of clay at a slope of
1:2 with the top serving as an access road. The width of this road was
usually 15 feet. The liner extension was placed into the bottom berm at
its outside surface. Prior to building the adjacent cell, a small cut was
made into this separation berm to expose the liner which was then seamed
and glued to that cell's liner. The other end of the liner was also extended
beyond that cell's separation berm to provide a seam and glue area for the
next cell's liner.
Each lift of waste is approximately 10 feet, including a soil cover.
Once a lift was completed, the berms were extended upward for the next
waste layer.
A leachate collection system and sump were placed in each subcell.
The design of the leachate collection systems changed with each newly
constructed cell in Section I. Additional collection piping was added
beginning with cell C. High density polyethylene (HOPE) pipe was used
instead of the clay pipe, beginning with cell D.
Hypalon is a registered trademark and appears hereafter without 6.
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18
The floor of each subcell generally sloped 2% toward the collection
system to enhance liquid migration to it. The collection system piping was
also sloped 2% toward the sump to allow liquid travel to it.
The sumps consisted of a cement base built into the soil layer on the
base of the subcell. A cement riser was placed on the cement base and
leachate collection lines radiated from it. As each new lift of waste was
deposited, new sections of cement riser were added to extend the sump
access. For both cells A and B, the sumps were located near the north edge
of the subcells. For cells C, D and E, the sumps were located near the
center of each subcell.
Once the cell was filled, 1 foot of soil sloped at a 10% grade, was
placed to act as a cover at cell A. A 30-mil Hypalon liner was placed over
the soil and seamed and glued to the 30-mil line extending from beneath the
waste. A compacted clay layer (permeability of 10 cm/sec) was placed
over the liner followed by a soil cover 18 inches thick at a 15% slope. A
change in state requirements altered the cover's slope to 8% for each of
the subsequent cells.
Clay berms for dividing the cell into subcells were constructed into
the soil layer so they sat on top of the liner. Berms were sloped 1:1 and
were not designed to act as roadways even though the top width was approxi-
mately 8 feet. Cell A in Section I was designed for four disposal subcells;
one each for disposal of oxidizer, alkaline, organic and acid wastes. The
expected market for oxidizer waste did not materialize; therefore, this
subcell was also used for organic wastes'.
Cell B in Section I initially was designed to have four subcells. The
separation berm between cells A and B was to be removed allowing leachate
to drain into the sumps in cell A. Instead, only three major and one minor
subcells were built (see Appendix B, Figure B-2) and sumps were placed in
the major subcells.
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19
The minor subcell was a triangle-shaped area on the west side of the
cell and was formed when the major subcell separation berms were angled
between the berms in cell A and those to be constructed in future cell C.
The separation berm between subcell A-4 and the triangle area was excavated
to form a trench, approximately 2 feet wide which extended from the top of
the separation berm to the landfill floor. Filter fabric was placed on the
bottom and sides of the trench and crushed stone was placed to a height of
approximately one lift of waste. Additional filter fabric was placed on
top of the stone and the remainder of the trench was backfilled with clay
to its original height. The floor of the triangular area was sloped to
allow drainage into subcell A-4 through the trench.
Only one lift of material was placed in the triangle area which was
then covered with a clay cap. The top of this cap then served as the base
for what was now an extension of subcell B-3. This extension area drained
to the leachate collection sump in that subcell. Appendix B, Figure B-13
is a cross-sectional depiction of cell B showing the covered area described
above.
A change was made on the cover of cell C, and was also used for all
subsequent cells in Section I. A 20 mil cover liner was used instead of a
30 rail liner.
Cell E was built in two stages with a temporary berm separating the
working area from future working areas. The drain system was extended into
the next area to be worked and inflatable plugs prevented movement in the
drains in either direction.
As each cell was installed, surface runoff was diverted through a
ditch running along the east and west sides and the separation berm.
Runoff followed drainage channels to a low area northwest of Section I
which, in turn, drains to Lake Marion. Surface runoff from the claystone
processing and drum solidification areas drains to a channel which also
empties into the low area.
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20
The shallow water-bearing sand layer presented a problem as constant
pressure against the clay berm and liner could force liquid into the cells.
A French drain was installed (see Appendix B, Figure B-12, Ground-Water
Collection System Location Map) around Section I which diverts shallow
ground water. The drain runs along the south, east and west sides of
Section I and is constructed of 6-inch perforated pipe placed in a trench
which is excavated into the opaline claystone layer and then backfilled
with gravel. A filter fabric is placed on top of the gravel and coarse
sand placed on the fabric. The drain discharges to a low area northwest of
Section I.
The cells for Section II are also placed in a mining area to the
northwest of Section I. This section is being built into a hillside which
runs along the north edge of the property. As the claystone is removed, an
excavation is produced, leaving approximately 10 feet of undisturbed clay-
stone to form the base. The excavation is approximately 60 feet below the
top of the claystone after the overburden has been removed. As the shallow
water-bearing sand is removed to expose the claystone, a ditch collects the
shallow ground water and directs it away from the open excavations. As the
excavation expands to the north, this ditch will follow it to divert the
shallow ground water. The ditch discharges to a low area west of Section
II which drains to Lake Marion.
In Section II, cells A and B have a base consisting of 5 feet of com-
_/
pacted clay (permeability of 10 cm/sec), an 80-mil HOPE liner, 9 inches
of soil and 1 foot of sand. The leachate collection system layout is
similar to Section I, cells C through E. The cover will consist of 1 foot
of soil over the waste, a 30 mil HOPE liner, 2 feet of clay and 6 inches of
topsoil. At the time of the Task Force inspection, the HOPE liner was
being installed.
The leachate collection system design in Section II differs from that
used in Section I. The sump itself is depressed approximately 5 feet below
the grade of the fill. The 5-foot compacted clay base layer follows the
depression, so that the layer is continuous.
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21
Section II, cell C, has the first leak detection system between two
liners. Construction of this and subsequent cells consists of 3 feet of
_7
compacted clay (permeability of 10 cm/sec), an 80 mil HOPE liner, a leak
detection system, 5 feet of recompacted clay, an 80 mil HOPE liner, a
1-foot coarse sand layer, filter fabric and 1 foot of soil on which the
waste is placed. All material is sloped to follow the grade in each subcell
The leak detection system consists of approximately 12 inches of sand,
and has a perforated HOPE pipe within it which is connected to a sump at
the side slope of the cell area. A pipe within the 5-foot clay layer on
the side slopes runs to the surface.
A review of landfill construction records indicated that no as-built
drawings exist for Sections I or II. Certification letters from the con-
struction contractors exist which state that the units were built in
accordance with construction drawings. Many of these letters are missing
from the GSX onsite files and attempts have been made by GSX to get them
from the contractor. This was ongoing at the time of the investigation.
The absence of as-built drawings led to confusion on how Section I, cell B,
was actually constructed. During the review of the construction drawings
for cell B, GSX onsite personnel offered more than one version on how the
triangular area was treated. GSX has a construction certification letter
describing how the triangular area in this cell was filled and then closed,
but the accompanying drawings were not available at the time of the
inspection.
GSX has chosen to treat the filled cells (those no longer receiving
waste) as under partial closure. At the time of the purchase, Section I
had a cover placed on it which was to undergo a year of settling. This
partial closure phase began in the spring of 1984. Section I has since
been graded and seeded for a final cover. Section II, cells A and B, were
receiving the cover liner during the inspection and soon will receive the
final soil cover. GSX intends to commence facility final closure when the
site can no longer accept waste (i.e., all cells are filled). This is
being done so the entire site will be monitored during post-closure and not
each cell or section. This is addressed in the site's closure/post-closure
plan, which is a portion of the Part B application.
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22
Treatment
Bulk liquid Is solidified In one of two open, below grade tanks. The
tanks are split In half heightwise and placed horizontally in below grade
vaults. The vaults can be entered for inspecting the tanks through a man-
hole. This operation is to be upgraded as described in the Part B submit-
tal and will handle approximately 90,000 gallons per day.
Bulk liquid which has been tested for solidification capabilities
prior to its acceptance is brought to the tanks and pumped in on a batch
basis. Pozzolanic material, a mixture which includes fuller's earth, is
added in amounts determined by laboratory testing or past experience. A
backhoe then mixes the material and a sample is taken to test its structural/
absorbtion properties. For hazardous waste containing greater than 10%
liquid, a compaction test is performed as well as a paint filter test. The
compaction test involves the sample withstanding 50 pounds-force-per-square-
inch in order to pass. This requirement was imposed by EPA, Region IV.
All other landfilled materials containing liquids must be tested by the
paint filter method before landfill ing. This is done to comply with the
liquid landfill ban Imposed by the 1984 RCRA amendments.
GSX also performs a test to determine if the landfill material can
withstand equipment being driven on it. Nonhazardous waste and hazardous
waste not containing organics 1s tested by taking a 3/4 inch diameter rod
that is 24 inches long and attempting to push it into the sample. If the
rod goes 1/4 inch or less into the sample, the material can withstand 1,000
pounds-force-per-square-inch and is landfilled.
Adding pozzolanic material and mixing continues until the material
passes the applicable test(s). The material is then landfilled in the
appropriate subcell.
Drummed liquid waste is solidified by employing a screw mixer system
on a batch basis. This system consists of two feed hoppers, for liquid and
absorbent, a screw mixer and a drum feeder. Liquid from the drums is
drained into one of the mixers' hoppers. Sorbent material is then added
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23
through another hopper based on either laboratory tests or experience.
Each of the three subcell materials (acids, bases, organics) has Its own
process line. The purpose of this process Is not to produce a structurally
sound material but one In which liquid 1s adequately absorbed. The mixed
material, is then placed 1h drums for placement in the appropriate subcell.
Each drummed liquid process area has its own drain and collection
system leading to a buried 10,000-gall on tank. These tanks are pumped
periodically and the fluid treated prior to landfill ing.
Storage
The facility has the capability to store up to 2,000 containers
(55-gallon drums) of hazardous waste. The storage is needed to accumulate
enough material for operation of the drummed solidification operation.
Material arriving onsite is sent to a roofed, two-sided, enclosed, cement
floored area. The drums of material are segregated by organics, acids and
bases. The floor is divided into areas, each of which has its own drain
and collection system which drain to 600-galIon buried tanks. These are
periodically pumped and treated for disposal onsite.
FACILITY OPERATIONS
Leachate Collection
Operations at the landfill, in addition to waste disposal and place-
ment of lift cover, Include the removal- of leachate from the collection
system on a periodic basis. Leachate levels are recorded daily at each
subcell's sump and the volume calculated. The daily leachate report shows
the liquid level and the corresponding volume, but the volume of leachate
pumped is not recorded. This pumped volume would also include fluid drained
from the collection lines and that which enters the collection system from
the subcell floor. Accumulated rainwater from the open cell and pumped
leachate are collected onsite. This liquid is either solidified onsite or
shipped offsite to OuPont, Oeepwater, New Jersey for treatment. The volume
solidified onsite is dependent on the excess solidification capacity
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24
available. In nearly all cases, the leachate and rainwater Is shipped
offsite for treatment as excess capacity is not available.
During an inspection on February 25, 1985, State inspectors found that
leachate levels in some sumps of Section I reached or exceeded 15 feet.
This issue was addressed in a notice of violation from SCDHEC, dated May 3,
1985. As part of a State consent order, SCDHEC required daily monitoring
of leachate levels, removal of leachate in excess of 3 feet and submittal
of a study to determine if the liner system had been compromised by the
excessive levels. A report dated October 29, 1985 was prepared by a GSX
consultant which concluded that no damage occurred to the liner system as a
result of high leachate levels.
Leachate has been pumped mostly from Section I, cells A and E, and
Section II, cells A and B. Section I, cell A, accepted liquids and this
could account for the volumes generated. Section I, cell E and Section II,
cells A and B, all were in use within the year preceding the Task Force
inspection and precipitation was accumulating in the open subcells of
Section II during the inspection. This could also account for part of the
volume generated.
Incoming Hazardous Waste Handling
Waste composition (characteristics) to be handled at the site is
reviewed by the SCDHEC prior to its acceptance. The waste generator will
fill out a State authorization report and send.it to GSX and SCDHEC. The
State will review the form and may disapprove it for handling. The authori-
zation report is to be submitted to the State at least 15 days prior to the
first shipment. In the past, SCOHEC issued disposal permits, but none are
issued at present.
GSX, meanwhile, reviews the authorization report along with a sample
of the waste from which a fingerprint analysis is developed. This is kept
in the generator file for future use if the waste is accepted.
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25
The facility accepts a wide variety of wastes such as oils, solvents,
sludges, manufacturing by-products, paints, Inks, spent pickle liquor,
plating wastes, acids, caustics and organic chemicals. Wastes not accepted
at the facility are PCBs, dioxln containing wastes (RCRA waste codes F022
through F028), RCRA waste code K099 (untreated wastewater from the produc-
tion of 2,4-0), radioactive material, explosives, oxidizers, cyanides and
flammable materials.
The site is limited to 135,000 tons of hazardous waste to be land-
filled each year. This is a requirement found in the South Carolina Hazard-
ous Waste Management Act, as amended.
When a generator is ready to ship waste, GSX 1s contacted and a work
order is issued. Upon arrival at the front gate, the manifest and work
order are checked by the guard. The load is directed to the scale where it
1s weighed and sent on to the staging area. The manifest and work order
are given to the GSX traffic clerk for review. The manifest is also reviewed
by a full-time onsite State inspector. A sample is taken and analyzed for
fingerprint matching. If the paperwork is correct and the waste matches
its fingerprint, the State inspector and the lab approve its unloading. A
site authorization form is filled out in which the lab will designate the
subcell location and notify the landfill supervisor that a load is available
for disposal. Bulk and drummed liquid is sent to the solidification process
for treatment and the authorization form identifies the relative amount of
absorbent to use. The form also Identifies the subcell to accept the
waste.
Landfill waste is issued a grid location by landfill personnel based
on the unit's current operation. The grid location is written on the
authorization form and given to the traffic clerk.
In the event that off-specification waste is found, the generator is
called for instructions. If waste is rejected, it is sent back or directed
to the alternate TSD identified on the original manifest. A letter is sent
with the manifest explaining what has occurred and outlines the generator
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26
instructions. The letter Is also sent to the generator for his signature
and return but the waste is not held at the site pending receipt of the
signed letter.
A review of records was conducted for the period 1980 through 1985.
These consisted of the State authorization reports, facility unloading
authorizations, fingerprint analyses and cell receiving reports. Some fin-
gerprint analyses for 1980 were not found. The site is presently placing
all records in computer files for easier access. Tracking of the waste was
readily followed by the forms and compared to the landfill grid maps.
Problems were found in Section I, cells A and B, as the grid maps did not
match the unloading authorization grid locations. The problem was caused
by the use of maps which were based on the system proposed to be used. The
unloading authorization form used a system followed by landfill personnel.
The maps showed cell A had grids 1 through 6, while cell B had grids 1
through 4. Personnel numbered the grids in cell A, 1 through 5 and those
in cell B, 6 through 8. The proper numbering system map is to be drawn for
cells A and B and kept onsite. An explanation 1s to be attached to it
describing why changes were made. This map will accompany the deed restric-
tion once the site is closed.
The failure to maintain an accurate map or diagram of the location of
each disposal location is a violation of R.61-79.265.73(b)(2), 265.119 and
265.309. Due to errors in properly recording the grid locations used in
Section I, cells A and B, GSX could not identify the location of waste dis-
posal through the use of their operating record. As a result, GSX would
provide a faulty record of waste disposal to the local zoning authority or
the agency with jurisdiction over land use.
Maintenance of Landfill Cover
Severe erosion problems were noted during the Task Force investigation
at the cover for Section I, cell E. The cover had been seeded but vegetation
had not begun to grow. As a result, precipitation and runoff were causing
portions of the cover to wash away to the southern portion of the cell
area. Erosion of the cover will reduce its effectiveness in preventing
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27
downward migration of liquid into the closed cell. This has the potential
for increasing liquid migration from the cell into the ground water. The
failure to adequately maintain the cover and minimize erosion is a violation
of R.61-79.265.310(a).
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28
SITE HYDROGEOLOGY
HYDROGEOLOGIC UNITS
A detailed characterization of the site hydrogeology was in progress
at the time of the Task Force inspection, although more general hydrogeolgic
descriptions had been done. GSX was attempting to identify the most prob-
able paths of potential contaminant migration from landfill units to ensure
that new monitoring wells were located properly. This section presents a
general description of the hydrogeology in the vicinity of the GSX facility.
The hydrogeological and ground-water flow discussion in this report is
based on findings reported by GSX consultants, AWARE Incorporated of West
Mil ford, New Jersey (AWARE). Figure 3 identifies the locations of previous
site characterization work and all monitoring wells.
The facility sits on the South Carolina Coastal Plain, which consists
of layered sedimentary deposits. These deposits thicken in a wedge-like
fashion to the southeast toward the ocean. This wedge of sediments lies
unconformably on the Piedmont basement rock.
The first group of rock formations above the bedrock is the Lumbee
Group consisting of, from lower to upper, the Middendorf, Black Creek and
Peede Formations. The Middendorf Formation is mostly kaolinite and quartz
sand with clay units, and includes numerous aquifer zones. The depth to
the top of the Middendorf is approximately 600 feet at the GSX site. The
town of Pinewood taps the Middendorf as a water supply with a well screened
in the interval between 700 and 750 feet below land surface; No test
drilling at the site has penetrated this formation.
The Black Creek Formation overlies the Middendorf and consists of
clays, shales and sands. The sand zones serve as major aquifers for the
area. The clay and shale zones act as aquitards. The depth to the top of
the Black Creek ranges from about 80 feet to about 140 feet at the GSX
site. The upper portion of the Black Creek is utilized by several produc-
tion wells at the GSX site.
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FIGURE 3
LEGEND
NOTE TOPOGRAPHY OfVELUPCO tOOM it*ปL
StPT 1981 Blf AlP. "MOfOGRAPMlCS iNC .COMPILED Bป'OP
PROPERTY UHC
KM GROVNO-IMTCD NONITOR1NG STSTCM HELL
TEST BORING LOCAIION
1-1 IMRU B-7 DRILLED IซI7H IS PART 01 INITI
HrtWOGtULOCIC INVtSIIUA-IQN
8-8 THOU e-li ORILUU 1479 CONHRfMTOHT U0ซ4
PUT Or AB[A A. 8, C UIMGN
6-17 Thau 1-20 DRIUtU 1980 CONflWWIOBt BO1
PAST Of ARIA D AND t UCS1GN
8-21 IH8U B-S3 OeiLLCO AS PART OF HiOaOGEOU,
INVESTIGATION PERrORHCC SEPT OCT 1981
B-67 MILLฃ0 AS PART Of HTOROGEOlOGIC INVES.
CONDUCTED WRCH 1982
S-68 THOU ป79 DRILLED AS PART OF HVOMOCEOL
INVESTIGATION CONDUCTED AUGUST. 1982
B-80 EIPLORATORT BODING DRILLED Hป" 1983
B-81 THRU B-84 DRILLED NOV 1983
TEST PIT LOCATION
TP-I THRU TP-32 DUG 1978 AS PART Or INITIAL
INVESTIGATION.
TP-33 THRU TP-52 DUG AS PAOT OF ON-SITE UA
INVESTIGATION DEPORT OCT 1979.
TP-53 AND TP-S4 DUG AS PART OF HIOKOGEOLOGI
INVESTIGATION CONDUCTED AUGUST. 1982
WELL LOCATION
DRILLED 1978 AS PART OF INITIAL HfDROGEOLOG
CORE BODING LOCATION
DRILLED ป1 OR PAUL BENNETT 1972
AUGER BODING LOCATION
DRILLED Br DR. CAUL BENNETT 1972.
ปUป> EXPOSURE LOCATION 1972
.vป BORINGS 2-0. 3-D. 4-D. AND B-S SERVE AS GRO
^ NONITODING WELLS UPGRADED SEPT 1981
WRINGS 5-0 THRU 9-0 DRILLED NAT/JUNE 1983.
GROUND HATER MONITORING WELLS
-wtu-J
El
GROUND-WATER
MOMTORJNG WELL LDCAHONi
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30
The second group of rock formations overlying the Lumbee Group is the
Black Mingo Group consisting solely of the Rhems Formation at the GSX site.
The Rhems overlies the Black Creek Formation and 1s divided into the Sawdust
Landing and the Lang Syne members (lowermost and uppermost, respectively).
The Sawdust Landing member averages about 30 feet in thickness through-
out the site and consists of sands, silts and clay beds. The top of the
Sawdust Landing is between 20 and 120 feet below the natural surface at the
GSX site and slopes to the east and northeast across the site. The Sawdust
Landing has been the focus of ground-water monitoring during the interim
status ground-water monitoring program and is considered by GSX to be the
uppermost aquifer beneath the landfill facility for the purpose of meeting
ground-water monitoring requirements.
The Lang Syne member overlies the Sawdust Landing member and contains
the massive opaline claystone unit in which trenches are excavated during
mining of fuller's earth. At least a 10-foot thickness of this material is
left in place below the bottoms of the trenches. This layer is intended
to serve as the base of and a natural geologic backup system for the trench
and liner systems which serve as the individual waste disposal units.
A surficial Red Sand Unit mantles portions of the site and is partially
saturated with ground water under natural conditions. This unit is stripped
off prior to mining of fuller's earth and subsequent construction of waste
disposal cells. Along the upgradient periphery of Section I, this unit is
drained by a French drain. A ditch along the upgradient side of Section II
diverts drainage, from this unit away from working areas.
GROUND-WATER FLOW
Ground-water flow across the site, as described by AWARE, is generally
in a southwesterly direction with the recharge areas being east and north-
east of the site and the ground-water discharge area being in the vicinity
of Lake Marion to the west and southwest of the site.
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31
AWARE reports in situ hydraulic testing results using recovery tests
_4
in wells for permeability of the Upper Black Creek range from 1.2 x 10
.4
cm/sec to 8.0 x 10- cm/sec having a geometric mean permeability from three
.4
tests of about 2.3 x 10 cm/sec. Results of permeability testing in the
.7 _s
Sawdust Landing range from 1.7 x 10 cm/sec to 2.2 x 10 cm/sec and have
.6
a geometric mean permeability of about 6.6 x 10 cm/sec.
GSX's hydrogeologic investigation reports were prepared by their con-
sultants AWARE. The Task Force came to the following conclusions and
recommendations as a result of the review of these reports.
1. GSX has failed to fully characterize the hydrogeology of the site
particularly with respect to:
a. Continuity or discontinuity of individual stratigraphic
units within the Sawdust Landing and the Upper Black Creek
b. Hydraulic interconnection or isolation of permeable zones
within the Sawdust Landing and the Upper Black Creek includ-
ing differences in vertical hydraulic head distribution
between zones
c. Hydraulic gradients, time of travel and dispersion charac-
teristics in the permeable zones of the uppermost aquifer
2. GSX has failed to verify the lower limit of the uppermost aquifer
The failure to fully characterize the site hydrogeology and to verify
the lower limits of the uppermost aquifer, as required, will result in the
facility being unable to fully comply with Part B requirements found at
R.61-79.270.14(c).
The above information must be provided before the adequacy of the
ground-water monitoring system can be affirmed.
It is the consensus of the Task Force that GSX Services, Inc. should
be required to:
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32
1. Adequately characterize the geology of the site, at a minimum
a. Define the vertical and lateral extent of the sand units
within the Sawdust Landing member of the Rhems Formation
b. Further define the areal extent and continuity of the clay
unit at the base of the Sawdust Landing member that the GSX
believes Is the unit that segregates the Sawdust Landing
from deeper aquifers.
2. Adequately characterize the ground-water hydrology of the site,
at a minimum
a. Install a series of geographically positioned piezometer
clusters across the entire site into all sand units within
the Sawdust Landing member and, if necessary, into the Upper
Black Creek Formation to determine the head relations
b. Conduct a sufficient number of pump tests across the site to
determine if interconnection exists between the Sawdust
Landing member and the Upper Black Creek Formation
c. Define and maintain a record of the hydraulic head in frac-
tured zones of the opaline claystone as part of the program
of installing piezometer clusters adjacent to the downgrad-
ient sides of Sections I and II.
3. Provide all previously requested data which was not submitted
with the December 1985 hydrogeologic report
4. As a result of the site characterization studies, define the
uppermost aquifer
5. Present a modified ground-water monitoring system.
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33
GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS
Ground-water monitoring at the GSX facility has been conducted under
State interim status regulations and the requirements of a State hazardous
waste permit. The following is an evaluation of the monitoring program
between November 1981, when the ground-water monitoring provisions of the
RCRA regulations became effective, and November 1985, when the Task Force
investigation was conducted. This section addresses:
1. Regulatory requirements
2. Ground-water sampling and analysis plan
3. Monitoring wells
4. Sample collection and handling procedures
5. Sample analysis methods and data quality
6. Ground-water quality assessment program (implemented in 1985)
REGULATORY REQUIREMENTS
Ground-water monitoring at the site has been regulated by three sources.
(1) Industrial Wastewater Permit-145 (IWP-145) conditions, (2) South Carolina
Hazardous Waste Management Regulations prior to June 1984 and (3) the State
equivalent of 40 CFR Part 265, Subpart F. Permit IWP-145 references the
State regulations and for the purpose of this report, the State regulations
prior to June 1984, will be discussed with the permit.
The State of South Carolina received RCRA Phase I interim authorization
in February 1981. At that time, the State regulations became enforceable
in lieu of the Federal ones. These regulations (South Carolina Hazardous
Waste Management Regulations R.61-79) were revised in June 1984 to be
essentially equivalent to the Federal regulations. The State interim
status ground-water monitoring requirements are found in R.61-79.265,
Subpart F.
After November 19, 1981, Permit IWP-145 and RCRA ground-water monitor-
ing programs followed a separate but parallel track. Beginning with SCA
and continuing with GSX, the site has been responsible for complying with
the above programs which, at some times, overlapped.
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34
Permit IWP-145
Ground-water monitoring began at the site with the SCDHEC issuance of
Permit IWP-145 to SCA on April 10, 1978. Monthly monitoring consisted of
sampling and analysis for pH, total organic carbon (TOC), chemical oxygen
demand (COD) and parameters to be determined by SCDHEC, based on the types
of waste disposed.
The July 11, 1979 reissuance of the permit required the sampling and
analysis of those parameters in Table 1. These parameters were to be moni-
tored on a monthly basis except for the presence of organic constituents,
which were monitored quarterly. SCA also agreed to sample and analyze for
those parameters in Tables 2 through 4. These parameters were monitored
quarterly. Monitoring for all parameters in Tables 1 through 4 ceased when
the site found a statistical difference in the RCRA ground-water monitoring
wells.
R.61-79 Part 265. Subpart F
RCRA ground-water monitoring at the site was regulated by the South
Carolina equivalent regulations to 40 CFR Part 265, Subpart F. Tables 5
through 7 outline the parameters which were to be sampled and analyzed.
All the parameters were to be monitored quarterly for 1 year to establish
background concentration for each parameter. During the period, four
replicate measurements were to be obtained for each parameter at each
sampling event.
After the first year, Table 7 parameters were to be monitored semi-
annual ly, while Table 6 parameters were to be monitored annually.
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35
Table 1
INDUSTRIAL LANDFILL PERMIT
IWP-145 PARAMETERS
Water level
Specific Conductivity (mho/cm)
Total dissolved solids (rag/2)
PH
Concentration of Nickel (mg/2)
Concentration of Phenolic compounds (mg/2)
Concentration of Chromium (mg/2)
Concentration of Lead (mg/2)
Concentration of Mercury (mg/2)
Concentration of Arsenic (mg/2)
Concentration of Cadmium (mg/2)
Concentration of Endrin (mg/2)
Concentration of Methoxychlor (mg/ฃ)
Concentration of Copper (mg/2)
Concentration of Zinc (mg/2)
COO
Presence of organic constituents as deter*
mined by scanning by gas chromotography (to
bซ don* quarterly)
Table 2
SCOHEC MINIMUM ANALYSIS
Specific conductivity mho/cm @ 25ฐC.
Temperature ฐC.
Total dissolved solids (TOS) mg/2
Chloride mg/ฃ
PH
Dissolved organic carbon (DOC) mg/2
Two principal metals mg/2
(found largest quantities or which
best serve as indicators)
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36
Table 3
SCDHEC COMPREHENSIVE ANALYSIS
SCDHEC minimum analysis
Plus EPA interim primary drinking water standard*
Plus EPA proposed secondary drinking water standards
Plus concentration of Beryllium mg/ฃ
Plus concentration of Cyanide mg/ฃ
Plus concentration of Nickel mg/ฃ
Plus concentration of phenolic compounds (as phenol) mg/ฃ
Plus presence of organic constituents as determined by a
scanning by gas chromatography
* Except radioactivity levels
Table 4
PROPOSED SECONDARY
DRINKING WATER PARAMETERS
Chloride
Copper
Foaming agents
Iron
Manganese
Sulfate
TDS
Color
Corrosivity
Odor
PH
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37
Table 5
INTERIM PRIMARY DRINKING WATER STANDARDS
Parameter
Arsenic 0.05 mg/2
Barium 1.0 mg/2
Cadmium 0.01 mg/2
Chromium 0.05 mg/2
Fluoride 1.4-2.4 mg/2
Lead 0.05 mg/i
Mercury 0.002 mg/i
Nitrate (As N) 10 mg/S.
Selenium 0.01 mg/2,
Silver 0.05 mg/2
Endrin 0.002 mg/2
Lindane 0.004 mg/2
Methoxychlor 0.1 mg/2
Toxaphene 0.005 mg/2
2,4-D 0.1 mg/2
2,4,5-TP Si 1 vex 0.01 mg/2
Radium 5pCi/2
Gross Alpha 15pCi/2
Gross Beta 4 millirem/yr.
"Turbidity 1 NTU
Coliform Bacteria 1/100 m2
* Turbidity is applicable only to surface
water supplies.
Table 6
EPA PARAMETERS
ESTABLISHING GROUND-WATER QUALITY
Chloride
Iron
Manganese
Phenols
Sodi urn
Sulfate
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38
Table 7
EPA PARAMETERS USED AS INDICATORS
OF GROUND-WATER CONTAMINATION
PH
Specific Conductance
Total organic carbon
Total organic halogen
GROUND-WATER SAMPLING AND ANALYSIS PUN
Three Ground-Water Sampling and Analysis Plans (SAP) have been prepared
in response to RCRA requirements. These are: (1) an SAP dated November 16,
1981, which covered landfill Section I, prepared by SCA, (2) an SAP which
was a part of the Part B permit application submittal dated August 25,
1983, which covered landfill Section II, prepared by SCA, (3) a sampling
and analytical protocol included in the "Interim Status Ground-Water Monitor-
ing Plan" (October 25, 1985) for the new system.
November 16. 1981 SAP
This SAP was designed to sample the ground water at the section which
was the only hazardous waste management landfill in existence at that time.
Monitoring under this SAP began in January 1982. This SAP also outlined
Permit IWP-145 and other state imposed monitoring requirements.
August 25. 1983 SAP
This SAP was designed to sample the ground water at the Section II
landfill which was starting up. Monitoring under this SAP began in October
1983.
October 25, 1985 SAP
This plan was formally submitted by GSX as the SAP to be followed for
subsequent sampling at the new wells. Monitoring under this SAP began in
October 1985. The entire site would be sampled as one entity and the
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39
previous SAPs were discontinued. Many deficiencies from previous plans
were corrected, but the following deficiencies remained:
There is no identified method of analysis for total organic
halogen.
More than one analytical method is listed for organic compounds.
The SAP included the operation of the new Well Wizard sampling device.
The SAP did not include a ground-water assessment plan outline because GSX
had already developed a Ground-Water Quality Assessment Plan and was in the
assessment mode.
The monitoring systems initially placed around Sections I and II were
to be sampled concurrently with the new one for a 6-month period ending in
May 1986. Plans for the abandonment of the old system wells will then be
implemented upon SCDHEC approval.
MONITORING WELLS
Prior to 1985, there were two well systems, totaling nine wells,
designated to monitor ground water around the Sections I and II landfills
[Figure 4]. The existing RCRA ground-water monitoring system at the GSX
site consists of 29 wells which were installed during 1985 [Figure 5].
These 29 wells replace the nine wells for purposes of ground-water monitor-
ing because the old systems were judged to be inadequate. In this report,
these systems shall be referred to as the "old" and "new" monitoring systems
[Table 8].
Well Construction - Old System
Well construction details of the old monitoring system, including Sec-
tions I and II, appear in Table 9. The annular space opposite the screens
Veil Wizard is a registered trademark and will be shown hereafter
without the 9.
-------
40
v
I
9
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e
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-------
-------
Table 8
WELLS DESIGNATED FOR GOUND-WATER MONITORING
DURING INTERIM STATUS AT THE GSX FACLITY
Well
B5
20
3D
40
5D
60
7D
80
90
MW-1
MW-2
MW-3
MW-4
MW-5
MW-6
MW-7
MW-8
MW-9
MW-10
MW-11
MW-12
MW-13
MW-14
MW-15
MW-16
MW-17
MW-18
MW-19
MW-20
MW-21
MW-22
MW-23
MW-24
MW-25
MW-26
MW-27
MW-28
Dates of Active Area
Monitoring Monitored
Old System
Section I
Section I
Section I
Section I
Section II
Section II
Section II
Section II
Section II
New System
Section II
Section II
Section I
Section I
Section I
Section I
Section I
Section I
Section I
Section I
Section I
Section I
Section I
Section I
Section I
Section I
Section I
Section II
Section II
Section II
Section II
Section II
Section II
Section II
Section II
Section II
Section II
Section II
Monitoring
Designation*
Upgradi ent
Oowngradi ent
Downgradient
Downgradient
Upgradi ent
Oowngradi ent
Downgradient
Downgradient
Downgradi ent
Upgradi ent
Upgradi ent
Upgradi ent
Upgradi ent
Downgradi ent
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradi ent
Downgradi ent
Downgradi ent
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradi ent
-------
43
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-------
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In Section I wells is filled with a gravel pack (unspecified) overlain by a
bentonite pellet seal, grout and miscellaneous backfill to near the surface
[Figure 6]. The cement surface seals are about 1 foot deep. The annular
space opposite the screens in Section II wells is filled with pea gravel
overlain by a 1- to 3-foot bentonite pellet seal and cement bentonite grout
to the surface.
Each well, in the old system, had an air lift device installed for
sampling and was cleaned of sediment prior to use. The cleaning or develop-
ment stage involved agitating the well water volume to suspend sediment so
it could be removed.
Tests were also done at the time of construction of the old wells to
identify the maximum air pressure to be used so that the sample would not
be altered (e.g., aerated or degassed). The goal was to obtain the most
volume of water with the least injected air pressure.
Well Construction - New System
The new monitoring system consists of 29 wells including four upgradient
wells (MW-1 through -4) and twenty-five downgradient wells (MW-5 through
-28 and MW-23A). Well construction details of the new system appear in
Table 10. A diagram of the typical well construction for the new wells
appears in Figure 7.
All of the new wells are constructed of 2-inch stainless steel (Type
316) pipe with 10-foot stainless steel (Type 316) screens. Coarse sand in
the annular space opposite the screen generally extends above the screen 1
to 3 feet. A bentonite seal, approximately 4 feet thick, overlies the sand
pack, which is overlain by cement and bentonite grout extending to the
ground surface. A concrete pad is constructed around the well at the sur-
face and provides additional protection against downward migration of sur-
face runoff.
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45
* PVC (4-in.)
CEMENT 86NTONITE
GPOUT
FIGURE 6
TYPICAL GROUND-WATER MONITORING WELL
OLD SYSTEM
Revised from AWARE, Inc.
-------
46
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-------
47
LOCXINO CAP-
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Stainless Steel
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-BENTONITE PELLET SEAL
FIGURE 7
TYPICAL GROUND-WATER MONITORING WELL
NEW SYSTEM
.Revised .from AWARE, Inc.
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48
Well Locations
Locations of the old monitoring wells will not be discussed because
these wells are being phased out of the interim status monitoring program.
Only the locations of the new wells are discussed here.
Regarding the new monitoring well system, additional hydrogeologic
study may indicate various water-bearing zones are interconnected and the
wells may, therefore, not be screened in appropriate units. In the case of
interconnected water-bearing zones, well clusters may need to be placed to
monitor each zone.
MW-1 and MW-2 are intended to provide upgradient background ground-
water quality data for Section II. MW-3 and MW-4 are intended to fulfill
the requirement for this data with respect to Section I. Locations of
these wells seem generally appropriate. However, additional stratigraphic
and hydrogeologic information is needed to assess whether the screened
intervals in these wells are correlative, both geologically and hydraulically,
with the intervals selected for monitoring in the downgradient wells.
Downgradient monitoring well locations are at the limits of the two
hazardous waste management areas (Sections I and II) and their areal dis-
tribution is probably adequate with respect to the point of compliance.
Additional information concerning the local stratigraphy, hydraulic gradients
and possible hydraulic interconnection of zones within the Sawdust Landing,
and possible hydraulic interconnection between the Sawdust Landing and the
Upper Black Creek is needed. Then, a determination can be made regarding
the suitability of the screened intervals to provide the required assurance
that the ground water is being adequately monitored.
GSX SAMPLE COLLECTION AND HANDLING PROCEDURES
The Task Force did not observe sample collection and handling by GSX
during the inspection because GSX had completed the first round of sampling
for the new monitoring system just prior to the Task Force visit. GSX did
purge the wells in order for the Task Force to take samples. The GSX
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49
purging procedure is discussed together with the Task Force sampling
procedure in a following section of this report entitled "Task Force Sample
Collection and Handling Procedure."
GROUND-WATER ASSESSMENT PROGRAM AND OUTLINE
As part of the ground-water monitoring program, SCA had found statisti-
cal differences at one monitoring well at Section I and at all downgradient
wells at Section II. These two events occurred at different times due to
the differing operation periods for each section. As required by
R.61-79.265.93, a ground-water quality assessment plan (dated June 1985)
was submitted in response to the failure of this statistical evaluation for
Section II. The assessment called for sampling of the old nine well system
for 40 CFR Part 261, Appendix VIII constituents. This sampling was conducted
during August 1985. This assessment program was being conducted concurrently
with the hydrogeologic assessment required by the EPA Compliance Order and
Consent Agreement.
Section I
Quarterly background sampling for the RCRA interim status requirements
began in March 1982. In October 1983, the first semi-annual sampling of
ground-water contamination indicators was done for comparison to the first
years' sampling results. The results were submitted to the State who found
an improper statistical method had been used. The proper calculations were
done and submitted to the State in May 1984. Statistical differences were
found at well B5 for pH and total organic halide (TOX); at well 20 for pH
and at well 30 for pH and specific conductance.
Based on these results, SCA resampled the wells in August 1984 and
could not confirm the statistical differences for any parameters in wells
20 and 3D or for TOX in B5. A difference for pH in 85 was confirmed but
was attributed to differences in analytical results and one high sample.
In June 1984, SCA also sampled and analyzed the monitoring wells for EPA
priority pollutants. No detectable levels were found for any of the wells.
SCA, therefore, concluded no statistical difference in water quality was
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50
found, but decided to enter the ground-water assessment phase at the site.
A ground-water assessment plan (GWAP) was submitted to SCOHEC In June 1985.
Section II
Quarterly background data gathering began for Section II wells in
October 1983 and continued for 10 months. Replicate samples were not
collected during the period which ended in July 1984. Only indicators of
ground-water contamination were analyzed during the period. This 10-month
period served as background for the system. The upgradient well (50) was
further sampled quarterly (on 1/84, 7/84 10/84 and 1/85) utilizing four
replicates at each sampling.
The Section II system was then statistically evaluated against the
upgradient well for Section I (B5) and against the upgradient well for
Section II (D5). Each downgradient well in Section II was also evaluated
against its own background. Table 11 shows where statistical differences
were found when comparisons were made. A resampling was done in'March 1985
and many of the differences were attributed to laboratory errors.
Table 11
STATISTICAL DIFFERENCE FOR LANDFILL SECTION II WELLS
Comparison to
Well Well B-5 Well 5-0 Own Background
6D TOC None None
70 TOC, pH,
Specific conductance pH Specific conductance Specific conductance
80 Specific conductance Specific conductance Specific conductance
9D Specific conductance, Specific conductance None
TOC
Ground-Water Assessment Results
As a result of the ground-water assessment of the site, all Section I
and II monitoring wells were sampled and analyzed for applicable 40 CFR
Part 261, Appendix VIII Hazardous Waste Constituents in August 1985. This
effort did not show detectable levels of the chosen constituents. GSX
originally proposed to return to detection monitoring; however, after
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51
discussions with SCOHEC personnel, GSX elected to remain in an assessment
mode for the remainder of interim status.
GROUND-WATER STUDY PLAN
As a result of interim status inspections conducted by both~SCDHEC and
EPA region IV, SCDHEC requested that GSX prepare a ground-water study plan
(GWSP). A plan was submitted in October 1984, was found to be deficient by
SCOHEC and was subsequently revised.
The GWSP was designed to better define the ground-water system at the
site and to replace the wells around Sections I and II. It further recog-
nized the need to upgrade the monitoring system at Section I, since the
system was not meeting the requirements of R.61-79.265.91 (a)(2).
EPA Region IV issued a Compliance Order and Consent Agreement (Docket
No. 85-11-R) on February 25, 1985, to GSX to outline a schedule for imple-
menting the GWSP agreed upon between GSX and SCOHEC. On April 4, 1985,
Partial Agreement and Order on Consent (Docket No. 85-11-R) was agreed to
by EPA Region IV and GSX.
The plan followed four phases, the first of which determined whether
the existing wells were properly placed and also consisted of a review of
past sampling data. Phase II consisted of installing piezometers to better
define ground-water flow paths, both laterally and vertically, in the Saw-
dust Landing. Phase III consisted of locating additional wells and pre-
paring a ground-water monitoring plan. Phase IV consisted of implementing
the new ground-water monitoring plan. It should be noted that this hydro-
geologic assessment was being conducted at the same time as the ground-water
quality assessment program required by R.61-79.265.93.
The new monitoring plan was developed in October 1985. This plan
defined the monitoring system evaluated during the inspection [Figure 5].
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52
GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT
A ground-water monitoring section was not Included In the September 6,
1985, Part B submittal because of the ongoing hydrogeologic studies. GSX
stated In Its Part B transmlttal letter that revisions were to be made to
the ground-water monitoring section of the August 25, 1983 Part B submittal.
Until this revised section of the Part B application Is evaluated, no
assessment of the adequacy of their program can be made.
The ground-water monitoring system that has been proposed for the RCRA
permit Is that system described In the October 25, 1985 Interim status
ground-water monitoring plan. The 29 wells described by the plan were
Installed In August-September 1985 and were sampled as part of the Task
Force effort. This is the new system described in the Ground-Water Monitor-
ing Program During Interim Status section of this report. Deficiencies in
this plan are also described in that section.
TASK FORCE SAMPLE COLLECTION AND HANDLING PROCEDURES
This section describes the well evacuation and ground-water sampling
procedures followed during the site inspection. GSX contractors measured
water levels and purged the wells scheduled for sampling. Samples were
collected by an EPA contractor for GSX and the Task Force to determine if
the ground water contained hazardous waste constituents or other indicators
of contamination. Task Force personnel observed all sampling procedures.
Water samples were collected from 20 monitoring wells and a French
drain [Table 12, Figure 5]. Selection of wells for sampling was based upon
well locations to provide areal coverage both upgradient and downgradient
of Sections I and II, giving special attention to monitoring wells in close
proximity to the downgradient sides of the older waste disposal units. The
French drain receives shallow ground-water discharge mixed with surface
runoff during and following storms.
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53
Table 12
SAMPLE COLLECTION DATA
Sample Point
MW-1**
MW-3**
MW-6
MW-8
MW-10
MW-11
MW-12
MW-13
MW-14
MW-15
MW-17
MW-19**
MW-20**
MW-21**
MW-22
MW-23
MW-23**
MW-24
MW-25
MW-26**
French drain
Organic
Leachate
Alkaline
Leachate
Acid Leachate
Samplinq
Date
10/31/85
11/06/85
11/06/85
11/06/85
10/31/85
11/05/85
10/30/85
10/30/85
10/30/85
11/07/85
11/07/85
11/05/85
11/01/85
11/07/85
11/05/85
11/04/85
11/04/85
11/04/85
1V04/85
11/05/85
10/29/85
11/01/85
11/01/85
11/01/85
Time*
0935
0905
1200
1105
1155
1015
1505
1000
1310
1100
0950
0755
1700
0915?
0835
0845
0840
1015
1145
1205
1400
0935
1305
1305
Remarks
Sample clear
Sample slightly turbid
Sample clear
Sample clear
Sample clear
Sample clear
Sample clear
>
Sample silty and grey
Sample turbid
Sample turbid
Sample clear; well dewatered;
parameters collected - 4 VOAs,
POX, POC, 2 extractable organics
Sample clear
Sample clear
Sample grey, silty; well de-
watered; parameters collected -
4 VOAs, POC, POX, 2 extractable
organics
Sample clear; triplicate poured
at this well
Sample clear
Sample clear
Sample clear; well dewatered;
parameters collected - 4 VOAs,
POX, POC, 2 extractable organics,
500 mฃ for total metals
Sample clear
4-way split: Task Force, GSX,
EPA Region IV, NEIC; straw-
colored, aqueous in nature
Black-colored with oil sheen
Straw-colored with oil sheen
* Time field measurements and filling bottles commenced, rounded to
nearest 5 minutes
** A period of recharge was allowed before sampling, due to dewatering.
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54
Three leachate samples were collected to determine their chemical
characteristics and provide a basis for assessing whether constituents in
the leachate have leaked into and contaminated the ground-water. The
chosen leachate collection sumps represent waste cells containing acid,
alkaline and organic hazardous wastes. Specific sumps sampled and waste
types represented are shown in Table 12. Locations of the sumps are shown
on Figure 5.
GSX received replicate samples of volatile organic samples and split
samples for all other parameters for each sampling station. Sample sets
for selected points were provided to EPA Region IV, SCOHEC and NEIC
[Table 13]. One set of field blanks was poured each day, for the Task
Force, by the EPA contractor at locations specified by the Task Force. The
first week of sampling, a set of field blanks was poured for GSX at the
French drain and the second week at MW-19 for a total of two sets of field
blanks for the facility. Water used to pour the blanks was HPLC Lot #855905.
One triplicate was taken from MW-23A for quality assurance/quality control
(QA/QC) purposes.
Table 13
LOCATIONS AND RECEIVERS OF SPLIT
SAMPLES OTHER THAN GSX
Location Receivers
MW-11 Region IV, SCOHEC
MW-13 Region IV, NEIC, SCDHEC
MW-14 Region IV, SCDHEC
MW-22 Region IV, SCDHEC
French drain Region IV, NEIC
Organic leachate Region IV, NEIC
All sample bottles and preservatives were provided by an EPA contract
laboratory. Samples were collected using the following protocol:
a. GSX personnel determined depth to ground water
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55
b. GSX calculated height and volume of the water column
c. GSX and Task Force personnel calculated three water-column volumes
d. GSX personnel purged the calculated three water-column volumes
(less if the well dewatered).
e. Prior to sampling (immediately after purging or after a period of
necessary recharge), the EPA sampling contractor monitored the
open well head for chemical vapors (HNlr) and radiation.
f. EPA contractor collected a sample aliquot and made field measure-
ments (water temperature, specific conductance and pH).
g. EPA contractor filled VGA vials, then filled the remaining sample
containers in the order shown on Table 14.
h EPA contractor placed samples on ice in an insulated container
immediately after filling the bottles.
The first step in the ground-water well sampling procedure is to
measure the depth to water from a reference point at the wellhead. At GSX,
that reference is a known elevation at the top of the well casing cap. GSX
personnel used a Well Wizard water level meter (Model 6000) to measure the
depth to water. The meter probe was rinsed with distilled water before and
after measuring water levels.
The water level meter used for this exercise was clean and kept pro-
tected from potential outside contamination. GSX was able to make repeat-
able measurements to within .01 foot.
The next step in the sample collection procedure is to calculate the
volume of water to be purged. The water-column volume of a well is the
volume of standing water in the well and is calculated using the depth-to-
water measurement, total well depth (from construction records) and casing
radius. GSX calculated the water-column volume properly.
For the purposes of the Task Force, the water-column volume is multi-
plied by three to compute the intended purge volume. The volume is then
8 HMJ is a registered trademark and appears hereafter without 8.
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56
measured as water flows from the well. In all cases, the Task Force used
standard field measurements (temperature, pH, specific conductivity) to
judge the representativeness of the ground water prior to sampling.
GSX purged the wells using a gasoline-fueled Briggs and Stratton air
compressor (Model SAE J607, 3hp, 127cc) to power a dedicated positive dis-
placement Well Wizard bladder pump. The ground water was evacuated to a
large barrel at the wellhead. None was allowed to run off onto the ground.
The volume measurement and purging procedures were satisfactory.
GSX indicated that the Teflon ground-water discharge line used for
sampling is cleaned with isopropanol and distilled water prior to pumping
the well. The tubes are stored individually in aluminum foil until ready
for use. The clean tubes are attached to the well head after purging
immediately prior to sampling.
After purging, the EPA contractor commenced the sampling procedure.
No chemical vapors or radiation were detected at.any of the wellheads.
Sample containers were filled directly from the discharge line. Parameter
by parameter, the sampler filled the sample container for the Task Force
and for the GSX contract laboratory. Step 'g' above was modified at sampl-
ing stations where EPA Region IV, SCOHEC and NEIC received samples
[Table 13].
At the French drain, all sample bottles except VOA* vials were filled
directly at the surface. To fill VOA vials, an intermediate glass beaker
was used. The same sequence of filling sample containers was followed.
Leachate samples were collected using a stainless steel dipper. To
fill the VOA vials, leachate was poured first into clean (dedicated) glass
beakers, then into the vials. The remaining bottles were filled directly
from the dipper through a clean glass funnel. HNU readings at the leachate
sumps appear in Table 14.
Briggs and Stratton is a registered trademark and appears hereafter
without 9.
Volatile organics analysis
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57
Table 14
HNU READINGS AT LEACHATE COLLECTION SUMPS
Location Subcell Background, ppm Inside Manhole, ppm
Section I
Trench A
Section I
Trench A
Section
Trench A
Organics
Acid
Alkaline
.6
.8
.8
1.0
1.8
1.0
After sampling was completed at a well, EPA contractor personnel took
the samples to a staging area where a turbidity measurement was taken and
one of the two sample aliquots for dissolved metals analysis was filtered.
In addition, metals, TOC, phenols, cyanide, nitrate and ammonia samples
were preserved [Table 15]. Leachate samples were not preserved.
Table 15
ORDER OF SAMPLE COLLECTION
BOTTLE TYPE AND PRESERVATIVE LIST
Parameter Bottle Preservative
Volatile Organic Analysis (VOA)
Purge and trap 2 60-mA VOA vials
Direct inject 2 60-mฃ VOA vials
Purgeable Organic Carbon (POC) 1 60-mฃ VOA vial
Purgeable Organic halogens (POX) 1 60-mฃ VOA vial
Extractable Organics 4 1-qt. amber glasses
Total Metals 1 qt. plastic HN03
Dissolved Metals 1 qt. plastic HNOj
Total Organic Carbon (TOC) 4 oz. glass HiS04
Total Organic Halogens (TOX) 1 qt. amber glass
Phenols 1 qt. amber glass H.jS04
Cyanide . 1 qt. plastic NaOH
Nitrate/ammonia 1 qt. plastic H^S04
Sulfate/chloride 1 qt. plastic
Radionuclides (NEIC only) 4 1-qt. amber glass
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58
At the end of the day, samples were packaged and shipped to the two
EPA contract laboratories, the EPA Region IV Environmental Services Divi-
sion and NEIC laboratories and the SCDHEC laboratory, as appropriate.
Samples were shipped according to applicable Department of Transportation
regulations (40 CFR Parts 171-177). Aqueous samples from monitoring wells
and the French drain were considered "environmental" and those from leach-
ate collection system sumps were considered "hazardous" for shipping purposes.
Each day of sampling, the EPA contractor prepared field blanks at one
location for each parameter group (e.g., volatile organics, metals).
Blanks were poured at locations listed in Table 16. The GSX contractor
laboratory received a set of blanks poured at the French drain and at
MW-19.
Table 16
LOCATIONS OF FIELD BLANKS
Date
10/29/85
10/30/85
10/31/85
11/01/85
11/04/85
11/05/85
1V06/85
11/07/85
Time*
1400
1345
0955
1605
0945
0730
0805
0830
Location
French drain
MW-14
MW-1
MW-20
MW-23A
MW-19
MW-3
MW-21
* riffle rounded to nearest 5 minutes
Samples were analyzed by the EPA contractor laboratories for the
parameter groups shown on Table 15. In cases where the well dewatered,
only the parameter groups listed in Table 12 under remarks, were obtained.
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59
GSX LABORATORY EVALUATIONS
The GSX onsite laboratory was evaluated on November 4, 1985 to assess
their capability to receive, handle and inspect samples of incoming waste
loads. During the laboratory inspection Mr. John Perna, Laboratory Manager,
provided information concerning the laboratory operation.
GSX contracts with Davis and Floyd, Inc. (D&F) of Greenwood, South
Carolina for analysis of ground-water samples from monitoring wells at the
Pinewood facility. The D&F laboratory assessment was made, as part of the
GSX inspection, during the period November 5-7, 1985 and included assessment
of the laboratory's capability to collect, receive, handle and analyze
ground-water samples for GSX. D&F personnel contacted during the assessment
included E. Carl Burrell, Laboratory Director; John H. McCord, Laboratory
Supervisor and Quality Assurance Coordinator and Gerald T. Smith, Analyst.
ONSITE LABORATORY FINDINGS
The onsite laboratory at GSX has a written Waste Analysis Plan (WAP)
as required by R.61-79.265, Subpart B. The laboratory has the personnel,
equipment and space necessary to complete representative checking of all
waste loads received. All waste accepted by the facility is accompanied by
a manifest which references a "Waste Product Survey" (WPS) form. This form
lists the results of the physical and chemical analyses of the waste, done
prior to acceptance by GSX. The "Waste Product Survey" form for each waste
is filed at GSX. Trucks are stopped at the laboratory and held in a parking
area until representative samples of the waste load are taken and analyzed.
The samples are analyzed to determine if they are organic, acid or alkaline
so that the waste can be routed to the appropriate cell of the landfill for
disposal. Samples are checked to determine if any excluded wastes are pre-
sent in the load. The samples are also analyzed for parameters that were
selected from the "Waste Product Survey" form that would allow the labora-
tory to state, with some certainty, that the waste received at that time is
the same waste that GSX agreed to accept in the first place. The analysis
results are recorded on the "Sample Evaluation and Material Description"
(SEMD) form. These forms are also filed at GSX. Different wastes from
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60
the same company, but a different company site has a separate pre-acceptance
form. Samples of wastes are labeled and stored in the onsite laboratory.
CONTRACTOR LABORATORY FINDINGS
During the inspection of D&F, NEIC personnel used the sampling of new
wells in October 1985 to document continuity between sampling, chain-of-
custody, analytical methodology, quality control and data reporting. The
samples collected in October did not serve as quarterly samples because the
wells were new and had not been developed at that time. The samples taken
from GSX were analyzed for background levels of the parameters listed in
R.61-79.265.92 plus volatile, semivolatile and pesticide priority pollutants.
Sampling is done by D&F employees who function as samplers and analysts.
Each sampler must qualify in the field under the supervision of experienced
samplers. The sampling protocols for each client are compiled in a manual
entitled, "Groundwater Sampling and Analysis Plan." D&F is assisted at GSX
by a person experienced in the use of a Well Wizard pump. Sample containers
leave D&F with preprinted labels applied and arrive at GSX organized accord-
ing to well site and parameter type. The preprinted labels do not have
unique numbers. A chain-of-custody form is filled in by D&F at each well
site. Each sample is identified by its well designation and analyses
required. Samples arriving at the laboratory are received by a sample
custodian and recorded in the D&F sample log. Sample containers for each
well site are assigned a laboratory number. Samples are logged into param-
eter books so that analysts are aware of what samples are to be analyzed
next.
Specific conductivity and pH were determined in the field. Temperature
correction of the results was not conducted. Samples collected for metals
were filtered before analysis, thereby generating data for dissolved metals
instead of total. Drinking water standards are based, however, on total
metals. Therefore, the GSX analytical methods are not consistent with
those required for drinking water supplies. The chief objection is that
for drinking water parameters to be determined [R.61-79.265.92], total
metals and not dissolved metals are required.
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61
D&F analyzed water samples from GSX using the methods listed in Table
17. There is a single GCMS used to analyze VGA's, base/neutrals (BNs) and
acids. The instrument is set up to run VOAs first, then BNs, then acids.
BNs and acids are also run on GCFID, if necessary, to avoid exceeding
holding times. D&F has a service contract on their GCMS. They can usually
get service in 2 days.
All instruments were in working order at the time of the inspection.
Samples are received and extracted in the same room. Organic samples are
extracted on an open bench. A single hood is operational in the extraction
laboratory and is located at the far end of the room.
The VGA and BNA results of the samples analyzed showed methylene
chloride, acetone, MEK, toluene and phthalates in the samples and blanks.
Therefore, the results are not reported.
The QC/QA procedures used at D&F are outlined in their manual, "Labora-
tory Quality Control Manual." No VGA matrix spike compounds were added to
a real sample, so no conclusion can be made about method accuracy and
precision for the samples analyzed. Spike compounds were added to blank
water; the analytical results from these spiked blanks were acceptable,
demonstrating that the laboratory is capable of obtaining acceptable analyt-
ical results using the VGA method. Surrogate spike results were generated
for BN base/neutral extractables and acid; the results were acceptable. No
other spikes or duplicates were run for BN and acids because the analysis
request was scheduled as a rush job according to instructions from GSX.
Limits of detection (LODs) were estimated by extrapolating standard ref-
erence compounds downward. LODs were estimated at 2X background. Histor-
ically, D&F does maintain Control Limit Charts that are used to evaluate
spike recoveries. D&F has documentation of regular participation in the
EPA Performance Evaluation Program in 1985. Halomethane results of 7/10/85
were not acceptable at low concentrations, but were acceptable at high
concentrations. Pesticide results of 7/10/85 were acceptable. The phenoxy
herbicide results of 1/4/85 were acceptable. D&F did not extract laboratory
blanks for each day of extracting samples. One laboratory blank was
extracted for each batch of samples regardless of how many days it took to
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62
Table 17
ANALYTICAL PROCEDURES
Parameter Method (SW-846)1
Arsenic
Barium
Beryl 1 1 urn
Cadmi urn
Chromium (T)
Copper
Iron
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Sodi urn
Zinc
Phenols
Endrln
LI ndane
Methoxychlor
Toxaphene
2,4-D
2,4,5-TP (Sllvex)
Cyanides
TOH
TOC
Sul fides
Sulfate
VGA GC/Ms
SNA GC/Ms
7060 or 7061
7080 or 7081
7090 or 7091
7130 or 7131
7090 or 7091
7210 or 7211
7380 or 7381
7420 or 7421
7460 or 7461
7470 or 7471
7520 or 7521
7740 or 7741
7760 or 7761
7770
7950 or 7951
9065
8080
8080
8080
8080
8150
8150
9010
9020
9060
9030
9035
8240
8280
'Test Methods for Evaluating
Solid Waste, Physical Chemical
Methods"; US SPA; July 1982;
SW-846; 2nd edition and
revision
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63
extract a batch. Batch size was determined by how many samples were listed
on organic extraction bench sheets. The laboratory was not using decafluoro-
triphenylphosphine or bromoflurobenzene to calibrate the GCMS at the time
of the Task Force inspection.
While both flame and furnace atomic absorption techniques are listed
in Table 17, discussion with laboratory personnel indicated that flame
atomic absorption spectroscopy techniques are used for all elemental analyses
other than arsenic and selenium. The detection limits for lead, chromium
and cadmium cannot achieve reliable results near the drinking water limits,
using the flame spectroscopic technique. Arsenic and selenium are determined
using a hydride generation method. Spiked samples have not been analyzed
and, therefore, possible matrix interferences have not been evaluated.
The analytical procedure for TOC is incomplete because the results
represent only nonpurgable organic carbon. Samples are acidified and
purged with nitrogen gas prior to determination of organic carbon, which
results in the loss of purgable (volatile) organic carbon. Analysis must
be made for purgable and nonpurgable organic carbon and the concentrations
summed to calculate a result for total organic carbon.
Quality control for cyanide determination is not fully characterized
by the inclusion of spiked samples. Matrix interferences which may create
systematic bias in the results are not determined. The lack of sufficient
glassware is given as the only reason.
The distillation of phenol in order to remove matrix interferences is
employed only if the samples are "colored." Chemical interferences are not
necessarily manifested by physical appearance. A consistent approach is
needed to eliminate indiscriminate selection of methodology.
Limits of detection are established in all of the analytical procedures
by estimation of twice the background noise level. Practically, this is a
subjective technique and a more statistical approach needs to be employed.
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64
MONITORING DATA ANALYSIS FOR INDICATIONS OF WASTE RELEASE
Tabulation, evaluation and interpretation of analytical data for
samples collected during the inspection and analyzed by EPA contract labor-
atories is discussed, in detail, in Appendix A. Splits of six of these
samples were provided to the EPA Region IV laboratory for analysis. These
stations were the French drain, MW-13, MW-24, MW-19, MW-22 and a leachate
sample. Inorganic chemical constituent analyses of these samples indicate
the presence of common naturally occurring cations and anions. Because of
the newness of the ground-water monitoring system being evaluated, it is
not appropriate to attempt to undertake a statistical comparison of upgra-
dient and downgradient ground-water quality. This comparison should be
made as soon as one year of quarterly sampling and analytical results are
available from the new system of wells. Evaluation of the EPA contract
laboratory data from samples collected by the Task Force indicate the
presence of nickel in samples from six monitoring wells and the French
drain. The source of nickel in these samples should be determined and the
first year of quarterly sampling and analysis of the new ground-water
monitoring system wells should be completed to confirm whether or not
ground water at the facility contains hazardous waste constituents resulting
from waste disposal activities.
A number of the newly-instailed wells were in a well-development stage
during the Task Force inspection. GSX was pumping the wells to remove
fluids introduced during drilling and to increase well efficiency. Turbid
ground-water discharge was observed in some wells as were changing water
quality parameters (pH and specific conductivity). Anomalously high pH
values were observed in some wells (e.g., MW-26, pH 11.5; MW-20, pH 10).
The Task Force considers the changing and anomalously high values to be
typical characteristics of ground-water discharge from developing wells.
The turbidity, specific conductivity and pH levels will probably decrease
and stabilize with time. Stabilization of these parameter values should be
noticeable in data from subsequent sampling events as more water is pumped
from each well.
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REFERENCES
1. AWARE, Inc., May 30, 1985. Draft Groundwater Assessment - Supplemental
Hydrogeologic Investigation, prepared for GSX Services of South
Carolina, Inc., Pinewood, South Carolina
Vol. I: Hydrogeologic Report
Vol. II: Appendix A - Test Boring and Geophysical Logs
Appendix B - Logs of Test Borings and Test Pits from
Previous Investigations
Appendix C - Permeability Data
Vol. Ill: Appendix D - Water Quality Data
Appendix E - Ground Water Monitoring Plan for the SCA
Pinewood facility
2. AWARE, Inc. (revised), July 2, 1985, Ground-water Assessment Plan -
Pinewood Facility, June 6, 1985 - prepared and certified by Michael R.
Brothers
3. AWARE, Inc., July 8, 1985, Draft Groundwater Monitoring Plan; prepared
for GSX Services of South Carolina, Inc.
4. AWARE, Inc., August 14, 1985, Additional Hydrogeologic Data - GSX
Services of South Carolina, Pinewood Facility
5. AWARE, Inc., September 12, 1985, Groundwater Assessment Report -
Pinewood Facility
6. AWARE, Inc., November 6, 1985, Phase IV Hydrogeologic Report: Prepared
for GSX of South Carol in*
7. AWARE, Inc., December 13, 1985, Groundwater Assessment Supplemental
Hydrogeologic Investigations,
Vol. I: Hydrogeologic Report
Vol. II: Appendix A Test Boring and Geophysical Logs
Vol. Ill: Appendix B - Logs of Test Borings and Test Pits from
Previous Investigations
Appendix C - Permeability Determinations
Vol. IV: Appendix D Summary of Laboratory Test Results
Appendix E - Ground-Water Monitoring Plan for the SCA
Pinewood Facility
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APPENDICES
A TASK FORCE ANALYTICAL RESULTS
B LANDFILL EXCAVATION AND OPERATIONAL PLANS
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APPENDIX A
TASK FORCE ANALYTICAL RESULTS
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A-l
Appendix A
ANALYTICAL TECHNIQUES AND RESULTS FOR TASK FORCE SAMPLES
GSX SERVICES FACILITY
Pinewood, South Carolina
The following discusses analytical techniques, methods and results for
water and leachate samples collected by the Task Force at the GSX Services
facility, Pinewood, South Carolina. Water sample analyses and results are
discussed in the first section; the second section addresses the leachate
analyses and results.
Field measurements on water samples, including conductance, pH and
turbidity were made by the EPA sampling contractor at the time of sampling.
No field measurements were made for the leachate samples. Laboratory anal-
ysis results were obtained from two EPA contractor laboratories (CL) partici-
pating in the Contract Laboratory Program (CLP). One CL analyzed the samples
for organic compounds while the other analyzed for metals and other
parameters.
Standard quality control measures were taken including: (1) the ana-
lysis of field and laboratory blanks to allow distinction of possible con-
tamination due to sample handling, (2) analysis of laboratory spiked samples
and performance evaluation samples and comparison of the CL results with
split sample results from other laboratories to estimate accuracy, and (3)
analysis of laboratory duplicates and field triplicates to estimate preci-
sion. The performance evaluation samples were samples of known analyte
concentrations prepared by the EPA Environmental Monitoring Systems Labora-
tory, Cincinnati, Ohio. The Region IV laboratory analyzed split samples
from wells MW-11, MW-13, MW-14 and MW-22, the French drain and the
Section I-A organic disposal cell leachate. The State laboratory analyzed
split samples from wells MW-11, MW-13, MW-14 and MW-22. Split samples from
well MW-13, the French drain and the Section I-A organic disposal cell leach-
ate were analyzed by NEIC.
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A-2
Table A-l provides a summary, by parameter, of the analytical techniques
used by the CLP laboratories and the reference methods for the sample analyses.
The CLP results are reported in the data tables and the split sample results
from the other laboratories are discussed where applicable in establishing
the reliability of the CLP results.
WATER SAMPLE ANALYSIS RESULTS
Specific Organic Analysis Results
Less than 2 ug/L of 1,1,1-trichloroethane was found in the sample from
well MW-23. This compound was not detected in any of the blanks and examin-
ation of the chromatograms and mass spectra confirm the presence of this
compound in the sample analyzed. None of the organic compounds determined
were detected above blank levels in other monitoring well samples or the
French drain sample. Table A-2 contains the limits of quantitation for the
analysis for the volatile, semivolatile and pesticide organic compounds.
Based on the matrix spike data, the volatile organic limits of quantitation
are reliable to within a factor of two, the neutral extractable organic and
pesticide limits are reliable to within factors of 2 to 4 and the acid
extractable organic limits to within factors of 2 to 10.
The CL determined 1,4-dioxane by both direct injection and purge and
trap. The results did not agree qualitatively or quantitatively. No 1,4-
dioxane was detected in the samples form MW-23A by the purge and trap meth-
od, while the direct injection method found concentrations of 25,000 ug/L
and 4,000 ug/L of 1,4-dioxane in 2 of the 3 samples collected from well
MW-23A. The 1,4-dioxane was not detected in the third MW-23A sample. The
well MW-23A sample was found to contain only 1 mg/L organic carbon which
does not substantiate the presence of the large 1,4-dioxane concentrations.
Direct injection chromatograms for some of the blanks show interference
near the retention time for 1,4-dioxane for masses 58 and 88 (the masses
used to monitor 1,4-dioxane). Further, none of the direct injection com-
pounds in the performance evaluation sample were detected by the CL.
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A-3
Because of the apparent erroneous direct injection analysis results, the
direct injection compounds should be considered to have not been determined.
Methylene chloride, acetone and 2-butanone were detected in all labora-
tory and field blanks. Bis(2-ethylhexyl)phthalate and di-n-butylphthalate
were also detected in the laboratory blanks. None of the sample concentra-
tions for these compounds exceeded the upper 99% confidence limit of the
blank values after subtraction of the average blank contaminant concentration.
None of laboratories that analyzed split samples detected any compund
above blank levels in the well samples or the French drain. The direct in-
jection and herbicide analyses were not performed by the laboratories for
the split samples.
Metals Analysis Results
The dissolved and total metals results for the groundwater monitoring
well samples and the French drain sample are reported in Table A-3. The
accuracy of each detectable value is footnoted in the table.
Besides zinc, the only other priority pollutant element detected
frequently was nickel. Nickel was detected in samples from six of the wells
and the French drain. In many of these samples the nickel was in a dissolved
form. Control measures indicate the reported nickel results are reliable.
Further, split sample results from NEIC and Region IV for well MW-13 and
French drain agreed to within a few parts per billions of the reported CL
values for nickel.
The dissolved elemental concentrations for many of the samples are
biased high. Mismatching of the calibration standards acid matrix to the
dissolved preserved sample acid matrix was the cause of the bias. In com-
parison to split sample results the bias does not exceed 20% for the major
and trace elements with the exception of zinc. Zinc contamination due to
sample handling was evident as many of the dissolved zinc concentrations
were greater than the total zinc concentrations." For example, a dissolved
zinc concentration of 88 ug/L was reported for well MW-17 while the total
zinc was reported as 33 ug/L. Further, one of the total zone spiked samples
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A-4
had a recovery of only 22%. Therefore, zinc concentrations are not reported
in the data tables.
Although antimony was determined, the results were unreliable and are
not reported. The lower 99% confidence limit for the spike recoveries was
below zero. The low antimony spike recoveries may be related to the spiking
standards use by the CL. Tin spike recoveries were also low, however,
little variability was observed in the spike recoveries indicating a problem
with the spiking standard mix. No tin was detected and the tin detection
limits have been raised to reflect the low spike recovery.
The split sample results, in general, agreed to within 20% of the CL
results.
General Analysis Results
The field measurements for conductance, pH and turbidity and the
results of other analytical testing for groundwater monitoring well samples
and the French drain sample are reported in Table A-4. The reliability of
each detectable value is footnoted in the table.
The performance evaluation sample had true pH of 7.1 which is what was
obtained by the field crew. Based on past comparisons with concurrent field
measurements, the pH values are indicated to be reliable to within 0.5 pH
units.
The conductance values are not very reliable. The performance eval-
uation sample has a true conductance of 552 umhos/cm and the field crew
obtained a value of 330 umhos/cm after temperature and cell constant correc-
tions. The bias would appear to be negative based on the performance evalua-
tion sample result, however, comparison with split sample results obtained
by NEIC indicates the error is not systematic. After temperature and cell
constant correction values of 430 umhos/cm and 390 umhos/cm were obtained
or samples from well MW-13 and French drain using the field crew measure-
ments. NEIC obtained values of 310 umhos/cm and 320 umhos/cm for split
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A-5
samples from well MW-13 and the French drain, respectively. Data tables
indicate that reported conductance values are probably reliable to within
about 200 umhos/cm.
For a number of the well samples, the reported purgable organic halogen
(POX) values are greater than the respective total organic halogen (TOX)
values. For example, a POX value of 114 ug/L was reported for the well
MW-24 sample while the TOX was reported by the CL as non-detectable at 5
ug/L. Review of the TOX data found the detection limit was actually 30
ug/L based on the standard deviation of the blanks. The spiked sample data
and the performance evaluation sample values show no indication of substan-
tial bias for either determination. NEIC determined POX for well MW-13
and the French drain samples and values of 10 ug/L and 3 ug/L were obtained,
respectively. The CL reported POX values of 11 ug/L for well MW-13 sample
and less than 5 ug/L for the French Drain sample. The positive POX values,
however, are not supported by the specific organic analyses as no organics
were detected in the wells. These anomalies cause the POX and TOX data to
be suspect and they are indicated as such in the data tables.
Although purgable organic carbon (POC) was determined, the results
were determined to be unreliable and are not reported. The CL reported a
value for the performance evaluation sample that was about 15% of the true
value.
The non-purgable organic carbon (NPOC) values are biased high by as
much as a factor of 2. This was determined by comparison of the CLP values
to the split sample values obtained by NEIC, Region IV and the State. For
example, the CLP reported a value of 3.8 mg/L for the French drain while
NEIC and Region IV obtained a value of 1.7 mg/L . For samples from well
MW-14, the CLP reported a NPOC value of 3.8 mg/L, while Region IV reported
1.9 mg/L and the State reported 1.2 mg/L. The CL NPOC values are reported
in the data table and are indicated to be biased high.
The chloride values are biased high by as much as a factor of two.
The CLP chloride values were always higher than those obtained by Region IV
or NEIC. For example, the CLP reported a value of 7 mg/L for the French
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A-6
drain while Region IV reported 4.5 mg/L and NEIC reported 4.4 mg/L The CL
chloride values are reported in the data tables and are indicated to be
biased high.
Samples collected for nitrate analyses were perserved with sulfuric
acid which is appropriate only when distinction between nitrate and nitrite
is not needed. Samples collected for nitrate analysis should be cooled to
4ฐ C. and analyzed within 48 hours a collection. Further, the colorimetric
method used is subject to positive interferences that were apparently not
compensated for by the CL procedure. This is indicated in comparison of
the CL results to the split sample results obtained by NEIC, Region IV and
the State. For example, the CL reported a nitrate value of 0.56 mg/L for
the sample from well MW-13, while NEIC and Region IV found less than 0.05
mg/L and the State reported 0.02 mg/L. NEIC analyzed samples by ion chroma-
tography that were cooled to 4'C and acidified. No nitrite was detected.
Region IV determined nitrate plus nitrite. Thus the CL nitrate results are
biased hugh due to interferences other than nitrate. The nitrate results
are unreliable and not reported in the data table.
LEACHATE SAMPLE ANALYSIS RESULTS
Specific Organic Analysis Results
Table A-5 reports the organic constituent analysis results for the
three leachate samples. Large amounts of volatile and semi-volatile organic
compounds were detected in all three leachate samples.
Although, 1,4-dioxane was detected by the CL in samples from the alka-
line leachate and the acid leachate, the results could not be confirmed as
discussed above and thus the results are not reported.
In consideration of the different dilutions analyzed, thus different
detection limits, fairly good agreement was obtained between the split sample
analyses performed by NEIC and Region IV and reported CL values for the
organic leachate samples. Generally the volatile organic concentrations
-------
A-7
agreed to within a factor of 2 while the extractable organic concentrations
generally agreed to within a factor of 3. Vinyl chloride was detected by
the CL and Region IV but not by NEIC. NEIC found 180,000 ug/L 2-propanol
while the CL and Region IV did not analyze the sample for this compound.
NEIC also detected three pesticides below the CL detection limits. NEIC
found 3 ug/L aldrin, 37 ug/L dieldrin and 19 ug/L heptachlor. Region IV
reported 10 ug/L dieldrin.
Metals Analysis Results
The dissolved and total metals results for the leachate samples are
reported in Table A-6. Depending on the suspended matter compositon, the
values reported for certain elements may not represent "total" concentra-
tions. If the suspended matter is siliceous, then values for aluminum,
calcium, magnesium, potassium and sodium are not "total" because the sili-
cate matrix was not dissolved. The heavy metal results would approximate
"total".concentrations because they are usually absorbed and are not en-
corporated in the silicate matrix.
In camparison to the split sample results the CL total values reported
for the organic leachate are biased low. The CL dissolved values are in
much better agreement with the total value's found by NEIC and Region IV.
There was very little difference between the dissolved and total values for
the split sample analyses. Other than zinc, nickel was the only priority
pollutant element detected at significant concentrations. NEIC found 1200
ug/L total nickel, Region IV reported 1000 ug/L and the CL reported 780
ug/L total nickel and 982 ug/L dissolved nickel in the organic leachate
sample. The CL reported nickel concentrations of about 3000 ug/L and
20,000 ug/L respectively for the alkaline and acid leachate samples.
Although mercury was determined, the values were determined to be un-
reliable because a spike recovery of only 10% was obtained. Mercury values
are not reported. Interference also precluded accurate determinations for
arsenic, selenium and thallium.
-------
A-8
General Analysis Results
Table A-7 reports the results of other testing for the leachate samples.
The calculated POX from the specific volatile organic results for the
organic leachate was 60,200 ug/L. The measured POX was 53,300 ug/L while
the measured TOX was only 45,400 ug/L. This indicates the POX values have
less of a negative bias than the TOX values. A substantial difference,
however, exists in the calculated POX of 18,200 ug/L for the acid leachate
and the measured POX of 92,000 ug/L. The measured TOX for this sample was
33,800 ug/L. Based on the organic carbon measurements, the acid leachate
contained about fifteen times the organic matter as the organic leachate
which may add some validity to the POX being higher. If the POX is not in
error, then the specific organic analyses were not sensitive to the halo-
genated compounds that comprise the POX, or the concentrations are biased
low or there may have been difficulty in obtaining representative samples.
The measured POX of less than 50 ug/L for the alkaline leachate is in agree-
ment with specific organics results where no halogenated compounds were
detected. The measured TOX for the alkaline leachate was 11,800 ug/L which
indicates that the specific organic analyses were not sensitive to the halo-
genated compounds that comprise the TOX.
As discussed above POC and nitrate were determined, but the results
have been determined to be unreliable and thus are not reported. The ammonia
and NPOC split sample results for the organic leachate are in agreement
with CLP values. Split sample values differed by less than 5% for NPOC and
less than 15% for ammonia.
The CL reported a chloride value of 8910 mg/L for the organic leachate
while Region IV reported 9100 mg/L. NEIC found only 5000 mg/L chloride,
however, 8000 mg/L bromide was also present in the sample. The CL and
Region IV used a titration that does not distinguish between chloride,
bromide or iodide. NEIC used ion chromatography for the anion analyses and
the presence of bromide was also confirmed by plasma source mass spectro-
scopy. The total milliequivalences of chloride reported by the CL and
-------
A-9
Region IV were 251 meq/L and 257 meq/L, respectively. The chloride
concentration found by NEIC is equivalent to 140 meq/L while the bromide
concentration is equivalent to 100 meq/L. The total halide found by the
laboratories was equivalent. Thus it is likely that chloride values for
the other two leachate samples also include substantial portions of bromide.
The bromide to chloride ratio in the organic leachate is unique when compared
to a freshwater ratio of about one part bromide to 300 parts chloride.
Because bromide and chloride have high mobility, this unique ratio may be a
good indicator for future ground-water monitoring to detect possible leakage
of the disposal cells.
Total bromine as determined by plasma source mass spectroscopy for the
NEIC split samples from well MW-13 and the French drain was 44 ug/L and 82
ug/L, respectively. Using NEIC chloride values for these samples, total
bromine to chloride ratios of one to 89 and one to 54 were calculated for
the samples from from well MW-13 and the French drain, respectively. Samples
from upgradient wells were not available for analysis by NEIC to determine
the naturally occuring ratio in the near vicinity.
None of the laboratories detected cyanide in the organic leachate
samples. However, the CL values for the other two leachate samples may be
unreliable because the holding time of 14 days was exceeded.
The sum of the phenolic compounds detected by the specific organic
analyses was 2820 ug/L for the organic leachate, 3400 ug/L for the alkaline
leachate and 10,600 ug/L for the acid leachate. Because of the generally
low recovery obtained by the specific organic analyses, one would expect
these totals to be biased low. However, these values compare well with the
colorimetrically measured values reported in Table A-7. Region IV obtained
a colorimetric phenol concentration of 1400 ug/L for the organic leachate
while the CL reported 2500 ug/L. Further, the CL obtained a spike recovery
of 160%. Comparison with the Region IV value and the high spike recovery,
would seem to indicate a high bias in the CL values which is contradictory
to the conclusion that would be drawn from the comparison with the sum of
specific phenolic compounds concentrations. These discrepancies may be due
-------
A-10
to the inablility to obtain a representative sample. The phenol data for
leachates are Indicated to be reliable to within a factor of two.
-------
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Taola A-2
LIMITS OF QtMNTITATION ซ MGMIIC COMPOUNDS
GSX SERVICES OF SOUTH CAMLIN*
Unmood. Sautli Caraltna
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Table A-5
Organic Analysis Results for the Leachate Samples
GSX Services Facility, Plnewood, SC
Station:
Compound (a)
Methyl ene chloride
Bromodlchloromethane
Chloroform
Carbon tetrachlorlde
Carbon dlsulflde
1 ,2-01bromoethane
l,l-01chloroethane
1,2-Oichloroethane
1,1,1-Trlchloroethane
1 ,1 ,2-Tr1chloroethane
1 ,1 ,2,2-Tetrachloroethane
Vinyl chloride
l,l-01chloroethene
Trans-1 ,2-d1chloroethene
Trlchloroethene
Tetrachloroethene
1,2-Olchloropropane
Benzene
Chlorobenzene
Ethylbenzene
Toluene
Xylenes
Acetone
2-Butanone
4-Methyl-2-pentanone
Styrene
Aniline
Benzyl alcohol
81s(2-ethylhexyl)phthalate
Butyl benzyl phthalate
01-n-butylphthalate
Olethylphthalate
01methylphtha1ate
Acenaphthy lene
Olbenzofuran
Fluorene
Isophorone
Naphthalene
2-Methylnapthalene
Phenanthrene
Benzole acid
Phenol
2-Chlorophenol
o-Cresol
p-Cresol
2, 4-01methyl phenol
2.4-0
LOQ Factors (d)
Volatlles
Adds
Base/Neutrals
Pesticides
Herbicides
Add
Leachate
2000.
360. c
7900.
310. c
2500.
2200. c
NO
NO
NO
NO
230. c
HO
NO
370. C
370. C
1200.
260. c
6600.
27000.
6700.
13000.
51000.
700000.
20000.
4700.
NO
NO
17000.
NO
490.
NO
2100.
2200.
NO
NO
NO
NO
2500.
NO
NO
24000.
8300.
NO
NO
NO
2300.
84.
200X
40X
40X
100X
100X
Alkaline
Leachate
NO b
NO
NO
NO
NO
NO
NO
NO
NO
NO
640. C
NO
NO
190. C
NO
NO
NO
6900.
NO
29000.
25000.
130000.
11000.
NO
3400.
43000.
53000.
NO
700. c
NO
HO
NO
NO
NO
NO
NO
NO
35000.
460. C
NO
NO
NO
NO
NO
3400.
NO
NO
200X
400X
200X
100X
100X
Organic
Leachate
1000.
NO
NO
NO
NO
NO
570.
3100.
15000.
11000.
NO
2700.
380. C
6900.
4500.
34000.
NO
1600.
1300.
NO
5600.
NO
78000.
11000.
2400.
NO
NO
100.
93. c
NO
31. c
NO
MO
50. c
32. c
38. c
430.
360.
77. c
53. c
1000.
780.
130.
140.
690.
77. c
NO
100X
20X
20X
100X
100X
a) Concentrations are fn ug/L.
b) NO Indicates not detected at LOQ given 1n Table A-2 after multiplication
by LOQ factor.
c) Values are estimated. Mass spectra matched compound Identified but the
concentration Mas less than LOQ.
d) LOQ factor 1s the factor the LOQs given Table A-2 are to be multiplied by
to correct LOQ values for the analysis dilution.
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FIGURE B-5
FH.TER FABRIC
WITH OVERLAPPING
(BOM C-22 OR EOWV.)
LANOFILLED
WASTE DRUMS
3/4" WASHED STONE
BACK ILL
PROTECTIVE SOIL COVER
30 MIL HYPALON MEMBRANE
Leachate Collection Lateral .Construction
Section I-Ccll C
-------
b-b
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TRENCH
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30 MIL HYPALQN MEMBRANE
Leachate Collection Header Contruction
Section I-Cell C
5 NOMINAL DIAMETER ^
EXTRA STRENGTH
PERFORATED VITRIFIED
CLAY PIPE
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U.S. Environmental Protection Agency
Region 5, library (ft., i 2j)
77 West Jackson Boulevard, 12th Floor
Chicago, IL 60604*3590
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