EPA-330/2-86-010
Hazardous Waste Ground-Water
Task Force
Evaluation of
Rollins Environmental
Services (TX), Inc.
Deer Park, Texas
US Environmental Protection Agency
^'SS
Chicago, IL 60604-3590
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
TEXAS WATER COMMISSION
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
July 31, 1986
UPDATE OF THE HAZARDOUS WASTE GROUND-WATER TASK FORCE
EVALUATION OF ROLLINS ENVIRONMENTAL SERVICES (TX)
DEER PARK FACILITY
The Hazardous Waste Ground-Water Task Force (Task Force) of the
Environmental Protection Agency in conjunction with the Texas Water Comnission
(TWC) conducted an evaluation of the ground-water monitoring program at the
Rollins Environmental Service, Deer Park, Texas (RES-TX) hazardous waste
treatment, storage and disposal facility. The on-site field inspection
was conducted over a two-week period from September 23 to October 4, 1985.
RES-TX is one of 58 facilities that are to be evaulated by the Task Force.
The purpose of the Task Force evaluations is to determine the adequacy
of ground-water monitoring programs at land disposal facilities in regard to
the applicable State and Federal ground-water monitoring requirements. The
Task Force effort was initiated due to concerns as to whether operators of
hazardous waste treatment, storage and disposal facilities are complying with
the State and Federal ground-water monitoring regulations. The evaluation
of the RES-TX facility focused on (1) determining if the facility was in com-
pliance with applicable regulatory requirements and policy, (2) determining
if hazardous constituents were present in the ground water and (3) providing
information to assist EPA in determining if the facility meets the EPA
requirements for facilities receiving wastes from response actions conducted
under the Federal Superfund program.
Prior to the Ground-Water Task Force evaluation, a Comprehensive Ground-
water Monitoring Evaluation (CME) inspection was performed by representatives
from the TWC and EPA Region VI at the facility on July 16, 1985. Based on
the results of this inspection, the TWC required the facility to conduct a
ground-water quality assessment program and to submit a plan for that program
within 15 days following the notification.
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While the Task Force evaluation was being conducted at RES-TX, the
owner/operator and the TWC were developing the details to be included in the
assessment plan, and the owner/operator was constructing new monitoring wells
that would be part of the assessment program. TWC granted approval of the
assessment plan on October 12, 1985. As part of the f?rst phase of the asses-
sment program, RES-TX constructed approximately thirty-five (35) monitoring
wells, many in a nested configuration, to monitor and test three seperate
permeable zones beneath the facility. Several additional wells were installed
in the second phase of the assessment, and four upgradient monitoring wells
were designated.
The results of the Task Force evaluation indicate that the facility was
out of compliance at the time of the evaluation with the Federal and State
regulatory requirements for ground-water monitoring. Deficiencies were found
in well construction, location of downgradient wells, and sampling procedures.
The analytical results for samples obtained during the Task Force evaluation
indicate that there are hazardous waste constituents in the ground water
beneath the facility.
The TWC is issuing a compliance order that addresses these deficiencies
and requires RES-TX to submit a plan for determining the extent and rate of
contaminant migration and a proposal to clean up the ground water at the
site. If the plans submitted under the provisions of the compliance order
are approved by the TWC, RES-TX may be eligible to treat, store and dispose
of hazardous waste from CERCLA response actions. A facility is eligible to
handle CERCLA waste if the owner/operator has met the requirements of the
CERCLA Off site Policy, as mentioned on page 1 o.f the Executive Summary.
A description of the Task Force activities and findings are contained
the attached report. This completes the Hazardous Waste Ground-Water Task
Force evaluation of the Rollins Environmental Services facility in Deer Park,
Texas.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUND-WATER TASK FORCE
EPA-330/2-86-010
GROUND-WATER MONITORING EVALUATION
ROLLINS ENVIRONMENTAL SERVICES (TX), INC.
Deer Park, Texas
July 1986
Steven W. Sisk
Project Coordinator
National Enforcement Investigations Center
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CONTENTS
EXECUTIVE SUMMARY
INTRODUCTION ............................. 1
SUMMARY OF FINDINGS AND CONCLUSIONS ................. 6
GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS ..,.,.,
Ground-Water Sampling and Analysis Plan ............. 8
Monitoring Well Network .....,,,...,,. . . 9
Sample Handling and Analysis Procedures . , . 10
Assessment Program Outline .................... 11
GROUND-WATER MONITORING PROGRAM PROPOSED FOR FINAL PERMIT ..... 12
TASK FORCE SAMPLING AND MONITORING DATA EVALUATION ......... 13
TECHNICAL REPORT
INVESTIGATION METHODS ........................ 16
RECORDS/DOCUMENTS REVIEW ...................... 16
FACILITY INSPECTION ........................ 17
LABORATORY EVALUATION ...... ....... 17
GROUND-WATER AND LEACHATE SAMPLING AND ANALYSIS ..... 17
WASTE MANAGEMENT UNITS AND FACILITY OPERATIONS ....... 27
WASTE MANAGEMENT UNITS . ..... ..... 27
Interim Status Regulated Waste Management Units . . 29
Non-Interim Status Regulated Waste Management Units ....... 43
FACILITY OPERATIONS . .......... 49
Waste Storage Operations .... ...... 50
Internal Waste Transfer Operations ... . 50
Waste Treatment Operations ...... ..... 50
Landfill Operations ,. . . 51
Waste Acceptance and Tracking , 53
SITE HYDROGEOLOGY 55
HYDROGEOLOGIC UNITS ................. 57
GROUND-WATER FLOW DIRECTIONS AND RATES 60
GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS 66
REGULATORY REQUIREMENTS ................. 66
GROUND-WATER SAMPLING AND ANALYSIS PLAN ....... 70
Plan Followed Until Mid-1985 ...... ........ 71
Plan Followed After Mid-1985 . . ........ 74
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CONTENTS (cont.)
MONITORING WELLS .,.,.,...,..,.,,...,....., 77
Well Construction ..,.,,.,.,..,......,,,,. 78
Well Locations and Numbers ,...,, ...... ........ 82!
RES SAMPLE COLLECTION AND HANDLING PROCEDURES
Water Level Measurements ........,.,..,..,..., 88
Purging ...... ....................... 90
Sample Collection .....,,„,.,,.,.. ..... ... 9".
Shipping and Chain-of-Custody .................. 9;'.
SAMPLE ANALYSIS AND DATA QUALITY EVALUATION ............ 9J
Initial Monitoring Well Network
(November 1981 to Nr"*>mber 1982) ................ 96
Second Monitoring Well Network (May 1983 to March 1985) ..... 93
Third Monitoring Well Network (March to September 1985) ..... 100
GROUND-WATER QUALITY ASSESSMENT PROGRAM OUTLINE .......... 103
Initial Assessment Program Outline .,,.,.....,...... 101
Revised Assessment Program Outline .,,.,....,,,...„, 102
GROUND-WATER MONITORING PROGRAM PROPOSED FOR FINAL PERMIT ....".. 104
PROPOSED MONITORING WELL NETWORK .................. 105
SAMPLE COLLECTION AND ANALYSIS . . ..... ............ 108
EVALUATION OF MONITORING DATA FOR INDICATIONS OF WASTE RELEASE .... 110
REFERENCES
APPENDICES
A PERMIT CONDITIONS FOR HAZARD WASTE, MANAGEMENT AND GROUND-WATER
MONITORING
8 CORRESPONDENCE REGARDING PERMIT CONDITIONS
C GROUND-WATER SAMPLING AND ANALYSIS PLAN IN EFFECT UNTIL MID-1985
D GROUND-WATER QUALITY ASSESSMENT OUTLINES
Part 1 - Outline Dated November 9, 1982
Part 2 - Outline in Revised Sampling and Analysis Plan (Mid- 1985)
E NOTICE OF DEFICIENCY LETTER ON REVISED PART B GROUND-WATER SAMPLING
ANALYSIS PLAN
F ANALYTICAL TECHNIQUES AND RESULTS FOR TASK FORCE SAMPLES
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CONTENTS (cont.)
FIGURES
1 Location Map .......................... 3
2 Monitoring Wells and Leachate Sumps Sampled During
Task Force Inspection ..,.,..,...,... 21
3 Location of Waste Management Units ..,.....,....., 28
4 Schematic of Wastewater Flow Through Management Units ,,..., 30
5 Site Stratigraphy ........................ 58
6 Potentiometric Contour Map of the Northern Area ......... 61
7 Potentiometric Contour Map of the Southern Area ......... 62
8 1981-1982 Monitoring Well Network ................ 83
9 1983-1985 Monitoring Well Network ................ 84
10 1985 Monitoring Well Network .................. 85
11 Proposed Monitoring Well Network for Final Permit .,.,,.., 107
TABLES
1 Sample Location and Well Description, Monitoring Well Data , , . 18
2 Sample Collection and Well Location Description, Leachate
Well Data ... .................. 20
3 Preferred Order of Sample Collection, Bottle Type and
Preservative List 23
4 Regulated Surface Impoundments ........ 31
5 Chronology of Use of Surface Impoundments, L-1000 and L-1001 . . 33
6 Waste Materials Treated and/or Stored in RES Treatment
Impoundments (L-1000, 1001, 31, 32, 33, 2, 12 and ASB) .... 34
7 Regulated Tanks ............... c 42
8 Non-RCRA Regulated Surface Impoundments ... . 45
9 Pre-RCRA Landfill Cells ..................... 48
10 RES Waste Tracking Records . 52
11 Hydrogeologic Units Identified at RES Deer Park Facility .... 59
12 Estimated Permeabilities of the Hydrogeologic Units ....... 63
13 State and Federal Counterpart Interim Status Regulations .... 67
14 Comparison of Ground-Water Monitoring Requirements in the
State Permit and TAC 69
15 Interim Status Monitoring Wells ..... ...... 79
16 Comparison of Required Interim Ground-Water Monitoring
to that Conducted by Rollins Environmental Services ...... 94
17 Organic Compounds Detected in Task Force Samples from
Monitoring Well ............ Ill
18 Organic Compounds Previously Detected in Well Samples ...... 112
19 Summary of Data for Total Organic Halogen (TOX) from
Monitoring Well Samples ..... ......... 114
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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 complying with the
ground-water monitoring requirements promulgated under the Resource Con-
servation and Recovery Act (RCRA)*. In question is the ability of existing
or proposed ground-water monitoring systems to detect contaminant releases
from waste management units. To evaluate these systems and determine the
current compliance status, the Administrator of the Environmental Protection
Agency (EPA) established a Hazardous Waste Ground-Water Task Force (Task
Force). The Task Fov"-e comprises personnel from EPA Office of Solid Waste
and Emergency Response (OSWER), National Enforcement Investigations Center
(NEIC), Regional Offices and State regulatory agencies. The Task Force is
conducting in-depth, onsite investigations of commercial TSDFs with the
following objectives:
Determine compliance with interim status ground-water monitoring
requirements of 40 CFR Part 265, as promulgated under RCRA or the
State equivalent (where the State has received RCRA authorization)
Evaluate the ground-water monitoring program described in the
RCRA Part B permit application, submitted by the facility, for
compliance with 40 CFR Part 270.14(c)
Determine if the ground water at the facility contains hazardous
waste constituents
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)**
* Regulations promulgated under RCRA address hazardous waste management
facility operations, including ground-water monitoring, to ensure that
hazardous waste constituents are not released to the environment.
** EPA policy, stated in Way 6, 1985 memorandum from Jack McGraw on "Pro-
cedures for Planning and Implementing Off-site Response," requires
that TSDFs receiving CERCLA waste be in compliance with applicable
RCRA ground-water monitoring requirements,
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To address these objectives, this Task Force evaluation will determine
if:
The facility has developed and is following an adequate ground-
water sampling and analysis plan
Designated RCRA and State-required monitoring wells are properly
located and constructed
Required analyses have been properly conducted on samples from
the designated RCRA monitoring wells
The ground-water quality assessment program outline (or plan, as
appropriate) is adequate
The first TSD facility the Task Force inspected in EPA Region VI was
the Rollins Environmental Services (RES), Deer Park, Texas site located in
the Houston, Texas metropolitan area about 2 miles south of the Houston
Ship Channel [Figure 1]. The onsite inspection was coordinated by personnel
from NEIC, a field component of the Office of Enforcement and Compliance
Monitoring. *
On September 16, 1985, the Texas Water Commission (TWC) notified Rollins
that ground-water monitoring data from the facility indicated a "substantial
likelihood" that waste constituents had entered the uppermost aquifer. As.
a result, the facility was required to initiate an assessment monitoring
program.
Technically, the facility was in assessment during the Task Force
inspection, which was conducted from September 24 through October 4, 1985.
During the inspection, Rollins personnel were working closely with TWC per-
sonnel to develop details of an assessment program plan. Because the pro-
gram plan was still being developed, the interim status program was evaluated
by Task Force personnel for compliance with State requirements. The evalua-
tion involved a review of State, Federal and facility records; facility and
laboratory inspections and ground-water and landfill leachate sampling and
analysis.
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Location Map
Rollins Deer Park Facility
Figure 1
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The area of land surrounding the current RES waste management site was
undeveloped coastal plain prior to purchase by RES in 1970. The area has
subsequently been developed into an industrial iDark with many large petro-
chemical facilities, several of whom are RES customers. This area has no
residential population and is several miles from downtown Deer Park.
In 1970, Rollins Properties, Inc., a subsidiary of Rollins Interna-
tional, Inc., purchased a 200-acre tract, which includes the land the present
facility occupies, for several other subsidiaries including Rollins-Purle,
Inc. In 1972, Rol1ins-Purle, Inc. changed its name to Rollins Environmental
Services, Inc., then, in 1978, to Rollins Environmental Services (TX), Inc.
to show the formation of a Texas subsidiary for hazardous waste management
activities.
Rollins-Purle began hazardous waste management activities at the Deer
Park site in June 1971. Initial operations included liquid waste stabili-
zaticfn (settling, cooling, neutralization) and thermal waste destruction
(incineration). Chemical and biological treatment and landfilling of waste
began by 1974. About 150 acres of the original 200-acre tract were sold in
1974 with 7 acres repurchased in 1975 and 30 acres repurchased in 1976.
The current site occupies these 87 acres.
The RES site has been regulated by State waste disposal regulations
since operations began. Currently, the site is operated pursuant to interim
status regulations promulgated under the Texas Administrative Code (TAC)
Section 335 rules. The State received RCRA Interim Authorization in Decem-
ber 1980 and Final Authorization in December 1984. RES currently operates
under the authority of a State permit (No. 01429) and as a Federal interim
status facility under EPA Identification Number TXD055141378. The Company
initially submitted a RCRA Part B permit application to EPA Region VI and
the TWC in August 1984; a revised Part B was submitted on November 20, 1984.
On September 20, 1985, TWC issued a 32-page notice of deficiency (NOD) con-
cerning the Part 8 permit application, which addressed many ground-water
i ssues.
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Waste management operations at this site are also regulated by waste
disposal, surface water discharge and air emissions permits. A State-issued
waste disposal permit (No. 01429) addresses waste management, ground-water
monitoring and effluent quality from two surface water discharges. An
NPDES* permit (No. TX0005941), issued by EPA Region VI, also regulates the
surface water discharges. Finally, a State air emissions permit (No. R-679)
establishes limits for the incinerator.
In addition to the State requirements and permits, which regulate poly-
chlorinated biphenyls (PCBs) as a Class I industrial solid waste, RES
manages PCBs and PCB waste pursuant to Federal regulations promulgated under
the Toxic Substances Control Act (TSCA, 40 CFR 761) and a PCB disposal
approval issued by EPA Region VI for incineration of PCBs.
NPDES refers to the EPA National Pollutant Discharge Elimination System
program administered under the Clean Water Act,
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SUMMARY OF FINDINGS AND CONCLUSIONS
The findings and conclusions presented in this report reflect conditions
existing at the facility in October 1985, Actions taken by the State, EPA
Region VI and RES subsequent to Octobe. are summarized in the accompanying
update.
Task Force personnel investigated the interim status ground-water moni-
toring program at the RES Deer Park facility for the period between Novem-
ber 1981, when applicable provisions of the rexas regulation became effec-
tive, and October 1985. There are no substantial differences between the
TAG and RCRA interim status requirements. The investigation revealed that
an interim status program was not implemented until May 1983 and, then, for
only half of the monitoring wells in the designated network. Although the
program has improved since 1983, some parts were inadequate and did not
fully comply with State requirements.
The ground-water monitoring program, proposed in the August 1984 RCRA
Part B permit application submitted by RES, was inadequate. Further expla-
nation was necessary for the selection of monitoring parameters, statistical
procedure used for evaluating the ground-water monitoring data, and how the
proposed monitoring well network would satisfy the regulatory requirements.
Revised monitoring program proposals were submitted in November 1984 and
April 1985. The April revision was improved over the previous submittals;,
but was still inadequate regarding the number, location and depths of wells
in the monitoring network; sample collection and analysis procedures; and
the statistical test to be used in evaluating the monitoring data.
The analytical data for samples collected by Rollins, EPA and the Task
Force indicate ground-water contamination by hazardous waste constituents.
During the Task Force inspection, 9 of the 25 wells in service either
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contained organic compounds identified in landfill leachate or had elevated
(i.e., greater than 100 pg/£)* TOX concentrations.
Under current EPA policy, if an offsite TSDF is used for land disposal
of waste from a CERCLA site, that site must be in compliance with the appli-
cable technical requirements of RCRA. As of October 1985, some parts of
the ground-water monitoring program were inadequate and did not fully comply
with State requirements.
Additional findings and conclusions, specific to selected ground-water
monitoring program requirements, are summarized below.
GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS
As of October 1985, the RES Deer Park facility did not have an adequate
interim status ground-water monitoring program. Program components, includ-
ing the ground-water sampling and analysis plan, monitoring well network,
sample analysis procedures and the assessment program outline, did not comply
with TAG requirements.
Rollins did not implement a ground-water monitoring program pursuant
to the TAG interim status requirements until May 1983. The State regula-
tions required that the program be implemented on November 19, 1981. The
1983 monitoring program included only 9 of the 18 existing wells in the
designated network. The other nine wells were monitored for the parameters
required by the TAG but not by the frequency specified for the first year
of monitoring (quarterly rather than semiannually).
On September 16, 1985, TWC notified RES that monitoring data indicated
a "substantial likelihood that hazardous waste or hazardous waste constit-
uents from the facility have entered the uppermost aquifer". As a result,
The TOX value of 100 ug/£, used as a benchmark far identifying elevated
concentrations, was based on a literature review, two data sets and
professional judgment.
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RES was required to submit a Ground Water Quality Assessment Plan within 15
days. TWC and RES personnel were developing the assessment program plan
during the Task Force inspection. Because the assessment program was not
completed or implemented until after the Task Force inspection, it is not
discu^ied in this report.
The adequacy of the interim status program in meeting regulatory
requirements at the time of the Task Force inspection is summarized below
and discussed in detail in the Technical Report section. The adequacy of
the program before October 1985 is also addressed in the Technical Report
section.
Ground-Water Sampling and Analysis Plan
Generally, the monitoring procedures described in the sampling and
analysis plan being followed during the inspection were adequate. However,
the plan did not comply with TAG requirements because it did not (1) incor-
porate ground-water monitoring requirements imposed by the State operating
permit for monitoring parameters and frequencies, (2) contain either a list
of monitoring wells or a sampling schedule, (3) present sufficient details;
for the procedures described and (4) specify analytical procedures for a
few of the required monitoring parameters.
A two-part regulatory framework controls the ground-water monitoring
program at the RES facility. These are the TAG regulations (Title 31, Sec-
tion 335, Subchapter I) and the State waste disposal permit (Part III, para-
graphs 4g and 5i) issued on September 3, 1981, both of which are administered
by the TWC. The permit specifies more frequent monitoring after the first
year and more analytical parameters during both the first and subsequent
years. The TAG (335.45) states that the regulations shall be followed except
where the permit contains additional or more stringent requirements, in
which case the permit requirements will be met. The ground-water monitoring
plan must, therefore, include the permit requirements, which it does not.
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The permit requires that the monitoring well network at the Rollins
facility include a minimum of 15 wells, The TAG specifies different moni-
toring requirements for the upgradient and downgradient wells during the
first year of monitoring. The monitoring plan is deficient because there
is no list of wells or a sampling schedule.
Some of the monitoring procedures described in the plan were incomplete.
For example, procedures for measuring depth to water and water level eleva-
tions and calculating purge volumes were not supplemented with key informa-
tion on well-head elevations and well depths. Procedures were described
for using the pumps in some of the wells (those equipped with bladder-type
pumps), but not for others (those equipped with electric submersible pumps).
Samples for some parameters, such as metals, are preserved by adding acid
until a specified pH is achieved; however, the monitoring plan does not
describe a procedure for determining when the proper pH has been reached.
Analytical procedures are specified in an appendix to the monitoring
plan pursuant to the TAG [335.193(a)(3)], Procedures for four monitoring
parameters required by the TAG (methoxychlor, radium, gross alpha and gross
beta) are not included.
Monitoring Well Network
The monitoring network included 25 wells during the Task Force inspec-
tion; however, 10 were to be replaced by November 7, 1985 in response to a
directive from the TWC on September 16. The TWC had determined that the 10
wells (MW-1 through 3 and 19 through 25) were unacceptable because they
were ". . .so completed as to allow cross-contamination of several saturated
strata." Task Force personnel agree with this determination. Construction
of the remaining 15 wells was found to be marginally adequate. Some wells
had excessive sand-pack lengths relative to the screen, no bentonite seals
between the sand pack and overlying grout, PVC casing and filter fabric
wrapped around the screen.
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The number and location of the 25 wells in the network were not
sufficient to immediately detect any statistically significant amounts of
hazardous waste constituents migrating to the uppermost aquifer from the
waste management units, as retired by the TAG [335.192(a)]. The well locai-
tions were not sufficient to immediately detect " aakage from all or major
portions of six surface impoundments subject to the ground-water monitoring
requi rements.
Sample Handling and Analysis Procedures
Laboratory records and data reviewed for samples collected from the
monitoring wells since 1981 revealed that inappropriate sample handling,
analysis and quality control procedures have been used. For example, the
procedures used for arsenic and selenium analyses did not follow the refer-
enced EPA method. Some of the data generated during the first year for
metals of interim status monitoring are not adequate to establish background
concentrations or values, as required by the TAG.[335.193(c)].
Samples for metals and total organic carbon (TOG) analysis were fil-
tered before concentrations were determined, Filtering of samples for TOC
analysis yields data representing dissolved rather than the total organic
carbon concentrations required by the TAG [335.193(b)(3)(C)]. Dissolved
organic carbon data are not adequate for establishing background concentra-
tions. Data from analysis of filtered samples may be biased low. The
effects of filtering ground-water samples from the RES facility need to be
documented and evaluated.
The analytical method used for TOC is appropriate only when the inor-
ganic carbon is a small part of the total carbon present, which was not the
case in ground-water samples from wells at the Rollins facility. Conse-
quently, TOC concentrations of less than 5,000 ug/£ are considered unre-
liable. In July 1985, the method was changed to include acidifying the
sample and purging it with nitrogen gas before measuring the carbon present
The purging results in loss of volatile carbon compounds and the method
yields results only for the nonpurgeable carbon content, which does not
satisfy the TAG requirements for total organic carbon.
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11
Inappropriate methods were also used for arsenic, selenium, cadmium,
chromium and lead. Samples for arsenic and selenium determinations were
not digested before analysis, as required by the referenced EPA methods
used. The methods used for cadmium, chromium and lead (flame atomic absorp-
tion sp^ctroscopy), which are used as indicators for drinking water suita-
bility, do not achieve reliable results near the drinking water limits for
these parameters; furnace atomic absorption spectroscopy is more appropriate.
The variation in total organic halogen (TOX) concentrations, where
quadruplicate measurements were made by Rollins during the first year of
monitoring, indicates that values below about 50 ug/£ are unreliable. Also,
the instrument used for TOX analyses produces data that are biased low.
Insufficient quality control measures were taken to assure that analy-
tical results for pesticides and herbicides were reliable. No analyses
have been performed on duplicates or matrix spikes; sample blanks have only
been analyzed since 1984.
Assessment Program Outline
An outline for a ground-water quality assessment program was required
[335.194(a)] by November 19, 1981. Rollins prepared an initial outline in
November 1982 in response to a notice of deficiency from TWC. A revised
outline, which was completed during mid-1985 and was on file during the
Task Force inspection, was updated over the initial version but needs fur-
ther improvement.
The TAG requires that the outline describe a more comprehensive program
than the one for routine interim status monitoring and be capable of deter-
mi ni ng:
Whether hazardous waste or hazardous waste constituents have
entered the ground water
The rate and extent of migration of hazardous waste or hazardous
waste constituents in the ground water
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The concentrations of hazardous waste or hazardous waste constit-
uents in the ground water
The monitoring parameters listed in the outline are not sufficiently
comprehensive for the hazardous waste constituents potentially present in
ground water. Lie one set of samples indicated is not adequate to determine
if leakage is occurring. Multiple samples are necessary. The outline does
not indicate how a monitoring plan would be developed nor does it propose
schedules for sampling, data evaluation or report preparation.
GROUND-WATER MONITORING PROGRAM PROPOSED FOR FINAL PERMIT
A revised Part B ground-water sampling and analysis plan, dated April 9,
1985, was submitted to the TWC. The State, in a letter dated September 27,
1985, outlined three major deficiencies in the April plan. First, the letter
noted an inadequate number of monitoring wells (well clusters were recom-
mended) and suggested dividing the facility into two waste management areas.
Second, an alternate statistical test was proposed by Rollins for evaluating
monitoring data; however, the Company did not provide a demonstration indi-
cating that the Student's t-test was not applicable to the RES data, as
required by the TAG. Third, no justification was presented for the proposec
location of the point of compliance, which was defined as a line through
the locations of the proposed monitoring well is.
In addition to the deficiencies noted by the TWC, Task Force personnel
determined that the Company definition of uppermost aquifer does not corre-
spond to that in the TAC [335.42(a)]. Wells designated by RES to be moni-
tored in accordance with the regulatory requirements are only completed in
the water bearing zone designated by RES as the uppermost aquifer.* Because
shallower saturated units are part of the uppermost aquifer, as defined by
the TAC, the proposed well network does not comply with TAC requirements.
Further, the proposed plan indicates that data from samples from three
A "continuous" permeable water-bearing unit occurring at a depth of
about 50 to 70 feet,
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13
shallow wells will not be subject to the required statistical comparisons;
provisions for such exceptions are indicated in the Texas regulations,
no
Some of the existing well1- are to be abandoned and replacements con-
structed. Descriptions of procedures for abandonment and construction are
incomplete. Two of the proposed downgradient monitoring well locations
(MW-45 and 46) do not comply with TAG requirements because they are 300
feet from the point of compliance, as defined by the State regulations
[335.461].
Sample collection and analysis procedures were incomplete and do not
comply with TAG requirements. The plan submitted for the Part B containing
these procedures was subsequently revised into a document that was being
used for the interim status program, which was evaluated in the previous
section. The procedures in the monitoring plan for the interim status pro-
gram are the de facto replacements for those in the Part B proposal. The
proposal has not been formally revised and submitted to the TV/C because the
facility is in assessment and preparation of a revised plan is pending the
outcome of that program.
TASK FORCE SAMPLING AND MONITORING DATA EVALUATION
During the inspection, Task Force personnel collected samples from 14
ground-water monitoring wells and 4 leachate collection sumps to determine
if the ground water contains hazardous waste constituents or other indica-
tors of contamination. Samples were drawn from some wells by RES personnel,
using their standard procedures, while others were drawn by an EPA contrac-
tor. Monitoring data from the Task Force samples were evaluated together
with previous Rollins and EPA data from the monitoring wells.
Analytical data for Task Force samples from five monitoring wells
(MW-2, 6, 13, 25 and 26) indicate the presence of organic hazardous waste
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14
constituents in ground water beneath the site.* Four of the wells (MW-6,
13, 26 and 35) containing organic compounds are adjacent to the operating
landfill; one (MW-2) is adjacent to a surface impoundment used for receiv-
ing incoming loads of wastewater and one (MW-25) is adjacent to a disposal
area for sludge dredged from impoundments used for treating : jrubber water.
Although previous data for organic analysis of samples from RES is
limited, organic compounds were detected in samples from five other wells
(MW-3, 8, 12, 15 and 18) by EPA and Rollins during 1980 and 1981. Well
MW-3 is adjacent to an old landfill (LF-17) and the other wells are adjacent
to the current landfill, "ills MW-8 and 12 are adjacent to wells MW-7 and
13, respectively, in which hazardous waste constituents were detected in
Task Force samples,
Elevated barium concentrations were also measured in the sample from
well MW-2. The concentration was nearly twice the next lower concentration
measured in other samples. Data from samples collected by EPA in 1981 and
Rollins in 1984 confirm this finding.
Monitoring data also indicate elevated (;.e., greater than 100
total organic halogen concentrations in 14 wells, as follows.
MW-1
MW-2
MW-6
MW-7
MW-8
MW-9
MW-10
MW-13
MW-14
MW-16
MW-17
MW-25
KW-26
MW-38
These include the five where hazardous waste constituents were detected and
five (MW-9, 10, 14, 16 and 17) that were abandoned during 1982 and 1983.
One (MW-2) is adjacent to an impoundment; one (MW-25) is next to a sludge
pond; and the remainder are (or were) adjacent to the operating landfill.
The organic compounds were identified as waste constituents because
they were detected in leachate samples. Appendix F in the Technical
Report section contains all analytical results for Task Force samples,
-------
15
Some wells, from which samples have been collected for several years, had
significant changes in TOX concentrations. Levels increased in three wells
(MW-1, 26 and 38) during 1985 while those in two wells (MW-8 and 7) decreased.
The increases suggest the arrival of a "plume", whereas the decreases suggest
improving ground-water quality.
The specific halogenated compounds have not all been identified because
the standard analytical methods used by EPA, Rollins and Task Force labora-
tories were not sensitive to them; special or research-type methods are
required. These compounds, and their sources, need to be identified.
-------
TECHNICAL REPORT
-------
-------
16
INVESTIGATION METHODS
Th? Task Force evaluation of RES consisted of:
Review and evaluation of records and documents from EPA Region
VI, TWC and RES
Facility onsite inspection conducted September 24 through October 4,
1985
Onsite and offsite analytical laboratory evaluations
Sampling and sMt">sequent analysis and data evaluation for selected
site ground-water and leachate monitoring systems
RECORDS/DOCUMENTS REVIEW
Records and documents from the TWC and EPA Region VI offices, compiled
by an EPA contractor, were reviewed prior to the onsite inspection. Addi-
tional TWC records were copied and reviewed by Task Force personnel con-
currently with the onsite inspection. Facility records were reviewed to
verify information currently in Government files and supplement Government
information where necessary. Selected documents requiring in-depth evalua-
tion were copied by the Task Force duri.ng the inspection. Records were
reviewed to obtain information on facility operations, construction of waste
management units and ground-water monitoring activities.
Specific documents and rescords 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
1ocations.
-------
17
FACILITY INSPECTION
The facility inspection, conducted from September through October 1985,
included identifying waste management units (past and present), waste man-
agement operations and pollution cont ol practices, and verifying the loca-
tion of ground-water monitoring wells and leacnate collection sumps.
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) the
ground-water monitoring system, (&-^ the ground-water sampling and analysis
plan, and (5) laboratory procedures for obtaining data on ground-water qua"i:y.
Because ground-water samples were analyzed by an offsite contractor labora-
tory, personnel from these facilities were also interviewed regarding sample
handling, analysis and document control,
LABORATORY EVALUATION
The RES and contractor laboratories, which analyze the ground-water
samples, were evaluated regarding their respective responsibilities under
the RES 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 AND LEACHATE SAMPLING AND ANALYSES
During the inspection, Task Force personnel collected samples for
analysis from 14 ground-water monitoring wells and 4 leachate collection
sumps [Tables 1 and 2, Figure 2] to determine if the ground water contains
hazardous waste constituents or other indicators of contamination. Further,
the sampling results were used in evaluating orevious Company data. Wells
were selected for sampling principally in areas where records show or suggest
that ground-water quality may have been affected by hazardous waste management
-------
18
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22
activities. Other wells were selected to confirm background ground-water
quality, The leachate sumps were selected based on whether sufficient
liquid was present for the samples. Duplicate volatile organic samples and
splits of all other samples were provided to RES personnel,
The monitoring wells were sampled according to one of two protocols
depending on whether the well was equipped with a dedicated pump. Sampled
wells equipped with dedicated pumps included MW-2, 3, 6, 7, 8, 11, 12 and
® ®
13, Each well had a Well Wizard Purge Master purge pump and a Well Wizard
sampling pump, which were operated by RES personnel. Samples were collected
from these wells by the following procedure. Additional details of RES
sampling procedures are described in the section on Ground-Water Monitoring
Program During Interim Status.
1. Company personnel determined depth to ground- water using a Powers
Well Sounder .
2. Company personnel calculated height of water column from depth to
water measurement and well depth (from construction records).
3. Company personnel determined the water column volume, using height
of water column and a graph containing a plot of volumes and
heights for 4 and 2-inch diameter wells.
4. Company personnel purged three water column volumes (due to slow
recovery rates in some wells, the purge period was protracted).*
5. After recharge, EPA contractor monitored open well head for chem-
ical vapors (HNU and/or a Foxboro^ organic vapor analyzer - OVA)
and radiation.
6, EPA contractor collected sample aliquot and made field measure-
ments (water temperature, pH, specific conductance).
7. EPA contractor filled sample containers in the order shown in
Table 3, alternating between filling a sample aliquot for the
Company and one for the EPA contract laboratory. When NEIC samples
were collected, the above protocol was modified to include filling
a sample aliquot for NEIC after filling one for the EPA contractor.
® Well Wizard Purge Master, Well Wizard, Powers Well Sounder, HNU, Fox-
boro and OVA are registered trademarks and appear hereafter without
the ®.
* Purge water from all wells was captured in metal drums and later dis-
charged into the onsite wastewater treatment facility.
-------
23
Table 3
PREFERRED ORDER OF SAMPLE COLLECTION,
BOTTLE TYPE AND PRESERVATIVE LIST
Parameter
Bottle
Preservative
1. Volatile organic analysis (VOA)
Purge and trap
Direct inject
2. Purgable organic carbon (POC)
3. Purgable organic halogens (POX)
4. Extractable organics
5, Total metals
6, Dissolved metals
7. Total organic carbon (TOC)
8. Total organic halogens (TOX)
9, Phenols
10. Cyanide
11. Sulfate/chloride
12. Nitrate/ammonia
13. Radionuclides (NEIC only)
2 60-ni£ VOA vials
2 60-nUl VOA vials
1 60-mui VOA vial
1 60-m£ VOA vial
4 1-qt. amber glass
1-qt. plastic
1-qt. plastic
4-oz, glass
1-qt. amber glass
1-qt. amber glass
1-qt. plastic
1-qt. plastic
1-qt. plastic
4 1-qt. amber glass
HN03
HN03
H2S04
H2S04
NaOH
H2S04
-------
24
8. Samples were placed on ice in an insulated container.
Wells not equipped with dedicated pumps during sample collection
included MW-21, 23, 24 and 25.* At these wells, an EPA contractor instal-
led a submersible bladder-type pump, purged the wells and collected samples
by the following procedures:
1. EPA contractor monitored open well head for chemical vapors (HNU
and/or OVA) and radiation,
2, EPA contractor determined depth ±o ground water using an Oil
Recovery Systems' Interface Probe water level meter.**
3, EPA contractor calculated height of water column from depth to
water measurement and well depth.***
4. EPA contractor calculated water column volume, using height of
water column and well casing radius.
5, EPA contractor installed a clean Timco bladder-type pump and
purged three water column volumes. The pump was operated using
compressed air.
6. After recharge, EPA contractor collected sample aliquot and made
field measurements (water temperature, pH, specific conductance).
7. EPA contractor filled sample containers in the order shown in
Table 3 alternating between filling a sample aliquot for the Com-
pany and one for the EPA contract laboratory.
8. Samples were placed on ice in an insulated container.
* These wells were previously equipped with dedicated pumps, which were
removed at the beginning of the Task Force inspection to enable use of
the interface probe.
** After measuring depth to water, while the tape and sensor were being
rewound onto the interface probe reel, they were cleaned with a hexane-
soaked laboratory wipe, then a distilled water-soaked wipe and finally
a dry wipe.
*** Wells having depths of less than 100 feet were measured with the inter-
face probe; those with depth greater than 100 feet were measured with
a weighted steel tape.
® Oil Recovery Systems' Interface Probe and Timco are registered trade-
marks and appear hereafter without the ®,
-------
25
Volatile organic samples at MW-6 were first poured into a 250-m£ beaker
then poured into 60-m£ vials (sample containers) due to difficulties in
controlling the pump flow rate. Other sample containers were filled direct!"
from the discharge line. At other we1Is, all sample containers were filled
directly from the sample pump discharge line.
After sampling was completed at a well, EPA contractor personnel took
their samples to a staging area where a turbidity measurement was taken and
one of two sample aliquots for metals analysis was filtered. In addition,
metals, TOC, phenols, cyanide, nitrate and ammonia samples were preserved
[Table 3],
Leachate was collected at sumps below the operating landfill in the
southern part of the facility. All leachate samples were collected on the!
same day to prevent possible cross-contamination of well samples. EPA con-
tractor personnel directly involved in the sampling wore full-face respira-
tors and protective clothing. The EPA contractor collected composite
samples in 5-gallon and/or 24-gallon glass jugs. Containers (provided by
the EPA contractor) for the Company, EPA and State (LC-3, 7) samples were
then filled from the jugs on a concrete slab on the south side of the RES
laboratory, with the VGA samples first being poured into a 2SO-m£ beaker
then into 60-m£ vials. Leachate samples were not preserved.
At the end of each day, samples were packaged and shipped to the two
EPA contract laboratories according to applicable Department of Transpor-
tation (DOT) regulations (40 CFR Parts 171-177). Samples from monitoring
wells were considered "environmental" and those from leachate collection
system sumps were considered "hazardous" for shipping purposes.
Each day of sampling, the EPA contractor prepared field blanks for
each analytical parameter group (e.g., volatiles, organics, metals) in a
parking lot southeast of the RES laboratory by pouring distilled deionized
water into sample containers. An equipment blank was prepared by running
distilled deionized water through the apparatus used to filter metals. An
additional equipment blank was prepared by running distilled deionized water
-------
26
through the new Well Wizard Purge Master and sampling pumps installed at
MW-2. One set of trip blanks for each parameter group was also prepared
and submitted during the inspection. The blanks were submitted with no
distinguishing labeling or markings.
Samples were analyzed by the EPA contractor laboratories for the param-
eter groups shown on Table 3 minus the groups indicated on Tables 1 and 2.
NEIC received and analyzed split samples for two ground-water monitoring
we!Is (MW-2 and MW-35),
-------
27
WASTE MANAGEMENT UNITS AND FACILITY OPERATIONS
WASTE MANAGEMENT UNITS
The RES facility handles both hazardous -waste, as defined in the Texas
Administrative Code Section 335 rules and regulated by the Texas Water Com-
mission, and polychlorinated biphenyl (PCB) waste, as defined in 40 CFR 761
and regulated by Texas (under TAC 335 rules) and EPA. Waste handling units
and operations were identified to determine where waste constituents han-
dled at RES might enter the ground water.
As of October 1985, RES reportedly used tne following management units/
areas for the treatment, storage and/or disposal of hazardous waste:
19 surface impoundments - storage and treatment*
I landfills - disposal
41 tanks - storage and treatment
3 drum storage areas - container storage
1 incinerator - thermal destruction
Past operations included filter beds for aerobic and anaerobic Diolog-
ical digestion of waste, other surface impoundments, landfill cells, tanks
and drum storage areas. As a result, most of the RES facility has been
used for management of hazardous waste.
PCB waste processing and disposal operations include storage, proces-
sing for disposal (transformer draining and flushing) and incineration of
PCB liquids. PCB solids (transformer carcasses, contaminated debris, etc.)
are disposed of offsite.
Figure 3 shows the location of all known RES treatment, storage and
disposal facilities. A discussion of waste management units related to
Includes three "rainwater" lagoons
-------
U)
"E
-------
29
ground-water monitoring at the RES site follows. This discussion is divided
into two major areas: (1) units subject to RCRA/TAC interim status require-
ments and (2) units operated and closed prior to RCRA/TAC interim status
regulations but which may have released contamination to the ground water.
Interim Status Regulated Waste Management Units
Surface Impoundments
Surface impoundments are used at the site for hazardous waste treat-
ment and storage [Figure 4]. RES has a total surface impoundment storage
capacity of about 21 million gallons; surface impoundment treatment capa-
city is about 6 million gallons,* The 24 surface impoundments described in
Table 4 and discussed below are subject to the ground-water monitoring
requirements of the RCRA/TAC interim status.
Most surface impoundments at RES were similarly constructed. The RES
site is underlain by clay into which shallow (up to about 20 feet deep)
lagoons were excavated. The natural clay was compacted with a sheepsfoot
_ ?
roller to achieve a permeability of 10 cm/second for the impoundments.
Clay dikes and the natural drainage were used to control runon/runoff from
the impoundments. When impoundments were cleaned or closed, waste sludge
was excavated until "clean" clay was observed. Thus, impoundments that
were cleaned tended to grow in depth if additional natural clay was not
brought in and recompacted.
According to a 1981 Ecology and Environment, Inc. report, the depth to
ground water is 10 feet and, during the Task Force inspection, similar results
were recorded with depth to ground water ranging from 8 to 22 feet.1 Because
water levels in the impoundments were maintained above the level of
As reported in RES' November 20, 1984 RCRA Part B application revision,
Section III, E.l.l.a,, pages 6 and 704
-------
3D
Figure 4
Waate Water l»»ut
Op«ratlBi L»n4fill Input
-H 1--1001 H-
L-1000
rr^i i
Water Welle
til
LJ
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lncin€r«tot
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F-4 K«cyc)c
R-J ^~
Feedback
> r
O»tfal!
F-2
F-3
H._I
-4
Outfall 001
R-1,1,3 RatBwacer HoI4i*i Lafoona
L-10*«,1001 Waate Water HoUIni Lajooa.
L-ll.32,33 Caeaileal Treataeat Lafoena
L-J Eeoaliiatlon Baaia
L-lt AeratloB Lafo«B
ASS Activated Slitejfle Baain
L-1 ,»• 1.1,3,4 iBclaerater, Scrubber Dlac»*r|e
1 7-a«r«
Orainaf«
Section
Schematic of Waste Water Flow Through Management Units
Rollins Deer Park Facility
-------
31
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32
the water table, an outward hydraulic gradient exists(ed) at these units.
This gradient would promote release of hazardous waste constituents to
ground water.
Lagoons L-10QO and L-1001
Lagoons L-1000 and L-1001 are surface impoundments most recently used
for storage and pretreatment of landfill leachate from the RES facility.
Both lagoons were out of service during the Task, Force inspection and RES.
plans to excavate these units during future landfill expansion. When con-
structed in 1972 and 1974, respectively, the lagoons were used as holding
lagoons for incoming loads of wastewater prior to chemical and biological
treatment.
A wide variety of wastes have been received in these surface impound-
ments and RES plans to analyze underlying so'ils for heavy metals, cyanides
and priority pollutants when these units are excavated. Wastes placed in
L-1000 and L-1001 after November 1980 (effective date of RCRA regulations)
have primarily been landfill leachate for metals precipitation, wastewate^s
received for biological treatment and wastewaters with heavy metals. L-100D
and L-1001 are considered primary treatment or, as needed, storage lagoons
and receive wastes with high concentrations of heavy metals. Table 5 sum-
marizes the historical use of these lagoons. Table 6 lists types of waste-
waters RES has historically accepted for chemical and biological treatment.
With L-1000 and L-1001 out of service, wastewater now goes directly to the
chemical and biological treatment units or to holding/treatment lagoons
within the landfill.
To prevent runon, lagoons L-1000 and L-1001 were constructed by exca-
vating 10 and 20 feet below grade, respectively, and building partial dikes
5 feet above grade.
-------
33
1979
1980
1982
1983
Table 5
CHRONOLOGY OF USE OF SURFACE IMPOUNDMENTS
L-1000 AND L-1001
Year
1972
1974
1975
1977
Impoundment
L-1000 L-1001
X
X
X
X
X
Use
Rainwater and wastewater storage
Wastewater storage
Aeration of wastewater
Storage of neutralized
supernatant
X
X
X
X
from treated wastewater (metals
precipitated) pumped from LF-6 and
LF-9
Storage of treated contaminated
water (heavy metals precipitated)
from landfill L-20
Contaminated water from landfill
pumped from L-21 for chemical
treatment in L-1000 and L-1001
Emptied/siudges landfi1 led/1iners
repaired (sand lenses removed)
Leachate pumped from landfill for
chemical precipitation of metals
in L-1000 and L-1001
1985
Emptied/sludges landfilled
-------
Table 6
WASTE MATERIALS TREATED AND/OR STORED
IN RES TREATMENT IMPOUNDMENTS
(L-1QQO, 1001, 31, 32, 33, 2, 12 and ASB)
Treatment
Waste Type
Waste Materials Treated
Chemical
Acids
Alkalies
Other
Biological
Pickle liquors (sulfuric, hydrochloric,
nitric, phosphoric, hydrofluoric acids and
mixtures of these with various dissolved
metals)
Chromic acid and sulfuric acid - dichromate
mixtures
Ferric and cupric chloride
Lab COD wastes
Caustic soda
Sodium sulfide - sodium hydrogen sulfide
mixtures
Cyanide plating wastes
Latex suspensions
Soda ash
Metal salts solutions
Oil-water emulsions
Mixed acrylate emulsions
Metallic oxides, halides, nitrates,
phosphates
Spent welding flux
Calcium sulfate, sludge
Organic acids and selected alcohols
Ammonia, phosphate - containing salt
solutions
Secondary sewage sludge
Aqueous truck washings
-------
35
Lagoons L-31, 32 and 33
Lagoons L-31, 32 and 33 are surface impoundments used for chemical
treatment of waste generated both on and offsite at the RES facility, L-31
and 32 are considered secondary treatment lagoons (L-1000 and L-1001 pre-
viously being primary treatment lagoons) and L-33 is considered a final
treatment lagoon. Landfill leachate, contaminated stormwater from R-l, 2
and 3 and wastewaters with moderate concentrations of heavy metals are
treated with an alum and lime slurry to precipitate metals. Aerators are
occasionally used in L-33 before treated wastew,-*°rs are pumped to L-2 or
L-12.
When constructed in 1980, L-31, 32 and 33 replaced lagoon L-3 (dis-
cussed in section on Non-Interim Status Regulated Waste Management Units).
After L-3 was emptied, sludges and contaminated soil were removed. Natural
clay from the RES site was used to construct three smaller lagoons in the
excavation. Lagoons L-31, 32 and 33 extend approximately 12 feet below
grade with runon prevention dikes approximately 4^ feet above grade.
Lagoons L-2 and L-12
Lagoons L-2 and L-12 are surface impoundments used for flow equaliza-
tion and aeration of wastewater prior to biological treatment in the acti-
vated sludge basin (ASB). Lagoon L-2 receives wastewater from L-33 and on
and offsite wastewater with low concentrations of heavy metals for flow
equalization and, occasionally, aeration. From L-2 wastewater goes to L-12,
where it is aerated.
After construction in 1971, L-2 was used as a filter bed (aerobic/ an
aerobic biological digestion) and L-12 and L-13 were used as neutralization
basins for storage and neutralization for contaminated sulfuric acid. By
1975, the filter bed had been removed from L-2, and L-13 and L-12 had been
combined by removing the dike separating the two impoundments. The result-
ing single impoundment was designated as L-12. Since then, L-2 has been
used primarily for equalization and L-12 primarily for aeration.
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36
Lagoons L-2 and L-12 were constructed by excavating 9 and 10 feet belov
grade, respectively, and building runon prevention dikes of 0 to 9 and 10
to 15 feet above grade, respectively.
Lagoon ASB
Lagoon ASB (activated sludge basin) is a surface impoundment used for
biological treatment of wastewater. Lagoon ASB receives pretreated and
pre-aerated wastewater from L-12. After activated sludge treatment in the
ASB, effluent is used for makeup water for the incinerator -^rubber.
Lagoon ASB was constructed by excavating 9 feet below grade and build-
ing runon prevention dikes 5 to 11 feet above grade. A ^-inch Gulf Seal
(tar and asphalt) liner was installed over compacted natural clay.
Lagoons' L-l, F-l, F-2, F-3 and F-4
Lagoons L-l and F-l, 2, 3 and 4 are surface impoundments operated in
series and used for settling and cooling of incinerator scrubber water.
Prior to 1976, the scrubber water effluent was from a spray tower which
used aqueous caustic soda to treat incinerator gases. In 1976, RES switched
from a caustic scrubber to a lime scrubber. The lime sludge (CaS04) and
CaOH) settles out primarily in F-l and F-2. The lime sludge is pumped/
dredged from the F-series lagoons to spoils areas where it is mixed with
cement kiln flue dust prior to landfilling. The F-series lagoons are also
used for final pH adjustment, cooling and flow equalization.
In 1970, three lagoons (L-l, an intermediate stabilization basin and «,
final stabilization basin) were constructed to treat incinerator scrubber
waste. By 1974, the final stabilization basin had been converted to a
series of four lagoons (F-l, 2, 3 and 4) to improve retention time. By
1977, the intermediate stabilization basin was taken out of service for
Gulf Seal is a registered trademark and appears hereafter without ®.
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37
treatment of incinerator scrubber water and had been divided into two
impoundments, L-5 for firewater storage and R-2 for rainwater collection.
A scrubber water canal was constructed to move incinerator scrubber water
from L-l to 7-1.
L-l is a small basin 2 to 4 feet deep with a natural clay liner, F-l,
2, 3 and 4 are 7, 7, 6 and 8 feet deep, respectively, Runon prevention
dikes vary from 0 to 3 feet above grade,
Unnumbered Sludge Ponds
Three unnumbered sludge ponds or dredged spoils areas are surface
impoundments used for drying/storage of calcium sludges removed from lagoons
F-l and F-2. The calcium sludges result from the neutralizing of incinerator
gases in the lime scrubber, The sludge ponds are interconnected and are
designed to drain to lagoon F-2, These ponds cover about 3 acres and have
been- in use since 1976 when RES switched from caustic to lime scrubbing for
the incinerator. Dried sludge is mixed with cement kiln flue dust and
landfilled.
The dredged spoils area is about 8 "feet above the water level in the
F-series lagoons and was formed by compacting the natural clay and building
dikes to control drainage.
Lagoons R-l, R-2 and R-3
Lagoons R-l, 2 and 3 are surface impoundments operated in series and
used for rainwater collection. Collected rainwater is sampled for total
organic carbon (TOC) prior to discharge. If the TOC level is less than
55 mg/SL, the rainwater is discharged from R-3 through NPDES Outfall 002 to
Tucker Bayou or used for incinerator scrubber makeup water, If the TOC
level is greater than 55 mg/£ in R-3, the water is pumped to lagoon L~2,
L-12 or ASB for treatment.
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38
R-l, 2 and 3 were constructed in 1976 with R-2 constructed by
partitioning part of L-5, the intermediate stabilization basin. Prior to
pattitioning, L-5 was used as part of the incinerator scrubber water cooling
and settling system. 1ne new lagoons were excavated to depths of 10, 7 and
8 feet, respectively (for R-2, the excavation was already in place). Dikes
and natural grade are used for runon diversion,
Lagoon L-5
Lagoon L-5 is a surface impoundment used for storage of firewater.
Prior to 1977, lagoon L-5 was an intermediate stabilization basin for
incinerator scrubber water. In 1976, lagoon L-5 was partitioned into two
lagoons, R-2 and L-5. Since 1977, water stored in lagoon L-5 included well
water and stormwater runoff. Stormwater runoff may contain hazardous waste
constituents from throughout the RES site.
Lagoon L-5 was constructed by excavating 6 to 8 feet below grade and
compacting the bottom and sides. Clay excavated onsite was used for the
dike to partition L-5 in 1976. Natural drainage was used to prevent runon.
Lagoon L-14
Lagoon L-14 is a surface impoundment originally used as a sludge
receiving/settling basin and currently used as a lagoon to receive truck
wash wastes. From 1971 to 1976, lagoon L-14 was originally two lagoons,
L-14 and L-15. Sludge from tanks T-43 and T-44 was placed in L-14 until
these tanks were removed in 1985. These tanks were chemical treatment tanks
for neutralization and settling of wastewater.
Lagoons L-14 and L-15 were constructed in 1971 and combined by remov-
ing the dike between them in 1976. Construction consisted of excavation to
a depth of 7 feet below grade and compacting the natural clay by sheepsfoot.
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39
Lagoons L-16, L-20 and L~21
Lagoons L-16, 20 and 21 were surface impoundments that were closed in
1981, although RES claims these are pre-RCRA units. Lagoon L-16 was con-
structed in 1971 and was used for firewater storage during the 1970s. Water
stored in this lagoon included well water and rainwater which may have con-
tained hazardous waste constituents. After L-5 was converted to a firewater
lagoon in 1976, L-16 continued to be used as a storage lagoon and received
accumulated fluids from the tank farm and drum storage pad sumps. This
fluid often had a high COD. In 1981, L-16 was converted to a truck parking
lot. The empty impoundment was filled with clay excavated onsite, which
was compacted and covered with a geomembrane to aid drainage. The geomem-
brane was covered with clay and gravel for truck parking.
Lagoons L-20 and 21 were constructed in 1978 and 1979, respectively.
These lagoons were used primarily for storage of runoff and landfill leachate
from the moving face landfill. The water was pumped to L-1000 and L-1001
for pretreatment prior to chemical and biotreatment. In 1981, these lagoons
were dewatered by pumping the water to the chemical/biotreatment system.
Remaining sludge was landfilled after being mixed with cement kiln flue
dust. The empty impoundments were then incorporated into the moving face
landfil1.
Drawings are not available to provide construction detai"!s of lagoons
L-16, 20 and 21. Reportedly, construction was similar to other lagoons
with excavation in natural clay and compaction by sheepsfoot.
Landfzll Rainwater Collection Basin
The rainwater collection basin is a surface impoundment in the present
moving face landfill (see description below). Because the landfill has a
leachate collection system and transverse berms are used to separate clean
and contaminated areas, RES has not listed the rainwater collection basin
as a RCRA-regulated unit. RES contends only rainwater is collected in this
basin. If analytical testing for hazardous waste constituents is negative,
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40
stormwater is discharged without treatment through NPDES Outfall 002. If
hazardous waste constituents are found, the stormwater is pumped to the
chemical treatment system,
Landfill
The landfill at the RES site (designated as LF-19) is used for the
burial of hazardous waste. RES has applied (RCRA Part B application) to
increase its permitted landfill capacity from 730,000 cubic yards to
6,300,000 cubic yards. Some 14 discrete landfill cells of about 10,000
cubic yards each were filled and completed in the 1970s before RCRA regu-
lations became effective in November 1980, The current landfill is operated
under a "moving face" concept of disposal, where waste is covered and capped
as the landfill progresses. Thus, closure is an ongoing process and only a
small portion of the excavation has exposed waste and the potential for
contaminated rainwater is reduced. The moving face landfill (LF-19) is
subject to the interim status ground-water monitoring requirements of RCRA,
Landfill LF-19
Landfill LF-19 is located on the southern half of the RES facility.
The currently active portion of this below-grade moving face landfill is
noted as the Excavated Fill Pit on Figure 3, The moving face landfill was
started in late 1976 or early 1977 and the depth gradually increased from
30 to 50 feet below grade. RES proposes to continue excavating northward,
excavating and re-landfi11ing waste from old completed landfill cells until
the entire southern portion of the facility has been excavated and filled
to 50 feet below grade. RES then proposes to landfill waste to a height of
23 feet above original grade over the southern portion of the facility.
Above-ground disposal will be made possiole by completing the contain-
ment dike that currently borders the east and south sides of LF-19. The
northern portion of the proposed RES landfill will be developed after (1)
the southern portion of the landfill is filled, (2) the drainage ditch and
pipeline that presently separates the north and south portions are relocated
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41
and (3) present surface impoundments are closed. Above and below grade
disposal would occur concurrently until the landfill is extended to just
south of Avenue A [Figure 3],
Landfill LF-19 was constructed by excavating the natural clay to the
desired depth. Sand lenses were dug out as encountered and refilled with
compacted clay in 6 to 8 inch lifts to a thickness of 12 feet. After exca-
vation, the bottom of the landfill was broken up (scarified) to a depth of
6 to 12 inches and recompacted with a Cat 815 sheepsfoot roller, Walls
were compacted by the same Cat 815 sheepsfoot roller but without
scari fication.
A leachate collection system was installed during a Srmonth period in
1982 before landfilling in the current cell began. Eight transverse dike-
like structures made of sand were constructed from the middle to the side
of the landfill. The structures are about 10 feet wide and 2 feet high.
The bottom of the landfill also sloped about 1% from the middle to the sides
of the landfill. The sand "dikes" end where the landfill floor meets the
side wall and drain to perpendicular trenches filled with pea gravel. To
enable leachate removal, 6-inch PVC standpipes (numbered CC~1 through 8)
run to ground level on the outside of the dike. Leachate is periodically
pumped to tank trucks and hauled to the chemical/biotreatment system. The
landfill also has one sand trench containing an 8-inch slotted PVC pipe
with a vertical 8-inch PVC riser inside 10-inch steel casing. A tenth
leachate collector with a radial collection system is to be installed soon.
Tanks
RES has operated and continues to operate a series of tanks and tank
farms for storage of RCRA waste and PCBs. The existing tank farms have
surrounding containment berms constructed either of clay or concrete. Leak-
age from the tanks, piping and waste transfer operations is collected in
sumps. Tank pads are either sand or concrete. The containment basins have
compacted clay floors. A list of existing tanks, capacity and types of
waste stored is presented in Table 7,
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42
Table 7
REGULATED TANKS
Tank Number
T-l
T-2
T-4
T-5
T-6
T-7
T-8
T-9
T-10
T-H
T-12
T-18
T-19
T-2Q
T-21
T-22
T-27
T-28
T-31
T-32
T-60
T-61
SX-2
SX-3
SX-4
T-40
V-22
V-23
T-24
T-25
T-26
T-29
T-30
PVT-1
PVT-2
T-49
T-50
T-54
V-l
West Mix Pan
East Mix Pan
Type of Waste
No. th Tank Farm
Transformer oils containing PCBs
Transformer oils containing PCBs
Out of service
Out of service
Transformer oils containing PCBs
Transformer oils containing PCBs
Transformer oils containing PCBs
Transformer oils contianing PCBs
Transformer oils containing PCBs
Transformer oils containing PCBs
Transformer oils containing PCBs
Transformer oils containing PCBs
Transformer oils containing PCBs
Dichl orobenzene , furfural, amine tars, pnenoi
l,4-dichlorobutene-2 mixture
Out of service
Methacrylates , cyclohexane, amine tars
Methacrylates , cyclohexane, amine tars
PCB blends
PCB blends
Transformer oils containing PCBs
Transformer oils containing PCBs
East Tank Farm
Liquid waste for thermal oxidation
Liquid waste for thermal oxidation
Liquid waste for thermal oxidation
Liquid waste for thermal oxidation
West Tank Farm
Transformer oils containing PCBs
Transformer oils containing PCBs
Transformer oils containing PCBs
Transformer oils containing PCBs
Transformer oils containing PCBs
Transformer oils containing PCBs
Transformer oils containing PCBs
Others
Appendix VIII emulsions
Appendix VIII emulsions
Clarified sludge
Clarified waste water
PCB-contami nated sludges
Knock-out pot
Liquid waste for sol idi fication/landf i 11 ing
Liquid waste for sol idi fication/landf i 1 1 ing
Capaci ty
(ga 1 1 ons)
21,000
25,300
26,400
26 , 400
26,400
26,400
26,400
15 , 000
1.5, 000
25,300
21,500
lies 7,400
7,400
15,400
15,400
,30,000
30,000
100,000
200,000
15,000
20,300
20,300
12,600
7,000
7,000
2,400
13,000
15,400
7,000
7,000
1,000
(portable)
1,000
(portable)
10,200
45,000
900
300
90-100 cubic yards
90-100 cubic yards
-------
43
Tanks listed in the "Others" section have no containment but are used
for short-term storage for special wastes, mixing wastes or when cleaning
out other tanks. Leakage from these tanks could contaminate ground water.
Container Storage Area
The container storage area consists of two warehouses and two pads
with interconnected roofs, walls and curbs. The warehouses are 3,000 and
10,000 square feet and were built in 1978 and 1982, respectively. Drummed
PCB tran<;former oils and drummed or boxed PCB capacitors are the main items
stored in the warehouses. The buildings have concrete floors with 6-inch
curbs and the RCRA Part B application lists the capacity of the warehouses
at 2,200 55-gallon drums and 200 wooden PCB capacitor containers.
The container storage pads are 7,800 and 3,900 square feet, respec-
tively, A large concrete drum storage pad of about 80 by 270 feet was
installed in 1973 after the State of Texas issued RES an Enforcement Order
because of contaminated stormwater runoff from the drum storage area. The
configuration of the drum storage area has changed with the building of the
PCB warehouses and completion of needed repairs. Potential for the release
of hazardous waste constituents to the ground water has existed from early
1970's storage of drums on the ground and later storage of drums off the
concrete pad or broken curbs allowing runoff from the concrete pad to the
ground. The RCRA Part B application lists the capacity of the pads as 800
55-gaHon drums, 50 35-gallon fiber drums and 900 steel PCB capacitor bins.
Non-Interim Status Regulated Waste Management Units
Waste management units and activities operated before November 19,
1980, which are not subject to the TAC interim status ground-water monitor-
ing requirements, are also potential sources for release of hazardous waste
constituents to ground water. RES submitted information to TWC in August
1985 on past waste management units and activities at the Deer Park facility,
pursuant to Section 3004(u) of RCRA. Lagoon L-998/999 (stabilization basin)
and unnamed disposal trenches, described below, were not included in the
submi ttal.
-------
44
This, along with other information about these units/activities, is
discussed below. Some areas, such as old landfill trenches are under study
to locate where waste was buried to facilitate monitoring well placement
^.id removal activities. Pre-RCRA units are the shaded units shown in
Figure 3.
Surface Impoundments
Surface impoundments were used at the site for hazardous waste treat-
ment and storage Some landfill cells were originally used as surface
impoundments and then filled with waste and completed as landfill cells.
All of the old surface impoundments are to be excavated and landfilled in
the new proposed moving face above and below-grade landfill. The 15 pre-
RCRA surface impoundments described in Table 8 and discussed below were
subject to pre-RCRA/TAC regulations.
Lagoon L-3
Lagoon L-3 was a 200-foot-square surface impoundment used for treatment
of wastewater and rainwater at the RES facility. After construction in
1971, L-3 was used as a filter bed (aerobic/anaerobic biological digestion).
According to a 1970 site development drawing, lagoon L-3 was to be con-
structed by excavating 2 feet below grade and constructing a dike to a heigh;
of 4ij feet above grade. This shallow impoundment was closed in 1980 by
draining and treating liquids, solidifying and landfill ing sludges, excavat-
ing and landfill ing underlying clay, and compacting additional clay from
onsite excavation to form three treatment lagoons (L-31, 32 and 33) - deeper,
but smaller in surface area,
Lagoon L-5
Lagoon L-5 was an approximately 100-foot by 400-foot rhomboidal sur-
face impoundment used as a settling basin for incinerator scrubber water
from 1971 to 1974 when F-l, 2, 3 and 4 and the scrubber-water ditch were
constructed. From 1974 to 1976, lagoon L-5 v/as used to store rainwater,
-------
45
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-------
46
According to a 1970 Site Development drawing, lagoon 1-5 was to be
constructed by excavating 2% feet below grade and constructing a dike to a
height of 2 feet above grade. This shallow impoundment was converted into
two impoundments in 1976; R-2 for collection of rainwater and L-5 for fire-
water storage. Both R-2 and L-5 were still in operation during the Task
Force inspection.
Lagoons L-6 through L-ll
Lagoons L-6 through L-ll were ?n-foot by 85-foot surface impoundments
used as receiving/storage basins for incoming loads of aqueous sludges.
L-6, 7 and 8 were hypalon-1ined and were initially used for acidic aqueous
sludges. However, the liners were ruined by portable aerator pipes after
approximately 1 year and after that there was no distinction between waste
placed in L-6, 7, 8 and L-9, 10, 11 (compacted clay liners). According to
a 1970 Site Development drawing, L-6 through 11 were to be constructed by
excavating 4 feet below grade and constructing dikes to a height of 3 feet
above grade. These shallow impoundments were closed in 1976 by pumping
wastewater to the biosystem, mixing sludges with cement kiln flue dust for
onsite landfill ing and capping the excavated lagoon areas with clay.
Lagoons L-ll, L-18 and L-19
Lagoons L-17, 18 and 19 were surface impoundments constructed in 1971,
1972 and 1973, respectively. These lagoons were "home built" and drawings
are not available to provide construction details. Construction was report-
edly similar to other lagoons with excavation in natural clay and compaction
by sheepsfoot. L-17 was used as a settling basin for solids, incinerable
dregs and customer filter cakes. In 1974, L-17 was allowed to dry out and
sludge was mixed with flue dust and landfilled in cell LF-4. L-18 was used
for acidic aqueous waste and L-19 was used for neutral wastewater and rain-
water. In 1976, these two lagoons were closed by pumping neutralized waste-
water to the biosystem, mixing sludges with flue dust for onsite landfill ing
and capping the lagoons with clay.
-------
47
East and West. Catch Basins
The East and West Catch Basins were surface impoundments used for
collection of rainwater. These lagoons were "home built" and drawings are
not available that would provide construction details. In general, these
were shallow basins that were bulldozed in natural clay and compacted by
sheepsfoot. Rainwater was collected in these areas until 1979 when the
area was recontoured.
Final Stabilization Basin
The Final Stabilization Basin was a surface impoundment used for final
cooling, settling and neutralization of incinerator scrubber water. This
shallow lagoon was "home built" in 1971 and detailed drawings are not avail-
able. In 1973, the Final Stabilization Basin was converted to a series of
fo.ur lagoons (F-l, 2, 3 and 4).
Lagoon L-998/999 (Stabilization Basin)
Lagoon L-998/999 was a surface impoundment that was formed in 1972
from excavation of natural clay used in the construction of other lagoons/
dikes at RES. This lagoon is marked Stabilization Basin on Figure 3 and
was near L-1000 and L-1001. Acid was neutralized in L-998/999 by mixing
the acid with ammonia. This basin was not used after 1973 and no detailed
drawings are available.
Landfills
Landfills were used at the site both as surface impoundments and land-
fill cells through 1978. The moving face landfill was started in 1977 and
the last discrete landfill cells were closed in 1979. All of the old dis-
crete landfill cells are to be excavated and re-1andfi11ed in the new pro-
posed moving face landfill. The 13 pre-RCRA landfills, listed in Table 9
and discussed below, were subject to the RCRA/TAC regulations. Landfill
records began on or about January 1, 1977. Records indicate the waste
-------
48
Table 9
PRE-RCRA LANDFILL CE.LS
Cell
Number
LF-4
LF-5
LF~6
LF-7
LF-8
LF-9
LF-10
LF-12
LF-14
LF-15
Unnamed
trenches
Date
Constructed
1973
1973
1974
1974
1973
1975
1075
1976
1977
1978
pre-1975
Date
Compl eted
1974
1976
1978
1976
1978
1976
1076
1977
1979
1980
pre-1976
Remarks
Old surface impoundment
Old surface impoundment
Old surface impoundment
Old surface impoundment
Old surface impoundment
Used as landfill only
Used as landf il 1 only
Start of moving face
landfill
Moving face landfill
Moving face landfill
Under dredged spoil
area
number, amount, depth in the cell and distance from the perimeter. Diagrams
of waste locations were made but a coordinate system was not used until
1980.
Landfill Cells LF-4 through LF-8
These landfill cells were constructed in 1973 and 1974, primarily as
wastewater lagoons. These cells were "home built" and detailed drawings
are not available. As with other units from :.his era, construction report-
edly consisted of bulldozing a shallow lagoon, less then 20 feet deep, in
the natural clay deposits at RES and compacting with a sheepsfoot. When
these units were closed, wastewater was pumped to the biotreatment system,
drummed solid waste was placed in the cells, and the cells were capped with
cl ay.
-------
49
Landfill Cells LF-9 and LF-10
These landfill c^lls were similar to LF-4 through LF-8 except they
were never used as surface impoundments.
Landfill Cells LF-12, LF-14 and LF-15
These landfill cells started the moving face landfill and were more of
a continuum than dis'crete cells. The depth of these cells gradually
increased from 30 to 50 feet deep. These cells were capped wit clay as
landfill ing progressed,
Unnamed Trenches
Drums were buried in other locations at the RES facility, Records of
these trenches are poor or nonexistent. RES has recently investigated the
site to locate old drum disposal areas and drums have been discovered buried
south of lagoon L-1001. Drums may also have been buried underneath the
dredged spoils area. RES has been conducting magnetometer studies to locate
these areas. Buried drums would be excavated and re-landfi1 led in the moving
face 1andfi11.
FACILITY OPERATIONS
Improper facility operation can result in the release of hazardous
waste constituents to ground water. Task Force personnel reviewed records
of facility operations for indications of problems that might lead to waste
releases and information to aid in interpreting ground-water monitoring
data.
To either conduct an interim status assessment monitoring program or
complete a RCRA Part B permit application, TSD personnel need to know the
identity and location of wastes in the regulated units. This information
must be maintained in the operational record for the facility. Conse-
quently, operational records, including selected waste preacceptance and
-------
50
tracking records, were reviewed to evaluate how well waste constituents
have been identified in incoming waste and whether the disposal locations
have been properly recorded.
Waste Storage Operations
Waste storage operations at RES, including drum and container storage
and bulk liquid or tank storage, have evolved with State and Federal regula-
tion changes. In the early 1970s, drums were stored throughout the site
and sometimes lined the roadways. Waste drums and containers are now kept-
on curbed, drum storage areas,
In the early 1970s, tanks were built on sand, clay or concrete founda-
tions, but often without containment. Containment basins were initially
constructed with clay floors and dikes. The clay dikes were subsequently
replaced with concrete walls. All tanks are vented into either a high pres-
sure or low pressure vent system. Overflow controls vary from manual to
automatic. As part of the RCRA Part B permitting process, many older tanks
are being replaced,
Internal Waste Transfer Operations
Internal waste transfers at RES include dredged spoils, incinerator
ash, surface impoundment sludge, tank clean-out material and spill clean-
ups. Incinerator ash is tested for PCBs and usually contains less than
5 parts per million (ppm) PCBs. Although internal waste transfers are not
manifested, RES tracks and analyzes the material with lab and landfill
records similar to waste accepted from offsite. RES has only recently begun
keeping internal waste transfer information.
Waste Treatment Operations
Waste treatment operations at RES include treatment in surface impound-
ments, tanks and incineration. Waste treatment units and internal waste
transfers have been previously discussed. NPDES discharge points 001 and
-------
51
002 and surface runoff remain as possible sources of release of hazardous
waste constituents from the RES facility. Surface runoff is controlled by
design features using dikes and natural contours. Discharge points 001 and
002 are monitored and sampled by RES,
Landfill Operations
Landfill operation at RES has evolved with increasing demands for effi-
cient use of landfill space and in response to changes in State and Federal
regulations. In 1971, when RES began accepting waste, burial was in shallow
trenches and few records were kept (RES is currently conducting magnetometer
studies to locate these shallow trenches). According to RES officials,
liquids were never landfilled without being solidified; flue dust has been
used for solidification since about 1975. Early landfill records, starting
in the mid-1970s, did not use a coordinate waste locating system but included
diagrams showing the depth at which the waste was buried and the distance
from the site perimeter. In 1980, a grid system to locate buried waste was
initiated and the landfill supervisor kept daily records.
The present grid system began in January 1984 and features a smaller
grid system capable of locating waste within 10 feet vertically and 5 to 10
feet horizontally. Records consist of a Daily Landfill Report by HO number
[Table 10]; Lab Discharge Slip, which includes analytical results (usually
percentage of solids and pass or fail on a paint filter test used since
May 8, 1985); Batch Composition Sheet for mix pan waste; Monthly Landfill
Summary and Grid Map, The landfill is surveyed quarterly, using reference
placards on the western boundary of the site. Waste is placed in the land-
fill in 5 to 10-foot lifts with about 2 feet of stabilized waste from the
mixing pan over and around the drums, which are usually stacked two high.
Each batch of stabilized waste must pass a paint filter test and is tested
for unconfined compressibility using ASTM Methods for penetrometer testing,
RES indicated they have never retrieved any landfilled waste. Because of
the random nature of waste burial, any hazardous waste constituents accepted
by RES could be present throughout the landfill areas.
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52
Tabla 10
RES WASTE TRACKING RECORDS
RES Tracking Number
HO Suffix
No, Code
1431
1696
1992
212f
3521
3791
4021
4284
5175
5481
6157
6473
6540
6599
6807
5891
7083
7821
7852
8612
9451
11039
11692
14989
50
51
51
51
51
55
51
50
51
51
51
51
37
51
52
51
51
55
51
51
50
51
Suffix
Meaning
Landf i 1 1 , direct
Landfi 11, mix w i th
dust
Landf 1 11, mix wi th
dust
Landf 1 11, mix wi th
dust
Landf 1 1 i , mix with
dust
Encapsulation for
landfill
Landfill , mix with
dust
Landfi 11 , direct
Landfill, mix with
dust
Landf i 11, mix with
dust
Landfi 11, nix with
dust
Landfi 11, mix with
dust
Landfi 1 1 , "put in
hole with flue
Oust to absorb"
uandf i 11, mix wi th
dust
Landfi 11, full drums
Landfi It, mix with
dust
Landf 1 II, mix with
dust
Encapsulation for
landfill
Landfi n j mix wi th
dust
Landf 11 I , mix with
dust
Landfill , direct
Landfill , mix with
dust
Date on Waste
Waste Type Data Sheet
Scrap sulfur
Butadiene process catalyst
Leachate filter cake
Chrome oxide slurry,
corrosive
Spent catalysts: alumina/
chrome, alumi na/si 1 ica
alumina
Phenol -formaldehyde resin
Cooling tower blowdown
Water treatment sludge.
ferrous sulfat* llm«
sludge or synthesis
process carpon recovery
blowdown containing CN
and sulfides
Paint spray booth sludge
Amorphous polyethylene
(HOE) wax
Tank bottoms-rust contain-
ing lead
Waste perchloroethyl ene
mixture
Mixed organics or tank
sludge with mercaptans
Sulfur sludge/polyethylene
glyco'
Paint residues/solvents or
flammable waste paint
s ' udge containing MEK
Creosote sludge
Naphthalene
Leaded gasoline tank
sludge
Plating sludge
Arsenic- contaminated
equipment
Sludge or cyanides (zinc
phosphate bath sludge)
Water/oily sludge
Solvents/soil
Oily si udge
5/28/81
8/30/75
2/3/77
7/12/77
5/7/79
7/20/79
Original
dated
8/27/79
with an up-
dated waste
data sheet
that was not
dated
11/12/79
6/17/80
9/10/80
2/20/81
6/24/81
6/22/81
7/15/81
10/2/81
1/8/82
10/18/84
8/2/82
8/4/82
1/17/83
6/10/83
11/22/83
Not dated
1/24/85
Dates Waste
Accepted
1981-1985
1980-1981
1980-1985
1980-1985
3/18/81
1982-1985
1980-1985
1980-1985
1980-1985
1980-1985
1981-1985
1981-1985
1981-1982
1981-1985
1981-1982
1982
1982-1985
9/14/82
1983-1985
1983-1984-
1983-1985
1983-1985
1984
3/22/85
Analyses Perf o 'Tied
When Waste Ace ip'.ed
None
None
% solids starting in 1962
% solids and/or pri s. art ing
in 1983
None
% solids starting in 1983
% sol las starting in 1982
% solids starting \r 1983
% sol ids
None
% solids starting ir 1982
Flue dust test starting in
1982, % sol ids stir-ting
i n 1983^
None
% solids starting ir 1933
None
None
None
Flash polnt/'X solid1
% sol ids
Visual
One out of five Gel veries
analyzed for ph and %
sol ids
% sol ids
Flash point
% solids
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53
Landfill operations at RES did not comply with TWC permit [Appendix A]
requirements for waste handling (Part III, Section 5, Requirements f, j, k
and 1). Leachate collection systens have not been inspected weekly and no
log has been kept as required by "f". Compatibility tests, when performed,
involve mixing two wastes together. Chemical analyses for compatibility
have not been conducted and records have not been maintained as required by
"j". Noncompatible wastes are often not identified, resulting in exothermic
reactions when the wastes are mixed in the mix pans. During the Task Force
inspection, "smoking" waste was observed and one day the contents of a mix
pan had to be unloaded to allow an exothermic reaction to go to completion
before the material could be landfilled. Incompatibles that are not identi-
fied or mixed may be placed in the landfill without regard to segregation.
This lack of identification and segregation of incompatibles is not in com-
pliance with "k", Landfill records have become more sophisticated and
specific with time, but no records exist of leachate collection system
inspections or leachate removal, as required by "1".
Waste Acceptance and Tracking
Waste characterization before receipt at a TSDF and tracking after
receipt are required under both RCRA and State interim status regulations.
These are important in determining the constituents that could potentially
be released from waste handling units. To determine whether RES sufficiently
characterizes waste it receives and records the disposal location, a review
of preacceptance and tracking records for 24 waste loads* received between
January 1980 and May 1985 was conducted.
The records review indicated that the paperwork was not always com-
pleted, the waste analysis information was often several years old and
analyses performed when waste was accepted were very limited [Table 10J.
About four waste loads were selected for each year and an attempt was
made to select wastes that would require more detailed analyses to
adequately characterize and fingerprint the waste.
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54
In general, the initial waste analysis may have been fairly comprehensive
for waste streams continually received, but it. was seldom updated. Also,
the analyses performed when waste is accepteH are not adequate to determine
if the waste stream is the same one originally approved for acceptance by
RES.
Waste acceptance at RES has evolved with State and Federal regulation
changes. In 1971, when RES began accepting waste, the facility reportedly
accepted all types of waste. In 1976, manifest records began and in 1977
landfill records began at RES. Waste data/acceptance information dates
back to 1977 for the 24 waste loads tracked during the Task Force inspec-
tion. After 1980, when RCRA regulations became effective, Rollins revised
and updated its "pre-acceptance/acceptance package." Basically, customers
have to provide RES with detailed waste characteristics, safety information
and a representative sample or analytical results for a representative sample
of the waste. Rollins does not accept radioactive waste or PC8 waste for
landfill ing. (PCS liquids are incinerated and RES brokers all PCB trans-
formers/solids to other landfills).
RES conducts no or only limited "fingerorinting" of incoming waste
loads to ensure that the manifested waste is the same as the waste stream
approved for receipt. RES contends that they have long-term steady cus-
tomers whose waste does not vary much. Waste loads to be landfilled are
usually only checked for percent of solids, which is used to determine the
amount of flue dust necessary to solidify the waste. Waste to be solidifiec
is placed in one of two large mix pans in the landfill area, and the flue
dust is added and mixed with a backhoe. Waste is directed to the mix pans
by laboratory personnel. Pan selection is based on mix pan capacity which
is tracked by the landfill operators. RES reports that exothermic reaction:,
between wastes mixed in the pans can result in steam generation, but RES
claims they have never had to evacuate the plant or had a fire as a result
of this operation.
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55
SITE HYDROGEOLOGY
Two major hydrogeologic investigations had been conducted by RES
consultants at the Deer Park facility prior to the Task Force field inves-
tigation. The firs* investigative report was prepared by Harding-Lawson
Associates in 1978, and the second by Law Engineering in 1980. At the time
of the Task Force field investigation, a third study was being conducted by
Ralph Reuss, a private consultant, with field support provided by Profes-
sional Services Industries, Inc. (PSI). A verbal update of that study was
provided by Mr. Reuss to Task Force personnel at the time of the field
investigation. The following information is provided to explain the com-
plexities of the site hydrogeology, the extent of work done up to the time
of the field investigation, and the plans for continuing studies at this
site.
The Deer Park facility is situated in the Gulf Coast structural prov-
ince, which is described as a huge sedimentary basin consisting of several
thousand feet of unconsolidated sand, silt and clay units, dipping region-
ally toward the Gulf of Mexico. At the Deer Park facility, the upper 150
to 200 feet of these deposits consists of the Beaumont Formation, which
comprises the Upper Chicot Aquifer. The Beaumont Formation is characterized
as a high-energy, wave-dominated delta facies. Characteristics of this
type of environment include:
Interbedded and interfingering sand, silt and clay strata in which
the strata are typically more horizontally continuous, one long
shore wave action
Channel sand deposits which are more prevalent in the pre-delta
regions and
Clay deposits, primarily found in the backswamp and lagoonal
envi ronments
The Lower Chicot Aquifer, 300 to 500 feet in thickness, is comprised
primarily of the Alta Loma Sand, and is a major source of ground water in
-------
56
the Houston area. The Alta Loma Sand is predominantly sand, with
intermittent silt and clay layers.
The Alta Loma Sand is immediately underlain by the Evangeline Aquifer
(also a rajor source of ground water) and are differentiated by an increase
in transmissivity in the Evangeline.
Collectively, these aquifers are interpreted as being part of the Gulf
Coast Aquifer.
In regard to required ground-water monitoring, the most important
hydrogeologic units underlying the site are the permeable in the upper por-
tion of the Beaumont Formation because of their potential to transport, waste
constituents from the management units. During the Task Force investigation,
a hydrogeologic study was being conducted to better define these zones.
Prior to the present investigation, data from several test pits and
approximately 39 borings had been used to characterize the hydrogeology at
the Deer Park facility. Soil and geologic data were also obtained by
observing the side walls in the landfill excavation, which expose the upper
40 feet of strata. Samples obtained from about half of the test borings
were undisturbed samples taken at 5-foot intervals with a split-spoon or a
Shelby-tube sampler. Samples from the other half of the test borings were
disturbed samples taken at 5-foot intervals. About 43 field and laboratory
permeability tests were performed.
A major shortcoming of these investigations was that the visual obser-
vations used to classify the hydrogeologic units at the site were incon-
sistent and inadequate to define the complex geology,
As part of the current investigation being conducted by Mr. Reuss,
continuous soil samples were taken from 29 boreholes in the northern portion
of the waste management area. Samples of cohesive sediments were obtained
with Shelby-tube samplers and non-cohesive samples were obtained with split--
spoon samplers. Results of liquid limit, plastic limit and penetrometer
-------
57
tests were used to classify the sample materials. Fifteen field permeability
tests had been performed.
HYDROGEOLOGIC UNITS
All the consultants to RES identified the same principal hydrogeologic
units [Figure 5]. However, different terms were applied to them in the
various reports. For ease of reference the Reuss unit designations will be
used in this report because they represent refined interpretations made
from a more comprehensive data base than that available to the previous
investigators. The different terms applied to the units are presented in
Table 11.
The clays of the Beaumont Formation are very plastic due to the high
montmori11onite content, especially in Stratum No. 4. The high montmori1-
lonite content is also responsible for the shrink/swell characteristics of
the Beaumont. The clays shrink or swell in response to moisture content
changes. As the clays undergo cycles of shrinking and swelling, fracture
planes or "siickensides" may develop. Additionally, subsidence resulting
from ground-water withdrawals may be partially responsible for siickensides
observed in the Beaumont. These fracture planes provide secondary perme-
ability. Clays with high montmori1lonite content also have relatively high
cation exchange capabilities, which is a desirable characteristic for a
landfill site.
Stratum 3 has been proposed as the uppermost aquifer by the consultants
to RES. Task Force personnel consider the uppermost aquifer to include the
entire saturated interval down to the Burkeville aquiclude at the base of
the Evangeline Aquifer (approximately 3,000 feet below ground surface),2
The Evangeline Aquifer and the Chicot Aquifer are hydraulically intercon-
nected with the highest head in the upper portion of the Chicot and the
lowest head in the Evangeline. Therefore, in addition to the horizontal
component of movement, a vertically downward component is present in the
hydrogeologic system.
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58
iiiil ?! -U U i { . •
liilii lil !j !' { r t ..M
,MiiM in ! M j i! i i
il'i ill ill i it H II.
© ©0 0
-------
59
Table 11
HYDROGEOLOGIC UNITS IDENTIFIED
AT RES DEER PARK FACILITY
Reuss Designation
Stratum Description
Hardi ng-Lawson and Law Designation
Stratum Description
7 to 32 feet of firm to stiff
tan and light gray clay, sandy
clay, and silty clay with silty
and clayey layers; replaced by
fill soils at many locations
30 feet of very stiff to hard
reddish-brown clay; contains
occasional fractures
2A Silt and sand layers and lenses;
contains perched water
3 4 to 28 feet of firm tan and
gray silty fine sand and sandy
silt with some low plasticity
clay zones
4 15 to 42 feet of hard red and
light gray high plasticity clay
with clayey sand lenses; contains
pronounced fractures
5 5 to 40 feet of dense tan silty
sand
6 4 to 16 feet of very stiff gray
and tan sandy clay
7 16 to 20 feet of dense silty sand
8 Very stiff gray and tan sandy clay
Black to dark gray surface
cl ay
II Gray to tan silty clay
with sandy and silty
layers and red mottled
clay and red silty clay
IIA Sandy silt and silty sand
1ayers
III Fine sand, silty fine sand
and fine sandy silt
IV Gray, tan and red mottled
c 1 ay to s i 1 ty cl ay
-------
60
Task Force personnel determined that, in addition to the silty sand
unit (Stratum 3), the silt and sand zones of Stratum land 2 need to be
monitored. As the?2 are permeable, saturated zones, monitoring wells com-
pleted in these zones would supplement .nonitoring of Stratum 3 to ensure
immediate detection of any statistically significant amounts of hazardous
waste or hazardous waste constituents that might migrate from the waste
management units.
GROUND-WATER FLOW DIRECTIONS AND RATES
A potentiometric contour map was presented in the Harding-Lawson report
for Stratum 3 in the southern portion of the waste management area [Figure; ij]
and one for the northern portion of the waste management area [Figure 7]
where the monitoring wells are completed through multiple zones (Strata 2,
3, 4 and 5). Harding-Lawson's interpretation of the water level measure-
ments, as illustrated by the contour maps, was confirmed by Task Force
personnel. •
The potentiometric contour map for Stratum 3 in the southern portion
of the site [Figure 6] suggests that horizontal ground-water flow is
radially toward the active below-grade disposal area. This localized
ground-water depression or sink is the result, of pumping runoff and ground-
water seepage ponded in the excavated area to dewater the active disposal
cell.
The potentiometric contour map for the northern portion of the site is
based on water levels in wells completed in multiple zones, and indicates
ground-water flow to the north-northeast. From data available to Task Force
personnel at the time of the inspection, the ground water in the northern
portion of the waste management area appears to be unaffected by the grouno-
water sink. The RES consultant interpreted (Task Force personnel concur-
red) the potentiometric contours in the northern portion of the waste
management area as reflecting the water levels and flow direction of
Stratum 5. At the time of the Task Force inspection, available data were
inadequate for characterizing the ground-water flow directions and rates
for Stratum 3 in the northern portion of the waste management area.
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61
s
ta
v
o
Z
o
-
e
V
£
2
5
o
3
w
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62
J !
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63
The permeability (hydraulic conductivity) of Strata 1, 2 and 3 at the
Deer Park site has been estimated by the RES consultants using two different
methods. These are (1) laboratory testing of "undisturbed" soil samples
with the permeability measured primarily in the vertical direction and (2)
in situ recovery tests. A summary of the permeabilities for the various
strata is presented in Table 12.
Table 12
ESTIMATED PERMEABILITIES OF THE HYDROGEOLOGIC UNITS
Hydrogeologic
Maximum
Permeabi1i ty
(cm/s)
Mi nimum
Permeabi1ity
(cm/s)
Mean
Permeabi1ity
(cm/s)
Unit
Stratum
Stratum
Stratum
Stratum
1
2
2A
3
Vertical
_7
3x10
_6
4x10
_4
1x10
—
Hori zontal
2x10
4x10
6x10
4x10
s
6
4
3
Vertical Horizontal
_8
1x10
- XU
1x10
_« _4
1x10 1x10
.5
1x10
Verti
_8
8x10
*_ 7
5x10
-5
2x10
«
cal
(4)*
(18)
(6)
Hori zontal
—
-
_4
4x10 (4)
_4
7x10 (24)
Number of measurements
The reliability of the laboratory and field permeability data cannot
be fully evaluated because the methods used are not sufficiently described,
For example, 19 measurements made by Harding~Lawson in 1978 used either an
unspecified falling head test or permeability was calculated from a measured
coefficient of compressibility. There are several different methods for
measuring permeability by these general procedures, each having different
shortcomi ngs.3
Most of the field permeabilities, which should be more reliable than
the laboratory data, are suspect due to potential interferences caused by
well construction. Results for 20 rising-head permeability tests conducted
on 18 wells were reviewed. Eight of the wells (MW-6, 7, 8, 11, 12, 13, 15
and 18) were installed with filter fabric wrapped around the "screen" (see
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64
section on Monitoring Wells), which could slow water entry into the well
and yield permeability results biased low.
Recovery tests yield results for transmissivity, which is a measure of
water production from the monitored zone. Permeability is then calculated
by dividing the transmissivity value by the composite thickness of the prin-
cipal water-producing zone(s) yielding water to the well or the length of
screen open to the water producing zone(s). Determining the composite thick-
ness is difficult when a water-producing zone is intersected above or below
the screened section of the well by an oversize sand pack. The head loss
of water moving from such a zone through the sand pack to the well screen
effectively reduces the thickness of the zone in the permeability calcula-
tion. Whether corrections were made is not reported.
The lack of method descriptions make data discrepancies difficult to
understand. Both Law Engineering and PSI, for example, conducted recovery
-4 _5
tests on well MW-12. The results were 6.1 x 1C) and 8 x 10 , respectively
The apparent decrease (almost an order of magnitude) in permeability between
1980 and 1985 could be due to (1) clogging of the filter fabric, (2) dif-
ferent value used for the composite thickness of the water-producing zone,
(3) different equations used to calculate transmissivity or (4) deteriora-
tion of the well screen.
One of the wells (MW-9) was a production-type used to dewater the grounj
near the landfill excavation. The well had (it was abandoned in 1983) a
10-inch diameter casing with a 24-foot screen installed in a nominal 24-inch
borehole that was 60 feet deep. The entire annular space was sand packed
so that any water-bearing unit could yield water to the well. No informa-
tion was provided on the value used for the composite thickness of the
transmissive units or how it was derived. Permeability data are also sus-
pect from three of the monitoring wells (MW-35, 37 and 38), which had 10-foot
screens and 18 or 19-foot long sand packs.
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65
In summary, permeability data for 12 of the 18 wells tested are suspect
because of potential construction interferences, Considering typical per-
meability values for the materials being measured in conjunction with
the other results, the suspect values are probably accurate withn an order
of magnitude,
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66
GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS
Ground-water monitoring at the Rollins Deer Park facility has been
conducted entirely under State interim status regulations because TWC was
delegated Interim Authorization in December 1980, The following is an ev«l-
uation of the monitoring program between November 1981, when the ground-
water monitoring provisions of the TAG became effective, and October 1985,
when the Task Force investigation was conducted. This section addresses:
Regulatory requirements
Ground-water sampling and analysis plan
Monitoring wells
Sample collection and handling procedures
Sample analysis and data quality
Ground-water Quality Assessment Program outline
REGULATORY REQUIREMENTS
Between November 1981 and October 1985, a two-part regulatory frame-
work controlled the design, installation and operation of the ground-water
monitoring program at the RES facility. These parts were (1) the TAG
regulations and (2) the State permit (No, 01.429) issued to the facility.
The information presented here is included as a background for subsequent
discussions of the monitoring wells and program and compliance by RES with
the monitoring requirements.
State regulations for interim status facilities are contained in
Title 31 of the TAG Section 335, Subchapters E through T, which became
effective on November 19, 1980. The State ground-water monitoring require-
ments (Subchapter I) are nearly identical to the RCRA interim status
requirements contained in Title 40 of the Code of Federal Regulations,
Part 265 (40 CFR Part 265), Subpart F; there are no substantive differ-
ences, Regulation counterparts are shown in Table 13.
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67
Table 13
STATE AND FEDERAL COUNTERPART
INTERIM STATUS REGULATIONS
RCRA
Subpart TAG Regulation
Title* (Title 31) (40 CFR Part)
Applicability 335.191 265.90
Ground-Water 335.192 265,91
Monitoring
System
Sampling and 335,193 265,92
Analysis
Preparation, 335,194 265.93
Eva!uation
and Response
Reporting and 335.195 265.94
Recordkeeping
* Subpart titles are the same in both the
State and RCRA regulations.
The TAG specifies a monitoring schedule, parameter list, requirements
for a sampling and analysis plan, and data evaluation and reporting proce-
dures. The permit only specifies a monitoring schedule and parameter list.
The monitoring schedule in the permit is different from the TAG and addi-
tional monitoring parameters are required by the permit, as discussed below.
The TAG states [335.45] that the regulations shall be followed except where
the permit contains additional or more 'stringent requirements, in which
case the permit requirements shall take precedence.
Since the 1980s, the Deer Park facility has been operated under a State
permit (No, 01429) that covers all phases of facility operation, but is
basically an expanded NPDES-type permit. In accordance with a State direc-
tive [Appendix B], permit conditions for the monitoring schedule and param-
eters were to be followed.
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68
The monitoring program followed by RES after November 19, 1980 began
with requirements contained in a revised version of the 1974 permit, which
was approved on April 9, 1979. At that time, the facility had an 18-well
monitoring network. The 1979 permit required monthly monitoring of the
wells for the first year and quarterly monitoring thereafter and nearly the
same permit parameters listed in Table 14. The 1979 permit also required
monitoring for silica, but not for iron, total organic halogen, radium,
gross alpha, or gross beta, as required by the TAG.
Following approval of the 1979 permit, RES applied to the State for an
expansion of landfill capacity. The mechanism for approval of the expan-
sion was through revision of the permit. During the permit revision process,
other necessary changes were made, including some to the monitoring well
network. Since the 1979 permit was issued, RES and TWC had determined that
9 of the 18 monitoring wells needed to be replaced. As a result of improve-
ments to the drainage channel at the southwest corner of the property, four
wells (MW-4, 5, 15 and 18) were to be abandoned. Five other wells (MW-9,
10, 14, 16 and 17) had been installed for landfill dewatering and were not,
acceptable as monitoring wells.*
A revised permit was issued on September 3, 1981 that approved the
landfill expansion and imposed monitoring requirements on the replacement
("new") wells, when constructed [Appendix A], The new wells were to be
sampled within 1 week of completion, then quarterly for 1 year and semi-
annual ly thereafter. The parameters to be monitored are compared to those
required by the TAC/RCRA interim status regulations in Table 14.
Since the permit only referred to new wells and the monitoring fre-
quency was different from that required for the existing wells by the 1979
permit, RES requested clarification of the 1981 permit requirements in a
December 3, 1981 letter to the State. The response was the letter in
The wells were not abandoned until 1982 -and 1983, respectively.
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69
Table 14
COMPARISON OF GROUND-WATER MONITORING REQUIREMENTS
IN THE STATE PERMIT AND TAG1
Parameters for Quarterly Samples Collected
During First Year of Monitoring
Requirea Dy both 1981 Permit and TAG
Specific conductance 2
Total organic carbon2
Total organic halogen2
Chloride
Iron
Manganese
Phenols
P! uoride
Sodiurn
Sulfate
Arsenic
Barium
2, Required by Permit Only
Calcium
Magnesiurn
Carbonate
Bicarbonate
Total dissolved solids
Phenolphthaiein alkalinity
Total alkalim ty
3. Reqin red__by TAC Only
Radi um
Gross beta
Cadmium
Cnromium
Lead
Mercury
Seleni urn
Si 1ver
Endrin
Lindane
Toxaphene
Methoxycnlor
2,4-0
2.4,5-TP (Silvex)
Nitrate
Chemica' oxygen demand (COD)
Total organic nitrogen
Copper
Nickel
Zinc
Polychlorinated biphenyls (PCBs)
Gross alpha
Fecal coli form
Parameters for Semi-Annual Samples Collected
After First Year of Monitoring
Required by Permit and TAC
phi3
Total organic carbon3
Required by Permit Only
Total organic nitrogen
Chloride"
Manganese4
Sodium*
Specific conductance3
Total organic halogen3
Total dissolved solids
Iron4
Pheno Is4
Sulfate4
Texas Permit to Dispose of Wastes tNo. 01429) issued by
Texas Water Commission on September 3, 1982 And TAC
regulations Chapter 335.193.
TAC requires quadruplicate measurements for these
parameters in the quarterly samples from the upgradient
wells where the permit does not.
TAC requires quadruclicate measurements for these
parameters from all wells semi-annually.
Aiso required by TAC; however, monitoring frequency is "at
least annually".
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70
Appendix B, which states that the existing wells were to be in the
semi-annual sampling schedule (per the permit requirements),
The letter apparently contradicts TAG regulations. Under the TAG
interim status requirements, a new "first year" of quarterly monitoring
should have commenced on November 19, 1981 on the existing monitoring well
network by the schedule and for the parameters specified in the regulations,
as a minimum.
In summary, between November 1981 and October 1985, the ground-water
monitoring program was regulated by TAG and State permit requirements, The
monitoring schedule provisions are apparently inconsistent and additional
monitoring parameters are specified by the permit. In this report, the
ground-water monitoring program implemented at the RES Deer Park facility
is compared to both sets of requirements for the purpose of determining
compliance. ,
GROUND-WATER SAMPLING 'AND ANALYSIS PLAN
Since the effective date of the TAG interim status ground-water moni-
toring requirements (November 19, 1981), at least two sampling and analysis
plans have been developed and followed at the Deer Park facility. Neither
the first nor second plan, which was being followed in October 1985, fully
complied with the TAG requirements.
Monitoring procedures were not well documented until after the second
plan was developed in mid-1985. The previous procedures and records could
not be fully explained by RES personnel because the person who had been
responsible for ground-water monitoring at the facility for many years died
in December 1984. The new person responsible for monitoring is a super-
visory chemist from the onsite lab and who has no previous experience with
the required program (or ground-water monitoring, in general).
The first plan has no cover date, but, because it alludes to permit
requirements for semi-annual sampling, it is presumed to have been developed
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71
after the permit was revised in September 1981. Company personnel stated
that this was the only plan on file that predated the mid-1985 plan. This
plan apparently constituted the interim status plan until a revised version
of the one submitted in the Part B permit application was implemented.
The following describes each of the plans and discusses the
defici enci es.
Plan Followed Until Mid-1985
The undated plan, followed until mid-1985, is three pages long
[Appendix C] and does not comply with the TAG requirements. It is incom-
plete, lacks many necessary details and describes procedures for sample
collection that are unacceptable, as described below.
The TAG [335.193(a)j requires that the plan include procedures and
techniques for (a) sample collection, (2) sample preservation and shipment,
(3) analytical procedures and (4) chain-of-custody control. The regula-
tions [335.193(c)j also require that the monitoring wells be sampled accord-
ing to a two-phase schedule (first and subsequent years) and, during the
first year, additional measurements must be made on samples from upgradient
wel1s.
The monitoring plan does not contain a list of wells composing the
monitoring network, nor does it designate wells upgradient and downgradient
from the waste management units. Neither does it present a schedule that
would indicate which wells were to be sampled quarterly or semi-annual ly in
accordance with the permit.
The plan states that wells will be purged once a month, but does not
specify whether the wells are to be purged just before the required sampling,
Purging just before sampling is necessary to ensure collection of repre-
sentative ground-water samples.
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72
The plan does not describe how depth-to-water measurements are to be
made or whether the depth is to be measured before or after sample collec-
tion, The plan erroneously states that water levels are not necessary for
reporting requirements. This is at variance with the TAG which require-
that the elevation of the ground-water surface be determined each time a
sample is obtained [335.193(e)] and that an evaluation of the ground-water
surface elevations must be submitted in an annual report [335.195(a)(2)(C)]
Samples are to be collected with an air eductor (air-lift) pump, which
is not an acceptable device. The parameters used as indicators of ground-
water contamination, including pH, specific conductance, total organic car-
bon (TOG) and total organic halogen (TOX) [335.193(b)(3)], are all sensitive
to the vigorous aeration caused by the air-lift device. Concentrations and
values can change significantly as a result of the aeration,
If pH changes occur, which is likely using an airlift device, change
in specific conductance is likely. If orgam'cs were leaching from the waste
management units, volatile organic compounds would likely be the first to
arrive at the monitoring wells. Volatiles could be easily stripped from
the sampled water by the air-lift device and would decrease TOX and, pos-
sibly, TOG concentrations.
Records of sampling, as described in the plan, are limited to the sample
tag and either a chain-of-custody record (if samples are shipped to an off-
site lab) or an analytical report form (if samples are analyzed "in-house"^ .
No logs of depth-to-water measurements, purge volumes, sample preservation
well condition or other field observations are described. The plan does
not specify sample handling procedures such as whether samples are to be
filtered (analytical records show that some samples were filtered after-
collection), placed on ice after collection or if field measurements were
to be made.
All methods used for preservation and analysis of samples are not speci-
fied, as required by the TAG [335,193(a)(2) and (3)]. The plan indicates
that methods for sample preservation and analysis are contained in "Methods
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73
for Chemical Analysis of Water [and Wastes]" published by EPA (EPA-600/
4-79-020), The referenced EPA document does not contain preservation and
analytical methods for the following parameters required by the permit and
the TAG,
TOX PCB
Endrin radium
Lindane gross alpha
Methoxychlor gross beta
Toxaphene carbonate*
2,4-D bicarbonate*
2,4,5-T (Silvex) phenolphthalein alkalinity*
Fecal coli form
Also, citing general analytical methods is not acceptable because those
methods often have alternate subparts that can yield significantly different
results for the same sample.
No sample shipment procedures are described, as required by the TAC
[335.193(a)(2)]. Nevertheless, samples were regularly shipped to a con-
tractor laboratory during the period the plan was being followed,
A chain-of~custody log is described in the plan, however, it is inade-
quate. The1 "log" does not indicate the number of sample containers in cus-
tody or the parameters for which the samples are to be analyzed. Whether a
single log may accompany a shipment from several we'Ms or a log must be
filled out for samples from each well is not clear,
In summary, the ground-water sampling and analysis plan reportedly in
effect until mid-1985, was inadequate and did not comply with the TAC
requi rements.
Required by the permit only
-------
Plan Followed After Mid-1985
Like the previous plan, the second plan has no cover date. RES
personnel stated only that it was a revised version of the Part B plan com-
pleted on April 9, 1985 and could not be more specific. Since the plan
describes operating procedures for pumps that. Company records show were
ordered and shipped in late June, an approximate date of mid-1985 is
assigned by Task Force personnel for the purpose of this discussion,
The plan developed and followed after mid-1985 was much improu°d over
the previously described plan. It is divided into six sections with addi-
tional details presented in appendices and provides much more detail on
sample collection, preservation shipment, analytical procedures and chain-
of-custody control. However, it does not fully comply with the TAG require-
ments because it does not (1) incorporate the permit requirements for moni-
toring parameters or frequencies, (2) contain either a list of monitoring
wells or a sampling schedule, (3) present adequate details for the proce-
dures described and (4) specify analytical procedures for all required moni-
toring parameters.
Section I of the plan, which addresses the purpose and scope, states
that the plan is intended to satisfy the TAG provisions for ground-water
monitoring, which are contained in Appendix 1 of the plan. Because moni-
toring requirements in the permit modify some of the TAG provisions (e.g.,
increase the sampling frequency for some parameters), reference should be
made to them. Further, those requirements must be incorporated into the
plan for it to be complete.
The plan does not contain a list or map of the wells composing the
monitoring network, which must also identify those upgradient and downgra-
dient from the waste management units. In the southern portion of the site
where dewatering of the landfill excavation causes a ground-water "sink"
(see section on Site Hydrogeology), the presumed upgradient and downgradiem.
wells are not obvious from a map of the ground-water flow direction.
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75
No sampling schedule is included in the plan, which is especially
important, as new wells have been added to the monitoring network twice
since November 1981 (see section on Monitoring Wells). Therefore, not all
wells are sampled at the same time (i.e., some are in the first year of
monitoring, a quarterly requirement).
Section II and Appendix 2 of the plan address sample collection and
lack several necessary details. The subsection on measuring ground-water
surface elevations provides an adequate step-by-step procedure for deter-
mining depth-to-water, but does not provide a table of wellhead elevations.
This subsection should also include periodic calibration of the markers on
the meter cord.
Similiarly, the subsection on calculation of purge volumes presents an
adequate procedure, but omits a table of total well depths necessary for
the calculation. This section should also include periodic determinations
of well depth. The samplers do not use the procedure described in the plan
to calculate the volume of water; rather, they have a graph where the height
of the water column in 2 and 4-inch-diameter wells is plotted with the cor-
responding volume. Also, no procedure is described for measuring the volume
of water removed during purging.
The plan indicates that each monitoring well is equipped with Well
Wizard purge and sampling pumps. Adequate descriptions of the pumps and
operating procedures are described. However, from the time the plan went
into effect until late September 1985, three of the 25 monitoring wells had
electric submersible pumps (MW-1, 2 and 3) and seven wells (MW-19 through
25) did not have purge pumps. The locations of the pumps, with respect to
the well screens, were not documented either in the plan or elsewhere.
Section II of the plan also specifies filtering of all samples for
metals analysis. In contrast to the plan, Company personnel stated that
samples for TOC are also filtered, but not all samples are filtered. The
decision on whether to filter is based on field observation of the settle-
able solids content of individual samples. Consequently, inconsistent
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76
results are obtained because samples from a particular well may be filtered
one time and not the next. Samples filtered before TQC analysis yield
results for di ssolved rather than total organic carbon, which are required.
by the TAG [335.193(b)(3)], The principal concern is that data from fil-
tered samples may be biased low.
The sampling section also addresses making field measurements for tem-
perature and pH. No procedure is described for making temperature measure-
ments; the result of which is used for adjusting the pH meter. Field
measurements are to be made for pH only if the sample holding time is
expected to exceed 1 hour. However, the storage and preservation require-
ments on Table III-l indicate that the sample should be analyzed immediate!),.
If a field measurement is made, the instrument calibration is to be checked
and four replicate measurements are to be made, No procedures are described
for either calibrating the meter or making the replicate measurements.
Section III of the plan addresses sample labeling, preservation and
shipment. Information to be included on the sample container labels (tags)
is incomplete because parameters to be analyzed and whether the sample is
preserved are omitted. The sample tags being used by the Company during
the Task Force inspection did not contain spaces for some of the informa-
tion specified in the plan. For example, no space was provided on the tag
for the "collector's unique sample identification" (nor does the plan
explain what this is). The tag does, however, include spaces for specify-
ing the analytical parameters.
Sample preservation is to be conducted in accordance with a table in
the plan that identifies the parameter, appropriate sample container, pre-
servative and recommended maximum holding time. No holding time for total
organic halogen is presented and that for fecal coliform should be 6 hours
rather than 24 [40 CFR Part 136.3, Table II], For several parameters, acid
is to be added to the sample until a specified pH is achieved. No proce-
dures are described for determining if the specified pH has been achieved
in the sample.
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77
Section 4 [sic] and Appendix 3 address analytical procedures. The
text states that the analytical procedures used are from one of three iden-
tified references. Appendix 3 contains the detailed methods for each param-
eter, however, it is deficient because none is presented for the following
parameters required by the TAG.
methoxychlor
radium
gross alpha
gross beta
Section V addresses chai'n-of-custody and field records of sample col-
lection. The procedures described are adequate; however, the sampling log
needs to indicate the parameters for which samples were collected and
whether preservatives were used. Section VI addresses State reporting
requirements and forms for the ground-water monitoring data.
MONITORING WELLS
The monitoring well network at the Deer Park facility has changed twice
since November 1981 when the ground-water monitoring provisions of the TAC
became effective. A third change was begun during the Task Force inspection,
which was to be completed by early November. In each of the network con-
figurations, the construction of some we 11s did not comply with TAC require-
ments for isolating the monitored zone [335.192(c)J.
Also, the location and number of wells were not sufficient to ensure
immediate detection of leakage migrating from the waste management area to
the uppermost aquifer, as required by the TAC [335.192(a)(2)].
On September 16, 1985, TWC notified Rollins that monitoring wells MW-1
through 3 and 19 through 25 (10 of the 25 wells in the monitoring network)
were "so completed as to allow potential cross-contamination of several
saturated strata." As a result, TWC would "no longer accept such data [from
these wells] as part of [the] monitoring system" and RES was required to
install single-zone completion wells by November 7, 1985, as replacements.
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78
The old wells were to be plugged and abandoned using state-of-the-art
technology.
The following is a description and evaluation of well construction and
the number and location of wells in the three network configurations,
Well Construction
Information on well construction was derived from boring logs and well
completion and certification reports and is summarized in Table 15.
The first of the monitoring network wells (MW-1, 2 and 3) were instal-
led in 1976. The casing in well MW-2 collapsed twice and the well was
replaced in September 1978 with two new ones. The two new wells, designatec
MW-2A and 28, were to monitor a deep sand unit and shallow "perched" water,
respectively. Well MW-2B, located about 15 feet from MW-2A, is 65 feet
deep and monitors the interval between 40 and 65 feet. Records suggest
that in about 1980, well MW-2B was dropped from the monitoring program and
the distinction between the wells in monitoring reports was dropped. Sub-
sequently, data for well MW-2A were reported only as data from well MW-2,
Discussions of well MW-2^,which follow, refer to MW-2A, unless otherwise
noted.
Records of construction procedures for wells MW-1 and 3 were not avail"
able for review. Well MW-2 was constructed in a borehole drilled by the
mud-rotary method. Wells MW-1 and 3 have PVC casing and MW-2 has a steel
casing; records of screen construction materials and slot sizes for these
wells were not found. These wells are inadequate for the interim status
network because the strata actually being monitored cannot be determined.
The long (51 to 87 feet) sand packs (and screen in MW-1) intersect multiple
ground-water flow zones and may provide conduits for downward contaminant
migration.
Monitoring wells MW-4, 5, 6, 7, 8, 11, 12, 13, 15 and 18 were genera'!!/
constructed in 8-inch diameter boreholes drilled with a hollow-stem auger.
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79
Table 15
INTERIM STATUS MONITORING WELLS
RES DEER PARK FACILITY
Monitori ng
a
b
c
Well
MW- 1
MW- 2
MW- 3
MW- 4
MW- 5
MW- 6
MW- 7
MW- 8
MW- 9C
MW-10C
MW-11
MW-12
MW-13
MW-14C
MW-15
MW-16C
MW-17C
MW-18
MW-19
MW-20
MW-21
MW-22
MW-23
MW-24
MW-25
MW-26
MW-27
MW-28
MW-29
MW-34
MW-35
MW-36
MW-37
MW-38
Strata
Moni tored
3,
2,
2,
b
b
3
1,
3
b
b
2,
3
1,
b
b
b
b
b
2,
2,
2,
2,
2,
2,
2,
2
3,
3
3
3
3
3,
2,
2,
4,5,6,7a
3,4,5
3,4,5
2
3
2
3,4,5
3,4,5
3,4,5
3,4,5
3,4,5
3,4,5
3,4,5
4
4
3
3
Strata underlined are
Date
Installed
05/01/76
09/06/78
05/01/76
05/04/78
05/04/78
05/02/78
05/01/78
05/01/78
12/01/78
12/01/78
04/26/78
04/19/78
04/19/78
12/15/78
02/24/78
12/15/78
12/15/78
04/24/78
11/24/81
11/20/81
11/19/81
11/13/81
11/16/81
11/17/81
11/19/81
01/25/83
01/26/83
01/28/83
01/18/83
05/04/83
05/06/83
04/28/83
05/02/83
05/03/83
Bottom
Screen
(ft,)
127
121
106
40
70
70
42
68
60
60
70
58
JO
60
74
60
60
75
100
102
106
100
99
100
L02
40
69
70
74
65
70
72
70
70
primary ground-water
of Screen
Length
(ft )
59
10
10
20
15
20
26
13
60
60
15
13
15
60
10
60
60
10
10
10
10
10
10
10
10
10
15
15
15
10
10
10
10
10
Sand Pack
uength
(ft, )
59
51
87
•20
15
20
26
13
60
60
15
13
15
60
10
60
60
10
67
58
73
55
64
72
50
16
20
20
20
15
19
15
18
18
Annular
Space
Seal Material
Grout
Grout
Grout
Grout
Grout
Grout
Grout
Grout
Grout
Grout
Grout
Grout
Grout
Grout
Grout.
Grou
Grout
Grout
Grout
Grout,
Grout
Grout
Grout
Grout
Grout
Grout
Grout
Grout
Grout
Grout
Grout
Grout
Grout
Grout
over
over
over
over
over
over
over
over
over
over
over
over
over
over
over
over
bentoni
bentoni
te
te
bentom te
bentoni
te
bentoni te
bentoni te
bentom
bentoni
bentoni
bentom
bentoni
bentoni
bentom
bentopi
bentoni
Dentom
te
te
te
te
te
te
te
te
te
te
contributing formations.
Not specified
Dewatering
dew* taring
walls - Screen length
includes
sand-pack length.
Design drawing for a typical
well has screen length of 24 feet.
Key to Table
Strata Monitored:
I
2
3
4
5
6
•y
Clay,
fill
Clay
Silty
High
Silty
Sandy
Silty
sandy clay
and silty
soils present at many
with sandy
fine sand
plasticity
s and
clay
sand
clay lenses
clay with
locations
Silty and clayey
sandy layers.
and layers
and sajndy silt with some clay zones
clay with clayey sand
lenses
-------
80
The annular space (space between the casing and borehole) above the sand
pack was filled with cement grout. These wells have 4-inch-diameter PVC
casing. The perforated section* of the casing is wrapped "with a polypro-
pylene filter fabric (U.S. Filters, No. 17085-045-72) to prevent silt and
fine sand-size particles from entering the casing". The reported installa-
tion sequence was:
Drill test boring and select zone from which water samples are to
be obtained
Drill second boring to bottom of the targeted monitored zone
Ream boring to 8-inch diameter, us>ng water (of unknown origin)
for dri11 ing fluid
Install PVC casing with perforations at monitored zone
Place sand backfill in monitored zone (method of placement not
speci fied)
Place cement grout up to ground surface (method of placement not
speci fied)
Develop well by pumping formation water until "reasonably1' clear
Screen lengths for this group of wells range from 10 (MW-18) to 26
feet (MW-7) with most being 13 to 20 feet; sand-pack lengths equal screen
lengths. The construction of these wells is marginally adequate for an
interim status network. Future wells should be constructed with manufac-
tured screens instead of perforated casing, no filter fabric, a bentonite
seal above the sand pack, a bentonite/cement or bentonite grout, and an
inert casing material.
Wells MW-9, 10, 14, 16 and 17 were installed as production-type wells
for dewatering the ground around the landfill excavation in the southern
portion of the facility. Records of construction procedures were not found.
Whether the casing was perforated or has a manufactured screen for
water entry is not clear in the 1978 Harding-Lawson report, which con-
tains construction details for these wells.
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81
The wells were all 60 feet deep and had 10-inch diameter steel casing.
They were screened and sand-packed throughout the entire depth. They moni-
tored several water bearing zones and were not sealed above the "monitored
zone", as required by the TAG [335,192(c)] and were not acceptable interim
status monitoring wells as also determined b\' the TWC.
Wells MW-19 through 25 were installed in November 1981, although they
were not included in the monitoring network until March 1985. Records of
construction procedures were not found. The wells have 2-inch-diameter PVC
casing and screens. These wells are about 100 feet deep with 10-foot screens
and have sand-pack lengths ranging from 50 to 73 feet, Consequently, the
wells also monitor multiple saturated strata and may be providing undesirable
hydraulic connections between them.
These connections are potential conduits for contaminated ground water
to reach deeper strata more quickly than through the natural connections.
This potential is the reason the TWC required RES to replace these wells.
Also, three of the wells (MW-21, 23 and 24) sampled during the Task Force
inspection produced very turbid water indicating either improper construc-
tion (sand-pack deficiencies) or development.
Monitoring wells 26 through 29 and 34 through 38* were generally con-
structed in 8 or 9-inch diameter boreholes using a wash-bore drilling method.
Whether mud or other additives were used is not reported in the records
reviewed. The annular space above the sand pack was filled with 3 to 5
feet of bentonite pellets, then backfilled with cement grout to the surface.
These wells were developed using an air-lift device. They have 4-inch PVC
casing and 10-slot (0.010-inch) screens and have locking we"M-head caps.
Screen length is 10 feet except for wells 27, 28 and 29 which have 15-foot
screens. Sand-pack length ranges from 15 to 20 feet.
Wells MW-30 through 33 were not installed.
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82
The construction of wells MW-27 through 29 and 34 through 38 is
marginally adequate for an interim status monitoring network. Future wells,
however, should be constructed with the sand-pack length being about the
same as the screen and complete ^ecords on well installation need to be
kept.
Other construction deficiencies were noted at the existing wells,
including cracked aprons and one that had a plastic bottle for a cap (MW-2);
the others had locking caps. The concrete aprons are supposed to drain
surface water away from the well and prevent it from entering the well bore,
Some wells had no discernible apron. Wells MW-3 and 37 were in snail
depressions and the well head for MW-1 was buried.
Well Locations and Numbers
From November 1981 to approximately mid-1982, the monitoring well net-
work included wells MW-1 through 18 [Figure 8], During the spring of 1982,
wells MW-4, 5, 15 and 18 were abandoned because of drainage improvements at
the southwestern corner of the facility. In January 1983, four monitoring
wells (MW-26 through 29) were constructed to replace MW-4, 5, 18 and 15,
respectively. During the period between spring 1982 and January 1983, the
monitoring well network comprised 14 wells instead of 15, as required by
the State permit.
On March 30, 1983, TWO notified Rollins that wells MW-9, 10, 14, 16
and 17, which were constructed as dewatering wells, were not acceptable as
monitoring wells and needed to be replaced. In May 1983, five wells (MW-34
through 38) were constructed to replace wells MW-17, 16, 14, 10 and 9, res-
pectively. The nine replacements and remaining nine original wells made up
the network from May 1983 to March 1985 [Figure 9],
In March 1985, seven monitoring wells (MW-19 through 25), which were
constructed in November 1981, were added to the network bringing the total
to 25 wells [Figure 10]. However, on September 16, TWC ordered Rollins to
abandon these and three other wells (MW-1, 2 and 3), i
-------
83
JJ
"3
u
00
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84
I
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u
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-------
86
The number and location of wells in three successive networks are
addressed and encompass the following periods:
November 1981 to November 1982
May 1983 to March 1985
March 1985 to September 1985
November 1981 to November 1982 Well Network
According to Texas interim status regulations [335.192(a)(2)], the
number and locations (and depths) of monitoring wells downgradient from
waste management units must be sufficient to ensure that any statistically
significant amounts of hazardous waste or hazardous waste constituents that
migrate to the uppermost aquifer are immediately detected. The monitoring
well network, used from November 1981 until about November 1982, did not
comply with that requirement.
Given the northerly ground-water flow beneath the facility, there are
no monitoring wells downgradient from most of the surface impoundments
[Figure 8] in the northern part of the facility. The two designated down-
gradient wells in that area (MW-2 and 3) are inadequately constructed, as
previously described.
May 1983 to March 1985 Well Network
Although nine new wells were installed between November 1982 and May
1983 as replacements for those abandoned, the monitoring network used from
May 1983 to March 1985 was essentially the same as the previous network.
No new wells were installed in the northern part of the facility. The same
regulated units had no downgradient monitoring wells; therefore, the network
did not comply with TAG requirements.
-------
87
March to September 1985 Well Network
Seven wells installed in November 1981 (MW-19 through 25) were added
to the monitoring well network in March 1985, Many of the downgradient
wells are not located close enough to the waste management area nor are
there a sufficient number to ensure immediate detection of chemicals migrat-
ing from those areas to the uppermost aquifer.
State regulations [335.192(b)] require that downgradient monitoring
wells be installed at the limit of the waste management area. Where facil-
ities have multiple waste management components subject to the groun~ water
monitoring requirements, such as the Deer Park facility, the waste manage-
ment area is described by an imaginary line which circumscribes several
components.
RES considers the site boundary lines as the waste management boundary
lines. Under present precepts," the site boundary lines are too far away
from the waste management units to constitute the circumscribing line, as
described in the regulations. At facilities having only one unit subject
to ground-water monitoring requirements, the waste management area is des-
cribed by the waste boundary. By analogy, the downgradient side of the
circumscribing boundary lines at the Deer Park facility should be the waste
boundaries (with allowance for containment structures), which is where the
wells should be installed.
In the northern portion of the waste management area, the designated
downgradient wells include MW-2, 3, 21, 23, 24 and 25,* Of these, only
MW-2 is close enough to the adjacent waste management unit (lagoon 1000),
Well MW-3 is about 220 feet from the nearest unit (Equalization Basin);
MW-21 is about 130 feet from lagoon 1000; MW-24 is about 220 feet from
scrubber lagoon F-2, and MW-25 is about 260 feet from the nearest unit (F-l).
Upgradient and downgradient wells were designated in monitoring reports
sent to the TWC.
-------
88
Although only about 50 feet from scrubber lagoon F-4, MW-23 is upgradient
from that unit according to the potentiometric contour map presented in the;
revised Ground-Water Monitoring Plan, dated April 9, 1985, submitted for
the Part B permit application. Further, the number of wells is not suffi-
cient to immediately detect leakage from all or major portions of the fol-
lowing units.
Equalization Basin (L-31)
Aeration Basin
Lagoon 32
Lagoon 33
Scrubber Lagoons F-3 and F-4
RES SAMPLE COLLECTION AND HANDLING PROCEDURES
During the inspection, samples were collected from 14 monitoring wells
and four leacha-te collection sumps for analysis by EPA contractor labora-
tories, as discussed in the section on Investigation Methods. At wells
equipped with dedicated pumps, RES personnel made water level measurements,
calculated purge volumes and purged the wells using their standard proce-
dures. At several wells, RES personnel collected samples for PCS analyses.
The procedures observed were generally acceptable, although some improve-
ments need to be made.
The Corporation has a RCRA compliance training program that was report-
edly given at RES Deer Park several months before the inspection; however,
the program does not address ground-water monitoring. Sampling personnel
receive on-the-job training. The sampling team comprises a coordinator and
any of four laboratory technicians. The RES sampling procedures are des-
cHbed and assessed in the following.
Water Level Measurements
At the wellhead, the first step in collecting samples is to measure
depth to water using an electric water level indicator (Powers Well Sounder
-------
89
The water level indicator consists of a reel with cable and sensor enclosed
in a metal box equipped with ammeter and battery power supply in the lid,
A two-conductor, extension-cord-type cable connects the ammeter to the
sensor. The cord had several spherical le?d weights attached to it just
above the sensor. When the box lid is opened, a mercury switch closes and
the meter is activated. The sensor and cable are pulled from the reel,
then lowered into the well.
Wells having dedicated Well Wizard pumps have a wellhead assembly from
which the pumps are suspended. The wellhead assembly has an access port
through which the water level sensor and cord are lowered. Water levels
are measured with reference to the top of the access port, The surveyed
reference point at each well is the top of casing; therefore, a correction
must be made for the height of the access port above the top of casing.
This height was measured and correction was made during the Task Force
inspection, but had not been done previously.
The cord, which was marked in sequential 5-foot increments, was lowered
into the well until the sensor reached the water, as indicated by deflection
of the ammeter needle. The cord was then slowly raised and lowered until
the exact point at which the sensor made contact was determined. The cord
was then pinched by the sampler adjacent to the access port lip and the
distance from the bottom of his fingers to the next higher cord marker was
measured with a measuring tape. Depth to water is calculated by subtract-
ing the reading made with the measuring tape from the cord marker value.
Following the measurement, the lower portion of the cord and the sensor
are cleaned by the following procedure. *
1. Washed in a container with a soap and water solution
2. Rinsed in a container of tap water
3. Sprayed with distilled water
4. Sensor-dryed with a packaged paper towel
Tap water in the rinse container is changed after every two wells,
-------
90
The depth indicator's cord (with side-by-side conductors) was twisted,
which effectively shortened the length, and was probably yielding inaccurate
depths to water. The cord needs to be replaced with a coaxial cable to
eliminate this problem. Also, the correction factor for the access port
elevation should be accurately determined for each well. The *ells should
be periodically checked for total depth and immiscible fluids. Otherwise,
the water level measurement and equipment decontamination procedures are
adequate.
Purging
The volume of water in the casing is determined using the depth to
water measurement, total well depth and casing diameter. Total well depth
data usually came from a table dated August 22, 1985, which presented total
casing length and was derived from construction records. When RES personnel
forgot to bring the table, they used information from a plastic placard
attached'to the protective steel frame at each well.
The plastic placard contained the well number, construction date,
screened interval, well elevation and well depth below the ground surface.
The well depth on the placard does not include the above-ground casing length
(usually about 3 feet) as does the August table. When the placard well
depth was used, the casing stick-up length was not accounted for by RES
personnel.
Once the height of the water column was determined, RES personnel usec
a graph, where column height had been plotted with volumes for 2 and 4-incf
diameter wells, to determine the water column volume. The volume of water
in the casing was then used to compute purge volumes by multiplying by three.
Purge water was discharged into 55 and 85-gallon drums. The purge volume
was calculated using the liquid height in the drums, measured directly in
those with open-tops or estimating it in those with closed tops (by tapping
or feeling the side) and the drum dimensions.
-------
91
Drums containing purge water had a sample container label placed on
them indicating the source well. The purge water was later disposed of in
the onsite wastewater treatment system.
The purging procedures are marginally adequate. They need to be
improved through consistent procedures for calculating purge volumes and
more accurate methods for measuring the volume purged into closed-top drums.
Sample Collection
Wells sampled by RES personnel during the inspection were equipped
with Well Wizard pumps and purge and sampling pumps, as previously described.
Electric submersible pumps were removed from wells MW-1, 2 and 3 before the
Task Force inspection, as part of abandonment procedures required by the
State. A recent study indicates that submersible centrifugal pumps, such
as those in the wells at the Deer Park facility, cause sample alteration as
a result of a partial vacuum developed by the impellers.4 Heat produced as
a result of friction between the water and the impeller can increase the
temperature of water passing through the pump.* During another Task Force
inspection, foaming was observed in submersible pump discharges and small
bubbles were entrained in the volatile organics sample.5
The principal effect is degassing of the samples, which may alter
levels of parameters such as volatile organics, total organic halogen, total
organic carbon, pH, alkalinity and others. Consequently, previous data for
samples collected from these three wells may be biased because of the pumps
used.
The 2-inch-diameter wells (MW-19 through 25) were equipped with only
sampling pumps; however, these were removed from the wells to be sampled on
the first day of the inspection to allow use of the interface probe in these
Average temperature increases of 14% were reported in the cited reference,
-------
92
wells. The pumps were not replaced because the wells were also to be aban-
doned; they were sampled with EPA-supplied pumps.
The nurge pumps (Model HR 4500) have stainless steel bodies and PVC
plastic assemblies. The sampling pumps (Model T 1200) have stainless steel
®
bodies and Teflon assemblies. In low yielding wells, the purge pump is
located beneath the sampling pump and in high yielding wells, it is above.
The pumps were powered by a small portable air compressor driven by a
3-horse-power gasoline engine. The compressor/engine was positioned down
or cross-wind during purging and sample colleciton.
Following the purge, the sampling pump is activated and cycled 10 time;
before samples are collected to clear stagnant water from the pump. The
sample containers are placed on ice in an insulated cooler. No preserva-
tives are added to samples and no field measurements are made on them, such
as for pH. Sample logs are completed and the samples are taken to the
onsite laboratory. Copies of the logs were provided to Task Force personrie .
The observed sample collection and documentation procedures were ade-
quate. However, the log of sample collection needs to be modified to
include a list of parameters for which samples are collected and whether
preservatives were added.
Shipping and Chain-of-Custody
Samples going to the RES contractor laboratory, NUS Corporation in
Clear Lake, Texas, were placed in ice chests on ice and transported by car
on the day of collection. A chain-of-custody form accompanies each shipment.
Copies of the chain-of-custody forms for samples collected during the inspec-
tion were provided to Task Force personnel. The shipping and custody pro-
cedures are adequate.
Talfon is a registered and will be shown hereafter without
-------
93
SAMPLE ANALYSIS AND DATA QUALITY EVALUATION
This section provides an evaluation of the quality and completeness of
interim status ground-water monitoring data gathered by Rollins between
November 1981 and October 1985. Analytical procedures for ground-water
samples and data quality were evaluated through laboratory inspections and
review of documents containing the required monitoring data. The onsite
laboratory and contractor laboratory doing required analyses for Rollins
were inspected in October 1985, The evaluations involved reviewing labora-
tory operating and analytical procedures, internal data reports, raw data
and quality control records; interviewing key laboratory personnel; and
inspecting laboratory facilities and analytical equipment.
The evaluation revealed•that the monitoring of wells existing before
November 1981 has, for the most part, followed the permit for sampling fre-
quency and analytical parameters rather than the TAG regulations, which are
different. Table 16 compares regulations and permit monitoring requirements
to the monitoring actually conducted. The first part of the table lists
requirements for quarterly monitoring by RES during the first year with the
sampling or reporting dates for three well groupings; the second part pro-
vides information on semi-annual monitoring.
No quarterly monitoring, pursuant to the TAG interim status require-
ments [335.193(c)], has been conducted for the monitoring network wells
existing in November 1981. The permit only required quarterly monitoring
of new wells (constructed after September 1981). Quarterly monitoring was
conducted between May 1983 and April 1984 for new wells incorporated into
the monitoring network. In March 1985, quarterly monitoring was initiated
for the second group of new wells. Table 16 also indicates when single and
quadruplicate measurements are required for upgradient and downgradient
wells and what type of measurements were made for the different parameter
groupings. Further, the table indicates where data could not be found in
the documents examined.
-------
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96
Since 1981, ground-water samples have been analyzed at the Rollins
onsite laboratory for pH, conductance, TOC, metals, PCBs and other conven-
tional parameters (e.g., chloride, sulfate, phenols, IDS). A Rollins con--
tractor laboratory, NUS Corporation in Clear Lake, Texas, has analyzed
samples for TOX, fluoride and organic constituents. At times, NUS has also
determined TOC and nitrate.
Much of the reported data are unreliable, biased or inadequate due to
sample handling, laboratory or reporting methods. Although present methods
are improved over past methods, major inadequacies still exist, as discussed
below.
Initial Monitoring Well Network (November 1981 to November 1982)
The TAC [335.193(c)] requires quarterly monitoring for the first
(initial) year of all wells to establish background concentrations or values.
The quarterly"monitoring must include analysis of well samples for the
indicators of ground-water contamination, ground-water quality parameters
and the drinking water supply parameters. The quarterly monitoring of the
upgradient wells must include quadruplicate measurements for the parameters
used as indicators of ground-water contamination (pH, specific conductance,
TOC and TOX).
After the first year, each well must be sampled at least semi-annually
and samples from both upgradient and downgradient wells must be analyzed in
quadruplicate for the indicators of ground-water contamination. Annually,
each well must be sampled and analyzed for the ground-water quality param-
eters. The permit, however, requires semi-annual monitoring for these
parameters.
The initial year of quarterly monitoring was not conducted. Rollins
started semi-annual monitoring with reports produced in May and November
1982. As indicated in Table 17, quadruplicate measurements were not obtained
for the indicator parameters and total organic nitrogen was not determined.
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97
The analysis plan indicates that the sample preservation procedures in
"Methods for Chemical Analysis of Water and Wastes" (EPA 600/4-79-20) were
to be followed. However, Company personnel reported that samples collected
for phenol, total organic carbon (TOC), iron, manganese and sodium were not
preserved. The phenol samples should have been preserved with phosphoric
acid and cupric sulfate. Samples collected for TOC should have been acidi-
fied to a pH of less than 2 with sulfuric acid. Samples collected for iron,
manganese and sodium analyses were not acidified and were filtered prior to
analysis. Because the samples were not preserved after filtration, the
results would be expected to be biased low even for dissolved concentrations.
The total organic halogen (TOX) values are probably biased low. The
TOX levels are often very large. Literature published by the instrument
manufacturer and experience indicate that the instrument used for TOX
analysis underestimates concentrations when they exceed about 300 ug/2.
TOC concentrations were determined with a method that was inappropriate
for the organic carbon levels present in the samples. The organic carbon
was calculated from the difference between total carbon and inorganic carbon
concentrations. When the inorganic carbon makes up most of the total carbon,
as is the case of samples from Rollins, the analysis variability becomes a
significant factor and results in large systematic errors. TOC should have
been determined by measuring nonpurgeable organic carbon and purgeable
organic carbon. Bias is evident in the data between samplings for a well.
Most TOC values for the November 1982 samples are greater than the May 1982
sample values. The bias is substantial". For example, the TOC value for
the May 1982 sample for well MW-14 was 1 mg/£ while in November a TOC value
of 14 mg/£ was reported.
The conductance and total dissolved solids (IDS) values often do not
correlate. The ratio of TDS to conductance should be similar for a partic-
ular well. However, comparison of the ratios for the two semi-annual sam-
plings for many of the wells are discordant. The TDS to conductance ratio
for the May sample for well MW-17 was 0.3, while the November sample ratio
was 0.8. Little change was observed in conductance and the major ion values
between samplings, which indicates that the TDS values are in error.
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98
Second Monitoring Well Network (May 1983 to March 1985)
The second ground-water well system consisted of nine of the wells of
the first system and nine new wells. The upgradient wells for this system,
as designated in monitoring reports sent to TWC, were MW-11, 12, 29 and
37.* In May 1983, Rollins initiated quarterly monitoring, pursuant to
335.93(c) on only the nine new wells. Quarterly monitoring on wells MW-26
through 29 (installed in January 1983) did not begin within 1 week after
installation, as required by the permit. The older nine wells were not
part of this quarterly monitoring effort and, as discussed above, no prior
quarterly monitoring had been conducted.
The laboratory findings discussed above are also applicable to these
data; except as described below, the methods did not change.
TOX values were reported incorrectly in May 1983 for many of the well
samples. Concentrations were reported one thousand times higher than found
by NUS. For example, NUS found a concentration of 3,025 ug/£ TOX for the
sample from well MW-7 while it was reported to the State as 3,025 mg/£.
Evaluation of the quadruplicate meausrements for TOX indicate a detec-
tion limit of about 50 ug/,2; reported concentrations less than this value
are unreliable. The quadruplicate values varied widely for a given sample.
For example, values ranging from 49 ug/£ to 80 ug/2 were reported for well
MW-12 in May 1983, and a range of 23 M9/£ to 100 ug/2 was reported for well
MW-38 in March 1984.
A ground-water monitoring report submitted to TWC in January 1934 for
samples collected on September 15, 1983, indicated that MW-26 was also
an upgradiant well. However, the report from the contractor labora-
tory to Rollins indicated that the well was downgradient. A similar
ground-water monitoring report containing data for samples collected
in August 1985 indicated that the upgradient wells were MW-12, 13, 29
and 36, All other reports designating the upgradient wells list those
stated in the above text.
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99
The TOC quadruplicate measurement variability indicates that values
below about 5 mg/£ are unreliable. For example, TOC values ranging from
1 mg/£ to 6 mg/£ were reported for well MW-29 in March 1984, The variation
between samplings suggests systematic errors. In December 1983, an average
TOC value of 2 mg/£ was reported for well MW-12 in June 1984 an average TOC
value of 17 mg/£ was reported.
As discussed above for iron, manganese and sodium results, samples
collected for the eight metals on the TAG drinking water parameter list
[Part 335, Appendix II] were filtered before analysis and not acidified,
thereby generating data that would be expected to be ""-^s than dissolved
metals results.
The methods used to determine arsenic and selenium resulted in unreli-
able data. Arsenic and selenium were determined without digestion by
hydride generation atomic absorption spectroscopy. EPA-approved hydride
generation methods require digestion. This practice would probably cause
results to be biased low even if the samples had been properly preserved.
Flame atomic absorption spectroscopy methods have been used for chro-
mium, lead and cadmium determinations. These methods often do not achieve
reliable results near the drinking water limits for these parameters. Nor-
mally, detection limits of 100 to 200 ug/£ for lead and chromium and 10 to
20 -ug/£ for cadmium can be reliably achieved by these methods. This is
reflected in apparently wide data variations for some of the wells. A
chromium concentration of 64 ug/£ was reported for well MW-35 in May 1983
while the two subsequent reported values were reported as <10 ug/£. A lead
concentration of 140 ug/£ was reported for well MW-34 in December 1983,
while the two previous reported values were less than 50 ug/£. A lead value
of 80 ug/£ was reported for three wells (MW-28, 11 and 7) in December 1983.
A cadmium value of 10 ug/£ was reported for well MW-8 in December 1983 while
previous and subsequent reported values were less than 5 ug/£. Furnace
atomic absorption spectroscopy methods are more applicable in establishing
background concentrations and subsequent monitoring of the wells for these
parameters.
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100
Insufficient quality control measures were taken to assure that the
pesticide and herbicide results were reliable. Prior to 1984, no blanks
were analyzed. Duplicates and matrix spikes have never been analyzed.
Further, data was reported with detection limits that were at the drinking
water limits when the analysis methods were capable of achieving detection
limits at least 10 times lower than those reported.
Third Monitoring Well Network (March to September 1985)
Quarterly monitoring was initiated for seven new wells in March 1985,
The first two quarterly monitoring reports (March and July 19?^") were
reviewed. The laboratory findings discussed above are applicable to these
data with one exception. The TOC method changed between the first quarter
sampling and the second. Samples are acidified and purged with nitrogen
gas prior to determination of organic carbon, which results in the loss of
purgeable (volatile) organic carbon. Thus nonpurgeable organic carbon is
actually determined, which is not acceptable because total organic carbon
results are required.
As discussed above, it was suspected that TOX values were biased low
and data obtained in July 1985 demonstrates that a bias does exist. For
example, concentrations of 470 ug/£ trichloroethene, 100 \ig/8, chlorobenzene,
26 ug/£ 1,1-dichloroethane and 13 ug/£ 1,1,2-trichloroethane were reported
for a sample from well MW-26. The calculated TOX from these data is 400
ug/£ while the measured TOX was 290 ug/£.
Finally, RES has been reporting data for total coliform rather than
fecal coliforro, as required by State regulations [335.93(b)(l)].
GROUND-WATER QUALITY ASSESSMENT PROGRAM OUTLINE
The TAG [335.193(a)] requires a facility to prepare, before November 19,
1981, an outline of a ground-water quality assessment program. The outline
must describe a more comprehensive program than the one for routine interim
status monitoring and be capable of determining:
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101
Whether hazardous waste or hazardous waste constituents have
entered the ground water
The rate and extent of migration of hazardous waste or hazardous
waste constituents in the ground water
The concentrations of hazardous waste or hazardous waste constit-
uents in the ground water
Between November 1981 and November 1982, the facility had no such out-
line. In response to a deficiency notice from the Texas Water Commission,
dated October 18, 1982, RES prepared an outline and sent it to the State on
November B. A revised outline was included in the mid-1985 Ground-Water
Sampling and Analysis Plan, previously described. An assessment monitoring
program was required by TWC at the Deer Park facility in 1985 based on a
data review.
On September 16, 1985, TWC notified RES that monitoring data indicated
a "substantial likelihood that hazardous waste or hazardous waste constit-
uents from the facility have entered the uppermost aquifer." As a result,
RES was required to submit a Ground-Water Quality Assessment Plan within 15
days. Further, the notification required RES to install replacements for
wells 1 through 3 and 19 through 25 with wells consistent with interim status
guidelines (constructed to monitor a single zone), TWC and RES personnel
were working out details of the assessment program plan and well installa-
tion during the Task Force inspection.
The following discussion addresses the initial and the revised assess-
ment program outlines. The assessment program plan is not addressed because
it was not completed or implemented until after the Task Force inspection,
Initial Assessment Program Outline
The one-page outline submitted to the TWC in November 1982 [Appendix D,
Part 1] was inadequate. It does not address determining whether hazardous
waste or constituents have entered the ground water (requirement 1, above).
Further, the outline does not address:
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102
Whether or how data triggering assessment would be evaluated to
confirm the apparent contamination
How the apparent source would be determined
Whether or how additional hydrogeologic data would be collected
How the rate and extent of contaminant migration would be
determined
Which aquifer zones would be monitored
How a monitoring plan would be developed and what the projected
sampling frequency would be
Which analyses would be conducted on ground water, surface water
and soil samples to identify contaminants of concern
Analytical methods to be used on samples
How the data would be evaluated to determine if more work is
required or the facility could return to the indicator evaluation
program required by 335.193 and 335.194(b)
Approximate schedules for sampling, analysis, data evaluation and
report preparation
Revised Assessment Program Outline
The revised outline [Appendix D, Part 2], although much improved over
the initial outline, requires further revision to include additional detail:.
The outline specifies that priority pollutant analyses would be con-
ducted on samples from monitoring wells and the suspected source (landfill
leachate or surface impoundment liquids), The priority pollutant list is
incomplete with respect to hazardous waste or constituents potentially pre-
sent in ground water at the site. Finding no priority pollutants in ground
water samples could not be considered conclusive evidence that no hazardous
wastes or constituents were present. A more comprehensive list of analyses
or methods is necessary,
The revised outline indicates that samples would be collected to deter-
mine if leakage were occuring; however, it suggests that only one set would
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103
be collected. One sample set is not adequate for the required determination;
multiple samples are necessary to verify findings and conclusions. The
outline needs to specify how a monitoring plan would be developed and what
the projected sampling schedule would be. It should also indicate an approxv
mate schedule for data evaluation and report preparation.
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GROUND-WATER MONITORING PROGRAM PROPOSED FOR FINAL PERMIT
In August 1984, RES submitted a RCRA Part B permit application to EPA
and TWC. Texas determined that the initial application was incomplete and
sent comments to the Company on Septemb^.* 24 [Appendix £]. On November 20,
a revised Part B was submitted which contained an updated ground-water
sampling and analysis plan (monitoring plan). A second revision to the
Part B monitoring plan dated April 9, 1985 was also submitted to TWC.
On September 27, TWC sent a letter to RES outlining deficiencies in
the revised Part B, including those in the April 9 monitoring plan [Appen-
dix E, Part 2]. Task Force personnel concur with the TWC deficiencies noted
in the plan and found others,
The April 9 monitoring plan outlines a detection monitoring program,
pursuant to the TAC (335.464), for the uppermost aquifer and describes the
proposed monitoring well network and sample collection, analysis and data
evaluation procedures.
Because the facility was in assessment during the inspection, the pro-
posed detection monitoring program may not be appropriate, Instead, a com-
pliance monitoring (335.465) and/or a corrective (335,466) action program
may be required by the final permit. Based on the State notices of defici-
ency, the number of wells in the final program will be greater than that
indicated in the Part B monitoring program. These issues will be resolved
by the State upon completion of the assessment program studies. The follow-
ing presents a general description of the April 9 plan and other deficiencies
in the monitoring well network and sample collection and analysis procedures.
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PROPOSED MONITORING WELL NETWORK
The TAG requires ground-water monitoring ir> the uppermost aquifer
beneath the regulated units at the point of compliance* (335.461 and related
provisions). The plan inadequately defines the uppermost aquifer by not
including hydraulically connected aquifers and ignores shallower water-
bearing zones that would yield significant water to monitoring wells. Con-
sequently, the well network proposed for monitoring the "uppermost aquifer"
is categorically inadequate because additional water-bearing zones need to
be monitored, as indicated in the sections on Site Hydrogeology and Monitor-
ing Data Analysis for Indications of Waste Release.
The monitoring plan defines the uppermost aquifer as the ", . .shallowest
continuous water bearing unit across the site. . .." This definition is
inconsistent with Texas regulations [335.42(a)], which state that the uppermost
aquifer is the "the geologic formation nearest the ground surface that is
an a'quifer, as well as lower aquifers that are hydraulically connected within
the facility's property boundary." An aquifer, according to the TAG, is "a
geologic formation or group of formations, or part of a formation capable
of yielding a significant amount of ground water to wells or springs."
The point of compliance is not clearly defined in the April 9 proposed
monitoring plan. A topographic map showing the location of the point of
compliance is supposed to be provided with the application [341.180(4), at
s«g.]. No such map was provided or referenced in the plan. A "definition"
is presented on page 11, where it states "The new plan essentially calls
for the entire waste management area to be circled by a series of regularly
spaced ground-water monitoring wells (i.e., point of compliance)." The
inference is that the point of compliance is defined by a line passing
TAG defines the point of compliance as the "vertical surface located
at the hydraulically dowigradient limit of the vasts management area
that extends doum to the uppermost aquifer underlying the regulated
units".
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106
through the locations of proposed monitoring wells [Figure 11], which is
essentially the site boundary.
State regulations [335.461] define the point of compliance as a vertical
surface located at the hydraulically downgradient limit of the area where
waste will be placed during the active life of the regulated unit plus the
area occupied by any containment structure. The reason the point of com-
pliance is so far north of the boundary of the proposed landfill is neither
apparent nor explained in the plan.
The plan proposes a 25-well network around the waste management area
which will ultimately consist of one Targe landfill. Because of the subsur-
face hydrology of the site, the well network is subdivided into northern
and southern sections, each having a respective set of upgradient and down-
gradient wells. In the southern section, dewatering of the landfill excava--
tion created a ground-water sink in the southern half of the site, thereby
creating a different flow regime than* in the unaffected northern half
[Figures 6 and 7]. Task Force personnel concur with the sectioning of the
waste management area delineations.
The 25-well network will comprise 13 from the existing network and 12
installed as replacements for older ones. The description of abandonment
procedures for the w*lls baing replaced is incomplete. More detail is
necessary on how the casing and sand pack would be removed. Specifications
for the bentonite/grout mixture used to backfill the hole and details of
emplacement are necessary in order to evaluate the adequacy of the proposal.
Construction details for the replacement wells are also incomplete.
Mud rotary is an acceptable method; however,, water should be tried as the
initial fluid and mud added only if necessary. Also, the type of mud and
any additives used should be specified. The method and rationale for
selecting the screen slot and sand pack sizes needs to be stated in the
text. Details on how the casing, sand pack and grout will be implaced neec
to be included. The use of PVC casing is not recommended by the Task Force
because of absorption/desorption problems with some hazardous waste
constituents.
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07
3
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108
In the southern section of the waste management area, four upgradient.
wells, two on the northern side and two on the southern side, and eight
downgradient wells are proposed. Three shallow wells from the previous
network (MW-7, 13 and 26) are also proposed; howeve^, the plan states that
the analytical results will not be subject to the required [335.463(8)]
statistical data comparisons. Texas regulations do not provide for such
exceptions. Notwithstanding the requirement, the plan does not address use
of data from the three wells, only that they will be reported to the State.
In the northern section of the waste management area, 10 monitoring
wells are proposed, including two upgradient and eight downgradient. The
locations of two of the "downgradient" wells (MW-45 and 4-6) are clearly
inadequate because they are about 300 feet from, instead of at, the point,
of compliance, as defined in and required by 335.461.
Four of the "downgradient" wells (MW-46 through 49) may not be down-
gradient from the waste management area. The water-table contour map of
the northern area (Figure 4 in the plan) has no reliable data points between
the eastern and western boundaries to suggest northeasterly flow toward the
four wells. The monitoring plan should use past water level elevation data
to indicate whether there are seasonal variations in flow directions and
illustrate interpretations on maps,
SAMPLE COLLECTION AND ANALYSIS
The sample collection and analysis portion of the monitoring plan does
not comply with Texas requirements (335.463), Procedures and equipment for
water level measurements and sample collection are inadequate because they
are not defined for the site and analytical procedures are not presented
for all required monitoring parameters. For example, the plan states that
water level measurements may be made with a fiberglass, plastic or steel
tape, an electric water level indicator [page 31], or an airline, electric
tape or "popper" [page 44]. No procedures are described for the use of
this equipment. Depending on how the devices would be used, some of them
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109
may be acceptable, while others may not. Also, the dedicated Well Wizard
equipment, which has been installed in the monitoring wells, is not
discussed.
Procedures for water level measurements, sampling and documentation
(field logs, tags and chain-of-custody) presented in the interim status
ground-water monitoring plan, are site specific revisions to the Part B
plan. Although not formally submitted as a Part B revision, procedures in
the interim status plan are d« facto replacements for those in the April 9
plan. These procedures are evaluated in the section on Ground-Water Moni-
toring Program During Interim Status. A revised Part B monitoring plan is
expected after the assessment program is completed.
The specific analytical procedures in the April 9 plan do not include
methods for methoxychlor, radium, gross alpha and gross beta, as required
by the TAG [335.463(4)(C)].
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110
EVALUATION OF MONITORING DATA FOR INDICATIONS OF WASTE RELEASE
This section presents an analysis of both Task Force and RES monitor-
ing data regarding indications of apparent leakage from the waste management
units. Analytica" results from and methods used on samples collected by
Task Force personnel are presented in Appendix F.
Task Force data indicate the presence of organic compounds in five of
the 14 wells sampled [Table 17]. Many of the compounds detected in five of
the wells (MW-2, 6, 13, 25 and 26) were also detected in the leachate
samples.
Organic compounds were detected in samples from five other wells
(MW-3, 8, 12, 15 and 18) by EPA and Rollins during monitoring in 1980 and
1981 [Table 18]. Well MW-3 is adjacent to an old landfill (LF-17) and the
other wells are adjacent to the current landfill. Wells MW-8 and 12 are
adjacent to wells MW-7 and 13, respectively, in which hazardous waste
constituents were detected in Task Force samples.
Elevated barium (Ba) concentrations (663 ug/2 for dissolved Ba; 669
jjg/£ for total Ba) were measured in the Task Force sample from well MW-2.
These concentrations were nearly twice the next lower ones measured. Data
from previous samples corroborate this finding, A concentration of
600 M9/£ for total barium was measured by an EPA contractor laboratory in a
sample collected in September 1981.
In a January 20, 1984 monitoring report to the TWC, RES reported
700 ug/£ Ba for a sample collected from MW-2 on December 15, 1983, which
was higher than any other measurement during the round of sampling of the
monitoring wells. However, laboratory records of raw data for these
samples indicate that the 700 ug/£ value is actually for well MW-2B, rather
than well MW-2A for which data is usually reported under the MW-2
designation.*
Se« section on Monitoring Wells,
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Ill
Table 17
ORGANIC COMPOUNDS DETECTED IN TASK FORCE SAMPLES FROM MONITORING WELLS
Well
Compound1
MW-02
MW-06
MW 13
MW-25
MW-26
1,1,1-Trichloroethane2 NC3 ND
1,1,2-Trichloroethane ND ND
1,1-Qichloroethene ND <5,
Trans=l,2-dichloroethene2 ND <5.
Trichloroethene2 ND <5.
Tetrachloroethene2 ND ND
Vinyl chloride2 120. <5,
Benzene2 ND ND
Chlorobenzene2 4000. <5.
1,2,4-Trichlorobenzene2 ND ND
Acrolein2 ND ND
4-Chloroaniline 36. ND
2-Chlorophenol <10. ND
Benzoic acid2 ND ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
<500. ND
ND ND
ND ND
NO 10.
5,60
17,
20.
ND
430.
8.20
ND
110.
ND
• ND
ND
ND
ND
1 Concentrations are reported in |Jsr/2.
2 Compound also detected in leachata samples.
3 ND - not detected.
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112
Table 18
ORGANIC COMPOUNDS PREVIOUSLY DETECTED IN WELL SAMPLES1
Well: MW-2
Date: 9/2/81 8/85
Data Source: RES
Organic Compounds2
2-Chlorophenol 42
Chloroform
D1chlorod1f luorome thane
Butyl benzyl phthalate
Chlorobenzene
1 , 1-0 1 ch 1 oroethy 1 ene
Phenol
1,1,2- !>1 chl oroethane
Tri chl oroethy] ene
Vinyl chloride 38
Well; Mif-2 MW-3
Date: 3/20/80 9/2/81 3/20/80
Data Source; EPA
Organic Compounds2
2-Chlorophenol 110
Chloroform
Butyl benzyl phthalate
b1s(2-Ethylhexyl)phthalate X
Benzene XXX
Chloroform XXX
Methylene chloride X 18 X
Toluene XXX
Chlorobenrene 15000 X
l.l-01chloroethy!en» X
1,2-Dlchloropropane X
Tetrach) oroethy 1 ene X X
Heptachlor X
Phenol
Tr i chl oroethy 1 ene
Vinyl chlorld*
Naphthalene
1,1,1-THchloroethane
1, 1,2, 2- Tetrach 1 oroethane
2,4-Q1n1trophenol
2,4-Oimethylpheno) X
l,2-D1chloroethy!ene X
1,2-Olchloropropane X
2,«,6-Tr1chlorophenol
2,4-Q1cftlorophenol
p-Ch 1 oro-w-cr«so !
Hexach 1 orobenzene
Acenaphthenc
Acenaphthylenv
2-Chloronaphth«lene
4-Chlorophenyl phenyl ether
4-Bromophenyl phenyl ether
Fluorene
Anthracene
Pcntach 1 oropheno 1
1 Data b*M» i* limited because only a (•» f*ll* h»d b*«n laufl
2 All conccntratioiu are in micrvgrmm* p«r llt.tr.
3 Pronmnt but not aUMntiflod ( l»Mt thmn 10 uo/£) .
HW- 12 MW- 13 MW- 18
9/2/81 9/2/81 9/2/81
20
17
12 37
130
MW-8 MVr-12 MW-13 MW-15
9/2/81 9/2/81 9/2/81 9/2/31
X3
X
X
X 13
X XX
X XX
23 X
X 53
X X
<
X
X
>. X
X
X
>;
>;
I'j X
>;
>;
X X
)! X
X
X X
X X
X X
X
X
X
X
X
X
•d for organic coaaoounds o«/or« thm fasJf
MW-26
7/85
100
26
13
470
MW-18
9/2/81
X
X
Fore*
-------
113
The barium concentration in MW-2A for the December 1983 sampling was 3260
|jg/£. This indicates inconsistencies in data reporting procedures and cor-
roborates the elevated Ba concentrations at this location.
RES data indicate high total coliform counts were reported for many of
the wells in June 1984. Well MW-7 was reported to have a coliform count of
greater than 30,000 per 100 milliters (m£); 22,300 per 100 m£ was reported
for well MW-2 and 28,000 per 100 ra£ was reported for well MW-11. Potential
sources of these bacteria were not identified,
RES and Task Force data indicate elevated TOX concentrations (i.e.,
greater than 100 ug/£)* in 14 wells [Table 19] some of which were abandoned
in 1982 and 1983. Elevated TOX concentrations indicate the presence of
halogenated (containing chlorine, bromine or iodine) organic compounds.6 ?
Their presence is significant because most halogenated organics are sus-
pected of being toxic or carcinogenic and they rarely occur in nature,8
The compounds composing the measured TOX were not all identified by
the standard methods used on Task Force samples, nor have they been identi-
fied by Rollins, whose methods are essentially the same. High concentra-
tions of many halogenated organic compounds are present in leachate samples
[Appendix F]. The TOX "indicator" test can detect these compounds at low
levels, where the analytical methods used to identify compounds in the
leachate and well samples may not be sensitive to them.7 8 9 10 Special or
research-type methods may be required to identify the compounds.
The TOX value of 100 pg/£, used as a benchmark for identifying elevated
concentrations, was based on the referenced literature, two data sets
and professional judgment. The first data set included RES data pre-
sented in Table 20, which contains more than 160 values. The lowest
values, which may represent background concentrations, are the 1984
data for the wells monitoring the zone SO to 70 feet deep. Concentra-
tions generally range from less than 10 to about 50 ug/£. Secondly,
literature reviewed contained data for samples collected from 22 water
supply wells in the United States. Concentrations range from 5 to 85
ug/Jl, with an average of 18 ug/£.? The value of LOO ug/£ is, therefore,
considered to be a conservative benchmark concentration.
-------
114
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-------
115
Well MW-2 was installed to monitor ground water adjacent to L-1000,
according to a March 9, 1979 State inspection report. The outward hydraulic
gradient would promote leakage (see section on Waste Management Units).
Organic compounds have been detected in ground-water samples from this well
since at least 1979.* Detection of hazardous waste/constituents in samples
from this well, where the depth interval of the sand-pack is 70 to 121 feet,
suggests substantial downward migration,
WeHl MW-25 is adjacent to (and may be downgradient from) the dewatering/
disposal impoundments for sludge dredged from F-l and F-2 (scrubber water
impoundments). Drums of hazardous waste may also have been buried in this
area.
Other wells having elevated TOX concentrations are (or were) adjacent
to the landfill in the southern portion of the facility. Wells monitoring
shallow ground water all have elevated TOX concentrations, which suggests
(1) widespread contamination, of the shallow zones by hazardous waste con-
stituents and (2) monitoring of this zone is necessary under the final permit
rather than just the zone at the 50 to 70-foot depth proposed in the Part B
submittal. Data from three nests of two wells illustrate these points,
TOX concentrations in samples from paired wells MW-7 and 8, 12 and 13 and
26 and 27 are consistently higher in the shallow well (7, 13 and 26,
respectively).
Some wells, from which samples have been collected for several years,
had significant changes in TOX concentrations. Levels increased in three
wells (MW-1, 26 and 38) during 1985 while those in two wells (MW-7 and 8)
decreased. The increases suggest the arrival of a "plume", whereas the
decreases suggest improving ground-water quality.
Additional work is necessary to identify the specific halogenated
organic compounds being detected by the TOX analyses in their sources.
Phenol iras detected by RES in a sample collected on January 18, 1979
at a concentration of 30 ug/£.
-------
116
Once these compounds are identified, samples from the other wells should be
analyzed for them as TOX concentrations of less than 100 \ng/l in the RES
data may represent analytical error,
-------
REFERENCES
1. Ecology and Environment, Inc., "Sits Inspection Report, Rollins
Environmental Services, Inc. Facility, Deer Park, Texas," prepared for
U.S. EPA Region VI, November 4, 1981
2. Texas Water Development Board, "Analog-Model Studies of Ground-Water
Hydrology in the Houston District, Texas", Report 190, February 1975
3. Olson, Roy E. , and Daniel, David E, , "Measurement of Hydraulic Con-
ductivity of Fine-Grained Soils, University of Texas, Austin,
November 1083.
4. Houghton, R. L. and Berger, M. E.„ May 1984, "Effects of Well-Casing
Composition and Sampling Method on Apparent Duality of Ground Water",
proceedings of the Fourth National Symposium and Exposition on Aquifer
Restoration and Ground-Water Monitoring sponsored by the National Water
Well Association and EPA, pp. 203-213
5. National Enforcement Investigations Center, April 1986, "Ground-Water
Monitoring Evaluation, Chemical Waste Management, Inc., Kettleman Hills
Facility", p. 38, Denver: Environmental Protection Agency,
EPA-330/2/86-003
6. Environmental Protection Agency, 'Test Methods for Evaluating Solid*
Waste", Revision B to SW-846, July 1981
7. Stevens, Alan A.; Dressman, Ronald C. ; Sorrell , R. Kent; and Brass,
Herbert J. ; "TOX, is it the Non-Specific Parameter of the Future?",
EPA-600/D-84-169, June 1984
8. Takahashi, Y, ; Moore, R. T. and Joyce, R.' J. , "Measurement of Total
Organic Halides (TOX) and Purgeafale Organic Hal ides (POX) in Water
Using Carbon Adsorption and Microcoulometric Determination," Chemistry
in Water Reuse, Vol. 2, 1981
9, Riggin, R. M. ; Lucas, S. V,; Lathouse, J. ; Jundaus, G. A. and Wensky,
A. K« » "Development and Evaluation of Methods for Total Organic Hlaide
and Purgeable Organic Halide in Wastewater, EPA-600/4-84-008, June
1984
10. Glaze, William H,; Peyton, Gary R. and Rawley, Richard, "total Organic
Halogen as Water Quality Parameter: Adsorption/Microcoulometric Method",
Environmental Science & Technology, Vol. 11, No. 7, July 1977
-------
APPENDICES
A PERMIT CONDITIONS FOR HAZARD WASTE MANAGEMENT AND GROUND-WATER
MONITORING
B CORRESPONDENCE REGARDING PERMIT CONDITIONS
C GROUND-WATER SAMPLING AND ANALYSIS PLAN IN EFFECT UNTIL MID-1985
D GROUND-WATER QUALITY ASSESSMENT OUTLINES
Part I - Outline- Dated November 9, 198Z |
Part 2 - Outline in Revised Sampling and Analysis Plan (Mid-1985) :
E NOTICE OF DEFICIENCY LETTER ON REVISED PART B GROUND-WATER
SAMPLING AND ANALYSIS PLAN
F ANALYTICAL TECHNIQUES AND RESULTS FOR TASK FORCE SAMPLES
" W:i
-------
-------
APPENDIX A
PERMIT CONDITIONS FOR HAZARD WASTE MANAGEMENT
AND GROUND-WATER MONITORING
-------
A-l
T 005 5 p09 - 3 02 2 0 Q&
PERMIT NO. Q1429
(Corresponds to
NPDES PERMIT NO. TX QQQ5941 )
This permit supersedes and
replaces'Permit No. 01429
TEXAS WATER COMMISSION approved April 9, 1979
Stephen F. Austin State Office Building '
Austin, Texas
PERMIT TO DISPOSE OF WASTES
under provisions of Chapter 26
of the Texas Hater Code
& Article 4477-7, Texas Revised Civil Statutes
Rollins Environmental Services (TX), Incorporated
whose mailing address is
P. 0. Box 609
Deer Park, Texas 77536
is authorized to dispose of wastes from its industrial waste
disposal facilities
located south of Tidal Road, west of State Highway 134 and east
of and adjacent to Tucker Bayou in Deer Park, Harris County,
Texas
to Tucker Bayou; thence to the Houston Ship Channel, Seoment
No. 1006 of the San Jacinto River Basin
*"' h' ".' •• n
SEP 2 4 1981
in accordance with effluent limitations, monitoring requirement's/TDWK
and other conditions set forth herein. This permit is granted
subject to the rules of the Department, the laws of the State of
Texas, and other orders of the Commission.
This permit and the authorizations contained herein shall expire
at midnight, five years after the date of Commission apnroval.
APPROVED, ISSUED, AND EFFECTIVE this 3rd day of September ,
ATTEST ;
-------
A-2
Rollins Environmental Services, Inc. 01429
PART III
OTHER REQUIREMENTS
The following additional limitations apply to outfall No. 001;
Volume; The 30-day average shall not exeed 975,000 gallons per day.
The daily maximum shall not exceed 2,,000,000 gallons per day,
Table 1
Grab Samples
Pollutants Column"!Column 2
Biochemical Oxygen Demand
(5-day), mg/1 45 90
Total Suspended Solids, mg/1 45 90
Total Organic Carbon, mg/1 75 140
Oil and Grease, mg/1 15 30
Phenolics, mg^l 0.1 0.3
Temperature, UF N/A 100
1. Storm runoff that has been segregated from the main waste treatment
system and discharged at points other than outfall Nos. 001 and 002
shall not exceed a concentration of 55 mg/1 total Organic Carbon (TOO
and 15 mg/1 oil and grease when discharged.
2. The permittee shall utilize incineration,, chemical and biological faci I
ities to dispose of materials amenable to these disposal processes.
Residues front these proetsses and those materials not amenable to the
above processes may be disposed of by landfill as authorized herein.
3. Solid Waste Management Authorization:
a. Permittee is authorized to store, process, and dispose of Class
I, II, and III industrial solids wastes in accordance with the
terms and provisions of this permit,, This authorization includes
disposal of materials by use of incineration, chemical, biologica
treatment and landfill facilities.
b. Permitted facilities are limited to:
1. tank farm(s) of 51,1,00 square feet and total waste storage
capacity, within the tank farm(s), not to exceed 2,540,000
gallons.
Sheet B of A Thru H
-------
Rollins environmental Services, Inc. 01429 A-3
PART III
OTHER REQUIREMENTS •
2. one containerized waste storage area of 16,000 square feet
and, within the drum storage area, a total volume of wastes
not to exceed 231,000 gallons (equivalent to 4,200 drums
(55 gallons).
3. waste water treatment tankage and surface impoundments of
not greater than 12,500,000 gallons total capacity.
4. secure class I landfill capacity not greater than 730,000
cubic yards and a maximum active landfill area not to exceed
20,000 square yards at the base of the dike.
5. two mixing pits not to exceed a volume of 3,000 cubic yards each,
c. All facilities shall be designed, constructed, maintained, and
operated to be compliant with the terms of this permit, the TDWR
rules, and in accordance with plans and specifications, except
as modified by the permit, submitted in support of the applications
for Permit No. 01429. Modifications to plans and specifications
following permit approval must conform to the standards established
by this permit and TDWR Rules, and be approved in writing by the
Executive Director prior to construction and operation.
d. Rainfall runoff segregated from active disposal areas is subject
to discharge limitations of this permit.
4. Solid Waste Disposal Facilities; Design and Construction Criteria:
a. All bottoms and sides of landfill cells, mixing pits and liquid
impoundment facilities shall serve as barriers to waste and leachate
movement. As a minimum, barriers shall meet the following:
1) In-place soil liner thickness ^ 4 feet, scarified to a minimum
depth of six (6) inches and recompacted; or
2) Constructed soil liner thickness > 3 feet, recompacted in
lifts not less than six (6) inches nor greater than nine
(9) inches, and scarified to a minimum depth of two (2) inches
prior to placement of the following lift.
3) All compaction to 95% Standard Proctor density at or slightly
above optimum moisture content.
b. Clay-rich materials serving as barriers to waste and leachate
movement shall exhibit the following minimum specifications:
1) Coefficient of permeability £ 1 x 10" cm/sec,
2) Plasticity index >_ 15.
«•
Sheet C of A Thru H
-------
A-4
Rollins Environmental Services, Inc, 01429
PART III
OTHER REQUIREMENTS
3) Liquid limit >. 30.
4) Percent passing no. 200 sieve >_ 30.
c. Inundation of and discharges from active storage, process and
disposal areas shall be prevented. As a minimum, surface water
control facilities shall be constructed of clay-rich material
to a level two (2) feet above grade level, the historical high
hurricane storm-surge tide, or one hundred (100) year flood level,
whichever is the greater elevation, measured nearest the facility
boundary.
d. Landfill facilities shall be designed and constructed to intercept,
collect, and remove On a permanent basis all waste, leachate, and
other liquids, prior to thtir penttration of protective barriers.
e. All waste deposited above-grade shall be confined by permanent
barriers to provide protection at least equivalent to a perimeter
dike constructed of clay-rich soil, described in Provision 4.b., with
an exterior slope of 4:1 (horizontal:vertical), 2:1 interior slope,
eight (8) foot minimum crest width, and erosion protection includirg
a vegetative cover, and concrete lined flumes which direct runoff
from the cap to natural grade elevation.
f. Landfill facilities shall be designed and constructed to provide,
on a permanent basis, monitoring of area ground water quality
horizontally adjacent to and vertically beneath the disposal area.
Dtpth of required monitoring shall not exceed fifty (50) feet
below the deepest excavation* nor be less than twtnty (20) feet
below natural grade level,
g. Permittee shall maintain a minimum of fifteen (15) monitor wells
distributed about the perimeter and along a North-South center
line through the disposal area. Distances between monitor wells
shall not exceed five hundred (500) feet. The Executive Director
may require additional monitoring devices for subsequent landfill
excavations.
5. Operation and Management of Solid Waste Disposal Facilities:
a. Semi-solid and free liquid containing waste materials shall be
mixed with clay-rich soils, flue dust from cement kilns, or other
sorbent approved by the Executive Director prior to their placement
in landfill(s). Direct landfill of such wastes unmixed, or
containers of such wastes, is prohibited.
Sheet D of A Thru H
-------
Rollins Environmental Servict,,, Inc. 01429
A-5
PART III
OTHER REQUIREMENTS
b. Waste materials shall not be deposited In1landfill(s) containing
free-standing liquids. Free-standing liquids shall be removed
to surface retention facilities prior to deposition of additional
waste materials. Liquid wastes may be disposed of:
1) When mixed with a binder such as soil or other sorbent in
accordance with Provision 5.a. above,
2) by incineration, and
3) at a disposal facility authorized to receive such materials,
c. Waste materials which have not been mixed with sorbent materials
shall be covered daily.
d. Waste materials shall be compacted in lifts not greater than six
(6) feet.
e. Solid wastes for which disposal requirements are established by the
federal government pursuent to the Toxic Substances Control Act due
to polychlorinated biphenol (PCB) content when landfilled shall be
segregated and landfilled seperately from other wastes. Such
landfill operations shall be in compliance with applicable federal
requirements.
f. leachate collection systems in open landfill(s) shall be inspected
at least weekly. The opeator shall maintain a log of the inspections
and the data shall be available for review,
g. Accumulated liquid shall be removed before one-half of the leachate
collection reservoir capacity is reached.
h. A minimum two (2) foot freeboard shall be maintained at all times
in open liquid retention facilities,,
i. Monitoring:
1} New ground water monitor wells shall be sampled within one
week of well completion and quarterly for one year in an
attempt to obtain ground water for analysis. Samples shall be
analyzed for iron, calcium, magnesium, sodium, carbonate,
phenols, bicarbonate, sulfate, chloride, fluoride, nitrate, pH,
total dissolved solids, phenolpthalein alkalinity as CaC03,
total alkalinity as CaCO,, specific conductance (micromhos/cm at
25 C), chemical oxygen demand, total organic carbon, total
organic nitrogen, arsenic, barium, cadmium, chromium, copper,
lead, manganese, mercury, nickel, selenium, silver, zinc,
endrin, lindane, methoxychlor, toxaphene, 2,4-D, 2,4,5-TP, total
organic halogens and polychlorinated biphenyls (PCB's).
Sheet E of A Thru H
-------
A-6
Rollins Environmental Services, Inc. 01429
PART III
OTHER REQUIREMENTS
2) Permittee shall notify the local Texas Department of Water
Resources, district office a minimum of one (1) week in advance,
of the date and time of any initial sampling of ground water
monitor wells.
3) Following sampling required by Provision 5.i.1., permittee shall
sample monitor wells senri-annuaTTy"! Samples required by this
provision shall be analyzed for specific conductance, pH, total
organic carbon, total organic nitrogen, chloride, iron,
manganese, phenols, sodium, sulfate, total organic halogen, and
total dissolved solids.
4) All results of sampling and analyses shall be submitted to
the Department not later than sixty (60) days following the
respective sampling.
j. Wastes shall be evaluated for non-compatible characteristics utiliz-
ing chemical analysis or other means as necessary. Non-compatible
wastes shall include those wastes which when mixed in the disposal
operation would produce a material, such as gas or liquid, that
is more toxic than the material prior to mixing. Permittee shall
maintain records demonstrating compliance with this provision.
These records shall be available for review.
k. Non-compatible wastes shall be segregated in storage and disposal
operations. A minimum of four (4) feet of clay-rich materials
as described in Provision 4,b. shall be placed between deposited
non-compatible wastes,~
1. The permittee shall maintain records of landfilling operations
consisting of the location, date, and quantity of each waste
deposited. Records of leachate collection system inspections
and leachate removal shall be maintained and made available for
review.
m« Emissions from this facility must not cause or contribute to a
condition of "air pollution" as defined in Section 1.03 of the
Texas Clean air Act or violate Section 4.01 of the Texas Clean
Air Act, Article 4477°5, V.A.T.S. If the Executive Director of
thi Texas Air Control Board determines that such a condition or
violation occurss the holder shall implement additional abatement
measures as necessary to central or prevent the condition or viola-
tion.
n. All dikes, ditches, tanks, and other structures and equipment shall
be maintained in good functional condition,
Sheet F of A Thru H
-------
Rollins Environmental Services, Inc. 01429
PART III
OTHER REQUIREMENTS •
6, Closure of Solid Waste Management Facilities:
a. Permittee shall secure and maintain in force at all times a bond
or other financial assurance acceptable to the Executive Director
in an amount of $1,946,000 that will provide for proper and adequate
closure of the site at any time as outlined in Provisions 6.b. and
6.c. The bond amount or other financial assurance required shall be
subject to review, alteration and approval by the Executive Director
so as to assure adequate and proper closure. This permit does not
become effective until the permittee obtains a bond or other
financial assurance acceptable to the Executive Director in the
amount above.
b. Permittee shall close areas of the site where wastes materials
have been landfilled to forty-four (44) feet above mean sea level
or six (6) feet below the top of the perimeter dike, which ever is
the lower elevation. Such closure at a minimum shall be in
accordance with Provision 6.d.4., 5. and 6.
c. Site closure shall commence:
1) Upon direction of the Texas Water Commission for violations
of the permit or Department Rules,
2) Upon abandonment of the site, or
3) Upon direction of the Executive Director for failure to secure
and maintain an adequate bond or other financial assurance
as outlined in Provision 6.a.
d. Site Closure shall include the following minimum actions:
1} Removal of all wastes from storage and mixing areas authorized
by Provision 3.b. to open landfill excavation, or off-site
to a facility authorized to receive such wastes,
2) Completion of the perimeter dike surrounding all wastes
deposited above natural grade in the landfill area.
3) Filling the diked landfill area with soil or Class III waste
to an elevation of forty-four (44) feet above mean sea level
or six (6) feet below the top of the perimeter dike, whichever
is the lower elevation.
4) Placement of a minimum four (4) foot clay-rich soil cover
over all areas where wastes have been deposited and grading
of this cover to a crown with a slope of 2S. Cover shall meet
the specifications described in Provisions 4.a. and 4.b.
Sheet G of A Thru H
-------
Rollins Environmental Services, Inc. 01429
PART III
OTHER REQUIREMENTS
5) Placement of a minimum of twelve (12) inches of uncompacted
soil cover over the constructed cover.
6) Establishment and maintenance of a g^ass cover on the uncom-
pacted soil layer and perimeter dike.
7) Installation of rainfall runoff control structures in accordance
with the Provision 4.d.
8) Decontamination of all waste storage and processing facilities.
e. Closure shall be completed within ninety (90) days following commence-
ment of closure.
f. Permittee shall notify the local Texas Department of Water Resources
district office for purposes of a closing inspection, of the date
final closure of any portion of the site commences.
g. Until permit cancellation, permittee shall continue to sample
all ground water monitoring devices according to the following
schedule:
1) quarterly for a full year following final closure.
2) every six (6) months thereafter.
3) Samples shall be analyzed for parameters cited in Provision
5. "L 3., and the results shall be reported as cited in ProvTsion
5.174. above.
h« Leachste collection systems in closed landfill(s) shall be inspected
at least monthly for one (1) year following closure, and thence
quarterly until permit cancellation. The records shall be maintained
for review as cited in Provision 5.f. above.
i. Permittee shall maintain on-site a stockpile of excavated clay-rich
soil as described in Provision 4.b. which is equivalent to not
less than 178,000 cubic yards when 'compacted as required by Provision
4.a.3.
J, Permittee shall maintain on-site a stockpile of excavated topsoil
of not less than 7,100 cubic yards.
Sheet H of A Thru H
-------
Rollins Environmental Services, Inc. 01429 A_9
DEFINITIONS
All definitions contained in Section 26.001 of the Texas Water Code and
Paragraph 502 of the Act shall apply to this permit and are incorporated
therein by reference. Additional definitions of words or phrases used
in this permit arc as follows:
1. The term "Act" means the Federal Water Pollution Control Act, as
amended, Public Law 92-500 (33 USC 1251 et seq) .
2. The term "Environmental Protection Agency" means the U. S. Environ-
mental Protection Agency.
3, The term "Administrator" means the Administrator of the U. S, Environ-
mental Protection Agency,
4, The term "Regional Administrator" means one of the Regional Adminis-
trators of the U. S. Environmental Protection Agency.
5. The term "National Pollutant Discharge Elimination System" (hereinafter
referred to as "NPDES") means the system for issuing, conditioning, and
denying permits for the discharge of pollutants from the point sources
into the navigable waters, the contiguous zone, and the oceans, by the
Administrator of the Environmental Protection Agency pursuant to section
402 of the Federal Water Pollution Control Act, as amended.
6. The term "applicable effluent standards and limitations" means all
State and Federal effluent standards and limitations to which a discharge
is subject under the Act, including, but not limited to, effluent
limitations, standards of performance, toxic effluent standards and
prohibitions, and pretreatment standards.
7, The terra "applicable water quality standards" means all water quality
standards to which a discharge is subject under the Act and which have
been (a) approved or permitted to remain in effect by the Administrator
following submission to him pursuant to Section 303(a) of the Act, or
(b) promulgated by the Administrator pursuant to section 303 (b) or203(c)
of the Act.
8. The term "sewage" means human body wastes and the wastes from toilets
and other receptacles intended to receive or retain body wastes.
9, The term "sewage sludge" shall,mean the solids and precipitates
separated from wastewater by unit processes.
-------
A-10
Rollins Environmental Services, Inc. 01429
10. The term "treatment works" means any devices and systems used in
the storage, treatment, recycling, and reclamation of municipal sewage
or industrial wastes of a liquid nature, to implement section 201. of the
Act, or necessary to recycle or reuse water at the most economical cost
ever the estimated life of the works, including .intercepting sewers
sewage collection systems, pumping, power, and other equipment, and
their appurtenances; extension, improvement, remodeling, additions, a^d
alterations thereof; elements essential to provide a reliable recycled
supply such as standby treatment units and clear well facilities; and
any works, including site acquisition of the land that will be an integral
part of the treatment process or is used for ultimate disposal of residues
resulting from such treatment.
11, The term "grab sample" means an individual sample collected in le;ss
than 15 minutes.
12«, The term "uncontaminated water" means water which has no direct
contact with any product or raw material and which does not. contain a
level of constituents detectably higher than that of the intake water.
13. The term "permitting authority" means the State water quality
control agency or the Environmental Protection Agency, who physically
the permit.
14. Items stamped N.P.D.E.S. REQUIREMENTS ONLY do not apply to this
permit and are retained in this permit to preserve the form and
numbering system of a National Pollutant Discharge Elimination System
permit. The items stamped N.P.D.E.S. REQUIREMENTS ONLY in this permit
were secured from a standard UeS. Environmental Protection Agency permit
format existent in February, 1974, and they may or may not be identical
eo the requirements or conditions of the actual N.P.D.E.S. permit
applicable to the facility covered by this permit. It is necessary to
examine the issued N.P.D.E.S. permit authorizing discharge to determine
the actual N.P.D.E.S. requirements.
15. The term "active landfill area" means that area within the landfill
which has not been closed in accordance with Provision Ill.e.b.
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APPENDIX 8
CORRESPONDENCE REGARDING PERMJT CONDITIONS
-------
-------
Rollif^tnvironmental Services (TXJ Inc.
P 0 Bo, 609, QetrPart, Texat 77536 (7131 479-6001 B<
Decenfcer 3, 1981
Q£Q gl 1981
Mr. Allen Messanger, Permits Section
Texas Dept. of Water Resources
Stephen F. Austin Bldg.
P.O. Box 13087
Capitol Station
Austin, Texas 78711
Dear Allen :
I want to follow up our phone conversation last week with this
formal letter so that you can give me a written response to these
questions for our TDWR Permit File.
My question(s) center around the sampling of ground water monitoring
wells here at our present Deer Park Landfill Facility. Referring
to Part III, sheet E of A thru H, provision 5, i, 1-4-, new monitoring
wells shall be sampled quarterly for one year and thence semi-
annually ; old (presently existing) monitoring wells shall be sampled
semi-annually as we have already sampled these wells monthly and
quarterly since 1979. Have I interpreted these provisions correctly?
Please advise.
Also, regarding provision 5g on sheet H of A thru H in Part III
of our present permit, at that point in time we would be sampling
our monitoring wells semi-annually (every 6 months). Why would
there be the need to revert back to a quarterly sampling frequency
for only one year then back to a semi-annual schedule thereafter?
Please respond once again and advise accordingly.
Thanks for your time regarding this matter
reply to these concerns.
Sincerely Yours,
Rollins Environmental Services (Tx.), Inc.
I await your written
David C. Stang
Project Manager
DCS/dr
J
cc/ 3erry D. Neel, Rollins
Donald C. Matter, Rollins
Michael Khatri , Rollins
Carl Brassaw, Law Engineering
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•ITXAS nri'AKTMi'.NT or wATI-IK. IU.SOUKCLS
1700 N, ('micros Avenue
Austin, Tcx us
,AS WA'ltlK DtiVr.l.OI'MENT HOARD
Louis A. Bccchefl. jr.. Ch.iirm.in
John H. Garret:, Vice Cluirnun
George W. McClokcy
Glen E. Konc\
\V. O. UaiiLston
Lonnic A. "bo" Pilgrim
I Ijrvcy Djvn
December 10, 1981
ri'XAS WAI I II COMMISSION
f-eitx iMcl)i)njlii, (.li.iiriu.m
Dorsey li. Hjrticnun
Lee li, M,
Mr. David C. Stang
Project Manager
Rollins Environmental Services
P.O. Box 609
beer Park, Texa's 77536
[nc,
Dear Mr. Stang:
RE: Commercial Solid
Permit No. 01429
Karris County
tlaste r'anatgement Facility
The follovnng is clarification of ground water Monitoring (requirements
contained in your current TDVIR Permit Number 01429, as you requested in
December 3, 1981 letter.
your
Provision 5i of Part III of the permit requires that new grounq water monitor-
ing wells snail oe sampled quarterly for tne first year of their operation.,
anc semiannually thereafter for the active life of the facility. Presently
existing ground water monitoring wells which were cu...;1oted and sampled during
their first year in accordance with provisions of your TD.vx permit prior to
1961 aniencrnent snail be samp! eel semi annual 1 y v.hile the faci
uncer terms of the current permit.
ity is active,
lihen the facility closes, Part III. Provision 6g, of your permit requires that
ground water monitoring wells must be sampled quarterly for one full year
following closure and then semiannually until permit cancel 1 ati_on, The post-
closure sampling freqjency was not amended in 1931 ana remains valid regardless
of sampling frequency before closure.
Should you have any further questions regarding the terms of your permit,
plpase contact me at AC 512/475-2041.
Sincerely,
\ \3-wJk(i^_
Allen Messenger, Head
Di sposal Faci1i ties Uni t
Sol id V.'aste Section
RLA:wls
cc: TDWR District 7 Office - Deer Park
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-------
APPENDIX C
GROUND-WATER SAMPLING AND ANALYSIS PLAN
IN EFFECT UNTIL MID-1985
-------
-------
Rollins Environmental Services ITXJ Inc.
P 0 8o*609 Deer P irk Texas 77536 I713i 479 6001
Rollins
SAMPLING AND ANALYSIS PLAN FOR
MONITORING WELLS AT RES (TX) INC.
PURPOSE:
Demonstrate the facility's landfill has a low potential for the
migration of hazardous waste constituents from the site. Furthermore,
early detection system for any contamination that may possibly propa-
gate from the landfill.
I. PROCEDURES: ,
1 . WELL PURGING:
All wells should be pumped and sampled at the least - once
•a month. Analysis should include pH , TOC and conductivity.
Any adverse results should be noted and further analysis
determi ned.
2. SAMPLE COLLECTION ACCORDING TO PERMIT REQUIREMENT:
All wells currently semf-annual sampling and analysis accord-
ing to the TDWR Permit 01429, Samples are collected from
each well by an air eductor pump. A 2-3 gal sample must be
taken.
Harris County and TDWR officials should be invited to attend
8-10 days prior to the sampling date. Samples can be col-
lected in clean 1-gal plastic jars. The depth to the water
level should be recorded for each water. (This is not
necessary for reporting requirements). If samples are
collected for PCB and pesticides, the sampler should use
a Hexane rinsed glass bottle.
3. CHAIN OF CUSTODY
The Technician who samples the wells will be responsible for
labeling each sample container and initiating the "Chain of
Custody" form. No seal is required since the sampler and
analyst are usually the same person.
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SAMPLING AND ANALYSIS PLAN FOR Rollins Environmental Services [ju Inc.
MONITORING" WELLS AT RES (IXfTNC.
Page 2
The information required on the container label should read
as follows:
WELL NO,:
DATE:
SAMPLER'S INITIALS:
The Chain of Custody log must; contain the following information:
WELL NO.:
DATE: TIME:
SIGNATURE OF SAMPLER:
SIGNATURE(S) OF PERSONS(S) INCLUDED IN THE
CHAIN OF POSSESSION:
INCLUSIVE DATES OF POSSESSION:
All samples sent to an "out-side" lab must have the above
"Chain of'Custody" with a return request for our records.
For in-house analysis the analytical report form (for Lab
use only) will serve both as Chain of Custody log and final
data report.
4, PRESERVATION:
Normally the analysis is completed for volatile and unstabl*
species on the same day as sampling. In the event that any
of the samples must be stored, refer to the "Sample Preser-
vation" section in "Methods for Chemical Analysis of Water
and Wastes", EPA60Q/4-79-020.
5. ANALYTICAL METHODS:
All analyses are to be performed using methods stated in
procedure manual according to "Methods for Chemical Analysis
of Water". EPA-600/4-79-020, Any questions regarding pro-
cedures should be directed to the Laboratory Supervisor or
Technical Manager,
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SAMPLING AND ANALYSIS PLAN FOR Rollins Environmental Services iw Inc.
MONITORING WELLS AT RES (TX) INC. C-3
Page 3
II. REPORTS:
Semi-annual and annual reports (use forms-TDWR-0910 and 0150)
should be sent to Texas Department fo Water Resources* .at the
address listed on the forms. Copies of the above reports should
be filed in appropriate file (in archives storage). An additional
copy should be sent to the locar TOUR Director* in. Deer Park,
(Check with Technical Secretary for Names of these individuals).
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-------
APPENDIX D
GROUND-WATER QUALITY ASSESSMENT OUTLINES
Part 1 - Outline Dated November 9, 1982
Part 2 - Outline in Revised Sampling and Analysis Plan
(Mid-1985)
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R
or*
flu I III tj ..,'tfiluillnUiiLlJllJCit/iUu^:'^ /' iu
/. c.**^,
Rollins
*•
N o v e m D e r 9 , 1952
Mr. MertonJ. Coloton * C- C>5 - ? -' -. "J
Supervisor, District 7
T e x ci b D e p d r L 1111; u t o 1 Water Resources
4301 Center Street
Deer Park, Texas 77536
Dear Mr. Coloton:
In response to v o u r letter dated October 18, i 9 ••? 2 , Rollins
Environmental Services ( T X ) Inc. has t a K. e n the following
actions :
1 )
As an a t t a c n ~ ^ r, t
water Assessment
Better is t r, <
as specified
oTe 3 3 ") , I 9 4 .
Texas Administration
understanding that a Grounc\iCer 0 u a 1 i '. v Assess
m e nt Plan is not required, jat an outline as
attacned is,
requirement and s no;
12, 1982.
t h e
Sincerely,
Rollins Environmental Services (TX)
Donald C . Matter-
Plant Manager
D C M / c m
attachment
NOV 10 1982
DEFT, OF
WATER RESOURCES
DISTRICT 7
-------
i its it/1 tu _/ik/l tjl ii l lUi llUl U6' i ' I
D-2
2206 Battleground Road, Deer Park, Tx, 77536
[, Estimate the Extent of the Contamination
A. Model the Region of Flow
3. Install Additional Selected Piezometer and/or Monitoring Weils
C. Collect Additional Surface Water Samples
D. Collect Adaitionai Water Samples
II. Determine any Change in Contaminate Concentration
t
A. Perform Additional Groundwater Quality Tests
3. Perform Additional Surface Water Quality Tests
C. Perform Attenuation Studies if Necessary
D, Perform Absorption Calculations if Necessarv
E. Perform a Dispersion Model if Necessary
Determine the Outer L'units of the Contaminate n Plume
A. Install Additional Piezometers
3. Install Additional Gbsenation Wells
C, Collect Additional Groundwater Samples
D. Perform "Additional Groundwater Tests
£. Calibrate and Verify the Horizontal Extent 'rcn the Effected ?h=sa
F. Produce a Suite of Groundwater Contour Maps and Grour.awate.r Qua.ity
Maps on Each Selected Indicator Parameter; Indicate tne Extent of
the Contaminate Movement
This Grour^water Assessment Outline is in compliance with the Texas Department
of Water Resources(Permit No. 01^29) Texas Administration Code 335.194 as
required by RCRA.
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D-3
GROUNDWATER QUALITY ASSESSMENT PLAN OUTLINE
31 TAG 335.194(a)
Rollins Environmental Services (TX) Inc.
Deer Park, Texas
Permit No. 0)429
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p_4 I. INTRODUCTION
-7 The following outlines the Groundwater Quality Assessment; Plan lior th<
RES (TX) Inc. Deer Park facility (Permit No. 01429). The outline ha
been prepared in accordance with the requirements of 31 TAG 335.L94(c)
RES (TX) Inc. will use this outline to prepare a Groundwater Qualit
Assessment Plan as required by 31 TAG 194(d)(2).
II. GROUNDWATER QUALITY ASSESSMENT PROCEDURE
A. Hazardous Waste and Hazardous "aste Constituent Identification
1. Sample and, analyze groundwater from the down gradient vell(s
which indicate a statistically significant variation in ground
water quality. Sample for priority pollutants in accordance wit
the Sampling and Analysts Plan. As necessary, modify th
Sampling and Analysis Plan to include required analytica
procedures.
2. If II.A.I. indicates that hazardous waste or hazardous wast
constituents are in the uppermost aquifer, sample and analyz
each adjacent monitoring well for identified constituents.
3. If II.A.I. and II.A.2. indicate hazardous waste or hazardou
waste constituents are in the uppermost aquifer, locate th
nearest hazardous waste land disposal unit and obtain a sample
If the unit'^a landfill cell, sample the leachate collection pipe
If the unit is a surface impoundment, sample the surface impound
ment contents. Analyze the sample for parameter(s) identified i
II,A.I. and II.A.2.
4. If II.A.I. does not indicate the presence of hazardous waste o
hazardous waste constituents in the uppermost aquifer, prepar
and submit a report as described in II.C. and reinstate th
indicator evaluation program required by 31 TAG 335.193 an
19A(b).
5. If II.A.i. and II.A,2. indicate hazardous waste or hasardou
waste constituents have entered the uppermost aquifer, sample an
analyze the groundwater from the affected monitoring we .Is fo
detectable hazardous waste or hazardous waste constituents on
quarterly basis after the determination required by 31 TA
335.194(d)(4).
B. Rate, Extent and Concentration Determinations.
1. Corings and Monitoring Well Installation, Sampling and Analysis
a. Core and continuously sample surficial clay strata to withi
five feet of uppermost aquifer. Then take precaution
necessary to prevent vertical contaminant migration an
complete coring through the uppermost aquifer.
;
-------
D-5
(1) Conduct at least two corings around affected well(s).
One coring should be located as close as practicable to
the hazardous waste land disposal unit nearest the
affected well(s). One coring should be located as close
as practicable to the property boundary. Additional
corings may be necessary during this initial coring
1 procedure.
(2) A qualified geologist or geotechnical engineer will
classify all encountered soils and will identify any
significant thicknesses (>2 feet) of relatively perme-
able soils. Retain and preserve all core samples.
(3) Install monitoring well clusters in each coring. Screen
interval and number will be based on the information
obtained in II.B.l., above. Determine water levels in
each screened interval.
(4) If corings/monitoring wells yield sufficient water for
sampling and analysis, obtain sample.
(5) If corings/monitoring wells do not yield sufficient
water for sampling and analysis within one week, use
procedure approved by TWC staff to extract pore water
from applicable interval of the coring.
(6) Analyze groundwater/pore water from each interval for
hazardous waste or hazardous waste constituents identi-
fied in II.A.1.
(7) Determine water levels in each screened interval on
at-time intervals, based on monitoring well completion
data, until a constant water level is obtained for three
consecutive measurements. The frequency of water level
measurements should be adjusted, if it is possible, to
conduct rising head tests.
(8) The transmissivity and hydraulic conductivity of each
screened interval should be determined using appropriate
test methods after a' constant water level [II.B,1,a.(7)]
is established.
b. Determine water/leachate levels in adjacent hazardous waste
land disposal units.
(1) Landfill Cells - If affected monitoring well(s) is
adjacent to a hazardous waste landfill cell, install
piezometer(s) in cell. Determine water levels in
leachate collection pipe(s) and piezometer(s).
Additional water level determinations should be made at
intervals which allow comparisons with water level
measurements made in corings/monitoring well.
-2-
-------
D-6 (2) Surface Impoundments - If affected monitoring well(s) is
adjacent to a hazardous waste surface impoundment(s),
determine water level in the surface impoundments).
Review surface impoundment design information. If
design provides for a constant water level, then no
additional measurements are required. If the surface
impoundment is designed for variable water levels, then
additional water level determinations will be made which
correlate with water level determinations in the
i corings/monitoring wells.
C. Data Reduction and Reporting
1. Use water level measurements obtained above in combination with
other available data to determine horizontal and vertical compo-
nents of flow in each screened interval above the uppermost
aquifer. Determine the horizontal component of flow in the
uppermost aquifer.
2. Use chemical analytical data to determine concentration gradients
in each screened interval and between each screened interval,
3. Prepare the report required by 31 TAG 335.194(d)(5) and submit to
the TWC within 15 days of completion of data reduction described
above.
i
DC Additional Assessment Procedures
1. Install additional corings/monitoring wells as necessary to
finalize the results of the activities described above. The need
for and location of additional corings and monitoring wells will
be based on guidance from TWC staff.
2, Report results obtained by additional assessment procedures
within 15 days of data evaluation to the TWC staff.
3= If the groundwater quality assessment demonstrates that hazardous
waste or hazardous waste constituents have not entered the
uppermost aquifer, reinstate the indicator evaluation program
required by 31 TAG 335.193 and 31 TAG 335.194(b).
E. Additional Assessment Requirements
I
If activities described in II.A. and II.B. determine that hazardous
waste or hazardous waste constituents have entered the uppermost
aquifer, resampie monitoring wells on a quarterly basis with RCRA
Part A issuance or with full facility closure. These data will be
reduced as described in II.G,
-3-
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APPENDIX E
NOTICE OF DEFICIENCY LETTER ON REVISED PART 8
GROUND-WATER SAMPLING AND ANALYSIS PLAN
-------
TEXAS WATER COMMISSION
I'.iul Hopkins, I. hiiirm.in
Kolph Kommij, Commissioner
John O Houi bins. Commissioner
- E-J •
. Cri.n
Larry R. Sovvard, Executive Director
Mary Ann Hefner, Chief Clerk
James K. Rourke, Jr., General Counse!
Mr. Tracy Hollister
Plane Manager
Rollins Environmental Services (Tx.), Inc.
P. 0. Box 609
Deer Park, Texas 77536
Dear Mr. Hollister:
CERTIFIED MAIL
Re: Rollins Environmental Services (TX) Inc. - Deer Park
Amendment to Consolidated Permit Nq. 01429
Proposed Hacardous Waste Permit No. HW-50089
Harris County
We have completed a technical review of the above-referenced application. Our
review indicates that insufficient information was presented to demonstrate
compliance with Title 31 Texas Administrative Code (TAG) Sections 341.153 and
341.180 and Title 40 of the Code of Federal Regulations (CFR) Parts 270.13-
270.21. The deficiencies in the application are detailed below and follow the
format of the Part A and Part B application forms and instructions, which you
will find enclosed:
PART A
Section III. Wastes and Waste Management
III.A.2.:
(1) In order to complete Table III-l, Rollins Environmental Services (TX),
Inc., hereinafter referred to as RES (TX), should also list all
mixtures containing any hazardous waste which are presently or proposed
to be handled at your facility. However, because it is infeasible to
anticipate and list every permutation of a waste mixture that you may
handle at your facility, RES (TX) should list the major categories of
wastes which you intend to handle. A rationale for the waste categories
selected should also be provided.
(2) For clarification purposes, please provide a list of hazardous wastes
which will not be accepted at your facility as an attachment to Table
111-1.
I1I.B.1.;
For each waste category listed in Table III-l, complete a copy of the
summary sheet shown in Table III-2. Be sure to indicate all the facility
components used for storage/processing/disposal of each waste category by
entering the number of such facility components managing the waste.
n a,. Hftt7 CiiDitol
* Austin TVxas7R7U • Area <~TdpSI?/'W 7H'»fl
-------
E-2
Mr. Tracy Hollister
Page 22
September 20. 1985
(3) Qualifications of Che field inspector who will be in charge
of identifying transmissive layers based on information from
boring logs and field inspection of the landfill excavation;
(4) The procedure for determining the extent of each identified
cram,missive layer exposed by the landfill excavation; ""
(5) The procedure for excavating a sufficient area to ensure a
minimum of a six (6) foot separation distance between the
containment barrier and all portions of each major transmia-
aive layer;
(6) The construction and quality control procedures to be
followed and equipment to be used_to ensure a hydraulic
conductivity of less than 1 x 10~ cm/sec for the backfilled
material; and
(7) Ac evaluation of the effectiveness and the feasibility of
constructing a slurry wall to seal off all minor transmiasiv
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E-3
Mr. Tracy Hollister
Page 23
September 20, 1985
E. I .b. :
Please provide geologic cross-sectional drawings of each waste management
area, as well as a full facility geologic cross-sectional drawing; this can
be one drawing. These cross-sectional drawing(s) should also include all
water levels.
E.1,c . and d .:
The subsurface soils above 60 feet are reported to contain perched water.
Please provide appropriate field test data to accurately define these soils
(i.e., field permeability, cohesive shear strength, dry unit weight, degree
of saturation, rate of dewatering, and estimated amounts of available
water). Please also provide hydraulic field parameters and data for the
proposed uppermost aquifer.
E.2.b. :
Please submit a table of all recorded water level measurements for both /
historic and new monitor wells.
E.2 . c . , d. and e .:
The information requested in E.2.C., d., and e. of the Part B instructions
was not submitted in the application. Please submit this information.
1, Please provide additional geologic and hydraulic information including
field data (i.e., field permeability, hydraulic conductivity, effective
porosity, etc.) on each of the saturated units to:
a. Identify the uppermost aquifer; and
b« Demonstrate that hydraulic separation exists between the proposed
uppermost aquifer and the permeable zones above and below.
2. Please submit the method for determining that artesian conditions
exist in the proposed uppermost aquifer.
Section V. Ground-Water Monitoring
These questions refer to the Ground-water Monitoring Plan dated April 9,
1985.
General:
The construction and completion of the existing monitoring wells does
not provide a representative ground water sample. We recommend that
supplemental monitor wells be installed with limited screened intervals
in such a manner to individually screen each permeable zone (i.e.,
cluster wells). Please revise the application with the requested
information.
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E-4
Mr, Tracy Hollister
Page 24
September 20, 1985
2, Please provide the basis for determining new well locations and
spacings; ground water modeling or other hydrogeologic tools or
applicable guidance will be necessary to determine the Information
requested.
3, It may be advisable to separate the facility into two (2) waste
management areas (a North half and a South half) to adequately under-
stand the complexity of the subsurface and ground water flow patterns.
If the site is split into two waste management areas then two (2)
points of compliance should be identified. The monitor wells should
be closely associated with each regulated unit. If the landfill
expands, as it is suggested, then the point of compliance would
correspondingly expand.
4. The applicant must consider the effect that dewatering by the existing
landfill has had on the ground water flow direction, flow rate and
levels when designating the points of compliance. We recommend the
use of cluster wells at the points of compliance.
5. RES (TX) must provide the justification for locations of the points of
compliance. These points of compliance must be hydraulically down-
gradient of each waste management area. RES (TX) must also provide
technical Justification that the monitor well locations and spacing
will provide samples that represent the quality of ground water
passing the points of compliance.
6. Individual supplementary monitoring programs will be required for each
identified saturated zone and also for all zones that are hydraulically
interconnected. Please submit the indicator parameters, proposed
sampling schedule, and time frames for submittal of the proposed
graphs for the supplementary monitoring programs. These monitoring
programs will help establish the different potential pathways for
migration at the site.
7, Before an alternative statistical method can be considered, in accor-
dance with 31 TAG 335.463(8)(A)(ii), the applicant must demonstrate
that the Student's t-test, as required by 31 TAG 335.463(8)(A)(i), is
not applicable for evaluating ground water data at the RES (TX)
facility and that the alternative method will not increase the number
of false negative results.
8, One of the objectives of the monitoring system is to determine any
change in ground water flow due to mounding effects and/or the
dewatering caused by the existing landfill. We recommend that you
establish a permanent water-level monitoring system in the interior of
the facility as well as in the existing landfill. The elevations
should be measured before every sampling event.
-------
E-5
Mr, Tracy Hollister
Page 25
September 20, 1985
9, Please submit a set of indicator parameters to be used in monitoring
at the point of compliance. The list must consist of indicator
parameters, waste constituents, or reaction products that can provide
a reliable indication of the presence of hazardous constituents in
ground water. Indicator parameters may include pH, specific conduc-
tance, total organic carbon, total organic halogen, etc. The parameters
proposed by RES (TX) do not adequately demonstrate either the mobility
or the detectability of the proposed parameters. The applicant should
revise the list of indicator parameters, if necessary, and fully
justify the suitability of each parameter and of the list as a whole.
Indicator parameters would not need to be capable of detecting all
known waste constituents. The parameters used must provide a reliable
indication of the presence of hazardous constituents in ground water,
10. During water sample collecting, RES (TX) should submit more specific
information concerning: (1) recordkeeping of estimated yield during
Che bailing process; (2) decontamination of water level equipment; (3)
decontamination of pumps; and (4) methodology of obtaining a represen-
tative sample.
11. The sample schedule for all monitor wells needs to be revised to
maintain a quarterly sample schedule. Please submit a revised
schedule.
12, Please submit a legible copy of Figure 12.
Section VI. Closure and Post-Closure Plans
i. The final facility closure plan proposes a four-phased closure. For
clarity please present the schedule for all four phases of closure on
one master chart.
2, Container Storage Areas;
For each container storage area, please submit a closure plan which
details the procedures for removing and verifying the removal of all
hazardous waste, waste residues, and PCBs.
3. Tanks:
Please revise "Closure Plan VI-CP-1 Detailed Closure Plan for Tanks"
by preparing one closure plan for each tank and/or group of identical
tanks (i.e., same capacity, design, and secondary containment),
storing similar wastes (i.e., waste requiring the same closure proce-
dures and rinsate analysis). Each closure plan should also include
che following:
a) Identify the tank(s) to which the plan applies;
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E-6
Mr, Tracy Hollister
Page 32
September 20, 1985
VII. B.I . ;
Please provide a cost estimate for post-closure care following the assump-
tions and guidance presented iu the TWC Closure and Post-Closure Cost
Estimate guidelines.
VII. B. 2. ;
Please update the financial assurance for post-closure care of the facility
to reflect the revised post-closure cost estimate,
if in response to this letter a facility component or structure is modified in
design or operation, or is added to or deleted from the permit application, then
all relevant sections of the application should be amended to reflect the change
and to provide any additional information requested by the application form anc:
instructions.
The information requested above is necessary for a complete hazardous waste
permit application. Please submit four copies of your response to this letter,
Failure to submit the requested information by February. 28, 1986 may result in
dismissal of the application or a recommendation to deny the permit for the
subject facility.
Cotnisuni cat ions relating to Parts A and B of the permit application should be
directed to Joe Gingerich of the Hazardous and Solid Waste Permits Section at
AC512/463-8L87.
Sl/jcer«ly J
/ i 1
Head
Unit II
Permits Section
Hazardous and Solid Waste Division
JG/CLSP:lab
Enclosure
cc: TDWR District 7 Office - Deer Park
Guy Tidmore, Hazardous & Solid Waste Enforcement Section - Austin
Allen Messenger, Espey, Huston, & Associates - Austin
Marc Sides, Environmental Protection Agency Region VI - Dallas
-------
APPENDIX F
ANALYTICAL TECHNIQUES AND RESULTS FOR
TASK FORCE SAMPLES
-------
F-l
Appendix F
ANALYTICAL TECHNIQUES AND RESULTS FOR TASK FORCE SAMPLES
ROLLINS ENVIRONMENTAL SERVICES FACILITY
Deer Park, Texas
The following discusses analytical techniques, methods and results for
water and leachate samples collected by the Task Force at the Rollins
Environmental Services facility, Deer Park, Texas, 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 on the leachate samples. Laboratory analy-
sis results were obtained from two EPA contractor laboratories (CL) parti-
cipating 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
analysis of field and laboratory blanks to allow distinction of possible
contamination due to sample handling, (2) analysis of laboratory spiked
samples and performance evaluation samples and comparison of the CL results
with NEIC split sample results to estimate accuracy, and (3) analysis of
laboratory duplicates and field triplicates to estimate precision. The
performance evaluation samples were samples of known analyte concentrations
prepared by the EPA Environmental Monitoring Systems Laboratory, Cincinnati,
Ohio, Split samples from wells MW-2 and MW-35 were analyzed by the NEIC,
Table F-l provides a summary, by parameter, of the analytical tech-
niques used and the reference methods for the sample analyses. The CLP
results are reported in the data tables and the split sample results are
discussed where applicable in establishing the reliability of the CLP
results,
-------
F-2
WATER SAMPLE ANALYSIS RESULTS
Specific Organic Analysis Results
Table F-2 lists the organic compound.* which can be reported with cer-
tainty as being present in the ground-water samples for the identified wells,
None of the organic compounds for which concentrations were reported were
detected above blank levels in other monitoring well samples.
Table F-3 contains the limits of quantitation for the analyses for the
volatile, semi volatile, pesticide and herbicide organic compounds. Based
on matrix spike data, the volatile organic limits of quantitation are prob-
ably reliable to within a factor of two, while the extractable organic,
pesticide and herbicide limits are probably reliable to within factors of
two to twenty.
The CL results for four of the five direct injection compounds were
unacceptable; only 1,4-dioxane was correctly identified and quantitated.
These findings are generally consistent with past and subsequent Task Force
performance evaluations for the direct injection analysis. Because of the
apparent erroneous direct injection analysis results, compounds determined
by this method should be considered to have been 'not analyzed1.
NEIC analyzed samples supposedly from wells MW-2 and MW-35. NEIC vola-
tile organic results for the MW-2 well sample are not consistent with the
CL results or with the facility's monitoring data for this well. Chloroben-
zene and vinyl chloride were detected by the CL at many times the detection
limit, while these two compounds were not detected in the sample received
by NEIC. NEIC analyzed the MW-2 well sample in triplicate and obtained an
acceptable chlorobenzene spike recovery, It appears the sample mixup only
occurred with the 60-mL VGA bottles, as NEIC and the CL both detected
2-chlorophenol and 4-ehloroaniline in the extractable sample. Further, the
purgable organic halide (POX) and purgable organic carbon (POC) values
obtained by NEIC are consistent with the NEIC volatile organic analyses.
The POX and POC samples are also in 60-mL VOA bottles. Based on
-------
F-3
conversations with the NEIC project coordinator, NEIC apparently received
sampling equipment rinses instead of ground water from well MW-2 for samples
taken in the VGA bottles. Neither NEIC nor the CL detected volatile or
semivolatile organic compounds in the samples from well MW-35,
The CL incorrectly identified the presence of benzyl alcohol in the
performance evaluation sample. This compound should be considered to have
not been determined for the sample analyses.
A few problems were encountered in the CL pesticide analyses; however,
the results are considered reliable, The contract required detection limits
for the pesticides -that were not achieved by the CL, based on the perform-
ance evaluation sample analysis results. Lindane and methoxychlor were not
identified by the CL. Pesticide surrogate spike recoveries were high for
the samples from wells MW-8 and MW-13. Due to early eluting interferences
present in the chromatogram for sample MW-2, the extract for this sample
was analyzed at a tenfold dilution. Neither the CL or NEIC detected pesti-
cides or PCBs in the samples from wells MW-2 and MW-35,
The CL reported the presence of 3 pg/L of 2,4-D in the sample from
well MW-35. However, the second column confirmation of 2,4-D was not
acceptable. The difference in the second column retention time between the
unknown and the standard was too large, The CL also incorrectly found 3.8
ug/L 2,4-D and 0.7 ug/L silvex in a field blank.
Acetone, methylene chloride and 2-butanone were detected in all the
field blanks and most of the laboratory blanks. Bis(2-ethylhexyl) phthalate
was also frequently detected in the field and laboratory blanks. Chloro-
form was detected in half of the field blanks. None of the sample concen-
trations for these compounds exceeded the upper 99% confidence limit of the
blank values after subtraction of the average blank contaminant
concentrations.
-------
F-4
Metals Analysis Results
The dissolved and total metals results for the ground-water monitoring
well samples are reported in Table F-4. The reliability of detectable value
is footnoted in the table.
The dissolved elenwntal concentrations determined by Inductively Couplec
Argon Plasma Optical Emission Spectroscopy (ICAP-OES) 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. The
bias for the dissolved concentrations does not exceed 20%, based on results
for the sample split with NEIC and the "total" concentrations determined by
the CL.
Tha CL reported 82 M9/U and 51 ug/L total lead, respectively, in the
samples from wells MW-23 and MW-32. These concentrations were obtained by
ICAP-OES. The CL performed an ICAP-OES duplicate analysis on the well MW-23
sample and obtained a total lead concentration of 62 ug/L. Examination of
the raw data revealed that the CL also analyzed the well MW-23 sample by
furnace atomic absorption spectroscopy (AAS) but indicated the data was
'not used1 in reporting the sample analysis results. The duplicate furnace
AAS analysis results for the well MW-23 sample wi^e 44 ug/L, and 32 ug/L.
Comparison of the furnace AAS results to the ICAP-OES results indicates a
substantial bias. Although not reported, the sample of well MW-3 was found
to contain 33 ug/L by the ICAP-OES; however, the CL reported the furnace
AAS result of 7 ug/L. Based on the standard deviation of the blanks, the
ICAP-OES method had a detection limit of about 60 ug/L instead of the 20
ug/L reported by the CL. Thus, the ICAP-OES lead concentrations reported
for the samples from wells MW-21 and MW-23 are unreliable as they are near
or below the detection limit and are in discordance with the furnace AAS
results, The furnace AAS results are reported for well MW-23; however, the
well MW-21 sample is indicated to have been not analyzed as no furnace AAS
analysis was performed for this sample for total lead.
-------
F-5
Total lead was detected in two of the field blanks. Concentrations of
3 ug/L ancl 7 H9/L lead were reported. For previous Task Force projects,
some of the field blanks have been found to contain lead. Based on the
lead found in these previous blanks and in the two blanks for this project,
an average field blank of 6 ug/L lead was calculated and the standard devia-
tion of the blank lead values would indicate a detection limit of 15 ug/L.
Therefore, the lead concentration reported by the CL for the well MW-3
sample of 7 ug/L may be due to sampling handling contamination and has been
changed to not detected at 15 ug/L.
Zinc contamination due to sampling handling was evident as some of the
dissolved zinc concentrations are greater than the total zinc concentra-
tions. For example, a dissolved zinc concentration of 27 M9/L was reported
for the well MW-12 sample while the total zinc was not detected at 2 H9/L.
Further, zinc was a common contaminant in the laboratory and field blanks,
A number of the field blanks were reported to contain over 20 pg/L zinc.
Because these levels are greater than or near to the levels reported for
many of the samples, dissolved and total zinc will not be reported,
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 used 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 total values for aluminum, iron and copper reported by the CL
required subtraction of the digestion blank contamination levels, The
reported sample values have been corrected for blank levels of 11 ug/L
aluminum, 40 ug/L iron and 5 ug/L copper. The variability observed in the
digestion blank contaminant levels has been accounted in the determination
of the detection limits for these elements.
-------
F-6
The CL reported results for arsenic, lead, selenium and thallium that
did not account for furnace AAS matrix effects. These effects have been
corrected for in th« results reported in the data tables. Further detec-
tion limits were recalculated based on the variability in the calibration
curves and on the variability in the signal response.
General Analysis Results
The field measurements for conductance, pH and turbidity and the
results of other analytical testing for ground-water monitoring well samples
are reported in Table F-5. The reliability of the detectable values are
footnoted in the table.
The performance evaluation sample had true pH of 5.7 and 5.6 was
reported 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 reported conductance values have not been corrected for daily cell
constant variability as no standardization data was found in the field note-
books. A cell constant of unity must be assumed. The values have been
corrected for temperature. After temperature correction, the measured per-
formance evaluation sample value was 970 uhmos/cm which compares well to
the true value of 963 uhraos/cm. NEIC split sample conductance measurements
for the samples from wells MW-2 and MW-35 were 1,030 uhmos/cro and 2,300
uhmos/cw, respectively. These values are 130 uhmos/cm and 200 un^os/cm
greater than the temperature corrected field measurements. The data tables
indicate the conductance values are reliable to within 200 uhmos/cm,
Purgable organic halide (POX) was detected in the samples for wells
MW-2, MW-6 and MW-26. The POX values for these samples are in good agreement
with the volatile organic constituent analysis results. For example, the
measured POX values for the samples from wells MW-2 and MW-26 were 78% and
88%, respectively, of the POX calculated from the specific organic analysis
results. The measured POX for the performance evaluation sample was
-------
F-7
283 ug/L while the true value was 291 ug/L. Spike recovery data also
indicates good accuracy. Laboratory duplicate data and the field triplicate
data for the samples from MW-6 indicate good precision. The field tripli-
cate sample values averaged 27 ug/L with a standard deviation of 4.6 ug/L,
NEIC did not detect POX in the sample from well MW-35 which is in
agreement with the CL data. As discussed above in the organic section, the
samples in 60-mL VOA bottles received by NEIC for well MW-2 were probably
sampling equipment rinses and not actually ground water from well MW-2.
The POX value of 21 ug/L and the purgable organic carbon (POC) value of 22
(jg/L obtained by NEIC, although in agreement with NEIC specific organic
analysis results, are in discordance with the CL results as well as the
facility's past monitoring data for well MW-2.
Although POC was measured by the CL and quality control data gathered
concurrently with the sample analyses indicate acceptable precision and
accuracy, the POC results are not reported. Previous and subsequent con-
trol measures for other Task Force projects have indicated frequently that
the POC results are unreliable.
The total oganic halide (TOX) concentrations are of questionable
reliability. The CL reported a TOX value of 139 ug/L for the performance
evaluation sample which had a true value of 336 ug/L. Although a negative
bias is indicated by the performance evaluation sample, the TOX levels for
some of the wells are substantiated by the specific organic analyses results.
For examplev the measured TOX for the sample from well MW-26 differs by
less than 6% from a calculated TOX using the specific organic analyses
results. Further, TOX spike recoveries were 115% and 125% which would indi-
cate values could be biased high. Where specific chlorinated organic com-
pounds were detected in well samples, the TOX values confirm the presence
of at least the concentrations found and often substantially more halo-
genated organic matter than found by the specific organic analyses. For
example, the measured TOX for the sample from MW-2 was 9,680 ug/L, while a
calculated TOX from the specific organic analysis results was 1,330 ug/L.
This would indicate that the common organic constituent analysis methods
are apparently not sensitive to the halogenated compounds present.
-------
F-8
The TOX values reported for the field triplicate samples from well
MW-6 indicate good precision at high TOX levels as the average was 284 ug/L
and the standard deviation as 11 ug/L. However, poor reproducibi1ity was
indicated by laboratory duplicate data for analyses of the sample from well
MW-23. The CL reported duplicate analysis results of 16 ug/L and 9 ug/L.
A detection limit of 30 ug/L was calculated from the variability in TOX
blanks; therefore, although the CL reported a detection limit of 5 pg/L,
values below 30 ug/L are not reported in the data tables. The data tables
also indicate the TOX values are of questionable reliability as discussed
above.
Although results for laboratory duplicates, spiked samples and the
performance evaluation sample would indicate acceptable precision and
accuracy for nonpurgable organic carbon (NPOC), the NPOC results are pro-
bably unreliable. The NPOC values reported for the field triplicate samples
from well MW-Q6 ranged from 1.0 mg/L to 5.3 mg/L. A similar variability
was also observed in .comparison of the well MW-2 split sample value of 2.2
?
mg/L obtained by NEIC and the CL reported value of 4.6 mg/L. The split
sample NPOC values for tha samples from well MW-35 compared much better,
differing by only 0.4 mg/L.
Although no field blanks were provided for the ammonia preservative,
field blanks from subsequent Task Force projects have found the blank level
to be about 0.1 mg/L N as ammonia. Based on the variability in the cali-
bration curve and the variability of the field blank contamination, the
detection limit for ammonia was calculated to be 0.23 mg/L. All ammonia
values have had the blank contamination subtracted.
Samples collected for nitrate analyses were preserved 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
4° C. and analyzed within 48 hours of collection. The CL colorimetric method
is subject to positive interferences that were apparently not compensated
for by the CL procedure. For example, NEIC split sample results for wells
MW-2 and MW-35 were not detected at 0.05 mg/L nitrate, while the CL reported
-------
F-9
0.2 mg/L and 0.1 mg/L nitrate, respectively. NEIC analyzed samples by ion
chromatography. The samples were cooled to 4° C. and not acidified. No
nitrite was detected by the ion chromatographic method which indicates that
the CL positive bias is not due to nitrite interference. Further, the CL
reported a nitrate value of 2 mg/L for the performance evaluation sample
which had a true value of 1.6 mg/L. Substantial bias in the CL results has
been found in sample results for previous and subsequent Task Force projects.
The nitrate results are unreliable and are not reported in the data tables.
The CL reported a chloride value of 2,040 mg/L for the well MW-11 sample,
which is greater than the conductance and is not substantiated by the cation
data. Review of the bench records found a calculation mistake and the cor-
rect chloride value should have been 510 mg/L. The results of other control
measures for chloride were found to be acceptable. Comparison of split
sample results also indicates the results are reliable, as NEIC obtained
chloride concentrations of 113 mg/L for the well MW-2 sample and 550 mg/L
for the well MW-35 sample.
Although control measures indicate that the sulfate results should be
reliable, data for one of the well samples was determined to be unreliable.
NEIC obtained a sulfate concentration of 3.7 mg/L for the well MW-2 sample,
which compares favorably with a value of 3 mg/L reported by Rollins for
this well in July 1985. The CL reported a value of 38 mg/L sulfate for the
well MW-2 sample. Examination of the raw data found a discrepancy in the
CL analyses of the sample for sulfate. The CL initially analyzed all
samples by a high-level procedure and those samples found to contain less
than 50 mg/L were reanalyzed with a low level procedure. With the high-
level procedure, 38 mg/L sulfate should have given an absorbance of 0.019
units. However, an absorbance of zero was obtained for the analysis of the
well MW-2 sample which is in discordance with the concentration obtained
using the low-level procedure. The data table indicates that sulfate was
not quantified for the well MW-2 sample. Comparison of the sulfate results
reported by Rollins for the other wells analyzed by the CL indicates only
one other discrepancy. Rollins found 17 mg/L sulfate in a well MW-26 sample,
while the CL reported that the sulfate was less than 5 mg/L. Because an
-------
F-10
error was discovered for the CL analysis of the MW-2 sample, it is possible
that the CL result for the MW-26 sample was in error. Therefore, the data
table indicates the sulfate concentration reported for the MW-26 sample may
be unreliable. NEIC obtained a sulfate concentration of 27 mg/L for the
MW-35 sample which compares favorably with the CL value of 28 rg/L.
LEACHATE SAMPLE ANALYSIS RESULTS
Specific Organic Analysis Results
Table F-6 reports the organic constituent analysis results for the
three leachate samples. The leachate samples contained high concentrations
of numerous volatile and serai volatile compounds. Many compounds given in
Table F3 were not detected in any of the samples and, thus, are not listed
in Table F-6.
The CL erroneously reported phenol as not detected and reported the
presence of 18 pg/L bis(chloroethyl)ether in th« LC-7 leachate sample,
Review of the data showed phenol was present at 1,000 ^g/L and the
bis(chloroethyl)ether was not present,
A reporting error was discovered for the acid fraction compound con-
centrations in the LC-3 leachate sample. The CL reported the concentrations
at one-half of the actual concentrations due to an error in calculating a
dilution factor. The concentrations reported in the data table have been
corrected for this error.
Early eluting interferences were present in the pesticide extract
chromatograms for all the leachate samples. This caused the detection
limits for many of the pesticides to be raised by factors of 5 to 100.
All leachate organic analyses results should be considered serai-
quantitative; that is, concentrations are probably reliable to within 10%
to 300% of actual sample concentrations for the semivolatiles and 50% to.
200% for the volatiles. These ranges are what has been observed for leachate
-------
F-ll
samples from previous Task Force projects where split sample analysis
results were provided.
Metals Analysis Results
The dissolved and total metals results for the leachate samples are
reported in Table F-7. Depending on the suspended matter composition, the
values reported for certain elements may not represent "total" concentra-
tions. If the suspended matter is siliceous, then values for aluminum,
magnesium, potassium and sodium are not "total" because the silicate matrix
was not dissolved. The heavy metal results would approximate "total" con-
centrations because they are usually absorbed and are not incorporated in
the silicate matrix.
The CL reported ICAP-QES total lead concentrations for the LC-6 and
LC-7 samples and furnace AAS results for total lead results for the LC-2
and LC-3 samples. Total lead was determined by ICAP-OES and furnace AAS
for all samples. The furnace AAS results are substantially lower than the
ICAP-OES results, For example, the CL reported the ICAP-OES value of 993
(jg/L for the LC-7 sample while examination of the raw data revealed that
540 M9/L lead was found by furnace AAS. Similarly, the CL reported 665
Mg/L lead in the LC-6 sample while the furnace AAS analysis found 380 ug/L.
Although the furnace AAS analysis result of 65 |jg/L was reported for the
LC-3, the ICAP-OES analysis found 286 Mg/L. Because of severe spectral
interference often encountered in the ICAP-OES analysis for lead in complex
sampless the furnace AAS results are reported in the data table.
Similarly, ICAP-OES arsenic determinations are often severely inter-
ferred by many elements in complex sample matrices. The CL reported furnace
AAS total arsenic results for three of the leachate samples but reported
both dissolved and total ICAP-OES arsenic results for the LC-3 sample and a
dissolved ICAP-OES arsenic result for the LC-2 sample. No furnace AAS
analyses were performed for samples where ICAP-OES arsenic results were
reported. The ICAP-OES analysis results are suspected to be biased sub-
stantially high based on comparison with furnace AAS results, For example,
-------
F-12
the CL reported a furnace AAS total arsenic result of 94 M9/L for the LC-7
sample while examination of the raw data revealed that the ICAP-OES analysis
found 570 M9/L arsenic. Similarly, the furnace AAS analysis found 49 ug/L
total arsenic for the LC-6 sample while the tCAP-OES analysis found 300
ug/l. Based on these findings, the 176 M9/L reported for the dissolved
arsenic in the LC-2 sample is probably biased high and the data tables
indicated the value was not quantified, Very large concentrations of dis-
solved and total arsenic were found for ICAP-OES analysis of the LC-3 sample.
No furnace AAS analyses were performed on the LC-3 samples., It is likely
that the arsenic concentrations found by ICAP-OES for the LC-3 samples are
biased high. Because the concentrations are very high, the arsenic values
for the LC-7 samples are reported but are indicated to be biased high.
Although zinc values were not reported for the well samples, the total
concentrations for the leachate samples are contained in the data table
because the concentrations are substantially greater than blank levels dis-
cussed above, the dissolved zinc concentrations are not reported because
they were indistinguishable from the field blank contaminant levels.
General Analysis Results
Table F-8 reports the results of other testing for the leachate sample:;.
As mentioned, no field measurements were made for pH, conductance or tur-
bidity. Further, samples were not collected for POX and POC. Although
nitrate was determined, the results are not reported for the reasons dis™
cussed above.
Similar to the comparison between the calculated and measured FOX for
some of the well samples, the measured TOX values for the leachates are
much greater than the TOX calculated from the specific organic analyses.
Assuming the measured TOX values are not in error, then the common organic
methods are not sensitive to many of the halogenated organics present in
the leaehate samples. Similarly, the organic compounds detected by the
methods are accounting for only a small percentage of the organic carbon.
-------
F-13
The ammonia spike recovery was only 48%; therefore, the ammonia values
are probably unreliable and are not reported. Spike recoveries of only 7%
and 14% were observed for the cyanide analyses, The cyanide results are
not reported.
The chloride and sulfate spike recoveries were around 92%, indicating
that the values are reliable. However, the CL reported 539 mg/L chloride
for both the LC-6 and LC-7 samples. From the metals, the cation equivalences
are calculated to be 21.7 meg/L and 6.02 meg/L, respectively, for the LC-6
and LC-7 samples. However, from the chloride and sulfate concentrations,
the anion equivalences are calculated to be 16 meg/L for both samples.
The metals data would indicate that the chloride concentration reported in
the LC-7 sample could not be present. The fact that both samples were
reported to contain exactly the same concentration chloride suggests a sample
mixup either at the laboratory or in the field. Chloride and sulfate are
not reported for the LC-7 sample. Sulfate was determined from the same
sample bottle as chloride.
The sum of the phenolic compounds detected by the specific organic
analyses are from 7% to 69% of the colorimetrically determined phenol con-
centrations. Low recoveries of phenolic compounds are expected for the
specific organic analysis method.
-------
F-14
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Table F-6
Organic Constituent Analysis Results
for the Leachate Samples
Rollins Environmental Services, Deer Park, TX
F-23
Compound
Carbon disulfide
1 ,1 ,1-Trichloroethane
Trans-l,2-dichloroethene
Trichloroethene
Tetrachloroethene
Methylene chloride
Vinyl chloride
Benzene
Chlorobenzene
Ethylbenzene
Toluene
Xyienes
Acetone
2-Butanone
4-Methyl-2-pentanone
Acrolein
Styrene
An1 1 ine
P-Chloroani 1 Ine
1,2,4-Trlchlorobenzene
B1s(2-chloroethyl) ether
tsophorone
Naphthalene
2-Methylnapthalene
Benzole acid
Phenol
2-Chlorophenol
o-Cresol
p-Cresol
2,4-Oimethy Iphenol
LOQ Factors
Volatiles
Base/Neutrals
Ac ids
Pesticides
Station: LC-2
Value(a)
40.
ND
36,
25. c
25. c
25. c
50. c
320,
690.
1300.
400.
220 „
300.
ND
290.
ND
180.
1200,
1600.
ND
ND
10, c
100.
20.
ND
140.
47 ,
240,
88,
160.
5X
4X
4X
SX d
LC-3
Value
900,
ND
ND
NO
ND
NO
NO
500. c
500. c
20000,
500, C
ND
20000,
1000.
NO
50000. c
700,
NO
ND
NO
ND
NO
ND
ND
140000.
100000,
ND
4000 , C
13000.
NO
100X
2000X
1600X
10X e
LC-6
Value
ND P
ND
NO
ND
NO
25. c
50. c
SO
48.
25, c
NO
ND
100.
4800,
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NO
10. c
14.
NO
ND
5X
4X
4X
IX
tC-7
Value
ND
74.
NO
34,
25,
28,
NO
ND
25.
25.
140.
64.
'00.
2700.
240,
ND
ND
ND
NO
580.
NO
ND
10.
ND
NO
1000.
NO
53.
12.
NO
5X
4X
4X
IX
c
c
c
c
f
a) Concentrations are reporteo in ug/L.
b) ND 1s not detected,
c) Compound is present but below the given limit of quant Hat ion.
d) LOQ factor 1s 10X for the 8HC isomers, heptachlor, heptachlor epoxide and aldrin.
e) LOO factor 1s 100X for the BHC Isomers, heptacMor, heptachlor epoxide and aldrin.
f) LOQ factor is 5X for the BHC isomers, heptachlor, heptachlor epoxide, aldrln and PCBs.
-------
F-24
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U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, IL 60604-3590
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