December 1986 EPA-330/2-86-012
Hazardous Waste Ground-Water
Task Force
Evaluation of
B. H. S., Inc.
Wright City, Missouri
US Environmental Protection Agtnc*
Region 5, Library (PL-12J)
77 West Jackson Boulevard, l«tn fmr
Chicago, IL 60604-3590
&EPA
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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U3SZ.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
"<. PSO^-' December 11, 1986
UPDATE OF THE HAZARDOUS WASTE GROUND-WATER
TASK FORCE EVALUATION OF THE B.H.S., INC.,
WRIGHT CITr', MISSOURI, FACILITY
The United States Environmental Protection Agency's Hazardous Waste
Ground-Water Task Force (Task Force) conducted an evaluation of the ground-
water monitoring program at the B.H.S., Inc. (B.H.S.), hazardous waste dis-
posal facility. The onsite field inspection was conducted during the period
February 19 through February 26, 1986. The Task Force was accompanied by
Missouri Department of Natural Resources (MDNR) and EPA Region VII personnel.
B.H.S. is one of 58 facilities that are being evaluated by the Task Force.
The B.H.S. facility is located approximately 50 miles west of St. Louis,
Missouri, near the town of Wright City.
The purpose of the Task Force evaluation was to determine the adequacy
of the B.H.S. ground-water monitoring system in regard to State and Federal
ground-water monitoring requirements. Specifically, the objectives of the
evaluation at B.H.S. were to:
Determine compliance with the State equivalent of 40 CFR Part 265
interim status ground-water monitoring requirements.
Evaluate the ground-water monitoring program described in the facility's
RCRA Part B permit application for compliance with the State equivalent
of 40 CFR Part 270.14(c) requirements.
Determine if hazardous waste constituents have entered the ground-
water at the facility.
Provide information to assist the Regional Administrator in determining
if the facility meets EPA requirements for waste management facilities
receiving waste from Federal Superfund response actions.
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The facility was closed at the time of the inspection and, therefore,
little activity has taken place since the field work was completed. The
faciltiy has met with MDNR once on July 3, 1986 to discuss closure, ground-
water monitoring ana Part B issues. EPA Region VII met with the facility on
December 8, 1986 to preliminarily identify the deficiencies at the facility,
ana the alternatives for correcting those deficiencies. EPA and MDNR corrments
on the Part B application for Area 2 have been formulated and will be sent to
the facility in December 1986.
Analytical data from the Task Force sampling effort have qualitatively
indentified the presence of methylene chloride and i ,2-dichloroethane in the
ground water at the facility. A majority of the wells sampled were installed
just prior to the investigation and were sampled for the first time with this
effort. The presence of these compounds will be confirmed with additional
sampling by both the facility, during routine quarterly events, and EPA.
The Task Force investigation identified several deficiencies in the
geologic and hydrolo^ic site characterization, and in the ground-water moni-
toring system. These include lack of identification of the uppermost aquifer,
lack of a true upgradient well to characterize the background ground-water
quality, failure to define the hydraulic characteristics of Units A and B.
failure to determine the nature and extent of the sand lenses present in
Unit A, and failure to assess the vertical head distribution within and between
Hydro log ic Units A and B. EPA, in consultation with MDNR, will initiate an
appropriate action that will correct these deficiencies and will ensure full
implementation of the Task Force recommendations.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUND-WATER TASK FORCE
EPA-330/2-86-012
GROUND-WATER MONITORING EVALUATION
B.H.S. , INC.
Wright City, Missouri
December 1986
Alan E. Peckham
Project Coordinator
National Enforcement Investigations Center
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CONTENTS
EXECUTIVE SUMMARY
INTRODUCTION 1
SUMMARY OF FINDINGS AND CONCLUSIONS 10
GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS 11
Site Hydrogeology 12
Ground-Water Sampling and Analysis Plan 13
Closure/Post Closure Plans 13
GROUND-WATER MONITORING PROGRAM PROPOSED FOR THE RCRA PERMIT .... 13
TASK FORCE SAMPLING AND MONITORING DATA ANALYSIS 14
COMPLIANCE WITH CERCLA/SUPERFUND OFFSITE POLICY 14
TECHNICAL REPORT
INSPECTION METHODS 15
RECORDS/DOCUMENTS REVIEW AND EVALUATION 15
FACILITY INSPECTION 15
GROUND-WATER AND LEACHATE SAMPLING AND ANALYSIS 16
LABORATORY INSPECTION 16
WASTE MANAGEMENT UNITS AND OPERATION 17
WASTE MANAGEMENT UNITS 17
RCRA-Regulated Landfills 19
Nonregulated Landfills 20
Surface Impoundments 21
FACILITY OPERATION 22
Waste Acceptance 23
Waste Handling 24
Inspection Procedures 25
Leachate and Surface Runoff Handling 25
SITE HYDROGEOLOGY 26
HYDROGEOLOGIC UNITS 26
GROUND-WATER FLOW 26
Hydrologic Unit A 29
Hydrologic Unit B 29
Ground-Water Flow Summary 30
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CONTENTS (cont.)
GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS 34
REGULATORY REQUIREMENTS 34
SWDAOP 721901 35
40 CFR Part 265 Subpart F 35
HWFP TSD 122282001 35
10 CSR 25-7.011(10) 37
GROUND-WATER SAMPLING AND ANALYSIS PLAN 38
December 31, 1981 SAPS 38
November 15, 1983 SAPS 38
April 16, 1984 SAPS 38
February 14, 1986 SAPS 39
MONITORING WELLS 39
System 1 40
System 2 41
System 3 41
Other Wells 42
Interceptor Trenches 42
Well Construction 42
System 1 43
System 2 46
System 3 47
Other Wells 48
Well Locations 53
Interceptor Trenches 53
SAMPLE COLLECTION AND HANDLING PROCEDURES 54
WAIVER OF GROUND-WATER MONITORING REQUIREMENTS DEMONSTRATION .... 54
GROUND-WATER ASSESSMENT PROGRAM AND OUTLINE 55
GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT 58
DEFINITION OF WASTE MANAGEMENT AREAS 58
POINT OF COMPLIANCE 58
DETECTION MONITORING PROGRAM 60
COMPLIANCE MONITORING PROGRAM 61
CORRECTIVE ACTION PLAN 63
TASK FORCE SAMPLE COLLECTION AND HANDLING PROCEDURES 64
MONITORING DATA ANALYSIS FOR INDICATIONS OF WASTE RELEASE 74
REFERENCES
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CONTENTS (cont.)
APPENDICES
A ANALYTICAL TECHNIQUES AND RESULTS FOR TASK FORCE SAMPLES
B CONSTRUCTION DRAWINGS
C POTENTIOMETRIC SURFACE MAPS
D GROUND-WATER MONITORING SYSTEMS
FIGURES
1 Location Map 3
2 Hazardous Waste Management Units and Locations 4
3 Area 1 Disposal Units 6
4 Locations of RCRA-Regulated Units in Area 1 7
5 Typical Well Construction Systems 1 and 2 45
6 Typical Well Construction System 3 and GMW Wells 50
7 Designation of Waste Management Areas 59
8 Location of Task Force Sample Stations with Facility
Units Shown 66
TABLES
1 Status of Waste Disposal Units, Area 1 18
2 Hazardous Waste Landfilled in Trench 21 19
3 Classification of Hydrologic Units 27
4 Additional Sampling and Monitoring Requirements
Imposed by MDNR 36
5 Ground-Water Sampling and Monitoring Requirements Imposed by
EPA and MDNR 37
6 Summary of Well Information, System 1 Nominal 3-Inch Diameter
PVC Pipe with Glued Joints 44
7 Summary of Well Information System 2, Nominal 4-Inch Diameter
Schedule 40 PVC Threaded Flush Joint Pipe 47
8 Summary of Well Information System 3 and GMW Wells Nominal
2-Inch Diameter No. 316 Stainless Steel, Treaded,
Flush-Jointed Pipe 49
9 Summary of Well Information, Wells P17 Through P22 and P-A
Through P-D Nominal 3-Inch Diameter PVC Pipe with
Glued Joints 51
10 Summary of Well Information Nominal \ and 1^-Inch Diameter
PVC Pipe with Glued Joints 52
11 Phase I Ground-Water Assessment Plan Parameters 56
12 Wells for Monthly Water Level Measurements 61
13 Parameters for Compliance Monitoring Program 62
14 Sample Collection Data 65
15 Order of Sample Collection Bottle Type and
Preservative List 67
16 Chemical Vapor and Radiation Detections at Sample Stations
Wellheads 70
17 Purging Data 71
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EXECUTIVE SUMMARY
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INTRODUCTION
Concerns have been raised about whether hazardous waste treatment,
storage and disposal facilities (TSDFs) are complying with the ground-water
monitoring requirements promulgated under the Resource Conservation and
Recovery Act (RCRA).* In question is the ability of existing or proposed
ground-water monitoring systems to detect contaminant releases from waste
management units. To evalaute these systems and determine the current com-
pliance status, the Administrator of the Environmental Protection Agency
(EPA) established a Hazardous Waste Ground-Water Task Force (Task Force) to
evaluate compliance at TSDFs and address the cause(s) of noncompliance.
The Task Force comprises personnel from the EPA Office of Solid Waste and
Emergency Response (OSWER), the National Enforcement Investigations Center
(NEIC), Office of Enforcement and Compliance Monitoring (OECM), EPA Regional
Offices and State regulatory agencies. The Task Force is conducting in-depth
onsite investigations of TSDFs with the following objectives:
Determine compliance with interim status ground-water monitoring
requirements of 40 CFR Part 265 as promulgated under RCRA or the
State equivalent (where the State has received RCRA authorization)
Evaluate the ground-water monitoring program described in the
facility's RCRA Part B permit application for compliance with 40
CFR Part 270.14(c) or the state equivalent (where the State has
received RCRA authorization)
Determine if the ground water at the facility contains hazardous
waste constituents
Provide information which can aid in determining whether the TSDF
can receive waste from response actions conducted pursuant to the
Regulations promulgated under RCRA address hazardous waste management
facility operations, including ground-water monitoring, to ensure that
hazardous waste constituents are not released to the environment.
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Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA, Public Law 91-510)*
To address these objectives, this Task Force evaluation determined
whether:
The facility has developed and is following an adequate ground-
water sampling and analysis plan
Designated RCRA and/or State-required monitoring wells are prop-
erly located and constructed
Required analyses have been properly conducted on samples from
the designated RCRA monitoring wells
The ground-water quality assessment program outline (or plan, as
appropriate) is adequate.
The B.H.S. Incorporated, Wright City, Missouri facility (B.H.S.) onsite
inspection was conducted from February 19 through 26, 1986. The inspection
was coordinated by personnel from NEIC. In general, the evaluation involved
a review of State, Federal and facility records; a facility inspection; and
ground-water and landfill leachate sampling and analysis.
The B.H.S. facility is located approximately 50 miles west of St. Louis,
Missouri [Figure 1], The site covers approximately 158 acres. The facility
has interim status (EPA ID Number MOD068521228) for a landfill (58.9-acre-
feet) and treatment in surface impoundments (123 gallons per day).
Hazardous waste related activities at the site consist of closure of
the Area 1 landfill and storage/treatment of landfill leachate by surface
impoundments [Figure 2], A new landfill and tank and drum storage opera-
tion is proposed for tne site in the February 1986 RCRA Part B application.
EPA policy, stated in the May 6, 1985 memorandum from Jack NcGraw on
"Procedures for Planning and Implementing Offsite Response", requires
that TSDFs receiving CERCLA wastes be in compliance with applicable
RCRA ground-water monitoring requirements.
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Figure 1
Location Map.
BHS, Inc., Wright
City, Missouri.
0
Scale:L
1000 2000 3000
I I I
«CCO 5000
1. 1 feel
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PROPOSED HAZARDOUS
WASTE DISPOSAL AREA
FIGURE 2. HAZARDOUS WASTE MANAGEMENT UNITS AND LOCATIONS
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Disposal operations began in 1971 when a sanitary landfill was put
into use. Little information is available about its construction, opera-
tion or the waste placed in it. This disposal area, designated as the San-
itary Landfill [Figure 2], ceased operation in early 1977.
In June 1977, operations began in Area 1. The disposal area eventually
covered approximately 12 acres containing 33 drilled cell* and trench areas
[Figure 3]. Of these, six trenches (IN, 2N, 6N, UN, 12N, and 21) [Figure 4]
and the Progessive Trench Area (PTA-highlighted in Figure 3) were in
existence on November 19, 1980 and qualified for interim status. The RCRA
regulated portion of Area 1 covers approximately 2 acres.
The proximity of RCRA regulated and pre-RCRA trenches and drilled cells
requires that all of Area 1 be treated as a single hazardous waste management
unit for ground-water monitoring purposes; however, because of this, ground-
water monitoring will be unable to identify releases from a specific trench
or drilled cell regardless of when it was placed into or removed from service.
The Missouri Department of Natural Resources (MDNR) has issued two
permits to regulate Area 1 operations. The first, a solid waste disposal
area operating permit, was issued in May 1977. On December 22, 1982, this
was replaced by a hazardous waste permit based on the Missouri Hazardous
Waste Management Law and associated regulations. The latter permit will
expire December 22, 1987. Missouri was given Phase I authorization to admin-
ister the State ground-water monitoring regulations [10 CSR 25-7.011(10)],
in lieu of the Federal ones, in November 1983 and received final authoriza-
tion to administer all of RCRA, except for the 1984 amendments, in December
1985.
A Part B RCRA permit application was submitted August 3, 1983. It
consisted mainly of the December 13, 1981 permit application to the MDNR.
The application was reviewed by EPA Region VII and the MDNR. EPA issued a
Drilled cells were reported by B.H.S. to be unlined, 3-foot-diameter
auger holes in which drums of waste were stacked and then covered with
locally available clayey soil.
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comment letter October 3, 1983, in which additional information and
correction of deficiencies was requested. In response, B.H.S. submitted an
amended Part B application on November 15, 1983. EPA determined that the
amended Part B application was also incomplete and contained deficiencies.
On March 12, 1984, EPA issued a Letter of Warning to B.H.S. requesting
additional information and correction of deficiencies. B.H.S. submitted an
amended Part B application to EPA on April 16, 1984. On August 21, 1985,
EPA issued an Administrative Order to B.H.S. The order stated B.H.S. had
failed to submit a complete application and proposed that B.H.S. pay a pen-
alty of $7,150. Attached to the order was a letter listing the deficien-
cies and comments concerning the Part B application. On October 18, 1985,
EPA and B.H.S. signed a Consent Agreement in which the Company agreed to
pay a $5,400 penalty and submit a complete application no later than Febru-
ary 14, 1986. The revised Part B was submitted on February 14, 1986 and is
currently under review.
The initial Part B and the two revisions covered primarily the expan-
sion of Area 1. The February 1986 submittal was essentially a new Part B.
It described a proposed new landfill (Area 2), a leachate treatment system,
tanks that would replace the current surface impoundments and a ground-water
monitoring system.
B.H.S. was not accepting waste for disposal during the inspection.
Area 1 was undergoing closure under interim status and no landfill units
were in operation.
The surficial soil at the site is weathered loess, a wind-blown deposit
of glacial origin. This is underlain by a weathered/oxidized glacial till
and is known as Hydrologic Unit A. Beneath this unit is an unoxidized gla-
cial till and some residual soil known as Hydrologic Unit B. For purposes
of RCRA-required ground-water monitoring, the saturated portion of Hydrologic
Unit A and the interface between Hydrologic Units A and B are considered by
B.H.S. to be the uppermost aquifer.
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Beneath the glacial deposits are a series of bedrock formations
consisting of shales, limestones and sandstone. The St. Peter Sandstone,
ranging in depth between 350 and 500 feet below land surface at the site,
is the principal regional water supply aquifer.
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10
SUMMARY OF FINDINGS AND CONCLUSIONS
The findings and conclusions presented below reflect conditions existing
at the facility during the February 1986 investigation. Actions taken by
the State, EPA Region VII and B.H.S. subsequent to February are summarized
in the accompanying update.
Task Force personnel evaluated the ground-water monitoring program
followed at the B.H.S. facility for the period November 1981, when the
applicable provisions of the RCRA regulations became effective, through
February 1986. This evaluation revealed that the interim status ground-
water monitoring program for Area 1, although modified since 1981, still
needs further refinements. New wells have been placed around the site as
part of an expanded site ground-water monitoring program. The Task Force
effort included the first sampling of some of these new wells.
B.H.S. is not in compliance with 10 CSR 25.7.011(10) [40 CFR Part 265.91]
or 10 CSR 25.7.011(2)(E)(20) [Part 270.14(c)] because proper well placement
cannot be determined with confidence based on currently available hydrogeo-
logical site characterization. Apparent ground-water mounding within the
site complicates locating an upgradient or background well to provide back-
ground ground-water quality data for Area 1. Further, B.H.S. has proposed
the entire perimeter of Area 1 as the point of compliance because all areas
adjacent to Area 1 are depicted by their consultants as being hydraulicaliy
downgradient. More recent (April, May and June 1986) data submitted to
MDNR show a different water table configuration than depicted earlier, but
some ground-water mounding is still apparent and a large vertically downward
hydraulic head differential between the upper and lower glacial till units
is still evident. The uncertainty concerning the hydrogeologic interpreta-
tion brings into question the ability of the present wells to adequately
determine the impact of Area 1 or Area 2 on the ground water. Because of
the site conditions, including apparent ground-water mounding and depres-
sions, and apparent differential vertical hydraulic head distribution, the
ground-water flow patterns are not sufficiently defined to design an adequate
ground-water monitoring system. Upgradient wells may not be truly upgradient
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11
and downgradient wells may not be located or completed in appropriate
locations and zones to intercept ground-water contaminant plume(s).
Inadequate interpretation of the hydrogeologic features of the site
and deficiencies in the ground-water monitoring system would adversely impact
the ability of Area 2 to accept CERCLA wastes, if it is constructed.
The following is a more detailed summary of the inspection findings
and conclusions.
GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS
A 19-well system was initially installed in late 1976 to early 1977 to
meet State ground-water monitoring requirements. B.H.S. designated six of
these wells for Area 1 RCRA ground-water monitoring purposes; however, the
19-well system was considered inadequate to meet ground-water monitoring
requirements for the following reasons. Many downgradient wells never pro-
duced water or only produced intermittently. The upgradient and downgradient
wells were placed in different water-bearing zones, precluding meaningful
ground-water quality comparisons.
A second well system, consisting of four wells, was installed in
November 1982 to meet Federal and State ground-water monitoring requirements;
however, the designated downgradient wells were spaced too far apart to
intersect potential contamination plumes from Area 1. In addition, the
designated upgradient well was too close to Area 1 and may be influenced by
potential releases from the landfill.
Additional wells were installed in 1984 as part of the second system
to correct the above problems. A new upgradient well and an additional
downgradient well were constructed. The previously designated upgradient
well was then redesignated as being downgradient of Area 1.
Due to changes in the well networks, no statistical analysis was done
against background data until 1985. At that time, significant statistical
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12
differences were found in a number of the wells for various required
parameters. B.H.S. is in the assessment phase which was to begin in May
1986.
The present Area 1 upgradient well is located within the boundary of
the proposed landfill (Area 2). If the new Area 2 landfill is issued a
RCRA permit and is constructed, this well will be destroyed. Background
data will need to be collected for any new upgradient well.
Three interceptor trenches [Figure 2] on the east and south sides of
Area 1 may have the capability to intercept shallow plumes of contaminated
ground water moving in an easterly or southeasterly direction toward down-
gradient monitoring wells. These trenches may be included in the Area 1
ground-water monitoring plan if they are determined to be usable based on
their design, construction, ground-water yielding capability and their
position in the ground-water flow system.
Site Hydrogeology
The hydrogeological investigations of the site, conducted by B.H.S.
consultants, have not adequately defined the limits of the uppermost aquifer.
The poor quality and confusing interpretations of such information precludes
accurately determining ground-water flow direction(s) to design an adequate
ground-water monitoring system.
Based on an existing potentiometric map of Hydrologic Unit B, four of
the five RCRA-designated downgradient wells may, in fact, be upgradient of
Area 1. The presently designated upgradient well and the other downgradient
well may be the only downgradient wells monitoring Area 1.
The shallow water-bearing strata are interpreted by B.H.S. consultants
to consist of two zones and each is indicated as having ground-water mounds
and depressions which make flow generalization across the site difficult.
Onsite ponds, which are not regulated by RCRA and which have been drained,
have further altered flow patterns. It is also difficult to identify an
onsite location for upgradient wells due to the apparent mounds and
depressions.
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13
Ground-Water Sampling and Analysis Plan
Four documents, issued at different times, have been prepared to describe
ground-water sampling and analysis activities at the site. The first three
documents were inadequate because they only summarized the Federal and State
monitoring requirements and did not describe activities needed to comply
with the requirements.
The fourth document primarily describes proposed monitoring activities
at Area 2 and is also inadequate as a sampling and analysis plan for the
site.
Closure/Post-Closure Plans
Closure and post-closure monitoring plans were submitted in 1985 and
were under joint review by EPA and MDNR at the time of the inspection.
GROUND-WATER MONITORING PROGRAM PROPOSED FOR THE RCRA PERMIT
The February 1986 Part B submittal contains a ground-water monitoring
program for the entire site; however, the program does not adequately
describe which wells will be sampled to accomplish specific tasks.
The proposed point of compliance for Area 2 is inadequate. It was
based on a simulated potentiometric map which used estimated values for
hydrogeologic parameters rather than in-situ physical measurements of hydrau-
lic conductivity and hydraulic head distribution. Monitoring system and
point of compliance evaluations must be based on actual physical measurements
rather than estimated values.
Because the hydrogeologic interpretations for the site are not adequate,
the proposed monitoring system may not comply with RCRA ground-water monitor-
ing requirements. The proposed program can only be effectively evaluated
after a thorough hydrogeclogic characterization of the site is completed.
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14
Construction information for some of the wells included in the proposed
program is inadequate. Because of this, the usefulness of these wells in
meeting permitting program requirements is questionable.
TASK FORCE SAMPLING AND MONITORING DATA ANALYSIS
During the inspection, Task Force personnel collected samples from
nine ground-water monitoring wells, two leachate collection sumps and two
interceptor trench systems. The sampling and analysis were conducted to
determine if the ground water contains hazardous waste constituents or other
contamination indicators. The monitoring wells were prepared for sampling
by B.H.S. and Task Force and contractor personnel. All samples were collected
by the Task Force contractor (VERSAR, Inc.) except for leachate samples and
samples from Interceptor Trench 3 which were collected by B.H.S. personnel
for the Task Force.
The analytical results did not indicate widespread ground-water contam-
ination; however, the majority of the trenches and all of the drilled cells
in Area 1 are not lined and do not have leachate collection systems. Thus,
the potential for leakage from these disposal units exists. In addition to
common naturally occurring cations and anions, selenium was found in wells
B-11A and B-15 at 164 ug/L and 280 ug/L, respectively. Organic chemical
constituent analyses indicate the presence of 1,2-dichloroethane and acetone
in well GM-1. Methylene chloride may also be present in this well. These
findings should be further investigated for confirmation and evaluation.
COMPLIANCE WITH CERCLA/SUPERFUND OFFSITE POLICY
The EPA offsite policy requires that any TSDF used for land disposal
of waste from CERCLA response actions must be in compliance with the applic-
able technical requirements of RCRA. Interim status facilities must have
an adequate ground-water monitoring program to assess whether the facility
has had a significant impact on ground-water quality. The B.H.S. facility
has not fully complied with the technical ground-water monitoring require-
ments for waste management facilities.
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TECHNICAL REPORT
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15
INSPECTION METHODS
The Task Force evaluation of B.H.S. consisted of:
Review and evaluation of records and documents from EPA Region
VII, MDNR and B.H.S.
A facility inspection conducted February 19 through February 26,
1986
Sampling and subsequent analysis and data evaluation for selected
site ground-water monitoring and leachate collection systems
RECORDS/DOCUMENTS REVIEW AND EVALUATION
Records and documents from EPA Region VII and the MDNR offices were
reviewed before the inspection. B.H.S. records were reviewed to verify
information currently in Government files and to supplement Government infor-
mation where necessary. Selected documents requiring in-depth evaluation
were copied and subsequently reviewed. Records review included evaluation
of facility operations, construction of waste management units and ground-
water monitoring activities.
Specific documents and records included the ground-water sampling and
analysis plan, the outline of a ground-water quality assessment program,
monitoring well construction data and logs, site geologic reports, site
operations plans, facility permits, unit design and operation reports, and
operating records showing the general types and quantities of wastes disposed
of at the facility and their locations.
FACILITY INSPECTION
The facility inspection, conducted in February 1986, included identifi-
cation of waste management units, identification and asssessment of waste
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16
management operations and pollution control practices, and verification of
the location of ground-water monitoring wells and the leachate collection
systems.
Company representatives were interviewed to identify records and
documents of interest, answer questions about the documents, and explain
(1) facility operations (past and present), (2) site hydrogeology, (3) ground-
water monitoring system rationale and (4) the ground-water sampling and
analysis plan.
GROUND-WATER AND LEACHATE SAMPLING AND ANALYSIS
During the inspection, the Task Force collected samples from B.H.S.
ground-water monitoring wells and landfill leachate collection system sumps.
Samples were taken from two interceptor trench systems in order to character-
ize ground-water quality in the zone at the base of the trenches. Most
samples were collected by an EPA contractor, Versar, Inc., Springfield,
Virginia, and sent to EPA contractor laboratories for analysis. Splits of
all samples were offered to B.H.S., but the facility declined. Region VII
and MDNR also declined the offer of sample splits. NEIC received and analyzed
two split samples. Data from sample analyses were reviewed to further eval-
uate the B.H.S. ground-water monitoring program and identify possible con-
taminants in the ground water. Analytical results from the samples collected
for the Task Force are presented in Appendix A.
LABORATORY INSPECTION
No B.H.S. or contractor laboratory facilities were evaluated. Arrange-
ments with laboratories which had provided analytical services to B.H.S.
prior to the Task Force inspection had been discontinued. B.H.S. had not
sampled any of the new ground-water monitoring wells prior to the inspection
and, while new contract laboratories had been selected, there was no analyt-
ical data to evaluate. The onsite laboratory had been dismantled when Area 1
reached capacity in May 1985.
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17
WASTE MANAGEMENT UNITS AND OPERATION
WASTE MANAGEMENT UNITS
This section describes the design, construction, operation and
management of waste disposal units and waste handling and disposal prac-
tices at B.H.S. The discussion presented here provides a framework for
assessing waste disposal unit integrity, explains the types and placement
of wastes disposed of at B.H.S. and serves as a reference to assist in
evaluating the potential for ground-water contamination in the event that
leakage occurs.
B.H.S. has operated a number of landfill units and surface impoundments
at the facility [Figure 2]. The landfill units can be broken down into two
areas: the Sanitary Landfill and Area 1. The Sanitary Landfill, located
just south of Area 1, began operation in 1971 and ceased operation in 1977.
Drawings of the facility in the February 1986 revised Part B submittal
treat Area 1 and the Sanitary Landfill as one unit designated "Previous
Disposal Area".
Area 1, which began operation in 1977 and ceased operation in May 1985,
comprises approximately 33 trench and drilled cell areas [Figure 3]. It is
currently undergoing closure. A number of the disposal units in Area 1 are
not regulated by RCRA [Table 1].
The facility's Part B application proposes that a landfill be built on
the western edge of the property [Figure 2]. This application is still
under review by the MDNR. and EPA Region VII.
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18
Table 1
STATUS OF WASTE DISPOSAL UNITS
AREA 1
Facil ity
Designation
Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
IN
2N
6N
UN
12N
Drilled cells
Trench eel 1 s
(0-2 through
0-4)
Flammable
drilled eel Is
Alkaline drilled
cells
Alkaline trench
cells
(B-2 through
B-6)
Acid cells
PTA*
Opened
07/77
07/77
07/78
09/77
02/78
08/77
02/79
06/79
06/79
07/79
08/79
10/79
11/79
12/79
01/80
04/80
04/80
04/80
05/80
06/80
09/80
10/80
03/81
11/80
12/80
12/80
03/78
11/79
03/78
04/78
11/79
04/78
01/82
Date Last
Waste Accepted
09/78
09/77
06/79
07/78
10/80
08/78
03/79
06/79
07/79
08/79
09/79
11/79
01/80
12/79
04/80
07/80
06/80
06/80
05/80
09/80
12/80
03/81
12/81
03/81
06/81
06/81
06/80
08/80
06/80
06/80
06/80
06/80
05/85
RCRA
Regulated
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
Yes
Progressive Trench A.^ea
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19
RCRA-Regulated Landfills
Of the 33 trench and drilled cell units in Area 1, trenches 21, IN, 2N,
6N, UN and 12N and the PTA received hazardous waste on or after November 19,
1980 [Figure 4].
Trench 21 was described in the B.H.S. Area 1 closure plans as not in
operation after November 1980; however, a review of waste disposal records
for the unit revealed that hazardous waste disposal occurred through
December 5, 1980 [Table 2]. Therefore, the trench was an active unit and
is subject to regulation under RCRA. The PTA and "N" trenches are clearly
identified as regulated by RCRA.
Table 2
HAZARDOUS WASTE LANDFILLED IN TRENCH 21
ON OR AFTER NOVEMBER 19, 1980
Waste
Received
11/19/80
11/24/80
11/19/80
11/24/80
11/26/80
11/21/80
11/19/80
12/05/80
Generator
Litton Systems, Inc.
Mobay Chemical
Monsanto Company
Mountain View
Fabricating
Ramsey Corporation
Rival Manufacturing Co.
United Petroleum
Service
Loxcreen Company
Waste
Description
Wastewater sludge
Waste sulfur
Arsenic gallium
trash
Wastewater sludge
Sludge
Wastewater sludge
Zinc sulfate sludge
Wastewater sludge
Quantity*
54 drums
34 drums
24 drums
12 drums
14 cubic yards
8 cubic yards
56 drums
15 cubic yards
* All drums are 55 gallons
The trenches were dug on demand, dependent upon the types and amounts
of waste received at the site. In Appendix B, Figures B-l through B-6 pro-
vide construction details of the RCRA-regulated trenches.
Operation of the PTA began in January 1982 and ceased in May 1985.
The section was excavated and five separate cells were consecutively filled
as waste was received. A common leachate collection system services the
PTA.
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20
Leachate collection and removal systems were installed in the "N" trench
system and the PTA. Each of the "N" trenches has a separate system while
the PTA has a common system serving all five cells.
Leachate collection and removal systems for the "N" trenches were con-
structed from a common design. A 4-foot trench was dug below the bottom
grade of the disposal trench and 1 foot of sand was laid as a base. A 4-inch
polyvinyl chloride (PVC) perforated pipe, enveloped in a filter fabric, was
placed on the sand. Sand, to a depth of 2-feet, was backfilled around and
over the pipe; 1-foot layers, each of crushed rock and soil, completed the
system. The trenches slope to a sand-filled sump dug to a depth of 2 feet
below the collection trench. A 6-inch PVC pipe acts as an annulus for a
4-inch PVC collection pipe. Rock and sand were backfilled around the 6-inch
pipe to a height above the anticipated waste levels. Figures B-l through
B-6, in Appendix B, contain the construction drawings for each "N" disposal
trench and indicate the location of each leachate collection system.
The leachate collection system for the PTA consists of two lateral
collection trenches, oriented approximately east-west, which drain to a
north-south trench, which has a collection sump. The laterals also have
collection sumps, but are used instead as observation sumps [Appendix B,
Figures B-7 and B-8].
The laterals are 2 feet deep below the trench bottom grade and 3 feet
wide. The trench sides and bottom are lined with a filter fabric which
envelopes a layer of crushed stone. The laterals slope approximately 2%
toward similarly constructed collection trenches.
Nonregulated Landfills
The remainder of the B.H.S. used landfill capacity consists of the
sanitary landfill and Area 1 trenches and drilled cells which were filled
before November 19, 1980. The latter group consists of trenches 1 through 20.
two organic drilled cell areas, a flammable drilled cell area, an alkaline
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21
drilled cell area, trench cells 02 through 04 (04 consists of eight separate
trenches), special waste trenches, an alkaline trench, an acid trench and
an organics trench.
No construction information is available for the sanitary landfill and
only generic types of waste are known to have been disposed of in this unit
(e.g., sanitary, industrial and municipal wastes). The landfill has a clay-
soil cap and vegetative cover. Portions of the sides have experienced
erosion problems as evidenced by runoff gullies exposing fill material.
These have been observed by MDNR personnel in the past and were observed
during the Task Force site reconnaissance on February 4, 1986.
The trenches in Area 1 were dug with a backhoe to a general depth of
27 feet. The MDNR required B.H.S. to inspect the excavations for pockets
of sand and gravel. As they were found, B.H.S. was required to remove as
much of the pockets as possible. Usually the trench was widened or deepened
to excavate as much of the sand as possible. The trench was then backfilled
with local clayey soil to the approximate original dimensions. Waste was
then placed in the trench and the unit covered with soil from the site.
The drilled cells were constructed by a 3-foct-diameter auger to an
approximate depth of 27 feet. Drums were vertically stacked to a height of
seven drums per cell. The remaining volume was backfilled and covered with
soil from the site. In each drilled cell area, the number of cells drilled
was dependent on the amount of waste to be disposed of.
Surface Impoundments
Three surface impoundments (SI-1, SI-2 and SI-4) are currently opera-
tional on the site [Figure 2]. These are to be replaced by tanks, as
described in the Part B application. A fourth impoundment, SI-3T, has been
drained and is not in use. The numbering system of these impoundments has
changed through the years, which has caused some confusion in following the
history of each unit.
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22
Two of the impoundments were constructed in 1977 and were identified
as Lagoons 1 and 2. They were used for the storage of water used for truck
washing and water removed from the active trenches at that time. Both were
renovated in 1983 with the installation of a clay liner and a leachate col-
lection system. The capacity of these lagoons (50,000 gallons each) was
not altered. The units were renumbered. Lagoon 1 became SI-2 and Lagoon 2
became SI-1. Both now store leachate from the PTA and "N" trenches.
Surface impoundment SI-3 was built in 1981 originally as a disposal
trench, but was never used. A section was dammed off and acted as an
impoundment which held surface runoff from Area 1. In 1983, it was pumped
out and spray irrigated, then SI-4 was built over much of the old area.
The remainder of the old excavation was backfilled with soil.
In 1983, surface impoundment SI-3T was built to act as a temporary
storage unit while SI-3 was being rebuilt. Impoundment SI-3T is not lined
nor does it have a leachate collection system. It is still present onsite
but is drained and inactive.
SI-4 has a 3-foot compacted clay liner and a leachate collection system.
The capacity is approximately 150,000 gallons. B.H.S. considers this as a
replacement for SI-3.
The leachate collection system for each surface impoundment was
installed beneath the clay liner and consisted of a minimum l^-foot-deep by
10-foot-wide trench in which a 3-inch layer of sand was placed. The trench
was sloped 0.5%. A 4-inch perforated PVC pipe was wrapped in filter fabric
and placed on the sand base. The remainder of the trench was backfilled
with sand. The perforated PVC pipe was connected to a 4-inch PVC riser
used to remove collected leachate [Appendix B, Figures B-8 and B-9].
FACILITY OPERATION
Since the site has not received waste since May 1985, no waste accept-
ance activities could be observed during the inspection. In many cases, a
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23
single load of one type of waste was disposed in a single trench or drilled
cell. The following sections discuss past operation practices.
Waste Acceptance
The MDNR issues approvals for wastes to be accepted at a TSDF. These
approvals are based on a review of composition, characteristics and hazards
for each waste material. The TSDF (in this case B.H.S.) submitted the
requests for review and notified the generator of the approval or denial.
Each waste type was assigned a sequence code by the MDNR which they used to
track the waste. In this case, each waste received at the B.H.S. site is
designated as BHSXXX.
A laboratory for analysis of incoming wastes was in use onsite during
the active period of Area 1. Due to the landfill being shutdown, the lab-
oratory has been dismantled and the equipment has been mothballed. If the
proposed landfill (Area 2) is opened, the laboratory will be reactivated.
B.H.S. relied heavily on customer waste characterization data for
approval submissions to the MDNR. Once a waste was approved by the State
for disposal, B.H.S. again relied heavily on the customers to notify them
if characteristics of a waste had changed.
Once a waste material had reached the facility, B.H.S. mainly performed
a physical, visual and odor examination. More extensive analysis was usually
done once a month for a given waste stream. The waste analysis plan was
not very detailed and lacked a written basis or schedule when sampling and
analysis of incoming waste loads would be done. As an example, the plan
states "B.H.S. shall sample a random movement of hazardous wastes. . ." but
does not fully identify the procedures to follow in order to determine what
is sampled, when and how often. The text refers to monthly sampling of
high volume generators but does not identify the sampling frequency of low
volume generators.
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24
The waste analysis plan indicates only that the first shipment of each
waste stream was tested for free liquids. There was no procedure to ensure
later shipments were similar to the first one. If the waste was identified
as having greater than 70% moisture content, the waste was tested daily for
percent volatiles.
As B.H.S. did not conduct their own analysis of waste as part of the
approval process, they relied on the generator not only to submit true and
valid data for approval purposes but also to alert B.H.S. to any waste changes.
B.H.S.'s waste analysis was not designed to identify changes in waste from
the original submittal, but to identify if the waste could be handled at
the site. In order to identify changes in waste from the original submis-
sion, B.H.S. stated that they would review analyses for large generators
(those disposing on a weekly basis), yearly, moderate generators (those
disposing on a monthly basis), e*/ery 2 years, and other generators when pro-
duction methods would alter physical characteristics. These time frames
were inadequate when based on the minimal analysis B.H.S. performed.
B.H.S. identified the following waste streams which we^e not to be
handled at the facility.
1. Ignitable wastes
2. Reactive wastes
3. Volatile waste having a vapor pressure of greater than 78 milli-
meters of mercury at 25° C.
4. Bulk liquids and sludges with more than 75% liquid by weight,
having free flowing liquid, which were free flowing themselves or
contained more than 5% by weight organic liquid
Waste Handling
After the waste material was checked at the facility's front gate, the
waste was directed to either a storage location or the designated disposal
unit. Drilled cells were drilled literally on demand. Trenches took more
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25
time to construct since they had to be excavated and the later ones had to
have a leachate collection system installed. In some cases, a single waste
was placed in a trench.
Inspection Procedures
No formal record of inspections conducted by B.H.S. prior to January
1984 is available. From November 1980 through December 1983, the visitor
sign-in log served as the record of inspection results. Few problems were
recorded during this period as most activities consisted of pumping water
from open trenches to the impoundments.
On January 23, 1984, an inspection log was initiated and maintained
along with inspection results. Daily inspections were performed for the
following items: surface impoundments, emergency equipment, storage and
unloading areas, site fencing, landfill surface-water diversion berms and
proper soil cover on disposal areas.
Leachate and Surface Runoff Handling
Throughout the operating life of Area 1, surface runoff and water found
in open trenches was collected and sprayed on the cover of closed sections
of Area 1. In all cases, the liquid was analyzed by B.H.S. and found not
to meet hazardous waste characteristic criteria [10 CSR 25.4.010(2) through
(5) - 40 CFR Part 261 Subpart C]. Nonetheless, much of this liquid was a
hazardous waste since it did come in contact with landfilled hazardous waste.
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26
SITE HYDROGEOLOGY
HYDROGEOLOGIC UNITS
The facility is situated in an area characterized by wind-blown soil
and glacial deposits which overlie bedrock formations consisting of shales,
limestones and sandstones. The wind-blown or loessial deposits comprise
the uppermost layer which consists of clayey silt to very silty clay that
becomes sandy near the base. This deposit includes the tillable soil in
the area and ranges in thickness up to 20 feet.
The loessial soil is underlain by a layer of oxidized glacial till, an
interface zone and a layer of unoxidized glacial till. The loess and oxi-
dized till have been designated the "A" hydrologic unit and the unoxidized
till and residual soils have been designated the "B" hydrologic unit
[Table 3]. These units make up the uppermost water-bearing zone for RCRA
ground-water monitoring purposes. The "A" unit consists of sandy clay to
sandy, silty clay and the "B" unit consists of silty clay near the top but
is primarily a sandy, silty clay.
A series of limestone and shale bedrock formations underlies the site.
Underlying the limestones and shales, at a depth of 350 to 500 feet, is the
St. Peter Sandstone which serves as a major regional water supply aquifer.
Other water-bearing strata occur at greater depths. Table 3 shows the hydro-
logic units identified at the site and their designation by B.H.S.
consultants.
GROUND-WATER FLOW
Two flow regimes are present for the area, one for the bedrock and one
for the overlying glacial deposits. The flow direction in the bedrock forma-
tions, including the St. Peter Sandstone, is to the northeast. Flow direc-
tion in the overlying glacial deposits is generally believed to be to the
south and southwest but locali?ed ground-water mounds and depressions at
the site and the difficulty in interpreting subsurface information, makes
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27
it difficult to determine specific ground-water flow directions and rates
within portions of the site. Additional information and revised interpreta-
tions are needed to clearly define the hydrogeological characteristics of
the site including local ground-water flow patterns and potential pathways
of pollutant migration.
Table 3
CLASSIFICATION OF HYDROLOGIC UNITS
Geol
Name
Loess
Oxidized
Unoxidized till
Residual soil
Sulfur Springs
Snyder Creek
Cal laway
Kimmswick
Decorah
Plattin
Joachim
St. Peter
Powell-Cotter
Jefferson City
Roubi doux
ogic Unit
Lithology
Silt
Clay
Clay
Clay
Shale
Shale
Limestone
Limestone
Shale
Limestone
Limestone
Sandstone
Limestone
Dolomite
Sandstone/
1 imestone
Thickness
0-20
0-60
40-190
0-20
0-20
0-20
55-60
20
75-95
75
110-125
325-345
130-165
150+
Hydrologi
Approx. Depth
0-60
80-250
350-500
450-600
900-1200
c Unit
Designation
A
A
B
B
C
C
C
c
c
c
c
D
P
E
F
Hydrogeologic work by Woodward Clyde Consultants (WCC), Kansas City,
Missouri, B.H.S.'s consultants, identifies a number of ground-water mounds
and depressions at the site. The ground-water flow regime at the site has
not been clearly defined and no true upgradient location for Area 1 has
been clearly identified. Although recent (April, May and June 1986) water
level data submitted to MDNR show a different water table configuration
than WCC, the problem of designating an upgradient or background well loca-
tion for Area 1 has not been resolved. Additional hydrological investigation
should reveal whether an acceptable background location or locations car be
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28
identified in an area which is hydrologically separated from, although
perhaps not upgradient of, Area I.
Because of the lack of clear definition of the ground-water gradients
at B.H.S., it is not presently clear where and at what interval(s) a truly
representative upgradient/background well or wells could be constructed.
The three interceptor trenches along the east side and a portion of the
south side of Area 1 may be considered for monitoring along this portion of
the proposed point of compliance for this area. Consideration should also
be given to installing additional interceptor trench systems around the
remainder of Area 1 as wells may not provide a feasible means of monitoring
ground-water quality in the low permeability terrain which characterizes
this site. The uncertainties caused by the difficulty of defining ground-
water gradients in this area shed further doubt on the feasibility of clearly
establishing acceptable upgradient or background and downgradient locations
to monitor this site effectively with wells.
Two ponds on the site, which were not regulated by RCRA since they
held stormwater runoff, were drained in October 1985 and were considered by
B.H.S. consultants to have contributed to ground-water mounding. With their
removal, the associated mound should disappear over time and result in a
different ground-water flow pattern. WCC was of the opinion that newly
installed wells used to measure ground-water elevations may not have reached
hydraulic equilibrium. This further leads to the conclusion that ground-
water gradients, as now measured, will change over time. Also, if new
interceptor trenches are excavated and if existing interceptor trenches are
pumped to maintain lower hydraulic head, these activities will affect
ground-water flow patterns.
The following is a discussion of each of the ground-water hydrologic
units that make up the uppermost aquifer at the site.
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29
Hydrologic Unit A
This unit is showing both downward and horizontal hydraulic gradients.
Based on calculations by WCC, the downward flow is greater than the hori-
zontal flow. Three ground-water mounds have been tentatively identified
and depicted as being: (1) around the present impoundments and stretching
to the west and northwest toward the drained ponds, (2) in Area 1 along its
eastern border, and (3) an area near the northwest corner of the site
[Appendix C, Figure C-l].
Hydrologic Unit B
This unit contains sand lenses located from place to place. WCC does
not feel the lenses are continuous or interconnected. This opinion has not
been supported by adequate field testing. Ground-water flow in the unit
appears to radiate from the mounds but probably has a net southeasterly to
southwesterly direction across the site. Three ground-water mounds and a
depression have been tentatively identified. The mounds are shown as being
at the approximate location of Unit A's first mentioned mound, at the north-
west corner of the site, and along the east boundary of the proposed landfil"
The depression appears to be located in the vicinity of Interceptor Trench 3
along Area 1's eastern boundary [Appendix C, Figure C-2].
Much of the water level data for Hydrologic Unit B was obtained from
the well series which was installed for permit monitoring purposes. Many
of these have not been fully developed according to WCC. These wells may
also not show hydraulic stability because of the intermittant purging
required for development. A true picture of the ground-water gradients
was, therefore, not obtainable at the time of the inspection. Additional
hydrologic site characterization is needed to clearly define both vertical
and horizontal flow patterns including hydraulic head distribution and per-
meability characteristics of the site. More recent (April, May and June
1986) water level data submitted to MDNR show a different water table con-
figuration than depicted b> WCC in the February 1986 Part B application;
however, some ground-water higns within the site are still apparent and a
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30
large vertically downward hydraulic head differential is still evident.
These need to be evaluated with respect to their influence on potential
pathways for contaminant migration.
Ground-Water Flow Summary
Ground-water flow from mounded areas within an aquifer would normally
be expected to form radial flow patterns. If this is truly the case at
B.H.S., as depicted for Hydrologic Unit A by WCC, an upgradient location is
not available within the site; however, a suitable location(s) for determin-
ing background ground-water quality may be an acceptable alternative depending
on the results of further hydrogeological investigation. Further, the
potentiometric surface maps presented by WCC in the February 14, 1986 Part B
application show decreasing hydraulic head between Hydrologic Units A and B
which provides a strong potential for vertically downward flow [Appendix C,
Figures C-l and C-2]. Therefore, if leakage from old disposal areas occurs,
it may be expected to move downward and would not be detectable by wells
constructed in Hydrologic Units A and B adjacent to the disposal areas.
The potentiometric surface map for Hydrologic Unit A indicates a ground-water
mound in approximately the same area as a ground-water depression in the
underlying Hydrologic Unit B. If this hydraulic head differential is real,
it provides the potential for downward movement of ground water and supports
the possibility that contaminants leaking into ground water in this area
could move downward to some unknown depth before moving laterally. Thus,
they may escape detection in monitoring wells or trenches located adjacent
to past waste disposal areas.
The simulated potentiometric surface map "A" Unit [Appendix C, Figure
C-3] shows potentiometric contours as much as 20 feet above the ground sur-
face. None of the piezometric surface maps generated by this model, with
estimated or assigned values for this site, are acceptable.
B.H.S.'s hydrogeologic investigation reports were prepared by their
consultants, D.E. Klockow and Associates (Klockow) and Woodward Clyde Con-
sultants (WCC). Review of reports prepared by these consultants reveals
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31
that a number of deficiencies remain. The Task Force came to the following
conclusions and recommendations as a result of the review of these reports.
1. B.H.S. has failed to fully characterize the hydrogeology of the
site, particularly with respect to:
a. The nature, extent and permeability characteristics of the
fracture network in Hydrologic Unit A
b. The permeability characteristics of Hydrologic Unit B regarding
its integrity as an aquitard
c. Evaluation of the broken, jointed and solutioned bedrock in
Hydrologic Unit C and its relationship to the overlying strata
which may constitute pathways for contaminants to escape the
site undetected
d. The nature and extent of sand lenses or stringers which have
been observed within the glacial till layers which constitute
Hydrologic Units A and B
e. Assessment of vertical hydraulic head distribution beneath
the site to the depth of the first aquiclude, aquifuge or
zone where horizontal ground-water flow dominates vertical
flow components
2. B.H.S. has failed to define the limits and hydrogeologic character-
istics of the uppermost aquifer.
3. B.H.S. has failed to comply with the terms of the EPA August 21,
1985 Compliance Order requiring deficiencies in the site character-
ization and ground-water monitoring system to be corrected.
The failure to fully characterize the site hydrogeology and define the
limits of the uppermost aquifer, as required, will result in the facility
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•39
Ji.
being unable to fully comply with Part B requirements found in 40 CFR Part
270.14(c).
Information addressing the above deficiencies must be provided before
an adequate ground-water monitoring system can be designed and evaluated.
It is the consensus of the Task Force that B.H.S. should be required
to provide:
1. Adequate characterization of the hydrogeology of the site; including
at a minimum:
Definition of the nature, extent and permeability character-
istics of the fracture network in Hydrologic Unit A utilizing
both laboratory and field testing methods.
Definition of the permeability characteristics of Hydrologic
Unit B regarding its integrity as an aquiclude using both
laboratory and field testing methods.
Evaluation of the broken, jointed and solutioned bedrock in
Hydrologic Unit C and its relationship to the overlying strata
with respect to the potential pathways for contaminant migra-
tion using cores and in-situ field testing methods.
Definition of the nature and extent of sand lenses or stringers
within the glacial till layers, whether they are intercon-
nected, are isolated pockets or sinuous sand stringers crossing
portions of the site or extending offsite.
Definition of the vertical hydraulic head distribution beneath
the site to the depth of the first aquiclude thoroughly enough
to show the three-dimensional characteristics of the ground-
water flow system.
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33
2. Provide additional data and interpretive information needed to
fully characterize the site hydrogeology in sufficient detail to
provide a basis for an integrated ground-water monitoring system.
3. As a result of the site characterization studies, define the limits
of the uppermost aquifer.
4. Present a modified ground-water monitoring system.
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34
GROUND-WATER MONITORING PROGRAM UNDER INTERIM STATUS
Ground-water monitoring at the B.H.S. facility has been conducted under
the requirements of Federal and State interim status regulations and two
State hazardous/solid waste permits. Prior to November 19, 1981, a State
permit defined monitoring requirements and a well system. A number of wells
in this system were specified as RCRA ground-water monitoring wells. After
November 19, 1981, the Federal and State regulations and a State permit
defined monitoring requirements. B.H.S. requested a waiver from RCRA ground-
water monitoring requirements but it was denied by EPA Region VII.
The following is an evaluation of the monitoring program between November
1981, when the ground-water monitoring provisions of the RCRA regulations
became effective, and February 1986, when the Task Force investigation was
conducted.
REGULATORY REQUIREMENTS
Ground-water monitoring at the facility has been regulated by both
Federal and State requirements. Federal requirements (40 CFR Part 265,
Subpart F) were in effect from November 1981 through November 1983. Tne
State ground-water monitoring regulations [10 CSR 25-7.011(10)] took effect
in lieu of the Federal regulations in November 1983 when the State was
granted Phase 1 interim authorization.
Two State permits have also outlined ground-water monitoring at the
site. These are Solid Waste Disposal Area Operating Permit (SWDAOP) 721901
issued on May 25, 1977 and Hazardous Waste Facility Permit (HWFP) T
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25
SWDAOP 721901
The MDNR issued this permit on May 25, 1977. It required quarterly
monitoring for total organic carbon (TOC), pH, heavy metals and conductivity.
The following were also to be analyzed initially: lead, chromium, copper
zinc, cadmium, nickel, fluoride, iron and manganese. Monitoring began in
August 1977 and two quarters of sampling were completed in that year. The
permit required the installation and monitoring of 17 wells and the monitor-
ing of two existing wells (System 1).
On January 1, 1978, the MDNR imposed additional parameter and sampling
requirements. These are outlined in Table 4 along with their frequency.
Sampling under this permit overlapped with the interim status requirements
which follow.
40 CFR Part 265, Subpart F
Monitoring under the Federal requirements began in November 1981.
These are outlined in Table 5 along with their frequency. Six wells from
System 1 were designated to serve as RCRA monitoring wells. In December
1983, System 1 was replaced for RCRA ground-water monitoring purposes by
wells required by the following State permit (HWFP TSD 122282001).
HWFP TSD 122282001
The MDNR issued this permit on December 22, 1982. It referenced sam-
pling and analytical requirements found in 10 CSR 25-7.011(10)(c), the State
hazardous waste regulations which were identical to 40 CFR Part 265. It
also required the installation of four wells (System 2) and three inter-
ceptor trenches as ground-water monitoring points and indicated five surface
water sampling points.
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36
Table 4
ADDITIONAL SAMPLING AND MONITORING
REQUIREMENTS IMPOSED BY MDNR
Parameter
PH
Redox potential
Specific conductivity
TOC
Chemical oxygen demand (COD)
Hardness (total as CaC03)
Chloride
Iron
All of the above
Biochemical oxygen demand (BOD)
Suspended solids
Total dissolved solids
Turbidity
Extractable oil
Fecal coliform bacteria
Alkalinity
Phenol s
Nitrate as nitrogen
Sulfates
Fluorides
Cyanides
Heavy metals2
Gas chromatograph scan for
chlorinated hydrocarbons and
pesticides
Arsenic
PCBs (specifically)
Frequency
Quarterly1
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Yearly on July 1
Yearly on July 1
Yearly on July 1
Yearly on July 1
Yearly on July 1
Yearly on July 1
Yearly on July 1
Yearly on July 1
Yearly on July 1
Yearly on July 1
Yearly on July 1
Yearly on July 1
Yearly on July 1
Yearly on July 1
Yearly on July 1
Quarterly
Annually
Quarterly is defined as the following periods.
1st quarter:
3rd quarter:
4th quarter:
January 1-March 31
Report due April 1
2nd quarter: April 1-June 30
Report due July 1
July 1-September 30
Report due October 1
October 1-December 31
Report due January 1
Heavy metals include:
Arsenic Copper
Barium Lead
Cadmium Manganese
Hexavalent chromium Mercury
Total chromium Nickel
Selenium
Silver
Zinc
The total of each is to be reported.
-------
37
Table 5
GROUND-WATER SAMPLING AND MONITORING REQUIREMENTS
IMPOSED BY EPA AND MDNR
Parameter
Chloride
Iron
Manganese
Phenols
Sodium
Sulfate
pH
Specific conductivitv
TOC
Total organic halide
(TOX)
Arsenic
Bari urn
Cadmium
Chromi urn
Fluoride
Lead
Mercury
Nitrate (as nitrogen)
Selenium
Si 1 ver
Endri n
Lindane
Methoxychlor
Toxaphene
2,4-D
2,4,5-TP, silvex
Radium
Gross alpha
Gross beta
Col iform bacteria
Frequency
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
for
for
for
for
for
for
for
for
for
for
for
for
for
for
for
for
for
for
for
for
for
for
for
for
for
for
for
for
for
for
fi
fi
fi
fi
fi
fi
fi
fi
fi
fi
fi
fi
fi
fi
fi
fi
fi
fi
fi
fi
fi
fi
fi
fi
fi
fi
fi
fi
fi
fi
rst
rst
rst
rst
rst
rst
rst
rst
rst
rst
rst
rst
rst
rst
rst
rst
rst
rst
rst
rst
rst
rst
rst
rst
rst
rst
rst
rst
rst
rst
year,
year,
year,
year,
year,
year,
year,
year,
year,
year,
year,
year,
year,
year,
year,
year,
year,
year,
year,
year,
year,
year,
year,
year,
year,
year,
year,
year,
year,
year,
annually thereafter
annually thereafter
annually thereafter
annually thereafter
annually thereafter
annually thereafter
semiannual
semiannual
semiannual
semiannual
semiannual
semiannual
semiannual
semiannual
semiannual
semiannual
semiannual
semiannual
semiannual
semiannual
semiannual
semiannual
semiannual
semiannual
semiannual
semiannual
semiannual
semiannual
semiannual
semiannual
iy
iy
iy
iy
iy
iy
iy
iy
iy
iy
iy
iy
iy
iy
iy
iy
iy
iy
iy
iy
iy
iy
iy
iy
thereafter
thereafter
thereafter
thereafter
thereafter
thereafter
thereafter
thereafter
thereafter
thereafter
thereafter
thereafter
thereafter
thereafter
thereafter
thereafter
thereafter
thereafter
thereafter
thereafter
thereafter
thereafter
thereafter
thereafter
10 CSR 25-7.011(10)
In November 1983, the State of Missouri was granted Phase 1 interim
authorization. At that time, State regulations became enforceable in lieu
of Federal ones. The State ground-water monitoring regulations are iden-
tical to 40 CFR Part 265. The ground-water monitoring well system consisted
of the four wells identified above, which was later modified by the addition
of two we!Is.
-------
38
GROUND-WATER SAMPLING AND ANALYSIS PLAN
Three ground-water sampling and analysis plan summaries (SAPS) and one
ground-water sampling and analysis plan (SAP) can be identified as being
prepared in response to RCRA requirements. These are (1) a SAPS which was
part of a December 31, 1981 permit application to the MDNR; (2) a SAPS found
in the November 15, 1983 revised Part B; (3) a SAPS found in the April 16,
1984 revised Part B and (4) a SAP contained in the February 14, 1986 Part B.
December 31, 1981 SAPS
A SAPS was prepared as part of a December 31, 1981 permit application
to the MDNR. The SAP could be characterized best as an outline from which
a more extensive, detailed plan should have been prepared. Based on this
SAPS, it appears B.H.S. personnel monitored according to interpretations
site personnel made of Federal and State regulations and State permit
requirements.
Those requirements outlined in the State permits were followed closely
as all parameters were monitored. On November 20, 1981 monitoring began
for Federal requirements, but only indicators of contamination were analyzed.
November 15, 1983 SAPS
This SAPS was basically a two-page summary of the interim status ground-
water monitoring requirements. Monitoring parameters were listed but pH
was missing from the indicators of contamination list. No sampling or
analytical techniques or methods were described. No procedures were listed
for any sampling or monitoring activity. The SAPS referred to new wells
(System 2) which were to be sampled to develop background data.
April 16, 1984 SAPS
This SAPS was also basically a summary of interim status ground-water
monitoring requirements. It contained no more information on monitoring
-------
39
activities at the site than the previous SAPS. Initial background data was
included with the revised Part B yet the SAPS still described parameters to
be monitored for the first year.
February 14, 1986 SAP
The SAP was presented in the February 14, 1986 Part B. It was prepared
to meet the requirements of 10 CSR 25.7.011(10)(2) [40 CFR Part 264.98] and
does differentiate somewhat between the RCRA requirements for the proposed
landfill and some of the post-closure monitoring requirements of Area 1.
The plan, as written, is not clear whether interim status monitoring
will be conducted at Area 1. The Part B implies the plan will be used for
interim status purposes but does not specifically state this.
MONITORING WELLS
B.H.S. has designated two well systems at various times as their RCRA
ground-water monitoring system. A well system of 16 piezometer wells
(P wells) and a deep downgradient well were installed to comply with
SWDAOP 721901. These were monitored along with two existing wells. Six of
these wells were designated for the initial RCRA ground-water monitoring
system.
The second system (GM wells) initially consisted of four wells with
two wells added at a later date. This system replaced the one above for
RCRA monitoring purposes.
A third system (B wells) was installed primarily to supplement the GM
wells for use in Area 2's RCRA permit monitoring program. Certain of these
wells were sampled by the Task Force. They were picked because their loca-
tions may intercept contamination plumes which originate in Area 1. Por-
tions of the well system may be used to supplement or replace the GM wells
in a post-closure perrit ::sued for Area 1. Certain of the B wells and two
GMW wells, described in System 2 belovv, are to be sampled during ground-Water
assessment work at the site.
-------
40
In addition to the well systems placed or designated for RCRA interim
status monitoring requirements, other wells had been installed and are listed
under the proposed RCRA permit monitoring scheme for Area 2. These wells
will be discussed and described in this section under "Other Wells".
This section will include a discussion of the interceptor trenches
placed on the east and south sides of Area 1. These trenches are located
between Area 1 and the designated downgradient wells GM-3 through GM-5.
They, therefore, may have the potential to intercept contaminant plumes
which may not reach the monitoring wells. These trenches have become for-
gotten members of the ground-water monitoring plan for the site and should
be included as monitoring points.
The following is a discussion of the wells used for RCRA ground-water
monitoring under Federal and State requirements.
System 1
The P wells and a companion downgradient well were installed in response
to SWDAOP 721901. Sixteen P wells were installed along with one identified
in the permit to be located in the southeast corner of Area 1. This well
has been identified by B.H.S. consultants as both MW and DMW (hereafter MW).
Two existing water supply wells were also designated b> the permit to
be part of the system. These were the Zykan Well and the Old/Wash/Truck
Wash Well (hereafter the Truck Wash Well).
This first well system [Appendix D, Figure D~l] was sampled to monitor
ground water for the State from August 1977 through June 1983.
B.H.S. designated six wells from this system to be their RCRA monitor-
ing system for Area 1. The upgradient ones were the Zykan and Truck Wash
Wells which are completed in the deep sandstone aquifer rather than in the
shallow aquifer immediately underlying waste disposal units. The downgra-
dient ones were wells P5, P8, P10 and MW. These were sampled for RCRA
monitoring purposes from November 1981 through December 1982.
-------
41
System 2
The entire first system was deemed inadequate by the MDNR for reasons
discussed in the Well Construction section which follows. The four GM wells
replaced System 1 in November 1982 (GM-1 through GM-4). These wells were
initially installed to meet the requirements of HWFP TSD 122282001.
Well GM-1 was designated as upgradient and wells GM-2 through GM-4 as
downgradient. Sampling and monitoring of these wells [Appendix D, Figure
D-2] for RCRA began in December 1983 and continued through December 1985.
The GM wells continued to be monitored for RCRA when the MDNR received
Phase I authorization. EPA Region VII required two wells be added to the
GM series. Well GM-5 was added in May 1984 and GM-1R in July 1984
[Appendix D, Figure D-2]. Well GM-1R was designated as an upgradient well
since well GM-1 was considered to be downgradient because it was influenced
by the regulated units. Well GM-5 was designated as a downgradient well.
Two additional wells were required to be installed by the MDNR, GMw-1
and GMW-4, in December 1985. They were not part of the RCRA system but
were used by the MDNR to evaluate the GM wells. They are used in the ground-
water assessment program for the site.
System 3
The B wells were installed [Appendix D, Figure D-3] to supplement the
GM wells for Area 2's RCRA permit ground-water monitoring plan. Certain of
these wells were sampled by the Task Force because it was felt they were
located in areas that would intercept contaminant plumes coming from Area 1
or possibly provide new background ground-water quality data.
These wells should also be considered among others to supplement or
replace the GM wells in Area 1's post-closure permit. Many of these wells
would, therefore, act as dual purpose ground-water monitoring points.
-------
42
Other Wells
In December 1978, six additional P wells were installed (wells P-17
through P-22) to meet State sampling and monitoring requirements. These
wells are located to the east, south and north of Area 1 and were considered
to be downgradient [Appendix D, Figure D-4].
During the period July through October 1981, a series of K wells were
installed. These were 12 clusters of piezometers placed at various loca-
tions throughout the site to monitor water levels to establish hydrogeo-
logic gradients [Appendix D, Figure D-5].
In October 1985, four additional piezometers were installed to monitor
hydrogeologic conditions. These are wells P-A, P-B, P-C and P-D and are
located to the west of Area 1 [Appendix D, Figure 6].
Interceptor Trenches
Three trenches were installed to comply with the requirements of State
Permit HWFP TSD 122282001. They were designed to intercept flow from Hydro-
logic Units A and B.
The trenches are pumped once or twice a year and are not on a set mon-
itoring schedule. The sumps for each trench (trenches 1 and 2 share a common
sump) were designated by the State permit as monitoring points. Minimal
information is available on monitoring results.
Well Construction
The following is a discussion of the known construction details for
each well system installed by B.H.S.
-------
System 1
This system comprises the P wells, well MW, the Zykan Well and the
Truck Wash Well. The P wells and well MW were installed from late 1976 to
early 1977. The P wells are all completed 35 feet below surface elevation
(BSE) and well MW is 128 feet BSE. Few construction details are available
for well MW although a boring log does exist. The well was probably con-
structed in the same manner and from the same materials as the P wells.
Well MW was initially bored to 174 feet BSE, 6 inches into limestone
bedrock. A gravel layer was found at 87 to 97 feet BSE. It subsequently
caved in, filling the bottom of the hole. The bottom of well MW's casing
sits on top of the gravel. The water quality of samples taken from the
well were, in all likelihood, related to the quality of water found in the
caved-in section of the boring.
The P wells were constructed by drilling an 8-inch boring and placing
a 3-inch PVC pipe within it. All wells were 35 feet deep and have a 25-foot
screened interval. Sand was placed as a filter within the boring/well pipe
annulus to just above the top screen. A bentonite plug was placed on top
of the sand filter and local soil was used to fill in the remaining space
to the surface. Table 6 provides a summary of the depth, screened interval
and screened hydrogeologic units of the P wells and well MW. Figure 5
provides the typical construction of the P wells and, probably, well MW.
-------
44
Table 6
SUMMARY OF WELL INFORMATION,
SYSTEM 1
NOMINAL 3-INCH-DIAMETER PVC PIPE
WITH GLUED JOINTS
Well
Number
P-l
P-2
P-3
P-4
P-5
P-6
P-7
P-8
P-9
P-10
P-ll
P-12
P-13
P-14
P-15
P-16
MW
Surface
El evation
(ft. msl)
804,
790,
778,
770.
765.
764,
759.
758.
755.
761.
777.
586.
794.
798.
804.
808.
735.
,9
,5
,3
.0
.9
,3
9
4
7
2
1
.7
.9
5
4
4
5
Screened
Zone
(ft. msl)
795-770
780-755
768-743
760-735
756-731
754-729
750-725
748-723
746-721
751-726
767-742
777-752
785-760
786-761
794-769
798-773
Unknown
Screened
Hydrologic
Unit(s)
A
A
A
A,
A,
A,
A,
A,
A,
A,
A
A
A
A,
A
A
A,
B
B
B
B
B
B
B
B
B
Many of the P wells never produced water or produced water inter-
mittently. Later hydrogeologic site investigators concluded fine-grained
material may have plugged the screens, causing dry or mud conditions in
these welIs.
The Zykan Well was constructed in 1970 to act as a water supply for
the site. It is approximately 404 feet BSE and draws water from the St.
Peter Sandstone formation. The Truck Wash Well also serves as a water supply
well for the site. There is no available data of its construction or depth.
It supposedly also draws water from the St. Peter Sandstone formation. No
other information is known for either well.
-------
45
REMOVABLE
PVC CAf
BENTONITE SEAL
SELECTED
GRADED SAND
3 In. PVC SCHEDULE 40 PLASTIC PIPE
.023 In. WIDE SLOTS^ -
I lo. DIAMETER HOLE 3
PVC CAP
FIGURE 5
TYPICAL WELL CONSTRUCTION
SYSTEMS *1 AND »2
(REVISED FROM RE1TZ 4 JENS, INC.
-------
46
The system P wells were deemed to be inadequate for the following
reasons:
I.
2.
Fine-grained material was believed to have plugged screens of
certain wells. This caused dry or mud conditions within wells,
making them unusable for monitoring purposes. It was therefore
concluded that certain or all P wells were improperly constructed.
The two upgradient wells were not screened in the same water-bearing
zone as the downgradient ones. No water quality comparison could
be made between the up and downgradient wells because different
water-bearing zones were being monitored.
System 2
This system comprises the GM wells (GM-1 through GM-5 and GM-1R).
Wells GM-1 through GM-4 were installed in November 1982 as replacements for
the System 1 wells. All were drilled in the same manner as the P wells and
well MW, although the System 2 wells have 4-inch PVC casings. Sand was
used as a filter pack material in the annulus from the bottom to 8 to 9
feet above the screened interval. The remaining annular space was filled
with a cement-bentonite grout to surface elevation.
Wells GM-5 and GM-1R were constructed in May 1984 and July 1984, respec-
tively, in the same manner as the other GM wells. Table 7 provides the
depth, screened interval and screened hydrogeologic unit for each well.
The typical construction of these wells would follow that of Figure 5 but
with a different casing size and depth.
-------
47
Table 7
SUMMARY OF WELL INFORMATION
SYSTEM 2*
NOMINAL 4-INCH-DIAMETER
SCHEDULE 40 PVC
THREADED FLUSH JOINT PIPE
Well
Number
GM1
GM2
GM3
GM4
GM5
GM1R
Surface
Elevation
(ft. msl)
796.3
812.3
772.8
758.0
777.6
765.3
Screened
Zone
(ft. msl)
700.8-670.3
665.0-636.5
675.8-647.0
682.3-653.0
686.4-631.4
728.0-705.0
All wells are screened in
Zone B.
The system was deemed by EPA to have an insufficient number of wells
in order to constitute effective detection monitoring and compliance monitor-
ing programs. Further wells were needed in order to adequately serve as
points of compliance.
System 3
This system comprises the 27 B wells. Two wells, GMW-1 and GMW-4,
were also drilled along with the B wells in order to monitor the performance
of wells GM-1 and GM-4, as required by the MDNR. These two wells are not a
pa^t of System 3.
All of the above wells were drilled from October through December 1985.
They were started with a 6-inch boring in which a 2-inch No. 316 stainless
steel casing was placed. The wells are screened in hydrogeologic units A
and B. The B wells have 10-foot screens and the GMW wells have 20-foot
screens.
-------
48
Two exceptions are wells B18A and B19 which are constructed of 2-inch
PVC pipe with 5-foot screens. These act as piezometers to monitor sand
lenses in the oxidizec zone (hydrologic unit A).
Sand was packed between the boring and casing from the bottom to 2 feet
above the screen. A 2-foot bentonite plug was placed on top of the sand,
followed by cement-bentonite grout to the surface. A steel protective cas-
ing was placed over the well and a concrete pad poured around the well.
Table 8 provides information on all B and GMW wells. Figure 6 shows
the typical contruction of the B and GMW wells.
Other Wells
Wells P-17 through P-22 and P-A through P-D have 3-inch PVC casings.
They were installed soon after the initial P wells. It is unknown how they
were constructed, but it is inferred construction procedures followed that
of the initial P welIs.
Wells P-17, P-18, P-20 and P-22 are 50 feet deep and have 40-foot
screens. Wells P-19 and P-21 were drilled 111 feet and 120 feet, respec-
tively, and have 40-foot screens. Sand filled the space between the bore
hole and casing just above the screens. It is unknown if a bentonite plug
was used to seal off the space above the sand and it is assumed local soil
was used to fill the remainder of the annular space.
Little construction information is available for wells P-A through P-D
other than their size, depth and screened interval, which is approximately
12 feet.
Table 9 provides the known construction information for the above wells.
-------
49
i ac e 3
NCM
piezometer*
we' 1 NuiflDer
B-1A
B-2
B-3A
B-4
B-5
B-6A
B-7
B-3A
B-9
B-iCA
B-11A
B-12A
B-12B
B-13
B-14A
B-15
B-16
B-17A
B-17C
B-13
B-13A*
B-19A
B-198*
B-20
B-21A
B-22A
B-23A
GMV- 1
GMV.-4
iS^L 2-INCH-MAME'E^
g or Mor
Well L:
2538N,
2623N,
0502N,
2351N,
2143N,
1900N,
1889N,
1861V
2171N,
2395N,
1378N,
2380N,
2392N,
2160N,
1890N,
1506N,
1320N,
1C46V
1C 3 IN,
3"5N,
877N,
S"6N,
S82N,
1300N,
1574N,
1035N,
195~V
•ts^-g
Dcat1 on'
995E
125 :E
1521E
IbDUt
1812E
139 7 E
1609E
1428E
1 0 5 3 E
959E
1155E
562E
675E
625E
625E
^c
625E
630E
525E
750E
752E
1025E
ir_5r.E
1425E
142EE
142 5 E
1150E
2C9BE
VE-. :N-ORMA*:ON SYSTEM 3 AND GMW WELLS
NO 516 STAINLESS STEEL, THREADED, FiLiSH-JCINTEj 5:;E
E 1 8 v a t " o r.
tne grcuic
Surface
1 ft "nsi ;
308
"91
' / L.
76"
760
"51
""3
790
799
304
793
307
SO7
800
792
7°"
^ ~ -,
76i
759
748
748
745
746
"69
778
750
794.
"61
9
2
3
3
Q
3
~
3
7
^
a
;
7
2
a
5
4
4
0
5
6
-4
5
0
5
3
0
Top of
3i ser
311
793
774
768
753
763
782
792
301
806
793
809
810
802
793
791.
776
762
762
750
749
746.
748
771
779
752
738 .
795
762
48
22
88
94
57
23
09
27
54
24
95
34
55
75
2
69
81
39
84
23
66
"9
52
46
56
56
S 3
96
61
of Hole
Bottom (.msl )
60
49
38.
38.
28
35
56
59
55
57
57
116
65
PI
56.
55
54
79
47
43
29
36
2?
54
49
41
124
104
75/748
/744
16/734.
847728
17/732
7726.
/722.
7731.
34/743.
/747
7736
5/692
41/742.
/739
75/735
,'732
5 7721
7681
7712
82 '704
33/718.
33/710.
5 ''"' 2 ^
7 7 IS!
33/728
"/709"
^P 71 c
,'670
7657
15
72
54
53
9
9
7
46
7
1
H
.39
,7
45
8
. 1
4
4
.37
, 77
.57
9
6
6 7
5
42
3
Wate- L
January
Cry
754
760.
763
736
747
762.
761
748
"54
754
Dry
748.
743
758
"56
752
6S3
741
~i "• 9
733
733.
733
751
752
734
687
.eve1
'" i986
1
K
9
3
s
0
o
6
Q
7
9
3
7
. 1
i
I
q
3
0
7
c
'
7
-
5
Piezometers constructed r'roc scneauie 4C P
-------
50
STEEL PROTECTIVE CASINO
WITH LOCKING MECHANISM
81< STAINLESS STEEL THREADED
FLUSH COUPLED 2 In. ID WELL CASIN<
UPPER 10 Ft. OF ANNULUS FILLED
IIT H EXPANDING NEAT CEMENT GROUT'
ANNULUS FILLED WITH NEAT CEMENT
GROUT, 10* BENTONITE ADDED
UNSATURATED ZONE \
SATURATED ZONE
DESIGNED FILTER PACK AROUND
WELL SCREEN TO HEIGHT fi Ft.
ABOVE SCREEN
O X IDIZED GL ACIAL PR I F T
UNOXIDIZED GLACIAL DRIPT
VENTED CAP
DRAIN HOLE
4 In. X 8 Ft. CONCRETE PAD
(ANNULUS SEALED WITH CERTIFIED
(COARSE GRIT SODIUM BENTONITE TO A
* THICKNESS OF ? 2 Ft.
816-STAINLESS STEEL 2 In. ID
WELL SCREEN 10 Ft. IN LENGTH
WITH DESIGNED SLOT SIZE
-8 In. • 10 In. DENSE
PHASE SAMPLING CAP
PLUG ON BOTTOM OF WELL SCREEN-
NOMINAL 6 I or.
FIGURE 6
TYPICAL WELL CONSTRUCTION
SYSTEM »3 AND GMW WELLS
(Rcviied for Wood ward-Clyde Consultants)
-------
Table 9
SUMMARY OF WELL INFORMATION
WELLS P17 THROUGH P22 AND P-A THROUGH P-D
NOMINAL 3-INCH-DIAMETER PVC PIPE
WITH GLUED JOINTS
Well
Number
P17
P18
P19
P20
P21
P22
PA
PB
PC
PD
Surface
Elevation
(ft. msl)
800.
748.
755.
764.
791.
779.
793.
793.
796.
796.
2
5
5
6
2
8
5*
5*
0*
0*
Screened
Zone
(ft. msl)
790-750
738-698
765-725
755-715
781.741
770-730
742-754
714-726
716-728
745-757
Screened
Hydro! ogic
Units
A,
B
A,
A,
A
A,
A,
B
B
A,
B
B
B
B
B
B
* Approximate
The K series of wells are clusters of ^-inch and 1^-inch wells. Each
cluster was placed to monitor water levels in one or more of the following
zones: at the oxidized/unoxidized interface, at a depth of approximately
50 feet below waste disposal and at depths below the 50-foot level to the
bedrock. It is unknown which size corresponds to which specific well in a
cluster. The holes were bored by 6-inch and 3^-inch hollow-stem augers and
4-inch solid core continuous flight augers. Screened intervals ranged from
10 to 20 feet depending upon the depth of the zone to be monitored. Screen
size was 0.5 millimeter.
The annular space between the screened interval and the total depth
was filled with sand. The remainder of the annular space above the sand
was filled with a cement/bentom'te grout.
Table 10 provides the available construction details for each cluster.
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Table 10
SUMMARY OF WELL INFORMATION
NOMINAL VINCH AND 1VINCH-DIAMETER
PVC PIPE WITH GLUED JOINTS
52
Well
Number
K-1-ox*
K-l-80'*
K-l-sa*
K-l-br*
K-2-ox
K-2-80'
K-2-sa
K-2-br
K-3-ox
K-3-801
K-3-1101*
K-3-br
K-4-ox
K-4-801
K-4-1201
K-4-br
K-4-brr*
K-5-ox
K-5-801
K-5-sa
K-5-br
K-6-ox
K-6-si*
K-6-br
K-7-ox
K-7-si
K-7-br
K-8-ox
K-8-si
K-8-br
K-9-801
K-9-sa
K-9-br
K-10-801
K-10-br
K-ll-ox
K-ll-sa
K-ll-br
K-12-br
* Note:
ox -
80 =
sa =
si =
110 -
br =
brr =
Surface
El evation
(ft. msl)
780.6
780.3
781.8
781.8
796.6
797.9
797.0
797.0
777.4
776.5
778.8
778.8
791.7
791.5
792.2
792.2
791.9
773.1
771.4
772. 1
772.1
746.3
745.5
745.9
770.6
769 7
770.1
793.9
791.9
792.8
736.35
736.5
736.5
732.9
732.5
759.2
759. 6
759.2
768.1
Screened
Zone
(ft. msl)
721.6-731.6
725 -705
672 -662
606 -604
739.6-741.6
741 -721
677 -667
606.4-604.4
713 -703
718 -698
688 -658
580 -578
748 -738
734 -714
672 -662
672 -662
582 -557
734.6-724.6
715 -695
677 -667
605 -603
735.3-727.3
644 -624
573 -568
737.3-727.3
772 -762
581.4-576.4
745.7-735.7
713 -693
605 -600
678 -658
625 -615
580 -575
657 -652
674 -654
724 -714
701 -691
663 -643
557 -555
Screened
Hvdrologic
'Um't(s)
A, B
B
B
B
A, B
B
B
B
A
B
B
B
A, B
B
B
B
B
A, B
B
B
B
A, B
B
B
A, B
B
B
A, B
B
B
B
B
B
B
B
A, B
B
B
B
oxidized unoxidized zone surface
SO feet in depth
completed in sand
completed in silty
110 feet in depth
bit refusal
layer
layer
bit refusal replacement
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53
Well Locations
Appendix D, Figures D-l through D-6, indicates the locations of each
well system, the interceptor trenches and the other well networks. The
proposed RCRA permit system encompasses nearly all wells installed at the
site.
Interceptor Trenches
Few as-built construction details are available for the trenches. All
trenches were to be excavated at least 2 feet below the interface zone between
Hydrologic Units A and B. A sand-filled lens was constructed that extended
2 feet into Hydrologic Unit B and the remainder in Hydrologic Unit A. For
trench 1, this sand-filled portion was 8 feet in total depth. For trenches
2 and 3, it ranged from 18 to 20 feet in total depth. All lenses were at
least 2 feet in width.
On the north side of trench 1 is a sand-filled lens that acts as the
collection zone. A clay cutoff wall was constructed to prevent flow beyond
the lens. The clay was extended above and beyond the lens to the north and
the remainder of the excavation backfilled with previously excavated soil
[Appendix B, Figure B-10].
Trenches 2 and 3 had a clay cutoff on top of the sand lens with the
remainder of the excavation backfilled with previously excavated soil
[Appendix B, Figure B-10].
Observation sumps were placed a short distance from the monitoring
sump. It is not clear if the trenches are sloped to either sump. Therefore,
it may not be possible to fully evacuate the trenches when they are pumped.
All monitoring sumps were sand-filled, fabric-lined and 20 feet square.
They extended at least 4 feet below the interceptor trench. A 6-inch PVC
pipe extended into the sump and is used to drain accumulated water.-
Trenches 1 and 2 share a common sump [Appendix B, Figure B-ll].
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54
The observation sump was of a similar construction but only 5 feet to
a side [Appendix B, Figure B-ll].
SAMPLE COLLECTION AND HANDLING PROCEDURES
The Task Force did not observe sample collection and handling by B.H.S.
during the inspection because B.H.S. had yet to initiate sampling of the
new monitoring well system. B.H.S. did assist in purging some wells in
order for the Task Force to take samples. The B.H.S. and Task Force purging
procedures are discussed together with the Task Force sampling procedure in
the section entitled "Task Force Sample Collection and Handling Procedures".
WAIVER OF GROUND-WATER MONITORING REQUIREMENTS DEMONSTRATION
A request for waiver of the interim status ground-water monitoring
requirements was submitted to EPA Region VII by B.H.S. in January 1982.
During review of the request, it was established that downgradient wells
P-5, P-8 and P-10 were not properly constructed (precipitation and surface
runoff may penetrate the wells and fine sediment particles entering the
screens may have plugged the wells) and the wells may not be screened in
the uppermost water-bearing zone. It was also established that the upgra-
dient wells and well MW were not in the same water-bearing zone as the P
wells. During the waiver request review period, the GM wells were
constructed.
The waiver was denied on September 3, 1983. EPA Region VII required
the installation of a new upgradient well (GM-1R) and a new downgradient
well (GM-5). These wells became part of the GM well system and were
installed in 1984.
A Letter of Warning, dated March 6, 1984, was issued by EPA Region VII
requiring the two above wells be installed. In a March 22, 1984 letter,
B.H.S. acknowledged they would comply and the wells were installed.
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55
GROUND-WATER ASSESSMENT PROGRAM AND OUTLINE
Sampling and monitoring under RCRA began with the System 1 wells in
November 1981. The program continued through September 1982 to build an
initial background data base. The installation of the System 2 wells, in
essence, made the data collected from System 1 useless in attempting to
determine compliance with ground-water monitoring requirements.
Sampling and monitoring under RCRA began at the System 2 wells in
December 1983. Required parameters not analyzed for were radium, gross
alpha, gross beta and coliform bacteria. Magnesium was reported instead of
manganese and all metals were reported as dissolved. Monthly sampling to
establish an initial background data base at these wells was conducted.
When well GM-1 was considered by the MDNR and EPA Region VII to not truly
represent background, well GM-1R was installed and initial background data
base sampling began in September 1984 and continued through May 1985.
In September 1985, the first statistical analysis was done for all
downgradient GM wells (GM-1 through GM-5) compared to well GM-1R. The
analysis showed the following statistical differences: well GM-1, decrease
in pH; well GM-2, increase in TOC; well GM-3, increase in specific conduc-
tivity; well GM-4, increase in TOC and TOX; and well GM-5, decrease in pH.
A Ground-water Assessment Plan (GWAP) was submitted to EPA Region VII
and MDNR on February 11, 1986. Its intent was to sample and monitor wells
B-l through B-ll, GMW-1 and GMW-4 to ascertain ground-water quality effects.
The GWAP was reviewed and subsequently amended and approved on April 16,
1986.
The plan calls for three study phases. Phase I is to consist of sam-
pling and analysis of certain B and the two GMW wells for the parameters
listed in Table 11. If contamination is found, Phase II will begin. The
following parameters will be analyzed to identify a contamination plume:
arsenic, barium, cadmium, chromium, lead, mercury and silver. Analysis of
vapors in the soil above the ground water will be used as an indicator of
contamination in the ground water.
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56
Table 11
PHASE I GROUND-WATER ASSESSMENT PLAN PARAMETERS
Indicator Parameter
pH
Ground-Water Quality Parameters
Total phenols
E.P. Metals
Arsenic
Barium
Cadmium
Chromi urn
Lead
Mercury
Selenium
Si 1ver
Volatile Organic Priority Pollutants
Acrolein
Acrylonitrile
Benzene
Bromoform
Carbon tetrachloride
Chlorobenzene
Dibromochloromethane
Chloroethane
2-Chloroethylvinyl ether
Acid Extractables
Naphthalene
Isophorone
Mi seel 1aneous
Maleic acid
Chloroform
Bromodichloromethane
1,1-Dichloroethane
1,2-Dichloroethane
1,2-Dichloropropane
cis 1,2-Oichloropropene
Ethylbenzene
Methyl bromide
Methyl chloride
Methylene chloride
1,1,2,2-Tetrachloroethane
Tetrachloroethene
Toluene
Trans-1,2-diChloroethane
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethene
Vinyl chloride
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57
The plan, as written, reveals that only the previously mentioned
parameters will be analyzed in Phase II. This may not be the true intent
of the Phase II work. Vapors above the soil are to be monitored and the
previously mentioned parameters have extremely low vapor pressures resulting
in extremely low vapor concentrations. Only the organic constituents of
Table 11 will give off vapors in sufficient quantities so that an attempt
can be made to measure them.
An approximate extent of the plume will be defined and additional bor-
ings and piezometers will be installed to confirm the shape of the plume.
An analytical model will be used to determine the flow rate and direction
of the plume movement.
If no contamination is found during Phase I, Phase III will be entered.
This portion of the plan is designed to evaluate whether the GM well con-
struction method caused the statistical differences. If this is the case,
new wells will be constructed and 4 months of sampling will act as background.
The fifth month of sampling will represent the first semiannual analysis
and statistical analyses will be initiated. All other sampling will follow
a semiannual schedule.
Phase I work of the GWAP was instituted on May 1, 1986.
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58
GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT
In its February 1986 Part B application, B.H.S. has proposed a series
of programs, parameters and well locations to be included in a RCRA permit
for Area 2. The application also briefly describes a program for Area 1.
The following is a discussion of these proposals. The RCRA permit will
describe these items in greater detail. The sanitary landfill is omitted
from any of the monitoring programs.
DEFINITION OF WASTE MANAGEMENT AREAS
B.H.S. has divided the facility into two Waste Management Areas (WMAs)
[Figure 7]. WMA1 includes Area 1 and surface impoundments SI-1, SI-2 and
SI-4. WMA2 includes Area 2 and the storage and treatment areas. A Compli-
ance Monitoring Plan for the areas has been proposed by B.H.S. and a proposed
Detection Monitoring Plan and Corrective Action Plan were provided in the
Part B application. Selected B series wells will serve as compliance points.
The site hydrogeology has been divided into two water-bearing zones
(Hydrologic Units A and B) for monitoring purposes. The oxidized glacial
till has been designated Hydrologic Unit A. The unoxidized till and below
to the first bedrock unit has been designated Hydrologic Unit B. All
B-series wells designated as points of compliance are screened in both
units.
POINT OF COMPLIANCE
B.H.S. has designated a network of B wells along the proposed points
of compliance for each WMA. Some of these wells are proposed and are identi-
fied by "(P)" in the following list. Appendix D, Figure D-7, identifies
the location of the wells for each WMA. Wells designated fcr WMA1 are:
B-1A, B-2, B-3A, B-4, B-5, B-6A, B-7, B-8A, B-34(P), B-35(P) and B-36(P).
Wells designated for WMA2 are: B-9, B-10A, B-11A, B-12A, B-12B, B-13, B-14A,
B-15, B-16A or B, B-17C, B-18, B-19A, B-20, B-21A, B-22A, B-23, B-31(P),
B-32(P), B-33(P), B-34(P), B-35(P) and B-36(P).
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59
ASTE MANAGEMENT AREA 1
PROPOSED HAZARDOUS
WASTE DISPOSAL AREA
FIGURE 7. DESIGNATION OF WASTE MANAGEMENT AREAS
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60
For WMA2, the point of compliance is the southern boundary of the
proposed landfill [Appendix D, Figure D-7]. The sufficiency of the point
of compliance proposed for WMA2 cannot be determined until a more thorough
hydrogeologic site characterization is provided and a presentation is made
to illustrate the effects of design, construction and operating practices
on the ground-water flow patterns.
DETECTION MONITORING PROGRAM
Both WMAs are to be monitored under the program. Ground-water quality
background data will be developed and subsequent monitoring results will be
compared to it. Statistical analysis of monitoring data, similar to that
done under interim status, will be conducted.
As proposed in the Part B, semiannual monitoring and sampling will be
conducted at all B, GM and GMW wells for the following parameters:
Arsenic
Lead
Chromium, total
2,4-Dichlorophenoxy acetic acid (2,4,-D)
Phenol
WMA1 monitoring and sampling points will consist of all previously
monitored B wells and wells GM-1 through GM-5, GM-1R, GMW-1 and GMW-4.
WMA2 monitoring and sampling points will consist of all previously moni-
tored B we!Is.
Wells identified in Table 12 are to be monitored monthly for water
level. This is being done to determine the impact of Area 2 on ground-water
flow directions. To best realize this goal, wells should be selected to
represent discrete interconnected intervals and potentiometric maps should
be prepared to depict lines of equal change in head over time.
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61
Parameters chosen for analysis should relate to wastes placed in Area 1,
wastes anticipated to be placed in Area 2 or constituents known to occur in
leachate from Area 1.
Table 12
WELLS FOR MONTHLY
WATER LEVEL MEASUREMENTS
B-1A
B-2
B-3A
B-4
B-5
B-6A
B-7
B-8A
B-9
B-10A
B-ll
B-12A
B-12B
B-13
B-14A
B-15
B-16
B-17A
B-17C
B-18
Truck
Wash
Well
B-18A
B-19A
B-19B
B-20B
B-21A
B-22B
B-23A
B-30 (P)
B-31 (P)
B-32 (P)
B-33 (P)
B-34 (P)
B-35 (P)
B-36 (P)
GM-1
GM-1R
GMW-1
GM-2
GM-3
GM-4
GMW-4
GM-5
K2-OX
K2-80
K2-SA
KS-BR
K3-OX
K3-110
K3-BR
K4-OX
K4-80
K4-120
K4-BR
K4-BRR
K5-OX
K5-80
K5-SA
K5-BR
K6-OX
K6-SI
KC-BR
K7-OX
K7-SI
K7-BR
K9-SA
K9-BR
K10-80
K10-BR
Kll-OX
Kll-SA
Kll-BR
K12-BR
P-18
P-20
P-21
P-22
PA
PB
PC
PD
COMPLIANCE MONITORING PROGRAM
This program will be initiated if the statistical analysis from the
detection monitoring program shows significantly elevated levels of monitored
parameters. A plan will be prepared that will characterize the contaminated
ground water based on 40 CFR 261, Appendix VIII. Table 13 outlines the
minimum list of parameters proposed to be monitored. Others will be chosen
based on the waste accepted for disposal.
B.H.S. will propose action levels for each hazardous constituent
detected, based on background concentrations. All wells that are part of
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62
the detection monitoring program will be monitored at this time. Quarterly
monitoring will be performed and a statistical analysis conducted on the
generated data.
Table 13
PARAMETERS FOR COMPLIANCE MONITORING PROGRAM
Parameter
pH
Specific conductance
Total organic carbon (TOC)
Total organic halide (TOX)
Cyanide, total
Chloride
Phenol
Sulfate
Dissolved arsenic
Dissolved barium
Dissolved chromium
Dissolved cadmium
Dissolved lead
Dissolved mercury
Dissolved silver
Dissolved selenium
2,4-D
2,4,5-TP silvex
Toxaphene
Analytical
Methods
EPA 150.1*
EPA 120.1*
EPA 415.1*
EPA 450.1*
EPA 335.2*
Method 407B**
EPA 625*
Method 426C**
EPA 206.2*
EPA 208.1*
EPA 218.2*
EPA 213.2*
EPA 239.2*
EPA 245.1*
EPA 272.2*
EPA 270.2*
Method 509B**
Method 509B**
Method 509A**
Detection
Limit for
Monitoring
1000 ug/£
10 ug/£
1.0 mg/£
1.0 mg/£
1.0 mg/£
50 (jg/£
1. 0 mg/£
50 ug/£
10 ug/£
50 M9/£
2.0 ug/£
50 ug/£
10 ug/£
100 ug/£
10.0 ug/£
5.0 (jg/£
Methods for Chemical Analysis of Water and Wastes,
EPA 600 4-79-020, March 1979, U.S. Environmental Pro-
tection Agency, Washington, D.C.
Standard Methods for the Examination of Water and
Waste Water, 15th Edition, 1980, American Public
Health Association, Washington, D.C.
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63
CORRECTIVE ACTION PLAN
This program will be initiated if hazardous constituents measured in
the ground water exceed the limits found in Table I of 10 CSR 27.7.011(10).
B.H.S. has left open the course of action it would take to prevent the con-
tamination and indicates that the problem will be studied and actions
developed at that time. The ground-water monitoring system will also be
evaluated to determine the adequacy for contamination delineation.
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64
TASK FORCE SAMPLE COLLECTION AND HANDLING PROCEDURES
Samples were collected from the B.H.S. facility for analysis to
determine if the ground water contains hazardous waste constituents or other
indicators of contamination. This section describes the sampling procedures
followed during the site inspection.
Thirteen stations were sampled comprising nine monitoring wells, two
interceptor trench sumps and two leachate collection sumps [Table 14,
Figure 8]. The wells were selected to provide areal coverage, both upgrad-
ient and downgradient of Area 1. The interceptor trenches receive shallow
ground-water discharge. Two leachate samples were also collected to deter-
mine leachate chemical characteristics and provide a basis for determining
constituents which may leach into and contaminate the ground water.
B.H.S. personnel made all water-level measurements in the wells and
interceptor trench sumps and sometimes assisted in the purging of wells and
sumps. An EPA contactor did most of the well purging and all but one of
the water sample collections. The one exception was interceptor trench 3,
where the sump well casing extends 13 feet above the ground. B.H.S. person-
nel drew the sample while standing on a raised lift of a Caterpilla10 tractor
while EPA contractor personnel stood below and assisted. B.H.S. also drew
all samples from the two leachate collection sumps while EPA contractor
personnel stood upwind. Task Force personnel observed all purging and sam-
pling procedures throughout the inspection.
A complete set of samples was collected from each sample station to be
analyzed by EPA contract laboratories. A complete sample set is shown in
Table 15, which lists the sample parameters with respective containers and
preservatives in the order in which they were collected. Replicate samples
of volatile organic samples and split samples for all other parameters for
each sampling station were offered to B.H.S. but were declined. Sample
sets from well B-8A and PTA leachate sump were provided to NEIC for quality
assurance/quality control purposes.
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65
Samc'e Static"
SAMPLE CGLLEC'IOS DATA
ing '.Ties
End
We
GM-1
GM-5
GMW-1
3-7
15-9 32, 24 'S6 1129 02/26 '86
1215 02 21/S6 1224 02 '21/36
i:i7 C2, 25/36 0919 02/26/86
0907 02 '25,36 0937 02/26/86
0900 02 20 36 0954 02''20/86
3-15 0916
B-20 1441 C2''20"36 1511 02/20/86
B-23A 1011 02'25,86 1036 02/25/86
Interceptor Treneges
Commc- sump 1236 02/20-36 1247 02''20/86
to interceptor
trencnes 1 i 2
Intercepto^ 1114 02/21/86 1128 02''21/86
trencf. 3 Sump
Leac^ate
Oommcr sumo to 1304 02 24/86 1323 02/24/86
t~e''cn 3rea
--encn 2N 1331 02 24-85 13-10 02 24/86
sump
Sample clear; submersible pump,
tripiicate
Sample clear, submersible pump
Sample slightly turbid, ^nooer-
aole Well wizard supstituted
witn Teflon bai1er
Sample clear, Teflon bailer,
NEIC split
Sample clear, Teflon bai"Ier
Sample sligtify turbid, Teflon
bailer
Sample sligntly turbid, Teflon
bailer
Samp]e sligntly turbid, Teflon
bailer
Sample clear, Teflon bailer
Sample clear witn slight sulfur
oacr; suDmersib1e pump
Sample clear, submersible pump,
collectea bv B » S
Sample bro*n- sh-g-^en
ibie pump, NEIO spl't, collected
by B H.S.
Sample cha^coa' -cc '• c»-ed, sub-
me'-siDle pump, co'lected by
B H.S.
* February 2i-2~, 1936 i»as a weekena and no sampling toon place
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66
rctptor Trine h • 3 S um[
INTERCEPTOR
TRENCH »2
PROPOSED HAZARDOUS
WASTE DISPOSAL AREA
1 W ^
^ ^ ^i Common Sump TO ,--""
^ ™ "~ A. lni«rc«pior Tr«n<;h *•
»B-23A
$!-Surf«c* 1 • p o u n d in « o i
FIGURE 8. LOCATION OF TASK FORCE SAMPLE STATIONS WITH FACILITY UNITS SHOWN
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67
Table 15
ORDER OF SAMPLE COLLECTION,
BOTTLE TYPE AND PRESERVATIVE LIST
Parameter
Container
Preservative*
Volatile organic analysis (VOA)
Purge and trap
Direct inject
Purgeable organic carbon (POC)
Purgeable organic halogens (POX)
Extractable organics
Pesticide/herbicide
Dioxi n
Total metals
Dissolved metals
Total organic carbon (TOC)
Total organic halogens (TOX)
Phenols
Cyanide
Nitrate/ammonia
Sulfate/chloride
Radionuclides (NEK only)
2 60-mA VOA vials
2 60-m.e VOA vials
2 60-m£ VOA vials
2 60-m£ VOA vials
4 1-qt. amber glass
2 1-qt. amber glass
2 1-qt. amber glass
1 1-qt. plastic
1 1-qt. plastic
1 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 - pH <2
HN03 - pH <2
H2S04
CuS04 + H3P04
NaOH - pH >12
H2S04
* All samples cooled to 4° C.
All sample containers and preservatives were provided by an EPA contract
laboratory. All sampling equipment was provided by the EPA sampling contrac-
tor. Ground-water samples were collected from each well using the following
protocol:
B.H.S. personnel or their contractor determined the depth to
ground water.
B.H.S. calculated the height and volume of the water column and
amount to be purged.
The EPA sampling contractor and/or B.H.S. purged the amount cal-
culated (less if the well was purged to dryness).
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68
The EPA contractor monitored the open wellhead for chemical vapors
and radiation (before and after purging).
The EPA contractor collected a sample aliquot and conducted field
measurements for water temperature, pH, specific conductance and
turbidity.
The EPA contractor filled VOA vials and then filled the remaining
sample containers in the order shown in Table 15.
The EPA contractor placed the sample container in ice immediately
after col lection.
The reference point from which the depth-to-water measurements are
made at B.H.S. is at the top of the well casing. B.H.S. personnel and their
contractor used a Water Level Indicator (Model 6000 by Slope Indicator Co.)
to make their measurements. The Water Level Indicator probe was improperly
rinsed with deiom'zed water between use in successive wells. Consequently,
the wells were exposed to potential outside or intercontamination. B.H.S.
was able to make repeatable water level measurements to within .01 foot.
The volume of the water column in a well can be calculated by first
subtracting the depth to water measurement from the total depth of the well
(from construction records) to obtain the height of the water column. The
volume can then be calculated using the following formula:
V = nr2h
where: V = water column volume
TT = 3.1416
r = inside radius of well casing
h = height of water column
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69
For the purpose of the Task Force sampling, the amount purged from
each well was equivalent to three water column volumes except as noted below.
During the inspection, B.H.S. made all calculations which were verified as
correct by Task Force personnel.
Dedicated equipment is set up at B.H.S. for the purging and sampling
of wells. Of the 11 wells chosen for this investigation, six are equipped
with Teflon bailers (B-7, B-8A, B-11A, B-15, B-20, B-23A), one with a Well
Wizard® pump (GMW-1) and four with submersible pumps (GM-1, GM-5, both
interceptor trench sumps). The Well Wizard at GMW-1 was not functioning
and, therefore, was replaced by a Teflon bailer on a stainless steel cable
provided by the EPA contractor.
Before and after purging, the EPA contractor monitored each open well-
head for chemical vapors and radiation. Chemical vapors were measured with
one of three instruments: (1) Century Systems Portable Organic Vapor
Analyzer Model OVA-128; (2) HNU Model Pl-101 Photoionization Analyzer or
(3) Photovac, Inc. TIP (Total lonizable Present). Radiation measurements
were made with a Ludlum Measurements, Inc. Model 3. Measurements are shown
in Table 16. At stations where measurements exceeded background levels,
sampling personnel wore Level C protection. Otherwise, Task Force personnel
wore Level D protection during sampling .
From the wells with bailers, water was manually evacuated and discharged
into 55-gallon drums at each wellhead. Responsibility for disposal was
left to B.H.S. The submersible pumps in wells and interceptor trenches
require electrical power sources, which were provided by a B.H.S. electric
generator. Electrical connections were made by B.H.S. personnel. Again,
responsibility for disposal of the purged water was left to B.H.S. In
accordance with B.H.S. standard operating procedures, the water was dis-
charged directly onto the ground. Table 17 lists the purge times and
volumes purged from each station.
Well Wizard is a registered trademark; appears hereafter without the §.
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70
Table 16
CHEMICAL VAPOR AND RADIATION DETECTIONS
AT SAMPLE STATION WELLHEADS
Sample Station
GM-1
GM-5
GMW-1
B-7
B-8A
B-11A
B-15
B-20
B-23A
Common sump to
interceptor
trenches 1 & 2
Interceptor
trench 3
Common sump to
progressive
trench area
Trench 2N sump
Chemical Vapor
Level (ppm)/
Meter Used
BackgroundVTIP
Background/TIP
Background/TIP
Background/OVA
5/TIP
80/TIP
Background/TIP
Background/TIP
Background/HNU
Background/TIP
Background/TIP
20/HNU
20/HNU
Radiation
Level
(mr/hr)
Background**
Background
Background
Background
Background
Background
Background
Background
Background
Background
Background
Background
Background
* Chemical vapor background level is 3 ppm.
** Radiation background level is 0.1 mr,hr.
In some cases, the intended (calculated) purge volume could not be
evacuated in a single attempt due to dewatering of the well. Purging con-
tinued after a time allowing the well to recharge. If the well failed to
produce the calculated purge volume after three or four purge attempts, the
total volume purged was noted and sampling commenced after recharge. Stand-
ard B.H.S. purging procedure for the interceptor trenches is to allow the
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71
Table 17
PURGING DATA
Sample Station
Purging Times*
End
Approximate
Volume
Purged
(gal Ions)
Remarks
GM-5
GMW-I
B-7
B-8A
B-11A
B-15
B-20
B-23A
Interceptor
trench 3
1628 02/20/86 1019 02/24/86
1350 02/20/86 1113 02/21/86
32
1204 02/21/86 1212 02/21/86 83
1450 02/21/86 1116 02/24/86 9
1355 02/19/86 1451 02/19/86 19
1611 02/21/86 1000 02/24/86 13*5
1320 02/19/86 1626 02/19/86 10
1535 02/20/86 1104 02/24/86 16*5
1500 02/19/86 1054 02/20/86 15*5
1503 02/21/86 0944 02/24/86 8*5
Common sump to 1205 02/20/86 1235 02/20/86 480
1nterceptor
trencnes 1 & 2
218
Wei1 dewatered, purgec Dy
B.H S.
Purged by B.H.S.
Well dewatered; purged by
B.H.S. , EPA Task Force
personnel and EPA
contractor
Purged by EPA contractor
We1! dewatered, purged by
EPA contractor
Well dewatered; purged by
E?A contractor
Well dewatered; purged by
EPA contractor
Well dewatered; purged by
EPA contractor
Well dewatered; purged by
EPA contractor
°urged by B.H.S.
Purged by B.H.S.
* February 22-23, 1966 was a weekend and no purging or sampling took place.
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72
pump to run for 30 minutes before sampling. The Task Force followed this
same procedure. The leachate systems were not purged before sampling.
After purging, a sample aliquot was collected for field measurements
(water temperature, specific conductance, pH and turbidity) which were made
at the EPA contractor's staging area (a garage unit near SI-2). Volatile
organic analysis (VOA) vials were the first sample containers filled, fol-
lowed by the order listed in Table 15. The VOA vials were filled directly
from the bailer or an intermediary glass beaker if a submersible pump was
used. All other sample containers were sequentially filled directly from
the bailer or pump hose.
B.H.S. personnel conducted the sampling at the leachate collection
systems (trench 2N ana the progressive trench area) and interceptor trench 3,
with the assistance of EPA contractor personnel. Difficulty with access to
interceptor trench 3 caused a safety problem in sampling from the 13-foot-
high outer well casing while standing atop the raised platform of a Cater-
pillar tractor.
At some stations, as in the case of purging, the ground-water recharge
was slow and the well dewatered while sampling. Rather than collecting the
entire sample set in a single attempt, all the sample parameters were col-
lected in as many as four attempts over a period of 3 days, as in the case
with GM-1. While the collection of a sample set may have been discontinuous,
the collection of each parameter was completed in one attempt. Moreover,
for the assurance of having enough ground water to obtain a complete sample
set, some parameter containers were only partially filled. (VOA vials,
however, were always completely filled, as required for proper analysis.)
The sample containers of those parameters requiring more than one container
(extractable organics, pesticides/herbicides, dioxin and radionuclides) or
of each parameter of a split sample contained equal volumes. For example,
instead of filling three of the four bottles for extractable organics com-
pletely while filling the fourth only partially, all four bottles were filled
with an equal, though reduced volume.
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73
After sampling was completed at each well, EPA contractor personnel
took the samples to the staging area where a turbidity measurement was taken
and the aliquot for dissolved metals analysis was filtered. In addition,
samples for analysis for metals, total organic carbon, phenols, cyanide,
nitrate and ammonia were preserved as indicated in Table 15. Leachate
samples were not preserved.
At the end of each day of sampling, the EPA sampling contractor pack-
aged and shipped the samples to the EPA contract laboratories and the NEIC
laboratory, as appropriate. Samples were shipped according to applicable
Department of Transportation regulations (40 CFR Parts 171-177). Aqueous
samples from monitoring wells and interceptor trench sumps were considered
"environmental" and those from leachate collection system sumps were con-
sidered "hazardous" for shipping purposes. The EPA sampling contractor
also prepared a set of field blanks for each analytical parameter (e.g.,
VOAs, organics, metals, etc.) each day. Field blanks were used to determine
whether contamination was introduced from the sample collection activities
or sampling environment.
One set each of trip blanks and equipment blanks was prepared by the
EPA sampling contractor during the investigation and shipped to the EPA
contract laboratory. Trip blanks were used to determine whether contamina-
tion was introduced from the sample containers during transport to and stor-
age at the B.H.S. facility, and equipment blanks were used to determine if
contamination was introduced from the bailer used at GMW-1. All blanks
were prepared at the staging area using distilled, deionized water of a
known high purity.
Additional QA/QC samples submitted by the EPA sampling contractor to
the EPA contract laboratories were the performance evaluation (PE) samples
and triplicate samples. The PE samples were initially prepared by the EPA
Environmental Monitoring and Support Laboratory in Cincinnati and were used
to evaluate the accuracy of analyses performed by the contract laboratories.
Triplicate samples of each analytical parameter taken at GM-1 were used to
evaluate the precision of the analytical methods employed by the contract
laboratories.
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74
MONITORING DATA ANALYSIS FOR INDICATIONS OF WASTE RELEASE
Tabulation, evaluation and interpretation of analytical data for samples
collected during the inspection and analyzed by EPA contractor laboratories
are discussed in detail in Appendix A. Inorganic chemical constituent
analyses of these samples indicate the presence of common, naturally occur-
ring cations and anions. In addition, selenium was found in wells B-11A
and B-15 at 164 ug/L and 280 ug/L, respectively. Because of the newness of
some of the ground-water monitoring wells in the system being evaluated
(B-11A and B-15), it is not appropriate to attempt to undertake a statistical
comparison of upgradient and downgradient ground-water quality. This compar-
ison should be made as soon as 1 year of quarterly sampling and analytical
results are available from the new system of wells. Evaluation of the organic
chemical constituent analyses indicate the presence of 1,2-dichloroethane
and acetone in well GM-1. Purgeable organic halide (POX) results indicate
that methylene chloride may also be present in this well. The source of
these organic constituents in samples should be determined and the first
year of quarterly sampling and analysis of the new ground-water monitoring
system wells should be completed to confirm whether or not ground water at
the facility contains hazardous waste constituents resulting from waste
disposal activities.
Trenches IN, 2N, 6N, UN, 12N and the PTA have leachate collection
systems. All other disposal trenches and drilled cells at Area 1 are unlined
and have the potential for leakage.
Due to the incomplete hydrogeologic characterization of the site and
the questions regarding ground-water flow direction, the wells may not be
properly placed or constructed to intercept leakage.
-------
REFERENCES
1. D.E. Klockow and Associates, December 31, 1981, "Engineering Design
Manual, Harzardous Waste Management Facility Permit Application Amend-
ments and Revisions", prepared for B.H.S., Inc. (included as part of
the August 1983 Part B Application)
2. D.E. Klockow and Associates, August 3, 1983, "Part B RCRA Application",
prepared for B.H.S., Inc.
3. D.E. Klockow and Associates, April 1984, "Geotechnical Investigation,
Soil Geology and Hydrogeology", prepared for B.H.S., Inc.
4. Reitz and Jens, Inc., April 1980, Bob's Home Service, Inc., Special
Waste Disposal Facility", Wright City, Missouri, prepared for Bob's Home
Service, Inc.
5. Reitz and Jens, Inc., July 1980, "Bob's Home Service, Inc., Hazardous
Waste Disposal Facility", prepared for Bob's Home Service, Inc.
6. Woodward-Clyde Consultants, March 15, 1985, "Evaluation of 1984 Ground-
Water Monitoring Data", prepared for B.H.S., Inc.
7. Woodward-Clyde Consultants, February 14, 1986, "Part B RCRA Permit
Application",, prepared for B.H.S., Inc.
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APPENDICES
A ANALTYICAL TECHNIQUES AND RESULTS FOR TASK FORCE SAMPLES
B CONSTRUCTION DRAWINGS
C POTENTIOMETRIC SURFACE MAPS
D GROUND-WATER MONITORING SYSTEMS
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APPENDIX A
ANALTYICAL TECHNIQUES AND RESULTS FOR TASK FORCE SAMPLES
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A-l
Appendix A
ANALTYICAL TECHNIQUES AND RESULTS FOR TASK FORCE SAMPLES
B.H.S. INC.
Wright City, Missouri
The following discusses analytical techniques, methods and results for
water and leachate samples collected by the Task Force at the B.H.S., Inc.
facility, Wright City, Missouri. 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 specific conductance,
pH and turbidity, were made by the EPA sampling contractor at the time of
sampling. No field measurements were made for the leachate samples. Labo-
ratory analysis results were obtained from two EPA contractor laboratories
(CL) participating 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) the 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) the analysis
of laboratory duplicates and field triplicates to estimate precision. The
performance evaluation (PE) samples were samples of known analyte concentra-
tions prepared by the EPA Environmental Monitoring Systems Laboratory, Cin-
cinnnati, Ohio. Split samples from well B-7 and leachate from the Progres-
sive Trench Area (PTA) were also analyzed by NEIC.
Table A-l provides a summary, by parameter, of the analytical techniques
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.
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A-2
WATER SAMPLE ANALYSIS RESULTS
Specific Organic Analysis Results
Acetone and 1,2-dichloroethane were quantified in samples from well
GM-1. This well was sampled as the field triplicate and all three samples
were reported to contain between 7.6 pg/L and 8 pg/L 1,2-dichloroethane.
The three samples were found to contain acetone at concentrations of 46 pg/L,
46 pg/L and 39 pg/L after laboratory blank contamination correction. An
acetone laboratory blank level of 10 pg/L has been subtracted from the above
acetone concentrations. Purgeable organic halide (POX) results indicate
the presence of about 22 pg/L halogen which is substantially more than that
contributed by the 1,2-dichloroethane. Methylene chloride was detected in
the samples; however, three field blanks were also found to contain methyl -
ene chloride. The methylene chloride concentration cannot be reliably quan-
tified because the field blank concentrations were 1.1 pg/L, 1.2 pg/L and
5 pg/L while the sample concentrations were about 10 pg/L. The POX results
indicate, however, that methylene chloride may be present in the ground
water at well GM-1 and warrants further investigation.
None of the organic compounds determined were detected above blank
levels in the other monitoring well samples, interceptor trench 1 and 2
sump and interceptor trench 3 sump; however, acid extractable compounds
should be considered to have not been determined for all samples except
those for wells GM-1 and GMW-1. The acid surrogate compound recoveries
were below the lower CLP limit even after re-extraction. Table A-2 contains
the limits of quantisation for the analyses for the volatile, semi volatile,
pesticide, PCB, herbicide and dioxin organic compounds.
Analysis of the PE sample for pesticides, herbicides, dioxins and
dibenzofurans was apparently performed very poorly. An investigation has
established that shipping and handling of the PE samples for only these
specific organic constituents was the major contributing factor. The appro-
priate PE samples were net analyzed for the particular class of compounds
for which the samples were intended. Thus, poor performance on the PE
samples is not reflective of the data quality of the other sample analyses.
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A-3
NEIC did not receive the dioxin and dibenzofuran data. According to
the PRC QA/QC data review, no dioxin target compounds were found in any of
the samples. Dioxin spike recoveries ranged from 95% to 170%. The Lockheed
QA/QC data review stated that there was contamination at a level of approx-
imately 10 ng/L within 10 scans of 2,3,7,8-TCDF in the samples from wells
GM-1 and GM-5.
Control measures for the other analyses indicate that sample analysis
results are reliable with the exception of the acid extractable compounds
results discussed above. Further, NEIC split sample results for the sample
from well B-7 agree with the CL results in that neither detected any vola-
tile, semivolatile, pesticide or PCB compounds above blank contaminant
levels.
Metals Analysis Results
The dissolved and total metals results for the water samples are
reported in Tables A-3 and A-4.
Caution must be exercised in associating any significance to trace
element concentrations determined by the Inductively Coupled Argon Plasma-
Optical Emission Spectroscopy (ICAP-OES) analysis. The CL did not make
background corrections for the ICAP-OES analyses. This may result in posi-
tive biases for trace elements when large concentrations of aluminum, cal-
cium, iron or magnesium are present in the samples. Further, the CL ICAP-OES
analysis for many of the trace elements may be biased low due to the negative
drift allowed for the calibration blanks. The negative bias was as much as
307 ug/L for aluminum, 164 ug/L for antimony, 4 ug/L for cadmium, 16 u/L
for chromium, 15 ug/L for cobalt, 34 ug/L for copper, 18 ug/L for nickel,
22 ug/L for silver, 66 ug/L for tin, 13 ug/L for vanadium and 12 ug/L for
zinc. The negative blank values arise from letting the intercepts of the
calibration curves drift. More frequent calibration was needed. Any
detected concentration for these elements could be biased low by the values
1isted above.
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A-4
The CL reported 925 (jg/L total lead in the sample from well GMW-1 as
determined by ICAP-OES. Examination of the raw data found that the CL
obtained this value from the analysis of a 1 to 5 dilution of the sample.
The diluted sample value was 185 ug/L. The calibration blank values for
lead ranged from -96 ug/L to 25 ug/L and calculation of the detection limit
from these blank values gives a detection limit of 200 ug/L. Thus the
diluted sample value is unreliable, as it is below the detection limit.
The CL did analyze the undiluted sample and obtained a value of 603 ug/L.
The lead analytical line is severly interfered on by an adjacent aluminum
spectral line; however, the CL made no interference correction for the
apparent lead due to the aluminum interference. Thus, the lead concentra-
tion that should have been reported would be 393 ug/L. The sample was found
to contain 131,000 ug/L aluminum which according to the CL would cause an
apparent lead concentration of 210 ug/L. Interference corrections of such
magnitude, relative to the sample concentration, are not highly accurate
and the 393 ug/L value should not be considered accurate. The CL did a
screening analysis of this sample using furnace Atomic Absorption Spectros-
copy (AAS) but did not quantitate the concentration appropriately. The AAS
analysis for lead is not interfered on by aluminum and indicated the concen-
tration to be greater than 200 ug/L.
The dissolved elemental concentrations determined by 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. In comparison of the CL results for the well B-7 samples, the
dissolved concentrations for manganese, potassium and sodium are about 50%
higher than the total concentrations while calcium and magnesium dissolved
concentrations are about 15% higher than the total concentrations. In com-
parison to NEIC split sample results for well B-7, the CL dissolved con-
centrations for calcium, magnesium, manganese, potassium and sodium are
about 30% higher than NEIC split sample results. Further, the CL total
concentrations are from 10% to 20% lower than NEIC total concentrations.
For barium and zinc the dissolved concentrations are at times about
twice the total concentrations. These dissolved barium concentrations are
in part higher than the total concentrations because of mismatching of the
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A-5
acid matrix. For barium, the digestion used for the total analysis may
have caused barium sulfate to precipitate. Zinc contamination due to field
sample handling of the dissolved samples has been identified for past Task
Force projects and is the suspected cause of much of the bias evident for
the dissolved zinc results.
Dissolved and total silver spike recoveries were biased low. The sample
analysis results for silver are, however, reported because the spike levels
may have exceeded the solubility allowed by the chloride concentration of
the spiked samples. The detection limit for silver has been increased based
on the average spike recovery. Copper spike recoveries were also quite low
indicating that values are unreliable and may be biased low. Aluminum dup-
licate analyses showed wiae variability which probably indicates the presence
of suspended solids.
The detection limits for the ICAP-OES analyses were recalculated based
on the variability observed for the calibration and field blanks between
several analytical runs. The recalculated detection limits increased over
those reported by the CL. As part of the detection limit recalculations,
the average negative blank value was added to the detection limit calculated
from the blank variability. The sample results are reported using the recal-
culated detection limits.
The CL reported results for arsenic, lead, selenium and thallium did
not account for furnace Atomic Absorption Spectroscopy (AAS) matrix effects.
These effects were corrected for by use of the known addition recoveries.
Further, detection limits were recalculated based on the variability in the
calibration curves, on the variability in the signal response and on the
known addition recoveries.
The CL reported total lead concentrations of 69 ug/L, 109 ug/L and
110 ug/L for the field triplicate samples for well GM-1. Examination of
the raw data indicates that the lead analyses for these samples are in error.
The CL analyzed the samples at various dilutions with concentrations of
69 ug/L, 83 ug/L and 110 ug/L being obtained for one of the samples. THS
-------
A-6
discordance of the dilution values suggests the presence of an interference
in the analysis and that the results are unreliable.
Fairly high selenium concentrations were reported by the CL for two of
the wells. The samples from wells B-11A and B-15 were reported to contain
164 fjg/L and 230 ug/L total selenium, respectively. The dissolved selenium
concentrations for these well samples were also high. Because the CL used
deuterium arc background correction for the furnace AAS analysis, such con-
centrations are often considered suspect because of the inability of the
correction system to compensate for high nonatomic background due to the
presence of high salt concentrations. However, the salt compositions of
these two samples are not substantially different than those of some of the
other samples where selenium was not detected or detected at much lower
concentrations. For example, the sample from well B-20 was found to contain
greater concentrations of sulfate and generally greater concentrations of
the major cations, yet selenium was not detected in this sample. This sug-
gests that the background correcting capability of the instrument may not
have been exceeded. Although NEIC did not receive samples from wells B-11A
and B-15, NEIC did find 15 (jg/L total selenium in the sample from well B-7
while the CL reported 17 jjg/L total selenium. NEIC determined selenium by
hydride generation coupled to ICAP-OES. This close agreement between labor-
atories using different analytical techniques suggests the CL selenium con-
centrations are reliable. It is possible that the well B-11A and B-15 samples
contain unique components that cause interference and confirmational analyses
are warranted before placing much significance on the CL selenium results
for these two well samples.
High iron concentrations cause a negative bias in deuterium arc back-
ground corrected furnace AAS analysis for selenium. Thus, when significant
iron was found in a sample, the selenium results may be unreliable. Simi-
larly, high aluminum concentrations cause a positive bias in deuteriuir arc
backgrounded furnace AAS analysis for arsenic. Thus the arsenic results
for samples containing high aluminum may be unreliable.
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A-7
The mercury analysis detection limits ranged from 0.4 ug/L to 1.8 ug/L
depending on the volume of the sample analyzed. The detection limit calcu-
lated from the variability in the calibration curve and blank values was
0.036 ug which for 100 ml of digested sample would give a detection of
0.36 ug/L instead of the 0.2 ug/L reported by the CL. There are two indica-
tions that the laboratory had contamination problems. The initial analysis
of one of the dissolved mercury field blanks found a concentration of 2
ug/L while a subsequent analysis of the same blank found less than 0.2 ug/L.
For dissolved mercury, the CL reported values of less than 0.2 ug/L for two
of three field triplicate samples from well GM-1 and reported 0.7 ug/L for
the third sample. The total mercury values for the field triplicate samples
were reported as less than 0.2 ug/L.
General Analysis Results
The field measurements for conductance, pH and turbidity and the
results of other analytical testing for the water samples are reported in
Table A-5.
All control measures indicate that the ammonia, cyanide, nitrate and
sulfate results should be reliable.
The PE sample result and comparison with the NEIC split sample for well
B-7 indicate that the CL chloride values are biased low. The PE sample had
a true value of 22.1 mg/L with an acceptance range of 19.6 mg/L to 25 mg/L.
The CL reported a value of 15 mg/L for the PE sample. NEIC obtained a
chloride value of 14 mg/L for well B-7 while the CL reported 10 mg/L. Other
control measure results were acceptable.
Examination of the raw data reveals that the CL analyzed four spiked
samples for phenol; however, only two spike recoveries were reported.
Aliquots of the samples from wells B-7 and B-20, the Interceptor
Trenches 1 and 2 Sump ana a field blank were spiked. Recoveries of 100%
were reported for both well B-7 and the field blank spiked samples. Calcu-
lation of the recovery for tne Trench spiked sample gives a recovery of 52%
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A-8
and the well B-20 spike recovery was 10%. Further, the CL analyzed the
well B-7 spiked sample twice and when the recoveries are calculated from
the raw data, recoveries of 50% and 74% are obtained. It is not known how
the CL calculated a 100% recovery for the well B-7 spiked sample. Another
indication that the phenol results are dubious is that the CL analyzed the
sample from well B-11A in duplicate and obtained concentrations of 10 ug/L
and 109 (jg/L. This set of duplicate data was not, however, reported on the
CLP duplicate analysis reporting sheet. Further, the CL reported a value
for the PE sample that was unacceptable with a 39% positive bias. These
data indicate the phenol results may be unreliable. The detection limit
was recalculated based on the variability in the blank over the analysis
run and in the calibration curve and a value of 33 ug/L instead of the CL
reported limit of 10 ug/L was obtained.
Control measures generally indicate the nonpurgeable organic carbon
(NPOC) and the purgeable organic carbon (POC) results should be reliable;
however, the laboratory blanks for these parameters were often high and
varied widely. NPOC blank values ranged from 0.13 mg/L to 2.12 mg/L. The
NPOC detection limit calculated from the variability in the blank values is
2.2 mg/L. Many of the sample NPOC values are close to the detection limit
and, thus, should not be considered highly accurate. The POC blanks ranged
from about 1.7 mg/L to 4.3 mg/L. These blank values are quite high and
would affect the accuracy of the calibration standards prepared with this
water. That is, a signal response calibrated as being due to 10 mg/L POC
would actually be due to the presence of 14 mg/L POC. Such a calibration
would cause a sample concentration to be under estimated. Another possible
error is that sample concentrations obtained from dilutions using this water
would result in over estimating the sample concentrations. Because of these
possible sources of error, the POC results may be unreliable and, thus, are
not reported.
All control measures indicate that the purgeable organic halide (POX)
results are reliable. A detection limit of 8 ug/L instead of the CL reported
limit of 5 ug/L was calculated from the variability in the blank values.
POX was detected in all three field triplicate samples from well GM-1. The
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A-9
reported POX values were 16 ug/L, 23 ug/L and 26 (jg/L. As discussed
previously, 1,2-dichloroethane and possibly methylene chloride were detected
in the samples from GM-1.
Although most control measures indicate that the total organic halide
(TOX) results should be reliable, the TOX values may be biased low. The
lack of correlation between the POX values and TOX values for the samples
from GM-1 suggests the TOX values are biased low. Further, as discussed
below in the leachate sample analysis section, TOX values are definitely
biased low. Calculation of the detection limit based on the variability in
the blank values results in a detection limit of 12 ug/L instead of CL
reported limit of 5 ug/L.
LEACHATE SAMPLE ANALYSIS RESULTS
Specific Organic Analysis Results
Table A-6 reports the organic constituent analysis results for the two
leachate samples. Large amounts of volatile and semivolatile organic com-
pounds were detected in both leachate samples.
In consideration of the different dilutions analyzed, thus different
detection limits, fairly good agreement was obtained between the split sample
analyses performed by NEIC and the reported CL values for the PTA leachate.
NEK analyzed a 1 to 10 dilution for the volatiles while the CL analyzed a
1 to 100 dilution. The concentrations for the detected volatile organic
compounds differed very little from NEIC results. The CL reported that
1,1-dichloroethane was present but below the Limit of Quantitation (LOQ).
NEIC found 400 ug/L 1,1-dichloroethane with an LOQ of about 60 ug/L. Further,
NEIC detected the presence of 1,2-dichloroethane, trichloroethene and
tetrachloroethene, although the concentrations were below the LOQs. NEIC
also found 500 ug/L xylene, 8,000 ug/L 2-propanol, 3,000 ug/L 2-butanol and
the presence of 4-methyl-2-pentanol that were not determinea or not detected
by the CL.
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A-10
Similarly, the CL analyzed a more diluted extract for semivolatiles.
Benzoic acid and phenol were the major semivolatiles found. The CL D5-phenol
surrogate recovery was only 12% and the CL reported the phenol concentration
in the sample as 2,000 ug/L. NEIC obtained a 40% recovery for the D5-phenol
surrogate recovery and found 8,000 ug/L phenol in the sample. Correction
of the CL phenol concentration for the recovery would indicate that the
sample actually contained about 17,000 ug/L phenol while correction of the
NEIC value would indicate that about 20,000 ug/L phenol was present. NEIC
also detected 700 ug/L 2-methylphenol, 220 ug/L 2-nitrophenol, 90 ug/L
4-methylphenol and 30 ug/L 2,4-dimethylphenol. The colorimetric phenol
analysis found 41,000 ug/L total phenol which indicates the presence of
other phenolic compounds that were not quantified or determined by the gas
chromatography-mass spectroscopy analysis.
Metals Analysis Results
The total metals results for the leachate samples are reported in
Table A-7. Depending on the suspended matter composition, the values
reported for certain elements may not represent "total" concentrations. If
the suspended matter is siliceous then values for aluminum, calcium, magne-
sium, potassium and sodium are not "total" because the silicate matrix was
not dissolved. The heavy metal results would approximate "total" concentra-
tions because they are usually absorbed and are not incorporated into the
silicate matrix.
NEIC split sample ICAP-OES results for the PTA leachate sample analysis
agree fairly well with the CL results. For example, the CL reported
6,370,000 ug/L potassium and 2,240,000 ug/L sodium while NEIC found 6,900,000
ug/L potassium and 2,030,000 ug/L sodium. The CL reported 717 ug/L nickel
and NEIC found 707 ug/L.
The CL encountered difficulties in analyzing the PTA leachate for
arsenic, lead and selenium. Apparently, the high dissolved solids content
of the sample caused background correction problems for the furnace AAS
analyses. NEIC found 27 ug/L arsenic and less than 7 ug/L selenium for the
-------
A-ll
PTA split sample. Hydride generation coupled to ICAP-OES was used by NEIC.
Less than 7 (jg/L lead was found by NEIC using Zeeman Effect background cor-
rected L'vov platform furnace AAS.
The CL raw data for the arsenic analyses are confusing in that it
appears that there may have been a mixup between the two leachate samples.
For the analysis run, the PTA sample was given a run number of 42 while the
other leachate had a run number of 41. The analysis of sample 42 found
15.4 ug/L and the analysis of a 20 pg/L arsenic spike to sample 42 gave a
concentration of 76.7 ug/L which is a spike recovery of 307%. A number of
different dilutions of sample 42 were analyzed and concentrations ranging
from 94 ug/L to 250 ug/L were obtained. Sample 42 was then analyzed by the
methods of standard addition and 125 ug/L was found; however, the 125 (jg/L
value was reported for the Trench 2N leachate and the PTA arsenic was
reported as less than 150 ug/L. Analyses of sample 41, which was the
Trench 2N leachate, indicate the presence of about 140 ug/L arsenic, although
analysis by the methods of standard addition was not performed. Since,
the CL results are confusing and interference was apparent, no arsenic data
is reported in the data table.
General Analysis Results
Table A-8 reports the results of other testing for the leachate samples.
The calculated POX from the specific volatile organic results for the
PTA leachate and the measured POX are in good agreement. It is obvious,
however, that the TOX is biased substantially low.
The anion data are in general agreement with NEIC split sample results.
NEIC did, however, detect 25 ug/L cyanide while the CL reported less than
10 ug/L. Only 3 mg/L ammonia was found by NEIC while the CL reported
30 mg/L.
-------
A-12
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A-13
Table A-2
LIMITS OF QUANTITATION FOR ORGANIC COMPOUNDS
B H S. , INC.
Wright City, Missouri
Limit of Limit of Limit of
Quantitatior Quantitation Quanti tatic"
(pg/'L) (pg/L) (.pg/L)
vc'atile Compounds (Purge
firomomet.hane
Chloromethane
Bromodich'oromethane
Dibromochloromethane
Bromof orm
Chi orof orm
Carbon tetracnloride
Carson ai sul f iae
CMoroetnane
1, 1-Oich'oroethene
1, -Dich'oroetnare
1, , l-Tri chioroethane
1, ,2-T'ichloroethane
1, ,2,2-Tetracnioroethane
1, -C'Chloroethane
trans- 1.2-Oicnloroethene
Trichloroethene
Tet'achloroethene
Methylene cn'oriae
Vinyl chlonde
1,2-Qichloroprcpare
cis-1.3-Cic*'cropropene
trans- 1. 3-D icnl oropropene
Be~zere
Ch'oro&erzene
Et^> lbenzene
To~ ,,ene
>V e-es
Acetone
2-3utanor,e
2-iexanore
4-Methv 1 -C'Dentanone
2~ Ch 1 c roetny 1 vinyl etrer
Styrene
\pinyl acetate
^'"Ot.C^S G 6 "^ v GG
i. t " j * D^'Qr[\Q'"3~c^ ic^CDrop'S
l,*,I,2-Tet,racn1orGeinane
"" - r • r-T-f-rnfpt *• a fi p
1,3 j~ ' ricM^oi~GprcpanG
1 , H ~ Q i c h or*o~t"bdX.snfi
"r- ch'orof luorome thane
Ac^olem
Acwj "or- tn le
h
Vo^fle Compounds (DAI)
MC^y loii t^l "e
i ^"^^OXSHB
M f y ' 3 i C 0 HC 1
b~ ^ ' cysn'Cs
Isoo-tyl alcohol
Metnacryloni tri le
Acr^" P' r
-• > - ' y . -
& ' *"3D )
1C
10
5
5
5
5
5
5
-, ^
iU
5
5
5
5
5
5
5
5
5
10
1'j
5
5
5
5
5
5
5
5
10
10
1.0
10
10
5
1 J
50
e 20
20
C,
5
20
5
50
50
r [-,
SO
ICO
5 0
1 no
1 - U
ICO
25
"inn
iO U
50
Semi -Vol at- 1 e Compounds
Am 1 1 ne
4-Chloroam 1 me
2-Ni troani 1 i i«
3-Ni troahi ! i ne
4-Ni troani 1 i ne
Benz'di ne
3,3' -D'cnloroDenz'dme
Benzyl alcohol
Benzy' crlor'de
,2-Cichlorobenze~e
J-Dic^^robenzeie
,4-0^"' loroDerze-e
,2 ,4-Trich'oropenzene
,2,4,5-Tet-achlorobenzene
,2,3.4-Tetrachlorobenzene
'entacnio-ooenjene
hexachiorobenzene
pentachlororitrobenzene
Nitrobenzene
2 .4-Oi ni trotol uene
2 ,5-Di ni trotoluene
N-Ni t re sod1 methyl ami ne
N-Nitrcsoaichenylammes
N-Nitrosoai-ropvlamme
P1s(2-Chloroethyl ) ether
4-Cn loropheny' pneny" ether
4-3romcpheny i phenyl ethe'
bi s(,2-Ch loroi sopropy i ) ether
Pi s(2-Chloroethoxy ) methane
hexacnloroethane
HexachloroDutadiene
Hexachlorocyclopentad'ene
b-s(2-Ethylnexyl) pntnalate
Butyl benzyl ohtha'ate
oi-n-Butylphthalate
di-n-Octy'^ntnalate
Ciethylpnthalate
C 'methy Iphthalate
Acenapn*hene
Acenaphthy lene
Anthracene
Benzo(.a)anth-acene
Benzo(c)f 1 ucranthene and/or
5e-zo(k)flLC'ahthene
BenzcvQ.h , i Jperylene
Benzo(a)pyrene
Cn'-vsene
C'berzo(a,h)anthracehe
n. £g-; J« jran
F" ^cranthene
Inflenc\1.2,3-c,d)pyrene
i 5 u 0 . ^ - . 6
N3~,Ktnaiene
2-Ch loronaphtPa1eie
2-Methvlnaohthaiehe
P^era"tnrene
Pyene
5-Si tro-c-toTu'd'.-e
20
20
100
100
100
100
40
20
x r\
•*u
20
20
20
20
40
40
40
20
40
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
1 f
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
~Tl
i.U
20
40
Semi-Volatile Compounds (cont
N- nitrosodi ethyl ami ne
Acetopnenone
N-mtrosodipipendine
Safrole
1,4-Napthoaumone
2 ,3,4,6-Tetrachiorophenol
2-Napthylamme
Pyndme
Pentachloroethene
1.3,5-tnmtrobenzehe
Ethylmethacrylate
o-Toluiaine hydrochlonde
2,6-Dichlorophenol
p-Dimethylaminoazobenzene
1,2,3-Trichlorobenzene
1,3,5-Trichlorobenzene
1,2,3,5-Tetrachlorobenzene
Ethyl-methanesulfonate
alpha, alpha-
Dime thy Iphenethyl ami ne
Methapyrilene
7.12-Dimethylbenzanthracene
Benzal chloride
Zih-opnos
4-Aminobiphehyl
Tetraetnyldithiopyro-
phosphate
3,3'-Oimethylbenzidihe
Pronantide
Chloro&*nzi late
o-?hehylenediamine
m-Pheny lenediami ne
p-Phehy'enediamine
Isosafro le
N-Nit'osopyrro1idine
A^aim te
Dial late
D^methoxyDeni'dine
Be nzctrich! Gride
N' trosinethyl ethyl ami he
N-Nitroso-di-N-butylamine
Cydophospham^de
^exachloroprcpene
= henacetm
Resorcmol
Dimethoate
4,4(Methylene-bis
(2-chlcroam 1 me)
Oa-aioehyde
Methyl methare sulfonate
N-mtrosomorBnolme
1-Naphthylamme
1.2-Dipnehyihydrazme
Benzoic acid
Phenol
2-Chloropheno1
2,4-Oich!orophenol
2.4,5-Trichlorophenol and/or
2,4,6-Trich'crcpnenol
}
20
40
40
40
40
40
40
40
40
40
•+ _i
40
40
40
40
40
40
40
40
40
40
40
40
40
40
40
4C
40
40
* ^
"U
40
40
40
40
** J
4C
£ ^
160
40
160
40
4C
40
40
40
40
40
40
40
ICO
20
20
in
100
-------
A-14
TaDle A-2 (cort.)
Quart'tat';
Se"n-vclati le Compounds \:ont )
Pentachloropheno i 100
4-Chloro-3-methylphenoi 20
2-Methy iphenol 20
4-Hethylphenol 20
2,4-Dimethylphenol 20
4,5-Dim tro-2-meth> Ipne^ol IOC
2-Nitropnenol 20
4-Ni tropneno1 100
2 ,4-Din' trocnenol 100
;n
Pest-cides 'PCEs
Aidrin
a^ha-BHC
beta-BHC
ga^ma-BHC
aelta-BHC
Chiordane
4.4'-DDO
4. 4 '-DOE
4.4' -OCT
Oie'dr-n
Enacsdifar I
Ercosu! 'an I!
Enaosulfan sol'ate
Encnr
Meptac"' or
H 6 [j t. 3 C I"! ' Or GJDOX 1 G6
f Ox ^D^ff np
Hetnoxj,:hlor
Endr1 1 k,e tone
PCB-1016
PCS- 1221
PC3-1232
PCB-1242
POB-124S
PCB-1254
prg-^_26C
Kepone
Limi t of
Quanti tafo
(M9/D
0 05
0 05
0 05
0 05
0 05
0 5
0 1
0 1
0 1
0 1
0 05
0 1
0 1
0 i
C 1
0 05
^i ^ C
d UD
1
0. 5
CT
1
0 5
0 5
0 5
0 5
0 5
1
1
0 1
n
herDic-des
QicamDa
Dalapon
MCPP
MCPA
Dichloroprop
2,4-Oichlorophehoxy
acetic acid
2,4,5-T
2,4-08
Oinoseo
Oioxms 4 3 ibenzo*urans
TCDO (Tet-a)
PeCDO (Penta)
HxCDD (Hexa)
HpCDO (lepta)
OCOD (Octa)
TCDF (Tetra)
PcCDF (Penta)
HxCDF (hexa)
HpCDF (Hepta)
CCDFF (Octa)
Limit o *
Quanti tation
(ug/L)
i
2
100
100
2
4
1
4
J.
(nq, u
5
6
4
44
i
3
3
17
13
easjrec as rip.T
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A-15
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APPENDIX B
CONSTRUCTION DRAWINGS
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E-l
44
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FIGURE B-l
TRENCH 1-N
(REVISED FROM B.H.S. INC.)
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FIGURE B-3
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FIGURE B-4
TRENCH 11-N
(REVISED FROM REITZ *TENS. INC.)
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LCS-Leachate Collection System
FIGURE B-5
TRENCH 12-N
(REVISED FROM REITZ ft JENS. INC.)
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B-6
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APPENDIX C
POTENTIOMETRIC SURFACE MAPS
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APPENDIX D
GROUND-WATER MONITORING SYSTEMS
-------
D-l
PROPOSED HAZARDOUS
WASTE DISPOSAL AREA
W«lli
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D-2
PROPOSED HAZARDOUS
WASTE DISPOSAL AREA
Flgur* D-2. Sy»ttra '2 W«lli
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D-3
INTERCEPTOR |\
TRENCH •!
PROPOSED HAZARDOUS
WASTE DISPOSAL AREA
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D-4
PROPOSED HAZARDOUS
WASTE DISPOSAL AREA
Flgur« D-4. W«IU P-17 through P-22
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PROPOSED HAZARDOUS
WASTE DISPOSAL AREA
Figure D-t. K-icri
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D-6
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PROPOSED HAZARDOUS
WASTE DISPOSAL AREA
Fi3urt D-6. W.IU PA through PD
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