May 7987 EPA-700 8-87-073
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Hazardous Waste Ground-Water
Task Force
Evaluation of the
Four County Landfill,
Fulton County, IN
US Environmental Protection Agency
Indiana Dept of Environmental Management
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MAY 1987
UPDATE OF THE HAZARDOUS WASTE GROUND-WATER TASK FORCE EVALUATION
OF FOUR COUNTY LANDFILL
The United States Environmental Protection Agency's (U.S. EPA) Ground-Water
Task Force ("Task Force"), in conjunction with the Indiana Department of
Environmental Management (IDEM), conducted an evaluation at the Four County
Landfill (FCL) hazardous waste disposal facility. The FCL facility, owned
by James Wilkins and operated by Environmental Waste Control, Inc. of
Wabash, Indiana, is the twenty-third facility investigated by the Task
Force. The FCL facility is located in the northwest corner of Fulton
County, Indiana, approximately 13 miles northwest of Rochester.
The on-site inspection was conducted from June 9 through June 13, 1986.
The purpose of the Task Force evaluation was to determine the adequacy
of the ground-water monitoring system in regard to the ground-water
monitoring requirements under the Resource Conservation and Recovery
Act (RCRA). Specifically, the objectives were:
0 To determine compliance with the applicable State ground-
water monitoring regulations 320 IAC 4.1-20 (40 CFR Part 265).
0 To evaluate the ground-water monitoring program described in
the RCRA Part B permit application for compliance with 320
IAC 4.1-34-5(c) and 4.1-54 (40 CFR Part 270.14(c) and Part
264 Subpart F).
0 To determine if hazardous constituents have entered the
ground water at the facility and,
0 To determine if the facility is meeting the requirements of
the superfund off-site policy.
This update of the Task Force evaluation summarizes the series of events
and actions that have occurred at the facility subsequent to the field
inspection.
I. The Task Force concluded that the ground-water monitoring system
currently in place is inadequate for compliance with the ground-
water monitoring requirements under RCRA. The outstanding ground-
water monitoring deficiencies in Indiana's complaint (Cause No.
209) and the adopted consent decree of 1984 and 1985 are still
unresolved.
FCL retained the services of a consulting firm to conduct a
detailed hydrogeology study of the site. FCL has installed
additional wells and some piezometers.
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chic.igo. IL 60604-3590
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However, the information from these new wells and borings does not
show compliance with the adopted consent decree, or resolve the
ground-water monitoring deficiencies. IDEM is preparing a referral
of the ground-water monitoring violations to U.S. EPA.
II. On July 24, 1986, IDEM referred FCL to U.S. EPA Region V for
possible violations of Section 3005(e)(2) of RCRA and also
violations of Section 3004(o) of HSWA.
III. U.S. EPA on October 16, 1986, referred these violations to the
Department of Justice (DOJ) and on February 5, 1987, DOJ filed
a suit against the owner and operator of the facility. The
suit contends that the owner/operator's legal authority to
operate the landfill terminated on November 8, 1985, because
the defendants certified compliance with Indiana financial
responsibility requirements when, in fact, they did not possess
the minimum insurance coverage.
The suit also alleges the violation of the minimum technology
requirements since the defendants engaged in lateral expansions
of the facility and placed hazardous waste in separately excavated
landfill cells without the required double liner and leachate
collection system. The suit asks the court to bar the defendants
from treating, storing or disposing of any additional hazardous
waste in land disposal units, to close these units, to remedy
all violations of the minimum technology requirements, and to
pay a civil penalty.
IV. On August 18, 1986, FCL began placing hazardous waste in the new
double lined area.
V. On February 13, 1987, IDEM sent a notice of deficiency (NOD)
to FCL for Part B of its RCRA permit application. FCL has
until June 30, 1987, to submit the required information. IDEM
is proposing a draft decision to be published by September 30,
1987.
VI. The U.S. EPA is currently reviewing the ground-water monitoring
violations for possible additional enforcement action. Based on
the Federal Judiciary Statute, IDEM is preparing to exercise
the right to intervene as a co-plaintiff in the current law suit
filed by the U.S. EPA against FCL.
In recent months, activities at the facility have generated much public
interest. It is the contention of the local residents that adverse health
effects are being produced by toxics escaping the landfill. On April 3,
1987, the Agency for Toxic Substances and Disease Registry (ATSDR)
notified the U.S. EPA of its proposal to obtain a health impact assess-
ment for FCL. Pursuant to Section 3019(b)(2) of the Solid Waste Disposal
Act, the U.S. EPA on March 19, 1987, formally requested the assistance
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of ATSDR in performing a health assessment for FCL as authorized by Section
104(b) and (i) of the Comprehensive Environmental Response, Compensation
and Liability Act (CERCLA).
ATSDR is now reviewing the available data and plans to send U.S. EPA a
draft proposal on the health assessment. Also in response to concerns
raised by the local citizens, the U.S. Fish and Wildlife Service has
submitted a study plan to the U.S. EPA, IDEM, ATSDR and the Indiana State
Board of Health. The study plan proposes a survey of contaminants in the
wetlands and biota near FCL.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUND WATER TASK FORCE
GROUND WATER EVALUATION
FOUR COUNTY LANDFILL
FULTON COUNTY, INDIANA
MAY 1987
JOSEPH J. FREDLE
PROJECT COORDINATOR
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION V
ENVIRONMENTAL SERVICES DIVISION
EASTERN DISTRICT OFFICE
WESTLAKE, OHIO
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TABLE OF CONTENTS
Page
LIST OF TABLES iii
LIST OF FIGURES iii
LIST OF APPENDICES iv
I. EXECUTIVE SUMMARY
A. Introduction 1
B. Summary of Findings and Conclusions 3
1. Compliance with Interim Status Ground Water
Monitoring Requirements - (320 IAC 4.1-20) 3
a. Ground Water Monitoring System 3
b. Sampling and Analyses 4
c. Preparation, Evaluation, and Response 5
d. Record Keeping and Reporting 5
e. Lateral Expansion 6
2. Ground Water Monitoring Program Proposed for RCRA
Permit 6
3. Task Force Sampling and Monitoring Data Analysis 6
4. Compliance with Superfund Off-Site Policy 7
II. TECHNICAL REPORT
A. Introduction 7
B. Objectives 8
C. Investigation Methods 9
1. Technical Review Team 9
2. Laboratory Evaluation Team 10
3. Sampling Team 11
D. Facility Operation, Design and History .-. 13
1. Background 13
2. Facility Operation 13
a. Introduction 13
b. Waste Handling Operations 14
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TABLE OF CONTENTS (continued)
Page
3. Old Waste Management Units 19
4. Future Waste Management Units 22
b. Operation with Regard to Future Units 23
E. Hydrogeology 24
1. Geomorphology 24
2. Hydrogeologic Units 25
3. Hydraulic Conductivity 27
4. Ground Water Flow 28
F. Ground Water Monitoring Under State Solid Waste Program 29
1. History 29
2. Previous State Evaluation of Ground Water Monitoring System . 30
a. RCRA Ground Water Monitoring 30
b. Sampling and Analyses Plan 31
c. Preparation, Evaluation and Response 31
d. Potential Compliance with 40 CFR 264 and 270 35
3. Other Monitoring During Interim Status 37
G. Task Force Evaluation for Compliance with RCRA 38
1. Evaluation of Ground Water Monitoring System 38
2. Evaluation of Sampling and Analyses Plan 41
3. Evaluation of Preparation, Evaluation and Response 43
4. Evaluation of RCRA Permit Application 43
5. Off-Site Laboratory Evaluation 47
6. Summary and Recommendations 48
H. Water Quality Data Interpretation 49
1. Task Force Analysis 49
2. Interpretation of Monitoring Well Data 49
3. Interpretation of Surface Water Data 57
REFERENCES
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LIST OF TABLES
Table 1 Order of Sample Collection Bottle Type and Preservation List
Table 2 Wastes Accepted at Four County Landfill
Table 3 Information About Borings Drilled at Four County Landfill
Table 4 Well History and Description for Monitoring Wells at Four
County Landfill
Table 5 Hydraulic Conductivity Results (1/23/79) Four County Landfill
Fulton County, Indiana
Table 6 Four County Landfill RCRA Interim Status Ground Water
Monitoring Parameters
Table 7 Well Construction Information for Monitoring Wells at Four
County Landfill
Table 8 Parameters and Analytical Techniques Employed by Task Force
Contract Laboratories
Note - Tables are located at back of report.
LIST OF FIGURES
Figure 1 Site Location Map
Figure 2 Past Designations of Waste Management Areas
Figure 3 Boring and Monitoring Well Location Plan
Figure 4 General Site Plan
Figure 5 Approximate Proposed Unit Layout
Figure 6 Construction Details of Cell Walls and Liners as Planned
For Future Installation
Figure 7 Geologic Cross Section A-A1
Figure 8 FCL Presumption of Ground Water Flow Directions
Figure 9 Sample Location Plan
Note - Figures are located at back of report.
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LIST OF APPENDICES
Appendix A Sampling Information
Appendix B QA/QC Summary of Task Force Data
Appendix C Analytical Results of Task Force Sampling
Appendix D Task Force Sampling Parameters
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I. EXECUTIVE SUMMARY
A. Introduction
Concerns have recently been raised as to whether the commercial hazardous
waste treatment, storage, and disposal (TSD) facilities are in compliance
with the ground water monitoring regulations to detect contaminant releases
from waste management units at TSD facilities. In response to these concerns,
the Administrator of the U.S. Environmental Protection Agency (EPA) established
a Hazardous Waste Ground Water Task Force (Task Force) to evaluate the level
of compliance at TSD facilities and address the cause(s) of noncompliance. The
Task Force is comprised of personnel from EPA Headquarters, including the Office
of Solid Waste and Emergency Response (OSWER), EPA Regional Offices, and State
regulatory agency personnel. To determine the status of facility compliance,
the Task Force is conducting in-depth facility investigations, including on-
site inspections at 58 TSD facilities nationwide. The objectives of these
investigations are to:
- Determine compliance with interim status ground water monitoring require-
ments of applicable State regulations 320 IAC 4.1-15 through 32 (40 CFR
Part 265). Facilities that lose interim status are still subject to
monitoring regulations.
- Evaluate the ground water monitoring program described in the facility's
RCRA Part B permit application for compliance with 320 IAC 4.1-34-5(c)
and 4.1-40-54 (40 CFR Part 270.14(c) and Part 264 Subpart F, respectively).
- Determine if the ground water at the facility contains hazardous waste
constituents.
- Provide information to assist the Agency in determining if the TSD facility
meets EPA ground water monitoring requirements for waste management
facilities receiving waste from response actions conducted under the
Comprehensive Environmental Response, Compensation and Liability Act, as
stated in Reference 1.
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To address these objectives, the Task Force will determine if:
- The facility has developed and is following an adequate ground water
sampling and analysis plan.
- Designated RCRA and/or State required monitoring wells are properly
located and constructed.
- Required analyses have been conducted on samples from the designated RCRA
monitoring we! Is.
- The ground water quality assessment program outline (or plan, as approp-
riate) is adequate.
The twenty-third TSD facility investigated by the Task Force was the Four
County Landfill (FCL) located in the northwest corner of Fulton County, Indiana,
approximately 13 miles northwest of Rochester (see Figure 1-Note that all figures
and tables can be found in the back of this report). The on-site inspection was
conducted from June 9 through June 13, 1986, and was coordinated by personnel
from EPA Region V. In general, the investigation involved review of State,
federal, and facility records; facility inspection; laboratory evaluation; and
sampling and analysis of ground water and surface water at the facility. The
geographic coordinates of the site are 41°07'45"N, 86°25'50"W in Fulton County,
Indiana (T31N, R1E, Sec. 16, southern half of southwest quarter). FCL is owned
by James A. Mil kins and is operated by Environmental Waste Control, Inc. of
Wabash, Indiana. Mr. Wilkins owns two parcels of land at this location.
Parcel A is located to the west of Rt. 17 and "is the present operating landfill
which had interim status under RCRA (ID No. IN000780544). Parcel B is located
to the east of Rt. 17 and is being considered for use in the RCRA Part B permit
application.
In the past, waste management areas at this facility have been designated as
Sections 1 through 6 (see Figure 2). Sections 1 and 2 have been used for
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general refuse, while Sections 3 through 5 have been used for "separate-area"
waste (pre-RCRA) and RCRA waste. Section 6 was reserved for future use.
During the Task Force investigation, hazardous waste was being placed in
Section 3. General refuse disposal was discontinued in 1978.
Future plans, as outlined in the facility's RCRA Part B application, call
for converting the complete site to a series of double lined cells. Such a
cell was in the process of being constructed in Section 6 of the landfill
during the Task Force inspection.
B. Summary of Findings and Conclusions
1. Compliance with Interim Status Ground Water Monitoring Requirements -
Indiana Regulations 320 IAC 4.1-20-1 through 20-5 (40 CFR 265 Subpart F)
a* Ground Water Monitoring System 320 IAC 4.1-20-1 through 20-2 (40 CFR
265.90-91)
The current RCRA ground water monitoring system at FCL consists of wells
W-6, W-20, W-21, W-22, W-23s, W-23m, and W-23d series (Note W-23 series are
shown on figures as one well). Prior to the installation of these RCRA wells,
seven wells (W-l through W-7, see Figure 3) were installed in 1978 for the
purpose of monitoring the solid waste disposed prior to the RCRA ground water
monitoring requirements that were promulgated on May 19, 1980. Well W-6
is designated as the upgradient well. An in-depth investigation of the site
hydrogeological data by the Task Force found the ground water monitoring system
currently in use as grossly inadequate for compliance with 320 IAC 4.1 (40 CFR
Part 265 and Part 270).
FCL began interim status background monitoring in December 1982, one year
after the effective date of the RCRA regulations. To date, FCL has failed to
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adequately define the uppermost aquifer beneath the facility. The number,
depths, and locations of the existing wells in relation to the Waste Management
Area (WMA) does not comply with 320 IAC 4.1-20-2 (40 CFR 265.91). The integrity
of the pre-RCRA wells (W-l through W-8) is not adequate to meet requirements of
320 IAC 4.1-20-2(c)(40 CFR 265.91(c)). Available ground water elevation data
suggests that ground water flow may not be in the direction that FCL contends.
Historically, the flow has been presumed by FCL to be in the northeasterly
direction. The facility needs to obtain more information to clarify the true
flow direction.
The total number of downgradient and upgradient RCRA monitoring wells that
will be required cannot be accurately assessed until more is known about the
ground water flow direction and site hydrogeology. Recent sampling results
would indicate that older wells with poor construction methods and materials
may be influencing the pH of ground water samples retrieved from them.
The Indiana Department of Environmental Management had previously identified
these deficiencies and issued enforcement actions, Cause Nos. N-128 and V-209.
The inadequate hydrogeological site characterization, well placement, and
well construction renders inadequate any assessment monitoring that FCL may
presently be performing "using the existing ground water monitoring system.
In essence, the Task Force concludes that the preliminary information needed to
design and operate a ground water mmonitoring program at a land disposal facility
is lacking.
b. Sampling and Analysis 320 IAC 4.1-20-3 (40 CFR 265.92)
The Task Force determined that FCL is not achieving the requirements of this
regulation. The Indiana Department of Environmental Management, through the
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inspection program, determined that the Sampling and Analysis Plan was not
followed during sampling events. The procedures for some aspects of sampling,
as described in the plan, are so general that it would be difficult to determine
if the sampler was following the proper procedure.
The deficiencies in the Sampling and Analysis Plan aspect of the ground
water monitoring program are included in the aforementioned State enforcement
action, Cause No. V-209.
c. Preparation, Evaluation, and Response 320 IAC 4.1-20-4 (40 CFR 265.93)
The Task Force determined that FCL has not achieved the requirements of
this regulation. FCL failed to properly evaluate the ground water monitoring
data and subsequently failed to respond with a ground water quality assessment
plan describing a program capable of adequately determining: (1) the rate and
extent of migration of hazardous waste or hazardous waste constituents in the
ground water; and (2) the concentrations of hazardous waste or hazardous waste
constituents in the ground water.
These deficiencies are included in the State enforcement actions, Cause Nos.
N-128 and V-209.
d. Recordkeeping and Reporting 320 IAC 4.1-20-5 (40 CFR 265.94)
As of June 1986, the Task Force determined that FCL is generally achieving
the requirements of this subpart. Overall, FCL is maintaining the records and
reports to the Agency as required by this regulation. However, FCL began a
ground water monitoring program for RCRA in December 1982, about one year later
than required.
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e. Lateral Expansion 3004(0) of RCRA
On June 10, 1986, the Task Force noted that FCL was engaging in the lateral
expansion of the facility. The Task Force observed the excavation of a new
unlined cell that was used for disposal of hazardous waste the next day. For
existing landfills that engage in a lateral expansion after May 8, 1985,
Section 3004(0) of RCRA requires the following standards be met: (1) installa-
tion of two or none liners and (2) a leachate collection system. This new cell
did not meet these standards.
2. Ground Water Program Proposed for RCRA Permit Standards
FCL has not proposed to alter the current ground water monitoring program in
the application for a RCRA permit. FCL's proposed Part B ground water monitor-
ing program was determined by the Task Force to be inadequate for the same
reasons that the current monitoring program is inadequate. Thus, major revi-
sions to Part B of the permit application are necessary.
3. Task Force Recommendations Regarding the Ground Water Monitoring Program
(a) FCL must conduct an in-depth study to characterize the site hydrogeology.
(b) FCL must install a monitoring network to meet the objectives of 320 IAC
4.1-20-45 (40 CFR Parts 265 and 264), and to obtain the information
needed for 320 IAC 4.1-34-5 (40 CFR Part 270).
(c) The Task Force recommends that due to the past high monitoring results,
the parameters characterizing the suitability of the ground water (gross
alpha, gross beta, drinking water, pesticides, and total coliform) as a
drinking water supply, be monitored in all new wells to be installed
upgradient or at the downgradient limit of the waste management area.
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(d) The Task Force recommends that all wells on site be monitored until a
final permit decision is made.
(e) The Task Force recommends that the detection levels for all drinking water
parameters be no greater than half of the standard for that parameter.
Also, the detection level of total phenol should be 5 parts per billion.
(f) The Task Force recommends that the cause of the contamination of the
southwest drainage basin be further investigated.
(g) A new detailed Sampling and Analysis Plan must be prepared and followed.
Based on the results, FCL must take the appropriate response measures
such as corrective action, plume description, etc.
4. Compliance and Superfund Off-Site Policy
Under the 1986 Superfund Ammendments and Reauthorization Act (SARA), if
an off-site TSD facility is to be used for land disposal of waste from a
Superfund-financed or enforced cleanup of a CERCLA site, the TSD facility must
be in compliance with the applicable requirements of RCRA. The disposal
units at the off-site TSD facility must not be releasing hazardous constituents
into the ground water, surface water, or soil.
The available evidence obtained and evaluated during the investigation
of the FCL facility indicates that a contaminant plume is originating from the
hazardous waste units. The facility presently is operating in the assessment
monitoring phase without a corrective action order program approved under
Subtitle C of RCRA. Therefore, FCL is not eligible for disposal of Superfund
waste under the off-site policy.
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II. TECHNICAL REPORT
A. Introduction
Operations at hazardous waste treatment, storage, and disposal (TSD) facili-
ties are regulated by the Resource Conservation and Recovery Act (RCRA P.L.
95-580). The Indiana Department of Environmental Management (IDEM) has been
given the authority by the USEPA to administer the RCRA program. Regulations
issued pursuant to RCRA (40 CFR Parts 260 through 265, as modified) and 320
IAC 4.1 address waste site operations including monitoring of ground water to
ensure that hazardous waste constituents are not being released to the environ-
ment.
The Administrator of the Environmental Protection Agency (EPA) established
a Hazardous Waste Ground Water Task Force (referred to hereafter as Task Force)
to evaluate the level of compliance with ground water monitoring requirements at
on-site and commercial off-site TSD facilities and address the cause of noncom-
pliance. In addition, the Task Force is to examine the suitability of the
facility as a provider of treatment, storage, or disposal services for waste
managed by the Agency's Superfund program. The Task Force is comprised of
personnel from EPA Headquarters, Regional offices, and the States. Currently,
58 TSD facilities are scheduled for ground water monitoring evaluations. One of
these is Four County Landfill (FCL), near Rochester, Indiana.
B. Objectives
The objectives of the Task Force evaluation at FCL were to:
- Determine compliance with the requirements of 320 Indiana Administrative
Code 4.1-20-1 through 20-5 (40 CFR 265 Subpart F) - Ground Water
Monitoring and the monitoring system's capability of providing the
requi red data.
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- Evaluate the facility's ground water monitoring program as described in
the RCRA Part B permit application for compliance with 320 IAC 4.1-34-
5(c) (40 CFR Part 270«14(c)).
- Evaluate the facility's potential compliance with 320 IAC 4.1-45-1
through 45-11 (40 CFR Part 264 Subpart F).
- Verify the quality of the company's ground water monitoring data and
evaluate the sampling and analytical procedures.
- Determine if any ground water contamination currently exists from site
operations.
- Provide information to assist the Agency in determining if the TSD
facilities meet EPA ground water monitoring requirements for waste
management facilities receiving waste from response actions conducted
under the Comprehensive Environmental Response, Compensation and Liability
Act, as stated in Reference 1.
C. Investigative Methods
The Task Force investigation of FCL consisted primarily of:
- Reviewing and evaluating records and documents from USEPA Region V, the
Indiana Department of Environmental Management (IDEM), and Four County
Landfill.
- Conducting an on-site inspection from June 9 through 13, 1986.
- Evaluating two of the off-site laboratories contracted by FCL for analysis
of past and present ground water samples.
- Sampling and analyzing data from the ground water monitoring wells and
surface water on and adjacent to FCL.
To accomplish the objectives, a Facility Evaluation Team was assembled,
comprised of a Technical (record) Review Team, a Laboratory Evaluation Team
(to evaluate off-site contractor laboratories), and a Sample Collection Team.
Each team had individual responsibilities to achieve the objectives of the
Task Force.
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1. Technical Review Team
The Technical Review Team was responsible for conducting the evaluation of
the facility with respect to applicable ground water monitoring requirements.
The team's objective was to determine compliance with 320 IAC 4.1-15 through
32 (40 CFR 265 Subpart F) and potential compliance with 320 IAC 4.1-45-34-5c
(40 CFR 264 Subpart F and 40 CFR 270.14(c)). The evaluation was divided into
six principal areas as follows:
- waste characterization and operations
- site history and design
- site hydrogeology
- ground water monitoring system
- ground water sampling and analysis
- ground water quality data and interpretation
The Task Force core team in Washington D.C., contracted with Planning Research
Corporation (PRC) of Chicago, Illinois, to prepare a document package of perti-
nent background information from public information sources, such as agency
files. The information collected by PRC primarily concentrated on site events
since about 1978 (e.g., inspection reports, hydrogeologic reports, and the Part
B application) and projected future activities. Aerial photographs of the site,
State geologic maps, and information obtained from FCL were also reviewed to
supplement the accuracy of the information in the public files. Combining
these information sources, the Technical Review Team was able to perform a
thorough evaluation of the facility with respect to the ground water monitoring
system.
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2. Laboratory Evaluation Team
The off-site laboratories that analyze water samples for the FCL were
evaluated by USEPA Region V Quality Assurance Office. FCL has used different
laboratories over the past six years to collect ground water samples and perform
analyses for parameters specified in 320 IAC 4.1-20-1 through 20-5 (40 CFR 265
Subpart F). The laboratories used currently are EMS Laboratories, 7901
W. Morris Street, Indianapolis, Indiana, and OA Laboratories, Inc., 1437 Sadlier
Circle, West Drive, Indianapolis, Indiana. Organic parameters were subcon-
tracted by OA Laboratories to Shrader Laboratories in Detroit, Michigan.
Shrader Laboratories was partially evaluated by the Task Force through informa-
tion made available by OA Laboratories.
3. Sampling Team
Samples for the Task Force evaluation were collected by Versar, Inc.,
hereafter called Versar, an EPA contractor, under the continuous supervision of
the Sampling Team Leader from USEPA Region V. Sampling procedures followed
those outlined in the June 1986 Quality Assurance Project Plan (Reference 7)
for this site. FCL personnel also accompanied the sampling team at all times,
and video tapes were made of some of the sampling activities. Bailers provided
by Versar were used to sample all of the wells. All samples and blanks were
split with the facility. All sample bottles and preservatives were provided by
Versar for Task Force samples and split samples distributed to FCL.
Prior to purging, Versar personnel monitored the open well heads for
chemical vapors using a HNU* photo-ionization detector as a safety precaution
to the sampling personnel. Task Force personnel then measured the depth to
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water using electronic water level indicators provided by Versar. This measure-
ment was used to calculate purge volumes. The Task Force's goal was to purge
three volumes of water from the well before sampling. Purge volumes were
measured in calibrated containers. Purging the three volumes was not always
possible because some wells exhibited slow recovery rates. In this situation,
the procedure used was to purge the well dry (if three volumes could not be
obtained) and return the next day to start sampling. All well purge waters
were disposed on the ground per the facility's instructions. If three volumes
could be obtained for the purge and water remained in the well, sampling
commenced immediately. Sampling continued until a complete sample set was
collected or the well ran dry. If the well ran dry, the team would return
the next day to complete the sampling (see Appendix A).
Samples were collected in the parameter sampling order shown in Table 1.
Appendix A details the purging and sampling information. Two wells, the Trailer
well and well W-8, had dedicated pumps and were purged and sampled using these
pumps. Well W-23D was purged and sampled using a bladder pump provided by
Versar.
Volatile organic samples collected for analysis by the EPA contract
laboratory and FCL were collected directly from the bailer into 60 ml glass
vials with Teflon® septa. Remaining sample aliquot containers were also filled
directly from a dedicated bailer, parameter by parameter, to obtain an exact
split. Volatile organic samples from surface water sites were first collected
in dedicated beakers and then poured into 60 ml Teflon® septum vials. Other
surface water sample aliquots were collected directly into sample containers.
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After sampling was completed at a well, EPA contractor personnel took
the samples to a staging area where field measurements of turbidity, pH, and
conductance were taken and one of the two sample aliquots for metals analysis
was filtered. In addition, metals, TOC, phenols, cyanide, nitrate and ammonia
samples were preserved. The EPA contractor prepared a field blank for each
parameter group (e.g., volatile organics, metals). A trip blank and two equip-
ment blanks were also sent for analysis.
At the end of each day, samples were packaged and shipped to the two EPA
contract laboratories according to applicable Department of Transportation
regulations (49 CFR 171-177). Aqueous samples from monitoring wells and surface
locations were considered "environmental".
D. Facility Operation, Design, and History
1. Background
FCL is located on State Route 17 approximately six miles south of Culver and
three miles northwest of Leiters Ford in Fulton County, Indiana (see Figure 1).
The property encompasses 61.5 acres of which Parcel A, 40 acres, lies west of
new State Route 17 and Parcel B, 21.5 acres, lies to the east. About 23.0
acres in Parcel A are subject to regulation under ground water monitoring
requirements of the Resource Conservation and Recovery Act (40 CFR 265) and 320
IAC 4.1-15 through 32. Figures 2, 3, 4, 5, 8, and 9 attached to this report
show Parcel A; Parcel B is not included.
The region is composed of hilly glacial terrain. In relation to the
surrounding properties, the site is located on a ridge. In general, property
surrounding the facility is open fields, wooded lots, and cultivated land.
Property to the north and east is partially subdivided. Two drinking water
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wells are on the facility's property^ the farm house well (also known as
well W-8) and the trailer well near the facility entrance from State Route 17
(Figure 3). Three residences with domestic wells are within 600 feet of the
site.
2. Facility Operations
a. Introduction
Preacceptance records, operational records and waste management units
were identified and studied to determine the sources and types of contaminants
that might enter the ground water. FCL disposes of hazardous waste as defined
in 320 IAC 4.1-3 through 6 (40 CFR 261) and regulated under RCRA by landfilling.
Landfills that handle hazardous waste (also called "separate area" waste in
Indiana prior to RCRA) are required to get a Letter of Approval from the State
of Indiana for each waste stream the landfill accepts. Generators are required
by 320 IAC 4.1-7 through 11 (40 CFR 262) to determine if the waste they generate
is a hazardous waste. In some cases, the State of Indiana requires analyses to
be submitted before a Letter of Approval is given.
Prior to November 19, 1980, FCL did not keep complete records of waste
types and volumes that FCL accepted. The facility's owner (Mr. James Wilkins)
stated during the Task Force Inspection that the waste accepted prior to November
19, 1980, was similar to that accepted between 1980 to 1983. Table 2 lists the
hazardous wastes identified in the facility's Part A application from 1980 to
1983. After 1983, FCL submitted a revised Part A application and began accepting
fewer wastes, restricting waste streams to predominantly emission control dust
and extraction procedure (EP) toxic waste containing heavy metals such as
cadmium, chromium, and lead (see Table 2).
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b. Waste Handling Operation
FCL's handling procedure for waste, from preacceptance to disposal, is
discussed in the Waste Analysis Plan (WAP). The procedure was reviewed to
determine the facility's ability to characterize the waste with respect to
volume, waste type, and waste characteristics. During the Task Force inspec-
tion, a load of waste was followed through the facility to observe FCL charac-
terizing ("fingerprinting") the waste received and accurately recording the
amount, type, and disposal location of the waste. The preacceptance and
tracking records from three waste loads: one received during the inspection;
one received six months earlier; and one received a year earlier, were checked
for completeness. The documents listed below are used by FCL to track various
streams. These documents were complete and on file for all waste streams
checked by the Task Force.
Preacceptance and tracking records include:
- A Letter of Approval from the Indiana State Board of Health for each
waste stream accepted.
- An annual laboratory analysis of the waste (provided by the generator).
- Hazardous Waste Inspection, Sampling, and Testing (1ST) report.
- Bench sheets of daily loads (listing generator, approximate volumes,
etc.).
- A comparative sample of the waste from a previous shipment of a waste
stream for reference purposes.
FCL's procedure for characterizing the waste when accepting it at the
gate were observed and compared to the WAP. In general, FCL follows the
WAP, but several deficiencies were noted in the WAP, The deficiencies are
discussed below. In the past, waste was delivered in bulk and in barrels so
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that different procedures were necessary to evaluate the waste being accepted.
FCL is currently only accepting bulk loads of hazardous waste.
The facility performs a visual inspection of each load and some simple lab
tests on a composite sample from each load. The general details (e.g., generator
and intended disposal location) for the load are also recorded on the daily
bench sheet. Recently, a technician was hired by FCL to perform the inspection
and analyses to characterize the waste at the gate. Mr. Wilkins stated that
he, one of the equipment operators, or the receptionist performed the gate
inspections before the technician was hired.
During the Task Force inspection, a truck was followed through the facility
from arrival to departure. This truck contained a bulk load of hazardous
foundry sand (D008) from Globe Valve Company. It was delivered on June 11,
1986, in a roll-off box (with about 14.5 cubic yards) that arrived covered with
a tarpaulin. The load was labeled as a 90-day accumulation of hazardous waste
with an accumulation date of June 6, 1986. The contents of the box were red,
black, and gray sand and a few pieces of general refuse (i.e., wood spool and
cardboard).
The load was measured with a steel tape to determine the volume being
delivered and it was compared to the manifest to see if it matched the volume
shipped. Measurement of the length, width, and depth of the box was made.
The depth from the top of the box to the top of the load was measured and
subtracted from the total depth and the volume of waste determined. The calcu-
lated volume was not within 8% of the volume reported on the manifest. The
generator was called to resolve the discrepancy. A variance of less than 8% is
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considered within specification by FCL. The operator and generator concurred
that the full load of foundry sand must have settled in transport. This problem
suggests that weight rather than volume would be a more representative measure
of delivered waste.
The load was then probed with a steel rod to see if it was consistent and no
containers (drums) were concealed beneath the sand.
During the inspection, an 1ST report was completed. This report describes
general characteristics of the waste, such as:
- Color
- Odor
- Texture
- Moisture
- Consistency or variation of all the above
The results of the inspection and 1ST report are compared to the description
of the waste from the annual lab analyses submitted by the generator and a
representative sample taken from previous loads. If these characteristics do
not match or if the load contains any free liquids seen in or falling from the
truck, the load is rejected.
The technician then took a small composite sample from the load. A PVC
scoop was used to take grab samples from four locations on top of the load.
This sample was placed in a container and tested on site for the following
characteristics:
- Flash point
- PH
- Free Liquid
- Radioactivity
- Reactivity - group determination
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The flash point of the waste was tested by directing the flame from a
cigarette lighter at the sample to see if it would ignite. The pH was
determined by mixing some of the sample with deionized water, mixing the sample,
and measuring the pH with a meter. No test (such as a paint filter test) was
performed to determine if free liquids were present. FCL considered the visual
inspection of the truck to be adequate. A simple test was performed to determine
if the waste was radioactive. Wastes are assumed to be compatible based upon
the waste types the facility accepts.
After passing the gate inspection, the truck followed a gravel road back
to the disposal cell where the truck 'was emptied. The truck driver helped the
operator empty the load. No safety equipment, such as a respirator1, was worn
by any FCL personnel. Some of the waste was observed to escape as fugitive
dust, with an estimated opacity ranging between 5 and 20 %. A small amount of
waste was also left on the edge of the pit after dumping but was not observed
to be carried out by the the transport truck. No decontamination of the truck
was performed. The waste was later covered with 6 to 8 inches of soil.
The WAP was reviewed and the following deficiencies were found:
- The plan is poorly organized. It does not contain a table of contents.
It is poorly formatted (e.g., it begins with Section II, there is no
Section I). Many sections are uncleanly written. It contains run-on
sentences with no meaning (see bottom of page 8 of the WAP).
- Sections exist in the plan, describing sampling and analyses for waste
in barrels. FCL stated it does not intend to accept barrels in the
future. These sections should be eliminated from the plan.
- The WAP unclearly describes a strategy for taking grab samples from
each load to produce a composite sample for fingerprinting purposes.
It states a minimum of nine (9) samples are to be taken horizontally and
vertically throughout loads that are 30 cubic yards or less in volume.
This was not done by the technician during the Task Force inspection,
and clarification of this procedure is required.
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- The plan identifies the tests to be conducted but does not describe
the equipment to be used or how the tests should be conducted.
- There is no protocol for the persons working with incoming waste,
such as those performing the waste analyses, or equipment operators.
- There is no safety protocol for the person sampling the waste, or personnel
working around the waste, such as truck drivers and equipment operators.
3. Old Waste Units
The site plan for Parcel A (Figure 4) shows where wastes have generally
been placed within this site since the facility's inception in August 1972.
Before 1978, the State of Indiana did not require waste to be separated as
nonhazardous or hazardous. Therefore, the area labeled General Refuse on the
site plan contains a mixture of general refuse, commercial, and industrial
waste. During 1974, Fulton County opened a landfill for general refuse, and
the volume of general household refuse the facility received was reduced. The
majority of waste received between 1974 and 1978 in the General Refuse Area is
thought to have been commercial and industrial in nature.
After 1978, the State of Indiana required disposal facilities to separate
general refuse from commercial and industrial wastes (i.e., "separate area
waste"). The approximate outline of the separate area waste is shown on the
general site plan (Figure 4). From 1978 to 1980, no record was kept of the
location of individual loads of separate area waste within the facility,
nor were such records required at that time.
On November 19, 1980, with the aid of a contract survey company, FCL began
recording placement of waste within the Waste Management Area (WMA). The
facility defines the WMA as approximately 23 acres located in Parcel A. This
excludes the general refuse area, which contains commercial and industrial
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wastes placed prior to RCRA. Within the WMA are many small waste management
units or cells which were often dug on a daily basis.
The approximate location of disposed waste was simply marked by the
contractor with a triangle on a site map. The dimensions of these units or
cells were not recorded. These units were dug and used daily, and were
abandoned in the spring of 1985 in favor of the "modified trench" method. In
addition to the triangles, a grid system consisting of 100-foot square blocks
with designated numbers was marked on the site map. The triangles were located
within a block to represent the location of the disposed waste within the grid
system and designated by distances from the edges of the block.
During 1985, and during the Task Force investigation, the facility had
placed waste in trenches assigned in the facility operation record log as Tl
through T8. In order to locate the waste disposed in the trenches, FCL alleged
that end points for the trenches were surveyed and staked in, and the developed
grid line was marked on the site map. The operator of the facility divided the
line into 15-foot sections to record waste placement within the trench. The
operator dug daily pits in a row along the "trench". The width of each
trench varies and is predominantly unknown. The depths of the trenches are
approximately 15 feet, the same as the pits.
On June 10, 1986, the Task Force noted that FCL was engaging in the lateral
expansion of the facility. The Task Force observed the excavation of a new
cell measuring 25 feet by 25 feet. According to FCL owner James Wilkins, advance
cell/trench construction one day earlier was normal FCL practice to prepare to
receive hazardous waste. On June 11, 1986, the Task Force observed the placement
of hazardous waste (D008) in this excavated landfill cell, which was not equipped
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with the double liner and leachate collection system required by RCRA. This
lateral expansion area of the existing landfill can be located on the site map
at FCL in Block 69 with XY coordinates of 3+00 E, 8+00 N.
Section 3004(0) of RCRA states the applicable performance standards for
owners and operators of hazardous waste treatment, storage, or disposal
facilities. For existing landfills engaged in a lateral expansion after May 8,
1985, Section 3004(0) of RCRA required the following standards be met:
(1) installation of two or more liners, and (2) a leachate collection system.
The direct disposal of hazardous waste into the ground without a double
liner is not only in direct contravention of the minimum technology standards
of Section 3004(0) of RCRA, but also greatly increases the probability of soil
and ground water contamination. The purpose of the double liner is to provide
additional protection from direct infiltration of contaminants into the soil
and ultimately into the ground water.
The two methods used to dispose waste reported above are referred to by FCL
as the "graveyard" and the "modified trench" methods. The graveyard method
is simply to dig a pit (unit) 20 feet X 20 feet X 15 feet (deep), place the
waste within the pit, and backfill over the waste with the excavated soil.
The modified trench method is similar to the graveyard method, but individual
pits are dug as necessary, in a line along what is called a "trench". The
waste in any unfilled pit is covered daily with soil. Therefore, with this
method of disposal only a small pit or waste management unit (RCRA landfill
cell), is being used at any one time.
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In some past reports (e.g., Reference 2), FCL divided the property in Parcel
A into sections in order to locate different areas (see Figure 2). Section 1
and 2 correspond to the General Refuse Area, Section 3 through 5 correspond to
the old hazardous waste areas, and Section 6 corresponds to where the new lined
cells (Units A & B) are located on Figure 4. These designations appear to have
been abandoned for the proposed unit layout, Figure 5.
4. Future Waste Management Units
FCL intends to build six new waste management units in Parcel A with flexible
membrane double-liner systems that include leachate collection and leak detec-
tion systems. These new units are designated as A through F (Figure 5).
Unit A was being constructed in the previously designated Section 6 of
Parcel A during the Task Force field inspection in June, 1986. The construc-
tion of the new unit was delayed at the time of the field inspection because of
ponded water within and under the unit. A FCL representative stated that the
water was a result of heavy spring rains. Construction has since been completed,
and FCL started placing waste in the new unit on August 18, 1986.
a. Design of New Haste Units
Unit A is approximately 250 X 500 feet (about 2-1/2 acres), and the
bottom is at approximately 760 feet above mean sea level or 30 to 35 feet below
ground level. This unit has a double-liner system composed of two 80-mil,
high-density polyethylene (HOPE) synthetic liners separated by a drainage mesh.
The drainage mesh (poly-drainage net Tensar ®OH-1) between liners is composed
of polyethylene plastic and allows for detection and collection of liquids
which would be an indicator of liner failure. Between the double liner and the
waste is a second drainage mesh, a permeable geotextile fabric, and 10 to 12
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inches of sand. The sand, geotextile fabric, and drainage mesh facilitate the
collection and removal of leachate. See Figure 6 for construction details.
The base of the unit is graded at a 2 percent slope toward collection
sumps on the central west edge of the unit. The facility intends to use above
ground tanks within a diked area to store leachate collected from the sumps.
Units B through F are to be constructed with a similar design as Unit A.
b. Operations with Regard to Future Units
Unit A was built in an area that was not previously used to landfill
hazardous waste. Unit B is to be constructed in a combination of virgin land
and existing landfill. Units C through F are to be located where waste has been
previously landfilled. The intent of FCL is to excavate all waste that has
been landfilled at the site since 1972, including the "nonhazardous" municipal
waste, and place it in the new double lined units or, if determined to be
nonhazardous, ship it to an off-site landfill.
FCL has stated the procedures to be used while developing the new units at
the site in the revised Part B application (December 31, 1985) as summarized
below:
- Select and store the cover soil and uncontaminated soil for future
final-cover material.
- Over a given unit area, excavate the previously landfilled hazardous
waste (about 15.0 feet thick) and place it into a newly constructed
double-lined unit.
- Install a double-flexible membrane liner system in the newly excavated
unit.
- Beginning from the outside, place hazardous waste to the design grades.
- When the outside slopes have been shaped to the design grades, the final-
closure grades are constructed using soil previously set aside. The
final three feet of closure soil will be compacted to density, shaped,
and seeded.
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The Part B application further indicates that leachate is to be pumped
into a holding basin (approximately 200,000 gallons capacity) or tanks.
At the time of this inspection, FCL was planning to use tanks for leachate
storage. FCL is to pump the leachate into trucks for off-site treatment and
disposal or, after development of a leachate treatment facility on Parcel B,
treat the leachate on site.
Although FCL intends to retrofit the site so that all waste would be
contained in double-lined units, the Task Force had some logistical and
technical concerns. The primary concerns are:
1) There is no indication in the Part B application of how FCL intends to
determine if cover soil or soil beneath the waste is contaminated.
- No analytical tests are proposed.
2) No health and safety considerations were given for the workers or
persons living on or around the site. FCL should perform a risk
assessment.
E. Hydrogeology
1. Geomorphology
The region consists of a hilly glacial terrain. The Four County Landfill
»
has a vertical surface relief of 50 to 70 feet which is typical of the region.
The original topography of the facility was dominated by a relatively narrow
ridge (Delong Lobe) that ran from the southeast to northwest corner of Parcel
A. This ridge has expanded to the southwest due to landfilling, so that only a
small portion of the southwest corner of the facility is topographically low.
The northeast portion of the site, not affected by landfilling, is also a
topographic low area.
Surface runoff presently drains from the ridge to the northeast and southwest
and is trapped in two drainage control basins at the corners of the facility.
The runoff collected in the southwest basin is pumped to the northeast basin.
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This basin drains into a lower, swampy area which eventually drains northward
through a culvert under county road 525N. Drainage then flows through
additional lowland areas and eventually to the Tippecanoe River, which is about
a mile north of the site.
Water runs onto the property from a low, swampy area along the south and
southwest edges of the facility. This water is trapped in a separate basin and
is diverted around the facility to the west where it eventually drains into
field tiles in an adjacent field.
2. Hydrogeologic Units
The stratigraphy and hydrogeologic characteristics were studied using logs
of borings and wells drilled on the facility, Fulton County water well logs,
geologic cross sections prepared by the Task Force, a geologic map of the area,
and reports written by consultants to the facility including ATEC and Associates,
Inc. (Reference 2) and Michigan Testing Engineers, Inc. (Reference 3). Borings
information is given in Table 3 and monitoring well information is given in
Table 4.
In general, three unconsolidated glacial units have been described in the
well and boring logs (see Cross Section, Figure 7). The location of the
contact between these glacial units is questionable based upon the logs and
therefore has not been drawn on the cross section. Figure 3 shows the
location of cross section A-A1. The depth to the top of bedrock has not been
determined by FCL, but is likely to be 150 to 250 feet, based on a regional geo-
logic map (Reference 9). Another regional geologic map (Reference 6) indicates
that the first bedrock unit present or encountered beneath the site is probably
the Traverse and Detroit River Formations, mostly limestone and dolomite.
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The lowest unit encountered in any of the wells or borings is a fine to
coarse sand with gravel that becomes finer in texture at shallower depths.
This unit is what the facility defines as the uppermost aquifer. The thickness
of this sand has not been determined because none of the on-site wells fully
penetrate it. In general, the top of this sand unit is encountered between 35
to 45 feet beneath the surface in the northeast portion of the site and is
reported as deep as 100 feet in the log of the southeast trailer well (un-
numbered).
Above this sand unit is a blue or gray clay till containing some sand and
gravel. Many of the logs describe the upper 10 feet of this clay unit as
"brown", which may be the result of weathering. In general, this unit is 30 to
40 feet thick. Sand seams 5 to 10 feet in thickness are reported to be within
this clay in borings B-9, B-12, and B-16 (see Figure 3). FCL has not established
that these seams are not hydraulically connected to the lower sands or continuous
across the site.
In the southwest portion of the site, a surficial sand unit mixed with
organic matter (described as peat) has been identified in borings B-9, B-10,
B-12, and B-15. This is confirmed by the surficial geologic map (Reference 6)
which describes this unit as dune sand or outwash gravel over till or lacustrine
clay. This unit and the underlying clay till appears to be saturated in some
borings based on water levels recorded just after the borings were drilled. The
B-series borings are no longer open so that the recorded static water levels
could not be verified.
Structural features, such as high or low areas on the top of the bedrock
that might affect the ground water flow, could not be evaluated due to the
absence of stratigraphic information at the depth of bedrock.
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The stratigraphic units that underlay FCL can be summarized as follows:
- Surficial Sand Unit - Thin (3 to 5 feet) sand and gravel deposit re-
presenting outwash or dune deposits in southwest portion of facility.
- Clay (Till) Unit - Blue-gray clay deposit, weathering to brown, usually
reported as 30 to 40 feet thick. Contains some minor sand and gravel and
some sand seams (5 to 10 feet thick).
- Sand and Gravel Unit - Brown sand and gravel generally fining upward to
silt. FCL has not estimated the thickness.
- Bedrock - Probably Devonian Age, Traverse and Detroit River Formation
Limestone Dolomites.
The Task Force concluded that the hydrogeology of the Four County Landfill
has been inadequately defined based on a review of the information cited above.
The primary inadequacies are described below.
- Fourteen (14) wells and twenty-one (21) test borings have been drilled
to varying depths, but none appear to fully penetrate the uppermost
aquifer. Therefore, the uppermost aquifer has not been defined.
- The locations of borings 17, 18, 19, 24, and 91 are not known.
- Descriptions of the stratigraphic intervals are incomplete. Shelby
tube or split spoon sampling was not continuous but rather every five
feet for wells and borings since 1978. Therefore, contacts between
units in the wells in which sampling was done are only considered
accurate to within +_ 5 feet.
- The well logs from 1978 and before (e.g., the trailer well logs) are less
accurate (using simpler water well methods and logging standards) and
should not be considered reliable.
- Geologic information is not available or is inadequate for most of the
site, especially the west and southwest portion.
3. Hydraulic Conductivity
The hydraulic conductivity of all the stratigraphic units was not determined
by FCL. Permeabilities at various intervals in some of the borings were cal-
culated from undisturbed Shelby tube samples, remolded Shelby tube samples, and
grain-size analyses. The results are shown in Table 5.
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The hydraulic conductivity estimates shown below are based upon tests per-
formed by Michigan Testing Engineers, Inc. (Reference 3). The results indicate
the vertical hydraulic conductivity of the clay unit is variable, but usually
1.2 X 10-7 cm/sec or less in these samples.
The Ground Water Sampling and Analyses Plan from FCL's Part B application
reports estimated hydraulic conductivities for the lower sand unit between
2 to 4 X 10-2 cm/sec or less, based on grain-size analyses. Also, based on
grain-size tests performed on the coarsest sand samples, an upper limit for the
seepage velocity was calculated by Hazen's formula. Assuming a typical sand
porosity of 30%, the seepage velocity in the uppermost portion of the sand is
calculated to be in the range of 13 feet per day; 4.7 X 10-3 cm/sec or less.
Pump tests are recommended by the Technical Enforcement Guidance Document
(TEGD; Reference 5) to determine the hydraulic conductivity.
More information is needed to adequately define the hydraulic conductivity
of the different units, especially the sand unit that is defined as the upper-
most aquifer. FCL currently is subject to the ground water quality assessment
program requirement, and it will not be possible to accurately determine the
rate and extent of contamination with the current information.
4. Ground Water Flow
FCL defines the uppermost aquifer as the sand and gravel unit beneath the
clay till. The top of the sand is 35 to 45 feet beneath ground surface in the
northeast portion of the property and continues to an undetermined depth. The
extent of this unit over the entire site is not known.
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FCL and its consultants state that the ground water flows to the north-
northeast (Figure 8). This conclusion is based upon the static water levels
within some of the wells on site. Well W-6, in the southwest portion of
the facility, historically (and when measured by the Task Force) showed higher
potentials (static water levels) than all other wells except well W-7,
located to the north of well W-6 (Figure 3). Static water levels measured at
well W-7 have consistently been the highest measured by FCL and the Task
Force. Well W-7 is not completed as deep as well W-6 or many of the other wells.
The Task Force concludes that more information is needed to explain this dis-
crepancy between static water levels and flow direction.
F. Ground Water Monitoring Under State Solid Waste Program
1. History
There are no records of ground water monitoring before March 5, 1979. The
State of Indiana required ground water monitoring under Solid Waste Regulations
approximately the same time (1978) that FCL was ordered to place hazardous
wastes in an area separate from nonhazardous wastes. The original monitoring
system consisted of wells W-l through W-8 (see Figure 9).
Ground water was sampled quarterly for the State solid waste management
program. Monitoring for this program was conducted from March 1979 until
December 1982 for all the wells, provided they were not dry. The following
indicator parameters were monitored during this period:
- Nickel - Copper
- Lead - Zinc
- Hexavalent Chromium - Cyanide
- Cadmium - Chemical Oxygen Demand
- Arsenic - TOC
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2. Previous Evaluation of the Ground Mater Monitoring System
a. RCRA Ground Water Monitoring
Originally, the RCRA monitoring system consisted of the same wells used for
the State solid waste program, wells 1 through 8. Well 6 was designated by
FCL as upgradient, and the other wells were all considered to be downgradient.
On December 29, 1982, the facility began background monitoring for the parameters
specified by 320 IAC 4.1-20-3 (40 CFR 265.92). These include indicators of
ground water contamination, indicators establishing ground water quality, and
the USEPA interim primary drinking water standards (see Table 6). A ground
water monitoring program was required to be implemented within a year after the
effective date of these regulations at hazardous waste landfills. The regula-
tions for interim status facilities were effective on November 19, 1980. Thus,
the ground water monitoring program was to have been implemented by November
19, 1981, under the provisions of RCRA. FCL did not meet this deadline.
In 1983, the facility installed three new wells, W-20, W-21, and W-22.
These wells replaced the existing downgradient wells. As the wells were com-
pleted they were tested for background values of the parameters listed in
Table 6.
IDEM performed a compliance monitoring inspection on June 10, 1985. During
this inspection, ground water monitoring violations were found. As a result, a
complaint (Cause Number V-209) was issued to the facility on October 11, 1985.
The ground water monitoring violations included in this complaint are summarized
below.
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FCL's monitoring system and program were found to be inadequate inasmuch as
the number, depth, and location of wells did not ensure a determination of the
impact on the ground water.
The number, depth, and location of the existing wells do not ensure that
they immediately detect any statistically significant amounts of hazardous
waste constituents that migrate from the waste management area to the uppermost
aquifer.
The existing documentation on the details of well completion do not identify
the development and seals used for well W-6, and the W-23 series wells.
b. Sampling & Analysis Plan
FCL failed to develop and follow a ground water sampling and analysis plan.
During the previously mentioned IDEM inspection on June 10, 1985, many problems
were noted with how the facility sampled the wells. Many of these problems
were deviations from what the written plan requires the sampler to do. For
example, purge volumes were not properly calculated and equipment was not
properly decontaminated. Also, proper laboratory procedures were not specified
by the Sampling and Analysis Plan.
c. Preparation, Evaluation, and Response
During a July and August 1984 record review, IDEM determined that there were
significant differences in pH, specific conductance, total organic carbon, and
total organic halogens in samples of the downgradient wells taken on May 5,
1984. On October 26, 1984, the IDEM issued a complaint (Cause Number N-128)
charging that the Respondents, Four County Landfill and Environmental
Waste Control, violated the Indiana Administrative Code. The findings listed,
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among other things, violations concerning the ground water monitoring.
Specifically, the ground water monitoring violations in the complaint were:
- Failure to immediately obtain additional ground water samples from
those downgradient wells where a significant difference was detected,
split the samples in two, and obtain analyses of all additional samples
to determine whether the significant difference was a result of
laboratory error, as required by 320 IAC 4.1-20-4(c)(2) (40 CFR 265.93
- Failure to develop and submit a ground water quality assessment program
as required by 320 IAC 4.1-20-4(d)(l) through (5) (40 CFR 265.93(d)(l)
through (5)).
- Failure to evaluate the data on ground water surface elevations obtained
under 320 IAC 4.1-20-3(e) (40 CFR 265.92(e))to determine whether the
requirements under 320 IAC 4.1-20-2 (265.91(aj) for locating the monitor-
ing wells continues to be satisfied as required by 320 IAC 4.1-20-4(f)
(40 CFR 265.93(f)).
- Failure to report the results of the evaluation of ground water surface
elevations under 320 IAC 4.1-20-4(f) (40 CFR 265.93(f)), and a description
of the response to that evaluation, where applicable, as required by
320 IAC 4.1-20-5(a)(2)(ii) (40 CFR 265.94(a)(2)(ii )).
FCL submitted notification to the Administrator on October 18, 1984, that
the facility may be affecting the ground water quality at the site. A ground
water quality assessment plan for the site was submitted to the IDEM on
November 1, 1984.
On April 23, 1985, the complaint (Cause Number N-128) was amended and
issued. The amended complaint included violations discovered during RCRA inspec-
tions conducted since the initial complaint was issued. The complaint was also
intended to resolve all hazardous waste violations detected up to that time.
No additional ground water monitoring violations were added to the complaint.
The complaint (Cause Number N-128) was resolved on July 19, 1985, through the
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adoption of a consent decree. With respect to ground water, the consent decree
ordered that FCL resubmit the ground water assessment plan within thirty days
of that date to embody each of the following aspects:
- Provide additional justification for well number, location, and depth
sufficient to identify the extent of the contaminant plume.
- Specifically identify all of the organics from Appendix VIII of 320
IAC 4.1-6-9 to be sampled and analyzed owing to TOC fluctuation. The
specific sampling and analytical protocol was also to be provided in the
plan.
- Identify the specific data evaluation procedures to be used after
sampling and analysis was completed. The rationale for the use
of that procedure was to be provided in the plan.
- Include a schedule of implementation of the assessment plan.
- Identify the specific methods, with rationale, to identify rate, extent of
migration, and concentration of contaminants.
- Within fifteen (15) days of receipt of notification of approval of the
assessment plan, conduct the first determination of rate, extent of migra-
tion, and concentration of hazardous waste and/or hazardous waste consti-
tuents.
- Install additional wells to address ground water fluctuations, contaminant
movement, and concentration. Drilling, well installation, and development
specifications were to be submitted and approved, prior to well placement.
Compliance was to be achieved in phases. Phase 1 was to consist of
further sampling and analyses for TOC in association with running an
organic scan. Phase 2 was to consist of installation of a three-well
nest at existing monitoring site No. 20. Phase 3 was to encompass in-
stallation of additional wells based on results of sampling and analysis
in Phase 1 and 2. Quality assurance/quality control information, the
adequacy of which was to be determined by the Chemical Evaluation Section,
Division of Land Pollution Control, was to be submitted in conjunction
with all analytical data.
- Comply with all recordkeeping and reporting requirements specified in
320 IAC 4.1-15 through 32 (40 CFR 265, Subpart F).
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In a letter to the IDEM dated August 29, 1985, FCL submitted a Revised
Ground Water Quality Assessment Plan in accordance with the consent decree. In
the revised submittal, FCL addressed the points in the consent decree regarding
ground water monitoring.
IDEM has completed the review of the response by FCL to the Consent Decree
on Cause Number N-128. FCL was informed of the IDEM findings in a letter dated
November 7, 1986. IDEM's concerns about FCL's response to the consent decree
are summarized below.
In the Revised Ground Water Quality Assessment Plan, FCL stated that TOC
variations were due to inadequate filtering. IDEM does not agree with this
statement. There is no EPA guidance or method which recommends or allows
filtering of the TOC portion of the sample. Further, FCL's claim that the
variations of ground water quality parameters were due to sampling and
testing variables, not leachate migration, had not been proven.
IDEM also stated that the presence of qualifiable and quantifiable amounts
of organics in samples was disturbing. Well W-20 had measured amounts of
p-chloro-m-cresol and 2,4,6-trichlorophenol, and well W-23m contained naph-
thalene. The amounts detected were very small (15.9 ppb and 13.6 ppb,
respectively). However, it must be kept in mind that only a small portion of
the aquifer was being monitored and the wells are somewhat removed from the
current areas of operation. These results may have been biased negatively by
the effects of diffusion; therefore, it is possible that only the fringes of
a plume were being detected and/or monitored.
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IDEM determined that the assessment plan was not adequate and the facility
had not properly:
(a) Provided additional justification for well number, location, and depth
that is sufficient to identify the extent of the contaminant
plume as requi red.
(b) Identified the rate and extent of migration and concentration of
the contaminants.
IDEM pointed out that compliance with Subpart F requirements may be achieved
in phases. Phase 1 and 2 have shown hazardous waste constituents in the
ground water. Therefore, the IDEM indicated Phase 3 should be initiated, to
include the installation of additional wells.
d. Potential Compliance with 320 IAC 4.1 (40 CFR 264 and 270)
FCL submitted a timely' notification of hazardous waste activity on August
18, 1980, and Part A of the permit application on November 19, 1980. Therefore,
FCL had obtained interim status as described in Section 3005(e) of RCRA.
On August 3, 1983, the USEPA formally requested that FCL submit Part B of
the RCRA permit application by January 31, 1984. The application was submitted
on January 27, 1984. A Notice of Deficiency (NOD) with respect to the complete-
ness of Part B permit application was sent to FCL on March 20, 1984. Specific
deficiencies in the Part B application with respect to ground water monitoring,
as described in the NOD, were:
(1) The applicant failed to provide a summary of the ground water monitoring
data obtained during the interim status period as required by 320 IAC
4.1-34-5(c)(2) (40 CFR 270.14(c)(2)).
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(2) The applicant failed to identify the aquifer underlying the uppermost
aquifer at the facility and document the presence or absence of any
hydraulic connection between the two aquifers as required by 320 IAC
4.1-34-5(c)(2) (40 CFR 270.14(c)(2)). Specifically, the application
should provide a geologic cross section of the regulated units showing
continuity or discontinuity of the sand layer below 40 feet, the relation-
ship of the sand layer to adjacent and lower stratigraphic units, the
location of monitoring wells and position of screens, and relationships
of waste to natural stratigraphy underlying the facility. Also, the
application must describe the hydrogeologic properties of underlying
units (e.g., hydraulic gradient, ground water flow, rates, and direction)
and provide the supporting data used to identify this information. A
comprehensive hydrogeologic assessment of the facility and surrounding
areas was required to be completed and submitted as supporting documen-
tation to the application.
(3) The applicant failed to supply a list of indicator parameters, waste
constituents, or reaction products that can provide a reliable indication
of the presence of hazardous constituents in the ground water as required
by 320 IAC 4.1-34-5(c)(6)(i) (40 CFR 270.14(c)(6)(i)). In addition, the
applicant failed to submit: (a) the type, quantity, and concentrations
of constituents in waste managed at the facility; (b) a description of
the mobility, stability, and persistence of waste constituents or their
reaction products in the unsaturated zone beneath the waste management
area; and, (c) a description of the detectability of indicator para-
meters, waste constituents, and reaction products in ground water.
(4) The applicant failed to submit a description of the facility, including
the ground water monitoring system of post-closure maintenance and
monitoring as described in 320 IAC 4.1-53-6 (40 CFR 264.310(b)) and as
required by 320 IAC 4.1-34-12(e) (40 CFR 270.21(e)).
(5) The applicant failed to adjust the post-closure cost estimate for
replicate sample analyses needed to comply with the requirement of
320 IAC 4.1-45-8(n)(l)(i) (40 CFR 264.97(h)(l)(i)).
The NOD established May 31, 1984, as a due date for FCL to respond. FCL
requested and was granted a 30-day extension to June 30, 1984. The revised
application was received on July 3, 1984.
A second NOD was sent to FCL on July 31, 1984. With respect to ground water,
the NOD indicated that FCL did not adequately respond to the first NOD, speci-
fically items (1), (2), and (3) as described above.
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The second NOD contained a due date of August 31, 1984. FCL requested a 30-
day extension and submitted revisions on October 1, 1984.
On September 26, 1985, a meeting was held between the USEPA and FCL. Part B
of the RCRA permit application was returned to the applicant for major revisions.
These revisions were due December 31, 1985, but were received by the USEPA on
January 21, 1986. On January 31, 1986, the State of Indiana was granted final
authorization to administer a hazardous waste program in lieu of the federal
program. At this time, Indiana assumed the lead role in a final determination
of FCL's permit application.
The most recent submittal of the Part B permit application containing ground
water monitoring information is dated October 1, 1984. The Task Force evaluated
the Part B proposal and Agency contractor review of the Part B submittal.
This is discussed in Section G of this report.
3. Other Monitoring
Sampling has been performed in wells on neighboring farms and in the
Tippecanoe River to the north by the Fulton County Health Department and IDEM.
The Health Department found an elevated level of lead in a single grab sample
from the Tippecanoe River near the effluent of the ditch that drains the
surface runoff from FCL. This single high lead concentration was not found in
subsequent sampling and the health department felt the origin was indeterminate.
An elevated concentration of lead was found in a well on the Widman farm
(June 11, 1981). Mr. Widman has complained to the Health Department and IDEM
that FCL was contaminating his water supply and that these contaminants (uniden-
tified) had poisoned a number of livestock. The initial sampling results
showing the elevated lead concentration has not been duplicated since. Due to
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the type of contaminant found and the distance between the farm and the FCL,
the State could not establish that the lead contamination was from the facility.
No proof to sustain Mr. Widman's allegations has been provided. An autopsy
performed by Purdue University on one of the cattle indicated that ground water
contamination was not the cause of the death, rather it was due to parasites in
the cow's intestines (Reference 8).
G. Task Force Evaluation for Compliance with RCRA
1. Evaluation of Ground Water Monitoring System 320 IAC 4.1-20-2
(40 CFR 265T9IT
The Task Force studied the location, depth, and construction of the wells
in the ground water monitoring system. The current RCRA ground water monitoring
system at FCL consists of wells W-6, W-20, W-21, W-22, W-23s, W-23m, and W-23d.
Prior to installation of wells W-20 through W-23d, seven wells (1 through 7)
were installed in 1978 for the purpose of monitoring the solid waste disposed
prior to the RCRA ground water monitoring regulation requirements that became
effective on November 19, 1980. Well W-6 has been designated by FCL as the
upgradient well for RCRA.
Figure 4 shows the location of the wells in the current RCRA ground water
monitoring system in relation to the Waste Management Area (WMA). The up-
gradient well (W-6) is extremely close to the trenches in which hazardous
wastes have been placed. Ground water samples from this well indicated con-
tamination of several waste types (see Ground Water Quality Data Interpretation).
Clearly, ground water from well W-6 is being affected by the facility. The
downgradient wells are W-20, W-21, W-22, and W-23 series, and are required to
be placed at the limit of the WMA so that they immediately detect any statisti-
cally significant amounts of hazardous waste or hazardous waste constituents
38
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that migrate from the WMA to the uppermost aquifer. Wells W-20, W-21, and W-22
are located between 100 to 400 feet beyond the limit of the WMA. (Unit A was
not active at the time of the Task Force field investigation). The number and
location of the existing wells in relation to the Waste Management Area (WMA)
does not comply with 320 IAC 4.1-20-2 (40 CFR 265.91).
To date, FCL has failed to adequately define the uppermost aquifer beneath
the facility. Total thickness of the uppermost aquifer is not known. Further-
more, questions exist regarding the true flow direction (see Section E.4 of
this report). The number and depth of downgradient and upgradient wells cannot
be accurately assessed until more is known about the site hydrogeology and flow
direction.
The construction of the older wells (W-l through W-8) is not adequate to meet
the requirements of 320 IAC 4.1-20-2(c) (40 CFR 265.91(c)).
Wells W-l through W-7 were installed in 1978. These are constructed from 4
inch PVC pipe. Available well records give little information about the
stratigraphy or how these wells were constructed. The records show that the
wells have 2-foot screens with a "25 slot" (assumed to mean 0.025 inch slot).
The screens are also assumed to be at the very bottom of the hole. Mr. Steven
Shaumbaugh, president of Environmental Waste Control, Inc. and operator of the
facility, stated that the joints of pipe were glued together (based on technology
and procedures used at that time).
Well W-8, the farm house well, is a domestic well constructed before the FCL
began operations. It is still used as a domestic well for drinking water. No
log or construction details are available for this well.
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Recent sampling results indicate that older wells (W-l through W-8) with poor
construction methods and materials may be influencing the quality of ground
water samples retrieved from them. The Indiana Department of Environmental
Management had previously identified these deficiencies and issued enforcement
actions, Cause Nos. N-128 and V-209.
In 1983, the facility installed three wells, W-20, W-21, and W-22. These
wells replaced the existing downgradient wells. As the wells were completed,
they were tested for background values of the parameters listed in Table 5.
FCL was able to produce construction records for wells W-20, W-21, and W-22.
These wells have 4 inch PVC casing and are screened for 15 feet with sand packs
extending approximately 5 feet above the screen where a 2-foot bentonite seal
is placed. The remainder of the annulus is filled with the leftover boring
material and grout. The top of these wells have a grout seal and a exterior
steel protective casing which can be opened with a special key. The screened
interval is approximately the same in all three wells, ranging from 713 to 732
feet above mean sea level (see Table 7).
Well construction records of the W-23 series wells (W-23s, W-23m, and W-23d)
indicate these wells are constructed of 2-inch threaded PVC casing with 2-inch
threaded PVC screening (0.010 inch slot). The screens are 20 to 30 feet long and
the sand packs are 70 to 90 feet long. W-23s does not appear to have a bentonite
seal above the sand pack. Well W-23m and W-23d have a one foot bentonite seal.
The remainder of the annulus is filled with "E.Z. Mud". The top of well W-23s
has a 4-foot grout seal , and the top of W-23m and W-23d have a 2-foot grout
seal. All three wells have protective covers.
The W-23 series wells have screens and sand packs that are too long. Long
screens and sand packs can dilute the ground water sample.
40
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The inadequate hydrogeological site characterization, well placement, and
well construction renders inadequate any assessment monitoring that FCL may
presently be performing using the existing ground water monitoring system.
In essence, the Task Force concludes that the preliminary information needed
to satisfy 320 IAC 4.1-20-3 and 20-4 (40 CFR 265.91 and 265.93) and to operate
a ground water monitoring program at the disposal facility is lacking.
2. Evaluation of the Sampling and Analysis Plan 320 IAC 4.1-20-3
(40 CFR 265T92T
FCL developed a Sampling and Analyses Plan (SAP) and keeps the SAP on site
in the office at the gate. The plan was developed in 1983 for wells W-l through
W-8 and W-20 and W-21. The SAP was revised in October 1985 to reflect the
addition of wells W-23s, W-23m, and W-23d. In addition, recent permeability
data were included in the revised plan.
The SAP generally addresses procedures and techniques for sample collec-
tion; sample preservation and shipment; analytical procedures; and chain of
custody, as required by 320 IAC 4.1-20-3 (40 CFR 265.92). However, the plan
lacks specific details which would allow any sampler to follow the identical
procedure from one sampling event to the next, thus minimizing variability in
sampling. After the site reconnaissance of FCL and prior to the Task Force
sampling, FCL's sampling procedures were observed by the Task Force and several
deficiencies and departures from the SAP were observed. These deficiencies are
similar to those cited by IDEM in Cause No. V-209.
The deficiencies were:
- Wells were purged only one annular volume (as specified in the SAP). It
is recommended (TEGD) that wells being sampled be purged three annular
volumes, or until the well has stabilized (determined by measuring pH or
specific conductance).
- The total depth of the wells was not measured at the time the samples
were taken. This is to determine if sediments are filling the well.
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- No gloves were worn by the sampler, potentially introducing contaminants
to the samples.
- The bailer rope was old and frayed and pieces were observed falling
into the well. Furthermore, the rope was not decontaminated between
wells as specified in the SAP. This could introduce contaminants or
cause cross contamination.
- Bottles were not filled in any particular order.
- Bottle labels lacked information concerning preservatives added.
It is recommended that FCL should develop a sampling and analysis plan
capable of yielding representative samples for a comparison of upgradient and
downgradient wells. The plan should be specific and include the following
elements:
- Well evacuation procedures, including volume to be evacuated prior to
sampling and handling procedures for purged well water.
- Sample withdrawal techniques. Sampling equipment and materials (tubing,
rope, pumps, etc.) shall be selected to yield representative samples in
light of parameters to be monitored. The sampling protocol is to include
field measurement of pH, conductivity, and temperature for each sample.
- Sample handling and preservative techniques, including provision for
field filtration of samples, as appropriate.
- Procedures for decontaminating sampling equipment between sample events.
- Procedures for measuring ground water elevations at each sampling event.
- Chain of custody procedures to be used for all phases of sample manage-
ment.
- Laboratory analytical techniques, including EPA-approved analytical
methods and quality assurance, detection levels, and quality control
procedures.
- Procedures for performing a comparison of upgradient and downgradient
ground water to determine whether contamination had occurred. The
procedures should include:
* A proposed method (statistical or otherwise) to compare upgradient
and downgradient well water that provides a reasonable balance between
the probability of falsely identifying and failing to identify contami-
nation.
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* An accelerated sampling schedule to establish data for the comparison.
* A proposed method for data organization and presentation.
3. Evaluation of Preparation, Evaluation and Response 320 IAC 4.1-20-4
(40 CFR 265.93)
The Task Force determined that FCL has not achieved the requirements of this
regulation. FCL failed to properly evaluate the ground water monitoring data and
subsequently failed to respond with a ground water quality assessment plan
describing a program capable of determining: (1) the rate and extent of migration
of hazardous waste or hazardous waste constituents in the ground water; and
(2) the concentrations of hazardous waste or hazardous waste constituents in
the ground water. Further, the Task Force determined it is not possible to
adequately perform an assessment of ground water contamination given the lack
of hydrogeologic information and the inadequate monitoring system.
These deficiencies are included in the State enforcement actions, Cause Nos.
N-128 and V-209.
4. Evaluation of RCRA Permit Application
The Task Force determined the Part B permit application to be deficient with
respect to the general requirements of 320 IAC 4.1-34-5(c) (40 CFR 270.14(c))
described below:
- FCL failed to provide a summary of the ground water monitoring data
obtained during the interim status period under 40 CFR 265.90 through
265.94. Specifically, FCL failed to submit the statistical analyses for
interim status data.
- FCL failed to adequately identify the uppermost aquifer and aquifers
hydraulically interconnected beneath the facility property, including
ground water flow direction and rate and the basis for such identification.
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- FCL failed to submit a topographic map as required by 40 CFR 270.14(b)
and 40 CFR 270.14(c). Specifically, FCL failed to submit a topographic
map at a scale no smaller than 1 to 200 which includes a delineation
of the waste management area, the property boundary, the proposed
"point of compliance" as defined under 40 CFR 265.95, the proposed location
of ground water monitoring wells as required under 40 CFR 265.97, and, to
the extent possible, the information in 40 CFR 270.14(c)(2).
- In order that FCL may meet the requirement of 40 CFR 270.14(c) (4), FCL
must provide a description of any plume of contamination that has
entered the ground water from a regulated unit. FCL has found a signifi-
cant increase in the parameters used as indicators of ground water con-
tamination, and is required to submit and implement a ground water quality
assessment plan after confirmatory analyses are run. FCL had failed to
submit and implement the specific plan which must, at a minimum, determine
the concentrations, rate, and extent of migration of the hazardous waste
or hazardous waste constituents in the ground water.
The Part B submittal for the ground water system does not meet 40 CFR
270.14(c)(5). This regulation requires the applicant to submit detailed
plans and an engineering report describing the proposed ground water
monitoring program to be implemented to meet the requirements of 40 (JFR
264.97. FCL's submittal is inadequate in that the proposal does not
describe a monitoring system which would meet 40 CFR 264.97. The ground
water monitoring system proposed to meet 40 CFR 264.97 is identical to
that used for 40 CFR 265 Subpart F. Deficiencies that apply to the
adequacy of the interim status ground water monitoring system, also apply
to the proposed monitoring system.
The Hazardous and Solid Waste Amendments of 1984 to RCRA established a
deadline of November 8, 1988, for the USEPA or authorized States (such as
Indiana) to make a final determination concerning RCRA permit applications for
landfills. With this deadline in mind and the numerous deficiencies in the
ground water monitoring system, the Task Force recommends that FCL immediately:
- Conduct a detailed assessment of the site's hydrogeology.
- Install a monitoring network to meet the objectives of 320 IAC 4.1 (40
CFR 264 and 270).
- Sample for all constituents required in 320 IAC 4.1-34-5(c).
- Establish background concentrations for 320 IAC 4.1-6-9 each Appendix
VIII constituent detected in the ground water, and submit data and plans
for compliance monitoring and corrective action as necessary per 320
IAC 4.1-34-5(c)(7) and (8) (40 CFR 270.14(c)(7) and (8)), respectively.
44
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The Task Force further recommends that FCL follow the guidance provided in
the September 1986 TEGD (Reference 5) in conducting the hydrogeologic study and
monitor well installation. The minimum information the Task Force seeks from
this study would include the following:
- The regional geologic and hydrogeologic characteristics in the vicinity,
including:
* regional stratigraphy: including strike and dip, identification of
stratigraphic contacts, petrographic analysis
* structural geology: local and regional structural features (e.g., fold-
ing, faulting, tilting, jointing, etc.)
* depositional history
* regional ground water flow patterns
* identification and characterization of areas of recharge and discharge
- An analysis of any topographic features that might influence the ground
water flow system. (Note that stereoscopic analysis of aerial photographs
could aid in this analysis).
- A classification and description of the hydrogeologic properties of all the
hydrogeologic units found at the site (i.e., the aquifers and intervening
saturated and unsaturated units), including:
* hydraulic conductivity, effective porosity
* lithology, grain size, sorting, degree of cementation
* an interpretation of hydraulic interconnections between saturated
zones
- A topographic map or aerial photograph at a scale of no smaller than
1" equals 200 feet as a base with maps of structural geology and at
least four hydrogeologic cross sections showing the extent (depth,
thickness, lateral extent) of all hydrogeologic units within the facility
property, identifying:
* sand and gravel deposits in unconsolidated deposits
* zones of fracturing or channeling in consolidated deposits
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* zones of higher permeability or lower permeability that might direct
or restrict the flow of contaminants
* perched aquifers
* the uppermost aquifer (includes all water-bearing zones above the first
confining layer that may serve as a pathway for contaminant migration
including perched zones of saturation
- A description of water level or fluid pressure monitoring including:
* water-level contour and/or potentiometric maps
* hydrologic cross sections showing vertical gradients
* an interpretation of the flow system, including the vertical and
horizontal components of flow
* an interpretation of any change in hydraulic gradients
- A description of man-made influences that may affect the hydrogeology of
the site, identifying:
* local water supply and production wells with an approximate schedule
of pumping
* man-made hydraulic structures (pipelines, french drains, ditches,
field tiles)
The Task Force recommends that FCL consider and address the following in
determining an expanded list of constituents:
- The types, quantities, and concentrations of constituents in wastes
managed at the facility
- The mobility, stability, and persistence of waste constituents or their
reaction products in the unsaturated zone beneath the waste management
area
- The detectability of the indicator parameters, waste constituents, or
reaction products in ground water
- The concentration or value and the natural variation (known or suspected)
of the proposed monitoring parameters in background ground water
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The list should also include the basis for selecting each proposed indicator
parameter, including any analyses or calculations performed. The basis for
selection must include chemical analysis of the facility's waste leachate.
The list should also include parameters to characterize the site-specific
chemistry of ground water at the site, including but not limited to the major
anions and cations that make up the bulk of dissolved solids in water (i.e.,
Cr, Fe, Mn, Na+, SO+24, Ca+, Mg+, K+, NO'3, P0"34).
5. Off-Site Laboratory Evaluations
EMS Laboratories, 7901 W. Morris Street, Indianapolis, Indiana, and OA
Laboratories, Inc., 1437 Sadlier Circle, West Drive, Indianapolis, Indiana,
were evaluated by the Task Force for general laboratory capability for analyzing
drinking water parameters, indicator parameters, and constituents listed in
Appendix VIII of 320 IAC 4.1-6-9. OA Laboratories was being used by FCL at the
time of the investigation, but the Task Force was informed by FCL that EMS
Laboratories would be their future analytical contractor.
OA Laboratories was evaluated for metals and indicator parameters. Compara-
tive results on performance evaluation samples were poor for most parameters.
The internal quality control program was incomplete. Data provided by this
laboratory for the specified parameters were termed questionable by the
evaluator.
Organic parameters were subcontracted by OA to Shrader Laboratories in
Detroit, Michigan. Shrader Laboratories was not evaluated as part ot this
project. A partial evaluation, based on data supplied to OA, was made. Holding
times for samples were exceeded and quality control deficiencies were noted.
Data from this laboratory should be considered qualitative.
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EMS Laboratories had participated in several EPA Performance Evaluation
Samples with inconsistent results. Internal quality assurance procedures were
determined to have a variety of deficiencies. The laboratory was well equipped
and adequately staffed, and these deficiencies may have been corrected since
this evaluation was completed.
6. Summary and Recommendations
The Task Force Technical Review Team has evaluated the available ground
water monitoring system and determined that FCL is not meeting the requirements
of 320 IAC 4.1-15 through 32 (40 CFR 265 Subpart F). The Task Force noted
numerous deficiencies in the ground water monitoring system which were
inadequate with respect to virtually every requirement of the regulations.
FCL has been informed of these deficiencies on numerous occasions by the State
of Indiana, including but not limited to complaints (Cause numbers N-128 and
V-209) and notices of deficiencies issued to FCL with respect to the Part B
application.
In order that FCL might achieve compliance with the requirements of 320 IAC
4.1-20-1 through 20-5 (40 CFR 265 Subpart F) and resolve some of the issues in
the State-issued complaints, the Task Force recommends that FCL immediately
begin a detailed hydrogeologic study. Based on this study and the TEGD
(Reference 5), FCL should install a monitoring well network capable of determ-
ing the facility's impact on the uppermost aquifer and capable of determining
the rate and extent of any hazardous waste or hazardous waste constituents
which have migrated to the uppermost aquifer. FCL should immediately begin an
accelerated sampling program of the monitoring system for an expanded list of
constituents.
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H. Ground Water Quality Data Interpretation
1. Task Force Analysis
Samples were analyzed by the EPA contractor laboratories for the parameter
groups shown in Appendix D, except for parameters which were not obtainable from
poorly producing wells, as indicated in Appendix A. Laboratory analytical
results were obtained from two EPA contractor laboratories participating in the
Contract Laboratory Program (CLP). One laboratory, CompuChem of Research
Triangle Park, North Carolina, analyzed the samples for specified organic
compounds, while the other, Centec of Salem, Virginia, analyzed for metals and
indicator parameters. Standard quality control measures were observed
including:
- The analysis of field and laboratory blanks to allow distinction of
possible contamination due to sample handling.
- Analysis of laboratory spiked samples and performance evaluation samples.
- Analysis of laboratory and sample duplicates to estimate precision.
- The review and interpretation of the results of these control measures.
These procedures can be found in the Quality Assurance Project Plan (QAPP) for
this site dated June 1986.
The Quality Assurance/Quality Control summary can be found in Appendix B.
Table 8 provides a summary, by parameter, of the analytical techniques used and
the reference methods for the sample analyses. Appendix C is a table of the
analytical results for all constituents found above detection limits.
2. Interpretation of Monitoring Well Data
Information supplied by FCL tends to indicate that wells 1, 4, 5, and 7 are
all screened in clay and that the remaining wells on site are screened in sand
and gravel. Well 1 has always been found to be dry, and well 5 is usually dry
(the Task Force did obtain a partial sample).
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The information which follows outlines the water quality determinations made
at FCL on a well-by-well basis.
WELL #2
Depth: 20 feet First sampled by FCL: June 1981
Drilled: December 1978 Sampled from 1981 through 1984
Screened in: gravel Sampled eight times by FCL
Range of Parameters that Indicate Contamination
from Facility Self-Monitoring Data
COD 36.0 - 4.9 ppm
TOC 82.0 - 2.0 ppm
Methoxychlor 1 ppb
*Total coliform bacteria 350 - 300 MPN
*Cadmium 50 - <2 ppb
*Lead 100 - <1 ppb
*Mercury 8 - <1 ppb
* Exceeds drinking water standards.
Task Force Sampling Results that Indicate Contamination
1,1-Dichloroethane 7.1 ppb
Note: 1) Well was found to be dry by FCL between 1978 and 1981.
WELL #4
Depth: 19 feet First sampled by FCL: March 1979
Drilled: February 1979 Sampled from 1979 through 1984
Screened in: Unknown Sampled 21 times by FCL
Range of Parameters that Indicate Contamination
from Facility Self-Monitoring Data
COD 1200 - 4.0 ppm
TOC 520 - 1.25 ppm
Total Phenol 5 -<5 ppb
*Total coliform bacteria 200,000 - 112 MPN
*Cadmium 50 -<1 ppb
*Lead 50 -<1 ppb
*Mercury 5 -<1 ppb
*Selenium 60 -<5 ppb
* Exceeds drinking water standards.
Task Force sampling results that indicate contamination: None.
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WELL #5
Depth: 35 feet Sampled once by FCL: March 1979
Drilled: February 1979
Screened in: clay
Results that Indicate Contamination
~from Facility Self-Monitor ing DaTa~
COD 1300 ppm
TOC 300 ppm
Note: 1) Lead found to be <200 ppb (detection level), but drinking water
standard i s 50 ppb.
2) FCL has found well to be dry since 1979 sampling.
Task Force Sampling Results that Indicate Contamination
Chloroform 2.8 ppb
Carbon tetrachloride 3.2 ppb
Note: 1) Well did not produce enough water for a complete Task Force sample;
thus, semivolatile organics, pesticide/PCB, TOX, total phenol, and
cyanide were not analyzed.
UELL #6 (upgradient well)
Depth: 51 feet First sampled by FCL: March 1974
Drilled: January 1979 Sampled from 1979 through present
Screened In: sand Sampled 31 times by FCL
Range of Parameters that Indicate Contamination
from Facility Self-Monitoring Data
COD 330 - <1.0 ppm
TOC 190 - 1.0 ppm
*Total col i form bacteria 50,000 - 190 MPN
TOX 66-9 ppb
Phenol 5 - <5 ppb
Cresol 12.3 ppb
*Cadmium 40 - <0.5 ppb
*Mercury 2 - <0.5 ppb
*Selenium 10 - <1 ppb
* Exceeds drinking water standards.
Task Force sampling results that indicate contamination: None.
51
-------
WELL #7
Depth: 36 feet First sampled by FCL: March 1979
Drilled: December 1978 Sampled from 1979 through 1984
Screened In: clay Sampled 24 times by FCL
Range of Parameters that Indicate Contamination
from Facility Self-Monitoring DaTaT
COD
TOC
TOX
Total phenol
*Total coli form bacteria
*Cadmium
Lead
*Mercury
*Selenium
150
160
61
5
22,500
30
43
2
10
- 0.8 ppm
- 1.0 ppm
- 10 ppb
- <5 ppb
- 20 MPN
- <1 ppb
-<10 ppb
- <0.5 ppb
- <5 ppb
* Exceeds drinking water standards.
Task Force Sampling Results that Indicate Contamination
Acetone
Phenol
Benzoic acid
dihydro-5,5-dimethyl 2 (3H) furanone
2-ethyl-hexanoic acid
1H, 3H naphtho (1,8-cd) pyran-l,3-dione
TOX
Total phenol
76
13
9.8
18
43
24
200
81
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
Note: 1) The Task Force bailer blank contained 12 ppb of TOX and 20 ppb of
total phenol .
WELL #3
Depth: Unknown First sampled by FCL: March 1979
Drilled: Unknown Sampled from 1979 through 1984
Screened In: Unknown Sampled 23 times by FCL
Range of Parameters that Indicate Contamination
from Facility Self -Monitoring DaTa"
COD 37 - 1.1 ppm
TOC 88 - 1.5 ppm
2,4-D 2 ppb
*Total coli form bacteria 25,000 - 200 MPN
Total phenol 5 - <5 ppb
*Cadmium 10 - <1 ppb
*Lead 80 - <1 ppb
Selenium 7 - <5 ppb
* Exceeds drinking water standards.
Task Force sampling results that indicate contamination: None.
-------
WELL #20
Depth: 46.5 feet First sampled by FCL: Sept. 1983
Drilled: May 1983 Sampled from 1983 through present
Screened In: sand Sampled 16 times by FCL
Range of Parameters that Indicate Contamination
*Total
2,4
from Facil
COD
pH
TOC
TOX
Total phenol
col i form bacteria
Toluene
p-chloro-m-cresol
,6-trichlorophenol
trichloroethylene
*Barium
*Cadmium
*Lead
*Selenium
*Gross alpha
*Gross beta
ity Self-Monitoring Data
12.2
58
227
4250
19,000
2,500
30
60
10
26
200
36
- 6.98
- 3
- <10
- <5
- <2
5.5
15.9
13.6
4.9
- <20
- <1
- <10
- <5
- <3
- 18.7
ppm
ppm
ppb
PPb
MPN
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
P Ci/1
P Ci/1
* Exceeds drinking water standards.
Note: 1) Sample with toluene result also had 2.1 ppb in the laboratory blank.
Task Force sampling results that indicate contamination: None.
WELL #21
Depth: 60 feet First sampled by FCL: Sept. 1983
Drilled: May 1983 Sampled from 1983 through present
Screened In: sand Sampled 16 times by FCL
Range of Parameters that Indicate Contamination
from Facility Self-Monitoring Da"ta"
COD 29 ppm
TOC 117 - 2 ppm
Total phenol 10 - <5 ppb
Trichloroethylene 4.1 ppb
*Total coliform bacteria 30,500 - 500 MPN
*Selenium 10 - <5 ppb
* Exceeds drinking water standards.
Task Force Sampling Results that Indicate Contamination
Total phenol 32 ppb
Note: 1) The Task Force bailer blank showed 20 ppb of phenol.
53
-------
WELL #22
Depth: 38 feet
Drilled: June 1983
Screened In: sand
First sampled by FCL: Sept. 1983
Sampled from 1983 through present
Sampled 16 times by FCL
Range of Parmameters that Indicate Contamination
from Facility Self-Monitoring Data
pH 8.9
TOC 159
TOX 72
Total phenol 40
*Total coliform bacteria 116,600
6.66
- <5
- 4240
ppb
ppb
ppb
MPN
* Exceeds drinking water standards.
Task Force sampling results that indicate contamination: None.
WELL 123s
Depth: 48 feet
Drilled: April 1985
Screened In: sand
First samples by FCL: April 1985
Sampled from 1985 through present
Sampled 6 times by FCL
Range of Parameters that Indicate Contamination
from Facility Self-Monitoring DaTeT
Total phenol
TOX
TOC
Napthalene
10 - <10 ppb
65.3 - <10 ppb
76-4 ppb
<4.9
Task Force Sampling Results that Indicate Contamination
Lindane 0.22 ppb
Unknown organic 17 ppb
WELL 123m
Depth: 85 feet
Drilled: April 1985
Screened In: sand
First Sampled by FCL: April 1985
Sampled from 1985 through present
Sampled 6 times by FCL
Range of Parameters that Indicate Contamination
from Facility Self-Monitoring Data
Pyridine
Naphthalene
TOC
*Cadmium
78
10 -
<4.1 ppb
16.3 ppb
<10 ppm
<10 ppb
* Exceeds drinking water standards.
Task Force sampling results that indicate contamination: None.
54
-------
WELL #23d
Depth: 118 feet First sampled by FCL: April 1985
Drilled: April 1985 Sampled from 1985 through present
Screened In: sand Sampled 6 times by FCL
Range of Parameters that Indicate Contamination
from Facility Self-Monitoring Data'
TOC 79 - 3.38 ppm
*Cadmium 10 - <10 ppb
* Exceeds drinking water standards.
Task Force sampling results that indicate contamination: None.
It should be noted that some of FCL's pesticide data had detection levels
that were above the drinking water standards for those compounds and that many
of the other drinking water parameters had detection levels that were identical
to the standard. Also, some of the drinking water parameters are no longer
being analyzed by laboratories currently employed by FCL. As previously men-
tioned, some of these parameters, such as gross beta, total coliform bacteria,
and gross alpha exceeded the drinking water standards in several samples
referenced above.
The Task Force sampling results indicated that some well contents included
some total metals at concentrations that were greater than or near drinking
water standard levels. In all cases, the corresponding dissolved metals results
did not indicate the presence of these metals. Thus, the Task Force assumes
that the results could be indicative of soil composition rather than landfill
leakage. Also, there is a question as to the type of metals analysis, total or
dissolved, that has been done for FCL in the past. Samples analyzed between
1979 and 1982 by Pollution Control Systems, Inc. (PCSI) were noted to have been
filtered. Thus, the reported results were for dissolved metals. It should
also be noted that EMS filtered TOC samples collected and analyzed for FCL
between September 1984 through April 1985.
55
-------
Historically, all of the wells have had some noteworthy analytical results,
with well W-20 having the highest number of parameters exceeding levels of
possible contamination. All wells but W-23d have shown either the presence
of a hazardous constituent listed in 320 IAC 4.1-6-9 Appendix VIII (40 CFR
261 Appendix VIII), or at least one value for one or more of the following
parameters above the indicated concentrations (which, for purposes of this
report, are assumed to be levels of possible contamination):
COD 50 ppm
TOC 100 ppm
TOX 100 ppb
Total phenol 10 ppb
Total coliform bacteria 1 MPN
All wells but W-5, W-22, and W-23d were found to have exceeded the drinking
water standards for at least one heavy metal. Well W-20 also had gross alpha
and gross beta readings that exceeded drinking water standards.
The analysis of Task Force samples found a number of organic compounds in
wells W-2, W-5, W-7, and W-23S (see previously tabulated data). The Task Force
concludes that FCL and Task Force data indicate that contamination does exist
in the ground water at the site.
In its August 12, 1985, Revised Ground Water Quality Assessment Plan,
FCL explained that the high pH levels found in well 20 were due to construction
problems. The Task Force does not believe that this is the case, because if it
were, the pH of the well would be consistently high and not vary as it does
between 12.2 and 6.98. Also, FCL states that the fluctuation in TOC levels is
due to the time and place of filtering of the samples before analysis. The Task
Force agrees that the fluctuation in TOC values may be due to filtering protocol,
56
-------
but the fact is that TOC samples (or any other organic sample) should not be
filtered at all before analysis. Thus, all TOC values reported by FCL are
probably biased low.
It should also be noted that some parameters that have shown levels of
concern in the past (COD, gross alpha, gross beta, pesticide, and total coliform
bacteria) have been dropped from FCL's analytical scheme for no apparent
reason. Also, the detection levels for most of the parameters with drinking
water standards have been raised to the value of the standard. These detection
levels should be no more than half of the corresponding standard.
3. Interpretation of Surface Water Data
During the Task Force investigation, four surface water .samples were
collected at FCL. Precipitation that falls on the closed areas of the landfill
will run off the site in either a northeasterly or southwesterly direction with
the approximate divide being the road that traverses the site. In the northeast
portion of the site, there is a drainage control basin (see Figure 3) which
collects the runoff that flows to the northeast. This basin discharges to a
swampy area that eventually discharges to the north through a culvert under
County Road 525. Drainage from the southwest portion of the site flows to a
southwest drainage control basin. Drainage from this basin was to be pumped to
the northeast basin and then discharged. The southwest basin was being dredged
and enlarged during our sampling. There is also a drainage ditch that skirts
the southwest corner of the site which is not supposed to receive any runoff
from the site. FCL has applied for a NPDES permit for the discharge from the
northeast basin. Samples were collected at the culvert that flows under County
57
-------
Road 525 (sample No. 516), the southwest basin (sample #513), and the runon
(sample No. 774) and runoff (sample No. 773) of the southwest ditch. The
analytical results can be found in Appendix C. Most parameters found (except
for TOC and TOX) increased from the runon to the runoff samples of the southwest
ditch. The most notable of these are total lead and mercury and dissolved
mercury.
There were numerous organic compounds found in the southwest basin sample of
which toluene had the highest concentration of 430 ppb. Other compounds of
interest found were total chromium, lead and mercury, POX, TOC, TOX, total
phenol, and ammonia nitrogen. The sample of the swampy area to the northeast
had a high TOC, but since no specific waste constituents were found, this result
probably represents the natural organic content of swamp water.
The Task Force finds that the contaminants found in the southwest basin
could have one or both of the following causes:
- leachate from the landfill.
- excavation of the basin in an old landfill.
Further investigation is needed in this area.
-------
REFERENCES
1. U.S. Environmental Protection Agency, November 1987, Procedures for Planning
and Implementing Off-Site Response Actions, Federal Register, Vol. 50, No.
214, Page 45933.
2. ATEC Associates, Incorporated, June 1983, Ground Water Study and Monitoring
Well Installation (Report and Maps - Four County Landfill).
3. Michigan Testing Engineers, Incorporated, June 1978, Soil Borings (Results -
Four County Landfill).
4. Michigan Testing Engineers, Incorporated, U.S. Environmental Protection
Agency, September 1978, Report of Soil Permeability Rate (Results -
Four County Landfill).
5. U.S. Environmental Protection Agency, September 1986, RCRA Ground Water
Monitoring Technical Enforcement Guidance Document (TEGD), U.S. Environ-
mental Protection Agency, Office of Waste Programs Enforcement and Office
of Solid Waste and Emergency Response, pg.- 1-30 to 1-33. 6.
6. Gray, H.H., et al , 1970, Geologic Map of the 1° X 2° Chicago Quadrangle,
Indiana, Illinois, and Michigan, Showing Bedrock and Unconsolidated
Deposits, Indiana Geological Survey, Regional Geologic Map No. 4
(Chicago Sheet), Scale 1:250,000.
7. U.S. Environmental Protection Agency, Eastern District Office, June 1986,
Quality Assurance Project Plan, Ground Water Monitoring Evaluation, Four
County Landfill, Fulton County, Indiana
8. Hayworth, John, April 1987, Personal Communication, Indiana Department of
Environmental Management.
9. Schneider, Allen F., S.J. Keller, 1983, Map of Indiana Showing Thickness of
Unconsoli dated Deposits, Indiana Geologic Survey, Miscellaneous Map 38.
59
-------
TABLE 1
ORDER OF SAMPLE COLLECTION
BOTTLE TYPE AND PRESERVATIVE LIST
Parameter
Volatile Organic Analysis (VGA)
purge and trap
direct inject
Purgeable Organic Carbon (POC)
Purgeable Organic Halogens (POX)
Extractable Organics
Total Metals
Dissolved Metals
Total Organic Carbon (TOC)
Total Organic Halogens (TOX)
Phenols
Cyanide
Nitrate/ammonia
Sulfate/chloride
Bottle
4 - 60 mL VOA vials
Preservative
Cool 4°C
1 - 60 mL VOA vials
1 - 60 mL VOA vials
4 - 1 L. amber glass
1 L. plastic
1 L. plastic
1 - 50 mL glass
1 L. amber glass
1 L. amber glass
1 L. plastic
1 L. plastic
1 L. plastic
Cool 4°C
Cool 4°C
Cool 4°C
HN03-5 mL
HN03-5 mL
H?S04-5 mL
Cool 4°C
Cool 4°C
no headspace
H2S04-5 mL
NaOH-5 mL
Cool 4°C
H2S04-5 mL
Cool 4°C
Cool 4°C
-------
TABLE 2
Waste Accepted at Four County Landfill
•on 1980
Waste
Codes
F011
F010
F018
F008
F006
F017
F005
F013
through 1983, based
Approx.
Tons/Yrs.
300
500
8,000
1,000
4,000
5,000
2,000
500
upon Part A application)
Description
Spent cyanide solvent
from salt bath
Quenching residue from
oil bath
Wastewater treatment sludge
from industrial painting
Plating bath residue from
electroplating w/cyanide
process
Wastewater treatment sludge
from electroplating operation
Paint residue
Spent halogen solvents
Filtration tailings from
*
*
I \J A *J *S W
metal recycling
operations
K001 500 Bottom sediment sludge from
wood preserving process
(after 1983 based upon revised Part A application)
D006
D007
DO 08
F006
400
100
400
600
Cadmium
Chromium
Lead
Wastewati
from electroplating operation
K061 20,000 Emission control dust/sludge
from steel production
*Waste code does not currently exist. A waste meeting this description
is hazardous only if it meets one of the other definitions of hazardous
waste.
-------
TABLE 3
Information About Borings Drilled
Four County Landfi11
at
Borehole
Number
B-l
B-2
B-3
B-4
B-5
B-6
B-7
B-8
B-9
8-10
8-11
B-12
B-13
B-14
B-15
B-16
B-17
B-18
B-19
B-24
B- ?
Date
Installed
Unknown
Unknown
it
ii
it
"
5/6/78
5/31/78
5/31/78
5/30/78
5/22/78
6/1/78
6/2/78
5/25/78
6/5/78
5/25/78
3/14/82
8/13/82
8/11/82
9/10/84
9/21/84
9/21/84
Total
Depth
18'
26'
23'
21'
28'
28'
41'
41'
41'
40.5'
41'
41'
36'
40'
46'
41'
80.5'
78'
80'
65'
25'
4'
Lithologic
Log Data
Available
Yes
(hard to read)
H
ii
H
ii
H
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Surface
Elevation
774'
775'
755'
755'
770'
749'
771'
773'
781'
786'
783'
778'
774'
Unknown
753'
Unknown
759'
Unknown
Unknown
-------
TABLE 4
Well History and Description for
Monitoring Wells at Four County Landfill
Well
Number
1
2
3
4
5
6 *
7
8
20
21
22
23s
23m
23d
Date
Installed
12/26/78
12/26/78
12/27/78
2/20/79
2/20/79
1/3/79
12/29/78
Unknown
5/19/83
5/27/83
6/1/83
4/8/85
4/8/85
4/8/85
Historical
Use
M.W.
M.W.
M.W.
M.W.
M.W.
M.W.
M.W.
D.W.
M.W.
M.W.
M.W.
M.W.
M.W.
M.W.
Elevation at
Unit Bottom of
Penetrated Screen or Hole
by Screen (ft MSL)
Clay
Gravel
Sand & Gravel
Unknown
Clay
Sand
Clay
Unknown
Sand
Sand
Sand
Sand
Sand
Sand
749'
750'
732'
Unknown
740'
724'
737'
Unknown
713'
715'
717'
717'
680'
647'
Total
Depth
on
Log
42'
20'
38'
19'
35'
51'
36'
Unknown
45'
60'
38'
48'
85'
118'
M.W. - Monitoring Well
D.W. - Domestic Well
-------
TABLE 5
Test No.
** 1
* 2
*** 3
* 4
* 5
* 6
***
8
* 9
no
**12
*13
***14
**15
**16
Hydraulic Conductivity Test Results (1/23/79)
Four County Landfill, Fulton County, Indiana
Boring No.
and Depth
B-7, 9.5 to 11.5 feet
B-7, 19.5 to 21.5 feet
B-8, 9.5 to 11.5 feet
B-8, 19.5 to 21.1 feet
B-9, 9.5 to 11.0 feet
B-9, 19.5 to 21.5 feet
BIO, 9.5 to 11.5 feet
BIO, 19.5 to 20.8 feet
B12, 9.5 to 11.5 feet
B12, 19.5 to 22.0 feet
B13, 14.5 to 17.0 feet
B13, 29.5 to 31.5 feet
B15, 9.5 to 11.5 feet
B15, 19.5 to 20.5 feet
B16, 9.5 to 11.5 feet
B16, 19.5 to 21.0 feet
Hydraulic Conductivity Rate
CM/SEC
1.2
1.6
5
2.5
8.7 x
6.2 x
6.2 x
5.2 x
1.5 x
5.8 x
3.5 x
1.9 x
8.1 x
1 x
9.5 x
4.8 x
10-7
ID'8
lO-8
10-7
10-7
ID"4
10-8
10-8
10-7
10-7
10-8
10-8
10-8
10-9
10-8
10-7
* Falling head hydraulic conductivity
** Hydraulic conductivity run remolded samples. Samples remolded to in-place
density value and run at 35 Ibs. pressure.
***
Estimated hydraulic conductivity based on grain-size analyses performed on
samples. Hydraulic conductivity tests performed on the tube samples indicate
water channeled at interface of tube and soil.
-------
TABLE 6
Four County Landfil 1
RCRA Interim Status Ground Water
Monitoring Parameters
Indicators of Ground Water Contamination
pH
Specific Conductance
Total Organic Carbon (TOC)
Total Organic Halide (TOX)
Ground Water Quality Standards
Chloride
Iron
Manganese
Phenols
Sodi urn
Sulfate
Arsenic
Barium
Cadmi urn
Chromium (Total)
Fluoride
Lead
Mercury
Nitrate (as N)
Selenium
Silver
Endrin
Lindane
Met ho xyc hi or
Toxaphene
2,4-D
2,4,5-TP Silver
Radium
G'ross Alpha
Gross Beta
Turbidity
Coli form Bacteria
EPA Interim Primary Drinking Water Standards
-------
TABLE 7
Well Construction Information for
Monitoring Wells at Four County Landfill
Well
Number
1
2
3
4
5
6
7
8
20
21
22
23s
23m
23d
Total
Depth
Tfeet)
42'
20'
38'
19'
35'
51'
36'
Unknown
45'
60'
38'
48'
85'
118'
Screen
Interval
(feet MSL)
749-751
750-52
732-34
7
740-42
724-26
737-39
Unknown
713-728
715-730
717-732
717-737
680-700
647-667
Sandpack
Interval
None *
»
»
"
'•
»
"
Unknown
713-731
715-735
717-731
717-741
680-750
635-733
Grout
Interval
Unknown
»
"
»
»
«
'•
Unknown
733-759
737-775
733-755
761-765
763-765
763-765
* Logs do not indicate whether grout was used.
-------
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-------
Figure 2
Past Designations of Waste
Management Areas
200
Feet
FOUR COUNTY LANDFILL
Fulton County, Indiana
Parcel A
-------
Figure 3
Boring and Monitoring Well
Location Plan
County Road 525N
NPDES Discharge
NE
Drainage
Control
Basin
SW Drainage
Control Basin
Trailer Office
Well
FOUR COUNTY LANDFILL
Fulton County, Indiana
Parcel A
Locations Approximate < O Monitoring Well
JS) Surface Water Sampling Locations
-------
Figure 4
General Site Plan
County Road 525 N
Feet
FOUR COUNTY LANDFILL
Fulton County, Indiana
Parcel A
RCRA Groundwater Monitoring System
Boundary of Waste Management Area (WMA)
(including preRCRA Separate Area Waste)
Before Aug. 18, 1986
-------
Figure 5
Approximate Proposed Unit Layout
County Road 525
200
Feet
FOUR COUNTY LANDFILL
Fulton County, Indiana
Parcel A
Location of Leachate
Collection
-------
TYPE 21 TREVIRA SPUNbOND GEOTEXTILI
POLY-DRAINAGE NET
80MIL HOPE LINER
8QMIL HOPE LINER
COMPACTED BACKFILL
10
SECTION A-A1
ANCHOR TRENCH DETAIL
(NOT TO SCALE)
LINER .SYSTEM
SECTION B-B1
TYPICAL BERN SECTION
(NOT TO SCALE)
SILTY CLAY
TYPE 21 TREVIRA SPUNBOND GEOTEXTILE
'POLY-DRAINAGE NET
80MIL HOPE LINER
'80MIL HOPE LINER
GEOMEMBRANE
20V
SILTY CLAY
TYPICAL SAND SEAM LINER SYSTEM
Four County Landfill
Fulton County, Indiana
FIGURE 6 -
Construction details of cell walls and liners as planned
for future installation. Taken from Revised Part B Application,
Sept. 1984, Part I, Appendix Cl.
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Figure 9
Sampling Location Plan
County Road 525N
.Culvert
NPDES Discharge
Owl
Ow-3
NE
Drainage
Control
Basin
Culvert.-*
SW Drainage
Control Basin
Trailer Office
Wei 1
Approximate Locations '
FOUR COUNTY LANDFILL
Fulton County, Indiana
Parcel A
O Monitoring Well
s) Surface Water Sampling Locations
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APPENDIX A
Sampling Information
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APPENDIX B
QA/QC Summary of Task Force Data
-------
MEMORANDUM
DATE: October 2, 1986
SUBJECT: Evaluation of Quality Control Attendant to the Analysis of Samples
from the Four County, Indiana Facility
FROM: Ken Partymiller, Chemist
PRC Environmental Management
THRU: Paul H. Friedman, Chemist*
Studies and Methods Branch (WH-562B)
TO: HWGWTF: Tony Montrone*
Gareth Pearson (EPA 8231)*
Richard Steimle*
Ed Berg (EPA 8214)*
Joe Fredle, Region V
James H. Adams, Jr., Region V
This memo summarizes the evaluation of the quality control data generated by
the Hazardous Waste Ground-Water Task Force (HWGWTF) contract analytical
laboratories (1). This evaluation and subsequent conclusions pertain to the data
from the Four County, Indiana sampling effort by the Hazardous Waste Ground-
Water Task Force.
The objective of this evaluation is to give users of the analytical data a more
precise understanding of the limitations of the data as well as their appropriate use.
A second objective is to identify weaknesses in the data generation process for
correction. This correction may act on future analyses at this or other sites.
The evaluation was carried out on information provided in the accompanying
quality control reports (2-3) which contain raw data, statistically transformed data,
and graphically transformed data.
The evaluation process consisted of three steps. Step one consisted of
generation of a package which presents the results of quality control procedures,
including the generation of data quality indicators, synopses of statistical indicators,
and the results of technical qualifier inspections. A report on the results of the
performance evaluation standards analyzed by the laboratory was also generated.
Step two was an independent examination of the quality control package and the
performance evaluation sample results by members of the Data Evaluation
Committee. This was followed by a meeting (teleconference) of the Data Evaluation
Committee to discuss the foregoing data and data presentations. These discussions
were to come to a consensus, if possible,
* HWGWTF Data Evaluation Committee Member
-------
concerning the appropriate use of the data within the context of the HWGWTF
objectives. The discussions were also to detect and discuss specific or general
inadequacies of the data and to determine if these are correctable or inherent in
the analytical process.
Preface
The data user should review the pertinent materials contained in the
accompanying reports (2-3). Questions generated in the interpretation of these data
relative to sampling and analysis should be referred to Rich Steimle of the
Hazardous Waste Ground-Water Task Force.
I. Site Overview
The Four County facility is located in Indiana in a rural location surrounded
by farm land. The facility presently accepts mainly inorganic waste, although, in
the past they accepted a wider variety of wastes. The facility uses a method
referred to as the "grave yard" method to bury the wastes. They dig a 15 by 15 by
15 foot hole in the ground, fill the unlined pit with waste, and then cover it. Then
they dig the next hole, adjacent to the previous hole and do the same. The facility
has 10 or 11 ground-water monitoring wells. Most of these are 20 to 50 feet deep
although there is one which is 85 feet deep and another which is 130 feet deep.
Most of the wells that were capable of supplying a sufficient volume of water for a
complete analysis of all analytes were monitored in this effort. Several surface
water samples were also collected. No leachate collection system is used at the
facility and thus, no leachate samples were collected. The top 30 feet of soil at
the facility is clay which is underlaid by sand of unknown depth.
Twenty-three field samples including one field blank (MQO/QO515), one trip
blank (MQO/QO276), two equipment blanks (MQO/QO712 and MQO/QO772), and two
pairs of duplicate samples (well 20, MQO/QO366 and MQO/QO367 and well 22,
MQO/QO512 and MQO/QO514) were collected at this facility. All samples were low
concentration ground water samples. Traffic reports indicated which samples were
blanks and duplicates.
II. Evaluation of Quality Control Data and Analytical Data
1.0 Metals
I.I Performance Evaluation Standards
Metal analyte performance evaluation standards were not evaluated in
conjunction with the samples collected from this facility.
1.2 Metals OC Evaluation
Total and dissolved metal spike recoveries were calculated for the twenty-
three total metals and seventeen dissolved metals spiked into three field samples
(MQO367, 399, and 773). Nineteen total metal and sixteen dissolved metal average
spike recoveries were within the data quality objectives (DQO) for this Program.
The total iron spike recovery was not required to be calculated because the
analytical results for iron in all three samples were greater than four times the
concentration of the spike added. The total aluminum and thallium and dissolved
silver average spike recoveries were below DQO with recoveries of 66, 74, and 63
percent, respectively. The total arsenic average spike recovery was above DQO
-------
with a recovery of 139 percent. Various individual total and dissolved metal spike
recoveries were also outside DQO.
These are listed in Table 3-2 of Reference 2 as well as in the following Sections.
All reported laboratory control sample (LCS) recoveries except arsenic and all
calibration verification standard (CVS) recoveries were within Program DQOs.
The average relative percent differences (RPDs) for all metallic analytes were
within the DQOs.
Required analyses were performed on all metals samples submitted to the
laboratory. The raw data for the dissolved metals were not found in the data
package submitted by the laboratory.
No contamination was reported in the laboratory blanks. Equipment and field
blanks show contamination involving aluminum at 278 ug/L (in sample MQO712, an
equipment blank) and chromium at 29 ug/L (in sample MQO515, the field blank).
1.3 Furnace Metals
The antimony, cadmium, and lead quality control was acceptable. All total and
dissolved antimony, cadmium, and lead results from this facility should be considered
quantitative.
One of two LCSs for arsenic, which were analyzed by the method of standard
addition (MSA), had correlation coefficients of less than 0.995 (0.972 and 0.983). .
This arsenic LCS result should not be used because of the poor correlation
coefficients. Based upon the dissolved arsenic result from sample MQO772, the
laboratory should have rerun the sample by MSA. The arsenic spike recoveries for
samples MQO339 and 773 were high (153 and 151 percent). High aluminum
concentrations in the field samples should not have effected the arsenic results
because the laboratory used Zeeman background correction. Overall, all total and
dissolved arsenic results should be considered to be biased high (approximately 50
percent) and semi-quantitative.
High iron concentrations in the field samples should not have effected the
selenium results because the laboratory equipment used Zeeman background .
correction. The dissolved selenium result for sample MQO775 does not meet
duplicate precision criteria. All total and dissolved selenium results should be
considered quantitative except for dissolved selenium from sample MQO775 which
should be considered to be unreliable.
Thallium spike recoveries for samples MQO339 and 367 were low (73 and 72
percent). All thallium results should all be considered to be biased low
(approximately 25 percent) and semi-quantitative.
1.4 ICP Metals
Individual spike recoveries were outside DQO for total aluminum in sample
MQO367 (66%), dissolved potassium in sample MQO773 (133%), total silver in sample
MQO376 (74%), and dissolved silver in samples MQO367 (64%), 399 (50%), and 773
(74%). All the low recoveries are expected to result in data that are biased low for
the appropriate total or dissolved analytes.
The low level (twice CRDL) linear range checks for total chromium, total
copper, total nickel, and total silver had low recoveries. All total chromium results
should be considered to be biased low by 25 percent. All total copper results
-------
should be considered to be biased low by 28 to 36 percent. All total nickel results
should be considered to be biased low by 12 to 25 percent. All total silver results
should be considered to be biased low by 35 to 40 percent. No total chromium,
copper, nickel, or silver results were found out of the range of the low level linear
range check so all results for these metals were affected and should be considered
semi-quantitative.
Total barium, beryllium, calcium, cobalt, iron, magnesium, manganese,
potassium, sodium, vanadium, and zinc results should all be considered quantitative.
All total aluminum, chromium, copper, nickel, and silver results should be considered
semi-quantitative.
The raw data for the dissolved metals determinations were not contained in
the data package. Without these data, only limited usability judgments can be made
about the data and all the ICP dissolved metals results should be considered to be
unreliable. These data are not generally required by the HWGWTF.
1.5 Mercury
No analytical problems were identified with the mercury results. All total and
dissolved mercury results should be considered to be quantitative.
2.0 Inorganic and Indicator Analvtes
2.1 Performance Evaluation Standard
Inorganic and indicator analyte performance evaluation standards were not
evaluated in conjunction with the samples collected from this facility.
2.2 Inorganic and Indicator Analvte OC Evaluation
The average spike recoveries of all of the inorganic and indicator analytes
were within the accuracy DQOs for all analytes except ammonia nitrogen which had
a slightly low average recovery of 84 percent (accuracy DQOs have not been
established for bromide and nitrite nitrogen matrix spikes but their average
recoveries were both 99 percent). This indicates acceptable recoveries for all these
analytes. All LCS and CVS recoveries reported in the raw data for inorganic and
indicator analytes were within Program DQOs. Average RPDs for all inorganic and
indicator analytes were within Program DQOs. Precision DQOs have not been
established for bromide and nitrite nitrogen.
Requested analyses were performed on all samples for the inorganic and
indicator analytes.
No laboratory blank contamination was reported for any inorganic or indicator
analyte. Total phenol was detected in an equipment blank at a concentration of 20
ug/L and TOC was detected in both the field blank and an equipment blank at
concentrations of 1500 and 1300 ug/L, respectively.
2,3 Inorganic and Indicator Analvte Data
The quality control results for cyanide, ammonia nitrogen, and total phenols
data are acceptable. The results for these analytes should be considered to be
quantitative.
-------
The holding times for the nitrate nitrogen analyses ranged from approximately
11 to 14 days from receipt of samples which, is significantly longer than the
recommended 48 hour holding time for unpfeserved samples. The laboratory did not
analyze a calibration blank at the beginning of the nitrate nitrogen run. A
calibration blank should be analyzed after the instrument calibration and before the
sample analysis. The nitrate nitrogen results should be considered semi-quantitative.
The laboratory did not analyze a calibration blank at the beginning of the
chloride run. A calibration blank should be analyzed after the instrument
calibration and before the sample analysis. Chloride results should be considered
quantitative.
The laboratory did not analyze a calibration blank at the beginning of the
sulfate run. A calibration blank should be analyzed after the instrument calibration
and before the sample analysis. Sulfate results should be considered quantitative.
The daily TOC instrument calibration data encompassing the expected
concentration ranges of the samples were not supplied with the raw data by the
laboratory. The laboratory also did not indicate the date of analysis in the raw
data. Holding times may have been exceeded. The TOC results should be
considered semi-quantitative.
No instrument calibration or calibration verification data were reported with
the raw POC data. Daily calibration of the instrument with an EPA or independent
calibration standard, at concentrations that encompass the expected concentration of
samples, is required. Also, a calibration blank was not analyzed at the beginning
and end of each batch of samples, as is required. The POC results should be
considered to be unreliable.
Instrument calibration data for TOX were not found for any of the analytical
batches. Instrument calibration, with standards that embrace the expected range of
concentrations of the samples, is required to be performed daily. Calibration
verification standards and blanks should also be analyzed every 10 samples and at
the beginning and end of each day's analyses. These standards were not analyzed
at the end of two analysis batches and this affects samples MQO368, 516, and 774.
The high level of chloride found in the sample MQO755 can cause positive
interference with the TOX analysis. Sample bottles lor samples MQO773 and 776
were broken in the laboratory prior to sample analysis. The TOX results should be
considered to be quantitative except for samples MQO368, 516, and 774 which should
be considered semi-quantitative and sample MQO755 which should be considered
qualitative.
Instrument calibration data were not found for any of the analyses.
Instrument calibration, with standards that embrace the expected range of
concentrations of the samples, is required to be performed daily. Also, a calibration
blank was not analyzed at the end of one of the analysis batches, as is required.
The POX results should be considered quantitative.
An initial calibration blank was not analyzed at the beginning of the bromide
analyses. Good laboratory practices include the analysis of a calibration blank after
the instrument calibration and before sample analysis. Bromide data for all samples
were acceptable and the results should be considered quantitative.
An initial calibration blank was not analyzed at the beginning of the nitrite
nitrogen analyses. The holding times for the nitrite nitrogen analyses were
approximately 11 to 14 days from receipt of samples which is significantly longer
-------
than the recommended 48 hour holding time for unpreserved samples. Nitrite
nitrogen data for all samples was acceptable and the results should be considered to
be semi-quantitative.
3.0 Organics and Pesticides
3.1 Performance Evaluation Standard
Organic performance evaluation standards were not evaluated in conjunction
with the samples collected from this facility.
3.2 Organic OC Evaluation
All matrix spike average recoveries were within established Program DQOs for
accuracy. Individual matrix spike recoveries which were outside the accuracy DQO
will be discussed in the appropriate Section below. All surrogate spike average
recoveries were also within DQOs for accuracy. Individual surrogate spike
recoveries which were outside the accuracy DQO will be discussed in the
appropriate Section below.
All matrix spike/matrix spike duplicate average RPDs were within Program
DQOs for precision. Individual matrix spike RPDs which were outside the precision
DQO will be discussed in the appropriate Section below. All average surrogate
spike RPDs were also within DQOs for precision.
All organic analyses were performed as requested. Direct injection volatile,
herbicide, and dioxin analyses were not requested or performed for any samples.
Laboratory blank contamination was reported for organics and is discussed in
the appropriate Sections below.
Detection limits for the organic fractions are summarized in the appropriate
Sections below.
3.3 Volatiles
Quality control data indicate that volatile organics were determined acceptably.
The chromatograms appear acceptable. Initial and continuing calibrations, tunings,
blanks, matrix spikes, matrix spike duplicates, and surrogate spikes are acceptable.
Several minor mix-ups were the only problems with the volatiles data. On one
date the laboratory ran a blank before a continuing calibration standard. On
another occasion, the laboratory mislabeled a RIC with the incorrect sample number.
Data usability was not affected.
The volatiles data are acceptable. The probability of false negative results for
the volatiles is acceptable. The estimated detection limits for the volatiles is CRDL
except for sample QO513 which is three times CRDL. The volatile compound results
should be considered to be quantitative.
3.4 Base/Neutrals and Acids
Calibrations, tunings, blanks, matrix spikes, matrix spike duplicates, surrogate
spikes, and chromatograms were acceptable for the semivolatiles.
-------
Di-n-butylphthalate was found in a semivolatile method blank (GH090335C21) at
an estimated concentration of 2 ug/L.
The relative percent difference (RPD) between matrix spike results for
pentachlorophcnol (76 percent) was above DQO (50 percent) for sample QO509.
The matrix spike recovery of 2,4-dinitrotoluene (99 percent) was above DQO
(24 to 96 percent). The matrix spike duplicate recovery for pentachlorophenol (7
percent) was slightly below the DQO limits (9 to 103 percent.
The surrogate percent recovery for tertphenyl-D14 (33-141 percent) in samples
QO513 (153 percent) and 712 (144 percent) and 2-fluorophenol (21 to 100 percent) in
samples QO368 (19 percent) and 773 (17 percent) were outside DQO.
One instrument blank on one date was not run under the submitted DFTPP
tuning interval.
The semivolatile data are acceptable and the results should be considered semi-
quantitative. The probability of false negatives is acceptable. Estimated detection
limits were twice CRDL for all samples.
3.5 Pesticides
The initial and continuing calibrations, blanks, and chromatographic quality for
pesticides were acceptable. The matrix spike, matrix spike duplicate, and surrogate
data were within acceptable limits.-
The laboratory did not submit raw data or chromatograms for pesticide method
blank #90159. Other pesticide method blank chromatograms show slight
contamination. Due to the laboratories use and variation of enlargement factors,
the extent of this contamination cannot be assessed.
Table 1 of Reference 3 (for organic analyses) lists peaks contained in the
pesticide chromatograms which were in the retention time window of pesticide HSL
compounds but which were not addressed by the laboratory in their data workup.
The estimated method detection limits for the pesticides fraction were CRDL
for all samples. The pesticides data should be considered to be unreliable due to
the lack of identification by the organic laboratory of many possible pesticide peaks
in the chromatograms. There is an enhanced probability of false negatives for
pesticides.
IV. Data Usability Summary
4.0 Graphite Furnace Metals, total and dissolved
Quantitative: antimony, cadmium, and lead; selenium with an exception
Semi-quantitative: arsenic and thallium
Unreliable: dissolved selenium result for sample MQO775
4.1 ICP Metals, total
Quantitative: barium, beryllium, calcium, cobalt, iron, magnesium, manganese,
potassium, sodium, vanadium, and zinc
Semi-quantitative: aluminum, chromium, copper, nickel, and silver
-------
4.2 ICP Metals, dissolved
Unreliable: all ICP dissolved metal results
4.3 Mercury, total and dissolved
Quantitative: all mercury data
4.4 Inorganic and Indicator Analvtes
Quantitative: cyanide, ammonia nitrogen, total phenols, chloride, sulfate,
POX, and bromide; TOX with exceptions
Semi-quantitative: nitrate nitrogen, TOC, nitrite nitrogen, and TOX data for
samples MQO368, 516, and 774
Qualitative: TOX data for sample MQO755
Unreliable: all POC data
4.5 Oraanics
Quantitative: all volatiles data
Semi-quantitative: all semivolatiles data
Unreliable: all pesticides data
IV. References
1. Organic Analyses: CompuChem Laboratories, Inc.
P.O. Box 12652
3308 Chapel Hill/Nelson Highway
Research Triangle Park, NC 27709
(919) 549-8263
Inorganic and Indicator Analyses:
Centec Laboratories
P.O. Box 956
2160 Industrial Drive
Salem, VA 24153
(703) 387-3995
2. Quality Control Data Evaluation Report for Four County, Indiana, 9/15/1986,
Prepared by Lockheed Engineering and Management Services Company, Inc., for the
US EPA Hazardous Waste Ground-Water Task Force.
3. Draft Inorganic Data Usability Audit Report and Draft Organic Data Usability
Report, for the Four County, Indiana site, Prepared by Laboratory Performance
Monitoring Group, Lockheed Engineering and Management Services Co., Las Vegas
Nevada, for US EPA, EMSL/Las Vegas, 9/16/1986.
-------
V. Addressees
Ed Berg
Chief, Project Management Section, Quality Assurance Branch, EMSL/CI
US Environmental Protection Agency
26 West St. Clair Street
Cincinnati, Ohio 45268
Anthony Montrone
Hazardous Waste Ground-Water Task Force, OSWER (WH-562A)
US Environmental Protection Agency
401 M Street S.W.
Washington, DC 20460
Garcth Pearson
Quality Assurance Division
US EPA Environmental Monitoring Systems Laboratory - Las Vegas
P.O. Box 1198
Las Vegas, Nevada 89114
Richard Steimle
Hazardous Waste Ground-Water Task Force, OSWER (WH-562A)
US Environmental Protection Agency
401 M Street S.W.
Washington, DC 20460
James H. Adams
Quality Assurance Office
Environmental Services Division
US Environmental Protection Agency
230 South Dearborn Street
Chicago, IL 60604
Joe Fredle
US Environmental Protection Agency
25089 Center Ridge Road
Westlake, OH 44145
Paul Friedman
Characterization and Assessment Division, OSW (WH-562B)
US Environmental Protection Agency
401 M Street S.W.
Washington, DC 20460
Chuck Hoover
Laboratory Performance Monitoring Group
Lockheed Engineering and Management Services Company
P.O. Box 15027
Las Vegas, Nevada 89114
-------
APPENDIX C
Analytical Results of Task Force Sampling
-------
SUMMARY OF CONCENTRATIONS FOR COMPOUNDS FOUND
IB LOW LEVEL GROUND-WATER AID SAMPLING
BLANK SAMPLES AT FOUR COUNTY. IN, Site 33
The following tables list the concentrations for compounds analyzed for
and four.d in samples at the site. Table Al-1 is generated by listing
all confounds detected and a listing of tentatively identified compounds
reported on the organic Form I, Part B.
Sample numbers are designated by the organic and corresponding inorganic
sample number. Organic sample numbers are preceded by the prefix "Q;"
inorganic sample numbers are preceded by the prefix "MQA."
-------
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-------
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-------
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49100
1330000
U
37000
200
81
1100
110000
400000
2540000
5000
50000
0.4 1
5470
191 I
1
I
9
154 !
1
;
108000 '
<
f
'
4420 '
!
38100 !
50 !
!
|
1
1
6550 !
1
135 !
i
3200 !
15 I
I
;
37500
2400 !
1
!
110
All CONCENTRATIONS API IN
Al-11
-------
APPENDIX D
Task Force Sampling Parameters
-------
SAMPLING PARAMETERS
Field Parameters
pH
Specific conductance
Temperature
Turbidity
Other Parameters
TOG
TOX
Chloride
local phenols
Sulface
Nicrace
Anncnia
POX
POC
Dissolved merals
Cyanide
METHOD 9060
METHOD 9020
METHOD 9252
METHOD 9066
METHOD 9036 or 9038
METHOD 9200
"Mechods for Cherucal Analysis of Wacer and Wasca"
USEPA - EWSL (Cincinnaci, 3/33, Method 350.1 or 350.3
EPA 600/4-3^-008
Ground Uacer, vol. 22, p. L3-23,
local raecals, and
I53-VA 8^-1092
-------
Appendix VIII METALS
METHOD 6010
Aluminum
Barium
Beryllium
Boron
Cadmium
Chromium
Iron
Lead
Nickel
Thallium
Vanadium
Zinc
Selenium*
Arsenic*
•These elements ar« not approved for 6010 but they are approved for
CLP .oetals ICP u>ethod. The CLP metals ICP method is identical to
the SW-846/6010.
Method 7470
Mercury
-------
Siiplt Number
Q036?
•bontorv
ab Sample 1C
ample utrii:
ata Release
uthoriztd ly:
CorpuChet
Ne: CK089905AI3
liquid
Or9«niM Analysis Data Sheet
(Paae 1)
Volatile Compounds
Concentration: ION
Date exacted/prepared: 06-17-86
Oat* analyztd: 96-17-86
Cone/Oil Factor: 1.00 pH: N/A
Percent moisture (not decanted): H/A
Case: M16SAS1
QC Report No:
Contract No: 68-01-7263
Date Sample
Received: 06-11-86
CAS
Nutter
74-87-3
74-93-9
75-01-4
75-00-3
75-09-2
67-64-1
75-15-0
75-35-*
75-34-:
156-60-5
67-6a-3
107-06-2
78-93-3
71-55-6
56-23-5
108-05-4
75-27-4
78-87-5
Chloromethane
Vinrl Chloride
Chioroettune
Hethyiene Chloride
Acetate
Carbon Bisulfide
1,1-DicMoroethene
1,1-Qichloroethans
trans-l ,2-Dichloroethene
Chloroform
i,2-3ichioroethane
2-Butanone
1,1,1-Trichloroethane
Carbon Tetrachieride
Vinyl Acetate
Bromodichloromethar.e
1 ,2-Dichloropropane
ire (not
09/1
10.
10.
10.
10.
5.0
10.
5.0
5.0
5.0
5.0
5.0
5.0
10.
5.0
5.0
10.
5.0
5.0
U
i»
U
U
U
U
U
U
ii
U
if
U
U
U
U
U
U
U
decanted): 1
CAS
Umber
10061-02-6
79-01-6
124-48-1
79-00-5
71-43-2
10061-01-5
110-75-8
75-25-2
108-10-1
591-78-6
127-18-4
79-34-5
108-8B-3
106-90-7
100-41-4
100-42-5
trans-l ,3-Di chl oropropene
Trichloroethene
Dibroiochlorotethane
1,1,2-Trichloroethar.e
Benzene
cis-l,3-Dichloropropene
2-Chloroethyl Vinyl Ether
BroiO-fori
4-Bethyl-2-?entanop«
2-Heianone
Tetrachloroethsne
1,1,2,2-Tetrachloroethane
Toluene
Chlorobenzene
Ethyl Benzene
Styrene
Total lylenes
ug/1
5.0
5.0
5.0
5.0
5.0
5.0
10.
5.0
10.
10.
5.0
5.0
5.0
5.0
5.0
5.0
5.0
U
U
U
U
U
U
U
M
ii
!J
L'
U
U
U
*
ii
L'
DATA REPORTING 3UALIFIERS
'or reporting results to EPA, the foiiaiiing results qualifiers are used. Additional flags or footnotes explaining results ire
encouraged. Ho»ever, the definition of eacti flag tust be explicit.
aiue If the result is a value greater than or equal to the
detection lint then report the value.
U Indicates coipound MS analyzed for but not detected.
Report the iiniiui detection lie.it for the satple nth
the U (e.g. iOU) based on necessary concentration/
dilution actions. (This is not necessarily the instrument
detection liiit.) The footncte should read: U-Coipound
•as analyzed for but not detected. The nuiber is the
•inifue attainable detection liiit for the saiple.
J Indicates an estimated value. This flag is used either
•hen estimating a concentration for tentatively identified
compounds *here t 1:1 response is assumed or nhen the mass
spectral data indicated the presence of a compound that
meets the identification criteria but the result is less
than the specified detection limit but greater than zero
Other
(e.g. 10J). If limit of detection is lOug and t
concentration of 3ug is calculated, then report as :.".
This flag applies to pesticide parameters «here the
identification has been confirmed by 6C/KS. Single
component pesticides >/* lOng/ul in the final extract
should be confirmed by SC/RS.
This flag is used vhen the analyte is found in th;
blank as veil as a sample. It indicates possible/
probable blank contamination and urns the data user is
take appropriate action.
Other specific flags and footnotes may be required tc
properly define the results. If used, they must be
fully described and such description attached to the
data summary report.
Form 1
10/85
-------
\f
ritory Nut: CO
i : 60t6SA;i
Saeplt Nu«t«r
Org*nics Analysis Data Sheet
(Piqe 2)
SMI volatile Compounds
IM
06-17-86
06-19-86
2.00
Phenol
bis(2-ChloroethyU ether
2-Chlorophenol
1,3-Dichlorobenzene
1,4-Oichlorobenzene
Ben:yi Alcohol
1,2-Qichloroberzene
2-1ethylphenol
bis(2-Chloroisopropyl> ether
4-flethyI phenol
N-Nitro!0-Oipropyia«:ne
Heiachioroethane
Nitrobenzene
Isophorone
2-Nitrophenol
2,4-Di»ethyipher.el
Benzole Acid
bis(2-Chioroethcxy! sethare
2,4-Dichlcropfcer.a!
1,2,4-Trichierobenzene
Naphthalene
4-Chloroaniline
Hexachlorobutadiene
4-Chioro-3-iethyiphenol
2-«ethyinaphthalene
Hexachlorocyciopentadiene
2,4,i-Trichlorophenol
2,4,5-Trichlorophenel
2-Chloronaphthalene
2-*itroaniline
Oiiethyl Phthalate
Aceniphthylene
3-Nitroaniline
centration:
I eitraeted/prepared:
• analyitd:
c/Dil Factor:
cent Mi sturt (decanted)
CAS
Nuiber
108-95-2
Ul-44-4
95-57-8
541-73-1
106-46-7
I00-51-6
95-50-1
95-48-7
9638-32-9
106-44-5
62l-s4-7
67-72-1
98-95-3
78-59-1
88-75-5
105-67-9
65-B5-0
111-91-1
120-83-2
120-92-1
91-20-3
106-47-8
87-68-3
59-5Q-7
91-57-6
77-47-4
88-06-2
95-95-4
91-58-7
88-74-4
131-11-3
208-96-8
99-09-2
u;/!
20.
20.
20.
20.
20.
20.
20.
20.
20.
20.
20.
20.
20.
20.
20.
20.
100
20.
20.
20.
20.
20.
20.
20.
20.
20.
20.
100
20.
100
20.
20.
100
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
i)
U
U
U
U
U
U
CAS
Nutber
83-32-9
51-28-5
100-02-7
132-64-9
121-14-2
606-20-2
84-66-2
7005-72-3
B6-73-7
100-91-6
534-52-1
86-30-e
101-55-3
118-74-1
87-36-5
85-01-8
120-12-7
84-74-2
206-44-0
129-30-0
85-68-7
91-94-1
56-55-3
117-81-7
218-01-?
117-84-0
205-99-2
207-08-9
50-32-8
193-39-5
53-70-3
191-24-2
6PC Cleanup: No
Separator? Funnel Extraction: Yes
Continuous Liquid - liquid Extraction: No
Acenaphthene
2,4-Oinitrophenol
4-Nitrophenol
Oibenzo^uran
2,4-Dinjtrotoluene
2.6-Oiritrotoluene
Oiethylshthalatt
4-Chlorophenyl Phenyl ether
Fluorine
4-Hitroanihne
4,6-Dinitro-2-§ethylphenol
N-nitrosodiphenyl3»ine (1)
4-Broeophenyl Phenyl ether
Hexachlcrobenzene
Pentachlorophenal
Phenanthrene
Anthracene
Di-n-butylphthalate
Fluoranthene
Pyrene
Butyl Benzyl Phthalate
3,3'-Dichloroben2idine
Benzoia)anthracene
bisi2-ethylhexyi)Dhthalate
Chrysene
Di-n-octy! Phthaiate
Benzotblfluoranthene
BenzotkHluor anthene
BenzoCalpyrene
Indeno(l,2,3-cd)pyrene
Dibenzla,h)anthracene
8enzo(o,h,i)perylene
(1) Cannot be separated trot diphenylatine
ug/1
20.
100
IOC
20.
20.
20.
20,
20.
20.
100
100
20.
20.
20.
100
20.
20,
20.
20.
20.
20.
40.
20.
20.
20.
20.
20.
20.
20.
20.
20.
20.
U
U
U
U
li
IJ
H
U
U
U
L
U
•J
U
I1
U
IJ
U
U
U
U
U
II
ii
!i
U
U
U
U
U
U
U
For* 1
10/85
------- |