May 1987 EPA-700/8-87-014
Hazardous Waste Ground-Water
Task Force
Evaluation of
Envirosafe Services, Inc. Site B
Grandview, Idaho
U.S. Environmental Protection Agency, Region 10
Idaho Division of Environment
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 10
and
THE HAZARDOUS WASTE GROUND WATER TASK FORCE
GROUND WATER MONITORING EVALUATION
Envirosafe Services of Idaho, Inc., Site B
Grand View, Idaho
May 1987
Marcia L. Bailey,
Project Coordinator
RCRA Compliance Section
U.S. EPA Region 10
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Acknowledgements
The contributions made to this report by Andrew Boyd, Robert Parrel 1
and Robert Stamnes are gratefully acknowledged.
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TABLE OF CONTENTS
page
EXECUTIVE SUMMARY i
INTRODUCTION 1
THE INSPECTION
Review of Records and Documents 5
Laboratory Evaluatlons 7
Field Activities 8
SITE HISTORY AND OPERATIONS
Overvi ew 12
Regulatory Information
Permi ts Hi story 15
Compl iance Hi story 17
Solid Waste Management Units (SWMUs) 20
Facility Discussion of Operations
Sol id Waste Management Units 28
Trench 5 29
Leachate Observation 30
Stabilization and Solidification 31
Surface Impoundments 32
Implementation of the Facility Contingency Plan 35
Conclusions 36
Evaluation of Facility Operations
Laboratory Evaluation 37
Waste Analysi s Plans 38
Waste Analysis and Tracking Records 44
Training 45
Concl usions 46
SITE HYDROGEOLOGY
Site Characterization Efforts 48
Ground Water Flow Directions and Rates 54
Possible Vertical Recharge around the Silo Complex 57
INTERIM STATUS GROUND WATER MONITORING PROGRAM
Background 59
Locations of Wei 1 s 61
Construction of Wei 1 s 63
ESII-B Sample Collection Procedures
Field Activities 69
Records Review 70
Sampl Ing and Analysis Plan 75
Outl ine of Ground Water Qual i ty Assessment Program 75
Statistical Analyses 78
Recordkeepi ng and Reporting 80
Concl usions 81
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Table of Contents, cont.
page
GROUND WATER MONITORING OF SILOS 85
PROPOSED GROUND WATER MONITORING PROGRAM
Wei 1 Locations 89
We] 1 Construction 90
Analytical Parameters 94
Monitoring for Heavy and Light Immi scibles 95
Purging and Sampling Techniques 96
Statistical Analyses 96
Non-statistical Evaluations 98
Wei 1 Maintenance 99
Determination of Water Table Elevations 99
Comments 101
GROUND WATER SAMPLE DATA RESULTS
Inspection data 105
Review of ESII-B Sampl ing Data 106
Concl us ions Ill
Figures after page
1 Locations of Well s 8
2 Location of ESII-B Faci 1 i ty 12
3 Locations of Solid Waste Management Units 12
4 Solid Waste Management Units Associated with the
Missi le Silo Complex 21
5 Missile Silo Compl ex Components 21
6 Stratigraphy of the Western Snake River Plain 49
7 Diagrammatic Cross-section of Upper and Lower Aquifers 51
8 Potentiometric Surface Map and Flow Lines for the Upper Aquifer...52
9 Potentiometric Surface Map and Flow Lines for the Lower Aquifer...52
10 A Demonstration of the Geochemical Differences between the Upper
and Lower Aquifers (Piper Diagram) 52
11 Upper Aquifer Equipotenti al Contour Map for July 1986 54
12 Upper Aquifer Equipotential Contour Map for December 1986 54
13 Locations of Monitoring Wells and Units Proposed in
ESII-B's Part B Permit Application 89
14 Proposed Monitoring Well Network for Upper Aquifer, with
Equipotential Lines 90
15 Proposed Monitoring Well Network for Lower Aquifer, with
Equipotential Lines 90
16 Proposed Upper Aquifer Well Typical Construction 91
17 Proposed Lower Aquifer Well Typical Construction 91
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Table of Contents, cont.
Tables after page
1 EPA Sample Collection Locations and Descriptions 9
2 Order of Sample Collection; Containers and Preservatives 10
3 Description of Sol id Waste Management Uni ts 21
4 Summary of Principal Aquifer Data 52
5 RCRA Ground Water Monitoring Wells for Interim Status Detection
Moni tori ng Program 61
6 Well Construction Summary 63
7 Depths of Wells Measured by EPA Compared with Depths Reported
in ESII-6 Construction Logs 65
8 Water Remaining in Wells with Submersible Pumps in which the
Wells are Pumped "Dry" Prior to Sampling 66
9 Quantities of Stagnant Water in Interim Status, PCS and Silo
Wells before Purging, Compared with Quantities Purged by ESII-B
Prior to Obtai ning Samples 68
10 Ground Water and Soil Contamination Reported
in the Area of the Si los 85
11 Historical Reports of Total Phenolics; ESII-B Ground Water
Samples, January 1984 to Apri 1 1986 109
12 Historical Specific Conductance and Total Dissolved Solids
Data for Wells Sampled During the June 1986 EPA Inspection 110
Appendices
A Field Measurements
B Parameters, Analytical Methods and Detection Limits for EPA Samples
Obtained at ESII-B
C Summary of Concentrations for Substances Reported in Ground Water and
Blank Samples Obtained during the EPA Inspection at ESII-B
D Evaluation of Quality Control Data and Analytical Data Generated from
EPA Samples Obtained at ESII-B
E Ground Water Analytical Data for Organic Compounds Detected in Silo Wells
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EXECUTIVE SUMMARY
BACKGROUND
This report describes the comprehensive ground water monitoring
inspection conducted at Envirosafe Services of Idaho, Inc., Site B (ESII-B), a
commercial, off-site hazardous waste land disposal facility located near Grand
View, Idaho. The inspection was conducted in June 1986 by Region 10 of the
United States Environmental Protection Agency (EPA) and the Idaho Department
of Health and Welfare, in conjunction with the EPA Hazardous Waste Ground
Water Task Force.
ESII-B is an operating treatment, storage and disposal facility which is
subject to the Resource Conservation and Recovery Act (RCRA), to the interim
status and permit application standards promulgated pursuant to RCRA, and to
applicable state of Idaho rules governing hazardous waste management
activities. The ESII-B site covers approximately 118 acres and is located at
the end of Missile Base Road approximately 10 miles west of Grand View, Idaho,
in Owyhee County.
The facility has been owned and operated by Envirosafe Services of Idaho,
Inc. since 1981. The site was formerly a United States Air Force Titan
missile defense facility, constructed in the late 1950s and early 1960s. Wes
Con, Inc., an Idaho corporation, subsequently purchased the site and operated
the facility beginning August 1, 1973. Hazardous waste was accepted and
disposed at the site both prior to and after November 19, 1980.
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There are three missile launch silos in addition to other underground
structures at the facility which were constructed by the U.S. Department of
Defense while the site was a Titan missile base. After acquisition of the
property and silo complex by Wes Con, and prior to November 19, 1980, many of
these underground structures were filled,with liquid and solid hazardous
wastes and PCS wastes.
ESII-B accepts a variety of wastes for land disposal, including
RCRA-regulated hazardous waste, wastes from Superfund sites, and PCB wastes
which are regulated pursuant to the Toxic Substances and Control Act (TSCA).
A Part B permit application has been submitted to EPA by ESII-B to continue
its hazardous waste management activities, including land disposal.
Objectives of the evaluation of ESII-B include determination of
compliance with the requirements of 40 CFR Part 265, Subpart F (interim status
ground water monitoring); 40 CFR § 270.14(c) (information required to be
submitted with the facility's Part B permit application); and potential
compliance with the requirements of 40 CFR Part 264 Subpart F. In addition to
wells designated by ESII-B as RCRA monitoring wells, the following ground
water monitoring wells were also subject to this inspection: wells installed
at the facility pursuant to a RCRA § 3013 investigative order; wells installed
pursuant to TSCA PCB-approval authorities; and test/observation wells and
piezometers at the facility.
The investigation team consisted of personnel from EPA Region 10; the
Idaho Department of Health and Welfare; EPA Headquarters; and contract
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personnel provided by the Task Force for obtaining ground water samples. To
accomplish the objectives, the investigation team reviewed records, inspected
the ground water monitoring system, reviewed on-site laboratory procedures,
conducted interviews with appropriate facility representatives, and collected
samples from 18 ground water monitoring wells for extensive chemical analyses.
FINDINGS
Interim Status Ground Hater Monitoring Program
ESII-B operates as an interim status land disposal facility and as such
is subject to the ground water monitoring requirements of 40 CFR Part 265
Subpart F. The facility operates a detection monitoring system to fulfill its
interim status ground water monitoring obligations. While the present
monitoring network affords a fair degree of assurance of protection of ground
water, several steps were identified which ESII-B should take to improve its
interim status ground water monitoring system and to secure more reliable
ground water samples. These steps are specifically delineated and discussed
in the text. They include recommendations which include or address the
following: (1) to incorporate an existing well into the monitoring network to
monitor downgradient of Trench 10; (2) to abandon or rehabilitate wells which
bridge the upper and lower aquifers; (3) to discontinue use of submersible
pumps for sampling purposes; (4) to purge at least three volumes of water,
including that calculated to reside in the filter pack, from each well prior
to purging, unless well yields prohibit this; (5) to obtain samples as soon as
feasible from wells purged to dryness; (6) to perform student's t-tests on
current indicator parameter data; (7) to comply with applicable EPA reporting
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requirements regarding ground water information; and (8) to increase the scope
of the facility's ground water quality assessment outline.
Hydrogeologic Characterization Efforts
Extensive work has been carried out by ESII-B in its efforts to
characterize the subsurface hydrogeology of the site, including saturated and
unsaturated zones. Such efforts have been sufficient to allow the design of
an adequate ground water monitoring system. There remain a few differences
between ESII-B and EPA in the interpretation of certain hydrogeologic factors
at the site, including ground water flow directions and rates in the middle of
the site. EPA recommends that water table elevations in this area and along
the northern boundary of the site be measured on a routine basis to provide
continual information on flow directions.
Moni tori ng of Silos
EPA and ESII-B entered into an Agreed Order in November 1983, requiring
an investigation of soils and ground-water contamination in the area of the
silos. ESII-B's subsequent sampling and analysis efforts at or near tne silos
demonstrated contamination in the form of volatile organic compounds in both
ground water and soils.
In October 1985, EPA issued a RCRA section 3008(h> order to ESII-B,
addressing remedial measures to be taken in the silo areas, should
contamination reach a specific concentration. In response, ESII-B initiated a
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silo well data assessment program to evaluate the presence of the
contamination. The assessment program included pumping three ground water
wells installed in the silo area for 15 days, subsequent to which
concentrations of the hazardous constituents in the silo wells decreased to
near or below detection limits.
In a report describing the results of the assessment program, ESII-B
offered its view that activities such as well drilling, well construction,
well development, sampling errors and/or analytical procedures could have been
responsible for the appearance of hazardous constituents in ground water
samples from the silo wells, as opposed to an actual release from the silo
complex. The analytical data support this conclusion. However, as detailed
in the report, EPA does not believe that the silo well data assessment program
adequately demonstrated that no release has occurred from the silo complex.
The data which were presented do not eliminate the possibility that the
volatile organics which have been detected are due to leakage from the silo
complex and that such contamination has migrated vertically through the
sediments to ground water.
Sampling and analysis of the silo wells and selected RCRA interim status
wells for volatile organic compounds is being required on a quarterly basis.
Should new evidence confirm that hazardous constituents have been released to
ground water, EPA would seek an accelerated investigation to fully
characterize the nature and extent of the contamination, in order to
facilitate any remedial action determined to be necessary.
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Proposed Ground Hater Monitoring Program
As part of its permit application, ESII-B has proposed a ground water
detection program which would monitor regulated units and which also includes
three wells to monitor the silos. ESII-B has proposed that each of the two
aquifers would have four upgradient wells. Sixteen downgradient wells are
proposed for the upper aquifer and eight for the lower aquifer. Proposed
construction designs and methods for the new upper and lower aquifer wells
appear to be appropriate for a detection monitoring system at this site.
ESII-B's rationale for horizontal spacing between wells is being evaluated and
independently studied by EPA.
Several comments regarding ESII-B's proposal for a ground water
monitoring system are made in the text. They address topics including the
following: (1) the continued use of original silo wells in the monitoring
network; (2) a discussion of the appropriate use of statistical methodologies;
(3) identification of appropriate indicator parameters; (4) the need to
identify specific concentrations (or trends) for individual parameters and
constituents which would act as triggers to address the possible existence of
ground-water contamination; (5) the importance of maintaining wells or
piezometers sufficient to evaluate ground water flow directions in the upper
aquifer; and (6) appropriate methods of purging wells prior to obtaining
samples.
Haste Tracking Records
Specific comments are made in the text regarding aspects of ESII-B's
current and historical waste analysis plans and tracking records. Based on
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such records, as well as on the degree of uncertainty in being able to
identify wastes which were disposed prior to ESII-B's ownership of the site,
it is concluded that monitoring of ground water potentially affected by each
waste management unit cannot be limited to those constituents identified by
ESII-B's operating records as having been disposed in the unit.
Results of Ground Nater Sample Analyses
The sample analysis data generated from this inspection are for the most
part unremarkable. Low levels of chloroform were detected in silo wells SW-1
and SW-3, consistent with the results ESII-B has obtained recently for those
wells. An unidentifiable semivolatile compound was reported in SW-3 at 17
ug/1, although it was not reported in the duplicate sample obtained from that
well. Low levels of phthalate compounds were reported in wells MW-11, MW-13,
PC8-1, PCB-2, PCB-3, MW-16 and MW-21, and in a field blank. Phthalates were
not detected in the stainless steel silo wells, reinforcing the belief that
phthalates are released from the polyvinyl chloride well casings.
N-buty!benzenesulfonamide was tentatively identified in Well D-19 at an
estimated concentration of 9 ug/1. The same compound was tentatively
identified in MW-3 at an estimated concentration of 17 ug/1 An
unidentifiable semi-volatile compound was identified at an estimated 215 ug/1
in MW-5.
Low levels of organic constituents (in addition to phthalates and other
compounds which apparently originated from equipment or laboratory
contamination) infrequently have been identified in ground-water samples
obtained by ESII-8 from its interim status well network over the past three
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years. Such findings have not been substantiated in location or over time,
either in ESII-B's frequent sampling efforts or in the comprehensive sample
analyses conducted as part of this inspection.
There does not appear to be any reliable evidence of ground-water
contamination at the site boundary of ESII-B in either of the two monitored
aquifers. As delineated in the text, ESII-B's techniques for purging and
sampling wells should be improved in order to be able to place more confidence
in the quality of the data generated from the samples it collects. From a
regulatory standpoint, ESII-B must fulfill its interim status obligations to
carry out required statistical analyses in order to obtain a RCRA permit
allowing it to operate in a detection monitoring mode. Long-term sampling of
wells in the silo complex area will be necessary to definitively determine
whether ground water contamination exists from past practices in that area.
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INTRODUCTION
The United States Environmental Protection Agency (EPA) is charged with
administration of the Resource Conservation and Recovery Act (RCRA), which
regulates operations at hazardous waste treatment, storage and disposal
facilities. Such facilities are subject to RCRA (as amended) and to
regulations promulgated thereunder, found at 40 CFR Parts 260 through 268, and
implemented through the hazardous waste permit program of 40 CFR Part 270.
These facilities are also subject to applicable state regulations, and in some
cases, state hazardous waste management programs may be in effect in lieu of
federal rules and regulations. In all instances, the regulations are intended
to address hazardous waste management operations to ensure that hazardous
waste is properly and safely managed. Ground water monitoring requirements
for land disposal facilities are included as part of these regulations, and
are intended to ensure that releases from hazardous waste management units
will be immediately detected, and that when such a release is known or
detected, that the nature and extent of the contamination will be fully
characterized, to enable prediction of contaminant movement and to facilitate
corrective action.
Commercial facilities which engage in land disposal of Hazardous waste,
and in particular those which accept waste from off-site generators for this
purpose, are being evaluated throughout the United States to determine
compliance with ground water monitoring requirements and to evaluate the
degree to which such facilities are protecting the ground water beneath their
sites. The inspections are being conducted in conjunction with the EPA
Hazardous Waste Ground Water Task Force (Task Force). The Task Force was
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established by the EPA Administrator to address rising concerns regarding
discoveries across the nation of incidents of serious ground-water
contamination. Hazardous waste land disposal facilities are a potential
source of contamination which occurs when pollutants such as toxic chemicals
seep through the soil Into underlying aquifers. Depending on the nature of
both the aquifer and the contaminant, such contamination may move off-site
with the ground water and cause serious consequences for downgradient users of
the aquifer water and other environmental receptors,
The Task Force effort has two major goals: to determine whether
regulated hazardous waste disposal facilities are meeting RCRA requirements to
protect ground water from contamination by hazardous materials, including
wastes taken from clean-up efforts at Superfund sites; and to identify and
evaluate causes of any deficiences in compliance and recommend measures to
amend such deficiencies.
This report describes the Task Force inspection at Envirosafe Services
of Idaho, Inc., Site B (ESII-B), a commercial, off-site hazardous waste land
disposal facility located near Grand View, Idaho. ESII-B accepts a variety of
wastes for land disposal, including RCRA-regulated hazardous waste, wastes
from Superfund sites (which may or may not be RCRA-regulated), and PCB
(polychlorlnated biphenyl) wastes which are regulated pursuant to the Toxic
Substances and Control Act (TSCA).
Objectives of the evaluation of ESII-B include determination of
compliance with the requirements of 40 CFR Part 265, Subpart F (interim status
ground water monitoring); 40 CFR § 270.14(c) (information required to be
submitted with the facility's Part B permit application); and potential
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compliance with the requirements of 40 CFR Part 264 Subpart F. In addition to
wells designated by ESII-8 as RCRA monitoring wells, the following ground
water monitoring wells were also subject to this inspection: wells installed
at the facility pursuant to a RCRA § 3013 investigative order; wells installed
pursuant to TSCA PCB-approval authorities; and test/observation wells and
piezometers at the facility. Specific objectives of the evaluation at ESII-B
included determining if:
(1) The ground water monitoring system is capable of immediately
detecting any statistically significant amounts of hazardous waste or
hazardous waste constituents that may migrate from the waste management
units to the aquifer which is uppermost in the vicinity of each waste
management unit;
(2) Designated RCRA monitoring wells are properly located and
constructed;
(3) ESII-B has developed and is following an adequate plan for ground
water sampling and analysis, and if well purging and sampling are
appropriately conducted;
(4) Required analyses have been conducted on samples from the
designated RCRA monitoring wells;
(5) The ground water quality assessment program outline is adequate;
(6) Ground water contamination currently exists;
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(7) The hydrogeology of the site and the geochemistry of the ground
water have been appropriately characterized; and
(8) Incoming hazardous waste is appropriately characterized by
generators and/or the facility, and adequately tracked by the facility.
The investigation team consisted of personnel from EPA Region 10; the
Idaho Department of Health and Welfare; EPA Headquarters; and contract
personnel provided by EPA Headquarters for obtaining ground water samples. To
accomplish the objectives, the investigation team reviewed records, inspected
the ground water monitoring system, reviewed on-site laboratory procedures,
conducted interviews with appropriate facility representatives, and collected
samples from selected ground water monitoring wells for extensive chemical
analyses.
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THE INSPECTION
The inspection of the ESII-8 facility consisted of the following
activities:
Review and evaluation of records and documents from the Region 10
office, the Idaho Department of Health and Welfare (IDHW), and
ESII-8;
Physical inspection of the facility from June 16 through June 25,
1986, which included further review of records and obtaining
ground-water samples; and
Analysis of ground water samples and subsequent evaluation of all
available ground water sampling data.
Participants in the inspection team consisted of the following: Marcia
Bailey and Andrew Boyd, EPA Region 10; Mark Torf, Katie Sewell, David Eighmey
and Al Ogden, IDHW; Robert Parrel 1, hydrogeology consultant to Region 10;
Brian Lewis, EPA Headquarters; and Richard Roat, David Billo and Julianne
Howe, GCA sample team.
REVIEN OP RECORDS AND DOCUMENTS
Records and documents from the EPA Region 10 and IDHW offices, comoiled
by an EPA contractor, were reviewed prior to and during the on-site
inspection. Prior to the inspection, company personnel were requested to make
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available specific, additional records during the inspection, including all
ground water monitoring data not previously submitted to EPA. Requests for
other records were requested during the inspection. A few records were
located and mailed to EPA subsequent to the inspection. Some records,
discovered to exist in ESII-B files, were not made available until March 1987.
During the inspection, a review of selected facility records was
conducted to determine the nature, extent, and reliability of waste analyses
and waste location records prepared by ESII-B since it obtained the facility
in 1981. Facility representatives were interviewed to aid in identifying
documents of interest and to discuss the contents of documents, and to discuss
facility operations. A soecial session was held during the first week of the
inspection in which the hydrogeologic characterization of the site was
discussed among EPA, IDHW and facility representatives.
Records selected for review were copied. They included all waste
analysis plans used by ESII-B at the site, and a selection of the following
records prepared from 1982 to the time of the inspection: waste analysis
records for waste generated on-site and off-site, manifests, waste location
records, inspection logs, training records for those conducting waste sampling
and analyses, and laboratory audit records. Also copied for review were the
facility's ground water assessment outline, ground water statistical
evaluations, and analytical results from ground water sampling.
Company personnel [specifically, corporate personnel located at
Envirosafe Services, Inc. (ESI) corporate offices in Pennsylvania] were called
upon during the preparation of this report to discuss and clarify various
issues and to provide additional information and data, as needed.
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Many of the records collected during the inspection were claimed by
ESII-B as Confidential Business Information (CBI). This claim covered such
documents as waste analysis plans, internal control forms, sampling and
analysis pians, and the ground water monitoring assessment outline. At EPA's
request, ESII-B qualified the CBI claim, making it possible to distribute this
document.
EPA inadvertently discovered very late during the report preparation
that records containing the results of monthly ground water sample analyses
existed and were in the possession of the company, but had not been provided
to or shared with EPA either during the inspection or in any other forum,
including the Part B permit development process. These data include
analytical parameters beyond those minimally required by applicable
regulations, including Priority Pollutant volatile and base/neutral
extractable compounds. Attempts to obtain these data from Envirosafe
personnel were successful. The analytical data that were provided are
discussed in this report, in the section on ground water sample data results.
LABORATORY EVALUATIONS
The off-site laboratory which has generated most of ESII-B's
ground-water data 1s ETC of Edison, New Jersey. This laboratory was evaluated
in July 1985 for its ability to produce quality data for required analyses, as
part of another Ground Water Task Force inspection. The August 1986 Ground
Water Task Force report for Chem-Security Systems, Inc. includes a discussion
of the laboratory evaluation. The problems noted with TOC analyses reportedly
have been corrected.
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11
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3
en
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At ESII-B's on-slte laboratory, waste analyses are performed on a
portion of the wastes accepted from off-site facilities. This laboratory was
visited during the inspection to confirm the availability of equipment
necessary to implement the current waste analysis plan. Record-keeping
procedures were also observed.
FIELD ACTIVITIES
Field activities included identifying current waste management units and
surface drainage routes, verifying monitoring well locations, obtaining ground
water elevation and well depth measurements, collecting samples from 18 ground
water monitoring wells, and observing ESII-B contractors purge and sample two
moni tor ing wel1s.
Field Team Sampling Activities
On the first day of the inspection, organic vapor readings (using an Hnu
meter) and depth-to-water measurements were made by the field team at 34 of
the 46 piezometers and ground water monitoring wells at ESII-B. In all cases
attempts were made to Identify and use the same measuring point on the well
that the facility utilizes for such measurements. On subsequent days of the
inspection, additional water level measurements were made at each well to be
sampled. Based on the measurements obtained by the field team, water level
contour maps were constructed to compare with those submitted by the
facility. Locations of wells are shown in Figure 1.
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-------
To verify well-construction records, well-depth measurements were made
by the field team at 11 wells, and depths to the top of the permanently-
Installed submersible pumps were determined at three others. These
measurements are presented In this report in the section on ESII-B's interim
status ground water monitoring program.
Samples from 18 ground water monitoring wells were obtained by the field
team during the Inspection. Upgradient and downgradient wells representing
both upper and lower aquifers were selected for sampling. For the most part,
downgradient wells were selected on the basis of being most likely to be
affected by current or past hazardous waste management practices at the
t
facility. Duplicates or replicates of samples from each well and of blank
samples (trip, equipment and field) were provided to ESII-B representatives.
A summary description of the sampling activities of the field team at
each well is given in Table 1. Wells were purged using either
permanently-installed submersible pumps, dedicated bladder-type pumps,
three-foot Teflon bailers provided by GCA, or a 20-foot stainless steel bailer
attached to a truck rig, which was kindly provided by ESII-B for wells which
would have proved formidable to purge otherwise. Samples were obtained with
the pumps, where in place; and with Teflon bailers in all other locations.
Submersible pumps were temporarily removed by ESII-B from four wells at EPA' s
request, to avoid using the pumps for sampling purposes during this inspection,
Typically, samples were collected by the field team pursuant to the
following procedures at each well:
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10
- A depth-to-water measurement was made using an electrical tape
designed for this purpose. The probe was cleaned subsequent to
each use.
- Depth to the bottom of each well was measured where possible.
(This was not possible when either a submersible pump was present
in the well, or when the well depth exceeded 250 feet, which was
the length of the measuring device provided by GCA. The GCA
interface probe was also not of use due to its short length
relative to the water table elevations at this site.) The height
of the water column was calculated from the measured depth to water
and the depth to the bottom of the well (if not measured, using the
value reported in ESII-B well-construction records).
The volume of standing water in the casing was calculated.
- The well was purged of the volume of water indicated in Table 1.
Purging activities at some wells required time lapses between
subsequent purges and/or sampling events, depending upon individual
well yields and casing volumes.
- Sample aliquots were collected three or more times during purging.
Field measurements (water temperature, pH and specific conductance)
were obtained from these aliquots (and are reported in Appendix A).
- Samples were obtained as soon as practicable after purging was
completed. Containers were filled in the order shown in Table 2.
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Table 2
ORDER OF SAMPLE COLLECTION;
CONTAINERS AND PRESERVATIVES
1.
2.
3.
4.
5.
6.
7.
8.
J-
10.
11.
U.
13.
Parameter
Volatile organic: analysis (VOA)
Purge and trap
Direct inject
Purgeaole organic caroon (POC)
Purgeaole organic nalogens (POX)
Extractaole organics
Dioxin
Total metals
Total organic carbon (TOC)
Total organic nalogens (TOX)
Pnenols
Cyanide
Nitrate/ammoma
Sulfate/cnloride
Car Donate/ Bicarbonate
Bottle
2
2
1
1
4
2
1
1
1
1
1
1
1
1
40-ml
40-ml
40-ml
40-ml
1
1
1
4
1
1
1
1
1
1
-qt.
-qt.
-qt.
-02.
-qt.
-qt.
-qt.
-qt.
-qt.
-qt.
Preservative*
(Concentration)
VOA vials
VOA vials
VOA vials
VOA vials
ameer
amber
plasti
glass
amoer
amber
plasti
glass
glass
c
glass
glass
c
plastic
plasci
plasti
c
c
HN03 (95-98%)
H2S04 (95-98%)
H2S04 (95-98%)
NaOH (12N)
H2S04 (95-98%)
Volume added to eacn sample *as 5 ml except for TOC, wnere aoout 1 ml was
added.
-------
11
- Sample containers were filled directly from the Teflon bailer or
pump di scharge 1i ne.
- Samoles were placed in an ice chest and returned to the GCA staging
area for shipment preparation. Samples obtained for the analysis
of metals, TOC, total phenols, cyanide, nitrate and ammonia were
preserved (Table 2). Split samples for ESII-B were similarly
prepared and turned over to facility personnel at the end of each
day.
- Each day, samples which had been obtained that day (and/or the
afternoon of the previous day) were packaged and shipped, under
chain-of-custody, to the EPA contract laboratories. Shipping
procedures were according to applicable U.S. Department of
Transportation regulations (40 CFR Parts 171-177). Monitoring well
samples were considered "environmental" for shipping purposes.
Samples were analyzed by the EPA contract laboratories for the parameter
groups shown in Table 2. Specific parameters and detection limits are listed
in Appendix 8. At well MH-5, samples for only volatile organics, extractable
organics and total metals were obtained due to insufficient volume and time.
Duplicate samples were obtained at wells SW-1 and SW-3. Field blanks were
obtained near wells MW-25, MW-16, and SW-3. Equipment blanks were made for a
Teflon bailer and a stainless steel pump (which was not used during the
inspection). A trip blank which accompanied the GCA personnel to the site was
also submitted for analysis. The trip blank was composed of high purity water
subjected to high performance liquid chromatography.
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12
SITE HISTORY AND OPERATIONS
OVERVIEW
The ESII Site B facility (ESII-B) is an operating treatment, storage and
disposal facility which ts subject to RCRA, to the interim status and permit
application standards promulgated pursuant to RCRA, and to applicable state of
Idaho rules governing hazardous waste management activities. The facility is
seeking a final RCRA permit for those activities. The ESII-B site covers
approximately 118 acres and is located at the end of Missile Base Road
approximately 10 miles west of Grand View, Idaho, in Owyhee County. Owyhee
County, encompassing 7000 square miles, is an area of agricultural activity
and ranges, and contains a birds-of-prey sanctuary adjacent to the facility
boundary. The county is sparsely populated, with an average of approximately
one person per square mile. The site location is shown in Figure 2, and the
current site plan is shown in Figure 3. Approximately 30 people are employed
by and work at the facility.
The facility has been owned and operated by Envirosafe Services of
Idaho, Inc. (ESII) since 1981. The site was formerly a United States Air
Force Titan missile defense facility, constructed in the late 1950s and early
1960s. Wes Con, Inc., an Idaho corporation, subsequently purchased the site
and operated the facility beginning August 1, 1973. Wes Con received a
Conditional Use Permit in June 1973, issued by IDHW for disposal of pesticide
wastes. Wes Con submitted a Notification of Hazardous Waste Activity and a
Part A application to EPA in 1980 and qualified for Interim Status for
hazardous waste storage and disposal activities. The facility accepted and
disposed of hazardous waste both prior to and after November 19, 1980.
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Figure 2
J^ • MOUHTAIM HOME
•GRAND view
ESII SITE B
9180M.CO
LOCATION OF ESII
SITE 8 FACILITY
-------
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en
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is
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13
There are three missile launch silos and other underground structures at
the facility which were constructed by the U.S. Department of Defense while
the site was used as a Titan missile base. The silos are each approximately
60 feet in diameter, and extend to depths of 160 feet below the surface.
Underground structures associated with the silos include smaller side silos, a
power house, control center, antenna silos, elevator and exhaust shafts, and a
tunnel system. After acquisition of the property and silo complex by Wes Con,
and prior to November 19, 1980, many of these underground structures were
filled with liquid and solid hazardous waste and PCS wastes. The integrity of
the underground missile base structures at this time is unknown.
In August 1981, the site was acquired by ESII, which is a wholly owned
subsidiary of IU Conversion Systems, Inc., a Delaware corporation. The site
is now known as ESII-B. Hazardous waste operations at the site were continued
under the new ownership. A revised Part A permit application was submitted to
EPA by the facility requesting approval to add treatment as a hazardous waste
management activity to be conducted at the facility. This was approved by EPA
in February 1982.
Initial waste management activities at the site involved disposal of
mostly pesticide wastes In the three main silos and other underground
structures associated with the silos. As capacity in these structures
diminished, a number of disposal trenches were excavated and used for waste
disposal. In addition, drums of hazardous waste were stored in many locations
at the site. In 1978, the site received certification to dispose PCS wastes
in the missile silos. In 1979, the state approved disposal of PCB wastes in
trenches near the silos.
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14
Current and/or recent hazardous waste management activities at the
facility include the following:
- Storage of bulk, and/or containerized hazardous waste.
- Solidification of hazardous waste In containers (and bulk
solidification prior to May 8, 1985).
- Management of recyclable hazardous waste for reclamation or
incineration at other hazardous waste management facilities.
- Disposal of hazardous waste by landfill burial.
Wastes not regulated by RCRA or TSCA are also managed at ESII-B.
Specific units and hazardous waste management activities are described in
further detail later in this report.
Many of the waste disposal units have reached capacity and no longer
receive waste. The regulatory status of each land disposal unit no longer in
operation is determined by the date hazardous waste was last placed in it. In
addition to old units and currently-active units, specific new units have been
proposed in ESII-B's Part 8 permit application. Active units as well as many
which are no longer active are shown in Figure 3,
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REGULATORY INFORMATION
Permits History
In June 1973, Wes-Con (then the owner/operator of the site) was granted
a Conditional Use Permit for pesticide-waste disposal by IDHW. It was stated
then that the disposal of hazardous waste other than pesticides would require
specific state approval, to be granted on a case-by-case basis.
In March 1977, subsequent to the occurrence of fires in the silos,
Wes-Con received a revised Conditional Use Permit that required Wes-Con to
lower drums into the silos rather than drop them, as previously had been done.
In 1978, Wes-Con received approval from the state of Idaho and EPA for
the disposal of PCBs in the on-site missile silos. In 1979, Wes-Con received
approval for disposal of PCB wastes in trenches adjacent to the silos and was
issued a revised Conditional Use Permit by IDHW for non-liquid disposal of
PCBs. This Conditional Use Permit, which is broad in scope and encompasses
management and disposal of both PCB and RCRA wastes, is currently in effect.
In 1983, EPA modified the site's PCB disposal approval by increasing
ground water monitoring requirements. Also in 1983, EPA called for the
submittal of the facility's RCRA Part B permit application for hazardous waste
management activities. The application was submitted on December 15, 1983.
EPA sent Notice of Deficiency letters regarding the application to ESII-B in
February 1984 and in January 1985. Revised Part B applications were submitted
in May 1984, May 1985 and April 1987. Updated information regarding site
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16
characterization for ground water program designs (Section E of the permit
application) were submitted in January 1985 and in February 1986. Revised
proposals for the ground water detection monitoring program (Section E-6 of
the permit application) were submitted in December 1986 and April 1987.
While Idaho is not yet authorized to implement a hazardous waste
regulatory program in lieu of the federal government, the state has
promulgated environmental statutes and regulations to which ESII-B is
subject. The Idaho legislature passed the Hazardous Waste Management Act
(HWMA) in 1983 giving the Board of Health and Welfare the authority to develop
regulations. The Idaho Rules, Regulations and Standards for Hazardous Wastes
were adopted In January 1985 and are consistent with the RCRA regulations.
The Idaho legislature added a new section to the HWMA in 1986 which adopted
the "California list" of land disposal restrictions. This ban affects the
types of wastes which ESII-B can accept for disposal. For example, hazardous
waste containing halogenated compounds in total concentration greater than, or
equal to, 1000 ppm may not be landfilled. In addition to these regulations
specific to hazardous waste, ESII-B is also subject to the Idaho Solid Waste
Management Act. The Conditional Use Permits which have been granted to ESII-B
were done so pursuant to this act.
ESII-B also operates pursuant to federal PCB-approval authorities under
TSCA, which regulates the disposal of PCB-containing materials. In 1982, a
Letter of Approval was issued covering disposal into silos and trench 4.
Trench 4 is now fu'l, and a closure plan has been submitted for it. ESII-B
currently disposes PCB-containing wastes pursuant to a temporary Letter of
Approval, which,allows for such disposal in one-third of the newly-constructed
-------
trench 5. It 1s anticipated that a final Letter of Approval will be issued
concurrently with the final determination of the RCRA permit, and that it will
address the entirety of trench 5, closure of past units which were approved
for PCB disposal, and ground water monitoring requirements (including how such
requirements will be carried out as part of the RCRA ground water monitoring
program).
Compliance History
In the early years of the site's operations, compliance actions taken
against the facility typically took the form of enforcement correspondence
between EPA and/or IDHW and the facility. These enforcement actions usually
resulted in the issuance of a revised state Conditional Use Permit. For
example, in 1977, the Conditional Use Permit was revised to require lowering
of the drums into silos, and in 1978 it was revised to allow PCB disposal ;n
trenches and silos. In a criminal trial in 1981, Wes Con was convicted of
i1 legal disposal of PCBs.
In March 1981, IDHW assessed a penalty against Wes Con, then the site
owner/operator, for Improper management of containers, in violation of the
Conditional Use Permit. The penalty was paid by the new owner, ESII-B.
Subsequent to inspections of the facility, EPA issued an administrative
order to ESII-S in November 1983. The order, issued pursuant to sections
3008(a) and 3013 of RCRA, required ESII-B to institute changes in the ohysical
condition of the site and site operations; to implement a plan that would
ensure that free liquids would not be placed in trench 11; to come into
compliance with 40 CFR Part 265 Subpart F ground water monitoring
-------
requirements; and to implement a sampling, analysis, and monitoring plan to
determine whether hazardous waste or hazardous waste constituents had leaked
from the silos or other underground structures at the site.
In August 1984, another administrative order was issued by EPA to ESII-B
pursuant to RCRA § 3008(a). Site inspections by IDHW and EPA had revealed a
number of violations regarding drum storage ranging from improper manifesting,
to the presence of leaking and improperly-closed drums. Violations concerning
the storage and disposal of incompatible wastes were also noted. A pond where
hazardous waste solidification activities were being carried out was ordered
to be removed from service, as it was being utilized as an unpermitted
hazardous waste management unit. ESII-B was assessed punitive damages and
ordered to come into compliance with applicable regulations, as well as to
investigate and remove soil contamination which may have occurred as a result
of improper drum storage and hazardous waste solidification practices. An
Agreed Order between EPA and ESII-B was signed in October 1984 in resolution
of this action.
A RCRA § 3008(a> Complaint and Compliance Order was issued to ESII-B in
August 1985, citing further violations of RCRA. Inspections conducted by EPA
and IDHW in 1985 revealed that ESII-B had Improperly manifested hazardous
waste shipments. The order required that this situation be corrected, and
also required ESII-B to amend its closure plan, revise its contingency plan,
and implement a plan to decontaminate the exterior surfaces of vehicles
leaving certain waste management areas of the site.
Another RCRA § 3008(a) Complaint and Compliance Order was issued to
ESII-B in February 1986, primarjly concerned with record-keeping violations
-------
observed by IDHW and EPA Inspectors. The order was not contested by ESII-B,
which was required to pay a penalty and institute measures to come into
compliance.
IDHW assessed a penalty to ESII-B in October 1986. for violations of
Conditional Use Permit requirements regarding cover material at trench 11.
EPA issued a corrective action order pursuant to RCRA § 3008(h) to
ESII-B in October 1985. This order addressed the presence of hazardous
constituents in ground water near the silos, discovered as a result of the
investigation undertaken in compliance with the § 3013 order issued in 1983.
A consent agreement was executed on February 12, 1986, which requires ESII-B
to conduct regular sampling of the silo wells and four downgradient, RCRA
perimeter wells, and to remove ground water in the event tnat the
concentration of any volatile organic compound exceeds 1 Dpm. ESII-B has
reserved its right to obtain a hearing on the order; and EPA has reserved its
right to demand an answer to or compliance with all other outstanding terms of
the original order.
ESII-B has contended that the presence of constituents found in the
ground water from the silo wells were caused by carry-down from contaminated
soils during well-drilling activities, from lab error, or from improper
sampling procedures. To investigate this, the facility instituted a pumping
program in which the three original silo wells were continuously pumped and
intermittently sampled over a period of about 15 days, immediately preceding
this inspection. The results of that effort, which showed diminished
concentrations of contamination, are discussed in the section on silo well
-------
20
monitoring. EPA considers the continued monitoring of the silo wells to be
necessary.
SOLID HASTE MANAGEMENT UNITS (SHMUs)
ESII-B includes units which fall into several categories:
(1) Units which received or stored hazardous waste before, but not
after, November 19, 1980: These units are not subject to the 40
CFR Part 265 interim status standards or to the 40 CFR Part 264
permitting standards of RCRA. They are, however, subject to other
applicable statutory and regulatory requirements of RCRA, pursuant
to the RCRA Hazardous and Solid Waste Amendments of 1984. Such
units are generally referred to as "not regulated," despite the
fact that, as described here, they are regulated under distinct
statutory provisions. These units are being addressed as part of
the RCRA permitting process, as required by section 3004(u) of RCRA;
(2) Units which received or stored hazardous waste after November
19, 1980: These units are subject to all applicable RCRA statutory
and regulatory requirements and are generally referred to as
"regulated units," as distinguished from the units described in
paragraph (1), above;
(3) Units which have been permitted to receive PCB wastes and
which are subject to TSCA requirements; and
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21
(4) Units which were not in existence on November 19, 1980, which
have not qualified for interim status, and which are not permitted
to receive hazardous waste: this category includes an evaporation
pond and three run-off collection ponds constructed in 1984 in
response to an EPA compliance action; the temporary solidification
pond which was operated without regulatory status or other
approval; and any other units (existing or future) which may be
included in the Part B permit application but which do not qualify
to be utilized for interim status hazardous waste management
activi ties.
Physical descriptions of units which have received hazardous and/or PCB
wastes and which are included in categories (1) through (3), above, are given
in Table 3. Their locations can be found in Figure 3. Trench 5, which was
under construction during this inspection, is the only existing trench which
is lined. It is operated under RCRA interim status and in the past year
received TSCA approval to receive PCB wastes in an area comprising one-third
of its surface area. Figures 4 and 5 are illustrations of SWMUs associated
with the missile silo complex.
ESII-B's application for final permitted status includes storage and
treatment in tanks; treatment and storage in containers; disposal in
landfills; storage, treatment and disposal in surface impoundments; operation
of the existing vehicle wash station; and closure of numerous temporary
storage areas.
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3. DESCRIPTION OF SOLID WASTE MANAGEMENT UNITS
Unit
Received
PCB #1
PCB #2
PCS #3
PCd #4
Cnem #1
Cnem #lb
Cnem #2
Cnem «*2b
Cnem #2C
Cnem #2L)
Cnem #2E
Cnem #3
Cnem #4
Cnem #43
Cnem #5
Cnem #5B
Horizontal
Dimensions,
Feet
Hazardous Waste Prior to
650 x20
1 ,300 x40
500 x50
710 xl 10
o2Q x35
590 x30
610 x20
470 x20
b70 x20
280 x20
270 x20
640 x30
520 x2b
430 x2S
230 x20
230 x20
Vertical
Dimensions,
Feet
Novemoer 19,
40
30
30
55
20
20
20
20
20
20
20
20
20
20
20
20
Vo 1 ume
(ft3)
1980
520,000
1 ,560,000
750,000
4,295,000
434,000
354,000
244,000
188,000
228,000
1 12.000
108,000
384,000
260,000
215,000
92,000
92,000
Location
Nortn side of site
Nortn side
Nortneast (NE)
side
Middle of site
near power station
NW quadrant
of site
NW quadrant
NE quadrant
NE quadrant
NE quaarant
NE quadrant
NE quadrant
NW quadrant
NE quadrant
NE quaarant
NE quaarant
para 1 1 e 1 to east
side
NE quadrant
paral lei to east
side
(continued)
-------
Taoie 3. (continued)
Unit
Received Hazardous
Cnem #o
Cnem #oa
Cnem #6B
unem #7
Cnem #6
Cnem #9
Silo * l
Si lo #l
( prope 1 lant room;
Si lo #1
(equipment termina
Si lo #2
Si lu fZ
( propel lant room)
Si lo ltd
(equpiment ternnna
Horizontal l/ertical
Dimensions, Dimensions,
Feet Feet
Waste Prior to Novemoer 19,
210 x20 20
180 x20 20
180 x20 20
220 x!5 20
240 x20 20
240 x40 20
40 dia. loO
40 aia. 35
4z dia. 6
-------
Taole 3. (continued)
Unu
Horizontal
Dimensions,
Feet
Vertical
Dimensions,
Feet
Volume
(ft3)
Location
Received Hazardous Waste Prior to Novemoer 19. I960 (cont.)
Silo #3 40 dia,, 160 201 ,062 Middle of
nortnerly portion
of site
Silu #3
(propellant room)
40 did
35
Si 10 #3 42 did 68
(.equipment terminals;
43.982
J4.2IO
Middle of
nortnerly portion
of sue
Middle of
nortnerly portion
of site
Antenna
Silo II
Antenna
Silo #2
Control Center
Elevator
Snatt
Exnaust
Snaft
Buried Drum
Area I
Buried Drum
Area 2
Aci a Disposal
Pi t #1
38 dla. 67
38 di a . 67
IOU dia 4U
30 dia 70
27 dia 40
Rlgnt trianqle
sides 100' ,70'
75' 20
Trapezoid sides
180' , 140' , dO1 ,
120' 20
20 x20 10
•
76,000 SE quadrant
7o,000 SE quadrant
Near po*ernouse
9,480 Middle of site
23,720 Middle of site
52,600 Nrt corner near
si lo #2
374,000 Middle of site
near silo #3
4,000 NE quadrant near
cnemica) trencnes
(continued
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Taole 3. (continued)
Unit
Horizontal
Dimensions,
Feet
Vertical
Dimensions,
Feet
volume
(ft3)
Location
RCKA-Reguldtea Units (cont.)
Paa #5 IUU xlOU
(Container storage;
original ly
so 1 101 fication
Urjin/ Container
Storage Areas
Temporary
So I lui tication
Pond
40 x50
unKno*n
Nortn of Si lo #3
Open areas a I I
around site;
oounded oy PCB 4,
Cnem Trencn 10
and Trencn 5
Soutn of
Trencn 5
Cental ner
Storage Area
Near Si lu # j
Storaye Tanics
1,2,3
Temporary Storage
Tanics (2)
unnno*n
16,000
gaI Ions eacn
20,000
ga I Ions ea .
Ola sol idi Mcation
area next to Si Io3
Process taci I i ty
Pad 4 wnen in use,
since disposed in
Trencn I I
-------
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u
\ \
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; *J
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^ ««
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-------
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22
Missile Silos I. 2. and 3
The missile silos were the first disposal units at the facility to
receive hazardous waste. None of the silos reportedly received waste after
November 19, 1980. The main silos are approximately 60 feet wide and 160 feet
deep with walls up to six feet thick and floors 13 feet thick. The main silos
and the side silos are interconnected by tunnels. Silo 2 has a 100-ton
reinforced concrete door which has been sealed. In addition. Silo 2 is fitted
with a vent pipe and a pressure relief valve intended to vent the silos should
extreme pressure excursions occur. Silos 1 and 3 are capped with compacted
soi 1.
Antenna Silos, Control Center, Equipment Terminals, Elevator Shafts,
Tunnels and Prppellant Rooms
Most of the structures associated with the missile silos reportedly were
used for disposal of hazardous waste. However, they are not RCRA-regulated
units, as they ceased receiving hazardous waste prior to November 19, 1980.
According to facility personnel interviewed, the tunnels associated with the
silos have blast doors at every joint, and the doors are believed to be
sealed. Disposal has occurred in the silos and side silos and in portions of
the tunnels. The power house associated with the silos reportedly was not
used as a site of waste disposal.
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23
PCB Trenches
Disposal of PCB wastes began in 1978 with the authorization to dispose
of PCBs in the silos. In 1979, Wes-Con received authorization to dispose of
PCB wastes in trenches. Since then, five trenches have been excavated and
used for PCB disposal. Trench 5 is the only PCB disposal location which is
active and which is also regulated under RCRA interim status and permitting
standards. The other PCB units are not RCRA-regulated, as they did not
receive hazardous waste (as defined under RCRA) after November 19, 1980. All
of the units are regulated under TSCA.
Chemical Trenches 1-9
Disposal in chemical trenches was initiated after the capacities of the
silos were reached. The chemical trenches are located in the northern portion
of the facility. The trenches range from 180 to 1300 feet in length. For
purposes of volume estimation, all chemical trenches are assumed to have a
depth of 20 feet. These trenches are not regulated under RCRA interim status,
as it has been reported that wastes were not placed in them subsequent to
November 19, 1980.
Buried Drum Areas 1 and 2
Two areas are identified on Figure 3 as containing drums of hazardous
waste. These buried-drum areas are assumed to be unlined pits approximately
10-20 feet deep. These areas ceased receiving hazardous waste before November
19, 1980 and hence are not regulated units.
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Acid Disposal Pits
Two small areas are identified on Figure 3 as containing acid wastes.
These areas are assumed to be unllned pits approximately 20 feet deep. It is
possible that acid wastes were dumped into these pits in bulk liquid form for
several years during operation of these units. These areas did not receive
hazardous waste after November 19, 1980 and are not regulated units.
Buried Transformer Skin Areas
Two areas are identified on Figure 3 as containing buried transformer
skins. These areas are assumed to be unlined pits approximately 10-20 feet
deep. They did not receive hazardous waste after November 19, 1980 and are
not regulated units. During the inspection, facility personnel indicated that
there is some doubt that these units actually exist. They were initially
identified based on employee interviews, but have not been substantiated in a
review of facility records by ESII-B.
Burial Haste Area and Chemical Area #1
These areas are identified on Figure 3 as containing buried chemical
wastes. Like the other buried waste areas, these areas are assumed to be
unlined pits approximately 20 feet deep. They also are not regulated units,
since they did not receive hazardous waste after November 19, 1980. The
existence of the unit identified as "buried waste," adjacent to the
maintenance facility, has not been substantiated in a review of facility
records by ESII-8. It was initially identified based on employee interviews.
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Trench 11
Trench 11 1s an active, RCRA-regulated unit located along the north edge
of the site. It was created by ESII-B after its purchase of the site. The
trench is unlined and is filled nearly to grade. ESII-B intends to place
waste in trench 11 to above-grade levels. The unit is reported to have an
approximate depth of 50 feet. Many drums were exhumed from trench 11 in 1984
due to reports that drums containing free liquid hazardous waste and
improperly solidified, liquid hazardous waste had been disposed in it.
Exhumation efforts were ceased before all of the drums were removed, based on
personnel safety considerations, the amount of free liquids being found in the
exhumed drums, and estimation of the fluid retention capacity of the trench.
A leachate detection system, consisting of two standpipes placed in low areas
of the trench, was instituted subsequent to this activity.
Trench 5
Trench 5 is a new, double-lined trench that reportedly began receiving
PCB wastes in November 1986 and RCRA wastes in December 1986. It is the only
land disposal unit that may qualify to receive federally-directed CERCLA
wastes, since no other trench at ESII-B is lined, and since no special
demonstration was made showing that disposal in any unlined units is
adequately protective of human health and the environment.
Trenches IQa and IQb
Trenches lOa and lOb are located adjacent to trench 11. They are
4RCRA-regulated units, having received hazardous waste after November 19,
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1980. The trenches are assumed to be 40 feet deep. They have not been
closed, but are presently covered with native soil from the site. It is
anticipated that they will be closed subsequent to the final RCRA permit
determination and along with closure activities for trench 11.
Pads 4 and 5
These areas, used as solidification pads until sometime during 1984, are
identified on Figure 3. Pad 5 is now used for container storage and
handling. Pad 4 is next to the process facility and is used as a staging area
for drums. Although some decontamination activities have taken place, it has
not yet been demonstrated that land disposal of hazardous waste or hazardous
waste constituents did not occur as a result of the operation of these units
for solidification activities. ESII-B is obligated to address these units in
its closure plan unless removal to background levels is demonstrated prior to
faci1i ty closure.
Collection Ponds 1.2 and 3 and the Evaporation Pond,
These ponds, constructed in 1984 pursuant to an EPA administrative order
to better manage and control on-site run-off, are located in the northwest and
northeast corners of the site, near the center of the site, and in the middle
of the eastern edge of the site, respectively. In a letter from Lee Cleveland
of Envirosafe Services, Inc. to EPA Region 10, dated February 11, 1986, it is
stated that "the units are not regulated units and do not contain hazardous
liquids." They are not considered to have qualified for interim status, and
therefore may not receive hazardous waste. Leaks have been detected in the
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primary liners of the evaporation pond and collection pond 3. Repairs have
been made, and monitoring is being continued to determine if all leaks have
been repaired.
Drum/Container Storage Areas
Drums are currently stored near silo 3 (pad 5) and on a concrete slab
(pad 4) in the processing plant. The earlier uses of pads 4 and 5 for
solidification are discussed above.
For a period after November 19, 1980, many drums and containers were
stored on ground surface (with no secondary containment) in the area roughly
bounded by trench PCS 4, trench 10, and trench 5. Poor container management
practices occurred in these areas, with leaking drums and improperly closed
drums identified by EPA and IDHW inspectors. An administrative order issued
by EPA in 1984 required sampling of the soils in the affected areas. However,
sampling and analytical efforts by ESII-B following soil excavation in these
regulated storage areas have failed to demonstrate complete decontamination to
background levels. Unless such demonstration is made prior to facility
closure, ESII-B is obligated to address these areas in its closure plan.
Temporary Solidification Pond
This area is located south of trench 5 on the western side of the site.
The lower aquifer is the uppermost aquifer at this unit. The unit was a lined
pit in the ground, used for hazardous waste solidification during 1984.
Cessation of use of this unpermitted unit, and soil contamination studies of
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this area, were required by the 1984 EPA administrative order; however,
analytical data from soil sampling has not yet been submitted. The liners and
some soil have been removed from the area, and ESII-B has stated its intention
to excavate additional soil from the area and resample prior to submitting
analytical data confirming clean-up. ESII-B 1s obligated to address this unit
in its closure plan unless removal to background levels is demonstrated prior
to fad 1 i ty closure.
FACILITY DISCUSSION OF OPERATIONS
Facility representatives were questioned regarding operations at the
site. The following is a summary of their responses. It was indicated that
bulk stabilization of liquids has not been conducted at the facility.
Solid Haste Management Units
When asked if information contained in recent submittals to EPA (made
upon request pursuant to § 3004(u) of RCRA) regarding past waste disposal
practices at the site was complete, facility representatives indicated that an
underground concrete tank, believed to be an old electrical vault, had been
discovered east of the operations trailer following soil subsidence above it.
This finding was not included in the subject documents. The tank is located
on the side of the site road opposite the laboratory and the administrative
trailer. The facility also has discovered a corrugated drainage pipe which is
part of an old military drainage structure. It was discovered in a
magnetometer survey southeast of trench PCB-4, and is said not to contain any
waste.
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The company's original submittal to EPA on past disposal practices
identified buried waste northwest of the maintenence trailer, and buried
transformer skins (two locations) west of trench PCB 4, but these were not
confirmed in a review of facility records, according to ESII-B.
Facility representatives indicated that land disposal conducted by the
prior owner of the site was generally shallow, on the order of 10-20 feet
deep. Information available concerning the nature of the covers on the units
is limited, according to ESII-B, but the trenches are believed to be covered
with three feet of soil. The horizontal locations of past disposal units are
believed to be within 10 feet of the locations identified in the 3004(u)
submittal. The units were surveyed pursuant to the state's conditional use
permits. Survey information was submitted to EPA by letters, dated May 30,
1986 and March 17, 1987.
Facility representatives indicated that the silos are gunnite-sea!ed
both inside and out, have walls which are eight feet thick, and were
constructed without calcium-treated concrete to avoid drying and cracking.
Trench 5
The facility engineer described the installation of trench 5. The
original lining was installed in 1984. It is now double-lined with 40 and 60
mil HOPE liners. Following the original excavation of native soils, the area
was hand-raked, and all aggregate larger than 1/2-inch was removed along with
any remaining sharp particles. The liners were installed in the south
one-third of the trench. A double connection was used on all seams. All
seams were pressure-tested and where greater than a 57. loss in pressure was
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observed the seams were patched. Twelve inches of sand have been placed over
the primary Hner In the bottom of the trench along with a four-inch HOPE
perforated pipe wrapped with geotextile, which was installed in the sand as a
leachate detection system. A hole was found in the primary liner. A third
liner was placed over the top of the primary liner in the bottom southern
third of the trench to plug the hole. Between the primary and secondary
liners is a sand layer of about 18 inches. A drainage net and a french drain
with 4-inch HOPE pipe has been installed between the liners for leak detection.
The final two-thirds of the trench have three feet of compacted clay
under the two liners. The liners are 60 and 80 mil HOPE, respectively.
Leachate Observation
According to facility records, leachate observation standpipes are
installed in trenches PCB 1, PCS 2, PCS 3, PCB 4, Chem 1, Chem IB, Chem 6,
Chem 68, RCRA lOb, and RClRA 11 (two standpipes). These pipes are checked
monthly for the presence of liquid. In trench 11 a french drain of gravel,
two feet deep, with a PVC riser-pipe which has a 10-foot screen and a 4 foot
silt-sump, has been installed in the lowest part of the trench, according to
the facility. There is a gravel trench between the two leachate detection
pipes.
Inspection logs for these standpipes from June 1983 through May 1986
were reviewed. The pipes are checked monthly for liquid with an electrical
conductivity meter or weighted sponge. On the following occasions liquid or
dampness in the pipe(s) was noted, as recorded in the logs:
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- liquid detected on 2/28/86 in trench 11 (11 8).
- dampness noted on 8/30/85 in trench PCS 4.
- dampness noted in trench 11 (11 A) on 8/30/85.
- liquid found on 7/26/85 in trench PCS 4 (300 milliliters was
removed).
- dampness noted in PCS 4 on 11/9/84.
- dampness noted in all standpipes in 12/83 and 1/84.
- dampness noted in PCB 1, PCB 2, Chem 1, Chem 2B, Chem 6, and Chem 6B
on 9/16/83.
- dampness noted in Chem 2B in 8/83.
Samples were withdrawn from the leachate pipes in PCB 4 on 8/7/85, and
from pipe 11 8 on 3/3/86. The sample from the PCB trench was analyzed for pH,
TOC and PCBs. Recorded results indicate less than 1 ppm PCB, 7.37 pH, and 18
ppb TOC. The sample from trench 11 was analyzed for pH (6.88), PCBs (less
than 1 ppm), TOC (62 ppb), conductivity (800), chloride (57.5), and hardness
(56.1) (units for conductivity, chloride and hardness were not identified in
the report). Metals and organic analyses were not conducted.
According to facility representatives, disposal at the site since ESII-B
obtained the facility, until the time of this inspection, had been in trenches
PCB 4, PCB 3, 11, and lOb. Trench 11 was excavated to 50 feet, and trench
PCB 4 to 40 feet. Both of these trenches are said to have bottoms that slope
to a low point. Leachate observation standpipes have been installed in the
trenches. Synthetic liners do not exist in any of the trenches, except trench
5, which began receiving waste in November 1986. Some unlined trenches
reportedly have a charcoal base.
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Stabilization and Solidification
The locations on site where solidification of waste occurred were
identified by facility representatives. They are pad 5, pad 4, a temporary
pond south of trench 5, the concrete pads near silos 1 and 2, and the bulk
solidification plant. Concrete pads exist in all these areas except the
temporary area, where a double synthetic/soil liner (described previously) was
said to have been used to cover the depression where the solidification
occurred. Solidification of bulk loads occurred on pads 4 and 5 and in the
temporary solidification pond, but ceased in 1984, pursuant to an
administrative order issued by EPA. Solidification was also said to have been
conducted in the silos by the prior owner of the facility.
Surface Impoundments
The evaporation pond and three run-off collection ponds, which are not
interim status hazardous waste management units, were constructed in the same
manner as the first 1/3 of trench 5, according to the facility. They have a
60 mil HOPE primary liner overlaying a leak collection zone. The secondary
liner is 40 ml 1 HOPE placed over base geotextile on compacted, native soil.
The leak collection system between the liners consists of 12-18 inches of
free-draining, granular materials with a geotextile-wrapped HOPE drain pipe.
The ponds do not, however, have a leachate detection system above the primary
liner since liquids are placed in these impoundments. Above the primary liner
is an 18-inch bed of sand and cobbles to protect the liner. Construction of
the surface impoundments was completed and all were put into operation in
October and November 1984.
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According to facility Inspection logs, liquid was detected in the leak
detection systems in collection pond 3 and the evaporation pond on
August 30, 1985. Memos to the file indicate that approximately 2300 gallons
were pumped from between the liners in the evaporation pond in October 1985,
and more than 20,000 gallons during the period February through March 1986.
Approximately 4000 gallons of liquid were pumped from collection pond 3 during
September, October and November of 1985. Another 2000 (approximately) gallons
were pumped out between February 25, 1986 and April 24, 1986. Samples drawn
from the leak detection systems were analyzed for pH and TOC, and in some
cases for conductivity, total hardness, and chloride. Values for pH ranged
from 9.69 (evaporation pond) to 6.81 (pond # 3).
Disposal records indicate that the following materials have been placed
in the evaporation pond: liquid waste from the truck, wash sump; liquid waste
from the lab sump; liquid pumped from the trench 5 primary leachate detection
system (prior to the time the trench began receiving waste); liquid from
collection ponds 1, 2 and 3; liquids from containment at the power dome;
drilling water; water collected from silo pad 3 and pads 4 and 5; plant sump
liquid; silo pump test water; water from the RCRA and PCB tank containment
areas; rain water collected at the PCB building and from puddles around the
site; bulk receiving dock sump water; and PCB building filtered water.
Analyses of lab sump waste were conducted from January to June 1985, for
pH, TOC, PCBs, arsenic, silver, barium, cadmium, chromium, lead, mercury and
selenium. Analyses for EP toxicity pesticides were also conducted for samples
drawn on April 29, 1985; May 6, 1985; and May 13, 1985. The results of these
limited analyses did not indicate that the materials were characteristic
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hazardous waste. During the same period, analyses for pH, TOC, and, In some
cases, PCBs, chloride, hardness, and/or conductivity were conducted on rain
water collected from puddles, storage areas, the bulk receiving sump, the drum
unloading sump and bay area, the plant sump, decant sump, pad 4, T-4 tank
sump, PCS tank sump, PCS tank containment area, RCRA tank sump (T-5 & T-6),
pad 5, PCS capacitor building, Pad 3, PCS drain and flush area; and on other
liquids including filtered water from the PCS area. The results are limited
for purposes of hazardous waste characterization, but do not indicate that any
of the materials tested is a hazardous waste. In general, the following
values were recorded: TOC less than 100 ppb; pH between 6 and 11; and PCS
less than 2 ppm, although there were instances of higher values for PCBs and
TOC.
Disposal records indicate that the following materials have been placed
in the following collection ponds: pond 1 - rain water from trench 11, water
from trench 5 (up to 11/8/85); pond 2 - rain water from trench 11; rain water
from pad 4, trench 5 rain water and water from leak detection systems (until
11/22/85), decant sump rain water, bulk receiving and decant sump rain water;
collection pond 3 - truck wash overflow. Samples drawn from the impoundments
were analyzed 1n most cases for pH, conductivity, total hardness, TOC and
chloride. Reported values for pH ranged from 10.95 (pond 1) to 7.07 (pond 3).
The Inspection log for January 31, 1986 shows damp soils reported in the
leak detection system for collection pond 2. The log for November 30, 1985
indicates water in the leak detection system in collection pond 1. No records
were provided to indicate that any pumping had been conducted at these two
ponds. Dye tests were conducted in the three collection ponds and in the
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evaporation pond. Magnesium chloride was also used in the collection ponds as
a tracer for purposes of leak, detection. According to the facility, leaks
were suspected in collection pond 3 and the evaporation pond. Leaks which
were located were repaired, and the facility is continuing to monitor for
evidence of any remaining leaks.
The facility has conducted daily inspections of the surface impoundments
(collection ponds 1, 2, and 3, and the evaporation pond) on site since July 1,
1985 for problems, including damage, maintenance of freeboard, and dike
integrity. Problems were noted on reports of inspections conducted from
5/21/86 to 6/3/86. A hole in the primary liner above the water mark was noted
for collection pond 1 on logs from 5/22/86 to 6/2/86. Duct tape was used to
provide a temporary patch and was checked daily. On the 6/3/86 log it was
noted that tne run-on pipe for collection pond 1 had washed out, and the down
pipe was clogged. It was noted that corrective action needed to be taken but
that the pond could continue to operate.
Implementation of the Facility Contingency Plan
Reports provided indicated the following:
- On May 31, 1983, on pad 4, a fire occurred on the pond solidification
area involving approximately 12,000 gallons of waste ink, paint sludge,
degreaser solvents (non-halogenated), grease, oil, and halogenated
solvents. The fire was brought under control with bulldozers, foam and
water-fogging after approximately 200 gallons of the waste were consumed.
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- On April 25, 1984, while solidifying waste containing methylene
chloride, methyl alcohol, and a propletary chemical Naprone, an odor was
detected and said to be from methyl mercaptan. The material was
landfilled and backfilled with clean fill to control the odor after
so!idifi cation.
- On January 18, 1984, vapor releases were detected from two drums of
organophosphate pesticide waste. The drums were overpacked and
landfi11ed.
- On June 5, 1984, there was a release of organic vapors when solidified
waste containing sulfamic acid was placed in trench 11. Ten to 15 cubic
yards of activated carbon and clean fill were used to control the vapors
and cover the area. The specific cause of the release was not
determined.
- On November 16-18, 1984, 30 gallons of liquid leaked from incoming
trucks containing PCS and solvent wastes. Liquids leaked on-site were
said to have been contained and cleaned up. The liquids were solidified
and placed in overpack. drums. Soil removed as part of the clean-up was
disposed 1n trench PCB 4.
Conclusions
The primary liners for the evaporation pond and collection pond 3 have
leaked. The ability of these units to prevent liquid releases to the soil,
particularly with regard to past activities, is not assured. However,
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disposal records indicate that these units are not used for hazardous waste
shipped to the site. Limited analytical data for purposes of hazardous waste
characterization do not indicate that the materials disposed in the surface
impoundments are characteristic hazardous waste. The generation of a vapor
cloud in trench 11 on June 5, 1984, and the facility's inability to Identify
the cause of the incident, indicate a likely failure of waste analysis and/or
tracking procedures.
EVALUATION OF FACILITY OPERATIONS
Laboratory Evaluation
Off-site contractor laboratories conduct the analyses of ESII-B's
ground-water samples. The facility has an on-site laboratory which is used
primarily for analysis of waste samples. A tour of that laboratory was
conducted with the facility's laboratory manager to confirm that equipment
necessary to implement the waste analysis plan was available. The equipment
in the facility lab included a gas chromatograph (the lab manger indicated
that the facility hopes to add columns to provide for PCB analysis at the
parts per billion level), pH meters, EP extraction equipment, a TOC analyzer,
an atomic absorption spectrophotometer, a hood, a refrigerator, an oven, and a
di shwasher.
The lab manager explained that the laboratory technicians usually obtain
the samples. Sampling information is recorded in a field notebook and on the
facility internal control form (ICF). The lab logbook is used to assign
numbers to samples of waste without ICF numbers, such as samples of rain water
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and lab sump waste. The numbers are assigned by year and In sequence - e.g.,
86-199 would be the 199th sample taken in 1986. Laboratory data for ICF loads
are kept in lab notebooks, and are also transferred to ICF forms. Waste
product questionnaires are also kept on file in the laboratory.
Hexane is used to decontaminate glassware by hand for the gas
chromatograph. Waste from RCRA and PCS samples are handled as RCRA and PCS
waste, according to the lab manager. Other wastes go to the lab sump, which
is a. double-lined, 1,000-gallon tank. These wastes are eventually disposed in
the evaporation pond.
The site laboratory participates in EPA's water pollution laboratory
performance evaluation studies. Records of participation between February
1985 and April 1985 indicate that the laboratory's performance was outside the
range of acceptable values for analyses of arsenic, chromium, iron, mercury,
and selenium. In a letter to EPA, ESII-8 attributed the incorrect values for
chromium and iron to calculation errors. The other discrepancies were
attributed to outdated analytical standards, dirty equipment, and
inappropriate analytical procedures (for selenium). The study conducted
between August 1985 and October 1985 indicated that the ESII-B lab-generated
results were outside of acceptable ranges for analytical results for zinc, pH,
arsenic and selenium. Performance evaluation results for tests conducted
between February and April 1986 were not provided.
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Haste Analysis Plans
Before the facility treats, stores or disposes hazardous waste, it is
obligated [40 CFR §265.13(a)] to obtain a detailed chemical and physical
analysis of a representative sample of the waste sufficient to ensure proper
treatment, storage, and/or disposal. Off-site facilities such as ESII-B are
also required to inspect and, as necessary, analyze waste received to
determine if it matches the identity of the waste described in the records
submitted by the generator. ESII-B's waste identification procedures are
described in the facility's waste analysis plans. Major revisions of the
facility waste analysis plans occurred in 1983, 1984 and 1985.
In general, ESII-B's waste analysis plans require the generators to
provide the necessary waste characterization data. On occasion, ESII-B may
request a pre-shipment sample and conduct the necessary analyses for the
generator. The plans also identify procedures for checking wastes upon
receipt at the facility to verify the information supplied by the generator.
The waste analysis plans used at the facility were reviewed to evaluate the
ability of the facility to reliably identify and locate hazardous constituents
managed at the facility, using operating records.
Facility personnel indicated that laboratory procedures for cyanide and
sulfide analyses are not contained in the waste analysis plans, but did
present written lab procedures used for confirming the absence of free
cyanides and sulfides. The facility also has a series of standard operating
procedure (SOP) documents which supplement the waste analysis plan:
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RCRA Hazardous Waste Sampling - 3/1/84
ESII Classification Procedure - 11/23/84
Classification Procedure - Table 3 - 11/7/83
Quality Assurance Testing - 9/14/81
Quality Control Testing - 3/1/84
PCS Sampling Procedure - no date
Section 7 - Envlronmental Services - SOPs
According to facility representatives, the waste analysis plan and
procedures in use from 1981 until December 1983 are contained in three
documents: the Waste Analysis Plan (four pages, not dated), Sampling of
Hazardous Waste Standard Operating Procedure (dated 8/28/80), and Quality
Testing Standard Operating Procedure (dated 9/14/81). These plans and
procedures fail to provide necessary technical detail. Specific deficiencies
identified are a:; follows:
- A description of the parameters to be analyzed and an explanation of
how selected parameters will provide Information needed to properly
treat, store and/or dispose of wastes received, are not included.
- The plan does not Indicate test methods to be used.
- The plan does not Include the sampling methods generators are to use
in obtaining representative samples, although sampling methods to be
used by ESII-B for Incoming wastes are included.
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- The plan does not address the frequency of analyses to be conducted by
generators for specific waste streams to ensure that the analyses are
accurate and up to date.
- The plan does not describe how waste analyses are to be conducted for
different waste management processes at the site to assure compatabi11ty
(e.g., at solidification units and landfills).
- The plan does not contain procedures to be followed if inspections
show that a waste is unacceptable to the facility.
- The ESII-B document "Sampling of Hazardous Waste Standard Operating
Procedure" describes sampling procedures for incoming waste loads, but
it does not provide sampling methods for solids in both open and closed
bed trucks, as called for in "Test Methods for Evaluating Solid Waste,
SW-846, Second Edition" (SW-846). The plan calls for use of tubes for
sampling, which Is not among those devices recommended for sampling in
SW-846. In addition, the sampling method provided does not address the
need to obtain representative samples.
- The plans do not Indicate that personnel involved in sampling will be
trained and evaluated.
In 1983, a second waste analysis plan was developed. It became
effective in December of that year. It was revised in June 1984. These plans
improved upon the earlier plan, but the following deficiencies were identified:
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- The plan does not describe the manner in which thin or viscous liquids
will be homogenized to obtain a representative sample. The plan calls
for using tubes for sampling and provides a method, but does not
indicate how representative samples will be obtained.
- The plan indicates that a collwasa sampler may be used for liquids,
powders and some cakes. Coliwasa is not among those devices recommended
in SW-846 for sampling of powders and cakes. Similarly, the plan
indicates that a scoop may be used to sample liquids, when a scoop is
not among the devices recommended by SW-846 for sampling liquids.
- The plan provides a sampling method for trucks, but it does not
provide sampling methods for solids in both open and closed bed trucks,
as called for in "Test Methods for Evaluating Solid Waste, SW-846,
Second Edition" (SW-846).
- The facility classification procedure indicates that volatile, toxic
liquids are not safe to handle. The waste analysis plan does not state
that such wastes will not be accepted at the facility.
- The plan indicates that the facility will use special techniques to
obtain very deep soil samples. A soil sampling plan to obtain such
samples should be included.
- The plan and procedures do not provide for the periodic maintenance
and servicing of laboratory equipment (standard operating procedures
were later developed for equipment maintenance, dated 11/25/85).
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- The plan calls for sampling 101 of containers received from off-site
facilities; however, the plans and procedures do not describe a
procedure for randomly selecting 101 of such containers for sampling.
- Although the plan and procedures include chain-of-custody procedures,
they do not provide procedures to determine the disposition of remaining
samples after analysis, and to document and record test results.
The waste analysis plan in use at the time of the inspection was
implemented on 5/31/85. It also improved upon the earlier plans; however,
potential deficiencies were identified, as follows:
- The plan calls for screening by composite sampling of up to 10 drums.
Analysis of the individual container samples without compositing (so as
not to mask the presence of material that does not fit the description)
would be a more reliable screening procedure.
- Compatabi1ity testing/determinations should be performed for all
stabilized or solidified waste designated for land disposal. The plan
indicates that this is not routinely done. It is stated in the plan
that "...incompatible materials when solidified/stabilized properly
become compatible." The plan should also identify how landfill and
storage cells are designated so as to assure adequate separation of
incompatible materials.
- The stated sample holding time in the plan for mercury analysis is 38
days. The EPA recommended holding time is 28 days (SW-846). In
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addition, the plan Indicates that no preservation is required for
samples requiring determinations of settleable matter. This Is contrary
to EPA methods which call for maintaining such samples at 4 degrees
centi grade.
- The plan provides for the use of tubing, spatulas, and vacuum samplers
as sampling devices. These are not included in SW-846. The plan
describes the equipment and how it is used, but does not indicate how
representative samples are to be obtained using this equipment.
- The plan does not describe procedures that the laboratory will follow
to record the disposition of remaining samples after analysis and to
document and forward test results for filing.
- The waste product questionnaire instructions for generators calls only
for providing percent ranges of constituents in the waste, but does not
call for providing concentrations to the ppm level for hazardous
constituents at: less than 0.1%, as required in the prior waste analysis
plan.
Haste Analysis and Tracking Records
Any hazardous waste load received at ESII-B is assigned a unique
tracking number. Each container in that load is marked with that number.
Records for that load reference the tracking number, referred to as the
internal control form (ICF) number. Storage locations are recorded on the
ICF. Disposal locations are recorded on field disposal forms, on the ICF, and
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on a three-dimensional map of the disposal trench. The 3-D disposal maps were
examined for several of the waste loads received. The disposal trench In use
at the time of the inspection (trench 11) is divided into cells approximately
70 feet wide by 5 feet long by 15 feet high for purposes of recording disposal
location. The records reviewed indicate the cells in which the wastes are
buried.
The facility records for a number of loads received In 1982, 1983, 1984,
1985 and 1986 were copied for review. The results of that review indicate the
following: in several cases, waste analysis records for loads received prior
to 1983 were not complete, Including in some cases, the absence of ESII-B
fingerprint results, and in others, incomplete waste characterization data;
generator laboratory analysis data sheets were not available for most wastes
received, although waste product questionnaires were submitted; and many of
the completed waste product questionnaire forms provide broad percentage
ranges rather than the specific concentrations. Information on sampling
methods used for each waste was not provided.
Training
The waste analysis plans in use after 1983 indicate that personnel
involved in sampling incoming waste loads will be trained. Records provided
on the training of employees who perform sampling and analytical work were
requested and reviewed. Resumes and employment applications that described
relevant training and education obtained outside of employment at ESII-B were
not examined.
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46
Records provided on training of samplers indicate that a single two-hour
course on sampling was offered on May 21, 1986. A memo to the file Indicates
that the laboratory technician who assumed that position in August 1985
received on-the-job training from the previous lab technician. No other
records were presented to document sampling training for that individual. The
facility provided no records indicating that training had been provided to
personnel who perform analytical techniques; however, training for such
personnel may have been obtained prior to or apart from their employment by
ESII-B.
Conclusions
Sampling and analytical information available for several of the waste
loads reviewed, particularly for the years before 1984, were incomplete.
Deficiencies were also identified in the current and past facility waste
analysis plans.
Problems were identified !n laboratory performance and sampling
methods. Classroom training of samplers has been deficient. A two-hour
sampling training course is unlikely to provide sufficient time to present and
make understandable all necessary information regarding sampling procedures
and techniques.
Consequent to these findings, it must be concluded that monitoring of
ground water potentially affected by each unit cannot be limited to
constituents identified in the operating record as being handled in that
unit. Should there come a time when assessment or compliance ground water
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47
monitoring is required at the facility, a more thorough analysis of the ground
water would be necessary than might otherwise be required if the identities of
constituents disposed were more completely known. However, this situation is
also attributable to the nature of the disposal activities which occurred at
the site before it was owned by Envirosafe Services.
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48
SITE HYDROGEOLOGY
Site Characterization Efforts
Investigations into the hydrogeology of the ESII-B site have been
reported in the original Part 8 permit application, December 1983; revised
Part 8 application, January 1985; ESII Site B Hydrogeology and Ground Water
Monitoring supplement, March 1985 (appendix K); Supplemental Analysis of
Hydrochemical Conditions at ESII Site B, November 1985; Interim Progress
Report - Site Characterization - Proposed Trench 14 Area, ESII Site B,
November 1985; and ESII Site B Site Characterization and Ground Water
Monitoring Program, February 1986. The content of this section draws
extensively on the information included in the February 1986 report.
The site characterization has been accompanied with mapping of the local
geology [Benfer, J.A., 1984, Geology in the Vicinity of the Envirosafe
Hazardous Waste Site (Site 8) near Grand View, Idaho] in the vicinity of the
facility and with demonstrations of how the site fits into the local geology.
The site itself was studied with 52 test borings, of which 13 were
continuously cored, 30 were geophysically logged, 34 were completed as test
wells and five were completed as piezometer clusters. Fourteen slug or pump
tests were done to determine the aquifer properties. The mineralogy of the
sediments were studied using X-ray diffraction, and geochemical water analyses
were done to explain the distribution of inorganic parameters and to support
the hydrogeologlc evaluation.
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Physiographical1y, the site is located on the Snake River Plain that
extends from Asotin, Idaho to Ontario, Oregon. The site's elevation varies
from 2525 to 2635 feet above mean sea level and is 250 feet above the Snake
River flood plain. The Owyhee Mountains are 25 miles to the south of the
site, and the Snake River is approximately 2.5 miles east and north of the
site. Castle Creek is a perennial stream about one mile west of the site, and
Cloud Burst Wash is an intermittent stream about two miles east of the site.
The Snake River Plain is underlain by 5000 feet of sedimentary and
interspersed basaltic flows over a basement complex of silicic volcanics. The
sedimentary deposits are assigned to the Idaho Group of Miocene to Pleistocene
age. Figure 6 represents the generalized stratigraphic column for the area.
The Idaho Group was deposited under three distinct episodes of lava damming of
the ancestral Snake River. These episodes resulted in the formation of large
lakes across the region. Lacustrine deposits predominate and form the most
contiguous sedimentary beds. The Snake River Basalts are regionally the
youngest formation but are absent from the vicinity of ESII-B.
ESII-B and the Snake River are located in a down-faulted block bounded
by normal faulting. The dip of the sedimentary units is gentle to the
northeast at about two to four degrees. Faulting has been observed on a
regional scale 1n the Idaho Group, but has not been observed locally near
ESII-B.
The Bruneau and Glenns Ferry Formations of the Idaho Group are of prime
importance in the characterization of ESII-B. The Bruneau Formation comprises
the surficia) sediments of the ESII-B site to a depth of up to 110 feet. The
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Figure 6.
AGE
.FORMATION
PLEISTOCENE
PLIOCENE
MIOCENE
SNAKE RIVER BASALT
8RUNEAU FORMATION
QLENNS FERRY FORMATION
CHALK HILLS FORMATION
BANBURY BASALT
POISOK CREEK FORMATION
IOAVADA VOLCANICS
O
(X
<3
O
X
Q
aiso«fl.co
STRATIGRAPHY OF THE WESTERN
SNAKE RIVER PLAIN
(MODIFIED AFTER MALDE AND POWERS, 1962)
f»;r
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50
Glenns Ferry Formation contains the two aquifers that are monitored at the
facility. The deeper formations of the Idaho Group contain the regional,
deep, artesian aquifers at depths of 2000 to 3000 feet. The artesian head in
the regional aquifer is usually above the ground surface throughout the area.
One well (not part of the monitoring network), which previously existed at the
facility, tapped the regional aquifer. The well had a head 160 feet above the
ground surface or about 300 feet higher than the potentiometric surface in the
shallower aquifers in the Glenns Ferry Formation. That well was permanently
sealed in March 1986.
The Bruneau Formation is an unconsolidated lake deposit made up of deep
and shallow facies. Only the near-shore beach facies of rounded pebbles and
cobbles with coarse sand are present at the site. These coarse sediments vary
from zero to about 110 feet thick, but in general are about 50 feet thick over
most of the site.
The Glenns Ferry Formation occurs below the Bruneau Formation and is
about 1550 feet thick at the site. The formation is made up of lacustrine,
fluvial, and flood-plain depositional facies. The upper fluvial sequence
contains many thick-bedded fine sands and silts containing a few clay seams.
These sediments are representative of lake-margin environments. This section
persists to approximately 130 feet in the center of the site. The bottom
contact of the fluvial facies overlies the lacustrine facies.
The lacustrine facies consists of thick-bedded clays and silts with
minor beds and lamina of sand and silt-sand. The sequence expresses cyclic
sedimentation with depth. This sequential, cyclic appearance reflects the
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51
changes in deposition as the lake levels rose and fell. The first sequence of
near-shore deposits underlying the fluvial fades occurs at approximately 160
feet. In the northwest portion of the site, the sequence contains numerous
thin beds and lamina of silty sand separated by thin to thick bedded silts and
clays. These sand beds appear to pinch and thin toward the south and east.
Although a continuous zone of thin beds exists across the site, individual
sand beds appear to be discontinuous. It is this zone of thin, discontinuous
and laterally variable sand and silts that represents the upper aquifer.
The near-shore facies grades vertically downward into a deep lake
deposit of thickly oedded, plastic clay. This clay unit, which is 20 to 30
feet thick and extends to a depth of 230 feet, is the confining bed separating
the upper and lower aquifers. The clay unit grades vertically into another
near-shore deposi't of thick-bedded silt and thin-bedded clay containing
thin-bedded sand and sand lamina.
The lower, near-shore sequence is the lower aquifer, extending to a
depth of approximately 250 feet. This unit grades vertically into another
off-shore facies that provides the basal confinement of the lower aquifer.
Deep drilling activities on and near the site indicate strata below the lower
aquifer to be predominantly blue clay and shale to at least 1770 feet.
As noted above, two water-bearing zones have been identified within the
Glenns Ferry Formation. These two zones have been denoted as the upper and
lower aquifers, illustrated in Figure 7 in diagrammatic cross-section. The
upper aquifer consists of three to eight cumulative feet of thinly bedded sand
within 80 to 90 feet of silt and clay. As a result of the northeasterly dip
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52
of the strata, the upper aquifer gradually emerges above the potentlometric
surface about half-way between the north and south ends of the facility.
Individual sand seams above the zone of saturation along the southern limits
of the aquifer intercept the potentiometric surface and become saturated along
the northern side of the site. The potentlometric surface of the upper
aquifer, shown in Figure 8, varies from 140 to about 200 feet below ground
level. The ground water flow directions in the upper aquifer are generally
west to east. Highest well yields occur in the northwest corner of the site,
with decreasing well yields to the east and south.
The lower aquifer is saturated beneath the entire site. It consists of
up to four feet of cumulative sand within 30 to 40 feet of bedded silts and
clays. Figure 9 shows the potentiometric surface in the lower aquifer. The
ground water flow direction in the lower aquifer is to the northeast. Well
yields in the lower aquifer are less than one gallon per minute.
The upper and lower aquifers are separated by 20 to 30 feet of deep
water fades clay. Three lines of evidence lead to the conclusion that the
upper and lower aquifers are not interconnected: (1) the intervening clay beds
are only partially saturated; (2) the two aquifers have different flow
directions; and (3) there are significant differences in water chemistry
between the two aquifers, as illustrated in Figure 10.
Table 4, taken from ESII-B's permit application, contains the principal
hydraulic properties for the upper and lower aquifers that were used to
determine the velocity of the ground water. The value given in the last
column is ESII-B's calculated velocity of ground water in the sand seams and
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«*M\ /\ /\
LOWER AQUIFER
C! -t- NO3
ANIONS
PERCENT OF TOTAL MILLIEQUIVALENTS
PER LITER
Figure 10
A Demonstration of the Geochemical
Differences between the Upper and Lower
Aquifers (Piper Diagram)
B18066 CO
ESII SITE 3
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beds within each aquifer. According to those calculations, which include an
assumed value for porosity of 0.43, the velocities in the upper aquifer range
from 12 to 82 feet per year, while the lower aquifer velocities range from
less than two to 13 feet per year.
Recharge to the regional aquifer is at the Owyhee Mountains, 25 miles
south of the site. The two shallow aquifers appear to be recharged by local
sources. The probable source of both aquifers is Castle Creek to the west of
the site and local areas of irrigation northwest of the site. Limited age
dating of the shallow ground water has suggested that the ground water is more
than 45 years old. This age is consistent with the time that would be
required to move ground water from Castle Creek to the site, estimated to be
from at least 64 years up to 2640 years, given the range of ground-water
velocities (Table 3).
The data taken together present a picture of low to very low yielding
aquifers that occur along a limited number of sand stringers over an 80 to 90
foot section for the upper aquifer and a 30 to 40 foot section for the lower
aquifer. Because of the high upward gradient between the deep regional
aquifer and the relatively shallow upper two aquifers, there is limited
potential for migration of contaminants from the site into the regional
aquifer. Because of the apparent lack of interconnection between the first
and second aquifers, the ground water flow in these aquifers must be parallel
to the bedding. The best means for monitoring the ground water, given this
hydrogeologic scheme, is in the upper aquifer down-gradient of hazardous waste
management units, in the second aquifer where the upper aquifer is not
present, and in both aquifers at or near the estimated zone of transition
where the upper aquifer becomes unsaturated.
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GROUND HATER FLOH DIRECTIONS AND RATES
Water table contour maps for the upper aquifer and the lower aquifer
were submitted by ESII-8 in its Part 8 application and are shown in Figures 4
and 5. These maps are based on water level data obtained in November and
December 1985. The water level elevations obtained by the field team during
this inspection were in agreement with the general shape of the water contours
for the two aquife-s as presented by ESII-8.
In constructing its upper aquifer contour maps, ESII-8 did not include
data from three important wells, D-4, D-8, and D-10. Water level data for
SW-1-2 and SW-3-2 became available after December 1985 and were therefore not
included in the construction of the maps. In addition, ESII-B's map for the
upper aquifer includes data from wells MW-2, MW-4 and MN-15. which span the
upper and lower aquifers and which therefore should not have been included in
the data base from which the maps were constructed. Because of these
shortcomings, EPA independently contoured the water table of the upper
aquifer. The resulting maps, constructed from data representing July and
December of 1986, are shown in Figures 11 and 12, respectively.
As noted previously, It is believed that horizontal flow dominates
beneath the facility due to the thick clay layers bounding both the upper and
lower aquifers. Evidence that hydraulic separation of the upper and lower
aquifers exists was also discussed. The direction of ground-water flow can be
interpreted as being approximately orthagonal to the equipotential lines on
the ground water contour maps.
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Figure 11
Upper Aquifer Equipotential
Contour Map for July, 1986
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Figure 12
Upper Aquifer Equipotential
Contour Map for December, 1986
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55
The ground water flow directions in the lower aquifer are generally from
the southwest to the northeast, becoming more easterly toward the eastern
boundary of the facility. The hydraulic conductivity of the lower aquifer has
been measured in in-situ slug tests to range from 2.0E-5 to 2.6E-4
centimeters/second. These hydraulic conductivities, combined with the
gradients from Figure 9 (and assuming an effective porosity of 0.2), result in
ground-water velocities ranging from approximately 4 to 51 feet/year (as
compared with 2 to 13 feet/year estimated by ESII-B).
The flow directions in the upper aquifer are more variable and are
subject to some interpretation. The equipotential lines shown in Figure 8
indicate ground water entering the site In the northwest corner and emerging
along the eastern boundary of the site along smooth curves. The more
extensive data used in the July and December 1986 contour maps (Figures 11 and
12) indicate the existence of a more complex pattern of flow, internal to the
facility around the silo complex (reference wells SW-3 and D-8 on each map).
The data in this area suggest ground-water flow to the south and southeast
rather than to the east as suggested in Figure 8. Whether the ground-water
flow continues to the south is not known, because the next well to the south
is D-17, for which the observation during drilling indicated the upper aquifer
zone to be unsaturated. At this point, ground water flow in the upper aquifer
has either turned to the east or entered the clay layer separating the upper
and lower aquifers. Because of the higher hydraulic conductivity of the upper
aquifer compared with that of the clay, the majority of the flow in the upper
aquifer in this area may be assumed to be channeled parallel to the southern
boundary of the upper aquifer. The increase in gradient near D-8 suggests an
increase in velocity to move the converging ground-water flow in this area.
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56
Such an Interpretation of flow in this part of the facility would have ground
water flowing east and exiting the site near well MW-4 (Figure 3).
The hydraulic conductivity in the upper aquifer measured for slug tests
ranges from 1.5E-3 to 5.4E-5 centimeters/second. The highest values of
hydraulic conductivity were measured In the northwest corner of the site. The
hydraulic conductivity decreases toward the southern boundary of the upper
aquifer. This decrease in hydraulic conductivity also may explain the bending
of the equipotential lines toward the south in the area of the silos. If this
is the case, then it is possible that ground-water flow from the upper aquifer
continues into the intervening clay layer separating the upper and lower
aquifers, as the upper aquifer sediments take on the characteristic of the
clay (i.e., lower hydraulic conductivity).
The velocity of ground water in the upper aquifer is highly variable.
EPA has calculated velocities in certain areas of the site which are
significantly higher than those estimated by ESII-B (Table 4). The highest
rates of travel occur In the northeast portions of the site, where the
combination of high gradients, high hydraulic conductivity and an effective
porosity value estimated to be 0.20, yield effective velocities that range
from approximately 85 to 200 feet/year. Near the silos and toward the
southern edge of the upper aquifer, the velocities are calculated to range
from approximately 10.6 to 96 feet/year.
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57
POSSIBLE VERTICAL RECHARGE
Four lines of evidence suggest that there may be vertical recharge to
the upper aquifer under the ESII-B facility: (1) the distribution of the
major ions in the ground water suggests vertical recharge; (2) the greater
variability of the hydrographs in the upper aquifer suggests vertical
recharge; (3) the presence of volatile organic chemicals detected in the
monitoring wells downgradlent of the silos (if verified as representing
ground-water contamination) suggests vertical migration through the sediments
above the upper aquifer; and (4) the equlpotential lines of the upper aquifer
contour maps bend around the silo area, as discussed in the previous section.
Two geochemical models have been proposed to explain the major ion
distribution in the upper aquifer at ESII-B. The first, proposed by ESII-B,
explains the distribution of major ions by the oxidation of pyrite, releasing
Iron and sulfate with a decrease in pH. The decrease in pH dissolves
carbonate with the release of bicarbonate. The second model requires the
breakdown of gypsum 1n the sediments overlying the upper aquifer as it is
recharged vertically under the facility. The latter is favored by EPA,
because the ratios of calcium and sulfate in the upper aquifer are consistent
with those expected for the breakdown of gypsum, but not of pyrite.
The variability of the hydrographs for ground water levels is greater in
the upper aquifer than Irt the lower aquifer. Changes in water levels in the
upper aquifer at times have been nearly five feet. The variation in water
levels is attributed by ESII-B to barometric effects and to errors in
measurements. However, careful examination of the hydrographs and
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58
precipitation records reveals a correlation of high rainfall with later higher
ground water elevations. Furthermore, these same events are not observed in
the lower aquifer.
At least the first three of these four phenomena have been individually
and independently explained by ESII-B in some manner that would not require
recharge vertical'./ into the upper aquifer beneath the facility. However,
taken together, they suggest that there are areas of preferred vertical
recharge at the facility. Such areas are likely to have been caused by human
activity, such as the installation of the silos and associated structures and
former on-site waste water disposal activities which occurred when the
facility was a missile base.
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59
INTERIM STATUS GROUND WATER MONITORING PROGRAM
BACKGROUND
ESII-8 operates as an interim status land disposal facility and as such
is subject to the ground water monitoring requirements of 40 CFR Part 265
Subpart F. Prior to September 1983, ESII-B (and its previous owner, Wes-Con)
believed that the shallowest, monitorable ground water beneath the site was
contained in the regional, artesian aquifer located at more than 3000 feet
below ground surface. Based on this assumption, Wes-Con had prepared a Ground
Water Monitoring Waiver in 1981, just prior to selling the site to Envirosafe
Services. EPA found the waiver to be inadequate in a September 1983 Notice of
Deficiency, subsequent to which ESII-B instituted a drilling program to gather
more information regarding the hydrogeology of the site. Those efforts
demonstrated the presence of ground water at 182 feet beneath the ground
surface on the northern edge of the site. At this point, it was apparent that
a waiver demonstration was not feasible, and ESII-B chose to institute an
interim status ground water program which would monitor the uppermost aquifer.
ESII-B proposed a system of six perimeter wells in October 1983, which
EPA accepted as "a method of initially determining whether gross contamination
is leaving the site." EPA also stated that "additional wells may be
necessary." An administrative order issued by EPA to ESII-B on November 23,
1983, required the implementation of the proposal. The six wells (MW-1
through MW-6) were installed by the end of December 1983.
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The initial ground water sampling event was conducted in January 1984,
with EPA and IDHW obtaining split samples. A few organic hazardous
constituents at very low concentrations were detected in the samples. On
February 29, 1984, EPA issued ESII-B a Notice of Deficiency and Warning which,
among other things, required ESII-B to "continue sampling and analysis of all
existing and new wells on a monthly basis for all parameters required under 40
CFR 265 and for all priority pollutants and 40 CFR 261, Appendix VIII
constituents detected by ESII, EPA or the state of Idaho. This monthly
monitoring must be continued until permit issuance." In February 1985, after
contamination was found in the silo wells, EPA required that a specific list
of volatile organic compounds be added to the analytical parameter lists of
upper aquifer, downgradient wells.
In May 1985, ESII-8 submitted a revised site characterization/ground
water monitoring program document to EPA as part of the facility's Part 8
permit application. This document included the finding that two aquifers,
instead of one, exist beneath the site (both above the deep, regional
aquifer). Wells MW-6, an upgradient well, and MW-5 were found to be located
in the lower aquifer. An additional monitoring well (MW-15) was installed as
an upper aquifer, upgradient well.
In order to better monitor both aquifers, seven additional wells were
added to the Interim status detection monitoring network in September 1985.
One of these (MH-26) was later dropped from the network, as ESII-B claimed
that it was screened at the wrong depth. Thus in September 1985, the 14 wells
that comprise the current interim status ground water monitoring system were
in place and being sampled monthly for the groups of parameters cited above.
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In May 1986, ESII-B requested that the required frequency of sampling
and the list of required analytical parameters be decreased. EPA responded in
June 1986, with concurrence that the facility could implement quarterly,
instead of monthly, sampling, but that the parameter list must remain the same
until a new one had been developed by EPA for the facility. However, ESII-B
apparently had already made the decision to discontinue the more extensive
parameter list; as of May 1986, the facility has, by its own report, obtained
samples for only those parameters required by 40 CFR § 265.92(c), with the
following frequency: ground-water quality parameters, semi-annually;
ground-water indicator parameters, quarterly. (Wells MW-3, MW-4, MW-10 and
MW-11 are also sampled quarterly for Priority Pollutant volatile organic
compounds, as part of the silo well monitoring program.)
LOCATIONS OF HELLS
The facility instituted a detection monitoring program in which wells at
the perimeter of the site have been utilized collectively as downgradient
wells for all of the regulated units. Figure 1 shows the locations of ground
water monitoring wells at ESII-8. Wells designated by the facility as forming
the RCRA detection monitoring program (at the time of this inspection) are
listed in Table 5. Six upper aquifer and four lower aquifer wells are located
near the facility boundary to monitor downgradient of the facility (although
ESII-8 claims that only four of the six upper aquifer wells are actually
downgradient of present or past waste management areas). There are two
upgradient wells monitoring each aquifer. According to water level contour
maps, the locations of upgradient wells are appropriate.
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Ta b 1 e 5
RCRA GROUND WATER MONITORING WELLS
FOR INTERIM STATUS DETECTION MONITORING PROGRAM
ESII-B
Lower Aquifer
upgradient welIs
MW-13
MU-6
downgradient wel1s
MW-5
MW-21
MW-24
MW-25
Upper Aquifer
upgradient we!1s
MW-15
MM-16
downgradient welIs
MW-1
MW-2
MW-3
MW-4
MW-10
MW-11
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62
Units at ESII-B which are subject to interim status ground water
monitoring requirements are trenches 5, 10 and 11; and areas on-site where
disposal of hazardous waste or hazardous waste constituents occurred since
November 19, 1980 and which have not been demonstrated to have been cleaned up
such that no hazardous waste or hazardous waste constituents remain. The
history and locations of these areas are discussed earlier 1n this report in
the section on solid waste management units.
The ground-water monitoring requirements to which the facility is
subject pursuant to TSCA are met by the three PCB wells (PCB-1, -2 and -3)
immediately east of trench 5, and by certain upgradient and downgradient wells
in the RCRA monitoring network. Thus the two systems are integrated to some
extent and historically have had overlapping functions, which is the choice of
ESII-B. The three designated PCB wells are immediately downgradient of trench
5. Disposal of RCRA-regulated hazardous waste in trench 5 is authorized
pursuant to interim status, and the southern third of the trench has received
approval for disposal of PCBs. Disposal of hazardous waste has occurred in
the southern third of the trench since December 1986. Trench 5 is
double-lined and is the only land disposal unit on-site that may qualify to
receive federally-directed Superfund wastes. The facility's analytical
schedule, obtained by EPA during a facility inspection in March 1987,
indicates that the three PCB wells were to be incorporated into the RCRA
interim status monitoring well network in March 1987. Until recently, ESII-B
sampled its PCB well network monthly, analyzing for specific Aroclors,
chloride, pH, specific conductance and total organics (electronegative). It
recently received approval to sample quarterly, and to substitute total
organic halides (TOX) for total organics. The results generated for
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PCB-approval purposes historically have not been included with ESII-B's RCRA
ground water data submlttals to EPA, but have been submitted to EPA separately.
CONSTRUCTION OF HELLS
Specific information on well construction materials and techniques
delineated below is derived from ESII-B's Part 8 application, February 1986.
A summary of well construction data is provided in Table 6. Silo wells SW-1-2
and SW-3-2 (installed later) are not included. The three original silo wells
and the three PCS wells, while not included in the interim status monitoring
network, at the time of this inspection, are included in the following
discussions regarding well construction and sampling.
Most of the wells in the RCRA monitoring network were installed by air
rotary drilling methods. One well (Mk-21) was installed using hollow stem
auger and wash rotary core methods. Air rotary methods for all wells
installed prior to July 19, 1985, involved foam and water injection to aid in
the removal of cuttings. This Includes all RCRA monitoring wells except MW-16
and MW-25. Other wells Installed using this method include PCB-1, PCB-2, and
five D-serles (test) wells. A sample of the foam ("Quik Foam") reportedly was
collected for chemical aneilysis to determine if organic compounds could be
detected 1n the foam.
Dry air rotary techniques were used on wells installed after July 1985,
which include current RCRA monitoring wells MW-16 and MW-25; MW-26 (no longer
in the RCRA network); and PCB-3. Silo well 1 was constructed during the
period from July to October 1984 using a modified cable tool. Silo wells 2
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64
and 3, constructed between February and May 1985, were drilled using a
combination of air rotary and modified bucket auger methods.
For wells drilled using dry air rotary, a booster air compressor,
augmenting that of the rig, was used to clear the well of cuttings. Water and
foam injection were used to clear cuttings from the holes after the first
saturated sands were encountered.
Most of the air rotary holes were drilled with a 7-7/8-inch tricone
roller bit. Steel surface casing (8-inch ID) was oriven downward as the hole
was advanced. Wells MW-2, MW-4 and MW-6 were drilled with a 5-7/8-inch
tricone roller bit, and a 6-inch ID steel casing was driven. For all air
rotary-drilled wells, the steel casing was seated in clayey strata, 120 to 160
feet below ground level. The annulus outside of the steel casing was filled
with dry, granulated bentontte as the casing was driven. The open hole was
drilled from the bottom of the casing to the total depth of the well
borehole. The final well screen and casing were installed in the open hole
and extended up through the steel casing to the surface.
Most of the RCRA and PCS wells consist of 4-inch ID, Schedule 40 PVC
joined with threaded flush joints and 4-inch ID PVC slotted well screens. The
exception is MH-6, which Is 3-1nch ID. Screen slots are .010 inch (except
SW-1, with a slot size of .020 inch), and 16-mesh, clean mesh silica sand was
used for the filter pack. S1lo wells 1, 2 and 3 have 4-1nch ID stainless
steel screens and steel well casings. Silo well SW-1 has no filter pack.
Filter packs in the other wells range in length from 10 feet to 90 feet.
Screen lengths range from 10 feet to 40 feet. There are no multiple
-------
65
completion wells or well clusters to monitor multiple, discrete aquifer
intervals. Wells are screened at the top of the aquifers. Since the lower
aquifer is partially confined, the head rises considerably above the top of
the aquifer and the screened zone (Table 6).
The primary PVC well casing was Installed through the outer steel
casing. In most wells the steel surface casing extended down from 120 to 160
feet and was left in place. In silo wells 1, 2 and 3, the surface casing was
retracted as the primary well casing, screen, sand pack, and annular seals
were placed. The annulus between the borehole and well casing, and the well
casing and steel surface casing were sealed with dry bentonite or bentonite
and cement grout. The top 10 feet of the annulus between the PVC and the
steel casing were filled with cement grout. Above-water annular seals were
placed from the surface. Annular seals beneath the water were tremied into
place with one-inch ID steel pipe. The amount of annular fill was determined
by periodically sounding the annulus as the sea! material was being placed.
During the inspection, depths to the bottoms of 11 wells were measured,
and depths to the tops of installed, submersible pumps were measured in two
others. The measurements, and their corresponding values as reported in
ESII-B construction logs, are given in Table 7. Eight of the 11 wells were
measured to be approximately two feet greater in depth than reported. In well
D-3 (shallow), which is reported to be 225 feet deep, soil was encountered at
216 feet. Well MW-9 was Initially measured to be approximately six feet
shallower than as reported in construction diagrams. During the purging
process, ESII-B's 20-foot stainless steel bailer was accidentally released
from the truck rig, plunging into the well. After the bailer was retrieved,
-------
Table 7
DEPTHS OF WELLS MEASURED BY EPA
COMPARED WITH DEPTHS REPORTED IN ESII-B CONSTRUCTION LOGS
Well
PCB-3
SW3-2
D-ia
MW-9
MW-3
D-3 Shallow
SW-2
SW-3
PCB-2
PCB-1
D-19
MW-25
(top of pump)
MW-1 1
(top of pump)
Reported
Depth, *Ft.
190
195
215
250
219
225
200
202.5
194
191
240
273
230
Measured
Depth, Ft.
191.84
197.69
217.45
243.81
246.14**
219.37
216.00
202.76
204.76
196.62
194.36
242.90
273.00
229.44
* as reported in well construction data in ESII-B Part B permit application
** after stainless steel bailer fell into well
-------
_3
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-------
66
the well was left for more than 24 hours before the field team returned to
resume the purging activity. At that time, the depth measurement indicated
that the well had increased in depth by more than two feet.
Measurements made to the tops of two submersible pumps were virtually
the same as the corresponding depths reported in construction diagrams. For
wells which were measured to be significantly deeper in total depth than as
reported in construction logs, errors in initial measurements during drilling
are suspected. Where depths appear to have decreased, both construction
record errors and sediments moving into the casing are suspected.
Eleven of the 14 RCRA monitoring network wells and one PCS well are
equipped with permanently-installed submersible pumps. The pump in each well
is placed near the bottom of the screen. Below the screen, typically, is a
ten to 20-foot sump. The discharge line of each pump holds approximately five
gallons of water and has no check valve. The combined effect of sumps beneath
the level of the pump Intake and the lack of check valves is to make it
impossible to purge such wells dry. In its "Sampling Procedures" document
(provided during the Inspection), ESII-B claims to purge "dry" six such wells
prior to sampling, but, for these wells, "dry" perforce means only until no
additional water can be extracted, given the existing equipment. Table 8
illustrates the relative effects that water which cannot be removed from a
well is calculated to have on the volume actually evacuated from that well,
expressed as a percentage of the total casing volume. Unless the wells with
such equipment were purged "dry" several times prior to sampling (with the
necessary purge quantity dependent upon how many well volumes it is possible
to extract prior to breaking suction), one could not be certain to have
-------
67
removed the stagnant water prior to obtaining samples. ESII-B's written
sampling procedures Indicate that, following the initial purge to "dryness," a
quantity representing less than one casing volume is purged the next day
immediately before samples are obtained from these wells.
As noted above, the lack of check valves In the submersible pumps
causes the water in the discharge lines to cascade back down into the wells
when either the pumps are turned off or when suction breaks by purging to
"dryness." If the pump is still running, the water will hit the moving
impellers. In any case, the water is subject to aeration that is unacceptable
for samples that may be analyzed for volatile substances or other labile
parameters.
As documented in Table 6, extremely long filter packs exist in most of
the 14 detection monitoring system wells. The lengths of effective filter
packs, that is, the length that is calculated to be saturated at each well,
ranges from 12 feet in MW-16 to 98 feet in MW-2. Eight of the wells have
effective filter packs greater than 45 feet in length. Filter packs serve to
Increase the effective screen lengths of the wells. In at least three upper
aquifer wells, MW-2, MW-4 and MW-15. the combination of the screen and filter
pack lengths cause the wells to effectively bridge the two aquifers. Such an
interconnection is not acceptable for two reasons: (1) water table
measurements are not valid, since they reflect influences from more than one
aquifer; and (2) should contamination occur in one aquifer, the
interconnection caused by the filter packs could cause the otherwise
unaffected aquifer to become contaminated. For that reason, ESII-B should
take steps to appropriately abandon or rehabilitate such wells as soon as
-------
68
practicable. Water level information obtained from these wells should not be
utilized in constructing water contour maps. Replacement wells should be
installed where necessary to maintain an adequate detection monitoring program.
Another effect of a filter pack which is much longer than the well
screen, is to greatly increase the amount of stagnant water that must be
removed from wells prior to sampling, to ensure that fresh formation water is
being sampled. This is true unless a well is purged virtually dry, in which
case formation water should enter the well casing at once. However, as
discussed above, ESII-B is not generally able to accomplish this, either due
to well yields, well design or the nature of the equipment in the wells. The
quantities of water which exist in the filter packs of the interim status
wells, the PCS wells and four silo wells have been calculated and are
presented in Table 9. (Volumes residing in filter packs were estimated
assuming a porosity of 0.20.) The calculated, total volume of the casing plus
the filter pack is shown for each well, along with the number of casing
volumes and the number of effective volumes (i.e., filter pack plus casing)
which are purged by ESII-B prior to obtaining samples from each well (obtained
from ESII-B's "Sampling Procedures" document).
Wells MW-6 and MH-4 are bailed dry prior to obtaining samples. Wells
which are balled to dryness do not have the problem of inaccessible water
remaining in the well casing as do wells with permanently installed
submersible pumps. For these wells, samples could properly be obtained as
soon as possible subsequent to bailing dry, regardless of the number of
volumes purged. Wells MW-5, MW-11, MW-13, MW-16, MW-21, and MW-24 have
submersible pumps and are bailed as dry as is possible, given the presence of
-------
69
the equipment. The balance of the wells, including PCS and silo wells, are
continuously purged (bailed or pumped) and then sampled. It is apparent from
Table 9 that insufficient volumes of water are being removed from many wells
prior to sampling, even when filter packs are not considered. When the impact
of the filter packs is taken into consideration, the calculations indicate
that, in some wells (aside from those bailed to virtual dryness), not even a
full volume of water is removed prior to sampling.
ESII-B SAMPLE COLLECTION PROCEDURES
Field Activi ties
As requested prior to the inspection, ESII-B had arranged for its
contractors to conduct "mock" purging and sampling activities at two wells.
EPA had requested to observe an example of these activities at a bailed well
and at a pumped well. ESII-B chose wells PCB-2 and MW-1 as the demonstration
wells. The purging and sampling procedures which were observed were generally
acceptable; however, in hindsight, it was determined that this was not an
adequate way to evaluate the practices that would be involved in an actual
purging and sampling event. This is due in part to the fact that essentially
every well in the monitoring network is unique, given the variety of equipment
used for purging and sampling and the wide range of yields of the wells, even
within aquifers. These factors force decisions at each well as to purge
rates, purge volumes and extent of recovery periods prior to sample
collection. In addition, 14 wells (or more if PCB wells and silo wells are
sampled during the same event) must be purged and sampled according to a
timetable, during an actual sampling event. All of these variables
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contributed to the conclusion that the two-well mock sampling event was
insufficient for the type of evaluation needed. Therefore, an assessment of
this portion of ESII-8's ground water monitoring effort has been deferred
until September 1987, when a routine comprehensive ground water monitoring
evaluation will be conducted by EPA and IDHW, during which ESII-8's ground
water sampling team will be observed during a scheduled sampling event, and
split samples will be obtained.
Records Review
During the inspection, two documents were provided by ESII-B pertaining
to its interim status ground water monitoring program. One is entitled
"Interim Status Groundwater Monitoring Program for the Hazardous Waste
Management Facility Located 10 Miles West of Grand View, Idaho (Site B)
Operated by Envirosafe Services of Idaho, Inc. Boise, Idaho IDD073J14655.
June, 1986." A November 1985 version of this document had been obtained from
ESII-8 prior to the inspection. The 1986 document includes a description of
the site hydrogeologlc characterization efforts and the history of ground
water monitoring events; well locations and specifications; sampling and
analysis plan; ground water quality assessment outline; and sections on
statistical analyses, reassessment of monitoring well locations, and
recordkeeplng and reporting. The second document is "Sampling Procedures,
ESII Site B, RCRA, TSCA, and Silo Test Wells," dated June 1986. This
document, which apparently was prepared by and for ESII-B's ground water
sampling contractors, describes the routine that is to be followed for the
interim status, silo and PCS wells during a sampling event. It specifies such
things as the order in which wells are to be purged and sampled; the volumes
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to be purged; the number of times to which each well is returned for purging
prior to sample collection; the rate at which water should be pumped during
purging at wells with submersible pumps; how long a well is to be left to
recover prior to further purging and/or sampling (specified as either later
during the same day or the next day, for wells which are not sampled directly
after an initial purge); the location of the water level measuring point on
each well head; and the level of personal safety protection required at each
well location. It also describes sampling techniques that are to be followed,
and includes a copy of a letter to ETC, the testing laboratory utilized by
ESII-B, delineating the analytical testing schedule from May through December
1986.
These two documents make it possible to evaluate the technical adequacy
and the appropriateness of ESII-B's sampling collection procedures as they
relate to the facility's regulatory obligations pursuant to the interim status
ground water monitoring requirements. As silo wells and PCB wells are
included in the documents, they are also included in this evaluation.
As demonstrated previously in the section on well construction, the
extensive filter packs 1n most of ESII-B's wells have the effect of increasing
the amount of water that should be purged prior to sampling for all wells
except those which are balled to dryness. Because of the sumps beneath the
pump intakes and the lack of check valves, the wells which have submersible
pumps installed cannot be purged to dryness. An evaluation of ESII-B's
purging and sampling routines, as found in the sampling procedures document,
best can be made by categorizing the types of wells and equipment as follows:
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(1) Wells which are purged dry prior to sampling:
According to ESII-B's sampling procedures document, two wells, MW-4
and MW-6, are balled dry during purging. The casing volume of MW-4 is
approximately 13 gallons. The procedures provided for purging this well
are to bail to dryness, approximately 17 gallons; return later the next
day, bail three more gallons and then collect samples. For MW-6, the
casing volume of which is approximately 12.5 gallons, the instructions
are to purge the well 15 gallons to dryness; return later the same day,
purge five additional gallons and then sample.
The preferable method for purging any well is to continuously purge
a sufficient volume (at least three volumes including filter pack.) and
then immediately collect samples. Purging to dryness is less preferable
due to the aeration of the water which occurs when the water level is
drawn below the top of the screen. However, wells located in certain
formations may not yield volumes sufficient to accomplish this, even
when purged very slowly. In such a case, the appropriate procedure
would be to purge to dryness; then wait only until the well has
recovered sufficiently to collect at least part of the required sample
volume, obtaining samples for labile parameters such as volatiles and pH
as soon as possible. If necessary, the well may be left to recover
further, after the initial samples have been obtained. However, the
well should not be purged further prior to sampling once it has been
purged dry, unless it is again purged to dryness. The benefit derived
from purging a few additional gallons from a well already purged to
dryness is outweighed by the aeration of the water in the casing which
would be created by the additional bailing action.
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(2) Wells with submersible pumps which are purged until no additional
water enters the pump intake (I.e., when pump suction breaks), but which
cannot be purged to virtual dryness due to the nature of the equipment
in the wel1s:
These wells were described in the section on well construction and
are summarized In Table 8. They are MW-5, MW-13, MW-24, MW-21 and
MW-11. While the purging Instructions for these wells vary somewhat,
each 1s purged until suction breaks, is allowed to recover until later
in the day or until the next day, at which time It is purged of a
specific amount of additional water, and then is sampled. It would be
difficult to ascertain what a sufficient purge volume would be for wells
which retain a significant portion of their casing volumes at a point
where no further water can be removed from them. Such a judgment is
made more difficult by the existence of the submersible pumps lacking
check valves, which cause the aeration of significant volumes of water
that cascade back into the well when suction is broken or the
submersible pump turned off.
Given the relatively small volumes that ESII-8 purges from these
wells prior to sampling (Table 9), it is unlikely that the samples
obtained represent close to 100% fresh formation water. In addition to
the drawbacks inherent in this sampling scheme, the discharge outlets
from submersible pumps serve as a poor method for obtaining ground-water
samples, especially those for analysis of volatile compounds, pH, or
other parameters which might be affected by aeration or heat. High
flow-rates delivered by submersible pumps cause turbulence and aeration
in the water; throttling back the flow in an attempt to control this may
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cause the water to gain heat (ESII-8's sampling instructions do not
address the flow rate to be used while obtaining samples). For these
reasons, it is recommended that the submersible pumps be removed from
these wells and that they be bailed for both purging and sampling
purposes. A continuous purge-to-sample routine would be preferable, but
if yields in these wells prohibit this, they should be balled to virtual
dryness prior to sampling.
(3) Wells which are purged and then sampled with no intervening time:
This category includes wells which have submersible pumps installed
(MH-15, MN-16, MW-1, MW-3, MW-25, MW-10, and PCB-3); wells which have
bladder-type pumps Installed (SW-1, SW-2, and SW-3); and wells which are,
bailed for both purging and sampling (MW-2, PCB-1 and SW-3-2). In all
of these wells, it is necessary to consider the effective volume of the
filter packs in determining the appropriate amount of water to be purged
prior to sample collection. It is apparent from Table 9 that none of
these wells is purged sufficiently. It is recommended that ESII-B
increase the quantity of water purged from these wells so that at least
three volumes (casing plus filter pack) are removed prior to sampling.
In addition, since obtaining samples using a submersible pump is not
acceptable for the reasons specified in (2), above, ESII-B should either
find another means for both purging and sampling such wells, or continue
to use a submersible pump for purging, but remove it prior to obtaining
samples with a bailer. Bladder-type pumps and bailers (made of
relatively Inert materials) are acceptable for both purging and sampling.
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SAMPLING AND ANALYSIS PLAN
The sampling and analysis plan is contained within the interim status
ground water monitoring document, cited above, which is a lengthy document
that covers virtually all aspects of the ground water monitoring program.
Sample collection, sample preservation and handling, cha1n-of-custody,
analytical procedures and quality assurance and quality control measures are
appropriately presented. EPA-approved analytical methods are cited for ground
water sample analyses.
It is impossible to determine from the sampling and analysis plan the
schedule for analytical parameters that are to be obtained during particular
sampling events, since the regulatory requirements for first-year samples and
subsequent-year samples are simply cited from the regulations, without
identifying which wells fall into which category. However, a copy of a letter
from Envirosafe Services, Inc. to the testing laboratory, delineates the
analytical needs for samples from specific wells for May through December
1986. This letter is included in the sampling procedures document prepared by
ESII-B's sampling contractor, dated June 1986.
OUTLINE OF GROUND MATER QUALITY ASSESSMENT PROGRAM
Pursuant to 40 CFR § 265.93(a), the owner/operator must prepare an
outline of a ground-water quality assessment program that describes a
ground-water monitoring program that is more comprehensive than its detection
monitoring system and which is capable of determining:
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(1) Whether hazardous waste or hazardous waste constituents have
entered the ground water;
(2) The rate and extent of migration of hazardous waste or
hazardous waste constituents 1n the ground water; and
(3) The concentrations of hazardous waste or hazardous waste
constituents In the ground water.
ESII-B's outline of such a program is quite brief and vague. The
introduction to the assessment outline states that the "outline will be
expanded into a plan" if dictated by ground-water quality. All items
discussed In the Outline need clarification and qualification. Specifics may
be limited in such an outline, but some should be included. The following
deficiencies are noted in the assessment outline:
The outline states that for the determination of the identity of
hazardous waste or hazardous waste constituents that have been released
to ground water, samples would be obtained for the parameters required
in 40 CFR §§ 265.92(b)(1), (2) and (3); and other parameters "specified
by the Regional Administrator." A method that ESII-8 would follow to
determine appropriate analytical parameters should be included. A time
frame and frequency for sampling and analysis are not specified, but
should be. The outline should also state if analytical results would be
submitted to regulatory authorities and if so, the time frame for
reporting.
The outline should specify if initial sampling activities would include
all interim status monitoring wells, other wells, or how well selection
would otherwise occu-.
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The outline states that the determination of the rate and extent of
migration of hazardous waste or hazardous waste constituents in the
ground water would entail the following:
(1) Documentation of aquifer characteristics based on exisiting
site-specific and published data;
(2) Sample and analysis of "supplemental wells in the vicinity of
site;"
(3) Drilling, sampling and analysis of "additional wells as
needed."
It is not specified or explained what site-specific data would be
available to be used in the assessment or what published data would be
used as a source of information. It is also not stated what "in the
vicinity" refers to in terms of wells, e.g., if they are private or
public wells, where they may be located, or whether they have already
been identified.
The outline states that to determine the concentrations of hazardous
waste or hazardous waste constituents in the ground water, water-quality
data developed as a result of the activities described above will be
"evaluated." The outline should make reference to a time frame for such
a determination and describe what protocols would be used to evaluate
the data. It should also state whether reports would be submitted to
the regulatory authorities and if so, the time frame for submittals.
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STATISTICAL ANALYSES
Records regarding the statistical analyses of ground-water data were
requested and provided during the inspection. ESII-8's interim status ground
water monitoring program document (June 1986) contains a section on
statistics. Also supplied was evidence of limited statistical tests of
ESII-B's ground-water data, performed and submitted to ESII-B by a statistical
consultant.
In the documents provided, ESII-8 states that, when sufficient data are
available, the Student's t-test and covariate analysis will be used to analyze
ground-water data. According to 40 CFR § 265.93(b), only the t-test is an
acceptable statistical method that an interim status facility may employ to
determine whether it should remain in a detection monitoring mode. Limited
results of covariate analyses conducted by the facility's statistician were
presented. T-tests apparently had not been conducted to compare data from
individual downgradient wells with background values. The results of the
analyses of covariance for Indicator parameter values in the upper aquifer and
the lower aquifer, pertaining only to the January 1986 sampling event, were
presented. It Is stated that no statistical "hits" were found. No other
evidence that statistical analyses had been performed was presented. In March
1987, ESII-B confirmed to EPA during a site inspection that no t-tests had
been performed on ground-water data, because "a year's worth of background
data was not available until the end of 1986." Statistical evaluations are
reportedly planned for 1987.
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Despite the absence of a year's worth of data for an upgradient, upper
aquifer well, ample data has been available for some time for ESII-B to
perform t-tests on the indicator parameter data from its interim status
wells. ESII-B was put into an accelerated (monthly) and expanded ground water
sampling schedule in 1984, because the site was behind in providing the ground
water monitoring information that exisiting facilities subject to RCRA were
required to have generated by November 1983; I.e., at least one year of
quarterly upgradient and downgradient data, including indicator parameters.
Information sufficient to conduct statistical analyses was not available in a
timely manner at ESII-B due to (1) the initial belief that a waiver from
ground water monitoring requirements would be feasible at this site (prior to
the discovery that water-bearing zones existed above the deep, regional
aquifer); and (2) the placement of the sole background well in an aquifer
other than the one monitored by the majority of the downgradient wells (prior
to the realization that two aquifers existed and must be monitored).
The fact that ESII-B had a technically inadequate detection monitoring
system in place until September 1985, should not be considered by the facility
as a basis to postpone determining whether statistically significant
indications of ground-water contamination exist at the site. It is
recommended that the statistics required by the interim status regulations be
performed by ESII-B and that the results be presented to EPA and IDHW as soon
as feasible.
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RECORDKEEPING AND REPORTING
In its interim status ground water monitoring program document (June
1986), ESII-8 explains how it will comply with the record-keeping and
reporting requirements regarding ground water, as required by 40 CFR
§ 265.94. The document basically reiterates the regulations as written,
except for the reporting requirements specified at § 265.94(a)(2)(iii). That
section requires the owner/operator to submit to the Regional Administrator
annually, no later than March 1 of the following year, results of the
evaluations of ground-water surface elevations made pursuant to § 265.93(f),
and a description of the response to that evaluation, where applicable.
ESII-B's plan states that such information will be submitted to the Regional
Administrator "as part of the annual report required under 265.75." However,
§ 265.75 requires the submlttal of a biennial, not an annual, report.
ESII-B's plan also states that it will comply with- § 265.94(a)(2)(ii), which
requires that the owner/operator annually submit the following information to
the Regional Administrator no later than March 1 following each calendar
year: concentrations or values of the parameters listed in § 265.92(b)(3)
(indicator parameters) for each ground-water monitoring well, along with the
statistical evaluations required by § 265.93(b) for such parameters.
EPA records Indicate that routine submittals from ESII-B to the Regional
Administrator of Interim status ground water monitoring data or statistical
analyses have not been made. On one occasion, a submittal of ESII-B's
analytical data and ground water elevation measurements was made to the
Regional Administrator, for ground water monitoring data collected from
January through June 1984. This document, dated August 16, 1984, included a
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statement that its submittal was intended to comply with interim status
recordkeeping and reporting requirements. In general, however, analytical
ground water monitoring data have been submitted by ESII-B as part of its Part
B application submittals. Laboratory data from 1986 sampling events had to be
specifically requested from ESII-B in mid-March 1987 In order to be evaluated
for this report, as it had not been submitted. No statistical analyses were
provided when that data was subsequently provided.
The facility should follow its written plan, where it is consistent with
regulatory requirements, for routine submittals of required information. The
reference to data being submitted with an annual report should be deleted, and
the facility should not tie its obligations to submit specific interim status
ground water monitoring data to submittals required under other provisions;
although it is certainly acceptable to submit information at the same time.
CONCLUSIONS
Considering the plethora of past and present land disposal activities at
the ESII-B site, the present monitoring network is thought to afford a fairly
high degree of assurance of protection of ground water, in that contamination
migrating from any point of origin on the site would likely have a discernible
effect on the ground water quality in one or more of the monitoring wells in
the interim status network. For this potential to be realized, however, it is
necessary to be able to place more confidence in the integrity of the
analytical samples collected from the wells.
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Because trench 11 1s virtually aligned with the flow lines of the upper
aquifer, it likely would be necessary to install wells within the disposal
trench in order to create a system that offers better monitoring
characteristics for contamination that may be released from the unit. Since
installing wells within the trench would not be environmentally sound,
monitoring the eastern edge of it along the flow lines 1s an acceptable
alternative, and one which should assure that contamination released from the
trench would be detected prior to migrating off-site. This explicitly
depends, of course, on the degree to which flow lines have been correctly
drawn; for this reason, it is imperative that ESII-B maintain wells and/or
piezometers which may not be in the monitoring network but which can provide
valuable water table elevation data on a regular basis.
The three PCB wells should provide adequate coverage immediately
downgradient of trench 5. During the next ground water monitoring inspection,
it will be verified formally whether they were incorporated into the interim
status ground water monitoring network since the trench began receiving RCRA
hazardous waste In December 1986.
Since ESII-B is proposing to install new wells for its detection
monitoring system for purposes of a final RCRA permit (discussed later in this
report), It Is not deemed necessary for the interim status network to be
independently upgraded by the installation of new wells, for the purpose of
improving on the construction of current wells. Nevertheless, there are
several steps ESII-B should take at once to improve its interim status ground
water monitoring system and to secure more reliable ground water samples:
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(1) Well D-19, which is located in the upper aquifer approximately
downgradient of trench 10, should be incorporated into the interim
status ground water monitoring network to provide an immediate detection
well for that trench, which is a regulated unit despite the fact that it
no longer receives waste.
(2) Wells with screens or filter packs which span the two aquifers
monitored beneath the facility should be appropriately abandoned or
rehabilitated, and replaced where necessary to maintain an adequate
detection monitoring network. All other wells, regardless of whether
they are included in the interim status network, should be maintained
for purposes of obtaining periodic water level data and updating water
table contour maps accordingly.
(3) Submersible pumps should not be used for obtaining ground water
samples. If they are used for purging, check valves must be installed.
(4) All wells should be purged of at least three volumes of water,
including that calculated to reside in the filter pack, immediately
prior to sampling. Wells with yields that are so low that this cannot
be accomplished, should be purged to virtual dryness and then sampled
for labile parameters as soon as the well has recovered sufficiently to
obtain the required sample volumes.
(5) Student's t-tests can and should be performed for indicator
parameter data generated from ESII-B's interim status monitoring wells.
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(6) Ground water monitoring data generated from the interim status well
network, water level measurement data and evaluations, and
demonstrations of required statistical analyses should be submitted
annually to the Regional Administrator, as required by 40 CFR
§ 265.94(a).
(7) The scope of ESII-B's ground water quality assessment outline
should be broadened, to reflect more specifically what a ground water
assessment plan would entail.
(3) The three PCS wells (PCB-1, PCB-2 and PCB-3) downgradient of
trench 5 should be verified formally as having been brought into the
RCRA interim status network, since the unit reportedly receives
RCRA-regulated hazardous waste (including Superfund wastes) in addition
to PCS wastes.
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GROUND WATER MONITORING OF SILOS
As described previously in this report, the ESII-B site was used in the
early 1960s as a Titan missile base. Massive concrete structures were
constructed within huge excavations, each of which extended to 160 feet in
depth at the locations of the three missile silos. Tunnels were installed
between silos at a depth of approximately 60 feet. Other underground
structures were constructed at various locations on the site at approximately
the same depth. Upon completion of the construction of each silo and its
underground support facilities, the excavations were backfilled with soil to
original grade. Each of the silos and many of the associated structures were
used for the disposal of hazardous and PCB wastes after the site ceased being
utilized as a missile base. Subsequent drilling activities at the site have
identified a variety of hazardous constituents in the soil at a depth of
approximately 60 feet in the vicinity of these structures.
EPA and ESII-B entered into an Agreed Order on November 23, 1983,
requiring an investigation of soils and ground water contamination in the area
of the silos. Pursuant to that order, a plan was implemented for sampling and
analysis of ground water downgradient of each of the three silos, and for
determining whether hazardous waste or hazardous constituents had leaked or
were leaking from the silos and ancillary underground structures. ESII-B's
subsequent sampling and analysis efforts at or near the silos detected
contamination in both ground water and soils, as shown in Table 10.
On October 31, 1985, EPA issued a RCRA section 3008(h) order to ESII-B,
addressing remedial measures to be taken in the silo areas where contamination
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Taole 10. Ground Water ana Soil Contamination
Reported in tne Area of tne Silos
SILO 1
SOIL
Sampling dates: 7/31/84 - 10/15/84
Deptn
56-58 ft.
(unsaturated)
192-193 ft.
Constituent
Concentration, ppo
chloroform 166,OOU
2-cnloropnenol 137,000
2,4-dicnlorophenol 993,000
2,4,5-tricnloropnenol 1,010,000
1 ,2,4-tricnlorooeruene 80,000
caroon tetracnloride 115
cnlorooenzene 115
cnlorofonn 143
metnyl bromide 862
metnylene cnloride 201
Sampling date: 6/28/85
GROUND WATER
Constituent
caroon tetracnloride
chloroform
metnyl chloride
metnylene cnloride
Concentration, ppo
15.3
86.9
54.5
38.8
SILO 2
Sampling dates:
Deptn
SOIL
2/24/85 to 3/14/85
Constituent
62.5- 63.5 ft.
(unsaturated)
179.5 ft.
chloroform
metnylene cnlonae
chloroform
metnylene cnloride
Concentration, ppo
32
46
26
109
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Taole 10, cont.
SILO I jcont.)
GROUND WATER
Samphny date: 4/29/85
Constituent Concentration, ppb
cnloroform 108.4
methylene cnlonde 35.0
metnyl chloride 107.1
caroon tetracnlonae 4.5
trichloroetnylene 3.6
Sampling date: 5/28/85
cnloroform 3.4
metnylene chloride 21.4
SILO 3
SOIL
sampling dates: 4/25/85 to 5/22/85
Deptn Constituent Concentration, ppo
6U-65 ft. methylene chloride 5,000
(unsaturatea) cnloromethdne 28,209
tetracnloroetnylene 6,657
chlorooenzene 39,487
PCB (aroclor 1260) 27.00U
2,4,o tricnloropnenol 20.U19
2,4 dicnloropnenol 27,102
202 ft. cnloroform 18
methylene cnlonde 347
GROUND WATER
Sampliny date: 6/28/85
Constituent Concentration, ppD
cnloroform 293
metnyl cnloriae 27.3
methylene cnloride 118
tricnloroetnylene 3.8
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had been discovered. In response, ESII-8 submitted a remedial investigation
work plan in April 1986, and as part of that plan initiated a silo well data
assessment program to evaluate the presence of the contamination. The
assessment program was designed to determine If hazardous constituents might
be present in the upper aquifer as a result of a release from the silos or if
contaminants were present due to other causes.
The results of the silo well data assessment program were submitted by
ESII-B in December 1986. Included in the program report are explanations of
how activities such as well drilling, well construction, well development,
sampling errors and/or analytical procedures could have been responsible for
the appearance of hazardous constituents in ground water samples from the silo
wells, as opposed to an actual release from the silo complex.
As part of the assessment program, silo wells SW-1, SW-2 and SW-3 were
continuously pumped and intermittently sampled for a period of 15 days,
immediately prior to this inspection. This was done, in part, in an attempt
to flush clean the Intake portion of the wells including the screens, filter
pack materials, void areas and collapsed formation materials immediately
outside the well screen, which could have been contaminated by previous well
drilling and/or Installation procedures.
A synopsis of analytical results of ground water samples for carbon
tetrachloride, chloroform, methyl chloride, and trichloroethylene from wells
SW-1, SW-2, SW-3, SW-3-2, MW-3, MW-4, MW-10, MW-11, PCB-1, PCB-2, PCB-3 and
various field and trip blanks was recently submitted by Envirosafe Services,
Inc. These data cover sampling dates from December 1984 through December 1986
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and are presented, as received from the company, in Appendix D.
Concentrations of the four hazardous constituents in the silo wells decreased
to near or below detection limits after the pumping activities of June 1986.
ESII-B has suggested that the volatile organic chemicals that have been
found in the ground water downgradient of the silos may have been the result
of drag-down of contamination from soil at higher levels into the upper
aquifer during well-drilling activities. However, as demonstrated in Table
10, not all of the constituents found in the ground water were also found in
•
the unsaturated soil at each respective silo. For example, carbon
tetrachlorlde, methyl chloride and methylene chloride were found in the ground
water at silo 1 but not in unsaturated soil samples at depths of 56-58 feet;
methyl chloride, carbon tetrachloride and trichloroethylene were found in
ground water at silo 2 but not in unsaturated soils at depths of 62.5-63.5
feet; and methyl chloride, trichloroethylene and chloroform were found in
ground water at silo 3 but not in unsaturated soils at depths of 60-65 feet.
EPA does not believe that the silo well data assessment program
adequately demonstrated that no release has occurred from the silo complex.
The nature of ESII-B's 15-day pump test, conducted in a low-yielding aquifer,
could have caused a masking of the contamination due to dilution by ground
water drawn from other parts of the aquifer. The data which were presented do
not eliminate the possibility that the volatile organics which have been
detected are due to leakage from the silo complex and that such contamination
has migrated vertically through the sediments to ground water. If ESII-B's
assessment that a release has not occurred is correct, the ground-water
contamination will not return over time. Therefore, sampling and analysis of
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the silo wells and selected RCRA Interim status wells for volatile organic
compounds is being required on a quarterly basis. Should new evidence confirm
that hazardous constituents have been released to ground water, EPA would seek
an accelerated investigation to fully characterize the nature and extent of
the contamination, in order to facilitate any remedial action determined to be
necessary.
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PROPOSED GROUND WATER MONITORING PROGRAM
In addition to existing regulated land disposal units, ESII-B has
proposed new surface impoundments and a new trench, shown on Figure 13, as
part of its Part B permit application. Other land disposal units may be
proposed for a later permit determination. As part of its application, ESII-B
has proposed a ground water detection program to monitor regulated units that
have received hazardous waste subsequent to November 19, 1980, or which will
receive hazardous waste if approved in the permit determination. The proposed
program is supplemented by three wells to monitor the silos, which are
pre-RCRA solid waste management units.
In addition to earlier proposals made as part of its Part B permit
application, ESII-B submitted revised proposals for a ground water monitoring
program in December 1986 and April 1987. Several discussions between EPA and
Envirosafe Services, Inc. personnel were held regarding the content of the
December submittal, leading to the recent submittal of the April document.
ESII-B's proposed ground water monitoring program is different in many
aspects from the interim status program. Those aspects, as presented in the
December 1986 and April 1987 submittals, are described here briefly.
HELL LOCATIONS
ESII-B has proposed that each of the two aquifers would have four
upgradient wells. Sixteen downgradient wells are proposed for the upper
aquifer and eight for the lower aquifer. Maps showing proposed well locations
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and equipotential contour lines for the upper and lower aquifers are shown in
Figures 14 and 15. At EPA's request, ESII-B included a proposal for the
installation of two wells at downgradient locations which are at or near the
estimated area of transition of the upper aquifer. At such locations, an
upper aquifer well and a lower aquifer well would be installed. The rationale
given by ESII-8 for the choice of monitoring locations is that they are "based
on groundwater flow directions, aquifer properties determined during the site
characterization study...and the location and orientation of existing and
proposed regulated units." Horizontal distances between proposed well
locations, as measured perpendicular to flow lines, average 145 feet in the
lower aquifer and ?85 feet in the upper aquifer. Regarding horizontal spacing
of monitoring wells, ESII-B states that computer modeling efforts of the
vadose zone "have shown [that] significant spreading of hypothetical leachate
plumes occurs in the vadose zone at Site B and [that] hypothetical leachate
volumes of reasonable size released into the vadose zone will not reach the
uppermost aquifer during the closure-post closure period of the site."
NELL CONSTRUCTION
ESII-B has proposed the use of a combination of new, existing and
redrilled wells for Its monitoring network, as indicated in Figure 13.
Redrilled wells would take advantage of the previous drilling efforts but
would include well design and contruction details identical to those of new
wells. In the lower aquifer, existing wells which are proposed to be included
in the new well network are the four background wells (LMW-13, LMW-27, LMW-28
and LMW-30). Existing wells proposed for the upper aquifer are UMk-16, PCB-1,
SW-1-2, SW-2 and SW-3-2. The general construction of existing wells is
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91
described previously In this report, in the section on the interim status
ground water monitoring program. Silo wells SW-1-2 and SW-3-2 are located
near silo wells 1 and 3, respectively, and are approximately 100 feet more
distant from the silos than are wells SW-1 and SW-3.
The proposed construction of new wells (illustrated in Figures 16 and
17) includes the following features:
()) Well screens would span the entire saturated thickness of the
aquifer at each well location. This would entail screen lengths ranging
from 10 feet to 60 feet.
(2) The drilling method proposed is air rotary with water and Quik-Foam
injection to set driven steel surface casing to approximately 140 feet.
From 140 feet to 20 feet above the top of the aquifer, dry air rotary is
proposed. It is also stated that if removal with dry air is not
possible below 140 feet, water/foam injection would be used to about 20
feet above the aquifer.
(3) Existing site characterization data would be used to guide well
construction activities. From 20 feet above the anticipated top of the
aquifer to the first saturated sand, and for an additional 20 feet (if
possible), the bucket auger method or a combination of dry air rotary
drilling and split spoon sampling would be used, in order to identify
the first saturated sand encountered. From the bottom of the bucket
auger section to the anticipated bottom of the aquifer, air rotary with
water and foam injection would be used.
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THICKNESS OF UPPER AQUIFER
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UPPER AQUIFER WELL
TYPICAL CONSTRUCTION I+WUllli
-------
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LENGTH WILL VARY WITH TOTAL THICKNESS OF LOWER AQUIFER
10" DENSE PHASE CUP
CENTRALIZER
LOWER AQUIFER WELL
, CONSTRUCTION
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92
(4) Each well would have a surface casing of 8-5/8-Inch OD (8-1/8-inch
ID) Schedule 40 steel with welded joints, which would be driven to
approximately 140 feet in a 7-7/8-inch diameter borehole.
(5) All new wells would have a nominal inside diameter of four inches.
A 10-inch dense phase cup is proposed for each well. The dense phase
cup, well screen and bottom end plate would be 304 stainless steel.
(6) Well screens, which would span the aquifer thickness at each
location, would extend 10 feet above the encountered static water level
in the upper aquifer wells. A five-foot stainless steel riser would be
placed above the screen. In the lower aquifer, screens would be
positioned at the bottoms of the inner confining bed, and a stainless
steel riser would be placed above the screen to five feet above the
static water level. Water levels in the lower aquifer would extend up
to 20 feet above the top of the screen due to the confined head of the
lower aquifer.
(7) From the top of the stainless steel to two feet above ground level,
4-inch Schedule 40 PVC with threaded flush joint couplings would be
used. Stainless steel centralizers would be located at the bottom and
top of the well screen assembly.
(8) Slot sizes of all screens would be .010-inch. No. 16 silica sand
would be used for the filter pack. In its proposal, ESII-B states that
the screen slot and filter pack sand were sized for the screen slot size
and aquifer sands, and further, that the use of the specified
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93
combination of slot size and filter pack material is supported by
textbook sizing calculations as well as prior experience at the site.
(9) For new wells, it is stated that the filter pack would extend from
the bottom of the dense phase cup to above the top of the screen not
less than two feet but not more than 10 percent of the total length of
the fi Her pack.
(10) Because the top of the filter pack would be below the
potentiometric surface in the lower aquifer wells, the requirements for
sealing the annulus of a well in the lower aquifer are different from
those in the upper aquifer. The seals in the upper aquifer wells would
have 10 feet of two percent bentonite-cement grout on top of the filter
pack. From the top of the cement to 10 feet below the steel surface
casing, dry granulated bentonite would be placed. Another plug of two
percent bentonite-cement would be tremied on top of the granulated
bentonite and would extend five feet up into the bottom of the steel
surface casing. Dry granulated bentonite would then be used to fill the
inside of the steel surface casing to 20 feet below ground level.
Concrete would be used to fill the upper 20 feet of annulus and to form
a four-foot-square pad approximately four inches thick around the base
of the welI head.
In lower aquifer wells, ten feet of two percent bentonite-cement
grout would be tremied on top of bentonite pellets placed on top of the
filter pack. From the top of the grout to 10 feet below the surface
casing, a bentonite grout with a high, unhydrated solids content would
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94
be tremied Into place. Bentonite-cement would be tremied on top of the
bentonite grout and would extend five feet into the surface casing. Dry
bentonite would then be used to fill the annulus to 20 feet below ground
level. Concrete would fill the upper 20 feet of annulus and create a
pad similar to those in upper aquifer wells.
(11) After completion of well construction, wells would be treated with
a disinfectant such as calcium hypochlorite to retard the growth of iron
and or sulfur bacteria. Wells would then be developed usin-g, in the
following order: stainless steel bailer, air lift surging, stainless
steel bailer, and final development by stainless steel submersible
pump. Water removed during the development process would be monitored
periodically for specific conductivity, temperature, pH and turbidity.
The total volume of water removed from each well would be recorded.
ANALYTICAL PARAMETERS
ESII-B has proposed a schedule for ground water sampling and analysis as
follows:
(1) Indicator parameters (TOX, TOC, pH and specific conductance)
quarterly for the first year and semi-annually thereafter;
(2) Volatile organic compounds from EPA's Priority Pollutant list and
total phenolic compounds, semi-annually;
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95
(3) Aroclors, cnloride and TOX quarterly, to satisfy TSCA requirements
for ground water monitoring of PCS disposal units; and
(4) Major anions and cations, annually.
ESII-B proposes that wells SW-1-2, SW-2 and SW-3-2 would be included for
the purpose of monitoring only non-regulated units, i.e., those that had not
received hazardous waste after November 19, 1980, and that these wells would
be sampled only once per year. Samples would be analyzed for the parameters
listed above, but the results would not be included in any statistical
analyses performed on the sample data obtained from the other wells.
MONITORING FOR HEAVY AND LIGHT IMMISCIBLES
ESII-B1s current (Interim status) ground water monitoring program does
not include checking for the presence of immiscible substances that may
collect at the tops or bottoms of water columns, depending upon their density
relative to water. ESII-8's proposal states the intention to check for the
presence of light and heavy immiscibles each time a well is sampled. Light
and heavy immiscible phases are proposed to be monitored using an interface
probe. If the presence of either were detected, a sample would be collected
to submit for laboratory analysis. ESII-B also states that, regardless of the
indications from the water-level probe, a sample of the top 0.5 foot of the
static water column In the well and the bottom liquids and sediments would be
collected twice per year, as part of the well maintenance program. A
discrete-Interval sampler (Kemerer-type) or double-check-valve sampler would
be used to collect the samples, which would be submitted for laboratory
analysi s.
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96
PURGING AND SAMPLING TECHNIQUES
ESII-B proposes that, depending upon field conditions encountered
subsequent to well installation, wells would be purged using stainless steel
submersible pumps (to be removed prior to obtaining samples) where well yields
are greater than one gallon per minute, and using stainless steel bailers in
other locations. ESII-B has agreed not to utilize submersible pumps for
obtaining ground water samples, and to install check valves where they are
used for purging purposes. All samples are proposed to be obtained using
dedicated Teflon bailers.
Three well volumes, including the quantity calculated to reside in the
filter pack., are proposed to be purged from wells prior to obtaining samples,
unless the wells can be evacuated to dryness. In that case, one volume would
be removed. ESII-B has not indicated that it would attempt to purge wells
continuously of three volumes instead of bailing to dryness, when yields (and
controlled purging rates) would permit. The proposal does include a provision
that samples would be collected as soon as the well had sufficiently
recovered, in low-yielding wells purged with a bailer. For wells purged with
a submersible pump, samples would be obtained immediately after the pump had
been removed from the well.
STATISTICAL ANALYSES
ESII-B has proposed to subject only indicator parameter data to
statistical analyses. ESII-B states in its proposal that "statistical
analyses... cannot be performed on the VOAs or total phenols because none are
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97
present in background analyses; therefore, any comparison of these parameters
between upgradient and downgradient wells, or within each well over time,
would be done using a non-statistical methodology, such as trend-line analysis
or other graphical techniques." While this argument may be valid for volatile
organic compounds, total phenolics in fact have been detected in certain
upgradient and downgradient wells at ESII-8, as discussed in this report in
the section on ground water sample data.
ESII-8 has proposed to utilize two separate parametric statistical
tests, both of which would have to indicate the presence of a significant
difference before an investigative action would be taken to verify or prove
erroneous the subject data. In accordance with 40 CFR § 264.97(h)(1)(ii), the
owner/operator must use either the Cochran's Approximation to the
Behrens-Fisher Student's t-test or an equivalent statistical procedure to
determine whether a statistically significant change has occurred in water
quality at the point of compliance as compared with background data. Such a
determination must be made semi-annually, pursuant to 40 CFR § 264.98(d).
ESII-8 has proposed to use the averaged replicate (AR) t-test and the
analysis of covariance (ANCOVA). ESII-8 states that ANCOVA eliminates several
biases that are iDuilt into the t-test because "it does not assume that ground
water data should be homogeneous over time and at all locations." ANCOVA does
eliminate seasonal effects that could alter the values of certain parameters
in some hydrogeologic regimes where such seasonal effects are significant; but
it also requires that, for a significant difference to be found, the
differences in values for a given parameter among downgradient wells must be
less than the difference between the value obtained for a particular
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downgradient well and the background value with which it is compared. This
effectively assumes that differences in the values of indicator parameters
would nearly uniformly change in the downgradient wells should a release occur
to ground water. However, at a large site such as ESII-B, a release would be
unlikely to affect all of the downgradient wells in either aquifer uniformly.
It is more likely that a narrow plume would initially affect the water quality
in one or two wells. This consideration is particularly important in a
detection monitoring system, where the goal is to detect a release before it
is allowed to disperse in any direction.
In its proposal, ESII-B states that if a statistically significant
difference is confirmed by both the AR and the ANCOVA procedures, the steps
described at 40 CFR § 264.97(h)(l) to certify the statistically significant
variance would be implemented. It goes on to state that if a confirmation
were made, the conditions described at 40 CFR § 264.98(h) would be implemented
with two exceptions: "only the well(s) in which the variance occurred will be
resampled, and background values will be established for an applicable list of
parameters to thorougly characterize the nature and extent of any contaminants
present." No description of what such an applicable list would entail is
provi ded.
NON-STATISTICAL EVALUATIONS
ESII-B proposes to use an unspecified trend line analysis to evaluate
all ground-water data other than those generated for indicator parameters.
The only explanation offered as to how such an evaluation would be conducted
and interpreted is that "CiJf trends are identified, a program will be
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99
developed to determine the cause and significance of the trend." Trend line
analyses, appropriately conducted, would be a suitable way to follow and
evaluate values of pH, specific conductance, total dissolved solids (if
monitored), total phenolics and major ions. Trend lines for volatile organic
compounds would be inappropriate in a detection monitoring system. The
detection of such a compound in a downgradient well should be considered a
"hit" under specified circumstances, such as: (1) the compound was not also
found in blank samples; (2) other volatile organic compounds were
concomitantly reported; and/or (3) the concentration of the compound exceeds
previously established threshhold values, such as the method detection limit.
A program that would specifically address such occurrences should be outlined
i n detai1.
HELL MAINTENANCE
ESII-B has described a well maintenance program to be conducted as part
of the ground water monitoring program for the site. It would entail
well-head inspection prior to sampling; semi-annual sounding to determine
total depth of each well; periodic re-development and disinfection; and
determination of specific capacity (gallons/minute/foot of drawdown after a
specified period of pumping) at the time of installation and before and after
any maintenance is performed, or bi-annually if no maintenance is scheduled.
DETERMINATION OF HATER TABLE ELEVATIONS
In its most recent proposal, ESII-B has stated its intention to retain
15 existing test and monitoring wells that would not be incorporated into the
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100
detection monitoring program, but which would be retained for the purpose of
periodically determining water levels. It is also proposed that 11 existing
wells and piezometers be abandoned, reportedly because they either connect the
upper and lower aquifers or have sand packs that come within 10 feet of
bridging the confining bed between the aquifers.
EPA agrees that wells or piezometers which bridge the two aquifers do
not provide useful water level data and may present pathways for contaminant
transport from one aquifer to another, and therefore should be appropriately
abandondoned or rehabilitated. For example, EPA concurs that wells MW-2 and
MW-4 should be abandoned, as stated in this report in the section on the
interim status ground water monitoring program. Well MW-15, which bridges the
aquifers, is an upgradlent well which ESII-B has proposed to redrill as an
upgradient well for the permitted monitoring network.
It is important that ESII-B maintain an adequate system that will allow
an accurate, routine evaluation of the ground water flow directions in the
aquifers. Such information is crucial in the upper aquifer along the northern
border of the site, where no wells have been proposed to be included in the
detection monitoring network. The decision to exclude placement of such wells
is based on ground water contour maps which indicate that flow lines parallel
trench 11. Such a conclusion is dependent upon water level data, which are
not fixed In time, and which must be verified periodically so that an adequate
degree of confidence can be placed in the locations of the wells in the
monitoring network. It is also important to procure such information in the
central areas of the site, where ground water flow direction in the upper
aquifer is in question, particularly as it relates to the area of the silo
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101
complex. ESII-B has proposed to abandon well D-8, which is centrally placed,
but which does not appear from well boring logs to breach the two aquifers.
It should not be abandoned unless it is replaced with an appropriate
substitute. Similarly, the construction of the remaining wells which ESII-B
has proposed to abandon should be scrutinized closely prior to doing so, as it
may be more appropriate to maintain some of them for informational
purposes.
COMMENTS
Since EPA and ESII-8 are still conducting dialogues concerning the
appropriate ground water monitoring program for the RCRA permit determination,
conclusions regarding ESII-B's permit application are not made here.
Following are a few comments regarding the facility's submittal.
(1) Proposed construction designs and methods for the new upper and
lower aquifer wells appear to be appropriate for a detection monitoring
system at this site. Where lower aquifer wells are to be placed in
locations where the upper aquifer is saturated, ESII-B should describe
the construction techniques to be used to prevent interconnection of the
aquifers and to preclude vertical migration of contamination, should it
be present at any time.
(2) Silo wells SW-1-2 and SW-3-2 may not be downgradient from their
respective silos. Silo wells SW-1 and SW-3 are more appropriately
located and should be utilized in ESII-B's ground water monitoring
network.
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102
(3) ESII-B's rationale for horizontal spacing between wells is being
evaluated and independently studied by EPA.
(4) EPA concurs that volatile organic compounds are appropriate to use
as indicators of contamination at this sfte. The volatile organic
compounds included 1n the Hazardous Substance List (as referenced in
EPA's contract laboratory program and in the Federal Register, Vol. 51,
No. 188) would be a more appropriate list than the Priority Pollutant
list, since the Hazardous Substance List of volatile organic compounds
includes all of those on the Priority Pollutant list, plus a few
additional compounds which could be important indicators of ground-water
contamination at a hazardous waste site.
(5) EPA agrees that statistical analyses should not be applied to
values obtained for volatile organic compounds at this site, at this
time. EPA is still considering what, if any, statistical methodologies
would be appropriate for ESII-B's indicator parameter data. However,
analysis of covarlance, as proposed by ESII-B, is not an acceptable
statistical methodology to be used in conjunction with or instead of
other statistical tests for such data generated at this site.
(6) A description of the procedures to be followed by ESII-B, should a
statistically significant change in indicator parameter values be
detected and verified, needs to be more detailed in a permit than ESII-8
has offered in its submittal.
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(7) ESII-8 proposes to deviate from 40 CFR § 264.98(g), which requires
that statistical analyses be conducted for all parameters and
constituents which are required by the permit to be monitored. However,
for parameter arid consitutents not proposed to be statistically
analyzed, ESII-B has provided no method for determining what value or
values would be considered indicative of ground water contamination, and
no reference is .Tiade to any actions that would be taken in response to
such a finding. Where application of statistical methods to data
generated at this site is deemed inappropriate by EPA, it would be
appropriate to specify concentrations (or trends) for Individual
parameters and constituents which would act as triggers to set into
motion procedures including the following: notification of the Regional
Administrator in writing of a finding indicative of ground-water
contamination; resampling efforts, including identification of wells to
be sampled and analytical parameters; submittal of an application for a
permit modification to establish a compliance monitoring program; and
provisions for a demonstration that a source other than a regulated
unit, or that error in sampling, analysis or evaluation was responsible
for the finding.
(8) Annual sampling of silo wells, as proposed by ESII-B, may not be
frequent enough to determine in a timely manner whether contamination
previously detected 1n those areas actually represents a release to
ground water.
(9) Wells and piezometers which currently exist within the interior of
the site or along the northern site boundary, and which do not bridge
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both aquifers, should be maintained for the purpose of obtaining water
elevation Information throughout the permitted life of the facility. If
sufficient numbers of such wells do not exist after determining which
should be abandoned due to bridging, additional wells or piezometers
should be installed to ensure that ground water flow directions in the
upper aquifer can be accurately and routinely evaluated.
(10) Wherever possible, wells should be purged of three or more volumes
of water to ensure that samples are representative of formation water,
and then immediately sampled. Wells should be purged to dryness only
when the aquifer yield in a given location precludes a continuous
purge-to-sample routine.
-------
105
GROUND WATER SAMPLE DATA
INSPECTION DATA
The analytical results obtained from ground water samples obtained
during this inspection are summarized in Appendix C. A discussion of the
usability of the data is reproduced in Appendix D. Data for total phenolics
and pesticides are reported to be unusable, based on quality assurance
considerations. Also unreliable are values for nitrate nitrogen, TOC and, in
certain specified samples, chloride, sulfate and ammonia nitrogen. Region 10
had intended to use the major ion data, including the carbonate/bicarbonate
balance, to supplement the geochemical characterization of the site; however,
this was not possible because the data were reported as qualitative rather
than quantitative. Acetone was abundant in blank, samples and therefore, the
values reported for all samples are unreliable as indicators of its presence
in ground water.
The balance of the data is usable, with usability classified as either
quantitative, semi-quantitative, or qualitative, as delineated in Appendix D.
Aside from the pesticide data, all results for volatile and semivolatile
compounds are quantitative. Samples were obtained for dioxin analyses, but
the samples were not analyzed until sometime after the other samples, and the
results presently cannot be located. This report will be amended to reflect
the results If they are discovered or reproduced.
The sample analysis data are for the most part unremarkable. Low levels
of chloroform were detected in silo wells SW-1 and SW-3, consistent with the
-------
106
results ESII-B has obtained recently for those wells. An unidentifiable
semivolatile compound was reported in SW-3 at 17 ug/1, although it was not
reported in the duplicate sample obtained from that well. Low levels of
phthalate compounds were reported in wells MW-11, MW-13, PCB-1, PCB-2, PCB-3,
MW-16 and Mk-21, and In a field blank. Phthalates were not detected in the
stainless steel silo wells, reinforcing the belief that phthalates are
released from the polyvinyl chloride well casings. N-butylbenzenesulfonamide
was tentatively identified in well D-19 at an estimated concentration of
9 ug/1. The same compound was tentatively identified in MW-3 at an estimated
concentration of 17 ug/1. An unidentifiable semi-volatile compound was
identified at an estimated 215 ug/1 in MW-5.
REVIEW OF ESII-B SAMPLING DATA FOR INTERIM STATUS WELLS
A review of the available ground-water data for the interim status
monitoring well network from January 1984 through December 1986 was
conducted. As mentioned previously, it was not until late in the report
preparation process that EPA realized that ESII-8 had been conducting monthly
analyses for samples from the Interim status wells that were much more
extensive than had been believed. These data were requested and obtained for
the sampling events 1r» 1984 through 1986. In May 1986, ESII-8 discontinued
monthly sampling and also discontinued analyzing ground-water samples for the
extensive list of organic parameters that it had been obtaining since January
1984. Since May 1986, only those parameters required by 40 CFR Part 265
Subpart F reportedly have been obtained for the evaluation of RCRA ground
water monitoring wells (except four upper aquifer, downgradient wells, which
are sampled quarterly for volatile organic compounds as part of the silo well
-------
107
monitoring program). In addition to the 40 CFR Part 265 Subpart f parameters
required of a facility operating a detection monitoring system, ESII-8's
historical data base includes monthly samples from January 1984 through April
1986, analyzed for the following parameters: Priority Pollutant volatile
organics and base/neutral extractable compounds; Priority Pollutant acid
extractable compounds and pestlcldes/PCBs (analyzed In only three sampling
events, in 1984); and a few constituents from the 40 CFR Part 261, Appendix
VIII list of hazardous constituents, which had been reported from the first
sampling event in January 1984, when EPA and IDHW obtained split samples for
analysis. Those constituents are Isophorone, naphthalene, pyrene and 2,4,5-T,
all reported at concentrations below 1 ug/1.
Trichloroethane was routinely discovered In wells MW-1, MW-3 and MW-5 in
1984. ESII-8 discovered that the pumps installed in those wells contained
substances other than stainless steel. It was reported that glue present in
the pumps contained solvents. The pumps were replaced in January 1985, and
the detected levels of trlchloroethane subsequently decreased and eventually
disappeared. The levels of trlchloroethane in well MW-5 (the well with the
highest concentrations) ranged between 12 and 61 ug/1 during 1984. In April
1985. the concentration of trlchloroethane in MW-5 was reported as 11 ug/1.
Trlchloroetnylene was detected 1n MW-3 at 3 ug/1 In April 1984, but was also
detected In a trip blank sample that month. In April 1985, trichloroethylene
and tetrachloroethylene were reported at concentrations of 7.6 and 7.4 ug/1,
respectively. None of these compounds was detected in samples after May 1985,
including those obtained during this inspection.
-------
108
Methylene chloride and trichlorofluoromethane have occurred regularly in
ESII-B ground-water samples. Because many blank, samples, both field and trip,
have shown the presence of comparable concentrations of these compounds, they
are not reliable indicators of contamination at this site. Also abundant in
the PVC wells are phthalate compounds. The balance of ESII-B's data base
reflects infrequent "hits" of organic compounds at low concentrations, the
existence of which have not been substantiated by subsequent sampling events.
For example, chloroform was reported In MW-5 and MW-3 at 0.6 ug/1 in February
1984 but has not been reported since. (It was, however, reported in a field
blank in June 1984.) Pyrene, reported in wells MW-4 and MW-5 in the January
1984 sampling event, was reported in MW-2 in August 1985 at a concentration of
2.21 ug/1. Fluoranthene was reported in the same well during the same
sampling event at 3.15 ug/1.
Analyses from 1986, obtained monthly by ESII-B for its extensive
parameter list only through April of that year, show the following compounds
as being detected, all in March: isophorone, 2.2 ug/1, MW-10; benzo(a)pyrene,
3.53 ug/1, MW-16 (upgradlent well); benzo(a)pyrene, 5.05 ug/1, MW-24;
benzodOfluoroanthene, 6.13 ug/1, MW-16 (upgradient well); and
benzodOfluoranthene, 9.49 ug/1, MW-24. Isophorone was reported in the
January 1984 sampling event In wells MW-4, MW-5 and upgradient well MW-6 (all
below 1 ug/1 concentration) and had not been detected again until March 1986.
Otherwise, the compounds noted above had not been detected previously, were
not detected in the April 1986 sampling event, and were not detected in the
samples obtained during this inspection. Not unlike these values, occasional
spikes of TOC or TOX appear in ESII-B's historical data base, although the
significance of these indicator parameters cannot be evaluated since
statistical analyses were not performed for them.
-------
109
Total phenol1cs presents a parameter category of interest at ESII-8.
Total phenolics have Oeen reported In a few wells over the period during which
ESII-8 has been sampling, but not all wells appear to be affected. Data for
total phenoli:s are shown in Table 11. There are no reports of total
phenolics detected in the upgradlent wells In the upper aquifer, although
MW-6, a lower aquifer, upgradient well, shows the presence of phenolics on
three occasions, all below 100 ug/1. Hell MW-11 shows a single reported value
in October 1985 of 294,000 ug/1, several orders of magnitude greater than any
other value reported. This value was confirmed by ESII-B to exist in the
technical data report as well as in the summary data report, which EPA
received.
Although values for total phenolics are prescribed for use as indicators
of ground water quality, the presence of total phenolics above detection
limits is not necessarily an indication that ground-water contamination has
occurred. Phenolics comprise a class of aromatic organic compounds which
occur in nature, but they also represent one of the highest-volume chemical
groups produced in the United States. Examples of phenolics are phenol, the
cresols, xylenols, resorclnol, naphthols, and chlorinated phenols, such as
pentachlorophenol.
The presence of total phenolics in ESII-8's data base does not have any
immediately clear significance. Except for three sampling events early in
1984, ESII-B's analytical efforts have not Included the acid extractable
compounds from the Priority Pollutant list, which consist of individual
phenolic compounds. The analytical methodology used by ESII-8's laboratory
may be responsible for the fact that only occasionally are values reported for
-------
We_l_
rtw-l
MW-2
MW-3
MW-4
MW-5
MW-6
MW-10
MW-1 1
MW-21
Sample
_Date_*
1/84
9/84
1/85
5/85
10/85
1/84
9/84
2/85
7/85
1/84
12/84
1/86
1/84
4/85
7/85
1/84
1/84
2/85
2/8b
10/85
10/85
10/85
1/86
986
16
290
750
68
69
22
170
7y
74
22
720
99
13
54
53
23
25
93
56
120
294,000'
80
51
Sample analyzed by
Sample analyzed by IOHW
Sample analyzed oy IDHW
Sample analyzed oy EPA
Sample analyzed oy EPA
Sample analyzed Oy EPA
**
ESII-B monthly data for total pnenohcs is available for wells MW-1
tnrougn MW-6 from January 1984-1986 and in wells MW-10, MW-11, MW-13,
MW-15, MW-16, MW-21, MW-24, and MW-25 from January 1985-Apnl 1986.
Where no data is reported in this table, no total pnenohcs were
detected.
ESI confirmed tnat tms value is founa in the laboratory raw data report
as well as tne summary data report. However, the company recently
requested its laboratory to confirm the value independently.
-------
10
total phenolIcs. Method 9065 of SW-846, which has the relatively high
detection limit of 50 ug/1, has been employed. It is not unlikely that
phenolic compounds occur naturally in the ground water beneath the ESII-B
site, but have not been reported because of the method detection limit.
During the process of preparing this report, EPA recommended to ESII-B that it
request its laboratory to change the subject methodology to SW-846 method
9066, which has a detection limit as low as 2 ug/1; or to some other
EPA-approved methodology which has a relatively low detection limit. By doing
so, the significance of the already-reported total phenolics data should
become more apparent.
Total dissolved solids (TOS) in the ground water at ESII-B also may be
of value to monitor. ESII-B has conducted limited analyses of total dissolved
solids, but a limited data base that was developed in 1984 and 1985 is
complemented by ESII-B's analysis for IDS in its samples split with EPA during
this inspection. Historical TOS data for the wells sampled during the
inspection, along with corresponding specific conductance values, are
tabulated in Table 12. It Is interesting to note that in certain wells, such
as MW-3, PCB-2, and SW-2, TOS values increased by approximately three-fold.
Although no previous TDS data exist for SW-1 and SW-3-2, the recent values are
very high compared with the most of the values for other parts of the site.
High total dissolved solids in the region of the silo complex would tend to
add credence to the previously discussed theory that vertical recharge
preferentially occurs In that area. However, since the value for SW-3 is
reported to be below detection limit, which is not a plausible value for any
ground-water sample, the reliability of all of the TDS data reported from this
sampling event must be questioned. ESII-B has been asked to have its
-------
Wen
MW-3
MW-b
MW-9
MW-lo
MW-1 I
Hk-13
HW-16
MH-21
MW-2b
PCB-I
PCB-2
PCB-3
SW-I
SW-2
TOSD
CONDC
TDS
COND
TDS
COND
TDS
COND
TDS
COND
TDS
COND
TDS
COND
TDS
COND
TDS
COND
TDS
CUNO
TDS
COND
TDS
COND
TDS
COND
TDS
COND
.12/8
1080
1500
862
1450
724
1010
802
1 1 10
1270
1710
652
U50
i/85
814
990
1410
862
1430
722
1010
840
1 160
1270
1780
744
1220
937
912
1430
960
1380
1060
1400
1060
1460
900
1340
100
6/86
3700
990
870
905
640
660
700
760
30d
1310
740
735
950
1020
810
925
690
735
500
1100
2800
1025
1900
850
3000
1225
2800
1100
-------
Table 12.
EPA «Ur,n ,nsp o
-it ' •
c Values in umnos/cm.
- r<~'r-B nas oeen asxed to verify tnese values,
8/85 ]
"NO ]250 8md
160Q BDI-
SW-3-2 IDs 1Q00
l 4600
D-ld Tos I06°
COND 2600
°-^ TDS 934 675
COND " 1050
1100
d All values are from ESII-f
-------
laboratory verify the value reported for SW-3. Regardless, analyzing for
total dissolved solids on a regular basis would be advisable at this site,
since it may provide valuable information as to the localized status of site
geochemistry and hydrology, and, therefore, contaminant transport.
CONCLUSIONS
There does not appear to be any reliable evidence of ground-water
contamination at the site boundary of ESII-8 in either of the two monitored
aquifers. From a regulatory standpoint, ESII-8 must fulfill its interim
status obligations to carry out required statistical analyses in order to
obtain a RCRA permit allowing it to operate In a detection monitoring mode.
Long-term sampling of wells in the silo complex area will be necessary to
definitively determine whether ground water contamination exists from past
practices in that area. The discussion below is limited to data generated
from the interim status ground water monitoring wells.
The occasional reports of the detection of various organic compounds at
low concentrations, not consistent in location or substantiated in time, are
not readily explainable. Technically, probably the best parameters to be used
as indicators of ground-water contamination at ESII-8 are volatile organic
compounds. ESII-8's monthly analyses of Priority Pollutant volatile organic
compounds serve as a good Indication that ground water contamination had not
occurred, at least until May 1986 when ESII-B discontinued that schedule.
However, such demonstration is somewhat diminished by the existing well
construction and the purging/sampling techniques employed by the facility.
-------
112
While the analytical tests have been thorough, the quality of many of the
samples, and thus the reliability of the data generated from them, 1s
questionable.
Specific changes In ESII-B's purging and sampling techniques are
recommended earlier in this report in the review of the facility's interim
status ground water monitoring program. Once ESII-8 Improves the degree of
reliability that can be placed in the samples it collects, additional analyses
should be conducted to confirm the absence of ground-water contamination in
the interim status wells. Analyses for total phenolics should continue, but
with a methodology that provides a detection limit lower than 50 ug/1. It is
also recommended that ESII-8 include total dissolved solids in its parameter
list, at least periodically, to follow trends in these values and to be
alerted to any dramatic elevations in TDS values which might be an early
indicator of contaminant transport.
-------
APPENDIX A
FIELD MEASUREMENTS
-------
FIELD
SWTF IN'SPECTIO.V, ESII-"
4i*£ -ill parameter
6/17 PCS-: time
tempCc)
PM
cond(umhos/cn)
5/17 TV n .,
1 ~ ! ' tine
temp
cond
pH
5/13 -/.in
•• ' J time
temp
cond
PH
f. /I O ,, . --
b/I- MH-25 time
temp
con^
PH
6/19 «M3 time
temp
cond
pH
r
6/1 " MH-16 time
PH
cond
temp
6/20 WB-l time
temp
PH
cond
1022
18.1
^ .—
7.9
375
«•>*..
151?
21.5
t J o A
14QC
5 a
^* • O
0845
20.3
750
7.05
1210
22.2
720
7 —
.3
OS 3 5
19.0
720
7_
.3
1000
6.9
1020
18.3
q^c
M4o
13.4
7 i
' . i.
1125
1045
13.0
7.0
850
1530
24.2
1260
r A
".3
0911
20.7
200
7.1
1300
22.5
750
7.3
C900
20.2
750
7.3
1035
7.0
1050
18.3
915
18.2
7.1
1100
114?
20.0
6.95
850
1600
24.1
1240
6.9
0940
21.3
76?
7 1
i . >.
142H
23.2
735
7.3
140Q
22.1
735
7.3
1155
7.0
980
18.5
550
18.4
7.2
1100
1725
21 ">
t i • i.
nn
6.9
0958
21.2
750
7.1
1212
7.1
1020
18.6
-------
page 2 of 3
date well parameter
6/20 MW-21 time
temp
pH
cond
5/23 SW3-2 time
PH
cond
temp
5/23 SW-1 time
temp
PH
cond
6/23 SW-2 time
temp
pH
cond
6/23 SH-3 time
temp
PH
cond
5/24 MH-3 time
temp
PH
cond
6/24 D-13 time
temp
PH
cond
6/25 MW-5 time
temp
pH
cond
1410
20.4
7.1
875
0950
5.9
1240
19.5
1010
20.2
7.2
975
1045
18.8''
7.1
900
1056
20.3
7.3
950
0905
19.6
7.2
1050
1345
18.3
7.4
650
3342
19.3
7.05
000
1500
21.3
7.1
040
1040
6.9
1100
19.3
1115
21.3
7.2
900
1155
19.4
7.0
800
1446
21.:
7.3
1120
0930
19.3
7.2
1050
H20
13.5
7.2
550
1343
21.9
*.35
930
1510
21.5
7.2
925
1?02
7.0
1060
19.3
1500 5/24
21.5
7.0
925
1452 5/24
19.8
6.9
360
1625
22.7
7.2
1000
6/25 0853
19.0
7.0
1000
1453
13.6
7.1
675
13C3
21.1
7.1
905
1030
21/1
7.1
1225
1320
19.3
6.35
1100
0032
19.0
7.4
990
-------
3 of 3
4i$i all parameter
5/25 pr3,2 t1me
PH
cond
temp
6/25 O-l? time
temp
PH
conductivity
5/25 ™-3 t1ne
0955
7.05
1000
19.3
1040
19.9
7.0
930
1030
7.05
1015
19.6
1115
19.6
7.0
1100
7.05
1020
20.2
1145
19.7
7.0
1100
IMS
7.0
1025
19.3
cond
PH
1050
19.5
750
7.2
1715
19.4
675
7.1
1730
18.7
690
7.1
13.9
660
7.0
(compiled from field notebooks)
-------
APPENDIX d
PARAMETERS, ANALYTICAL METHODS AND DETECTION LIMITS
FOR EPA SAMPLES OBTAINED AT ESII-B
-------
Table 8-1
ANALYTICAL PARAMETER LIST AND DETECTION LIMITS
detection limit, ug/l VOLATILES
10 chlorometnane
5 1,1,2,2,tetracnloroetnane
10 oromometnane
5 I ,2-dicnloropropane
10 vinyl cnloride
5 trans-1 ,3-dicnloropropene
1U cnloroetnane
5 tricnloroetnylene
5 methylene cnlonae
5 dibromocnlorometnane
10 acetone
5 1 ,1 ,2-tricnloroetnane
5 carbon disulfide
5 oenzene
5 1,1 -aichloroetnene
5 cis-1 ,3-dicnloropropene
5 1,1-dicnloroetnane
10 2-cnloroetnylvinyiether
5 trans-1 ,2-dicfiloroetnene
5 oromoform
5 chloroform
10 2-nexanone
o 1 ,2-dichloroethane
10 4-metnyl-2-pentanone
10 2-butanone
5 tetracnloroetnene
5 1,1,1-tncnloroetnane
5 toluene
5 caroon tatrachloride
5 cnloroben^ene
1U vinyl acetate
5 etnylDenzene
5 bromodicnlorometnane
5 styrene
20 acenaphtnene
20 pnenol
100 2,4-d1mtropnenol
100 4-mtropnenol
20 bis(2-cnloroethyl)etner
-------
Table B-l, continued
detection limit, ug/1 SEMIYOLATILE COMPOUNDS
20 di oenzofurari
cJ 2-cnloropnenoI
20 2,4-dinitrotoluene
20 1 ,3-chcnlorooenzene
20 2,6-dimtrotoluene
20 1 ,4-dichloroDenzene
20 diecnyIpntnalate
20 benzyl alconol
20 4-cnlorupnenyl-pnenyletner
20 1 ,2-dicnlorooenzene
20 fluorene
20 2-metnylpnenoI
100 4-nitro
-------
Table B-l, continued
detection limit, ug/1
SEMIVOLATILE COMPOUNDS
20
20
20
20
20
2U
100
20
20
20
100
20
20
20
20
100
4-cnloro-3-
-------
Table 8-1, continued
detection limit, ug/1
PESTICIDES/PCBs
1.0
.Oo
.Ub
.05
.05
.05
. 10
.10
.10
.50
.30
.30
.50
1.0
aroclor-1254
Deta-8HC
delta-BHC
gamma-BHC (lindane)
aldrin
endosulfan I
4,4'-DDE
endosulfan II
endosulfan su)face
metnoxycnlor
cnlordane
aroclor-1016
aroclor-1232
aroclor-1248
aroc1or-!2oO
detection limit, ug/1
100
3
6
4
4
0.5
93
8
16
12
21
12
500
100U
238
3
0.2
20
2160
10
10
156
5
10
2
10
1000
METALS AND OTHERS
a 1 umi num
antimony
arsenic
oanum
Deryl1lum
cadmium
calcium
chromium
cobalt
copper
vanadium
zinc
sulfate
total organic carbon
magnesium
manganese
mercury
nickel
potasium
selenium
silver
sodium
tnalIium
i ron
lead
cyanide
cnloride
-------
Table 8-1, continued
detection limit, ug/1 METALS AND OTHERS
50 Dronude
300 nitrate
1000 total organic nafide
100 purgeaole organic carbon
50 nitrite
10 total pnenols
5 purgeaole organic nahde
100 carDonate/bicaroonate
-------
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-------
APPENDIX C
SUMMARY OF CONCENTRATIONS FOR SUBSTANCES REPORTED
IN GKOUND WATER AND BLANK SAMPLES OBTAINED DURING
THE EPA INSPECTION AT ESII-B
-------
TABLE C-l
Trip Blank
a
3 ank near MH-25 4 MW-lo
Blank near MW-ld
Fle'd Blank near sw-3
Sailer Blank
PCB-1
PC8-2
PCB-3
SW-1
SW-] dup.
SW-2
SW-3
SW-3 dup.
SW-3-2
MW-3
HW-5
MW-9
rtW-10
MW-1 1
MW-13
HW-16
MW-21
MW-25
D-18
0-19
MQA 461
MQA 447
MQA 445
MQA 454
MQA 440
MQA 452
MQA 443
MQA 444
MQA 449
MQA 458
MQA 456
MQA 457
MQA 450
MQA 442
MQA 459
MQA 436
MQA 460
MQA 433
MQA 455
MQA 434
MQA 439
MQA 451
MQA 453
MQA 446
MQA 448
MQA 441
Q1250
Q1236
Q1234
Q1243
Q1229
Q1241
Q1232
Q1233
Q1238
Q1247
Q1245
Q1246
Q1239
Q1231
Q1248
Q1225
Q1249
Q1222
Q1244
Q1223
Q1228
Q1240
Q1242
Q1235
Q1237
Q1230
-------
TABLE C-2
ANALYTICAL RESULTS
-------
CASE MO!
SAMPLE MO,'
ami LOCATION;
ami TYPE:
*TKTLDC CHLORIDE
SOU- PHENOL
m I'HJIOtflROBEXZBC
DI-K-BUTYUWHflJTE
PEST/ NO HITS
PCB
W HITS
4,2 J
TIC-
SOU- TETRAffTHYLTHIOUSA
WA 1MMWN
l/MKMWN
17 J
TOTAL
ARSEMC
CALCIUM
COBALT
COPPER
IRON
L£AD
P0TASSIUK
SILVER
SDDIUN
! ! J
' 42 1 , ' 13>4 '
1 58 1 224 |
1 1
' ' I
1 153000 1 134ooo , 102000 ;
' l •
1 '
! :
J 171° 1 ™* I 787 ,
! 7"£ ' «100 I 58500 ,'
, ^" ^' 221 ,
i
14,1 |
251 !
1
1
112000 |
9 1
1
t
f
1340 I
1
69200 I
254 1
28700 ' 24800 | 28200
I 142000
120000
148000
30100
145000
192
719
ALL awcDrnwnws ARE IN
A2-2
-------
SITE:
CASE
ij
svni NO:
ami LOCATIW:
S*TLE TYPE:
WMonif
n« -
SEE-
" *
IWR6. AWIONIA NITROGEN
INDIC. BRONIK
CHJKIIC
CYWUK
NITRATE HITR06EK
NITRITE NITROGEN
5200 |
I
124000 I
I
2200 1
30 1
42000 |
1
1
i
2?00 I
1
48000 |
1
780 I
8200
490000
1060
POX
SULW7!
roc
TOTAL PfflfflLS
TQX
CARKVMTE
1?5000 1
2200 I
76 1
3BOOOO |
3200 I
1
i
195000 I
5200 I
20 .1
480000
3400
f
I
I
i
693000
782000
973000
776000
1200
I
12000 I
ALL CWCOfflWTIWS ARE IN
-------
NO:
ID «J3
SEW- PHENOL
VGA IrHIICHLORQSEKZDe
J I
2,4 J
1 2,6 J I
PCB
«) HITS
WA-PT
NO HITS
nc-
SEMI- TFTIWETHTLTHIIWEA
^M 1MMOW
861) MJ |
24 J I
200 J |
TOTAL
ARSEKTC
BARIUM
COBALT
COPPER
zmw
LEAD "
HICKS.
SELENIUM
SILVER
THALLIW
I 232 I
984
0,2
599
333
918
311
S30
9 I
320
718
ALL CONCENTRATIONS ARE IN u*/L.
A2-4
-------
sin;
CASE
SMTLE ND:
is <«J3
IMR6,
IKDIC,
NITROGEN
CNLORJK
NITWTE
NITRITE MITROGEX
POC _
PtJX
SULFATE
TOC
TUTAL PfOfflLS
TDX
CARKWATE
BICARBONATE
7 I
1200
22
150 |
I
10000 I
I
1200 I
3000
100
6000
1000
I
6000 !
6000 I
1100 I
« I
6000
AIL cwremwnws ARE IN usi/i,
A2-5
-------
SITS;
CASE «: 4044
SOU- PHENOL
W 1'4-DIWJROflQCDe
TCP
W HITS
2,2 J I
2 J
NO HITS
HC-
SSfl- irnWCTHYLTHJOUREA
UMOflNN
HPUR 994) 17J
BARIUM
CAWJIUH
CALCIUH
CHROKUM
COBALT
COPPER-
LEAD -
«A6*SIUH
>iAW6AWE5£
«RCURT
WOE.
PfJTASSIt*
SELENIUH
SILVER
SODIWf
THALLIUH
5440 I
1
1
1
1
J
1
1
1
1
1
f
f
1
1
45 I
1
1
159000 1
17 I
1
16 I
703 I
1
73200 |
443 I
1
46,8 | ,
48 1 43 i
1J I
' 1
i
1 |
94600 1 140000 |
i .
1 1
1 ,
' 1
' 1
9410 I 144 ,
2.9 / ,
f
38500 I W9oO 1
295 ! 141 ,
I i
i
1
60 |
1
1
143000 I
23 1
1
I
I
4450 I
3,4 I
68500 (
367 |
7
573
46600
194
25400
141
29000
133000
24600
2<*» I 29700
I I
74?W I 133000 I ;i9ooo
14700 I
1
!
167000 I
All CWCENTRATIOW ftt£ IN u«/L,
-------
VAMMIUN
zi«- -
INOR6, MWMA NITROGEN
INDIC. BROMIDE
CHLORIK
CYAWIDE
NITRATE
NITRITE
POC
TOX
SILFATE
TOC
TOTAL P«WLS
TOX
CARBONATE
BICARBONATE
4400 |
700 f
33^> I 13900 I
' I
3*> ' 270 I
' I
1 I
' I
I 180000 I
2700 I I700 ,
3500 |
60 I
4800 I
1
220 |
5600 |
i
13400 !
1
310 |
60
24600
«fl«
I
I
100000 I
2000 I
645000
3?4000
50000
2900
681000
8600
6100
764000
CONCENTRATIONS ARE IN
A2-7
-------
SHI:
CASE M
SAMPLE
SAfTLE
m
SKI-
PSST/
PCS
TIC-
VOA-PT
nc-
SEHI-
TDTAL
CTALS
): 4044
NO:
TYPE:
CH.OROFORM
fCTWYLE* CHLORIDE
PHDflL
JJ-K-BUTTLPHTWLATE
m HITS
W HITS
TETRAffTHTLTHIOLREA
LWKNDW
1MNOUN
AL1WIMJK
ARSENIC.
BAWWI-
CADHHJH
CALCIUH
CWQHIWf
COBALT
COPPER'
IRW .
LEAD -
AASESIUf -
POTASSIUM
SELEXIlffi
SILVER
SOBIUN
O237>^BM4€
yELL 9-18
1 9.7 Jl
1
1
1
I
1
1
I
1
1
1
I
1
1
1372
204
0.5
90700
S3
13
61000
29.1
27400
1370
19700
11,4
73600
«LL M9
1 43 B
1
1
1
1
!
1
(POP 889) 9J
I
1
1
678
131000
1080
62000
269
26800
96800
B1232/MA44J B1233/WM444
KLL PCI-1 1CLL PCK2
' 9 J I 77 1
1 1
1 I
1
1 5,2 J 3.6 J
1
1 2,2 J
1 1
1 1
I l'
1 1
1
1 1
1
1
1450 6180
11
361 119
1
79600 1 135000
1 16
1
1 30
2360 t 4800
1 22,8
44800 1 63800
209 / 529
1
1
23100 1 30000
1
!
165000 1 138000
tCLL W-25
t 5,4 Jf
1
1
1
1
1
1
1
1
15.9
560
53400
293
29800
51
19900
11,9 I
I
157000 1
THALLIUM
ALL CONCENTRATIONS ARE IN m/L,
A2-3
-------
CASE »: 6044
ZINC
IWW, AWJKIA KITWS3*
. 8WWIK
010RIK
CY/WIK
KITRATE xrnaKii
NmiTE WTROGEN
PX
POX
SULfATI
Ttt
TOTAL Pf£fflLS
TOX
CARfiOMATE
BICAKBONATE
900 |
1
140000 I
2800 I
I
19400 |
I
230 |
I
135W« I 2050000
1800 | 14flo
370000
445000
1600 I
I
42000 I
I
4800 I
I
I
22000 I
3900 I
(
I
767000
6800
36000
365000
400
100
50
25300
900
3700
681000
ALL OWCOrTRATIOffi ARE IK at/I.
A2-9
-------
NO.' 6044
LXATIW:
PEST/. WHITS
PCS
T-- . W HITS
VOA-PT
gsr Bar
TIC- ff-BUTTlJEXZDCJJLOWCK
SEW- TETRASTHTLTHIOUREA
m UfKMMff
UNKMWN
12 J
TOTAL
24400
2050 I
I
mm
BERTLLJUN
CAMIUH
- CALCItff.
CHRQHIIM
COBALT. .
COPPER
IRW
LEAD
NABESIUK
nAMGAttSfc
SROJRT
WOCEL
POTASSIUH
SSJNIWf
CTI ncp
dl^YCA
SODIUH
THALLIUM
14 1
144 i
1
171000
42
250
24400
30.4
41400
813
29200
I
98400 1
1
1
441 1
1
1
103000 1
1
1
1
1880 1
1
50600 i
216 1
- I
I
28200 1
)
1
135000 j
41,2
685
52200
544
29800
47
20200
165000
?2200
261 f
I
47900 I
24200
89000
41
135000 I
16 I
!
16 I
383 I
489
•
28400
103000
ALL CONCENTRATIONS ARE IN u*/L.
A2-10
-------
ZIMC -
IMffi, AffiOKIA KITROff*
I»IC. BWKIJE
OURIJE
CYAWK
WTMTE MTROGtt
WTRHE
POC
Pt3X
SULfATE
roc '
TOTAL PJOEH.S
TOX ~
CARItMATE
BIDKBOfMTE
300 I
I
13MO I
!
70 I
450000 |
2800 |
2700 I
10 I
54000 !
I
ioeo i
I
86000 I
2600 |
MOO !
1
23800 I
2200 |
1
14*00 |
5200
40
1WOO
512000 I 457000
500 I
I
12000 I
4200 I
(
I
705000
600000
1400
10
561000
I
I
600000 |
2900 ]
537000
CONCENTRATIONS ARE IN
A2-II
-------
-sin; &v;«os»rtf is
CASE m;
ami TT?E:
B1249/NBMM
KLL W-5
ACETD*
DOROFOBf
«7WL£« CHJRJK
Jll
SEMI- P«NOL
WW 1^-DICHLOROJOCDC
BIS (2-CTHYLHEXYL) PHTmLATE
PEST/ HO HITS
PCB
TIC- . XO HITS
VOA-PT
JIC- .
SEMI-' TETRWCTHTLTHiajREA
V(M 1MMWN
UNKNOWN
I.
213 J I
I
TOTAL ALMNWf
tfTALS AWTIrtCWT
ARSEHIC
BMZUf
SCRrLLIlfl
CAiCIUH
CHRWIUN
COBALT .
COPPER
IRW._
L£AH -
NA6ME5IW
OCURY
WDCEL
POTASSIIH
SELENIUM
SILVER
9.3
859
75300
576
5W
42300
72
2WOO
17?000
THALLIWf
ALL OWCEKTRAHOW ARE IN USA,
A2-12
-------
CASE MO.'
NO;
LOCATION:
smr TTFEJ
W-5
UK
VAMWIUI
IMJRS,
WTTO6EX
DLORUC
CTAWJE
NITRATE HITTOGEN
WTRITE HITKOBOt
PX
POX -
SULFATE
roc
rar/w. PHEMJLS
TOX
CARBONATE
BICARBWttTE
ALL CWftSmWTIONS ARE IN uS/L,
A2-13
-------
APPENDIX D
EVALUATION OF QUALITY CONTROL DATA AND ANALYTICAL DATA
GENERATED FROM EPA SAMPLES OBTAINED AT ESII-b
-------
Evaluation of Quality Control Data and Analytical Data
i.o
1.1 Performance Evaluation Standards
Metal anaiyte performance evaluation standards were not evaluated in
conjunction with the samples collected from this facility.
1.2 Metals QC Evaluation
Total metal spike recoveries were calculated for the twenty-three metals
spiked into four field samples (MQA434, 439, 448, and 450). Twenty metal
average spike recoveries were within the data quality objectives (DQO) for this
Program. The total aluminum average spike recovery was above DQO with a
recovery of 186 percent. The total selenium and thallium average spike
recoveries were below DQO with recoveries of 70 and 63 percent, respectively.
Various individual metal spike recoveries were also outside DQO. These are
listed in Table 3-2a of Reference 2 as well as in the following Sections. All
reported laboratory control sample (LCS) recoveries and all calibration
verification standard (CVS) recoveries were within Program DQOs.
The average relative percent differences (RPDs) for all metallic analytes
except aluminum and iron were within the DQOs.
Required analyses were performed on all metals samples submitted to the
laboratory.
No contamination was reported in the laboratory blanks. Sampling blanks
all contained metal contamination (barium, calcium, sodium, or zinc) including
field blank MQA440 which also showed mercury contamination at 0.2 ug/L.
1.3 Furnace Metals
The antimony, cadmium, and lead quality control was acceptable. All
antimony, cadmium, and lead results should be considered quantitative.
The arsenic spike recoveries for samples MQA434 and 439 (40 and 135
percent) were outside DQO, however, the average of the three arsenic spikes was
an acceptable 94 percent. Aluminum concentrations in the field samples should
not have affected the arsenic results because the laboratory used Zeeman
background correction. Overall, arsenic results should be considered semi-
quantitative.
High iron concentrations in some of the field samples should not have
affected the selenium results because the laboratory used Zeeman background
correction. The selenium spike recoveries for samples MQA434 and 450 were low
and below DQO (66 and 52 percent). The average recovery of the three se'lenium
spikes was also below DQO (70 percent). All selenium results should be
considered semi-quantitative and biased approximately 40 percent low due to low
spike recovery.
-------
Thallium spike recoveries for samples MQA434, 439, 448, and 450 were low
(61, 65, 63, and 63 percent, respectively). All thallium results should all be
considered to be biased low by approximately 35 percent and semi-quantitative
due to low spike recovery.
1.4 fCP Metals
Individual spike recoveries were outside DQO for aluminum in sample MQA448
(414 percent), calcium in sample MQA450 (127 percent), magnesium in sample
MQA450 (136 percent), manganese in sample MQA450 (127 percent), and sodium in
sample MQA450 (130 percent). High spike recoveries indicate results which are
biased high.
The TCP serial dilution results were outside DQO for barium, calcium,
magnesium, manganese, and sodium in sample MQA443. Results for these metals in
this sample should be considered semi-quantitative.
Although high sulfate concentrations were found in many of the samples it
does not appear to have interfered with the barium determination as barium
spikes were within DQO.
The low level (twice CRDL) linear range checks for chromium, copper,
nickel, and silver had poor recoveries. The accuracy reported for these
elements is not unexpected for results near the detection limit. All chromium
results, except those for sample MQA460, should be considered qualitative with
a bias ranging from minus 75 to plus 35 percent. Chromium results for sample
MQO460 should be considered to be quantitative. All copper results should be
considered semi-quantitative and biased high by approximately 15 percent. All
nickel results should be considered semi-quantitative. Nickel results for
samples MQA434, 445, 446, 447, 449, and 455 should be considered biased low by
approximately 12 percent. Nickel results for samples MQA436, 439, 440, 441,
442, 443, 444, 448, 450, 451, 452, 453, 454, 456, 457, 458, 459, 460, and 461
should be considered biased low by approximately 20 percent. All silver
results, except samples MQA434, 445, 446, 447, 449, and 455 which were not
affected, should be considered semi-quantitative and biased low by 15 to 65
percent. Silver results for samples MQA434, 445, 446, 447, 449, and 455 should
be considered quantitative.
Duplicate relative percent differences (RPDs) for iron and vanadium in
duplicate pair MQA456/458 and for sodium in duplicate pair MQA442/450 were
large. The sodium and vanadium results should be considered semi-quantitative
and the iron results qualitative.
iMatrix duplicate RPDs for aluminum and iron in sample MQA443 were outside
precision DQOs, Aluminum and iron results should be considered qualitative.
Beryllium, cobalt, potassium, and zinc results, as well as chromium
results for sample MQA460 and silver results for samples MQA434, 445, 446, 447,
449, and 455 should be considered quantitative. Barium, calcium, barium,
calcium, copper, magnesium, manganese, nickel, silver (with the above mentioned
exceptions), sodium, and vanadium results should be considered semi-
quantitative. Aluminum, iron, and chromium (with the above mentioned
exception) results should be considered qualitative.
-------
1.5 Mercury
Mercury blank contamination of 0.2 ug/L was found in one of the field
blanks but was not detected in any of the other field blanks or samples. All
mercury results should be considered quantitative with an acceptable
probability of false negatives.
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 (accuracy DQOs have not
been established for bromide and nitrite nitrogen matrix spikes but their
average recoveries were both 92 percent, which should be considered
acceptable). This indicates acceptable recoveries for all inorganic and
indicator analytei. 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. Contamination involving a variety of analytes was found in
three of the sampling blanks (MQA440, 452, and 454) at significant levels.
These contaminants and their concentrations are listed in Section 3.2.4 (page
3-3) of Reference 2.
2.3 Inorganic and Indicator Analvte Data
The quality control results for cyanide and bromide are acceptable. The
results for these analytes should be considered quantitative.
The holding times for the nitrate nitrogen analyses ranged from
approximately 4 to 13 days from receipt of samples which is significantly
longer than the recommended 48 hour holding time for unpreserved samples.
Field blank sample MQA440 was contaminated with nitrate nitrogen at 1200 ug/L
(24 times the DL). The nitrate nitrogen results should be considered
unreliable due to the blank contamination.
The holding times for the nitrite nitrogen analyses ranged from
approximately 4 to 13 days from receipt of samples which is significantly
longer than the recommended 48 hour holding time for unpreserved samples. The
nitrite nitrogen results should be considered to be serai-quantitative.
The RPD for chloride in both pairs of field duplicates (MQA442/450 and
MQA456/458) was large. Field blank sample MQA440 was contaminated with
-------
chloride at 10,000 ug/L (JOO times DL). Chloride results much greater than
J0,000 ug/L (samples MQA442, 448, and 458) should be considered qualitative
while all other lower results (all other samples) should be considered
unreliable.
The RPD for sulfate in both pairs of field duplicates (MQA442/450 and
MQA456/458) was large. Field blank sample MQA440 was contaminated with sulfate
at 3000 ug/L (30 times DL). Sulfate results between one and 30,000 ug/L
(samples MQA439, 443, 446, and 453) should be considered unreliable and all
other sulfate results should be considered qualitative.
One of four ammonia nitrogen matrix spikes (sample MQA448) was outside
DQO. The matrix spike/matrix spike duplicate RPD for sample MQA451 was outside
DQO although two others for ammonia nitrogen were within DQO. The ammonia
nitrogen RPDs for both pairs of field duplicates were large. Ammonia nitrogen
contamination was found in field blanks MQA440 (150 ug/L) and MQA454 (100
ug/L). These values are equal to or above the DL of 100 ug/L. Ammonia
nitrogen results for samples MQA443 and 446 are unreliable due to blank
contamination. All other ammonia nitrogen results should be considered
qualitative.
The total phenol RPDs for both pairs of field duplicates were large.
Total phenol contamination was found in field blanks MQA447 (32 ug/L) and
MQA454 (41 ug/L). These values are above the total phenol DL of 10 ug/L. All
total phenol results should be considered unreliable due blank contamination.
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 TOC RPD for one of the two pairs of field duplicates was high.
TOC contamination was found in blanks MQA445 (1000 ug/L), MQA447 (1200 ug/L),
MQA454 (1100 ug/L), and MQA461 (1200 ug/L). These values are equal to or above
the TOC DL of 1000 ug/L. The TOC results should be considered unreliable due
to blank contamination.
Initial calibration verification and continuing calibration verification
standards for POC were not analyzed. No calibration curve information was
supplied with the raw data. The POC results should be considered semi-
quantitative.
Instrument calibration data for TOX were not found for any of the
analytical batches although these standards were analyzed. Calibration
verification standards and blanks should 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 at least two analysis batches. This affects samples
MQA433, 434, 440, 441, 448, 452, and 453. High levels of chloride (above 200
mg/L) were found in only one sample and no TOX was detected in that sample.
Chloride interference is, therefore, not suspected with the TOX analysis. The
TOX results should be considered quantitative except for samples MQA433, 434,
440, 441, 448, 452, and 453 which should be considered serai-quantitative.
Calibration curve information was not reported in the POX raw data. A
three point calibration curve should be analyzed for each day's analytical
batches. Continuing calibration blanks (CCBs) were not analyzed frequently
enough and, along with continuing calibration verifications (CCVs), were not
-------
analyzed at the end of the analytical batches. The POX results should be
considered quantitative except for sample MQA460 which should be considered
semi-quantitative as there was no corresponding final CCV or CCB.
An initial and final calibration verification were the only calibration
verifications analyzed for carbonate/bicarbonate. A continuing calibration
verification should be analyzed every ten samples as well as at the beginning
and end of the analytical batch. Spike recovery for one of the four matrix
spikes (MQA448) was outside DQO. The RPD for one of the two sets of field
duplicates was large. The holding times for the carbonate/bicarbonate analyses
ranged from 24 hours to eight days. Although no holding time is specified for
this analysis, a 24 hour holding time is recommended. Results for samples
MQA433 and 436, which were analyzed in 24 hours, should be considered
quantitative while all other carbonate/bicarbonate results should be considered
semi-quantitative.
3.0 Oraanics 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 neither requested nor 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.
-------
Sample Q1222 was listed, by mistake, as sample Q1212 on the mass
calibration and tuning form (Form V) for 6/30/86.
Acetone was found in nine laboratory blanks at estimated values of 5 to 9
ug/L. The CRDL for acetone is 10 ug/L. Acetone results in this range should
be considered unreliable.
The volatiles data are acceptable. The probability of false negative
results for the volatiles is acceptable. The estimated detection limits for
the volatiles is the CRDL. The volatile compound results should be considered
to be quantitative.
3.4 Semivolatiles
Calibrations, tunings, blanks, matrix spikes, matrix spike duplicates,
surrogate spikes, and chromatograms were acceptable for the semivolatiles.
Unidentified compounds were found in two semivolatile method blanks at
concentration of 11 (estimated concentration) and 53 ug/L.
The matrix spike and matrix spike duplicate recovery of 1,2,4-
trichlorobenzene (103 and 104 percent) were above DQO (39 to 98 percent).
The surrogate percent recoveries for 2-fluorophenol in samples Q1228 and
QI229 (42 percent in each) were outside the DQO (43 to 116 percent).
The semivolatile data are acceptable and the results should be considered
quantitative. The probability of false negatives is acceptable. Estimated
semivolatile detection limits were twice CRDL for all samples.
3.5 Pesticide^
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.
Pesticide method blank chromatograms show slight contamination. Due to
the laboratory's 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 results should be considered to be
unreliable due to the lack of identification by the organic laboratosy of many
possible pesticide peaks in the chromatograms. There is an enhanced
probability of false negatives for pesticides.
-------
Data Usability Summary
4.0 praohite Furnace Metals
Quantitative: antimony, cadmium, and lead
Semi-quantitative: arsenic, selenium, and thallium
4.1 ICP Metals
Quantitative: beryllium, cobalt, potassium, zinc, chromium for sample MQA460,
and silver for samples MQA434, 445, 446, 447, 449, and 455
Semi-quantitative: barium, calcium, copper, magnesium, manganese, nickel,
sodium, and vanadium and silver with the above mentioned exceptions
Qualitative: aluminum and iron and chromium with the above mentioned
exception
4.2 Mercury
Quantitative: all mercury data
•4.3 Inorganic and Indicator Analvtes
Quantitative: cyanide and bromide, TOX and POX with exceptions, and
carbonate/bicarbonate for samples MQA433 and 436
Semi-quantitative: nitrite nitrogen, POC, TOX results for samples MQA433, 434,
440, 441, 448, 452, and 453, POX results for sample MQA460, and
carbonate/bicarbonate results with exceptions
Qualitative: chlorine results for samples MQA442, 450, and 448, sulfate
results with exceptions, and ammonia nitrogen results except for
samples MQA433 and 446
Unreliable: nitrate nitrogen, chloride with above mentioned exceptions,
sulfate results for samples MQA439, 443, 446, and 453, ammonia
nitrogen results for samples MQA433 and 446, total phenols, and TOC
4.4 Oraanics
Quantitative: all volatiles and semivolatiles results
Unreliable: all pesticides data
-------
Refcrtoces
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 (Revision) for Envirosafe, Idaho,
9/25/1986, 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 (Revision) and Draft Organic
Data Usability Report, for the Envirosafe, Idaho site, Prepared by Laboratory
Performance Monitoring Group, Lockheed Engineering and Management Services Co.,
Las Vegas, Nevada, for US EPA, EMSL/Las Vegas, 9/26/1986 and 9/23/1986.
-------
APPENDIX £
GROUND WATER ANAL/TICAL DATA FOR ORGANIC COMPOUNDS
DETECTED IN SILO WELLS
-------
APPENDIX £
GROUND WATER ANALYTICAL DATA FOR ORGANIC COMPOUNDS
DETECTED IN SILO WELLS
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