November 1987 «»• *fEPA-700 8-87-032
Hazardous Waste Ground-Water
Task Force
Evaluation of CECOS International, Inc.
Aber Road Facility
Williamsburg, Ohio
SB* ONoEFfc
l/S Environmental Protection Agency
Ohio Environmental Protection Agency
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NOVEMBER 1987
UPDATE OF THE HAZARDOUS WASTE GROUND-WATER TASK FORCE
EVALUATION OF CECOS INTERNATIONAL, INC.
The United States Environmental Protection Agency's Hazardous Waste Groundwater
Task Force ("Task Force"), in conjunction with the Ohio Environmental Protec-
tion Agency (OEPA), conducted an evaluation at the CECOS International, Incor-
porated (CECOS) hazardous waste disposal facility. The Task Force effort is in
response to recent concerns as to whether owners and operators of hazardous
waste disposal facilities are complying with the Resource Conservation and
Recovery Act (RCRA) groundwater monitoring regulations, and whether the ground-
water monitoring systems in place at the facilities are capable of detecting
contaminant releases from waste management units. CECOS is located near
Williamsburg, Ohio, which is just east of Cincinnati, Ohio. The on-site field
inspection was conducted over a two-week period from November 10 - 21, 1986.
This update of the Task Force evaluation summarizes subsequent events that are
directly related to hazardous waste groundwater monitoring issues.
The groundwater monitoring system which was in place during the Task Force
evaluation has been modified to accomodate new cells.
Since the Task Force site visit, technical review of CECOS's Part B permit
application has been ongoing. On July 22, 1987, U.S. EPA issued a Letter of
Warning and Notice of Deficiency to CECOS after having reviewed the application
submitted December 19, 1986, and finding a number of deficiencies. CECOS sub-
mitted a response to the Letter of Warning/Notice of Deficiency on September 4,
1987. On October 15, 1987, CECOS submitted a Part B which was a compilation
of its September 4, 1987, response and the December 19, 1986, Part B.
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U.S. EPA has reviewed the October 15, 1986, Part B, submitted by CECOS and has
determined that CECOS still has not submitted an adequate Part B permit applica-
tion.
Specifically, CECOS has not provided adequate identification of the uppermost
aquifer hydraulically interconnected beneath the facility property. Plates and
descriptions of the 880 sand are inconsistent or incorrectly illustrated to
demonstrate the aerial extent of the 880 sand.
CECOS has not; proposed an appropriate list of indicator parameters, waste constitu-
ents or reaction products that can provide a reliable indication of the presence
of hazardous constituents 1n the groundwater.,
CECOS has not provided a sufficient number of monitor wells installed at appro-
priate locations and depths to yield groundwater samples from tie uppermost
aquifer which represent the quality of background water that has not been
affected by leakage from a regulated unit or from dewatering activities.
Several monitoring wells designated by CECOS as upgradient are, in fact, either
currently downgradlent or, in the future, will be downgradient of the landfill
cells at the site.
CECOS has not provided a sufficient number of wells installed at appropriate
locations and depths to yield groundwater samples from the uppermost aquifer
that represent the quality of groundwater passing the point of compliance. The
groundwater monitoring system does not have an adequate number of downgradient
wells to monitor the channel sand deposit. The system does not provide for a
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"moveable point of compliance" which accounts for the lateral distance between
units, and provides for immediate detection of hazardous constituents for each
unit. The system fails to provide for proper well casing and screening mater-
ials.
CECOS has not proposed sampling collection, preservation, and shipment proced-
ures to ensure monitoring results that provide a reliable indication of ground-
water quality.
Finally, CECOS has not proposed statistical procedures which will provide
reasonable confidence that migration of hazardous constituents from a regulated
unit into and through the aquifer will be detected.
On September 25, 1987, CECOS and U.S. EPA signed an Administrative Order by
Consent pursuant to Section 3008(h) of RCRA.
In entering into this Consent Order, the mutual objectives of the U.S. EPA and
CECOS are: 1) to Implement selected Interim Measures deemed necessary by the
U.S. EPA and CECOS; 2) to review previously completed contamination studies,
perform additional contamination assessment activities, submit a RCRA Facility
Investigation (RFI) Report that fully describes the nature and releases of
hazardous wastes and/or hazardous constituents from the facility; and 3) to
review and refine previously submitted remedial evaluations, perform additional
evaluations, and provide these evaluations in a Corrective Measures Study (CMS)
that identifies the most appropriate methodology or methodologies for corrective
measures.
In response to implementing selected Interim Measures, CECOS has submitted for
U.S. EPA approval, a proposal for the construction of a landfill gas extraction
system. U.S. EPA is currently reviewing that proposal.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUND WATER TASK FORCE
GROUND WATER EVALUATION
CECOS INTERNATIONAL, INC
ABER ROAD FACILITY
WILLIAMS3URG, OHIO
NOVEMBER 1987
JOSEPH J. FREDLE
PROJECT COORDINATOR
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION -V
ENVIRONMENTAL SERVICES DIVISION
EASTERN DISTRICT OFFICE
WESTLAKE, OHIO
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TABLE OF CONTENTS
I. EXECUTIVE SUMMARY
A. Introduction 1
B. Objectives 1
C. Investigative Method 2
D. Facility Background Information 3
E. Summary of Findings and Conclusions 5
1. Geologic Characterization 5
2. Compliance with Interim Status Ground Water Monitoring
Requirements (40 CFR Part 265, Subpart F and Ohio
Revised Code 3745-65) 6
a. 40 CFR 265.90 - Ground Vater Monitoring System ... 6
1) 265.91 (a)(l) Humber of Upgradient Wells .... 6
2) 265.91 (a)(2) Number of Downgradient Wells .. 7
3) 265.91 (a)(3) Well Construction 7
b. 40 CFR 265.92 - Sampling and Analysis Plan 8
c. 40 CFR 265.93 - Preparation, Evaluation, and
Response 8
d. 40 CFR 265.94 - Recordkeeping and Reporting 9
3. Compliance with RCRA Permit Retirements (40 CFR Part
270 and Part 264 - Part A and Part B application).... 9
4. Ground Water Contamination (CECOS and Task Force analy-
tical data - prior or continuing releases) 10
5. Eligibility under the CERCLA Off-site Policy 10
6. Other Compliance Issues 11
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TABLE OF CONTENTS (Continued)
II. TECHNICAL REPORT
A. Introduction „ 12
B. Objectives „ 13
C. Investigative Methods 13
1. Technical Review Team 14
2. Lalxjratory Evaluation Team 15
3. Sampling Collection Team 15
D. Waste Management Units . 15
1. Introduction 15
2. Design of RCRA and TSCA Regulated Cells . 17
3. Surface Impoundments 19
a. Pirepond 1 and Firepond 2 19
b. Firepond 4/5 19
C. Solidification Basin 20
4. Spray Irrigation Areas 21
5. Hon-RCRA Units 21
a. Cell 1 21
b. Cell 2 21
C. Intermediate Cell 22
d. Firepond 3 22
e. Sanitary Landfill 22
E. Facility Operations 23
1. Waste Characterization 23
a. Introduction 23
b. Preacceptance 23
C. Acceptance Procedures (Waste Analysis Plan) 24
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TABLE OF CONTENTS (Continued)
E. Facility Operations (continued)
d. Discussion 27
2. Site Operation 29
a. Waste Disposal 29
b. Leachate Handling 29
c. Dewatering 30
d. Potential Runoff Contamination 30
F. Site Geology and Hydrogeology 31
1. Introduction 31
2. Glacial Tills 31
3. Sand Deposits 33
a. Upper Sand 34
b. 880 Sand 34
c. 850 Sand 35
d. 840 Sand 36
e. Bedrock\Tlll Interface 36
4. Hydraulic Conductivity 36
a. Upper Till Hydraulic Conductivity 37
b. 880 Sand Hydraulic Conductivity 37
c. Lower Till Hydraulic Conductivity 38
d. 850 Sand Hydraulic Conductivity 38
e. 840 Sand Hydraulic Conductivity 38
f. Bedrock Hydraulic Conductivity „. 39
5. Ground Vater Flow 39
a. Upper Till 40
b. 880 Sand 40
Hi
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TABLE OF CONTENTS (Continued)
F. Site Geology and Hydrogeology (continued)
e. Lower Till . . . 41
d. 840 Sand 42
e. Bedrock\Tlll Interface 42
6. Discussion „ 42
G. Compliance Under RCRA and TSCA 43
H. Ground Water Monitoring Program under RCRA Interim Status
and TSCA 46
1. Historic Ground Water Monitoring Systems 46
2. Proposed Ground Water Monitoring System 49
a. Uppermost Aquifer -. 50
b. Upgradient Wells 50
c. Downgradient Wells 51
d. Well Construction 51
3. Sampling and Analysis Plan 52
a. Sampling Plan 52
b. Sample Collection and Handling Procedures 53
4. Preparation, Evaluation and Response 60
I. Ground Water Monitoring Program Proposed for RCRA Permit.. 62
1. Introduction 62
2. Review off Current Submittal 63
a. 40 CFR 270.14 (c)(l) 64
b. 40 CFR 270.14 {c)(2J , 64
C. 40 CFR 270.14 (c)(3) 64
d. 40 CFR 270.14 (c){4) 64
e. 40 CFR 270.14 (c){5) 64
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TABLE OF CONTENTS (Continued)
I. Ground Water Monitoring Program Proposed for RCRA Permit
(continued)
f. 40 CFR 270.14 (c)(6) 65
g. 40 CFR 270.14 (c){7) and (8) 65
h. 40 CFR 264 (Part A Deficiencies) 65
i. 49 CFR 264 (Part B Deficiencies) 66
J. Off-site Laboratory Evaluation 67
K. Task Force Sampling 68
1. Method 68
2. Sample Locations 71
3. Quality Assurance and Control 72
4. Custody and Sample Handling 73
5. Scheduling 74
L. Ground Water Quality Interpretation 75
1. Task Force Analyses 75
2. Data Interpretation 76
a. Horthwest Area 76
b. Flrepond 4/5 - Sanitary Landfill 78
c. Cell 6 79
d. Well M-26 80
e. Underdrains 80
M. Summary 81
References 85
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TABLE OF CONTENTS (Continued)
Appendix A - Sampling Information
Appendix B - QA/QC Summary of Task Force Data
Appendix C - Analytical Results from Task Force Sampling;
Appendix D - Task Force Sampling Parameters
Appendix E - History of Waste Treatment, Storage, and
Disposal Units
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List of Figures
Figure 1 - Facility Location Map
Figure 2 - Site Map
Figure 3 - Task Force Chain-of-Custody Form
Figure 4 - Task Force Receipt of Sample Form
Figure 5 - CECOS's Waste Product Record
Figure 6 - Isopach Map of the Upper Sand
Figure 7 - Isopach Map of the 880 Sand
Figure 8 - Isopach Map of the 850 Sand
Figure 9 - Isopach Map of the 840 Sand
Figure 10 - Structure Map of the Top of Bedrock
Figure 11 - Potentlometric Map of the 880 Sand (taken
from Varzyn, 1986)
Figure 12 - Potentlometric Map of the Bedrock Till
Interface {taken from Varzyn, 1986)
Figure 13 - Location of Existing Wells and Borings and
Recommendations for Exploration Boring
Locations for the Eastern Portion of the
Site.
Figure 14 - Existing RCRA Ground Water Monitoring System
Figure 15 - Proposed RCRA Ground Water Monitoring System,
CECOS, November 1986
Figure 16 - RCRA Ground Water Monitoring System
Recommended by the Task Force
All Figures are located at the end of the report.
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List of Tables
Table 1 - Sample Bottle Type, Volumes, and Preserva-
tives used by the Task: Force
Table 2 - Hydraulic Conductivities of Various Strati-
graphic Units (taken from Varzyn, 1986)
Table 3 - List of Veils at the CECOS Aber Road facility
(as of May 1986)
Table 4 - Ground Vater Monitoring Systems for the Upper
Sand (Existing, Proposed, and RecommendedJ
Table 5 - Ground Vater Monitoring Systems for the 880
Sand (Existing, Proposed, and Recommended)
Table 6 - Ground Vater Monitoring Systems for the Lower
Till (Existing, Proposed, and Recommended)
Table 7 - Ground Vater Monitoring Systems for the Bedrock
Till Interface (Existing. Proposed, and Recommended)
Table 8 - Veil and Boring Depths in the Eastern Portion
of the Site
Table 9 - Comparison of TOI. TOC, pH, and total chromium
analytical results for the 880 Sand.
All Tables are located at the end of the report.
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EXECUTIVE SUMMARY
A. Introduction
Operations at hazardous waste treatment, storage, and
disposal (TSD) facilities are regulated under the Resource
Conservation and Recovery Act of 1976 (RCRA), 42 U.S.C. 6901 et.
sea. Implementing regulations issued on May 19, 1980, (40 CFR
Part 260 through 265, as modified), established operating
requirements for TSD facilities, including the monitoring of
ground water. The Administrator of the U.S. Environmental
Protection Agency (U.S. EPA) established a Hazardous Waste Ground
Water Task Force (referred to hereafter as the Task Force) to
evaluate the level of compliance with ground water monitoring
requirements at on-site and commercial off-site TSD facilities
and to address the cause(s) of noncompliance. In addition, the
Task Force is to examine the suitability of the TSD facility to
receive hazardous waste under the Comprehensive Environmental
Response and Liability Act (CERCLA) or Superfund program.
The Taslc Force is comprised of personnel from U.S. EPA
headquarters, U.S. EPA regional offices, and state environmental
agencies. This evaluation concerns the CECOS International, Inc.
(hereafter called CECOS), Aber Road facility, located north of
Williamsburg, Ohio. CECOS is an operating subsidiary of Browning-
Ferris Industries which is headquartered in Houston, Texas.
B. Objectives
The objectives of the Task Force evaluation at CECOS were
to: (1) determine compliance with the requirements of 40 CFR Part
265, Subpart F - Ground Water Monitoring (Ohio Administrative
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Code (OAC) 3745-65-90 through 3745-65-94) and 40 CFR 761; (2)
evaluate the facility's proposed ground water monitoring program
described in Part B of its RCRA permit application for compliance
with 40 CFR Part 270.14 (OAC 3745-70); (3) evaluate the
facility's potential compliance with 40 CFR Part 264, Subpart F
(OAC 3745-54); (4) verify the quality of the facility's ground
water monitoring data and evaluate the sampling and analysis
procedures; (5) determine if any ground water contamination
currently exists; and (6) determine if the facility is eligible
to receive waste under the Superfund Off-site Policy.
C. Investigative Methods
To accomplish the objectives, a facility Evaluation Team was
assembled. The Facility Evaluation Team was comprised of a
Management Team, a Technical Review Team, a Laboratory Evaluation
Team, and a Sample Collection Team.
The on-site facility inspection began on November 10, 1986,
and was conducted by three teams: the Management Team; the
Technical Review Team; and the Sampling Team. Off-site
inspections were conducted at contract laboratories by the
Laboratory Evaluation Team. The investigation methods used by
these teams are described in the technical portion of this
report.
The Task Force contracted with Planning Research Corporation
(PRC) of Chicago, Illinois, to prepare a document package of
pertinent background information from public information sources
(i.e., U.S. EPA and OEPA files). The information collected by PRC
concentrated on site activities since about 197EI (e.g..
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inspection reports, hydrogeologic reports, the Part B
application, etc.) and projected future activities. Information
obtained from CECOS during the evaluation was also reviewed to
supplement the information in the public files. Based upon
information from these sources, the technical review team
evaluated the facility with respect to the various ground water
monitoring requirements.
Unless specifically stated (e.g., the review of the Revised
Part B application, December 1986), the evaluation considers only
information available at the time of the evaluation (November
1986) .
D. Facility .Background Information
CECOS operates a waste management facility in Clermont
County, Ohio, located about five miles north of Williamsburg,
Ohio (see Figure 1 -please note that all figures and tables are
1 located in the back of the report). RCRA hazardous wastes,
wastes containing polychlorinated biphenyls (PCB's) regulated by
the Toxic Substances Control Act (TSCA), and other nonliquid
wastes are landfilled in lined cells.
CECOS has nine filled cells (Cells 1-8 plus the Intermediate
Cell) which are closed or are being closed. Cells 9 (nearly
full) and 10 were the active cells at the time of the evaluation.
.CECOS has proposed building seven additional cells (11 through
17). In addition to the cells described above, other units at the
facility include (or have included in the past) a closed sanitary
landfill, three RCRA surface impoundments (Fireponds 1, 3, and
4/5), the Solidification Basin, and four spray irrigation areas.
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Figure 2 shows the location of the units described above that
existed at the time of the Tasfc Force Inspection. The
Solidification Basin, spray irrigation areas, and Firepond 3 no
longer exist. See Appendix E, pages 38 through 40 for the
location of the Solidification Basin and spray irrigation areas.
Firepond 3 was located where Cell 4/5 currently exists.
Cells 3 through 10 contain wastes which are regulated by 40
CFR Part 265 (RCRA) and 40 CFR Part 761 (TSCA). Cells 1 and 2
and the Intermediate Cell were closed before the effective date
of the RCRA regulations. Cells 3, 4/5, 6, and 7 were closed in
accordance with the provisions of the regulations cited above.
Cell 8 is currently being closed. A closure plan has been
approved for Firepond 1 by the Ohio EPA. Cells 9 and 10, the
active cells, are located in the northeast corner of the site.
Cell 11 was partially constructed at the time of the evaluation.
The construction of Cell 11 was delayed because of the discovery
of a significant water-producing deposit, the 850 Sand, at or
near the bottom of the excavation. Areas designated as cells 12
through 17 on Figure 2 are planned future cells. The Intermediate
Cell contains waste which would be considered hazardous waste
under RCRA. However, the Intermediate Cell was closed prior to
the effective dates of RCRA. The Sanitary Landfill was closed in
1982. Under the Hazardous and Solid Waste Amendments of 1984,
V
these units are considered solid waste management units. As such
they are subject to corrective action under 40 CFR 264.101 and
Sections 3004 (u) and 3008 (h) of RCRA.
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The facility is located in a rural setting in which adjacent
land is used for agricultural purposes. Residences on Aber Road
use a public water supply. Other homes around the facility obtain
potable water from individual private wells.
E. Summary of Findings and Conclusions
1. Geologic Characterization
The Task Force determined that the areas beneath Cells 8, 9,
10, 11, and beneath the dewatering retention ponds (i.e., the
eastern portion of the site) lack adequate geologic
characterization between bedrock and an elevation of about 845
feet. With the exception of the area immediately around proposed
Cell 11 and a few scattered wells, borings and wells in this
portion of the site do not reach to bedrock and offer no
information concerning any lower till sands which may be present
between bedrock and an elevation of 845 feet (above mean sea
level). The Task Force recommends that continuous borings be
drilled throughout this area to determine the presence and extent
of lower till sands (e.g., the sand that occurs at an elevation
of 840 feet above rasl).
The remainder of the site appears to be adequately
characterized in terms of the geology, but due to the complex
nature of the glacial stratigraphy, the Task Force recommends
that all future borings should be continuously sampled and
logged except those adjacent to previous borings which were
continuously sampled.
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2. Compliance with Interim Status Ground Water Monitoring
Requirements (40 CFR Part 265, Subpart F and Ohio
Administrative Code 3745-65)
a. 40 CFR 265.90 - Ground Water Monitoring System. CECOS was
implementing a ground water quality assessment program
(assessment monitoring) at the time of the Task Force Evaluation.
The Task Force determined that neither the existing nor the
proposed ground water monitoring system (see tables 4 through 7)
is adequate to satisfy the requirements of assessment monitoring
under 40 CFR Part 265. The major deficiencies Included the
inadequate placement of upgradient and downgradient wells, the
need for additional wells to determine the extent of
contamination, and the need to measure static ground water levels
over a shorter period of time.
(1) 255.91 (aldl Number of' Upgradlent Wells. The Task Force
concluded that there is not a sufficient number of upgradient
wells capable of yielding representative background samples of
ground water quality. Historically well M 15 (screened in the 880
«
Sand) has been considered upgradient. Dewatering activities have
changed the gradient such that this well can no longer be
considered upgradient. Ground water quality studies (Warzyn,
1986) indicate water quality is highly variable between the
different stratigraphic zones. Based upon these findings, the
Task Force concluded that several upgradient well nests are
needed to adequately characterize background water quality in
each monitoring zones above bedrock. They must be located such
that future dewatering activities will not transform these wells
into downgradient wells.
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(2) 2.65.91 (aj(2) - Number of Downaradient Wells. The Task
Force concluded that the number of downgradient wells in the
existing ground water monitoring system is inadequate. The
placement of the existing wells is' not capable of effectively
monitoring the contaminant flow pattern at the site. In addition,
the construction of some of the wells is inadequate. CECOS has
proposed a single comprehensive Ground Water Monitoring Program
(November, 1986) that includes a more comprehensive" monitoring
system. Task Force determined that the proposed system does not
have sufficient numbers of properly located wells to immediately
detect and assess contamination from the existing cells into all
of the potentially affected sand deposits. The Task Force also
finds that the changing flow patterns at the site caused by
dewatering activities will require CECCG to continually reassess
both placement and numbers of wells to insure effective
monitoring.
(31 265.91 (al(3) - Well Construction. CECOS has an older
series of wells, the M series, which should be plugged and
abandoned immediately unless they are suitable for water level
measurement (i.e., wells with no greater than 15 foot screen
lengths and which monitor only one one sand deposit). The newer
MP series wells comprise most of the existing monitoring system
at CECOS. These wells are generally of better design and
construction. However, some of the early MP series wells
experienced grout contamination and were subsequently replaced.
The Tasfc Force recommends that future wells be constructed
with inert casing materials. Because of the nature of the wastes
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landfilled at CECOS, stainless steel or perfluorocarbons are the
most suitable materials. The Task Force does not find it
necessary to replace existing wells solely because they are
constructed with PVC casing.-
b. 40 CFR 265.92 - Sampling and Analysis Plan. The Tasfc Force
found the sampling and analysis plan to be inadequate. The
current plan is comprised of several documents, which
occasionally are contradictory. The sampling protocols are not
fully detailed. For example, there is no sample collection order
specified (i.e., volatile organics first). The Taste Force
concluded that the various documents must be consolidated into a
single plan and the contradictions eliminated. In addition, the
plan must specify the sampling frequency and should require that
water level measurements be obtained from all wells to be sampled
over a set period of time (i.e., a few days) before sampling
begins.
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c. 40 CFR 265.93 - Preparation. Evaluation, and Response.
CECOS has been following a ground water quality assessment plan
since August 1985. A report completed in accordance with the plan
indicated more information on the extent of. contamination is
needed {Warzyn, 1986).
The Tasfc Force concluded that the existing and proposed
monitoring systems (November 1986) are not capable of determining
extent of contaminant migration. To achieve compliance,
additional wells are needed.
Water level measurements for assessment monitoring were
conducted by CECOS in October of 1986, after Warzyn completed its
8
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study. These measurements were taken over a one month period,
therefore, rate and direction of ground water flow may not be
adequately determined. Water level measurements should be taken
each quarter over a shorter period of time (i.e., five
consecutive days at all wells to be sampled) to accurately
determine the rate and direction of ground water flow.
d. 40 CFR 265.94 - Recordkeeplnq and Reporting. There have
been several changes in the dewatering configuration through time
which have caused changes in ground water flow directions and
rates. CECOS did not have maps or records that accurately
documented these changes. As stated above, information of this
type must be collected to insure the ground water monitoring
system does not require modification due to effects of the
dewatering program.
3. Compliance with RCRA Permit Requirements (40 CFR
Part 270 and Part 264 - Part A and B application)
The Tasfc Force reviewed the revised Part B of the hazardous
waste permit application which was submitted on December 22,
1986, and found it to be inadequate. Inadequacies exist in
nearly every section of the application.
The detection monitoring system proposed in Part B of the
December 1986 submittal of the RCRA permit application is very
similar to the Proposed Monitoring System (November 1986) for
Interim Status. However, no attempt was made in the Part B to
discuss either a compliance (40CFR 264.99) or a corrective action
(40 CFR 264.100 - 101} monitoring program for that portion of the
facility where there is evidence of ground water contamination.
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The Task Force determined that the proposed systems J!or 40 CFR
264 (RCRA permit) was inadequate.
Other deficiencies in the application noted by the Task
Force are associated with the waste analysis plan, contingency
plan, and closure plans (refer to Technical Report for details).
4. Groundwater Contamination (CECOS and Task Force
analytical data - prior or continuing releases)
The Task Force has concluded that there is evidence of
contaminant releases near Firepond 1, the Sanitary Landfill, the
Intermediate Landfill, and Cells 1, 2, 3, and 4/5. Further
investigation into the source and extent of these releases is
necessary to determine what corrective measures .are needed.
Also, the source of organic contaminants in wells MP 227 and M 26
and total selenium in the underdrains needs to be investigated
further.
5. Eligibility under the CEHCLA Off-site Policy
The Superfund Amendments and Reauthorization Act (SARA)
imposed specific requirements on land disposal facilities,
Specifi. Section 121 (d)(3)(B) requires that all releases
from any unit (hazardous or nonhazardous) at a land disposal
facility be addressed by an enforceable corrective action program
(permit, order, or consent decree) in order for that facility to
receive Superfund waste. Releases of hazardous constituents have
been documented in the vicinity of the Sanitary Landfill, the
Intermediate Cell, Cells 1, 2, 3, 4/5, and the surface
impoundments. Thus, the Task force recommends that the Regional
10
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Administrator of the U.S. EPA Region V take this Information into
consideration when determining compliance with this policy.
6. Other Compliance Issues
An additional area of noncompliance was noted by the Tasfc
Force. The Solidification Basin was operated as a hazardous
waste management unit during 1981 without having been identified
on Part A of the application for a RCRA permit. Additionally, a
closure plan has never been submitted to the U.S. EPA or Ohio EPA
for this unit.
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TECHNICAL REPORT
A. Introduction
Operations at hazardous waste treatment, storage, and
disposal (TSD) facilities are regulated by the Resource
Conservation and Recovery Act (RCRA) (42 U.S.C. 6901 et sea.).
Regulations issued pursuant to RCRA (40 CFR Parts 260 through
268) address waste site operations, including monitoring of
ground water, to ensure that hazardous waste and hazardous waste
constituents do not escape undetected into the environment.
The Administrator of the U.S. Environmental Protection
Agency (U.S. EPA) established a Hazardous Waste Ground Water Task
Force (referred to hereafter as the Task Force) to evaluate the
levels of compliance with ground water monitoring requirements at
on-site and commercial off-site TSD facilities and to address the
causes of noncompliance. In addition, the Task Force examines
the suitability of the facilities as a provider of treatment,
storage, or disposal services for waste managed by the U.S. EPA's
Superfund program. The TasJc Force is comprised of personnel from
U.S. EPA Headquarters, U.S. EPA Regional offices, and the States.
Sixty TSD facilities are scheduled for ground water evaluations.
One of these is the CECOS International, Inc., Aber Road facility
near Williamsburg, Ohio (CECOS).
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B. Objectives
The objectives of the Task Force evaluation at CECOS were
to:
* Determine compliance with the requirements of 40 CFR Part
265, Subpart F (Ohio Administrative Code 3745-65) and 40
CFR Part 761 (Toxic Substances Control Act (TSCAJ).
* Evaluate the facility's proposed ground water monitoring
program as described in the Part B of the RCRA permit
application for compliance with 40 CFR 270.14 (c) ( OAC
3745-70) .
* Evaluate the facility's potential compliance with 40 CFR
Part 264, Subpart F (OAC 3745-55).
* Verify the quality of the facility's ground water
monitoring data and evaluate sampling and analytical
procedures .
* Determine if any ground water contamination currently
exists .
* Determine If the this aite is eligible to dispose of
CERCLA (Superfund) waste.
C_, _ Investigativ
The Tas)c Force investigation at CECOS consisted of:
* Reviewing and evaluating records and documents from
U.S. EPA-Region V and Ohio EPA files, and provided by
CECOS during the on-slte Inspection.
* Conducting an on-slte Inspection from November 10 through
21, 1986.
* Evaluating two off-site laboratories utilized by CECOS
for the analysis of past and present ground water samples
* Sampling and analysis of ground water from monitoring
wells and underdrains at CECOS.
To accomplish the objectives, a Facility Evaluation Team was
assembled, and was comprised of a Technical Review Team, a
Laboratory Evaluation Team and a Sample Collection Team.
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1. Technical Review Team
The Technical Review Team conducted the evaluation of the
facility with respect to applicable ground water monitoring
regulations. The team's objective was to determine compliance
with 40 CFR Part 265, Subpart F; 40 CFR Part 761 (TSCA);
potential compliance with 40 CFR Part 264, Subpart F; and
compliance with 40 CFR 270.14 (c). The evaluation focused on the
following six areas:
1. waste characterization and operations;
2. site history and design;
3. site geology and hydrogeology;
4. ground water monitoring system adequacy;
5. ground water sampling and analysis procedures; and
6. ground water quality data and interpretation.
The Task Force core team in Washington, D.C. contracted with
Planning Research Corporation (PRC) of Chicago, Illinois, to
prepare a document package of pertinent background information.
The information collected by PRC concentrated primarily on past
inspections and submittals (e.g., inspection reports,
hydrogeologic reports, and Part B of CECOS's RCRA permit
application). Information obtained from CECOS during the Task
Force evaluation was also reviewed to supplement the information
in the public files. By combining these information sources, the
Technical Review Team performed a complete evaluation of the
facility records with respect to the ground water monitoring
program.
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2, Laboratory Evaluation Team
The off-site laboratories that analyze or have' analyzed
samples for CECOS were evaluated by the U.S. EPA, Region V,
Quality Assurance Office. The laboratories evaluated were Howard
Laboratories, Inc., of Dayton, Ohio, and Environmental Testing
and Certification Corporation (ETC) of Edison, New Jersey.
3. Sample Collection Team
Samples for the Tas)c Force evaluation at CECOS were
collected by Versar, Inc., (referred to hereafter as Versar), a
U.S. EPA contractor, under the supervision of U.S. EPA personnel.
D. Waste Management Units
1.. Introduction
CECOS has treated, stored and disposed of RCRA regulated
hazardous waste at the Aber Road facility utilizing the following
techniques:
1. land disposal of waste (hazardous and nonhazardous) by
landfilling
2. storage and treatment of hazardous waste In surface
impoundments
3. storage of hazardous waste in a drum storage area
4. storage of leachate in large tanks
5. land treatment of hazardous waste through spray
irrigation.
In addition, CECOS has had authorization to dispose of waste
containing polychlorinated biphenyls (PCBs) since September 1979.
The hazardous waste units in which the above activities
occurred were active after November 19, 1980, and are regulated
by the applicable provisions of RCRA. Many of these units also
15
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contain PCB's and are also regulated by applicable provisions of
TSCA. Cells 3 through 10 are considered RCRA hazardous waste
disposal cells and are also authorized TSCA units. Fireponds 1
(combined with Firepond 2) and 4/5, and the Old Solidification
Basin (all surface impoundments) have been used to store and/or
treat leachate and contaminated runoff. These fireponds are no
longer used. The Solidification Basin was filled and covered in
1981. Although required to under RCRA, this unit did not go
through formal RCRA closure pursuant to 40 CFR Part 265, Subpart
G. RCRA closure of Fireponds 1 and 4/5 is planned. Two spray
irrigation fields (Areas C and D) were used to treat
contaminated water and sludge between 1980 and 1984 (Cells 8, 9,
and 10 were constructed in the areas were spray fields C and D
were located).
Cells 1 and 2, Firepond 3 (no longer existing), and the
Intermediate Cell were closed prior to the effective date of
RCRA regulations. The Sanitary Landfill reportedly did not
receive.hazardous waste after November 19, 1980. Therefore, these
disposal units are not regulated as active portions of the
facility, but are considered solid waste management units under
the Hazardous and Solid Waste Amendments of 1984 (HSWA), 40 CFR
Part 264.101, and Sections 3004 (u) and 3008 (h) of RCRA.
Figure 2 shows the location of the units described above
that existed at the time of the Tasfc Force inspection. The
Solidification Basin, spray irrigation areas, and Firepond 3 no
longer exist. See Appendix E, pages 38 through 40 for the
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location of the Solidification Basin and spray irrigation areas.
Firepond 3 was located where Cell 4/5 currently exists.
A history of these solid and hazardous waste management
units was supplied by CECOS during the Task Force Evaluation
(Appendix E) and is summarized below. CECOS refers to the hazar-
dous waste landfills (RCRA, TSCA and pre-RCRA) in Appendix E as
"Secure Chemical Management Facilities" (SCMF). In past reports
(e.g. Bennett arid Williams, 1985 and Warzyn, 1986] and in this
report the hazardous waste landfill units are called cells.
According to the facility's revised Part A application
(December 1.986 submittal), the design capacity for all of the
hazardous waste cells is 1,923 acre-feet At the time of the
Task Force evaluation, this volume was to be distributed among 17
cells. Of these 17 cells, eight were closed, two were active,
and seven w«re planned. The total volume landfllled at the time
of the Task Force evaluation was about 774.0 acre-feet. The
' actual land area occupied by the facility is about 211 acres.
2. Degion of RCRA and TSCA Regulated Cells
Cell 3 measures 300 by 300 feet and Cell 4/5 is 300 feet.
wide by 500 feet long. Both of these cells are approximately 26
feet deep. All of the remaining cells, 6 through 10, are
approximately 500 'to 550 feet square and 50 feet deep. The
locations of these cells are shown on Figure 2.
Cells 4/5 through 10 were constructed with at least one
layer of recompacted fine-grained glacial sediments along the
bottom and the sidewalls. Cell 3 had recompacted glacial
sediments along the bottom only. CECOS refers to this as a
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recompacted lining. For units with no recompacted glacial
sediment liner, CECOS uses the term "natural" lining. The fine
grained materials used to construct the recompacted liners were
obtained from the glacial sediments deposited at the site.
Cells 3 through 9 are lined with a single synthetic liner
{"Hypalon" or High Density Polyethylene (HOPE)) that ranges in
thickness from 30 to 80 mil (a mil equals 1/1,000 of an inch).
Cell 10 has primary and secondary synthetic liners made of 80 mil
HOPE. The secondary liner extends across the base of the cell
and up the sidewall to a height of one foot above the primary
liner.
Leak detection systems, constructed of PVC or HOPE pipe and
sand, were installed under Cells 9 and 10 to detect any leakage
which could pass through the primary synthetic liner. In Cell 9,
the leak detection system is located between two lower
recompacted liners. In Cell 10 it is located between the primary
and secondary synthetic liners. Leak detection systems were not
installed under Cells 3 through 8.
Underdrains were required to be installed beneath the bottom
liner of Cells 3 through 10 as part of U.S. EPA's approval for
PCS disposal under TSCA. They are constructed with PVC pipe,
stone, in some cases geotext^le, and riser pipes. Underdrains
may serve to indicate leakage from the cells. The underdrain
systems beneath some cells have been used for monitoring the
ground water. If a liner fails, evidence of contamination is
likely to be found in the underdrain system.
A leachate collection system was installed within each of
the RCRA cells. Cells 3 and 4/5 have concrete standpipes (24
18
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inches in diameter) which were installed to collect leachate
after waste was placed within the cells. The newer cells (6
through 10) were built with a PVC pipe network placed within
stone above the primary liner. A polyethylene drainage net was
placed on the sidewalls of these cells to facilitate drainage.
Three to five 36-inch standpipes were built into these five cells
to collect leachate from the PVC pipe network. The standpipes
were constructed of reinforced perforated concrete which was
wrapped in a geotextile and surrounded by crushed stone.
There are three subcells within each cell. These are: (1) an
amphoteric subcell (i.e., for substances that act as acids or
bases); (2) a heavy metal subcell; and (3) a general subcell.
Subcell reconfigurations were made in some of the cells while
they were being filled (see Appendix E).
3, Surface Impoundments
a. Firepond 1 &Flrepond 2. Firepond 1 and 2 were origi-
nally built for fire protection and water containment in 1977
(along with Cell 1). It was later used to store and treat lea-
chate from closed disposal cells. Firepond 1 was combined with
Firepond 2 by removal of a soil berm between them in 1980.
Individually, these unlined ponds were both approximately 80 feet
square in surface area and 8 feet deep. CECOS plans to close
these ponds consistent with an Ohio EPA-approved closure plan
after a new leachate tank farm has been constructed.
b. Firepond 4/5. Firepond 4/5 was constructed in 1979 at the
same time as Cell 4/5. It is about 220 feet by 170 feet in
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surface area and 13 feet deep, and is unlined. This pond was
intended to store potentially contaminated rainwater which fell
in the active cell and was pumped from the cell shortly after
accumulation. Analytical data indicate that some of this
potentially contaminated rainwater would meet the definition of
leachate. The firepond is currently available for emergency
purposes and a RCRA closure plan is being prepared.
c. Solidification Basin. The solidification basin was used
between July and December 1981 and therefore is a RCRA unit. It
was approximately 200 feet square in surface area and 5 to 6 feet
deep (2 feet below grade), with soil berms as sidewalls, and was
unlined. The basin was divided into three sections by two
internal soil berms.
Leachate from Firepond 1 was pumped into the solidification
basin and solidified with high calcium oxide lime and sodium
silicate. The solidified material was then placed in Cell 6.
•CECOS reports that all wastes and contaminated soil were removed
and placed into Cell 6 before clean on-site soil was placed into
the basin area {Appendix E). However, during the construction of
an equipment shed, buried waste was encountered.
The location of the solidification basin is shown in
enclosures 3 and 4 (pages 38 and 39) of Appendix E. This unit
was not identified on CECOS's application for a RCRA hazardous
waste permit. A closure plan has not been submitted to the U.S.
EPA or the Ohio EPA.
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4. Sorav Irrigation Areas.
CECOS had a permit from the Ohio EPA to operate four fields
for spray irrigation from September 1980 through October 1984.
These fields were identified as Fields A, B, C, and D (for the
location of these fields, Appendix E, page 40). Fields A and B
were reportedly•never used. All of Field D was used and a portion
of Field C was used between fall 1980 and October 1984.
Potentially contaminated water from Firepond 4/5, leachate from
the Sanitary Landfill (also called "Tri Pit" water), and Clermont
County sewage sludge (waste water treatment plant source unknown)
were the principal materials sprayed onto the fields The top
six inches ' of soil from Field D were stripped off and used in
Cells 8 and 9 as daily cover or placed in Firepond 4/5. It. is not
fcnown what was done with the topsoil from Field C.
5, Non-RCRA Units
a. Cel 1 L. Cell 1 was constructed and filled with "indus-
trial waste" (predominantly paint sludges in drums) in 1977. It
la about 30 feet wide, 50 feet long, 18 feet deep, and does not
have a liner. There are grid charts at the facility which
indicate where waste was placed within Cells 1 and 2.
b. Cell. 2. Cell 2 was built between 1977 and 1978 and
filled in 1978. It varies from 60 to 90 feet in width (at
opposite ends) and is about 515 feet long and" 25 feet deep. It
does not have any lining, lealc detection system, underdrains, or
a subcell design. Two 24-inch reinforced concrete standpipes
were installed (date unknown) to collect leachate after the cell
was closed.
21
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ct Intermediate Cell. The Intermediate Cell was filled
between 1977 and 1979. This cell actually consists of many
individual trenches excavated for specific waste streams. The
trenches are estimated to be 12 feet wide by 30 feet long and 25
feet deep. There is no liner, leak detection system, or
underdrain. CECOS maintains a map on site showing the general
waste types and trench locations.
d. Firepond No. 3. This pond was constructed along with
Cell 3 (1978) and measured about 250 feet by 100 feet in surface
area. Firepond 3 was 8 feet deep. This firepond had no liner and
was removed during the construction of Cell 4/5 in September of
1979 .
e. Sanitary .Landfill. The Sanitary Landfill was used be-
tween 1972 and 1982. It is approximately 19 acres in area, and no
liners were installed. Three leachate standpipes were installed
•in 1985 and three more were being installed on the north side of
the landfill at the time of the TasJc Force evaluation. According
to CECOS (Appendix E), waste disposed in the Sanitary Landfill
included:
* sanitary solid waste
* household waste
* "Bio sludge" from DuPont
* waste water treatment sludge from a General Motors Plant
in Norwood, Ohio;
* "Bio sludge" from Procter and Gamble.
The Sanitary landfill included an small pond called the "Tri
Pit". This area was used to solidify liquids (composition
22
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unknown]. It was later covered and incorporated into the
landfill.
E. Facility Operations
I, Waste Characterization
a. Introduction. CECOS receives, treats, and stores waste
defined as hazardous in 40 CFR Part 261, including; ignitable,
reactive, corrosive, and E.P. toxic wastes. PCB wastes are also
disposed at this facility under the provisions of TSCA. CECOS
reports that it does not accept materials which are radioactive,
pyrophoric, biologically infectious, shock sensitive, explosive,
or reactive with air or water.
b . Preacceptance. CECOS requires a "Waste Product Record"
(WPR) form to be completed by the waste generator prior to each
waste stream being sent to CECOS (see Figure 5). Data requested
on this form are intended to the provide the information
•necessary for CECOS to treat, store, or dispose of the waste in
accordance with the requirements of RCRA and TSCA. The WPR
contains the waste stream description, chemical composition
(components and their concentrations), the EPA hazzirdous waste
number, «hlpping retirements, a certification by a
representative of the generator that the information is true and
accurate, and a section for approval (with any special
conditions) by the Ohio EPA. No sampling and analysis procedures
are supplied on the WPR to indicate how the generator sampled or
analyzed the waste stream.
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c. Acceptance Procedures (Waste Analysis . Planl. CECOS's
handling procedure for wastes, from preacceptance to disposal,
is described in the waste analysis plan (WAP). The Task Force
reviewed the waste acceptance procedures in the WAP that CECOS
was using at the time of the evaluation. Based upon this review
the Task Force determined that the procedures in the WAP are
inadequate to meet the requirements of 40 CFR 265.13. In
addition, the inadequate plan is not being followed. Problems are
associated with both preacceptance and acceptance procedures at
the facility.
The WAP used at the time of the Task Force evaluation
(primary document) was dated September 19, 1983. It is not known
what document may have been used prior to this. Since the
primary document was issued, the plan has been revised by adding
addenda (about 33) as new techniques or procedures were initiated
at the facility.
The Task Force concluded that the WAP must be rewritten.
Much of the information in the plan is repetitive or irrelevant.
For example, the section discussing bulk free liquid sampling
and solidification (page 31 and addendum 33) is not needed
because this process has not been conducted at the Aber Road
facility for several years. Several other sections appear to be
outdated and should be removed.
The WAP in the December 1986 submittal of Part B of the RCRA
application is more concise than the plan being used at the
facility during the Task Force inspection. Much of the irrelevant
information has been excised. However, deficiencies continue to
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exist the in this revised WAP as well (See Section I. 2., page
63, "Review of Current Submittal").
The WAP describes inspection, sampling, and "fingerprinting"
procedures to be conducted on each load of hazardous waste
entering th« facility. The Task Force observed one bulk load and
one barrel load being inspected, sampled and fingerprinted during
the site evaluation. Based upon these observations, the Task
Force believes that, with the methods specified in the WAP, CECOS
cannot identify off-specification waste that might come into the
facility. The Task Force noted that in several cases the WAP was
not being followed.
According to the WAP, four grab samples are to be taken from
four different locations in the bulk loads using a steel rod core
sampler or thief sampler and composited. Samples are to be taken
"through the waste".
The Task Force observed a bulk load of contaminated soil as
'it was being inspected and sampled. The technician who sampled
the load took three scoops from the waste surface at the center
of the load. He did not sample "through the waste" as the plan
specifies. This sampling was not in accordance with the WAP and
cannot be considered to generate representative samples. The
plan should be followed so that a representative composite
sample is collected randomly (as specified in the document Test
Methods for Evaluating Solid Waste (SW-846)) and should include
some portions of waste taken at or near the bottom o:f the load.
When attempting to gather a representative sample from a load of
bulk waste, samples should be taken vertically through the waste.
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The WAP states that when containerized waste arrives the
containers- are to be counted, .checked for free liquids (which
involves tapping the container with a steel rod), and a
percentage of the barrels is to be opened. The percentage to be
opened is not clearly stated. In the plan which the Task Force
reviewed, "10 *" was typed into the plan, but was later deleted
(i.e., scratched out) and "15 *" substituted. From one or two
drums a representative sample is to be collected and composited
for fingerprinting. As with bulk loads, a steel rod core sampler
or thief is to be pushed through the waste for sampling purposes.
The Task Force observed the sampling of a load of drummed
waste and found problems similar to those noted with bulk loads.
Less than 10 * of the barrels (four out of forty-two barrels) were
opened. The technician taking the sample for fingerprinting
grabbed it from the top of one barrel. Only barrels with bung
holes (i.e., twist-out caps located on the lid) were opened.
CECOS analyzes samples of incoming wastes at an on-site
laboratory for the following characteristics:
* pH
* ignitability
* presence of free liquids
* reactivity with water
* compatibility with samples from previous loads of waste
* generation of cyanide gas
* load-bearing capacity
The pH is tested with litmus paper to determine if it is
between 6 and 9. If it is found to be outside this range, it is
26
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then tested with a pK meter. If the waste is not liquid, the pH
is obtained by mixing a small portion of the sample in deionized
water.
Ignitability is determined by passing a match flame beneath
the sample.
The presence of free liquids is tested using the paint
filter test (SW-846 Method 9095). This test is conducted only if
liquids are suspected (i.e., the load appears wet).
A portion of the sample is sprayed with deionized water to
determine if it is water-reactive. Similarly, a portion of the
sample is mixed with a composite sample ("running mixture") made
from previous loads to see if it is compatible with wastes
already placed into the cell. The composite sample being created
at the time of the Tas)c Force Investigation was begun on November
11 , 1986 .
If the generator indicates that the waste may contain
•cyanide, CECOS will test the sample for the ability to generate
free hydrogen cyanide.
Load-bearing capacity is required to be tested by the Ohio
EPA. The test is conducted using a hand-held penetrometer. This
test is required only when specified by the on-site Ohio EPA
representatives on the approved VPR.
d. Discussion. The fingerprinting procedures used by CECOS
are inadequate to characterize incoming waste. As indicated
above, the Tasfc Force has concerns regarding whether the samples
collected are representative of entire shipments.
27
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A CECOS representative indicated that the fingerprinting
procedures described above were used to quickly check the waste
to see that it matches the manifest, the WPR, and to insure that
it is safe to handle by facility personnel. CECOS contends that
the generator is responsible for identifying the waste on the WPR
and the manifest that is being forwarded to CECOS and that the
company is not liable for misidentified waste disposed at the
facility.
The Task Force strongly disagrees with the concept that
generators bear sole responsibility to insure proper
identification and classification of waste being disposed at the
facility. If CECOS chooses to rely upon information supplied by
generators to identify and classify waste, then standard methods
to analyze the waste must be used by the generator and a copy of
any laboratory analyses must be attached to the WPR.
•Additionally, some detailed analyses must be conducted on-site by
•CECOS to verify information supplied by generators.
The Hazardous and Solid Waste Amendments of 1984 (HSWA)
place restrictions on the land disposal of some wastes (e.g.,
F001 through F005 code wastes). The WPR must clearly identify how
the waste was classified to insure that it is not a restricted
waste, or, if It is a restricted waste, how it was treated (and
by whom) to meet applicable land disposal concentration limits.
CECOS representatives should verify that a generator has properly
identified and classified waste streams that are being shipped
and disposed at the facility. Additionally. some confirmatory
analyses are necessary to verify that restricted wastes which
28
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have been treated meet the applicable treatment standard found In
40 CFR Part 268.
2. Site Operations
a. Waste Disposal. After a sample from the load has been
fingerprinted and the load has been approved for acceptance, an
on-site waste tracking form is completed, indicating the selected
disposal subcell. This form is then given to the driver of the
truck. The driver proceeds to the specified cell and presents
this form to the cell operations foreman to demonstrate that the
load has been approved for disposal. During disposal, the
foreman specifies on the tracking sheet the location where the
waste is placed within the cell A grid system and depth
determination using a transit is utilized to provide this
Information. After unloading, the form is returned to the truck
driver,, who takes his truck to be washed and weighed out. The
weight of the load is recorded on this sheet. The waste within
the cell is covered immediately.
bf Leachate Handling. In the past, leachate was collected
from cells and stored and treated in the fireponds. Currently
the leachate is pumped directly into tank trucks, and shipped
off-site. Some of the leachate contains high concentrations of
arsenic (according to a CECOS representative at the time of the
Task Force evaluation) and is shipped to the CECOS Calcasieu
County, Louisiana facility for deep well injection. The remainder
of the leachate is transported to the CECOS Spring Grove Facility
in Cincinnati, Ohio, for treatment with activated carbon and
29
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discharged to the Cincinnati Metropolitan Sanitary Sewer
District.
c. Dewaterina. Dewatering systems are used to reduce the
pressure of ground water on the sidewalls of empty cells, thereby
preventing sidewall failure. Pumping rates around Cells 9 and 10
are currently estimated to be about 100 gallons per minute.
Water removed by the dewatering system (predominantly from the
Upper Sand and the 880 Sand) is pumped into one of two retention
ponds on an alternating basis. The retention ponds have
approximately 2 to 3 million gallons capacity each. Water from
the ponds is sampled and analyzed for metals, volatile organics,
pesticides, acid extractable and base/neutral organics, and
phenolic compounds The analytical results are sent to the Ohio
EPA for review and approval prior to the leachate being
discharged. After the discharge is approved by the Ohio EPA, the
public is notified through a public notice. After the public
notice period, the water is discharged to the receiving stream.
The Task Force concluded that if hazardous waste or
hazardous waste constituents are found in samples taken from the
retention ponds, the water will be considered hazardous waste and
the ponds must be considered RCRA-regulated units.
d. Potential Runoff Contamin. The Task: Force observed
a potential source of contamination to Pleasant Run Creek on the
west side of the facility. A drain in the parking area
discharges directly to the creek. The source of the water
entering this drain is runoff from a parking lot and driveway
which is traveled by trucks and equipment that enter the active
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cell. Overspray from the truck wash may also enter this drain.
Runoff from the access roads also discharges to the creeks. It is
suggested that this area be investigated and if necessary an
alternate discharge point and treatment method selected.
F. Site Geology and Hydroceolocv
1 , Introduction
The Aber Road facility is located in the Till Plain Region
of the Interior Lowland physiographic province. Glacial deposits
overlay relatively flat-lying Ordoviclan bedrock. The; bedrock is
thinly bedded (rarely exceeding 10 inches) limestone and shale
deposits of the Richmond and Maysville formations These two
formations have a combined thickness of about 600 feet in some
parts of southwestern Ohio. Field and laboratory permeability
tests indicate the shale and the limestone are dense and have
relatively low primary permeabilities
The facility is located on the eastern s.'.de of the
Cincinnati Arch. The bedrock has a gentle relief overall, sloping
to the north and east. The bedrock surface was eroded by a pre-
Illlnolan river system that formed a dendritic drainage pattern
that trends predominantly north-south. A portion of the site is
located over one of the buried valleys in this ancestral river
system.
2. Glacial Tills
Overlying the bedrock are glacial deposits, identified on
USGS Map U-316 as being deposited during the Illlnoian Stage of
the Pleistocene Epoch. The glacial deposits in Clermont County
31
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range from 0 to 300 feet in thickness. At the facility, two
distinct till units have been identified and are commonly
referred to by CECOS as the Upper and Lower Tills. The total
thickness of the glacial deposits at the site ranges from about
30 feet, south of the Sanitary Landfill, to more than 100 feet in
the buried bedrock valley. The Upper Till is comprised of
predominantly hard, dense, sandy silty clays with scattered
gravel and rock fragments. The Lower Till is a mixture of clay,
silt, sand and gravel. The tills contain several lenses of sand,
sand and gravel, and silty sand.
The two tills are separated by a sand and gravel deposit
which generally occurs with a fine-grained silt matrix between
the elevations of 870 and 890 feet (msl). This contact between
the till units has been referred to by CECOS as the 880 Zone or
880 Sand.
The Upper Till is predominantly brown in color, stiff to
.hard in consistency, and is mottled in the upper 5 to 10 feet.
Natural moisture content varies from 7 to 10 percent in the
unweathered portion to 20 percent in the upper mottled portion.
This till is classified as CL or CL-ML (Lean Clay or Silty Clay,
respectively) in the Unified Soil Classification System.
Contained within the Upper Till is a semicontinuous sand deposit
referred to by CECOS as the Upper Sand. This sand deposit
appears to be separated from the 880 Sand by about 5 to 15 feet
of clay till.
The Lower Till is gray in color and very hard and brittle.
This till has a natural moisture content of about 7 to 10 percent
and ranges in classification from CL-ML to SC-SM (silty clay to
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sand with clay and sand with silt, SiME, 1986a). In the western
portion of the site, sand deposits are less common in the Lower
Till than in the Upper Till. If present in the Lower Till., these
sand deposits tend to be discontinuous. At several locations in
the western portion of the facility, sand deposits occur at the
Bedrocfc\Ti11 Interface. These sands are unnamed and generally
Included with discussions regarding the Bedrocfc\Ti 11 Interface.
In the eastern portion of the site, two relatively large sand
deposits were recently discovered by CECOS while excavating Cell
11. These two sands are commonly referred to as the 840 and 850
Sands.
• 3 , Sand Deposits..
As indicated above, there are several sand deposits or
permeable zones within both till units. The Tas)c Force considers
these zones to be preferential flow pathways within the uppermost
•aquifer. Any other sand deposits at the site are thin and
discontinuous. Five deposits or zones have been discovered to be
relatively thick and areally extensive enough to map and
physically describe. These units are referred to by CECOS from
shallowest to deepest as: the Upper Sand, the 880 Sajid, the 850
Sand, the 840 Sand, and the Bedroc)c\Till Interface.
The Upper Sand and 880 Sand have been mapped and described
in several hydrogeologic reports. The Task Force concluded that
the extent and aquifer characteristics of these two deposits have
been adequately defined for the purpose of RCRA and TSCA
monitoring for the regulated units in existence at the time of
the evaluation.
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At the time of the evaluation, CECOS was studying the 840
and 850 sands. More information is needed concerning the
distribution of these sands and any other lower till sands in the
eastern portion of the facility (proximal to Cells 8 through 15
on Figure 2) so that they can be adequately monitored (see
discussion below).
Based upon the information available at the time of the Task
Force evaluation, the following sections provide a brief
description of each of these five deposits, including locations,
estimates of hydraulic conductivity, and the ground water flow
direction and gradient within the sand deposits.
a, Upper Sand. The Upper Sand is typically found in lenses
of limited lateral extent and above an elevation of 890 feet
(msl). Figure 6 is an isopach map showing the thickness and
distribution of the Upper Sand. The largest occurrence of the
•Upper Sand at the site is in the area of Cells 8 and 9, where it
is as much as nine feet thick. More commonly this deposit is one
foot or less in thickness. Figure 6 shows the approximate
distribution of this sand.
b. 880 Sand. The 880 Sand is usually found at the base of
the Upper Till which is normally between elevations 870 and 890
feet (msl). This sand is much more extensive than the Upper
Sand, but is not continuous across the entire site. East of Cell
7 and south of Cells 8 and 9 it has been reported to be six feet
thick (Warzyn, 1986). In the northwest portion of the site and
in the eastern part of the site, thinner lenses occur. The 880
34
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Sand is believed to extend off-site on the eastern boundary, at
the southern boundary east of the Sanitary Landfill, and along
the north boundary between Cells 6 and 7. Figure 7 is an isopach
map which depicts the distribution of the 880 Sand.
C. 850 Sand. The 850 Sand is found in the eastern portion
of the site between the elevations of 839 and 863 feet (rnsl) and
within the Lower Till. It consists of poorly sorted sands and
gravels with minor amounts of silt. A layer of fine sand (less
than one foot thick) frequently occurs at the top of the 850
Sand. Based upon a report written by Soils and Materials
Engineers (SiME, 1986b), the sand is thought to be a channel sand
that ranges from 14 to 23 feet in its thickest portions and
follows the bedrock valley. Deposited in topographic lows in the
bedrock surface, this sand deposit apparently pinches out
perpendicular to the channel axis. See Figure 8 for the
distribution of the 850 Sand as it was presented by CECOS at the
time of the Task Force Evaluation.
After studying boring and well logs the Task Force
determined that the distribution of the 850 Sand and 840 Sand may
be more extensive than Figures 8 and 9 Indicate. One well, PB 6,
on the adjacent Thomas property to the east had nearly five feet
of sand at em elevation of 847 feet. This is interpreted by the
Task Force to be part of the 850 Sand. The Task Force: also noted
that the borings north of Cells 8, 9, and 10 are drilled
predominantly to a depth of 845 feet or higher and may not have
penetrated these sand deposits.
35
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d. 840 Sand. The 840 Sand appears to be a relatively small
linear sand deposit that passes beneath the 850 Sand. The 840
and 850 Sands are vertically close to one another. In some
locations 840 Sand is found adjacent to the Bedrock Till
Interface. Based upon pump test data, these three units appear
to be hydraulically connected (S&ME, 1986b). The 840 Sand is a
poorly sorted mixture of silt, sand, and gravel, commonly
overlaid by a thin bed of well sorted fine to medium sand.
Figure 9 shows the distribution of the sand as presented by S&ME
(1986b).
e. Bedroc)c\T 111 Interface Sand deposits have been encoun-
tered on top of the bedrock; at many locations. Fracturing and
weathering of the bedrock may also contribute to flow in this
zone. The top of the bedrock has been mapped and is shown in
Figure 10. This figure gives a sitewide representation of the
bedrock surface, but more recent work by S&ME (1986b) indicates
the surface is different (a bedrock high is present) in the
eastern portion of the site.
4, Hydraulic Conductivity
The hydraulic conductivity of the different hydrostrati-
graphic units has been tested by several methods including: (1)
falling head tests on both undisturbed and recompacted soil
samples; (2) packer pressure tests within the bedrock borehole;
(3) baildown tests on completed wells; and (4) pumping tests.
Table 2 presents the results of the testing by hydrostratigraphic
unit and test type (Warzyn, 1986). The results for each
hydrostratigraphic unit varies with test type and location.
36
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Localized hydraulic conductivities may very greatly from the the
results of the bulk hydraulic conductivity tests.
a. Upper Till Hydraulic Conductivity. The falling head
laboratory tests indicate the matrix of the Upper Till has a
-7 -9
hydraulic conductivity of between 2.4 X 10 and 2.5 X 10
cm/sec. Baildown test data indicate that the hydraulic conductiv-
-5
ities in the weathered Upper Till ranges between 8 X 10 and
-7
7 X 10 cm/sec. The higher values from some baildown tests
reflect wells monitoring small sand seams (possibly Upper Sand).
Pumping tests have indicated higher hydraulic conductivities than
did the baildown tests. Pump test results for the Upper Sar.d
-5 -4
range from 1.5 X 10 to 1.7 X 10 cm/sec. Warzyn concluded
that the most representative estimate of the hydraulic
conductivity in the upper till is from pumping tests and is
-5
approximately 1.5 X 10 cm/sec,
b. 880 Sand Hydraulic Conductivity. Excluding the remolded
falling head test results, the range of hydraulic conductivity
-1
for the 880 Sand from all Varzyn (1986) tests was 1 X 10 to 3.4
-4
X 10 cm/sec. Varzyn was concerned about underestimating
hydraulic conductivity in the area outside the immediate well
hole by the baildown test and overestimating hydraulic
conductivity in the pump test because of departures; from the
assumptions of the pumping test (i.e., infinite extent and
uniform thickness). Therefore, an average hydraulic conductivity
•-2
of 1.3 X 10 cm/sec was computed using the geometric mean of the
baildown and pump tests. This value appears reasonable and was
37
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used for the ground water flow velocity calculations discussed
later in this section.
C. Lower Till Hydraulic Conductivity. The Lower Till was
tested only by falling head tests. The results indicate
-8 -9
hydraulic conductivity ranges from 1.7 X 10 to 4.0 X 10
cm/sec. These values are considered by Warzyn to be
representative of the bulk hydraulic conductivity of the Lower
-9
Till. A geometric mean of 7.5 X 10 cm/sec was used in flow
rate estimates.
d. 850 Sand Hydraulic Conductivity An aquifer test was
conducted on the 850 and 840 Sands by Ground Water Associates
Inc. on September 23 through 27, 1986. The results were provided
in S&ME (1986b). The tests were conducted in two phases. The
first phase consisted of a recovery test and the second phase a
pump test. The dewatering system in and around Cell 11 was
.turned off for 48 hours to allow the water levels to recover.
The pumps were then turned back on for phase 2 of the test.
Based upon these tests, the hydraulic conductivity of the 850
-2 -1
Sand is considered to vary between 3.8 X10 and 1.1 X 10
cm/sec, respectively.
e, 840 Sand Hydraulic Conductivity. The hydraulic conducti-
vity of the 840 Sand had not been determined by CECOS at the time
of the evaluation. The 840 Sand has a similar composition as the
850 Sand (silty sand and gravel) and therefore is believed to
have similar hydraulic conductivities.
38
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f. Bedrock: Hydraulic Conductivity. The bedrock hydraulic
conductivity was estimated by pressure testing an isolated zone
in the bedrock (i.e., packer tests) and using baildown tests in
wells screened across the Bedrocfc\Till Interface. The packer
-7
tests had uniform results of less than II 10 cm/sec. The
Bedrock\Till Interface baildown tests indicated a higher
-4 -5
hydraulic conductivity, ranging from 7 X 10 to 1 X 10 cm/sec.
The results of the baildown tests confirm that the Bedrock\Till
Interface is a preferential flow pathway.
5, Ground Vater.. Flow
Warzyn (1986) Identified four hydrostratigraphic units at
the CECOS facility. From top to bottom these are: the Upper
Till (which contains the Upper Sand), the 8RO Sand, the Lower
Till, and the Bedrock. Warzyn concentrated its study of
hydraulic conductivity and ground water flow within these units
to the western portion of the facility. The 850 and 840 Sands
were not addressed. SIME (1986b) did study the 850 and 840 Sands.
The following discussion of hydraulic conductivity, flow rate and
direction la based primarily upon information provided in those
two reports.
Outside the influence of dewatering, the water table
generally occurs between the elevations of 890 and 900 feet
(msl). All glacial deposits and the bedrock appear to be
saturated beneath the water table. It is important to note that
as dewatering activities change, the rate and direction of ground
water flow will also change. This may require additional wells
to be installed.
39
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a. Upper Till. Generally, the ground water flow direction
through the Uoper Till is controlled by the hydraulic
conductivity contrast between the Upper Till and the 880 Sand and
the lower heaa in the 880 Sand (Warzyn, 1986). In places where
the 880 Sand is not present, the gradient downward is lower, but
still toward bedrock.
The Upper Sand within the Upper Till appears to have flow
through it from the till above to the 880 Sand below (Warzyn,
1986).
b. 880 Sand. Ground water flow within the 880 Sand is
complex because of natural and site-engineered factors. Factors
contributing to flow within the 880 Sand include:
* The downward gradient from the upper till;
* Upward gradient from bedrock;
* Irregular distribution of sands and gravels within the
880 Zone;
* Lined secure cell boundaries that intersect this zone; and
* Dewatering activities at the eastern portion of the
facility.
CECOS describes the natural direction of ground water flow
(without dewatering) in the 880 Sand and the at the Bedrocfc\Till
Interface as generally from north to south. A portion of the flow
in the 880 Sand appears to be towards the southeast and southwest
near the two streams on the site.
Dewatering activities designed to help stabilize the glacial
deposits during cell construction (beginning in 1981) have
produced cones of depression in which the flow is toward the
40
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center of pumping. The pumping center has changed through time as
dewatering activities have progracsed. Some flow information is
available for the 880 Sand and the Bedrocfc\Till Interface that
reflect the effects of dewatering. Figure 11 is a potentiometric
map of the 880 Sand from Warzyn (1986) and indicates the general
flow directions around the site during dewatering.
As Figure 11 indicates, a ground water mound exists in and
around the Sanitary Landfill. The 900-foot contour of ground
water potential around this mound extends beyond the northern
limit of the landfill because the 880 Sand is absent and cannot
relieve the built-up head. A second smaller mound is associated
with Cell 2. Ground water lows include the streams on the west
and southeast, the 880 Sand in the area of the Intermediate
Landfill, and the dewatering area to the northeast. In general,
ground water flows outward from the mounds toward the lows. Flow
rates within the 880 Sand are estimated to range from 0.2 to 0.6
•ft/day. Where the 880 Sand is not present the flow rates are
estimated to be less than 0.01 ft/day.
c. Lower Till. The hydraulic potential In the bedrock is
generally higher than that of the 880 Sand. Therefore, ground
water should flow upward toward the 880 Sand through the Lower
Till. In the area north of the Sanitary Landfill, a potentio-
metric high, attributed to the absence of 880 Sand (Warzyn,
1986), causes a downward gradient in the Lower Till. Excluding
sand deposits, flow rates in the Lower Till are less than 5 X
-5
10 ft/day. The 850 Sand appears to have ground water flowing
toward Cell 11 from both the north and south during dewatering.
-------
Based upon water levels measured in two wells (HP 215B and MP
231B) it appears that water flows toward the south under non-
pumping conditions at a rate of 0.5 ft/day (S&ME, 1986b).
d, 840 Sand. There is no information about the flow rate or
direction in the 840 Sand.
e. Bedrock\Till Interface. The hydraulic potential in the
bedrock is greater than the 880 Sand. CECOS concluded this acts
as a hydraulic barrier to downward movement of water or
contaminants. Figure 12 is a potentiometric map of the
Bedroc)c\Til 1 Interface from Warzyn (1986). There is flow along
the Interface based upon the potenticmetric map and the pump test
data that indicates this is a preferential pathway.
6, Discussion
After reviewing the available geologic and hydrogeologic
information, the Task Force concluded that information is lacking
in the eastern portion of the site near Cells 8 through 15, for
the interval between 845 feet (msl) and bedrock. Few borings in
the eastern portion of the site fully penetrate the glacial tills
(see Table 8 and Figure 13). Most of these borings terminate at
or above 846 feet (msl). The lack of information below this
elevation in the eastern area precludes evaluation of whether the
lower till sands are adequately mapped and therefore if the
monitoring system is adequate in these areas. Further geologic
investigation is required (e.g., continuous cores and the
determination of ground water flow directions) to determine the
42
-------
presence, extent and importance of the lower till sands in this
portion of the site.
Figure 13 shows the locations of existing wells or borings
that fully penetrate the glacial tills in the eastern area. In
addition, this figure indicates locations recommended by the Task
Force for new, continuously cored exploration borings. These
borings should fully penetrate the glacial tills and core five
feet of bedrock. The new exploration borings should identify all
Lower Till sand in the eastern area.
Based upon the existing geologic information, the Task
Force concluded that the areas near the Intermediate Cell and
Cells 1 through 7 have been adequately characterized for purposes
of the detection and ground water quality assessment monitoring.
Due to the complex stratigraphy at this site, it is recommended
that whenever a well is installed at a new location on the site,
its borehole be continuously sampled during drilling.
G. Compliance Under RCRA and TCSA
CECOS'a Aber Road facility has been cited for several
violations of RCRA and TSCA. These include: structural
.inadequacies associated with Cell 8; the failure of Cell 9 to
comply with minimum technology standards under RCRA; a release of
contaminated surface waters into Pleasant Run Creek; and
inadequate ground water monitoring programs. Historically, the
facility hzis exhibited occasional non-compliance with respect to
recordkeeping, Below is a summary of the compliance history at
the CECOS Aber Road facility since 1983.
43
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The first formal action was in April 1983, when the Ohio
EPA issued a formal warning to CECOS about the inadequacy of the
ground water monitoring program under RCRA (Goldman, et. al.,
1986).
In February 1984 the Ohio EPA ordered CECOS to halt
construction of Cell 8, because a portion of the cell sidewall
collapsed from instabilities caused by ground water saturation of
the sediments. As a result of this failure, on May 31, 1984, the
Ohio EPA required CECOS to obtain a $ 300,000 surety bond to
"guarantee" against similar failures. The slope failure also
caused the U.S. EPA to suspend the approval under TSCA for PCB
disposal from February 22 through April 13, 1984.
On September 24, 1984, U S. EPA issued a Complaint, Findings
of Violation and Order. This administrative action alleged that
CECOS had failed to file a timely Part B of the RCRA hazardous
waste permit application. The complaint also alleged that CECOS
•failed to respond in a timely manner to a U.S. EPA Notice of
Deficiency concerning the original Part B application. A penalty
of $ 11,000 was assessed.
On May 7, 1985, CECOS and EPA entered into a Consent
Agreement and Final Order (CAFO) to resolve the September 24,
1984 administrative action. CECOS had supplied the necessary
information to the U.S. EPA and agreed to pay the $ 11,000
penalty.
The Ohio EPA ordered CECOS to suspend operations after
receiving reports on November 9, 1984, that the facility
operators pumped phenol-contaminated water from a landfill cell
into a tributary of the East Fork of the Little Miami River
44
-------
upstream from public drinking water intakes. Ohio EPA issued
Director's Final Findings and Orders on November 26, 1984,
ordering CECOS to comply with 25 provisions including:
* specification and monitoring of truck routes to the
facility;
* construction of a truck wash;
* limitation of operating hours;
* submission of a revised surface water management plan;
* retention of an independent environmental auditor;
* sampling of off-site monitoring wells;
* submission of particulate emission control arid personnel
decontamination plans;
* holding monthly meetings with a citizen committee
On November 27, 1984, the Ohio EPA allowed the facility to
reopen.
The Ohio EPA contracted Bennett and Williams, Inc., to
perform a Gaotechnlcal Assessment In the spring of 1985 (Bennett
and Williams, 1986). Preliminary data from this geotechnical
assessment triggered Ohio EPA to issue emergency Findings and
Orders on May 9, 1985, which included the suspension of both RCRA
and TSCA activities and required the submission of a ground water
quality assessment plan. The state issued Final Findings and
Orders on August 13, 1985, allowing for aitional reopening.
The Findings and Orders issued by the Ohio EPA on May 9,
1985, required the company to prepare sufficient information to
confirm or deny the presence of ground water contamination.
These investigations revealed widespread deficiencies in the TSCA
45
-------
ground water monitoring system, including grout contamination of
monitoring wells. After reviewing data generated by these
investigations, the U.S. EPA temporarily suspended the facility's
TSCA disposal authorization on August 2, 1985. Subsequently,
CECOS agreed to replace all inadequate wells by January 1, 1986.
The TSCA authorization was reinstated on August 27, 1985.
On January 23, 1986 the EPA issued a Notice of Violation to
CECOS for solidifying leachate in an unpermitted unit (the truck
bay of the container storage area) and for placing the solidified
leachate into a cell which did not meet the minimum technology
requirements (Cell 9). CECOS removed the solidified waste from
Cell 9.
Most recently, an Ohio EPA inspection of the facility on
June 19, 1986, found no deficiencies in the areas reviewed. The
facility was declared to be in "substantial compliance with the
applicable hazardous waste rules." Ground water monitoring was
not reviewed at the time of the inspection.
H. Ground Water Monitoring Program under RCRA Interim Status
and TSCA
The following section, which describes the historical ground
water monitoring systems, is taken predominantly from the CECOS
Project Plan {U.S. EPA, 1986c) and CECOS's Proposed Interim
Ground Water Monitoring Program {CECOS, 1985a).
1. Historical Ground Water Monitoring System
The Aber Road facility began accepting selected industrial
wastes in late 1976 and began monitoring the ground water in
1977. The original ground water monitoring system consisted of
46
-------
several M-serles wells which were Installed between 1977 and
1983. This monitoring system was used through 1983 to respond to
the ground water monitoring requirements for RCRA, TSCA, and an
Ohio EPA Permit to Install (PTI) issued pursuant to Ohio
Administrative Code 3745-27-06. Dewatering activities at the site
began in June 1981, and altered the ground water flow direction
within some portions of the site. Because of the gradient changes
and questionable well integrity (see discussion below;, the U.S.
EPA determined in 1984 that the original TSCA and RCRA monitoring
systems were inadequate.
As a result of these findings. Installation of the Mr-series
wells began in the spring of 1984. These wells were intended to
be part of a new comprehensive TSCA monitoring system and to
replace some of the existing RCRA wells. About 170 MP-series
monitoring wells have been Installed.
Warzyn (1986) identified 222 existing wells and developed a
well inventory (see Table 3) which documents most of the problems
with these wells. Twenty-one of the wells shown In Table 1 were
Installed by Warzyn between February and April 1986, as part of
the Assessment Program described below. (Note - the information
provided under the "comments" column of Table 3 was meant to act
as a guide rather than a definitive description. The information
was derived from several sources, including previous engineering
studies and observations made by Varzyn at the site.)
CECOS has received five U.S. EPA approval permits to dispose
PCBs in accordance with TSCA. The first was issued on September
28, 1979, for secure Cell 3. Two others were issued in May 1980
47
-------
and July 1981 for Cell 4/5 and 6 through 17, respectively.
However, on January 17, 1984, the U.S. EPA notified CECOS that
all additional cells would require individual approval under
TSCA. Cells 9 and 10 were approved by U.S. EPA under TSCA on
February 6, 1985, and September 12, 1986, respectively.
In accordance with the approvals, monthly monitoring of
seven of the M-series wells (M 4, M 11, M 15, M 18, M 21, M 23,
and M 24) began in 1979. One well (M 15) was considered
upgradient and six others were considered downgradient . In 1984,
these original wells were replaced by 45 well nests of the MP-
series. In addition to its monitoring wells, CECCS has monitored
some underdrains, leachate standpipes, and surface waters since
1983 to satisfy TSCA requirements. In 1985, as part of the TSCA
well replacement program described above, four supplemental well
nests were added to the TSCA ground water monitoring program.
RCRA quarterly background monitoring began on December 18,
•1981, and continued until December 12, 1983, using wells M 15
(originally considered upgradient), M 18, M 24, and M 25
(originally considered downgradient). Between 1983 and 1985,
leachate standpipes, underdrains, and several of the MP-series
wells were monitored to satisfy the RCRA requirements.
In the spring of 1985. CECOS initiated a site-wide
monitoring well development program to respond to Director's
Findings and Orders issued by the Ohio EPA. During the summer of
1985, CECOS sampled 33 leachate standpipes and analyzed them for
compounds listed in Appendix VIII of 40 CFR Part 261. Based on
the results of this analysis, CECOS proposed a list of compounds
to the Ohio EPA for future monitoring. After the leachate
48
-------
sampling, CECOS began sampling 59 monitoring wells for volatile
organics analysis (VOA) until a final ground water monitoring
program could be established. (Also see Preparation, Evaluation
and Response, Subpart 4}.
Based upon historical data and the initial results of the
ground water quality assessment program, CECOS concluded that the
pre-RCRA cells (Cells 1 and 2 and the Intermediate Cell) in the
northwest quadrant of the site, and the old Sanitary Landfill in
the southern portion of th« site were the primary areas that
required further study. Warzyn was contracted in the spring of
1985 to perform this study, and completed it in May of 1986.
Quarterly monitoring of wells M 15, M 21, M 22, M 26, M 27,
and M 28 began on November 12, 1980 as required by the Permit to
Install (PTI) for Cells 3 and 17. A stipulation of the permit
required that 19 additional wells had to be maintained as
"standby" wells.
2. Proposed Ground Water Monitoring System
In response to a request by the U.S. EPA and Ohio EPA at a
meeting held in Columbus, Ohio, in August 1986, and as
recommended by Warzyn (1986), CECOS prepared a report describing
a Proposed Ground Water Monitoring Program (CECOS, 1986) that was
intended to satisfy all of the monitoring requirements of RCRA,
TSCA, and the Ohio PTI. This program was evaluated by the Task
Force and found to be inadequate. The proposed system is shown
on Figure 15 and is listed in Tables 4 through 7. The
inadequacies under RCRA noted by the Tasfc Force in the Proposed
49
-------
Ground Water Monitoring system are discussed later in this
section.
a. Uppermost Aquifer. CECOS has defined the uppermost
aquifer to be the 880 Sand zone. The Task Force determined that
the uppermost aquifer includes all unconsolidated sand or more
highly permeable deposits at or above the Bedrock\Ti11 Interface.
The hazardous waste cells cut through or are in contact with many
of the sand deposits (e.g.. Upper Sand , 880 Sand, and 850 Sand).
Therefore, even if the sand deposits are not directly connected,
a release could occur to the the uppermost aquifer without being
detected in the 880 Sand.
b. Upgradient Veils. The Tasfc Force concluded that there are
not enough upgradient wells capable of yielding representative
samples of the uppermost aquifer. Historically, well M 15
(screened in 880 Sand) was considered upgradient. Dewatering
•activities have changed the gradient (i.e., flow direction) such
that this well can no longer be considered upgradient.
Furthermore, not enough is known about the construction of most
M-scries wells (e.g., M 19 through M 28, Table 3) to ascertain
if these wells are screened in discrete intervals or if their
construction might be affecting the ground water samples.
Ground water quality studies by Warzyn (1986) indicate the
concentrations of different cations and anions (SO , HCO , Cl,
4 3
Na, K, Mg and Ca) are highly variable between the Bedrock\Till
Interface wells and shallower glacial sand deposits (880 Sand and
Upper Sand). Therefore, the Task Force determined that several
upgradient well nests are required to adequately characterize the
50
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background inorganic water quality of all sand zones above
bedrocfc. These nests should be located outside the influence of
dewatering activities. The wells designated as upgradient in the
current monitoring system and proposed monitoring systems appear
either to be too close to be unaffected by the hazardous waste
cells, or are not upgradient of the facility. It is recommended
several upgradient well nests be installed outside the influence
of dewatering.
C. Downaradlent Veils. The number of downgradient wells in
the existing system (See Table 4 through 7) is sufficient. In
response to a meeting with the U S. EPA and Chio EPA in Columbus
on August 13, 1986 and recommendations by Warzyn (1986), CECOS
has proposed a single Comprehensive Ground Water Monitoring
Program (CECOS, 1986) that includes downgradient wells in many of
the sand units (see Tables 4 through 7} Although this program
would be a significant improvement over the current system, the
TasJc Force determined the proposed system does not have
sufficient wells to immediately detect or assess contamination
from the existing cells into all of the sand deposits in contact
with the cells. Further, some of the existing wells in the
proposed system are inadequately constructed. The TasJc Force
recommends that the downgradient wells in the proposed system
with inadequate construction (see below) be replaced if CECOS
intends to use them.
d. Veil Construction. CECOS has an older series of wells
fcnown as the M series. Many of the M series wells are "fully
penetrating" (i.e., screened throughout their length), have no
51
-------
"as-built" construction diagrams, and failed to produce non-
turbid water during development. Therefore, a program to plug and
abandon the M series wells should be developed. Some of the M
series wells may be suitable for water level measurement. These
would be wells with screens 15 feet or less in length, and
screened in one sand deposit.
The newer MP series wells are better designed in that they
generally have limited screen lengths, as-built construction
diagrams are available, and for the most part they were developed
properly. Some of the original MP wells were constructed
improperly, and were found to be contaminated with grout. MP
wells with improper well construction have been replaced or are
not included in the Comprehensive Ground Water Monitoring Program
(CECOS, 1986). These improperly constructed wells should also be
plugged and abandoned.
Future monitoring wells used for collection of samples
should be constructed with inert casing materials. Because of the
nature of the wastes landfilled at the CECOS Aber Road facili
stainless steel (304, 316, or 2205) or polytetrafluoroethylene
(PTFE) are the best-suited materials. The Tasfc Force has
determined that It is not necessary to replace properly designed
and built existing wells solely because they are constructed with
PVC casing.
3. Sampling and Analysis Plan
a. Sampling Plan. The Sampling and Analysis Plan is inade-
quate. The plan is composed of several documents which contradict
one another (see list in next section). These contradictions
52
-------
exist in the equipment decontamination procedures and also in the
specification for cable to be used for sampling;. Another
deficiency was noted in that the plans contain references
describing sampling and analysis procedures rather than the
procedures themselves. Also, the order of sample collection was
not specified. However, as discussed later, CECOS does collect
samples in a correct order. The Task Force recommends that the
plan be consolidated into one document and the deficiencies and
contradictions eliminated. The plan must specify sampling1
frequency and length of time allowed to take water level
measurements. CECOS indicated that It was rewriting the plan at
the time the field sampling and analysis activities were
observed.
b. Sample Collection and. Kar.d 1 ing Proc*dur?s On February 19,
1987, routine field sampling and analysis activities performed by
,CECOS personnel were observed by the Task Force. Activities for
the sampling of one monitoring well and one underdrain were
observed. The Sampling and Analysis Plans In effect: were the
sane as the ones reviewed by the Technical Review Team. As
indicated above, many other documents describing general'and/ or
specific field sampling and analysis procedures are available for
this facility. Some of these documents are:
* the Part B application (September, 1984 submittal)
* Proposed Ground-Water Quality Monitoring Plan for CECOS
International Aber Road Secure Landfill, Jackson Town-
ship, Clermont County, Ohio (Ecological Analysts, Inc,
1983)
* Guide for Sampling Groundwater Monitoring for CECOS Aber
Road facility (CECOS, 1985b)
-------
* Howard Laboratories Quality Assurance/Quality Control
Program
* ETC Summary of Quality Assurance/Quality Control
Procedures
None of the above referenced documents are complete, accurate
descriptions of field sampling activities as they are currently
being; performed at CECOS. Problems noted during this review of
field activities were:
1) shortage of bacfcup sampling equipment;
2) inadequate decontamination of field equipment;
3) No effort is made to check for hazardous gases or
immiscible liquids in the wells;
4) Precise purge volumes are hot measured;
5) inadequate control of bailer; lowered too fast,
possibly aerating the sample;
6) field equipment blanks are not prepared for the
underdrain pumps; and
7) inadequate number of dedicated field personnel.
Supplies and equipment generally appeared to be adequate.
There is a shortage in bacfcup equipment, specifically pumps used
for purging and sampling underdrains. Sample bottles utilized
are appropriate, but it appears there is an occasional shortfall
in available inventory. When bottles specified in the plan are
not available, substitute bottles are used. The inventory of
sample bottles may require more frequent review. New sample
bottles are shipped to the contract laboratory (Howard
Laboratories or ETC), where they are prepared. The bottle cleanup
is consistent with U.S. EPA procedures. After being labeled, the
washed bottles are sent to CECOS from the contract laboratories.
54
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Paper towels are used in sampling equipment decontamination
activities. This could lead to false positives due to possible
contaminants in the towels. The towels also have the potential
to disintegrate and leave residue on equipment. It is suggested
that the facility use towels made of a more sturdy and inert
materials.
Presampling procedures Include the measurement of water
levels and total depth for wells and the purging of stagnant
water from both wells and underdrains. There is no effort made
to check for hazardous gases or immiscible liquids Water levels
are measured using a Slope Indicator Company water level
indicator, Model" #51453 . In this type of water level indicator,
a sensor is lowered into the well and a signal on the cable reel
sounds when the sensor reaches the air/water contact. The cable
is coated with black vinyl or rubber, and the sensor is not
•weighted. Repeated measurements are made to assure an accurate
measurement. The cable Is measured from a designated point on the
well casing. The cable Is marked in one foot Increments. A foot
ruler is used to determine depths to an accuracy of 0.25 inch.
Total depth Is also determined with the water level
Indicator. In the measurement of total depth observed by the
Taslc Force, some difficulty was encountered in determining the
actual bottom. During bailing, it was discovered there were some
ridges in the well casing of monitoring well M 15 that could
potentially give false bottom readings. It is suggested that a
weighted device be used for water level and total depth
measurements.
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The cable was decontaminated using deionized distilled water
and a paper towel. The problems with the paper towel were
discussed above. Based upon water level and total depth
measurements, the well and purge volumes were properly
calculated.
The purging and sampling of monitoring well M 15 was
accomplished using a dedicated PVC 3-1/2" I.D. bailer. Most
routinely sampled monitoring wells appeared to have similar
equipment. The bailer is stored inside the locked well casing
when not in use. The bailer appeared to be relatively clean and
in good condition. The bailer is suspended on a 130 pound test
monofilament nylon line using a brass clevis hoofc. The bailer is
raised and lowered using a "Penn" downrlgger reel mounted on a
surveyor's tripod. The reel was manually powered. The facility
also has a battery-powered downrigger reel. The battery powered
•reel is used with smaller bailers.
Sampling efforts at monitoring well M 15 were observed. The
bailer used for M 15 has been determined by CECOS to contain a
volume of one gallon when full. The actual volume purged was
determined by counting the number of full bailers removed from
the well. Fractional volumes were estimated. The total volume
of water purged from M 15 was far in excess of the three well-
volume criterion. A more precise measurement of purge volume may
result in less time spent in bailing and provide a better
documentation of actual purge volumes. Well M 15 was not
considered contaminated and therefore the purge water was dumped
directly onto the ground. The monofilament line was wiped with a
dry paper towel each time the bailer was pulled from the well.
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Between wells the bailer line was wiped with paper towels soaked
with deionized water. The purging operation began with the
expectation of sampling Immediately after purging. The lowering
of the bailer was not adequately controlled, and the bailer
splashed heavily, resulting in the aeration of water remaining in
the well (problem 5 above). The bailing operation caused a
significant drawdown within the well, and the well needed some
time to recover before sampling. Therefore, the bailing
procedure was not a problem in term of aerating the sample.
However, It would have been a problem if sampling had started
immediately after purging as originally planned.
The well was sampled one hour after completing the purging
operation. A water level measurement just prior to sampling
indicated the well had recovered approximately 70* of its
original volume. The lowering of the bailer for sampling
purposes waa done more carefully to avoid sample aeration. The
initial bailer full of sample water was discarded. The sample
order began with volatile organics followed by TOX, TOG, phenols,
metals, SO /Cl, and field parameters. The sample bottles were
4
filled by pouring from the top of the bailer. All sample
containers except for volitile organic analysis (VOA) vials were
rinsed with sample water before filling. A quadruple sample was
Collected for TOX and TOC. Field parameters (pH, temperature,
and specific conductance) were determined immediately after
collection. The meters were appropriately calibrated prior to
beginning field activities for that day. A one-point check at pH
7.0 was performed prior to the actual pH measurement.
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Temperature values were taken from ths pH meter (Orion SA250).
The conductivity meter was a YSI Model 33. This instrument is
not temperature-compensated. Conductivity values are noted "NIC"
(not temperature compensated) and adjusted for temperature later.
Samples are returned to the facility's laboratory for
preservation and filtration, when required. The TOC and phenol
samples are preserved with reagent grade H SO dispensed from a
2 4
VOA vial using a disposable plastic pipette. The sample is then
checked to assure that the pH is less than 2. The entire metals
sample is filtered through a 0.45-micron filter using a glass
"Millipore" apparatus, which is appropriately cleaned between
samples. Filter blank samples are not collected. The empty
original sample bottle is rinsed with deionized water, rinsed
with filtered sample water, and then refilled with the remaining
filtered sample. The filtered sample is then preserved with HNO
3
•dispensed and checked in the same manner as with the H SO
2 4
preservative. All samples are stored in a locked refrigerator
located In the laboratory. Volatile organic samples are shipped
to ETC and all other routine samples are picked up by Howard
Laboratories.
Sample tracking and custody procedures are well documented
through the use of a "Field Log", "Chain of Custody", and "Sample
Analysis Request" forms. Observations found these forms to be
properly used. Previous data pertaining to the sample sites were
available for reference at the time of sampling.
Sample collection at underdrain U 20 was performed
immediately after completing the well sampling. The initial
purge water appeared muddy and rusty. At the end of the purge
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cycle, estimated at the time of pumping to be 200 gallons, the
water appeared clear. Purge water was run onto the ground.
•
Samples were collected from a 12-foot long rubber discharge hose.
The sampling order began with volatile organics, then TOX, and
PCBs. Field parameter aliquots were collected last. The
determination of field parameters was performed at the sample
location, immediately after their collection.
The material in the pump system used for underdrain sampling
include metals and rubber hose. The use of this unit at the
different underdrain sites requires a thorough cleaning between
sites." Each cleaning event performed should be documented in
writing. The adequacy of the cleaning procedures should be
supported by at least one equipment blank for each round of
underdrain sampling. The Task Force recommends this protocol for
the pump system be developed and added to the proposed facility
.sampling and analysis plan.
Field blanks and trip blanks are prepared by CECOS. Their
preparation was not observed. A verbal review of blank
preparation protocols indicated that the procedures followed were
appropriate for the purposes of these two types of blank samples.
Equipment blanks are not prepared which the Task Forc« considers
to be a deficiency. Equipment blanks for the underdrain pump
system and filter (for dissolved parameters) must be ccnsidered
for addition to the facility's QA/QC program.
Field sampling activities appear to be hampered by an
insufficient number of personnel. The entire field sampling and
analysis program is supported by less than two full-time
KQ
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positions. There is little or no time for self-evaluation of the
program by those actually performing the field tasks. Equipment
maintenance and supply inventories cannot be adequately
maintained with the present number of field staff. This lack of
personnel may also be contributing to the slow development of a
single adequate {i.e., up-to-date) "Sampling and Analysis Plan"
for this facility. In summary, the Task Force recommends that
the number of personnel used for sampling and monitoring
activities be increased.
4. Preparation Evaluation and Response
CECOS has been implementing a ground water quality
assessment plan since August 1985 after observing a significant
increase in pH and specific conductance in some of the wells on
the western portion of the site. The Task Force noted
inadequacies in the ground water quality assessment plan in the
area of determination of the rate and extent of contamination and
in taking water level measurements. Also, CECOS was one month
late in talcing samples for second quarter 1986 reassessment
monitoring.
The Task Force reviewed the initial report submitted under
the ground water quality assessment plan (Warzyn, 1986). The
Task Force concurs with many of the conclusions and
recommendations in that report. However, the Task Force
concluded that monitoring wells in addition to those proposed in
that report are necessary to determine the extent of
contamination.
60
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Following the completion of the Warzyn report, CECOS
discussed the conclusions and recommendations in that report with
representatives of the Ohio EPA and U.S. EPA. Following that
discussion, CECOS began implementing the recommendations in that
report. In addition to the new wells recommended by by Warzyn,
CECOS agreed to install three additional wells at the request of
the regulatory agencies. At the time of the Task: Force
evaluation, CECOS was installing these wells.
In addition to implementing the recommendations in the
Warzyn report to further delineate the extent of contamination,
CECOS continued the "Interim Ground Water Monitoring Program"
(CECOS, 1985a.) . This program called for the analysis of sample
from 56 monitoring wells for volatile organic compounds. At the
request of the U.S. EPA and Ohio EPA, three additional wells, HP
248, MP 200R, and HP 262, were added to this program CECOS was
to monitor these 59 wells quarterly and based upon the
potantiometrlc and analytical data, make the determinations
required under 40 CFR 265.93 (d)(4). The ground water monitoring
program was to be continued until the Comprehensive Ground Water
Monitoring Program suggested by Warzyn could be developed and
approved by the appropriate regulatory agencies.
The Tasfc Force reviewed potentiometric information being
gathered by CECOS and noted these data are collected over an
excessively long period of time. The potentiometric data are
collected prior to sampling an individual well. Because of the
large number of wells being monitored, the collection of this
information extends over a period of several months. The Task
Force concluded that this procedure was unacceptable. In order to
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obtain an accurate "snapshot" of the potentiometric surface
within the various sand deposits, water level measurements must
be collected over a period of several days. Without accurate
potentiometric data, CECOS cannot accurately determine the ground
water flow velocity (i.e., rate) and flow direction. Therefore,
the Task Force believes water level measurements should be taken
over a shorter period of time (i.e. five days in a row) to
accurately determine the flow velocity and direction.
I. Ground Water Monitoring Program Proposed for Final Permit
1 . Introduct ion
The original Part B application for the CECOS Aber Road
facility was submitted to the U.S. EPA Region V, Waste
Management Division, RCRA Permits Section on September 23, 1983.
The original Part B application was not adequate and two Notices
of Deficiency (NOD) were issued on December 2, 1982, and March
i
13, 1984. In general, this Part B submission was incomplete in
all areas including ground water monitoring. It did not consider
the changes In ground water flow caused by the dewatering
activities at the site. CECOS revised the Part B application and
submitted a second application on September 15, 1984. On
September 24, 1984, the U.S. EPA issued a Finding of Violation
and Compliance Order because the original Part B submission and
the resubmissions were submitted late.
The U.S. EPA, Region V sent CECOS a letter on September 3,
1986, which indicated the major deficiencies of the revised Part
B application (September 1984 submittal). The letter indicated
the areas to be updated included, but were not limited to:
62
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* Closure Plan for Flrepond 4/5
* Spray Irrigation Field(s)
* Amended construction details
* Waste Analysis Plan
* Facility Closure Plan
* Inspection schedule
* Contingency Plan
* Closure Cost Estimates
CECOS was allowed 90 days to submit another revision. The second
revision of the Part B application was received by the U S EPA
on December 22, 1986.
2. Review of Current Submjttal
The Tasfc Force reviewed the revised Part B application and
found the revised application to be extremely incomplete and
'technically inadequate. It contained generalities where
specific, detailed information and procedures were required, and
also contained information that is obsolete or outdated. It also
failed to include areas that needed to be addressed.
The following section contains some of the deficiencies in
the December 1986 RCRA permit application found by the Tasfc Force
with respect to the requirements of 40 CFR 270.14 and the 40 CFR
Part 264. The U.S. EPA, Region V has completed a Notice of
Deficiency which specifies in detail the deficiencies and
technical inadequacies in the application.
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a. 40 CFR 270.14 (cl(1) . Future Part B applications for the
RCRA permit submittals must contain all quarterly monitoring data
obtained during Interim Status.
b. 40 CFR 270 .14 fcl (21 . The Task Force determined that the
uppermost aquifer has not been adequately characterized (See
Section H.2.a., page 49). This section details the need for
further characterization below the elevation of 845 msl in the
eastern portion of the site. It is recommended that continuous
borings be installed to bedrock and that five feet of bedrock be
cored when installing the new borings.
c. 40 CFR 270 14 (cl(31 A deficient Point of Compliance was
proposed in that wells were not adequately spaced along the
perimeter of the hazardous waste management areas and did not
take into account pumping cpnditions at the site.
d. 40 CFR 270 ,14 (cl (41 . Ground water contamination around
Cell 4/5, Firepond 4/5, and the Sanitary Landfill exists (See
Section L.2.b., page 78). If Firepond 4/5 is leaking, a
description of the plume of contamination that entered the ground
water, including a delineation of the plume on a topographic map,
is required under 40 CFR 270.14 (c)(4). Additional wells are
recommended in the area of Firepond '4/5 to determine if the
firepond is contaminating the ground water.
e. 40 CFR 270 .14 (cl(5) . The proposed monitoring system in
the Part B of the RCRA permit application is inadequate in the
following areas: a) an inadequate geologic characterization of
the eastern portion of the site (see Section F.6., page 41); b)
64
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inadequate plume delineation (described above); and c) inadequacy
of some of the existing well locations and construction (see
Section H. 2. b. through d., pages 50 through 51).
f. 40 CFR 270 .14 (c) f 6) . CECOS has proposed detection moni-
toring in the eastern portion of the site. The Tasfc Force
determined that more supporting data, analyses, and additional
well Installation are necessary to implement an adequate
detection monitoring program.
q. 40 CF"R 270 14 (c)(7) and (8). Because ground water conta-
mination exists at the site, CECOS should initiate a compliance
ground water monitoring program for that portion of the facility
affected by the contamination. CECOS should be monitoring under
this program until some type of corrective action plan is
implemented.
t
h. 40 CFR 264 (Part A Deficiencies 1 . The Part A application
does not contain a required description of all the processes
CECOS intends to use to handle wastes. For example, there is no
discussion of the processes CECOS plans to use with the proposed
solidification impoundments and drum storage associated with the
solidification impoundments. In addition, the Part A application
includes outdated waste codes and codes for wastes that cannot be
landfilled at this facility (e.g., all hazardous waste whose
hazardous waste number begins with P are banned by Ohio EPA
requirements).
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1. 40 CFR 264 (Part B Deficiencies). The detection moni-
toring system proposed in Part B of the CECOS application for the
RCRA permit is very similar to the Proposed Monitoring System
(November 1986) for Interim Status (40 CFR 265). However, no
attempt was made in the Part B application to discuss either a
compliance (40 CFR 264.99) or corrective action (40 CFR
264.100-101) monitoring program for that portion of the facility
were there is evidence of contamination. The Task Force
determined that both proposed systems for 40 CFR 264 (RCRA
permit) and 40 CFR 265 (Interim Status) are inadequate to satisfy
the respective regulations.
The waste analysis plan in the Part B application lacked
sufficient detail in many areas, failed to include required
information, relied too heavily on generator information, and
contained inadequate procedures to meet the requirements.
Required information not addressed in the plan included:
* A brief description of all of the treatment, storage, and
disposal methods utilized at the facility.
* A general description of the types of wastes to be received
by the facility, brofcen down by facility process. This
must include wastes generated on-site.
* Procedures for identifying restricted wastes (waste defined
under 40 CFR Part 268) in the screening of incoming loads.
The waste analysis plan fails to demonstrate that the proposed
screening methods for incoming waste are adequate to establish
that wastes received are the same as identified on the manifests.
CECOS must also implement a procedure to routinely verify the
information supplied by the generator on the WPR.
66
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J. Off-site Laboratory Evaluation
The Task Force evaluated both off-site laboratories used by
CECOS. Howard Laboratories, Inc., In Dayton, Ohio, analyzes
samples from CECOS for inorganic drinking water quality
parameters (arsenic, barium, cadmium, chromium, fluoride, lead,
mercury, nitrate, selenium, and silver), ground water quality
parameters (chloride, iron, manganese, total phenol, sodium, and
sulfate), ground water indicator parameters (pH, specific
conductance, total organic carboa, and total organic halogen),
organochlorine pesticides (endrin, lindane, methoxychlor, and
toxaphene), PCBs, plus volatile and semivolatile extractable
organ ics.
The principal deficiencies found In evaluation of Howard
Laboratories (U.S. EPA, 1987) pertain to quality control
practices affecting data validation The laboratory is not using
a U.S. EPA-approved method for semi-volat1le organics. The
laboratory has participated successfully in performance
evaluation studies for drinking water metals, pesticides and
herbicides. Performance data for PCBs are not available. In
general, the laboratory shows competence for analytical work for
the parameters of interest, but must improve its quality
assurance practices.
Environmental Testing and Certification (ETC) Corporation
analyzes most of the constituents listed in Appendix VIII of 40
CFR Part 261 for CECOS. The laboratory staff, equipment,
methodology, quality assurance, and quality control program were
found to be acceptable by the Task Force (U.S. EPA, 1936).
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K. Task Force Sampling
1. J^ethodoloov
Samples for the Task Force evaluation at CECOS were
collected by Versar, Inc., (Versar), a U.S. EPA contractor, under
the supervision of U.S. EPA personnel. A CECOS representative
accompanied the sampling team at all times. Video tapes were made
by CECOS of most sampling activities. Polytetrafluoroethylene
(PTFE) bailers provided by Versar were used to sample all
monitoring wells. Pumps supplied by CECOS were used to sample the
underdrains. All samples and blanks were split into two portions
with the facility receiving one portion and the EPA retaining the
second. All Task Force sample bottles and preservatives were
provided by a U.S. EPA contract laboratory. Bottles for CECOS's
sample splits were supplied by ETC. Versar provided all of the
equipment and materials necessary to manage, handle, field
filter, document, and ship the Task Force samples.
Prior to obtaining water levels, purging, or sampling,
Versar monitored the open well head for organic chemical vapors
using a photoionizatlon detector. After this safety screening,
static water levels were measured in 160 wells for evaluation by
the Technical Review Team. Water level indicators were supplied
by the U.S. EPA, Region V and Versar. All water level indicator
units were calibrated to ensure comparable measurements.
Monitoring well sampling activities were preceded by the
removal of the static water column. This "purging" was completed
using bailers. The same bailer was then used to collect samples
from the well. A volume of water equal to three times the static
water volume present in the well was evacuated. When three
68
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volumes of water could not be removed, the wells were purged to
dryness. These slow recharging wells were sampled when there was
a sufficient volume of water to fill at least one parameter
bottle set (Including split samples). For many wells this
required purging on one day and sampling on the next day. To
obtain a sufficient volume of water for all parameters it was
necessary to return to some wells on a number of successive days.
Underdrains which were sampled were purged prior to sampling
using equipment supplied by CECOS. This was the same equipment
that CECOS normally utilizes to sample the underdrains . All of
the underdrains except one, identified as U 24, were purged
using a portable gasoline-driven pump. At each underdrain at
least 200 gallons of water was purged. If CECOS suspected the
underdrain water to be contaminated, the purge water was placed
in drums and sent to be treated with leachate. Water within
•underdrains not believed to be contaminated was allowed to run
onto the ground. Field parameters (pH, specific conductance, and
temperature) were analyzed periodically to determine If sample
water constituents were stabilizing. After stable field parameter
readings were obtained, sampling began. A blank sample was
obtained from the portable pump prior to its use.
At underdrain U 24, purging and sampling was accomplished
using a submersible electric pump. The volume of water purged
from this location was not measured. Underdrain U 24 was purged
to dryness, and sampling then occurred on the following day.
Dewatering activities at Cell 9 appeared to be responsible for
the small amount of water present in this underdrain.
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For monitoring wells, the method of sample collection was
dependent upon the recharge of the individual well. All wells
were sampled using dedicated PTFE bailers supplied by Versar. In
some wells there was a CECOS-owned, dedicated PVC bailer. These
bailers were removed, identified, placed in a heavy plastic bag
and given to CECOS personnel for custody. In a few cases, well
recharge rates were sufficient to allow sampling immediately
after purging. However, at most wells it was necessary to wait at
least 24 hours for the well to recharge sufficiently to obtain
the necessary sample volume. The bailer and cable used at these
slow recharging wells were left on site, but were custody sealed
by the Tasfc Force Sampling Team. Soma wells required two visits
to obtain the required sample volume and one well required three
visits.
All sample bottles were filled directly from the bailer
using a bottom-emptying device. Volatile organic analyses (VOA)
vials were filled as replicate samples while other sample bottles
were split proportionally between U.S. EPA and CECOS containers.
Sample bottle types, sizes, and preservatives are listed in
Table 1. Samples for the seepage site in Cell 11 were collected
as replicate aliquots. A PTFE bailer tube was used to drain the
seepage stream into the sample bottles. The discharge from the
bailer tube was allowed to flow for 20 minutes prior to sampling.
Underdrain samples collected using the portable pump were
collected in replicate. The samples were collected directly from
the pump's discharge hose. At underdrain U 24 the sample was
first collected into a clean glass 2.5 gallon Jug. This jug was
cleaned by Versar in accordance with contract requirements.
70
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Sample bottles were filled from the jug with the aid of a clean
glass funnel. It was necessary to fill the jug three times to
fill all U.S. EPA and CECOS sample containers.
2. Sampling Locations
Sampling points for this evaluation Included six
underdrains, twenty-three monitoring wells, and one seepage area.
Quality assurance samples are discussed in the following section
(K. 3.). Specific sample locations and the cells or
hydrostratigraphic units they represent are listed below.
SITS REPRESENTING
Underdrains:
U 4 Cell 3
U 12 Cell 4/5
U 13 Cell 6
U 17 Cell 7
U 22 Cell 8
U 24 Cell 9
Monitoring Wells:
M 41, MP 220AR, HP 244AR Upper Sand
M 3, M 26, MP 200R, MP 206, 880 Sand
MP 208, MP 217A, MP 219A,
MP 222B, MP 229B, MP 232A,
MP 246, MP 248B, MP 249B,
MP 253A, MP 256A, MP 261A,
MP 215BR
MP 222R, MP 261, MP 227 Bedroc)c\Ti 11 Interface and
Lower Till
Cell 11 Seep: 880 Sand
71
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3. Quality Assurance and Control
Quality assurance and control (QA/QC) for U.S. EPA
contractor sample collection, handling and analysis were
conducted in accordance with the Hazardous Waste Ground Water
Task Force - Protocol for Ground-Water Evaluation (EPA, 1986a).
The Sampling Team oversaw Versar's procedures during the
sampling effort to ensure consistency with the QA/QC and evidence
handling requirements contained in that document.
A total of ten Q.A.-related samples were collected. These
samples included field blanks (2), a trip blank (1), equipment
blanks (3), a bottle blank (1), and duplicates (3). Field blanks
were prepared at representative sampling locations for all
samples collected during the inspection. The trip blank was
prepared by Versar at its Virginia laboratory prior to departure.
The trip blanks were held by Versar in their truck, during the
entire period of sampling at CECOS. The trip blanks were
submitted for analysis along with the last day's samples.
Equipment blanks were prepared to cover the two batches of
bailers {different dates of preparation) used at this facility.
The third equipment blank was taken from the CECOS portable pump
which was used to sample the underdrains. A bottle blank was
prepared to assure no contamination was introduced through
storage on-site and for comparison with the CECOS bottle blanks.
Matrix spikes involved collecting an extra sample volume for the
laboratory and were taken from underdrain U 4, and monitoring
wells MP 200R and MP 249B. Duplicate samples were collected at
10* of the sample locations. Duplicate samples were obtained
from underdrain U 4, and monitoring wells MP 222B and MP 249B.
72
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Field measurements Included temperature, pH, specific
conductance, and turbidity. All thermometers were traceable to
NBS-standardized instruments. Daily calibrations were performed
on each of the pH and specific conductance meters to be used on
that day. Calibration checfcs were performed prior to each
measurement of pH and conductivity. The turbidity meter was
standardized daily immediately prior to commencing sampling
activities.
All sampling equipment was thoroughly cleaned and wrapped
for transport to CECOS at Versar's laboratory. Bailers to be
reused at the same monitoring well were stored in the well casing
under custody seal. No sampling equipment was used at more than
one monitoring well. Used or contaminated bailer caole or water
level indicator tapes were cleaned by wiping with a hexane-soalced
tissue followed by wiping with a tissue soaked with distilled
water.
»
4. Custody and Sample Handling
All samples collected for the U. S. EPA were shipped to the
contract laboratories: Compu-Chera In Research Triangle Park,
North Carolina, completed the organic analyses, and Centec in
Salem, Virginia, completed the inorganic analyses. All samples
were shipped in accordance with applicable Department of
Transportation regulations (49 CFR Parts 171-177). Samples in
which contamination was expected were designated as "medium-level
hazardous" for laboratory personnel. All samples from wells,
underdrains, and the seepage area were considered "environmental"
for shipping purposes. Each sample shipment was accompanied by a
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Chain-of-Custody Record which was completed by Versar. This form
(Figure 3) Identified the contents of the shipment in terms of
sample type, date and time, etc. The original chain-of-custody
form accompanied the shipment and a copy was provided to the
Field Team Leader. Samples tafcen from the facility by U.S. EPA
were documented with a Receipt for Samples form (Figure 4), which
was completed by Versar personnel. A copy of this receipt was
provided to facility personnel. The originals were retained by
the U.S. EPA Field Team Leader.
5. Scheduling
Many logistical problems, such as weather, equipment, and
well performance affected the time required to obtain the samples
and influenced the sequence of sampling. The Sampling Team
Leader, in conjunction with the Field Team Leader, established
the priority for sampling and developed daily schedules to
minimize delays. The expected recharge rate for some wells was
not well known prior to sampling. In most cases recharge rate
data provided by CECOS indicated faster recharge rates than were
actually experienced by the TasJc Force. Most wells required at
least two sampling setup and teardown sequences. One well
required four sets of these operations. On November 10-12, 1986,
static water levels were measured in 160 wells for use by the
Technical Review Team. Actual sampling activities began on
November 13, and were concluded on November 21, 1986.
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L. Ground Water Quality Interpretation
1. Tasfc Force Analyses
Samples were analyzed by the U.S. EPA contract laboratories
for the parameter groups shown In Appendix D. The slow rate of
recharge in some wells prevented the Tasfc Force from obtaining
analyses for all parameters in several wells. These wells are
indicated in Appendix A. Laboratory analytical results were
obtained from two U.S. EPA contractor laboratories participating
in the Contract Laboratory Program (CLP). Standard quality
control measures were observed including:
* The analysis of field and laboratory blanks to allow
detection of possible contamination due to sample
handling;
* Analysis of laboratory spiked samples and performance
evaluation samples;
* Analysis of laboratory and sample duplicates to estimate
precision; and
* The review and interpretation of the results of these
control measures. These procedures can be found in the
Quality Assurance Project Plan (QAPP) for this site (U.S.
EPA. 1986C).
The Quality Assurance/Quality Control summary can be found
In Appendix B. Appendix C is a table of the analytical results
for all constituents found above the limits of detection.
Appendix D provides a summary, by parameter, of the analytical
techniques used and the reference methods for the sample
analyses.
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2. Data Interpretation
Historically, there have been a number of areas that have
shown ground water contamination. The following text will
discuss these areas individually.
a. Northwest Area. This area consists of the Intermediate
Cell, Firepond 1, and Cells 1, and 2.
Well MP 222B indicates that the shallow sand seam (Upper
Sand) between the Intermediate Cell and Cell 3 is highly
contaminated with organic and inorganic constituents. Warzyn
(1986) Indicated the source of this contamination to be the
Intermediate Cell. A report written by U.S. EPA (U.S. EPA, 1985}
stated that the source of contamination in this area may be
either Firepond 1 or Cell 3. CECOS contends that Cell 3 is not
leaking. Monitoring data provided to members of the Task Force
indicates that contamination of the Cell 3 underdrains is less
than the contamination of the monitoring wells between Cell 3 and
the Intermediate Cell. This Information suggests that the source
of contamination in. this part of the northwest area is
originating from firepond 1 and/or the Intermediate Cell, not
Cell 3.
Contamination has also been found in the 880 Sand beneath
this shallow sand. CECOS concluded that this contamination is due
either to vertical migration through the Upper Till or migration
through the annulus of poorly sealed wells. The Task Force
determined there also may be direct hydraulic communication
between the Upper Sand and the 880 Sand in this area.
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Well KP 246 has historically shown chlorinated organic
contamination. This was also confirmed by the Taste Force
analytical results. This well is located near the northwest
corner of Cell 2 and is screened in till Just below a. sand seam
at 885 feet: msl. This sand is probably directly ccnnected to
Cell 2. It has not been determined if this sand is the Upper
Sand or the 880 Sand. The Tasfc Force agrees with the Warzyn
(1986) recommendation that the extent of this contaminated sand
zone must be determined.
Well M 11 and HP 248B are located alone, the northeast border
of Cell 2. Well M 11 has shown elevated concentrations of TOX in
the past. However, this well has a 30 foot screen, and it is
uncertain which sand zone is the source of the contamination.
Taslc Force results which indicate contamination in MP 248B were
as foilows:
TOX 247 ppb
POC 8 ,300 ppb
Ammonia Nitrogen 13,000 ppb
Total Chromium 42 ppb
These results have been found to be acceptable during the TasJc
Force QA\QC review. Table 9 is a comparison of Task Force
analytical results for TOX, POC, ammonia nitrogen, and total
chromium from wells across the site screened in the 880 Sand.
Assuming these values represent background concentrations for the
site, it is apparent that the concentrations in MP 248B are 5 to
10 times higher than the other 880 Sand wells sampled.
Historically, MP 248B has not shown elevated concentrations of
these analyses. Therefore, the Tasfc Force concluded that these
-------
results indicate a contaminant plume has advanced into this area,
originating from Cell 2.
The Task Force recommends that the extent of the
contamination found in this area of the site be further
investigated and that the identity of the compounds that compose
the elevated TOX values be determined. Corrective action must be
initiated in this area to halt the advance of this plume.
b. Firepond 4/5 - Sanitary Landfill. The area between Fire-
pond 4/5, Cell 4/5, and the Sanitary Landfill contains a number
of monitoring wells that have been sampled and show
contamination. In the past well MP 200 has shown vinyl chloride
contamination. The Task Force sampled well MP 200R and found
vinyl chloride along with purgeable organic carbon (POC) and
purgeable organic halogenated carbon (POX). The Task; Force
detected the following constituents in the wells shown:
Well MP200R
Vinyl Chloride 17 ppb
POC 4,800 ppb
POX 11 ppb
Well MP261
Acetone 13 ppb
Well MP261A
Unknown Semi-volatile Organic 14 ppb
25 ppb
Well MP244AR
Unknown Semi-volatile Organic 14 ppb
Well MP219A
POC 870 ppb
Tfl
-------
Well MP220AR
Dichlorofluoromethane 6 ppb
POC 540 ppb
TOX 62 ppb
These results confirm CECOS's suspicion that there Is
contamination In the ground water In this area. Facility
representatives have reported an increase in conductivity and TOX
values In wells MP 200, HP 219A, MP 220A, and MP 244A. Facility
representatives have stated (Warzyn, 1986) that the source of
this contamination is landfill gas from the Sanitary Landfill.
The Tasfc Force has concluded that the source of this
contamination has not been adequately determined by CECOS. It
could be Cell 4/5, Flrepond 4/5, the Sanitary Landfill, or any
combination of them. Further investigation into the source of
this contamination is needed.
c. Cell 6. Well MP 227, located just north of Cell 6, was
sampled by the Task Force, with the following results:
. «
Benzene 1.1 ppb
Toluene 2.4 ppb
Phenol 3.3 ppb
CECOS's analytical results have indicated that low levels of
volatile organic compounds are present in this well. CECOS. has
alleged that this contamination of the well occurred during
construction or sampling of the well. The Task Force recommends
that the extent of this contamination be investigated further to
determine if CECOS's allegation is correct or if this is an
indication of contamination migrating from Cell 6.
-------
d. Veil M 26. Well M 26 is located at the southern end of
the Sanitary Landfill. The Task Force sampling results indicate
that the ground water in this well had 13 ppb of acetone and 53
ppb of an unknown semi-volatile organic compound. An October
1985 sampling of this well by CECOS found TOX at 475 ppb and COD
at 228 ppm, both very high values that may indicate at least
periodic releases of contamination in this area. The Task Force
recommends that this area be included in the assessment studies
being conducted at the site.
e. Underdrains. CECOS has found that underdrains U 4, U 5,
U 6, and U 7 under Cell 3 and U 9, U 10, and U 12 under Cell 12
4/5 are contaminated. The Task Force has confirmed these
findings with its analyses of U 4 and U 12. The Task force also
analyzed U13 (Cell 6), U17 (Cell 7), U 22 (Cell 8), and U 24
(Cell 9). The Task Force analyses found the following total
selenium levels in the underdrains:
U 4 5.1 ppb
U 24 12.2 ppb
0 22 7.6 ppb
U 13 10.5 ppb
U 17 22.9 ppb
Some of these values exceeded the Primary Drinking Water
Standard of 10 ppb for selenium. Few wells were found to contain
selenium and it is not known whether or not this element is
naturally occurring in the soil at the site or may be caused by
the synthetic liners used by the facility. In view of these
findings, the Task Force recommends further investigation into
the source of selenium in these underdrains is necessary.
-------
M. Summary of Findings and Recommendations
Hazardous Waste Units
1. The Solidification Basin was used between July and
December 1981 and therefore is subject to the
requirements of 40 CFR 265. A closure plan for the
Solidification Basin has never been submitted as required
under 40 CFR 265.112.
2. The topsoil from the Spray Irrigation Field C was
excavated to build Cell 7. It is not known whether this
topsoil was treated as hazardous waste or used as
construction material.
3. Retentions ponds are used to hold ground water from
dewatering activities. The Tas)c Force concluded that if
hazardous waste constituents appear in the pond, then
these ponds should be considered hazardous waste units.
Waste Handling
4. The waste analysis plan (WAP) fails to meet the
requirement of 40 CFR 265.13 and must be rewritten. The
following topics need to be addressed:
a. Sampling and analysis procedures should be specified
on the Waste Product Record by the the generator to
indicate how the waste stream was analyzed.
b. The Task Force disagrees with CECOS's contention that
the generator bears sole responsibility to identify and
classify the waste on the Waste Product Record.
c. The Task Force observed that the sampling protocols in
the WAP were not followed. The Task Force believes that
CECOS can not identify all off specification waste using
the current sampling protocols. Sampling protocols
should be specified and followed to obtain representative
samples of entire incoming shipments of waste.
d. Drums of waste without "bung holes" are not opened or
sampled routinely. This is an example of where off-
specification waste can go undetected. Generators should
use lids with bung holes on all barrels or CECOS should
routinely check the barrels without the holes.
5. The Task Force observed a potential surface water
contamination problem near the truck wash. The overspray
from the truck wash and water that comes in contact with
yard vehicles is drained through a catch bsisin to
Pleasant Run Creek. Run-off from the access roads in the
facility also drain into the creek.
81
-------
Hvdroqeoloqv
6. The Task force finds that hydrogeological information in
the eastern portion of the site below the elevation of
845 feet (msl) is inadequate. The 840 and 850 Sands may
be more extensive than CECOS has interpreted and other
Lower Till sands may be present. The Task Force
recommends that:
a. Exploration borings be installed at the locations
shown on Figure 13.
b. The borings must be continuously sampled to bedrock
below the elevation of 850 feet and include a five-foot
core of bedrock in order to obtain the missing
Information.
7. There is no information on the flow direction in the 840
Sand .
8. The Task Force finds that all unconso1idated sands above
bedrock should be considered the uppermost aquifer.
9. The Task Force recommends that all future borings be
continuously sampled and logged except those borings
adjacent to previous borings that were continuously
sampled.
Ground Water Monitoring
10. The Task Force found that the existing and proposed
ground water monitoring systems failed to meet the
requirements of 40 CFR 265.90 and 265.91. These systems
are inadequate in the following areas:
a. an inadequate definition of uppermost aquifer;
b. inadequate number of upgradient and downgradient wells
capable of yielding representative samples; and
c. wells included in these systems with inadequate
construction, logs or construction diagrams.
11. The Task Force recommends that the ground water
monitoring system include several upgradient well nests.
Wells proposed that are not adequately constructed (e.g.,
M series wells) should be replaced if used.
12. Improperly constructed wells not intended to be replaced
should be plugged and abandoned.
13. Due to the complexity of the hydrogeology at the site and
the effect of dewaterlng and cell walls, the Task Force
recommends that CECOS generate flow maps quarterly to
reevaluate whether the ground water monitoring system is
-------
adequate. Major events that effect ground water flow
(e.g. start-up or shutdown of dewatering wells) should be
recorded.
Sampling and Analysis
14. The Task Force found the sampling and analysis plan (SAP)
to be inadequate. Some of the inadequacies are:
a. The plan consists of several documents. It must be
consolidated into one document.
b. The protocol for decontamination of the pump used to
sample the underdrains is inadequate.
c. Dguipment blanks should be incorporated into the QA\QC
procedures.
15. The Tas)c Force observed a number of deficiencies in
CECOS's sampling procedures (see section H 3 b )
16. Water level measurements are taken over too Long of a
time span. Water level measurements should be taX:en over
a shorter period, no more than five consecutive days.
Preparation. Evaluation, and Kespons?
17. The Tas)c Force found the ground water quality assessment
to be inadequate due to Inadequate determination of rate
and extent of contamination. Additional monitoring wells
are needed.
RCRA Permit Application
18. The Task Force found the revised RCRA permit application
(December 1986 submittal) to be inadequate.
a. All ground water monitoring data must be submitted
with tart B RCRA permit application.
b. The uppermost aquifer has not been adequately defined.
The Task Force determined that the uppermost aquifer
should include all unconsolidated deposits above bedrock.
Further investigation is needed in the eastern portion of
the site to define the deposits below an elevation of 850
feet (msl).
c. A deficient Point of Compliance was proposed in that
the wells were not adequately spaced along the perimeter
of the hazardous waste management areas and did not take
into account pumping conditions at the site.
d. Contamination exists at the site. If a regulated unit
is leaking (e.g., Firepond 4/5), then a description and
-------
delineation of the plume(s) on a topographic map must be
submitted in the RCRA permit application.
e. The ground water monitoring system proposed in the
Part B or the RCRA permit application is inadequate based
upon: 1) an inadequate definition of the uppermost
aquifer, 2) inadequate plume delineation, and 3) inade-
quacy of the location and construction of some of the
existing wells.
f. CECOS has proposed a detection monitoring system in
the eastern portion of the site and the Tasfc Force
determined more supporting data and analyses are required
to justify detection monitoring in this portion of the
site.
g. Because ground water contamination exists at the
site, CECOS should implement a compliance monitoring
program for that portion of the facility affected by the
contamination. CECOS should continue monitoring under
this program until some type of corrective action plan is
implemented.
h. The Part A of the RCRA permit epplication does not
have a description of all processes used at the facility.
i. The waste analysis plan (WAP) and closure plan are
inadequate.
Offsjte Laboratory
i
19. The Task Force found deficiencies with the quality
control practices of the Howard Laboratories. No
problems were found with ETC laboratories for Appendix
VIII samples analyzed for CECOS.
Ground Water Quality Interpretation
20. The extent of contamination in the sand deposit to the
north of Cell 2 must be determined.
21. The advance of the contamination plume to well HP 248B,
north of Cell 2, needs to be halted with corrective
action. Corrective action around the Intermediate
Landfill, Cell 1 and Firepond 1 is also needed.
22. Further investigation into the source of contamination
and the need for corrective actions is needed in the
areas of:
a. Cell 4/5 and the Sanitary Landfill,
b. Cell 6,
c. the underdrains, for selenium.
-------
REFERENCES
Bennett and Williams, Inc., (August) 1985, Geological and
Hydrogeological Assessment of the Aber Road Hazardous Waste
Facility, Clermont County, Ohio.
CECOS International, Inc., (July) 1985a, Proposed Interim Ground
Water Monitoring Program.
CECOS International, Inc., (November) 1985b, Guide for Sampling
Groundwater Monitoring Wells.
CECOS International, Inc., (November) 1986, Proposed Ground Water
Monitoring Program CECOS International, Inc., Aber Road
Facility Williamsburg, Ohio.
Ecological Analysts, Inc., (September) 1983, Proposed Ground-
water Quality Monitoring Plan For CECOS International Aber
Road Secure Landfill Jackson Township, Clermont County,
Ohio.
Goldman, Benjamin A., and others, 1986, Hazardous Waste
Management - Reducing the Risk (Council on Economic
Priorities), Island Press.
Life Systems, Inc. and PRC Environmental Management, Inc.,
(September) 1985, Hazardous Waste Groundwater Task Force
Facility Assessment Program - Quality Assurance Project
Plan.
Soil and Material Engineers (S&ME), Inc., (September) 1986a,
CECOS International Construction Certification SCMF No. 10 -
Aber Road Facility - Clerraont County, Ohio (S4ME Project
Number 023-85-018).
Soil and Material Engineers (SiME), Inc., (October) 1986b, CECOS
International - Hydrogeologic Assessment SCMF NO. 11 - Aber
Road Facility - Clermont County, Ohio (S&ME Project Number
021-85-211-1.1) .
U.S. EPA, (November) 1985, Memorandum - Analyses of Ground Water
Chemical Concentration Measurements Collected from CECOS,
International Facility in Williamsburg, Ohio.
U.S. EPA, (May) 1986, On-site Evaluation of the Environmental
Testing and Certification Corporation (ETC), Edison, New
Jersey, U.S. EPA Region V Quality Assurance Office.
U.S. EPA, (September) 1986a, Hazardous Waste Ground-Water Task
Force - Protocol for Ground-Water Evaluations.
U.S. EPA, (September) 1986b, RCRA Ground-Water Monitoring
Technical Enforcement Guidance Document.
85
-------
REFERENCES (Cont.l
U.S. EPA, (November) 1986c, Quality Assurance Project Plan
Ground Water Monitoring Evaluation - CECOS International
Aber Road Facility - Wllllamsburg, Ohio.
U.S. EPA, (May) 1987, On-Site Evaluation of Howard Laboratories,
U.S. EPA Region V Quality Assurance Office.
Versar, Inc., (September) 1985, Draft - Monitoring Services
Operations - Standard Operating Procedures - Minimum
Standards and Guidelines of Operations - Ground Water
Sampling
Warzyn Engineering, Inc., (May) 1986, The Groundwater Assessment
Program - Aber Road Facility.
86
-------
TABLES
-------
TABLE 1
Parameter Sampling Order, Bottle Type, and Preservative
List
Sampl i ng
Order
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
Parameter
Field measurements
Volatile organics
Purgeable organic
carbon (POC)
Purgeable organic
halogens (POX)
Extractable organics
Pesticides/herbi cides
Total metals
Dissolved metals
Total organic carbon
(TOC)
Total organic halogens
(TOX)
Phenols
Cyanide
Nitrate and ammonia
Sulfate and chlorine
Field measurements
200
2 -
1 -
1 -
4 -
2 -
1 L
1 L
1 -
1 L
1 L
1 L
1 L
1 L
200
Bottle Type
mL plastic
40 mL VOA vials
40 mL VOA vials
40 mL VOA vials
1 L. amber glass
1 L. amber glass
. plastic
. plastic
120 mL glass
. amber glass
. amber glass
. plastic
. plastic
. plastic
mL plastic
Preservatives*
None
Cool 4°C
Cool 4°C
Cool 4°C
Cool 4°C
Cool 4°C
HN03 2 mL
(to pH <2)
HN03 2 mL
(to pH <2)
H2S04 2 mL
(to pH <2)
Cool 4°C
Cool 4°C
no headspace
H2S04 2 mL
(to pH <2)
Cool 4°C
NaOH 2 mL
(to pH >12)
Cool 4°C
H2S04 2 mL
(to pH <2)
Cool 4°C
Cool 4°C
None
* Preservative Concentrations:
HN03 - 1:1 dilution of 35% solution
H2S04 - concentrated (98%)
NaOH - 400 g/L (10 normal)
-------
TABLE 2
(Taken from Warzyn, 1986)
HYDRAULIC CONDUCTIVI
wen
Comment
Elevation of
Tested Zone
TY TEST RESULTS
Type of Test1
UPPER TILL
MP-253
MP-254
MP-254
MP-255A
MP-257A
MP-259
MP-260A
MP-256A
MP-252A
MP-254A
MP-25SA
MP-2S5A
MP-2248
MP-261A
MP-201
MP-262
1 FH-R -
FH-U -
Weathered, 1 ft
sand i gravel
Weathered
Weathered
Weathered
Weathered
fathered
Weathered
Weathered
Weathered with
2 sand seaus
Weathered
Weathered
Upper S*nd
Upper S«nd
Weathered
* SEE
* SEE
888-890
882-884
876-879
888-890
890-893
886-889
901-905
898-900
882-887
877-882
882-891
845-894
897-900
882-891
TEXT *
TEXT *
FH-R
FH-R
FH-R
FH-R
FH-R
FH-R
FH-R
FH-U
Balldown test
B*1ldcwn test
B* 11 down ttst
Bt.1l down Ust
8*11 down t*sf.
Ball down te$i:
Puaplng test
Puaplng test
Hydraulic
Conductivity
(CBi/sec)
7.5 x 10'9
1.2 x 10'7
8.0 x 10"9
2.5 x 10'9
5.3 x 10'9
4,0 x 10"9
1.1 x 10"8
2.4 x 10*7
8.0 x IO"5
2.0 x IO"6
2.0 x IO"6
2.0 x 10'6
1.0 x IO"4
7.0 x 10'7
1.4 x IO"5
1,7 x IO"4
Laboratory Falling Head, remolded saeplt.
Laboratory Falling Head, undisturbed saople.
-------
TABLE 2 (CONTINUED)
Hell
Comment
Elevation of
Tested Zone
Type of Test1
1 FH-R • Laboratory Falling
FH-U • Laboratory Falling
Head, refolded swple.
Head, undisturbed sanp!«.
Hydraulic
Conductivity
880 SAND
MP-256A 2' Sand
MP-201 3' Sand
MP-223AR 0' Sand
MP-201 3' Sand
MP-202 2* Sand
MP-223A 2.5' Sand
LOWER TILL
MP-252
MP-252
MP-252
MP-253
MP-256
MP-257
MP-258
MP-258A
MP-259
MP-259
MP-260
MP-261
MP-255
MP-253
871-874
870-873
867-879
870-873
879-881
866-870
869-873
857-859
844-849
868-865
865-865
872-876
865-868
856-863
867-869
846-848
853-860
864-867
862-864
862-864
FH-R
Balldown Test
Ball down Test
Pumping Test
Pionplng Test
Puaplng Test
FH-R
FH-R
FH-R
FH-R
FH-R
FH-R
FH-R
FH-R
FH-R
FH-R
FH-R
FH-R
FH-U
FH-U
(cm/sec)
6.4 x 10"9
2.0 x 10'3
3.0 x 10"4
6.0 x 10"2
1.0 x 10"1
1.0 x 10'1
4.0 x 10'9
6.0 x 10"9
2.9 x 10"8
3.8 x 10"9
5.3 x 10"9
4.5 x 10"9
4.7 x 10'9
7.4 x 10*9
4.0 x 10"9
2.9 x 10"8
1.7 x 10'8
1.1 x 10"8
8.0 x 10"9
6.0 x 10"9
-------
TABLE 2 (CONTINUED)
Comment
Elevation of
Tested Zone
Type of Test
Hydraulic
Conductivity
BEDROCK
MP-252
MP-253
MP-254
MP-255
MP-256
MP-257
MP-258
MP-259
MP-260
MP-261
MP-252
MP-253
MP-254
MP-259
L1»estone-Shale
Limestone-Shale
LInestone-Shale
L1«stone-Shale
Limestone-Shale
Limestone-Shale
Limestone-Shale
LInestone-Shale
LInestone-Shale
Limestone-Shale
Tin-B«drock
Till -Bedrock
Till-B«drocx
TW-B«droct
824-842
829-848
829-846
838-852
831-849 .
834-853
833-850
824-842
825-843
835-853
842-848
850-853
849-857
841-650
Packer
Packer
Packer
Packer
Picker
Packer
Packer
Packer
Packer
Packer
Balldown
Ball down
8*11 down
B4 11 down
_ _ _ . „ j
Icai/secj
3.0 x 10"10
1.0 x 10"7
5.0 x 10"10
1.0 x 10"10
1.0 x 10"9
1.0 x 10~8
4.0 x 10"8
4.0 x 10"8
1.0 x 10"9
8.0 x 10"9
6.0 x 10"5
7.0 x 10'4
1.0 x 10"5
5.0 x 10'4
Ccic-68]
-------
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-------
EXISTING
WELL
TABLE 4: GRGUNDWATER MONITORING SYSTEMS
UFFER SAND WELLS
EX I STING
RCFA
MONITORING
SYSTEM t
E* I STING
TSCA
MONITORING
SYSTEM
EXISTING
PTI
MONITOR I
PROPOSED
COMPREHENSIVE
MONITOP ING
S /STEM * *
207A
207P
2070
2<;>4C
M 18
M 4 1
MP
MR
MP
MP
MF
MP
MP
MR
MP
MP
MR
MR
MP
MP
MP
ftp ..
MP 235A
MP 235CR
MP" 244AR
X
X
X
X
20o8
207
209R
2 ISA
220AR
2229
224E-
271 A
71AR
A
246
MP 24SB
MP
MP
MP
55A
MP 257A
UNDERDRAINS
U 4
U 9
U 10
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
* TAKEN FROM: PRELIMINARY REPORT INTERIM GROUND WATER MONITORING
PROGRAM ABER ROAD FACILITY (CECOS. l^SSA).
** TAKEN FROM: PROPOSED GROUND WATER MONITORING PROGRAM
(NOVEMBER, 1^66).
-------
EXISTING
WELL
TABLE 5: GROUND WATER MONITORING SYSTEMS
880 SAND WELLS
EXISTING
RCRA
MONITOR ING
SYSTEM *
EXISTING
TSCA
MONITORING
SYSTEM
EXISTING
PTI
MONITORING
SYSTEM
PROPOSED
COMPREHENSIVE
MOM I TOR ING
SYSTEM **
M
M
M
M
M
M
M
M
M
M
M
M
M
M
M
MP
MP
MP
MR
'MR
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
6
7
<9
11
15
18
26
2?
28
36
41
43
45
47
2
200
200R
201
202
20 3R
204R
204A
204B
205A
205AR
205BR
206
206CR
208
210A
211B
212A
212C
212D
213A
214B
214BR
216B
216BR
217A
217B
219A
X
X
X
X
X
X
X
X
X
X
X
X
X
x
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
-------
TABLE 5 (CONTINUED): GROUND WATER MONITORING SYSTEMS
EXISTING
WELL
EXISTING
RCRA
MONITOR ING
SYSTEM *
880 SAND WELLS
EXISTING
TSCA
MONiTORiNG
SVSTEM
EXISTING
RTI
MONITOR I NG
SYSTEM
PROPOSED
COMPREHENSIVE
MONITORING
SVSTEM * *
MF 21C'AR
MF1 22'! A
MF ZZT-^F
MR 227A
MP 227AR
MP 228A
MR 228AR
MP 229B
MF 22^&
MR 27<~>A
MR 272A
MF 277A
MP 277AR
MP 274AR
MR 274B
MP 275B
MP 275BR
MR 278A
MR 241A
MP 241AR
MR 242AR
MP 244A
MP 245
MP 247
MP 247A
MP 248A
MP 249B
MP 250A
MP 251A
MP 252A
MP 257A
MP 254A
MP 259A
MP 261A
MP 262
x
X
X
X
X
X
X
X
X
X
X
y
X
X
X
x
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
* TAKEN FROM: PRELIMINARY REPORT INTERIM GROUND WATER MONITORING
PROGRAM ABER ROAD FACILITY (CECOS, 1985A).
** TAKEN FROM: PROPOSED GROUND WATER MONITORING PROGRAM
(NOVEMBER, 1986).
-------
EXISTING
WELL
TABLE 6: GROUND WATER MONITORING SYSTEMS
LOWER TILL (INCLUDING 84O AND 85O WELLS)
EXISTING
RCF'A
MONITORING
SYSTEM *
EXISTING
TSCA
MONITORING
SYSTEM
EXISTING
PTI
MONITORING
SYSTEM
PROPOSED
COMPREHENSIVE
MONITQRING
SYSTEM **
M 4
M 21
M 22
MP 2
MP
MP
MP
X
X
X
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
210
21 OR
211
21 1R
212
217
217R
214AR
215
215B
215BR
216
217
219
220
227A
224
225
226
227
228
231R
231BR
232
235
236
238
239
240R
242AR
249A
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
MP 250
X
X
X
X
X
X
X
X
X
X
X
X
X
X
* TAKEN FROM: PRELIMINARY REPORT INTERIM GROUND WATER MONITORING
PROGRAM ABER ROAD FACILITY (CECOS, 1985A).
** TAKEN FROM: PROPOSED GROUND WATER MONITORING PROGRAM
(NOVEMBER, 1986).
-------
TABLE 7; GROUND WATER MONITORING SYSTEMS
BEDROCh TILL INTERFACE WELLS
EXISTING EXISTING EXISTING PROPOSED
RCRA TSCA PTI COMPRHENSIVE
EXISTING MOM I TOP I NO MONITORING MONITORING MONITORING
WELL S/STEM * SVSTEM SVSTEM SVSTEM **
M 4
MP 200
MP 20"A X
MP 2 I 4^ x X
MP 217R X X
MP 218 X X
MP 220R X X
MP 221 X
MP 22 IF x x
MP 222 X
MP 222R < X
MP 227 <
MP 227R * X
MP 227R
MP 228
MP 228R X X
MP 230R X X
MP 27 IP
MP 277 X
MP 27AR x
MP 277 X X
MP 278R X
MP 241R X
MP 242 X X
MP 243 X X
MP 244R X
MP 248 X X
MP 249 X X
MP 251 X X
MP 252 X
MP 253 X
MP 254 ' X
MP 256 X
MP 257 • X
MP 258 ' X
•MP 261 X
* TAI-EN FROM: PRELIMINARY REPORT INTERIM GROUND WATER MONITORING
PROGRAM ABER ROAD FACILITY (CECOS, 1985A).
** TAHEN PROM: PROPOSED GROUND WATER MONITORING PROGRAM
(NOVEMBER, 1^86).
-------
TABLE 8 - HELL AW BORING TOTAL DEPTHS THE EASTERN PORTION OF THE SITE
Hells
n i
N 4
H 15
H 20
H 31
H 32
n 43
n 48
H 49
H 50
HP 1
IIP 2
W 203
NP 204
W 205A
flP 206CR
HP 209A
HP 210R
HP 211
IIP 212
W> 213R
Iff 214R
» 215
BP-216
HP 217R
HP 230R
HP 231R
HP 232
If 233
HP 251
Depth
(feet)
18
34
34
63
7
98
44
87
37
21
•>
•>
53
43
54
41
143
64
62
62
61
96
80
62
79
86
120
62
62
102
Bottoi of Hell
(feet elev.)
TOO
852
882
854
?
814
869
822
872
888
•>
i
877
875
861
874
780
848
850
851
830
815
829
848
819
823
796
846
846
810
Boring
11-1
11-1A
11-2
11-2A
11-3
11-3A
11-4
11-4A
11-5
11-6
11-7
11-8
11-9
11-10
11-11
11-12
11-13
11-14
11-15
11-16
12-1
11-37
OB-10-7A
Depth
(feet)
70.5
26
71
36
71
36
85
36
78
86
W
105
79
22
87
71
27
26
20
16
103
i
7
Bottoi of Hell
(feet elev.)
•>
-i
843
882
840
875
823
873
830
823
810
812
835
841
833
840
841
841
847
845
818
i
i
-------
Table 9
ANALYTICAL RESULTS FOR THE TASK FORCE
SAMPLES OF THE S30 SAND
TOTAL AMMONIA
WELL CHROMIUM NITROGEN POC TOX
M-3 ND
M--26 ND
MF-206 ND
MF-208 13
MF-217A 11
MP-219A ND
MP-229B ND
MP-232A 10
MP-246 ND
MP-749B 13
MF-249E 20
MP-253A ND
MP-256A 7
MP-261A NA
MP-21SBR ND
MP-227 8
ND
ND
1400
400
900
400
400
ND
200
300
4OO
ND
700
NA
1400
150O
ND
ND
650
ND
ND
870
ND
ND
160
ND
ND
ND
ND
ND
ND
ND
9. 9
20
7. 2
ND
1 1
ND
ND
ND
*jo
ND
ND
24
6. 5
NA
ND
28
Note: All results are in parts per billion
NA - not analyzed
ND - not detected
-------
FIGURES
-------
-------
FIGURE 1
CECOS International
Aber Road Facility
Wllliamsburg, Ohio
Facility Location Diagram
71
LLIAMSBURG
2 MILES
Approx. SCAL£ i:
e
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FIGURE 5
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-------
-------
-------
APPENDIX A
Sampling Information
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APPENDIX B
QA/QC Summary of TasV Force Data
-------
MEMORANDUM
DATE: March 26, 1987
SUBJECT: Evaluation of Quality Control Attendant to the Analysis of Samples
from the CECOS, Ohio Facility
FROM Ken Partymillcr, Chemist
PRC Environmental Management
THRU: Paul H. Friedman, Chemist*
Studies and Methods Branch (WH-562B)
TO: HWGWTF: Tony Montrone*
Garcth Pearson (EPA 8231)*
Richard Stcimle, HWGWTF*
Joe Fredlc, Region V
Maxine Long, Region V
Steve Mangion, Region I
This memo summarizes the evaluation of the quality control data generated
by the Hazardous Waste Ground-Water Task Force (HWGWTF) contract analytical
laboratories (1). This evaluation and subsequent conclusions pertain to the
data from the CECOS, Ohio sampling effort by the Hazardous Waste Ground-Water
Task Force.
The objective of this evaluation is to give users of the analytical data a
more precise understanding of the limitations of the data as well as their
appropriate use. A second objective is to identify weaknesses in the data
generation process for correction. This correction may act on future analyses
at this or other sites.
The evaluation was carried out on information provided in the accompanying
quality control reports (2-3) which contain raw data, statistically transformed
data, and graphically transformed data.
HWGWTF Data Evaluation Committee Member
-------
The evaluation process consisted of three steps. Step one consisted of
generation of a package which presents the results of quality control
procedures, including the generation of data quality indicators, synopses of
statistical indicators, and the results of technical qualifier inspections. A
report on the results of the performance evaluation standards analyzed by the
laboratory was also generated. Step two was an independent examination of the
quality control package and the performance evaluation sample result!! by
members of the Data Evaluation Committee. This was followed by a meeting
(teleconference) of the Data Evaluation Committee to discuss the foregoing data
and data presentations. These discussions were to come to a consensus, if
possible, concerning the appropriate use of the data within the contex1: of the
HWGWTF objectives. The discussions were also to detect and discuss specific or
general inadequacies of the data and to determine if these are correctable or
inherent in the analytical process.
Preface
The data user should review the pertinent materials contained in the
accompanying reports (2-3). Questions generated in the interpretation of these
data relative to sampling and analysis should be referred to Rich Steirnle of
the Hazardous Waste Ground-Water Task Force.
I. Site O*erylew
The CECOS, Ohio facility is located near Williamsburg, Ohio which is
approximately 30 miles east of Cincinnati. The facility started operation in
the early 1970's as a sanitary landfill and expanded into the hazardous waste
business. Today, the facility is strictly a hazardous waste landfill with no
active sanitary areas. Presently the landfill is filling its tenth cell and
constructing its eleventh. All of the cells arc lined. There arc a number of
dewatcring pumps around each ceil due to the high water table in the area. The
facility accepts just about all types of hazardous waste, including PCBs, which
a landfill can be permitted to accept.
The geology of the area is rather complex. Above bedrock there are
numerous sand seams intermixed with clay. There are, therefore, a number of
sand zones which need to be monitored. The facility has in excess of 200
monitoring wells. During the HWGWTF monitoring study, samples from three wells
in the upper sand zone, 18 wells in the intermediate sand (refered to as the
880 sand), several bedrock wells, and a water seep into the eleventh, and as
yet unused, cell, were collected. Six underdrains or sumps were also sampled.
These sumps, which were required by provisions of the Toxic Substances Control
Act, were placed under each cell to allow the monitoring of any leakage.
Ground-water contamination already exists at the facility and, therefore,
the facility is under RCRA assessment. Historically, volatile solvents,
including mcthylene chloride, as well as PCBs, and other chemicals have been
detected in various of the monitoring wells.
Forty field samples including two field blanks (MQO942/QO942 and
MQO969/QO969), two equipment blanks representing the two lots of bailers used
at the facility (MQO962/QO962 and MQO976/QO976), a trip blank (MQO939/QO939), a
pump blank from the portable venturi pump used to collect samples from the
underdrains (MQO965/QO965), a sample bottle blank of the type used by CECOS
-------
which was filled with dcionized water (MQO972/QO972), and three pairs of
duplicate samples (well MP249B, samples MQO945/QO945 and MQO946/QO946, well
MP222B, samples MQO955/QO955 and MQO956/QO956, and underdrain U-4, samples
MQO977/QO977 and MQO978/QO978) were collected at this facility. Samples
MQO955/QO955 and MQO956/QO956 were medium concentration matrix ground-water
samples. Samples MQO966/QO966, 968, 971, 973, 975, 977, and 978 were the low
concentration matrix samples collected from the waste cell underdrains. Sample
MQO966/QO966 corresponded to underdrain U24 which had its own dedicated pump_.
All other underdrains which were monitored (U4, U12, U13, CTl7, and U22)
required a portable venturi pump for sampling. Sample MQO970/QO970 was the low
concentration matrix ground-water seep flowing into the not yet completed cell
number 11. All other samples were low concentration matrix ground-water
samples from the monitoring wells.
II. Evaluation of Quality Control Data and Analytical Data
1.0 Metals.
1.1 Performance Evaluation Standards
Metal analyte performance evaluation standards were not evaluated in
conjunction with the samples collected from this facility.
1-2 Metals QC Evaluation
Total and dissolved metal spike recoveries were analyzed for twenty-three
metals spiked into three low concentration matrix samples (MQO945, 963, and
977) and one (of two) medium concentration matrix samples (MQO955 or 956). Not
all metals were spiked into both of these samples. Twenty-two total and
eighteen dissolved metal average spike recoveries from the low concentration
matrix samples were within the data quality objectives (DQOs) for this Program.
Total and dissolved antimony average (of three values) spike recoveries were
outside DQO with values of 67 and 226 percent. Various individual metal spike
recoveries from the low concentration matrix samples were also outside DQO.
These are listed in Tables 3-la, 3-lc, 3-2a, and 3-2c of Reference 2 as well as
in the following Sections. The dissolved calcium and magnesium spike
recoveries were not calculated because the sample concentrations of these
metals were greater than four times the concentration of the spike. A listing
of which samples were spiked for each analyte is also available in Tables 3-2a
and 3-2c of Reference 2,
Fourteen total and seventeen dissolved of twenty-three metal spike
recoveries from the medium concentration spiked samples were within Program
DQOs. Only one medium concentration matrix sample was spiked for each total
and dissolved metal. The total beryllium, cobalt, lead, nickel, selenium,
thallium, and zinc and dissolved lead and selenium spike recoveries were
outside DQO with values of 72, 70, 41, 70, 762, 36, 62, 48, and 23 percent,
respectively. The total iron and manganese and dissolved calcium, iron,
manganese, and sodium spike recoveries were not calculated because the sample
concentrations of these metals were greater than four times the concentration
of the spike. A listing of which samples were spiked for each analyte is
available in Tables 3-2b and 3-2d of Reference 2.
-------
The calculable average relative percent differences (RPDs) for all
metallic analytes in the low concentration matrix samples, except for total
aluminum, were within Program DQOs, The calculable RPDs for all metallic
analytes in the medium concentration matrix samples were within the DQOs. RPDs
were not calculated for about two-thirds of the metal analytes because the
concentrations of many of the metals in the field samples used for the RPD
determination were less than the CRDL and thus were not required, or in some
cases, not possible to be calculated.
Required analyses were performed on all metals samples submitted to the
laboratory.
No metal contamination was reported in the laboratory blanks. Dissolved
zinc was found in field blank MQO942 and portable venturi pump blank MQO965.
Total zinc was found in pump blank MQO965 and field blank MQO969. Dissolved
chromium was found in equipment blank MQO962 and field blank MQO969. Dissolved
lead was found in equipment blank MQO962 and pump blank MQO965. Total lead was
found in pump blank MQO965. Total iron was found in pump blank MQO965. All of
these total and dissolved metals were found at concentrations above their
CRDLs. These metals and their concentrations and CRDLs are listed in Section
3.1.4 of Reference 2 as well as in the appropriate Sections below.
1-3 Furnace Metals
The quality control for the graphite furnace metals (antimony, arsenic,
cadmium, lead, selenium, and thallium) was generally acceptable.
All three dissolved antimony spike recoveries from the low concentration
matrix samples were above DQO with values of 214, 250, and 214 percent. Due to
the reproducability of these results, there may have been problems with the
preparation of the antimony spike solution. This had no effect on the
dissolved antimony data quality as none was detected in any samples. All total
and dissolved antimony results for low concentration matrix samples should be
considered quantitative. Dissolved antimony duplicate injection precision for
medium concentration matrix sample MQO956 was outside DQO. Dissolved antimony
results for this sample should be considered semi-quantitative. For medium
concentration samples, all total antimony results and dissolved antimony
results for sample MQO955 should be considered quantitative.
Duplicate injection precision for total arsenic in medium concentration
matrix sample MQO955 was outside DQO. The sample was reanalyzed a second time
and the duplicate injection precision was not calculable. Based upon these
results, it was not possible to determine if arsenic was present in this
sample. High levels of dissolved solids may have caused the problems. Arsenic
results for this sample should not be used. Method of standard addition (MSA)
analysis should have been run on dissolved arsenic for low concentration matrix
sample MQO953. Results for this sample should be considered qualitative. The
MSA correlation coefficient for total arsenic in sample MQO949 was below
control limits. Arsenic results for this sample should be considered
qualitative. The matrix spike recovery of dissolved arsenic from low
concentration matrix sample MQO945 was 72 percent which is below DQO. This was
considered insignificant as the other two arsenic spike recoveries, as well as
the average spike recovery, were all within DQO limits. No reason for this was
given. Field duplicate precision for total arsenic in duplicate pair
-------
MQO945/946 was poor. See Note (1) at the end of this Report for a discussion
of why field precision results are not used in the determination of data
quality. Total and dissolved arsenic results,'with exceptions, in the low
concentration matrix samples should be considered quantitative. The dissolved
arsenic results for the medium concentration matrix samples should also be
considered quantitative. Total arsenic results for medium concentration matrix
sample MQO956 should be considered quantitative. Total arsenic results for
sample MQO949 and dissolved arsenic results for sample MQO953, both low
concentration matrix samples, should be considered qualitative. Total arsenic
results for medium concentration matrix sample MQO955 should not be used.
The dissolved cadmium matrix spike recovery for low concentration matrix
sample MQO963 was above DQO with a value of 128 percent. This was considered
insignificant as the other two dissolved cadmium spike recoveries, as well as
the average spike recovery, were all within DQO limits. MSA analysis should
have been run on total cadmium for medium concentration matrix sample MQO956.
These problems were judged not to affect ovelall data quality and all cadmium
results should be considered quantitative.
The total and dissolved lead spike recoveries from the medium
concentration matrix spiked samples (total lead MQO956 and dissolved lead
MQO955) and one dissolved lead spike recovery from one of the three low
concentration matrix spiked samples (MQO963) were outside DQO with values of
41, 48, and 154 percent, respectively. The high spike recovery for the low
concentration matrix result was considered insignificant as the other two low
concentration matrix dissolved lead spike recoveries, as well as the average
spike recovery, were all within DQO limits. Dissolved lead contamination was
found in equipment blank MQO962 at a concentration of 744 ug/L (CRDL equals 5
ug/L). Total and dissolved lead were also found in pump blank MQO965 at 8.4
and 136 ug/L, respectively. Due to this contamination, dissolved lead results
for samples MQO971 and 973 and total lead results for sample MQO968 (all three
are underdrain samples) should not be used. See Note (2) at the.end of this
Report for a discussion of how blank contamination affects sample results. The
correlation coefficient for the MSA analysis of total lead in samples MQO944,
948, 950, 957, 965, and 968 and dissolved lead in samples MQO965 and 971 was
outside of DQO. Total lead results for samples MQO944, 948, 950, 957r 965, and
968 and dissolved lead results for sample MQO971 should not be used. Dissolved
lead results for sample MQO965 should be considered qualitative. Total, with
an exception, and dissolved low, with exceptions, concentration matrix lead
results should be considered quantitative. Total and dissolved lead results
for the medium concentration matrix samples and dissolved lead results for low
concentration matrix sample MQO965 should be considered qualitative. Total
lead results for medium concentration matrix sample MQO955 and low
concentration matrix samples MQO944, 948, 950, 957, 965, and 968 and dissolved
lead results for low concentration matrix samples MQO971 and 973 should not be
used.
The total and dissolved selenium spike recoveries from the medium
concentration matrix spiked samples (total selenium MQO956 and dissolved
selenium MQO955) and one dissolved selenium spike recovery from one of the
three low concentration matrix spiked samples (MQO945) were outside DQO with
values of 762, 23, and 73 percent, respectively. The low spike recovery for
the low concentration matrix result was considered insignificant as the other
two low concentration matrix dissolved selenium spike recoveries, as well as
-------
the average spike recovery, were all within DQO limits. The dissolved selenium
analytical spike recovery for medium concentration matrix samples MQO955 and
956 were below control limits with values of 23 and 7 percent, respectively.
Selenium results for these samples should be considered to be biased very low
tnd should not be used. All other selenium results should be considered
quantitative. Field duplicate precision for total selenium in duplicate pair
MQO977/97S was poor. See Note (1) at the end of this Report for a discussion
of why field precision results are not used in the determination of data
quality.
The total thallium spike recovery from the medium concentration matrix
spiked sample (MQO956) and one dissolved thallium spike recovery from one of
the three low concentration matrix spiked samples (MQO977) were outside DQO
with values of 36 and 131 percent. The high spike recovery for the low
concentration matrix result was considered insignificant as the other two low
concentration matrix dissolved thallium spike recoveries, as well as the
average spike recovery, were all within DQO limits. All thallium results, with
one exception, should be considered quantitative. Total thallium results for
the medium concentration matrix samples should be considered to be qualitative.
The usability of all total and dissolved graphite furnace analytes is
summarized in Sections 4.0 and 4.1 at the end of this Report.
1.4 ICP Metiis
Total ::inc contamination was found in the portable venturi pump blank
(MQO965) and a field blank (MQO969) at concentrations of 53 and 51 ug/L,
respectively. Dissolved zinc contamination was found in the pump blank
(MQO965) and a field blank (MQO942) at concentrations of 30 ug/L, each. The
CRDL for ::inc is 20 ug/L. Due to this contamination, total zinc results for
samples MQO940, 941, 943, 944, 946, 950. 954, 955, 957. 963, 966. 968, 973.
974, 975, and 977 and the dissolved zinc results for samples MQO943, 944, 945,
946, 947, 948, 949, 951, 953, 954, 955, 956, 957, 959, 967, 971, 973, and 975
should be considered unusable. The remaining low concentration matrix total
ind dissolved zinc results should be considered quantitative. Dissolved
chromium contamination was found in an equipment blank (MQO962) and a field
blank (MQO969) at concentrations of 18 and 27 ug/L, respectively. The CRDL for
chromium is 10 ug/L. In spite of this contamination, dissolved chromium
results for samples MQO970, 971, 977, and 978 should be considered
quantitative. The remaining dissolved chromium results should be considered
unusable as they are within a factor of five of the highest level of blank
contamination. Total iron contamination was found in the portable venturi pump
blank (MQO965) at a concentration of 246 ug/L. The CRDL for iron is 200 ug/L.
The usability of iron results were not affected by this portable vcntuti pump
contamination and all total iron results should be considered quantitative.
Note (2) at the end of this Report contains a discussion of how blank
contamination affects sample results.
The low level (twice CRDL) linear range check for total and dissolved
chromium, copper, and zinc and dissolved nickel and silver exhibited poor
recoveries on various analysis dates (sec Section B5 of Reference 3 for
inorganics for a detailed listing). The low level linear range check is an
analysis of a solution with elemental concentrations near the detection limit.
The range c:hcck analysis shows the accuracy and recovery which can be expected
-------
by the method for results near the detection limits. The relatively poorer
accuracy reported for these metals is not unexpected. The recoveries of these
metals from the range check solutions determine the biases in the results which
are listed below. Total chromium and copper results for samples MQO940 through
954, 957 through 960, and 962 through 964 should be considered to be biased low
by approximately 30 to 40 percent. Total chromium results for samples MQO965
and 978 should be considered to be biased low by approximately 60 percent.
Total copper results for samples MQO955 and 956 should be considered to be
biased low by approximately 30 percent. Total copper was not recovered from
samples MQO965 and 978 therefore results for these samples should be considered
unreliable. Dissolved chromium and copper results for all samples except
MQO955, 956, 961, 963, and 975 should be considered to be biased low by
approximately 30 percent. Dissolved chromium results for sample MQO963 should
be considered to be biased high by approximately 30 pefcent. Dissolved copper
results for samples MQO955, 956, 963, and 975 should be considered to be biased
low by approximately 30 percent. Total zinc results for samples MQO965 and 978
should be considered to be biased low by approximately 45 percent. Dissolved
zinc results for sample MQO963 should be considered to be biased low by
approximately 25 percent. Dissolved silver results for sample MQO963 should be
considered to be biased low by approximately 35 percent. Dissolved nickel
results for samples MQO955, 956, and 975 should be considered to be biased low
by approximately 10 percent.
Individual matrix spike recoveries, for samples which were designated as
low concentration by the sampling team, were outside DQO for dissolved iron in
sample MQO963 with 69 percent recovery and for dissolved manganese in sample
MQO977 with 74 percent recovery. These results were judged to have no impact
on the data quality as they represented only one of three matrix spikes for
each metal. Total beryllium, cobalt, nickel, and zinc matrix spike recoveries
in medium concentration matrix sample MQO955 were below DQO with recoveries of
72, 70, 70, and 62 percent, respectively. Results for these four total metals
in the medium concentration matrix samples should be considered to be biased
low and semi-quantitative.
The serial dilution results were greater than 10 percent different from
the original determination (outside DQO) for total barium, iron, and manganese
in medium concentration matrix sample MQO95S and for dissolved iron, magnesium,
manganese, and sodium in low concentration matrix sample MQO963. Poor serial
dilution results can be an indication of physical interferences, such as high
solids loading of the samples, in the analyses. Such interferences usually
yield results with a negative bias and thus a low recovery. Results for these
metals in the specified samples should be considered semi-quantitative.
Laboratory duplicate results for total aluminum in low concentration
matrix sample MQO945 was outside DQO. This result caused no impact on the
aluminum results as it represented only one of three duplicates.
The field duplicate precision for total and dissolved iron in duplicate
pair (MQO945/946) was poor with RPDs of 25 and 23 percent, respectively. The
field duplicate precision for total zinc in medium concentration matrix
duplicate pair (MQO955/956) was poor with 49 ug/L reported in the first sample
and no total zinc reported in the other sample. Sec Note (1) at the end of
this Report for a discussion of why field precision results arc not used in the
determination of data quality.
-------
Usability of all total and dissolved ICP metal analytes is summarized in
Sections 4.2 and 4.3 at the end of this Report
1.5 Mercury
One of three individual matrix spike- recoveries was outside DQO for total
mercury in low concentration matrix sample MQO977 with 60 recovery. This was
considered insignificant as the other mercury matrix spike recoveries were
within DQO limits. All mercury results should be considered quantitative.
2.0 Inorganic and Indicator Analvt;s
2-1 Performance Evaluation Standard
Inorganic and indicator analytc performance evaluation standards were not
evaluated in conjunction with the samples collected from this facility.
2.2 Inorganic and Indicator Amlvte QC"Evaluation
The average spike recoveries of all of the inorganic and indicator
analytes, except for chloride in the medium concentration matrix sample were
within the accuracy DQOs (accuracy DQOs have not been established for bromide
and nitrite nitrogen matrix spikes). The chloride spike recovery (only one
sample spiked) was 87 percent in the medium concentration matrix sample The
bromide and nitrite nitrogen average spike recoveries were 98 and 100 percent
in the low concentration matrix samples and 112 and 118 percent in the medium
concentration matrix sample.
Average RPDs for all inorganic and indicator analytes were within Program
DQOs. The RPDs were not calculated if either one or both of the duplicate
values were less than the CRDL. Precision DQOs have not been established for
bromide and nitrite nitrogen.
Requested analyses were performed on all samples for the inorganic and
indicator analytes. The ion chromatography (1C) sample bottle for sample
MQO9SO was not received by the laboratory.
No laboratory blank contamination was reported for any inorganic or
indicator anaiyte. Sampling blank contamination involving POX, TOX, and/or
total phenols was found in one or more of the sampling blanks at levels above
CRDL. These contaminants and their concentrations are listed below, as well as
in Section 3.2.4 (page 3-3) of Reference 2.
-.3 Inorganic and Indicator Analvtc Data
All results for bromide, chloride, sulfatc, cyanide, ammonia nitrogen, and
TOC should be considered quantitative with an acceptable probability of false
negatives.
The matrix spike recovery for nitrite nitrogen from the medium
concentration matrix spiked sample was above DQO with a value of 118 percent.
This was not judged to have a significant impact on the quality of the data.
The holding times for the nitrate and nitrite nitrogen analyses ranged from 3
-------
to 15 days from receipt of samples which is longer than the recommended 48 hour
holding time for unpreserved samples. Nitrate and nitrite nitrogen results for
samples MQO940, 943, 945 through 949, 951 through 959, 963, 964, 966, 968, and
969 should be considered semi-quantitative. All other nitrate and nitrite
nitrogen results should be considered to be quantitative. The laboratory
received no ion chromatography (1C) sample MQO950, therefore, there were no
nitrate and nitrite nitrogen results for this sample.
The matrix spike recovery of chloride from one of three low concentration
matrix spiked samples was above DQO with a value of 115 percent. This was not
judged to have a significant impact on the quality of the data as the other two
chloride matrix spike recoveries were within DQO limits. Two of the three sets
of chloride field duplicates (lo.w concentration matrix duplicate pair
MQO977/978 and medium concentration matrix duplicate pair MQO955/956) had large
RPDs of 19 and 24 percent. See Note (1) at the end of this Report for a
discussion of why field precision results are not used in the determination of
data quality. All chloride results should be considered quantitative. The
laboratory received no ion chromatography (1C) sample MQO950, therefore, there
were no chloride results for this sample.
All bromide results should be considered quantitative. The laboratory
received no ion chromatogriphy (1C) sample MQO950, therefore, there were no
bromide results for this sample.
Two of the three sets of sulfate field duplicates (low concentration
matrix duplicate pair MQO945/946 and medium concentration matrix duplicate pair
MQO955/956) had excessive RPDs of 27 and 22 percent See Note (1) at the end
of this Report for a discussion of why field precision results are not used in
the determination of data quality. All sulfate results should be considered
quantitative. The laboratory received no ion chromatography (1C) sample
MQO950, therefore, there were no bromide results for this sample.
The trip blank and both of the equipment blanks contained total phenols
contamination at levels of 13, 13, and 17 ug/L which are greater than the total
phenols CRDL of 10 ug/L. Due to this blank contamination (see Note (2) at the
end of this Report for further explanation), total phenols results for samples
MQO941, 943, 945 through 951, 954, 957, 958, 960, 968, 975, 977, and 978 should
be considered unusable. All other total phenols results should be considered
quantitative.
Calibration verification standards for POC were not analyzed. A POC spike
solution was run during the analytical batch but the "true" value of the spike
was not provided by the laboratory. EPA needs to supply the inorganic
laboratory with a POC calibration verification solution. Until then, the
instrument calibration can not be assessed. One of three low concentration POC
laboratory duplicates was outside DQO with an RPD of 11 percent. This was not
judged to affect overall POC data quality as results for the other laboratory
duplicates were acceptable. One of three sets of field duplicates (medium
concentration matrix duplicate pair MQO955/956) showed poor precision with an
RPD of 11 percent See Note (1) at the end of this Report for a discussion of
why field precision results are not used in the determination of data quality.
POC holding times ranged from 9 to 12 days. Although the EMSL/Las Vegas data
reviewers recommend a seven day holding time, the laboratory has been
-------
:;: that a 14 day holding time is
rcred qualitative.
coratory duplicates was outside DQO
.dged to affect overall TOX data
.plicates were acceptable. Both
pump blank, and the bonle blank
, 13, 13, and 6.6 ug/L which are
'o the blank contamination (see Note
:a:r.pks MQO977 and 978 should be
..-nples MQO941, 943, 944, 950
;gh 9~5 should not be usc:d. TOX
.tions of chloride above 500 mg/L
avc enhanced the TOX results for
_l:rc'.i quantitative except for
-..Tsidcred qualitative and samples
\ 963, 971, and 973 through 973
-,ed POX contamination at a level of
- of 5 ug/L. Due to this blank
' Report) POX results for samples
-,c PCX holding times ranged from 5
."A rc'-iewcrs recommend a seven day
:cd by the EPA Sample Management
sic. The POX results should be
..IQO975, 977 and 978 which should not
';rds were not evaluated in conjunction
; : V.
cept 1,1-dichloroethene, were
icy. Individual matrix spike
DQO will be discussed in the
ike average recoveries were within
; acid fraction of the scmivolatilcs
e samples. Surrogate spike
DQO will be discussed in the
fc average RPDs were within Program
: RPDs which were outside the
^priate Sections below. All average
-------
Laboratory blank contamination was reported for organics and is discussed
in Reference 3 (for organics) as well as the appropriate Sections below.
Detection limits for the organic fractions are summarized in Reference 3
(for organics) as well as the appropriate Sections below.
3.3 Volatile^
Quality control data indicate that volatile organics were determined
acceptably. The chromatograms appear acceptable. Initial and continuing
calibrations, tunings and mass calibrations, matrix spikes and matrix spike
duplicates (with an exception), surrogate spikes, and holding times were
acceptable. Some laboratory blank contamination was reported.
The 1,1-dichloroethene matrix spike and matrix spike duplicate recoveries
for samples QO963 and 977 were in the range of 160 to 176 percent, which is
above the DQO range of 61 to 145 percent for 1,1-dichloroethcne. As 1,1-
dichloroethene was only detected in sample QO960 at a concentration of 10 ug/L,
this value should be considered qualitative and biased high.
Estimated method detection limits were CRDL for all samples except QO960
(2 times CRDL), QO956 (333 times CRDL), and QO955 (417 times CRDL). Dilution
of these samples was required due to high concentrations of organics. The high
dilutions of samples QO955 and 956 may results in false negatives.
Six laboratory blanks contained methylenc chloride. Three laboratory
blanks contained acetone, and one laboratory blank contained total xylenes.
These common laboratory contaminants were present at levels in the vicinity of
the CRDL. Acetone results for sample QO957 and methylene chloride results for
samples QO951, 952, 957, 958, 961, 962, 967, 968, 969, 970, 971, 972, 973, 974,
975, 976, 977, and 978 should not be used due to this laboratory blank
contamination. Methylene chloride results for samples QO956, 960, 963, 965,
and 966 should be considered qualitative due to the blank contamination.
According to contract procedures, VOA instrument blank CD861122A12 was
unacceptable because total xylenes contamination (8.1 ug/L) above the CRDL (5
ug/L) was detected. The blank was not rerun as no samples contained this
compound. There was no impact on the data.
The volatiles data are acceptable. The volatile compound results should
be considered quantitative with the exceptions mentioned above for acetone and
methylcne chloride. False negatives for the medium concentration matrix
samples (QO955 and 956) should be considered a possibility due to large sample
dilutions. The probability of false negative results for all other compounds
in all low concentration samples is acceptable.
3.4 Semivolatiles
Initial and continuing calibrations and chromatograms were acceptable for
the semivolatiles. In some instances, problems were encountered with tunings
and mass calibrations, blanks, matrix spikes and matrix spike duplicates,
surrogate spike recoveries, and holding times.
The estimated detection limits for the semivolatiles were approximately
twice the CRDL.
-------
The matrix spike (MS) and/or matrix spike duplicate (MSD) recoveries of
pyrene from samples QO963MS and 977MSD were above the DQO range of 26 to 127
percent with values of 130 percent each. The matrix spike (MS) and/or matrix
spike duplicate (MSD) recoveries of pentachlorophenol from samples QO945MS and
MSD and 2-chlorophenol from sample QO977MSD were below their DQO ranges of 9 to
103 and 27 to 123 percent with values of 6, 4, and 23 percent, respectively.
The RPD between the MS and MSD for pentachlorophenol in sample pair QO945MS/MSD
and phenol in sample pair QO977MS/MSD exceeded the DQO limit.
One or more of the phenol-D5, 2-fluorophenol, and 2,4,6-tribromophenol
(acid) surrogate spikes in samples QO945, 951, 953, 953RE (reanalysis), 954,
954RE, 955, 955RE, 956, 956RE, 960, 966, 971, 971RE, 972, 975, 975RE, 977, 978,
and 978RE were either not recovered or their recovery wis below the DQO range.
The terphenyl-D14 surrogate spike recoveries from samples QO939, 960, arid 963MS
(matrix spike sample analysis) were above the DQO range with recoveries of 158,
147, and 146 percent, respectively. A systematic error may have caused the
high recovery of the terphenyl-DI4 surrogate spike in these three samples.
One of the semivolatile instrument blanks contained an unknown contaminant
at a concentration of 11 ug/L. The list of semivolatile tentatively identified
compounds was not submitted for samples QO943 and 977.
The semivolatile holding time for sample QO971 was exceeded by three days.
This did not affect data quality for this sample.
The semivolatile data are acceptable and. the results should be considered
quantitative for all samples with exceptions. All semivolatile acid fraction
results for samples QO945, 951, 960, 966, 972, 977, and 978 should be
considered semi-quantitative due to poor surrogate recoveries. All
semivolatile base/neutral fraction results for samples QO939 and 960 should
also be considered semi-quantitative due to poor surrogate recoveries. The
acid fraction results for samples QO953, 954, 955, 956, 971, and 975 and the
reanalysis of all of these samples should be considered unreliable due to the
lack of surrogate recovery data. Results for sample QO971 should be considered
unreliable because of the lack of surrogate data and the absence of a tune
prior to analysis. The probability of false negatives for all samples, with
the exception of the acid fraction results for the samples mentioned above is
acceptable,
3.5 Pesticides
The initial and continuing calibrations, blanks, matrix spike/matrix spike
duplicates, surrogate spikes, holding times, and chromatography for pesticides
were acceptable.
The estimated pesticide method detection limits were approximately CRDL
for all samples. The probability of false negative results for all samples is
acceptable,
Non-pesticide contamination was present in samples QO952 (packs 03 and
07), QO966, 971, and 973 (pack 03).
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4.3 Dissolved ICP Metals
Quantitative:
Semi-quantitative:
Unusable:
all aluminum, barium, beryllium, calcium, cobalt, copper,
nickel, potassium, silver, and vanadium results for both
matrices; all iron, magnesium, manganese, and sodium
results for the medium concentration matrix samples; all
zinc results with exceptions; chromium results for low
concentration samples MQO970, 971, 977, and 978
all low concentration matrix results for iron, magnesium,
manganese, and sodium
all medium concentration matrix zinc results; low
concentration matrix zinc results for samples MQO943
through 949, 951, 953, 954, 957, 959, 967, 971, 973, and
975; all chromium results with exceptions
4.4 Mercury
Quantitative: all mercury results
4.5 Inorganic and Indicator Analvtes
Quantitative:
Semi-quantitative:
Qualitative:
Unusable:
4.6 Qraanics
Quantitative:
Semi-quantitative:
Qualitative:
Unreliable:
Unusable:
all bromide, chloride, sulfate, cyanide, ammonia nitrogen,
and TOC results; nitrate nitrogen, nitrite nitrogen, total
phenols, TOX, and POX results with exceptions listed below
nitrate and nitrite nitrogen results for samples MQO940,
943, 945 through 949, 951 through 959, 964, 966, 968, and
969; POX results for samples MQO939, 960, 961, 963, 965,
966, 967, 969, and 970 through 978
all POC results; TOX results for samples MQO977 and 978
total phenols results for samples MQO941, 943, 945 through
951, 954, 957, 958, 960, 968, 975, 977, and 978; TOX
results for samples MQO941, 943, 944, 950 through 953, 958,
960, 968, 971, and 973 through 975; POX results for samples
MQO975, 977, and 978
all volatile and pesticide results; semivolatile results
with exceptions
semivolatile acid fraction results for samples QO945, 951,
960, 966, 972, 977, 977MSD, and 978; semivolatile
base/neutral fraction results for samples QO039 and 960
acetone (volatile) results for sample QO957 and methylene
chloride results for samples QO956, 960, 963, 966, and 965
semivolatile acid fraction results for samples QO953, 954,
955, 956, 971, and 975 and the reanalyses of these samples;
all semivolatile results for sample QO971
methylene chloride (volatile) results for samples QO951,
952, 957, 958, 961, 962, 967, 968, 969, 970, 971, 972, 973,
974, 975, 976, 977, and 978
-------
The pesticides results should be considered quantitative with an
acceptable probability of false negatives.
Notes:
(1) The comparative precision of field duplicate resulu is not used in the
evaluation of sample results. It is not possible to determine the source of
this imprecision. This poor precision may be reflective of sample to sample
variation rather than actual sampling variations. Thus, field duplicate
precision i:s reported for informational purposes only.
(2) Blank contamination is judged to have the following affect on simple
results for the contaminant only. All negative sample results and positive
sample results greater than ten times the concentration of the highest blank
concentration (for the contaminant) should be considered quantitative unless
there are Cither data quality problems. All positive sample results greater
than five but less than ten times the concentration of the highest blank
concentration should be considered qualitative. All positive sample results
less than five times the highest blank concentration should be considered
unusable. The detection limit for the contaminant should be considered to be
raised to five times the level of the highest blank contamination. Other data
quality problems may further reduce the quality of these determinations.
-------
III. Data Usability Summary
4.0 Total Graphite Furnac; Metals
Quantitative: all antimony, cadmium, selenium, and thallium low
concentration matrix results; arsenic and lead low
concentration matrix results with exceptions; all antimony,
cadmium, and selenium medium concentration matrix results;
arsenic medium concentration matrix results for sample
MQO956
Qualitative: lead and thallium medium concentration matrix results;
arsenic low concentration matrix results for sample MQO949
Unusable: arsenic medium concentration matrix results for sample
MQO955; lead low concentration matrix results for samples
MQO944, 948, 950, 957, 965, and 968
4-1 Dissolved Graphite Furnace Metals
Quantitative: all antimony, cadmium, selenium, and thallium low
concentration matrix results; arsenic and lead low
concentation matrix results with exceptions; all arsenic,
cadmium, and thallium medium concentration matrix results;
antimony medium concentration results for sample MQO955
Semi-quantitative: antimony medium concentration matrix results for sample
MQO956
Qualitative: all lead medium concentration matrix results; arsenic low
concentration matrix results for sample MQO953; lead low
concentration matrix results for sample MQO965
Unusable: all selenium results for medium concentration matrix
samples; lead results for low concentration matrix samples
MQO971 and 973
4.2 Total ICP Metals
Quantitative: all aluminum, calcium, chromium, copper, iron, magnesium,
potassium, silver, sodium, and vanadium results for both
matrices; manganese and zinc results for both matrices with
exceptions
Semi-quantitative: all barium, beryllium, cobalt, nickel, iron, and manganese
medium concentration matrix results
Unusable: zinc results for medium concentration sample MQO955; zinc
results for low concentration samples MQO940, 941, 943,
944, 946, 950, 954, 957, 963, 966, 968, 973 through 975,
and 977
-------
4.3 Dissolved 1C? Metals
Quantitative:
Semi-quantitative:
Unusable:
4.4 Mercury
Quantitative:
all aluminum, barium, beryllium, calcium, cobalt, copper,
nickel, potassium, silver, and vanadium results for both
matrices; all iron, magnesium, manganese, and sodium
results for the medium concentration matrix samples; all
zinc results with exceptions; chromium results for low
concentration samples MQO970, 971, 977, and 973,
all low concentration matrix results for iron, magnesium,
manganese, and sodium
all medium concentration matrix zinc results; low
concentration matrix zinc results for samples MQO943
through 949, 951, 953, 954, 957, 959. 967, 971, 973, and
975; all chromium results with exceptions
all mercury results
4.5 Inorganic and Indicator AnaNtes
Quantitative:
Semi-quantitative:
Qualitative:
Unusable:
4.6 Qraanics
Quantitative
Semi-quantitative:
Qualitative:
Unreliable:
Unusable:
all bromide, chloride, sulfatc, cyanide, ammonia nitrogen,
and TOC results; nitrate nitrogen, nitrite nitrogen, total
phenols, TOX, and POX results with exceptions listed below
nitrate and nitrite nitrogen results for samples MQO940,
943, 945 through 949, 951 through 959, 964, 966, 968, and
969; POX results for samples MQO939, 960, 961, 963, 965,
966, 967, 969, and 970 through 978
all POC results; TOX results for samples MQO977 and 978
total phenols results for samples MQO941, 943, 945 through
951, 954, 957, 953, 960, 963, 975, 977, and 978; TOX
results for samples MQO941, 943, 944, 950 through 953, 958,
960, 968, 971, and 973 through 975; POX rcs'ults for samples
MQO975, 977, and 978
all volatile and pesticide results; scmivolatile results
with exceptions
semivolatile acid fraction results for samples QO945, 951,
960, 966, 972, 977, 977MSD, and 978; semivolatile
base/neutral fraction results for samples QO039 and 960
acetone (volatile) results for sample QO957 and methylcne
chloride results for samples QO956, 960, 963, 966, and 965
scmivolatile acid fraction results for samples QO953, 954,
955, 956, 971, and 975 and the reanalyses of these samples;
all scmivolatile results for sample QO971
methylenc chloride (volatile) results for samples QO951,
952, 957, 958, 961, 962, 967, 968, 969, 970, 971, 972, 973,
974, 975, 976, 977, and 978
-------
IV. References
1. Organic Analyses: CompuChem Laboratories, Inc.
P.O. Box 12652
3308 Chapel Hill/Nelson Highway
Research Triangle Park, NC 27709
(919) 549-8263
Inorganic and Indicator Analyses:
Centec Laboratories
P.O. Box 956
2160 Industrial Drive
Salem, VA 24153
(703) 387-3995
2. Draft Quality Control Data Evaluation Report (Assessment of the Usability
of the Data Generated) for site 58, CECOS, Ohio, 2/3/1987, Prepared by Lockheed
Engineering and Management Services Company, Inc., for the US EPA Hazardous
Waste Ground-Water Task Force.
3. Draft Inorganic Data Usability Audit Report and Draft Organic Data Usability
Report, for the CECOS, Ohio facility. Prepared by Laboratory Performance
Monitoring Group, Lockheed Engineering and Management Services Co., Las Vegas,
Nevada, for US EPA, EMSL/Las Vegas, 2/13/1987.
-------
-------
APPENDIX C
Analytical Results of Task Force Samplinq
-------
-------
CECOS Landfill
Initial In Situ
Field Parameters
Final In Situ
Field Parameters
Location
MP220AR
MP249B
MP208
MP229B
MP219A
MP256A
M41
MP215BR
MP227
M3
M26
MP248B
MP206
MP222B
MP244AR
MP253A
MP246
MP261A
MP222R
MP261
temp. pH Sp Cond.** Date/Time
12°C 6.6 1095 umhos 11-13/0933
13°C 6.5 1576 umhos 11-13/1433
11.8°C 6.7 1625 umhos 11-14/1030
11.8°C 6.8 1139 umhos 11-14/1420
13.4°C 6.7 1000 umhos 11-13/0930
9.0°C 7.6 1100 umhos 11-13/1417
12.4°C 7.3 650 umhos 11-13/1622
11.7°C 7.0 950 umhos 11-14/1303
11.0°C 10.9 1050 umhos 11-14/1604
14. 1°C 7.1 1263 umhos 11-17/1235
13.5°C 6.9 meter not 11-17/1225
operating
13.3°C 6.7 2071 umhos 11-17/1610
14.9°C 6.6 1050 umhos 11-18/0912
14.7°C 6.7 >50000 umhos /0947
(off scale)
(end 1st sample event)
14.78C 7.1 825 umhos 11-18/1225
14.0°C 6.8 700 umhos 11-18/1507
13.4°C 6.8 1413 umhos 11-19/0900
13.7°C 7.0 11-187
13.6°C 7.7 771 umhos 11-197
12.8°C 7.3 750 umhos 11-197
temp. pH Sp Cond.** Date/Time Meters*
11.0°C 7.0 1034 umhos 11-13/1112
10.3°C 6.7 2943 umhos 11-137
11°C 6.7 1638 umhos 11-14/1139
11.8°C 6.8 1136 umhos 11-14
14.0°C 7.0 950 umhos 11-13/1100
11.8°C 7.4 900 umhos 11-14/1100
13.2°C 7.3 650 umhos 11-13/1718
ll.Q°C 6.9 1000 umhos 11-14/1400
12.4°C 10.9 1000 umhos 11-17/1000
13.5°C 7.2 1153 umhos 11-177
13.7°C 6.8 561 umhos 11-17/1319
12.8°C 6.6 2527 umhos 11-17/1726
13.4°C 6.7 1000 umhos 11-18/1025
14.7°C 6.0 >50000 umhosll-18/1120
(off scale)
13.3°C 6.8 750 umhos 11-18/1632
12.7°C 6.9 850 umhos 11-19/1239
-
12.8°C 7.9 856 umhos 11-197
11.9°C 7.3 800 umhos 11-19/1654
1,3
1,3
1,3
1,3
2,4
2,4
2,4
2,4
2,4 1st
2,3 2nc
1,4
1,3
1,3
2,3
1,4
2,3
2,3
1,47
2,3
4
1,4
2,3
* 1-YSI Cond Meter 10855 2-Cole Parmer Cond Meter #1273 3-pH Cole Partner #433290
4-pH Cole Parmer #433251.
-------
CECOS Landfill (Continued)
Initial In Situ
Field Parameters
Final In Situ
Field Parameters
Location
MP200R
||.?4
II ??
-------
SUMMARY OF CONCENTRATIONS FOB COMPOUNDS FOUND
IN GROUND-WATER AMD SAMPLING
BLANK SAMPLES AT SITE 58, CECOS, OH
The following table list* the concentrations for compounds analyzed for
and found in samples at the »ite. Table A2-1 is generated by listing
all compounds detected and all tentatively identified compounds reported
on the organic Form I, Part B. All tentatively identified compounds
with a spectral purity greater than 850 are identified by name and
purity in the table. Those with a purity of less than 850 are labeled,
unknown.
Sample numbers are designated by the inorganic and corresponding organic
sample number. Inorganic sample numbers are preceded by the prefix
**MQO" organic sample numbers are preceded by the prefix "QO."
Samples Q0955 and 0^)956 were re-extracted and reanalyzed for BNAs. The
TIC* detected in the reanalyses of these samples are not reported in the
following table.
A2-1
-------
TABU KZY
A value without a flag indicates a result above the contract
required detection limit (CBDL).
J Indicates an estimated valua. Thii fl«E is used aithar when
estimating • concentration for tentatively identified compounds
where a 1:1 response is assumed or when the macs rp«ctrml data
indicated the presence of a compound that m«ets the identification
criteria but the result is less than the specified detection limit
but greater than rero. If the limit of detection is 10 vs »nd a
concentration of 3 vs is calculated, then report as 3J.
B This flai, is used when the analjrta is found in the blank as well as
a sample. It indicates possible/probable blank contamination and
warns the data user to take appropriate action.
CU • ground-water
SW • surface-water
low and medium are indicators of concentration.
A2-2
-------
The pesticides results should be considered quantitative with an
acceptable probability of false negatives.
Notes:
(1) The comparative precision of field duplicate results is not used in the
evaluation of sample results. It is not possible to determine the source of
this Imprecision. This poor precision may be reflective of sample to sample
variation rather than actual sampling variations. Thus, field duplicate
precision is reported for informational purposes only.
(2) Blank contamination is judged to have the following affect on sample
results for the contaminant only. All negative sample results and positive
sample results greater than ten times the concentration of the highest blank
concentration (for the contaminant) should be considered quantitative unless
there are other data quality problems. All positive sample results greater
than five but less than ten times the concentration of the highest blank
concentration should be considered qualitative. All positive sample results
less than five times the highest blank concentration should be considered
unusable. The detection limit for the contaminant should be considered to be
raised to five times the level of the highest blank contamination. Other data
quality problems may further reduce the quality of these determinations.
-------
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CAS? *0:
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SITE: 39 CECOS, OH
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CASE MO'. 63I3/SA?'1«44HQ
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SITE: 58 CETOS. OH
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A2-15
-------
CITE! 56 CECOS. OH
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A2-16
-------
NO!
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A2-18
-------
ITE: » CETOS- OH
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1
i
1
i
i
1
!
1
1
1
1
1
I
I
1
I
1
1
I
1
1
1
1
,
1
|
1
1
A2-1Q
-------
-ITE: 58 cicos- OH
CASE «: «H3/S*S/19*4HQ
SAMPLE HO!
SAMPLE LOCATION
TYPE:
THALLIW
VANAJIW1
- ZINC
I NOW. WWONIA «TT?06tH
iHDIC.
CHLORIDE
CYANIDE
NITRATE
NITRITE NITROGEN
POC
POX
SULFATE
TOC
TOTAL
TOX
WELL «P200f
W-LW
1
1
1
1 300
1 400
1 31000
1
1
t
1
1 11
1 160000
1 2500
1
! 7,6
WELL W241
SV-LN
700
"000
120000
1000
5.8
KQC*64/QO«64
SHOW
800
53000
8
4*0000
4700
12
WELL MP233*
W-LOM
S
27
220000
2000
WELL U-22
400
100
9600
?00
170000
5000
7^
SEEP ?V£LL U
200
200
30000
330000
1400
A2-20
-------
I L> ••«
HO: 63I2/SAS/1944HQ
LOCATION:
TTP£!
MQ0971/8W71
«LL U-13 WOl !M7
SIH.OW 61H.W
WELL «P21'A
S»H.W
U-12
2-WTWOHE
ft£THTL£«
TOLUEH
-1 r2-DIDt Of CE
VIMTL
BIS C-ETHTLHEm ) PHDIALATI
POCTL ALCDHOI.
BEM20IC ACIB
DI-^-OCTYLPHTH/iLATE
PHEWJL
HO HITS
TIC-
';WH>T 1-PUTftHOL
^WPAWL
ETHAMOL» CHLOPOETHOXT
OHAWI.I CHLOPOETHOn SUWT,
CHLOW3ETHO.XT PJFST.
ACID
HDAWIC ACID
3-(M-DI«THYLETHYL)
CAF.POm.IC ACID
CAfKXTLIC ACID
WKKOW
L'^HOWN
UKKMQVN
UMOTUH
UNKHOVH
8.3 B
22 J
11 J
16 J
12 B
4« J
70 J
12 I
2,1 J
45
3,1 J
?.?
<.» J
35
I PUR 969 8 J
29 J
43 J
*4 J
17 J
A2-21
-------
: TE: 58 CEOJSf OH
CAS* NO: *533/SAS/i«44HB
5*»ii HO:
SAMPLE TYPE:
TOT/1 /1UHIHUH
fCTALS AKTIflOHY
MtSOIC
BAftlUH
wmiiiH
CAW1IW
CALCI'Jfl
CHROfllWI
CGMLT
ctmp
IRW
LEAD
HAENESIW1
Jew?SE
KICTIL
POTASSIUM
SELENIUM
SILKR
SOSIPH
THALLIUM
WAPILfl
ZI*C
i-!S, M.UKWJN
CTALS AHTIWOT
AKEMIC
WftlUN
BERYLLltfl
C4MIUH
r^j rt|_i^
oSl'JH
03BALT
COPPffi
IRM
LLAP
MASffSIUM
MAWAfSSE
MERCURY
HICXEL
WTASSIW
SELINIW
SILMS
SCPIIM
HQW71/Q0971
BELL U-13
1 129
i
1 10, i
1 217
1
1
1 187000
1
i 11
1
1 4540
1
1 74*00
1 1680
1
1
1 3460
1 10,5
1
1 30800
1
1
1
,
I
1 26
1 23
1
1
1 345000
1
1 10
i
1 1040
1 12.9
1 131000
1 2330
1
1
1 14900
1
1
| WUWV
WELL IM7
1 136
1
1
1 14
1
1
1 470000
1 17
1 22
1
1 5300
1
1 138000
1580
1
1 30
1 12900
1 22,9
1
1 104000
1
1
1 57
1
1
1
1 2?
\
1
1 «rniw*
1 6
1 13
1
6410
17 9
17^000
19?0
14200
1'iOftftrt
VEU HP217A
8H.W
223
13,9
49
18200"
11
8
30*0
95200
317
4640
62500
-*
19,7
76
2020^0
10
2550
"6900
255
51°0
iOXrtrt
WELL IM2
1020
42
1 1
360000
17
34
19 1
1°600 I
1
13^000
24*)
16700
1
1
96300 1
1
9
113 1
i
1
4.1 1
254 1
1
1
211000 !
7 1
IP
5120
84100 1
1910 !
1
I
'030
1
1
^iArt 1
A2-22
-------
Jlti
SA*PL£ LOCATION:
SAW.! TYPt:
THK1IW
W*BIW
21HC
IWRS. ^fOHIA "UPOK)'
IMJIC, ?pn*.!K
CHLFIPE
CYiwir*
wiTPAH CITP??W
MITRI7I «TWS<
FOC
POT
SUUATI
TOC
TOTAL PHENOLS
TOT
KLL IM3
5*KW
*•
300
300
34000
340
1250W
2100
4
¥01 IM? «1 W217A
6V-LW 6V-IOM
1
I
71 1
*00 1 ?00
!"0 1 190
74000 1 20000
1
90 1
1
120 1
1
13/vwvi | 410000
3500 1 1900
1
1" i 11
«B1 IM2
S^-iOV
i
•
3» 1
330
>8A(Vt
2300
°0
130000
1*00
1?
63
A2-23
-------
APPENDIX Q
Task Force Sampling Parameters
-------
P*
Specific cooductanct
Teaptraturt
Turbidity
Other Parameter^
TOC METHOO 9C60
TOX METHOD 9020
Chloride KETHCO 9252
Total phenols KETHCO 9C66
SuLface METX30 9036 or 9023
Nicrac* HEnCO 9200 •
Amacnia "Mechods for C«ical Ar-alv3i3 Of Wac*r and .« e
wx ofm/wHsF^1' 3/33' Ke^ 35°'L or 350-3
S?° i ^ i ^^ Uac-r- ^^ 22- P- la-**.
Dissolved aecala local rn«cals. and
C/anide 153-WA 3^-7092
-------
VI 1 1
XETHOO 6010
Aland num
Boron
Cadmium
Chromium
Iron
Thallium
Vanadium
Zinc
approved for 6010 but th«y ar« *pprov«d for
?£« CLP -tal* 1C? -thc^ i. identical ta
SW-846/6010.
X«tho4 7470
M«rcury
-------
K347
fall
laitt Co»3v;Oft
n
4414SAS1
uiriit
MU 111 us*
AwttanzH If-
K ttport fc
Contract lot
bctivrii I4-1H4
CaiKHtraiinu
Jate
liti
Co«/lil Facton
PerC»t •OlStari
CAS
74-17-J
74-fM
73-01-4
73-i»-"
75-01-:
67-64-i
75-13-v
l56-aO-5
47-44-2
107-04-2
7B-J3-3
71-33-4
54-23-5
106-O-4
73-27-4
71-97-5
CMxotetfiaae
IroesietNne
Vinyl Chloride
Chioroethine
Setbyltre Dilor:de
*ctta-e
Carbon Suulfide
l,i-3icMsroet?U£»
trws-l ,2-3ul»loro«the!!i
D»lorot'cr»
1,2-iichlcroetham
2-Buta/!oni*
1,1,1-TrichIorQtthMi
CarbM Tetracitioride
Vinyl Acetati
3r otcd : c h 1 or OH t har. e
l,2-8ichloropropant
/preji
n
trt
ii 14-17-14
l.M
r» (Mt eecaoted): \
•f/1
10.
14.
10.
10.
5.0
10.
5.0
5.0
5.0
5.0
3.0
3.3
10.
5.3
5.0
10.
3.0
5.0
II
1
8
9
o
a
u
u
ere the
identification Us been confuted by 6C/HS. S:aqle
CMpofknt pesticides >/« 10nq/»l in the fiaal eitrac*
siould be confined by SC/HS.
His fla^ is ts*d »fce« the analyse is fouad it the
blank as veil as a utple. It indicates possible.'
trooallt blank contajnaatioa and urns tht data user ta
taki aefropriatt action.
V«iut U til rtvilt is l vilst artattr Utan or i^ual t«
» footftett should rttd: lhCo«po«H
•as aealriH for !iut tot ictKtH. Tte nubtr is tbt
ittunibli detection hut for tie uiple.
fodicitts an estiutH valut. Tais flaf is n«d either
^n ntiMtitf i conctatratiot for ttfltatittly ietatif JH
compounds there a 1:1 response is assuiri ar rfiea tie lass
spictril data indicated tie orevnce »f a co«?oand Uiat
»#eti the identification cnteria tut the result is less
the specified detKtioa hut but ereater tbo zero
Other Other specific flaqs and footnotes lay bt required te
properly iefi»e Ibe results. If ased, they rust b«
fully described aftd sucS description attached to the
data salary report.
Fori 1
10/15
-------
iru*7 **»*• *.»:*•-•*
M I 4014UJ1
2)
StsirtUtilt
It ntrutri/prtfirri: 04-17-14
tt MulyiHi
K/fil Fictar:
real Miitirt «tt»tH): 1VI
CAS
hcktr
101-15-2 Kifaoi
Ml-44-4 ln(2-Olyo«tlSfU ithff
15-57H
141-7VI
104-44-7 l,4-9u!>lor&fi*ut5»
100-51-4 l«t«yl Alcohol
421-i*"?
•7-72-1
lt-75-5
105-47-1
tt-37-4
77-47-^
tt-44-2
ki j 1 2-2: lor 3i w?r 057!)
litrobro:t".i
In:oic Atitf
120-C-2 2,
120-C-l l,2,4-Trichlero6tn:rn
11-20-3 I^htiilBf
4-QtlorotfilJM
W-74-4 2HUtrwiiilio«
131-11-3
•1/1
20.
20.
20.
20.
20.
20.
20.
20.
20.
20.
20.
20.
20.
20.
20.
20.
100
20.
20.
20.
20.
21.
20.
20.
20.
20.
20.
100
20.
104
20.
20.
100
0
1
9
a
it
0
u
u
u
u
J
j
IJ
u
u
0
u
u
0
u
9
1
8
0
0
1
0
9
a
8
a
u
0
CAS
fcaber
13-32-4
3I-2f-5
100-02-7
12-44-4
121-14-2
404-20-2
M-44-2
7005-72-!
tt-73-7
tOC-Jl-i
5:4-12-1
w-;o-»
101-55-3
111-74-1
I7H4-5
B-01H
120-12-7
14-74-2
20i-44-0
12«->0-0
B-41-7
tW4J-|
54-5*-3
117H1-7
21H1-1
I1M4-0
205-W-2
W-OI-f
50-12-1
in- 31-5
5>70-3
111-24-2
»Afflt
«o:tt
! Citrictioei Yt*
- Lirii< htrKtiom Ic
4-litrtxhinol
2,4-9ititr3tahnt
4-3r5«C9^wyl
Anthractnt
IruoUltfltVictnt
,2 ,3-cd) WCM
h Inj d,h) jnthr KB*
20.
100
IX
w.
20.
20.
20.
20.
100
li
9
U
L1
U
U
M
U
u
u
20.
20.
2
-------
Saaple Number I
00398 !
Organic* Analysis Data Sheet
(Pag* 3)
Pe«ticid»/PC8s
Concentration: [Low] Hedius (Circlt One)
Data Extracted/Prepared; 06/14/86
Data Analyzed: 06/22/86
Cone/Oil Factor 1.00
CAS
Number
Cug/1 3 or ug/Kg
(Circle One)
319-84-6
31 9-8S-7
31 9-86-?
S3 -8 9- 9
7 & - 4 4 - 8
:io9-oo-a
1 024-57-3
<> 59-93-3
60-57-1
72-55-9
72-20-8
33213-65-9
72-54-8
1 031 -07-8
50-29-3
72-43-5
53494-70-5
57-74-9
8001-35-2
12674-1 1-2
1 1 1 04-23-2
1 1 141-16-5
53469-21-9
12672-29-6
1 1 097-69-1
1 1 096-82-5
Alpha - BHC
Beta - BHC
Delta - BHC
Camma - BHC ( L i ncU n« )
Hept ach 1 or
A Idr i n
H»ptachlor Epoxide
Endosu 1 fin I
D leldr in
4-4' - DDE
Endr in
Endosulfan II
4-4' - ODD
Endosulfan Sulfate
4-4' - DDT
Met ho x ych 1 or
Endr in Ket one
Chlordane
Toxaphene
Aroclor - 1016
Aroclor - 1221
Aroclor - 1232
Aroclor - 1242
Aroclor - 1248
Aroclor - 125-4
Aroclor - 1260
05 U
. 05 U
. 05 U
05 U
OS U
05 U
05 U
05 U
. 1 0 U
. 1 0 U
. 10 U
. 1 0 U
. 10 U
. 1 0 U
. 1 0 U
.50 U
. 1 0 U
.50 U
1.0 U
.50 U
.50 U
.50 U
.50 U
.50 U
1.0 U
1.0 U
V(i) - Volume
V(i.) » Volume
U(s) - Weight
V(t) * Voluae
_ 1000.00_ or U(«)
of extract injected (ul)
of water extracted (ml)
of sample extracted (g)
of total extract (ul)
_ V(t) ..10000.00_ V(
_ 5.0_
Forn 1
-------
APPENDIX E
History of Waste Treatment, Storage, and Disposal Units
-------
TO: Scott Thomas
USEPA Region V Hazardous Waste Ground Water Task Force
ERCM: Mark Monroe/Gary Saylor/John Stirnkorb
SUBJECT: Site Design - Construction - of all inactive and active
disposal cells at the permitted Aber Road Facility
DATE: November 14, 1986
The following is a surcnary of our joint en-site meeting Tuesday, November 11,
1986, to discuss the history of design, construction, use, and closure of each
secure chemical management facility (SCMF), the Solid Waste Sanitary landfill,
fire ponds, the spray irrigation system and the solidification basin.
Attendees at the joint on-site meeting were:
1. Joe Fredle, USEPA Region V
2. Srott Ttxinas, USEPA Region V
3. David Petrovski, USEPA Region V
4. Eruce Sypniewski, USEPA Region V
5. Stephen Mangion, USEPA
6. John Stirnkorb, CECDS
7. Gary Saylor, CECOS
8. Mark Monroe, CECOS
9. John Oneacre, BFI
10. Jim Veith, S & ME
Secure Chemical Management Facility No. 1
1. General Description
a. Date of Construction:
0 Construction began: 1977
0 Construction completed: 1977
b. Date of use: 1977
c. Size of the disposal cell: 30' wide x 50' long x 18' deep
d. Purpose: Disposal of "Industrial Waste" not suitable for sanitary
Landfill disposal.
-------
Scott Thomas _,, __, , /J
USEPA Region V __________ /^ _ °
November 14, 1986
Page 2
«. East end of SCMF No. 1 cut out and extended into ami made a part of
SCMF No. 2.
2. Construction Performance Standard
a. Liner construction:
( 1 ) Natural soil material - no compaction on the bottom nor the
sidewalls.
(2) No synthetic liner.
b. Detection Systems:
(1) TSCA - none.
(2) Leak detection -- none.
c. Leachate Collection:
(1) Design -- no leachate collection system installed.
d. Subcell Layout:
(1) No subcella constructed within disposal cell no. 1.
(2) Disposal cell no. 1 -was an open trench design.
e. Cap Closure Design:
(1) Compacted fill and 3* thick clay material graded to drain and
with fescue for erosion control.
3. Types of Waata Material Disposed within SOff No. 1 .
a. Permits:
( 1 ) TSCA -- none .
(2) Pre RCHA.
b. Waste streams received and disposed:
(1) Paint sludge material contained within 55 gallon drums.
c. Reconfiguration:
(1) None.
4. No Dewa tering Systems.
-------
Scott Ttonaa ' <-«=W.a -///,,/«- 37
DSEPA Regicn V
*Mfflber14, 1986 - /?
-------
wegion v
November 14, 1986 ____ . _ • • pnq*. V of S 7
Page 4 Q '
Intermedd.ate Landfill (Series of individual trenches)
1. General Description
a. Date of Construction
* Construction of the first of the series of individual trenches
began in the fall of 1977.
* The last intermediate landfill trench was constructed in July 1979.
b. Date of Use: Fan of 1977 to 1979.
c. Estimated size of each intermediate landfill trench: 12' wide x 30'
long x 25' deep.
d. Purpose: To dispose select/specific waste material within each indivi-
dual intermediate landfill trench.
2. Construction Perforrar.ee
a. Liner Construction
( 1 ) Natural soil material -- no ccr^acticn en the bo t ton or the side-
walls. Trenches excavated by a track excavator (back hoe) ---
shear sidewalls.
(21 No synthetic liner installed.
b. Detection Systems
(1 ) TSCA - none.
(2) Leak detection — none.
c. Leachate Collection
(1) Design — no leachate collection system installed,
d. Subcell layout — none.
Individual trenches were excavated for each specific waste stream.
e. Cap Closure Design
Individual trenches were covered with 3' of compacted clay. The entire
area was covered with 2' of soil material and seeded in 1979.
3. Types of waste material disposed within the Intermediate Landfill Trenches
a. Permits
(1 ) TSCA -- none.
(2) Pre RCRA.
-------
Scott Thcnma <^O • ////?/?$ - 07
USEPA Region V _,/->.
November 14, 1986 /^
-------
Scott Thomas • ,- /> ™
USEPA Region V /^«- 6 « ^ ^ 7
November 14, 1986
Page 6
3. Types of waste material disposed within the sanitary landfill.
a. Permit — Ohio EPA permit to install (PTI) dated November 4, 1976.
RE: Clermcnt County, Jackscn Township, application for expansion .
of the Clement Environmental Reclamation, Inc., Landfill for
disposal of various industrial waste liquids and sludges.
b. Waste streams received and disposed.
{1) Sanitary Solid Waste
(2) Household Waste
(3) Bio sludge from EXiPcnt
(4) Water treatment sludge from O4 Plant, Nor-cod
(5) Bio sludge from Proctor and Gamble (filter media ncn-hazardous).
-------
- O 7
Scott Thomas ,,
USEPA Region V - — — P^^ ? °" ^ 7 '
November 14, 1986
Page 7
Secure Chemical Management Facility No. 3
1. General Description
a. Date of construction
0 Construction began: 1978
0 Construction completed: 1978
b. Date of use: Early 1979 to Spring of 1981.
c. Size of the disposal cell:
300' wide x 300' long x 26' deep.
d. Purpose: Disposal of Hazardous Waste Material.
e. This disposal cell is the first cell at the Aber Road Facility to be
authorized for "crowning" of the landfill. Refer to: Report on permit
to install application and detail plans of proposed modifications to
the Clermont Environmental Reclamation Cor^pany Landfill, an attachment,
to tie Ohio PIT dated November 12, 1980.
2. Construction Performance Standard
a. Liner Construction
(1) Recompacted bottom of the disposal cell with 5 feet of clay soil
material.
(2) 30 rail, nylon reinforced "Hypalon" liner was installed on the bottom
and the sidewalls of the disposal cell and secured at the top of
the cell by an anchor trench.
(3) 2:1 side slopes non-reoompacted soil material — insitu material.
(4) Two feet of soil buffer material was placed on top of the synthetic
liner on the sidewalls and on the bottom.
b. Detection Systems.
(1) TSCA - 8 - 4" perforated FVC pipes installed under the reccrnpacted
soil liner.
(2) Leak detection. No leak detection system installed within this
disposal cell.
c. Leachate Collection.
(1) Design — no leachate collection system installed.
(2) Three 24" diameter precast concrete standpipes were installed.
-------
mmt
Novemoer n, t?w — - ^^\, a C?T -7 f
Page 8 Q
d. Subcell Layout
(1) SCMF No. 3 ves constructed with 3 subcells: Amphoteiric, Heavy Metals
and General. Cne (1) standpipe in each subcell.
e. Cap closure design
3' thick compacted soil layer. 20 mil. PVC synthetic lirer attached
to primary synthetic liner. 2? feet thick root raterial placed on top
of the primary synthetic liner. The slope of the finished/final graded
cap is 7%. Gas vent system is installed within the 3 feet of ccrnpacted
soil layer.
3. Types of waste rnaterial disposed within SCMF No. 3:
a. Permits
(1) TSCA yes.
(2) RCRA yes.
b. Waste streams received and disposed:
(1) Waste water treatment sludges.
(2) Acid sludges.
(3) Organic still bottoms.
(4) PCS Bulk, transformer carcasses, capacitors.
(5) Paint sludges.
(6) Cyanides.
(7) Arsenic.
(8) Lab Paks.
4. Reconfiguration of subcella None.
-------
Scott Thomas / -'
USEPA Regicn V Pc^oe Q o-C
-------
USEPA Region V .. — A?oov> /C7 o /* <-,' -
November 14, 1986 . '
-------
Scott Thomas v.c.^vo // /a$ u,
USEPA Region V , . .„ ac.no. // „./? o 7
• ~ ^ j ~" "^ A <* j* -•.—— ..—- - — —- f*=* ^** *^ c~. f f fj i t /
November 14, 1986 ' ^ v '
Page 11
Secure Chemical Management Facility No. 6
1. General Description
a. Dates of construction: Fall 1980 to completion in Spring of
1981.
b. Dates of Use: April 1981 to August 1983.
c. Size of Facility: 520' x 460' x 50' deep.
d. Purpose: Disposal of Hazardous Waste.
2. Construction Performance Standards
a. Liner Systems
(1) Natural Liners
7-j feet reccmpacted sidewalls on a 1.5:1 slope.
5 feet recompacted bottom.
(2) Synthetic Liner
60 mil. HOPE liner installed (heat welded) bottom and sidewalls
and anchor trench.
2 feet soil buffer material on the sidewalls and the bottom.
b. Detection Systems
(11) TSCA System
Four (4") PVC perforated pipe underdrain in a sand bed system
led into 8" ABS truss wall riser.
(2) No "Leak Detection" system installed.
c. Leachate Collection
Five leachate standpipes 36" reinforced concrete perforated wrapped
with geotextile and crushed stone in place surrounding the leachate
standpipes.
d. Subcell lay-out
3 subcells — amphoteric, heavy metals and general. Separated by
4' thick divider berms, 1 standpipe - amphoteric, 2 standpipes -
heavy metals, 2 standpipes - general.
e. Cap Design
(1) 3 feet thick compacted soil layer.
(2) 20 mil. PVC synthetic liner attached to primary synthetic liner.
(3) Perimeter sand drainage fingers.
(4) Gas vent system.
(5) Finished cap slope 7%.
(6) 2-i feet thick root zone material.
-------
Scott Thomas
USEPA Region V
November 14, 1986
Page 12
3. Types of waste accepted,
a. Permits
(1) TSCA Yes.
(2) RORA Yes.
b. Types of waste material disposed within Cell No. 6:
PCB contaminated soils.
Waste water treatment.
Acid Sludge.
Organic Still Bottoms.
Paint Sludges.
Cyanides.
Arsenic.
Lab Paks.
c. Reconfiguration
SCMF No. 6 reconfiguration construction requirements:
* Subcell reconfiguration performed two times. During the operation
of the disposal cell (SCMF No. 6).
* Heavy metal subcell made 80% larger, amphoteric decreased 80% in
size.
0 Standpipe added during 2nd reconfiguration (L-14).
0 2nd reconfiguration accomplished after several layers of waste
was disposed in SCMF No. 6.
t\e>. (o
of
^
. (o
-------
ceco £ - nft r/te •- o i
Scott Thomas '
USEPA Regicri V . „__ r — pao £ /3 &-p 97
November 14, 1986 d
Page 13
4. Dewatering Systens — None.
Water encountered during excavation - insignificant quantity to affect
construction.
-------
Scott Thomas >- *- *«^o ' '// '*/ 2"^ - O ~
USEPA Region V ._ ._..... . . .... _ .
November 14, 1986 " ^<5.?C /V of c/7
Page 14 ' d
Secure Chemical Management Facility No. 7
1. General Description
a. Construction of this disposal cell began in sinner of 1981 and con- •
pleted March 1982.
b. Dates SCMF No.- 7 was in operation November 1982 to June 1984.
c. Size of the Facility is approximately 500' x 550' x 50' deep.
d. Purpose: Land disposal of TSCA and RCRA, and other waste material.
2. Construction Performance Standards
a. Liner Systems
(1) Natural liner. Reccmpacted soil material placed in the bottom
and sidewalls. 1.5:1 side slopes no toe berms. Cut off walls
(clay plug) at sand seams intercepted on the side wall.
(2) Synthetic liner. 80 mil. HDPE liner (heat welded) installed
on the sidewalls and botton anchor trench. Two feet of
soil buffer material in place en top of the liner on the
sidewalls and the botton.
b. Detection Systems
(1| TSCA Systems. Four 4-inch PVC perforated pipe tied into an &
ABS truss wall riser for under drains and sand blanket on botton
of cell.
(2) No "Leak Detected System".
c. Leachate Collection System
0
(1) Five leachate collecticn standpipes 36" reinforced concrete
perforated with geotextile filter wrap and gravel surrounding
each leachate standpipe.
d. Subcell Layout
(1) Three subcells: amphoteric, general and heavy metals. Elach
subcell divided by a 4' thick berm. 1 stanclpipe - amphoteric,
3 standpipes - heavy metals, 1 standpipe - general.
e. Cap Design
(1) 3 feet thick compacted soil layer.
(2) 20 mil. PVC synthetic liner attached to primary synthetic liner.
(3) 6" thick sand drainage blanket or synthetic drainage media.
(4) Gas Vent System.
(5) 2? feet to thick root zone material.
(6) Finished cap slope 7%.
-------
Scott Thomas
USEPA Region V
November 14, 1986
Page 15
3. Types of waste accepted
a. Permits
(1) RCRA
(2) TSCA
b. Types of Waste^Stream disposed within Cell No. 7:
0 PCS contaminated soils.
0 Waste water treatment sludge.
0 Acid sludge.
0 Organic still bottoms.
0 Paint sludges.
0 Cyanides.
0 Arsenic.
0 Lab Paks.
0 Phenols.
c. SCMF No. 7 Reconfiguration Construction Requirement
0 Subcell reconfiguration construction was performed one time during
the operation of the disposal cell (SCMF No. 7).
0 Heavy metals subcell enlarged and general subcell reduced by one
half its original design size/reconfiguration.
Heavy Metals Subcell
Heavy Metals Subcell \
-------
/*-//• ^ t / -i
€ ^ O-f S 7
USEPA Region V
November 14, 1986
Page 16
4. Dswa taring Systems.
a. System specifications.
(1) 4 wells -- 12" gravel pack with 6" PVC casing ani screens.
(2) Screen internal 860' - 880' msl.
(3) Pumping mechanism: sufcmersible pumps with floats.
(4) Gallons output: 2-40 GPM.
b. Water encountered curing excavation. Impacted construction and
required dewatering wells to slow in flow to allow clay plugs to
be installed before reconstruction began.
-------
n of
November.14, 1986__. . ...
Page 17
Secure Chemical Management Facility No. 8
1. General Information
a. Construction of this disposal cell began in summer of 1983 and com-
pleted in December 1983 and remediated Spring 1984.
b. Dates of Use: , June 1984/February 1985.
Capped: March 1985.
c. Estimated size of disposal cell 550' wide x 550' long x 50' deep.
d. Used for disposal of RCRA, TSCA and other waste materials.
2. Constjnjction Performance Standards
a. Liner Systems
(1) Natural liner. Reccnpacted soil material placed in the bottom
and sidewalls.
- 5' thick bottom.
- 7^' thick sidewalls.
Cut off walls (clay plug) of sand seams intercepted on the side
wall.
- ° Side slopes:
- South wall — 1.5:1.
- West wall 1.9:1.
- North wall — 1.7:1.
- East wall 1.5:1.
Top bertns and eductor dewatering system were added to ensure
sidewall stability.
(2) Synthetic Liner. 80 mil. HDPE liner (heat welded) installed
on the sidewalls and bottom and secured by an anchor trench
on top of the cell. Two feet of soil buffer material in place
on the top of the liner installed in the sidewalls and one foot
of soil buffer material on top of the leachate collection system
on the cell bottom.
b. Defection Systems
(1 ) TSCA system 4" perforated PVC in a sand blanket over the better
tied into a 10" ABS truss wall riser.
(2) No "Leak Detection" System.
c. Leachate Collection System
(1) Leachate collection system installed on the bottom of Cell No
8 — sand and piping. Five 36" leachate collection standpipes
— reinforced concrete perforated wrapped with geotextile filter
media and gravel material surrounding each leachate standpipe.
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Scott Thoras -- -- -, -
USEPA Region V — oa?£ t *
November 14, 1986 / (/ '
Page 18
d. Subcell Configuration.
(1) Three subcella: amphoteric, heavy metals and general divided
by 4' thick soil berms. 2 standpipes in heavy metals, 2 stand-
pipes in general, and 1 standpipe in amphoteric.
e. Cap Design:
(1) 3 feet thick ccmpacted soil layer.
(2) 40 mil. HDPE synthetic liner attached to primary synthetic liner.
(3) 6" thick sand drainage blanket.
(4) Gas Vent System.
(5) 2-jr feet thick root zone material.
(6) Finished cap slope 7%.
3. Types of Waste Accepted
a. Permits
(1 ) TSCA
(2) RCRA
b. Waste stream disposed in Cell No. 8:
PCS contaminated soils.
Waste water treatment sludge.
Organic still bottoms.
Paint sludges.
Cyanide.
Arsenic.
Tab Paks.
Phenol.
^Reconfiguration — None. •
4. Dewatering Systems
a. System specifications
(1) 56 perimeter dewatering wells installed 16" sand pack with
6" PVC casing and screens.
(2) Screened internal 860 - 900 msl.
(3) Pumping mechanism eductor system.
(4) Gallons output by system - 15 GPM.
b. Water encountered during excavation - None.
-------
C £"095 - It/t 7/V6 ' O 7
Scott Ituonas ' '
USEPA Region V _ ~- - r>o.(\a /Q _/"* (j ~j
November^, 1986 P*3 ^ '^ ^ ^ 1
Page 19
Secure Chemical Management Facility No. 9
1. General Information
a. Date construction started: August 1984.
Date construction completed: March 1985.
b. Dates of Use: ' March 1985.
Still actively used. (General subcell estimated 10,000 cubic
yards of air space remaining).
c. Estimated size of disposal cell:
- 550' wide x 550' long x 50' deep.
d. Purpose: Land disposal of RCRA, TSCA, and other waste material.
2. Construction Performance Standards
a. Liner Construction
(1) Natural Liner.
Reconpacted soil material. TVro soil liners installed on the
bottom separated by a leak detection system. Combined thickness
of the two soil liners is 6-j feet. Side walls consist of
compacted soil liner 7? feet. Cut off walls (clay plug) sand
seams intercepted on the side wall. Side slopes 2:1. No
toe berms.
(2) Synthetic Liner.
80 mil. HDPE (heat welded) single synthetic liner.
b. Detection Systems
(1 ) Leak detection system consist of sand and pipe installed on
the bottom of the disposal cell between the two soil liners.
(2) TSCA under drain monitoring system installed on the bottom of
the disposal cell underneath the bottom clay liner consists
of sand and pipe. Size of the sidewall discharge pipes
10" ABS truss wall pipe.
c. Leachate Collection Systems
(1) Leachate collection system installed on the bottom and side
walls consists of sand and piping on the bottom.
(2) Three 36" leachate collection standpipes installed — reinforced
concrete wrapped with geotextile filter media material and
gravel basket surrounding each standpipe.
(3) Eight contingency leachate removal riser pipes installed on
the sidewalls.
d. Subcell confiouration
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Scott Thomas
USEPA Region V
November 14, 1986
Page 20
(J
(1) 3 subcells amphoteric, general and heavy metals divided
4' thick soil berms. 1 standpipe per subcell.
e. Cap Design
(1) 3* thick compacted soil layer.
(2) 80 mil. HDPE synthetic liner attached to primary synthetic liner.
(3) 6" thick sand drainage blanket or synthetic drainage media.
(4) 2-i' to 3' - 0" thick root zone material.
(5) Gas vent system.
(6) Finished cap slope 6-8%.
3. Types of waste accepted
a. Permits
(D
(2)
TSCA
RCRA
b. Types of waste stream disposed within Cell No. 9
PCB contaminated soils.
Waste water treatment sludge.
Organic still bottoms.
Paint sludge.
Cyanide.
Arsenic.
Lab Paks.
Phenol, Sludges.
-------
Scott Thomas
USEPA Region V
November 14,1986
Page 21
C £'COS - I ///
-------
USEPA Region V _ .. ^ _ ~ - -
November 14, 1986 /^^ ** <-
Page 22 W
4. Dewatering System
a. System Specificaticn
(1) No. wells installed on the periphery of SCMF No. 9 is 51.
(2) 40 wells 12" sand pack with a 4" PVC casing and screens.
The remaining 11 wells are part of SO
-------
Soott Thomas ^
USEPA Region V P0^ ^3 o-f
November 14, 1986 ^
Page 22
Secure Chemical Management Facility No. 10
1. General Information
a. Date construction started: October 1985.
Date construction completed: September 1986.
b. Dates of Use: First waste stream disposed on October 24, 1986.
Still active. '
c. Size of the disposal cell 510' wide x 550' long x 50' deep.
d. Purpose: Land disposal of RCRA, TSCA, and other waste materials.
2. Construction Performance Standards
a. Liner construction
(1) Natural liners.
Recompacted soil material. Two soil liners installed on the
bottom separated by a leak detection system on the bottom and
the sidewalls. The combined thickness of the soil liner is
?i' on the bottom and ?£' on the sidewalls.
No cut off walls installed within the entire cell because the
entire cell was over excavated.
-Side slopes: 2:1.
No toe berms.
(2) Synthetic Liners
(1) Primary synthetic liner is 80 mil. HDPE — on the bottom,
and up the sidewalls and secured on the top of the cell
by an anchor trench.
(2) Secondary synthetic liner is 80 mil., HDPE installed
on the bottom of the cell and terminates 12 feet up the
side walls. This liner is installed below the leak
detection system.
b. Detection Systems
(1) The leak detection system consist of sand and pipe on the bottom
of the cell, and non woven geotextile on the side walls.
(2) TSCA monitoring system installed below the bottom of the soil
liner consists of sand and pipe and seme 70 oz., non woven
geotextile.
c. Leachate Collection System
(1) Leachate collection system is installed on the bottom and
the sidewalls. On the bottom the system consists of sand and
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Scott Thomas
USEPA Region V /Oaqe 2 4 of
November 14, 1986 ' V
Page 24
(2) Three 36" diaiueier reinforced concrete perforated leadhate
collection standpipes wrapped with geotextile filter material
media and gravel basket surrounding each standpipe.
d. Subcell Configuraticn
(1) 3 subcells amphoteric, general and heavy metal divided by
4' thick soil berms. 1 standpipe per subcell.
e. Cap Design
(1) 3 feet thick compacted soil layer.
(2) 80 mil. HDPE synthetic liner attached to primary synthetic
liner.
(3) 6" thick sand drainage blanket or synthetic drainage media.
(4) 2-i1 to 3' thick root rone material.
(5) Gas vent system.
(6) Finished cap slope 6.6%.
3. Types of -waste accepted:
a. Permits
(1) RCRA
(2) TSCA
b. Type of waste stream disposed within Cell No. 10:
PCS contaminated soils.
Waste water treatment sludge.
Organic still bottoms.
Paint sludge.
Non-hazardous non-PCB soil material with vegetation excavated from
Aber Road.
0
c. Reconfigurations of subcells — None.
4. Dewatering Systems (Perimeter dewatering system installed prior to
excavation).
a. System specifications
(1) No. of wells installed is 58, 12" gravel pack with 6" PVC
casings and screens.
(2) Screened internal is 845 to 900 feet mean sea level.
(3) Pumping mechanisms submersible pump connected to a timer
system.
(4) Gallons cut put 40 GPM total system.
b. Water encountered during excavation seeps along east wall no
significant volume of water in flowing.
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ScottThoras . C6 OM .///'r/« -O7
Page 25
Secure Chemical Management Facility No. 11
1 . Basic Cell Design Concept for SCMF No. 1 1
0 Approximate size 550' x 550'.
0 Approximate Depth - 45 to 50 '.
0 Side slopes 2:1.
0 Primary synthetic liner - 80 mil. HDPE will cover bottom and sidewalls.
8 Secondary synthetic liner - 80 mil. HDPE will cover bottom and terminate
approximately 10 to 15 feet up the sidewall.
8 Primary leachate collection system will cover bottom and sidewalls - sand and
piping system en the bottom, synthetic drainage media on the sidewalls.
0 Secondary leachate collection system will cover bottom and sidewalls - ,sand
and piping system on the bottom, synthetic drainage media en the bottom.
8 Compacted soil liners on the bottom and sidewalls of the cell. Primary sand
liner will be minimum 4 to 6 inches thick. Secondary soil liner will be 3'-
0" thick.
0 All collection/detection systems will have minimum 2% slope and designed to
limit head on the synthetic liner to one (1 ) foot.
0 Cut off wall (clay plug) of sand seams intercepted in the sidewalls of the
excavation.
8 Dewatering wells installed on 40 feet centers on the perimeter of the cell
during initiated excavation. Extend to about elevation 835 and are fully
penetrating from about elevation 890. Well depths about 75 feet below present
grades .
8 During excavation seapage from the 880 sand zone.
-------
v-.~7r.rft
November 14, 1986 ^ao-e. 2-£ 0-/ 'V
Page 26 *>
2. Capping Design Concept
* 3 feet thick conpacted soil layer.
0 80 mil. HOPE synthetic liner attached to primary synthetic liner.
0 6" 'thick sand drainage blanket or synthetic drainage media.
0 2' - 6" to 3' - 0" thick root zone material
0 Finished cap slcpe 6.6%.
3. Design Modification
0 Discussion during excavation of the SCMF, the 850 sand zone was encountered
in the prcpcsed bottom of the cell in the southeast comer of the cell. The'
top of the sard was excavated to about elevation 860. Excavation to desi.gr.
elevations could not be completed because of water in the sand zone. A well
point dewatering system was installed across the south toe of the cell which
permitted excavation to continue to about elevation 856 and its lowest points/
still above original design elevation. Based upon the results of more extensive.
hydrogeologic investigation, redesign of the cell has been implemented. The:
following are the significant factors of the redesign.
o
* The well point system will be replaced with a dewatering header constructed!
• across the south toe of the cell in the 850 sand zone. The header 'will be;
connected to inclined discharge lines installed in original ground behind the>
sidewall compacted soil liners. The toe dewatering system 'will be designed
-*
to function through the construction and operation period of the SCMF.
0 The design bottom elevation of the cell will be raised from the original design
elevation. Very little/ if any, excavation will be made in the bottom of the
cell below current elevations.
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Scott uicmas v_ c. v_ wo ~ ' y ' */ f e> -
USEPA Region V n
November 14, 1986 p&Q*. 17 oi *i
Page 27 W
0 A low permability soil b?rrier will be constructed between the 850 sand zone
and the TSCA monitoring system. The soil barrier will be 2 feet thick
constructed of on-site soils having permability of 1 x 10~ on/sec or less.
0 80 mil. thick HDPE synthetic liner will be installed above the 2 feet thick
compacted soil liner and will terminate approximately 10 to 15 feet up the
side slopes.
0 The TSCA monitoring system will be constructed en the bottom of the cell above
the synthetic liner. The monitoring system will consist of sand and piping
system.
0 Construction above the TSCA system will be as presented in the Basic Cell De-
sign Concepts above.
0 Conclusions. The presented redesign concept will permit construction operation
and monitoring system of the cell consistent with recent past practices. The
perimeter dewatering system and 850 sand zone dewatering system are to control
groundwater during construction and operations and will remain functional
through construction and partial filling of the cell to prevent bottom heave
or sidewall stability failures. This concept of protection is consistent with
previous cells 8, 9 and 10. It will be possible to monitor groundwater quality
in the secondary leachate collection system and TSCA system consistent with
current practices and permits. If desired the 850 sand zone dewatering system
could also be monitored through the closure period. The design rationale (lea-
chate collection system, secondary leachate collection system, and TSCA system)
will provide protection of the environment equal to that of cells 9 and 10.
The performance of the primary leachate collection system in cell no. 9 has
demonstrated the ability to operate the secured cell and control leachate.
Based upon the redesign of the cell, the TSCA system will function more as
a detection system of potential contaminants migrating vertically downward
than a 'groundwater collection system during the construction, operation, closure
-------
'USEPA Region V ~
November 14, 1986 A*0-?*- 2? o-{
Ffcge 28 CJ
and post-closure periods.
A sunmary of the dewatering systems installed on the perimeter of each Secure
Chemical Management Facility is shown at enclosure 1.
A summary of the; capping requirements for the closure of each Secure Chemical Manage-
ment Facility is shown at enclosure 2.
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USEPA Region V P<±Q
-------
Novembe/14, 1986 /-'Ooe 3O o-f' S
Page 30 ^
Firepond No. 2 (Firepond No. 1/2, Firepond No. 1)
1. General
0 Constructed in late 1977 at the same time as SCMF No. 2.
* Approximate size: 80' x 80' x 8'.
0 Dates of use: 1978 to October 1985.
0 Purpose: Originally to contain a water supply for fire protection. Later
used to store and treat leachate fron inactive cells.
0 Firepond No. 2 was combined with firepond No. 1 in 1980 by removal of
the separation berm. The combined firepond No. 1 ard firepond No. 2 is
titled: Firepond No. 1.
0 Current status: Closure Plan approved, scheduled to be closed upon comple-
tion of leachate storage tank farm.
2. Construction Performance Standard
0 Trench excavated in native clay soils.
0 No soil or synthetic liner systems installed.
0 Combined with firepond No. 1 to form one larger impoundment by removal.
of the separation berm.
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Scott Thcmas <- * tf -///>*/?£- O 7
USEPA Region V
November 14, 1986 /°a,?e 3/
Page 31 ^
Firepond No. 3
1. General
0 Constructed in conjunction with SCMF No. 3 in 1978.
0 Approximate size: 250' x 100' x 8' deep.
0 Dates of use: 1978 until firepond No. 4/5 was constructed (approx. Sept.
1979).
0 Used for storage of collected storm water within SCMF No. 3.
2. Construction Performance Standards
0 Trench excavation in natural clay soils.
0 No reccrTTpacted soil liner or synthetic liner installed.
0 Removed in September 1979 during excavation of SCMF 4/5.
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USEPA Recjicn V /?Aj?f ^^ a-S° U -7
November 14, 1986 V 3 a '
Page 32
Solidification Basin
1. General
* Constructed in the early summer of 1 981 .
• Used f ran July 1 981 through December 1 981 .
* Size of Facility approximately 200' x 200' x 2' deep below grade with
3 ' - 4 ' high berms for a total depth of 5 ' - 6 ' .
* Purpose: To solidify leachate frcm firepcnd No.1.
0 Located west of SCMF 4/5 and east of the truck dock.
2, Construction Performance Standards
* A shallow excavation into natural soils at a depth of 2 feet.
0 Three (3) to four (4) feet thick soil berms were constructed en all 4
sides of the excavated open trench.
0 A series of 2 interior soil divider berms .were later constructed to divide
the basin into 3 sections.
0 No soil or synthetic liner systems installed within the solidification •
basin.
3. Material. Treated and Processed
* Leachate from firepond No. 1 was treated due to the lack of alternate
disposal methods at the Aber Road Facility.
* Leachate pumped frcm firepond No. 1 through a ribbon mixer with high cal-
ciun oxide lime and scdiun silicate was adrifd to solidify the leachate.
* The solidified material was pumped from the miv&r to the; solidification
basin for curing.
* The cured solidified material was disposed within SG-tF No. 6 during tine
period of August to December 1 981 .
4. Status of the Solidification Basin
0 All cured material and contaminciued soils were removed and disposed in
SCMF No. 6.
0 The solidification basin area was back filled with clean on-site soil
material December 1 981 .
5. Location, of the closed solidification basin at the Aber Read Facility is
shown at. enclosures 3 and 4.
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— —' -w vrf ' ' / " / " W
Scott Thomas
USEPA Region V ^Da.o^_ ^g 3 3 o _^
November 14, 1986 7
Page 33
Firepond 4/5
1. General
0 Constructed in fall of 1979 as part of SCMF No. 4/5 construction.
0 Approximate size: 220' x 170' x 13' deep.
0 Dates of Use: Fall 1979 through October 1985.
0 Purpose of this iinpoundment was to store potentially contaminated rain
water which fell into the active cell and was pumped from the surface
of the daily cover shortly after accumulation.
0 Current Status: Not in use. For emergency use only. Closure plan being
completed for sutmittal to approving agencies. (USEPA Region V and Ohio
EPA). Firepcnd 4/5 will be replaced by the leachate storage tank farm.
2. Construction Performance Standards
0 Trench excavated in natural clay soils.
0 No soil or synthetic liner systems installed.
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-inoraas - — / -/ - w
USEPA Region V „ n
Nove*ber'l4, 1986 /-'a?* 3 V O~T C,
Page 34 u
Spray Irrigation
1. Introduction:
The spray irrigation system was developed to treat lightly contaminated rain
water generated at the Aber Read Facility. This water was stored within*
firepond 4/5 and pumped via irrigation pipe to specific locations on the
permitted area of .Aber Road Facility. At these specific locations sprinkler
heads were set up to broadcast the water over approved aresas. CECDS submitted
a permit application in July 1980 and received approval from the Ohio EPA
in September. 1980 for the spray irrigation system. This method of treatment
was used from the fall of 1980 to October 1984.
2. Treatment Methods
Waste water to be treated was broadcast via sprinkler heads over irrigation
field "D" and a portion of irrigation field "C" now occupied by SCMF No.
7 (See Figure 1 at enclosure 5). The fields were sprinkled to near saturatj.cn
point.
Organics were degraded by biological/photo chemical action to harmless
byproducts. Water was eliminated through evapotranspiraticn and percolation
within the topsoil (.See Table 3 at enclosure 6). Metals, concentrations'were
limited to prevent toxic boil ups within the areas spra>e:l. Run off was
controlled by alternating areas sprayed to prevent over saturation.
3. Material Treated
Potentially contaminated waste frcnv firepcnd 4/5 was the predominant material.
- treated. Also treated was "Tri Pit" water, (which was sanitary landfill
leachate) and dermont County Sewer sludge, which was left over from a
previous irrigation program run by Clermont County.
All materials treated were tested to assure compliance with limits set in
the permit to operate (PTO) issued by Ohio EPA. (See figure 3 shown at
enclosure 7).
4. Treatment Areas Status
The irrigation permit set up 4 fields for irrigation. Fields A, B, C, and
D,. (See figure 1 at enclosure 5). Field A and B were never used. All of
field "D" was used and the portion of field "C" was used which is now occupied
by SCMF No. 7. Material from the top 6" of field "D" was stripped and placed
within SCMF No. 8 and ? as daily cover. The disposition of the material
from field "C" is unknown. Firepond 4/5 is presently slated to be closed.
The spray irrigation of waste water was halted in October 1984 by revocation
of our PTO by Ohio EPA. The system afforded CECOS International an efficient
method of treatment of lightly contaminated water during its life.
-------
Scott Thomas
USEPA Region V
November 14, 1986
Page 35
The Ohio EPA letter dated July 21, 1977, shewn at enclosure 8 summarizes the
activities leading up to the approval of the CER hazardous waste disposal site (Aber
Read Facility).
Please contact me, Gary Say lor or John Stirnkorb if you have any questions on this
historical summary of our facilities described in this memorandum.
MAM/bjd
Attachments
-------
SUMMARY CF CEWATERING SYSTEMS AT inn IJJU.Q INTERNATIONAL, INC.
ABER ROAD FAdLTTY (J
3ER OF
LS *
EZNED
.EKVAL
CING-
DCNS
PUT
SYSTEM
PING
HANI SMS
SCMF'
No. 7
4
860 - 880
Varies
2-40
GPM
Submers-
ible pump
4 float
SCMF
No. 8
56
860 - 890
20' on center
west side
50' on center
E, N, 4 S sidt
15
GPM
Eductor
systems
SCMF
No. 9
51
(40 + 11*)
860 - 900
40' en center
E, N, S, 50'
on center W.
»
15-20
GPM
Eductor
system
SCMF
No- 10
58 *
(44 + 14)
845-900
40'
on center.
40
GPM
Submers-
ible pump
w/tiner
SCMF
No. 11
57 <
(41 -f 16)
840 - 900
40'
on center.
40
GPM
Submers-
ible pump
w/ floats
SCMF
'3C
•
'
•
Includes common wells.
Enclosure 1
-------
37
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7. Hydraulic Loading Rate '
The zero discharge system will be flexible in operations
in relying on maximum evaportranspiration. The maximum
loading rate (in inches) is developed from the following
Table 3.
TABLE
Hydrologic Budget for Soil Percolation Based on 0.06 inches
per day average rate.
Max. Waste
Average Evaportranspiration Loading
Month Precipitation Potential Percolation Inches/Month
January 3.34 .65 1.8 - .89
February 3.04 .90 1.8 - .34
March 4.09 1.63 - - 1.8 - .66
April 3.64 2.86 1.8 1.02
May 3.74 4.37 1.8 2.43
June 3.81 5.06 1.8 3.05
July . 4.12 5.39 .. -, 1.8 - 3.07
August 2.62 " 4.60 - ' 1.8 3.78 •
September 2.55 3.17 . 1.8 2.42
October 2.15 2.01 ,-' 1.8 1.66
November 3.03 .99 •' - 1.8. - .29
December 2.86 .56 ' 1.8 - .50
Note:' All values are expressed in inches of water
Table 3 dictates the operating period of April - October
for normal average operations. The percolation rate of
0.06 inches per day is well below the 1 inch per day rate
that would normally be accepted. This proposal relys
primarily on evaportranspiration to accomplish zero
discharge.
a. Annual Liquid Loading Rate
The proposed system will operate from April through
October (184 days). This will allow a maximum waste
loading in inches per acre per operating season of
17.43 inches. This equates to approximately 0.09
inches per day average, including evaportranspiration,
rainfall and percolation. (See Table 3)
Enclosure 6
-10-
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'3T
FIGURE 3
PERMIT LIMITS OF MATERIALS TO BE TREATED BY SPRAY IRRIGATION
PARAMETER OHIO EPA
PERMIT TO OPERATE
PERMITTED RANGE (PPM)
COD , 100 - 500
TOC 10 - 1000
PHENOL 1.0 - 2.0
BOD 100 - 400
TKN 10 - 100
AMMONIA 10 - 30
NITRATE . 10 - 100
PHOSPHORUS 0.1 - 0.9
CHROMIUM . 0.1 - 1.0
CADIUM 0.005 - 0.01
COPPER 0.1 - 1.0
NICKEL, 0.1 - 0.9
LEAD . 0.001 - 0.1
ZINC . 0.1 - 1.0
MERCURY 0.001 - 0.02
Enclosure 7
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"/ ' «/ 6 0 -<
Re: Clenaont County"
Clermont Environmental Reclamation
Mr. Harold Flannery • July 21, 1977
4-£ieraont Environmental' Reclamation
j 980 Cincinnati-Batavia Pike
| Batavia, Ohio 45103 ' •-
Dear Mr. Flannery:
Introduction. This letter will serve to summarize the activities' leading
up to the approval of the CER hazardous waste disposal site and to note
for the record some of the verbal agreements between CER and OEPA. The
letter will also summarize the discussiors of the June 7 and July 13, 1977
ceetings between CER and OEPA, and contains comments on the revised plans
{ submitted tc OEPA on May 27, 1977.
*
of the_ Approval cf the Facility. The OEPA suggested cc CIR in
; January of IS76 that CER consider applying for a PTI for dispcsal of hazc.
* v«ste ac their landfill. The need for such a landfill in soutVivest era C^
) vz j great and io the opinion of the OtTA. -sr.iff the geology of ih* ClvP. ai'.
4 v*s prohjtbly suitable for a secure 1 wad fill. Free the initial discus s:iv>n
\ c* Joni^ary 1976 to the present time, the OHPA staff has been working clos
vith CER in the developcect of a aounti oc?ra"ioual plan and a more carefu
tvaluation of the geology of the site. "he Clernoat County Health
tawnt via also involved in this vcrX trom beginning. Detailed plur3
received by OEPA on Kay i3, 1976, revised plans were received on Aug
t3, 1976. Detailed soils infcrcation was received on September 3, 1976
\ and October 18, 1976. TU« plans were approved on November 4, 1976. A
3 revised, operational plao was recaived e& March 9, 1977 and a second dra!
icf this op-rational plat vas received on May 27, 1977, including revisior
jjla the "regular" solid wtste disposal area as well as ia th* hazardcua
%i waste area.
*
••
McniCoring. In addition to the discussion in Abduhl ?zshidi"3
-*port of November 5, 1976, f.i.« following ccmments are nade:
The exact details of the monitoring system have not be-en
determined at this time. JJjs.Perjiico and this writer
discussed this with Dave S.iarcro on .January 26, 1977.
At that time it was agreed ubac or.e lysineter and cce welJ
would ba developed in order to coapare the effectH-nes-s :
;':J«G* devices for obtaining vcvtcr ssuples free the ti^ht
soils on the site. The remainder cf the system will ba
•developed alter t^.is initial evaluation, Jra Pe.rjvir.o'o
U-tte? of February 9, 1577 co Dave Santoro discusses the
agreements of ch* January 26, 1^77 ceeting. It should be
at this time that some consideration should also be given
I use of resistivity probes.
note-i
to the
closure 8
Pfolection Aaencv
James A. Rhodes Governor
-------
Harold Flannery
y 21. 1977
"Vo
1« iaperative that the first well and lysineter be developed as soon as
ibl« so that the necessary information can be obtained for designing
irerall monitoring systea. As discussed in our July 13, 1977 meeting
be CER site, the plan for the overall monitoring systea should be
leted by early April, 1978, and-submitted to OEPA as an operational
. The QEPA ground water hydrology staff will aisist CER in developing
plan. The' monitoring systea should b« installed by October,"1978.
1 Control and Safety. The operation of CZR without spills or personnel
ry accidents must be of the highest priority. CEX and OE2A have
issed this during our July 13, 1977 meeting. The following points
of concern and ihould be addressed by emergency contingency plans.
A. There is a possibility that the snail streaa on the
western side of the cite could become contaminated
as a result of an accident. The entrance road crosses
the small streaa and there is a possibility that a truck
might runoff the narrow bridge or road into the stream.
For this reason it was agreed that a stock pile of earth
would be maintained along the streaa which could b« used
Co dan the stream if necessary during an emergency
clean up of a spill. The OEPA staff considered this as
•> * temporary measure. Ultlaately, a control structure should
be developed across the streaa which could be closed at a
moments notice.
The OEPA also requested that CER prepare a contingency
plan for handling a clean up of a spill in the small streams.
A first draft of such a plan was received Kay 27, 1977. After
a careful review,, it was concluded that considerably more work
is required on this plan. It Is the opinion of the OEPA staff
that CER should consult with some experts in this area and
prepare a revised draft. In particular, consideration should
be given to handling various categories of waste spills. Also,
it is not acceptable to depend on dilution of a spill during
times of high flow as a solution to the spill clean up problem.
Equipment and techniques are available for containing spills
and CER should become more knowledgeable in this'area.
•
B. Fire control was discussed during our July 13, 1977 meeting.
Again, the OEPA requests that a contingency plan be developed
to indicate how a fire will be contained if it were to occur
in the storage area, during the operation of placing drums in
the pit, en loaded trucks, or any other activity which might
result in a cheaical fire.
-------
c
Earold Flannery
july 21, 1977
page Three
C. Another concern is the safety of personnel during any activity
where the wastes are handled or stored. A contingency plan
is requested!on what would be done if a drum were accidentally
ruptured during unloading operations, operation in the pit,
etc. Also, what would be done if someone were overcome by
fuaea. Who would rescue such a person and how would it be
done.
Revised Plans. The revision of the plans for the CZR facility has been
under consideration since March 9, 1977. This was to be handled as a
revised operational plan which would not require a new PTI. The following
points are under consideration:
A. The depth of cells on the hazardous waste disposal area
was to be increased from 15 to 25 feet. This was considered
by the OE?A staff and was found to be an acceptable modification.
B. The design of the storage area has been modified from the
original plans. In our meeting of June 7, the following agreements
were reached:
• 1. The gated valve from the sump must be removed and the
stora water overflow cust be plugged. Revised plans
must clearly show proper construction detail.
2. Stonn water will be permitted to collect In the sump
area. It will be tested for contamination with
hazardous materials. If no contamination is detected,
the water will be applied to the nearby fields as an
irrigation application. If the water is contaminated,
it will have to be handled as a hazardous material and
containerized for disposal in the hazardous waste
facility. In no event will storm water be discharged
directly from the sump into the small streams on the
primeters of the property. Notes on plans must explain
this item clearly.
3. The drainage pipe under the dike on the west side will
be plugged. (It should be removed.)
4. Discussion regarding the storage area dikes and entrance
ramps to place during our July 13 on-site meeting. The
ramps were observed to be about 18" high, or somewhat lower
than the remaining dike walls. An accurate measurement of
the dike, entrance ramps, and storage floor elevations,
plus dimensions is needed to calculate exact volume of
storage area. The volume must be equal to intended material
to be stored, plus a reserve for fire control material,
plus freeboard. Detail plans must clearly show that
retention volume is provided.
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Harold Flannery
r 21. 1977
E Four
5. Baaed upon our observations of July 13, an area may
be required for "temporary" parking of hazardous
waste laden trucks prior to unloading to pits or
storage area. Although this type of occurrence i«i
somewhat but of your control, it is a serious problem
needing a contingency plan. The observed truck
was not parked within a diked area and runoff of
waste would be a certainty if the truck were to leak,
explode, or catch on fire. Even though you claimed
to fcot have "officially" received the waste, the fact
that-ie is parked on your property would probably
require you to share in the legal responsibility for
any accident which might occur. Tou should discuss
this with your attorney. It would be our recommendation
that in the future you check the manifest as soon as the
truck enters your facility. If the waste on the truck
does not correspond to waste categories already approved
by OE?A send the load back to the generator. There should
be a containnenc dike around any trucks parked at the sice
waiting to be unloaded. This portion of your operation
requires further consideration.
The sequence of operation in the revised plans still requires
clarification. " The cell drawings and the narrative statements
(especially f4) do not clearly describe how cells will be developed
or managed. Clarification is needed on how the ramp into cell
will be developed; the dimensions of the ramp; how will the sump
in the corner of the cell will be constructed, moved, drained,
etc.; how much Intermediate cover will there be; will this be
compacted; what machinery will run over the drums and intermediate
cover; etc. The drawing of a typical completed cell suggests
that each cell will b« covered with a mount of earth rather
Chan one mound over the entire site as shown .in the iiinal contours.
A statement is required to clarify this point. Finally, the plans
should clearly state procedures used to seed and establish
vegetation on the final cover. A narrative statement will
suffice.
The narrow bridge on the entrance road to the property is a very
weak link in the overall facility design. Serious consideration
must be given to increasing the bridge width and structural
integrity.
The plans should show « distance of at least 50 feet of undisturbed
earth between the hazardous waste cells and the conventional waste
disposal area.
-------
Harold Flannery
ily 21, 1977
ige Five
7
i
F. The need for clarification of design concepts and exact
operational steps in the hazardous waste disposal area
cannot be over-eniphasized. Your plans must be readily
understood by all your personnel, not only a select few.
areas,
Miscellaneous comments, hazardous waste and sanitary landfill
i
1. Hazardous vaste storage area "floor" should eventually be
concrete to allow for easier observation of leaking drums, easier
cleanup, etc.
2. The request to raise elevation in the sanitary landfill area
should be reflected on detail plans, i.e., new plan and profile
drawings, new topo contours of proposed grades, cell detail,
step-by-step procedures, etc. Maainuni side slope ratios above
normal grade is to be 1 v to 10 H, as discussed July 13.
;Tou should make necessary revisions to plans and resubcit to this off ice,as
jsoon as possible. We would like to finalize this project!
(Tours truly, .
Dan T. Redman, P.E.
Chief, Division of Solid Vaste
Management Operations
Office of Land Pollution Control
I
Robert E. Brown, P.E.
Public Health Engineer
Office of Land Pollution Control
DTR/REB/paa
cc: Clennont County Health Department
cc: Southwest District Office, OEPA
RECEIVED mi 271077
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