August 1987 EPA-330/2-87-028 /
Hazardous Waste Ground-Water
Task Force
Evaluation of
CECOS International, Inc.
Niagara Falls, New York
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Root
Chicago, 11 60604-3590
United States Environmental Protection Agency
New York State Department of Environmental Conservation
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p A \
| ^5^ I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
\^0^ AUGUST 31, 1987
UPDATE OF THE HAZARDOUS WASTE GROUND-WATER TASK FORCE EVALUATION OF
THE CECOS INTERNATIONAL NIAGARA FALLS FACILITY
The Hazardous Waste Ground-Water Task Force (Task Force) of the United
States Environmental Protection Agency (EPA) in conjunction with the New York
State Department of Environmental Conservation (NYSDEC) conducted an evalua-
tion of the ground-water monitoring program at the CECOS International hazar-
dous waste treatment, storage and disposal facility, Niagara Falls, New York.
The onsite field inspection was conducted over a ten day period from October
21 through 30, 1986. The CECOS facility is one of 58 hazardous waste treat-
ment, storage and disposal facilities (TSDFs) evaluated by the Task Force.
The Task Force effort came about in light of recent concerns as to whether
operators of hazardous waste TSDFs are complying with the State and Federal
ground-water monitoring requirements.
The objectives of the Task Force evaluation were to:
0 Determine the facility's compliance with the interim status ground-water
monitoring requirements of 40 CFR Part 265 and the equivalent state
requirements;
0 Evaluate the ground-water monitoring program described in the RCRA Part
B permit application for compliance with 40 CFR 270.14(c) and the
equivalent state requirements;
0 Determine if the ground water at the facility contains hazardous waste
or hazardous waste constituents;
0 Provide information to assist the Agency in determining if the TSDF
meets EPA ground-water monitoring requirements for waste management
facilities receiving waste from response actions conducted under the
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Comprehensive Environmental Response, Compensation and Liability Act,
as amended (CERCLA).
The Task Force prepared the accompanying report on its evaluation, which
revealed a number of deficiencies in the ground-water monitoring program at
the CECOS facility. EPA Region II and NYSDEC personnel had previously ident-
ified many of the deficiencies that are discussed in the Task Force report.
Efforts have been underway since 1985 to address those deficiencies and to
develop a "state-of-the-art" ground-water monitoring program at the CECOS
Niagara Falls facility.
The major deficiencies have been addressed primarily through EPA Admin-
istrative Orders issued pursuant to Sections 3008 and 3013 of the Resource
Conservation and Recovery Act (RCRA) and modifications to the State-issued
operation permit. Since 1985, the NYSDEC also issued several Administrative
Orders to CECOS that address permit violations and deficiencies in the ground-
water monitoring program.
The purpose of this update is to summarize the progress made through
these earlier initiatives, and to describe the actions that have been taken
to correct the additional deficiencies that were revealed by the Task Force
evaluation. The update is organized so as to first address activities
regarding each Task Force objective, then additional findings not specifical-
ly related to the objectives are presented.
Determine Compliance with the Ground-Water Monitoring Requirements of 40 CFR
Fart 265 and the Equivalent State Requirements
The Task Force evaluation revealed that CECOS was not in full compliance
with the ground-water monitoring requirements of 40 CFR Fart 265 and the
equivalent State requirements. Deficiencies were found in both the monitor-
ing well network and the sampling and analysis plans.
Because of previous deficiencies in the monitoring well network, EPA
Region II issued RCRA 3008 and 3013 Orders to CECOS on February 22, 1985.
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The Orders required evaluation and upgrading of the ground-water monitoring
program at secure landfills (SCMFs) 4 and 5, and investigation of the ground-
water contamination in the vicinity of SCMFs 1, 2 and 3. To comply with the
EPA 3008 and 3013 Orders, CECOS has installed 9 new wells near SCMF 4, 15 new
wells near SCMF 5 and 20 new wells near SCMFs 1, 2, and 3 since 1985. This
work was ongoing during the Task Force inspection; the monitoring networks in
the vicinity of those units are now in compliance with the regulations.
The Task Force determined that the monitoring well networks near two
waste management areas (Phase I and II Wastewater Treatment Plants - WWTPs)
did not have enough wells to adequately monitor the surface impoundments
in those areas. These inadequacies are being addressed through two State-
issued Orders on Consent (Nos. 86-123 and 87-110) that were signed in
August 1987.
The sampling and analysis plans that have been in use at the site be-
tween 1981 and 1985 were found to be inadequate by the Task Force. EPA and
NYSDEC personnel had previously recognized most of the deficiencies that
were identified by the Task Force. The current plan, which was implemented
in 1985 in response to the EPA Orders, is superior to the previous plans,
but further improvement is necessary.
The approved sampling program (MMCP) which CECOS conducted under its
NYSDEC operation permit does not conform to the requirements of the State
Part 360 Regulations (the State equivalent of 40 CFR Part 265) that were in
effect when the operation permit was issued to CECOS for the Niagara Falls
facility. NYSDEC personnel recognized the MMCP program deficiencies, and in
December 1985, modified the operation permit to require CECOS to develop a
monitoring program and plan that would conform to the standards of 6 NYCRR
Part 373-2, the State equivalent of 40 CFR Part 264. The plan was initially
submitted in March 1986 and is currently being modified. When implemented,
the plan will supercede the one currently in use.
In August 1987, subsequent to the Task Force inspection, NYSDEC issued
an Order on Consent (No. 87-118) to CECOS and collected a penalty of $50,000
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for violations of the approved sampling and analysis plan. In addition, the
NYSDEC notified CECOS of the deficiencies in its currently approved sampling
program. Those deficiencies are being corrected as required under Special
Condition B.2 of operation permit.
Evaluation of the Ground-Water Monitoring Program Described in the RCRA Part
B for Compliance with 40 CFR 270.14(c) and the Equivalent State Requirements
The Task Force evaluation revealed that deficiencies in the sampling
and analysis program that was implemented by CECOS in 1985 were also present
in the program proposed by CECOS in recent applications for two Part 373-2
permits for the facility. In addition, the monitoring well network which
was proposed in the permit application for secure landfill 6 (SCRF 6) is
inconsistent with the networks used at the other secure landfills. The "top
of clay" zone is monitored at other landfills at the site, yet "top of clay"
monitoring wells were not proposed for SCRF 6.
IXiring the review of the SCRF 6 permit application, NYSDEC personnel
identified the deficiencies that were found during the Task Force evaluation.
The NYSDEC draft permit for SCRF 6, which was issued in February 1987, in-
cludes provisions that correct the sampling and analysis deficiencies, and
address the "top of clay" monitoring issue. No additional action is neces-
sary to address this problem.
Determine if the Ground-Water at the Facility Contains Hazardous Waste or
Hazardous Waste Constituents
The Task Force evaluation confirmed the presence of hazardous waste
constituents in the ground-water near SCMFs 4 and 5. The evaluation also
confirmed that leachate was escaping from the base of a sanitary landfill at
the site, and that other waste management units may be impacting the ground-
water. The following summarizes ongoing actions by CECOS to address contam-
ination at the facility.
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SCMFs 1, 2 and 3
CEOOS is continuing to investigate SCMFs 1, 2 and 3 and is in compliance
with the EPA 3013 Order with respect to this investigation. At present, two
investigative approaches are being used to evaluate the landfills:
1. A chemical aipproach which compares constituents found in the land-
fills with those found in the ground-water upgradient and downgradient
of the landfills;
2. A hydraulic approach which compares the amount of leachate withdrawn
from each landfill with the amount one would expect to withdraw if
the landfill envelope were intact.
Through considerable effort by EPA, NYSDEC and CECOS, a testing program
has been developed which should provide a chemical basis for determining
whether SCMFs 1, 2 and 3 are contributing to the plume of ground-water
contamination which ananates at the Dupont Necco Park dumpsite immediately
upgradient of these units. Based upon the ground-water monitoring data
which has been collected since 1985, it appears that the Necco Park leachate
plume passes beneath SCMFs 1, 2 and 3. The ground-water data collected by
EPA indicate that contaminants have probably not migrated south of Pine
Avenue. Preliminary conclusions using historical data suggest that SCMFs 1,
2 and 3 may not be contributing to the Necco Park leachate plume. These
conclusions cannot be confirmed until data from the recently developed chemi-
cal testing program is reviewed. The first data should be available by
December, 1987.
Because the initial hydraulic study which CECOS conducted under the EPA
3013 Order was inconclusive, EPA Region II is requiring CECOS to conduct.
additional tests to evaluate the hydraulic integrity of SCMFs 1, 2 and 3.
The NYSDEC has determined that excessive leachate has been withdrawn from
SCMF 1, and issued an Order on Consent (No. 87-118) in August 1987, which
requires modifications to the SCMF 1 cap so that it conforms with the
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requirements of NYCRR Part 373-2.14(g). A hydraulic study of SCMF 1 will be
initiated upon completion of the modification of the cap at that landfill.
The hydraulic studies at SCMF 2 and 3 will commence in September 1987.
SCMF 4
Under the EPA 3008 Order and an assessment program which the State
initiated in July 1987, CECOS has been investigating the ground-water condi-
tions in the vicinity of SCMF 4. CECOS has complied with the provisions of
the 3008 Order and investigated ground-water conditions around SCMF 4, but
the results to date have not been conclusive. Therefore, additional study
is necessary to establish the source and extent of ground-water contamination
in the vicinity of SCMF 4. That study will be implemented under the assess-
ment program for the NYSDEC.
SCMF 5
The EPA and State have previously identified the presence of hazardous
waste constituents in the ground-water near SCMF 5. In July 1986, the State
required CECOS to implement an investigation of the contamination in the
vicinity of SCMF 5. The results of that investigation were submitted to
NYSDEC on August 13, 1987, and are currently under review. Based on a preli-
minary review of the investigative report, SCMF 5 does not appear to be the
source of the ground-water contaminants. Nevertheless, due to the complex
relationships between the location of SCMF 5 and former waste disposal activ-
ities, the impacts (if any) of the landfill are not yet fully understood.
The NYSDEC has informed CECOS that additional investigations and corrective
actions are necessary in the area of SCMF 5.
Phase I and II Wastewater Treatment Plants
Previous data from ground water near the Phase I and II WWTPs contained
hazardous waste constituents, some of which may be attributible to surface
impoundments in those areas. In August 1987, subsequent to the Task Force
inspection, NYSDEC issued two Orders on Consent (No. 86-123 and No. 87-110)
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to CECOS that require replacement of the surface impoundments at the Phase
I and Phase II WWTPs. The impoundments are to be replaced with tanks that
are equipped with leak detection/secondary containment systems.
Sanitary Landfills
As a result of NYSDEC Order on Consent No. 85-298, NEWCO (a sister
company to CECOS that is responsible for management of the sanitary landfills
at the site) is currently completing corrective measures that are designed to
permanently control leachate migration from the leaking sanitary landfills.
Those measures should be completed by the fall of 1987. NEWCO has taken
effective interim measures to intercept the leachate until the final control
program is in place.
Solid Waste Management Units
As a result of a December 1986 modification to the State-issued opera-
tion permit, CECOS developed a detailed program for investigating the impacts
of present and past solid waste management units at the site. To facilitate
public review and input on the investigation, the NYSDEC and EPA Region II
incorporated the program into the draft SCRF 6 permit, which was issued in
February, 1987. Because the hearing on the draft permit has been postponed,
and because it is essential that the ground-water problems are addressed in
a timely fashion, the NYSDEC has recently issued a public notice of its
intent to require CECOS to implement the investigative programs as provided
in the existing operating permit. That notice included provisions for a
public comment period. Upon completion of the comment period, the investiga-
tive programs will be modified as necessary, and implemented by CECOS.
Provide Information to Assist the Agency in Determining if the TSDF is
Suitable for Receipt of CERCLA Wastes'
The Task Force evaluation revealed that at the time of the inspection
the CECOS facility did not meet the technical requirements necessary for
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receipt of CERCLA fund-financed cleanup wastes. EPA Region II had previously
determined that the facility was ineligible to receive fund-financed CERCLA
wastes and had taken action to ensure that those wastes were not being disposed
of at the site.
Additional Task Force Findings
Although the primary focus of the Task Force was the CECOS ground-water
monitoring program, the evaluation revealed deficiencies in the operation and
maintenance (O&M) program at the site which, if not corrected, could result
in releases to the environment. Those deficiencies include: inadequate
inspection of tanks and impoundments at the Phase I WWTP, failure to maintain
sufficient freeboard at impoundments in the Phase I WWTP, and storage of
drummed wastes over unlined areas.
The O&M deficiencies that were revealed during the Task Force inspection
have been addressed. In April, 1987, the NYSDEC executed an Order on Consent
with CECOS (No. 87-30) that included monetary penalties and required CECOS
to correct the deficiencies. To ensure that operation and maintenance pro-
blems are recognized and corrected quickly, the NYSDEC maintains a cadre of
full-time environmental monitors at the CECOS facility. Those monitors
perform daily inspections of the site, and report all observed deficiencies
to both CECOS and the NYSDEC Regional office. In addition EPA and NYSDEC
conduct at least two full scale RCRA inspections at CECOS each year. At
least one of those inspections includes a comprehensive review of the CECOS
ground-water monitoring program.
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SUMMARY
Deficiencies in the ground-water monitoring program identified before
and during the Task Force investigation have been addressed by EPA Region
II and the NYSDEC through administrative orders and modifications to the
operation permit for the CEOOS facility. Dae to the complexities of separa-
ting the impacts of past disposal practices from the impacts of the waste
management units which are currently in operation, the development of an
adequate site-wide monitoring program and the implementation of corrective
measures that remediate the ground-water problems at the site have been
iterative processes. CECOS has made progress in addressing these issues,
however, more work needs to be done.
This completes the Hazardous Waste Ground-Water Task Force evaluation
of the CECOS International Niagara Falls Facility.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUND-WATER TASK FORCE
EPA-330/2-87-028
GROUND-WATER MONITORING EVALUATION
CECOS International, Inc.
Niagara Falls, New York
August 1987
Steven W. Sisk
Project Coordinator
National Enforcement Investigations Center
Denver, Colorado
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CONTENTS
EXECUTIVE SUMMARY
INTRODUCTION 1
SUMMARY OF FINDINGS AND CONCLUSIONS.. 12
GROUND-WATER MONITORING DURING INTERIM STATUS 12
Ground-Water Sampling and Analysis Plan 12
Sample Analysis and Data Quality Evaluation 14
GROUND-WATER MONITORING PROGRAMS PROPOSED FOR
FINAL PERMITS 14
TASK FORCE SAMPLING AND DATA EVALUATION 1 5
SUITABILITY FOR RECEIVING WASTES FROM CERCLA
ACTIONS 16
TECHNICAL REPORT
INVESTIGATIVE METHODS 17
RECORDS/DOCUMENTS REVIEW AND EVALUATION 1 7
FACILITY INSPECTION 18
LABORATORY [EVALUATION 18
WATER LEVEL MEASUREMENTS AND SAMPLE COLLECTION 1 8
FACILITY OPERATIONS AND WASTE MANAGEMENT UNITS 26
FACILITY OPERATIONS 26
WASTE MANAGEMENT UNITS 28
RCRA Interim Status Units/Operations 30
Non-Interim Status Waste Management Units 43
SITE HYDROGEOLOGY 56
HYDROGEOLOGIC UNITS 56
GROUND-WATER FLOW DIRECTIONS AND RATES 59
GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS 64
REGULATORY REQUIREMENTS 64
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CONTENTS (Cont.)
State Regulations 65
General Operation Permit and MMCP 65
GROUND-WATER SAMPLING AND ANALYSIS PLAN 65
Monitoring Plan Under EPA/RCRA Regulations (1981-
1983) 66
Monitoring Plan Under NYSDEC/State Regulations (1984-
1985) 70
SAMPLE ANALYSIS AND DATA QUALITY EVALUATION 72
Initial Year of Monitoring (1982) 73
Monitoring from 1983 to 1985 77
Current Practices (January to October 1986) 77
GROUND-WATER QUALITY ASSESSMENT OUTLINE 77
GROUND-WATER MONITORING PROGRAMS PROPOSED FOR FINAL
PERMITS 80
GENERAL FACILITY PERMIT APPLICATION PLAN 80
SCRF 6 PERMIT APPLICATION PLAN 82
CECOS SAMPLE COLLECTION AND HANDLING PROCEDURES 83
Water Level Measurements 84
Purging 86
Sample Collection and Preservation 87
Chain-of-Custody 89
EVALUATION OF MONITORING DATA FOR INDICATIONS OF WASTE
RELEASE 90
SCMF4 90
SCMF5 93
REFERENCES
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CONTENTS (Cont.)
APPENDICES
A MODIFICATIONS TO STATE OPERATION PERMIT NO. 3404
B MMCP WELL LOCATIONS AT PHASE I AND II WASTEWATER
TREATMENT FACILITIES
C ANALYTICAL TECHNIQUES AND RESULTS FOR TASK FORCE
SAMPLES
D LEACHATE MONITORING DATA FOR SCMFs 4 AND 5
FIGURES
1 Site Map 2
2 Timeline of Actions Related to Ground-Water Monitoring at
CECOS 7
3 Location Map for Water Level Measurements 19
4 Location Map for Wells Sampled , 22
5 Solid Waste Management Units 29
6 Well Locations-RCRA Ground-Water Monitoring 68
TABLES
1 Purging and Sampling Data 21
2 Order of Sample Collection, Bottle Type and Preservative List 25
3 Interim Status Waste Management Units 31
4 Units of Phase I Wastewater Treatment Facility 33
5 Units of Phase II Wastewater Treatment Facility 36
6 Non-RCRA Interim Status Waste Management Units 44
7 Characteristics of Lockport Dolomite Members 58
8 Water Level Measurements Made in Wells Near SCMFs 4 and 5 61
9 Water Level Elevations in Wells Near SCMFs 4 and 5 63
10 State and Federal Counterpart Interim Status Regulations 66
11 Comparison of Data from Monitoring Wells to SCMF 4 Leachate 92
12 Comparison of Data from Monitoring Wells 307 and 313 to
SCMF 5 Leachate 94
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EXECUTIVE SUMMARY
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INTRODUCTION
Concerns have been raised about whether commercial and onsite
hazardous waste treatment, storage and disposal facilities (TSDFs) are
complying with the ground-water monitoring requirements promulgated under
the Resource Conservation and Recovery Act (RCRA), as amended.* In
question is the ability of existing or proposed ground-water monitoring systems
to detect contaminant, releases from waste management units at these facilities.
The Administrator of the Environmental Protection Agency (EPA) established a
Hazardous Waste Ground-Water Task Force (Task Force) to evaluate these
systems and determine current compliance. The Task Force comprises
personnel from the EPA Office of Solid Waste and Emergency Response, Office
of Enforcement and Compliance Monitoring, National Enforcement
Investigations Center (NEIC), Regional Offices and State regulatory agencies.
During the fall of 1986, the Task Force investigated the CECOS
International, Inc., facility (CECOS) located in the city of Niagara Falls and town
of Niagara, New York [Figure 1]. The onsite inspection was conducted from
October 21 through 30, 1986 and was coordinated by NEIC personnel. The
objectives of this investigation are similar to those for other Task Force
investigations, namely:
Determine compliance with interim status ground-water monitoring
requirements of 40 CFR Part 265, as promulgated under RCRA, and the
equivalent New York regulations, as appropriate.
Evaluate the ground-water monitoring program described in the RCRA
Part B permit application, submitted by the facility, for compliance with 40
CFR Part 270.14(c) and the equivalent New York Regulation, as
appropriate.
Determine if the ground water at the facility contains hazardous waste or
hazardous waste constituents.
Regulations promulgated under RCRA address hazardous waste management facility
operations, including ground-water monitoring, to ensure that hazardous waste
constituents are not released to the environment.
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Provide information to assist the Agency in determining if the TSDF
meets EPA ground-water monitoring requirement for waste management
facilities receiving waste from response actions conducted under the
Comprehensive Environmental Response, Compensation and Liability
Act. (CERCLA).*
The 385-acre site (EPA ID No NYD080336241) has been used to treat,
store and dispose of municipal and industrial waste for over 80 years. More
than 30 waste management operations and units have been operated on the
properly. Initial site operations began in 1897 when the Union carbide
Company used a portion of the area for industrial waste disposal. By the 1960s,
Union carbide had expanded the site to its present size through acquisition of
adjacent properties. Between 1897 and the 1960s, the site was used chemical
for the disposal of furnace slag and hydrated lime, produced during the
manufacture of acetylene.
In 1972, Union carbide sold the site to Niagara Recycling, Inc. which
began operating the first of five sanitary landfills and a sludge drying area.
Niagara Recycling incorporated into Newco Chemical Waste Systems, Inc.
(Newco) in 1976 and began operating the first of five chemical waste landfills.
Between 1976 and 1981, numerous waste management units/processes
including acid neutralization ponds, sludge drying beds, wastewater treatment
facilities, metal recovery operations for foundry sands and scrap metal, and
storage facilities for sewage treatment plant sludges were constructed and
operated. In 1979, the Newco hazardous waste operation became CECOS
International, while the nonhazardous and sanitary operations retained the
Newco name. Both became subsidiaries of Browning Ferris Industries (BFI) in
1983.
Current operations include hazardous waste storage (containers, tanks
and surface impoundments), tanks and surface impoundments) and disposal
(landfills), and nonhazardous waste landfills.
Policy, stated in May 6, 1985 memorandum form Jack W. McGraw on "Procedures for
Planning and Implementing Off site Response", requires that TFDSs receiving CERCLA
waste be in compliance with applicable RCRA ground-water requirements.
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During the Task Force inspection, hazardous waste management
activities at the CECOS facility were regulated by a general operation permit
(No. 3404) issued in April 1983 by the new York State Department of
Environmental (NYSCEC). The permit was issued pursuant to State Solid and
Hazardous Waste Management regulations (6 NYCRR Part 360), which were
equivalent to interim status regulations promulgated under RCRA (40 CFR
Part 265). The Part 360 regulations qualified New York for RCRA interim
authorization which was delegated to NYSDEC in December 1983. The permit
expired in July 1986; however, under State regulations, CECOS must continue
to operate in accordance with the permit until final disposition of the renewal
application is made.
Although the general operation permit regulates waste management
operations at the CECOS facility, its administrative status was changed by
revisions to State regulations that became effective in July 1985. The revised
regulations (recodified as 6 NYCRR Part 373*) made commercial hazardous
waste facilities, such as CECOS, ineligible to receive State-authorized interim
status. Instead, the revised regulations stated that facilities currently operating
under a Part 360 permit were deemed to have a valid permit under Part 373. As
a result, CECOS was allowed to continue operating under its existing State-
issued permit. When the Part 360 permit expired in July 1986, a renewal
application (equivalent to a RCRA Part B application) was required in order the
receive a Part 373-2 permit (equivalent to a RCRA permit). This application was
pending during the Task Force inspection, as explained below.
The precursor of the current renewal application for the State operation
permit was a RCRA Part B application for the Niagara Falls facility submitted by
CECOS to EPA Region II in August 1983. Subsequently, CECOS decided to
seek a permit for a new landfill, which was not proposed in the Part B. A
separate Part B application for the proposed landfill (called a Secure Chemical
Residue Facility ad designated as SCRF 6) was submitted to EPA Region II and
NYSDEC in May 1985 in order to expedite permitting of that unit.
Hereafter "6 NYCRR" will be omitted from citations of NYSDEC regulations.
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The NYSDEC was delegated RCRA final authorization in May 1986.
During the months preceding delegation, CECOS reformatted both Part B
applications to meet the State Part 373 requirements and revised them in
response to comments and notices of deficiencies from EPA and NYSDEC.
The Part B application for the general facility (excluding SCRF 6) was initially
submitted to NYSDEC in January 1986 as the renewal application for State
permit 3404. The application was revised and resubmitted in May 1986. A
revised portion of the SCRF 6 application regarding the ground-water
monitoring program was also submitted in May 1986.
State law (Uniform Procedures Act) requires NYSDEC to issue a draft
permit within 60 days of receipt of a complete application unless the Company
and the Department agree to waive the requirement. The Company and the
Department agreed on a waiver for the general facility permit application, but
not for the SCRF 6 application. The effect of these actions was to have the
SCRF 6 application processed ahead of the one for the rest of the facility. Both
applications were under review by the State during the Task Force inspection.
CECOS has a State Pollutant Discharge Elimination System (SPDES)
permit to discharge surface runoff into the Niagara River. Although this permit
(No. NY009425) expired in November 1982, NYSDEC has extended it, pending
renewal. CECOS also discharges effluent from its wastewater treatment system
to the city of Niagara Falls municipal treatment facility under a city-issued
pretreatment permit.
The ground-water monitoring program for the facility has been revised
extensively since early 1985. EPA and NYSDEC evaluations of the facility
through late 1984 revealed that (1) the adequacy of the monitoring program and
well construction at the CECOS facility was questionable and (2) facility
operations might be affecting ground-water quality. Because of these findings,
EPA Region II issued CECOS two Administrative Orders on Consent (consent
orders) in February 1985. The first, issued pursuant to RCRA Section 3013,
required CECOS to: (1) determine whether hazardous wastes have been
released from three hazardous waste landfills [Secure Chemical Management
Facilities (SCMFs) 1, 2 and 3] and the nature of the release if one occurred,
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(2) further characterize site hydrology, (3) evaluate the adequacy of existing
monitoring well network.
The second consent order, issued pursuant to RCRA Section 3008,
addressed monitoring program deficiencies for two other hazardous waste
landfills (SCMFs 4 and 5) at the facility. This consent order required CECOS to
submit (1) an outline of a ground-water assessment plan, (2) the results of a
Students "t" analysis of ground-water monitoring data, (3) a plan for installing
new monitoring wells (4) a plan for analyzing trends and patterns in analytical
data obtained from monitoring wells at SCMF 4 and (5) a plan for better defining
ground-water flow near SCMF 4. Information submitted as a result of these two
orders was being evaluated by EPA and NYSDEC during the Task Force
inspection.
The consent orders issued by EPA addressed evaluation of the
monitoring wells and potential releases in only a portion of the facility; the
remainder of the facility was addressed through modification of the general
operation permit issued by the State. The permit modification [Appendix a],
which became effective December 1, 1985, required the development of an
expanded site-wide ground-water monitoring program that includes evaluating
all existing wells proposed for use in the program. It also required CECOS to
submit a report that identifies all past and present solid waste management
units (SWMUs) and contains proposals for evaluating impacts of those units on
ground-water quality.
In response to the permit modification, CECOS submitted a proposed
"Expanded Ground-Water Monitoring Program" plan to the State in March 1986
and an SWMU report in July. The SWMU report was being revised during the
Task Force inspection. Also in July 1986, NYSDEC notified CECOS that a
ground-water quality assessment program would be required for the only active
hazardous waste landfill at the facility (SCMF 5). A timeline of actions related to
ground-water monitoring is presented in Figure 2.
As a result of the revised State regulations, work conducted pursuant to
the EPA consent orders, modification of the State permit, revision of the Part
373-2 permit applications, and the requirement for assessment monitoring at
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Figure 2
TIMELINE OF ACTIONS RELATED TO GROUND-WATER MONITORING AT CECOS
Government Actions
Date
CECOS Actions
NYSDEC issued first general
facility operation permit
(No. 2025)
General operation permit
(No. 2025) expired
RCRA ground-water monitoring
requirements take effect
NYSDEC issued operation permit
(No. 2561) for SCMFs 4 and 5
State Part 360 regulations
revised (equivalent to RCRA
Part 265 regulations)
EPA Region II requested RCRA
Part B Application from
CECOS
NYSDEC issued new general
facility operation permit
(No.3404)
EPA Region II delegated
interim authorization to
NYSDEC
RCRA amended. Continuing
releases from SWMUs* must be
addressed in facility permit
10/27/79
10/27/81
11/19/81
11/20/81
01/82
03/82
08/82
02/83
04/04/83
08/83
12/83
11/84
CECOS initiated interim
status ground-water
monitoring program
CECOS submitted renewal
application for general
operation permit 2025
and three others
CECOS submitted RCRA Part B
to EPA Region II
Solid Waste Management Units
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Figure 2 (cont.)
Government Actions
Date
CECOS Actions
EPA issued consent orders
(3013 and 3008) to CECOS
Modified State regulations
(Part 373) became effective
NYSDEC modification to
general operating permit
requiring expanded ground-
water monitoring program
and SWMU evaluation
02/85
05/85
07/15/85
11/85
12/85
01/86
EPA delegated final auth-
orization to NYSDEC for
hazardous waste program
03/86
05/86
05/86
05/86
NYSDEC required CECOS
to implement ground-water
quality assessment program
for SCMF 5
07/86
CECOS submitted RCRA Part B
for SCRF 6 to EPA and
NYSDEC
CECOS initiated ground-
water monitoring program
under EPA orders
CECOS submitted partially
revised RCRA Part B to
NYSDEC as renewal appli-
cation for general facil-
ity operation permit
(No. 3404)
CECOS submitted plan for
expanded ground-water
monitoring program
CECOS submitted revised and
reformatted Part B appli-
cation to NYSDEC (Part
373-2 application) for
general facility permit
CECOS submitted revised
ground-water monitoring
portion of Part 373-2
application for SCRF 6
CECOS submitted SWMU report
to NYSDEC and EPA
Region II
-------
Figure 2 (cont.)
Government Actions Date CECOS Actions
General facility operations 07/01/86
permit (No. 3404) expired*
EPA and NYSDEC conducted 10/86
Task Force inspection
Under NYSDEC regulations, CECOS must continue to operate according to
the 3404 permit until final disposition of the Part 373-2 permit
applications.
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10
SCMF 5, the scope of the Task Force investigation at the CECOS facility was
modified. Much of the work required by the EPA orders and the permit
modification was intended to bring the ground-water monitoring program into
compliance with standards applicable to State Part 373-2 and RCRA permits
rather than interim status regulations. This work began in about mid-1985,
revised State regulations made the CECOS facility ineligible for State-
authorized interim status and changed the administrative status of the general
operation permit. Because of these facts, compliance with "interim status"
ground-water monitoring requirements is evaluated for the period between
November 1981 and July 1985 in this report.
Under the EPA consent orders, CECOS developed a monitoring program
plan that was implemented in the fall of 1985. This plan was the basis of the
March 1986 Expanded Groundwater Program plan required by the permit
modification, and the May 1986 ground-water monitoring program revision to
the SCRF 6 application for a Part 373-2 permit. The Expanded Groundwater
Program was a "de facto" replacement for the plan submitted in the Part 373-2
application for the general facility permit. As a result, evaluation of the ground-
water monitoring program proposed for the final permits involved reviewing
these two plans and the field procedures that had been initially implemented
pursuant to the EPA orders.
Proposed monitoring well networks were in such a state of flux that they were
not evaluated.
Data from previous sampling by CECOS and EPA indicated that waste
constituents were present in ground water beneath the facility. Investigations of
potential sources are addressed by the EPA consent orders, SWMU report and
SCMF 5 assessment program. In order to obtain additional information,
independent ground-water quality data, samples were collected by the Task
Force from wells near SCMFs 4 and 5.
Wells near SCMF 4 were sampled by the Task Force primarily for two
reasons. First, a July 1986 CECOS report, titled "Groundwater Monitoring Data
Assessment, SCMF #4, 1982-1984" (required by the EPA 3008 order),
concluded that, although some of the data are anomalous, they "...strongly
indicate that SCMF #4 leachates are not being detected in SCMF #4 monitoring
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11
wells." Since that report was submitted, CECOS installed 13 new wells
adjacent to SCMF 4, which had not been sampled. Task Force data form these
wells could provide additional information regarding waste releases.
Wells near SCMF 5 were sampled by the Task Force because it was the
only active hazardous waste landfill at the facility that might be eligible to
receive superfund wastes. The NYSDEC notice to CECOS requiring the
assessment program indicated that the ground-water contamination that
prompted the notification may be unrelated to SCMF 5. Task Force data from
these wells cold aid in identifying the source of the contamination.
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12
SUMMARY OF FINDINGS AND CONCLUSIONS
The findings and conclusions presented in this report reflect conditions
existing at the facility in October 1986. Acions taken by the State, EPA Regions
II and CECOS subsequent to October are summarized in the accompanying
update.
GROUND-WATER MONITORING DURING INTERIM STATUS
Task Force personnel investigated the interim status ground-water
monitoring program at the CECOS facility for the period between November
1981, when applicable provisions of the RCRA regulations became effective,
and July 1985, as discussed on Page 10 of this report. The interim status
monitoring program was administered by EPA from November 1981 until late
December 1983, when NYSDEC was delegated RCRA interim authorization.
An equivalent program was administered by NYSDEC after receiving RCRA
authorization. The investigation revealed instances of noncompliance with EPA
and NYSDEC regulations.
After July 1985, CECOS continued to operate under authority of and
pursuant to the State-issued general operation permit. Unless otherwise noted,
deficiencies described in the ground-water monitoring program being followed
in July 1985 were not corrected before the Task Force inspection.
Ground-Water Sampling and Analysis Plan
Under the EPA-administered program, CECOS developed a monitoring
plan titled "RCRA Ground-Water Monitoring Program for Hazardous Waste
Management Facilities at the Pine Avenue Site" dated November 1981. The
plan addressed all subjects required by 40 CFR 265.92(a);* however, many
necessary details regarding sampling and analysis were omitted and the
designated RCRA monitoring well network did not comply with the EPA
regulations [265.91 (a)]. Procedures for making water level measurements,
calculating purge volumes, decontaminating equipment and shipping samples
Hereafter, "40 CFR" will be omitted from citations of EPA regulations.
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13
were omitted. Procedures for preserving and analyzing samples were
incomplete. Chain-of-custody procedures and the outline for a ground-water
quality assessment program were adequate. The well network only monitored
two (SCMFs 2 and 3) of the six regualted unites where ground-water monitoring
was required.
Under the Sate program, CECOS followed the MMCP, which was
developed in 1980 and 1981 pursuant to operation permits and State
regulations in effect at that time. State regulations equivalent to the EPA interim
status regulations did not become effective until March 1982. In August 1982,
CECOS submitted a renewal application to NYSDEC that contained the MMCP
developed for the operation permits (which had expired in 1981) and previous
regulations. The proposed MMCP was approved as the monitoring plan for
Permit 3404; however when compared against the regulatory standards
[360.8(c)(5) that were in effect when the permit was issued, the MMCP has
deficiencies.
Although the MMCP included a network of more than 100 wells, it does
not include a statistical comparison of indicator parameter data from upgradient
and downgradient wells, nor does it include procedures for sample
preservation, shipment and chain-of-custody. It does not list a specific
analytical method for each analytical parameter, and the list of monitoring
parameters is not as comprehensive as required. CECOS only had historical
analyses of 11 of the 21 parameters that were initially to be used to
characterized the suitability of the ground water as a drinking water supply.
Furthermore, the MMCP proposed monitoring for only 2 of the 6 parameters that
must be measured annually to be used to establish ground-water quality.
Though not in conformance with the Part 360 requirements, the approved
MMCP program has technical merit. All of the MMCP wells are sampled at least
quarterly, and those in the vicinity of the hazardous waste landfills are sampled
bimonthly. The monitoring parameters that are measured in wells near each
waste management unit were chosen to reflect the types, quantities,
concentrations and mobility of constituents in wastes managed at the unit.
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14
Sample Analysis and Data Quality Evaluation
The laboratory evaluation revealed problems that could affect data
quality. For example, written standard operating procedures were not
completed and in use until January 1984. The analytical methods used form
1982 through the Task Force inspection did not take into account the high
dissolved solids content of the samples, which adversely affected data quality.
Holding times were routinely exceeded for pH until 1985, when field
measurements were initiated. Conductance results were not corrected for
temperature or the cell constant of the meter. Required total organic carbon
(TOC) results actually represent nonpurgeable organic carbon (NPOC), which
excludes the purgeable (volatile) organic carbon content of the sample. Total
organic halogen (TOX) analyses were not performed on samples collected for
interim status monitoring. Fluoride and nitrate results may not be reliable due to
lack of corrections for interferences and some phenol data are suspect.
Detection limits reported for some metals were inadequate for establishing
background levels relative to the drinking water supply standards. Pesticide,
herbicide and other specific organic compound determinations lacked
adequate quality control.
GROUND-WATER MONITORING PROGRAMS PROPOSED FOR FINAL
PERMITS
CECOS has applied for two State Part 737-2 permits, as discussed in the
Introduction section. The ground-water monitoring program plan proposed for
the general facility permit was"in effect" superceded by the plan submitted in
response to the permit modification (titled"Expanded Ground-Water Monitoring
Program"). The monitoring procedures described in this plan and the one
submitted in the permit application for SCRF 6 were acceptable; however,, more
details need to be added to the descriptions of sampling (e.g., identifying the
specific method to be followed). The proposed monitoring well networks and
list of monitored parameters were being revised by CECOS during the
inspection and were not evaluated by Task Force personnel.
The sampling sampling and analysis procedures proposed for the final
permits had been implemented by CECOS by virtue of those procedures being
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15
based on ones developed for the EPA consent orders. Although the
procedures described in the expanded Ground-Water Program and SCRF 6
application plans were acceptable, contractor personnel collecting samples for
CECOS did not exercise sufficient care in making some of the field
measurements and minimizing the potential for cross-contamination of samples.
Significant errors were made, for example, in measuring the depth to water.
Protective gloves worn during sample collection were not changed between
wells. This could result in cross-contamination of samples.
TASK FORCE SAMPLING AND DATA EVALUATION
During the inspection, Task Force personnel collected samples from 16
monitoring wells near SCMFs 4 and 5 to determine if the ground water
contained hazardous waste constituents or other indicators of contamination.
Samples were drawn from the wells by a CECOS contractor into sample
containers provided by the Task Force; split samples were collected from all
wells in containers provided by the CECOS contractor. Monitoring data from
the Task Force samples were evaluated together with Company data from
leachate and well samples.
Task Force and CECOS monitoring data strongly suggest that ground-
water quality near SCMFs 4 and 5 have been affected by past site activities
and/or materials used in constructing the exterior structural berms. These
activities complete data evaluations regarding possible releases from the
regulated units. Reports on these activities and construction of SCMFS 4 and 5
were reviewed in conjunction with the evaluation of ground-water quality,
ground-water data from the wells sampled by the Task Force and leachate data
were compared to identify common constituents.
Samples from well 416, adjacent to SCMF 4 and well 307, adjacent to
SCMF 5 contained substantial concentrations of hazardous waste constituents
(primarily phenolic compounds). In addition, three other wells (165, 169 and
413) adjacent to SCMF 4 and one other well adjacent to SCMF 5 contained
trace levels of hazardous waste constituents. The compounds detected in the
wells may indicate waste releases from SCMFs 4 and 5, because many of them
were also present in the leachate.
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16
SUITABILITY FOR RECEIVING WASTES FROM CERCLA ACTIONS
Under current EPA policy, if an offsite TSDF is used for land disposal of
waste from a CERCLA site, That site must be in compliance with the applicable
technical requirements of RCRA. At the time of the Task Force inspection, the
ground-water monitoring program at the CECOS facility was in a transition
stage between interim status and receipt of a final permit. Ground-water
monitoring during the transition period was being conducted pursuant to the
MMCP developed in 1980 and 1981, which was incorporated in to the 1983
operating permit.
At the time of the Task Force inspection, the facility did not meet the
technical requirements for a RCRA ground-water monitoring system. CECOS
was acting under EPA orders and State permit modification, however, to
develop a monitoring program that conforms to Federal And State permit
requirements (Pars 264 and 373-2, respectively). EPA Region II had previously
determined that the facility was ineligible to receive CERCLA wastes and had
taken action to ensure that no fund-financed cleanup wastes were being
disposed of at the site.
-------
TECHNICAL REPORT
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17
INVESTIGATIVE METHODS
The Task Force evaluation of CECOS consisted of:
Reviewing and evaluating records and documents from EPA
Region II, DEC and CECOS
Conducting an onsite facility inspection October 21 through
October 30, 1986
Evaluating an offsite contractor laboratory
Determining water level elevations in selected wells
Sampling and subsequent analysis of ground water from selected
wells
RECORDS/DOCUMENTS REVIEW AND EVALUATION
Records and documents from EPA Region II and NYSDEC offices were
reviewed prior to the onsite inspection. Additional state records were obtained
by Task Force personnel during the onsite inspection. Facility records were
reviewed to verify information currently in Government files and supplement
Government information where necessary. Selected documents requiring
further evaluation were copied by Task Force personnel during the inspection.
Records were reviewed to obtain information about facility operations, locations
and construction of waste management units and monitoring wells, and ground-
water monitoring activities.
Specific documents and records that were reviewed included the
ground-water sampling and analysis plans, ground-water quality assessment
program outline, analytical results from past ground-water sampling; monitoring
well construction data and logs, site geologic reports, site operation plans,
facility permits, unit design and operation reports, selected personnel position
descriptions and qualifications (those related to the required ground-water
-------
18
monitoring) and operation records showing the general types and quantities of
wastes disposed of at the facility and their locations.
FACILITY INSPECTION
The facility inspection was conducted to identify waste management units
(past and present), waste management operations and pollution control
practices and to verify the location of ground-water monitoring wells and
leachate collection sumps.
Company representatives supplied records and documents, answered
questions about documents and explained: (1) past and present facility
operations, (2) site hydrogeology, (3) ground-water monitoring system and (4)
the ground-water sampling and analysis plan. Ground-water samples are
collected and analyzed by an offsite contractor, Recra Environmental, Inc.
(Recra). Personnel from Recra were questioned regarding sample collection,
handling, analysis and document control.
LABORATORY EVALUATION
The Recra laboratory in Tonawanda, New York, analyzed ground-water
samples for CECOS from 1982 through 1986. The laboratory was evaluated to
determine its ability to produce valid data. Analytical equipment and methods,
quality assurance procedures and records were examined for adequacy.
Laboratory records were inspected for completeness, accuracy and compliance
with State and Federal requirements.
WATER LEVEL MEASUREMENTS AND SAMPLE COLLECTION
Task Force personnel observed Recra personnel measuring water levels
in 47 wells adjacent to Secure Chemical Management Facilities (SCMF)
landfills 4 and 5 [Figure 3] to verify past data and evaluate the procedure used
by the CECOS contractor. Duplicate measurements were made at fifteen wells
to verify the reproducibility of the data. Additional water level measurements
were made on the wells sampled, both prior to purging and prior to sampling.
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19
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20
Ground-water samples were collected from 16 monitoring wells [Table 1]
to determine if the ground-water contains hazardous waste or hazardous waste
constituents [Figure 4]. The sampling effort was focused on SCMFs 4 and 5, as
previously discussed (see Introduction section).
The CECOS contractor made all water level measurements, and purged
and bailed samples from the wells using their equipment. The wells were
purged using either ISCO Model 1580 peristaltic pumps or dedicated stainless
steel bailers. All samples were taken using dedicated bailers. Task Force
samples were collected in containers provided by an EPA contractor. Split
samples were provided to Recra personnel from all monitoring points in their
containers. The Task Force and CECOS containers for each parameter group,
except volatile organics (VOAs), were alternately filled in sequence in
increments of 1/3 of a bottle (or 1/2 of a bailer per bottle when a complete one-
third of a bottle could not be filled). Duplicate VOA samples were collected in
lieu of splits. Samples were collected from each well by the following
procedures:
Recra personnel washed the water level meter and the last 2 to 3
feet of cable using a solution of 10% Liquinoxฎ and rinsed with
deionized (Dl) water.
EPA contractor monitored the open well head for chemical vapors
(HNUฎ, explosivity and radiation).
Recra personnel determined the depth to water using a Slope
Indicatorฎ meter (Model 51453).
Recra personnel calculated the height of the water column from
the depth to water measurement and the well depth (from
soundings reportedly made one month prior to the inspection).
Liquinox, Slope Indicator and HNU are registered trademarks and will be hereafter shown
without ฎ
-------
21
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23
Recra personnel determined the water column volume using a
table of depths, well radii and computed water volumes.
Recra personnel washed the stainless steel bailers by brushing
both inside and outside with a 10% Liquinox solution and nylon
bristle brush.
The wash was followed by three rinses with Dl water
(approximately 200 ml each). The third rinse was collected and
the pH and specific conductivity were compared to the
measurements for Dl water. If the ISCO pump was used for
purging, dedicated tubing was rinsed with Dl water before use.
Recra personnel purged three water column volumes (or
evacuated to dryness) using either an ISCO pump and dedicated
tubing, or a dedicated stainless steel bailer. Purged water was
collected in both calibrated and noncalibrated plastic buckets
(approximately 2.5- and 5-gallon capacity buckets). Purge water
was transferred to a portable tank and disposed of onsite.*
EPA contractor collected sample aliquots at the beginning, middle
and end of purge and made field measurements for water
temperature, pH and specific conductance.
After purging, Recra personnel remeasured the water level to
determine if the well had recharged sufficiently for sample
collection (i.e., at least 90% of initial water level, according to
Recra personnel).
After recharge, Recra (and EPA if 10-15 minutes elapsed since the
end of purge) collected sample aliquots for field measurements for
temperature, pH and specific conductance.
Purge water is treated in the onsite waste water treatment facility (Phase I),which
discharges to City of Niagara Falls wastewater treatment plant.
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24
Recra personnel drew water from the well with a dedicated
stainless steel bailer and the EPA contractor filled prelabeled
sample containers in the order shown in Table 2.
EPA contractor placed Task Force samples on ice as soon as
samples were collected.
Recra and EPA collected sample aliquots to remeasure field
parameters after collection of all samples from the well.
The order of sample aliquot collection was modified when slow recharge
prevented collection of all aliquots at one time. In these cases (wells 169, 307
and 413) organics samples were collected immediately following recharge; the
other aliquots were collected later. If a well was allowed to recharge overnight,
the aliquots for inorganic parameters were collected first.
After sampling each well, Recra personnel took their samples to their
truck where aliquots for rnetals, TOC, phenols, cyanide and ammonia were
preserved. EPA contractors kept samples on ice and, within 2 hours after
collection, took them to an offsite staging area where they were preserved. The
final pH was measured in samples preserved by acid or base addition.
The EPA contractor prepared field blanks for each analytical parameter
group (e.g., volatiles, organics and metals) twice during the investigation (near
wells 261 and 307) by pouring distilled, deionized water into sample containers.
In addition, one laboratory matrix spike, which consisted of two duplicate VOA
vials and two 1-liter amber glass bottles, was collected per week (from wells
165 and 316). One trip blank for each parameter group was also prepared and
submitted during the inspection. The blanks were submitted with no
distinguishing labeling or markings to identify them as blanks. A laboratory
triplicate of all parameter groups was collected at well 413.
During collection of all samples, any Task Force personnel within 10 feet
of an open wellhead wore full-face respirators and protective clothing.
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25
At the end of each day, Task Force samples were packaged and shipped
to the two EPA contract laboratories according to applicable Department of
Transportation (DOT) regulations (49 CFR Parts 171-177). CECOS personnel
were given receipts for all samples collected. EPA chain-of-custody procedures
were followed during the handling, transfer and shipping of all samples.
Table 2
ORDER OF SAMPLE COLLECTION,
BOTTLE TYPE AND PRESERVATIVE LIST
Parameter
Bottle
Preservative
Volatile organic analysis (VOA)
Purge and trap
Purgeable organic carbon (POC)
Purgeable organic halogens (POX)
Extractable organics
Total metals
Total organic carbon (TOC)
Total organic halogens (TOX)
Phenol
Cyanide
Sulfate/chloride/nitrate
Ammonia
2 60-mL VOA vials
2 60-ml VOA vials
2 60-ml VOA vials
4 1-qt. amber glass
1 1-qt. plastic HNOa
1 4-oz. glass H2SO4
1-qt. amber glass
1 -qt. amber glass CuSO4 + HsPO4
1-qt. plastic
NaOH
1-qt. plastic
1-qt. plastic H2SO4
All samples were stored on ice immediately after collection and during transport to the
analytical laboratories.
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26
FACILITY OPERATIONS AND WASTE MANAGEMENT UNITS
Task Force personnel reviewed records of facility operations and waste
management units for indications of problems that might lead to waste releases
and information to aid in interpreting ground-water monitoring data. Some of
the information reviewed at the facility was part of the operating record required
by EPA and NYSDEC regulations [Parts 265.73 and 360.8(c)(4), respectively].
Because of the scope of the Task Force investigation, operating records were
not evaluated for compliance with regulatory requirements.
FACILITY OPERATIONS
The operating record should contain information on the identity and
location of waste constituents in the regulated units. This information is
necessary for conducting an interim status assessment or corrective action
program, or preparing a RCRA Part B permit application. Consequently,
operating records, including those for pre- acceptance and waste tracking,
were reviewed to evaluate how well waste constituents have been identified in
incoming waste and whether the disposal locations have been properly
recorded.
Waste identification is required by EPA and NYSDEC regulations for pre-
acceptance of waste and verification of characteristics of incoming loads.
Sampling methods, analytical techniques and waste identification procedures
are specified in the facility Waste Analysis Plan (WAP).
Each CECOS hazardous waste customer must complete a Waste
Characterization Data Sheet (WCD) and submit it to CECOS for review and
acceptance. A waste sample may be requested at CECOS' discretion. If the
waste is approved for acceptance, it is given a unique waste product code
which identifies the waste generator and specific waste stream. The waste is
then scheduled for receiving.
Upon arrival onsite, the shipping manifest is reviewed and the
waste sampled for indicator parameters. If waste characteristics match those
of the WCD, a waste receiving report (WRR) is completed to indicate
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27
how/where the waste will be treated/disposed of. The WRR accompanies the
waste load to the designated onsite treatment/disposal location and is signed
by the area foreman. The WRR is used to track waste to initial disposition. If a
waste is stored prior to final disposition, the waste is logged into the
storage area record. A new WRR is prepared to track the waste from storage to
final treatment/disposal.
Preacceptance/tracking records for 16 waste loads received at the facility
between 1983 and 1986 were reviewed; 4 loads per year were selected from
July receipts. Information on waste characterization/tracking prior to 1980 was
also reviewed. The records indicated that waste loads to be disposed of in a
hazardous waste landfill (called Secure Chemical Management Facilities -
SCMFs) could be tracked to a specific location; however, the specific SCMF
was not always identified. CECOS personnel indicated that the specific SCMF
could be determined based on the disposal date since only one SCMF was
generally operated for a specific class of waste at any one time.
Tracking records were adequate to follow wastes to other operating
hazardous waste units (e.g., wastewater treatment plants, container storage,
etc.); however, they did not identify the composition/quantities of wastes
handled in many of the waste management units operated prior to
promulgation of RCRA regulations (late 1980). Except for nonhazardous
industrial waste which is characterized prior to disposal, the specific types of
wastes currently disposed of in the nonhazardous waste disposal areas
(including sanitary landfills) are not known.
As a result, information in the operating record on waste composition and
location would be of limited value in conducting an assessment or corrective
action program, or completing a Part B application. Monitoring of ground-water
quality at the facility should not be limited to constituents shown as being
handled at the facility by the operating record.
-------
28
WASTE MANAGEMENT UNITS
Waste handling units and operations at CECOS were identified to
determine possible sources and pathways for waste constituents to enter the
ground water. More than 30 waste handling units and processes have been
operated on the 385-acre property since 1897 [Figure 5].
The facility has handled, and continues to handle, hazardous waste,
as defined in 40 CFR 261 and regulated by RCRA and NYSDEC regulations;
polychlorinated biphenyl (PCB) waste, regulated by Toxic Substances Control
Act (TSCA) requirements (40 CFR 761) and NYSDEC regulations; and
nonhazardous industrial, municipal and construction waste.
The following waste management processes/units are currently used
at CECOS and regulated by RCRA/TSCA and State law.
Treatment - tanks, surface impoundments
Storage - containers, tanks, surface impoundments
Disposal - landfills
Various tanks, impoundments, landfills and other waste handling systems used
in the past, but have not received hazardous waste since November 1980, are
not subject to RCRA interim status regulations. Environmental impacts, if any,
from these operations must be addressed, including corrective action for any
waste released, as part of the State 373-2 permit and RCRA permit
as required by RCRA Section 3004(u).
Additionally, in December 1985, NYSDEC modified the general
operation permit for the facility [Appendix A]. The modification required
CECOS to submit a report identifying all known past and present solid waste
management units (SWMU report), and include proposals to evaluate the
ground-water impact of these units. An initial SWMU report was submitted to
NYSDEC in June 1986. It was subsequently modified and resubmitted in
November 1986 in response to comments by the state. The report indicates that
additional study is proposed by CECOS for most of the units and operations that
existed at the facility.
-------
29
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-------
30
Information on waste management units, operations and proposed
investigations of those areas and operations for impacts on ground-water
quality is presented in the following two sections. The first section addresses
facility units and operations subject to RCRA interim status regulation; the
second addresses those which did not receive hazardous waste after October
1980.
RCRA Interim Status Units/Operations
General information on the CECOS waste handling units/operations
subject to RCRA interim status requirements is provided in Table 3 and in the
following discussion.
Wastewater Treatment Plant (WWTP) - Phase I
The Phase I WWTP, operated since 1979, is used for physical
treatment of liquid waste, primarily by pH adjustment and sedimentation.
Operation units include steel and fiberglass tanks, concrete and clay-lined
surface impoundments and a filter press [Table 4]. Effluent from the WWTP is
pumped to the Phase II WWTP through a buried pipeline. Solids generated in
the Phase I plant are periodically removed and disposed of in the onsite
secure chemical management facilities (landfills).
In 1984, low pH liquid was found in the lysimeter beneath concrete tank
L-1, which was used to receive acidic wastewater. Examination of the tank
following waste removal in 1986* showed the presence of three holes.
CECOS has conducted preliminary ground-water studies in the area to
determine the impact of this unit. Additional investigation of the area has been
required by the State.
Although L-1 did not receive waste after 1984, disagreement between CECOS and
regulatory agency personnel over how to dispose of the waste in the tank delayed
cleanout and examination until 1986.
-------
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33
Table 4
UNITS OF PHASE I WASTEWATER TREATMENT FACILITY
Unit
Designation
Construction
Capacity
(gal)
Use
L-l
L-R
Lime slurry
tank
Open-top in-ground concrete
storage tank lined with 60
mil HOPE* membrane
Open-top, above/below grade
concrete tank
Vertical carbon steel tank
Neutralization Vertical carbon steel tank
Tank
Filter Press
L-2
L-3
L-4
L4A
Drum crusher
Plate and frame press
2 ft. compacted clay-lined
surface impoundment; 6"-12"
1ime over clay
2 ft. compacted clay-lined
surface impoundment; 6"-12"
1ime over clay
2 ft. compacted clay-lined
surface impoundment, 6"-12"
1ime over clay
2 ft. compacted clay-lined
surface impoundment
Pickle liquor Fiberglass above-ground
storage tank tank
600,000 Out-of-service - received/stored acidic and
aqueous waste prior to treatment. Also,
used by Union Carbide as settling basin.
All wastes and liner have been removed.
50,000 Receive/store acidic and aqueous waste
prior to treatment, waste oxidation/
reduction.
10,000 Lime combined with alkaline wastewater to
produce slurry used for pH adjustment of
acidic wastes
3,000 Lime slurry added to acidic waste (from
L-R) for pH adjustment
Remove solids from neutralized acidic waste
and aqueous wastes containing high-solids
300,000 Out-of-service; received/stored aqueous
waste receipts with high suspended solids
concentrations for sedimentation.
300,000 Receive/store filter press filtrate and
waste receipts with high suspended solids;
sodium sulfide precipitation of metals;
sedimentation.
300,000 Store waste from L-3 prior to transfer to
Phase II WWTP. May also receive filtrate
from filter press, leachate from SCMF 4,
SCMF 5 and the intermediate landfill-
sedimentation.
300,000 Provides secondary containment for any
overflow from other WWTP Phase I units.
Crush drums following transfer of waste to
L-R.
Out-of-service. Stored waste pickle
1iquor.
High density polyethylene
-------
34
After L-1 was taken out of service, concrete tank L-R began to
receive acidic wastewater. Since the concrete of L-R is incompatible with low
pH material, dissolution of the concrete would be expected. Numerous
pits, ranging in diameter from about 1/2 to 2 inches, were observed in the
concrete walls during the Task Force inspection. The depths of the pits are
unknown. Continued use of this unit for acidic waste will probably result in
failure similar to that in tank L-1.
Although CECOS indicated that inspections of the surface
impoundments/tanks have shown that the "integrity of the units have remained
intact", trace concentrations of organics and other constituents have been
found in ground-water monitoring wells immediately south (downgradient) of
the area. There was evidence of erosion of the containment walls of the clay-
lined surface impoundments during the Task Force investigation. CECOS is
conducting ongoing investigations of the ground-water quality in the area.
Drums of waste awaiting treatment in the WWTP are stored on
trucks near the facility. While most were parked on an asphalt-lined area (with
curbing) during the Task Force inspection, some were stored over unlined
areas. Leakage from drums stored in the unlined areas could effect ground-
water quality.
Wastewater Treatment Plant (WWTP) - Phase II
The Phase II WWTP, which began operating in 1979, is used to
chemically, physically and biologically treat various liquid waste including
Phase I WWTP effluent, landfill leachate generated onsite, Necco Park
leachate and other offsite receipts. Operational units include synthetic-lined,
steel-walled surface impoundments and steel and concrete tanks [Table 5].
Effluent from this facility is discharged to the City of Niagara Falls WWTP.
All surface impoundments are located on asphalt-lined bermed areas
(with curbing) which are underlain by compacted clay.
-------
35
Although the double synthetic-lined surface impoundments [Table 5]
reportedly have lysimeters between the liners for leak detection, CECOS could
provide no data on the results of monitoring of these lysimeters. Therefore, it is
not known if the liners have leaked. Additionally, the ends of the sample tubes
for some of the lysimeters were broken or crushed, making them unusable.
The number of usable lysimeters is unknown as pressure from liquid stored
within the impoundments may have flattened many of the tubes. CECOS has
proposed an evaluation program to assess the impact of any leaks which may
have occurred from the WWTP Phase II units.
Secure Chemical Management Facility 2 (SCMF 2)
Hazardous wastes*, polychlorinated biphenyls (PCBs) and
nonhazardous wastes were disposed of in this landfill in 1978 and 1979.
SCMF 2 has a synthetic liner and is subdivided into three subcells for
segregation of pseudometal** , heavy metal and general (including PCB)
wastes [Table 3].
The landfill is capped with compacted clay, a 6-mil-thick
polyethylene membrane, uncompacted clay, topsoil and grass cover following
the provisions of a NYSDEC approved closure plan. Design drawings show a
surface runoff collection drain at the perimeter of the cap which directs runoff
into the leachate standpipes. The existence of this system, however, could not
be verified and CECOS indicated that it was never constructed.
Accumulated leachate is removed through standpipes and pumped to
the onsite Phase II WWTP. The general operating permit (No. 2025), issued
by NYSDEC to CECOS on October 27, 1979, requires that leachate levels be
maintained at less than 2 feet in the SCMF 2 leachate sumps. Prior to about
1984, NYSDEC monitoring reports indicated that leachate in the sumps
frequently exceeded this level. For example, on January 20, 1981, leachate in
the SCMF 2 sumps ranged in depth from 4.8 feet (sump 46) to over 10 feet
(sump 45). On February 23, 1983, leachate depths ranged in depth from
As defined by RCRA regulations 40 CFR 261
Waste placed in the pseudometal cell include compounds containing antimony, arsenic,
beryllium, bismuth, phosphorous, selenium and tellurium.
-------
36
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37
NYSDEC issued a consent order, requiring upgrading (from manual to
automatic level control) of the pumping system. Leachate levels following
modifications in 1984, have been generally maintained below the 2-foot level.
High leachate levels create hydrostatic pressure against the landfill liner and
may promote leachate movement through the liner.
As required by the EPA consent order, CECOS is currently
evaluating the impacts of this unit on area ground water.
Secure Chemical Management Facility 3 (SCMF 3)
RCRA hazardous waste, PCBs and nonhazardous waste were disposed
of in this landfill from 1979 into 1982. Five lined subcells were used to segre-
gate general, pseudometal, heavy metal, highly flammable and toxic
wastes [Table 3]. The cap consists of 3 feet of compacted clay and a 20-mil
layer of high density polyethylene (HOPE). The top of the HOPE liner is
covered with uncompacted clay, topsoil and vegetation to reduce cap erosion.
The unit was closed in accordance with the NYSDEC approved closure plan.
Leachate is collected and pumped from each subcell to the Phase I!
WWTP. Automatic pumping of leachate was not used in SCMF 3 until early
1984, prior to which time the pumps were started manually. The general facility
operation permit, issued by DEC to CECOS on October 27, 1979, required that
leachate levels in SCMF 3 be less than 2 feet. As was the case for SCMF 2,
weekly NYSDEC monitoring reports indicate that leachate levels frequently
exceeded 2 feet, prior to modification of the leachate removal system in 1984.
For example, on January 20, 1981, leachate levels for sumps 58, 58A, 62 and
62A were 7.5 feet, 7.3 feet, 4.2 feet and 6.5 feet, respectively. On February 23,
1983, levels for these four sumps were 19.6 feet, 15.3 feet, 12.4 feet and 19.8
feet, respectively. Leachate levels from 1984 to present have been
substantially better controlled. Impacts on ground water from the operation of
SCMF 3 are being evaluated by CECOS as part of the requirements of an EPA
issued consent order.
-------
38
Secure Chemical Management Facility 4 (SCMF 4)
RCRA hazardous waste and PCB wastes were disposed of in SCMF 4
from 1982 to the end of 1984. SCMF 4 is a lined landfill which is divided into
five subcells for segregation of general, pseudometal, heavy metal,
highly flammable and toxic wastes. Each subcell has a leachate collection
system which collects and automatically pumps leachate to a nearby buried
steel tank for storage (see Leachate Storage Tanks discussion), prior to
treatment in an onsite WWTP (either Phase I or Phase II plants). The final
cover on the landfill consists of topsoil over 1.5 feet compacted clay over a 20-
mil-thick HOPE membrane bonded to the liner in the landfill sides. The unit
was closed in accordance with the provisions of a NYSDEC approved closure
plan.
The general operation permit (No. 3404), issued to CECOS by NYSDEC
on April 4, 1983, requires that leachate levels be maintained below 2 feet in the
sumps in SCMF 4. According to weekly NYSDEC reports, leachate levels are
usually maintained below this level although some exceedences have
occurred. For example, on March 20, 1984, leachate levels in sumps 3, 4 and
5A were 2.7 feet, 4.0 feet and 2.6 feet, respectively. Levels in sump 3 and 5A
were reported at 5.4 feet and 10.5 feet, respectively, on January 31, 1986.
-------
39
Secure Chemical Management Facility 5 (SCMF 5)
SCMF 5 is the active hazardous waste landfill at the CECOS facility. The
lined unit is divided into four subcells for segregation of general, heavy metal,
flammable and toxic wastes. A leachate collection system conveys leachate
from all of the subcells to a common sump in the heavy metal cell where the
liquid is automatically pumped to a nearby underground storage tank prior to
transfer to the Phase I or Phase II WWTP. CECOS is currently evaluating the
effects of this unit on area ground water as part of an assessment program
required by the State.*
Intermediate Landfill Cells B and C (Secure Sludge Management
Facility)
These two landfill cells were part of a three-cell land disposal unit used to
dewater and dispose of municipal and industrial (including heavy metal)
sludges from 1979 into 1985. Wastes with relatively high liquid content were
handled in these units. The third cell, cell A, is discussed later in the report.
Construction diagrams indicate the sides of these units are lined with 3
feet of lime/slag waste over 2 feet of compacted clay (maximum permeability 10-
7 cm/sec) while the bottom has 3 feet lime/slag over natural clay. A leachate
collection and removal system was installed in the floor during construction.
Leachate is pumped to the Phase I WWTP.
The landfills were capped in 1985 with 6 inches topsoil and vegetation
over 1 foot clayey soil above 2 feet compacted clay (maximum permeability 10-
7 cm/sec). The units were closed under the provisions of a NYSDEC approved
closure plan. Ground water from monitoring wells (307 and 317) near these
units has had elevated concentrations of total organic halogens, total organic
carbon and total recoverable phenolics. CECOS has proposed, in the SWMU
report, to study these units and further evaluate the environmental effects of
their operation.
A NYSDEC letter to CECOS on July 7, 1986, required the Company to implement an
assessment program for SCMF 5 as a result of the detection of hazardous waste
constituents in the ground water near this unit.
-------
40
Leachate Storage Tanks
CECOS has two 22,500-gallon buried steel tanks for collection/storage of
leachate from SCMF 4 and SCMF 5, runoff from the container management unit
and wastewater from the truck wash (discussed later).
Leachate from the two landfills is automatically pumped through a buried
pipe to the tanks. The leachate lines have secondary containment consisting of
a synthetic membrane sleeve around the pipe for SCMF 4 and double walled
pipe for SCMF 5. There are no automatic shutoff devices on the tanks to
prevent overflow. The units are reportedly checked visually for freeboard level.
According to CECOS, the tank contents are pumped to tank trucks daily for
transportation to the Phase I or II WWTP.
The tanks were placed in clay-lined excavations for secondary contain-
ment and lysimeters were installed for leachate detection. None of the
secondary containment systems installed with the pipes/tanks have been
checked for the presence of liquid and the transfer lines have not been pressure
tested; therefore, the integrity of the leachate storage tanks and leachate feed
lines is unknown.
Container Management Unit
The 34,200-square-foot container management unit, built in 1981, is
used to store containers of waste from incoming loads prior to onsite treatment
or disposal. Maximum capacity is 1,200 drums. A drum crusher is also located
at this unit.
The base is asphalt-lined with berms to prevent runoff. Drains collect
runoff and direct it through a buried transfer pipe to the underground leachate
storage tanks (discussed previously). This 3-inch pipe has secondary
containment consisting of sand surrounded by a 30 mil PVC synthetic
membrane. The secondary containment system has not been monitored for
presence of liquid.
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41
Truck Wash Facility
The CECOS truck wash facility has been used since 1984 for exterior
washing of equipment leaving secure landfill areas and muddy vehicles leav-
ing the site. The facility consists of a 1200-square-foot concrete/asphalt pad
with automatic spray towers and a manual-wash hose. Wash water drains into
an underground concrete sump where solids settle. Overflow is to a second
sump which drains into one of the underground leachate storage tanks
(discussed previously). Solids are periodically removed from the sumps and
disposed of onsite. The wash water would normally contain relatively low
concentrations, if any, of hazardous waste constituents.
Acid Neutralization Ponds
The acid neutralization ponds consisted of nine surface impoundments
covering approximately 10 acres, which were leased to Hooker Chemical and
Plastics Corporation and used to neutralize hydrochloric acid with lime. These
impoundments had berms which were constructed with silt/sand and some clay,
but they were probably not lined with low permeability impermeable materials
such as synthetic membranes or compacted clay.
Hydrochloric acid and lime waste were loaded into one of two receiving
surface impoundments and mixed using a dragline. Liquid overflowed into
adjacent impoundments where additional lime was added and mixed. After
flowing through a series of these impoundments, each with lime addition, the
liquid entered the final impoundment which was hydraulically connected to the
bedrock (the base of the surface impoundment was permeable and located very
near bedrock surface). Neutralized acid, essentially a concentrated calcium
chloride solution, would leach from this impoundment into the bedrock aquifer.
This discharge was permitted under State Pollutant Discharge Elimination
System (SPDES) permit NY0094251 issued in 1977.
The acid neutralization impoundments stopped receiving waste in about
December 1980. Sludge was removed and disposed of onsite by June 1981.
Although clay liners were installed in the units after sludge removal, the
retrofitted impoundments have not been used for hazardous waste. The State
-------
42
verified closure of these units, following a NYSDEC-approved closure plan, on
December 17, 1984.
Although specific information was not available on the characteristics of
the "product grade" acid treated in these units, the SPDES permit application for
this discharge indicated that the hydrochloric acid may have contained arsenic,
chromium, copper, chloro-toluenes, benzoic acid and benzyl chloride. Any of
these or other constituents present in the acid, which remained dissolved in the
liquid in the final impoundment, may have entered the ground water.
EPA Region II issued a waiver of the RCRA ground-water monitoring
requirements for these units in March 1982. Bedrock ground-water sampling
and analysis, conducted as part of a hydrogeologic investigation of the ground-
water impacts of this operation, dated January 2, 1981* showed that while
calcium and chloride concentrations were generally elevated in the
downgradient well, there was no apparent increase in total organic carbon,
phenol and "organics." The report did not contain any sampling results for
heavy metals; however, it concludes that "no significant adverse impact on
ground-water quality is apparent in the area of the acid neutralization facility."
Drying Bed No. 1
Drying Bed No. 1 was used between 1979 and 1981 to solidify/stabilize
and dewater sludges containing heavy metals. It was a 228-foot by 228-foot
excavation, lined with 2 feet compacted clay (maximum permeablity 10-7
cm/sec). A sump was used to collect and remove liquids resulting from sludge
dewatering. Several techniques were used to solidify/stabilize heavy metal
sludges; however, they did not function as planned and the unit was finally used
to decant liquid from sludge. The liquid was pumped to the onsite WWTP and
sludge was disposed of in intermediate landfill cells B and C.
The unit was closed in 1981 under the provisions of a NYSDEC-
approved closure plan. A CECOS letter, dated on February 11, 1981, certified
Hydrogeologic Investigation, Acid Neutralization Facility, Pine Ave./Parcard Road,
January 2, 1981
-------
43
that all sludge and contaminated clay had been removed. CECOS personnel
indicated that soil sampling and analysis was conducted to ensure that all
contaminated material was removed; however, they could not provide the
sampling results during the Task Force inspection.
Although CECOS does not believe that this unit has impacted area
ground water, they have proposed additional study of this general area as part
of an evaluation to determine the source of elevated levels of TOC, total organic
halogens and total phenolics found in the ground water.
Drum Handling/Drum Transfer Facility
This facility was used between 1979 and 1984 to store containerized
waste awaiting treatment or disposal at CECOS. The area (approximately .5
acre) is lined with 2 feet of compacted clay (10-7 cm/sec, maximum perme-
ability) over a slag base. Additional liner material, consisting of a solvent
resistant sealer on asphalt over additional slag, was placed on the original clay
base shortly after the facility began operating. The base was sloped to a sump
for runoff collection and removal to the Phase 11 WWTP. Two sides of the pad
were bermed to help prevent runoff. Although drums of waste are no longer
stored at this facility, it has not been closed and is periodically used to store
trucks with waste awaiting off-loading. CECOS has proposed additional study
of this area to determine the environmental impact, including ground-water
effects from this facility.
Non-Interim Status Waste Management Units
Non-interim Status Waste Management Units as referred to herein are
those units which were not subject to hazardous waste interim status require-
ments because they were either inactive prior to November 1980 or have not
been used for hazardous waste (as defined in 40 CFR 261.3) management
[Table 6]. Operation of these units may have resulted in the release of
hazardous waste constituents to the ground water. In many cases, CECOS has
proposed additional investigation of these past waste management areas (in
the SWMU report) to identify environmental impacts.
-------
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46
Secure Chemical Management Facility 1 (SCMF 1)
SCMF 1 was used in 1977 and 1978 for landfill disposal of hazardous
waste. The unit was lined but was not divided into subcells for waste segre-
gation. Two leachate collection sumps, installed in the landfill during
construction, are used to remove leachate. The unit is capped with topsoil, 3
feet of compacted clay, two 6-mil polyethylene membranes (separated by 2 feet
of sand) and 1 foot of clay over the waste. Vegetation in topsoil is maintained
on the cap to prevent erosion. A collection system diverts surface runoff into the
landfill leachate collection sumps.
The October 27, 1979 general operation permit (No. 2025) required that
leachate levels in SCMF 1 be maintained below 2 feet. As was the case with
SCMF 2 and SCMF 3, weekly NYSDEC monitoring reports indicate that
leachate levels in SCMF 1 have often exceeded this 2-foot limit, prior to
modification of the leachate removal system in 1984. For example, leachate
levels in sump 6 and sump 7 were 9.1 feet and 9.4 feet respectively, on March
18, 1981 and 10.8 feet and 13.7 feet on February 23, 1983. Monitoring reports
from 1984 to present, indicate that leachate levels have been better controlled.
An in-depth evaluation of the impact of this unit on ground water is being
conducted by CECOS as part of an EPA-issued consent order.
Sanitary Landfills I and II
Sanitary landfills I and II, considered to be a single unit, were used from
about 1972 into 1985 for land disposal of municipal, industrial and construction
waste. The Sanitary II area received some waste in 1986 to build up the grade
as part of the initial capping process. Synthetic or compacted clay liners and
leachate collection and removal systems were not constructed in these disposal
areas. Because of this, leachate found in the landfill forms a mound which is
hydraulically connected to the top of clay transmissive zone (see Site
Hydrogeology section).
A toe-of-slope leachate collection system was installed to intercept and
collect leachate in the top of clay zone for treatment at the Niagara Falls WWTP;
-------
47
however, the system did not intercept all leachate and some has been found in
the CECOS facility perimeter surface drainage channel, which also intercepts
the top of clay zone. Liquid in the surface drainage channel has only pH
adjustment prior to discharge from the CECOS facility. Pursuant to NYSDEC
order 85-29B, issued May 1985, CECOS is currently improving the toe-of-slope
drainage system to more effectively intercept leachate. During the Task Force
investigation, seeps of reddish leachate were present along the toe areas of
sanitary landfills I and II. The leachate was also present in the facility perimeter
ditch immediately south of the landfill. In conformance with the State order,
contents of the ditch were being pumped to the Niagara Falls WWTP.
Sanitary Landfill III
Sanitary landfill III has been used for municipal, industrial and con-
struction debris since 1984 and is currently the active sanitary landfill for
nonputrescible waste. The unit is lined with 2 feet of compacted clay (10-7
cm/sec maximum permeability). A leachate collection system consisting of
french drains carries leachate to sumps where the liquid is removed and
pumped to the City of Niagara Falls WWTP.
Sanitary Landfill IV
Sanitary Landfill IV began accepting municipal and industrial waste in
1983 and is currently the active landfill for putrescible nonhazardous waste.
This landfill has a 2-foot compacted clay liner with leachate collection and
removal. Leachate is pumped to the City of Niagara Falls WWTP.
During the Task Force investigation, discolored water was present in
surface depressions adjacent to the southwest side of this unit, suggesting that
leachate may be migrating from the above-grade portion of the landfill.
-------
48
Lime/Slag Waste Storage/Disposal
About 90 acres of the CECOS site has been used from 1917 to present to
dewater and/or store !ime slurry. The slurry, principally calcium hydroxide and
calcium carbonate from acetylene manufacturing, was originally placed in
sedimentation ponds, constructed of slag (molten rock from metallurgical
operations) and miscellaneous debris, for dewatering. The dry lime has been
used for onsite operations (neutralization, landfill cover, construction, etc.) and
sold for offsite industrial use. The slag has been used for onsite construction
(landfill berms). Much of the lime remains unused and in storage at the site.
Portions of the lime have been found to be contaminated with construc-
tion debris, "low level radioactivity", and hexachlorocyclopentadiene (C56, a
pesticide ingredient). Following discovery, the pesticide contaminated lime was
excavated and disposed of in SCMF 5.
The presence of large quantities of lime at CECOS is the likely source of
the elevated pH levels in ground water found in the top-of-clay monitoring wells.
CECOS has proposed additional study to evaluate the impacts of the lime slurry
operation.
Intermediate Landfill Cell A (Secure Sludae Management Facility Cell A)
Intermediate landfill cell A (cell A), a 9-acre drying bed/landfill was
operated beginning in 1979 for the disposal of calcium fluoride (CaF2) waste.
Construction diagrams indicate that the bottom of the landfill was lined with 3
feet of lime over virgin clay while the sides have 3 feet of lime over 2 feet of
compacted clay. A leachate collection/removal system was installed to remove
liquid to the onsite Phase I WWTP. A southern portion of cell A was constructed
over refuse disposed of in Sanitary Landfill I.
Much of the CaF2 sludge was removed in 1985 when the unit was
recertified by NYSDEC for nonhazardous industrial waste disposal; about 8 to
10 feet of sludge remains. The unit is currently used for nonhazardous
industrial waste disposal.
-------
49
Analysis of the calcium fluoride sludge originally disposed of in cell A
indicates the presence of relatively low concentrations of organics (primarily p-
chlorobenzotrifluoride) and metals (chromium, cadmium, lead).
Elevated concentrations of fluoride and total organic halogens have
been found in the ground-water monitoring wells in the area of cell A. Because
the southern (downgradient) side of cell A was constructed over waste in
sanitary landfill I, ground-water monitoring wells cannot be located to
adequately identify hazardous waste constituents, if any, coming from only
cell A; therefore, CECOS has proposed to study the general area of this cell as
part of the study of other nearby units to identify any ground- water impacts.
Drying Bed No. 4
Drying Bed No. 4 was constructed in 1978 for storage of calcium fluoride
sludge. This 200-foot by 200-foot bed was lined with 2 feet compacted clay (to
maximum permeability of 10-7 cm/sec). The CaF sludge was excavated and
disposed of in intermediate landfill cell A in 1979. Drying Bed No. 4 was
reconstructed in 1983 and used for storage of nonhazardous waste prior to
disposal in cell A.
The drying bed was closed under the provisions of a NYSDEC approved
closure plan in 1985. Closure included excavating all of the waste and clay
liner and backfilling/grading the area. Soil sampling and analysis indicated that
contaminated material was removed during the excavation.
Calcium Fluoride Pond
Calcium fluoride waste was temporarily stored in this surface impound-
ment between 1978 and 1980. Although the size and construction details of
this unit are unknown, CECOS personnel stated that the unit was constructed
with slag berms and was not lined with either compacted clay or synthetic liner.
CECOS also indicated that all of the sludge was probably excavated and
placed into cell A. The area of the calcium fluoride pond has since been
backfilled and graded.
-------
50
Elevated concentrations of fluoride and total organic halogens have
been found in the ground water near this surface impoundment. CECOS has
proposed additional study of this area to identify the impact of the calcium
fluoride surface impoundment on the ground water.
Drv Lime Neutralization
A dry lime neutralization operation using waste lime to adjust the pH of
nitric, sulfuric and hydrochloric acid waste began in about 1975. The operation
covered about 2 acres and involved the use of clay-lined surface
impoundments and concrete tanks. Little additional information is available on
the operation, except that the process required continual modification and
maintenance, received numerous odor complaints and ceased operation in
1978. The limited information on the characteristics of the waste neutralized
suggests that organic compounds may have been present.
Portions of the impoundments were probably removed when SCMF 5
was constructed. Other portions and possibly waste sludge may remain.
CECOS has proposed additional study of this operation to help identify any
ground-water impact.
Foundry Sand Storage/Reuse
Sand from metal casting operations has been stored/processed onsite
since 1975. Three areas were used totaling about 22 acres. Two of the areas
have since been covered by sanitary and secure chemical management
landfills. Some sand remains at the third area (about 6 acres in size) and is
currently used for daily cover material in SCMF 5.
Metal fragments in the sand were removed during a screening process
and the processed sand used for sludge solidification and intermediate cover in
the onsite landfills. General analysis of the sand indicates the presence of lead,
copper, zinc, phenol, chromium, grease, oils and "hydrocarbons".
CECOS has proposed to study the remaining foundry sand area to
determine if this operation impacted ground-water quality.
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Sewage Sludge Storage/Disposal
Sewage sludge from the City of Niagara Falls was stored at the CECOS
facility from June 1977 to 1984. The sludge was stored on about 3 feet of slag
over about 11 feet of waste lime. The sludge was excavated and disposed of in
an onsite sanitary landfill in 1984/1985 when it was determined that the material
was not hazardous.
The slag/lime base still remains and no analytical testing has been
conducted to determine if all the contaminated material has been excavated.
CECOS has proposed sampling and analysis of the remaining material to
determine if contaminants are present and help identify if there was any ground-
water impact as a result of this operation.
Brine/Lime Sludge Disposal
Brine and lime sludge, from Olin Corporation chlorine production cells,
was disposed of in two areas between 1972 and 1977. The first, a 10-foot by
10-foot test area, 10 feet deep, received about 1,500 pounds of sludge.
Ground-water monitoring wells installed at each corner were used to test the
leachability of mercury from the sludge. According to CECOS, mercury did not
leach out of the material and 22,000 tons of brine sludge and 3,500 tons of lime
sludge were subsequently disposed of west of the test area. Brine sludge
consisted of water, sodium chloride, "siliconaceous material" and 30 to 50 ppm
total mercury. The lime sludge was water, calcium hydroxide, sodium chloride,
sodium chlorate and sodium (or calcium) hypochlorite.
The sludge may have been excavated and disposed of in SCMF 2 and/or
SCMF 3; however, little information exists on the operation and the disposal
areas have since been regraded. CECOS has proposed to conduct additional
studies to confirm sludge removal and determine if ground-water quality has
been impacted.
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Copper Recovery Process
A pilot project was conducted by CECOS in 1983 to test the feasibility of
decontaminating and recovering the metal, principally copper, from PCB
transformers. The process involved degreasing the transformers with tri-
chloroethylene and by melting the decontaminated unit in a furnace to recover
the metal. Following the test, all solids, including the recovered copper was
disposed of in SCMF 5. All transformer liquids and contaminated tri-
chloroethylene were shipped offsite for disposal.
Since the operation was conducted in an enclosed building with a con-
crete slab floor, no ground-water impact from this operation would be expected.
Scrap Metal Salvage Area
Scrap metal salvaging for reuse began in about 1972 and continued until
November 1985. The scrap area included a large metal shed and a storage
building. Scrap metal was stored at the area until it was taken offsite for
recycling. All of the buildings and equipment have since been dismantled.
Small pieces of scrap metal and miscellaneous debris remain in the area.
Discolored soil, indicating some type of contamination, was visible during the
Task Force investigation.
The scrap metal salvage area was also used for an unknown length of
time for overnight storage of tank trucks awaiting waste offloading.
CECOS is currently studying this area to determine the environmental
impact of the salvage operation. Preliminary investigation indicated the
presence of polychlorinated biphenyls in the area soil.
Cobalt/Vanadium/Ammonia Paratungstate Processing
Union Carbide operated processing operations for cobalt, vanadium and
ammonia paratungstate on about 10 acres of the current CECOS property from
the 1930's to the early 1960's. These operations were conducted in buildings
with concrete floors. The buildings have since been removed.
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53
This processing area occupied a portion of the facility, which was later
used for the scrap metal salvage operation (discussed above). Thus, the
proposed study and preliminary results discussed in the previous section apply
to this process area as well.
Ammonium Chloride Application
Ammonium chloride was applied to soil at the facility between 1977 and
1979 (reportedly for dust control) at the rate of about 30,000 gallons per month.
A portion of the application area has since been used for construction of
SCMF 5.
Elevated concentrations of ammonia have been found by CECOS in the
ground water in the general vicinity of this activity. CECOS has proposed
additional study to further evaluate the impact of this ammonium chloride
application.
Thorium Disposal
Slag and dust from the production of ferro-columbium alloy at Union
Carbide, possibly containing thorium oxide, were buried at CECOS in the late
1960's. The waste was buried in pits which were about 30 feet square and 4
feet deep. The exact size and location of the total disposal area is unknown;
however, the general vicinity of disposal activity was posted as containing
radioactive material. CECOS reports that numerous surveys conducted in the
suspected area of disposal failed to show more than "background levels" of
radioactivity at the surface. Reported detection limits for the radiochemistry
analyses, however, are suspect (see Sample Analysis and Data Quality
Evaluation section). Consequently, background levels are poorly defined.
Roadway Oiling
Oil-water solutions were applied to CECOS roadways from
approximately 1976 to 1980, reportedly for dust control. Principal roadways
oiled were those between the front gate and the sanitary landfills. Little
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information is available on the type of oil used; however, oil content reportedly
ranged between 2% and 40% of the mixture. The roadways that were oiled
have either been removed or paved. Because of the limited information on the
composition of the oil, CECOS proposes to conduct core sampling of and near
the old roadways to try to define any environmental impact.
Leachate Collection/Storage Tank For SCMF 1. SCMF 2 and SCMF 3
A leachate collection tank, used to collect and store leachate pumped
from SCMF 1, SCMF 2 and SCMF 3, was located somewhere just north of these
landfills. Little information was available for this unit, which was reportedly an
above ground tank that has been removed.
Building Debris
Building debris from the demolition of buildings of the Buffalo Color
Company was disposed of in an area between SCMF 1 and Sanitary landfill 1
in 1979. Sanitary landfill III has been built over this area.
Industrial operations which had been conducted in the building prior to
demolition raised concerns about the impact of this disposal (i.e., leaching of
hazardous waste constituents) on the area surface and ground water.
According to CECOS, a 6-month study of this area indicated that no
environmental impact was expected.
Buried Waste Transport Pipelines
Various buried pipelines are used to transport liquid containing
hazardous waste constituents within the site. The leachate transfer lines for
SCMF 4 and SCMF 5, the runoff transfer lines for the container management
unit and the washwater pipe for the truck wash were discussed in the previous
sections.
Additionally, an 18-inch-diameter pipeline is currently used to transport
effluent from the Phase I to the Phase II WWTP. This line is periodically
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pressure tested and has been reported to be tight, according to CECOS
personnel.
Ground water pumped from the Necco Park site is also pumped through
an underground pipeline to the Phase II WWTP. No information on the testing
of this line was available.
Finally, as with any complex industrial facility, other underground
pipelines may have been used in various past operations. If not plugged,
abandoned pipelines could provide conduits for hazardous waste or hazardous
waste constituents to enter the ground water.
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SITE HYDROGEOLOGY
The CECOS facility has been undergoing a process of site
characterization and hydrogeologic investigation continuously since 1978. In
that time, 18 different consultants have generated 40 reports of various types
dealing with both individual areas and the property as a whole. The following
information was derived from several of the major hydrogeologic reports
prepared to date and a hydrologic overview presented by BFI hydrogeologists
during the inspection.
Generally, the site hydrogeology has been adequately characterized for
the purpose of monitoring the regulated units. The EPA 3008 order, however,
required better definition of ground-water flow near SCMF 4. A report on this
work, which included a pump test, was being prepared by CECOS during the
Task Force inspection. During the overview presentation, BFI hydrogeologists
discussed the results of the SCMF 4 investigation. To date, more than 300
monitoring wells have been installed at the site, primarily in three transmissive
zones, which are described below.
HYDROGEOLOGIC UNITS
Two major stratigraphic units have been identified beneath the CECOS
site: overburden and bedrock. 1 The overburden consists of four types of
materials which include industrial fill, lacustrine (lake deposited) silty clay,
glacial till and weathered bedrock. The overburden thickness generally ranges
from 5 to 55 feet thick across the site, with as little as 5 to 10 feet in the Necco
Park and Acid Neutralization areas.
The industrial fill consists of metallurgical slag, cinders, ashes, municipal
sludge, lime sludge, foundry sand, building rubble and miscellaneous earth fill.
In some areas, the fill was placed directly on top of the glacial deposits while in
others the clay and till deposits have been excavated prior to disposal of
industrial fill.
The lacustrine silty clay, where present, ranges in thickness from 3 to 10
feet and overlies 0 to 5 feet of dense glacial till. The lacustrine clay is generally
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continuous across the site except where it has been removed by excavation.
The clay is brownish yellow and is commonly varved. The unit contains
occasional horizontal stringers of sand and silt. The overburden horizons,
above and including the lacustrine clay material, are referred to as the "top-of-
clay" transmissive zone.
The glacial till is typically heterogeneous, nonstratified and poorly sorted.
It consists of silt, sandy silt, sand, pebbles and varying amounts of clay-size
material.2 The till is discontinuous across the site and the lacustrine clay is
often found directly overlying the bedrock. The upper portion (about 10 feet) of
the bedrock, is generally, highly fractured and weathered. This portion of the
bedrock and the overlying glacial till compose the "top-of-rock" transmissive
zone.
The bedrock underlying the site is the relatively flat-lying Lockport
Dolomite, which is a massively bedded, grey to brownish colored dolomite,
averaging 135 feet in thickness. The Lockport Dolomite is subdivided into five
members: Oak Orchard, Eramosa, Goat Island, Gasport and Decew [Table 7].
The Rochester Shale Formation underlies the Lockport Dolomite. It
consists of grey dolomite and silty shale and its thickness is approximately 60
feet in the area. Characterization of deeper units has not been completed for
the site. To date, none of the monitoring wells penetrate the Rochester shale.
The bedrock surface slopes from northwest to southeast across the site
from an elevation of 590 feet to 550 feet. Beneath the northwest portion of the
site the bedrock surface slopes at approximately 15 feet per 1,000 feet (1.5%)
and at approximately 5 feet per 1,000 feet (0.5%) beneath the southeast portion
of the site. The direction and magnitude of the slope of the bedrock are
comparable to the regional dip of the sedimentary bedding planes in the
Lockport and underlying formations.
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Table 7
CHARACTERISTICS OF LOCKPORT DOLOMITE MEMBERS
Approximate
Thickness at
Member Lithology Site (feet)
Oak Orchard Brown to grey, fine to medium grained, 70
thin to thick bedded dolomite
Eramosa Grey, fine grained, thin to medium 16
bedded, argillaceous and bituminous
dolomite
Goat Island Greenish to brownish grey, medium 22
grained, thick bedded dolomite
Gasport Greenish to brownish grey, coarse 20
grained, medium to thick bedded
fossiliferous dolomite and limestone
Decew Grey, fine grained, thin bedded to 8
massive argillaceous limestone
Ground-water flow in the Lockport Dolomite occurs principally along
horizontal bedding planes, joints, fractures and solution cavities. Recharge to
lower water-bearing zones from upper zones within the bedrock occurs
principally through solution cavities and along vertical joints and fractures. A
moderately permeable zone exists in the upper few tens of feet below the top-
of-rock zone and is referred to as the "bedrock" transmissive zone. This zone
has extensive vertical joints and bedding planes, widened by the solution of
dolomite, and small solution cavities.2 These features are not as well
developed as in the top-of-rock zone.
Both the NYSDEC and EPA consider the top-of-clay, top-of-rock and
bedrock transmissive zones combined to compose the uppermost aquifer for
ground-water monitoring required by State regulations.
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GROUND-WATER FLOW DIRECTIONS AND RATES
In the top of clay zone, ground water occurs on top of the lacustrine clay
under water table (unconfined) conditions. The fill material overlying the
lacustrine clay is moderately permeable. The clay, where present (excavated in
some portions of the property) serves to retard downward migration of ground
water. Where clay is not present, surface water more readily recharges the top-
of-rock transmissive zone.
Ground-water flow in the top-of-clay zone is predominantly south-
southeasterly. Localized variations in flow directions range from due west to
due east. Variations in the thickness of the clay unit and man-made influences
(i.e., mounding) account for the reported flow directions. Flow rates range from
0.0004 to 0.02 feet per day. Permeability values range from 10-4 to 10-5
centimeters per second (cm/sec). Hydraulic gradients range from 0.01 to 0.02.
Vertical hydraulic connection with the top-of-rock zone is found in the central
southwest portion of the site.2
The top-of-rock transmissive zone exists under artesian (semi-confined)
conditions where overlain by lacustrine clay. This zone consists of the
unconsolidated till materials underlying the clay and extends downward to
include the upper 5 to 10 feet of the Lockport dolostone.
Ground water in the top-of-rock zone flows in a southeasterly direction at
a calculated rate of 0.06 to 0.1 feet per day.* Permeability values range from
10-3 to 10-4 cm/sec and the hydraulic gradient ranges from 0.005 to 0.01.
Vertical hydraulic connection with the bedrock zone is reported in the central
portion of the site. The absence of the confining clay layer in the northwestern
portion of the site may account for a steep hydraulic gradient in that area. This
area is likely to be a source of direct recharge to the top-of-rock transmissive
zone.2
Flow rates in fractures are probably higher than the calculated flow rate, which represents
an average through a unit cross-section.
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Ground water in the bedrock transmissive zone occurs under semi-
confined conditions. Differentiation between this zone and the top-of-rock is
based on depth according to different CECOS consultants. Ground-water flow
is predominantly toward the southeast; however, pumping wells in the
southwest portion of the site have reportedly altered the flow patterns in their
vicinity. The calculated rate of ground-water flow ranges from 0.003 to 0.03 feet
per day. Permeability in the zone ranges from 10~5 to 10~6 cm/sec. The
hydraulic gradient varies across the site and ranges from 0.005 to 0.01.2
Hydraulically, the top-of-rock and bedrock zones are connected by joints
and fractures. The degree of interconnection is dependent on variations in the
distribution and density of joints and fractures and the continuity of natural
vertical pathways for ground-water movement. Excavation and construction
activities at this site have contributed to the degree of interconnection between
the top-of-rock and bedrock transmissive zones.
During the Task Force inspection, water level measurements [Table 8]
were made by Recra personnel in wells near SCMF 4 and 5 (see Investigative
Methods section and Figure 3). Water levels were also measured before
purging, for use in calculating purge volumes. The data indicate that the
measurements lack the precision to adequately determine ground-water flow
directions in the vicinity of the units. Duplicate measurements at 15 wells varied
by as much as 0.26 feet (well 252). Consequently, historical water level data
may be suspect.
A comparison of the initial water level measurements with those made
before purging (1 to 9 days later), revealed several substantial changes (from
+2.63 to -5.56 feet). Whether the apparent changes were due to measurement
errors or real changes in water levels could not be determined from the data;
however, because there is no apparent pattern to the changes, measurement
errors are suspected. These potential errors are much greater than
themaximum differences in water levels across either unit; therefore, ground-
water flow directions inferred from these and previous data are potentially
inaccurate.
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Table 8
WATER LEVEL MEASUREMENTS MADE BY RCRA IN WELLS NEAR SCMFs 4 AND 5
Well Depth
Nuatoer to Water*
164 7.52
165 6.28/6 14
167 4.25
168 10.42
169 27.92
170 38.34
171 37.40/37 35
172 17.74
173 38.23
250 6.04
251 5.58
252 9.09/8.83
260 37.50
261 3.40
413 27.32/27.34
414 38.31
415 38.10
416 37.06
417 38.15
418 39.48/39.46
419 38.80
420 39.02
421 39.47
422 36.33
423 39.32/39.34
424 39.31
425 39.29
300 44 12/44.09
301 43.67/43.65
302 32.30/32.29
303A 48.35/48.36
304 44.37/44.35
305 33.64/33.75
306 56.29
307 45.78
308 58.31/58.30
309 58.74
310 55.68
311 46 75/46.74
312 57.42/57.43
313 57.17
314 48.27
315 58.06
316 53.51
317 49.33
318 55.89
319 54 25
Depth to Water
Before Purge**
SCMF 4
8.49
6.86
10.80
28.02
38.34
4 20
27 22
36.69
40.65
41.22
SCMF 5
45.95
51.81
52.69
52 50
51.83
* Initial and duplicate measurements
as distance, in feet, below the top
near SCMF 4 were
10/22/86.
** Distance, in feet,
*** Difference between
purge in feet.
made on 10/21/B6
below the top of
Number of
Days Between
Differences*** Measurements
+0.97
+0.72
+0.38
+0.10
+0.99
+0.80
-0.12
+2.63
+2.50
+2.42
+0.12
-3.87
-4.48
-5.56
-1.68
recorded by Task
3
3
9
6
6
3
6
2
2
2
6
8
6
7
6
force personnel,
of casing. Measurements at wells
and at wells near SCMF 5 on
casing.
initial depth recorded and that
recorded before
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Furthermore, allowable leachate levels in the units [approximately 585
feet above mean sea level (msl) for SCMF 4 and 592 feet above msl for
SCMF 5 are above the water levels in adjacent monitoring wells completed in
the top-of-rock and bedrock zones [Table 9]. This suggests that none of the
wells is upgradient since they are not out of the potential area of influence of
either regulated unit. CECOS needs to make future water level measurements
with greater precision and accuracy. If there are significant fluctuations in
elevation from one day to the next as seen during the inspection then an
explanation needs to be provided.
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Table 9
WATER LEVEL ELEVATIONS IN WELLS NEAR SCMFs 4 AND 5
Well
Number
164
165
167
168
169
170
171
172
173
250
251
252
260
261
413
414
415
416
417
418
419
420
421
422
423
424
425
300
301
302
303A
304
305
306
307
308
309
310
311
312
313
314
315
316
317
318
319
1 re -
2 Feet
3 Calcu
Transmissive Top of Casing
Zone1
TR
TR
TR
R
TC
TR
R
TC
TR
R
TR
TR
TR
TR
TC
TR
TR
TR
TR
TR
TR
TR
TR
TR
TR
R
TR
R
TR
TC
R
TR
TC
TR
TC
R
R
TR
TC
R
TR
TC
R
TR
TC
R
TR
Top of clay
Elevation2
SCMF 4
582.83
580.92
578.24
578.37
610.80
612.39
611.44
612.42
612.41
580.62
580.30
582.81
611.70
577.38
611.67
612.41
612.27
511.13
612.21
613.54
612.87
613.21
613.90
611.02
613.82
613.88
613.74
SCMF 5
610.61
610.25
610.99
614.03
612.97
615.09
624.96
624.97
624.53
624 62
624.93
626.18
625.43
626.43
625.85
626.05
625.80
623.77
623.97
623.68
TR - Top of rock R
Water Level
Elevation2 3
575.31
579.78
573.99
567.95
582.88
574.05
574.09
594.68
574.18
574.58
574.72
573.98
574.20
573.98
589.33
574.10
574.17
574.07
574.06
574.08
574.07
574.19
574.43
574.69
574.48
574.57
574.45
566.49
566.58
578.70
565.67
568.62
581.34
568.67
579.19
566.23
565.88
569.33
579.44
568.00
569.26
577.58
567.99
572.29
574.44
568.08
569 43
= Bedrock
above moan sea level
la ted using
and 22, 1986, as
data obtained on
listed in Table 3.
October 21
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GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS
Ground-water monitoring at the CECOS facility has been conducted
under both Federal interim status regulations and equivalent State regulations.
The following is an evaluation of the monitoring program followed between
November 1981, when the ground-water monitoring provisions of the RCRA
regulations became effective, and July 1985 (see Introduction section). After
July 1985, CECOS continued to operate under authority of and pursuant to the
State-issued general operation permit. Unless otherwise noted, deficiencies
described in the ground-water monitoring program being followed in July 1985
were not corrected before the Task Force inspection. This section addresses:
Regulatory requirements
Ground-water sampling and analysis plan
Sample analysis and data quality
Ground-water quality assessment outline
REGULATORY REQUIREMENTS
The information presented here is included as a background for
subsequent discussions of compliance by CECOS with the various monitoring
requirements. Regulatory requirements for ground-water monitoring at the
CECOS facility are complex and precepts (i.e., guiding principles) have
changed since 1981 when the RCRA interim status provisions went into effect.
Because of this, CECOS developed different monitoring programs for nearly
identical State and EPA requirements.
The interim status program was administered by EPA from November
1980 until late December 1983, when NYSDEC was delegated interim
authorization. Ground-water monitoring requirements for interim status during
this period are contained in 40 CFR Part 265, Subpart F. Under the program
administered by NYSDEC, a two-part regulatory framework controlled the
design, installation and operation of the ground-water monitoring program at
the CECOS facility. These were: (1) facility requirements contained in the New
York State Part 360 regulations [360.8(c)(5)] and (2) the general operation
permit (No. 3404) issued by NYSDEC, which became effective on April 4, 1983
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and incorporated the MMCP by reference. The State regulations, operating
permit and MMCP impose somewhat different requirements than the RCRA Part
265 regulations, as explained below.
State Regulations
The New York State Part 360 Facility Requirements (March 1982
revision) for ground-water monitoring were nearly identical to, but broader in
scope than, the RCRA Part 265, Subpart F interim status requirements. The
substantive differences were that the State could require ground-water
monitoring of (1) units other than surface impoundments, landfills and land
treatment areas (units covered by subpart F regulations); (2) water-bearing
zones other than the uppermost aquifer; and (3) separate waste management
components, even if they were within a line circumscribing several units.
Furthermore, Part 360 regulations governed management of PCB wastes.
Regulation counterparts are shown in Table 10.
General Operation Permit and MMCP
The principal requirements in the permit (No. 3404) pertaining to ground-
water monitoring are contained in General Condition 6 and Special Condition
2, 10 and 14. They require the facility to follow State regulations and maintain
and follow an MMCP (which is contained in the Facility Operation Plan). The
MMCP is considered by CECOS and NYSDEC to be the ground-water
sampling and analysis plan required by State regulations [360.8(c)(5) (iii)].
GROUND-WATER SAMPLING AND ANALYSIS PLAN
From the effective date of the RCRA ground-water monitoring
requirements (November 19, 1981) until July 1985, two ground-water sampling
and analysis (monitoring) plans were followed. The first was for the interim
status program under RCRA regulations, which was administered by EPA. The
second was for the program developed under State regulations and was
administered by NYSDEC. Neither plan fully complied with the regulatory
requirements, as explained below.
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Table 10
STATE AND FEDERAL COUNTERPART
INTERIM STATUS REGULATIONS
New York State RCRA
Subpart Regulation Regulation
Title* (360. +) (40CFRPart)
Applicability 8(>
Ground-water 8(
c)(5)(i) 265.90
c)(5)(ii) 265.91
Monitoring System
Sampling and Analysis 8(c)(5)(iii) 265.92
Preparation, 8(c)(5)(iv) 265.93
Evaluation
and Response
Reporting and 8(c)(5)(v) 265.94
Recordkeeping
Subpart titles are the same in both the State and RCRA regulatons.
Monitoring Plan Under EPA/RCRA Regulations (1981-1983)
By November 1981, CECOS had developed a monitoring plan titled
"RCRA Groundwater Monitoring Program for Hazardous Waste Management
Facilities at the Pine Avenue Site" to meet EPA requirements. The plan,
provided to Task Force personnel by CECOS, addressed all of the Subpart F
provisions [295.92(a)]; however, many necessary details regarding sampling
and analysis were omitted. The designated monitoring well network did not
comply with the regulations [265.91 (a)].
According to RCRA regulations [265.92(a)j, a ground-water sampling and
analysis plan must address (1) sample collection, (2) sample preservation and
shipment (3) analytical procedures and (4) chain-of-custody control. The
procedures described for sample collection were inadequate because the
measurement of water level elevations and the related calculation of purge
volumes were not described. The water level elevation must be determined
each time a sample is obtained [265.92(e)]. The plan states that bailers and
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peristaltic pumps were to be used for sample collection. Equipment
decontamination procedures and explanations about whether any equipment
was dedicated to a specific well were omitted.
The section on sample preservation is incomplete because no
preservation procedures are specified for pesticides, radionuclides, total
organic carbon, total organic halogen, specific conductance, coliform bacteria
and pH (which was not measured in the field in order to meet the EPA-
recommended holding time, as it should have been). The preservation
procedure specified for nitrate is incorrect. Samples for nitrate analysis should
be cooled to 4 ฐC. rather than acidified to a pH of less than 2. Several other
parameters were to be preserved by addition of acid to a specified pH; however,
there were no procedures described for determining when that pH was
achieved in the sample.
No procedures for sample shipment were described, except that the
samples should be placed in a strong container with ample packing. Details
need to be presented regarding sealing of the container to prevent or provide
indications of unauthorized entry. Contractor personnel responsible for
collecting samples from 1981 to present stated that they never had written
procedures for shipping samples even through the task is routinely performed.
Analytical procedures were incomplete because no method was
presented for total organic halogen; rather an alternative test, identified as a
halogenated organic scan procedure, was indicated. EPA Region II has no
record of CECOS requesting approval for an alternative test procedure. For
many of the parameters more than one test method is indicated. Citing multiple
methods for one parameter is not acceptable because those methods may yield
significantly different results for the same sample.
Chain-of-custody procedures were acceptable.
The monitoring well network designated in the plan initially comprised six
wells [Figure 6], which were completed in the top-of-rock zone. The plan stated
that ground water in that zone flowed from the northeast toward the southwest.
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Consequently, wells 3, 18 and 64 were designated as upgradient wells. The
network ostensibly monitored SCMF 1 through 4 and the intermediate landfill.
After the first quarter of monitoring, two other wells (10 and 20) were
added to the network. These wells were just upgradient from SCMFs 2 and 3,
respectively, and were intended to provide more information on the quality of
ground water coming from the Necco Park area.
Data provided by CECOS indicate two major deficiencies in the
monitoring well network. First, hydrogeologic reports prepared in July 1978,
April 1981 and August 1981 clearly show that ground-water flow in the top of
bedrock zone is not southwesterly across the entire site.3 4 5 These reports
indicate a southwesterly flow only in the western part of the facility. In the
central portion of the facility, near the intermediate landfill, flow in the top-of-rock
zone is southerly. In the eastern portion, near SCMF 4, the ground-water flow is
northeasterly and southeasterly.
Consequently, the well network was not adequate for monitoring
potential releases from the intermediate landfill and SCMF 4. Company
personnel attributed the inaccurate description of the flow direction across the
site in the monitoring plan to a "mistake"; however, because of this mistake the
monitoring well network was much smaller than would have otherwise been
necessary.
Secondly, the plan did not include all regulated units that required
ground-water monitoring under RCRA regulations [265.90(a)]. Units not
addressed in the monitoring plan nor covered by the well network were the
Phase I and Phase II wastewater treatment units, both of which included surface
impoundments. Furthermore, based on ground-water flow directions discussed
in the reports referenced above, only two (SCMFs 2 and 3) of the six regulated
units requiring a ground-water monitoring program were actually being
monitored.
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Monitoring Plan Under NYSDEC/State Regulations (1984-1985)
Under the State Part 360 regulations, like the Federal counterparts, a
facility must develop and follow a ground-water sampling and analysis plan. As
previously discussed, the MMCP represents the required plan for the CECOS
facility according to Company and State personnel. The MMCP, however, was
developed before State regulations were revised to reflect those promulgated
under RCRA. As a result, the MMCP does not fulfill most of the State regulatory
requirements for a ground-water monitoring program plan. This section
describes the development of the MMCP and the major deficiencies.
Most of the MMCP was developed pursuant to Special Condition 8 of a
general operating permit for the facility (No. 2025) issued by NYSDEC in
October 1979. The permit required that an MMCP be submitted to the
Department for approval by January 1980. The approved version of the MMCP
was dated April 28, 1980. Another operating permit (No. 2561) was issued by
NYSDEC for SCMFs 4 and 5 in November 1981 which required (Special
Condition B 5) development of MMCP for those units. At least three versions of
an MMCP for SCMFs 4 and 5 were prepared. The most recent version on file
was dated April 29, 1981, well before the permit was issued.
The general operation permit (No. 2025) expired in October 1981. An
application for renewal of that permit, along with three other permits issued to
the facility (Nos. 2268, 2306 and 2581), was received by NYSDEC in August
1982. When renewed, these permits were combined with the operation permit
for SCMFs 4 and 5 into a new general operation permit for the facility (No.
3404), which was issued on April 4, 1983. During the period between October
1981, when the general operation permit expired, and August 1982, when the
renewal application was submitted, the Part 360 interim status regulations were
promulgated (March 1982).
The renewal application, mentioned above, contained a facility operation
plan that included the MMCP for all waste management units. The proposed
monitoring program was essentially the same program that had been
developed and approved under the former operating permits No. 2025 and
2561. The proposed MMCP was approved as the monitoring plan for Permit
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southerly, the three nearby top-of-c!ay wells (66, 68 and 119) and two top-of-
rock wells (67 and 69) [Appendix B] are inadequate to immediately detect
releases from L-1 (currently out of service), LR and major areas of L-2, L-3 and
L-4. Furthermore, leakage from the western area of L-3 and the eastern area of
L-4, would probably migrate southward, undetected by the MMCP monitoring
wells.
At the Phase II WWTP, where ground-water flow is southwesterly, one
top-of-clay well (71) and two top-of-rock wells (72 and 73) are designated for
downgradient monitoring. Well 71 is not close enough to the waste
management units and leakage from all or major areas of L-5 through L-11
would probably go undetected.
SAMPLE ANALYSIS AND DATA QUALITY EVALUATION
This section provides an evaluation of the quality and completeness of
ground-water monitoring data gathered by CECOS between January 1982 and
June 1986. Recra Environmental (formerly known as Recra Research, Inc.) of
the City of Townawanda, New York was responsible for sampling, analytical
work and reporting of monitoring data for CECOS during this time period. The
Recra laboratory was evaluated concurrently with the onsite inspection of the
CECOS facility. During the laboratory evaluation, operating and analytical
procedures, internal data reports, raw data and quality control records were
reviewed and analytical equipment was examined.
The inspection revealed problems that could affect data quality. Written
standard operating procedures were not completed and in use until January
1984. The analytical methods used did not take into account the high dissolved
solids content of samples which could adversely affect data quality. Holding
times were routinely exceeded for pH until 1985, when field measurements
were initiated. Conductance results were not corrected for temperature or the
cell constant. Total organic carbon (TOC) results actually represent
nonpurgeable organic carbon (NPOC), which excludes purgeable organic
carbon. CECOS did not perform total organic halide (TOX) measurements.
Fluoride and nitrate results may not be reliable due to lack of corrections for
interferences and some phenol data are suspect. Detection limits reported for
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3404; however, when compared against the regulatory standards [360.8 (c)(5)]
that were in effect when the permit was issued, the MMCP has numerous
deficiencies.
Although the MMCP included a network of more than 100 wells, it does
not include a statistical comparison indicator parameter data from upgradient
and downgradient wells, nor does it include procedures for sample
preservation, shipment and chain of custody. It does not list a specific analytical
method for each analytical parameter, and the list of monitoring parameters is
not as comprehensive as required. CECOS only had historical analyses of 11
of the 21 parameters that were initially to be used to characterize the suitability
of the ground water as a drinking water supply. Furthermore, the MMCP
proposed to monitor for only 2 of the 6 parameters that must be measured
annually to establish ground-water quality.
Though not in conformance with the Part 360 requirements, certain
aspects of the approved MMCP program have technical merit. All of the MMCP
wells are sampled at least quarterly, and those in the vicinity of the hazardous
waste landfills are sampled bimonthly. The monitoring parameters that are
measured in wells near each waste management unit were chosen to reflect the
types, quantities, concentrations and mobility of constituents in wastes
managed at the unit.
The adequacy of the construction, design and location of the MMCP
monitoring network wells was being evaluated by CECOS during the Task
Force inspection in response to the EPA consent orders and modification of the
State-issued permit, as previously discussed. Many of the wells near SCMFs 1,
2 and 3 were already slated for replacement and proposed locations for
additional new wells had been submitted to EPA and NYSDEC. During 1986,
13 wells were installed adjacent to SCMF 4 and the 300-series wells around
SCMF 5 were incorporated into the MMCP network.
The improvements to the monitoring well network, however, have not
addressed deficiencies at the Phase I and II WWTPs. At these locations, the
well network is inadequate for immediately detecting releases from most areas
of the regulated units. At the Phase I WWTP, where the ground-water flow is
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some metals were inadequate for determining the suitability of ground water as
a drinking water supply. Pesticide, herbicide and other specific organic
compound determinations lacked adequate quality control. These problems
are discussed in the following sections.
Initial Year of Monitoring M9821
RCRA regulations [265.92(c)] require quarterly monitoring of all wells
during the initial year to establish background values. Quarterly monitoring of
the upgradient wells must include quadruplicate measurements of the four
parameters used as indicators of ground-water contamination (pH, specific
conductance, TOC and TOX).
In January 1982, CECOS initiated quarterly monitoring pursuant to
265.92(c) on the RCRA well network. The network included wells 3, 18 and 64
as upgradient and wells 8, 19 and 26 as downgradient. Monitoring of two
additional upgradient wells, 10 and 20, began the second quarter of the initial
year. Quarterly monitoring was conducted on wells 10 and 20 for the second,
third and fourth quarter of the initial year only; no additional samples were
collected for the first quarter monitoring that was omitted.
The pH data are suspect because measurements were made after the
EPA formerly recommended holding time of 2 hours and substantially after the
current recommended holding time of 15 minutes. Typically, pH measurements
were made a day or two after collection, which would affect the accuracy of the
determinations.
Specific conductance measurements were not corrected for temperature
or the cell constant which adversely affected the accuracy of the determinations.
These practices could introduce a higher variability between quarters for a well
than actually existed.
The results for TOC are biased low. The values reported for TOC
represent only NPOC because of the analytical method used. The method used
involved acidifying the sample and purging it with nitrogen gas before
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determining the organic carbon content. This procedure results in the loss of
purgeable (volatile) organic carbon.
CECOS substituted a halogen organic scan/electron capture detector
(HOSE) analysis for the TOX analysis. State and EPA regulations require
analysis of ground-water samples for TOX. HOSE results are not equivalent to
TOX results and do not satisfy the regulatory monitoring requirements for TOX.
The HOSE analysis evolved from a screening test for PCBs required by the
State and consists of analyzing a solvent extract of the sample by gas
chromatography. By contrast, the TOX method involves the adsorption of
organics from the whole sample onto activated carbon (in a closed system),
combustion of the activated carbon and coulometric titration of the evolved
halides.
Fluoride results may not be reliable as samples were not distilled prior to
measurement. Distillation may be required to eliminate possible interferences.
Nitrate values may not be reliable because the steps in the brucine sulfate
colorimetric method for interference corrections were not performed. The
phenol value reported for well 19 in the second quarter is suspect as the
concentration is ten times lower than the other three quarters and no similar
significant change was observed in the TOC results.
Most of the metals were determined after digestion by flame atomic
spectroscopy methods. Analysis for mercury was being satisfactorily
determined by cold vapor atomic absorption spectroscopy. Adequate methods
were not used for sodium, arsenic and selenium determinations. Sodium was
determined using flame emissions spectroscopy. The percent level dissolved
solids content of the well samples (as indicated by conductance) require
background correction and the use of a large amount of ionization reagent to
enable proper analysis. Neither control measure was used in the analyses and
several sodium results were determined to be erroneous; consequently, all
reported sodium should be considered suspect. For example, the sodium
concentration of 2300 milligrams per liter (mg/L) reported for well 18 (fourth
quarter) is erroneous, as indicated by sodium and chloride equivalence ratios.
For the other three quarters, the ratios ranged from 0.78 to 0.96 while the ratio
for the fourth quarter was 0.079. Similar equivalence ratios, also substantiated
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The radiochemical analyses were contracted out by Recra. The gross
alpha and beta results are suspect. Many of the gross alpha values are
reported as not detected at 2 picouries per liter (pCi/L). This detection limit is
achievable for samples containing low levels of dissolved solids, but not
samples containing percent levels (i.e., greater than 10,000 mg/L of dissolved
solids). Because of the high dissolved solids content of the CECOS ground-
water samples, the analytical method used by the laboratory required the use of
smaller sample aliquots, which resulted in higher detection limits than those
reported. Based on the dissolved solids indicated by the conductance values,
the detection limit for the gross alpha samples would have ranged from 2 pCi/L
to 80 pCi/L For the same reason, many of the gross beta results should also be
considered suspect. The detection limits for gross beta could have ranged from
2 pCi/L to 200 pCi/L.
Analytical results for pesticides and herbicides are suspect. Recra
reported values for the pesticide lindane on the basis of a single column
identification. It is customary to confirm the presence of pesticides using
alternate column gas chromatography with an electron capture detector or with
a mass spectrometer. No well samples were spiked with either pesticides or
herbicides to assess matrix effects on these determinations. Matrix effects
would be expected to be significant for these samples because of the high
dissolved solids content.
Recra has analyzed samples from about 35 monitoring wells adjacent to
the CECOS hazardous waste landfills for organic priority pollutants
semiannually since 1982. This monitoring was required by EPA approvals for
disposal fo polychlorinated biphenyls (PCBs), issued under authority of the
Toxic Substances Control Act (TSCA). The samples were analyzed for volatile
(VGA) priority pollutants using EPA Method 624 and for extractable (BNA) using
EPA Method 625. Priority pollutant identifications near the detection limits are
suspect. Compounds were identified by retention time using the ratios of the
relative abundances of characteristic ions for each compound. At low levels,
this procedure can result in erroneous identifications. Identifications need to be
confirmed by comparing the mass spectrum of the compound in the sample to
the mass spectrum of a standard reference compound.
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by the conductance, indicate that the sodium values reported for well 10 (third
quarter), well 8 (fourth quarter) and probably wells 19 and 26 (second and
fourth quarters) are erroneous. Furthermore, the sodium values reported for
well 20 (third and fourth quarters) are erroneous, as evidenced by sodium to
conductance ratio; sodium accounts for too much of the conductance.
The high dissolved solids probably interfered with most of the analyses
conducted by flame atomic absorption spectroscopy methods. This interference
would be particularly evident in the barium analyses, where no background
correction or ionization reagents were used. The high cadmium values
reported for many of the wells in the fourth quarter are suspect; not only
because of dissolved solids interference, but also because cadmium was not
detected at such high levels in the other quarters. Flame atomic spectroscopy
methods do not achieve the detection limits required to reliably establish
background levels near and below the drinking water limits for elements such
as cadmium, lead and chromium, especially for water samples of such high
dissolved solids.
Hydride generation atomic absorption spectroscopy methods were used
for arsenic and selenium determinations. The method used sodium
borohydride as the reductant while the EPA method uses stannous chloride and
zinc metal as the reductants. The digestion used to prepare the samples does
not render organo-arsenic or organo-selenium compounds to a quantitatively
measurable form. The very high organic content of the samples emphasizes
the need to assure that such compounds would be measured. Furthermore,
steps were not incorporated to assure that all other arsenic and selenium were
in the measurable forms. It is possible that these elements would not have
been detected or the reported concentrations would be biased low.
Furthermore, the detection limit often reported for selenium was not low enough
to reliably establish background levels near and below the drinking water
standard of 10 micrograms per liter (ug/L).
The detection limits reported for the mercury determinations were often
much greater than the drinking water standard of 2 ug/L, thus, background
levels near or below the standard were not reliably established.
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Monitoring from 1983 to 1985
The laboratory findings discussed in the initial year of monitoring are also
applicable to the semiannual data, as most of the methods did not change. In
1983, the four parameters used as indicators of ground-water contamination
were reported in quadruplicate for the RCRA well network semiannually.
During the second half of sampling in 1983, pH and specific conductance were
done 28 days after the samples were received. Beginning in 1985, pH and
specific conductance were done in the field.
The parameters used as indicators of ground-water quality (phenols,
chloride, sulfate, iron, manganese and sodium) were reported once per year, in
1983 and 1985. The metals, iron and manganese were analyzed using flame
AA and sodium was analyzed using flame emission photometry, as previously
discussed.
Current Practices (January to October 1986)
The samples are still being analyzed using the same methods and
procedures used in 1983, with the following exception. Arsenic, selenium and
lead are determined using furnace atomic absorption spectroscopy; however,
the method of standard addition is not used. The high dissolved solids content
of many of the samples would cause interference in these metal determinations.
This interference could have been mitigated by using the method of standard
addition. The data should be considered suspect.
GROUND-WATER QUALITY ASSESSMENT OUTLINE
During the period that the interim status program was administered by
EPA (1981-1983), the outline for a ground-water quality assessment program
was included in the monitoring plan. During NYSDEC administration of the
program (1984-1985), an "outline" of general procedures to be followed if
ground-water contamination were detected was presented in the MMCP.
The outline in the RCRA monitoring plan was generally acceptable for
the period it was in effect. As explained earlier, precepts for implementing the
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regulations have changed. To satisfy current expectations, much more detail
and some changes in the procedures would be necessary. For example, the
outline section titled "Sample and Analytical Methods" states that once a source
area is identified, samples would be analyzed for specific parameters instead of
the screening/indicator parameters. The procedure for determining such
parameters, which was not included, would be necessary. Furthermore, an
expanded parameter list would be necessary during the source identification
phase.
The MMCP procedures for responding to ground-water contamination
are presented for each type of regulated unit, but are essentially the same. The
principal elements are to:
Remove liquids from the suspected source area
Pump ground water from existing wells until remedial repair is
completed and the water quality data returns to background levels
Determine extent of containment failure
Develop engineering plans to correct the situation in an
environmentally sound and economical manner
The MMCP procedures are inadequate because they do not describe:
Whether or how data triggering assessment would be evaluated to
confirm the apparent contamination
How the apparent source would be determined
Whether or how additional hydrogeologic data would be collected
How the rate and extent of contaminant migration would be
determined
Which aquifer zones would be monitored
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How a monitoring plan would be developed and what the
projected sampling frequency would be
Which analyses would be conducted on ground water and soil
samples to identify contaminants of concern
Analytical methods to be used on the samples
How the data would be evaluated to determine if more work is
required or the facility could return to the indicator evaluation
program
Approximate time frames for sampling, analysis, data evaluation
and report preparation
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GROUND-WATER MONITORING PROGRAMS PROPOSED FOR FINAL
PERMITS
In August 1983, CECOS submitted a Part B RCRA permit application to
EPA Region II for waste management units that were subject to RCRA
regulations at that time (i.e., operated or closed after November 19, 1980).*
Subsequently, CECOS decided to seek a permit for a new landfill that was not
proposed in the Part B. To expedite permitting of the proposed landfill, a
separate Part B application was prepared and submitted to EPA Region II and
NYSDEC in May 1985.
The two applications (although extensively revised) were being reviewed
by NYSDEC personnel during the Task Force inspection. The proposed
monitoring programs in these applications are discussed in this section. The
sampling and analysis procedures for the proposed plans have, in effect,
already been implemented and were evaluated during the Task Force
inspection. The sampling procedures are discussed in this section; analytical
procedures were addressed in the section on Sample Analysis and Data
Quality Evaluation.
GENERAL FACILITY PERMIT APPLICATION PLAN
The ground-water monitoring plan reviewed for the general facility permit
application was developed in response to a December 1985 modification to the
general operation permit (No. 3404) [Appendix A] and is based on the
monitoring procedures used for the program conducted under the consent
orders issued by EPA Region II in February 1985. The modification to the
general operation permit required development of an expanded site-wide
monitoring program for ground water. A program plan, titled "Expanded
Groundwater Monitoring Program" was submitted in March 1986.
In November 1984, Section 3004 of RCRA was amended so that subsequently issued
permits would require "corrective actions for all releases.from any solid waste
management unit, regardless of the time waste was placed in the unit."
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In May 1986, the Part B application for the general facility permit was
revised and reformatted to comply with Part 373 of the State regulations. The
plan submitted in the application was unacceptable. Rather than revise the
plan immediately, CECOS and NYSDEC personnel decided to first develop an
acceptable expanded ground-water monitoring program since it would become
effective long before the permit was issued. Once approved, the expanded
monitoring plan would then be used as a basis for revising the permit
application, thus, the expanded monitoring plan is considered by CECOS and
NYSDEC personnel to supercede the plan submitted in the permit application.
At the time of the Task Force inspection, the expanded monitoring plan was
under review by NYSDEC and had not been approved.
Several parts of the expanded monitoring program plan need to be
improved, including sampling and analysis procedures and chain-of-custody.
The procedures described for decontamination of the water level probe after
each use are inadequate. The probe and the entire length of cable entering the
well need to be decontaminated, instead of only the last several feet of cable. In
addition, the probe should be protected from sources of contamination after
cleaning and during transport.
The plan does not include a procedure for determining purge volumes. A
procedure is included for measuring water levels, but the means and frequency
of measuring the total depth of the well is not included. The plan needs to
include a method to determine the volume of water in the casing and the
associated volume to be purged prior to sampling. The plan requires that care
be taken to avoid contamination of bailers, pumps and samples; however,
procedures are not included.
Analytical methods used by the laboratory need to be specifically
identified. The referenced documents listed in the plan have multiple methods
listed for analysis of several of the sampled parameters. Each method has
different detection limits and/or interferences, therefore, a specific method
should be listed to ensure that the same procedures are used each time so that
results can be compared.
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Filtering equipment is listed in the plans; however, the aliquots to be
filtered are not listed. During the inspection, none of the aliquots collected were
filtered in the field by Recra. The plan needs to be modified to reflect actual
procedures.
Chain-of-custody procedures need to be described in more detail. The
chain-of-custody form referenced in the text is not included in the plan.
SCRF 6 PERMIT APPLICATION PLAN
The ground-water monitoring plan reviewed for the SCRF 6 permit was
presented in a May 15, 1986 revision to the application. The plan was being
revised during the Task Force inspection to reflect new monitoring well
locations. The changes were necessary because the design of the proposed
landfill was modified, which shifted the point of compliance location.
Because of the 1984 amendments to RCRA (and corresponding
legislation passed by the State) regarding corrective actions for all releases
from any solid waste management units (SWMUs), the SCRF 6 application was
supplemented with an SWMU report and corrective action plan in July 1986.
The report was being revised during the Task Force inspection. Consequently,
only the monitoring program for SCRF 6 was evaluated.
The monitoring program proposed for the SCRF 6 permit application has
the same deficiencies in the sample collection and analysis procedures as cited
in the discussion of the expanded ground-water monitoring program; with the
exception that the chain-of-custody form is attached as referenced.
In addition, the proposed monitoring program is inconsistent in the
identification of the uppermost aquifer. Attachment II of the proposed plan
identifies the "top-of-rock" formation as the uppermost aquifer where Attachment
I and all other contractor documents, identify the uppermost aquifer as three
transmissive zones (top-of-clay, top-of-rock and bedrock). An explanation
should be provided as to why there are no proposed monitoring wells for the
top-of-clay zone.
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CECOS SAMPLE COLLECTION AND HANDLING PROCEDURES
As previously discussed, the general operating permit (No. 3404)
modification requires CECOS to follow the MMCP for ground-water sampling
and analysis until the expanded ground-water monitoring program is approved.
Although the permit expired in July 1986, State regulations require CECOS to
comply with the permit conditions until a new permit is issued.
As a result of the consent order (RCRA Section 3013 order) issued by
EPA, CECOS developed a monitoring program for determining if wastes have
been released from SCMFs 1, 2 and 3. During the Task Force inspection,
CECOS personnel reported that samples required by the MMCP were collected
using the procedures presented in the plan developed for the consent order. In
general, procedures in the plan developed pursuant to the consent order
supplement those in the MMCP and are a "de facto" addendum to it. In October
1986, the program plan for the consent orders comprised three documents:
Two documents, one titled "Required Modifications for the Plan
Entitled Initial Monitoring Network for Existing Wells," submitted by
CECOS on August 2, 1985 and a supplemental letter dated
October 17, 1985 from K.C. Malinowski of CECOS to Conrad
Simon of EPA regarding the construction of bailers and the start-
up date for the program.
Document titled "3013 and 3008 Order on Consent Investigation
Safety Manual" undated.
During the Task Force inspection, CECOS contractor (Recra) personnel
were evaluated regarding their sampling techniques and whether they were
following procedures described in the MMCP and plan developed for the
consent order. Samples were collected from 16 monitoring wells and water
levels were measured in 47 wells, as discussed in the Investigation Methods
section. At each of the wells sampled, Recra personnel measured the water
level, calculated the purge volume, purged stagnant water, collected and
preserved samples, made field measurements for pH, Eh specific conductance
and temperature and completed a chain-of-custody form. Observation of these
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procedures revealed that some are inadequate and that the plan in many
instances is not being followed.
The procedures described in the plans are acceptable; however, Recra
personnel did not exercise adequate care in making some of the field
measurements and minimizing the potential for cross-contamination of samples.
For example, a clean sheet of plastic was placed on the ground by the
contractor around each well so as to have a clean surface to lay equipment on
and handle samples. Then, no care was taken to keep the plastic clean.
Contractor personnel walked on the plastic with muddy boots and spilled water
from the bailers on it when purging and filling sample containers. The water
spilled during bailing (about half of the total at some wells) was not accounted
for in calculating the volume actually purged. The bailers and/or wire were
often dropped on the muddy, wet plastic and then were not cleaned prior to
continued use. The contractor did not always change gloves between wells or
after handling a dirty bailer, which can also be a source of cross-contamination.
Furthermore, Recra personnel were not following the safety plan, listed
above, while sampling the wells. The plan specifies that a full-face respirator is
to be worn at all times when near an open wellhead. Recra personnel wore
half-face respirators, if a respirator was worn at all.
Water Level Measurements
Water level measurements are taken at each well, to determine the
volume of water in the well casing for calculating purge volumes. The well
covers were unlocked and removed by Recra personnel. An electronic water
level indicator (Slope Indicator Model No. 51453) was used to measure the
depth to water from the top of casing. This indicator consists of a reel with a
control panel, cable and sensor. A two-conductor cable, which is marked in
sequential 1-foot increments, connects the control panel to the sensor. When
the sensor makes contact with the water, an indicator light and buzzer on the
control panel are activated.
The cord and sensor were lowered into the open casing until the sensor
reached water. The probe is raised and lowered in the well until the exact point
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of contact is determined. The cable, at the top of the casing, is pinched by the
sampler's fingers and the distance from the bottom of his fingers to the next
lower cable marker is measured with a ruler then the distance is added to the
cable marker value to determine the depth to water. Following this
measurement, the well is supposed to be sounded to determine the total depth
for calculation to the water column volume. Field personnel are supplied with
prepared tables for computation of the purge volume. The tables list water
column volumes for various water column heights and well radii. The probe is
then removed and the last several feet of cable and the probe are washed with
a 10% soap (Liquinox) solution and deionized water, then brushed and rinsed
three times with deionized water.
Although the method of making water level measurements is generally
adequate, the precision achieved by the sampling contractor was inadequate.
Duplicate water level measurements were made at 15 wells and the results
varied by as much as 0.26 feet [Table 8]. This variability appeared to be due to
the contractor's fingers slipping or mismarking the location of the top of casing
on the cable.
During the first day of water level measurements, the contractor was not
decontaminating the cable, as specified in the plan; only the probe was being
rinsed with the Liquinox solution and deionized water. Following discussions
with CECOS personnel, Recra began cleaning the last several feet of cable.
The procedures were inadequate, however, as evidenced by particles that were
often visible on the probe following cleaning. Furthermore, the entire length of
cable entering the well needs to be cleaned and the reel should be protected
when being transported.
The water level indicator was prone to false contacts. Several times
when good contact with the water surface had apparently been made,
rechecking revealed a depth to water up to 15 feet deeper than the initial
reading. In addition, the distance between the water level markers imbedded in
the insulated cable need to be periodically checked.
Recra personnel were not following the plan, because they did not sound
the wells to determine the total depth following each water level measurement.
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Construction details and previous soundings were used to determine the water
column volume for purging purposes. A number of the wells had dedicated
PVC and/or stainless steel bailers suspended in them; several were partially
immersed in the well water. The plan, however, specifies that the bailers are to
be suspended above the water level.
Purging
For purging, the plan specifies either evacuation to dryness and
recharge, or removal of three well volumes depending on well characteristics,
prior to sampling. If the well can be evacuated to dryness and recharges
rapidly, water is removed as it recharges until three volumes are removed. If the
well can be evacuated to dryness and is slow to recharge, it is sampled upon
"complete" recharge (when 90% of initial water level has been achieved, the
well is considered to be completely recharged for sampling purposes). All other
wells are purged of three well volumes and sampled.
The plan specifies use of an ISCO pump (Model 1580) for purging wells
where the water level can be maintained at 25 feet or less during pumping;
otherwise, a dedicated bailer made of the same material as the well casing, is
specified for purging.
Prior to initial use, the bailers (stainless steel) and cable (stainless steel)
are cleaned thoroughly with Liquinox and water. Following the Liquinox
solution, the bailer is rinsed three to four times with deionized water and, on the
last rinse, the specific conductivity of the rinse water is compared to deionized
water. Purge water is collected in a tank and disposed of at the wastewater
treatment plant onsite.
The plan is not strictly followed when decontaminating the bailers prior to
use. The bailers are cleaned with a nylon bristle brush, as specified in the plan;
however, the brush does not extend the full length of the bailers and cannot
completely clean them. The brush, which is used for all the bailers, is not
cleaned nor protected from other sources of contamination between uses.
Furthermore, the brush was also allowed to rest against the dirty truck or was
placed back in the truck following use.
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87
The bailer wire was not decontaminated prior to use and on occasion,
when new wire was used, the wire was removed from a large reel that rode in
the dirty truck. The wire, which appeared to have been coated with an oil, was
never cleaned before use. On one occasion the wire used for one well was
placed back in a bag marked with a different well number; therefore, the wire
may have been used on another well. Finally, the wire often cut deeply into the
casing collar, sending metal shavings into the well.
Sample Collection and Preservation
After purging, the contractor remeasures the water level in each well to
determine if the well has recharged sufficiently for sample collection. Following
recharge, a sample aliquot is collected for measuring field parameters including
pH, Eh, conductivity and temperature.
The pH and Eh are measured with an Orion model 201 Digital meter. For
pH measurements, the meter is standardized using a pH 7.00 buffer and then
calibrated with either 10.00 or 4.00 buffer solutions depending on the expected
range for the well. The buffer solutions are to be sealed and kept out of direct
sunlight when not in use. Redox potential (Eh) is measured with an Eh probe
using the millivolt scale of the meter. Conductivity and temperature are to be
measured using a temperature compensated Extech compact conductivity
meter. The conductivity meter is to be calibrated once a day at the lab and in
the field. The contractor reported that the meter had been calibrated in the lab;
calibration was also observed in the field.
Field personnel keep a bound field notebook and record activities
including water levels, pH, Eh, conductivity, temperature, calibrations and
chain-of-custody numbers with a waterproof permanent marker as specified in
the plan.
Samples were collected using only precleaned dedicated bailers.
According to the plan, samples are to be placed in precleaned bottles that have
been rinsed with sample. Volatile organic vials are detergent washed, rinsed
and dried then sodium thiosulfate is added to each vial. Sample bottles are
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88
labeled with the following information: sample identification, project
identification, date and sampler's initials. The labels are covered with
waterproof clear tape. The plan was followed except the bottles were not rinsed
with sample before use.
Following collection of samples, the bailer is suspended in the well for
use in future sampling. Samples are preserved in the field. Samples are to be
kept on ice in coolers for transport to the laboratory. During no point of the
sampling are sample containers to come in contact with surrounding soils or
items which could introduce the possibility of contamination.
Blank samples are to be prepared for each set of sample collections.
Two types of blanks, trip and field blanks (as defined by CECOS) are prepared
in the field and transported to the laboratory for analysis. Trip blanks consist of
deionized water poured directly into a set of sample containers and preserved
as normal samples. Field blanks are prepared by running deionized water
through a piece of sampling equipment and then into appropriate sample
containers.
The procedures outlined in the sampling protocol are adequate to ensure
collection of representative ground-water samples. The procedures were not
adhered to, however, in several areas. Several of the sample containers were
not labeled, as specified in the plan, and sampling personnel were not sure
what analyses would be conducted on a second, non-preserved metals sample.
CECOS contractor personnel were given trip blanks prepared by the EPA
contractor; however, they prepared no blanks of their own during the 2-week
investigation. Instead, Recra collected two duplicate sets of samples during the
inspection for laboratory quality control. Recra personnel only occasionally
stored finished samples in coolers. Samples were transported around the site
in buckets and boxes in the back of the truck. Samples were not iced during the
day, as specified in the plan.
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89
Chain-of-Custodv
Sample containers are sealed with a chain-of-custody tape placed over
the sample cap. Field personnel are to initiate a sample custody sheet and
insure its proper transfer to laboratory staff. Custody procedures are referenced
to be based on NEIC policies and procedures (EPA-330/9-78-001-12). The
chain-of-custody procedures are adequate and are being followed by Recra.
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90
EVALUATION OF MONITORING DATA FOR INDICATIONS OF WASTE
RELEASE
This section presents an analysis of Task Force and Company
monitoring data regarding indications of waste releases to ground water from
SCMFs 4 and 5. Field and laboratory analytical results from samples collected
by Task Force personnel are presented in Appendix C, together with the
analytical methods.
Interpretation of Task Force and Company data for indications of waste
release was complicated by apparent impacts of several past site activities (see
Facility Operations and Waste Management Units). Reports on these activities
and the construction of SCMFs 4 and 5 were reviewed in conjunction with the
evaluation of ground-water data. After identifying probable effects of these
activities on ground-water quality, ground-water and leachate data were
compared to identify any common constituents.
The evaluation was focused on data from 10 wells near SCMF 4 and
6 wells near SCMF 5, which were sampled during the Task Force Inspection.
Most of the wells sampled were new or had been installed in the past two years.
Consequently, monitoring data were limited. Data from older wells were
inconclusive regarding releases from SCMFs 4 and 5. Task Force samples
from well 416, adjacent to SCMF 4, and well 307, adjacent to SCMF 5,
contained substantial concentrations of hazardous waste constituents. In
addition, three other wells (165, 169 and 413) adjacent to SCMF 4 and one
other well (313) adjacent to SCMF 5 contained trace levels of hazardous waste
constituents. These findings are further discussed in the following sections.
SCMF 4
Task Force and Company monitoring data strongly suggest that ground-
water quality near SCMF 4 has been affected by past site activities and/or
materials used in constructing the landfill. These activities could have caused
or contributed to the high pH and specific conductance values, the elevated
metals, ammonia and chloride concentrations and the benzoic acid detected in
ground-water samples collected by the Task Force.
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91
The adjacent area west of SCMF 4 was used for lime and industrial
process slag waste (composition unknown); the exterior structural berms of the
landfill were constructed of these materials. These materials could affect the pH
and metals concentrations in the ground water.
To the southwest, in the approximate area of SCMF 5, ammonium
chloride was sprayed on the ground between 1977 and 1979 at the rate of
about 30,000 gallons per month. Potentially affected ground water could have
moved toward the SCMF 4 area when a clay pit on the north side was being
dewatered during the early 1980s.4 ln addition, ammonia could have mobilized
metals in the soil by forming complexes.
Acid (HCI) neutralization ponds, which leaked into the bedrock by
design, were located northwest (hydraulically upgradient) of SCMF 4.
Dewatering of the clay pit would probably have accelerated movement of
contaminated ground water from the acid ponds toward SCMF 4. According to
the SPDES permit application (for the discharge to ground water), the waste
acid may have contained arsenic, chromium, chloro-toluenes, benzoic acid and
benzyl chloride.
Leachate samples from SCMF 4 are routinely collected and analyzed for
priority pollutants. One data set from each of 4 years (1982 through 1985) was
reviewed to identify major constituents [Appendix C, Table 1]. The major
constituents (in order of decreasing concentration) were total phenolics,
methylene chloride, phenol, toluene, total cyanide and trichloroethylene.
Task Force data for well 416 indicate the presence of compounds that
are also present in the leachate data [Table 11]. The major organic constituents
quantified in the well sample are phenol, 2-methylphenol, 4-methylphenol, 2,4-
dimethylphenol (i.e., phenolic compounds). Napthalene was also detected in
both leachate and well 416 samples. The presence of these compounds in the
well 416 sample may indicate a waste release from SCMF 4.
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92
Table 11
COMPARISON OF DATA FROM MONITORING WELLS TO SCMF 4 LEACHATE
Samolina Station
Parameter
Total phenolics
4 Methylphenol
2 Methylphenol
Phenol
2 Methylnapthalene
Napthalene
2,4 Dimethylphenol
Phenanthrene
Acetone
Benzole acid
Methylene chloride
Benzyl alcohol
2,4,5 Trichlorophenol
Benzene
Ammonia
Well
416
940
590
530
260
190
11
13
7.5
30
520
Well
165
21
100
7.4
7.4
2.6
1.4
9100
Well
169
15
8.6
17
72
3
2.4
23000
Well
413
6.5
1.9
21
84
13
6.2
15000
SCMF 4
Leachate
2600-254000**
230-92000
49-420
110-1400
5300-150000
All concentrations are expressed in micrograms per liter.
The range presented represents parameter values fore all standpipes and samples where
the concentration of the compounds were measured.
Three other wells (165, 169 and 413) adjacent to SCMF 4 contain trace
levels of hazardous waste constituents [Table 11], based on the "fingerprint"
compounds detected in the sample from well 416. Samples from wells 169 and
413 contained low levels of phenol, 2-methylphenol and 4-methylphenol. The
sample from well 165 contained low levels of phenol, 2,4,5-trichlorophenol and
benzene, which was also reported for well 413 and the leachate.
Samples from the three wells contained acetone and ammonia at
concentrations substantially above those in other wells near SCMF 4. No
potential source of the acetone was apparent. Acetone, a common laboratory-
induced contaminant, had not been previously reported in leachate or
monitoring well data collected by the Company and others, nor had it been
reported in any of the nearby waste management units. About 10 micrograms
per liter (ug/L) of acetone was measured in one of the method blanks analyzed
with the Task Force samples. The concentration was subtracted from the
-------
93
reported data. The ammonia is probably related to the ammonium chloride
disposal, as explained in the following discussion on SCMF 5.
SCMF5
Task Force and company data also strongly suggest that ground-water
quality near SCMF 5 has been affected by past site activities and/or materials
used in constructing the unit. The effects are the same as those noted for
SCMF 4.
The area of SCMF 5 was used for disposal of ammonium chloride, as
previously mentioned. In addition, releases from three adjacent areas and the
acid neutralization ponds (discussed above) may have affected ground-water
quality. The area north of SCMF 5 (hydraulically upgradient) was used for
disposal of lime and industrial process slag. The dry lime neutralization area,
where spent nitric, sulfuric and hydrochloric acids were treated, is on the west
side of SCMF 5. A portion of the landfill may have been constructed on this
area. Intermediate landfill cell C is adjacent to the southwestern berm of
SCMF 5. It was used for industrial and municipal sludges, which contained
metals and may have contained organics.
Waste disposal in SCMF 5 began in late 1984, consequently, analytical
data for leachate is limited. Priority pollutant organics data for a leachate
sample taken in May 1985 was reviewed [Appendix D, Table 2]. The major
constituents (in order of decreasing concentration) were total phenolics, phenol,
methylene chloride, chloroform, 1,1,1-trichloroethane, isophorone, toluene and
trichloroethylene.
Task Force data for well 307 indicates the presence of compounds that
are also present in the leachate [Table 12]. The major organic constituents
common to the leachate are phenol, 4-methylphenol, 2,4-dimethylphenol, 2-
methylphenol and methylene chloride. These compounds, minus 2-
methylphenol were also detected in well 313. Benzene was detected in both
the leachate and well 313. The presence of the phenolic compounds (and
others) in these wells may indicate a waste release from SCMF 5.
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94
Table 12
COMPARISON OF DATA FROM MONITORING WELLS 307
AND 313 TO SCMF 5 LEACHATE*
Samolina Station
Parameter
Acetone
Total phenolics
Phenol
Benzole acid
4 Methylphenol
4 Methyl-2-
pentanone
Methylene chloride
Benzyl alcohol
2,4-Dimethylphenol
2-Methylphenol
Cyanide
Benzene
Well
307
20000
15000
3000
940
720
590
470
140
64
60
21
Well
313
24
47
78
4.6
2.3
2.4
520
1.1
Standpipe
35-1,3,4
45000
28000
26000
6
110
230
Standpipe
S5-5
65000
21000
1900
7.7
BDL"
All concentrations are expressed as micrograms per liter.
BDL means the compound was identified below the detection limit.
Four of the six wells (307, 310, 313 and 315) sampled near SCMF 5
contained acetone and have elevated ammonia concentrations. In well 307,
the acetone concentration was very high (20,000 ug/L) yet none was reported in
the leachate. Again, no potential source is apparent.
Because ammonium chloride was disposed of on the area occupied by
SCMF 5, ammonia and chloride data from the wells were examined and
compared. No discernible pattern in chloride concentrations was apparent;
however, ammonia concentrations appeared to be elevated in the following
eight wells, where concentrations ranged from 9.1 to 525 milligrams per liter:
-------
95
SCMF 4 Wells
165
169
413
SCMF 5 Wells
307
310
313
315
325
-------
REFERENCES
1. Golder Associates report to Niagara River Steering Committee, Ontario
Ministry of the Environment "Hydrogeologic Assessment of the CECOS-
Necco Park Waste Disposal Facilities, Niagara Falls, New York,
December 1985, pp. 26-41
2. Recra Research, Inc.,"Secure Chemical Residue Facility Site
Characterization Report", April 1985, pp. 66-92.
3. R. F. Weston Consultants, July 25, 1978. "Hydrogeologic Investigation of
the Newco-Niagara Recycling Site, Niagara Falls, New York", Roy F.
Weston Consultants, West Chester, Pa., Figures 3 through 12.
4. Wehran Engineering, April 24, 1981. "Supplemental Hydrogeologic
Study of the Packard Road/Pine Avenue Site in Connection with
NYSDEC Applications for SCMF Numbers 4 and 5, CECOS
International, Inc. Niagara Falls, New York", Wehran Engineering,
Middletown, New York, pp. 10-12 and sheets 3 and 5.
5. Wehran Engineering, August 1981. "Hydrogeologic-Geotechnical
Investigation, Proposed Sanitary Landfill Facilities Newco Waste
Systems, Inc., Pine Avenue Site, Niagara Falls, New York", Wehran
Engineering, Middletown, New York, page 32 and sheet 5.
-------
APPENDICES
A MODIFICATION TO STATE OPERATION PERMIT NO. 3404
B MMCP WELL LOCATIONS AT PHASE I AND II WASTEWATER
TREATMENT FACILITY
C ANALYTICAL TECHNIQUES AND RESULTS FOR TASK FORCE
D LEACHATE MONITORING DATA FOR SCMFs 4 AND 5
-------
-------
APPENDIX A
MODIFICATION TO STATE OPERATION PERMIT NO. 3404
-------
New York State Department of Environmental Conservation
Centennial
Division of Regulatory Affairs - Region Q
600 Delaware Avenue, Buffalo, New York 1-2Q2-1071
,, ^ / o -.--, '^enrvG Williams
/ ifa/ 0-4 i -H J Oi Commissioner
November
8
M.r. Norman J. Goutant. Jr.
New York District Manager
CECOS International, Inc.
2321 Kenmore Avenue
Buffalo, New York 1A2G7
Dear Mr. Ccutar.t:
Notice of Intent to Mod ifv
Amendment, Pemit to Operate 3AO-
This Department cives notice that effective on Decemoer 1. 19S5,
Special Condition 32 cf the accve perr.it is modified to reauire the
ceveioomer.t of an exoanded, site-vice mom coring program for groundwater
3otr. requirement1
x^ j^^ accordance with A c n ^ ฐ d i x - attacnec
to consistently extend improved monitoring
3008 and 3013 thrcucncut the entire site. Althouun I understand tr.a;
natter was discussea with vour firr., within 10 caienaar days of the receipt
cf this letter, vou ~av submit to .".-.is orfice a written stater.ent or a
recuest for nearinc ;ivir.~ reasons wnv t.~e Territ snould rot be ~oci:i^d
The Permittee snail b.ave and ~.aintain a ".or 11 r rir.c, , Maintenance
and Continpencv Plan 'V?',C?'1 chat addresses all of the facilities
listed in soecial condition A. The "_MCP shall contain Dcth -re-
closure and post-closure moni tor inc and maintenance ^rocrcm.s .
and continpencv plans. The monitoring programs snail include
previsions for de ter-'inir.s surface water qualitv, crcundwa tcr
cuaiitv and flow direction, air runlitv, licuid levels in
surface im.poundments and tanks, leacr.ate levels, and leacnate
qualitv and snail be of sufficient detail to demonstrate comnliar.ee
with water anc air c/ualitv criteria, desmn. standards, and -icciican
permit conditions. T;-.e monitoring programs shall also include
sampling schedules, a description of samole collection and
preservation techniques, a listing of anaivticai parameters to
be tested for, and a description of analytical testing procedures.
-------
Mr. Norman J. Coutant, Jr.
November 1^, 1985
Page 2
The Permittee shall both develop the expanded site-wide monitoring
program for groundwater and comply with the other P^IOGIC
reporting retirements of the attached Appendix I. The maintenance
programs shall include inspection and repair ot all berm side
slopes and landfill cover erosion and settling, care of cover-
vegetation, leachate withdrawal and treatment, inspection and
repair of surface drainage swales and appurtenances, and inspection
and repair of all tanics , surface impoundments, and storage areas.
The contingency plans shall include provisions for site remediation
for escaped wastes below, on, or above the site that the monitoring
programs mav reveal and shall also include plans of action for
unexpected occurrences such as fires cr explosions. As new
facilities are constructed, or as existing facilities are modified.
the MMCP shall be modified and upaatec accordingly.
If vou have anv questions concerning procedural matters relating to
s'pecific requirements of this modification. Thank you.
P.espect fully ,
/ ' ^
- " >i/-
Paul D. Eismann
Alternate Permit Administrato
PDE/lad
Enc.
cc: E. Belmore (3)
p . Counterman
J. Kenoe
L. Stiller
C. Ricnards
H. Albor.d
P. Tarnawsky]
-------
APPENDIX I
1. On or before June 1, 1986, CECOS shall submit to DEC for review and
approval a report and site plan which identifies all known past and
present solid waste management units or areas at the site, and provide
a brief history of the operation and design of those units or areas.
The report shall distinguish between RCRA Regulated Units and other
Solid Waste Management Units (SWMU's). The report shall also identifv
any areas which due to known ^piils or leaks may contain soil or
groundwater contamination. It shall include proposed plans to evaluate
the impacts, if any, tnat tne SVMUs and spills or leaks have had or
are having on groundwater cualitv at the site, and a preiiminarv
schedule for implementing tne evaluations.
30 davs of receiving written notice from DEC, CECOS shall:
a. In the case of disapproval, modify the report to address anv
deficiencies specified by DEC and suomit the revised report to
DEC for review and written approval; and/or
b. In the case of approval, bemn to implement tne plan accordine
to the approved scnedule.
Witr.in 30 .avs
approved plan,
in writing to DEC. The report snail include, if deemed
necessarv, recommendations for future grounawater monitoring
and corrective actions.
before March 1, 19^o, CECOS shall suo~it :j DEC for approval a
crMC- i _ t
o ^>. .. i_ j
Intermediate Landfill, Ceils A, 3, and C
Sanitarv Dane fills 1-3 ana
Phase 1 Treatment Impoundments
Phase - Treatment Complex
CECOS must 'ustifv tnat their proposed well network is composed of a
surficent num.oer OE wells so as to provide immediate Detection of
significant increases in monitored constituents in tr-.e grounawa ter .it
each, of the units listed a;
to pe incorporated *n the -rogram.
-------
-2-
Feacures such as well diameter, installation date, screen and casing
type, filter pack and annular seal construction details, and methods
used to connect segments of the well casing and screens will be
evaluated. Furthermore, the existing well evaluation plan shall
include a schedule for field verification that all existing
groundwater wells to be incorporated in the site-wide monitoring
plan are stracigraphicaily in the formation depicted on the well
logs, and that all well screens are properly located.
c. A schedule under which CECOS will install new groundwater monitoring
wells for incorporation in the new site-wide groundwater monitoring
plan. As part of the scnedule, a plan will be developed that
includes well construction specifications and details.
d. A data acquisition plan vnich will be used to establish indicator
parameters and statistical methods for 'jse in a detection monitorir.c
svstem. In the plan, CECUS must provide a detailed discussion of
the program's seals and implementation. The plan must also specifv
and provide justification for selection of che following:
(10 Parameters to be ar.aivzed;
(20 Sampx-p.,; protocol;
(30 Methods for tne preparation and maintenance of sample containers
(^.) Means for defining and separating multi-phase samples;
(50 Methods for sample preservation;
Preparation and use of field blan.KS ;
ccedutes for maintaining samoie control and chain of custody;
(i , iamo_ir.g J.ocations;
(9.) Same ling frequencv;
(1C.'; Freliminarv statistical tests for vr.ioh the cata acquisition proc-.
is designed;
(liJ Length of the cata acquisition program
Witr.in 30 aavs or receiving written notice from DEC, CECOS snail:
(1) In tne .-ase of disapproval, modify tne Program to address anv
der: cic-ncies specified by DEC and submit the revised Program
to ^]~.C for review and written approval; and/or
(2) Begin to implement tne program upon approval.
-------
e. Within 30 davs after receiving the analytical results of the last
sampling event specified in the data acquisition program, CECOS shall
submit to DEC for review and approval a sampling and anaivsis plan
for long-term groundwater monitoring at the site. That plan shall
specify the wells wnich will comprise the site-wide monitoring
network, the indicator parameters which will be used for detection
monitoring, the freauenc/ of groundwater sampling, the statistical
metnods which will be ennloved to evaluate tne sample results, and
a plan which will be followed in the event tnat statistically
significant increases in the concentrations of the indicator
parameters are detected.
Within 30 davs of receiving written notice from DEC, CECOS shall:
(1) In the case or disapproval, mod if'/ the Proa ram to address
anv deficiencies specified ov DEC and submit the revised
Program to DEC f.jr review and written approval; ana/or
(2) 5egin to implement tne program upon approval.
f. Once tne accepted plans, required herein, have been implemented
anc certified as nece=sar' , ;ne plan snail be deemed operational.
The corresponding monitoring programs whicn are <. urrer.tiv bei;v_;
followed unoer tr.e ei'.istin^ p'.-TCR.R Part 373 Permit sha^l cease
to pe in force at =u>_n time as tne require plan is deemed operational.
3. On a triennial pasis, CECDS -nail perform, an evaluation of tne ac.ecua.cv
of grouncvater monitor me veils that are inciud.-d in tne new sitc--wice
monitoring program and icentif" wells tnat need replacement or repair.
The evaluation snail pe cert~f:ec b^ a professional engineer or qualified
b. '. isua^ inspection. or each veil to determine
c. Throu^n a trend anal vs is of anaivticai data ana using ether
mechanisms as necessary, deter .me i: each grouncA.a ter monitoring
well is functioning in accordance w 1 1 r its o r i z i n a 1 1 y certified
purpose of collecting representative samples o: grouncvater.
CECOS must receive approval -1 C the Department peiore ohv^icallv removing
anc sealing an'.' grouncvater monitoring well at tr.e
On an annual basis, CECOS snail prepare a report Comparing the leachate
sampling b.istcrv of each or trie landfills (excluding the sanitary
landfills) listed in Item 2 o, f this appendix. to the water table
elevations in the vicinitv of eacn lancfill. These ccmnarisons should
be made witr.in the context of each landfill's design, including at the
least the cap, surficiai drainage svstem, liner, and leachate collection
system design and operation.
-------
APPENDIX B
MMCP WELL LOCATONS AT PHASE I AND II
WASTEWATER TREATMENT FACILITIES
-------
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-------
W3MOd XMVHOW VbVDVIN
-------
APPENDIX C
ANALYTICAL TECHNIQUES AND RESULTS FOR TASK FORCE SAMPLES
-------
prc
PRC Engineering
5u'e cCO
303 East Wacker Drive
Cn.cago il 60601
312 938-0300
~/VX 3-0-2215112
~aoie CONTOWENG
Planning Research Corporation
EVALUATION OF QUALITY CONTROL ATTENDANT
TO THE ANALYSIS OF SAMPLES FROM THE
CECOS, NEW YORK FACILITY
FINAL MEMORANDUM
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Waste Programs Enforcement
Washington, D.C. 20460
Work Assignment No.
EPA Region
Site No.
Date Prepared
Contract No.
PRC No.
Prepared By
Telephone No.
EPA Primary Contacts
Telephone No.
549
Headquarters
N/A
January 21, 1987
68-01-7037
15-5490-15
PRC Environmental
Management, Inc.
(Ken Partymiller)
(713) 292-7568
Anthony Montrone/
Barbara Elkus
(202) 382-7912
-------
MEMORANDUM
DATE: January 20, 1986
SUBJECT: Evaluation of Quality Control Attendant to the Analysis of Samples
from the CECOS, New York Facility
FROM: Ken Partymiller, Chemist
PRC Environmental Management
THRU: Paul H. Friedman, Chemist*
Studies and Methods Branch (WH-562B)
TO: HWGWTF: Tony Montrone*
Gareth Pearson (EPA 8231)*
Richard Steimle*
Ed Berg (EPA 8214)*
Steve Sisk, NEIC
Fred Haber, Region II
Paul Ingrasano, Region II
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, New York sampling effort by the Hazardous Waste Ground-
Water Task Force.
The objective of this evaluation is to give users of the analytical data a
more precise understanding of the limitations of the data as well as their
appropriate use. A second objective is to identify weaknesses in the data
generation process for correction. This correction may act on future analyses
at this or other sites.
The evaluation was carried out on information provided in the accompanying
quality control reports (2-3) which contain raw data, statistically transformed
data, and graphically transformed data.
The evaluation process consisted of three steps. Step one consisted of
generation of a package which presents the results of quality control
HWGWTF Data Evaluation Committee Member
-------
procedures, including the generation of data quality indicators, synopses of
statistical indicators, and the results of technical qualifier inspections. A
report on the results of the performance evaluation standards analyzed by the
laboratory was also generated. Step two was an independent examination of the
quality control package and the performance evaluation sample results by
members of the Data Evaluation Committee. This was followed by a meeting
(teleconference) of the Data Evaluation Committee to discuss the foregoing data
and data presentations. These discussions were to come to a consensus, if
possible, concerning the appropriate use of the data within the context of the
HWGWTF objectives. The discussions were also to detect and discuss specific or
general inadequacies of the data and to determine if these are correctable or
inherent in the analytical process.
Preface
The data user should review the pertinent materials contained in the
accompanying reports (2-3). Questions generated in the interpretation of these
data relative to sampling and analysis should be referred to Rich Steimle of
the Hazardous Waste Ground-Water Task Force.
I. Site Overview
The CECOS, New York facility is a large commercial hazardous waste
facility located in Niagara Falls. It is owned by Browning-Ferris Industries,
Inc. No other background information concerning the CECOS, facility was
available to the HWGWTF Data Evaluation Committee teleconference.
Twenty-one field samples including two field blanks (MQA608/Q1308 and
MQA610/Q1310), one trip blank (MQA746/Q1446), and a set of triplicate samples
(well 413, samples MQA611/Q1311, MQA660/Q1260, and MQA664/Q1364) were collected
at this facility. All field samples were low concentration ground-water
samples.
II. Evaluation of Quality Control Data and Analytical Data
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 metal spike recoveries were calculated for twenty-three metals
spiked into two low concentration ground-water samples (MQA464 and 673).
Twenty-two of the twenty-three average spike recoveries were within the data
quality objectives (DQOs) for this Program. The aluminum average spike
recovery was outside DQO with a value of 147 percent. Only two individual
metal spike recoveries from all the samples were outside DQO. One of these two
spikes (for iron) was not used because the concentration of iron in the sample
was greater than four times the concentration of iron in the spike. These
results are listed in Tables 3-1 and 3-2 of Reference 2 as well as in the
following Sections.
-------
All reported laboratory control sample (LCS) recoveries and all
calibration verification standard (CVS) recoveries were within Program DQOs.
All of the average relative percent differences (RPDs) for all duplicate
metal analyses in ground-water samples were within the Program DQOs.
Noncalculable RPDs were reported for 70 percent of the samples. RPDs were not
calculated for the remainder of the metal analytes because many of the
duplicate values used to calculate the RPDs were less than the CRDL.
Required analyses were performed on all metals samples submitted to the
laboratory.
No metal contamination was reported in the laboratory blanks.
1.3 Furnace Metals
The graphite furnace metals (antimony, arsenic, cadmium, lead, selenium,
and thallium) quality control was generally acceptable.
Duplicate injection precision for selenium was poor for both sample and
spiked sample MQA671. Selenium results for this sample should not be used.
All other selenium results should be considered quantitative.
The correlation coefficients for the method of standard addition (MSA)
analysis of lead in samples MQA464, 622, 661, and 664 were outside of DQO.
Lead results for these four samples should be considered qualitative. The
laboratory duplicate result for lead in sample MQA464 was outside the DQO for
precision. All lead results, with the exceptions of the four previously
mentioned samples, should be considered to be semi-quantitative due to poor
duplicate precision.
All antimony, arsenic, cadmium, and thallium results should be considered
quantitative.
1.4 ICP Metals
Two of the sampling blanks contained aluminum contamination at
concentrations near the CRDL. Field blank MQA608 contained 190 ug/L of
aluminum and trip blank MQA746 contained 176 ug/L of aluminum. The aluminum
CRDL is 200 ug/L. Due to the aluminum contamination found in these blanks, the
aluminum results for samples MQA462, 662, 665, 666, 669, 675, and 747 should be
considered unreliable.
The low level (twice CRDL) linear range checks for chromium, nickel, and
zinc had poor recoveries. The low level linear range check is an analysis of a
solution with elemental concentrations near the detection limit. The range
check analysis shows the accuracy which can be expected by the method for
results near the detection limits. The accuracy reported for these elements
was not unexpected. The chromium results for samples MQA462, 464, 609, 622,
623, 661, 662, 665, 666, 669, 671, 673, and 675 were affected buy the poor
recovery of the low level linear range check calibration and should be
considered to be biased low. Nickel results in for all samples except MQA608,
610, 623, 666, 669, 675, and 746 should also be considered to be biased low.
-------
Zinc results for samples MQA462, 463, 464, 609, 611, 623, 660, 661, 664, 669,
671, 675, and 747 should be considered to be biased high.
One of two spike recoveries for aluminum in sample MQA464 and the
resulting aluminum average spike recovery were above DQO with values of 185 and
147 percent, respectively. An iron spike recovery for the same sample was not
calculated because the concentration of iron in the sample exceeded the
concentration of iron in the spiked solution by more than four times. Although
these elements are of little environmental concern, their presence may
potentially cause interference with the analysis of other analytes.
The ICP serial dilution results were not within 10 percent of the original
determination for aluminum, chromium, and iron in sample MQA464. Poor serial
dilution results can be an indication of physical interferences in these
analyses. At this facility, the interference was most prevalent in samples
with high dissolved solids. Such interferences usually yield results with a
negative bias and thus a low recovery. Results for aluminum, chromium, and
iron in all samples except MQA608, 610, and 746 were affected and should be
considered semi-quantitative for chromium and iron and qualitative for
aluminum.
All barium, beryllium, calcium, cobalt, copper, magnesium, manganese,
nickel, potassium, silver, sodium, and zinc results should be considered
quantitative. Chromium and iron results for samples MQA608, 610, and 746
should also be considered quantitative. Chromium and iron results, with the
above exceptions, should be considered semi-quantitative. Aluminum results,
with exceptions, should be considered qualitative. Aluminum results for
samples MQA462, 608, 622, 665, 666, 669, 675, 746, and 747 should be considered
unreliable due to sampling blank contamination.
1.5 Mercury
Although the calibration curve generated by the analytical laboratory for
mercury was poor at high concentrations, all results for mercury should be
considered quantitative with an acceptable probability of false negatives.
2.0 Inorganic and Indicator Analvtes
2.1 Performance Evaluation Standard
Inorganic and indicator analyte performance evaluation standards were not
evaluated in conjunction with the samples collected from this facility.
2.2 Inorganic and Indicator Analvte OC Evaluation
The average spike recoveries of all of the inorganic and indicator
analytes, except for sulfate, were within the accuracy DQOs (accuracy DQOs have
not been established for bromide and nitrite nitrogen matrix spikes). The
average sulfate spike recovery was 131 percent. The bromide and nitrite
nitrogen average spike recoveries were each 100 percent. This indicates
acceptable recoveries for all inorganic and indicator analytes with the
possible exception of sulfate.
-------
AH LCS and CVS recoveries reported in the raw data for all inorganic and
indicator analytcs except TOC and total phenols were within Program DQOs.
All calculable average RPDs for all inorganic and indicator analytes were
within Program DQOs. Precision DQOs have not been established for bromide and
nitrite nitrogen. Some RPDs were not calculable because one or both of the
duplicate values were less than the CRDL.
Requested analyses were performed on all samples for the inorganic and
indicator analytes.
No laboratory blank contamination was reported for any inorganic or
indicator analyte. Contamination involving POX, TOC, total phenols, and TOX
was found in two or three 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.
2.3 Inorganic and Indicator Analvte Data
All results for ammonia nitrogen, cyanide, chloride, and sulfate should be
considered quantitative.
The analytical laboratory did not analyze a calibration verification
standard and a calibration blank after a four hour break in the analysis on
11/10/86. Therefore, the nitrate and nitrite nitrogen and bromide results for
samples MQA462, 463, 609, 610, 611, 660, 661, 664, 665, and 669 should be
considered semi-quantitative. All other bromide results should be considered
quantitative. The holding times for the nitrate and nitrite nitrogen
determinations ranged from 13 to 20 days from receipt of samples which is
significantly longer than the recommended 48 hour holding time for unpreserved
samples. Therefore, all nitrate and nitrite nitrogen results should be
considered to be semi-quantitative.
Total phenols contamination was found in one of the two field blanks
(MQA608) and the trip blank (MQA746) at concentrations of 15 and 24 ug/L.
These values are above the total phenol CRDL of 10 ug/L. Based upon HWGWTF
conventions, all total phenols results greater than 10 times the highest
concentration of total phenols contamination in the sampling blanks or less
than the detection limit should be considered quantitative unless there are
other quality control problems. Total phenols results for samples MQA610, 662,
673, and 747 should be considered quantitative. All total phenols results
greater than five but less than ten times the highest concentration of sampling
blank contamination should be considered qualitative and all other data should
be considered unusable. Total phenols results for samples MQA462, 622, 660,
and 664 should be considered qualitative and total phenol results for all other
samples should not be used due to this contamination.
Both field blanks (MQA608 and 610) and the trip blank (MQA746) contained
TOC contamination at concentrations of 1400, 1300, and 1500 ug/L, respectively.
These values are above the TOC CRDL of 1000 ug/L. Again, as a HWGWTF
convention, all TOC results greater that ten times the highest concentration of
field blank contamination or less than the TOC detection limit should be
considered quantitative. All TOC results greater than five but less than ten
times the highest concentration of sampling blank contamination should be
-------
considered qualitative and all other data should be considered unusable. The
TOC results for samples MQA462, 611, 622, 662, 664, and 747 should be
considered quantitative, TOC results for samples MQA665 and 675 should be
considered qualitative, and all other TOC should not be used. The percent
relative standard deviation for the set of field triplicates (MQA611, 660, and
664) showed poor precision with TOC concentrations of 28000, 6200, and 29000
ug/L reported. The comparative precision of the field duplicate results is not
used in the evaluation of sample data as it is not possible to determine the
source of this imprecision. Field duplicate precision is reported for
informational purposes only.
ICV and CCV standards for POC were not analyzed. A POC spike solution was
run in place of these calibration verifications 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. The POC analyses
were performed 7 to 14 days after receipt of the samples. Although the
analytical laboratory was told by the Sample Management Office to use a 14 day
holding time, the EMSL/Las Vegas data reviewers recommend a seven day holding
time. This confusion should be corrected. The POC results should be
considered qualitative.
TOX contamination was found in one of the field blanks (MQA610) at a
concentration of 6.2 ug/L. This value is above the TOX CRDL of 5 ug/L. Based
upon HWGWTF conventions, all TOX results greater than 10 times the highest
concentration of TOX contamination in the sampling blanks or less than the
detection limit should be considered quantitative unless there are other
quality control problems. All TOX results greater than five but less than ten
times the highest concentration of sampling blank contamination should be
considered qualitative and all other data should be considered unusable. High
levels of chloride (greater than 500 ppm) were detected in samples MQA609, 623,
665, 673, and 675. The chloride may have caused positive interferences with
the TOX in these samples. Based upon the blank contamination and the high
chloride levels, TOX results for samples MQA609, 623, 665, 669, and 675 should
be considered qualitative and TOX results for samples MQA463, 464, 610, and 673
should not be used. All other TOX results should be considered quantitative.
The sample holding time until POX analysis was 5 to 12 days from receipt
of samples which, for some samples, exceeded the EMSL/Las Vegas recommended
holding time of seven days. The laboratory has been directed by the Sample
Management Office that a 14 day holding time is adequate. This confusion for
both POC and POX should be clarified with both the inorganic laboratory and
SMO. Field blank MQA608 contained POX contamination at a concentration of 16
ug/L. This value is above the POX CRDL of 5 ug/L. Again, as a HWGWTF
convention, all POX results greater that ten times the highest concentration of
field blank contamination or less than the POX detection limit should be
considered quantitative. All POX results greater than five but less than ten
times the highest concentration of sampling blank contamination should be
considered qualitative and all other data should be considered unusable. The
percent relative standard deviation for the set of field triplicates (MQA611,
660, and 664) showed poor precision with POX concentrations of 2980, 3480, and
6950 ug/L reported. The comparative precision of the field duplicate results
is not used in the evaluation of sample data as it is not possible to determine
the source of this imprecision. Field duplicate precision is reported for
-------
informational purposes only. POX results should be considered quantitative
except for samples MQA608, 610, 623, and 673 which should not be used due to
blank contamination.
3.0 Organics and Pesticides
3.1 Performance Evaluation Standard
Organic analyte performance evaluation standards were not evaluated in
conjunction with the samples collected from this facility.
3.2 Organic OC Evaluation
All matrix spike average recoveries except for trichloroethene (41
percent) were within established Program DQOs for accuracy. Individual matrix
spike recoveries which were outside the accuracy DQO will be discussed in the
appropriate Sections below. All surrogate spike average recoveries were within
DQOs for accuracy. Individual surrogate spike recoveries which were outside
the accuracy DQO will be discussed in the appropriate Sections below.
Eighteen of twenty-two matrix spike/matrix spike duplicate average RPDs
were within Program DQOs for precision. Average and individual matrix spike
RPDs which were outside the precision DQO will be discussed in the appropriate
Sections below. All average surrogate spike RPDs were within DQOs for
precision.
All organic analyses were performed as requested except for samples Q1261
and Q1309. Portions of each of these samples were lost due to sample bottles
which broke during shipment. Both of these samples were analyzed for volatiles
and semivolatiles only.
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 Volatiles
Quality control data indicate that volatile organics were determined
acceptably. The chromatograms appear acceptable. Initial and continuing
calibrations, tunings and mass calibrations, blanks, matrix spikes and matrix
spike duplicates, surrogate spikes, and holding times were all acceptable.
Acetone or methylene chloride were found in method (laboratory) blanks on
three occasions. Methylene chloride was found in two method blanks at
concentrations of approximately one-half of the methylene chloride detection
limit of 5 ug/L. Acetone was found in one method blank at its CRDL of 10 ug/L.
There was judged to be no impact on the data due to this contamination.
Estimated method detection limits were CRDL for all samples except Q1262,
which was 135 times CRDL due to dilution. This sample was diluted 135 times
prior to analysis due to the presence of high amounts (20,000 ug/L) of acetone.
-------
The matrix spike/matrix spike duplicate recovery of trichloroethene was
below DQO in both matrix spike/matrix spike duplicates.
The volatile blanks analyzed on 11/2 and 11/3/86 on instrument 12 and on
10/30/86 on instrument 18 were analyzed before rather than after the continuing
calibration.
The volatiles data are acceptable. The volatile compound results should
be considered quantitative. Low concentration (up to 135 times the CRDL) false
negative results for sample Q1262 should be considered a possibility due to the
raised (because of the 135 fold dilution) detection limits for this sample.
The probability of false negative results for all other samples is acceptable.
3.4 Semivolatiles
Initial and continuing calibrations, tuning and mass calibrations, blanks,
holding times, and chromatography were acceptable for the seraivolatiles. Some
problems were encountered with matrix spike/matrix spike duplicate and
surrogate recoveries.
The RPDs for 1,2,4-trichlorobenzene, acenaphthene, pyrene, N-nitroso-di-n-
propylamine, 1,4-dichlorobenzene, and pentachlorophenol were above DQO limits
in one or two matrix spike/matrix spike duplicate pairs. The recoveries of
acenaphthene, N-nitroso-di-n-propylamine, and pentachlorophenol in matrix spike
sample Q1253 were outside their respective DQO ranges.
Contamination of a dimethyl substituted undecane was detected in one
laboratory method blank at a concentration of 14 ug/L. This was judged by the
EMSL/Las Vegas data reviewers to have no impact on the semivolatile results.
The surrogate percent recoveries for nitrobenzene-DS (26 and 28 percent
recovery) in samples Q1261 and 1263 and 2-fluorophenol (15 and 18 percent) in
samples Q1301 and 1309 were outside their respective DQO ranges. No surrogate
compounds were recovered from sample Q1262 due to a 40 fold dilution of that
sample.
Estimated method detection limits were twice CRDL for all samples except
for sample Q1261 which was 8 times CRDL and sample Q1262 which was 40 times
CRDL, both due to dilution. Sample Q1262 was diluted due to-the presence of
high levels of phenol (3000 ug/L).
The semivolatile analysis, by virtue of the established DQOs, yields
results which arc semi-quantitative. The semivolatile data from this facility
are acceptable and the results should be considered semi-quantitative. The
probability of false negatives is acceptable for all semivolatile samples
except Q1262 for which the probability of false negatives is increased due to
the 40 fold dilution resulting in raised detection limits.
3.5 Pesticides
The initial and continuing calibrations, matrix spike/matrix spike
duplicates, surrogate spikes, holding times, and chromatography for pesticides
were acceptable.
-------
A peak was found on all of the blank chromatograms run on pack 07. This
peak also appeared in all sample chromatograms analyzed on pack 07, had a
retention time of approximately 17.6 minutes. The presence of this non-HSL
contamination should be addressed by the organic laboratory.
The dibutylchlorendate spike recovery was outside DQO limits for samples
Q1262 and 1302.
The analytical instrument detector appeared to be saturated in many of the
sample and blank chromatograms for approximately 3 minutes. Early eluting
pesticides would have been obscured by this large solvent peak.
The laboratory did not use the correct graphical procedure to determine
the peak area of the pesticide compounds. Enclosures 1 through 7 of Reference
3 for organics demonstrate both the procedure used and the correct (tangent
lines) procedure.
The estimated method detection limits for the pesticides fraction were
CRDL for all samples. The positive pesticides results should be considered
qualitative. Probability of false negatives (unrecovered pesticides in the
sample) should be considered acceptable except for compounds which elute in the
first three minute of the pesticide chromatogram. Due to detector saturation,
any chromatographic peaks eluting during these three minutes would be obscured
and false negative results would be possible.
-------
III. Data Usability Summary
4.0 Graphite Furnace Metals
Quantitative:
Semi-quantitative:
Qualitative:
Unusable:
4.1 ICP Metals
Quantitative:
Semi-quantitative:
Qualitative:
Unreliable:
4.2 Mercury
all antimony, arsenic, cadmium, and thallium results;
selenium results with an exception
lead results with exceptions
lead results for samples MQA464, 622, 661, and 664
selenium results for sample MQA671
all barium, beryllium, calcium, cobalt, copper, magnesium,
manganese, nickel, potassium, silver, sodium, and zinc
results; chromium and iron results for samples MQA608, 610,
and 746
chromium and iron results with the above exceptions
aluminum results with the exceptions listed below
aluminum results for samples MQA462, 608, 622, 665, 666,
669, 675, 746, and 747
Quantitative: all mercury results
4.3 Inorganic and Indicator Analvtes
Quantitative:
Semi-quantitative:
Qualitative:
Unusable:
4.4 Organics
Quantitative:
Semi-quantitative:
Qualitative:
all ammonia nitrogen, cyanide, chloride, and sulfate
results; bromide, TOX, and POX results with exceptions
listed below; total phenols results for samples MQA610,
662, 673, and 747; TOC results for samples MQA462, 611,
622, 662, 664, and 747
all nitrate and nitrite nitrogen results; bromide results
for samples MQA462, 463, 609, 610, 611, 660, 661, 664, 665,
and 669
all POC results; total phenols results for samples MQA462,
622, 660, and 664; TOC results for samples MQA665 and 675;
TOX results for samples MQA609, 623, 665, 669, and 675
total phenols and TOC results with the above exceptions;
TOX results for samples MQA463, 464, 610, and 673; POX
results for samples MQA608, 610, 623, and 673
volatiles data
all semivolatile results
all pesticides results
-------
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 #42, CECOS, New York, 12/16/1986, Prepared by
Lockheed Engineering and Management Services Company, Inc., for the US EPA
Hazardous Waste Ground-Water Task Force.
3. Draft Inorganic Data Usability Audit Report and Draft Organic Data Usability
Report, for the CECOS, New York facility, Prepared by Laboratory Performance
Monitoring Group, Lockheed Engineering and Management Services Co., Las Vegas,
Nevada, for US EPA, EMSL/Las Vegas, 12/16/1986.
-------
ANALYTICAL RESULTS
Table C-l Sample Preparation, Analytical Techniques, and Methods
Table C-2 Organic Results
Table C-3 Limits of Quantitation for Organic Results
Table C-4 Total Metal Results
Table C-5 Field Measurements and General Analytical Parameters
-------
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Table C-3
LIMITS OF QUANTITATION FOR ORGANIC COMPOUNDS
CECOS INTERNATIONAL
Niagara Falls, New York
Limit of
Quantisation
fug/L)
Limit of
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(M9/L)
Limit of
Quantitation
(M9/L)
/olatile Compounds (Purge & Trap)
irosnomethane 20
^hloromethane 30
iromodichloromethane 20
)ibromochloromethane 10
Jroisoform 10
Chloroform 20
Carbon tetrachloride 10
Maroon disulfide 20
;hloroethane 10
1,1-Dichloroethene 20
1,2-Dichloroethane 10
1,1,1-Trichloroethane 20
1,1,2-Trichloroethane 10
1,1,2,2-Tetrachloroethane 10
1,1-Dichloroethane 20
trans-l,2-0ichloroethene 20
Trichloroethene 10
Tetrachloroethene 10
Methylene chloride 20
Vinyl chloride 20
1,2-Dichloropropane 20
cis-l,3-0ichloropropene 10
trans-l,3-Qicnloropropene 20
Benzene 10
Chlorobenzene 10
Ethylbenzene 10
Toluene 20
m-Xylene 10
o & p-Xylene 30
Acetone 10
2-Butanone 20
2-Hexanone 20
4-Methyl-2-pentanone 20
2-Chloroethyl vinyl ether 20
Styrene 10
Vinyl acetate 20
Semi-Volatile Compounds
4-Chloroamline 20
2-Nitroaniline 100
3-Nitroani1ine 100
4-Nitroaniline 100
3,3'-Oichlorobenzidine 40
Benzyl alcohol 20
1,2-Dichlorobenzene 20
1,3-Oichlorobenzene 40
1,4-Dichlorobenzene 20
1,2,4-Trichlorobenzene 20
Hexachlorobenzene 20
Nitrobenzene 20
2,4-Dinitrotoluene 40
2,6-Dinitrotoluene 20
N-Nitrosodiphenylaminea 20
N-Nitrosodipropylamine 20
bis(2-Chloroethyl) ether 20
4-Chlorophenyl phenyl ether 20
4-Bromophenyl phenyl ether 20
bis(2-Chloroisopropyl) ether 20
bis(2-Chloroethoxy) methane 20
Hexachloroethane 20
Hexachlorobutadiene 20
Hexachlorocyclopentadiene 30
Semi-Volatile Compounds (cont.)
bis(2-Ethylhexyl) phthalate 20
Butyl benzyl phthalate 20
di-n-Butylphthalate 20
di-n-Octylphthalate 20
Diethylphthalate 20
Dimethylphthalate 20
Acenaphthene 20
Acenaphthylene 20
Anthracene 20
Benzo(a)anthracene 20
Benzo(b)fluoranthene and/or
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Benzo(g,h,i)perylene 40
Benzo(a)pyrene 50
Chrysene 20
Oibenzo(a,h)anthracene 40
Dibenzofuran 20
Fluoranthene 20
Fluorene 20
Indeno(l,2,3-c,d)pyrene 40
Isophorone 20
Naphthalene 20
2-Chloronaphthalene 20
2-Methylnaphthalene 20
Phenanthrene 20
Pyrene 20
Benzoic acid 100
Phenol 20
2-Chlorophenol 20
2,4-Dichlorophenol 20
2,4,5-Trichlorophenol 100
2,4,6-Trichlorophenol 20
Pentachlorophenol 100
4-Chloro-3-methylphenol 20
2-Methylphenol 20
4-Methylphenol 20
2,4-Oimethylphenol 20
4,6-Oinitro-2-methylphenol 100
2-Nitrophenol 20
4-Nitrophenol 100
2,4-Dimtrophenol 100
Pesticides/PCBs
Aldrin 0 05
alpha-BHC 0.05
beta-BHC 0.05
gamma-BHC 0.05
delta-BHC 0.05
Chlordane 0.5
4,4'-DDD 0.1
4,4'-DDE 0.1
4,4'-ODT 0.1
Dieldrin 0.1
Endosulfan I 0.05
Endosulfan II 0.1
Endosulfan sulfate 0.2
Endrin 0 1
Heptachlor 0.05
Heptachlor epoxide 0.05
Toxaphene 1
Methoxychlor 0.5
Endrin ketone 0 2
PCB-1016 0.5
PCB-1221 0.5
PCB-1232 0.5
PC8-1242 0.5
PCB-1248 0.5
PCB-1254 1
PCB-1260 1
Measured as diphenylaatinซ
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-------
Appendix D - Table 2
LEACHATE DATA FOR SCMF 5J
Standpipe and
Date Sampled
S5-1, 3, 4
Parameter 05/10/85
Total Phenol ics
Phenol
Methylene chloride
Chloroform
1,1,1 Trichloroethane
Isophorone
Toluene
Trichloroethylene
Tetrachloroethylene
Chlorobenzene
1,1 Dichloroethane
1,2 Dichloroethane
1,1 Dichloroethylene
Trans 1,2 dichloroethylene
Ethyl benzene
1,1,2,2 Tectrachloroethane
1,1,2 Trichloroethane
2,4 Dimethylphenol
Benzene
Butylbenzlphthalate
1,2 Dichlorobenzene
Dimethylpthalate
Nitrobenzene
1,2,4 Trichlorobenzene
Total cyanide
45000
28000
26000
10000
6300
5800
2300
1100
490
140
140
760
660
6
230
73
BDL
520
S5-5
05/10/85
65000
21000
1900
1200
2200
20
210
840
1800
BDL5
c
170
14
BDL
93
59
140
7.7
BDL
230
4.3
1.6
110
a All concentrations are expressed in
micrograms per liter.
b BDL means the compound was identified
below the detection limit.
c Where no entry is made, the compound was
not detected in the sample.
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