April 1988 EPA-330/2-88-036
Hazardous Waste Ground-Water
Task Force
Evaluation of
U.S. Pollution Control, Inc.
Grassy Mountain Facility
Utah
U.S. Environmental Protection Agency
Library (PL-12J)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
UTAH DEPARTMENT OF HEALTH
BUREAU OF SOLID AND HAZARDOUS WASTE
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UPDATE OF THE HAZARDOUS WASTE GROUND-WATER TASK FORCE
EVALUATION OF U.S. POLLUTION CONTROL, INC.
GRASSY MOUNTAIN FACILITY
May 12, 1988
, The Hazardous Waste Ground-Water Task Force (Task Force) of the
United States Environmental Protection Agency (EPA), in conjunction with the
Utah Department of Health Bureau of Solid and Hazardous Waste (UDH),
conducted an evaluation of the ground-water monitoring program at the U.S.
Pollution Control Incorporated (USPCI) Grassy Mountain hazardous waste
treatment, storage and disposal facility. The Grassy Mountain facility is located
approximately 80 miles west of Salt Lake City, Utah in the Great Salt Lake
Desert. The onsite field inspection was conducted during the period June 23
through 1 7, 1 986 and July 9 through 11,1 986.
USPCI is one of 58 facilities evaluated by the Task Force for compliance
with applicable State and Federal ground-water monitoring requirements. The
Task Force effort originated in light of concerns as to whether operations of
hazardous waste treatment, storage and disposal facilities are complying with
State and Federal ground-water monitoring requirements.
The objectives of the Task Force evaluation were to:
Determine compliance with interim status ground-water monitoring
requirements of Title 40 of the Code of Federal Regulations,
Part 265, Subpart F (40 CFR 265), as promulgated under RCRA
and the equivalent State requirements
Evaluate the ground-water monitoring program described in the
RCRA Part B permit application submitted by the Company for
compliance with 40 CFR 270.14(c) and the equivalent State
requirements
Determine if the ground water beneath the facility contains
hazardous waste or hazardous waste constituents
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 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 Grassy Mountain facility. EPA Region VIII and UDH personnel
had previously identified many of the deficiencies that are discussed in the Task
Force report. In the process of writing a RCRA permit for the facility, the
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regulatory agencies have tried to address those deficiencies and develop an
appropriate ground-water monitoring program at Grassy Mountain.
The major deficiencies have been addressed through requiring
modification of operations through the permitting process. The RCRA draft
permit for the USPCI Grassy Mountain facility has been written and is
undergoing modification prior to final permit issuance in 1988.
Determine Compliance with the Ground-Water Monitoring Requirements of 40
CFR. Part 265 and the Equivalent State Requirements
The Task Force evaluation revealed that USPCI was not in full
compliance with the ground-water monitoring requirements of 40 CFR, Part
265 and the equivalent State requirements in the Utah Hazardous Waste Rules
7.13. Deficiencies were found in the sampling and analysis plan and the
implementation of that plan, sample analyses, the assessment monitoring plan
and the monitoring system.
The Task Force found that several monitoring wells included in the
sampling plan for Grassy Mountain may have settled, causing changes in the
elevations of the surveyed measuring points on the wells. Since the Task Force
inspection, USPCI has extended most of the wells an additional 2.5 feet above
ground. The extensions were accomplished in March 1987 and were
resurveyed at that time. The final RCRA facility permit will require an annual
survey of all well elevation measuring points.
The highly saline (greater than 70,000 ppm) ground water beneath the
Grassy Mountain facility has created problems with standard analyses for the
indicator parameters required by 40 CFR 265.92 and for metals and inorganics.
The Task Force recommendations for changes to sampling and analytical
protocols will be incorporated into the final USPCI RCRA permit and will require
USPCI to monitor for specific volatile and semivolatile organics parameters in
lieu of TOX as an indicator parameter.
USPCI completed over a year of quarterly assessment monitoring in
1986 and 1987, using GC/MS analysis for volatile and semivolatile Appendix IX
constituents as well as analyses for metals and other inorganics. In addition to
the two sampling periods prior to the Task Force inspection, USPCI completed
four subsequent quarterly samplings and associated analyses. EPA, the State
and USPCI agreed that after assessment, USPCI would continue to do
quarterly interim status monitoring until issuance of the RCRA permit, using the
same parameters and analytical methods as those used for assessment
monitoring. -
Following a meeting between EPA, the State and USPCI on March 30
and 31,1987, USPCI was instructed by EPA Region VIII to complete a report on
the results of the ground-water assessment monitoring program, as required by
40 CFR 265.93(d)(5). USPCI submitted the assessment monitoring results to
UDH in May 1987. A decision on how to proceed with ground-water monitoring
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will be made by UDH, pending the final results from an April 1988 Compliance
Monitoring Evaluation (CME).
With respect to sample analysis, the NAL laboratory has been instructed
by EPA Region VIII to identify specifically which compounds it is capable of
analyzing. In addition, the USPCI RCRA permit specifies which Appendix IX
and other GC/MS parameters will be monitored during the term of the permit.
The Task Force report identifies critical deficiencies in the documentation
of the initial well monitoring system MW-1 through MW-8. Following the State-
USPCI Consent Agreement of October 1985, monitoring wells MW-9 through
MW-25 were installed. These wells met regulatory objectives. Additional wells
have been installed since 1986 which also meet the regulatory objectives.
MW-1 and MW-2 will continue as upgradient wells (new wells MW-9 and
MW-20 are used also). MW-5 will continue as one of four downgradient
monitoring wells at the land treatment area; MW-6 may be used for a
nonregulated unit or may be replaced. Without any of the initial monitoring
wells, the remaining wells are considered adequate for monitoring needs. This
monitoring system will remain in effect for the duration of interim status and for
the term of the permit; wells may be added as disposal operations expand.
Evaluation of the Ground-Water Monitoring Program Described in the RCRA
Part B for Compliance with 40 CFR 27Q.14(c) and the Equivalent State
Requirements
The RCRA permit will require detection monitoring under 40 CFR 264,
modified to include the GC/MS methods for volatile and semivolatile organic
parameters (108 constituents) as detection monitoring parameters. Metals and
inorganic parameters will also be simultaneously collected semiannually,
although the regulatory agencies recognize that the reliability of these
measurements is limited as a result of the naturally high salinity of the ground
water.
The permit contains a specific statistical evaluation protocol for the
monitored chemical constituents. USPCI has not submitted statistical
comparisons during interim status, however, based on the April 1988 CME,
USPCI was requested to submit a statistical comparison on all future monitoring
events.
Petermine if the Ground Water Beneath the Facility Contains Hazardous Waste
or Hazardous Waste Constituents
Analyses of ground-water samples have not shown that hazardous waste
or hazardous waste constituents have entered the ground water beneath the
facility.
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Provide Information to Assist the Agency in Determining if the TSDF is Suitable
for Receipt of CERCLA Waste
EPA Region VIII has determined that the USPCI Grassy Mountain Facility
may receive CERCLA waste.
This update completes the Task Force evaluation of the USPCI Grassy
Mountain facility.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUND-WATER TASK FORCE
EPA-330/2-88-036
GROUND-WATER MONITORING EVALUATION
U.S. POLLUTION CONTROL, INC.
Grassy Mountain Facility
Clive, Utah
April 1988
Sally C. Arnold
Project Coordinator
National Enforcement Investigations Center
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CONTENTS
EXECUTIVE SUMMARY
INTRODUCTION 1
SUMMARY OF FINDINGS AND CONCLUSIONS 6
GROUND-WATER MONITORING PROGRAM DURING INTERIM
STATUS 6
Ground-Water Sampling and Analysis Plan 7
Monitoring Wells 8
USPCI Sample Collection and Handling Procedures 10
Samples Analysis and Data Quality Evaluation 12
Ground-Water Quality Assessment Program 15
GROUND-WATER MONITORING PROGRAM PROPOSED FOR
FINAL PERMIT 15
TASK FORCE SAMPLING AND MONITORING DATA EVALUATION 18
SUITABILITY FOR RECEIVING WASTES FROM CERCLA ACTIONS.... 18
TECHNICAL REPORT
INVESTIGATION METHODS 19
RECORDS/DOCUMENT REVIEW 19
FACILITY INSPECTION 20
LABORATORY EVALUATION 20
GROUND-WATER AND LEACHATE SAMPLING AND ANALYSIS 20
WASTE MANAGEMENT UNITS AND FACILITY OPERATIONS 26
WASTE MANAGEMENT UNITS 26
Surface Impoundment 29
Landfills 31
Tanks 37
Drum Storage Area 39
Land Treatment Areas 39
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CONTENTS (Cont.)
FACILITY OPERATIONS 39
Surface Impoundment 39
Landfills :40
Tanks 40
Drum Storage Area 41
Land Treatment Areas 42
SITE HYDROGEOLOGY 43
HYDROGEOLOGIC UNITS 44
GROUND-WATER FLOW DIRECTION AND RATES 45
GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS 50
REGULATORY REQUIREMENTS 53
GROUND-WATER SAMPLING AND ANALYSIS PLAN 54
Elements of the USPCI Sampling and Analysis Plan 54
Sampling Records During Interim Status 56
MONITORING WELLS 58
Well Construction 59
Well Locations 66
USPCI SAMPLE COLLECTION AND HANDLING PROCEDURES 67
Water Level Measurements 68
Purging 70
Field Data and Sample Collection 71
Shipping and Chain-of-Custody 74
Sampling and Analysis Plan 74
SAMPLE ANALYSIS AND DATA QUALITY EVALUATION 75
GROUND-WATER QUALITY ASSESSMENT PROGRAM 75
GROUND-WATER MONITORING PROPOSED FOR FINAL PERMIT 78
PROPOSED MONITORING WELL NETWORK 78
PROPOSED SAMPLING AND ANALYSIS PROGRAM 80
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CONTENTS (Cont.)
EVALUATION OF MONITORING DATA FOR INDICATIONS OF WASTE
RELEASE 82
REFERENCES
APPENDICES
A USPCI SAMPLE ANALYSIS AND DATA QUALITY EVALUATION
B ANALYSIS AND DATA EVALUATION FOR TASK FORCE SAMPLES
FIGURES
1. USPCI Grassy Mountain Location Facility Map 2
2. Monitoring Well Locations, June 1986 9
3. Disposal Units at USPCI 27
4. Surface Impoundment Leachate Detection System Details 30
5. Landfill Cell 2 Leachate Sump Details 35
6. Landfill Cell 2 Leachate Withdrawal System Details 36
7. Water Level Elevations June 1986 49
8. Monitoring Well and Lysimeter Locations 61
9. General Monitoring Well Construction (MW-9 through MW-25) 64
10. Well Cap Assembly 69
in
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CONTENTS (Cont.)
TABLES
1. Sample Collection and Location Description Monitoring Well Data 21
2. Leachate Sample Description and Collection Location 22
3. Preferred Order of Sample Collection, Bottle Type and Presevative
List : 24
4. Hazardous Waste Disposed at USPCI, Grassy Mountain 1985 28
5. Existing RCRA Tanks, Capacity and Types of Waste Stored 38
6. Range of Values of Porosity in Unconsolidated Sediments 46
7. Ground-Water Flow Velocity Computed by USPCI Consultants 47
8. Regulatory Authority, Requirements and Events During USPCI
Interim Status 51
9. State and Federal Counterpart Interim Status Regulations 53
10. Water Level Measurements Omitted, December 1985 - June 1986 57
11. USPCI Interim Status Monitoring Wells - June 1986 60
12. Construction Specifications for Monitoring Wells 62
13. USPCI Quarterly Sampling Parameters 73
14. Monitoring Wells Sampled by Task Force 83
15. Leachate Sample Location Descriptions .-.83
16. Selected Compounds Found in Leachate Samples from the
Leachate Detection System of Cell 2 84
IV
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EXECUTIVE SUMMARY
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INTRODUCTION
Concerns have been raised about whether commercial hazardous waste
treatment, storage and disposal facilities (TSDFs) are complying with the
ground-water monitoring requirements promulgated under the Resource
Conservation and Recovery Act (RCRA).* In question is the ability of existing or
proposed ground-water monitoring systems to detect contaminant releases from
waste management units. To evaluate these systems and determine the current
compliance status, the Administrator of the Environmental Protection Agency
(EPA) established a Hazardous Waste Ground-Water Task Force (Task Force).
The Task Force comprises personnel from 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.
The first TSD facility the Task Force inspected in EPA Region VIII was the
U.S. Pollution Control, Inc. (USPCI), Grassy Mountain Facility, Clive, Utah
located in the Great Salt Lake Desert about 80 miles west of Salt Lake City,
Utah [Figure 1]. The onsite inspection was coordinated by personnel from
NEIC, a field component of the EPA Office of Enforcement and Compliance
Monitoring, during the period June 23 through June 27, 1986 and July 9
through July 11, 1986. Personnel from the State of Utah Department of Health,
Bureau of Solid and Hazardous Waste, and EPA Region VIII also participated.
The objectives of this investigation were similar to those of other Task Force
investigations, namely:
Determine compliance with interim status ground-water monitoring
requirements of Title 40 of the Code of Federal Regulations Part
265 Subpart F (40 CFR Part 265), as promulgated under RCRA
and the equivalent Utah Hazardous Waste Rules (UHWR 7.13)
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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NORTHERN
GREAT
SALT LAKE
DESERT
APPROXIMATE DEBCrtT BOUNDARY
(ป doflncd by Otophปnป, 1074)
TERRACE x
UOUNTAIHS\
NEWFOUNDLAND
MOUNTAINS
SILVER ISLAND
MOUNTAINS
USPCI
GRASSY
MOUNTAIN
FACILITY
Knolls Exit
610 20
DISTANCE IN MILES
NORTH
Figure 1.
USPCI GRASSY MOUNTAIN
FACILITY LOCATION MAP
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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 UHWR 3.3.2(c)
Determine if the ground water beneath the facility contains
hazardous waste or hazardous waste constituents
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 Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), as amended*
To address these objectives, this Task Force evaluation determined if:
The facility has developed and is following an adequate ground-
water sampling and analysis plan.
Designated RCRA- and/or State-required monitoring wells are
properly located and constructed.
Required analyses have been done properly on samples from the
designated RCRA monitoring wells.
The ground-water quality assessment program outline (or plan, as
appropriate) is adequate.
The land surrounding the Grassy Mountain facility is undeveloped desert
belonging to the U.S. Bureau of Land Management. A Hill Air Force Base
bombing range is located just north of the site. This area has no residential
population.
EPA policy, stated in May 6, 1985 memorandum from Jack McGraw on "Procedures for
Planning and Implementing Off site Response" requires that TSDFs receiving CERCLA
waste be in compliance with applicable RCRA ground-water monitoring requirements.
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In 1981, USPCI leased the approximately 1-square-mile tract (643 acres)
from Khosrow Semnani, who attempted to develop a metals
reclamation/recovery operation. Semnani had acquired, but not set up, some
processing equipment. Some test drilling had been completed in the area and
two gondolas (roll-off boxes) of "waste" had been brought to the site. These
activities occurred in what became a 206-acre land treatment area. For
purposes of RCRA interim status ground-water monitoring, eight wells were
installed at the site in 1981.
USPCI submitted a RCRA Part A application in December 1981 and
began hazardous waste management activities at the Grassy Mountain facility
in March 1982. Initial operations were limited to storage and landfilling of
waste. Land treatment began in April 1982. Liquid waste neutralization and
sulfide treatment began in 1985. Landfilling of polychlorinated biphenyls
(PCBs) began in April 1986. PPM, Inc., a subsidiary of USPCI, began operating
a liquid PCB treatment system at the Grassy Mountain site in 1986. All of the
above activities were ongoing during the Task Force inspection.
The Grassy Mountain facility has been regulated by State waste disposal
requirements since operations began. Currently, the site is operated pursuant
to interim status regulations promulgated under the Utah Code Annotated
Title 26 - Health Chapter 14 rules (UC 26-14).* The Utah Department of
Health (UDH) received RCRA interim authorization in December 1980 and final
authorization in September 1984. EPA administers regulatory programs
-pursuant to the Hazardous and Solid Waste Amendments of 1984 and the
Toxic Substances Control Act (TSCA).
USPCI currently operates as an interim status facility under EPA
Identification Number UTD991301748. The Company initially submitted a
RCRA Part B permit application to EPA Region VIII and UDH in August 1983; a
revised Part B was submitted in July 1984.
The State equivalent of RCRA is the Utah Code Annotated Title 26 - Health Chapter 14
rules (UC 26-14). The State equivalents of Title 40 Code of Federal Regulations, Parts 260-
265 are the Utah Hazardous Waste Rules (UHWR).
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Upon receipt and review of the revised Part B, UDH and EPA Region VIII
determined that, among other things, the ground-water monitoring system was
deficient. In August 1985, the UDH sent a stipulation and consent order to the
Company requiring them to upgrade the existing ground-water monitoring
system. A complaint paralleling the State action was filed by EPA in
September 1985. On October 2, 1985, the Company signed a stipulation and
consent order to install a new ground-water monitoring system by November 8,
1985.
Ground-water monitoring data from October 1984 samples showed a
statistically significant increase of total organic carbon (TOC) in ground-water
monitoring well 3 (MW-3). On October 31, 1985, USPCI was ordered to initiate
an assessment monitoring program by the Utah Department of Health.
Therefore, the facility was in ground-water assessment monitoring under Utah
Hazardous Waste Rules 7.13.4 (UHWR 7.13.4) and 40 CFR 265.93 during the
Task Force inspection. The assessment monitoring consisted of sampling and
analyzing for an increased number of parameters for all the ground-water
monitoring wells as well as increased sampling for MW-3.
Waste management operations for the nonhazardous USPCI industrial
landfill are regulated by Utah Solid Waste Management Regulations. There
were no State or Federal permits for air emissions or water discharges, but the
State will issue an air permit in 1988. A TSCA permit for treatment and
disposal of PCB waste was issued to the Company by EPA on November 26,
1985. Additional permits include a Tooele County Conditional Use Permit
(number 100-81) issued on February 11, 1981 and amended August 12,
1981; and a right-of-way permit from the United States Bureau of Land
Management (number U-47260) issued October 23, 1986.
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SUMMARY OF FINDINGS AND CONCLUSIONS
The findings and conclusions presented in this report reflect conditions
existing at the facility in June 1986. Actions taken by the State, EPA Region VIM
and USPCI subsequent to June are summarized in the accompanying update.
Task Force personnel inspected the Grassy Mountain facility from
June 23 through June 27, 1986. From July 9 through July 11, 1986, Task
Force personnel observed quarterly ground-water sampling to verify that a new
sampling and analysis plan was being implemented.
The interim status ground-water monitoring program was evaluated for
compliance on the basis of the Utah Hazardous Waste Rules (UHWR 7.13),
which are equivalent to the Federal Regulations (40 CFR Part 265, Subpart F).
The UHWR have governed the development of the ground-water monitoring
program since the beginning of hazardous disposal operations at the facility in
March 1982. No hazardous waste disposal permit had been issued by the
State by the end of the onsite inspection.
The inspection revealed that the USPCI interim status ground-water
monitoring program was inadequate from the beginning of waste disposal
operations in 1982. The Task Force found that as of July 1986, the interim
status ground-water monitoring program components, including the ground-
water sampling and analysis plan, the ground-water assessment program and
assessment program outline, did not comply with State of Utah and RCRA
requirements. Most ground-water quality data obtained prior to the Task Force
inspection were not reliable. These findings are summarized here and are
detailed further in the technical report.
GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS
Major ground-water problems facing USPCI during interim status include
characterizing the ground-water quality at Grassy Mountain and implementing
a monitoring program that ensures adequate coverage of disposal units and
reliable analytical results. The reliability of water quality data from 1981 (when
USPCI leased the property) through 1985 is suspect because of both analytical
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deficiencies and interferences from the naturally high concentration of salts in
the ground water. As a result, the true character of background ground-water
quality is not well understood. Throughout this period, USPCI continued
quarterly monitoring with some analytical revisions in an effort to define
background water quality.
In 1986, USPCI began a new effort to characterize the ground water
using more wells and expanded analyses. This effort coincided with the
initiation of assessment monitoring triggered by elevated levels of total organic
carbon (TOC) in MW-3. At the request of EPA Region VIII and the State, the
expanded analyses included additional organic parameters. The early 1986
water quality data, although showing improvement over previous years,
continued to be deficient because of analytical problems. The result is a
shortage of reliable data characterizing background ground-water quality at
Grassy Mountain as of mid-1986.
Ground-Water Sampling and Analysis Plan
The ground-water sampling and analysis plan submitted in November
1985, in response to an October 1985 stipulation and consent order issued by
UDH, is inadequate. The sampling and analysis plan includes wells (MW-4,
MW-6, MW-7 and MW-8) that are no longer used. The sampling and analysis
plan also includes a four-page unreferenced list of Appendix VIII components;
the laboratory does not analyze for each of the listed parameters, neither does
the plan indicate which of these parameters are analyzed. Only the list of
parameters for which analyses actually are done should appear in the plan
and USPCI should follow the plan by analyzing for all the compounds listed.
More than one analytical method is listed for some parameters. The plan needs
to be revised to reflect which analytical methods are actually used.
Methods in the plan for measuring static water levels, are acceptable
except for the provision that measurement accuracy be obtained within 1/32 of
an inch (approximately 0.003 feet). This accuracy is unrealistic and cannot be
obtained with the electric water level indicator used by the facility.
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8
The plan provisions for field sampling are generally acceptable with the
exception of waiting until all the wells are purged before sampling begins.
Some lag times may be necessary for slowly recharging wells; however, those
that recharge quickly should be sampled as soon as possible.
The provisions for collecting field blanks need to state that field blanks be
preserved or not preserved, according to what is done for the corresponding
sample. Otherwise the method for field blanks is acceptable.
The provisions for preservatives, chain-of-custody and shipping are also
acceptable.
Monitoring Wells
Prior to 1986, the interim status ground-water monitoring system at
Grassy Mountain consisted of eight wells, MW-1 through MW-8. In early 1986,
12 new wells (MW-9 through MW-20) became part of the monitoring program at
Grassy Mountain. These new wells were constructed in response to the
October 2, 1985 stipulation and consent order. Wells MW-21 through MW-25
also were added in 1986.
The monitoring well network being used during the Task Force
inspection, included 23 (MW-1 through MW-23) of the 25 wells [Figure 2]. Two
additional wells (MW-24 and MW-25) were under construction at that time.
Exactly which of these wells were being sampled for interim status ground-
water monitoring was unclear because Company personnel contradicted both
one another and their sampling and analysis plan on this subject.
In 1986, some of the older wells sampled prior to 1986 were dropped
from the sampling program. Sampling records for 1986 were inconsistent and
did not show the same wells sampled each time. As a result, USPCI personnel
appeared not to know which of the earlier wells were still included for interim
status monitoring.
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IMPOUNDMENT
f LAB AND''/
ACCESS ROAO
LANDFILL
MW-22
CELL X
RUNOFF
CONTROL
PONO
RUNOFF
CONTROL!
POND' I
ACCESS ROAO
MW-9
LAND TREATMENT AREA II
LAND TREATMENT AREA I
LAND TREATMENT AREA III
LAND TREATMENT AREA IV
Approximate Scale
600 300 0 600
Monitoring Well
Figure 2. Monitoring Well Locations
June 1986
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10
Information available to the Task Force was insufficient to determine
whether monitoring wells MW-1 through MW-8 were properly constructed for
compliance with UHWR 7.13.2 (40 CFR 265.91). If the information does not
exist, then USPCI cannot demonstrate that these wells were properly
constructed for ground-water monitoring purposes and meet regulatory
requirements. The construction design and material for the new monitoring
wells (MW-9 through MW-23) are acceptable.
The number and location of the wells in the network were determined to
be adequate to detect any statistically significant amounts of hazardous waste
constituents migrating to the uppermost aquifer from the waste management
units in place at the time of the Task Force inspection. Additional wells will be
required as the facility expands the hazardous waste operations.
USPCI Sample Collection and Handling Procedures
USPCI personnel did not follow their sampling and analysis plan with
respect to: (1)pH standardization, (2) preservatives and (3) immediate
sample shipment. By not following the plan, USPCI was out of compliance with
UHWR 7.13.3 (40 CFR 265.92). Sampling procedures in the field were
careless and could potentially compromise sample integrity. Water level
measurements were inaccurate because of changing baseline elevations
resulting from wells sinking and lack of precision in measuring water levels.
The pH of ground water beneath the facility ranges from 7.1 to 7.5. In
standardizing the pH meter, the standard at 7.4 and then the standard at 10.4
were checked. The meter should be rechecked with the pH 7.4 standard to
ensure the instrument has not drifted in the 10.4 standard adjustments. Also, in
order to follow the sampling and analysis plan, a standard in the pH range of
4.0 to 5.0 should be added to the calibration procedure. Measurements for pH
and specific conductance are temperature-dependent. Reported pH and
specific conductance results need to be corrected adequately for the
temperature of the sample at the time of measurement.
The shipping forms and labels on the sample bottles for phenols from
National Analytical Laboratory (NAL) list phosphoric acid/cupric sulfate
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11
(HPO3/CUSO4) as the preservatives.* The sampling and analysis plan
specifies H2SO4 as the preservative for phenols. Better communication
between the facility and the laboratory is needed to ensure that the plan
matches the laboratory practices. Additionally, the plan needs to state that field
blanks poured for sample parameters requiring preservatives should be
preserved in a like manner to completely verify laboratory results.
Sampling the monitoring wells requires more than 1 day. Samples are
preserved and packed each day but are held for shipping up to 1 day and
1 night until sampling is completed. No samples were held longer than
prescribed in EPA guidelines (including shipping time); however, the sampling
and analysis plan directs shipping immediately after collection and packing.
USPCI personnel demonstrated their well purging techniques and water
level measurement techniques during the June 1986 Task Force inspection.
During the July 1986 site visit by the Task Force, USPCI personnel also
demonstrated their sample collection techniques. During the July 1986 visit,
new USPCI personnel were being trained in the sampling and handling
procedures.
At the time of the June and July 1986 site visits, USPCI personnel made
water level measurements in the monitoring wells using an electric water level
indicator. The electric water level indicator (ACTAT Olympic Well Probe,ฎ
Model 150) did not measure water levels with consistent accuracy. Task Force
personnel repeatedly observed sequential measurements in the same well that
differed by as much as ฑ0.2 feet (measured with a tape measure). This margin
of error is unacceptable for accurate water-level analysis in conditions of a
shallow hydraulic gradient such as the one at Grassy Mountain.
Each well was equipped with a dedicated Well Wizardฎ bladder pump
and wellhead assembly for purging and sampling. For sampling required by
UHWR 7.13.3 (40 CFR 265.92), USPCI personnel purged all monitoring wells
NAL (Tulsa, Oklahoma) has done most of the ground-water analyses for the USPCI Grassy
Mountain Facility.
ฎ Olympic Well Probe and Well Wizard are registered trademarks and will appear hereafter
without .
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24 hours or more before sampling began. Sampling should be performed
immediately on any well that recharges rapidly in order to obtain fresh water
from the aquifer. Otherwise, chemical reactions may occur in water that
stagnates in the well casing. Wells that recharge slowly need to be sampled as
soon as a sufficient volume is available for sampling parameters.* Although an
error in the sampling and analysis plan on procedures for computing the purge
volumes was noted by Task Force personnel, correct volumes were purged.
The USPCI sampling personnel wore latex surgical gloves that were discarded
upon contact with foreign substances and upon completing sampling of a well;
however, the inside of the sample containers and bottle caps were sometimes
touched by the samplers. Anytime the inside of a sampling container is
possibly contaminated by contact with a foreign substance or a sampler's
finger, the container needs to be replaced by a clean one.
Dedicated Teflonฎ sampling tubing was stored inside most wellhead
assemblies. At any well without dedicated tubing, the samplers utilized spare
tubing from their supplies. In at least two cases, this tubing was reused without
rinsing between wells. The possibility of cross-well contamination is increased
greatly by this practice and should be discontinued.
Samples Analysis anq1 Data Quality Evaluation
The Task Force inspection revealed analytical inadequacies and found
that much of the ground-water monitoring between 1982 and June 1986 was
not performed properly. Most of the analytical inadequacies stem from
improper sample handling or calibration procedures, the lack of quality control
measures, and/or not accounting for the high dissolved solids content of the
sample. The high levels of dissolved solids can introduce variability to the data
and thereby have adversely affected the reliability of data in establishing
background levels or in detecting releases into ground water.
RCRA Ground-Water Monitoring Technical Enforcement Guidance Document (TEGD),
EPA, 1986, OSWER 9950.1
Teflon is a registered trademark and will appear hereafter without ฎ.
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13
Ground-Water Analysis. 1982 through 1985
Ground-water monitoring for background water quality in 1982 was
incomplete. The quadruplicate measurements for the four indicator parameters
required by UHWR 7.13.3 (40 CFR 265.92) were not reported. Background
monitoring results for the required pesticides, herbicides and radio-chemical
parameters were not reported (UHWR 7.13.3, 40 CFR 265.92). Several
constituents were not reported in one or more quarters [e.g., fluoride, nitrate,
pH, total organic carbon (TOC), total organic halogens (TOX), coliform, silver
and chromium].
Long holding times for pH resulted because USPCI shipped samples
from Utah to a laboratory in Oklahoma before measuring pH (prior to 1984,
EPA recommended holding times of not more than 2 hours for wastewater and,
since that time, recommended measuring pH immediately).* Measurement of
pH should be done in the field at the time of sampling.
Specific conductance results for 1982 through 1985 are suspect because
cell constant corrections were not made for the measurements. Standards to
establish the cell constant were not within the same range as the samples.
Total organic halogens results for this period are unreliable. TOX
measurements using the standard method and instrumentation for ground
water containing such high levels of dissolved salts and suspended solids
cannot serve as an indicator of low level contamination of halogenated
organics. Purgeable organic halogens (POX) could serve as an indicator of
low level contamination of volatile halogenated organics (see Appendix A).
Total organic carbon results for this period were actually measurements
of nonpurgeable organic carbon. The method of acidifying and purging
samples prior to analysis eliminates purgeable organic carbon.
(1) 40 CFR 136, Table II
(2) TEGD
(3) Procedures Manual for Groundwater Monitoring at Solid Waste Disposal Facilities.
PB 84-17480
(4) Methods for Chemical Analysis of Water and Wastes. EPA 600/4-79-020
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14
Many of the determinations for metals prior to 1985 are unreliable
because the high dissolved solids content of the ground-water samples has
caused serious interferences with the analytical methods (atomic absorption
spectroscopy techniques). In 1985, the laboratory began using Inductively
Coupled Argon Plasma Optical Emission Spectroscopy (ICP) which is also
subject to interferences from high dissolved solids. Neither method attained
detection limits low enough to establish background levels reliable for ground
water.
A number of records for metals and pesticides determinations that were
performed on ground-water samples could not be found by the laboratory
personnel. The absence of these records prevented the Task Force from
evaluating the data quality for these parameters.
Data reported for the phenoxy acid herbicides 2,4-D and Silvex are not
reliable, as the method used would not detect the herbicides present in-the
ester form. In addition, gross alpha and gross beta data are unreliable
because levels are reported below what can be measured reliably in samples
containing percent levels of dissolved solids.
Ground-Water Analysis Commencing January 1986
Certain ground-water monitoring data for the first two quarters of 1986
were absent. No results were available for MW-5 during the first quarter.
According to the Utah Department of Health, only volatile and semivolatile
organic compounds were reported for the second quarter for all the wells.
Most of the laboratory findings applicable to the period prior to 1986
(discussed above) are also applicable to 1986 data, as most of the methods
did not change. Determinations still lacked adequate quality control measures.
Volatile and semivolatile organic results for the first two quarters of 1986
are unreliable. The methods used (EPA Methods 624 and 625) were not
properly followed. Accuracy and precision control measures required by the
methods were not properly implemented or evaluated.
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15
Ground-Water Quality Assessment Program
Statistically significant elevated levels of total organic carbon (TOC) were
measured in MW-3 on November 13, 1985. A letter sent on December 12,
1985 by UDH notified USPCI that their ground-water quality assessment plan
should have been submitted 15 days after the initial notification, as required by
UHWR 7.13.4 (40 CFR 265.93). USPCI only resubmitted the sampling and
analysis plan, which had been submitted in November 1985. The sampling
and analysis plan does not meet the requirements of a ground-water quality
assessment plan or programs, as required by UHWR 7.13.4 (40 CFR 265.93).
The plan does not:
Specify for which organic compounds samples will be analyzed
Identify the specific methods of analysis for organic compounds
List and identify detection limits that NAL is able to achieve for
each parameter analyzed
Include any evaluation procedures for the ground-water
monitoring data, including analytical and water level data
Make provisions for determining the rate and extent of migrations
of the hazardous waste or constituents in the ground water
Include complete and legible well construction specifications
The Grassy Mountain facility began a year of quarterly assessment
monitoring in the first quarter of 1986 but was not following an approved
assessment monitoring plan.
GROUND-WATER MONITORING PROGRAM PROPOSED FOR FINAL PERMIT
In May 1986, USPCI submitted a hydrogeologic characterization report
for the Grassy Mountain facility to UDH and EPA. The report was written to
satisfy the Part B ground-water requirements detailed in UHWR Part III
(40 CFR 270.14). Although the report addresses the requirements, it is
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16
inadequate in detail and revisions to the proposed ground-water monitoring
program will be necessary for the final RCRA permit.
The report outlines a detection monitoring program pursuant to UHWR
8.6.9 (40 CFR 264.98) for the uppermost aquifer and describes the proposed
monitoring well network, monitoring parameters, sample analyses, sample
collection and data evaluation. The Task Force considers detection monitoring
to be appropriate at Grassy Mountain.
As USPCI expands operations, the number of wells in the detection
monitoring program probably will increase. For the October 1985 Stipulation
and Consent Order, UDH and EPA Region VIII proposed dedicating wells to
monitor each regulated unit rather than monitoring all the units as a group. The
regulatory agencies also propose placement of monitoring wells so that they
circumscribe the landfill cells (as opposed to downgradient only) in order to
provide radial detection coverage of ground-water mounds induced by landfill
loading. This approach optimizes the chances of detecting leakage from
individual units.
Wells MW-4, MW-6 and MW-7 are several hundred feet from waste
management units and cannot provide immediate detection of leakage. These
wells are not suitable to be included in the regular ground-water monitoring
program proposed for the permit, however they may provide useful water level
data and periodic ground-water quality data. For reasons stated in the section
entitled "Well Construction," USPCI was unable to demonstrate that monitoring
wells MW-1 through MW-8 were in compliance with UHWR 7.13.2 (40 CFR
265.91).
For the land treatment areas, the existing downgradient monitoring wells
in the saturated zone combined with the 16 lysimeters in the unsaturated zone
should be adequate for compliance with 40 CFR 264.278 (UHWR 8.13.9,
when written, will be the State's corresponding regulation for unsaturated zone
monitoring beneath a land treatment area), and UHWR 8.6.8 and 8.6.9
(40 CFR 264.97 and 264.98).
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17
The Task Force agrees with the identification of the "shallow brine
aquifer" as the uppermost aquifer, as defined by UHWR Part 1 (40 CFR
260.10). The proposed design for future monitoring well construction is
acceptable.
Leakage of hazardous waste or hazardous waste constituents to the
ground water has not been substantiated; however, analyses of leachate
samples drawn from between two synthetic liners of cell 2 indicate the upper
liner has failed. USPCI must be prepared to implement a compliance
monitoring program under UHWR 8.6.10 (40 CFR 264.99) in case the second,
lower liner of cell 2 or liners of other units fail.
The list of proposed analytical parameters is too comprehensive and
includes compounds that are not analyzable by GC/MS. USPCI needs to
develop a list of parameters they can analyze and provide attainable detection
limits with each parameter listed.
The analytical procedures used to date by NAL have been judged by the
Task Force to be incapable of accurately measuring hazardous constituents in
ground-water samples or of providing a reliable indication of ground-water
quality. For the permit, personnel from the NAL laboratory should assess the
laboratory capabilities and protocols and propose analytical methods they can
do properly.
The inconsistent sampling procedures that existed prior to the Task Force
inspection cannot ensure monitoring results that provide a reliable indication of
ground-water quality. USPCI needs to ensure consistent sampling and
analytical procedures to comply with UHWR 8.6.8 (40 CFR 264.97).
USPCI has proposed to evaluate ground-water analytical data
statistically using the Chemical Manufacturers1-Assocfation-4CMA) standard
t-test. This procedure is inappropriate for the Grassy Mountain facility as it
does not account for variables such as the naturally high salts in the ground
water and the apparently natural fluctuations in ground-water quality.
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18
TASK FORCE SAMPLING AND MONITORING DATA EVALUATION
During the June 1986 onsite inspection, samples were collected by Task
Force contractors from 10 monitoring wells and 6 leachate collection sumps to
determine if the ground water contained hazardous waste constituents or other
indicators of contamination. Water levels were measured and samples were
drawn from the wells and sumps by USPCI personnel using their standard
procedures.
Analytical data for the Task Force samples from the monitoring wells do
not indicate the presence of hazardous constituents in the ground water
beneath the site. Previously, statistically elevated levels of total organic carbon
were found in well MW-3 by NAL; however, these elevated levels were not
substantiated by the Task Force sampling nor by additional monitoring by the
Company.
Task Force data for the leachate detection sump samples from landfill
cell 2 indicated a leak of the upper synthetic landfill liner. Data collected by
USPCI confirm that in landfill cell 2, such a leak has occurred. Ground-water
data, however, show no indication that the lower synthetic liner has leaked.
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. During the Task Force inspection, the
ground-water monitoring program at the Grassy Mountain facility was being
conducted pursuant to the October 1985 Stipulation and Consent Order prior to
issuance of the final RCRA permit by the State.
At the time of the Task Force inspection, the facility did not meet all the
technical requirements for a RCRA ground-water monitoring program. USPCI
was acting under State and EPA orders, however, to develop a monitoring
program that conforms to State and Federal permit requirements (Parts 8.6
and 264, respectively).
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TECHNICAL REPORT
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19
INVESTIGATION METHODS
The Task Force evaluation of USPCI consisted of:
Review and evaluation of records and documents from EPA
Region VIII, UDH and USPCI
Facility onsite inspection conducted June 23 through 27 and
July 9 through 11, 1986
Offsite analytical laboratory evaluation
Sampling and subsequent analysis and data evaluation for
selected ground-water and leachate monitoring systems
RECORDS/DOCUMENT REVIEW
Records and documents from the UDH and EPA Region VIII offices,
compiled by an EPA contractor, were reviewed prior to an onsite inspection.
Facility records also were reviewed to verify information currently in
Government files and supplement Government information where necessary.
Selected documents requiring in-depth evaluation were copied by the Task
Force during the inspection. Records were reviewed to obtain information on
facility operations, construction of waste management units and ground-water
monitoring activities.
Specific documents and records reviewed and evaluated included the
ground-water sampling and analysis plan (SAP), a ground-water quality
assessment plan, analytical results from past ground-water sampling,
monitoring well construction data and logs, site geologic reports, site operations
plans, facility permits, unit design and operation reports, and operating records
showing the general types and quantities of wastes disposed of at the facility
and the disposal locations.
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20
FACILITY INSPECTION
The facility inspection included identifying waste management units,
waste management operations and pollution control practices, and verifying the
location of ground-water monitoring wells and leachate collection sumps.
Company representatives were interviewed to identify records and
documents of interest, answer questions about the documents, and explain:
(1) facility operations (past and present), (2) site hydrogeology, (3) the
ground-water monitoring system, (4) the ground-water sampling and analysis
plan, (5) company procedures for assessment, and (6) laboratory procedures
for obtaining data on ground-water quality. Laboratory personnel from an offsite
laboratory that analyzed ground-water samples for USPCI were interviewed
regarding sample handling, analysis and document control.
LABORATORY EVALUATION
The USPCI-owned National Analytical Laboratory (NAL) in Tulsa,
Oklahoma, was evaluated regarding responsibilities for analysis of
ground-water samples from the Grassy Mountain facility. Analytical equipment
and methods, quality assurance procedures and documentation were
examined for adequacy. Laboratory records were inspected for completeness,
accuracy and for compliance with State and Federal requirements. The ability
of NAL to produce quality data for the required analyses was evaluated.
GROUND-WATER AND LEACHATE SAMPLING AND ANALYSIS
During the inspection, Task Force personnel collected samples for
analysis from 10 ground-water monitoring wells and 6 leachate collection
sumps [Tables 1 and 2] to determine if the ground water contained hazardous
waste constituents or other indicators of contamination. The sampling results
were used in evaluating previous Company data. Wells were selected for
sampling either in areas where records suggest that ground-water quality may
be or may have been affected by hazardous waste management activities.
Other wells were selected to confirm background ground-water quality.
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21
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22
Leachate sumps were sampled to the extent that sufficient liquid was present for
the samples. Duplicate volatile organic samples and splits of all other samples
were provided to USPCI personnel.
Table 2
LEACHATE SAMPLE DESCRIPTION AND COLLECTION LOCATION
Leachate
Sump
Cell 1
Cell 2
1B
2B
3B
4B
Surface
Impound-
ment
Location
Southern end
of cell 1
Northeast
corner
Southeast
corner
Southwest
corner
Northwest
corner
West end
Date Time Remarks
6/24 1 040 Sample dark straw/amber
color with black sediment;
oily sheen on surface
6/23 1501 Sample clear; NEIC split
6/24 0914 Containers omitted: phenols
su If ate/chloride, nitrate,
ammonia, sulfides
6/23 1348 Sample light straw color
6/23 1 138 Sample grey in color
6/24 1 223 Sample grey in color; sedi-
ment present; collected
only three TOC* containers
Total Organic Carbon
Each of the monitoring wells was equipped with a dedicated Well Wizard
sampling pump, which was operated by USPCI personnel. Samples were
collected from these wells by the following procedure. Additional details of
USPCI sampling procedures are described in the section on Ground-Water
Monitoring Program During Interim Status.
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23
1. Company personnel determined depth to ground water using an
ACTAT Olympic Well Probe, Model 150.
2. Company personnel calculated the height of the water column
from depth to water measurement and well depth (from
construction records).
3. Company personnel determined the water column volume using
the formula:
volume = n (radius)2 (height of water column)
4. Company personnel purged three water column volumes.
5. After recharge, EPA contractor monitored open well head for
chemical vapors (HNU) and radiation.
6. EPA contractor collected sample aliquot and measured water
temperature and pH.
7. EPA contractor filled sample containers in the order shown in
Table 3, alternating between filling a sample aliquot for the
Company and one for the EPA contract laboratory. When NEIC
samples were collected, the above protocol was modified to
include filling a sample aliquot for NEIC after filling one for the
EPA contractor.
8. Samples were placed on ice in an insulated container.
All sample containers were filled directly from the discharge line. After
sampling was completed at a well, EPA contractor personnel took their samples
to a staging area where a turbidity measurement was taken and one of two
sample aliquots for metals analysis was filtered. In addition, metals, TOC,
phenols, cyanide, nitrate and ammonia samples were preserved [Table 3].
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24
Table 3
PREFERRED ORDER OF SAMPLE COLLECTION, BOTTLE TYPE AND
PRESERVATIVE LIST
Parameter
Bottle
Preservative
1. Volatile organic analysis (VOA)
Purge and trap
Direct inject
2. Purgeable organic
carbon (POC)
3. Purgeable organic,
halogens (POX)
4. Extractable organics
5. Total metals
6. Total organic
carbon (TOC)
7. Total organic
halogens (TOX)
8. Phenols
9. Cyanide
10. Nitrate/ammonia
11. Su If ate/chloride
12. Radionuclides
(NEIC only)
13. Sulfides
Two 60-ml VOA vials
Two 60-ml VOA vials
One 60-ml VOA vial
One 60-ml VOA vial
Four 1 -qt. amber glass
1-qt plastic
4-oz. glass
1-qt. amber glass
1-qt. amber glass
1-qt. plastic
1-qt. plastic
1-qt. plastic
Four 1-qt. amber
glass
HNO3
H2S04
H2S04
NaOH
H2SO
0.2 ml of 2N
acetate* solution
and 0.2 ml
NaOH
2 Normal Acetate Solution:
in 870 ml Hฃ0
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25
Leachate was collected at sumps below the operating landfills 1 and 2,
and below the surface impoundment. All leachate samples were collected prior
to collecting ground-water samples to prevent possible cross-contamination
between the two. The EPA contractor collected composite samples in gallon
glass jugs then transferred the leachate to sample containers provided by the
EPA contractor. Leachate samples were not preserved.
At the end of each day, samples were packaged and shipped to the two
EPA contract laboratories according to applicable Department of Transportation
(DOT) regulations (40 CFR Parts 171 through 177). Samples from monitoring
wells were considered "environmental" and those from leachate sumps were
considered "hazardous" for shipping purposes.
At two sampling locations (MW-14 and MW-15), the EPA contractor
prepared field blanks for each analytical parameter group (e.g., volatiles,
organics, metals) by pouring high pressure liquid chromatography (HPkC)
water of known quality into sample containers. One set of trip blanks for each
parameter group was also prepared and submitted during the inspection. The
blanks were submitted to the laboratories with no distinguishing labeling or
markings.
Samples were analyzed by the EPA contractor laboratories for the
parameter groups shown on Table 3 minus the groups indicated on Tables 1
and 2. NEIC received and analyzed split samples for one ground-water
monitoring well (MW-14) and one leachate sump (cell 2, sump 1B).
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26
WASTE MANAGEMENT UNITS AND FACILITY OPERATIONS
WASTE MANAGEMENT UNITS
The Grassy Mountain facility handles both hazardous waste, as defined
by the Utah Hazardous Waste Rules pursuant to the Utah Code Annotated
Title 26 - Health Chapter 14 (UC 26-14) and regulated by the UDH and EPA,
and PCS waste, as defined in 40 CFR 761 and regulated by EPA. The Task
Force identified waste handling units and operations to determine where waste
constituents handled at Grassy Mountain might enter the ground water. This
section describes the waste management units at the Grassy Mountain facility.
During the Task Force inspection, USPCI was using the following
management units/areas for the treatment, storage and/or disposal of
hazardous waste:
One surface impoundment - storage
Four landfills*- disposal
Nine tanks - storage and treatment
One drum storage area - container storage
Four land treatment areas - disposal
No waste handling operations existed prior to the enactment of RCRA, as
the site has accepted hazardous wastes only since 1982. At the time of the
Task Force inspection, all operations and units ever used by USPCI were still
active [Figure 3], although landfill cell 1 was nearly full and expected to close
soon. Hazardous wastes accepted by USPCI in 1985 are presented in
Table 4.
Only two landfills were used for hazardous waste disposal. The other two landfills were
used for PCBs or nonhazardous industrial waste and were not evaluated for compliance
with Subpart F.
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27
.
INDUSTRIAL
WASTE
LANDFILL
CELL
ACCESS ROAD
r
u
LANDFILL
CELL 2
/
SURFACE'lf]
IMPOUNDMENT
''.LAB AND'''
/f
'Q>
OFFICE
"| j LANDFILL
i CELL 1
RUNOFF
CONTROL.
I POND i
ACCESS ROAD
LANO TREATMENT AREA II
LANO TREATMENT AREA III
LANO TREATMENT AREA I
LANO TREATMENT AREA IV
Figure -3
DISPOSAL UNITS AT USPCI
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28
Table 4
HAZARDOUS WASTE DISPOSED AT USPCI, GRASSY MOUNTAIN, 1985
EPA Hazardous
Waste Number
DOOO
D001
D002
D003
D003/K049/K051
D004
D005
D006
D007 EP Toxic
D008 Waste
D009
D012
D013
D016
F001/F002
F003/F004/F005
F006/F008
F009/F019
K001
K037
K048/K049/K050
K051/K052
K061/K062
K087
U007
U036
U044
U051
U092
U151
U188
U220
U223
U230
U239
U240
U242
P012
Description of Waste
Miscellaneous hazardous waste
Igni table waste
Corrosive waste
Reactive waste
Reactive plus petroleum refining
waste
Arsenic waste
Barium waste
Cadmium waste
Chromium waste
Lead waste
Mercury waste
Endrin waste
Lindane waste
2,4-D waste
Spent halogenated solvents
Spent nonhalogenated solvents
Treatment sludges/solutions
Wood preservation waste
Pesticide waste
Petroleum refining waste
Iron and steel waste
Coking waste
Acrylamide
Chlordane
Chloroform
Creosote
Dimethylamine
Mercury
Phenol
Toluene
Benzene
2,4,6-Trichlorophenol
Xylene
2,4-D
Pentachlorophenol
Arsenic trioxide
Landfilled
109,624
745,042
4,155,313
273,826
1 1 ,782,274
35,996
1,757,595
3,145,664
701,601
9,320
4,119,067
333
42,858
172,817
262,496
929,108
809,697
543,140
16,853,317
9,563,800
705,702
225
508
959
486,615
2,020
500
9,200
617
500
19
3,073
2,524
1,022
Amount (pounds^
Tank Treatment Land Application
399,835
1.448 2,033,998
9,806,450
54,330
13,195
187,317
822,264
20,086 9,470,441
338,760
500
Source: 1985 Annual Report
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29
PCB waste processing and disposal operations included storage,
treatment and disposal. Any storage and treatment of liquid PCBs is operated
by PPM, Inc., a subsidiary of USPCI. PCB liquids are detoxified and shipped
offsite as a fuel oil blend. As a result of the detoxification process, a spent
caustic solution is generated that is used by USPCI for waste neutralization.
PCB solids (transformer carcasses, contaminated debris, etc.) are landfilled
onsite.
Surface Impoundment
USPCI uses the surface impoundment for liquid hazardous waste
storage prior to land treatment. USPCI stores waste water from refinery
processes in the impoundment and removes oil from the top, as necessary. The
surface impoundment storage capacity is about 6.2 acre-feet (about 2 million
gallons).* The surface impoundment is subject to the ground-water monitoring
requirements of the UHWR interim status regulations.
The USPCI site is underlain by lakebed sediments (primarily silty clay).
The surface impoundment is mostly above grade with the bottom about 2 feet
below grade. USPCI constructed the embankment in 1982 from soil obtained
from a nearby ridge consisting of a mixture of sands, silts and clays. The
Company added and tested a 3-foot clay liner, leachate detection system and
synthetic liner in 1984 and 1985.
The clay liner was constructed with clay from borrow areas on the
northwest portion of the property. The clay was compacted, but no permeability
tests were done.
The leachate detection system was constructed by placing 8-inch-
diameter pipe with 1/4-inch holes on 1-foot centers in a gravel sump [Figure 4].
This system was originally designed as a gravel relief vent system and was
modified for use as a leachate detection system.
,4s reported in a USPCI September 28, 1984 transmittal regarding Surface
Impoundment A, Exhibit C
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30
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SECTION B - B*
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31
The synthetic liner is 100 mil High Density Polyethylene (HOPE).
Compatibility testing conducted by consultants indicated the HOPE liner was
compatible with solutions similar to refinery wastewater; USPCI proposed
impounding refinery wastewater (EPA hazardous waste numbers K048-K051)
in this impoundment. The State approved of this impoundment for storage of
petroleum refinery wastes on April 2, 1985.
The impoundment is square with a finished bottom width of 115 feet, 3:1
side slopes and a total depth of 14 feet (2 feet of freeboard are required, thus,
useable depth is 12 feet). The dike crest is about 14 feet wide and the outer
embankment has a 2:1 slope. The dike top and outer embankment were
covered with a minimum of 4 inches of gravel. The impoundment bottom is
sloped toward the leachate collection system. Waste levels in the impoundment
are mostly above ground and always above the water table.
The surface impoundment has been in service since mid-1985. During
the Task Force inspection, more than a 2-foot freeboard was observed.
Freeboard measurements are referenced by marks on a pump track for raising
or lowering the pump used to remove liquid from the impoundment.
Landfills
Although there were four landfills at the USPCI site, only two were
hazardous waste landfills (landfill cells 1 and 2) and subject to the RCRA interim
status ground-water requirements. One landfill (industrial waste landfill cell)
was used for burial of non-RCRA industrial waste and one landfill (landfill cell X)
was used for burial of PCB solid waste.* Total capacity for the four existing
landfills was approximately 275 acre-feet.
USPCI operates the landfills using a progressive slope or ramp method
of landfilling where each layer is completed and compacted and the landfill is
filled from the bottom up. Each landfill cell will be closed and capped after the
cell is full. Landfill cell 1 was almost full at the time of the inspection. The first
A fifth landfill cell (landfill cell 3), for burial of hazardous waste, was under construction during
the Task Force inspection.
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32
waste was placed in landfill cell 1 in March 1982; all other landfills went into
service after that date.
Landfill Cell 1
Landfill cell 1 is located in the middle of the northern half of the USPCI
facility. The landfill was completed and began accepting waste in March 1982.
The landfill was expanded in 1984 by adding 10 feet in height to the cell. Total
capacity of the expanded cell is about 29 acre-feet.
The landfill was constructed so that all waste is buried above grade.
Existing soil (5 feet) was excavated for later replacement with compacted clay.
At the bottom of the excavation, three gas relief trenches were dug. These
trenches transect the landfill cell under the clay liner. The trenches consist of
gravel surrounded with geotextile fabric and vented by vertical riser pipe. The
embankment was constructed with material taken from the same ridge of sands,
silts and clays, as for the surface impoundment. A 5-foot clay liner and a gravel
layer for leachate collection and removal were installed after the embankment
was constructed.
The ground surface to receive embankment material was scarified to a
depth of about 8 inches and recompacted. Embankment and backfill material
were monitored for moisture content before compaction. Moisture content
varied more than original design specifications, but desired compaction
densities (95% Standard Proctor) were almost always achieved.
The clay liner was constructed with clay from a nearby borrow area that
complied with the Unified Soil Classification of CL materials with an additional
requirement that at least 80% of the material pass through a No. 200 sieve.
Liner material moisture content also varied but desired compaction densities
were achieved except for one test which indicated 94% instead of 95% of
Standard Proctor. Clay used for the cell 1 liner may not have met permeability
standards. Although permeability tests conducted on two laboratory samples
indicated the clay liner has a permeability less than 1 x 10~7 cm/sec, more
comprehensive field and laboratory testing on clay from the same area
indicated permeability was greater than 1 x 10"7 cm/sec and sodium
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33
hexametaphosphate had to be added to the clay to meet permeability
standards.
The top of the clay liner (bottom of the landfill) was crowned 6 inches to
provided drainage to the edges for removal of rainfall. A 6-inch-thick layer of
uniform size gravel was placed over the clay liner to serve as a leachate
collection and removal system; however, no sumps or risers were installed to
facilitate leachate removal.
Landfill cell 1 is rectangular with finished bottom dimensions of 100 feet
by 300 feet, 3:1 side slopes and a total depth of 22 feet. The dike top is about
18 feet wide and the outer embankment has a 2:1 slope. The dike top and outer
embankment are covered with gravel.
Landfill cell 1 has received various solid, semi-solid and sludge type
waste. Table 4 presents waste placed in both landfill cells 1 and 2. During the
Task Force inspection, landfill cell 1 was almost full. USPCI officials indicated
they were waiting for an appropriate waste such as contaminated soil to
completely fill landfill cell 1 and provide a suitable base for the cap to be
installed during closure of the unit.
Landfill Cell 2
Landfill cell 2 is located directly north of landfill cell 1 and shares a
common side. The landfill was completed in 1984 and 1985. Waste was
landfilled in cell 2 beginning in September 1985. Total capacity of landfill cell 2
is about 62 acre-feet.
The landfill was constructed so that all waste is buried above grade. The
natural ground surface was scarified to a depth of 8 inches and recompacted.
The new embankment was benched into the existing embankment where
landfill cell 2 abuts landfill cell 1. The embankment was constructed similarly to
the landfill cell 1 embankment with material from a nearby borrow area. The
liner, in ascending order, consists of a 2-foot compacted clay liner, a 60-mil
HOPE liner, drainage net, a 60-mil HOPE liner, drainage net, non-woven
geotextile fabric and a 2-foot protective sand layer. The leachate
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34
collection/detection system consists of pipes and four secondary or detection
sumps between the synthetic liners and pipes, and four primary or collection
sumps on top of the synthetic liners [Figures 5 and 6].
The clay liner was constructed with clay from a nearby borrow area. To
meet permeability requirements of 1 x 10~7 cm/sec or less, sodium hexameta-
phosphate was added to the clay. Permeability tests in the field (7.6 x 10~9 to
7.6 x 10"8 cm/sec) and laboratory (2.1 x 10~8 to 4.5 x 10~8 cm/sec) indicated the
clay liner has permeability less than 1 x 10"7 cm/sec.
The top of the clay liner is sloped radially to the four leachate collection
sumps. The primary leachate collection system is designed to collect any
leachate reaching the bottom of the cell. The secondary leachate detection
system is designed to collect any leachate that has breached the uppermost
synthetic liner. Any leachate collected in the secondary/detection system would
indicate a failure of the uppermost synthetic liner.
Landfill cell 2 is rectangular with finished bottom dimensions of 340 feet
by 375 feet, 3:1 side slopes and a total depth of 16 feet. The dike top is about
12 feet wide and the outer embankment has a 2:1 slope. The dike top and outer
embankment are covered with gravel.
USPCI has placed various waste into landfill cell 2 [Table 4]. During the
Task Force inspection, landfill cell 2 was in service and USPCI was concerned
that leachate had been collected from the secondary leachate detection system
indicating a failure of the upper synthetic liner. The Task Force collected
samples from the secondary leachate detection system for analysis to
investigate this concern.
PCB Landfill Cell X
The PCB landfill cell X is located east of the office in the northeast
quadrant of the USPCI facility. The unit was built in 1985-86 and began
accepting waste in April 1986. The unit is regulated by Federal TSCA
regulations (40 CFR 761) and does not receive hazardous waste. Total
capacity of the unit is 150,000 cubic yards or about 93 acre-feet.
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35
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36
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37
The landfill was constructed so that all waste is buried above grade. The
design is similar to landfill cell 2, however cell X has a 3-foot compacted clay
liner. Most of the waste for cell X comes from PPM, Inc. and includes PCS
solids, transformers and debris. During the Task Force inspection, this unit was
in service.
Industrial Waste Landfill Cell
The industrial waste landfill cell is located near the northwest corner of
the Grassy Mountain facility. The unit was built in 1985 and began accepting
waste in August 1985. The unit is regulated by Utah Solid Waste Regulations
and does not accept hazardous waste. Non-PCB transformers, empty drums,
debris and other non-RCRA waste are landfilled in this unit. No municipal
waste has been accepted to date, but would be if a customer desired. The
rectangular cell has finished bottom dimensions of approximately 150 feet by
1,050 feet. The cell has a single liner and two sumps for collection of fluids.
During the Task Force inspection, the unit was in service and UDH inspections
indicated there was a lot of fluid in this landfill.
Tanks
USPCI operates nine tanks for storage and treatment of RCRA waste.
PPM, Inc. operates another seven tanks for storage and treatment of PCBs at
the Grassy Mountain facility. The RCRA tanks are within the processing area
and surrounded by a clay containment dike. Any leakage from the tanks, piping
and waste transfer operations is collected in runoff control ponds (oil/caustic
storage tanks) or sumps (solvent tanks, acid tank and reaction tank). Tank pads
are either compacted clay or concrete. The processing area has natural
underlying silty clay soil. The PCS tanks are within a smaller separate area with
a clay containment dike. Any leakage from the three storage and three
treatment tanks, piping and waste transfer operations is collected in sumps on
the- concrete tank pads. The one "clean" tank for treated oil (sold offsite) is
located off the concrete pads. A list of existing RCRA tanks, capacity and types
of waste stored is presented in Table 5.
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38
Table 5
EXISTING RCRA TANKS, CAPACITY AND TYPES OF WASTE STORED*
Number of Type/Construction Capacity
Tank Name Tanks Dimensions Materials (Gallons)
Waste oil/caustic
storage tanks
(Tanks 1-5)
12'Dx20'H
VA/C.S
Note:
According to the RCRA Part B permit application
Calculated from dimensions listed on design drawings
D = Diameter
H= Height
VA ป Vertical above ground
HA = Horizontal above ground
VACB = Vertical above ground with cone bottom .
C.S. = Carbon steel
FRP = Fiberglass reinforced plastic
16,000 ea
Waste solvent 2
storage tanks
(Tanks ST1 and
ST2)
Acid waste 1
storage tanks
Neutralization/ 1
reaction tank
8'Dx21'H
10'D x 33'H
10'Dx 16'H
12'Dx20'H
HA/C.S.
VA/FRP
VACB/C.S.
with epoxy
liner
7,500
18,000**
10,000
16,000
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39
Drum Storage Area
The drum storage area consists of two pads with interconnnected curbs.
One pad has a partial roof. The pads are 2400- and 7200-square-feet and were
built in 1982 and 1985, respectively. The pads have 8-inch curbs and concrete
floors, which slope to concrete sumps. The RCRA Part B application lists the
capacity of the pads at 250 and 800 55-gallon drums.
Land Treatment Areas
USPCI operates four land treatment areas for treatment of oily waste
sludges from petroleum refineries and other industries. The four land treatment
areas are designated Areas I through IV and have surface areas of 41, 68, 57
and 40 acres, respectively. A 2-foot dike surrounds the entire land treatment
portion of the Grassy Mountain facility. USPCI installed lysimeters in the
unsaturated zone to monitor soil moisture and four monitoring wells to monitor
ground water. USPCI also collects soil cores to monitor leaching from the land
treatment area.
FACILITY OPERATIONS
Task Force personnel reviewed records of facility operations to identify
any activities that might result in waste releases to ground water. Pre-
acceptance records were evaluated to determine how adequately waste
constituents have been identified in incoming waste loads. Waste tracking
records were evaluated to determine how wastes were handled and whether
waste disposal locations have been properly recorded. These records required
by both State and Federal interim status regulations enable identification of
hazardous waste constituents that could potentially be released from individual
waste handling units.
Surface Impoundment
Two waste streams from petroleum refineries are stored in the USPCI
surface impoundment prior to land treatment. Oil is periodically pumped off the
top of the surface impoundment. Stored waste is pumped to a spreader prior to
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40
land treatment. Freeboard reference marks for the surface impoundment are on
the pump track on the inner face of the surface impoundment. As of
December 31, 1985, the surface impoundment was about half full, containing
about 1 million gallons of waste. During the Task Force inspection, the
impoundment still appeared to be about half full.
Landfills
The present grid system for locating where hazardous waste is buried
began about June 1984. Large maps of the grid system are on the hall walls in
the office/lab building. The drum dock supervisor provides coordinates for
buried drums. Lab personnel and landfill operators cooperate in providing
coordinates for bulk loads.
Waste containing any free liquids is solidified prior to landfilling. USPCI
has used oil field mud tanks, cement mixers and currently uses gondola cars
(like a large dumpster or roll-off box) to mix waste and absorbent material prior
to landfilling. USPCI switched to using gondola cars as mix tanks after the
State complained in a November 14, 1985 memo that cement mixers did not
meet RCRA definition of a tank.
Normally, USPCI uses solidified material and bulk solids for packing
around drums in the progressive slope or ramp method of landfilling used at the
site. With a large contract to landfill over 76,000 drums, USPCI contracted with
another firm to provide a lime slurry to fill spaces around the drums. Old
solidification tanks were used as forms for the lime slurry.
Tanks
Waste is directed to tanks based on the type of waste. Oil and caustic
liquid waste is usually placed in tanks 1 through 5 with caustic waste usually
placed in tank 5 and sometimes in tanks 3 and 4. Oil field wastes for land
treatment are usually stored in tanks 1 through 4 or the surface impoundment.
Acid waste is stored in the acid tank and mixed solvent waste is usually stored
in the solvent tanks (tanks ST1 and ST2). Solvents are usually shipped offsite
for fuel blending. The reaction tank is used for neutralization of acids/bases and
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41
treatment of sulfides. Freeboard in the oil and caustic tanks is manually
measured with a tape measure once a day and after loads are pumped to the
tanks. The solvent tanks are measured before and after each load. The acid
and reaction tanks are not measured directly but a log of specific gravity and
volumes received is kept.
USPCI claims not to have ever had a major spill and that any small spills
or leaks were cleaned up and the debris landfilled. The State did order USPCI
to fix one tank that had settling problems and USPCI complied.
Drum Storage Area
Drummed waste is off-loaded directly to the drum storage area after the
manifest has been checked, a piece count made and manifest information
logged into the computer. The drums are sampled after off-loading at the drum
storage area. Normally, more than 20% of the drums from each waste stream
are sampled. Each drum is checked for free liquids and volume of waste.
Disposition of each drum is recorded on drum disposal logs.
The drum storage area is loosely organized and no attempt is made to
assign a specific location to each drum. Flammable liquids are kept on the
covered drum dock, thus providing shade for these drums. Caustics and
organics are stored on one side of the drum pad and acids are stored on the
other as a method of keeping incompatibles separated.
Acids can be pumped directly to the acid tank. Caustics and solvents are
usually transferred to their respective tanks via a tractor-pulled spreader tank.
Solids and drums containing liquids to be solidified are transferred to the landfill
via front-end loader. Large volumes of liquids may occasionally be pumped to
a USPCI tanker truck for transfer to the designated tank.
Material accumulating in the drum storage area sumps is analyzed for
organic chlorides and usually solidified and landfilled. Records indicate no
previous incidents resulting in potential ground-water contamination from
operation of the drum storage area.
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42
Land Treatment Areas
Oily waste sludges from petroleum refineries and other industries are
applied to land treatment areas by a tractor-pulled spreader. Solids are usually
applied to area 1 by a paddle wheel cart similar to home grass seed or fertilizer
spreaders, only much larger. Unless there is a concern about concentration,
most applications are sequential (e.g., row 1, then row 2, then row 3). A
computer program is used to keep track of amounts applied and cumulative
concentrations of oil and metals.
Wastes have been applied to the treatment areas since April 1982.
Wastes destined for land treatment are usually placed in the surface
impoundment or tanks 1 through 4 prior to application. Gravity separation of oil
is accomplished in the surface impoundment or tanks. Oil is reclaimed from the
tanks/surface impoundments as possible. The USPCI RCRA Part B permit
application specifies the oil content of the residues for land application is
generally 15% by weight or lower. The residue is pumped to the spreader and
applied to the designated row and tilled into the top 7 to 8 inches of soil. A
spring tooth type tiller is used to reduce fines and blowing dust. The land
treatment areas are retilled periodically to aerate the soil and promote microbial
action on the oily waste.
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SITE HYDROGEOLOGY
The USPCI Grassy Mountain Facility lies in the Northern Great Salt Lake
Desert in northwest Utah. The Great Salt Lake Desert has been the subject of
numerous regional geologic and hydrologic investigations done by universities,
the State of Utah and the United States Geological Survey. In addition, USPCI
has initiated onsite geotechnical investigations at the Grassy Mountain facility to
characterize the site hydrogeology. These investigations primarily have been
done by USPCI consultants, Vaughn Hansen and Associates of Salt Lake City,
Utah and Chen and Associates of Denver, Colorado. The investigations
include exploratory drilling, geologic coring, lineament analysis, seismic
studies, aquifer testing and water level analysis.
During the inspection, Task Force personnel interviewed a
representative of Vaughn Hansen and Associates regarding a hydrogeologic
characterization report prepared by his firm, which was submitted by USPCI to
the State and EPA in May 1986.* This report was prepared, as required by UDH
for the Part B application. The following information is largely derived from the
interview and the report.
Salt flats, lake beds of the former Lake Bonneville, alluvial material
(stream deposits) from surrounding mountains and wind-blown sand compose
the sediments of the Great Salt Lake Desert. At the USPCI site, the exposed
sediments are Pleistocene Lake Bonneville and younger sediments. These
sediments consist of calcareous (calcium carbonate) clays, silts and fine to
medium-grained sands. The lakebed sediments are more than 300 feet thick
beneath the Grassy Mountain Facility. The Grayback Hills are east of the
facility. Alluvial deposits from the Grayback Hills coalesce with the younger
lakebed sediments at the base of the Hills. At the western edge of the site, wind
action has formed sand dunes on the surface near some topographic low spots
hereafter referred to as mudflats. These sediment features may affect local
ground-water flow patterns.
USPCI, May 1986. "Response to Federal Ground Water Regulations 40 CFR 270.14(c)
Regarding Grassy Mountain Facility Near Knolls, Utah," Volumes 1 through 3.
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44
Geologic core analyses on two 100-foot and one 300-foot exploratory
borings indicate that quartz and calcareous sands compose most of the layered
sands and silts beneath the ground surface. The May 1986 hydrogeologic
report details each of the sands, silts and clays and the original depositional
environments (e.g., open fresh water, shallow fresh water, saline shallow or
shoreline or paleosoil).
Subsurface profiles, developed from geologic coring information indicate
the upper silty sand (dune) deposits are not continuous across the site. Various
subsurface profiles developed from drilling logs suggest that some of the
deeper sand units do appear to be continuous or nearly continuous across the
site, while other units appear to be discontinuous. The continuous materials
exhibit a slightly westward dip in slope. Some of these layered units apparently
undergo gradational grain-size and compositional changes as they extend
across the site.
HYDROGEOLOGIC UNITS
The upper 25 feet of the deposits contain an unconfined, principal
aquifer, known as the shallow brine aquifer. The elevation of the water table in
the shallow brine aquifer was about 4,229 to 4,233 feet above mean sea level
at the time of the Task Force inspection. Depth to ground water beneath the
facility ranged from about 10 to 30 feet from land surface, depending upon
surface topography.
USPCI consultants state that the shallow brine aquifer contains many
dessication cracks that may be up to 1 inch in width, as close as 1 foot apart,
and as deep as 25 feet. The consultants contend that these cracks substantially
increase hydraulic conductivity within the aquifer and increase its water yield.
The hydraulic conductivity and water yield in the shallow brine aquifer are
greater through the dessication cracks than in the underlying sediments that do
not contain cracks. The consultants state the increased hydraulic conductivity
as the reason this aquifer is identified as the "uppermost aquifer" for regulatory
purposes. Below the upper 25 feet, the dessication cracks are absent or less
prevalent, thus, they are less a factor in water movement.
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45
The May 1986 hydrogeologic characterization report states that regional
recharge to the shallow brine aquifer occurs primarily through lateral ground-
water flow from adjacent sediments near the Grayback Hills and upward flow
from deeper sediments. To a much lesser extent, recharge may occur through
infiltration from precipitation and storm runoff.
The sediments below the shallow brine aquifer have poor water yield
and variable water quality depending upon the chemical composition of the
depositional layer, the original depositional environment and patterns of
ground-water discharge. USPCI personnel measured specific conductance
values on the order of 90,000 to 100,000 micromhos per centimeter (jimhos/cm)
during the July 1986 sampling. None of this ground water is used as a drinking
water supply, and it has not been classified under the Safe Drinking Water Act.*
GROUND-WATER FLOW DIRECTION AND RATES
The hydraulic gradient in the shallow brine aquifer across the site has a
very shallow apparent slope to the west." Ground water flows westward from
the Grayback Hills toward the sand dunes and mudflats. Consultants'
piezometric (water level) contour data indicate that in the vicinity of the sand
dunes (located just east of the western mudflats) the gradient in the shallow
brine aquifer steepens as ground water flows beneath the dunes toward a
western mudflat. Near the Grassy Mountain Facility, the flow direction diverges
toward each of three major depressional mudflats located to the south, west and
northwest of the facility. Historical piezometric data suggest that locally there is
decreasing hydraulic head with depth (net downward flow) beneath the facility
and increasing head with depth (net upward flow) beneath the sand dunes and
western mudflats.
USPCI consultants' estimation of ground-water flow velocity may be
lower than the actual ground-water flow velocities as a result of overestimating
porosity. They report the rate of ground-water flow across the site to be about
The Safe Drinking Water Act (42 U.S.C.A. ง 300f et seq.) defines an underground source
of drinking water to be an underground water which supplies or can reasonably be
expected to supply any public water system.
Based on June 1986 measured water levels (see Figure 6).
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46
0.6 feet per year.* The formula used by the consultants to compute ground-
water flow velocity was:
V = KL where
n
V = velocity of ground-water flow
K = hydraulic conductivity
I = hydraulic gradient
n = porosity of the porous media
The consultants used porosity values of 30% and 66%, water level
contours developed in January 1986 for the hydraulic gradient, and values for
hydraulic conductivity from field and laboratory testing. The porosity values of
30% and 66% are within published porosity ranges for sands and clays
[Table 6].
Table 6
RANGE OF VALUES OF
POROSITY IN
UNCONSOLIDATED SEDIMENTS*
Porosity n(%
Gravel 25-40
Sand 25-50
Silt 35-50
Clay 40-70
Source: Freeze and Cherry, 1979
The consultants values used for computing ground-water flow velocity
are presented in Table 7. The 66% used to compute the flow rate of about 0.3
feet per year is too high because it represents total porosity, not all of which
would be available for fluid flow. Using total porosity results in an
underestimated value for ground-water flow velocity.
May 1986 Hydrogeologic Characterization Report
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Table 7
GROUND-WATER FLOW VELOCITY COMPUTED
BY USPCI CONSULTANTS
K ft./sec.
4.1 x10'5
4.1 x10"5
l%
0.014
0.014
n%
30
66
V ft/year
.6
.27
Several qualifiers apply to the computation in Table 7. First, the K value
used is the average of K values measured in six wells, some of which are nearly
a mile apart. Second, the K values were derived from single-hole slug tests in
each well and at best, represent ground-water conditions within a few feet of the
well tested rather than over a broad area. Third, a steeper gradient would
increase flow velocity. The Task Force computed a range of hydraulic gradients
from 0.02 to 0.29%, using June 1986 water level data. A gradient as high as
0.2% would increase the computed flow velocities to about 9 and 4 feet per year
for values of n = .3 and n = .66, respectively. Additionally, the desiccation
cracks in the shallow brine aquifer and any sand lenses in the sediments would
be preferential ground-water flow paths. The May 1986 hydrogeologic report
does not calculate ground-water flow velocity using the effective porosity of
sand (i.e., a lower value of porosity that represents a volume of void space
actually available for ground-water flow).' For all these reasons, the Task Force
believes ground-water flow velocity at Grassy Mountain could range up to one
and perhaps two orders of magnitude above the values in Table 7.
The loading activities of building the berms surrounding landfill cells 1
and 2 and filling the cells with waste materials appear to have altered the
ground-water flow patterns in the vicinity of these disposal units. Consultants to
USPCI state that the loading at the surface has caused sediment compaction
immediately beneath the landfill cells, so that the dessication cracks seal under
the weight and no longer serve as primary avenues of ground-water flow. As a
Some void space in earth materials is occupied by air and fluids held by surface tension.
This void space is unavailable for transmitting fluids and should be subtracted from the
porosity (total void space) value, leaving an estimate of what is known as "effective porosity"
(i.e., that pore space in earth materials capable of transmitting fluids).
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48
result, sediment permeability beneath the cells decreases. The Task Force
agrees with this conclusion.
The loading of the landfill cells and resultant compaction has caused a
rise in ground-water pore pressure beneath the cells. USPCI consultants
contend that the rise in pore pressure is indicated by unusually high ground-
water levels in the vicinity of the cells and normal levels elsewhere on the site.
The effect of elevating the water table is the induction of a slightly steeper
hydraulic gradient around the cells (i.e., a ground-water mounding effect). The
"mounding" should not affect background wells at USPCI because the effect is
slight and the background wells are several thousand feet away. The Task
Force agrees that this effect should equilibrate and a shallow gradient should
be restored once surface loading has ceased.
USPCI needs to survey the monitoring wells regularly to provide a basis
for reliable water level measurements. The very shallow gradient necessitates
careful piezometric analysis. The Task Force was unable to verify that water
levels in monitoring wells MW-13 through MW-17 might be unusually high
because these wells, constructed in the landfill berm, had settled and had not
been resurveyed. Consequently, the accuracy of water levels measured in
these wells is questionable. Water level elevations measured by the Company
during the Task Force inspection appear in Figure 7.
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M W 7
4229.4
ACCESS RCAO,
M W 1 4 H
MW-ll .
4233.3 4232.2
4233.2
MW-I5
4233.6 ,
MW-16 !
4233.4
MW-17
4233.1
M W 3
4232.6
MW-9 !
4233.0
LAND TREATUENT AREA II
IANO TREATUENT ABEA I
MW-20
423Z.7
LAND TREATUENT AREA III
Approximate Scale
LAHO TREATMENT AREA IV
600
300
M o n i t
0
o r i ng
600
Well
Feet \ , '
MW/8 MW-1
4231,4 4232.7
Figure 7. Water Level Elevations
(feet above mean sea level)
June 1986
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GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS
This section is an evaluation of the interim status monitoring program at
Grassy Mountain between March 1982 and June 1986, the time of the Task
Force inspection. Table 8 presents a brief regulatory history with respect to
ground-water monitoring. The section also addresses the following topics:
Regulatory requirements
Ground-water sampling and analysis plan
Monitoring wells
Sample collection and handling procedures
Ground-water Quality Assessment Program
Prior to 1986, the effort to collect background ground-water quality data
identified continual problems stemming from the inadequacies in sampling and
analysis, the nature of the saline aquifer, and the inappropriateness of certain
analytical methods for saline ground-water samples. UDH had to re-evaluate
the background water quality characterization several times in the period
between 1982 and 1986 in an effort to obtain reliable ground-water quality data.
In 1983, UDH determined that previous ground-water quality analyses for
the Grassy Mountain facility did not accurately depict background water quality
conditions. UDH ordered the data collection for background water quality to be
restarted. The continuing effort to obtain meaningful background data resulted
in quarterly monitoring at Grassy Mountain through the end of 1985. In 1986,
USPCI began a new period of data collection for background water quality
comparisons using additional wells.*
As a result of triggering ground-water assessment under UHWR 7.13.4
(40 CFR 265.93) in October 1985, the Grassy Mountain Facility also began
quarterly assessment monitoring during the first quarter of 1986. EPA and UDH
requested that USPCI analyze for organic parameters in addition to those
Phone conversation with Roy Murphy, USPCI, February 11, 1987
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Table 8
REGULATORY AUTHORITY, REQUIREMENTS AND EVENTS DURING INTERIM STATUS
Date
Action
December 1980
March 1982
1983
September 1984
Februarys, 1985
March 5,1985
June 19, 1985
October 2, 1985
October 21, 1985
October 31, 1985
Novembers, 1985
November 13, 1985
Utah received RCRA interim authorization.
The Utah Hazardous Waste Rules (UHWR) became effective Decem-
ber^, 1980.
Grassy Mountain Facility began waste management activities.
Utah Department of Health (UDH) determined that previous ground-water
analyses for the Grassy Mountain Facility did not accurately depict
background water quality conditions.
UDH ordered the data collection for background water quality to be
restarted.
Utah received final RCRA authorization, with exception of authorization
for the Hazardous and Solid Waste Amendments of 1984 (HSWA). EPA
administers HSWA in Utah.
UDH issued a Notice of Violation (NOV) and Order of Compliance
(NOV/CO No. UTD9931301748) citing USPCI for having inadequate
placement of monitoring wells and for not having an acceptable sampling
and analysis plan.
USPCI agreed to: (1) prepare a hydrogeologic survey at the site, (2)
locate new monitoring wells, (3) establish new ground-water monitoring
procedures and (4) provide employee training on implementing the
ground-water monitoring procedures.
USPCI submitted a proposed plan for the hydrogeologic investigation to
EPA.
UDH and USPCI signed a Stipulation and Consent Order in which USPCI
was ordered to install a mutually-agreed-upon ground-water monitoring
system and develop and follow a sampling and analysis plan by
Novembers, 1985.
EPA notified UDH that total organic carbon (TOC) in well MW-3 showed a
statistically significant increase. EPA determined that USPCI should be in
assessment monitoring under UHWR 7.13 (40 CFR Part 265.93).
UDH told USPCI to submit a water quality assessment monitoring
program.
USPCI submitted a sampling and analysis plan to UDH.
USPCI notified UDH that the Grassy Mountain facility would enter ground-
water assessment monitoring in conjunction with the sampling and
analysis plan.
UDH formally requested the (overdue)1 assessment plan. USPCI did not
submit the plan.
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52
Table 8 (cont.)
REGULATORY AUTHORITY, REQUIREMENTS AND EVENTS DURING INTERIM STATUS
Date
Action
January 1986
February 21, 1986
USPCI restarted background ground-water quality monitoring, including
newly-installed monitoring wells (MW-9 through MW-20).2
UDH requested the assessment plan again.
UDH also identified certain information related to ground water that
should have been forthcoming in USPCI's Part B resubmission due in
late March 1986. This information was specifically described in a letter
from EPA to UDH dated February 4,1986.
USPCI submitted a hydrogeologic characterization report on Grassy
Mountain Facility.3 USPCI still had not submitted an assessment plan, as
required by UHWR7.13.4.4
1 UHWR 7.13.4 (40 CFR 265.93) requires that the owner/operator develop and submit an assessment
plan within 15 days of notifying the regulatory authority of a statistically significant increase in
indicator parameters.
2 Phone conversation with Roy Murphy, USPCI, February 11, 1987.
3 USPCI, May 1986, "Response to Federal Ground-Water Regulations, 40 CFR 270.14(c), Regarding
Grassy Mountain Facility Near Knolls, Utah,'Volume 1-3.
4 EPA and Utah State Regulations are cross-referenced in Table 8.
May 1986
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53
parameters required by UHWR 7.13.3 (40 CFR 265.92). The 1986 quarterly
sampling parameters appear later in this report in a section entitled, "USPCI
Sample Collection and Handling Procedures."
Also in early 1986, USPCI began sampling a number of new monitoring
wells installed in response to an October 1985 Stipulation and Consent Order
from UDH. The existence of these new wells is one reason USPCI restarted
background water quality monitoring in 1986.
EPA and UDH agreed to allow USPCI to submit the results of the
hydrogeologic investigation as late as March 1986, so that USPCI could
concentrate on installing monitoring wells in order to meet a statutory
Novembers, 1985 deadline for certifying ground-water compliance under 40
CFR Part 265. USPCI submitted the hydrogeologic characterization report to
UDH in May 1986.
REGULATORY REQUIREMENTS
The State interim status ground-water monitoring requirements (UHWR
7.13) are equivalent to the RCRA interim status requirements contained in 40
CFR Part 265, Subpart F; there are no substantive differences. Regulation
counterparts are shown in Table 9.
Table 9
STATE AND FEDERAL COUNTERPART
INTERIM STATUS REGULATIONS (1986)
RCRA Regulation
Subpart Title* UHWR (40 CFR Part)
Applicability
Ground-Water Monitoring System
Sampling and Analysis
Preparation, Evaluation and
Response
Recordkeeping and Reporting
7.13.1
7.13.2
7.13.3
7.13.4
7.13.5
265.90
265.91
265.92
265.93
265.94
Subpart titles are the same in both the State and RCRA regulations.
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54
GROUND-WATER SAMPLING AND ANALYSIS PLAN
This section evaluates the completeness and adequacy of the USPCI
sampling and analysis plan. USPCI is required by interim status regulations in
UHWR 7.13.3 (40 CFR 265.92) to develop and follow a sampling and analysis
plan. This plan must contain procedures and techniques for: (1) sample
collection, (2) sample preservation and shipment, (3) analytical procedures and
(4) chain-of-custody control.
Prior to November 1985, USPCI did not have an interim status ground-
water sampling and analysis plan at the Grassy Mountain facility, as required by
UHWR 7.13.3. Prior to November 1985, USPCI had submitted a sampling and
analysis plan with their Part B Application to UDH and EPA. Both agencies
determined that the submitted plan was deficient and did not meet regulatory
requirements for either interim status or the permit. USPCI submitted a
November 1985 plan (the plan) to UDH and EPA in response to the October
1985 Stipulation and Consent Order issued by UDH. Company personnel told
the Task Force that this November plan was the interim status sampling and
analysis plan.
USPCI personnel also told the Task Force that they first used the
November 1985 plan the first quarter of 1986. However, the individual
responsible for sampling at the Grassy Mountain Facility during the first and
second quarters of 1986, told Task Force personnel he had not seen that plan
until commencement of the Task Force inspection (June 1986). No plan had
been used at Grassy Mountain prior to that.
Elements of the USPCI Sampling and Analysis Plan
The November 1985 sampling and analysis plan contains procedures for
the following elerrrentsr---
Measuring depth to water
Well evacuation
Sample collection and field measurements
Collecting field blanks
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55
Preservatives
Analytical procedures, including laboratory quality assurance and
quality control
Chain-of-custody
Shipping
The methods in the plan for measuring static water levels are acceptable
except for the provision that measurement accuracy be obtained within 1/32 of
an inch (about 0.003 feet). This accuracy is unrealistic and cannot be obtained
with the electric water level indicator used by the facility. A more obtainable
value is 0.01 foot with a steel tape or 0.1 foot with an electric tape.
Methods in the plan for purging the well are acceptable except for the
example calculation on how to calculate purge volumes. This calculation is
incorrect in that it indicates a 2-inch (inside diameter) pipe holds 11 milliliters
(ml) of water per inch length of pipe. The correct volume is approximately 51 ml
per inch.
The example table in the plan showing volume of water in MW-8 per inch
of water column needs to be removed or corrected to reflect accurate numbers.
If the table is retained, the total depth of MW-8 should appear so that total water-
column volume may be calculated. Furthermore, using well MW-8 as an
example for calculating purge volumes is inappropriate, as USPCI no longer
samples this well.
The methods in the plan for field sampling are acceptable, with the
exception of waiting until all the wells are purged before sampling begins. At
the Grassy Mountain facility, purging all the wells takes 24 hours or more.
Although some lag time may be necessary for slowly recharging wells, those
that recharge quickly should be sampled as soon as possible in order to obtain
as fresh a sample from the aquifer as possible. Allowing water in the well to
recharge, stagnate and have prolonged contact time with air and the well
casing needs to be avoided so that the sample is representative of the quality of
water flowing through the aquifer.
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56
The provisions in the plan for field blanks need to include instructions
that blanks for sample parameters that are preserved in the field be preserved
in the same manner. Otherwise the method for field blanks is acceptable.
The provisions in the plan for preservatives, chain-of-custody and
shipping are also acceptable.
The plan includes a four-page, unreferenced list of Appendix VIII
compounds. Laboratory* personnel were unable to explain the source of this
list or the reason for it in the plan. The laboratory does not analyze for each of
the parameters listed, neither does the plan indicate which of these parameters
the laboratory does analyze. Only the list of compounds actually analyzed for
should appear in the sampling and analysis plan.
The plan does not list appropriate analytical methods for specific organic
analyses to be done. Only one analytical method for each compound should be
listed in the plan and only that method should be followed, thereby allowing
statistical comparison of analytical data.
The plan does not identify appropriate detection limits for all compounds
which NAL is capable of achieving. Appropriate, achievable detection limits
need to be presented.
Sampling Records Purina Interim Status
USPCI did not follow the November 1985 sampling and analysis plan
with respect to sampling records in 1986. USPCI began keeping more
thorough sampling records beginning with the first quarter of 1986, although not
all of the sampling activities were done for every monitoring well. Task Force
personnel were able to verify that water level measurements, quarterly
sampling, replicate field measurements and wellhead inspections had been
done during the first and second quarters of 1986, but not at every well for each
sampling. Most of the field procedures were consistent with the 1985 sampling
and analysis plan, even though the sampler had not seen that plan.
National Analytical Laboratories (NAL), Tulsa, Oklahoma.
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57
The sampling and analysis plan states that 19 monitoring wells (MW-1
through MW-7, MW-9 through MW-20) would be sampled quarterly for 1 year,
beginning with the first quarter of 1986; however, field records for 1986 do not
show that all 19 wells were sampled according to the prescribed schedule.
USPCI no longer samples MW-4. Sampling records indicate that MW-7 and
MW-6 were not sampled in the second quarter of 1986. USPCI indicated MW-7
would not have been sampled in June 1986 had the Task Force not selected it
for sampling (USPCI credited split samples from the June Task Force inspection
toward their third quarter sampling event). MW-3 was physically removed in
August 1986 and replaced with a new well, MW-26.
The sampling and analysis plan also states that USPCI would measure
water levels in the monitoring wells each month for 1 year, beginning
December 1, 1985. Field sampling records for December 1985 and the first
half of 1986 do not indicate that USPCI measured all the water levels according
to the prescribed schedule [Table 10].
Table 10
WATER LEVEL MEASUREMENTS OMITTED
December 1985 - June 1986
Year Month Well
1985 December MW-1 through MW6,
MW-16, MW-18, MW19
1986 January MW-9 through MW12,
MW-17 through MW-20
March All Wells
Prior to the implementation of the interim status sampling and analysis
plan in 1986, a few scattered and incomplete sampling records were found in
Company files, but no complete continuous sampling records were found.
USPCI indicated that several individuals had been doing the sampling and that
there had been no continuity of personnel responsible for sampling. Company
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58
records reflected this situation. As a result of this poor documentation, the Task
Force was unable to verify the field sampling procedures prior to 1986 for the
purpose of determining regulatory compliance. Records of analysis and water
surface elevations required by UHWR 7.13.3 (40 CFR 265.92) must be
maintained for compliance with UHWR 7.13.5 (40 CFR 265.94).
MONITORING WELLS
At the beginning of the inspection, USPCI personnel indicated which
wells at Grassy Mountain were included in the interim status ground-water
monitoring system. The monitoring system was evaluated for well construction
and for numbers and locations of wells. Well construction for newer wells was
determined to be acceptable, whereas, the complete construction details for
older wells could not be determined due to insufficient information. Placement
of some of the older wells was not satisfactory. The selected locations of newer
wells MW-9 through MW-20 are satisfactory. These issues are discussed later
in this section.
Evaluation of well construction included determining whether
construction materials and well design met regulatory requirements in UHWR
7.13.2 (40 CFR 265.91). Evaluation of well locations included determining
whether or not the monitoring system met requirements of UHWR 7.13.2.
At the time of the inspection, USPCI personnel could not identify
precisely which wells were included in the interim status ground-water
monitoring program and which wells were being used for other purposes.
USPCI changed the list of wells they sample from those identified in the
November 1985 sampling and analysis plan. The sampling and analysis plan
needs to be updated to reflect any changes and USPCI needs to notify the
State of any well additions or deletions. The USPCI hydrogeologic
characterization report, submitted in May 1986, indicates that older wells MW-4,
MW-6, MW-7 and MW-8 are no longer used for ground-water sampling but
serve only to monitor piezometric surfaces. USPCI personnel indicated that
only MW-4 and MW-8 are no longer sampled but did not say why.* The
Telephone communication with Lee O'Laughlin, USPCI, Novembers, 1986.
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59
November 1985 sampling and analysis plan states that USPCI samples MW-4,
MW-6 and MW-7. USPCI needs to clarify these discrepancies and notify UDH
of which wells are included in interim status ground-water monitoring.
The entire ground-water monitoring system at the Grassy Mountain
Facility consisted of 23 completed monitoring wells, designated as MW-1
through MW-23 [Table 11, Figure 8]. MW-1 through MW-8 were completed in
1981 and, until the first quarter of 1986, served as the only RCRA monitoring
wells. USPCI ceased sampling MW-8 during the fourth quarter of 1985. MW-9
through MW-20 were completed in late 1985 and became part of the RCRA
interim status monitoring system starting the first quarter of 1986.
In 1986, wells MW-21 through MW-23 were drilled in order to monitor the
PCB landfill X regulated by the Toxic Substances and Control Act (TSCA) and
EPA. USPCI samples MW-21 through MW-23 as part of the interim status
monitoring program. Also in 1986, the State requested USPCI to install MW-24
and MW-25 at specific locations east of landfill cell 2 in order to confirm or refute
the suspicion that landfill cell 2 was leaking. MW-24 and MW-25 were not in
service in time for the Task Force inspection (June 1986).
Well Construction
The driller's construction summary is insufficient to determine that the old
monitoring wells, MW-1 through MW-7, were properly constructed for
compliance with UHWR 7.13.2 (40 CFR 265.91). The construction design and
materials for the new monitoring wells MW-9 through MW-23 are acceptable.
Information on well construction was derived primarily from the May 1986
hydrogeologic report which includes general summary descriptions from the
drilling company for MW-1 through MW-7 and well design and construction
specifications for MW-9 through MW-20. No construction specifications for MW-
8 were provided. Information on MW-21 through MW-25 was obtained directly
from USPCI. Well specifications for MW-1 through MW-25 appear in Table 12.
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60
Table 11
USPCI INTERIM STATUS MONITORING WELLS
June 1986
Well
Number
MW-1
MW-2
MW-3
MW-4*
MW-5
MW-6**
MW-7*
MW-8*
MW-9
MW-10
MW-11
MW-1 2
MW-1 3
MW-1 4
MW-1 5
MW-1 6
MW-1 7
MW-1 8
MW-1 9
MW-20
MW-21*"
MW-22***
MW-23***
USPCI
Designation
Upgradient
Upgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Upgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Upgradient
Downgradient
Downgradient
Downgradient
Waste Management
Unit Monitored
Landfill cell 1
Land treatment area
Land treatment area
Surface impoundment
Surface impoundment
Surface impoundment
Landfill cell 2
Landfill cell 2
Landfill cell 2
Landfill cells 1 & 2
Landfill cell 1
Land treatment area
Land treatment area
Landfill cell X
Landfill cell X
Landfill cell X
In practice, USPCI does not sample MW-4, MW-7 and MW-8, but
measures only water levels in these wells.
MW-6 is downgradient from the land treatment area and upgradient
from the industrial landfill.
Wells MW-21, MW-22 and MW-23 monitor a PCB landfill regulated
by the Toxic Substances Control Act (TSCA), 40 CFR 761. These
wells were sampled as part of the interim status program during the
Task Force visit.
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61
IMPOUNDMENT^
r-MW-12iซ
LANOFIUl
MW-22
CELL X
MW-23
CONTROL
POND'
ACCESS ROAD
MW-9
LAND TREATMENT AREA I
LAND TREATMENT AREA II
A A
LAND TREATMENT AREA III
ILANO TREATMENT AREA iv
Approximate Scale
600 300 0 600 Feet
Monitoring Well A Lysimeter
Figure 8. Monitoring Well and Lysimeter Locations
June 1986
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62
Table 12
CONSTRUCTION SPECIFICATIONS FOR MONITORING WELLS
USPCI Grassy Mountain Facility
As-Built
Top of Casing
Cap Elevation
Well (ft. MSL)1
MW-1 4240.03
MW-2 4240.76
MW-3 4244.35
MW-45 4252.54
MW-5 4257.32
MW-65 4262.34
MW-75 4249.09
MW-85 4244.04
MW-9 4238.65
MW-10 4242.82
MW-11 4242.94
MW-1 2 4243.26
MW-1 3 4262.65
MW-1 4 4262.25
MW-1 5 4262.46
MW-1 6 4262.03
MW-17 4263.18
MW-1 8 4249.57
MW-1 9 4247.65
MW-20 4238.16
MW-21 4241 .76
MW-22 4241 .34
MW-23 4241 .92
MW-24
MW-25
Depth to Static Water
Water Level Elevation Total Depth
(ft.)2 (ft. MSL)3
7.3 4232.7
8.5 4232.3
1 1 .8 4232.6
20.4 4232.1
26.9 4230.4
32.8 4229.5
19.7 4229.4
1 1 .6 4232.4
5.7 4233.0
10.6 4232.2
10.7 4232.2
10.6 4232.7
29.4 4233.3
29.1 4233.2
29.0 4233.6
28.6 4233.4
30.1 4233.1
17.5 4232.1
15.6 4232.1
5.5 4232.7
9.4 4232.4
9.0 4232.3
9.6 4232.3
1 USPCI "Response to Federal Ground-Water Regulation, 40
Utah, " May 1986 submittal;
feet above mean sea level.
2 Measured on June 23 through 24, 1986 during Hazardous
0. 1 foot
Approximate
Perforated
Interval
(ft.)' (ft. to ft. MSL)
14
14
18
40
30
39
34
15.5
19.3
19.7
18.66
40.3
41 ,27
39.8
40.5
27.1 6
26.46
14.3e
18.8
18.5
18.9
CFR 270.14(c) Regarding
4236-4226
4237-4227
4236-4226
4223-4213
4237-4227
4233-4223
4225-4215
4234.4224
4234-4224
4234-4224
4234-4224
4233-4223
4233-4223
4232-4222
4233-4223
4234-4224
4231-4221
4232-4222
4235-4225
4234-4224
4234-4224
4234-4224
4234-4224
4234-4224
Grassy Mountain
Waste Ground-Water Task Force inspection;
Bottom of
Casing
Elevation
(ft. MSL)
4226.03
4226.76
4226.35
4212.54
4227.32
4223.34
4215.09
4223.15
4223.52
4223.24
4223.3
4222.1
4221 .95
4221 .26
4222.23
4222.68
4220.1
4220.6
4224.1
4223.1
4223.1
4223.1
4223.0
4223.0
Facility near Knolls,
rounded to nearest
3 Rounded to nearest 0. 1 foot
4 Source: USPCI sampling personnel's field records; May 1986 submittal
5 Piezometric levels only
6 Back calculated from water level records
7 Back calculations from water level records indicate this well is 39.6 feet deep. USPCI was unable to provide an explanaton for
this discrepancy
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63
The Task Force asked for and did not receive any detailed drilling or
construction logs for monitoring wells MW-1 through MW-7. Well completion
information from the driller's summary provided in the May 1986 hydrogeologic
report was limited to drilled depth, casing length, perforated interval, gravel
pack interval and casing materials. According to the driller's summary, wells
MW-1 through MW-7 are each cased with 4-inch polyvinylchloride (PVC) casing
that extends approximately 2 feet above the land surface. A 4-foot length of
8-inch steel casing protects the PVC casing at the wellhead and extends
approximately 2.5 feet above ground surface. The gravel pack around the
screen extends to a height of 2 feet above the screen. A bentonite pellet seal
was placed in the annular space from the top of the gravel pack to ground
surface. This information is insufficient to document compliance with UHWR
7.13.2 (40 CFR 265.91). Additional information that is needed includes, but is
not limited to:
The type and grain size distribution of the gravel pack
The size of screen openings
The casing joint fittings (i.e., are they flush-fitted screw joints, glued
joints, etc.?)
The total depth of the borehole
Any plugged back depth of the borehole
The borehole diameter
The volume of gravel-pack bentonite used and the method of
installation
The well development technique
The May 1986 hydrogeologic report states that the general design
specifications [Figure 9] for the casings and screens of the monitoring wells
MW-9 through MW-20 are as follows (from bottom to top):
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64
11" Inside Diameter x 1/4" Steel Cap
Padlock \ Hot DIp
Ground Surface
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2" Schedule 80 PVC Cas
with Threaded Flush J
2" Teflon Casing, 2 Foot
Sand Pack Around Wei
~ Teflon Casing , 1 Foot
2* Threaded End Plug
Figure 9. General Monitoring Well Construction (MVV9 through MW25)
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65
A 1-foot blank length of Schedule 80, 2-inch diameter of Teflon
casing
A 10-foot length of Schedule 80, 2-inch diameter Teflon well
screen with slot size of 0.01 inch
A 2-foot length of Schedule 80, 2-inch diameter Teflon casing to a
height of 1.5 feet above the projected high water table. The
projected high water table was based upon historical piezometric
data.
A variable length (depending on the well) of Schedule 80 2-inch
diameter PVC casing to a point above ground surface
All casing/screen joints are threaded flush joints.
USPCI placed the well screens in MW-9 through MW-20 so that the open
screen area would intersect the fluctuating water table.* The sand pack in the
annular space opposite the well screen consists of a clean, quartz sand"
placed from the bottom of the hole to a height approximately 0.5 feet above the
well screen. A 1- to 2-foot sodium bentonite seal was placed in the annular
space above the sand pack, followed by cement grout to within 2.5 feet of the
surface. The remaining 2.5 feet of hole was enlarged and filled with cement
grout that also created a concrete apron around the well at the surface. This
apron both supports a lockable steel protective well covering and directs
precipitation away from the well.
USPCI provided drilling construction details for MW-21 through MW-26 to
the Task Force after the inspection. These wells are designed similarly to MW-9
through MW-20 (MW-26 was installed in August 1986).
USPCI has noticed some settling of wells completed in the landfill berm (MW-13 through
MW-17), so that the open screen area may no longer continuously intersect the fluctuating
water table.
Particle size gradation is provided in the May 1986 hydrogeologic report.
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66
Well Locations
The locations of interim status ground-water monitoring wells MW-9
through MW-25 were decided by the Company and the regulatory agencies
prior to installation.* The well locations were selected using guidance provided
in the EPA Ground-Water Monitoring Technical Enforcement Guidance
Document.' USPCI has not provided rationale for the locations of wells MW-1
through MW-8, however MW-1 and MW-2 provide useful background and
piezometric data. MW-5 is useful for downgradient monitoring of the land
treatment areas.
USPCI has located upgradient wells at a distance from waste
management units so that they monitor background water quality unaffected by
site activities. This conclusion is based upon the direction of the hydraulic
gradient in the monitored aquifer and the distance of the upgradient wells from
waste management units.
The Company has located three downgradient wells at the downgradient
boundary of each waste management unit. In the cases of landfill cells 1 and 2,
the surface impoundment, and PCB cell X, the downgradient wells are
sufficiently close together (100 to 200 feet) to expect that they would intercept a
contaminant plume issuing from the waste management unit.
The three wells downgradient from the land treatment area are
approximately 1,000 feet apart. Closer spacing probably would not significantly
enhance the capability to immediately detect a contaminant plume. Four
lysimeters have been installed in each of the four land treatment areas to collect
water samples from the unsaturated zone 36 to 48 inches below ground surface
[Figure 7]. The water samples are analyzed for hazardous constituents. The
lysimeters, together with soil cores, would detect these constituents long before
the monitoring wells.
The 1986 hydrogeologic report provides information that suggests an
aqueous plume would move slowly across the land treatment area and be
Stipulation and Consent Order between UDH and USPCI, October 2, 1985
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67
dispersed over a broad area prior to reaching the monitoring wells. For
instance, the natural hydraulic gradient is very low, and the resulting potential
velocity of ground-water movement is low (estimated at less than 0.1 to 10 feet
per year). Much of the water beneath the land treatment area must travel a long
distance to reach the monitoring wells. The land treatment area encompasses
a broad area (206 acres) and is about three quarters of a mile across from east
to west (the direction of ground-water movement).
As for the fate of the contaminants, piezometric data support the
conclusion that net ground-water flow in the uppermost aquifer moves westward
toward the mudflats, with slight diversion to the southwest and northwest toward
mudflats located in those directions. These mudflats exist where ground water
ultimately discharges from beneath the land treatment area. Some ground
water may continue to flow beneath and beyond these mudflats.
The remote locations of monitoring wells MW-4, MW-6 and MW-7 render
these wells incapable of providing immediate leak detection from any waste
management units existing during the Task Force inspection. These well
locations may eventually be useful for ground-water monitoring or for
piezometric levels as additional waste management units become active.
USPCI SAMPLE COLLECTION AND HANDLING PROCEDURES
During the inspection, the Task Force evaluated sample collection and
handling procedures practiced by USPCI personnel. The evaluation included
observing water level measurements, well purging procedures, field data
collection, and sample collection, preservation and shipment. USPCI
procedures were evaluated for technical soundness and for compliance with
the sampling and analysis plan, as required by UHWR 7.13.3 (40 CFR 265.92).
The Task Force observed that in several instances, USPCI personnel did not
follow the sampling and analysis plan.
The Task Force observed water level measurements during the initial
onsite visit and well purging in June 1986. At this time, samples were collected
from 10 wells by an EPA contractor but not by USPCI. The Task Force elected
to observe routine sampling procedures by the Company during a subsequent
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68
site visit July 9 through 11, 1986. In July, USPCI personnel did normal quarterly
sampling at wells which had not been sampled by the Task Force in June. This
section details procedures used by USPCI personnel during the July sampling.
At the time of the Task Force inspection, the Company was in the process
of training personnel for the sampling responsibility. As a result, the field
methods the Task Force observed during the July quarterly sampling were done
by personnel not normally responsible for those duties and by personnel being
trained for those duties.
Water Level Measurements
At the wellhead, the first step USPCI followed in collecting samples was
measuring depth to water using an electric water level indicator (ACTAT
Olympic Well Probe, Model 150). The water level indicator consisted of a reel
with electric cable and sensor equipped with a battery power supply and a
buzzer. The cord had cylindrical metal weights attached below the sensor, so
that the sensor was between the cord and the weights. There was no meter on
the instrument and contact with water was signaled solely by the sensor
activating the buzzer.
The water level indicator used was insufficient. Moisture in the well
(above the water level) set off the buzzer by bridging across the sensor, thereby
closing the electrical circuit and reading false water levels. The absence of an
ammeter on the instrument prevented double checking the buzzer and
determining whether the reading was a good one. Task Force personnel
judged the accuracy of the water level measurements to be within +0.2 feet,
based upon the repeatability of sequential measurements.
All the USPCI wells, except MW-8, had dedicated Well Wizard pumps,
including a wellhead assembly from which the pumps were suspended. The
wellhead assembly had an access port through which the water level sensor
and cord were lowered [Figure 10]. Water levels were measured with
reference to the top of the cap on the top of the well casing, which was a
surveyed reference point.
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The cord, which was marked in sequential 5-foot increments, was
lowered into the well until the sensor reached the water, as indicated by the
buzzer. The cord was then slowly raised and lowered until the point at which
the sensor made contact was determined. The cord was then marked with
chalk by the sampler adjacent to the lip of the access port, and the distance from
the chalk mark to the next higher cord marker was measured with a measuring
tape. Depth to water was calculated by subtracting the reading made with the
measuring tape from the cord marker value. Water level measurements had to
be repeated several times to ensure that electrical bridging across the sensor
caused, for example, by humidity in the well, was not giving false readings.
Following the measurement, the entire length of cord that entered the
well, the sensor and the metal weights were triple-rinsed with deionized water.
The deionized water was sprayed from a squeeze bottle with a very thin spray.
The thin spray was difficult to keep trained on the thin cord to the meter, thus, a
triple rinse on the entire length took a long time to accomplish, and some
segments of the cord may not have been adequately rinsed. A more efficient
method of rinsing would ensure a better rinse.
Purging
USPCI personnel handled all wellhead equipment and purged each well
during both the June Task Force inspection and the July quarterly sampling, as
noted earlier. Each sampled well was equipped with a dedicated Well Wizard
bladder pump and well head assembly.
The power source for operating the pumps was the 12-volt battery of one
of the Company trucks attached to the Well Wizard control box with electrical
jumper cables. During sampling, this truck with its attendant exhaust was
positioned downwind from the wellhead. For two wells, MW-15 and MW-14, a
portable generator served^as~the-powef-source because there was no access
available for the truck.
USPCI personnel correctly determined the volume of water in the well
casing using the measured depth to water, total well depth and casing diameter
(even though the sampling and analysis plan provides an incorrect method).
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71
Total well depth data came from well construction records. Once the volume of
the water column was calculated, USPCI personnel multiplied the volume by
three to obtain the total amount of water to be evacuated.
Purge water was discharged into a graduated bucket in order to
determine when the three water column volumes had been obtained. As the
bucket filled, it was emptied into a large drum for subsequent disposal.
Field Data and Sample Collection
USPCI personnel first measured water levels in every well. They then
purged all the wells. Finally they began sampling. In some cases, sampling
commenced as much as 24 or more hours after purging stopped. This lag time
is not necessary on all wells, as many of them recover rapidly from purging and
could be sampled immediately upon completion of purging or at least within a
few hours. If full recovery exceeds 2 hours, the Company needs to extract-the
sample as soon as sufficient volume is available for a sample for each
parameter/
During the July quarterly sampling, USPCI personnel began sampling by
clearing the water line from the pump to the wellhead then collecting an aliquot
of sample for making field measurements, including temperature, specific
conductance and pH. USPCI had ordered a new conductance meter (YSIฎ
Model 32) and was using it for the first time.
Both the conductance meter and the pH meter were standardized prior to
making measurements on sample water. The conductance meter was
calibrated with standards having specific conductance values of 24,820 and
111,900 [imhos/cm. These values are appropriate for the naturally high total
dissolved solids (TDS) in ground water at this site. The pH meter was
calibrated with standards having pHs in the range of 7.4 and 10.4.
TEGD
YSI is a registered trademark and will be shown hereafter without the ฎ.
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72
For pH, the 7.4 standard was run first, then the 10.4 standard was run.
The samplers did not return to the 7.4 range to double check that the instrument
had not drifted after adjustment to 10.4. Since the ground water beneath the
USPCI site typically has a pH around 7.1 to 7.5, the 7.4 standard should have
been rechecked following the 10.4 standard.
Four replicate measurements were made for pH and specific
conductance for each sample. The instrument probes were not rinsed between
replicate measurements; however, the probes were rinsed with deionized water
prior to replicate measuring and upon completion of replicate measuring.
Specific conductance and pH are temperature-sensitive measurements.* In
several instances, the sample was allowed to rest several minutes between pH
and conductivity measurements and was not retested for temperature prior to
the second set of measurements. Ambient temperature should be a
consideration for frequent temperature correction when making temperature-
sensitive field measurements of this sort.
Following field measurements, filling sample bottles commenced.
USPCI 1986 quarterly sampling parameters appear in Table 13. Task Force
personnel noticed the extremely rapid entry of water into the vials for volatile
organics analysis (VOA). The resulting turbulence aerated the sample visibly.
Aeration strips the volatile organic compounds from the sample and should be
avoided to the extent possible. USPCI personnel later realized the error and
reduced the rate of flow into subsequent VOA bottles.
USPCI sampling personnel wore latex surgical gloves to minimize the
potential for sample contamination. These gloves were promptly changed upon
contact with foreign surfaces; however, the Task Force observed that the
samplers sometimes touched the inside surfaces of bottle caps with their
gloves, including the septa inside the caps of the volatile organics bottles when
the septa jarred loose from the cap. No effort was made to replace the caps or
use a different bottle. The samplers need to take care not to touch the insides of
the sampling containers with anything other than the sample itself in order to
minimize contamination from outside sources.
Standard Methods for the Examination of Water and Wastewater. 15th edition, 1980.
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73
Table 13
USPCI QUARTERLY SAMPLING PARAMETERS*
Parameter Container Preservative
Volatile Organics 3 60-ml glass vials Iced
Appendix VIII, TOX 1-gallon amber glass
Total Organic 250-ml clear glass H2SO4
Carbon/Hardness
Phenols 250-ml clear glass H3PO4/CuSO4
Metals 1-liter plastic HNO3
Total Dissolved 1 -liter plastic
Solids/Alkalinity/
Anions
* Parameters sampled when the Task Force observed UPSCI's quarterly
sampling on July 9 and 10, 1986. USPCI sampled these parameters
because they were in assessment monitoring during 1986. UDH and EPA
Region VIII selected the parameters.
A number of the monitoring wells were equipped at the wellhead with
dedicated Teflon sampling tubing; however, the Task Force noted that in at least
two instances, a length of tubing was reused at consecutive wells without being
decontaminated between wells. This practice introduces the possibility of
cross-contamination between wells and should be discontinued. Sampling
tubes should be either dedicated to the well or cleaned between wells.
In the final quarter of 1985, USPCI began keeping a bound logbook of
each sampling event. This log contains information on weather conditions,
wellhead conditions, field measurements and any extenuating circumstances
that might affect sampling. The sampling log should also document the types of
field instruments used and any changes in instrumentation. Documentation of
early 1986 sampling was erratic. USPCI needs to establish a standard format
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74
and completely document all sampling. Documentation of the July 1986
sampling was complete and correct.
Generally speaking, sampling practices at the USPCI facility are good,
with the exception of the deficiencies mentioned above. In the future, sampling
personnel need to pay close attention to the details of proper sample handling
and maintaining sample integrity.
Shipping and Chain-of-Custody
Quarterly samples going to the USPCI-owned NAL laboratory in Tulsa,
Oklahoma were preserved as necessary, placed in ice chests on ice and sealed
for shipping. A chain-of-custody form and analytical request sheet
accompanied each shipment. Copies of these completed documents are kept
onsite. Copies of the chain-of-custody forms were provided to Task Force
personnel. These forms contained spaces for the necessary information but
were not always completed properly. Several lacked notations for the number
of sample bottles in the shipment for each parameter. Sample bottle numbers,
specific to each bottle, were not always recorded.
Sampling and Analysis Plan
Task Force personnel observed USPCI sampling procedures for
adherence to the November 1985 sampling and analysis plan. USPCI
samplers used the November 1985 sampling and analysis plan for the third
quarter sampling in July 1986. Task Force personnel noticed that USPCI
personnel did not follow the plan on several points, thereby failing to comply
with UHWR 7.13.3 (40 CFR 265.92).
The samplers did not use a pH buffer in the 4.0 to 5.0 range of standard
in the field, as indicated by the plan. The samplers did not return to pH 7.4
buffer after standardizing the meter at pH 10.4, as indicated by the plan, but
instead standardized at 7.4 first.
The Company did not follow the plan with respect to the preservative for
phenols. The plan states that phenols will be preserved with sulfuric acid
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75
(H2SO4), but shipping forms and labels on sample bottles from the USPCI-NAL
laboratory specify the use of phosphoric acid and cupric sulfate (HPCVCuSCU).
When asked about this discrepancy, USPCI personnel indicated they will follow
laboratory instructions until the discrepancy is resolved in order to prevent
laboratory error regarding analysis of samples and blanks. This temporary
solution was acceptable, however, better communication with the laboratory
needs to be established so that the sampling and analysis plan reflects what is
actually done. In other words, follow the plan. Either preservative is accept-
able; however, the preservative listed in the plan should either be changed to
HPO3/CuSO4, or H2SO4 (as indicated in the plan) should be the preservative
used for phenols.
USPCI allowed a day's samples to wait overnight and through the
following day before shipment; thus, they did not follow the schedule for
shipment in the plan. The plan states that samples will be shipped immediately
after collection and packing.
SAMPLE ANALYSIS AND DATA QUALITY EVALUATION
The sample analysis and data quality evaluation for NAL are in
Appendix A. The analyses and data evaluation for Task Force samples are in
Appendix B.
GROUND-WATER QUALITY ASSESSMENT PROGRAM
The Grassy Mountain facility entered a year of ground-water assessment
monitoring in the first quarter of 1986. The following summary provides details
of events leading up to the initiation of assessment monitoring and following its
implementation.
On November 13, 1985, USPCI notified the Utah Solid and Hazardous
Waste Committee that they had measured statistically significant elevated levels
of total organic carbon (TOC) in MW-3. USPCI also had measured elevated
TOC in upgradient and other downgradient wells on an irregular basis, with no
apparent pattern. Quarterly sampling data from December 9, 1985 showed
continued elevated TOC in MW-3.
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76
On December 12, 1985, UDH notified USPCI by letter that the ground-
water quality assessment plan was overdue and should have been submitted
within 15 days of the initial notification under UHWR 7.13.4 (40 CFR 265.93).
UDH formally requested that USPCI submit the plan. USPCI responded by
resubmitting their sampling and analysis plan on January 8, 1986.
The sampling and analysis plan does not meet the basic requirements
for assessment monitoring under UHWR 7.13.4 (40 CFR 265.93). The plan
does not:
Specify clearly for which organic compounds samples will be
analyzed
Specify the appropriate methods of analysis for organic
compounds
List and identify detection limits that NAL is capable of achieving
for the analyzable compounds
Include any evaluation procedures for the ground-water
monitoring data, including analytical and water level data
Make provisions for determining the rate and extent of migration of
the hazardous waste or hazardous waste constituents in the
ground water
Include complete and legible well construction specifications
In effect, the USPCI Grassy Mountain facility had no ground-water quality
assessment plan, as required by UHWR 7.13.4 (40 CFR 265.93). Neither did
the facility have an outline of a ground-water quality assessment program, as
required by UHWR 7.13.4 (40 CFR 265.93).
USPCI did, however, comply with instructions from UDH and EPA to
sample and analyze for selected* organic compounds quarterly during
Organic compounds to be analyzed for were selected by UDH and EPA Region VIII.
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77
assessment monitoring in 1986. In this respect, USPCI was following the
agency directives for assessment monitoring.
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78
GROUND-WATER MONITORING PROPOSED FOR FINAL PERMIT
This section presents an evaluation of the ground-water monitoring
program at Grassy Mountain as proposed for the final permit under UHWR 8.6
(40 CFR 264 Subpart F). The section also includes proposed changes in the
ground-water monitoring system associated with expansion of hazardous waste
disposal activities at Grassy Mountain.
USPCI received two notices of deficiency for their Part B permit
application from UDH. With the second one, UDH included a compliance
schedule for the permitting process. The compliance schedule included
submission of the hydrogeologic characterization report, which UDH received in
May 1986. The three-volume report includes plans for a ground-water
monitoring program proposed for the final permit and was intended to be part of
the Part B application. Because of the remote locations of MW-4, MW-6 and
MW-7, these wells may not provide useful monitoring coverage for those units
existing during the Task Force inspection. The Task Force evaluated the
ground-water program proposed in this report with UHWR Part III criteria (40
CFR 270).
The report outlines a detection monitoring program pursuant to UHWR
8.6.9 for the uppermost aquifer and describes the proposed monitoring well
network, monitoring parameters, sample analysis, sample collection and data
evaluation. The following discussion reflects the Task Force conclusions on
these items.
PROPOSED MONITORING WELL NETWORK
As USPCI expands operations, the number of wells in the detection
monitoring program, under the permit, will increase above that in the interim
status monitoring program. UDH and EPA Region VIII propose that dedicating
wells to monitor each regulated unit is preferable to monitoring all the units as a
group. This approach optimizes the chances of detecting leakage from
individual units. Considering the low hydraulic gradient, the regulatory
agencies also propose the placement of monitoring wells so that they
circumscribe the landfill cells (as opposed to downgradient only) in order to
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79
provide better detection coverage radially in the event a leak occurs through a
cell liner.
Wells MW-4, MW-6 and MW-7 are several hundred feet from waste
management units and cannot provide immediate detection of leakage;
however, they may provide useful water level data and periodic ground-water
quality data. USPCI is justified in proposing to delete them from the required
detection monitoring program under UHWR 8.6.9 (40 CFR 264.98) as long as
expanded operations do not require these monitoring well locations and
hazardous constituents have not been detected in wells located next to the
waste management units.
For reasons stated in the section entitled "Well Construction," USPCI was
unable to demonstrate that monitoring wells MW-1 through MW-8 were in
compliance with UHWR 7.13.2 (40 CFR 265.91). Special consideration of the
construction of these wells needs to be given by the regulatory agencies prior to
including these wells in a ground-water monitoring program under the permit.
As for the land treatment areas, the existing, downgradient monitoring
wells in the saturated zone combined with the total of 16 lysimeters in the
unsaturated zone should be adequate for compliance with 40 CFR 264.278 (in
lieu of UHWR 8.13.19 which, when written, will be the State's corresponding
regulation for unsaturated zone monitoring beneath a land treatment area), and
UHWR 8.6.8 and 8.6.9 (40 CFR 264.97 and 264.98).
The Task Force agrees with the identification of the "shallow brine
aquifer" as the uppermost aquifer, as defined by UHWR Part 1 (40 CFR 260.10).
Wells completed in appropriate locations in this aquifer would detect leakage
earlier and more reliably than if they were completed in deeper, less permeable
sediments.
The proposed design for future monitoring well construction is
acceptable. USPCI should, however, provide to the State and EPA legible well
construction diagrams that completely show the design and position of each
well. The diagrams provided to the Task Force were not completely legible and
complicated the verification of well specifications.
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80
PROPOSED SAMPLING AND ANALYSIS PROGRAM
Although the facility was in assessment during the inspection, leakage to
ground water from hazardous waste units has not been substantiated. Whether
or not the bottom liner has leaked hazardous constituents to the ground water
needs to be supported or refuted prior to selecting a ground-water monitoring
program for the final permit.
Analysis of samples from the secondary leachate detection system,
located between the two synthetic liners of landfill cell 2, indicates that the
upper liner has failed. USPCI should be prepared to implement a compliance
monitoring program under UHWR 8.6.10 (40 CFR 264.99) in case the second,
lower liner of cell 2 or liners of other units fail.
The list of proposed analytical parameters is too comprehensive and
includes some compounds that are not analyzable by GC/MS. USPCI should
develop a list of parameters they can analyze." Leachate analysis would
provide guidance as to which chemical compounds or species USPCI should
monitor in ground water. Detection limits that are attainable by the NAL
laboratory need to appear with each analytical parameter listed.
The analytical procedures used to date by NAL have been judged by the
Task Force to be incapable of accurately measuring hazardous constituents in
ground-water samples or of providing a reliable indication of ground-water
quality [Appendix A]. NAL personnel should assess their laboratory capabilities
and protocols and propose analytical methods that they can do properly.
The inconsistent sampling procedures that existed prior to the Task Force
inspection cannot ensure monitoring results that provide a reliable indication of
ground-water quality. USPCI has taken steps to correct this problem by
devising a sampling and analysis plan (the deficiencies in this plan have been
discussed in the section entitled "Ground-Water Monitoring Program During
EPA requires a list [Appendix IX] of compounds that can be analyzed (Federal Register, Vol.
52, No. 131, July 9, 1987, 25942).
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81
Interim Status"). USPCI needs to ensure consistent sampling and analytical
procedures to comply with UHWR 8.6.8 (40 CFR 264.97).
USPCI has proposed to evaluate ground-water analytical data
statistically using the Chemical Manufacturers' Association (CMA) standard
t-test. This procedure is inappropriate for USPCI as it does not take into
account other variables at Grassy Mountain, such as the naturally high salts in
the ground water and the apparently natural fluctuations in ground-water
quality. USPCI should propose an evaluating method that accounts for this
variability.
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82
EVALUATION OF MONITORING DATA FOR INDICATIONS OF WASTE
RELEASE
This section presents an analysis of the Task Force monitoring data
regarding indications of apparent leakage from the waste management units.
Analytical results from and methods used on samples collected by Task Force
personnel are presented in Appendix B. Ground-water samples collected by
the Task Force are identified in Table 14. Locations of leachate sumps sampled
are described in Table 15.
Task Force data do not indicate the presence of organic compounds in
the 10 wells sampled. The organic analyses do not detect ground-water
contamination. The analytical results for inorganics may reflect interferences
from the naturally high salts in the ground water, thereby making these results
unreliable.
Collectively, both organic and inorganic chemical analyses of leachate
provide evidence that the upper liner of landfill cell 2 has been breached in one
or more places and that hazardous waste constituents have migrated between
the two liners [Table 16]. In particular, leachate samples from sumps 3-B and
4-B show elevated concentrations of compounds one would not expect to see if
the liner were an effective partition separating hazardous waste constituents
from the leachate detection sumps. Followup sampling and analysis may be
desirable to confirm or refute this conclusion.
The organic constituent analysis results of samples from the leachate
detection system in cell 2 indicate the presence of elevated levels of several
organic compounds. Methylene chloride was detected at 1200 fig/L in sump
3-B and 245 ng/L in 2-B, whereas concentrations in 1-B and 4-B were much
lower at 36 and 31 p.g/L, respectively. The compounds 2-butanone (970 |j.g/L)
and acetone (270 ng/L) were detected in sump 4-B, but were not detected in the
other sumps of cell 2.
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83
Table 14
MONITORING WELLS SAMPLED BY
TASK FORCE
Well
MW-3
MW-7
MW-9
MW-10
MW-11
MW-13
MW-14
MW-15
MW-16
MQ-17
Sample Number
MQ0545
MQ0539
MQ0548
M00537
MQ0536
MQ0541
MQ0540
MQ0543
MQ0549
MQ0550
Table 15
LEACHATE SAMPLE LOCATION DESCRIPTIONS
Unit
Sump Designation
Location
Sample Number
Cell 1
Cell
Cell
Cell
Cell
Cell 1
1-B
2-B
3-B
4-B
Surface
Impoundment
Southern end of
CelM
Northeast corner
Southeast corner
Southwest corner
Northwest corner
West end
MQ0396
MQ0394
MQ0395
MQ0393
MQ0392
MQ0538
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84
Table 16
SELECTED COMPOUNDS FOUND IN LEACHATE SAMPLES FROM THE
LEACHATE DETECTION SYSTEM OF CELL 2*
Sumps
Units*
1-B
2-B
3-B
4-B
Organic Constituent Analysis
Methylene
Chloride
2-Butanone
Tetrahydrofuran
Phenol
2-Methylphenol
H9/L
^g/L
jig/L
W/L
W/L
36
ND
850
ND
ND
245
ND
1100
ND
ND
1200
ND
240
1500
980
31
270
7800
ND
ND
General Analysis
Purgeable Organic
Halogens (POX)
Nonpurgeable
Organic Carbon
(POC)
Chromium, Cr
Iron, Fe
Potassium, K
mg/L Cl
mg/LC
W/L
M/L
W/L
27
43
Metals Analysis
34
67
259,000 221
34
57
34
37
,000
840
223
20,000
280
1,560,000
160
91
684
13,200
240,000
Complete analytical results appear in Appendix B.
, micrograms per liter; mg/L, milligrams per liter; C, Carbon; Cl, Chloride.
Tetrahydrofuran was detected in each of the sumps of cell 2, ranging
from 240 |ig/L in sump 3-B to 7800 p.g/L in sump 4-B. The presence of
tetrahydrofuran in Task Force samples was confirmed by an independent NEIC
laboratory analysis.
Phenol and 2-methylphenol were detected in sump 3-B at 1500 ng/L and
980 ng/L, respectively, but were not detected in sumps 1-B, 2-B and 4-B.
Leachate analyses for 3-B also indicate elevated purgeable organic
halogens (POX) at 840 |ig/L Cl and 160 ng/L in 4-B. The presence of POX
beneath the upper liner is significant because most halogenated organics rarely
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85
occur in nature.* Consequently, the Task Force concludes that the occurrence
of purgeable organic halogens at such levels in the leachate detection system
suggests that the upper liner in cell 2 has leaked.
The level of nonpurgeable organic carbon (NPOC) in sump 3-B
(223 mg/L) exceeds those levels in 1-B (43 mg/L) and 2-B (57 mg/L) by about
four times and is two times higher than the NPOC in 4-B (91 mg/L). The
analytical results for NPOC show a similar pattern to that exhibited by POX,
supporting the conclusion that the upper synthetic liner has been breached,
probably somewhere in the western half of cell 2.
Task Force data indicated elevated chromium levels in leachate
detection sump 3-B in the southwestern quadrant of cell 2 (20,000 |ig/L) and in
sump 4-B in the northwestern quadrant of cell 2 (684 |ig/L). By contrast,
analyses of leachate samples from the northeastern and southeastern
quadrants (1-B and 2-B, respectively) each indicate chromium in a
concentration of 34 p.g/L The leachate analysis for unlined cell 1 indicates
chromium at 134 |ig/L
Iron in leachate sump 4-B was measured at 13,200 jj.g/L, 47 times the
concentration of iron (Fe) in 3-B (280 |ig/L) and more than 150 times the
concentration of iron in 1-B and 2-B. The cause of elevated iron in 4-B is
unknown.
The leachate sample from sump 3-B had a potassium concentration of
1,560,000 ^ig/L, which is seven times greater than in other sumps of cell 2.
Although potassium is not listed in 40 CFR 261 as a toxic metal, the higher
levels in 3-B suggest the leachate in that sump has been affected by potassium-
bearing waste streams in the landfill cell.
Samples fFOflv^raund-water_monitoring wells near cell 2 do not show
chemical evidence that the bottom liner has leaked.
Takahashi, Y; Moore, R.T.; and Joyce, R.J., "Measurement of Total Organic Halides (TOX)
and Purgeable Organic Halogens (POX) in Water Using Carbon Absorption and
Microcoulometric Determination," Chemistry in Water Reuse, Volume 2, 1981
-------
REFERENCES
1. EPA RCRA Ground-Water Monitoring Technical Enforcement Guidance
Document (TEGD), OSWER 9950.1, September 1986
2. McGraw, Jack, EPA Memorandum on "Procedures for Planning and
Implementing Offsite Response", May 6,1985.
3. USPCI Transmittal to U.S. EPA Region VIII, Exhibit C, "Impoundment A
Capacities", September 28, 1984.
4. USPCI, 1985 "Grassy Mountain Facility, EPA Biennial Report" (RCRA
Annual Report).
5. USPCI "Waste Analysis Plan", August 22, 1985 (PRC. Vol. 9, T017-P09-
601-010, Attachment B).
6. USPCI, "Response to Federal Ground-Water Regulations 40 CFR
170.14(c) Regarding Grassy Mountain Facility Near Knolls, Utah",
Volumes 1, 2 and 3, May 1986.
7. Freeze, R. A., and Cherry, J. A. 1979. Groundwater. Prentice-Hall Inc.,
Englewood Cliffs, New Jersey, 604 p.
8. Driscoll, F. G., ed 1986. Groundwater and Wells. Johnson Division, St.
Paul, Minnesota, 1089 p.
9. Federal Register. Vol. 52, No. 131, July 9, 1987, 25942.
10. Takahashi, Y., Moore, R. T. and Joyce, R. J., "Measurement of Total
Organic Halides (TOX) and Purgeable Organic Halides (POX) in Water
Using Carbon Absorption and Microcoulometric Determination,"
Chemistry in Water Reuse, Vol. 2,1981.
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APPENDICES
A USPCI SAMPLE ANALYSIS AND DATA QUALITY EVALUATION
B ANALYSIS AND DATA EVALUATION FOR TASK FORCE
SAMPLES
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APPENDIX A
USPCI SAMPLE ANALYSIS AND DATA QUALITY EVALUATION
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A-1
Appendix A
USPCI SAMPLE ANALYSIS AND DATA QUALITY EVALUATION
This section provides an evaluation of the quality and completeness of
ground-water monitoring data gathered by USPCI between March 1982 and
June 1986. Mideco Laboratories performed analyses for the first quarter of
1982 and Ford Laboratories provided analyses for the second quarter. National
Analytical Laboratories (NAL) has been responsible for the analytical work for
USPCI since August 1982. USPCI personnel at the site performed some
measurements for specific conductance and pH. NAL was evaluated
concurrently with the onsite inspection of the USPCI 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 analytical inadequacies and found that much of
the monitoring required in 1982 and 1986 has not been performed. Most
analytical inadequacies stem from improper sample handling or calibration
procedures, the lack of quality control measures, and/or not accounting for the
high dissolved solids content of the sample. The initial year of required
background quarterly monitoring conducted in 1982 was incomplete as was the
monitoring conducted in 1986. These inadequacies adversely affected the
reliability of data in establishing background levels or in detecting releases into
the ground water. A detailed discussion of these inadequacies is given in the
following sections.
Ground-Water Analysis. 1982 through 1985
UHWR 7.13.3 (40 CFR 265.92) requires 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, TOG and TOX). In March 1982 USPCI initiated quarterly
monitoring pursuant to 7.13.3.(c) on the RCRA well network. The network
included upgradient wells 1 and 2 and downgradient wells 3 through 8. UDH
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A-2
required USPCI to restart background monitoring at the beginning of 1983,
because of the incompleteness and the poor data quality of the 1982
monitoring.
The first year of background water quality monitoring in 1982 was
incomplete. The required quadruplicate measurements for the four indicator
parameters for upgradient wells were not reported. Background monitoring
results for the required pesticides, herbicides and the radiochemical parameters
were not reported at all (UHWR 7.13.3 and 40 CFR Part 265.92). Fluoride,
nitrate and pH were not reported for the fourth quarter. TOG and coliform were
not reported for the first and second quarters and TOX was not reported for the
third and fourth quarters. Silver was not reported in the fourth quarter of 1982
and chromium was not reported for the first quarter of 1983. Subsequent
monitoring through 1985 monitoring was complete; all monitoring suffered
analytical deficiencies.
Holding times for pH measurements were exceeded. Between
November 1983 and August 1984, pH was measured after samples were
shipped to NAL in Oklahoma rather than analyzed on site. Prior to 1984, the
EPA-recommended holding time was 2 hours. Since 1984, EPA has
recommended that samples be analyzed immediately. Due to the susceptibility
of pH to change with time for ground water samples, the pH results for
November 1983 to August 1984 are unreliable.
Specific conductance results are suspect. Cell constant corrections have
not been made for the measurements. Further, standards to establish the cell
constant were not within the same range as the samples. The lack of these
measures causes bias in the results. A detailed explanation of cell corrections
can be found in Standard Methods. 15th edition, and in the instruction manual
for the particular instrument.
The standard TOX method can often achieve a detection limit of between
5 |ig/L and 30 |ig/L; however, the high chloride levels in the site ground-water
samples would prevent such a detection limit from being achieved. High
chloride levels can cause TOX results to be biased high. Typically 50 mg/L
chloride could cause an apparent TOX of 1 mg/L. Some of the ground-water
-------
A-3
samples have been found to contain as much as 50,000 mg/L chloride. Such
samples could cause an apparent TOX of 1,000 jig/L.
Some of the samples also have a high turbidity which infers high
suspended solids. In 1982, at least some of the samples were filtered prior to
analyzing for TOX. Between 1982 and the beginning of 1986, records do not
clearly indicate if samples were filtered or not. Filtering could cause TOX values
to be biased low due to the loss of volatile organics and the sorption of
dissolved organics. However, TOX could be biased high if the paniculate
matter contained chloride and it is not removed. Further, the high sodium
content of these samples can cause the quartz furnace of the TOX analyzer to
deteriorate resulting in a negative bias for TOX measurements.
TOX measurements using the standard method and instrumentation for
ground water containing such high levels of dissolved salts and suspended
solids can not serve as an indicator of low level contamination of halogenated
organics and thus the reported TOX results are unreliable. POX (purgeable
organic halogens) measurements could serve as an indicator of low level
contamination of volatile halogenated organics, assuming proper care is taken
to ensure the quartz furnace does not deteriorate due to an excessive purge
rate introducing sodium into the furnace.
TOC was determined by acidifying and purging samples prior to analysis.
The results for this type of measurement are best termed nonpurgeable organic
carbon (NPOC) as the purging not only eliminates inorganic carbon from the
measurement but also purgeable organic carbon (POC). To indicate that NPOC
results are equivalent to TOC results would require the measurement of POC to
establish that POC does not contribute significantly to the TOC.
Mercury has been exclusively determined by cold vapor atomic
absorption spectroscopy. Prior to 1983, NAL used sodium borohydride as the
reductant. The EPA method uses stannous chloride. NAL personnel indicated
that they started using stannous chloride as the reductant for the mercury
determinations sometime in 1983.
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A-4
Mercury was detected in only two quarters. In the last quarter of 1982, all
well samples were reported to contain mercury at concentrations in excess of
the drinking water standard of 2 (ig/L The reported values ranged from 3 |j.g/L
to 6 |ig/L In the next sampling in March of 1983, five well samples were
reported to contain mercury at concentrations ranging from 0.4 |ig/L to 2.5 |ig/L.
Previous and subsequent to these two instances, mercury was not detected.
The positive results observed for these two samplings are probably due to
systematic error caused by the laboratory and probably do not represent actual
concentrations in the well samples. The error may have been caused by the
use of the sodium borohydride reductant or could possibly be introduced, as
NAL did not take steps to eliminate interference due to the formation of chlorine
from chloride during the oxidative digestion in the procedure.
Many of the determinations for the other metals or elements are
unreliable because the high dissolved solids content of the ground-water
samples have caused serious interference. Atomic absorption spectroscopy
techniques were exclusively used for metals determinations, except barium,
until 1985. The high salt concentration causes so much molecular background
that the analyte atomic absorption signal cannot be distinguished reliably by the
furnace background correction instrumentation. Further, ionization interference
would have been severe for the flame technique.
In 1983, NAL started to use Zeeman background correction furnace
atomic absorption spectroscopy for some of the metals determinations. The
Zeeman technique can compensate for larger molecular interference than the
continuum background correction system used previously. However, the
implementation of the Zeeman technique did not resolve all the sample matrix
effects and much of the data are unreliable.
In 1985, NAL started to use Inductively Coupled Argon Plasma Optical
Emission Spectroscopy (ICP) instead-of-Atomic^Absorption Spectroscopy for
some of the other metals determinations. ICP is also subject to interferences
due to high dissolved solids. The ICP background generally increases with
increasing dissolved solids content and signal to concentration calibration
changes with increasing dissolved solids which is partially due to changes in
the sample introduction rate and changes in the plasma emission profiles of the
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A-5
analytes. Apparently cognizant of the problems with high dissolved solids in
ICP analyses, NAL analyzed dilutions of samples. Diluting the sample will help
to eliminate interference but dilution compromises the detection limit. Typically,
ICP can often achieve detection limits of 2 jig/L for cadmium and 30 fig/L for
lead. At the 1:10 dilution used by NAL, the detection limits for cadmium and
lead would at least have been 20 ^.g/L and 300 (ig/L, respectively. Both
detection limits exceed the respective drinking water standards for cadmium
and lead and are not low enough to reliably establish background levels for
ground water.
The ground-water sample matrices challenge many of the commonly
used methods for metals determinations. Reliable results that established
background levels have not been obtained using these methods. Methodology
common to low level determinations in seawater could possibly provide such
results. Extraction and coprecipitation isolation techniques are used prior to
atomic absorption or ICP spectroscopic analysis. Direct analysis without the
use of isolation techniques may prove successful. The method of standard
additions in an ICP analysis for barium, cadmium, chromium, iron, sodium and
silver would be a possibility. Alternately, exact matching of the calibration
standards to the ground-water sample matrix for ICP analyses may be
appropriate. ICP analysis of dilutions for barium, iron and sodium may be
successful. Cadmium, chromium, lead and silver could probably be determined
by furnace atomic absorption spectroscopy. The use of Zeeman background
correction, the L'vov platform, matrix modifiers possibly including palladium and
absorbic acid, as well as appropriate dilutions should facilitate the furnace
technique analyses. Arsenic and selenium could be determined by hydride
generation atomic spectroscopy. Mercury should continue to be determined by
cold vapor atomic absorption spectroscopy although purging of the digests prior
to the addition of the reductant should be employed to circumvent possible
interference due to the formation of chlorine. The use of any technique must be
predicated on achieving detection limits well below the drinking water
standards established in UHWR, Appendix E (40 CFR 265, Appendix III).
A number of laboratory records for metals and pesticides determinations
that were performed for ground-water samples prior to and around mid-1985
could not be located by NAL personnel. A large turnover in both analysts and
-------
A-6
managers at NAL has resulted in some discontinuity in the way samples have
been processed at the lab since early 1983. The lack of records for the
pesticide determinations prevented evaluation of the data quality for these
parameters.
Data reported for the phenoxy acid herbicides, 2,4-D and Silvex, are not
reliable. The method used would not detect the herbicides present in the ester
form. A reliable method, such as the one recommended under the Safe
Drinking Water Act, would detect the herbicides present in both the acid and
ester forms. Problems with the method are illustrated when NAL failed to
achieve acceptable results for 2,4-D in a State of Kansas performance
evaluation for drinking water certification in 1984.
Gross alpha and gross beta activity measurements have been made
subsequent to 1982. Many of the gross alpha values are reported as not
detected at the maximum contaminant level of 2 pCi/L (40 CFR Part 265,
Appendix III). This detection limit is achievable for samples containing low
levels of dissolved solids, but not for samples containing percent levels of
dissolved solids. Analytical methods require the use of smaller aliquots of
samples containing high levels of dissolved solids resulting in increased
detection limits. For samples containing 50,000 mg/L dissolved solids a
detection limit of about 100 pCi/L gross alpha and 200 pCi/L gross beta would
normally be achieved. Thus the gross alpha and gross beta data as reported
are not reliable.
NAL personnel indicated that some of the resulting distillates from the
phenol determinations were noticeably turbid. The colorimetric analysis of a
turbid distillate could cause a high bias and may account for the anomalous
detection of phenol in some of the samples. NAL was planning to use the
chloroform extraction procedure which should circumvent the turbidity
interference for future determinations.
Ground-water Analysis Commencing January 1986
USPCI restarted background ground-water quality monitoring at the
beginning of 1986. The new sampling and analysis plan called for monitoring
-------
A-7
wells 1 through 7 and wells 9 through 20. Parameters were added to those
included in previous sections of this report. No results could be found for well 5
during the first quarter of 1986. According to UDH, only volatile and
semivolatile organic compounds were reported for the second quarter of 1986
for all the wells. All other analyses required by the sampling and analysis plan
were not reported (e.g., metals were not reported for the second quarter).
Most of the laboratory findings discussed in the previous section are also
applicable to the 1986 data, as most of the methods did not change.
Determinations still lacked adequate quality control measures. NAL used gas
chromatography/mass spectrometry (GC/MS) methods for the pesticides
determinations rather than the gas chromatography methods used previously.
The GC/MS methodology cannot achieve detection limits below drinking water
standards and thus can not reliably establish background levels. NAL was
using a more appropriate method (including the ester form) for herbicide
determinations at the time of the Task Force inspection.
The volatile and semivolatile organic results for the first two quarters of
1986 should be considered unreliable. Methods 624 and 625* were cited as
being used, however, the cited methods were not properly followed. Accuracy
and precision control measures required by the methods were not properly
implemented or evaluated. For example, the mass spectrometer was not
properly calibrated for the Method 624 analyses. Bromofluorobenzene (BFB)
was not used to check the instrument calibration, as required. In addition,
purgeable gases could not be detected at concentrations at least 20 times the
normal method detection limit of 5 jig/L. Reported GC/MS detection limits
should be considered an estimate as they were taken from the published
method without having performed the actual determination required by the
methods.
Reportedly, during 1986, TOX samples were not filtered as is proper.
Other comments relative to TOX, as presented in the section above, continue to
apply.
40 CFR Part 136
-------
APPENDIX B
ANALYSIS AND DATA EVALUATION FOR TASK FORCE SAMPLES
-------
B-l
II. Evaluation of Quality Control Data and Analytical Data
1.0 Metala
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 ground-water samples (MQO539 and 546) and two leachate samples
(MQO392 [graphite furnace metals only] and MQO393 [ICP metals and mercury
only]). Six average spike recoveries from the ground-water samples and eight
individual spike recoveries from the leachate samples were within the data quality
objectives (DQOs) for this Program. Spike recoveries for four of the metals from
the ground-water samples and seven of the metals from the leachate samples were
not calculated because the sample concentrations were greater than four times the
concentration of spike added. In the ground-water samples, the cadmium, lead, and
selenium average spike recoveries were above DQO with values of 560, 3250, and 440
percent, respectively. The barium, beryllium, chromium, cobalt, copper, manganese,
nickel, silver, thallium, and zinc average spike recoveries were below DQO with
values of 18, 69, 70, 67, 45, 37, 66, 0, 26, and 69 percent, respectively. Various
individual metal spike recoveries from the ground-water samples were also outside
DQO. These are listed in Table 3-2a of Reference 2 as well as in the following
Sections. In the leachate samples, arsenic, cadmium, lead, and manganese spike
recoveries were above DQO with values of 240, 226, 444, and 188 percent,
respectively. The barium, mercury, silver, and thallium spike recoveries were below
DQO with values of 25, 16, 26, and 57 percent, respectively. Only one leachate
sample was spiked for each metal. Sample MQO392 was spiked for the furnace
metals and sample MQO393 was spiked for the ICP metals.
All reported laboratory control sample (LCS) recoveries and all calibration
verification standard (CVS) recoveries were within Program DQOs.
The average relative percent differences (RPDs) for all metallic analytes in
both ground water and leachate, except selenium in a leachate sample, were within
the DQOs.
Required analyses were performed on all metals samples submitted to the
laboratory.
No contamination was reported in the laboratory or sampling blanks.
1.3 Furnace Metals
The furnace metals (antimony, arsenic, cadmium, lead, selenium, and thallium)
quality control, with a few exceptions, was acceptable. The traffic reports for
samples MQO549 and 550 were not included in the data package from the laboratory.
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B-2
All antimony results, with the exceptions of samples MQO394, 395, 545, 546,
and 550, should be considered quantitative. Duplicate injection precision for
antimony was outside DQO for samples MQO394, 395, 545, 546, and 550. Because of
this, antimony results for samples MQO394 and 550 should be considered qualitative
while those for samples MQO395, 545, and 546 should be considered unreliable.
The arsenic spike recoveries for samples MQO392 (leachate sample), 539
(ground-water sample), and 546 (ground-water sample) were outside DQO with
recoveries of 240, 155, and 0 percent, respectively. The correlation coefficients for
the method of standard addition analysis of two arsenic laboratory control standards
(LCS*1 and LCS*2) were outside of DQO. Duplicate injection precision was outside
DQO for arsenic in samples MQO547, 548, and 549. Arsenic results, with the
exceptions listed below, should be considered unreliable due to the above problems.
Arsenic results for samples MQO542, 544, and 551 should be considered semi-
quantitative and results for samples MQO392 and 396 should be considered
qualitative.
The cadmium spike recoveries for samples MQO392 (leachate sample), 539
(ground water), and 546 (ground water) were outside DQO with recoveries of 226,
50, and 1070 percent, respectively. Duplicate injection precision was outside DQO
for cadmium in samples MQO546 and 547. Cadmium results, with the exceptions
listed below, should be considered qualitative. Cadmium results for samples
MQO542, 544, and 551 should be considered semi-quantitative and results for samples
MQO546 and 547 should be considered unreliable.
The lead spike recoveries for samples MQO392 (leachate sample) and 546
(ground-water sample) were outside DQO with recoveries of 444 and 3250 percent,
respectively. The correlation coefficients for the method of standard addition
analysis of three lead samples (MQO393 and 395) were outside of DQO. Lead
results, with the exceptions listed below, should be considered unreliable due to the
above problems. Lead results for samples MQO542, 544, and 551 should be
considered semi-quantitative.
The selenium spike recoveries for samples MQO392 (leachate sample) and 539
(ground-water sample) were outside DQO with recoveries of 0 and 440 percent,
respectively. Duplicate injection precision was outside DQO for selenium in samples
MQO541, 545, 546Dup, 549, and 550. A duplicate injection was not run for sample
MQO539. Selenium results, with the exceptions mentioned below, should be
considered unreliable due to the above problems. Selenium results for samples
MQO542, 544, and 551 should be considered semi-quantitative and results for
MQO393, 394, 396, 536, 537, 540, and 543 should be considered qualitative.
The thallium spike recoveries for samples MQO392 (leachate sample), 539
(ground-water sample), and 546 (ground-water sample) were outside DQO with
recoveries of 57, 51, and 398 percent, respectively. Duplicate injection precision
was outside DQO for thallium in sample MQO543. All thallium results should be
considered qualitative.
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B-3
All aluminum, calcium, magnesium, sodium, and vanadium results should be
considered quantitative. All beryllium, chromium, cobalt, iron, nickel, and potassium
results, as well as zinc results with the exceptions listed below, should be
considered semi-quantitative. All barium, copper, and manganese results, as well as
zinc results for samples MQO392, 393, 394, 395, and 396, should be considered
qualitative. All silver results should be considered unreliable.
1.5 Mercury
Some samples which were analyzed for mercury required additional dilution.
Mercury detection limits for these samples were raised and false negatives are a
possibility.
The mercury spike recovery for the leachate spike (MQO393) was biased low by
84 percent (16 percent recovery). All non-detect mercury results for leachate
samples are unreliable (high probability of false negatives). All positive mercury
results in the leachate samples are qualitative.
All mercury results, with the exceptions of results for the leachate samples
(MQO392, 393, 394, 395, and 396), should be considered quantitative with an
acceptable probability of false negatives. Mercury results for leachate samples
MQO393, 394, and 396 should be considered qualitative and results for MQO392 and
395 unreliable.
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, in
both ground water and leachate, were within the accuracy DQOs (accuracy DQOs
have not been established for bromide and nitrite nitrogen matrix spikes). This
indicates acceptable recoveries for all inorganic and indicator analytes.
All LCS and CVS recoveries reported in the raw data for inorganic and
indicator analytes were within Program DQOs.
Average RPDs for all inorganic and indicator analytes were within Program
DQOs. Precision DQOs have not been established for bromide and nitrite nitrogen.
Requested analyses were performed on all samples for the inorganic and
indicator analytes.
No laboratory blank contamination was reported for any inorganic or indicator
analyte. Contamination involving POX, total phenols, and TDS was found in the
sampling blanks (MQO542, 544, and 551) at levels above CRDL. ^T-hese_CQfliaminants
and their concentrations are listed below, as well as in Section 3.2.4 (page 3-2) of
Reference 2. ^
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B-4
2.3 Inorganic and Indicator Amlvte Data
The quality control results for cyanide, sulfate, sulfide, chloride, and total
dissolved solids (TDS) are acceptable. The results for these analytes should be
considered quantitative.
The holding times for the nitrate nitrogen analyses ranged from six to eight
days from receipt of samples which is longer than the recommended 48 hour holding
time for unpreserved samples. The nitrate nitrogen results should be considered
semi-quantitative with detection limits raised by a factor of 1000 due to dilutions
required by the high concentrations of sulfate and chloride present in the samples.
The holding times for the nitrite nitrogen analyses ranged from six to eight
days from receipt of samples which is longer than the recommended 48 hour holding
time for unpreserved samples. The laboratory did not analyze an initial calibration
verification (ICV) at the beginning of the nitrite nitrogen ion chromatography
analytical batch, as requirrd. The nitrite nitrogen results should be considered to
be semi-quantitative with detection limits raised by a factor of 1000 due to dilutions
required by the high concentrations of sulfate and chloride present in the samples.
The laboratory did not analyze an ICV at the beginning of the bromide ion
chromatography analytical batch, as required. The bromide results should be
considered to be semi-quantitative with detection limits raised by a factor of 1000
due to dilutions required by the high concentrations of sulfate and chloride present
in the samples.
One of three ammonia nitrogen matrix spikes (into a ground-water sample) was
above the DQO with a recovery of 114 percent (DQO range 90 to 110 percent). All
ammonia nitrogen results should be considered semi-quantitative.
One of three total phenols matrix spike recoveries (into a leachate sample) was
above the DQO with a recovery of 122 percent (DQO range 80 to 120 percent).
Total phenol contamination was found in the trip and field blanks (MQOS42, 544,
and SSI) at concentrations of 52, 20, and 520 ug/L. These values are above the
total phenol CRDL of 10 ug/L. All total phenols results greater than 10 times the
highest concentration of total phenols in the field blanks or less than the detection
limit are considered semi-quantitative. This includes samples MQO392, 393, 394, 395,
396, 540, 543, and 548. All other total phenols results arc unreliable. Many of the
total phenols samples were diluted by 2 to 20 times normal dilutions. This results
in raised detection limits for the affected samples.
A final TOC calibration verification (CV) and final calibration blank (CB) were
not analyzed for one of the analytical batches. Results for sample MQO393 and the
spike analysis results for MQO396 were affected. The agreement of results between
one of the field triplicates and the other two was poor with reported TOC
concentrations of 1000 (an estimated concentration because 1000 ug/L is the .
detection limit), 8100, and 8500 ug/L. The comparative precision of the field
triplicate results is not used in the evaluation of sample data as it is not possible
to determine the source of this imprecision. Field triplicate precision is reported
for informational purposes only. The 28 day TOC holding time was exceeded by one
to three days. All TOC results should be considered semi-quantitative.
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B-5
Initial calibration verification and continuing calibration verification (CCV)
standards for POC were not analyzed. EPA needs to supply the inorganic laboratory
with a POC calibration verification solution. Until then, the instrument calibration
can not be assessed. The POC results should be considered qualitative.
A CCV and CCB were not run at the end of each days TOX analytical batches.
Instrument calibration curve information for TOX was not provided in the raw data.
High levels of chloride (above 200 mg/L) were found in all field samples. All
samples had to be diluted by as much as 100,000 to 1 because of this interference.
Most of the TOX results, except for the blanks, are unreliable with greatly
increased detection limits. The TOX results for the sampling blanks should be
considered quantitative.
Field blank MQOS51 contained POX contamination at 20 ug/L which is above
the CRDL. All POX results greater than 10 times the highest concentration of POX
in the field blanks (samples MQO393 and 539) should be considered quantitative and
all POX results greater than 4 times the blank concentration (samples MQO392)
should be considered qualitative. The other POX results should be considered
unreliable.
The field triplicate RSD was 41 percent for TDS which the data reviewers
consider excessive. The comparative precision of the field triplicate results is not
used in the evaluation of sample data as it is not possible to determine the source
of this imprecision. Field triplicate precision is reported for informational purposes
only. No laboratory blanks were analyzed for TDS. One field blank had TDS
contamination of 4000 ug/L. This contamination level was so much lower than field
sample results that it was felt to have no impact on the field sample results. As
mentioned previously, the TDS data should be considered quantitative.
3.0 Organics and Pesticides
3.1 Performance Evaluation Standard
Organic performance evaluation standards were not evaluated in conjunction
with the samples collected from this facility.
3.2 Organic OC Evaluation
All matrix spike average recoveries were within established Program DQOs for
accuracy. Individual matrix spike recoveries which were outside the accuracy DQO
will be discussed in the appropriate Section below. All surrogate spike average
recoveries were also within DQOs for accuracy. Individual surrogate spike
recoveries which were outside the accuracy DQO will be discussed in the
appropriate Section below.
All matrix spike/matrix spike duplicate average RPDs were within Program
DQOs for precision except those for phenol and 2-chlorophenol. Individual matrix
spike RPDs which were outside the precision DQO will be discussed in the
appropriate Section below. All average surrogate spike RPDs were also within DQOs
for precision except those for phenol-D5, 2-fIuorophcnol, and dibutylchlorendate.
All organic analyses were performed as requested.
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B-6
Laboratory blank contamination was reported for organics and is discussed in
the appropriate Sections below.
Detection limits for the organic fractions are summarized in the appropriate
Sections below.
3.3 Volatiles
Quality control data indicate that volatile organics were determined acceptably.
The chromatograms appear acceptable. Initial and continuing calibrations, tunings
and mass calibrations, blanks, matrix spikes, matrix spike duplicates, surrogate
spikes, and holding times are all within acceptance limits.
Acetone was found in five laboratory blanks at values of 5 to 12 ug/L. The
CRDL for acetone is 10 ug/L. Acetone results in this range should be considered
unreliable.
Estimated method detection limits are CRDL for all samples except QO392
which is 10 times CRDL, QO393 which is 7.7 times CRDL, and QO396 which is :.
times CRDL.
The volatiles data are acceptable. The probability of false negative results for
the volatiles is acceptable except for the three samples with raised detection limits.
The volatile compound results should be considered quantitative.
3.4 Semivolatiles
Calibrations, tuning and mass calibrations, blanks, matrix spikes, matrix spike
duplicates, surrogate spikes, holding times, and chromatograms were acceptable for
the semivolatiles.
The matrix spike (but not matrix spike duplicate) recovery of 2-chlorophcr. .
was 25 percent which is below the DQO of 27 to 123 percent. The matrix spike
and matrix spike duplicate RPDs for phenol (72 percent) and 2-chlorophenol (77
percent) were above the DQO limits of 42 and 40 percent, respectively.
The surrogate percent recoveries for phenol-D5 in samples QO543RE
(reextraction or reanalysis), 549, and 549RE, 2-fluorophenol in samples QO543,
543RE, 549, 549RE, and 550, and 2,4,6-tribromophenol in sample QO396 were below
their DQOs. These low recoveries will adversely affect the usability of the acid
fraction results.
The semivolatile data are acceptable and the results should be considered
quantitative except for the acid fraction results for samples QO396, 543, 549, and
550 which should be considered unreliable due to poor surrogate recoveries.
Estimated method detection limits are CRDl^_far_alLsamples except QO393 which is
14 times CRDL, QO395 which is 3 times CRDL, and Qb396~whlch is 100 times CRDL.
The probability of false negatives is acceptable with the exception of the three
samples with raised detection limits. False negatives are more likely in the samples
where the detection limits were raised.
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B-7
3.5 Pesticides
The initial and continuing calibrations, and chromatographic quality, with
exceptions, for pesticides were acceptable. The matrix spike, matrix spike duplicate,
surrogate spikes, and holding times were within acceptable limits.
Pesticide method blank chromatograms (samples 9206407 and 919403) show the
presence of an unknown contaminant.
Seven of the 20 pesticide sample chromatograms were unusable due to poor
chromatographic quality. A baseline was not obtained from 3 to 10 minutes into the
run. Any early eluting pesticides peaks, if present, would have been obscured.
Samples affected included QO539, 540, 542, 543, 546, 547, and 549.
Results, especially for early eluting pesticides, for these samples should be
considered suspect.
The estimated method detection limits for the pesticides fraction were CRDL
for all samples except sample QO392 which is twice CRDL. The pesticides results
should be considered qualitative for all samples except QO539, 540, 541, 543, 546,
547, and 549. There is a possible enhanced probability of false negatives for
pesticides.
III. Data Usability Summary
4.0 Graohite Furnace Metals
Quantitative:
Semi-quantitative:
Qualitative:
Unreliable:
4.1 TCP Metals
Quantitative:
Semi-quantitative:
Qualitative:
Unreliable:
4.2 Mercury
Quantitative:
Qualitative:
Unreliable:
antimony results with exceptions
arsenic, cadmium, lead, and selenium results for samples
MQO542, 544, and 551
cadmium and thallium results, both with exceptions; arsenic
results for samples MQO392 and 396; antimony results for
samples MQO394 and 550; and selenium results for samples
MQO393, 394, 396, 536, 537, 540, and 543
arsenic, lead, and selenium results, all with exceptions;
antimony results for MQO395, 545, and 546; cadmium results for
MQO546 and 547
all aluminum, calcium, magnesium, sodium, and vanadium results
all beryllium, chromium, cobalt, iron, nickel, and
potassium, results; zinc results with exceptions
all barium, copper, and manganese results and zinc results for
samples MQO392, 393, 394, 395, and 396
all silver results
all mercury results with exceptions
mercury results for samples MQO393, 394, and 396
mercury results for samples MQO392 and 395
10
-------
B-8
4.3 Inorganic and Indicator Analvtes
Quantitative:
Semi-quantitative:
Qualitative:
Unreliable:
4.4 Organic;
Quantitative:
Qualitative:
Unreliable:
Suspect:
all cyanide, sulfate, sulfide, chloride, and total dissolved solids
results; TOX results for samples MQO542, 543, and 544;
and POX results for samples MQO393 and 539
all bromide, nitrate nitrogen, nitrite nitrogen, ammonia,
and TOC results; and total phenol results for samples MQO392,
393, 394, 395, 396, 540, 543, and 548
all POC data; POX results for sample MQO392
total phenols, TOX, and POX results, all with exceptions
all volatiles results; semivolatiles results with exceptions
pesticides results with exceptions
semivolatile acid fraction results for samples QO396, 543, 549,
and 550
pesticides results for samples QO539, 540, 541, 543, 546, 547,
and 549
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
Quality Control Data Evaluation Report for USPCI, Utah, 10/17/1986, Prepared
by Lockheed Engineering and Management Services Company, Inc., for the US
EPA Hazardous Waste Ground-Water Task Force.
Draft Inorganic Data Usability Audit Report and Draft Organic Data Usability
Report, for the USPCI, Utah site. Prepared by Laboratory Performance
Monitoring Group, Lockheed Engineering and Management Services Co., Las
Vegas, Nevada, for US EPA, EMSL/Las Vegas, 10/21/1986.
11
-------
B-9
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LIMITS OF QUAHT1TATION FO* OMAMIC COMPOUNuS
USKI
fantsy Mountain Facility, Utah
B-ll
Linit of
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Volatile Compounds (Purge & Trap)
BromojMthane 20
Chloronethane 30
BroiiodichloroACthane 20
OibromochloroMthan* 10
Broftofor* 10
Chlorofora 20
Carton tetrachloride 10
Carbon dlsulfide 20
Chloroethane 10
1,1-Oichloroethene 20
1,2-Oichloroethane 10
1,1,1-Trichloroethane 20
1,1,2-Trichloroethane 10
1,1,2,2-Tetrachloroethane 10
1,1-Dichloroethane 20
trans-l,2-Dichloroethene 20
Trichloroethene 10
Tetrachloroethene 10
Methylene chloride 20
Vinyl chloride 20
1,2-Dichloropropane 20
cis-l,3-0icmoropropene 10
trans-l,3-Dichloropropene 20
Benzene 10
Chlorobenzene 10
Ethyl benzene 10
Toluene 20
irXylene 10
o & p-Xylene 30
:etone 10
-Butanone 20
"2-Hexanone 20
4-Methyl-2-pentanone 20
2-Chloroethyl vinyl ether 20
Styrene 10
Vinyl acetate 20
Setii-Volatile Compounds '
4-Chloroaniline 20
2-Nitroaniline 100
3-Nitroaniline 100
4-Nitroaniline 100
3,3'-Oichloroben2idine 40
Benzyl alcohol 20
1,2-Oichlorobenzene 20
1,3-Dichlorobenzene 40
1,4-Oichlorobenzene 20
1,2,4-Trichlorobenzene 20
. Hexachlorobenzene 20
Nitrobenzene 20
2,4-Oinitrotoluene 40
2,6-Dinitrotoluene 20
, N-Nitrosodiphenylamine 20
N'Nitrosodipropylamine 20
bis(2-Chloroethyl) ether 20
4-Chlorophenyl phenvl ether 20
4-Bromophenyl phenyl ether 20
bi$(2-Chloroisopropyl) ether 20
bis(2-Chloroethoxy) aethane 20
Hexachloroethane 20
^^lexachlorobutadiene 20
^Pซxach1orocyclopentadiene .30
Seซi-Volatile Compounds (cont.)
bis(2-Ethylhexyl) phthalate 20
Butyl benzyl phthalate 20
di-n-8utylphthalate 20
di-n-Octylphthalate 20
Oiethylphthalate 20
Dimethylphthalate 20
Acenaphthene 20
Acenaphthylene 20
Anthracene 20
Benzo(a)anthracene 20
Benzo(b)fluoranthene and/or
Benzo(k)fluoranthene 20
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-Hethylnaphthalene 20
Phenanthrene 20
Pyrene 20
Benzoic acid 100
Phenol 20
2-Chlorophenol 20
2,4-Dichlorophenol 20
2,4,5-Tn'chlorophenol 100
2,4,6-Trichlorophenol 20
Pentachlorophenol 100
4-Chloro-3-methylpheno1 20
2-Methylphenol 20
4-Methylphenol 20
2,4-Oinethylphenol 20
4,6-Oinitro-2-ซethylphenol 100
2-Nitrophenol 20
4-Nitrophenol 100
2,4-Oinitrophenol 100
Pesticides/PCBs
Aldrin
alphซ-BHC
beta-BHC
gaปa-6HC
delta-BHC
Chlordane
4,4'-000
4,4'-DOE
4,4'-OOT
Dieldrin
Endosulfan I
Endosulfan II
Endosulfan sulfate
Endrin
Heptachlor
Heptachlor epoxide
Toxaphene
Methoxychlor
Endrin ketone
PCB-1016
PCB-1221
PCS-1232
PC8-1242
PCS-1248
PCB-1254
PCB-1260
Limit of
Quantitation
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