EPA 700-8-87-010
Hazardous Waste Ground-Water
Task Force
Evaluation of
U.S. Ecology Facility
Beatty, Nevada
6ER*
UNTTED STATES EWRONMENTAL PROTECTION AGENCY

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                           UPDATE
          HAZARDOUS  WASTE GROUND WATER TASK  FORCE
    EVALUATION OF U.S. ECOLOGY'S BEATTY, NEVADA FACILITY


  The  United States Environmental  Protection  Agency's
 Hazardous Waste Ground Water Task  Force (Task Force),  in  con-
 junction  with the Nevada Department  of  Environmental Protection
 conducted an evaluation of the ground water monitoring program
 at  U.S. Ecology's hazardous waste  disposal  facility  located
 near Beatty, Nevada.  The site investigation  took place between
 October 20-24,  1986 which included sampling of the facility's
 ground water monitoring wells.  The  objectives of this investigation
 were to (1) determine the facility's degree of compliance with
 applicable ground water regulations  of  the  Resource  Conservation
 and Recovery Act  (RCRA), (2) determine  whether or not  ground
 water  contamination has occurred at  the facility and (3)  make
.recommendations directing the  facility.towards obtaining
 compliance.

  U.S. Ecology  is one of 60 facilities  nationwide that have  been
 evaluated by the Task Force.   The  Task  Force  ground  water in-
 vestigations were initiated in response to  concerns  expressed.by
 Congress  and the public over whether operators of hazardous
 waste  treatment, storage and disposal facilities, were  complying
 with State and  Federal ground  water  regulations.

  Results of the ground water  sample analyses  indicated  cne
 presence  of several organic compounds at  low  concentrations  in
 one of U.S. Ecology's ground water monitoring wells  (307).
 These  results have  been confirmed  by U.S.  Ecology which  must
 now perform a ground water assessment to determine the source
 and extent of the ground water contamination  which has occurred.
 U.S. Ecology has submitted a ground  water  assessment plan to
 address this problem in a. report dated  April  15,  1987.   However,
 additional work beyond the scope of  this report will be  required
 to  adequately define the exact source and  extent  of  the  contamina-
 tion.

  U.S. Ecology  is presently in the final stages of obtaining
 a\ permit, to allow continuation of  operations  of  its  hazardous
 waste  diposal facility which consists of an existing disposal.
 trench 10 and a PCB drainage and storage  area.  An above-grade
 expansion of trench 10 will also be  allowed under-this Permit.
 The Permit does not include  the  adjacent  low  level radioactive
 disposal  area.  The Permit will also address  the  deficiencies
 found  in  U.S. Ecology's Part B application through permit
 conditions and compliance schedules. The  additional site
 characterization and ground water  contamination assessment
 requirements are contained under the RFI Technical Requirements
 portion of the  Permit while  the  deficiencies  found with  the
 ground water monitoring system are contained  in the  Ground
 Water  Monitoring portion of  the Permit.  The  following is a
 comparison of the Task Force's recommendations with  the
 corresponding portions of the  Permit that  addresses  that issue.

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   4.  Reconaendations

      1. Site Characterization:

         A. A more precise determination of the upper limit of the uppermost
            water-bearing unit must be made through the use of air rotary or  (a)(3)
Permit-     other appropriate drilling method.  Such method must permit detec-
Pg A-a      tion of changes in moisture content of materials as well as detec-
(a)(3)(vi)  tion of the uppermost saturated zone.

         B. Provide petrographic and structural descriptions of the unsaturated
            zone, with particular attention given to the initial clay units
Permit-     encountered, along with the three or more saturated zones which
Pg- A-a      have been identified in the site water supply well..  The logging
(a)(i-v)    of the samples shall be by a qualified professional geologist.
            Samples shall be collected by Shelby Tube, split Spoon or equiv-
            alent sampling device.

         C. Physical testing of the cored samples for the parameters of rois-
Permit      ture content, density, Atterberg  Limits (Conesiveness), sorting,
Pg A-a      and permeability (in-situ testing for the clay units and saturated'
(a)(3)(iii) zones) will be required.  Continuous soil sampling should also be
            conducted for at least the first  50 feet of vadose zone material.

        • D. Construct at least two geologic cross-sections perpendicu-
            lar to one another from data obtained from the exploratory.bore-
Permit-     holes required for the site characterization.  The cross-sections
Pg A- 3     should also include the depths .and thicknessess of all icnes of
(b) (D(iii) saturation.

         E. Determine the aquifer characteristics of permeability, transmissivity,
            storage coefficient and rate(s) and direction(s) of ground
            water flow.  Horizontal permeabilities can be determined through
Permit-     the use of in-situ permeability testing, referred  to above.
Pg A-2.      However, vertical permeability, transmissivity and storage coefficients
(a)(3)(ii)  must be obtained through the use  of pump or aquifer test methods.
            A number of tests, spaced out over the entire facility .will be
            required to determine aquifer characteristics and  the degree of
            variability of these parameters across the site.  —

         P. Further define the extent of the  lower-lying water-bearing units
Permit-     identified in the site water well (at least 3 zones).  Determine
Pg A-2.     whether there is hydraulic connection between the  uppermost water-
(a)(3)(iv,  bearing unit and underlying units.  This can also  be accomplished
vi)         through the use of aquifer tests.
      2. Well Construction:  Due to the inadequacies of the existing ground water
         monitoring system, new monitoring wells will be  required  to replace
         wells 301, 305, 306 and 307 along with additional upgradient and  down-
         gradient monitoring wells.

         A. Screen Length:  The present ground water monitoring wells have screen
Permit-     lengths  of  50. and 70  feet which are too long for  the  purposes of
G.W.        ground water monitoring at specific intervals.  Screen lengths in
Monitoring  the range of 10 to 20  feet should be used.  The exact  length of
(4) (A) (1Kb)

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Permit-G.W.
Monitoring
(4)(A)(l)(c) screen will be dependent on the exact formation conditions encoun-
             tered.  If homogeneous water-bearing units are encountered that are
             significantly thicker than 20 feet, then multiple wells screened over
             10 to. 20 foot intervals covering the entire thickness of the unit should
             be constructed.

         B. Pump Placement.  The position of the pump should be determined from
   "        well production data obtained for each well during the development
            of the well and/or during the previously referred to aquifer tests.

         C. Filter Pack:  The length of the filter pack must be significantly
   "        reduced.  The top of the filter pack should not extend more than a few
            feet above the top of the screened interval.  The filter pack must
            be sized to the formation which is being screened through the use
            of seive analyses.

         D. Screen Slot Size/Spacing   This should be determined after the size
            o£ the filter.pack has been determined.  Screen slot size should
   "        conform to the size characteristics of the gravel pack, not of the
            formation.

   "     E. Bentdnite Seals:   Seals should be placed immediately above the filter
            pack followed by a grout seal.


      3. Other Recommended Activities:                  .    '

         A. Conduce an assessment of che contaminacion.which has occurred ir.
Permit-     the vicinity of well 307 which would include a deliniation of the
Pg A- 9      horizontal and vertical extent of the contaminant plume(s), dir-
(C)(l)(a-f) ections and rates of movement (vertical and horizontal) of the
            ground water plume(s).

         B. Initiate a new investigation aimed at determining the current
Permit-     extent of contamination in the unsaturated zone which has resulted
Pg A- ^      from the past disposal of phosphoric acid liquors in the south-
(C)(2)(a-c) eastern portion of the facility as well as other potential con-
            tamination which may have occurred as a result of past disposal
            practices in the area of trenches 1-9.   Activities should consist of
            vadose zone monitoring for soil moisture and subsurface gases.
            The objective of this investigation is the determination of whether
            contaminant migration has moved beyond the facility boundary.

         C. Investigate the feasibility of installing a vadose zone monitoring
            system.  The purpose of such a system would be to augment the
Permit-     deep ground water monitoring system allowing the detection of
Pg A- 5"      subsurface contamination in advance of its reaching the ground
(A)(c)(3)   water.  This system would also be incorporated into the facility's
            ground water assessment program which has been triggered following
            the discovery in October, 1986 of ground water contamination  in
            well 307.  Given the high negative values for soil moisture
            potential found in the vadose zone, standard porous cup lysimetry
            may be ineffective in monitoring the limited soil moisture.
            Alternate methods for measuring soil moisture such as Neutron
            Probes should be considered.  The limitations of all vadose
            zone monitoring devices should be considered before a system  is
            selected for use.

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                        TABLE OF CONTENTS                           PAGE

     LIST OF TABLES                                                  1

     LIST OF FIGURES                                     .            2
     LIST OF ABBREVIATIONS                                           3

I.   EXECUTIVE SUMMARY

     A.   Introduction
          1.  General Task Force Objectives                          4
          2.  Task Force Objectives Specific to U.S. Ecology         5
          3.  Task Force Participants/Roles                          5
          4.  Other Task Force Reports                        .       5
     B.   Summary of Findings                                         7

II. TECHNICAL REPORT

     A.   Facility History/Regulatory Milestones                      3
   •  3.   Facility Location/Tcpcgraphic Setting                       15
     C.   Area Geology/Stratigraphy                                   13
     D.   Climate                                                     19
     E.   Site Hydrogeolcgy
          1.  Depth to Ground Water                                  21
          2.  Hydraulic Gradients,  Permeabilities                    22
              Transmissivities
          3.  Hydrogeoiogic Site Characterization                ^  27
     F.   Leachate. Migration Potential  in  trie Unsaturated Zone       29

     G.   Well Evaluation'
          1.  RCPA Designated Ground Water Monitoring '.fells
               a.  Well Placement/Mutter                             33
               b.  Construction  (drilling methods,  materials,       33
                   screens gravel pack, filter pack, annular
                   sealant, casing  etc.)
               c.  Screen Placement/Length                           35
               d.  Development         .                              35

          2.  Non-RCRA wells
               a.  Phosphoric Liquor Investigation  Borings          45
               b.  Unsaturated Zone Characterization/Monitoring     46
                   Wells and Boreholes
          3.  Other Ground Water Wells                              46
          4.  Reccoraendations                                        52
     H.   Analytical Results                                          55
     I.   Facility Laboratory Quality Assurance/Cuality  Control      56
     J.   Compliance with Ground Water  Monitoring  Requirements       56
     K.   Sunroary of Rec&nnendations                                  58

     References                                                      5?

     Appendicies

     APPENDIX A  Ground Water Conditions  Contained  in  U.S.
                 Ecology's RCRA Operating Permit  for their
                 Beatty, Nevada  Facility

     APPENDIX B  Analytical  Parameters For  Ground Water Analysis

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                                     -1-
                        LIST OF TABLES
                                                                      Page


   1:  BEATTY CHEMICAL DISPOSAL (AS OF 4/15/85)                        12

   2:  RCRA INTERIM STATUS MEASURED GROUND WATER ELEVATIONS            24

   3:  RCRA MONITORING WELL SPECIFICATIONS      •                       42

4/4A:  NON-RCRA VADOSE ZONE MONITORING WELL SPECIFICATIONS         '    43/44

   5:  NON-RCRA VADOSE ZONE MONITORING WELL SPECIFICATIONS             50

   6:  NON-RCRA SHALLOW MONITORING WELL SPECIFICATIONS   .              51

   7:  COMPARISON OF TASK FORCE AND U.S. ECOLOGY'S SAMPLING            57
         RESULTS

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                                   -2-
                     LIST OF FIGURES
                                                                 Page
 1:  U.S. ECOLOGY BEATTY, NEVADA DISPOSAL FACILITY                 13

 2:  AREAL EXTENT OF PHOSPHORIC LIQUOR INTRUSION'                  14

 3:  PCS PROCESSING FACILITIES LOCATION   '                         15

 4:  LOCATION OF STUDY AREA                                        17

 5:  PROXIMITY OF DISPOSAL AREA TO HIGHWAY 95      •                18

 6:  GEOLOGIC HAP OF ARMAGCSA DESERT      •                         20

 7:  GENERALIZED FENCE DIAGRAM OF LOCAL GEOLOGY                    23

 8:  LOCATION OF ROSA GROUND WATER MONITORING WELLS                36
         AND OTHER GROUND WATER WELLS

 9:  MONITORING WELL CONSTRUCTION. SCHEMATIC         '               37

10:  COMPLETION DIAGRAM FOR MONITORING WELL-301                   .33

11:  COMPLETION DIAGRAM fCR MONITORING WELL. .2C5                    23

12:  COMPLETION DIAGRAM FOR MONITORING WELL 306                    40

13:  COMPLETION DIAGRAM FOR MONITORING WELL 307                    41

14:  NCN-RCRA VACCSE ZONE MONITORING WELL LOCATIONS                48

IS:  NCtMOA SHALLOW GROUND WATER MONITORING WELL                 49
     LOCATION  '

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       LIST OF ABBREVIATIONS USED IN THIS REPORT



AEC- Atonic Energy Commission

GEM- Camp Dreeser and Mckee (EPA contractor)

CLP- Contract Laboratory Program

CME- Comprehensive Monitoring Evaluation

EPA- Environmental Protection" Agency

RFA- RCRA Facility Assessment

RFI- RCRA Facility Investigation

HWS«rrF- Hazardous Waste Ground Water TasK Force

HSWA- Hazardous and Solid Waste Amendments

MDEP- tevada Department of Environmental  Protection
                 V
NECC— Nuclear Engineering Company

\'CD- totice of Cejficiancy

NRC- Nuclear Regulatory Commission

PC3- Polychlorinated Biphenol

PRC- Planning Research Corporation  (EPA contractor)

RCRA- Resourse Conservation and Recovery  Act

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                                       -4-
I.  EXECUTIVE SUMMARY
A.  Introduction

    In January, 1985, the Administrator of the Environmental
    Protection Agency (EPA) formed an investigatory group known
    as the Hazardous Waste Ground Water Task Force (HWGWTF)
    to conduct nationwide ground water investigations at 58
    ccnmercial and generator^owned hazardous waste disposal
    facilities.  The primary objectives of these  investigations
    are to:

     1.  General Objectives;

          a.  Determine the degree of compliance  with ground
              water monitoring requirements of 40 CFR Part  265,
              Subpart F- 3CRA Laterim Status;

          b.  Determine the degree, of compliance  with ground
              water informational requirements of 40 CFR Part
              270.14(c) of the RCRA Part B application.

          c.'  Determine whether ground water contamination  is
              occurring or has occurred during. the operating
              histories of these facilities and whether these
              facilities currently pose i threat  to riusvan  isalch
              and the environment.

          d.  Address deficiencies found, and propose solutions
              enabling facilities to achieve compliance with  the
              RCRA regulations.  Recommendations  may  include
              enforcement actions, compliance schedules/permit
              conditions, remedial/corrective actions or other
              measures designed to bring the facilities  into
              compliance.

          «.  encourage state participation, promote cooperation
              between state and federal agencies, and provide the
              states with first-hand experience  in the conducting
              of this type of in-depth investigation which should
              be of assistance when states conduct CME's  (Compre-
              hensive Monitoring Evaluations), or are assisting
              in the conducting of RFA'g  (RCRA Facility Assess-
              ments), and RFI's (RCRA Facility Investigations).

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                                  -5-
 2.   Specific  Objectives:

     In October,  1986,  the  HWGWTF conducted their investiga-
     tion at U.S.  Ecology's hazardous waste disposal facility
     located near the town  of Beatty, Nevada.   In addition
     to,  and in conjunction with the primary Task Force
   '  objectives stated above, the Task Force investigation
     at U.S. Ecology sought specifically to determine if:

      1.   The  ground water  monitoring wells are capable
          of detecting releases from the regulated RCRA
          hazardous waste management units, specifically
          Trench 10.  This  includes an investigation of the
          adequacy of the site characterization.

      2.   "The  RCRA ground water monitoring wells have been
          constructed properly.

      3.   U.S.Ecology has developed and has implemented an
          adequate plan for the sampling and analyses of
          ground wacer.

      4.   The  Laboratories  contracted by U.S.Ecology are
          producing analytical results which are of
          abie accuracy and precision.

I.  Task "ores  Participants/Poles
     Mitch Kaplan- EPA Region IX Project Leader

     Dan Sullivan- Task Force Core Team Representative

     Donn Zuroski- EPA Region IX Sample Team Leader

     John Hatcher, Con Paquette and Pat.Cobak- Versar, Inc.
                   Sampling Team

     Tbn Fronapfel- NDEP State Representative

     Claire Elliott- EPA Region IX Permit Writer- U.S. Ecology


 4.   Other Task Force Reports:

     In addition to the Technical Report, reports have been
     prepared covering the other aspects of the Task Force
     investigation at U.S. Ecology.  These reports are listed
     below along with the report's author.

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                                 -6-
1.  Facility Sample Audit- Evaluation of U.S. Ecology's
    ground water sampling procedures, Sept., 1986 by
    Donn Zuroski

2.  Report on Sample Collection Documentation at U.S.
    Ecology, October, 1986 by Donn Zuroski

3.  Report on the Laboratory Audit of C.E.P. Laboratories,
    Inc. Santa Fe, New Mexico by GEM. September, 1987

4.  Audit of U.S. Ecology's Cn-Site Laboratory Facilities
    September, 1986 by Donn Zuroski

5.  Data Analysis Report for Technical Support of U.S.
    Ecology Hazardous Waste Ground Water Task Force Inves- .
    tigation, Beatty, Nevada September, 1987 by CDM

5.  Validation of Selected Historical Ground Water Data  fron
    U.S. Ecology by PPC for GEM, September, 1987

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                                      -7-


B.  Summary of Findings

     1. RCRA Interim Status Requirements:

          a.  Well Placement/Number- U.S. Ecology currently has
              four ground water monitoring wells, which meet  the
              minimum requirement of one upgradient and three
              downgradient wells.  However more additional wells
              will be required to provide adequate coverage for
              the trench system.  The three downgradient wells
              (305, 306, and 307 as designated by U.S.  Ecology)
              are at the compliance point of trench 10.  Well
              301 is located an adequate distance frcra trench  10
              so as not to be affected By that trench.  The
              determination of whether the existing wells are
              properly designated as upgradient and downgradient
              will depend on the results of the additional hydro-
              geologic characterization.  Fart of this charac-
              terization will consist of a more precise defini-
              tion of the local ground water flow direction.

          b.  Weil Construction- Inadequacies  in well design
              and construction include excessively  long screened
              intervals of 50 to 70 feet, excessively long gravel
              packs ranging from 103 to  235 feety insufficient
              data on thicknessess and composition of bentonite
              seals and che improper design of ^~.e  .veil intake
              system.

          c.  .Sampling and Analaysis Plan- A review of U.S.
              ecology's Sampling and Analysis  Plan was made by
              Conn Zuroski and are contained in the report
              entitled U.S. Ecology Beatty Facility Ground Water
              Sampling Audit September,  1986 Deficiencies were
              found in sampling procedures, preservation methods,
              chain of custody and shipment procedures.  A com-
              parison between U.S.  Ecology's  September,  1986
              sailing and their sample  plan is made along
              with recommendations to correct  the deficiencies
              previously identified.

          d.  Laboratory Audit- A laboratory :.
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                                 -8-
2.  RCBA Ground Water Informational Requirements Part
    270.14(c)  Part B Application

     a.  Site Characterization (270.14)(c)(2)- The method of
         drilling incorporating drilling mud has prevented
         identification and detailed description of sub-
         surface materials.  Lithologic descriptions are
         only of a general nature, physical testing of the
         materials are inadequate or absent, and continuity
         of lithologic units across the facility has not
         been determined.

     b.  Uppermost Aquifer (270.14)(c)(2)- The drilling
         method used has not allowed the definition of the
         top of the uppermost aquifer to be made.  .Only a
         general ground water flow direction and gradient
         are known, degree of hydraulic connection between
         the uppermost aquifer and underlying waterbearing
         units is unknown, and whether the uppermost aquifer
         exists under confined, semiconfined, water table
         conditions or a combination thereof is unknown.
         Aquifer characteristics of permeability, transmisr
         sivity and rate of ground water movement have not
         been properly defined.

     c.  Plume Description '(270.14)(c)(4)- A description of
         che joncencracion and <_-xcont oc ground -acer con-
         tamination in well 307 and vicinity has not been
         completed by U.S. Ecology.  Ground water assessment
         monitoring will be accomplished through the permit
         conditions (See Appendix A).

3.  Ground Water Contamination;

    Ground water contamination has been detected in U.S.
    Ecology's well 307 as indicated by water quality data
    obtained during the Task Force's October/ 1986 sampling.
    A total of nine (9) volatile organics were detected, all
    in the part per billion (ppb) range.  The compounds are:
    1,1 DICHLOFOETHENE, 1,1 DICHLCROETHANE, CHLOROFORM,
    1,1,1 TISCHLOROETHANE, CASBCH TETFACHLORIDE, TKECHLORC-
    EIHENE, BENZENE, TEIEACKK.3C ATHENE and TOLUENE.  In
  .  addition, ACETONE, CARBCN Cr.-ULFIDE> ETHYL BENZENE and
    TOTAL XXLENES, also in the ppb range were detected by
    U.S. Ecology in their sample split.  These compounds
    were not detected by the Ground Water Task Force.

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                                       -9-
II.   TECHNICAL REPORT
 A.   Facility History/Regulatory Milestones

     The Beatty Nevada facility was first opened and permitted  for
     the disposal of low-level solid radioactive wastes in 1962 by
     the Atomic Energy Commission (AEC), which later became the
     Nuclear Regulatory Commission (NRC).  U.S. Ecology, Inc. was
     known at that time as Nuclear Engineering Company, Inc.(NECO).
     U.S. Ecology currently leases the land used for chemical
     hazardous waste disposal from the State of Nevada.   In 1972,
     the AEC transferred the responsibility of licensing and •
     regulation of the low level radioactive disposal site to the
     State of Nevada.  The low level radioactive wastes were and
     are currently being disposed of in cut-and-cover trenches
     which are located at the western side of the property (Figure
     1 ).  Trenches  1 through 21 are now closed.  Trench 22 was
     opened in 1981 and is the only active trench in which low
     Level radioactive wastes are being .disposed.  The wastes
     consist of materials that have been exposed to radiation and
     are therefore considered contaminated.  The disposal area  is
     separated from the chemical disposal area by a buffer zone
     approximately 200 feet.wide.  Typical trench dimensions are
     20-25 feet deep, 40-50 feet wide and up to 600 feet in length.

     In  1970, hazardous wastes began to be disposed of  in trenches
     located in the southeastern portion of the property (Figure
    • 1).  Both solid and liquid hazardous wastes were initially
     accepted including phosphoric acids.  Trenches numbered  1-5
     were first utilized for waste burial, but insufficient docu-
     mentation exists to define the exact dimensions or locations
     of these trenches.  Between 1973 and 1978, a waste pile
     which overlies portions of the non-RCPA trenches in the
     southeastern portion of the facility/ was used to dispose  of
     approximately 1.2x106 cu.ft. of phosphoric acid mixed with
     soil.  Table 1 presents waste quantities disposed of in  the
     trenches.  The blending of phosphoric acid liquors with  soils
     was initiated to reduce the leakage of these liquids into  the
     subsurface that had been detected  in shallow monitoring wells
     1 and 2 in 1973 (Figure 2 ). Liquid contamination consisting
     of phosphoric acid liquors were detected  in shallow borehole
     13 in the late 1970s (probably 1978), which resulted in  the
     cessation of phosphoric acid disposal at  the facility.

     In  1978, a permit was issued to Nuclear Engineering Company,
     Inc. by EPA allowing the disposal  of PCS  (Polychlorinated
     Biphenols) contaminated materials.  The PCS waste consist  of
     an  inert material such as empty transformer carcasses, empty
     steel drums and soils which have come in contact with
     PCBs either through normal usage or from  spills.  The PCBs

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                                     -10-
    are removed from containers during cleaning and flushing
    operations and placed in storage tanks with a combined capa-
    city of 25,000 gallons.  These tanks are located immediately
    south of active trench 10 and overlying portions of closed
    trenches 6 and 9 (Figure 3)-.  The PCBs are then shipped to an
    approved incinerator for destruction.  The PCS contaminated
    materials are placed in a segregated portion of trench 10.  At
    the present time only trench 10 is in operation as a disposal
    area for hazardous wastes.  U.S. Ecology currently has plans
    for the permitting of another disposal trench for both PCB
    and hazardous wastes.  U.S. Ecology currently accepts wastes
   . identified by the characteristics of Ignitability (D001),
    Corrosivity (D002), and EP Toxicity (D004-D017).  Wastes
    exhibiting the characteristic of Reactivity (D003) are not  •
    routinely accepted unless rendered non-reactive by treatment.
    Part A of U.S. Ecology's application also indicates that
    listed wastes are accepted:  F (Hazardous waste from non-
    specific sources), K (Hazardous wastes from specific sources),
    and ? and U wastes (Hazardous Wastes consisting of discarded
    commercial products, off specification species, container and
    spill residues having acutely hazardous and toxic characteris-
    tics, respectively).

  .  The following is an outline of the regulatory events which  .
    haw occurred concerning U.S. Ecology's Beatty, Nevada
    disposal facility:

    1961-  Facility opened as Nuclear Engineering Company, Inc.
           for the disposal of solid low-Level radioactive
           wastes.  The initial permit was obtained from the AEC.

    1970-  Hazardous wastes first accepted at the facility.

    1978-  A permit for disposal of PCB-contarainated materials
           was issued by EPA Region 9.

11/19/80-  Nuclear Engineering Company, Inc. submitted the
           original Part A application to EPA Region 9 and
           obtained Interim Status authority to continue
           operations until a final RCPA permit is  issued.

  1/1/81-  Nuclear Engineering Company, Inc. became U.S. Ecology,
           Inc.

12/22/92-  3007 Letter sent to U.S.Ecology outlining deficiencies
           noted during an inspection by NDEP.

  3/3/83-  U.S. Ecology submitted a waiver request package for
           ground water monitoring

 7/20/83-  A revised RCPA Part A application is submitted to  EPA
           region 9.

 7/30/83-  A RCPA Part B application was submitted  to EPA Region 9.

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                                        -11-
              U.S. Ecology submitted a revised waiver request for
              ground water monitoring.

              3008 Warning Letter transmitted a Notice of Deficiency
              (NOD) to U.S. Ecology from EPA Region 9-outlining
              deficiencies in the submitted Part B application,
              including deficiencies with their ground water monito-
              ring program.

              U.S. Ecology withdraws waiver request for ground water
              monitoring.

              An Administrative Order is issued by the Nevada
              Department of Environmental Protection  (NDEP) requi-
              ring the installation of a ground water monitoring
              system as required under 40 CFR, Part 265, Subpart F.
              This Order in effect denied U.S. Ecology's waiver
              •request for ground water monitoring.

              Three (3) ground water monitoring wells are installed
              in order to comply with the 265 ground water monito-
              ring requirements.

              3008 Warning Letter transmitted a second MCD to U.S.
              Ecology from EPA, which included deficiencies still
              outstanding from -the Administrative Order  issued by
              the :-!EEP on 5/14/84.

              EPA submitted additional cements regarding Part B
              deficiencies including ground water monitoring and
              subsurface site characterization to the tfDEP.

       8/86-  A new dedicated well sampling system was installed.
              Prior to this, well purging and sampling was
              accomplished by bailing.

10/20-24/86-'  Qraund Water Task Force Sampling Investigation

   11/21/86-  NDEP issued a third NOD covering the Part  B applica-
              tion.  It included EPA's 12/28/86 comments regarding
              the current status of U.S.  Ecology's ground
              water monitoring system and hydrogeologic  site
              characterization.
    7/84-



10/30/84-





 1/28/86-

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                                         -12-
             TABLE 1;  BEATTY CHEMICAL DISPOSAL (AS OF 4/15/85)
UNIT
1*
2

3

4

5

6


^

3

9

10

—
TYPE
LANDFILL
TRENCH
it

n

n

n

H


n

N

•

•

WASTE PILE
OPERATING
STATUS
CLOSED
CLCSED

C10SED

C1CSED

CLCSED

CLOSED-
WASTE
DESCRIPTION
• ACID/PHGS-
ALID
GENERAL

ACIDS

GENERAL

UNKNOWN

G(NERAL
I

CLCSED

C1CSED

CLCSED

OPERATING

CLCSED

Ge.'ERAL/
PHCS-ACID

PHCS-ACID

GENERAL

GENERAL

PHCS-ACID/
SOIL
APPROXIMATE
DIMENSIONS (FT)
300x100x10
350x40x20

350x4x10

350x40x20

350x40x20

550x70x30
. WASTE
QUANTITY (OJ. FT
4
7.5x10
4
7.0x10
3
3.5x10
4
7.0x10
4
7.0x10
5
2.39x10
. '

350x100x20

300x60x25

550x70x30

580x580x50

N/A
5
2.62x10
3
9.6x10
c
2.09x10
6
3.99x10
6
1.2x10
*   APPROXIMATE SUMMATION OF ALL SMALL UNITS FOUND ON OLD DRAWINGS
**  PER BEST DOCUMENTATION AVAILABLE

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        FIGURE 1:  MAP OF U.S. ECOLOGY'S LOW LEVEL RADIOACTIVE


                AND HAZARDOUS WASTE DISPOSAL AREAS


       	r*	— —T	T	
                                       HAZARDOUS  WASTE

                                       MANAGEMENT AREA
                                            WBLr.trrj J.u
                                            3Z£33bim3~^
                                                FUTURE  ,

                                                LANDFILL  :t
                                                -AREA-
 ^r::        ri-
         •  ''  t
:===^r?3™ \
                                                                   MAI I

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                           14
N
                        PHOS'HATt UOUC*
                         DISPOSAL

                                                    mttttt
0

^

I^J

X
                                               ;AI.£ ' i I»CA « l-
         «Ht<««»4 *•
                            Source: Nucf««r Engineering Co^ Inc. 1973

   FIGURE   2    AREAL EXTENT OF PHOSPHORIC
                        LIQUOR INTRUSION

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         Sill CLAN





             Seal* »"=IOO
                             Source: US Ecology 1984
FIGURE
PCB PROCESSING FACILITIES LOCATION

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                                     -16-
B.  Facility Location/Topographic Setting

    U.S.Ecology's hazardous waste disposal  facility  consists  of
    an 80 acre tract of land located in the Armagosa  Desert 11
    miles southest of the town of Beatty, Nye County,  Nevada,  18
    miles northwest of Lathrop Wells, Nevada, approximately 20
    miles east of Death Valley, California and approximately  100
    miles northwest of Las Vegas, Nevada (Figure 4).   U.S. 95,
    a two laned paved road serving as the principle  highway link  .
    between Las Vegas and Reno, Nevada, passes approximately  1100
    feet northeast of the northeastern corner of the facility
    (Figure 5).  Land elevations at the facility range from 2770
    to 2786 feet above sea level.  The general topographic trend
    of of the valley is to the southeast with the facility
    situated on the northeastern side of the valley  which is
    dissected by the Amagosa river bed.

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                                          17
38*30-

                                ^,.^ STUDY AREA

                                   '
                               V.
                    »    30
                     I	 |
                                                                   \
                                 « 4:   LOCATION OF  STUDY  AREA

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                                     18
FIGURK:  5    PROXIMITY OF DISPOSAL AREA TO HIGHWAY  95
       EXPLANATION
              r«dio«ctr»«-*«tt
      burial VM, 1980
 m
        r ad «»«»•••«•»•»«
burial arta b«
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                                     -19-
C.  Area Geology/Stratigraphy

    This portion of southern Nevada lies within the Basin and Range
    Physiographic Province, Death Valley Subprovince,  which  is
    characterized by broad, open, relatively flat-floored valleys
    separated by rugged mountain ranges.  The  facility is located
    within a broad linear valley trending northwest to southeast.
    The Valley is bounded on the west by the Funeral Mountains, on
    the north by the Bullfrog Hills and on the Jtorthwest by.  the
    Grapevine Mountains (Figure 6).  These mountains are composed
    of Lower Paleozoic carbonate and clastic sedimentary rocks.   In
    places, intrusions of Tertiary aged igneous rocks  can be found.
    Volcanic rocks, primarily basaltic and rhyolitic lavas and
    tuffs, are quite ccmnon especially in the  areas upslope  of  the
    facility.  The valley floor is assumed to  be underlain by rocks
    of similar composition, although limited exploratory drilling
    in the area has not penetrated the bedrock.

    The-valley fill deposits consist of sands, gravels and cobbles
    of local origin, primarily volcanic rocks, which have been
   • transported into the valley by a combination of gravity  move-
    ment and water with.the sediments having originated from the
    surrounding mountains.  Sajada or alluvial fan deposits  are
    primarily very coarse-grained which grade  finer with increased
    distance from che mountains.  Cesert  flac  materials are  a
    combination of fine to coarse-grained materials laid down at
    the lower ands of alluvial  fans .and 'daceriais  .-i-jcosited  in
    valley stream beds and basinal lakes.  The thicknesses of these
   . unconsolidated deposits range from at  least  560  feet  in  the
    northern Annagosa Desert to 790 feet near  Lathrop  Wells  (1).

D.  Climate

    The U.S.Ecology'facility lies in a desert  region,  its climate
    characterized as arid.  Mean annual precipitation  ranges from
    2.9 inches at Lathrop Wells to 4.5 inches  at Beatty (2). Pre-
    cipitation is extremely variable in terms  of times of occ.rence,
    length and intensity of rainfall events.   The  majority of the
    yearly rainfall occurs during the winter months  (November
    through April).

    Temperature ranges are extreme, typical of this arid environ-
    ment.  Minimun/maximum monthly temperatures range  from -3/12
    degrees C in January to 17/37 degrees C in July.   Potential
    evapotranspiration  rates have been estimated  for  this  site  in a
    number of reports.  Values range from greater  than 91 centi-
    meters/year (1), a  16 year average of  190  centimeters/year  (2)
    to 250 centimeters/year (3).  In all cases evapotranspiration
    exceeds precipitation.  Accurate determinations of evapotrans-
    piration is difficult  in this case due to  the  sparcity of the
    meteorological data.
 1  Walker and Aekin,  1963
 2  Nichols,  1986
 3  Grant and Associates,  1984  Ground Water Monitoring Program
    meteorological data.

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                EXPLANATION
                   DRAINAGE-BASIN BOUNDARY

                   VALLEY-FILL .'.iDlMENTARY DEPOSITS

                   SEDIMENTARY ROCKS

                   METAMORPHIC ROCKS

                   VOLCANIC ROCKS

                   WASTE -BURIAL SITE
FIGURE 6:  GEOUXTf OF TOE ASMAGOSA RIV^H REGION
          OF SOUTffiRN NEVADA AHD ADJACENT CALIFORNIA

                             20

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                                     -21-
E.  Site Hydrogeology

     1.  Dapth to Ground Water

        . U.S.Ecology has had a number of geotechnical and
         hydrogeologic investigations performed  from which deter-
         minations of the depth to the upper-most aquifer have
         been made.  The site well was the first well drilled at
         the facility in 1961 and is also the deepest exploratory
         boring at 575 feet.  The upper-most water-bearing zone
         was identified by U.S. Ecology as lying between the 326
         and 340 foot depths.  However, due to the drilling
         method used, there remains the uncertainty as to
         whether ground water exists at a level  shallower than
         that identified by U.S. Ecology.  See Hydrogeologic Site
         Characterization section.  The drillers logs contained
         in the Clebsch report indicates a potential water-
         bearing zone consisting of boulders, gravels and sands
         underlying a zone of clays approximately 60 feet thick.
         Three other potential water-bearing zones are also
         identified at depths ranging to the bottom of the
         boring.  These zones also consist of gravels, sands and
         boulders with seme intermixed clays.  Intervening strata
         cons: t of clays, clayey  limestones and calcareous
        ' clays.  The upper-most boulder/gravel/sand zone can be
         trace;: beneath trench 10 as evidenced by the drillers
         log descriptions of borings 304, 305 and 306.  The
         relative paucity of gravels as described in  the drillers
         logs of borings 305 and 306 compared to the abundance of
         gravels as described in the log of boring  307 provides .
         some evidence of a thinning of this unit to the north
         and east.  The thickness of alluvial material comprising
         the unsaturated zone averages approximately  300 feet
         based on the results of the facility's  previous geotech-
         nical studies and through installation  of its ground
         water monitoring system.  This material varies from
         partially cemented to unconsolidated silty sands and
         gravels with boulders.  Figure 7 is a block diagram of
         th» local stratigraphy.  This diagram was produced by
         U.S. Ecology from data obtained from the logs of wells
         304, 305 and 306.

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                                -22-
2.   Hydraulic Gradients/Permeabilities/Transmissivities

    U.S.Ecology has made-an estimate of the regional
    hydraulic gradient in the upper-most aquifer based on
    the water levels as measured in the site water supply
    well and in two domestic water supply wells located
    14 and 17 miles downgradient of the facility.  The
    hydraulic gradient was estimated by the facility to be
    approximately 30 feet/mile in a southeasterly direction
    following the trend of the alluvial valley.  Calcula-
    tions of the hydraulic gradient at the facility were
    made during preparation of this report using the water
    level data obtained during Interim Status ground water
    monitoring.  Calculations using these water level
    measurements yielded hydraulic gradients ranging from 94
    feet/mile to 133 feet/mile in a southeasterly direction.
    Averaged values for water levels for each well were used
    in iiaking these calculations.  Fluctuations in water
    levies ranged from 2 feet in well 301 to 15 feet in -veil
    307.  Causes of the fluctuations may have been the result
    of sampling or measuring errors.  These fluctuations are
    extremely large and probably are not naturally occurring.
    Table 2 summarizes the water level data that was available
    for these calculations:

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                                                                  23
              FIGURE  7:    GENERALIZED  FENCE DIAGRAM OF  LOCAL GEOLOGY
                                                                                                        WELL . 106
                                       -  -  -^____ -     -—    m
                                       -*:^c'''''     ;
                                                                                                                  — 2680
                                                                                                                  —  2580
                                                                                                                          ftiVAIION
                                                                                                                            III
                                                                                                                           Utt
                                                                                                                  —  2180
                                                                                                                   ICMCiNfB
                                                                                                                   IMUIIVAL
  2180-
ICIKMtP
IMIIIVAL
  2»80 —
_  .
     ilttfAU
cza ctA»
     tin

7^3 »*»«»
                                                                                  IMIIMVAL
                                                                                                                            AUG. a.
                                                          Mil
                                                                                              FKOM:   U.S.  ECOLOGY PART  »

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                                          -24-


                                  TABLE  2

                INTERIM STATUS HCRA GROUND WATER ELEVATIONS
 DATE
WELL    DEPTH-TO WATER  (FEET)   WATER  LEVEL ELEVATION (FEET)
2/09/85
2/09/85
1/13/85
2/06/85
3/04/85
3/06/85
3/06/85
3/05/85
4/08/85
4/11/85
4/10/85
4/09/85 .
4/12/85
4/26/8*
4/25/85
4/ 23, 35
4/22/85
4/24/8S
5/16/85
5/28/85
5/24/85
5/23/85
5/29/85
6/24/85
V27/8S
6/25/85
6/26/85
6/2C/85
7/30/85
7/24/85
7/26/85
7/29/85
7/25/85
. 301
304
305
306
301
304
305
306
301
304
305
306
307
301
304
305
306
307
301
304
305
306
307
:oi
304
305
306
307
301
304
305
306
307
                            287
                            304
                            304
                            312

                            286
                            307
                            305
                            312

                            286
                            306
                            305
                            312
                            310

                            287
                            305
                            :o~
                            302
                            311

                            287
                            310
                            310
                            300
                            312

                            287
                            310
                            308
                            300
                            312

                            287
                            310
                            312
                            300
                            320
                                           2496.39
                                           2475.36
                                           2471.71
                                           2464.88

                                           2497.89
                                           2472.36
                                           2470.71
                                           2464.88

                                           2497.39
                                           2473.36
                                           2470.71
                                           2464.88.
                                           2469.39

                                           2496.89
                                           2474.36
                                           2463.71
                                           2474.88
                                           2468.39

                                           2496.39
                                           2469.36
                                           2465.71
                                           2476.88
                                           2467.39

                                           2496.89
                                           2469.36
                                           2467.71
                                           2476.88
                                           2467.39

                                           2496.89
                                           2469.36
                                           2463.71
                                           2476.88
                                           2459.39
8/28/85
8/23/85
8/26/85
8/27/85
8/22/85
301
304
305
306
307
287
311
310
300
313
2496.89
2468.36
2465.71
2476.88
2466.39

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                                         -25-


                                  TABLE 2

                INTERIM STATUS RCRA GROUND WATER ELEVATIONS
DATE

10/03/85
10/07/85
10/04/85
10/17/85

03/25/86
03/27/86
03/26/86
03/27/86

06/30/86
06/27/86
06/26/86
06/27/86
09/03/86
09/25/86
03/26/87
WELL    DEPTH TO WATER (FEET)    WATER LEVEL ELEVATION  (FEET)
301
305
306
307

301
305
306
307

301
305
306
307
287
312
300
325

287
310
300
312

237
318
300
312
2496.89
2463.71
2476.88
2454.39

2496.89
2465.71
2476.88
2467.39

2496.39
2457.71
2476.88
2467.39
          (DEDICATED SAMPLING- EQUIPMENT  INSIAL1ED IN AUGUST 1986)
301
305
306
307

301
305
306
307'

301
305
306
307
      289.88
      315.5-
      306.42
      315.46

      290
      321
      314
      315 .

      289.9
      313
      313.95
      315.2
        2495.80
        2462.06
        2473.42
        2465.64

        2495.68
        2457.56
        2465.84
        2466.1

        2495.78
        2460.56
        2465.89
        2465.9
NOTE:  Before August 1986, the depths to water wer-a measured  from the top
       of pipe elevations:
                          301
                          304
                          305
                          306
                          307
                     2783.89
                     2779.36
                     2775.71
                     2776.88
                     2779.39
       After August  1986,  the dedicated  saxpling systexs were installed and
       measurements were taken from the  elevation of  the top  of  the water
       level tube.
                          301
                          305
                          306
                          307
                     2785.68
                     2778.56
                     2779.84
                     2781.10

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                                -26-
SUMMARY OF INTERIM STATUS RCRA GPDUND WATER ELEVATION  DATA
WELL
301
305
306
307
HIGffiST RECORDED
WATER LEVEL
ELEVATION/DATE
2497.89, 3/85
2471.71, 1/85
2476.88, 5/85-6/86'
2469.39, 4/85
LOWEST RECORDED
WATER LEVEL
ELEVATION/DATE
2495.68, 9/25
2457.56, 9/25
2464.88, 1-3/85
2454.39, 3/86
MEAN WATER
LEVEL
ELEVATION (FT)'
2496.72
2465.21
. 2472.44
2465.4
The use of water level data taken from the site well when
attempting co calculate the Local hydraulic gradient tends
to skew the results due to the fact  that  the site well  is
screened in multiple water-bearing zones with the resulting
water levels treasured in the well representing an average
water level of the four screened intervals.  The regional
hydraulic gradient determined by the facility to be approxi-
mately 30 feet/ mile is suspect due  co a  lack of information
concerning the two off-site wells. Information such as  ceptn
to water, length of screened interval, length of filter
pacx, well construction uietnccs, Iicnolcgic  legs of'ir.a
boreholes and whether the wells fully penetrate the aquifer
is needed.

Data on permeabilities of the saturated zones underlying
the facility are.extremely limited and of questionable
value.  Clebsch in his report describes the'hydraulic con-
ductivity of an intact section of core obtained from the
276-280 interval.  A value of 3.4xlO~4 centimeters/second
was obtained which is more indicative c':  a fine sand than
of a clay which is descrit*J for this i .terval.  The only
data on transmisaivities cf the upper— .ost aquifer were
obtained from two aquifer (pump) tests.  The first consisted
of a series of injection tests performed during July,  1961
while the second was a standard pump test performed in
March, 1982.  These tests yialded transmissivities of  650-
7000 gallons/day/foot and 16,000-18,000 gallons/day/foot
respectively.  Problems with the validity of the hydraulic
conductivity and transmissivity data are discussed in  the
Hydrogeologic Site Characterization  section. A ground water
velocity, using these transmissivities and the facility's
calculated ground water gradient was determined to be  2 to  4
feet/day.

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                                -27-
3.  Hydrogeologic Site Characterization

    The following inconsistencies and deficiencies relating
    to the facility's hydrogeologic site characterization
    have been identified:

     a.  Definition of the upper-most aquifer:  The facility
         has identified the top of the saturated zone as
         lying between 275 and 300 feet deep based on strati-
         graphic information obtained through lithologic
         logs and downhole geophysical measurements.  How-
         ever, questions remain concerning interpretation
         of the geophysical logs and in the drilling method
         employed.  The gamma and electric logs, run for
         wells 304, 305 and 306, indicate significant
         changes at approximately the 275 foot depth in each
         well.  The gamma logs show a decrease In activity
         below this depth.  The electric Legs show a similar
         decrease in resistivity values.  Natural gamma logs
         are generally sensitive to clay content due to the
         presence of radioactive potassium in clays.  There-
         .fore, it is possible that the decrease in natural
         gamma values is due to a decrease in' clay mineral
         content.  If this decrease were 'lue to a decrease
         in clay mineral content, then this would contradict
         the lithologic log...descriptions in which an
         increase' in clay .Tiineral ccncenc is .-.ccec.  The
         decrease in electrical resistance celcw approxi-
         mately the 275 foot depth may be due co an'
         increase in clay mineral content and/or an increase
         in moisture concent.  The facility did not deter-
         mine the depth or depths at which ground water was
         initially detected.  This was most likely the
         result of the use of a mud rotary drilling method
         which makes the detection of ground water difficult
         since another fluid is introduced into the bore-
         hole.  In addition, the facility did not identify
         the chemical composition of the drilling fluids
         used.  These factors have all contributed to a
         lade of definition of the upper boundary of the
         saturated zone, i.e. the limits of the upper most
         aquifer have not been adequately identified.

     b.  Cuality of Geologic Descriptions;  Most samples of
         the subsurface materials' obtained at the site have
         been from cuttings obtained during mud rotary
         drilling rather than from intact core samples.
         Samples of this type can only indicate in general
         the grainsize distribution of the materials and do
         not reveal small scale structure such as bedding or
         degree of cementation, jointing or faulting.  The
         lithologic descriptions of the logs of borings 304,
         305, and 306 were mostly size-descriptive with
         little petrographic information included.  Moisture
         contents are described in non-numeric terms only.

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                           -28-
b.  Quality of Geologic Descriptions (Cont.)

    Other tests such as Atterberg, standard penetration
    and dry density were not run on these samples.
    Lithologic logs of borings 301, 302 and 303 did
    include penetration test results but the lithologic
    descriptions were only general in content and.fran
    widely spaced intervals within the column.  The
   .most detailed description of the geology is found
    in the log for the site well.  However, no other
    tests were run on the materials obtained from this
    boring.

    There has been a lack of documentation of data
    collection and interpretation procedures such as
    how the lithologic legs from the borings were cons-
    tructed or how the geologic materials were classi-
    fied.  The problems described above are the result,
    at least in part, of che fact that a numoer of
    consultants have been employed using varied field
    and Laboratory procedures to analyze the geologic
    data.  This introduces a certain degree of sub-
    jectivity into the site characterization procsss.  .

c.  Correlation of Water-Bearing Zones:  The coring log
    of the site well identified four potential water-
    tearing zones ranging from approximate!'/ 223  zo 57"
    feet deep.  The logs of wells 305, 306, 307
    identify a potential water-bearing zone or zones
    between the depths of approximately 310 to 380
    feet.  The vertical interval of potential water-
    bearing strata conacn to all site monitoring  wells
    is limited to approximately 60 feet.  An accurate
    pptenticmetrie surface cannot be defined since only
    the site well penetrates the deeper water-bearing
    zones.  There are no means presently available,
    using the facility's data/ to correlate the shallow
    with the deeper water-bearing zones.  This can be
    accomplished through the drilling of additional
    piezometers and/or monitoring wells that  intersect
    the deeper water bearing zones identified  in  the
    log of the site water well.

d.  Hydraulic Gradient:  U.S. Ecology has determined
    that the uppermost aquifer exists under confined
    conditions at their facility.  This determination
    is based on measured ground water levels  in
    their RCRA monitoring wells and stratigraphic data
    obtained from previous geotechnical investigations.
    U.S. Ecology has not determined whether a  vertical
    gradient within the uppermost aquifer exists  or
    not.  This can be accomplished by the  installation
    of piezometers screened at varying  intervals
    throughout the thickness of  the aquifer.

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                                     -29-

F.  Leachate Migration Potential in the Unsaturated Zone

    Based on results of the facility's geotechnical investiga-
    tions and from data obtained through the installation of the
    RCRA ground water monitoring wells, the thickness of the
    unsaturated zone has been established by the facility at
    approximately 300 feet.  Based on the large depth to ground
    water combined'with the arid climate of southern Nevada and
    the physical properties of the unsaturated zone led U.S.
    Ecology to apply, in 1983, for a waiver from part or all of
    the RCRA ground water monitoring requirements under 40 CFR
    Part 265.90(c) of Subpart F.  .Such a demonstration must
    establish the potential for migration of hazardous waste
    constituents from the waste management units to the uppermost
    aquifer as well as the direction and rate of migration of
    hazardous waste constituents once they reach the uppermost
    aquifer. This waiver request was in effect denied when the
    MDEP issued an Administrative Order on May  14, 1984 which
    required che installation of a. jround water monitoring system
    which was completed in July of 1984.

    U.S. Ecology also applied for a Liner Waiver when their
    Part B was submitted in 1983 for a future trench  (11).  Under
    provisions of 3004(o)(2) codified in 40 C.F.R. 264.301(b),
    such'a waiver would allow an owner/operator to be exempted
    frciiV installation of a landfill liner if it can be demons-
    trated that "alternate design and operating practices,
    ccgecher wich Locacicn characteristics, will prevent  ;he
   'migration of any hazardous constituents into the ground water
   'or surface water at least as effectively as the liner system
    required by 3004(a)(l)(A)".  EPA has not yet made a final
    determination whether or not to grant the liner waiver
    request.  That decision will be made as part of the permit-
    ting process.

    When examining the potential for migration of liquids or
    moisture  -hrough the unsaturated or vadose  zone, a large
   . number oi factors must be considered including saturated
    versus unsaturated hydraulic conductivity,  porosity, grain
    size and degree of sorting, capillarity, surface tension,
    fluid viscosity, soil moisture/pore pressure or matric potential,
    climatic factors including rainfall length  and  intensity,
    evaporation rates, the type and volume of wastes being disposed
    of and the various attenuation mechanisms available.   In
    addition, macropore flow must be considered, which involves
    the rapid transmission of free liquid through large continuous
    pores or channels and can occur in materials with moisture
    contents less than field capacity  (Everett, 1987).

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                                     -30-
F.  Leachate Migration Potential in the Unsaturated Zone  (Cont.)

    A number of calculations have been performed by both EPA and
    U.S. Ecology using various combinations of these factors
    which yielded a large range of travel times and seepage
    velocities for fluid migration in the unsaturated zone.  EPA
    has.made a determination of a theoretical seepage velocity
    (4)  which is based on very conservative assumptions
    including:

    *  The regulated units are completely full of liquids.

    *  The fluid velocity of the least viscous fluid is used.

    *  The maximum hydraulic conductivity for the vadose zone is
       used which would be its saturated hydraulic conductivity.-
       This assumption in effect negates the presence of the
       unsaturated zone.

    These assumptions are intended for use when considering
    waiver requests from ground water monitoring under Part 264
    Subpart F requirements.  These assumptions can be applied to
    the evaluation of liner waiver requests as well since  the
    ability of fluids to migrate from regulated units through the
    unsaturated zone to the ground water Ls of concern in  both
    cases.

    A seepage velocity of 19.2 feet/day was obtained which would
    require 13 days for fluids leaving the trench to reach the
    ground water.   This figure should be considered as a  worst
    case and used as a reference point 'when considering other
    theories of fluid migration.  EKTEC also cased cheir calcula-
    tions on the premise that field capacity does not represent a
    threshold for unsaturated flow.  There is currently disagree-
    ment over whether there is a threshold point at which  flow
    commences, and if so, what the threshold point is.

    U.S. Ecology had calculations performed by Law Engineering
    Testing Ccnpany, Inc. and contained in a report dated
    August 13, 1981, which resulted in a travel time of approxi-
    mately 9000 years required for leachate to migrate from the
    trench through the vadose zone to the ground water.  Gravity
    versus capillary forces are discussed with the conclusion
    drawn that saturated zone flow is controlled by gravity
    forces while capillary forces control unsaturated zone flow.
    A major assumption used for 'these calculations was that
    gravity drainage will not occur until the moisture content
    of the soil exceeds its field capacity.
(4)  Program Management Assistance for Review of a Request  for
     a Waiver from Ground Water Pursuant to  40 C.F.R.  Part  264
     Subpart F:  U.S. Ecology, Inc., Beatty, Nevada, Second
     Review, Prepared by EPTEC, Inc.  for  EPA, August  25,  1983.

-------
                                     -31-
F.  Leachate Migration Potential in the Unsaturated Zone

    A report by EMCCN, Assoc. prepared for U.S.  Ecology and
    dated October 2,  1973 calculated a total penetration depth
    of 195 feet as the depth to which liquids could migrate .
    assuming the simultaneous rupture of all buried drums.  This
    calculation is also based on the assumption that the specific
    capacity of the soil must be overcome before fluid movement
    within the unsaturated zone will occur.

    The most recent study which has looked at  fluid migration
    potential in the vadose zone is a preliminary report by
    Nichols, U.S.G.S., 1986. ' This study is being conducted in  •
    an area lying immediately adjacent to and outside of U.S.
    Ecology's facility perimeter.  The Nichols study focuses
    on the potential  for the movement of radionuclides from the
    waste burial trenches to the subsurface concentrating on the
    upper 10 raters of the unsaturated zone.  An -axransive review
    of. climatological data covering a period of  27 years  from
    1949 to 1976 was made by Nichols.  A water balance model was
    created which was used to identify conditions necessary to
    induce deep percolation  (2 meters or greater).  Four such
    instances were identified over the 27 year time span  in which
    deep percolation could have occurred.  However, it mus" be
    remembered that only natural factors were, considered  i..
    preparing the-water balance model.  Factors such as lie;:ids
    contained in che  trenches and the assumptions used By £PA
    were not included in Nichols.1 calculations.

    Soil moisture potentials* were monitored yielding values
    from -10 to -30.bars**.  These values represent high negative
    soil moisture potentials which must be considered when desig-
    ning an effective vadose monitoring system (see Secatmenda-
    tions Section).   Saturated and unsaturated hydraulic conduc-
    tivities, both measured and calculated, are discussed.
    Saturated hydraulic conductivities ranged  from 10~4 on/s to
    10~"7 an/a while unsaturated hydraulic conductivities ranged
    from 10~7 cm/3 to 10~17 cm/s to a depth of 10 meters.  These
    values compare with estimates of hydraulic conductivity
    between 10"^^ on/s to 10"^ cm/s as given  in the Liner Waiver
    Request dated April 25,  1984 prepared by James L. Grant and
    Assoc.  A letter  from Grant to U.S. Ecology dated
    October 25, 1983 provides values of unsaturated.hydraulic
    conductivities ranging from 10~9 on/s to  lO"1^ Qn/s 3^ a
    saturated hydraulic conductivity of 10~3 on/s.
*   Soil moisture potential  is  the  ability of a material (soil)
    to retain moisture against  forces such as gravity.

**  A bar is equivalent  to  1 atmosphere of pressure or 14.7 psi.

-------
                                     -32-
F.  .Leachate Migration Potential in the Unsaturated  Zone  (Cent.)

    In addition, Nichols makes reference to a study done by
    Mehuys (1975) which considered stoney soils  in arid environ-
    ments in the vicinity of Rock Valley in southern Nevada.  The
    geologies .and geomorphologies of the two study areas are
    similar in that the surficial deposits at both sites consist
    of alluvial materials derived from nearby mountain ranges.
    Unsaturated hydraulic conductivities in this report ranged
    from 10-8 an
-------
                                     -33-


G.  Well Evaluation

     1.  RCPA designated Ground Water Monitoring Wells

         The ground water monitoring system at U.S. Ecology's
         Beatty, Nevada facility, as it currently exists under
         the Interim Status provisions of RCPA 40 CFR Part  265
         Subpart F consists of four monitoring wells; 301,  305,
         306 and 307.  Monitoring -veil 301 was installed in
         December, 1980.  The remaining wells, 304, 305, and
         306 were installed in July, 1984 as a result of EPA's
         denial of U.S. Ecology's Ground Water Monitoring Wavier-
         Request.  Well 307 is located approximately eight  feet  '
         from well 304.  It was drilled in February, 1985 as a
         replacement for well 304 when a submersible pump became
         wedged in the casing and could not be removed.  The
         locations of these wells are given on Figure 8.

          a.  Well Placement/Number

              The number of JOA-designated monitoring wells
              (four) meet the minimum requirements of 40 CFR  Part
              265 Subpart F of one upgradient  (well 301) and
              three dcwngradient .(wells 305, 306 and 307) as
              designated by the facility.  Bowever, fcur ground .
              water monitoring wells are not a sufficient number
              co monitor a 10 acre landfill.  The adequacy  of
              placement of these wells, especially the upgradient
              well, depends on the results obtained from the
              additional hydrogeologic characterization to  be
              performed.  A better definition of the ground water
              flow direction will determine whether well 301  is
              serving as an upgradient or background well or not.
              At least one additional upgradient well along with
              additional down gradient wells are recaimended  to
              provide better coverage for the dcwngradient  por-
              tions of trench 10 and for the southern and eastern
              perimeters of the facility.

          b.  Well Construction

              All four of the RCBA-designated ground water
              monitoring wells were drilled using a mud rotary
              drilling method.  The wells were completed to
              depths ranging from 342.1 to 390.7 feet.  Wells
              301, 305, and 306 were cased using schedule 40,
              4-inch flush-threaded PW pipe and well screen.
              Well 307 was constructed using schedule 80,
              6-inch flush-threaded PVC pipe and well screen.

-------
                           -34-


b.  Well Obstruction (Cont.)

    Table 3 gives details of well construction.  Figure
    9 is a schematic drawing of the construction of a
    typical monitoring well while figures 10 through 13
    present diagrams for RCPA wells 301, 305, 306 and
    307.  The use of a mud rotary drilling method has
    the major disadvantage of not allowing an easy
    identification of the upper-most zone of saturation
    with the introduction of an additional fluid to the
    well.  In this situation, the use of an air rotary
    drilling method would be better suited for use when
    attempting to identify the depth to first ground
    water.  However, since drilling at this location
    involves the penetration of large thicknesses of
    unconsolidated material, caving and straightness
    of hole are primary concerns.  Air rotary drilling
    has been employed sucessfuily to the depths at which
    these wells have been drilled.  Screen specifica-
    tions for the monitoring wells are inadequate based
    on the following physical evidence.

    It is noted that the monitoring -veils have accumu-
    lated .sediments in the screened portion of the.
    wells ranging from 12.7 to 16.5 feet.  Turbidity
    measurements made by U.S. Ecology during their
    Interim ^tacus ground *acer .ronitcring, in 1235
    and 1986, have resulted in values of turbidity as
    high as 970 NTU (Nephelametric Turbidity Units).

    The wells were screened using PVC factory slotted
    screens witn slot sizes of either 0.010 or 0.020
    inches.  Seive analyses have not been performed for
    the formation materials which have been screened
  .  resulting in the inconpatability between formation
    grain size, filter pack particle size and screen
    slot size.  The sedimentation and turbidity pro-
    blems of these wells are symptomatic of the lacK"
    of wall intake design.  In Volume IV (Engineering
    and Construction Manual) of the Part 3 application
    under facility design it is stated that the purpose
    of the gravel pack was for stabilization and not
    for filtering or for the purpose of ground water
    sampling.

-------
                           -35-
b.  Well Construction (Cont.)

    Hie wells were gravel packed using well sorted
    siliceous pea gravel sized .2.50 to .375 inches
    in diameter.  The gravel packs however, are
    exceedingly long, ranging from 103 to 235 feet
    (Table 3 ).  This additional.length increases the
    total effective length of the well open to the
    formation which does not allow an accurate deter-
    mination of the source or sources of ground water
    entering the well.  Water quality data obtained
    from wells of this type can only represent an
    average of the entire saturated length of the
    formation open to the well.

    Bentonite seals were placed  in the wells above the
    top of the gravel pack in thicknesses of at least
    one foot.  Cata on the thicknesses of bentonite as
    installed are not available nor is the exact con-
    position of the bentonite.  The wells were then
    grouted from the top of the bentonite seals to the
    surface using a cement-bentonite. mixture of 6:1.

c.  Screen Placement/Length

    The vertical placement of the well screens are
    inadequate in that the top of the '-loper Test
    aquifer has not been identified through the site
    characterization process.  Verification of the
    position of the top of the uppermost aquifer
    through drilling of additional piezometers using
    a dry drilling method must be made.  The length
    of screen used in these wells ranged from 50 feet
    for weU 301 to 70 feet for wells 305, 306 and 307.
    The length of screen should be minimized to prevent
    dilution of contaminants if detected.  However, the
    entire aquifer thickness should be monitored to insure
    that potential contaminats of varying densities, fol-
    lowing different flow paths can be detected.  The way
    this can be accomplished is  through the use of well
    clusters.  The exact length of screen to be used and
    whether well clusters would be appropriate depends on
    conditions encountered at each drilling location.

d.  Well Development

    Development of the well 307 was accomplished by
    means of bailing while wells 301, 305 and 306 were
    developed by surging and back-washing with com-
    pressed air until the wells produced clear water.
    These methods are deemed adequate in allowing
    for sufficient well development.  However, due to
    inadequacies in well construction methods pre-
    viously detailed, siltation  and turbidity continue
    to cause problems which no amount of well develop-
    ment will remedy.

-------
                                   I\J
                                   301
LOW LEVEL RADIOACTIVE
   WASTE TROJCIIES
                                              SITE
                                              WATER
                                              wtnx
                                                             SOIL
                                                            UORROW
                                                             1>1LE
              -403-
                                                                           ACTIVE TRENCH 10
                                                                                                 306
                                                                           304/307
305
                                                                           a/OSED TRENCHES
                                                                                  1-9
                                                                                    303
                                                                  RISK SCIENCES iwiiiRNATiONAL  1985
          FIGURE  fl. M CATIONS OF Ri!l(A C.RfUJNI) WATER MWI'IURING WE1J.S
                      AND OTHER ClRUINh WATER WEl.lii

-------
                            37
                               lockabte Cover
     Protective Casing
'nreaded Coupling CTyp.)
         Borenole Wail
      1' Bentonite Seal
          Bottom Cap
Ground
Surface
                          Figure :   9

                    MONITORING  WELL
                CONSTRUCTION  SCHEMATIC
                     Ht'
                                  lo

-------
               EST.  G.S.
               ELEV.  2780'
c _
10 ^
O-J
Ikl
Ul
          FEET
                                   ~7\—8"O.D. CSG ,  STEEL
                                   /
                                   V— 8 3/4" BOREHOLE
                                   X
                                         4" !.D. CSG, ?VC
                                         GROU
                                         IMFiHM£A3L£ LAY£?.
                                         GRAVEL FILTER
                                    ^T—4" LD. WELL SCREEN, PVC
                                         XAP
                                         CAVED MATERIAL
          LAW  ENGINEERING
           TESTING  COMPANY

             DENVER, COLORADO
                                            FIGURE:  10
                                           COMPLETION DIAGRAM

                                           MONITORING WELL 30!

-------
                               39
     MOUNO SURFACE
             TTtEL CASINO
               4'-OIA.
           SCHEDULE 40 PVC
            (FLUSH »ALL)
            tort
            0 MACHINE
                PVC
                            '.'1
                                                !1N6E9 TOP
                                           7-7/8* OUMETER
                MS Ft

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                                                •EMTOMITI PLUS
                                                  AT 230 FT.
                                               (APPRO*. 1 FT THICK)
                                           WATIK LEVEL
                                                 AT 215 FT.
                                             ON 7-«-«4
        IGEOTECHN1CAL
        1 SERVICES,  INC.
CEOTECMNICAL CONSULTANTS • MATE At A US TEST ING
0!
  FIOJPE U: CCMFLEITCN DLAGRAM FT>T
WELL  NO.   305

-------
4U
•AOUMU fiOflTACE -^
STEEL CASINO
4"- 0IA
SCHEDULE 40 PVC
(FLUSH WALL)





70 FT SKTIOK-^
.MO MACHINE SLOTTED.
PVC
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(TSC^nCSECTECHNICAL ,
IS©U SERVICES, IMC. 1
CtOTECMNlCAL CONSULTANTS • MATERIALS TESTING
K^HI
FIGURE 12: CCMPLE^IOM DIAGRAM FOR
i/VELL NO. 306 |

-------
                            41
Ground Surface
         ISO1
          235'
                               8" Protective Steel Casing
                                Cement-Bentonite  Grout
                                313', 6" Sen. 80 PVC
                                Flush Threaded Casing
                                 Pea Gravel
                                 70' Screen
                                 6" Sch 80 PVC
                                 0.020- Slot
                                  Threaded Bottom Plug
              COMPLETION DIAGRAM FOR WELL 307

-------
                                                                            42
TABI£ 3:   RCI
3
• ^
LCNGIII
SUCK-UP
IOP ELEVAflON*
BOIIOH CLCVAIION
IOP ELCVAIION OF
WATER LEVEL TUBE
DCPIH IOP/BOHOH
HAICRIAL
OIAHCIIM
LENGIII
SLOI SUE
IOT ELEVAflON
BOIIOH ELEVAMON
Of Pill IOP/BOHOH
UIAHLUR
LfN(.IM ' > •
IOP flfVAIIOII .
UOMOU (KVAIKMI
101
2/81.8'
342. »'
SCII. 40 PVC
4"
292.1'
3.5*
2785.33'
2493.2'
•
2785.68*
292.1/342.1
PVC
4-
50*
0.020"
2493.2'
2443.2'
239.1/342.1'
8.75-
10)'
2546.2'
244J.2'
305
2774.8'
388.8*
SCII. 40 PVC
4"
318.8'
3.2*
2777.99'
2459.2'
2778.56'
318.8/380.8
PVC
4'
70'
0.010*
2459.2'
2389.2'
253.8/188.8'
7.08"
IJ5'
2524.2
2389.2
106
2776.0*
390. 7'
SCII. 40 PVC
4" '
120.7'
1.5'
2779.45'
2458.8'
2779.84'
120.7/190.7
PVC
4"
JO'
0.010*
2458.8'
2188.8'
253.7/390.7*
;.80"
117-
2025.8
?iu».a
30 ;
2776.5*
18,2.7'
SCII. 80 PVC
6"
312.7'
4,4'
2780.92*
2468.2'
2781.10*
112.7/182.7
PVC
6"
70'
0.020"
2468.2'
2198.2'
47. //182. 7*
10"
2 lb*
2711.2
2 1'JII . 2



















1


,_/1
j^f   I.   Hetsureil from tup of protective  steel casing.  Hoi*;:  Slllatl'oii has reduced  ilejitlts.  See  Attachment ) 6.

z   2.   Surveyed »t lop of well hc«d.  less  than 0.1M let-1 ahuve jirolti.t Ivc casln
-------
                                               43
                          TABLE   4   «  NON-liCRA VAD06E  ZONE MONITORING WELL SPECIFICATIONS
WELL
NUMBER
7
8
10
12
13
DEPTH OF
BORING (FT) I
51.33
45.17
49.75
40
65
SURFACE
ELEVATION (FT)
2772.3*
2770*
2772*
2775.19
2739.88
Ix/ITOM OF
WRING
Eli£VATION (FT)
2720.97*
2724.83*
2722.25*
2735.19
2674.88
SCREENED
mi'ERVAL
DEFIES (FT)
UNKNOWN
UNKNOWN
UNKNOWN
2745.19-
2735.19
- 2684.88-
2674.88
CASING
I.D.
(INCHES)
2
2
UNKNOWN
UNKNOWN
UNKNOWN
DATE
DRILLED
PRIOR TO
8/73
PRIOR TO
7/30/75
PRIOR TO
7/30/75
3/79
1/81
*  ESTIMATED VALUE

-------
                                               44
                          TABLE 4A  i  NON-ICRA VADDSE ZONE MONITORING WELL SPECIFICATIONS
WELL
NUMBER
14(4)t
15(3)t
16(2)t
nd)t
18(P-l)t
19(P-3)t
20
DEPTH OF
BORING (Pf)
50
50
50
50
50
50
50
SURFACE
ELEVATION (FT)
2769*
2773*
2773*
2772*
2771*
2773*
UNKNOWN
b/TTTM OF
BORING
EF.EVATION (FT)
2719*
• 2723*
2723*
2722*
2721*
2723*
UNKNfVJN
SCREENED
INTERVAL
DEFIES (FT)
2766-2719*
2770-2723*
2770-2723*
2769-2722*
2768-2721*
2770-2723*
UNKNOWN
CASING
I.D.
(INCHES)
4
4
4
4
4
4
2
DATE
DRILLED
8/73
8/73
8/73
8/73
8/73
8/73
8/73
*  ESTIMATED VALUE
t  BORINGS IDENTIFIED UNDER TWO NUMBERING SYSTKMS

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                               -45-


     2.   Non-fOA Wells

          a.   Phosphoric Acid Liquor Investigation Borings

              A series of boreholes and ground water monitoring
              wells have been installed at U.S. Ecology's dis-
              posal facility as part of a number of geotechnical.
              investigations conducted by U.S. Ecology's consul-
              tants.  A report was produced by EMCCN (5) in 1973.

              The 1973 investigation was conducted to determine
              the extent of migration of phosphorous acid liquors
              in the subsurface which were disposed of between
              1973 and 1978 in the southeastern corner of U.S.
              Ecology's property (Figure 14 ).  A total of 20
              borings were drilled for this investigation.
              Borings numbered 1 through 6 and 9 were drilled as
              test borings for the purpose of  identification of
              subsurface materials, while borings 7, 3 and 10
              through 20 were drilled as test borings and then
              completed as observation wells.  Locations of these
              borings are shown in Figure 14.  All of the above
              referenced borings 'were drilled  in August, 1973
              except for bori-ngs 7, 8, 10, 11 and 13.  See Tables
              4 and 4A for details of construction specifications
              and installation dates.

              Phosphoric acid liquor contamination was discovered
              in boreholes 1 and 2 by U.S..Ecology in 1973 with
              contamination detected in borehole 13  in the late
              70s (exact date unknown although probably during
              1978).  This resulted in the cessation of the
              disposal of phosphoric acid liquors at the facility.
              The exact interval at which the contamination was
              detected in the .three boreholes has not been deter-
              mined at this time.  No contamination has been
              detected in any of the other boreholes as reported
              by the facility.

              An air rotary drill rig with a  4 and 7/8 inch Tri-
              cone bit was used to drill the  holes.  Borings
              7,8,10,11,13 and 20 were all completed with 2 inch
              diameter PTC pipe which was vertically perforrated.
              The annular spaces were gravel  packed and grouted.
              Borings 14,15,16 and 17 were completed with 4 inch
              diameter plastic pipe which was  vertically slotted.
              Details of the specifications of gravel pack,
              grout, whether or not seive analyses were run on
              formation material or the slot  spacings used were
              not available.
5  Geologic Investigation To Determine Extent of  Phosphoric
   Liquor Migration and Installation of Monitoring Wells,  Beatty,
   Nevada, August, 1973.

-------
                                -46-
     b.  Onsaturated Zone Characterization- Monitoring
         Wells/Boreholes

         A second series of seven ground water monitoring
         wells numbered 101 through 107 were installed
         during December, 1980 and January, 1981.  Figure 15
         gives their locations.  These wells were installed
         as part of a geotechnical investigation, the pur-
         pose of which was to evaluate the adequacy of
         .natural containment mechanisms of the shallow
         subsurface at the Beatty, Nevada facility including
         the low-level radioactive disposal area.
                                   •
         The borings were drilled to depths between 95 and
         109 feet using a hollow stem auger (except boring
         107 which was only drilled to a 74.5 foot total
         depth.  The borings were completed to their final
         depths using an 3 inch gear bit with drilling mid.
         The total depths of the wells range from 74.5 to
         160 feet, all completed as shallow ground water
         monitoring wells.  The wells were cased using 4
         inch diameter PVC pipe, the bottom 10 feet of each
         consisting of well screen.  Ground water was not
         encountered in any of these weiis .according to
         facility records.  Gravel pack was placed the
         entire length of annular spacs sxcect for the ^cper
         10 to 21 feec in wnich a cemenc grout: was placed.
         Bentonite seals were not used.  The wells were
         cleaned through bailing which involved the removal
         of cuttings and drilling fluid from the borings.
         Screen slot spacing/ size and its compatibility
         with the formation's grain size distribution was
         not taken into consideration when constructing
         these .wells.  Information concerning screen slot
         spacing was not available from the facility.  See
         Table 5 for details of construction specifications
         and installation details.

3.  Other Ground Water Wells

    Several other ground water wells have been installed
    at the Beatty facility during its operational history.
    The site well serves as the water supply well for the
    facilty.  The well was drilled during May and June,  1961,
    using a water rotary rig to a depth of 573 feet.  The
    well was cased and screened with galvanized pipe with
    screen placed at two intervals using factory slotted
    screen.  A third and fourth screened interval were added
    to this well at shallower depths in February, 1981 using
    hand-cut screen slots.  Information was not available
    concerning details of construction of this well.

-------
                          -47-


3.  Other Ground Water Wells (Cont.)

    Well number 302 is located along the southern perimeter
    of the facility adjacent to the low level radioactive
    disposal area (Figure 8).  This well was drilled in
    February, 1981 to a depth of 355 feet.  No ground water
    has been encountered in this well during previous
    sampling events with only damp bottom-of-hole sediments
    noted.  Well number 303 is also located along the
    southern perimeter of the facility immediately adjacent
    to the phosphoric acid disposal area  (Figure 4).  This
    well was drilled in January, 1981 to a depth of  350
    feet, cased with 4 inch diameter PVC pipe and screened
    at two intervals between 290 and 310  feet where ground
    water had been detected by the facility.  A gravel pack
    was placed in the annular space from  235 feet to the
    bottom of the well.  A grout seal extends from the sur-
    face to the top of the 
-------
                                           48
NUCLEAR  WASTE
      DISPOSAL  AREA
                                         l*n*« Una
                                  • ^ __t_ H  _ _ . •  	  • f
                                                                          CHEMICAL  WASTE
                                                                                  DISPOSAL  AREA
                                                                        -i—,—,	,.
                                                                                                I
                                                                                   o«
                                                                                         Os
   I
V
 SYMBOL;
0 dialing Ok»«f •«H»« W»ll
0 Cipl<»«l*'r •«!•• By
O C.plo»«l«lf Boil*0 By
 SCAI C t I Inch* ZOO l«tl
                                                                              N
                                                                                              sw  of
                        *• Ok»w.«IU« Well
                                                                Source: Nuclear Engineering Co.. Inc. 1973
                   i 14:  NCN-W:i
-------
                                   SITE BOUNDARY
                           107
~\
          106
     SITE OFFICES
     AND SHOP
                               •105
                TRENCH 22
            \   TRENCH 21    /
         ry'
RADIOACTIVE
  WASTE   -
   SITE
                                                             103
      BUFFER
        ZONE
                                  101
                                                                  EXISTING TRENCh
                             ^
                  TRENCH 10
               •EXPANSION LIMITS
        a

CHEMICAL
  WASTE
   SITE
                                                                                  02
FIGURE 15:  NON-RCRA SIIAIJJOW GROUND WA'IIIK MfWHUONC WI3.I.
                                                                  0
                                      400
                                      FEET
                                      800
LEGEND

MONITORING  WELL LOCATION
     LAW  ENGINEERING
       TESTING COMPANY
        DENVER,COLORADO
                          U  S.  ECOLOGY , INC.
                     BEATTY, NV  DISPOSAL  FACILITY

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                                                       50
                         TABLE 5:  NON-RCRA VADOSE ZONE MONITORING WKU, SPHCIF.TCATIOIJ2
WELL
NUMBER
101
102
103
104
105
106
107
DEPTH OF
BORING
(FT)
140
95
99
156
99
160
74.5
ELEVATION
TOP OF
CASING
(FT)
2760.41
2779.51
2780.48
2775.57
UNKNOWN
UNKNOWN
UNKNOWN
SURFACE
ELEVATION
(FT)
2779.67
2777.87
2779.81
2769.99
2782*
2785*
2783*
BOTTOM OF
BORING
ELEVATION
(FT)
2639.67
2682.67
2660.61
2613.99
2683*
2625*
2708.5*
SCREENED
INTERVAL,
DEPTH
(FT)
2649.67-
2639.67
2692.87-
2682.87
2690.81-
2680.81
2623.99-
26 131. 99
2693-*
2663
2646-*
2636
2721-*
2711
CASING
I.D.
(INCHES)
4
4
4
4
4
4
4
DATE
DRILLED
1/81
1/81
1/81
1/81
12/9/80
12/19/80
12/5/80
FILTER
PACK
INTERVAL
(FT)
2760.67-
2639.67
2761.87-
2682.87
2769.81-
2680.81
2753.99-
2613.99
2763-*
2683
2764-*
2636
2772-*
2711
ESTIMATED VALUE




INFORMATION TAKEN FROM FACILITY  PART B API'LICATION

-------
                                TABLE  6   »   NON-RCRA GROUND WATER MONITORING WELL SPECIFICATIONS
WELL
NUMBER


302


303


304

SITE
WELL


DEPTH OP
BORING
(FT)

355


350


390


573


ELEVATION
TOP OF
CASING
(FT)
2779.40


2771.23


2779.36


2780


SURFACE
ELEVATION
(FT)

2777.6


2769.9


2777.1


2780


BQflTOM OF
BORING
ELfcVATION
(FT)
2422.6


2419.9


2387.1


2205


SCRittNtID
INTERVAL
DEPTH
(FT)
2472.6-
242-2.6
2479.9-
2459.9
2449.9-
2419.9
2472.1-
2402 . 1
2454-2440
2423-2332
2327-2287
2267-2207
CASING
i.n.
(INCHES)

UNKNfJWN


4


4


8


DATE
DRILLED


2/1/81


1/81


6/28/84


7/17/61


FILTER
PACK
INTERVAL
(FT)
UNKNOWN


2419.9


2527.1-
2402.1

UNKNOWN


*  ESTIMATED VALUE




   INFORMATION TAKEN FROM FACILITY  PART B APl'l.fCATIdN

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                          -52-


4.   Recuimendations

     1.   Site Characterization:

         A.   A more precise determination of the upper limit
             of the uppermost water-bearing unit must be
             made through the use of air rotary or other
             appropriate drilling method.•  Such method
             must permit detection of changes in moisture
             content of materials as well as detection of the
             uppermost saturated zone.

         B.   Provide petrographic and structural descrip-
             tions of the unsaturated zone, with particular
             attention given to the initial clay units
             encountered,'along with the three or more
             saturated zones which have been identified in
             the site water supply "veil.  The logging of the'
             samples shall be by a qualified professional
             geologist.  Samples shall be collected by
             Shelby Tube, Split Spoon or equivalent sampling
             device.

         C.   Physical testing of the cored samples for the
             parameters of moisture content, density,
             Atterberg Limits  (Conesiveness~j, sorting, and
             permeability 'in-situ casting for the -:iay
             units and saturated zones) will be required.
             Continuous soil sampling should also be con-
             ducted for at least the first 50 feet of vadose
             zone material.

         0.   Construct at least two geologic cross-sections
             perpendicular to one another from data obtained
             from the exploratory boreholes required for the
             site characterization.  The cross-sections
             should also  include the depths and thicknessess
             of all zones of saturation.

         E.   Determine the aquifer characteristics of perme-
             ability, transmissivity, storage coefficient
             and rate(s) and direction(s) of ground water
             flow.  Horizontal permeabilities can be deter-
             mined through the use of in-situ permeability
             testing, referred to above.  However, vertical
             permeability, transmissivity and storage
             coefficients must be obtained through the use
             of pump or aquifer test methods.  A number of
             tests, spaced out over the entire facility
             will be required  to determine aquifer charac-
             teristics and the degree of variability of
             these parameters across  the site.

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                           -53-


1.  Site Characterization: (Cont.)
    F.  Further define the extent of the lower-lying
        water-bearing units identified in the site
        water well (at least 3 zones).  Determine
        whether there is hydraulic connection between
        the uppermost water-bearing unit and underlying
        units.  This can also be acconplished through
        the use of aquifer tests.

2.  Well Construction;  Due to the inadequacies of the
    existing ground water monitoring system, new
    monitoring wells will be required to replace wells
    301, 305, 306 and 307 along with additional upgra-
    dient and down-gradient monitoring wells.

    A.  Screen Length:  The present ground water
        monitoring -veils have screen lengths' cf 50 and
        70 feet which are too long for the purposes of
        ground water monitoring at specific intervals.
        Screen lengths in the range of 10 to 20 feet
        should be used.  The exact length of screen
        will- be dependent on the exact formation condi-
        tions encountered.  If homogeneous water-bearing
        units are encountered that are significantly
        thicker than  10 fast, inen .-aucipie weils
        screened over 10 to 20 foot intervals covering
        the entire thickness of the unit should be
      .  constructed.

    3.  Pump Placement:  The position of the pump
        should be determined from well production data
        obtained for each well during the development
        of the well and/or during the previously
        referred to aquifer tests.

    C.  Filter Rack;  The length of the filter pack
        must be significantly reduced.  The top of the
        filter pack should not extend more than a few
        feet above the top of the screened interval.
        The filter pack must be sized to the formation
        which is being screened through the use of
        seive analyses.

    D.  Screen Slot Size/Spacing;  This should be
        determined after the size of the filter pack
        has been determined.  Screen slot size should
        conform to the size characteristics of the
        gravel pack, not of the formation.

    E.  Bentonite Seals;  Seals should be placed
        immediately above the filter pack followed by
        a grout seal.

-------
                           -54-


3.  Other Recommended Activities:

    A.  Conduct an assessment of the contamination
        which has occurred in the vicinity of well
        307 which would include a deliniation of the
        horizontal and vertical extent of the con-
        tamination plume(s) and directions and rates of
        movement (vertical and horizontal) of the
        ground water plume (s). .

    B.  Initiate a new investigation aimed at deter-
        mining the current extent of contamination in
        the unsaturated zone which has resulted from
        the past disposal of phosphoric acid liquors
        in the southeastern portion of the facility as '
        well as other potential contamination which may
        have occurred as a result of oast dsposal
        practices in the -area of trencr.es L-9.  Activi-
        ties should consist of vadose zone rccnitoring
        for soil moisture and subsurface gases.  The
        objective of this investigation is the deter-
        mination of whether contaminant migration has
       .moved beyond the facility boundary.

  '  C.  Investigate the feasibility of installin; a
       •vadose zone monitoring system.  The purposa of
        this system would be to augment cne deep ground
        water monitoring system allowing  the detection
        of subsurface contamination in advance of its
       -reaching the ground water.  This system would
        also be incorporated into the facility's ground
        water assessment program which has been triggered
        following the discovery in October,  1986 of
        ground water contamination in well 307.  Given
        the high negative values for soil moisture
        potential found in the vadose zone,  standard
        porous cup lysijnetry may be ineffective in
        monitoring the Limited soil moisture.  Alternate
        methods for measuring soil moisture such as
        Neutron Probes should be considered.  The
        limitations of all vadose zone monitoring
        devices should be considered before a system is
        selected for use.

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                               -55-
H.  Analytical Results

    Water quality data were validated- by. PRC for the ground
    Water Task Force for quality assurance.  Analytical results
    indicated ground water contamination- in well 307.  Mine  (9)
    volatile organic compounds were detected, all  in the parts
    per billion (ppb) range.  These compounds are:  1,1 DICHLORO-
    ETHENE, 1,1 DICHLOROETHANE, CHLOROFORM, 1,1,1  TRICHLORO-
    ETHENE, CARBON TETRACHLORIDE, TRICHLOROETHENE,  BENZENE,
    TETRACHLOROETHENE, and TOLUENE.  Results of U.S. Ecology's
    sample analysis of the splits taken during the  Task Force
    investigation indicated thirteen (13) volatile organic compounds
    detected.  In addition to the 9 compounds detected by the
    Task Force, TOTAL XYLENES, ACETONE, ETHYLBENZENE and CARBON
    DISULFIDE were detected by U.S. Ecology.  It is unknown  why
    these discrepancies exist.  In addition, TRICHLOROFLUORO-
    ETHENE was detected in wells 301, 305 and 306  which was  not
    detected in the Task Force sample split for these wells.
    -Table 7 presents r-^he results of this sampling.  METHYLENE
    CHLORIDE was detected in trip and field blanks along with  the
    sample and duplicates for well 307 so that results for
    METHYLENE CHLORIDE for all Task Force samples  were deemed
    invalid.  Other parameters which were detected in one or more
    blanks and determined to be invalid for Task Force data  were:

    Iron results for wells 305, 306 and 307
    Zinc result ;or  :he -site water supply weii  '
    Antimony result for well 306
    TOC results for all wells
    Total Phenols results for the water supply well-.
    TOX result for well 303

    All other parameters were considered validated and usable.
    Refer- to the Data Analysis Report, prepared by CDM, for  more
    detailed information.

-------
                               -56-
  I.  Facility Laboratory Quality Assurance/ Quality Control

      U.S. Ecology's contract laboratories consist of CEP Labora-
      tories of Santa Fe, New Mexico and Compuchem Laboratories
      of Triangle Park, North Carolina.  A laboratory audit was
      conducted by EPA contractor for CEP Laboratories, Inc. on
      July 23, 1987.  The results of this audit are contained in •
      the report entitled:  Report on the Audit of C.E.P.
      Laboratories, Inc., Santa Fe, New Mexico, September, 1987.
      CEP Laboratories, Inc. performed all chemical analyses
      of ground water samples collected at the Beatty, Nevada
      hazardous waste disposal facility as required under Interim
      Status ground water monitoring.  Compuchem Laboratories
      performed the ground water chemical analyses on samples
      taken by U.S. Ecology during the Ground Water Task Force
      field sampling which involved additional chemical
      parameters not routinely tested for under Interim Status
      ground water monitoring.  Compuchem Labs is a member of the
      Contract Laboratory Program ( CLP ) .  Therefore a laboratory
      audit was not conducted.  Data validation was performed on
      selected historical ground water data, obtained during
      Interim Status ground water monitoring during 1985 and 1986
      which were analyzed by CEP Labs.  Results are contained in
      the report entitled:''  Validation of Selected Historical
     • Ground Water Data from U.S. Ecology, September, 1987.

J.  Compliance With Ground Water Monitoring Requirerrents

    1)  270.14(c)- The full extent of the upper most aquifer has
        not been adequately defined in terms of its upper limit
        and the degree of its hydraulic connection with under-
        lying aquifers.  The ground water flow rate within the
        aquifer and the existance and magnitude of a vertical
        gradient within the aquifer have not been defined.
        Hydraulic characteristics of the aquifer have not been
        defined.

    2)  265.91- The areal coverage of the monitoring well network
        is insufficient to immediately detect statistically
        significant amounts of hazardous wastes or waste cons-
        tituents at all facility compliance points.  The wells
        are improperly designed for IOA ground water monitoring
    3)  265.93(a)- A ground water assessment plan has not been
        provided.

    4)  265.93(b)(c)(2)- Statistical comparisons have not been
        made between the arithmetic means of the indicator
        parameters (pH, specific conductance, TOX and TOC) of
        the monthly sampling of each well to its background  mean
        established after the initial year of sampling.  If  this
        procedure had been followed, contamination  in well  307
        may have been confirmed prior to October,  1986 when  U.S.
        Ecology and the Ground Water Task Force  took samples.   Data
        from March, 1986 for well  307 indicated  elevated levels of
        TOX.

-------
                                     -57-
    TABLE 7:  COMPARISON OF TASK FORCE AND U.S. ECOLOGY'S SAMPLING RESULTS
WELL
NUMBER

307














303 •
CONTAMINANT


METHYLENE CHLORIDE
1,1 DICHLQROETHENE
1,1 DICHLOROETHANE
CHLOROFORM
1,1,1 TRICHIOROETHANE
CARBON TETRACHLORIDE
TRICHLOROETHENE •
BENZENE
7ETRACHLOROETHENE
TOLUENE
ACETONE
CARBON DISULFIDE
ETHYL BENZENE
TOTAL XYLENES
TOX
METHYLENE CHLORIDE
U.S. ECOLOGY'S
SAMPLE RESULIS
10/86
5.6ug/l*
110
9.2
170
30
42
66
11
190
56
12
4. It
1.7t
9.6
•)
2. It
HWGWTF
SAMPLE RESULT
10/86
**
75/75tt
7.5/7.4
146/141
24/24
39/33
58/58
11/11
37/157
61/58
NOT FOUND
NOT FCUND
NOT FCUND
NOT FCUND
209/254
**
SITE WATER
WELL
301
305
306
METHYLENE CHLORIDE
ACETONE
BENZENE
TJRIG3LOROFUXDROETHENE
TRICHLQROFLUQROETHENE
TRICHDDROFLUOROETHENE
5. It
24
l.lt
2.4t
i.et
1.6t
»*
NOT FOUND
**
NOT FOUND
NOT FOUND
NOT FOUND
*   All concentrations in micrograms per  liter.
**  Contaminant found in trip and field blanks.  Results  should  not be used.
t   Value estimated by CEP  Laboratories,  Inc.
tt  First value is the sample, second value is the duplicate.

-------
                                     -58-
J.  Summary of Recommendations

    U.S. Ecology's ground water monitoring system for trench
    10 is inadequate.  The number of monitoring wells is
    insufficient to immediately detect leakage from a unit the  .
    size of trench 10.  Well construction is inadequate in terms
    of screen and filter pack lengths,.screen slot size/spacing
    and filter pack sizing.  Seive analyses should be performed.
    A new detection monitoring system must be installed after
    the facility has completed its hydrogeologic site charac-
    terization.  The upper limit of the uppermost water-bearing
    unit must be defined, more detailed borehole geologic des-
    criptions are needed, physical testing of cored samples and
    determination of aquifer characteristics including rate and
    direction of ground water movement.

-------
                                          -59-
                                  REFERENCES
 1.   Report on the Disposal Site at the Nuclear Engineering Co., Inc.
     July 18, 1961, Vincent P. Gianella.

 2.   Inscription and Interpretation of Aquifer Tests Performed on
     Nuclear Engineering Company's Test Well No. 1 near Beatty, Nevada.
     July. 14-17, 1961.  Charles E. Price.

 3.   Geology and Hydrology of a Proposed Site for Burial of Solid  Radio-
     active Waste SE o£ Beatty, Nevada.  June 1962.  Alfred Clebsch.

 4.   Walker, G.E., and Eakin, T.E., 1963, Geology and Ground Water of
     Armaqosa Desert, Nevada- California:  Nevada Department of Conser-
     vation and Natural Resources Reconnaissance Report 14, 57p.

 3.   Evaluation of the Potential for Waste Migration and Contingency
     Plan for Waste Containment,  industrial - Nuclear vv'aste Disposal
     Site, Beatty, Nevada, cor Nuclear Engineering Co., October 2,  1973.

 6.   Geohydrological Studies, Beatty, Nevada Disposal Facility,
     August 13, 1981.  Law Engineering Testing Company, Inc.  *

 7.   Geohydrologrcal/Ceotechrucal.Investigation Cata Report,
     May 13, 1981.  Law Engineering Testing Company, Inc.  *

 8.   Aquifer Test Results, Beatty Disposal Site, Beatty, >tevada,
     March 30,  1982, Converse Consultants, Inc. *

 9.   Program Management Assistance for Review of a Request for a Waiver
     from Ground Water Monitoring Pursuant to 40 CFR 264:  U.S. Ecology
     Inc., Beatty, Nevada, Second Review prepared by EPTEC for EPA,
     August 25, 1983.

10.   Letter to Mr. LaVferne Hosse, State of Nevada from Mr. David Fetter,
     U.S. Ecology dated September 31,  1984.

11.   Ground Water Monitoring Program, Seatty Nevada Facility.
     James L. Grant and Associates, April.25, 1984. *

12.   Report of Services Monitoring Well  Installation, U.S. Ecology
     Facility,  Beatty, Nevada.  Geotechnical Services,  Inc.
     July 10, 1984.

13.   Nicholas, William D., Geohydrology of the Unsaturated Zone at
     the Burial Site for Low-Level Radioactive Waste near  Beatty,  Nye
     County, Nevada, U.S. Geological Survey, Open File  Report 85-198.


 *  Reports prepared for U.S. Ecology

-------
                      APPENDIX  A
GROUND WATER CONDITIONS CONTAINED IN U.S. ECOLOGY'S RCRA
   OPERATING PERMIT FOR THE BEATTY,  NEVADA FACILITY

-------
                               A-l
II.  RFI TECHNICAL REQCJIREMEOTS

RCRA Facility Investigation;

     The Permittee shall follow.the procedures described in this
section when conducting  investigations to:  characterize the'
facility (Enviromental Setting); define the source  (Source Charac-
terization) ; define the  degree and extent of release of hazardous
constituents (Contamination Characterization); and  identify
actual or potential receptors.

     The investigation shall result in data of adequate technical
content and quality to support  the development and  evaluation
of the Corrective Action Plan if necessary. • The  information
contained in a RCRA Part B permit application and/or RCRA Section
3019 Exposure information Report may be referenced  as appropriate.

     The scope of all sampling and analyses shall be conducted
in accordance with the Sampling and Analysis Plan.  All sampling
locations shall be documented in a log and identified on a
detailed site map.

A.  Environmental Setting

     The Permittee shall collect information .to .supplement and/or
verify Part B information on the environmental setting at  the
facility.  The rennitte  shall characterize the following as  they
relate to identified sources, pathways, and areas of releases of
hazardous constituents frcm Solid waste Management  Units.

II.A.I.  Geologic and Hydrogeologic Site Characterization

    The permittee shall  conduct a program to evaluate geologic
and hydrogeologic conditions at the facility.  This program  shall
provide the following reports under the following schedules:

	Requirements	   	die Date	

Site Characterization Plan         45 days after  the effective  date
                                   this permit.

Site Characterization Plan         60 days after  the Administrator
Results and Well Installation      Director approve the Site
Plan                               Characterization Plan.

Implement well Installation        90 days after  the Administrator
Plan                               Director approve this plan.

Report on Ground Water             60 days after  the implementation
Monitoring Well Installations,     the well  Installation  Plan
and the Results of the
Hydrogeological Investigations.

-------
                               A-2
a.  Site Characterization Plan:'  This plan at a minimum shall
    include the following information:

     1. .A description of the regional and facility specific
         geologic and hydrcgeologic characteristics affecting
         ground water flow in the saturated and unsaturated
         zones beneath the facility, including:

          i.  Regional and facility specific stratigraphic
              description of strata including strike and dip,
              identification of stratigraphic contacts;
         ii.  Structural geology:  description of local and
              regional structural features (e.g., folding,
              faulting, tilting,  jointing, etc.);
        iii.  Cepositional history;
         iv.  Regional and facility specific hydraulic gradients
              and ground-water flow patterns;
          v.  Identification and characterization of areas and
              amounts of recharge and discharge; and

     2.  An analysis of any topographic features tht might
         influence the ground water flow system.

     3.  A plan to.provide adequate and .sufficient field 'data,
         through tests, cores and p.jzcmeters, classify and
         describe 'the hydrogeologic units which may be part of
         the migration pathways ac the facility  (.i.e., one
         aquifers and any intervening saturated and unsaturatec
         uhi ts), including:

          i.  Drilling method (e.g. Cable Tool, Air Sotory with
              casing hammer or equivalent)
         ii.  Hydraulic conductivity and porosity (total and
              effective);
        iii.  Lithology,. grain size, sorting, degree cf cementa-
              tion and moisture,  lithe-logical changes, beddings,
              fractures, color, mineralogical and petrolcgical
              identification, depth at which ground water first
              encounters any chemical odors with depth indications
         iv.  An interpretation of hydraulic interconnections
              between saturated zones;
          v.  The attenuation capacity and mechanisms of the
              natural earth materials (e.g., ion exchange capacity,
              organic carbon content, mineral content etc.);
         vi.  The uppermost aquifer: geologic formation, group of
            '  formations, or part of a formation capable of
              yielding a significant amount of ground water  to
              wells or springs; and
        vii.  Water-bearing zones above the first confining  layer
              that may serve as a pathway for contaminant migra-
              tion including perched zones of saturation.

-------
                               A-3
b.  Site Characterization Plan Results and Well Installation Plan

    This report shall be submitted to the Administrator and
  .  Director for review and approval of the Well Installation
    Plan.  This report shall include the following:

     1.  Based on data obtained from exploratory borings and
         piezo meters installed upgradient and downgradient of
         the -waste management facilities and potential contami-
         nant sources, an initial description of water level or
         fluid pressure monitoring including:

          i.  Water-level contour and/or potentimetric maps;
         ii.  Hydrologic cross sections showing vertical
              gradients;
        iii.  Geologic cross sections parallel and perpendicular
              to the ground water flow; and
         iv.  The flow system, including the vertical and'
              horizontal components of flow;

     2.  A description of manmade influences that may affect the
         hydrology of the site, identifying:

          i.  Local water supply and production wells with an
              approximate schedule of.pump ing;
         ii.  Site specific water supply and production well(s)
              with scneduie and race of Dumpings; anc
        iii.  Manmade hydraulic structures  (pipelines, trench
              drains, ditches, etc.).

     3.  All the results of the tests performed and calculations
         and detailed descriptions of methods of various analyses.

     4.  The proposed well Installation Plan incorporating:

          i.  •  Location of wells relative to waste management
                 areas.

              *  Horizontal placement of downgradient monitoring
                 wells.                          -     .

              •  ^fertical placement and screen lengths  [screen
                 lengths shall not exceed more than ten  (10)
                 feet.  If the Permittee proceses screen lengths
                 more than ten (10) feet, the proposal must  be
                 thoroughly justified].

              0  Drilling method  (cable tool, air rotory with
                 casing hammer or equivalent),

              0  Monitoring well construction materials.

              0  Sieve  analysis results of  the formation material
                 taken  from the horizons  in the  boreholes  where
                 each well will be screened.

-------
                       A-4
      0  Monitoring well filter pack sand (gravel) size
         based on sieve analysis results.

      0  Monitoring well screen slot size based on filter
         pack size.

      0  All the results of the analysis regarding the
         filter pack and screen slot size design
         including grain size distribution curves and
         calculations used to pick the filter pack and
         screen slot size.

      0  Well casings, annular sealants.

      0  Well development.

      3  Depth of dedicated pump below the static water
         Level in each monitoring well.  The dedicated
         pump in each well shall be installed so that
         samples from the upper 5 feet of water column
         be collected.  The maximum fluctuation of water
         level should be considered in each well and
         compensated for when determining the depths at
         which pumps will be installed.

 ii.   All ground water monitoring wells' installed after
      che effective uace of .this- permic .snail oe cons-
      tructed in a manner that maintains the integrity of
      the drill hole and prevents cross contamination of
      saturated zones.  The annular space shall be packed
      with'appropriate filter material; .the annular space
      above the screened depth shall be appropriately
      scaled to prevent the movement of sediment into the
      casing.  Each well shall be marked permanently so as
      to readily identify it.  All monitoring weels shall
      be logged during drilling under the direct
      supervision of a registered geologist.  Soil shall
      be described according to the united Soil Clas-
      sification System.
ill.   The installation of several deep monitoring wells,
      which would be screened in the saturated zone(s)
      below the "upper-most aquifer", at several loca-
      tions throughout the facility;
 iv.   Rimp test programs incorporating the deep wells,
      wells screened- in "uppermost aquifer", and any
      other shallower wells; and
  v.   Description of the method which will be utilized
      to analyze the pump test data
 vi.   Packer and/or slug tests.

-------
                               A-5
c.  Report on. Ground Water Monitoring well Installation and
    Results of the Hydrogeologic Investigations.

    Based on all the data obtained from ground water monitoring
    wells and piezometers installed upgradient and downgradient
    of the waste management units, the Permittee shall sutter a
    representative description of hydrogeologic characteristics
    of the facility including:

          i.  water level contour maps;
         ii.  Flow nets showing the vertical gradients;
        iii.  Geologic cross sections parallel and perpendicular
              to the flow iv.  Permeability, transmissivity,
              storage capacity and porosity values based on pump
              tests, packer and/or slug tests.
          v.  Any temporal changes in hydraulic gradients due to
              seasonal influences.

     2.  Soils                   •               -  '

     The Permittee shall conduct a program to evaluate soils at
the facility  (or refer to such a program previously submitted
with the Part B) which shall provide the following information:

          a.  Surface soil distribution;                   •
          b.  Soil profile, including ASH1 classification of soils;
          c.  transects .;i soil stratigraphy;
          d.  Hydraulic conductivity (saturated and unsaturated);
          e.  Relative permeability;
          f.  Bulk density;
          h.  Soil sorptive capacity;
          i.  Cation exchange capacity (CZC);
          j.  Soil organic content;
              Soil pH;
          1.  Particle size distribution.
          m.  Depth of water table;
          n.  Moisture content;
          o.  Effect of stratification on unsaturated flow;
          p.  Infiltration;
          q.  Bvapotranspiration;
          r.  Storage capacity;
          s.  Vartical flow rate; and
          t.  Mineral content.

     3.  Vadose Zone Monitoring

     The Permittee shall submit a workplan for a program to
assess the technical ieasibility of an effective Vadose Zone
monitoring system.

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                               A-6


   •  4.  Surface Water and Sediment

     The Permittee shall conduct a program to evaluate surface
water bodies in the vicinit of the facility.  Such characteriza-
tion may include, but not be limited to, the following activities
and provide the following information

     a.  Description of the temporal and permanent surface water
         bodies including:

          i.  For lakes and estuaries:  location, elevation,
              surface area inflow, outflow, depth, hexperature
              stratification, and volume;
         ii.  For impoundments:  location, elevation surface
              area, depth volume, freeboard, and construction and
              purpose;
        iii.  For streams, ditches, and channels:  location,
              elevation, flow, ^velocity,, depth, width, seasonal
              fluctuations, flooding tendencies  (i.e., 100 year
              event), discharge point(s), and general contents;
         iv.  Drainage patterns; and
         v.   Evapotranspiration..

     b. . Description of the chemistry of the natural surface
         water and sediments.  This includes determining the pH,
         total dissolved solids, total suspense solids, bio-
         logical oxygen demand, alkali conductivity, -dissolved
         oxygen profiles nutrients (NH chemical oxygen demand,
         total organic carbon, specifi con concentrations, etc.

     c.  Description of sediment characteristics including:

          i.  Deposition area;
         ii.  Thickness profile; and
        iii.  Physical and chemical parameters (e.g., grain size,
              density/ organic carbon content, ion, exchange, pH,
              etc.).

    5.  Air

     The Permittee shall provide information characterizing the
climate in the vicinity of the facility.  Such information may
include/ but not be limited to:

     b.  A description of the following parameters:

          i.  Actual and monthly rainfall averages;
         ii.  Monthly temperature averages and extremes;
        iii.  Wind speed and direction;
         iv.  Relative humidity/dew point;
          v.  Atmospheric pressure;
         vi.  Evaporation data;
        vii.  Development of  inversions; and
       viii.  Climate extremes that have been known  to occur  in
              the vicinity of  the  facility,  including frequency
              of occurrence  (i.e., hurricanes).

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                               A-7
    b.   A description of topographic and manmade features which
         affect air flow and emission patterns, including:

          i.  Ridges, hills or mountain areas:
         ii.  Canyons or valleys;
        iii..  Surface water bodies (e.g., rivers, lakes, bays, etc.);
         iv.  Buildings.

B.  Source characterization

    For those sources free which releases of hazardous cons-
tituents have been detected the Permittee shall collect analytic
data to conpletely characterize the wastes and the areas where
wastes have been placed, to the degree possible without undue
safety risks, including:  type; quantity; physical form; disposi-
tion (containment or nature of deposits); and facility charac-
teristics affecting release (e.g., facility security, and
engineering barriers).  This snail include quantification of the
following specific characteristics, at each source area:

     1.  Unit/Disposal Area Characteristics;

         a.   Iccation cf unit/disposal area;
         b.   Type of unit/disposal, irea;             '  •
        . c.   Design features;
         d.   Operating practices (oust and present);
         <3.   ?eriod oi operation;
         f.   Age of unit/disposal area;
         gi   General physical conditions; and
         h.   Method used to close the unit/disposal area.

     2.  Waste Characteristics;

          a.  Type of wastes placed in the unit:

               i.  Hazardous classification  (e.g.,- flammable,
                   reactive, corosive, oxidizing or reducing
                   agent);
              ii.  Quantity; and
             iii.  Chemical composition.

          b.  Physical and chemical characteristics such as:

               i.  Physical form  (solid, liquids, gas);
              ii.  Physical description  (e.g., pcwder, oily
                   sludge);
             iii.  Temperature;
              iv.  pH;
               v.  General chemical class (e.g., acid, base, solvent);
              vi.  Molecular weight;
             vii.  Density;
            viii.  Boiling point;
              ix.  Viscosity;
               x.  Sclubility in water;
              xi.  Conesiveness of the waste; and
             xii.  Vapor pressure.

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                               A-8
          c.  Migration and dispersal characteristics of the
             . waste such as:          •

              . i.  Sorption capability;
            •  ii.  Biodegradability, bioconcentration, biotrans-
                   formation;
             iii.  Photodegradation rates;
              iv.  Hydrolysis rates; and
               v.  Chemical transformations.

    The Permittee shall document the procedures used in making
the above determination.

C.  Characterization of Release of Hazardous Constituents

     The Permittee shall collect analytical data en ground water,
soils, surface water, sediment, and subsurface gas contamination
in che vicinity of the facilicy in accordance with the sampling
and analysis plan as required above.  These data shall be suf-
ficient to define the extent, origin, direction, and rate of
movement of contamination.  Data shall include time and location
of sampling, media sampled, concentrations found, conditions
during sampling, and the identify of the individuals performing
the sampling and analysis. .The Permittee shall follow the pro-
cedures described below when investigating each of the media:
     The Permittee shall collect at a manimum the following
information when conducting investigations of ground-water con-
tamination at the facility including -well 307 at the compliance
point of Trench 10:

          a.  A descriptoicn of the horizontal and vertical
              extent of any plumes(s) of horizontal constituents
              originating from the facility;
          b.  The horizontal and vertical direction of contamina-
              tion movement;

          c.  The velocity of contaminant movement;

          d.  The horizontal and vertical concentration profiles
              of Appendix IX (Table 4 of Attachment B) hazardous
              constituents in the plume(s);

          e.  An evaluation of factors  influencing the plume
              movement; and

          f.  An extrapolation of future contaminant movement.

     The Permittee shall document the procedures used  in  making
the above determinations (e.g., well design, well construction,
geophysics, modeling, etc.).

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                               A-9


     2.  Soil Contamination

     The Permittee shall collect at a minimum the following
information when conducting investigations of soil contamination
at the facility:

          a.  A description of the vertical and horizontal exte'nt
              of contamination;

          b.  A description of appropriate contaminant and soil
              chemical properties within the contaminant source
              area "and plume,  this may inlcude contaminant
              solubility, speciation, adsorption, leachability;
              exchange capacity, biodegradability, hydrolysis,
              photolysis, oxidation and other factors that might
              affect contaminant migration and transformation;

          c.  Specific contaminant concentrations;

          <*-  The velocity and direction of contamination move-
              ment; and

          e.  An extrapolation of future contaminant movement.

     The Permittee shall document the procedures used in making
the .above determinations.

     3.  Surface Water and Sediment Contamination

     The Permittee shall collect at a minimum the following
information when conducting investigations of surface water and
sediment contamination at the facility:

          a.  A description of the horizontal and vertical extent
              of any plume(s) originating from the facility/ and
              the extent of contamination in underlying sediments

          b.  The horizontal and vertical direction of contaminant

          c.  The contaminant velocity;

          d.  An evaluation of the Physical, biological and
              chemical factors influencing contaminant movements

          e.  An extrapolation of future contaminant movement; and

          f.  A description of the chemistry of the contaminated
              surface waters and sediments.  This includes deter-
              mining the pH, total dissolved solids, specific
              contaminant concentrations, etc.

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                               A-10


     4.  Air Contamination

     The Permittee shall collect at a minimum the following
information when conducting investigations of air contamination
at the facility:

          a.  A description of the horizontal and vertical
              direction and velocity of contaminant movement;

          b.  The rate and amount of the release; and

          c.  The chemical and physical composition of.the
              contaminant(s) released/ including horizontal and
              vertical concentration profiles.

     The Permittee shall document the procedures used  in making
the aJbove determinations.

     5.  Subsurface Gas Contamination

     The Permittee shall collect at a minimum the following
information as part of the Vadcse Zone monitoring and  conducting
investigations of air contamination at the facility:

          a.  Sample che-gas'phase in all existing dry wells
              (prior to plugging) and monitoring wells. . Samples
              ohall '33 analysed ' for ail parameters listed  in
              table 1 of Attachment B.

          b.  A description of the horizontal and vertical
              extent of subsurface gas migration;

          c.  The chemical composition of the gases being emitted;

          d.  The rate, amount, and density of  the gases being
              emitted; and

          a.  Horizontal and verticar~concentration Profiles' of
              the subsurface gases emitted.

    The Permittee shall document the procedures used in making
the above determinations.

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                               A-ll
4.  Ground Water Monitoring

    [40 C.F.R. 264.90(a)(c), 264.91(a)(4) and (b), 264.97,
     270.14(c)]     -

A.  New RCRA Ground Water Monitoring System Location, Design and
    Construction

    The Administrator and Director have determined that the
    existing ground water monitoring wells at the facility are
    not capable of yielding representative ground water samples,
    the Permittee shall replace all the existing upgradient and
    downgradient wells with new RCRA ground water monitoring
    system. The Permittee shall install and maintain a ground
    water monitoring system to comply with the requirements of
    §264.97. The RCRA Ground Water Monitoring Technical
    Enforcement Guidance document will be used by the director
    for evaluation of the Permittee's proposed ground water
    monitoring system. The Permittee shall 'comply with the
    following conditions, as specified below:

    1.  The Permittee shall submit a plan for installation,
        locations and number of RCRA ground water monitoring
        wells' for .the regulated unit trench 10 to the Adminis-
        trator and Director for approval, within two  (2)
        months after the completion of site characterization as
        .specified in --he ?QA. Facility Investigation • !?5I}  .uan
        required by Condition II.A.I of the Permit issued by the
        E.P.A under the authority of Hazardous and Solid Waste
        Anmendments (HSWA).  The plan shall include:

          a.  Technical report regarding geological and hydroge-
              ological site characterization as specified  in the
              RFI Plan of HSWA portion of this permit.

        •  b.  Detailed report describing proposed program regar-
              ding the placement of upgradient and downgradient
              ground water monitoring wells. The plan shall
              include:

              0  Location of wells relative to waste management
                 areas

              9  Horizontal placement of downgradient monitoring
                 wells

              0  Vertical placement and screen  lengths  [srceen
                 lengths shall not exceed more  than  ten  (10)
                 feet.   If  the Permittee proposes screen  lengths
                 more than  ten  (10) feet,  the proposal must be
                 thoroughly justified.]

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                     A-12
c.    Detailed report, describing proposed ground water
      monitoring well design and construction.  The
      proposed plan shall include:

      0  Drilling method (cable tool, air rotary with
         casing hammer or equivalent)

      0  Monitoring well construction Materials

      0  Sieve analysis results of the formation
         material taken from the horizons in the bore-
         holes where each well will be screened  .

      0  Monitoring well filter pack sand (gravel) size
         based on sieve analysis results

      0  Monitoring.well screen slot size based on the
         filter pack size

      0  All the results of the analysis regarding
         the filter pack and screen slot size design
         including grain size distribution curves and
         calculations used to pick the filter pack and
         screen slot size.     ...

      0  well casings, annular sealants .

      0  well development

      0  Depth of dedicated pump below the static water
         level in each monitoring well. The dedicated
         pump in each well shall.be installed so that
         samples from the upper 5 feet of water column
         be collected. The maximum fluctuation of water
       •  level should be considered in each well and
         compensated for when determining the depths at
         which pumps will be installed.

d.  All ground water monitoring wells installed after
    the effective date of this permit shall be cons-
    tructed in a manner that maintains the integrity of
    the drill hole and prevents cross contamination of
    saturated zones. The annular space shall be packed
    with appropriate filter material; the annular space
    above the screened depth shall be appropriately
    scaled to prevent contamination of samples and the
    ground water; and the well shall be adequately
    developed to prevent the movement of sediment into
    the casing.  Each well shall be marked permanently
    so as to readily identify it.  All monitoring wells
    shall be logged during drilling under the direct
    supervision of a registered geologist.  Soil shall
    be described according to the United Soil
    Classification System.

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                               A-13
          e.  The Pennittee shall install the new RCRA ground
              water monitoring system and shall submit certifica-
              tion of installation within three (3) months of
              approval of the number, location, design and cons-
              truction of the ground water monitoring wells.

          f.  The Pennittee shall continue sampling the existing
              ground water monitoring wells for parameter listed
              in condition 4.E.3 quarterly until the new. RCEA
              system is in place in accordance with condition  4.A
              of this permit.

B.  Sampling and Analysis Procedures  [264.97(d) and (e)]
     1.  The Pennittee shall revise, incorporate and  implement
        • the following, modifications and revisions  in  the
         Sampling Manual, Vol. VI of the part  3 application,
         immediately after the effective date  of this  permit:

          a.  Develop a Guality Assurance/Quality Control  program
              that includes adequate, duplicate and  blank samples.
              Follow the criteria specified  in the  TEGD dated
              September 1986.

          b.  A method shall be devised to measure  the depth  to
              the boctcm of che wells at every .sampling event.

          c.  A tape measure with increments of  1/100 of a foot
              shall be used to measure depth to water and  depth
              to the bottom of the well in aver/ sampling  event.

          d.  Monitor for organic vapors at  the well  head

          e.  A method shall be developed for  detection of immis-
              cibles in the wells.  This must  occur before the
              purge begins.

          f.  In-situ measurements shall include PH,  turbidity,
              temperature and specific conductance.  These
              measurements must be made at the well,  not back at
              the facility laboratory.

          g.  In-situ measurements shall be  measured  both  before
              and after sampling.

          h.  TOX and TOC samples shall be collected  in separate
              bottles with correct preservatives.   Samples for
              TQX should have no head space.  The bottles  must  be
              glass and have  teflon  lined caps.

          i.  Phenol samples shall be preserved with  sulfuric
              acid (H2S04).

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                               A-14


          j.  The water level indicator shall be calibrated on
              a regular basis.

          k.  Hie calibration of the water level indicator, PH
              and conductance meters shall be documented  in the
              field log books.

          .1.  Sample containers, sample I.D. numbers and  sample
              preservation shall be listed in the  field leg book.

          m.  Information to be noted on the chain of custody/
             . lab request form must be listed in complete detail.

          n.  The laboratory where samples are analyzed must
              maintain a log beek detailing the condition or;  the
              samples at the time of receipt, sample hold ".Lxes
              and analysis procedures.

     2.  The Permittee shall collect, preserve, ship, tracx and
         control samples in accordance with the conditions listed
         in Section 4.B.I of this permit, the criteria specified
         in the TEGD dated - September 1986, and by  the techniques
         described in Sections 3.0 through 6.0 of  Volume-  VI
         of the May 27, 1987 revised application.  Where
         apparent conf"ict. exists between the part B application
         and this section of the permit, the Permittee shall
         comply wich conditions listed in cnis cermic.  •[4G
         C.F.R.  264.97(d)(l) (2)(4), 264.97(ef, and 264.98{£)].

C.  Ground Water Elevation

    The Permittee shall determine the ground water surface
    elevation in each well, prior to pumping/ at each sampling
    event;  [40 C.F.R. 264.97(f)].

D.  Background Ground Water Cuality

    The Permittee shall collect and analyze samples fron  the  new
    upgradient ground water monitoring wells, described in condi-
    tion 4.A, quarterly for one year and hence forth semi-
    annually during the active life of the facility, and  during
    the closure and post-closure care periods. The Permittee
    shall conduct the first quarterly sampling event immediately
    after completion of condition 4.A in this permit. The
    Permittee shall collect and analyze samples  frcm these ground
    water monitoring wells as follows'  [40 C.F.R.  264.97(g)(1)(4)
    and (h), 264.98(a), 264.98(c), 270.31, and  270.32].

     1.  The Permittee shall collect and analyze samples  pursuant
         to condition 4.B; except that,

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                               A-15
     2.  The samples collected from each ground water monitoring
         well shall be split by the Permittee into at least four
         individually preserved and labeled samples before ship-
         ment for analyses; and

     3.  The Permittee shall analyze the individually preserved
         and labeled split samples for each parameter in Tables
         1 through 3, in Attachment B. If more than four split
         samples are required to obtain analyses from each ground
         water monitoring well for each parameter in Tables 1
         through 3, the Permittee shall prepare additional split
         samples as may be required.

E.  Ground Water Quality

    The Permittee shall -collect and analyze samples from all new
    downgradient ground water monitoring wells described in
    permit -condition 4.A quarterly curing the active life of
    the facility, and during che closure and oost-clcsure care
    periods.  The Permittee shall conduct the first quarterly
    sampling event immediately after completion of condition
    4.A in this permit. The Permittee shall collect and analyze
    samples from these ground water monitoring wells as follows:

    [40'C.F.R. 264.97(h), 254.98(a), 264.98(d),• 270.31, and
    270.32].                 '                       ••     .

     i.  The Permittee shall collect samples pursuant to condi-
         tion 4.B; except that,

     2.  The samples collected from each ground water monitoring
         well shall be split by the Permittee* into  at least four
         individually preserved and labeled samples before ship-
         ment for analyses; and

     3.  the Permittee shall analyze the individually preserved
         and labeled split samples for each parameter in Tables
         1 through 3, in'Attachment B. If more  than four split
         saaplea are required to obtain analyses from each ground
         water monitoring well for each parameter in Tables 1
         through 3, the Permittee shall prepare additional split
         sangles as may be required.

     4.  The Permittee shall determine the ground water flow  rate
         and direction in the uppermost aquifer at  least annually,
         as required by 40 C.F.R 264.99(e).

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                               A-16
     5.  The Permittee shall determine whether  there  is a  statis-
         tically significant increase, for each parameter  inden-
         tified in condition 4.D.3, over  the background values
         for that parameter each time ground water quality is
         determined in accordance with condition  4.E.  In
         determining whether such an increase has occured, the
         Permittee must compare the ground water quality at each
         new monitoring well described in condition 4.A, to the
         background levels established by the procedures set
         forth in condition 4.D, and in accordance with the
         procedures specified in condition 4.F.

F.  Statistical Analysis

     1.  The Permittee shall analyze the data obtained from all
         sampling events required by permit conditions 4.D and
         4.£ by using the following procedures:

     2.  When a constituent's oackground value has a  sample
         coefficient of variation less than 1.00, the Permittee
         shall follow the statistical procedures described in 40
         C.F.R. 264.97(h)(l)(i).

     3.  In all other situations' the Permittee shall  use a
         statistical procedures which satisfy' the requirements of
         40 C.F.R.' 264.97(h)(2)

G.  Reporting, Recordkeeginq and Response
     1.  The Permittee shall enter all monitoring,  testing
         and analytical data obtained pursuant to condicion
         4.E in the operating record, as required by  40 C.F.R.
         264.73(b)(6).

     2.  The Permittee shall submit to the Administrator and
         Director all the analyses results regarding  the
         indicator parameters (TCC, TQX, IDS, heavy metals,
         and PH) obtained pursuant to conditions 4.0  and 4.E,
         in the following format*

          i.  Sunraary of the sampling results shall be submitted
              in a tabular form showing in columns: well number,
              quarterly dates of sampling, and concentration of
              each indicator parameter  (specified in  condition
              4.G.2) corresponding to each new well in parts per
              million (ppm).

         ii.  The.results described in condition 4.G.2.i shall
              also be submitted in the  form of graphs. Each
              graph must show concentrations of each  indicator
              parameter, specified in condition  4.G.2, versus
              time (quarterly) for all  the new ground water
              wells.

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                          A-17
   iii.   The information in conditions 4.G.2.i and 4.G.2.ii
         shall be sutmitted biannually to the Administrator
         and Director sixty (60) calendar days after the
         completion of second and forth quarterly sampling
         event. The information submitted must include the
         previous quarterly results.

3.   The  Permittee shall submit all data and  analyses
    obtained pursuant to conditions 4.D, 4.E, and" 4.F to the
    Administrator and the Director no later  than ninety
    (90) calendar days after each sampling event [40 C.F.R.
    270.31 and 270.32].

4.   If the Permittee determines, pursuant to condition 4.F
    that there is a statistically significant increase above
    background values for the parameters specified in Tables
    1 through 3, the Permittee shall:

     i.   Notify the Administrator and the Director in
         writing within seven (7) days pursuant to 40
         C.F.R. 264.98(h)(l);

    ii.   immediately sample the groundwacer in all wells
         and determine tfce concentration of all the Appendix
         IX parameters identified in Taole 4, pursuant to  40
         C.F.R. 264.98(h)(2);

   iii.   establish background values pursuant to 40 C.F.R.
         264.98(h)(3) for each parameter from Table 4 found
         in the ground water pursuant to condition G.4.ii;

    iv.   An assessment plan shall be submitted to the
         Administrator and the Director for review and
         approval immediately after performing conditions
         G.4.i, G.4.ii and G.4.iii. The plan shall include
         the requirements specified in the condition II.C.I
         (Attachment A, RFI Technical Requirements) of the
         permit issued by the EPA under the authority of
         Hazardous and Solid Waste Amendments (HSWA).

     v.   Sutmit to the Administrator and Director pursuant
         to 40 C.F.R. 264.98(h)(4) and application for a
         permit modification to establish a compliance
         monitoring program meeting the requirements of 40
         C.F.R. 264.99; the applicant must include the
         information specified in 264.98(h)(4)(i) through
         264.98(h)(4)(iv).

    vi.   Submit to the Administrator and Director a correc-
         tive action feasibility plan pursuant to 40 C.F.R.
         264.98(h)(5).   [40 C.F.R.  264.98(h)(5)].

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                               A-18
H.  If the Permittee determines that the ground water detection
    and assessment monitoring program required by this permit no
    .longer satisfies the requirements of 40 C.F.R. 264.98,  the
    Permittee must,.within ninety (90) calendar days after
    making such a determination, submit an application for  a
    permit modification to make any appropriate changes to  fche
    ground water monitoring program.  [40 C.F.R. 264.98(j)J.

I.  The Permittee must assure that monitoring and corrective
    action measures necessary to achieve compliance with a  ground
    water protection standard under 40 C.F.R. 264.92 are taken
    during the term of this permit.  [40 C.F.R. 264.98(k)].

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                   APPENDIX B
Analytical Parameters for Ground Water Analysis

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                      US ECOLXY BEATTY SITE
    Analytical Parameters  for Groundwater  and  Leachate  Samples
                        Volatiles
chloromethane
brcnone thane
vinyl chloride
chloroethane
methylene
acetone
carbon disulfide
1,1,-dichloroethene
1,1, -dichloroechane
trans-1,2-dichlorcethene
chloroform
1,2-dichioroethane
2-butanone
1,1,1-trichloroe thane  •
carbon tatrac' loride
vynil acetate
bromodichlorcT.e thane
1,1,2,2,tetrachloroethane
1,2-dichloropropane
trans-1,3-dichloropropene
trichloroethane
dibromochloromethane
1,1,2-trichloroethane
benzene
cis-1,3-dichloropropene
2-iiloroetnylvinylecner
brcrnoform
2-hexanone
4-methyl-2-pentanone
tetrachloroethene
toluene
chlorobenzene
ethylbenzene
styrene

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                       Semi-Volatiles
acenaphthene
2,4-dinitrophenol
bis(2-chloroethyl) ether
2-chlorophenol
1,3-dichlorobenzene
1,4-dichlorobenzene
benzyl alcohol
1,2-dichlorobenzene
2-tne thy 1 phenol
bis(2-chloroisopropyl)ether
4-methylphenol
n-ni troso-di-n-propylamine
hexachloroethane
nitrobenzene
isophorone
2-nitrophenol
2,4-dimethylphenol
benzoic acid
bis(2-chloroethoxy)methane
2,4-d ichlorophenol
1,2,4-trichlorobenzene
naphthalene
4-chloroaniline
hexachlorobutadiene
4-chloro-3-methylphenol
2-methyInaphthalene
hexachlorocyclopentadiene
2,4,6-trichlorophenol
2,4,5-trichloropnenol
2-cnloronaphthalene
2-nitroaniline
dimethyl phthalate
acenaphthylene
phenol
4-nitrophenol
dibenzofuran           .
2,4-dinitrotoluene
2,6-dinitrotoluenc
diethylphthalate
4-chlorophenyl-phenylether
fluorene
4-nitroaniline
4,6-dinitro-2-methylphenol
n-notrosodiphenylamine(1)
4-bronopheny1-phenyle the r
hexachlorobenzene
pentachloropheno1
phenanthrene
anthracene
di-n-butylphthalate
fluoranthene
benzidine
pyrene
butylbenzylphthalate
3,3-dichlorobenzidine
ienzo(a)anthracene
bis(2-« thyIhexyl)phthalate
chrysene.
di-n-octyl phthalate
benzo(b)fluoranthene
benzo(k)fluoranthene
benzo(a)pyrene
indeno(1,2,3-cd) pyrene
dibenz(a,h)anthracene
benzo(g,h,t)perylene
3-nitroaniline

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                    Pesticides/PCB'S
alPha-BHC
delta-BHC
heptachlor
heptachlor epoxide
dieldrin
endrin
4, 4-DDD.
endosulfan sulfate
methoxychlor
chlordane
aroclor-1016
aroclor-1232
aroclor-1248
arocior-1260
                 Metals and Others
aluminum
antimony
arsenic   ^
barium. '
beryllium
cadmium
calcium
chrcmium
cobalt
copper
iron
lead
cyanide
anncnia
chloride
nitrate
Purgeable organic carbon
Purgeable organic halide
beta-BHC
gamma-BHC (lindane)
aldrin
endosulfan 1
4,4-ODE
endosulfan II
endrin aldehyde
4,4-DDT
endrin ketone
toxaphene
aroclor-1221
aroclor-1242
arccior-1254
magnesium
manganese
mercury
nickel
potassium
silver
sodium
thallium
tin
vanadium
zinc
Percent solids  (%)
sulfates
total organic carbon
total organic halide
total Phenols

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