-------
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
-------
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
-------
-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.
-------
-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.
-------
-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.
-------
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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