Hazardous Waste Ground-Water Task Force: Evaluation of U.S. Ecology Facility Beatty, Nevada


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

—
TYPE
LANDFILL
TRENCH
it

•

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

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

350x4x10

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
-------
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
-------
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
-------
Sill CLAN

Seal* »"=IOO
Source: US Ecology 1984
FIGURE
PCB PROCESSING FACILITIES LOCATION
-------
-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.
-------
17
38*30-

^,.^ STUDY AREA

'
V.
» 30
I |
\
« 4: LOCATION OF STUDY AREA
-------
18
FIGURK: 5 PROXIMITY OF DISPOSAL AREA TO HIGHWAY 95
EXPLANATION
r«dio«ctr»«-*«tt
burial VM, 1980
m
r ad «»«»•••«•»•»«
burial arta b«
-------
-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.
-------
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
-------
-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.
-------
-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:
-------
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 »
-------
-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
-------
-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
-------
-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.
-------
-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.
-------
-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.
-------
-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).
-------
-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

*
yrrto

' *«
r*
fe
X

1
•^•••i
1 II
III
Ml
III
1"
i i i n
n
A

^^__ 1
^^ U

X
•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
s
, ^%
•• •
• '**'
* 4
'(:]
....-)
t\ *
-
. '.•",
-.-.-
UB
s,
L^
• 1
• *
\*
**4
4
;;
• t
''.

1 1 'I
it
i>
|i
i »
i
_L i 1 1
' _-*— • HIMOEO TOP
=^— -^^

\
•
*

':, IOW> 220 Ft)
• 4
*•
» r
\

' f
.'J ^>0^— 8ENTONITE PLUS
^^^ AT 430 FT
*1 ( AFWIOX. 1 Ft THICK)
, | ^ WATEff LEVEL
^— ~ MEASURED AT SOO FT.
OK 7-«-»4

(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
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
-------
-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
-------
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

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.
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-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.
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-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.
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-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).
-------
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.
-------
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.).
-------
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.
-------
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.
-------
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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