July 1986 EPA-330/2-86-008 Hazardous Waste Ground-Water Task Force Evaluation of Wayne Disposal, Inc. Belleville, Michigan UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ------- July 14, 1986 UPDATE OF THE HAZARDOUS WASTE GROUND-WATER TASK FORCE EVALUATION OF WAYNE DISPOSAL, INC. , FACILITY The United States Environmental Protection Agency’s Hazardous Waste Ground-Water Task Force (“Task Force”), in conjunction with the Michigan Department of Natural Resources (MDNR), conducted an evaluation at the Wayne Disposal, Inc. hazardous waste disposal facility. Wayne Disposal was the third of 58 facilities to be evaluated by the Task Force. The Task Force effort is in response to recent concerns as to whether owners and operators of hazardous waste disposal facilities are complying with the RCRA ground-water monitoring regulations, and whether the ground-water monitoring systems in place at the facilities are capable of detecting contaminant releases from waste management units. The Wayne Disposal facility is located in Belleville, Michigan, which is approximately 15 miles west of Detroit, Michigan. The onsite field inspection was conducted over a 2—week period from August 27 through September 6, 1985. The purpose of the Task Force evaluation was to determine the adequacy of the ground-water monitoring system in regard to Federal ground-water monitoring requirements. Specifically, the objectives of the evaluation at Wayne Disposal were to: • Determine compliance with 40 CFR Part 265 interim status ground- water monitoring requirements • Evaluate the ground-water monitoring program described in the RCRA Part B permit application for compliance with 40 CFR Part 270. 14(c) • Determine if hazardous waste constituents have entered the ground- water at the facility At the time of the inspection, the facility had a total of 33 ground- water monitoring wells, 14 of which are used for RCRA monitoring. The current number and position of RCRA wells is based on a 1984 consent agree- ment between USEPA and Wayne Disposal. It was determined that the facility was in compliance with the applicable RCRA interim status requirements ------- 2 for certification, as required by the Hazardous and Solid Waste Act Amendments (HSWA) of 1984. Wayne Disposal was not following the onsite sampling and analysis plan presented during the evaluation. Also, the reported total organic carbon values were not valid because the analytical method used only yielded results representative of the nonpurgeable organic carbon fraction of each sample rather than total organic carbon. The Task Force found the facility to be in compliance with 40 CFR Parts 265.93 and 265.94, as the ground-water quality assessment was carried out as required. At this time, the facility is conducting interim status detection monitoring. The Task Force recommends that the Wayne Disposal facility upgrade and improve the ground-water monitoring program described in the RCRA Part B permit application in order to comply with the 40 CFR Part 270.14(c). Specific issues will be addressed during the decision process for issuing the RCRA permit. The Task Force analytical results show organic hazardous waste constit- uents in six wells. However, these constituents are believed to have originated from contaminated pumps rather than from the waste management units. Based on the existing ground-water monitoring system, there is no indication that the hazardous waste management units are contributing to ground-water contamination. On April 25, 1986, USEPA issued a complaint for the ground-water monitoring violations that were discovered as a result of the facility evalutaion, in addition to other violations. The ground-water monitoring violations cited were: 40 CFR Part 265.92(a) - Failure to follow the onsite sampling and analysis plan 40 CFR Part 265.92(b), (c) and (d) — Failure to determine concentra- tion of TOC in ground-water samples ------- 3 Enclosed with the complaint was a compliance order requiring Wayne Disposal to comply with the above referenced regulatory ground-water moni- toring requirements, and to correct other RCRA interim status violations (not related to ground-water monitoring). A civil penalty of $62,000 was proposed. The facility reserved its right to a formal hearing, but is pre- sently pursuing an out-of-court settlement. This completes the Hazardous Waste Ground-Water Task Force evaluation of the Wayne Disposal, Inc. facility. ------- UNITED STATES ENVIRONMENTAL PROTECTION AGENCY HAZARDOUS WASTE GROUND-WATER TASK FORCE EPA-330/2-86-008 GROUND-WATER MONITORING EVALUATION WAYNE DISPOSAL, INC. Belleville, Michigan July 1986 Alan E. Peckham Project Coordinator National Enforcement Investigations Center ------- 9 9 10 13 13 14 15 CONTENTS EXECUTIVE SIJ IARY INTRODUCTION . 1 SU 1ARY OF FINDINGS AND CONCLUSIONS 8 COMPLIANCE WITH INTERIM STATUS GROUND-WATER MONITORING - 40 CFR 265 SUBPART F §265 91 Ground-Water Monitoring System §265.92 SamplIng and Analysis . §265.93 PreparatIon, Evaluation and Response GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT TASK FORCE SAMPLING AND MONITORING DATA ANALYSIS COMPLIANCE WITH SUPERFUND OFFSITE POLICY TECHNICAL REPORT INVESTIGATIVE METHODS . . . 16 RECORDS/DOCUMENTS REVIEW AND EVALUATION 16 FACILITY INSPECTION 17 LABORATORY EVALUATION 17 GROUND-WATER. SURFACE WATER AND LEACHATE SAMPLING AND ANALYSIS . . . 18 WASTE MANAGEMENT UNITS AND FACILITY DESIGN . . . 19 OPERATION 19 HAZARDOUS WASTE MANAGEMENT UNITS . . 22 Michigan Disposal 22 Hazardous Waste Disposal Cells . . . 24 SOLID WASTE MANAGEMENT UNITS . . . . . . 30 Solid Waste Disposal Cells . . . . 30 GENERAL SITE DESIGN FEATURES . 33 Perimeter Drains 33 Surface Drainage 34 Leachate Removal System 34 OFFSITE ACTIVITIES . . . . 36 HYDROGEOLOGY 39 GROUND-WATER MONITORING DURING INTERIM STATUS 41 REGULATORY REQUIREMENTS 41 GROUND-WATER SAMPLING AND ANALYSIS PLAN 41 MONITORING WELLS 44 Well Locations Well Construction 48 SAMPLE COLLECTION AND HANDLING PROCEDURES . 51 SAMPLE ANALYSIS AND DATA QUALITY EVALUATION 58 Initial Ground-Water Monitoring Well System 59 New Ground-Water Monitoring Well System . . 63 GROUND-WATER ASSESSMENT MONITORING AND OUTLINE 65 I ------- CONTENTS (cont.) GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT . - . 67 MONITORING DATA ANALYSIS FOR INDICATIONS OF WASTE RELEASE . . . 68 REFERENCES APPENDIX A ANALYTICAL TECHNIQUES AND RESULTS FOR TASK FORCE SAMPLES, WAYNE DISPOSAL, INC. . BELLEVILLE, MICHIGAN FIGURES 1 SIte Vicinity. Wayne Disposal, Inc., Belleville. Michigan . . . . 3 2 Wayne Disposal, Inc., Belleville, Michigan, September 1985 . . . 5 3 Area Activities Potentially Impacting Ground-Water Quality at Wayne Disposal, Inc 37 4 Ground-water Monitoring Well and Leachate Collection Sump Locations, Wayne Disposal, Inc., Belleville, Michigan, September 1985 5 Schematic Diagram of Typical Monitoring Welt Assembly 50 TABLES 1 Operation and Bottom Liner Design Information 25 2 Disposal Cell Leachate, Gas Collection, Cap and Leak Detection Systems Information 26 3 MonItoring Wells at Wayne Disposal, Inc., August 1985 42 4 Developmental Sta9es of the Ground-Water Monitoring System . . . 44 5 MonItoring Well Depth Zones and Relative Yields 47 6 Monitoring Well Construction Data 49 7 Sample Collection Data 52 8 Leachate Sample Collection Data 53 9 Order of Sample Collection, Bottle Type and Preservative List 56 10 LocatIons of Field Blanks 58 11. Organic Compounds Detected in Task Force Ground-Water Samples August-September 1985 69 12 Total Zinc Concentrations Detected in Task Force Ground-Water Samples 70 11 ------- EXECUTIVE SUMMARY ------- INTRODUCTION Concerns have recently been raised whether the commercial hazardous waste treatment, storage and disposal facilities (TSDFs) are in compliance with the ground-water monitoring requirements promulgated under the Resource Conservation and Recovery Act (RCRA)*. Specifically, the concerns focus on the ability of ground-water monitoring systems to detect contaminant releases from waste management units at TSDFs. In response to these concerns, the Administrator of the Environmental Protection Agency (EPA) established a Hazardous Waste Ground-Water Task Force (Task Force) to evaluate the level of compliance at TSDFs and address the cause(s) of noncompliance. The Task Force comprises personnel from EPA Headquarters, including the Offices of Solid Waste and Emergency Response (OSWER), National Enforcement Investiga- tions Center, EPA Regional Offices and State regulatory agency personnel. To determine the status of facility compliance, the Task Force is conduct- ing in—depth facility investigations, including onsite inspections, of TSDFs. The objectives of these investigations are to: • Determine compliance with interim status ground-water monitoring requirements of 40 CFR Part 265 as promulgated under RCRA or the State equivalent (where the State has received RCRA authorization) • Evaluate the ground-water monitoring program described in the facilities’ RCRA Part B permit applications for compliance with 40 CFR Part 270. 14(c) • Determine if the ground water at the facility contains hazardous waste constituents * Regulations promulgated under RCRA address hazardous waste management facilities’ operations, including ground-water monitoring, to ensure that hazardous waste constituents are not released to the environment. ------- 2 Provide information to assist the Agency in determining if the TSDF meets EPA ground-water monitoring requirements for waste management facilities receiving waste from response actions con- ducted under the Comprehensive Environmental Response, Compensa- tion and Liability Act (CERCLA, Public Law 91_510)* To address these objectives, each Task Force investigation will determine if: • The facility has developed and is following an adequate ground- water sampling and analysis plan • Designated RCRA and/or State-required monitoring wells are properly located and constructed • Required analyses have been conducted on samples from the designated RCRA monitoring wells • The ground-water quality assessment program outline (or plan, as appropriate) is adequate The third TSDF investigated by the Task Force was the Wayne Disposal, Inc. site (Wayne) located in Belleville, Michigan about 15 miles west of Detroit [ Figure 1]. Michigan Disposal, Inc. (MDI) provides a liquid waste solidification service to Wayne and operates within the Wayne facility area. For this reason, this operation was also inspected. The onsite inspection was conducted from August 27 through September 6, 1985 and was coordinated by personnel from the EPA National Enforcement Investigations Center (NEIC). In general, the investigation involved review of State, Federal and facil- ity records; facility inspection; laboratory evaluation; and ground-water, surface water runoff and landfill leachate sampling and analysis. * EPA policy, stated in the May 6, 1985 memorandum from Jack McGraw on “Procedures for Planning and Implementing Offsite Response”, requires that TSDFs receiving CERCLA wastes be in compliance with applicable RCRA ground-water monitoring requirements. ------- FIGURE 1 Scab, of M ii i. 0 I 3 3 4 • 10 Site Vicinity Wayn. Disposal inc. B.ll .viIlI. MIchigan (A) ------- 4 The site is located in Sections 17 and 18, T.3 S., R.8 E., Van Buren Township in Wayne County, Michigan. The property is owned by Ford Motor Company and is operated independently by Wayne Disposal, Inc. The facility currently accepts RCRA hazardous wastes in bulk or con- tainers for disposal in hazardous waste management cells and nonhazardous industrial and municipal wastes for disposal in solid waste management cells. Prior to being developed as a waste disposal site, the Wayne site was used for agricultural purposes. Landfill operations began at the present site in 1972 when the Wayne Disposal #1 landfill [ Figure 2] was opened. This site, which contains both hazardous and nonhazardous wastes, was closed in 1975. The site officially began operation as a State-approved hazardous waste disposal facility in October 1975 as Wayne Disposal #2 landfill. The Wayne Disposal #2 landfill contains about 375 acres of landfill area divided into eight master cells (MCs) varying in size from 35 to 60 acres [ Figure 2]. Wayne has designated three of these master cells (MC V, VI and VII) as RCRA-regulated hazardous waste disposal units. Two other cells (MC I and IV), closed before the advent of RCRA, received industrial wastes which would now be considered hazardous, and the remaining cells (MC IX, X and XI) are designated for nonhazardous waste disposal. Operating periods for the various disposal cells in the Wayne Disposal #2 landfill are as follows: MC I Fall 1975 - Winter 1978 MC IV Winter 1978 - Winter 1980 MC V Winter 1980 - September 1985 MC VI Unfilled (planned startup 1986) MC VII September 1983 - present MC IX April 1985 - present MC X Unfilled (planned startup 1988) MC XI September 1982 - April 1985 The facility has operated under Federal interim status authorization (EPA ID number MI 0048090633). Wayne submitted a Part A permit application to EPA Region V in November 1980 and a RCRA Part B application on Sept- ember 12, 1983. The Part B application has been under review by both Michigan DNR and EPA Region V with Notices of Deficiency (NOD) issued to Wayne Disposal on November 28, 1983; April 17, 1984; April 15, 1985 and November 14, 1985. ------- WILLOW RUN AIRPORT SCALE o 200 400 600 *00 0 50 100 150 200 TO WILLOW WAYNE DISPOSAL I I A WEST PERIMETER LEGEND RCRA Hazardouu waste ares A 1 3.... Trenches within master cells ------- 6 Wayne is also operated under Michigan Act 64 Hazardous Waste Operating License #321, Michigan Act 641 Sanitary Landfill License #7083 and, prior to 1979, operated under a Michigan Act 87 solid waste disposal license. The Michigan Act 64 license regulates a variety of hazardous waste site management practices including the construction and certification of liners, dike walls, leachate collection systems and final cover; the installation of leak detection systems, gas venting systems and lysimeters; ground water, ambient air, gas, leak detection, lysimeters, surface water and leachate monitoring; the control of maximum leachate levels in leachate collect nn system sumps and allowable waste types and quantities. The Michigan Act 641 license regulates construction activities and general operating procedures of the nonhazardous waste cells. The regula- tions require both surface-water and ground-water monitoring programs. The entire ground-water monitoring system (31 wells) is used for monitoring under Act 641 and Act 64. Fourteen of these wells are designated for RCRA Part 265, Subpart F. The Wayne County Department of Public Works Class 0 Wastewater Dis- charge Permit regulates discharges from the facility into the Wayne County sewerage system (pretreatment). This permit requires that wastewater gen- erated at the site meet specific organic and inorganic concentration limits before discharge into the sewer. In late 1977, Michigan Disposal, Inc. (MDI), an independently owned and operated company, started a liquid solidification operation at the Wayne Disposal site. MDI solidifies both hazardous and nonhazardous liquids and is operated under Michigan Acts 64 and 641, as well as RCRA interim status authorization (MI D000724831). MDI has also submitted a RCRA Part B appli- cation to EPA and MDNR for review. All solidified wastes are placed in the Wayne landfill. Wayne triggered ground-water assessment for the indicator parameter pH in 1983 and responded with appropriate notification of EPA. After a period ------- 7 of assessment monitoring, Wayne determined that there were no hazardous waste constituents present above background levels and assessment was no longer necessary. The indicator evaluation program, as described in 40 CFR 265.93(d)(6), was reinstated in November 1985. ------- 8 SUMMARY OF FINDINGS AND CONCLUSIONS Task Force personnel investigated the interim-status ground-water monitoring program at the Wayne Disposal, Inc. facility in Belleville, Michigan during the period August 27 through September 6, 1985 to meet the objectives discussed previously. The interim status ground-water monitor- ing period began in November 1981, when applicable provisions of the RCRA regulations became effective. Because the State of Michigan was not author- ized, EPA administered and enforced the program in 40 CFR Part 260 through Part 270 between November 1981 and September 1985. The findings and conclu- sions presented below reflect conditions existing at the facility during this period. Historically, Wayne has conducted the required sampling and analyses at the required intervals. Background ground-water quality data may be suspect due to possible influences of differing well construction materials and possible residual contaminants introduced by the pumps. Some of the interim status monitoring data and analytical methods are also unreliable. Wayne has routinely applied the required statistical tests to analytical data and reported the results to EPA. The ground-water monitoring system does not fully comply with the requirements of 40 CFR §270.14(c). Further hydrogeological definition of the interconnection and ground-water flow regimes within the drift and bedrock aquifers is needed to thoroughly assess the current configuration of monitoring wells to assure immediate leakage detection. The quality control for the sampling and analysis needs further refinement. The Task Force analytical results show organic hazardous waste consti- tuents in six wells. However, these constituents are believed to have originated from contaminated pumps rather than from the waste management units. Well construction materials are believed to have contributed to elevated zinc concentrations found in several wells. Based on the existing ground-water monitoring system, there is no indication that the hazardous waste management units are contributing to ground-water contamination. ------- 9 Under current EPA policy, if an offsite TSDF must be used for land disposal of waste from a Superfund cleanup of a CERCLA site, that site must be in compliance with the applicable technical requirements of RCRA. Interim status facilities must have adequate ground-water monitoring data to assess whether the facility poses a threat to ground water. Some parts of the ground-water monitoring program do not fully comply with EPA requirements. The following is a more detailed summary of the inspection findings and conclusions. COMPLIANCE WITH INTERIM STATUS GROUND-WATER MONITORING - 40 CFR 265 SUBPART F §265.91 Ground—Water Monitoring System The hazardous waste management area, as proposed by Wayne Disposal in their Part B application, includes Master Cells V. VI and VII. At the time of the Task Force inspection, MC VI was inactive and proposed for future land disposal of hazardous wastes. Michigan Disposal, Inc. (MDI), a solid- ification plant, was operating in the area designated as MC VI. Monitoring wells OB-18 through OB-31 constitute the RCRA ground-water monitoring system during the interim status period. Downgradient wells OB-2O through OB-25 are located at distances ranging from about 500 feet to as much as 1,300 feet from the southern limit of MC V, which was being closed at the time of the inspection. These wells are at the downgradient bound- ary of MC VI which is anticipated to be receiving wastes during 1986 under interim status. Hence, all of the monitoring wells are at the limits of the waste management area which constitutes the designated point of compliance. Additional wells are needed to more thoroughly monitor the hazardous waste management units. An expansion to the clusters of piezometers is needed to improve the hydrogeological characterization of the site. This characterization should further evaluate the vertical head distribution in both the upper and lower glacial drift zones including the bedrock inter- face. This information will provide finer details to determine what addi- tional locations and depths (screened intervals) should be selected for ------- 10 additional monitoring wells. The existing ground-water monitoring system is considered adequate for interim status as it was installed in compliance with an EPA Region V order, but the additional wells are needed for full compliance with 40 CFR Part 270. 14(c)(2) and Part 264. The number of downgradient RCRA monitoring wells is insufficient based on vertical and horizontal spacing. The number and location of upgradient wells is probably adequate. Vertical hydraulic head distributions (dif- fering head with depth) need further definition in order to determine if the necessary depths are being thoroughly monitored. Piezometer clusters are needed to assist additional hydrogeologic rharacterization using pump- ing tests and water level distributions. There is inadequate spacing of monitoring wells on the east sides of MCs VI and VII, considering that ground-water flow direction is south-southeast. Some monitoring wells were constructed with galvanized steel casings and stainless steel screens while others have PVC casings and screens. There is concern that differences in well construction methods and mate- rials may influence the quality of ground-water samples. Poor wellhead maintenance threatens the integrity of three RCRA monitoring wells, OB-19, 23 and 25. Problems include cracked concrete well pads and erosion around the pads. §265.92 Sampling and Analysis Wayne has developed a Sampling and Analysis Plan (SAP), as required, and keeps the SAP onsite. The SAP is generally complete, but needs revision to bring it up to date. Wayne has sampled the necessary parameters at the required intervals for wells OB-1 through OB-17. These wells composed the originally desig- nated RCRA monitoring system but were phased out of the RCRA system when wells OB-18 through 08-31 were installed. During this transition period, wells 08-1 through OB-17 were used for detection monitoring while OB-18 ------- 11 through OB—31 were being monitored to establish background. The required replicate samples have also been taken and analyzed. Although the required reporting is complete, much of the reported data are unreliable, biased or inadequate due to improper sample handling, analytical procedures, field determinations of pH and specific conductance, and reporting methods. The quarterly sampling required to produce a year’s worth of back- ground ground-water quality data for OB-1 through OB-17 yielded unreliable results for all indicator parameters: pH, specific conductance, total organic carbon (TOC) and total organic halogen (lOX). Subsequent semi- annual sampling data for these parameters showed simil ” unreliability. The sampling data acquired so far from the revised RCRA wells (OB-18 through OB-31) appears to be more reliable than the original program. Comparison of the SAP with the methods actually used indicates that these are differences which constitute a violation of 40 CFR 265.92, due to lack of proper SAP revisions. The pH and conductance data are suspect or biased because of improper sampling or calibration procedures. Although field pH and conductivity were taken, Wayne reported laboratory pH and conductivity measurements. These reported pH measurements, in many cases, were made the day after sampling rather than within the required 2 hours. The presently recommended holding time is 15 minutes. In addition, buffer solutions were not changed with adequate frequency. Conductivity data produced at the contractor laboratory prior to 1984 were not reliable because of improper meter calibration (lack of chemical calibration standards used to make cell constant corrections) and lack of proper temperature correction. In 1984 the use of proper calibration standards was implemented; however, proper temperature compensation was still not performed. Subsequent to 1984 a new contract or laboratory was utilized that again failed to use chemical calibration standards or make proper temperature compensations. The TOC and lOX data are unreliable because of improper or variable analytical methods. The analytical procedure used by the Company’s contract ------- 12 laboratories for TOC yields results representing only nonpurgeable organic carbon, which results in the loss of purgeable (volatile) organic carbon. lox results were unacceptable in terms of variability between quadruplicate sample analyses. Prior to mid-1983, metals samples were handled so that analytical results represented neither total nor dissolved metals, but some extract- able concentration. After mid-1983, dissolved metals were determined, thereby diminishing the ability to compare these results with background data. Prior to mid-1983, Wayne reported extractable concentrations of lead and mercury which exceeded drinking water standards. After mid-1983, Wayne changed the metals analysis method. The reported dissolved concentrations did not exceed drinking water standards, suggesting that background data for these parameters inadequately characterized the ground water due to the presence of turbidity in samples from some wells. Collection of 1 year of background data from the new RCRA wells, OB-18 through OB-31, was completed in September 1985. Quarterly analytical reports were complete but contained suspect data. The data problems are similar to those noted for the old wells (i.e., the pH, TOC and lOX are unreliable). Specific conductance measurements are suspect and probably low because of the inadequate calibration and computation procedures followed. The metals samples from the new wells were filtered and acidified; thus, dissolved metals were determined. Data from analyses of samples may be biased low. The effects of filtering on ground-water samples collected at the Wayne Disposal facility need to be further evaluated and documented through the permit process. Statistical methods conducted on the original designate RCRA wells 08-1 through OB-17 to compare analytical data from ground-water samples were satisfactory, but the analytical results are of questionable value. Back- ground statistics are still in progress for the RCRA wells OB-18 through OB-31. ------- 13 §265.93 Preparation, Evaluation and Response Wayne Disposal has developed and maintains onsite, an outline of a ground-water quality assessment program, as required. They have developed a ground-water quality assessment program plan based on this outline. In 1983 and 1984, Wayne notified EPA within the required time frame of statistically significant decreases in pH in well OB-13. Wayne then devel- oped an assessment plan, which EPA Region V approved, to evaluate the causes of pH changes. Wayne attributed the causes for the changes to unreliable background water quality data affecting their statistical comparison. During the assessment for pH, the ground-water analyses indicated ele- vated barium concentrations were present. The Company notified EPA and began investigating the source of the barium. After a period of monitoring and comparison of laboratory data, the Company reported to EPA that the barium levels were natural background concentrations and reinstated the indicator evaluation program in November 1985. GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT The initial ground-water monitoring system was considered by EPA to be inadequate because of improper monitoring well placement at this point of compliance. Subsequently, 14 new wells were installed at the limits of the waste management area. The inadequate hydrogeological site characterization precludes an assessment on whether the designated RCRA ground-water mon- itoring wells are screened in the proper zones of the glacial drift aquifer to provide the required monitoring capability. Well spacing, differences in well construction materials, and inadequate quality control procedures for sampling and analysis render the program inadequate and not in full compliance with 40 CFR §270.14(c). The current array of monitoring wells will need to be improved for the final permit. In addition, the lysimeters along the north side of MC V and MC VII should be included under the Part B permit to provide for leak detection and monitoring of the vadose zone. ------- 14 TASK FORCE SAMPLING AND MONITORING DATA ANALYSIS During the inspection, Task Force personnel collected samples from 23 ground-water monitoring wells, one water supply well, two surface ponds and two drains to determine if the ground water contains hazardous waste con- stituents or other indicators of contamination. Five leachate samples were also collected. Samples were drawn from the wells by Wayne personnel. Monitoring data from the Task Force samples were evaluated, together with previous Wayne Disposal ground-water monitoring data. The September 1985 Task Force data indicate that at least six wells contain organic hazardous waste constituents. Wells OB—18, 20, 26 and 2 show elevated levels of 1,1,1-trichloroethane. Wells OB-20, 26, 29 and 30 show elevated levels of tetrachioroethene. Toluene was detected in OB-8 and OB-26. The presence of volatile organic compounds in the new wells is attrib- uted to contamination introduced from the dedicated sampling apparatus rather than an indication of ground-water contamination from waste disposal operations. The pump supplier notified Wayne that some pumps had been contaminated by a lubricating oil used during manufacture. The contaminated pumps have been replaced by new pumps certified to be free of contaminants. Wayne has indicated that subsequent analyses show steadily decreasing con- centrations of the organic compounds. The presence of toluene in OB-8 and 08-26 needs to be confirmed. Confirmation sampling should include extensive use of blank samples to determine if the source is external. Elevated zinc levels in some wells probably originate from the galva- nized steel casing/stainless steel screen well construction assembly. Zinc is not likely to move freely through the thick, low—permeability clays sep- arating the waste handling facilities and the monitored aquifer zones. The wells exhibiting high zinc levels were observed across the site and do not represent any pattern indicating contaminant plume migration. ------- 15 COMPLIANCE WITH SUPERFUND OFFSITE POLICY Under current EPA policy, if an offsite TSDF must be used for land disposal of waste from a Superfund cleanup of a CERCLA site, that site must be in compliance with the applicable technical requirements of RCRA. Interim status facilities must have adequate ground-water monitoring data to assess whether the facility poses a threat to ground water. The Task Force found the ground-water monitoring system at Wayne Disposal to be adequate with respect to well numbers and locations for interim status mon- itoring. However, the facility is not fully in compliance with sampling and analysis requirements. Samples were analyzed and reported at required intervals, but some of the data are questionable. The evidence obtained and evaluated during the investigation of the Wayne Disposal facility does not indicate that any contaminant plume is originating from the hazardous waste units and migrating across the site. Most contaminants found in ground-water samples are concluded to have orig- inated from contaminated pump assemblies which have since been replaced. The facility presently is operating in the detection monitoring phase. ------- TECHNICAL REPORT ------- 16 INVESTIGATIVE METHODS The Task Force evaluation of the Wayne Disposal site, including Michigan Disposal, Inc. , consisted of: • Review and evaluation of records and documents from EPA Region V; MDNR;’Wayne Disposal, Inc.; and Michigan Disposal, Inc. • An onsite inspection of the facility conducted August 27 through September 6, 1985 • Onsite and offsite analytical laboratory evaluations • Sampling and subsequent analysis and data evaluation for selected site ground—water points and leachate monitoring points and surface water sampling points RECORDS/DOCUMENTS REVIEW AND EVALUATION Records and documents from EPA Region V and the MDNR offices, compiled by an EPA contractor, were reviewed prior to the onsite inspection. Onsite facility records were reviewed to verify information currently in Govern- ment files and supplement Government information, where necessary. Selected documents requiring in-depth evaluation were copied by the Task Force during the inspection. Records were reviewed to evaluate facility operations, identify location and construction details of waste management units and evaluate ground-water monitoring activities. Specific documents and records reviewed and evaluated included the ground-water sampling and analysis plan (SAP), outline of the facility ground—water quality assessment program, analytical results from past ground-water sampling, monitoring well construction data and logs, site geologic reports, site operations plans, facility permits, waste management unit design and operation reports, selected personnel position descriptions and qualifications (those related to the required ground-water monitoring ------- 17 program) and operating records showing the general types and quantities of wastes disposed of at the facility and their locations. FACILITY INSPECTION The facility inspection included identification of waste management units (past and present); identification and assessment of waste management operations and pollution control practices, surface drainage routes and local land uses; and verification of location of ground-water and leachate monitoring systems. Wayne representatives were interviewed to identify records and docu- ments of interest, discuss the contents of the documents and explain (1) facility operations and design (past and present), (2) site hydrogeology, (3) ground-water monitoring system rationale, (4) the SAP and (5) labora- tory procedures for obtaining data on ground-water quality. Because ground- water samples were analyzed by offsite laboratories, personnel from these facilities were also interviewed regarding sample handling and analysis and document control. LABORATORY EVALUATION The onsite and offsite laboratory facilities handling ground-water samples were evaluated regarding their respective responsibilities under the Wayne Disposal SAP. Analytical equipment and methods, quality assur- ance procedures and documentation were examined for adequacy. Laboratory records were inspected for completeness, accuracy and compliance with State and Federal requirements. The ability of each laboratory to produce quality data for the required analyses was evaluated. Detailed discussion of this evaluation is presented under “Sample Analysis and Data Quality Evaluation” later in this report. ------- 18 GROUND-WATER, SURFACE WATER AND LEACHATE SAMPLING AND ANALYSIS During the onsite inspection, the Task Force, assisted by Wayne personnel, collected ground-water samples from the monitoring wells and leachate samples from leachate collection sumps in the landfills, as well as samples from two drains, two ponds and an onsite water supply well. Samples were taken by an EPA contractor and sent to EPA contract labora- tories for analysis. Split samples were collected by the Task Force for Wayne Disposal, Inc. The EPA NEIC laboratory in Denver, Colorado, received and analyzed additional split samples from four selected points for compara- tive quality assurance purposes. Data from sample analyses were reviewed to further evaluate Wayne’s ground-water monitoring program and identify possible ground-water contaminants. Analytical results of the samples collected by the Task Force are presented in Appendix A of this report. ------- 19 WASTE MANAGEMENT UNITS AND FACILITY DESIGN The Wayne site has two active RCRA-regulated hazardous waste management units (MC VII and the MDI waste pile), two RCRA-regulated units in the proc- ess of closure (MC V, MDI lagoons) and a RCRA-regulated waste disposal unit which is being developed (MC VI) [ Figure 2]. The site also has several pre-RCRA facilities which contain hazardous wastes (MC I, MC IV and WD 1) and nonhazardous waste disposal units which could affect the local ground-water quality. Several unique general site design features (drainage, automatic leachate recovery system and perimeter drains) could potentially affect ground-water quality and subsurface fluid flow. The design and opera- tion of these various components of the Wayne facility, the overall opera- tional procedures at this site, and land uses are discussed in the following sections. This discussion is presented here to provide a framework for assessing waste disposal unit integrity, explain the types and placement of wastes disposed of at Wayne and serve as a reference to assist in evaluating the potential for ground-water contamination in the event that leakage occurs and threatens to degrade ground-water quality. OPERATION Wayne handles approximately 500,000 cubic yards of hazardous wastes and 1,500,000 cubic yards of nonhazardous wastes annually. The types of hazardous wastes entering the facility have remained the same since the startup of MC I in 1975, but the volumes of hazardous wastes have increased greatly, and the commingling of hazardous wastes with nonhazardous wastes is no longer practiced. Under its State licenses, Wayne has only been allowed to dispose of wastes with no releasable liquids. About 95% of these wastes fall into the following waste categories: corrosive wastes; heavy-metal-bearing wastes; halogenated and non-halogenated solvent-bearing wastes*; non-cyanide-bearing electroplating sludge; pesticide—bearing wastes; petroleum wastes; iron, steel and coking wastes; ink formulation wastes and * Wa jne can accept wastes containing a maximum of 10% halogenated and 10% non-halogenated solvents. ------- 20 creosote—bearing wastes. Other wastes landfilled onsite include cyanide-bearing wastes, organic chemical production wastes and a variety of toxic commercial chemical products and intermediates. Reactive, explosive, radioactive, ignitable and regulated poly-chlorinated biphenyl (PCB) wastes have never been permitted for disposal at this facility. All liquid wastes are received by MDI for solidification before disposal in the master cells. Bulk shipments of wastes entering the facility are visually checked to ensure that they are non—liquid and that they match the identity of the material designated on the manifest and described and char- acterized by the generator in the pre-acceptance form. Wayne officials indicated that, if multiple shipments from a single generator are received, every load may not be visually inspected but may be sent directly to the disposal cell. When necessary, samples are collected and crude flashpoint, pH, reactivity or paint filter tests (check for free liquids) are run. If free liquids are encountered, MDI must process the wastes and cumulative bucket compatability testing is done. This is done by adding samples from succes- sive loads to be processed by MDI into a bucket to observe if any type of reaction occurs. All testing is done to assess whether the wastes can be physically handled by Wayne’s or MDI’s handling and disposal equipment and methods. Of the drummed wastes entering Wayne Disposal, 10% are visually inspected. If necessary, the same types of testing performed on the bulk shipments are also run on the drummed wastes. Liquids,when encountered, are pumped from the drums using a vacuum truck, and must be processed by MDI. No compatability testing is performed on drummed liquids pumped into vacuum trucks. Final disposal in Wayne’s landfill is accomplished by trucking the bulk solidified wastes (directly from the generator or from MDI) or drummed solid wastes and dumping them at the top end of the working face in the currently active hazardous waste master cell. The wastes are spread down the working face (22° working angle) in lifts about 2 feet in thickness. The surface of the lifts is spread daily with 6 inches of cover material. ------- 21 Characterization of wastes prior to acceptance and tracking of wastes after receipt are important in determining the constituents that could potentially be released from waste handling units. Wayne was found to have deficiencies in both waste characterization and tracking of waste within the site. Several discrepancies in the 1985 annual report were observed. Mani- fests were checked from six randomly selected companies against this annual report. The reported volumes from five of the companies were found to be inaccurate by between 2 and 33%. Approximately 40 manifests from six sep- arate companies were spot checked to see if the daily operating logs were accurate in reporting types and volumes of materials entering the landfill. No discrepancies were found. Wastes accepted from several sources including Chem-Met, Waste Conver- sion, Alcherntron, Erieway Pollution Control, Frontier Chemical, Haz-0-Waste, S&W Wastes and Delaware Containers were found to be manifested and reported in the annual report as a single type of waste. Actually, these shipments were several wastes commingled and manifested under the hazardous waste code number for the largest single waste within the shipment. Because of this practice, the annual report over estimates the volumes of some types of waste and under estimates other types. The final disposal location of wastes within a specific trench was difficult to ascertain. The location of the working face at the top of the trench dike is recorded daily. This location, the known working angle (22°), and the daily incoming waste logs served to pinpoint the placement of spe- cific loads. However, wastes are heaped well over the top of the trench dikes in the latter stages of cell filling and no method for recording the history of this disposal was practiced. At the time of the inspection, the facility was changing to a surveying method which would define both vertical and areal placement of wastes in the cells. ------- 22 Regardless of the problems associated with waste characterization and tracking, the information is sufficient to identify the hazardous waste constituents of the various wastes and the ultimate trench or cell where specific loads and types of wastes are placed. HAZARDOUS WASTE MANAGEMENT UNITS Michigan Disposal Past and present activities at the MDI facility, located on Wayne’s undeveloped Master Cell VI, may affect the Wayne ground-water monitoring program. At the MDI facility, hazardous and nonhazardous wastes are solidified using spent lime, cement dust and/or electric arc furnace dust (K061 waste) before transport and placement in the Wayne Disposal landfill. At the time of the inspection, only hazardous wastes were being handled by MDI. Pre-acceptance screening, waste analysis (flammability, corrosivity, paint filter test) and compatability testing are conducted by Wayne prior to transfer to MDI. Both firms are prohibited by State Act 64 permits from handling wastes which have greater than or equal to 10% chlorinated or 20% non-chlorinated solvent concentrations. Bulk wastes (sludges and liquids) are placed in sludge boxes and trans- ferred to a pug mill mixer where the wastes are mixed with the solidifying agents. Drummed liquid hazardous wastes are stored outside on a concrete pad at the north end of the MDI facility. The State allows MDI to store no more than 1,500 drums of waste and drums can be held for only 8 hours. The drummed wastes are emptied by a forklift or vacuum truck into a sludge box and then transferred to the pug mill mixer where the solidifying agents are added. All solidified wastes are stored in a waste pile inside of the MDI processing building until they are trucked to the Wayne hazardous waste landfill for disposal. Of particular concern to ground—water monitoring at the Wayne Disposal site are the three lagoons which MDI has operated. Basins A (2.5-million -gallon capacity) and C (3.4-million-gallon capacity) stopped receiving hazardous wastes in July 1979 but stored wastes until August 1981. At that ------- 23 time, all waste materials were removed and several feet of clay soil were removed (no closure plan was submitted) and approximately 3,800 cubic yards of excavated soil were placed in the Wayne landfill. Limited soils testing for residual contamination was done after excavating Basin C, but no test- ing was done after completion of the Basin A excavation. The excavated basins were filled with clean soils, and a stormwater lagoon for storage of surface runoff was installed. The stormwater lagoon covered the southern half of former Basin A and was located about 200 feet from the southwest corner of the MDI south sludge l-—’. The lagoon was 150’ x 80’ with 180,000—gallon capacity (assuming about 2 feet of liquid) designed to contain a 24-hour stormwater runoff event. It had a compacted clay liner (no specific design specifications) with trench wall slopes of 2 to 1 (horizontal to vertical). The lagoon was fed by four catch basins located inside the bermed and paved MDI working area. The entire bermed area, except the drum storage area, the unloading areas and areas inside the processing facility, is sloped toward one of these catch basins. During the inspection, solidified hazardous wastes could be seen on the pavement which slopes toward the catch basins. These materials were present due to carryout on transport vehicle tires and could be washed into the catch basins and carried into the stormwater lagoon during storm— water runoff events. An oily sheen could also be seen on the surface of the stormwater lagoon indicating that waste materials may have entered this lagoon. A closure plan was submitted by MDI on July 11, 1984 for formal closure of Basins A and C to be instituted after the stormwater lagoon was emptied and taken out of service. Company personnel stated that the stormwater lagoon was closed on November 7, 1985; the lagoon subsequently was emptied and the liquids were either treated by the MDI process or were directly discharged to the sewer without treatment. Soils sampling was conducted as specified in the closure plan for Basins A and C to verify that the under- lying soil in Basin C was not contaminated and to determine the depth to which re—excavation of Basin A should be extended. Excavation of contami- nated sediments and soils, and subsequent placement of these materials in the Wayne landfill, was done. A 50,000-gallon, double-lined underground ------- 24 tank was then placed in the area of the lagoon to store stormwater runoff generated from within the bermed area at the MDI site. Hazardous Waste Disposal Cells Three hazardous waste disposal cells (MC V, MC VI and MC VII) have been or are planned to be used for RCRA-regulated hazardous waste disposal. The various operating periods, size, design features, waste types, etc. for the three RCRA cells are shown in Tables 1 and 2. Of particular importance to ground-water monitoring at the site are the cell bottom liner, leachate collection cystem and the leak detection system designs. These items are discussed below. Master Cell V (MC V ) The certified clay* base (maximum permeability 5 x 10 cm/sec) of trenches V-A, V-C and V-D provide a minumum of 10 feet of isolation between the wastes and the underlying glacial drift aquifer. Trenches V-B and V-E have certified clay bases 15 feet thick isolating the wastes from the under- lying drift aquifer. The bottom elevation of the lowest trench (trench V-A) is approximately the same as the piezometric surface elevation which is about 653 feet msl and indicates semi confined aquifer conditions. Changes in leachate levels or the piezometric surface elevation could create a hydraulic gradient either into or out of the cell. The thicknesses of the liners were confirmed with soil borings and a resistivity study was performed in trench V—B to isolate anomalies in the clay zone (confirmation to 5 feet in the northern half and 15 feet in the southern half). Repairs were needed for the trench V-B certified clay base only. In this case, borrowed clay was placed on top of the natural clay in 12-inch lifts and compacted (93% modified Proctor density, minimum permeability of 5 x 10 cm/sec at 1 ton/ft 2 load increment) to achieve the specified clay thickness (15 feet). * The claç,r is referred to as a silty clay by Wayr e’s consultants. ------- 14C-IV Non-RCRA regular unit RCRA regular unit NC-XI Non-RCRA 36 regular unit MC- 1X 3 Non-RCRA regular unit NC-VIZ 3 RCRA regular unit MC-X 3 Non-RCRA regular unit Table 1 OPERATION AND BOTTOM LINER DESIGN INFORMATION WAYNE DISPOSAL, INC. Belleville, Michigan September 1985 Winter 1978- 5 Winter 1980 (east/west) - Winter 1980- Sept 198 - Sept. 1982- 5 Apr 1985 (north/south) 55 2.9 x 106 Apr. 1985 4 to present (north/south) 30 1.3 x 106 Sept. 1985 3 to present (north/south) 36 2.65 x 106 Startup 1987 (predicted life, 3.9 years) 38 2.1 x 10° Startup 1988 5 (east/west) Comi ngl ed hazardous! nonhazardous wastes (2 0%/8 0%) Trench V-B hazardous wastes only; other trenches cornngled hazardous! nonhazardous wastes Hazardous wastes 15 Nonhazardous wastes 10 Present in 660 trench VU-C only ‘ Nazi periDe bi2ity - 1 x 1O - cm/sec Trenches V-A, C and 1) - 10 feet; trenches V-B and 6 - 15 feet Proposed design information The aouthern 600 feet of trench X1-B has only 5 feet of clay isolating wastes from the imderlying aquifer; the remaining Mc XI bottom liners have 10 feet of clay. WD-I Non- RCRA regular unit 54 NC-I Minimum Cell Double Lowest Cell Piezoiuetric Disposal Current Number of Bottom Clay’ Synthetic Bottom Surface Cell RCRA Area Volume Operating Trenches and Waste Thickness Bottom Elevation Elevation Designation Status (acres) (cu. yds.) Period Orientation Type (feet) Liner (feet msl) (feet msl) Non- RCRA regular unit Early 1970s- 1975 - Fall 1975- Winter 1978 70 35 40 6 (5 east/west & 1 north/south) 8 (7 east/west & 1 north/south) Comi ngled hazardous! nonhaiardous wastes MC- V Comi ngled hazardous! nonhazardous wastes (15X/85X) 5 (north/south) 10_ 152 54 10 MC-V 1 3 RCRA regular unit Nonhazardous wastes Nonhazardous wastes None None None 10 None 655 652 10 None 669 655 653 653 656 652 649 652 654 15 Present 645 652 3 4 2 Hazardous wastes (north/south) N) U i ------- 26 Table 2 DISPOSAL CELL LEACHATE AND GAS COLLECTION, CAP AND LEAK DETECTION SYSTEMS INFORMATION WAYNE DISPOSAL, INC Belleville, Michigan Septeniber 1985 Disposal Cell Designation Cap Thickness Clay 1 Layer. (feet) Synthetic Cap Liner Gas Collection System Leak Detection System Leachate Collection System WD-1 - None None None None NC-i 3_52 None None None None NC-Tv 3.52 None Present None None NC-V 45 Present Present 2 lysimeters in trench V-B only Present MC-XI 3_52 None 4 Proposed None Present NC-TX 3 3.52 None 4 Proposed None Present MC-V 1 1 3 5 Present None Lysimeters in all trenches (8 total)leak detection drainage net for Trench VII—C Present MC-V 1 3 5 Present None Lysimeters and leak detection drainage nets for all trenches Present MC-X 3 3_52 None 4 Proposed None Present Maxz permeability - 1 x iO- cm/sec 2 Michigan regulations require a min im of 2 feet of clay. Proposed design information Two separate clay layers (1 and 3 feet thick) & Synthetic liner installation cost/benefit analysis to be conducted. ------- 27 Each trench has a leachate collection system and leachate collection sump except trenches V-A and V-0 which are served by a common sump located in trench V-A. The leachate collection systems consist of a 1-foot sand layer above the clay bottom which slopes northward at a minimum slope of 1%. At the northern end of each trench, an 8-inch perforated truss pipe runs east-west to the appropriate 60-inch diameter concrete sump. Two lysimeters serve MC trench V-B as a leak detection system. These lysimeters are located at the northern end of the trench and were installed after closure of the trench using diagonal drilling techniques. The lysim- eters were manufactured by Timco Manuferturing and, because of the depth of installation, required transfer vessels at mid-depth. The lysimeters, transfer vessels and tubing are made entirely of Teflon® and the 2-inch casing attached to the transfer vessel is PVC. The sand pack around the lysimeter is a silica flour passing a No. 200 sieve. The whole system, down to within 4 feet of the lysimeter assembly, is encased in a 6-inch steel casing. Bentonite pellets were used to seal the annular space directly above the silica flour. Master Cell VII (MC VII ) The certified clay bases for trenches Vu—A and Vu-B are very similar to the certified clay base in MC V. Fifteen feet of clay with a maximum permeability of 5 x 10 cm/sec separates the wastes from the underlying drift aquifer. The bottom elevation of the lower trench (trench C) is approximately 6 feet above the piezometric surface elevation (654 feet msl) creating a positive hydraulic gradient out of the disposal cell into adja- cent clay. Trench Vu-C has additional synthetic liners on top of the natural or recompacted certified clay base (93% modified Proctor density specification). The synthetic liners include two 60-mil high-density poly- ethylene (HDPE) sandwiching a polyethylene drainage net (Grundnet #3 MDPE) which is used to provide drainage as part of a leak detection system. ® Teflon is a registered trademark and appears hereafter without ®. ------- 28 To aid in leachate collection and protect the synthetic liner, 1 foot of sand was placed over the top 60 mu HOPE liner. To keep the sand in place on the steep trench sidewalls, 57,000 automobile tires were attached together and placed on the sidewalls. Exploration borings and resistivity testing were used to verify the clay liner thickness and identify anomalies in the trench liners. About 70 to 120 borings per trench were used to con- firm the thickness of this naturally occurring clay. The resistivity did show several anomalies in the clay zone which were either excavated and replaced with borrowed clay or the certified clay base was built up around the anomalies to maintain the clay thickness and permeability specifications. All three trenches needed extensive clay build-up which decreased the poten- tial capacity of the trenches for waste disposal. An anomaly 250 feet wide in trench Vu-B, which had to be built up, created the need for installation of an additional leachate collection sump. Smaller anomalies in trenches Vu-A and Vu-C caused leachate collection pipe layout or design changes. The trench Vu-A leachate collection system consists of 1 foot of sand bedded on the cerified clay base which has a i.% northward slope. Six lateral 4—inch ADS perforated collection pipes, spaced 200 feet apart, run westward at a 2% slope to a 4-inch ADS perforated main. This main runs northward along the western edge at a 1% slope to a 60-inch diameter concrete sump located at the northwest corner of the trench. An 8-inch perforated pipe also runs westward (2% slope) along the lowest point of trench VU-A along the northern boundary directly into the collection sump. All collection pipes are equipped with filter fabric socks. Trench Vu-B is equipped with a leachate collection system very similar to trench Vu—A, except the 11 lateral collection pipes are spaced 100 feet apart and a minimum of 1/2% slope was used in the 4-inch main collection pipe. Trench Vu-C, because of the double synthetic liners and leak detection drainage net, has a leachate collection system different from trenches Vu-A and Vu—B. The 1—foot sand collection layer is covered with a filter fabric. The lateral collection pipes are spaced 100 feet apart and are extra high molecular weight (EHMW) high—density polyethylene (HOPE) perforated pipes. These ------- 29 lateral pipes run eastward at the 2% slope into a 4-inch main pipe (same material as laterals) which runs north along the eastern boundary of the trench. The main collection pipe ties into a leachate collection sump located along the north-central boundary of the trench. This 60-inch diameter sump is constructed of 1.6-inch-thick HOPE. Any liquids entering the sandwiched polyethylene drainage net (leak detection zone) would feed into a collection area at the northern end of trench Vu-C. This collec- tion area is an 8-inch perforated HOPE pipe encased in a 10-inch deep by 20-inch wide peastone filled trench sloping to the west. The upper primary 60-mu polyliner is underneath the peastone collection zone. An 8-inch access pipe will be placed from the trench surface to the ‘ ‘west end of the collection zone in the northwest corner of the trench. Eight lysimeters also provide leak detection for MC VII and are constructed identically to the MC V lysimeters. Trenches Vu-A and Vu-B have two lysimeters each, bottomed about 10 to 15 feet below the trench bottoms. Trench Vu-C has four lysimeters bottomed about 20 feet below the trench bottom. The lysimeters for trenches Vu-A and Vu—B were installed after construction of the trenches with diagonal drilling techniques while the trench Vu-C lysinierers were installed prior to placement of the syn- thetic liners. Master Cell VI (MC VI ) The design for the liners the two trenches in MC VI is similar to MC trench Vu-C except for a few minor modifications. These modifications involve direction of the cell bottom liner slope. The bottoms of both trenches are designed to slope toward the southern ends where the leachate sumps will be located: leak detection sumps and lysimeters will also be located at the southern end of the trenches. Trench VIB, which will be the largest hazardous waste disposal trench on the Wayne site, will have the lateral collection pipes running both from the east and west sides of the trench toward the main collection pipe, which runs along the north-south ------- 30 axis. All other trenches on the site have laterals running either east or west to a main collection pipe located along the east or west boundary of the trench. The bottom liner elevation of the lowest trench (trench VI-B) will be approximately 7 feet below the piezometric surface elevation (652 feet msl), creating a positive hydraulic gradient into the disposal cell when leachate levels are kept below the required 6-inch maximum. All other liner, cover, leachate collection, trench dike (internal and perimeter), lysimeter, etc. specifications are to remain similar to those described for MC VII, trench Vu-C. With the upcoming renewal of the State Act 64 permit and the RCRA Part B, MC-VI may have design plan revisions prior to approval to construct. SOLID WASTE MANAGEMENT UNITS Solid Waste Disposal Cells There are six nonhazardous waste disposal cells located at the Wayne Disposal site which could affect ground-water quality in the area. Three of these cells, WD-1, MC I and MC IV, received hazardous wastes prior to the advent of RCRA. Three of the cells received or will receive only non- hazardous wastes including MC XI, MC IX and MC X. The various operating periods, sizes, design features, waste types, etc. for the non-RCRA— regulated sites are shown in Table 1. Of particular importance to ground- wate r monitoring at the site is the cell liner and leachate collection system designs for the various cells. These items are discussed below. Wayne Disposal Number I (WD I ) This landfill has a minimum of 32 feet of natural clay beneath the trench excavations. The lowest cell bottom elevation is approximately 22 feet above the local piezometric surface elevation (653 feet msl), creating a positive hydraulic gradient out of the disposal cell into adjacent clay. No specific soils testing was done to establish the permeability of the soils beneath the trenches or to locate anomalies in the clay soil zone. Soil borings were done, however, to establish the extent of the clay soil zone. ------- 31 Master Cell I (MC I ) The bottom consists of at least 10 feet of natural clay above the underlying drift aquifer with the thickness confirmed by a series of borings. The various trenches were excavated about 45 feet below the original grade (700 feet msl). The bottom elevation of the lowest portion of the cell is approximately 3 feet above the local piezometric surface elevation (652 feet msl), creating a positive hydraulic gradient out of the disposal cell into adjacent clay. There is no leachate collection system. Master Cell IV (MC IV ) The MC IV bottom is designed similarly to MC I, except that an increased number of soil borings were used to confirm clay thickness (minimum 10 feet). The lowest point in the cell bottom is about 14 feet above the piezometric surface elevation (655 feet msl), creating a positive hydraulic gradient out of the disposal cell into the adjacent clay. Master Cell XI (MC XI ) The bottom of the trenches consist of 10 feet of natural or compacted —7 clay with a maximum permeability of 1 x 10 cm/sec. Because of an anomaly in the natural clay deposit, an exception to these specifications was made for the southern 600 feet of MC XI trench XI-B where only 5 feet of clay isolate the wastes from the underlying glacial drift aquifer. The bottom of the trenches are a maximum of 44 feet below original grade (about 700 feet msl). The lowest point of the cell is about 4 feet above the local piezo- metric surface elevation, creating a positive hydraulic gradient out of the disposal cell into the adjacent clay. Each trench has a leachate collection system consisting of a 12-inch sand layer covering the southerly sloping bottom (approximately 1%) and a 4-inch perforated pipe running north—south feeding a collection sump (5 feet in depth) located at the southern end of each trench. Trench XI-A, however, has no 4-inch north—south collection pipe but only an 8-inch perforated pipe ------- 32 running east-west along the trench’s southern boundary. Trenches XJ-B, C, O and E also each have an 8-inch pipe running east-west at the southern end draining into the respective collection sumps. Master Cell IX (MC IX ) The construction of the trench bottom in MC IX will be the same as MC XI. Twenty soil borings have confirmed that a minimum of 10 feet of natural clay with a permeability of less than 1 x iQ- cm/sec exists beneath the entire master cell. The lowest portion of the cell bottom will be about 3 feet below the piezometric surface elevation (652 feet msl). If the leach- ate level is kept below the 6-inch allowable maximum, there will be a posi- tive hydraulic gradient into the disposal cell from the adjacent soil zone. The leachate collection system will consist of 12 inches of sand with the collection sumps serving the four trenches located approximately one-third of the cell length from the northern boundary. Filter-fabric- wrapped, 8-inch perforated collection pipes will run in a north-south orien- tation from both ends of the trenches toward the sumps. Master Cell X (MC X ) The trench bottom will be constructed similarly to those in MC XI with the bottom of the cell being about 15 feet above the piezometric surface elevation (652 feet msl). This will cause a positive hydraulic gradient from the disposal cell into adjacent soil zones. The leachate collection system will consist of 12 inches of sand placed over the westerly sloping trenches with a filter-fabric-wrapped 8-inch perforated pipe running east— west (1% slope). The collection sumps will be located at the west end of each trench. ------- 33 GENERAL SITE DESIGN FEATURES Perimeter Drains The surficial deltaic sands found in the vicinity of Wayne Disposal are from 7 to 15 feet thick and transmit a significant amount of locally recharged ground water. This sand layer has, for the most part, been removed from the Wayne site in the master cell construction process. To prevent the upgradient and adjacent ground water, transmitted through the sands, from entering the site, the Company has installed perimeter drains [ Figure 2] on the north, east and west sides of the site. These drains collect and transport shallow ground water around the site for discharge into either the Quirk Drain near the southeast corner of the site or Willow Run near the west side of the site. The east and west perimeter drains originate at the northwest corner of MC IV. The east drain runs east to the northeast corner of the site, then south to final discharge in the Quirk Drain. The west drain runs south to the northwest corner of MC I, then west to final discharge in Willow Run. Both the Quirk Drain and Willow Run discharge into Belleville Lake, a reservoir on the Huron River. The perimeter drains generally run near the surficial sand/clay interface; however, the drain bottom elevations are based on slope to maintain flow and are not tied into the clay zone in all portions of the drains. These saturated sands allow limited hydraulic head on the clay perimeter wall dikes and potential migration of ground water into disposal cells. During the site inspection, the east perimeter dike was observed to be leaking large amounts of water (several hundred gpm) into the MC IX excava- tion pit. This water was being pumped into the 48-inch storm sewer located at the northeast corner of the site and into the east perimeter drain closer to the Quirk Drain. This problem should be eliminated by the construction of the MC IX clay perimeter dike which will seal the perimeter drain side wall. The portion of the east perimeter ditch located in this area (MC IX) was also constructed at a low gradient (less than 0.1%) creating a buildup ------- 34 of water in the perimeter drain which could be observed in the drain manholes. This buildup could cause a limited hydraulic head on the clay perimeter dike when completed and potential ground-water migration into MC IX. Surface Drainage All portions of the site, except the west side of MC I, WD-1 and areas of the facility which have secondary containment, drain through a series of ditches to the sedimentation pond located immediately south of MC XI. The sedimentation pond drains to the west branch of the Quirk Drain, which even- tually discharges into Belleville Lake (Huron River). Surface drainage from MC I and WD-1 drain into Willow Run or into ditches adjacent to Interstate Highway 94 and eventually into Belleville Lake. All drainage on the site is due to direct precipitation with no drainages entering the site or runoff from outside the boundary of the site entering the facility. A 48-inch storm sewer crosses the extreme northeast corner of the site, adjacent to MC IX. No runoff from the facility, however, enters this storm sewer. The State requires surface water sampling at both the sedimentation pond and in the ditch separating MC VI and MC XI. Parameters analyzed are iron, chloride, pH, chromium (hexavalent and total), TOC, lead and cadmium. Sampling is conducted quarterly and, for the ditch, must occur within 24 hours of a 0.5-inch or greater rainfall (or equivalent snowfall) event when the ditch is flowing. Leachate Removal System Wayne has an automated leachate removal system operating for leachate collection sumps in MC V trenches V-A, D, B, E and C and MC VII trenches Vu-A and B (all are hazardous waste disposal trenches). Eventually, MC VII (trench Vu-C) and the proposed MC VI trenches will be included in this system. ------- 35 The system is designed to pump the leachate extracted from the hazardous waste cells (MC V and VII) to a central control box. From the control box the leachate can be delivered to Michigan Disposal or on to the outfall into the Wayne County Department of Public Works Sewerage System. Wayne personnel stated that no leachate from hazardous waste cells has been pumped through this system to the sewerage system; leachate from the hazard- ous cells has been delivered to Michigan Disposal for solidification and final disposal in the operating hazardous waste disposal trench. The Michigan Disposal lagoon is also tied into the central control box. Liquids from this lagoon may be pumped from the lagoon through the control box to he sewerage system outfall. All pipelines, except the one line from the Michigan Disposal lagoon to the control box and the one from the control box to the sewerage system outfall, are double lined. A 3-inch polyethylene line carries leachate while a 6-inch PVC line serves as containment casing. ------- 36 OFFSITE ACTIVITIES Several offsite activities [ Figure 3] at nearby facilities could affect surface and ground-water quality in the Wayne Disposal site vicinity. These facilities, which are all to the north and west of the site, include: General Motors Hydramatic Division General Motors Assembly Division (GMAD) Willow Run Airport Ypsilanti Community Utilities Authority (YCUA) WWTP5* Fons Landfill Wayne Disposal, Inc. (west side) The General Motors Hydramatic Division (GM), located about 1.5 miles northwest of Wayne, was built in 1941 by the Defense Plant Corporation of America (DPCA) to produce bomber aircraft and was operated by Ford. Ford reported that plating wastewaters were discharged directly into Tyler Pond (an impoundment on Willow Run) after chromium and cyanide removal. Sludge from this treatment was piped to a lagoon located on the southeast corner of the Fons Landfill. This facility has been operated by GM since 1950. Sludge samples collected by MDNR were found to contain PCBs, heavy metals and cyanide. Industrial wastewaters, which contain emulsified oils, have been sent to the new YCUA WWTP since 1982. Between 1969 and 1982, this wastewater was sent to the Wayne Co. , Wyandotte WWTP. Before 1969, GM wastewater was treated in an oil separation process and the water released to Tyler Pond which is an impoundment on Willow Run. Noncontact cooling water and stormwater runoff are released into Tyler Pond through two oil separators. The General Motors Assembly Division, located directly south of the Hydramatic Division and west of Willow Run, was built in 1942 to store * Was tewater treatment plants ------- 37 FIGURE 3 AREA ACTIVITIES POTENTIALLY IMPACTING GROUNDWATER flUALITY AT WAYNE DISPOSAL, INC. ------- 38 bomber aircraft parts. GM used the facility as a warehouse between 1952 and 1956 and has used the facility as an assembly plant since 1956. Indus- trial wastewater consisting of paint spray booth effluent, car wash water and welding cooling water is pretreated and, since 1982, has been released to the new YCUA WWTP. Prior to 1982, this pretreated wastewater was dis- charged to the old YCUA WWTP. Since 1968, Tyler Pond has received treated stormwater runoff from GMAO. Prior to 1968, untreated stormwater was dis- charged into Willow Run. The Willow Run Airport, located directly north of Wayne, was owned by the University of Michigan ntil 1977, when ownership and operation was transferred to the Wayne County Road Commission. No industrial wastewaters are generated at the airport. Since 1973, runoff has been treated in an oil separator. Prior to that time, there was no runoff control. Under- ground fuel storage capacity of the airport is about 410,000 gallons. The new YCUA WWTP is a 28.9-mgd-capacity tertiary treatment plant which discharges to Willow Run and is located south of GMAD, west of Willow Run. This plant, which has operated since 1982, receives the wastewater, includ- ing significant industrial wastewater flow, from the former City of Ypsilanti treatment plant and from the two former YCUA treatment plants. These older YCUA plants were located on the east side of Willow Run (Tyler Pond) directly south of General Motors Hydramatic. The Eons Landfill, located between the new YCUA WWTP and Willow Run, began operation in 1960 as the Ypsilanti Township landfill. This landfill was owned by Ford Motor Company and operated by the J. Eons Company. Wastes placed in the landfill included paint sludges, oil wastes and heavy metal sludges. Ford, alone, proposed to place 475,000 gallons of liquid wastes and sludges in this landfill. The Fons Landfill was closed in 1972. A large pit at the Eons site was used to mix liquid waste materials with lime. The resultant solidified materials were transported to the now inactive Wayne Disposal landfill located directly south of the Eons site. Both land- fills were closed in 1972. ------- 39 FfYDROGEO LOGY The Wayne Disposal site is situated on a glacial lake plain characterized by relatively flat topography, poor surface drainage and fine-grained cohesive soils. The shallow deposits comprise the delta of the ancestral Huron River and are made up of fine sand, silty sand and silt. These shallow glacio-fluvial deposits overlie the Devonian Antrim shale which locally ranges in thickness from about 50 to 100 feet. Deeper lime- stone bedrock formations contain relatively poor quality water and are not used for water supplies. There are a number of older wells in the area but, because the area is serviced by ‘ municipal water supply system, these wells may no longer be in use. The surface topography and bedrock surface in the site vicinity slope about 1 foot in 200 to 300 feet southward toward Belleville Lake which is an impoundment in the Huron River. Willow Run drains the area northwest of the site and discharges into Belleville Lake near the southwest corner of the Wayne Disposal site. The surficial brown and gray sand contains traces of silt and averages about 10 feet in thickness. This material is under- lain by a layer of gray silty clay containing traces of sand and gravel and ranges in thickness from about 20 feet to as much as 60 feet. The waste disposal trenches are excavated in this unit. Beneath the silty clay is a layer of gray silty fine-to-medium sand and traces of gravel ranging in thickness between 30 and 50 feet. This zone directly overlies the bedrock Antrim formation which is a dark brown and black shale. All of these units contain ground water under natural conditions. The unit being monitored at the site is the zone of silty fine to medium sand and gravel which consists of one or more layers overlying the shale bedrock and occurs between elevations 575 and 640 feet msl. This aquifer is generally 50 to 60 feet below land surface at the site. The piezometric surface in this aquifer slopes generally to the south and southeast toward Belleville Lake. The ground-water gradient is about 1 foot per 1,000 feet and is about 50 feet below land surface at the site. ------- 40 The adequacy of the site hydrogeological characterization is lacking in detail, although the general nature of the geological deposits under- lying the site is known. The hydrologic properties of the monitored zone are not sufficiently well understood to assure that the monitoring wells are screened in the proper intervals to intercept a plume(s) of contaminants should leakage occur. Some hydraulic testing of the monitored zone is needed to demonstrate whether or not the monitored intervals are hydraul- ically interconnected. Additional wells, including several clusters of piezometers, are needed to adequately characterize the hydrologic features of the monitored zone, including further definition of vertical hydraulic head distribution. The glacial drift aquifer which constitutes the monitored interval has a zone of transitional silts underlain by a zone of sands, silts and some gravel. The transitional silt zone is less permeable than the sand, silt and gravel zone and the underlying weathered and fractured bedrock shale surface. Some of the present monitoring wells are screened in the transi- tional silt zone while other deeper wells are screened in the more permeable zone. The hydrologic properties of these zones need more detailed study to provide adequate characterization. ------- 41 GROUND-WATER MONITORING DURING INTERIM STATUS REGULATORY REQUIREMENTS EPA administers the RCRA interim-status ground—water monitoring regulations in the state of Michigan. The RCRA monitoring system consisted of wells OB-1 through OB-17 from April 1981 until 1984. In 1984, EPA ordered Wayne to install 14 new monitoring wells (OB-18 through OB-31) located upgradient and downgradient at the limits of the existing and pro- posed RCRA hazardous waste regulated units. The Company designated the new wells as RCRA and Act 64 monitoring wells at the time of installation. Wells OB-1 through OB-17 were dropped from the RCRA monitoring program when the new wells were completed, but are retained in the Michigan Act 64 monitoring program. The 10 lysimeters are also part of the Act 64 monitoring program but not the RCRA Part 265 program. The facility has remained in interim—status ground—water monitoring since November 19, 1980. In January 1985, quarterly background monitoring began on the 14 new RCRA wells, as required by 40 CFR Part 265.92 and the Region V Consent Agreement and Final Order of 1984. The quarterly monitor- ing was completed in September 1985, and the facility plans to begin semi- annual and annual sampling in March 1986 for indicator parameters, water quality parameters and volatile organics scans. The designated RCRA and State Act 64 wells are identified in Table 3. Table 3 also indicates whether each of the wells in the system is upgrad- ient (background) or downgradient. GROUND-WATER SAMPLING AND ANALYSIS PLAN Wayne has developed a Sampling and Analysis Plan (SAP), as required, and keeps the SAP onsite in the RCRA Part B application. The plan was developed in 1983 for the first year of annual and semi-annual monitoring for wells 08-1 through OB-17. The SAP has not been updated to reflect what ------- 42 Table 3 MONITORING WELLS AT WAYNE DISPOSAL, INC. August 1985 Compliance Monitoring Well Designation* Location 08-1 Act 64 Upgradient from Master Cell IX OB-1A Act 64 Upgradient from Master Cell IX OB-2 Act 64 Downgradient from Master Cell X OB-3 Act 64 Downgradient from Master Cells IV and VI OB-4 Act 64 Upgradient from Master Cell IV OB-5 Act 64 Oowngradient from Master Cell VI OB-6 Act 64 Downgradient from Master Cell I 08-7 Act 64 Upgradient from Master Cell VII OB-8 Act 64 Downgradient from Master C .1 1 OB-9 Act 64 Downgradient from Master Cell VI OB-lO Act 64 Downgradient from Master Cell XI and sediment pond OB-li Act 64 Downgradient from Master Cells IX and X GB-hA Act 64 Downgradient from Master Cell X OB-12 Act 64 Downgradient from Master Cell I 08-13 Act 64 Downgradient from Master Cell I GB-14 Act 64 Downgradient from Master Cell VI 08-15 Act 64 Downgradient from Master Cell VI OB-16 Act 64 Downgradient from Master Cell XI OB-17 Act 64 Downgradient from Master Cell IV 08-18 RCRA, Act 64 Upgradient from Master Cells V, VI and VII OB-19 RCRA, Act 64 Upgradient from Master Cells V and VI OB—20 RCRA, Act 64 Downgradient from Master Cell VI 08-21 RCRA, Act 64 Downgradient from Master Cell VI 08-22 RCRA, Act 64 Downgradient from Master Cell VI OB—23 RCRA, Act 64 Downgradient from Master Cell VI OB-24 RCRA, Act 64 Downgradient from Master Cell VI OB-25 RCRA, Act 64 Downgradient from Master Cell VII OB-26 RCRA, Act 64 Downgradient from Master Cell VII OB-27 RCRA, Act 64 Downgradient from Master Cell VII OB-28 RCRA, Act 64 Downgradient from Master Cell VII OB-29 RCRA, Act 64 Downgradient from Master Cell VII OB-30 RCRA, Act 64 Downgradient from Master Cell VII 08-31 RCRA, Act 64 Upgradient from Master Cell VII * Mark Young, WDI, personal communication of March 11, 1986 ------- 43 procedures the Company has followed since 1983 or what changes, if any, have been made in their analyses. The SAP does not address the new RCRA monitoring well system (OB—18 through OB-31) on which background monitoring was completed in September 1985; however, Wayne indicates the SAP is for all 33 monitoring wells. The SAP should be revised to include a sampling schedule for the new wells and the sampling and analytical procedures followed since 1983. The SAP is generally complete in that it addresses procedures and techniques for sample collection, sample preservation and shipment, analyt- ical procedures and chain—of-custody, as required. The plan should be revised to exclude the purge calculation curve provided by QED (the Well Wizard manufacturer). This curve is a sales tool used by the manufacturer and should not be used to estimate purge volumes. The SAP should also delete the second static water level sounding method presented with the Well Wizard literature in the SAP. This method is not used by Wayne. Regarding sample preservatives, the SAP should indicate how much pre- servative is added to samples and how the final pH of the sample is deter- mined. The holding time (2 hours) for the indicator parameter pH should be revised to reflect the new EPA guidance of 15 minutes. Wayne has developed an apparatus known as a “clean box” in which sample bottles are kept during sampling to isolate the bottles from potential contamination by dust particles or other possible airborne contaminants; however, the tubing used to convey the samples from the wellhead to bottles in the “clean box” is not changed between use from well to well. Although Wayne does run a minimum of 2 liters of well water through the tubing at each well prior to sampling, a potential still exists for cross-contamination between samples from different wells if contamination occurs. The Task Force did not observe sampling by Wayne, so whether or not the entire SAP is followed, as required, could not be determined. Wayne ------- 44 personnel did measure water levels and purged the wells, following the SAP, prior to Task Force sampling. However, the Task Force elected to use a different technique of determining the purge volume. The reason for this decision is discussed in the next section. The hazardous waste management area consists of MC V, MC VI and MC VII. The point of compliance is not clearly defined but should include the west, south and east sides of the MCs which make up the hazardous waste management area. A revision to the SAP should include definition of the point of compliance. MONITORING WELLS The ground-water monitoring system was developed in stages beginning in January 1975 [ Table 4]. At the time of the Task Force inspection, the system consisted of 33 monitoring wells [ Figure 4]. These wells are num- bered OB-1 through OB-31, plus OB-1A and OB-11A, which are proposed replace- ment wells for 08-1 and 08-11 [ Table 3]. Ten lysimeters, required by the State, monitor the vadose zone beneath the northern edges of MC V and MC VII. Table 4 DEVELOPMENTAL STAGES OF THE GROUND-WATER MONITORING SYSTEM WAYNE DISPOSAL, INC. Ann Arbor, Michigan Well Numbers Date of Installation OB-1, 08—2, OB-3 January 1975 OB-4, OB-5 May 1979 OB-6, 08-8 September and October 1980 OB-7, 08—9 through OB-17 March and April 1981 OB-18 through OB-31 July through September 1984 OB-1A, OB—11A July 1985 Well Locations The 17 Michigan Act 64 wells (OB-1 through 08-17) are located at or near the site boundary. With few exceptions, these wells are located at ------- WILLOW RUN AIRPORT SCALE. I ’ S , 0 200 4?0 600 800 5•0 ISO 2 J0 LI RCRAHaz,,d ,,, , ,,,,, OB • II tI.,., O d,.I TO WILLOW WEST I’ERiMLTEH WAYNE DISPOSAL I FIGURE 4 GROUND WATER MONITORING WELL AND LEACI-IATE COLLECTION SUMP LOCATIONS WAYNE DISPOSAL, INC. BELLEVILLE, MICHIGAN SEPTEMBER 1985 DRIVE AL 8-1 1A ------- 46 distances of about 200 feet to as much as 2,000 feet from individual hazardous waste disposal unit boundaries. The 14 RCRA ground-water mon- itoring wells (OB—18 through OB-31) are at the boundaries of individual master cells of the hazardous waste management area. Additionally, two replacement wells (OB-1A and OB-11A) are located near the perimeter drain at the eastern limit of the nonhazardous waste management areas MC IX and MC X, respectively. Monitoring wells OB-18 through OB-31 are completed at different depths ranging between 637 feet (msl) and 568 feet (msl) [ Table 5] and the screened intervals are relatively short, being no more than 5 feet in length. The adequacy of the monitoring well network is questionable because the hydrau- lic interconnection of the various screened zones has not been clearly demonstrated and the vertical hydraulic head distribution within the monitored zone has not been adequately defined. All of the deeper wells, those having well screen tip elevations below about 600 feet (msl), were relatively good yielding wells and appear to be clearly within the intended zone to be monitored in the glacial drift aquifer and the top of the weathered shale bedrock. All but one (OB-25) of the shallower wells, those having well screen tip elevations above about 600 feet (msl), are screened in silty fine sand and had relatively poor yields. This suggests that these shallower wells may be tapping the zone of transitional silts between the glacial clay till unit, in which the waste disposal trenches are constructed, and the intended ground-water monitoring zone in the glacial drift aquifer. Because of the apparent distinct differences in the hydrologic proper- ties of the silty fine sand layer and the underlying more permeable zone, consideration should be given as to whether both zones should be monitored. If so, further consideration should be given as to whether paired wells should be installed to monitor both the transitional silt zone and the more permeable deeper zone, and at how many locations. ------- 47 Table 5 MONITORING WELL DEPTH ZONES AND RELATIVE YIELDS Well Number Well Poin Elevation t Tip (msl)* Formation Description Relative Yield** OB-27 637.2 Silty fine sand Poor OB-26 630.1 . Silty sand Poor OB-31 627.7 Silty fine sand Poor OB-25 620.0 Silty fine sand Good OB-24 614.4 Silty sand Fair to poor OB-11A 611.4 Silty fine sand Not sampled OB-20 609.9 Silty sand Poor OB-29 609.4 Silty fine sand Poor 08-30 607.4 Silty fine sand Poor OB-21 600.9 Silty sand and gravelly sand Good 08-18 589.2 Weathered shale Good OB-19 587.5 Weathered shale Good OB-28 583.9 Gravelly sand Good OB-1A 03-23 579.9 577.5 Clayey silt (over bedrock, shale) Gravelly sand Good Good OB-22 568.3 Weathered shale Good * Mean sea level datam - wells listed in order of increasing depth ** Good = yielded enough water for continuous purge followed immediately by sampling Fair = slow yield but continuous Poor = purge followed by extended periods of recharge (sometimes over- night) before yielding enough water for sampling and, in some cases, only partial sample sets were obtained. ------- 48 The rationale for placement of the monitoring wells is not specifically apparent with respect to which trenches within a given master cell are being monitored by which wells. In the event that leakage occurs, the means by which it can be identified with respect to its source is not evident. Downgradient well spacing on the southern boundaries of MC VI and MC VII is about 400 feet, leaving broad areas through which contaminants could migrate undetected if leakage occurs. There are no ground-water monitoring wells along the downgradient, southern side of MC V which is the assumed down- gradient limit of the present hazardous waste management area. However, as MC VI is developed, the final downgradient limit will move southward to the downg ’lient edge of MC VI. Well Construction Construction details for the designated ground-water monitoring wells are listed on Table 6. The wells were drilled using both hollow- and solid- stem augers and mud-rotary drilling methods. All of the well casings are 2 inches in diameter. All but six wells (OB-18, 21, 22, 24, 26 and 29) have 2-inch inside diameter galvanized steel casing and stainless steel screens or slotted well points. The six listed above have 2-inch-inside-diameter PVC casings and screens. Analyses of water samples from these PVC wells may not be truly representative of the ground-water quality due to potential chemical interaction of organic chemical contaminants and the PVC. Consideration should be given to whether these PVC wells should be replaced with wells constructed of inert materials. The annular space around the well casings is filled with cement grout over a sand pack opposite the well screens. These two materials are sepa- rated by a bentonite pellet seal in wells OB—18 through OB-31, OB-1A and OB-11A [ Figure 5]. Well construction logs do not indicate any seal between the cement grout and sand pack in wells OB-1 through OB—17. ------- 49 a Source: Wayn. Disposal well construction logs b Grotmd surface elevation c Top of casing d GAL: Galvanized steel; PVC: Polyvinylchloride a SS: Stainless steel f Not available Date Well Number Completed MONITORING table 6 WELL CONSTRUCTION DATAa GSE TOC Casiag Scre n Screen (ms l) (msl) Type Type Length (ft Total Dep h From GSE 08-1 1/75 NA NA NA GAL SS 3 0 08-2 1/75 NA NA NA GAL SS 3 0 08—3 1/75 NA NA NA GAL 5 5 3 0 08-4 5/22/79 71.0 708 4 712.6 GAL SS NA 06-5 5/23/79 95.5 697 0 702 9 GAL SS NA 06-6 9/30/80 75 0 702.1 703.8 GAL SS .4 08-7 3/30/81 70.0 697.0 698 6 GAL SS 3 5 08—8 10/1/80 75.0 704.0 706.6 GAL SS 08-9 4/1/80 86.0 700.1 701.1 GAL SS 3 5 OB-lO 4/1/80 85.5 706 5 707.7 GAL 55 3 5 08-11 3/26/81 85.0 695.3 696.3 GAL SS 3.5 08—12 4/1, 82.0 702.6 704.8 GAL SS 3 5 08—13 4/1/81 82.0 700.9 703.1 GAL SS 3 5 OB—14 3/27/81 97.0 697.1 699.6 GAL SS 3 5 06-15 3/30/81 82 5 699.8 702 0 GAL SS 3.5 OB—16 3/31/81 98.0 695.0 697.3 GAL SS 3.5 06—17 4/2/81 80 0 706.2 708 3 GAL SS 3 5 OB—18 91/1/84 113.8 702.2 703 0 PVC PVC 5 0 06—19 9/5/84 119.0 706.1 707 8 GAL SS 3.0 06-20 8/28/4 93.0 702.9 704 5 GAL 55 3 0 OB-21 7/24/84 100 0 699.9 704.8 PVC PVC 5.0 08-22 91/4/84 127 0 692.3 694.1 PVC PVC 5.0 08-23 8—24-84 120.7 698.2 700.6 GAL SS 3 0 OB—24 72/4/84 78.4 692.7 694 6 PVC PVC 5.0 08-25 8/25/84 80 8 700 7 702.7 GAL SS 3 0 09-26 72/7/84 80 5 710.1 713.3 PVC PVC 5.0 09-27 8/15/84 65.0 702.2 704 1 GAL SS 3.0 OB-28 8/14/84 120.0 703.9 704.4 GAL SS 3 0 08-29 7/308/4 95 0 704.4 706.7 PVC PVC 5 0 08-30 8/29/84 95.0 702 4 703 6 GAL SS 3 0 08-31 9/18/84 70.0 697.7 699.3 GAL 5$ 3.0 OB-].A 7/9/85 114.7 694.6 697.6 GAL SS 3.5 OB- 1 1A 71/2/85 85.0 696.4 698.7 GAL SS 3 5 ------- 50 PV & L J D ‘irEa PIPE EM 4 r1 c wr lb J F%L i J ii t’E er P L P VC TAI 4LE E.L orr WO.1. JT 10 IC O . &tLV. ,41 NfT gE U S * SchematIc Diagram of Typical Monitoring Well Assembly Figure 5 (from Neyer, Tiseo & Hindo. LTD.) ------- 51 The sand packs vary from less than 10 feet in length (OB-30) to over 20 feet (0B17). The sand packs extend above the top of the well screen, effectively extending the length of the monitored interval. Measured water- level elevations reflect the average hydraulic head over the entire sand packed interval and not just over the shorter screened interval. A poured concrete pad at land surface anchors an overturned drum and lock bar which provide well security. The concrete at several wells was slightly to severely cracked (OB-8, 12, 17, 19, 23 and 25). The concrete pad at OB-4 was intact but loose and wobbly. Erosion was observed around and beneath the concrete pad at OB-25. Unless the concrete is adequately maintained, the potentially severe freeze/thaw processes in Michigan could damage the casing as well as the cement grout surface seal in the annular space around the casing. The integrity of the well would be compromised by such damage. The concrete pad was absent at OB-27 and there was no locked security. Security at the other wells is adequate. SAMPLE COLLECTION AND HANDLING PROCEDURES During the inspection, samples were collected by an EPA contractor to determine if the ground water contains hazardous waste constituents or other indicators of contamination. Water samples were collected from 23 monitor- ing wells, one water supply well, two surface ponds and two drains [ Table 7, Figure 4). Five leachate samples were collected to determine their chemical char- acteristics and provide a basis for assessing whether constituents in the leachate have leaked into and contaminated the ground water. Leachate col- lection system sumps selected for sampling were chosen to represent dif- ferent disposal units reported by the Company to contain similar waste types. Specific sumps sampled and waste types represented are shown in Table 8. ------- Table 7 52 SAMPLE COLLECTION DATA Sample Sampling Location Date Time Remarks 08—lA 8/29/85 0834 Water cloudy; well dewatered; overnight recovery 08-4 8/30/85 0917 Water cloudy, greyish; well dewatered; overnight recovery 08-6 9/6/85 1311 08-8 9/6/85 1050 Water clear OB—9 9/6/85 1916 Water clear OB-12 9/5/85 1458 Water cloudy 08—13 9/5/85 1223 NEIC replicate samples collected; water silty 08-16 9/6/85 1817 Water cloudy 08-17 8/29/85 1510 08-18 9/3/85 1012 OB-19 8/30/85 1107 Water clear OB—20 9/6/85 1205 Well dewatered; overnight recovery; containers omitted - cyanide nitrate/ammonia, sulfate/chloride 08-21 °/6/85 1440 08-22 8/30/85 1424 08-23 9/4/85 1250 Water cloudy, greyish 08-24 9/6/85 1535 Water cloudy; well dewatered OB-25 9/4/85 1520 Water cloudy, greyish 08—26 9/5/85 0953 Water clear; well dewatered; overnight recovery, con- tainers omitted — one extractable organics, nitrate! ammonia, sulfate/chloride OB—27 9/5/85 0845 Well dewatered; overnight recovery; containers omitted - two extractable organics, total and dissolved metals, TOC, TOX, phenols, cyanide, nitrate/ammonia, sulfate/chloride 08-28 9/3/85 1605 Water clear 08-29 9/6/85 0738 Water silty; containers omitted - phenols, cyanide, nitrate/ammonia, sulfate/chloride OB-30 8/30/85 1536 Well dewatered, overnight recovery 08-31 8/29/85 0950 Water cloudy; containers omitted - one extractable organics East perimeter 9/3/85 1700 NEIC replicate samble collected containers omitted - one drain extractable organics (bottle broke) West perimeter 9/4/85 1725 drain Michigan DIsposal 8/30/85 1240 NEIC replicate samples collected; water greenish yellow, Stormwater sheen on surface retention basin Sedimentation pond 8/29/85 1736 Michigan Disposal 9/5/85 1700 water supply well MC V 9/3/85 0953 NEIC replicate samples collected; containers omitted - A, C, E dissolved metals MC V 9/3/85 Containers omitted - dissolved metals B MC VII 9/4/85 0835 Containers omitted - dissolved metals A, B north and south MC VII 9/4/85 Containers omitted - dissolved metals C MC XI 9/4/85 Containers omitted - dissolved metals ------- 53 Table 8 LEACHATE SAMPLE COLLECTION DATA Master Cell Sump(s) Waste Type Remarks V A/D (common sump), C&E Commingled hazardous and nonhazardous Composite V B Hazardous VII A and B north and south Hazardous Composite VII C Hazardous XI A, B and C Nonhazardous Composite Composited samples were comprised of equal volumes of leachate from each sump sampled. Locations of master cells and their respective leachate collection sumps are shown on Figure 4. Selection of wells for sampling was based on well locations to provide areal coverage both upgradient and downgradient of units which have received hazardous waste and to provide a basis for comparison of analytical results with historical data. The unlined Michigan Disposal stormwater retention basin receives surface drainage from a hazardous waste management area and may potentially affect ground-water quality. In addition, it is a surface monitoring point for Michigan Act 64. The perimeter drains intercept shallow ground water from the surficial sands adjacent to and upgradient of the site and bypass this water around the site. These drains discharge to tributaries which flow into Belleville Lake. The sedimentation pond receives surface runoff from hazardous and nonhazardous waste management areas and may receive ground-water discharge from potentially contaminated areas. The first step in the ground-water well sampling procedure is to meas- ure the depth to water from a reference point at the welihead. At Wayne Disposal, that reference point is a known elevation at the top of the well casing. Wayne personnel removed the upper cap of the Well Wizard pump to expose the casing and used a Fisher M-Scope (electric tape) to measure depth to water. ------- 54 The M—Scope used for this exercise was dirty and in poor condition. Although the electric probe was rinsed with deionized water between use in different wells, the line was not. The dirty line could be a source of contaminants to a well. The line was twisted and precluded accurate water- level measurement. A handle on the spool had broken off, thereby making handling awkward and possibly introducing additional error to measurement. Measurements were not consistently repeatable to better than within a tenth of a foot. This is acceptable for calculating purge volumes but not for defining hydraulic gradients or assessing water level changes. The next step in the sample collection procedure was to calculate the volume of water to be purged. The column volume of a well was calculated using the depth to water measurement, total well depth (from construction records) and casing radius. For the purposes of the Task Force, the volume of water in the casing is multiplied by three to compute the intended purge volume. The volume was then measured as water flows from the well. Stand- ard field measurements (temperature, pH and specific conductivity) were taken of the ground water prior to sampling. Volume calculations and measurements had not been done routinely by Wayne personnel. Instead, time of purging was calculated using a formula prepared by the pump manufacturer. Wayne practice was to purge the well for the amount of time derived from this calculation, consequently Wayne personnel were either underpurging or overpurging each well. This method is unsatisfactory because it does not employ any judgment as to whether or not representative aquifer water is being obtained for samp1ing. Neither does it provide any indication of the volume pumped from each well or the rate of discharge. The sampling crew should purge the well(s) into a calibrated vessel so that the actual purged volume is known. Further, a series of objective field measurements (e.g., pH, specific conductance) should be made at sev- eral intervals during purging until successive measurements are stabilized. This provides a basis for judging when water representative of the nat- urally occurring ground water is being produced. ------- 55 Wayne received split samples of volatile organics and replicate samples for all other parameters for each sampling point. They also received two complete sets of field blanks per day. The EPA contractor poured each set of blanks at locations specified by the Company. NEIC received a set of samples from each of four sample locations. All sample bottles and preser- vatives were provided by an EPA contract laboratory. Samples were collected using the following protocol. Wayne personnel determined depth to ground water using a Fisher M-Scope water level indicator. • Task Force personnel calculated height and volume of the water column. • Task Force personnel calculated three water column volumes. • Wayne personnel purged the calculated three water column volumes (less if the well dewatered). • Prior to sampling (immediately after purging or after a period of necessary recharge), the EPA sampling ontractor monitored the open well head for chemical vapors (HNU ) and radiation. • EPA contractor collected a sample aliquot and made field measure- cnents (water temperature, specific conductance and pH). • EPA contractor filled VOA* vials, then filled the remaining sample containers in the order shown on Table 9. • Samples were placed on ice in an insulated container. Volatile organic samples collected for analysis by the EPA contract laboratory and the Wayne contract laboratory were first poured into a 250-aZ beaker then poured into 60-ritZ glass vials with teflon septa. Each beaker was dedicated to the well sampled. Remaining sample containers were filled directly from the dedicated teflon discharge line. Parameter by parameter, the sampler filled the sample container for the Task Force and for the Wayne contract laboratory. N M ) is a registered trademark and appears hereafter without ®. * Volatile organics anal jsis ------- 56 Parameter Volatile Organic Analysis (VOA) Purge and trap Direct inject Purgeable Organic Carbon (POC) Purgeable Organic halogens (POX) Extractable Organics Total Metals Dissolved Metals Total Organic Carbon (TOC) Total Organic Halogens (lOX) Phenols Cyanide Nitrate/ammonia Sulfate/chloride Radionuclides (NEIC only) 2 60-mL VOA vials 2 6O-m VOA vials 1 6O-rn VOA vial 1 60-rn2 VOA vial 4 1-qt. amber glasses 1 qt. plastic 1 qt. plastic 4 oz. glass 1 qt. amber 1 qt. amber 1 qt. plastic 1 qt. plastic 1 qt. plastic 4 1-qt. amber glass HNO 3 HNO 3 H 2 SO 4 H 2 SO 4 NaOH H 2 SO 4 Table 9 ORDER OF SAMPLE COLLECTION BOTTLE TYPE AND PRESERVATIVE LIST Bottle Preservative glass glass ------- 57 At surface sampling points, all sample bottles except VOA vials were filled directly at the surface. To fill VOA vials, an intermediate glass beaker was used. The same sequence of filling sample containers was followed. Leachate samples were collected using a PVC bailer and compositing in 5—gallon glass containers. The leachate was poured into the sample con- tainers for both the EPA and the Wayne contract laboratories using two methods. 1. For the VOA vials, leachate was poured first into clean (dedicated) glass beakers, then into the VOA vials. 2. The remaining bottles were filled by siphoning through teflon tubing from the composite in the 5-gallon glass containers. After sampling was completed at a well, EPA contractor personnel took their samples to a staging area where a turbidity measurement was taken and one of the two sample aliquots for metals analysis was filtered. In addi- tion, metals, TOC, phenols, cyanide, nitrate and ammonia samples were pre- served [ Table 9]. Leachate samples were not preserved. At the end of the day, samples were packaged and shipped to the two EPA contract laboratories or NEIC according to applicable Department of Transportation regulations (40 CFR Parts 171-177). Aqueous samples from monitoring wells and surface locations were considered “environmental” and those from leachate collection system sumps were considered “hazardous” for shipping purposes. Each day of sampling the EPA contractor prepared field blanks at two locations for each parameter group (e.g. , volatile organics, metals) in the field. Blanks were poured at the locations listed in Table 10. The Com- pany contract laboratory provided bottles and water for pouring their own blanks at locations where the EPA contractor did not pour blanks. Task Force personnel noted that some of these bottles were dirty and the lip of at least one bottle was chipped. ------- 58 Table 10 LOCATIONS OF FIELD BLANKS Date Time Location Receiver 08/29/85 1257 1610 08-31 0B107 Facility, Facility, EPA EPA 08/30/85 1335 1530 Michigan Disposal pond OB-30 Facility, Facility, EPA EPA 09/03/85 1055 1645 OB-18 OB-28 Facility, Facility, EPA EPA 09/04/85 1300 OB-23 West perimeter drain Facility, Facility, EPA EPA 09/05/85 “.1000 ‘ .1530 ‘d245 OB-26 OB-12 OB-13 Facility, Facility, NEIC EPA EPA 09/06/85 0800 OB-29 Facility, EPA Samples were analyzed by the EPA contractor laboratories for the param- eter groups shown on Table 9 except for samples which were not obtainable from poorly producing wells, as indicated on Table 7. NEIC received and analyzed replicate samples for one ground-water monitoring well (08-13), two surface locations (east perimeter drain and the Michigan Disposal pond) and one leachate composite (MC V, sumps A, C and E). SAMPLE ANALYSIS AND DATA QUALITY EVALUATION This section provides an evaluation of the quality of interim status ground-water monitoring data gathered by Wayne between November 1981 and August 1985. Analytical procedures for the analysis of ground-water samples and data quality were evaluated through laboratory inspections and review of documents containing the required monitoring data. The Wayne onsite laboratory and two Wayne contract laboratories were inspected in August and September 1985. The Company’s contract laboratories being used at the time of the inspection were Canton Analytical Laboratories, Inc. (CAL) of Ypsilanti, Michigan and Encotec of Ann Arbor, Michigan. The evaluations included review of laboratory operating and analytical procedures, internal data reports, raw data and quality control records; interviews of key ------- 59 laboratory personnel; and inspection of laboratory facilities and analytical equi pment. This evaluation revealed that, in accordance with the applicable analysis plans, samples have been collected and analyzed for the specified parameters at the required frequencies. Nowever, much of the reported data are unreliable, biased or inadequate due to improper sample handling, labora- tory or reporting methods. Although present methods are improved in a number of ways over past methods, inadequacies still exist. Since 1981, CAL has performed most analyses of ground-water samples for monitorthg wells OB-1 through 08-17. Radiochemical analyses were per- formed by the University of Michigan, and Mid-Missouri Testing of Columbia; Missouri performed the first quarter TOX analyses. All other lox analyses were done by CAL. During 1982 and 1983, CLOW Hydro Research Services of Pontiac, Michigan sporadically performed some inorganic analyses. The onsite laboratory has performed temperature and pN measurements on monitor- ing well samples as an internal evaluation of CAL’s results and have not been included in monitoring reports to the State or EPA. In January 1985, Encotec of Ann Arbor, Michigan began analyzing samples from monitoring wells OB-18 through OB-31. Encotec subcontracts lOX and radiochemical analyses to Environmental Research Group, Inc. of Ann Arbor. At the time of inspection, the first two quarters of background determina- tions for these wells had been completed. CAL and Encotec have provided the vast majority of monitoring data and, thus, were the focus of the laboratory inspections. Initial Ground-Water Monitoring Well System In November 1981, Wayne initiated quarterly monitoring on the RCRA well network pursuant to 265.92(c). As previously noted, the network con- sisted of 17 wells, four of which were considered upgradient COB-i, 4, 7 and 11). The four quarterly monitoring reports, subsequent semi-annual ------- 60 and assessment reports and associated laboratory records were reviewed for this well network. The reports were found to be complete but contained biased or suspect data. RCRA regulations [ 265.92(c)] require quarterly monitoring for the first (initial) year of all wells to establish background concentrations or values. Quarterly monitoring of the upgradient wells must include quadruplicate measurement of the four parameters used as indications of ground-water con- tamination (pH, specific conductance, TOC and TOX). After the first year, samples from each well must be analyzed at least semi-annually. Quaclruplicate measurements were obtained as required; however, the variability of these measurements for TOC and lOX indicate that the reported results are not reliable. The pH and conductance data are suspect or biased due to improper sample handling or calibration procedures. The variability observed for a set of quadruplicate measurements for TOC was often much greater than expected for the method. For example, second quarter results for well OB-6 ranged from 3 mg/i to 10 mg/ . with an average value of 6 mgR; the method should have observed a standard devia- tion of about 0.5 mg/i. Systematic errors are evident in the data between quarters for a well. For example, TOG values ranging from less than 5 mg/ . to 200 mg/i were reported for well OB-13 while COD values for the same samples ranged from 3 mgI. to 15 mgI2. COD should be greater than TOG. Subsequent roc analysis results for this well have been less than 5 mg/i. The analytical procedure for TOC was incomplete because the results repre- sent only nonpurgeable organic carbon. Samples were purged with nitrogen gas prior to determination of organic carbon, which results in the loss of purgeable (volatile) organic carbon. lox coricentrations below about 40 pgI2 are unreliable. The variability observed for sets of quadruplicate measurements indicate that concentrations less than 40 pg/2 may not be distinguishable from the method blank. For example, the third quarter quadruplicate TOX concentrations for well OB-lO ranged from less than 5 pg/ to 20 pg/L The apparent systematic error ------- 61 observed between quarters for a well are probably a result of the high method variability. For example, the third quarter lOX concentration for well OB-8 was reported as less than 5 .ig/ while the fourth quarter concen- tration was reported as 51 pgI2. CAL performs lox analyses near an area where solvents are stored and samples are extracted with chlorinated solvents (oil and grease procedure, etc.). This practice is cautioned against by the instrument manufacturers as the activated carbon used in the lOX analysis is highly susceptible to contamination by fugitive organic vapors, lox analyses should be performed in an area isolated “om solvents. Laboratory records show that ph measurements were, at times, performed the day after collection of the sample. All reported pH measurements were performed by CAL at their Ypsilanti laboratory. No reported pH measure- ments were made in the field. These data are suspect due to the instability of the pH ol ground-water samples. Currently, the EPA is recommending that pH measurements be made within 15 minutes of sample collection. Conductance values are probably biased low. Laboratory records indi- cate that neither cell constant nor temperature corrections were made for samples collected prior to 1984. The EPA method requires daily determina- tion of the cell constant, correction of conductance values for the cell constant and correction of values for temperature so that values are reported as the conductance at 25° C. A meter internal calibration procedure was used; however, this procedure does not compensate for changes in the resistance of the probe or temperature differences. In 1984, CAL started to make the appropriate cell constant corrections; however, temperature corrections were still lacking. These corrections would be expected to generally increase the conductance values; thus, reported values are biased low. Sample; collected for the eight metals on the drinking water parameter list [ 265, Appendix III] prior to mid-1983 were handled in such a manner ------- 62 that the analysis results represent neither dissolved nor total concentrations. Samples were acidified and then filtered; thus, the results would represent some extractable concentration. After mid-1983, dissolved metal concentra- tions have been determined. This has diminished the validity of any com- parison of post mid-1983 concentrations to background concentrations. Fur- ther, drinking water standards are based on total metal and not dissolved metal concentrations [ 40 CFR Part 141.23(f)]. Therefore, the analytical results are not adequate for characterizing the suitability of ground water as a drinking water supply. The quarterly monitoring data reported for lead and mercury often exceeded the drinking water standards. The drinking water standards for lead and mercury are 0.05 mg/i and 0.002 mg/L, respectively. For the first quarter, lead concentrations of 1.1 mg/i, 0.35 mg/2 and 0.75 mg/i were reported for wells OB-2, OB-4 and OB-il, respectively. Concentrations of 2 mg/i and 0.38 mg/2 were reported in the second quarter for wells OB-15 and OB-17, respectively. Ten wells were reported to exceed the lead drink- ing water standard of 0.05 mg/2 , in the fourth quarter. Similarly, high concentrations of mercury were reported. For example, six wells for the first quarter and seven wells for the fourth quarter were reported to exceed the mercury drinking water standard with the highest concentration of 0.015 mg/i reported for well OB-4 in the first quarter. After mid-1983, analyses for these parameters have not found concentrations to exceed drink- ing water standards. This suggests that the background monitoring inad- equately characterized the ground water for these parameters. The lead and mercury concentrations identified by Wayne in their initial sampling are not considered to be indicators of ground-water contamination. Since field techniques, analytical methods and laboratories have changed, these metals have not been observed to exceed drinking water standards. Further, Task Force sample analyses did not confirm the presence of these metals. The flame atomic absorption spectroscopy methods, used by CAL for cad- mium and lead, did not achieve reliable results near the drinking water limits for these parameters. Reported detection limits were often greater than the drinking water standard for the cadmium analyses and at the ------- 63 standard for lead. The detection limits reported are those claimed by the instrument manufacturer and were not substantiated by CAL. Furnace atomic absorption 5 pectroscopy would have been more applicable in establishing background concentrations. Wide variations in gross alpha and gross beta measurements between quarters for a well and the variability in the ratios of these two measure- ments at specific wells, indicate that the results are suspect and possibly unreliable. For example, in the first quarter, well 06-11 was reported to have a gross alpha of 74 pCi/i and a gross beta of 290 pCi/2 while, in the second quart.er, the values were report d as less than 1.0 pCi/2. Such a change would be expected to be reflected in the conductance as usually gross alpha increases with increasing dissolved salts, but the conductance changed very little. First quarter gross alpha and gross beta activities of 19 pCi/i and 80 pCi/2 were reported for well OB-6, while for the second quarters, levels of 68 pCi/i and 114 pCi/2 were reported, respectively. The ratio of gross beta activity to the gross alpha activity is one to four for the first quarter and one to two for the second quarter. The ratio of gross alpha to gross beta should be similar even if the levels do change. All specific organic analyses were performed using gas chromatography. No gas chromatography/mass spectroscopy analyses were performed for ground- water samples. CAL participated in EPA interlaboratory performance evalua- tions in 1983 and 1984. The results for the halomethanes were often not acceptable as were phenoxy herbicide analysis results. No organic compound has been detected by CAL in any well. The reported detection limits are typical for the methods; however, they were not substantiated by the laboratory. New Ground-Water Monitoring Well System The current ground—water monitoring plan directed the installation of 14 new wells (OB—18 through OB-31) at the perimeter of the hazardous waste management area. The well installation was completed in 1984, except for proposed replacement wells OB-1A and OB-11A, which were installed in July ------- 64 1985. Since installation, Encotec has analyzed samples from these wells for Wayne a!; part of the required quarterly background monitoring program. The two quarterly monitoring reports and associated laboratory records were reviewed for this well network. The reports were complete but contained suspect or unreliable data. The pH data are unreliable. Measurement of pH has never been per- formed within recommended holding times. Custody records demonstrate that these analyses were, in many cases, performed the day after sampling. During the laboratory inspection, a dark floc was observed in the sample cup of a pH buffer standard used for calibration. Reportedly, buffer solu- tions are only changed once per week which is not frequent enough for good laboratory practice. Encotec did not make cell constant or temperature corrections, as required by the EPA methods and, thus, the conductance values are probably low. The TOC results are unreliable. Systematic error is evident in com- parison of the first and second quarters’ results where the first quarter results for every well are greater than the respective second quarter values. Further participation in an EPA performance evaluation in May 1985 indicated unacceptable performance on TOC determinations. Reported concentrations were about one-half of the actual concentration of the performance sample. TOC concentrations represent nonpurgeable organic carbon results instead of total organic carbon results. lox data is unreliable. TOX is determined by ERG using the Neutron Activation method. Quadruplicate measurements vary widely. For example, second quarter TOX concentrations for well OB-19 range from less than 10 ig/. to 70 pg/i and a T0)( range of 20 pgl2 to 880 pg/i was reported for well 08—23. Such variability indicates that background levels have not been accurately established. ------- 65 The metals data are not adequate for characterizing the suitability of ground water as a drinking water supply. Samples collected for metals analysis were filtered and then acidified, thus, dissolved concentrations instead of total concentrations were determined. Turbidity affects the evaluation of total metals concentrations in well water samples. The reported flame atomic absorption spectroscopy detection limits for cadmium and lead were 0.02 mg/. and 0.1 mg/2, respectively. These detection limits are twice the drinking water standards for these elements. The monitoring plan references the argentometric method for chloride determinations; however, Encotec has been using a specific ion electrode method. EPA methods manuals do contain an electrode method for chloride. The electrode method is subject to numerous interferences from common con- stituents of ground water. Further, this method would not be expected to achieve the precision and accuracy of the argentometric titration. GROUND-WATER ASSESSMENT MONITORING AND OUTLINE Wayne keeps a ground-water assessment monitoring plan outline onsite in their Part B application. On December 15, 1983, Wayne notified EPA of decreased pH in the down- gradient monitoring well OB-13. The measured pH was a statistically sig- nificant change from background pH values measured in upgradient wells based on the Student’s t-test required by 40 CER Part 265.93. Wayne submitted a letter describing a more specific assessment of ground-water quality to EPA on December 30, 1983 and a followup report on February 2, 1984. EPA responded stating the plan did not address hazardous waste constituents or the specific hazardous wastes handled at the land disposal facility. In July 1984, Wayne notified EPA of additional statistically sig- nificant changes in pH in other downgradient wells. The Company attributed these variances to faulty background data. In October 1984, EPA requested that Wayne submit a specific plan for a ground-water assessment program. ------- 66 EPA followed up in November 1984 with a letter instructing Wayne to submit a ground-water quality assessment plan addressing all hazardous wastes and hazardous waste constituents disposed of at the facility. The letter instructed that the rate and extent of migration of hazardous waste constit- uents should be addressed in the plan. Wayne submitted an assessment plan in January and February 1985. EPA approved the plan in February 1985 and assessment monitoring went into effect. The first round of sampling in March 1985 revealed that no organic hazardous waste constituents were present in any of the specified walls. Barium was the only inorganic hazardous waste constituent detectable. Wayne began an investigation of the ground-water quality across the site and deter- mined that the barium levels were consistent with background concentrations found in local soils and ground water. The Sampling and Analysis section of this report presents further discussion on this subject. Wayne notified EPA of its conclusions in a letter dated November 1, 1985. Wayne’s conclusions are that the assessment effort shows that the facility has not failed and that there has not been a release of hazardous waste constituents to the ground water. Wayne indicated it considers the assessment program to be terminated and has resumed interim status detection moni tori ng. ------- 67 GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT EPA Region V requested a Part B application from Wayne on February 7, 1983 and received it on September 8, 1983. Review of the Part B by MDNR and EPA led to issuance of a Notice of Deficiency (NOD) to Wayne on Novem- ber 28, 1983. Subsequentl j, three additional exchanges of responses, reviews and NODs have occurred through 1985 and review is continuing while still awaiting a response from the November 14, 1985, NOD. On March 29, 1984, EPA issued to Wayne a Complaint and Findings of Violations which included a requirement for compliance with the appropriate placement of downgradient wells per 40 CFR 265.91(a)(2). Wayne was advised that these additional wells should be placed at the limits of the hazardous waste management area. Wayne was fined and agreed to install 14 new wells including both upgradient and downgradient locations at the limits of their designated waste management area. These wells were installed during the period July through September 1984. These new well locations are shown on Figure 4 of this report. The adequacy of these new wells, with respect to location, construction and sampling and analysis, is still under review and is the subject of other portions of this report. Revision and updating of the Sampling and Analysis Plan is needed and additional monitoring wells will be required at locations and screened in such intervals as is determined to be appropriate based on further refine- ment of the hydrogeological details of site characterization. Consideration should also be given to replacing PVC monitoring wells with chemically inert construction materials because of the potential for chemical interaction between organic chemicals and PVC well casings and screens. Residual trace levels of organic contaminants apparently introduced by contaminated Well Wizard pumps have only been associated with wells having PVC casings and screens. The facility should remain in the detection monitoring phase while evaluating the acceptability of the first year’s background monitoring data. ------- 68 MONITORING DATA ANALYSIS FOR INDICATIONS OF WASTE RELEASE This section presents an evaluation of both Task Force and Wayne monitoring data regarding indications of apparent or potential leakage from the waste management units. Analytical results from and methods used on samples collected by Task Force personnel are presented in Appendix A. Organic compounds found in samples from some of the RCRA wells may be attributed to contamination from the sampling apparatus rather than an indication of ground-water contamination related to waste disposal activi- ties. In June 1985, MDNR reported detectable amounts of organic compounds in ground-water samples taken from Wayne’s monitoring wells. The analytical report showed 1,1-dichioroethane, 1,2-dichloroethane, 1,1,1-trichioroethane, tetrachioroethene and/or toluene were present in most of the new RCRA wells (OB-18, 19, 21, 22, 23, 24, 26, 27, 29 and 30). MDNR did not analyze for methylene chloride. MDNR conducted a resampling in August 1985 which con- firmed the presence of these organics in six of the wells. On September 20, 1985, QED Environmental Systems, Inc. (manufacturer of the Well Wizard bladder pumps) notified Wayne that the series of pumps installed in new wells OB-18 through OB-31, OB-1A and OB-11A, were from a series of pumps contaminated with a lubricant containing organic constitu- ents. The constituents identified by QED include 1,1,1-trichloroethane, tetrachioroethene and methylene chloride. Wayne subsequently notified EPA, Region V of QED’s letter and MDNR’s analytical results. The Task Force data indicate some of the same compounds are present in six of the monitoring wells [ Table 11]. The contaminated wells identified by the Task Force are located across the site and do not indicate a con- taminant plume. Furthermore, Wayne has indicated that these contaminant concentrations have declined since the contaminated pumps were removed and continue to decline over time. The continued detection of diminishing concentrations of residual organics appears to be associated with wells having PVC casings and screens. ------- 69 Table 11 ORGANIC COMPOUNDS DETECTED IN TASK FORCE GROUND-WATER SAMPLES ( g/ ) August-September 1985 Compound • OB-8 Well 08-18 OB-20 OB-26 OB-29 OB-30 1,1,1-trichloroethane 7.8 7.9 35 40 Tetrachioroethene 12 32 18 5* Toluene 5* 10 * Estimated. See Table A-2 of Appendix A. The source of the toluene in monitoring wells OB-8 and OB-26 should be investigated. 08-8 did not receive one of the new Well Wizard pumps; how- ever, 08-8 is located about 2,000 feet southwest of the limit of the hazardous waste management area and is not considered to be directly down- gradient of the hazardous waste cells (the ground-water flow gradient is to the south-southeast). 08-8 is a downgradient monitoring well for MC I. Some ground-water samples indicate elevated levels of zinc. Although concentrations do not exceed the drinking water standard (5 mg/2), some of the samples show concentrations above normal background levels. The zinc is not considered to originate from the hazardous waste management units, but rather irom well construction materials. Samples from wells constructed of a galvanized steel/stainless steel assembly show higher zinc concentra- tions than samples from PVC wells (Table 12]. The wells showing zinc were observed across the site and indicate no pattern of migration. Some of these wells are background wells that are upgradient ?rom site operations. ------- 70 Table 12 TOTAL ZINC CONCENTRATIONS DETECTED IN TASK FORCE GROUND-WATER SAMPLES • Well Zinc (pgI. ) Construction Material OB-1A 529 GAL/SS OB-4 1300 GAL/SS OB-6 176 GAL/SS OB-8 784 GAL/SS OB-9 3610 GAL/SS 08-12 457 GAL/SS OB-13 292 GAL/SS OB-16 292 GAL/SS OB-17 290 GAL/SS 08-18 9.5 PVC OB-19 243 GAL/SS OB-20 777 GAL/SS OB-21 7.1 PVC OB-22 9.1 PVC 08-23 37 GAL/SS OB-24 21 PVC OB-25 35 GAL/SS OB-26 16 PVC OB-28 116 GAL/SS OB-29 22 PVC OB-30 1500 GAL/SS OB-31 3430 GAL/SS * Galvanized steel/stainless steel; polyvinylchloride Available evidence suggests that the hazardous waste disposal cells at Wayne have not failed and are not leaking hazardous waste constituents into to ground witer. ------- REFERENCES 1. Neyer, Tiseo and Hindo, Ltd. (NTH), November 5, 1980, “Report on Preliminary Hydrogeologic Investigation” 2. NTH, July 8, 1981, “Report on Final Hydrogeologic Investigation” 3. NTH, September 7, 1983, “ITEM IV - Grouzid-water Protection (Supbart F), Hazardous Waste Management Area” 4. NTH, October 26, 1984, “Report on Monitoring Well Installation” 5. NIH, August 1, 1985, “Monitoring Well Replacement, OB-1 and OB-li” 6. EPA Notification Letter, October 5, 1984, Miner to Vilnius ------- APPENDIX A ANALYTICAL TECHNIQUES AND RESULTS FOR TASK FORCE SAMPLES WAYNE DISPOSAL INC., BELLEVILLE, MICHIGAN ------- A-i ANALYTICAL TECHNIQUES AND RESULTS FOR TASK FORCE SAMPLES WAYNE DISPOSAL, INC. , BELLEVILLE, MICHIGAN The following discusses analytical techniques, methods and results for water and leachate samplescollected by the Ground Water Task Force at Wayne Dispo•;al, Inc., Belleville, Michigan. Water sample analyses and results are discussed in the first section; the second section addresses the leachate analyses and results. Field measurements on water samples, including conductance and pH were made by the EPA sampling contractor at the time of sampling. No field measurements were made for the leachate samples. Laboratory analysis results were obtained from two EPA contractor laboratories (CL) participa- ting in the Contract Laboratory Program (CLP). One CL analyzed the samples for specified organic compounds while the other analyzed for metals and other parameters. Standard quality control measures were taken including: (1) the analysis of field and laboratory blanks to allow distinction of possible contamination due to sample handling, (2) analysis of laboratory spiked samples and performance evaluation samples and comparison of the CL results with NEIC split sample analyses to estimate accuracy, (3) analysis of lab- oratory duplicates and field triplicates to estimate precision and (4) the review and interpretation of the results of these control measures. The performance evaluation samples were samples of known analyte concentrations prepared by the EPA Environmental Monitoring Systems Laboratory, Cincinnati, Ohio. NEIC and the CL analyzed split samples from well OB-i3, the Michigan Disposal stormwater retention basin, the East Edge Drain and the MC-V-ACE disposal cell leachate. Table A-i provides a summary, by parameter, of the analytical techni- ques used arid the reference methods for the sample analyses. ------- A-2 WATER SAMPLE ANALYSIS RESULTS Specific Organic Analysis Results Table A-2 lists the organic compounds which can be reported as being present in the ground-water monitoring samples for the identified wells. The organic results for the Michigan Disposal Water Supply well (MDWS), the Michigan Disposal stormwater retention basin, the sedimentation pond and the east and west edge drain water samples are given in Table A-3. None of the organic compounds determined were detected above blank levels in the other water samples. Table A-4 contains the limits of quantitation for the analyses for volatiles, semivolatiles and pesticides. Many compounds given in Table A-4 were not detected in any of the samples and thus are not listed in Tables A-2 and A-3. Based on the matrix spikes, the volatile organic limits of quantitation are probably reliable to within a few parts per billion, to within factors of 2 to 20 for the semivolatile organic compounds and to within a factor of 4 for the pesticides. The CL reported 70 pg/. of 1,2-dibromo-2-chloropropane in the sample for well OB-17. Examination of the data found that the compound determined was actually 1,2-dibromo-3-chloropropane (DBCP) and that the apparent pres- ence of this compound in this sample is probably due to carry-over from the previously analyzed sample. The performance evaluation sample which con- tained 500 pg/i DBCP was analyzed just prior to the well OB-17 sample. Subsequent to the well OB-17 sample analysis, a blank was analyzed and was found to contain 20 pg/i of DBCP. Further, 70 pgI. OBCP should have resulted in a purgable organic halogen (POX) of 32 pgI. . However, the measured POX was less than 5 pg/i. The CL reported 2,4—D concentrations ranging from 0.3 pg/. to 6.5 pg/2 in some of the water samples including some of the field blanks. Further, the chromatograms often contained interfering peaks and the quantitative results from the two-column confirmation analyses often disagreed substan- tially. Therefore, the detection limit for 2,4-0 was raised to 10 pg/i. ------- A- 3 The NEIC laboratory analyzed water samples from three sampling points. Both the NEEC organic data and the CL data showed no compounds detected in the samples for well OB-13 and the east edge drain. In general, NEIC results for the Michigan Disposal stormwater retention basin sample were in qualitative agreement with the CL results. NEIC found 5,500 pg/2 isopropanol while the CL did not determine this compound. Due to severe foaming problems in the purge and trap volatile analysis, NEIC analyzed the pond sample at a high dilution and, thus, did not achieve the CL detection limits. The chlor- inated organics found by the CL were not detected by NEIC. The presence of these compounds is substantiated by the CL chromatograms and the mass spectra. As discussed below, the total organic halogen (TOX) concentrations were in general determined to be biased low and are not reported. However, the TOX obtained for the pond sample of 628 ig/2 chlorine does substantiate the presence of the chlorinated compounds. POX was determined for the pond sample. NEIC’s extractable results for the Michigan Disposal stormwater reten- tion basin sample are in qualitative agreement with the CL results and the quantitative results compared favorably. The CL reported 5,200 pg/2 phenol and 1,000 pg/i benzoic acid, while NEIC found 3,900 pg/i phenol and 1,000 gI2 benzoic acid. Metals Analysis Results The dissolved and total metals results for the ground-water monitoring system well samples are reported in Table A-5. Table A-6 contains the metal results for the other water samples. The accuracy of each detectable value is footnoted in the tables. The dissolved elemental concentrations for many of the samples are biased high. Mismatching of the calibration standards acid matrix to the dissolved preserved sample matrix was the cause of the bias. Comparison of the CL dissolved values to NEIC’s, for the samples from well OB-13, the disposal pond and the east edge drain, and comparison to the CL total values indicates that the dissolved values are generally biased high by as much as 20%. ------- A- 4 No values are reported for total silver and dissolved or total anti- rnony because the lower 99% confidence limits for the spike recoveries for these elements were below zero. The digestion in combination with the sample matrx apparently caused precipitation of the silver. The low antimony spike recoveries are apparently related to the spiking standards used by the CL. NEIC observed no sample matrix effect for antimony spikes. Tin spike recoveries for both the dissolved and total analyses were low. However, no tin was detected and the tin detection limits have been raised to reflect the low spike recovery. “‘IC’s analyses confirm the CL results. In general, NEIC’s values agreed to within 20% of the CL values. General Analysis Results The field measurements and the results of other analytical testing for ground-water monitoring well samples are reported in Table A-7. Table A-8 reports the results for the other water samples. The reliability of each detectable value is footnoted in the tables. Although samples were analyzed for total organic halide (lOX) and purge- able organic carbon (POC), the results were determined to be unreliable and are not reported in the data tables. The TOX results were not substantiated by the POX results or by the specific organic constituent analysis results. Further, the CL reported a lOX value of 75 pg/i for the performance evalua- tion sample which had an acceptance range of 96 pg/2 to 122 pg/i. POC values were often not substantiated by the specific organic constituent analysis results. Comparison with NEIC POC results indicates that the CL POC values were biased high. For example, NEIC found less than 5 pg/2 POC for the well OB-13 sample while the CL reported 1,800 pg/i POC. The CL reported a POC value of 91 mg/2 for the performance evaluation sample which had a true value of 448 mg/i. NPOC represents non-purgeable organic carbon. Cyanide was determined by the CL. However, the results are unreliable. The CL reported a cyanide value of 290 pg/i for the performance evaluation ------- A- 5 sample which had a true value of 480 pg/i. Further, NEIC found the Michigan Disposal stormwater retention basin sample to contain 20 ig/. cyanide and the MC-V-ACE leachate sample to contain 33 pg/.e cyanide while the CL obtained cyanide concentration of 9 pg/i and 13 j g/2, respectively. The low bias indicates that cyanide could have been present in a sample and may not have been detected. Therefore, the cyanide results are not reported in the data tables. Samples collected for nitrate analyses were preserved with sulfuric acid which is appropriate only when determination between nitrate and nitrite is no 4 needed. Samples collected for nitrate analysis should be cooled to 4° C. and analyzed within 48 hours of collection. Further, the colorimetric method used is subject to positive interferences that were apparently not compensated for by the CL procedure. This is indicated in comparison of the CL results with those of NEIC. NEIC found less than 0.05 mg/. nitrate as nitrogen for both the well OB-13 and Michigan Disposal stormwater retention basin samples and 0.8 mg/i nitrate as nitrogen for the east edge drain sample. The CL reported 1.1 mgIQ., 0.93 mgI9 and 1.7 mg/2 , respectively, for the well OB-13, the Michigan Disposal stormwater reten- tion basin and the east edge drain samples. NEIC analyzed samples that were cooled to 4° C. and not activated. These samples were analyzed by ion chromatography the same day that they were received. No nitrite was detected by NEIC. Thus, the CL nitrate results are positively biased due to interferences other than nitrite. The nitrate results are unreliable and not reported in the data tables. Although chloride and sulfate were determined, the results were deter- mined to be unreliable and are not reported. A chloride concentration of 147 mg/ . and a sulfate concentration of 8,300 mg/i was reported for the sample for well OB-18. The conductance measured in the field was 290 umhos/cm which does not substantiate such high levels of the anions. Fur- ther, from the cation data, the milliequivalence of anion should not exceed about 4.9 mg/L Since no calculation mistakes were discovered, it must be assumed that sample mishandling or mislabeling was the cause of the erronous chloride and sulfate data. Further, indication of mishandling or mislabel- ing problems for the chloride and sulfate samples is found in comparison of ------- A- 6 NEIC results to the CL results for the leachate sample. NEIC found 1,900 mg/t chloride and 105 mg/i sulfate, while the CL reported 25 mgI. chloride and less than 5 mg/. sulfate for samples for the MC-V-ACE leachate. The cation data for the leachate would indicate that NEIC’s results are more reasonable. These apparent mishandling or mislabeling problems cast doubt on the reliability of the chloride and sulfate data for the other samples. LEACHATE SAMPLE ANALYSIS RESULTS Specific Organic Analysis Results Table A-9 reports the organic constituent analysis results for the five leachate samples. Many compounds given in Table A-4 were not detected in any of the samples and thus are not listed in Table A-9. The limit of quantitation (LOQ) for a particular compound can be determined by multiply- ing the LOQ factors given in the Table A-9 by the compound’s LOQ given in Table A-4. NEIC results agreed qualitatively with the CL results for the MC-V-ACE leachate sample. Sample results agreed quantitatively within a factor of three. NEIC did not determine the herbicides, and for the reasons discussed above, the CL 2,4—0 results should be considered tentative. Metals Analysis Results The total metals results for the leachate samples are reported in Table A-b. Depending on the suspended matter composition, the values reported for certain elements may not represent “total” concentrations. If the suspended matter is siliceous then values for aluminum, magnesium, potassium and sodium are not “total” because the silicate matrix was not dissolved. The heavy metal results would approximate “total” concentrations because they are usually absorbed and are not incorporated in the silicate matrix. ------- A- 7 For the major cations, NEIC results for the MC-V-ACE leachate sample agreed to within about 30% of the CL results, while the trace element results agreed to within a factor of two. General Analysis Results Table A-il reports the results of other testing for the leachate sam- ples. For the reasons discussed above, the results for POC, chloride, nitrate and sulfate were determined to be unreliable and, thus, are not reported. Although lOX and cyanide were determined to be unreliable because of significant low biases the results for these two parameters are reported for the leachates because significant levels were found. ------- rable A-I Sample Preparation and Analysis Techniques and Methods Parameter asannans ens. en S 5= Conductance pH Turbidity POX TOX POC UPOC Ansiionia Chloride Nitrate Sulfate Cyanide Phenol Mercury As, Pb, Se and 11 Other Elements Volatiles Preparation Technique None None None None Carbon absorption None Acidify and purge particulates settled Particu lateS settled Particulates settled ParticulateS settled Manual distillation Manual distillation Wet digestion for dissolved and total Acid digestion for total Acid digestion for total Purge and trap Direct Injection Methylene chloride extraction Methylefle chioride/hexane extraction Diethylether , raction/methylati0fl Dana s 55255 SSaCfl Analysis Technique ElectrometriC. Wheatstone Bridge Potentlo metrY NephelOmetr 1 C Purgable combusted. MicrocoulometrY Carbon combusted. F4 crocoulometry Purgable combusted. Non-dispersive Infrared Liquid combusted. Non-dispersive Infrared Phenolate Colorimetry of supernatant Mercuric Precipitation Titration of supernatant Brucine Sulfate Colorimetry of supernatant Barium Sulfate Turbidimetry of supernatant Pyridine BarbituriC Acid ColorimetrY Ferricyanide 4-Aminoantipyrifle Colorimetry Cold Vapor Atomic Absorption SpectroscOpy Furnace Atomic Absorption SpectroscoPy Inductively Coupled Plasma Emission Spectroscopy Gas Chromatography with Electron Capture Detection Gas Chromatography — Mass SpectrosCopy or Gas Chromatography with Flame Ionization Detection Gas Chromatography — Mass SpectrosCopy Gas Chromatography with Electron Capture Detection Gas Chromatography with Electron Capture Detection nanana_saa_naae.__n____n__.___a_a_._anases___aenaa Method keference =aaas_n.__s_e_.n Method 120.1 (a) Method 150.1 (a) No reference EPA 600/4-84-008 Method 9020 (b) No reference Method 415.1 (a) Method 350.1 (a) Method 9252 (b) Method 9200 (b) Method 9038 (b) CIP Method (c) Method 420.1 (a) CIP t4ethod CLP Method CLP Method CIP Method CIP Method CIP Method CIP Method CLP Method Method 8150 (b) S D aDS Semi—vol ati les PesticideslPCB Herbicides a CaseS Sfl S S DSCfl D a) Methods for Chemical Analysts of Water and Wastes, EPA-600/4-79- 020 . b) Test Methods for Evaluating Solid Wastes, SW-846. c) Contract Laboratory Program, IFB methods. ------- Table A-2 Organic Constituent Analysis Results for the Monitoring Well Samples Wayne Disposal Inc., Bellevifle, NI Compounds Detected LOQ FACTORS (a) 1.1,1—Trichloroethafle letrachlorOethefle Toluene Station Value. ugh Value, ugh Value, ugh VOA RHA PEST 06-IA ND b ND ND I X IX 11 OB—4 ND ND ND IX l x IX 06-6 ND ND ND IX IX IX 06-8 ND NO 5. c IX IX 2X 06-9 ND NO ND IX IX IX OB—12 ND 110 ND IX IX l x 08—13 ND ND ND IX 2X LX 06—16 ND ND ND LX LX IX OB-17 ND ND ND LX IX 1X 08-18 8. ND ND IX IX IX 08—19 ND ND ND U IX LX 08—20 8. 12. ND LX l x IX 06-21 ND ND ND IX l x IX 08-22 ND ND ND IX l x IX 06-23 ND ND ND IX IX 11 08—24 ND ND ND LX lx IX 09-25 ND ND ND 1X 1X IX 08—26 35. 32. 10. IX IX l x OB—27 ND ND ND IX 2X 2X 09-28 ND ND ND IX 1X IX OB-29 40. 18. ND l x 2X 11 08-30 ND 5. c ND IX IX IX OB-3 1 ND ND NO IX IX IX means macace. a) Factors are limit of quantitation multiplication factors for the TabL A—4 LOQ5. b) Indicates compound was not detected. c) lass spectra data indicates the presence of a compound that meets the identification criteria but the result Is less than the given fimit of quantitation but greater than zero. ------- Table A-3 Organic Constituent Analysis Results for the Supply, Pond and Drain Samples Wayne Disposal Inc., Belleville , MI Station: MOWS Well MI Disposal Sediment East / West Pond Pond Dr 1n Drain Compound Value (a) Value Value Value Value 1,L.1-TrichlOrOethafle ND b 310. 140 ND ND Chloroform ND 52. ND ND ND Ethylbentefle ND 25. c ND ND ND Tetrachloroethene ND 67. ND ND ND Trichioroethefle ND 130. ND ND ND Toluene ND 340. ND ND ND lylene ND 110. ND ND ND 4-Ilethyl-2-pefltaflone ND 62. ND ND . ND 1,4-Dioxane ND 3,000. c ND NO ND Benzyl alcohol ND 710. ND ND ND Isophorone ND 200. c ND ND ND Benzoic acid ND 1,000. c ND NO ND Phenol ND 5,200. ND ND NO 2-Chlorophenol ND 200. C ND ND ND 2-Methy lphenOl Nfl 200. C ND liD NO 2,4-Dimethyl pheflOl ND 200. c ND ND ND LOQ Factors (d) Volatiles I X 51 IX lx ix SNA Extractable IX 401 LX IX IX Pesticides IX lOX LX IX IX naa a) Concentrations are reported in ugh. b) Indicates compound was not detected. c) Mass spectra data Indicates the presence of a compound that meets the identification criteria but the result Is less than the given limit of quantitation but greater than zero. d) Factors are limit of quantitation multiplication factors for the Table A—4 LOQs. ------- Ba../NiUtra l Co flMfl Ac.na htMrii 1,2 ,4 trfchl0robSrIZSflI l4sx ach orobUnZSA s Kezacp, l Oro .tMflI bIs(2-ChlOr ’osthyl ).th.r 2 -ChloronaPhthil an. 1.2-OIchlOrobsflien. 1. 3O1ch1ofobIflie 1.4- OICh lOrObe nZSf ’e 2.4—DinItrOtO lUefli 2.6—OIni trotG1uui I i,2— O tph.nylhydrll lfl s’ 1uoranther i e 4-Chioropheflyl ph.nyl ether 4-BrOol0pheI Yl phinyl ether bI s(2_ChlorofsoprOpyfl0th 5 bI,(2 _ChlOrOithO).y) thafl0 M.xaChlOrOOutddifln. t4sxaCh I orocyc lop intadI ens I sophoron. NaØitha lens NI trobeflzin s N_eitrOSod SthYla&n.b N—ni trosodi phony I ami rio N —nItrQIOdi r lPI ’ PYlamh 1 5 Bls(2EthytheAYl )p4itrialats Butyl b.nZyl phtPle at. 0l -n-butylphthal ate DInoctyIphtha I tO Di.thy lphthalate D t..thy lphtha lat i B.nzo( a )inthracsn. 3.nzo( a )pyrfls 9.nzo(b ) f 1 uoranth in and/Or 8an10( k)f 1 uoraflth*flS CPirys ins Acenaphthy line AnthreCins 8anzo(g,I i. )PirY le nS Fluorens Pp i en anthr en e Dtb.nZO($. h)anthrlCsns lndSnO(t.Z.3C ,cI)pyrsns Pyrsnl B intidifia 3,3’ -OIchlorOb .uiZIdins Anl lIns 8.nzyl chioridi B.nzy l alcohol p-Ch l or oar ll lfn* Dtb.nzofuran 2-Methyl n. hthO1 5flS 4-Nt troani 11 ne Pentach 1 orobenzefls 1,2.4. 5 -Tetrach lOrOCiflZSnl 1,2.3 ,4 -TetraCiiIOrObSnZefli Pentachlorofll trObeflZSflS 2-M.triy 1 naphthtl ens 2-Nt tr oa ni l triI 3—Nt treai tH n a • Acid Co 0ufløi 2 .4,6-Tr IC%10?OPMfl0l Parach oro taCreIOI 2-Cpu oro ftin01 2 ,4 -OIcPilorOPhSflOl 2 ,4-OtoithyIPhSflOI 2-MI troonenol 4-Ni tropninol 2.4-O initrOPhenOl 4 ,6-OtnItrOOCrSSOl P .nt achlorOph iflO l Phsno 3enz 1C acId 4-Mithyiphiflol (p ’cri$Ol) 2 ’4tethylpheflOl (0-CresOl) 2,4,S-TrICh lOrOPhiflOl Volatfie CompoundS Benz en. BromOd t cfl lOrOlaithifl o 8 romoform Bromoinethafle Carbon Tetrachlortde Ch lorobsflieni C l i I orosthans Chloroform Chior000thane Olbromo cli lOr oit h afle 1. L-0tcn1orve 1. 2-01 ch 10 roe than. 1, 1-Oicfl loroethsni 1,2—01 clil orosthtfl s l.2-OIchIoroPrOP a iS Ethylben zl l ue MetPiyleni cfllorId i 1,1.2 ,2.Tetr.ChlOrOethaf ia Tetrachi oroetlilni Toluens 1.1, 1-1r1ch1orOet s 1.1. 2—TrtCh)OrOSthafl S TrIch lorOethirii ‘IInyl chioridi Acitons 2-ButaneOns (M D) 1.2-Dibromoetnani (EDB) 2- 4sxan0 nS I en., 1 .4-0Io ani 1 ,Z_OIbro .O.2.Ch1Or0Pr0Pan i O Pyridini Acrotulli Acrylonitri l i CarOon lsu1fid5 transt. 3-Qtcn loroeroOi nS cis I ,3-OIchlorOprCPS’S 2-CM orouthylv lfly letlulr Styreni Vinyl acetate 4 -NetnyI-2 -psntanone (MIBk) Pest IC I d.,/PC8 . 10 Aidrifu 20 a lphaBHC 10 bot a— BHC 10 ga a-B$C 10 d eta- BNC 10 C Itlordans 50 4,4-000 50 4,4-DOE SO 4,4 ’- ODT 50 DI. ldr ln 10 Endoaulfan 1 50 Endosulfan It 10 Endosulfan sulfato 10 Endriri 50 Endrln aldehyds K.ptaCh l Or 4.ptachlor .po*Id . Toaaphsni M.tPI OxyCP i lO? Erudrin etone PCB 1016 PCB- 1221 PCB-l2 2 PCB— 1242 PC B- 1248 PC8— 1254 PCB’ 1260 S S 5 10 S S 10 S 10 S S 5 5 S S 5 5 S S S 5 S S 10 50 20 20 20 S 500 100 100 500 500 S 5 S 40 5 40 20 0 05 0 05 0 05 0 05 0 05 05 01 01 01 01 0 05 01 01 01 0 05 0 05 1 0.5 01 S I 1 OS 0.5 1 1 a b a N.aur.d flu A ebeflZWi A-li Table frA UNITS OF OUA$TITATION FOR ORGAMIC COMRGUNOS Wayne Otaposal, Inc., B.llsvIlls, Michigan Limit of Quantttat lon ( g/t) Quant ltatlon ( ,ig/2) Quanti tatlon (iig/t) 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 20 10 10 10 NA 40 20 40 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 P tA 100 10 10 20 100 10 10 100 10 10 10 10 10 100 L00 N.aiw’od ii, daphnyiaauI . Not Ana1yn .d ------- a Concentrations are reported In ugh. b Sample concentration Is less than X at 99% confidence. c — Control measures Indicate value is within 75% to 125% of actual the dissolved concentrations are often biased high. d • Control measures Indicate value s within 50% to 150% of actual the dissolved concentrations are often biased high. e Control measures indicate value was not quantified. concentration at 95% confIdence and concentration at 95% confidence and F•.) 08-01 Dissolved Total Value (a) Value (30. b 94. d e e ( 17. ‘ 8. 60. c 57. d Table A-S Dissolved and Total Metals Analysis Results for the Monitoring Well Samples Wayne Disposal Inc., Belleville, MI 08-04 Dissolved Total Value Value < 30. 58. d e e ‘ 16. ‘ 7. 75. c 60. d Element Al Sb As Ba Be Cd Co Cr Co Cu Fe Pb Mg Pin Hg NI c i < 2. ( 12. 159,000. C 7. C 5. C 5 < 26. < 6. 08-06 Dissolved Total Value Value <30. (41. e e 7. c 8. c 154. c 149. d ‘ 2. C 13. 187,000. c C 15. C B. 23. c 262. d ‘ 14. 5,520. d 27. C C .1 < 12. < 2. C 12. 14,000. C 7. C C 5. < 26. C 5. 13 ,100. < 6. C .1 ( 10. d d C d 13. 12. < 13. 22,100. d . 21,000. C 15. C 7 C 15. <8. C 12. (5. C 5 (8. C 12. C 120. 50. c C 120. C 5. C 6. C 11,600. d C 8. ( .1 < 12. 5,190. 23. d d 7. C .1 d 10. C .1 c C .1 ( 10. C 12. C 10. K Se C 3,200. 4. C 2,700. C 13. < 3.200. C 5• C 2,700. C 14. e C 3,200. C 5. <7. C 2,700. C 11. e Ag Na J. 115,000. d e 109,000. c 42,100. d 37,200. c 35,100. d 32,900. c Tl C 7. C 6. < 6. ( 5. C 130. ‘ 5. < 130. < 8. C 130. Sn C 130. ( 130. ( C 7 C 6. C 7. V C 6. ( 7. 1,290. C 67. d 169. c Zn 349. C 522. C 115. C ------- Table A—5 (continued) Dissolved and Total Metals Analysis Results for the Monitoring Well Samples Wayne Disposal Inc.. BellevIlle, 141 08-08 Dissolved Total Value (a) Value <30, b (41. e e <7. (7. 197. c 178. d 08-09 D sso1ved Total Value Value 30. 446. d e e <6. <8. 97. c 94. d Element Al Sb As Ba Be Cd Ca Cr Co Cu Fe Pb Mg Mn Hg NI d C 2. < 12. 31,800. C 7. C 5. C 5. < 26. ( 5. 08-12 Dissolved Total Value Value c 30. 113. d e e <9. <9. 154. c 155. d ( 2. ( 13. 28,600. C C 15. < 8. 12. < 120. ( 12. d C 2. C 12. 25.100. C 7. C 5. < 5. C 26. < 5. ( 2. < 13. 27,800. C 15. C 8. C 12. 905. 16. C d d C 2. ‘ 12. 39,800. d C 1. C 5. C 5, C 26. 6. ( 2. < 13. 40,400. < 15. ( 8. ( 12. 345. < 5. C d 16,400. 12. d d 15,500. 12. C .1 d c ‘ 6. < .1 20. C .1 C 55. C .1 d 70. ‘ .1 < 12. c C .1 < 12. < 10. < 12. < 10. < 10. < 2,700. < 3,200. C 2,700. K Se C 3,200. < 5. C 2,700. ‘ 11. e C 3,200. < 6. (7. C 12. e 5. (7. C 10. e c Ag Na <7. 23,500. d 19,800. c 31,100. d 30,800. 8. c 24,700. C 5. d 23,500. < 9. Ti < 5. ‘ 8. (130. < 5. (130. <130. <130. (130. 7. Sn <130. C 7. ( 6. ( 7. C 6. 450. c V C 6. C 153. C 3,600. C 59. d Zn 309. C a = Concentrations are reported In ugIL. b Sample concentration is less than I at 99% confldenCe. c — Control measures Indicate value Is within 75% to 125% of actual the dissolved concentrations are often biased high. d Control measures Indicate value Is within 50% to 150% of actual the dissolved concentrations are often biased high. e Control measures Indicate value was not quantified. concentration at 95% confidence and concentration at 95% confidence and ------- Table A-S (continued) Dissolved and Total Metals Analysis esults for the Monitoring Well Samples Wayne Disposal inc., BellewUle , MI a • Concentrations are reported in ug/L. b Sample concentration is less than X at 99% confidence. c • Control measures Indicate value Is within 75% to 125% of actual the dissolved concentrations are often biased high. d Control measures Indicate value Is within 50% to 150% of actual the dissolved concentrations are often biased high. e Control measures Indicate value was not quantified. 00—13 OB-IS GB- I l Element Al Sb As Ba Be Cd Ca Cr Co Cu Fe Pb Mg Hg Ni K Se Ag Na 11 Sn V Zn < 2. ‘ 13. 78.900. ( 15. C B• 15. 6.316. C 1 • C 5. C < 26. C 6. 12,200. d 7. d ( .1 C 10 < 2. C 12. 40.100. C C ( 5. 37. C 5. Dissolved Total Dissolved Total Dissolved Total Value (a) Value Value Value Value Value C 30. b 1,830. d C 30. 2,360. d < 30. C 41. e P e e e e C 7. C 9. ( 7. 6. c ‘ 17. C 7. 110. c 128. d 146. c 156. d 210. c 200. d < 2. ‘ 12. 30,000. d c d c d C 7. C d c d c 31,400. 185. C .1 12. d c 13,400. 41. C .1 C d d 37,400. 260. ‘ .1 ( 12. d c 20,500. 15. ‘ .1 C 10. d d 19,000. 16. C .1 < 12. d c < 3,200. ( 6. < 2,700. < 11. < 3,200. ( 6. 2,750. C 14. d C 3,200. < 5. < 2,700. C 14. <7. e <7. e <7. e 27,300. 27,300. C 23,600. d 24,200. c 14,800. d 13,500. ( 2. C 13. 110,000. C 15. 8. C 12. 1,586. C 16. C 2. C (2. 59,100. C 7 C 5 C 64. C 5. < 2. C j3 57.400. C 15. ( 8. 21. 996. ‘ 8. d C C d C 5 C 130. C 6. 41. d C 8. C 130. 7. C 285. C C C 130. < 6. 118. C C < 8. C 130. 10. C 436. C concentration at concentration at C ( 130. C 7. 283. C < 6. C 130. C 6. 81. d confidence and confidence and 951 951 ------- Table A-S (continued) Dissolved and Total Meta’s Analysis Results for the Monitoring Well Samples Wayne Disposal Inc.. Qelleville, M l a Concentrations are reported In ugh. b Sample concentration is less than X at 99% confidence. c Control measures indicate value is within 75% to 125% of actual the dissolved concentrations are often biased high. d Control measures indicate value is within 50% to 150% of actual the dissolved concentrations are often biased high. e Control measures indicate value was not quantified. concentration at 95% confidence and concentration at 95% confidence and I-J (ii Dissolved Total Element Dissolved Value (a) Total Value Dissolved Value Total Value d Value C 30. Value 129. d Al Sb As Ba 83. e < 8. 69. c c 283. e < 8. 67. d d C 30. e < 17. 92. b C e < 8. 86. d e C 7. 163. c e < 7. 169. d Be Cd Ca Cr C 2. C 12. 8,380. < 7. d C 2. C 13. 8,990. < 15. C < 2. < 12. 9,690. 7. d ( 8. C d C 5. < 8. c Co Cu Fe Pb C 5. < 5. 194. C 6. c ‘ 8. C 12. 506. C 5. d C 5. C 5. C 26. C 5. 29. 270. ‘ 12. C d d 5. C 26. C 5 d C 12. 318. 12. Mg Mn Hg Ni 2,150. 14. < .1 C 12. d C 3,570. (8. < .1 < 12. C 13. 13,300. C 15. C 2. C 12. 31,800. ( 7. C 2. .. C 13. 33,000. C 15. 2,550. d 8. d < .1 ( 10. K < 3,200. Se C5 Ag <7. Ha 104,000. d Tl <6. Sn < 130. V ‘6. Zn 5. d C C d d 2,840. C 9. e 94,100. C 7. ‘ 130. C 7. ‘ 13. 2 970. d C 6. C .1 C 10. C 3,200. C 4. C 7. 101,000. d C 6. C 130. C 6. 11. d C C 2,700. C e 93,800. C 6. C 130. C 7. 236. C 20,300. C 6. C .1 C 10. 4,140. d C 5, C 7. 16,800. d C 5. C 130. ‘ 6. 167. C 20,200. d 9. C C .1 C 12. 4,300. C C 10. e 14,800. c < 8. < 130. C 7. 770. C ------- Table A-S (continued) Dissolved and Total Metals Analysis Results for the Monitoring Well Samples Wayne Disposal Inc., Belleville, NI a Concentrations are reported in u IL. b • Sample concentration is less than X at 991 confidence. c — Control measures Indicate value Is within 751 to 1251 of actual the dissolved concentritions are often biased high. d Control measures Indicate value Is within 501 to 1501 of actual the dissolved concentrations are often biased high. e Control measures indicate value was not quantified. concentration at 95% confidence and concentration at 951 confidence and ft U- Dissolved Total Value (a) Value 30. b C 41. e e <6. 8. 223. c 213. d 00-22 Dissolved Total Value Value ( 30. 295. d e a C 17. < 7. 141. c 145. d 08-23 Dissolved Total Value Value ‘ 30. 128. d a e ‘8. ‘8. 154. c 146. d Element Al Sb As Ba Be Cd Ca Cr Co Cu Fe Pb Mg Mn Hg NI K Se Ag Ha Sn V Zn C < 2. C 12. 71,900. ii C C 5• C 1,260. c C 10. 21,300. d 24. d ‘ .1 C 10. C 3,200. ( 6. C 7. 16,200. d 6. 130. ‘ 6. C 3. C 2. C 13. 68,700. c C 15. 8. C 12. 1,406. d C 11. 21,000. d 25. C ‘ .1 C 12. ( 2,100. C 13. e 15,900. C C 9• C 130. C 7. C 13. d C C C 2. C 12. 41,500. d C C C 150. C C 5. 15,600. d 20. d C .1 C 10. 5,050. d C 4 C 57,400. d C 6. C 130. C 6. C 3. ‘2. ‘2. c2. < 13. < 12. .• < 13. 44,300. 94,100. 90,200. C 15. C 7. C 15. C 8. < 5. ‘ 8. 26. c ‘ 5. c 12. 720. d 908. 1.696. d C 10. ‘ 7. C 19. 15,000. d 28,900. d 28,100. d 28. C 24. d 30. c C .1 C .1 ‘ .1 C 12. < 10. C 12. 5,890. C C 3.200. C 2.100. C 13. C 6. ( 12. e <7• a 54,100. c 16,900. d 16,100. c ‘ 5. C 6. c C 130. < 130. ‘ 130. (1. <6. l. 13. 5. d 30. d ------- Table A-S (continued) Dissolved and Total Metals Analysis Results for the Monitoring Well Samples Wayne Disposal Inc., Bellevifle. MI a Concentrations are reported in ugh. b Sample concentration Is less than X at 99% confidence. c Control measures indicate value is within 75% to 125% of actual the dissolved concentrations are often biased high. d — Control measures indicate value is within 50% to 150% of actual the dissolved concentrations are often biased high. e - Control measures Indicate value was not quantified. concentration at 95% confidence and concentration at 95% confidence and ( 2. < 12. 52 ,400. ( 7. < 5. < 5. 45. C 5. ‘ 2. C 13. 55,500. C 15. C 8. c 12. 2 ,226. C 7. C 2. < 12. 34,200. C 7. C 5. C 5. 72. C 6. 08—24 Total Element Dissolved Value (a) Total Value Dissolved Value Total Value Value 48. c Value 49. d Al Sb As Ba C 30. e C 8. 154. b C 1,140. e C 8. 162. d d < 30. e C 7, 137. C 96. e C 8. 133. d d e C 9. 122. C e C 8. 132. C 2. d d c d c d < 13. 8,760. C 15. ( 8. c c d c d ( 12. C 120. C 12. 4,950. d 15,600. 37. C .1 C 10. d d 16,600. 65. C .1 12. d c 14,100. d ii. d C .1 C 10. 13,800. 13. C .1 C 12. d c ‘ 8. C .1 C 12. c c 3,200. C 6. 7. 15,900. d ‘ 2,700. C 12. e 14,600. c < 3,200. < 5. <1. 27,200. d C 2,700. 10. e 25,800. c c Be Cd Ca Cr Co Cu Fe Pb Mg Mn 119 Ni K Se Ag Na TI Sn V in C 2. C 13. 32,900. C 15. C 8. C 12. 472. C 5. C 2. C 12. 6,400. C 7. C 5. C 5. C 26. C 5, 4,980. d C 6. C .1 C 10. 7,960. d C 7. C 36,800. d 5. C 130. ‘ 6. 11. d C 8. C 130. C 1. 14. d C 130. C 130. C 130. ‘ 6. ‘ 7. ( 6. 7. d 28. d 16. d 7,250. C 10. e 35,300. C 8. C 130. C 7 C 13. ------- a Concentrations are reported n ugh. b Sample concentration Is less than X at 99% confidence. c • Control measures Indicate value Is within 75% to 125% of actual the dissolved concentrations are often biased high. d Control measures Indicate value is within 50% to 150% of actual the dissolved concentrations are often biased high. e Control measures Indicate value was not quantified. concentration at 95% confidence and concentration at 95% confidence and 1 Table A-S (continued) Dissolved and Total Metals Analysis Results for the Monitoring Well Samples Wayne Disposal Inc., Belleville, M I Element Al Sb As Ba Be Cd Ca Cr ( 2. 13. 36,700. C 15. Co Cu Fe Pb ( 2. < 12. 16.800. ( 7. C 8. C 12. 840. ( 10. 2. C 13. 17,000. C 15. 05—26 08-29 Dissolved Total Dissolved Total Dissolved Total Value Value (a) Value Value Value Value ‘ 30. b C 41. ( 30. 116. d C 30. e 110. e d e e e e ‘ C ( 1. C 8. C 7. 7. 180. d 122. c 117. d 137. c 136. d C 2. . C 12. ci c 38,800. d C d c C 7• c ci d d ci 11,300. 18. ‘ .1 ‘ 12. d c 8,510. (6. C .1 C 0. d 8,660. (8. ‘ .1 C 12. d 11,600. 20. C .1 ‘ 10. d d d C C 3,200. C C 7 C 5. C 5. C 26. C 10. C 2. C 12. 26.100. C 7. C 8. C 12. 300. C 10. ( 2. ‘ 13. 25,800. C 15. C 5• C 5 26. ‘ 5. C 2,700. C 10. e 42,200. C 8. C 12. 262. 12. C 5. C 5. 32. C 6. Mg Mn 11,600. 15. d ci 10,300. 26. < .1 ci C Hg Ni C .1 C 10. C 12. K Se C 3,200. ‘ 6. C 2.700. C 14. e Ag Na <7. 43,700. ci c d C d 57,600. c Ti Sn V Zn ‘6. c 130. ‘ 6. 52. ci C (8. 130. C 7. 109. C C ‘6. 130. C 6. 28. d (10. C 130. C 1. IS. d C <6. 130. ( 6. 684. C ‘6. C 130. ‘ 7. 1.500. c 6,220. C 5. C 7 49,700. 6,440. C 11. e 41.000. ------- Table A-S (continued) Dissolved and Total Metals Analysis Results for the Monitoring Well Samples Wayne Disposal Inc., Belleville, HI OB-31 Dissolved Total Element Value (a) Value Al < 30. b 4,910. d Sb e e As < 17. ( 7. Ba 95. C 123. d Be < 2. < 2. Cd < 12. 13. Ca 9,930. d 20,800. c Cr < 7. 15. Co <5. (8. Cu 6. d 12. Fe 26. 4,966. Pb < tO. 82. d Hg 5,410. d 8,120. d N f l ‘ 6. 73. c Hg ‘ .1 ‘ .1 Ni ( 10. C 12. K 3•670. d 5,980. c Se ‘ 4. C 13. Ag ‘7. e Na 54,500. d 47,900. c Ti < 6. ( 5. Sn C 130. < 130. V <6. 14. c Zn 70. d 3,420. c a Concentrations are reported in ugh. b Sample concentration is less than X at 99% confidence. c Control measures indicate value is within 75% to 125% of actual concentration at 95% confidence and the dissolved concentrations are often biased high. d Control measures indicate value Is within 50% to 150% of actual concentration at 951 confidence and the dissolved concentrations are often biased high. e Control measures indicate value was not quantified. ------- 0 NUllS Well Dissolved Total Value (a) Value 30. b ‘41. e e <8. (10. 149. c 146. d Element Al Sb As Ba Be Cd Ca Cr Co Cu Fe Pb 14g Mn Hg Ni c 2. ( 13. 90,400. ( 7. < S. ( 5. 72. ( 7. SedIment Pond Dissolved Total Value Value ( 30. 1,150. d e e <18. ‘B. 63. c 62. d d C ‘ 2. ( 13. 85.500. ( is. ‘ 8. C 12. 1,566. 16. C d Table A-6 Dissolved and Total Metals Analysis Results for the Supply, Pond and Drain Samples Wayne Disposal Inc., Belleville, MI Michigan Disposal Pond Dissolved Total Value Value 59. c 536. d e e ‘ 19. 12. c 84. c 10. d ‘ 2. < 2. C 13. < 13. 111,000. d 110,000. C 69. c 181. c 20. c 17. c 116. c Li. d 19,800. d 18,300. d 133. d 176. C .1 .2 d 253. c 244. C 78 100. d 66,400. C (9. 6. d 7. e 268,000. d 238.000. C C 19. < B. < 130. C 130. 6. <7. 189. C 810. c C 2. < 13. 96,700. C 1. 18. 152. 1,136. 154. d C C C d C C 5. 1. 26. C 8. 28. d 26. c ‘ .1 ( .1 ( 10. C 12. K Se ( 3,200. 7. 1. C 2,700. C 13. e Ag Na 15,000. d 14,100. C Ti C 6. 130. C < 130. Sn <6. (7. V 14. d 49. d Zn ‘2. ( 13. 85,500. C C iS. C 8. ‘ 12. 1,456. d ‘ 8. 16,900. d 66. C C .1 C 12. 6,160. C C 11. e 34,300. C C 1. C 130. C 7. 24. d 19,200. d 52. d C .1 C 10. 7,010. d 3. d C 7. 40,300. d C 16. ( 130. C 6. 16. d a Concentrations are reported in ugh. b — Sample concentration Is less than X at 99% confidence. c Control measures Indicate value is within 15% to 125% of actual the dissolved concentrations are often biased high. d • Control measures indicate value Is within 50% to 150% of actual the dissolved concentrations are often biased high. e Control measures indicate value was not quantified. concentration at 95% confIdenCe and concentration at 95% confidenCe and ------- Table A-6 (continued) Dissolved and Total Metals Analysis Results for the Supply, Pond and Drain Samples Wayne Disposal Inc., Belleville, III £ lement Al Sb As Ba Hg Mn Mg NI K Se Ag Na Tl Sn V Zn East Edge Drain Dissolved Total Value (a) Value 30. b 3,180. d e e (8. 8. 70. c 81. d 21,600. d 119. d ( .1 ‘ 10. ‘ 3,200. < 5. ( 7. 12,000. d < 6. ( 130. 6. 15. d 23,700. 186. ‘ .1 < 12. 3,140. C C 15. e 12,300. c 8. C 130. 8. C 15. d West Edge Drain Dissolved Total Value Value C 30. C 41. e e 7. C 7• 33. C 31. d 16,500. d 440. d ( .1 C 10. C 3.200. C 6. C 1. 6,490. d C 5. C 130. C 6. 8. d 16,400. d 420. C C .1 C 12. C 2,700. C e 6,730. C C 9. C 130. C 7• C 13. a Concentrations are reported in ug/L. b • Sample concentration is less than X at 991 confidence. C Control measures indicate value is within 15% to 125% of actua’ concentration at 951 confidence and the dissolved concentrations are often b sed high. d Control measures indicate value is within 501 to 150% of actual concentration at 951 confidence and the dissolved concentrations are often biased high. e Control measures indicate value was not quantified. Be ‘ 2. Cd C 13. Ca 136,000. Cr < 7. 0 Co Cu Fe Pb < 2. C 13. 142,000. C 15. C 8. < 12. 5,066. C 15. C 5. C 5. 26. C 6. C 2. C 13. 128,000. C 1. C 5. C 5 1,150. C 6. C d d C d c C 2. C 13. 121,000. ( 15. C 8. < 12. 1 .230. C 12. C d ------- Table A-i Field Heasurements and General Constituent Analysis Results for the Honitoring Well Samples Wayne Disposal Inc.. Belleville. MI Station: OB-IA 08-4 08-6 OB-8 08-9 08-12 08-13 0B 16 Parameter Units Value Value Value Value Value Value Value Value pH (a) Units 8. 8.1 7.9 8.3 8.3 7.8 8. 7.6 Conductance (b) umhos/Cm 340. 330. 310. 390. 370. 400. 360. 420. POX (c) ug/1 Cl 5. e < 5. < 5. ‘ 5. C 5. < 5. < 5. < 5. NPOC (d mg/I C 5.1 2. 3.6 9.8 2.6 5. 5.8 2.1 Amonia mg/I H < .4 .4 < .4 C •4 C •4 < .4 < .4 < .4 Phenol ugh C 40. <40. < 40. < 40. C 40. C 40. C 40. C 40. naa=na = =fl flflflS a) Control measures Indicate values are within 0.5 units. b) Control measures indicate values are within 75% to 125% of the actual value. c) Control measures indicate values are biased low by as much as 30% or 20 ug I. d) Values are of unknown reliability because of the lack of field blanks and a large variability in the field triplicate sample values. e) Sample concentration Is less than X at 99% confidence. ------- Table A-i (continued) Field Measurements and General Constituent Analysis Results for the Monitoring Well Samples Wayne Disposal Inc., bellewille, Ml St t.i0fl; O 17 0B18 0B19 OB20 00-21 0B22 0 023 0B24 Parameter Units Value Value Value Value Value Value Value Value pH (a) Units 7.8 8.3 7.8 9.3 6.8 7.2 7.4 7.8 Conductance (b) umhoslCm 340. 430. 490. 310. 590. 510. 670. 450. POX (c) ugh Cl ‘5. e <5. <5. <5. <5. (5. <5. 5. NPOC (d) mg/I C 3.3 2.1 2.1 5.4 3.1 4.5 1.5 1.6 ArTI onia mg/I N < .4 C •4 ( .4 NA f < .4 ‘ .4 < .4 .4 Phenol ugh. ( 40. ‘ 40. < 40. NA C 40. 40. < 40. . < 40. c eases 5 gssn a cn saaSfltflfl Scan n nc nnana•ne s a) Control measures 1nd cate values are within 0.5 unIts. b) Control measures indicate values are within 75% to 125% of the actual concentration. c) Control measures indicate values are biased low by as much as 30% or 20 ugh. d) Values are of unknown reliability because of the lack of field blanks and a large variability in the field triplicate sample values. e) Sample concentration is less than I at 99% confidence. f) indicates parameter was not analyzed. ------- Table A-i (continued) N) Field Measurements and General Constituent Analysis Results - for the Monitoring Well Samples Wayne Disposal Inc., Belleville, HI St 5tlon: 08-26 OB-27 OB-28 08-29 08—30 08-31 Parameter Units Value Value Value Value Value Value Value p 11 (a) Units 8.2 9.2 8.8 1.5 7.7 9.3 9. Conductance (b) umhoslcm 380. 280. 330. 370. 420. 510. 290. POX (c) ugh Cl 5. e 35. <5. 5. 27. 13. ‘5. NPOC (di mg/I C NA f 2.3 NA 3.1 5.6 5.9 4.7 Amonla mg/I N ‘.4 .4 NA < .4 NA .4 < .4 Phenol ugh ( 40. C 40. NA C 40. NA ( 40. . ( 40. a) Control measures indicate values are within 0.5 units. b) Control measures Indicate values are within 751 to 125% of the actual concentration. c) Control measures indicate values are biased low by as much as 30% or 20 ug/L. d) Values are of unknown reliability because of the lack of field blanks and a large variability in the field triplicate sample values. e) Sample concentration is less than X at 99% confidence. I) Indicates parameter was not analyzed. ------- Table A-8 Field Measurements and General Constituent Analysis Results for the Supply. Pond and Drain Samples Wayne Disposal Inc., Belleville, 141 Station: MOWS Disposal Sediment East Edge West Edge Well Pono Pond Drain Drain Parameter Units Value Value Value Value Value p14 (a) unIts 7.6 8. 8. 6.9 6.8 Conductance (b) umhos/cm 670. 2100. 570. 940. 180. POX (c) ugh Cl < 5. e NA f < S. 5. 5. NPOC (d) mg/I C 3.5 180. 5.2 3.7 3.4 Armnonla (b) mg/L N < .4 25. < .4 < .4 .4 Phenol (0) ugh < 40. 12000. ( 40. C 40. C 40. a) Control measures indicate values are within 0.5 units. b) Control measures indicate detectable values are within 75% to 125% of the actual value. c) Control measures indicate values are biased low by as much as 30% or 20 ug/L. d) Values are of unknown reliability because of the lack of field blanks and a large variability In the field triplicate sample values. e) Sample concentration Is less than X at 99% confidence. f) Indicates parameter was not analyzed. N.) ------- A-26 Table A-9 Organic Constituent Analysis Results for the Disposal Cell Leachate Samples Wayne Disposal Inc.. Belleyllle, MI Stat Ion: MC-5 ACE NC—S B NC-i AB MC-7 C NC-li ABC Compound Value (a). Value Value Value Value Benzene 25. c NO b ND 7. 25. Chlorobeflzefle 25. C NO MO ND 25. l,4 _Olchlorobenzene ND MD ND o 10. C I,l,l.Trichloroethafle ND ND 770. 13. ND l,1 —Dich loroethane ND 910. 2,600. 10. NO Chloroform ND ND ND S. c ND Trans_l,2 _OiChlOrOethene 25. C ND NO NO 25. c EthylbenZefle 86. 250. C NO 5. c 67. Tetrachioroethefle NO MD NO 5. C MO Toluene 300. 2,600. 2,100. iS. 170. TrlchloroetPlene MD 250. C 460. 5. C NO Xylene 350. 400. 530. 7. 410. 1,4—D loxane 2,500. 80,000. 50,000. 7,000. 2,400. 4 —Methyl-2 pentaflOfle 1.300. 11,000. 17,000. 300. 20,000. TettahydrOfUran ND MD MO MD 20,000. Acenaphthefle N!) ND ND ND 10. c Fluoranthefle NO ND ND ND 12. Bls(2—EthYlheXY1) Phthalate ND MD ND MD 65. Di -n. B utylphtha late NO ND ND NO 10. C D1 -n—OctylPhtha late ND NO ND ND 13. Benzo(A)aflthraCefle ND ND NO P lO 10. c Benzo(B) and/or Benzo(K)flUOraflthene ND MO ND NO 10. c Chrysene ND ND MD ND 10. c Acenaphthylefle D ND ND P lO 10. c Anthracene NO ND ND MD 10. C Flourene NO ND ND ND 13. Phenanthrefle ND ND ND MD 32. Pyrene NO ND NO ND 11. DibenzOfur&fl ND ND ND ND Ii. Isophorofle ND ND 1,000. c NO ND Naphthalefle 200. c ND ND NO 210. Benzyl alcohol MD 130,000. 28,000. 2,900. MD 2 Methyl-naphthalefle ND ND ND ND 15. Benzolc acid 12,000. 520,000. 200,000. ND NO phenol 1,100. 19,000. 140,000. 89,000. 190. 2-Methyipheflol ND NO 21,000. ND 380. 4-MethylpheflOl 3,200. 25,000. 46,000. 10,000. C 380. 2,4 -D1methylPheflOl 1,000. 5,000. c 15,000. MD s o. 2,4 -DiChlOrOPheflOxY acetic acid NO 440. 80. MD NO LOQ Factors (d) Volatiles SX 50X box IX SX Base/Neutral Extractablo 20X 200X 400X 400X 2X Acid Extractable 40X 900X 1600X 1600X 4X Pesticides lox ioox lx lox lOX a) Concentrations are reported in ug/L. b) Indicates compound was not detected. c) Mass spectra data indicates the presence of a compound that meets the identification criteria but the result Is less than the given limit of quantitatlOfl but greater than zero. d) Factors are limit of quantltatiOfl multiplication factors for the Table A—4 LOQ5. ------- Table A-jo Total Metals Analysis Results for the Disposal Cell leachate Samples Wayne Disposal inc.. Belleville. MI a Concentrations are reported in ugh. b — Sample concentration Is less than X at 99% confidence. c Control measures indicate value is within 75% to 125% of actual d • Control measures Indicate value Is within 50% to 150% of actual e — Control measures Indicate value was not quantified. concentration at 95% confidence. concentration at 95% confIdence. Element Al Sb As Ba Be Cd Ca Cr Co Cu Fe Pb 149 Mn Hg NI K Se Ag Na Ti Sn V Zn NC—S ACE NC-S B Total Value (a) Total Value Total Value Total Value Total Value 4,120. e 110. 470. d c d 5,500. e 150. 1,080. d c d 11,200. e 17,100. 403. d c d 1 .490. e 190. 386. d c d 2,520. d e < 70. b 391.. d (20. ( 130. 132,000. 255. c d (20. C 130. 281,000. ‘ 150. C <20. < 130. 292,000. 248. c d (20. ‘ 130. 199,000. ( 150. c (20. C 130. 68,200. c ‘ 150. C 83. < 120. 10,600. 64. d. d 226. 139. 26,600. C 100. c d d 588. 1,444. 31,400. 956. c c d C 101. 319. 6,400. 310. c C d c C 83. < 120. 11,800. d 220. c 79,500. 345. < 1. 2,500. d C c 31,100. 846. ‘ 1. 26,800. d C c 89,500. 413. 1.1 15,800. d C d c 24,000. 2,150. 1.2 1,100. d C d c 203,000. d 370. c < 1. 800. 1,330,000. C 80. c 3,430,000. 190. c 1,390,000. 120. C d < 100. e C 80. e 2,030,000. e C 8,840,000. e c e 8,470,000. c 1,350,000. C 1.960,000. C 90. C 1,300. 140. C 424. C C C c C 130. C 1,300. C 1,300. 1,300. ( 71. C 71. 190. c C 4,300. c 3.650. c 859. c 991. c F ) ------- Table A-li f’.) 6eneral Constituent Analysis Results for the Disposal Cell leachate Samples Wayne Disposal Inc.. Bellevflle. MI Station: MC-5-ACE MC5B MC7AB MC-7-C NC-il-ABC Parameter Units Value Value Value Value Value POX (a) ugh Cl ‘ 500. e 1000. 22800. ( 500. ‘ 500. lox (b) ugh Cl 1120. 10100. 12000. 1280. 2040. NPOC (c) mg/L C 1400. 12700. 7800. 1210. 657. Anmionia (d) mgIL N 870. 865. 755. 11. 760. Cyanide (b) ugh CN- 13. 2140. 77100. 81. 22. Phenol (d) ugh 3700. 370000. 195000. 178000. 810. ncna.asnsncaCCCSSCSZflflaC 3CCfl nga s OflS . aacssnflfl3CCaaCS5flflflflCSSBaSSCfla a) Control measures indicate values are biased low by as much as 30%. b) Control measures indicate values are biased low, often by as much as 50%. C) Values are of unknown reliability because of the lack of field blanks and a large variability in the field triplicate sample values. d) Control measures Indicate values are within 75% to 125% of the actual concentration. e) Sample concehtratton was determined to be less than X. ------- |