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AR226-2536 ATTACHMENTI VERIFICATION INVESTIGATION WORKPLAN E. I. Ou Font de Nemours & Co. Washington Works February 9, 1990 #560-1 CF031556 EID480934 VEBIgICATIOM INVgSTIGATION 1.0 INTRODUCTION 1.1 objective 1.2 Scope 2.0 SITE DESCRIPTION AND HISTORY 2.1 Site Background and History 2.2 Geological and Hydrologic Conditions 3.0 BACKGROUND AND WASTE CHARACTERIZATION 3.1 A-l Du Pont Local Landfill 3.1.1 Current and Historical Background Conditions 3.1..2 Waste characterization 3.2 A-3 River Banie Landfill \ 3.2.1 Current and Historical Background Condition 3.2.2 Waste Characterization 3.3 B-4 Anaerobic Digestion Ponds 3.3.1 3.3.2 Current and Historical Background Conditions Haste Characterization 3.4 F-ll Injection Wells Wo. 1 and Ho. 2 3.4.1 3.4.2 Current and Historical Background Conditions Waste Characterization 3.s H-14 Burning Grounds 3.5.1 3.5.2 Current and Historical Background Conditions Waste Characterization PAGE 8 16 16 16 17 17 17 2S 25 25 38 38 38 39 CF031557 EID480935 3.0 BACKGROUND AND WASTE CHARACTERIZATION (Cont.) 3.6 C-6 Polyacetal Waste incinerator 39 3.6.1 Current and Historical Background 39 3.6.2 Waste Characterization 39 3.6.3 Combustion Product Characterization 42 4.0 RCRA VERIFICATION INVESTI6ATIOH - SCOPE OP WORK 4.1 Hydrogeologioal verification Program 44 4.2 A-l Du Font Local Landfill 51 4.2.1 Soil Sampling Program 51 4.2.2 firoundwater Investigation 52 4*2.3 Leaehata Sampling Program 52 4.3 A-3 River Bank Landfill 52 4.3.1 Soil Sampling Program 52 4.3.2 Groundwater investigation 53 4.3.3 Leachate sampling Program 53 4.4 B-4 Anaerobic Digestion Ponds 53 4.4.1 Soil Sampling Program 53 4.4.2 Sroundwater Investigation 54 4.5 H-14 Burning Grounds 55 4.3.1 Groundwater investigation 55 4.6 C-6 polyaeetal Incinerator Test 55 4*6.1 Emission Sampling 55 4*6.2 Emission Analysis 56 CB-031558 EID480936 List of figures ITOMBSB 1 Facility Location Map 1A Facility SWMU Location Map 2 Generalized Stratigraphic Column 3 Pond 1 - Cere Analysis 4 Pond 2 - cere Analysis 5 Pond 3 - core Analysis 6 Waste well Mo. 1 - Drilling Log 7 Waste Well Me. 1 " Well Construction Diagram 8 Waste Well No. 2 ' Well construction Diagram 9 Waste Well No. 2 - Geophysical Logs 10 Map Indicating Location of Polyacetal Product Incinerator 11 Proposed Sampling Location Map for SWMtT A-l Local Landfill 12 Proposed Sampling Location Map for SWMU A-3 River Bank Landfill 13 Proposed Sampling Location Map for SWMU B-4 Anaerobic Digestion Ponds 14 Proposed Sampling Location Map for SWMCJ H-14 Burning Grounds PAGE 3 4 5 20 21 22 27 28 29 30 40 45 46 47 48 CB-031559 EID480937 LIST OF TABLES NUMBER 1 Description of Geologic Units 2 solid Waate Types Disposed in the Local Landfill 3 Suaaary of Leaehatee Analytical froa the Local Landfill 4 Test Well 27 - State Analytical Fona 5 Test Well 25 - State Analytical Fom 6 Well 331 ~ State Analytical Form 7 Suianary of the Loeal Landfill Shelby Tube Analyses 8 Pond l - pre-excavation Analytical Results 9 Single Sample Analysis After Sludge Renoval 10 SUirunary of the Waste Composition In the Anaerobic Digestion Ponds 11 Suimnary of the Monitoring Well Data for the Waste Injection Wells 12 Monitoring Well Analyses - combined BlennerhasBett island Wells 13 Monitoring Well Analyses - Well #20 14 Monitoring Well Analyses - Well #23 15 Monitoring Well Analyses " Well #307 16 Monitoring Well Analyses - well WOO-577 Red 17 EPA Constituent r,i8t 18 SuMmary of Sampling Media PASE 10 11 12 13 14 15 23 23 24 31 32 33 34 33 36 49 50 CF031560 EID480838 APPENDICES Title A Injection Well Summary Local and Regional Geology Structural Features Page 1 2 16 B Quality Assurance/Quality control Plan 1 See Index in Appendix C QA/QC: Polyacetal Product Incinerator Emission Testing 1 1 Quality Assurance Plan 2 See Index in Appendix 2 Sample Collection Methods and Procedures Plan 57 D Community Relations Plan 1 E Health and Safety Plan 1 see index in Appendix F References A-l Local Landfill Soil Characteristic Tests 1 Analytical Data Taken from B-4 Anaerobic Digestion ponds During Closure 23 Supernate Ponds - Analysis of Core Samples 24 Addendum; Supemato Pond Samples Analysis 31 jfl& Triton1311 X-100 in upstream Supernate Pond sludge 32 No 1 Supernate Pond Sludge Analysis 33 ^r Analysis of Supernate Sludge Samples for c-8 36 pennslyvania Drilling Company Test Borings 37 Supernate Pond Soil Samples, 3/30/88 41 Zinc Content of Upstream Supernate Pond Sludge 42 Letter, A. C. Hustsn to D. W. Robinson, MVDNK 43 Zinc Content of Soil Samples 47 Upstream Supernate Pond Composite Sidge Srnpl Anal 48 Supernate Pond Soil Samples, 5/27/88 SO Supernal Pond Soil Samples, 1/9/89 51 Supernate Pond Amount of soil Excavated 52 P-ll Special Reports for Waste Well No. 1 and 2 53 Washington Works No. I Waste Disposal Well 54 Washington Works No. 2 waste Disposal Well 85 F-ll WLeastttee rW, eSl.l AN*0. Sa1 vRageewotrokin3g. AN.oteDsavies, WVDNR 110089 ill Plastics - W.W., No. 1 Waste HC1 Well, 12/20/66 Plastics - w.w.. No. l waste HCI well, 10/13/70 ll4 Test Well 2S and 27 and Well 331 Analytical to Date 132 r-ll Test Well 27 133 Well 331 135 Test Well 2S 139 H-14 Burning Ground soil Logs 145 General - Appendix IX Analysis 154 CF031S61 E1D480939 VI Plan - Page 1 1.0 IHTRODt 3N ' . 1.1 Obj actives III, E.I. and du Font de Solid Waste Heaours S Co. (HSWA) permit entered into a with the U.S. Hazardous Environmental Protection Agency (EPA) Region effective as of December requires the development 13, and 1989. This permit implementation of a RCRA vWearsihfiincgattoinonWoirnkvs efsaticgialititoyn lo(cVaI)tedWoirnkpPlaanrkaetrsdbuurgF,onWt'esst Virginia. The objectives environmental study which o the VI is will achieve to perform an the following; (1) hinavzaersdtoiguastecoinfstaitureenletasseococurhreadzartdoouthsewgarsotuenodwr ater via four solid Waste Management Units (SWMlKs); (2) Submit additional information on one SWMO. (3) Cduhrainragctbeurirzneingtbaofcopmolbyuasetieotnalpprorodduuctcstsre(lCe-a6s)?edand (4) Determine the future investigative and/or implementation needs. The Verification divided into two investigation (VI) Workplan is major sections. The main body of text contains tha general technical approaches site history and proposed which will be implemented during the course of documents are the VI. The contained as reguired separate VI procedural attachments to the main body of text. l.2 Scope The verification Investigation aa required by the permit will determine if or hazardous constituents a release of hazardous has occurred or is lik waste ely to occur froa any of the six identified SVWBJ'S. The VI will provide detemine if s a uffic &CBA i ent Fac in ili for ty mation Invest i fo ga r t i EPA on ( to BT I ) is warranted. At the time the vi report is written, it wwairllrabneteddeoterrmitinecdorirfecftuivretheacr tiionnvemsteiagsautrieosnsshaorueld be iaiplenented or if no further action or investigation is required. CE-031562 EID480940 VI plan - Page 2 2.0 SITE DESCRIPTION AND HISTORY 2.1 site Background and History The S.I. du Font de Hemours & Company Washington Works facility is located in Wood County, West Virginia, approximately seven miles southwest of Parkeraburg, along Route 892 (see Figure l). The facility is situated in the Ohio River Valley along the banks of the Ohio River. The Washington Works facility started producing bulk plastic materials in 1948. The first polymer products compounded were polyethylene, Hylen molding powders and filaments, Lucite* acrylic molding powder, and later polyvinyl butyral, acrylic resins, fluoifopolymer, and polyacetals. The Color and processing Division was started in 1966 as a small lot custom color compounding operation. In 1885, the U.S. EPft, requested Washington Works to provide information concerning sixteen units identified as potential Solid Waste Management Units (swMtKs). The review of the material contained in the June 5, 1985 subaittal document resulted in issuing a RCRA HSWA permit requiring a Verification Investigation (VI) for six of the original sixteen identified SWWs. The location of these six are shown in Figure A-l. The data in the 1985 subaittal was sufficient to remove ten units from any further investigation. 2.2 Geologic and Hydrologic Conditions It The surticial soils covering the site are derived from the in-situ weathering of the underlying Permian bedrock and ace Quaternary Ohio River Valley alluvium. The Quaternary alluvium ia relatively eearse-grained, unconBelidated sediment and serves as the major source of grouildwatw in the area of the plant. These shallow aquifers are limited in areal extent. The underlying , bedrock is dominantly claystones, shales, ailtstones, and thin sandstones of th@ Permian or Pennsylvanian formation of the Dunkard Group (see Figure 2). is likely that perched water tables are present in the sandstone horizons and that they are reeharged by precipitation and surface runoff and fluctuate saasonally. Evidence for the occurrence of the perched water tables include surface seepage of water at the base of sandstones that crop out. This phenomena also attests to the relative impermeability of the shale intervals of the bedrock. CB-031563 EID480941 CB-031564 EI0480942 FIGURE 2 vi plan - Page 5 r.Fm^mc SYSTEM CENOZOIC PERMIAN PENNmyAHlAN 6BOUP OB FOBhATiOH QUATERNARY ALLUVIUM DUNKAR& MBNONOAHELA ClWEMAUOH ALLEGHENy POTTSVI.LE MSSS13SEPP1AH DEYONiAN DEPTH_<m ftBI I IgP-S FORMATIONS . 0 lOrounij LVtll -BASEOFUS&W COV RUN SAND .2ND SALT SAN& - 3Rt> SALT SANO .810 INAIN SAND. - COFFEESHA1.6 - BEREASANCSTONe eHEMUN06ROW 6EVON1AN SHALE BRALl.lEftrO^A|| QHtOBROVNSt-1 HARRB.L SHALE MARCELLUS SHALE ONONDA6ALIME ORlSieAIW SA( OHIO/BROWNer DEVONIAN SHALES CORNIFEROUSLIME -ORISKANY SAN& E. 1. DU POMT DE NEMOUR3 & CO.. INC. WASHINGTON WORKS WASTE DISPOSAL WELL FIELD WOOD COUNTY. WEST VIRGINIA GENERALIZED STRATIGRAPHIC COUJMN BENEATH THE WASHINGTON WORKS SITE CF031565 EID480943 VI plan - Page 6 According to B. M. Wilmoth (1966), the rocks of the Dunkard Group are gently folded with dips ranging from about 7 feet to 145 feet per mile in this geographic area. The bedrock material dips to the east as the plant lies on the western flank of the north-south trending Parkersburg Syncline. The subsurface strata at the plant site slopes to the east at a rate of approximately 25 feet to the mile (Johnston, 1966). The higher knob country of the Ohio River valley is characterized by branching V-shaped valleys typical of a dissected plateau geomorpbology. The slope of the valley walls are relatively steep, and elevations at the site range from about-630 feet along the Ohio River to 860 feet above sea level in areas of the Local Landfill. The area is well drained by ephemeral streams, including Page Run and unnamed tributaries on the western edge of the site, and an unnamed tributary that parallels and then intersects the stream of Coal Hollow. All of the above runs empty into the Ohio River (towards the north) in the area of Washington Bottom. Sroundwater from the bedrock aquifer (Dunkard) is very limited due to a high percentage of shale and to its topographic location (see Table 1). Most of the groundwater used in the area is derived from the alluvium of the Ohio River Valley. High yield, good quality ground water can be produced frott these alluvium aquifers. The topography and general geofflorpbology at the site indicates the groundwatar flow is north toward the river. Tha stratigraphy in the region suggests a southerly groundwater flow toward the Parkersbury Syncline. The flow direction needs to be determined. This will be further discussed in section 4.0. The natural quality of the groundwater in the bedrock is usually hard (calcium/sodiua bicarbonate type), alkaline, and of moderate iron content (wilmoth, 3.966) . Iron is also present in concentrations great enough to cause staining and/or discoloration of the water. CB-031566 EID480944 VI Plan - Page 7 TABLE 1 GEOLOGIC UNITS DESCRIPTION Name Age Thicleness Description & Lithology Quaternary Alluvium Dwikard Group Monongahela Group conenaugh Group Allegheny/ Pottsville Group Cenozoic 0-100 Permian/ 300 Pennsylvanian Pennsylvanian OOO Pennsylvanian >500 Pennsylvanian >650 Brown and gray^ poorly to well-sorted clay^ ailt, sand, and gravel. Red and gray-green shales, thin-to-naBBive sandstones/ and some thin limestones. shales (generally red), thin sandstones, and some limestone. Calcareous shale, thin limestones, and ebert Thin-to-thiek, fina-tocoarse-grained, light colored channel sands and light-to-dark gray shales. Notei Total Dissolved Solids (TDS) data was net available. Due to the similar lithology o the groups, exact formation thickness could not be determined. CB-031567 EID480945 VI Plan - page 8 ^ 3.0 BACKGROUND AND WASTE CHARACTERIZATION 3.1 A-l Du Pont Local Landfill 3.1.1 Current and Historical Background Conditions The plants principal landfill area has historically been in the natural ravines located on the south side of Du Pont Road (see Figure 1A). The landfill covers approximately 251 acres and was opened in 1964. It is currently operating under State Permit #3494, The remaining life of this unit is estimated to be seven years. The landfill operation has typically bean filling tha ravines with waste materials and covering it with local soil to form terraces. The size of the "cells" as they were developed and the depth of each layer is unknown, Table 2 summari zee present average landftiled quantities and lists materials that were disposed of in the past. All waste were generated at Washington Works or at contract facilities. Access to this unit is by an asphalt road restricted by a chain link fence at the east entrance and a locked bar gate at the west entrance. The east gate is operated remotely via intercom communication to plant security. The landfill is surrounded in portions by chain link fence, barbed wire fence, wooden fence and heavy vegetation over-growth. Leachate is collected from one point eastern side ot the landfill monthly analyzed for pH, chloride, fluorlde, COD (see Table 3). This information used as baseline data to compare any sampling. on the and TOC, and will be future roundwater quality data collected on 8/6/87 trsm the three wells indicate there is no water quality problem in any of these wells. This is based on U.S. EPA Drinking Water Quality standards. Test Well 27 haa 5 feet of screen in the 566.7 to 538.07 foot sandy grave-l zone and is located approximately 600 feet from the closest portion o tha north western boundary of the Local I-andtill. The well ia approximately 98 feet deep. The well has a specific conductance of 560 aicroBhos, total iron 2.78 ag/1, sulfate 81 ag/1, chloride 40 mg/1, and 0.01 ng/1 total organic carbon (TOC) (see Table 4). CF031568 EID480946 VI Plan - page 9 Test Well 2S has 5 feet of screen in the 565 to 537.81 foot sandy gravel zone and is located approximately 100 feet from the northern boundary of the landfill. The well is approximately 100 feet deep. The analytical data indicates a specific conductance oC 780 mieromhos, TOC 0.4 ng/l, total icon 2.05 ng/1, sultate 32 mg/l, and chloride 61 sag/I (see Table S). Well 331 has 15 feet of screen in the 5C5 to 538.7 foot sandy gravel zone and is located approximately 750 feet from the northern most portion of the Local Landfill. The well is approximately 95 feet deep. The analytical data indicatea specific conductance of 460 mieroinhos, TOC 2 mg/1, total iron 0.19 ng/1, sulfate 89 mg/l, and chloride 22 mg/1 (see Table 6). The well is locates 100 feet tvom the Ohio River and is known to be influenced by the river. The water quality data from this well is considered background or upgradient data because of the constant influx of river water. Appendix IX analyses were performed twice in late 1988/early 1989 (see Appendix F) in these same three wells. The wells were retested to determine it the contaminants found present in the first set of analysis represented lab contamination or actual groundwater contamination. The net result of the two analyses showed Test Well 25 contained levels of iron 3.9 mg/1, zinc .13 ing/I and 1.8 ug/1 nitrate as M and Test Well 27 contained 3.59 ug/1 chloroform, *23 mg/l aluminum, 2.4 ng/l iron, and 1.2 ug/1 nitrate as W. Well 331 contained iron levels, .60 mg/1. Iron content is naturally elevated in this area. These results indicate there is no water quality problem based on Drinking Water Quality gtandards. The other contaminants present during the first set of analyses were considered to be lab contaminants.. Table 7 is a sumaary of the laboratory test run on the shelby tubes collected during the September 1989 installation of the eight, new monitoring wells. The soils are described as reddish brown, sandy clay with soft shale fragments. The pH range o( the soils is in the neutral range, 6.0 to 7*4. The soil permeability ranges from 1.41 X 10-6 to 4.88 x 10-8 cm/sec at depths of 2.5 to 4.5 feet and 1.67 af 10-8 to 9.57 x 10-6 oM/see in soils from 7.5 to 9,5 ft. deep. CF03156& BID480947 Table 2 VI plan - page 10 SOLID WASTE TYPES DISPOSED OP IN THE LOCAL LAMDiTLL PRgSEMT cenatituents Acrylic Slurry (Dry Bas.)(l) Mixed Plastics (Dry Bas,)(2) Ash (3) Average Iba/day 550 Minimum Ibs/day Maximum Iba/dav 4000 First Year iffifeop'a^.Yr 100 Fifth Year mtona/yr 100 165 1500 30 30 100 2000 20 10 (1) This material is a mixture of inert aorylic solids and water. The material ie greater than 40% solids. Suspension agents and residual organicss comprise less than 0.5%. (2) This Material is mixture of inert mixed plastics such as polyamides, polyvlnyl butyral, fluoropolyiners, polyactal, polyethylene, and terephthalates. (3) This ash could contain ssn aluminum or steel components. The ash is HOT E. P. toxic. SOLID WASTE TYPES DISPOSED OF IM THE LOCAL LANDFILL PAST Fly Ash Bottom Ash Polyamides Aery lies polyacetal Polyvinyl Butyral polyethylene Terephthalata Fluoropolymers paraffin Wax paper and Cardboard Glass and Misc. solids Scrap Metal and Piping Putrescible Wastes (very saall amounts) Cff031570 EID480948 VI Plan - Page 11 TABLE 3 DUPONT ROAD LANDFILL LEACHATB DATE 12/10/86 1/29/S7 2/27/87 3/31/87 4/23/87 5/29/87 6/26/87 7/31/87 8/26/87 9/30/87 10/30/87 11/24/87 12/29/87 1/29/88 2/24/88 3/15/88 4/12/88 S/20/88 6/28/88 7/29/88 8/30/88 9/27/88 10/18/88 11/29/88 12/29/88 1/17/89 2/14/89 3/28/89 4/14/89 5/30/89 6/27/89 7/25/89 8/30/89 9/26/89 10/24/89 11/29/89 12/28/89 EH 7.82 7.57 7.67 7.30 7.80 7.90 8.33 8.08 7-90 7.90 8.00 7.30 7.6S 8.00 7.70 7.70 8.00 7.90 8.30 8.00 8.20 8.20 8.30 6.00 7.60 7.60 8.20 8.10 8.10 8.30 8.00 8.20 7.40 7.80 7.60 7.60 7.60 CHLOR IDES (ggMl 35 166 155 30 140 439 569 614 646 625 760 6S8 16 278 129 86 95 239 98 533 599 435 414 211 50 9 33 55 120 87 1S3 274 34 10 108 120 143 TOC (EPM) 10 9 6 7 8 17 18 20 H.S. H.S. 19 23 8 15 8 6 7 15 19 22 20 19 25 9 5 7 7 9 9 13 151 211 10 8 6 7 17 COD (PPM) 16 16 16 28 20 41 67 47 47 53 50 H.S. 16 0 16 0 12 38 124 56 64 64 62 28 20 30 24 20 16 20 41 70 24 20 16 28 44 OTHER AHALYSISt 10/18/88 5/30/89 HARDNESS? 619 HARDNESS! 333 SULFAT3E!; 90 ODOR #1 CHEM HOME #1 SULF NOME HOME #1 SULF #1 CHEM #1 CHEM #1 STO? #1 StJLF #1 STOP #1 IND WS Sl STOP #1 BVtS #1 STCF #1 IMD WST #1 SV1S #1 SOL? #1 MUSTY #1 SULF #1 SULF 0 #1 MUSTY 0 0 HONE #1 CBOSM #1 MUSTY NONE NONE #1 KASSY GRASSY MOHB MONB #1 SULF MOHB FL1OORID:ES IEPM) 0 0. 01 0. 01 0 0. 01 0. 02 0. 02 0. 02 0. 03 0. 02 0. 03 0. 30 0. 25 0. 10 0. 09 0. 06 0.09 0. 18 0. 26 0.32 0. 02 0.22 0. 40 0. 19 0. 07 0. 72 0. 08 0. 13 0. 12 0. 16 0. 17 0. 18 0. 18 0. 16 0. 05 0.19 0.13 FLOW (GPD) 43200 43200 21600 86400 53200 7200 1440 6912 2880 4320 1 14400 43200 11520 12200 10080 30 1440 2880 5760 2880 14400 21600 50400 43200 14400 11520 86400 72000 85400 86400 43200 CF031571 EID480949 -'" TABLE 4 VI plan - Page 12 STATE W ftST 'AffctW^ ortryt, oa'awiBcivE nn, asiccs rem QaajaBy n_E^_t^ cm pent ca. . CoeationsTOJdUflcytanWBrica. Pk^fHV tye o< Aeeivltyt _X_ Lmltl.U Spwy icnwiw ---- tWDMsif> ___ MBU tMast.fHa^ea, f&atw JL2.2 W^..Ctag. GaQtd.91^^^.. 4214 nttoi of oruuagt.. Cable Ttoola _aw sj^uudi _Septe_57 ttotai Qi^thi *8fKa tUfvtian: 631 > 92' (J^rMfic) .aMidiMei typ of CMtiqt <^ban Sftal- QU r at Cuinqt "JSi.of" Qnpef oi ZaiM Ci--di 5-tfl.AT ten-- Opt to *qui(tt^ iw __ ZonM oraufil ttoae ot Grareifti ttone HBBtr BMci.nt zeMiiA6j6.'?__-J_3_8.0? Uertsioijy o( KICK iMcio; zcxifi Sandy Geayel Mgtina ot SfU^i A ,^__BttH B.a._azfiza2 .anptte aMfft Otheein--CTibtt; 82.6' aHifl-pi^ -U2-jfl,0' 9NUMBER ^'""'^'T 7.4 56' 202 348 25 .ififl- UffiB JA. -2- Bfci OPMf40 0 iedti.M '<^-t ^ffp .01 86 M. .9 1.3 ^A- A_^- -005- 81 JL -1*1. JB3. .<rm -a^- j^. -aO. -30. CB'031572 EID480950 TABLE 5 VI Plan - Page 13 S!KX or wist 'ApcnaA nnTiAL oawoacxvE MSA. fQfse row caWW '"--' S.^l. DttpBHt lectuflni WashingtonWorks, .^ ^ o< tetivtty* .A. Urtttll Spray ,,__. Ijrewtieft Otlr(I^ciib*i DupCe^M.530^ifa^., _ Hdl yRCitiCTUon (MMaei j^a^ . LH-LEB^; ^^p^ Ptaf^W ____________ WAV mica of BrtUto Cable Ibala OattEn. aoqapiii,fudt August, 1&57 ui 'W^ of efi,n? a-i*e EKvueni 5xhqnSte^ .aajl^ly'WtWA^WwSs'. WMUS 9t __._ Oswrottcft! S_ ^p C4u<4i .^'*_, _ ^ g^tir oS sew ei: 537.81 &W Opw ea gui.gtti 542 '-Lg^^ ya Geowsi' tfcne 1W ot aswiflgi Hafle awe Mui9 taftiatJM-537.81. utfslow at KMW tewnj taMi ,Saffidy.QytMt3 tKd OC 3t>iyqt ^_, Pifi alUe ottBB (0--eHb) i siMtj^az __ BKt) Nteft 7^.4-* _ QKieti w Sflti 54QJ^_98j5' _ to sasfie fwwsai M. L ^^^"^ osmenw.w 7.14 %- JA2- 454 Tr 780 woa AB^ .x. JS/J- MB/I JO. ^^.u^ t-.g"^-PotlMMJUi . ""^Illll"**8^- A^U^ffO a^t _niMi_ BUl 0.0. 0.0 .142,0 ^r J 1.0 Z.OS Tor S3. Tolo" %" HB/X jaa, i/i jsa. JO. -s^ <1 1.2 .03 <.001 CE-031573 EID480951 TABLE 6 VI Plan - Page 14 s^fst Of tW viaci^a nnTLu, ixjfswatcM wen. BCTCKT eQm ^MI HM>_E^I. og fcpt OQ. toMtAenst^aiinggan WBE]g,_ gkgbg,w . fyf ot Aeeivtiyi Liiadfl.U ..._ s_ ttU IdBfctJEleiitts (MNaiet 331 Mtted 8< DrtMJ^t C^Ble jQQJ.a S|iry ttr, lAid.Eud sacsi iBou. Enpt smrtot 8l<vtion! 633' Tyt* of CMU^t Carbg:}^ Sfteel__ y 8 aL-- "35 -- S 2.a t t iw(0rtetito t^Ai 4 _33_9_.2_5_ _ _ ' jafat <a^>iBtiidi _3UX^ 1960 Upiinrlint! oi--w ei ^cw_u_qi Ei^ou2n0qr'idiA! J|_ cpci o< asw cuii ggi _? , zoBr OPM to *Bai& Tj' sew aEwwi; . f^i o( Qro'atingi UyeiflW o< ttwu- awiag zcnri gjacty (aayeX , (EK aMu-ui toBM> 56S' to538.7 tttted sf SjnpUnq ^ St 8/6/8'? (> ___ 3aUr OKXh to Nuw Ocii<D--aU) i 68.3' D^BI EO 3ji9li j^ai PJWMESR -a- a.icodKKncN .ZA. 58* -nr -sgr 22S UJSTB Aai. ^. ,'^tetg, |..-aad4^,, tefeM^m .?^tffH iwm^ .SWSI- fl-grrtfn IUI 460 0.0 0.0 T A 16 1.7 ^2- ^a-. <0.). 22 i.015 89 Jl. -aL <.os L2Z, ififiL ^1- -HZJL jali. jaa. --KL J^L. jm, CF031574 EID480952 TABLE 7 u<Bflwrof TEST swrow Local Landfills W6HlNGTa< MATEil DORKSPLWr ^ Sayietto.* fc; B-l (Local) B-l (tflcal^ B-2 (Local) B-3 (local) &-3. (Local) B-4 (Local) B-1 (Ijncal) . B-5 (Local} B-5 (local!! B-7 (Uxal) B-7 (t-ocal) Depth ft. 3-5 5-7 7.5-9.5 2.5-4.5 5-7 7.5-9.5 . 10-12 5-7 7.5- 9.5 2.5 - 4.5 Visual Bescriptlon WidiSh bFown SMCY 'CLAY with soft shale fragnents Shale, soft, ^brown Bnlwn and gray SWDY ClAT with saiKfstone fTagnents BnMi SWOY ttAY with soft shale fragnmts Eteddish brtwn SMW CLAY Liglit broMn SMDY CLAY Broken SWCSTDNE 'teddlsh hraim SILT/ W REd SIW Clffif Brown SfWf CLAYwith rock fragcnts Sandstone fragients Unifiom Classification PH ML 7.4 91 7.2 (1-0. 6.0 ML-O 6.3 H.-0. 7.1 ?1 6.4 W 6.0 0- 6.8 * Also indicates well number as shown of Figure 1-A fennBabffity cni/sec Not suitable for testin Wot suitable fir testin 9.57 x l0"6 4.8B x lO'8 2.43 x IBi"8 (tot siritable for testin Hot suitable for testin 1.67 x 10r8 1.99 K 10.-8 2.06 x 10-6 Mat aritable for testii aMiSss^k ' ;::::-;'/:-:-:-:-'-;a VI Plan - Page 16 Water quality data will be taken in February 1990 to comply with the Landfill Liner Equivalency Demonstration request for an April 1990 deadline* This data set will be used as baseline water quality data for any future monitoring at the Local Landfill * 3.1.2 Waste Characterization The wastes currently and previously disposed of in the landfill are listed in Table 2. They are inert acrylio slurry, inert mixed plastics, fly ash and bottom ash from power generation and plant trash. The powerhouse ash comprised approximately 70 percent of the total waste. No liquids were disposed of in the landfill. Detection of chloride from leaohate samples prompted the discontinuation of disposal of chloride sludge in 1982. The leachates analyses up to December 1989 have not indicated any other potential contamination (see Table 3). t e s t e dSmall quantities of RCRA hazardous ash were landtilled prior to 1980 when the ash residues hazardous per the E,p. Toxicity test. Ash from the incineration of plastics contained barium, cadmium, selenium, and chromium. The fly ash and bottom ash is now sent to another disposal unit outside the facility boundaries. Some ash material is still landfilled and could contain some aluminum or steel components, but it is not classified as hazardous per the E.P. Toxieity test. 3.2 A-3 River Bank Landfill 3.2.1 Current and Historical Background conditions fill The River Bank Landfill is located on the northern edge of the site adjacent to the Ohio River (see Figure 1A). A portion of the old river bank, approximately 125 feet from the river was used for a landfill. The unit is presently inactive? however, it was the only landfill in use at the facility from 1948 to 1964. The landfill was closed by covering the material with 6 to 36-inches of soil and then vegetated. This landfill extends approximately 2,400 feet parallel to the river bank and is up to 50 feet wide in some places. CF031576 EID480954 VI Plan - Pago 17 Wa are currently using Well 331 as the background well for this unit. On 8/6/87, an Appendix IX analysis was performed. The results were 460 nicromhos specif ie conductivity, 89 mg/1 sultate, and 2 ng/l TOC. A 10/6/88 Appendix IX analysis reported .60 ing/I of iron, but Iron is naturally elevated in the groundwater in this region (Wilmoth, 1966). This data will be used as baseline background data for two units during the implementation of the VI werkplan. As indicated in section 2.2, the groundwater flow direction ia unknown at this time. The upgradient and downgradient wells for this unit will be verified attar the flow gradient is con tinued by the program descriped in section 4.1. 3.2.2 Waste characteristics r e s u l t e d Powerhouse ash, plastics, rubble, and plant trash were disposed of in the landfill. The landfill waste were dry, sine plant policy has always been to burn all liquid waste. At one tine, approximately 200 waste drums at solid material were buried in the landfill. One of the materials landfilled was RCRA hazardous ash, which from the incineration of plastics containing barium, cadmium, selenium, and chromium pigments. 3.3 B-4 Anaerobic Digestion Ponds 3,3.1 current and Historical Background Conditions Three anaerobic digestion ponds were located next to the Ohio River, on the northern edge o the facility in the 100-year flood plain (see Figure 1A). The three surface impoundments were located in a row, and wastes? were cascaded from the third(west) to the second and first(east) ponds. The three ponds were approximately e feet deep with sloped, earthen banks about 22 feet wide at the base. The eoabined volume capacity of the three ponds was about 3 million gallons. CF031S77 EID480955 VI plan - Page 18 This unit was initially constructed as a single pond in the mid-1950's. In the mid-1970's, this pond was enlarged and two more ponds were added. Alt three ponds ceased receiving wastes in 1985 and were officially closed in 1988. All waste is now transferred off-site. The dimensions of pond 1 (eastern most pond) was 52 feet by deep. The 237 feet capacity and was aepstpimroaxtiemdatteolybe6.0553ft,0. 00 gals, and the volume was 12,324 ft3. When this pond was reconstructed in the aid 1970's (1973-74), a natural clay layer was used in the walls and polyethylene sheets were placed on the walls. Then e to 12-inehes of bentonite was placed over the entire pond cell. The dimensions of pond 2 (middle pond) was 53 ft. by 180 ft. and approximately 5.9 feet deep. The capacity was estimated to be 428,000 gals. and the volume 9,540 ft3. Pond 3^8 (western most pond) dimensions were 76 ft. by 134 ft. and approximately 5.9 faet deep. The capacity o( the pond was estimated to be 457,000 gals. and the volume 10,184 ft3. Releases have occurred in the past* Flooding occasionally inundated the impoundments prior to construction of the Belleville Dam in 1964. Ho flooding has occurred since the construction of the dam. The impoundments were re-lined with a 6 to 12-inch layer of bentonite to reduce the potential of infiltration to the groundwater in 1973-74. The Lubeck public supply wells have detectable levels (ppb) of ammonium perfluerooetanoate (also called C-8). Washington Works ig in the process of purchasing these welIs from Lubeck water supply* Pond 1 was closed in January 1988. A 22.5 foot, 22e off vertical core sample was taken 23 feet north (past the bem) of the center of this unit to characterize the subsurface lltholegy and to detemina the level of contamination. Figure 3 summarized the results. Approximately 5@,700 cubic feet of soil was excavated from this pond including the 5-foot high berm. CF031578 EID480956 VI Plan - Page 19 Pond 2 was closed in February 1988. A 22.5 foot, 22a oft vertical core sample was taken 19 feet north (past the berm) of the center of this unit to characterize the subsurface litbology and to determine the level of contamination. Figure 4 summarizes the results. Approximately 43,900 cubic feet of soil was excavated from this pond including the 6-foot high benn. Pond 3 was closed in November-December 1988. A 22.5 foot, 22o off vertical core sample was taken 16 feet north (past barm) of the center of this unit t& characterize the subsurface litbology and to determine the level of contamination horizontally from the unit* Figure S summarizes the results. Approximately 46,900 cubic feet of soil was excavated from this pond including the 9-foot high bern. Figures 3 through 5 suBroarize the initial results taken from these ponda. A total of approximately 14,012,500 Ibs. of soil was excavated from the three ponds site. This material was landfilled off site. chemical analyses were taken at six intervals of approximately 2.7-2.8 feet starting 1.4 feet below grade. Analysis was run fars Triton? c-8; polytetraflWM-oethylene (PTFE); total zinc? E.P. toxieity methods for zinc, fluoride, and chloride; percent organics? and percent mineral. The results from each of these ponds is shown in Figures 3 through 5. It After each pond was emptied, a 4-foot core was taken in the center. Chemical analyses were perforated on the four samples taken at 1-foot intervals to material had d b eter een mi re ne mo if ved . a ll T h th e e re conta sults min of ated this analysis are shown in Table 8. The description of the first two feet of sample and the analytical confirm the sludge had contaminated the upper 2f@et of the native clay layer. Table 9 summarizes the analytical results of the soil samples taken from the center of each pond after all the sludge was excavated. A cornfield was used as background. is located approximately 50 feet south of the parking lot along Route 892. CF031579 EID480957 rt Lkl m 1' !|^^ ^?**; fl^- ^^^ S1^ ^ o VI Plan - Page 20 ^ 3 3 3 a a a s K ^ sd ? s ; ^ x! Sl |a| 8 [ ] nl ^1^3 Sfc tu.1 " w M i^ n T n r* ^ A^ N ? s gs a s s s *i --Hi--I H M "I 2 a 5 S a S 3. 2 8 ni tt <1 N 1* a i n * n i it tt r) 9 N9 & Sl (M - * ^ 2 8a s a s s a ,j0 - i i i-! .--! ' .i>i I. i . I 5 lu I I^ I^--k P <M CB-031580 EID480958 1j- ! u> b^j LL. Q <1^ kfsi^g iS'^lN ^^o I ft* s is a Sl_l 4 o.5 I ia ' . 1 ^ ?^^ 5 s ? s 8 4 ,.^ -;'5ai>"]ftS S 'S M N B S " M 0 s < ., a sa ihi i in fi i r; CTI 'o s g a y; ft '1 (<,(') <^ . l1 rt rt " ..l 33 Z a' a o i aaaBOo |i--^>MXO fl)f3 'M>'< On S,^ 3 S l rt <n 1^ N " .^ i o o o VI Plan - Page 21 *M a, i 60 o e a 8 A a N " t A N g - ZOIOaeiOOo it?^CI <OiBQ -, TM K " " 1 - , , ? : ;cEO i<fNvp- .a .* Citt C? i '0 P^ S N b'te w ly Q ^ >^- S 16 Ot ^ ki j CF0315B1 EID480959 SUfiERWTE POW A/a J - WEST CORE /\IWLYS/S FIGURE 5 -tS' SAMPLE CORE ZZ OFF VRTtCAL ~A(. ^8 = / f PPH m 77 76 Bl 120 77 73 62 79 w t*M xn W PPM F W W CL MW X PTfE MxfW 0 0.1 1.10 2.tl 7 9 0.2 O.SO 2.90 6 0 .3 1.60 2.Sf 3 o a.a 1.16 3.00 3 t 0 0.2 2.20 2.OT 3 4 0.9 2.00 2.40 S 4 0.2 l.oo 2.00 * 0 0.2 2.71> 2.10 2 t TOTAL Z/W ^ HWfW SOLUBLE VI Plan " Page 23 TABt^ 8 SaTOBle Deoth fet 1 foot 2 feet 3 4 feet % TritonR mg/Kg 5.9% $.8% 1.4% 1.2% ppm C-8 mg/igg 610 258 HD 234 ppB 2N mCT/ka 34 37 26 21 TABLE 9 Single Sample Analytical After Sludge Removal g^Ria EEB 21 Pond I (east) 0.1 Pond 2 (middle) 0.3 Pond 3 (we8t) 0.8 Cornfield 0.3 (background) %TjrA^on Q.29 0.25 0.18 0.03 ppa fiyt 110 66 173 <4 %jerPB 0.07 0.03 0.45 0.0 CF031S63 EID480961 VI Plan - Page 24 TABLE 10 WASTE COMPOSITIOW FOR ANAEROBIC DrGBSTIOH PONDf BOD COD Suspended Detargent PH Solids 700 ppm 3,000 ppn 700 pptt 26,000 ppm 10 Trace components less than 10 ppm; NH40H eaC12 d-Linonane Ethylene Qlycol Ainaonlua perfluoreoetanoate (also known as c-8) Tyzor m, Zonyl Ba(N03)2 Cyelohexane/High Boilers Polytetrafluei-oethylene (also known as PT?E) Citric Acid Duponal Glass Bubbles Teletaaier^ Teflon M Caustic Soda Preon Z Glass Beads Zinc Chloride Hexafluoroethane 38 AD Biooide CF031584 EID480962 VI Plan - Page 25 3.3.2 Waste characterization This unit treated wast from a fluorocarbon manufacturing process. The waste was principally detergent with trace quantities of a number of constituents summarized in Table 10 (proceeding page). Liquid from the pond was trucked off-site when the units ceased operating in 1988. 3.4 F-ll Injection Wells Mo. 1 and No. 2 3.4.1 Current and Historical Background Conditions Two deep wells were installed tor injection of plant wastes generated by the operating divisions (sea Figure l-A). Construction of Injection Well No. 1 (l-WW) began in September 19C6 and construction of injection well <2 (2-WW) in August of 1970. Details of injection well design, geological strata, and acid storage (feed) tanks are contained in the two reports included in Appendix F. Washington works MO. 1 disposal well (l-ww) started operating in 1969 and was plugged on 2/24/76. The geologic injection unit is tha Big Injun, a quartz sandstone of Missiasippian age and corresponds to the Greenbrier unit. Well Me. 2 started operating in March 1972 and was plugged on 11/14/80. The waste in Well No. 2 was injected into Middle Devonian age shales, over the ll-year period of operation, a total of 112.5 million gallons of aeid wastes was injected into these two wells. It Washington Works Ho. 1 (1-WW) disposal well was drilled to a depth of 1,677 feet and bridge plugged back to 1,485 feet. A geologic core was collected fro the intervals 1,419 ft. to 1,435 (t., 1,60 9 1,52 ft 6 ( s f e t. e to 1^851 Figure 6) . f tT.,he and we 1,598 ll was ft. to cased (injection easing) with l,23S ft. of steel easing with 246 ft. of reinforced fibercast as a bottom hole injection zona extension* was cemented with 430 gallons of Dowell K-70-71 asaccidks-proofoCf lacsems eAntcetome1n,t20tr7oaft.1,,20a7ndfwt*ithto 3t0h0e surface (see figure 7). injection tubing of 3-inch Fibercast Bpoxy Tubing was implaeed to the middle of the perforated zone. The CF031585 EID480963 VI Plan - Page 26 injection casing was perforated trcro 1,323 ft. to 1,439 ft. Brine was sampled from the injection zone. chlorides measured 3.93% and the pH was 6.83. Total dissolved solids were 7.6%. Waste Well Mo. 1 was re-worked during the period June 20, 1970 through July 2, 1970 (see Appendix P for details). The re-working consisted of the following; 1. Placing a sand plug in the well from a total depth back to 1,318 feet. 2. Installation o( 31 joints of 5-1/2" liner with a special 10 toot machined Hastelloy sleeve to a depth of I,314 feet. 3. Cementing the 5-1/2" liner in place with an acid resistant cement. 4. Drilling out cement left inside the easing and flushing out the sand plug. 5. purging twice with nitrogen and fresh water. 6. A short tens injection test using fresh water. The results of this work indicated the cementing of the 5-1/2" liner was successful with acid resistant cement placed around the entire length of liner. Both nitrogen purges produced large quantities of dirty water with some solids. A short tera injection teat indicated that the well had been rejuvenated to near its original capacity (150 gpa at 500 psi). Washington Works No. 2 (Well 593) disposal well was drilled to 4,056 feet and bridge plugged back to 3,650 feet (see Figure 8). The injection casing, 3,808 feet steel with 239 feet reinforced Fibercast and 12 feet of Hastelloy-C as a bottom bole injection zone extension, was cemented with 1,166 gallons Haliburton LR-ll acid resistant cement to 3,608 feet and 1,000 sacks of poznix cement with 14 percent salt. Shot holes at 2,919-foot depth were squeezed with 450 sacks of eontton cement with no returns. Shot holes at 2,134-foot depth were squeezed with 500 sacks of common cement to ground surface. Ho cores were taken during drilling but lithologie information was obtained froa geophysical logs (see Figure 9). Mine veils are used for groundwalei? monitoring for the two injection wells; an abandoned gas well (WOO-577 red), Test Well 20 (replaced Test Well 23), Well 331 (replaced Well 307), and six CP031586 EID480964 VI Plan - Page 27a '. ^tel^^^^n^sn '1' ; ^jl^Ji^ sst^s.h^'''^^^ ^.'c!.'^' .t^ll i' ^: ^ Si ''; A ^ i3 i) a ' ' > 1' ''1' ) u a jW ,u w ' >' I' 1 vi tB 11 I,' h;' y. ' * i ' i , 1 , ? ,?,,',- !t:s ^ ^W j^l. '^-;|41 11 ^r|^^ js : ^ ^ .^-ia- , !?^i^|^ ' ^.^- r 1 ^ i i i ! ! P ? ^1 !" 2 a^'i ^M.l8"-: \ ^t-'^j .^ ;f1e^-t' |1 1 ^ 5T f' c'- . j H| ^|-.. tl^| l -^ . . i' .,,,,,,,.,, ,',,,, , ,, , ..^ ,,,,,!,,,' 'T, ^ L^, - i^ -WH^ I U li f -'s t H ^ } ^ i : * ' " , 0^ . ': flM ^^'^i^i '^"s^^ r?i^j^^!f? [^|^I?S??P? ^ ^ ? '' ' ^ s i > 4 .~~"""| ~"^y- --|a.-----<f!i " = w -S. .1 ^Q ; 1 ?^ i "'! 1! ! ,^ ^? ^j ,i ;; -" g^a; -- ----S1 '.4 ,, 5' . 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CF031591 EID480969 FIGURE 7 vi plan " Page 23 From ^n^esfclon P'-iiSp -- ^ ^ '* 3" HatteUoy ''C" Pipe - Schedule 10 ----I(:: Daigel Oil 3'Qpaie 1 8" 1 3'1 Hatl;ay "C" Coupling s o- 'jl ;, --- 3 - a 1*1^ ^'1' P i ^ . ^;gg :Ni aoo.o' ^?. i; aj 1,244.0' p J aA--' ( ^ 1 1 fc ^ k1 i S ? ^ y -" R ^ ^f ,,,,,,,,,,,,,,, 11s?^, , , ^<? ,, , , , ,,,,,,,,,,,,,,,,,,,,,,,,., ,,,,,,,,^,,,, ^ s-'i/a* Rrf -" St.tl Caning ;-^/" Typ# H-in StBel Cuing ^-?/<" rt-B- BpB.] Qlw cattng 1.33,0- ' p 1.3SO.O- ijaa.a^ i ^? . ' , - wyv: i.4.o ;la l.W.ar'-Ti^ ^ r a1111-11-1'11-11-1111'- t^i'; &'' I 1 ^>-* ; '''? f/9" x 3/8" fprorttiBo in Fibtt Oluc Ca1ni[ 4 pP foot A. %* * ^ ' . M'v'',,x----AlJUJiIu-i,j <hTM CF031S92 BID480970 W^STE DiSPQS^ ,\'SL- WA2HIMOTON VI pla" ~ ^^ 29 \yvGBK*Q^5R 4,MO ^SPA>^ ^^?.AKJgg_M6KtT FIGURE 8 ^"'"^ "^^t1'at' tl*l| [I suApA&e M ^^.^.-.= CF0315&3 EID480971 CF031594 EID480972 vx Plan - Page 30a CB-031595 EID480973 VI Plan - Page 31 TABLE 11 SUMMARY OP MONITORINS WELL DATA FOR THE WASTB TMJBCTION WELLS Monitor Hairjto. 577-Red injection Facility Ho. 23 (replaced w/ 20) 20 331 307 (replaced w/ 331) BLENMERHASSETT* ISLAND WELLS Vertical Distance to Injection Zone 745 2,910 1,395 3,560 1,395 3,560 1,395 3.S60 3,560 1,395 3,560 Horizontal Distance to Injection Zone 650 850 $25 700 650 575 6,070 6,350 1,275 1,680 7.780 8,150 *The sample taken fron this "monitor well'1 was combined or. averaged sample from six wells on the island. The distance for thia "monitor well" is the nearest well to the disposal wells. CF031596 EID480974 VI plan - Paga 32 TABLE 12 MONITOR WEUi ANALYSIS OP COMBIMEDLBLENNERHASSETT ISLAND WELLS DATE Eg ?-12/73 I3-/742/74 10/20/77 3/23/77 7/20/78 10/19/78 11/16/78 12/14/78 3/22/79 4/7$ 9/79 1/21/82 4/15/82 7/16/82 10/20/82 1/25/83 4/13/83 7/15/83 10/25/83 1/26/84 4/26/84 7/30/84 10/23/84 1/30/85 4/29/6S 7/17/85 1/24/86 7/30/86 10/29/86 1/29/87 4/22/87 7/31/87 10/30/87 1/29/88 4/12/88 7/29/88 10/18/88 1/12/89 4/14/89 7/25/89 10/24/89 7 21 7 46 7 46 6 96 7 12 7 10 7 11 7 12 6 98 6 91 7 04 7 12 7 57 7 02 7 03 7 22 7 27 7 30 6 95 7 18 7 04 7 02 7 09 7 11 7 11 6 97 7 17 7 15 7 15 7 28 7 44 7 17 6 80 7 10 7 40 7 60 7 30 7 10 7 20 7 00 7 10 6 70 CHLO)RIDES ismQ. 38 36 32 33 27 28 35 38 34 27 27 33 30 26 26 36 40 33 26 43 34 30 26 33 31 27 30 31 32 38 30 31 31 30 32 33 26 45 35 29 26 28 TOC CPPM1 N/A 7 12 42 39 24 22 18 0 18 18 52 8 11 0 7 72 4 8 0 30 34 0 2 13 9 7 0.05 3 1 1 1 1 1 3 i 2 0 2 2 2 10 CF031S97 EID480975 VI Plan - Page 33 TABLE 13 MONITOR WELL_WA'FBR ANALYSIS - WEUi #20 DATE 1" 2/74 3/74 10/20/77 3/23/77 7/20/78 10/19/78 11/16/78 12/14/78 3/22/79 4/79 9/79 1/21/82 4/15/82 7/16/82 10/20/82 1/25/83 4/13/83 7/15/83 10/2S/83 1/26/84 4/26/84 7/30/84 10/23/84 1/30/85 4/29/85 7/17/85 1/24/86 7/30/86 10/29/86 1/29/87 4/22/87 7/31/87 1.0/30/87 1/29/88 4/12/88 7/2&/88 10/18/88 1/12/89 4/14/89 7/25/89 10/24/89 fiH 8.31 8.38 7.83 7.74 7.96 7.73 7.3$ 7.76 7.43 7.6$ 8.02 8.21 7.87 7.77 7.72 7.73 7.93 7.64 8.78 7.84 7.91 7.93 7.76 5.13 6.96 7.76 7.62 7.52 7.90 7.43 7.44 7.50 7.50 7.70 7.60 7.80 8.00 7.60 7.72 8.00 7.70 CHLORIDES (gPM) 46 44 27 31 31 33 30 29 32 32 28 25 26 28 28 26 28 28 32 28 34 34 27 36 36 28 29 24 35 41 35 39 23 28 24 27 27 24 26 41 47 TOC fPPM) 13 9 25 37 10 12 36 24 31 27 28 5 11 0 19 4 8 4 0 17 20 1 0 30 12 86 0.02 0 19 1 1 1 2 8 1 7 7 1 7 1 <! CF031598 EID480976  VI Plan - Page 34 TABa! 14 MONITOR WELL WATER ANALYSIS - WELL #23 >ATE EH CHLOR TOC IDES CPPM) (P^M) 5/31/73 6/29/73 7-12/73 1- 2/74 7.32 29 7.55 26 7.70 27 NO SAMPLES - 6 N/A 23 WELI, DRY REPLACED WITS WEIiIi #20 (SEE APPENDIX E) CF03159& EID480977 VI Plan - Page 35 TABLE 15 MONITOR WELL WATER ANALYSIS - WELL *307 DftTE fiH CSWB.- TOC IDES (PPM) IPTM) 5/31/73 7 53 47 28 6/29/73 7 72 48 N/A 7-12/73 7 74 51 23 1-2/74 7 54 56 22 3/74 7 40 53 18 10/20/77 7 23 60 39 3/23/78 7 49 25 61 7/20/78 7 40 55 28 9/79 7 76 62 30 REPIACED WITH WEIiI, #331 (SEE APPENDIX E) CF031600 EID480978 VI Plan - Page 36a TABLE 16 MONITOR WELL WATER ANALYSIS -_WELL #MOQ 577 RED PAGB 2 OF 3 DATE Ea CHLOR TOC ODOR IDES (PPM) (PPH) I/ 5/77 5 15 33050 19 2/ 3/77 6 IS 9656 14 3/ 2/77 5 38 26345 11 4/19/77 4 17 34169 24 5/11/77 5 55 36240 34 6/ 9/77 5 05 34998 8 7/15/77 5 32 35267 17 8/11/77 5 46 34206 5 9/15/77 5 3 33500 8 10/20/77 4 76 35611 5 11/16/77 4 98 35294 1 12/12/77 6 41 32067 25 1/12/78 4 84 32662 35 2/16/78 S 07 34361 10 3/22/78 5 05 34757 17 4/13/78 5 74 34141 30 5/10/78 6 00 34376 18 6/19/78 4 53 33701 10 7/20/78 6 73 33062 27 8/23/78 6 61 34362 30 10/19/78 S 50 33482 42 11/16/78 5 57 30531 28 12/14/78 5 9S 33882 8 1/11/79 5 77 33568 8 2/22/79 6 32 32598 12 3/22/79 5 63 33730 16 4/26/79 S 85 35133 17 S/30/79 5 84 34323 35 6/28/79 5 30 34SS4 42 7/26/79 5 22 34343 56 8/23/79 5 64 33569 9 9/27/79 5 87 32149 44 10/2S/79 6 05 327S? 51 11/15/79 30 32757 63 12/19/79 6 56 34825 12 1/10/80 6 35 35564 4 2/14/80 6 79 31489 13 3/20/80 6 65 40978 48 4/24/80 6 73 40084 11 5/ 8/80 6 90 37375 7 6/ 5/80 88 38474 17 7/10/80 6 10 32290 25 8/20/80 5 97 38722 9 9/ 4/80 6 11 42041 41 HONE NONE NONE HONE NONE NOME NONE NONE NONE NONE HYDCBN NONE NONE NONE NONE HOME NONE SALTY NOME NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NOME NONE NONE NONE 6RASSY GRASSY NONE NONE NONE GRASSY CF031601 EID480979 VI plan - Page 36b TABLE 16 MONITOR WELL WATER ANALYSIS - WELL JWOO 577 BED PAGE I OF 3 DATE BH 5/31/73 6/29/73 1-12/73 I- 2/74 3/74 5/17/74 5/24/74 5/31/74 6/ 7/74 6/14/74 6/28/74 7/ 5/74 7/12/74 7/19/74 7/26/74 8/ 2/74 8/ 9/74 9/ 6/74 10/11/74 I1I2// 7/74 6/74 1/10/75 2/ 7/78 3/ 6/7S 4/ 9/75 5/12/75 6/ 3/73 7/10/75 8/ 6/75 9/ 3/75 10/8/7S lI2I// 6/75 4/7S 2I// 8/76 4/76 3/ 4/76 4/ 6/76 5/ 6/76 6/ 7/76 7/13/76 8/ 9/76 9/ 9/76 IQ/ 5/76 IV 3/76 12/ 8/76 6.84 6.59 6.83 6.83 6.14 6.45 6.56 6.54 6*84 6.57 6.57 7.02 6.78 6.88 6.96 S.99 7.00 6.81 6.92 7.02 6.51 6.49 6.49 6.58 6.43 6.58 6.76 6.65 6.55 6.59 6.66 6.83 6.55 6.85 6.77 6.61 6.67 6.37 .60 6.32 6.63 6.16 5.92 5.46 5.67 CIttORIDBS Jim 34800 33800 33600 33600 34800 3S416 34907 34297 32566 33279 34952 35792 35477 35267 35372 23951 33737 33939 31742 3S205 33964 33163 3290 35012 407&9 32300 30800 30800 33048 45253. 34481 32483 32414 34847 34805 32960 32758 36354 37059 34341 33639 34331 32399 341S5 34299 TOC (PPM) N/A 22 13 8 37 28 6 4 22 0 14 2 10 32 0 5 19 0 19 17 14 3 12 11 7 14 14 11 11 8 10 7 3 10 11 14 8 16 12 11 1 6 5 22 ODOR N/A N/A N/A N/A H/A NONE NONE NOME NOME HONE NOME NONE KOBE NONE HONE NONE NONB NOME NOME HOME NONE K/A NONE HONE NONE H/A NONE NONE GASSED NONE NONE HONE HONE NONE NONE HONE NONE HONE NONE NONE HONS NONE MONTE NONE NONE CF031602 EID480980 VI Plan - Page 36c TABLE IS MONITOR HELI, WATER ANALYSIS - WEVL, 1WO_Q 577 RED PAGB 3 OF 3 DATE Eg CHLOR- TOC ODOR IDES tPPIQ IPPM). 1/21/82 4/1S/82 7/16/82 10/20/82 1/25/83 4/13/83 7/15/83 10/25/83 1/26/84 4/26/84 7/30/84 10/23/84 1/30/85 4/29/85 7/17/85 1/24/86 7/30/86 10/29/86 1/29/87 4/22/87 7/31/87 10/30/87 1/29/88 4/12/88 7/29/88 10/18/88 1/12/89 4/14/89 7/2S/89 10/24/89 6 44 4 91 5 46 4 77 4 13 5 64 4 99 5 95 4 77 S 50 6 42 S 36 4 97 4 58 4 39 4 75 4 47 5 45 4 68 5 33 5 S4 6 10 6 30 6 3 6 10 6 80 60 6 19 6 20 6 20 25531 44006 40566 39690 38807 39829 36459 40850 37480 38808 42307 33421 34964 35084 38048 39318 38058 37616 40935 38680 34819 36328 36651 34819 33747 33747 36158 37134 35932 35582 12 11 10 16 10 13 1 0 57 29 1 10 18 13 16 0.5 26 3 9 6 5 8 9 15 12 7 10 15 20 5 H/A H/A H/A M/A H/A H/A N/A M/A N/A N/A M/A H/A N/A H/A M/A N/A M/A M/A M/A M/A N/A N/A M/A M/A M/A M/A M/A M/A M/A M/A CF031603 EID480981 VI plan - Page 37 Blennerhasset Island veils (see Figure 1A for the location of the plant wells and Figure 1 for the location of the island). The vertical and horizontal distances from the injection wells is summarized in Table 11. Test Well 23 was monitored from 5/73 to 1/74 when it want dry. Well 307 was Monitored tron 5/31/73 until 7/20/78 when the well was taken out o service. WOO-577 red has bean monitored continuously from 5/31/73 to the present. Analyses of the groundwater has been conducted for pH, chlorides, and total organic carbon. Tables 12 through 16 summarize the analytical results for all the monitoring wells. Sas well (WOO-577 red) was drilled to 2.200 feet and plugged back to 740 feet. The natural chloride level in WOO-577 red is approximately 35,000 ppin. This is a flowing well. Test well 20 was monitored twice in 1974 and then continuously fro 10/20/77 to the present. The background chloride concentration is 36 ppn. The Blennerhasset Island Wells were monitored continuously from 7/73 to the present. The background chloride concentration for these wells is 27 ppm Information and details on closure of thee wells are contained in Appendix V. This is the Affidavit of Plugging and Filling the wells l-WW and 2-MW. Note these wells are listed as 2 and 3 respectively in the West Virginia Oil and Gas Division records, but these are the only two injection walls at the facility, in order to effectively evaluate the capability of the existing monitoring wells ability to detect a release tron the two injection wells, the local and regional geology and the structural features need to be described. This is done in detail in Appendix A. Appendix A is broken down into two sections. The first section discusses in detail tha local and regional geology, the stratigraphy, the unit thickness, and the confining and injection zone parameters. The second section discusses the structural features, earthquake activity, and seismic events in th area surrounding Parkersburg. CB'031604 EID480982 VI flan - Page 38 3.4.2 Waste Characterization The principal waste disposed of in the wells was an aqueous waste stream containing 6 to 15 percent hydrochloric acid combined with 2 to 5 percent solution of formic aeid and formaldehyde from the polyacetal division, and vent scrubber effluent containing organics fron the nylon manufacturing operation, fluoroearbon chemicals, and hydrogen fluoride (<IO,OQO ppm). The temperature of the waste material at the point of injection was approximately l05oC. 3.5 H-14 Burning Grounds-Liquid/Solid 3.5.1 current and Historical Background conditions Use of the Burning Grounds began close to the start-up date of the plant in 1948. Prior to 1965, open burning of plant trash and organic liquids was conducted in this area (see Figure 1A). An additional area was used for burning liquid waste. Drums of liquid were placed at the top of the river bank, with a gravity feed to a burner below. About 40 drums per month were burned in this manner. In 1974, two buildings, B-256 process Building (114' x 54') and B-253 Warehouse (280^ x 140') were constructed. Approximately 2800 cubic feet of soil was excavated from thie area. When this work was performed, it was noted that the dirt had no smell or unusual color. No waste was visible. Six test soil borings were taken in July 1989 by Mid-Eaatem SaoTeeh Inc. Marietta, OH. The test boring log reports indicate the soil along the eastern aide of the building is a. moist, loose, yellowish brown sandy silt-silty sand to a depth of 50 feet. No discoloration or odor was noted in the boring logs. This indicates there is no potential for residual release fron the soil. A moisture density relationship feet of the soils was performed. The results showed a maximum dry density of 115.6 Ibs/ft. and an optimum moisture content of 10.6%. In 1989, construction began on an addition to B-256 and loading docks for B-253 were constructed. Approximately 1800 tt3 of soil was removed. No gross eontaiaination has been reported during this construction project* CF03160S BID480983 VI Plan - Page 39 3.5.2 Waste Characterization The liquid wastes that were burned at this area include acrylic monomer slurries, Butacite^ ink slurries, and high boiling liquid fluorocarbon compounds; as well as solvents in use at the plant. The solids included paper, trash, and plastics. 3,6 C-6 Polyacetal Product Incinerator 3.6.1 current and Historical Background The polyaceteal product incinerator has been in operation since the plant started up in 1959. off-specification polyacetal product polymer and certain other non-hazardous solid wastes (sea section 3.S.2) are burned in the unit. The polyacateal product incinerator consists of two (2) screencovered brick-lined burning pits. The two pits are collectively referred to as one (1) unit. Each pit ia constructed of reinforced concrete lined with fire brick. Screens, on roller, are placed over the pits during incineration. Bach pit by 10 ft is by a box 10 ft with approximate inside dimensions of 9 ft deep. Approximately 6 ft of the depth is below grade. Unlike the front wall, the side and back walls extend approximately 4 ft above grade. The product incinerator is located east of the bio-oxidation wastewater treatment plant, and the unit's location is shown in Figure 10. AS the pits have the same construction, same waste feeds, and same operating procedures, air emissions sampling and analysis for one pit is representative of the emissions from both pits. Sampling an operating pit is discussed in section 4.S.2 and in Appendix c,2. 3.6.2 Waste Characterization In order to characterize the combustion products released during the burning of polyacetal products in unit C-6, the wastes fed to the unit were thoroughly reviewed. As the focus of the sampling and analysis effort will be to characterize the air emissions released from the incinerator process to identify hazardous constituents, the waste characterization review focused on hazardous constituents present in the wastes fed to the unit. CF031606 EID480984 FIGURE 10: A MAP INDICATING LOCATION OF POLYACETAL PRODUCT INCINERATOR VI Plan - Page 41 The Delrin area Maintains strict administrative control over the polyacetal product incinerator to ensure that no wastes other than specific non-hazardous wastes from the Delrin area are fed to the unit. Currently, wastes from other parts of tha site are not fed to tha incinerator. Historically, only grades of Delrin-"1 have been burned here. Two basic types of product-related solid non-hazardous wastes are burned in the polyacetal product incinerator; Delrin Chemical Area wastes and Delrin Finishing Area wastes. The main waste feed to the unit is off-specification polyacetal product polymer from the Chemical Area. Chemical Area Wastes Chemical area wastes fed to the product incinerator include raw polyacetal polymer and capped polyacetal polymer (also known as Delrin fluff). Both of these materials contain formaldehyde and may contain trace quantities of toluena. These Materials are fed to the unit in cardboard boxes lined with polyethylene plastic or similar fiber containers. Chemical area tank and snap cleanings also contain formaldehyde-based polymeric solids, and these are also burned in the product incinerator following such cleanings. Eropty boxes and.wooden pallets may also be burned in the unit, The only Appendix VIII hazardous constituents Known or suspected to be present in the chemical area wastes fed to the product incinerator are Formaldehyde and Toluene. Finishing Area Wastes Finishing area wastes fed to the unit are limited to proprietary mixtures of powder and solid concentrates. Excess and nen-atandard batches of these concentrate mixtures nay be burned in the product incinerator. These concentrates include stabilizer concentrate which may contain nitrogencontaining compounds such as Mylon and earbon black color additive. "Chose concentrates may include polyacetal polymer (which contains formaldehyde) which has been added to improve processing. Review of the compounds used in finishing area concentrates indicates that tha following Appendix VIII hazardous constituents may b present in the finishing area wastes fed to the product incinerator; Formaldehyde, -Cr@sol and potentially trace quantities of Bthylene oxide. Hazardous Constituents As a part of the review of chemical area and finishing waste feeds to the product incinerator, the waste feed materials compounds were reviewed to determine it they contained one or nore of the sixteen (16) volatile and volatile compounds listed in Attachment 1 of the RCHA area semi- CB-031608 EID480986 VI plan " Page 42 Corrective C-6. Host AofcttiohnosePecrommipt oausndas naarleytnicoat lusreeqduiirnemtheentsmafnourfaUctnuirte of Delrin, and several of these compounds do not appear to be used anywhere on the site. Of the compounds on Attachment l of the RCKA Correetive Action permit, only m-Cresol and Toluene are suspected to be present in tha feeds to the product incinerator. The hazardous constituents that are Icnown or suspected to be present in the waste Materials fed to the product incinerator are Formaldehyde, Toluene, a-Cresol, and possibly Ethylene oxide. 3.6.3 Combustion Product Characterization One of the objectives of the Verification Investigation is to characterize the the combustion products released during the burning of polyaeetal products in unit C-6. This characterization of the combustion products is necessary to ensure that any hazardous constituents ]cnown or suspected to have been released to the air fron the unit will be sampled and analyzed. it As with any burning process, the principal combustion products from the product incinerator should be carbon dioxide and water. Since some waste feeds may contain nitrogen, oxides will is likely be evolved that some small quantity of nitrogen during combustion of these materials. Also, as with any burning process, monoxide (CO) is generated some low level of carbon The preceding waste characterization identified hazardous constituents that may be present in the feeds to the product incinerator. Trace quantities of these hazardous constituents in the feed (Formaldehyde, Toluene, ffl-Cresol, agnadseps ofsrosmiblytheSuthnyilte.ne oxide) may also be present in the off- it Additionally, is possible that this combustion process generates trace levels of some products of incomplete combustion (PICs). For the types of material in the waste feeds, methyl aldehydes (e.g., formaldehyde) and ketonea ethyl ketone) are potential decomposition (e.g., products and PICs. And, for aroaatic compounds such as toluene and cresol, benzene is a potential pic. Phenol is another potential Pic from the combustion of ereaol. The volatile and seai-volatila compounds listed in Attachment 1 of the RCBA Corrective Action Permit as analytical requirements for Onit C-6 were reviewed to determine which of those compounds would be likely Pica fro the burning of the CB-031609 EID480987 VI Plan - Page 43 wastes fed to the product incinerator. As noted above, benzene, methyl ethyl ketone, and phenol have been Identified as potential PICs. The other compounds en the Attachment 1 list do not appear to be potential PICs from the burning of the wastes to the product incinerator* The four compounds potentially in the teed (Formaldehyde, Toluene, Ethylene exide, and m-cresol) as well as the three compounds identified as potential PICs (benzene, methyl ethyl ketone, and phenol) were next reviewed against ERA'S Principal Hazardous Organic Constituent Thermal Stability Index (Appendix D of "Guidance on Setting Permit conditions and Reporting Trial Bum Results," January 1S89) to determine the likelihood of their presence or absence in the air emissions from the unite. Although the unit does not closely resemble a hazardous waste incinerator for which one night typically use the index, the conditions in the unit probably resemble the post-flaae-zone-like low oxygen conditions that were used to establish the index. This "incinerability11 index ranks compounds in descending order of difficulty of destruction. Benzene is ranked number 3 on the index and is a Clasa l compound. Class l compounds are considered to be more difficult to destroy by burning than Class 2 compounds; Class 2 eoaipounds are considered to be aore difficult to destroy than class 3 compounds? and so on. Toluene (ranked 35) and Formaldehyde (ranked 4@-so) are both Class 2 compounds. Phenol (ranked 100-101), n-cresol (ranked 104-15), and methyl ethyl ketone (ranked 108-109) are Class 3 compounds Ethylene oxide is considered to be much easier to destroy by burning than the other compounds and is a Class 4 compound, ranked as number 174 on the index. it Given that is considered to be much easier to destroy by burning than the other compounds and that it is thought to be present in the teed to the unit at lower (it any) levels, it does not appear that ethylene oxide would be present in the air emissions from the unit* Based on this combustion product characterization, air emission testing for hazardous constituents that may be released from the polyacetal product incinerator should include the sampling and analysis f@r the following hazardous constituents! Formaldehyde Toluene n-Cresol Methyl ethyl ketone Benzene Phenol CF031610 EID480988 VI Plan - Page 44 4.0 RCRA VERIFICATION INVESTIGATION (VI) " SCOPE OP WORK The premise behind a determine if a solid Verification Investigation (VI) is waste management unit (SWMU) has to released contaminants not intended to be as to the environment or not. A detailed an investigation as VI is a RCRA Facility Investigation (RF1), but a simpler, field screening process. Six SWMU'S require some form of investigation under Washington Works HSWA permit. Appendix A is the supporting information and No. 2. requested for unit F-ll, Injection NO investigation plan was required Wells No.l for this unit. Four units will have groundwater investigation programs, three of those will have soil investigation programs, and two of the four units will have leaehate collected. Unit H-14 Burning Srounds does not include a soil investigation plan, only a groundwater investigation plan. units One are: unit A-l will have an air sampling Local Landfill, A-3 River program. The six Bank Landfill, B-4 Anaerobic Injection Digestion Wells No. Ponds, l and H-14 Ho. 2, Burning and c-6 Grounds, F-ll Polyaeetal Waste Incinerator. will The normal be the list of analytical for all groundwater investigated the U.S. EgA requested unless otherwise noted s(saemeplTinagb.le 17). We have requested a shortened list for soil ll Table l8 summarizes the number of analytical samples proposed in the investigation of the five SWMU's. The locations of these sampling spots are approximated on the naps included under eaeh SWWJ investigation plan in this section (Figures through 14). 4.1 Hydrogeologieal Verification Prograia Several cross-sections of the SWMU areas will be constructed to illustrate the proposed monitoring wells capacity to monitor a potential release, It The groundwater flow direction needs to be mor firmly established on the site prior to determining any upgradient or downgradient monitoring wells. is believed the river is the recharge zone and the stratigraphy dips to the southeast. But, surface CE'031611 EID480989 FIGURE 11: PROPOSED SAMPLING LOCATION MAP FOR SWMU A-1 DUPONT ROAD LANDFILL FIGURE 12: PROPOSED SAMPLING LOCATION MAP FOR SWMU A-3 RIVER BANK LANDFILL 13s SAMPLING LOCATION MAP B-4 ANAEROBIC DIGESTION PONDS ^buRE 14: PROPOSED SAMPLING LO FOR SWMU H-14 BURNING VI plan - Page 49 TABLE 17 EPA CQIJSTlTUgMT ,. Hetala . Antimony Arsenic Bar fun Caditi ChloPoethanc ChlocgdifluoitiBBhUn* Cllloroferm Z-Chloroniiphthalena Z-Chlarophenol L*ad Itereupy ChryswM IB-CPSSOl Nickel Stieniun Stiver Cynid (alienable) o-Cresol p-cpesol ^hwvtt6.ManthroeuM Bf-n-butyl phthatf o'BtehlorobBttw VAlatUes/SMivetatjiM !-Bfehl6Mbw*n Acetone p-Dichttirobefuent Acrolin AerylanftMIe 3,3'<Dfdloitbtn2tdfnc DSchlni-ocHfluorciirtrtw Anthr*e*fw BnZfMI Bw0 tal BnthrpcetUt 1,1 D i eh lorwthllM ,2-OidilGroetlif 1.1-0(ehlorethylttr BenzoCb]fluoranthn BmoM fluarBnttiw trn*-l ,2-(Hcht6rttet!)ylen 1.2-&ichloropropan Beniottlpys-trr 2,4-BiehlBpephMlol Bf8(2-chlorot!thoxy?B9thn elE-1,3-Dlehloropfopen 81s(2-chtorothy0thr Diethyl phtliataf 8f8(2-chlflretsoppopyt)cthr 2,4-Stimthylphenot BisCZ-nttiylhexyl )phthlata Olinethyl phthalate Broinodichloremthiine Srvmsfwm 4-8roiiiophenyl phwyt tthw Butyl benzyl pilthalate Carbon duulfldt Carbon ftfkchlorid* 4,6-Dfnitro-o-creaol 2,4-0(htrfl(*tll 2,4-Dinitrotolun 2,6-0fnttr9totuw Dl-n-oetyl phthnlnf EthytbtnxMM p-CtllOrtwnilina FtuonnthMw chlorobwitn* FonMidehydt p-chloro-lferMol forsie oclcl HexichlorcfcBrow HaxsehIorobutadine Hexachlorocyclopentadfent HMachlorocthafia indwoll ,2,3*c(ll pyrem Methyl 6r<ni(d Hethyl Alorlite Hthyl ethyl fcetont Methyl IsBbutyt ketorw Hftthyl mettiacrylatt Methylefle thioride Nsphthlne p-MHrMntUn* Mfti^fewttfiM p-mtroptiwol N-NftruediphenylMin* M-Hltrosodf rrprnpyla(nine Pentach loi-ophifiot Phefianthrcnt Phenol PyraM 1,1,1,2- TetfiteH iBroathfr 1.1,2,2-T*tr*ehlorotlw TBtrBeh t oroithylene Ta(ur 1,2,4-Tplehlerobwitne 1,l,1-Trfehloroathn 1,l,Z-Tr(ehlof9thnn Tf(chloreiliylw Trfchlerofluopa--tlw Triehlopafltphthalw 2,4.5"Tr(ehlepopieKit 2,*,<rTfteMorophnttl Vinyl chtop}* CF031616 EID480994 VI Plan - page 50 TABLE 18 SUMMARY OP SAMPLING MEDIA SWMU A-l Local Landfill A-3 River BanM Landfill B-4 Anaerobic Ponds H-14 Burning Grounds TOTAL SAMPLES PROPOSED SaU 21 9 6 0 36 Media GroHndwater 15 9 4 10 38 Laaahata CF031617 EID480995 VI Plan - Page 51 topography suggests the ground water flows to the north towards the river. We are proposing that one complete round of water level measurements be taken in all available monitoring wells to establish a better understanding of the groundwater flow pattern on the site. 4.2 A-l Du Font Road Landfill 4.2.1 Soil Sampling Program A soil sampling and analysis program will attempt to dateraine if subsurface contamination escistes. Figure II shows the preliminary proposed areal coverage and location of the seven soil borings. Sample locations were chosen near areas where it is known that material was landfilled. In the case of surface refusal, a second attempt will be made five feet from the aborted sampling point. These sampling locations are tentative. Because of the limited hydrogeological information available for this site, we have just recently completed the installation of eight monitoring wells. Once groundwater level measurements have been established and we have a more thourough understanding of the groundwater flow, we will reevaluate our proposed locations and contact the EPA and the WvDMR if changes in the location or number of samples is necessary, and will be finalized in the field prior to drilling. Three soil samples from each boring will be retained at various depths for laboratory analysis. The depths will be determined once more information about the hydrogeology is obtained. if Each sample will be field checked for contamination by placing a portion of the soil in a polyethylene bag, shaking the bag, and inserting the probe end of an Organic Vapor Analyzer (OVA) into the bag and measuring the organic vapor content. The OVA will detect any organic contamination is present in the soil. it is proposed that the soil samples be analyzed for E.P. Toxic metals, formaldehyde, and formic aeid. These compounds were chosen after of review of the landfilled materials. The OVA will act as CB'031618 EI0480996 vi Plan - paga 62 if an organic contamination screen, the OVA indicates the presence of organics^ further analysis will be performed. They make excellent indicator parameters without requiring a large sample. The volume of soil collected by a cone penetrometor in a 6 to 8-inch long sample will not provide a sufficient amount of sample to preform the analyses requested by the EPA (Table 17). 4*2.2 Groundwater Investigation Groundwater sampling and analysis will determine if contamination of the groundwater exists. Fifteen groundwater samples are proposed. Eight will be collected from existing monitoring .wells and 7 will be troa th cone penetrometer soil sample locations. Figure 11 Illustrates the proposed locations of the groundwater sampling locations. Figure 1-A shows tha well locations. It is proposed the groundwater samples be analyzed for all the parameters the U.S. SPA Region IIX requested (Table 17)* 4,2,3 Leaehate Sampling program It is proposed that six collected. One will be leaehate samples be taken from each of the three leaehate collaetion ponds located in the eastern portion of the landfill. The remaining three samples will be taken from tha terraced area in the western portion of the landfill. These samples will be analyzed for the list of constituents listed in Table 17. 4.3 A-3 River Bank Landfill 4.3.1 Soil sampling Prograa The soil around the River Bank Landfill will be evaluated. Nine soil sampling locations are identified in Figure 12. Soil samples will be collected using a cone penetrometer and analysed for the same constituents as the DuPont Road landfill. Four samples will be taken approximately 400 feet to the north and south of the landfill at approximately 600-foot intervals and one other sample will be taken which is the control sample near Test Well 40. CF031619 BID480997 VI plan - Page 53 As in the DuPont Road landfill, each sample will be field cheeked tor contamination by placing a portion of the soil in a polyethylene bag, shaking the bag, and inserting the probe end of an Organic Vapor Analyzer (OVA) into the bag and measuring the organic vapor content. 4.3.2 Gceundwater investigation Groundwater samples will be taken and analyzed for the parameters listed in Table 17 plus butyraldehyde, adipic aoid, ammonium perfluorooctanoate, hexamethyl diamine and chlorides. Four samples will be taken approximately 400 feet to the north and south of the landfill at approximately 600-foot intervals and one other sample will be taken which is the control sample from Test Well 40. These are the same locations as the sampling points tor the soil investigation. Wells or sampling points were not proposed in the landfill to characterize the buried waste because any hole eould potentially create open vertical conduits through which hazardous material could flow. The groundwater sampling interval in the monitoring wells is above the toedreck and weathered surface material interface. The bedrock interface is approximately 90 to 100 feat below grade along the river bank and approximately 21 to 38 feet below grade in the ravines of the Local Landfill, approximately 2000 feet due south of the river. 4.4.3 Leachate Analysis Two existing leachate streams will be sampled, one on the far west end of the landfill and one on the far east end. These samples will be analyzed for all the constituents in Table 17 plus the six additional chemicals listed for the River Bank landfill groundwater. 4.4 B-4 Anaerobic Digestion ponds 4.4.1 Soil Saapling Program It The data presented in section 2*5 provides the closure information for thia SMSJ, ia proposed to take two cone penetrometer cores from the eenter of the middle pond (#2) and the western pond (#3) (see Figure 13). All three ponds were closed in the saae fashion but native clay samples were not taken from ponds 2 and 3 CE'031620 EID480998 VI Plan - Page 54 4.4.2 after excavation of the material. The samples will be collected at l-foot intervals starting at the base of the fill material for a total of 3-feet. This three foot depth was chosen to determine if all gross contamination wag excavated during closure. The analysis will be performed starting in the native clay layer, approximately 10 feet below grade, and extend at one foot intervals for three feet. Each sample will be field checked for contamination by placing a portion of the soil in a polyethylene bag, shaking the bag, and inserting the probe end off an Organic vapor Analyzer (OVA) into the bag and measuring the organic vapor content. This interval was chosen because when the ponds were initially closed, samples were taleen at one foot intervals and it was determined that the first two feet of clay contained low levels of Triton, C-8, and PTFE. The remaining two feet of clay contained very lew concentrations of the two surfactants. It appears the native clay unit acts aa a natural liner preventing downward contaminant migration. The purpose of this sampling Is to verity this. The sampling profile from the collection tube ia 6 to 8-lnches in length and 10 ca is diameter. This will only provide enough sample for analysis of Triton c-8, fluorocarbon resins (PTFE), total zinc, soluble zinc, chloride, and fluoride. Not enough sample ean be collected to analyze for the requested list (see Table 17), The purpose here if is to determine the gross contamination waa it removed when the ponds were closed and is known these were the only waste materials placed ia these ponds* Table 8 is a summary of the waste analysis performed on the sludge prior te closure, Groundwater Investigation If The proposed groundwater sampling locations ara located along the river bank in four spots, These are the same four locations proposed for the A-3 River Bank Landfill. All samples will be from the same location as the cone penetroneter cores i. any contamination has migrated toward the southern plant boundary, it will be detected in these sampling locations. CB-031621 EID480999 VI Plan - Page S3 |^ The samples will be analyzed foe C-8, Triton, ITFE, total zinc, soluble zinc, chloride, and It tluoride. is proposed that these constituents be analyzed for instead of those listed in Table 17 as these were the only contaminants placed in the ponds. 4.5 H-14 Burning Grounds 4.5.1 Groundwater Investigation if The proposed groundwater sampling locations are; Test Well 22. Test Well E-6, Test Well S, and seven cone penetrometer boring locations around the perimeter of the two buildings located in the area t the old burning grounds (see Figure 14 and Figure 1-A). The purpose here is to determine there is any residual contamination to the grsundwater. These ten groundwater samples will be analyzed tor the parameters list in Table 17. 4.6 Polyacetal Product Incinerator T h e objective of this sampling and analysis effort is to determine th coneentratlons of hazardous constituents potentially preaent in the air emissions (based on the combustion products characterization) from the product incinerator. 4.S.I Emission sampling In order to meet the objectives of the verification Investigation for unit C-6, it was necessary to develop a saapling rationale that accounted fer; o the specific sampling points for the unit with respect to the potentially affected environmental media, and o the population of passible sampling locations and how these were narrowed down to specific sampling points. The media of concern tor potential release of hazardous constituents froa the product incinerator ia the air. The focus of this sampling and analysis effort is to identify hazardous constituents potentially present in the air emissions from the unit. CP031622 EID481000 VI Plan - Page 56 The polyacetal Product Incinerator consists of two (2) screen-covered brick-lined burning pits. The two pits are collectively referred to as one (1) unit. As the pits have the same construction, same type of screen covers, same waste feeds, and same operating procedures, air emissions sampling and analysis for one pit is representative of the emissions from both pits. Hence, sampling and analysis will be conducted during the operation of a single pit. During operation of a pit, the air emissions rise and are primarily released vertically upward through the opening at the top of the pit. Hence, it is necessary to sample the emissions off the top of the pit. And, in order to obtain a representative sample a fixed "rake" sample collection apparatus will be placed above the pit to catch a composite air emission sample which will be collected' using appropriate techniques. Following the initial light off period for the operation of a pit, air emissions will be sampled for three 1-hour periods while tha pit is in operation. The "rake" sampling apparatus and sample collection techniques that will be employed are described in the Sample Collection and procedures plan for this unit in Appendix C,2. Other options for sampling location and sampling points included taking ambient air samples downwind of the operating pit or traversing the top of the pit. Neither option appears to be able to produce a more representative sample of the actual air emissions being released from the top of the pit. Hence, taking a "rake" compoaite air sample from the top of a single operating pit was ehosen as the sampling location and method. 4.6*2 Emission Analysis In order to ensure that the compounds in Attachment 1 of the RCRA Corrective Action Permit and any other hazardous constituents known or suspected to have been released from the unit would be analyzed, the potential hazardous constituent air emissions from the unit where compiled in section 3.6.3 (Combustion CF031623 810481001 VI Plan - Page 57 itProduct characterization). In that section, it was found that six (6) hazardous constituents nay be present in -the air emissions from the polyacetal product incinerator. Specifically, was found that one (I) hazardous constituent not on the Attachment 1 list may be present in the air emissions from the unit and that 11 of the 16 hazardous constituents on the Attachment 1 list do not appear to be potentially present in the air emissions from the unit. Therefore, it is proposed that sampling and analysis of the air emissions from the polyacetal product incinerator be limited to the following six (6) hazardous constituents in accordance with the analytical protocols in the Sample Collection Methods and Procedures Plan for this in Appendix C,2: Formaldehyde Toluene m-Cresol Methyl ethyl ketone Benzene Phenol CF031624 EXD481002