Document rRjejK6O3n68x3m91O61mw5J

AR226-2536 ATTACHMENT 1 VERIFICATION INVESTIGATION WORK PLAN E. I. Du Pont de Nemours & Co. Washington Works February 9 1990 C F031556 EID480934 YfEIFICATION INVESTIGATION 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 Bank Landfill 3.2.1 Current and Historical Background Conditions 3,2.2 Waste Characterization 3.3 B-4 Anaerobic Digestion Ponds 3.3.1 Current and Historical Background Conditions 3,3,2 Waste Characterization 3.4 F-ll Injection Wells No, 1 and No, 2 3.4,1 Current and Historical Background Conditions 3.4.2 Waste Characterization 3.5 H-14 Burning Grounds 3.5.1 Current and Historical Background Conditions 3.5.2 Waste Characterization PAGE 1 X 2 2 3 8 16 16 16 17 17 17 25 25 25 38 38 38 39 C P031557 EID480935 3.0 BACKGROUND AND WASTE CHARACTERIZATION (Cont.) 3.6 C-6 Polyacetal Waste incinerator 3.6.1 Current and Historical Background 3.6.2 Waste Characterization 3.6.3 Combustion Product Characterization 4.0 RCRA VERIFICATION INVESTIGATION - SCOPE OF WORK 4.1 Hydrogeological verification Program 4.2 A-1 Du Pont Local Landfill 4.2.1 Soil Sampling Program 4.2.2 Groundwater Investigation 4.2.3 Leachate Sampling Program 4.3 A-3 River Bank Landfill 4.3.1 soil Sampling Program 4.3.2 Groundwater investigation 4.3.3 Leachate sampling Program 4.4 B-4 Anaerobic Digestion Ponds 4.4.1 Soil Sampling Program 4.4.2 Groundwater Investigation 4.5 H--14 Burning Grounds 4.5.1 Groundwater investigation 4.6 C-6 Polyacetal Incinerator Test 4.6.1 Emission Sampling 4.6.2 Emission Analysis PAGE 39 39 39 42 44 SI 51 52 52 52 52 53 53 53 S3 54 55 55 55 55 56 CF031558 EID480936 List of Figures, Maim 1 Facility Location Map 1A Facility SWMU Location Map 2 Generalized Stratigraphic Column 3 Pond 1 - Core Analysis 4 Pond 2 - Core Analysis 5 Pond 3 - core Analysis 6 Waste Well No. 1 - Drilling Log 7 Waste Well No. 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 s w m u A-l Local Landfill 12 Proposed Sampling Location Map for SWMU A-3 River Bank Landfill 13 Proposed Sampling Location Mapfor SWMU B-4 Anaerobic Digestion Ponds 14 Proposed Sampling Location Mapfor SWMU H-14 Burning Grounds page 3 4 5 20 21 22 27 28 29 30 40 45 46 47 48 C F031559 EID480937 m S T OF TABLES number 1 Description of Geologic Units 2 solid Waste Types Disposed in the Local Landfill 3 Summary of Leachate Analytical from the Local Landfill 4 Test Well 27 - State Analytical Form 5 Test Well 25 - State Analytical Form 6 Well 331 - State Analytical Form 7 Summary of the Local Landfill Shelby Tube Analyses 8 Pond l - pre-excavation Analytical Results 9 Single Sample Analysis After Sludge Removal 10 Summary of the Waste Composition in the Anaerobic Digestion Ponds 11 Summary of the Monitoring Well Data for the Waste Injection Wells 12 Monitoring Well Analyses -combined Blennerhassett 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 ERA Constituent List 18 Summary of Sampling Media EMI 7 10 11 12 13 14 15 23 23 24 31 32 33 34 35 36 49 50 CF031560 EID480938 M PENDXCE? Title A Injection Well Summary Local and Regional Geology Structural Features ,aaa l 2 16 B Quality Assurance/Quality control Plan See Index in Appendix C QA/QC: Polyacetal Product Incinerator Emission Testing 1 Quality Assurance Plan See Index in Appendix 2 Sample Collection Methods and Procedures Plan 1 1 2 57 D Community Relations Plan 1 I Health and safety Plan see index in Appendix 1 F References A-l Local Landfill Soil Characteristic Tests 1 Analytical Data Taken from B-4 Anaerobic Digestion ponds During closure 23 Supemate Pends - Analysis of Core Samples 24 Addendums Supemate Pond Samples Analysis 31 Triton*1 X-100 in Upstream Supemate Pond Sludge 32 No, 1 Supemate Pond Sludge Analysis 33 Analysis of Supemate Sludge Samples for C-8 36 Pennslyvania Drilling Company Test Borings 37 supemate Pond Soil Samples, 3/30/88 41 Zinc Content of Upstream Supe m a t e Pond Sludge 42 Letter, A, C. Huston to D. W. Robinson, WVDNR 43 Zinc Content of Soil Samples 47 Upstream Supem a t e Pond composite Sldge Smpl Anal 48 Supemate Pond Soil Samples, 5/27/88 50 Supemate Pond Soil Samples, 1/9/89 51 supemate Pond Amount of soil Excavated 52 F-ll Special Reports for Waste Well No. 1 and 2 53 Washington Works No. 1 Waste Disposal Well 54 Washington Works No. 2 Waste Disposal Well 85 F-ll Waste Well No. 1 Reworking Notes 108 Letter, S. A. Savage to J. A. Davies, WVDNR 109 Plasties - W.W., No. 1 Waste HC1 Well, 12/20/66 ill Plasties - w.w., n o . 1 waste HCl well, 10/13/70 114 F-ll Test Well 25 and 27 and Well 331 Analytical to Date 132 Test Well 27 133 Well 331 135 Test Well 25 139 H-- 14 Burning Ground soil Logs 145 General - Appendix ix Analysis 154 CF031561 EID480939 VI Plan - Page 1 1 . 0 INTRODC ON . l.l objectives E l * du Pont de Nemours & Co. entered into a Hazardous and Solid Waste (HSWA) permit with the 0.S. Environmental Protection Agency (BFA) Region effective as of December 13, 1989 This permit requires the development and implementation of a RCRA verification investigation (VI) Workplan at du Font's Washington Works facility located in Parkersburg, West Virginia. The objectives of the VI is to perform an environmental study which will achieve the following: fll investigate if a release of hazardous waste or ' ' hazardous constituents occurred to the groundwater via four solid Waste Management Units (SWMU's) ; (2) submit additional information on one SWMU. (3) Characterize the combustion products released during burning of polyacetal products (C--6) , and (4) Determine the future investigative and/or implementation needs. The Verification investigation (VI) Workplan is divided into two major sections. The main body of text contains the general site history and proposed technical approaches which will be implemented during the course of the VI. The required VI procedural documents are contained as separate attachments to the main body of text. 1.2 Scope The Verification Investigation as required by the oermit will determine if a release of hazardous waste or^hazardous constituents has occurred or is lively to occur from any of the six identified SWMU'd. The vi will provide sufficient information for EPA to determine if a NCSA Facility Investigation (BFI) is warranted. At the time the VI report is written, it will be determined if further investigations are warranted or if corrective action measures should be implemented or if no further action or investigation is required. C F031562 EID480940 VI Plan - Page 2 2,0 SITE DESCRIPTION AND HISTORY 2.1 site Background and History The E.X. du Pont de Nemours & Company Washington Works facility is located in Wood County, West Virginia, approximately seven miles southwest of Parkersburg, 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, Nylon molding powders and filaments, Lucite* acrylic molding powder, and later polyvinyl butyral, acrylic resins, fluoropolymers, and polyacetals. The Color and Processing Division was started in 1968 as a small lot custom color compounding operation. in 1985, the U.S. EPA. requested Washington Works to provide information concerning sixteen units identified as potential Solid Waste Management Units (SWMU's). The review of the material contained in the June 5, 1985 submittal document resulted in issuing a RCRA h s w a permit requiring a Verification Investigation (VI) for six of the original sixteen identified SWMU's. The location of these six are shewn in Figure A-l. The data in the 1985 submittal was sufficient to remove ten units from any further investigation. 2.2 Geologic and Hydrologic Conditions The surficial soils covering the site are derived from the in-situ weathering of the underlying Permian bedrock and are Quaternary Ohio River Valley alluvium. The Quaternary alluvium is relatively coarse-grained, unconsolidated sediment and serves as the major source of groundwater in the area of the plant. These shallow aquifers are limited in areal extent. The underlying , bedrock is dominantly claystones, shales, siltstones, and thin sandstones of the Permian or Pennsylvanian formation of the Dunkard Group (see Figure 2). It is likely that perched water tables are present in the sandstone horizons and that they are recharged by precipitation and surface runoff and fluctuate seasonally. 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. CF031563 EID480941 C 7031564 EXD480942 FIGURE 2 vi plan - Page 5 crmnBiC SYSTEM CENOZOIC PERMIAN pe n n sy l y a n ia n RPIUIP OB FORMATION QUATERNARY ALLUVIUM DUNKARD MONONGANELA CONEMAUGH ALLEGHENY PTT5VLLE m ississipp ia n DEVONIAN DEPT.H-X.Et). DRILLER'S fORMATjONS 0 iQrouwj L*v*11 DASE OF USOV 500 -- COV RUN SAND _ 2ND SALT SAND -- 3RD SALT SAND -- BIG fWUN SAND - -- COFFEE SHALE BEREA SANDSTONE CHEMUNG GROUP DEVONIAN SHALE BRAIL ER;FO.:R*M`AT;' OHIO BROWN SH HARRaL SHALE MARCELLUS SHALE ONONDAGA LIMI GR1SKANY SAND OHIO/BROWN or DEVONIAN SHALES CORNIFEROUS LIME 0R1SKANY SAND E. I. D PONT DE N E M O U R S & C0 . INC. WASHINGTON WORKS WASTE DISPOSAL WELL FIELD WOOD COUNTY, WEST VIRGINIA _____ GENERALIZED STRATIGRAPHIC COLUMN BENEATH THE WASHINGTON WORKS SITE C F031565 EID480943 VI Flan - 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 geomorphology. 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. Groundwater 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 Rivet valley. High yield, good quality ground water can be produced from these alluvium aquifers. The topography and general geomor phology at the site indicates the groundwater flow is north toward the river. The 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.o. The natural quality of the groundwater in the bedrock is usually hard (calcium/sodium bicarbonate type), alkaline, and of moderate iron content (Wilmoth, 1966). Iron , is also present in concentrations great enough to cause staining and/or discoloration of the water. CF031566 EID480944 VI Plan - Pag ? TABLE 1 GEOLOGIC UNITS DESCRIPTION Name Age Thickness Description & Lithology Quaternary Alluvium Dunkard Group Monengahela Group conemaugh Group Allegheny/ Pottsville Group Cenozoic o-ioo Permian/ 300 Pennsylvanian Pennsylvanian <300 Pennsylvanian >500 Pennsylvanian >650 Brown and gray, poorly to well-sorted clay, silt, sand, and gravel. Red and gray-green shales, thin-to-massive sandstones and some thin limestones. Shales (generally red), thin sandstones, and some limestone. Calcareous shale, thin limestones, and chert Thin-to-thick, fine-tocoarse-grained, light colored channel sands and light-to-dark gray shales. Not: Total Dissolved Solids (TDS) data was not available Du to the similar lithology of the groups, exact formation thickness could not be determined. CF031567 EID480945 VI Plan - Page 8 3.0 BACKGROUND AND WASTE CHARACTERIZATION 3.1 A-l Du Pont Local Landfill 3.1.1 Currant 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 been filling the 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 summarizes present average landfilled 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 on the eastern side of the landfill monthly and analyzed for pH, chloride, fluoride, TOC, and COD (see Table 3), This information will be used as baseline data to compare any future sampling. Groundwater quality data collected on 8/6/87 from the three wells indicate there is no water quality problem in any of these wells. This is based on U.S. IPA Drinking Water Duality standards. Test Well 27 has 5 feet of screen in the 566.7 to 538.07 foot sandy gravel zone and is located approximately 600 feet from the closest portion of the north western boundary of the Local Landfill. The well is approximately 98 feet deep. The well had a specific conductance of 560 micromhos, total iron 2.78 mg/1, sulfate 81 mg/i, chloride 40 mg/1, and 0.01 ag/1 total organic carbon (TOC) (see Table 4), CF031568 EID480946 VI Plan - Pag 9 Test Well 25 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 of 780 micromhos, TOC 0.4 mg/1, total iron 2.05 mg/1, sulfate 32 mg/1, and chloride 61 mg/1 (see Table i). Well 331 has 15 feet of screen in the 565 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 indicates specific conductance of 460 micromhos, TOC 2 mg/1, total iron 0.19 mg/1, sulfate 89 mg/1, and chloride 22 mg/1 (see Table 6). The well is locates 100 feet from the Ohio River and is known to be influenced by the river. The water quality data from this well is considered background of 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 if 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 mg/1 and 1.8 ug/1 nitrate as N and Test Well 27 contained 3.59 ug/1 chloroform, ,23 mg/1 aluminum, 2.4 mg/1 iron, and 1.2 ug/1 nitrate as N. 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 standards, The other contaminants present during the first set of analyses were considered to be lab contaminants., fable 7 is a summary 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 of 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 x 10-8 to 9.57 x 10-6 cm/sec in soils from 7.5 to 9.5 ft. deep. CF031569 EID480947 VI Plan - Page 10 Table 2 Constituents SOLID WASTE TYPES DISPOSED OF IN THE LOCAL LANDFILL m ama Average Ifes/day Minimum lbs/day First Fifth Maximum Year Year lbs/dav mtons/yr mfcons/vr Acrylic Slurry (Dry Bas.) (1) 55Q 0 4000 100 100 Mixed Plastics (Dry Bas.)(2) 155 0 1500 30 30 Ash (3) 100 0 2000 20 10 (1) This material is a mixture of inert acrylic solids and water. The material is greater than 40% solids. Suspension agents and residual organics comprise less than 0.5%. (2) This material is mixture of inert mixed plastics such as polyamides, polyvinyl butyral, fluoropolymers, pol^actal, polyethylene, and terephthalates. (3) This ash could contain some aluminum or steel components. The ash is NOT E. P. toxic. SOLID WASTE TYPES DISPOSED OF IN THE LOCAL LANDFILL PAST , Fly Ash Bottom Ash Polyamides Acrylics Polyacetal Polyvinyl Butyral Polyethylene Terephthalate Fluoropolymers Paraffin Wax Paper and Cardboard Class and Misc. Solids Scrap Metal and Piping Putrescible Wastes (very small amounts) CF031570 EID480948 VI Plan - Page ll TABLE 3 DUPONT ROAD LANDFILL LEACHATE DATE 12/10/86 1/29/87 2/27/87 3/31/87 4/23/87 3/29/87 6/26/87 7/31/87 8/26/87 9/30/87 10/30/87 11/24/8? 12/29/87 1/29/88 2/24/88 3/15/88 4/12/88 5/20/88 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 CHLOR IDES (PPM) 7.82 35 7.57 166 7.67 155 7.30 30 7.80 140 7.90 439 8.33 569 8.08 614 7.90 646 7.90 625 8.00 760 7.30 658 7.66 1 8,00 278 7.70 129 7.70 86 8.00 95 7.90 239 8.30 98 8.00 533 8.20 599 8.20 435 8.30 414 6.00 211 7.60 50 7.60 9 8.20 33 8.10 55 8,10 120 8.30 87 8.00 153 8.20 274 7.40 34 7,80 10 7.60 108 7.60 120 7.60 143 TOC M 10 9 6 ? 8 17 18 20 N.S. N.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 N.S. 16 0 16 0 12 38 124 56 64 64 62 28 20 20 24 20 16 20 41 70 24 20 16 28 44 ODOR FLUOR- FLOW IDES (GPD) #1 CHEM (PPM) 0 NON! 0.01 #1 SULF 0,01 NONE NONE 0 0.01 #1 SULF 0.02 #1 CHEM 0.02 #1 CHEM 0.02 #1 SULF #1 SULF 0.03 0.02 #1 SULF 0.03 #1 IND WST 0.30 !1 SULF 0.25 #1 SULF 0.10 #1 SULF 0.09 #1 IND WST 0.06 #1 SULF 0.09 #1 SULF 0.18 #1 MUSTY 0.26 #1 SULF 0.32 #1 SULF 0,02 0 0.22 0.40 #1 MUSTY 0.19 0 0.07 0 0.72 NONE 0.08 #1 CHEM 0.13 #1 MUSTY 0,12 NONE 0.16 NONE 0.17 #1 GRASSY 0.18 GRASSY 0 *IS NONE 0.16 NONE 0.05 #1 SULF 0.19 NONE 0.13 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 86400 86400 43200 OTHER ANALYSIS : 10/18/88 HARDNESSi 619 5/30/89 HARDNESS: 333 SULFATE: 90 CF031571 EID480949 TABLE 4 VI Plan - Page 12 STATE0' *IST ArctMEA anTTAfe oqvhhdgive in assets re* Q"*" " y 1* `" I ` raa P o n t .CO.- CoMfejemT O ^ i l n a t a n w o r k s , p k a h n w v t m of XxiM iVi J L M t U l ____ C m atini_________ tStmiUBmmma HU tdMKiftettlAMr, 12?.-.. ,Ufti^iDuP. Coord.91EfeCw. 4214"" * HK** of fcilUw. Cable Tteola_________ on. Sept. 57 tool Duptiii 53B?n7 jugfaa th m u o t: 531.321u ^ n ^ m > ___~ " r - l l f j j __ fvt of CMimt earfaan S teal Utmtmg of c*Wn*t 7 ___ Qaptm of term Cmmii afl.n?_____________ _ Zero CfM ta Aquittri 538 .O f" f e w Grant*: Jjbng___ 1YT* of Sreufcu*i None......... mmu a m in zatm t 566.7 - 538,07 Utisiaoy of Ktuur 8**rirajZoom: Sandy Qeavel nte* of SKpUnfi j (Hap___ BailM ___ etiier(BMsife*is . D"M* -- SZfiZai-------- M a **> --------- & * * * * * . S S I.82 * iO .O' BIlllMTlm _fii______________________________________________________ _ ........ aWWCTWHf___________ _ ... . . . . . . . mil aueciivoan i*. OmtoA Omnm Omni . Meal OilMlllCllllll <*tei* SMBMiHi ............... ..- .. Sofia _ _ .. __ ttmi txm ..... ... mamma .... .. . ... Umiam- .... caoemaKN 7.4 56* 202 309 349 25 580 0 0 .01 `86 14 9 1.3 2.78 .04 .1 ... 40 ----*! matMilli M a U a tH ------- - m 81 2 <1 . .03 <.001 tuns 1 .0 . * f/l m /1 M/l M/l M/l tmil . M/l .... M/l M/l M/l. M/l mil m n~~ . M/l M/l M/l M/l ..... mil i ! C F031572 EID480950 TABLE 5 VI Plan - Page 13 state o r h ist v tic n A initial o aw w H aeiv c wcu. s s tn ro w u e < u o n t W a s h in g to n W orks Pkg> WV 0i AcdLvieyt ^x. __ ,, S W litigation Ojt ihnMuiiCOwccnnbb t ) ------ y^teliieA lar tMMMci .. Utitwfrs D l^.0 0 0 1 ^ .5 3 0 ^ ^ ^ = Jgflfl-- *U * rah la 'tools O f asipiaadt August, 17 te**i 9*0**" fyi* of Otfingi ed of f a * 11 $urc* Elm tiani Carbon " c***d: 537.81 TVS* of aow iogi 6111.51 Upggdiftti ---- Oa*wmimi I , SUo*tar of Ciu*)i _77,,,, ______ 'ZMM Opwt ea teujfwh 542* .Level... H3a w*e SMtfios term* 161-537,81 utJflow ofw*r teasing&** Sandv Qfavel ---- -- -- -- -- ***** of a*pMgt JL . * *___ -- otheriDweriten---------------------- a/fi/fl? Dc** opa was*7S-4> QI to sam ple ifMMXf* OaCWlUMSCM ua -- g.. _ --------------------------- - _ TWT11HTT 1 `......' m*mm**+*T .. TM1|`| ""^ B 7:14 s.o. 58* 3P ... -- - 1 ______ __________ '3 3 4 2 _______ m /l _ 454 --------- m il------- Tnt,\ impbM mlidfl - rt--t.<i*w 16 n*A 780 aAsssijfti. 0.0 ....... 0.0 m il -4...... ......... .. m il 120 m il------- 20 "*A_____ 34 A ------- 1.0 --------- m il-------- TBMt KCTl . ------- *J 2.05 .02 "1 BS/l m il -----m tk,----- 1 ....... 61 .6l6 ' -M fl------* A ------- .... 32 ,_,,,M at fil^MiJUiirrM 2 <1 -M ft... -- "A ---- 1 .2 .. -M /l-------- .03 _________ 1 f t <.001 H fl------- C F031573 EID480951 TABLE 6 VX Pian - Page 14 stAit or est t/taciH istmi, swnsivs hm, repcrt asm wmbi--h X, Du Pen t Qo. taxation;W&shXnc^fctjriWorXs, PlcskA^,W fypl o f S i v l t y t x L m d flU -- - Stwy irr: _Ottfgto-- crib * y id w T ti i ie a t i (MMatei 3 3 1 tw iM M i i^thad s i stiUkMi Cable foo l s -- 352 9 ijxqicuda: 4 3 3 9 .2 5 ------ J ia t* sa^lasM ti J u ly . 1960 to ta l f t * * * 5 3 fl;7 * a u rfa e t tU r*m m i , M 3 .. , UpsrwJiwtJ -- _ OcMiqcidisnei typv Ot CMinft carbon Steel-- --- c*pti oi m m cawa gg^ i --- ,-- - ia m Sroutad: TliP* o f Gsm xiiqi D im ta r of bavins 20* m m Opan ea to u ifa ri IS* MteK aaarinq la m t 565* t o 5 3 8 .7 Utielasy of Hteairavannj Sews Sandy Gravel Hatted s i SaapUmi J L , * m 8^ esnw<o*veUsv> ........... ... saw a/6/a?___,,On*" **' 68.3* Oapt* to saltivi 342* 91' wms* ^1 anlirfa (HnliTnrf.ral v1--1" " " l a flWtfWtl tn' -- A.IAakt ------ coemnwncH ues 7.5 - s.o. 58* lib _ . m &------ 202 __________ M i____ 225 tasJl 7 m il 460 miima' 0.0 *8/1------ 0.0 . m il____ 2 - M i ____ 52 mi 11 -- mux--- 16 m il 1.7 m il .19 _________ " in .... .42 __ ___ ______ js I L _ ,, <0.1 22 a t /1 ----- .015 m il------ 89 _ m il.....-- <1 . <1 _ <.05 .07 <*M1.. . ati l ,, ..- m il------- mil CF031S74 EID480952 V I P la n - P age 15 1ID480953 TABLE 7 LABORATORY TEST StMWY Local Landfills VWSHlNGTOu WATERWORKS PLANT Sample No.* B-l (Local) 8-1 (lo c a l) B-2 (L ocal) B*3 (L o ca l) B-3: (lo c a l) B-4 ( lo c a l) B-4 ( l o c a l) B-5 ( l o c a l ) B-5 (local} B-7 ( l o c a l) B-7 ( l o c a l) Depth f t . 3 -5 5- 7 7.5 - 9.5 2.5 - 4.5 5-7 7 .5 - 9.5 . 1 0 - 12 5- 7 7 .5 - 9.5 2.5 - 4 3 Visual D escription R eddish brown SANDY CLAY w ith s o f t sh a le fragments S h a le , s o f t , brown Brown and g ra y SANDY CLAY w ith sandstone firap en ts Bk m i SANDY CLAY w ith s o f t sh a le fragments Reddish brawn SANDY CLAY L ig h t brown SANDY CLAY Broken SANDSTONE Reddish brown SILTY CLAY Red SILTY CLAY Brown SANDY CLAY w ith rock fragments Sandstone fragm ents Uniform C la s s ific a tio n ML . SM Hu-CL H.-CL HL-CL MH Mi a * A lso I n d ic a te s w e ll num ber a s shown o f F ig u re 1-A PH 7.4 .7.2 Perm eability on/sec Not su ita b le f i r testin g Not suitable f ir testing 937 x U f6 6 .0 4.88 x l(f8 6 .3 2 .43 x ID*8 7.1 Nat suitable for testin g - Mot s u ita b le f i r te s tin g 6.4 1 3 7 x H f8 6 .0 1 .99 x IQ"8 6.8 2.05 x K f6 Not su itab le f i r testin g *> t- in (O o * ;,-T \ 'J 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 of 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 acrylic 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 leachate 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). ... Small quantities of RCRA hazardous ash were landfilled prior to 1980 when the ash residues tested 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. Toxicity test, 3.2 A-3 River Bank Landfill 3.2.1 Current and Historical Background conditions The River lank 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 123 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 fill material with 6 to 36-inches of soil and then vegetated. This landfill extends approximately 2,4Q0 feet parallel to the river bank and is up to 50 feet wide in some places. CF031S76 EID480954 VI Plan - Page 17 We 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 micromhos specific conductivity, 89 mg/1 sulfate, and 2 mg/1 TOC. A 10/6/88 Appendix IX analysis reported .60 mg/1 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 workplan. As indicated in section 2.2, the groundwater flow direction is unknown at this time. The upgradient and downgradient wells for this unit will be verified after the flow gradient is con firmed by the program descriped In section 4.1. 3,2.2 Waste Characteristics Powerhouse ash, plasties, rubble, and plant trash were disposed of in the landfill. The landfill wastes were dry, since plant policy has always been to burn all liquid waste, At one time, approximately 200 waste drums of solid material were buried in the landfill. One of the materials landfilled was RCRA hazardous ash, which resulted 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 of 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 6 feet deep with sloped, earthen banks about 22 feet wide at the base. The combined volume capacity of the three ponds was about 3 million gallons. CF031577 EID480955 VI plan - Page 18 This unit was initially constructed as a single pend in the mid-1950's. in the mid-1970's, this pond was enlarged and two more ponds were added. All 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 237 feet and approximately 6.0 ft. deep. The capacity was estimated to be 553,000 gals, and the volume was 12,324 ft3. When this pond was reconstructed in the mid 1970's (1973-74), a natural clay layer was used in the walls and polyethylene sheets were placed on the walls. Then 6 to 12-inches 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's (western most pond) dimensions were 76 ft. by 134 ft. and approximately 5,9 feet deep. The capacity of the pond was estimated to be 457,000 gals, and the volume 10,184 t3. 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 perfluorooctanoate (also called 0-8), Washington Works is in the process of purchasing these wells from Lubeck water supply. Pond 1 was closed in January 1988. A 22.5 foot, 22 off vertical core sample was taken 23 feet north (past the berm) of the center of this unit to characterize the subsurface lithology and to determine the level of contamination. Figure 3 summarized the results. Approximately 56,700 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, 22o off vertical core sample was taken 19 feet north (past the berm) of the center of this unit to characterize the subsurface lithology and to determine the level of contamination. Figure 4 summarizes the results. Approximately 43,000 cubic feet of soil was excavated from this pond including the 6-foot high berm. Pond 3 was closed in November-December 1988. A 22.5 foot, 22o off vertical core sample was taken 16 feet north (past berm) of the center of this unit to characterize the subsurface lithology and to determine the level of contamination horizontally from the unit. Figure 5 summarizes the results. Approximately 46,900 cubic feet of soil was excavated from this pond including the 9-foot high berm. Figures 3 through 5 summarize the initial results taken from these ponds. A total of approximately 14,012,500 lbs. 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 fort Triton; c-S; polytetrafluoroethylene (PTFE); total zinc; E.P. toxicity 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. After each pond was emptied, a 4-foot core was taken in the center. Chemical analyses were performed on the four samples taken at 1-foot intervals to determine if all the contaminated ' material had been removed. The results of 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 2-feet 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. It is located approximately 50 feet south of the parking lot along Route 892. CF031579 UD480957 4 c LU J> I '1 Ses"d^ip VI Plan - Paga 20 CFO31580 EID48Q958 SUPERNATE TOWD N O 2 -M ID D L E CORE ANALYSIS FIGURE 4 )-------- / 9 ' - --------- * PPM X ce TRITON 4 0.10 1 pm m w PPM ZM pm F IT PPM CL PTFE r, uRGwHIC % HINEAAL 70 & 0 0.38 2.90 .00 i .20 24 0.10 14 0.20 07 0.78' 1.2 0.10 8 0.10 B 0.10 02 0 92 7 64 67 0 l . i 7.10 2.90 2.1:0 34. 0 0.2 5.20 3.20 2.60 0 0.3 6.10 3.60 3.0m 0 0.2 2.00 2.00 2.71* 95.3V 0 0.1 2.20 1.90 2.SO 0 0.1 3.09 1.30 1.6* ,J.3w a o w in CO ^ II SCALE / a - 1 t total z in c w WATER SOLUBLE VI Plan - Page 21 EID480959 SUPERNTE POND NO. 3 - WEST CO RE ANALYSIS IB P C ffT SAMPLE CORE 2 2 OFF VERTICAL ALE %8 * / 9 PPM X ca TH1T0N i t.4 ` 2 0.10 4 .2 ' 0 0.10 -7.O' 3 ^0.10 9.7* 29 0 .20 12.5' 70 0.50 /5.5' 60 . 0.30 8J0% 9 <0.10 2 0 .8 1 <0.10 PPM 2N 77 78 81 120 77 73 62 70 t TOTAL ZfNC W WATER SOLUBLE FIGURE 5 m u EID480960 i PPMw ZM PPMw F Hr PPM MOKI X * CL PIPE 0ftV*NlC MINCPAL 0 0.1 1.10 5 0.2 0.50 0 0 i 0 4 0.3 0.2 0.2 0.3 1.60 1 .10 2.20 2.00 4 0.2 1.00 0 0.2 2.70 2.60 2.90 2.50 3.00 2.00 2.40 2.00 2.10 7.SO 03.9O 0.10 31.00 3.00 34.50 3.00 93.10 3.30 93.00 ?.rm 94.80 1.70 36.30 2.60 95.40 VI Plan - page 23 TABU 8 POfld 1 - Pre-excavation Analytical Results sample Depth l foot 2 feet 3 feet 4 feet % TritonR m /M 5.9% 5.8% 1.4% 1.2% ppm C-8 mg/kq 610 258 NO 234 ppm m 34 37 26 21 TABU 9 gingie Sample Analytical After Sludge Removal Sample ppm Zn Pond 1 (east) 0 .1 Pond 2 (middle) 0.3 Pond 3 (west) 0.8 Cornfield 0.3 (background) frfrjtton 0.29 0.25 0.18 0.03 POH C-8 110 66 173 <4 %PTFE 0,07 0.03 0.45 0 .0 CF031583 EID480961 VI Plan - Page 24 TABLE 10 H&ffiCB COMPOSITION FOR ANAEROBIC DIGESTION PONns BOD COD Suspended Solids Detergent pH 700 ppm 3,000 ppm 700 ppm 26,000 ppm 10 Trace components less than 10 ppm: NH40H Citric Acid CaC12 Duponal d-Limonene Glass Bubbles Ethylene Glycol Tektamer Ammonium Perfluorooctanoate Teflon M (also known as c-8) Caustic Soda Tyzor LA Zonyl Freon I Glass Beads Ba(N03)2 Zinc Chloride Cyclohexane/High Boilers Hexafluoroethane Polytetrafluoroethylene 38 AD Biocide (also known as PIPE) CP031584 EID480962 Vi Plan - Page 25 3.3,2 Waste Characterization This unit treated waste from a fluorocarbon manufacturing process. The waste was number of d6!?fgmi with quantities constituents summarized in Table 10of a . (proceeding page). Liquid from the ponds was i n w s a off`site when '" its ceased operating 3.4 P-11 Injection Wells Mo, 1 and Mo. 2 3,4.1 Current and Historical Background Conditions two deep wells were installed for injection of plant wastes generated by the operating divisions (see Figure 1-A), Construction of j Wel1 N o * 1 (l"WW) began in September 1966 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 n o . i disposal well (1--WW) operating in 1969 and was plugged on 2/24/76. The geologic injection unit is the Big Injun, a quartz sandstone of Mississippian age and corresponds to the Greenbrier unit, well No. 2 started operating in March 1972 and was plugged on 11/14/80. The waste in Well Mo. 2 was injected into Middle Devonian age shales, over ^ "Yfar period of operation, a total of 112.5 million gallons of acid wastes was injected into these two wells. Washington Works Mo. 1 (1-WW) disposal well was drilled to a depth of 1,677 feet and bridge , plugged back to 1,483 feet, A geologic core was collected from the intervals 1,419 ft. to 1,435 ft., 1,526 ft. to 1,351 ft., and 1,538 ft. to 1,609 ft (see Figure 6). The well was cased (injection casing) with 1,233 ft, of steel casing with 246 ft, of reinforced fibercast as a bottom hole injection zone extension. It was cemented with 430 gallons of Dowell K-70-71 acid-proof cement to 1,207 ft., and with 300 of,class A cement from 1,207 ft. to the surface (see Figure 7), Injection tubing of 3-ineh Fibercast Epoxy Tubing was implaced to the middle of the perforated zone. The CF0315S5 EID480963 VI Plan - Page 26 injection casing was perforated from 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 No. 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 of 31 joints of 5-1/2" liner with a special 10 foot machined Hastelloy sleeve to a depth of 1,314 feet. 3. Cementing the 5-1/2" liner in place with an acid resistant cement. 4. Drilling out cement left inside the casing and flushing out the sand plug. 5. purging twice with nitrogen and fresh water. 6. A short term 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 term injection test indicated that the well had been rejuvenated to near its original capacity (150 gpm 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 238 feet reinforced Fibercast and 12 feet of Hastelloy-C as a bottom hole injection zone extension, was cemented with 1,166 gallons Haliburton LR-ll acid resistant cement to 3,608 feet and 1,000 sacks of pozmix cement with 14 percent salt. Shot holes at 2,919-foot depth were squeezed with 450 sacks of common cement with no returns, Shot holes at 2,134-foot depth were squeezed with 500 sacks of common cement to ground surface. No cores were taken during drilling but lithologic information was obtained from geophysical logs (see Figure 9), Nine wells are used for groundwater 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 CF031586 EID480964 VI Plan - Page 27a CF031587 EID480965 CF31588 EID480966 V I p Xcm - P a g a 2 7 c i' % pS i, a ji . L ^ IL V J. II i-- - + *%\ | i i * i\k 1 rrc %?* * 1* 1 i i i r $ i <* * !' !' 10 s j 0? i t 0\ ls ? S felfe I i " H y e' Sk iVi fi'fS |N wi %t ,i! T T v i ii i*` k ! ;i ! 1' i Ui i&f i1! ! : , iU '_ _ L j ---t -j- ' , , ` i ; i i 1i s 1 $ t fe $ fe & >4jfcv V* > ! 4 ! J* ! fe- * fe r |ya*| . ir f ? * * np-..si -j **, . >- : %Nt * m T M f-1 ;4 ; : .,; .i 'i? --= 4. f* j fe 5' \ 2 i i1 . 1 i i i i :? 1 i' i i ' - sl l a i 5 : * 5^ i ! s?: ?. 4 , = + i !fc| 'n-T- ' h f i ii ! 4T i !i! i--r- i n 4- 4- 4- 4* !! 4141+1i, I 1 1ii 5T r i 1 ~r *i r1 t i fe i j + r X r fe fe 5 <--irr * | fr!"Co* i ^' u * ,7: ? ?*;? ? : : i? i? h3 ; ` *j* i; ' ^94 tti" l! l| `5 ,i< 9 |L ! ; L M ih r _Lk fe fe i i fe % % T . * t I k i --= 4- L ** 1 i bi l fe i fe % 4 fe m % l > T !1 l m I fe * * Tf i V 1 5 W' i TtV- ?r I K f X ii \ r X\ X\ % x X X * XX\ X X Xi fe ir * ' ~}r ; ?*r r r\ l r E ^ ; J*" P s . :T ii > f l S1 ~r~ i '\ X X X \ !?! c 4 * X X\ 1` r j r :; ;' i ii It ; $ *% \ fe i i i i t 1} i \ * 1 \ 1 \ i> l 1 ,1 fV \ 1 1 \i s \ w n r ir -1 i ff . *c 3 ; >. t ! h i s '4 ' : w i j \ . 1' i ` Fi : : 14. * i4 ! * | \ !^ F ; i [ o 1 r.xysi ta"a#v<n0 & ;? a J o^ > 1 . en { . __ 1 fv * \" CF031589 EID480967 CF031S90 EID480968 VI Plan - Paga 27e * CF031591 EID480969 vi plan ** Page 28 FIGURE 7 4 CF031592 IID 480970 I W B3TE D I S P O S A L W L L - W A S H I M G T Q N VI plan ` Pa9 29 w f i B K * O V E R A.MQ f t g P A I * A S P . A M S c M g K i T FIGURE 8 ouAPAce API C*M**4T- M O W U N A V O '': Iivtfi m y g g P ' O M a r a Ik n ^ '*Tgaj_. STISL- 4%* * m w K * * r i w t enow 7y*l *70 PT oli. pilli* a w n u u m i AL COVtwT MTwetW P i M o e A t r u m no % *t v LAd ANO* PUN C4> , PLua&ts jfceLLAPMD CASH *- * * m a t . u M i R IL PM.UO ANNULUS O^mOMOASTUMi VmameAor N ^ s e m i Tuewft BPHAL eCMCNT 0i*IMir&LflV 0*07 ui^AOO.wtuLiocno % n u x u v r u tw rmtouvr u m h V ^oncAor oitfienoM t u o i m ! LOAD A*4#0t OINOt (4 B * W *00*70 I 0*07-7 CF031593 EID480971 CI'031594 EID480972 CF031595 EID480973 VI Plan - Page 31 TABLE 11 SUMMARY OF MONITORING NELL DATA FOR THE WASTE INJECTION WELLS Monitor Well No. Injection Facility HO.. Vertical Distance to Injection Zone 577-Red 1 745 2 2,910 23 (replaced w/ 20) 1 2 1,395 3,560 20 1 1,395 2 3,560 331 1 1,395 2 3,560 307 (replaced w/ 331) 1 2 1,395 3,560 BLENNIRHASSETT* ISLAND WILLS 1 2 1,395 3,560 Horizontal Distance to Injection Zone 650 850 925 700 650 575 6,070 6,350 1,275 1,680 7,750 8,150 *1316 sample taken from this "monitor well" was combined or, averaged sample from six wells on the island. The distance for this "monitor well" is the nearest well to the disposal wells. CF031596 EID480974 VI Plan - Page 32 TABLE 12 MONITOR WILL ANALYSIS OP COMBINED BLENNERHASSETT ISLAND WELLS DATE ES 7-12/73 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 10/25/83 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 7/25/89 10/24/89 7,21 7.46 7.46 6.96 7.12 7.10 7.11 7,12 6.93 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 CHLOR TOC IDES (PPM) (PPM), 38 N/ 36 7 32 12 33 42 27 39 28 24 35 22 38 18 34 0 27 18 27 18 33 52 30 8 26 11 26 0 36 7 40 72 33 4 26 8 43 0 34 30 30 34 26 0 33 2 31 13 27 9 30 7 31 0.05 32 3 38 1 30 1 31 1 31 1 30 1 32 3 33 1 26 2 45 0 35 2 29 2 26 2 28 10 CF031597 IID480975 VI Plan - Page 33 4 TABLE 13 MONITOR WELL WATER ANALYSIS - WELL DATE IS CHLOR- TOC IDES (PPM) (PPM) 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 10/25/83 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 7/25/89 10/24/89 8.31 8.38 7.83 7.74 7.96 7.73 7.36 7.76 7.49 7.66 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 7.12 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 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 26 26 41 47 15 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 <1 CFO31598 EID480976 VI Plan - Page 34 TABU! 14 MONITOR WELL WATER ANALYSIS - WELL 23 DATE IS CHLOR- TOC IDES (PPM) 5/31/73 6/29/73 7-12/73 1- 2/74 7.32 29 6 7.55 26 N/A 7.70 27 23 NO SAMPLES - WELL DRY REPLACED WITS WELL *20 (SEE APPENDIX E) CF031599 EID480977 VI Plan - Page 35 TABLE 15 MONITOR WELL WATER ANALYSIS - WRT.t. 1-n? DATE Ml CHLOR TOC IDES mm (PPM) 5/31/73 6/29/73 7-12/73 1-2/74 3/74 10/20/77 3/23/78 7/20/78 9/79 7.53 7.72 7.74 7.54 7,40 7.23 7.49 7,40 7,76 47 48 51 56 53 60 25 55 62 28 N/A 23 22 18 39 61 28 30 REPLACED WITH WELL #331 (SEE APPENDIX I) C F031600 EID480978 Vi Plan - Page 36a TABLE 16 MONITOR WELL WATER ANALYSIS WELL #WOO 577 RED PAGE 2 OF 3 DATE 83 CHLOR TOC ODOR IDES 1/ 5/77 2/ 3/77 3/ 2/77 4/19/77 5/11/77 6/ 9/77 7/15/77 8/11/77 9/15/77 10/20/77 11/16/77 12/12/77 1/12/78 2/16/78 3/22/78 4/13/78 5/10/78 6/19/78 7/20/78 8/23/78 10/19/78 11/16/78 12/14/78 1/11/79 2/22/79 3/22/79 4/26/79 5/30/79 6/28/79 7/26/79 8/23/79 9/27/79 10/25/79 11/15/79 12/19/79 1/10/80 2/14/80 3/20/80 4/24/80 5/ 8/80 6/ 5/80 7/10/80 8/20/80 9/ 4/80 5.15 6.15 5.38 4.17 5.55 5.05 5.32 5.46 5.3 4.76 4,95 6,41 4.84 5.07 5.05 5,74 6.00 4,53 6.73 6.61 5.50 5.57 5.95 5,77 6.32 5,63 5.85 5.84 5,30 5.22 5.64 5.87 6.05 6,30 6.56 6.35 6.79 6,65 6.73 6,90 6,88 6.10 5.97 6.11 33050 9656 26345 34169 36240 34998 35267 34206 33500 35611 35294 32067 32662 34361 34757 34141 34376 33701 33062 34362 33482 30531 33882 33568 32598 33730 35133 34323 34554 34343 33569 32149 32757 32757 34825 35564 31489 40978 40084 37375 38474 32290 38722 42041 19 14 11 24 34 8 17 5 a 5 1 25 35 10 17 30 18 10 27 30 42 28 8 8 12 16 17 35 42 56 9 44 51 63 12 4 13 48 11 7 17 25 9 41 NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE HYDCBN NONE NONE NONE NONE NONE NONE SALTY NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE GRASSY GRASSY NONE NONE NONE GRASSY CF031601 1ID480979 Vi pian - Paga 36b TABLE 16 MONITOR WELL WATER ANALYSIS - WILL #WOO 577 PAGE 1 OP 3 DATE El CHLOR- TOC ODOR IDES rppM> ism 5/31/73 6/29/73 1-12/73 1" 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 11/ 7/74 12/ 6/74 1/10/75 2/ 7/75 3/ 6/75 4/ 9/75 5/12/75 6/ 3/75 7/10/75 8/ 6/75 9/ 3/75 10/8/75 11/ 6/75 12/ 4/75 1/ 8/76 2/ 4/76 3/ 4/76 4/ 6/76 5/ 6/76 6/ 7/76 7/13/76 8/ 9/76 9/ 9/76 10/ 5/76 11/ 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 6.83 6,96 6,99 7.00 6.81 6.92 7.02 6.51 6.49 6.49 6.53 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 6.60 6.32 6.63 6.16 5.92 5.46 5.67 34800 33800 33600 33600 34800 35416 34907 34297 32566 33279 34952 35792 35477 35267 35372 23951 33737 33939 31742 35205 33964 33163 32960 35012 40799 32300 30800 30800 33048 45251 34481 32483 32414 34847 34805 32960 32758 36354 37059 34341 33639 34331 32399 34155 34299 N/A 22 13 8 37 23 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 U 1 6 5 22 N/A N/A N/A N/A N/A NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE H/A NONE NONE NONE N/A NONE NONE GSSEY NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE NONE CF031602 EID4O980 VI Plan - Page 36e TABLE 16 MONITOR WELL WATER ANALYSIS - WELL #WOO S77 RED PAGE 3 OF 3 DATE m CHLOR TOC ODOR IDES (PPM) (PPM) 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 4/29/85 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 7/25/89 10/24/89 6.44 4.91 5.46 4,77 4,13 5.64 4,99 5,95 4,77 5,50 6.42 5.36 4.97 4.58 4.39 4.75 4.47 5.45 4.68 5,33 5.54 6,10 6.30 6,5 6.10 6.80 6.60 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 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A CF031603 EID40O981 VI Plan - page 37 Blennerhasset Island wells (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 from 5/31/73 until 7/20/78 when the well was taken out of service, W00**5?7 red has been 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. Gas 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 ppm. This is a flowing well. Test well 20 was monitored twice in 1974 and then continuously from 10/20/77 to the present. The background chloride concentration is 36 ppm. 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 these wells are contained in Appendix P. This is the Affidavit of Plugging and Filling the wells 1-WW and 2-WW. 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 wells at the facility, in order to effectively evaluate the capability of the existing monitoring wells ability to detect a release from 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 the 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 the area surrounding Parkersburg. , CFQ31604 EID480982 VI Plan - 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 acid and formaldehyde from the polyacetal division, and vent scrubber effluent containing organics from the nylon manufacturing operation, fluorocarbon chemicals, and hydrogen fluoride (<10,000 ppm). The temperature of the waste material at the point of injection was approximately I05oc. 3.5 H-14 Burning Grounds-Liquid/Selid 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 LA). 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 this 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-Eastern GeoTech Inc. Marietta, OH. The test boring log reports indicate the soil along the eastern side 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 legs. This indicates there Is no potential for residual release from the soil. A moisture density relationship test of the soils was performed. The results showed a maximum dry density of 115.6 lbs/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 ft3 of soil was removed. No gross contamination has been reported during this construction project. CF031605 IID480983 VI Plan - Page 39 3*5.2 Waste Characterization The liquid wastes that were turned at this area include acrylic monomer slurries, Butacite^tt ink slurries, and high boiling liquid fluorocarbon compounds? as well as solvents in use at the plant. The solids included paper, trash, and plasties. 3,6 C-6 Polyacetal Product Incinerator 3.6.1 current and Historical Background The polyacetal 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 (see section 3.6.2) are burned in the unit. The polyacetal product incinerator consists of two (2) screencovered brick-lined burning pits. The two pits are collectively referred to as one (1) unit. Each pit is constructed of reinforced concrete lined with fire brick. Screens, on rollers, are placed over the pits during incineration. Each pit is a box with approximate inside dimensions of 9 ft by 10 ft by 10 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 4.5.2 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 EID480985 o u 0o) J 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 the site are not fed to the incinerator. Historically, only grades of D e l r i n 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 toluene. These materials are fed to the unit in eardboard boxes lined with polyethylene plastic or similar fiber containers. Chemical area tank and sump cleanings also contain formaldehyde-based polymeric solids, and these are also burned in the product incinerator following such cleanings. Empty 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 non-standard batches of these concentrate mixtures may be burned in the product incinerator. These concentrates include stabilizer concentrate which may contain nitrogencontaining compounds such as Nylon and carbon black color additive. These 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 the following Appendix VIII hazardous constituents may be present in the finishing area wastes fed to the product incinerator: Formaldehyde, m-Cresol, and potentially trace quantities of Ethylene oxide. Hazardous Constituents As a part of the review of chemical area and finishing area waste feeds to the product incinerator, the waste feed materials compounds were reviewed to determine if they contained one or more of the sixteen (16) volatile and semi volatile compounds listed in Attachment 1 of the RCRA CF031608 EID480986 vx Plan Page 42 Corrective Action Permit as analytical requirements for Unit C-6. Most f those compounds are not used in the manufacture of Oelrin, and several of these compounds do not appear to be used anywhere on the site. Of the compounds on Attachment l of the RCRA Corrective Action Permit, only m-Cresol and Toluene are suspected to be present in the feeds to the product incinerator. r The hazardous constituents that are known or suspected to be present in the waste materials fed to the product incinerator ^l^ermaidehyde, Toluene, m-Cresol, and possibly Ethylene 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 polyacetal products in unit c-6. This characterization of the combustion products is necessary to ensure that any hazardous constituents known or suspected to have been released to the air from the unit will be sampled and analyzed. As with any burning process, the principal combustion products frem the product incinerator should be carbon dioxide and water. Since some waste feeds may contain nitrogen, it is likely that some small quantity of nitrogen oxides will be evolved during combustion of these materials. Also, as with any burning process, some low level of carbon monoxide (CO) is generated 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, m-Cresol, and possibly Ethylene oxide) may also be present in the off gases from the unit. Additionally, it 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, aldehydes (e.g., formaldehyde) and ketones (e.g., methyl ethyl ketone) are potential decomposition products and PICs. And, for aromatic compounds such as toluene and cresol, benzene is a potential p i c . Phenol is another potential Pic from the combustion of cresol. 1 . The volatile and semi-volatile compounds listed in Attachment 1 of the RCRA Corrective Action Permit as analytical requirements for Unit C-6 were reviewed to determine which of those compounds would be likely PICs from the burning of the 01-031609 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 on 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 feed (Formaldehyde, Toluene, Ethylene oxide, and m-cresol) as well as the three compounds identified as potential PICs (benzene, methyl ethyl ketone, and phenol) were next reviewed against EPA's Principal Hazardous Organic Constituent Thermal Stability Index (Appendix D of "Guidance on Setting Permit conditions and Reporting Trial Burn Results," January 1989) to determine the likelihood of their presence or absence in the air emissions from the unit. Although the unit does not closely resemble a hazardous waste incinerator for which one might typically use the index, the conditions in the unit probably resemble the post-flame-zone-like low oxygen conditions that were used to establish the index. This "incinerability" index ranks compounds in descending order of difficulty of destruction. Benzene is ranked number 3 on the index and is a Class 1 compound. Class 1 compounds are considered to be more difficult to destroy by burning than Class 2 compounds; Class % compounds are considered to be more difficult to destroy than class 3 compounds; and so ?n * Toluene (ranked 35) and Formaldehyde (ranked 48-50) are both Class 2 compounds, Phenol (ranked 100-101), m-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. Given that it is considered to be much easier to destroy by burning than the other compounds and that it is thought to be present in the feed to the unit at lower (if 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 i n d u d e the sampling and analysis for the following hazardous Formaldehyde Toluene m-Cresol Methyl ethyl ketone Benzene Phenol CF031610 EID480988 VI Plan - Page 44 4.0 RCRA VERIFICATION INVESTIGATION (VI) - SCOPE OF WORK The premise behind a Verification Investigation (VI) is to determine if a solid waste management unit (SWMU) has released contaminants to the environment or not. A VI is not intended to be as detailed an investigation as a RCRA Facility Investigation (RFI), but a simpler, field screening process. Six SWMU's require some fora of investigation under Washington Works HSWA permit. Appendix A is the supporting information requested for unit F-ll, Injection Wells No.l and No. 2. No investigation plan was required 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 leachate collected. Unit H-14 Burning Grounds does not include a soil investigation plan, only a groundwater investigation plan, one unit will have an air sampling program. The six units are: A-l Local Landfill, A-3 River lank Landfill, 1-4 Anaerobic Digestion Ponds, H-14 Burning Grounds, F--ll Injection Welle No. 1 and No. 2, and c--6 Polyacatal Waste Incinerator. 4,, normal of analytical for all groundwater investigated will be the list the U.s. EPA requested unless otherwise noted (see Table 17). We have requested a shortened list for soil sampling. Table 18 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 maps included under each SWMU investigation plan in this section (Figures 11 through 14). 4.1 Hydrogeological Verification Program Several cross-sections of the SWMU areas will be > constructed to illustrate the proposed monitoring wells capacity to monitor a potential release. The groundwater flow direction needs to be mor firmly established on the site prior to determining any upgradient or downgradient monitoring wells. It is believed the river is the recharge zone and the stratigraphy dips to the southeast. But, surface i ili|J CF031611 EID480989 FIGURE 11: PROPOSED SAMPLING LOCATION MAP FOR SWMU A-1 DUPONT ROAD LANDFILL I VI Plan - Paga 45 VT Pint " Page EID480991 FIGURE 12: PROPOSED SAMPLING LOCATION MAP FOR SWMU A -3 RIVER BANK LANDFILL o o w 2 CO i; t - SAMPLE POINT BOO' - 15* FIGURE 13: w PRO PO SED SAMPLING LOCATION MAP FOR SW MU B -4 ANAEROBIC DIGESTION PONDS VI Plan - page 47 10480992 VI Plan - Page 43 EID480993 l tn flfcuRE 14: fe PROPOSED SAMPLING LOCATION MAP VI Plan - Page 49 TABLE 17 E M CONSTITUENT LIST SsMa Antimony Arsenic Barium Cadiurn Lead Mercury Nickel Selenium Silver Cyanide (amenable) chloreethane Chlorodifluoromahttne Chloroform 2-Chloronaphthalena 2-Chlerophenol Chrysene m-Cresot o-Cresol p-cresol 0ibenzCa.hJanthrocene Di-n*butyl phthalate Haxachlorobanzene Hexschlorobutadiene Hexachloreeyelopentadiena Hexachloroathene Indenoll,2,3*edjpyrene Methyl bromide Methyl chloride Methyl ethyl ketone Methyl iaobutyl ketone Methyl methacrylate Methylene chloride Volati tes/SajivaletilM Acetone Acrolein Acrylonitrile Anthracene Benzene Benzslalanthrecene BenzoCb]fluoranthene 0Diehlorebef8ene Bichlerobenzene p-Diohlerobenzene 3 ,3 '`pichlercbetBidine Diohlerodifluoromtehane 1,1`Dichloreethane 1.2- Dichloroethane 1,1 -0 ichlorethylane trane-l,2-Dlehloroethytene Naphthalene p*Nitroanitine Nitrobenzene p-NItrophenoi N-Nitroaodiphenylamine M'Nltrosodi>n-propylamine Pentachlorophenol Phenanthrene Phenol Benzolfc]fluoranthene 1.2- Dichlorepropane Pyrene Senzotajpyrene 2,4-Diehlorophenol 1>1>12*Tetrachloroethane Bie(2-chloroethoxy)i>thane Cls-1,3*t)1chloropropene 1>1>22-Tatrachloroethane BI(2-chloroethyt)ether Biethyl phthalate Tetrachloroathylene Bisc2-chloroisopropyl>ether 2,4-pfmethytphenol Toluene BisCZ-ethylhexylJphthlate Dimethyl phthalate 1.2.4- Trichlorobenzcne Bronodlehloromethane Brqmoform 4,6-Dinftre-e-creaol 2,4-Dinitrophenol 1.1.1- Trichloroothane 1.1.2- Trichloreathene 4-Bromophenyl phenyl ether 2,4*0initroteluane Trichloroethylene Butyl benzyl phthalate 2,6-Dfnftrototuane Trichlorofluoroaethane Carbon dieulftde Di-n-octyl phthalate Triehloronaphthatene Carbon tetrachloride Ethylbenzene 2.4.5- Trtehlorophenot p*Chloroanfline Fluorinthane 2,4,6*Trfehlorophanal Chlorobenzene Formaldehyde Vinyl chtorfda p-Chloro-arcrMol Formic acid CF031616 E ID 480994 vx Plan - Page 50 TABLE 18 SUMMARY OP SAMPLING MKTvra, SWMU A-l Local Landfill A-3 River Bank Landfill B-4 Anaerobic Ponds H-14 Burning Grounds TOTAL SAMPLES PROPOSED sail 21 9 6 0 3$ Media Groundwater 15 9 4 10 38 Leachate 2 0 0 8 CFQ31617 EID480995 VI Plan - Page 51 suggests the ground water flows to the north round nf>^^f1Vfr* tWe are PrPsing that one complete Wate? leYel measurements be taken in all available monitoring wells to establish a better understanding of the groundwater flow pattern on the 4.2 A-l Du Pont load landfill 4 .2.1 Soil Sampling Program A soil sampling and analysis program will attempt to determine if subsurface contamination exists. Figure 11 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 1PA and the WVDNR if changes in the location or number of samples is necessary, and will be finalized in the field prior to drilling. Hhree 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. lach sample will be field checked for contamination by placing a portion of the soil in a polyethylene bag, shaking the bag, and inserting < ? Pf?8 of 30 Organic Vapor Analyser (OVA) into the bag and measuring the organic vapor content. The OVA will detect if any organic contamination is present in the soil. It is proposed that the soil samples be analyzed Toxic metals, formaldehyde, and formic T?ese compounds were chosen after of review of the landfilled materials. The OVA will act as CF031618 EID48Q996 VX Plan - page 52 an organic contamination screen, if 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 penetrometer 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. Bight will be collected from existing monitoring wells and 7 will be from the cone penetrometer soil sample locations. Figure 11 Illustrates the proposed locations of the groundwater sampling locations. Figure 1-A shows the well locations, It is proposed the groundwater samples be analyzed for all the parameters the u.s. e p a Region III requested (Table 17). 4.2,3 Leachate Sampling Program It is proposed that six leachate samples be collected, one will be taken from each of the three leachate collection pends located in the eastern portion of the landfill. The remaining three samples will be taken from the 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 Program The soil around the River Bank Landfill will be ' evaluated. Bine 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 D480997 VI Plan - Page 53 hm in the DuPont Read landfill, each sample will B o r t i S d0? ? h ked f?r .contaoeinatio1 by placing a th?hart n5hTSOiL in ? polyethylene hag, shaking VtthhaeepoborargAg,naanlaiycnzdveraipnso(eOrVrAct)ionngItnettnohte. thperobbeageannddomfeaasnurOirngag*nic 4.3.2 Groundwater Investigation Groundwater samples will be taken and analyzed for the parameters listed in Table 17 plus butyraldhyde, adipic acid, ammonium perfluoro- .bexamethyl 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 ' froa^est^ieli !?" nJhiCh is ths control sample afss ?thhe seaLmpfliing4p0o*4ints for0Xt0he**s*oilsamienvelsotciagtaitoinosn. ^felS,?F famPlinG points were not proposed in the anv^hrti-1 tQ characterize the buried waste because any hole could potentially create open vertical conduits through which hazardous material could 10W The groundwater sampling interval in the monitoring wells is above the bedrock and weathered surface material interface. The bedrock interface is approximately 00 to 100 feet below grade along the river bank and approximately 21 to 38 feet below grade in the a I063 Local Landfill, approximately 2000 feet due south of the river. Y 4,4.3 Leachate Analysis Two existing leachate streams will be sampled, one of *nd one on ?e rar east end. These samples will be analyzed for a3 i , ^ e constituents in Table 17 plus the six ch0" icala listed for the River Bank landfill groundwater. 4,4 B-4 Anaerobic Digestion Fonds 4 .4.1 Soil Sampling Program The data presented in section 2,5 provides the closure information for this SWM0, it is proposed to take two cone penetrometer cores from the center of the middle pond (#2) and the isef **& *** 13). M l three ponds were closed in the same fashion but native clay samples were not taken from ponds 2 and 3 C F031620 ED480998 VI Plan - Page 54 after excavation of the material. The samples will be collected at 1-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 was 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 of 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 taken 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 as a natural liner preventing downward contaminant migration. The purpose of this sampling is to verify this. The sampling profile from the collection tube is 6 to 8-inehes in length and 10 cm 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 can be collected to analyze for the requested list (see Table 17). The purpose here is to determine if the gross contamination was removed when the ponds were closed and it is known these were the only waste materials placed in these ponds. Table 8 is a summary of the waste analysis performed on the sludge prior to closure. 4.4.2 Groundwater Investigation P proposed groundwater sampling locations are 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 penetrometer cores* If any contamination has migrated toward the southern plant boundary, it will be detected in these sampling locations. CF031621 EID480999 VI Plan - page 55 The samples will be analyzed for C-B, Triton, PTPl, total zinc, soluble zinc, chloride, and fluoride. It 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 The proposed groundwater sampling locations are: Test Well 22, Test Well 1-6, Test Well 5, and seven cone penetrometer boring locations around the perimeter of the two buildings located in the area of the old burning grounds (see Figure 14 and Figure 1-A). The purpose here is to determine if there is any residual contamination to the groundwater. These ten groundwater samples will be analyzed for the parameters list in Table 17. .6 Polyacetal Product Incinerator The objective of this sampling and analysis effort is to determine the concentrations of hazardous constituents potentially present in the air emissions (based on the combustion products characterization) from the product incinerator. 4.5.1 Emission sampling In order to meet the objectives of the Verification Investigation for unit C-6, it was necessary to develop a sampling rationale that accounted for: o the specific sampling points for the unit with respect to the potentially affected environmental media, and ' o the population of possible sampling locations and how these were narrowed down to specific sampling points. The media of concern for potential release of hazardous constituents from the product incinerator is the air. The focus of this sampling and analysis effort is to identify hazardous constituents potentially present in the air emissions from the unit. C F031622 EID4810Q0 4 -J 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 constructionj 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 the pit is in operation. The "rake" sampling apparatus and sample collection techniques that will be employed are described in the Sample Collection and t 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" composite air sample from the top of a single operating pit was chosen 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 ) - .................................. -- ............................................................................................ C F031623 EID481001 VI Plan - Page 57 Product Characterization). In that section, it was found that six (5) hazardous constituents may be present in the air emissions from the polyacetal product incinerator. Specifically, it was found that one (1) 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 EID48102