nebraska department of environmental quality · 1---t carbon1 tetrachloride at the, water table...

15
o NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY Agenda/Meeting Record Date: April 13, 1995 Time: 9:00 am Place: Room 403, Nebraska Department of Environmental Quality File: Remedial Action Plan Monitoring Act Purpose of Meeting Introductory meeting with representatives of Garvey Elevators Inc. regarding the Remedial Action Plan Monitoring Act program and the gale of their Hastings property. Issues Discussed The meeting opened with Dave Traster, a lawyer representing Garvey Elevators, Inc., expressing his client's interest in working with NDEQ. He said Garvey wants to see their site become a state-lead site for remediation. Dave asked about our relation to EPA. He then outlined the issues to be dealt with at Garvey's Hastings grain facility. These issues are off-gas treatment, cleanup level goals, and alternate water supply issues. Rich Schlenker gave an overview of our RAPM program. He stressed the points that the program is voluntary, has an open application process, and a opinion letter will be issued by NDEQ once the site has reached the mutually agreed upon state of cleanup. Rich also briefly explained the objectives of the program and its funding. He emphasized the flexibility of the program and the fact that the applicants tell us what they want to achieve. Rich also stressed NDEQ's willingness to offer applicants information on innovative technologies which may cleanup a site quicker and cheaper than conventional remediation technologies. Dave said Garvey's goal is to receive a letter from NDEQ saying further cleanup at this site isn't required. He made the point that ARARs be met and said Garvey doesn't want to have to cleanup to MCLs. Dave asked again about our relationship with EPA. He said Kansas is very proactive and EPA isn't involved with many sites. He said EPA has come into a site where the potentially responsible parties (PRPs) are contentious. Dave said he wants to work well together with NDEQ and not have EPA as lead on the site. ru Rich mentioned Nebraska doesn't have a state Superfund statute. Marty said the <j Ground Water section deals with non-RCRA hazardous waste projects. Rich ° mentioned the NPL sites in the state. Rich said he believes EPA will stay out a . of the RAPMA program. He mentioned the Lindsay site where NDEQ took r- enforcement lead. NDEQ also had another similar site but turned both it and £• Lindsay over to EPA voluntarily. Dave said this is a concern for Garvey . ^ Elevators, Inc.

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Page 1: NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY · 1---T Carbon1 Tetrachloride at the, Water Table LEGEND 180,fao-ND Monitoring Well Designation With Carbon Tetrachloride Concentration

o

NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY

Agenda/Meeting Record

Date: April 13, 1995 Time: 9:00 am

Place: Room 403, Nebraska Department of Environmental Quality

File: Remedial Action Plan Monitoring Act

Purpose of Meeting

Introductory meeting with representatives of Garvey Elevators Inc. regardingthe Remedial Action Plan Monitoring Act program and the gale of their Hastingsproperty.

Issues Discussed

The meeting opened with Dave Traster, a lawyer representing Garvey Elevators,Inc., expressing his client's interest in working with NDEQ. He said Garveywants to see their site become a state-lead site for remediation. Dave askedabout our relation to EPA. He then outlined the issues to be dealt with atGarvey's Hastings grain facility. These issues are off-gas treatment, cleanuplevel goals, and alternate water supply issues.

Rich Schlenker gave an overview of our RAPM program. He stressed the pointsthat the program is voluntary, has an open application process, and a opinionletter will be issued by NDEQ once the site has reached the mutually agreedupon state of cleanup. Rich also briefly explained the objectives of theprogram and its funding. He emphasized the flexibility of the program and thefact that the applicants tell us what they want to achieve. Rich also stressedNDEQ's willingness to offer applicants information on innovative technologieswhich may cleanup a site quicker and cheaper than conventional remediationtechnologies.

Dave said Garvey's goal is to receive a letter from NDEQ saying further cleanupat this site isn't required. He made the point that ARARs be met and saidGarvey doesn't want to have to cleanup to MCLs.

Dave asked again about our relationship with EPA. He said Kansas is veryproactive and EPA isn't involved with many sites. He said EPA has come into asite where the potentially responsible parties (PRPs) are contentious. Davesaid he wants to work well together with NDEQ and not have EPA as lead on thesite.

ruRich mentioned Nebraska doesn't have a state Superfund statute. Marty said the <jGround Water section deals with non-RCRA hazardous waste projects. Rich °mentioned the NPL sites in the state. Rich said he believes EPA will stay out a.of the RAPMA program. He mentioned the Lindsay site where NDEQ took r-enforcement lead. NDEQ also had another similar site but turned both it and £•Lindsay over to EPA voluntarily. Dave said this is a concern for Garvey . ^Elevators, Inc.

Page 2: NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY · 1---T Carbon1 Tetrachloride at the, Water Table LEGEND 180,fao-ND Monitoring Well Designation With Carbon Tetrachloride Concentration

Dave said EPA is heavily involved in Hastings. He also said Garvey has 30,000ppm carbon tetrachloride at their Hastings site. Both Rich and Annette Kovarexpressed thoughts that because the Garvey site is on the west side ofHastings, and not by any Hastings Superfund subsites, EPA will not be inclinedto want to take the lead on the site.

The goal of Garvey Elevators, Inc. is to keep their Hastings site out of theSuperfund process. Dave and Richard F. Garvey said they will be doing all ofthe requirements of Superfund and some minor public participation without beingunder the program.

Mike Madcharo of HWS then gave a brief overview of the site (see attachments).The Garvey property has an on-site well inside one of their buildings. Thewell is contaminated with carbon tetrachloride (CT). Other nearby sites suchas Mike's Auction are also contaminated with CT. The Rolls property has a newdeep well which is clean but the old shallow well has CT contamination.

Mike said his company believes the CT is a dissolved problem and not a freeproduct problem. What gets through the clay lense enters a zone of hightransmissivity and moves east of the Garvey site. Mike said everything theyhave studied appears consistent with the nature of the area and elevatorproperty. The highest concentration of CT in the ground water has been 29,000ppm.

On the attached Figures 8, 9, and 10 the consultant has shown movement of CT inthree aquifer zones. Zone A is the area of the water table at 100 to 110 feetin depth. Zone B is at 130 to 150 feet in depth. Zone C is at 170 to 200 feetin depth. The plumes are moving toward the southeast.

Dave mentioned they are having difficulty getting a neighboring landowner toallow them to install an extraction system on his property. They requestedhelp from NDEQ. Mike said their inability to have access to this land has keptthem from having as good of an understanding of the 1,000 to 10,000 CT contourshown on the attached maps.

Rich brought up the alternate water supply issue. Dave said they offeradjoining homeowners the option of a new well into a deeper, uncontaminatedaquifer, or they offer a hookup to city water. He said they have had someproblems at the vadose zone and need soil venting to off-gas. Rich mentionedexperiences at the M-3 site in Hastings. Dave asked about a variance andtalked about riak-based levels for air emissions. Rich said it the emissionsrarely exceed the 2.5 tons/yr level.

Dave said he wanted to get a handle on costs and also to talk about anagreement. He mentioned putting a cap on charges as the Kansas program does.Rich said it isn't our intention to have lots of reviews to drive up costs.Dave said he is trying to budget and estimate costs. He said they would moveforward with the work plan and make application. He said they may want atightly drawn agreement. Rich said NDEQ would try to give them what theyneeded. Annette said it could also depend on the specifics of each individualsite.

Dave said AGP is buying their site for an ethanol plant. He talked abouthaving a covenant not to sue. Annette said she doesn't think there is any wayunder state law that AGP could be held responsible. She did say NDEQ couldprobably say they wouldn't sue anyone if cleanup was on-going. She said Garvey

Page 3: NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY · 1---T Carbon1 Tetrachloride at the, Water Table LEGEND 180,fao-ND Monitoring Well Designation With Carbon Tetrachloride Concentration

could propose an agreement if they wish. Dave and Richard produced two checksand signed the appropriate forms to begin the RAPMA process on the Garvey sitein Hastings.

Action Required or Pending

Process application and participation forms and fees and await arrival of workplan.

Follow-up

Maintain contact with Garvey Elevators Inc.

In AttendanceName

Jeff RaymondRichard F. GarveyMike MadcharoRich SchlenkerSean BrownBedford BurgherDavid M. Traster

Marty LinkAnnette Kovar

Department

NDEQ, Superfund SectionGarvey Elevators, Inc.HWSNDEQ, Superfund SectionHWSGarvey Elevators, Inc.Foulston & Siefkin for GarveyElevators, Inc.NDEQ, Ground Water SectionNDEQ, Legal Services

Person Documenting Meeting

Date

Page 4: NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY · 1---T Carbon1 Tetrachloride at the, Water Table LEGEND 180,fao-ND Monitoring Well Designation With Carbon Tetrachloride Concentration

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Page 5: NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY · 1---T Carbon1 Tetrachloride at the, Water Table LEGEND 180,fao-ND Monitoring Well Designation With Carbon Tetrachloride Concentration

DAVID M. TRASTERATTORNEY AND COUNSELOR AT LAW

FOULSTON & SIEFKINL A W O F F I C E S

700 FOURTH FINANCIAL CENTERWICHITA, KANSAS 67202

(316)267-6371FAX (316) 267-6345

RICHARD F. GARVEY

3228 CAMP BOWIE BLVD.MAILING ADDRESS: P.O. Box 96OO

FORT WORTH. TEXAS 76147-2600

817-335-5881

Page 6: NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY · 1---T Carbon1 Tetrachloride at the, Water Table LEGEND 180,fao-ND Monitoring Well Designation With Carbon Tetrachloride Concentration

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Approximate Scale:1 Inch = 2000 feet

NEBRASKA

QUADRANGLE LOCATION

FIGURE 1: Site LocationGARVEY ELEVATOR

Hastings, NebraskaNW 1/4, SECTION 23, T7N, R10W

m

aiC3C3P-

Page 7: NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY · 1---T Carbon1 Tetrachloride at the, Water Table LEGEND 180,fao-ND Monitoring Well Designation With Carbon Tetrachloride Concentration

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oFour Mom'toring We//sLocated At The CountyLandfill, Approximately.5 Miles West (2)and .5 M/7es West-Northwest (2)

Domestic WellLocated AtFairbanksInternational,Approximately500' West OfHwy. 6 &Marian Road

StarrProperty

Hastings Industrial Park West

£ Well LEggg.:. .rllf;._—lffi£^_..

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SITE PLAN ANDIMMEDIATE VICINITY

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DATE

11-23-94

JOB NO.

72-44-0029

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Page 8: NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY · 1---T Carbon1 Tetrachloride at the, Water Table LEGEND 180,fao-ND Monitoring Well Designation With Carbon Tetrachloride Concentration

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MONITORING WELLS& WATER TABLECONFIGURATION

3-21-95

LEGEND

' u$ 1 Monitoring Well Showing1819^16 Water El^vation ln A Wells

/.*Water Table Contour"-

Direction Of Groundwater Flow

A—A' Line of SectionShown in Figure 4

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Page 9: NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY · 1---T Carbon1 Tetrachloride at the, Water Table LEGEND 180,fao-ND Monitoring Well Designation With Carbon Tetrachloride Concentration

:CMV ANDS1LTY CLAY

CLAYEYSAND?

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Carbon Tetrachloride OccurrenceAt The Garvey Elevator Facility

Hastings, NebraskaHorizontal Scale

500 o 200 400

LEGEND

50

250 100Vertical Scale

0 20

25 10

300 500

40

JO 50

I

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NO

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Water Table Elevation

Carbon Tetrachloride Concentration("9/D 'None Detected

^Contour of Carbon Tetrachlon'de i" Contamination \

Screen Placement of Existing ,Monitoring Wells .

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Silt

Sand

Silty/Clayey Sand

Gravel

Shale

Page 10: NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY · 1---T Carbon1 Tetrachloride at the, Water Table LEGEND 180,fao-ND Monitoring Well Designation With Carbon Tetrachloride Concentration

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Carbon Tetrachloride OccurrenceAt The Carrey Elevator Facility

Hastings, NebraskaHorizontal Scale

500 Q 200 400

SHALE

LEGEND Clay and Silty Clay

250 JOO 500

Vertical Scale

50 0 20 40

25 10 JO 50

I Water Table Elevation

,on Carbon Tetrachloride Concentration180 (ug/L)ND None Detected100^Contour of Carbon Tetrachloride

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Page 11: NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY · 1---T Carbon1 Tetrachloride at the, Water Table LEGEND 180,fao-ND Monitoring Well Designation With Carbon Tetrachloride Concentration

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200 0 100 200

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Scale In FeetND

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Contour Line of CarbonTetrachloride Concentrations(Units are ug/L in Air)

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etrachloridelow Soil Gas

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Page 12: NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY · 1---T Carbon1 Tetrachloride at the, Water Table LEGEND 180,fao-ND Monitoring Well Designation With Carbon Tetrachloride Concentration

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M~m $11t

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ug}/(, Concentration In SoUat Depth Shown

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Horizontal Scale 180020 0 '0 20

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Page 13: NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY · 1---T Carbon1 Tetrachloride at the, Water Table LEGEND 180,fao-ND Monitoring Well Designation With Carbon Tetrachloride Concentration

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Monitoring Well DesignationWith Carbon TetrachlorideConcentration (Units Aremicrograms Per liter— ug/L)

Contour Of CarbonTetrachloride

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(Samples Collected in"A" Zone Wells)

N

800 0 400 800

400 200 600Scale In Feet

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Page 14: NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY · 1---T Carbon1 Tetrachloride at the, Water Table LEGEND 180,fao-ND Monitoring Well Designation With Carbon Tetrachloride Concentration

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Monitoring Well DesignationWith Carbon JetrachlorideConcentration (Units Aremicrograms Per liter—ug/L)

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'(Samples Collected in the r.\ "B" Zone Wells)

0 400 800

400 200 600

Scale In Feet

AS SHOWN

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Page 15: NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY · 1---T Carbon1 Tetrachloride at the, Water Table LEGEND 180,fao-ND Monitoring Well Designation With Carbon Tetrachloride Concentration

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Carbon Tetrachloride at the"C" Zone

EGENDIV-1

\i42 Monitoring Well Designation1 ' With Carbon Tetrachloride

Concentration (Units Aremicrograms Per liter—ug/L)

- Contour Of CarbonTetrachloride

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Scale In Feet

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