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Refinery Casper, Wyoming B. Listed below are selected items pertaining to events which transpired after the inspection during the period August to September The program consisted of building a dike across the southern third of the CEP and pumping North Platte River water into the southern portion of the CEP for infiltration into the aquifer below.

Description

Refinery Casper, Wyoming B. Listed below are selected items pertaining to events which transpired after the inspection during the period August to September The program consisted of building a dike across the southern third of the CEP and pumping North Platte River water into the southern portion of the CEP for infiltration into the aquifer below.

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Attached to this report is an analysis titled "Effects of Chemical Evaporation Pond Recharge" which is an analysis of the aquifer recharge activities performed since October Recommendations of the analysis will be addressed in the h corrective action order issued on September 30,and which is discussed later in this update. The Report provided soil analyses of landfarm soils which showed parts of the landfarm to have elevated metal and oil levels.

These investigations were to determine extent and rate of migration of hazardous constituents in the landfarm soils. Texaco never conducted the requested investigations. The action was taken due to Texaco's failure to provide: 1 requested information, 2 permit application information, and 3 a demonstrated ability to manage a land treatment area in an environmentally safe manner. Texaco's application was denied and the facility was ordered to cease receiving wastes. Task Force Effort 1 2.

Task Force Objectives 1 3.

Introduction

Evaluation Procedures 1 B. Hydrogeology 2 2. Ground-Water Monitoring System 3 a. Task Lokking Sampling and Monitoring Data 10 4. On-Sitc Inspection 13 3. Background 14 2. Regulatory Background 18 3. Facility Operations 20 4. Solid Waste Management Units 21 C. Regional Geologic Setting 28 2. Regional Hydrologic Setting 28 3.

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Site Geology and Hydrogeology 29 4. Hydrogeology of the North Area 44 5. Hydrogeology of the South Area 55 D. History of Interim Status Monitoring 62 b. Compliance with Applicable Regulations a. Interim Status Program b.

History b. Hydrocarbon Recovery System E. Texaco a. Sampling and Analysis Plan Review b. Field Implementation - Sampling Dqting 2. Task Force a. Techniques of Sampling b. Interpretation of Data 3. Data Comparison Task Force and Texaco 4. Comparison to Past Texaco Data F. L Regulations promulgated pursuant to RCRA 40 CFR Parts througheffective on November 19, and subsequently modified datting hazardous waste site operations including monitoring of ground water to ensure that hazardous constituents are not released to the environment.

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The Administrator of the U. Environmental Protection Agency U. The Task Force is generally comprised of personnel from EPA headquarters core team, regional offices, and the states. Task Force Objectives The principal objectives of the investigation at the Texaco Refinery in Casper, Wyoming were to determine the following: a Compliance with the requirements of 40 CFR Subpart F - Ground-Water Monitoring b Evaluate the existing information on the ground-water protection program for potential compliance with 40 CFR Part c Evaluate the existing and proposed ground-water protection program for potential compliance with 40 CFR Part d Verify the quality of the facility's ground-water monitoring data e Evaluate the sampling and analytical procedures employed by the facility f Collect ground-water samples using the Task Force Protocol in order to evaluate and compare analytical with those collected by Texaco in addition to determining the presence of hazardous waste constituents.

Evaluation Procedures To meet the objectives of the task Force evaluation for the Texaco facility in Casper, Wyoming, the following activities occurred: a Compilation and analysis of all relevant data, reports and correspondence from U.

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EPA Region VIII files and files present in the offices of Wyoming DEQ in Cheyenne, Wyoming 1 b Sampling audit of facility's ground-water sampling procedures conducted from June 18 to June 20, lf c Collection and subsequent analysis of ground-water, surface water, hydrocarbon and pond liquid samples obtained from August 11 to August 15, d Site inspection and interviews with facility personnel and contractors from September 29 to September 30, Some of the information obtained from Texaco was acquired well after the Task Force site visit in August These data have been utilized in this report where required to support the Task Force's evaluation of the current ground-water monitoring program.

For simplicity, the Task Force's findings and conclusions below have been subdivided into sections corresponding to those of the technical report Part II. Hydrogeology Two aquifers of concern exist in the North Area. The uppermost aquifer is composed of unconsolidated eolian sands and alluvial deposits, and the consolidated Teapot Sandstone, subcropping in the eastern portion of the facility.

The second aquifer consists of unconsolidated alluvial deposits located within the North Platte River floodplain. The second aquifer is tower than the uppermost aquifer, but this difference is topographic, not stratigraphic. Even though the two aquifers are not connected in a geologic or hydrostratigraphic sense, the uppermost aquifer recharges the alluvial aquifer by means of see along an intervening bluff.

The only aquifer of concern in the South Area is the unconsolidated alluvial aquifer. Except where the bedrock outcrops, the alluvial aquifer is present throughout the South Area. North Area The major potential contaminant pathways include the North Platte River and its associated alluvium, and possibly the Teapot Sandstone. All the above are used for water supply east of the site. The potential for contamination of the Teapot aquifer is undefined at the present time.

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Testing of downgradient Teapot wells for contamination is recommended. Escape of contaminants to the east, around the bedrock high and through permeable lenses in the unnamed middle member of the Mesaverde Formation are possible pathways to the river. While no bedrock aquifers underlie the South Area, migration of contaminants to the northeast may impact the Teapot aquifer.

This pathway is presently undefined and conjectural. To reach the subcrop of this 2 eval-B aquifer, migration off-site to the northeast must take place. The distance to the subcrop of the Teapot Sandstone from the eastern boundary is not defined. Ground-water Monitoring System a. North Area Ground-water Monitoring Systems The ground-water monitoring system in the North Area is currently regulated under interim status.

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The land farm is currently accepting and disposing waste under interim status. Caspee to Texaco, the CEP ceased to accept wastes after Juneand was closed under interim status in Due to this contamination, Texaco initiated an assessment monitoring program to delineate the. Texaco originally considered the two regulated units as one hazardous waste management unit.

At no time has Texaco deated monitoring wells as part of a detection monitoring program under interim status for the North Land Farm, even though they maintain that contamination is from the CEP. Because a detection system has not been deated, baseline and statistical data are not available. This information must be presented as Texaco intends to ror into detection monitoring under 40 CFR upon permit approval.

Interim Status Ground-Water Monitoring 40 CFR The present assessment monitoring program for the North Area as interpreted by the Task Tor has several technical deficiencies that may not allow for an evaluation of the rate and extent of Loiking in the ground water. Texaco is required by 40 CFR A thorough evaluation of the adequacy of the existing monitoring wells to detect such phases should be initiated.

These data are needed for a complete evaluation of the extent and migration of contaminants in the uppermost aquifer as required by 40 CFR As ly mentioned under hydrogeology, the full extent of the uppermost aquifer and the possible extent of the CEP contaminant plume may not be completely evaluated.

This is due to the potential 3 for hydraulic communication between the Teapot Sandstone, a potential contaminant pathway, and the alluvium. The subcrop of the Teapot lies to the east of the CEP. Texaco must determine the rate and extent of migration and concentration of hazardous waste in the ground water 40 CFR Currently, Texaco has made the above determination on only four parameters TOC, phenol, sulfide and ammonia.

The rate and extent of migration and concentration of all Appendix VII wastes must be established. As part of defining the rate and extent of contaminant migration under 40 CFR This is important under assessment monitoring as the dimensions of the plume are bound to be affected by the recharge of the CEP as part of Tcxaco's remedial action plan for this ground-water contamination.

Texaco has not proposed, as part of their interim status assessment program, data evaluation techniques which will fully address plume migration. This is a very important point in that when a corrective action program is initiated under 40 CFR A of possible analytic procedures could be applied to existing data to further assess the effects of recharge datinh river water on the attenuation of contaminant concentrations in ground water in the CEP area. These could include, but not necessarily be limited to, the following kinds of analyses: o Trend analyses of contaminant concentrations versus time in monitoring wells, in an effort to isolate the effects of river water recharge from attenuation effects occurring prior to recharge.

Monitoring wells might be grouped according to their distances downgradient from the recharge pond in an effort to eliminate some fr in the data. In addition, the wells at which maximum quarterly concentrations are detected should be identified, and an assessment made as to whether or not there is an identifiable trend of distance of maximum concentration from the CEP versus time.

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Similar geochemical studies might be possible using other chemical species. Furthermore, by treating the recharged water as an ideal tracer within an appropriate mass-transport model, it should be possible to estimate the attenuation due solely to dilution and dispersion effects, and thus provide estimates of the attenuation due to chemical and biological degradation phenomena.

Texaco should expand the sampling and analysis of indicator parameters e. These data can be used not only to correlate with the indicator parameters, but to evaluate the effectiveness of corrective action in attenuating concentrations of organic constituents in the future. Under 40 CFR Once Texaco determined that waste constituents had entered the ground water, they were required to continue monitoring these constituents on a quarterly basis 40 CFR

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