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DEPARTMENT OF ENVIRONMENTAL PROTECTION June 23, 2004 Ann Thayer
RE: Review of Water Quality Results - Data Through 2003 Dear Ms. Thayer: The Department has completed its review of the water quality monitoring data from Dragon's facility in Thomaston. This review includes data through the October 2003 sampling round. Please see the memorandum from Richard Heath, Project Geologist, dated June 14, 2004, for further details and clarification. 1. The leachate sampling locations DQl and CD1 continue to show what appear to be erroneously low specific conductance readings. 2. Since 1998, concentrations of inorganic parameters have shown statistically significant increases at monitoring well B2. Parameter concentrations at the remaining B-series wells appear slightly to moderately elevated. 3. Water quality at monitoring well C2 has improved significantly since 2000. Parameter concentrations at the remaining C-series wells appear slightly to moderately elevated with statistically significant trends for several parameters. 4. The pH at the leachate sampling locations has exceeded the hazardous waste criteria of 12.5 standard pH units on several occasions. 5. Surface water monitoring locations SP l and UNSl appear to be moderately to strongly impacted based on inorganic and indicator parameters. 6. Dragon's monitoring plan must be updated to include the installation of an additional background groundwater monitoring location. It should also be updated to include the statistical analysis of data trends or background versus downgradient wells. I am including Richard Heath's memorandum dated August 12, 2003. 7. Duplicate data submitted to the Department in the past has not included the location where the duplicate was collected. ===================================== Based on the information outlined above, Dragon must do the following: 1. Please investigate the possible causes for the erroneously low specific conductance readings at DQ1 and CD1 within 30 days of receipt of this letter. 2. Since water quality at monitoring well B2 is significantly impacted and continues to degrade, Dragon must initiate an evaluation of the cause of the deterioration vimmediately upon receipt of this letter. A report of the evaluation, prepared by a sealed and qualified professional, must be submitted to the Department for review and approval within 90 days of the date the evaluation is initiated. Please see 06-096 CMR 405.C(2)(i) for the requirements of the evaluation and report. If the Department does concur that a source other than the solid waste facility is the likely source of this deterioration, Dragon will be required to initiate Assessment Monitoring within 90 days of the date of the report mentioned above. 3. Please update your environmental monitoring plan (EMP) in accordance with Richard Heath's recommendations. Please forward the revised EMP to the Department for review and approval within 60 days of receipt of this letter. 4. Please submit all future monitoring data electronically in the current EDD format required by the Department. Please contact Richard Heath directly if you have questions about this. 5. Duplicate data submitted to the Department must include the location where it was collected. If you have any questions please call me at (207) 287-8491, write to me at the Augusta mailing address, or you may e-mail me at carla.j.hopkins@maine.gov. Carla J. Hopkifrs Bureau of Remediation and Waste Management
Encl: Memorandum from Richard Heath dated August 12, 2003 Memorandum from Richard Heath dated June 14, 2004 PC: Richard Heath. MDEP Project Geologist James Glasgow, MDEP Dragon Water Quality Review Thru 200; 06304.doc Dragon Water Quality Review Thru 2003 062304.doc Page 2 of 2 END ------------------------------------ |