June 14 2004 Memorandum between 2 Maine DEP officials reviewing Dragon's water quality testing results.

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TO: Carla Hopkins, Project Manager, Division of Solid Waste
FROM: Richard Heath, Senior Geologist, Division of Technical Services
DATE: June 14, 2004
RE: Review of Water Quality Results
Dragon Products Company
Thomaston, ME
Cement Manufacturing Facility

General Comments

Water Quality Data
In reviewing water quality results for the Dragon Products, Inc. facility I graphically represented data of major ions and indicator parameters on time-series plots for:

· Groundwater monitoring locations associated with the CKD pile (attached Figure 1);
· Groundwater monitoring locations associated with the Clinker pile (attached Figure 2);
· Leachate for both the CKD (DQ1) and Clinker piles (CD1) (attached Figure 3); and
· Surface water monitoring locations (attached Figure 4)

I visually inspected these time-series and performed statistical trend analysis using the Mann-Kendall test. A tabular summary of water quality at these locations is provided in Table 1. Results of upward and downward trend analyses are included in Tables 2A and 2B, respectively. A summary of exceedances of MCL and MEGs is provided in Table 3.

The leachate sampling locations (DQ1 and CD1) continue to show erroneously low specific conductance (SpC) readings. The most likely reason for this discrepancy is the improper reading of the gain function on the field conductivity meter. Field personnel should be instructed in the proper reading of the instrument.

The following paragraphs provide a general assessment of water quality.

Figure 1 - CKD Pile Groundwater Monitoring Results(TO BE ADDED)

The most apparent impact to groundwater quality associated with the CKD pile has occurred at monitoring well B2; which is screened in bedrock approximately 46 to 50 feet below ground surface. Since approximately 1998 concentrations of inorganic parameters have shown statistically significant increases at this location. In addition, the predominant anion at B2 is sulfate which is also the predominant ion associated with the leachate sampled at DQ1.

Parameter concentrations at the remaining B-series monitoring wells appear slightly to moderately elevated. Several locations show statistically significant trending in several parameters. Most notably B2B shows upward trends in Na, Ca, Cl, and SO4; and B1Z shows downward trends in specific conductance, TDS, Ca, and Na.

Figure 2 - Clinker Pile Groundwater Monitoring Results (TO BE ADDED)

Historically the greatest impact to water quality associated with the Clinker pile occurred at C2; screened in bedrock approximately 125 to 129 feet below ground surface. Water quality at this location has improved significantly since 2000. This is supported by statistically significant downward trends for a number of parameters; although I still consider the location to be moderately impacted.

Parameter concentrations at the remaining C-series monitoring wells appear slightly to moderately elevated with statistically significant trends for several parameters. The water quality at these wells appears to remain generally unchanged at these wells since approximately 2000.

Figure 3 - Leachate Monitoring Results (TO BE ADDED)

Leachate quality for both the CKD pile (DQ1) and the Clinker pile (CD1) is dominated by potassium and carbonate. Sulfate is also elevated at DQ1 and periodically exceeds carbonate values. As shown in the following time-series plot, the pH for each leachate is generally greater than 12 and has historically exceeded defined hazardous characteristic criteria of 12.5 standard pH units .

Figure 4 - Surface Water Monitoring Results (TO BE ADDED)

Surface water monitoring locations SP1 and UNS1 appear to be moderately to strongly impacted based on reported inorganic and indicator parameter results. When last sampled in 2002 the Quarry surface water locations at Q1 and Q5 also appear to be moderately impacted.

Groundwater Monitoring Plan
My most recent memorandum commenting on a proposed monitoring plan is dated August 12, 2003 (Footnote 1). In this memo I recommended:

· Installation of an additional background groundwater monitoring location; and

· Inclusion of statistical analysis of data trends or background vs. downgradient wells in the monitoring plan.

An approved finalized version of the monitoring plan should be completed as soon as possible.

Recommendations

1. Water quality at B2 is significantly impacted and continues to degrade. Statistical analysis shows significant upward parameters trends at this location. I recommend that the water quality for B2 be reviewed based on the requirements of Chapter 405 Section 2.C.(2)(i) and (j).

(i) If the results of detection monitoring indicate a possible deterioration in water quality at one or more ground water monitoring wells or surface water monitoring points, the owner/operator of the solid waste facility shall initiate an evaluation of the causes of the deterioration in water quality within 30 days of its receipt of the laboratory results. A report of the evaluation, prepared and sealed by a qualified professional, must be submitted to the Department for review and approval within 90 days of the date the evaluation is initiated. The report may be a part of the regular monitoring report or a separate document. The evaluation must include the following:

(i) a statistical analysis of the data from the monitoring program, performed in accordance with Section 3 .

(ii) an evaluation of sources other than the solid waste facility which may have caused or contributed to the possible deterioration in water quality, such as natural variation in water quality or another development.

(iii) an evaluation of possible errors, such as errors in sampling, analysis, or mathematical problems with the monitoring data. If resampling of monitoring points is performed, the samples must be independent of the previous sample; however, the sample must be collected within the same season as the original sample.

NOTE: Staff consider "possible deterioration" to mean a change in data values that appears significant after considering normal variations in the historical database and any acute events that might have triggered short-term water quality changes.

( j ) Assessment monitoring must be initiated within 90 days of the date the report required by Section 2.C(2)(i), above, is submitted, unless the Department concurs that a source other than the solid waste facility is the likely source of the deterioration in water quality. Assessment monitoring must be conducted in accordance with a plan approved by the Department.

2. All future monitoring data should be submitted electronically in the current EDD format required by the department.

3. Duplicate data submitted to the department must include the location where the duplicate was collected. This has not been the case in recent data submittals from Dragon.

4. Recommendations for the monitoring program including installation of a new background monitoring well and annual statistical analysis of data should be implemented.

Footnote (1) Heath, Richard MEDEP, Memorandum to Carla Hopkins MEDEP, RE: Environmental Monitoring Plan for Dragon Products Company, Thomaston, ME, Cement Manufacturing Facility, July 2003, memorandum dated August 12, 2003.

cc Victoria Eleftheriou