COMMUNICATION Region II Headquarters Roscommon, Michigan 48653 May 4, 1981 TO: Poseyville Road Sanitary Landfill File (Dow Chemical)MidlandCounty I FROM: John M. Alford, Env.~Sanit. - Resource Recovery Division SUBJ: April 30, 1981 meeting with Dow Chemical Company regarding closure of Poseyville Road Sanitary Landfill On April 30, 1981, Larry Washington and David Wilson of Dow met with Larry Thornton, Fred and the writer to present their closure plan for the referenced facility. Dow indicated their belief that the site has been monitored operationally to insure proper disposal of non-hazardous waste. The line where the City of Midland stopped disposing waste in 1955 and Bow began is known as was pointed out on the site plan. Dow will provide a written plan of closure for our review explaining what has taken place and what is planned for the balance of the closure plan. We provided a copy of a Schedule for Compliance and Final Closure encompassing the required work items for proper closure and on?going monitoring of the facility. Dow discussed their procedure for the leachate drainage system, showed a sample or the pipe to be used, and also explained the slurry wall system. Dave Wilson stated that some wells have been sampled in the area with no evidence of contamination. Sodium and chloride levels are high in most wells, which, according to Dow is normal for the area. JMA:lje LQZW DOW CHEMICAL USA. August 19, 1981 Mmmemquwsmw MIDLAND. MICHIGAN 43540 I yuan-5:! .mr. L. Thornton ?eng? MI Department of Natural Resources . on Resource Recovery Divisio P.0- Box 128 I Roscommon, MI 48653 Dear Mr: Thornton: SUBJECT: CLOSURE AT POSEYVILLE LANDFILL THROUGH AUGUST 13, 1981 Since clay covering commenced on May 21, 530,310 yards of clay has been hauled and placed. Total working days have consisted ?of fifty-one, with twenty four days being lost due to wet weatne The work week is still co- sisting of six days wheneverlpossible Soil testing is showing 85% or greater modified proctor and unified soil classificatio determined Method D2487. Qua ity Assurance reports are included, for your evaluation. - . Plans for covering the nor lepe'of-Poseyville Landfill are enclosed.- Procedures for rosion control will be forwarded to you at a later date. Landfill venting procedures were reviewed with James Janicek on August 12 1981, at the site. The plan is to install six 4" vents packed in a gravel base along an equally spaced mid? line of the .site, going from east to west. If you have questions concerning any of these matters, please contact John Tomke,636? 2646, as I will be out of town for two weeks._ Sincerely, 9 8222.25 ., - D. . . Wilson Environmental Services cs Enclosures: Soil Testing 82?004e810278 Roscommon, Hichigen #8653 April 16, 1381 I To: Beth Hursch FROM: John a. Alford SUBJ: Dow Chemical Company, Poseyville Road Landfill As discussed with you on a meeting on 4/39/81 has been scheduled with Dow Chemi.csl Company to discuss closure and site restoration of the former Poseyville Road Landfill. Eco intends to present their.proposal for closure and restoration on that date. ?e facility has been operated as a general non-haeardous waste facility, since 1976, and has never been licensed und er.Act 87 or Act 6&1. So t?hat you may familiarize yourself vi the -loeation I am enclosing appropriate information .-for your review from our files. Additional information that you may have access to -may also be helpful when discussing- -the Dow proposal on the 30th. If you have any questions, please let me know. mama Encl. I - Description i The Michigan Division of the Dow Chemical Company operates a landfill as a means of disposal of solid wastes of Types II, and IV. The landfill is located in the of the l/2 of Section 29 in Hidland Township, Midland County. The fenced portion of the property used for landfill comprises ml08. acres. Primary access_to the property is by Poseyville Road across Dow; preperty. Access is by Dow employees only using Dow trucks and equipment.- The use of this landfill is limited to solid wastes generated by The Dow Chemical Company. Soil borings indicate soil conditions compatible with the use of the property for landfill: Generally speaking, the soil is loose to medium compact fine to medium sand oter 20.? 30 feet of stiff gray silty clay (soil boring data and soil profile are attached). The clay layers are Ef very low permeability with boring-samples indicating permeabilities from _3 l0?7 to 5 10?10 cm/sec.. The landfill area is ditched to provide drainage for surface water and to collect any leachate. The ditches dsain to a sump and then flow underground ?to a lift station where plant sewage is pumped across the river to theisewer? system and Dow's Waste Treatment Plait. Access to the landfill is limited to Dow equipment operated by Dow employees and is available day and night for seven days a week, although it may be limited to-weekday Operation in the future.' Both the area fill and ramp fill methods are used. In the ramp fill method, the materials are discharged at the base of the working face and spread from the bottom up. The dozer spreads the waste at the base of the slope, then compacts it and moves dirt from the base to cover the waste. l-3- In the area fill methOd the dozer sp eads and compacts the waste, but the cover material is hauled to the site by truck or other equipment. The land? fill site is compacted and covered daily" The landfill is operated in such 3 a way that nuisances and/or hazards to health and safety are avoided by con? fining the operation to the smallest praCtical area and compacting the waste to the smallest practical volume. Labelled and lined containers of asbestos materials are placed in designated areas in thealandfill and the area is posted according to State and Federal regulations. There are explicit operating instructions for.proper handling and disposal of aSbestos containing materials. The landfill is patrolled routinely by Plant Security and Environmental Services personnel. Any fires occuring in landfill are classified as an emergency and Plant Security, Dow Fire Department and operations personnel respond. The minimum equipment sent to a landfill fire is one dozer, one loader and two dump trucks. No wastes are hauled to the landfill in such an emergency until the area is back to normal. Based on l977 and l978 records, the average volUme of waste to an's landfill is l0,200 yd.3. Using eight feet as a lift, this amounts to a rate of completion of landfill Operation of 0.79 acres/month/lift or l.26 months/acre/ lift. The life of this landfill site is estimated at ten years. . 3 k3; . w; DOW CHEMICAL. USA is): 2m, .1981 Mr. Larry Thornton Resource Recovery Division Department of Natural Resources P. O. Box 128 Roscommon, MI 48653 Dear Mr . Thornton: SUBJECT: The Dow Chemical Company has Oper MICHIGAN DIVISION MIDLAND. 48540 RECEEVEB iIiA?I'28i981 Resource Recovery Division Mai Regen POSEYVILLE LAHDFILL CLOSURE PLAN ted a solid waste disposal facility in Section 29, Midland Township, Midland County, since 1955. The land? fill at the time of purchase had een used by the City of Midland from 1940 until the property was transferred in 1955. Landfilling operations were disco tions shifted to the newly licens Final closure of the Poseyville Act 641, PA 1978, as amended, and 245, PA 1929 as amended. The present schedule of closure permitting: l. The leachate collection tile east portion of the site, ext ntinued on January 5, 1981 and opera- ed sanitary landfill on Salzburg Road. acility will be in compliance with the rules and Act ill consist of the following,weather system will be completed on the north? ending approximately 2,500 feet from the present north sump to the present south leachate collection sump. Completion will be dep September, 1981c endent on weather but is eXpected by 2. A soil bentonite slurry wall will be placed on the north?east portion of the site running approximately 1,500 feet beginning at If termination points. 3 All leachate is now and will the north leachate collection sump and going to the east appro i? mately 1,150 feet and then south approximately 350 feet. will be keyed into clay at all points along the bottom and at both Completion will be dependent on weather but is expected by September, 1981. I The wall continue to be delivered to the Dew Waste Treatment Plant by an existing sewer at the site. AN UNIT OF DOW CHEMICAL COMPANY u. . 1 Icerams-mm . Mr . La rry May 26, 1981 Page Two 10. ll. ,feasible. The entire landfill will be capped with-a final cover material com- pacted to a minimum thickness of two (2) feet. soil-Specifications The clay will meet and will be placed in nine inch lifts (and compacted prior to the next lift). The area will be seeded after capping is complete . Weather permitting the site will be capped by late fall of 19 l. The site will be graded prevent the collection of standing water, facilitate the run.off of surface water, and prevent erosion. A gradient of one vertical four herizontal will be maintained where DNR staff conc rrance on any alternate gradients will be agreed upon before installation. The sOuth, east and west sides of the site including the'capping will be completed by latelfall of 1981, weather permitting. A clay key will be placedlaround the site perineter, with the slurry wall keying into this clay key barrier, The key will extend :into the clay. The final the clay-key area as part key on the south, east an: by 1ate.Fa11 of 1981, wea1 clay capping of the slopes will cover of the site. The completion of the i west-sides of the site is eXpected :her permitting. The clay key, slope backfilling, and capping of-the slope on the north?side of the site wii 1 be completed by the end of August, 1982. In the event weather and time permits further work in 1981, the key will be completed An approved hydrogeologic toring wells, water sampli will be carried out in a Chemical and the DNR Resou transmitted to the DNR in sions have commenced cones in the fall of 1981. evaluation of the site, location of monim ng frequency and analyses by DNR methods onsistent manner agreed upon by Dow rce Recovery Division. Data a timely, agreed upon fashion. Discus? rning these matters (4/30/81, 5/7/81). i The Dow Chemical Company expects the DNR to inSpect the sitd on a routine basis to assure satisfaction of the final closure of the site, which will remain the property of The Dow Chemical Company.- The Dow Chemical Company tion and comments as the work will be accomplished niques. Rainfall, snow melt collec the perimeter of the site, will be treated at the Dow for discharge are agreed ill submit plans to the DNR for inapec? losure work progresses. All plansland by approved methods and tehh? I tion ditches will be installed arohnd outside of the clay key. This water Waste Treatment Plant until agreements 'pon with DNR Hater Resources Staff. Mr. Larry Thornton May 26, 1981 Page Three Long?term Care of the Site: 1. The site will be inspected'in a consistent manner to assure repair of any eroded areas. 2; Seeded areas will be inepected regularly and apprOpriate measures taken to aesure vegetation is maintained. My. a Site fencing will be maintained in a consistent fashion to prevent deterioration. 4. All cracked, eroded and uneven areas due to settling in the final cover will be repaired in an expeditious manner. I 0 Work efforts are proceeding as rapidly as possible in accordance with the closure plan presented. If you have comments or suggestions, please contact me. . . Sincerely, ?5)ij 5C1: . J. D. Wilson Environmental Services (517) 636-5925 .w i a 7 .5 - 17. cur qua-?m "r DOW CH EMICAL 1 Sincerely, May 20, 1981 Mr. Larry Thornton Resource Recovery Division Department of Natural Resources P.0. Box 128 Roscommon, MI 48653 Dear Mr. Thornton: SUBJECT: As discussed with you?on 4/30/81 DIVISION MIDLAND. MICHIGAN 48540 EEC MAY 2 1981 I Resoo rce Recovery Division Re?onl! LANDFILL CLOSURE I am providing as-built drawingslof the leachate collection system for the nor_th, west and south sides of the Landfill. The flow rate fro approximately 50 and the sou the north sump has been measuredlat th sump at approximately 70 gpm. Leachate analysis has been measuled as follows: I 222 Chloride 9,940 TOD 1,320 TDC 680 pH '7.5 Leachate organic analysis have identified and confirmed the presence of six organics at less than 10 for each constituent. tensive evaluation would be nece A more ex? sary to determine the key compounds. Inorganic analysis for brine chemical levels have been performed and are consistent with the brine and inorganic chemical residues disposed at the siteh Landfill materials have consisted of plastic materials, demo? lition debris, rubbish, latex, Waste treatment sludges,yfly? ash and cinders, incinerator ash, asbestos, spill yard clean?up solids, FDA products salicylic acid, and and inorganic residues. terials is enclosed. of the site will be forwarded to' Rain has held up survey field ac 13"? J. D. Wilson Environmental Services 636-5925 Enclosure A further discussion of these ma? Draw1n?s _sh_owing. the final grades and contour you as soon "as "they are completed tivities over the last two weeks. AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY r. 111?.) rar? a? "if: a? WASTE I-IATERIALS MAT 2 0 198] - . Resource, Recovery Divislon Latex Sludges Latexes are polymer or copolymer particles dispars?d En water. They are important to industry primarily as binders and saturants. Examples are styrene?butadiene latexes and vinylidene chloride latexes., Plastic Molding and Extrusion Materials Dow produces three major types of plastic molding and extrusion materials: styrenedcontaining, ethylene and chlorine?containing. In addition, xtensive research and development?ac? tivity is directed to new and uniqu polymers that can open new application opportunities for thermoplastics. Resins are designed for particular;suit? ability to the broad range of commercial fabrication methods, including in? . . jection molding, sheet and film extrusion, thermoforming, blow molding, rota? tional casting and coextrusion. The Dow resins serve nearly all markets, with particular emphasis on packag?ng materials, appliances, furniture, and industrial parts. Examples are: (styrene-acrylonitrile c0polymers), ABS copolymers), polymers). Uses include injection molding, cups, lids, toys, furniture, automotive parts, appliances, etc.. 13"" 4. (rd?a?va Flocculants Dow flocculants are high?molecular?weight, wmter? soluble polymers. The products span a broad range of molecular weig?ts and include cationic, essentially nonionic, and anionic materials used solid] liquid separations in water and wastewater treatment; and mining and'paper . process applications. Examples are: and acrylamide poly? mers. u- - Packaging Products The Dow Chemical Company markets materials which are used by other manufacturers to contain, support, or protect their products. These packaging materials include clear films, loose?fill packaging. An example is a vinylidene chloride vinyl?chloride i - m. copolymer film, used for industrial packaging, bakery products, and households. Product Residues cellulose ether products are water? soluble gums having_surface-active properties and selective organic solubility. The products are nonionic, are not metabolized, and possess unusual thermal?gel properties. The products function'as thickeners, suspending agents, dispersants,ibinders, film formers, water?retention aids; emulsion stabilizers, or impart a combina? tion of these properties. Some products are used as food.thickeners. Ion Exchange Resins ion ex%hange resins are produced in four major types. Strong_acid cation resins Ere capable of exchanging cations, or posi? tively charged ions. For example, such resins will exchange sodium (Me) for calcium (Ca) and magnesium a in water softening, or hydrogen for i2- calcium, magnesium, and sodium, as in ?salt splittina". The weak acid cation resin is capable of exchanging positively charged metal cations associated - with weak bases, such as bicarbonates, for hydrogen at near?stoichiometric regeneration use and does not split salts. The strong base anion resins are capable of exchanging anions, dr negatively charged ions, and can split salts to bases. The weak base aniqn resins are capable of neutralizing acids. Combinations of cation andlanion exchange resins can effectively demineralize water, recover wastes from process streams, and function as condensate polishers for nuclear and fossil-fuel power plants. Foamed Product Residues used for flotation for docks, rafts, insulation for residences, etc. .a - do . V's-a? I Residues resins These products - are used as gel lacquer coatings fo bowling pins, generator field coils, and glass bottles; hot?melt strippakle coatings and paper coatings; lacquers for paper coating, electrical insulation, strippable coatings, fabric coatings, bronzing, and alkali resistance laaquers. They are also employed as binders or viscosity modifiers for nitrocellulose_lacquers, glass ?rits, delayed? release coatings, printing inks, va nishes, and pigment print pastes. Inorganic Residues Examples: Calc'um chloride CaClz Magnesium hydroxide Magnesium sulfate Potntsium bromide RUE Sodi bromide NaBr Asbestos Insulation and Demolition Asbestos FDA Products Salicylic acid residues, SARAH Demolition Debris faom Building Demolitions I Waste Treatment Sludges I I MAY 20 1981 Flyash Cinders from Powerhouses Incinerator Ash Spill Yard Clean?up Solids Resource Recovery Division - Region II ?anwaw - . - ,5 3.3521'ip, Midland County, Michigan. The fenced site is rectangular in @ape,? is imately 5000 feet long and 12 ii approx 50 feet wide and occupies approximately 140' ?ags rThe site boundaries are shown on the Site location Plan, Plate 1. Approximately 75 percent of the site has been covered with some fill since the site?s opening in the 1950' s. The eastern portion of the site has been filled 0 its final elevation and the surface is covered with grass and occasional small area at the tins of our investigation A north south fence bis-acting this {Iii-has since been moved to the eastern perimeter of the landfill. Landfilling opera? continuing in the central portion of the site using a combination of area and cell methods, with each lift approximately 10 feet thick. A combination of Cinders and soil is used "to provide the daily cover. This portion of the site has little vegetative cover and. various roads are present. No landfilling has been conducted along the southern property line in the central and western portions of the site. Host of the surface sand deposits have been removed from this area. Various east west utility lines, including gas, water, salt and brine lines, were noted between the northern fence line and the service drive. Also, 6 salt wells were noted along the northern edge of the site. Along the north, south and east fill boundaries, a ditch collects the surface runoff and intercepts leachate generated by the landfill." The ditch has been constructed by digging in the surface deposits, and no lining has been installed. The water collected from this ditch flows under Poseyville Road to the Dow Waste Treatment Plant. The property north of the site was also investigated as part of this and earlier studies. This property is largely undeveloped, with the majority being used for agricultural purposes. A wooded area is present north of the central pOrtion of the landfill. The topography of this area is relatively flat 'and con? tains several low areas in which standing iwater is noted much of the year. 5h}: . Eggs ix .. rte-"49407 ii on 28 fi'owever, this sand deposit was not found to be continuous under the entire site. In several areas, a silt layer was encountered at approximately the same elevations! Another major sand layer was noted in the hardpan deposit, approximately 20 to 30 feet below the ground surface. This layer was encountered in the central portion of the existing landfill site, extending to the area of Test Boring. No. 2169 A to the north and Test Boring No. 2196 to the east; Sections 13-8 and [Plates 6 and of the generalized subsoil profiles best illustrate this sand layer. The thickness of the layer ranged from 2 to 15 feet. To aid in defining the depth, thickness and extent of this sand layer, profile borings were made (Figures 121 through l24). In most cases, the groun ater was observed to be artesian in these borings. A similar sand deposit was noted in Test Boring No. hovever, due to the fill in the area, it was not possible to evaluate its areal extent. The ground- water well records from this area indicate that several homes use a similar soil 'stratum for their groundwater supply. This tcpic is further discussed in the section on groundwater supply. 'In the vicinity of Test Boring Nos. 2186A, 2357, 2415 and 2416, a sand layer was encountered from approximately Elevation 595 to 540. This relatively thick sand deposit appears to connect the upper and lower sand deposits encountered in other areas. Several water well records from wells south of the site indicate that. a similar soil condition exists in the area. Several of the borings performed in the summer of 1978 2180 and 2185) indicate that this layer could be guite extensive. However, due to a restric? tion?of 40 feet maximum on the borings, the ?vertical thickness of the sand? was 'not determined. Its lateral extent is somewhat defined on the Subsoil Profile Section along the southern property line. The aquifer schanatic, Plate ll, was developed to illustrate the sand column connecting the upper and. lower sand layers in? the hardpan. This connection was also investigated using the groundwater elev- ation and? water quality data and this information is presented in later sections. I 1 - . I . if . . . -??-49407 .MGE 13,0, 28 Throughout the general area, the surface soil deposits consist of loose to nadium compact brown silty sand. This layer is approrimately 3 to 15 feet thick. In the fenced landfill area, this has generally been removed down to the silty clay. In the area north of the landfill site some sand has been removed from the open areas. Hydrologic Conditions The site is located on the flood plain of theFChippewa River near the point where the Chippewa and Pine Rivers conflue with theiTittaba? wassee River. These rivers drain a large portion of the central-lower peninsula. ofher significant drainage features in the area include Bullock Creek, which flows from west to east and enters the Tittabawassee below the Dow Dam. The general area receives approximately 30 inches of rainfall annually. Since most of the area near the site, west of the Dow Conplex, is developed and the surface soils are generally sandy, the rainfall infiltratiOn percentage is expected to be rela- tively high. Some of this infiltration recharges deemr layers in the groundwater system, while the remainder flows through the surface soils to the river. Specifically, much of the surface drainage near the site is within the direct runoff drainage area of the Chippewa and Tittabawassee Rivers, since the site is adjacent to the river's flood plain. The. position of. the flood plain and the drainage area boundary are shown on Plate 12. The lateral extent of the surficial sand deposit on the site, as shown on the Logs of Test Boring, Hand Auger and Test Pit, indicates that much of the rainfall incident to the site will percolate into the soil rather than runoff overland. However, since the site is by a drainage ditch cut into this sand layer, it is expected that much of the infiltrated water eventually is intercepted by the ditch. Geology of the Area The compllex geologic history of the Midland area includes subsurface formations deposited during the Paleozoic and Cendzoic Eras. The youngest Paleozoic age formations are marine sandstones and shales of the Period. Thick glacial deposits were left in the Saginaw Bay area alga-1.5m 5* :3"va Cry-E Kg .1 ??2233 ?r-E 3E lift-EH In?: ., - iguana?; - Ania-Earn?? vhf. I PAGE 16 0F 28 The sandstone aquifer is a water supply source for some of the residential development southwest of the site. Well records and geologic maps indicate that the sandstone is a member of the Saginaw formation and is overlain by a shale stratum from the same formation. The shale ranges -in thickness, as recorded on available well records, from 40 to 160 feet. These sandstone wells range in depth from g75 to 415 feet. Although the information needed assess the hydrogeologic properties of ?the sandstone is limited, it appears that tlLese wells are of low capacity. Three eater. quality sampling test results wells show chloride concentrations of 180, 200 and 830 milligrams per liter The water bearing subsoil in the Lower _Drift aquifer'is recorded on the water well records as a fine to medium Sand. Wells for residential development, particularly to the southeast of the site, tap this aquifer at depths ranging from 90 to 141 feet. Water levels indicate that many of thewells are artesiani Al- though many of the wells do not penetrate the entire aquifer, available rIecords indicate that it ranges from 2 to 25 feet in thickness. This Lower Drift aquifer appears to be separated the bedrock by more than 100 feet of clay and hardpan deposits. Specific capacity data recorded on water well records ranged from .16 to .74 gallons/minute/foot of drawdown for pumping durations between 2 and 4 hours. This is approximately equivalent to a transmissivity of' 100 fizz/day. Chloride sampling data from this set of wells shows a range from 50 to 325 mg?Cl/l. Thus, it appears that this aquifer then Supplies moderate volumes of water ranging in quality from good to poor, as based on the conparisons with the proposed U.S. Environmental Protection Agency's Secondary Drinking Water Standards. . The Upper Drift aquifer recognized in the well records available for the development south of the site is a thin, fine to medium sand layer. Only a few of the well records supply information on tLis layer. However, it appears to he PAGE 17 or 1.. between 5 and 15 feet thick, with wells langing from 36 to 44 feet deep. One of the wells in this set recorded a groundwater elevation above the ground surface at the time it was installed. Most of the other-wells also indicate that the aquifer-is artesian. Limited specific capacity data indicate that it also has moderate permea?' bility. Two groundwater quality Samples show chloride concentrations of; 19 and 80 ng/l, respectively. This aquifer appears to provide moderate supplies hf fair to good quality water. The approximate locations of many of the wells for which records are available is presented on P1 te l. The numbers correspond to the figure thumbers on the respective Logs in Appendix II. I On?Site Hydrogeologic Conditions The Pleistocene glaciation whicii produced the complex geologic environment in the Lrea has also produced a complicated ground? water flow system. Analyses of the Logs of Test Boring and Logs of Piezometers, presented in Appendix I, indicate that a two~part groundwater flow systemiis present on the site. Generally; both of the previously described glacial aquifer; which are used for water supply in the area have been identified on the site. A water bearing surficial sand deposit was also identified in most of the on?site test borings. The water bearing strata on the site are generally separated by two aquicludes {con- fining layers) as shown by analyses of Dogs of Test Boring and Piezometer. Each of these aquifers and aquicludes are descr' ed in the following section. The Lower Drift aquifer on the site generally consists of a v!ery compact gray silty fine sand and a fine to medium sand. In the east central portion of the site, this lower water bearing stratum is a very compact gray silt. Piezometer Nos. 2353AP, 24l3P and 2439p are set in thei silt layer at- elevations ranging from 463.5 1 to 477.5. The Lower Drift fine sand aquifer is monitored by Piezometer :Nos. 243812?, I - 2440P, 2441P and?2442P, set at elevatilons ranging from 487.2 to 524.8, and by No. 218613.? set at Elevation 576.9. The total thickness of the aquifer was not deter? mined. Homver, at the loCation of Test Boring No. 2440, the aquifer is at least 9 feet thick. It should be noted that at Piezometer 2186AP, the intermediate overlying I I (h ,4 gun-T: 41.33;} a A: ?91- I a u. . 5- minus-*1; I .2..- m' gar!" .- 211,. I I. . grormIater monitoring veils bet? -en Septeroer, 19:9 th. rough Eel. ruary, 19.33. . 12.1. .. page 23 car-'28 aquifer and an Upper Drift sand aquifer which merge and are connected in the area monitored by Piezoneter No. 2186A. Basically, groundwater in the western port-ion of the Lower Drift sand aquifer flows to the south.? southwest, towards Piezometer No. 2186AP. Due to the higher piezometric surface in the Lower Drift sand aquifer, vertical flow results through the connection at Test Boring No. 2186A, to the Upper Drift sand aquifer. The groundwater flow d'rection in the Upper Drift sand deposit is north northeast, indicating that th flow then moves from the 00 action through the upper layer to its discharge area .to the northeast. These flow patterns are illustrated on the groundwater surface elevation contour maps shown on Plates 13 through 17. Evaluation of Groundwater Quality thorough evaluation of hydrogeologic conditions on the site must include a complete evaluation of groundwater quality. The purpose of the groundwater quality evaluation is to determine the effect of potential sources of groundwater contamination on groundwater supply resources, to assist. in evaluating groundwater flow conditions and to provide a base of data for designing a groundwater monitoring program. This evaluation represents a prelim- inary assessment of groundwater quality and does not provide final conclusions and recommendat ions . The evaluation is based on the results of laboratory tests on water samples collected by personnel from the Dow Chemical Company from the on?site The I data used in the analysis are presented on Figure 156, Appendix I. This monitoring program is described in the section on Laboratory Studies. Some water quality data were also aVailable on water well records from the Midland County Department of Public Health andwere used'in the evaluation. Although some data for other chemi- cal parameters are available (see Appendix the evaluation is based primarily on chloride as measured by the Volhard Titration technique. Isochem maps, which Show lines of equal chemical concentration, were also produced to assist in the i I ru'? Parfs?tltt'. 'q - 49407 NEYER. mm 8: HINDO- LTD- 24 0F ?28 evaluation and are presented as Plates 18' and 19. Plate 18 shows lines of equal chloride concentration in the Upper Drift aquifer. Plate 19 shows lines of equal chloride concentration in the Lower Drift aquifer. i The water quality data from ori?site groundwater monitoring wells show . that the average chloride concentration for wells set in the Lower Drift :aquifer range between 6 mg/l and 238 mg/l. Isochem maps indicate that the concentration MM generally decreases in the western half of the site, in the direction of grotndwater movement, towards Piezometer. No. 2186AP, (Plate 19). In the Upper Drift 5 nd r' aqtiifer, the chloride concentrations range-from 7 mg/l at Piezometer No. 2357AP-to - 660 mg/l at Piezomet'er No. 2196P. In general, the concentration in this layer increased in the direction of flow, (Plate 18). The average chloride concentram tion measured in Piezoneter Nos. 2354 and 2356 was 479 mg/l and 1741 mg/l, respect? ively. These wells are set in the surficial sand deposit. Water quality data from water supply wells in the development sout:h of the site show that the sandstone aquifer is tLe most highlv mineralized, with :chloride concentrations as high as 830 mg/l. Available data for the Lower Drift sand aquifer in the glacial drift indicate a range of Ichloride values from 50 mg/l to 325 mg/l. Only two sanple results are available to evaluate the quality of the Upper Drift aquifer offsite. These recorded chloride concentrations of 19 mg/l and 80 mg/l, respect ive 1y . . i A renew of the water quality data with re5pect to the groundwater flow pattern (discussed earlier in the report) indicates good correlation between ground- water flow patterns and chloride concentration movement patterns in the grorindwater. Half-J - In general, __the flow pattern is believed to be south southwesterly__in the Lower Drift (toward Piezometer No. 2186A), then upward to the Upper'Drift aquifer, and then in_ an east northeasterly direction within the Upper Drift aquifer. This is corroborated by the water quality data as follows: Chloride concentrations in the LowerDrift aquifer decrease to the south land west, indicating dilution as the water {sq-3?13; rang".55 swig.7117.5.5223 - . 494,0}1 .. MEYER. TISEO 8: I NDO. LTD. PAGE 25 OF 28 reaches. the sanpling'point at Piezometer No. 2186A. As water moves to the north and east through the shallow aquifer, chloride concentrations increase, indicating that chlorides are being added to the groundwater. The chloride movement patterns are illustrated on the Groundwater Quality ont0ur (isochem) Maps shown On Plate Nos. 18 and 19. A partial inventory of groun ater contamination in the area shows that - salt production Operations, .dcmestic septic systems, and naturally occurring brines, as well as the landfill, are all potential oontaninatim sources. Many studies t-(Salvato 1971, Fungaroli 1973, Andersen .1972 and Hughes et.a.l. 1969) have shown that chloride is a decomposition by?product of both general mmicipal refuse and house- hold wastewater, which is the reason for its frequent use in evalua? tions. Since these sources' exist in the area, it "is possible that they are contri? buting chloride to the groundwater system. The groundwater quality conditions can only be conclusively determined by further evaluation. One method to evaluate the groundwater quality would involve collection and analysis of samples from the potential- sources brine and landfill leachate). In this way, a chemical parameter which is unique to each source could be identified and used as an-indicator. Future water quality saIrples could then be tested for that parameter and the data oonpared. This :would also require several additional sample collection periods on a seasonal basis. - SUMMARY I The foregoing sections of _the report have presented the datalt developed during the course of the study and have presented evaluations of the Subsoil and .L - groundwater conditions at the site. Certain parameters, such as groundwater qual? ity, have not been fully tested and evaluated; thus, definitive conclusions and/or Ireoomndations-r'egarding the condition of the landfill cannot be made. However, certain observations can be made baseji on the 'data' already available. In this reqard, it has been requested to assess: the condition of the existing larofill with I I ha? . I . .73?3?33"; I Wis-1? if?? PAGE 26 0F 28 respect to the proposed DNR criteria for Type I (Act 64) and Type II (Act 6'41)? landfills. It should be noted that the rules for both Acts are still in the review stage, and that the final versiions may be somewhat different than the . current drafts. Based on the available data and on a review of theproposed Acts, it is a our opinion that the existing Poseyville Landfill does notlsatisfy allproposed requirements as outlined. in the two Acts. The rationale for our conclusion is discussed below: 3% Type I CRITERIA . The proposed administrative rules (dated November 16, 1979) for the Hazardous Waste Management Act, Act 64 of the Public Acts. of 1979, in part include the following criteria: A. Part 4, Rule 417, . A landfill shall be located, designed, constructed and operated} so that there is no direct contact between the landfill and surface waters or groundwater. Comment At the existing landfill, geotechnical data along the northern fence line indicate that a direct connection exists between the landfill and the surface sand deposit, which contains perched groundwater. B. Part 4, Rule 417, (3) A landfillshall not be located in an area where there is less than 20 . feet of soil with a permeability of 10"6cm/sec, or less immediately below and lateral to thel liner. I Comment Test Boring Nos. 2194, 2165, and 2139 all encountered an aquifer within 20 ?feet of the bottom of the adjacent fill. "r mag 27 0:28 Part 4, Rule 41.8, An emplaced compacted clay liner shall have a minimum thickness of five feet. Comment I This investigation did not disclose any evidence of a compacted clay liner. Other rules would effect the operation of a Type I landfill. IHowever, mph?compliance to these three rules is sufficient to support our conclusion. TYPE II CRITERIA The Reproposed Administrative Rules (dated December 21., 1979) for the Michigan Solid Waste Management Act, Act 641 of the Public Acts of 1978,. in part include the following criteria: VA. R299, Rule 406 Sanitary landfills shall be designed to prOtebt surface and groundwater by vertical and lateral isolation, by natural geology or by engineered modifications of the site. Comment I As mentioned previously, the surface water is not protected from the landfill. Without conclusive cmoundwater quality data, it is not known if -J the landfill. is cOnnected to the shallow artesian aquifer. B. R299, Rul? An acceptable natural clay base shall have a minimum thickness of 10 feet. A compacted clay liner shall have a minimum thickness of 3 feet. In either case, the clay shall have a maximum in?situ permeability coef? ficient of 10"7 cm/sec, shall meet criteria for a unified soil classifi? cation of SC, ML, CL, or CH, and shall have an Atterberg limit above the line, as determined by AISTM method D2487. The clay shall have a a 3. 3:533530-4940up! ..-. 11-.HHL a? - wr? OF 28 maximum allowable liquid limit of 60 units, as determined by ASTM method and plasticity index greater than 4, as determined by ASTH method D424. A minimum of 1 foot of .sand or other approved protective cover shall be provided to protect the compacted clay liner and facilitate leachate collect ion. Comment Several borings along the north fence line disclosed clay thicknesses of less than 10 feet. In Test Boring Nos.- 2192 and 2195, clay was noted to be 3.5 and 6.0 feet thick, respectively. It should be noted that the clay soil does satisfy the material type criteria as outlined in this rule. This rule contains some errors which are being corrected by the DIR, however, the changes are not expected to affect this project. I Although the above indicate that the existing Poseyville Landfill ci loes not satisfy all of the proposed DNR criteria for Type I or Type II landfills, it should be noted that the proposed rules allow for variances bythe Director. in granting operating licenses. {It general, it? is anticipated that the variance may only be granted if sufficient data are presented which indicate that, although that certain require- ments are not being met, the intent of the rules is being complied with. or this project it is conceivable that, with additional studies and a comprehensive ground-water quality evaluation, it may be shown that the intent of the rules for Type II landfill could be satisfied. Howeverr it should also be noted that the additional studies may only support the conclusionsheretofore presented. ReSpectfully E'Cilgimoaib? 1 Daniel L. Harpstead Robert . K. R. Hindo, 9.13. April 1, 1980