TEXAS DEPARTMENT OF HEALTH
TDH MEMO

To: File: WCS New
CC: Phil Shaver
Special Licensing Projects
Through: Ruth E. McBurney, CHP, Director, Division of Licensing, Registration, and Standards
Through: Gary L. Smith, Ph.D., Deputy Director, Technical Assessments
From: Bruce Calder, Geologist, Technical Assessments
Subject: Meeting with Representatives of WCS
Date: April 17, 1998


The purpose of this memo is to offer a brief summary of the meeting between myself and three representatives of AM Environmental (AME) which took place yesterday in my office. AME is currently representing Waste Control Specialists, LLC (WCS) in the preparation of their license application for a byproduct disposal facility (landfill) in Andrews County, Texas. The meeting was attended by the following individuals:

Name	Title	Affiliation
Bruce Calder	Geologist	TDH/BRC
Allen Messenger	President/Engineer	AME
Andy Witteveld	Geologist	AME
David Allen	Engineer	AME

Highlights of information gathered from the meeting are as follows:

WCS Purpose

- To obtain a license for a byproduct disposal landfill in Andrews Co.

Primary Siting Criterion (i.e., reason for choosing this particular site)

- The relatively shallow depth from the surface of the redbeds of the Triassic Dockum Group (this group of formations was sought after for its relatively low moisture content, Iow hydraulic conductivity, apparent lack of cracks or fracturing, and great thickness over the underlying Santa Rosa Aquifer).

Description of WCS Property

- WCS owns ~16,000-acres located in Andrews Co., Texas, and Lea Co., New Mexico

- USGS topographic map is "Eunice NE, TX-NM"

- WCS now has 3 permitted RCRA/TSCA landfills; only one is currently in operation

Description of 3 Currently Permitted Landfills (LFs)

- 3 landfills are designed to accept RCRA hazardous waste, along with Toxic Substances Control Act (TSCA, 15 U.S.C. §2601, et seq., pronounced "Tosca") wastes

- Only 1,338 acres (of the 16,000 owned) are actually under permit

- 1 LF - design ~1 mi in length; capacity ~10 million cu yds; and is yet to be built

- Other 2 LFs have design capacity ~637,000 cu yds each (only 1 is built/operating)

- LFs are ~75 ft deep, ~20 to 45 ft into the Dockum redbeds

- TNRCC/I&HW Division permitted LFs for RCRA wastes; EPA permitted them for TSCA wastes (mostly PCBs)

Current Groundwater Monitoring System (RCRA/TSCA Landfills)

- TNRCC and EPA-approved

- Includes wells completed in "uppermost aquifer" and wells considered "supplemental"

Description of Uppermost Aquifer

- ~20-ft thick; laterally continuous (across site); silt lens; within the Dockum Clay

- Located ~ 280 ft below ground surface (bgs)

- Hydraulic conductivity ~1 X 10^-7 cm/sec (very slow recharge- wells bail dry)

- Monitoring wells have 20-ft screens

- The zone is a confined aquifer with groundwater yield ~0.05 gpm (at best)

- Given time, heads rise as much as ~70 ft within the mon wells (30 ft above silt bed)

- Upperm aquifer has relatively poor water quality - TDS is ~3,000 ("moderately saline")

"Supplemental Wells"

- Completed in a completely dry silt lens (within Dockum) that is laterally discontinuous

- The silt lens is ~20-ft thick

- The silt lens is located ~120 ft bgs

- Hydraulic conductivity ~1 X 10^-6 cm/sec

Drilling

- To date, borings have been drilled on 500-ft centers with air rotary; may increase distances

- All borings are continuously cored

- Wells are completed with 4-in PVC pipe, ~2-ft filter pack, 4-ft bent seal

- WCS didn't cite any particular guidance used in well construction (e.g., ASTM D 5092)

Concerning the Ogallala Aquifer

- TX Water Development Board Pub. No. 288 indicates Ogallala covers Andrews Co.

- AME exploratory borings found maps in Pub. 288 to be in error Re: water levels

- AME found Dockum redbeds ~ 25 ft bgs, and only few inches overlying water in spots

- AME unable to recover consolidated samples of the material above the Dockum

- AME did find a "buffalo wallow" (~100 yd wide) where 2 ft water overlying Dockum, but no water was found outside of it; corresponding depression in Dockum found also.

- AME identified the overlying material to be Ogallala in its original permit applications

- TNRCC and EPA decided that mtl overlying Dockum NOT an aquifer (insufficient water); the silt bed within the Dockam was declared to be the Uppermost Aquifer.

- The proposed landfill will end up excavating the overlying material out, anyway (~40 ft)

- Geology professor Tom Lehman, Texas Tech, later undertook study of area; declared that overlying material NOT Ogallala

- Prof Lehman theorized that the site is situated just south of the crest of the "Mescalero Ridge", an elevated subsurface geological feature in the Dockum which separates the Ogallala deposits to the north from the Gatuna deposits to the south

- AME stated that the Ogallala is present to the north of site ~10 mi. (1st use of irrig water, also)

- AME stated that the first "usable" aquifer in the site area is the Santa Rosa, which has a TDS ~2,500 ("slightly saline") but a Na content that prohibits its use for irrigation.

- Eunice, NM is the nearest town (6 mi away) and it gets its water from 20 mi away in NM

What BRC Emphasized in the Meeting

- The applicant must submit all proposals and specific requests in writing; the BRC will not commit to requests or proposals given orally

- Appropriate baseline sampling must be completed prior to BRC declaration that the application is "administratively complete"

- The application must follow the applicable rules in 25 TAC §289.260, and the applicant was urged to utilize the TNRCC guidance document for preparation of an Environmental Report, which includes guidance for baseline sampling (BRC provided WCS with a copy)

- The disposal site must have sufficient integrity to last at least 1,000 years

- Although a different aquifer and different set of circumstances, BRC recommends the Texcor application as one that was very well prepared and which provides an excellent example of what an applicant should do to prepare a satisfactory application

- WCS was urged to perform computer (groundwater) modeling in support of their application