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HomeMy WebLinkAbout1984 Letter Well No. 5_Quendall Terminals.pdfWILLIAM R LENIMAN, P. S: JAMES F. MCATEER, P. S. JAMES. C. HANKER, P. S. SIGURD BOROERSEN, p.11. ANN FOREST BURNS LENIHAN, MCATEER, HANKEN & BORGERSEN A PARTNiRSHI!„1$4CLUDIN3 PROFESSIONAL CORPORATIONS ATTORNEYS AT LAW 13TH FLOOR, SEATTLE TOWER 1218 THIRD AVENUE SEATTLE; WA 98IO1 (208) 824-4212 December 13, 1984 United States Environmental Protection Agency Region X 1200 6th Avenue Seattle, WA 98101 Re: Quendall Terminals Gentlemen: or COUNSEL: JOSEPH 9. IVCRS HENRY T. (VERS (1002-1974) EMMETT O. LENIHAN (1894-1931) DEC 14 1984 OFFICE. OF REGIONAL COUNSLi. EPA - REGION X This letter is submitted on behalf of Quendall Terminals in regards to it's Renton site being nominated for inclusion on the National Priority List for hazardous waste sites. Quendall Terminals believe that the listing of its site at Renton, Washington on the National Priorities List for Superfund to be in error. Apparently only superficial confirmation • of the Renton Municipal Supply System was relied upon. We believe that inappropriate (wrong) choices as to certain scoring decisions were made. We shall delineate the precise errors we find below. However, we would appreciate the opportunity to provide whatever information or additional details that you may want after you have reviewed this or during your review process. We believe the history and background of the site has been docu- mented in the information presently in your hands. The site was acquired by Reilly. Tar & Chemical, our predecessors in interest, over sixty years ago. Quendall Terminals acquired the property in 1971. Prior to the acquisition,. Reilly Tar & Chemical terminated operations in approximately 1968/69. No further deposit of hazardous waste materials has occurred. Quendall Terminals has made extensive site investigation and studies for rehabilitation of the site. Our investigation and evaluations have been shared with you. Much of the documentation utilized in your scoring is from information provided by us to you. We have reviewed the Hazardous Ranking Score (HRS) for Quendall Terminals. We take no exception with the evaluation with the air route analysis since it was found to be not applicable to conditions on the site. We have a single comment as to the surface water evaluation. Our comment relates to the evaluation of toxicity and persistence which we will address in the ground water route comments. The scoring as U.S. Environmental Protection Agency +' December 13, 1984 Page 2 _ to this section should be the same as scored in the ground water route for the reasons we will give there. This brings us to ground water route worksheet. We agree that there is an observed release. This brings into play sections 4 and 5 for evaluation. In our opinion we believe that the follow- ing portions were inappropriately scored. 1. 4-Toxicity/Persistence 2. 5 -Targets -Ground Water Use 3. 5 -Targets -Distance To Nearest Well/Population Served We will discuss each item in turn. TOXICITY/PERSISTENCE The choice utilized in the HRS was as to Toxicity/Persistence element of waste character Penta -chlorophenol. It has a toxicity level of 3 and a persistency level of 3. This results in an HRS score of 18: However in the sampling of the .entire site this compound was located in a one location at a quantity of 86 UGL which represents a very minute quantity. Under CERCLA §102 it must meet a reportable. quantity. There are no standards establishing that we have found establishing this quantity as reportable. This level of concentration is too small, too insignificant and can not be justified as the substance of concern for purposes of determin- ing waste characteristics in a 20 acre parcel. We submit that the next item for scoring, Benzene which has a toxicity of 3 and a persistency of 1 is the appropriate substance. This would result in a HRS score of 12. Therefore a total score of 13 under waste characteristics should be made for both the ground water analysis and the surface water analysis. TARGET -GROUND WATER USE In reference to Target -Ground Water Use, the HRS score is 3. This is based on 'the conclusion_ that these are private wells outside the municipal war surface area and no alternative source is available. Howv,7, wells are not located in the aquifer of concern. F ur. ther.- -= •, ,:he referenced water supply for the Class 1 well for the City .' 11. ion ignores the fact that this well has been out of 9t i t'i ..: twenty years. and is only being studied for po:asible reinstatement. No funding is current- ly available for :::.r. The entire city water supply is now U.S. Environmental Protection Agency December 13, 1984 Page 3 ,�;,__. and has been adequately supplied by other alternative sources existing and available. We submit that the HRS score under this category should be 2. TARGET -WELL AND POPULATION SERVED There is a statement that there are shallow domestic wells supply- ing water in the hills east of the site. By virtue of the eleva- tions of the hills east of the site, any shallow well would have to be located in a different aquifer than the aquifer located on the subject property. We contend and assert that neither of these well categories, shallow private wells or the public Class I Well, draw upon the aquifer of concern. The Class 1 well is stated as being used for peak summer demand only. This is totally.false. See R.W. Beck, Engineers Well No. 5 Report, 83-5194. The City of Renton verifies that the well referred to has been out of service for twenty years and is not at the present time connected into the city water system whatsoever. It is being considered as additional site. However, the City of Renton is aware of the contamination at Port Quendall and has - relied upon engineering studies that this problem would not be a matter of concern. See R.W. Beck Report 83-5194. However, no funding currently exists and the plans are so indefinite and speculative to invalidate consideration of this well. Since we believe that the private wells .are not in the aquifer of concern and since the Class 1 well referred to is not even in operation and has not been for many years, we believe that the appropriate value be placed at 0. But even should the private wells be considered, the population served should be measured by a popu- lation of only 100. This would result in a scoring of 8. There- fore, the HRS scoring under ground water route analysis for "Target" scores would then be 14 which is eight times the multi- plier of one plus two times the multiplier of 3. This would result in a scoring from the following factors: 45 X 13 X 14 with a resultant score of 8,190. 8,190 divided by 57,330 equals .1428 which multiplied by 100 would give a score of 14.28. This would be the score for the ground water route worksheet. The surface water r «ut:e worksheet would also he similarly adjusted to reflect the t-.oca1 waste characteristic score of 13. Which would reduce its current score of 7.97. . The effect of both results in a figure ten worksheet computation substantially less than 28.5. U.S. Environmental Protection Agency December 13, 1984 Page 4 In conclusion, we submit that the HRS of the Quendall Terminals site is faulty as outlined abdve. We believe the information supplied and referenced herein greatly changes the scoreand takes it under the standard established for inclusion on the NPL. We would be happy to discuss this further and supply additional detail as you wish. Sincerely, LENIHAN, McATEER, HANKEN & BORGERSEN dAME . HANKEN JCH/rw (H 768/H8) cc: Quendall Terminals The aquifer utilized by the well is a zone of predominantly sands and gravelsabout, 60 feet thick. Of this thickness, about 35 feet is rela- tively clean -, permeable material, and the remainder is clayey and there- fore relatively impermeable. Materials of all gradations may be closely interstratified throughout the water -bearing stratum. The two lengths of well screen are situated opposite two main sections of water -bearing sands and grvels. A bed of fine sand about six feet thick was reported to overlie the lower water -bearing gravel; that bed is suspected to be the main source of fine sand produced by the well. The water -bearing materials are probably outwash deposited by meltwater streams emanating from a very old (pre-Vashon) glaciation. The inter- vening clayey beds may be glacial tills, lacustrine deposits, or debris flows. Accurate geologic dating and correlation of these materials would require research of other well logs and outcrops in the vicinity, which is beyond the scope of this study; however, the aquifer response to pumping suggests that it may terminate in one direction between 1/4 and 1/2 mile away. this distance suggests the aquifer strata may be truncated by deposits flooring Lake Washington. EXISTING WELL CONSTRUCTION The well was completed in 1953 and details of Well No. 5 construction characteristics are shown on Drawing 1. Construction details presented in this report are based solely on information provided by the City of Renton. The well consists of a 20 -inch O.D. cased drill hole to a depth of 287 feet. The well was underreamed to 30 inches from 287 to 338 feet, and below 338 feet, the well bore diameter was reduced to 18 inches. Two 12 -inch diameter Everdur bronze "Cook" well screens connected by black iron inner casings are installed in the well. From the ground surface, the lower 10 -foot screen ranges in depth from 366 to 376 feet whereas the cpp_r 20 -foot screen ranges in depth from 318 to 338 feet. A 12 -inch casing/riser extends 71 feet above the upper screen, of which Converse Consultant$. Inc. -2 - INTRODUCTION. ` This report presents results -•of our ge0hydrologic- investigation- for evaluating the feasibility of well rehabilitation of the City s been out f Renton Well No. 5. This well was originally drill -ed in ficials5but report that during of service since the early 1960's'City -. operation, the well apparently pumpedmoderate amounts of sand and had; detectable iron concentrations. TheP urpose of our investigation was to evaluate characteristics of aquarifer well as required to 1) provide preliminary evaluations of qi acteristics and well production, including sand yield and pumping: rates,. assess the suitability of the well for producing a minimum of and .2) to Converse Consultants con- ducted gallons per minute of sand -free water. testing, ducted downhole evaluations, supervised and droloZed pump ic evaluations of the com- pleted laboratory tests and performed an earlier Converse investigation well. The present study Supp (Project No. 83-5194-01, dated November 16, 1983) of well characteris- tics and groundwater conditions at the well site. SITE DESCRIPTION The City of Renton Well No. 5 is located in the SW 1/4 of the W24th Section 5, T23N, R5E, just northwest of the intersection of on. of N.W. The well is and Jones Avenue N.E.. about 2-1/2miles whichnorth is elevated about 240 feet located on a gently sloping hillside, The area is above and approximately one mile east of cldere sresidences as well as ton. primarily residential, supporting scattered more recent subdivisions. GEOLOGIC CONDITIONS A driller's log of materials penetrated by Well No. 5 is included in the "As -Constructed Details," Drawing 1. Converse Coneultenb, Inc. -33 - The aquifer utilized by the well 1s a zone of predominantly sands and gravels about 60 feet thick. Of this thickness, about 35 feet 1s rela- tively clean, permeable material, and the remainder is clayey and there- fore relatively impermeable. Materials of all gradations may be closely interstratified throughout the water -bearing stratus. The two lengths of well screen are situated opposite two main sections of water -bearing sands and grvels. A bed of fine sand about six feet thick was reported to overlie the lower water -bearing gravel; that bed is suspected to be the main source of fine sand produced by the well. The water -bearing materials are probably outwash deposited by meltwater streams emanating from a very old (pre-Vashon) glaciation. The inter- vening clayey beds may be glacial tills, lacustrine deposits, or debris flows. Accurate geologic dating and correlation of these materials would require research of other well logs and outcrops in the vicinity, which is beyond the scope of this study; however, the aquifer response to pumping suggests that it may terminate in one direction between 1/4 and 1/2 mile away. this distance suggests the aquifer strata may be truncated by deposits flooring Lake Washington. EXISTING WELL CONSTRUCTION The well was completed in 1953 and details of Well No. 5 construction characteristics are shown on Drawing 1. Construction details presented in this report are based solely on information provided by the to a City of depth Renton. The well consists of a 20 -inch 0.D. cased drill hole of 287 feet. The well was underreamed to 30 inches from 287 to 338 feet, and below 338 feet, the well bore diameter was reduced to 18 inches. Two 12 -inch diameter Everdur bronze "Cook" well screens connectedegroundy black iron inner casings are installed in the well. From surface, the lower 10 -foot screen ranges in depth from 366to33768 ffeefeet whereas the upper 20 -foot screen ranges in depth from 318 L o A 12 -inch cas ' /riser extends 71 feet above the upper screen, of which -4- rma 40 feeL..9QeS.-into. the 20 -inch outer casing. -,Based, on he�i available leadt1 on , . that fig! fi screen is plugged at the bottom by ei t packer 9r similar plug• pack envelopes the 12 -inch inner casing and screen assembly. A gravelp The pack consists of 1/4 -inch minus. Poorly -graded pea gravel, extending from a depth of approximately 248 feet to the bottom of the well.a The thickness of the pack surrounding the screens varies from er screen to a minimum of thickness of nine inches adjacs`�een. to the The pack extends nearly 40 feet three inches around the lower up into the 12 -inch inner and 20 -inch outer casing. WELL PRODUCTION AND AQUIFER TESTS PUMP TESTS The purpose of the pump tests conducted on Renton Well No. 5 was to p the upper and evaluate the relative contributions of waterand Details," lower screened sections of the we�lide s'formation on the effect on sand Draw- ing 1). The'pump test also pro production and well capacity of sealing off the lower section of the well. in tests were conducted on Well No. 5, on February 10 and The two pump 9 ed continuously for slightly 16, 1984, respectively. The well was pump over six hours during each test while water levels were monitored in the he pumping well. Pump dicharge was .increased in steps throughout and performance. The maximum pumping tests to evaluate well capacity Graphs of well draw - rate reached was 1,280 gallons per minute tg�ad'usted for the variable ). down versus time for each test, roximate concentra- tion rate, are shown on Drawings 1 and 2. Theispestimated using the tion of sand being discharged during used9eaduring pump testing are Imhoff cone Method. The proc described in Appendix A. Convene Consultants, Inc. -6 - pump -discharge, was initially run at_380 gpm to observe drawdown condi- tions.. in_ the well. After 30 minutes of pumping it was evident .that the drawdow ipr the well had increased over threefold in contrast to Test No. 1. After no measurable sand was observed, the pumping rate was stepped up to 600 gpm for about 140 minutes and finally to 80U gpm for the remainder of the test. Slight fluctuations in water levels were ob- served during testing at 600 and 800 gpm which suggested that some groundwater was moving up through the gravel pack on the outside of the inner casing, contributing to the well yield.. WELL HYDRAULICS The hydraulic characteristics of Well No. 5 were evaluated from the step -drawdown test by the method of Cooper and Jacob (1946), as de- scribed in Kruseman and DeRidder (1970, pp. 138-140). This procedure consists of plotting and analyzing drawdowns in the usual way (see. standard references such as Johnson UOP, 1972) except that times are mathematically adjusted for all observations made after pump discharge is increased. Both the original and adjusted drawdown data are plotted on Drawings 2 and 3 for the first and second tests, respectively.are Cal- culated specific capacities and apparent transmissivit for each discharge increment. Effect of uifer Pro erties on Well Performance The drawdown characteristics observed in the first pump test (D aig between) suggest that the aquifer utilized by the This is could ssuggested by an abrupt 1/4 and 3/4 mile away in some direction. decrease in apparent transmissivity* after about 115 minuater bearing t M of pumping att 1,100 gpm or 150 minutes at 1,280 gpm. Some of thebeds appear to be even more limited in extent, as suggested by a de- crease in apparent transmissivity about 20 minutes into pumping at 600 f the *Transmissivity is a measure of the water-transmitting tiotmes aquifer. It is equivalen�totheaverageaquiferpermeability its thickness. c -a -7- x`',, g�`- ---- 35_ minutes at 850 gpm. This probably corresponds to the re- ductio*in:.transmissivity after 115 minutes at 380 gpm in the second test ;_ The aquifer utilized by Well No. 5 appears to have an "effective" trans- missivity of about 30,000 gpd/foot, but a longer pump tests would be re- quired to determine whether this value holds for extended pumping sties. An effective transmissivity of 30,000 gpd/foot should allow ed pumping at 1,300 gpm or higher. Effect of Well Construction on Performance During the first test, with both screen sections open to the well bore, specific capacities* decreased slightly with increasing pump rates, from 70 gpm/foot at 380 gpm to 53 gpm/foot at 1,280 gpm. The first reduction in specific capacity, between the 380 to 600 gpm pumping rates, is prob- ably related to aquifer properties. Some of the sand and gravel vells that in the aquifer zone are probably discontinuous, such they produce water at a reduced rate after a short period of pumping. This "boundary effect" was noticed after about 25 minutes at 600 gpm or 40 minutes at 850 gpm, as discussed in the previous subsection. The second reduction in specific capacity, between 850 and 1,100 gpm, probably represents a decrease in well efficiency related to the onset of the turbulent flow across the well screen. Well efficiency was fur- ther reduced at 1,280 gpm, and increasing well losses due to turbulent flow should be expected at higher discharge rates. Specific capacities were much lower during the second test, capacities which thelower well screen was sealed off with a packer. Specific during the second test varied from 28 gpm/foot at 380. gpm to 23 pa at 800 gpm. Apparent transmissivities were undiminished, -however, prob- ably indicating that water was flowing into the well bore from the lower *Specific caNa=ity, a measure of well capacity, is discharge per unit of drawdown, here computed as gpm/foot after one hour of pumping. Converse Consultant, Inc. -9-_. At flow rates above 600 gpm, measurable sand concentrations were ob- served_during both pumping tests. In general, the water discharge be- came:=sand--free or produced less than 1 to 2 ppm by volume of sand after 10 to 15,minutes of pumping. At no time did the water come sand -free at pumping rates above 800 gpm. Sand concentrations ranged from 75 to under 1 ppm by volume when both screens were being pumped simultaneously (Test No. 1). At the end of each step during Test No. 1, sand concentrations diminished from a trace at 600 gpm to 5 ppm at 1,100 gpm. Sand production during testing of the upper screen (Test No. 2) at the end of 30 minutes of pumping ranged from a trace to 1 ppm by volume. Based on these results, there appears to be a two- to threefold increase in sand production when pumping from both screens at 600 gpm or greater in comparison to the upper screen by itself. Although sanding rates are less when pumping the upper screen alone, it is our opinion that corrective measures are advisable to elim- inate sand production from both screens. Sand production from the upper screen could possibly be eliminated by surging and redeveloping the screen; however, the success of this procedure would not be known until after redevelopment has been attempted. A groundwater investigation report of the Port Quendall property, pre- pared in 1983 by Woodward -Clyde Consultants, was reviewed at requestls the of the City of Renton. The property is locatedapproximately 4 miles north of the City of Renton Well #5. The iinvestigation shallow alluval con- ducted to evaluate groundwater contamination in deposits beneath the former tar and chemical facility. The site is underlain by Recent sands, clay, silt and gravel and. is located on a delta/alluvial fan at the original mouth of May Creek. Ground lundlsurface elevations range from about 20 to 25 feet above meansea oss the site, with groundwater elevations ranging from 16 to measured in 4feet boe mean sea level. In contrast, the static water .ele at Well #5 is approximately 107 feet above mean sea level, or over 80 feet higher in elevation than static levels noted at the Port Quendall site. Comers. Con mina Ms, Inc. -10 - The: 1983 report suggests the alluvial deposits are underlain by a rela- tively thick clay unit that is widespread throughout King County. They further state that it appears the clay unit acts as an aquitard, in- hibiting downward movement of water from the younger alluvial sediments. A published geologic map of the area shows that the side slopes of May Creek valley are mantled by glacial till, a relatively impermeable de- posit consisting of cobbles to clay -size materials. This suggests that the lateral migration of potential contaminants from the Port Quendall site into adjacent aquifers is unlikely, although further study would be needed to confirm this conclusion. However, based on the subsurface conditions at the Port Quendall site as indicated by Woodward -Clyde's report and the relatively steep potential gradient between both sites (note groundwater flows from higher to lower elevations), it does not appear that the proposed pumping of Well 15 will induce movement of groundwater from the Port Quendall property into the glacial aquifer penetrated by Well 05. RECOMMENDATIONS FOR WELL REHABILITATION Based on evaluation of geologic conditions and pump test results, it appears that Well No. 5 penetrates a highly productive aquifer at a depth of about 325 to 375 feet. The aquifer is well stratified, ranging from layers of fine sand to layers of coarse sand and gravel. Because of the gradation characteristics, thicknesses, and amount of interbed- ding, the aquifer is quite complex and variable at the well site. Pump test results indicate both screened sections contribute substantially to the well capacity. The variability of aquifer deposits, in combination with the coarse, well -graded gravel pack, is the primary cause of sand production through both screens, but particularly, the lower one. • • r • • Smodomil G F 1s• 142.4. so,o. Carso v.•11 wt cloy fort, dose corss "as y.rs...l fs:o ,;,.+.r1.. 1 csososlel HI: s+=` •�7rosob•P/wj .w et.y owns , to 443;te 1 of ID• Tial prre. k• X.P. swags. G.e,ol tat- IV 80+1 • A -Of tea Imicorawnei sob, co Fw+s sem I Cowie Jori a L Cessot' e.44. -11 Not remise. -Coo *croon • • Toot �'� by toy -RawAc Wall a.,, try N. c. J AP ;YR Cass: Ewgs. — R.E.Wo1 f Source: City of Renton 5 CONOTRUCTP • DETAILS RENTON WELL NO.5 ;KENNYOA� CITY OF RENTON WELL N0. 5 for R.W. Beck and Associates Converse Consultants chni Gaol*Chn1W1 Engineering and d 8elanaat • Project No 83-5194 prawmq No 1 -3- +PPENDIX A The City_of Renton Well No. 5 was drilled and completed by N.C. Jannsen Drilling Canipanyin 1953. Records show the well was drilled to a depth of 3813,.feet.. and cased with 3/8 -inch x 20 -inch 0.D. casing from original ground=surfade`to 287 feet. From 287 to 340 feet in depth, the hole was "under reamed" to 30 inches in diameter and below 340 feet the well was completed with an 18 -inch diameter drill hole. A copy of the original as -constructed details of Well No. 5 is shown on Drawing 1. All meas- urements shown on Drawing 1 are referenced to original ground surface. Drawing 1 indicates that a 12 -inch I.D. inner casing extends from 247 to 376 feet, with two separate sections of 12 -inch Everdor Bronze Cook screen (0.100 -inch slots) joined to the casing from 318 to 338 feet and 366 to 376 feet, respectively. The original driller's record indicates that a 12 -inch casing extends from 376 to 388 feet below the lower screen which conflicts with the final detail shown on Drawing 1. It is likely that a casing does extend to the bottom of the drill hole but this could not be confirmed during our Task 1 investigation. Records also show that the bottom of the screen was plugged to tightly seal the bottom of screen. The means of plugging could not be determined, but several possibilities exist, including but not limited to: a concrete bottom, a threaded or welded plate attached to the screen or casing, and a lead or clay plug. The original bid proposal from N.C. Jannsen indi- cates their wells are generally completed with cemented bottoms but no reference to how Well No. 5 was completed could be found. The well was gravel -packed with a 1/4 -inch minus washed fine gravel. The gravel pack extended from approximately 248 to 388 feet, enveloping the inner casing and screen. The gravel pack extended 40 feet into the 20 -inch 0.D. casing and 12 feet below the lower screen.