700888050
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
        HAZARDOUS WASTE GROUND-HATER
                 TASK FORCE
         GROUND-WATER EVALUATION Of
     WASTE MANAGEMENT Of ILLINOIS,  Inc.
      ENVIRONMENTAL SANITARY LANDFILL
              JOLIET,  ILLINOIS
               ( MAY 1989 )
               JOHN J. MCGUIRE
       PROJECT COORDINATOR,   REGION V
       ENVIRONMENTAL SCIENCES DIVISION
           CENTRAL DISTRICT OFFICE
                                     Au't'N'Jr

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     UPDATE OF THE HAZARDOUS WASTE GROUND-WATER TASK FORCE
      EVALUATION OF ENVIRONMENTAL SANITARY LANDFILL, INC.
                   ELWOOD, ILLINOIS FACILITY
The  U.S.   EPA's  Hazardous  Waste  Ground-Water Task  Force,  in
conjunction with  the Illinois  Environmental  Protection  Agency
(IEPA), conducted  an evaluation  of the  Environmental  Sanitary
Landfill (ESL) hazardous  waste  disposal facility.  ESL was the
48th  of 58  hazardous  waste treatment,  storage,  and  disposal
facilities to  be  evaluated by the  Task Force.  The  Task Force
effort  is  in  response  to  recent  concerns as  to  whether  owners
and  operators  of   hazardous  waste   disposal  facilities  are
complying with the RCRA ground-water monitoring regulations, and
whether  the  ground-water  monitoring  systems  in  place   at  the
facilities are capable of  detecting  contaminant  releases  from
waste management units.   The ESL  facility is located in Elwood,
Illinois,  which  is  approximately  3   miles   south  of  Joliet,
Illinois.  The on-site field inspection was conducted from March
16 through March 20, 1987.

The  purpose of the  Task  Force  evaluation was to  determine the
adequacy  of  the  ground-water monitoring system  in regard  to
federal ground-water monitoring requirements.  Specifically, the
objectives of the evaluation at ESL were to:
             Determine compliance  with  40 CFR Part  265  interim
             status ground-water monitoring requirements
             Evaluate   the  ground-water  monitoring  program
             described in the RCRA Part  B permit  application for
             compliance with 40 CFR Part 270.14(c)

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        o    Determine  if  hazardous  waste  constituents  have
             entered the ground water at the facility

At the  time  of the inspection, the  facility had a total  of 41
RCRA ground-water monitoring wells.   The  number  and position of
these  RCRA  wells  were  determined   from a  1984  supplemental
permit  issued  by  IEPA to  modify the  previous monitoring network
to  provide  adequate  monitoring   of  the   uppermost  aquifer
surrounding the perimeter of waste management activities.

Downgradient monitoring wells G-139  and G-140 have  a history of
organic contamination.  These two wells were not sampled at the
time  of  the  Task  Force  inspection because  Waste  Management
Incorporated  (WMI)  had installed inflatable packing  devices in
the wells.    The  inflatable packers  were installed  to  prevent
contaminants  from reaching  the ground-water through the  well
casing  after  an  August  25, 1986, borescope inspection of  the
wells revealed  cracks and red staining below the cracks..   IEPA
issued  Supplemental Permit No.  L986-221-SP to WMI replace wells
G-139   and  G-140.     Once   the  replacement wells  have  been
installed, developed,  and approved  by  IEPA, wells  G-139 and G-
140 may be decommissioned  and future  sampling  efforts can be
concentrated on the replacement wells.

Three  replacement wells  have  been   installed at ESL  since  the
March 1987 inspection. Well  R-139 replaces well  G-139 and wells
R-40S   (shallow)   and  R-40D  (deep)  are   the well  cluster
replacements  for  well  G-140.     Subsequent sampling  results
indicate a continued  problem with organic contaminants  in this
vicinity.    A  list  of  organic  contaminants  detected  in  the
replacement wells  in  1987 and from  subsequent sampling  in 1988
is shown in Table A.

WMI  maintains  that  the  source  of  the  hazardous  waste  or
hazardous waste constituents detected in  old well G140 and well
R40D  are  the  result of  contaminants  moving   down  through  a
cracked casing in  former well  G140.   Though   a  crack in  the

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casing  of  the former well G140 was  documented by videotapes of
borescope  investigations,  the  source of the contamination which
may have  entered this casing has not been  identified.   WMI has
stated,  in their  August 26,  1986  Assessment Report,  that the
exact  pattern and  source of  seepage  (into  well G140)  is not
known.   They stated  that  one  possibility  was  surface  water
seeping  down  from  the landfill  and stone  access road.   This
hypothesis  still fails  to address  a source  of contamination,
since  surface water  would  only  come  into contact  with  clean
soil overlaying a clay cover, and should never come into contact
with hazardous waste  or  hazardous waste constituents.  The clay
cover  itself  has been  described  by  WMI  (in their May  4,  1988
Closure Plan Revision) as consisting of a minimum of 2.5 feet of
compacted fine-textured soil with an average permeability of 2.2
x  10~8 cm/sec.   Furthermore, well  G140 was protected with  a
concrete  collar   (i.e.,  concrete  apron)  and  was grouted  with
cement/bentonite  mixture  to  prevent  infiltration  of  surface
water  runoff  into the well.   Alternatively,  WMI has  stated, in
their August  26,  1986  Assessment  Report,  that gas has also been
detected in the  well headspace of G140.   They  have  postulated
that the crack in the well may be the  avenue through which gas
entered  G140.  They  further  stated  that  the  gas  from  the
landfills carry  liquid with  it,  that the  liquid condenses when
it is  exposed to  cooler  air,  and  the seeping into G140 (assumed
from borescope investigations) may be this  gas condensate.   But
again, WMI failed to identify the source of contamination,  since
this well  was not  finished  in  a landfill,  it  was  located at
least  25  feet south  of  the  edge  of the  landfill,  and it was
isolated from the landfill by a ten  foot  clay  liner  of similar
quality to the clay cover described above.

WMI has yet to prove that  the  small  crack in the casing of well
G140  is responsible  for  introduction  of  contaminants of  the
variety  and  concentrations  that  have   been  so persistent  in
groundwater samples from this area.   Assuming the cracked casing
did allow  contaminants to impact  groundwater quality, WMI has

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also failed  to  identify the source of these contaminants.   The
contaminants that  have been  identified  in groundwater  samples
from this area thus far are also those that have been identified
in leachate samples from the Area 1 co-disposal landfill.

It is concluded, from review of the data  that has been presented
thus far, that the Area 1  co-disposal  landfill  is  the source of
groundwater contamination by hazardous waste or hazardous  waste
constituents, and WMI  has  failed to  provide convincing evidence
to the contrary.

WMI submitted  a closure plan  for its RCRA-regulated hazardous
waste management  units at  ESL in February 1988.    The  closure
plan  includes  the  surface   impoundments  (Ponds   5  and  6),
container   storage  facility,   decant   facility,   co-disposal
landfill, and drum disposal trenches.

In May 1988, WMI  requested that  it's Part  B Permit  application
be withdrawn and  in November  1988,  IEPA formally granted that
request.

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Well
RU9
R40S
R40S
R40S
R400
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R400
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R400
R40D
R40D
R40D
Sample
Date
05/06/87
08/05/87
11/05/87
02/26/88
05/06/87
05/06/87
05/06/87
05/06/87
05/06/87
05/06/87
05/06/87
05/06/87
05/06/87
05/06/87
05/06/87
05/06/87
05/06/87
05/27/87
07/10/87
07/10/87
07/10/87
07/1 0/87
07/10/87
07/1 0/87
07/10/87
08/05/87
08/05/87
08/05/87
08/05/87
08/05/87
08/05/87
09/1 0/87
09/10/87
09/10/87
09/10/87
09/1 0/87
09/10/87
10/02/87
10/02/87
10/02/87
-10/02/87
1 0/02/87
10/02/87
11/05/87
                     TABLE  A

ORGANIC CONTAMINANTS DETECTED IN REPLACEMENT WELLS


                  Parameter                        Cone.

                  Methylene Chloride               9.4 ug/1
                  Methylene Chloride               29.0 ug/1
                  Methylene Chloride               43.0 ug/1
                  Methylene Chloride               10.2 ug/1
                  1,1 -01 chloroethane               225.0 ug/1
                  1,2-Dichloroethane               34.2 ug/1
                  Methylene Chloride               4.11 ug/1
                  1,2-Dichloropropane              14.3 ug/1
                  1,2-trans-Dichloroethylene       254.0 ug/1
                  Trichloroethylene                13.0 ug/1
                  Trichloroethylene                14.7 ug/1
                  Vinyl Chloride                   63.6 ug/1
                  Chromium (total)                 178.0 ug/1
                  Iron                             37.5 mg/1
                  Iron                             37.5 mg/1
                  Hexachlorophene                  104.0 ug/1
                  Kepone                           1.39 ug/1
                  Trichloroethylene                13.0 ug/1
                  Benzene                          5.58 ug/1
                  1,1-Dichloroethane               216.0 ug/1
                  1,2-Dichloroethane               25.0 ug/1
                  1,2-Dichloropropane              15.2 ug/1
                  1,2-trans-Dichloroethylene       196.0 ug/1
                  Trichloroethylene                13.1 ug/1
                  Vinyl Chloride                   69.1 ug/1
                  l,l-D1chloroethane               130.0 ug/1
                  1,2-01 chloroethane               18.6 ug/1
                  1,2-Dichloropropane              10.2 ug/1
                  l,2-trans-D1chloroetnylene       93.5 ug/1
                  Trichloroethylene                6.38 ug/1
                  Vinyl Chloride                   36.5 ug/1
                  1,1-Dichloroethane               131.0 ug/1
                  1,2-Dichloroethane               17.7 ug/1
                  1,2-Dichloropropane              9.98 ug/1
                  1,2-trans-Dichloroethylene       84.5 ug/1
                  Trichloroethylene                8.25 ug/1
                  Vinyl Chloride                   32.1 ug/1
                  1.1-Dichloroethane               107.0 ug/1
                  1,2-Dichloroethane               16.2 ug/1
                  1,2-Dichloropropane              7.94 ug/1
                  Methylene Chloride               7.6 ug/1
                  1,2-trans-Dichloroethylene       50.0 ug/1
                  Vinyl Chloride                   24.7 ug/1
                  Methylene Chloride               18.9 ug/1

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                             TABLE A (Continued)

             ORGANIC CONTAMINANTS DETECTED IN REPLACEMENT WELLS

Well
R40D
R40D '
R400
R40D
R400
R400
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R400
R400
R40D
R40D
R40D
R40D
R40D
R400
R400
R400
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
R40D
Samp! e
Date
02/26/88
02/26/88
02/26/88
02/26/88
02/26/88
02/26/88
02/26/88
06/01 /88
06/01 /88
06/01 /88
06/01 /88
06/01 /88
06/01 /88
06/01 /88
06/01/88
06/01 /88
06/01 /88
06/01 /88
06/22/88
06/22/88
06/22/88
06/22/88
06/22/88
06/22/88
06/22/88
06/22/88
06/22/88
06/22/88
07/21 /88
07/21 /88
07/21/88
07/21 /88
07/21/88
07/21 /88
07/21 /88
07/21 /88
07/21 /88

Parameter
l,l-D1chloroe thane
Methylene Chloride
1 ,2-trans-D1chloroethylene
Vinyl Chloride
1,1-Oichloroethane
Methylene Chloride
1 ,2-trans-D1chloroethylene
Chi oroethane
Dichl orodi fl uoromethane
1,1-Dichloroethane
1,2-Dichloroe thane
1 ,2-D1chloropropane
Methylene Chloride
1 ,2-trans-Dichloroethylene
Trichloroethylene
Tri chl orofl uoromethane
Chi orome thane
Vinyl Chloride
Chl oroe thane
Chloromethane
Di chl orodi f 1 uoromethane
1,1 -Dichl oroethane
1,2-Dichloroe thane
1 ,2-Dichloropropane
Methylene Chloride
1 ,2-trans-Dichloroethylene
Tri chl orofl uoromethane
Vinyl Chloride
Chl oroethane
Dichl orodi fl uoromethane
1,1-Dichloroethane
1 ,2 -Dichl oroethane
1 ,2-Dichloropropane
1 ,2-trans-Dichloroethylene
Trichloroethylene
Trfchl orofl uoromethane
Vinyl Chloride
**
     Methylene  chloride  detected in 6/22/88 field blank at
     4.64 ug/1.
     Trichojrofluoromethane detected in 6/22/88 field blank
     at 10.0 ug/1.
***  Trichlorofl.uoromethane detected in 7/21/88 field blank
     at 1.2 ug/1.
                                                                Cone.

                                                                87.5 ug/1
                                                                9.79 ug/1
                                                                30.5 ug/1
                                                                20.9 ug/1
                                                                70.3 ug/1
                                                                7.63 ug/1
                                                                29.8 ug/1
                                                                1.8 ug/1
                                                                6.7 ug/1
                                                                57.0 ug/1
                                                                7.1 ug/1
                                                                3.3 ug/1
                                                                1.8 ug/1
                                                                21.0 ug/1
                                                                3.3 ug/1
                                                                2.8 ug/1
                                                                2.0 ug/1
                                                                6.7 ug/1
                                                                3.5 ug/1
                                                                5.0 ug/1
                                                                8.3 ug/1
                                                                75.0 ug/1
                                                                8.9 ug/1
                                                                4.6 ug/1
                                                                1.8 ug/1 *
                                                                19.0 ug/1
                                                                13 ug/1 **
                                                                8.3 ug/1
                                                                1.8 ug/1
                                                                4.7 ug/1
                                                                46.0 ug/1
                                                                5.8 ug/1
                                                                3.0 ug/1
                                                                12.0 ug/1
                                                                1.0 ug/1
                                                                1.7 ug/1***
                                                                4.7 ug/1

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
        HAZARDOUS WASTE GROUND-WATER
                  TASK FORCE
         GROUND-WATER EVALUATION Of
     WASTE MANAGEMENT of  ILLINOIS,  Inc.
       ENVIRONMENTAL  SANITARY LANDFILL
               JOLIET,  ILLINOIS
                  (MAY 1989)
               JOHN J. McGUIRE
       PROJECT COORDINATOR,  REGION V
       ENVIRONMENTAL SCIENCES DIVISION
           CENTRAL DISTRICT OFFICE

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                                  TABLE OF ULNHNES
EXECUTIVE SUMMARY

     INTRODUCTION	    1

     SUMMARY OF FINDINGS AND CCNCLUSICNS	  .  .  .    8
          CCMPLIANCE WITH  INTERIM STATUS GROUND-WATER  IYCNTTQRING - CHAPTER  35
          ILLINOIS ADMINISTRATIVE CODE 725 SUBPART F (40 CFR 265 - SUBPART F)  .  .    8
          Section 725.191 (Section 265.91) Ground-Water Monitoring System ....    9
          Section 725.192 (Section 265.92) Sampling and Analysis	12
          Section 725.193 (Section 265.93) Preparation,  Evaluation, and Response .   13
     GROUND-WATER PROGRAM PROPOSED FOR RCRA PERMIT	14
     TASK FORCE SAMPLING AND MCNITORING DATA ANALYSIS	     14
     CONFORMANCE WITH SUPERFUND OFF-SITE POLICY	15

TECHNICAL REPORT

     INVESTIGATIVE METHODS	17

          RECORDS/TORMENTS REVIEW AND EVALUATION	17
          FACILITY INSPECTION	18
          LABORATORY EVALUATION	19
          WATER LEVEL AND WELL DEPTH MEASUREMENTS	19
          GROUND-WATER SAMPLING AND ANALYSIS	20

               Purging	26
               Sample Collection, Handling and Preservation	27

     FACILITY OPERATIONS AND WASTE MANAGEMENT UNITS	31

          FACILITY OPERATIONS	31
          WASTE MANAGEMENT UNITS	32

               RCRA-Regulated Waste Management Units	35

                    Co-Disposal Landfill	35
                    Drum Disposal Trenches	37
                    Container Storage Area	38
                    Decant Facility	39
                    Surface Inpoundments	42
                    Trench. 11	43

               Pre-RCRA Waste Management Units	43

                    Surface impoundments	43
                    Landfarm	44

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                                                                                 Page
     SITE HYDRCGEQLOGY	;	45
               STRATIGRAPHY	47
               HYDROGEOLOGIC UNITS	50

                    Monitored Composite Aquifer	51
                    Silurian Transmissive Zones	52
                    Cambro-Ordovician Aquifer System	53

               GROUND-WATER FLOW DIRECTION AND RATES	53

     GROUND-WATER MONITORING DURING INTERIM STATUS	60

          REGULATORY REQUIREMENTS	60
          GROUND-WATER SAMPLING AND ANALYSIS ELAN	61
          SAMPLE ANALYSIS AND DATA QUALITY EVALUATION	62

               Inorganic Laboratory	63
               Organic Laboratory	65
               Radiochemistry Laboratory	66

     MONITORING WELLS	67

               Well Locations	69
               Well Construction	72

     GROUND-WATER ASSESSMENT PROGRAM OUTLINE	78
     GROUND-WATER ASSESSMENT MONITORING	81

               Ground-Water Quality Assessment for tne P-Series Wells	81
               Ground-Water Quality Assessment for the G-Series Wells	86

     STATUS OF GROUND-WATER MONITORING UNDER INTERIM STATUS	91
     GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA. PERMIT	92

     MONITORING DATA ANALYSIS FOR INDICATIONS OF WASTE RELEASE	93

REFERENCES	97


Appendices

     A    GROUND-WATER SAMPLE ANALYSES FOR TASK FORCE INSPECTION OF ESL
                                

     B    EVALUATION  OF THE  QUALITY  CONTROL DATA PERTAINING  TO  THE ANALYSIS  OF
          SAMPLES FROM ESL

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                                LIST CF TABLES


Table                                                                         Page

  1    TASK FORCE SAMPLE CQLLECTICN DESCRIPTION  ...............  21

  2    ORDER OF SAMPLE COLLECTICN BOTTLE TXPE AND PRESERVATIVE LIST  .....  29

  3    WASTE STREAMS ACCEPTED BY raf. .....................  32
  4    QUANTITY CF WASTES RhX/KLVED AT ESL CO-DISPOSAL LANDFILL AND DRUM
       DISPOSAL TRENCHES ...........................   36

  5    PUMPING TEST RESULTS FRCM AQUIFER WELLS ................   58

  6    MCNITQRING WELL CONSTRUCTION DESCRIPTION  ...............   73

  7    HISTCRIC  IKilL'HD   QRQ\NIC  CCNEAMINANTS  REQUIRING  INITIATION  OF   THE
       ASSESSMENT PROGRAM  ..........................   89

  8    ORGANIC ANALYSES FRCM TASK FORCE SAMPLING ...............   96

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                                LIST OF FIGURES


Figure                                                                       Page

   i   SHE LOCATION MAP	   3

   2   WASTE MANAGEMENT UNIT AND INTERIM STATUS MHTTORING WELL LOCATIONS  . .   5

   3   WELLS SAMPLED DURING TASK FORCE INSPECTION	24

   4   LOCATION  OF  CURRENT  AND   PAST   WASTE  MANAGEMENT  UNITS  ENVIRONMENTAL
       SANTTARy LANDFILL	34

   5   GENERALIZED STRATIGRAFHIC COLUMN OF THE GEOLOGY OF THE CHICAGO REGION .  48

   6   GENERALIZED GEOLOGIC CROSS-SECTICN  OF THE ESL SITE	49

   7   COMPARISON  OF WATER  LEVELS IN UPPERMOST  AQUIFER  AND COMPOSITE  DEEPER
       SILURIAN DOLOMITE TRANSMISSIVE  ZONES	55

   8   LOCATION MAP OF P-SERIES  MONITORING WELLS	68

   9   LOCATION MAP OF G-SERIES  MCNTTORING WELLS	70

  10   TYPICAL CONSTRUCTION FOR  THE UPPERMOST AQUIFER MONITORING WELLS ....  74

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EXECUTIVE SUMMARY

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                          INTRODUCTION
Concerns  have  recently  been  raised  about whether  commercial
hazardous waste  treatment,  storage,  and disposal (TSD) facilit-
ies  are  in  compliance with the ground-water monitoring require-
ments  promulgated under  the Resource  Conservation  and Recovery
Act  (RCRA).   Specifically,  the concerns focus  on the ability of
existing or proposed ground-water monitoring  systems  to detect
contaminant  releases  from   waste   management   units  at  TSD
facilities.   In response  to these concerns, the administrator of
the  U.S.  Environmental  Protection Agency  (EPA) established  a
Hazardous Waste Ground-Water Task Force to evaluate the level of
compliance  at  TSD facilities and address the  causes  of noncom-
pliance.  The Task Force  is comprised of personnel from U.S. EPA
headquarters, including the  Office  of Solid Waste and Emergency
Response (OSWER), U.S.  EPA  regional offices,  and state regulat-
ory  agencies.    To  determine  the  compliance   status  of  all
facilities  nationwide, the Task  Force is conducting an in-depth
facility investigations,  including on-site  inspections,  of  58
facilities.   The objectives of these investigations  are to:
        o  Determine compliance with interim status ground-
           water monitoring  requirements  of 40 CFR Part  265  as
           promulgated under RCRA or  35  Illinois  Administrative
           Code (IAC) Part 725 (the state equivalent).

a   Regulations promulgated  under  RCRA address hazardous  waste
management  facilities'   operations,   including  ground-water
monitoring, to ensure that hazardous  waste  constituents are not
released to the environment.

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        o  Evaluate '  the  ground-water  monitoring  program
           described  in  each  facility's  RCRA  Part  B  permit
           application for compliance with 40 CFR Part 270.14(c)
           and 35 IAC Part 703.185.

        o  Determine  if  the  ground  water   at   each  facility
           contains hazardous waste  constituents.

        o  Verify  the quality  of  the  facility's  ground-water
           monitoring data and evaluate the sampling and
           analytical procedures.

        o  Provide information to  assist the  agency in determin-
           ing,  if  each  inspected TSD  facility  meets  EPA's
           ground-water  monitoring  requirements   for   waste
           management  facilities   receiving  waste   from   the
           response   actions  conducted under the  Comprehensive
           Environmental Response,  Compensation,  and  Liability
           Act (CERCLA, Public Law 91-510)a.

To address these  objectives,  each Task  Force investigation  will

determine if:

        o  The  facility  has  developed  and  is   following  an
           adequate ground-water sampling and analysis plan.

        o  Designated  RCRA   and/or  state-required  monitoring
           wells are properly located and constructed.

        o  Required analyses have  been conducted  on samples  from
           the designated RCRA monitoring wells.

        o  The ground-water  quality assessment program outline
           (or plan, as appropriate) is adequate.

One of the TSD facilities investigated by the Task Force was the

Environmental  Sanitary  Landfill  (ESL)  facility,  also  known  as

Waste Management Inc. - Joliet (WMI).  The 260-acre site
   EPA policy,  stated in  the  November 13,  1897  directive on
   "Procedures  for  Implementation  Offsite  Response  actions"
   requires that TSD  facilities receiving CERCLA waste  be  in
   compliance with applicable RCRA ground-water monitoring
   requirements.

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                                  FIGURE 1
                            SITE LOCATION MAP
Source:    Woodward-Clyde Consultants 1982.  Geologic, Geotechnical, and
Hydrogeologic Evaluation of Expansion Area to Chemical Waste Management, Inc.
Joliet, Will County, Illinois, July 1982.

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                               4
is  located  southwest of the  junction of Laraway  and Patterson
Roads in Elwood, Will County, Illinois (  see Figure 1).  The Des
Plaines  River  is  1/2  mile  to  the northwest,  and the  City of
Joliet is less  than  3  miles to the north.   The ESL facility is
owned and operated by  Waste Management of Illinois, Inc. (WMI).
The Task Force  conducted  its on-site  inspection of the facility
from  March  16  through March 20,  1987.    The  Central  District
Office  of  EPA  Region   V's  Environmental  Services  Division
coordinated  the  inspection  activities.    Personnel  from  EPA
Region V RCRA Enforcement  and Permit  organizations and from the
IEPA participated in the Task Force inspection activities.

WMI acquired the site  on February  5,  1973,  at which time only a
small  portion  of  the  co-disposal  landfill  had  been  filled.
Little  information  is  available  concerning  early  landfilling
practices at  the site.   Prior to 1980,  the  facility operated
five pre-RCRA waste management units:
        o  Four  surface  impoundments   (Ponds  1 through  4)  that
           were used to  store industrial and municipal  sludges
           prior to land treatment.
        o  A  landfarm  where  the   industrial  and  municipal
           sludges were sprayed.

The  facility  also  includes  the   following  six RCRA  hazardous
waste management units  (see Figure 2):
        o  Co-disposal  landfill
        o  Drum disposal trenches
        o  Container storage area
        o  Decant facility  
        o  Surface impoundments (Ponds 5  and 6)

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                FIGURE 2
WASTE MANAGEMENT UNIT AND INTERIM STATUS



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-------
                               6
The hazardous  waste management units at  this  facility received
RCRA  hazardous wastes both  in  bulk form and  in  containers for
on-site  disposal.    The  facility  also  received  industrial and
municipal  wastes  for  disposal  in the  co-disposal  landfill.
These wastes included waste  considered  hazardous  under RCRA due
to  the   characteristics  of   ignitability,   EP   toxicity,  or
corrosivity,  and   solvents   from  non-specific   and  specific
sources.    The  facility  stopped  receiving  wastes in  Spring  of
1984.   Since 1984,  materials generated  from the decommissioning
and closure of  several  units  have been  disposed  of  in  the
landfill.   The facility was inactive at the  time of the  Task
Force  inspection.

WMI submitted  a RCRA  Part  B permit  application  on  August 29,
1983,   and  has since  received  several   notices  of  deficiency
(NODs) from U.S.  EPA  and IEPA  regarding the  application.   WMI
has submitted  revisions to U.S. EPA  and  IEPA of its  RCRA Part B
permit application in response to the NODs.

The site  is   underlain  by  approximately  30  feet  of  glacial
sediments consisting of a till unit over a glacial outwash unit.
These  glacial  sediments lie  atop  the  lower  Paleozoic  bedrock
sequence   of sedimentary rocks.    WMI's  consultants  have  iden-
tified three   major  hydrologic  units  beneath  the  site.    The
uppermost  portion  of  the   bedrock contains  ground  water  in
fissures,  joints,  bedding  planes,  solution   cavities,   and

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                               7
crevices.   WMI's consultants  have  determined that  the  glacial
outwash unit and the weathered and fractured bedrock immediately
beneath the outwash  are  hydraulically connected and, therefore,
the facility considers  this composite unit to  be  the uppermost
aquifer.   The  U.S.  EPA  and IEPA agree with the designation of
this combined  unit  as the  uppermost  aquifer.   Ground water in
this  aquifer  flows  primarily  in  a  northwest   to  westerly
direction across the site, toward the Des Plaines River.

An  interim status  ground-water monitoring  system  consisting of
41  wells  (G-series)  have  been in  place  since March  1984   (see
Figure 2).  This system consists of four upgradient wells (G-lll
through G-114)  and  37 downgradient wells  at the  limits  of the
waste management areas  to monitor the uppermost aquifer.   This
system  replaced  the previous  system  of eight  wells (P-series)
which was  not  considered by IEPA to  be adequate to monitor the
ground water in  the  uppermost aquifer.  Five wells  are  also in
place  (GT-series)  to monitor the ground  water in  the  glacial
till, overlying the  glacial  outwash.   The  Task Force sampled 26
monitoring wells during  the March 1987 inspection,  including 2
GT  series  wells.   The  GT-series  well system  was  sampled and
evaluated  to   aid  in assessment  of  the  adequacy  of the  RCRA
interim status ground-water monitoring program.

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                               8
              SUMMARY OF FINDINGS AND CONCLUSIONS

From  March 16  through  March 20,  1987,  Task Force  personnel
investigated the RCRA  compliance of the  interim  status ground-
water monitoring  program at  the Waste Management  of  Illinois,
Inc., ESL  facility  in  Elwood,  Illinois.   The  interim status
ground-water  monitoring  period  began  in November  1981  when
applicable provisions of the  RCRA regulations became effective.
The  findings  and conclusions  presented in this  report reflect
conditions  existing at  the   facility  in  March   1987.    Later
actions taken by Illinois EPA  (IEPA), U.S. EPA Region V, and ESL
are summarized in the update.
COMPLIANCE WITH INTERIM STATUS GROUND-WATER MONITORING - CHAPTER
35  ILLINOIS ADMINISTRATIVE  CODE  725  SUBPART  F  (40 CFR  265-
SUBPART F)
WMI  installed  an  initial  ground-water  monitoring system  (P-
series wells) in January  1980  at its ESL facility.   Six of the
eight P-series  wells  exhibited  significant  changes in indicator
parameters in the  Spring of  1983,  triggering these  wells into
ground-water  assessment  monitoring.   The  P-series wells were
characterized as  being insufficient  to  adequately monitor  the
ground water  at the  facility.    In  December  1983,  WMI submitted
an  application  to IEPA  to modify  the ground-water  monitoring
program.  IEPA  issued a supplemental  operating permit to WMI to
modify the ground-water monitoring system.

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                               9
WMI  installed the  new RCRA  ground-water monitoring  system in
March  1984.   This monitoring system consists of 41 ground-water
monitoring wells  (G-lll through G-151) which are screened in the
uppermost aquifer.   At this time,  WMI also installed five wells
(GT-10 through GT-14)  to  monitor the glacial till located above
the  uppermost aquifer.   Figure  2 shows  the  locations  of  the
waste  management  units  and  the   interim status  ground-water
monitoring network.    Based on the  results  of the  August  1985
sampling  event,   seven  of  the  G-series  wells  entered  the
assessment monitoring phase.

Section 725.191 (Section 265.91) Ground-Water Monitoring System

The  Task Force  noted  several problems  with the  ground-water
monitoring system  in place  at  WMI's ESL  facility  at  the time of
the inspection.  Two of the downgradient wells (G-139 and G-140)
were  unavailable   for  sampling at  the  time  of  the  inspection
because inflatable  packing  devices had been installed in them.
WMI  stated  that  the packers were  installed  by WMI  to prevent
contaminants  from reaching  ground water  through cracked  well
casings.   Well G-139 and  G-140 were  scheduled to be  sampled by
the Task  Force because they were two  of  the  downgradient wells
with a history of detected contamination.  Both  of  these wells
were in the assessment sampling phase.  WMI presented Task Force
personnel  with  a  waiver  of  responsibility  for  ground-water
contamination  resulting  from  the  removal  of  the  inflatable

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                               10
packers.   The wells  were not sampled  because  (1) U.  S.  EPA's
policy  is  not to sign  any waiver of responsibility,  (2)  there
was no  method available  to sample the ground  water  below the
packer,  (3)   these  wells have  a  well documented  history  of
contamination, and  '(4)  of the time constraints of the inspec-
tion.    Because of the packers in these wells a period of time,
including the time  of the inspection, the  quality  of  the ground
water in an area approximately 600  feet along the  southern edge
of the co-disposal landfill was unknown

The Task Force personnel  noted that for some of the  wells con-
structed prior  to  1984,  discrepancies existed  between  field
observations  and  the sampling plan regarding the  construction
material.    Not   all  of   these  wells  were  constructed  using
Schedule 80 PVC pipe.  The Task Force is concerned that some of
the wells  have excessive  screened intervals.  The RCRA Ground-
Water Monitoring Technical  Enforcement  Guidance Document states
that  excessive  screen  lengths can  result  in  the dilution  of
contaminants  present  in  the  ground  water  (U.S.  EPA,  1986b).
The use of  interval sampling in  those  wells  with  excessive
screen  lengths  could possibly  reduce  the effect  of  dilution.
However, in  situations  such as those existing at  ESL, with the
wells  located in  outwash  sediments  in excess  of  40  feet  in
thickness,   there   is  no  guarantee  that  dilution   would  be
completely eliminated because  of  mixing and vertical  communica-
tion.  In addition,  because interval sampling does  not allow for

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                              11

purging of the wells,  it  is  likely  that  a'representative sample

of groundwater would not be produced.  The Task Force also recom-

mends that well  clusters  be used for  any additional monitoring

wells installed at  the ESL  facility where the uppermost aquifer

is of great thickness.  The  Task  Force recommends  that the con-

taminant dispersion model used by WMI's consultants be evaluated

to  assess  (1)  the assumptions  it  incorporates  and   (2)  the

conversion of the  model results to the  lateral  monitoring well

spacing used  at  the site.  Several  deficiencies  in  the ground-

water monitoring system were also noted  at  the time  of the Task

Force inspection:

        o  Wells G-136 and G-137 were  discovered  to be 3.65 feet
           and 4.06 feet shallower,  respectively, than when they
           were originally installed.

        o  WMI made no  provisions for  disposing  of the ground
           water purged from the monitoring  wells  before  the
           samples were taken.  If  sample analyses suggest that
           the ground-water  is  hazardous,  it  should  be drummed
           and disposed of properly.

        o  All of the well construction and many  of the sampling
           components are made  of PVC  plastic  that can sorb and
           desorb  organic  constituents.    The  extensive use  of
           PVC rather  than more  inert materials could  lead  to
           biased  ground-water  sample.     The   use  of  other
           devices,  such  as   stainless   steel   and  dedicated
           sampling    equipment,  would  minimize  possible
           contamination   during  withdrawal and ensure samples
           that are representative of  the aquifer.

        o  Five   glacial till  (GT-series)  monitoring  wells are
           situated around the perimeter  of the waste management
           area.   WMI  indicated that the purpose of  these  wells
           was to detect any contaminants migrating horizontally
           through  the  till  and bypassing  the wells monitoring
           the uppermost aquifer.  The number, location, and
           spacing of the glacial till wells  is  inadequate to
           meet the outlined objective.

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                               12
The  Task  Force,   in   their   evaluation,   identified  several
deficiencies  in  the  ground-water  monitoring program  currently
in use at the ESL  facility.  In addition several flaws  were also
noted in the analytical procedures utilized by the facility. The
Task Force concludes  that  the  ESL  facility  is not in compliance
with the  interim status  ground-water monitoring requirements of
111. Adm. Code Part 725 or 40 CFR as. promulgated under  RCRA.

Section 725.192 (Section 265.92) Sampling and Analysis

The ground-water sampling  and  analysis plan  contained in ESL's
RCRA  Part  B permit application  does  not  contain  any  site-
specific  guidelines  or  information-.    Task  Force  personnel
reviewed  two  other  sampling   and  analysis  plans  during  the
facility  inspection.    One was   a  site   specific  plan  dated
November  1985,  and  the other  was  a generalized WMI document
dated September 1986.  These two documents should be included in
ESL's RCRA Part B permit application.

WMI  uses three  off-site  laboratories to  provide  analyses  of
ground-water samples  taken  at  the  ESL facility.  The  laborator-
ies  used by WMI  are Environmental  Testing and Certification
(ETC)  of  Edison,   New  Jersey;   Gulf  Coast  Laboratories  of
University  Park,   Illinois;  and  Core  Laboratories  of  Casper,
Wyoming.  The Task Force noted two deficiencies in the procedu-
res  used by  Gulf  Coast Laboratories in analyzing  samples for

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                               13
cyanide.   The  Task Force noted two deficiencies  in  the extrac-
tion  procedures  used  by ETC  when analyzing  samples  for  pes-
ticides  and PCBs  and  semi-volatiles.    Core  Laboratories  has
been certified by EPA Region VIII for the analysis of radionucl-
ides.    Other  observations  and  recommendations  regarding  the
laboratories appear  in  full  in  the Sample  Analysis  and  Data
Quality Evaluation section of this report.

Section  725.193  (Section 265.93)  Preparationf  Evaluation,  and
Response

At  the  time of  the inspection,  the  P-series monitoring  wells
remained  at  the  site,   but  they were  plugged  and  awaiting
decommissioning.    Some of the  G-series  wells  triggered into the
assessment  monitoring  phase in  August  1985 were still in the
assessment phase.  The Task Force noted the following deficien-
cies in the facility's ground-water assessment program outline:
        o  The  facility's  "Outline  of  Ground-Water   Quality
           Assessment Program" is  too vague.   The outline  lacks
           sufficient detail  that could  be used to  determine:
           (1)     whether hazardous  waste  or  hazardous  waste
           constituents have entered  the ground water;  (2)  the
           rate  and  extent  of migration  of hazardous  waste  or
           hazardous waste constituents  in the ground water; and
           (3)  the concentration of hazardous waste or hazardous
           waste constituents in the ground water.

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                               14



GROUND-WATER PROGRAM PROPQfiT;;]? fOR RCRA PERMIT







On  June  21,  1986  U.S. EPA  Region V  issued an  administrative



complaint  and compliance  order to  WMI  for  failing to  supply



information  required  to  complete  the   RCRA   Part  B.  permit



application for the  ESL  facility.   Two areas of  concern  in the



order are:   (1)  an.  incomplete  summary  of ground-water  monitor-



ing data obtained  during  interim status,  and (2) the  lack of a



plan for the description of  any plume of  contamination  that has



entered the ground water from a regulated unit.







TASK FORCE SAMPLING AND MONITORING DATA ANALYSIS







Organic  analyses  of  samples  from  the  ground-water  monitoring



wells  indicated  that  a  release of hazardous  constituents  .is



probably occurring  at ESL.    Several wells recorded levels  of



organic   constituents  greater  than  the  contract  required



detection levels (CRDL).   These wells included:







        G-123 (1,2-trans-dichloroethane - 6 ug/L),



        G-129 (vinyl chloride - 10 ug/L and 11 ug/L, duplicate),



        G-134 (trans-1,2-dichloroethane 7 19 ug/L,



                1,1-dichloroethane - 12 ug/L).







The total  lead data  was  judged to be qualitative,  but  wells



G-117, G-118,  G-137,  and  G-141 all showed increases  in total

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                               15
lead  levels  over  the  upgradient wells  and above  the  national
interim  primary  drinking  water  standard  levels.    Twenty-one
wells  showed total  iron  levels  above  the proposed  secondary
drinking water  standards  levels.   Other metals  were present in
downgradient wells at levels above those found in the upgradient
wells.

Based on  historical  sampling  data  and the TasJc Force  sampling
data, the Task  Force concludes that the ground-water at the ESL
facility does contain hazardous waste constituents  and that the
Area  1  co-disposal landfill is the source of  the  ground-water
contamination.  The Task Force recommends  that  a  thorough and
complete evaluation of  the plume of  contamination  be conducted
by ESL, unless  they can clearly demonstrate that the contamina-
tion is from a source other than the regulated units.

CONFORMANCE WITH SUPERFUND OFF-SITE POLICY  .

The ESL facility  was not accepting  hazardous  waste  generated at
a  Superfund  cleanup site.  The pendency  of the administrative
complaint citing ground-water monitoring violations  rendered the
facility unacceptable,  in  accordance with u. S.  EPA's  Off-Site
Policy, to receive Superfund cleanup waste.

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TECHNICAL REPORT

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                              17
                     INVESTIGATIVE METHODS

The Task Force evaluation of tne ESL facility consisted of:
        o  Reviewing and evaluating records  and  documents from
           EPA Region V, IEPA, and ESL.
        o  Conducting an on-site  facility  inspection  from March
           16 through March 20, 1987.
        o  Evaluating the off-site contractor  laboratories used
           by ESL.
        o  Determining water  level  elevations  and  total  depths
           in selected wells.
        o  Sampling and subsequent analysis of  ground water from
           selected monitoring wells.
RECORDS /DQCuT     REVIEW AND EVALUATION
Before conducting  the on-site inspection, Task  Force personnel
reviewed  records  and  documents  from  EPA  Region V and  IEPA
offices, compiled by an EPA contractor.   Additional IEPA records
were obtained by Task Force personnel after the inspection.   On-
site  facility  records  were  reviewed"  to  verify  information
currently  in  government  files   and   supplement  government
information where  necessary.   Selected documents  requiring in-
depth  evaluation  were  copied  by  the Task  Force during  the
inspection.    Records  were  reviewed   to   evaluate  facility
operations, identify locations and construction details of waste
management units and monitoring wells, and evaluate ground-water
monitoring activities.

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                              18
Specific documents  and records reviewed and  evaluated  included
the facility ground-water sampling and analysis plan,  an outline
of  the  ground-water  quality  assessment   program,   analytical
results   from  past   ground-water   sampling,   monitoring  well
construction  data  and  logs,   site  geologic   reports,  site
operations plans, facility permits,  waste management  unit design
and operation reports, and operating records showing  the general
types and quantities  of  wastes disposed of at  the facility and
the i r loc at ions.

FACILITY INSPECTION

The ESL  facility inspection,  conducted in March  1987,  involved
identifying waste management units (past and present); identify-
ing  and assessing  waste  management  operations  and  pollution
control practices;  and verifying  the locations,  procedures, and
operation of the ground-water monitoring system.

Task  Force  personnel interviewed   company  representatives  to
identify records and  documents  of interest,  discuss  the content
of  the  documents,  and  obtain  information  on   (1)  facility
operations  (past  and  present);  (2)  site  hydrogeology;   (3)
ground-water  monitoring  system rationale;  and (4)  the ground-
water sampling and analysis plan.

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                              19
LABORATORY EVALUATION
The  off-site contractor  laboratories  handling most  of  ESL's
ground-water samples  were evaluated regarding  their  respective
responsibilities  under  the  ESL   ground-water   sampling  and
analysis plan.   Analytical equipment, methods, quality assurance
procedures,  and  documentation  were   examined  for   adequacy.
Laboratory  records  were  inspected  for completeness,  accuracy,
and compliance with state and federal requirements.  The ability
of  the  laboratories  to  produce quality  data for  the  required
analyses  also  was  evaluated.    A  detailed  discussion of this
evaluation is presented in the "Sample Analysis and Data Quality
Evaluation" section.
WATER LEVEL AND WELL DEPTH
Water level measurements  were  made by WMI's sampling contractor
in 44 of the  46  monitoring  network wells  (wells G-139 and G-140
reportedly  were  inoperable)   on  the  first   full  day  of  the
inspection  before the  wells  were purged  for  sampling.    The
measurements were made at the request of Task Force personnel to
evaluate the  facility's procedures.   Depth  to the water surface
was  measured using  an  electric water  level  indicator  (Slope
Indicator) .   The water  level  indicator consisted of a reel with
a control panel, cable, and sensor.  The cable, which was marked
in 1-foot increments, connected the control panel to the sensor.
When the water level sensor made contact with the water surface ,

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                              20

an  indicator  light and  buzzer  on  the control  panel were  ac-

tivated.  Duplicate measurements  were made at several  wells to

verify  the  reproducibility of  the results.   Additional  water

level measurements were made on  the wells sampled before purging

and, at a few wells, before sampling.   Water  Level measurements

for wells sampled during the inspection are  presented  in Table

1.   Table 6  lists the water level  measurements  for all  wells


measured at the time of the inspection.




Because a Well  Wizard^R^a had  been  installed  on  some  wells,

total  depth  measurements  could  not   be  made on those  wells.

During  the   inspection,  well-depth  measurements  were  made  by

WMI's  contractor  on eight wells,  at  the request  of Task Force


personnel,   for   verifying  construction   records.     Facility


personnel stated  that, on  an annual  basis,  WMI  removes  the Well

Wizards and  measures  the  well  depths.   WMI  provided  the data

from the most recent measuring event (January 6,  1987).




GROUND-WATER SAMPLING AND ANALYSIS




During  the  inspection,  Task  Force personnel collected samples
                                            *
for analysis  from 26 .ground-water monitoring  wells  (see Table  l

and  Figure  3)   to  determine  if  the  ground  water  contains

hazardous waste  constituents or  other  indicators of possible

a  Well Wizard  is a  registered  trademark and  will  be  shown
hereafter without  the  (R).

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G112
G113
G11S
G117
G150
G119
G118
G128
G14B
G149
 PATE,
03/17/67
03/17/87
03/17/87
03/17/87
03/17/87
03/17/87
03/17/87
03/18/87
03/18/87
03/18/87
21
TABLE 1
TASK FORCE SAMPLE COLLECTION DESCRIPTION
(Page 1 of 3)
PURGE
Depth**
Jim; yo Water
0910- 23.0
1010
0932- 31.5
1032
1117- 34.2
1217
1320- 33.9
1339
1310- 33.7
1400
1432- 31.3
1452
1450- 34.1
1538
0905- 33.6
0955
0912- 27.8
1006
1042- 29.2
1120
purae Vpl * Remarks***
30 Dedicated well wizard punp;
water did not change during
purging
26 Dedicated well wizard punp;
water clear
30 Dedicated well ulxard pump;
water Initially reddish yellow
but cleared after first 5 gallons
14 PVC bsller; water dark brown
and very cloudy
16.5 Dedicated well wizard pump
10 Dedicated well wizard pump;
water Initially surky, but
cleared
16.4 Dedicated well wizard punp
water clear
12.5 Dedicated well wizard punp;
water Initially cloudy and turbid,
then cleared
24 Dedicated well wizard pump,
water Initially cloudy and turbid,
then cleared
17 Dedicated well wizard pump
1020-
1040
1033-
1046
1217-
1233
1343-
1418
1400-
1418
1457-
1510
1540-
1602
1000-
1110
1008-
1022
1120-
1142
SAMPLING
Method
Dedicated
well wizard
pump
Dedicated
well wizard
Dedicated well
wizard punp
PVC bailer
Dedicated well
wizard
Dedicated well
wizard
Dedicated well
wizard
Dedicated well
. wizard pump
Dedicated well
wizard pump
Dedicated well
wizard pump
Remarks***
Company purged 54 gallons
before sampling well 1150-1225
Company started sampling after
9 gallons purged, ESL sampled
0954-1017
Company did not sample this
well
Company did not sample this
well; turbidity exceeded meter
upper bounds
Company did not sample this
well
Company did not sample this
well
Company did not samp Is this
well
Company took split samples; well
wizard malfunctioned 1024-1032
Company started sampling after
12.5 gallons purged, sampled
0940
Company alternated sampling
with Task force

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HOI       *!
6129      03/18/87
C120      03/18/87
C130      03/18/87
C123      03/18/87
G131      03/18/87
GT12      03/18/87
GT14      03/18/87
GUI      03/19/87
22
TABLE 1
TASK FORCE SAMPLE COUECTIOM DESCRIPTION
(Pagt 2 of 3)
PUBCE
lias
IKS*
1210
1245-
1300
1330-
U04
1415-
1442
1522-
1555
1550-
155S
1615-
IMS
0912-
1107
1610-
1615
Depth"
Jo Wafer furae Vol . Remark****
3S.5 12 Dedicated well uliard punp;
water Initially aurky, but
cleared
32.1 12 Dedicated well Miiard punp;
water Initially yellowish, then
cleared
36.7 1$ Dedicated well wiiard puap;
water Initially aurky, then
cleared tone
30.2 12.S Dedicated well wiiard puMp;
water Initially reddish and
turbid, then yellowish
37.4 14.J Dedicated well wlsard punp;
water very clear
19.4 4.8 laller. balled to dryness
21 PVC Uller, bailed to dryness,
water turbid and sandy
30.0 20 Dedicated welt wiiard punp;
water Initially surky, then
cleared
Ila*
1213-
125S
1310*
1323
1404-
1435
1445-
1509 .
1610-
1o32
0935-
0945
0905-
0920
1620-
1636
SAMPLING
Method
Dedicated well
wiiard punp
Dedicated well
wizard punp
Dedicated well
wiiard puap
Dedicated well
wiiard pi*p
Dedicated well
uliard punp
PVC boiler
PVC bailer
Teflon
bailer
iwrks*
Company took VOA samplea
after 11 gallons purged, then
took splits for rest of samples
Company did not sample this
well
Company took VOA simples
after 12.5 gallons purged, then
took splits for rest of samples
Company alternated sampling
with Talk Force
Company took split samples
Company did not take samples
Company did not teke samples
Company started sanpltng In the
morning and finished In the
afternoon

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0132
C134
C124
C13S
6125
C137
PATE
eWwUlt

03/19/87



03/19/87


03/19/87


03/19/87


03/19/87


03/19/87




03/20/87

23
TABLE 1
TASK FORCE SAMPLE COLLECTION DESCRIPTION
(Page 3 of 3)
PURGE
Depth**
Time 19 Wstef
0938- 33.8
1017


1100- 34.2
1136

1140- 30.2
1200

1240- 34.3
1314

1350- 30.S
1418

1356- 32.8
1450



0850- 27.9
0930

furae Vol.* Remarks***
16.5 Dedicated well wizard punp;
water Initially murky, then
cleared

13.8 Dedicated well wizard punp;
water milky with white
precipitate, Initial pH  12
12.S Dedlceted well wizard punp;
water Initially yellowish, but
then cleared
16 Dedicated well wizard punp.
water Inltlelly murky, but then
cleared
IS Dedicated well wizard punp;
water Initially yellowish and
turbid, then cleared
16.8 Dedicated well wizard punp;
water murky then clearing



6.7


list
1017-
1026


1136-
1215

1205-
1222

1314-
1333

1418-
1438

U51-
1505



0955*
1015
A |
SAMPLING
.
Method
Dedicated well
wizard puap


Dedicated well
wizard puap

Dedicated well
wizard punp

Dedicated well
wizard punp

Dedicated well
wizard punp

Dedlceted well
wizard punp






Remarks***
Company took VOA samples
after IS gallona purged, only
took splits for nitrate and
sulphide
Company started sampling after
18 gel Ions purged, only took
splits for nitrate and sulphide
Company took split samples


Company took VOA samples
after 14.5 gallona purged, then
took splits for rest of samples
Company took split samples


Company started sampling after
12.5 gallona purged 1420-1450.
water had pungent odor, water
became milky during Task Force
sampling
Company also sampled this well

G144
*     Indicates  volune (In gallons) purged before Tesk Force personnel begen sampling.  Volume of weter purged prior to company sampling (if different) is recorded
      in the remarks column.

'    Depth  is measured In feet  from the top of the casing to the water surface.

**   The remarks are from Task  Force field notebook observations.

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                    24
                 FIGURE 3
WELLS SAMPLED DURING TASK FORCE INSPECTION

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                               25
contamination.  No surface water or leachate samples were taken.
The sampling  results  were used in evaluating  previous  company-
supplied data.  The wells selected for  sampling were those that
were more likely to show  the  impact  on  groundwater by the waste
management activities.    These  included wells that  monitor the
uppermost aquifer  and two wells  that  monitor the  glacial till
adjacent to waste  management  units.   The  facility analyzed for
40 CFR  Part  264 Appendix IX organic constituents  for  14 of the
26 wells  the Task Force  sampled  (see  Table  1).   Samples were
collected according to the following  procedures.

WMI's contractor:
        o  Determined the depth to water using a Slope Indicator
           water level meter.
        o  Calculated the height of the water column from depth-
           to-water  measurement  and  total  well  depth  (from
           construction records).
        o  Calculated  the volume  of  water  in  the  casing  by
           multiplying the height  of  the  water column (in feet)
           by a conversion  factor  (gallons per foot  of  casing)
           to determine  the  amount of  water  to be purged from
           the well  before  the  facility's samples were  taken.
           The Task  Force calculated  the volume  to  be  purged
           before  its  samples  were  taken  using  the  method
           described in the following section on purging.
        o  Purged  the  number  of well  volumes in  the well  as
           indicated in Table 1 before samples were taken.

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                               26

EPA's contractor:
        o  Monitored the wellhead  for  chemical  vapors (Photovac
           Tip(R)a) and  radiation  as  soon as the  inner  protec-
           tive cap  was  opened and   at  intervals  during  the
           sampling.

        o  Collected  sample  aliquots  for  field  measurements
           (water  temperature,  pH,  specific  conductance  and
           turbidity) and filled sample containers  in the order
           shown  in Table  2.   Sample containers  were  filled
           directly from the bailer or pump discharge line.

        o  Placed the samples in an insulated container contain-
           ing ice (ice chest), and shipped the samples to   the
           laboratories daily under appropriate chain-of-
           custody regulations.
Purging



Task Force personnel calculated the volume of water to be purged

from each well using the volume of  the  sandpack  plus the volume

of the water  in  the casing above the sandpack.   In  some wells,

purge volumes were  less than the customary  three well volumes.

In the wells  that WMI elected to  sample,  WMI sampled only after

three full casing volumes  had been  removed.   This difference in

purge  volume  calculation   accounted   for   the   variations  in

sampling start time shown Table  1.   The wells  screened in the

glacial till  (GT-series) were purged to dryness the day prior to

sampling.
a   Photovac Tip  is  a  registered trademark  and will be  shown
hereafter without the *R).

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                               27
During the  site  reconnaissance,  WMI personnel were  informed by
the Task  Force team, that  it would be their  responsibility to
properly dispose of  the purge water.   Purge  water from any well
showing  strong evidence  of  contamination was  supposed  to  be
containerized  and  treated.   At the time of  the  inspection, WMI
had made  no provisions to   handle the purge water  and claimed
that  the   Task  Force  members   were   the  generators  of  the
"wastewater."   WMI  made  the decision  that  the ground  water
showed no  strong  evidence of contamination  and  disposed of the
purge water  on the ground as per  the  sampling plan  followed at
the facility.

Sample Collectionr Handling and Preservation

During the Task Force inspection, samples were collected from 26
wells using several different methods including  dedicated and
nondedicated  bailers  and  dedicated  submersible  bladder-type
(Well Wizard)  pumps  (see  Table 1).  A nondedicated  bailer made
of Teflon(R)a  was  used at  Well  G-141 after the  dedicated Well
Wizard pump malfunctioned.   In  the wells screened  in glacial
till (GT-series)  and Well G-117,  dedicated PVC bailers were used
for purging  and  sampling.   For the rest of  the  G-series wells,
dedicated Well Wizard pumps were  used for purging and sampling.
a  Teflon  is a registered  trademark and will be  shown hereafter
     without the **'.

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                               28
Representatives  of  the  EPA sampling  contractor monitored  the
open wellhead  for  chemical vapors as soon as  the  inner protec-
tive cap was removed and prior to  sampling.   The EPA contractor
also took  field measurement  of pH,  specific conductance,  and
temperature  of  the  ground water before,  during,  and  after
purging.  Field  measurements were  also  performed on some of the
retrieved samples.   These  field  measurements are  presented in
Appendix A.

The ESL  facility also  collected samples from  some  of  the wells
sampled by the Task Force.  However, because  of differences in
purge volume calculations  and sampling procedures,  the samples
were  not  usually  considered  to  be  splits  of  the  samples
collected by  the  Task  Force.    The  facility  representatives
filtered all  of  their samples  for inorganic analyses  at  the
wellhead.  The Task Force  took filtered and  unfiltered samples.
The  filtered  samples  were for metals  analyses.   In  addition,
metals, TOC,  phenols,  cyanide,  nitrate,  and ammonia samples were
preserved  (see  Table   2).    All  filtering  and preserving  of
samples were done at a central location.  Duplicate samples were
taken at two of the wells  (G-117  and  G-129).    Trip blanks and
field  blanks   samples  were  also   taken.   The  sample  analyses
results are contained in Appendix A.

At the end of each day, the samples were packaged in coolers and
shipped to the EPA contract laboratories according to applicable

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                                         29
                                       TM3LE 2
                                   QF SfifLE OCHU3CTICN
                          ki 11*1-1 je TXFE AND PRESERVATIVE USD
          Parameter
Bottle
Preservative*
 1.  Volatile organic analysis CVCA)
 2.  Purgeable organic carbon (POC)
 3.  Purgeable organic halogens (POX)
 4.  Extractable organics

 5.  Pesticide/herbicide
 6.  Dioxiri
 7.  Total metals
 8.  Dissolved metals
 9.  Total organic carbon (TOG)
10.  Total organic halogens (TGK)
11.  Phenols
12.  Cyanide
13.  Anions
14.  Sulfate/chloride/fluoride
15.  Nitrate/anroonia 	
2 40-ml VO\ vials
1 40-ml VCA vial
1 40-ml VCA vial
4 or 6 1-L. amber
glass
2 1-L. amber glass
2 1-L. amber glass
1 1-L. plastic
1 1-L. plastic
1 50-ml glass
1 1-L. amber glass
1 1-L. plastic
1 1-L. plastic
1 1-L. plastic
1 1-L. plastic
1 1-L. Dlastic
HN03 to pH <2
HN03 to pH <2
H2SO4 to pH <2

H2SO4 to pH <2
NaOH to pH >10
H2SO1 to PH <2
*A11 samples were iced to 4C after collection and during shipment to the laboratory

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                              30
Department of Transportation regulations (40 CFR Parts 171-177).
The aqueous  samples  from  the monitoring wells  were considered
"environmental"  for  shipping purposes.    A  signed  chain-of-
custody  form,  designating the  analytical  requirements,  accom-
panied each  sample.    This  form also   indicated  the location,
date  and  time  of  sampling,  sample  size  and  preservatives,
whether the  sample was  filtered, and the  numbers of the custody
seals.

Samples were analyzed by the EPA contractor laboratories for the
parameter groups shown in Table 2.

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                               31
        FACILITY  OPERATIONS AND WASTE MANAGEMENT UNITS

FACILITY OPERATIONS

WMI acquired the ESL facility in 1973.   There is little informa-
tion available concerning the early landfilling practices at the
site.   The  facility  operated five  pre-RCRA waste  management
units,  four  surface  impoundments  (Ponds 1  through  4)  and  a
landfarm,  which were used for storage and disposal of industrial
and municipal sludges prior to 1980.  RCRA hazardous wastes were
disposed of  in  10 trenches,  and  industrial and municipal wastes
were  placed  in a co-disposal landfill.   Other  RCRA-regulated
waste management  units  include  a  container  storage area,  two
surface impoundments  (Ponds  5  and 6)  used for containment  of
runoff from  the container storage  area,  and  a decant facility.
The ESL facility  has  not received  wastes from off-site sources
since Spring 1984.  Some materials  generated from the decommis-
sioning and  closure of  on-site  units  have been disposed  of  in
the landfill since  1984.  The facility  was inactive at the time
of the Task  Force inspection.  Table 3  summarizes the  types  of
hazardous wastes that were accepted at the ESL facility.

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                              32
                            TABLE 3
            HAZARDOUS WASTE STREAMS ACCEPTED BY ESL
                (by EPA Hazardous Waste Number)
D001
D002
D003
D004
D005
D006
D007
D008
D009
D010

F001
F002
F003
F004
F005
F006
F007
F009
F012
F019

K016
K048
K049
K050
K051
K052
K061
K071
K080
K086
K094
U002
U008
U013
U028
U031
U043
U044
U057
U070
U072
U080
U112
U122
U131
U147
U154
U159
U171
U188
U190
U210
U220
U223
U226
U233
U238
U239
U252
POOS
P015
P106
P120

WMI submitted a RCRA Part  B  permit  application to EPA on August
29, 1983,  and  has since received several  notices of deficiency
(NOD)  from EPA and IEPA  regarding its  application for ESL.  WMI
has submitted  revisions  to  EPA  and  IEPA of  its RCRA  Part B
permit application in response to the NODs.

WASTE MANAGEMENT UNITS
Waste  handling units  and operations  at  ESL were  evaluated to
identify possible sources and pathways for waste constituents to
enter  the  ground  water.   The ESL facility has handled hazardous
waste  as  defined  in  40 CFR *261 and  35  IAC 721  and regulated
under  RCRA and IAC regulations.

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                               33
ESL  has  used   the   following  RCRA-regulated  units  for  the
treatment, storage, and/or disposal of hazardous waste:

        o  Co-disposal landfill
        o  Drum disposal trenches
        o  Container storage area
        o  Decant facility
        o  Surface impoundments (Ponds 5 and 6)

The  facility also  contains several  pre-RCRA  waste  management
units consisting of:

        o  Four surface impoundments (Ponds 1 through 4)
        o  A landfarm

All units have been  inactive since the Spring  of  1984.   Use of
the surface  impoundments  (Ponds 1  through 4)  and  the landfarm
was  discontinued  in  1979.     WMI  reported   that  the  surface
impoundments  (Ponds  1 through 4)   were  cleaned  in 1980.   .The
container storage  area  and decant  facility  were  used  in the
early 1980s but have since been decommissioned.
                           
Figure  4  shows  the locations  of   current and  past  treatment,
storage,  and disposal facilities.   A  discussion of  the waste
management units at the ESL facility follows.

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                          34
                      FIGURE 4
LOCATION OF CURRENT AND PAST WASTE MANAGEMENT UNITS
          ENVIRONMENTAL SANITARY LANDFILL

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                               35
RCRA-Reaulated Waste Management Units

Co-Disposal Landfill

The  co-disposal landfill  has  not been  used  for disposal  of
hazardous waste from off-site  sources  since  early 1984.   It has
accepted some internally generated waste since then, such as the
material removed  from  the container  storage area.   This  clay-
lined unit  has  been used  for the disposal  of  municipal refuse
and  industrial  bulk waste.   A  preliminary EPA  report indicates
that several  existing  trenches and ponds may be  covered by the
co-disposal mound (U.S. EPA, 1985).  The CERCLA 103 notification
identified  organics,  inorganics,  solvents,  pesticides,  heavy
metals,  bases,  municipal  waste,   and  paint  and  oil wastes  as
being  disposed of   at ESL's  co-disposal landfill.    Table  4
provides a  summary  of the  wastes  received by  the ESL  facility
for  disposal  in the co-disposal landfill and the drum  disposal
trenches during its last 3 operating years.

WMI claimed that co-disposal landfill was constructed as a clay-
lined  disposal  unit.    Municipal  refuse and  bulk  industrial
wastes were disposed of at the co-disposal landfill by spreading
them uniformly and compacting them an a daily basis.

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                                   36
                        *

                               TABLE 4

                     QUANTITY OF WASTES RECEIVED

        AT ESL CO-DISPOSAL LANDFILL AND DRUM DISPOSAL TRENCHES
     (By Relative Percent Of Total Volume Of Waste Managed)
                        1991
               198?
D001
DO 02
15004 through DO 11
F001 through F005
F006
F0072
F0172
K061
E094 
62
IS
2S
85S1
2S
OS
IS
OS
IS
42
12
76S1
6S
6S
IS
OS
4S
IS
4S
IS
40S1
6S
43S
OS
OS
2S
IS
Approximate Volume
  Of Waste Received
  (Total/Tons/Year)
92,000
60,000
17,000
NOTE:     While other  F, K,   D,  and  P wastes were accepted into
          Areas 1 and  2,  the volumes  of these  individual  waste
          types are  less than  1/2S of the total volume  of  waste
          accepted in  a  given year.  For brevity and because  these
          wastes account  for a  very small volume, they have been
          omitted from this Table.   The percentages  in the  Table
          may not  equal 100S because of this omission and due  to
          rounding.


1    A substantial portion of this percentage is from  a  one-time
     clean-up where soil was  contaminated with this waste code.

2    This waste  code  has subsequently been dropped from  the RCRA
     list.
   Source:   Waste Management of Illinois, Inc., 1988. Closure Plan for ESL, received

           by U.S. Region V, February 26,  1988.

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                               37
The liner for the co-disposal landfill was constructed of native
clay.   WMI  claimed that  the naturally  occurring clay  of the
area has  a  hydraulic  conductivity ranging  from  1 to  8  x 10~8
cm/sec.   WMI states that  a  base  of at least  10  feet thick was
maintained  in  the landfill  area.   WMI has  also  indicated that
this unit has  a  cover  consisting of a compacted fine-textured
soil layer  that is  at  least  2.5  feet  thick.   This soil was also
claimed by  WMI to have  a in  situ hydraulic conductivity of 10~7
cm/sec or less. The clay layer was then overlain  by 6 inches of
topsoil  and  seeded  with shallow-rooted grasses  for  erosion
control.

A gas  venting  system was  installed in 1986  consisting of three
vents  located at  the  northwest corner, southwest  corner,  and on
the south side.   There  is a  leachate collection  system that is
contiguous with the gas venting system.

Drum Disposal Trenches

This  disposal  area  consists   of  10   recompacted  clay-lined
trenches.    The trenches  are approximately  15  feet deep.   The
trenches were used  for  the disposal of RCRA-regulated hazardous
wastes  (all RCRA  wastes with  few exceptions; see Tables  3 and
4), that  were  either  "solidified" or in drums.    The trenches
were filled with hazardous waste to approximately grade

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                              38
elevations.   Subsequently,  three trenches  on  the west  side  of
the main  haul  road were  covered by  the  co-disposal  landfill
operation.

WMI has stated that the liners for the trenches were constructed
with a native clay layer with a minimum  thickness  of  ten feet.
The trenches  have  a leachate  collection system that consists  of
PVC pipes beneath  each trench,  installed  in a  gravel base.   WMI
has stated that these trenches were covered by at least 2.5 feet
of recompacted  clay,  which were then  overlain with topsoil and
seeded with shallow rooted grasses.

Container Storage Area

From  late  1981  until  late  1984,  ESL  stored  containers  of
hazardous  wastes   in  an  open air,  clay-lined  area.    The  unit
measures  approximately 330  feet  by 200 feet with a very gradual
slope to  the  northeast corner.   The storage area is surrounded
by a  2-   to 5-foot-high  clay  berm.  WMI  stated that containers
were stored on pallets to elevate them above the soil.

In  1981,  U.S.  EPA  approved  an  increase in  interim  status
capacity  that allowed ESL to  store  up  to 110,000  gallons  of
hazardous  wastes   in  containers.   Although  the current  interim
status  container   storage capacity   is  275,000  gallons,  no
containers are currently stored at ESL.

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                               39
ESL  has  indicated  that most  (about  60  percent)  of the  con-
tainerized wastes managed at this unit were considered hazardous
due  to  the  characteristic of  ignitability  (DOOl).   About  20
percent of the wastes handled at this unit were characterized as
hazardous due to EP toxic metals (D004 through D011), especially
chromium and lead.   Wastes  considered  hazardous  due  to  cor-
rosivity (D002)  comprise  about 3 percent  of  the wastes  handled
at the unit.   Wastes from  nonspecific  sources,  especially F001
through F005, comprised about  16  percent  of the wastes managed,
and  wastes  from ink  formulation  (K086)  comprised  1  percent  of
the  containerized  wastes.   Several  additional  listed hazardous
wastes comprised less  than 1 percent  of  the  total  volume  of
wastes received  at  the container storage  facility.   "WMI stated
that no  reactive wastes (D003) were  recorded as being accepted
at this unit.

In  late  1984  and  early   1985,  soil  was excavated from  the
container storage  area.   This  material was  disposed  of in the
RCRA landfill.   Soil samples were taken  in accordance with the
interim status closure plan.

Decant Facility

ESL  operated  a pilot decant facility from late 1981 until 1983,
while a  permanent decant  facility was being constructed.   The
permanent decant facility ceased operations in 1984.  WMI stated

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                              40
that both  the pilot  decant facility  and the permanent  decant
facility   were  designed  to  provide  physical   treatment  of
containerized wastes by a combination of the following steps:
        o  Removal of liquids from drums
        o  Liquid phase  separation,  for subsequent treatment,
           recovery, or disposal of the liquid phases
        o  Stabilization of sludge and selected liquids
The final products of both decant facilities were liquids, which
were sent  off-site  for  recovery, or  stabilized  wastes,  which
were disposed of  in  the co-disposal  landfill  on-site.    WMI
indicated the stabilization  process  used  kiln dust or a similar
fixing reagent.

The pilot decant  facility was located  in the container storage
area.   The base  of this  area  was  compacted  clay.    The pilot
decant facility consisted of storage tanks, treatment tanks, and
auxiliary equipment  (mixer,  conveyors,  pumps, and piping).   in
1983, the  pilot plant  was disassembled.    WMI stated  that the
tanks and  other  equipment  were  either  used in  the permanent
decant facility,  disposed of in the RCRA landfill at ESL", sent
to another WMI hazardous waste facility to be used, or stored at
ESL for future disposition or use.  WMI stated that in late 1984
or  early  1985, soil was  excavated  from  the  container storage
area, including the area underlying the  pilot decant facility,
and that soil samples  were taken in accordance with the interim
status closure plan.

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                               41
In 1983, the permanent decant facility was constructed and began
operating.   This  facility was located  in  a 50 foot by  50 foot
metal building  with a concrete  floor.   A  concrete  diked area,
located outside the building  along  the south wall, housed two
large storage tanks.  All other storage and treatment tanks were
inside  the  building.    Containers  were  transported  from  the
storage area and placed  on  a conveyor system that moved through
the decant facility.   The decanted liquid was either solidified
and  disposed of on-site or  shipped off-site for  supplemental
fuel,  recovery,  or  incineration.    This facility operated for
approximately 1 year.

The  pilot and  permanent decant  facilities  received the same
wastes  that were   listed as  being  handled  at  the  container
storage  area.    The  wastes  received have  been  summarized  as
approximately 60 percent ignitable wastes (DOOl), 20 percent EP
toxic  metals waste (D004  through  D011),  3  percent  corrosive
wastes, 16  percent wastes from  nonspecific sources  (especially
F001 through F005), and  1 percent other listed hazardous wastes.
In  July 1985,  most of  the  tanks  and  other  equipment  in the
permanent decant facility were dismantled.  WMI stated that most
of  the  equipment  was decontaminated and  shipped  to another WMI
facility to  be  used for hazardous waste storage  and treatment.
Some piping and equipment were disposed of in the interim status

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                              42
landfill at ESL.  WMI stated that the  floor  of  the building was
sandblasted, and  the spent  sand was  also  disposed  of  in  the
landfill.   One  6,000-gallon  tank remains  in the  concrete diked
area south of the decant building.

Surface Impoundments

The  RCRA-regulated  surface  impoundments  are  Ponds   5  and  6.
These  ponds were  constructed  in  the  late  1970s  using  native
clay.   WMI  stated that the sides  and bottoms of  the  ponds are
surrounded by 20 feet of clay with a hydraulic conductivity less
than 1 x  10~7 cm/sec.   Pond 5 has  dimensions of 170 feet by 300
feet by 13 feet deep.  The internal sides have a slope of 3 to l
(horizontal  to  vertical) with  a minimum  freeboard of  2 feet.
Pond  5 has  a   capacity of approximately  3.3  million gallons.
Pond 6  has  dimensions  of 190  feet by  310  feet  by 13  feet deep.
Similar 3:1  internal side  slopes  and 2-foot  freeboard were used
in the construction of pond 6,  which has an approximate capacity
of 4 million gallons.

Ponds  5  and 6 were used to  collect  rainfall  and  stormwater
runoff  prior to  November  19,   1980.    In  1982,  the  ponds were
used to hold runoff  from the container handling areas.  ESL has
an NPDES  permit which  allows  it  to discharge this stormwater to
the  Des  Plaines River.   Ponds  5  and 6  served  as storage units
so that the water could be sampled before  it is discharged.

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                               43
In 1985, the ponds were drained and water, and soil samples were
taken.   Although the facility did. not  have  an approved interim
status  closure  plan  and  closure  of  these  units  were  not
certified, WMI  stated  that  an independent professional engineer
certified  the  procedures.   Very  little water remains  in these
ponds.

Trench 11

Trench 11  was  constructed with a compound synthetic liner that
was underlain  by an impermeable clay  base.   The  trench  was to
have been  used for the disposal of hazardous waste,  but  it has
never been used.   The  permit for this  unit  was  denied in April
1984.

Pre-RCRA Waste Management Units

Surface Impoundments

The pre-RCRA surface impoundments are  Ponds  1  through 4.   These
four clay-lined  impoundments  were  used to store  industrial and
municipal sludges  prior  to  land* treatment.   These impoundments
were used  from  1975  until 1979.   WMI  stated that  the  wastes
disposed  of  in the  impoundments were nonhazardous,  but  the
company has not  provided any  information to  document this fact.
The ponds were excavated in 1980.

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                               44
Two other impoundments  are  located  along  the southern border of
the disposal  facility.    These impoundments were  intended  for
disposal  of solid  waste,  but they  never  received any  waste
material.   They  now hold  rainwater  and runoff  from the  co-
disposal landfill.

Landfarm

The landfarm is  located east of the  "future disposal area"  and
has also been  identified  as the  "proposed expansion area."  Use
of  the  landfarm  was  discontinued  in  1979.    The  pre-RCRA
activities  involved the landfarming (spraying)  of municipal  and
industrial  sludges,  FCC  (fluid-cracking  catalyst)   fines,  API
oily  sludges,  water  and  residue  from the  ponds,  and  organic
liquids  (U.S.  EPA,  1985).   The  facility never  notified  EPA of
this  unit   in  any CERCLA 103  or solid waste  management  units
response.

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                              45
                       SITE HYDROGEOLOGY

Several investigations have been  conducted  by WMI's consultants
to define  the  hydrogeologic  setting of the ESL  facility.   This
section  incorporates information  obtained from two  geologic,
geotechnical,   and   hydrogeologic   evaluations   prepared  by
Woodward-Clyde  Consultants in  July  1982  and  July  1983,  and
boring  logs  from various  boring operations  at  ESL by  Testing
Services Corporation  and Woodward-Clyde Consultants.   Informa-
tion from  the  Illinois State Geologic  Survey,  circulars  460 and
505,  was  also consulted  to  provide  this discussion  of  the
geologic and hydrogeologic setting of the ESL  facility.

The ESL  site is located  in Will County, Illinois,  on  the  south
side of  the Des  Plaines River, south  of  Joliet.   The  surface
elevation of the site is,  on average,  100 feet above the normal
pool  elevation  (506  feet)  of the  Des  Plaines  River.     No
development  on the  site  lies  within  the  flood plain  of  the
river or any of its  tributaries.

The facility is situated in the central portion of  the  Central
               
Lowland physiographic province.   The Central Lowland province is
divided into two sections, the  Great Lakes  section  and the Till
Plains section, based on  the surficial features which resulted

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                              46
from the  action of  glacial  ice  and meltwater.   The  boundary
between the  two sections passes  to  the northwest of  the site.
The ESL  site is situated in the  Till  Plain section,  which  is
characterized by subdued topography,  consisting of few lakes and
older  Wisconsinian  till plains   that  have  been  modified  by
erosion.

The  Sandwich  Fault  Zone  is  located  approximately  3  miles
southwest of the ESL site.  The fault  zone  consists  of a narrow
belt of high angle  faults, generally 1/2 to 2 miles wide.  Along
most of the  zone,  the  faults are upthrown  on  the southern side
of the fault.  At the southeastern end of the fault zone, in the
vicinity of  the ESL facility,  the  fault 'is downthrown  to the
south.    At the  southeastern  end of  the  fault zone,  the total
vertical displacement across the zone is approximately 150 feet.
The  faulting  affects   all  of  the  bedrock  units  below  the
Pleistocene deposits.   The faulting  is believed to  be contem-
poraneous   with  other   Late  Paleozoic  . deformational  events
affecting  the  eastern  craton  on North  America.   "Earthquake
epicenters within the area in historic time show no relationship
to the Sandwich Fault Zone" (Kolata,  et al,  1978).

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                               47
STRATIGRAPHY

The  sequence  of  sedimentary  rock  units  and  unconsolidated
sediments present in the region of the ESL site is summarized in
Figure 5.   The  generalized stratigraphic  column shown in Figure
5  indicates the units  present in  the  greater Chicago  area in
northeastern Illinois.   The stippling indicates  units  that are
not present at  the ESL  site.   The stratigraphic sequence at the
site  consists  of   approximately  50  feet  of  unconsolidated
Pleistocene  sediments  underlain  by  more  than  1,500   feet  of
Silurian,  Ordovician,  and  Cambrian sedimentary  bedrock,  which
lies  unconformably  atop  the  Precambrian crystalline  basement
rocks.   Figure 6 shows  a  generalized  geologic  cross-section
through the sedimentary sequence underlying the ESL site that is
relatively flat lying and shows no structural deformation.

The Pleistocene deposits  consist of  an  upper  till  unit,  which
WMl's consultants  identified as  being  the Yorkviile Member of
the Wedron  Formation.   The  unit's  thickness varies  across the
site but,  on  average,  is at  least  20 feet thick  and  in places
is approximately  50  feet  thick.  This layer  overlies  a glacial
outwash unit, which  also varies  in thickness  across the site.
The glacial outwash is absent in the extreme northeast corner of
the site  and  reaches a  maximum thickness  of 20  feet  in the
extreme southeast corner of the site.  Under most of the

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                                     48

                                FIGURES
             GENERALIZED STRATIGRAPHIC COLUMN OF THE
                   GEOLOGY OF THE CHICAGO REGION
Source:   Willman, 1971, Illinois State Geological Survey Circular No. 460.

Note:     The stippling indicates units not present at the ESL site.

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                                    49
                                FIGURE 6
        GENERALIZED GEOLOGIC CROSS-SECTION OF THE ESL SITE
                                                  l  i  ii!   HI
Source:   Woodward-Clyde Consultants, 1982.  Geologic Gcotcchnical and
         Hydrogcologic Evaluation of Exposure Area to Chemical Waste
         Management, Inc., Joliet, Will County, Illinois, July 1982.

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                               50
hazardous  waste  management area,  the average thickness  of the
glacial outwash  is 5 feet.   In the  southeastern  corner  of the
site, a  second till unit  is  present below the  glacial outwash
and above the Silurian bedrock.

HYDRQGEOLOGIC UNITS

In  the  vicinity  of the   ESL facility,  the  WMI  consultants
identified  several major units,  which  are potential  aquifers.
These units are  the Pleistocene  age sand  and gravel  outwash
deposits  and the  fractured  surface of  the  Joliet  Formation,
immediately beneath the outwash deposits; two  transmissive zones
within the Silurian age dolomite sequence; and the stratigraphi-
cally lower bedrock aquifer,  which consists  of the  Ordovician
and Cambrian  age  carbonate and sandstone units.   Most  of the
water supply  wells  in  the vicinity of   the  ESL  facility  draw
water from  the Silurian  dolomite  formations.   WMI's consultants
noted  that,  although  the  Pleistocene   outwash  deposits  are
capable  of  providing water,   no  production  wells  from  this
aquifer were identified within a 2-mile  radius of the site.   The
City of Joliet, located less than 3 miles northeast of the site,
reportedly  draws  more than 2.2  million .gallons  per day  from
wells that  are completed in  the  glacial outwash  aquifer.   The
glacial outwash at that location,  however, occupies a preglacial
bedrock  valley  that,  according   to WMI  consultants,  is  not
hydraulically connected to the outwash beneath the ESL site.

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                              51
For  the  purpose  of  ground-water  monitoring,  the  uppermost
aquifer beneath the ESL  site has  been  identified as a composite
zone consisting of the glacial outwash aquifer  and the upper 10
to 20 feet of the underlying Silurian dolomite.

Monitored Composite Aquifer

The  glacial  outwash aquifer  consists  of  a  sand and  gravel
outwash deposit at or near the base of the Pleistocene units and
on top  of  the Silurian dolomite  bedrock.   It  is  overlain  by a
continuous  till  layer that acts  as  a  confining layer.   In the
southeast corner  of  the site, the dolomite slopes  away,  and a
second  till  layer  is   present   between   the   outwash  and  the
dolomite.   No active water supply wells within a  1-mile radius
of the  site are developed in the  glacial  outwash  aquifer (WCC,
1982).  WMI consultants  found evidence of  an abandoned hand dug
well, which was  developed in the  glacial  outwash  aquifer.   The
water level obtained from the monitoring  well  screened only in
the glacial outwash correlates with water levels of wells in the
Silurian dolomite.  Well pairs,  one screened in the dolomite and
the other in the glacial outwash, have equal water levels.  This
indicates   that  the  glacial  outwash  aquifer  and  the  water
contained in the uppermost portion  of the  Silurian  age Joliet
Formation are in relatively complete hydrologic contact.

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                              52
The water  contained in the  upper  10 to  20  feet of  the Joliet
Formation  is  located along  bedding planes,  solution cavities,
fissures,  and crevices.   This  zone of  the unit  is the  most
weathered and relatively more permeable.

Silurian Transmissive Zones

The Silurian  dolomite is  the uppermost bedrock  unit beneath the
Pleistocene glacial deposits.   Of  the   81  water  supply  wells
reported  in  the  Illinois State Water Survey records for  this
area  (within  a  2  mile  radius  and  south  of  the  Des  P-laines
River),   68  wells draw  their water  from various  zones  in the
Silurian dolomite.   The ground water in  the  dolomite occurs in
fissures,   joints,  bedding  planes,  solution  cavities,   and
crevices.  The water-yielding zones are  irregularly distributed
both vertically and horizontally.

WMI consultants  tentatively  identified  two  other  transmissive
zones, besides the  upper  10  to  20  feet of the Joliet Formation,
within the Silurian dolomite.  The  first is  located within the
Joliet  and Kankakee  Formations,   in the  units  that form the
contact  between  the formations.   The second transmissive  zone
was identified as being  in  the Edgewood  Formation,  which  is at
the base  of  the Silurian sequence  and just  above the Maquoketa

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                               53
Shale.    WMI's consultants  estimated  that these  transmissive
zones  lie approximately 100  and 200  feet  below the  ESL site,
respectively.

CambroOrdovician Aquifer System

The Cambro-Ordovician  aquifer  system consists of a sequence of
hydrologically interconnected  units  that  are separated from the
overlying  Silurian aquifer  by the  low  permeability  Maquoketa
Shale.   The  Cambro-Ordovician series consists of  sandstone and
dolomite  units  interbedded  with siltstones  and  shales;  the
series  is over  1,300  feet thick  in  the   region.    The water
bearing  units  which  form the  Cambro-Ordovician  aquifer  are the
Galena  and  Plattevilie  dolomite,  Glenwood   and  St.   Peter
sandstones,  Prairie   Chien  Group   sandstones   and  dolomites,
Eminence  and  Potosi  dolomite, Franconia  Formation,  and  Ironton
and  Galesville  Formation  sandstones.    The  principal  water-
yielding  units  are  the  Ironton,   Galesville,  and  St.  Peter
Formation sandstones (see Figure 5),  which provide 80 percent of
the total aquifer capacity.

GROUND-WATER FLOW DIRECTION AND RATES

The  uppermost aquifer  beneath  the  ESL site   is  a  composite
aquifer   consisting  of  the   hydraulically  connected  glacial
outwash  aquifer and  the upper 10 to 20 feet of the  underlying

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                              54
Silurian dolomite.  Figure 7 shows a contour map  of  the ground-
water surface.  This map  shows  that the  ground-water surface of
the uppermost aquifer slopes gradually to the  northwest, towards
the Des Plaines River.   WMI's consultants identified a southwest
to westerly flow component in the southwest portion of the site.
They also  identified a bedrock  valley south  of the  site which
influences this portion of the site.   WMl's consultants noted an
easterly flow component in the  southeastern portion  of the site
that may be a seasonal effect.   WMI's  consultants  noted that the
gradient  is  relatively flat  beneath   the  site,  and  pumping of
wells from  the  unit could  locally  change the direction  of the
gradient and the direction of ground-water flow.   As a result of
its inspection, the  Task  Force  noted  a northerly  flow component
in the ground water at the northern portion of the site.

Hydraulic  conductivity  measurements  were  made,   by  WMI's
consultants,  on  41  wells  (G-series   wells)   installed  in  the
uppermost  aquifer using  both variable head tests  and constant
head tests.  The hydraulic conductivities measured ranged from a
low of 2.6 x  10~6  cm/sec  (G-139)  to a high of 2.8 x 10~2 cm/sec
(G-136); most  of  the values fell  in  the range of  10~3 to  10~4
cm/sec.  Transmissivity values were then calculated for these 40
wells ranged  from a low  of  7.19 x 10~8 m2/sec  (G-139) to more
than 2.16  x 10~3  m2/sec  (G-136); values ranged from 2.88 x 10"
5 to more  than  1.44  x  10~4  m2/sec.  Table 5 shows the  hydraulic

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                               55
conductivity  and  transmissivity  values  for  all the  G-series
monitoring wells.

Available  information   on  the   stratigraphy,  potent iometric
surface wells screened  in the Silurian dolomite,  and the packer
(borehole  pump)   test  conducted  within  the  Silurian  dolomite
indicate  a   lack  of   significant   hydrologic  interconnection
between the  uppermost  aquifer and  the  lower  two  transmissive
zones  within the  Silurian dolomite.  Figure  7 shows  the  com-
parison of  the  water  level  contour  for wells  screen  in  the
uppermost  aquifer versus  a  composite  of wells  in  the  deeper
Silurian  dolomite transmissive zones.   The  comparison between
the  water level  contour  sets  indicates  that the composite  of
wells  in  the deeper  Silurian  dolomite  transmissive zones  are
tapping a different water supply than  the  uppermost  aquifer.
The  first transmissive   zone  is approximately  30   feet  thick
within the  Joliet  and  Kankakee dolomites.    This  transmissive
zone  is   separated  from   the  weathered  zone by  very  dense,
unfractured,  low  permeability  dolomite.   The lower  transmissive
zone  is  near the base  of the Edgewood Formation  and  is  ap-
proximately 20 to 30 feet thick.  The middle and lower transmis-
sive  zones  are   separated  by  dense,  shaly,   low  permeability
dolomite.     The  packer  (borehole   pump)  tests  confirmed  the
existence  of  the low hydraulically conductive zone of bedrock

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                                      56
                                  FIGURE 7

         COMPARISON OF WATER LEVELS IN UPPERMOST AQUIFER
               AND COMPOSITE DEEPER SILURIAN DOLOMITE
                            TRANSMISSIVE ZONES

%S...~-
                 $.66
                         WMK tow! contourt in ooiwin and too of OeotocK wntmtw ion*

                                                  Siiunan coiomn* nnumw iofv
                                 trom Tt> ES-1
                         wll. wu 0. f V* G. Jun 1983 w ****
Source:    Waste Management of Illinois, 1983. RCRA Part B Permit Application.
          Volume II - Groundwatcr Monitoring, September 1983 with revisions, July
          1985.

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                               57
beneath the  weathered and  fractured dolomite, which  separates the
uppermost aquifer from the  transmissive  zone deeper in the Silurian
dolomite.

The rate  of  ground-water flow in the uppermost  aquifer beneath the
site can  be  calculated from known or estimated aquifer characteris-
tics.   The gradient measured beneath the site ranged  from 0.004 to
0.007.    The  hydraulic  conductivity  of the uppermost  aquifer was
estimated in  the  range  of  10~3 to  10~4  cm/sec  (see Table 5).   The
effective porosity  was  estimated  to be between 20 to  25 percent.
Using these  parameters,  WMI consultants estimated  the ground-water
flow velocity to be in the range of 2 to 35 feet per year.

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                                               58
                                         TABLE 5

                    PUMPING TEST RESULTS FROM AQUIFER WELLS
                                       (Page 1 of 2)
Well No.1

G-lll
G-112
G-113
G-114

G-115
G-116
G-117
G-118

G-119
G-120
G-121
G-122

G-123
G-124
G-125
G-126

G-127
G-128
G-129
G-130

G-131
G-132
G-133
G-134

G-135
G-136
G-137
G-138

G-139
G-140
G-141
G-142

G-143
G-144
G-145
G-146
Type of*
  Teat

  VJL
  VJL
  VJL
  VJL

  CJL
  CJL
  VJL
  VJL

  CJL
  VJL
  V.H.
  CH.

  CH.
  CH.
  CH.
  CH.

  CH.
  VJL
  CH.
  CH.

  CH.
  CH.
  CH.
  VJL

  CH.
  CH.
  CH.
  CH.

  V.H.
  C.H.
  CH.
  CH.

  V.H.
  V.H.
  CH.
  CH.
 Hydraulic3
Conductivity
 Kh fem/aee>

 2.6 x 10-*
 9.0 x 10"*
 92 x 10-4
 7.6 x 10-*

 52 x 10-4
 7.8 x 10-4
 6.6 x 10-4
 1.1 x 10-3

 1 .5 x 10-3
 2.1 x 10-3
 3.7 x 10-4
 9.7 x 10-3

 22 x lO'3
 1 J x lO"3
 1.7 x 10-3
 5.83 x I0-s

 2J x 10-3
 9.3 x 10-4
 4.8 x 10-*
 4.8 x lO'3

 1.1 x 10-3
 2.0 x lO'3
 8.2 x lO'3
 1.7 x lO'3

 8.0 x 10-4
 2.8 x 10'J
 1.45 x lO'3
 6.1 x lO*3
                                                  Length of
                                              Screened Interval
 Z6 x
 2.4 x ID'3
 1.83 x  lO'3
 2.30 x  10-<

 3.6 x 10'
 8.3 x lO'5
 1.80 x  lO'4
 2.6 x lO*4
 5
 5
20
15

25
25
 5
15

15
15
15
10

20
15
20
20

20
20
20
20

20
20
20
 5

20
25
25
25

10
25
20
20

15
 5
30
20
  Calculated4
Transmissivity
  T fend/ft^

   27.2
     9.5
  389.7
  242.6

  273.6
  415.2
   70.5
  351.3

  483.0
  894.0
  118.5
 2059.4

  954.8
  409.4
  739.7
 1474.6

  975.6
  394.3
 2055.2
 2053.9

  456.3
  866.1
 3464.4
  178.9

  338.4
15,012.5
  770.7
 3251.6

     0.5
 1252.0
  770.0
   97.6

     1.16
     8.8
  114.6
  111.0

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                                             59

                                        TABLE 5

                    PUMPING TEST RESULTS FROM AQUIFER WELLS
                                       (Page 2 of 2)


                              Hydraulic3         Length of             Calculated4
               Type of*      Conductivity    Screened Interval        Transmissivity
Well No.1         Test         Kh /em/seel   	Uft)	      T
G-147            CH.          5.8 x IV4             20                 245.4
G-148            CH.          2.0 x 10-*             15                 626.7
G-149            V.H.          7.7 x 10-*              5                    8.16
G-150            V.H.          9.6 x 10-*              5                   10.13

G-151            CH.          7.5 x 10-*             15                2378.3
Notes:

(1)   See Figure 2 for monitoring well locations.  These wells were designed and installed to
     obtain ground-water level measurements and ground-water samples for water quality
     testing, not for the determination of the permeability and transmissivity of the screened
     interval of the well.  As such, the calculated result may not be indicative of actual in-
     situ values of  transmissivity and permeability. These quantities should be determined
     using test methods specifically designed for the purpose of measuring either permeability
     and/or transmissivity.  The accuracy of these results is judged to be within an order of
     magnitude of actual conditions, based on the limitations stated above.

(2)   V.H.  Variable head test. After achieving drawdown, the recovery or rise in water level
     was monitored over time.
     CH. - Constant head test. During pumping, a constant drawdown condition  was achieved.

(3)   T - Kh x L with units of gallons per day per foot of horizontal width of the geologic
     strata penetrated.  Kh was calculated based on  the C.H. and V.H. equations presented in
     Soil Mechanics (1968), by Lambe & Whitman, Pages 284 and 285, Case F.

     Where:
     Kh - calculated horizontal hydraulic conductivity (cm/sec)
     Kh - Ke was assumed for this calculation.

(4)   These transmissivity values were calculated from the screen lengths, not the  aquifer
     thickness, and therefore are low estimates.


Source:    Waste Management of Illinois, Inc., 1983.  RCRA Part B Permit Application.  Volume
          II- Groundwater Monitoring, September 1983 with  revisions, July 1985.

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                               60
         GROUND-WATER MONITORING DURING INTERIM STATUS

REGULATORY REQUIREMENT?

IEPA administers the RCRA interim status ground-water monitoring
regulations in  the  State of Illinois.   ESL's  RCRA ground-water
monitoring  system  from  December   1981  until  February  1984
consisted of wells P-l through P-8.   In March 1984, ESL received
a supplemental  operating permit  from IEPA to modify its ground-
water monitoring  program.   In April 1984,  an  expanded ground-
water monitoring  system was installed.   This system consists of
41  G-series  wells  (G-lll  through  G-151)  that  monitor  the
uppermost aquifer.  Five other wells were also  installed at this
time to monitor the glacial till above the uppermost aquifer.

ESL is an  interim status facility and has maintained an interim
status  ground-water  monitoring  program  since  November  1980.
IEPA was notified of significant changes in indicator parameters
for  the  P-series  wells  in  June  1983.    Well  P-l   showed  a
significant  decrease  in pH,  while  wells  P-l  through  P-6  all
showed  significant  increases  in  specific  conductance.    On
October  11,  1985,  the  facility received a compliance inquiry
letter  (CIL)  from IEPA for failing  to implement a ground-water
quality  assessment  plan  citing  35   IAC  725.193(d)(4)  (40  CFR
265.93(d)(4)).    On  March  5,  1986,  the facility  resolved  the
violation cited in the CIL.  On November 27, 1985, ESL  submitted

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                               61
statistics showing  that  seven of the new  G-series  wells failed
the  average  replicate  test,  as  shown  in the  results of  the
August  1985   sampling.    These  wells  are G-117  for  specific
conductance;  wells G-128, G-129, G-131,  G-137, and G-140 for pH;
and well  G-139  for specific conductance,  total  organic carbon,
and total organic halogens.

On June 12, 1986, U.S. EPA issued an administrative complaint to
ESL for  failing to supply information  required  to  complete the
RCRA  Part B  application.   On December  1, 1986, IEPA  sent the
facility  another CIL  for failing  to retest wells that indicated
a statistical change,  in violation of  35  IAC 725.193(c)(2) (40
CFR  265.93(c) (2)) ,  and  for  failing to  determine the  rate and
extent  of  migration  of  hazardous waste or  hazardous  waste
constituents,  in  violation  of  35  IAC 725.193(d)(4)   (40  CFR
265.93(d) (4)).   At the  time of the Task  Force  inspection, WMI
contended that  it  had completed  its assessment  program and has
returned to the detection monitoring phase.

GROUND-WATER SAMPLING AND ANALYSIS PLAN
The ESL facility uses two sampling and analysis plans.  One is a
site-specific plan titled "Specific Ground-Water Monitoring Plan
for ESL" dated November  1985.  The memo indicates that this plan
addresses  the  analytical methods,  parameters,  and  schedule  of
sampling  and preservation.  "  The  second  plan  is   titled  "WMI
Manual  for  Ground-Water  Sampling"  (revised  September  1986).

-------
                              62

This is a generalized document that addresses sampling procedur-

es.  A number of deficiencies were noted in these plans:

        o  Neither plan identified the procedures that would be
           used to check wells for immiscible layers such as low
           density (floaters) or high density (sinkers) con-
           taminants .

        o  Neither plan contains documentation of decontamina-
           tion procedures used to clean the cable for the
           water level indicator equipment.

        o  Neither plan contains the documentation as to the
           quality of water used to prepare blanks.  This
           information was requested and later supplied by the
           facility.  It should be included in the site-specific
           plan.

        o  Neither plan includes procedures for using the in-
           line filtering equipment of the Well Wizard pumps.
           Also needed is the procedure used to clean the
           filtering equipment between wells.

        o  The general plan "WMI Manual for Ground-Water Sam-
           pling" requires total organic carbon (TOO to be
           filtered.  This is an incorrect procedure that will
           bias results low.

        o  The site-specific plan stated that wells installed
           before 1984 used schedule 40 PVC pipe.  The boring
           logs for Well G-139,  which was installed in 1983,
           shows that schedule 80 pipe was installed.


The facility removed sampling equipment from 21 wells in January

1987, and measured  total depth of these wells.    The remaining

wells have not had their total depths checked since May 1985.
SAMPLE ANALYSIS AND DATA QUALITY EVALUATION



WMI uses  contract laboratories  to provide analyses  of ground-

water samples taken  at  the  ESL  facility.   The laboratories used

by  ESL are  Environmental  Testing and  Certification  (ETC)  of

-------
                               63
Edison, New  Jersey;  Gulf Coast Laboratories of University Park,
Illinois;  and Core  Laboratories  of  Casper,  Wyoming.    An  EPA
Region  V  team  visited  ETC  and  Gulf  Coast  Laboratories  to
evaluate the laboratories '  operating and  analytical procedures
and  documentation  system.    Data  for   Core Laboratories  were
provided by EPA Region VIII.
Inoranic
ESL contracts with  Gulf Coast Laboratories  to  perform analyses
for metals,  total organic  carbon,  total organic  halogens,  arid
indicator parameters.   The  laboratory analyzed  most metals (Ba,
Cd, Cr,  Fe,  Na,  Ag, Mn, etc.)  by inductively  coupled plasma-
atomic emission  spectroscopy.   Graphite  furnace  atomic absorp-
tion  is  used to  analyze for  arsenic,  lead, and  selenium,  and
cold vapor atomic absorption is used to analyze  for mercury.

The Task Force  laboratory  evaluation team  had the  following
comments, observations, recommendations and noted some deficien-
cies regarding Gulf Coast Laboratories.
        o  Comment:  The.laboratory  should  be  commended for the
           excellent documentation  of  graphite furnace  atomic
           absorption  problems  and   corrective  action  report
           forms.     The  analytical   corrective  action  report
           addressed the following problems:
                1.  Duplicate analysis not within  control
                   limits.
                2.  Low  spike recovery.

-------
                       64
        3. Correlation coefficient does  not  meet
           the acceptance criteria.

        4. Severe matrix interference present.

        5. Laboratory control sample/blank does not
           fall within control limits.

o  Comment:  An interference check sample is  analyzed to
   verify  inter  element   and  background   correction
   factors at  the  beginning and end  of  the  sample run.
   Also the  acceptance  criteria is consistent  with EPA
   Method 200.7.

o   Observation:   A  high standard and  internal quality
   control samples  are  analyzed  at  a  frequency  of  10
   percent to  determine instrument  drift.    The accep-
   tance  criteria  of  +  5  percent  of  the  expected
   values  or  within the  established  control  limits,
   whichever is  lower,  is  not observed  as mandatory by
   EPA Method 200.7 (ICP procedure).

   Recommendation:     The acceptance  criteria   of    5
   percent   of  the  expected  values   or   within  the
   established  control  limits,  whichever   is  lower,
   should be observed.

o   Observation:   An external quality control sample is
   used for  the  initial  verification  of the  calibration
   standards.  The acceptance criteria of  5 percent of
   the true  value  listed for the control sample is not
   observed as mandatory by EPA Method 2020.7.

   Recommendation:     The acceptance  criteria   of  +  5
   percent of the true value should be observed.

o  Observation:  The laboratory put a lot of  emphasis on
   the objective  to provide  a  measure of the  accuracy
   and precision  of analytical methods,  but failed  to
   emphasize continuing  assessment  of the accuracy and
   precision of data generated over time.

   Recommendation:    The  laboratory  should  maintain  a
   continuing  assessment of  the accuracy and precision
   of data generated over time.

o  Deficiency:   The laboratory does not field screen the
   ground-water/surface water  samples for the  presence
   of sulfide before analyzing for cyanide.

-------
                              65

           Recommendation:   Since the  sample holding time  for
           cyanide test procedure is only 24  hours  when sulfide
           is present, the laboratory  should  screen all cyanide
           samples in field with lead  acetate paper for sulfide
           and analyze the samples that are positive within 24
           hours.     Please  refer  to  40  CFR Part  136,  dated
           October 26, 1984,  for further instructions.

        o  Deficiency:   The  laboratory does not  have a  well
           documented test procedure for the  analysis of cyanide
           in water samples.

           Recommendation:    The laboratory  should,  as  soon  as
           possible, document the  cyanide  test procedure.   The
           test  procedure  should  describe  exactly   how  the
           laboratory is performing the cyanide  analysis.

        o  Observation:    The laboratory data on total  organic
           carbon  (TOO are  hard  to evaluate since  the instru-
           ment outputs  (data)  are  not legible.  This  is  not a
           good recordkeeping practice.

           Recommendation:   The laboratory should  look into the
           possibilities of acquiring a printer  that would print
           the sample data  legibly  so that the TOC  data can be
           evaluated, if necessary.
ESL  contracts  with  ETC to  perform analyses  for organic  con-

taminants.   The Task  Force  laboratory evaluation team  visited

ETC  in July  1987  to determine the  laboratory's  capabilities  to

analyze the  following  organic  contaminants:   benzene,  methylene

chloride,  tetrachloroethylene,   trichloroethylene,   toluene,

1,1,1-trichloroethane,  methyl  ethyl  ketone,   xylenes,   ethyl

benzene,   1,1-dichloroethane,  1,2-dichloroethane,  trichloroflu-

oromethane, and ethyl acetate.   The Task  Force evaluation of ETC

determined that the overall performance of the laboratory was

-------
                              66

acceptable.   However,  the  following deficiencies  were  noted

during the evaluation:

        o   Deficiency:   The  laboratory  did not extract   pest-
           icides and PCBs samples at the pH  range  specified in
           the EPA  manual,  SW-846,  Second  Edition  (1984).  The
           audit team was told that the  laboratory staff did not
           determine the pH  of  the water samples  since  the
           Sample Field  Parameter  forms  (CC2)  have the  pH data
           on them.

           Recommendation:    If  the  laboratory  cannot  extract
           (i.e.,   sample  extraction   by   liquid-liquid  or
           continuous extraction technique  and concentration of
           the extract  to 5.0  ml) pesticides  and PCBs  sample
           within 48 hours of  collection,  the sample  should be
           adjusted  to  a pH  range of  6.0  to  8.0  with  sodium
           hydroxide or sulfuric  acid,  if  <=< -BHC,   tf  -BHC,
           endosulfan I and II, and  endrin  are of interest. All
           samples must be extracted within  7  days and  complete-
           ly analyzed within 30 days of sample  collection.

        o  Deficiency:   The laboratory did not extract  the semi-
           volatile  (acid,  base,   and neutrals)  samples  within
           14 days of sample collection.

           Recommendation:    The semivolatile sample  extraction
           step must be completed (i.e., sample  extraction and
           concentration  of   the   extract)  within  14  days  of
           sample collection.   (Note:  The  EPA new  RCRA Methods
           Manual,  SW-846,   Third  Edition  1986,  requires  the
           semivolatile  organic  samples be  extracted  within  7
           days of sample collection.)

        o  Comment:   Since the  Second Edition of SW-846 did not
           properly address the sample preservation  and holding
           time requirements  for  aromatics  in EPA Methods 5030
           and 8240,  it is  advised  that the laboratory follow
           the sample preservation and holding time requirements
           specified in EPA Method 8020  of the RCRA Manual.
Radiochemistrv Laboratory

Core Laboratories has been  certified  by  EPA Region VIII for the

analysis  of  radionuclides  in  drinking  water  since 1980  with

current certification through November  1987.   The radionuclides

-------
                               67
analyzed  by  Core Laboratories  are  gross  alpha,  gross  beta,
Radium-226, Radium-228, and uranium.

MONITORING WELLS

The   initial  RCRA  monitoring   system  (P-series   wells)  was
installed  in  January 1980.   The  locations of the P-series wells
are shown  in  Figure 8.   These wells were characterized as being
insufficient  to  adequately  monitor  ground water at  the facility
due to the following reasons:
        o  Sampling  had  to  be  conducted during  two  or  three
           separate  occasions  to obtain enough  samples for one
           quarterly analysis.
        o  Several wells were often dry at the sampling time.
        o  The  P-series  wells  were  screened  only in the glacial
           outwash and did not monitor the upper fractured zone
           of the Silurian dolomite to which it is hydraulically
           connected.
WMI  submitted an  application  in  December  1983  to modify the
ground-water monitoring program.  After several revisions to the
application,  a supplemental  operating  permit  (1984-16-SP)  was
issued to WMI by IEPA.

The  installation  of the new  monitoring wells was  completed on
April  2,  1984.   The current monitoring  system consists  of 41
ground-water monitoring wells (G-lll through G-151)  and five  .

-------
                                     68

                                 FIGURE 8

             LOCATION MAP OF P-SERIES MONITORING WELLS
    mi
                                                         O
                                                         <
                                                         o
o

                                                                      0

                                                                     i
                                                                  Ul   Ul

                                                                  Ul   *
                                                                  u.
                                                                  o
                                                                      z
                                                                      o
                                                                      s
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                                                                  O   (A

                                                                      ft.

                                                                  ^   O

                                                                  ui   2
                                                                  c   5

                                                                  1   ?
                                                                  u.   (0
Source:  P.E. LaMorcaux, 1984. Ground-water Quality Assessment for ESL Facility.

Will County, Illinois, July 1984.

-------
                               69
glacial till monitoring wells  (GT-10  through GT-14).   The first
year  of  quarterly  sampling  performed  to  establish  initial
background concentrations  and  values was completed  in February
1985.

Well Locations

Four G-series wells  are  installed hydraulically upgradient from
the  limit of the waste management area.   Monitoring wells G-lll
through G-114 are  located along  Patterson  Road (see  Figure 9).
They  are  designated as  background wells  by  virtue of  their
location upgradient  from  the facility and  away from  past waste
management areas.    The  other  37 G-series  wells  are installed
hydraulically downgradient at the limits of the waste management
areas and monitor the uppermost aquifer.  The locations of these
downgradient wells  were  determined  using  the  results  of  the
contaminant dispersion  equation  and model  studies conducted by
WMI consultants.

During  the  Task  Force  inspection,  members  of the  Task  Force
identified two deficiencies in the well locations:
        o   Two  of the downgradient wells were  unavailable for
           sampling at the  time of the  inspection  because they
           were installed with inflatable packing devices.  IEPA
           was  notified  on  March  9,  1987,  that  inflatable
           packers had been  installed  in wells  G-139 and G-140.
           WMI purportedly installed the packers to prevent

-------


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70
FIGURE 9
LOCATION MAP OF G-SERIES MONITORING WEL
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-------
                               71

           contamination  of  ground water  through cracked  well
           casings,  which  were   discovered  during  voluntary
           borescope investigations.  The cracked well casings
           were  visually  verified  by   IEPA  from  viewing  a
           videotape  of  the   borescope  investigations.    Both
           wells were  in  the  assessment  phase of monitoring and
           were scheduled to  be  sampled during the  Task  Force
           inspection.  WMI presented  Task Force personnel  with
           a  waiver  of  responsibility  for  ground-water  con-
           tamination  resulting   from   the   removal  of  the
           inflatable  packers.    The  wells  were  not  sampled
           because  (1)  EPA  policy is not to  sign  any waiver of
           responsibility, (2) there was no  available method to
           sample  the  ground  water  below the  packer,  3)  they
           have a  well  documented history of contamination, and
           (4)  of  the  time  constraints  of  the  inspection.
           Therefore,  a  portion of the  perimeter of  the  waste
           management  area,   longer than 600   feet  along  the
           southern  edge  of  the co-disposal   landfill,   was
           unmonitored for a  period of time,  including the  time
           of the Task Force inspection.

        o   Five GT-series monitoring  wells  (GT-10  through
           GT-14)  are situated around the perimeter of the waste
           management  area,   one   upgradient  (GT-14)  and  four
           downgradient  (see  Figure  9).   The  purpose of  the
           glacial  till  wells as  stated by  WMI is  to  confirm
           that  no  contaminants   are  migrating   horizontally
           through  the  clay   till and  bypassing  the  aquifer
           monitoring  wells.    The number  of  wells and  their
           associated  spacing appears  inadequate to meet  the
           stated  objective,  because  WMI's  consultants  deter-
           mined  that  a  37-well network   was  necessary  to
           adequately  monitor  the  perimeter  of   the  waste
           management area in the uppermost aquifer.
The Task Force  recommends  that  the  contaminant  dispersion model

used by WMI's consultants be evaluated to assess the assumptions

it  incorporates  and to  assess  the  conversion of  the  model

results to the lateral monitoring well spacing used at the site.

-------
                               72
Well Construction
The modified  ground-water  monitoring well system consists  of a
total of 46 wells, shown in Figure 9.  The system consists of 11
wells installed  at the site  in several phases during  1982 and
1983  and  35  new  wells  installed  in  March  1984.    The  wells
include  2-inch  ID  and 4-inch  ID PVC  riser  and  screen.   WMI
indicated that the older 4-inch diameter wells were  drilled with
a hollow stem auger, nominal 8-inch diameter boring.   The 2-inch
diameter  wells  were  drilled  using  rotary   wash   techniques,
nominal 6-inch diameter borings.   The  4-inch or  6-inch nominal
diameter borings  were advanced into  bedrock.   WMI  stated  that
the older  wells  were installed with  Schedule  80 PVC  plastic.
WMI stated that all of the  joints  are threaded  with  Teflon tape
on the threads.   All well  screens are No. 10 slot size.   Table 6
presents   a  summary  of   the  monitoring   well  construction
parameters.

The 41  wells installed  in the  uppermost aquifer have varying
ranges in  screen  lengths (see  Table  6).   WMI  indicated  that the
length of  screen  in each well  was  selected to provide screening
in  the  entire  section of  the uppermost  aquifer to  intercept
water through the aquifer  profile.   The  wells extend  10  feet
into the bedrock  to sample  water  in  the fractured and weathered
dolomite of  the  uppermost  aquifer.   Figure  10 is  a schematic
diagram of the  typical construction for the uppermost aquifer
monitoring wells.

-------
                                               73

                                          TABLE 6

                  MONITORING WELL CONSTRUCTION DESCRIPTION
  DM
 00/10/03
 00/11/03
 03/29/04
 03/30/14
 03/24/04

 03/34/14
 10/14/03
 03/30/04
 03/70/14
 03/21/14

 03/21/14
 13/07/12
 03/23/14
 03/23/14
 03/3C/04

 03/30/14
 03/2C/04
 03/29/14
 03/29/14
 03/31/04

 03/37/04
 03/24/04
 03/33/14
 10/27/13
 03/2C/04

 03/33/04
 03/31/14
 03/37/04
 OC/17/13
 03/37/04

 03/30/04
 03/30/04
 03/21/04
 09/37/03
 03/1C/04

 03/13/04
 03/K/04
 03/23/14
 04/14/13
 04/U/S3

 03/21/04
12/04/02
03/20/14
03/2S/I4
01/29/02

03/30/04
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CU3
C114
G113
C114
C117
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C123
C124
C123
C13C
C127
C12S
CU9
CUO
CU1
C132
CU3
C134
CU3
cue
C137
C13I
C139
C140
C141
C142
C143
C144
C145
C14C
C147
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C149
C150
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CT18
CT11
CT12
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Old
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7 3/4* D*f Bit. 7 3/4* Tricon*
< 1/2" OFA. S S/f ft 3 7/0 Tricon*
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3 7/f ft 3 7/f Tricon*
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3 S/f ft 3 7/f TXicoiM
3 7/0* ft 3 3/4- Tricon*
S 7/0  3 7/f Tricon*
3 3/0- ft 3 7/1- Tricon*
7 3/4 Mali Til
3 7/0, 3 3/4 Tricon*
3 7/0- . 3 3/4 Tricon*
S 7/t". 3 3/4' Tricon*
3 3/f. 3 7/f Tricon*
C* BaUo* St.* Au**r
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3 7/0- ft 3 7/f Tricon*
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3 7/f ft 3 3/4* TTleon.
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47.0
32.0
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31.0
37.0
37.0
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Cl.S
43.0
C1.3
C2.0
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C2.0
41.0
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49.0
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14.71'
14.71'
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9.4*
13.2'
14.4*
19.12'
19.1'
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19.1'
19.1'
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14.71'
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29.57'
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5'
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9.4'
9.4'
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314*
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31.7'
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334'
NA
NA
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394'
37.9'
374'
S7J'
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33.7'
34.9'

21.91
19.4'
11.9'
CT14
                                     (* Bollo* st.a
15.0'
  Note:     Depth to water level measurements were made from the top of the casing.
             NA  designates wells that were not available for sampling at the time  .
             of the inspection.

  Source:    Waste Management of Illinois, Inc., 1983.  RCRA Part B Permit
             Application, Volume II - Groundwater Monitoring.  September 1983 with
             revisions, July 1985.

-------
                                        74

                                   FIGURE 10

TYPICAL CONSTRUCTION FOR THE UPPERMOST AQUIFER MONITORING WELLS


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           Application, Volume II - Groundwatcr Monitoring, September 1983 with
           revisions, July 1985.

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                               75
After each borehole was completed, the well screen and pipe were
installed in the  boring.   Well-graded sand was installed around
the well screen to the top of the bedrock.  Then the temporary
casing was  removed and water  flushed through the  casing (from
inside to  outside) to clean any  mud cake in  the  outwash zone.
Sand pack was added to the annular space to approximately 2 feet
above the  base of  the till.   A bentonite  pellet seal  with a
minimum thickness  of  2 feet was  installed above the  sand pack.
Cement-bentonite grout was used to fill  the  annular  space from
the top of  the  bentonite  pellet seal to  the  ground surface.   A
concrete anchor collar, which  extended to approximately  3 feet
deep, was cast around the  well  at the ground surface.   A 6-inch
diameter protective steel  casing with a hinged cap and provision
for a lock was set in the  anchor collar.

The  construction  of  the   wells  completed in the  glacial  till
varied somewhat from  the  uppermost  aquifer wells.   Borings were
drilled to  approximately  25 feet using nominal  8-inch diameter
hollow stem augers.   Schedule  80,  4-inch diameter  PVC with No.
10 well screen  and casing were installed after  the augers were
removed.    Well-graded sand was  installed in  the  annular space
around the well screen to  approximately 2 feet above  the  top of
the  screen.   Then  a  bentonite  pellet   seal with  a  minimum
thickness of  1 foot  was   installed above the sand pack.   The
remainder of the  glacial  till  well construction is the  same as
that used for the aquifer  wells.

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                               76
Following  construction,  each-well  was developed  by  continuous
pumping or bailing to remove fines from the well casing and sand
pack.   A minimum  of three well  volumes  was removed  from each
well.

Total depth measurements could not  be  made on the aquifer wells
because  each  was equipped  with  a  dedicated  Well Wizard.   The
facility  representatives  remove  the Well  Wizards on  an annual
basis to measure total well depths.   WMI provided the total well
depths from the most  recent measuring.  This  data revealed that
well G-136  is 3.65 feet shallower  and well G-137 is  4.06 feet
shallower than when originally installed.

The  Task Force  has  raised the   concern  of  potential  chemical
interaction between organic chemical  contaminants and  the  PVC
well casing  and screen  material.   Both  the RCRA Ground-Water
Monitoring Technical  Enforcement  Guidance  Document (TEGD) (U.S.
EPA, 1986b)  and the  Illinois  State Water  Survey Guide  to  the
Selection  of  Materials  for  Monitoring Well Construction  and
Ground-Water Sampling, state that well construction and sampling
components made  of PVC rather than more  inert  materials could
lead to. a bias  in ground-water samples because  of sorption and
desorption of hazardous constituents  onto the  casing  and pump
discharge tubing.

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                               77
Task Force personnel  indicated that for wells constructed prior
to 1984, discrepancies were found between field observations and
the sampling plan  regarding  the construction material.   Not all
of these wells were constructed using Schedule 80 PVC pipe.  The
Task Force also noted that the sand pack was not selected based
on site-specific geologic information, but rather based on basic
general procedures.

The Task  Force  noted that some of  the  wells have long screened
intervals, in excess  of  20  feet.   Well construction information
indicates that there  is  also 2 feet of  sand pack above the top
of the  screen,  so that  the  effective  screened  intervals  are 2
feet longer than  the values given  in Table 6.   The  Task Force
feels that some of these screened  intervals  are  too  long.   The
TEGD states  that  excessive  screen lengths  can  result  in the
dilution of contaminants  present  in the ground water (U.S. EPA,
1986b).   The  Task Force  also  recommends that well  clusters be
used for  any  additional  monitoring wells installed at  the ESL
facility  where  the  uppermost   aquifer  thickness  requires  that
water would be drawn from the entire thickness.

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                              78

GROUND-WATER AE-TflNT PROGRAM  OUTLINE
State regulations,  35 IAC  725.193  (equivalent to  40  CFR Part

265.93),  require  a  TSD  facility  to  prepare  an outline  of a

ground-water  quality assessment  program.    This  outline must

describe a comprehensive  program capable of determining:
        o  Whether  hazardous  waste  or  hazardous  waste
           constituents have entered the ground water

        o  The rate  and extent of  migration of hazardous
           waste   or  hazardous  waste constituents  in the
           ground water and

        o  The  concentrations  of  hazardous  waste  or
           hazardous  waste constituents in the ground water
If  analyses  conducted under  the  indicator  evaluation program

indicate  that  the   facility  may  be  affecting  ground  water,

additional samples are to  be  taken immediately to determine  if

the original analytical results  were biased by.laboratory error.

If  ground-water effects  are  still  suspected,  a ground-water

quality  assessment  program is  to  be  developed  based  on the

outline and specifying:

        o  Number,  location, and depth of wells

        o  Sampling   and  analytical  methods  for   those
           hazardous wastes or hazardous waste  constituents
           in the facility

        o  Evaluation  procedures,   including   any use  of
           previously   gathered   ground-water   quality
           information

        o  A schedule of implementation

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                              79
The   "Outline  of  Ground-Water   Quality   Assessment  Program"
appearing  in  an  undated  document   entitled  "Ground-Water
Monitoring  Program  for  CWM,  Inc..,   Joliet,   Chemical  Waste
Management, Inc., Laraway Road,  Elwood,  Illinois" was determined
by IEPA  to be  inadequate to meet the  requirements of  35  IAC
725.193.

In general,  the  outline  lacks  the  specificity  of detail  in
procedures and methodology that  should facilitate development of
assessment plans  which adequately deal with  detected releases.
As a  result  of this  lack of specificity,  ground-water  quality
assessments which have occurred at the ESL facility have  been
characterized by long, drawn-out iterative processes in develop-
ment  of  acceptable  assessment plans and,  thereby,  contributing
to  lengthy but  essentially  superficial  ground-water  quality
assessments.  Specifically, the  deficiencies in  the  "Outline of
Ground Water  Quality  Assessment  Program" which  lead  to  the
problems  discussed above include the following:
        o  The outline did not stipulate  specific criteria
           for installing additional downgradient wells  and
           a  predetermined  strategy  for  locating  those
           wells.
                                                                i
        o  The outline contains  insufficient information on
           when, why,  and under what  conditions  the number
           of cluster wells should be increased.
        o  The outline  did  not  stipulate  conditions under
           "which  nearby  ground-water  supplies   (such   as
           private  wells)  indicator  parameters  would  be
           analyzed for in the samples.

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                      80

o  The outline  fails to  stipulate  the conditions
   under  which downgradient surface waters, which
   receive   ground-water  discharge,  would  be
   sampled,  the sampling scheme  that would be used,
   and what indicator parameters would be analyzed
   for in the samples.

o  The  outline fails  to  specify  the acceptable
   conditions under which monitoring wells would be
   allowed to return to  indicator  evaluation
   monitoring.

o  The outline fails to  specify  the proposed models
   for predicting  rate  and extent of migration of
   pollutants, though modeling is proposed for
   evaluating nonattenuating pollutants, attenuat-
   ing  pollutants,  pollutants  chemically  or
   biologically  affected  in  ground  water,  and
   pollutants subject to filtration  in  ground-water
   media.    The  outline  should specify which model
   or  models  are  being  proposed  so  that  the
   adequacy of those models can be reviewed before
   they are  actually needed.   It should  also be
   specified that  modeling  would  only be used for
   interpolation due  to  lack  of  confidence  with
   well  system,  and  because  of  difficulty  in
   meeting  all  the  assumptions  required  in  most
   ground-water models.  Often  it  is  particularly
   difficult to meet the  assumption of homogeneous
   media  found  in  most   ground-water  models.
   Specific models  should be proposed,  and those
   proposals  should  be  either  supported  by field
   data  or   associated   uncertainties  should  be
   identified  so   that   modeling  results  can  be
   evaluated in the proper framework.

o  The outline should specify in greater detail the
   conditions for  adjustment of,  and the criteria
   for  determining,  the  selection   of,  and  the
   frequency.     The   current  outline   states,
   "Increase sampling   frequency  based upon plume
   movement,  environment  hazard  potential,  and
   probable  timing   of  pollution  abatement
   measures."   The  outline  fails  to  state  what
   conditions  of  plume  movement  would  trigger
   increased   sampling  frequency and how  informa
   tion on plume movement will be  used to select or
   propose  alternate   sampling  frequencies.   The
   outline  fails  to evaluate environmental hazard
   potential and how would it be used  to propose or
   alter  sampling  frequency.    The  outline  also

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                              81
           needs to  address  the potential hazard  to  human
           health and  wildlife and  the exposure  pathways
           that need to be considered.
GROUND-WATER
Ground-water assessment  monitoring  has been  initiated  for some
of  the  wells  in  both  the  P-  and  G-series,  as  mentioned
previously.  The  specific  details of these ground-water quality
assessment programs  are  discussed  in the  following  two subsec-
tions.

Ground-Water Quality Assessment for the P-Series Wells

In  a  June 9,  1983  letter,  WMI notified  IEPA of  significant
changes   in  indicator  parameters   for   the  P-series  wells.
Statistically significant  changes  in ground-water  quality were
indicated  for wells  P-l  for pH  (decrease)  and specific conduc-
tance  (SO, well  P-2 for SC,  well P-3 for pH (decrease) and SC ,
well  P-4  for  pH  (increase), well P-7 for SC, and  well P-8 for
SC.   The  facility's Student's  t-test  compared the semiannual
sampling  results  with  background quality  for each downgradient
well.  Statistical  comparisons under 35  IAC 725.193 (b) should
have  been  made  between semiannual  sampling  results   and  the
initial  background  quality  of  the  upgradient  wells.    WMI
subsequently  reran   its  Student's  t-test,  this time  comparing
semiannual sampling  results  with the- background quality at each

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                              82
upgradient well  (P-4  and P-7)  separately.  This  time,  well P-l
showed a  significant  decrease  in pH, while P-series  wells (P-l
through P-6) showed significant increases in SC.

WMI submitted a  ground-water quality assessment  plan  to IEPA on
June 24,  1983.   That  plan was subsequently found  deficient by
IEPA reviewers.   An iterative process of revising the assessment
plan then began,  involving a series  of  phone  conversations and
letters between WMI and  IEPA personnel.   This  iterative process
continued from  June  1983 to November 18, 1983.   On  that date,
WMI submitted  a revised  ground-water quality assessment plan,
which the facility characterized as  better portraying  "Phase I
of  the plan  in  context of  the  overall plan."   lEPA's  Land
Division  Subpart  F file  includes  no record that  IEPA  approved
the November  18,  1983,  revised plan.   Nevertheless,  this was
apparently  the  final  implemented   form  of  the  ground-water
quality assessment plan  for the P-series wells assessment.  The
revised assessment plan consists mainly of a first determination
(false  positive  rationale) approach to ground-water  quality
assessment.    In addition, an "Outline of Assessment  of Ground-
Water  Quality"  was attached to  the  revised assessment  plan to
demonstrate* Phase  I activities  in  the context  of the facility's
overall  plan.    The  schedule  of implementation  indicated that
completion  of  Phase  I and  submittal of  Phase  II of  the plan
would be completed by March 1, 1984.

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                               83

WMI concluded  in  its Phase I  assessment  report  that additional

sampling and analysis was  needed  to further assess ground-water

quality in the vicinity of monitoring well P-5.  The following

proposals were  recommended by  WMI  for continued  assessment in

this area:'



    Phase II

    A.  Obtain samples from P-5 and the two new wells nearest to
        it and  analyze  these  samples for  indicator   parameters
        (replicate  analyses)  and  ground-water   quality   par-
        ameters.    These  analyses  should  be  evaluated  both
        statistically and qualitatively to determine if samples
        from P-5 are representative of the uppermost aquifer, if
        the  elevated  TOX  values  persist,  and  if  similarly
        elevated TOX values are  found in the new  wells  fully
        penetrating the uppermost  aquifer.

    B.  If  this sampling  and  analysis  does  not  confirm  the
        anomalous TOH values,  report on the results of the Phase
        II assessment, proceed  with the decommissioning of P-5,
        and resume the detection monitoring program specified by
        40 CFR Part 265 Subpart F  and 35 IAC Part 725 Subpart F.


    Phase III

        If the  sampling  and analysis conducted under  the  Phase
        II  assessment described  above  show  the  elevated  TOH
        levels  persist  and  determine  those  levels  to  be
        .representative of  the  upper most  aquifer,  WMl's  con-
        tractor  recommended that  the  results of  Phase II  be
        reported and  that  a Phase  III assessment  be conducted.
        Phase III would  likely  include  sampling  and analysis of
        well P-5  and the  two   adjacent new wells  for  volatile
        organic  compounds.    This  analysis   should   allow
        definitive  conclusions to  be  made.   More  detailed
        recommendations  for Phase  III will be prepared at  the
        conclusion of Phase II, as appropriate.

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                               34
WMI failed  to  voluntarily  move into Phase II of its assessment.
A CIL, citing 35 IAC 725.193(d)(4), was issued to WMI by IEPA on
October  11, 1985,  for  failing  to  implement Phase  II of  the
ground-water quality assessment  plan.    This CIL  specifically
stated that the results of analyses for wells P-5, G-128, and G-
129 were not evaluated  either statistically or qualitatively to
determine if:
        o  Samples from P-5 were representative of the
           uppermost aquifers
        o  The elevated TOH values persisted
        o   Similarly  elevated TOH values were  found  in the new
           wells   (G-128  and  G-129)   fully  penetrating  the
           uppermost aquifer, as were found in the old well P-5.
At the time of issuance of the October 11, 1985 CIL, WMI had not
moved  into  Phase  II  of  the  assessment  regarding  well P-5  as
indicated  in  its  July  1984  Phase  I assessment  report and  as
required pursuant  to  35 IAC  725.193(d)(4).   The  first sampling
event in fulfillment of Phase II of the assessment did not occur
until  November  25,  1985,   almost   1-1/2   years  after  final
submittal of the Phase I assessment report, and after receipt of
lEPA's October 11, 1985 CIL.  WMI  implemented Phases II and III
of  the assessment  based  only  on  an  assessment plan  outline
rather than a  formal  assessment plan,  detailing  the  specific
evaluation  procedures for Phases  II and  III,  as  required under
35 IAC 725.193(d)(3).

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                               85
On February  18, 1986,  IEPA received copies  of a  February 17,
1986, document entitled "Phase II and III Recommendations to the
Ground-Water  Quality  Assessment  for  the  ESL  Facility,  Will
County, Illinois (The  P-Series Wells)."   The document indicated
that  WMI  had  decided  to  move  into  Phases  II  "and  III  simul-
taneously.  Based upon Phase II report results incorporating two
sampling events  (November  25,  1985 and  December 27,  1985), WMI
concluded that  elevated TOH levels  were  erratic in P-5,  showing
up  in  the  November  sample but not  in the December  sample.
Similarly,  WMI  also  concluded  that the  results  of  volatile
organic compound analyses  for  well P-5  were  also  erratic since
volatile organics were  not present at detectable  levels during
the November sampling  event, even though the following organics
were detected in the December samples:
      Dichlorodifluoromethane       116  ug/L
      1,1-Dichloroethane            6.42 ug/L
      Vinyl chloride                271  ug/L

Despite these  findings, WMI concluded in its  February 17, 1986,
document that:
        "P-5  should  also  be  decommissioned,  along  with  the
        remaining P-Series  wells.   There  are several  reasons
        for this,  based  on results of  the Phase  II  and  III
        investigation.
        1. P-5  is not screened in the roc3c/outwash interface.
           The purpose of the  G-Series wells was  to monitor the
           outwash and rock portions of the aquifer, because the
           P-Series   wells  were  always  drying up  and  a  more

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                              86
           representative  sample  of  the  aquifer   could   be
           obtained from the G-Series wells.
        2. The surrounding G-Series  wells  are yielding  samples
           that  are   accurately   representing   ground-water
           quality in the aquifer near P-5.
        3.  The  erratic  elevated  TOX and  detectable  volatile
           compounds in P-5, where these parameters are  absent
           in G-126  and  G-127,  suggest contamination  of  P-5,
           which is not related to the landfill.
        A schedule and method  of decommissioning the P-Series
        wells will be forwarded to the Agency within  30  days."
IEPA was  subsequently notified on  March 5,  1987,  that the  P-
series wells had indeed been decommissioned  on March 4,  1987.

Ground-Water Quality Assessment for  the G-Series  Wells

From the results of the August 1985  sampling event,  seven of the
new G-series  wells  entered the assessment  phase.   These  wells
included G-117 for specific conductance  (SO; G-128,  G-129,
G-131 and G-137  for  pH; G-139 for  SC,  TOC, and TOX; and  G-140
for pH.   WMI  failed to immediately retest  the seven  monitoring
wells that  showed significant changes  in indicator  parameters,
as  required  under 35  IAC,  Part 725.193 (c)  (2) and  40 CFR  Part
265.93  (c)(2).    A  "Ground-Water   Quality  Assessment  of  ESL,
Joliet, Illinois" report submitted  to  IEPA  by WMI on  August 25,
1986, contains  a statistical re-evaluation  of monitoring  wells
G-128, G-129, G-131,  G-137, and G-140  for pH.   Of these,  only G-
131  failed  the average replicate  test the  second  time.   This

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                              87
second statistical re-evaluation,  based on data collected by WMI
during the first quarter  1986, was  interpreted by  IEPA as their
eventual submittal of  results of  the  resample  efforts to comply
with  35  IAC  725.193 (c) (2).    As  such,  IEPA  issued  a CIL  on
December   1,   1986,   citing  apparent   violation   of  35  IAC
725.193(c)(2)  for  failing to retest  wells  G-117 and  G-139  for
SC,  and  G-139 for  TOX and  TOC.    In  addition,  the  CIL  cited
apparent  violation  of  35  IAC   725.193(d)(4)  for  failing  to
determine rate  and  extent of migration  of hazardous  waste  or
hazardous waste constituents from well G-131, the only well that
failed the average  replicate test for pH the  second time.   The
results of analyses  of parameters contained in  40  CFR Part 261
Appendix VII  submitted for  the  well G-131  assessment detected
the presence of methylene chloride at 3.77 ug/L and methyl ethyl
ketone at  4.2 ug/L,  thus subjecting the  ESL facility  to  the
plume description  requirements of 35 IAC .725.193(d)(4) .   EPA'S
July  16,  1986  complaint  had  already  sought  a complete  plume
description for all hazardous constituents in the ground water.

WMI's December  12,  1986,  response  to lEPA's  December  l,  1986,
CIL  adequately  resolved  the  citation of 35  IAC 725.193(c)(2) ,
but the citation  for Section 725.193(d)(4)  remained unresolved.
A return to compliance letter for Section 725.193{d)(2) was sent
to  WMI on  December  19,  1987.    However,  WMI was  apparently
unaware that  Section  725.193(d)(4)  remained  outstanding  until
this  fact was pointed  out by IEPA personnel  during a February

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                              88
12, 1987,  reconnaissance  visit  to the ESL  facility  in prepara-
tion for the March 1987 Task Force inspection.

A  response from  WMI  dated  March 13,  1987, further  addressed
apparent violation of  35  IAC 725.193(d)(4).  This  response was
subsequently  deemed  inadequate  to   resolve   the   outstanding
violation, but it did clear  up  one point  of confusion regarding
WMI's eventual ("immediate") resampling effort  submitted in its
August  25, 1986,  assessment report.    WMI's   March  13,  1987,
letter to  IEPA stated that  the second round of  statistics had
not been submitted pursuant to the regulatory requirements of 35
IAC  725.193,  as  had  been previously   interpreted  by  IEPA
personnel.  As a result of this  finding, IEPA concluded that all
seven   monitoring  wells  that  originally  "triggered"  into
assessment during the August 1985 sampling event were subject to
the  immediate resample requirements  of  35 IAC  725.193(c)(2) ,
and, failing  to  meet this  requirement,  all seven wells became
subject  to   the  plume   description   requirements   of  35  IAC
725.193(d)(4).  Table  7 shows the detected organic  contaminants
reported  in  the  40  CFR  Part 261 Appendix VII test  results  in
WMI's August  25, 1986, assessment report.

Despite detection of the contaminants listed below,  WMI's August
25, 1986,  assessment  report concluded that  monitoring wells  G-
117, G-128,  G-129,  G-131, and  G-137  should return  to indicator
evaluation monitoring because methylene chloride was detected in

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                              89

                               TABLE 7

                HISTORIC DETECTED ORGANIC CONTAMINANTS
            REQUIRING INITIATION  OF THE ASSESSMENT PROGRAM


Well Number              Parameter	Level  (ucr/L)

G-117         '      Methylene Chloride                1.3
G-117               Methyl Ethyl Ketone               2.8

G-128               Methylene Ch-loride               12.4
G-128               Methyl Ethyl Ketone               2.4

G-129               Methylene Chloride               14.2
G-129               Vinyl Chloride                   24.3

G-131               Methylene Chloride                   3.77
G-131               Methyl Ethyl Ketone               4.2

G-137               Methylene Chloride                   3.11

G-139               Benzene                 .         44.7
G-139               Benzene                          10.6
G-139               Benzene                          27.3
G-139               Toluene                         154.0
G-139               Toluene                          41.0
G-139               Toluene                         153.0
G-139               Trichloroethylene                11.l
G-139               Trichloroethylene                21.9
G-139               Methylene Chloride                   3.61
G-139               Methyl Ethyl Ketone              85.7
G-139               m-xylene                         11.1
G-139               o&p-xylenes                      53.2
G-139               m&p-cresols                      77.8
G-139               1,4-Dichlorobenzene                  6.89
G-139      .         Phenol                           40.5

G-140               Benzene                          24.2
G-140               1,1-Dichloroethane              309.0
G-140               1,2-Dichloroethane               45.1
G-140               1,2-trans-Dichloroethylene      603.0
G-140               Methylene Chloride                   4.59
G-140               1,2-Dichloropropane              30.4
G-140               Tetrachloroethylene                  7.34
G-140               Trichloroethylene                37.1
G-140               Vinyl Chloride                   41.2

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                              90
the  QC  matrix  unspiked  sample -(6.79  ug/L)  and  methyl  ethyl
ketone was detected in both the QC blank  and  QC  matrix unspiked
sample (23.8 and 4.31 ug/L, respectively).  It should be pointed
out, however,  that  neither the QC  blank or QC  matrix unspiked
sample represented the sample control  values  for the downgradi-
ent  wells.   Proper  sample control  values for  the test  wells
(assessment wells) are represented by the field blanks drawn for
these  seven  wells.     WMI's  August   1986  assessment  report
indicated  that  neither  methylene  chloride  nor  methyl  ethyl
ketone had  been detected  in the  field blanks for  these wells.
The  only verified  external contamination occurred  in the  QC
samples prepared  totally within the laboratory.   Nevertheless,
WMI  concluded  that  the absence of methylene  chloride  or methyl
ethyl ketone in the  field blank did  not indicate the absence of
methylene chloride or  methyl ethyl  ketone in  the laboratory and
that  it  considers   these contaminants   attributable  to  lab
contamination and not related to the ground water.

WMI  failed  to   address  possible   reasons  for  detection  of
methylene chloride and methyl  ethyl  ketone in downgradient well
samples  while  failing to detect  identical contaminants in the
field  blank controls,  which  were  prepared  and  handled  in  a
manner identical  to  the  downgradient well  samples.   No further
investigation was proposed by WMI at the time of the inspection.

-------
                              91

STATUS OF GROUND-WATER MONITORING UNDER INTERIM STATUS



As  a  result  of  the  Task  Force  inspection,   the  following

violations of  the RCRA  regulations  pertaining to  ground-water

monitoring were discovered.


    1.  Pursuant to 35 IAC  725.190(b),  except  as  paragraphs  (c)
        and  (d)  provide  otherwise, the owner  or  operator of  a
        TSD  facility  must   install,   operate   and  maintain  a
        ground-water monitoring system which meets  the  require-
        ments of  Section  725.191  and must comply with  Sections
        725.192  through  725.194.   This ground-water  monitoring
        program  must  be  carried out during  the active  life  of
        the  facility   and  for  disposal  facilities  during  the
        post-closure care period as well.

        ESL  is  in apparent  violation  of  35  IAC  725.190 (b)  for
        the  following  reasons:   At the  time of March  1987  CME
        (compliance  monitoring   evaluation)  and   Task  Force
        inspections,   temporary  packing   devices  had   been
        installed  in  monitoring  wells  G-139  and  G-140,  and
        therefore, the  wells  did  not  meet the requirements  of
        725.191(a)(2).   A waiver  was  prepared by WMI  stating
        that any ground-water  contamination  that resulted from
        the removal of the packers for sampling   purposes  would
        be the  responsibility  of the  Task  Force     The  Task
        Force  did not  sign the  waiver.   On  this  basis,   it
        appears  that   the  ground-water  monitoring  system  did
        not meet  the  requirements of 725.191(1)(2).    Specifi-
        cally,   a  portion   of  the   perimeter   of   the  waste
        management boundary consisting of  greater  than  600 feet
        (the distance between monitoring  wells  G-138  and G-141)
        was  unavailable  for  sampling  for a period  of time,
        including  the time  of  the  CME  and Ground-Water  Task
        Force  inspections.    Both wells  G-139 and G-140  were
        scheduled for sampling during these inspections.

    2.  Pursuant to 35 IAC  725.193(d)(4),  the  owner or  operator
        must implement the ground-water quality assessment plan
        which  satisfies  the requirements  of paragraph  (d)(3),
        and,  at a minimum, determine:

        A. The  rate  and extent  of migration of the  hazardous
           waste  or hazardous  waste constituents  in  the  ground
           water; and

-------
                              92

        B. The concentrations of the hazardous waste or
           hazardous waste constituents in the ground water.
           ESL is in apparent violation of 35 IAC 725.193(d)(4)
           for the following reason(s):   The  rate and extent of
           migration of  the  hazardous waste  or  hazardous waste
           constituents  detected  during  assessment  monitoring
           have  not been determined.
Two additional deficiencies  were noted at the time  of  the Task

Force inspection:

        o  Discrepancies in total well  depths  were discovered
           when  original  boring  logs  were  compared with data
           from the most  recent (January 6, 1987)  measuring.
           Well G-136 was 3.65 feet shallower and well G-137 was
           4.06 feet shallower than when originally installed.

        o  The  facility made no provisions  for  the disposal of
           the ground water  purged from  the  monitoring  wells
           before the  samples were taken.   If  analysis  of the
           well water  suggest that  the water  is  hazardous,  it
           should be drummed and disposed of properly.
GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT



EPA  Region V  requested a  Part  B  permit  application  from ESL

early in 1983 and received it on September 1, 1983.  As a result

of  IEPArs  and EPA  Region  V's  review of  the  Part  B  permit

application, ESL was issued several notices of deficiency (NOD),

and many responses and reviews have been exchanged.  On June 21,

1986,  EPA  issued an  administrative  complaint  and  compliance

order  to  WMI  for  failing  to  supply  information required  to

complete the Part B permit application.

-------
                               93

The  compliance order  identified  the  following  information as

necessary to complete the Part B application.
        o  A  complete summary  of ground-water  monitoring data
           obtained during interim status, as required by  35 IAC
           703.185U) and 40 CFR  270.14(c) (1) . '

        o  A plan and implementation  schedule  for the descrip-
           tion of any plumes of  contamination that have entered
           the. ground water  from a regulated  unit.    The plan
           must  include  the  information  required by  35  IAC
           703.185(b-d) and 40 CFR 270.14(c)(2-4).

        o  Detailed plans and an  engineering report describing a
           proposed  ground-water  corrective action  monitoring
           program to meet the requirements of 35 IAC 724.200 as
           required by  35  IAC 703.185 (e  and h)  (40 CFR 264.100
           as required by 40 CFR  270.14(c)(8).
MONITORING DATA ANALYSIS FOR INDICATIONS OF WASTE RELEASE



This section presents an evaluation of the Task Force monitoring

data regarding indications -of apparent or potential leakage from

the waste management  units  at  the ESL facility.   The analytical

results  from  samples collected  by  Task 'Force  personnel  are

presented in Appendix A.   Appendix B  contains  an evaluation of

the quality control data pertaining to the analysis of the Task

Force  samples.    This  evaluation should be  considered  when

assessing the ground-water analyses.



All  positive  acetone  and   methylene   chloride  results  are

considered unusable because these contaminants were also present

in the  field  and  trip blank  samples.   Table  8  indicates  the

-------
                               94
concentrations  of  volatile  and  semivolatile  organics  found
during the Task Force sampling.  Several wells exhibited organic
constituents at levels greater than CRDL.   Well  G-129 had vinyl
chloride present  (10  ug/L and 11 ug/L  (duplicate)),  well G-123
had  1,2-trans-dichloroethane  present  (6  ug/L),  and  well G-134
had trans-1,2-dichloroethane  and  1,1-dichloroethane  present (19
ug/L and 12 ug/L,  respectively).

Two wells  showed  values  exceeding the  maximum levels specified
in 40 CFR  265  Appendix III (35 IAC 725 Appendix  C) .   The wells
affected were G-117 (fluoride at 9.2 mg/L) and GT-14  (Nitrate at
20.0 mg/L).

The total  lead data was  judged to be qualitative  in an evalua-
tion of  the quality  control  data.   Wells  G-117,  G-118, G-137,
and  G-141  all showed  an  increase  in  total  lead over  the
upgradient  wells  and are  above  the national  interim  primary
drinking water  standards  levels.   Twenty-one wells showed total
iron   levels   above   the   proposed   secondary  drinking  water
standards  levels.    Total  aluminum,  calcium, magnesium,  man-
ganese,  and sodium values  for  downgradient  wells  were often
above the  values  for  the  upgradient wells.   Zinc, vanadium, and
tin were detected in some of the downgradient wells but were not
present in either of the upgradient wells (G-112 and G-113).

-------
                               95
Wells  G-117,  G-124,  G-134,  and  G-149  revealed  values  for  total
organic carbon  (TOO at  least  two times  greater  than the  upgradient
wells.    Wells  G-125,  G-131, G-132, G-134, G-137,  and G-141 showed
values  for purgeable  organic  carbon  10  times  greater  than  the
upgradient wells.

Further analyses of 12 wells  indicated sulfate values at  least four
times greater than  the  values for the upgradient  wells.  The sample
analyses  also  indicated  that no  pesticides   or  herbicides  were
detected in any of the wells.

The analysis  of samples  collected  by the Task Force  found  a number
of organic  compounds  in well  G-123, G-129,  and G134.  Based on the
historical sampling data and the Task Force sampling data,  the Task
Force concludes that contamination does  exist  in the ground-water at
the ESL facility.

-------
                                                96

                                              TABLE 8

                             ORGANIC ANALYSES FRCM TASK FCRCE SAMPLING
Well
Field Blank
G-123
G-129
G-129*
G-131
G-134
G-;44
Vinyl
Chloride

2J
10
11


1,2-Trans 1,1-
Fhenol Dichloroethene Dichloroethane
6J
1J 6


1J
19 12
3J
Benzene





1J
Notes:  All concentrations are reported in ug/L.

   *    Indicates a duplicate sanple.

   J    Indicates an estimated value.   This flag  is  used either when estimating a concentration for
        tentatively identified compounds where a  1:1 response  is assumed or when the mass  spectral
        data  indicated  the presence of a  compound that meets  the  identification criteria but  the
        result is less than the specified detection limit but greater than zero.

Source: Task Force ground-water sample analyses.   See Appendix B.

-------
                                      97

                                  REFERENCES

 Alliance Technologies Corp., 1987.  Trip Report on ESL, Joliet, Illinois.  April 1,
      1987.

 Illinois State Water Survey, 1983, Guide to the Selection of Materials for Monitoring
      Nell Construction and Groundwater Sampling, August, 1983.

 Kblata,  D.R., T.C. Buschbach, and J.D. Trevrorgy, 1978.  The Sandwich Fault Zone of
      Northern Illinois, Illinois State Geological Survey Circular Mb. 505, p. 26.

 LaMoreaux, P.E.  (PELA), 1984.  Ground-Water Quality Assessment for the ESL
      Facility, Win County, Illinois, July 1984.

 PRC Environmental Management, Inc., 1987.  Report to the Hazardous Waste
      Ground-Water Task Force, Re:  Evaluation of Quality Control Attendant to the
      Analysis of Samples from the Chemical Waste Management, Inc., ESL, Joliet,
      Illinois, Facility, August 5, 1987.

 united States Environmental Protection Agency (U.S. EPA), 1985.  Preliminary
      report on ESL-Joliet site by Gale Hruska, April 1985.

 U.S.  EPA, 1986a.  Administrative Complaint and Compliance Order issued to WMI
      regarding ESL facility, June 21, 1986.

 U.S.  EPA, 1986b.  RCRA Ground-Water Monitoring Technical Enforcement Guidance
      Document (TEGD), Office of Solid Waste and Emergency Response, September
      1986.

 U.S.  EPA, 1987.  Memorandum fron Maxine Long to John McGuire, U.S.  EPA
      Region V, Re:  Evaluations of Laboratories used by ESL, October 21, 1987.

 Waste Management of Illinois, Inc.  (WMI), 1983.   RORA Part B Permit Application,
      Volume II'- Groundwater Monitoring, September 1983 with revisions, July 1985.

 WMI,  1988.  Closure Plan for ESL, received by U.S.  EPA Region V February 26,
      1988.

 Willman, H.B., 1971.  Summary of the Geology of the Chicago Area, Illinois State
      Geological Survey Circular No.  460, p.  77.

 Woodward-Clyde Consultants (WCC), 1982.   Geologic,  Geotechnical and Hydrogeologic
     Evaluation of Expansion Area to Chemical Waste Management, Inc.  - Joliet,
     Will County, Illinois,  July 1982.

WCC, 1983, Geologic, Geotechnical and Hydrogeologic Evaluation and  Monitoring
     Well Recommendations for the Chemical Waste Management - Joliet Landfill,
     Will County, Illinois,  July 1983.

-------
          APPENDIX A






 GROUND-WATER SAMPLE ANALYSES




FOR TASK FORCE 3NSPECTDN OF

-------
                                TABLE Al-1

            COHTRACT REQUIRED DETECTION LIMITS AHD IKSTRUMEMT   
     DETECTIOH LIMITS FOR" METALS.  IHOHCAHIC,  ATO INDICATOR PARAMETERS
Parameter
Metals
Aluminum
Antimony
Arsenic
Barium
L- 1 > 1 J i uiu
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Hickel
Potassium
Selenium
Silver
Sodium
Tin
Thallium
Vanadium
Zinc
Inorganic and Indicators
Bromide
Chloride
Cyanide
Fluoride
Nitrate-nitrogen
Nitrite-nitrogen
POC
POX
Sulfate
Sulfide
TOC
TOX
Total Phenols
CSDL

200
60
10
200
'j
5
5000
10
50
25
100
5
5000
15
0.2
40
5000
5
10
5000
50
10
50
20

1000
1000
10
1000
300
300
100
5
lO'OO
1000
1000
5
50
IDL

94
5
6
3
2
0.5
6?
6
7
18
23
2
84
4
0.2
23
486
4
5
163
72
6
8
20

50
1000

1000
300
50
20
5
500
1000
1000
5
10
concentrations are in yg/1
                                   Al-2

-------
           ALLIANCE
           T*cnnoiogs Corporation

T0        R.J. DeLuca                                             1 April 1987

FROM*      Julianne Howe ^'^

SUBJECT:   Trip Report - ESL, JolieC, Illinois
Th U.S. EPA has established a Hazardous Waste Ground Water Task Force
(HWGWTF) to evaluate the level of ground water monitoring compliance at RCRA
regulated treatment, storage and disposal facilities.  In order to perform
this evaluation, the EPA has contracted PRO Environmental Management, Inc. to
provide technical services.  PRC has subcontracted to Alliance Technologies
Corporation and Versar, Inc. to conduct sampling and provide technical
assistance to the HWGWTF.

One of the facilities selected for evaluation, Environmental Sanitary Landfill
(ESL) is operated by Waste Management of North America, Inc. and located in
Joliet, Illinois.  The 260 acre site is located southwest of the junction of
Laraway and Patterson Roads in Will County, Illinois.  There has been no
disposal at the site for several years and the landfill.areas are nov covered
with vegetation.  There are 41 monitoring wells at the site.  Five have
dedicated PVC bailers and the remainder have dedicated Well Wizard teflon
bladder pumps.

On Monday, March 16, 1987 an opening meeting was held at the ESL facility
between participating HWGWTF team members and facility personnel.  Present
we res

John McDonnell, Waste Management of N.A., district engineer
John McGuire, EPA Region V, Field Team Leader
Ken Jennings, EPA Washington
Steve Wynnechenko, EPA Region V, Sampling Team Leader
Ken Liss, EPA, State of Illinois
Jonathan Adenaga, EPA Region V
Gulf Coast Personnel (contractors for waste management of NA)
Julie Hove, Alliance
David Billo, Alliance
Sylvie Olney, Alliance

After a brief introduction, the sampling group left the meeting to begin water
level measurements.  These were taken by Gulf Coast personnel and included all
but 2 wells which were covered with plastic.  Waste management claims that
these wells, G139 and G140,  are damaged and would not allow them to be
sampled.  There is some dispute between EPA and the facility on this issue.

On Tuesday, March 17, sampling activities began and continued through friday,
March 20.  Tuesday through Thursday two field teams were  formed,  each
consisting of 2 Gulf Coast personnel, 1 Waste Management  representative, 1 or
2 Alliance personnel and 1 EPA sampling coordinator.  In  accordance with Waste


                  213 Eurfmcton Road. Bedford. Massachusetts 01730 617-275-9000

-------
           ALLIANCE
           Tecnnottgies Corporation
Management's policy, only their equipment was used in the wells and their
contractors operated that equipment.  The facility collected samples at some
of the veils bat because of differences in sampling procedures, were not
considered splits of the samples collected by Alliance for EFA.  The purge
volumes calculated by EPA were based on the sum of the volume of sand filter
pack and the additional standing water in the well casing, whereas the
facility based their purge volumes on 3 well casing volumes.  The facility
also filtered all their samples for inorganic analyses at the well head.

Twentyfive veils were sampled during the evaluation quality control measures
included duplicate samples taken at two of the wells, one field blank and one
trip bank.  Full sample sets were obtained from all but one well (GT 12).

Table 1 summarizes the sampling data at the ESL project.

Table 2 presents the data from field measurements taken during purging.
                                      -2-

-------
                                                         SAMPLING DATA
WELL
C131
CT14
C132
C134
C135
C13?
GUI
C124
C125
CT12




HQB
9
038
048
053
046
031
049
037
044
041
040




SAMPLING
DATE
3/18/87
3/19/87
3/19/87
3/19/87
3/19/87
3/19/87
3/19/87
3/19/87
3/19/87
3/20/87




CASING
DIAMETER
2"
4"
2"
4"
2"
2"
2"
2"
2"
4"




TOTAL
DEPTH
65.0
15.0
62.0
45.0
61.5
61.0
49.0
47.0
52.0
27.0




DEPTH
TO 1120
37.4

33.8
34.2
34.3
32.8
30.0
30.2
30.5
19.4




VOLUME
PURGED
14.5
pbCC
16.5
13.8
16
16.8
20
12.5
15
pbCC




TURUIDITY
(NTU) COMMENTS
4.0
MOO
47
14
32
41
50
8.9
22
MOO








I P & T aomple




Partial Set
5 Extractable
2 P & T
I POC
1 POX




broken





Orfcnnlce



1 Diiiolved Hctala


C144
T
FU


027
050
029


3/20/87
3/13/87
3/19/87


4"
N/A
N/A


30.0
N/A
N/A


27.9
N/A
N/A


6.7
N/A
N/A


62
N/A
N/A
1 Cyanide
1 TOG

Trip Blank
Field Blank at




C125
pbCC - Purged by Gulf Coaat when Alliance  personnel were not  present.

-------
WELL
t
cm
OT14
C132
C134
CI35
C137
GUI
C124
ens'
CT12
0144
TR
FB
IK)B
*
038
048
053
046
031
049
037
044
041
040
02?
050
029
SAMPLING
DATE
3/18/87
3/19/87
3/19/87
3/19/87
3/19/87
3/19/87
3/19/87
3/19/87
3/19/87
3/20/87
3/20/87
3/13/87
3/19/87
CASING
DIAMETER
2"
4"
2"
4"
2"
2"
2"
2"
2"
4"
4"
N/A
N/A
SAMPLING DATA
TOTAL
DEPTH
65.0
15.0
62.0
45.0
61.5
'61.0
49.0
47.0
52.0
27.0
30.0
N/A
N/A
DEPTH
TO 1120
37.4

33.8
34.2
34.3
32.8
30.0
30,2
30. 5
19.4
27.9
N/A
N/A
VOLUME
PURGED
14.5
pbCC
16.5
13.8
16
16.8
20
12.5
15
pbCC
6.7
N/A
N/A
TURBIDITY
(NTU) COMMENTS
4.0
MOO
47
14
32 1 F & T aaple broken
41
50
a. 9
22
MOO Partial Set
5 Extractabl* Organic*
2 P & T
1 POC
1 POX
1 Dlatolved Hetala
1 Cyanide
1 TOG
62
N/A Trip Blank
N/A Field Blank at C125
pbCC - Purged by Gulf Coaat vlien Alliance personnel were not present.

-------
TADI.E 2  CON'T
FIELD MEASUREMENTS
WELL 1
DATE
cm
3/19/87*

CI34
3/19/87

cm
3/19/8?

C137
3/19/87

cm
3/17/87


cm
3/17/87



C1SO
3/17/87


CUB
3/17/87


IN SITU
t
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
4
1
2
3
4
5
1
2
3
4
1
2
3'
4
TIHE
09.36
09i50
10.04
10.58
11,13
Ili30
12.35
12.47
13.00
13.55
14,10
14.40


10,25
10.45
11.15
11,35
12.00
12.13
12,30
13.08
13.29
13.52
14,16
14.33
15,04
15,34
16.00
GALLONS
PURGED
0.5
8.3
15.5
1
7
13
O.S
8 
IS
0
10
16













0
9
16
AS
pll
7.2
7.3
7.1
11.8
8.6
7.4
7.1
7.1
7.0
7.6
7.1
7.1
7.09
7.10
7.S
7.2
6.9
6.6
6.B
6.65
6.85
7.2
6.9
6.9
6.9
6.85
6.75
6.7
6.7
CONDUCTIVITY
(ualioi/cn)
1240
1240
122S
2000
780
860
92S
910
92S
960
. 940
970
1600
1595
1420
1440
1660
1740
1780
1700
1740
1120
1150
1160
1140
1800
1860
1830
1930
TEMP

-------
TABLE 2

wri.i. t
DATE
C112
3/17/87

-
CU7
3/17/87

CII9
3/17/87

C128
3/18/87



C129
3/18/87

CI30
3/18/B7

C131
3/18/87



IN SITU
t
1
2
3
4
1
2
3
1
2
3
1
2
3
4
5
1
2
3
1
2
3
1
2
3
4

TIME
09.10
09.40
09i57
lOilS
13i20
13.30
13i40
14i3S
14.43
14.48
08.50
08.55
09.05
09.20
09.50
11.47
11.52
11.59
13.20
13.42
13.55
15.20
15.40


PI ELI
GALLONS
I'URCED
0
18
24
28 '
3
7

1
7
9
0.5
3.5
5
I
12.5
0.5
6.5
11
4
8.5
13
0
8.5
10
14
) MEASUREMENTS
pll
7.7
.5
.5
.5
.2
.1
.0
t .2
.2
.1
11.5
11.8
9.7
9.0
8.8
7.7
7.3
7.2
6.8
6.6
6.6
8.4
6.5
6.7
6.4

CONDUCTIVITY
(umlioi/cn)
660
620
640
640
2000
1800
1800
1575
1580
1575
 4300
2200
1150
1380
1420
19SO
1575
1530
1230
1150
1130
790
990
1000
1000

TEMP

-------
                                                          SAMPLING  DATA
WEM.
1
C113
CHS
C150
CII2
C117
C117
C119
CUB
cua
C149
C120
CI23
C12B
C129
C129
MQB
t
047
039
032
056
033
04 5
043
034
030
052
042
055
036
051
035
SAMPLING
DATE
3/17/87
3/17/87
3/17/87
3/17/B7
3/17/87
3/17/87
3/17/87
3/17/87
3/18/87
3/18/87
3/18/87
3/18/87
3/18787
3/18/87
3/18/87
CASING
DIAMETER
2"
2"
4 1/4"
4"
4"
N/A
2"
2"
2"
4 1/4"
2"
2"
2"
2"
N/A
TOTAL
DEPTH
46.0'
57.0'
37.5'
48.8*
34. S1
N/A
45.0'
48.0*
51.0'
37.0'
47.0*
53.0'
57.0'
57.0'
N/A
DEPTH
TO 1120
31.5'
34.2'
33.7'
23.0'
33.9'
N/A
31.3'
34.1*
27.8'
29.2'
32.1'
30.2'
33.6'
35.5'
N/A
. VOLUME
PURGED
(GALLONS)
26
30
16.5
30
. 1
U/A
10
16.4
24
17
12
12.5
12.5
12
N/A
TURBIDITY
(NTU) COMMENTS
2.0
1.4
2.6
7.0
>100 Matrix spike (all but
Dloxln).
N/A Duplicate
7.4 Matrix aplke Dloxln
only
2.5
16
4.1
11
52
46
6.9
N/A Duplicate & Matrix
_  _ .
                                                                                                           aplka
C130
028
3/18/87
                                               2"
61.0'
                                                            36.7'
IS
                                                                     15

-------
TADI.F.  2  CON'T
FIELD MEASUREMENTS
WELL *
DATE
C132
3/19/87'

C134
3/19/87

C135
3/19/87

C137
3/19/87

cm
3/17/87


ens
3/17/87



C150
3/17/87


cue
3/17/87


IN SITU
t
1
2
3
I
2
3
1
2
3
1
2
3
1
2
3
4
1
2
3
4
5
1
2
3
4
1
2
3
4
TIME
09.36
09iSO
10i04
10i58
Ilil3
11.30
12.35
12.47
13.00
13.55
14,10
14.40


10.25
10.45
11.15
11.35
12.00
12,13
12.30
13.08
13.29
13,52
Uil6
14,33
15.04
15,34
16.00
GALLONS
PURGED
O.S
8.3
15.5
1
7
13
0.5
8 
IS
0
10
16













0
9
16
AS
pll
7.2
7.3
7.1
11.8
8.6
7.4
7.1
7.1
7.0
7.6
7.1
7.1
7.09
7.10
7.5
7.2
6.9
6.8
6.8
6.65
6.85
7.2
6.9
6.9
6.9
6.R5
6.75
6.7
6.7
CONDUCTIVITY
(ulio/c)
1240
1240
1225
2000
780
860
925
910
925
960
. 940
970
1600
1595
1420
1440
1660
1740
1780
1700
1740
1120
1150
1160
1140
1800
1860
1830
1930
TEMP

-------
FIELD MEASUREMENTS
WELL i
DATE
CUB
3/18/87


C149
3/18/87


C120
3/18/87


C123
3/18/87


GUI
3/19/87


CI24
3/19/87


C12S
3/19/87

t
IN SITU
i
I
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4*
1
2
3
4
1
2
3
4
TIME
09llO
09i29
lOiOO
10il9
10i39
10.57
11.11
11.39
I2i43
12.52
13.02
13.19
14.15
14.30
14,39
15.05
9.09
9.38
10.33
16il5
11.38
11.45
11.55
12.19
13.47
13.58
14.07
14.32
GALLONS
PURGED
0
10
24
AS
0
10
16
30
0
$.5
11.5
AS
0
9.5
14
AS
0
5
16
19
0
5
9.5
AS
0
6.5
12.0
AS
pll
7.3
7.1
7.1
7.1
7.15
.2
.1
.2
.0
.9
.0
.9
7.25
7.1
7.1
7.05
7.6*
7.0
7.1
6.8
7.3
7.9
7.2
7.2
7.3
7.0
6.9
6.9
CONDUCTIVITY
(U|.O/CM)
1050
1030
1050
1055
2500
2800
2600
2200
1770
1800
1780
1770
1460
1470
1460
1460
1180
1080
1170
1040
1290
1250
1300
1225
1070
1040
1260
1220
TEMP
(c>
9.0
10.5
10.5
10.2
10.0
10.7
10.9
10.7
10.7
11.1
11.0
10.9
10.2
10.9
11.1
11.1
10.6
11.5
11.9
12.2
11.4
11.5
11.5
11.6
11.5
11.9
11.9
11.8

-------
WELL *
DATE
G144
3/20/87
CT12
3/20/87
IN SITU
t
I
2
3
4
BS
TIKE
08i48
09*04
09i30
10il5
09  40
FIELD
GALLONS
PURGED
0
3.5
6.9
AS

MEASUREMENTS
pH
7.0
7.0
7.0
7.0
7.4
\
CONDUCTIVITY
(umhos/ca)
1790
1625
1S40
1420
990
TEMP

-------
           APPENDIX A
               SWLE MW25ES




FOR IftSK FCRCE mSFECHCN CF

-------
                                APPENDIX 2

               SUMMARY OF CONCENTRATIOHS FOR COMPOUNDS FOUND
                       IH GROUND-WATER AND SAMPLING
               BLANK SAMPLES AT SITE NO. 48;  ESL,  JOI.1ET.  1L
The following table lists the concentrations for compounds analyzed for
and found in samples at the site.  Table A2-I is generated by listing
all compounds detected and all tentatively identified compounds reported
on the organic Fora I. Part B.  All tentatively identified compounds
with * spectral purity greater than 850 are identified by name and
purity in the table.  Those with a purity of less than 850 are labeled.
unknown.

Ml concentrations are reported in yg/L.
                                   A2-1

-------
                                TABLE KEY
     A value without a flag indicates a result above the contract




     required detection limit (CKDL).








J    Indicates an estimated value.   This flag is used either when



     estimating a concentration for tentatively identified compounds




     where a 1:1 response is assumed or when the mass spectral data




     indicated the presence of a compound that meets the identification




     criteria but the result is less than the specified detection limit




     but greater than zero.  If the limit of detection is 10 yg and a



     concentration of 3 vg is calculated, then report as 3J.








B    This flag is used when the analyte is found in the blank as well as




     a sample.  It indicates possible/probable blank contamination and



    warns the data user to take appropriate action.
GU * ground-water




SW  surface-water




low and medium are indicators of  concentration.




                                   A2-2

-------

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-------
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-------
                 APPENDIX B




    EVALUATION CF THE CjQRLPI? GQORCL




HEE3AINING 10 THE ANALYSIS CF SAMPLES ERQM

-------
MEMORANDUM

DATE:        August 5, 1987

SUBJECT:     Evaluation of Quality Control Attendant to the Analysis of Samples
               from the Chemical Waste Management, Inc., ESL, Joliet, Illinois,
               Facility

FROM:        Ken Partymiller, Chemist
               PRC Environmental Management Inc.

THRU:        Paul H. Friedman, Chemist*

TO:           HWGWTF: Richard Steimle, HWGWTF*
               Gareth Pearson (EPA 8231)*
               Maxine Long, Region V
               Ken Jennings, HWGWTF
               John McGuire, Region V


     This memo summarizes the evaluation of the quality control data generated by
the Hazardous Waste Ground-Water Task Force (HWGWTF) contract analytical
laboratories (1).  This evaluation and subsequent conclusions pertain to the data
from the Chemical Waste Management, Inc., Environmental Sanitary Landfill, Joliet,
Illinois sampling effort by the Hazardous Waste Ground-Water Task Force.

     The objective of this evaluation is to give users, of the analytical data a more
precise understanding of the  limitations of the data as well as their appropriate use.
A second objective is to identify weaknesses in the data generation process for
correction. This correction may act on future analyses at this or other sites.

     The evaluation was carried out on information provided in the accompanying
quality control reports (2-5) which contain raw data, statistically transformed data,
and graphically transformed data.

     The evaluation process consisted of three steps.  Step one consisted of
generation uf a package which presented the results of quality control procedures,
including  the generation  of data quality indicators, synopses of statistical indicators,
and the results of technical qualifier inspections.  A report on the results  of  the
performance evaluation standards analyzed by the laboratory was also generated.
Step two was an independent examination of the quality control package and the
performance evaluation sample  results by members of  the Data Evaluation
Committee.  This was followed by a meeting (teleconference) of the Data  Evaluation
Committee to discuss the foregoing data and data presentations. These discussions
were to come to a consensus, if  possible, concerning the appropriate use of the data
within the context of the HWGWTF objectives. The discussions were also to  detect
and discuss specific or general inadequacies of the data and to determine  if these
are correctable or inherent in the analytical process.
* HWGWTF Data Evaluation Committee Member

-------
 Preface

     The data user should review the pertinent materials contained in the
 accompanying reports (2-5). Questions generated in the interpretation of these data
 relative to sampling and analysis should be referred to Rich Steimle of the
 Hazardous Waste Ground-Water Task Force.

 L   Sit* Overview

     The Chemical Waste Management, Inc. Joliet Environmental Sanitary Landfill
 (ESL) facility is located in Joliet, Illinois just outside the Joliet prison and along
 the banks of the Oes Plaines River.  The facility is presently closed as a result of
 contaminated ground water. The geology consists of a till layer or layers with an
 interspersed outwash sand layer overlying Silurian carbonate formations.  There are
 three series of wells at the facility.  The wells are designated "P", "G", and T* and
 are categorized chronologically. The "P" series of wells were the first wells  at the
 facility. They were poorly developed and are no longer used. The "G" series of
 wells are the present monitoring wells into the outwash sand and dolomite layers
 and they are supplemented by a "T"  series of wells into the till layer.  The facility
 has accepted all types of wastes.  Contaminants detected in the past include smaller
 aliphatic organics.

     Twenty-nine field samples were collected at this facility.  The samples included
 a field  blank (MQB029), a trip blank (MQB050), and two pairs of duplicate samples
 (well G117, samples MQB033 and MQB045 and well GI29, samples MQB035 and
 MQB051) as well  as  twenty-three'other field samples.  All samples were designated
 as low concentration ground-water samples.  All samples were analyzed for all
 HWGWTF Phase 3 analytes.

 II.   Evaluation of Quality Control Data and Analytical Data

 1.0  Metals

 1.1   Metals OC Evaluation

     Total and dissolved metal spike recoveries were calculated for twenty-four
 metals spiked into two samples (MQB033 and 035). Twenty-one total metal average
 spike recoveries from these samples were within the data quality objectives (DQOs)
 for this Program.  The total cadmium, lead, and thallium average spike recoveries
 were outside the DQO with values of 770, 152, and 73 percent, respectively.  One of
 the total iron  spike recoveries  and one  of the total magnesium spike recoveries
 were not calculated because the sample results were greater than four times the
 amount of spike added.  Six individual total metal spike recoveries were also outside
 DQO.  This information is listed in Tables 3-la and 3-2a of Reference 2 as well as
 in the following Sections.

     Twenty-four dissolved metals were also spiked into two samples  (MQB004 and
 012). Twenty of the twenty-four dissolved metal average spike recoveries were
 within the data quality objectives (DQOs) for  this Program.  Dissolved cadmium and
 lead average spike recoveries were outside DQO with values of 147 and 126 percent.
 Both of the dissolved calcium and dissolved magnesium and one of the dissolved
 sodium  spike recoveries were not calculated because the sample results were  greater
 than four times the amount of spike  added.  Three individual dissolved metal  spike
 recoveries from these samples were also outside DQO. These samples and  results
 are listed in Tables 3-1 b and 3-2b of  Reference 2 as well as in the following
Sections.

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     The calculable average relative percent differences (RPDs) for all metallic
analytes, with the exception of total arsenic, were within Program DQOs.  RPDs
were not calculated for about two-thirds of the metal analytes because the
concentrations of many of the metals in the field samples used for the RPD
determination were less than the contract required detection limit (CRDL) and  thus
were not required, or in some cases, not possible to be calculated.

     Required metal analyte analyses were performed on all samples submitted to
the laboratory.

     No sample contamination involving the metallic analytes was reported in the
laboratory blanks. Sampling blank contamination was found  in the  field blank and
will be discussed  below.

1.2  Furnace Metals

     The quality control results for the graphite furnace metals (antimony, arsenic,
cadmium, lead, selenium, and thallium) were generally acceptable.

     The total cadmium, lead, and thallium matrix spike recoveries  for spiked sample
MQB033 were outside DQO with values of 800, 224, and 71 percent, respectively.
The total arsenic and cadmium and the dissolved cadmium and lead matrix spike
recoveries for spiked  sample MQB03S were outside DQO with values of 65, 740, 176,
and 129 percent, respectively. As a trend, results for analytes with high spike
recoveries should be considered to be biased high and results for analytes with  low.
spike recoveries should be considered to be biased low. All results for total
arsenic, total thallium, and dissolved lead should be considered semi-quantitative
unless otherwise qualified. The non-detccts for total and dissolved cadmium and
total lead results  should be considered quantitative unless otherwise qualified.  All
positive results for  these analytes should be considered qualitative.

     The correlation  coefficients for the method of standard addition (MSA)
determination of total arsenic in samples MQB027, 043, and 046 were  below  DQO.
The correlation coefficients for the MSA determination of dissolved arsenic in
samples MQB031, 032, 035, 037, 038, and 053 were also below DQO.  The  total
arsenic  result for sample MQB027 and the dissolved arsenic results for samples
MQB032, 037, and 038 should be considered unusable. All other results for the
samples/analytes  mentioned in this paragraph should be considered qualitative.

     An MSA determination should have been performed on dissolved arsenic in
sample MQB027.  Results for dissolved arsenic in this sample  should be considered
qualitative.

     The duplicate RPD value for total arsenic in sample MQB033 was above DQO.
Total arsenic results should be considered semi-quantitative unless otherwise
qualified.

     Continuing calibration verifications (CCVs) for total antimony in samples
MQB027, 029, 041, and 050, dissolved cadmium in samples MQB027, 029, 037, 040,
041, 044, and 050, total selenium in samples MQB027, 029. 032, 039, 041, 047, 050,
and 056, and dissolved selenium in samples MQB030, 034, 043, 045, and 052 were
outside DQO limits.  The samples preceding the poor CCV were rerun  but the CCV
was not.  Results  for these samples should be considered semi-quantitative.

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     It should be noted that in several of the samples the dissolved arsenic results
were greater than the total arsenic results. The HWGWTF does not normally
require a dissolved metals analysis because EPA does not have a standardized
procedure for separating  dissolved from total metals.

     All dissolved antimony and thallium and total cadmium results should be
considered quantitative.  Total antimony, lead, and selenium, and dissolved arsenic,
cadmium, and  selenium results should be considered quantitative with exceptions.
All total thallium and dissolved lead results should be considered semi-quantitative.
Total arsenic results, with exceptions, should also be considered semi-quantitative.
Total antimony results for samples MQB027, 029, 041, and 050, dissolved cadmium
results for samples MQB027, 029, 037, 040, 041, 044, and 050, total selenium results
for samples MQB027, 029, 032, 039. 041,  047, 050, and 056, and dissolved selenium
results for samples MQB030, 034, 043, 045, and 052 should also be considered semi-
quantitative.  Total arsenic results for samples MQB043 and 046, dissolved arsenic
results for sample MQB027, 031, 035, and 053, and total lead  results for samples
MQB033, 034, 037, 045, 048, and 049 should  be considered qualitative.  Total  arsenic
results for sample MQB027, dissolved arsenic results for sample MQB032, 037, and
038, and total lead results for samples MQB028 and 035 should not be  used.  The
usability of all graphite furnace analytes is  summarized in Section 4.0 and 4.1 at the
end of this Report.

1.3  TCP Metals

     The matrix  spike recoveries for total aluminum and  dissolved tin in sample
MQB033 were outside DQO with  recoveries of 61 and 73 percent, respectively.
Trends of low  spike recoveries indicate a low bias in the data.  All results for
these analytes should be considered semi-quantitative.

     The low level (twice CRDL) linear  range check for all dissolved  beryllium,
chromium, cobalt, copper, nickel, silver,  vanadium, and  zinc results and certain  of
the results for  total beryllium, chromium, cobalt, copper, nickel, silver, vanadium,
and zinc exhibited low recoveries. See Section B5 of Reference 3 for a detailed
listing of analysis dates, samples  affected, and biases. The low level linear range
check is an analysis of a  solution with elemental  concentrations near the detection
limit. The range check analysis shows the accuracy which can be expected by the
method for results near the detection limits.  The accuracy reported for these
metals at these levels is not unexpected.

     Dissolved calcium, iron, magnesium, manganese, and sodium and  total chromium
contamination were found in the field blank (sample MQB029) at concentrations of
125,000, 1610, 71, 72,500.  9870, and 11 ug/L, respectively.  CRDLs for  these analytes
are 5000, 100,  15, 5000, 5000, and 10 ug/L, respectively. Due to this contamination,
all positive results greater than 10 times the level of contamination and all negative
results should be considered quantitative. All positive results between 5 and 10
times the highest level of contamination  should be considered qualitative and all
other results should  not be used.  Due to the high level of analytes found in  this
sample there is a possibility  that  this sample was  a mislabelcd field sample rather
than a blank.

     The internal control standard used  for the ICP  interference check solution
should have an established mean  and standard deviation before being  used as an
internal  control standard.

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     It should be noted that in several of the samples the dissolved aluminum,
sodium, and iron results were greater than the total metal results. As a result the
total and dissolved aluminum results for samples MQB028, 034, 035, 042, 043, 052,
and 055 and the total and dissolved sodium results for sample MQB028 should be
considered semi-quantitative. The total and dissolved sodium results for sample
MQB028 and the total and dissolved iron results for sample MQB044 should not be
used.

     All total barium, beryllium, calcium, cobalt, copper, magnesium, manganese,
nickel, potassium, silver, tin, vanadium, and zinc results should be considered
quantitative. All dissolved barium, beryllium, chromium, cobalt, copper, nickel,
potassium, silver, vanadium, and zinc results should be considered quantitative.
Total chromium, iron, and sodium and dissolved aluminum results, all with
exceptions, should be considered quantitative.  Dissolved calcium results for samples
MQB029 and 050, dissolved iron results for samples MQB029, 033, 034, 040, 041, 045,
050, 052, and 056, dissolved magnesium results for samples MQB029, 041, and 050,
dissolved manganese results for samples MQB029, 041, 048, and 050, and dissolved
sodium results for samples MQB029, 033, 045, 050, and 052 should also be considered
quantitative. All total aluminum and dissolved tin results should be considered
semi-quantitative. Dissolved aluminum results for samples MQB028, 034, 035, 042,
043, 052, and 055, total  iron results for sample MQB044, and  total sodium results for
samples MQB028 and 047 should also be considered semi-quantitative. Dissolved
sodium results for sample MQB047 should be considered qualitative. The  dissolved
metal results for calcium, iron, magnesium, manganese, and sodium, all with
exceptions listed above, and the total chromium results for samples MQB031, 033,
037, and 052 should not be used. The usability of all total and dissolved ICP. metal
analytes is summarized  in Section 4.2 and 4.3 at the end of this Report.

1.4  Mercury

     AH mercury results should be considered  quantitative with an  acceptable
probability of false negatives.

2.0  Inorganic and Indicator Analvtes

2.1  Inorganic and Indicator Analvte OC Evaluation

     The average spike recoveries of all of the inorganic and indicator analytes,
except for  chloride, were within the accuracy DQOs. Accuracy DQOs have not been
established for the bromide, fluoride, nitrite nitrogen, and sulfide matrix spikes.

     Average RPDs for all inorganic and indicator analytes were within Program 
DQOs. The RPDs were  not calculated if either one or both of the duplicate values
were less than the CRDL. Precision DQOs have not been established for bromide,
fluoride, nitrite nitrogen, and sulfide.

     Requested analyses were performed on all samples for the inorganic and
indicator analytes.

     No laboratory blank contamination was reported for any inorganic or indicator
analyte. TOX contamination was found in the field blank at a concentration of 6
ug/L. The TOX CRDL  is 5 ug/L.

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     It should be noted that in several of the samples the dissolved aluminum,
sodium, and iron results were greater than the total metal results. As a result the
total and dissolved aluminum results for samples MQB028, 034, 035, 042, 043, 022,
and 055 and the total and dissolved sodium results for sample MQB028 should be
considered semi-quantitative. The total and dissolved sodium results for sample
MQB028 and the total and dissolved iron results for sample MQB044 should not be
used.

     All total barium, beryllium, calcium, cobalt, copper, magnesium, manganese,
nickel, potassium, silver,  tin, vanadium, and zinc results should* be considered
quantitative. AH dissolved barium, beryllium, chromium, cobalt, copper, nickel,
potassium, silver, vanadium, and zinc  results should be considered quantitative.
Total chromium, iron, and sodium and dissolved aluminum results, all with
exceptions, should be considered quantitative. Dissolved calcium results for samples
MQB029 and 050, dissolved iron  results for samples MQB029, 033, 034, 040, 041, 045,
050, 052, and 056, dissolved magnesium results for samples MQB029, 041, and 050,
dissolved manganese results for samples MQB029, 041, 048, and  050, and dissolved
sodium results for samples MQB029, 033, 045, 050, and 052 should also be considered
quantitative. All total aluminum and dissolved tin results should be considered
semi-quantitative. Dissolved aluminum results for samples MQB028, 034, 035, 042,
043, 052, and 055, total iron results for sample MQB044, and total sodium results for
samples MQB028 and 047 should also be considered semi-quantitative.  Dissolved
sodium results for sample MQB047 should be considered qualitative. The dissolved
metal results for calcium, iron, magnesium, manganese, and sodium, all with
exceptions listed above, and the  total chromium results for samples MQB031, 033,
037, and 052 should  not be used.  The usability of all total  and  dissolved ICP metal
analytes is summarized in Section 4.2  and  4.3 at the end of this Report.

1.4  Mercury

     All mercury results should  be considered quantitative with an acceptable
probability of false negatives.

2.0  Inorganic and Indicator Analvtes

2.1  Inorganic and Indicator Analvte OC  Evaluation

     The average spike recoveries of all of the inorganic and indicator analytes,
except for chloride,  were within the accuracy DQOs. Accuracy DQOs have not been
established for the bromide, fluoride,  nitrite nitrogen, and sulfide matrix spikes.

     Average RPDs  for all inorganic and indicator analytes were within  Program
DQOs.  The RPDs were not calculated if either one or both of the duplicate values
were less  than the CRDL.  Precision DQOs have  not  been established for  bromide,
fluoride, nitrite nitrogen, and sulfide.

     Requested analyses  were performed on all samples for the  inorganic and
indicator  analytes.

     No laboratory blank contamination was reported for any inorganic or indicator
analyte.  TOX contamination was found in the field  blank at a  concentration of 6
ug/L. The TOX CRDL is 5 ug/L.

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 23.  Inorganic and Indicator Analvte Data

      All results for cyanide, bromide, fluoride, sulfate, sulfide, total phenols, TOC,
 and POX should be considered quantitative with an acceptable probability of false
 negatives.  The laboratory erroneously listed the instrument report date for the ion
 chromatography analytes (bromide, chloride, fluoride, nitrate and nitrite nitrogen,
 and sulfate as 3/18/87 rather than 3/24/87.

      The spike recovery for chloride from sample MQ6035 was outside DQO with a
 value of 114 percent. All chloride results should be considered semi-quantitative.

      The holding times for  the nitrate and nitrite nitrogen determinations ranged
 from 3 to 5 days from receipt of the samples which is longer than the  recommended
 48 hour holding time for unpreserved samples.  All nitrate and nitrite  nitrogen
 results should be considered semi-quantitative.

      Calibration verification standards for POC were not analyzed.  A POC spike
 solution was  run during the analytical batch but the "true" value of the spike was
 not provided by the laboratory.  EPA needs to supply the inorganic laboratory with
 a POC calibration verification solution.  Until then, the instrument calibration can
 not be assessed.  The POC results should be considered  qualitative.

      TOX contamination was found in the field blank (MQB029) at a concentration
 of 6 ug/L. The TOX CRDL is 5 ug/L. Due to this contamination, all  positive TOX
 results five times the  higher concentration or less should not be used, all TOX
 results between five and ten times the higher of the concentrations should be
 considered qualitative, and all results ten times the level of contamination or
 greater, as well as all  negative results, should be considered quantitative.
 Therefore, TOX results for samples MQB028, 029, 030. 031, 032, 034, 035, 037, 038,
 039, 040, 041, 044, 049, 050, and 053 should be considered quantitative  and all other
 TOX results should not be used.  Results for TOX in field duplicate sample pair
 MQB033/045  were in poor agreement. The comparative precision of field duplicate
 results is not  used in the usability evaluation of sample  results. It is not possible
 to determine  the source of this imprecision.  The poor precision may be reflective
 of actual sample to sample variation rather than analytical precision.

 3.0   Qrganics and Pesticides

 3.1   Organic OC Evaluation

     All matrix spike average recoveries were within established Program DQOs for
 accuracy.  Individual matrix spike recoveries which were outside the accuracy DQO
 will be discussed in the appropriate Sections below.

     All surrogate spike average recoveries, with the exception of the organo-
 phospnorous herbicide surrogates which were neither required nor analyzed, were
 within DQOs  for accuracy.  No accuracy DQO has been set for the 2,4-DB
 chloroherbicide surrogate.  Individual surrogate spike recoveries which  were outside
 the accuracy DQO will be discussed in the appropriate Sections below.

     All reported matrix spike/matrix spike duplicate average RPDs. with the
exception of pcntachlorophcnol, were within Program DQOs for precision.  Individual
matrix spike RPDs which were outside the precision DQO will be discussed  in the
appropriate Sections below.

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     All average surrogate spike RPDs were within DQOs for precision.  No
surrogate standard was used or required for the organo-phosphorous herbicide
analysis. 2,4-DB was used as a chloroherbicide surrogate.

     Requested  analyses were performed on all samples submitted to the laboratory.

     Laboratory (method) and sampling blank contamination was reported for
organics and is discussed in  Reference 4 as well as the appropriate Sections below.

     Detection limits for the organic fractions are summarized in Reference 4 as
well as the appropriate Sections below.

3.2  Volatile^

     Acetone contamination was found in  sampling blanks MQB029 and  050 at
concentrations of 2 and 11 ug/L.  Additionally, acetone contamination was found in
laboratory (method) blanks MB-1, MB-3, MB-4, and MB-6 at concentrations of 1 to
5 ug/L.  The acetone CRDL  is 10 ug/L.  The source of this contamination is
probably in the analytical laboratory. AH  positive acetone results should not be
used due to this blank contamination.

     Methylene  chloride contamination was found in sampling blanks MQB029 and
050 at concentrations of 7 and 18 ug/L. Additionally, laboratory (method) blanks
MB-2 through MB-6 contained methylene chloride contamination.  This common
laboratory contaminant was  present at concentrations of 1  to 14 ug/L. The
methylene chloride CRDL is 5 ug/L. All positive methylene chloride results should
not be used due to this blank contamination.

     The analytical laboratory continues to fail to use the contract specified
primary  ion for the analysis of chloroethane on the Finnigan OWA instrument.
They claim  that there is an  interference with vinyl chloride and therefore they use
a secondary ion. The detection limit should not have been affected.

     There  was no quantitation report included for the additional (Appendix IX)
volatile compounds.  The laboratory accidentally destroyed the magnetic tape with
this information. According to the laboratory, no Appendix IX compounds were
present  in the sample.

     Estimated  method detection limits were CRDL for all samples.  All  positive
acetone and methylene chloride results should not be  used due  to sampling and
laboratory  (method) blank contamination.  The probability of false negative results
is acceptable.  The volatile results should be considered quantitative.

3.3  Semivolatiles

     The analytical  laboratory exceeded the semivolatilc 40 day holding time
between extraction and analysis  for eight of the semivolatile samples (MQB046, 048,
049, 050, 051, 052, 053, and  055).  Holding  times for these samples ranged from 4 to
30 days in  excess of the permitted 40 day holding time between extraction and
analysis.

     The acid matrix spike  and matrix spike duplicate recoveries for 4-nitrophenol
were outside DQO.

     The RPD  for the matrix spike/matrix spike duplicate recoveries for N-
nitrosodi-n-propylaminc and pcntachlorophcnol were above DQO.

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      The semivolatile laboratory (method) blanks contained a variety of compounds
 including bis(2-ethylhexyl)phthalate (2 ug/L), 5-methyl-2-hexanone (10 ug/L), di-n-
 butylphthalate (1 ug/L), and four unknowns (10 to 20 ug/L).  The bis(2-
 cthylhexyl)phthalate and di-n-butylphthalate CRDLs are 10 ug/L.  Bis(2-
 ethylhexyl)phthalate was also found in the trip blank at a concentration of 3 ug/L.
 No positive bis(2-ethylhexyl)phthalate results should be used. Phenol was found in
 the field blank at a concentration of 6 ug/L. No positive phenol or di-n-
 butylphthalate results were reported in any other field samples.

      An unknown semivolatile compound was detected but not confirmed or reported
 as a tentatively identified compound (TIC) at the approximate retention time of 2-
 hexanone in many of the samples.  The laboratory claims that they are not required
 to report compounds which elute before the first surrogate compound and that the
 TIC probably represents an artifact from the extraction.

      Due to a dilution factor of 2.0 for all samples, the  estimated detection limits
 for the semivolatiles were approximately twice the CRDL.  The semivolatile data are
 acceptable and the results should be considered semi-quantitative with exceptions.
 Results for samples MQB049, 053 and 055, with the exception of the  positive bis(2-
 ethyihexyl)phthalate and phenol results, should be considered unreliable. All
 positive bis(2-ethylhexyl)phthalate and phenol  results, with the exception of the
 phenol result for sample MQB029, should not be used due to laboratory and/or
 sampling blank  contamination.

 3.4    Pesticides

     The pesticide determinations were conducted on three different analytical
 systems. On two of these systems the retention time of kepone falls within  the
 retention time window of endosulfan sulfate. Additionally, kepone carryover was
 observed in one of these systems for pesticide standard EVALA.

     The percent difference for the dibutylchlorendate retention time shift was
 above DQO for several capillary column analyses (sample MQB037 and standard
 AR1660). This was  not judged to affect the data usability.

     No pesticides were detected.  The estimated method  detection limits for all
 pesticides analyses is the CRDL. The pesticides results should be considered
 quantitative.

 3.5  Herbicides

     The herbicides for which the laboratory analyzed include only 2,4-D, 2,4,5-T,
 2,4,5-TP, chlorobcnzilate, phorate, disulfoton, parathion, and famphur.
     ^    surrogates were included for the organo-phosphorous herbicides.  2,4-DB
was included as a surrogate in some of the chloroherbicide samples but was not
used with all of the samples. Surrogate recovery was poor for the first extraction.
A second extraction was performed and surrogate recoveries ranged from  85 to 120
percent.

     The quality of the chlorohcrbicide chromatograms was not sufficient to allow
the tentative identification and confirmation of these compounds. Contamination
was observed in the method blanks and  samples which  was within the retention time
windows of the target analytcs. The electron capture detector settings were not
sufficiently sensitive.

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     The chlorobenzilate recoveries from matrix spike and matrix spike duplicate
sample MQB047 were 8 and 22 percent, respectively, with an average RPD of 93
percent. No DQO limits have been established for chlorobenzilate.

     No herbicides were detected.  The organo-phosphorous herbicide results should
be considered qualitative due to the lack of surrogates. The estimated method
detection limits were the CRDL for the organo-phosphorous herbicides.  The
chloroherbicide results should be considered unreliable due to blank contamination
and the absence of surrogate analyses.

3.6  Dioxins and Dibenzofurans

     Dioxin and dibenzofuran spike recovery from the spiked samples ranged from
76 to 114 percent which is considered to be acceptable accuracy. No performance
evaluation standard was required or evaluated for dioxins and dibenzofurans.
Analytes were not detected in the laboratory duplicate samples so laboratory
precision could not be evaluated.  Required dioxin/dibenzofuran analyses were
performed on all samples submitted to the laboratory. No dioxin or dibenzofuran
compounds were detected in the field samples and no contamination  was found in
the laboratory (method) or field blanks.

     Two of the spiked samples (MQ8035 and 043) were field samples.  Neither of
these samples was analyzed prior to spiking. It is impossible to verify that low
levels of target analytes were not present in these samples.  Sample MQB035 was
one-half of a field duplicate sample and no target analytes were found in its
duplicate. False negatives are a possibility in sample MQB043.

     Due to a method modification supplied to the laboratory by  the U.S. EPA
Sample Management  Office, the column performance check solution was not analyzed
by the laboratory.

     The percent valley between the internal  standard (carbon-13 labeled 2,3,7,8-
TCDD) and  the recovery standard (carbon-13  labeled 1,2,3,4-TCDD) was above DQO
for two standard analyses.

     Samples MQB020, 033, 034, 042, 045D (duplicate), 051, 052, 056 and blank
CC*123597 did not meet the DQO requirement for resolution of the percent valley
being less than or equal to 25 percent.

     Chlorinated  organics which might be considered to indicate the possible
presence of chlorinated dioxins and dibenzof urans were not detected in  the sampling
and analysis at this facility.

     The dioxin and dibenzofuran results should be considered  to be semi-
quantitative. The probability of false negative results is acceptable.  Dioxin and
dibenzofuran detection limits should be considered to be the normal method
detection limits.

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 III. Data Usability Summary

 4.0  Graphite Furnace Metals. Total (Section 1.2)

 Quantitative:       all cadmium results; antimony, lead, and selenium results with
                    exceptions
 Semi-quantitative:   all thallium results; arsenic results with exceptions; antimony
                    results for samples MQB027, 029, 041, and 050; selenium results
                    for samples MQB027, 029, 032, 039, 041, 047, 050, and 056
 Qualitative:         arsenic results for samples MQB043 and 046; lead results for
                    samples MQB033, 034, 037. 045, 048, and 049
 Unusable:           arsenic results for sample MQB027; lead results for samples
                    MQB028 and 035

 4.1  Graphite Furnace Metals. Dissolved (Section 1.2)

 Quantitative:       all antimony and thallium results; arsenic, cadmium, and
                    selenium results with exceptions
 Semi-quantitative:   all lead results; cadmium results for samples MQB027. 029, 037,
                    040, 041, 044, and 050
 Qualitative:         arsenic results for samples MQB027, 031, 035, and MQB053
 Unusable:           arsenic results for samples MQB032, 037, and 038

 4.2  TCP Metals. Total  (Section  1.3)

 Quantitative:       all barium, beryllium, calcium, cobalt, copper, magnesium,
                    manganese, nickel, potassium, silver,  tin, vanadium, and zinc
                    results; chromium, iron, and sodium results with exceptions
 Semi-quantitative:   all aluminum results; iron results for sample MQB044;  sodium
                    results for samples MQB028 and 047
 Unusable:           chromium results for samples MQB031, 033, 037, and 052

 4.3  TCP Metals. Dissolved (Section 1.3)

 Quantitative:       all barium, beryllium, chromium, cobalt, nickel, potassium,
                    silver, vanadium, and  zinc results; calcium results for samples
                    MQB029 and 050; iron results for samples MQB029, 033, 034,
                    040, 041, 045, 050, 052, and 056; magnesium results for  samples
                    MQB029, 041, and 050; manganese results for samples MQB029,
                    041, 048, and 050; sodium results for  samples MQB029,  033 045
                    050, and 052
 Semi-quantitative:   all tin results; aluminum  results for samples MQB028, 034  035
                    042,  043, 052, and 055
 Qualitative:         sodium results for sample MQB047
 Unusable:           calcium, iron, magnesium, manganese, and  sodium results with
                    exceptions

4.4 Mercury (Section  1.4)

Quantitative:        all mercury results

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4.5 Inorganic and Indicator Analvfes (Section

Quantitative:        all cyanide, bromide, fluoride, sulfate, sulfide, total phenols,
                    TOC, and POX results; TOX results for samples MQB028, 029,
                    030, 031, 032, 034, 035, 037, 038, 039, 040, 041, 044, 049, 050,
                    and  053
Semi-quantitative:   all chloride and nitrate and nitrite nitrogen results
Qualitative:         all POC results
Unusable:           TOX results with exceptions

4.6 Organic* (Section 3.2  through 3.5)

Quantitative:        volatile results with exceptions; all pesticides results
Semi-quantitative:   semivolatile results with exceptions
Qualitative:         all organo-phosphorous herbicide results
Unreliable:          semivolatile results for samples MQB049, 053,  and 055;
                    all chloroherbicide results
Unusable:           all positive acetone and methylene chloride (volatiles) results;
                    all positive phenol (a semivolatile) results except for sample
                    MQB029; all positive bis(2-ethylhexyl)phthalate (a semivolatile)
                    results
                       

4.7  Dioxins and Dibenzofurans (Section 3.6)

Semi-quantitative:   all dioxin and dibenzofuran results

IV. References

1.   Organic Analyses:    EMSI
                          4765 Calle Quetzal
                          Camarillo, CA 93010

     Inorganic and Indicator Analyses:
                          Centec Laboratories
                          P.O. Box 956
                          2160 Industrial Drive
                          Salem, VA 24153
                          (703) 387-3995

     Dioxin/Dibenzofuran Analyses:
                          CompuChem Laboratories, Inc.
                          P.O. Box 12652
                          3308 Chapel Hill/Nelson Highway
                          Research Triangle Park, NC  27709
                          (919) 549-8263


2.   Draft Assessment of the Usability of the Data Generated  for Case I-2363HQ,
     Site 48, ESL, Joliet,  IL, 6/17/87, Prepared by Lockheed  Engineering and
     Management Services Company,  Inc., for the US EPA Hazardous Waste Ground-
     Water Task Force.

3.   Draft Inorganic Data Usability Audit Report, for  Case I-2363HQ, ESL, Joiict,
     IL, Prepared by Laboratory Performance Monitoring Group, Lockheed
     Engineering and Management Services Co., Las Vegas, Nevada, for US EPA,
     EMSL/Las Vegas, 6/15/87.

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