JuJy 1986 EPA-530/SW-86-018
Hazardous Waste Ground-Water
Task Force
Evaluation of
Casmalia Resources Disposal Facility
Casmalia, California
&EPA
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
215 Fremont Street
San Francisco, Ca. 94105
July 9, 1986
UPDATE OF THE HAZARDOUS WASTE GROUND WATER TASK FORCE EVALUATION
OF CASMALIA RESOURCES, CASMALIA, CALIFORNIA
The United States Environmental Protection Agency's Hazardous
Waste Ground Water Task Force (Task Force) in conjunction with
the State of California Department of Health Services, State
Water Resources Control Board, and Regional Water Quality Control
Board conducted an evaluation of the ground water monitoring
program at the Casmalia Resources disposal facility located near
Casmalia, California. Onsite field inspections were conducted
between October 21-30, 1985 and November 18-21, 1985. The
evaluation of the Casmalia Resources facility focused on (1)
determining if the facility was in compliance with applicable
regulatory ground water requirements and policies under the
Resource Conservation and Recovery Act (RCRA), (2) determining
if hazardous waste constituents were present in the ground water,
and (3) providing information to assist EPA in determining if the
facility meets EPA requirements for waste management facilities ^
receiving wastes from response actions conducted under the Federal
Superfund program.
Casmalia Resources is one of 58 facilities that are to be
evaluated by the Task Force. The Task Force effort came about in
response to recent concerns by Congress and the public as to
whether operations of hazardous waste treatment, storage and
disposal facilities are complying with the state and Federal
ground water monitoring regulations.
The results of the chemical analysis of ground water samples
collected from existing monitoring wells at the facility indicated
low levels of organic constituents in several off-site and on-site
wells. Additional work will be necessary before it can be determined
whether the source of these contaminants is from well construction
materials and methods, sampling and analysis errors, or ground
water contamination.
The additional work needed must be performed by Casmalia
Resources in accordance with State and Federal requirements for a
ground water quality assessment program. If the assessment indi-
cates off-site ground water contamination to be present, the
facility will be required to take corrective measures.
In accordance with ground water monitoring permit requirements,
a facility's monitoring system must be capable of immediately
detecting a release of hazardous waste constituents from a regulated
unit. Under the current EPA permitting standards for ground water
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monitoring, Casmalia Resources must upgrade and improve their
ground water monitoring program in order to fully comply with
applicable requirements. The facility is currently conducting an
extensive hydrogeologic investigation of the site as part of its
RCRA Part B permit application process. The existing ground water
monitoring system will be upgraded based on the results of this
investigation. This work is being conducted in response to a
Part B application Notice of Deficiency (NOD) issued by EPA and
the State of California in March 1986. EPA and the State of
California are currently reviewing the work completed to date and
proposed work, as part of the NOD response and hazardous waste
management permitting process. Installation of the upgraded
ground water monitoring system is expected to be completed by
July 1987. The results of the Task Force investigation support
the need to complete these activities as planned.
Task Force sampling personnel worked with the facility and
their contractor after the investigation towards revising the
facility's field sampling and analysis procedures. Implementation
of the revised sampling procedures has been in effect since
February 1986. EPA observed the May 1986 RCRA ground water
sampling episode at the facility and found their practices to be
greatly improved. They appeared to be in full compliance with
current EPA sampling standards. The facility is required to
submit a revised Sampling and Analysis Plan by August 1986 in
accordance with the March 1986 NOD. :
Based on the Task Force investigation at this facility the
following activities are necessary:
1. The facility should begin a ground water assessment program
to determine the presence and source of:
a. Tetrahydrofuran in wells C6B, C1B, C2M, WS4, A2M, C4M,
A2B, and CpH.
b. Elevated levels of TOX in wells A1B, C4M, and A2B,
including a complete pesticides scan.
c. Dichloroethane and Phthalate in wells B3B and C5.
d. pH values in wells C1B, C6B, and CpH.
e. Metals levels in wells CpH, A1B, B3B, and C6B.
2. Redevelop or replace existing monitoring wells, as necessary,
after completion of a site characterization.
3. Conduct statistical evaluation of heavy metals to determine
background levels and statistical differences.
4. Provide an updated Sampling and Analysis Plan that identifies
the procedures currently being used by the facility.
5. Determine the degree of hydraulic continuity between the
facility and nearby ground water basins.
6. Determine the effect of the surface impoundments on local
hydrology.
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7. Determine the effectiveness of. the barrier dams to impede
ground water flow.
8. Develop a statistical evaluation method to ascertain when
statistically significant ditterences occur between background
and downgradient ground water quality.
Technical aspects of items 2 thru 8 are being addressed
through the NOD process. California Department of Health Services
(DOHS) and Casmalia Resources are currently negotiating a settlement
of a DOHS Directors Order issued in December: 1984. The State is
attempting to incorporate the above recommendations into a Consent
Agreement. EPA and DOHS coordinated enforcement action will
continue to insure full implementation of all of the above items.
In addition, EPA and the State will continue to work with the
facility to bring the ground water monitoring system into compliance
with 40 CFR Part 264 for permitting purposes.
This concludes the Hazardous Waste Ground Water Task Force
evaluation of the Casmalia Resources facility.
Mark G. Filippini
U.S. Environmental Protection Agency
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EPA-530/SW-86-018
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUND WATER TASK FORCE
GROUND WATER MONITORING EVALUATION
CASMALIA RESOURCES DISPOSAL FACILITY
CASMALIA, CALIFORNIA
July 1986
Mark G. Filippini
Project Leader
U.S. Environmental Protection Agency
Region 9
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CONTENTS
page
I. EXECUTIVE SUMMARY 1
A. INTRODUCTION 1
1 Task Force Objectives * 1
2 Participants 2
3 Facility Background/Location 3
B. SUMMARY OF FINDINGS AND CONCLUSIONS 5
1 Ground Water Monitoring Program During Interim Status 6
2 Proposed Ground Water Monitoring Program 10
3 Task Force Sampling Data 11
4 Conclusions 12
II. TECHNICAL REPORT 14
A. BACKGROUND 14
1 Site History 14
2 Enforcement Actions 16
3 Adjacent Land Use 17
B. INVESTIGATIVE METHODS 18
1 Facility Inspection/Record Review 18
2 Laboratory Audits and Inspections 19
3 Sampling Audits 20
4 Sampling Program 21
C. WASTE MANAGEMENT UNITS & OPERATIONS 22
1 Waste Management Units " 22
2 Facility Operations 23
D. SITE GEOLOGY/HYDROGEOLOGY 26
1 Geomorphology 26
2 Geology 28
3 Hydrogeology 28
4 Climate 32
(continued)
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II. (Continued)
E. GROUND WATER MONITORING SYSTEM
page
33
1
2
3
4
5
6
7
State/Interim
Network
Status
Monitoring Requirements
Current Monitoring Well
Well Construction
Site Characterization
Sampling & Analysis Plan and Field Procedures
Facility Water Quality Analysis &^Data Quality Assessment
Interim Status Ground Water Monitoring Data
1 Initial Submittals
2 Deficiency Notices
3 Revised Proposals
4 Current Status
G. TASK FORCE DATA COLLECTION/RESULTS
1 Sample Collection Methods
2 Limitations of Data
3 Results of Task Force Data
33
33
35
42
43
45
46
F. GROUND WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT 48
48
48
52
54
55
55
62
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REFERENCES
68
APPENDICIES
APPENDIX A Analytical Parameters for Ground Water and
Leachate Samples
APPENDIX B Table of Water Level Measurements from November
1985 Task Force Sampling
APPENDIX C Contractual and Actual Laboratory Limits of
Quantification for Organic Compounds
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I. EXECUTIVE SUMMARY
I. A. INTRODUCTION
1. Task Force Objectives
This report summarizes the results of investigations
conducted during October and November 1985 at the Casmalia
Resources disposal facility located near Casmalia, California.
The Administrator of the Environmental Protection Agency
(EPA) established a Hazardous Waste Ground Water Task Force
(Task Force) to evaluate the level of compliance with ground
water monitoring requirements at commercial off-site treatment
storage and disposal (TSD) facilities and address the causes
of non-compliance. The Task Force comprises personnel from
EPA Headquarters core team, Regional offices and the states.
This investigation was conducted on behalf of the Task Force
by Region 9 and represented the first Region-lead investiga-
tion nationwide.
The principal objectives of the inspection at Casmalia
Resources were to determine the level of compliance with the
requirements of 40 C.F.R. Part 265, Subpart F - Ground Water
Monitoring, determine if the ground water monitoring program
described in the Resource Conservation and Recovery Act (RCRA)
Part B Permit application for the Casmalia facility was in
compliance with Part 270.14(c), and determine if hazardous
waste constituents have migrated into ground water around
the facility.
The Casmalia facility has received wastes from Superfund
sites where response actions are being conducted under the
Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA P.L. 96-510). Under current policy,
specific land disposal units used for Superfund wastes must be
in compliance with the Part 265 ground water monitoring
requirements.* The results of this investigation will
determine the ability of this site to meet the policy's
requirements.
The specific objectives of the investigation were to
determine if:
1. The facility has in place a ground water monitoring system
capable of meeting RCRA 40 CFR Parts 265 and 264 ground
water monitoring requirements.
2. The wells in place at the facility have detected any
contamination.
3. Designated RCRA monitoring wells are properly located
and constructed.
* May 6, 1985 memorandum from Jack McGraw on "Procedures for
Planning and Implementing Off-Site Response".
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4. Casmalia has developed and is following an adequate plan
and procedures for ground water sampling and analysis.
5. The facility's ground water laboratory is producing
accurate and precise results.
6. The ground water quality assessment program outline
is adequate.
7. Record keeping and reporting procedures for ground water
monitoring are adequate.
Since these objectives required both in-field and in-
office investigations and reviews, and the expertise of
sampling, laboratory (analysis), and geologic personnel, the
investigation was conducted in several discrete components.
In-depth record reviews and interviews of facility personnel
were conducted by the project leader, Mark Filippini, EPA
Region 9 and Donald Shosky, on detail to the Task Force from
EPA Region 8. Sampling of 16 facility wells, direction of
the Versar Inc. contract sampling team, and the audit of
facility sampling procedures was conducted by Peter Rubenstein
of the Field Operations Branch, EPA Region 9. Laboratory
audits of both on and off-site facility and contract labs
were conducted by Kevin Wong, also of EPA Region 9. Analyses
of ground water samples for 194 organic and inorganic parameters
were conducted through the EPA Contract Laboratory Program
(CLP). Organic parameters were run by California Analytical
Laboratories of Sacramento, California. Inorganic parameters
were run by Rocky Mountain Analytical of Denver, Colorado.
A complete Project Plan which incorporates a Sampling
Plan for sampling of the facility wells, a Laboratory Audit
Plan for the audit of both on and off-site laboratory and a
Sampling Audit Plan for the audit of facility sampling
procedures is incorporated into this report by reference and
not included in whole.
2. Participants
Participants in the Task Force investigation included
Regional, Task Force, Headquarters, and State personnel.
Aside from Filippini, Shosky, Rubenstein, and Wong mentioned
above as project and task leaders, 11 other State, Regional,
and contract personnel were involved. Mark Kamiya, the EPA
permit writer for the site, was present for initial facility
personnel interviews and data gathering and record reviews.
Messers Jim Foster, Michael Grasso, and Don Paquette repre-
sented the contract sampling team for Versar, Inc., of
Springfield, Virginia.
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All four California State regulatory agency offices were
represented at the initial organizational and kickoff meetings
and at various times throughout the field investigations.
Department of Health Services (DOHS), Los Angeles, and Regional
Water Quality Control Board (RWQCB), San Luis Obispo, had
representatives present throughout the entire investigation.
Steve Lavinger, Maxine Richey, and Nick Sauer represented
the DOHS-LA office. Eric Gobler and Vern Jones were present
from RWQCB, San Luis Obispo. Elizabeth Babcock and Mike
Sorensen from State Water Resources Control Board and DOHS,
Sacramento, respectively, were also present. All parties
were part of the report review team and their input is
incorporated into this report.
3. Background
Casmalia Resources operates a 250-acre commercial Class I
waste management facility which includes five RCRA landfills
and one TSCA landfill, 43 RCRA surface impoundments, and one
treatment unit (i.e. wet air oxidation). The landfills
contain solvents and pesticides, acids, metal sludges, and
alkaline and cyanide wastes. The wastes are segregated into
different landfills depending upon compatibility characteristics,
In the past, containerized liquid wastes were also put into "
the landfills. The land application unit handles oil field
sludges, sewage sludges, drilling muds, and storm waters
mixed with hazardous wastes. Several land application units
are operated to dewater oil field sludges and sewage sludges,
and to evaporate storm waters. The surface impoundments
contain oil field wastes, metal finishing wastes, agricultural
wastes, acid/alkaline wastes, and storm water runoff. As of
1985, Casmalia handled approximately 536,200,000 pounds of
liquids and 48,700 cubic yards of solids yearly.
The facility began operation in 1972 under RWQCB Waste
Discharge Requirements as a Class I site for oil field waste
disposal, owned and operated by Hunter Resources of Santa
Barbara, California. The facility received a State DOHS
permit in 1979, and attained interim status in 1980 to
handle all hazardous wastes listed in 40 C.F.R. Part 261 and
PCB's under a Toxics Substance Control Act (TSCA) permit.
Casmalia Resources is located in the south-central coast
area of California approximately 50 miles north of Santa
Barbara, California, halfway between San Francisco and Los
Angeles (Figure 1). The facility lies 4 miles from the
Pacific Coast and 10 miles south of Santa Maria, California
(population 47,000). The town of Casmalia (population 250)
lies about 2 miles to the south of the site. The site is
about 2 miles south of State Highway 1 on Black Road. The
-Class I site occupies approximately 250 acres of a 4,300-
acre undeveloped land holding.
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Figure 1. FACILITY LOCATION MAP
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Background data for interim status were collected by the
facility in July/August, September, October, and November 1984
as part of the September 1984 Consent Agreement. Statistical
analysis of ground water data was run on the May 1985 and
November 1985 data. The May 1985 data indicated statistically
significant increases in Specific Conductance (SpC) in wells
A2B and B3M, total organic halides (TOX) in well B3M, and pH
in well CIB. The November 1985 data indicated two wells
showing significant increases in pH, wells CIB and C6B. CIB
is the only well showing a recurrence ol a statistically
significant increase of an indicator parameter from May 1985
to November 1985.
The organic analysis conducted by the facility during
detection monitoring indicated the presence of several com-
pounds. Tetrahydrofuran (THF) was reported at levels ranging
from 10 to 200 ppb in five wells in the July 1984 sampling.
THF levels were attributed by the facility to the PVC glue
used for well casing construction. However, these high
levels may not be completely attributed to glues especially
if purging was conducted properly. Trihalomethane (THM)
compounds such as chloroform and bromoform have been reported
for all sampling periods. Other organic compounds reported
for the six sampling episodes were a phthalate compound, '
methylene chloride, and caprolactam, detected in the May 1985
analyses.
Although all the above compounds are accepted in the
facility waste streams, the facility attributes their presence
to the following well construction and sampling methods: The
presence of THM is attributed to the use of sodium hypochlorite
which was added to several wells to breakdown the organic
drilling mud used during well construction. The phthalate
and methylene chloride levels are attributed to field and
laboratory contamination. Caprolactam is reportedly a leachable
compound found in some grades of nylon and is attributed to
the nylon line used during sampling.
2. Ground Water Monitoring Program Proposed for RCRA Permit
A revised Part B permit application was submitted in
January 1985 for the proposed ground water monitoring program
for Part 264. This revised monitoring plan, although improved
over the original submittal, was still inadequate. The
proposed ground water monitoring system for 264 .final permit
includes the 11 wells currently in place for interim status
plus the addition of an existing well not included in interim
status. The facility also proposed to abandon and replace
two of the Interim Status wells which have had high levels of
THF and pH.
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As stated previously, the Agency and the State have
determined the inadequacy of the proposed system and issued a
Notice of Deficiency in March 1986. The Agency and State are
pursuing upgrading the monitoring system through this process.
Upgrading will require a complete hydrogeologic investigation
and installation of monitoring wells based on the results of
the investigation.
Task Force Sampling Data
f
As part of the Task Force investigation samples were
collected from 16 facility wells and one ground water spring
near the facility. Samples were analyzed for 194 organic and
inorganic parameters through the Agency Contract Laboratory
Program. Due to laboratory analytical problems several
organic parameters were analyzed with abnormally high detection
limits thus rendering the possibility that contaminants went
undetected if concentrations were below the detection limit.
Of the organic data that were validated, three organic
compounds were identified in several facility wells. In one
well, B3B, 1,2-dichloroethane (DCA) was detected at a level
of 5 ppb. In well C5, a ground water gallery well upgradient
of the C barrier dam, bis-(2-ethylhexyl)phthalate was detected
at a level of 16 ppb.
The most common organic found in the samples was tetra-
hydrofuran (THF), detected in eight facility wells; C4M, CpH,
ClB, WS4, A2M, A2B, C6B, and C4M. The range in levels was
from 2.5 to 780 ppb. The concentrations of THF could not be
confirmed by our data reviewers through the data validation
process, as documentation for standards and spectra were not
provided. Therefore, the data roust be used with caution.
Samples from three wells; C5, A1B, and C4M indicated the
presence of Total Organic Halides (TOX) at concentrations
greater than 1000 ppb. Well A1B, the background well, had
the highest level of 2140 ppb as did a duplicate sample of
well C5. The original C5 reading was 1420 ppb. Well C4M had
a level of 1260 ppb. All other sampling points reported
levels between 12 and 323 ppb. None of the high TOX values
correlated to any sampling point where speciated organics were
recorded. Therefore, the type of organic halide(s) causing
these levels is unknown.
Values for pH ranged from 6.3 (B3M) to 10.4 (ClB) and
specific conductance ranged from 2600 urn/cm (DIM) to 14000
urn/cm (B spring). These values are highly variable through-
out the site due to the existence of evaporite deposits such
as gypsum, present naturally throughout the region.
Several inorganic constituents of interest appear in
the analyses at some sampling points. Arsenic was detected
in well AlB (21 ppb) and in the B canyon ground water spring
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0 The facility's ground water quality assessment program out-
line is adequate.
0 Reporting procedures for ground water monitoring data are
adequate although recordkeeping procedures in the field
are not.
There exists enough uncertainty concerning the source of
contaminants at several wells to warrant consideration of
further analyses for selected analytical parameters or to
place the facility into partial or full assessment. This
would confirm contaminant sources and d'etermine whether leaks
from the facility have gone undetected.
A more thorough hydrogeologic characterization of the
site should be conducted and a monitoring system, which meets
current EPA construction standards, should be installed based
on the characterization. Although recent changes have been
made to the sampling and analysis procedures used by the
facility, inspections should be made to assure these procedures
are being properly implemented.
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II. TECHNICAL REPORT
II. A. BACKGROUND
1. Site History
Casmalia Resources currently operates a commercial
off-site hazardous waste disposal facility consisting of 43
RCRA surface impoundments, 5 RCRA Landfills, 1 TSCA landfill
for PCB's, and a Zimpro Wet Air Oxidation treatment unit
(Figure 3). All units at the facility are hazardous waste
units. The facility began operation in 1972 under Regional
Water Quality Control Board Waste Discharge Requirements
(Order Number 72-28) as a 61-acre oilfield hazardous waste
disposal site. At that time the facility consisted of 15
surface impoundments and 1 landfill.
The Waste Discharge Requirements were amended in 1976 to
allow for a 118-acre expansion of the facility to the east
and north, bringing the site to 179 acres. In November
1978, EPA issued the facility a Toxics Substance Control Act
(TSCA) permit for the disposal of PCB's. The PCB landfill
was later expanded under new orders issued in March 1979 and "
January 1980. In addition, California Department of Health
Services issued a Hazardous Waste Facility Permit to the
site on April 20, 1979 (Permit No. 42-001-78) in response
to then-new California State DOHS requirements.
Just prior to receiving RCRA interim status on November
19, 1980, the facility received an additional revision to
their Waste Discharge Requirements (Order No. 80-43) expanding
by 75 acres to the west. This revision was issued on November
14, 1980, added 5 surface impoundments and 1 landfill, and
brought the facility to its current size of 254 acres.
California DOHS issued an addendum to the Hazardous Waste
Facility Permit in September 1982 for a Zimpro Wet Air
Oxidation Thermo Treatment unit bringing the facility to its
current operating status. In November 1985 DOHS issued a
directive to Casmalia to cease accepting liquid organic hazar-
dous wastes and implement an air monitoring/odor mitigation
program. In January 1986 DOHS also amended the permit to
include an in-tank acid neutralization system.
The facility was issued a Conditional Use Permit (CUP)
(76-CP-6) by the Santa Barbara County Planning Commission on
June 23, 1976. The CUP was issued for 168 acres of the
facility prior to the 1980 expansion. In 1985, the County of
Santa Barbara claimed Casmalia Resources violated their
Conditional Use Permit by expanding beyond the 1976 boundaries.
An agreement between the County and the facility, signed in
April 1986, redefined the total acreage of the site, limited
daily truck traffic, restricted liquids received on-site,
restricted the use of the TSCA PCB landfill, and revised the
administrative record.
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3.
CASMALIA RESOURCES
HAZARDOUS. WASTE MANAGEMENT FACILllY
400W
6-26-85
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The facility also operates under a County Dump Permit
and an Oil Recovery Permit issued by Santa Barbara County.
None of the county permits involve any ground water monitoring
requirements.
The RCRA Part B Permit Application was called in by EPA
in January 1983 and the first application was received in
July 1983. After review of the application, the Agency issued
the first Notice of Deficiency (NOD) in May 1984 under a
Warning Letter. That same month (May 1984) the Agency
issued a 3008(a) complaint against Casmalia Resources for
ground water monitoring violations noted during a December
1983 ground water inspection. That order was settled under
a Consent Agreement finalized in September 1984 with a
$35,000 fine. A second Part B application, incorporating
changes resulting from the NOD and the Consent Agreement, was
received in November 1984. The ground water (Subpart F)
portion of the application was, however, received in January
1985 to allow the incorporation of the data from the ground
water sampling conducted in November 1984.
A second NOD for the revised application which included
State comments was issued in March 1986 under a Warning
Letter. The agencies are currently working with the facility ..
on the technical details and schedule for implementation of
the tasks identified in the NOD.
2. Enforcement Actions
State enforcement action against Casmalia came in
December 1984 and November 1985. In December 1984, DOHS
issued a complaint in response to a May 1984 General Opera-
ting Requirements Inspection. A Consent Agreement was
drafted in June 1985 with a $47,000 proposed penalty. In
lieu of the penalty, an agreement was reached with the
facility to fund a $626,000 air study and monitoring plan
and comply with the other terms of the complaint. In
November 1985, DOHS directed the facility to cease receipt
of liquid hazardous hazardous wastes excluding inorganic acids
and bases. This became effective December 21, 1985. The
Regional Water Quality Control Board has implemented several
administrative enforcement actions, under Title 23, Chapter 3,
Subchapter 15 of the California Administrative Code authority,
since 1972.
The only EPA enforcement action involved the May 1984
Complaint which resulted in a September 1984 Consent Agreement
carrying a $35,000 fine.
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Adjacent Land Use
The facility was developed in a range of hills about 5
miles wide, known as the Casmalia hills, which separates two
15-mile wide regional river valleys: the Santa Maria Valley
to the north and the San Antonio Creek Valley (in which
Vandenburg Air Force Base lies) to the south. Both valleys,
and the Casmalia Hills, trend almost due east-west.
The facility represents 250 acres of a 4,300 acre land-
holding. The land use immediately adjacent to the facility,
and the entire Casmalia Hills area, is almost exclusively
cattle grazing. There are several oil-well fields to the
east of the facility and several ranch homesites about a
mile east and north of the site.
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II. B. INVESTIGATIVE METHODS
Data gathering and methods used for this investigation
involved four major areas; record reviews and facility
personnel interviews, ground water sampling and analysis,
audit of sampling procedures, and audit of on-site and
off-site facility and contractor laboratories. For each
task, a specific program .plan was developed by the individual
task leader. As mentioned previously, the record reviews
and facility personnel interviews were conducted by the
overall project leader, Mark Filippini-, EPA Region 9. Both
ground water sampling and sampling audit projects were led
by Peter Rubenstein of Region 9 Field Inspections Section.
Laboratory audits both on and off-site and ground water data
validation were conducted by Kevin Wong, chemist, also of
Region 9. The Project Plan which consists of the Sampling
Plan, Sampling Audit Plan, and On-site and Off-site Laboratory
Audit Plans are incorporated by reference. For a thorough
review of the procedures used in this investigation and for
a comprehensive understanding of the results of this report,
the Project Plan should be consulted.
1. Facility Inspection/Record Review
The facility inspection involved two major areas,
collection and review of all pertinent data and documents
relating to the facility design and operation, and interviews
of facility personnel. Inspections of facility units and
operations were also conducted.
In June 1985, Planning Research Corporation (PRO
Chicago, Illinois under contract to U.S. EPA Headquarters
and the Task Force, compiled an information/document package
for the Casmalia Disposal Facility. The PRC file consists
of 12 volumes containing a cataloguing of copies of all
documents and correspondence regarding the facility from all
EPA and State files. The PRC file was used as a comprehensive
review and reference document to aid in this investigative
process. Documents and records were also reviewed and
collected at the facility to verify information currently in
Government files and to supplement them with new informa-
tion. A total of 69 documents were reviewed, copied and
collected at the facility. Documents requested of the
facility were those known to be missing from Government
files, new information or documents not yet received by the
Agency, and documents of interest brought to our attention
through interviews with facility personnel. All documents
are on file with EPA Region 9.
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Interviews of facility personnel and their contractors
were conducted throughout the investigation. A total of
eight facility representatives were interviewed through six
interview/meeting sessions totaling approximately 10 hours.
The kickoff meeting held the first morning of the field
investigation at the facility offices lasted three hours and
involved four facility representatives as well as Task Force,
Regional, and State representatives. Discussions from the
meetings and interviews were documented in field log "books
issued to each Task Force participant.. Sixteen notebooks
were issued to Task Force/ Versar, Regional and State partici-
pants to document and log all activities observed and conducted
during the investigation. All notebooks were collected at
the end of the investigation, used in the report writing, and
are kept on file at Region 9.
Photodocumentation of facility units and operations,
Task Force operations, and facility sampling procedures were
also conducted. Sixteen rolls of film were taken and all
photographs and slides are on file at Region 9. Selected
photos were incorporated into the Sampling Audit report,
Laboratory Audit report, and the Sampling and Documentation
report.
2. Laboratory Audits and Inspections
Audits were conducted at both the on-site facility
laboratory and the facility's contract off-site laboratory,
Brown and Caldwell of Pasadena, California. The on-site
laboratory conducts mostly fingerprinting of waste loads
received at the facility to assure consistency with the mani-
fest and waste description provided by the generator. The
off-site contract laboratory conducts analyses of the ground
water samples collected by either facility personnel or
their sampling consultant Woodward-Clyde. Kevin Wong was
the Laboratory Audit program leader for this investigation.
His Laboratory Audit Plan is Attachment B of the Project
Plan and should be consulted for details of the investigation.
The purpose of the audits was to assess such factors as
the laboratories' analytical capabilities, the technical
capability of laboratory personnel, and the existence and
implementation of a proper quality assurance/quality control
plan. The Audits involved acquisition of documents regarding
laboratory equipment, personnel, and operations, interviews
of laboratory personnel and management, determination of
personnel qualifications, verification of instruments, and
evaluation of quality control/quality assurance procedures.
The reader is referred to the Laboratory Audit Plan developed
by Kevin Wong, dated October 16, 1985, for details. Results
of the audits are discussed in Sections II. C. 2 and II. E. 6
of this report.
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The on-site laboratory audit was conducted on October 21
and 22, 1985. The off-site laboratory audit was conducted
on October 23, 24, and 25, 1985 at the Brown and Caldwell
laboratories in Pasadena, California. As mentioned, the
purpose of the on-site laboratory audit was to determine the
facility's capability to perform screening ("fingerprinting")
analysis of wastes received by the facility for potential
disposal. The purpose of the off-site commercial laboratory
audit was to determine the laboratory's ability to perform
appropriate chemical analyses on ground water samples. The
results of these investigations are discussed in subsequent
portions of this report.
3. Sampling Audit
In order to assess the facility's ground water sampling
procedures, an audit was conducted during the facility's
November sampling. The sampling was conducted by Woodward-Clyde
Consultants between November 18 and November 21, 1985. Sixteen
samples including one duplicate and one blank were collected
by the facility contractor during the sampling. The investi-
gative procedures included observations of sampling procedures,
interviewing sampling personnel, collection of documents,
review of the sampling plan, and photodocumentatlon of
procedures.
A Sampling Audit Plan was developed by Peter Rubenstein
and is included as Attachment C of the Project Plan. The
purpose of conducting this portion of the investigation
separately from the sample collection, as opposed to conduc-
ting it in conjunction with the Task Force sampling as it
has historically been done, was to give a more representative
perspective of the procedures used by the facility sampling
personnel. To attempt to critique facility sampling procedures
during Task Force sampling would place an excessive workload
on the facility sampling team as well as Task Force personnel
who have to coordinate both the sampling audit and the sample
collection for the Task Force. A review of the well purging
procedures used by Casmalia was, however, conducted during
the Task Force sampling in October 21-30, 1985.
The Sampling Audit team was led by Peter Rubenstein and
included Mark Filippini and Kevin Wong. State involvement
was limited in this phase of the investigation. To facilitate
a consistent review at each well, a checklist was developed
to record all pertinent information. An additional checklist
was developed for general field methods, quality assurance and
quality control (QA/QC), and Chain-of-Custody. Copies of the
checklists are included in the Sampling Audit Plan (Attachment
C) of the Project Plan.
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-21-
4. Sampling Program
One of the major objectives of the Task Force investiga-
tion at Casmalia was to determine if any of the monitoring
wells at the facility have detected any contamination.
Between October 21 and 30, 1985 EPA, with our contractor,
Versar Inc, sampled 15 of the facility perimeter monitoring
wells, one water supply well, and one ground water spring.
Including replicates, performance evaluations, and blank
samples, a total of 35 sets of samples were collected. The
facility declined an offer for split samples. However, the
State DOHS and RWQCB requested splits "from selected sampling
points. DOHS collected samples to analyze at their own labor-
atory in order to get a faster turnaround on the analyses.
The RWQCB collected samples in order to verify their own
laboratory's data. DOHS and RWQCB took 14 replicate samples
from 10 wells during the investigation. Their results will
not be discussed in this report due to the limited QA/QC
that was conducted on the samples.
The sampling team leader in charge of all field sampling
operations was Peter Rubenstein. Peter was in charge of the
three-man Versar sampling team and was assisted by Donald
Shosky on detail to the Task Force from EPA Region 8, Denver.
Various state personnel observed the sampling operations and ..
were on hand during collection of their split samples.
Samples were shipped the same day or the day following
sample collection to the EPA contract laboratories for
analysis. Organic samples were shipped to California Analy-
tical Laboratory in Sacramento and inorganic samples were
shipped to Rocky Mountain Analytical Laboratory in Arvada,
Colorado.
The sampling activities were based upon the October 1985
Sample Plan, developed by Rubenstein. Sampling procedures
are described in detail in the Sampling Plan, Attachment A
of the Project Plan. Description of sampling protocol,
proposed sampling schedule, container and preservative
details, shipping, and QA/QC procedures are described in the
Sample Plan. The reader is referred to the Sampling Plan
and the Sampling and Documentation Report, March 1986, for
details of the actual procedures used during the investigation,
These reports are on file at the Region 9 office.
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-22-
II. C. WASTE MANAGEMENT UNITS AND OPERATIONS
1. Waste Management Units
The facility consists of 43 RCRA surface impoundments,
5 RCRA landfills, 1 TSCA landfill, and a Wet Air Oxidation
treatment unit (see Figure 2). All units at the facility
receive hazardous waste. Until recently large spray fields
were also employed to encourage evaporation of liquid hazardous
wastes mixed with runoff. They were removed from operation
as part of an agreement with the State. Shallow evaporation
ponds are being employed instead to accommodate evaporation.
As of 1985, Casmalia handled approximately 536,200,000
pounds of liquids and 48,700 cubic yards of solids yearly.
There is a capacity of 200,000,000 gallons of surface impound-
ment and 2,000,000 acre-feet of landfill.
All units at the facility are currently active. There
are no closed units at the facility. The several spray areas
were used prior to April 1985 but were decommissioned as part
of the State directive. The spray areas were mostly hillsides
above landfills and impoundments and were frequently moved
around the facility through the use of irrigation-type
piping. The spray areas were not considered RCRA units by
the facility.
None of the units at the facility are lined. All impound-
ments are constructed of local soil materials. The facility-
plans to phase out most active surface impoundments by the RCRA
November 1988 deadline for double lining. Several lined units
may remain for impounding runoff from the facility. It plans
on building larger scale treatment systems to maintain liquid
capacity. Negotiations are ongoing with Santa Barbara County
for treatment permits. After County approval, RCRA/State
permits will be sought.
Casmalia has also proposed a double liner for the RCRA
Solid Wastes Landfill on the western edge of the facility.
Approval by the County of this expansion and construction
(which could be done under RCRA interim status) would give the
facility 2,100,000 cubic yards of lined solid waste disposal
capacity. That capacity currently exists under interim
status but has not been granted by County permit.
Whereas none of the units have any liners or leachate
collection systems, the lower ends of the two canyons on which
the facility is constructed, have barrier dike systems.
These dikes were constructed at the request of the State to
intercept any ground water or leachate that might migrate
off the facility through these potential ground water flow
paths.
The dikes are constructed of recompacted soil borrowed
from on-site and keyed to the bedrock contact. The effective-
-------
-23-
ness of the dikes has not been demonstrated through pump
tests, tracer tests, or construction details.
The smaller of the two barriers, the "B" dam is between
130 and 150 feet long (east-west), and 50 feet wide (north-
south). The trench was excavated four feet into "unweathered"
bedrock, and a 10-foot thick compacted clay layer was placed
in the trench. On the downgradient side .(south), a one- to
two-foot thick gravel layer was placed in the trench, with a
six-inch diameter pipe underdrain and vertical pipe to collect
and remove liquids which leak through the barrier. The pipe is
the gallery well B5.
The second barrier, "C" dam, is 1200-feet long and
reportedly constructed in the same fashion as the "B" dam
except the gravel blanket and piping were placed upgradient
of the dam to capture ground waters upgradient of the
barrier. Gallery wells C-5, C5E, and C5W are part of that
system.
The B gallery well, B-5, collects on the order of 100
cubic feet per day (800 gallons). The C gallery well, C-5
collects about 200 cubic feet of liquid a day (1,500 gallons).
Recovered water is reintroduced back into the surface impound-
ments. Both gallery wells were sampled as part of the Task
Force sampling program.
2. Facility Operations
The following description of facility operations is
based on interviews of facility personnel, review of facility
documents, and review of the RCRA Part B permit application.
Implementation of these practices was not actually observed.
Inspection reports should be consulted to confirm the actual
implementation of the procedures.
Normal operating hours for receipt of hazardous waste
loads are between 7:30 a.m. and 4:30 p.m., 5 days a week.
Waste loads received after these hours are usually restricted
to oilfield refinery wastes and non-hazardous wastes which
are accepted on a 24-hour basis. However, there have been
exceptions to this practice, as exhibited by the facility's
acceptance of routine waste loads delivered by Casmalia
Resources' own transporters. If hazardous waste loads are
received after hours, the stated standard policy is for the
weighmaster to contact the on-call chemist prior to acceptance.
The time and date of receipt of all accepted waste loads are
recorded and noted on all accompanying documentation.
The standard waste acceptance procedures reportedly
being implemented at the time of the audit required that all
generators be provided with a waste acceptance policy form
-------
-24-
and that a Waste Characterization Form (WCF) be completed by
generators prior to any acceptance of waste. Upon review
and/ in some cases, analysis of pre-disposal samples, a
waste disposition form is forwarded to the generator.
Final disposition in determining where to dispose of a
particular waste load on-site is the responsibility of the
chemist or laboratory technician. If a waste load is refused,
a Waste Refusal Report is completed, logged and filed. The
laboratory typically analyzes approximately 50 samples a
day, and reportedly averages about 2 to 3 refusals per week.
Samples are typically collected by the drivers of the
trucks delivering the samples, and are immediately provided
directly to the weighmaster. After processing the appropriate
paperwork, the weighmaster handcarries these samples, with
documentation, to the laboratory. Standard fingerprint
testing includes pH, flash point, heavy metals, sulfides,
cyanides, halogens, and/or oxidizers. Fingerprinting proce-
dures identified in the Waste Analyses Plan, which has been
modified since the November 1984 Part B submittal, are those
followed by the facility.
The laboratory also performs the Paint Filter Test on
all bulk solids ("pasty or wet solids") received at the .
facility. If liquids are determined to be present in the
waste, the facility will provide two options to the generator.
The first option is to provide the generator an opportunity
to solicit outside assistance in "solidifying" the load in
question. The second option is for Casmalia Resources to
offer to solidify the waste load by using vermiculite,
cement or some other absorbant. If the second option is
used, the waste loads are allowed to set directly in the
trucks prior to disposal. No chemical or physical tests are
conducted on the "solidified" waste to assess the structural
integrity or chemical stability of the waste load.
Once a determination has been made as to final disposal
of a waste to a particular pond or landfill, the transporters
are informed of the disposal area's location. Only five of
the 43 impoundments are receiving ponds for bulk liquids.
Organic wastes are placed in either ponds A, B, or C. Non-RCRA
wastes are placed in Pond A and RCRA wastes are placed in
Ponds B or C. RCRA acid wastes are received in Pond E and
alkaline wastes are placed in Pond J. Heavy metals are
placed in either the Acid or Alkaline ponds which are later
mixed for precipitation of the metals. Liquids from the
receiving ponds are then pumped into other units, through
the use of irrigation piping and portable pumps, depending
on the nature of waste and level of ponds. Very little
control on the wastes streams is exercised after discharge
into receiving ponds. Non-RCRA wastes are routinely mixed
with RCRA wastes. The actual implementation of these practices
was not verified by the Task Force.
-------
-25-
The wet air oxidation unit at the facility is used for
the oxidation of sulfide scrubbing wastes, cyanide plating
wastes, and various organic wastes. The two former represent
the majority of the wastes streams treated. The unit is
operated by the manufacturer, Zimpro Inc. of Wisconsin. A
sample of each waste stream is sent to the manufacturer in
Wisconsin for evaluation before treatment.
Solid wastes are segregated for disposal into one of six
landfills: Acids, Caustic Cyanides, Heavy Metals, Solvent-
Pesticides, RCRA Solid Wastes, and a TSCA PCB landfill. The
on-site chemist decides on the disposition of the load per
procedures described above. The load is then sent to the
loading dock where it is checked for standing liquids. A
spot check of 10% of the containerized loads is conducted by
sounding the drum and use of a PVC sampler. As stated, the
implementation of this practice for drum testing was not
observed by the Task Force.
-------
-26-
II. D. SITE GEOLOGY/HYDROGEOLOGY
1. Geomorphology
The Casmalia facility is located in a range of hills
with a vertical relief on the order of 700 feet. The relief
at the site ranges from 350 feet elevation to the south to
650 feet elevation to the north over the 4,000 foot length
of the facility. The facility is constructed on the southern
slope of a ridge and encompasses three small subdrainages of
a watershed which drains to the south tsee Figure 2). The
drainage has been altered by the facility such that no run-
off leaves the facility boundaries. Runoff is circulated
into the surface impoundment system. The canyons are now
used for landfills and surface impoundments.
The main drainage course in the area, to which the
streams on the facility previously discharged, is Casmalia
Creek which runs due south along the western boundary of the
site. The nearest stream to the east is Shuman Creek
located about one mile from the eastern boundary of the
site. Casmalia Creek is joined by Shuman Creek and then
drains west to the Pacific Ocean.
The Casmalia Hills are located between two large ground
water basins (Figure 4). The Santa Maria Valley ground
water basin to the north and the San Antonio Creek basin to
the south (part of the Santa Ynez Valley) in which Vandenberg
Air Force Base is located. The Santa Maria Valley, San
Antonio Creek basin, and Santa Ynez Valley aquifers are the
main water supply in the region. Several livestock wells
and the facility non-potable water supply wells are located
in the small Casmalia Creek alluvial aquifer near the site.
This water is not potable because of high TDS levels, due to
gypsum and other evaporite deposits that exist in the area.
The above ground water basins are comprised of unconso-
lidated alluvial deposits underlain by consolidated marine
deposits of the Sisquoc and Monterey Formations. The uncon-
solidated alluvial deposits constitute the basin aquifers.
Ground water flow in these basins is seaward, east to west.
According to available data and a study conducted by the
Santa Barbara County Water Agency, the ground water basin
boundaries generally coincide with the surface water divides.
The surface water, and apparently ground water units
surrounding the facility drain towards the south and San
Antonio Creek basin. There is no evidence of a bedrock
aquifer in the Casmalia Hills. Direct hydrologic connections
through bedrock between the facility and either of the
basins is not indicated.
-------
-27-
SOLOMON
HILLS
CASMALIA
RESOURCES
Figure 4. Ground Hater Basins of Santa Barbara County.
-------
-28-
2. Geology
The bedrock lithology of the site consists entirely of
the lower portion of the Sisquoc Formation which is a late
Miocene, early Pliocene marine deposit of claystones, silty
claystones, shales, and diatomaceous and partly opaline
shales. According to geologic studies conducted by Alden
Loomis, the Sisquoc Formation extends downward for 400 to 700
feet below the surface where it contacts the Monterey Forma-
tion (Figure 5). The bedrock is thinly bedded under most of
the site with no known sand beds throutjh the formation.
No known large folds or faults affect the unit beneath
the site. There is surface and near surface fracturing of
the bedrock. The bedrock weathers into silty clay that
contains shale fragments. Soils are fine grained with low
permeability. Bedding dips gently to the east and north
from about 1 to 15 degrees.
The soils and weathered bedrock on the site range in
thickness from about 3 feet in the upper reaches of the site
to over 35 feet in the lower portions of the site.
3. Hydrogeology
The facility has designated two separate water-bearing
strata; fractured or weathered bedrock (Sisquoc Formation),
and alluvial/unconsolidated deposits. To estimate hydraulic
conductivities of each of the zones field testing was performed
at selected wells and piezometers by the facility in 1984.
Rising head permeability tests were conducted by the
facility on wells A1B, A2M, A2B, B3B, C2M, C2B, CpH, DIM,
and DIB. Constant discharge permeability tests were also
conducted on piezometers T-3A, T-3B, T-3C, SB-5, SB-6, SB-7,
SB-8, SB-10 and WB-7. The estimated permeability values are
presented in Tables 1 and 2.
Hydraulic conductivity values, estimated by the facility
from field data measured in wells completed in relatively
unweathered bedrock were low and ranged from 10~° to 10~~'cm/sec,
Weathered bedrock or mantle zones, such as alluvial soils,
yielded hydraulic conductivity values of 10~5 to 10"7cm/sec.
There are several exceptions to the ranges as noted in Tables
1 and 2. Local fracturing of the bedrock has probably caused
increases in the permeability to 10"5cm/sec.
Potentiometric maps developed by the facility indicate
the ground water flow direction to be due south through either
the C-canyon or the B-canyon to the barrier dams. With the
given potentiomentric surface, the facility calculated esti-
mated ground water flow velocities from well A1B to well 05
-------
I5OO-
750
Seo level-
-75O-
-I5OO-1
-225O-*
Ts,
Disposal Site o
E
S.squoc tormot.on
nferey formafion
II
t/>U-
3079
Scale I" = I50O'
- 75O
\- Sea level
- -750
- -I5OO
--225O
N4I°E
Figure 5. GEOLOGIC CROSS SECTION A-A1
HUNTER DISPOSAL SITE
Courtesy Union Oil Company
A Loomis
January. 1972
I
to
vo
I
-------
-30-
TABLE 1.
RISING HEAD PERMEABILITY TEST RESULTS
(Saturated Zone)
(From Casmalia January 1985 Part B Permit Application)
Hydraulic
Conductivity*
(cm/sec)
-3 x 10~7
2 x 10"5
6 x 1C"6
2 x 10"7
2 x 10~6
3 x 10~5
1 x 10~7
1 x 10"6
1 x 10~6
Well Screened
Number Interval (feet)
A1B
A2M
A2B
B33
C2M
C2B
CpH
DIM
DIB
174
10
37
40
10
82.5
110
10
78
*Method of analysis
Soil Permeability in
- 198
- 15.5
- 61
- 64
- 55.5
- 92.5
- 120
- 44.5
- 102
as specified
Groundwater
Lithology
mud stone
clay & shale
mud stone
mudstone
fill & shale
oud stone
mudstone
fill & shale
mudstone
by M. Juul Hvor
Observation, Bu
of Engineers, U.S. Army (1951).
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TABLE 2.
CONSTANT DISCHARGE PERMEABILITY TEST RESULTS
(From Casmalia January 1985 Part B Permit Application)
Piezometer Screened Permeability*
Number Interval (feet) Lithology (cm/sec)
T-3A
T-3B
T-3C
SB- 5
SB-6
SB- 7
SS-8
SB- 10
WB-7
29.5 -
45 -
95 -
31 -
39 -
29.5 -
37 -
11 -
15 -
39.5
59.5
139
39.5
46
40
49
22
26
clay and shale .
clay and shale
mudstone
clay and shale
mudstone
mudstone
mudstone
mudstone
inudstone
1 x 10"7
1 x 10"7
<1 x 10'7
4 x 10"6
7 x 10"7
8 x 10~5
2 x 10~7
<1 x 10"7
, «-7
<1 x 10 '
*Method of analysis as specified by H. Bouwer, Groundwater
Hydrogeology, McGraw-Hill Company, (1978), and by Juul Hvorslev,
Time Lag and Soil Permeability in Groundwater Observation,
Bulletin No. 36, Corps of Engineers, U.S. Army (1951).
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(the steepest topographic gradient). Velocities in the
bedrock zone were estimated to be 7 X 10~7 cm/sec (or 1
foot/year). Velocities in the mantle zone were calculated
to be 4 X 10~6 cm/sec (or 4 feet/year). Using values for
the higher permeability alluvium or fractured bedrock, this
author calculated velocities on the order of 6 X 10~5 cm/sec
(or 60 feet/year). These high permeabilities were confirmed by
observation of water level recovery rates in wells during
Task Force purging and sampling operations. This indicates
the possibility of higher permeability areas of the alluvial
and fractured bedrock zones than indicated by the facility.
Boring logs reviewed by Yelsey (1984) indicated the
presence of discrete seepage zones. He felt the heterogeneity
of the unconsolidated deposits (clays, gravelly clays, silty
sands) probably resulted in lateral ground water movement in
materials of slightly higher permeability. The unconsolidated
deposits appear to act as semi-permeable aquitards, helping
to explain the presence of multiple seepage zones in some
boring logs.
Climate
The area is characterized by short, mild winters and dry./
warm summers. Most precipitation falls during the winter
months of November through April. The average annual precipi-
tation ranges from 10 to 15 inches. Annual precipitation
can vary from as low as 5 inches to as much as 30 inches.
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II. E. GROUND WATER MONITORING SYSTEM
1. Monitoring Requirements State/Interim Status
A monitoring program has been in effect at Casmalia
Resources since 1972 when State Waste Discharge Requirements
were granted. The ground water monitoring program evolved
over the years as the site expanded and modifications were
made to the facility. To bring the facility into compliance
with Interim Status requirements under* RCRA, the Water
Quality Control Board modified the monitoring program in
1981. Modifications to the monitoring program, after the
initial 1972 well system was installed, came in 1974, 1982,
and 1983 per additional State changes.
However, as a result of a December 1983 ground water
monitoring inspection conducted by EPA, a Consent Agreement
was entered into in September 1984 for further modifications
to the program. Four additional wells were installed per
this agreement. A total of 11 wells currently comprise the
RCRA interim status monitoring system. Previous wells were
phased out of the RCRA system due to their inappropriate
construction. The RWQCB requires monitoring of 19 facility
wells. The location of each facility well including non-RCRA^
wells, gallery wells, and water supply wells is provided in
Figure 6.
2. Current Monitoring Well Network
The current RCRA monitoring system consists of one
upgradient well (AlB) and 10 downgradient wells (A2M, A2B,
B3M, B3B, C1B, C2M, C4M, C6B, DIM, and DIB)(see Figure 6).
The first letter of the well nomenclature refers to the area
on the facility where wells are placed (B-canyon, C-canyon
etc). Further classification of wells is into one of two
categories, bedrock monitoring wells and soil-mantle monitoring
wells. The bedrock wells are reported to be screened in
consolidated deposits, and the soil-mantle monitoring wells
are reported to be screened in the overlying unconsolidated
materials and fractured bedrock. The letters B and M after
a well number designate a bedrock (B) or soil-mantle (M)
monitoring well. The numeric designation in the well nomen-
clature is an ordinal number.
Two additional wells were constructed at the base of the
PCB landfill (EPA-1 and EPA-2). These wells were constructed
to comply with the TSCA permit for PCB disposal. Records
indicate these wells have never had any water in them. They
are monitored per a TSCA permit and are not monitored (or
constructed) to meet RCRA requirements.
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-34-
400 ft
Contour Interval:
40 ft.
Figure 6. Topographic Map with Waste Units and Facility
Well Locations, Casmalia Resources. (Source;
Uoodward-Clyde Consultants, 1985)
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-35-
The downgradient wells are located from 300 to 1150
feet from the edge of the waste management units and may not
meet the RCRA requirement for placement at the limit of the
waste management boundary to immediately detect potential
releases of hazardous waste constituents.
3. Well Construction
A summary of the well construction details for the 11
RCRA wells is provided in Table 3. The explanation of well
construction which follows was provided by the facility
and was not confirmed by State or EPA observations.
The five soil-mantle wells (A2M, B3M, C2M, C4M, and DIM)
were installed in 1982. Well drilling was accomplished
using a bucket auger rig to obtain an 18-inch diameter bore
hole. The well casings are PVC-glue cemented 6-inch I.D.
PVC which are perforated (0.08 inch saw-cut) from approximately
10 feet below the ground surface to the bottom of the well.
An unperforated 2.5-foot section of casing and a cap was
placed at the bottom of each well to act as a collection
sump for well debris and silt. A filter pack of 1/4 to 1/8-
inch gravel was placed around the entire length of the
perforated section. The annular spaces above and below the
screened interval were sealed with concrete grout. The
space above the pack were grouted to the surface. No bentonite
seals were used between the filter packs and the grouting.
See Figure 7 for a schematic of a typical soil-mantle well
construction.
The purpose of this type of construction was to collect
water samples from the entire length of the unconsolidated
zone. This, however, resulted in excessively long screen
lengths (some in excess of 70 feet) causing, at times,
several saturated zones to be transected.
The six B-wells (AlB, A2B, B3B, C1B, C6B, and DIB), were
installed into less weathered bedrock. Wells C1B and C6B
were installed in 1982 using a rotary-wash method which makes
logging down-hole moisture conditions at the site impossible.
C1B and C6B were drilled with an 18-inch diameter borehole, a
6-inch inside diameter well casing, and a 10- to 20-foot long
machine-slotted well screen. These two wells, constructed
similarly to the M-wells, have PVC glue-cemented well casings
rather than threaded couples and have no bentonite seals
between the filter pack and the cement seal. S-ee Figure 8 for
a schematic of a typical older bedrock well construction.
Well AlB, A2B, B3B, and DIB were installed in 1984 in
response to a Consent Agreement reached in September 1984
between EPA and the facility. The four wells constructed in
1984 were installed under the direction of Woodward-Clyde
Consultants. These bedrock wells were drilled until bedrock
-------
TABLE 3
SIMMARY OF WF.I.L CONSTRUCTION DETAILS
(frcm Casmalia January 1985 Part B Permit Application)
Well
Number
AIB
A2M
A2B
B3H
B3B
GIB
C2H
C4N
C6B
DIN
DIB
Depth of
Date Drilling Boring
Constructed Method (feet)
7/84
8/82
7/84
6/82
8/84
1982
1982
8/82
1982
1982
7/84
Rotary-Wash
Bucket Auger
Rotary-Wash
Bucket Auger
Rotary-Wash
Rotary- Wash
Bucket Auger
Bucket Auger
Rotary-Wash
Bucket Auger
Rotary-Wash
357
18
61
25
70
87
58
89
106
47
130
Casing
Borehole Depth of Screened Diameter
Diameter Well Casing Interval 1.0. Llthology of
(Inches) (feet) (feet) (Inches) Screened Interval
12.25
18
12.25
18
12.25
18
18
18
IB
18
12.25
I9R
18
61
25
64
87
58
89
106
47
102
174 -
10 -
37 -
10 -
40 -
74.5
10 -
10 -
94 -
10 -
78 -
198
15.5
61
22.5
64
- 87
55.5
8«>.5
103.5
44.5
102
6
6
6
4
6
6
6
6
6
6
6
gray mud stone
clay & tan shale
gray mud stone
clay & tan shale
gray muds tone
gray mud stone
fill & tan shale
flit & tan shale
gr.ty mud stone
fill & tan shale
gray mudntone
Surveyed Elevation
(feet)
Top of Well
Pad Casing
806.6
415.5
452.0*
383.0
383.3
435.5
445.3
452.9
450.9
474.9
477.9
808.01
419.14
452. 84
385.97
384.56
439.06
448.56
456.16
453.91
478.45
478.86
U)
O\
1
-------
•!•«! CM
MUrlM r«M»v«fcl* f VC ctp
DM*'**"!*' >VC
••rU*. NWMClly 10* Ml*.
for ••Ck
••II !• protal
Mffoct C««l««l««llM
•' 1.0.-CUM tO
P«rf«r«l«4 PVC
O.OCO* •••-««l-f«rt.
4 •!«•• •! »!»•
10"
-,
__1-
C»ftcr«l« frtnl •••!
1/4" I* !/•* «r«vtl
T«» «f fetftMk
€•••?•!•
^ • •« • K *
;,* • -jfe.'.
i
!I
W«l«
•" •'••' •••!•$
0«NU - LvckUf ••»
SOIL
MONITORING WELL
rr • r I
.'•i '»•!
CA3MALIA RESOURCES'
Figure 7. Typical Soil-Mantle Vfell Construction, 1981, Casmalia Resources.
-------
•!••! e«»
InUrUr *•»•••»>• PVC «••
•0* • to* tMcr«l« •!••
••<•«•••! 1* Mid.
1/4" !• !/•"
Oclcll - L*cM«f c«p
W.V«W ••• — ••! — pv* I.
1
f
10 ••»•'' •*•'•' T
1.
"v
.«
•
p
I
H
1.
-------
-39-
was reached, then an additional 5 feet into bedrock, 20 feet
of well screen was then used with four feet or unscreened
casing at the bottom to serve as a sump.
The wells were drilled using an air rotary method to
obtain a 12.25-inch diameter bore hole. After the water
table was reached with air-rotary, the boring was then
continued using a rotary-wash method. An organic drilling
mud {"Clear Mud") was then used to develop the hole. The
well casing is 6-inch PVC with 20-foot of slotted PVC screening
and four feet of unslotted casing at the bottom to serve as
a sump. Threaded joints were used rather than glue with
these four wells. A filter pack was placed along the entire
length of the screened interval plus three to five feet
above the top of the well screen. Dry sodium hypochlorite
was added to the sand to break down the drilling mud. Three
to four feet of bentonite seal was then placed above the
filter pack and the remainder of the annular space was
filled to the surface with cement/bentonite grout. Figure 9
gives a schematic of a typical construction of the four
newer wells.
The screen slot size determination was made by the
Woodward-Clyde project geologists. No rationale is given
for their selection; it was not done based on grain size
analyses. Filter pack size selection was then based on the
screen slot size, not formation grain size.
PVC materials used for construction of the wells in 1984
were steam cleaned prior to their installation, details on
decontamination procedures for wells installed prior to 1984
are not available.
To accomodate purging prior to sampling, all but two
RCRA wells have dedicated jet pumps installed which operate
with a portable air compressor (see Figure 10). The purging
and operation of the air compressor is conducted by a Casmalia
site employee. The Task Force found that these jet pumps do
not work efficiently under conditions of low head or where
the purge water has to be lifted any height. Wells appear
to go dry even when water remains in the casing.
All of the wells also have a bailer access tube for
access of the bailer used for sample collection. Water can
only enter the tube through the bottom which prevents free
circulation of water within the well casing. The access
tubes have a constriction at their base to prevent the bailer
from falling through the bottom. An indirect result of the
construction of the bailer access tube is that immiscible
compounds in the ground water (floating and sinking fractions)
cannot enter the sampling tube. The tubes must be perforated
throughout the entire length of the water column to allow
free circulation of water.
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-40-
Outlct and inltt port
for jet pump
Water umpling
port
Locking steel well cover
(12" diameter)
4' x 4' Concrete pad
Cement/Bentonite Seal
Surface - 165'
6" 1.0. Sen 40 PVC blank,
threaded joint casing
Bentonite Sea
165' - 169'
Washed Quartz Sand- Pack
Monterey size 8 x 16
169' - 198'
6" I.D. slotted (0.020") screen,
threaded joint. Sen 40 PVC
Screened interval: 174' - 194'
Jet Pump — water
extraction tystem
V 1.0. Sen 40 PVC sump with
threaded bottom plug <4' long)
^ Well depth • 198'
Bottom of borehole at 357';
backfilled to 198* with
bentonite slurry
CASMALIA RESOURCES
Woocfward-Ctyde Consultants
SCHEMATIC WELL CONSTRUCTION DIAGRAM
MONITORING WELL A1B
Figure 9. Typical Well Construction, 1984, Casnalia Resources.
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-41-
PVC outlet line
PVC sampling line
PVC inlet line
Stainless steel band
Brass jet pump
PVC connecting pipe
Rubber foot valve
Brass foot valve assembly
with screen
PVC well casing
(6-inch diameter)
(not to scale)
Figure 10. Schenatic Drawing of Jet Purtp Assembly (fron Vfoodward-Clyde Consultants, 1985)
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-42-
4. Site Characterization
An insufficient amount of site characterization has
been conducted at the Casmalia facility. Site characteriza-
tion started in 1972, however, it is not adequate for the
complexity of the site. A broad concept of the hydrogeology
exists for the site, but .it is not detailed enough to assure
adequate well placement. Well placement has not been based
on flow paths identified through hydrogeologic characteriza-
tion. Well locations have been based on topographic consi-
derations (canyons, downgradient of barrier dam etc.), not
demonstrated hydrogeologic considerations. Wells were
logged from cuttings and not from soil or rock samples.
This has yielded well log descriptions with too little
detail. No continuous soil corings have been taken and the
intermittent samples that have been taken were not analyzed
for grain size or any other physical properties.
Vertical and horizontal hydraulic conductivity distribution
has not been defined for the unconsolidated alluvial deposits,
the Sisquoc, or the Monterey Formations.
Nine off-site piezometers have been installed to attempt
to determine horizontal flowpaths, however, no characteriza- -"
tion of vertical gradients of flow has been attempted. The
wells and piezometers that have been installed have such
large and variable screen intervals that accurate water
level measurements are impossible. In addition, past water
level measurements have not allowed for proper recovery of
wells prior to measurement.
Based on given rationale for well construction, screen
locations have also not been based on locations of saturated
zones. Saturated zones should be identified through proper
well logging and continuous corings of well borings. The
background well (AlB) has not been demonstrated to be reflec-
tive of proper background quality water. High and variable
TOX levels have plagued this well as well as several others
at the site.
The facility originally contended that no ground water
existed beneath the site. This assumption was based on an
improper definition of aquifer as being a water supply rather
than a potential pathway. The wells were installed to meet
State monitoring requirements prior to attainment of interim
status. However, the facility acted based on the assumption
that no ground water existed beneath the site up until the
1984 Consent Agreement.
The facility has subsequently identified two water-bearing
zones at the site; the weathered/fractured bedrock zone (where the
B series wells are installed) and the alluvial/unconsolidated
aquifers (where the M series wells are installed). The
characteristics and extent of these two zones have not been
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-43-
fully demonstrated by the facility. Potential pathways off-
site through the bedrock saturated zones have not been iden-
tified and the interaction between the bedrock saturated zones
and the alluvial saturated zones has not been characterized.
5. Sampling and Analysis Plan and Field Procedures
The Sampling and Analysis Plan presented in the Part B
application was reviewed as part of the Sampling Audit con-
ducted during November 1985. Review erf the plans was
conducted by Peter Rubenstein, the sampling team leader.
The plan was critiqued, observations of its implementation
were made in the field, and facility representatives were
interviewed for details of field practices and rationales.
Detailed review of the Sampling and Analysis Plan is provided
in the Ground Water Sampling Audit report prepared by Peter
Rubenstein, March, 1986. As with the other supporting
documents and reports, it is incorporated into this report
by reference and is part of the Task Force file.
The plan was not written to guide field work, but rather
as a documentation report for work already completed. The
plan needs to be a stand-alone document with enough detail
such that any qualified sampler can apply the document at
the facility and assure consistency.
The sampling plan differed from actual field procedures
used and observed during the November, 1985 sampling. Both
the plan and actual field procedures used have several
problems which must be corrected before the data collected
by the facility can be considered unbiased and representative
of the uppermost aquifer. Improper sampling procedures can
either add constituents not actually present in the ground
water (false positives) or potentially mask parameters actu-
ally present in the ground water (false negatives).
The biggest problem observed with sample collection was
the improper well purging procedures used. The amount of
water purged from the wells was not based on the casing volume.
The wells were purged using a jet pump assembly run with an
air compressor. Purging was conducted by facility site
personnel several days prior to the start of sampling by
Woodward-Clyde. No sampling team member was available to
direct the purging and assure consistency with the sampling
plan. The purge volumes evacuated from the wells were not
measured or documented. The amount of purging was based on
the length of time the operator had purged or until the well
appeared to have run dry because no water discharged from
the pump. On several occasions the well appeared to have
"run dry" when there were tens of feet of water remaining in
the well. Purging volumes must be based on the well casing
volume and the number of casing volumes purged should remain
constant between each sampling event. Purging must also be
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-44-
done at a rate such that cascading in the well does not occur.
Some sampling did not occur until eight days after purging.
The incomplete purging and the excessive length of time
between purging and sampling can cause chemical interference
and allow the loss of volatile and semi-volatile organic
compounds. Volatile samples must be collected as soon as
possible after a complete purging to assure a minimal loss
of volatile constituents.
Water level measurements were not taken at the proper
time. Water level measurements in wells were taken after
purging, not before when static water levels were reached.
This adds an additional potential error to potentiometric
surface measurements.
Sampling was conducted by the facility contractor,
Woodward-Clyde Consultants from Walnut Creek, California.
A sampling team of four was present for the sampling event.
Just prior to sampling, water levels were taken by the
sampling team. Samples were collected using a 2-inch diameter,
3- or 4-foot long sectional Teflon bailer with a ball check
valve on the bottom. The bailer was lowered through the
2.25-inch sampling access tube on teflon coated line.
Sampling containers were provided by the facility's contract
analytical lab, Brown and Caldwell in Pasadena, California.
Containers arrived on-site with preservative already in
them. Whereas this expedited the sampling process, it allowed
spillage of preservatives during filling and leakage during
transport, and possibly changed preservative concentration.
Pre-labeled, pre-preserved sampling containers together
with a Sampling Plan with too little detail caused several
container mixups during the observed sampling. TOC samples
were not acidified, while TOX samples were acidified and
allowed to have head space. These are not standard sample
collection methods.
QA samples were not collected as "splits" of the original,
but rather as "duplicates". This is not an inappropriate
procedure but should be designated properly. Only one blank
sample was taken per sampling event and it was not filled in
a clean area. The water used for the blanks was store-bought
distilled water not demonstrated to meet "organic free"
standards.
Chain of Custody procedures were not being properly
maintained. Records were not established until the end of
each day, rather than being maintained throughout sampling
activities. Chain of Custody was not maintained on samples
throughout the day. Samples were observed being left
unattended in an unlocked storage area several times during
the day. Samples were also shipped without Chain of Custody
seals so custody was not maintained through arrival at the
laboratory.
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-45-
The varied sampling practices followed by the facility
sampling personnel cannot assure unbiased sampling. Cross-
contamination and loss of sample integrity were potential
problems as a result of the procedures followed. The sampling
plan does not provide enough detail to assure errors are not
made during sampling. It also does not provide enough guidance
such that a different sampling team could collect samples in
an appropriate, consistent manner.
Data from the volatile organic samples collected with a
time lag of greater than one day between purge and sample
must be considered suspect. The bailer access tube construc-
tion can also cause masking of parameters. This, in conjunc-
tion with incomplete well purging, can cause bias of certain
indicator parameters and should be considered when reviewing
facility ground water quality data.
The facility has been apprised through interviews and
the Notice of Deficency (NOD), issued in March 1986, of all
of the concerns identified in Rubenstein's Sampling Audit
Report. Correction of these deficiencies is being pursued
by the State and Federal agencies.
Facility Water Quality Analysis and Data Quality Assessment
To assess the facility's contract laboratory's ability
to analyze the ground water samples, an audit of Brown and
Caldwell's analytical laboratory in Pasadena, California was
conducted. Brown and Caldwell is an off-site commercial
laboratory which has been contracted by Casmalia Resources
to perform ground water analyses. The audit was conducted
by Kevin Wong, Chemist, EPA Region 9.
The major objectives of the audit were twofold: 1) To
assess Brown and Caldwell's capabilities to conduct ground
water analyses and their general ability to produce data of
acceptable quality; and 2) To investigate and assess the
quality of actual ground water data generated specifically
for Casmalia Resources. In conjunction with this Task Force
audit, the California Department of Health Services also
participated in a concurrent laboratory evaluation in
support of the State's hazardous waste laboratory certifi-
cation program.
The laboratory procedures were found to be generally
acceptable. However, several QA/QC problems were noted.
The lack of sufficient documentation and establishment of
standard operating procedures for sample receiving, glass-
ware cleaning, and instrument servicing appear to be the
major problems found with the laboratory.
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-46-
As mentioned earlier in this report, a problem was
encountered in the field during our audit of Woodward-Clyde
sampling when inappropriate sample containers were received
from Brown and Caldwell. For the sampling, sample containers
are labeled and the necessary preservatives added prior to
shipping the containers to the sampling team. During the
November sampling audit, the TOC sample container, and thus
the sample, was not acidified. The TOX sample container was
acidified but not checked for headspace.
Such mixups can be avoided by following a more thorough
Sampling and Analysis Plan, but a strict sample handling
protocol by the laboratory is also necessary.
7. Interim Status Ground Water Monitoring Data
As discussed previously, only limited Part 265 Interim
Status ground water monitoring parameters were being analyzed
at Casmalia Resources prior to the September 1984 Consent
Agreement. No statistical analysis had been run on any of
the data prior to that time. Statistical analysis of the
data was not run until May 1985. Accelerated ground water
monitoring analysis for the Part 265 parameters was conducted
in July/August, September, October, and November 1984 for
the purpose of establishing background water quality. After
the next semi-annual sampling {May 1985) statistical analysis
was conducted on the data using the Cochran's approximation
to the Behrens-Fisher t-Test (Students t-Test).
The results of the May 1985 analyses with the statistical
calculations were received in July 1985. The results indicated
statistically significant increases or decreases in pH, specific
conductance (SpC), and/or total organic halogens (TOX) for
all but three of the monitoring wells (A2M, B3B, and C6B).
Due to the drastic seasonal and spatial variations in these
parameters seen over the year, it was suggested by the
facility that the Students t-Test, required by RCRA Part
265, was not appropriate for this hydrogeologic system.
An alternative statistical method was proposed by the
facility to accommodate the geochemical and seasonal influences
on the ground water. The average replicate Students t-Test
using a natural-log-transformation on the data to account
for highly skewed, non-normally distributed data was suggested
by the facility and accepted by the Agency. The reanalysis
also incorporated the May 1985 upgradient data into the
background to account for more seasonal variations in the
parameters. Reanalysis of the May 1985 data using the log-
transformation reduced the number of statistically significant
increases to three wells (A2B, SpC; B3M, SpC? Duplicate B3M,
TOX; and CiB, pH). Subsequent analysis of data taken in
November 1985 indicated two wells showing significant increases
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-47-
in pH, C1B and C6B. C1B is the only well showing a recurrence
from November 1985 to May 1985 of a statistically significant
increase of a parameter. The facility notified the State and
EPA of the statistical results in a Februaty 28, 1986 letter
and contended the increase resulted from improper well
construction. There were no plans submitted to address the
apparent triggering of assessment. However, the facility
indicated that correction of well construction problems and
a reanalysis of the indicator problems would be conducted
through the NOD process when new wells are to be constructed
and installed after a thorough hydrogeologic investigation.
Also, in order to account for high TOX levels in their
samples, the facility has conducted a scan for priority
pollutants for each sampling period since July 1984. The
analytical method used was GC/MS, EPA method 624 and 625 or
501.2. The organic analysis indicated the presence of
several compounds. Tetrahydrofuran (THF) was reported at
levels ranging from 10 to 200 ppb in five wells in the July
1984 sampling. THF levels are attributed by the facility to
the PVC glue used for well casing construction. However,
these high levels may not be completely attributed to glues
especially if proper purging was conducted. Trihalomethane
(THM) compounds such as chloroform and bromoform have been
reported for all sampling periods. Other organic compounds
reported for the six sampling episodes were an unidentified
phthalate compound, methylene chloride, and caprolactam
detected in the May 1985 analyses.
The facility attributes the presence of THM to the use
of sodium hypochlorite which was added to several wells to
breakdown the organic drilling mud used during well construc-
tion. The phthalate and methylene chloride levels are
attributed by the facililty to the field and laboratory
contamination. The facility has linked caprolactam to the
nylon line used during sampling. Caprolactam is reportedly
a leachable compound found in some grades of nylon.
It should be noted that waste streams accepted at the
facility contain all of the above-mentioned compounds.
During the December 1983 EPA ground water inspection,
several RCRA monitoring wells were reported to have exceeded
federal drinking water standards for chromium (RCRA Inspection
Report, Yelsey, March 1984). The chromium standard was
exceeded at three wells, A2M, C6B, and DIM, in a 1982 sampling
episode. This reporting of contaminant levels exceeding
drinking water standards has received much publicity in the
past as being an indication of a release from the facility.
However, a determination of a release must be based on a
comparison of background to downgradient values. It has
subsequently been suggested by the facility that analysis of
turbid ground water samples was incorporating metals from
suspended clay minerals and drilling muds, therefore elevating
the levels.
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II. F. GROUND WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT
1. Initial Submittals
Casmalia's Part B application was first called in January
1983 and subsequently received in July 1983. The ground water
monitoring system proposed in July 1983 consisted of 12
monitoring wells, 2 TSCA wells, and 4 gallery wells, (See
Figure 11). At that time, the facility contended that "... no
ground water existed in the area ..." but it was "... still
essential to provide continuous environmental monitoring to
detect the presence of any potential leachate leaving the
facility." This contention concerning ground water, again,
probably rose for the water-supply definition of ground water
and not the definition for the purpose of RCRA. However, the
facility did monitor, under the direction of the Regional Water
Quality Control Board, for most of the 265.92 parameters
in the wells on a complex schedule of monthly, quarterly,
biannually, and annually, depending on the parameter and the
well (see Table 4).
2. Deficiency Notices
The first NOD was issued in May 1984 by EPA. The ground
water portion of the NOD contained rather generic comments
requesting additional information on the system and clarifi-
cation of the original submittals. No additional wells were
requested but detailed information regarding well design and
construction and more description of the site hydrogeologic
properties was requested.
The deficiencies of the monitoring system and the lack
of appropriate 265.92 monitoring was noted in a December
1983 ground water monitoring inspection conducted by EPA.
The inspection report was issued in March 1984 and resulted
in a Compliance Order. A Consent Agreement was reached in
September 1984. As a result, the facility installed four
additional wells and conducted sampling of the full suite of
265.92 ground water monitoring parameters on an accelerated
scale. The four wells were installed as part of the Consent
Agreement (A1B, A2B, B3B, and DIB) are described in section
II. E. of this report. The suite of 265.92 parameters were
run on all 11 RCRA wells in July/August, September, October,
and November, 1984 to establish background water quality.
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-49-
+ 84
Figure 11. Ground Water Monitoring System Proposed in Casnalia Resources'
July 1983 Part B Permit Application.
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Table 4. Casmalia Resources Ground Water Monitoring Parameters
and Frequency of Sampling used During Interim Status
ftonitoring, November 1981 to June 1984. (from June 1983
Part B Permit Application)
Parameter
Units
Frequency/Well No.
Water Surface
Elevation
Water Surface
Elevation
Volume Pumped
*pH
*Specific Conductance
•Total Organic
Halogens (TOX)
*Total Organic
Carbon (TOC)
PCBs
Arsenic
Cadmium
Lead
Total Filtrable
Residue (IDS)
Chemical Oxygen
Demand (COD)
•Total Organic
Halogens (TOX)
•Total Organic
Carbon (TOC)
feet
feet
cubic feet
umhos/cm
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
Daily
B-5, C-5
Monthly
All but B-5 § C-5
B-5, C-5
All wells
All wells
B-5, C-5, EPA-1, EPA-2
B-5, C-5, EPA-1, EPA-2
B-5, C-5, EPA-1, EPA-2
Quarterly
(Jan., Apr., July § Oct.)
B-5, B-6, C-5, C-6
B-5, B-6, C-5, C-6
B-5, B-6, C-5, C-6
B-5, B-6, C-5, C-6
All but B-4, C5E § C5W
A-l, A-2 § D-l
A-l, A-2 $ D-l
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TABLE 4, CONT'd
Parameter
'
Copper
Cyanide
Total Chromium
Mercury
Nickel
Phenols
Silver
Zinc
Boron
Chloride
PCBs
TOX
TOC
Units
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
Frequency /Well No.
Bi -Annually
(April § Oct.)
B-5, B-6, C-5, C-6
B-5, B-6, C-5, C-6
B-5, B-6, C-5, C-6
B-5, B-6, C-5, C-6
B-5, B-6, C-5, C-6
B-5, B-6, C-5, C-6
B-5, B-6, C-5, C-6
B-5, B-6, C-5, C-6
B-5, B-6, C-5, C-6
B-5, B-6, C-5, C-6
A-l, A-2, B-6 § D-l; C-6
if detected in B-S or C-5
B-3, B-6, C-l, C-2B, C-6
B-3, B-6, C-6
TOX
TOC
Annually (April)
mg/1 C-2M, C-3, C-4
Once Each Even-Numbered
Year (April)
mg/1 C-l, C-3, C-4
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3. Revised Proposals
The revised Part B application was submitted in November
1984 for all portions of the application except Subpart F
(Ground Water Monitoring). The ground water portion of the
application was submitted to the Agency in January 1985 to
allow for the analytical results from the November 1984
sampling to return from the lab. This application represented
a more detailed presentation of the monitoring system,
presented the 265 data produced during the accelerated
monitoring program, and contained a Sampling and Analysis
Plan. However, the first round of Detection Monitoring was
not conducted until six months after background monitoring
was completed (May 1985). Results from that sampling were
submitted to the Agency in July 1985. RCRA Detection Moni-
toring continues on a semi-annual basis and Regional Board
monitoring is conducted quarterly.
The proposed ground water monitoring system for 264 final
permit included the 11 wells currently in place for interim
status (see Section II E) plus the addition of existing well
C2B (constructed in 1982). The addition of C2B to the
monitoring system for 264 permitting purposes was proposed
by the facility in order to provide a deep bedrock well at
the southeast end of the C barrier dam. The facility also
proposed to abandon and replace wells ClB and C6B for
permitting. These two wells (constructed in 1982) have
yielded samples containing high levels of Tetrahydrofuran
(THF) (200 ppb) reportedly resulting from the PVC glue used
for well casing construction. The proposed reconstruction
of wells ClB and C6B was to be of similar design to the
wells constructed in 1984 (AlB, A2B, B3B, and DIB). Detail
of their construction is given in Section II E.
The ground water monitoring parameters proposed by
Casmalia Resources for the permit included the four 265.92
indicator parameters (pH, SpC, TOC, TOX) plus a host of
metals and inorganics, the complete proposed list is in
Table 5. No organic constituents were proposed.
Potentiometric surface determinations were made from
monitoring wells, springs and ground water seeps, water supply
wells, and nine exploratory borings/wells. Water level
measurements were taken from the wells during the summer and
fall of 1984. The potentiometric surface map provided in
the Part B application was generated from these measurements.
No details are provided on the construction and installation
of the nine boring/wells or the rationale for their location.
Potentiometric surface water measurements from the wells are
considered by the facility to be reflecting levels from the
same hydrologic unit. However, the bedrock and the unconsol-
idated monitoring wells are completed in different geologic
units, and may be effected differently by local gradients.
Also, some wells have excessively long screen intervals thst
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-53-
Table 5
Proposed 264 Ground Water Monitoring Parameters
Casmalia Resources, January 1985
0 specific conductance
0 total organic carbon (TOO
0 total halogenated organics (TOX)
0 sodium
0 magnesium
0 chloride
0 cyanide
0 fluoride
0 arsenic
8 barium
0 cadmium
0 chromium
0 copper
0 lead
0 mercury
0 nickel
0 silver
0 zinc
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-54-
may transect several saturated zones. If the water level
measurements were taken immediately after the purging, as
during the sampling event/ the measurements may be inaccurate.
4. Current Status
In March 1986 the second Notice of Deficiency (NOD) was
issued to the facility to address the 1984/85 application.
The NOD included comments and requests which resulted from
the observations made during the Task Force investigation.
State comments were also included in the NOD. The ground
water portion of the NOD basically stated that a complete
hydrogeologic investigation must be conducted at the facility
before an appropriate ground water monitoring system can be
selected for permitting. The monitoring system design must
then be based on the site characterization.
It was also stated that the construction of the proposed
monitoring wells, the proposed monitoring parameters, and the
sampling procedures were inappropriate for 264 permitting
purposes.
Due to the complex nature of the required submittals,
the NOD required the facility to develop a proposed schedule
for implementation of the requirements identified in the
NOD. The facility submitted its proposed schedule on March
28, 1986. It is currently being reviewed and finalized by
the State and EPA. The details of the proposed implementation
schedule will not be discussed in this report due to the
schedule's dratt status. Meetings are being held with the
facility, the State, and Federal agencies to finalize the
schedule and discuss the technical details of the projects.
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II. G. TASK FORCE DATA COLLECTION/RESULTS
Sample Collection Methods
In order to determine if any of the monitoring wells at
Casmalia had detected any contamination, selected wells at
and around the facility were sampled. Between October 21
and 30, 1985 our sampling contractor, Versar Inc., under the
direction of Peter Rubenstein, sampled 15 facility monitoring
wells, one water supply well, and a ground water spring.
The list of sampling points sampled during the investigation,
including dates of purging and sampling, is provided in
Table 6.
The sampling points were selected, in a priority order,
during a preliminary meeting of State and Task Force person-
nel. Selection was made based on well location, construction,
screen interval, and previous water quality data in order to
get the most indictive sampling points. Not all wells sampled
were RCRA monitoring wells. Gallery wells were sampled to
give an indication as to whether the dams were being effective
in retaining ground water contaminants. This was done by
comparing water quality above and below the dams. The water
supply well was sampled to determine if contamination had
reached the Casmalia Creek alluvial aquifer. The list of
sampling points, in priority order is provided in Table 7.
Not all sampling points were sampled due to field and time
constraints.
The list of chemical parameters selected for analyses at
Casmalia was based on the modified Hazardous Substances List
(HSL) of organic and inorganic constituents specified under
the Agency's Contract Laboratory Program (CLP) contract. The
HSL essentially includes priority pollutants, a number of
RCRA indicator parameters, radionuclides and additional inor-
ganic compounds. For this sampling event, it was deemed
appropriate to monitor for other chemical compounds suspected
to be contaminants in the ground water at the site. As a
result, the list for the Casmalia investigation was expanded
to include seven (7) additional volatile organics, six (6)
additional semivolatile organics, three (3) additional
pesticides, and three (3) additional miscellaneous inorganic
compounds. The purpose of this revised monitoring list was
to provide a broader spectrum of analyses to detect and
identify the most prevalent type of chemical contaminants
which could be expected in the site's ground water matrix if
there were a release from the facility. A complete list
of the specific chemical constituents analyzed is provided
in Appendix A.
-------
-56-
Table 6: Purge/Sample Sequence for Sampling by EPA at Casmalia Resources (10/22-10/29;
Well f
AlB^
A2B*3
A2Md
B3Bd
B3Md
B5
B6B
cirf
C2M<3
C4Md
C5
C6Bd
CpH
**
Wrf
WS4
SEEP
Date (Hrs)
10/23 (3.9)
10/28 (2.4)
10/25 (2.7)
10/22 (0.6)
10/23 (0.1)
10/23 (1.8)
10/28 (4.4)
10/24 (2.7)
10/28 (2.1)
10/29 (6.5)
10/23 (1.0)
10/24 (4.2)
10/29 (3.7)
10/24 (4.4)
10/22 (1.4)
10/22 (2.9)
10/25 (0.7)
(0.2)
10/25
PURGE IN
DIW3
164.96'
13.26'
7.18'
55.09'
57.71'
5.91'
3.12'
68.06'
33.71'
35.81'
50.97'
52.73'
81.15'
22.88'
20.53'
17.79'
7.65'
FORMATION
Volume (gal)b
episode total
22
227
30-dry
7
1
58
206
23-dry
41
73
56
112
35-dry
18.0
117
137
370
125
22
227
30
8
58
206
23
114
168
35
18.0
117
137
495
3CV=
(1CV)
(48.5)
210
48
(13.4)
41.2
206
(30)
107
168
(40)
(12.5)
244
129
371
SAMPLE
Date
10/24
10/28
10/25
10/23
10/23
10/23
10/28
10/25
10/29
10/24
10/24
10/29
10/24
10/23
10/22
10/25
10/25
INFORMATION
Purge/Sample
Time Lag
18.2 hrs
0.4 hrs
2.8 hrs
22.2 hrs
4.8 hrs
1.0 hr
0.7 hr
17.4 hrs
1.6 hrs
2.6 hrs
1.8 hrs
3 hrs
16.25 hrs
0.3 hr
0.1 hr
1.0 -hr
a Measured by EPA on 10/21 prior to purge.
b Measured by EPA w/ a 55-gal drum.
c Casing Volume (CV) calculations based on pre-purge DTW measurements
d Designated by Casmalia Resources as a RCRA Monitoring Well
-------
Table 7: Sample Location Priorities
Sampling Casing
Point Dla (in)
Dedicated
Pumping
Equipment
Comments on
Purging
Analytical
Parameters
I) Gallery
C5
B5
C5W
8
8
6
2) Honitoring
B3M*
B6B
B3B*
C1B*
C2M*
C4M*
C6B*
CpH
A1B*
A2M*
A2B*
DIM*
DIB*
4
6
6
6
6
6
6
2
6
6
6
6
6
3) Seeps
< 6
submersible
submersible
none
Nells
none
none
jet
Jet
jet
jet
jet
none
jet
jet
jet
Jet
jet
Sample fro* tap in outflow.
Sample from tap in outflow.
Use portable submersible punf> to purge*
Use portable submersible pump to purge.
Use portable submersible pump to purge.
3 weeks to recover**
6 weeks to recover**
12 hours to recover**
24 hours to recover**
6 weeks to recover**
48 hours to recover**
C.R. purges 1 casing
C.R. purges 3 casing
C.R. purges 3 casing
1 week to recover** C.R. purges 1 casing
1 hour to purge 3 casing volumes.
1 hour to purge 3 casing volumes.
t hour to purge 3 casing volumes.
1 hour to purge 3 casing volumes.
4) Off-site Itater Supply Mells
< 3
4) Other Honitoring Nella (Least likely to be sampled)
C2B
C3M
C5E
B4M
AIM
t
4
6
4
6
•
* RCRA
** 1 Cftt
none
none
Jet
Use portable submersible pump to purge.
Use portable submersible pump to purge.
Use portable submersible pump to purge.
6 to 8 weeks to recover.
RCRA Monitoring Well
1 Casing Volume
All Org, Inorg, t Rad.
All Org, Inorg, t Rad
All Org t Inorg.
RNQCB dups.
All Org
All Org
All Org
All Org
All Org
All Org
All Org
All Org
Inorg.
Inorg.
Inorg.
Inorg.
Inorg.
Inorg.
Inorg.
Inorg.
All Org t Inorg.
All Org, Inorg, t
All Org t Inorg.
RMQCB dupe
Rad.
RMQCB dups
I
en
All Org fc Inorg.
All Org, Inorg, t Rad.
| All Org t Inorg.
| All Org t Inorg
All Org
All Org
All Org
All Org
All Org
Inorg.
Inorg.
Inorg.
Inorg.
Inorg.
-------
-58-
The organic samples were analyzed by California Analytical
Laboratories in Sacramento, California. The inorganic
samples were analyzed by Rocky Mountain Analytical Laboratory
in Arvada, Colorado. Both labs are part of the EPA Contract
Laboratory Program.
As arranged by prior agreement, five (5) ground water
samples collected for radionuclides and seven (7) for organo-
sulfide analyses were submitted to the California Department
of Health Services - Hazardous Materials Laboratory in
Berkeley. However, at the time of this report, no analytical
data for these constituents had yet been received by Region 9.
All the wells were measured prior to purging for depth
to the water table. A table of potentiometric surface
elevations for the 11 RCRA monitoring wells measured during
the Task Force sampling is presented in Appendix B. The
wells were purged using the dedicated jet pump present in
most wells (see Figure 10). The jet pump is operated using
a portable air compressor. Operation of the compressor and
hookup to the jet pump was conducted by a Casmalia site
employee, Abel Valli. Purge water was discharged into
55-gallon drums for measurement and later disposal into the
facility's surface impoundments. Wells which could not be
purged with the jet pump (either because pumps were not in
place or because the pumps were not functioning properly)
were purged by hand with 2-inch teflon bailers. The Task
Force team attempted to purge three casing volumes of water
from each well, if possible. Casing volumes were calculated
using the casing size and the length of the water column.
Volumes were measured in the 55-gallon drums provided by the
facility. Slow recovery wells were purged of at least one
casing volume, if possible. Actual purge volumes are
presented in Table 6.
Wells were sampled as soon after purging as possible.
A lag time of less than three hours was attempted at all wells.
However, with wells that were slow to purge and recover, it
was sometimes necessary to wait overnight in order to assure
enough water in the well column for sampling of a complete
host of parameters.
Sample parameters were collected in priority order,
starting with volatile organics, in case an insufficient
volume of water remained in some of the slow-recovery wells.
The list of sample aliquots and their containers is given in
priority order of collection in Table 8. Teflon bailers
with double check valves that are bottom filling and emptying
were used. Bailers were decontaminated in the lab and
shipped, sealed, to the site. The bailers were lowered
using Teflon coated wire to minimize introduction of any
outside chemical interference.
-------
-59-
Table 8: Sanple Aliquots and Containers
Parameters
Volatile Organics
Total Organic Carbon )
(TOC) )
Purgeable Organic Carbon )
(POC) )
Acid Extractables )
Base/Neutral Extractables Y
Pesticides/PCBs )
Metals (Total & Dissolved)
Cyanide
Total Organic Halogens )
(TCK) )
Purgeable Organic Halogens)
(PQK) )
Organo Sulfides*
Chlorides
Sulfates
Fluorides
Alkalinity
Nitrates
and
Ammonia
Phenolics
Gross Alpha*
Gross Beta*
Uranium*
Radium*
Radium 226*
* / Type of
Sample Container
4 / 40 ml glass vials
teflon septa
2 / 40 ml glass vials)
teflon septa )
1 / 40 ml glass vial )
teflon septa )
Preservation
Cool, 4"
H2S04 to pH<2
Cool, 4"
4 / 1 liter amber
glass bottles
)
) Cool, 4"
2 / 1 liter Polyethylene HN03 to pH<2
bottles Cool, 4"
1 / 1 liter Polyethylene NaOH to pH>12
bottle Cool, 4*
1 / 1 liter amber
glass bottle
1 / 1 liter amber
glass bottle
Cool, 4"
Cool, 4"
1 / 1 liter Polyethylene Cool, 4"
bottle
1 / 1 liter Polyethylene H2SO4 to pH<2
bottle Cool, 4'
1 / 1 liter amber
glass
to pH<2
Cool, 4'
1 / 1 gallon Cubetainer HNO3 to pH<2
Cerements
No Head Space
Dissolved sample
to be filtered in
field
No Head Space
Nitrates must
be analyzed
w/in 48 hours
* To be Analyzed by California DOHS Laboratories in Berkeley.
-------
-60-
The facility did not request or take any split samples.
EPA's activity at the wells was observed and technical assist-
ance was provided by Mr. Abel Valli, an employee of Casmalia
Resources. Mr. Valli provided operation of purging equipment,
answered operational questions, and provided the sampling team
with any equipment or access needed from the facility.
Samples were preserved and prepared for shipment immedi-
ately upon collection. They were then shipped the same day
or the day following collection by next-day delivery Federal
Express to the respective labs. Complete details of sample
collection, preservation, and shipment are given in the
Sampling Plan and Sampling and Documentation Report. The
reader is referred to the documents for further elaboration
of procedures used in the field.
As mentioned, a ground water spring and a water supply
well were also sampled during the investigation. A goal of
the investigation was to sample as many ground water springs
emanating from and around the facility as possible. There
has been much concern expressed by local community members
regarding springs and seeps they see around the site. Since
these springs also discharge directly to surface waters, it
was our desire to sample as many as possible. Reconnaissance
was conducted of the entire perimeter area and all stream
channels around the facility, only one spring was found to
be discharging enough water to sample. This spring was
located in the B-canyon on the southern border of the
facility just above the site boundary fence (see Figure 6).
The spring did not appear to be emanating from any units
on-site.
A facility water supply well was also selected for sampling,
The selected well, WS4, is located south and west of the C-
barrier dam in the alluvial aquifer of Casmalia Creek. This
well was selected due to its high rate of discharge, the fact
that it is the furthest downgradient of any well in Casmalia
Canyon, and downgradient of the C-barrier dam. The water
supply wells at the facility (WS 1 to 4) supply only general
utility water to the facility; rinse water, process water,
and water for sinks and toilets. The water produced from
the Casmalia Creek aquifer exceeds Santa Barbara County TDS
standards for human consumption. Due to gypsum and other
salt deposits in the area, the ground water is unpotable.
A day-by-day breakdown of samples collected, blanks, and
duplicates is give in Table 9.
-------
-D 1-
Table 9. Sanples collected each day at Casmalia Resources, sorted by
agency and parameter and identifying the sample f and the
number of sample containers per parameter.
Dltt
10/22
10/23
10/24
10/25
10/28
10/29
Well
DIM
FtaoiN
PE -
TIWPE
D1B
IS
I3B
I3M
FtaesB
cs
A1B
C4M
CpH
FB3A1B
C1I
WS4
A2X
•1" Seep
Fiaus4
A2B
Ml
riaio!
Equip*
TB
CS
Col
C2M
Fiacoi
Cooler!
Agency
EPA
EPA.
EPA
EPA
EPA
DNS
EPA
EPA dup
EPA trp
DHS
DHS dup
RUQCB
EPA
OHS
EPA
EPA
EPA
EPA dup
DHS
RWQCB
EPA
OKS
EPA
OHS
EPA
EPA
EPA
EPA
EPA dup
EPA
DHS
EPA
EPA
EPA
EPA dup
RWQCB
EPA
DNS
EPA
EPA
EPA
EPA
EPA
RWBCI
EPA
EPA dup
DNS
EPA
EPA
Swpte ff
002S6/M02S6
00257/W002S7
00306/M00306
00272
002S8/N00258
002S9/W00259
00260/M00260
00261 /M0261
00262/M00262
00264 /M00264
00263 /M00263
00265/MQ026S
00266/M00266
00267/M00267
00279/H00279
00280/M00280
00268/M00268
002B1/M00281
00282/MQ0282
002S3/MQ02B3
00286/M00286
M28S/H0028S
00284 /M00284
00287/H002B7
00288/M00288
00291 /M00291
00290/M00290
Q0289/M0289
0030S/M0030S
00273/M00273
00293/M00293
00294/M00294
00295 /M0029S
00292/M00292
00296/H00296
Ext
Orj
4
4
4
2
4
1
4
4
4
1
1
3
1
4
4
4
4
1
1
4
1
4
1
4
4
4
4
4
4
1
4
4
4
4
1
4
1
4
2
4
4
4
4
1
4
VOAs VOAS Metelt Metllc H03/ Org
(P*T) (01) (Tot) (Dist) CM Phenols MH4 An ions TOX TOC POX POC Sul RAD
22 1 11 11 11111
12 1 11 11 11111
21 1 11 11 11111
2 2
22 11 11 11111
2 1 4
22 11 11 11111
22 11 11 11111
22 11 11 10111
21 14
1 *
2 1
22 1 11 11 11111
2 1 1
22 1 11 11 11111
22 1 11 11 11111
22 11 11 11111
22 11 11 11111
2 1 4
2
22 11 11 11111
22 1 11 11 11111
2 1
22 1 11 11 11111
22 1 11 11 11111
22 1 11 11 11111
22 1 11 11 11111
22 1 11 11 11111
22 1 11 11 11111
21 14
22 1 11 11 11111
22 1 11 11 11111
22 1 11 11 11111
22 1 11 11 11111
2 1 1
22 1 11 11 10111
2 1
22 1 11 11 10111
221 11
22 1 11 11 10111
2 1
22 1 11 11 101*11
21
22 1 11 11 10111
22 1 11 11 10111
2 1 1
22 1 11 11 10111
22 11
-------
-62-
2. Limitations of Data
In order to validate the Task Force data, a thorough
quality assurance/quality control review of the data was
conducted. Upon completion of analyses, the complete data
packages were simultaneously forwarded by the laboratories
to EPA's Sample Management Office (SMO), EPA-EMSL-Las Vegas,
and to the Ground Water Task Force's QA contractor (Life
Systems, Inc.) for completeness review, validation, and
evaluation. Final evaluation reports were then prepared
and transmitted to Region 9 and to the Agency's Ground
Water Task Force. Subsequently, the Task Force prepared a
summary which highlighted the findings from these reports,
and forwarded this product to the Region for final disposition,
Each of these reports are included in the Summary of the
Ground Water Sample Analysis Data report prepared by Kevin
Wong, Region 9 chemist in charge of RCRA data review. The
reader is referred to this report for complete details of
data results and validation.
Review of procedures used in the laboratories resulted
in several findings regarding the validity of the data pro-
vided the Task Force. Several analytical problems resulted
in detection limits too high for the level of accuracy needed
for a complete ground water evaluation. The laboratory
deviated from specified methods for analysis of semi-volatile
organics thus causing detection limits to be raised by 2 to
8 times acceptable levels. While the detection limits were
high, no values were detected above these limits. A table
of the contracted and actual detection limits achieved for
each sample is given in Appendix C.
Lack of adherence to laboratory extraction/concentration
procedures and poor chromatography had rendered the pesticide
and PCB data unusable with the recommendation that no
conclusions be drawn as to whether pesticides are present
in any sample. Inappropriate procedures have also rendered
the herbicide data inconclusive with a possibility of false
negatives.
Results from samples taken for analysis of radionuclides
and seven organosulfides have not been received in time by
the Task Force from the California Department of Health
Services - Hazardous Materials Laboratory in Berkeley where
they were sent per a State request. Consequently these
results cannot be discussed in this report.
Several analytical problems were discovered for a few
inorganic parameters analyzed, but they were not considered
significant. Otherwise, all volatile organics, metals, and
the other parameters analyzed are acceptable.
-------
-63-
Tentatively identified compounds or estimated data
that did not meet our minimum quality control requirements
is not reported or discussed in this document per Agency
policy. However, they can be the basis for further investi-
gation either by the Agency or the facility.
Several factors from EPA sample collection procedures
in the field could also have effected the data for certain
wells. Large time lag between purging and sample collection,
purging of less than two casing volumes, and construction
of the bailer access tubes as discussed previously could
have negatively biased the Task Force sampling results.
Parameter levels could actually be higher than reported due
to these field conditions. The Sampling and Documentation
report should be consulted for details.
3. Results of Task Force Data
Tabulated results of the Task Force data are provided
in Tables 10 and 11. Discussions of significant results and
parameters follow.
The Task Force data on 17 sampling points confirmed
the identification of a total of 3 different organic
constituents in Casmalia wells. In one well, B3B,
1,2-dichloroethane (DCA) was detected at a level of 5 ppb.
DCA was not found in any field or travel blanks so its
source is not considered to be lab or field contamination.
The most ubiquitous organic found in the samples was
tetrahydrofuran (THF), detected in eight facility wells;
C4M, CpH, C1B, WS4, A2M, A2B, C6B, and C4M. The Task Force
results confirmed the results submitted by the facility for
THF levels detected during interim status sampling. The
range in levels was from 2.5 to 780 ppb. The only significant
differences in the Task Force data and the facility data were
the high level of THF in well C6B and the detection of THF in
wells A2B and CpH. The level of THF in well C6B determined
from the Task Force data was 780 ppb in October 1985 as
compared to 200 ppb reported by the facility in November
1985. A2B and CpH are wells reportedly constructed with
threaded PVC casing, not glue, the suspected source of the
contamination in other wells. The facility had also not
previously reported THF in wells C4M and WS4. The concentra-
tions of THF could not be confirmed by our data reviewers
through the data validation process, as documentation for
standards and spectra were not provided. Therefore, the
data must be used with caution.
The only other quantifiable organic contaminant found
in a facility well was bis-(2-ethylhexyl)phthalate. This
was detected in well C-5 at a level of 16 ppb. Well C-5
is a gallery collection well located upgradient of the C-
barrier dam to collect accumulated ground water.
-------
Table 10. Summary of Organic Parameters Analyzed from October 1985
Ground Water Task Force Sampling at Casmalia Resources.
(units = ug/1 unless otherwise noted)
*D1M
DIMfb
*D1B
DIBre
B5
BSdup
BStrp
*B3B
B3Btb
*B3M
C5
C5re
CSdup
C5
bg*A18
AlBfb
TB:PE
*C4M
CpH
*C1B
WS4
WS4dup
WS4fb
Bspring
*A2M
*A2B
A2Bdup
EB
B6Bfb
B6b
CGBfb
*C6B
*C2M
C2NWup
7H
TB
PB
TUX
NR
36
257
225
323
41
76
1420
2140
2140
1260
21
76
24
18
12
34
44
408
133
5
96
60
67
mg/1 Methylene
POX TOC POC Chloride
5.9 5.7
0.59
5.7 0.11
22 0.17
16 20 0.23
35 NR 0.24
54 7.8
0.56
12 0.17
9 18
31 17
7.3
11
0.53
7.3
6.4
12
4.0
6.9
6.4
0.56
23 29 0.11
7 4.6
6 5.9
5.4
0.4
5.4
0.41
8.6 0.53
4.9 0.14
5.5
0.49 5.9
Acetone
13
13
11
14
11
15
11
13
22
12
14
14
11
12
32/28
2-Butanone
12
16
15
14
13
14
12
12
16
14
17
16
12
14
14
15
11
15
14
16
12
14
14
12
12
13
30
13
13
13
12
14
16/15
1 , 2-Dichloro- Tetrahydro- Bis ( 2-Ethylhexyl ]
Ethane Furan Phthalate
5
16
25
2.5
490
35
13
27
9.0
780
65
27
.£.
I
tb: ffeld blank, dup: duplicate,trp: triplicate,re: replicate,TB: travel blank,EB: equipment blank
CB: cooler blank, PE: performance evaluation sample, *: RCRA monitoring well, bg: background well, NR: not analyzed
Blank Space = Non-Detection
-------
T&ble 11. Summary of Inorganic Parameters Analyzed from October 1985
Ground Water Task Force Sampling at Casmalia Resources.
(units = mg/1 unless otherwise noted) (T/D = Total/Dissolved)
Aluminum Arsenic Cadmium
T/D T/D T
*D1M
DIMfb
*D1B 0.64/
DIBre NR — >
B5
B5dup
B5trp
*B3B 0.683/
B3Bfb
*B3M
C5
C5re NR — »
CSdup 0.029
C5 /NR 0.028
bg*A!B 0.021/
AlBfb /0.215
TB:PE NR — >
*C4M
CpH 0.771/ 0.453
*C1B
WS4
WS4dup
WS4tb
Bspring 36. 6/ .044/.028
*A2M
*A2B 0.017
A2Bdup 0.18
EB /NR — »
B6Bfb 0.006
B6B 0.636/
C6Bfb
*C6B
*C2M 0.031/ 0.014
C2Mdup 0.008
CB NR — »
TB
Calcium
139
106
981
991
944
199
657
673
763
773
177
262
124
161
101
100
784
569
469
493
129
235
416
391
6.79
Chromium Copper Iron Lead Magnesium
T T T T T
.041 0.366 0.022 71.9
.065 1.82 0.02 76.9
18.6
18.8
17.9
0.373 1.23 0.102
0.005
3.62
0.231 2.88 0.614
.098 0.63 0.025
1.43 0.126
0.51 0.282
13.1
13.1
.086 92.2
0.246
2.20
2.33
2.17 0.015
.041
0.012
.033 0.15 0.051
642
652
620
110
482
551
622
605
210
137
69.7
57.8
57.7
702
408
654
672
94.7
299
274
Manganese
T
0.162
0.434
5.28
5.33
5.07
0.216
0.052
3.52
4.00
4.03
0.376
0.632
0.364
1.27
1.27
6.27
0.498
0.526
0.262
0.767
0.675
Nickel Potassium
T T
20.0
30.2
11.3
0.309 27.9
0.363 31.2
0.348 29.5 ^
78.2 in
I
7.85
28.2
41.3
12.6
12.6
27.8
45.8
47.0
16.6
16.1
0.054 17.2
0.059 15.3
fb: field blank, dup: duplicate, trp: triplicate, re: replicate, TB: travel blank, EB: equipment blank
CB: cooler blank, PE: performance evaluation sample, *: RCRA monitoring well, bg: background well, NR: not analyzed
Blank Space = Non-Detection
-------
Table 11. Continued
•Total Total
Selenium Sodium Vanadium Zinc Nitrate Alkalinity Chloride Fluoride Sulfate Phenolics Ammonia pH SpC
D T T D unv/cm
*D1M
DIMfb
*D1B
UlBre
B5
BSdup
BStrp
*B3B
B3Bfb
*B3M
C5
C5re
CSdup
C5
bg*A!B
AlBfb
TB:PE
*C4M
CpH
*C1B
WS4
WS4dup
WS4fb
Bspring
*A2M
*A2B
A2Bdup
EB
B6BEb
B6B
C6Bfb
*C6B
*C2M
C2Mdup
CB
TB
tb: field
427
637
NR — »
2150
2180
2080
1010
1590
1660
NR — >
1880
1850
1280
NR — >
671
0.10 1050
832
311
310
2550
1180
1550
1600
766
775 0.061
999
917
NR — »
7.42
blank, dup: duplicate,
.023
.076
.173
.054
.053
.230
.064
.027
.081
.075
.028
.031
.240
.047
.025
.080
trp:
5.1
2.6
1.3
1.4
1.0
1.4
7.0
8.5
9.5
16.0
1.4
0.7
0.8
1.1
1.2
1.1
22.0
2.0
1.8
0.4
0.9
1.3
1.3
1.0
triplicate,
227
335
274
363
343
475
220
314
309
821
203
886
150
345
495
369
162
479
489
512
77
422
414
30
576
522
4860
4850
4870
1240
2950
3670
3650
888
1140
1120
1360
268
283
4800
1260
1450
1480
926
4.5
900
1160
1190
4.2
re: replicate, TB:
0.40
0.34
0.31
0.31
0.31
0.21
0.26
0.74
0.70
0.22
0.52
0.34
0.19
0.82
0.80
1.00
0.52
0.52
0.52
0.21
0.15
0.72
0.70
travel
700
1080
2620
2610
2610
780
6900
2880
2900
2610
730
395
506
312
315
6
2960
3370
3900
4000
590
700
2050
1090
blank, EB:
10.
0.02 1.3
1.3
1.3
0.8
0.1
0.4
0.4
45
0.3
22
18
0.04 6.4
0.014 6.6
0.8
29
31
14
11
0.2
0.1
equipment blank
6-7
6-7
6-7
6.8
6.5
6.3
7.1
6.5
7.6
10.4
6.4
6.5
7.5
6.8
7.1
9.3
6.5
2600
2700
12800
5300
11100
13600
7000
4500
5100
4700
1800
14400
8000
10600
3400
2900
4800
CB: cooler blank,
Blank Space = Non-
PE: performance evaluation sample,
Detection
*: RCRA monitoring well, bg: background well,
NR: not analyzed
-------
-67-
Three additional organics were identified in the
samples, 2-butanone, methylene chloride, and acetone.
However, all were determined to be present in all or most
of the field and laboratory blanks. Therefore these cons-
tituents are considered to be artifacts due to laboratory
contamination and not present in the ground water.
Samples from three wells C5, A1B, and C4M indicated
the presence of Total Organic Halides (TOX) at concentrations
greater than 1000 ppb. Well A1B, the designated background
well had the highest level of 2140 ppb as did a duplicate
sample of well C5. The original C5 reading was 1420 ppb.
Well C4M had a level of 1260 ppb. All other sampling
points reported levels between 12 and 323 ppb. None of the
high TOX values correlated to any sampling point where
speciated organics were recorded.
Purgeable organic halides (POX) concentrations were
detected at six sampling points B5, B3B, C5, B-spring, A2M,
and A2B, ranging from 6 to 54 ppb. However, these results
have not been verified by the detection of specific volatile
organic compounds analyzed.
Values for pH ranged from 6.3 (B3M) to 10.4 (C1B) and
specific conductivity values ranged from 2600 um/cm (DIM) to
14400 um/cm (B spring).
Several inorganic constituents of interest appeared in
the analyses at some sampling points. Arsenic was detected
in the background well A1B (21 ppb) and in the B-canyon
ground water spring (B-spring)(44 ppb total and 28 ppb
dissolved). None of the arsenic values exceeded federal
drinking water standards. Cadmium was detected in wells
C5, CpH, A2B and C2M in concentrations ranging from 14 ppb
(C2M) to 453 ppb (CpH). All other values for cadmium and
arsenic were below detection limits. The only chromium
value reported above detection limits was 86 ppb found in
the B canyon ground water spring. Maximum contamination
levels for federal drinking water standards for cadmium is
10 ppb and for chromium is 50 ppb. Lead was detected in
wells B3B, AlB, CpH, and C2M in concentrations ranging from
614 ppb (AlB) to 51 ppb (C2M). The maximum contamination
level for lead is 50 ppb.
Total phenols were reported above detection limits in
two ground water samples. Gallery well B5 had a level of
20 ppb and water supply well WS4 had a level of 40 ppb.
-------
-68-
REFERENCES
RCRA Ground Water Investigation, Casmalia Resources,
Kenneth Yelsey, USEPA Region 9, Report Number R(84)E031,
March 1984.
Geologic and Hydrogeologic Aspects, Hunter Disposal Site,
Casmalia, California, Alden Loomis Associates, 1972.
Hydrogeologic Characteristics of Proposed Western Expansion,
Casmalia Disposal Site, Alden Loomis Associates, 1980.
Project Plan, Hazardous Waste Ground Water Task Force,
Casmalia Resources, Casmalia, California, Mark Filippini
USEPA Region 9, October 1985.
Casmalia Resources Ground Water Sample Plan, Peter
Rubenstein, USEPA Region 9, October 18, 1985.
Casmalia Resources Laboratory Audit Plan, Kevin W. Wong,
USEPA Region 9, October 16, 1985.
Casmalia Resources Sampling Audit Plan, Peter Rubenstein,
USEPA Region 9, October 18, 1985.
Casmalia Resources Ground Water Sampling Audit Report, Peter
Rubenstein, USEPA Region 9, March 1986.
Casmalia Resources Sampling and Documentation Report, Peter
Rubenstein, USEPA Region 9, March 1986.
Laboratory Audit Report, Casmalia Resources, Kevin Wong,
USEPA Region 9, April 1986.
Summary of the Ground Water Sample and Analysis Data,
Casmalia Resources, Kevin Wong, USEPA Region 9, April
1986.
Notice of Deficency issued to Casmalia Resources
March 7, 1986 by USEPA Region 9.
-------
APPENDIX A
Analytical Parameters for Ground Water and Leachate Samples
-------
Appendix A
Analytical Parameters for Groundwater and Leachate Samples
Volatiles
Chloromethane
Bromomethane
Vinyl chloride
Chloroethane
Methylene chloride
Acetone
Carbon disulfide
1,1-Dichloroethene
1,1-Dichloroethane
trans-1,2-Dichloroethene
Chloroform
1,2-Dichloroethane
2-Butanone
1,1,1-Trichloroethane
Carbon tetrachloride
Vinyl acetate
BromodiChloromethane
1,1,2,2-Tetrachloroethane
1,2-Dichloropropane
trans-1,3-Dichloropropene
Trichloroethene
Dibromochloromethane
1,1,2-Trichloroethane
Benzene
cis-1,3-Dichloropropene
2-Chloroethyl vinyl ether
Bromoform
2-Hexanone
4-Methyl-2-pentanone
Tetrachloroethene
Toluene
Chlorobenzene
Ethyl benzene
Styrene
Total xylenes
Acrolein
Acrylonitrile
1,2-Dibromo-3-chloropropane
1,2-Dichloroethene
1,4-Dioxane
Pyridine
1,2,4,5-Tetrachlorobenzene
1,2,3,4-Tetrachlorobenzene
Ethylene dibromide (EDB)
A - 1
-------
Semi-Volatiles
N-Nitrosodimethylamine
Phenol
Aniline
bis(2-Chloroethyl) ether
2-Chlorophenol
1,3-Dichlorobenzene
1,4-Dichlorobenzene
Benzyl alcohol
1,2-Dichlorobenzene
2-Methylphenol
bis(2-Chloroisopropyl) ether
4-Methylphenol
N-Nitrosodipropylamine
Hexachloroethane
Nitrobenzene
Isophorone
2-Nitrophenol
2,4-Dimethylphenol
Benzole acid
bis(2-Chloroethoxy) methane
2,4-Dichlorophenol
1,2,4-Trichlorobenzene
Naphthalene
4-Chloroaniline
Hexachlorobutadiene
4-Chloro-3-methylphenol
(para-chloro-meta-cresol)
2-Methylnaphthalene
Hexachlorocyclopentadiene
2,4,6-Trichlorophenol
2,4,5-Trichlorophenol
2-Chloronaphthalene
2-Nitroaniline
Dimethyl phthalate
Acenaphthylene
3-Nitroaniline
Acenaphthene
2,4-Dinitrophenol
4-Nitrophenol
Dibenzofuran
2,4-Di ni trotoluene
2,6-Dinitrotoluene
Diethyl phthalate
4-Chlorophenyl phenyl ether
Fluorene
4-Nitroaniline
4,6-Dinitro-2-methylphenol
N-Nitrosodiphenylamine
4-Bromophenyl phenyl ether
Hexachlorobenzene
Pentachlorophenol
Phenanthrene
Anthracene
Di-n-butyl phthalate
Fluoranthene
Benzidine
Pyrene
Butyl benzyl phthalate
3,3'-Dichlorobenzidine
Benzo(a)anthracene
bis(2-ethylhexyl)phthalate
Chrysene
Di-n-octyl phthalate
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(l,2,3-cd)pyrene
Dibenz(a,h)anthracene
Benzo(g,h,i Jperylene
Benz [a]anthracene .
Benzyl chloride
2,4-Dichlorophenoxyacetic acid
2,4,5-Trichlorophenoxyacetic acid
Diphenylamine
1,2,4,5-Tetrachlorobenzene
1,2,3,4-Tetrachlorobenzene
Pentachloronitrobenzene (PCNB)
Tetrahydrofurans
Pentachlorobenzene
1,4-Dioxane
A - 2
-------
Pesticides
alpha-BHC Endrin aldehyde
beta-BHC Endosulfan sulfate
delta-BHC 4,4'-DDT
gamma-BHC (Lindane) Endrin ketone
Heptachlor Methoxychlor
Aldrin Chlordane
Heptachlor epoxide Toxaphene
Endosulfan I AROCLOR-1016
Dieldrin AROCLOR-1221
4,4'-DDE AROCLOR-1232
Endrin AROCLOR-1242
Endosulfan II AROCLOR-1248
4,4'-DDD AROCLOR-1254
AROCLOR-1260
Metals (Dissolved and Total)
Aluminum Magnesium
Antimony Manganese
Arsenic Mercury
Barium Molybdenum
Beryllium Nickel
Boron Potassium
Cadmium Selenium
Calcium Silver
Chromium Sodium
Cobalt Thallium
Copper Tin
Iron Vanadium
Lead Zinc
Silica
A - 3
-------
Misc. (via the CLP)
Purgeable organic carbons (POC)
Total organic carbon (TOO
Purgeable organic halogens (POX)
Total organic halogens (TOX)
Alkalinity
Ammonia
Chlorides
Fluorides
Sulfates
Nitrates
Phenolics
Cyanide
Misc. (via CA DOHS lab)
Organosulfides
Gross alpha
Gross beta
Uranium
Radium, total
Radium 226
A - 4
-------
APPENDIX B
Table of Water Level Measurements from
November 1985 Task Force Sampling
-------
Appendix B
Table of Water Level Measurements from November 1985 Task
Force Sampling
November 1985 Task Force
Measurements (feet)
Well
Number
A1B
A2M
A2B
B3M
B3B
C1B
C2M
C4M
C6B
DIM
DIB
Surveyed Elevations (feet)
Top of Well Casing
808.01
419.14
452.84
385.97
384.56
439.06
448.56
456.16
453.91
478.45
478.86
Depth to
Water
164.96
7.18
13.26
5.91
55.09
68.06
33.71
50.97
81.15
17.79
20.53
Elevation of
Water (MSL)
643.05
411.96
439.58
380.06
329.47
371.00
414.85
405.19
372.76
460.66
458.33
-------
APPENDIX C
Contractual and Actual Laboratory Limits of
Quantification for Organic Compounds
-------
APPENDIX C
CONTRACTUAL AND ACTUAL LABORATORY LIMITS OF QUANTITATION FOR ORGANIC COMPOUNDS
VOLATILES
Contract Limit of
Quantitation
(ug/1)
Contract Limit of
Quantitation
(ug/1)
Chlorome thane
Bromome thane
Vinyl chloride
Chioroethane
Methylene chloride
Acetone
Carbon disulfide
1,1-Dichloroethene
1,1-Dichloroethane
trans-1,2-Dichloroethene
Chloroform
1,2-Dichloroethane
2-Butanone
1,1,1-Trichloroethane
Carbon tetrachloride
Vinyl acetate
Bromodichloromethane
1,1,2,2-Tetrachloroethane
1,2-Dichloroprcpane
trans-1,3-Dicnloropropene
Tr i chloroethene
Dibromochloromethane
10 1,1,2-Tr i chloroethane
10 Benzene
10 cis-1,3-Dichloropropene
10 2-Chloroethyl vinyl ether
5 Bromoform
100 2-Hexanone
5 4-Methyl-2-pentanone
5 Tetrachloroethene
5 Toluene
5 Chlorobenzene
5 Ethyl benzene
5 Styrene
20 Total xylenes
5 Acrolein
5 Acrylonitrile
10 l,2-Dibromo-3-chloroprcpane
5 1,2-Dichloroethene
5 1,4-Dioxane
5 Pyridine
5 Ethylene dibronide (EDB)
5
5
5
5
5
10
b
10
10
5
5
5
5
5
5
500
500
100
NA*
SOU
100
NA*
Multiplication Factors for Determining Actual Limits of Quantitation:
xl: all samples
* Not analyzed
C - 1
-------
Semi-Volatiles
Contract Limit of
Quantitation
(ug/1)
Contract Limit of
Quantitat ion
(ug/1)
N-Nitrosodimethylamine NA*
Phenol 10
Aniline 20
bis(2-Chloroethyl) ether 10
2-Chlorophenol 10
1,3-Dichlorobenzene 10
1,4-Dichlorobenzene 10
Benzyl alcohol 10
1,2-Di chlorobe nzene 10
2-Methylphenol 10
bis(2-Chloroisoprcpyl) etner 10
4-Methylphenol 10
N-Nitrosodiprcpylamine 10
Hexachloroethane 10
Nitrobenzene 10
Isophorone 10
2-Nitrophenol 10
2,4-Dimethylphenol 10
Benzoic acid 50
bis(2-Chloroethoxy) methane 10
2,4-Dichlorophenol 10
1,2,4-Trichlorobenzene 10
Naphthalene 10
4-Chloroaniline 10
Hexachlorobutadiene 10
4-Chloro-3-methylphenol 10
(para-chloro-neta-cresol)
2-Methy1naphthalene 10
Hexachlorocyclcpentadiene 10
2,4,6-Tr ichlorophenol 10
2,4,5-Trichlorophenol 50
2-Chloronaphthalene 10
2-Nitroaniline 50
Dimethyl phthalate 10
Acenaphthylene 10
3-Nitroaniline 50
Acenaphthene 10
2,4-Dinitrophenol 50
4-Nitrophenol 50
Dibenzofuran 10
2,4-Dinitrotoluene 10
2,6-Dinitrotoluene 10
Diethyl phthalate 10
4-Chlorophenyl phenyl ether 10
Fluorene 10
4-Nitroaniline 50
4,6-Dinitro-2-methylphenol 50
N-Nitrosodiphenylamine 10
4-Bromophenyl phenyl ether 10
Hexachlorobenzene 10
Pentachlorophenol 50
Phenanthrene 10
Anthracene 10
Di-n-butyl phthalate 1U
Fluoranthene 10
Benzidine 100
Pyrene 10
Butyl benzyl phthalate 10
3,3'-Dichlorobenzidine 20
Benzo(a)anthracene 10
bis(2-ethylhexyl)phthalate 10
Chrysene 10
Di-n-octyl phthaiate 10
Benzo(b)fluoranthene 10
Benzo(k)fluoranthene 10
Benzo(a)pyrene 10
Indeno(1,2,3-cd)pyrene 10
Dibenz(a,h)anthracene 10
Benzo(g,h,i)perylene 10
Benzyl chloride 10
2,4-Dichlorophenoxyacetic acid 0.25
2,4,5-Trichlorophenoxy- 0.05
proprionic acid
2,4,5-Trichlorophenoxyacetic acid O.Ob
Diphenylamine
1,2,4,5-Tetrachlorobenzene
1,2,3,4-Tetrachlorobenzene
Pentachloronitrobenzene (PCNB)
Pentachlorobenzene
Te trahydrofurans
NA*
10
10
10
10
10
Multiplication Factors for Determining Actual Limits of Quantitation:
x2: Samples Q0258 Q0260RE Q0265 QO267 Q0282 Q0284 Q0292 Q0305
Q0259 Q0261 Q0265RE Q0268 Q0282RE Q0286 Q0293 Q0306
Q0259RE Q0263 Q0266 QO279 Q0283 Q0288 Q0294
Q0260 Q0264 Q0266RE Q0281 QO283RE Q0290 Q0295
x4: Samples QO257 QO261 QO261RE QO262 Q0272 Q0280 Q0285 Q0287 QO289
x8: Sample QO256
* Not Analyzed
C - 2
-------
Pesticides
Contract Limit of
Quantitation
(ug/1)
alpha-BHC 0.05
beta-BHC O.Ob
delta-BHC 0.05
ganima-BHC (Lindane) 0.05
Heptachlor 0.05
Aldrin 0.05
Heptachlor epoxide 0.05
Endosulfan I 0.05
Dieldrin 0.10
4,4'-DDE 0.10
Endrin 0.10
Endosulfan II 0.10
4,4'-DDD 0.10
Endrin aldehyde 0.10
Endosulfan sulfate . 0.10
4,4'-DDT 0.10
Endrin ketone 0.10
Methoxychlor 0.50
Chlordane 0.50
Toxaphene 1.00
AROODR-1016 0.50
AROCLOR-1221 0.50
AROCLOR-1232 0.50
AROCLOR-1242 0.50
AROCLDR-1248 0.50
AROCLOR-1254 1.00
AROCLOR-1260 1.00
Multiplication Factors for Determining Actual Limits of Quantitation:
x2.5: Samples QO258 Q0265 Q0282 Q0290 Q0305
00259 Q0266 QO283 QO291 Q0306
Q0260 Q0267 Q0284 Q0292
00261 QO268 00285 00293
Q0263 Q0279 Q0286 Q0294
Q0264 Q0280 QO287 Q0295
x5: Samples 00257
Q0262
Q0272
Q02 81
00288
00289
xlO: Sample QO288RI
C - 3
------- |