October 1986
Hazardous Waste Gro
Task Force
Evaluation of
CECOS International
Livingston, Louisian
*3 UNITED STATES ENVIRONME1
; LOUISIANA DEPARTMENT OF
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Protection Agency
L-12J)
auievard, 12th Floor
4-3590
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VI
1201 ELM STREET
DALLAS. TEXAS 7527O
September 30, 1986
UPDATE OF THE HAZARDOUS HASTE GROUND-MATER TASK FORCE
EVALUATION OF CECOS INTERNATIONAL, INC.
LIVINGSTON, LA FACILITY
The Hazardous Waste Ground-Water Task Force (Task Force) of the
Environmental Protection Agency in conjunction with the Louisiana Department
of Environmental Quality (LDEQ) conducted an evaluation of the ground-
water monitoring program at the CECOS International, Inc., Livingston, LA
(CECOS). hazardous waste treatment, storage, and disposal facility. The
on-site field inspection was conducted over a two-week period from December
9, 1985 to December 18, 1985. CECOS is one of over 50 facilities that
are to be evaluated by the Task Force.
The purpose of the Task Force evaluations is to determine the
adequacy of ground-water monitoring programs at land disposal facilities
in regard to applicable State and Federal ground-water Monitoring
requirements. The evaluation focused on (1) determining If the facility
was in compliance with applicable regulatory requirements and policy, (2)
determining if hazardous constituents were present In the ground water
beyond the known plume of contamination, and (3) providing Information to
assist EPA in determining if the facility meets the EPA requirements for
facilities receiving waste from response actions conducted under the
Federal Superfund program.
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Prior to the Task Force evaluation, a Comprehensive Ground-Water
Monitoring Evaluation (CME) with sampling was conducted by representatives
from LDEQ and EPA Region VI at the facility on March 24-27, 1985. Based
on the results of this inspection, the LDEQ required the facility to
conduct a ground-water quality assessment program for contamination
stemming from pre-RCRA SWECO landfill cells.
Presently, the CECOS assessment study has not been completed, the
final assessment report is due to be submitted to LDEQ by November 1986.
LDEQ upon receipt of the assessment study will evaluate its findings
along with those stated in the Task Force report.
Based on the Task Force report the following actions will be required:
1) Further site characterization with respect to shallow and deep
aquifer flow directions and rates in all areas of the site;
2) Determine the influence of 'The Lake' in the northwest corner
of the site, on the upgradient wells.
3) Assessment of elevated metals detected in Task Force sample results;
and
4) Assessment of the cause for the slight contamination detected in
upgradient wells.
These actions can be modified contingent upon review of the assessment study.
Through a permit modification LDEQ is regrouping the waste management
areas and moving the point of compliance closer to the existing units.
This would increase the number of interior monitoring wells and improve
the systems' ability to immediately detect a release from the units. LDEQ
is currently studying proper well placement to better delineate the area.
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LDEQ has determined that the old solidification storage and the #2
rainwater storage basin are regulated units due to their past usage and
contents. These units will be added to the ground-water monitoring system
in the near future. LDEQ will notify CECOS of this through a letter of
notification.
LDEQ will be issuing a compliance order to CECOS for two issues:
1) Upgradient monitoring wells have inadequate construction detail
records and are suspected of being below RCRA construction standards;
and
2) Actual sampling practices contradicts those specified in the
approved sampling plan as specified in the permit application. .
Finally wells deemed unacceptable by LDEO will be propenly plugged and
abandoned. This action will take place in the permitting process.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUND-WATER TASK FORCE
GROUND-WATER MONITORING EVALUATION
BROWNING-FERRIS INDUSTRIES/CECOS
LIVINGSTON FACILITY
LIVINGSTON, LOUISIANA
SEPTEMBER 1986
U.S. EPA Region VI
Dallas, Texas
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CONTENTS
I. EXECUTIVE SUMMARY
A. Introduction 4
1. Task Force Objectives 4
2. Participants 6
B. Summary of Findings and Conclusions 7
1. Ground-Water Monitoring Program During Interim Status ...9
a. Direction of Ground-Water Flow 9
b. Background Wells 9
c. Downgradient Wells 10
d. Sampling and Analysis Plan 10
2. Assessment Monitoring 12
3. Sampling Results ; 12
II. TECHNICAL REPORT
A. Facility Background 13
B. Waste Management Units 16
C. Site Geology 19
D. Site Hydrology 22
Shallow Sand Aquifer 23
Deep Sand Aquifer 24
E. Ground-Water Monitoring System 26
Well Construction Details 26
RCRA Compliance Monitoring System 28
Sampling and Analysis Plan 30
F. Sample Analysis and Data Quality Evaluation 32
G. Task Force Sampling Results 40
Limitations of Data 41
H. Ground-Water Assessment Monitoring System 45
REFERENCES 48
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Attachment 1
FIGURES
1 Location Map for the CECOS Facility
2 Location Map for Existing Landfill Cells
3 Location Map for Future Landfill Cells
4 Surface Watersheds of the Amite and Tickfaw Rivers
5 Generalized Stratigraphic Section
6 Potentiometric Map for the Shallow Aquifer
7 Shallow Monitoring Wells Location Map
8 Deep Monitoring Wells Location Map
9 Graphic Display of Monitoring Well Completion Depths
10 Diagram of MW-Series Well Construction
11 Diagram of OW-Series Well Construction
12 TOX Contour Map of Contaminant Plume — Shallow Aquifer
13 TOX Contour Map of Contaminant Plume — Deep Aquifer
Attachment 2
TABLES
1 Enforcement History
2 Private Water Wells Within a Two Mile Radius of the CECOS Site
3 Hydraulic Conductivities of Select Formations
4 Stages of Well Installation at the CECOS Site
5 Well Location and Construction Details
6 West-Paine Laboratories, Inc., TOX Data Sheet
7 Task Force Sampling Locations
Attachment 3
Parameters Analyzed
Task Force Sampling Results
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I. EXECUTIVE SUMMARY
A. INTRODUCTION
1. Task Force Objectives
Congress has raised concerns as to whether commercial and on-site
hazardous waste treatment, storage, and disposal facilities (TSDFs)
are in compliance with the ground-water monitoring requirements
promulgated under the Resource Conservation and Recovery Act (RCRA).
Specifically, questions have been raised about the ability of
existing or proposed ground-water monitoring systems to detect
contaminants released from waste management units. Under current
policy, specific land disposal units used for Superfund wastes must
be in compliance with the Part 265 ground-water monitoring require-
ments.* The results of this investigation will determine the
ability of this site to meet the policy's requirements.
To evaluate the ground-water monitoring systems and determine TSDFs
current compliance status, the Administrator of the Environmental
Protection Agency (EPA) established the Hazardous Waste Ground-Water
Task Force. The task force is comprised of personnel from EPA
headquarters, National Enforcement Investigation Center (NEIC),
regional offices, and state regulatory agencies. The task force is
evaluating 58 sites nationwide.
The second TSDF investigated in EPA, Region 6, and the tenth
investigation nationwide by the task force was the CECOS
International, Inc., facility located in Livingston, Louisiana.
* May 6, 1985 memorandum from Jack McGraw, Acting Assistant Administrator,
on "Procedures for Planning and Implementing Off-Site Responses".
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The on-site inspection was conducted between December 9 and 18,
1985. The lab evaluations were conducted by NEIC between
November 1985 and January 1986. NEIC, in addition, conducted
a multimedia investigation between November 19 and 27, 1985 and
January 20 and 24, 1986 as part of the facility's evaluation.
NEIC prepared a separate report that evaluated the site's
operations, stormwater management, surface water discharges,
air controls and monitoring, operating and waste analysis records,
preparedness and prevention, training, and closure/postclosure
plans. The task force evaluation focused on compliance with
RCRA Subpart F ground-water monitoring requirements and were
not addressed in NEIC's report. Specific task force objectives
addressed during the inspection were determinations as to
whether:
a. The ground-water monitoring system at CECOS could immediately
detect statistically significant amounts of hazardous waste or
hazardous waste constituents that may have migrated from the
waste management areas to the uppermost aquifer underlying the
facility.
b. CECOS's designated RCRA monitoring wells were properly located
and constructed.
c. CECOS had developed and was following an effective plan for
ground-water sampling and analysis.
d. The ground-water quality assessment program at CECOS is
effective in defining the rate and extent of ground-water
contamination beneath the site.
e. Samples have been collected properly.
f. Analyses were reliable, i.e., quality of data.
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Subsequent to extensive file reviews, EPA and the Louisiana
Department of Environmental Quality (LDEQ) jointly conducted a week
and a half field investigation at the CECOS Livingston facility
between December 9 and 18, 1985. This included an exhaustive collection
and review of all available geologic and hydrologic data, well
construction details, ground-water modeling efforts, and sampling of
22 monitoring wells and leachate collection systems for Appendix
VIII constituents. The sampling efforts were directed at identifying
and determining the rate and extent of ground-water contamination
which had previously been detected at the site by the facility.
2. Participants
Much of the information presented in this report was obtained by a
review of EPA, Region 6 (Dallas), and Louisiana environmental
regulatory agency files, as well as discussion with EPA and state
staffs. The EPA Region 6 Project Team included Mr. Steven Schwartz,
RCRA program Hydrologist, and Ms. Robin Seguin, RCRA Environmental
Specialist. Core team assistance and coordination for the project
was provided by Mr. Brian Lewis, Engineering Geologist, State of
California, on assignment to EPA. Field assistance was provided by
Mr. Joseph Hebert, Geologist, LDEQ. Mr. Richard Ross, Mr. James
Slovinski, and Mr. Tim Meszaros from NEIC conducted the lab audits.
Mr. Darcy Higgins, Mr. .Don Paquette, Mr. Scott Slagley, and
Ms. Alicia Fleitas represented the contract sampling team for
Versar, Inc., of Springfield, Virginia. Howard Wilson represented
the Office of Waste Program Enforcement, EPA, Headquarters.
State file reviews included the Hazardous Waste, Ground-Water,and
Air Quality Divisions of LDEQ. Inverviews were conducted with
Mr. George Cramer, Administrator for Ground-Water Protection
Division; Mr. Maurice Laserre, Geologist, Ground-Water Protection
Division; Mr. Gus Von Bodungen, Administrator, Air Quality Division;
and Mr. Tom Coerver, Enforcement Program Manager.
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B. SUMMARY OF FINDINGS AND CONCLUSIONS
The-findings and conclusions presented in this report reflect the
conditions existing at the facility and practices used by the facility at
the time of the task force investigation in December 1985. Subsequent
actions taken by the facility, the State, and Region 6 since the
investigation are summarized in the accompanying update cover memo
attached to this report.
Task force personnel investigated the interim status ground-water
monitoring program at the Livingston facility for the period between
November 1980, when applicable provisions of the RCRA regulations became
effective, and December 1985. The investigation indicated that, although
the monitoring program had improved considerably since 1980, some parts
are inadequate and do not fully comply with state requirements. The
assessment program around the SWECO* and early BFI cells was also
evaluated. It, too, was found to be inadequate.
In general, the site is located in an area of a high water table. Slurry
walls and extraction pumps are needed during the construction of new
cells. During the construction of cell 15, task force personnel observed
substantial sand seams 5 to 12 feet in thickness in the side wall of the
cell. Because of the high water table, thick sand seams, and past
disposal practices, contamination at this site will probably be a
continual problem. Removal of the pre-RCRA SWECO cells and some of the
early BFI cells may be necessary to close them.
During the December 1985 inspection, task force personnel collected
samples from 18 ground-water monitoring wells, 2 leachate collection
sumps, and leachate detection systems from both the Rainwater Pond 2 and
the enclosed solidification building which contains four mixing basins
and became operational in July 1985.
Southwest Environmental Company (SWECO) operated the site between May
1977 to June 1978.
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Well 21, completed in the shallower 30-foot zone, contained a variety
of listed chlorinated hydrocarbons, solvents, and herbicides including
9,400ppb 2,4-D, 77,000ppb 1,2-dichloroethane, and 630ppb 2,4,5-T.
Monitor well MW-20, completed in the deeper 60-foot zone, also contained
numerous chlorinated hydrocarbons and solvents although herbicides were
absent. Compounds identified include 7,600ppb 1-2-dichloroethane and
2,000ppb 2-chlorophenol. Some of the contaminates identified in MW-20
and MW-21 were identical, but exhibited decreasing concentration with
depth.
The task force sampling confirmed that these two wells (MW-20 and MW-21)
that triggered the assessment clearly contain organic hazardous waste
constituents.
In addition to hazardous organic waste contamination, two wells (MW-1 and
OW-1) contained toxic metal contamination in excess of the Federal
Primary Drinking Water Standards (FPDWS). Monitor well MW-1 contained
barium, cadmium, and chromium. Well OW-1 contained elevated levels of
cadmium, chromium, and lead. One additional well, MW-29, contained
chromium slightly in excess of the FPDWS.
The TOX was elevated at 70ppb for the leachate detection system
underlying the southern half of the enclosed solidification building.
Under current EPA policy, if an off-site TSDF must be used for land
disposal of waste from a Superfund cleanup of a Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) site,
that site must be in compliance with the applicable technical require-
ments of RCRA. Interim status facilities must have adequate ground-water
monitoring data to assess whether the facility poses a threat to ground-
water. Some parts of the ground-water monitoring and assessment program
were inadequate and did not fully comply with state requirements.
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The following is a more detailed summary of the inspection findings and
conclusions:
1. Ground-Water Monitoring Program During Interim Status
As of December 1985, the BFI-CECOS Livingston facility did not have
an adequate interim status ground-water monitoring program.
Components of the ground-water monitoring program, Including the
ground-water sampling and analysis plan, monitoring well network,
sample handling procedures, and the assessment program, need
improvement. Sample analyses conducted as part of the detection and
assessment monitoring do not fully comply with applicable state
requirements.
A ground-water monitoring program plan, which formed the basis of
the December 1985 program, was approved by LDEQ in July 1985.
The findings described below reflect Task Force evaluations of the
on-going assessment and detection monitoring program.
a. Direction of Ground-Water Flow
Ground-water flow direction and rates need to be better
determined in portions of the shallow and deeper aquifer. For
the shallow zone, the area around the "monofill"* and BFI cells
5S, 5, 10, 11, 12, and 12L need piezometers to better define
the direction of ground-water flow both horizontally and
vertically. The water level information is for the most part
projected from the perimeter of the site to the cells in the
* This is a CECOS term and is not a "monofill" as defined by RCRA. CECOS
used the term to denote that it receives waste from one company, but
there are multiple waste streams.
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center of the site. The deeper zone is even less well defined
throughout the site. The facility's November 1985 water level data
was used to draw contour maps for both zones, but some of the
data was not incorporated because several wells were monitoring
a zone not representative of the shallow or deeper aquifers. The
vertical gradients need to be better defined throughout the site.
b. Background Wells
The site currently has two background wells, D-7 and D-8.
These wells were installed in 1977-78. No construction
drawings are available for these wells. The integrity of
annual seals and gravel pack material is not known. Well D-8
has elevated TOX values. The cause of the elevated TOX
values should be investigated. These background wells
should be replaced because of the sketchy information on the
construction of these wells and the elevated TOX values. It
also is not known what influence the recreational lake on
the northwest corner of the site would be having on these
wells.
c. Downgradient Wells
The perimeter detection monitoring system cannot immediately
detect any statistically significant amounts of hazardous waste
constituents that migrate from the waste management area to the
uppermost aquifer. Additional downgradient wells around
current and past waste management areas need to be installed.
The location of these wells should be based on the additional
piezometric data needed to better define the direction of
ground-water flow. Closer well spacing is needed, especially
in parts of the site where eight to ten-foot sand beds have
been identified in borings and excavations.
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Currently, PYC pipe with glued joints is the casing material
installed. Stainless steel 304 or 316 or Teflon® resins
casing materials should be installed for all future wells.
Potentially sorbing organic constituents are present in the
groundwater and have been disposed of on site. Inert casing
material, therefore, is the recommended material.
d. Sampling and Analysis Plan
Dedicated PVC bailers are used for sampling. However,
teflon or stainless steel bottom filling bailers or bladder
pumps constructed of inert material are the recommended
sampling method. The facility fills their sample containers by
inverting the bailer. This method agitates and aerates the
samples. The facility should be using a bottom emptying device
to fill sample containers.
The facility does not use any field or equipment blanks. Also,
the facility's contract lab was performing only minimum quality
assurance/quality control (QA/QC) on the facility's samples. The
reliability of the facility's historical data cannot be quantified.
Insufficient purge volumes were withdrawn from some wells
because the facility had not measured the total depth on any of
the wells. The task force personnel found some wells up to
five feet deeper than the depths used by the facility's
• The use of the term "teflon" in this report by U. S. EPA is purely as a
generic expression for polytetrafluoroethylene (PTFE) materials and in no
way is meant to serve as an endorsement of PTFE products under the U. S.
Trademark name of E. I. DuPont DeNemours and Company. It will appear
hereafter without ®.
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sampling crew to calculate purge volumes. Also, four wells
were found to be four-inch wells rather than what the
facility's crew assumed to be three-inch wells.
2. Assessment Monitoring
The facility was following an assessment plan approved with
modifications by DEQ. The TOX parameter was the primary method of
screening a well sample to determine whether or not further analysis was
needed. However, the lab audit showed that the lab for the facility
was not achieving the detection limit. So far, only the TOX
data has been used which has proven to be invalid. The facility
should be using parameters based on the Appendix VIII constituents
for assessment monitoring. The rate and extent of the plume,
both horizontally and vertically, needs to be better defined.
3. Sampling Results
Task Force sampling confirmed that ground water beneath the CECOS
site contained hazardous waste constituents or other indicators
of contamination. Wells monitoring both the shallow (MW-21) and
deep aquifers (MW-20) found contamination, thus, supporting the
postulate of a downward migration of waste.
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II. TECHNICAL REPORT
A. FACILITY BACKGROUND
The CECOS Livingston facility is a major commercial hazardous waste
disposal facility located about 30 miles east of Baton Rouge in the
southeast quadrant of the intersection of Interstate Highway 12 and
Louisiana Highway 63 (Figure 1). Routine operations conducted at the
site consist of direct landfill of waste and solidification of liquids
and sludges with subsequent landfill disposal of solidified waste.
Operations began at the facility in 1977 before there was development
of a Louisiana or EPA hazardous waste regulatory program under the
provisions of the Resource Conservation and Recovery Act of 1976 (RCRA).
The facility initially came under Louisiana hazardous waste regulations
in 1979 and EPA RCRA regulations in 1980. A Louisiana hazardous waste
disposal permit was issued to the facility in January 1983 which defined
operating conditions.
Southwest Environmental Company (SWECO) initiated operations at the
facility on May 1977 upon approval of their application from the
Louisiana Department of Health and Human Resources.
Browning Ferris Industries (BFI) acquired the SWECO facility on May 19, 1978
BFI operated the facility until October 1, 1983 when the operational
control was taken over by CECOS International, Inc.
The CECOS facility consists of approximately 380 acres which are
centrally bisected by the main access road which runs north-south through
the site. Nine pre-RCRA waste disposal cells had been utilized in the
past for landfill operations, all of which have since been closed,
capped, and covered in place.* Dates of closure vary from 1979 through
1981. Presently, active cells at the site include cells 12, 12L, and the
"monofill" (Figure 2).
* Closed and capped in no way refers to RCRA closed or RCRA capped.
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There are still large areas of land available for additional cell
construction in the southeastern and western parts of the property.
Final development of the site is expected to include 29 additional cells
as illustrated in Figure 3. These new cells will be developed in a
phased time sequence beginning with the cell group marked "I" and pro-
ceeding numerically to the group marked "IV".
Various construction projects have been underway at the site since early
1984. As required by LDEQ environmental permits, a perimeter dike and
soil/bentonite slurry wall have been installed around the facility.
Slurry walls are also installed around cells 5S, 8, 9, 10, 11, 12, and
12L, as well as the new waste solidification building (Figure 2). Two
rainwater storage basins for uncontaminated and potentially contaminated
surface runoff have also been constructed. Rainwater Basin 1 will receive
uncontaminated rainwater and Rainwater Basin 2 receive potentially
contaminated rainwater. In addition, two 250,000-gallon storage tanks
are to be used for contaminated rainwater. Two 8,000-gallon above-
ground leachate storage tanks are in use for leachate storage and
subsequent shipment off site for deep well injection disposal.
Throughout its operating history, the facility has received frequent
attention from Louisiana environmental agencies (Table 1, NEIC). Site
inspections have been performed in response to complaints, in support
of permit activities, as routine compliance checks, and as follow-up
to enforcement actions. Numerous compliance orders and other enforcement
actions have been directed toward air emission violations, improper
waste handling practices, facilities design, construction problems,
and ground-water contamination. No fines or penalties have been
assessed. EPA, Region 6, has made two joint RCRA inspections with
LDEQ, the latest of which was in March 1985. The facility was also
inspected in November 1985 and January 1986 by NEIC and in December
1985 by the Ground-Water Task Force for this report.
Ground-water contamination by chlorinated hydrocarbons and herbicides had
been detected in the shallow aquifer beneath the SWECO cells and the
old rainwater basin between cells 6 and 8 in December 1984. This
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was followed by an LDEQ compliance order siting several ground-water
protection deficiencies, one of which was an insufficient number of
downgradient monitoring wells.
In March 1985, contamination was also detected in the deeper aquifer
beneath the same SWECO cells. This again prompted LDEQ to officially
notify CECOS in April 1985 of their determination that a release of
hazardous waste had occurred. CECOS was directed to submit a
ground-water assessment plan and apply for a permit modification to
implement a corrective action program. In June 1985, the ground-water
assessment plan was submitted to LDEQ and was subsequently approved, with
several conditions, in July 1985.
The contaminants identified appear to be wastes that were disposed of in
the SWECO and early BFI landfill cells which were closed in 1978, prior
to utilizing present day construction techniques for secure landfills.
Information from a records search indicated that 2,745 55-gallon
drums containing 2,4-D acid sludges were disposed of in these land-
fill ceils from September 1977 through November 1978 by the previous
site operators, SWECO and BFI.
As a result of LDEQ monitoring and enforcement efforts, CECOS has
installed 35 additional monitoring wells under their ground-water
assessment program. These wells were initially sampled for the RCRA
indicators, drinking water, and water quality parameters as specified in
40 CFR 265.92. Samples which exhibited a TOX value of 50ppb or greater
were subjected to a priority pollutant analysis. The CECOS assessment
program is covered in more detail in its respective section.
The facility is presently in the assessment phase of ground-water
monitoring and is attempting to determine the rate and extent of
groundwater contaminated beneath the SWECO cells.
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B. WASTE MANAGEMENT UNITS
To identify possible sources and pathways for waste constituents handled
at CECOS to enter the groundwater, waste handling units and operations
were identified. Seventeen disposal cells have been placed in service at
this facility. These cells can be grouped by construction methods as
follows:
0 SWECO Cells — SWECO operated three landfills known as SWECO
cells 1, 2, and 3; a series of waste storage pits and ponds;
and two waste landfarms through 1977 and 1978.
The three landfill cells are unlined and have neither leachate
collection nor detection systems. Construction of a soil/bentonite
trench about 20-25 feet deep was started for SWECO cell 1, but
the QC inspectors were dismissed halfway into its construction
and futher details are sketchy. The cells are approximately 200
by 250 feet in plain view and extend to base elevations near +10 mean
sea level. The design side slope for SWECO cell 1 was 1(V):1.5(H);
early construction observations indicate that steeper slopes may
have been used.
0 BFI cells 1 through 8 were in use during the period May 1978
to November 19, 1980. The latter date marked the start of the
RCRA program under EPA. Cells 9, 10A and 11 were in used during
1981. Cell 10B was used in early 1982 followed by cell 5S.
BFI Cell 1 — This cell had a liner consisting of five feet of
recompacted clay, but no leachate collection or detection system.
It is roughly 200 by 250 feet in plain view at the top. The depth
and side slopes are currently not known.
BFI Cells 2-5 — These cells all have liners consisting of at least
five feet of recompacted clay, plus leachate collection systems.
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BFI Cells 6-11 — These cells have five-foot thick recompacted clay
liners, which were placed under professional QC to ensure that the
liners had a permeability of lxlO~7 cm/sec or better. They have
leachate collection systems. Furthermore, each is closely
surrounded by construction slurry wall which 1s keyed into the clay
of zone 4 (see Site Geology for description of zone 4).
BFI Cell 5S — This cell was active from April 29, 1982 to August 24,
1983. It was constructed in a similar manner to as cells 6
through 11. Additionally, the cell has a leachate detection
system beneath its five-foot recompacted clay liner.
BFI Cell 12* -- This cell was put in use on August 8, 1983 and
received hazardous waste until May 8, 1985. The cell is still in use
for non-hazardous wastes. It has the construction slurry wall,
leachate collection and detection systems, and a liner consisting
of five feet of recompacted clay (placed under professional QC)
overlain by an 80-mil HOPE synthetic membrance.
BFI Cell 12L* -- This cell is a double liner landfill that was put
into operation May 9, 1985. Both primary and secondary liners
consist of three feet of clay plus 80-mil HOPE. Cell 12L has both
leachate collection and leak detection capabilities. Rainwater,
which collects on the top of the active cell, is transferred by vacuum
truck to the contaminated rainwater pond. (NEIC, 1986)
* Cells 12 and/or 12L were originally designated as cell 22 and review and
approved was for cell 22. The cell 22 designation is no longer used at
this facility.
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Tetraethyl Lead (TEL) "Monofill" Landfill — The TEL Monofill**
project at Livingston was reported as dedicated to the receiving and
disposing of TEL cleanup, waste from PPG, Beaumont, Texas. The
landfill was enclosed with an inflatable fabric dome otherwise known
as the "CECOSDOME". First wastes were received into the TEL
Monofill on October 1, 1985. The CECOSDOME failed on October 28,
1985 because of the damage incurred during hurrican Juan, and the
dome was recompleted in January 1986. The landfill was underlaid
with dual synthetic clay liners; the primary clay liner was five
feet thick and the secondary liner three feet thick. The landfill
was enclosed with an inflatable structure because of the high hazard
of organic and inorganic lead to the environment (NEIC, 1986).
Old Solidification Basins (through June 1985) -- The old
solidification facility, which operated until June 1985, was located
directly north of Rainwater Basin 2 and immediately west of old
landfill 5S. It consisted of four concrete basins numbered 1
through 4 running south to north'until around early 1983. At that
time, the two middle basins were reported taken out of use and
"capped closed".* The basin on the south side was continued to be
called basin 1, and the basin on the north side was renumbered
basin 2. These remaining active basins were divided into front and
rear sections called 1F,1R, 2F, and 2R. All basins were capable of
receiving drums and bulk materials for solidification. 1R was
devoted to the washing of rolloff boxes and 2R used for "special"
wastes, such as acidic streams, etc. Each basin was 25 feet wide by
90 feet long by 10 feet deep. Basin operating depth was eight
feet (with two feet of freeboard). Rear compartments of basins
1 and 2 were about one-third of total basin capacity (NEIC,1986).
** According to CECOS personnel, "monofill" is a generic definition and does
not correspond to the November 1985 EPA definition of monofill.
* The definition "capped closed" is unique to Livingtson and in no way
refers to RCRA closed or RCRA capped.
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C. SITE GEOLOGY
The CECOS facility is located in a wooded, relatively flat area about two
miles south of the small town of Livingston. The areas adjoining the
site are predominantly undeveloped wooded lands with a history of active
petroleum development.
The site is located on the drainage divide between the watershed of
Little Colyell Creek, which drains southwesterly into the Amite River,
and the watershed of Caney Branch, which drains southeasterly into the
Tickfaw River (Figure 4). The area is one of low relief with surface
elevations between 25 and 40 feet above mean sea level. A gentle ridge
extends north-south through the site forming the drainage divide
described above.
The geologic data accumulated by CECOS has been the result of work which
began in 1977, during SWECO ownership, and completed with the final
assessment well installation in 1985. A total of 216 borings were
completed at the site, most of which were generally less than 100 feet in
depth.
The entire CECOS facility is located on the Late Pleistocene Prairie
Formation which, in this area, has a gently southerly slope of about
three feet per mile. The shallow geology beneath the CECOS site has been
defined to a depth of 90 to 100 feet. The strata encountered consist
primarily of clays, silty clays, and sands which extend from the surface
to a depth of approximatley 70 feet bis, at which point the alternating
strata overlie a prominent sand aquifer. The shallow clays generally
contain interbeds of saturated sands and silty sands, the most
pronounced and laterally consistent of which occurs between 5 and 25
feet bis. Discontinuous sandy layers also occur between 20 and 40
feet bis. A generalized stratigraphic section of the subsurface
geology is presented in Figure 5. The strata, however, typically
display a variable thickness across the site.
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Although the stratigraphy of the site is quite variable, the geology can
be idealized by an upper silty sandy aquifer, separated from a lower
dense sand aquifer by a thick clay unit. These laterally consistent
saturated zones are identifiable and presently monitored by well
clusters.
Identifiable zones recognized across the CECOS site include:
Zone 1: Surficial Silty Clays
The surficial materials consist almost entirely of plastic to stiff
clays, grading to silty, and sandy clays of variable thickness throughout
the site. The zone typically extends to ten feet bis.
Zone 2: Shallow Sands
Zone 2 is a prominent stratum in the east and central parts of the CECOS
site but appears to thin towards the west (Figures 5.5 and 5.6).
This unit occurs as a channel sand in the clays and varys from medium
grained sand to silty/clayey sand. Zone 2 is saturated and typically
occurs between 5 and 25 feet bis. This shallow aquifer has been impacted
by contaminants released from the old SWECO landfill cells and is
presently being monitored under an assessment program. At least 16
domestic and agricultural water wells in the area of the CECOS facility
are reportedly supplied by this aquifer (Table 2 — Well Inventory).
Zone 3: Alternating Layers
The lithologic composition of zone 3 alternates across the CECOS site
between stiff clay, clayey silt, clayey sands, and silty sand. Sand and
silt layers are common. The depth to the top of this stratum is variable
but frequently begins at 15 to 20-feet bis and extends 5 to 20-feet in
thickness. Jointing and slickensides in the stiff clays of zone 3 are
commonly mentioned in the drill logs. In the western part of the active
CECOS site, zone 3 lies immediately beneath the surficial clays of
zone 1.
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Zone 4; Deep Clay
Zone 4 is comprised primarily of gray to tan stiff clays which frequently
grade to a sandy silty clay or silty sand. Interbeds of sand and silt
occur within the zone 4 strata and are especially prominent at the depth
of approximately 50 feet bis. These interbeds are as thick as 20 feet in
some areas. Slickensides and jointing are frequently mentioned in the
drill logs with occasional mention of vertical silt streaks. These
secondary permeability features, in addition to sand and silt interbeds,
appear to interconnect the upper zone 2 and lower zone 5 aquifers. The
thickness of zone varies but is commonly about 40-feet and appears to be
laterally continuous under the CECOS site. The soil-bentonite slurry
trench cutoff wall which was constructed around the perimeter of the
facility is keyed into the upper three feet of zone 4.
Zone 5; Deep Sand
Zone 5 consists primarily of medium grained sands and clayey sands which
are saturated with fresh water. This stratum appears to be a major
aquifer in the area, as many of the private wells in the vicinity of the
site are completed in these sands (Table 2 — Well Inventory). The
secondary permeability features and sand/silt interbeds of zones 3 and 4
appear to indirectly connect zone 5 with the shallow aquifer of zone 2.
This has resulted in contamination of zone 5, in the area beneath the old
SWECO cells, by chlorinated hydrocarbons and solvents similar to those
found in the channel sands of zone 2.
The top of this deep sand zone is identifiable at varying depths across
the CECOS site but appears most consistent at about 60 to 70 feet bis.
Zone 5 seems to be laterally continuous under the site, but well control
is limited.
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D. SITE HYDROLOGY
The various sands and clayey sand units of the Prairie Formation comprise
the uppermost aquifer beneath the CECOS site. Specifically, the shallow
saturated sands of zone 2 and the deeper medium grained sands of zone 5
have been identified as the uppermost aquifer system. These two zones
appear to be hydraulically and stratigraphically interconnected by such
secondary permeability features as joints, slickensides, and vertical
silt seams.
The hydraulic relationship between the upper and lower aquifers can be
idealized as an upper water table which is separated from the lower
aquife" by a semiconfining clay bed. The potential for vertical
ground-water flow is downward, as evidenced by decreasing head with
depth, i.e., the deeper monitoring wells usually display deeper water
levels than their shallow well counterparts. The net result is downward
seepage from the upper to the lower aquifer through the silty/sandy
interbeds within the zone 3 and zone 4 strata, as well as across the
secondary permeability features previously mentioned.
Ground-water flow within the shallow zone 2 aquifer has been directly
affected by the construction of a slurry wall which was emplaced along
the perimeter of the site. This wall was completed in November 1984 and
is keyed into the clay layer of zone 4. Smaller slurry walls also
surround individual waste disposal cells. The net effect is to retard
horizontal ground-water flow within the shallow aquifer. Differences in
water level elevations are now apparent on opposite sides of the
perimeter slurry wall, with elevations in the shallow aquifer two to four
feet higher inside the wall along the southern part of the facility. The
slurry walls, however, have no apparent effect on the deeper zone 5
aquifer. Any contaminants moving vertically into the lower aquifer would
be free to migrate laterally.
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Zone 2: Shallow Sand Aquifer
A potentiometric contour map for zone 2 which has been prepared by the
Task Force is presented in Figure 6. Generally, horizontal ground-water
flow inside the slurry wall is to the west-southwest. This direction
differs from the east-southeast flow which had been historically reported
and probably reflects the influence of the site perimeter slurry wall.
Although significant features are identified in the contour map, critical
areas still exist where meaningful definition of the water table and flow
direction are missing. Definition of the elevation and direction of flow
is necessary around the areas of active cells 12/12L, the monofill, and
closed BFI cells 3, 4, 5, 6, 8, 9, 10, and 11. When the western part of
the CECOS site is developed, additional piezometric data will become
necessary, although thinning of the zone 2 aquifer is anticipated.
In the north-central area of the CECOS site, a ground-water mound has
been identified directly beneath the SWECO landfill cells. These cells,
which had been constructed in 1977 without any liner system other than
the natural clayey soils, had previously been implicated as a point
source of contaminants to the groundwater directly beneath them. The
flow away from the cells appears radial, at an immediate gradient of
0.002.
The second significant feature identified in the water table contour map
lies in the southeast corner of the facility. This area is
topographically lower than the rest of the site and frequent inundation
by surface runoff appears likely. The area was flooded during the
December inspection. A relatively steep northwesterly gradient is
observed in the contour map and probably reflects recharge to the shallow
zone 2 aquifer.
The average horizontal hydraulic conductivity values for the upper zone 2
aquifer, as determined by laboratory tests performed by CECOS, is IxlO"4
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cm/sec (Table 3). No field tests were performed to verify this
value. This value may not represent the hydraulic and lithologic
variability of the upper sands. Utilizing Darcy's Law, hydraulic
gradients from Figure 6, and effective porosity estimated at 30 percent
ground-water flow velocities in the zone 2 sands varies from 12-1/2
feet/year in the immediate area of the SWECO cells to 6-1/2 feet/year in
the southeastern part of the facility.
Zone 5; Deep Sand Aquifer
The deep sand aquifer is separated from the shallow zone aquifer by about
40 feet of interbedded and discontinuous clayey silt, sand and/or gravel
lenses, stiff clays, and silty sand. The initial water bearing zone for
this aquifer traditionally appears at 55 to 60 feet bis. Measured
potentiometric surface ranges from 21 to 25 feet bis in the north end of
the property to about 19 to 23 feet bis in the south end.
Natural ground-water flow is southerly with velocities up to 40 feet per
year or a permeability on the order of 1x10-3 to 1x10-4 cm/sec. An
eastward flow component has been detected in the northern half of the
site.
The deep sand or zone 5 aquifer is monitored by wells OW-2, OW-1, OW-5B,
MW-18, MW-5, MW-20, OW-8, OW-10, OW-11, OW-12, OW-13, OW-14, and OW-15.
Monitoring information provided by the facility indicates that the deep
sand aquifer potentiometric surface and its flow was unaffected by
facility operations until August 1984.
Dewatering pumping conducted at well OW-15, which is screened at 80 to 90
feet in the base of zone 4, began to affect flow rates, direction, and
water levels in the deep aquifer soon after it began pumping in 1984.
This change of flow continued until mid-1985 when the pumping changed
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from a continuous to an intermittent pumping frequency. Further evidence
of the change in flow rates due to the pumping is a gradient change of
0.0013 in January 1982 to 0.00076 in January 1984.
As with the shallow zone aquifer, further definition of the water table,
flow direction, and rates are needed on a wore unit specific basis. Many
facility or facility consultant prepared studies Indicate that the deep
sand aquifer is not Interconnected with the shallow sand because of a
stiff clay separating the two. However, pumping of OW-15 and the
resulting deep aquifer flow rate changes indicate otherwise. Also, due
to the extremely interbedded nature of upper zones 3 and 4, it would be
difficult to say the two aquifers were not interconnected without further
study. Finally, accurate flow rate and direction of the deep aquifer is
necessary because of the many residential and agricultural water wells in
the immediate vacinity of the side that utilize this aquifer. Attempts
to contour the deep aquifer with the facilities data resulted in three
possible contour schematics. Although no map was drawn for this report,
the direction of flow appear to be southerly.
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E. GROUND-WATER MONITORING SYSTEM
The present ground-water monitoring program at the CECOS facility
utilizes a total of 56 wells which are completed in the various sands and
silty clays which comprise the shallow and deep zone aquifers. Of the
total, 28 wells are used in the RCRA compliance monitoring program and
are sampled on a quarterly basis. The remaining 25 wells are part of the
ground-water quality assessment program in progress at the site and are
monitored monthly. Sampling results are reported to LDEQ. The locations
of the shallow and deep monitor wells are as shown in Figures 7 and 8.
While the detailed stratigraphy of the site is somewhat irregular, the
geology can be idealized by an upper silty sandy aquifer, separated from
a lower dense sand aquifer by a thick clay unit. The installation of
monitoring wells in these two water bearing strata is graphically
represented in Figure 9. A clustering of data points, representing well
completion depths, is evident from the graph. The diagram illustrates 29
wells screened in the shallow zone, at depths ranging from 10 to 30 feet
bis. An additional 27 wells have been screened in the lower sands, at
depths ranging from 50 to 90 feet bis.
Well Construction Details
Monitor well construction began at the CECOS site in late 1977 and has
progressed in phases, with the most recent assessment wells completed in
August 1985. Table 4 summarizes the various stages of well installation.
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Specific well location and construction details are summarized in
Table 5. Generally, the MW-series wells are constructed to RCRA
standards, although the PVC materials used in the well construction are
generally not recommended by the EPA Science Advisory Board for use in
ground-water monitoring when organic contaminants are present. Stainless
steel or teflon are the recommended materials for use 1n those parts of
future wells that will be in contact with the groundwater. The MW-series
well screens vary from five to ten feet in length and are typically
enveloped in a four-inch annular graded sand, filter pack. The pack
extends one to two feet atop the well screen and is, in turn, overlain by
a one-foot thick fine sand seal to protect from contamination from the
overlying cement/bentonite grout. All well elevations have been
surveyed. A typical MW-series well construction is shown in Figure 10.
The older OW-series wells do not meet present RCRA specifications. A
sand and clay backfill has been used to fill the annular space to ground
surface, rather than the recommended cement/bentonite grout. The
integrity of this material to supply a good annular seal against upper
ground-water migration down the borehold is questionable. PVC materials
have been utilized in the well construction with solvent glued casing
joints. Well screens are typically three feet in length, but details on
several of these older wells were not available. A sand pack had been
utilized around the well screens and appears to extend one to two feet
above the top of the screen. A typical OW-series well construction is
shown in Figure 11.
Specific construction details on the older D-series, including upgradient
wells D-7 and D-8, and the plain number wells are not available, except
what has been previously listed in Table 4. It is difficult to determine
the integrity of these wells since information regarding annular seals
and gravel pack placement/materials is unavailable. PVC solvents were
probably used in the well construction.
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Compliance (Detection) Monitoring
CECOS presently monitors a total of 56 wells at the Livingston site at
different frequencies. The 28 RCRA compliance wells are monitored on a
quarterly basis. The remaining 25 wells are part of the assessment and
are monitored on a monthly basis. This compliance monitoring system is
comprised of the following wells:
OW-1 Well 2
OW-13 Well 3
OW-15 MW-16
D-l MW-17
D-2 MW-22
D-4 MW-23
D-5 MW-24 through
0-7 MW-36
D-8
The compliance monitoring system utilizes wells D-7 and D-8, located
north of the facility and outside the slurry wall, for upgradient water
quality. Both of these wells are located in the immediate area of an
existing lake which formed as a result of the excavation of a borrow pit
for construction of Interstate Highway 12. The effect of the lake on the
upgradient wells is unknown. It should be noted, however, that the
facility's historical data for TOX from upgradient well D-8 indicated an
average value of 81 and 54ppb, respectively, for June and December 1984.
Task force results indicated a TOX concentration of 27ppb. TOX should
not be present in an uncontaminated well. Consequently, the use of
well D-8 as an upgradient well should be reassessed. Monitor well D-7
should also be reviewed due to lack of available construction details.
Both wells should be replaced.
The existing compliance monitoring system at the CECOS facility was
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originally constructed to monitor ground-water quality around the peri-
meter of the site. This requirement was part of the hazardous waste
disposal permit which was issued to Browning-Ferris Industries by the
Louisiana Environmental Control Commission in January 1983. The existing
compliance monitoring (detection) system is deficient since the number
and location of wells completed at the site are not adequate to
immediately detect a release from active or closed waste management
units. The monitoring system does not meet the performance standard of
the regulations to ensure immediate detection of any contamination
migrating from the facility. Additional down-gradient wells are
necessary, in both the upper and lower aquifers, to define water quality,
hydraulic gradients, and ground-water flow directions near active and
closed waste management cells. The lack of essential piezometrie data in
critical areas of the site underscores the need for the additional wells.
Despite the extensive assessment monitoring presently underway around the
SWECO cells (Figure 2), water quality and flow direction information is
deficient in the areas around closed BFI cells 3, 4, and 5; the new
mixing basins; and to the east of closed cells 8, 9, 10, and 11. This is
especially significant in light of the task force sampling results which
indicate toxic metal contamination in the only well (OW-1 Deep) available
east of closed cells 10 and 11. Additionally, surrounding areas to
active cells 12/12L and the "monofill" also lack the necessary water
quality and directional information. While several deep wells exist
downgradient of these cells, shallow aquifer monitoring is totally
absent. The channel sands, which comprise the shallow zone 2 aquifer,
achieve their greatest thickness in this area of the site and are
extremely vulnerable to contamination.
Monitor well OW-1, which indicates the presence of toxic metals, is the
only well available in the area east of BFI cells #10 and #11. Additional
monitoring of zone 5 is a necessity in this area.
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Sampling and Analysis Plan
As part of CECOS ground-water monitoring program, the sampling and
analyses of wells is conducted. The groundwater has been under a
monitoring program since 1977. RCRA quarterly monitoring, starting with
statistical analysis, was initiated in 1982-83. Under the current
Detection Monitoring Program, 28 ground-water wells are sampled and
analyzed.
During the inspection, CECOS personnel collected samples using their
standard procedures, which were observed by task force personnel. The
following sampling deficiencies were noted:
0 Some wells were not properly purged because CECOS personnel did not
measure the total depth of the wells and relied on the construction
drawings. Some wells were up to five feet deeper than indicated on
the drawings. Also, some wells were larger diameter than the field
personnel assumed.
CECOS needs to field check total depth each time the wells are
sampled. They also need to recheck the diameter of the well with
their records.
0 CECOS currently uses a dedicated PVC bailer for sampling.
The Final Technical Enforcement Guidance Document (TEGD) recommends
the use of teflon or stainless steel bottom filling bailers or a
bladder pump for sample retrieval.
0 Sampling technique is inappropriate for minimizing volatilization.
The facility fills their sample containers by inverting the bailer.
This process could agitate the sample, thus causing the loss of
volatiles. It is recommended that bottom value bailers or a bladder
pump be used.
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0 The facility apparently does not employ field or QA/QC sample blanks,
even though their sampling plan specifies this practice.
The collection of blanks is recommended as to assure consistent
sample and laboratory data quality.
0 CECOS sampling plan does not indicate if immisicible layers are
tested for prior to purging of the well.
It is recommended that prior to purging, it should be determined if
an immisicible layer exists and if found, it should be sampled.
The following section discusses the quality of the data generated by the
current labs used by the facility.
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F. SAMPLE ANALYSIS AND DATA QUALITY EVALUATION
Introduction
Nine laboratories were identified as having analyzed ground-water samples
for the BFI CECOS, Livingston facility. These include BFI Houston; the
CECOS, Livingston on-site lab; West-Paine, Baton Rouge; Spectrix
Laboratories of Houston; Environmental Testing and Certification (ETC) of
Edison, New Jersey; Kemron Laboratories of Baton Rouge; Toxicon
Laboratories of Houston; Microbiological and Biochemical Laboratories
(MBA) of Houston; and SCAN at McNesse State University, Lake Charles,
Louisiana (subcontractor to West-Paine). NEIC conducted on-site audits
at the first four laboratories. These audits were conducted over the
period of November 1985 through January 1986.
This evaluation focuses on data from 1983 to the present, but also
provides some appraisal of the quality of metals and TOX data in the
pre-1983 period. Problem areas will be specifically elaborated upon.
The analytical procedures that were examined were those specified in the
various ground-water monitoring plans and the 1985 ground-water assess-
ment plan. These evaluations included review of laboratory analytical
procedures, internal data reports, raw data and quality control records,
interview of key laboratory personnel, and inspection of analytical
equipment.
Before December 1983, the BFI Houston laboratory performed most of the
inorganic testing, except for temperature, pH, and specific conductance
which were performed by the on-site laboratory. The Houston laboratory
also performed some of the gas chromatographic (GO analyses. Other GC
and GC-Mass Spectrometry (GC-MS) analyses were contracted to Spectrix
Laboratories. ETC was responsible for some of the ground-water testing
between September 1982 and September 1983. Kemron Laboratories performed
the coliform analyses during December of 1982 as part of the third
quarter requirements of the first year background determinations.
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lexicon Laboratories of Houston performed gross alpha, gross beta,
radium, and other coliform analyses during other quarters as part of the
initial background determination. Prior to December 1983, all or part of
the TOX measurements were performed by MBA.
Commencing in December 1983, West-Paine Laboratories of Baton Rouge
performed all ground-water testing except for pH and specific con-
ductance, which were performed on site. West-Paine also provided con-
tainers and preservatives to BFI for sample collection. SCAN
Laboratories, under contract to West-Paine, performed the radiochemical
analyses.
Summary of Findings
This evaluation revealed that the ground-water monitoring and assessment
program is not adequate from an analytical standpoint. While data has
been presumed adequate, the NEIC found that some data reported for
certain key parameters is biased or inadequate due to inappropriate
sample handling, laboratory, or reporting methods. The same was also
true of data generated in 1981 and 1982 by the BFI Houston lab.
BFI Houston Laboratory
Metals data reported by this lab did not, in all cases, adequately
characterize groundwater sampled from monitoring wells as 40 CFR 265.92
requires. The flame atomic absorption spectroscopy methods used to
determine cadmium, chromium, and lead were inappropriate because they did
not reliably measure levels near the drinking water limits. In 1982,
listed detection limits for cadmium, chromium, lead, selenium, and silver
were twice the maximum concentration level specified for ground-water
protection. Some data for these parameters was erroneously reported
because it was below stated detection limits.
Dissolved, rather than total metals, were determined for the Livingston
site. This practice conforms to regulatory requirements because
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Louisiana prescribes dissolved metals.
CECOS, Livingston Laboratory
Specific conductance measurements may be as much as 20 percent low due to
lack of proper temperature compensation. The lab uses a YSI model 33
which, contrary to the lab's understanding, does not have a temperature
compensation adjustment. pH and specific conductance for ground-water
monitoring are performed on site. No problems were observed with pH
measurements.
Spectrix
Spectrix had performed ground-water GC-MS analyses prior to 1983 and
certain leachate GC-MS analyses prior to 1983 and certain leachate GC-MS
analyses since. No problems were found either with methodology or data
generation.
West-Paine Laboratories
The required testing is being performed, and by appropriate methods,
except as noted below. BFI did not comply with state and federal
regulations (265.92) when TOX, TOC, and semivolatile organic compounds,
endrin, lead, cadmium, chromium, and mercury data was reported for
ground-water samples by West-Paine because this data fails to adequately
characterize the suitability of groundwater as a drinking water supply as
the regulations intend. Similarly, noncompliance with Section 265.92 (a)
is indicated in the case of mercury data because West-Paine did not
follow the methods specified in the ground-water monitoring and assess-
ment plan.
The precision and accuracy of reported data is somewhat undefined because
of a chronic lack of laboratory quality control (attendant spiked and
duplicate samples) for work contracted by BFI CECOS. On the other hand,
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except for mercury, consistently acceptable results were achieved on EPA
performance check samples which demonstrate calibration accuracy, but not
performance at or near drinking water limits. Other parameter-specific
anomalies are noted.
After discussions with key laboratory personnel and examining equipment,
bench records and reports, deviations from stated procedures, and several
specific problems with reported data were indicated. The flame atomic
absorption spectroscopy methods used to determine cadmium, chromium, and
lead do not reliably measure levels near the drinking water limits for
these parameters. Measurements near the detection limits are not
reliable because of high variability. These analyses need to be
performed by furnace atomic absorption spectroscopy whereby reliable data
will be generated.
Cadmium and lead results may be biased high because no background
correction was used. Analyses at low concentrations require background
correction. Air, rather than nitrous oxide, as the method prescribes, is
used as the oxidant gas in the determination of chromium. Matrix inter-
ferences may bias results low. The question of matrix interferences in
other metals determinations for the particular ground-water samples in
question has not been properly pursued; the laboratory has not spiked
Livingston samples in the past to evaluate biases caused by matrix
interferents. Mercury results may be biased low because samples are not
heated during digestion in accordance with the EPA Method 245.1,
specified in the ground-water monitoring plan. Without heating, organo-
mercury compounds are not satisfactorily recovered.
West-Paine analyzed for dissolved rather than total metals. The same
comments pertaining to dissolved metals that appear in the BFI laboratory
section, above, also apply here.
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TOX data was seen to be highly variable and unreliable. Monitoring
well D-8, used by the site as the upgradient well, ranged from an average
value of 250 mg/L in February of 1984 to a barely detectable level of
13 ug/L in October 1984. Average TOX values of 81 and 54 ug/L were
reported, respectively, for June and December 1984. It seems reasonable
that 250 ug/L, rather than 250 mg/L, should have been reported; however,
bench data confuses interpretation. Table 6 is the TOX results from the
February 1984 report. Reported units are in mg/L and these seem to be
substantiated by the quality assurance results reported in column 3,
i.e., 0.200 mg/L standards which are in the appropriate concentration
range of the method. Sample results were not simply transposed from
ug/L to mg/L, however. Had they been, the levels reported for well
D-7 would be below what the detection system of the instrument is able
to see. Results are clearly inconsistent with data from other quarters
and one may conclude that sample values, in this instance, were incorrectly
calculated or reported.
Much of the TOX data reported for monitoring well analyses is below 60
ug/L. Values reported in this range are very unreliable based on
achieved detection limit. The laboratory cannot achieve the 5 ug/L
detection limit for TOX that they report. The replicates for June 1984
were 40, 51, 72, and 51 ug/L. This infers a detection limit of 60 ug/L,
i.e., that at the 99 percent confidence level, one cannot distinguish any
value less than 60 ug/L from zero. Sixty ug/L is much too high a
detection limit for TOX if it is to be used as a sensitive indicator of
ground-water contamination. Twenty ug/L or less should be achievable
and, therefore, laboratory precision must be improved.
The use of well D-8 as an upgradient well should have been more closely
examined by BFI. Any detectable concentration of TOX indicates
ground-water contamination. In most instances observed, well D-8 had
reported levels of TOX higher than downgradient wells. Even before
West-Paine analyzed samples, TOX had been found in samples from well D-8.
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A report from M.B.A. Laboratories, dated September 22, 1983, and stamped
"received September 26, 1983" by the BFI Houston lab, shows 69 ug/L TOX
for monitoring well D-8. The upgradient well should not show con-
tamination from the facility. Well D-8 shows apparent contamination
greater than downgradient wells.
Two problems exist with reported TOC values. First, TOC is reported as
the difference between total carbon and inorganic carbon. Where
inorganic carbon is significant in proportion to total carbon for a
particular sample, as it was here, this method is inappropriate. For
example, for monitoring well D-7, on May 29, 1984, the TC was 9 mg/L and
the 1C was 7 mg/L, leaving a net difference, reported as TOC, of 2 mg/L.
The uncertainty of the 9 mg/L and 7 mg/L propagate to the 2 mg/L and lead
to an uncertainty of at least 100 percent of the value reported. The
method used here results in large systematic biases in the data.
TOC may not be truly indicative of properly defined total organic carbon.
TOC is performed by a standard EPA water method which allows the sample
to be exposed to air. Properly defined, however, TOC is the sum of
nonpurgeable organic carbon (NPOC) plus purgeable organic carbon (POC).
POC sample aliquots should be taken from a container such as VOA
(Volatile Organic Analysis) bottle which is filled without headspace and
sealed.
When samples contain measurable amounts of POC compounds, results
produced by the traditional TOC method will be biased low in relationship
to TOC results obtained by summing NPOC plus POC. The latter procedure
is recommended to adequately characterize groundwater.
Problems in cyanide analysis or reporting are indicated. Cyanide was
reported at 2 mg/L for well D-7 in a February 1984 report. Results from
the analyses of monitoring well D-7 in October 1984 and in 1985, however,
showed no contamination above the reported detection limit of 0.01 mg/L.
The February 1984 result is, therefore, suspect.
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Based upon NEIC's evaluation of instrument response, the laboratory did
not achieve the normal method detection limits for semi volatile analyses
(Method 625). Previously reported detection limits of 5 and 10 ug/L were
not adequately substantiated, and for many of the semi volatile compounds
probably were not achieved. Analysis of standards during various time
periods showed low and widely varying responses.
The quality of semi volatile organic data is not quantifiable because the
lab failed to use the recommended quality control on CECOS Livingston
samples. The 1979 EPA method, stated to be in use, recommends, as part
of the procedure, that matrix spikes be analyzed in conjunction with
regular samples. Furthermore, EPA, has instituted tighter instrument
performance and quality control measures since that time which do not
substantially change the method, but which do improve and more carefully
define data generated by it. The laboratory has failed to implement
these additional provisions. While the deviations observed do not
constitute a violation, the laboratory should be directed to implement
current EPA protocols .into their procedure.
Instances were observed which further decreased the overall reliability
of reported semi volatile data. Although the laboratory routinely tuned
their mass spectrometer to meet DFTPP specifications, on at least one
occasion, BFI Livingston samples for this parameter were analyzed without
meeting acceptable spectral abundance criteria. Also, on at least two
occasions, CECOS samples for volatile organics were analyzed beyond the
maximum recommended holding time of 14 days. Similarly, a monitoring
well sample dated March 26, 1985, analyzed by Method 625, which pre-
scribes a maximum holding time of 7 days before extraction, was not
extracted until 22 days after collection.
The laboratory failed to achieve a detection limit sufficiently low to
reliably measure the pesticide endrin. The detection limit reported was
1 ug/L or five times the maximum concentration for ground-water protection,
Method 608, which the laboratory uses, has a detection limit of 0.2 ug/L
when performed correctly.
-38-
-------
The lack of routine quality control checks fails to define past and
present data quality. Replicate and spiked sample measurements are
practically nonexistent. Therefore, the accuracy of data and the number
of significant figures sometimes reported cannot be substantiated. As an
example of the latter finding, toluene was reported to four significant
figures for a leachate sample collected in March of 1985.
West-Paine routinely participates in intralaboratory check sample pro-
grams for many of the organic parameters of interest. Results, except
for mercury, since the end of 1983, were generally acceptable for the
parameters of interest.
-39-
-------
G. TASK FORCE SAMPLING RESULTS
During the December 1985 inspection, task force personnel collected
samples from 18 ground-water monitoring wells, 2 leachate collection
sumps, and leachate detection systems from both the Rainwater Pond 2 and
the new enclosed solidification building. The sampling locations and
rationale for well selection are identified 1n Table 7. These
samples confirmed that groundwater beneath the CECOS site contained
hazardous waste constituents or other indicators of contamination.
Task force sample results and parameters analyzed are presented in
Attachment 3.
The data indicate that at least two wells (MW-20 and MW-21) clearly
contain organic hazardous waste constituents. Well MW-21, completed in
the shallow zone 2 aquifer, contained a variety of listed chlorinated
hydrocarbons, solvents, and herbicides including 2,4-D, 2,4,5,5-T,
methylene chloride, and 1,2-dichloroethane.
Monitor well MW-20, completed in the deeper zone 5 aquifer, also
contained numerous chlorinated hydrocarbons and solvents although
herbicides were absent. Compounds identified include methylene chloride,
1,2-dichloroethane, and 2-chlorophenol. Many of the contaminants
identified in MW-20 and MW-21 were identical, but exhibited decreasing
concentrations with depth. These findings, in conjunction with the
aquifer hydraulics previously identified, support the postulate of a
downward migration of waste from the channel sands of zone 2 to the
deeper aquifer of zone 5.
In addition to hazardous organic waste contamination, two wells (MW-1 and
OW-1) clearly contained toxic metal contamination in excess of the FPDWS.
Monitor well MW-1, completed in the shallow zone 2 aquifer, contained
barium, cadmium, and chromium. Well OW-1, located east of closed BFI
cell 10/11 in the lower sandy clays, contained elevated levels of
cadmium, chromium, and lead. Monitor well MW-29 also contained chromium
slightly in excess of the FPDWS.
-40-
-------
The organic compounds and toxic metals detected in the above-mentioned
monitor wells were also identified in leachate samples collected by task
force personnel from SWECO cell 2 and BFI cell 1.
Samples from shallow well MW-3 and the leak detection system beneath the
new solidification building contained elevated levels (greater than 50ppb)
of TOX. In addition, TOX was detected at 27ppb in upgradient well D-8.
The specific organic halogenated compounds, however, were not identified
in the task force samples.
Additional sampling and anlysis is necessary to identify the specific
compounds detected by the TOX analyses and their sources. Similary,
sampling should also be performed at those wells exhibiting elevated
levels of toxic metals.
Limitations of Data
In order to validate the task force data, a thorough QA/QC 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 6 and to the
Agency's Ground-Water Task Force. Below is a summary of findings
regarding the limits of the analytical data. The reader is referred to
the referenced reports for complete details of data results and
validation.
A total of 37 samples, including a performance evaluation (PE) sample and
various blanks, were collected at the facility. Samples were split with
the facility but their results have not yet been provided to EPA or the
State.
-41-
-------
1. Metals
Neither the field or the equipment blank show unusual metal
contamination.
a. AA - Graphite Furnance
The uniformly high recovery of the dissolved metals spikes and
the phenomenon, for most metals analysed in most samples, of
higher reported results for the dissolved component of the
metal compared to the total metal indicates a positive bias for
the dissolved metals relative to the total metals. The
dissolved metals were high because there was an error in the
amount of spike added.
Samples with very high aluminum concentrations, such as for wells
MW-1 and OW-1, have an enhancement of the arsenic signal
and, in the presence of iron, a suppression of the selenium
signals. Heavy metals are biased low and should be thought
of as mininum values except for arsenic which may be enhanced.
In these samples with high interfering concentrations of
analytes, the data should be considered qualitative. Leachate
from BFI cell 1 and SWECO cell 2 contain a high sulfate
concentration which would be expected to bias the barium
concentration low as it draws the barium out of solution.
b. ICP Metals
Samples from wells MW-1, MW-21, and leachate from BFI cell 1
and SWECO cell 2 contained high concentrations of sodium,
calcium, magnesium, and for several of these samples, high
aluminum and iron. This probably results in some problems
with the introduction of samples into the ICP due to high
dissolved solids, and therefore, results for these samples
should be considered qualitative and biased low (lower limit
values).
-42-
-------
Otherwise the results for ICP total metallic analytes are
acceptable and the data should be considered quantitative.
Results for ICP dissolved metallic analytes are unreliable and
should be considered qualitative.
2. Indicator Parameter Data
No blank contamination was reported for any indicator parameters but
values of POC were found at values above the contract required
detection limits in some blanks. TOC, TOX, POC, and POX data, in
many instances, do not correlate with the actual volatile organic
data and, due to the more quantiative nature of the actual volatile
organics data, the purgeable and total organics and halides
indicator parameter data must be questioned. High chloride levels
in some of the samples may be a reason for some of this inconsis-
tency. There was a correlation between the total phenol values
and the presence of phenolics in the semivolatile fractions of
the field samples.
The lab performed acceptably on its verification standards, calibration
standards, spikes, and duplicates. These were generally within the
limits. The indicator parameter data should be considered usable but
suspect.
3. Organics and Pesticides
a. Volatiles
Internal and external quality control data indicate that
volatile organics are unacceptable. The chromatograms appear
acceptable. The matrix spikes are acceptable with acceptable
recoveries. The surrogates appear acceptable. Overall, the
volatiles data are acceptable and should be considered
quantitative.
-43-
-------
b. Base/Neutrals and Acid Fractions
Base/neutrals appear normal from a QC view point. Matrix
spikes and the chromatography are acceptable. Overall, the
base/neutral data are acceptable and should be considered
semi quantitative due to limitations of the methods. Because no
acid extractable compounds (including phenolics) were present
in the Performance Evaluation (PE) samples, the acid fraction
data should be considered to be semi quantitative.
Pesticides and Herbicides
The pesticide data should be considered quantitative based on
the labs ability to quantitatively recover pesticides from
their spikes and surrogates.
The herbicide data should be considered quantitative. The
laboratory achieves acceptable recoveries and met all
performance criteria on matrix and matrix spikes. They
achieved acceptable recoveries on the surrogates.
Dioxins and Dibenzofurans
Recoveries of dioxins from the PE sample, by both the referee
labs and the organic lab, appear to be low (15 to 30 percent).
Recoveries of the dioxin from the spikes appear, however, to be
quantitative (92 to 120 percent). A problem, possibly
adsorption of dioxin to the glassware, is affecting dioxin in
the PE sample and probably in the field samples (if any dioxin
is present). No dioxins or dibenzofurans were detected in any
field samples but, because of the above problem, if any dioxins
or dibenzofurans were present, the probability of false
negatives is high. The detection limit for these compounds
should be considered approximately SOOppt based upon 20 percent
recovery of PE samples and the labs ability to detect lOOppt in
spikes.
-44-
-------
H. GROUND-WATER ASSESSMENT MONITORING SYSTEM
The CECOS facility is presently in the assessment phase of ground-water
monitoring. LDEQ notified CECOS on April 26, 1985 of their determination
of the presence of ground-water contamination in the shallow and deep
aquifers beneath SWECO Cell 3. CECOS was directed to submit a
ground-water assessment plan and apply for a permit modification to
implement a corrective action program. 'The areas of concern included the
SWECO landfill cells, the early BFI cells, and the old (active) rainwater
pond. Evaluation of the operation of dewatering well OW-15 was also
requested.
On May 13, 1985, CECOS met with LDEQ to refine LDEQ expectations of the
new ground-water assessment plan. The plan was submitted to LDEQ in
early June and was subsequently approved, with several conditions, in
July 1985. The final plan outlined the installation of monitoring wells,
continuous soil sampling with each six-foot sample checked with an
organic vapor analyzer, field permeability tests at each new well,
ground-water sampling and analysis methods, and data evaluation
techniques to delineate the contamination. Submission of a corrective
action plan was withheld pending data collection and evaluation.
Since approval of the assessment plan in July 1985, CECOS has installed
36 MW-series monitoring wells as part of both the assessment and
compliance monitoring system throughout the eastern half of the
Livingston site (Figures 7 and 8). Fifteen of these wells lie in the
immediate area of the SWECO cells and the rainwater basin. The purpose
of the assessment monitoring system is to delineate the vertical and
horizontal extent of contamination earlier detected by wells L-205A and
L-205B (MW-20 and MW-21). Adequate ground-water monitoring around many
of the closed BFI cells is still inadequate.
-45-
-------
The RCRA assessment monitoring system is comprised of the following 25
wells:
OW-2 MW-1 through
OW-5A MW-15
OW-5B MW-18 through
OW-6 MW-21
No. 1
No. 5
The initial sampling parameters proposed for the assessment program
included the contamination indicators, water quality, and drinking water
suitability parameters identified in 40 CFR 265.92 (LHWR, Section
23.366). The TOX indicator parameter was used as a screening mechanism
whereby any ground-water sample exhibiting a TOX level greater than 50ppb
was subjected to a priority pollutant scan to identify specific
chlorinated constituents.
While the use of the TOX indicator appears to be a valid screening
approach, a major concern was -raised during the evaluation of the CECOS
contract and in-house laboratories. Specifically, the historical data
evaluated by NEIC indicated that TOX analyses prepared by CECOS
contractor lab, West-Paine Laboratories, were highly variable. By
statistically assessing replicate data found in bench records, NEIC
believes that the detection limit at West-Paine is greater than what is
reported.
A comparison of TOX values taken from task force results and CECOS
samples which were used to delineate the contaminant plume, yields
ambiguous results. They are as follows (in ppm):
-46-
-------
Shallow Aquifer
Deep Aquifer
Dec. 1985 TF Sept. 1985 CECOS Data Dec. 1985 TF Sept. 1985 CECOS Data
MW-1
MH-2
MW-3
MW-7
MW-19
MW-21
0.029
0.021
0.053
0.007
0.026
350
| 0.042
| 0.038
| 0.037
I ND
| 0.007
1 105.2
MW-8 ND
MW-10 ND
MW-18 0.015
MW-20 20
ND
ND
0.004
12.78
\ •
Numerous organic compounds were
reported in MW-21 in both CECOS
and task force data.
Numerous organic compounds were
reported in MW-20 in both CECOS
and task force data.
CECOS's sampling results of the TOX data, part of which is presented
above, were used to identify the area! extent of the contaminant plumes
in both the shallow and deep aquifers. These isopleth maps are presented
in Figures 12 and 13. The contour plots indicate that the organic
contaminants have not experienced extensive lateral migration. This
finding makes sense from a Darcy velocity approach. The contamination
appears to be confined, in both aquifers, to the immediate area of the
SWECO cells. Vertical migration to the lower zone 5 aquifer is apparent.
This data, though, can only be used qualitatively because of the problems
West-Paine Laboratories had with the detection limits. Using the task
force values, TOX data at face value indicate that the plume appears to be
expanding slowly westward in the shallow aquifer with a modest decrease
in TOX values to the east of the SWECO cells and a corresponding increase
to the west. A similar pattern could not be identified in the deep
aquifer due to lack of data points. Additional sampling for priority
polluants at select wells is needed to confirm TOX data.
-47-
-------
REFERENCES
1. Ground-Water Assessment Plan Pre-RCRA Cell Area and Proposed Site
Monitoring Plan; CECOS Facility, Livingston, Louisiana; Soil Testing
Engineers, Inc.
2. Ground-Water Assessment Plan; SWECO Cell Area; CECOS Facility,
Livingston, Louisiana; Soil Testing Engineers, Inc., June 1985.
3. "Browning-Ferris Industries/CECOS, Livingston, Louisiana, Summary of
Investigation", Draft Report, National Enforcement Investigations Center,
June 1986.
-48-
-------
. .._
v.- ..... r
^ . • - -I v
....... --
- ".r. .......
BFI-LIVINGSTON
SITE LOCATION
L'f^Ui liMfciit ol lru»^po
-------
4
NE OUTFALL
« -c
en 12
CAITI
BFI
I2L
CFUS
»«/•«
***»*
MONO-
FILL
RAINWATER
BASIN I
Cl
yj.s i ~~ ~~ ~1
OLD
SOLIDIFICATION
AREA
FIGURE 2
EXISTING DISPOSAL CELLS
LOCATION MAP
(NEIC 1986)
SITE MAP
BFl-CECOS
LIVINGSTON.l-A
-------
< *oo
tl*OO *1«OO 11*00 SitOO
• ope
V.
FIGURE 3
FUTURE CELL DEVELOPMENT-LOCATION MAP
It*
AFTER: SOIL TESTING ENGINEERS, INC.
-------
Map
USOS Topo. Map Baton Rouge. La, Miss
r«vi»«d 1972. NH 16-6 Scries V502
t*-H !
-------
m
-------
FIGURE 5.5
GEOLOGIC CROSS-SECTION LOOKING NORTH
SEE FIGURE 7 FOR TRAVERSE
il
L-
-------
FIGURE 5.6
GEOLOGIC CROSS-SECTION LOOKING EAST
SEE FIGURE 7 FOR TRAVERSE
\
ftr
-------
• 000
• OOP
FROM: SOIL TESTING ENGINEERS. INC.
•01 « turtwt
•••»iii
^••v C.ll ••MtrmtlM il«rry ••!!
«M l«rf««* *••« L«»»l«
«
-------
FROM: SOIL TESTING ENGINEERS. INC.
HOT I «nr««M tl«mi<» •"« ««fl««« V««r
• IB»HII»« fr»» T*»« •( ll-OT-M
FIGURE 7
SHALLOW AQUIFER WELL LOCATION MAP
o ,,,, aoo
»C»L«
-------
00
0 000 • «0«
• 1100
> I BOO
32400 9)000
SSiOO
84100 S4IOO
FIGURE 8
DEEP AQUIFER WELL LOCATION MAP
300
FROM: SOIL TESTING F Nf, INFERS, INC.
SCALt
-------
FIGURE 9
T
T
1
> yu »i»^ ^^ |,>r-mU
-* 11
-< 1 h
10
1—I—I—I—h
30
1
SCREENED INTERVAL
-------
+34.45 (MSL)
2" dit. Tbrttdtd PVC
anaiit / Rant «ni t •
6" BJn. diA. Bora
Tmm »t Se
2M diA.-.O I O Inch S
Claan Unifnrmlw Crarf^d Sand
Btttia if CM
FIGURE 10
CONSTRUCTION DIAGRAM--MW SERIES WELLS
CECOS Inttrnitlontl
Livinfiton, Leulsitna
FROM: SOIL TESTING ENGINEERS INC
-------
SOIL TESTING ENGINEERS. INC.
3" Dia. Plastic Pipe
Natural Soil
Gr^
Cap
— Air Vent
General Sand £ Clay
BacXfill
Lower Three Foot
Manufactured V.'ell
Screen, Sanded In
Concrete Plug (41 min.)
Bentonite Clay Plug (21 mir..)
OBSERVATION WELL
FIGURE 11
CONSTRUCTION DIAGRAM-OW SERIES WELLS
Waste Disposal Area
Livingston, Louisiana
-------
#.. ow
— -O O-
OW-3AN *>
• Ell. 0-«
: o.o»«
ASSESSMENT AREA
•MALLOW ZON«
O ,.., «SO
0
-------
• too
•ILL »-r
•/••/••••.•I*
ASSESSMENT AREA
••IP ZONI
•••••II**
••l *•• •«IHt*4
HTi «• TMI
From: Soil Testing Engineers
9/26/85 - 10/24/85 DA
FIGURE 13
TOX in ppm
-------
Table 1
Enforcement History
1977 - 1980
11 Sept. 1980
17 Sept. 1980
1 Oct. 1980
24 June 1981
7 July 1980
18 May 1982
16 June 1982
29 November 1982
9 March 1983
18 May 1983
29 April 1983
18 Jan. 1984
19 June 1984
11-12 June 1984
25 July 1984
12 Sept. 1984
Louisiana Department of Health and Human Resources
conducted Inspections relating to citizens complaints
and odors
Louisiana Department of Natural Resources (DNR)
inspects the site for odor complaints
DNR issued notice of violation (NOV)
BFI responds to DNR NOV
DNR conducts first RCRA interim status inspection
DNR requests several actions of BFI regarding generated
landfill leachate and contaminated rainwater
Fire occurs at one of the solidification basins,
burns for 3-days
Second annual RCRA inspection by DNR
DNR sends letter to BFI notifying them that rainwater
impoundment does not meet Louisiana regulations.
DNR conducts follow-up inspection. BFI claims
they were unaware if November requested action
BFI responds to DNR concerning contaminated rainwater
impoundment
DNR Water Pollution Control Division issued a compliance
order to BFI regarding exceedance of permit limits,
improper monitoring and failure to report violations.
DNR notified CECOS of financial assurance/issurance
documents non-compliance.
CECOS submits corrected Part I to Louisiana
Department of Environmental Quality (DEQ)
Joint DEQ and EPA Region VI RCRA inspection.
DEQ sends warning letter to CECOS
Follow-up inspection by DEQ finds CECOS had corrected
inspection problems.
-------
2 Oct. 1984
DEQ issues NOV To CECOS on inadequate financial
assurance documents
31 Oct. 1984
11 Sept. 1984
18 Dec. 1984
CECOS submits new documents on financial assurance
DEQ receives a consulting engineering contract
evaluation of the ground-water monitoring program
at CECOS. The evaluation identified regulatory
deficiencies, including the need for additional
monitoring wells
DEQ issues a compliance order to CECOS based
on September 1984 consi Hants report
date unknown
21 Jan. 85
6 June 1985
20 March 1985
24-29 March 1985
26 April 1985
9-18 Dec. 1985
CECOS responds to DEQA and appeals all findings
and the proposed penalty of $16,000, and requests
a hearing
CECOS submits second response
DEQ rescinded 18 Dec. 1984 order
EPA conducts a RCRA oversight inspection
Joint EPA and DEQ ground-water sampling inspection
is conducted. Contamination of the near surface
aquifer and the initial detection of contamination
of the deeper aquifer near SWECO cell 3 was detected.
DEQ request CECOS to implement a ground-water assessment
program.
Ground-Water Task Force Evaluation of CECOS,
International, Inc.
-------
TABLE 2
PRIVATE WATER WELLS WITHIN A TWO MILE
RADIUS OF THE CECOS LIVINGSTON FACILITY
JUNE 1982
Owner's Name
Linda Hughes
B. V. Grantham
J. W. Sartwell, Jr.
Mack Fairburn
Jeff Lasara
Jonny Case
C. L. Watts
Charlie Watts
Maria Wheat
Ellis Watts
Ruth Watts
Nelson Thomas
C. M. McSwain
Charles Holliday
Hampton Bankston
Jewel E. Lee
Herbert W. Ballard
Birdie Green
Newton Green
Depth of Well
(feet)
135
1700
1700
220
1700
112
90
55
120
100
110
90
100
96
95
95
96
95
210
Age of Well
(years)
Unknown
1
20+
15+
Unknown
1
2
Unknown
Unknown
Unknown
Unknown
3
10+
20+
10+
10+
Unknown
10+
20+
Useage
Domestic
Domestic &
Agriculture
Domestic &
Agriculture
Abandoned
Domestic &
Agriculture
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
*Taken from CECOS Part B application
-------
Owner's Name
Horace Mayfield
Mr. Rayburn
Leslee Davison
Newton Green, Jr.
Elton Goings
Fuqua Sibley
Mrs. Jonnie Watts
Charles Kinchen
Ernest Cote
Guy Seven'o
Dallas Severio
Cliff Hood
Edward Bowling
Alton Balfontz
Kenneth Severio
Wilma Stafford
H. E. Whitfield
0. D. Severio
David Wheat
B. Mayeaux
Depth of Well
(feet)
105
105
105
105
105
285
100
300
255
110
175
300
60
210
150
300
180
25
180
19
25
195
15
90
190
12
Age of Well
(years)
5
5
1
1
1
3
Unknown
Unknown
15
2
22
2
10+
15+
Unknown
Unknown
2
Unknown
15+
10+
Unknown
15
Unknown
2
5
Unknown
Useage
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Abandoned
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Agriculture
-------
Owner's Name
Albert Ziggler
Rufus Severio
Maudie Simeon
Herman Simeon, Jr.
James C. Simeon
Mavis Gant
James Reedy
Wilford Gautreaux
James Arnold
Charles All good
Kelly Wheat
Willard Hill
Oliver Wheat
George Taylor
Wayne Wheat
Danny Wheat
Lee Wheat
Huey Wheat
Adella Efferson
D. K. Starkey
Depth of Well
(feet)
190
96
110
13
90
11
196
204
22
20
12
400
110
107
110
397
109
190
18
18
12
22
22
21
342
Age of Well
(years)
Unknown
1
15
12
14
Unknown
10
3
3
Unknown
Unknown
9+
3
2
Unknown
5
15
10
2
12
12
6
30
3
5
Useage
Domestic
. Domestic
Domestic
Domestic
Domestic
Agriculture
Domestic
Domestic
Domestic
Agriculture
Agriculture
Domestic
Domestic
Domestic
Abandoned
Domestic
Domestic
Domestic
Domestic
Domestic
Agriculture
Domestic
Domestic
Domestic
Domestic
-------
Owner's Name Depth of Well Age of Well
(feet) (years)
U. S.
Clarency Stovall
C. K. Wheat
Ricky Wheat
Bill Jones
Birty Stewart
Jack Rate! iff
Mr. Oliver
E. A. Haggard
Robert Bennett
Ron Blount
Malcolm Blount
Jonny Wheat
Browning-Ferris Industries
Browning-Ferris Industries
Browning-Ferris Industries
Geological Survey Registered Wells
Li -73 Town of Livingston
Li-172a. La. Office of Public Works
ll-172b. Livingston Parish Police Jury
95
397
14
110
300
95
100
100
100
300
290
290
110
440
440
440
in Study Area:
1925
751
290
Unknown
1
5
5
2
1
20+
30+
30+
3
6
6
2
3
3
3
24
7
7
Useage
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Public
Abandoned
Abandoned*
* Well was used by maintenance garage, but recently abandoned for use of public
water
-------
TABLE 3
HYDRAULIC CONDUCTIVITIES OF SELECT FORMATIONS
ZONE
I
II
IIIA
IIIB
IVA
IVB
V
VI
DESCRIPTION
Stiff silty clay with some
clayey silt at ground surface
Firm sand, silty sand, and
clayey sand
Stiff Clay
Firm clayey silt or sandy
silt often clay with silt
layers
Stiff clay, occasionally
silty clay
Firm silty sand, often as
Dense sand and silty sand
Stiff clay and silty clay
CLASSES
CL - ML
SP-SM-ML
CH
ML
CH
SM-SP
SP-SM
CH-CL
PERMEABILITIES cm/sec
VERTICAL
5 x 10-7
1 x ID'5
5 x 10-7
5 x ID'5
1 x 10-7
1 x 10-4
1 x 10-3
1 x 10-7
HORIZONTAL
1 x 10-6
1 x 10~4
1 x ID'6
5 x 10-4
1 x ID'7
4 x ID"4
1 x lO-3
1 x 10-7
-------
TABLE 4
STAGES OF WELL INSTALLATION AT THE CECOS SITE
D-SERIES WELLS
- 6 wells
- installed 1977-78
- all 3" diam. PVC
- depth range: 12-75'
- all with 31 screens
- all wells located
outside of slurry
wall except D-l
OW-SERIES WELLS
- 10 wells
- installed 1977
(except OW-1 & 2)
- 3" 4 4" diam. PVC
(except OW-15 -6")
PLAIN NO. WELLS
- 4 wells
- installed 1979
- all 3" diam. PVC
NW SERIES
ASSESSMENT WELLS
- 36 wells
- installed 1984-*
- 2" 4 4" diam. Pi
- depth range: 25-90' - depth range: 25-80' - depth range: 12-
- mostly 3' screens
(but many unknown)
except OW-15-201
screen
- 5 wells inside
slurry walls
- 5 wells outside
slurry wall
- 3 to 5' screens
- all inside slurry
wall
- 5 to 10' screen:
(except MW-33-li
- all inside slun
wall
CECOS has proposed to abandon the following wells for the reasons given:
OW-11 and OW-11B — Redundent information.
OW-12A and 12B — Redundent information.
(These areas are monitored by OW-13 and MW-23.)
OW-5A — Redundent information.
Well 5 — Caved in.
MW-6, MW-23, MW-36 — Dry wells.
MW-22 — Bent casing, cannot sample.
MW-6, MW-23, MW-36 — Dry wells.
MW-22 — Bent casing, cannot sample.
-------
TABLE 5 continued
* * Outside of Slurry Walls
WELL LOCATION AND CONSTRUCTION DETAILS
WELL
NUMBER
MW-15
MW-16
MW-17
MW-18
MW-19
MW-20
MW-21
MW-22
MW-23
MW-24
MW-25
DATE
COMPLETED
8/85
9/85
11/85
11/84
11/84
12/84
12/84
9/85
9/85
9/85
9/85
DEPTH
BLS
80'
24'
12'
60'
30'
60'
30'
24'
18'
90'
83'
WELL
DIAMETER
2"
2"
2"
4"
4"
4"
4"
2"
2"
2«
2"
APPROXIMATE
LOCATION
Directly
North of BFI
cell #6
150' South of
Lake In NW
corner
Directly
North of
Rainwater
Basin #1
Downward of
SWECO cell
#1-4
Downward of
SWECO cell
#1-3
Downward of
SWECO cells
11-3
Downward of
SWECO cells
#1-3
750' North of
Active cell
#12
400' North of
Acitve cell
#12
700' North of
cell #24
South of
Rainwater
Basin #1
SCREENED
INTERVAL
BLS
70-80'
19-24'
7-12'
50-60'
20-30'
50-60'
20-30'
19-24'
13-18'
80-90'
73-83'
FORMATION
MONITORED
Sand, silty
sand/clay
Silty clay/
clay
Silty snad
Sandy clay
w/sand
lenses
Clay w/lay-
ers of sand
silt
Clay w/ lay-
ers of
sandy silt
Sandy clay
w/sand lay-
?
Sandy w/
clay
Slightly
silty sand
Silty sand/
sandy clay
COMMENTS
( A K A !
L-244
L-246
Dry
L-259
Also
L-204A
Also
L-204B
Also
L-205A
Also
L-205B
L-247
L-248
L-249
L-250
-------
TABLE 5 continued
* » Outside of Slurry Walls
WELL LOCATION AND CONSTRUCTION DETAILS
WELL
NUMBER
MW-26
MW-27
MW-28
MW-29
MW-30
MW-31
MW-32
MW-33
MW-34
MW-35
MW-36
#1
DATE
COMPLETED
10/85
9/85
9/85
9/85
9/85
9/85
8/85
8/85
8/85
8/85
11/85
7/79
DEPTH
BLS
30'
18'
60'
29 .
60'
21'
20'
80'
29'
80'
85'
80'
WELL
DIAMETER
2H
2"
2"
2"
2"
2"
2"
2"
2"
2"
2"
3"
APPROXIMATE
LOCATION
400' South of
Rainwater
Basin 11
1200' South
of Rainwater
Basin #1
1200 South
of Rainwater
750' South
of cell #5
750' South of
cell #5
750' South of
cell #5
850' S. of
cell #5
outside of
slurry wall
400' S. of
Rainwater
Basin #2
Southwest
side of
facility
Westside of
facility near
Perimeter
Berm
Eastside of
Monofill
Westside of
BFI cell #3
SCREENED
INTERVAL
BLS
25-30'
13-18'
50-60'
24-29'
50-60'
11-16'
8-13'
65-80'
17-24'
70-80'
75-85'
75-80'
FORMATION
MONITORED
Clayey silt
clay
Silty sand/
silty clay
Clayey silt
clay
Sand/sandy
silt
Cl ay w/some
silt & sand
Sand/some
silty clay
Clay silt
Slightly
Clayey sand
Clay
Cl ay/si Ity
clay
Sand w/
thin clay
layers
Clayey sand
Dense sand
COMMENTS
( A K A
L-251
L-252
L-252
L-253
L-253
L-254
L-255
L-256
L-257
L-258
L-259
Never
samp let
L-53A
-------
TABLE 5 continued
* = Outside of Slurry Walls
WELL LOCATION AND CONSTRUCTION DETAILS
WELL
NUMBER
MW-3
MW-4
MW-5
MW-6
MW-7
MW-8
MW-9
MW-10
MW-11
MW-12
MW-13
MW-14
DATE
COMPLETED
8/85
8/85
8/85 .
7/85
8/85
8/85
8/85
8/85
8/85
8/85
8/85
8/85
DEPTH
BLS
22 '
22-
23'
15'
20'
66'
88'
80'
65'
80'
70'
90'
WELL
DIAMETER
2"
2"
2"
2"
2"
2"
2"
2"
2"
2"
2"
2"
APPROXIMATE
LOCATION
West of SWECO
cell 13
MW of SWECO
cell 11
West of BFI
cell #1
NE corner of
BFI cell 16
North of BFI
Cell #6
North of BFI
East of SWECO
cell #2
East of BFI
cell #1
West of SWECO
cell #3
West of SWECO
cell 13
Directly West
of BFI cell
cell #1
Directly East
of BFI Cell
#6
SCREENED
INTERVAL
BLS
17-22'
17-22'
18-23'
10-15'
15-20'
56-66'
83-88'
70-80'
60-65'
70-80'
62-67 '
80-90'
FORMATION
MONITORED
Clayey silt
clay
Silty clay/
clay
Silty sandy
clay
Sandy silt
Silty clay
Fine sand/
Silty sand
Grey sand
Silty clay/
sandy silt
Sandy clay/
grey sand
Silty sand
trace
gravel
Clayey silt
Clayey sand
Silty sand
pea gravel
trace/clay
COMMENTS
( A K A )
VOA
Detected
L-240
VOA
Deteceted
at 25'
L-241
L-242
L-243
Dry
VOA
Detected
at 17'
L-244
L-245
VOA at
88'
L-238
L-239
VOA at
52-56'
L-240
L-241
L-242
VOA
at 66*67'
L-243
-------
TABLE 5
WELL LOCATION AND CONSTRUCTION DETAILS
* = Outside of Slurry Walls
WELL
NUMBER
OW-1
OW-2
OW-5B
OW-6
OW-11A*
OW-1 IB*
OW-12A*
OW-12B*
OW-1 3*
OW-1 5
MW-1
MW-2
DATE
COMPLETED
3/81
3/81
4/77
4/77
5/77
5/77
5/77
5/77
5/77
?
8/85
8/85
DEPTH
BLS
46'
58'
60'
30'
30'
20.7'
25. 21
30'
29.4'
90'
18'
26'
WELL
DIAMETER
4"
4"
4"
4"
3"
3"
3"
3"
3"
6"
2"
2"
APPROXIMATE
LOCATION
100' E. of
BFI Cell 110
& 11
500' E. of
SWECO Cells
West of N.
End of SWECO
#1 Cell
NE Permieter
of site;
outside of
of slurry
wall
NE side of
facility
upgrad of
cell #12
Sidegrad of
cell #12
NE Perimeter
of site;
outside of
slurry wall
Downgrad of
cell #12
Just west of
active cell
#12 and 12L
West of SWECO
cell #2
East of BFI
Cell #1
SCREENED
INTERVAL
BLS
42 - 46*
55.5 - 58
?
?
?
17.7-20.7'
22.2-25.2
?
26.4-29.4'
80-90'
13-18'
21-26'
FORMATION
MONITORED
Sand at 41'
Sand at 56'
Sand at 55-
60'
Clay w/thin
sand
streaks
Below 23'
stiff clay
w/sand
Sand w/pea
gravel
Clay w/lay-
ers of silt
Below 18'
clay w/
sandy silt
1 ayers
Clay w/silt
1 ayers
White sand
-fine
Sandy clay
clay w/
sandy silt
COMMENTS
( A K A )
L-140
L-141
A-4
L-28
A-5
L-29
C-4
L-37
outside of
slurry
wall
C-3
C-3
L-36
L-203
Used as
De water
well
L-238
L-239
-------
TABLE 5 continued
* = Outside of Slurry Walls
WELL LOCATION AND CONSTRUCTION DETAILS
NELL
NUMBER
*2
13
15
D-l
D-2*
D-4*
D-5*
D-7*
D-8*
DATE
COMPLETED
7/79
7/79
7/79
12/77
12/77
3/78
12/77
3/78
3/78
DEPTH
BLS
25'
80'
80'
65'
12'
70'
12'
75'
20'
WELL
DIAMETER
3"
3"
3"
3"
3"
3"
3"
3"
3"
APPROXIMATE
LOCATION
North of
Rainwater
Basin #2
North of
Rainwater
Basin #2
400' S. of
cell #4
Southeast
corner of
facility
Southeast
corner of
facility
Far SW corner
of facility
Far SW corner
of facility
NW corner
landfill
cells
Far north-
upgrad of
landfill
cells
SCREENED
INTERVAL
BLS
20-23'
77-80'
77-80'
62-65'
9-13'
67-70'
9-12'
72-75'
17-20'
FORMATION
MONITORED
Sand
Sandy silt
Sandy silt
Clay w/silt
pockets
Silty sand
Silty clay
w/silt
pockets
Lower part
of White
Sand
Dense grey
sand
Sandy silt
w/trace
clay
COMMENTS
( A K A
L-54
L-55B
Caved in
Screened
in clay
instead
of sands
outside o
slurry
wall
outside
of slurry
wall
outisde c
slurry
wall
outside c
slurry
wall
outside c
slurry
wall
-------
TABLE 6
TOX Sampling Results
February 20, 1984
Sample
Identification
Total
Organic Hal ides
Quality Assurance
Actual/Found
(mg/L CD
D 1
D 2
D 8
5 B
OW 12 A
OW 11 B
D 4
OW 13
D 5
D 7
4
9
260
16
5.
2
18
1
1
0
.3
.5
5
.0
.9
.4
.7
5
12
240
38
2
1
15
2
1
1
.3
.4
.5
.5
.3
.4
.3
1
6
270
38
7
1
13
3
1
1
.6
.5
.4
.5
.9
.7
.4
1
8
230
41
3
1
11
1
1
1
.6
.7
.4
.9
.9
.7
.0
0
0
0
0
0
0
0
0
0
0
.200/0
.200/0
.200/0
.200/0
.200/0
.200/0
.200/0
.200/0
.200/0
.200/0
.205
.208
.193
.203
.185
.196
.203
.185
.195
.216
Date/Time
Analyst
12-29/0800/MS
01-04/0800/MS
01-16/0800/MS-GS
01-09/0800/MS
01-05/0800/MS
01-06/0930/MS
01-09/0800/MS
01-05/0800/MS
01-12/0800/MS-GS
01-16/0800/MS
-------
TABLE 7
SAMPLING POINT LOCATIONS
SAMPLING
POINT
D-7
D-8
Sweco #2
BFI-1
MW-18
MW-19
MW-20
MW-21
MW-2
MW-10
MW-8
MW-7
MW-1
M-5=MW-36
D-l
MW-3
Underdrain
RW #2
New mixing basins;
leak detection
system
MW-29
#2 well
OW-13
OW-1
SAMPLING RATIONAL
Ambient Water Quality
Ambient Water Quality
Leachate Characterization
Leachate Characterization
Plume Delineation
Plume Delineation
Known Contaminated Well
Known Contaminated Well
Well Downgrad. of suspected contam. source
Well near suspected contam. source
Vertical plume Delineation
Adjacent to suspected contam. source
Plume Delineation
Never tested; adjacent to monofill
State request; most downgrad well
Suspected tail of plume
Basin contains potentially contam. rain
runoff
Check Integrity of mixing basin
construction
Monitor shallow aquifer beneath area of
discharge from rainwater basin #2
Check shallow aquifer for release from old
mix basins
Downgrad of monofill & active cell 12L -
shallow aquifer
Check shallow aquifer beneath cell
-------
GROUND-WATER TASK FORCE
PARAMETERS COLLECTED AT CECOS INTERNATIONAL, INC,
Parameter
Bottle
Preservative
1. Volatile Organic Analysis (VOA)
Purge and Trap
Direct Inject
2. Purgable Organic Carbons (POC)
3. Purgable Organic Halogens (POX)
4. Extractable Organics
5. Pesticide/Herbicide
6. Dibenzofuran/Dioxin
7. Total Metals
8. Dissloved Metals
9. Total Organic Carbon (TOC)
10. Total Organic Halogens (TOX)
11. Phenols
12. Cyanide
13. Sulfate/Chloride
14. Nitrate/Ammonia
2 - 60-ml VOA vials
2 - 60-ml VOA vials
1 _ 60-nl VOA vial
1 . 60-ml VOA vial
4 - 1-qt. amber glass
1- 1-qt. amber glass
1-qt. amber glass
1-qt. plastic
1-qt. plastic
4-oz. glass
1-qt. amber glass
1-qt.amber glass
1-qt. plastic
1-qt. plastic
1-qt. plastic
HN03
HN03
H2S04
NaOH
-------
Organic Analysis Summary
Parameters
D3-2, 4-dinitrophenol
Methyl ene Chloride
Acetone
Chloroform
1, 2-Di chl oroethane
1 , 1 , 2-Tr i chl oroethane
Toluene
Phenol
2-Chl orophenol
2,6-Dichlorophenol
Ethane, 2 , 2-Di chl orophenol -1,1,1-
trifluoro
Methyl benzene
Aziridine, 2-hexyl
Furan, tetrahydro
Cyclohexane, methyl -
2-Cycl ohepten-1-one
Cyclopentanol, 2 -methyl -,cis-
Cyclopentanone, 2-methyl
2, 4-Di chl orophenol
2,6-Dichlorophenol
2,4-D
2,4,5-T
2-Hexanone
Acetic Add
EPA SAMPLE LOCATION (ppm)
MW-21
3.8E+05
77000
6300
5300
8300
9400
630
4000
8600
MW-18
15
MW-3
78
MW-19
16
MW-1
8.1
OW-13
n'
T5W-1
--
1 nn
1UU
MW-20
4600
650
V w V
~T £. f\
760
T f f\f\
7600
nf\f\
700
660
V v V
f f\f\
Kl 11 1
\J\J\J
onnn
^UUU
Qd
jH
oori
tL£.\J
•nftr*
390
MW-29
1fi
1U
26
inn
X \J\J
MW-b
45
1 **
29
10
JL V
a
J
-------
Inorganic Analysis Summary
Parameters
Al umi num
Antimony
Arsenic
Barium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Tin
Vanadium
Zinc
POC
POX
TOC
TOX
Ammonia Nitrogen
Sulfate
Chloride
Total Phenols
Cyanide
EPA SAMPLE LOCATION (ppm)
MW-3
19900
7.1
795
3
163000
26
12300
70600
903
4950
168000
31
40
.015
1200
53
1600
15500
404000
MW-7
3480
474
66600
13
1970
28900
178
52800
14
7.3
170
3100
55000
D-8
14300
7.7
194
21800
7220
7880
296
21
3800
27
240
9000
12200
D-7
681
227
16700
592
6110
181
49200
18
6.8
290
1100
6100
MW-2
10800
11.2
602
96000
6150
44200
214
142000
34
8
1200
21
260
6400
164000
MW-20
804
988
3
196000
10
52
3280
84100
1970
38
143000
15
4000
9800
1300
20000
310
505000
5200
16
MW-19
5210
799
145000
10
2480
58600
215
110000
19
26
260
9000
128000
MW-1
281000
1.13
1550
22
85000
205
65
66
131000
63600
1400
152
22400
409000
377
308
1200
29
180
17500
392000
i
D-l
366
173
24800
560
10400
172
70400
9
8.9
250
4300
-------
Inorganic Analysis Summary
Parameters
Al umi num
Antimony
Arsenic
Barium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Tin
Vanadium
Zinc
Lead
POC
POX
TOC
TOX
Ammonia Nitrogen
Sulfate
Chloride
Total Phenols
Cyanide
Nitrate
EPA SAMPLE LOCATION (ppm)
OW-13
894
425
64800
205
17200
546
42700
26
5.9
200
1900
32400
M-5
16500
096
182
3
17300
14
6760
6260
205
35600
18
39
1.1
970
5.5
240
1200
4060
OW-1
157000
193
545
842
17
45300
157
31
66
73400
29700
1480
94
15300
43100
53
215
246
62
3400
2000
MW^Z9
46500
126
145
660
7
41400
55
23
26300
19000
902
4890
58100
65
67
21
1400
21
550
15500
4060
540
MW-10
10900
175
2460
7
3710
4290
50
3390
62300
21
4800
240
9000
10100
10
MW-8
9470
176
18600
12
4480
7390
231
49100
820
250
5500
6100
#2
495
1190
14600
1120
7590
6480
13
9.8
190
2900
142000
MM-Z1
3020
94
2850
6
535000
16
40
4390
236000
2340
56
236000
101
23
88000
246000
86000
350000
170
6000
1440000
3000
MW-18
1840
147
3
23100
13
15
1040
6410
241
58600
13
209
1200
15
200
800
22300
12
-------
LEACHATE FROM BFI CELL #1
Compound
Concentration, ug/L
Acetone
2-Butanone
Benzene
4-Methyl-2-pentanone
Toluene
2,4-Dichlorophenol
2,4,6-Tn'chlorophenol
2,6-Dichlorophenol
Aluminum (T)
Antimony (T)
Arsenic (T)
Barium (T)
Cadmium (T)
Calcium (T)
Chromium (T)
Cobalt (T)
Copper (T)
Iron (T)
Lead (T)
Magnesium
Manganese (T)
Mercury (T)
Nickel (T)
Potassium (T)
Sodium (T)
Vanadium (T)
Zinc (T)
POC
POX
TOC
TOX
Total phenol
Ammonia nitrogen
Sulfate
Chloride
Pentanoic acid, 3-methyl
Oxirane, (Butoxylmethyl)
Hexanoic acid
Pheno, 2,4-Dichloro-
Benzene acetic acid
Acetic acid, (2,4-Dichlorophenoxy)-
Acetic acid, (2,4-Dichlorophenoxy) isomer
Phenol, 4,4 -(1-Methylethylidene)bis-
Acetophenox
5,1000
1,1000
210
740
300
36,000
15,000
22,000
7,840
1,360
960
315
10
1,480,000
193
316
90
290
13.7
6,110
174
45
1,230
628,000
3,550,000
1,410
12,400
8,900
11,000
1,960,000
270,000
18,000
26,000
3,880,000
809,000
4,100
2,500
2,900
18,000
5,000
94,000
19,000
5,100
3,200
-------
LEACHATE FROM SWECO CELL #2
Compound
Concentration, ug/L
Vinyl chloride
Chloroethane
Methylene chloride
Acetone
1,1-Dichloroethane
trans-1,2-Dichl oroethene
Chloroform
1,2-Dichlorethane
2-Butanone
Trichloroethene
Toleune
Hexachlorobutadiene
Hexachlorobenzene
Aluminum (T)
Arsenic (T)
Barium (T)
Beryllium (T)
Cadmium (T)
Calcium (T)
Chromium (T)
Cobalt (T)
Copper (T)
Iron (T)
Lead (T)
Magnesium (T)
Magnanese (T)
Mercury (T)
Nickel (T)
Potassium (T)
Silver (T)
Sodium (T)
Vanadium (T)
Zinc (T)
POC
POX
TOC
TOX
Ammonia nitrogen
Sulfate
Chloride
Hexachlorobutadiene
Hexachlorobenzene
530
160
59
400
20
130
66
66
210
47
100
160
75
1,570,000
277
39,200
29
90
3,800,000
1,160
308
3,640
850,000
79,600
682,000
568,000
8.0
1,060
114,000
20
930,000
1,600
11,100
3,900
650
171,000
6,600
1,310
10,000
5,840,000
49
24
-------
LEACHATE FROM SWECO CELL #2
Compound Concentration, ug/L
Bicyclo [2.2.1] heptane-2-one, 1,3,3-tri 170
(scan No. 573)
Bicyclo [2.2.1] heptan-2-one,1,7,7-trimethyl 110
(scan No. 585)
Bicyclo [2.2.1] heptan-2-,01, 1,3,3-trimethy! 26
(scan No. 610)
7-oxy abicyclo [2.2.1] heptane, 1-methyl-l 32
(1-methyl ethyl)
Benzene, methyl 85
Propanolc acid, 2-methyl 47
Hexanoic acid 67
Propanedioic acid 200
Hexanoic acid, 2-methyl 62
Hexanoic acid 140
Hexanoic acid 100
l,3-Butadiene,l,l,3,4-tetrachloro 15
Bicyclo [2.2.1[ heptan-2-one, 1,3,3-trimethyl 210
(scan No. 210)
Bicyclo [2.2.1] heptan-2-ol, 1,3,3-trimethyl 120
(scan No. 515)
Bicyclo [2.2.1] heptan-2-one, 1,7,7-trimethyl 610
(scan No. 535)
Cyclohexanol, 1-methyl-4-(1-methyl ethenyl) 45
Bicyclo [2.2.1] heptan-2-ol, 1,7,7-trimethyl-, 20
endo
l,6,10-Dodecatrien-3-oL, 3,7,11-trimethyl-, 260
[S-(z)-
3-Cyclohexane-lmethanol, .alpha., alpha.4- 220
trimethyl
1-Octanol, 2-butyl- 42
4-Hepten-3-one, 2,5,6-trimethyl 1,600
Cyclohexanemethanol, 4-hydroxy-.alpha., 1,800
.alpha, 4-tri
1,1' Biphenyl 34
Benzene, acetic acid 41
Benzene, 1,2,3,5-tetrachloro- 19
Undecane 3-ethyl 21
Propanedioic acid 87
Hexanoic acids, 2-methyl 33
Benzene, l-methyl-4-(l-methyl ethyl)- 19
1,3, Butadiene, 1,1,3,4-tetrachloro 9
Hexanoic acid, 2-ethyl 13
1-Dodecyne 20
3-Cyclohexen-lol, 4-methyl-l-(l-methyl 70
ethyl)-
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RAINWATER BASIN #2 UNDERDRAIN
Compound Concentration, ug/L
POC 41
POX 6
TOX 16
Total phenols 26
Ammonia nitrogen 250
Sulfate 11,000
Aluminum (T) 1,090
Barium (T) 262
Cadmium (T) 4
Calcium (T) 44,100
Chromium (T) 20
Copper (T) 72
Iron (T) 1,840
Magnesium (T) 18,800
Manganese (T) 297
Sodium (T) 58,900
Zinc (T) 66
Oxgenated compound 5.19
Cyclohexane, methyl- 30
Cyclopentanol, 2-methyl-, cix- 10
Ethanone, l-[4-(1-hydroxy-l-methyl 8
ethyl) phenyl]-
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