JUy1987
EPA-700 8-87-009
Hazardous Waste Ground-Water
Task Force
Evaluation of
Koppers Tie Plant
Grenada, Mississippi
&EPA
US Environmental Protection Agency
Mississippi Department of Natural Resources
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JUNE 22, 1987
HAZARDOUS WASTE GROUND WATER TASK EVALUATION
OF KOPPERS CO., INC.
GRENADA, MISSISSIPPI
UPDATE
The Hazardous Waste Ground Water Task Force (Task Force), in
conjunction with the Mississippi Department of Natural Resources (MSDNR),
evaluated the ground water monitoring system at the Koppers Tie Plant
facility in Grenada, Mississippi during the week of May 19, 1986. Several
deficiencies pertaining to the RCRA ground water monitoring system were
noted during the evaluation. S.E. Matthews, project coordinator for the
evaluation, compiled a report that detailed these deficiencies and
summarized results from water quality samples collected from RCRA
monitoring wells at the facility.
The purpose of the Task Force evaluation was to determine the
adequacy of Kopper's ground water monitoring program with regard to State
and Federal ground water monitoring requirements. Specifically, the
objectives of the evaluation were to:
Determine compliance with 40 CFR Part 265 interim status ground
water monitoring requirements and the State's counterpart
regulations.
Evaluate the ground water monitoring program described in the
facility's RCRA Part B Permit application for compliance with
40 CFR 270.14(c) requirements and the State's counterpart
regulations.
Determine if hazardous waste or hazardous waste constituents have
entered the ground water beneath the facility.
This update chronicles activities at the Koppers facility following
the Task Force evaluation and actions taken by the MSDNR and EPA Region IV
regarding RCRA ground water monitoring at the facility.
In August 1986, the MSDNR served a Commission Order on Koppers
regarding ground water monitoring deficiencies and assessed a penalty of
$20,000. Koppers entered a plea of nolo contendere to the changes and
paid the penalty.
In October 1986, MSDNR ordered Koppers to submit an assessment plan
that would address the hydrogeology of the site. Information gathered
during the assessment was to provide data capable of determining if either
the RCRA regulated surface impoundment or the sprayfield had adversely
affected ground water beneath the facility. In November 1986, MSDNR
issued a Commission Order with a compliance schedule to gather information
for the assessment plan.
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In January 1987, Koppers submitted the "Report of Findings,
Hydrogeologic Investigation" for the surface impoundment and the
sprayfield. Based on technical reviews conducted by Task Force members,
it was the consensus that more hydrogeologic characterization was needed
for the site.
In March 1987, MSDNR advised Koppers by letter, of the ground water
information which should be included in their Part B submittal on
April 15, 1987, and that a site specific sampling and analysis plan
should be submitted.
In April 1987, Koppers submitted additional hydrogeologic
information in their Part B. This information was subsequently reviewed
by the Task Force and the following conclusions were made:
Koppers has still not adequately defined site hydrogeology,
in that very little site specific geology is available and no
vertical hydraulic gradient has been established.
Koppers proposed ground water monitoring system is unaccept-
able. Well R-l is improperly constructed. Well R-10 shows
penatachlorophenol contamination and is screened in a silty
material different from the geologic settings other wells
are screened in.
Additional clustered wells would be advisable because the
constituents of concern have a high specific gravity and tend
to sink. Also, based on the latest ground water elevation data
Koppers should consider a clustered well on the west side of
the unit.
Koppers should submit a site specific sampling and analysis
plan.
Mississippi is currently reviewing the Part B for adequacy and
completeness and will issue required notices upon completion of their
review.
Koppers is proceeding with an investigation to identify sources and
extent of contamination on the site. This will include additional
geologic and hydrogeologic investigations.
During the task force evaluation the flyash land farm was identified
as a RCRA regulated unit. This was later confirmed by MSDNR and EPA
Region IV. On March 25, 1987, MSDNR issued an order to Koppers which
required them to cease using the unit; submit a closure plan; install a
ground water monitoring system, which complies with Part 265 Subpart F of
the Mississippi Hazardous Waste Management Regulations; and submit a Part
B post-closure application or a demonstration of clean closure.
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This order is currently under litigation.
Koppers was also ordered to submit a report which demonstrates
conclusively whether or not K001 sludge has been applied to or has
accumulated on its spray field. MSDNR is currently reviewing this report,
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUND WATER TASK FORCE
GROUND WATER MONITORING EVALUATION
KOPPERS TIE PLANT
GRENADA, MISSISSIPPI
MARCH 1987
SHARON E. MATTTHEWS
Project Coordinator
Environmental Services Division
Region IV
US-EPA
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TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY
INTRODUCTION 1
Background 2
SUMMARY OF FINDINGS AND CONCLUSIONS 3
COMPLIANCE WITH INTERIM STATUS REQUIREMENTS 3
Inadequate Hydrogeological Characterization 3
Improper Monitoring System 5
Failure to Address Effects of Possible Confining Units 5
Monitoring Well Construction Deficiencies 5
Inadequate Ground Water Sampling and Analysis Plan 6
Preparation, Evaluation and Response 6
Annual Report 6
Laboratory Evaluation 6
Monitoring Data Analysis 6
TECHNICAL REPORT
INVESTIGATIVE METHODS 7
Records/Documents Review and Evaluation 7
Facility Inspection. 7
Laboratory Evaluation 8
Ground Water Sampling and Analysis 8
WASTE MANAGEMENT UNITS AND OPERATIONS 8
Surface Impoundment Description. 8
Sprayfield Description 10
Solid Waste Management Units 11
FACILITY OPERATIONS 12
REGIONAL GEOLOGY/HYDROGEOLOGY 13
Geology 13
Hydrogeology of RCRA Facility Area 15
Ground Water Flow Directions and Rates 16
Adequacy of Hydrogeologic Characterization 16
GROUND WATER MONITORING PROGRAM UNDER INTERIM STATUS 17
Regulatory Requirements 17
MHWMR Part 265 Subpart F 18
Compliance History 18
Monitoring Well Data 21
Ground Water Sampling - Detection/Assessment 23
Koppers Sampling Collection and Handling Procedures 26
Alternate Concentration Limits (ACL1 s) 27
TASK FORCE SAMPLE COLLECTION AND HANDLING PROCEDURES 28
LABORATORY EVALUATION 30
MONITORING DATA ANALYSIS 30
REFERENCES 33
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APPENDICES
A - Task Force Analytical Results
B - Region IV BSD Athens Analytical Results
C - Monitoring Well Logs
D - "Procedures for Ground Water Sampling"
Koppers Company. Inc.
FIGURES
1 - Facility Location Map
2 - RCRA Monitoring Wells Location Map
3 - Surface Impoundment Diagram
4 - Flow Diagram of the Wastewater Treatment System
5 - Map showing the location of the Solid Waste Management Units
TABLES
1 - Stratigraphic Units and Their Water-Bearing Characteristics
2 - RCRA Ground Water Monitoring Parameters
3 - Monitoring Well Construction Data
4 - Wells Designated for Ground Water Monitoring During Interim Status
5 - Sample Collection Data
6 - Order of Sample Collection, Bottle Type and Preservative List
7 - Analytical Data Summary - HWGWTF
8 - Analytical Data Summary - ESD. Athens
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GROUND WATER MONITORING COMPLIANCE EVALUATION
KOPPERS TIE PLANT
GRENADA, MISSISSIPPI
ESD PROJECT #86-292
EXECUTIVE SUMMARY
INTRODUCTION
Task Force Effort
Operations at hazardous waste treatment, storage and disposal (TSD)
facilities are regulated by the Resource Conservation and Recovery Act
(RCRA P.L. 94-850). Regulations promulgated pursuant to RCRA (40 CFR Parts
260 through 265, effective on November 19, 1980 and subsequently modified)
address hazardous waste site operations including monitoring of ground water
to ensure that hazardous waste constituents are not released to the environ-
ment. The regulations for TSD facilities are implemented (for EPA administer-
ed programs) through the hazardous waste permit program outlined in 40 CFR
Part 270.
The Administrator of the Environmental Protection Agency (EPA) establish-
ed a Hazardous Waste Ground Water Task Force (Task Force) to evaluate the
level of compliance with ground water monitoring requirements at commercial
off-site and selected on-site TSD facilities and address the cause of non-
compliance. The Task Force is comprised of personnel from EPA Headquarters
Core Team, Regional Offices and the States.
There will be eight Task Force evaluations conducted in Region IV during
FY-86 and FY-87. Evaluations have been conducted at both of the region's two
off-site commercial facilities. Six evaluations will be conducted at private,
on-site facilities. The evaluation of Koppers was the second private on-site
investigation in Region IV and was conducted the week of May 19, 1986.
Objectives of the Evaluation
The principal objective of the inspection at Koppers Tie Plant was to
determine compliance of the RCRA surface impoundment and the sprayfield with
the requirements of 40 CFR Part 265, Subpart F - Ground Water Monitoring and
to determine compliance with related requirements of the Part 265 interim
status regulations and the state's counterpart regulations. The ground water
monitoring program described in the RCRA Part B permit application was also
evaluated for compliance with Part 270.14(c) and potential compliance with
Part 264. Recent amendments to RCRA require that facilities seeking a RCRA
permit also address solid waste management units at the facilities; therefore,
any ground water monitoring wells associated with solid waste management
units at the facility were to be sampled to provide data and information to
be used during the permit review process.
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The Koppers Tie Plant inspection was coordinated by the Region IV United
States Environmental Protection Agency (EPA), Environmental Services Division
and included participation by the EPA Headquarters Core Team, Region IV EPA
Waste Management Division and the Mississippi Department of Natural Resources,
Bureau of Pollution Control. In general, the evaluation involved a review of
State, Federal and facility records, a facility inspection, a laboratory
evaluation and ground water sampling and analysis.
BACKGROUND
Locale/General
The Koppers Tie Plant facility is located about five miles southeast of
Grenada, Mississippi. The site is situated about halfway between U.S. Highway
51 and the Batupan Bogue (see Figure 1). The facility uses creosote and
pentachlorophenol-in-oil in the pressure treatment of wood products for rail-
road cross ties, utility poles and pilings. The hazardous wastes produced
by this facility are K001, U051, and F027 and consist of bottom sediment sludge
from the treatment of wastewater from wood preserving processes that use
creosote and/or pentachlorophenol (K001), and waste creosote (U051) or certain
waste pentachlorophenol (F027). The waste management units at the facility
are a drum storage area, a surface impoundment and a sprayfield. For purposes
of the Task Force inspection, the ground water monitoring systems at the sur-
face impoundment and the sprayfield were evaluated for compliance with the
40 CFR Part 265, Subpart F, 270.14 (c) and 264 regulations.
Wood treating has been carried out in this locale since 1903. Koppers
took over the operation in the 1930's.
The facility has RCRA interim status (EPA ID# MSD 007 027 543). In
January 1984, a preliminary RCRA Part B permit application was submitted to
the Mississippi Department of Natural Resources (MSDNR) for review. The
State of Mississippi has final RCRA authorization for permit issuance.
MSDNR was granted RCRA Phase I interim authorization on January 7, 1981
which allows the State to enforce State-promulgated regulations in lieu of
Federal regulations promulgated under RCRA (40 CFR Parts 260 through 265).
RCRA activities at this site have, therefore, been governed by State regula-
tions.
Phase II, A and B interim authorization was granted on August 31, 1982.
Phase II C was granted April 26, 1983. The state received final authorization
on June 27, 1984 for all aspects of RCRA except for the 1984 amendments.
Since the preliminary Part B submittal, there have been several revisions
as a result of MSDNR, and to a lesser extent, EPA Region IV reviews. The
latest version of the Part B was submitted January 1986 and has been reviewed.
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Several deficiencies were noted. An order was issued in August 1986 to
correct these deficiencies. The facility has received several Notices of
Deficiency (NOD's) and Commission Orders from MSDNR for inadequate Part B
submittals and for non-compliance with 40 CFR Part 265 Subpart F regulations.
SUMMARY OF FINDINGS AND CONCLUSIONS
The Task Force investigated the interim status ground water monitoring
program implemented by Koppers Tie Plant. The consensus opinion of the Task
Force was that this program is not in compliance with 40 CFR Part 265, Sub-
part F and the State counterpart regulations, which are the equivalent regula-
tions to 40 CFR Part 265, Subpart F. The information submitted to date is
also insufficient to satisfy the requirements of 40 CFR Part 270.14(c).
This investigation revealed that two ground water monitoring programs
have been implemented at the surface impoundment since November 19, 1981.
The basis for changing the original program was to change the ground water
monitoring system from a detection to an assessment phase. This change
resulted in the installation of a new RCRA system that consisted of wells
R-5 to R-9, with R-5 being designated the new upgradient well. For reasons
described in this report, this well is inadequate as an upgradient well.
The investigation also revealed inadequacies in the area of hydrogeologic
characterization. The facility has begun an Alternate Concentration Limit
(ACL) evaluation, but has developed relatively no information to prove their
premise that an attenuation mechanism can be used at this site. The Task
Force investigation also revealed that some water quality data from the spray-
field had not been submitted to MSDNR or EPA for review, and that the sampling
and analysis plan is incomplete.
Analytical results of ground water samples collected from the RCRA moni-
toring systems at the surface impoundment and the sprayfield indicate some
ground water degradation had occurred at the site. The lack of a complete
hydrogeologic chracterization makes it difficult to establish the on-site
source of the contamination. In addition, there is a concern that surface
water degradation is occurring due to the discharge of contaminated ground
water. An oily sheen was noted floating on a tributary to Batupan Bogue
running through the property. Oily liquid was seen oozing from the banks
into this tributary.
The following is a more detailed summary of the inspection findings and
conclusions.
COMPLIANCE WITH INTERIM STATUS REQUIREMENTS
Inadequate Hydrogeological Characterization (40 CFR Part 265.91)
Koppers has not adequately characterized the hydrogeology of the site.
It is the consensus of the Task Force that Koppers Tie Plant should be required
to:
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(1) Adequately characterize the geology of the site, at a minimum,
a. define the uppermost aquifer.
b. define the vertical and lateral extent of the base of the
uppermost aquifer and any confining beds contained within and
below that aquifer.
c. prepare a stratigraphic section, fence diagram, etc. of the
geology underlying the surface impoundment and sprayfield.
(2) Adequately characterize the ground water hydrology of the site,
at a minimum,
a. conduct a pumping test(s) to determine if interconnection
exists between the various aquifers underlying the site,
b. install a series of nested piezometers to adequately determine
the potentiometric surface at the surface impoundment and
sprayfield.
c. determine the influence of precipitation, nearby pumpage, etc.
on water levels and hydraulic gradients.
d. survey all wells relative to mean sea level (MSL).
e. design and implement an investigatory plan capable of demon-
strating the absence or presence of dense non-aqueous phase
liquids beneath the regulated unit. If dense non-aqueous
phase liquids are found to have escaped from the regulated
unit, Koppers should accomplish the following tasks:
1. determine the direction of non-aqueous phase liquid
migration. Base this determination on aquifer properties,
contaminant mobility characteristics and the availability
of migratory pathways beneath the site. Note that migrating
pathways for dense non-aqueous phase liquids may consist of
structural contours of aquitard units, planes or channels
of permeability variations within the aquifer, root zones,
lithologic contact planes, buried pipelines, etc.
2. determine the rate of non-aqueous phase liquid migration.
Base this determination on consideration of contaminant
properties such as density, viscosity, and the surface
tension, capillary pressures and pore radii of the media,
as well as subsurface structural gradients and hydraulic
gradients.
(3) Provide all previously requested data not submitted with the 1-7-86
Part B submittal, specifically,
a. potentiometric water level data and maps,
b. water quality analyses,
c. map showing all solid waste management units,
d. most recent report(s) on the sprayfield - include water quality,
geologic logs, etc.,
e. recent pumping data for production wells on-site
f. revision of Part B for the sprayfield.
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Improper Monitoring System (40 CFR Part 265.91)
It appears from water quality data that the new upgradient well R-5
at the surface impoundment is not representative of background water quality.
It is located near a heavy traffic area and is close to stacks of treated
lumber. It is also downgradient from an old wastewater pond which is classi-
fied as a solid waste management unit (SMU). A new upgradient well must be
installed at the surface impoundment to collect background data on water
quality that has not been affected by the facility as per 40 CFR Part 265.91
(a)(l)(i) and (ii) regulations.
40 CFR 265.278 requires an unsaturated zone monitoring system around the
sprayfield. The system would provide valuable information as to the adequacy
of treatment and potential contaminant migration.
Failure to Address Effects of Possible Confining Units (40 CFR Part 265.91)
Existing geotechnical data indicate the presence of a clay unit under-
lying the site. The thickness and continuity of this clay have not been
determined. This clay may or may not be a confining unit between the upper
saturated zone and underlying aquifers. Interconnection between the aquifers
underlying the site should be addressed. At the time of the inspection,
the uppermost aquifer had been defined only through a literature review.
Monitoring Well Construction Deficiencies (40 CFR Part 265.91(c))
After reviewing the monitoring well construction data, several defi-
ciencies were noted. The following comments and questions need to be
addressed by the facility, so that a determination can be made as to the
adequacy of the well construction:
1. What method was used to drill the surface impoundment wells? Was
any type of drilling fluid used in any of the wells?
2. What are the elevations of all the wells relative to MSL (mean sea
level)?
3. Why was PVC casing chosen over teflon-coated or stainless steel con-
sidering that organics are of primary concern at this facility?
4. What are the dimensions of the sand pack? Were any sieve analyses
run on the sand pack? Could an adequate sand pack explain the high
turbidity?
5. Is the annular space adequately sealed?
6. How long were the wells developed? Were the wells developed until pH,
temperature and specific conductance stabilized?
7. Are any of the wells capped at the bottom?
8. There is a possibility of contamination by placing cuttings from the
well on top of the sand pack. What measures were taken to prevent
this?
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Inadequate Groundwater Sampling and Analysis Plan (40 CFR Part 265.92)
The sampling and analysis plan that has been submitted is not site-
specific for this facility. The plan should be rewritten to reflect the
actual procedures followed at this Koppers facility. Also, there is no
reference to a specific analytical procedure for each parameter or constituent
which are analyzed or measured. These procedures are required to be included
in the sampling and analysis plan by 265.92 (a) (3).
Preparation. Evaluation and Response (40 CFR Part 265.93)
Because the facility is in assessment, a specific plan for a ground water
quality assessment program is required. The plan for this facility is not
adequate to meet the 40 CFR 265.93 requirements. Specifically, the sampling
and analytical methods must be specified by the facility as per 265.93 (d)
(3)(ii) regulations. Also, the extent and rate of migration of hazardous
waste into the ground water must be determined as per 265.93(d)(4)(i).
During the Task Force inspection, no historical water quality data for the
surface impoundment for 1985 was available for review. From discussions with
facility personnel, it was stated that there had been no quarterly monitoring
for the surface impoundment since the latter part of 1985. This is in con-
flict with the requirements of 265.93(d)(7)(i) that requires a facility to
continue a ground water quality assessment program on a quarterly basis that,
at a minimum, determines the rate and extent of hazardous waste constituents
in the ground water and the concentration of the hazardous constituents in
the ground water.
Annual Report 265.94 (b)(2)
Koppers is required to submit an annual report containing the results
of the Ground Water Quality Assessment program that should include the rate
of migration of hazardous waste constituents in the ground water during the
reporting period. At the time of the Task Force inspection, an Annual Report
had not been submitted that characterized the horizontal and vertical extent
of the plume(s).
Laboratory Evaluation
To be issued at a later date as an addendum.
Monitoring Data Analysis
All data from analysis of samples collected during the task force in-
spection was evaluated and considered usuable except for the antimony and
much of the arsenic results. Pesticide, herbicide and dioxin data was
considered to be unreliable.
A review of the data indicates ground water degradation has occurred at
the facility. Upgradient well R-5 showed the most metals, extractable and
purgeable compounds. Several wells, specifically R-l, R-4, R-5 and R-7 at
the surface impod of 50 ug/1.
Their presence or the concentrations at which they were detected suggest
they are either not naturally occurring or are above background concentrations
in this area.
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TECHNICAL REPORT
INVESTIGATIVE METHODS
The Task Force evaluation of the Koppers site consisted of:
o A review and evaluation of records and documents from EPA Region
IV, MSDNR and Koppers Tie Plant.
o A facility on-site inspection conducted May 19-21, 1986.
o An off-site analytical laboratory evaluation.
o Sampling and subsequent analysis and data evaluation for the ground
water monitoring systems at the surface impoundment and the spray-
. field.
Records/Documents Review and Evaluation
Records and documents from EPA Region IV and the MSDNR offices, compiled
by an EPA contractor (PRC), were reviewed prior to the on-site inspection.
The first day of the inspection (May 19, 1986), the Task Force met with
Mr. Rock Clayton, Plant Manager for Koppers Tie Plant, and Mr. Dave King,
Environmental Officer. Mr. Clayton was helpful in giving a general overview
of the plant and locating past solid waste management units.
The next two days were spent with Mr. Martin Schlesinger, Koppers
Corporate office, and Mr. Brad Peebles, consultant from Law Environmental
Services. Neither had been to the facility before and could offer little in
the way of information. There were very few on-site facility records available
for review. It was explained that most information was kept at the Koppers
Corporate office in Pittsburgh, PA or at the consulting firm. Mr. Schlesinger
and Mr. Peebles reviewed the material that had been copied from EPA Region IV
and MSDNR files and could add little to what had been copied. The last day
of the inspection, Mr. Ken Lindval gave the Task Force a tour of the plant.
Facility Inspection
The facility inspection, conducted May 19-21, 1986, included identifi-
cation of waste management units, identification and assessment of waste
management operations and pollution control practices and verification of
location of ground water monitoring wells.
Company representatives were interviewed to identify records and docu-
ments of interest, answer questions about the documents and explain (1)
facility operations (past and present), (2) site hydrogeology, (3) ground
water monitoring system rationale, (4) the ground water sampling and analysis
plan and (5) laboratory procedures for obtaining data on ground water quality.
Because ground water samples are analyzed by an off-site laboratory, person-
nel from these facilities will also be interviewed regarding sample handling
and analysis, and document control.
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Laboratory Evaluation
The off-site laboratory facility handling ground water samples will be
evaluated regarding its respective responsibilities under the Koppers ground
water sampling and analysis plan. Analytical equipment and methods, quality
assurance procedures and documentation will be examined for adequacy. Labora-
tory records will be inspected for completeness, accuracy and compliance with
State and Federal requirements. The ability of the laboratory to produce
quality data for the required analyses will be evaluated. The evaluation
results will be issued at a later date as an addendum.
Ground Water Sampling and Analysis
Sampling Locations
Water samples were collected from wells R-l, R-4, R-5, R-7 and R-9 at
the surface impoundment, and from wells SF-1, SF-2 and SF-4 at the spray-
field. The selection of these eight wells for sampling was based on well
locations to provide areal coverage both up and downgradient at the surface
impoundment and the sprayfield. The locations are identified in Figure 2.
Samples were taken by an EPA contractor and sent to EPA contractor lab-
oratories for analysis. EPA Region IV requested and received four sample
splits. MSDNR and Koppers declined to split samples for independent analysis.
Data from sampling analysis will be reviewed to further evaluate the Koppers
ground water monitoring program and identify possible contaminants in the
ground water. An analytical data summary of the results from the samples
collected for the Task Force is presented as Tables 7 and 8. Actual ana-
lytical data is available from EPA Region IV.
WASTE MANAGEMENT UNITS AND OPERATIONS
Surface Impoundment Description
The RCRA waste management facility is a wastewater treatment lagoon (sur-
face impoundment) that is about one-half acre in size and has a maximum opera-
ting depth of about 7 feet. Although the surface impoundment has no docu-
mented liner, it was constructed in the near-surface clays and silts present
at the site. The surface impoundment has been in operation since the mid-
1970's. (See Figure 3).
The impoundment is an irregular-shaped rectangle which measures 284' x
95' from top of dike to top of dike. It is surrounded by a 4-foot high metal
mesh and 2 feet of barbed wire fence with warning signs posted. The bottom
of the impoundment is about 10' below the top of the dike (berm) with side
slopes of 1:3. The gross surface area at top of the dike is 26,980 ft2.
Koppers estimates 2,500 pounds or 312 gallons (100 percent solids) of sludge
will be collected each year and stored on the bottom of the impoundment. The
facility estimates a life of about 62 years under present conditions.
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The surface impoundment was constructed in the early 1970's by exca-
vating soil from within the containment area and using the excavated material
in the perimeter dike. No design drawings or documentation of construction
procedures were available for review. Verbal history indicates that the
impoundment was excavated in natural clay soils and the surface mechanically
compacted.
The ground elevation just beyond the downstream toe of the dike ranges
from about 206 to 209 feet. The impoundment has a bottom elevation of about
202 and 203 ft and the crest of the dike is generally at elevation 211 to 212
ft with what appears to be emergency spillway in the southwest corner at ele-
vation 210.4 feet. The dike has a crest width ranging from about 9 to 17
ft with about 12 ft being most typical. The dike is only about 5 ft high
above the outside ground level. Upstream (inside) slopes range from about
2.3 to 3.3 horizontal to 1 vertical and downstream (outside) slopes range
from about 1.5 to 2.8 horizontal to 1 vertical.
The maximum elevation of the fluctuating water level is about 209 feet.
The water level in the impoundment is controlled by plant operations. Both
the inflow to and the outflow from the impoundment can be regulated so that
the maximum water elevation is not exceeded. Typically, the water level is
well below the maximum elevation. Thus, there is a minimum freeboard of 2
ft except at the emergency spillway.
Law Engineering Testing Company personnel observed the conditions of
the surface impoundment dike on several occasions in mid-to late-1984. The
following is a summary of their inspection conducted August 2, 1984.
The dike crest and downstream slope are covered with grass and in the
denser wooded areas with pinestraw. Trees up to about 5 inches in diameter
are scattered around the dike, especially along the north and east sides.
No evidence of seeps or significant surface erosion was observed by Law
Engineering personnel. At the time of the site visits, the water level was
at about elevation 205 ft, which is below the lowest outside grade.
Based on soil borings drilled through and outside but adjacent to the
dike, clayey silts and silty clays were used to construct the dike. Generally,
foundation soils consist of clayey silts and silty clays to elevations ranging
from about 202 to 195 feet. The upper clayey soils are underlain by sands
with traces of silt. No unusually soft or wet zones were noted on the boring
records. The water level in the borings through the crest of the dike was
at about elevation 187 ft, well below the bottom of the dike and impoundment.
The water level in the borings outside the dike was likewise at about elevation
187 feet.
When the impoundment water level is at its maximum (elevation 209 ft) it
is only 3 ft above the lowest adjacent outside grade (elevation 206 ft).
Assuming a dike crest elevation of 211 ft and width of 12 ft and 2 horizontal
to 1 vertical slopes, the horizontal distance from the uppermost water-dike
contact through the dike to the downstream dike slope is 20 feet. Typically,
within the geotechnical engineering profession a 5 ft high earth dike retaining
3 ft of water would not be evaluated for potential slope in stability by soil
shear. Because of the geometry of the dike, any slope failures would essen-
tially be surface sloughs. The dike has been in operation for 10 years or
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more and no such sloughs were observed by Law Engineering personnel. Prelimi-
nary calculations showed that even if very low strength parameters for the
dike material are assumed, calculated factors of safety against dike shear
failure are well above the normal criterion of 1.5.
Normally trees in the size range of those on this dike (up to about 5
inches in diameter) should be removed to enhance inspection and maintenance
and to prevent roots of the eventually larger trees from developing poten-
tial seepage channels within the embankment. However, because of the geome-
try of this dike, the size of the trees, and because of regulatory require-
ments that the dike will be removed in less than four years, it was Law
Engineering's opinion that the trees should be left in place. They believe
that the usefulness of the trees to help control surface erosion outweighs
potential disadvantages of leaving the trees in place. The facility intends
to close the impoundment by November 1988.
The surface impoundment generates only one type of waste, K001 (bottom
sediment sludge from the treatment of wastewaters from wood preserving pro-
cesses using creosote or pentachlorophenol). The amount and schedule of
K001 received varies with the level of business the treating plant handles.
The hydraulic capacity of the surface impoundment is about 867,680 gallons.
After a long hydraulic detention time, wastewaters from this process generate
a small amount of bottom sediment sludge. The surface impoundment acts as
a polishing pond to remove oil from the effluent. The impoundment is pre-
ceded by a mechanical oil/water separator and flow equalization which re-
captures product and minimizes the amount of creosote which flows into the
impoundment and becomes waste. Wastewater from the impoundment is pumped
to a sprayfield for treatment. All flow between these unit processes are
piped and valved (see Figure 4).
Sprayfield Description
The sprayfield is located on the north-northwest section of the property.
It is about four acres in size and surrounded by a low berm (one to 3 feet)
that controls run-on/run-off. The ground surface slope is estimated to range
from zero to 3 percent. The field is covered with non-food chain vegetation
that includes bermuda grass, smart weed, panic grass and a broad leaf weed
dock. There are six willow trees located within the sprayfield.
The sprayfield was constructed upon native soils. These soils were
considered relatively uniform over the entire sprayfield as verified by
four hand auger borings conducted outside the perimeter of the sprayfield.
The Grenada series is a member of the fine silty mixed theimic Ochreptic
Fragindalf subgroup. The Grenada series soils are moderately well drained
and are characterized by a firm, dense subsurface horizon, a fragipan, at
approximately the two foot depth. The auger borings indicated the fragipan
can be 30 inches or more in thickness. The surface soil overlying the
fragipan is friable as well as the underlying soil layer which has a silt
loam texture. The permeability of the friable silt loam layer is consid-
ered moderately slow. The fragipan has slow to very slow permeability. Due
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to slow permeability of the fragipan, a temporary perched water table may
occur above this dense layer. One hand auger boring, on the north side of
the sprayfield, revealed free water at the 30 inch depth and relative dry
conditions at deeper depths.
The sprayfield receives wastewater after it has been pretreated by two
separate processes. The production process includes two oil/water separators
which operate in series. The first separator receives an oil/water mixture
and a flocculation agent. The solids are removed, pentachlorophenol and oil
are recovered and recycled back to the process before the wastewater passes
into the second separator. Here creosote is removed and recycled back to the
process. The wastewater effluent is then pumped to the surface impoundment.
Treatment occurs in the surface impoundment where biological processes degrade
organic constituents in the wastewaters and long term hydraulic detention
allows for oils to separate by gravity.
Effluent from the surface impoundment is periodically pumped to the
sprayfield. The frequency of pumping depends upon water levels within the
surface impoundment and climatic conditions. Spraying does not occur during
rainfall. The maximum application rate would be 1,800 gallons per day sprayed
in one 15 minute period. During periods of high evaporation the facility
(surface impoundment) will operate for days or weeks at a time between appli-
cations of effluent to the sprayfield.
There has been much discussion between the facility, US-EPA and the
Mississippi Department of Natural Resources as to whether this sprayfield
is a RCRA regulated unit. Until the facility proves there are no hazardous
waste constituents in the land treatment unit, EPA will regard the sprayfield
as a hazardous waste treatment unit. On November 8, 1985, Koppers submitted
a revised Part A as protective filing that included the sprayfield. Ground
water monitoring wells were installed around the sptayfield in August 1985.
Solid Waste Management Units
There was very little information on the solid waste management units
for the Koppers Tie Plant. According to facility personnel, there were two
wastewater/settling ponds, each less than one acre in size, that were closed
out before November 1980. The ponds were dug out and landfarmed but no ana-
lyses have been run to verify clean closure.
There is a three-acre landfarm that began operations when the two waste-
water/settling ponds were closed. The landfarm still receives some flyash
residue from the boiler process which burns U051 and F027 waste. According
to 261.3 (c)(2)(i), the ash resulting from the boiler is also considered a
hazardous waste. This would make the landfarm a regulated unit and subject
to interim status regulations that would include meeting the requirements
of 40 CFR Part 265 Subpart F.
There is also a waste pile at the north end of the yard that receives
debarking/cut wood ends and waste wood. It has been in existence for many
years and is still used today.
Throughout the facility are evidences of black oily materials, possibly
spills or runoff. The drip tracks are considered as solid waste management
units by EPA. Figure 5 shows the approximate location of the solid waste
man agement uni t s.
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It appears that there has been a release to ground water based on water-
quality data derived from the RCRA monitoring wells, particularly R-5, and
the oily discharge oozing from the banks into the tributary on the property.
The solid waste management information supplied by Koppers is insufficient
and the following data is needed to understand the potential for releases:
1) Analysis of historical air photographs;
2) Description of past processes used at the facility;
3) An estimate of the volume of creosote and pentachlorophenol that
has been used at the plant. These figures could be derived from
purchasing records.
It was noted during the inspection that the following could be considered
as potential solid waste management units:
penta sump cooling pond
creosote sump sumps 1,2 and 4
old separator emergency pond
industrial boiler
The facility should be required to submit information on the above -
mentioned units that would determine whether or not these actually are solid
waste management units.
FACILITY OPERATIONS
The Koppers Tie Plant operations in Grenada, Mississippi include wood
treating facilities, a drum storage area, a surface impoundment and a spray-
fi^ld which are used to treat wastewater streams and provide a no discharge
system for treated effluent. An in-plant process boiler also uses high BTU
spent residues for fuel. All of the waste associated with this facility are
derived from a common source which is the pressure treatment of wood products
(primarily railroad ties and telephone poles) with creosote and pentachloro-
phenol-in-oil. The hazardous waste produced by this facility, K001, U051
and F027, consist of bottom sediment sludge from the treatment of wastewater
from wood preserving processes that use creosote and/or pentachlorophenol
(K001), and waste creosote (U051) or certain waste pantachlorophenol (F027).
The solids wastes handled at this facility include, in addition to the above,
soil contaminated with creosote or pentachlorophenol, unreclaimable oil from
process storage tanks, and door pit waste from the treatment area. The door-
pit waste consists of wood chips, dirt and oil residues.
The Koppers Tie Plant uses creosote and pentachlorophenol-in-oil in the
pressure treatment of wood products for railroad cross ties, utility poles
and pilings. The raw materials include creosote, petroluem oil, pentachloro-
phenol and wood. Raw materials and treated products arrive and leave by rail
and truck.
Generally, wood comes to the plant pre-sized. It is seasoned at the plant
by air drying, steaming or the "Boultron" process.
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Once the wood is sized, it is pressure treated in a cylinder. Generally,
the wood is loaded on to tram cars which are pushed into the cylinder using
a small locomotive, lift truck, or similar equipment. The cylinder door is
sealed via a pressure tight door, and a vacuum is applied to remove most of
the air from the cylinder and wood cells. Treating solutionj is then pumped
into the cylinder and pressure applied. At the end of the process, the excess
treating solution is pumped out of the cylinder and back to storage for re-use.
A final vacuum is then pulled and any additional solution on the wood or in
the cylinder is pumped to storage for re-use. The cylinder door is opened
and the trams, loaded and treated wood, are pulled from the cylinder.
The container storage area receives three types of waste, U051 (creosote),
F027 (certain pentachlorophenol wastes) and K001 (bottom sediment sludge from
the treatment of wastewaters from wood preserving processes that use creosote
and/or pentachlorophenol). The U051 comes from cleaning of storage tanks, and
process equipment. These cleanings occur on an as needed basis. The K001
comes from cleaning of the surface impoundment and the oil/waste separator.
This cleaning also occurs on an as needed basis. F027 is generated when
pentachlorophenol is discarded.
REGIONAL GEOLOGY/HYDROGEOLOGY
To date, there has been little site-specific work done for the Koppers
Tie Plant facility. According to the Law Environmental consultant Brad
Peebles, a detailed assessment of the geology and hydrology would be under-
taken the summer of 1986. Results from the study are to include a site-
specific map of ground water divides, swales, etc.; a summary of all compo-
nents of flow; an ACL report to include preliminary values of contaminant
constituents with decay, dispersion and dilution factors; pu iping influences
and seasonal variations on the potentiometric surface; a model of the ground
water regime; soil analyses, and water quality analyses.
The hydrogeological and ground water flow discussion in this report are
based on findings reported by the Koppers consultants, Law Engineering of
Marietta, Georgia as a section of the Part B for this facility (February 27,
]985, revised 8/9/85).
Geology
The site is located in Grenada County and the loessal hills physiographic
area.
Grenada County can be divided into three physiographic areas: (from west
to east) th thinning progressively
to the east. (Grenada County Soil Survey, 1967).
The loessal hills are silty and the mantle of loess in Grenada County
is about 30 ft thick at its extreme western edge thinning progressively
to the east. (Grenada County Soil Survey, 1967).
The following discussion on the hydrogeology of Grenada County is based
on studies by Newcome and Bettandorff (1973).
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The formations exposed in this area range in age from Upper Cretaceous
to Holocene and crop out in nearly north-south bands. The general dip direc-
tion of these formations, with the exception of flat lying surface deposits,
is westward toward the Mississippi embayment which is the regional controll-
ing structure.
All of the rocks in the area are sedimentary in origin and consist
primarily of clay, chalk, loess, and gravel. Wide lowlands were formed by
the eroding of thick clay or chalk beds. Where sandy units crop out, they
are generally deeply dissected and constitute both in-take and discharge
areas for the ground water reservoir.
The Tertiary aquifers are the main fresh water supply for most of the
wells in Grenada County.
The Tertiary aquifers present in Grenada County include in ascending
order the Lower Wilcox, Minor Wilcox, Meridian Upper Wilcox, Winona Sand,
and the Sparta Sand (See Table 1) (Newcome and Bettandorff).
The uppermost aquifer in the Tie Plant area based on geohydrologic
sections by C. A. Spiers (1977) is the Winona-Tallahatta which is part of
the Claiborne Group of Eocene Age.
The basal unit of the Claiborne Group is the Tallahatta formation which
includes, in ascending order, the Meridian Sand, Basic City Shale, and
Nashoba Sand Members. (Spiers, 1977)
The Meridian Sand Member is a part of the Tallahatta Formation but it
forms a separate aquifer with the sand beds in the upper part of the Wilcox
Group named trie Meridian Upper Wilcox aquifer (Spiers, 1977). Clay beds
which commonly occur above and below the Meridian Upper Wilcox aquifer
generally restrict vertical movement of water in and out of the aquifer
except in some areas where the clay beds are thin or more permeable and
separation is poor. In these areas the water in the Meridian Upper Wilcox
can be influenced by the water in the Wilcox Group below and can influence
the water in the overlying Tallahatta aquifer (Wasson, 1980). Regionally,
the overlying Zilpha Clay hydraulically separates the Winona Sand aquifer
from the next shallower aquifer, the Sparta Sand. The Winona-Tallahatta
aquifer is recharged principally by precipitation in the outcrop area
(Spiers, 1977).
The regional flow of water in the central and northwestern parts of the
aquifer including Grenada County is down the dip in a westerly and south-
westerly direction toward the Mississippi River alluvial plain (Newcome and
Bettandorff, 1973).
The Winona-Tallahatta aquifer is the source of water for hundreds of
small yield domestic wells and stock wells less than 200 ft deep (Spiers,
1977). Production rates as high as 700 gpm have been reported and the water
quality in the aquifer is reported as generally good with the exception
of high iron concentration and intensity of color. Water for domestic use
is obtained from bored or dug wells and springs (Spiers, 1977).
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Hydrogeology of RCRA Facility Area
The undisturbed soils encountered in this area are the result of depo-
sition of sediments in a former marine environment. The typical marine
soils vary from sands, silts and clays to interbedded deposits of sand,
silt and clay. In some low lying areas near present streams or drainage
features the originally deposited soils may be overlain by geologically
younger water deposited (alluvial) soils.
Alluvial soils are fairly widespread to the far east around the Batupan
Bogue based on the Grenada County Soil Survey. Although the thickness of these
alluvial deposits is not known they are usually relatively thin.
Nine borings were drilled around the surface impoundment (R-l through
R-4 in March, 1982, and R-5 through R-9 in July, 1984). Borings SF-1 through
SF-4 were drilled around the sprayfield in August, 1985.
A 12-inch thick surface layer of topsoil was encountered at boring R-5.
Boring R-l penetrated approximately 2 feet of man-made fill.
Beneath the topsoil layer encountered in R-5 and the fill in R-l and from
the surface in remaining borings, silts and clays were encountered to depths
of 6 to 15.5 feet. These materials are probably loess deposits. Loess
deposits are generally homogeneous, non-stratified, unindurated and consist
predominately of silt with subordinate amounts of very fine sand and clay.
Beneath the loess deposits, very fine to coarse sands with traces of silt
and clay were encountered to the boring termination depths of approximately
30 to 33 feet. These soils probably belong to the Nashoba Sand Member of the
Claiborne Group.
Boring R-6 encountered a fine to medium sand layer containing silt and
clay at 15.5 to 20.5 ft underlain by a clay and silt lense with traces of
fine sand to 20.5 to 25.5 feet.
The occurrence, location and movement of ground water at the site is
controlled by the interaction of several factors including: recharge areas,
hydrologic characteristics of the geologic units, hydraulic gradients, man-
made influences, and the proximity of discharge areas such as creeks and
the Batupan Bogue. The regional flow direction of the ground water in the
Winona-Tallahatta Aquifer is to the west and southwest. However, ground
water flow in the RCRA facility area, based on available data, is generally
north-northeasterly toward the Batupan Bogue. It should be noted that the
available data indicated relatively flat gradients and very small ground
water elevation differences between wells. Also, the ground water flow
directions could be affected by local influences such as large scale pumping
operations (City of Grenada) and discharge areas (Batupan Bogue).
Based on the consultant's understanding of the hydrogeology of the area,
the Batupan Bogue is a local discharge drainage feature. It is Law Engineer-
ing's opinion that ground water from the RCRA facility area flows toward the
Batupan Bogue which eventually discharges into the Yalobusha River. It is
the opinion of the Task Force that there is not enough data to support this.
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The Winona-Tallahatta aquifer in which the monitoring wells are screened,
is hydraulically separated from the next shallower aquifer by clay, but could
be locally influenced by the next deeper aquifer, the Meridian-Upper Wilcox.
The actual depth of the uppermost aquifer at the site is unknown.
Field permeability tests were performed in all nine wells. The perme-
ability tests were performed using a SE 1000 Hydrologic Monitor with an
in-situ pressure transducer and a slug. Permeability calculations ranged
from 6 x 10"3 to 1 x 10~2 cm/sec based on data recorded during the field
testing.
Ground Water Flow Directions and Rates
Ground water gradients at the site are controlled by the topography,
lithology, elevation of recharge and discharge areas, and possibly nearby
pumping. Ground water elevations were determined by measuring the top of
well casing elevation with a survey instrument, measuring the water level
in the boring well and computing the elevation of the ground water at the
time of measurement. Directions of ground water flow were determined
between wells by comparing the ground water elevation at those locations.
Ground water elevation will fluctuate with seasonal and rainfall variations
and with changes in the water level in adjacent drainage features.
Hydraulic gradients were determined by the facility by dividing the
difference in ground water elevation at two locations by the horizontal
distance between the two locations. Computed hydraulic gradients range from
0.00038 to 0.0022, the steeper gradients occurring generally to the south of
the surface impoundment.
In addition to hydraulic gradients (i), the rates of ground water move-
ment (v) are a function of permeability (k) and effective porosity (n), as
indicated by the equation v = ki/n. The effective porosity can be expected
(based on Fetter, 1981) to range from about 0.24 for the fine sands to about
0.27 for the coarse sands. Based on typical values of hydraulic gradient,
permeability and porosity in the site area, ground water movement in the fine
to coarse sands can be expected to be on the order of a few tenths of a foot
per day and 40 to 60 feet per year.
Adequacy of Hydrogeologic Characterization
The major sources of hydrogeologic information pertaining to the Koppers
Tie Plant facility are the facility RCRA Part B and the facility ground water
monitoring reports, (both of which contain essentially the same information),
and monitoring well logs for the surface impoundment and sprayfield. Col-
lectively, these sources address the hydrogeology in a general manner and do
not present much in the way of site-specific data on the physical properties
of the aquifers and associated confining units (i.e. vertical and horizontal
hydraulic properties, detailed lithology and stratigraphy). It is the con-
sensus opinion of the Task Force that Koppers has not fully characterized the
hydrogeology of the site, and that the following steps should be taken by
the facility to provide the necessary data to resolve the hydrogeologic issues:
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1. Conduct additional borings for defining the vertical and lateral
extent of confining clay(s); is this unit continuous across the site
and can it be considered a true confining unit; what is the thick-
ness of the unit? Conduct sieve analyses on all lithologic units
encountered during coring; determine porosity of cores;
2. Prepare a stratigraphic section, fence diagram, etc. of the geology
underlying the surface impoundment and sprayfield;
3. Define the various aquifers underlying the site; conduct pumping
tests to determine if interconnection exists between the aquifers;
4. Install a series of nested piezometers throughout the thickness of
the uppermost aquifer to adequately determine the potentiometric
surface at the surface impoundment and sprayfield and to define
the presence and magnitude of vertical gradients;
5. Survey all wells relative to mean sea level (MSL).
The following information should be submitted to resolve the above
issues:
potentiometric water level data and maps
- water quality analyses
map showing all SMU units
most recent report(s) on the sprayfield - include water quality,
geologic logs, etc.
- recent pumping data for production wells on-site
- revision of Part B for the sprayfield.
GROUND WATER MONITORING PROGRAM DURING INTERIM STATUS
Ground water monitoring at the Koppers Tie Plant facility has been con-
ducted under State interim status regulations. The following is an evaluation
of the monitoring program between November 1981, when the ground water moni-
toring provisions of the RCRA regulations became effective, and May 1986 when
the Task Force investigation was conducted.
Regulatory Requirements
Ground water monitoring at this site is now regulated by the Mississippi
Hazardous Waste Management Regulations (MHWMR), which are the State equivalent
of 40 CFR Part 265, Subpart F, which were to be implemented by November 19,
1981.
The State of Mississippi received RCRA Phase I interim authorization in
January 1981. At that time, the State regulations became enforceable in lieu
of the Federal regulations. The State interim status ground water monitoring'
requirements are found in MHWMR 265.90 - 265.94 Subpart F.
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MHWMR Part 265 Subpart F
RCRA ground water monitoring at the site was regulated by the Mississippi
equivalent regulations to 40 CFR Part 265, Subpart F. Table 2 outlines the
parameters to be sampled and analyzed. All the parameters are to be monitored
quarterly for one year to establish background concentrations for each para-
meter. During this period, four replicate measurements are to be obtained for
each parameter in Category 3 for each sampling event.
After the first year, Category 3 parameters are to be monitored semi-
annually, while Category 2 parameters are to be monitored annually.
Compliance History
The compliance history for the Koppers Tie Plant regarding ground water
monitoring has been a long one. The following is a chronological summary of
that history.
2-82: Four wells (R-l, R-2, R-3, R-4) are installed as the RCRA
monitoring system around the surface impoundment. Quarterly
to sampling began that same month. Information pertaining to
this system was included as part of the January 1984 prelimi-
10-83: nary Part B application. The first four quarters of data
(March, June, September, December) did not contain all of the
required 265.93(b)(l)(2) (3) parameters. Only pH, TOG, COD,
phenols, PCP, specific conductance, arsenic, chromium, hexava-
lent chromium and copper were analyzed for. The semi-annual
results (June, October 1983) were for the 265.93(b) (2) (3)
parameters. A student's t-test for the 1982-1983 data indicat-
ed no significant differences.
7-83: Part B call-in
1-84: Part B received
3-84: Both MS DNR and EPA note during their review of the Part B
that the application is incomplete. Points specific to the
ground water monitoring plan included: lack of detailed well
location; lack of well construction details; drilling methods
and well development not included; elevations for well screens
not included, R-l (background well) unsuitable; lack of 265.93
(b)(l)(2) (3) parameters; invalid student's t-test, etc. The
first NOD for the Part B was issued March 1984.
5-8-84: A facility inspection by MS DNR in April 1984 noted areas of
non-compliance with the 265 Subpart F regulations. These
deficiencies are then conveyed to the facility on this date.
5-19-84: Commission Order No. 705-84 was issued to the facility to
correct the Part B deficiencies, including those pertaining
to ground water monitoring. Revisions were due by 6-15-84.
6-84: A revised student's t-test of the 1982-83 data was submitted
by Koppers that indicated some significant differences.
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7-84: MS DNR reminds the facility that information pertaining to the
surface impoundment well system had not been submitted. Kop—
pers was directed to submit a revised Part B by 9-12-84 and a
proposed plan for a new monitoring system by 7-15-84.
7-16-84: Ground water assessment plan submitted for five new wells at
the surface impoundment.
7-17-84: Wells R-5, R-6, R-7, R-8, R-9 installed. MS DNR directs both
the old and new wells to be sampled four times on a bimonthly
basis.
7-24-84: A written complaint was served against the facility on the
grounds that they failed to notify the Executive Director in
a timely manner of its findings indicating ground water con-
tamination or submit a ground water assessment plan in a
timely manner.
8-8-84: Commission Order No. 746-84 was issued against the facility for
the above-mentioned violations and a penalty of $4000.00 was
assessed.
8-13-84: Commission Order No. 705-84 was amended. Koppers was ordered
to submit a complete Part B including information pertaining
to ground water monitoring by 9-12-84 and to implement the
ground water assessment plan.
8-84: Law Engineering retained to work on the Part B for Koppers, in
particular to address the hydrogeological conditions at the
site.
9-25-84: Written complaint served against the facility based on the
violation of Commission Order No. 705-84 -ie- the facility had
failed to submit a complete Part B on the date required.
10-10-84: Commission Order No. 772-84 issued and a penalty of $10,000.00
assessed for failure to submit a complete Part B by the time
specified. A complete Part B was directed to be issued by
January 31, 1985.
11-84 Law Engineering submits monthly reports on the status of the
to Part B, particularly those elements pertaining to ground water.
12-84: Little work was done at the site during this time due to delays
in procurring a topographic map of the site. Lab analyses from
the bimonthly sampling were not available due to lab delays.
1-17-85 A revised Part B was submitted in two parts. Section E on
to ground water monitoring gives an overview of the geology/
2-27-85: hydrology of the site and includes historical water quality
data.
3-6-85: MSDNR directed the facility to sample the new well system for
Appendix VIII parameters and submit the results by 6-7-85.
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3-14-85 Koppers submitted the 3004(u) information regarding potential
releases from Solid Waste Management Units (SMU's). The reply
was not complete and more information was to be delivered in the
"very near future".
5-7-85: MSDNR issued the 2nd NOD regarding the incomplete Part B and
orders it to be submitted within 30 days.
5-8-85 MSDNR issued a letter detailing interim status and ground water
monitoring violations noted during a 4-16-85 inspection. The
company responds by letter 5-24-85 that these problems were
being corrected.
7-85: Law Engineering submitted a status report and states that Koppers
intends to demonstrate justification for ACL's and that the
Exposure Information Report is in progress.
7-9-85: Appendix VIII analyses submitted. A preliminary review of the
data shows that upgradient well R-5 often has the highest con-
centrations of detected parameters.
8-8-85: Appendix VII analyses submitted and again shows that upgradient
well R-5 often has the highest concentrations of detected para-
meters.
8-85: A proposed monitoring system for the sprayfield was submitted
for review. Approved by MSDNR 8-13-85. Four wells (SF-1,
SF-2, SF-3, SF-4) installed end of August.
9-19-85: Commission Order No. 913-85 issued ordering the facility to
submit additional information for the Part B including spray-
field irrigation information, a ground water assessment report,
a corrective action plan or ACL proposal and updated cost
estimates. All of this was due on or before 11-8-85.
9-27-85: Law Engineering submitted a ground water assessment plan for
review which contained much of the information submitted in
previous Part B's.
10-22-85: A 3rd NOD was issued to Koppers pertaining to an incomplete
Part B regarding ground water. This information was to be
addressed by 11-8-85.
11-8-85: Koppers submits a revised Part A to EPA Region IV to include
the sprayfield as a protective filing. The facility contends
that the sprayfield is not a RCRA regulated unit.
11-25-85: Commission Order No. 951-85 issued regarding the storage of
hazardous waste in excess of their interim status design
capacity noted from a 10-29-85 MSDNR inspection. This vio-
lation was to be corrected by 12-15-85.
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12-5-85: Law Engineering submitted a Revised Exposure Information Report
to MSDNR that updates the 8-7-85 version submitted to EPA
Region IV.
2-28-86: The 1985 Annual RCRA Ground Water Monitoring Report for the
sprayfield is submitted to MSDNR for review to satisfy item #2
of the 913-85 order requiring sampling around the sprayfield.
3-12-86: A recodified version of the Part B was submitted to EPA Region
IV for review. Region IV contracted the review out and the
final was due 6-30-86. MSDNR reviewed the Part B and issued
an order (August 1986) regarding the deficiencies.
During the inspection, the Task Force learned that there was some ground
water monitoring data that had not been submitted to EPA or MSDNR. An inten-
sive hydrogeologic investigation and ACL study was to be conducted during the
summer of 1986. Results were to be sent to EPA and MSDNR for review.
Monitoring Well Data
Surface Impoundment
The interim status monitoring program was instituted at this site in
1982 (See Table 3). Four ground water monitoring wells (R-l through R-4) were
installed in March, 1982. R-l served as the upgradient well (See Figure 2).
Analyses were performed on samples collected from the wells in 1982 and 1983
(See Table 4).
It was determined by the Mississippi Bureau of Pollution Control (MBPC)
that the interim status monitoring program being conducted by Koppers was
inadequate to meet regulatory requirements. In mid-1984, the MBPC and Koppers
agreed to an assessment program that would be implemented at an accelerated
schedule. The purposes of the assessment program were to meet some of the
deficiencies of the original interim status program and to perform a more
comprehensive assessment of the ground water closer to the RCRA facility (sur-
face impoundment). Five new monitoring wells (R-5 through R-9) were installed
in July, 1984 with R-5 as the upgradient well (See Figure 2). A program of
bi-monthly sampling and analysis was started with the last of the four bi-monthly
sampling and analysis episodes completed in February, 1985. Appendix VIII
sampling was completed in July 1985.
The wells were installed by inserting a length of PVC pipe (schedule
40 with flush threaded joints) into the borehole. The bottom 10 ft section
of the well was a manufactured well screen with 0.01 inch wide openings.
Coarse sand backfill was placed around the outside of the pipe to at least
1 ft above the top of the well screen. The coarse sand backfill was used
to stabilize the formation and to help yield a less turbid water. The coarse
sand used was obtained from a local supply company.
In monitoring wells R-l through R-4, auger cuttings were placed on top
of the sand pack and a bentonite seal was placed on top of the auger cuttings.
In wells R-5 through R-9 a bentonite seal (minimum 1 ft thick) was installed
on top of the coarse sand backfill to seal the monitoring well at the desired
level. The borehole was then grouted with concrete to the ground surface.
A steel protective cover was placed over the wells for security.
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After the grout had set, the wells were purged by bailing water from the
well. This procedure was followed to develop the wells and to determine if
they were functioning properly.
Surveying of the well locations and elevations was performed by McRee,
Dardaman, Jones and LaCoste, Ltd., of Grenada. The elevations were referenced
to the USC & GS Datum.
The location of the screened interval was selected to monitor the ground
water in the uppermost water-bearing zone. All nine wells were screened in
a sand layer underlying a near surface layer of clay and silt with the excep-
tion of R-6 where about half of the screened interval is in clay and silt.
Copies of the monitoring wells logs have been included in Appendix B.
Sprayfield
Ground water contours were available for the southern end of the Koppers
property near the existing impoundments, and this data was used to place the
four monitoring well locations with respect to the sprayfield. Drilling
operations for the four wells were completed in late August 1985 (See Table
3). All monitoring wells were drilled using hollow stem augers with split-
spoon soil samples collected every 2.5 feet to the termination depth. Wells
were constructed of 2-inch inside diameter flush threaded PVC riser and 10 feet
of manufactured PVC screen having a slot size of 0.010 inches. The screened
interval was placed such that approximately 8 feet were below the encountered
water table with 2 feet above to allow for seasonal fluctuations.
Coarse sand was placed in the annulus around the screen to act as a for-
mation stabilizer; this sand extends approximately 2 feet above the screened
interval. A bentonite seal was placed above the coarse sand. The remaining
annulus was sealed with a cement/bentonite grout. At the ground surface, a
protective steel casing with locking cap was installed around the PVC casing.
To prevent surface water ponding and infiltration near the well casing, a
sloping cement collar was constructed around the protective casing. The
soils beneath the sprayfield, as determined by the ground water monitoring
well logs are generally characterized by: clay and silty clay for the first
11 to 18.5 feet; sand and silt are present with traces of clay (in one instance
a gray silty clay lens at 15- 15.5 feet and 19.5 to 20 feet) from 11 to 21
feet; then two foot layers of fine sand with some silt, alternating with one
to two foot layers of silty clay. The four wells all terminated in sand at
depths ranging from 26.1 to 30.3 feet below the surface. Copies of the
monitoring well logs have been included in Appendix B.
After reviewing the monitoring well data for the surface impoundment
and sprayfield wells, several deficiencies were noted. The following are
general comments on information that should be submitted for review:
1. What method was used to drill the surface impoundment wells? Was any
type of drilling fluid used in any of the wells?
2. What are the elevations of all the wells relative to MSL (mean
sea level)?
3. Why was PVC casing chosen over teflon-coated or stainless steel
considering that organics are of primary concern at this facility?
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4. What are the dimensions of the sand pack? Were any sieve analyses
run on the sand pack? Could an inadequate sand pack explain the
high turbidity? (If the facility cannot demonstrate that the filter
pack was designed for the formation, then the wells yielding turbid
samples are not suitable for monitoring purposes).
5. Is the annular space adequately sealed? (Wells in which drill
cuttings were backfilled and used as the annular seal are not
acceptable as RCRA monitoring wells.)
6. How long were the wells developed? Were the wells developed until
pH, temperature and specific conductance stabilized?
7. Are any of the wells capped at the bottom?
8. There is a possibility of contamination by placing cuttings from
the well on top of the sand pack. What measures were taken to
prevent this?
There is not enough information to determine if the monitoring wells are
adequately located at the surface impoundment and the sprayfield. It is
evident that upgradient well R-5 appears to be affected by the facility and
a new well should be required. Also, an unsaturated zone monitoring system
is required at the sprayfield. Regulation 40 CFR 265.278 - Unsaturated Zone
Monitoring requires owners/operators to implement an unsaturated zone moni-
toring system which will detect migration of hazardous wastes under the active
portion of a land treatment facility, and provide background information on
untreated soils. This type of monitoring will show the adequacy of the land
treatment process and provide an early detection of contaminant migration.
Little site-specific hydrogeologic work is available. Additional strati-
graphic and hydrogeologic information is needed to assess whether the screened
intervals are appropriate. Hydraulic gradients and possible hydraulic inter-
connection between the saturated zones underlying the site are also needed to
properly assess the present well design. Also, the possibility of mounding
at the surface impoundment indicates that additional wells should be placed
on the north side of the impoundment.
Ground Water Sampling - Detection/Assessment
Surface Impoundment
The facility began their quarterly RCRA ground water monitoring program
in March 1982 for wells R-l, R-2, R-3 and R-4. Quarterly analyses were taken
in March, June, September and December 1982. The only parameters sampled for
during this time were pH, TOC, COD (total), phenols, PCP, specific conductivi-
ty, arsenic, chromium (total and hexavalent) and copper. Semi-annual sampling
and the student's t-test were performed June 1983. No statistically signifi-
cant differences were noted.
In January 1984, Koppers forwarded the October 1983 semi-annual sample
analyses to MSDNR for review. The report contained a revised version of the
June 1983 data to include some additional parameters. The list now included
chloride, iron, manganese, sodium, phenol, sulfate, pH, specific conductance,
TOC, TOH and PCP. No student's t-test results were included.
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In March 1984, EPA Region IV Atlanta sent MSDNR a copy of EPA's comments
on the Koppers Part B application. Several deficiencies were noted pertaining
to ground water monitoring:
- incomplete summary of ground water monitoring data.
- student's t—test results were invalid because incorrect water
quality data was used.
- hydrogeologic characteristics of the uppermost aquifer were not
included for review.
- incomplete topographic map.
- inadequate description of any contaminant plume.
inadequate report describing the 264 Subpart F ground water moni-
toring system.
- downgradient wells too far from the point-of-compliance.
June 1984, Koppers submitted a revised student's t-test of the previously
collected sampling data. There was a statistically significant change for
well R-2 in pH and conductivity. No other changes were noted.
It was determined by the Mississippi Bureau of Pollution Control (MBPC-
MSDNR) that the interim status monitoring program being conducted by Koppers
was inadequate to meet regulatory requirements. Commission Order No. 705-84
was issued to Koppers to correct the deficiencies (May 1984). A written com-
plaint was served on Koppers for failing to notify the proper authorities in
a timely manner of its findings indicating ground water contamination (July
1984).
In July 1984, the MBPC and Koppers agreed to an assessment program that
would be implemented on an accelerated schedule. The purposes of the assess-
ment program were to meet some of the deficiencies of the original interim
status program and to perform a more comprehensive assessment of the ground
water closer to the surface impoundment.
Five new monitoring wells (R-5 through R-9) were installed in July 1984,
and a program of bi-monthly sampling and analysis was started. Law Engineering
Testing Company was retained to act as hydrologic consultants for the Koppers
facility. Their job was to assess the hydrogeologic conditions at the site,
prepare a revised Part B, and revise the Part A to include a new waste storage
building.
The last of the bi-monthly sampling and analysis episodes was to be com-
pleted in February 1985. Sampling for wells R-l through R-4 included indicator
parameters, ground water quality parameters, drinking water standards and
priority pollutants. In August 1984, Wells R-6 through R-9 were sampled for
the indicator parameters, primary drinking water standards, ground water
quality parameters, select organics, pesticides and herbicides. The new up-
gradient well, R-5, was not sampled due to mechanical interference of the
bailer.
In October 1984, wells R-6 through R-9 were sampled for all parameters
mentioned above except select organics, pesticides and herbicides. Acid
extractable organics and base neutral extractable organics were added. Again,
R-5 was not sampled due to mechanical interference of the bailer.
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In December 1984 and February 1985, wells R-l through R-9 were sampled,
thus completing the accelerated bi-monthly program. The samples were ana-
lyzed for the indicator parameters, primary drinking water standards, ground
water quality parameters, PAH's and chlorophenols. The statistical analysis
performed indicated significant changes in R-8. No other changes were noted.
The significant change triggered "compliance" monitoring - a term used
by the facility. Wells R-5 through R-9 were the "compliance" monitoring
system and were to be sampled once each quarter using the same procedures
used for interim status and the assessment program. Parameters to be sampled
for were pH, conductivity, TOG, TOX, PCP, napthalene, acenaphthene, chloride,
sodium, sulfate and phenol.
In April 1985 samples were collected from wells R-5 through R-9 for
Appendix VIII analyses. Results were submitted to MSDNR for review July
1985.
In September 1985, Law Engineering prepared for Koppers the submittal
"Report on Ground Water Assessment" which was submitted to MSDNR and out-
lined the procedures used during the assessment and presented the results.
The report was basically Section E of the Part B submitted in February 1985
with some field permeability test results added.
In December 1985, Law Engineering prepared for Koppers an "Exposure
Information Report" to address potential exposure to humans resulting from
the operation of the surface impoundment. The report concluded that a
potential ground water pathway could exist for shallow private wells that
might be located north-northeast of the facility and between Batupan Bogue
and the facility. There was no evidence that private wells in the area
had been contaminated.
The report also concluded that a ground water pathway for public,
industrial and institutional wells did not likely exist because those wells
draw from deep water-bearing units that are hydrogeologically isolated from
the uppermost aquifer immediately below the surface impoundment.
It was stated that normal operating procedures would reduce the risk
of exposure through surface water and soil pathways and that security,
inspection and training programs existed to correct potential releases. The
report concluded that current data did not suggest a plume of contamination.
At the time of the Task Force inspection, no further information per-
taining to the surface impoundment was available for review. It is the con-
clusion of the Task Force that a contaminant plume does exist at the surface
impoundment and that Koppers has not defined the extent of the plume nor the
rate of travel as required by 265.93 (d)(4), nor does the Part B contain the
information required by 270.14 (c).
A ground water monitoring system of four wells was installed around the
sprayfield in August. Two rounds of samples were taken in September and
three rounds in October. The results were evaluated using the student's
t-test and statistically significant differences were noted for pH in wells
SF-2, SF-3, and SF-4; conductivity in SF-2; and TOX in SF-2 and SF-3. This
was compiled into a "1985 Annual RCRA Ground Water Monitoring Summary, Grenada
Sprayfield" in February 1986.
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At the time of the Task Force inspection, no further information per-
taining to ground water quality at the sprayfield was available for review.
Historical water quality indicates the hazardous constituents (trichloro-
phenols) are contaminating the ground water and that an assessment program is
needed for this unit. The Task Force also recommends that the following
additional work should be completed as part of the assessment at the surface
impoundment and the sprayfield:
1. A series of closely spaced borings should be placed around the
surface impoundment. The cores should be analyzed for free oil
and dissolved constituents. There is the possibility that a dense
immiscible creosote phase is present and work should be done to
determine if this phase exists.
2. Additional wells are needed downgradient of the surface impoundment
and the sprayfield to define the lateral extent of the plume. In
addition, some wells should be screened in the uppermost aquifer
so that the vertical extent of the plume can be determined.
Koppers Sampling Collection and Handling Procedures
During the inspection, samples were collected from eight wells for ana-
lysis by the EPA contractor laboratory. After the Task Force sampling, the
facility took samples for their second quarter sampling event. Steve Hall
of the Task Force observed the sample collection and handling procedures.
Koppers personnel closely followed the protocol established in the "Procedures
for Ground Water Sampling", submitted as Appendix B of the Part B, January
1985, revised January 1986. A copy is included as Appendix C in this report.
The following is a summary of the sampling protocol followed by Koppers
personnel:
a. determine when sampling is to be performed and what analyses are
required,
b. bottle preparation - use new, pre-cleaned bottles for samples,
c. bailers to be used are dedicated for each well; bailer is stainless
steel with an open top and a new disposable cork for the bottom;
new cotton string is used as lowering cord,
d. after use, bailers are thoroughly cleaned and stored for next sam-
pling program,
e. before sampling, take water levels from all wells; mark last few
feet of measuring tape with water - soluble ink; lower tape into
well; read tape to nearest hundredth; calculate water level.
f. determine purge volumns for three well-casing volumes - purge water
can be disposed of on the ground, but contaminated water is disposed
of in the plant wastewater system.
g. sample the well - place plastic around the wells to prevent sampling
equipment from coming into contact with the ground; tie cotton cord
to bailer and place cork securely in end of bailer; put on disposable
gloves; lower bailer into well; remove three well volumes; fill con-
tainers; if VOA's are taken, aerate the sample as little as possible;
check for air bubbles.
h. take samples to field laboratory where pH and specific conductance
measurements are made - instruments are to be calibrated before use
each day and at periodic intervals throughout the day.
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i. samples are to be capped, placed on ice, put into cooler that is
then sealed with evidence tape.
j. at the end of each day of sampling, coolers are shipped via over-
night air express to the Koppers Environmental Analysis Laboratory,
440 College Park Drive, Monroeville, PA 15146, or to be appropriate
contract laboratory.
k. a field blank will be collected during sampling for QA/QC purposes.
An example of the field data sheets, chain-of-custody, etc. is also in-
cluded in Appendix C of this report.
Some comments on the sampling protocol used by Koppers are:
1. Using a water soluble ink pen to mark the water level measuring tape
may introduce some organics into the well.
2. Cleaning the bailers with acetone and hexane may introduce some
organics into the wells if the bailers are not totally allowed to
dry.
Except for the use of open top bailers (closed top bailers should be
used), procedures utilized by Koppers for RCRA ground water monitoring appear
adequate for sampling purposes. However, the RCRA ground water sampling and
analysis plan (SAP) is incomplete.
The SAP, as written and compiled, does not fully meet the requirements
of a sampling and analysis plan as described at 40 CFR Part 265.92(a). These
requirements state that the SAP must contain procedures and techniques for:
1. sample collection
2. sample preservation and shipment
3. analytical procedures; and
4. chain-of-custody control
The SAP covers items 1,2 and 4 adequately but does not include a reference
to a specific analytical procedure for each parameter or constituent which is
analyzed or measured.
In addition, there are no specific procedures referenced for the 40 CFR
Part 265.92 (b)(l)(2) and (3) parameters. These procedures must be included
in the SAP.
Alternate Concentration Limits (ACL's)
Alternate concentration limit evaluations are presently being conducted
to determine the concentrations that could exist at the point of compliance
and still preclude substantial present or potential hazards to human health
and the environment at the point of exposure (point of use). Koppers has begun
their ACL evaluation based on procedures outlined in the US-EPA memorandum
by John H. Skinner pertaining to ACL Guidance.
The point-of-compliance has been designated the exterior toe of the
slope of the surface impoundment. The point of exposure is the Koppers pro-
perty line, about 300 feet downgradient from the impoundment. Existing
wells R-2, R-3 and R-4 are to provide preliminary downgradient monitoring.
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The ACL demonstration is to be based on attenuation mechanism analyses.
Other analyses will also consider decay, retardation, advection and disper-
sion. The key constituents may include napthalene, fluoranthene, benz(a)
anthracene, benz(c) fluoranthene, benz(a) pyrene and dibenze (a, h) anthra-
cene.
The thickness of the contaminated zone at the point-of-compliance is
taken as the 20 feet immediately beneath the surface impoundment.
Much work needs to be done to show the merits of ACL's for this site.
The Task Force recommends that at ji minimum future work should determine:
- continuity of the silt/clay layer underlying the site
thickness of the underlying primary sand unit
- potentiometric surface of the primary sand unit - should include
seasonal variations
- discharge area of the primary sand unit
- hydraulic characteristics of the underlying geologic units - should
include silts, clays, sands, etc.
- effects of retardation factors, degradation half-lifes, decay and
advection of the key constituents
- effects of transverse and longitudinal dispersion
exposure assessment regarding human health, and the environment -
should include possible exposure pathways
- additional wells at the point-of-compliance and downgradient of
the surface impoundment
At the time of the inspection, the Task Force was informed that the ACL
demonstration was underway and a summary of the findings would be available
at the end of summer (August - September 1986). It should be noted that in-
formation contained in the Part B was not adequate to support the ACL.
TASK FORCE SAMPLE COLLECTION AND HANDLING PROCEDURES
This section describes the well evacuation and ground water sampling
procedures followed by Task Force personnel during the May 1986 site inspec-
tion. Samples were collected by an EPA contractor (GCA) to determine if the
ground water contains hazardous waste constituents or other indicators of
contamination. Koppers declined to split samples with the Task Force, but
did take samples for their 2nd quarter sampling period. The Task Force
observed their procedures for sampling.
Water samples were collected from wells R-l, R-4, R-5, R-7 and R-9 at
the surface impoundment; and from wells SF-1, SF-2 and SF-4 at the sprayfield
(See Table 5). The selection of these eight wells for sampling was based on
well locations to provide areal coverage both up and downgradient at the sur-
face impoundment and the sprayfield.
EPA Region IV requested and received split samples for the wells R-5, R-9,
SF-1 and SF-2. MSDNR and Koppers declined to split samples for independent
analysis. A field blank was poured the first two days of sampling by the
EPA contractor at locations specified by the Task Force. Water used to pour
the blanks was HPLC water. One duplicate was taken from R-5 for quality
assessment/quality control (QA/QC) purposes. A trip blank was poured prior
to the trip and an equipment blank was poured after all samples were taken
on the last day for QA/QC purposes.
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All samples bottles and preservatives were provided by an EPA contractor
(1-Chem). Samples were collected by the EPA sampling contractor using the
following protocol:
a) Depth to ground water determined by using an electric water - level
recorder. Total well depth also measured.
b) Height and volume of the water column then calculated.
c) Calculated three water column volumes.
d) Purged the well three well volumes using a pre-cleaned teflon bailer.
e) Prior to sampling, the EPA sampling contractor monitored the open
well for chemical vapors using an HNU meter, and monitored for
radiation using a Geiger counter.
f) Collected a sample aliquot and made field measurements (water tempera-
ture, specific conductance and pH) a minimum of three times.
g) EPA contractor filled VGA vials, then filled the remaining sample con-
tainers in the order shown on Table 6.
h) EPA contractor placed samples on ice in an insulated container imme-
diately after filling the bottles.
The first step in the ground water well sampling procedure is to measure
the depth from a reference point at the wellhead. At Koppers, that reference
is a known elevation at a mark near the top of the well casing. The EPA sam-
pling contractor used an electric water-level recorder to measure the depth
to water. The recorder was rinsed with isopropanol alcohol and wiped dry with
a Kim® wipe. The recorder used for this exercise was clean and kept protected
from potential outside contamination. Water-level measurements were made to
within 0.01 foot.
The volume of water to be purged was then calculated. The column volume
of a well is the volume of standing water in the well and is calculated using
the depth-to-water measurement, total well depth (determined in the field
with well sounder) and casing radius. All calculations were done correctly
by the EPA contractor.
For purposes of the Task Force, the column volume is multiplied by three
to compute the purge volume. The volume is measured into a graduated bucket
as it is taken from the well. In all cases, standard field measurements
(temperature, pH, specific conductance) were taken to determine when sampling
should begin.
The wells were purged by the EPA sampling contractor using a pre-cleaned,
double check-valve Teflon bailer which was lowered into the well with teflon-
covered stainless steel cable.
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After purging, the EPA contractor began the sampling procedure. HNU
readings ranged from 0.1 to 0.5 ppm at the surface impoundment wells and 0.1
to 0.2 ppm at the sprayfield wells. Geiger counter readings ranged from 0.01
to 0.02 millirems/hr at the surface impoundment wells and at the sprayfield
wells. Parameter by parameter, the EPA contractor filled the sample containers
in the order listed in Table 6.
After sampling was completed, the EPA contractor took the samples to a
staging area where a turbidity measurement was taken. Samples for metals, TOC,
phenols, cyanide, nitrate and ammonia were preserved.
At the end of the day, samples were packaged and shipped to the EPA Con-
tract Laboratory. The EPA Region IV samples were released to EPA Region IV
Environmental Services Division personnel for transport. A "Receipt for Sam-
ples" was given to Koppers for the samples taken off-site by the Task Force.
All samples were shipped according to applicable Department of Transportation
regulations (40 CFR Part 171-177). All water samples from monitoring wells
were considered "environmental" for shipping purposes.
LABORATORY EVALUATION
To be completed at a later date - will be issued as an addendum.
MONITORING DATA ANALYSIS
Acceptability and Validity of Data
The samples collected during this evaluation were analyzed by Compu Chem
Laboratories, Research Triangle Park, North Carolina, and Centec Laboratories,
Salem, Virginia. Compu Chem performed the organic analyses and Centec performed
the inorganic analyses. The results were compiled and tabulated by Life Systems,
Inc. and forwarded to the Task Force for evaluation. The OSWER functional
guidelines for evaluating contract laboratory program data, as well as the
Region IV EPA protocols were used to assess the validity of the data. All data
was considered valid except for the results of analyses for antimony and most
of the arsenic. Some data was qualified, as indicated in the data summary
tables, as estimated in concentrations or as presumptive evidence of material.
Pesticide, herbicide and dioxin data was considered to be unreliable.
There was generally a good agreement between the contract labs and the
Region IV lab, except for the arsenic analyses and one aluminum analysis, on
the four samples split with Region IV. For station number R-9, the contractor
result was 25,000 ug/1 for aluminum, while the Region IV lab reported 14-000
ug/1. This may appear to be a significant difference, but might be expected if
the sample contained substantial amounts of particulate matter. The aluminum
results for the remaining split samples were comparable. For station number
R-5, the average arsenic result reported by the contract lab was 23 ug/1, while
Region IV reported 90 ug/1. Arsenic results for the remaining three stations
agreed well. All other organic and inorganic indicator parameters were in close
agreement for the split samples.
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Discussion of Results
A review of the data indicates ground water degradation has occurred at
upgradient well R-5. The degradation in this area was metals, extractable and
purgeable organics. Table 7 summarizes the contractor data from the samples
collected from the RCRA monitoring wells at the surface impoundment and the
sprayfield. Table 8 is a summary of analyses performed by the Region IV BSD
laboratory. The contractor data is discussed in the following sections.
Surface Impoundment
Inorganic Elements/Compounds
Twenty inorganic elements and compounds were detected in samples collected
from monitoring wells in this area. Upgradient well R-5 had the highest con-
centrations for seventeen of the twenty elements/compounds. The National
Interim Primary Drinking Water Standard (NIPDWS) of 50 ug/1 for chromium was
exceeded in R-7 (160 ug/1), R-4 (190 ug/1), R-5 (530 ug/1), R-5 duplicate (580
ug/1) and R-l (63 ug/1). The NIPDWS of 50 ug/1 for lead was exceeded in R-4
(estimated 80 ug/1), R-5 and R-5 duplicate (estimated 70 ug/1). The NIPDWS of
10 ug/1 for selenium was exceeded in R-5 (estimated 15 ug/1), R-5 duplicate
(estimated 13 ug/1) and R-l (estimated 18 ug/1). The secondary drinking water
standard of 50 ug/1 for manganese was exceeded in R-7 (estimated 620 ug/1), R-4
(estimated 360 ug/1), R-5 (estimated 2,700 ug/1), R-5 duplicate (estimated
2,600 ug/1), R-l (estimated 130 ug/1) and R-9 (estimated 280 ug/1). The secon-
dary drinking water standard of 0.3 mg/1 for iron was exceeded in R-7 (80
mg/1), R-4 (137 mg/1), R-5 (134 mg/1), R-5 duplicate (146 mg/1), R-l (29 mg/1)
and R-9 (21 mg/1). Aluminum concentrations ranged from 25,000 ug/1 in R-9 to
84,000 ug/1 in R-5 duplicate.
Extractable Organic Compounds
Ten extractable organic compounds were detected in samples collected from
upgradient wells R-5 and R-l. Napthalene was detected in R-5 and R-5 duplicate
at 2,200 and 870 ug/1, respectively. Estimated concentrations of acenaphthene
for R-5 were, (120 ug/1), R-5 duplicate (63 ug/1) and R-l (3.2 ug/1). Estimated
concentrations were also given for fluorene, phenanthrene, 2-methylnapthalene
and dibenzofuran in R-5 and the R-5 duplicate. 12 ug/1 of 1,4 naphthoquinone was
estimated for the R-5 duplicate. Presumptive evidence was found for C3 alkyl-
benzene, benzothiophene, and ethylideneindene in R-5 and the R-5 duplicate. No
other extractable organic compounds were detected in any of the surface impound-
ment wells.
Purgeable Organic Compounds
Purgeable organic compounds were detected only in R-5 and the R-5 dupli-
cate. Benzene was measured at 5.4 ug/1 and estimated at 4.1 ug/1; toluene 6.1
ug/1 and estimated 4.7 ug/1; ethyl benzene 9.0 and 6.8 ug/1; and total xylenes
16 and 6.5 ug/1, respectively. However, according to the QA/QC check, there
was a possibility of false negatives for the semi-volatiles in well R-5.
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Conventional/Indicator Parameters
Consistent with the previously discussed organic data, there is a clear
indication of ground water degradation at R-5. Chloride, ammonia, sulfate, TOG
and TOH were detected at concentrations exceeding those in the other surface
impoundment wells. Phenols were undetected in all wells except R-5 and the R-5
duplicate, which had concentrations of 220 and 210 ug/1, respectively.
Sprayfield
Inorganic elements/compounds
Sixteen inorganic elements and compounds were detected in samples col-
lected from monitoring wells around the sprayfield. Of these sixteen, thir-
teen were found in noticeably higher concentrations in downgradient well SF-2.
The NIPDWS limit of 50 ug/1 for chromium was exceeded in SF-2 (70 ug/1). The
secondary drinking water limit of 50 ug/1 for manganese was exceeded in SF-2
(estimated 250 ug/1) and SF-1 (estimated 150 ug/1). The secondary drinking
water standard of 0.03 mg/1 for iron was exceeded in SF-2 (44 mg/1), SF-4
(6.9 mg/1) and SF-1 (16 mg/1). Aluminum concentrations ranged from 7,200
ug/1 in SF-4 to 15,000 ug/1 in SF-2.
Extractable Organic Compounds
Four unidentified compounds were detected in upgradient well SF-1 with an
estimated concentration of 200 ug/1. No other extractable compounds were
detected in any of the sprayfield wells.
Purgeable Organic Compounds
No purgeable organic compounds were detected in any of the sprayfield
wells.
Conventional/Indicator Parameters
Nitrate-nitrite nitrogen, sulfate and TOH were detected in all of the
sprayfield wells, but concentrations were highest in upgradient well SF-1.
Chloride and TOC concentrations were highest in downgradient well SF-4. No
phenols were detected in any of the sprayfield wells.
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REFERENCES
1. "Revised Draft Protocol for Ground Water Inspections at Hazardous Waste
Treatment, Storage and Disposal Facilities", by the EPA Hazardous Waste
Ground Water Task Force April 1986.
2. 1985 Annual RCRA Ground Water Monitoring Summary, Grenada Sprayfield.
Grenada. MS: prepared by Koppers Co. Inc.. February. 1986.
3. Report of Ground Water Assessment, Grenada, MS: prepared for Koppers
Co. Inc.. by Law Engineering. September- 1985.
4. Proposed RCRA Compliance Ground Water Monitoring Spray Irrigation Field.
Koppers Co. Inc., Grenada, MS: prepared by Koppers Co. Inc., August,
1985.
5. Application for RCRA Part B Permit, Volume II prepared for Koppers Co.
Inc.. by Law Engineering, February, 1985.
6. RCRA Part B Application for the Koppers Co. Inc., Hazardous Waste Manage-
ment Facility, Grenada, MS: submitted by Koppers Co. Inc., January, 1985.
7. Fetter, C. W. Jr.. Applied Hydrogeology. Bell and Howell Company. 1980.
8. Wasson, B.E., Potentiometric Map of the Meridian - Upper Wilcox Aquifer
in Mississippi, Fall, 1979. USGS WRI Report 80-590. 1980.
9. Spiers, C. A., The Winona-Tallahatta Aquifer in Mississippi, USGS WRI
77-125, 1977.
10. Newcome, R. Jr. and J. M. Bettandorff, Water for Industrial Development
in Calhoun, Chickasaw, Choctaw, Grenada, Montgomery, Webster and
Yalobusha Counties, Mississippi, U.S.G.S. and Mississippi Research and
Development Center, 1973.
11. Soil Survey, Grenada County, Mississippi. TJSDA, SCS, April 1967.
-------
-------
\
Approximate
Property
Boundaries
SF-4
-H4-W-
1 I
yf Sprayfield Monitoring Well
RCRA Monitoring Well
Figure 2
RCK Monitoring Wells Location Map
Koppers Tie Plant
Grenada," Mississippi
R-4 R-3
R-8
R-9
Surface
Impoundment
Plant Yard
R-5
\
Treating
Area
-+4-
4-4-
\\ H M
Scale
• • —•
0 200
(ft)
after Law Engineer in
-------
Figure 3
Surface Impoundment Diagram
Koppers Tie Plant
Grenada, Mississippi
- SURFACE IMPOUNDMENT CALCULATIONS
General Shape of Impoundment
.. vrt
lo'
8'
\
•1° \
8'
\- & —\
Net cross section area equals 8' x (83 + 35/2) = 472 sq. ft.
Gross volume = 272' x-472 sq. ft. = 128,384 cu. ft.
Less end wedge of 12,384 cu. ft.
Net volume = 116,000 cu. ft.
867,680 cu. ft.
Sludge Generation
2,500 pounds = 312 gallons at 8 Ibs/gallon
42 cu. ft.
Bottom Area = 35' x 224' = 7,840 sq. ft.
Bottom Storage = 42 cu. ft./yr./7,840 sq. ft.
= 0.063"/yr,
-------
Figure 4
Flow Diagram of the Water Treatment System
" Koppers Tie Plant
Grenada, Mississippi
CREOSOTE TREATING
CYLINDER
CREOSOTE TREATING
CYLINDER
Kopper}
-------
yr^^.. Tie Plan
A\ • . t. J ' -^ ^^^-— '3« /
•\ .
-------
Table 1
Stratigraphic Units and their Water-Bearing Characteristics
Era
Ceoosoio
1 Hesoiol ,
Paleosolc
Sys-
tem,
Quaternary
Tertiary
Cretaceou,.
Series
Holocerw
Pleistocene
Eocene
Paleocene
Upper
Cretaceous
Lower
Cretaceous
Group
Claiborae
Ullcox
Midway
Seloa
Tuscaloosa
Reference:
Newcome, R. Jr., and J.M
Chickasaw, Choctaw,
Stratlgrmphlo unit
Flood-plain deposit*
Loess
Terrace dapoelte and
lover part of
Mississippi River
alluvium
Sparta Sand
Zilpha Clay
Uinona Sand
Tallahatta
Meridian Sand
Member
upper
minor aquifers
lower
Kaheola Formation
Porters Creek Clay
Clayton Formation
Prairie HLuff Chalk
Rlpley Formation
D»mopolls Chalk
Hoorevllle Chalk
Cutaw Formation
MeShan Formation
Gordo Formation
Coker Formation
Undlfferentlated
Undlfferentiated
Thickness
(ft)
0-50
0-60
0-170
0-150
0-40
0-30
250-300
400-450
450-900
300^900
300-350
200-500
0-400
0-1100
Water-bearing character
Small supplies available from shallow veils.
Mot an aquifer.
Water hard and high in iron. Probably large supplies
available from alluvium.
Too liaited in extent and too shallow to be a major
aquifer in project area. Kay have local Importance.
Not an aquifer.
Hot a major aquifer in project area.
Hot an aquifer.
50-225 feet thick. The principal source of water supply
in western part of project area. Large yields available.
Water levels shallow. Water contains iron, but good
otherwise.
Minor aquifers in Uilcox are locally Important sources
of water in Choctaw and Grenada Counties and potentially
major sources in lalobusha County.
100-250 feet thick. Principal aquifer in southeastern
part of project area. Iron a problem.
Hot aquifers.
Rlpley supplies many wells in Chickasaw County but few
major ones. Liaited potential for industrial supplies.
Chalk units are not aquifers.
S Principal aquifer in Chickasaw County, Important in
• Calhoun County. Some iron problems. Fluoride
.§• excessive.,
« A principal aquifer In Calhoun and Webster Counties.
K Dissolved solid* exceed 400 mg/1. Iron Is a problem
| locally.
y Tapped by few walls. Potential source of water supplies
g in northeastern part of project area. Quality similar
> to Gordo.
.g No wells. Water probably is slightly saline.
"2
«l
&
*>
O
x Not known to cont&in aquifer* In project AT««.
. Bettandorff, Water For Industrial Development in Calhoun,
Grenada, Montgomery, Webster, and Yalobusha Counties,
Mississippi, U.S. Geological Survey and the Mississippi Research and Development
Center 1973
-------
TABLE 2
RCRA GROUND WATER MONITORING PARAMETERS
*Category 1
Arsenic
Barium
Cadmium
Chromium
Fluoride
Lead
Mercury
Nitrate (as N)
Selenium
Silver
Endrin
Lindane
Methoxychlor
Toxaphene
2, 4-D
2,4,5-TP Silvex
Radium
Gross Alpha
Gross Beta
Turbidity
Coliform Bacteria
**Category 2
Chloride
Iron
Manganese
Phenols
Sodium
Sulfate
***Category 3
PH
Specific Conductance
Total Organic Carbon
Total Organic Halogen
*EPA Interim Primary Drinking Water Standards
**Ground Water Quality Parameters
***Ground Water Contamination Indicator Parameters
-------
TABLE 3
MONITORING WELL CONSTRUCTION DATA
Total Casing/
GSE Depth Screen Screened Date
Well (ft, MSL) (ft) Material Interval Completed
(ft)
R-l 98.59 32.77 2" #40 PVC 21-31 3-24-82
R-2 97.16 30.54 2" #40 PVC 19-29 3-25-82
R-3 94.47 29.80 2" #40 PVC 18-28 3-26-82
R-4 93.65 30.55 2" #40 PVC 19-29 3-27-82
R-5 - 31.0 2" #40 PVC 21-31 7-17-84
R-6 - 31.0 2" #40 PVC 21-31 7-17-84
R-7 - 31.0 2" #40 PVC 21-31 7-17-84
R-8 - 31.0 2" #40 PVC 21-31 7-17-84
R-9 - 31.0 2" #40 PVC 21-31 7-17-84
SF-1 99.67 27.5 2" #40 PVC 17-27 8-21-85
SF-2 98.02 30.0 2" #40 PVC 20-30 8-22-85
SF-3 98.23 26.0 2" #40 PVC 16-26 8-22-85
Sf-4 99.23 30.0 2" #40 PVC 20-30 8-23-85
-------
Table 4
Wells Designated for Ground Water Monitoring During
Interim Status at the Koppers Tie Plant Facility
Old System Surface Impoundment
Date of Monitoring
Well Active Monitoring Designation
R-l March 1982 to upgradient
R-2 February 1985 downgradient
R-3 downgradient
R-4 downgradient
New System Surface Impoundment
R-5 July 1984 upgradient
R-6 to downgradient
R-7 ? downgradient
R-8 downgradient
R-9
Spray Field
SF-1 August 1985 upgradient
SF-2 to downgradient
SF-3 ? downgradient
SF-4 downgradient
-------
TABLE 5
SAMPLE COLLECTION DATA
Sample Sampling
Point Date Time Remarks
SF-1 5-19-86 1120 light yellow, cloudy, clayey
SF-2 5-19-86 1230 orange, cloudy-turbid
SF-4 5-19-86 1450 light yellow, clear, gritty
with mica flakes
R-l 5-20-86 0925 yellow, cloudy
R-9 5-20-86 0910 light orange, cloudy-turbid
R-4 5-20-86 1120 orange, opaque, turbid
R-7 5-20-86 1425 orange, opaque
R-5 5-21-86 0930 dark gray, opaque
R-5 (dup) 5-21-86 0930 dark gray, opaque
-------
TABLE 6
ORDER OF SAMPLE COLLECTION
BOTTLE TYPE AND PRESERVATIVE LIST
Parameter
Bottle
Preservative
Volatile Organic Analysis (VOA)
Purge and trap
Direct inject
Purgeable Organic Carbon (POC)
Purgeable Organic Halogens (POX)
Extractable Organics
Pesticide/Herbicide
Dioxins
Total Metals
Total Organic Carbon (TOC)
Total Organic Halogens (TOX)
Phenols
Cyanide
Nitrate/ammonia
Sulfate/chloride
2 60-ml VOA vials
2 60-ml VOA vials
1 60-ml VOA vial
1 60-ml VOA vial
A 1-qt. amber glasses
2 qt. amber glass
2 qt. amber glass
1 qt. plastic
4 oz. glass
1 qt. amber glass
1 qt. amber glass
1 qt. plastic
1 qt. plastic
1 qt. plastic
HN03
H2S04
NaOH
-------
PAGE
TABLE 7
KOPPBRS TIB PLANT
GRENADA, MISSISSIPPI
HVGHTF
AHALRICAL DATA SUMMARY
R-7 SF-2 SF-4 R-4 R-5 R-S(dup) SF-1 R-l R-9
S.I. S.F. S.F. S.I. S.I. S.I. S.F. S.I. S.I.
DN GRAD DH GRAD DM GRAD DN GRAD UP GRAD UP GRAD UP GRAD UP GRAD DN GRAD
05/20/86 05/19/86 05/1S/86 05/20/86 05/21/86 05/21/86 05/19/86 05/20/86 05/20/86
RCRA HASTE CHARACTERISTICS
PURGEABLE ORGANIC HALOGEN
INORGANIC ELEMENT/COMPOUND
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
COBALT
CHROMIUM
COPPER
NICKEL
LEAD
SELENIUM
VANADIUM
ZINC
MERCURY
ALUMINUM
MANGANESE
CALCIUM
MAGNESIUM
IRON
SODIUM
POTASSIUM
EXTRACTABLE ORGANIC COMPOUNDS
NAPHTHALENE
' ' .!. ;A: 1
KLUUSKNE
PHENANTHRENE
C3 ALKYLBENZENE
BENZOTHIOPHENE
ETHYLIDENEINDENE
4 UNIDENTIFIED COMPOUNDS
2-HETHYLNAPHTHALENE
DIBENZOFURAN
1,4-NAPHTHOQUINONE
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
—
280
—
1
--
160
30
40
33J
—
230
180
0.62JN
64000
620J
UG/L
—
320
7JN
—
—
70
30
46
—
—
80
120
—
36000
250J
UG/L
—
130
—
1
~
11
—
—
—
—
~
33
0.3JN
7200
—
UG/L
13J
330
11JN
1
~
190
47
54
80J
~
290
290
0.04JN
82000
360J
UG/L
19J
330
31JN
4J
410J
530
88
270
70J
15J
550
2400
—
82000
2700J
UG/L
27J
320
33JN
4J
400J
580
83
260
70J
13J
610
2300
—
84000
2600J
UG/L
..
110
~
—
—
26
—
—
--
—
—
39
—
15000
150J
UG/L
160
—
1
—
63
—
__
—
18J
50
79
.-
27000
130J
UG/L
15J
140
—
1
—
43
__
—
—
45
73
—
25000
280J
MG/L
UG/L
MG/L
UG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
21
14
80
25
7.6
87
21
44
145
6.1
55
23
6.9
69
5.8
22
16
137
21
8.0
35
17
134
140
11
34
16
146
138
11
44
19
16
150
—
16
11
29
20
—
12
6.9
21
22
—
UG/L
UG/L
UG/L
2200
52J
24J
200JN
300JN
200JN
70J
64J
UG/L
870
63J
24J
12J
130JN
140JN
90JN
30J
40J
12J
UG/L
UG/L
UG/L
200J
-------
PAGE 2
TABLE 7 (cont.)
HOPPERS TIE PLANT
GRENADA, MISSISSIPPI
INGOT
ANALYTICAL DATA SUMMART
R-7 SF-2 SF-4 R-4 R-5 R-S(dup) SF-1 R-l R-9
S.I. S.F. S.F. S.I. S.I. S.I. S.F. S.I. S.I.
DN GRAD DN GRAD DH GRAD ON GRAD UP GRAD UP GRAD UP GRAD UP GRAD DN GRAD
OS/20/86 05/19/8S 05/19/86 05/20/86 05/21/86 05/21/86 OS/19/86 05/20/86 05/20/86
PURGEABLE ORGANIC COMPOUNDS UG/L UG/L UG/L UG/L UG/L UG/L UG/L UG/L UG/L
BENZENE
TOLUENE
ETHYL BENZENE
TOTAL XILENES
CONVENTIONAL PARAMETERS
AMMONIA
CHLORIDE
NITRATE-NITRITE NITROGEN
SULFATE
PHENOL (4AAP)
TOTAL ORGANIC CARBON
TOTAL ORGANIC HALOGEN
—
—
MG/L
24
0.46
40
UG/L
~
MG/L
1.1
UG/L
13
—
—
MG/L
„
108
0.60
140
UG/L
—
MG/L
1.8
UG/L
34
—
—
MG/L
..
120
0.67
98
UG/L
—
MG/L
1.9
UG/L
16
—
—
MG/L
..
48
0.72 '
30
UG/L
—
MG/L
1.9
UG/L
19
5.4
6.1
9.0
16
MG/L
0.35
72
—
190
UG/L
220
MG/L
12
UG/L
56
4.1J
4.7J
6.8
6.5
MG/L
0.35
71
—
220
UG/L
210
MG/L
14
UG/L
53
—
—
MG/L
__
76
2.2
200
UG/L
—
MG/L
1.0
UG/L
18
—
—
MG/L
^—
11
1.5
66
UG/L
—
MG/L
1.8
UG/L
14
—
—
MG/L
_—
9.8
1.3
63
UG/L
—
MG/L
—
UG/L
5
llt»ttttttttt*ltttttt*t»tt***tt»*t*ttt*ttttt»t*t*«*tt«*ttt»tt*t«
"'FOOTNOTES*"
J - ESTIMATED VALUE
N - PRESUMPTIVE EVIDENCE OF PRESENCE OF HATERir
-- - MATERIAL WAS ANALYZED FOR BUT NOT DETECTED
-------
(CONTINUED)
TABLE 0
KOPPERS TIE PLANT
GRENADA, MISSISSIPPI
HUGUIttr
ESD - ATHENS DATA SUHHARY
SF-1 SF-2 R-5 R-9
UP DOWN UP DOWN
05/19/86 05/19/86 05/21/86 05/20/86
1120 1230 0930 0910
UG/L
UG/L
1-ltETHYLNAPHTHALENE
C5 ALKYLBENZENE (4 ISONERS) >,
Cb ALKYLBENZENE (2 1SOHERS)
BIPHENYL
C2 ALKYLNAPHTHALENE (4 ISONERS)
NAPHTHALENECARBONITRILE
NAPHTHALENOL
HETHYLFLUORENE
HETHYLNAPHTHALENOL
HETHYLDIBENZOrURAN
DIBENZOTHIOPHENE
BIPHENYLOL
NAPHTHALENECARB01YLIC ACID
DIBENZOFURANOL
NITRQ50CARBAZOLE
ACRIDINONE
4 UNIDENTIFIED CONFOUNDS
2-HETHYLPIOOl
4-NETHYLPHENOL
DIBENZOFURAN
2-METHYLNAPH1HALENE
PURGEA8LE ORGANIC CONPOUNDS
BENZENE
ETHYL BENZENE
TOTAL IYLENES
CONVENTIONAL PARAMETERS
UG/L
MG/L
UG/L
100JN
80JN
30JN
30JN
80JN
20JN
30JN
.20JN
30JN
30JN
30JN
30JN
30JN
30JN
100JN
IOJN
400J
21
7.6J
45
38
5J
8.3
12
nfi/L
UG/L
mil
AIWONIA
CHLORIDE
NITRATE-NITRITE NITROGEN
SULFATE
PHENOL (4AAP)
TOTAL ORGANIC CARBON
—
82A
2.0
170A
—
110
0.87
110
0.25
74
0.12
120
—
10
1.1
50
UG/L
HG/L
3.8
UG/L
HG/L
3.5A
UG/L
200
BG/L
22
UG/L
HG/L
3.1
tititmmttttittiiiitiiiiiifuiiiifimitifitiftiitiftHHiiff
iiiFOQTNOTES«i<
•A-AVERAGE VALUE
-------
TABLE 8
KOPPERS TIE PLANT
GRENADA, MISSISSIPPI
HWGUHTF
ESD - ATHENS DATA SUHNARY
SF-I SF-2 R-5 R-9
UP DOUN UP DOWN
OS/19/86 05/19/86 OS/21/86 OS/20/86
1120 1230 0930 • 0910
INORGANIC ELEHENT/CONPOUND UG/L UG/L UG/L U6/L .
ARSENIC - - 90 -
BARIUN 93 310 3SO 110
BERYLLIUN - - 31
COBALT - ~ 380
CHRQHIUH 19 60 490 30
COPPER ~ 13 79
NICKEL - 23 2BO
LEAD - --• 65J
STRONTIUM 420 1200 310 190
TITANIUM * 200 470 810 170
VANADIUM 23 89 S40 44
YTTRIUM -- 24 180
ZINC 27 83 2600 SI
ALUMINUM 11000 31000 91000 14000
MANGANESE ISO 270 3400 260
^ MG/L H6/L HG/L MG/L
CALCIUM 43 85 40 12
MAGNESIUM 17 19 18 5.7
IRON , 13 43 120 16
SODIUM ISO 140 150 21
EITRACTABLE ORGANIC COMPOUNDS UG/L UG/L UG/L UG/L
NAPHTHALENE - - 5&o
ACENAPHTHENE -- - 85
FLUORENE - - ;jj
PHENANTHRENE - - 32
ANTHRACENE -- - 2.8J
FLUORANTHENE - - j.jj
BIS(2-ETHYLHEXYL) PHTHALATE • - 22
PHENOL - - 2.4J
2,4-OIHETHYLPHENQL - - 34
2-HETHYL-4.&-DINITROPHENOL - - - 6.&J
PENTACHLOROPHENOL ~ - 5.0J
BENZOFURAN - ~ 30JN
HETHYLSTYRENE - - 100JN
INDENE - - , 30JN
NETHYLBENIONITRILE -- - 30JN
C4 ALKYLBENZENE - - 3QJN
C3 ALKYLBICYCLOHEPTANONE - - 30JN
HETHYLBENZOFURAN - - 4QJN
C2 ALKYLPHENOL (NOT 2,4-DIHETHYL)(3 ISOH - - 100JN
C2 ALKYLSTYRENE (2 ISOHERS) - - 40JN
CHLOROANILINE (NOT 4-) - -- 30JN
BENZOTHIOPHENE - - lOOJN
C3 ALKYLPHENOL (7 ISONERS) -- - 200JN
C4 ALKYLPHENOL (3 ISOHERS) - - BOJN
C2 ALKYLBENZOFURAN - - 20JN
-------
APPENDIX A
TASK FORCE ANALYTICAL RESULTS
Due to size, the raw data is not included in this report.
A copy of the data can be requested from:
EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
-------
APPENDIX B
EPA REGION IV BSD ANALYTICAL RESULTS
Due to size, the raw data is not included in this report,
A copy of the data can be requested from:
EPA Region IV
Residuals Management Branch
345 Courtland Street, N.E.
Atlanta, Georgia 30365
-------
-5-
MONITORING WELL LOG
PROJECT
DRILl
DRILl
.ING Mr
.ER DIS
Grenada, MS (RCRA)
FHOD H.S.A.
GEOLOGIST
I
VELL NO
C (Developers International Service DATE •»/-,,«,.»
GROUND ELEVATION 96.55
TOP OF WELL
100.36
DEPTH OF WELL (ft) 32.77
CASING MATERIAL 2" PVC
DEPTH
•
•
•
5 -
•
•
10 -
•
15 -
20 -
25 -
•
•
30 -
•
•M
DEPTH
m
[• 2.0
- 5.0
• 7.0
• 9.0
*
w
»
- 21 0
• 27 0 i
• 31 .0
m
I
GROUND WATER DEPTH (ft):
AT COMPLETION 2?.?
AFTER 12 HOURS 22.6
SCREEN 10 ft cf 0.010" ?erPon
DESCRIPTION
Brown FILL
and CLAY & SILT, -It broken rock
GRAVEL PA
BENTONITE
BACK FILL
CONCRETE
' SCREEN
" Gray /tan CLAY i SILT, tr f brown sand
- . Brown CLAY
Tan F-SAND,
i SILT, U f sand
tr brown clay & silt
*
•
Tan F-SAND
•
Lt tan F-M
Lt red/tan
SAND, tr c sar.d
F-SAND, tr silt
•«
^•i
CXES
i- '"•;»
h^n
CONSTRUCTIC
•
•
•
•
^
u
il
r
t '
f
r
|p
•1
s *
1 ' — i '
t
-------
MONITORING WELL LOG
PROJECT-
Grenada. MS ffi:?.A'. • wn i
OR ILL ING METHOD H.S.A.
DRILLER Develose-s Int«-*av
GROUND ELEVATION 97.16
TOP OF WELL
98.70
DEPTH OF WELL (ft) 30.54
CASING MATERIAL 2" PVC
DEPTH
•
•
•
5 -
• *
*
10 -
1.5 -
•
20 -
•
•
25 -
30 -
«i
*
DEPTH
•
- 2.0
*
- 6.0
>•
••
-10.0
- 12.0
•»
•
•
•
r-25.0
•2S.O
•
m
-
p~
r
GEOLOGIST
Nw . •?•"
oral s.-v*,-. f>^ DATE 9/75/P9
GROUND WATER DEPTH (ft):
AT COMPLETION 21.54 Stt
AFTER 12 HOURS 21.5 I**!
WEL PACK RT
••
•
•
\
f f
c -
<•
i
i
I
i
[
t
B
1
i
i
-------
MONITORING WILL LOG
PROJECT
Grenada. MS
W—t I i* ** •* •
C.LL f>c. r.-.
DRILLING METHOD H.S.A.
GEOLOGIST
DRILLER Pavelo~ers Internetional Service Ccrs. DATE
3/25/S2
GROUND ELEVATION 94.47
TOP OF WELL 96.27
DEPTH OF WELL (ft) 29.8
GROUND WATER DEPTH (ft):
AT COMPLETION 21.8
AFTER 12 HOURS 22.0
CASING MATERIAL 2" PVC
SCREEN 10 ft of 0.010" screen
GRAVEL PACK
BENTONITE
BACK FILL
CONCRETE
SCREEN
STRATA SAMPLE
DEPTH I DEPTH
DESCRIPTION
CONSTRUCT:
-- 2.0
5--
20--
'25 -T-
- Brown/gray SILTY CLAY, tr f sand
^ Brown/gray CLAYEY SILT. It f sand
10--
-- 12.0
15--
— Lt tan M-F SAND, tr silt
30
1
T
28.0
-------
MONITORING WELL LOG
PROJECT
WELL NO.
DRILLING METHOD
DRILLER
GEOLOGIST
DATE
GROUND ELEVATION 93.65
TOP OF WELL
95.22
DEPTH OF WELL (ft) 30.55
GROUND WATER DEPTH (ft):
AT COMPLETION 21.5?
AFTER 12 HOURS 21.0
CASING MATERIAL 2" PVC
SCREEN 1C ft of 0.010" screen
GRAVEL PACKJ7v/>.
BENTONITE
BACK FILL
CONCRETE
SCREEN KHr»-
STRATA
DEPTH
SAMPLE
DEPTH
DESCRIPTION
CONSTRUCTION
4.0
T 6.0
- Brown CLAY & SILT, tr f sand
— Lt tan CLAYEY SILT, and F SAND
10--
-- 12.0
15-1-
~ Lt gray/tan F SAND, tr silt
gray M-F SAND, tr silt
20-1-
25 —
•- 27.0
30-L
i
1
••
;; i
- i
-•i
-------
MONITORING WELL LOG
™™
PROJECT
Grenada, MS
WELL NO.
DRILLING METHOD H.S.A.
DRILLER P.S.I. Inc.-Engineering
GEOLOGIST
DATE
B. Gillespie
7/17/84
GROUND ELEVATION,
TOP OF WELL
DEPTH OF WELL (ft) 31.0
GROUND WATER DEPTH (ft):
AT COMPLETION
AFTER HOURS
CASING MATERIAL 2" PVD
SCREEN 10' 0.010 Slot
GRAVEL PACK
BENTONITE
BACK FILL
SCREEN
.'•*.-."•
STRATA
DEPTH
SAMPLE
DEPTH
DESCRIPTION
crown lUfbUiL, tr organic (roots)
CONSTRUCT! 0
^<
Tan/brown/gray SILT, tr organics (roots)
5.0-3.
, some
tr stone fragments"
X
_ Brown SILT and SILT & CLAY
io.o->
Brown/gray SILT & CLAY and f SAND
;£
tx
_ Tan SILT & CLAY and F SAND
15.
X
I
&
~ Tan f SAND, tr. silt
-- *g
20.0-><
25-°->
-------
MONITOR ING 'WELL LOG
PROJECT
Grenada, MS
WELL NO.R-6
DRILLING METHOD H.S.A.
DRILLER P.S.I. Inc.-Engineering
GEOLOGIST J- B. Cillespie
DATE 7/17/84
GROUND ELEVATION.
TOP OF WELL
DEPTH OF WELL (ft) 31-0
GROUND WATER DEPTH (ft);
AT COMPLETION
AFTER HOURS
CASING MATERIAL 2"
SCREEN 10' 0.010 Slot
GRAVEL PACK
BENTONITE
BACK FILL
CONCRETE
SCREEN
s /^"xi
STRATA
DEPTH
S AMPLE
DEPTH
DESCRIPTION
CONSTRUCTION
_ Brown SILT, and SILT fit CLAY, tr stone fragments
><
_ Tan/gray SILT
5.0->
><
- Gray/brown SILT & CLAY
10.0-^
X
><
- Tan/white f SAND, tr silt
iso--><
_ Rtast/gray fm SAND and CLAY & SILT
20.
r^
_ Gray CLAY & SILT, tr f SAND
25
-
Gray fmc SAND, tr silt
30.0-^
^
1
I
1
„
;\ o
6
•'.'1 -
rurt-T
-------
MONITORING WELL LOG
PROJECT Grenada, MS
WELL NO.*-'
DRILLING METHOD H.S.A.
DRILLER
P.S.I. Inc. -Engineering
GEOLOGIST J- B. Cillespi(
DATE 7/17/84
GROUND ELEVATION,
TOP OF WELL
DEPTH OF WELL (ft) 31.0 •
GROUND WATER DEPTH (ft)
AT COMPLETION
AFTER. HOURS
CASING MATERIAL
2" PVC SCREEN 10' 0.010 Slot
GRAVEL
BENTONITE
BACK FILL
CONCRETE
SCREEN
DEPTH
X
><1
5.
10.0-2
^
15.0-^
20.
25.0--
30.0__
SAMPLE
DEPTH
X
X
DESCRIPTION
Tan/brown/gray SILT, tr roots
_ Tan /brown SILT and SILT & CLAY
Brown SILT & CLAY and f SAND, SILT
_ White vf SAND, some brown silt & clay, tr silt
White vf SAND, tr brown silt & clay, tr silt
- Tan f SAND, tr silt
_ Gray/tan af SAND, tr clay & silt
tfci
CONSTRUCTION
.
**
currr 1
-------
MONITORING WELL LOG
PROJECT Grenada. MS
DRILLING METHOD H.S.A.
DRILLER p
GEOLOGIST J
WELL NO.R-8
B. Gillesole
.S.I. Inc. -Engineering DATE 7/17/84
GROUND ELEVATION
TOP OF WELL
DEPTH
OF WELL (ft) 31.0 '
CASING MATERIAL 2" PVC
STRATA! SAMPLE
DEPTH 1 DEPTH
X
r" "- •
T
5.0-
•-
N.
10.0"
15.0-
20.0-
25.0-
30.0-
X
X
• \
X
r><
1
i^r:
•S
t
V'
* •
^ •
Q
V
0
o
0
-
—
T
1
j
—
D
0 _
3
C
-------
MONITORING WELL LOG
PROJECT Cr««.d,. MS
DRILLING METHOD
WELL NO.R-S
DRILLER p.s.I. Inc.-Eneineerin* DATE 7
GROUND ELEVATION GROUND WATER DEPTH fftV
TOP OF WELL
AT COMPLETION
DEPTH OF WELL (ft) 31.0 ' AFTER HOURS
CASING MATERIAL 2" PVC SCREEN 10' 0.010 Slot
STRATA
DEPTH
5.0-
'10. (L
15.0-
20.0-
25.0-
30.0-
^•^•^^•^
SAMPLE
DEPTH
^*^>^-*^'
X
X
^x.
^^^^^^^^^
>x^
•
•
LX
•
••
^»
•••MM^MM
DESCRIPTION
^D. uiiiesni*.
/17/8A
l~»«~~~»»«B
• GRAVEL W
BENTONIT
BACK FIL!
CONCRETE
SCREEN
- Tan SILT, tr roots
- Brown SILT
— Gray SILT, little silt & clay
- Shelby tube
— Brovn SILT & CLAY, tr roots
_ Brovn SILT & CLAY, tr f sand
" Tan f SAND, tr silt
- Tan fmc SAND, tr silt
-
— — — —
^~
CONSTRUCTION
_
-
<
—
\
^w*
* •*
*.*
•
-==m_
X
V«<
j^r
i^r
I
%•
%
'%
i
!
* •
?/
i
1
—
—
—
-------
MONITORING WELL LOG
PROJECT Grenada. Miss. Soravfield
WELL NO. SF-1
DRILLING METHOD.
DRILLER PSI
HSA
GEOLOGI5T__C.A- Cramer
DATE
8/21/85
GROUND ELEVATION 99.67
TOP OF WELL 101-92
DEPTH OF WELL (ft)
GROUND WATER DEPTH (ft);
AT COMPLETION
AFTER. HOURS
CASING MATERIAL
SCREEN 1°' -°«010 slotted PVC
GRAVEL PACK
BENTONITE
BACK FILL
CONCRETE
SCREEN
STRATA
DEPTH
SAMPLE
DEPTH
DESCRIPTION
CONSTRUCTION
5 --
10 . _
15 --
20 H-
25 --
30 --
35
~ Brown silty CLAY, tr gravel, tr roocs, moist
Light gray and brown mottled silty CLAY, tr silt
_ pockets* tr organics, moist
_ Rust to orange, and light gray mottled silty CLAY,
_ some organic stains, tr concretions (m gravel),
moist
' SAND and SILT, tr clay, moist to wet
Gray to Rust £ SAND, little silt, tr clay, wet
Gray silty CLAY, tr sand, wet
Gray SILT and f SAND, wet
Rust to black f SAND, tr silt, wee
SHEET 1
OF
-------
MONITORING WELL LOG
PROJECT Grenada, Miss. Sprayfield
WELL flQSF-2
DRILLING METHOD HSA
DRILLER
PSI
GEOLOG1ST C'A' Cramer
DATE 8/22/85
GROUND ELEVATION
TOP OF WELL
98'02
100.22
DEPTH OF WELL (ft)
GROUND WATER DEPTH (ft);
AT COMPLETION _
AFTER
CASING MATERIAL 2" ?VC SCREEN 10' 0-010 «lo*ted ?VC
GRAVEL PACK
BENTONITE
BACK FILL
CONCRETE
• SCREEN
STRATA
EPTH
SAMPLE
DEPTH
DESCRIPTION
CONSTRUCTION
Light brown silty CLAY, some roots, moist
Light brown and gray mottled clayey SILT* tr roots,,
moist
5- -
— Brown and white silty CLAY> fractured, dry
Tan clayey SILT, tr white silt pockets, moist
10--
_ Light gray and rust CLAY and SILT, moist
White, tan, and rust f SAND, tr to some silt,
moist
15--
25--
30..
35. .
Tan mf SAND, little silt, wet
Blue gray silty CLAY,wet
Tan to gray mf SAND, little silt, wet
SHEET
OF
-------
MONITORING WELL LOG
PROJECT Grenada, Miss. Sprayfield
WELL NO.
SF-3
DRILLING METHODHSA
DRILLER
PSI
GEOLOGIST.
DATE
8/22/85
GROUND ELEVATION 98-23
TOP OF WELL 100-23?
DEPTH OF WELL (ft)
GROUND WATER DEPTH (ft):
AT COMPLETION
AFTER HOURS
CASING MATERIAL 2" PVC
SCREEN 10' 0.010" slotted PVC
GRAVEL PACK
BENTONITE
BACK FILL
CONCRETE
SCREEN
STRATA
DEPTH
SAMPLE
DEPTH
DESCRIPTION
CONSTRUCTION
5--
10- -
15..
20..
25. _
30
35
Brown to gray clayey SILT, some roots, moist
Tan and gray mottled silty CLAY, tr organic stains,
moist
Rust and gray mottled CLAY and SILT, tr £ sand,
moist
White f SAND and SILT, moist
Rose,*tan and white lamina t ed^ mf SAND,, tr silt,
gray silty clay lens, 15-15.5', 19.5-20', tr sand,
moist
- Tan to gray f SAND, little to some silt, wet
Tan mf SAND, tr silt, wet
SHEET
OF
-------
PROOECT
MONITORING WELL LOG
Grenada, Miss. Sprayfield
WELL NO.
DRILLING METHOD
DRILLER
HSA
PSI
GEOLOGIST
DATE
C.A. Cramer
8/23/85
GROUND ELEVATION 99.23'
TOP OF WELL 101-33'
DEPTH OF WELL (ft)
GROUND WATER DEPTH (ft);
AT COMPLETION
AFTER HOURS
CASING MATERIAL
SCREEN
GRAVEL
BENTONITE
BACK FILL
CONCRETE
SCREEN
STRATA
DEPTH
SAMPLE
DEPTH
DESCRIPTION
CONSTRUCTION
10--
15--
Brown silty CLAY,some organics, tr sand, moist
5 -- —
Brown and tan mottled clayey SILT, tr roots,
tr organic stains, moist
Light gray and orange mottled, SILT and CLAY,
come c sand size black concretions, moist
White, tan, and rust lamina ted £ SAND to of SAND,
tr silt, moist
Tan to gray silty CLAY, moist to wet
Gray f SAND and SILT,.wet
Kus ana can i
o.LC.e slit, cr cay, wet
• r/
\
SHEET
OF
-------
KOPPERS COMPANY, INC,
PROCEDURES FOR GROUNDWATER SAMPLING,
CHAIN OF CUSTODY,
ANALYTICAL METHODS,
AND ANALYTICAL QA/QC
-------
KOPPERS COMPANY, INC.
PROCEDURES FOR GROUNDWATER SAMPLING
Y
-------
GROUNDWATElOAMPLING^ —"— ~~ ..
A. - Preparation for Sampling Trip" _
1. Determine when sampling is to be performed.
a. Meet with Project Manager or Environmental Coordinator to deter-
mine sampling scheduling requirements, i.e., when was sampling pro-
posed and determine if there is any variability in the sampling dates.
b. When sampling trip is scheduled, inform Project Manager of dates.
2. Determine what analyses are to be performed.
a. Review proposal or pertinent environmental regulations with Project
Manager to assure that all required samples aJong with any additional
samples are obtained. Also, special sampling requirements such as
filtering samples, etc. will have to be indicated by the Project
Manager.
3. Bottle Preparation
a. . Conventional Pollutants
^(1) Sample bottles for holding and shipping samples are all new
bottles with screw-type lids.
(2) Bottles are prelabeled and pre-preserved for the specific
analyses. Specific preservatives and containers are listed in an
a:;dx.nrnent to this document.
(3) The bottles are securely boxed and labeled and placed in
reinforced containers for shipping to the sample site.
(4) If bottles are sent air freight, no preservatives are added to the
bottles due to airline regulations; therefore, preservatives are
purchased locally and added to the bottles at the field
laboratory prior to sampling.
b. Priority Pollutants and Appendix VIII Parameters
(1) Sample bottles for holding and shipping samples are all new
bottles with screw-type lids, then specially cleaned as follows.
(a) Wash with hot, soapy water.
_ — - (b) Rinse with tap water.
-i J _ (c) Rinse with 1:1 nitric acid.
-------
(d) Rlnse_with -distilled water.
(e) Wash with .acetone (Pesticide Grade). -- !
(f) Wash with hexane (Pesticide Grade).
(g) Wash with methylene chloride (HPLC Grade).
(h) Dry glassware and equipment with pure nitrogen.
(i) All lids are lined with Teflon.
(j) The bottles are prelabeled and preserved to identify what
analyses they are for. Specific preservatives and
containers are listed in an attachment to this document.
Preparation Of Bailers
au Description of bailers - bailers are constructed of 1.5-inch diameter
stainless steel, and are approximately IS inches long. A stainless
steel ring has been welded to the top of the bailer to tie the lowering
cord onto. The bottom of the bailer is fitted at the site with a
disposable, natural cork laboratory stopper. New cotton string is
used as lowering cord.
b. Cleaning procedure for routine RCRA sampling - After each
sampling, the stainless steel bailers are thoroughly cleaned and stored
for the next sampling program.
(1) If the bailer is coated with oils, prewash the bailer with
acetone.
(2) Rinse with hot, soapy water.
(3) Rinse with tap water.
(*») Rinse with distilled water.
(5) Burn off bailer for one hour at 1200°F.
V
, (6) Wrap each bailer with aluminum foil (shiny side out) and store
/ for next use.
c. Cleaning procedure for bailers for PAH's, priority pollutants, interim
primary drinking water standards, and Appendix VIII.
"Wash with hot, soapy water.
-\
:•?*_
____ (2) Rinse with tap water.
-------
(3) ""Rinse with hi nitric aid; —
(4) Riryse-with distilled water. . •
(5) Wash with acetone (Pesticide Grade).
(6) Wash with hexane (Pesticide Grade).
(7) Wash with methylene chloride (HPLC Grade).
(8) Dry with pure nitrogen.
Burn off bailer for one hour at 1200°F.
(10) Wrap bailers with aluminum foil shiny side out.
B. Procedure for Sampling Wells
1. Measuring Water Levels
/
^ • a. Wetted-Tape Method
(1) Mark .first two (2) feet of measuring tape using water-soluble
pen.
(2) Lower tape into well to approximate depth (using last well
reading as a reference).
(3) Note tape reading at iop of well to cne .'ieafey* -SU.U^SMI.;
(0.00).
(4) Retrieve tape from well noting that point at which the ink is
washed off by the water. Clean tape thoroughly after each
time it is used.
EXAMPLE: 25.00 feet - top of well
1.6» feet - length of ink washed off
23.36 feet - depth to water
2. Measuring Well Depth
a. Tie weight to new length of lowering cord.
_ — b. Lower the cord into well until it reaches bottom.
~J c. Mark the point on the cord equal to the top of the well casing.
-------
d. Remove the cord-from the well and stretch out on the ground.
-~~e. Measure the length from the_weight to the'markjjn the cord — this is.
depth of well from the top of the casing.
f. Remove weight and wash thoroughly. Dispose of cord.
3. Determining Purging Volumes
*
a. In order to remove stagnant water and flush the well, three (3) casing
volumes of water are removed from each well before sampling. If
the well goes dry before three (3) casing volumes are removed, let
the well recover, then sample.
NOTE; Contaminated water will not be disposed of on the
'.ground, but will be put in the plant waste water system. •
(measured) (listed below are vol for casing) mis/gal
ft of H2O in well x gallons of H2O per linear ft of casing dia x 3785
of bails = ; — X 3
volume of. bailer
(listed below are vol for bailer size)
Gallons of H2O/linear foot of casing diameter:
•1/2" = 0.1057
2" = 0.1623
4" s 0.6613
6" s 1.5003
Volume of Bailers Used
1-1/8" = 225 mis
1-1/2" = 400 mis
3" = 2000 mis
Sampling The Well
a. Open a plastic garbage can liner and place around bottom of well (if
necessary, use stones at corners to secure it). This plastic will
prevent sampling equipment from coming into contact with the
ground.
b. Tie coTd securely to bailer.
c. Place cork securely in end of bailer.
-------
,.- -
A. Put on disposable gloves --cloth or plastic. , x ~
e. Lower bailer jnto the well until you reach-water level, allow-the-
bailer to sink to the bottom of the well and cut the cord and tie it
~^ securely to the well casing.
f. Proceed to remove the determined number of full bails needed from
^ the well for purging; lower the bailer to the bottom of the well at
least once every 10 bails.
g. Mark site number on jar. Start filling sample holding container until
full, removing lid and replacing between each bail. Lower the bailer
slowly (to prevent degassing of the sample) approximately 2 feet
below the water surface..
h. When filling the sample bottle for any Volatile Organics analysis, do
not aerate the sample. Allow a meniscus to form at the lip of the
bottle, and cap the bottle such that no air is present. Check for air
by tilting bottle upside-down. If an air bubble is present, re-open and
add sample to form a meniscus, and re-cap.
5. Field Handling of the Samples
a. Immediately after collection, the samples are to be taken to a field
laboratory established tt the site.
K At the field laboratory, the oH and speetfic <*K**U«'-tarv7e of
samples will be measured using the appropnatfc^ioottle from each
well. Instruments will be calibrated before use each day, and at four-
hour intervals during the day. Instrument operation will be in
accordance with the specific manufacturer's instructions.
c. Sample bottles will be tightly capped and placed on ice in insulated
coolers. As each cooler is filled, it will be sealed with shipping tape,
and security will be established by placing evidence tape across the
lid and body of the cooler. The cooler will then be labeled with
appropriate shipping labels.
d. At the end of each day of sampling, the filled coolers will be shipped
via overnight air express to the Koppers Environmental Analysis
Laboratory, WO College Park Drive, Monroeville, PA 151*6, or to the
appropriate contract laboratory.
6. Field Blank
a. A field blank will be collected during the sampling process. This will
- involve pouring distilled .water into a laboratory-cleaned bailer, and
then distributing the water between the appropriate sample bottles.
-------
7. Field Data- Sheets
All pertinent, field information will be recorded on the field-data
sheet (example attached). This will include the date and time of
sampling, the sampler, the measured depth to water, the number of
bails required to purge the well, and the field pH and conductivity
measurements. In addition, the sampling crews are instructed to
include significant observations, such as the number of bails removed
before a well ran dry, unusual sample conditions (oily, cloudy,
colored), unusual sampling conditions (bee's nest in protective pipe,
flooded location, etc.), and unusual .well conditions (lock broken,
protector pipe bit, etc.).
Upon return of the sampling crew to Monroeville, the field data
sheets are to be given to the sampling coordinator. That person will
distribute copies to the appropriate personnel, and retain the original
sheets in the plant sampling file.
J
-------
PIKM) DATA SIII-ICT FOI .. JNOWATKIl SAMPLING
>"•'' ^*r/ ' ' ' --
1,'LANT:
I'UOJIiCTj
.HAMI'LKU UY:
WKATIIIill: : >
1
i
SAMPLING MLTIIOL):
Site No.
1
1
i
!
Oiilc,;
I'
1
Time
Well Din.
(in.)
Depth of Well (ft)
(including slickup)
'
Depth to II2O
in Well
(ft)
,, ,
, -
Depth of HjO
in Well
(ft)
Well Elcvnlion
(ft)
(top of casing)
'
"7.O
Kl CVH (Ion
(ft)
Numl>cr
of fails
Removed
In-silu Mcnsurcmcnts
pll
(units)
Conductivity
(|imhos/cm)
h
,
1
i
i *
I «
1 ' ,
SITE NO.
OBSERVATIONS
i
i
it
i
i
i
,
1
t
i
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1
:
i
!
1
ANALYSKS SAMI'LKD FOR:
I'A OK 01'
-------
CHAIN-OF-CUSTODY
.PROCEDURES
KOPPERS COMPANY, INC.
-------
CHAIN OF CUSTODY — . — -'
The procedures for chain of custody of samples collected by Koppers
personnel, pertaining to those working for the Water Quality Engineering
Department and Hydrogeology Department, will follow these specific rules
and regulations when sampling a plant or facility, whether it be
groundwater, surface water, stormwater, or plant discharge water. These
procedures are described in detail and are basically the same as those
outlined by the EPA.
SAMPLE IDENTIFICATION
Samples collected will be identified by sample tape placed on each
individual bottle for analyses. The tape is waterproof and color coded
V specific to the type of analyses to be performed. Printing on the tape is
waterproof and any additional writing placed on the label will be with
waterproof ink. Each sample label will include the following information:
" . 7^,;?7t r«de - Abbreviation of plant or project. ^.
2. Station Location - identifiable from map layout, usually a
number or letter-number.
3. Date - Six digit number, e.g. 6/12/24.
*. Time - four digit number, e.g. 0954 for 9:54 a.m.;
1629 for 4:29 p.m.
5. Sample Analyses
6. Preservatives
7. Samplers - Initials of person collecting sample.
— NOTE: Any, in-situ measurements made will be
recorded directly on field data sheets.
- "~ Examples of in-situ measurements include pH,
temperature, conductivity, flow measurements,
color, odor, and any special observations.
-------
SAMPLE CUSTODY _ -
A sample is under custody if:
1. It is in your possession, or
2. It is in your view, after being in your possession, or
3. It was in your possession and you locked it up, or
4. It is in a designated secure area.
FIELD CUSTODY PROCEDURES
1. Koppers will collect only the number of samples needed to
represent the media being sampled. To the extent possible,
/ Koppers will determine the quantity and types of samples and
sample locations prior to the actual field work. Only the
technicians will handle samples.
sampler will be personally responsible for the care and
custody of the samples collected until they are properly trans-
ferred or dispatched.
3. Sample labels will be completed for each sample, using water-
proof ink unless prohibited by weather conditions. For example,
a notation would explain that a pencil was used to fill out the
sample label because a ballpoint pen would not function in
freezing weather.
tt. The Project Coordinator will determine whether proper custody
_ procedures, were followed during the field work and decides if
\ - additionar"tamples are required.
-------
TRANSFER OF COSTOQY AND SHIPMENT
Samples are accompanied of a Chain-of-Custody Record (see
page fc). When transferring the possession of samples, the
individuals relinquishing and receiving will sign, date, and note
the time on the Record. This Record documents sample
custody transfer from the sampler, often through another
person, to the analyst.
Samples will be packaged properly for shipment and dispatched
to the appropriate laboratory for analysis, with a separate
custody record accompanying each shipment (e.g., one for each
field laboratory, one for samples shipped, driven, or otherwise
transported. Shipping containers will be taped and sealed for
shipment to the laboratory. The method of shipment, courier
name(s), and other pertinent information is entered in the
"Remarks" section on the custody record.
Whenever samples are split with" a source or: government
agency, a separate Receipt for Samples form (see page 5) is
prepared for those samples and marked to indicate with whom
the samples are being split. The person relinquishing the
samples to the facility or agency should request the signature
of a representative of the appropriate party acknowledging
receipt of the samples. If a representative is unavailable or
refuses to sign, this is noted in the "Received by" space. When
appropriate, as in the case where the representative is unavail-
able, the custody record should contain a statement that the
samples were delivered to the designated location at the
designated time.
-------
Ill
CHAIN OP CU,' .. RECORD
FLAMT CODI
NOJMCT HANI ' . i
SAHFuns (Signature)
STA. MO.
! 1
1
,
1
, '• 1 i
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1
ll
bftTI
•
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TIN*
i
Relinquished byt (Signature)
Relinquished byt (Signature)
i 1 '
Relinquished byt (Signature)
3
a
Date
Data
Date
STATION LOCATION
'•
• i
I 1
*
•
Time
Time
Time
•UHDBR
or
l*UW 1 A m H
ms
• .
Received bys (Signature)
Received byt (Signature)
Received for Laboratory byi
(Signature)
////// 'WDUUUW OR
////// OBSraVATIOHS
.
-
11
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,
Relinquished by: (Signature)
Relinquished byt (Signature)
Date
Time
DISTRIUUnONt Original accompanies shipment; Copy to Coordinator Field Piles.
Date
Date
Time
Time
t
Received byt tSignc
R'tceivedbyt (Signa
Remarkst
!
1
,
|[
,u^l
until
PAGR OP
I ., . '
-------
' w
FIRLO DATA SIIULT POU .IDWATKR SAMPLING
PLANT: ~
PROJECT:
'
1
ri
SAMPLED UYl ' ,
WEATHER:
SAMPLING METHOD: . ' ' !
Sitb No.
1 '
|
i
i
i
SITI-: NO.
1
Diltc
: 1
1
lime
1
l!
,
I
Well Din.
(in.)
Dcplh of Well (fl)
(including slickup)
•
Dcplh to HjO
in Well
(ft)
<
Dcplh of IIZO
in Well
(M)
•
Well Elevation
(fl)
(top of casing)
•
H20
Elevation
(fl)
tr
Number
of (tails
Removed
In-silu Measurements
pit
(units)
Conductivity
(limhos/cm)
1
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OUSKKVATIONS
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ANALYSIS SAMPLED POIt:
t <
t
PAGK Ol»_
- i
-------
4. All shipments ^iJl be accompanied-by the Chain-of-Custody
_ Record identifying its contents. JThe "original Record will
accompany the shipment, and the copy will be retained by the
Project Coordinator.
5. If sent by mail, the package will be registered with return
receipt requested. Freight bills, post office receipts, and Bills
of Lading will be retained as part of the permanent documenta-
tion.
PROJECT LOGBOOKS
The Project Coordinator is responsible for the transfer of field data sheets
to the individuals who have been designated to perform specific tasks on
the survey. Individuals sign their field data sheets upon receipt and use
them to record all pertinent information until the project is completed.
Observations made into a recording device must be promptly transcribed
and retained for the records.
Field data sheets should be dated, legible, and contain accurate and inclu-
sive documentation of an individual's project activities. Because the data
sheet forms the basis for the later written reports, it must contain only
facts and observations. Language should be objective and factual. If
entries are made by more than one individual, then both should sign the
field data sheet.
The field data sheet needs to contain information sufficient to recall and
describe succinctly each step of the analysis performed because it may be
necessary for the analyst to testify in subsequent enforcement proceedings.
Moreover, sufficient detailjte necessary tojsnable others to_reconstruct the
procedures followed-should-the originarfrTalysT~be unavailable for testi-
mony. Any irregularkiesr observed during-the testing process need to be
-------
noted. If, in -the technical -judgment of the analyst, it is necessary to
deviate-from ajjarticular analytical method, the deviation shall be justified
and properly documented.
FIELD DATA RECORDS
Where appropriate, Field Data Records (in the form of individual sheets)
are maintained for each survey sampling station or location and the project
code and station number are usually recorded on each page. All in-situ
measurements and field observations are recorded in the FDRs with all
pertinent information necessary to explain and reconstruct sampling
operations. Each page of a Field Data Record is dated and jsigned by all
individuals making entries on that page. The Coordinator and the field
team on duty are responsible for ensuring that FDRs are present during all
monitoring activities and are stored safely to avoid possible tampering.
CHAIN-OF-CUSTODY RECORDS
Serialized Chain-of-Custody Records are distributed in a manner similar to"
that used for sample labels. When samples are transferred to mobile
laboratory personnel, the analyst, after signing, retains the white (original)
custody record and files it in a safe place. The courier returns a copy of
the custody record to the Project Coordinator. A similar procedure is
followed when dispatching samples via common carrier, mail, etc., so that
the original accompanies the shipment and is signed and retained by the
receiving laboratory sample custodian while the copy retained for the
Coordinator is returned from the dispatch point.
When samples are split with the source or another government agency, this
is documented by the Receipt -for Samples_foFm. The label numbers from
all splits are recorded onThe form. " _ -
-------
CHAIN OF CUSTODY - LABORATORY " -_ '
SAMPLE DELIVERY TO THE LABORATORY
The sample will be delivered to the laboratory for analysis by overnight air
express from the job site. Samples will have been preserved appropriately
prior to shipment; recommended holding times will not be exceeded. The
sample must be accompanied by the chain-of-custody record and by a
;?? sample analysis request sheet (Figure 1). The sample must be delivered to
the Manager, Environmental Analysis Laboratory, or his representative in
his absence, hereafter referred to as the "Custodian."
RECEIPT OF SAMPLE
\ Field samples are delivered to the laboratory either personally or through a
public carrier. In the laboratory, a sample custodian will receive the
S samples. Upon receipt of a sample, the custodian will inspect the condition
of the sample and the sample seal, reconcile the information on the sample
label and seal against that on ihe cnam oi custody record, assign a
laboratory number, log in the sample in the laboratory log book, and store
the sample in a secured sample storage refrigerator room until assigned to
an analyst for analysis.
SAMPLE INSPECTION
The sample custodian will inspect the sample for any leakage from the
container. A leaky container containing multiphase sample will not be
accepted for analysis. This sample will no longer be a representative
sample. If the sample is contained in a plastic bottle and the walls show
any bulging or collapsing, the custodian shouW note that the-sample is
under pressure or rejeasirig~gases, respectively. A~ sample under pressure
will be treated with caution. "It can be explosive or release extremely
-------
-poisonous gases. _The custodian will examine'whether the sample seal is
intact or broken, since a broken seal may mean sample tampering and
would make analysis results inadmissible in court as evidence. Discrep-
ancies between the information on the sample label and seal and that on
the chain of custody record and the sample analysis request sheet will be
resolved before the sample is assigned for analysis. This effort might
require communication with the sample collector. Results of the inspec-
tion will be noted on the sample analysis request sheet and on the
laboratory sample log book.
^ -.
ASSIGNMENT OF X.ABOR ATOR Y NUMBER
Incoming samples usually carry the inspector's or collector's identification
numbers. To further identify these samples, the laboratory will assign its
s own site identification numbers, which are given consecutively. '• Each
sample will be marked with the assigned laboratory number. This number
is correspondingly recorded in a laboratory sample JogJ>.ook along with the
information describing the sample.'"The sample information"is copied from
the sample analysis request sheet and cross-checked against, that on the
sample label.
ASSIGNMENT OF SAMPLE FOR ANALYSIS
The manager of the Environmental Analysis Laboratory (or his representa-
tive) will assign the sample for analysis. The manager will decide what
analyses are to be performed, based on the sample analysis request sheet
(Figure 1) and other information at his disposal.
In his own laboratory, the manager may assign ibe sample analysis^to one
or more technicians for therequested analysesfThe technican assigned to
i analysis will record in the—bound laboratory~Inotebook the identifying
-------
— - TO"
laboratory_sample number, the date of analysis and subsequent testing data
and calculations.
The sample may have to be split with other laboratories in order to obtain
all the necessary analytical information. In this case, the same type of
chain-of-custody procedures must be employed at the other laboratory and
while the sample is being transported to the other laboratory.
Once the sample has been received in the laboratory, the manager or his
^ \
assignee is responsible for its care and custody. He should be prepared to
testify that the sample was in his possession or secured in the laboratory at
all times from the moment it was received until the analyses were
performed.
—xiuS'
-------
TCh __
LOCATION:
SUBJECT:
Environmental
Laboratory
FROM:
MSTC
Analytical Instructions
DATE: -
ACTIVITY NO;
Please carry out the indicated tests for specified samples f rom:_
TYPE
EXTRACTS
SOIL GROUNDWATER COMPOSITE
RESIDUE SURFACE WATER GRAB
OTHER PROCESS WATER BAILER
PUMP
TOTAL
EP-TOXICITY
ASTM
ANALYSES
1.
2.
3.
5.
6.
7.
8.
9.
. 10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
pH
Conductivity
Color
Turbidity
Acidity
»
Alkalinity
Solids-Evaporated T-F-V
Solids-Suspended T-F-V -
Solids-Dissolved T-F-V
TOC
COD - Total-Soluble
BOD - Total-Soluble
Phenols
Ammonia-N
Kjeldahl-N
Nitrate-N
Nitrite-N
Phosphorus - Total
Phosphorus - Ortho
Oil &. Grease ~~~ . ~~
CIAL INSTRUCTIONS:
21..
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40. _
Cyanide-Total-Amenable
PCP
Thiocyanate
Antimony (Sb)
Arsenic (As)
Barium (Ba)
Beryllium (Be)
Bicarbonate (HCO3) —
Boron (B)
Cadmium (Cd)
Calcium (Ca)
Car bonate
-------
LABORATORY QUALITY CONTROL PROCEDURE
KOPPERS COMPANY, INC.
ii
-------
;t Duality Control~"?rocextees=- •* • "
A. Evaluation of Daily Performance " . •— -~
lT-At least two standards £a high .and a low) should be analyied. routinely
along with a blank (if applicable) to determine that comparable
operating conditions'exist. In addition, it is recommended that with
specific ion probe procedures, an additional midrange standard also
be run as a check standard.
2. Run duplicate samples every 10th sample or equivalent to 102 of
the time.
* •
3. Run duplicate standard after every 10 samples.
4. Run spike every 10th sample or equivalent to 102 of the time.
) -a. Guidelines-for Spike Selection
.1) Sample selected for spiking should be.well within
the detectable limits of your test.
2) _ror H**t. «-pr«"!>^f-'?;»3u'l*t"the amount (ppin) of spike
should fall between 50-1002 of the known value, for a
given sample.
3) For easiest calculations a. 1:1 mixture of sample and
.spike is recommended.
b. Calculation of Spike
^ 2 Recovery * Value
-K
iheoretical Value of Mixed Spike
-------
8b.
3) _£xample~7: COcprke PL-1355
..." 5Q ml pLjj355_^. 50 1^500''
Theoretical"* t81S ppm)(.5p) + (503 ppm).(.50)
«. " A09.5 . + 251.5.
Theoretical * 661 ppm
4) Example 2: Percent Recovery for COD Spike PL-1355
Actual - 671 ppm Theoretical s 661 ppm
• 1ol-ss
B. Quality Assurance Tab.les
1. Record results of duplicate samples, standards and s,pike on
Quality Assurance Table I. (See attached table.)
\. Plot msan (T) of duplicate standard.-bn S52 confidence T chart.
(See attached chart A).
*
3. Plot range ("R) of duplicate standards on 95* cnnf^.icT.12*
cnart. (See attached chart B.)
*
f .4. Record data on Quality Assurance Table II. (See attached Table II.)
5: Compare data to known tendencies'
.• a. i.e., TOC, BOD, COD relationships
Conductivity-solids relationships
Ammonia nitrogens to TKK, etc.
b. See references.
1) EPA, Analytical Quality Control. Cha-pter 6 — _^:_
2) -Environmental Resource Associates., A Guide to OuaJHtv
' ~ Control Prccticfs for Waste and Potable Wete
p. 17.
-------
Be.
-Reasons for Rejection of Data—="
j«i^m«•* . _-?
-Reason •. ' ~ - „ Course of Action
1. Ksan Tor duplicate standards not
within c&ntrol limits on 95*
confidence T chart (accuracy chart).
*
2. Mean R" of duplicate standards not
within control limits on 95S
confidence R chart (precision chart)
3. Z recovery of spike falls less than
902 or creater then 110*-
id Miller
e IS, 1981
-------
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MAY
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03 Oft 05 06 07 Od 1 09 10
F1CUIIE 2. U C1IA11T
95% CONF1DF.NCE
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