March 1988  '                           700/8-88-040

    EPA-700/8-88-040
      Hazardous Waste Ground-Water
      Task Force
      Evaluation of
      Koppers, Company, Inc.
      North Little Rock, Arkansas
             United States Environmental Protection Agency
7
'i
             Arkansas Department of Pollution Control and Ecology

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    * UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                      WASHINGTON, D.C. 20460
                                                       OFFICE OF
                                                     ADMINISTRATION
                                                     AND RESOURCES
                                                      MANAGEMENT
MEMORANDUM

SUBJECT:   Hazardous Waste Collection

FROM:      i^arbara S. Roth, Acting  Chief
           Information Services Branch

TO:        See Addressees

     This package contains the following  document  which is
to be included in your Hazardous Waste  Collection:

     Hazardous Waste Ground-Water Task  Force  Evaluation
     of Koppers Company, Inc./ North Little Rock/
     Arkansas.
     700/8-88-040, March 1988.

     If you have any questions, please  contact  Jean  Davis  at
 PTS 475-7705.

Attachment

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ADDRESSEES:

EPA Librarians — Regions 1-10; Edison, NJ; RTF, NC; Cincinnati,
                  OH; Ada, OK; Las Vegas, NV; NEIC, Denver, CO;
                  and Headquarters:

     Peg Nelson, Region 1
     Dennis Carey, Region 2
     Diane McCreary, Region 3
     Gayle Alston, Region 4
     Lou Tilley, Region 5
     Nita House, Region 6
     Connie McKenzie, Region 7
     Dolores Eddy, Region 8
     Linda Sunnen, Region 9
     Julienne Sears, Region 10
     Dorothy Szefczyk, Edison, NJ
     Libby Smith, RTP, NC
     Jonda Byrd, Cincinnati, OH
     Stanley Shannon, Ada, OK
     Doreen Wickman, Las Vegas,^NV
     Dorothy Biggs, NEIC, Denver, CO
     Mary Hoffman,  Washington, DC

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      HAZARDOUS WASTE GROUND-WATER TASK FORCE
                   EVALUATION  OF
               KOPPERS  COMPANY,  INC.
            NORTH LITTLE  ROCK, ARKANSAS
                           ~  ,  Environmentaa Protection Agency
                           •r";' .. 5, Library (5PL-16)
                               ,  reborn St-eet.  Room 1670
                           'f.;.... VlL   60604
   UNITED STATES ENVIRONMENTAL  PROTECTION AGENCY
ARKANSAS DEPARTMENT OF  POLLUTION  CONTROL AND ECOLOGY

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                                May 19, 1988
           UPDATE OF THE HAZARDOUS WASTE GROUND-WATER TASK FORCE
                    EVALUATION OF KOPPERS COMPANY, INC.
                        NORTH LITTLE ROCK, ARKANSAS
       The Hazardous Waste Ground-Water Task Force (Task Force) of the
Environnental Protection Agency conducted an evaluation of the ground-
water monitoring program at the Koppers Conpany, Inc., North Little Rock,
Arkansas hazardous waste treatment, storage and disposal facility.  The
on-site field inspection was conducted over a two-week period from July
22, 1986 to July 31, 1986.  Koppers is one of fifty nine facilities that
were evaluated by the Task Force.

       The purpose of the Task Force evaluations is to determine the adequacy
of ground-water monitoring programs at land disposal  facilities in regard to
applicable State and Federal ground-water monitoring requirements.  The eval-
uation focused on determining if the facility was in compliance with applicable
regulatory requirements and policy, and if hazardous constituents were present
in the ground water.

       Since the time of the Task Force Evaluation, the facility has continued
to evolve and change.  Listed below are selected items pertaining to events
which transpired after the inspection.

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On April 24, 1987, Koppers submitted their 1986 annual  ground-water
quality assessment program report.  This report, entitled "Report
of Findings - Second Phase Hydrogeologic Investigation", included
data from the analysis of ground-water samples from the M-series wells
and wells R5B and R5C.  These wells had been completed  at the time of
the Task Force inspection but had not been previously sampled by the
facility.  Also included in the report was analytical data from ground-
water samples taken from offsite wells that had been drilled and com-
pleted after the inspection.  This new analytical  data  has futher con-
firmed the presence of hazardous constituents in the ground water.

In response to the 1986 annual assessment report (dated April 24, 1987),
U.S. EPA Region VI RCRA Enforcement Section transmitted'to Koppers a
list of interim measures which addressed several issues and concerns
related to the ground-water monitoring system.  This letter was
dated November 25, 1987 and called for the installation of a deep
monitoring well.  This well was to fully penetrate the  alluvial
section beneath the facility and be screened immediately above the
underlying clay zone.  This letter also included a list of ten
hazardous constituents; seven componants of creosote and three
metals.  All existing monitoring wells are to be sampled for these
constituents.  These interim measures had not been implemented at the
time of this update.

An EPA contractor conducted a Visual Site Inspection (VSI) at Koppers on
May 12 and 13, 1988.  A report presenting the results of the Preliminary
Review (PR) and the VSI was submitted to EPA Region VI  on June 12, 1987.
A subsequent sampling visit (SV) was conducted July 14  and 15, 1987
and the "Sampling Visit Report" was issued October 12,  1987.  The PR/
VSI/SV reports constitute the facilities RCRA Facility  Assessment (RFA).
The RFA report identified 17 Solid Waste Management Units (SWMUs) and
six other areas of concern (Table A).  It also discussed the potential.
for these units to release hazardous waste or constituents to the
environment.

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                                             TABLE A



SOLID WASTE MANAGEMENT UNITS AND AREAS OF CONCERN AT KOPPERS, CO. INC., NORTH LITTLE ROCK,
UNIT
Solid Waste Management Units:
Past Landfarm #1
Past Landfarm #2
Past Landfarm #3
Waste Container Storage
Facility
Former Sprayfield Area
Drip Track Area
Former Lagoon Area
Container Storage Facility
Surface Impoundment 11
(Upper Lagoon)
RCRA
No<2>
No
No
No
No
No
No
Yes
Yes
STATUS
l(3)
I
I
A
I
A
A
A
A
DATE
1980-81
1980-81
1980-81
1986
1977-83
1907
early
1930 's
1982
1975
CAPACITY
400'xlOO
600'xlOO1
300'xlOO1
190'x54'x5'
\l/2 acres
900'xlOO'
200,000 sq.feet
up to 6' deep
14.5'x51.4'
with 12" curb
100'x80'x7'
RELEASE
Yes
Yes
Unknown
ii
Yes
Yes
Yes
Unknown
H
COMMENTS
Visual contamination
to 2.5". Received sludge
from Former Lagoon Area
Visual contamination to 1.5'
Recieved sludge from Former
Lagoon Area.
Potential for release is
high. Recieved sludge from
Former Lagoon Area.
Being planned at time of
GWTF inspection.
Sampling found elevated
levels of 9 metals.
Being replaced by Concrete
Drip Track and expected to
be closed by 1987. Soil
visibly contaminated.
Visible contamination up to
depth of 18'
Low potential for release.
Subject to Subpart F Ground
Water Monitoring - Closure
by 11/88. Potential for
releases high.

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                                      TABLE A, (continued)



SOLID WASTE MANAGEMENT UNITS AND AREAS OF CONCERN AT KOPPERS, CO. INC., NORTH LITTLE ROCK, ARK.
UNIT
Solid Waste Management Units:
Surface Impoundment #2
(Lower Lagoon)
Primary API Separator
Secondary API Separator
Dehydrator Secondary
Containment
Basement Beneath Treatment
Cylinders
Septic Tank for Shower House
and Lab
PCP Effluent Treatment System
RCRA
Yes
No
No
No
No
No
No
STATUS
A
A
A
A
A
A
I
DATE
1975
1977
early
1970's
1977
1907
. 1907
1973-85
CAPACITY
200 ' x80 ' x7 '
45'xl2'xir
60'x20'xl2'
will contain a
6,000 gal .
Spill
140'x60'x2.5'


60'xl2'
RELEASE
Unknown
ii
Yes
Unknown
Yes
Yes
Yes
COMMENTS
Subject to Subpart F Ground
Water Monitoring - Closure
by 11/88. Potential for
releases high.
Concrete, unlined NPDES
outfall .
Staining observed. Sampling
found elevated levels of 4
metals and elevated levels
of PCP and 12 constituents
of creosote.
Unsealed concrete contain-
ment area. Release poten-
tial is modest.
Visual observation of con-
tamination to 12.5*.
Building is 20'x25'. Samp-
ling found elevated levels
of 5 metals and 11 constit-
uents of creosote.
Above ground cylindrical
tank. Sampling found
elevated levels of 3 metals
and 14 constituents of
creosote.

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                                      TABLE A (continued)



SOLID WASTE MANAGEMENT UNITS AND AREAS OF CONCERN AT KOPPERS, CO. INC., NORTH LITTLE ROCK, ARK.
UNIT
Solid Waste Management Units:
Effluent Surge Tank
Areas of Concern:
Tank Farm Area
Rail Car Concrete Pad
Unloading Area
Truck Unloading Concrete Pad
Stained Soil
Treatment Cylinders
RCRA
No
No
No
No
No
No
STATUS
A
A
A
A
?
A
DATE
1907
1907
	
	
_____
1907
CAPACITY
270,000 gal
(60'dx20'h)
Unknown
	
	
	
Six Cylinders
RELEASE
Yes
Yes
Yes
Yes
Yes
Yes
COMMENTS
Closed circular concrete
tank; stains observed
around tank.
Approximately 50% of ground
surface stained black. 1800-
2000 gal . of creosote not
recovered during spill
6/23/88. Soil sampling
found elevated levels of 5
metals, volatile organics,
PCP and 7 constituents of
of creosote.
Spills have occurred 2/79,
1/82, 9/83.
Staining visibly. Elevated
levels of 3 metals,
polynuclear aromatic
hydrocarbons and volatile
organics were found in
soil samples.
A pile of visibly stained
soil and gravel.
Visibly stained and high
potential for a release.

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                                                TABLE A  (continued)

  SOLID  WASTE MANAGEMENT  UNITS AND AREAS OF CONCERN AT KOPPERS, CO. INC., NORTH LITTLE ROCK,
UNIT
Areas of Concern:
Visual Evidence of Offsite
Contamination
RCRA
No
STATUS


DATE


CAPACITY


RELEASE
Yes
COMMENTS
Visible evidence of stain-
ing around perimeter of
facility. Soil sampling
found elevated levels of 6
metals and elevated levels
of 15 constituents of
creosote.
(1)  From:   Kearney,  A.T., Inc.,  1986,  PR/VSI  Report  for  Koppers  Company,  Inc. North Little  Rock  Arkansas:
            report prepared for U.S.  EPA Region  VI, 65p.

(2)  Regulated under  Subtitle C of RCRA

(3)  I = Inactive
     A = Active

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On July 23, 1987, ADPC&E issued a notice of intent to Koppers to
deny the Part B Application for failure to submit a technically
complete Permit Application.  The final decision to deny the Part
B Application was issued on September 30, 1987.  Koppers petitioned
ADPC&E to delay the effective date of the denial.  ADPC&E and Koppers
have subsequently agreed to a new effective date of September 1, 1988.
In so doing, Koppers has agreed to a consent Administrative Order on
January 18, 1988.  This order commits Koppers to obtain an approved
closure plan and to pay fees resulting from the review of closure
plans by ADPC&E.  At the time of this update no final closure plan
had been approved.

A draft §3008(h) Administrative Order has been prepared by EPA Region VI
and comments are being solicited.  It is scheduled for final issu-
ance in FY88.

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  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
     HAZARDOUS WASTE GROUND-WATER TASK FORCE
        GROUND-WATER MONITORING EVALUATION
KOPPERS COMPANY, INC., NORTH LITTLE ROCK, ARKANSAS
                WALTER R. HELMICK
                  RCRA GEOLOGIST
         US EPA REGION VI, DALLAS,  TEXAS

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                                CONTENTS

                                                                   PAGE

EXECUTIVE SUMMARY

     INTRODUCTION	    2
     SITE BACKGROUND	    6
     SUMMARY OF FINDINGS AND RECOMMENDATIONS	    8

TECHNICAL REPORT

     INVESTIGATION METHODS	    14

        Records/Documents Review	    14
        Task Force Inspection	    15
        Laboratory Evaluations	    15
        Ground-Water and Lagoon Sampling
          and Analysis	    16

     FACILITY BACKGROUND

        Location and Land Use	    22
        Regul atory Hi story	    24

     WASTE MANAGEMENT OPERATIONS

        Facility Operations	    27
        Interim Status Regulated Uaste
          Management Units	    28
        Other Sources of Possible Ground-Water
          Contami nati on	    29

     SITE HYDROGEOLOGY

        Local Physiography and Pedologic Units	    31
        Geol ogy	    33
        Hydrol ogy	    43

     GROUND-WATER MONITORING SYSTEM UNDER
       INTERIM STATUS

        Monitoring Well Placement	    52
        Monitoring Well Construction and Completion	    53
        Sampling Collection and Handling Procedures	    56

     MONITORING DATA ANALYSIS FOR INDICATIONS
       OF WASTE RELEASE

        Koppers Company Data	    60
        Task Force Data	.	    63

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                                                              PAGE


REFERENCES	    65


APPENDIX A:   BORING LOG B-l	    A-l

APPENDIX B:   MONITORING WELL LOGS FOR
             WELLS Rl, R2, R5, R6, and MIC	    B-l

APPENDIX C:   FORMS:  FIELD DATA SHEET FOR GROUND-WATER
             SAMPLING, FORM FOR ANALYTICAL INSTRUCTIONS,
             CHAIN OF CUSTODY RECORD	    C-l

APPENDIX D:   ON-SITE EVALUATION OF AMERICAN INTERPLEX
             CORPORATION	    D-l

APPENDIX E:   TABLES AND CORRESPONDENCE PRESENTING
             SAMPLING DATA FROM THE OFF-SITE
             DOMESTIC WELLS	    E-l

APPENDIX F:   EVALUATION OF QUALITY CONTROL ATTENDANT
             TO THE ANALYSIS OF SAMPLES FROM THE
             KOPPERS FACILITY, ARKANSAS and
             TABLE OF TASK FORCE DATA	    F-l

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                                FIGURES

                                                                   PAGE


1.  Vicinity flap, North Little Rock, AR	     23

2.  The State of Arkansas and the Location
      of Koppers Co., Inc	     32

3.  Plan of Soil Sampling Locations	     36

4.  Plan of Monitoring Well Locations	     37

5.  Water-Level  Map of the Alluvial Aquifer in
      Eastern Arkansas, Fall 1985	     44

6.  Water-Level  Map of the Alluvial Aquifer in
      Eastern Arkansas, Spring 1985	    45

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                                   TABLES


                                                                     PAGE

  1.  Task Force Sample Collection and Sample Location
        Description	     17

  2.  Preferred Order of Sample Collection, Bottle Type
        and Preservative List	     21

  3.  Boring Data	     34

  4.  Monitoring Well Data	     40

 5A.  Ground-Water Elevations,  1981 and 1982	     47

 58.  Ground-Water Elevations,  1983 Through 1986	    48

E-l.  Local Domestic Well Information, North Little
        Rock Plant	    E-l

E-2.  Local Domestic Well Sampling Data	    E-2

E-3.  Koppers Company Inc.,  North Little Rock, AR,
        Residential Well Analyses - Sampling Date:
        May 6, 1985	    E-5

F-l.  Summary of Concentrations Found in Low Level
        Ground-Water and Sampling Blank Samples
        at Site #31, Koppers, Arkansas	;	    F-16

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o
CO
c:

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                            INTRODUCTION
     Concerns have recently been raised by Congress and the public about
whether hazardous waste treatment, storage, and disposal facilities (TSDFs)
are complying with the ground-water monitoring requirements promulgated under
the Resource Conservation and Recovery Act (RCRA).*  The ability of existing
or proposed ground-water monitoring systems to detect contaminant releases
from waste management units has been questioned.
     The Administrator of the Environmental Protection Agency (EPA) established
a Hazardous Waste Ground-Water Task Force (Task Force) to evaluate the level
of compliance with ground-water monitoring requirements at TSD facilities
and to address the cause of any noncompliance.  The Task Force for this
facility was comprised of personnel from the EPA Office of Solid Waste and
Emergency Response (OSWER), EPA Regional office, and the State regulatory
agency.
     Fifty-nine TSD facilities were scheduled for compliance inspections of
their ground-water monitoring systems.  In most cases, the facilities chosen
for compliance inspections are commercial off-site TSD facilities.  However,
a few noncommercial facilities were also chosen for evaluation.  The Koppers
Company, Inc. facility at North Little Rock, Arkansas is one of the noncommer-
cial facilities and it is the subject of this project report.  It is the
fifth facility inspected in Region VI and it was a regional-lead inspection.
     Regulations promulgated under RCRA address hazardous waste management
     facility operations, including ground-water monitoring, to ensure that
     hazardous waste constituents are not released to the environment.
                                    -2-

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     The principal objective of the inspection at Koppers was to determine
compliance with the requirements of 40 CFR Part 265, Subpart F - Ground-Water
Monitoring and the Hazardous and Solid Waste Amendments (HSWA) of 1984.
Also, the ground-water monitoring described in the RCRA Part B permit
application for the Koppers facility was evaluated for compliance with part
270.14(c).
     Specific objectives of the investigation were to determine if:

     1.  The ground-water assessment program is adequate and evaluate whether
         the ground-water monitoring system meets the requirements of this
         program.
     2.  Designated RCRA monitoring wells are properly located and
         constructed.
     3.  Koppers is following an adequate ground-water sampling and analysis
         plan.
     4.  Required analyses have been conducted on samples from the detection
         and assessment monitoring well system.
     5.  Record keeping and reporting procedures for ground-water monitoring
         are adequate.
     6.  Characterization of the vertical and horizontal strata under of the
         site is adequate.
     7.  Analytical laboratories utilized by the facility are capable of
         providing reliable analytical results.

     The objectives were accomplished by conducting a Preliminary
Reconnaissance Inspection and a Full Field Inspection.  The Preliminary
Reconnaissance Inspection was conducted July 10, 1986 and the full Ground-
Water Task Force Inspection at the Koppers facility began Tuesday, July 22,
1986, and ended Thursday, July 31, 1986.
                                    -3-

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     Examples of the types  of information  requested  of Koppers  for  the  Task
Force inspection included:

     1.  Past activities  and uses,  including identification  of  prior
         releases of hazardous materials,  at units that have received or  are
         receiving wastes.
     2.  Types and volumes  of waste received and  disposal  locations.
     3.  Man-made barriers  to the release  of hazardous waste constituents.
     4.  Site and local  geology including  cross-sections,  drill  logs, and
         potentiometric  maps.
     5.  Ground-water hydrology including  flow directions, rates,  pathways
         (natural and man-made) and hydraulic relationships  between aquifers,
     6.  Monitoring well  locations  and  construction.
     7.  Sampling plan,  chemical  parameters, and  chain-of-custody  control,
         collection procedures (including  handling)  and equipment.
     8.  Analysis plan,  procedures, data management, and QA/QC  controls of
         the laboratory(ies).
     9.  All  the existing water quality data from ground-water  monitoring.
    10.  Extent of ground-water contamination resulting from previous
         operations at the  site.
    11.  Current and planned corrective actions.
                                    -4-

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                          Inspection Participants
                      (July 22 through July 31, 1986)

EPA Headquarters:  Roy Murphy (Safety Officer)
EPA Region VI:
EPA contractor:
Julie Wanslow (Regional Team Leader)
Lauren Heffleman (Document Control Officer)

Richard J. Deluca (Monitoring Specialist Leader)
Sharon Secovich
Mark Lewis
Koppers Co. Inc.:
Dick Blankenbeker (Plant Manager)
Charles P. Brush, P.E. (Program Manager-Hazardous Waste Affairs)
David Kerschner (Manager-Environmental Regulatory Programs)
David L. King (Regional Environmental Supervisor)
Ronald M. Morosky, P.G. (Hydrogeologist-Environmental Resources)
Mark Stolki (Production Supervisor)
Steven Rodel (Senior Environmental Technician)
Arkansas Department of Pollution Control  and Ecology:
                   Jim Rigg (Geologist)
                                    -5-

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                          SITE BACKGROUND

     The Koppers Company,  Inc. is a 155 acre facility which generates,
treats and stores hazardous waste associated with wood treatment
activities.  The facility  is located at 2201 Edmonds Street in North
Little Rock, Arkansas; a suburb of Little Rock.   The current mailing
address, telephone number  and EPA facility identification number are
as follows:
     Address:  Koppers Company Inc.
               Forest Products Group
               P.O. Box 15490
               North Little Rock, Arkansas  72231
     Telephone:  (501) 945-4581
     EPA Identification Number:  ARD006344824
     The Plant Manager is  Mr. Dick Blankenbeker

     The site is located on the flat geomorphic floodplain
approximately one mile north of the Arkansas River.  The geologic
materials immediately underlying the facility consist of approximately
97 feet of alluvium.  This alluvium is predominantly fine sand, silt
and clay near the surface  but grades into coarse sands arid gravels near
the base.
     The area is densely populated with over 45,000 people residing within
a four mile radius and 1,500 people within a one-half mile radius of the
facility.  There is no known current use of ground-water as a drinking
water supply downgradient of the facility and north of the Arkansas
River.  Eight domestic water wells have been identified within one mile
of the facility but these are used for such activities as washing cars
and watering lawns and gardens.
     The facility pressure treats wood products  (primarily railroad
ties) with creosote and oil mixtures.  The hazardous wastes produced by
this facility consist of bottom sediment sludge  from the treatment of
wastewaters from wood preserving processes that  use creosote.  A second
category of waste is waste creosote (U051).  Pentachlorophenol  (PCP)
and chromated copper arsenates  (CCA) have also been used in the past to"
treat wood.  The site has been  in continuous operation since  1907.
                                  -6-

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     The only RCRA regulated land disposal units at the facility are
two surface impoundments; the upper and lower lagoons.  These units
biologically treat wastewater from the wood preserving process prior to
NPDES discharge.  One ground-water monitoring system is in place for
both lagoons.  These lagoons are approximately seven feet deep and are
constructed of earthen material with no constructed liner.  The upper
lagoon is approximately 80 feet by 100 feet and is equipped with
aerators.  The lower lagoon is approximately 80 feet by 200 feet.  The
two lagoons are separated by a wooden spillway.  Both lagoons were
constructed in 1975 and plans have been made to close them by November
1988.
     The interim status ground-water monitoring program at Koppers
began in November 1981, with the installation of four monitoring wells
(R1-R4).  On Hay 1, 1984, an Administrative Order under §3008(a) was
issued against the facility partly in response to inadequate ground-
water monitoring and assessment.  As a result of the order a new
upgradient well (R5) and two new downgradient wells (R6 and R7) were
installed.  Koppers had also failed to analyze ground-water samples for
all parameters required under 40 CFR §265.92 and failed to collect the
proper number of replicate samples as required in 40 CFR §265.93(2).
An accelerated monitoring program was initiated to satisfy these defi-
ciencies in the detection monitoring program.  Ground-water samples from
a domestic well downgradient of the facility were analyzed and found to
contain constituents of creosote.  As a result a §3013 Administrative
Order was issued on February 4, 1985.  The data collected from the
first quarter of 1985 under the accelerated sampling program found
significant increases in contaminants in downgradient wells.  These
increases, as well as information gathered pursuant to the §3013 Order,
triggered the facility from detection monitoring into assessment monitoring
and required development of an assessment plan.
     The assessment plan proposed that 35 wells be installed both within
and outside the boundaries of the facility.  At the time of the Task Force
inspection, only 17 of the 35 wells had been installed and these were all
located on Koppers' property.  Also, no ground-water samples had been
collected from these new wells.
                                  -7-

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                SUMMARY OF FINDINGS AND RECOMMENDATIONS

     The findings and recommendations presented in this report reflect
the conditions existing at the facility and practices used by the
facility personnel at the time of the Task Force investigation in July
1986.  Subsequent actions taken by the facility, the State, and Region
VI since the investigation are summarized in the accompanying report
update.
     According to Koppers, the facility has already established that
releases to ground water have occurred.  The results of analyses of
ground-water samples collected during the Task Force inspection confirmed
the presence of commonly occurring components of creosote in the ground
water.  These Task Force results have also added to the list of these
components that have been detected.  Seventeen common components of
creosote were identified in the Task Force ground-water samples.
Chlorinated dioxins and furans were also identified in the Task Force
samples.
     Numerous deficiencies were found during the Task Force evaluation.
These deficiencies are outlined below.  For a complete discussion of all
deficiencies found by the Task Force the reader is referred to the
appropriate sections in the text of the technical report.  Following
the list of deficiencies is a list of recommendations that are offered
to improve the present assessment monitoring program and any future work
to be done at the facility.

Regulatory Deficiencies

1.  The facility has failed to identify the uppermost aquifer and aquifers
    hydraulically interconnected beneath the facility property, including
    the ground-water flow direction and rate.  This is a regulatory re-
    quirement under 40 CFR Section 270.14(c)(2) and a technical require-
    ment of the §3013 Order.  This deficiency is a result of the lack of
    characterization of the vertical and lateral extent of the alluvial
    sediments underlying the site.  This characterization should include an
    evaluation of the vertical and lateral extent of the underlying clay zone,
                                  -8-

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    A demonstration is needed to determine if the clay provides only limited
    hydraulic interconnection between the overlying alluvial sediments and
    underlying shale.  Ground-water flow direction and rate needs to be de-
    termined for all parts of the alluvial section and any interconnected
    aquifers.  (Reference the Site Hydrogeology Section of the Technical
    Report)

2.  The facility has failed to determine the rate and extent of migration
    of hazardous waste or hazardous constituents in the ground water.  This
    determination is required in 40 CFR §265.93(d)(4)(i) and in §270.14(c)(4),
    This determination was further stipulated in the §3013 Order.  (Reference
    the Ground-water Monitoring System Under Interim Status Section of the
    Technical Report)

3.  The facility has used detection limits for lead which were above the
    Interim Primary Drinking Water Standards (IPDWS).  Thus, values that
    were actually above the IPDWS have not properly been reported.  These
    standards are specified in 40 CFR §265,  Appendix III and it is a re-
    quirement of §265.92(b)(l) in accordance with §265.92(c)(l).
    (Reference the Sample Collection and Handling Procedures Section of
     the Technical  Report)

4.  The facility has failed to measure ground-water elevations to a suitable
    accuracy to determine ground-water flow directions and rates as required
    under §265.91(a)(l),  (a)(2) and §270.14(c)(2).  (Reference the section
    on Groundwater Monitoring System Under Interim Status)

5.  The facility has failed to evaluate ground-water elevation data for
    temporal  variations when establishing flow directions.  Ground-water
    flow directions and rates must be properly determined as required
    under §265.91(a)(l),  (2) and §270.14(c)(2).  (Reference the section on
    Groundwater Monitoring Systems Under Interim Status)
                                  -9-

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Technical Deficiencies

1.  Monitoring well  Rl has the annular space, above the seal,  filled with
    an inappropriate "backfill" material.  This backfill  could provide a
    pathway for downward migration of contaminants and could itself have
    been contaminated.

2.  Monitoring well  R6 was drilled into and is partially screened in a
    zone of potentially contaminated fill material.  This well is poten-
    tially providing samples that are not representative of the ground
    water at that location.

3.  Monitoring wells have not been properly constructed or developed
    to provide low turbidity ground-water samples.

4.  The facility has failed to measure the total  depth of the monitoring
    wells prior purging.  This measurement is required to determine the
    volume of water to be evacuated and to ensure that the well is not
    silting.

5.  The facility has failed to provide for the detection and sampling
    of light or dense phase immiscibles in monitoring wells.

6.  The facility has failed to collect field blanks.  The high proba-
    bility of air emissions from waste management and treatment areas
    contaminating sample containers makes this a necessary quaTity con-
    trol measure.
                                   10

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7.  The facility has not reported adequate aquifer-testing data (from the
    pump tests or slug tests) or performed suitable calculations on the
    data to determine values for in situ permeabilites and flow rates.
    The facility has failed to perform any aquifer tests on deeper portions
    of the aquifer below 25 feet.

8.  Numerous deficiencies were noted during the Task Force inspection of
    the laboratory used by Koppers for analysis of ground-water samples.
    These deficiencies included problems in methodologies, quality
    assurance and laboratory administration.  It is the responsibility
    of the facility to ensure that analytical data submitted to satisfy
    regulatory requirements meets established analytical criteria.

Task Force Recommendations

1.  The facility needs to initiate a boring program to evaluate the
    lateral and vertical extent of unconsolidated sediments beneath
    the site.  This should include the alluvial deposits and the
    underlying clay.  If the clay zone is not a suitable confining
    layer, than the boring program should be expanded to include the
    underlying shale bedrock.

2.  Koppers needs to further evaluate the ground-water flow directions
    beneath the facility.  Monitoring wells or piezometers should be
    installed in order to gain added details on ground-water flow direc-
    tions and temporal variations in these directions.

3.  Koppers needs to expand the monitoring well system in order to
    determine vertical and lateral extent of any plume or plumes of
    contamination from the facility.  The rate and direction of move-
    ment of any plume of contamination needs to be evaluated.
                                  -11-

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 4.  Monitoring well  Rl should be properly plugged,  abandoned
     and replaced with a properly constructed well.   The four pre-RCRA
     monitoring wells and the "deep" or "withdrawal" well  should also be
     properly plugged and abandoned.

 5.  All monitoring wells drilled in the future should have a double casing
     design with surface casing installed down to a  suitable depth.
     This is to protect deeper zones from near-surface soil contamination.

 6.  The logging of future wells should include more detailed geologic and
     engineering information.  This information should include descriptions
     of gross mineralogy, degree of weathering, bedding, discontinuities,  de-
     positional structures and strike and dip of bedding.   Atterburg limits
     or grain size analysis should be used to supplement the soil  classi-
     fication system.  Information on the drilling advance rate and  the
     percentage of the samples recovered should also be logged.

 7.  All wells should be redeveloped to attempt to reduce  the amount of
     turbidity in water samples.  A block and surge  method is recommended
     for redevelopment of the wells.  Future wells should  have filter
     packs and screens designed on a well by well  basis.

 8.  To minimize possible contamination, the use of  methylene chloride in
     sample bottle and bailer cleaning should be discontinued.

 9.  The filtering of all samples should be discontinued.   Samples should
     be filtered only as required in a specific analytical  method.  If a
     filtered sample is desired for dissolved metals the filtering should
     be done at the monitoring well.  The samples collected for total
     metals analysis should not be filtered.

10.  The facility needs to evaluate the existing monitoring wells  for
     damage to the PVC screens and casing by creosote.  Consideration
     should be given to using stainless steel screens and  casing in  all
     in all future wells.  Wells with PVC components that  exhibit  damage
     by exposure to creosote should be replaced with stainless steel.

                                   -12-

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TECHNICAL   REPORT

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                         INVESTIGATION METHODS

     The Task Force investigation of the Koppers Company, Inc. facility
consisted of:

     0  Reviewing and evaluating records and documents from EPA Region
        VI, Arkansas Department of Pollution Control and Ecology (ADPC&E),
        and Koppers Company, Inc.

     0  Conducting a preliminary reconnaissance inspection July 10, 1986
        and a full-facility inspection July 22 through July 31, 1986.

     0  Evaluating on-site and off-site analytical  laboratories.

     0  Sampling and analyzing data from selected ground-water
        monitoring wells and wastewater treatment lagoons.
Records/Documents Review

     Records and documents from EPA Region VI and ADPC&E offices, compiled by
an EPA contractor, were reviewed prior to and during the on-site inspection.
Additional ADPC&E records were copied and reviewed by Task Force personnel
concurrently with the reconnaissance inspection.  On-site facility records
were reviewed to verify information currently in Government files and to
supplement Government information where necessary.  Selected documents
requiring in-depth evaluation were requested from the facility by the Task
Force during the inspection.  These documents were provided by Koppers upon
request.  Records were reviewed to obtain information on operations,
construction details of waste management units and the ground-water
monitoring program.
     Specific documents and records that were reviewed included the ground-
water sampling and analysis plan(s), the RCRA Part B Application, analytical
results from past ground-water sampling, monitoring well construction data
and logs, site geologic reports, site operational plans, facility permits,
                                  -14-

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designs of waste management units, and position descriptions and
qualifications of selected personnel and operating records showing the
general types, quantities and locations of wastes disposed at the facility.

Task Force Inspection

     Inspection activities conducted in July 1986 included identifying waste
management units (past and present), waste management operations, pollution
control practices, surface drainage routes, verification of the location of
ground-water monitoring wells, and sampling and analysis of the groundwater
and lagoon contents.
     Company representatives were interviewed to identify records and
documents of interest, discuss the contents of the documents, and explain
(1) facility operations (past and present), (2) site hydrogeology,
(3) the ground-water monitoring system, (4) the ground-water sampling and
analysis plan, and (5) laboratory procedures for obtaining data on ground-
water quality.
     The procedures used by the Task Force followed the EPA "Hazardous
Waste Groundwater Task Force Protocol for Ground-Water Evaluations"
(1986).  These procedures included the use of individual log books to
record information obtained in the field and information obtained
from discussions with site personnel.  Photographs were taken by the
Task Force during the inspection to supplement the log books.

Laboratory Evaluations

     The on-site laboratory and off-site laboratories handling ground-
water samples were evaluated regarding their respective responsibilities
under the Koppers ground-water sampling and analysis plan.  Analytical
equipment and methods, quality assurance procedures and records were
examined for adequacy.  Laboratory records were inspected for complete-
ness, accuracy and compliance with State and Federal requirements.  The
ability of each laboratory to produce quality data for the required
analysis was also evaluated.
                                  -15-

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Ground-Water and Lagoon Sampling and Analysis

     During the inspection Task Force personnel  collected samples for
analysis from 17 ground-water monitoring wells (Table 1) to determine
if the ground water contains hazardous waste constituents and to verify
previous sampling data.  One sample from each of the two lagoons was
also taken.
     Sampling locations were selected based on past monitoring records,
well logs, and hydrogeologic reports.  The lagoon samples were taken
to determine the type and concentration of potential contaminants that
these lagoons could contribute to ground water.
     All samples were collected by EPA contractor personnel with splits
of selected samples being provided to the facility and State.  The
wells were sampled with 1.66-inch (OD) Teflon® bailers with Teflon coated
stainless steel cable.  Samples were collected from the wells using the
following protocol:

     1)  EPA contractor personnel monitored open well head for chemical
         vapors and radiation.
     2)  EPA contractors, accompanied by Koppers personnel, determined
         depth to ground water and total depth using an interface probe.
     3)  EPA contractor personnel calculated height of water column.
     4)  EPA contractor personnel calculated three casing volumes.
     5)  EPA contractor personnel purged the calculated three casing
         volumes.  Purge water and excess sample water were placed in
         drums, then disposed by Koppers personnel.
     6)  Samples were collected with a bottom-filling Teflon bailer supplied
         by the EPA contractors.
® Registered trademark of E.I. DuPont de Nemours and Co,
                                  -16-

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                                                         TABLE 1

                               TASK FORCE SAMPLE COLLECTION AND SAMPLE  LOCATION DESCRIPTION
   SAMPLE
                     SAMPLING
DATE
  TIME
       REMARKS
         LOCATION/DESCRIPTION
    WELL

    R-5
    R-5B

    R-6
    R-2
    M-2A
    M-2B

    M-2C


    M-4A
7/23
7/23

7/23
7/23
7/23
7/23

7/23


7/24
0835-0850
0904-0922

1012-1027
1055-1110
1205-1228
1343-1400

1410-1423


0800-0830
Purge water silty and
reddish in color.  Turb.
>100 NTU.
Turb. > 100 NTU

Purge water silty, slightly
foainy, black in color with
an oil sheen.  Turb. > 100
NTU

Purge water silty with
brownish color.  Turb. >
100 NTU.

Purge water lightly turbid
with brownish color.  Turb.
> 100 NTU.  First field
blank prepared.

Turb. 60 NTU.

Turb. > 100 NTU.  All
samples sent to labs.

Somewhat turbid (100 NTU) -
brown color
Approx. 130'"' N of Lagoon 2.  Upgradient of
lagoons; down and cross gradient of old land
treatment areas (spray fields).  Part of 3-well
cluster.
On SE corner Lagoon 1.  Downgradient of lagoons;
down and cross gradient of the old land treatment
areas (spray fields).
Approx. 50' W of SW Corner of Lagoon 1.  Downgradient
of lagoons; down and cross gradient of the old land
treatment areas (spray fields).

Approx. 200' W of SE corner of the facility, near
entrance gate.  Downgradient of lagoons and drum
storage area; down and across gradient of old
land treatment areas (spray field); 3-well cluster.
Approx. 60' from SE property line and 500' from SW
corner of facility.  Downgradient of lagoons and
drum storage area; downgradient of old land
treatment area (spray field); 3-well cluster.
(1)  Distances  are only approximate  due  to questions  concerning map  scales.

                                                            -17-

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                                                 TABLE 1,  continued

                            TASK FORCE SAMPLE  COLLECTION AND SAMPLE LOCATION DESCRIPTION
SAMPLE
                  SAMPLING
DATE
  TIME
       REMARKS
                                                                         LOCATION/DESCRIPTION
WELL

M-4B
 M-4C

 M-3A
 M-3B
              7/24
          0910-0835
7/24

7/24
1035-1052

1207-1222
7/24
1305-1325
 M-5A
 M-5B
7/25
7/25
0823-0844
0920-0950
Purge water foamy and
grayish.  Turb. = 7 NTU at
1:1 solution with DI water.
Duplicate samples taken.

Turb. 60 NTU.

Turb. > 100 NTU
Turb. 80 NTU.  Trip blank
and equipment blank
prepared.  All  samples
sent to lab.

Water turbid (>100 NTU) and
brown in color.
Turb. > 100 NTU.  Second
field blank prepared.
                                         Approx. 60'  from SE property line and 500" from SW
                                         corner of facility.  Downgradient of lagoons and
                                         drum storage area; downgradient of old land
                                         treatment area (spray field); 3-well cluster.
                                                                Approx. 100' S of treatment area; 550' from SE corner
                                                                and 900' from SW corner.  Downgradient of lagoons
                                                                and drum storage area; down and cross gradient of old
                                                                land treatment areas (spray field), down gradient of
                                                                drip track and treatment areas; 3-well cluster.
                                                                Approx. 100' from SW corner.  Downgradient of lagoons
                                                                and of old land treatment area (spray field); 3-well
                                                                cluster.
                                                           -18-

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                     TABLE 1, continued



TASK FORCE SAMPLE COLLECTION AND SAMPLE LOCATION DESCRIPTION
SAMPLE
WELL
M-1A








M-1B

M-1C

Lagoon
#1
(upper)
#2
(lower)

SAMPLING
DATE TIME

7/25 1203-1242








7/25 1330-1351

7/28 0815-0839


7/28 0916-0933

7/28 1018-1036


REMARKS

A very thick, dense oily
phase occurs in this well.
Somewhat soluble but dense
phase was evident on the
bottom. Sampled first
prior to boiling. Unable
to fill two sample bottles
(dioxin and one of the
extras).
Turb. > 100 NTU. All
samples shipped.
Turb. > 100 NTU. Duplicate
samples taken

Turb. >100 NTU. (lagoon
has bottom aeration only)
Turb. >100 NTU. (lagoon
has bottom aeration and
sprayers)
LOCATION/DESCRIPTION

Approx. 130' SW of the SW corner of Lagoon 1. Down-
gradient of lagoons and old land treatment area
(Spray field); 3-well cluster.






M

ii


Approx. 9" from W bank of lagoon opposite telephone
pole; depth of lagoon is 4.0'.
Approx. 9' from S bank of lagoon, opposite discharge
line.

                               -19-

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7)  A sample aliquot  was  collected  and field  measurements  (water
    temperature, pH,  specific conductance,  turbidity)  taken.
8)  EPA contractor, using alternating methods,  filled  sample  containers
    in the order shown in Table 2.
9)  Samples were then placed on ice in an  insulated  container and  taken
    to the EPA staging area.

     When sampling was completed at each well,  the samples  were taken
to the EPA staging area.   Metals, TOC, phenols, cyanide, nitrate  and
ammonia samples were  appropiately preserved (Table 2).
     Leachate samples were all  collected and  shipped the same day  to
prevent possible cross contamination through  handling  with  other  well
samples and shipping.  These samples were  considered to be  of medium
hazardous concentration and were shipped according to  DOT  regulations.
All EPA contractor personnel wore Tyvek® protective  clothing.  Plastic
sheeting was laid around  each sampling point  in order  to prevent  area
contamination in case of  spillage.
     Two field blanks for each analytical  parameter  group  (e.g.,
volatiles, organics,  metals) were prepared near monitoring  wells  M2A
and M5B so as to represent field conditions.   One equipment blank  was
prepared at the facility  by running distilled,  deionized water through
a precleaned bailer.   One set of trip blanks  for each  parameter group
was also prepared.  The blanks were submitted to the EPAs  lab as  samples
with no distinguishing labeling or  markings.
     The samples and  blanks were packaged  and shipped  to two EPA  contract
laboratories, as environmental  samples, in accordance  with  Department
of Transportation (DOT) regulations (40 CFR Parts 171-177).
     Samples were analyzed by EPA contractor  laboratories  (Centec,
Salem, WA for inorganics; Compu/Chem, Research Triangle Park, N.C. for
organics) for the parameters shown  in Table 2.   An analysis of the
sample results will follow.
                                  -20-

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                                                      TABLE 2
                                        PREFERRED ORDER OF SAMPLE COLLECTION
                                         BOTTLE TYPE AND PRESERVATIVE LIST
               PARAMETER
BOTTLE
PRESERVATIVE
 1.  Volatile Organic Analysis (VOA)
         Purge and Trap
         Direct Inject
 2.  Purgable Organic Carbons (POC)
 3.  Purgable Organic Halogens (POX)
 4.  Extractable Organics
 5.  Pesticide/Herbicide
 6.  Dibenzofuran/Dioxin
 7.  Total  Metals
 8.  Dissolved Metals
 9.  Total  Organic Carbon (TOC)
10.  Total  Organic Halogens (TOX)
11.  Phenols
12.  Cyanide
13.  Sulfate/Chloride
14.  Nitrate/Ammonia
2 - 60-ml VOA vials
2 - 60-ml VOA vials
1 - 60-ml VOA vial
1 - 60-ml VOA vial
4 - 1-qt. amber glass
1 - 1-qt. amber glass
1-qt. amber glass
1-qt. plastic
1-qt. plastic
4-oz. glass
1-qt. amber glass
1-qt. amber glass
1-qt. plastic
1-qt. plastic
1-qt. plastic
    HNO-
    HNO-
    H2S04
    NaOH
                                                   -21-

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                          FACILITY BACKGROUND
Location and Land Use

     The Koppers Company, Inc. facility is an existing wood preserv-
ing facility that generates, treats and stores hazardous waste onsite.
The facility began operation in 1907 as the Ayer and Lord Tie Company.
Koppers Company acquired Ayer and Lord in 1930.  The property boundary
of the facility has remained essentially the same since 1907.  The plant
is presently part of the Koppers Company Forest Products Division.
     The facility is located at 2201 Edmonds Street in North Little
Rock, Pulaski County, Arkansas and occupies an area of approximately
155 acres (Figure 1).  The midpoint of the facility is at 34°46'03"
Latitude and 92°13'22" Longitude (Township 2 North, Range 11 West in
the southwest quadrant of Section 29 and the northwest quadrant of
Section 32).  Access to the facility is by road and two railroad spurs;
the Chicago, Rock Island and Pacific Railroad is to the south and to
the north is the Missouri Pacific Railroad.  The intersection of Inter-
state Highways 40 and 67 is approximately one mile to the northwest.
     Land surrounding the facility has a variety of uses.  To the south
and east of the facility are residential areas consisting predominantly
of single-family dwellings.  The residential areas extend for approxi-
mately 1 mile to the south and there are over 100 residences east of
the facility.  To the north and west, the land is zoned for manufactur-
ing, assembling and fabricating plants.  Several small businesses are
located north of Koppers but the land immediately to the west is not
developed.  A parcel of  land in the southwest corner of the facility,
consisting of approximately two acres, has been leased to the city of
North Little Rock to operate a municipal waste incinerator.  Within a
1.5 mile radius of the facility are 12 churches and 6 schools.  There
are over 45,000 people residing within a four-mile radius, while 1,500
people live within a one-half mile  radius of the facility.
                                  -22-

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J
    MC ALMONT OUAORANOLE
     ARKANSAS-PULAUCI CO.

   SWEET HOME OUAORANOLE
     ARKANSAS—PULASKI CO
  7.5 MINUTE SERIES (TOPOGRAPHIC)
                               Cu«0*M&,.C lOC*1«N
                                 iKEYSTOC
                  SCALE i'-ZOOO*
         FIGURE i


       VICINITY MAP

NORTH LITTLE ROCK.  AR
 KOPPERS COMPANY.  INC.  \C67S57

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Regulatory History

     Waste discharges from the Koppers facility became regulated on
June 2, 1971, with the issuance of both State (#10905-W)  and Federal
(#01716) NPDES discharge permits.  These permits address  discharges
into an unnamed ditch (Outfall 001) which drains westward from the
facility and into the Redwood Tunnel  Ditch.  This ditch receives run-
off from the areas of the surface impoundments, the Tank  Farm Area, the
Drip Track Area and Lumber Storage Areas.
     Koppers supplied the EPA, Region VI with a Notification of Hazardous
Activity on August 18, 1980.  The Part A Application was  then filed in
November 1980, when the RCRA interim status regulations went into effect.
The interim status ground-water monitoring program began  in November 1981
and Koppers installed monitoring wells Rl through R4.  RCRA inspections
in March 1981, January 1982 and September 1983 were conducted by ADPC&E
inspectors.  The last two inspections found violations regarding con-
tainer storage, information retained in the operating record, the contin-
gency plan, and the integrity of the dike between the two surface impound-
ments.  A CERCLA Preliminary Assessment Inspection on July 7, 1981 was
followed by a sampling inspection on November 11, 1981.  These inspec-
tions found evidence of releases of creosote and its components.
     Subsequent to a Compliance Monitoring Inspection by EPA Region VI
personnel on February 21, 1984, an Administrative Order was served on
May 1, 1984.  This RCRA §3008(a) order was issued in response to inade-
quacies identified in the ground-water monitoring system, ground-water
assessment program, reporting procedures and closure plan.  The Consent
Agreement and Final Order became effective on December 14, 1984.  This
agreement assessed a penalty of $17,800 and required the facility to
install new monitoring wells and submit the necessary ground-water
quality data.  Monitoring wells R5 through R7 were installed in November
of  1984 in response to this order.
     A §3013 Order was issued to Koppers on February 4, 1985.  This
order was issued  in response to analytical results from the sampling of
groundwater from  the Mrs. C. C. Smith Well, located one-half mile down-
                                  -24-

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gradient from the facility.  The well is located on private property
and the owner had observed that the well water had an unusual odor and
an oily appearance.  A sample, collected on July 5, 1984, by the North
Little Rock Health Department, revealed that eleven components of creo-
sote were in the water.  Three of these components were positively iden-
tified as acenapthene, napthalene and phenanthrene.  A subsequent samp-
ling on August 30, 1984 of the same well by ADPC&E personnel found eleva-
ted concentrations of napthalene and acenapthene.
     The §3013 Order required that the facility prepare and implement
a ground-water assessment plan.  The object of this plan was to outline
the means by which the facility was to determine the extent and magnitude
of any plume of contamination.  This plan was to include contamination
both within and outside the facilities boundaries.  It was also to pro-
vide for the determination of the rate and direction of movement of all
contaminantion.  Koppers prepared the ground-water assessment plan in
April and began implementation of the plan in May 1985.
     Personnel from ADPC&E conducted a CERCLA Site Inspection on November
20, 1984.  Samples collected during this inspection found evidence of
creosote contamination in the soils of the marshy area on the southwest
side of the facility.  In response to citizen concerns, an EPA Region
VI Technical Assistance Team visited the site on September 16 and 17,
1985.  This team recommended improvements in security, run-off control
and further sampling for evidence of releases and risk assessment.
     Also, in December 1984, an accelerated sampling program was begun
with Well R5 in the upgradient location.  Statistical analyses performed
on data from the first quarter of 1985 found sixteen statistically signif-
icant changes in concentrations in the downgradient wells.  These changes
triggered the facility into assessment monitoring.
     In response to the assessment program, soil samples and soil borings
were collected in May 1985.  Five nested monitoring wells (Ml through M5),
consisting of 3 wells each, were installed in August.  Two more wells were
also drilled adjacent to R5 in order to make this a 3-well nest.  Koppers
prepared status reports on the assessment programs in February and July
1986.
                                  -25-

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     On June 25, 1986,  EPA met with Koppers to discuss and visually
inspect the proposed locations for the off-site monitoring wells.  They
also discussed revisions to the proposed ground-water quality assessment
program.
     At this tine the facility had been unable to adhere to their proposed
project timetable.  This, in part, was a result of problems of access to
offsite drilling locations.  The Ground-Water Task Force held a reconnais-
sance inspection on July 10, 1986.  This was followed by the full inspec-
tion on July 22 through July 31, 1986.  Since 1985; Koppers has used American
Inteplex Corporation to perform chemical analyses of their ground-water sam-
ples.  A laboratory inspection of the American Interplex Laboratory was
conducted on August 5,  1986, by Region VI staff as part of the Task Force
evaluation.
                                  -26-

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                      WASTE MANAGEMENT OPERATIONS

Facility Operations

     The principal activity at Koppers has been the pressure treatment
of wood using creosote.  At present, railroad ties are the
only wood products being treated but in the past the company has
treated bridge pilings, telephone poles and miscellaneous types of
lumber.  The treated wood products are stored on-site until shipped by
rail to customers.
     Since 1982, the only raw materials used to treat wood have been
creosote and carbon black oil.  In the past Koppers, has used
pentachlorophenol (PCP) and chromated copper arsenates (CCA) in addition
to the creosote and carbon black oil.  PCP was used during the 1960's
until its use was suspended in 1982 while CCA was used during the 1950's
and early 1960's until it was discontinued in 1964.  PCP was used mainly
to treat telephone poles.
     The wood treating processes using creosote generates wastes with
the Waste Codes U051 and K001.  K001 waste is toxic and is derived from
bottom sediment sludge from the treatment of wastewaters from
preserving processes that use creosote and/or pentachlorphenol (PCP).
Waste U051 is unused creosote.  The PCP process generated K001 wastes
but it may have generated F027 waste as well.  The F027 waste is discarded
unused formulations containing PCP.  CCA treatment of wood may generate
wastes containing the hazardous constituents of hexavalent chromium and
arsenic pentoxide.  The PCP and CCA treating processes were analogous
to the creosote treating processes.
     At present, there are three waste streams at Koppers.  The
wastewater treatment system begins with the catchment basin or basement
beneath the treatment cylinders.  This system includes a two-phase API
separator and two surface impoundments.  Residues can be either recycled
or drummed and stored for future off-site disposal.  Wastewater can be
either recycled as a coolant for the plant, sent to a spray field
(discontinued in 1983) or discharged at the NPDES regulated outfall
                                  -27-

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(001).  The second waste stream ends with  a septic  tank  which  leads
from the laboratory and shower house.  The third  stream  is  at  the  drip
track where treated ties are allowed to dry following  treatment  in the
treatment cylinders.
     The details of past waste management  practices are  lacking  but
were probably analogous to the present system.

Interim Status Regulated Waste Management  Units

     There are three RCRA Subtitle C regulated  units at  the Koppers
facility (Figure 3).  The first of these units  is the  Container  Storage
Area which does not require 265 Subpart F  ground-water monitoring.  There
is a low potential for releases to the environment  from  this unit  but
directly west of the unit drums were being stored on sheets of plastic.
This practice could lead to soil contamination  and, in turn, have  an im-
pact on the ground-water.
     The remaining two regulated units at  the facility are  the two
surface impoundments - the upper and lower lagoons.  Both lagoons  require
ground-water monitoring under 265 Subpart  F.  The units  are part of  the
wastewater treatment system where the wastewater  is treated biologically.
Both units use aerators but the lower, or  northern, lagoon  also uses
sprayers.  These lagoons were excavated and constructed  of  earthen
material with no constructed clay or synthetic  liner.  The  lower lagoon
is larger than the upper lagoon and the two have  a  combined capacity of
90,000 gallons.  Both lagoons maintain two feet of  freeboard but the
operating level of the upper lagoon is two feet higher than the lower
lagoon.  The two lagoons are separated by  a divider wall and the flow
from the upper to the lower lagoon is by way of a wooden, rectangular
spillway.  Both lagoons have been operating since 1975 and  plans have
been made to close them by November 1988.
                                  -28-

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Other Sources of Possible Ground-Water Contamination

     The Task Force inspection found numerous other areas that could
possibly contribute to ground-water contamination.  Many of these areas
have exhibited releases of hazardous waste or constituents to soil which
could lead to groundwater contamination.  Other areas could cause releases
directly to ground water or provide a direct conduit to ground water.  These
areas should be investigated for their role as possible contributors of con-
tamination.  The remainder of this section discusses these areas.
     During the inspection, it was found that there were numerous waste
management and production facilities which may have contributed releases
to the environment.  These facilities include, API separators, pre-RCRA
impoundments, driptrack areas, waste storage areas, inactive landfarms,
and tank farm areas.  All of these areas have exhibited possible soil
contamination and may have caused releases of contaminants to the ground
water.
     Four monitoring wells were discovered during the inspection which
the facility identified as pre-RCRA wells.  These wells were installed
in the 1970's and are constructed of four-inch PVC pipe with no pro-
tective casing or locking caps.  Other construction details, past water
level elevations and sampling data were not available from the facility.
Water-level elevations and total-depth measurements were made during
the Task Force inspection.  The total depths ranged from 17.56 to 22.21
feet below the top of casing.  The lack of information on construction
techniques and materials raises concerns that contamination could migrate
downward from the surface or between horizons in the subsurface.  These
monitoring wells should be properly plugged and abandoned.
     Another ground-water well is located north of the surface Impound-
ments that has been referred to as the "withdrawal" or "deep" well.  Depth
and construction details on the well are lacking.  The well is no longer
used but it has not been abandoned and the pump is still on the well.  The
well was used to supply water for fire protection and is located just north
of the surface impoundments.  The lack of information on the quality of
                                  -29-

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annular seals and other construction materials and techniques raises
concerns that the well  could serve as a route for contaminant migration.
This well, too, should  be plugged and abandoned.
     An underground storage tank was located near the Rail  Car Concrete
Pad Unloading Area.  This was a concrete underground tank that has been
closed.  Koppers personnel state that the closure consisted of removing
the sides of the tank but the concrete base was buried in place.  No
sampling of soils was done during the closure process.  Even though
several spills have occurred in the area of this tank, there is no evi-
dence of releases fron the tank itself.  Given the lack of evidence on
the design, construction and maintenance of the tank, it should be con-
sidered as a possible source of contamination.
                                  -30-

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                           SITE HYDROGEOLOGY

Local Physiography and Pedologlc Units

     The Koppers facility is located on the geomorphic floodplain of
the Arkansas River within the Mississippi Embayment of the Gulf
Coastal  Plain.  This floodplain is a complex of modern and abandoned
natural  levees, abandoned meander bends (oxbows), and backswamps.
Topographic relief of the floodplain is very gentle (<0.5%) with the
slope toward the river.
     The topographic relief of the floodplain is in sharp contrast to
the relief of the Interior Highlands.  Approximately one mile northwest
of the facility a fall line separates the Interior Highlands from the
Mississippi Embayment (Figure 2).  The Koppers facility is located in
an area where the Arkansas River floodplain widens after crossing the
fall line.  Northwest of the fall line the strata of the Interior High-
lands are structurally complex and more resistant to erosion.  South
and east of the fall line the Tertiary sediments of the Mississippi
Embayment are weakly lithified and less resistant to erosion.
     The different deposits associated with natural levees, oxbows,
and backswamps on the floodplain has lead to the development of
different soil series (Haley, G. J. and others, 1975).  The urban
complexes of three soil series have been mapped at the Koppers
facility.  The Perry series are clayey soils commonly associated with
backswamp areas.  The Rilla series are fine sand to silt loams usually
found on older natural levees.  The younger natural levees will develop
the fine sand to silt loams of the Keo series.  The Keo and Rill a
series soils have moderate permeabilities and moderate bearing
capacities.  The Perry soils, however, have low permeabilities and are
poorly drained.  The high concentration of smectite* clay minerals in Perry
soils results in a high shrink-swell potential.
* Smectite clay minerals are a group of clay minerals that include mont-
  morillonite, nontronite and saponite.  These minerals tend to swell or
  expand when wetted, both by interparticle and intracrystalline expansion,
                                  -31-

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36
                                            Location of the
                                            Koppers Facility
 Figure  2.   The  State  of  Arkansas  and  the  Location  of
            Koppers  Company,  Inc.

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     Around the  facility,  surface water  drainage  is  either  through
 drainage  ditches  or  into  closed, marshy  areas.  The  western  half  of  the
 site is drained  by a ditch  (the NPDES  001  Outfall) that  leads to  the
 Redwood Tunnel Ditch.  The  Redwood  Tunnel  Ditch eventually  flows  to  the
 Arkansas  River.   Most  of  the eastern half  of the  facility drains  to  a
 marshy area about 1/4  mile  to the east.  Numerous other  wetlands  areas
 have been  identified around the area.  One area of undeveloped  land
 immediately west  of  Koppers, between the Chicago, Rock Island and Pacific
 Railroad  and the  west  flowing drainage ditch, may receive run-off when
 on-site ditches  overflow.

 Geology

     A program of soil borings and monitoring well installation has
 been conducted at the  Koppers facility.  A total of  41 soil  borings
 (Table 3)  have been drilled.  Figure 3 is a map showing  the  location of
 the test  borings  and the  locations proposed for additional borings.
 The borings were made  in May 1985.  The locations for these  borings  are
 concentrated at the Former  Lagoon Area and treatment areas on the
 southwest  side and at  the Past Land Farms  (No. 1 through No. 3) on the
 northeast  side of the  facility.
     Twenty-four monitoring wells have also been installed at the facility,
 Six of these monitoring wells are single wells while 18  are divided  into
 6 sets of  nested wells.  The nested wells are arranged in 3-well configu-
 rations.   Figure 4 shows locations of monitoring wells.  Wells Rl  through
 R4 were drilled in November 1981,  and R5, R6 and R7 were added to the well
 network around the upper and lower lagoons in November 1984.  The nested
wells,  M1A,B and C through MSA, B  and C,  were added in May 1985 around
the lagoons and along the southern boundary of the facility.  Wells R5B
 and R5C were added at the same time to the R5 well to make it a 3-well
nest.
     The logs of these borings and wells  were used to gain some insight
 into the nature of the subsurface  stratigraphy and the uppermost
aquifer.   The facility is sitting  on unconsolidated Quaternary alluvium
deposited  by the  Arkansas River.   Only Boring B-l  (see Appendix A)
                                  -33-

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                              TABLE  3...
                          BORING  DATA11'
                         (All  Depths  in  Feet)
                                                               INTERVAL  OF
SURFACE
# DATE DEPTH(FT) ELEV(FT)
B-l
B-2
B-3
B-4
B-5
B-6
B-7
B-8
B-9
B-10
B-ll
B-12
B-13
B-14
B-15
B-16
B-17
B-18
B-19
B-20
B-21
B-22
(1) From
5-6-85 to
5-8-85
5-8-85
5-8-85
5-8-85
5-8-85
5-9-85
5-9-85
5-9-85
5-9-85
5-9-85
5-9-85
5-9-85
5-9-85
5-10-85
5-13-85
5-13-85
5-14-85
5-9-85
5-10-85
5-10-85
5-13-85
5-13-85
Status Report
116.5
15.0
15.0
15.0
15.0
12.0
12.0
12.0
12.5
12.5
9.0
10.5
20.0
20.0
35.0
20.0
45.0
20.0
15.0
27.5
20.0
30.0
No. 2
256.0
253.0
253.5
254.0
254.0
254.0
253.0
252.5
254.5
253.5
253.5
253.0
257.5
257.0
256.0
255.0
253.0
258.0
258.0
256.5
256.0
253.0
- Groundwater
DRILLING WATER
METHOD DEPTH
SSA &
Wash Rot.
SSA
SSA
SSA
SSA
SSA
SSA
SSA
SSA
SSA
SSA
SSA
SSA
SSA
SSA
SSA
SSA
SSA
SSA
SSA
Shelby Tube,
HSA
Quality Assessment
-
8
5
8
7.5
9
6
4.5
5
6.5
6
7.5
18.0
11.25
-
13.5
10.5
-
-
18.5
—
, Koppers
VISIBLE OIL
CONTAMINATIC
-
-
-
-
0.0-1.0
0.0-1.5
0.0-1.5
0.0-1.5
0.0-1.5
-
-
-
1.5-18.0
2.5-11.2
3.0-13.5
1.0-13.5
3.0-10.5
3.0-12.0
6.0-10.0
4.5-16.0
0.0-12.5
1.0-18.0
Co., Inc.,
North Little Rock, Ark. (July 17, 1986)
                                 -34-

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B-41
                                     TABLE 3, continued



                                     BORING DATA
5-22-85
8.5
257.0
                                                                       INTERVAL OF
BORING
#
B-23
B-24
B-25
B-26
B-27
B-28
B-29
B-30
B-31
B-32
B-33
B-34
B-35
B-36
B-37
B-38
B-39
B-40
DATE
5-20-85
5-15-85
5-14-85
5-14-85
5-15-85
5-16-85
5-15-85
5-16-85
5-20-85
5-21-85
5-17-85
5-17-85
5-20-85
5-20-85
5-22-85
5-21-85
5-22-85
5-22-85
DEPTH (FT)
19.0
35.0
50.0
32.5
15.0
7.5
35.0
20.0
29.0
21.5
10.0
10.0
25.0
25.0
9.5
9.5
12.5
16.5
SURFACE DRILLING WATER
ELEV(FT) METHOD DEPTH
258.0 Shelby Tube, 13.5
HSA
257.5
253.0
257.5 SSA 4
256.5 " 13.5
257.0
254.0
257.0 " 6.0
255.0 Shelby Tube, 11.75
SSA
255.0 Shelby Tube, 11.75
SSA
257.0 Shelby Tube, -
HSA
256.5
257.0
257.5
257.0
257.0
257.5
257.0 Shelby Tube, 4.0
SSA
VISIBLE OIL
CONTAMINATIOI
5.0-11.7
0.0-25.0
0.0-7.0 &
12.0-14.5
2.5-4.0 &
6.0-18.0
1.5-13.5
1.5-4.5
1.5-3.0 &
4.5-18.0
0.0-2.5 &
6.0-7.5
0.0-11.7
1.5-3.2 &
5.2-11.7
0.0-1.5
0.0-2.0
0.0-2.0 &
3.0-20.5
3.5-5.0 &
8.0-20.0
0.0-4.0
0.0-2.0
0.0-2.0
0.0-2.7 &
7.7-12.5
                                         -35-

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                                 Container Storage
               o^"
              V\  O  oo°°0  •"
                     oo
           JSEI
A  H^OXKfP SOrt AWIMT
0
                                          I. LOCATIONS OF POOPOSCO SOTL BOHHSS
                                            Mf
t. onLr
              rtctLirr FT* runts
PLM OF 50fL  SAMPLING
     LOCATIONS
NORTH L ITTlf OOCK.  4/7
        COHP«MY.  IMC fT
                                            Figure  3.   Plan  of  Soil  Sampling  Locations.

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                   General
                   Ground-Water
                   Flow  Direction
                                                                                                                             POOPtttTY
                                                                                                                             BOUNDARY
       *m
   FXISTIHt HtLL
 • o&fsrrc mi
-^ etouwMfln* «o«r oTtrcrrtrt
i. tfpooxrmtrt LOCATIONS OF rmvsto
            *fiis.
                                                                                                                       PLAN OF MONITORING Hflt
                                                                                                                             LOCATIONS
                                                                                                                        NORTH LITTLE OOCK. M
                                                                                                                               COMPANY.  INC rrzn
t. OK r PFKTINFNT FACILITY rtATVOeS Mf
  SNOttH.
                              Figure  4.   Plan of Monitoring Well Locations.   Refer to  Table  E-l  for
                                           Information  on domestic, wells.

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completely penetrates the alluvial  sequence and encounters the
underlying bedrock.
     Even though there are numerous borings in the shallower portions of
the alluvial sequence, more borings will  be needed to fully characterize
this sequence.  Many of these borings will  need to not only fully penetrate
the alluvial sequence but also need to penetrate through the underlying
clay unit and sample the shale bedrock.  The boring and well logs indicate
that the alluvial sequence exhibits a textural gradation from sands and
gravels near the base to fine sand, silt  and clay near the surface.  The
colors of these sediments are gray, tan,  brown and reddish brown.  The
alluvial sequence can be roughly divided  into two general units.  The
lower unit is fine to coarse, poorly sorted sands and gravels with lesser
amounts of silt and  clay.  The top  of the lower unit ranges from 20 to 40
feet below the surface.  The upper  unit is  dominated by fine sand, silt
and clay.  Clayey units frequently  have a blocky structure.  The upper
unit extends from the surface down  to a maximum of 40 feet.  The upper
unit is frequently truncated at the surface by a layer of fill.  The fill
is a variable mixture of sand, silt, gravel, construction debris, cinder,
wood and redeposited top soil.  The fill  unit is usually two to three
feet thick but varies in thickness  from zero to at least 16 feet in mon-
itoring well R6.  The alluvial sequence in  Boring B-l is 94 feet thick.
      Below the alluvial sequence,  at a depth of 97 feet below the sur-
face in Boring B-l,  is a dark gray  clay unit.  This clay is 19 feet thick
and contains only a trace of fine to coarse sand.  It would appear from
the texture of this  unit that it is not part of the overlying alluvial
sequence.  Since the unit is unconsolidated, it is possible that it is
a remnant of the Tertiary Midway or Wilcox  Groups.  These Tertiary units
have exhibited similar characteristics in Pulaski County where they thin
against the fall line (Plebuch and  Mines, 1967).
     At 116 feet in Boring B-l, a dark gray shale was encountered.
Since the unit is a consolidated shale unit, it has been inferred to be
a member of the Jackfork Sandstone  of Pennsylvanian age  (C.G. Stone,
Arkansas Geologic Commission, personal communication).
                                  -38-

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     The logs of the soil borings also indicate that subsurface
contamination by creosote is fairly extensive.  Of 41 borings logged,
33 showed visible evidence of creosote contamination (Table 4).  Ten of
the logs exhibiting creosote staining indicated that the contamination
was limited to the layer of fill material.  The remaining 23
contaminated borings exhibited staining in the zone beneath the fill.
In some cases this creosote staining filled cracks in blocky structured
clays.  The areal distribution of soil borings shows that releases of
creosote to soils (and possibly ground water) is extensive in the areas
of the abandoned impoundments, the drip track, the treating area and
the loading dock area.  During the Task Force inspection, selected
cores were examined and it was found that creosote contamination may
extend to depths greater than those indicated in Table 4.  For example,
in Boring B-23 the facility reported contamination from 5 feet to 11.7
feet.  Task Force inspectors found that core samples taken down to 15 feet
still gave off a strong creosote odor and had a slight black color.
Fractionation of the constituents of creosote may result in lightening
of the color of staining and make visible detection of contamination
more difficult.  A similar condition was also found in Boring B-24,
where the facility reported staining down to 25 feet but Task Force
personnel  found that it extended down to at least 35 feet.
     The soil boring logs and well logs that have been discussed in
this section are the only source of subsurface information.  However,
numerous deficiencies have been found in this program which have
prevented the development of a clear picture of subsurface conditions
at the facility.  The major deficiency is the lack of data on the
deeper portions of the alluvial section.  Only one boring fully pene-
trates the alluvial  section and this boring (Boring B-l) is not
adjacent to the surface impoundments.  There is no evidence to support
the interpretation that any of the sand stringers beneath the surface
impoundments are not hydraulically connected to lower sands and
gravels.  A thorough characterization of this uppermost aquifer will
require a knowledge of the nature of the contact between the alluvium
and the underlying clay as well as knowing whether any facies changes
                                  -39-

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                                                      TABLE 4

                                                MONITORING WELL DATA
                                                (All  Depths in Feet)
(1)
WELL
NUMBER
R-l
R-2
R-3
R-4
R-5
R-5B
R-5C
R-6
R-7
M-1A
M-1B
M-1C
M-2A
M-2B
M-2C
DATE
11/16/81
11/17/81
11/18/81
11/19/81
11/27/84
5/24/85
5/24/85
11/27/84
11/27/84
5/31/85
5/31/85
5/31/85
5/29/85
5/29/85
5/29/85
DEPTH
25.0
25.0
25.0
25.0
23.0
45.0
65.0
24.0
24.0
22.0
45.4
65.2
21.0
44.8
65.3
GROUND
ELEV.
255.5
257.5
257.0
255.0
255.0
254.9
255.2
257.5
258.0
257.5
257.4
257.2
256.6
256.8
256.7.
TOP OF
WELL (PVC)
257.28
259.75
258.83
257.04
257.24
257.43
257.76
259.53
260.31
260.15
259.95
259.74
259.16
259.19
259.21
DEPTH,
TOP OF
SCREEN
15
15
15
15
13
34.6
54.6
14
14
11.6
35.0
54.8
10.6
34.4
54.9
SCREEN
LENGTH
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
DEPTH TO
SAND PACK
(EST.)
13
14
13
13
6
33
52.5
13
12
9.6
32
50
10
32
49.5
DEPTH TO
TOP WATER
(ENCOUNTERED)
18.5
16.0
-
22
9
-
-
-
-
-
-
-
-
-
_
DRILLING/
SAMPLING
METHOD
WR <2)
M
"
"
SSA/ST
ST/HSA
HSA, W(M)R
SSA/ST
SSA/ST
W(M)R
»
»
W(M)R
"
W(M)R/ST
(1) From Status Report No. 2 - Groundwater  Quality  Assessment,  Koppers Co.  Inc., North Little Rock, Arkansas
    (July 17,  1986).
(2) WR = Water rotary; W(M)R = Wash(mud)  rotary;  SSA  =  Solid  stem auger; HSA  = Hollow stem auger; ST = Shelby tube.
                                                        -40-

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 TABLE 4, continued

MONITORING Wai DATA
(All Depths in Feet)
WELL
NUMBER
M-3A
M-3B
M-3C
M-4A
M-4B
M-4C
M-5A
M-5B
M-5C
DATE
5/22/85
5/22/85
5/23/85
5/24/85
5/24/85
5/22/85
5/29/85
5/29/85
5/29/85
DEPTH
22.0
45.0
65.4
21.5
45.0
64.1
21.4
45.0
65.0
GROUND
ELEV.
256.1
256.3
256.1
256.2
256.1
258.2
256.4
256.1
256.2
TOP OF
WELL (PVC)
258.53
258.80
258.64
258.63
258.64
258.69
258.90
258.57
258.70
DEPTH,
TOP OF
SCREEN
11.6
34.6
55
11.1
34.6
53.7
11.0
34.6
54.6
SCREEN
LENGTH
10
10
10
10
10
10
10
10
10
DEPTH TO
SAND PACK
(EST.)
9
31.5
52
10
32
49.5
8.5
33
51.5
DEPTH TO
TOP WATER
(ENCOUNTERED)



	


	


DRILLING/
SAMPLING
METHOD
HSA/ST
II
II
W(M)R
ii
W(M)R/ST
HSA & W(M)
ST
ii
H
        -41-

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or erosin of the lower clay unit  has occurred.   It is recommended that
a more extensive boring or well  program be implemented to evaluate the
full vertical and lateral  extent  of alluvium and the underlying clay.
Without this information,  the identification and subsequent monitoring
of potential pathways for  contaminant migration are not possible.  This
is also needed for full characterization of existing contamination.
     During the drilling and logging of the wells and borings,  Koppers
failed to collect much of  the data that would be necessary in an
aquifer evaluation.  They  have failed to provide any information on
advance rate or the percentage of samples recovered.  Also, lacking in the
narrative on the logs are  data on degree of weathering of sediments,
gross mineralogy, bedding, discontinuties, depositional structures or
strike and dip of bedding.  The depths at which water was encountered
are indicated on only 37 of the 53 logs and it  is not clear if this was
the first water encountered.
     The Burmeister Soil Classification System is a visual classification
system that was used by the contractor for the  facility to describe the
samples.  Such a classification system needs to be supplimented by analyt-
ical data and no such data was collected.  Atterburg limits or a grain
size analysis using seives and/or settling tubes should also have been
made.  The data could be used to characterize the physical properties of
the sediments.  This data then can be used in the design of the monitor-
ing well system.  Laboratory tests to determine hydraulic conductivity
could be used to supplement field measured (in situ) data.
     Review  of the technical adequacy of Koppers1 groundwater monitoring
system was hampered by problems in material supplied by the facility in
support of the Part B Application.  The exact locations of the borings
and wells are not known because of errors in the scales on maps.  No
cross-sections were provided using both borings and wells.  Cross-sec-
tions provided in the  Part B Application use only wells around the
surface impoundments and there are questions concerning plotting and
interpretation of the data.  No geologic or soils maps were submitted.
                                  -42-

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Hydrology

     The alluvial sequence beneath the Koppers facility is part of the
Mississippi Alluvial Plain aquifer.  Reports by Bedinger and Jeffery
(1964), Plebuch and Hines (1967) and Plafcan and Fugitt (1987) developed
a regional picture of the groundwater conditions of the Mississippi
Alluvial Plain of Eastern Arkansas.  The Koppers facility is along the
western-most limit of this alluvial plain.  Figures 5 and 6 are of the fall
and spring 1985 water levels of the alluvial aquifer.  They indicate that
flow conditions in the North Little Rock area should be in a southerly
to southeasterly direction.  When Figure 5  (Fall 1985) is compared to
Figure 6 (Spring 1985), it can be seen that water-level elevations do
vary seasonally.
     In this part of Pulaski County depths to water can vary from 5 to
35 feet below th$ land surface, however, annual fluctuations rarely ex-
ceed 20 feet.  The chemistry of the water in the region is a calcium
bicarbonate-type water with concentrations of dissolved-mineral constit-
uents that vary greatly.  Plebuch and Hines (1967) report iron concentra-
tions that vary from 0.1 to 52 ppm (90 samples), dissolved solids from
242 to 327 ppm (3 samples) and hardness from 6 to 505 ppm (76 samples).
     The previous section of this report discussed the site-specific
geology at the Koppers facility.  The Task Force believes the the upper-
most aquifer will predominantly consist of the whole of the alluvial
section.  There is a lack of evidence for a continuous confining layer
in any shallower portions of this section from the logs of borings.
Shallow clay layers can not be correlated across the facility and the
blocky structure of the clays allows for pathways for contaminant migra-
tion.  Task Force inspectors observed in boring samples that constituents
of creosote had migrated along the cracks in this blocky clay.  Water
level elevations that were measured in the nested wells further support
the argument for the lack of a continuous confining layer above 65 feet
which is capable of maintaining differential pressures.  It is possible
that the clay layer encountered in Boring B-l at a depth of 97 feet
could serve as a lower confining layer for the aquifer.  However, there
is too little data on this lower clay to determine if it is an effective
confining layer.
                                  -43-

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     Koppers Co.,  Inc.
  City  of
  Little Rock
1'0   '
                                9    MILES
                                J    KILOMETERS
Figure 5.   Water-Level Map of the Alluvial Aquifer in Eastern
           Arkansas, Fall 1985 (from Plafcan and Fugitt,  1987),

-------
         Koppers Co
    City  of
    Little Rock
                          10
9 MILES
  KILOMETERS
_
~l
Figure 6.   Water-level Map of the Alluvial  Aquifer in Eastern
           Arkansas, Spring 1985 (from Plafcan and Fugitt, 1987),

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     Koppers has conducted nine "slug" tests in an attempt to determine
the hydraulic conductivity of sediments in the area of the impoundments
and along the southern boundary of the facility.  The reported results
of these tests are questionable because of the methods and assumptions
used to make these calculations.  It is recommended that the facility
do additional conductivity testing by more commonly used methods to con-
firm the results of previous tests.  Without a reasonably accurate
measurement of hydraulic conductivity, flow rates can not be computed.
Also, hydraulic conductivity data will need to be determined for all
portions of alluvial  section.
     Ground-water elevation data has been collected at Koppers since
December 1981 (Tables 5A and 5B).  Ground-water elevations are
approximately 15 feet below the ground surface.  Contour maps of
these elevations prepared by the facility indicate a general southerly
flow direction for the groundwater.  On further evaluation of the data,
it was found that as  much as a 2.7 foot variation in water levels have
occurred in wells Rl  through R4 over the five years of measurements.
This data also indicates that there are localized variations in flow
directions.  These flow directions could vary as much as 90° from the
general southerly flow direction.  These temporal and spatial
variations in water-level elevations are possibly a response to flow
conditions in the Arkansas River, seasonal or annual variations in
rainfall rates, localized runon/runoff conditions and localized
permeability conditions.  Ground-water elevations in the well R6 show
anomalous values that are at least four feet higher than those in
other wells.  This well is located in a thick fill sequence and is
adjacent to Surface Impoundment No. 1 (Upper Lagoon).  Water-level
elevations in well R6 are probably being influenced by the water levels
in the lagoon.  The water levels in the lagoon are reportedly maintained
at about one foot below ground surface or approximately 14 feet above
normal ground-water levels.
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                                     TABLE 5A

                     GROUNDWATER ELEVATIONS,  1981  AND 1982^ >
                 (WELLS SCREENED ABOVE 25' BELOW GROUND SURFACE)

R-l
R-2
R-3
R-4
12-15-81
238.45
238.34
238.39
238.40
03-03-82
239.28
239.2
239.3
239.4
06-24-82
240.08
240.0
240.0
240.1
09-16-82
239.31
239.22
239.27
239.37
12-06-82
238.87
238.75
238.80
238.64
(1) See Table 5 for  other  parameters  on  well  construction
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                                            TABLE  58

                         GROUND-WATER  ELEVATIONS,  1983  THROUGH  1986^
    Well
   Number  07-20-83  10-12-83  12-18-83   02-01-84   03-14-85   08-02-85   10-22-85    07-22-86
   R-l
   R-2
   R-3
   R-4
   R-5A
   R-6
   R-7
   M-1A
   M-2A
   M-3A
   M-4A
   H-5A
   H-1B
   M-28
   M-3B
   M-4B
   M-5B
   R-5B
WELLS SCREENED ABOVE 25' BELOW GROUND SURFACE
240.37
240.29
240.34
240.43








WELLS






239.27 238.86 238.79 241.22
239.19 238.75 238.78 241.04
239.06 238.80 238.81 241.10
239.31 238.89 238.92 241.16
241.26
245.73
241.06





SCREENED BETWEEN 25 AND 35 FEET BELOW






240.54
240.33
240.39
240.54
240.64
245.34
240.39
240.44
240.14
240.07
239.84
239.92
239.53
239.43
239.49
239.59
239.59
244.91
239.47
239.58
239.22
239.61
238.93
238.93
GROUND SURFACED
240.26
240.12
239.97
239.87
239.86
240.72
239.47
239.19
239.10
238.95
238.94
239.70
239.57
239.59
239.58
239.53
239.75
243.97
239.49
239.70
239.47
239.32
239.07
239.28
239.43
239.50
239.30
239.52
239.13
239.91
(1) See Table for other  parameters  on well construction,
(2) HWGWTF Inspection
(3) Approximate Range
                                              -48-

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                                   TABLE  5B,  Continued


 Well                                                                                  /0.
Number  07-20-83  10-12-83  12-18-83  02-01-84  03-14-85  08-02-85  10-22-85   07-22-86^

             WELLS SCREENED BETWEEN 55 AND  65 FEET BELOW GROUND SURFACED


 H-1C                                                      240.26     239.35     239.60
 M-2C                                                      240.13     239.29     239.45
 M-3C                                                      240.02     239.09     239.25
 M-4C                                                      239.34     238.92     239.05
 H-5C                                                      239.85     238.92     239.02
 R-5C                                                      240.68     239.70     240.60
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     Several deficiencies have been noted in the hydrologic character-
ization of the Koppers site.  These deficiencies are a result of the
lack of data concerning the lower portion of the alluvial  section and
the underlying clay.   Slug tests or pumping-well tests should be used
to determine in situ  hydraulic conductivities in the lower parts of the
alluvial  aquifer and  in the underlying clay.  Hydraulic conductivities
determined in the laboratory on recovered samples could be used, but
only to supplement the in situ values.  Piezometers  or wells should be
added to the monitoring system to ensure that ground-water flow directions
are adequately characterized.
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           GROUNDWATER MONITORING SYSTEM UNDER INTERIM STATUS

     In 1985 the State of Arkansas became authorized to administer the
RCRA program.  The Arkansas Hazardous Waste Management Code was promulgated
pursuant to the Arkansas Hazardous Waste Management Act, as amended
(Act 406 of 1979, as amended, Arkansas Stats. Ann. §82-4201 et. seq.).
Section 3(a)(6) of this Code has adopted by reference the ground-water
monitoring requirements of 40 CFR 265 Subpart F.  The information
requirements that apply to owners or operators with ground-water
monitoring programs are stated in 40 CFR 270.14(c).  These regulations
were similarly adopted in Section 3(a)(9) of the Arkansas Code.
References in this report to any relevant citation will refer to
the language in 40 CFR with the understanding that the language is the
same in the State Code.
     Koppers Company, Inc. began their RCRA 265 Subpart F ground-water
monitoring program in mid-November of 1981.  This program consisted of
four monitoring wells (Rl through R4) around the surface impoundments.
Monitoring wells R5 through R7 were installed in response to a 3008(a)
order in November of 1984.  A ground-water quality assessment program
was begun in February of 1985 in response to a §3013 order and in response
to data from the first quarter of sampling in 1985.  A total of 35
wells were proposed in this program but at the time of the Task Force
inspection only 17 wells had been installed.  These 17 wells are the Ml
through M5 series wells, which consist of a 3-well, nested configuration
(designated A, B and C) and wells R5B and R5C.  The 3-well nest consist-
ing of R5 (now referred to as R5A), R5B, and R5C is intended to serve
as the upgradient wells for the M-series wells.  With the exception of
the Ml  wells (A.B, and C), the M-series wells were installed along the
southern boundary of the facility.
     The ground-water quality assessment program Included the installa-
tion of 18 off-site monitoring wells.  The purpose of these wells was to
determine the rate and extent of migration of any hazardous waste or
hazardous waste constituents.  This determination is required in Sections
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265.93(d)(4)(i) and 270.14(c)(4).  This is also a requirement of the §3013
order.  At the time of the Task Force Inspection these wells had not been
installed and Koppers had not determined the rate and extent of migration
of any contaninant plumes beyond the facility boundary.

Monitoring Well Placement

     The evaluation of the placement of monitoring wells at the Koppers
facility is hampered by two problems.  The first problem is the lack of
data to properly characterize the uppermost aquifer.  Without more data
on the vertical and lateral extent of the aquifer and temporal variation
in groundwater flow directions, a full  evaluation of well placement can
not be conducted.  However, there are a number of problems related to
the vertical and area! distribution of wells that is evident from the
existing data.  The vertical  placement of screened intervals needs to
be evaluated to ensure that the rate and extent of vertical contaminant
migration can be determined.   Wells need to be added to ensure the
lower-most levels of the alluvial sequence are being monitored.  If the
lower clay zone (at 97 feet in Boring B-l) can not be shown to be an
effective barrier to ground-water flow, this too will need to be monitor-
ed.  If this clay zone is not laterally continuous or if it is possible
for contaminants to reach the underlying shale bedrock, the geohydrologic
evaluation and monitoring program will  need to be expanded to include
this bedrock.  Even if this clay zone is continuous, a test will need to
be made to determine the effect of the contaminants on the clay chemistry
and permeability.  During the sampling of monitoring well MIA, by the
Task Force, it was observed that there were immiscible contaminant phases
in the well.  Napthalene and  phenanthrene are components of creosote
which have been identified in groundwater samples.  The specific gravity
of creosote ranges from 1.05  to 1.09 while napthalene has a specific
gravity of 1.145 and phenanthrene has a value 1.179.  Pentachlorphenol
has a specific gravity of 1.978.  The possible presence of these dense
contaminant phases in ground  water makes monitoring the lower portions
of the alluvial sequence a necessity.
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Monitoring Well Construction and Completion

     A variety of drilling techniques have been used in the construc-
tion of the monitoring wells (see Table 4).  All or part of 15 wells
were drilled with either water-rotary or mud-rotary methods.  Seven
wells were drilled with a hollow-stem auger or solid-stem auger.  In
wells R5C, MSA, M5B and M5C, both mud-rotary and hollow-stem augers
were used.  Shelby tubes were used to collect samples.  Drilling equip-
ment was steam cleaned between holes and sampling equipment was steam
cleaned between samples.  The diameters of the holes drilled with solid-
stem auger and rotary methods are six inches.  No records for hole
diameters were made available to the Task Force for the wells drilled
with a hollow-stem auger.
     From the information available to the Task Force, numerous defici-
encies were noted concerning drilling techniques.  The water used for
drilling or as make-up water for drilling muds was taken from a fire
hydrant connected to either the city water supply or to the "deep" well
at the facility.  This water was not analyzed for possible contaminants.
The drilling mud is Baroid Quik-gel® which is predominantly a sodium
bentonite mud with a biodegradable peptizing agent added.  Both water
and drilling muds are capable of inducing contaminants into the well
bores.  Mud-rotary drilling is also capable of forcing irrecoverable
quantities of mud into the formation.  Rotary drilling techniques should
only be used when hollow-stem or solid stem augers can not be used.
     The soil  boring program has indicated that soil contamination is
common at the facility.  It would be advisable that any future wells
drilled at the facility contain protective surface casing (double
casing design) to prevent the contamination of lower horizons.  This
problem is especially true for the area around the R6 well  (see appendix
B) which was drilled through fill.  This fill  contained oily wood and a
variety of soil  and building materials.  The filter pack surrounding
the screen is  exposed to three feet of this fill.  The act of drilling
through a minimum of 6 feet of this contaminated fill  and then taking
ground-water samples potentially exposed to the fill raises questions
concerning the capacity of this well  to provide samples that are repre-
sentative of the groundwater at that location.
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     The wells are constructed with Schedule 40 PVC pipe and screens
with flush threated joints.  Pipe and screens are two inches in di-
ameter and all screens are ten feet in length with a manufactured 0.01
inch slot size.  Wells R2 and R3 have four inch protective steel casing
from 0 to 15 feet and 1 to 14 feet, respectively.  The M-series wells,
R5B and R5C have a 0.4 foot sump attached to the bottom of the screen.
The other R-series wells do not have bottom caps on the screens.  Pipe,
screens, bottom-caps and other equipment used in constructing the wells
were not cleaned prior to placing them in the holes.
     Potential problems exist when PVC casing is exposed to creosote.
Creosote can cause structural damage to PVC casing and may prevent accu-
rate contamination assessment.  Consideration should be given to the
use of stainless steel casing in the construction of any future monitor-
ing wells.  The older wells with PVC casing should be evaluated for
their structural integrity and their effect on ground-water samples.
     The annular space adjacent to the screen is filled with a 100%
silica formation stabilizer in the coarse sand-size range (see
Appendix B).  This filter pack material  extends from one to seven
feet above the screen with 11 wells exceeding the recommended 2 foot
limit.  An annular seal consisting of one-half inch (1/21) Volclay®
(bentonite) tablets was placed above the filter pack.  This seal ranges
from two to 12 feet in thickness and in  wells R2, R3 and R4 it extends
to within two feet of surface.  In these three wells the two foot
interval  from the top of the annular seal  to the concrete apron was
filled with concrete.  Three other wells .have concrete between the
annular seal and the apron.  In well R5  it is four feet thick, while in
wells R6 and R7 it is 10 feet thick.  Well Rl has an inappropriate
"backfill" material  above the annular seal which is followed by a two
foot concrete interval just below the apron.  This "backfill" material
could serve as a conduit for migration of contaminants and the well
should be replaced.  All  remaining wells have a cement/bentom'te grout
that fills the annular space from the top of the seal to the base of
the apron.  This grout was made by mixing 188 Ibs. of Type 1 Portland
cement to 25 Ibs of bentonite.
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     The stick-up height at the surface is approximately two feet.  The
PVC is protected by steel protective casing and locking caps which are
painted orange.  A concrete apron was poured around the casing.  In
areas of vehicular traffic the wells are further protected with steel
bumper guards.  During the Task Force inspection, an examination was
made of the well aprons and seals.  Five wells (Ml, MSB and C, M4C and
R5B) were found to have cracks and three wells (R4, R6 and R5B) had
problems with the seals or loose surface casing.  Those seals with problems
should be replaced or repaired.  The remainder of the wells were in good
condition with good seals and aprons of good integrity.
     The R-series and some of the M-series wells were developed primarily
by bailing approximately five casing volumes of water.  In a few of the
M-series wells, air lifting was used to remove five casing volumes.
During the Task Force inspection, water recovered from wells had very
high turbidity values.  These values are given in Table 1.  These high
turbidity values are possibly indicative of inadequate well development
or improper design of the intake.  The use of air lifting or bailing
techniques to remove only five casing volumes of water was apparently
not sufficient to properly develop these wells.  Since wash and mud-ro-
tary drilling techniques were used at the facility, surge blocks should
be used to develop the wells.  The volume of water removed should not
be limited to five casing volumes but should be removed until the turbid-
ity drops below five nephelometric turbidity units (NTU) or its equiva-
lent.  Unless the source of the high turbidity in water samples can be
shown to be from another source, all the wells at the Koppers facility
should be redeveloped.  Any future wells should have the filterpack and
screen combinations designed on a well-by-well  basis.
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Sample Collection and Handling Procedures

     The Task Force conducted an evaluation of the sample collection
and handling procedures.  This evaluation consisted of a review of
plans submitted by Koppers in their Part B Application, Groundwater
Quality Assessment Program and in their assessment status reports.
These plans were discussed with Koppers personnel and a Koppers sampl-
ing team made a demonstration of their procedures by sampling well R6.
Further sampling by facility personnel was not conducted at the time of
the Task Force inspection.
     The facility sampling team first approached the well with level-D
safety equipment (cotton clothing, steel-toed boots, protective eyewear
and hard hats) but no attempt was made to monitor for organic vapors
or radiation.  A plastic sheet was then spread on the ground.  It was
noted during the sampling demonstration that a larger sheet of plastic
is needed for the procedures used by the sampling team.  A form entitled
"Field Data Sheet for Groundwater Sampling" is used to record data
collected at the well (Appendix C-l).
     Water-level elevations were measured with a steel tape which had
the bottom several  feet marked with water soluble ink.  This tape was
not made of stainless steel.  A measurement of the total well depth is
not routinely measured.  This method of elevation measurement is not
sufficiently accurate for measurement to the nearest 0.01 foot and is
not capable of detecting immiscible phases.  An electronic device of
suitable accuracy and with the capacity to detect separate phases would
be preferable to the steel tape.  A measurement of the total well depth
should be done each time the well is sampled in order to determine the
volume of water that needs to be evacuated during purging and to deter-
mine if silting is occurring in the well.  The steel tape is only wiped
with towels between wells.  A more contaminant-specific decontamination
should be done to prevent cross contamination and protect sampling per-
sonnel .
     The wells are sampled by first removing three casing volumes with top-
filling, stainless steel bailers.  The bailers are cleaned at the
Koppers laboratory in Monroeville, Pennsylvania and then shipped to the
facility.  One bailer is used for each well then returned to the laboratory
                                  -56-

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for cleaning.  A cork is used in the bottom of the bailer, but because
cork is absorptive of organic contaminants, its use should be discontinued.
Even though bailers are used at the facility, their sampling plans
allowed for the use of numerous types of pumps.  Since many of these
pumps could cause volatilization of organic constituents only the bladder
pumps would be suitable for both purging and sampling.  The casing
volume of water is calculated using the total depth of the well as it
was constructed.  This total-depth value should be replaced with a
value measured each time the well is sampled.  Samples are not tested
to determine purging efficiency.  For the deeper wells, purging and
sampling is aided by a tripod and pulley.  The rope attached to the
bailer is made of cotton and disposed of after each well.
     The procedures used for cleaning sample bottles and bailers are
similar.  This procedure is in the following order:  nonphosphate detergent
wash, tap water rinse, 1:1 nitric acid rinse, distilled water rinse,
acetone rinse, hexane rinse, methylene chloride rinse and then dry with
nitrogen.  Acetone and hexane are pesticide grade while the methylene
chloride is HPLC grade.  The stainless steel bailers are also heated
for one hour at 1200° F, cooled and wrapped with aluminum foil.  The
use of methylene chloride in the cleaning procedure should be discon-
tinued because methylene chloride is not only a Priority Pollutant but
has been identified as a possible laboratory contaminant at the facility
laboratory.  This step should be taken to reduce the possible sources
of methylene chloride that could affect TOX and TOC measurements.
     Samples are collected with the same bailers used for purging and
they are transferred to sample bottles prepared by the Koppers
laboratory.  The preservatives are placed in the bottles at the analytical
laboratory.
     Samples are not filtered at the well and measurement of the j_n_
situ values of specific conductivity, pH, and temperature are taken
after all the samples are collected and taken to a laboratory area at
the facility.  This practice of taking the samples "in batches" to an
onsite laboratory for the measurement of in situ values should be discon-
tinued in favor of making these measurements at the well.  The types of
sample bottles, caps, cap liners, and preservatives all meet Technical
Enforcement Guidance Document (1986) recommendations.  No procedures
have been developed for sampling of immiscible phases.
                                  -57-

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     Trip blanks are required in Koppers sample collection and handling
plans.  An equipment blank is prepared for each day of sampling by
placing distilled water from the laboratory into the bailers and then
transferring it to sample bottles.  Equipment blanks are called "field
blanks" in Koppers plans.  True field blanks, however, are not prepared.
Koppers should take field blanks since atmospheric emissions from impound-
ments and treatment areas are possible.
     All samples are stored in an ice chest and taken to their labora-
tory.  Sample labels appear to be properly filled out and bottles and
containers are properly sealed.  A chain-of-custody record and analysis
request sheet is prepared and taken to the laboratory with the samples
(Appendices C-2 and C-3).  Labels are color coded for the different
classes of analyses to be conducted on the samples.
     From 1982 to 1984, Koppers sent their samples to their laboratory
in Monroeville, Pennsylvania.  Beginning with the samples collected in
December 1984, samples were sent to the American Interplex Corporation
in Little Rock.  As part of the Task Force inspection program, an on-site
evaluation was conducted at this laboratory.  No evaluation was made at
the Koppers company laboratory.
     The laboratory evaluation was conducted by the EPA Region VI Environ-
mental Services Division along with staff of the Task Force and with EPA
Region VI RCRA Enforcement Section.  The evaluation team found (see
Appendix D) numerous deficiencies in methodologies, quality assurance
and laboratory administration.  Methylene chloride was found to be a
possible laboratory contaminant and it has been detected in distilled
water samples prepared at the laboratory.  Since Koppers uses distilled
water from this laboratory to prepare equipment blanks, the values of
TOX from these blanks could reflect contamination by methylene chloride.
     It was found during the review of data from the American Interplex
Laboratory that all samples are pre-filtered.  This should not be done
because it biases sample values downward.  Filtering can have a
significant effect on the reported concentrations for metals and
volatile organic constituents.
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     If an analysis for dissolved metals is desired then it is recom-
mended that the sample be filtered at the well.  An additional, unfilter-
ed sample should also be collected and analyzed for total metals.  It
was also found that the American Interplex lab was reporting a minimum
detection limit for lead of 0.1 ppm.  The minimum detection limit should
be below the drinking water standard of 0.05 ppm.  The method used by
the lab to analyze for lead is Standard Methods (15th Ed.) 303A which
is equivalent to Method 239.2 (Environmental Protection Agency, 1983).
The detection limit for this method is 0.001 ppm.
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      MONITORING DATA ANALYSIS FOR INDICATIONS OF WASTE RELEASE

Koppers Company Data

     In 1982, Koppers collected four quarters of monitoring data.  This
data was from the four wells in existence at the time (Rl  through R4) and
consisted of the following parameters:

          1.  pH
          2.  Total  Organic Carbon (TOC)
          3.  Chemical Oxygen Demand (COD)
          4.  Phenols
          5.  Pentachlorophenol (PCP)
          6.  Conductivity
          7.  Arsenic
          8.  Chromium, Total
          9.  Chromium, Hexavalent
         10.  Copper

Koppers was notified in November 1982 and again in January 1983 by
ADPC&E that they were required to also analyze for the parameters of
total organic halogen (TOX), chlorides, iron, manganese, sodium, sulfates,
and the remaining parameters in 40 CFR §265 Appendix III (Interim Primary
Drinking Water Standards).  Beginning in July 1983, Koppers began analyzing
for all parameters required in 40 CFR §265.  They also included analyses
for pentachlorophenol (PCP).  In addition to the missing parameters in the
first year of sampling, Koppers failed to collect four replicate samples
for the first quarterly sampling event as required in 40 CFR §265.93(2).
     During a review of ground-water elevations by EPA staff, for the
3008(a) order issued against Koppers in May 1984, it became apparent
that the Rl well was not a suitable upgradient well.  This well is not
located in the direction of increasing hydrostatic head.  In fact, the
R4 well is slightly up-gradient to Rl but it too remains an unsuitable  -

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upgradient well.  This immediate situation was remedied by the drilling
of the R5 well in November 1984 in response to the order.  Despite the
inadequacies  in the monitoring system, the sampling data collected in
the period from March 1982 to February 1984, indicates that two parameters
of concern were appearing in the ground water.  The concentration of
total chromium exceeded the maximum level of 0.05 ppm as established in
the Interim Primary Drinking Water Standards five times.  The concentra-
tions found are as follows:

                                         Total Chromium
               Hell       Date         Concentration (ppm)

               R 4       3/3/82                0.28

               R 1       6/24/82               0.135

               R 2       6/24/82               0.079

               R 3       6/24/82               0.128

               R 4       6/24/82               0.131

Even through these concentrations were found, subsequent samplings
found concentrations below 0.05 ppm.
     Pentachlorophenol  (PCP) was found in samples in concentrations
from .00078 to .0033 ppm.  However, frequently Koppers reported de-
tection limits of .001  ppm.
     In the last half of 1984,  the North Little Rock Department of
Health, ADPC&E and Koppers sampled four residential  water wells hydro-
logically downgradient  from the Kopper facility.   Eight water wells
have been identified within one mile of the plant but the four wells
that were sampled (Appendix E)  were within one-half mile.  These
samples established the presence of eleven components of creosote in
groundwater at the C.C.  Smitn Well.  Three of these components are
napthalene (0.338 to 3.200 ppm),  acenapthene  (.0315 to .061ppm)  and
phenanthrene (.0028 ppm).  These components were  not found in concentra-
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tions above the detection limits in the other three off-site wells.
Subsequent sampling in May of 1985 found the presence of phenanthrene
in the Clyde Little Well  (.000048 ppm) and fluoranthene in both the
Clyde Little (.000037 ppm) and Frank Herrod Wells (.000015 ppm).
     Pentachlorophenol (PCP) continued to be found in the domestic
wells above the detection limits but below the established
concentration limit.  The concentrations found in three of the four
off-site wells had a range of 0.0011 to 0.021 ppm.  In the May 6,  1985
sample, from the Frank Herrod Well, a PCP concentration of .0054 ppm
was measured.
     Koppers began an accelerated sampling program in order to comply
with the Agreed Order stemming from the §3008(a)  order.  Monitoring
data from the R5 well was to slowly replace the data supplied by the
former upgradient well, Rl.  Wells R6 and R7 are  also now in a downgrad-
ient position.  The first quarter of sampling data in this program
triggered the facility into assessment monitoring.  There were sixteen
statistically significant changes in the six downgradient wells.  The
second quarter of sampling found eighteen significant changes.  These
changes were in all four indicator parameters - pH, specific conduct-
ivity, TOX, and TOC.  Since the facility was now clearly in assessment
monitoring, Koppers appealed for relief from the requirement to continue
submitting the results of the statistical analyses.  However, sampling
of the wells in the accelerated program continued up to May 1986.   This
was the last data made available to the Task Force.  Sampling data from
the M-series wells and wells R5B and R5C were not available to the Task
Force since they did not receive their initial sampling until September
1986.'
     The data collected during the accelerated sampling program
(November 1984 to May 1986) consisted of the twenty interim primary
drinking water quality parameters and the four indicator parameters as
required in 40 CFR 265.92.  Koppers also analyzed their samples for
pentachlorophenol.  These samples were collected monthly.  Of the 18
sampling events in the accelerated sampling program, eleven sampling
events consisted of taking samples from only wells Rl and R5.  The
remainder of the events involved all seven R-series wells.
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Task Force Data

     All  analytical data from samples collected at Koppers by the Task
Force was subjected to a data usability assessment by an EPA
contractor (Lockheed Engineering and Management Services Company, Inc. of
Las Vegas, Nevada).  This assessment was designed to assist the user in
interpreting the analytical data.  The assessment is summarized in a
memorandum titled "Evaluation of Quality Control Attendant to the
Analysis of Samples from the Koppers Facility, Arkansas" which is
included in Appendix E along with tables of data.
     Table E-l (Appendix E) presents the data from the Task Force
groundwater and surface impoundment samples.  Numerous organic and
inorganic compounds of concern were identified in the ground-water
samples, including, more than 20 unknown semivolatiles.
     Lead is the only metal whose concentrations can be considered
quantitative that exceeded the drinking water standards.  This occurred
in well R5 (upgradient) as well as wells MSA, M4A, and R6.  Chromium
and arsenic concentrations that exceed the standards can only be
considered qualitative for chromium and semiquantitative for arsenic.
     Pentachlorophenol concentrations are only semiquantitative to
qualitative and were was found in two wells (MIC and MSA).
     Three groundwater samples (M1B, MSA, R6) and the two samples
from the lagoons had detectable quantities of chlorinated dioxins and
furans.  Even though concentrations of these compounds should be considered
qualitative, the reported quantities are probably lower than actual
concentrations.  There is also a high probability that where the results
indicate "no detection" there is actually a higher concentration
of these compounds in the groundwater.  This error is known to result
from adsorption of the dioxins and dibenzoforans to the walls of the
sample bottles.
     Seventeen polynuclear aromatic hydrocarbons are considered common
components of creosote (Environmental Protection Agency, 1981).  All
seventeen of these compounds were identified in the groundwater samples
in concentrations that can be used semi-quantitatively.  None of these
compounds were detected in six of the wells and in the remaining 11
                                  -63-

-------
well samples the numbers of compounds detected ranged from one to 15.
In the upgradient wells, the R5A sample found none of the compounds in
detectable quantities, while the R5B sample contained only one.
     The Task Force data indicate that the ground water beneath the site
is contaminated by hazardous waste constituents.  However, the surface
impoundments are not the only possible contributors to this contamination.
Further assessment must be done to identity the sources of this contamination,
                                  -64-

-------
                               REFERENCE

     Bedinger, M.S. and Jeffery, H. G., 1964, Ground Water in the Lower
Arkansas River Valley, Arkansas:  U. S. Geological Survey, Water-Supply
Paper 1669-V, pVl-V17.

     Environmental Protection Agency, 1981, Development Document for
Effluent Limitations, Guidelines and Standards for the Timber Products
Processing Point Source Category:  U.S. EPA 440/1-81/023, 498p.

	, 1986(a), Hazardous Waste Ground-Water Task
Force Protocol for Ground-Water Evaluations:  U.S. EPA OSWER Dir. 9080.0-
1, 220p.

	,1986(b), RCRA Ground-Water Monitoring
Technical Enforcement Guidance Document:  U.S. EPA, Office of Waste
Programs Enforcement, Office of Solid Waste and Emergency Response,
OSWER Dir. 9950.1, 317p.

     Haley, G. J., Buckner, R.O., Festervand, D. F., 1975, Soil  Survey
of Pulaski County, Arkansas:  U.S. Department of Agriculture, Soil
Conservation Service, 65p.

     Plafcan, M. and Fugitt, D. T., 1987, Water-Level Maps of the
Alluvial Aquifer in Eastern Arkansas, 1985:  U.S. Geological  Survey Water-
Resources Inv. Report 86-4178, 1 sheet.

     Plebuch, R.O. and Hines, M.S., 1967, Water Resources of  Pulaski
and Saline Counties, Arkansas:  U.S. Geological Survey, Water-Supply
Paper 1839-B, 25 p.
                                  -65-

-------
  Appendix A
Boring Log 6-1

-------
                                  BORING  LOG
PROJECT   NORTH LITTLE ROCK. AR PLANT  GWQA
DRILLING METHOD  SSA  and Wash	Rotary
                                                                BORING NO.  B-l
                                                 GEOLOGIST   D. R.
FILLER   McClelland Engineers. Inc.
                                                 DATE  5-6-85 to 5-8-85
jZC'JNO ELEVATION  ?56.Q
DEPTH OF BORING   116.5
                              GROUND WATER DEPTH (ft);
                                 AT COMPLETION	
                                 AFTER      HOURS
     SAMPLE
      nrpTH
                                 DESCRIPTION
            - 2.5
                    GRAVEL (FILL)
              5.75
                    Red/brown SILT and  f SAND
            - 7.75  Dk.  Brown clayey SILT, thin silt lenses
 10 --
              10.5   Dk.  Brown silty CLAY
             13.0   Tan  f  SAND, little silt
 15
 20
 25
 30
    tx-
                    Tan f SAND, tr silt
              27.0
                    Tan mf SAND, tr silt
    j.
               32.0-
  35
                    Brown f SAND,  tr silt
             —31.0.
                    Gray-tan mf SAND, clay at 40'

-------
                                    BCRIN'G  LOG
            .'.-QSTH LITTLE ROCK.  AR  PL;VT   GnSA
                                                           BORING NO. B-l
  DRILLING METHOD  SSA and Wash   '• .' '  Rotary
  DRILLER   McClelland Engineers. Inc.
                                           GEOLOGIST  D. R. Kerschner
                                           DATE  5-6-85 to 5-8-85
  G-.O'jrO ELEVATION   256.0
  DE?TH  OF  BORING  116.5
                        GROUND WATER DEPTH (ft):
                           AT COMPLETION	
                           AFTER	HOURS
D-CTH
DEPTH
                                  DESCRIPTION
             -  Grayish-tan cmf SAND
 45
 50
        NR
                52.0
 55
                Dk brown f SAND and clayey SILT
             h  57.0
 60
             -  Dk brown clayey SILT, little f sand
     ••  NR
 65
 70
             -  66.5
      •x-
        • Brown f SAND, tr clayey silt
         72.0 .
 75
      I
      T
         Brown mcf SAND, little small gravel,
         (Boulders below 75')
         77.0
 80
              -  Brown cmf SAND, little sm gravel
                                        A-2
                                                       SHEET
                                                                           OF

-------
                                    BORING LOG

  PROJECT   NORTH LITTLE ROCK. AR PLANT   GWQA
                                                           BORING NO.  B-l
  DRILLING METHOD SSA and  Wash
                             Rotary
  DRILLER   McClelland Engineers.  Inc.
                GEOLOGIST D. R. Kerschner

                DATE    5-6-85  to 5-8-85
  SROWO ELEVATION  256.0
  DEPTH OF BORING     116.5
                         GROUND WATER DEPTH (ft):
                            AT COMPLETION	

                            AFTER      HOURS
STRATA
DEPTH
SAMPLE
DEPTH
DESCRIPTION
   85'
   90
   95
  100
  105
  110
  115
                82.0
         sm GRAVEL


         87.0
              -  Brown cmf SAND and sm GRAVEL
              - 96.75
              - Dark gray CLAY, tr fme sand
                 116.0
              —J116.5 (wash sample)   Dk  prav sandv shaTT
                                         A-3
                                                        eurrr
                                                                            OF

-------
          Appendix B
Monitoring Well Logs for Wells
    Rl, R2, R5, R6 and MIC

-------
                             MONITORING  WELL  LOG
  PROJECT
                 N. Little Rock, AR
DRILLING METHOD
DRILLER
                                                                    WELL NO. R-l
                      Water-Rotar
             Mrnpllrinrt  Fnn    Tnr
                GEOLOGIST
                DATE
                                                               D.  R.  Kerschner
  GROUND ELEVATION  255.5

  TOP OF WELL CPVC)  257.28
  DEPTH OF WELL '(ft)  25.0
                                                          11/16/81
                              GROUND WATER DEPTH (ft);
                                 AT COMPLETION	^_

                                 AFTER  -    HOURS   "
  CASING MATERIAL 2" PVC
                             SCREEN  10 ft of 0.010" screen
STRATA
DEPTH
     SAMPLE
     DEPTH
DESCRIPTION
                               GRAVEL PACK &7F?
                               BENTONITE
                               BACK FILL
                               CONCRETE
CONSTRUCTION
              _ Brown CLAY, tr f sand
              _ Brown F SAND
10
      X
  15
                  Wet at 18.5
  25
    ><
                 Brown F SAND,  and brown CLAYEY SILT
                 (wet)
  30 --
                                       B-l
                                                                 :.  £

                                                              SHEET  1
                                                                         OF  1

-------
PROJECT
                             MONITORING WELL LOG

                    N.  Little Rock.  AR	
                                                                  WELL NO.  R-2
DRILLING METHOD

DRILLER
                  Water-Rotary
                         Fng.n Tnr
                                                   GEOLOGIST   D. R. Kerschner

                                                   DATE        11/17/81
GROUND ELEVATION,

TOP OF WELL
                   257.5
                  259.75
DEPTH OF WELL (ft)   25.0
                                GROUND WATER DEPTH (ft);

                                   AT COMPLETION

                                   AFTER  -	HOURS   -
CASING MATERIAL  ?" PVC
                               SCREEN   10 ft of 0.010"  screen
GRAVEL PACK i:-X:vj
BENTONITE
BACK FILL
CONCRETE
SCREEN
STRATA
     SAMPLE
      nrpTH
                                   DESCRIPTION
                                                                      CONSTRUCTION
            I  Brown F SAND (fill)
                Dk qrav CLAY  (fill ?)
                Dk brown SILTY CLAY
             -   Dk  brown F SAND and SILT  (wet)
 20
 25
                 (4" steel  casing set from 0 to 15 feet
                  below ground surface)
                                        B-2
                                                               SHEET   1	OF	I

-------
MONITORING WELL LOG
PROJECT North Little Rock
DRILLING METHOD SSA
DRILLER McClelland
GROUND ELEV;
\TION 255.0

TOP OF WELL (PVC) 257.24
DEPTH OF WELL (ft) 23

CASING MATERIAL 2" PVC
STRATA
DEPTH



5-
. «
•
*
10-

•


4
15-

•

20-
25-
mi
•«
SAMPLE
DEPTH



•»



i*









•t
k
••
WELL NO. R-5
GEOLOGIST D. R. Kerschner
DATE 11 727/84
GROUND WATER DEPTH (ft):

VEL PACK UV'X'1
AT COMPLETION - BENTONITE -M-MM
AFTER - HOURS - *Jjj
K FILL p;*l&
CRETE ^'-'.-l-
SCREEN C-I-I-:-:-
SCREEN 2" PVC, 0.010" slot
DESCRIPTION
- Dark brown SILT and CLAY
-
- Red-brown CLAY

and SILT
— Red- brown s1Uy CLAY
-
_


r~ -wet sllty seam at 9'


•—



—
- Brown F. SAND
**
>—
_






•
and SILT - wet


Ml
(Samples collected of each unit
with Shelby tubes)
I^MM •
CONSTRUCTION
T '7 ~

i —
• • i ~
F-l ^1 "
1 •"* 1 " • 1 ™
I/; "'••1
— 1 *" 1 *•*' 1 	
l^w*l • \
I * *" • ""
\'"' '''\ "
\ '• •". \
* •
- K — .*': —
: K 5 .::• :
•.; ~ '-tl "
• 1 —
•I=DI
—
> ^
B-3
                      SHEET
OF

-------
MONITORING WELL LOG
PROJECT North Little Rock
DRILLING METHOD SSA
DRILLER McClelland
GROUND ELEVJ
tflON 257.5

TOP OF WELL (PVC) 259.53
DEPTH OF WEL
1 (ft) 24


CASING MATERIAL 2" PVC
WELL NO. R-6
GEOLOGIST D. R. Kerschner
DATE 11/27/84
GROUND WATER DEPTH (ft):

VEL PACK (;«.V>.'1
AT COMPLETION - BENTONITE ••••
AFTER - HOURS - X£

K FILL ^:*v^
CRETE •>-:•',-/.•
SCREEN >:-:-:-:-
SCREEN 2" PVC, 0.010" slot

STRATA
DEPTH

•

5-


4
10-



15-


«
20-
w «


25-

•
M
••
SAMPLE
DEPTH











^



•••



^

•
>
•
»
»
^
^
DESCRIPTION
•»



*

— Brown CLAY and SILT, soft. Little
- siltstone chunks, piece of iron (nail?) (FILL)

~ Brown clayey
~ chunks


SILT, soft, Little siltstone
(FILL) .
• 	 	 — — —
~ Hit wood at 10 ft. - felt like large
~ piece
~ More wood at
•w

(FILL)
13 ft., oily

	 	 	 	
_ (Sand on augers at 16' )

••



MM»
(Samples
with
•
••V

*•



M
collected of each unit
Shelby tubes)
«•
CONSTRUCTION
n-
"

—
-
_
:
—
-


—

_
-
«• _ •••••
^ * »
'.* — • i
i *""*••'
r* * "" «'•'
—
i *•

B-4
SHEET
OF

-------
                             MONITORING WELL  LOG

  PROJECT North Little Rock. AR Plant - GWQA
  DRILLING METHOD   Wash (Mud) Rotary

  DRILLER McClelland Engineers. Inc.
                                             GEOLOGIST  R- M

                                             DATE    5-31-85
                                 WELL NO.  M-tC
                                 Morosky
  GROUND ELEVATION   257.2
  TOP OF WELL(PVC)  259.74

  DEPTH OF WELL (ft)  65.2
                         GROUND WATER  DEPTH (ft):
                            AT COMPLETION

                            AFTER   -   HOURS  -
  CASING MATERIAL 2" PVC
                        SCREEN O.or Slot(54.8 to 64.8)
                                SAND PACK  (?/>;
                                BENTONITE
                                BACK FILL
                                GROUT
                                SCREEN
STRATA
DEPTH
SAMPLE
DEPTH
DESCRIPTION
CONSTRUCTION
 35
 40
 45
 50
 55
  60
  65
      •X
       -  33.0       SEE BORING LOG FOR BORING B-26

       -  Brown/Gray, f SAND, tr silt, silt increases with depth
          47.0	

       -  Brown/Gray cmf SAND,
       -  53.5-55 mf SAND, tr silt
        • 63.5-65 cmf SAND, some mf gravel
         NR
              -  NOTES:  1.  A 0.4' tail pipe is attached to the bottom
                            of the screen

                         2.  PVC casing stick-up is 2.5'
                         (Bottom of Boring at 66.0')

                                         B-5
                                                        SHEET   1	OF	1

-------
                     Appendix C
Forms:  Field Data Sheet for Groundwater Sampling,
        Form for Analytical  Instructions, Chain
        of Custody Record

-------

*
u
5
u
2
2
at
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a






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o









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a
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1













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•





















































































•














































r*
*
*

*
A
H
3
n
C»fl
•*
f»
}j
"1
|
— ? 5
M
0
•8 ~
nS?
S" 2
3
*• * < 2
- 2.**
f
Number
or tolls
ltcmo*«M)
f - f
VI i*

^ & e
I.S 3
i| 3
*"»« cr


^
r
z
r.
2
2
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w



•


















2
«.
?







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1 SAMPL
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e





 o

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 u
 o
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tn


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Z

-------
                                                             CHAIN OP CUSTODY HKCOIW
       COOH
                 rmxircT  BANS
           tSigntttur*/
  T». HO.
            OATH
                    Tim
i    i
       •TATI Oft IOCATKM
                                                                        Mutinim
                                                                          or
                                                                     CONTAIHRMS
  I
 ro
elinijulshed byt (Signalure)
    Uate  Time   Heccivedbyt  (Si{nalure
                                       llclinqiibficd byt (Sifnilure)      Dale  Time  Iteeelrcd byt
•llnqubhed byt (Sfgnalure)
   D«le
Time
Received byi (Sifntlurc)
Itelinqulihed byi (Sifiwlure)
                        Dale
                        Time
necelved byt (Signature)
HinquishcO byt |Si|nalur«) .
   Dale
Time
Received for Laboratory byt
(Signature)
Dale
Time
lalribulloni Original accompanies shipment! Copy to Coordinator Field Files.
Remarks

-------
iO-.

. >CAT10N:
1UBJECT:
                Manager Environmental
                Analysis Laboratory
                MSTC	
                Analytical Instructions
. FIGURE 3.1
       FROM:
       LOCATION:
       DATEs
                                                                          8
       ACTIVITY NO.'
[ Mease carry out the indicated tests for specified samples from:
      TYPE
                     EXTRACTS
l_
L
SOIL
WATER
RESIDUE
OTHER
COMPOSITE
CRAB
TOTAL
EP-TOXICITY
ASTM
l« ANALYSES
1.
L.2.
3.
L4.
*
L,-
7.
L>
•9.
L°*
11.
L 2*
13.
st
6.
17-
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
Ammonla-N
Kjeldahl-N
Nitrate-N
Nitrite-N
S. Phosphorus - Total
^19. Phosphorus - Ortho
i !0. Oil In. Crease
*- "»ECIAL INSTRUCTIONS:
21.
22.
23.
24.
25.
26.
27.
11.
29.
30.
31.
32.
33.
34.
35.
•36.
37.
3S.
39.
Cyanide-Total-Amen.
PCP
Thiocyanate
Antimony (Sb)
Arsenic (As)
Barium (Ba) .
Beryllium (Be)
Bicarbonate (HCOj)
Boron (B) ..
Cadmium (Cd)
Calcium. (Ca)
Carbonate (COj)
Chloride (CD
Chromium (Cr) Total-Hex ,
Copper (Cu)
Fluoride (F)
Iron(Fe)
Lead (Pb)
Magnesium (Mg)
Manganese (Mn)
42.
43.
44.
45.
46.
47.
41.
49.
50.
51.
52.
53.
»

54.
55.
Mercury (Hg)
Nickel (Ni)
Potassium (K)
Selenium (Se)
SUver (Ag)
Sodium (Na)
' Sulf ate (SO4)
Sulfite ($03)
Sulfide (S)
Thallium (Tl)
Tin (Sn)
Zinc(Zn)
Priority Pollutants:
VOA, BN, AE,
PEST/HERB.
METALS
PAH
OTHER:

•

L

-------
                 Appendix D
On-Site Evaluation of the American Interplex
                Corporation

-------
              On - Site Evaluation
                     of the
         American Interplex  Corporation
               3400 Asher Avenue
         Little Rock, Arkansas  72204
                       by
        Environmental Services Division
U.S.  Environmental Protection Agency - Region VI
              Dallas, Texas  75270
                         D-l

-------
 Report of an On -  Site  Evaluation  of  the  American  Tnterplex  Corporation

                            Table of Contents

1.     Introduction                                                  ?
2.     Organization and Personnel                                    ?
3.     Facilities and Equipment                                      3
3.1    Facilities                                                    3
3.2    Equipment                                                     !*
4.     Laboratory Adminisration, Methodology,  and finality  Assurance  ?
4.1    Subcontracts                                                  "
4.2    Findings                                                      "
4.2.1  Laboratory Adminnistrati on                                    4
4.2.2  Methodology                                                   *
4.2.3  Duality Assurance                                             *
5.     Conclusions                                                   7
                                      D-2

-------
Report of  an On-Site  Evaluation  of  the  American Interplex  Corporation
1.  Introduction
     From July  30 through  August 1,  1986,  Kendall  Young  and Charles
Ritchey of the Environmental Services Division, U.S. Environmental Protec-
tion Agency - Region VI  performed an on-site evaluation of  the American
Interplex Corporation  which  is located at  3400  Asher  Avenue in Little
Rock, Arkansas and which  is  under contract  to the Koppers Company,  Inc.
to perform  certain  analytical  services.  This  evaluation  was  requested
by the Hazardous  Waste Management Division  in  support of the  Hazardous
Waste Ground - Water Monitoring Task  Force.
2.  Organization and Personnel
   .  The American Interplex  Corporation  is  organized as shown  in figure
1.  The technical staff  is also indicated by  name in  this  organizational
chart.
     LydiaS.L.  Morton,  the  Laboratory/Quality Assurance Director,  holds
a B.A. in Chemistry and has been with American Interplex for  8 1/2 years.
She has  had a wide  range of  analytical  experience  while employed  with
this company.
     Michael W. McNerlin, the Laboratory Manager,  has a 8.S.  In  chemistry
and has been with the  company  for 3  1/2 years.  All  of the analysts have
either a B.S. or B.A in chemistry.
     Joe D.  Henry,  the  Microbiology  Division Manager, holds a M.S.  In
Biology and has  been employed  by  American Interplex'for 9 years.   Larry
Kerr has a B.S in biology and hss been a biologist with the company  for a
year.
                                    2
                                     D-3

-------
3.  Facilities and Equipment

     Thp American Interplpx Corporation lahortnry  at  Littlp

on an average  approximately 500 samples a month.   No attempt was maHp to

determine what  percentage   of these   came  from  Koppprs.   The samples

submitted hy Koppers  are, for the most  part, water samples hut an  occasion-

al sludge sample is received hy the laboratory  for  analysis.

3.1.  Facilities

3.1.1.  Security.  Access to the laboratory  is  limited to  company employ-

ees and to escorted  visitors.   Further, a  sign in/sign  out.  procedure is

used.  Outside of normal  working hours (P:0n a.m. to  5:0.0  p.nO, however,

no special  security is employed such as burglar alarms or  separate locked

sample storage.

3.1.2.  Temperature  control.  While we did  not make direct- tempprature

measurements, we  observed  that almost all  employees  wore abbreviated

clothing (shorts  and  T-shirts)   due   to  the  high  temperature in  t>e

laboratories.  High temperatures not only affect the productivity o* thp

analysts and the quality of their work, hut. thpy  also  can have adverse

effects on the  operation  of  analytical  equipment  -  especially  those

employing data systems or computer chips.

3.2.  Equipment.  The laboratory appeared  to he adequately equipped with

the exception  of the  Hewlett-Parkard  mass selective  detector (HP?»Q7n}

which does not have a data system sophisticated  enough to  meet, the require-

ments of the  RCRA program.   The  mass  spectra library  1s  too  small  to

analyze all  of the compounds  in the RCRA  program and does not  allow the

tentative identification of the  compounds  in  thp H«7ardnus substance*

list.

4.  Laboratory Administration, Methodology  and  Duality Assurance
                                    3
                                     0-4

-------
(President)



o T Branch T
01 1 Manager |


|Sectretary[ jjechniclan[
1
1
Field 1 Main
Technician! Tech

,. i , 	 r T_:
Chief 1 1
1 Chemistj Chemist | Chem
Vice President/ 1
Technical Director |

(Off ice 1
(Manager [
| |
JRecept ionist | (processor |


laboratory/Qual i ty 1
Assurance Director |
(lydia S. I. Morton)
1
r 1
tenance Laboratory!
n lei an Manager
(Michael W. McNerlin)

1st Chemist Chemist Chem is

Ess istant
echnical Director


Microbiology
Division Manager
(Joe D. Henry)
(Biologist
(Lawrence M. Kerr)

it Chemist
(David H. (Steven E. (Gregory F. (Annjanette (Donna C. (Richard T. (C. Eugene
King) love 1) Moler) Stone) Nontague) Bonner) Grassle)
Figure 1.   Organizational  chart of  the American Interplex Corporation
                            August I,  1986

-------
4.1. Subcontracts.  Not  all  of  the  analytical  work  is being



by the American Interplex Corporation in its  laboratories in  littlp  Port.



The TOX analysis is being  subcontracted to MMTL Analytical  S



South Keene  Strept,  Columbia,   Missouri   65201   and  the



analyses are subcontracted to Controls  for Fnvironmental Povliitinn,



Rosina, Santa FP, New  Mexico  P7501.



4.2  Findings



4.2.1.  Laboratory administration.



4.2.1.1.  Sample chain-of-custody.   Few of thp chain-pf-custody r»rorHs



which were on  file  in  thp  laboratory wprp complptp; many of t.hp record*



were missing.



4.2.1.2.  It was  observed  that  the  total  organic haiidp  TTOX^  levpi  in



the field blank almost always exceedpd  the level  in thp actual samples.



This could  well  be caused by methylenp  chloride, for pxamplp,  in the



distilled water which  is used as the field  blank (the  fipld blanks



bottles of distilled water supplipd to  Koppprs by this  lahnr^tory^  s



samples are extracted using this  solvent  1n the  samp ronm in which



water still  is located.   Methylene  chlnridp is  also  detpct.pd  in



distilled water when it is  used as a blank 1n the mass  spipctivp



It has  been learned that  (Coppers has  been  using t.hp  field  blanks  as



equipment blanks,  i.e.,  Koppprs  has been  running thp distillpd  water



supplied by American Interplex through  t.he equipment  used  1n the  field.



Further, It  was learned that this  equipmpnt 1s  normally  c'leanpd  with,



among other soluents,  methyl ene  chloridp.   Thp residu^H frorr thi?  r.T^n-



ing could  also  contribute  to a  high field  blank.  T«M«>  I  illustrate*




this problem.





                                    4



                                     D-6

-------
 Deternination            Sample 1           Sample 2     Field Blank
      1                   0.21 mg/1          0.051 mg/1    0.66 mg/1
      2                   0.25               0.048        0.64
      3                   0.28               0.049        0.63
      4                   0.23               0.048        0.63
    average               0.24               0.049        0.64
Table I.   Values  of the TOX  reported  on two  samples  and a  field  blank
showing that the level  of TOX  1n  the field  blank  is actually much  higher
than in  the  samples.   [American  Interplex Corporation  Control   Number
6961]
4.2.2  Methodology
4.2.2.1.  Detection limits must be established for each of the methods used
in the  laboratory.  When  an  analyte is reported as  "not  detected", then
the customer  must  know   this   detection  limit.   As  an  alternative  to
reporting an analyte  as   "not  detected",  the  result may  be  reported  as
"less than" the detection limits.
4.2.3.  Quality Assurance
4.2.3.1  The  conductance of  the  water  coming from  the  still  is  not
monitored on a  routine basis and is measured  only  approximately yearly.
Since it  is  this water  that  is  used  in analytical work  throughout  the
laboratory, the  quality  of  the distilled  water  must  not  be  in  doubt.
4.2.3.2.  The dates that standards, buffers, and reagents  are prepared or
received are  not documented  on  the  bottles.  This  1s  very  important
since many reagents, buffers,  and standards do have optimum shelf  lives.
4.2.3.3.  No record  is  kept of  the  proper  tuning of the mass  selective
detector.  This  Is  important  to  Insure  the  proper  Identification  of
organic compounds analyzed  with this  Instrument.   Further,  no surogates
were analyzed as a matter of analytical routine.
                                       D-?

-------
4.2.3.4.  Through  the  examination  of  quality  control  charts,  it  was
determined that certain fluoride analyses were out of  control,  further,
it was determined that  these samples  had not  heen  rerun.
4.2.3.5.  In the analysis  for mercury, blanks and  standards are run with
the samples, but  control  samples  are not included.   Control samples are
very important  since  they  provide  information on  the  quality  of the
analysis.
4.2.3.6.  During  an  attempt to  verify  the  manganpse analysis   on  a
sample, the  work   sheet  showing  the  raw  data  r.ould  not  he  located.
The raw data from gas  chromatography,  atomic  absorption, gas chromatogra-
phy/ mass  spectroscopy, etc. must always  be kept  and m£urt  be readily
retrievable when necessary.
4.2.3.7.  When analyzing  for selenium and arsenic, the analyst has not
been keeping raw  data  sheets;  therefore, his results  could  not he con-
firmed.  Further,  blanks  were  analyzed only  several  times  during thp
week and  spikes  were  analyzed  only  once  or twice  a week;  blanks and
spikes must he run with each batch of analyses.
4.2.3.8.  When pesticides  are determined by gas chromatography, only one
column is  used  presently.   The  chromatographic  results  from  a   single
column must be confirmed by  using  a  second  column  or a  gas chromatograph/
mass spectrometer.  Further, the retention times of these compounds must
be checked  during each analytical  run  since  the  retention  time* are
dependent upon the conditions at the time of that run.   Relative  retention
times were used as means of identification  of the  pesticides.
4.2.3.9.  When analyses are performed by gas chromatography, each run of
analyses did  not  always  contain  spikes, duplicates,  and  other quality
control checks; this must  be done.
                                    fi
                                      0-8

-------
4.2.3.11.  While the analyst  stated  that he  checked  on a  daily  basis the
temperature of the incubator  used  for determining  the  biochemical  oxygen
demand, no log was kept.  Records such as this are essential  for assuring
the quality of the data.
4.2.3.12.  When preparing  media  for  microbiological  assays, the  poured
plates which have  been autoclaved are  checked to see that  there  is  no
growth on the  media.   However,  there 1s no  attempt made to  insure that
sterilizing conditions  are met 1n the autoclave;  this deficiency could be
overcome by  Including  1n each sterilization,  pellets  that  melt  or tape
that changes  color when  these  sterilizing   conditions  have  been  met.
Further, the  sterilized media  is  not  checked to  Insure that 1t  will
support growth by  steak ing plates as  controls.
5.  Conclusions
     While there  is  no doubt that the  staff  of  the  American  Interplex
Corporation has been trying to fulfill  its analytical  commitments,  there
are definite  deficiencies   1n  the company's  quality  assurance  program
that may lead one to question the  validity of certain of the data  generated
by this laboratory.
                                     D-9

-------
                  Appendix E
Tables and Correspondence Presenting Sampling
    Data from the Off-Site Domestic Wells

-------
                                TABLE E-l

                   LOCAL DOMESTIC WELL INFORMATION

                         NORTH LITTLE ROCK PLANT
WELL NO.


  1.



  2.



  8.



 12.



 13.



 14.



 15.



 16.




(1)   -



(2)   -

(3)   -
       RESIDENCE AND APPROXIMATE
       DISTANCE FROM FACILITY
      J. Thompson
      Oakley & Lincoln Roads
      (1 mile South)

      B. Oakley
      Washington St.
      (1 mile South)

      C. C. Smith
      4205 Rogers St.
      (1/8 mile)

      C. Little
      4817 Atkins St.
      (1/2 mile)

      H. Fegert
      4824 Rogers St.
      (1/2 mile)

      Scoggs
      N/A
      (1/2 mile)

      W. T. Garrick
      4805 Alpha
      (1/2 mile)

      F. Herrod
      4809 Rogers St.
      (1/2 mile)
  WELL TYPE
DEPTH
(FEET)
2" Galv. Steel     46
2"PVC
1-1/2" Galv.
Steel
1-1/4" Galv,
Steel
N/A (3)
N/A
1-1/4" Galv,
Steel
1-1/4" Galv,
Steel
  60
  35
  35
  N/A
  N/A
  35
  34
SCREENED
INTERVAL
(FEET)
             41-46
  55-60
  30-35
  32-35
  N/A
  N/A
  32-35
  30-34
Information provided by local residents, public officials or published
documents.  Well use is not for domestic purposes and is primarily restricted
washing cars, watering gardens, etc.

Approximate interval based on reported information.

N/A denotes Not Available.

                                   E-l

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             Tahle  1-2.   Loral Domestic Well Sampling Data
 Koppers Company Incorporated
  ATA SHEET. .(REVISED)
 AIC Control No.  1956
                             10/16/84 10:00 am   10/16/84 10:20 am
                             Clyde Little Well   W. T. Carrick Well   Detection
                               4817 Atkins          4805 Alpha         Limit

pH,  Standard Units                  6.16               6.25             N/A
TOC,  ppm                          32                 19                 5
COD  (soluble), ppm                *20                *20                20
Total Phenols, ppm                 *0.001              0.0089            0.001
Total Suspended Solids,-ppm        26                  1.0               1
Total Dissolved Solids, ppm       210                260                 1
Ammonia  as N, ppm                   0.092             *0.05              0.05
Nitrate  as N, ppm                   2.0                6.8               0.1
Oil  * Grease, ppm                   1.5               *1                 1
Pentachlorophenol, ppm              0.0011            *0.001             0.001
Specific Conductivity,  pmho/cm   320                420                50
Arsenic, ppm                       *0.002             *0.002             0-.002
Bicarbonate, ppm as CaCOj         120                 87                 1
Calcium, ppm                       18                 11                 0.1
Chloride, ppm                      35                  6.6               1
Total' Cromium, ppm                 *0.01              *0.01              0.01
Total Iron, ppm                     8.7                0.89              0.02
 apper,  ppm                        *0.01              *0.01              0.01
..agnesium, ppm                     10                 15                 0.1
Sodium,  ppm                         9.3               24                 0.1
Potassium, ppm                      1.5                1.9               0.05
Sulfate, ppm                       12                 55                 1
Carbonate, ppm as CaCO*            *1                 *1                 1
Naphthalene, ppb                   *1                 *1                 1
Acenaphthylene, ppb                *1                 *1                 1
Acenaphthene, ppb                  *1                 *1                 1
Fluorene, ppb                      *1                 *1                 1
Phenanthrene, ppb                  *1                 *1                 1
Anthracene, ppb                    *1                 *1                 1
Flouranthene, ppb                  *1                 *1                 L
Pyrene,  ppb                        *1                 *1                 I
Benz (a) anthracene, ppb           *1                 *1                 L
Chryaene, ppb                      *1                 *1                 1
Benzo (b) fluoranthene, ppb        *1                 *1                 1
Benzo (k) fluoranthene, ppb        *1                 *1                 1
Benzo (a) pyrene, ppb              *1                 *1                 1
Dibenzo  (a.h) anthracene, ppb      *1                 *1                 1
Benzo (g,h,i) perylene, ppb        *1                 *1                 1
Indeno (1,2,3 - c,d) pyrene, ppb   *1                 *1                 1

N/A • Not Applicable

    • Leas than

                                    1-2

-------
                             Tar>le £-2.  continued.

                                8/30/66  10':20an     8/30/84  ll:00aa
                                C.C.  Saith veil       Koppers Pl«nt    Detection
                                  4205 Rogers             Well           Limit

 pH                                   6.74                 6.75            N/A
 TOC, ppa                           22                    18                5
 COD  (soluble),  ppa                33                    33               20
 Total Phenols,  ppa                  0.055                *0.001            0.001
 Total Suspended Solids,  ppa          2.7                  28                1
 Total Disolved  Solids,  ppa        360                  230                1
 Aamonia as N, ppo                   2.1                  0.33             0.05
 Nitrate as N, ppa                   0.30                 0.24             0.1
 Oil  & Grease, ppa                 *1                    *1                1
 Pentachlorophenol,  ppo               0.021                0.011            0.001
•Specific Conductivity,  umho/ca   520                  340               50
 Arsenic, ppa                        0.0069               0.0050           0.002
 Bicarbonate, ppa as CaCO3         27                    8.5              1
 Caltiua, ppa                      54                    49                D.I
 Chloride, ppa                      60                    41                1
 Total Croolua,  ppa                *0.01                 *0.01             0.01
 Total Iron,  ppa                   17                    18                0.02
 Copper, ppa                        *0.01                 *0.01             0.01
 Hagnesiua, ppa                       6.3                  8.2              0.1
 Sodium, ppa                        50                    12                0.1
 Potassiua, ppa                       2.5                  2.5              0.05
 Sulfate, ppa                      69                    22                1
 Carbonate, ppa  as CaCO 3           *1                    *1                1
 Naphthalene, ppb                 3200                    *1                1
 Acenaphthylene, ppb               *1                    *1                1
 Acenaphthece, ppb                 320                    *1                1
 Fluorene, ppb                      *1                    *1                1
 Phenanthrene, ppb                 *1                    *1                1
 Anthracene,  ppb                   *1                    *1                1
 Tlouranthene, ppb                 *1                    *1                1
 Pyrene, ppb                        *1                    *1                1
 Benz (a) anthracene, ppb          *1                    *1                1
 Chrysene, ppb                      *1                    *1                1
 Benzo  (b) fluoranthene,  ppb        *1                    *1                1
 Benzo  (k) fluoranthene,  ppb        *1                    *1                1
 Benzo  (a) pyrene, ppb             *1                    *1                1
 Dibenzo  (a,h) anthracene, ppb     *1                    *1                1
 Benzo  (g,h,i)  perylene,  ppb        *1                    *1                1
 Indeno  (1,2,3 - c,d) pyrene, ppb  *1                    *1                1

 K/A »  Not applicable

 *   •  Less  than
                                       E-3

-------
                                -2.
 pH, Standard Units
 TOC, ppm
 COD (soluble),  ppm
 Total Phenols,  ppo
 Total Suspended Solids,  ppm
 Total Dissolved Solids,  ppm
 Ammonia as N, ppm
 Nitrate as K, ppm
 Oil 4 Grease, ppm
 Pentachlorophenol, ppm
 Specific Conductivity,  timho/cm
 Arsenic-, ppm
 Bicarbonate, ppm as
 Calcium, ppm
 Chloride, ppm
 Total Cromium,  ppm
 Total Iron, ppm
 Copper, ppm
 Magnesium, ppm
 Sodium, ppm
 "otassium, ppm
  ilfate, ppm
 Carbonate, ppm as
 Naphthalene, ppb
 Acenaphthylene, ppb
 Acenaphthene, ppb
 Tluorene, ppb
 Phenanthrene, ppb
 Anthracene, ppb
 Flouranthene, ppb
 Pyrene, ppb
~Benz (aj anthracene, ppb
 Chrysene, ppb
 Benzo (b) fluoranthene,  ppb
 Benzo (k.) f luoranthene,  ppb
 Benzo (a) pyrene, ppb
 Dibenzo (a.h) anthracene, ppb
 Benzo (g,h,i) perylene,  ppb
 Indeno (1,2,3 - c,d) pyrene, ppb
10/24/84  10:20am
Frank Herrod Well
  4809 Rogers

         6.27
        16
        33
        *0.001
        *1
       220
        14
         1.8
        *1
         0.017
       300
        *0.002
       140
         4.0
        14
        *0.01
         1.8
        *0.01
        13
        18
         1.9
        19
        *1
        *1
        *l'
        *1
        *1
        *1
        M
        *1
        *1
        *1
        *1
        *1
        *1
        *1
        *1
Detection
  Limit

   N/A
    5
   20
    0.001
    1
    1
    0.05
    0.1
    1
    0.001
   50
    0.002
    1
    0.1
    1
    0.01
    0.02
    0.01
    0.
    0.
    0.05
    1
,1
,1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
    1
 N/A -Not Applicable

 *   • Less than
                                  E-4

-------
                          TABLE E-3

                    KOPPERS COMPANY,  INC.
                    NORTH LITTLE ROCK, AR
                  RESIDENTIAL WELL ANALYSES
                 SAMPLING DATE:  MAY  6, 1985
                  SUMMARY OF ANALYTICAL DATA
Naphthalene
Acenaphthylene
Acenaphthene
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benz(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Dibenzo(a,h)anthracene
Benzo(g,h,i)perylene
Indeno(l,2,3-c,d)pyrene
Phenol
Pentachlorophenol
Mr. Frank Herrod
      Well

     <0.025
     <0.025
     <0.025
     <0.010
     <0.010
     <0.010
      0.015
     <0.010
     <0.005
     <0.005
     <0.005
     <0.005
     <0.005
     <0.005
     <0.005
     <0.005
     <2
      5.4
Mr. Clyde Little
      Well

     <0.025
     <0.025
     <0.025
     <0.010
      0.048
     <0.010
      0.037
      0.017
     <0.005
     <0.005
     <0.005
     <0.005
     <0.005
     <0.005
     <0.005
     <0.005
     <2
      1
NOTE:  Test results in micrograms/liter
       unless otherwise noted.
                             E-5

-------
                           STATE OF •_ n "• A •> -i A S

      DEPARTMENT OF POLLUTION CONTROL AND ECOLOGY
                       8301 NATIONAL ORl^E PO BOX 9SB3
                         LITTLE ROCK ARKANSAS 72209
                                                             : rsoi' Jf 2-7444
September  11,  1984


/is. C. C.  Smith
42C5 Rogers
North Little Rock, Ar  12117

Dear Ms. Smith:

Tl-.e simple of  well v=ter,  collected by Jay Justice &nd myself  on
August 30, 1984,  huS been  analyzed with the results  as follows.

  Naphthalene                   380 ug/1  (parts per_billion)
                                 61 ug/1  (parts per  billion)
Tr.'.-se cor.pouncs  are  components of creosote and show  the probable
presence of  creosote in the well.  The Health £*partr.*nt will have
to ssvise you  on t'-e suitability of '.he water for watering your
c-:fsn.  '-'e  will rzriin-je our work with Hoppers or, ths  prcble~. Wid
-.•:':! notify  you  :f  -.r.y cevelipr.ents.

:! *e csn irs of  farther assistance directly to you,  rlesse ceil HI*
cr ."a  J-:s-;ice  st t."ie Deartment.
Tick Castaz,  :-'2.r.ager
l-.c'.r.Sral  services Branch
                                 E-6

-------
                           S'   E OF ARKANSAS

      DEPARTMENT OF POLLUTION CONTROL AND £COLOGY
                       8OOI NATIONAL DRIVE. f.Q BOX »Sft»
                         LITTLE KOCK. ARKANSAS 722Ot
                                                       PHONE: (SOU 562 74A4
Mr. Dean Edwards
North Little  Rock  Health  Department
2600 Willow
North Little  Rock, Arkansas  72114

Dear Mr. Edwards:

The water sample submitted  by you on  July 5, 1984, has been screened
for polynuclear aromatic  hydrocarbons to detect the presence of
the component: of  creosote.   The analysis detected 11 compounds in
the extract with three  of the eleven identified.  The results are
as follows.

  Naphthalene                      338 ug/1
  Acenaphthene                     31.5 ug/1
  Phenanthrene                      2.8 ug/1

These compounds are components of creosote and verify the contamination
of the well by creosote.   The Department will  pursue the  matter
with the plant.
Sincerely,
Dick Cassat
Technical Services  Branch
                Nnte:  Tne sampled well  is the C. C. S«vith well.
                                   E-7

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                  Appendix F


Evaluation of Quality Control Attendant to the
Analysis of Samples from the Koppers Facility,
                   Arkansas

                     and

           Table of Task Force Data

-------
PRC Engineering
pro
Planning
                 EVALUATION OF QUALITY CONTROL ATTENDANT
                    TO THE ANALYSIS OF SAMPLES FROM THE
                         KOPPERS FACILITY, ARKANSAS
                              FINAL MEMORANDUM
                                   Prepared for
                   U.S. ENV IRONMENTAL PROTECTION AGENCY
                        Office of Waste Programs Enforcement
                              Washington, D.C. 20460
                                Work Assignment No.
                                EPA Region
                                Site  No.
                                Date Prepared
                                Contract No.
                                PRC No.
                                Prepared By
                                Telephone No.
                                EPA Primary Contacts

                                Telephone No.
                   548
                   Headquarters
                   N/A
                   November 14, 1986
                   68-01-7037
                   15-5480-04
                   PRC Environmental
                   Management, Inc.
                   (Ken Partymillcr)
                   (713) 292-7568
                   Anthony Montronc
                   Barbara Elkus
                   (202) 382-7912
                                 F-l

-------
MEMORANDUM

DATE:    November 14, 1986

SUBJECT: Evaluation of Quality Control Attendant to the Analysis of Samples
          from the Koppers, Arkansas Facility

FROM:    Ken Partymiller, Chemist
          PRC Environmental Management

THRU:    Paul H.  Friedman, Chemist*
          Studies and Methods  Branch (WH-562B)

TO:       HWGWTF:  Tony Montrone*
          Gareth Pearson  (EPA 8231)*
          Richard Steimle*
          Ed Berg (EPA 8214)*
          Robert Forrest,  Region VI
     This memo summarizes the evaluation of the quality control data generated by
the Hazardous Waste Ground-Water Task Force (HWGWTF) contract analytical
laboratories (1).  This evaluation and subsequent conclusions pertain to the data
from the Koppers, Arkansas sampling effort by the Hazardous Waste Ground-Water
Task Force.

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

     The evaluation was carried out  on information provided in the accompanying
quality control reports (2-3) which contain  raw data, statistically transformed data.
and graphically transformed data.

     The evaluation process consisted of three steps. Step one consisted of
generation of a package which presents the results of quality control procedures,
including the generation of data quality indicators, synopses of statistical  indicators.
and the results of technical qualifier inspections.  A  report  on the results of the
performance evaluation standards analyzed by the
*  HWGWTF Data Evaluation Committee Member


                                     F-2

-------
laboratory was also generated. Step two was an independent examination of the
quality control package and the performance evaluation sample results by members
of the Data  Evaluation  Committee.  This was followed  by a meeting (teleconference)
of the Data  Evaluation  Committee to discuss the foregoing data and data
presentations.  These discussions were to come to a consensus, if possible,
concerning the appropriate use of the data within the context of the HWGWTF
objectives.  The discussions were also to detect and discuss specific or general
inadequacies of the data and to determine if these are correctable or inherent in
the analytical  process.

Preface

     The data user should review the pertinent materials contained in the
accompanying reports (2-3).  Questions generated in the interpretation of these data
relative to sampling and analysis should be referred to  Rich Steimle of  the
Hazardous Waste Ground-Water Task Force.

I.    Site Overview

     The Koppers  facility is an existing wood preservation operation located in
Arkansas.  The facility has been in operation  for nearly 100 years.  Presently the
facility pressure treats wood products, mainly railroad ties, with petroleum  and coal
tar based products. Heavy petroleum oil  is added to creosote to make the treatment
solution.  Wastes produced at the facility are bottom sediment sludges from  the
treatment solutions and probably contain pentachlorophenol (which is no longer
used) and creosote  as well as wood chips and dirt.  The contaminated
pentachlorophenol  was sent to a series of lagoons where it  is separated from water
and reused.  Arsenates are not known to be used at this facility.

     Two lagoons  are used at the facility to treat waste water.  Eighteen ground-
water monitoring wells are present at the facility.  Polynuclear aromatic
hydrocarbons have been detected in many of the wells.  Elevated levels of arsenic
have also been  detected in several wells in the past. This facility is presently in
Assessment due to  the presence of a contaminant plume.

     Twenty-five  field samples including two field blanks (MQA473/Q1273 and
MQA487/Q1287), one equipment blank (MQA481/Q1281), one trip blank
(MQA490/Q1290),  and two pairs of duplicate  samples (well M-IC, MQA466/Q1266 and
MQA469/Q1269 and well M-4B, MQA467/Q1267 and MQA489/Q1289) were  collected at
this facility.  Samples MQA47S/Q12275 and MQA477/Q1277 are medium concentration
lagoon (surface impoundment) samples.  Sample MQA476/Q1276 is a medium
concentration ground-water sample.  All other samples were low concentration
ground-water samples.
                                     F-3

-------
II.   Evaluation of Quality Control Data and Analytical Data

1.0   Metals

1.1   Performance Evaluation Standards

     Metal analyte performance evaluation standards were not evaluated in
conjunction with the samples collected from this facility.

1.2   Metals OC Evaluation

     Total metal spike recoveries were calculated for twenty-three metals spiked
into four low concentration and two medium concentration ground-water samples
(MQA466, 469, 488, 489, 475, and 477, respectively).  Nineteen average spike
recoveries from the low  concentration ground-water samples and ten individual spike
recoveries from the medium  concentration ground-water samples were within the
data  quality objectives (DQOs) for this Program.  In  the low concentration ground-
water samples, the antimony, selenium, and silver average spike recoveries were
outside DQO  with values of  65, 32, and 219 percent,  respectively. Only two low
concentration ground-water samples were spiked for  each metal.  Sample MQA466
was spiked only for mercury, sample MQA469 was spiked for graphite furnace and
ICP metals, sample MQA488  was spiked for ICP metals only, and sample MQA489
was spiked for graphite  furnace metals and mercury.  The average spike recovery
for aluminum in the  low concentration ground-water samples was not calculated
because the sample concentrations were greater than  four times the concentration
of spike added. Various individual metal spike recoveries from the ground-water
samples were also outside DQO. These are listed in Table 3-2a of Reference 2  as
well  as in the following Sections.

     In the medium concentration ground-water samples, antimony, copper, mercury,
selenium,  silver, and  thallium spike recoveries were outside DQO with values of 34,
74, 50, 6800, 314, and 530 percent, respectively. There are no apparent reasons for
the high and  low recoveries. Only one medium concentration ground-water sample
was spiked for each metal. Sample MQA475 was spiked for the furnace metals and
ICP metals. Sample MQA477 was spiked for mercury.  Spike recoveries for seven of
the metals from the medium concentration ground-water samples  were not calculated
because the sample concentrations were greater than four times the concentration
of spike added.

     All reported laboratory control sample (LCS) recoveries and all  calibration
verification standard (CVS) recoveries were within Program DQOs.

     The  average relative percent differences (RPDs) for all metallic analytes were
within the DQOs.

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

     No contamination  was  reported in the laboratory blanks.  All four sampling
blanks contained aluminum  contamination at concentrations above the CRDL.
Samples MQA473 (field blank), MQA481 (equipment blank), MQA487 (field blank)," and
MQA490 (trip blank) contained 209, 270, 224, and 221  ug/L, respectively, of
aluminum.

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 1.3  Furnace Metals

     The graphite furnace metals (antimony, arsenic, cadmium, lead, selenium, and
 thallium) quality control, with a few exceptions, was acceptable.  Laboratory
 numbers 55006, 55007, 55008, 55009, and 55010 were assigned the  incorrect EPA
 sample numbers.  EPA sample numbers MQA481, 483, 484, 488, and 489, in that
 order, are the correct EPA sample numbers. This applies only to graphite furnace
 metals data (see  Reference 3, inorganics, comment A6).

     Matrix interferences were  present for antimony in the medium level sample and
 duplicate results. These results  were not considered in the  determination of data
 usability.  Antimony spike recoveries were outside DQO for samples MQA475 and 489
 with recoveries of 34 and 35 percent, respectively.  Duplicate injection precision  for
 antimony was poor for samples  MQA475Spk (spiked sample), 477 and 477Dup
(duplicate sample).  Antimony was detected in the trip blank at 6.1 ug/L which is
above the  instrument detection  limit (IDL) but below the contract required  detection
 limit (CRDL).  Data guality  for all results less than 60 ug/L (all samples) may be
affected.  All antimony results should be considered qualitative.

     The arsenic spike recovery for sample MQA489 was outside DQO with a
recovery of 128  percent.  The arsenic duplicate RPD for sample MQA477 was above
acceptable limits.  Arsenic results should be considered semi-quantitative.

     The cadmium spike  recovery for sample MQA469 was outside DQO with a
recovery of 138  percent.  The cadmium duplicate RPDs for samples MQA469 and 477
were above acceptable limits. The cadmium analytical spike result for sample
MQA484 was outside of the calibration range and  should have been rerun.  The
method of standard addition (MSA) correlation coefficient for cadmium in sample
MQA485 was outside control limits.  Cadmium results, with the exceptions listed
 below, should be considered  semi-quantitative.  Cadmium results for samples
MQA475, 476, 477, 484, and 485 should be considered qualitative.

     The correlation coefficient for the MSA analysis  of lead  in sample MQA489Dup
 was outside of DQO. Never-the-less, all lead results should be considered
quantitative.

     The selenium spike recoveries for samples MQA469, 475, and 489 were outside
 DQO with recoveries of 14, 6800, and 50 percent, respectively.  As previously
 mentioned, there is no apparent reason for these unacceptable recoveries.  Duplicate
 injection precision was poor for selenium in samples MQA477  and 477Dup. Matrix
 interferences were present for selenium in the medium level sample and duplicate
 results.  These results were not considered in the determination of data usability.
 The MSA correlation coefficients for selenium in samples MQA475 and 488 were
 outside control limits. Selenium results, with the exceptions mentioned below,
 should be  considered unreliable due to the above problems. Selenium results for
 samples MQA470, 475, and 480  should be  considered qualitative.

     The thallium spike recovery for sample MQA475 was outside DQO with a
 recovery of 530  percent.  Duplicate injection precision was poor for thallium in
 sample MQA477. The MSA correlation coefficient for thallium in sample MQA475
 was outside of control limits. Thallium results, with the following exceptions,
 should be  considered quantitative. Thallium results should be considered qualitative
 for sample MQA475 and unreliable for sample MQA477.

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1.4   ICP Metals

     All four field blanks contained aluminum contamination at concentrations
greater than CRDL.  All aluminum results in the field samples were greater than ten
times the aluminum concentration found in the field blanks so the aluminum data
quality was not affected.

     Individual spike recoveries were outside DQO for chromium in sample MQA48S
(66  percent), copper in sample M.QA475 (74 percent), potassium in sample MQA488
(70  percent), and silver in samples MQA469 (74 percent), 475 (314 percent), and 488
(364 percent).  Low spike recoveries indicate results which are biased low and high
spike recoveries indicate results which are biased high.

     The ICP serial dilution results were not within 10 percent of the original
determination for chromium and vanadium in sample MQA488 and for copper and
potassium in sample MQA477. Poor serial dilution  results can be an indication of
physical interferences in the analyses. At this facility, the  interference is most
prevalent in samples which contain high concentrations of dissolved solids and
usually yields results with a negative bias and thus low recovery.

     The low level (twice CRDL) linear range checks for chromium, copper, nickel,
silver, and  zinc had poor recoveries.  The low level linear range check is an
analysis of a  solution  with elemental concentrations near the detection limit. The
range check analysis shows the accuracy which can be expected by the method for
results near the detection limits.  The accuracy reported for these elements is as
expected.  AH chromium results,  except those for sample MQA486, should be
considered  biased low. All copper results, except those for samples MQA476 and
477, should be considered to be biased low. All nickel and  silver results should be
considered  to be biased low.  No zinc results are affected.

     Duplicate injection  relative standard deviation (RSD)  results for barium,
calcium, chromium, cobalt, copper, manganese, nickel, and zinc in sample MQA477
were all above DQO.

     All aluminum, beryllium, iron, magnesium, and sodium results should be
considered  quantitative.  Barium, calcium, cobalt, copper, manganese, nickel, and
zinc results, with exceptions listed below, and  vanadium results for samples MQA475
and 477 should also be considered quantitative. All potassium  results, as well as
barium, calcium, chromium, cobalt, copper, manganese, nickel, and zinc results for
samples MQA475 and  477, and vanadium results, with exceptions listed below, should
be considered semi-quantitative.  All chromium results should be considered
qualitative. All silver results should be  considered unreliable due to  poor matrix
spike recoveries.

1.5   frfercurv

     Three of the  sampling blanks, MQA473 (a field blank), 481 (equipment blank),
and 490 (trip blank) had mercury contamination at 0.2 ug/L which is the mercury
CRDL.  Positive mercury results below 2 ug/L may be affected by this contamination
and may be false positives.  Probability of false negatives is acceptable, however.

     Mercury results  for samples MQA475 and 477 should be considered semi-
quantitative.  Due to  blank contamination all other positive mercury results should
be considered unreliable.

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2.0   Inorganic and Indicator Analvtes

2.1   Performance Evaluation Standard

     Inorganic and indicator analyte performance evaluation standards were not
evaluated in conjunction with the samples collected  from this facility.

2.2   Inorganic and Indicator Analvte OC Evaluation

     The average spike recoveries of all of the inorganic and indicator analytes, in
both ground water and leachate samples, were within the accuracy DQOs (accuracy
DQOs have not been established  for bromide  and nitrite nitrogen  matrix spikes).
This indicates acceptable recoveries for all  inorganic and indicator analytes.

     All LCS and CVS recoveries reported  in the raw data for inorganic and
indicator analytes were within Program DQOs.

     Average RPDs for all inorganic and indicator analytes  were  within Program
DQOs.  Precision DQOs have not been established for bromide and nitrite  nitrogen.

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

     No laboratory blank contamination was  reported for any inorganic or indicator
analyte.  Contamination involving cyanide, POX, TOC, and total phenols was found
in the sampling blanks at levels above CRDL. These contaminants and their
concentrations are listed below, as well as in  Section 3.2.4 (page 3-3) of Reference
2.

2.3   Inorganic and Indicator Analvte Data

     The quality control results  for sulfate, chloride, and ammonia nitrogen are
acceptable.  The results for these analytes should be considered quantitative.

     The equipment blank, MQA481, contained cyanide contamination at 20 ug/L.
Samples  MQA470 and 475 were the only field samples which contained cyanide (10
and 20 ug/L, respectively).  As the concentration of cyanide found in the two  field
samples was approximately the same as that in the contaminated blank, these
positive cyanide results should be considered  unreliable.  All other (negative)
cyanide results should be considered quantitative  with an acceptable probability of
false negatives.

     The holding times for the nitrate nitrogen analyses  ranged from 8 to 13 days
from receipt of samples which is longer than  the recommended 48 hour holding time
for  unpreserved samples.  The field duplicate precision for one of the two duplicate
pairs (MQA467/489) was poor (no nitrate nitrogen detected in  one sample, 750 ug/L
detected in the other). The comparative precision of the field duplicate results is
not  used in the evaluation of sample data as  it is not possible to determine the
source of this  imprecision. Field duplicate precision is reported for informational
purposes only.  Th- nitrate nitrogen results should be considered semi-quantitative.

     The holding times for the nitrite nitrogen analyses ranged from  8 to 13 days
from receipt of samples which is longer than  the recommended 48 hour holding time
for  unpreserved samples.  The laboratory did  not analyze an initial calibration
verification (ICV) at the beginning of the nitrite nitrogen ion chromatography

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analytical batch, as required.  The nitrite nitrogen results should be considered to
be semi-quantitative.

     The laboratory did not analyze an ICV at the beginning of the bromide ion
chromatography analytical batch, as required.  The bromide results should be
considered  to be semi-quantitative.

     The sulfate field duplicate precision for both of the duplicate pairs
(MQA466/469 and  MQA467/489).was poor (5000 versus 850 ug/L in the first pair and
no sulfate detected versus 32500 ug/L detected in the other).  These data were not
used in the data usability  determination as  the results may only be a reflection of
poor duplicate sampling techniques.  The sulfate data, as mentioned above, should be
considered  quantitative.

     One of three  ammonia nitrogen matrix spikes (into sample MQA476) was below
DQO with a recovery of 86 percent (DQO range 90 to 110 percent).  As mentioned
above,  all ammonia nitrogen results should  be considered quantitative.

     Total  phenol  contamination was found in the equipment and trip blanks
(MQA481 and 490) at concentrations of 13 and  17 ug/L. These values are above  the
total phenol CRDL of 10 ug/L. All total phenols  results greater than 10 times the
highest concentration of total phenols in the sampling blanks or less than the
detection limit are considered  quantitative.  This  includes samples MQA466, 467, 469,
471, 473, 475, 476, 477, 487, and 489. Bases upon  HWGWTF conventions, all total
phenols results between  five and ten times  the highest sampling blank concentration
should be considered qualitative.  Results for sample MQA468 should be considered
qualitative.  All other total phenols results  are unreliable.  Total phenols results for
samples MQA465, 470, 472, 474, 478, 479, 480, 481, 483, 484, 485, 486, 488, and 490
should be considered unreliable. The total  phenols field duplicate  precision for one
of the  duplicate pairs (MQA466/469) was poor (1080 versus 475 ug/L).

     A final TOC calibration  blank (CB) was not analyzed at the end  of the last
two analytical batches.  The agreement of results  between one of the pairs of field
duplicates and two pairs of laboratory duplicates was poor. Field duplicate pair
MQA466/469 had concentrations of 18,000  and  14,000 ug/L of TOC. The comparative
precision of the field duplicate results is not used in the evaluation of sample data
as it is not possible to determine the source of this imprecision.  Field duplicate
precision is reported for informational purposes only. Laboratory duplicates run on
sample MQA469 had large RPDs. TOC matrix spike recoveries were outside DQO for
samples MQA476 and 489  with recoveries of 78 to 326 percent.  Sample MQA476
contained a distinct water and heavy organic phase and that is attributed to the
spike recovery problems with that sample.  The trip blank (MQA490) and a
preparation blank  contained TOC at concentrations of 3100 and  2500 ug/L.  Again,
as a HWGWTF convention, all TOC results  greater that ten times the highest field
blank  concentration or less than the detection limit should be considered
quantitative. TOC results for samples MQA467, 473, 475, 477, 483, 487, and 489
should be considered semi-quantitative, results for sample 'MQA466 should be
considered  qualitative, and all  other TOC should  be considered unreliable.

     Initial calibration verification and continuing calibration verification  (CCV)
standards for POC were not analyzed.  Initial calibration blanks were not analyzed
at the  beginning of every  analytical batch.  POC  spiked solutions were analyzed
during the  course of the POC  analyses but  the "true" value of the spike was not
provided by the laboratory. EPA needs to supply the inorganic laboratory with a
POC calibration verification solution.  Until then, the instrument calibration can not
be assessed. One of two sets of field duplicates (MQA467/489) showed poor

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precision with POC concentrations of 3900 and 250 ug/L.  The comparative precision
of the field duplicate results is not used in the evaluation  of sample data as it is
not possible to determine the source of this imprecision. Field duplicate precision
is reported for informational purposes only. The POC results should be considered
qualitative.

     A TOX ICV and initial calibration blank (ICB) were not run at the start of
every analytical batch.  A CCV and CCB were not  run at the  end of every day's
TOX analytical batches.  The results of both pairs  of field duplicates (MQA466/469
and MQA467/489) showed poor precision with TOX concentrations of  10 and 28 ug  L
for the first duplicate pair and 305 and  22 ug/L for the second  duplicate pair.  The
comparative precision of the field duplicate results is not used in the evaluation of
sample data as it is not possible to determine the source  of this imprecision.  Field
duplicate precision is reported for informational purposes only.   The TOX results
should be considered quantitative except for the samples where  insufficient
calibrations were performed.  Samples with insufficient  calibrations include MQA470,
471, 472, 476, 478,  479, 480, and 486 and results for these samples should be
considered  semi-quantitative.

     A final POX  calibration blank was not analyzed at the end of two different
day's analytical batches.  One of the two sets of POX field duplicates (MQA467/489)
showed poor precision with a reported concentration of  32 ug/L  in one sample and
no POX detected in the other. The comparative precision of the field  duplicate
results is not used in the evaluation of sample data as it is not possible to
determine the source of this imprecision.  Field duplicate precision is reported for
informational purposes only.  Field blank MQA473 contained  POX  contamination  at 7
ug/L which is above the CRDL.  All  POX results less than the POX CRDL (5 ug/L)
should be considered qualitative and all POX results greater than the CRDL but less
than four times the concentration of POX in the blank should be considered
unreliable.  POX results should be considered quantitative except for sample MQA467
which  should be considered qualitative and samples MQA466, 473, and 477 should be
considered  unreliable.

3.0   Oreanics and Pesticides

3.1   Performance  Evaluation Standard

     Organic performance evaluation standards were not evaluated in conjunction
with the samples collected from this facility.

3.2   Organic QC Evaluation

     All matrix spike average recoveries, except acenaphthene, 2-chlorophenol,  and
4-chloro-3-methylphenol, were within  established Program  DQOs for accuracy.
Matrix spike recoveries which were  outside the accuracy DQO will be discussed in
the appropriate Sections below. All surrogate spike average recoveries were within
DQOs  for accuracy with two exceptions.  Average  recovery for  2-fluorophcnol was
below DQO and no semivolatile surrogate spike compounds were recovered from the
medium concentration samples due to the large sample dilutions  which were made.
Surrogate spike recoveries which were outside the accuracy DQO will be discussed
in the  appropriate Sections below.

     Seventeen  of  twenty-two matrix  spike/matrix spike duplicate  average RPDs
were within Program DQOs for precision.  Matrix spikes average RPDs were out of
DQO for benzene,  acenaphthene, pyrene, 2-chlorophenol, and  4-chloro-3-
methylphenol. Matrix spike RPDs which were outside the precision DQO will be

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discussed in the appropriate Sections below.  All average surrogate spike RPDs were
within DQOs for precision.

     All organic analyses were performed as requested.

     Laboratory blank contamination was reported for organics and is discussed in
Reference 3 (for organics) as well as the appropriate Sections below.

     Detection limits for the organic fractions are summarized in Reference 3 (for
organics) as well as the appropriate Sections below.

3.3   Volatiles

     Quality control data indicate that  volatile organics were determined acceptably.
The chromatograms appear  acceptable.  Initial and continuing calibrations, tunings
and mass calibrations, blanks, matrix spikes, and surrogate spikes  are acceptable.
One problem with a matrix spike duplicate was encountered.  The holding time for
sample QI285 was exceeded by two days.

     The matrix spike duplicate recovery and RPD for benzene was outside DQO in
sample Q1269MSD  (matrix spike duplicate).  This appears to be the result of a bad
spike and should have no impact on overall data quality.

     Acetone, methylene chloride, ethyl benzene, and tetrachloroethene were  found
in five instrument  blanks (CD860729C18, CB860728A12, CD860727B12, CC860731A11,
and CB86G801C18) at values just below  the CRDL.  Results for these volatiles in the
range of the CRDL should be considered unreliable.

     Estimated  method detection limits are CRDL for all samples except Q1267
which is 2.S times CRDL, Q1275 which  is 1.7 times CRDL, and Q1289 which  is 3.3
times CRDL.

     The volatiles  data are acceptable.  The probability of  false negative results for
the volatiles is acceptable.  The volatile compound results should be considered
quantitative with the exception of low concentration (at or below CRDL) positive
results for  the four compounds found in the  instrument blanks.

3.4   Semivolatiles

     Calibrations,  tuning and mass calibrations, and chromatograms were acceptable
for the semivolatiles.  Problems were encountered with matrix spike/matrix spike
duplicate recoveries, surrogate recoveries, holding times, and blank contamination.

     Contamination was detected in three laboratory blanks (GH094416A21,
GH095380C21, and GJ094128A21). The contamination included three unknown
contaminants and di-n-butylphthalate, all at  less than the CRDL.

     Semivolatile matrix spike compounds were not recovered from sample
Q1269MS/MSD  which was diluted 100 times  due to the high naphthalene
concentration which was present.

     The matrix spike (MS) and matrix spike duplicate (MSD) recoveries of
acenaphthene (23 and 9 percent) were  below DQO (46 to 118 percent). The MSD
recovery of pyrene (137 percent) was above DQO (26 to  127 percent).  The MS
recovery of 2-chlorophenol (13 percent) was  below the DQO (27 to 123 percent).
The MS and MSD recoveries of 4-chloro-3-methylphenol (6  and 12 percent) were

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below DQO (23 to 97 percent). The matrix spike and matrix spike duplicate RPDs
for all four of these compounds were above the  respective DQOs.

     Semivolatile surrogate compounds were not recovered from samples Q1266,
1267, 1268, 1269, 1276,  1269MS, 1269MSD, 1277, and  1289 due to large sample
dilutions (100 to 200 times) required due to high concentrations of semivolatiles.
Surrogate compounds were not recovered from sample Q1275 which was diluted on!\
eightfold. The problem with surrogate recovery  from this sample has  been
attributed to unspecified matrix effects.

     The surrogate percent recoveries  for 2-fluorobiphenyl  in samples Q1265RE
(reextraction) and Q1280, terphenyl-D14  in sample Q1280, phenol-D5 in samples
Q1265, 1265RE, 1278, 1278RE, 1279, 1279RE, 1280, 1280RE, and 1285, 2-fluorophcnol
in samples Q1265, 1265RE,  1270, 1271, 1278, 1278RE, 1279,  1279RE, 1280, 1280RE.
and  1285, and 2,4,6-tribromophenol in  samples Q1265RE, 1273, 1280, J280RE, 1285,
and  1286 were outside their respective DQOs.

     The holding time  until extraction was exceeded for samples Q1265RE  and 1287
by 6 and 5 days, respectively.

     The semivolatile data are acceptable and the  results should be considered semi-
quantitative except for the  acid fraction results  for samples Q1265, 1270, 1271, 1273.
1278, 1279,  1280, 1285,  and  1286 which should be considered to  be biased low and
qualitative due to poor  recoveries. Estimated method detection  limits  are CRDL for
all samples except Q1274 and  1275 which are 8 times CRDL, Q1266, 1267, 1268, 1269,
and  1289 which are 100 times CRDL, Q1277 which is 160 times  CRDL, and  Q1276
which is  200 times CRDL.  The probability of false negatives is acceptable  for all
samples with the exception of those with raised detection limits caused by dilution
where the probability of false negatives is  high.

3.5    Pesticides

     The initial and continuing calibrations, and chromatographic quality,  with
exceptions, for pesticides were acceptable.  The matrix spike, matrix spike duplicate,
and holding  times were within acceptable limits.

     The surrogate recovery for dibutylchlorendaie was outside DQO  (24 to 154
percent)  for  samples Q1273 (22 percent) and Q1276 (no recovery).  The retention
time shift for dibutylchlorendate was  greater than two percent  in sample Q1276.

     The holding time  until extraction was exceeded by eight days for the  matrix
spike and matrix spike  duplicate for sample Q1269.

     Pesticide method blank chromatogram number 94559 and chromatograms of the
PCB standards show unknown  peaks representing unknown contamination.  Many  of
the sample chromatograms also had peaks which were not inside the pesticide
retention time windows. This possible contamination may be due to improper sample
clean-up  procedures (fluorosil clean-up was used) and should  have been addressed by
the laboratory.  See Reference 3 (organics) for more  information as well as  the
chromatograms.

     The estimated method detection limits for  the pesticides fraction were CRDL
for all samples except Q1275 and 1277 which are 10  times and two times CRDL,
respectively.  The pesticides results should  be considered unreliable although no
pesticides were detected.  It is  possible that no pesticides could  be found due to
the clean-up method used and the sample preparation, including recombination of

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III.  Data Usability Summary

4.0 Graphite Furnace Metal?

Quantitative:  thallium results with exceptions and all lead results
Semi-quantitative:   cadmium results with exceptions and all arsenic results
Qualitative:    all antimony results, thallium results for sample MQA475,
selenium results for samples MQA470, 475, 480, and 488, and
cadmium results for samples MQA475, 476, 477, 484, and 485
Unreliable:     thallium results for sample MQA477  and all selenium results

4.1  TCP Metals

Quantitative:   all aluminum, beryllium, iron, magnesium, and  sodium results,
               barium, calcium, cobalt, copper, manganese, nickel, and zinc
               results with exceptions, and vanadium results for samples MQA475
               and 477
Semi-quantitative:   all potassium results, vanadium results with exceptions,
                    and barium calcium, chromium, cobalt, copper, manganese,
                    nickel, and zinc results for samples MQA475 and 477
Qualitative:    chromium results with exceptions
Unreliable:     all silver results

4.2 Mercury

Quantitative:   mercury results with exceptions
Semi-quantitative:   mercury results for samples MQA475 and  477

4.3 Jnorganic and Indicator Analvtes

Quantitative:   cyanide, TOX, and POX results  with exceptions, all  sulfate,
               chloride, and ammonia nitrogen results, and total phenols
               results for samples MQA466, 467, 469, 471, 473, 475, 476, 477,
               487, and 489
Semi-quantitative:   all  nitrate nitrogen, nitrite nitrogen, and  bromide
                    results, TOC results for samples MQA467, 473,  475, 476, 477,
                    483, 487, and 489, and TOX results for samples MQA470, 471,
                    472,  476, 478, 479, 480, and 486
Qualitative:    total phenols results for  sample MQA468, TOC results for sample
               MQA466, all POC results, and POX  results for  sample MQA467
Unreliable:    cyanide  results for samples MQA470 and 475, total phenols
               results for samples MQA465, 470, 472, 474, 478, 479, 480, 481,
               483, 484, 485, 486, 488, and 490, TOC results with the above
               exceptions, and  POX results for samples MQA466, 473, and 477

4.4 Organic;

Quantitative:    all volatiles results
Semi-quantitative:    semivolatiles results with exceptions
Qualitative:    semivolatile acid  fraction results for samples Q1265, 1270,
 1271, 1273, 1278, 1279, 1280, 1285, and 1286, all positive                  dioxin
results
Unreliable:     all pesticides results, all negative dioxin results


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sample fractions.  There is a possible enhanced probability of false negatives for
pesticides based upon chromatography.  The presence of pesticides at this type of
facility (wood treatment) is unlikely.

3.6   Dioxins

     Recoveries of dioxin spikes by the organics laboratory appear to be
quantitative (99.9  to 119 percent recoveries).  No contamination was found in the
dioxin blanks.  Dioxins sample data were  missing for samples Q1267, 1268, and 1276.

     The holding  times until extraction and analysis was exceeded for all
reextractions and  reanalyses by 9 to 22 days for reextraction and  0 to 1  day for
reanalysis (samples Q1266, 1275, 1277, 1285, 1287, and 1287Dup were the only
samples reextracted and reanalyzed).

     Based upon past PE samples, a significant problem, possibly  adsorption of the
dioxins and dibenzofurans to the w:Uls of the  sample bottle, is probably  affecting
(diminishing) the concentration of the dioxins in the field samples.  Although
dioxins were detected in five of the field samples, the probability of false negatives
in the other samples is unacceptably high.  The positive dioxin results should be
considered  qualitative.  There is a high probability of false negatives in  the  non-
detect dioxins results.
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 IV.   References

 1.    Organic Analyses:    CompuChcm Laboratories, Inc.
                         P.O. Box 12652
                         3308 Chapel Hill/Nelson Highway
                         Research Triangle Park, NC 27709
                         (9J9) 549-8263

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

2.    Quality Control Data Evaluation Report for Koppers, Arkansas, 10/27/1986,
     Prepared by Lockheed Engineering and Management Services Company, Inc., for
     the US EPA Hazardous Waste Ground-Water Task Force.


3.    Draft Inorganic Data Usability Audit  Report and Draft Organic Data Usability
     Report, for the Koppers, Arkansas site. Prepared by Laboratory Performance
     Monitoring Group, Lockheed Engineering and Management Services Co., Las
     Vegas, Nevada, for US EPA, EMSL/Las Vegas, 10/27/1986.
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V. Addressees

Ed Berg
Chief, Project Management Section, Quality Assurance Branch, EMSL/CI
US Environmental Protection Agency
26 West St. Clair Street
Cincinnati, Ohio  45268

Anthony Montrone
Hazardous Waste  Ground-Water Task  Force, OSWER (WH-562A)
US Environmental Protection Agency
401 M Street S.W.
Washington, DC 20460

Gareth Pearson
Quality Assurance Division
US EPA Environmental Monitoring Systems Laboratory - Las Vegas
P.O. Box 1198
Las Vegas, Nevada  89114

Richard Steimle
Hazardous Waste  Ground-Water Task  Force, OSWER (WH-562A)
US Environmental Protection Agency
401 M Street S.W.
Washington, DC 20460

Robert Forrest
US Environmental Protection Agency
1201  Elm Street
Dallas, TX  75270

Paul  Friedman
Characterization and Assessment Division, OSW (WH-562B)
US Environmental Protection Agency
401 M Street S.W.
Washington, DC 20460

Chuck Hoover
Laboratory Performance Monitoring Group
Lockheed Engineering and Management Services Company
P.O. Box 15027
Las Vegas, Nevada  89114
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                                 Tahle F-l

               SUMMARY OF CONCENTRATIONS  FOR COMPOUNDS  FOUND
                  IN LOW LEVEL GROUND-WATER AND SAMPLING
               BLANK SAMPLES AT SITE #31, Koppers,  Arkansas
The following tables list the concentrations for compounds analyzed for
and found in samples at the site.  Table A2-1 is generated by listing
all compounds detected and all tentatively identified compounds reported
on the organic Form I, Part B.  All tentatively identified compounds
with a spectral purity greater than 850 are identified by name and
purity in the table.  Those with a purity of less than 850 are labeled,
unknown.

Sample numbers are designated by the organic and corresponding inorganic
sample number.  Organic sample numbers are preceded by the prefix "Q;"
inorganic sample numbers are preceded by the prefix "HQA."
                                  F-16

-------
                                 TABLE KEY
     Value without a flag indicates a result above the contract required
     detection limit.

J    Indicates an estimated value.  This flag is used either when
     estimating a concentration for tentatively identified compounds
     where a 1:1 response is .assumed or when the mass spectral data
     indicated the presence of a compound that meets the identification
     criteria but the result is less than the specified detection limit
     but greater than zero.  If the limit of detection is 10 tig and a
     concentration of 3 vg is calculated, then report as 3J.

6    This flag is used when the analyte is found in the blank as well as
     a sample.  It indicates possible/probable blank contamination and
     warns the data user to take appropriate action.
GW = ground-water
SW - surface-water
low and medium are indicators of concentration.
                                 F-17

-------
SITE:    «3i
CASE mi 4253
        no:
 SA«DL£  LOCATION
 SA*PL£  TYPE:
                                       Q1273'K(to473   Q12S7/«Q*497
                                       VEL1 «*      WELL K-5*      EW!
                                       FIELn PLA*'^    FIELT PLA«ff    E2L'!P
VOA
        ACETWE
        BEK2EKE
        ETHYL PEHZEHE
        2-PUTANWE
        CHLOROFORM
        METHYLENE CHLORIDE
        Iflrl-TRlCHLOROETHWC
        TOLUENE
        XYLEHES» TOTAL
SEKJ-
WA
        ACENAPHTHYLENE
        ANTHRACENE
        PEKZDIC ACID
        P£f!20(P)FLLlORAKTH£HE
        PEHZO(K)FLUORAKTH£N£
        BEKZDF
TIC-    UW91WN
TIC-    'JHPECAHE' 4!~-r!METHYL
                                               5,4 JP!
                                               2,1 JP
                                                                                            7,8 .' I
                                      I(PL* E75)  2iJPI               I

                                                        F-1S
                                                                                                           130
                                                                                                            10
                                                                                                           310

                                                                                                           640  J

                                                                                                           140  J
                                                                                                          340 .'
                                                                                                          2?0  J
                                                                                                          240  J

                                                                                                          1200
                                                                                                          A4A J

                                                                                                          210 J

-------
SHE:   «3! r.opPEP.s-
CASE KG: 6253
SAMPLE NC:
SA*Dif LOCATION:
       TYPE:
WILL f-2A      WELL M-5P      E001
FIELI1 PLANK    FIELP PLANK    E&'IP,
                      TRIP PL
                      «/ELL *-i:
                      P'^LICATE
SEHI-   fllBENZOTHIflPHEKE
VM     2.3-PIMETHTLPHENOL
        PECEHEr  2-Pf?OPEHTL
        BEKZENEf  1-PROPYNYL
        PEH20(P)THIOPHENE
        HEPTAKEr  2H-PIHETHYL
        KHZENEt  l-£THENYL-2-«ETHYL
        PHENOL. HHHYL SUBSTITUTED
        PHENOL. KETHYL SUBSTITUTE!!
        NAPHTHALENEr  1.3-PIMETHYL
        2UH) QUINOLINONE
        QUINOLINI/ISOOUINOLINE
        PEfCENI ACETONITRILE
        1H-INPENE
        1H-INPENE.  1-ETHYLIIiENE
        2-HETHYLQUINOLIHE
        11H-PEH20(A)FLUPRENE
        1-PHTHALAZINAMINE
        2.4.6-TRI«ETHYL!lECAHE
        UNKNOWN
        UNKNCWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
                      (PW 939)  12J
                                     (PUR920) 360J
                                     (PW920.U400J
                                            890 J
TOTAL   ALUNKMi
tSTALS  ANTIMONY
        ARSENIC
        BARIW
        BERYLLIUM

        CA?M!L»(
        CALCIUM
        CHROMIUM
        CQPA1T
        COPPER
        209


          8


        0,5
270
380
224
221
6.1
               200
79500

   11

    2

  S,7
£2700

   It
                                                       F-19

-------
SITE:   «3i  WPERSI
CASE NO: 6253
sa«! »:
SAMPLE LOCATION:
SAMPLE TYPE:
IRON
LEAP
MAGNESIUM
MANGANESE
MIRCURY
NICKEL
POTASSIUM
SELENIUM
SILVER
SODIUM
THALLIUM
VANAPItM
ZINC
01273 'MGA473
WELL h-2A
FIELP BLANK




0,2




648



Q1267/HGM8''
WELL M-5B
nar fim
46








825



D1M1/MQA481
E001
EQUIP, BLANK




0,2




409



Q12»0/MQ*4»0

TFIP BLANK




0,2




766



Q126^MOA4i6
KLL h-lC
WPLICATE
7POOO
41,9
22POO
1440
0,4
49
14600


28500

152
276
1NORG,   AMMONIA  NITROGEN
1HPIC,   BROhIK
        CHLOP.IPE
    .    CYANIDE
        NITRATE  NITROGEN
        NITRITE  NITROGEN

        POC
        POX
        SULFATE
        TOC
        TOTAL PHENOLS
        TOX

        CARBONATE
        BICARBONATE
  20
1000
  13
3100
  17
                            55000
    5
 5000
leooo
 10BO
   10
                                                         F-20
 *LL

-------
SITE: tz: KOPEKS* A^WSAE
CASE NCI 6253
SWPLE MO!
SA*>L£ LOCATION:
SAMPLE TYPE:
VOA ACHONE
PEKZENE
ETHYL PENZENE
2-PtrtANDNE
CHLDROFOW
NETHYL£NE CHLORIK
4-HETHYL-2-PENTANDNE
Iflrl-TKICHLOROETHANE
TOLUENE
XYLINESf TOTAL
KM- ACENAPHTHENE
VOA ACENAPHTHYLENE
ANTHRACENE
PENZOIC ACIP
PENZO( A) ANTHRACENE
PENZOCP)FLIK»?!AVTHENE
PENZO(K)FLUORANTHENE
PENZO(A)PYRENE
PIS(2-£THYLHEXYL»PHTHALATE
CHRYSENE
PIPENZOFURAN
n-'N-PUTYLPHTHALATE
Dl4rOCTYLPHTHALAT£
1,4-!>ICHLOROBENZ£NE
FLUOKNE
FLUORANTHENE
2»4-I)ICHLOROPKENOL
NAPHTHALENE
2-«ETHYLNA?HTHAL£NE
H-NITRCS05IPHEHYLAMNS
PHENOL
2HETHYLPHEMOL
4-HETHYLPHENOL
2»4-P!METHYLPHENOL
PHENANTHRENE
PYRENE
PENTACHLOROPHENOL
PEST/ NO HITS
PtP
DIOXIN/ TOTAL *CPP
FURAN TOTAL HxCM
TOTAL OCPP
TOTAL HxCDF
TOTAL H-CDF
TOTAL OCD"
TIC- l»K»WN
VOA-PT


01269/WW469
WELL ^1C
PLPLICATE

K
120


2,4 J
*

36
270
390 J









180 J
110 J
300 J

150 J


9600
300 J





420 J










1
•


Q1267/MA467
WELL MP
KPLICATE
21 J
290
390


170
11 J
5,6 J
400
680
250 J









100 J






9200
580 J

3800
4600
7400
4300















01289/WOA489
WELL F-4P
DUPLICATE
21 J
260
350


85
10 J

350
800
360 J









120 J






12000
660 J

2900
3400
5800
3200






1








Q1265/MM65
WELL f»-5P
W-LOW










17/8,8 J







6,6 J

5,8 J



5,4 J
• 10/7 J








6,6 J
5,8/3.2 J













0126E'«S*46e
WELL M:
Sfr-LOV
4,6 J
26
82


3 J



68
260 J
















6100
290 J
110 J





































































TIC-    WPECAWE* 4./-!'!«• THYL
                                                       F-21

-------
 SITE:    13!  rPPE'S-  ARMWSAE
 CASE KOI  £253

 SAMPLE NO:
 SWIPL£ LOCATION;
 SAMPLE TYPE:
                               Q1269/MQA4i9
                               WELL MC
                               PLICATE
WELL MB
WPLICATE
Q12?9/MQA4P«
WELL MB
DUPLICATE
WELL f-5
WEIL MC
6W-LDW
 SEW-   FIBENZDTHIOPHEHE
 WA     2.3-PIMETHYLPHENOL
        fEKZE«E» 2-PROPENYL
        BENZENE. 1-PROPYHYL
        BEK20(B)THIOPHEHE
        HEPTAHE. 2»4-riNETHYL
        BE«ZEKE» l-CTHEWYL-2-flETHYL
        PHENOL r METHYL SUPSTITtfTEIi
        PHENOL» METHYL SUBSTITUTE!!
        NAPHTHALENE. li3-DUOHYL
        2(1H) QL'INOLINONE
        DUINOLINE/ISOO'JINOLINE
        BENZENE ACETONITRILE
        1H-INPENE
        1H-INPENE.  1-ETHYLIBENE
        2-KETHYLGL'INOLINE
        11H-BEKZO(A)FLIK«!ENE
        1-PHTHALAZINAMINE
        2r4f6-TR!«ETHYLI»ECANE
        WWKWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
                               
-------
 SITE:    «3i MJP?ERS»
 CASE WO:  6253
SAMPLE NCI
SWPLE LOCATION:
SAMPLE TYPE:
IRON
LEAP
HA6NESIUM
MANGANESE
HfRCURY
NICKEL
POTASSIUM
SELENIUM
SILVER
SODIUM
THALLIUM I
VANADIUM 1
ZINC 1
01269/KOA469
WELL MC
WIIMTE
75500
42,1
22700
1430
0,3
48 .
13900
4,5

28400

141
285
Q1267/WA467
WELL *-4i<
DUPLICATE
42200
13,1
24000
1470
0.3

7290


67200


se
G12P9/MOA4P0
WELL fc-4F
PLICATE
39900
11.5
22700
1450


6200


66400


22
WELL f-5?
6H.W
60300
26.1
19300
1°00
0,5
37
10100


2?5W

59
308
Q12iB'HOA46E
WELL M:
6¥-L»
15500
5.5
7730
731
0,7

2320


12600


1G














INORG,  AMMONIA NITROGEN
INDIC,  BROMIDE
        CHLORIDE
        CYANIDE
        NITRATE NITROGEN
        NITRITE NITROGEN

        POC
        POX
        SULFATE
        TOC
        TOTAL PHENOLS
        TOX

        CARBONATE
        BICARBONATE
470

57000



650
14000
475
26


2500
70
30500

3900
32

134000
19000
305


2500

25000
750
250

32500
134000
19800
22


230
150
44300
130


32500
1500
40



330

20600

720


13000
156
20
1

                                                          F-23

-------
£IT£.' 131 KO^^ERS- A*?K£**SA:
CASE tic: 6253
SAMPLE HO:
SA«°L£ LOCATION
SAMPLE TYPE:
VOA ACETONE
PEKZENE
ETHYL PEKZENE
2-WTANONE
CHLOROFORM
METHYLENE CHLORIPE
4-«ETHYL-2-PENTA«WE
hhl-TRICHLOROETHAHE
TOLUENE
XYLENESf TOTAL
SEMI- ACENAPHTHENE
VOA ACEHAPHTHYLEKE
ANTHRACENE
PEHZOIC ACIP
PENID(A)ANTHRACENE
BENZO(B)FLUORANTHEKE
P£KZD(K)FLUORANTHEN£
PEKZD(A)PYRENE
PIS(2-ETHYLH£XYL)PHTHALAT£
CHRYSENE
HPENZDFURAN
PI-trPUTYLPHTHALATE
1T4-PICHLOROPEMZENE
FLUOPINE
FLUORAHTHE>i£
2»4-P!CHLDRDPH£NOL
NAPHTHALENE
2-«£THYLNAPHTHALENE
PHENOL
2-MITHYLPHENOL
4-HETHYLPHEKOL
2f4-IiIMETHYLPHENOL
PHENAKTHF5NE
PYRENE
PEHTACHLOROPKffflL
PEST/ NO HITS
PCP
PIOXIN/ TOTAL tKDD
FURAN TOTAL HxCPP
TOTAL OCPP
TOTAL HxCPF
TOTAL HfCPF
TOTAL O:DF
TIC- WKMCWN
VWrPT


G1270/MOA470
YELL P-5
ew-Loy
1 9.4 JP




4.5 JP
'








































Q1271'«GA47!
WELL P-5F
6W-LOW
1 6.2 JP




1,6 JP












2.' J




























01272 'NSA472
YELL ^2F
6*-LW
1 6.6 JS




2,6 JP




































1
1
1


Q1274'«0*474
YELL f-lf
W-LW
1 3.6 JS
1.6 J
l.P i






1 8
110

26 J







:>40


.'230
58 J

1JOO
120




350
28 J



0,013

0,072

0.023
0.04B




Qi-vn/finw-*
LA50O' tl

1 250 1
2,8 J
25
24




21
130
2000

1900
660 J
930
660 J
660 J
310 J

960
1200


1700
4300

12000
1BOO
3900
6700
11000
1300
7500
3900



0.225

0,659

0,04
O.OP5
If J

TIC-    IW!'£CAM» 4'7-FIKETHYL
I (PI'S  E74)  !9JPI(F1!£  867)  IBJPKPL* 654) 23JP!
                     F-24
 . i  -r,..-rwT;'TTr,^r  ;,::

-------
SITE:    13:  UPPERS-
CASE NO!  625:

SAfcPLE NCI
SA^LE LO:ATIW:
SAMPLE TYPE:
SEMI-   MBENZDTHIDPHEKE
VGA     2»?-Dl«ETHYLPHENQL
        PENZENEt 2-PROPEKYL
        BEKZEKEf l-PWPYNYL
        PEKZOWTHIOPHBE
        KPTANE* 2»4-I>I«E7HYL
        PEfGENEf l-£THENYL-2-«ETHYL
        PHENOL* KETHYL SUPSTITUTEP
        PHENOL* JETHYL SUPSTITUTEI>
        NAPHTHALENE. lf3-n«ETHYL
        2(1H) QUINOLINWE
        QUINOLINE/ISOQUINOLINE
        PDC£« ACETONITRILE
        1H-INPENE
        1H-INI»EHE» 1-HHYLIPENE
        2-HETHYLQUINOL1NE
        11WEH20(A)FLUOR£KE
        1-PHTHALAZ!NA«!NE
        2»4»6-TRHCTHYLKCAHE
        IWKNOVN
WELL f>-
        IMHDUN
        IWKHOW
        UNKHOWN
        UNKNOWN
        UNKMWN
        WKNOUN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        L
-------
£IT£'
CASE *
SAMPLE
SAMPLE













INORG,
INDIC.












:: 6253
LOCATION: WELL F-S
TYPE: BH.W
IRON 77000 !
LEAD 50.4
MAGNESIUM 53900 1
MANGANESE 1010
MIRCURT 0,4 I
NICKEL 93
POTASSIUM 20300 ' 1
SELENIUM 16 1
SILVER 1
SODIUM 96700
THALLIUM I 1
VANADIUM 1 190
ZINC 1 262 1
AMMONIA NITROGEN
BROMIDE
CHLORIDE 1500
CYANIK 10
NITRATE NITROGEN 1800
NITRITE NITROGEN
POC
POX
SULFATE 45000
TOC 2000
TOTAL PHENOLS 21
TDX 19
CARBONATE 1
BICARBONATE I
01271 'MQ*4?1
WELL P-5*
GtHW
12100
7.1
14300
1290
0.3

4430


21500


46
200
70
11400

160



49000
1000

16


01272 '«9W2
WELL fc-2P
6H.W
2«eo

12300 1
E32
0,2 1

3400


20SOO


49 I
1 120
80
1 20400

1 50
1
1
I
1 43000
1 3600
1 15
1 13
1
1
WELL f-lP
13500
e.e
12000
1510
0,2

3190


23600


64
1200
120
33000

1900



1£300
4400
74
13


G^TS/WWS
LAGOON »1
191000 1
1728
12700
10°0
1,2
151
14600


50900

98
5340
6400

50000
20
4000

2400

45000
391000
232
66


                                       F-26
IWS AF:E  IN »S/L.

-------
                    AfiMWSAE
CASE MCI 6253
SAMPLE NO!
SA*IE LOCATION:
SAMPLE TYPE:
WA ACETONE
PEH2ENE
ETHYL PENZENE
2-BUTANONE
CHLOROFORM
HETHYLENE CHLOP.IPE
4-HETHYL-2-PENTANOKE
Iflrl-TRICHLOROETHANE
TOLUENE
XYL£NES» TOTAL
SEMI- ACENAPHTHENE
VDA ACENAPHTHYLENE
ANTHRACENE
BEKZOIC ACIP
BENZO(A)AKTHRACENE
BEN20(P)FLUORANTHENE
PEHZO(K)FLUORANTHENE
PEKZO(A)PYRENE
BI S (2-ETHYLHEX YL ) PHTHAL ATE
CHRYSENE
PIPEHZOFURAN
PI-f-'PUTYLPHTHALATE
DUHJCTYLPHTHAIATE
1?4-PICHLORDBENZENE
FLUORENE
FLUQftANTH£NE
2»4-PICHLOROPHENOL
NAPHTHALENE
2-HETHYLNAPHTHALEKE
N-NITROSOPIPHENYLANINE
PHENOL
2-KETHYLPHENOL
4-*£THYLPHENOL
2'4-PIMTTHYLPHENOL
PH£HANTHP£N£
' PYPIHE
' PENTACHLOROPHINOL
PEST/ NO HITS
'PCB
PIOXIN/ TOTAL H»CPP
'FURAN TOTAL HxCPP
TOTAL OCPP
TOTAL HxCPF
TOTAL H»CPF
TOTAL OCPF
TIC- UNKNOWN
VOA-PT
KLL ^1A
W-OIL*
12
110
130

1,3 J

3,5 J

140
150
3400

1100 J

560 J




660 J
3000



3000
4200

19000
4000


S20 J

980 J
1000
2300










1
LAGOOf 42
30
1.4 J
4.3 J





6,8
6.6
3200
ieo j
3900

3900
1600
2000
1700

4600
2300



4100
18000

2500
1400 J




450 J
1900
18000



0.3B3
0,033
1,359
0.038
0,123
0,156
1 14 J

KLL f-2C
6*-LN
5,9 JP




1.3 JP












11/8,8 J






















_





WELL ft-2A
GW-LOW
5,3 JP




1,3 JP












2,2 J





_






















WELL P-2
5.9 JPI




1,2 JP









































TIC-    'JNPECANI.  4./-PIMTTHYL
    rncTi.'T:..'.TTnuc  ACT  T4- .../
                                                           F-27

-------
S:TE:   »21 KIPPERS'  A*C.A«SAS
CASE «t 6253
SAf^LE NO:
SAf LE LOCATION:
smE TYPE:
SEW- PIBENZDTHIOPHIN£
VOA 2>?-IiIM£THYU>HENQL
BENZENE f 2-PROPENYL
BENZENE r 1-PRDPYNYL
PENZO(B)THIOPH£NE
HEPTANE* 2»4-PI«ETHYL
BENZENE* l-ETHENYL-2-METHYL
PHENOL* KETHYL SUBSTITUTED
PHENOL* METHYL SUBSTITUTE!*
NAPHTHALENE* li3-DIMETHYL
2(1H) OUINOLINONE
QL'INOLINE/ISOQUINOLINE
PEKZENE ACETONITRILE
1H-INPENE
1H-INMNE* 1-FTHYLIPENE
2-«ETHYLOUINDLlNE
llh-PEHZO(A)FLUDP£NE
l-PHTHALAZINA«If(E
2»4f6-TRI«ETHYLTECANE
IWKNOUN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
. UNKNOWN
UNKNOWN
UNKNOWN
Q1276/tW
-------
SITE: f' KOPPERS* ARKANSAS
CASE NO: 6253
SWPLE NO:
SAfltu LOCATION:
SAMPLE TYPE:
IRON
LEAP
MAGNESIUM
MANGANESE
HfRCURY
NICKEL
POTASSIUM
SELENIUM
SILVER
SODIUM
THALLIUM
VANADIUM
ZINC
INDRG, ASHONIA NITROGEN
INTIC, BROMIDE
CHLORIDE
CYANIDE
NITRATE NITROGEN
NITRITE NITROGEN
POC
POX
SULFATE
TOC
TOTAL PHENOLS
TOX
CAPJONATE
BICARBONATE
Q1276/MM476
WELL MA
6WOIW.















147000

5000

1000

30000
339000
5900
184


012^7 /HQA477
LABOOf 12
391000
1630
29000
5B20
2
419
33500


92000
63
275
177W
4500

155000

6000

87000
6
110000
267000
750
356


WELL h-2C
22500
5.1
14100
1440
0,5

3460


21500


28
200
80
22500





36000
3300
15



WELL f-2A
P700
1 17,6
27700
1780
0,4

6690


17300

38
59
200
60
4900

90



27000
2100
13
6.3


WELL P.-2
6V-LW
40300
13.9
1B6000
17400
0,4
53
1C500
3,6

2000000

65
100

5500
460000





75000
2900
28
59


                            F-29
A
AP
ys/L.

-------
SITE:    t3: ROGERS-
CASE M: 6253
SAWJ w:
SAMPLE LOCATION:
SA«IE TYPE:
                                     WELL ^
Q1284/HW4W   01255/HOA4B5   01286'MDHB6
WELL K-3F      WELL f-5A     WELL P-6       WELL MA
6W-LOW         ffr-LW        6W-LOW         6W-LOV
SEMI- riPENZOTHIOPHENE
VOA 2.3-riMETHYLPHENOL
BENZENE. 2-PR0PENYL
BENZENE. 1-PKOPYNYL
PENZO(P)THIDPHENE
HEPTANE. 2.4-PINETHYL
BENZENE. l-ETHENYL-2-METHYL
PHENOL. METHYL SUPSTITlfiED
PHENOL. METHYL SUBSTITUTED
NAPHTHALENE. 1.3-D1METHYL
2(1H) OUINOLINONE
fit'INOLINE/ISOQUINOLINE
PENZENE ACETONITRILE
1H-INDENE
1H-INDENE. 1-ETHYLIPENE
2-MnHYLQL'lNOLlNE
11H-PENZO(A)FLUORENE
1-PHTHALAZINAMINE
2.4.6-TRIMETHYLPECANE
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
1





•







































































1


















23 J
33 J
51 J
15 J
100 J
33 J
46 J
23 J
43 J
20 J
17 J
27 J
35 J
34 J
34 J
23J
32 J
36 j
19 J
29 J
,
1
I (PUP 91 3) 45J
KPUf: ?H) 15J
KPUR P?5) 14J




(PUR 6?1) 23J









16 JP
14 j
10 J
27 J
17 J
16 J
11 J
12 J
15 J
2? J
13 JB
10 J
20 J
52 J













































TOTAL   ALUKINUH
METALS  ANTIMONY
        ARSENIC
        BAPJUK
        BERYLLIUM

        CADMIUM
        CALCIUM
        CHROMIUM
        COBALT
        COPPER
20500

162

2
31000
25


B520

226

7,1
41100



313000
27.1
2690
12
3,5
166000
344
130
2S1
16400
366
316

M.I
136000
604

61
170*00

fi*8
6
1.7
164000
206
53
63
                                                        F-31
                   :r TU i.-

-------
SITE:    «3i  ROGERS.
CASE w: 62S3
SAMPLE NO!
SAMPLE LOCATION:
SAMPLE TTPE:
IRON
LEAP
MAGNESIUM
MANGANESE
MERCURY
NICKEL
POTASSIUM
SELENIUM
SILVER
SODIUM
THALLIUM
VANADIUM
ZINC
012H/WMB3
WELL f-3A
W-LOW
15900
13.5
19500
317
0,6
•
4310


21800

25
57
01284/MQA484
WELL fc-3*
W-LOW
7340
7,6
16700
37°
0,3

3040


21000


49
Q12B5'«OA4e5
WELL M-5A
W-LW
278000
78
230000
10200
0,5
319
56400


176000

5B2
721
C1266/MQA4B6
WELL f"6
6V-LW
35300
89,6
19900
2550
0,6

13900


49500

22
2350
Qi2ee/M0*4ee
WELL fMA
W-LW
113000
75
150000
2060
0,2
130
37800
5,9

165000

299
397
INORG,  AMMONIA NITROGEN
INDIC,  BROMIDE
        CHLORIDE
        CYANIDE
        NITRATE NITROGEN
        NITRITE NITROGEN

        POC
        POX
        SULFATE
        TOC
        TOTAL PHENOLS
        TOX

        CARBONATE
        BICARBONATE

90
122000
840

20000

16
6,1

50
1000


5000
1800
32


430
115000
100

16000
15000
39
216
800

2000
150
900
10200
14000
74
36

5000
83000
2000

110000
9300
24

                                                         F-32

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