May 1988                         EPA-700/8-88-044
Hazardcxjs Waste Ground-Water
Task Force
Evaluation of
Chemical Waste Management, Bnc
Vickery, Ohio
fjf tHr\
            United States Environmental Protection Agency
            Ohio Environmental Protection Agency

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                                MX 1988
          DPEKIE OF THE HAZARDOUS HASTE GRCKHDNAQER TASK FORCE
        EVALUATION OF CHEMICAL WASIE MANAGEMENT, INC. - VICKERY
The United States Environmental Protection Agency's (U.S. EPA.)
Hazardous Waste Groundwater Task Force ("Task Force"), in conjunction
with the Ohio Environmental Protection Agency (OEPA),  conducted an
evaluation at the Chemical Waste Management, Inc. - Vickery (CWM-V)
hazardous waste disposal facility.  The Task Force effort is in
response to recent concerns as to whether owners and operators of
hazardous waste disposal facilities are complying with the Resource
Conservation and Recovery Act (RCRA) groundwater monitoring
regulations, and whether the groundwater monitoring systems in place at
the facilities are capable of detecting contaminant releases from waste
management units.  CWM-V is located near Vickery, Ohio, approximately
seventy-five miles west of Cleveland.  The on-site field inspection
began on April 6, 1987.

This update of the Task Force evaluation summarizes subsequent events
that are directly related to hazardous waste groundwater monitoring
issues.

The Task Force evaluation of CWM-V revealed several violations and
deficiencies.  The details of each violation and deficiency are
explained in the text of the Task Force report.   U.S.  EPA sent a letter
to CWM dated June 18, 1987, notifying them of the violations identified
during the Task Force evaluation and informing CWM that the Vickery

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                              - 2 -
facility is unacceptable to receive waste from response actions taken
under the Comprehensive Environmental, Response, Compensation, and
Liability Act  (CERCLA) in conjunction with the U.S. EPA Off-site
Policy.   CWM responded in a letter to U.S. EPA dated July 10, 1987,
explaining that none of the violations cited in U.S. EPA's letter are
justified.  On August 27, 1987, U.S. EPA sent a letter to CWM stating
that the Agency does not concur with CWM's conclusion that the
violations are unjustified.  In addition, the Agency reminded CWM of
Paragraph O of the Consent Agreement and Final Order between U.S.  EPA
and CWM  dated  April 5, 1985, that subjects CWM to payment of stipulated
penalties from the date of the violations.  CWM responded to the Agency
in a letter dated. September 4,. 1987, stating that they believe that the
facility is in compliance with the Consent Agreement and Final Order
and therefore, have no obligation to pay any stipulated penalty.
U.S. EPA is currently considering the appropriate action concerning
the observed violations.

Paragraphs H(ll) and H(12) of the Consent Agreement and Final Order
states that CWM shall submit the results of each semi-annual analyses
and a report on the same to U.S.  EPA and OEPA within thirty (30)  days
after receipt of all such final results.  CWM submitted a report to
U.S. EPA dated April 1988 entitled "ttonitoring Well System, Analytical
Data Evaluation, Vickery, Ohio Facility".   This report is an evaluation
of the chemical analysis results from CWM's monitoring wells sampled in
April 1986, October 1976, April 1987, and October 1987.  U.S.  EPA is
currently reviewing the report to determine its technical adequacy.

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                              - 3 -

The construction of a disposal cell for the placement of wastes

contained in the temporary waste pile and the placement of those wastes

into the cell is described in Phase II of the Closure Plan for Surface

Impoundments 4, 5, and 7.  The Region V RORA Permitting Branch issued

an approval of the Phase II Closure Plan dated March 30, 1988.  The

approval letter also contained several conditions of approval with a

staggered schedule for completions of each condition.


CWM is also required to receive a Toxic Substances Control Act (TSCA)

Landfill Authorization from Region V prior to the placement of waste

into the proposed disposal cell.  Region V TSCA personnel are currently

reviewing the proposal; consequently, a landfill authorization has not

been issued to date.


CWXR7 is required to sutmit a no-migration petition under RCRA, if it

intends to inject wastes that are subject to the land disposal

restrictions that apply to Underground Injection Control (UIC) wells.

The regulations require owners/operators who desire to inject

restricted wastes to submit a demonstration showing that:


     (1)  The hydrogeological and geochemical conditions at the site
          and the physiochemical nature of the waste streams(s) are
          such that reliable predictions can be made that:

          (i)  Fluid movement conditions are such that injected fluids
               will not migrate within 10,000 years:

                (A)  Vertically upward out of the injection zone; or

                (B)  Laterally within the injection zone to a point of
                    discharge or interface with an underground source
                    of drinking water (USEW); or

          (ii)  Before the injected fluids migrate out of the injection
/               zone or to a point of discharge or interface with an

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                              - 4 -

                USDtf, the wastes will no longer be hazardous because
                the hazardous constituents will have been attenuated or
                iimobilized within the injection zone by hydrolysis,
                chemical interactions or other means.

CWPfr-V submitted a no-migration petition to U.S. EPA on April 29. 1988.

U.S. EPA is currently reviewing the petition.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
   HAZARDOUS WASTE GROUND WATER TASK FORCE
           GROUND WATER EVALUATION
       CHEMICAL WASTE MANAGEMENT,  INC.
                VICKERY, OHIO
                   MAY 1988
               JOSEPH J.  FREDLE
             PROJECT COORDINATOR
     U.S.  ENVIRONMENTAL PROTECTION AGENCY
                   REGION V
       ENVIRONMENTAL SCIENCES DIVISION
           EASTERN DISTRICT OFFICE
                WESTLAKE, OHIO

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                                TABLE OF CONTENTS

                                                                             Page

 I.  EXECUTIVE SUMMARY 	       1

     A.  Introduction  	       1

     B.  Objectives    	       1

     C.  Investigative Methods 	       2

     D.  Task Force Findings & Recommendations 	       3
         1.  Waste Management Units                                            3
         2.  Ground Water Monitoring System                                    3
         3.  Ground Water Assessment                                          "4

     E.  RCRA Permit	       4

     F.  Compliance with Superfund Offsite Policy  	       5


II.  TECHNICAL REPORT  	       6

     A.  Introduction	•	       6

     B.  Objectives    ."	       6

     C.  Investigative Methods   	       7
         1.  Technical  Review Team                                             7
         2.  Laboratory Evaluation Team                                        9
         3.  Sample Collection Team                                            9

     D.  Waste Management Units  	       9
         1.  Introduction                                                      9
         2.  Surface Impoundments                                            11
         3.  Abandoned Oil  Recovery Facility and Sludge Farm                 14
         4.  Injection Wells                                                 14

     E.  General  Geology   	     19
         1.  Previous Investigation                                          19
         2.  Glacial  Overburden                                              20
         3.  Bedrock                                                         22

     F.  Hydrogeology	     23
         1.  General                                                          23
         2.  Ground Water Flow in the Bedrock                                24
         3.  Ground Water Flow in the Glacial Overburden                     25
                                        ii

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                         TABLE  OF  CONTENTS  (continued)

                                                                            Page

    G.  Ground Water Monitoring System   	      26
        1.  Historical Ground Water Monitoring  System                        26
        2.  Current Ground Water Monitoring  System                           27
        3.  Sampling and Analysis                                            32

    H.  RCRA Permit (40 CFR 264 and 270)	      35

    I.  Task Force Sampling	      36
        1.  Methods                                                          36
        2.  Sampling Location                                                40
        3.  Scheduling                                                       40

    J.  Ground Water Quality Interpretation  	      41
        1.  Task Force Analyses                                              41
        2.  Data Interpretation                            '                  42


REFERENCES	      53

TABLES

FIGURES

APPENDICES
                                       iii

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 I.   EXECUTIVE  SUMMARY
 A.   Introduction
     Operations at   hazardous  waste   treatment,   storage,   and   disposal   (TSD)
 facilities are  regulated under the  Resource Conservation  and  Recovery Act  of
 1976  (RCRA),  42  U.S.  6901 et.seq.   Implementing  regulations  which were issued
 on May 19, 1980 (40 CFR  Part 260 through 265, as modified),  established operating
 requirements for TSD facilities  including the monitoring of ground water.  The
 Administrator of  the  United  States  Environmental  Protection  Agency   (USEPA)
 established a Hazardous  Waste Ground  Water Task Force  (referred  to hereafter  as
 Task  Force) to evaluate the level of compliance with  ground  water monitoring
 requirements at  on-site and commercial  off-site  TSD  facilities  and to  address
 the cause(s)  of  noncompliance.    In  addition  the  Task  Force  is to   examine
 the suitability  of  the TSD  f.acility  to receive  hazardous  waste  under the
 Comprehensive Environmental Response  and  Liability  Act (CERCLA)  or  Superfund
 program.

    The Task  Force is   comprised  of  personnel  from USEPA  headquarters, USEPA
 regional offices,  and  the  state's environmental  agencies.   This evaluation  is
of the  Chemical  Waste  Management,  Inc., facility  in  Vickery,  Ohio  (CWM-V).
B.  Objectives
    The objectives of the Task Force evaluation at CWM-V are to:  (1)  determine
compliance with the requirements  of Ohio Administrative Code 3745-65-90 through
3745-65-94 and 40 CFR 265 Subpart F - Ground Water  Monitoring, and the monitoring
system's capability of  providing  the required data; (?.} evaluate the facility's

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ground water  monitoring  program  as  described  in  the  RCRA  Part   B  permit
application for  compliance  with  40 CFR  Part  270.14  (c);  (3)  evaluate the
.facility's potential  compliance  with 40 CFR Part 264  Subpart  F;  (4) verify the
quality of the company's ground water monitoring data  and evaluate the sampling
and analytical  procedures;   (5)  determine  if any  ground  water contamination
currently exists from site operations;  (6) determine if  the facility is meeting
the requirements  of  the  Superfund  off-site  policy;  and  (7) evaluate  the
interrelationships of the  RCRA,  TSCA,  and  UIC  regulations  at  this  facility.

C.  Investigative Methods
    To accomplish  the objectives,  a Facility  Evaluation Team  was  assembled,
comprised of  a Management Team,  a Technical  (record)  Review Team, a Laboratory
Evaluation Team  (to  evaluate off-site  contractor  laboratories), and  a  Sample
Collection Team.   Each  team  had  individual  responsibilities  to achieve  the
objectives of the Task Force.

    The on-site facility inspection  began  on April  6,  1987,  and was  conducted
by three teams:   the Management Team, the Technical Review Team, and the Sampling
Team.  Off-site  inspections   were  conducted  at  contract  laboratories by  the
Laboratory Evaluation Team.

    The Task  Force contracted Planning  Research Corporation  (PRC)  of  Chicago,
Illinois, to  prepare  a  document  package  of  pertinent  background  information
from public information  sources (i.e., USEPA, and OEPA files).  The information
collected by PRC concentrated on site events since about 1978 (e.g.,  inspection
reports, hydrogeologic reports,  and  Part  B  application) and  projected  future
activities.  Information  obtained  from  CWM-V during  the evaluation   was  also

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reviewed to supplement the information in the public files.  By combining these

information sources, the  Technical  Review  Team was able to  perform  a  complete

evaluation of the facility with respect to ground water.


    This evaluation  considers  only  information  available at  the  time  of  the

investigation (April 1987) or before, unless specifically stated.


D.  Task Force Findings & Recommendations

    1.  Waste Management Units

        The pond to the east  of  the  hazardous   waste  pile  on site  contains
        hazardous waste and will  require proper RCRA closure.

        Hazardous waste from  the  pond  east  of  the  hazardous waste pile is
        pumped into pond  12.   Pond  12 does not  have  interim status  or  a  RCRA
        permit.

        The effectiveness of the confining   system  for the injection wells  has
        not been thoroughly addressed.

        The need for ground water  monitoring  of the injection wells should be
        thoroughly addressed and  evaluated  in detail  by CWM-V.

    2.  Ground Water Monitoring System

        It is recommended that  one bedrock   well  be installed near the  location
        of L-30  to accommodate  the change in ground water flow resulting  in  the
        operation of the truck  wash  well.

        It is recommended that  initially a  minimum of three lacustrine  wells
        be installed on  the east  side  of  the waste  pile  retention basin  to
        adequately monitor the  surface impoundment.

        The new  CAFO wells that have  been   installed   appear to have been ade-
        quately  constructed.

        A number of deficiencies   have been noted  in  the Sampling and  Analysis
        Plan of  CWM-V.   They  are discussed  in Section  G.3.  of the technical
        report.   The most  noteworthy  deficiency  is  that CWM-V requires total
        organic  carbon  and extractable organic  samples  to be  filtered.  This  is
        an inappropriate  procedure   which   should   be   corrected  immediately.

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        The usability of CWM-V's existing  data was evaluated by the Task Force
        and determined to be classfied as:

        Inorganic and Indicator Parameters - Qualitative
        Volatile Organics - Quantitative
        Semi-Volatile (extractable) Organics, PCBs, and Pesticides -
            Qualitative, Biased Low


    3.  Ground Water Assessment

        Specific organics  (e.g.,  methylene  chloride,  methanol, methyl ethyl
        ketone ...) have been found in the monitoring wells at CWM-V.

        o  The  lacustrine  zone  on site  is  contaminated  and  a  ground  water
           assessment plan is needed.

        o  Bedrock  background  well   MW-23RA is   contaminated  and  should  be
           relocated as a background well.

        o  Bedrock well P-10  shows  contamination  that  needs  to  be addressed in
           a grourtd water assessment plan.

        o  The  bedrock  ground  water  monitoring  system  indicates  periodic
           contamination.  Further study  is  needed  for this  ground  water -zone.

        As of the date of the  Task  Force inspection,  CWM-V has  not conducted
        a ground  water  assessment nor   submitted any  ground  water  reports
        evaluating the  rate  and extent  of migration  of hazardous  waste con-
        stituents identified  during  several  ground  water  sampling events  as
        required in 40 CFR 265.93 and  the CAFO.

        CWM-V had not submitted  ground  water monitoring results  for the April
        and October 1986 CAFO  sampling  to USEPA and OEPA within  30 days after
        receiving final results, as required in the CAFO.


E.  RCRA Permit

    The current application for  a  RCRA permit does not  include a ground water

monitoring program because CWM-V is seeking  a permit  for storage  and treatment

tanks and the UIC wells; these activities  do not require ground water monitoring

under RCRA.   The  hazardous  waste  impoundments  are  being   closed  under  the

authority of 40 CFR 265  (interim status).   The USEPA has not requested that CWM-V

provide the  ground water  monitoring  information  for  the  post-closure  care

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portion of the permit.  Based on the current  ground water monitoring information,
a compliance monitoring program  under  40 CFR 264.99 should  be  provided  in the
permit appl ication.

F.  Compliance with Superfund Offsite Policy
    Under current USEPA policy, if an offsite TSD facility  is  to be used for land
disposal  of waste  from a  Superfund financed cleanup of a  CERCLA  site, the TSD
facility must  be  in compliance  with the applicable technical  requirements  of
RCRA.  As of June 18, 1987, CWM-V has been declared  ineligible to  receive waste
from response actions taken under CERCLA.  Region V made this determination based
upon violations found during the  Task Force  inspection.

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II.   TECHNICAL REPORT
 A.   Introduction
     Operations at  hazardous  waste  treatment,   storage,   and  disposal   (TSD)
 facilities are regulated by the  Resource  Conservation and Recovery  Act  (RCRA)
 (42 U.S.C. 6901  et.seq.).  Implementing  regulations  issued  pursuant to  RCRA
 (40 CFR Parts  260  through  265,  as modified)  address waste site  operations
 including  monitoring of  ground water to ensure that hazardous waste and hazardous
 waste contaminants do not escape undetected  into the environment.

     The Administrator of the  United  States Environmental   Protection  Agency
 (USEPA) established  a  Hazardous  Waste Ground  Water  Task  Force  (referred  to
 hereafter  as  Task Force) to  evaluate the levels  of  compliance with  ground water
 requirements  at on-site  and commercial  off-site TSD facilities and  to  address
 the cause   of noncompliance.   In addition  the  Task  Force  is  to  examine  the
 suitability of the  facility  as  a provider  of treatment,  storage, or disposal
 services for  waste  managed  by the  USEPA1s  Superfund program.  The  Task  Force
 is  comprised   of  personnel  from  USEPA  headquarters,  regional   offices,  and
 the states.   Fifty-nine  TSD  facilities  have had   a  Task Force  ground  water
 evaluation; one of  these is the  Chemical  Waste Management,   Inc., facility  in
 Vickery, Ohio (CWM-V).

 B.   Objectives
     The objectives of the Task Force evaluation  at  CWM-V were to:
     o  Determine compliance with requirements  of  40 CFR  Part  265,   Subpart  F
        (Ohio  Administrative   Code  3745-65)   ground   water  monitoring,  40  CFR
        Part 761  (TSCA  ground  water monitoring   requirements  for future  waste
        cell), and 40  CFR Parts  144-148 (underground  injection  control  (UIC)
        requirements).

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    o  Evaluate  the facility's  potential   compliance  with  40  CFR  Part  264,
       Subpart F (OAC 3745-55).

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

    o  Determine if any ground water contamination currently exists.

    o  Determine if this  site  meets  the  requirements  of  the CERCLA (Superfund)
       off-site policy.


C.  Investigative Methods

    The Task Force investigation at CWM-V consisted of:

    o  Reviewing and evaluating records and  documents from  USEPA-Region V files,
       Ohio EPA  files,  and provided  by  CWM-V  during  the  on-site  inspection.

    o  Conducting  an  on-site  inspection  from  April  6  through  16,  1987.

    o  Evaluating the  off-site laboratory  utilized  by  CWM-V for  analysis  of
       past and present ground water samples.

    o  Sampling and analysis  of ground  water from monitoring wells  at  CWM-V.

    o  Sampling  and  analysis   of  surface water and leachate  found  at  CWM-V.


    To accomplish the  objectives,  a  Facility  Evaluation  Team  was  assembled,

comprised of a Technical Review Team, a Laboratory Evaluation Team and a Sample

Collection Team.  Each team had individual  responsibilities which when combined

will achieve the objectives of the Task Force.


    1.  Technical Review Team

    The Technical Review Team  was  responsible for  conducting the evaluation  of

the facility with  respect to  applicable  ground water monitoring  regulations.

The team's objective was to determine compliance with  40 CFR Part  265, Subpart F;

40 CFR 270.14(c); 40  CFR Parts 144-148; and  potential  compliance with  40  CFR

761 (TSCA); and  40  CFR  Part   264,  Subpart  F.  The  evaluation focused  on  the

following six areas:

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    1.  waste characterization and operations;
    2.  site history and design;
    3.  site geology and hydrogeology;
    4.  ground water monitoring system adequacy;
    5.  ground water sampling and analysis procedures; and
    6.  ground water quality data and interpretation.

    The Task Force  core  team  in  Washington,  D.C.,  contracted Planning Research
Corporation (PRC)  of  Chicago,   Illinois,  to  prepare  a  document  package  of
pertinent background  information.   The  information collected  by  PRC primarily
concentrated on  past  inspections  and  submittals  (e.g.,  inspection  reports,
hydrogeologic reports, TSCA  land disposal application,  and  the Part  B  appli-
cation) from regional  and  state  files.   Information  obtained from CWM-V during
the Task Force evaluation  was also reviewed to supplement the accuracy  of the
information in the   public  files.    Combining  these  information  sources,  the
technical  review team  performed  a  complete evaluation of  the  facility records
with respect to the ground water monitoring system.

    During the investigation  the team  met with  facility representatives  and
legal  counsel  at least twice  a  day to  request  information.   Typically,  infor-
mation requested  by  the  Task  Force in  one meeting  was supplied by  CWM-V  in  a
subsequent meeting by  referencing specific sections of past reports.   CWM-V did
not permit  the Task Force to directly  question any  of its  consultants.   The
team also toured the  site  to  evaluate and verify the  waste  units  and handling
at the facility.
                                       8

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     2.   Laboratory  Evaluation  Team
     The  off-site  laboratory that analyzes  samples  for  CWM-V  was evaluated  by
the  USEPA  Region  V,  Quality Assurance  Office.   The  laboratory  evaluated was
Environmental  Testing and Certification Corporation (ETC) of Edison,  New Jersey.

     3.   Sample Collection Team
     Samples and field measurements  for the Task  Force evaluation at  CWM-V were
collected by  Alliance  Technologies   Corporation    (referred  to  as   Alliance
hereafter), a  USEPA  contractor,  under the  supervision  of  USEPA  personnel.

D.   Waste Management Units
     1.   Introduction
     CWM-V operates  a liquid  treatment  and disposal facility in Sandusky County,
Ohio, approximately two miles north of  Clyde along State Route 510 (see  Figure  1,
all  figures and tables can  be  found after page 55 at the back of this  report).
At the time  of the Task  Force  inspection,  wastes were  disposed  by deep-well
injection into the  five  operational   wells  located  on the  437-acre facility.
Only liquid wastes stored  or generated  on site were being injected.  No off-site
wastes were accepted at that time.

    This site, originally known  as  Don's Waste Oil, was  first used  in 1958 to
recycle waste oil collected from service stations.   In 1961, the company began
to accept various  industrial wastes,  such  as  cutting oils,  hydraulic fluids,
and some solvents.  These materials were stored in containment ponds.  In 1964,
the Ohio Water Pollution  Control Board  (predecessor to  the  Ohio Environmental
Protection Agency)  granted  the facility permission to accept  chemical  process
wastes such as pickle liquors  from metal-working operations,  lime sludge, and

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other miscellaneous chemical products.   More ponds  were  constructed to facili-
tate the growing inventory of liquid wastes, and by the late 1960's, the amount
of industrial  wastes  received  by  the  facility  exceeded  that  of waste  oil.

    In 1971,  the  firm was  incorporated  as Ohio  Liquid  Disposal,  Inc.   Faced
with growing volumes of waste, the company began investigating a suitable means
of disposal.   In  1972,  permission was granted by the  Ohio Division of Oil  and
Gas to  drill   a  test  hole  to  evaluate  subsurface conditions  for a  possible
injection well.  An application  was submitted  for permission to  use  this  well
for injection  of  industrial  waste.   In  September of  1972, the  Water  Pollution
Control Board  refused approval  for  a permit.   In this same month, the Division
of Oil and Gas refused to  issue  a permit  to convert the well for waste  disposal.
These decisions were appealed through the  state  judicial  system,  and  in  May of
1975, the  State  Court of  Appeals  in Toledo,  Ohio,  ruled that the permit  be
issued.  In July  of 1975,  a permit  to use well  No. 1 as 9 waste  disposal  well
was issued by the Division of-Oil and Gas.22  Injection into  this  well  began in
June 1976.  In January 1976, permits  were  issued  for  the installation  of wells
Nos. 2, 3, and 4  (see  Figure  19). Well No. 2 was completed  in November 1976 and
injection began in  March  1977.   Wells   Nos.  3 and 4 were  both   completed  in
November 1976, with injection  beginning in August  1977.   Due to  corrosion  of
the long string casing in well  No.  1, it was  not used for injection after  July
1979 and was eventually plugged and capped.  To replace well  No. 1, well  No. 1A
was drilled and completed in  October 1979.  Injection into this well  began  in
January 1980.  Wells No. 5 and  6 were completed in December  1980  and  May 1981,
respectively.  Injection of waste into  both  of these  wells  began  in  September
1981.  In May  of  1986  well   No.  3  was also  found to  have corrosion  problems;
                                       10

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operation of well  No.  3 ceased at that time.  It was  plugged  in  July of 1987.
Well 1A was taken  out  of service in the fall of 1987; thus only four wells (2,
4, 5, and 6) are presently being used for injection.

    CWM-V had, at one time, 12 unlined ponds (Nos. 1-12) in which liquid wastes
were settled and stored prior  to  filtration and injection.  At this writing (May
1988) all  but five  ponds (Nos.  4, 5, 7, 11, and  12) have been filled and covered.
Ponds Nos. 4,  5, and  7  (see Figure 2)  have  been  drained,  and  the contaminated
bottom sludge has been  solidified and is  currently  being  stored in a stockpile
to the east  of pond No.  4.   This stockpiled material  is  to  be  replaced  in  a
cell located at the former  site  of  ponds  Nos.  4,  5, and  7  once an appropriate
liner and  leachate  collection   system  are  installed   and  a   closure plan  is
approved; this  will  create  a disposal  cell  on  site.   Ponds  11  and  12  are
partially drained and  once  completely emptied, the  contaminated  bottom  sludge
is also to  be  disposed  in the  above-mentioned  cell.  At  the  time  of  the
inspection, construction of the  disposal  cell  was  suspended.   Both  the  USEPA
TSCA and RCRA programs  were in the process of reviewing its design and adequacy.

    A summary of regulatory  history  for  CWM-V, starting in 1979, can be found in
Appendix A of  this  report.   This summary deals mainly with the  RCRA and  TSCA
compliance history  of the facility.
    2.   Surface Impoundments
    CWM-V has  stated  that   the    surface  impoundments  were   constructed   by
excavating the clay down to the  proposed  bottom elevation of  each impoundment
and using  the  excavated clay  to construct  the  containment dikes  around  the
impoundments.   No linings were placed  in  any  of  the  impoundments.   The  dikes
range in  elevation  from 10 to  20 feet above  the  original  ground  surface.31

                                       11

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    a.  Surface Impoundments That Have Been Filled and Capped^l
    Pond No.  1  (see Figure  2)  was  opened  in  1961  and  filled  in  1980.   When
emptied its  sludge was  removed  and placed  in Pond  No.  4.   Pond  No.  1 was
approximately 430  feet  x  90  feet x  12  feet  deep.   CWM-V  stated that  it was
filled with demolition debris and capped with clean fill.

    Pond No.  2  was opened  in 1962 and filled  in 1979.  When emptied the sludge
was fixed  with  foundry sand  and lime kiln  flue dust.  CWM-V  stated that the
fixed sludge  was   then  left  in  place  and covered  with demolition  debris and
capped with  clean  fill.   Pond  No.  2 was  approximately  320 feet  x  100 feet x
12 feet deep.

    Pond No.  3  was opened in  1962  and  filled  in 1977.  CWM-V  stated that the
sludge was  removed from this pond and landfarmed  on  site  (see Figure 2).   It
was then capped  with  clean  fill.  The pond  was  approximately  230  feet x 150
feet x 6 feet deep.

    Pond No.  6  was opened  in 1966 and was  split into an east and west pond  in
1976.  Pond No. 6-East was filled in 1979 and the sludge was removed and placed
in Pond No. 4.  CWM-V stated that  clean fill was used  to cap it.   It was approxi-
mately 125 feet x  75  feet  x  12 feet deep.  Pond No.  6-West was  filled in  1981;
CWM-V stated that some of the sludge was landfarmed (in 1978/1979) and some was
fixed with foundry  sand and  lime kiln flue dust  (in  1981).   CWM-V stated that
this mixture was left in the pond and capped  with  clean  fill.   Pond No. 6-West
was approximately 200 feet x 75 feet x 15 feet deep.
                                       12

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     Pond  No.  9  was  opened  in  1969  and  filled  in  1981.   CWM-V  stated  that  it  was
 filled  and capped with clean fill.   It is uncertain whether the sludge  from  Pond
 No.  9 was removed or solidified  and left  in  place.   Pond No. 9 was  approximately
 440  feet  x 75 feet  x  11  feet  deep.

     Pond  No.  10 was opened  in 1971  and filled  in 1982;  CWM-V  stated  that  sludge
 removed from  this  pond was placed  in Pond  No. 4.   Clean soil was used to  fill
 and  cap it.   Pond  No. 10 was  approximately  520 feet x 150  feet x  12 feet deep.

     The closure requirements  of RCRA are applicable  to Ponds Nos. 1,  4, 5,  6,
 7, 9, 10, 11, and 12.  Closure  plans  have  not been submitted  for  Ponds Nos.  1,
 6, 9, and 10  as  of this  writing.

     b.  Surface  Impoundments Awaiting Closure
     At the time of  this  investigation,  ponds  No.  4,  5, and 7 had been drained
 and  the sludges solidified  and  placed in a  temporary waste pile to the east  of
 Pond No.  4.   The area that included Ponds  No. 4,  5,  and 7 is presently in the
 process of being constructed into a  RCRA/TSCA disposal cell.  When final approval
 is obtained  from both the  USEPA RCRA and  TSCA programs,  the waste  from  the
 temporary waste  pile  will  be  placed in the new cell.   It  should  be noted that
 Pond No. 7 includes the old Pond No. 8.

     Ponds No. 11 and  12  are still  open  but  not receiving  waste from off site,
 except that  Pond No.  12 accepts hazardous  waste  as  stated  below.   They  are
 planned to be closed  with their  solidified sludges being  put into  the above-
mentioned disposal  cell.

    There is   presently a pond  to  the east  of the  above-mentioned  waste pile
which collects runoff  and leachate  from the  waste pile.   The waste  pile contains

                                       13

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 hazardous waste;  therefore,  leachate  from  it  is  also considered to  be  hazardous
 waste  under  40  CFR  261.3(c)(2)  and will  require  proper  RCRA  closure.   Also,  the
 Task Force  analysis found that this  pond contains hazardous waste  constituents
 (see Section  J.2.d.4).  The hazardous  waste  from this  pond  is  pumped to Pond
 No. 12 before being deep-well  injected.

    3.  Abandoned Oil  Recovery  Facility  and Sludge Farm*?
    The oil  recovery  facility  on the  eastern  side  of the  site  was used  to
 recover No.  5 fuel  oil  for resale  from used machinery  oils,  hydraulic oils,
 water soluble  oils, motor oils,  rolling mill stock  oils,  etc.   This facility
 was decommissioned  during the summer  of  1986.

    Oily sludges  were landfarmed  into  the  soil  for a  biological  degradation
 experiment in the sludge  farm  area north of  Ponds No.  11  and 12 in 1978.   The
 project was  not successful  and  was  abandoned after two months.  The  soil   and
                 «
 oily sludge were excavated and transferred to the waste ponds.

    4.  Injection Wells
    a.  Background
    Class I injection wells as defined in 40 CFR 146.6 (a)(l) are wells used by
 generators of hazardous waste or owners or operators of hazardous waste manage-
 ment facilities  to   inject   hazardous waste  beneath the  lowermost  formation
 containing, within  one-quarter mile of the  well  bore, an underground  source  of
 drinking water  (USDW), and  (2)  other  industrial  and municipal disposal  wells
which inject  fluids beneath the  lowermost formation  containing,  within  one-
quarter mile of the well  bore,  an  USDW.   These wells  are regulated  by  the Ohio
 Environmental Protection   Agency  (OEPA)  Underground  Injection  Control   (UIC)
program pursuant  to Chapter  3745-34  of  the   Ohio  Administrative  Code  (OAC).

                                       14

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 OEPA  was  granted.authority  to  administer  the  UIC  program  (40  CFR  Parts  144-148)
 by  the USEPA Region V Water  Division.  USEPA retains authority for  UIC  provisions
 under the Hazardous  and  Solid  Waste Amendments of  1984  (HSWA).

    b.  Site Stratigraphy
    All injection  wells  were completed with an open hole construction  into the
 Mt. Simon Formation  (the injection zone).  Located at a depth of approximately
 2800  feet below the  ground  surface, the Mt. Simon  Formation is composed of fine
 to  coarse grained  sandstone  that averages in thickness between 84 and 139 feet.
 The injection zone is overlain by  a confining system which is comprised of four
 individual formations  which occur between  2366  and 2808  feet.   The formation
 which is  located  immediately above the  injection  zone  is  the basal  dolomite of
 the Rome  Formation which is composed of thin interbedded, moderately permeable
 (1-1500 md)  dolomites and  sandstones  and  thicker  layers  of  lower permeable
 (<0.01 md)  dolomites.1  The Mt.  Simon  Formation is  overlain,  in  ascending
 order, by  the Rome Sandstone and  Dolomite  Formation;  the Conasauga Formation;
 the Kerbel  Formation,  which  is  composed  of  interbedded dolomitic  sandstone,
 shaley sandstone  and sandstone;  and the  Copper  Ridge  (Knox) Dolomite.   The
 Mt. Simon  Formation  and its confining  system  is  further  separated  from  the
 lowermost fresh  water aquifer  (the  Big  Lime)  by  approximately  1700  feet  of
 sedimentary strata (Figure 3).

    c.  Operation
    Injection well No. 1 was drilled  in 1972 and  began  operation in  1976.   Four
years  later this  well  was  plugged and  abandoned  due to  a  hole  in  the casing
 caused by  corrosion.   Subsequently,  six  additional   packerless  wells   v/ere
constructed during 1976 to  1980.   Numerous reworks  were conducted on  the  wells
                                       15

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 at  CWM-V  in an  attempt  to  correct  recurring mechanical  well  failures  which
 allowed acid waste to enter formations above the Mt.  Simon  Formation.22  Finally,
 in  1983  to 1985,  all wells  were  reworked  and  recompleted  with  packers  and
 corrosion  resistant casing  and cement.

    The replacement of injection well materials with corrosion resistant casing
 and cement was a necessary  precaution given that the injectant is a very acidic
 (pH <1.0)  waste  pickling  liquid  used  for  steel   processing.   Injection  of
 this waste  into  noncorrosion resistant  wells probably  facilitated  mechanical
 failures.

    d.  Mechanical Integrity Tests
    As a  result  of  these  prior releases  both USEPA  and OEPA  imposed  annual
 mechanical integrity test (MIT) requirements on CWM-V.   These MITs  are used to
 test:  (1) the integrity  of the casing, tubing and packer and (2)  to  demonstrate
 the absence of upward fluid migration adjacent to  the well bore.   Part  1 of  the
 MIT is accomplished by performing a pressure test with a liquid.  A predetermined
 pressure is applied  to  the entire  annulus  (Figure 4);  in  the meantime,  the
 tubing is either injecting or shut-in.  In order for the injection well  to pass
 this test, the annular pressure must remain constant (±3%  for  error  or  surface
 piping leaks)  for one  hour.   If the pressure increases or decreases  it indicates
 that the integrity of the well  is  in question.

    Part 2 of the  MIT uses geophysical  logging methods, in this case a  radio-
 active tracer  (RAT), to  detect  casing leaks and/or  fluid movement   behind  the
casing.  If none of the  tracer  is  detected escaping from the  casing or  moving
up behind  the  casing into unpermitted zones,  then  the well  passes.
                                       16

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     In  May  1986  injection  wells  No. 1A through 6 (except No. 3, which  has  been
 plugged)  were  tested  for mechanical integrity.  All of the tested  wells  passed
 Part  1  and  all but well No. 2 passed Part 2 of the MIT.  Well No. 2  was suspected
 of  having  a channel  adjacent to the well bore  at the  base of the well,  but  it
 passed  the  MIT in  1987  as  noted below.

     Subsequent MITs performed  on  injection  wells  No. 1A, 2, 4, 5, and  6  in the
 fall  of 1987 passed four of  the five wells  (see Figure  19).  Well  No. 1A  failed
 and was taken  out  of service and  is plugged and abandoned.

    e.  Discussion
     In  the  past  ten years  of underground injection  at  CWM-V a  number of  opera-
 tional  problems  have occurred at  the facility.   Initial  injection well construc-
 tion  and  configuration did  not  -provide  adequate  protection against  the acid
 waste,  resulting in numerous well failures/leaks, some of which went unreported
 by CWM-V for an  extended period of time.  At the time of the Task Force review,
 these releases were still  not  completely defined by CWM-V, and even though the
 facility's  UIC   consultants  were  on  site  during   this  investigation,  CWM-V
 did not  permit the Task  Force to  question  these  consultants  on  this  or  any
 other issue.   The  causes  of these releases were addressed  in  a Consent Decree
 with  OEPA which  required  CWM-V to rework all  wells  and install  an  annular seal
 system.  CWM-V performed this task between 1983 and 1985.

    The effectiveness  of the confining unit in containing the injected waste is
 of concern  to  the Task  Force.   The clustering of  the injection  wells  on  the
 CWM-V site  results in  significant pressure increases in the Mt.  Simon Formation
 when the wells are in  operation.   According to CWM-V,  this  pressure  increase
dissipates with time once injection has ceased.   The  concern  is how this  pressure

                                       17

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 increase  affects  the  initial  confining  layer  which  is the basal dolomite of the
 Rome  Formation.   The  basal   dolomite   of  the  Rome Formation  is  composed  of
 interbedded,  moderately  permeable  and  lower  permeable  dolomites.  Laboratory
 compatibility tests,  performed by  CWM-V,  on  the  dolomite  and the acid waste
 suggest that, although the dolomite  is fairly permeable to  natural  Mt. Simon
 brines, the  waste acid reacts with the dolomite causing a reduction in permea-
 bility.   Given the pressure  buildup and potential  reduction  in confining layer
 permeability  of  the  dolomite,  an  estimate of  upward  penetration  of  brine  or
 waste was  made by CWM-V.   It was  estimated  that  it  would take  brine  or acid
 waste 20 years to migrate through the dolomite and  into the overlying sandstone
 of the  Rome  Formation.1>22   Once it reaches the sandstone it is suggested that
 the sandstone would  dissipate the  energy  laterally within  the permeable sand-
 stones, which would lower the  potential for vertical migration from that point.

    The Task  Force found that  the effectiveness of the immediate confining unit
 has not  been  thoroughly  demonstrated  by  CWM-V  and  that the ability  of  the
 immediate confining unit to  contain the waste  remains  questionable.   The Task
 Force suggests deep  well  monitoring  of the  Rome  Formation  could  provide  the
 ability to detect migration  of waste from the injection  zone, if any migration
 should occur.

    CWM-V will be  required  to  submit  a no-migration  petition under RCRA,  if
 it intends to  inject  wastes  that  are subject to the land  disposal  restrictions
 that apply to UIC wells.  The subject petition must demonstrate that the disposal
 of hazardous  wastes by deep  well injection  at  the  facility  is done in  such  a
 way as to be  protective of human health  and  the  environment  and that  the waste
 will  not migrate  from the injection  zone  for  10,000 years  or as  long  as the
wastes remain hazardous.
                                       18

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     After  a  thorough  review  of the  petition,  a  site-specific  requirement  of
 ambient monitoring  (deep  well)  could  be initiated  to enhance  confidence  in
 CWM-V's petition demonstration  of  no-migration.   The actual implementation  and
 parameters thereof  cannot be evaluated  at  the  time  of this  report.  The  Task
 Force  recommends that  the ambient monitoring question  be thoroughly addressed
 and  evaluated  in  detail  during the Land  Ban  Petition evaluation process to  be
 completed  by  USEPA  Region V.   The  Task  Force believes that  recent and future
 data acquisition and modeling will provide insight  into this concern.
 E.   General Geology
     1.  Previous Investigation
     The first  significant hydrogeologic investigation  for the  facility  was
 conducted by  Bowser-Morner Laboratories,  Inc.,  and  is described in a  report
 dated May  1983.2  A  hydrogeologic  investigation  and  statistical  analyses of
 ground water quality data were performed.  Thirty-two (32)  borings were made and
 five (5) piezometers were installed during the study.  The boring program focused
 on describing the glacial overburden.  A  pump test of the bedrock was conducted
 to determine  aquifer  characteristics.   The  overall  flow   system described in
 this report is generally consistent with  subsequent reports.  Bowser-Morner was
 first to identify the  inward  flow pattern at the  site caused  by pumping in the
 water supply wells (e.g., truck wash well).

    The majority  of  site-specific  studies  that   followed  the  Bowser-Morner
 report were conducted  by  Colder and  Associates,  who   reevaluated  the  hydro-
 geologic system  based  upon  additional   data  and  focused   on  specific  issues
concerning  the hydrogeologic  or monitoring systems.  A listing  of site-specific
hydrogeologic  studies is included in  the reference section at the  end  of  this
                                       19

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report.  A  more  comprehensive list  of references  (including  off-site studies
in the  area of the  site)  is given  in the Golder  and  Associates report dated
July 1986.19

     Figure 5  shows  locations of  borings,  wells and  piezometers installed at
the facility as of May 1986.19  The Task Force  is not aware of any hydrogeologic
studies conducted between July 1986 and  the Task Force inspection  in April 1987.

    2.  Glacial Overburden
    The facility  is  underlain by  33  to  52  feet  of  glacial  overburden.   The
overburden  is  comprised  of   glacial   lacustrine  deposits  overlying  two  till
units.  The glacial  overburden  overlies  a predominantly dolomite  bedrock.   A
500 to  550  foot  thick sequence  of Devonian and  Silurian age dolomite deposits
are found under the glacial overburden.  Figure 6 depicts  the glacial overburden
at the  site in cross-sectional  view.   The  figure  shows  that  the contacts  are
generally horizontal   and that the  ponds that contain hazardous  waste are about
30 to 40' feet above the bedrock.

     The uppermost deposit is comprised of lacustrine  materials.  This deposit
is thought  to  have  been deposited  in a  pro-glacial  lake.   The  deposit  is
described as having  horizontal  laminations  of silty clay with occasional  fine
sand between the  laminations.   In the  area  around the  facility, this deposit
ranges from 0  to  25   feet in  thickness.19  The most recent  boring  program  for
the facility revealed  that the  lacustrine material  is  generally  absent  south
of State  Route 412  and is  up  to 16.7  feet  thick  at  monitoring  well  L-34
(Figure 16).
                                       20

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     Glacial till  underlies  the lacustrine deposit.  The till  is  divided into
an upper  unit that  is  continuous  across  the  site and a  lower unit  that  is
discontinuous.  The  upper  till  unit  ranges  from  11 to  38 feet  in  thickness
while the  lower  till unit  is  less  than  13  feet  thick.   The  upper  till  unit
generally consists of silty  clay  to clayey silt with some sand and gravel, and
is relatively  homogeneous   with  no distinct depositional   structures  (e.g.,
bedding or  laminations).  The  lower till  unit is  comprised  of  silt  with some
clay, sand  and gravel.   The  lower till  is more dense and more coarsely graded
than the upper till unit.

     Some fine sand  and/or  silt deposits  have been  encountered  in  the glacial
tills.  Material  that can be classified as predominantly sand was found in four
borings over  a  total interval  of 5.7 feet.   The  specific  locations  of  these
sand lenses are as follows:
Boring
Number
SS-13
SL-1
6-14
G-27
Depth of
From - To
27.5 -
20.4 -
19.6 -
29.3 -
Lenses
(ft.)
31.2
21.3
20.4
29.6
Material Description
Fine coarse SAND, little
fine to coarse gravel (SP)
Fine to coarse SAND and
SILTY CLAY (SC)
Fine to coarse SAND and
CLAYEY SILT (SM)
Fine to coarse SAND, some
                                           fine gravel, trace silt  (SP)
This information  is  taken  from  Reference  6.   The  sand  lenses discovered  in
borings G-14 and G-27 are monitored by wells T-14 and T-27,  respectively,  which
are screened over these intervals.   Borings SS-13 and SL-1 were located  next  to
one another along the east side of old  Pond  No.  4 (now the  new disposal cell).
A till  monitoring well  is not present or proposed in  this  area.
                                       21

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    The upper  5  to 10  feet  of  glacial  overburden has  been  desiccated (i.e.,
dried out).  Desiccation cracks  are common in the upper  portions of the uppermost
deposits.  Below the limit  of desiccation the lacustrine and upper till  deposits
are usually soft with relatively high moisture contents and are nearly normally
consolidated.  The  lower  till   appeared  more  consolidated than the  upper till
based upon descriptions of this  deposit.  Observation  of  some cores present at
the facility  and comparison  to their  logs  verifies  the descriptions  of  the
deposits given in the reports at the facility.

    3.  Bedrock
    The Tymochtee  Dolomite,  middle  member  of  the Bass  Island  Formation,  is
immediately under the glacial tills.   It  is  approximately 150 feet thick under
the site.  The  Tymochtee  is underlain  by the  Greenfield Dolomite  (also  Bass
Island Formation).  Underneath  the  Bass Island Formation  is  the  Lockport For-
mation.  Although not differentiated on  Figure  3,  these  formations  are part of
the "Big Lime."   The  Big  Lime  is an informal driller's  name  for this  geologic
sequence.

    The Tymochtee Dolomite is  generally described  as  thin bedded,  gray-brown,
very fine  grained  dolomite with solution  zones and evaporate beds  (anhydrite
and gypsum).   This dolomite unit is interbedded with shale and exhibits parting
in which gypsum and calcite have formed  as a  secondary filling.   The Tymochtee
Dolomite has  been cored to a depth of  125  feet  beneath the site.  Descriptions
of the  cores  confirm  the  general  descriptions given above  and  show  highly
weathered zones  and  that  most  solution  cavities  were relatively small  (less
than one inch).19
                                       22

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    The top  of  bedrock in the  region  has  been mapped by  Hoovered  (Figure  7).
This map shows the site in relation to the major top of bedrock features around
the site.  As can  be  seen in  this  figure,  a major bedrock valley exists to the
west of the  facility  (trending north-south).  The  eastern side of  the  buried
valley on  which  the  facility  is  located  has  a  uniform  slope, with  no  other
major buried valleys intersecting  it.

    The top  of  bedrock under and immediately  around  the  site  has  been  mapped
from data collected from  the  geotechnical  borings,  piezometers, and monitoring
wells (Figure 8).   This   figure shows  a bedrock  ridge south  of the  facility
that trends  southwest-northeast and  a  general  flat  area under  the  site.   Both
Figure 7  and 8  show  that  the bedrock  surface  is sloped  toward  the  north.

F.  Hydrogeology
    1.  General
    The major sources of  ground water  in the  region surrounding the  site  are:

          - Tymochtee  Dolomite
          - Greenfield Dolomite
          - Lockport Dolomite

    These formations  have  solutioning  and  jointing  (i.e.,  fractures)   that
enhance their porosity, transmissivity, and storativity.  In the area around  the
facility, these  formations are under confined conditions.

    The glacial  overburden is saturated to within 2-5 feet of the ground surface.
The glacial   overburden  is not  used  as a domestic  or  commercial  water supply
except for sand  and gravel valley  deposits.19
                                       23

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     In the Tymochtee Dolomite, regional flow is to the north-northwest as shown
 in  Figure 9.  The major  recharge  area  is  reported  to be to the southeast where
 the  Tymochtee comes  to within a  few feet  of the  surface.19  The glacial over-
 burden acts  as  a leaky  confining layer under the  facility.   Flowing artesian
 conditions do  not  exist at the  site  but  can  be  found  around  the  facility in
 Riley, Green Creek, and Townsend  townships.

     2.  Ground Water Flow in the  Bedrock
     Ground water  flow  in  the dolomite bedrock  under  the  facility  has  been
 interpreted from  water level  data  collected  over  several years.   Golder  and
 Associates19 presents a typical potentiometric  map  for  the bedrock units for the
 period between 1982  and  1984 (see Figure  10).  This map shows  the  radial  flow
 pattern (identified  by Bowser-Morner)  which   is  produced by  pumping  on-site.
 This flow pattern is characteristic of this period  and is anticipated when the
 site becomes active  and pumping  begins.  Other examples of potentiometric maps
 from this  two-year  period that   show  similar  flow  patterns  can  be  found  in
 Reference 19.

    The bedrock  units  are quick  to  respond to pumping  stresses at  the  site.
 This is typical  of  a  confined aquifer with fracture flow. The  quick response
to pumping stress is clearly demonstrated in Figure  11, which is a potentiometric
map produced from water  levels measurements  taken after  eight  hours  of  steady
pumping.   The flow directions  are radially inward  toward  the pumping  well  and
gradients are relatively high.

    Under nonpumping conditions these  units quickly recover toward  natural  flow
and gradient conditions.   Figure  12 is  a potentiometric  map  made  from  water
                                       24

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 level measurements  taken after  the truck wash  well  at the  facility had been
 shut  down  for  a minimum  of eight  hours.   This  shows a  flat potentiometric
 surface  under the facility with  a slight  gradient to the north.

    An accurate  determination of flow rate and  direction is necessary to perform
 an  adequate  assessment.  The  Task  Force has  concerns  regarding  the  lack  of
 information on   flow  rate  and   direction in  the  bedrock  (discussed  below).

    CWM-V has  estimated  flow  rate  in  the  bedrock  using  Darcy's  law  to  be
 1600  ft/yr.32  Because this  is a  fracture flow system, the assumptions of Darcy's
 law may not apply.  Based upon these findings,  the  Task  Force feels the estimate
 of  flow  rate may be inaccurate,  and most  likely low.

    The  flow direction is north-northwest under the site based upon water level
 data  collected  to  date.  Karst  conditions  have been  reported to be  near the
 site, but have  not  been  identified  as a major  feature in the  bedrock  at the
 site.  If large  solution  cavities exist  beneath  the site,  flow direction  could
 differ from that described in site-specific  geologic reports.

    3.  Ground Water Flow in the Glacial  Overburden
    The potentiometric surface in the overburden (Figure 13)  was estimated from
 water levels taken between  June  and August  1984.  The  Task  Force  is  not  aware
 of  any potentiometric maps for the glacial overburden  produced before this.  At
 the time this map was generated, Ponds No. 4,  5, 7, 11,  and 12 contained  fluids
which strongly  influenced the  flow directions  in  the  overburden.   As the map
 illustrates, ground   water mounds  existed  under  these ponds.   Ground  water
mounding  under material  used to  fill  the old  ponds  No.  1,  3, 4,  9, and  10
can also  be  seen.  Mounding occurs because of the large hydraulic heads available
                                       25

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from the  ponds and  their  elevation  relative  to  the  ground surface.19   The
relatively steep gradients  along the edge of the mounds  were  caused  by the low
permeability soils  which restrict  seepage  (flow)  and  allow rapid  head  loss.

    Site alterations have  caused  changes in the potentiometric  surface in the
glacial overburden.  Ground water data  obtained in  January  1986  were  used to
create the potentiometric map shown in Figure 14.  As this map indicates, Ponds
No. 4, 5, and 7 have been emptied and the ground water mound under them and the
other closed ponds (1, 2, 3, 9, 10) had dissipated  at this time.   A mound still
existed under  Ponds  No.  11  and  12, which  still  had  fluid  in them.   A  small
mound exists that is associated with  the  stockpile of hazardous material  removed
from Ponds No.  4,  5,  7.   With the exception of these  ground  water mounds, the
overall flow in the overburden is generally to the  north.

    Ground water levels measured  by the Task Force  and those used to  create the
potentiometric maps  in   Figures  13  and  14  are  given in  Tables  1 through  3.
Comparing water  levels   in  the various  well   nests  indicates that  the  water
levels decrease with depth, which indicates  a downward vertical  gradient toward
the bedrock.

G.  Ground Water Monitoring System
    1.  Historical  Ground Water Monitoring System
    During the 1970's,  both CWM-V  and the Ohio  EPA monitored ground water at the
site.  They used  the same  wells  but gave  them different designation  numbers
(e.g., Ohio  EPA No.  1   is  equivalent  to CWM  No.  4).   Ultimately this  older
ground water monitoring system  evolved into a 12-well  system which was  originally
used by CWM to  satisfy  40  CFR Part  265  ground water  monitoring  requirements.
                                       26

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The following  section  describes  how the older  ground water monitoring  system
evolved.  The Task Force has given the Ohio EPA wells the prefix "OEPA" and the
CWM-V wells the designation "MW".

    In addition  to  the  monitoring  wells,   several  piezometers  have  been
installed.  Some of these piezometers have  been  sampled  at  various times.   One
piezometer in particular, P-10,  has  shown  contamination  (discussed  in Section
J.2).  Figures 5 and 13 show the location of the piezometers.

    In 1972  the  Ohio  EPA  began  monitoring  four  wells,  MW-4 (OEPA-1),  MW-5
(OEPA-2), MW-8 (OEPA-3), and OEPA-5 (Figure 15).  Two  of these wells were on-site
and two were  off-site.   In  1974,  CWM-V  added  an  on-site  testing laboratory and
another monitoring well,  OEPA-4, to the  system.  In 1976  the Ohio  EPA  added
OEPA-6.  Between 1976  and  1978,  CWM-V  added  monitoring  wells  MW-1,  1A,  MW-2,
MW-3, 3A, MW-6, and 6A.   In 1979, the steel-cased wells  were abandoned and new
PVC-cased wells were  installed  and  renumbered MW-1N, MW-3N, MW-4N,  and  MW-6N.
A new well, MW-7,  was  also  added at this time.  In  1981, three more monitoring
wells (MW-11, MW-12, and  MW-13)  were  added to the north of  the existing  waste
management area.

    By 1982, the monitoring system at CWM-V site had evolved to include eleven
wells:  MW-1N, MW-2, MW-3N, MW-4N,  MW-5,  MW-6N,  MW-7, MW-8, MW-11,  MW-12, and
MW-13.  As  indicated  above, these  wells  were used   initially  to   satisfy  the
ground water  monitoring  requirements  specified  in   40  CFR Part  265  (RCRA).

    2.  Current Ground Water Monitoring  System
    In 1983, the USEPA determined that the wells in  this monitoring  system did
not satisfy the  requirements  of  40  CFR  Part 265 based  upon  inadequate  well
construction, location, and  depth.  As a result of these  findings,  CWM-V agreed
                                      27

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to enter into a Consent Agreement and Final  Order (CAFO)  on April  5,  1985,  with

the USEPA.  The CAFO required, among other  things, that  new  wells,  constructed

of type 316  stainless  steel,  be  installed  at  several  locations  and  depths.  As

a result  of  the  CAFO,  a  workplan  was developed  describing a new  monitoring

system.  The workplan was  originally submitted  in  May 1985 and  was  modified in

four addenda (numbers  1  through  4)  dated August 5, August 27,  and  October 17,

1985, and February  11,  1986,  respectively.  The workplan was approved  by the

USEPA and the Ohio EPA on November 29,  1985, and January  6, 1986,  respectively.


    The CAFO monitoring  system  is designed to  provide ground water  monitoring

for the  glacial  overburden  and   the  bedrock.    The  new  monitoring  wells  are

designated by  a  number  and  several   letters.   The  number  corresponds  to

continuously sampled boreholes  that were made  during the continuous  borehole

study.6  Information gathered  during this study was  used to design the monitoring

wells in the  new system.  The  letter  designations are  used to  differentiate

wells completed  in  the  lacustrine  deposits  (L),  till   deposits  (T),  and  the

bedrock (MW).


    The CAFO specified  the new monitoring wells  be  installed in  accordance  with

the following schedule:


        Phase 1

        (1)   Within 90 days after approval  of the Workplan by the
             USEPA and  the Ohio EPA, install wells  MW-14R, MW-19R
             to MW-24R, L-14, L-19 to L-23, L-26 to L-35, T-14,
             T-19, T-23, T-24, and T-27.

        (2)   Within 90  days after excavation of  the fixed sludge
             soil  and rip-rap from ponds  4, 5,  and  7,  install wells
             MW-15R, MW-16R,  L-15, and  L-16.
                                       28

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        Phase 2
        (3)  Within 90 days after removal of the clay liner beneath
             the temporary stockpile and regrading of the area,
             install wells MW-17R, MW-18R, L-17, L-18, L-25, T-17,
             and T-18.
Phase 1 monitoring wells were  installed  by November 1, 1985, in advance of the
required schedule.  Phase 2 monitoring wells will be installed in accordance with
the requirements of paragraph  3  of the  CAFO.   These wells have been designated
with a "P" on Figures 15 through 17.  In addition to the wells specified in the
CAFO, the Task Force is recommending locations for additional monitoring wells,
designated with  an  "R" on the figures.   The  recommended wells  are  discussed
further under Section C (Downgradient Wells) below.

    Table 4  lists  general  information   for  all  wells at  CWM-V.  Figures  15
through 17 show  the  location  of the new monitoring  wells by the  stratigraphic
interval monitored (lacustrine,  till, and  bedrock,  respectively).  Wells  with
the same  number  on  different  figures  are   located  at  the  same  location.

    The CAFO monitoring system is  being used  to meet the  performance  standards
of 40 CFR  Parts  265,  Subpart  F.  There are two  parts to the  CAFO  monitoring
program, an  "Initial   Ground   Water  Program"   and  a  "Continuing  Ground  Water
Program."  The  Initial  Ground  Water  Program  was completed  in May 1986.   The
Continuing Ground Water Program is currently being followed by CWM-V,  and calls
for semi-annual  monitoring for a list of contaminants agreed upon  by the USEPA,
the Ohio EPA, and CWM-V.  According to the CAFO,  CWM-V must  submit  the  results
of the Initial  Ground  Water Program and the Continuing Ground Water Program to
USEPA and OEPA  within 30 days  after  receipt   of  the final  results of  all  the
analyses in that set  by CWM-V.  At the  time  of the  Task  Force investigation,
CWM-V had not complied with this requirement of the CAFO.
                                       29

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   Analytical results  from the  initial  and  continuing  CAFO  monitoring  has
revealed contamination in several wells  (see  Section  J  of this  report).   CWM-V
has not submitted an assessment plan as  required in 40  CFR 265.93 or installed
additional  wells to  define  the  rate and extent  of contamination  found  in  the
wells.  The  Task  Force  finds  that  the  existing system is  inadequate  for
assessment purposes.

    a.  Upgradient Wells
    Wells MW-23RA, MW-24R,  MW-37R, and MW-38R are bedrock monitoring wells that
are upgradient  of  the  facility during  natural  and pumping conditions.   Wells
MW-23RA, MW-24R, and MW-37R are part of the CAFO Continuing Ground Water Program
and are constructed  of  stainless  steel casings and screens.  Well  MW-38R is a
CWM-V research  well  constructed of PVC  and  is  not intended to be  part  of  the
RCRA ground  water monitoring  system.   All three  of  the  upgradient  stainless
steel wells  appear  to be  properly located  and  constructed  for   ground  water
monitoring to determine background water quality.

    Wells T-23,  T-24, T-37,  and T-38  are  till  monitoring wells  upgradient  of
the facility.   As with  the  upgradient bedrock wells, T-23, T-24,  and T-37  are
constructed of stainless steel  casing and screens and  were installed as part of
the CAFO.  Well T-38 is a CWM-V research well constructed of PVC.

    CWM-V had trouble finding a  location  upgradient of the facility at which  the
lacustrine deposit  was  present.   Wells  L-23  and  L-39 are wells  upgradient  of
the facility and screened in the lacustrine zone.   The  wells are both constructed
with stainless steel casing and screens.
                                       30

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    b.  Downgradient Wells
    The new CAFO wells which are  considered downgradient by  CWM-V  are  shown  in
Table 5.  L-series  and T-series wells are referred to  as  lateral  gradient  wells
in Table 5.  All  wells except  those described  in  the previous section  should  be
considered downgradient wells for detection monitoring.  The location,  depth and
construction of these wells appear adequate to determine  if the hazardous  waste
management units are leaking at the  facility, with the exceptions  given  below.
Contamination has been detected in  some of the wells  on site  (see  Section J);
thus a ground water assessment should be conducted by  CWM-V.

    Delays in approving the closure  plan have left the facility  unmonitored  in
the northeast  area,  specifically  around  the  stockpile.    Several  wells are
proposed for this area (L-17,  L-18,  L-25, T-17, T-18, MW-17,  and  MW-18). The
Task Force  recommends that the Phase  2  wells  be  completed  as soon  as  possible.

    As discussed  earlier, the  "runoff  retention pond"  to  the  east  of the
stockpile was found to contain hazardous  waste leachate  by the Task Force, and
therefore is  considered  by the  Task  Force  to be a  RCRA-regulated unit.   As
such, a  RCRA approved closure of  this area is  necessary.   Based upon  these
findings, the Task  Force  recommends a  minimum  of three  lacustrine  wells  be
installed at the location shown on Figure 16 to the east of the retention pond.
Shallow lacustrine  deposits would  be the  first  to become  contaminated  if the
retention pond is leaking.
    Finally, one  additional   bedrock  monitoring  well  is  recommended at  the
location of  L-30.   During pumping  conditions  at the  site, this   location  is
downgradient of the proposed closure  cell  as  well  as  the  areas  being  closed  in
                                       31

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the eastern portion  of  the  facility.  Therefore, the  Task  Force recommends  a

bedrock well  be installed to help detect immediate contamination to  the bedrock

from these areas.   This is  also  provided  for under  paragraph  H of the  CAFO.


    c.  Well  Construction

    All wells in the CAFO monitoring system are constructed  of  stainless  steel

casing and  screens.   Future  wells  proposed under  the  CAFO  will  also  be

constructed of the same material.   Reference  25 gives details of how the  wells

were constructed  and  completed.   The  new  wells  appear  to   be   adequately

constructed and completed  based  upon the  discussion  in this document  and  the

workplan.H


    3.  Sampling and Analysis

    a.  Sampling and Analysis Plan (SAP)

    The SAP  for  CWM-V consists  of  two separate documents.   One is a  general

Waste Management, Inc., Manual for Ground Water Sampling (MGWS)24 and the  other

is a  Site-Specific   Ground  Water Monitoring  Plan  (SSGWMP)25  for  the  Vickery

facility.  A  number of  deficiencies  in  these plans  were  noted  by  the  Task

Force:


    - When the well  heads are first  approached by the sampling team,
      no organic vapor monitoring is  required by the above-mentioned
      plans.  This type of monitoring would give an initial  indica-
      tion of the presence  of volatile  organics  in the  well.   It
      could also  be  used to  help determine  the  level  of personal
      protection necessary while sampling the well.

    - No indication  is  given in  the above-mentioned plans that  the
      sampling team  should  be  checking  the  well  for  immiscible
      layers such  as  low  density   (floaters)   or  high  density
       (sinkers) contaminants.
                                      32

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    - There is  no  requirement in the  above-mentioned  documents  to
      decontaminate the  cable used  to  lower the  electric  water
      level indicator into the well  unless visible contamination  is
      present.  Although  when a  weighted tape is  used  for  water
      level measurement  it  is required  to be decontaminated  (see
      item 2  on  page 65  of  the  MGWS24).  The cable used to  lower
      the electric water  level indicator  should  also  be decontami-
      nated.

    - CWM-V's  field  form  CC2 does  not  provide  for  documentation
      of sampling  time  for  pH,   conductivity,  and   temperature
      measurements.

    - A low-yield well  is only required  to be  purged one well volume
      by the  above-mentioned  documents.   Low-yield  wells  should  be
      purged to  dryness  or  three  well  volumes,  whichever  comes
      first.

    - Field parameters  (pH,  temperature,  and  specific  conductance)
      are only  analyzed in the  beginning of the  sampling  order.
      The TEGD27  and  the Task   Force   recommend  that  the  field
      parameters be measured  both at  the beginning and end  of the
      sampling order.

    - Total  organic  carbon  (TOC)  and  extractable  organic samples  -
      (except volatile  organics (VOAs)) are required to be filtered
      according to the  above-mentioned plans.  This is  an incorrect
      procedure and  will  cause all  of  these  analyses  to  be biased
      low.


    b.  Sample Collection and Handling Procedures

    The Task  Force observed  the  facility's sampling procedures during the Task

Force sampling effort.   One questionable protocol  practice was  noted during the

HWGWTF activities.  This involved the method of cleaning the cable of the water

level detection instrument.   Only the probe is rinsed  after it has  been  reeled

up.  It would be more appropriate to wipe and/or  rinse  the cable  as it is being

reeled up to minimize possible cross-contamination of  wells.


    A very  small   segment of  facility  sampling  procedures  was  observed  on

April 15,  1987.   These  activities  occurred  at  well   T23A,  a  bailer  equipped

well.  This was the second day of sampling at this site.  Samples  were collected
                                       33

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for total  and  dissolved  metals, chloride,  sulfide,  and phenol  analyses.   All
sampling activities followed facility protocol.  All  sample  water,  except  that
for total  metals,  was  filtered on  site.   Samples requiring preservation  were
immediately preserved  upon  collection  or  completion  of  filtration.   Sample
water for parameters collected on this day  were placed  in  brown  glass bottles.
The filtering  device  was Teflon®  lined  and had  a capacity of  1500 ml.   The
device was driven by compressed nitrogen  delivered at  40 psi  using  a regulator.
The filtering device was fitted with a 0.45 micron filter.   The filter unit was
rinsed with deionized water and dried with a paper towel between  uses.  At  Well
Wizard®-equipped wells the facility used  an in-line filter, a QED model  FF-8000
(0.45 micron) to filter  samples.   The operation  or use  of this  device  was not
observed.  If such  a  device  is used there did  not appear  to be  a  protocol  for
it in the  sampling and  analysis  plan.    Sample parameter  types  that were  not
filtered were field parameters (pH, conductivity,  temperature), oil  and grease,
solids, VOAs, total organic halogens  (TOX),  and total metals.  The two filtering
methodologies used appeared to  be acceptable for those  parameters  which should be
filtered, except  for  the previously  discussed errors  and omissions.   In  the
case of phenols there is concern that  filtering of any  kind  may  still introduce a
negative bias.  Under basic conditions,  phenols can form calcium  phenoxide  (not
water soluble) which would be removed by  the filtering process.
                                t
    From the observations of well  sampling procedures  performed at  well  T23A as
well as procedures used to obtain samples  for the Task  Force it appeared that all
protocols are  followed by  CWM-V's sampling  team.   In summary,  a  number  of
protocol concerns  have been  identified   above  or  in the  SAP  review.   Those
identified in this  section  include cleaning of  water  level instrument  cable,
lack of filtering  protocol  for "Well  Wizard®"-equipped  wells, and  bias  intro-
duced by filtering of phenol  samples.
                                       34

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    c.  Off-Site Laboratory Evaluation
    Two off-site  laboratories  are  used  by  CWM-V.   All  samples  are sent  to
Environmental  Testing  and  Certification  (ETC),  Inc., in  Edison,  New  Jersey.
ETC does all of  the organic and most of the inorganic analyses.  Total  phenolics
and sulfates are  subcontracted out  by  ETC to  Chyun  Associates for  analysis.
Both of these laboratories were evaluated by the Task  Force and that  evaluation
can be found in Appendix B of this report.  A number of minor deficiencies were
found at these  laboratories, most  of which may  have already  been  corrected.
Based on these  evaluations,  the  Task Force concludes that  CWM-V's past  ground
water self-monitoring data should be classified as follows:

        Inorganic and Indicator Parameters - Qualitative
        Volatile Organics - Quantitative
        Semi volatile Organics, PCBs,  and Pesticides  - Qualitative,  Biased Low

H.  RCRA Permit (40 CFR 264 and 270)
    The original Part B of the RCRA permit application (40 CFR 264 and 270) was
submitted to the USEPA,  Region  V, on May 16,  1985.  Additional information was
submitted on November  7,  1985.   The original  application was deemed  inadequate
and a  Notice  of  Deficiency  (NOD)   was  issued  on May  16,  1986.   Additional
information was submitted on  September 26 and October  7, 1986.  The RCRA Permits
Section of Region V and  the Ohio EPA are  currently reviewing  the new information.

    This permit application  addresses hazardous  waste treatment  and  storage at
the facility using equipment at or above the ground surface (e.g., tanks) which
would not require a  ground  water monitoring program.   The application does not
address the closure of the ponds (surface impoundments) or the  proposed hazardous
waste disposal   cell  which  requires ground water  monitoring.   The  ground water
                                       35

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monitoring program is  addressed  in  the CAFO.   Closure  of these units  will  be
conducted under the authority of 40  CFR  265.  Eventually, the permit will have
to be  modified  to  include the  post  closure  monitoring  requirements  of  the
closed portion of the facility.

I.  Task Force Sampling
    1.  Methods
    All samples  were  collected  by a  USEPA contractor,  Alliance  Technologies
Corporation (Alliance)  using  all  of the  appropriate guidelines  mentioned  in
Reference 28.  Sampling  by Alliance  was  performed  under  the  supervision of EPA
personnel.  CWM-V  contractor  personnel   operated  the  CWM-V  owned  sampling
equipment as directed by Alliance and  USEPA representatives.   Dedicated facility
sampling equipment was  used at  each well  site.   The facility  contractor  was
IEP,  Inc., of Westerville, Ohio.  Replicate volatile organic  samples and splits
of all  other  samples  were offered  to the  facility.  This  offer was declined.
Alliance provided  equipment  used to  collect  surface  water  samples  along with
all sample  containers  and preservatives   used  for  the  Task   Force  samples.
Alliance also provided all equipment and materials necessary  to manage, handle,
field  filter, document, and ship the  required samples.  Field analyses (in situ
data)  were also performed  by Alliance.

    All wells were monitored  for organic  vapors  when first  opened.  Prior to
purging or  sampling  the monitoring  wells, water  levels  were measured  in  all
wells  for use in  the geological evaluation of the site. Monitoring  well sampling
was preceded  by  purging operations  (using bailers or pumps).   When possible,
a volume  equal  to three  times  the  volume of  water  present  in the well  was
evacuated.  If it  was  not  possible to obtain  the  three  well  volumes, the well
was purged to dryness.
                                       36

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    Purge water disposal  was the responsibility of the facility.  Purge volumes
were measured in calibrated  buckets.   In all  cases purge water was  spilled on
the ground by facility personnel  a  short distance from  the  well  being purged.
Wells that were  purged to  dryness  were  sampled when  there was  a  sufficient
recharge volume of water to  fill  at  least  one parameter bottle set.   In  a  few
extreme cases this practice  was  not  strictly followed.  Six  of the  18  wells
sampled were purged  to dryness  on  one  day  and  sampled on the  next  day(s).
Wells that were  not  purged  to  dryness had three  well  volumes  removed  before
sampling.  Slow recharging wells  were  also  sampled when there  was a sufficient
volume of  water  for  at   least  one  parameter  bottle set.    For  example,  the
extractable organic samples  had to  be collected when  there was  a  sufficient
volume of  water  in the  well  (4  liters)  for all of the extractable  organic
bottles.  For 12  of  the  18-wells sampled, it  was  necessary to  return  to  the
same well on successive days  in order to obtain a complete  set  of samples.  A
summary of purging and sampling data  can be found in  Appendix C.

    A total of 18 wells were sampled  at this facility.  Eight of the wells were
equipped with bladder  pumps  (Well  Wizards®);  the remainder  were  equipped with
stainless steel  bailers with  Teflon®  check  valves.   Sample  bottles  were filled
directly from a short  segment of  Teflon® tubing  connected to the top  of  wells
equipped with bladder  pumps.   Sample  bottles were  also filled directly from
stainless steel  bailers  by pouring  from the  top  of the bailer.   The  surface
water sample  was   collected   directly  into the  sample containers.   Leachate
samples were obtained using an intermediate glass sampling container from which
the sample bottles were  filled.  These  intermediate  containers were  from  the
standard stock of sample  bottles used by Alliance.
                                       37

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    Table 6  lists  the  parameters  (analytical  groups),  sample  bottle  types,

and preservatives used  in this  survey.   The  parameters  are listed  in  the order

in which they  were  sampled.   All  samples  were  shipped  for  analysis  to  the

contract laboratories indicated below:


    Laboratory        Location                    Components to be  Analyzed

    Compu-Chem     Research Triangle  Park, NC     Dioxins, Furans
    EMSI           Camarillo, CA                  Organics
    Centec         Salem, VA                      Inorganics


All shipments were made in  accordance with applicable  Department  of  Transpor-

tation (DOT)  regulations  (49  CFR  Parts  171-177).   Leachate  and  suspected

contaminated samples  were shipped as  "medium-level  hazardous" and other samples

from wells  and  surface  points  were   shipped  as  "environmental".   All  samples

were collected in accordance with guidance in Reference 29.


    Each sample shipment was  accompanied  by a chain-of-custody record, completed

by Alliance, identifying contents  in  terms of sample type, date  and time, etc.

The original records accompanied the  shipment,  and a copy  was provided  to the

Field Team Leader.  No samples were split with the facility.


    All  samples taken  from  the  CWM-V site were  documented  with a  receipt  for

samples  form, completed  by  Alliance.  The sample  tag serial  numbers  from  all

samples  shipped off  site were recorded  on the form,  and  a  copy  of the receipt

was provided to  facility personnel.   Alliance also performed  all  analyses  for

pH, specific conductance, temperature, and turbidity,  as well as field filtering

of the dissolved metals  samples.   Samples were  designated to be  analyzed  for

the constituents listed in Appendix D.
                                       38

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    Quality assurance and control  (QA/QC)  for USEPA contractor sample  collec-
tion, handling, and analysis were  conducted  in  accordance  with  the  appropriate
protocols in  Reference  28.   The  Sampling Team  monitored Alliance  procedures
during the  sampling  effort  to  ensure  consistency  with the QA/QC and  evidence
handling requirements.  In addition, the following  QA/QC samples ware required.

    a.  Blank Samples
    These samples included  field  blanks,  equipment blanks,  and  trip  blanks.
Field blanks were prepared by Alliance using  distilled  deionized water  of  known
high purity, and unused sample bottles.  Alliance  prepared two  field blanks  at
representative sampling sites  (well  sites  L-15 and L-35)  for  all  parameters
sampled during the inspection.   Alliance  prepared  one   set  of trip  blanks  for
each type  of  analysis (e.g., organics,  metals, volatiles) prior to departure
       *
from its home office in Bedford,  Massachusetts.   The trip blank  accompanied  the
sampling crew throughout the entire sampling procedure  and  was submitted  for
analysis along, with the last day's  samples.  Equipment  blanks  were  not  prepared
by Alliance, as  all  equipment which contacted sampled   liquids  was  supplied  by
the facility  in  the  form of  dedicated sampling devices,  bailers,  and pumps.

    b.  Duplicate Samples
    At each sampling  location where volatile organics  were sampled, duplicate
samples (i.e., two VOA vials)  were  taken.   Samples  at two sample locations were
collected in  duplicate  for   all  parameter types.   The  duplicate  sample  site
locations are identified in  the  following  section.
                                       39

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    2.  Sampling Location

    The sampling locations for this investigation are listed below:

Lacustrine Wells            Till  Hells                   Bedrock Wells

 L-15 (field blank site)    *T-19                        *MW-14R
 L-19                        T-24 (background)           *MW-16R
*L-20                                                    *MW-21R
 L-21                                                    *MW-23RA (background)
*L-26 (duplicate)                                          P-10
 L-27
*L-29
 L-31
 L-34 (duplicate)
 L-35 (field blank site)
 L-39 (background)          *Wells equipped with dedicated bladder pumps.

Non-Ground Water Sites

Waste Pile Leachate (1)
Surface Water (1)

Quality Assurance Samples

Duplicate Samples (2) Designated Above
Field Blanks (2)
Trip Blank (1)


    3.  Scheduling

    Prior to  sampling  activities,  water levels were measured  in  all  available

wells for use  in the  geological  evaluation.   This  was performed  earlier,  on

March 29, 1987, by facility personnel, with USEPA supervision.  Many logistical

considerations, particularly  well  performance,  affected  the time  required  to

obtain the samples and  influenced the sequence  of  sampling.  The Sampling Team

Leader, in conjunction with the Technical Review Team, identified one additional

sampling point  (well  P-10)  during  the on-site  inspection.   This  well  was then

added to the schedule.  Special scheduling effort was also required to complete

the leachate  sampling  because  the sampling  points were  located  in an  area

designated as a TSCA  waste  storage  site  which  required  that  special  safety

precautions be taken.

                                       40

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    The Sampling Team members  calculated  water volumes  in  each well  from  the
static water levels  measured  at  the time  of purging,  and then proceeded  to
remove three well  volumes.   Task  Force  Field Team members  recorded  the  above
data in the field logbooks,  as  well as the starting and ending times of purging,
sampling times, and unusual  activities taking .place  in  the  area during purging
and sampling.   Unique  characteristics  of the  monitoring  well   or its  contents
were also noted by the Sampling Team.

    Field work began on  Monday, April  6, 1987, and  was  completed  on April  14,
1987.  The actual sampling work was conducted during the hours  of 0800 to  1700.

J.  Ground Water Quality Interpretation
    1.  Task Force Analyses
    Samples were analyzed by the  USEPA  contract  laboratories for the parameter
groups shown in  Appendix  D.  Laboratory  analytical  results  were obtained from
three USEPA  contractor laboratories participating  in the  Contract  Laboratory
Program (CLP).   Standard quality  control  measures  were   observed  including:

      -  Analysis of field and laboratory blanks  to allow detection  of possible
         contamination due to sample handling;
      -  Analysis  of  laboratory  spike  samples  and  performance  evaluation
         samples;
      -  Analysis of laboratory and sample duplicates  to estimate precision; and
      -  Review and interpretation of the  results  of  these control measures.
         These procedures can be found in Reference 30.

    The QA/QC summary can be found in Appendix E.  Appendix F is a table of the
analytical results  for all  constituents  found above the limits  of detection.
Appendix D provides a  summary,  by parameter, of  the analytical  techniques used
and the reference methods for the sample analyses.

                                       41

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    2.  Data Interpretation

    a.  Organics

    Results from  six  monitoring  events  at  CWM-V  were  available  to the  Task

Force for use in  evaluating  the presence of specific organic  compounds  in the

ground water at  CWM-V.  These consist of an  October  and  December  1983  volatile

organic (VOA) sampling, the April and October  1986 plus  the  April  1987  Consent

Agreement and Final  Order  (CAFO) monitoring events, and the Task Force sampling.


        (1) Methylene chloride

        Positive results for methylene chloride were  found in two  bedrock wells

    in 1983; six lacustrine and  one  till well  in April  1986; eight lacustrine,

    three till  and eight bedrock wells in October 1986;  eleven lacustrine, four

    till, and two bedrock  wells in  April 1987;  and two  bedrock,  one till, and

    four lacustrine wells in the Task Force results.   Most of the  these results'

    can be disregarded because the results  are  below  background levels for that

    particular sampling event and ground water zone  or,  as  in the  case  of the

    Task Force  sampling,  because  methylene chloride was  also  found   in  the

    blanks associated  with that  sample.   With this  in  mind,  the  following

    selected methylene chloride  sampling results remain  of concern to the Task

    Force because they were above background levels:

           Sampling Event          Well           Methylene Chloride (ppb)

           1983 (VOA)             3N                       53
           October 1986 CAFO      MW-16R                   34.2
                                  MW-21R                   25.2
                                  MW-38R (background)      21.0
           April 1987 CAFO        L-22                     40.2
                                  L-23A  (background)       8.97

    The Task Force  recommends that methylene chloride results from these wells

    be tracked  closely with  increased monitoring to  determine if  these  results

    are significant.

                                       42

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    (2) Methanol
    Methanol  was  found by  CWM-V  in  two wells, L-20 at  92.1  ppm  and MW-38R
at 19.3 ppm, during  the  April  1986 CAFO  sampling event.  Mo  methanol  was
found in any  wells  during  the  October  1986 or  April   1987 CAFO  sampling
events.  The Task Force did not  look  for  methanol in  its sampling program.
It should be  noted  that in  the  April 1987 CAFO sampling, the detection level
for methanol  increased from  10 ppm (in 1986 samples) to 60  ppm  and in the
case of L-19 and  T-19, 100  ppm.  These detection  levels  need  to be explained
by CWM-V since the  new  detection levels are above  concentrations  found in
the April 1986 sample.   Due  to the presence of  methanol stated  above, the
Task Force  recommends  that  methanol  results  be  tracked  closely  with
increased monitoring  to  determine  if these results  are  significant,  and
that the  detection  level  be  reduced to  the  previous level   of  10  ppm.

    (3) Methyl  ethyl ketone (2-butanone)
    Methyl ethyl   ketone  (MEK)  has been  found  by  CWM-V  as  shown  be-low:

         Sampling Event         Well       Methyl Ethyl  Ketone (ppb)
April 1986 CAFO
October 1986 CAFO






L-34
L-34
L-35
MW-14R
MW-21R
MW-23R
MW-24R
MW-38R
12.0
12.3
31.7
11.5
11.7
18.1
11.2
11.6
The Task Force did  not  find  significant concentrations of MEK (2-butanone)
in its samples and  what was found was  disregarded  after quality assurance
review of the  data.   Thus, the Task  Force  did  not  confirm the presence of
MEK in the ground water and  recommends that MEK results be tracked closely
with increased monitoring  to determine  if these results  are significant.
                                   43

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    (4) 1,2-Dichloroethane

    This organic  compound has  been  detected  during  the sampling  events

stated below:

                                                  Concentration
             Sampling Event             Well          (ppb)

             April 1986 CAFO            L-19        10.1/8.81
             October 1986 CAFO          L-19            12.1
             Task Force-April 1987      L-19             5
             April 1987 CAFO            L-19             9.1


    The Task Force also  found  trace levels  (1-2  ppb)  of 1,1-dichloroethane

in wells  L-19  and  L-26.  The  consistent  presence of  1,2-dichloroethane

during each  sampling  of  L-19  is  of  concern  to  the Task  Force.   The Task

Force recommends  that  a  ground  water  quality  assessment be  conducted  to

determine the rate and  extent  of 1,2-dichloroethane migration at  the site.
                                                                      •»

    (5) Other organics

    CWM-V's self-monitoring  data  show   the  following  specific  organic

compounds detected (other than those already mentioned) during the sampling

events stated:

                                                           Concentration
  Sampling Event        Well         Organic Compound           (ppb)

 October 1983 VOA      IN          Benzene                    12
                       P-10        Benzene                   113
                                   Toluene                    44
December 1983 VOA      P-10        Toluene                   289
                                   Ethyl benzene              350
 October 1986 CAFO     MW-23RA     Chloroform                  5.92


    Specific organics found  by  the  Task Force sampling  efforts  are listed

in Appendix  F.   In  summary,  the  Task  Force found the  following  number  of

valid specific  organic compounds in each well:
                                   44

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Number of
Well Organi
L-15
L-19
L-20
L-21
L-26 (duplicate)
L-27
L-29
L-31
L-34 (duplicate)
c Compounds
6
6
8
1
23
0
0
0
3

Well
L-35
L-39
T-19
T-24
P-10
MW-14R
MW-16R
MW-21R
MW-23RA
Number of
Organic Compounds
1
0
1
0
19
0
1
2
16
Note that acetone, methylene chloride,  2-butanone  (MEK),  bis(2-ethylhexyl)
phthalate, 2-methylcyclopentanol,   the  compounds  specifically  stated  as
unknown, and the unknown alkylamide results were disregarded in this count,
after the quality assurance review of the data.   Other classes  of unknowns,
as identified in Appendix  F,  were used  in the  above  count.   It  should  be
noted that the term "unknown"  as  it is used in the  Task Force results means
that the organic compound  could not  be  identified by  the  laboratory.   The
count noted  above  for  duplicate   samples  (L-26  and   L-34)  includes  some
compounds that  only  were found in one  of the two duplicate samples.   The
high number  of  organic  compounds  found  in  some of the Task Force  samples
indicates the  need  for  a  ground  water  quality  assessment  at   CWM-V.

b.  Indicator Parameters
    (1) Total organic halogens  (TOX)
    Many of  the lacustrine zone   monitoring  wells show  high  TOX  values.
This is especially true of L-26 (values range from  1313 to 2080 ppb) to the
south of the waste pile.   Other  wells such as L-15 (range  from  131 to 310
ppb), L-19 (range from  177 to  273  ppb),  L-20  (range from  397 to 1173 ppb),
L-28 (range from 189  to  204 ppb), and  L-30  (range from 295  to 1069 ppb)  also
                                   45

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contained high  TOX  values.  A  number of the  other lacustrine  wells  have
never been  analyzed  for TOX,  such  as wells L-21,  1-22,  L-29,  L-31,  L-32,
L-33, L-34, L-35, 1A, and  6A.   The  Task  Force  concludes that  these results
indicate possible  contamination of the  ground  water,  in the  lacustrine
zone, from the hazardous waste pile or the old lagoons on site.   The source
and extent  of  this  contamination must be specifically  determined  by  CWM-V
in a  ground  water quality assessment.  An expanded  monitoring  program for
TOX should be implemented for all lacustrine  wells on site, and the specific
halogenated organics  or  other   compounds  that  are causing  the  high  TOX
values should be identified.

    Some of  the bedrock  wells  have  also shown  significant  TOX  results.
CWM-V results  indicate  that wells  IN,  2, 3N,  6N,  7,  8,  11, 12,  13,  and
                                                  •»
MW-37R show the  periodic  presence  of significant  (greater  than  100  ppb)
TOX levels.  The  Task  Force  results found  MW-14R  (120  ppb)  and MW-23RA
(129 ppb) to be  high  in TOX.   These results  are confusing because some of
these wells are  somewhat  removed,  both  horizontally and  vertically,  from
the waste management  units.  The cause  for  these periodic high  TOX values
in the  bedrock  wells  should  be   investigated  and  explained   by  CWM-V.

    (2)  Ammonia,  chemical  oxygen demand  (COD),  and  oil  and  grease  (O&G)
    These parameters have  been  analyzed  in  samples from  only the  non-CAFO
wells.  Significant  COD levels  (greater  than  50 ppm) have been found in all
non-CAFO wells, with  wells 1,  IN,  1A, 4N,  6N,  11,  12  and 13 showing  more
significant numbers  of  high results  than the  rest of  the wells.   Well  1
contained levels as high  as  600 ppm  of  COD.  Also, periodic high  results
for O&G  (greater than  10 ppm)  have  been  found in wells  1,  3A, 4, 4N, 5,  6,
                                   46

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6N, 6A, 11, and  12.  All of the non-CAFO bedrock wells show at least periodic
high ammonia levels (greater than 0.5 ppm).  Well  8 is a background bedrock
well and it  also  contained ammonia  levels  as  high as 1.5 ppm.   Wells  IN,
3N, 6N, 7, 11, and 12 all  contained  ammonia  concentrations  over background
levels found in well  8, with well 12 being as high as 20 ppm.

    Though well construction may be  a  factor in  some of these results,  the
Task Force  concludes  that  the  above-mentioned  results  indicate  potential
ground water  contamination at  CWM-V.   It  is  recommended  that  additional
monitoring of ammonia, COD and O&G be initiated for all monitoring wells on
site.

    (3) Other indicator parameters
    Self-monitoring data  from  old  bedrock  wells  3 and  6  show  somewhat
consistent high  pH results.   The Task  Force concluded that these  older
wells were probably grout contaminated and were not indicating ground water
contamination for  pH.   This  conclusion  is  also  based • on  the  fact  that
replacement wells  3N  and  6N  have  shown  no high  pH levels.   Also,  total
coliform bacteria have been found to periodically exceed the USEPA drinking
water standards in wells  7, 8, 11,  and 12;  but  these levels do  not exceed
the background  levels  found   in  well  8.   Thus,  these  results  are  not
considered to  be  an  indication  of  ground  water  contamination  caused  by
CWM-V.
    Total organic carbon  (TOC)  has been found  to  be high (greater than  100
ppm) in  well  1A.  Also,  periodic high levels  of  radionuclides  have  been
found to exceed the USEPA drinking water standards and background levels in
bedrock wells  IN,  2,  5,  6N,  7, and 12.   CWM-V  does not  monitor  the  CAFO

                                   47

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wells for the above-mentioned  parameters.   The  Task Force recommends further
investigation, by  CWM-V,  into the  source of  the above-mentioned  TOC  and
radionuclide levels.  The  CAFO  wells  should  also  be  analyzed  for  these
parameters.
    Host of the  wells on  site have been  found  to contain  above detectable
levels of total phenol,  but not all of the wells have been found to contain
values above  background  levels.   The  highest  background levels  are  noted
below:
                   Zone         Well      Total Phenol (ppb)
Bedrock
Till
Lacustrine
8
T-23
L-39
180
15
19
     Wells that  have  been  found  to  contain  total   phenol  levels  above
background levels are as follows:
                               Well -     Total Phenol  (ppb)
Bedrock




Till

Lacustrine




1
IN
3
6
7
T-19
T-27
1A
3A
L-20
L-26
L-35
188
89,000
480
380
280
21
53
400
120
73
59
28
                                                   59 (Task Force results)
                                                   28

    Although the  results  are  scattered, they  indicate  contamination  may
exist around  wells  1,  IN,  and  1A.  The Task  Force  recommends increased
monitoring and  further  investigation into the total  phenol  levels on site.

                                    48

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    c.  Inorganic Parameters
    A number of  inorganic  (heavy metals) constituents  have  been found  in  the
ground water through  facility  self-monitoring and Task Force  analysis.   Those
found were arsenic, cadmium, and chromium.

        (1) Arsenic
        Arsenic has been  found  by CWM-V in  self-monitoring  data from well  11
    (50 ppb) and well  12 (60 ppb).  These were one time results which  are at or
    over the USEPA  drinking  water standard  of 50 ppb.  Due to  the horizontal
    and vertical distance of these wells from the waste management  units  at  the
    site and the fact  that  no other bedrock wells closer to the waste management
    units have  been  found  to contain  such  levels of  arsenic, the Task  Force
    does not consider these results  to indicate ground  water  contamination from
    CWM^V.Thff Task Torce^does  recommend that arsenic  continue to  be  monitored
    for indications of any developing trends.

        (2) Cadmium
        Cadmium has been periodically found by CWM-V to  exceed the USEPA drinking
    water standard of 10 ppb in  nine of the  non-CAFO  bedrock  wells.  Background
    well 8 had the highest value  of  4820 ppb.  The highest nonbackground  value
    for cadmium was found in well 6N  at  47 ppb.   Since the high  result in well
    8 has never been duplicated  (all  other  results from well  8 have been below
    detection levels)  it is  probably an error.  The same  conclusion  could  be
    drawn for the cadmium levels found in the other bedrock wells on site since
    the highest results  were seldom duplicated in the numerous  analyses done on
    these wells.   Thus,  the Task Force  cannot  conclude that  these cadmium
    results indicate ground water  contamination from the waste management  units.
                                       49

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    In the lacustrine  zone,  well  1A  has a  consistent  history of  cadmium
contamination with the highest  value  found at 81  ppb.   This well  has  not
been sampled since 1980 and has been abandoned.   The lacustrine zone around
this old well is probably contaminated and the Task Force recommends that a
ground water quality assessment  be initiated  in  this  area.   The Task  Force
sampling found 13 ppb of dissolved cadmium in well  L-19.   This may indicate
that the  lacustrine   zone  near  L-19 is  contaminated.   The  Task  Force
recommends further investigation into this possibility.

    (3) Chromium
    Fourteen lacustrine wells  have been  found to have chromium levels that
exceed the USEPA  drinking water  standard  of 50 ppb.   Only  seven  of them
exceed the highest background  level  of 150 ppb  found in  well  L-23.  These
seven are L-14  (350  ppb), L-16 (390  ppb), L-19  (290  ppb),  L-21  (301 ppb),
L-30 (210 ppb), L-33  (780 ppb), and  L-34 (392 ppb).  These  results  are an
indication of"contamination  and the  Task Force  recommends  a  ground  water
quality assessment be conducted.

d.  Areas of Concern
    (1) Bedrock wells
    Many of the older  bedrock  wells (1,  IN,  2,  3,   3N, 4, 4N,  5,  6,  6N, 7,
8, 11, 12, and 13) have been found to contain high  TOX,  COD, O&G, ammonia,
radionuclides, and total  phenol.   The  Task Force suspects that these results
indicate periodic contamination  of the bedrock ground water zone  by CWM-V,
but further  study  is  needed  to confirm this.  Of  the newer (CAFO)  bedrock
wells, only  MW-23RA   showed   significant organic   contamination,  and  the
sample had a sulfide odor when  collected by the  Task  Force.  MW-23RA is
                                   50

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considered to  be  a  background well  by  CWM-V,  but  these sample  results
indicate this well is contaminated, possibly from another source, and is of
questionable value as  a background  well.  Piezometer  well  P-10 has  been
found by CWM-V to be  contaminated  with benzene, toluene, and ethyl benzene.
The presence  of  these  compounds  was  confirmed by  the  Task Force  sample
results.  The Task Force also found 16 other  specific organic  compounds in
its sample  and noted  that the  sample  had  a  sulfide  odor when   it  was
collected.  The bedrock  zone  around  well  P-10 is  definitely  contaminated
and the Task Force recommends  that  the rate  and extent of this contamination
be identified in a ground water quality assessment.

    (2) Till wells
    The Task Force found no  indication of contamination in the  till  wells
tfiatTexist on site.

    (3) Lacustrine wells
    Three of the  older wells  at  CWM-V are lacustrine  wells (1A,  3A,  and
6A).  Historical  results from  these wells show that  1A is highly contaminated
with COD, TOC, total  phenol,  TOX,  and cadmium.  Well  3A  has  periodic high
COD, O&G,  and  total   phenol  results.  Most of the new  (CAFO)  lacustrine
wells (L-14, L-15,  L-16, L-19, L-20, L-21, L-26,  L-28,  L-30,  L-33, L-34,
and L-35) have been found to have at  least some contamination from chromium,
total phenols, TOX,  1,2-dichloroethane,   MEK,  methanol,  and/or  other  or-
ganics.  Wells L-19,  L-20,  and L-26 show the highest concentrations of these
contaminants.  The  Task  Force recommends  that  a  ground  water  quality
assessment be developed  for the lacustrine  zone on  site,  with  emphasis on
the area around L-19, L-20, and L-26.
                                   51

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    (4) Collection pond east of waste pile



    The Task Force collected a sample from the above-mentioned pond (sample



number MQB-326) and  from  a stream  of liquid flowing to the  pond  from the



waste pile  (sample number  MQB-306).   Task Force  sample  results  were found



to contain hazardous  waste constituents (see Appendices F and G).
                                   52

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                                 REFERENCES
 1.  Bentley, M. E., Kent,  R.  T.,  and Myers,  G.  R.,  "Site  Suitability for Waste
     Injection, Vickery, Ohio," UIPC Symposium 1986, pages 330-354.

 2.  Bowser-Morner,  Inc.,   "Hydrogeologic  Assessment,  Northern  Ohio  Treatment
     Facility, Vickery, Ohio," May 1983.

 3.  Bowser-Morner, Inc., "Surface Water Run-on and Run-off Evaluation, Northern
     Ohio Treatment Facility, Vickery, Ohio," May 1983.

 4.  Consent Agreement  and  Final  Order, Docket  Nos.  TSCA-V-C-307  and RCRA-V-C-
     000, between United States  Environmental  Protection Agency,  Region  V,  and
     Chemical Waste Management, Inc., dated April 4, 1985.

 5.  Golder & Associates,  "Assessment  of Perimeter  Containment  Dike Stability,
     Ponds 4, 5, 7, 11, and 12, Chemical Waste Management, Inc.,  Liquid Disposal
     Facility, Vickery, Ohio," June 1983.

 6.  Golder  & Associates,  "Continuous  Overburden  Borehole  Sampling  Results,
     Chemical Waste Management, Inc., Vickery, Ohio Facility," May 1985.

 7.  Golder & Associates,  "Evaluation  of Potential  Borrow Areas,  Vickery,  Ohio
     Facility," March 1984.

 8.  Golder & Associates, "Geotechnical  and  Geohydrologic  Data Review,  Vickery,
     Ohio, Chemical  Waste Management Facility," June 1983.

 9.  Golder  &  Associates,  "Ground Water Monitoring  Program,  CWM  Northern  Ohio
     Treatment Facility, Vickery, Ohio," April  1984.

10.  Golder & Associates, "Phase I Ground Water  Monitoring Program, Chemical Waste
     Management, Inc.,  Vickery, Ohio Facility," March 1986.

11.  Golder  &  Associates,  "The  Ground   Water  Program Workplan,  Chemical  Waste
     Management, Inc.,  Vickery, Ohio Facility,  May 1985;" Addenda Nos. 1 through
     4 dated  August  5,  August 27,  October 17,  1985,  and  February 11,  1986,
     respectively.

12.  Golder & Associates, "Physical Property Testing of Fixed  Material,  Chemical
     Waste Management,  Inc., Vickery, Ohio  Facility," August  1984.

13.  Golder & Associates, "Overburden Ground Water Testing Program, Vickery, Ohio
     Facility,"  September 1984.

14.  Golder &  Associates,  "Scaling  of   Overburden  Wells  and  Dike  Piezometers,
     Vickery Facility," January 1986.
                                       53

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                              REFERENCES (continued)


15.  Colder & Associates,  "Stability  Analyses  of Interior Dikes  Between Lagoons
     4/5 and 5/7,  CWM  Northern Ohio  Treatment  Facility,  Vickery,  Ohio,"  March
     1984.

16.  Golder & Associates, "Stability Analysis of Interior Dikes Between Lagoons 11
     and 12, CWM  Northern  Ohio Treatment Facility, Vickery, Ohio,"  March  1984.

17.  Golder &  Associates,  "Summary and  Characterization of Site  Geohydrologic
     Conditions, Chemical   Waste  Management,  Inc.,   Vickery,   Ohio  Facility,"
     September  1983.

18.  Golder &  Associates,    "Surface  Water  Management  Plan, Vickery  Facility,
     Vickery,  Ohio," November 1983.

19.  Golder & Associates, "Monitoring  Program Hydrogeologic Study, Chemical  Waste
     Management, Inc.,  Vickery, Ohio Facility," July  1986.

20.  Hoover, J.  A., "Ground Water  Resources of  Sandusky County,  Ohio,"  Unpublished,
     University of Toledo  Masters  Thesis, 1982.

21.  Norling,  D. L., "Statement  concerning ground water  conditions  in  vicinity
     of Ohio Liquid Disposal, Inc., operations, Riley  Township,  Sandusky County,
     Ohio," presented at  special  meeting  of the  Ohio  Water Pollution  Control
     Board in  Fremont,  Ohio, August 30,  1972, by Ranney Water Systems,  Columbus, .
     Ohio, 1972.

22.  Underground Resource  Management, Inc., "Evaluation  of a Subsurface  Waste
     Injection  System near  Vickery,  Ohio,"  Consultant  Report,  169  pgs.,  1984.

23.  Versar, Inc., "Comprehensive  Monitoring Evaluation," Chemical  Waste Manage-
     ment, Inc., Vickery,  Ohio, September 30, 1987.

24.  Waste Management,  Inc.,  "Manual  for Ground Water  Sampling,"  Waste Manage-
     ment, Inc., Oak Brook, Illinois,  1985.

25.  Waste Management,  Inc., "Site-Specific  Ground  Water  Monitoring  Plan  for
     Chemical Waste Management,  Inc., Vickery  Facility,  Vickery,  Ohio,"  Waste
     Management, Inc.,  Oak  Brook,  Illinois, March 1987.

26.  Witherspoon,  P. A. and  Neuman,  S.  P.,  "Hydrodynamics of Fluid  Injection,"
     in T.  D.   Cook,  edition,  Underground Waste Management and  Environmental
     Implications, American  Association  Petroleum  Geologist Memoir T5~,  pages
     258-272,  1972.
                                       54

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                              REFERENCES (continued)


27.  United States Environmental  Protection Agency, RCRA Ground Hater Monitoring
     Technical  Enforcement Guidance Document (TEGD), September 1986.

28.  United States Environmental  Protection Agency, Hazardous Waste Ground Water
     Task Force Protocol  for Ground Water Evaluation (HWGWTF Protocol), Hazardous
     Waste Ground Water Task Force, September 1986.

29.  United States Environmental Protection Agency, Characterization of Hazardous
     Waste Sites - A Method Manual:   Volume  II.   Available  Sampling Methods,
     Second Edition (see Appendix C), December 1984.

30.  United States Environmental  Protection Agency, Region V, "Quality Assurance
     Project Plan -  Ground  Water Monitoring Evaluation,  Chemical  Waste Manage-
     ment, Inc., Vickery, Ohio Facility," April  1987.

31.  Chemical  Waste Management, Inc., Submission to Maynard (OEPA) and Constantelos
     (USEPA),  March 6, 1984.

32.  Colder and Associates, Appendix II, Closure Cell Design, Phase 2 of Closure
    • Plan for  Ponds No.  4, 5,  and  7,  Chemical Waste  Inc., Vickery, Ohio Facility,
     April 1985.
                                      55

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FIGURES

-------
A* 2O44OA-S
                                                                 LTE LOCATIpN

                                                                     SANOUSKY
           OHIO TURNPIKE 1-80/90
                         APPROX.SCALE: 1  - 0 MILES
       834-1358
 ONAVN
         JLW
 CHCCKCO
NO  SCALE
  3/13/88
                     OW«. NO.
                             391
Figxore 1  - Site Location Plan for
  Chemical Waste Management,Vickery
  Facility, taken from Golder § Assoc.,
  1986.	
         Colder  Associates
                GHByCM. WASTE
                                 1

-------
Abandoned
    Recovery

-------
   200
   400
   600
   800
  1800
  2000
  2200
  2400
  2600
  2800
DEPTH
(FEET)
               BIG LIME
            CLINTON SHALE
             BRAS8FIELD
          QUEENSTON SHALE
          REEDSVILLE SHALE
          TRENTON LIMESTONE
        BLACK RIVER LIMESTONE
             GULL RIVER
COPPER RIDGE
 DOLOMITE
            Kerbel  Fm.
          Conasauga Fm.
           ROME DOLOMITE
          ROME SANDSTONE
         L. Rome  DOLOMITE
        MT. SIMON SANDSTONE
            PRE-CAMBRIAN
         Figure 3  - Stratigraphic Units beneath
           the •Chemical Waste Management Vickery
           Facility.

-------
CROSS-SECTION  OF  A WELL




CEMENT

SURFACE CASING

'






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"
f ^


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^
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CEMENT
	 1 NTETOOrATE CAS I NG

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ANNULUS



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(
PRODUCTION CASING


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TUBING
PACKER


Figure 4 - Cross Section of a Injec-
tion Well showing typical . '
construction.
» \
• ^



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-------

                                             .•.:sc""
jo. NO 334-! 35e
       8KB
      Figure 5 - Well, Piezometer,  and Boring
"ZZl  *   Location Plan for  Chemical  Waste Man-
^Tt	   agement Vickery Faclity,  taken from  -n
^r^Colder § Assoc., 1986.                }«
      Colder  Associates
               CHEMCAL WASTE MANAGEI.'.CT NC.

-------
™£~i~-_L —. v_i^lilMtl5§tylil:&
                                                      »-i.i-. ,?".-s'. 3 .(', \.-\' v .
„•• •  , 'ei»T IILI," 4rv-<" •."'-i-5 -••?'
-^^   * "• ' <^',"f \ ,  - ," 'A-
                                     Figure 6  -  Cross Sections  of the Chemical
                                       Waste Management Vickery Facility,
                                       taken from Colder S Assoc., 1986.

-------
A ' 20440A-8
   SANDUSKY RIVER
                  \BURIED
                  •VALLEY
                  r  -I
  Ref. Taken from Bowser-Morner Report (Reference 2)
      (from HOOVER  1982)
        834-1358
 MAWN
          8KB
 CMCCKCD
SCALC 1'-12,500 Approx
                   DATE
       5/14/86
                   M«. NO.
                           402
Figure 7 - Regional Top of Bedrock
      Map, taken from Hoover, 1982,
        Bolder  Associates
                  CHEMCAL mSTE MANAGEMENT NO

-------
                      01 CtTHMTtO MMM OMU.M*



                    S7(>—TO1 Of KMOOI ELEVATKM COVTflM »l JMLl MKO IMI
Figure_8  - Top of Bedrock Map for  the
  Chemical Waste Management Vickery
  Facility, taken from Colder § Assoc.,
  1986.

-------
 A - 2044OA-8
       MAP TAKEN FROM BOWSER - MORNER REPORT (Ref.2)
      LEGEND

      	6IO-
GROUNOWATER  SURFACE
CONTOUR LINE
J08 NO  834-1358
DRAWN
       SKB
CHECKED
     l"=8250'(ApprwO
       8-3-83
                    DWG NO
                            43
Figure 9 - Regional Potentiometric
      Map for the Bedrock, taken
      from Bowser Homer, 1983.

-------
* r 1O44OC-D
                                                                                             A  SOIL BORING WITH PIEZOMETER

                                                                                                ACTIVE DOLOMITE MONITORING WELL

                                                                                                COLDER ASSOCIATES PIEZOMETERS
                                                                            Colder  Associates
                                                                                               Figure  10 - Typical  Potent!ometric
                                                                                         i"' SOP-        Map for the  Bedrock for  1982
                                                                                                       to 1984 period,  taken from
                                                                                                       Goder and Assoc., 1986.

-------
                      CD ' i»S IT 6COC* **SOCi*t£»
                    •Ttlt LiVttl ME *T • -OUW ATTCN MTM.
                    KM W njMrwc |ju MVJ-f? OM TAKE 9
                    r !•« HEMHTIAM) DC*** '•€ HAmMJM
Figure 11 -  Potentiometric  Map for
        the Bedrock  after 8  Hours of
        pumping, taken from  Colder  and
        Assoc.,  1986

-------
\
\ •  r^V
      .-, «>,
                                                       Figure 12 - Potentiometric Map for
                                                              the Bedrock (4/7/86),  taken
                                                              from Golder and Assoc., 1986.
                             |i'

-------
                            L E 0 E N 0
                                  TEST PIT LOCATION

                                  OVERBURDEN MONITORING WELLS
                                  AND  PIEZOMETERS

                                  HOCK AQUIFER MONITORING WILL*
                                  AND  PIEZOMETERS
                                  IMACTIVf MONITOIIINa WEllB
                                  AND PIEZOMETERS


                                  CORING*
                                  CHEMICAL WAiTI UAHAOIUIMT. INC
                                  UONITORIN* WILL!


                                  OHIO IPA WILL NUUfIRt
                              ...   rilSOMITIMt IN«TAHIO AND
                              *"   ODIILII) IT IOWII* «0«NI«.  INC
                                  rtnoutrtm iNiTAitia AT TNI
                                  BlMIOTION Or aOLDIR A1IOCIAT
                                  FOR «*OUNO«ATI« ITUOIII
                                  	INSTAILB-O AT TNE
                                  DIRECTION OF GOIOER ASSOCIATES
                                  FOR DIKE STABILITY STUOIIS
                                 »S-IS

                                 «08.»3 - WATER LEVEL
                             NOTE:

                               IORINOS. PIEZOMETERS. AND MONITORING WELL! tHOWlJ
                               ARE THOSE WHICH WERE INSTALLED PRIOR TO JUIV
                               WATER LEVELS SHOWN M PARENTHESIS OBTAINED BY

                               QOLDER ASSOCIATES ON 0/28/S4

                               WATER LEVELS NOT SHOWN IN PARENTHESIS OBTAINED 9V

                               OOLDER ASSOCIATES FROM AUOU3T «. 1M4 TO AUGUST 13. !»•«.

                               EXCEPT FOR SS-21. OBTAINED ON JULY 11. IM4
834-1358
                  AS SHOWN
  8KB
                  5/7/86
                    AO7
       SHALLOW
GROUNDWATER  LEVEL
   CONTOUR  PLOT
kGolder      Figure  13 -  Potentionmetric  Map  for
                        Glacial  Overburden  (6/84-8/84)
                        Taken from Colder and Assoc.,
                        1986.

-------
Figure 14 - Potentiometric Map for
       Lacustrine Deposit (1/14/86)
       Taken from Golder and Assoc.,
       1986.

-------
Borrow
 Area
                                                                                       RW-4N
                                                                                       (OEPA-1)
                                                                                                    OEPA-4 -Q «*
                               Abandoned
                             Sludqe Farm
                                                                                         Abandoned
                                                                                         Oil  Recovery
                                                                                  H1W-5
                                                                                    (OEPA-2)
                                                                            M>IW-8 (OEPA-3)
                                   Q-OEPA-5
                                                                     Figure 15 - Location of Old (Pre-CAFO)
                                                                       Monitoring Wells at the Chemical
                                                                       Waste Management Vickery Facility.

-------
 Borrow
  Area
                /-3A _-
               L-3K
                L-32
                                               N
                L-14
                                        Injection
                                        Well
                                        Control
                                        Center
                                  New
                                  Truck.
                                  UasH*
MW-1A  CO
O   ^O°
                                                  n
                                                    L-35-
                                           L-:
  L-23
Not to Scale - Locations Approximate
                                                                                L-16
                                                                                        L-17
                                                              L-15.
                              Proposed
                              Disposal
                                Cell

                           (Approximate
                              Location)

                           1-30
                                         Hazardous
                                           Waste
                                            Pile
                                                               -L-25
 Runoff.
•Retention   ^l
 Pond"
                                                                                                 L-18
                         L-20
                                                                             ing
                          J.-27-
                              —
                       Jlecieving
                          Area
                                                                                          Gaurd
                                                                                          House
                                  Office
D
   LEGEND
O  Lacustrine Monitoring  h'ell

(P)  Proposed Lacustrine Monitoring  Well

®  Recommended Lacustrine Monitoring  Well
Q                                              Figure 16 - Location of Lacustrine
                                                Mrmi
                                                                                     Monitoring Wells at the Chemical Waste
                                                                                     Management Vickery Facility.

-------
  Borrow
   Area
                                     Injection
                                     Well
                                     Control
                                     Center
        T-N^
                                                Proposed
                                                Disposal
                                                  Cell

                                             (Approximate
                                                Location)

                                                                                             "Runoff
                                                                                             -Retention
                                                                                              Pond"
       Hazardous
         Waste
          Pile
                                         LJ0DD
                                                       Recieving
                                                         Area
Not to Scale
                       O Til1 Monitoring Well


Locations Approximate!]   ® Pr°P°Sed  T111 Monitoring WeT
                                                                              VT-24
                                                                                                     7-37
                                                                                                     1-3Q
Figure  17 - Location of Till Monitoring
  Wells at the Chemical Waste Management
  Vickery Facility.

-------
   Borrow
    Area
MW-13
                                          Injection
                                          Well
                                          Control
                                          Center
                                                    MW-14R
                            Shop
       MW-11 $ MW-12


                MW-3N
MW-1N  OO


S O^  <"
                                        Proposed
                                        Disposal
                                          Cell
                                     (Approximate
                                        Location)
                                                                                     Hazardous
                                                                                       Waste
                                                                                         Pile
                                           Y   MW-19
                                          MW-2

                                             Parking
                  "Runoff
                  -Retention    -4
                   Pond"
                                                                   fv
                                                                   MW-18R
                                                                                  Q
                                                                                                •MW-7
                                                                                           Gaurd
                                                                                           House
MW-23RA

MW-23R
                                                                                 Q
                                                                                      • MW-5
                                                            HW-24R
                          MW-38R
                          MU-37R


                            V
                                               Bedrock Monitoring Well
                                                      A n j   i  H  -4.  •    .,11
                                               Proposed Bedrock Monitoring Well
  Not
Figure 18 - Location of Bedrock
  Monitoring Wells at the Chemical
                Qv^, r.^"-^" ^^.^.wv-^ ,,u,,,^u, ,,,y ,,v...       Monitoring Wells  at  tne  Lnemicai
                (R) Recommended Bedrock Monitoring Well    Waste Management  Vickery Facility.

-------
 Borrow
  Area
                                       Injection
                                       Well
                                       Control
                                       Center
                                                   Proposed
                                                   Disposal
                                                     Cell
                                                                                                   "Runoff
                                                                                                   -Retention
                                                                                                    Pond"
                                                (Approximate
                                                   Location)
Hazardous
  Waste
   Pile
New
Truck,
WasH
                                                                                     4-y\Gaurd
                                                                                        House
                                                            Recieving
                                                                         Figure 19 - Location of Hazardous Waste
                                                                           Injection Wells at the Chemical Waste
                                                                           Management Vickery Facility.
                              Injection Well
Not to Scale
Locations Approximate

-------
TABLES

-------
                                 TABLE 1

                 CHEMICAL WASTE MANA6EMENT.  VIChERY FACILITY

                           6ROUNDWATER ELEVATIONS
                              LACUSTRINE  WELLS
WELL
NUMBER
L-14
L-15
L-16
L-19
L-20
L-21
L-22
L-23
L-26
L-27
L-28
L-29
L-30
L-31
L-32
L-33
L-34
L-35
L-39
TOP OF CASING
ELEVATIONS
(FEET. MSL)
607.92
608.87
612.70
617.87
614.04
612.08
610.73
613.49
612.41
613.70
613.40
609.65
610.84
611.32
611.78
612.41
612.59
612.15
613.28
HATER WATER
ELEVATIONS ELEVATIONS
(3/30/87) (4/07/86)
(FEET, MSL) (FEET. MSL)
604.78
605.28
605.73
608.77
608.94
607.56
606.21
609.19
608.36
608.95
609.06
603.79
606.22
605.89
606.73
604.30
606.35
o07.59
609.48
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
WATER
ELEVATIONS
(1/14/86)
(FEET, MSL)
604. 15
603.04
604.51
sO&.4
606.56
606.09
605.90
607.18
606.39
o07.26
607.43
602.96
603.86
605. 14
606.21
604.82
606.30
600.82
606.79
NA - Data not available

-------
DECEMBER 1. 1987
                                    TABLE 2
                CHEMICAL WASTE MANAGEMENT, VICKERY FACILITv
                               8RQUNDWATER ELEVATIONS
                                     TILL WELLS

WELL
NUMBER
T-14
T-19
T-23
T-24
T-27
T-37
T-38
TOP OF CASING
ELEVATIONS
(FEET, MSL)
609.84
618.04
613.05
615.25
614.86
615.22
614.50
WATER
ELEVATIONS
(3/30/87)
(FEET, USD
603.67
608.41
604.8?
607.42
606.91
612.16
603.41
WATER
ELEVATIONS
(4/07/86)
(FEET, MSL)
NA
NA
NA
NA
NA
NA
NA
WATER
ELEVATIONS
(1/14/86)
(FEET, MSD
597.98
606. 18
605.^
608.05
606.19
611.45
611.52
NA - Data not available

-------
DECEMBER 1. 1987
                                   TABLE 3

                CHEMICAL WASTE MANAGEMENT. VICKERV FACILITY

                           GROUNDWATER ELEVATIONS
                                BEDROCK WELLS
TOP OF CASING
WELL ELEVATIONS
NUMBER (FEET. MSL)
MW-14R
MW-15R
MW-16R
MW-19R
MW-20R
MW-21R
MW-22R
MW-23R
MW-24R
MW-37R
MW-38R
607.64
607.84
613.76
617.79
614.04
613.10 .
608.49
612.96
614.04
616.40
617.22
WATER
ELEVATIONS
(3/30/87)
(FEET, USD
593.18
593.35
593.28
593.24
593.26
593.25
593.22
593.17
593.31
605.48
605.51
WATER
ELEVATIONS
(4/07/86)
(FEET, MSL)
592.98
593.09
593. 12
592.99
593.08
593. 14
593.23
593.26
593.27
606.06
606.08
WATER
ELEVATIONS
(1/14/86)
(FEET, MSL)
592.67
592.63
592.73
592.71
592.68
592.70
592.69
592.63
592.84
605.34
605.36

-------
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-------
M» 1*6
                                                Table  4  (cont.)
                                        MMITOIIIC NEU MB PIEIMTEI CDNStRUCf ION SUNMMV
                                                                                                                     •Sl-HM
                                        MEU           INIDUESS OF
                               OPEN    MTlllim  MtNM    KNlONirt    HP OF
MILL
Ml.
Nb-IM(2>
T-III2I
L-IH2I
MH«
Ml
1-11
MI-2M
L-21
Mt-211
L-21
M-221
L-22
NM-231
1-21
L-21
NU-241
T-24
L-25I2I
.-a
T-27
>•<»
...
.-rt
MTE
INSIALLEI
-
-
-
•MI-IS
11- IMS
II-2I-B
«-2J-*5
I1-2I-B
W-ll-15
IH4-B
»M7-*3
I*-14-B
1*-*H5
IHI-B
11-24-19
n-11-B
,1-22-19
-
1H1-15
11-23-15
,1-21-*
:*-H-B
14-31-15
SKIM
SlMFMX
-
-
-
614.1
616.1
615.5
611.1
(11.2
611.1
M1.1
6K.4
6*1.2
611.5
(It.!
611.1
(.2.6
612.1
-
4*1.4
412.3
bl'e.i
411.3
6*4.4
TOP OF
CABINS
-
-
-
(17.71
(11.14
(17.17
614.11
614.11
611. N
(12.17
6*1.44
(11.71
(12.26
411*4
(11. 11
(14. »4
(19.25
-
612.41
614.15
til. 71
613.31
4*1.41
INTEMNL
Ift.Mll
-
-
-
946. 6-961. 1
SM.*-5%.5
514.6-4*4.2
94H-9611
5B. 4-611. 4
942.1-991.1
511.1-4*3.5
944.1-9(1.1
5«.*-6*2.7
554.5-571.1
512.4-513.5
912.1-612.1
553.1 -571. 2
511.5-4*4.4
-
4*4.4-512.4
5*1. 1-511.1
Hi. 1-4*5.1
5». 3 -t«5. 3
1*1.1-6*1.1
INIEML
Ift.Mll
-
-
-
546.6
5M.I
914.1
9411
115.4
942.1
9111
944.1
512.1
994.9
512.4
912.1
9511
911.9
-
Ml. 4
SM.I
513..
S3*. 3
511.1 '
OF SEAL
Ift.l
-
-
-
9(17
916.9
(14.2
9611
Ml*
991.1
M19
9(1.1
6*2.7
971.1
9119
M2.1
971. 2
4*4.4
-
614.6
911.1
4*5.1
4*5.3
6*1.1
PELLET SEN.
Ut.l
-
-
-
11.4
4.1
5.1
7.2
9.1
1.2
4.1
KM
4.9
1.2
4.1
9.4
1.6
4.1
-
2.1
3.1
4.1
UNKNOWN
1.1
we*
lft.nl)
-
-
-
961.7
UNKNOWN
UMUOM
9611
UNO*
951.1
UNKMMN
961.1
UNKMMN
571.1
UMUOM
IMKMMN
57*. 2
UNKMMN
-
UNKMMN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
US1NS
TYPE
-
-
-
2', IK SS
2',11( SI
2',1K SS
2*,JK SI
2', IK SS
2', 116 SS
2',116 SS
2',1I6 SS
2', 116 SS
2', 316 SI
2-.3K SS
2', 316 SS
2", 314 SS
2%1K SI
-
2', 314 SS
2-, 116 SS
2".3l4 SS
i',316 SS
2', 116 SS
MTEIIM.
-
-
-
H
K
H
K
•
n
H
N
H
K
K
N
H
H
-
K
K
W
K
16
FOfMTION
SCKEMII
-
-
-
KCN
TIU
DC.
KCN
uc.
KCN
LlC.
KCN
UC.
KCK
TILL
UC.
OCX
TILL
iflC.
' UC.
TILL
UC.
.flC.
LAC.
KU
STATUS KNMMS
TO K MlLlil
TO K NIU0
TO K MILLED
MMITOKI
MMITOKO
MMITOKI
MMIIOKD
MMITOKI
MMITOKD
MMITOKI
MMITOKD
MMITOKI
MMITOKD
NONITOKI
MMITOKD
MMITOKI
MMITOKD
TO K MkLEI
MMITOKI
NONITOKI SCKENEO IN SRN* IICH {ONE
•UMTOttO
^..rotto
NONiioKD T^en from G
                                                                                                                           Colder  f, Assoc.,  1986

-------
JULT IW
       Table 4  (cont.)
munm cu M PIEIKTEA CONSTRUCTION
                                                                                                   W-J02*.
CM
NELL
NO.
i-JI
L-ll
L-12
L-ll
L-34
L-35
W-3UI3I
M-17R
T-37
W-3M
T-a
I.-39
M-l
M-S
M-.»
M-ll
*<9
P-4
P-5
;-6
PI
MTE SROUt)
INSTALLED SURFACE
ID-2D-IS 4*7.1
ID-1I-B M7.1
ID-29-DS Ml. 5
ID-2D-D5 Ml. 6
ID-ID-DS 41*. I
ID-ll-IS 6M.4
-
ID-IS-B 113.2
\t-it-to i!2.1
II-I2-D5 413.7
II-I4-D5 i!3.i
11-17-15 41*. 1
ID-I4-D2 Ml.l
ID-14-12 ili.5
ll-li-D2 M4.2
ID-14-12 MM
l»-l9-8i 4ID.3
ft-tt-83 419. 1
ft-28-83 419. 3
15-16-83 4*9.3
K-a9-83 4*3.9
flpa i
TOP OF INTERVAL
CASINB iri.Mll
61*. M S96.2-M1.I
111.33 SU.I-M2.1
411. H 59D.7-M3.I
412.42 594.7-M3.3
il2.il 5*1. 5-4*4.1
412. 11 511. 4-4*3.1
-
ili.41 531.2-513.4
4IS.22 5W.I-M5.1
117.22' 531.4-343.7
i,».» MD.4^.5
ill. 21 4*2.1-4*4.4
Ml. 14 537.1-557.1
ilS. IV SK.D-S71.D
4*5.1* 544.2-554.2
4D2.15 541.1-555.1
412.4* 544.3-S44.3
411.41 571.1-5*2.1
6 11.44 59S. 3-4*5.1
611. j« 5JI.JS46.*
611.8* 597.9-4(5.8
KU
urmiit
in. •!>
^
511.1
51*, 7
514.7
5*9.5
511.4
-
551.2
SH.i
SSI.i
S1D.4
M2.I
517.1
534.1
544.2
541.1
5*6.3
574.1
595.3
5JI.J
Uf.9
nim
OF SEAL
If I.I
Ml.D
M2.1
413.1
Mil
M4.I
M3.I
-
543.5
MS.i
543.7
M4.5
414.4
557.1
574. D
354.2
553.9
544.1
S62.D
4*5.1
544.*
4*5.1
THIDUCSS OF
DENTMITE
PELUTStAL
Ift.l
4.D
3.7
3.2
4.D
4.D
13

2.7
4.D
4.1
4.7
2.1
14. D
N/A
N/A
2.D
N/A
N/A
N/A
N/A
N/A
TOP OF
NOCK
Ift.nll
UMNO*
UNNOM
UNKNOWN
UMNO*
UNKNOWN
UNKNOWN
-
544.7
UNKNOWN
517.2
UNNOM
UNKNOWN
557.1
S7i.D
554.7
552.1
567.8
UNKNOWN
UNKNOUN
,**»,
UNUlOWt
MINI
r.iii ss
r.iu si
2Mlt SS
2-.3H SS
2', 314 SB
2-.314 SS
-
2', 314 SS
2', 311 SS
2.r, PVC
2.r, PVC
2'. 311 SS
I.Z5-, PVC
1.25% PVC
1.25*, PVC
1.25% PVC
\.a; PVC
2.D", PVC
t.V, PVC
i.f. PVC
i!.*', PVC
Moriu
MTEIIRL 1
DS
M
H
DS
DS
DS
-
K
DS
K
M
IS
I/CEMENT
I/CEHENT
I/GENENT
I/CENENT
I/CEKNI
I/CENENT
I/CENENT
MZKM
I/CENENT
FOMHIO
SCREEKI
LAC.
LAC.
LAC.
LAC.
LAC.
LAC.
-
ROCK
TILL
ROCK
TILL
LAC.
HEN
HEN
RDM
HOC*
ROCK
TILL
LAC.
DOCK
LAC.
1 HELL
STATUS
NMTOREI
NMITOREt
NONITOREI
KMITOREI
NftlTOm
MMITORD
TO DE MILLS
NONITOREI
MONITORED
NONITMED
MMITOREB
HDNITORED
ACCESSAW
ACCESSW.E
ACCESSMLE
ACCESSADLE
ACCESSABLE
ACCESSADLE
ACCESSABLE
ACCESSACLf
ACCESSAtLE
RMMNS


9CREENII IN SAM IICH IOC



D


OMPAMTIVE STUDY
NONITOAINS UEU
CONMMATIVE STUDY
NONITMINE HtLL
SCREEN INTERVAL
INSANDLENSE

NO DENT. SEAL
NO DENT. SEAL

M BENT. SEAL
NO DENT. SEAL
M) KM. SEAL
V) KM. SC'«L
TaV^n f-rnm Hn
                                                                                                 from Colder  § Assoc., 1986

-------
                                                OO
                                                u
                                                o
                                                (SI
 5
 2
    i
  ?  a
   • Jl  1  • *>  •
          — — i ~  5  s J  3  S 3  S  91 s  S
              n  irt  iw 
-------
SITE:   Vickery
( 490
   Table 5



WEIL ID CHART
DATE:  11/14/86

WELL
ID 1

LI 4
L15
L16
L19
L20
L21
L22
L23
L23A
L26
L.27
L28
L29
ACTIVE
OR
CLOSED

A
A
A
'A
A
A
A
C
A
A
. A
A
A
PURPOSE

CAFO
and
TSCA
CAFO
and
TSCA
CAFO
and
TSCA
CAFO
and
TSCA
CAFO
and
TSCA
CAFO
only
CAFO
only

CAFO
and
TSCA
CAFO
and
TSCA
CAFO
T§CA
CAFO
and
TSCA
CAFO
only
GRADIENT

Lateral
Lateral
Lateral
Lateral
Lateral
Lateral
Lateral

Lateral
Lateral
Lateral
Lateral

DEPTH
OF
WELL
(feet)














ELEVATION
AT TOP
OF CASING
(msl)

607.92
608.87
612.70
617.87
614.04
612.08
610.73

613.49
612.41
613.70
613.40
609.65
NORMAL RANGE
PURGE
VOLUME
(gallons)

2.2-2.4
2.1-2.5
1.1-2.6
2.1-2.5
1.9-2.2
1.7-2.0
2.1-2.4

2.0-2.7
6.1-7.2
2.4-3.0
6.0-7.5
4.6-5.4
DEPTH TO
WATER
(feet)

4.29-4.34
3.60-4.90
6T95-7.86
8.62-10.33
5.23-6.45
5.00-7.00
3.30-4.90

4.00-5.00
5.00-7.30
4.55-5.30
4.66-7.59
5.79-7.59
RECHARGE
TIME
(hrs)

48 hours
>3 days
> 3 davs
48 hours
36 hours
24 hours
36 hours

<.3 days
^12 hours
24 hours
^.16 hours
^16 hours
TEMP.
(°C)
10.8-
15.0
11.0-
14.0
11.1
13.7
13.3-
13.5
12°-
14.8
9-13°
8-15°

10-13°
13-16°
9-13°
10-15°
9-15°
pit
(Std)
6.70-
7.12
6.80-
7.00
6.69-
6.94
6.50-
6.90
6.60-
6.90
6.70-
6.90
6.90-
7.25

7.30-
7.50
6.70-
7.10
7.10-
7.70
6.50-
6.70
7.00-
7.40

SPECIFIC
CONDUCT.
(umhos)
at 25°C

4100-
4300
4700-
7500
4700-
7000
6000-
7700
8000-
8500
3800-
3900
2900-
3500

1300-
1400
3990-
5100
1000-
1500
6000-
6500
1000-
1500

COMMENTS

Jow yield
1 casing
volume
Low yield
1 casing
vnl limp.
jow yield
1 casing
volume 	
Dow yield
1 casing
vnl limp
Low yield
1 casing
\/n! nmf»
'..ow yield
1 casing
/olumfi
-.ow yield
I casing
rnl nmp,
Plugged
abandoned or
10/9/86
*Low yield
well 1 cas-
ing. Volume
purge.
*High yield
3 casing
volume pure
*Low yield
well 1 casii
VQlume purctf
*High yield
well 3 cas-
ing. Volum
• puirqe . 	
*ffigfi yield
well 3 cas
ing. Volum

-------
SITE:  Vickery
Table 5 (cont.)




  WELT. ID CHART
DATE:   n/14/86

WELL
ID 1

L30
L31
L32
L33
L34
L35
L39







ACTIVE
OR
CLOSED

A
A
A
A
A
A
A







PURPOSE

CAFO
and
TSCA
CAFO
and TSCA
CAFO
onlv
CAFO
only
CAFO
only
CAFO
only
CAFO
only







GRADIENT

Lateral
Lateral
Lateral
Lateral
Lateral
Lateral
Lateral







DEPTH
OF
WELL
(feet)















ELEVATION
AT TOP
OF CASING
(msl)

610.84
611.32
611.78
612.41
612.59
612.15
613.28







PURGE
VOLUME
(gallons)

1.7-1.9
1.5-2.1
1.0-2.0
1.0-1.5
2.0-3.0
2.5-2.9
0.3-1.0







DEPTH TO
WATER
(feet)

5.0-5.7
5.4-8.4
5.0-7.0
6.0-8.0
5.0-7.0
4.6-4.8
5.0-7.0






NORMAL \
RECHARGE
TIME
(hrs)

^.3 davs
>4fl hours
> 4 days
> 3 days
24
-612
+ 12






ftANGE
TEMP.
(°C)

7.5-
15.0
10-
15°
10-
16°
1.0-
15°
1.2-
15°
10-
14°
9-
17°







PH
(Std)

6.30-
6.90
6.80-
7.10
7.00-
7.50
6.50-
7.10
6.90-
7.30
7.10-
7.40
6.80-
7.90







SPECIFIC
CONDUCT.
(umhos)
at 25°C

8000-
10,000
1400-
1700
1400-
1600
7200-
8300
2000-
2200
1100-
1200
1600-
1800







COMMENTS















-------
SITE:   Vickery
(490
Table 5  (cont.)



WELL ID CHART
DATE:  n/14/86

WELL
ID 1

MW14R
MW15R
MW16R
MW19R
MH2OR
MW21R
MW22R
MW23R
MH23RA
MW24R
MW37R
MW38R


ACTIVE
OR
CLOSED

A
A
A
A
A
A
A
C
A
A
A
A


PURPOSE

CAFO
TSCA
CAFO
TSCA
CAFO
TSCA
CAFO
TSCA
CAFO
TSCA
CAFO
CAFO

CAFO
CAFO
TSCA
Back-
ground
CWM
Research


GRADIENT

Down
Down
Down
Down
Down
Down
Down

Up
Up
Up
Up


DEPTH
OF
WELL
(feet)















ELEVATIOK
AT TOP
OF CASING
(msl)

607.64
607.84
613.76
617.79
614.04
613.10
608.49

612.96
614.04
616.40
617.22


PURGE
VOLUME
(gallons)

21-22
24-25
20-21
22
21-24
23-25
21

16
16-17
24-25 '
26-27


DEPTH TO
WATER
(feet)

14.65-
14.75
14.66-
15.50
21.0-
21.5
24.8-
25.5
21.15-
21.25
19.9-
20.1
15.2-
15.6

25.9 '
20.8-
21.2
10.0-
11.0
11.0-
12.0

NORMAL 1
RECHARGE
TIME
(hrs)

^1
^.1
<£.!

-------
SITE:   Vickery
                               490
 Table 5 (cont.)



WEIL ID CHART
DATE:   n/14/86

WELL
ID 1

T14
T19
T23
T23A

T24
T?7
T37
T38






ACTIVE
OR
CLOSED

A
A
c
'A

A
A
A
A






PURPOSE

CAFO
and
TSCA
CAFO
and
TSCA

CAEO
ana
TSCA
CAFO
only
CAFO
ana
Tcr^a
CAFO
PVC well
CWM
Research






GRADIENT

Lateral
Lateral

Lateral

Lateral
Lateral
Lateral
Lateral






DEPTH
OF
WELL
(feet)
















ELEVATION
AT TOP
OF CASING
(msl)

609.84
618.04

613.05

615.25
614.86
615.22
614.50






PURGE
VOLUME
(gallons)

3.1-3.3
12-13

@ 1 gallon

3.2-4.0
4.0-5.0
3.7-3.9
3.5-3.7






DEPTH TO
WATER
(feet)

7.0-9.9
9.9-11.1

24.9

6.6-6.7
8.0-8.7
3.49-4.00
2.37-2.84





NORMAL 1
RECHARGE
TIME
(hrs)

3 days
8 hours

3 days

2 days
3 days
3 days
3 days





RANGE
TEMP.
(°C)

11-12°
11-13°

11.9
9.9-
12.0
11.7-
13.1
12.2-
12.5
10.0-
12.5






p!I
(Std)

7.29-
7.37
7.29-
7.64

7.13
7.19-
7.24
7.10-
7.80
7.10-
7.22
7.10-
7.22






SPECIFIC
CONDUCT.
(umhos)
at 25°C

1900-
2100
no, 400-
1280

1720
2050-
2100
1200-
9800
2500-
2900
2500-
2900






COMMENTS

Low yield-
well 1 cas-
i no vr>1 limp
Well wizarc
high yield
3 casing
vr>Tnm4
Plugged and
abandoned on
10/9/86
Low yield
well-1 cas-
j ng volume
Replaces T2:
LOW ^lefd
Low yield
well
Low yield
well
Low yield
well





*10,400 was back in April, well is still being developed by sampling.

-------
SITE:   Vickery
490  \
   Table 5



WEIL ID CHART
DATE:  11/14/86

WELL
ID 1
LI 4
LI 5
L16
L19
L20
L21
L22
L23
L23A
L26
L27
L28
L29

ACTIVE
OR
CLOSED
A
A
A
A
A
A
A
C
A
A
A
A
A

PURPOSE
CAFO
and
TSCA
CAFO
and
TSCA
CAFO
and
TSCA
CAFO
ana
TSCA
CAFO
and
TSCA
CAFO
only
CAFO
only

CAFO
and
TSCA
CAFO
and
TSCA
CAFO
T§CA
CAFO
and
TSCA
CAFO
only
GRADIENT
Lateral
Lateral
Lateral
Lateral
Lateral
Lateral
Lateral

Lateral
Lateral
Lateral
Lateral
Lateral
DEPTH
OF
WELL
(feet)













ELEVATION
AT TOP
OF CASING
(msl)
607 92
608.87
612.70
617.87
614.04
612.08
610.73

613.49
612.41
613.70
613.40
609.65
NORMAL RANGE
PURGE
VOLUME
(gallons)
2.2-2.4
2.1-2.5
1.1-2.6
2.1-2.5
1.9-2.2
1.7-2.0,
2.1-2.4

2.0-2.7
6.1-7.2
2.4-3.0
6.0-7,5
4.6-5.4
DEPTH TO
WATER
(feet)
4.29-4.34
3.60-4.90
6.95-7.86
8.62-10.33
5.23-6.45
5.00-7.00
3.30-4.90

4.00-5.00
5.00-7.30
4.55-5.30
4.66-7.59
5.79-7.59
RECHARGE
TIME
(hrs)
48 hours
>3, days
> 3 davs
48 hours
36 hours
24 hours
36 hours

<.3 days
^.12 hours
24 hours
-£16 hours
•<16 hours
TEMP.
CO
10.8-
15.0
11.0-
34.0
11.1
13.7
13.3-
13.5
12°-
14.8
9-13°
8-15°

10-13°
13-16°
9-13°
10-15°
9-15°
pit
(Std)
6.70-
7.12
6.80-
7.00
6.69-
6.94
6.50-
6.90
6.60-
6.90
6.70-
6.90
6.90-
7.25

7.30-
7.50
6.70-
7.10
7.10-
7.70
6.50-
6.70
7.00-
7.40
SPECIFIC
CONDUCT.
(umhos)
at 25°C
4100-
4300
4700-
7500
4700-
7000
6000-
7700
8000-
8500
3800-
3900
2900-
3500

1300-
1400
3990-
5100
1000-
1500
6000-
6500
1000-
1500

COMMENTS
Low yield
1 casing
volume
Low yield
1 casing
VOl ivn**
Low yield
1 casing
Low yield
1 casing
\rol nmo
Low y^eld
1 casing
\rr»1 niyio
r.ow yield
1 casing
i/oliim«
jow yield
I casing
ml lima
Plugged
abandoned or
10/9/86
*Low yield
well 1 cas-
ing. Volunu
purge .
*High yield
3 casing
volume purt
*Low yield
well 1 casii
volume pyrg<
*High yield
well 3 cas-
ing. Volum<
*ffigfi"vield
well 3 cas-
ing , Volumi

-------
SITE;  Vickery
( 490
Table 5 (cont.)




  WELT. ID CHART
DATE:   11/14/86

WELL
ID 1

L30
L31
L32
L33
L34
L3S
L39







ACTIVE
OR
CLOSED

A
A
A
A
A
A
A







PURPOSE

CAFO
and
TSCA
CAFO
and TSCA
CAFO
onlv
CAFO
only
CAFO
only
CAFO
only
CAFO
only







GRADIENT

Lateral
Lateral
Lateral
Lateral
Lateral
Lateral
Lateral







DEPTH
OF
WELL
(feet)















ELEVATION
AT TOP
OF CASING
(msl)

610.84
611.32
611.78
612.41
612.59
612.15
613.28







PURGE
VOLUME
(gallons)

1.7-1.9
1.5-2.1
1.0-2.0
1.0-1.5
2.0-3.0
2.5-2.9
0.3-1.0







DEPTH TO
WATER
(feet)

5.0-5.7
5.4-8.4
5.0-7.0
6.0-8.0
5.0-7.0
4.6-4.8
5.0-7.0






NORMAL 1
RECHARGE
TIME
(hr.)

^-3 davs
>4fl hours
^ 4 days
.> 3 davs
24
-«12
+12






RANGE
TEMP.
<°c>

7.5-
15.0
10-
15°
10-
16°
10-
15°
12-
15°
10-
14°
9-
17°






1
PH
(Std)

6.30-
6.90
6.RO-
7.10
7.00-
7.50
6.50-
7.10
6.90-
7.30
7.10-
7.40
6.80-
7.90







SPECIFIC
CONDUCT .
(umhos)
at 25°C

8000-
10,000
1.400-
1700
1400-
1600
7200-
8300
2000-
2200
1100-
1200
1600-
1800







COMMENTS













._, 	 ,,,, .

-------
SITE:   Vickery
Table  5  (cont.)
WELL ID CHART
DATE:  H/14/86

WELL
ID 1

MW14R
MW15R
HH16R
HW19R
MU2OR
HM21R
MW22R
MW23R
MW23RA
MH24R
MH37R
HN38R


ACTIVE
OR
CLOSED

A
A
A
A
A
A
A
C
A
A
A
A


PURPOSE

CAFO
TSCA
CAFO
TSCA
CAFO
TSCA
CAFO
TSCA
CAFO
TSCA
CAFO
CAFO

CAFO
CAFO
TSCA
Jack-
ground
CWM
Research


GRADIENT

Down
Down
Down
Down
Down
Down
Down

Up
Up
Up
Up


DEPTH
OF
WELL
(feet)















ELEVATION
AT TOP
OF CASING
(msl)

607.64
607.84
613.76
617.79
614.04
613.10
606.49

612.96
614.04
616.40
617.22


PURGE
VOLUME
(gallons)

21-22
24-25
20-21
22
21-24
23-25,
21

16
16-17
24-25
26-27


DEPTH TO
WATER
(feet)

14.65-
14.75
14.G6-
15.50
21.0-
21.5
24.8-
25.5
21.15-
21.25
19.9-
20.1
15.2-
15.6

25.9 '
20.8-
21.2
10.0-
11.0
11.0-
12.0

NORMAL 1
RECHARGE
TIME
(hr.)

^1
<£!
^1

-------
  SITE:   Vickery
t 490
 Table 5
WEIL ID
 (cont.)
CHART
DATE:   11/14/86

WELL
ID 1

T14
T19
T23
T23A

T24
T37
T37
T38






ACTIVE
OR
CLOSED

A
A
C
A

A
A
A
A






PURPOSE

CAFO
and
TSCA
CAFO
and
TSCA

fiM°
TSCA
CAFO
only
CAFO
and
Tcr'fv
CAFO
PVC well
CWM
Research






GRADIENT

Lateral
Lateral

Lateral

Lateral
Lateral
Lateral
Lateral






DEPTH
OF
WELL
(feet)
















ELEVATION
AT TOP
OF CASING
(msl)

609.84
618.04

613.05

615.25
614.86
615.22
614.50






PURGE
VOLUME
(gallons)

3.1-3.3
12-13

@ 1 gallon

3.2-4.0
4.0-5.0
3.7-3.9
3.5-3.7


(



DEPTH TO
WATER
(feet)

7.0-9.9
9.9-11.1

24.9

6.6-6.7
8.0-8.7
3.49-4.00
2.37-2.84





NORMAL
RECHARGE
TIME
(hrs)

3 days
8 hours

3 days

2 days
3 days
3 days
3 days





RANGE
TEMP.
(°C)

11-12"
11-13°

11.9
9.9-
12.0
11.7-
13.1
12.2-
12.5
10.0-
12.5





1
pH
(Std)

7.29-
7.37
7.29-
7.64

7.13
7.19-
7.24
7.10-
7.80
7.10-
7.22
7.10-
7.22






SPECIFIC
CONDUCT.
(umhos )
at 25°C

1900-
2100
no, 400-
1280

1720
2050-
2100
1200-
9800
2500-
2900
2500-
2900






COHMF.N

Low yie^
well 1 <
i r\q vnl I
Well wis
high yif
3 casing
T/OTumA
Plugged a
abandoned
10/9/86
Low yielc
well-1 ca
j ng volurr
Replaces
LOW y^Jd
Low yield
well
Low yield
well
Low yield
well





*10»400 was back in April, well is still  beina

-------
                   Table  6
     Parameter,  Bottle Type, and Preservative List
Sampling
Order
1.
2.
3.
4.

5.
6.
7.
8.


- 9.

10.

11.


12.

13.


14.
15.

16.

17.
Parameter
Volatile organics
Field measurements
Purgeable organic
carbon (POC)
Purgeable organic
halogens (POX)
Extractable organics
Pesticides/herbicides
Dioxi n
Total organic carbon
(TOO

Total organic halogens
(TOX)
Total phenols (4AAP)

Cyanide
•

Sulfide

Nitrate


Anions
Total metals

Dissolved metals

Field measurements
Bottle Type Preservatives
2 -
200
1 -
1 -

4 -
2 -
2 -
1 -


1 L

1 L

1 L


1 L

1 L


1 L
1 L

1 L

200 ml
40 ml VOA vials
ml plastic
40 ml VOA vials
40 ml VOA vials

1 L. amber glass
1 L. amber glass
1 L. amber glass
12H ml glass


. amber glass

. amber glass

. plastic


. plastic

. plastic


. plastic
. plastic

. plastic

plastic
Cool 4°C
None
Cool 4°C
Cool 4°C

Cool 4°C
Cool 4°C
Cool 4°C
H9S04 2 ml
(to pH 
-------
                APPENDIX A



       SUMMARY OF REGULATORY HISTORY


                                         23
(from Comprehensive Monitoring Evaluation  )

-------
                                 SUMMARY OF  REGULATORY  HISTORY
 Date
 Action
 Conments
 12-19-79

 12-26-79

 8-10-80

 M-19-80


 12-2-80

 12-8-80


 1-16-81
 1-22-81
 1-22-81
1-29-81
2-9-81
 Preliminary Assessment (PA)

 Preliminary Assessment (PA)

 Notice of Hazardous Waste Activity

 RCRA Part A Application


 OHIO EPA RCRA Inspection

 Complaint and Findings of Violation


 Response to Complaint and Findings
Answer to Complaint
USEPA Region V RCRA Inspection
                 Consent  Agreement  and  Final  Order
                 Informal  Settlement Conference
 Mo action recommended

 No action recommended

 Submitted

 Submitted most recent revision dated
 10-4-85

 6  violations

 $2500  civil penalty, remediate
 out-of-compliance status

 Response  to the 6 violations listed and
 the civil  penalty assessed in the
 complaint  and findings of violation
 dated  12-18-30

 Court document containing issues
 presented  in the response to complaint
 and findings of violation dated 1-16-81

 Request for Office of Emergency and
 Remedial Response (OERR) to sample and
 analyze "PUG" material  for EP Tox.  All
 violations listed in RCRA inspection
 dated 12-2-80 are remediated

 Issue regarding "PUG" material  removed.
 $2500 civil penalty contested and not
yet resolved.

Conference regarding consent  agreement
and final  order dated 1-29-81.
Discussions regarding $2500  civil
penaltyjustification
2-25-31
                 Court Order
                                                              Order for parties in the consent
                                                              agreement and final  order dated 1-29-81
                                                              to decide NLT 3-10-81 how the $2500
                                                              civil penalty issue will be determined

-------
Date
                 Action
                                                               Comments
3-9-81



4-2-81


9-2-81

10-15-81
                 Court Order
Supplemental Consent Agreement
and Final Order

Ohio EPA RCRA Inspection

Certification by Administrative Law
Judge
 Orders  final  settlement  on  consent
 agreement  and final  order  dated  1-29-81
 to  be extended NLT  3-24-81

 EP/TOX  will be done  on  "PUG"  material.
 Civil penalty reduced to $2000

 No  violations

 Official disposition and disposal of
 complaint  and findings  of violation
 dated 12-18-80
10-27-82         Ohio EPA  RCRA  Inspection

1-10-83          USEPA Region V Letter  of Warning

3-30-83          USEPA Region V RCRA  Inspection
6-30-83          Ohio  EPA  Director's  Final  Findings
                 and Orders
                                              1 violation

                                              Violation of sect 3004 RCRA

                                              Recommends PCB investigation in selected
                                              areas.  Non-compliance regarding subpart
                                              F requirements

                                              Alleges numerous violations of Federal
                                              and state environmental laws and
                                              regulations.  Orders compliance of
                                              violations
6-30-83
5-22-84
7-:i-84
Facility Authorization
Consent Decree between Ohio EPA
and CUM
                N.O.P.E. Inc. Appeal of Permit to
                Install Approval.  Findings of Fact
                and Fir il Order
Authorization from OEPA Director for
continuation of deep-well  injection
activities

Identifies numerous violations and
deficiencies of state environmental
protection codes.  Civil penalty: $5
million.  Compensatory damages:  $2.4
million.  Ohio superfund contribution:
$2 mill ion

Appeal by citizens group,  regarding Ohio
EPA directors approval of  a surface
water management plan.  Director's order
was reaffirmed

-------
Date
                 Action
                                                               Comments
9_ig_84          Ohio EPA Director's  Final  Findings
                 and Order

9-25-84          Ohio EPA Director's  Final  Findings
                 and Orders
9-11-84          Ohio EPA RCRA  Inspection
12-27-84         Ohio  EPA  RCRA  Inspection

4-5-85           USEPA Complaint.   Findings  of
                 Violation and  Compliance  Order

4-5-35           Consent Agreement  and  Final  Order  (CAFO)
                                              4 violations resulting  in  two air
                                              releases of possible" hazardous gases

                                              Recinds 2 orders  issued on 9-19-84.
                                              Assesses a c-vil  penalty of $40,000.
                                              Sets operating hours of the facility

                                             "Not in compliance with  subpart F
                                              requirements.  Being mitigated currently

                                              4 violations found

                                              9 violations alledged.  Civil penalty:
                                              $200.000 requested

                                              Addresses many RCRA violations Orders
                                              facility to come  into compliance except
                                              as noted in CAFO.  Civic penalty:  $2.5
                                              mill ion
5-10-85
RCRA Part B Application
Submitted.  The Part B has undergone
numerous revisions with the most
recently approved version being dated
11-8-85
12-11-85

12-31-85
J-4^86


J-12-86

•-12-86
Ohio EPA RCRA Inspection

Ohio EPA RCRA Inspection
Hazardous Waste Release
Ohio EPA Enforcement Response

USEPA Comprehensive Ground-Water
Monitoring Evaluation
Mo violations

Old ground-water monitoring system is
not in compliance but under
modification.  Documentation under
Subpart F in compliance

Surface water release from retention
area through a partially open gate

Situation evaluated.  5 violations found

-------
             APPENDIX B



Off-Site Laboratory Evaluation Report

-------
                  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                       REGION V

   DATE: October 20, 1987

SUBJECT: On-Site Evaluation of ETC Laboratory for Vickery,
        Ohio Analytical  Activities

   FROM: WaxTne^Long^vChemist
        Quality Assurance Office

     TO: Joseph Fredle
        Eastern District Office	^ .

        THROUGHS-^e^ffrA^ms, Jr.,  Chief
                  Quality Assurance Office


        The results of the on-site laboratory evaluation of  the Environmental  Testing

        and Certification,   Inc.  (ETC)  Laboratory,  Edison,  New Jersey  are  attached.

        The laboratory performs organic and inorganic  chemical analyses  for  the  Chem-

        ical Waste Management,  Vickery,  Ohio site as  part  of  their self-monitoring

        requirements.


        ETC is a modern, well  run  laboratory  with excellent analytical  capabilities.

        The deficiencies in  the laboratory were those observed  at  the time of the

        on-site evaluation.    They  should  be  corrected  as  quickly   as   possible.
EPA FORM 1320-6 (REV. 3-76)

-------
INORGANIC
CHEMISTRY

-------
On July  7,  1987,  Donald Booker,  Chemist,  Quality  Assurance  Office  (QAO),
Environmental Services Division, Region V, conducted an on-site evaluation of
the Environmental  Testing  and Certification,  Incorporated (ETC) laboratory,
Edison, New  Jersey.   The inspection  was  conducted pursuant  to  the National
Hazardous Waste  Groundwater  Task  Force  Facility  Assessment Program Plan.

The purpose  of  the visit  was to  evaluate  the  laboratory's  capabilities to
a-nalyze groundwater  samples  for  inorganic  parameters   (antimony,  arsenic,
cadmium, chromium,  iron, lead,  mercury,  nickel,  selenium,  zinc,  chloride,
cyanide, TOC and TOX).

The evaluator has  observed many  good aspects  of  the  laboratory procedures.
The ETC personnel are well qualified to perform trace analyses  of environmental
samples for  chemical  contaminants  and they maintain the  instruments  in good
operating condition.

The laboratory evaluation team wishes to thank the laboratory staff for their
courtesy and cooperation during the on-site evaluation.

The following are  observations  that  were made during  the evaluation  and the
recommendations of the  Quality  Assurance Office to  ETC  to  improve the data
quality:

1. Observation - The laboratory does not reanalyze the highjjstjrnxed calibra-
tion standard before  beginning  the  sample  run as^ mandatory by  EPA  Method
200.7 (ICP Method).

   Recommendation - Before  beginning the  sample run, the laboratory  should
reanalyze the highest  mixed  calibration  standard as  if  it  were  a  sample.
Concentration values obtained should not deviate  from the actual  values by
more than +_ 5 percent (or the established control limits whichever is lower).

2. Observation - The mid-check  standard is used to determine the instrument
drift.  The acceptance  criteria  of the mid-check standard is not consistent
with EPA Method 200.7.

   Recommendation  -The  mid-check  standard  concentration  values  obtained
should not deviate from the expected values by more than +_ 5% percent (or the
established control limits whichever is lower).

3. Observation - An external  quality control  sample is used  for the  initial
verification of the calibration  standards.   The acceptance criteria of +_ 5%
percent of the true values  listed  for the  control  sample  is  not  observed as
mandatory by EPA Method 200.7.

   Recommendation - The external quality control sample  concentration  values
obtained should  not deviate from  the true values by more than +_ 5% percent.

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

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

-------
On July  8,  1987,  Donald Booker,  Chemist,  Quality  Assurance  Office  (QAO),
Environmental  Services Division, Region V, conducted an on-site evaluation of
Chyun Associates, Princeton,  New Jersey.   The inspection  was  conducted pur-
suant to the  National Hazardous  Waste Groundwater  Task  Force  Facility As-
sessment Program Plan.

The purpose of  the visit  was to  evaluate the  laboratory's  capabilities  to
analyze groundwater  samples  for  inorganic  parameters  (total  phenolics and
sulfates).   Chyun Associates  is a sub-contractor of ETC.

The evaluator has  observed many  good aspects of  the  laboratory procedures.
The Chyun Associates  personnel  are well  qualified to  perform trace analyses
of environmental  samples  for chemical  contaminants  and  they maintain the
instruments in good operating conditions.

The laboratory evaluator wishes to thank the laboratory staff for their  cour-
tesy and cooperation during the on-site evaluation.

The following are observations  that were made during the  evaluation and the
recommendations of the Quality Assurance Office to Chyun Associates to improve
the data quality:

1. Observation - The total phenolics working standard curve is not continually
verified by a check standard.	

   Recommendation - A check standard should be periodically employed to ensure
that correct procedures are being followed and that all equipment is operating
properly.

2". Observation - The acceptance criteria of total  phenolics  for the spike  blank
is not appropriate (_+ 30.816% of the expected value).

   Recommendation - The  spiked  blank  should be within +_  10% of the expected
value.

3. Observation - The sulfate working standard curve  is not continually verified
by a check  standard.

   Recommendation - A check standard should be periodically employed to ensure
that correct procedures are being followed and that all equipment is operating
properly.

4. Observation - The  acceptance criteria of sulfate for the spiked blank is not
appropriate (_+ 50.436% of the expected value).

   Recommendation - The  spiked  blank  should be within +_  10% of the expected
value.

5. Observation  - The  laboratory unsuccessfully  analyzed  total  phenolics and
sulfate on  the  performance  evaluation U.S. EPA Water Pollution  Study Number
WP017.

-------
                                     -2-

   Recommendation -  The  laboratory  should  analyze  the  total  phenolics  and
sulfate performance evaluation samples  sent to  them  by  the  Quality Assurance
Office.  The results should  be  sent back to the Quality Assurance  Office as
soon as possible.

Update 08-11-87 - The laboratory has successfully analyzed the total  phenolics
and sulfate performance evaluation samples sent to them  by  the Quality  Assur-
ance Office.

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

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

-------
ORGANIC     CHEMISTRY

-------
During July, 1987, Babu  Paruchuri,  Chemist, Quality Assurance  Office (QAO),
conducted an on-site evaluation  of  ETC laboratory pursuant to the Harzardous
Waste Ground Water Task Force Program.

ETC had analyzed  the  parameters  listed in Attachment A  during  Phase I moni-
toring activities.  The  laboratory was  analyzing  the  parameters  listed  in
Attachment B (Phase II) at the time of the  audit.   Attachment  C of this report
has the list of parameters that was  proposed  to be analyzed as per the Consent
Agreement between Chemical Waste Management, Incorporated, Vickery, Ohio, and
U.S. EPA.  The  U.S. EPA  audit conducted during July,  1987,  was concentrated
on the laboratory  data quality for the parameters  listed  in  Attachments A &
B.  The overall performance of the  laboratory is acceptable.   Listed below are
the deficiencies observed at ETC at the time of the quality assurance/quality
control audit.   These  deficiencies may have  been subsequently   corrected.

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

Recommendation -  If the  laboratory  can not  extract  (i.e., sample extraction
by liquid-liquid or continuous extraction  technique and  concentration of the
extract to 5.0 ml) pesticides and PCBs  sample within 48  hours of  collection,
the sample should be adjusted to  a  pH  range of 6.0  - 8.0 with sodium^hydroxide
or sulfuric  acid,  if«/c -BHC, y -BHC,  endosuTfan I^ancT II, ancT endrin  are  of
interest.  All samples  must be extracted within 7 days and completely analyzed
within 30 days of sample collection.

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

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

GENERAL COMMENT

Since the second  edition  of SW-846 did not  properly address  the  sample pre-
servation and holding  time requirement  for aromatics in  EPA methods 5030 and
8240, it  is  advised  that the  laboratory  follow  the sample  preservation and
holding time requirements specified in the method 8020.

-------
        VICKERY

      ATTACHMENT A

        Compound

Benzene
bis(chloromethyl) Ether
Bromoform
Carbon tetrachloride
Chlorobenzene
Chiorodibromomethane
Chloroform
Di chlorobromomethane
1,2-Dichloroethane
1,2-Dichloropropane
Ethyl benzene
Methyl chloride
Methyl ethyl ketone
Methylene chloride
1,1,2,2-Tetrachloroethane
Tetrachloroethylene
Toluene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
o&p-Xylenes
Tri chloroethylene

Aniline
o-Cresol
m & p-Cresols
o-Di chlorobenzene
m-Di chl orobenzene
2,4-Dimethyl phenol
Heptachlor
Methoxychlor
Naphthalene
2-Picoline
Methanol
PP/PCBs

-------
                   ATTACHMENT B

(Organic Compounds Analyzed at ETC under Phase  II)

                Benzene
                Chlorobenzene
                Chloroform
                1,2-Dichloroethane
                Ethyl  benzene
                Methyl  ethyl  ketone
                Toluene
                1,1, 1-Tri chloroethane
                Trichloroethylene
                Methanol
                PCBs

-------
         ATTACHMENT C

Proposed Analytical Scheme for
Appendix VII (Compounds)

     Isobutanol
     Chloroacetaldehyde
     Dichloropropanol
     Methanol

     Pyridine
     Tetrachloroethylene
     Methylene chloride
     Trichloroethylene
     1,1,1-Tri chloroethane
     Carbon tetrachloride
     l,l,2-trichloro-l,2,2-trifluoroethane
     Tri chlorof1uoromethane
     Chlorobenzene
     Toluene
     Methyl ethyl  ketone
     Carbon disulfide
     Chloroform
     Methyl chloride
     Acrylonitrile
     1,2-Dichloroethane
     1,1,2-Trichloroethane
     1,1,1,2-Tetrachloroethane
     1,1,2,2-Tetrachloroethane
     Vinyl chloride
     1,1-Di chloroethylene
     Benzene
     1,1,2-Trichloropropane
     1,2,3-Trichloropropane
     1,2,2-Tri chloropropane
     bi s(chloromethyl) ether

     o-dichlorobenzene
     o-cresol
     m & p-cresol

     Nitrobenzene
     Pentachlorophenol
     Phenol
     2-Chlorophenol
     p-chloro-m-cresol
     2,4-Dimethyl  phenol
     2,4,5-Trichlorophenol
     bis(2-chloroethyl) ether
     2,4,6-Trichlorophenol
     4-nitrophenol
     4,6-Dinitro-o-cresol
     2,3,5,6-Tetrachlorophenol

-------
        -2-

2,3,4,6-Tetrachlorophenol
2,3,4,5-Tetrachlorophenol
Chrysene
Naphthalene
Fluoranthene
Benzo(b)fluoranthene
Benzo(a)pyrene
Indeno(l,2,3-cd)pyrene
8enzo(a)anthracene
Dibenz(a)anthracene
Acenapthalene
Benzyl chloride
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
m-Dinitrobenzene
2,4-Dinitrotoluene
2-Picoline
Hexachlorocyclopentadi ene
2,4-Dichlorophenol
2,6-Dichlorophenol
Aniline
Diphenylamine
m-Dichlorobenzene
p-Dichlorobenzene
1,2,4-Trichlorobenzene
1,2,3-Trichlorobenzene
2,4,6-Tri chlorobenzene
1,2,3,4-Tetrachl orobenzene
1,2,3,5-Tetrachlorobenzene
1,2,4,5-Tetrachl orobenzene
1,4-Naphthoquinone
Chlordane
Heptachlor
Toxaphene

Acrylamide
Acetonitrile
2,4-Toluene diamine
(o,m,p)-Phenylenediamines

Cadmi urn
Hexavalent chromium
Nickel
Lead
Arsenic
Mercury
Antimony
Chromium

Cyanide, Total

-------
                   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                        REGION V

   DATE;  1 March 1988

 SUBJECT:  Your Request for PE Results from ETC Corporation
   FROM:  Bob Gnaedinger, Chemist

         QAS/5
     TO:  Maxine Long, Microbiologist
         QAS/5
          ETC Corporation in Edison, NJ, normally participates  in WS studies
          through the State of New Jersey, I am led to  understand.  I have
          received performance evaluation results only  for WS019, WS020 and
          WS021.  In response to your request this morning,  I gave you a copy
          of their WS021 PE results.  I am herewith attaching copies of their
          PE results from WS019 and WS020.  Their  Lab I.D. from EMSL is  NJ136
          end
EPA FORM 13204 (REV 3-76)

-------
                          PERFORMANCE EVALUATION REPORT



                         WATER SUPPLY STUDY NUMBER VS020
DATE: 07/Z7/
LABORATORY NJ136
ANALYTES
SAMPLE REPORTED
NUMBER VALUE
TRACE METALS IN MICPOGRAMS PER
ARSENIC
BARIUM
CADMIUM
CHROMIUM
LEAD
MERCURY
SELENIUM
SILVER
NITRATE/FLUORI
NITRATE AS H
FLUORIDE
1
2
1
2
1
2
1
2
1
2
1
2
1
2
1
2
DE IN
1
2
1
2
109
34.0
77.0
746
17.8
4.85
13.0
74.5
26.1
103
5.14
1.73
9.9
56.3
27.5
15.0
MILLIGRAMS
0.948
6.95
0.177
1.54
TRUE
VALUE*
LITER:
106
32.0
75.0
776
17.0
4.16
12.7
71.1
25.7
99.0
5.25
1.92
9.71
53.9
27.5
13.8
PER LITE
0.900
7.00
0.160
1.60
ACCEPTANCE
LIMITS

86.8-
25.8-
54.7-
664.-
14.3-
3.54-
10.1-
61.1-
20.6-
31. 7-
3.84-
1.32-
6.94-
42.4-
23.1-
11.2-
R:
.762-
6.18-
.148-
1.48-

121.
37.4
88.6
860.
19.6
4.79
15.6
80.9
30.5
113.
6.54
2.47
12.2
65.7
31.9
16.6

1.04
7.82
.215
1.69
PERFORMANCE
EVALUATIONS

ACCEPTABLE
ACCEPTA9LE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
NOT ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE

ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
       BASED UPON THEORETICAL  CALCULATIONS,  OR  A  REFERENCE  VALUE  WHEN  NECESSARY




                                        PAGE    1

-------
                          PERFORMANCE EVALUATION REPORT




                         WATER SUPPLY STUDY NUMBER WS020
DATE: 07/27
LABORATORY NJ136
ANALYTES
INSECTICIDES
ENDRXN
LINDANE
METHOXYCHLOR
TOXAPHENE
HERBICIDES IN
2,4-D
2,4,5-TP (SILVEX)
SAMPLE
NUMBER
REPORTED TRUE
VALUE VALUE*
ACCEPTANCE PERFORMANCE
LIMITS EVALUATIONS
IN MICR06RAMS PER LITER:
1
2
1
2
1
2
3
4
0.388 0
6.77
0.576 ** 0
4.23 **
2.37
84.2
1.90
8.93
MICR06RAKS PER LITER
1
2
1
2
TRIHALOMETHANES IN MIC
CHLOROFORM
BROKOFORM
BROMODICHLOROMETHANE
DIBROMOCHLOROMETHANE
* BASED UPON THE
** SIGNIFICANT 6E
1
2
1
2
1
2
1
2
ORETICAL
NERAL MET
64.9 **
3.36
31.0 **
3.63 **
ROSRANS PER
19.2
S4.4
53.2
19.9
23.6
72.1
73.2
31.2
CALCULATIONS
HOD BT1S TS
.344
6.19
.512
3.84
2.22
80.8
1.42
7.09
*
•
62.7
3.22
30.0
3.71
LITER:
17.7
49.5
42.2
16.9
20.4
63.2
56.9
24.9
» OR A
IMTTf T»
.211-
3.86-
.279-
2.22-
1.34-
52.4-
.432-
3.85^

26.0-
.413-
9.42-
1.23-

14.2-
39.6-
33.8-
13.5-
16.3-
50.6-
45.5-
19.9-
.448
7.84
.651
4.79
3.05
104.
2.23
9.80

83.8
5.66
41.1
5.00

21.2
59.4
50.6 NOT
20.3
24.5
75.8
68.3 NOT
29.9 NOT
REFERENCE VALUE
>ATPB eno TUTC DF
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE

ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE

ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
WHEN NECESSARY

-------
                           PERFORMANCE  EVALUATION REPORT




                         WATER SUPPLY  STUDY NUMBER WS020
DATE: 07/27J
LABORATORY NJ136
SAMPLE REPORTED TRUE
ANALYTES NUMBER VALUE VALUE*
TRIHALOMETHANES
TOTAL TRIHALOMETHANE
VOLATILE ORGANIC
VINYL CHLORIDE
1,1-DICHLOROETHYLENE
1,2-DICHLOROETHANE
1*1*1-TRICHLOROETHANE
CARBON TETRACHLORIOE
TRICHLOROETHYLENE
BENZENE
TETRACHLOROETHYLENE
1,4-DICHLOROBENZENE
CHLOR03ENZENE
IN
1
2
HICR06RANS
169.2
177.6
COMPOUNDS IN
1
1
2
1
2
1
2
1
1
2
1
2
1
4
7.06
3.30
18.3
6.99
11.1
12.6
196
1.52
3.44
10.8
3.76
7.60
7.72
14.6
PER LITER:
137.2
154.5
NICR06RAMS
5.98
2.53
12.7
6.23
8.90
10.5
182.5
1.36
8.22
10.3
4.32
8.16
6.93
14.6
ACCEPTANCE
LIMITS

110.-
124.-

165.
185.
PERFORMANCE
EVALUATIONS
"
NOT ACCEPTABLE
ACCEPTABLE
PER LITER:
3.59-
1.52-
10.2-
3.74-
5.34-
8.40-
146.-
.816-
4.93-
8.24-
2.59-
4.90-
4.16-
11.7-
3.37
3.54
15.2
8.72
12.5
12.6
219.
1.90
11.5
12.4
6.05
11.4
9.70
17.5
ACCEPTABLE
ACCEPTABLE
NOT ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTA9LE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
       BASED UPON THEORETICAL CALCULATIONS, OR A REFERENCE VALUE WHEN NECESSAP1




                                       PAGE   3                         /

-------
                          PERFORMANCE EVALUATION REPORT

                         WATER SUPPLY STUDY NUMBER WS020
LABORATORY NJ136
                                             DATE: 07/27/
ANALYTES
SAMPLE  REPORTED
NUMBER   VALUE
          TRUE   ACCEPTANCE
         VALUE*    LIMITS
               PERFORMANCE
               EVALUATIONS
        VOLATILE ORGANIC COMPOUNDS IN MICROGRAMS PER LITER:

METHYLENE CHLORIDE      2       14.4      12.0   9.60- 14.4
                                            ACCEPTABLE
1,1-DICHLOROETHANE
          11.4
          10.3   8.24- 12.4
                 ACCEPTABLE
1,1-DICHLOROPROPENE
                    31.6   25.3- 37.9   NOT ACCEPTABLE
1s1*2-TRICHLOROETHANE   2
          14.2
          12.8   10.2- 15.4
                 ACCEPTABLE
1s1*1s2TETRACHLOROETHANE2
          15.4
          17.3   13.8- 20.8
                 ACCEPTABLE
2-CHLOROTOLUENE
          3.02
          8.28   4.97- 11.6   NOT ACCEPTABLE
4-CMLOROTOLUENE
          3.C2
                 D.L.- D.L.   NOT ACCEPTABLE
        MISCELLANEOUS ANALYTES:
TURBIDITY
(NTU'S)

PH-UNITS
  1
  2
4.28      4.50
0.51  ** 0.500
          8.56
3.84- 5.08
.341- .779
ACCEPTABLE
ACCEPTABLE
          9.12   8.79- 9.34   NOT ACCEPTABLE
SODIUM                  1
(MILLIGRAMS PER LITER)
         13650
          14.5   13.4- 15.9   NOT ACCEPTABLE
*      BASED UPON THEORETICAL CALCULATIONS, OR A REFERENCE VALUE WHEN NECESSARY
**     SIGNIFICANT GENERAL METHOD BIAS  IS  ANTICIPATED FOR THIS RESULT.
D.L.   STANDS FOR DETECTION LIMIT
                                PAGE   4  (LAST PAGE)

-------
                          PERFORMANCE EVALUATION REPORT




                         WATER SUPPLY STUDY NUMBER WS019
DATE: 12/24/8
LABORATORY NJ136
SAMPLE
'NALYTES NUMBER
ALL VALUES IN
CHLOROFORM
3RONOFORM
3?0«I03ICHLOROMETHANE
OI3R3HOCHL3ROMETHANE
TOTAL TRIHALOMETHANE
REPORTED
VALUE
TRUE ACCEPTANCE PERFORMANCE
VALUE* LIMITS EVALUATIONS
MICROGRAMS PER LITER (EXCEPT AS NOTED)
1
2
1
2
1
2
1
2
1
2
* BASED UPON THEORETICAL
83.2
9.80
22.4
87.7
76.?
17.0
71.6
18.7
254.0
133.2
CALCULAT
81.5
9.06
20.2
84.3
75.1
15.6
64.4
15.0
241.2
124.0
IONS. OR
65.2- 97.8
7.25- 10.9
16.2- 24.2
67.4- 101.
60.1- 90.1
12.5- 18.7
51.5- 77.3
12.0- 13.0 NOT
193.- 289.
99.2- 149.
A REFERENCE VALUE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
WHrN NECESSARY.
                                 PAGE    1  (LAST  »AG£>

-------
                          PERFORMANCE EVALUATION REPORT




                         WATER SUPPLY STUDY NUMBER US021
DATE: 01/07/6
LABORATORY NJ136
SAMPLE REPORTED
ANALYTES NUMBER VALUE
TRACE METALS ZN
CADMIUM
TRZHALOMETHANES
CHLOROFORM
BROMOFORM
BROMODZCHLOROMETHANE
DZBROMOCHLOftOMETHANE
TOTAL TRZHALOMETHANE
VOLATZLE ORGANIC
VZNYL CHLORZDE
1x1-DICHLOROETHYLENE
U2-DICHLOROETHANE
1,1,1-TRZCHLOROETHANE
MZ
1
2
ZN
1
2
1
2
1
2
1
2
1
2
C
1
1
1
1
2
* BASED UPON THEORETZ
** SIGNIFICANT GENERAL
CR06RAMS PER
1.84
13.7
MZCROGRAMS
12.2
58.6
65.3
23.4
11.0
39.1
43.5
17.8
132.0
143.9
OMPOUNOS ZN
4.23
6.92
4.51
5.11
CAL CALCULAT
METHOD BIAS
TRUE
VALUE*
LITER:
** 1.60
14,1
PER LZTER:
14.1
74.2
63.3
27.4
11.1
40.9
44.4
17.8
132.9
160.3
«fZCR06RAMS
1.26
7.27
4.78
4.77
214.5
IONS, OR A
IS ANTZCII
ACCEPTANCE PERFORMANCE
LZMZTS EVALUATZONS

1.21- 2.25
11.8- 16.6

11.3- 16.9
59.4- 89.0 NOT
50.6- 76.0
21.9- 32.9
8.83- 13.3
32.7- 49.1
35.5- 53.3
14.2- 21.4
106.- 159.
128.- 192.
PER LITER:
.768- 1.79 NOT
4.36- 10.2
2.87- 6.69
2.86- 6.68
172.- 257. NOT
REFERENCE VALUE
>ATED FOP THIS RE

ACCEPTABLE
ACCEPTABLE

ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE

ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
WHEN NECESSARY
SULT.
                                       PACE

-------
                          PERFORMANCE EVALUATION REPORT

                         WATER SUPPLY STUDY NUM3ER VS021
 MORATORY NJ136
                                             DATE:  01/07/88
 NALYTES
SAMPLE  REPORTED
NUMBER   VALUE
          TRUE   ACCEPTANCE
         VALUE*    LIMITS
                      PERFORMANCE
                      EVALUATIONS
        VOLATILE ORGANIC COMPOUNDS IN MICROGRAMS PER LITER:

 ARBON TETRACHLORIDE    1       6.36      7.31   4.39- 10.2
                                            ACCEPTABLE
 RICHLOROETHYLENE
  NZENE
 ,4-DICHLOR03£NZENE
  1
  1
  2

  1
  2
3.43


2.26


4.84
3.57   2.14- 5.00
2.37   1.42- 3.32
11.9   9.52- 14.3

4.68   2.31- 6.55
12.6   10.1- 15.1
    ACCEPTABLE
    ACCEPTABLE
NOT ACCEPTABLE

    ACCEPTABLE
NOT ACCEPTABLE
                                          8.10   4.86- 11.3   NOT ACCEPTABLE
ITHfLBENZENE
                    9.32   5.59- 13.0   NOT ACCEPTABLE
"•)TAL XYLENES
                    6.36   4.12- 9.60   NOT ACCEPTABLE
5TYRENE
                    11.4   9.12- 13.7   NOT ACCEPTABLE
 •PROPYLBEMZENE
                    8.35   5.01- 11.7   NOT ACCEPTABLE
N-BUTYLBENZENE
                    10.5   8.40- 12.6   NOT ACCEPTABLE
        MISCELLANEOUS ANALYTES:

PH-UNITS                1        9.1  **  9.14   5.81- 9.33
                                            ACCEPTABLE
       BASED UPON THEORETICAL CALCULATIONS/ OR A REFERENCE VALUE WHEN NECESSARY,
       SIGNIFICANT GENERAL METHOD BIAS IS ANTICIPATED FOR THIS RESULT.
                                       PAGE

-------
                          PERFORMANCE EVALUATION REPORT            DATE: 01/07/88


                         WATER SUPPLY STUDY NUMBER WS021


.ABORATORY  NJ136
» ^ • • ••«•) <•» • • ^P ^»«» *P «•> •* Vk^B ^m fM>^BMB ^ • ^•»«» •»4B»^»«»^* ^B ^^ «*^^^ ^«»^»^» MB ^^^ ^ ^ ^•^•^•^•^B ^•^•4B> ^» ^P ^»^»^»^»^» OT ^B ^B^B^^B^ ^»•»«•) •••k^B ^ ^ «• •• ••>

                      SAMPLE  REPORTED    TRUE   ACCEPTANCE     PERFORMANCE
kNALYTES               NUMBER   VALUE     VALUE*    LIMITS       EVALUATIONS



       MISCELLANEOUS ANALYTES:


 ODIUM                   1       15.S      15.7   14.3- 17.5        ACCEPTABLE
MILLIGRAMS PER LITER)


-      BASED UPON THEORETICAL CALCULATIONS' OR A REFERENCE VALUE WHEN NECESSARY.


                                PAGE   3 (LAST PAGE)

-------
          APPENDIX C



Task Force Sampling Information

-------
CHEMICAL WASTE MANAGEMENT, INC.
     VICKERY, OHIO FACILITY
TASK FORCE SAMPLING INFORMATION
Well Number
L15
L19
L20
L21
L26
L27
Depth
of Well
(feet)
17.50
19.43
15.60
15.40
19.91
20.00
Depth
To Water
(feet)
3.25
9.50
4.66
dry
15.79
3.8
Purge Vol .
Calculated
(gallons)
7.10
4.80
5.50

7.30
8.10
Purge
Volume
Actual
(gal)
2.40
2.33
2.00
0.20
3.00
2.80
Purging
Date
1987 Time(EST)
4/6 . 1250-1302
4/6 . 1225-1235
4/6 1340-1345
4/7 1521-1523
4/6 1310-1320
4/6 1204-1212
Sampling
Date
1987 Time(EST)
4/7 1000-1012
4/8 1030-1033
4/8 1411-1415
4/9 aOlO-1015
•11615-1620
4/6 1435-1450
4/7 1056-1106
4/7 1428-1431
4/8 1203-1212
4/8 1516-1530
4/6 1449-1453
4/7 1030-1040
4/7 1350-1356
4/8 1000-1011
4/8 1532-1536
4/9 1037-1043
4/9 1628-1632
4/10 1034-1039
4/13 1353-1356
4/7 0948-1007
4/7 1349-1405
4/7 1546-1552
4/6 1433-1440
4/7 0937-0948
4/7 1444-1446
4/8 1058-1105
4/8 1546-1547
Remarks
Field blank site.
MQB 304

Sample water turned
dark during sampling
for cyanide analysis,
no odors detected.

Duplicate site.


-------
                                                               Page 2 of 3
CHEMICAL WASTE MANAGEMENT, INC.
     VICKERY, OHIO FACILITY

TASK FORCE SAMPLING INFORMATION
          (continued)



Well Number
L29
L31





L34



L35



L39


T19




Depth
of Well
(feet)
19.43
17.45





22.50



19.91



6.68


37.50




Depth
To Water
(feet)
5.92
5.40





10.63



5.42



3.75


12.13




Purge Vol .
Calculated
(gallons)
6.80
5.90





5.84



7.20



1.46


12.45



Purge
Volume
Actual
(gal)
2.90
2.75





2.00



3.00



1.00


5.00




Purging
Date
1987 Time(fST)
4/7 1235-1245
4/6 1150-1205





4/7 1255-1309



4/7 1327-1335



4/6 . 1137-1145


4/6 1245-1255




Sampling
Date
1987 Time(EST)
4/7 1455-1514
4/6 1350-1530
4/7 1124-1132
4/8 0958-1007
4/8 1410-1423
4/9 1031-1035
4/10 1016-1027
4/8 1034-1058
4/8 1434-1442
4/9 1047-1102
4/10 0939-1004
4/8 1125-1142
4/8 1457-1508
4/9 1014-1022
4/10 1046-1052
4/6 1359-1411
4/6 1513-1528
4/7 1119-1127
4/6 1510-1519
4/7 1023-1030
4/7 1417-1421
4/7 1615-1619



Remarks







Duplicate site.



Field blank site.
MBQ 311


Background well .







-------
                                                               Page 3 of 3
CHEMICAL WASTE MANAGEMENT, INC.
     VICKERY, OHIO FACILITY

TASK FORCE SAMPLING INFORMATION
          (continued)
Well Number
T24
MW14R
MW16R
MW21R
MW23RA
P10
Leachate Pond
SE Leachate
Meyers Ditch
Depth
of Well
(feet)
24.96
62.45
67.50
69.67
57.52
87.20


	
Depth
To Water
(feet)
20.66
13.50
19.00
18.93
18.80
12.81
„

— _
Purge Vol .
Calculated
(gallons)
2.15
24.4
24.0
25.4
19.0
36.6
._

__
Purge
Volume
Actual
(gal).
0.60
25.0
25.0
25.0
19.5
37.0
_.
„
__
Purging
Date
1987 Time(EST)
4/6 1541-1547
4/8 1227-1310
4/8 1431-1507
4/8 1305-1335
• 4/7 1215-1244
4/14 0930-1150
_ • w —
_.
— — --
Sampling
Date
1987 Time(EST)
4/7 1146-1200
4/7 1457
4/8 1128-1131
4/8 1600
4/9 1131-1133
4/9 1641-1645
4/10 1101-1105
4/13 1333-1339
4/14 1237-1245
4/15 0909-0920
4/8 1314-1328
4/8 1508-1518
4/8 1340-1358
4/7 1247-1300
4/7 1408-1600
4/14 1153-1227
4/14 1400-1430
4/14 1535-1600
.4/13 1413-1424
Remarks
Background well .



Initial purge water
blackish with sulfide
odor. Background well.
Water had milky color
after purging 5 gal .
Water had sulfide odor.




-------
          APPENDIX 0
Task Force Sampling Parameters

-------
Held
Specific conductance

Teaperittre

Turbidity


 Other Parameters,

TOC                METHOD     9060
TOX                METHOD     9020
Chloride           METHOO     9252
Tocal phenols      METHOO     9066
Sulface            METHOO     9036 or 9038
Nitrate            METHOO     9200
Anaemia            "Methods for Conical Analysis of Water and VI	
                   USEPA - E«L (Cincinnati, 3/83. Method 350.1 or 350.3
POX                EPA 60n/4-3*-008
pnc                Ground Vater, vol. 22, p. 18-23.
Dissolved metals   Tocal metals, and
Cyanide

-------
Appendix VI I I

METHOO   6010

Aluminum
Barium
a«ryllium
Boron
Cadmium
Chromium
Iron
Lead
 Thallium
 Vanadium
 Sine
 Selenium*
 Arsenic*
 •These elements are not approved  for 6010 but they are  approved foi
  CLP metals 1CP method.  The CLf  metals  1CP method is identical to
  the SU-846/6010.
 Method 7470

 Kercury

-------
                                                                                                        SittU
Utrattr* IIMI
la* Sattlt II fc
««tlt Mtriit
lata Itltast
Artktrixtd ly
                 CkOfUOSAil
                 Utvid
       CAS
      •utotr
     74-87-J
              ChlorMtthant
     75-01-4
     75-0*-:
     75-09-2
     47-44-1
     75-1S-J
     75-35-*
     75-I4-:
     1S4-W-!
     47-4A-;
     107-04-2
              Vinyl Chlaridt
              Ckiorotthwt
              Rtthyltnt Chlondt
              Aetto^t
              Carton Oisulfidt
              •.,1-luHorMthtr.*
              l,l-9jchlorott!ust
              trans- 1 ,2-9ichloro«th«!t
              Chloroforo
              l,2-)ichiorotthant
              2-fcitancnt
              1,1,1-Truhlorotthttt
              Carbon Tttrartflondt
              Vinyl Acttatt
              8rotod:chlorootthar.t
              1,2-lichloroeropant
      71-55-4
      54-23-5
     108-05-4
      75-27-4
      71-17-5
for rttorting rtsolts to EM, tkt
                             tncauriqtd.
trfMln AMlysis Ma Skttt
          ffaft II                   Caw        ttUSASl
                                   Kltftrtltt	
                                   Contract to   4M1-72U
                                   Mt Sasylt
        folitilt Ctttoods          ItctifHi     14-IH*
Concntratitni           In
Mt ntracttd/prtitrtdi  04-17-14
Mt analyitdt           04-17-04
Conc/lil Facttn         1.00       pfli I/I
'trcnt toistirt  (not dtcanttd): I/ft
                          CAS
              •f/1
             10.
             10.
             10.
             10.
              5.0
             10.
              5.0
              5.)
              2.0
              3.0
              S.O
              5.0
             10.
              5.0
              5.0
             10.
              5.0
              5.0
        Mia KPttTIK UAUFIOS
    rtsvlts toalifitrs art ostd.  Additional  flags  or footnotts nptaining
   Moitvtr, tht dt^inition of tart flag tost  kt  tiplicit.

1
1
V
tt
0
1
0
0
'J
w
u
»
9
0
U
0
0
ftitktr
10041-02-4
W-01-4
124-48-1
71-00-5
71-43-2
10041-01-5
110-75-1
75-25-2
108-10-1
5*1-71-4
127-18-4
71-34-5
108-86-3
106-10-7
100-41-4
100-42-5


trus-l,3-lickltrapropnt
Trichlorttthtnt
li br otockl or ottthaat
1,1,2-TnchlorotUiwi
Itiutnt
ci s- 1 , 3-li chl or otr optnt
2-Oilorottbyl Viayl Ether
Ironofort
4-Hothyl-2-9ntanont
2-titianont
Tttracklorotthtst
1 , 1 , 2 , Mttr acbl or ot Uiaitt
Tolunt
Chlorobnitnt
Ethyl Itnztnt
Styrtnt
Total lylnts
5.0
5.
5.
5.
5.
5.
10.
5.9
10.
10.
5.0
5,0
5.0
5.0
5.0
5.0
5.-J
0
V
U
u
u
u
u
M
u
u
I!
II
I!
I'
•j
U
c
                                                                                                             rtsclts art
 laiut  14 tit rtsvlt is a valit o/Httr tkan or tqaal U tkt
        tftttctioi litit tkM rtpvt tkt valit.

    f   Micatts coopound MS analyitd for k«t not dtttcttd.
        itiort tkt usisttt tettctiM litit ftr  tkt satplt oitk
        tkt I (t.|.  IflU) basts' m Mcnsary coKMtratioW
        dilotioo actions.  (Tkis is tot atcHsarily tkt iMtrunt
        dtttction lioit.)  Tte footnctt skovld rtadi  «-€Mpo«n<
        MS analrztd for but tot dtttcttd.  Tkt notbtr is tkt
        oinitus ittaiMblt dtttction liait for  tkt sanplt.

    1   ladicatts an tstioattd faint.  Tkis flaf is ntd titktr
        rtn tstiMtinf a conctntration for ttntatiTtly idtntifitd
        cotpoonds ihtrt a 1:1 rtsponst is assuitd r ihtn tkt tass
        satctral data iadicattd tkt prtsact of a cataoond tkat
        otfts tht  idtntification crittria tot tkt rtsalt is Itss
        tkaa tht sptcifitd dtttction lioit M  trtattr tkan ztra
                                                                  Otktr
                                   (t.|.  1W).  If litit  tf dtttctitn is  Itet. and a
                                   ctnctntratitn tf 3oo, is calnlattd, tktn rttart as w.

                                   Tkis flaf  asflits U ptsticidt paraotttrs «bert tkt
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                                                       Foral
                                                                                                            10/15

-------
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-------
                                                    I  Sample Number  |
                                                    I    00399        |
       Organics  Analysis Data Sheet
                 (Page 3)
                          •e«ticide/PCB«
       Concentration:   (Low]
       Date  Extracted/Prepared
       Data  Analyzed:  	
       Cone/Oil  Factor--  	
                                     Hediue,   (Circle One)
                                        06/14/86
                                            1 .00
       CAS
       Number
                                              Cug/1 J or  ug/Kg
                                                    (Circle One)
319-84-6
319-85-7
319-86-f
58-89-9.
76-44-8
309-00-3
1034-57-3
959-98-3
60-S7-1
72-55-9
73-20-8
33213-65-9
72-54-8
1031-07-8
50-29-3
72-43-5
53494-70-5
57-74-9
8001-35-2
12674-11-2
11104-28-2
1 1 141-16-5
53469-21-9
12672-29-6
11097-69-1
11096-82-5
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Beta - BHC
Delta - BHC
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Aldrin
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Endrin
Endosulfan II
4-4' - ODD
Endosulfan Sulfate
4-4' - DDT
Methoxychlor
Endrin Ketone
Chlordane
Toxaphene
Aroclor - 1016
Aroclor - 1221
Aroclor - 1£32
Aroclor - 1242
Aroclor - 1248
Aroclor - 1254
Aroclor - 1260
.05 U
.05 U
. 05 U
05 U
.05 U
. 05 U
05 U
. 05 U
. 10 U
. 10 U
. 10 U
. 10 U
.10 U
. 10 U
. 10 U
.50 U
.10 U
50 U
1.0 U
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.50 U
1.0 U
1 .0 U
•) _
             Vli)
             V(i.)
             U(«)
             V(t )

1000. 00_ or U(«)
Voluae  of extract injected (ul)
Voluae  of water extracted (•!)
Weight  of sanple extracted (g)
Volume  of total extract (ul)

_  V(t) _10000.00_    V(
_ S.0_
                      For* 1

-------
    APPENDIX E
   QA/QC SUMMARY
TASK FORCE SAMPLING

-------
MEMORANDUM

DATE:    September 14, 1987

SUBJECT: Evaluation of Quality Control Attendant to the Analysis of Samples
          from the Chemical Waste Management, Vickery, Ohio Facility

FROM:    Ken Partymiller, Chemist
          PRC Environmental Management, Inc.

TO:       HWGWTF:  Richard Steimle, HWGWTF*
          Paul H. Friedman, Chemist*
          Gareth Pearson, EMSL/Las Vegas*
          Joe Fredle, Region V
          Maxine Long, Region V
          Don Haggard, Region VIII
     This memo summarizes the evaluation of the quality control data generated by
the Hazardous Waste Ground-Water Task Force (HWGWTF) contract analytical
laboratories (1).  This evaluation and subsequent conclusions pertain to the data
from the Chemical Waste Management, Vickery, Ohio sampling effort by the
Hazardous Waste Ground-Water Task Force.

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

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

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

Preface

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

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I.    Site Overview

     The Chemical Waste Management/Vickery facility is located in Vickery, Ohio.
The facility is primarily an injection well facility. The facility also operated
lagoons which are being closed.  Solidified sludges from these lagoons will be placed
in an on-site landfill.  Until construction of this landfill is completed, these sludges
are being stored in a large waste pile.  Most of the samples collected for this study
were collected from monitoring  wells associated with the lagoons. Two leachate
samples and a surface  water sample were collected from the waste pile.

     The facility has,  in the past, accepted large quantities of waste oils. The
facility operated an oil recycling facility which is now closed.  The injection wells
are used mainly for waste acids.

     The geology at the facility consists of 75 to 100 feet of clay on top of sand.
The injection wells are 2500 to 3000  feet deep and inject into a strata containing
unusable salt water which is just above bedrock.

     Twenty-six field  samples were collected at this facility. The samples included
two field blanks (MQB304 and 311),  a  trip blank (MQB301), and two sets of
duplicate samples (MQB307/MQB319 and MQB314/MQB316).  All samples were
designated as low concentration  ground-water samples except for samples MQB306
and 326 which were designated as medium concentration leachate samples, MQB310
which  was designated as a  medium concentration ground-water sample,  and MQB313
which  was designated as a low concentration surface water sample. All samples
were analyzed for all HWGWTF Phase 3 analytes with the following exception.
Sample MQB325 was not analyzed for chloroherbicides.

II.   Evaluation  of Quality Control Data and Analytical Data

1.0   Metals

1.1   Metals OC Evaluation

     Total and dissolved spike recoveries were calculated  for twenty-four metals
which  were spiked  into two of three low concentration samples (MQB312, 319, and
321) and into one of two medium concentration samples (MQB306 and 326).

     Twenty-two of the low concentration total metal  average spike recoveries from
these samples were within the data quality objectives (DQOs) for this Program. The
average matrix spike recoveries for total cadmium (137 percent) and selenium (51
percent) were outside the DQO.  Eight low concentration individual total metal
spike recoveries  were outside DQO and will  be discussed in the following Sections.
The total  metal spike recoveries  for aluminum and iron from sample MQB319 were
not calculated because the amounts of  these  metals in this sample were greater than
four times the amount  of the spike.  This information  is listed in Tables 3-la and
3-2a of Reference 2 as well as in the following Sections.

     Twenty-two of the low concentration dissolved  metal average spike recoveries
were within the DQOs  for this Program.  The average matrix spike recoveries for
dissolved iron (128  percent) and  magnesium (73 percent) were outside DQO. Four
individual dissolved metal spike  recoveries were outside DQO and will be discussed
in the following  Sections. This information is listed  in Tables 3-lc and 3-2c of
Reference 2 as well as  in the following Sections.

-------
     Seventeen of the medium concentration total metal spike recoveries from the
spiked sample were within the DQOs for this Program.  The matrix spike recoveries
for total cadmium (62 percent), selenium (20 percent), silver (72 percent), thallium
(74 percent), and tin (64 percent) were  below the  DQO.  The total metal spike
recoveries for arsenic and magnesium were not calculated because the amounts of
these metals in the spiked sample were greater than four times the amount of the
spike.  This information is listed  in Tables 3-1 b and 3-2b of Reference 2 as well as
in the following Sections.

     Thirteen of the medium  concentration dissolved metal spike recoveries were
within the  DQOs for this  Program.  The matrix spike recoveries for dissolved
antimony (37 percent), cadmium (68 percent), copper (53 percent), lead (no
recovery), mercury (60 percent), silver  (62 percent), thallium (no recovery), and tin
(34 percent) were outside DQO.  The dissolved metal spike recoveries for calcium,
potassium,  and sodium were not calculated because the amounts of these metals in
the spiked  sample were  greater than four times the amount of the spike.  This
information is listed in  Tables 3-ld and 3-2d of Reference 2 as well as in the
following Sections.

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

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

     No contamination  involving the metallic analytes was reported in the laboratory
blanks. Sampling blank contamination was reported and will be discussed in the
following Sections.

1.2  Furnace Metals

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

     The matrix spike  recoveries for total arsenic (72 percent) and selenium (50
percent) for the low concentration matrix spiked sample MQB312 were below their
DQOs.  The matrix spike recoveries for total arsenic (127 percent), cadmium (178
percent), lead (152 percent), and selenium (51 percent) for the  low concentration
matrix spiked  sample MQB319 were outside their  DQOs. The matrix spike recoveries
for total cadmium (62 percent), selenium  (20 percent), and thallium (74 percent) for
the medium concentration matrix spiked sample MQB326 were below their DQOs.
The matrix spike recoveries for dissolved antimony (37 percent), cadmium (68
percent), lead (no recovery), and thallium (no recovery) for the medium
concentration matrix spiked sample (MQB306) were below  their DQOs.  No obvious
trends were observed in these  matrix spike results. All low concentration matrix
results for total arsenic, cadmium, lead, and selenium should be considered semi-
quantitative.  Medium concentration matrix results for total and dissolved cadmium
and total thallium should also be  considered semi-quantitative.  Dissolved antimony
results for the medium concentration samples should be considered qualitative.  Due

-------
to the low spike recoveries, all medium concentration matrix results for total
selenium and dissolved lead and thallium should not be used. All of these usability
judgments may be further qualified.

     Several continuing calibration verifications (CCVs) for total and dissolved
arsenic and  dissolved cadmium were outside DQO limits.  The data for the CCV,
which should have been run after recalibration, was missing.  Total  arsenic results
for samples  MQB314 and 316, dissolved arsenic results for samples MQB301,  306, 310,
313, and 318, and dissolved cadmium results for samples MQB309, 314,  316, 317, and
320 were affected and  should be considered semi-quantitative unless otherwise
qualified.

     The correlation coefficients for the method of standard addition (MSA)
determination of total antimony in sample MQB326D (D .= duplicate analysis),
dissolved antimony in sample MQB306D, total arsenic in sample MQB306, total
cadmium in the laboratory control sample #3, dissolved cadmium in sample MQB306,
and  total lead in samples MQB305 and 320 were below DQO.  The results for these
analytes  in the indicated matrices and samples, except for total arsenic in sample
MQB306 and dissolved  antimony in sample MQB306D, should be considered
qualitative.  The results for total arsenic in sample MQB306 and dissolved antimony
in sample MQB306D should  not be used.

     The analytical spike recoveries of dissolved antimony in sample MQB306 and
dissolved selenium in samples MQB306D and  326 ranged from 0 to 37 percent. These
results should not be used.

     The double burn precision for total selenium in sample MQB318 and for
dissolved selenium in samples MQB306D and  310 was above DQO. Results for these
analytes  in these samples should be considered unusable.

     The duplicate RPD for total selenium in sample MQB326 was above DQO.  Total
selenium result for this sample, unless otherwise qualified,  should be considered
semi-quantitative.

     Dissolved lead contamination was found in field blanks MQB304 (16 ug/L)  and
MQB311  (6.8 ug/L). The lead CRDL is 5 ug/L. As a result of this contamination
dissolved lead results for samples MQB305, 312, 319, 320,  322, 323, 324, and 325 (all
positive lead results) should not be used.  Other lead results (negative results) were
not affected.

     The usability of all graphite furnace analytes is summarized in Sections 5.0  and
5.1 at the end  of this Report.

1.3  ICP Metals

     The matrix spike  recovery for dissolved tin (67 percent) in low concentration
matrix sample MQB312 was below the DQO.  The matrix spike recoveries for
dissolved chromium (147 percent), iron (159 percent), and tin (57 percent) in low
concentration matrix sample MQB319 were outside of their  DQOs. The matrix spike
recoveries for  total silver (72 percent) and tin (64 percent) in medium concentration
matrix sample MQB326 were outside of their  DQOs. The matrix  spike recoveries for
dissolved copper (53 percent), silver (62 percent), and tin (34 percent) in medium
concentration matrix sample MQB306 were below their DQOs. The trend of low
spike recoveries indicate a low bias in the data and  high spike recoveries indicate a
high bias in the data.  Results for these analytes in  the above specified matrices
should be considered semi-quantitative unless further qualified except for all

-------
dissolved tin results in the medium concentration matrix which should be considered
qualitative.

     The low level (twice CRDL) linear range checks for all total beryllium, silver,
vanadium, and  zinc samples as well as for total cobalt and copper samples MQB301,
302, 306, 310, 313, 318, 321,  325, and 326 exhibited low recoveries. The low level
linear range check for total  manganese in samples MQB303, 304, 305,  307, 308, 309,
311, 312, 314, 315, 316, 317,  319, 320, 322, 323, and 324 exhibited high recoveries.
The low level linear range checks for all dissolved beryllium, cobalt, chromium,
silver, vanadium, and zinc samples, as well as for dissolved copper samples MQB301,
302, 306, 310, 313, 318, 321,  325, and 326, exhibited low recoveries. The  low level
linear range checks for dissolved manganese samples MQB301, 302, 306, 310, 313,
318, 321, 325, and 326 exhibited high recoveries.  The data user should refer to
Comment B5 of Reference 3 for a detailed listing of analysis dates, samples
affected, and biases.  The low level linear range check is an  analysis of a solution
with elemental  concentrations near the detection limit.  The range check analysis
shows the accuracy which can be expected by the method for results near the
detection limits.  The accuracy  reported for these metals at low concentrations is
not unexpected. The recoveries  indicate the possible directions and extent of the
biases in the low  concentration samples.

     Dissolved aluminum contamination was reported in field blank MQB311 at a
concentration of  259  ug/L.  The aluminum CRDL is 200 ug/L.  As a result of this
contamination, all positive dissolved aluminum results (all are in the concentration
range of the blank) should not be used.  Total sodium contamination was reported
in trip blank MQB301 at a concentration of 160,000 ug/L.  The sodium CRDL is 5000
ug/L.  As a result of  this contamination, all positive total sodium results, with the
exception of samples  MQB301, 304, 306, 309, 310, 311, 317, and 323, should not  be
used.  Total sodium results for samples MQB301, 304, 306, 310, and 311 should be
considered quantitative while results for samples MQB309, 317, and 323 should be
considered qualitative unless otherwise qualified.  Dissolved  sodium contamination
was reported in trip blank MQB301  and field blank MQB304 at concentrations of
162,000 and 173,000 ug/L, respectively.  As a result of this contamination, all
positive dissolved sodium results, with the exception of  samples MQB301, 304, 305,
306, 309, 310, 311, 317, and  323, should not be used.  Total sodium results for
samples MQB301, 304, 306, 310, and 311 should be considered quantitative while
results for samples MQB305, 309, 317, and 323 should be considered qualitative
unless otherwise qualified.

     The serial dilution RPD results for total aluminum and dissolved calcium,
manganese, and sodium in low concentration matrix sample MQB319 were outside
DQO.  The serial dilution RPD results for total potassium and dissolved calcium,
potassium, and sodium in medium concentration matrix  sample MQB306 were also
outside DQO. All results  for these analytes should be considered semi-quantitative
unless otherwise qualified.

     A continuing calibration verification (CCB) was missing from the raw data.
CCBs should be run at a  frequency of every 10 samples  and also at the end  of the
analytical batch.

     Although  high sulfate  concentrations were found in many of the samples,  the
barium matrix  spike recoveries  were  all  acceptable and thus possible sulfate
interference with the barium determination was not expected to  be significant.

-------
     The laboratory duplicate RPD for total aluminum  in sample MQB319 was above
DQO. The total aluminum result for this sample should be considered semi-
quantitative unless otherwise qualified.

     Duplicate field sample precision for total aluminum and dissolved nickel and
sodium in duplicate sample pair MQB314/316 was poor.  The comparative precision of
field duplicate results is not used in the preparation of  the usability evaluation of
sample results.  It is  not possible to determine the source of this imprecision.  The
poor precision may  be reflective of sample to sample variation rather than actual
analytical variations.

     The usability of all total and dissolved ICP metal analytes is summarized in
Sections 5.2 and 5.3 at the end of this Report.

1.4  Mercury

     The matrix spike recovery for dissolved mercury (60 percent) from medium
concentration matrix sample MQB326 was below DQO.  All medium concentration
matrix results for dissolved mercury (MQB306, 310, and 326) should be considered
semi-quantitative.  All other mercury results should be considered quantitative.

2.0  Inorganic and Indicator Analvtes

2.1  Inorganic and Indicator Analvte OC Evaluation

     The average spike recoveries of all of the inorganic and indicator analytes,
with the exceptions of those of sulfate and cyanide from the medium concentration
samples, were within the accuracy DQOs. The  matrix spike recoveries of sulfate (70
percent) and cyanide (13 percent) from the medium concentration matrix spikes were
below DQO.  Accuracy DQOs have not been established for the bromide, fluoride,'
nitrite nitrogen, and sulfide matrix spikes.

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

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

     No laboratory blank contamination was reported for any inorganic or indicator
analyte.  Sulfate, sulfide, POC and TOX contamination  were each found in one of
the field blanks (sample MQB304 or 311). This contamination will be discussed
below.

2.2  Inorganic and Indicator Analvte Data

     All results for bromide, fluoride, total phenols, TOC, and POX should be
considered quantitative with an acceptable probability of false negatives.

     The matrix spike recovery of cyanide (13  percent) from medium concentration
matrix sample MQB306  was below DQO. The trend of low spike recoveries indicate
a low bias  in the data.  Medium concentration cyanide results should not be used
due to the  poor matrix spike recovery.  Low concentration matrix cyanide results
should be considered quantitative.

-------
     The matrix spike recovery of chloride (120 percent) from low concentration
matrix sample MQB319 was above DQO. The trend of high spike recoveries indicate
a high bias in the data. The concentration of chloride reported by the analytical
laboratory for sample MQB301 was incorrect.  According to the raw data no chloride
was detected in this sample. All low concentration matrix  results for chloride
should be considered semi-quantitative. All medium concentration matrix results
should be considered quantitative.

     The holding times for  the nitrate and nitrite nitrogen determinations ranged
from 9 to 38 days from receipt of the samples which is longer than the
recommended 48 hour holding time for unpreserved samples. All nitrate and nitrite
nitrogen results should be considered semi-quantitative.

     The matrix spike recoveries of sulfate from low concentration matrix sample
MQB312 (140 percent) and from the medium  concentration matrix sample MQB306 (70
percent) were outside DQO. All sulfate results should  be considered  semi-
quantitative unless otherwise qualified. Sulfate contamination was present in field
blank MQB304 at a concentration of 1,880,000 ug/L.  The sulfate CRDL is 1000
ug/L.  As a  result of this contamination, all positive  sulfate results, except those
for samples  MQB301, 304, and 311, should not be used. Sulfate results for samples
MQB301, 304, and 311  should be considered semi-quantitative.

     Sulfide contamination  was present in field blank MQB311  at a concentration of
217,000 ug/L. The sulfide CRDL is 1000 ug/L.  As a result of this contamination,
all positive sulfide results, except those for samples MQB301, 304, 305, 306, 311,.
312, 315, 318, and 323, should  not be used. Sulfide results  for samples MQB301,
304, 305, 311, 312,  315, 318, and  323 should be considered quantitative and results
for sample MQB306 should be considered qualitative.

     Calibration verification standards for POC were not analyzed.  A POC spike
solution was run during the analytical batch  but the  "true" value of the spike was
not provided by the laboratory.  EPA needs to supply the inorganic laboratory with
a POC calibration verification solution.  Until then,  the instrument calibration can
not be assessed.  POC contamination was present in field blank MQB311 at a
concentration of 220 ug/L.  The POC CRDL  is 100 ug/L.  As a result of this
contamination, all  positive POC results, except those  for samples MQB301, 304, 306,
309, 310, and 311, should not be used.  POC results for samples MQB301, 304, 306,
309, 310, and 311 should be  considered qualitative. The POC holding time ranged
from 4 to 13 days. Although the EMSL/Las Vegas data reviewers recommend a 7
day holding time, the EPA Sample Management Office (SMO) has instructed the lab
that a  14 day holding time is acceptable.

     TOX contamination was  present in field blank  MQB304 at a concentration of
9.4 ug/L. The TOX CRDL is 5 ug/L.  As a result of  this contamination, TOX
results, with exceptions, should be considered quantitative unless otherwise qualified.
TOX results for sample MQB318 should be considered qualitative and results for
samples MQB305, 307, 312, 313, 315, 319, 320, 322, and  324  should not be used.  Due
to high chloride concentrations, constructive  interference with the TOX
determination was  possible for samples MQB303, 317, 318, and 323. TOX results for
these samples should be considered semi-quantitative, unless otherwise qualified, and
biased high.  In summary, TOX results, with  exceptions, should be considered
quantitative. TOX results for samples MQB303, 317,  and 323 should  be considered
semi-quantitative.  The TOX result for sample MQB318 should be considered
qualitative.  The TOX  result for sample MQB305, 307,  312, 313, 315, 319, 320, 322,
and 324 should not be used.

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3.0   Oreanics and Pesticides

3.1   Organic OC Evaluation

     All matrix spike average recoveries, with the exceptions of 2-chlorophenol and
Parathion, were within established Program DQOs for accuracy. Matrix spike
average recoveries for 2-chlorophenol (26 percent) and Parathion (123 percent) were
outside DQO.  Individual matrix spike recoveries which were outside DQO limits will
be discussed in the appropriate Sections below.

     All average surrogate spike recoveries, with the exceptions of 2-fluorobiphenyl
in the  sampling blanks and 2-fluorophenol  in the matrix spike/matrix spike duplicate
samples were within DQOs for accuracy. Individual surrogate  spike recoveries which
were outside the accuracy DQO will be discussed in the appropriate Sections below.

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

     All average surrogate spike RPDs were within DQOs for precision.  Surrogate
standard were neither required nor used for the organo-phosphorous herbicide
analysis.

     Requested organic  analyses were performed, with one exception, on all samples
submitted to the laboratory.  Sample MQB325  was not analyzed for chloroherbicides.

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

     Detection limits for the organic fractions are summarized in the appropriate
Sections below.

3.2  Volatiles

     The analytical  laboratory exceeded the volatile holding time of seven days for
all samples except MQB309, 314, 315, 317, and 324 by 1 to 70 days. Volatile results
for these samples should not be used because they exceeded the holding time.
Volatile results for all other samples should be considered quantitative.

     Acetone contamination was found in  laboratory (method) blanks MB-1 through
MB-4, MB-7, and MB-8 at concentrations ranging from 1 to 7 ug/L. Acetone
contamination was also  found  in the trip blank at a concentration of 6 ug/L. The
acetone CRDL is 10 ug/L. Laboratory contamination is the probable source of this
result.  All positive acetone results (samples MQB301, 303, 306, 313, 314, 316, 317,
320, 321, 324, and 326),  with the exception  of sample MQB306  which had a high
concentration of acetone, were judged to be unusable due to this blank
contamination.

     Laboratory (method) blanks MB-1 through MB-4 and MB-8 contained methylene
chloride contamination at concentrations ranging from  1  to 5 ug/L.  The methylene
chloride CRDL is 5  ug/L. Laboratory contamination is the probable source of this
result.  All positive methylene chloride results (samples MQB306, 308, 310, 313, 315,
317, 318, 320, 324, and 326) should not be used due to this blank contamination.

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     Laboratory (method) blank MB-7 contained 2 ug/L of 2-butanone.  The 2-
butanone CRDL is 10 ug/L.  As a result of this contamination, all positive 2-
butanone results (sample MQB313) should not be used.

     The matrix spike/matrix spike duplicate RPDs for trichloroethene,
chlorobenzene, and benzene in sample MQB309 were above DQO.  This lack  of
precision was judged not  to affect data quality.

     In their standards, the analytical laboratory confused the cis- and trans-1,3-
dichloropropene isomers and the 4-methyl-2-pentanone and 2-hexanone isomers.  As
no dichloropropene isomers were found in the samples, the data quality for those
isomers was not affected.  2-Hexanone and 4-methyl-2-pentanone were each reported
in two volatile  samples and their identifications were reversed. The data user
should be aware of this reversal.

     Erratic percent differences between the average response factors for the initial
calibration and the daily calibration check standards were observed for various
Appendix IX compounds.

     Estimated method detection limits were CRDL for all samples, except MQB306
which  was  100  times the CRDL. Dilution of this sample was required due to the
high concentrations of  acetone, isobutyl alcohol, and several other volatiles.  The
volatile results, with exceptions listed below, should be considered  unreliable due to
excessive holding times. Volatile results for samples MQB309, 314, 315, 317,  and 324
should be considered quantitative with the exceptions of any acetone or methylene
chloride results. No positive acetone, methylene chloride, or 2-butanone results
should be used  due to laboratory (method) blank contamination.  The probabilities of
false negative and positive results are acceptable (with the exceptions of the
positive acetone and methylene chloride  results, if any) for samples MQB309, 314,
315, 317, and 324 which had acceptable holding times.

3.3  Semivolatiles

     The semivolatile holding time between sample receipt and analysis was
exceeded by 22 to 36 days for all samples.

     The matrix spike  (MS) and/or matrix spike duplicate (MSD) recoveries  for
pentachlorophcnol in samples MQB306MS (111 percent), MQB314MS (4 percent),
MQB314MSD (6 percent), MQB316MS (6 percent), and MQB316MSD (6 percent) were
outside DQO.  The matrix spike and matrix spike duplicate recoveries for phenol in
samples MQB306MS (168 percent), MQB306MSD (105 percent), MQB314MS (6 percent),
MQB314MSD (10 percent), MQB316MS (8  percent), and MQB316MSD  (6 percent) were
outside DQO.  The matrix spike recovery for 4-chloro-3-methylphenol in sample
MQB306MS (99 percent) was above  DQO.  The matrix spike and matrix spike
duplicate recoveries for 2-chlorophenol in samples MQB314MS (3 percent),
MQB314MSD (4 percent), MQB316MS (3 percent), and MQB316MSD (3 percent) were
below  DQO.  The matrix  spike and matrix spike duplicate recoveries for 4-
nitrophenol in samples  MQB314MS  (3 percent), MQB314MSD (3 percent), MQB316MS
(3 percent), and MQB316MSD (3 percent)  were below DQO. The low recoveries in
certain of the samples may be due to a systematic interference in those samples.

     The surrogate spike recoveries of 2-fluorophenol from samples MQB303, 303RE
(reanalysis), 314, 314MS, 314MSD, 316, 316MS, 316MSD, 317, 317RE, 323, and 323RE,
were below DQO. The  surrogate spike recoveries of phenol-d5 from samples
MQB314, 314MS, 316MS, 316MSD, 317, 317RE, 323,  and 323RE, were below DQO.
The surrogate spike recovery of 2-fluorobiphenyl from samples MQB302, 304, 305,

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308, 311. 312, 315, 319, 320, 322, 325, MB-1, and MB-5 were below DQO.  The
surrogate spike recoveries of 2,4,6-tribromophenol from samples MQB314, 314MS,
314MSD, 316, 316MS, 316MSD, 317, 317RE, 323, and 323RE, were below DQO.
Although, all other surrogate recoveries were within DQO, the acid surrogate
recoveries for samples MQB314, 316,  317, and 323 were generally low and thus the
acid fraction results for these samples are expected to  be biased low.

     Semivolatile laboratory (method) blanks, MB-1 through MB-6 contained
contamination including several unknown compounds at estimated concentrations
ranging from 10 to 200 ug/L as well  as bis(2-ethylhexyl)phthalate at concentrations
of 5 ug/L in MB-3 (method blank MB-3 was analyzed as a  medium concentration
sample, thus the sample was diluted by a factor of 100 and the resulting
concentration was reported as 500 ug/L) and 6 ug/L in MB-6 and unknown
alkylamides at estimated  concentrations of 10 and 20 ug/L. The trip  blank and one
field blank also contained bis(2-ethylhexyl)phthalate at concentrations of 5 and 3
ug/L.  The CRDL for bis(2-ethylhexyl)phthalate is 10 ug/L.  No positive bis(2-
ethylhexyl)phthalate results should be used due to this contamination. Positive
sample results for semivolatile unknowns whose standards  are found at approximate
scan numbers 320, 353, 492, 1427, 1437 (an unknown alkylamide), 1508, 1518 (an
unknown alkylamide),  1542, 1552, 1620/1621,  1725, 1758, and  1772, as well as
unspecified 2-methylcyclopentanol isomers, should also not be used due to laboratory
blank contamination.

     Standards for all Appendix IX semivolatile compounds have not been obtained
by the analytical laboratory.  All results for these compounds, which  were analyzed
by using extracted ion current profiles for major ion quantitation, should be
considered qualitative. The laboratory must obtain standards for these compounds.

     All semivolatile samples, with the exceptions of leachate samples MQB306 and
326 which were diluted by factors of 2000 and  100, had dilution factors of two. As
a result, the estimated detection limits for the semivolatiles, with the exceptions of
samples MQB306 and 326, were approximately twice the CRDL. The  estimated
detection limits for samples MQB306 and 326 are approximately 2000 and 100 times
the CRDL.

     The semivolatile data are acceptable and the results should be considered semi-
quantitative with the exceptions of the results for the  semivolatile compounds for
which  there were no analytical standard and the compounds which had blank
contamination.  The results for the Appendix IX compounds mentioned above  should
be considered qualitative. All positive bis(2-ethylhexyl)phthalate results, as well as
all results for unknowns at the scan numbers listed above,  should not be  used due
to blank contamination. Probabilities of false negatives and positives are acceptable
with the exceptions of false negatives for the  two diluted samples and the
possibility of false negative and positive results for the compounds for which  there
were no analytical standards.

3.4    Pesticides

     No laboratory (method) blank contamination was  detected for the pesticides.
Chromatographic  contamination was present in both samples and blanks in the
region  of the BHCs and aldrin.  A unidentified  Chromatographic peak was present  at
a retention time of approximately 3.65 minutes in all samples and blanks run on the
OV-101 column.

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     The retention times for the pesticide standards for endrin, endrin aldehyde,
endrin ketone, aldrin, heptachlor epoxide, DDT, methoxychlor, beta-BHC, and delta-
BHC fell outside the  laboratory's established retention time window.

     The presence of an early eluting chromatographic peak may have obscured the
detection of BHCs and Aroclors. False negative results for these pesticides are a
possibility.

     The estimated method detection limits for all pesticides analyses, with the
exceptions of samples MQB306,  310, 314, 316, and  326, are the CRDLs.  Samples
MQB306 (diluted by a factor of 10), 310 (10), 314 (5), 316 (5), and 326 (2) were
diluted prior to  analysis and therefore have elevated detection limits. The
pesticides results should  be considered qualitative with the exceptions of results for
endrin, endrin aldehyde, endrin ketone, aldrin, heptachlor epoxide, DDT,
methoxychlor, BHCs,  and the Aroclors.  False negative results are possible for these
pesticides as the retention  times for their standards were outside of the analytical
laboratory's established retention time window and because of  the presence of an
early eluting chromatographic peak.  Results for these pesticides should  not be used.

3.5  Herbicides

     The herbicides for  which the  laboratory analyzed include only 2,4-D, 2,4,5-T,
2,4,5-TP, chlorobenzilate, phorate, disulfoton, parathion, and famphur.  Sample
MQB325 was not analyzed  for chloroherbicides due to an insufficient volume of
sample.

     2,4-DB was used as a  surrogate for the chloroherbicide fraction.  No
surrogates were included for the organo-phosphorous herbicides.

     Numerous artifact peaks or interferences were  observed in the chloroherbicide
method blank and sample chromatograms. These  peaks are at concentrations near
the CRDL for most of the  target analytes. Samples MQB303, 306, 314, 315, 316,
317, 318, and 326 contained peaks at concentrations above target analyte CRDLs.
False negatives are a  possibility for these samples.

     Due to large background interferences, the chloroherbicide matrix spike
compounds could not  be  quantitated in sample MQB306MS/MSD.

     Unidentified peaks were also  present in the  organo-phosphorous herbicide
chromatogram for sample MQB306.   One of these  peaks was just outside the phorate
retention time window.  Confirmation analysis was not performed. False negative
results have an enhanced probability for this sample.

     The chloroherbicide fraction for samples MQB306 and 326 were diluted by
factors of 1000 and 100.  The organo-phosphorous  herbicide fraction for samples
MQB306 and 326 were each diluted by a factor of 100.  False negative results have
an enhanced probability  for these samples.

     The estimated method detection limits were the CRDL for the organo-
phosphorous herbicides with the exceptions of the  diluted samples. The organo-
phosphorous herbicide results should be considered qualitative due to the lack of a
surrogate.  Although surrogates are  routinely used  in organic analyses, results of
the organo-phosphorous herbicides are less confident since no surrogates  were  used
here.  The results for  chloroherbicides should not  be  used.

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4.0   Dioxins and Furans

4.1   Dioxin and Furan OC Evaluation

     The recoveries of the dioxin native spikes from two blank samples and a field
sample (spiked and analyzed in duplicate) ranged from 88 to 112 percent which is
within the DQO range.

     Samples MQB302, 307, and 320 were analyzed in duplicate.  No target analytes
were detected in samples MQB302 and 320. Sample MQB307 was spiked prior to its
duplicate analysis. No dioxins or furans were detected in the duplicate field
samples and thus method precision could not  be evaluated.

     Dioxin and furan determinations were performed on all samples which were
submitted to  the laboratory.  No dioxins or furans were detected in the field
samples.

     Dioxin and furan contamination was neither detected in the laboratory
(method) blanks nor the field blanks.

4.2   Dioxin and Furan Data

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

     The resolution (percent valley) between  the internal standard (carbon-13
labeled 2,3,7,8-TCDD) and the recovery standard (carbon-13 labeled  1,2,3,4-TCDD)
was above DQO for three initial calibration analyses, two continuing calibration
analyses, three blanks, and samples MQB301,  302D (duplicate),  304, 306, 309, 310,
313, 314, 318, 322, 325, and 326.

     Many of the ion current profiles exhibited  poor peak shape.  This may  be  the
result of lack of sample carbon clean-up  and  results in poor signal to noise rations
and raised detection limits.

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

III.  Data Usability Summary

5.0  Graphite Furnace Metals. Total (See Section  1.2)

Quantitative:        all low concentration antimony and thallium results; low
                    concentration cadmium and  lead results with exceptions;
                    all medium concentration antimony and lead results; medium
                    concentration arsenic results with exceptions Semi-quantitative:
                    low concentration arsenic and selenium results with
                    exceptions; all medium concentration cadmium  and thallium
                    results; cadmium results for  samples MQB303 and  318;
                    lead results for samples  MQB302,  307, 314, 315, 316, 318,
                    319, 321, and 322 Qualitative: medium concentration selenium
                    results with exceptions; arsenic results for samples MQB309 and
                    319 Unusable: arsenic results for samples MQB306 and 323; the

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                    cadmium result for sample MQB325; the lead result for sample
                    MQB303; selenium results for samples MQB310 and 318.
5.1 Graphite Furnace Metals. Dissolved (See Section 1.2)
Quantitative:



Semi-quantitative:

Qualitative:

Unusable:
                    all low concentration antimony, arsenic, selenium, and
                    thallium results; low concentration cadmium and lead
                    results with exceptions; all medium concentration results
                    for arsenic; selenium results for sample MQB306
                    medium concentration cadmium results with exceptions;
                    cadmium results for samples MQB309, 314, 316, 317, and 320
                    medium concentration antimony results with exceptions; the
                    cadmium result for sample MQB306
                    all medium concentration  lead and thallium results; medium
                    concentration selenium results with exceptions; lead results for
                    samples MQB305, 308, 312, 316, 319, 320, 322, 323, 324, and
                    325; the antimony result for sample MQB306; the selenium
                    result for sample MQB310.
5.2 ICP Metals. Total (See Section 1.3)
Quantitative:
Semi-quantitative:

Qualitative:
Unusable:
                    all barium, beryllium, calcium, chromium, cobalt, copper,
                    iron, magnesium, manganese, nickel, vanadium, and zinc
                    results; all low concentration potassium, silver, and tin
                    results; all medium concentration aluminum results; medium
                    concentration sodium results with an exception
                    all low concentration aluminum  results; all medium
                    concentration potassium, silver, and  tin results
                    sodium results for samples MQB309, 317, and 323
                    low concentration sodium results with  exceptions;  the
                    sodium result for sample MQB326
5.3  ICP Metals. Dissolved (See Section 1.3)
Quantitative:
                    all barium, beryllium, chromium, cobalt, nickel, vanadium,
                    and zinc results; all low concentration copper, potassium,
                    and silver results; all medium concentration iron,
                    magnesium, and manganese results; iron results for samples
                    MQB302, 304, 307, 309, 319, 320, 322, and 324; aluminum
                    results for samples MQB302, 304, and 320
                    all low concentration calcium, magnesium, manganese, and
                    tin result;; low  concentration iron results  with exceptions; all
                    medium concentration calcium, copper, potassium, and silver
                    results; medium concentration sodium results with an exception
                    all medium concentration tin results; sodium  results for
                    samples MQB305, 309, 317, and  323 Unusable: all aluminum
                    results; low concentration sodium results with exceptions; iron
                    results for samples MQB303, 311, and 321; sodium results for
                    sample MQB326

5.4  Mercury (See Section 1.4)

Quantitative:        all total mercury results; dissolved mercury results with
                    exceptions
Semi-quantitative:   dissolved mercury results for samples MQB306, 310, and 326
Semi-quantitative:
Qualitative:

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5.5  Inorganic and Indicator Analvtes (See Section 2.2)

Quantitative:        all bromide, fluoride, total phenols, TOC, and POX results;
                    all low concentration  matrix cyanide results; all medium
                    concentration matrix chloride results; sulfide results for
                    samples MQB301, 304, 305, 311, 312, 315, 318, and 323; TOX
                    results with exceptions
Semi-quantitative:   all nitrate and nitrite nitrogen results; all low
                    concentration chloride results; TOX results for samples
                    MQB303, 317, and 323
Qualitative:         all POC results; the sulfide result for sample MQB306
Unusable:           all medium concentration cyanide results; sulfate and
                    sulfide results with exceptions; TOX results for samples
                    MQB305, 307, 312, 313, 315, 319, 320, 322, and 324

5.6  Oreanics (See Sections  3.2 through 3.5)

Quantitative:        volatile results for samples MQB309, 314, 315, 317, and
                    324 with the exception of positive acetone and methylene
                    results which should not be used Semi-quantitative: semivolatile
                    results with exceptions Qualitative: results for Appendix IX
                    semivolatile compounds for which there  were no analytical
                    standards; pesticide results with exceptions;  organo-phosphorous
                    herbicide results
Unusable:           volatile results with exceptions; all positive  acetone,
                    methylene chloride, and 2-butanone (all are  volatiles)
                    results; all bis(2-ethylhexyl)phthalate  (a semivolatile)
                    results; all positive 2-methylcyclopentanol isomer results;  all
                    positive semivolatile results for alkylamides found at
                    scan numbers 1437 and  1518; all positive semivolatile unknown
                    compound results at scans 320, 353, 492,  1427,  1508, 1542,
                     1552,  1620/1621, 1725, 1758, and  1772; pesticide results for
                    endrin, endrin aldehyde, endrin ketone, aldrin, heptachlor
                    epoxide, DDT, methoxychlor, beta-BHC,  delta-BHC,  and the
                    Aroclors; all chloro-herbicide results

5.7    Dioxins and Furans (See Section 4.2)

Semi-quantitative:   all dioxin and furan results

IV.   References

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

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

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

2.    Draft Quality Control Data Evaluation Report (Assessment of the Usability of
     the Data Generated) for Case M-2363HQ, Site 57, Chemical Waste Management,
     Vickery, OH, Prepared by Lockheed Engineering and Management Services
     Company,  Inc., for the US EPA Hazardous Waste Ground-Water Task Force,
     8/5/1987.

3.    Draft Inorganic Data Usability Audit  Report, for Case M-2363HQ, Chemical
     Waste Management, Vickery, OH, Prepared by Laboratory Performance
     Monitoring Group, Lockheed Engineering and Management Services Co., Las
     Vegas, Nevada, for US EPA, EMSL/Las Vegas, 8/5/1987.

4.    Draft Organic Data Usability Audit Report, for Case M-2363HQ, Chemical Waste
     Management, Vickery, OH, Prepared by Laboratory Performance Monitoring
     Group, Lockheed Engineering and Management Services Co., Las Vegas, Nevada,
     for US EPA, EMSL/Las Vegas, 8/5/1987.

5.    Draft Dioxin/Furan Usability Audit Report, for Case M-2363HQ, Chemical Waste
     Management, Vickery, OH, Prepared by Laboratory Performance Monitoring
     Group, Lockheed Engineering and Management Services Co., Las Vegas, Nevada,
     for US EPA, EMSL/Las Vegas, 8/5/1987.

V.  Addressees

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

John Haggard
US Environmental Protection Agency
One Denver Place
Denver, CO 80202-2413

Joe Fredle
US Environmental Protection Agency
25089 Center Ridge Road
Westlake, OH  44145

Maxine Long
US Environmental Protection Agency
230 South  Dearborn Street
Chicago, IL 60604

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Paul Friedman
Room 413-W
Science Policy Branch (PM-220)
US Environmental Protection Agency
401  M Street S.W.
Washington, DC 20460

Sujith Kumar
Laboratory Performance Monitoring Group
Lockheed Engineering and Management Services Company
1051 East Flamingo Drive, Suite 257
Las Vegas, Nevada  89119

Ken  Partymiller
PRC EMI/Houston
10716 Whisper Willow Place
The Woodlands, TX  77380

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    APPENDIX F
ANALITICAL RESULTS
TASK FORCE SAMPLES

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               SUMMARY OF CONCENTRATIONS FOR COMPOUNDS FOUND
                       IN GROUND-WATER AND SAMPLING
                     BLANK SAMPLES AT CWM,  VICKORY,  OH
The following table lists 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.
                                   A2-1
                                                                                  •r-jr-

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                                 TABLE  KEY
     A value without a flag indicates a result above the contract
     required detection limit (CRDL).

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 ng and a
     concentration of 3 pg is calculated, then report as 3J.

B    This flag is used when the analyte is found in the blank as well as
     a sample.  It indicates possible/probable blank contamination and
     warns the data user to take appropriate action.
GW = ground-water
SW = surface-water
low and medium are indicators of concentration.
Results for the samples reanalyzed and/or reextracted are preceeded by a
/ (slash).

All concentrations are in pg/L.
                                   A2-2

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  APPENDIX G



TCLP SAMPLING

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                  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                        REGION V

   DATE:  September 16, 1987

SUBJECT:  Land Ban Rule Inspection - Chemical Waste Management Inc.,
         Vickery, Ohio (C28361)

   FROM:  Philip E. Gehring  /fa
         THRU:  A. R. Winklhofer;c*icf,6fc>

     T0:  Craig Li ska, 5HE

         In response to a Priority  I request from Craig Liska, SHE, a  Land Ban Rule
         (LBR) Inspection was performed at the subject  facility on April 14, 1987.
         The purpose  of  the inspection was to  determine  possible limitations to
         land disposal of materials now stored at Chemical Waste Management Inc.,
         Vickery, Ohio  (CWM-V).  These limitations  would  be imposed pending LBR
         regulations  anticipated  to  become  effective in   1988.   The LBR  also
         specifies a  new test procedure,  "Toxicity  Characteristic Leaching Pro-
         cedure"  (TCLP).   Special  sample  collection  procedures  specified  in the
         TCLP were employed  for this inspection.

         CWM-V is anticipating the land disposal of  contaminated  pond sludges from
         previous on-site  operations.   These pond sludges  are  being stored in a
         large plastic  covered mound  pending completion of  the  intended disposal
         cell and  Ohio  EPA and I).  S.  EPA approvals for disposal.   Closure plans
         must also  be similarly approved.  At  the  time of this inspection there
         was  considerable  storm damage to the  plastic cover of the waste mound,
         exposing the stored wastes.   The facility was  actively working toward
         recovering  the  mound.

         Earthen  dikes  around the  mound  catch  run  off from the plastic covering
         and  leachate from under the covering.   These  liquids flow into a  pond to
         the  east  of the  covered  waste  mound.   The   facility periodically pumps
         these waters to  another  larger  pond  for  settling prior  to  deep well
         injection.   The entire area  around the waste mound and adjacent  pond is
         posted  as  a hazardous waste area.

         Mr.  Craig  Liska of the Region V  Waste  Management  Division,  also a member
         of the  Hazardous  Waste  Ground  Water  Task   Force  (HWGWTF)  requested a
         modified TCLP  analysis of the liquids leaching from the  waste mound  and
         those  1n  the   pond  adjacent  to  the  waste  mound.   This  request   was
         assigned a Priority I for sampling only with a completion  date of April
          15,  1987.    Analysis  of  the   samples  for  TCLP  limited  parameters   was
          requested.   Additional  prarmeters  were also requested  including  TOC.

          Samples were collected as requested on April  14,  1987.   The sampling  and
          inspection team consisted of Mr. Craig Liska, SHE, Mr.  Philip E. Gehring,
          5SEDO,  Mr. David Petrovski, 5SPT, and Mr. Mark Lewis, Alliance Technology
          Corp.   (EPA-HWGWTF Contractor).   Mr. James Doyle, CWM-V was the facility
          observer.   Sample  sites  were selected  by Mr.  Liska  and  Mr.  Petrovski
 EPA FOUM 1330-6 (REV. 3-T«)

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                                 - 2 -

after a complete  inspection of the  waste mound area.   Three  sites
were selected  including  one   from  the  pond  and  two  from  active
leachate sites at the base of the waste mound.  The attached diagram
indicates the approximate location of the sample sites.  Photographs
were taken to further document the nature  of the  sample sites.  The
photographs were  taken  by  Mr. Dave  Petrovski.   Special  procedure
requirements for  TCLP  sampling,  transportation,  and  preservation
were followed.  The  sampling  methods used are  referenced  in "Char-
acterization of Hazardous Waste Sites, A Methods Manual, Volume II -
Available Sampling  Methods."   Specific  TCLP sampling  and analysis
requirements for volatile organic compounds are referenced 1n
Appendix I to  40  CFR Part  268 TCLP.   The sampling  requirements  in
this document were met  by collecting liquid^ samples into a "Tedlar"
bag.  This was accomplished by filling a  clean  clear glass jar with
sample liquid  and  transferring  the sample  liquid to  the "Tedlar"
bag.  After  filling the  bag  was  exhausted  of  all  air  and sealed.
The sampling  method  was  used  at all  three sample  sites  using  a
dedicated glass jar for each  site.   TOC  samples were collected into
a plastic 250 ML container.

A duplicate  sample was collected at the  pond site.   Sample numbers
were 87EG11S01 and  87EG11D02.  This first  leachate site southeast of
the waste mound was  sampled from  an existing  pond  of leachate^  This
sample was  designated as  87E611S03.  The  leachate site west of the
waste mound  was  sampled from a ponded area which  was constructed to
catch a  seepage  flow about  3.5  hours prior  to   sample collection.
This sample  was designated  as  87E611S04.   A  blank  sample was made up.
using HPLC  water  which was  poured  directly from the commercially
supplied bottle  into the  "Tedlar"  bag.- This  sample  was  made  up
immediately  outside the posted area around  the waste mound, at the
southwest entrance   gate  used to entrance and exit  the area.  The
blank  sample was desinated as 87EG11R05.   Standard samples for the
HWGWTF were  also collected at the  SOI  site, MQB  sample number 326,
and at the  S03 site, MQB sample  number  306.  Completed  samples were
passed over  the  fence  to  EPA or Alliance  personnel  for  transport
back to  the onslte trailer.   Samples  for TCLP analysis  were iced and
driven to  the EDO.   Samples  were then packaged for hazardous waste
 requirements and  shipped  to  the   contract  laboratory,   Cambridge
Analytical  Associates  of  Boston, Massachusetts on  April  20,  1987.
Data was received at CRL on  June 1,  1987  and  finally  arrived  at EDO
on  August  24, 1987.

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                                  - 3 -

Results of the  requested  TCLP  analyses are  presented  on table  I.   Data
for the blank sample were all  less than detectable except  for  methylene
chloride.  Samples SOI and  D02 were diluted tenfold before  analysis  and
samples SOS and  S04 were diluted 50  times.   The  blank  sample was  not
diluted.  Values  reported  for  chlorobenzene appear  to excedw  limits  of
the LBR  as  listed  in  Appendix  II  to 40 CFR  Part 268.   TOC  data  was
received at EDO on September 8, 1987.  Results  are presented on  Table II.
Dilution factors  used  for TOC  analysis were 5X  for sample  Nos. D02 and
S04, 10X  for  SOI, and 20X  for SOS.   Copies  of  raw TOC data sheets  are
enclosed.

Questions regarding  the  field  activities   related  to  this  inspection
should be addressed to Philip E. Gehring at FTS 942-7260.

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1106 Commonwealth Avenue / Boston, Massachusetts 02215 / (617) 232-2207

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                                   TABLE I
                     Chemical  Waste Management-VIckery
                             Volatile Organic*
                               April  14, 1987
 Lab.  Sample No.
 EDO Sample No.  87EG11  -
E2508
 SOI
E2509
 D02
E2510
 S03
E2511
 S04
  Requested Parameters

 Methylene Chloride ug/L
 Carbon Disulfide
 2-Butanone
 1,1,1- Trichloroethane
 Carbon TetrachloMde
 Trlchlorothene
 1,1,2 - Trichloroethane
 Benzene
 Tetrachloroethene
 To!uene
 Chlorobenzene
 Tri chlorof1uoromethane
 1,1,2 - Trichloro - 1,2,2
   Trifluoroethane
1—Hltropropane
 Isobutanol
 1,2 - d1chlorobenzene

 Non requested Parameters

 Acetone
 4- Methyl-2-pentanone
 Chloroform
20JB
SOU
100U
SOU
SOU
SOU
SOU
sou
sou
sou
sou
100U
100U
100U
250J
100U
20JB
SOU
100U
sou
sou
sou
sou
sou
sou
sou
sou
100U
100U
100U
190J
100U
200JB
250U
500U
250U
250U
250U
250U
250U
250U
2000
670
500U
500U
500U
15,000
310J
2400JB
250U
500U
250U
250U
250U
250U
250U
250U
100J
630
500U
500U
SOOU
11,000
SOOU
                  17,000
                   1,200
                  7,000
                    940
                    80J
 B- found in blank (80ug/L);  U- Undetected at level  specified; J- Estimated
 Concentration below detection limits.

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                                TABLE II
                    Chemical  Waste Management-Vlckery
                                   TOC
                             April 14, 1987

Lab. Sample No.               E2708    E2709    E2710    E2711
EDO Sample No. 87EG11 -        SOI      002      S03      S04      R05
  Requested Parameters
TOC ug/ml                      833      820      8460     3800     2.0u

        u - undetected at level specified

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