November 1988
                    EPA-330/2-89-006
 Hazardous Waste  Ground-Water
 Task Force
 Evaluation of
 IT  Corporation
 Vine  Hill  and Baker  Facilities
 Martinez,   California
&EPA
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
             CALIFORNIA DEPARTMENT OF HEALTH SERVICES
             CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
                        U.S. Environmental Protection Agency
                        Region 5, Library (PI -12J)
                        77 West Jackson Boulevard, 12th Floor
                        Chicago, IL 60604-3590

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            *        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
 t> \5S2£/                     WASHINGTON. D.C. 20460
 ^   '"'•"•-^                        November 21, 1988
 eH
 •p-       UPDATE OF THE HAZARDOUS WASTE GROUND-WATER TASK FORCE
;H         EVALUATION OF THE IT CORPORATION, VINE HILL AND FACILITIES
-^                            MARTINEZ, CALIFORNIA

             The Hazardous Waste Ground-Water  Task Force  (Task Force) of the
       United States Environmental  Protection Agency (EPA), in conjunction with the
       California Department of  Health Services (DHS)  and the California Regional
       Water Quality Control Board (RWQCB), conducted an evaluation of the ground-
       water monitoring program  at the IT Corporation,  Vine Hill and Baker hazardous
       waste disposal facilities, Martinez, California. The  onsite field investigation was
       conducted during the period, June 2 through 12,  1987. The IT facilities are 2 of
       58  hazardous waste treatment, storage and disposal facilities (TSDFs)
       evaluated by the Task Force. The  Task Force effort came about in  light of
       concerns as to whether operators of hazardous waste TSDFs are complying
       with the State and Federal ground-water monitoring requirements.

            The objectives of the Task Force evaluation were to:

                 Determine the facility's compliance with the interim status ground-
                 water monitoring requirements of 40 CFR Part 265 and the equiv-
                 alent state requirements

                 Evaluate the  ground-water monitoring program described  in the
                 RCRA Part B permit application for compliance  with 40 CFR Part
                 270.14(c) and the equivalent State requirements, if applicable

                 Determine if the  ground water at the facility contains hazardous
                 waste or hazardous waste constituents

                 Provide information to assist the Agency in determining  if the
                 TSDF meets EPA ground-water monitoring requirements for waste
                 management  facilities receiving waste from response  actions

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             conducted under the Comprehensive Environmental Response,
             Compensation and Liability Act (CERCLA), as amended

       The Task Force prepared the accompanying evaluation report, which
  revealed a number of deficiencies in the ground-water monitoring program at
  the IT facilities.  The Executive Summary of the report discusses the findings
  related to the objectives of the investigation.

       In summary:

             The Sampling and Analysis Plans (SAPs) were deficient.

             It was not complying with the existing SAPs.

             It did not adequately characterize the hydrogeology of the sites.

             There were deficiencies in the ground-water assessment outlines
             and programs.

             The ground-water monitoring programs described in the Part B
             RCRA permit application were inadequate.

             Hazardous waste constituents are leaking to the ground-water
             from the hazardous waste surface impoundments.

             The facilities were not in compliance with the ground-water moni-
             toring requirements for the CERCLA  offsite policy and as such,
             may not receive CERCLA waste.

       This update provides information on ground-water related activities by IT
 since the Task Force inspection.  These activities are in response to measures
. taken  by EPA Region 9 and State agencies (DHS and RWQCB) to bring the
 facilities  into compliance with RCRA and other State regulations.

       The Vine Hill and Baker facilities are presently subject to Clean-up and
 Abatement  Orders (CAOs) issued by  RWQCB which require the continued

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 monitoring and evaluation of ground-water quality and levels within and around
 the facility.  While the CAOs  were in  effect at the time of the  Task Force
 inspection,  many reports  in response to the  CAOs were yet to be submitted..
 The  CAOs  required,  among other things, that IT determine the initial
 background ground-water quality, that the SAPs be  revised, that IT characterize
 the hydrogeology, and that IT investigate the contamination at Vine Hill and the
 waste constituent migration at Baker.  IT has since submitted a number  of
 reports pursuant to the CAOs.  The IT submittals are  currently being evaluated
 by RWQCB.

       A consent agreement which was  filed on April 1, 1987, by DHS with  IT
 Corporation for the Vine  Hill facility, required correction of numerous interim
 status operational requirements. These include those requirements pertaining
 to  inspections, waste  analysis  and tracking,  drum storage, closure plan  and
 closure cost estimate, and financial assurance. As of this date, IT has submitted
 a response  to all tasks required by the  consent  agreement.  Discussions are
 continuing between IT and DHS on some of the  submittals.  A civil penalty  of
 $2.1 million has been paid by IT Corporation.

       At the time of the Task Force inspection, in June and August of  1987,  IT
 Corporation  was seeking a permit to modernize and continue operations at the
 Vine Hill facility. Since that  time, however,  It  has withdrawn the RCRA Part  B
 permit applications  for both  the Vine Hill and Baker facilities and  is pursuing
 closure at both sites.

       On June 30, 1988, a Consent Decree was filed  in the U.S. District Court
 for the Northern District of California (Civil Number D-87-2071 SC) for the  Baker
 facility. The Consent Decree required, among other things, that IT Corporation
 cease  acceptance of hazardous waste at the. Baker facility, submit a closure
 plan for the purpose of obtaining closure plan approval, and complete
 implementation of the Agency-approved closure plan.  IT Corporation paid  a
civil penalty of $260,000.

      A closure plan for both the Vine Hill and Baker facilities was previously
submitted in December 1987 and April 1988.  Further revisions to the closure

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plan are still necessary.  The revised closure plan is due for EPA and State reg-
ulatory authority review in November 1988.

      IT Corporation is required by State law to remove all hazardous waste
liquids from the surface impoundments by January 1, 1989.  At the present time,
12 out of 22 surface impoundments have been emptied at the Vine Hill and
Baker facilities and  the  reduction  of  the hazardous waste  inventory  is
continuing. The primary goals of Federal and State regulatory authorities is to
close the  facilities in an  environmentally sound manner and prevent
degradation of both surface and ground waters.

      This update completes the Task Force evaluation of  the It Corporation,
Vine Hill and Baker facilities in Martinez, California.

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 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
 OFFICE OF ENFORCEMENT AND COMPLIANCE MONITORING
 EPA-330/2-89-006

 GROUND-WATER  MONITORING EVALUATION
 IT CORPORATION
 VINE HILL AND BAKER FACILITIES
 Martinez, California

 November 1988
Alan E. Peckham
Project Coordinator
National Enforcement Investigations Center

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                         CONTENTS


 EXECUTIVE SUMMARY

 INTRODUCTION	1

 SUMMARY OF FINDINGS AND CONCLUSIONS	9

     GROUND-WATER MONITORING DURING INTERIM STATUS	9

          Ground-water Sampling and Analysis Plan	9
          Sampling and Analysis Procedures	1 o
          Ground-Water Monitoring Well Network	11

     GROUND-WATER QUALITY ASSESSMENT PROGRAM	     12
     GROUND-WATER MONITORING PROGRAMS PROPOSED FOR
        RCRA PERMITS	           14
     TASK FORCE SAMPLING AND MONITORING DATA EVALUATION	15
     COMPLIANCE WITH CERCLA OFFSITE POLICY	1 5

TECHNICAL REPORT

INVESTIGATIVE METHODS	16

     RECORDS/DOCUMENT REVIEW AND EVALUATION	        16
     FACILITY INSPECTION	            17
     LABORATORY EVALUATION	         17
     WATER LEVEL MEASUREMENTS AND SAMPLE COLLECTION	18

FACILITY DESCRIPTION	35

     WASTE ACCEPTANCE PROCEDURES - VINE HILL	35

         Pre-Acceptance	35
         Truck Receiving	36

     WASTE TRACKING	                 36
     WASTE HANDLING UNITS AND FACILITY OPERATIONS	  37
     VINE HILL	37

         Container Storage Area	40
         Surface Impoundments	40
         Tanks	56
         Incineration	66
         Centrifugation (Sludge Dewatering)	68

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                          CONTENTS (cont.)
     BAKER FACILITY	69

          Impoundments A-1 through A-5....	70
          Impoundments B and C	73
          Impoundments D-1 through D-3	73
          Impoundment E	73
          Impoundments 1 through 4	73

SITE HYDROGEOLOGY	74

     INTRODUCTION	74

     HYDROGEOLOGIC UNITS	      75
     GROUND-WATER FLOW, DIRECTIONS, AND RATES	78

          Bedrock (Kp)	80
          Quaternary Older Bay Mud (Qobm)	80
          Quaternary Younger Bay Mud (Qybm)	80

GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS	83

     REGULATORY AUTHORITY	    83
     REQUIREMENTS AND EVENTS DURING INTERIM STATUS AT IT
       VINE HILL AND BAKER	       83
     GROUND-WATER SAMPLING AND ANALYSIS PLANS	    86
     IT SAMPLE COLLECTION AND HANDLING PROCEDURES	87

          Wellhead Measurements	88
          Purging of Monitoring Wells	90
          Sampling of Monitoring Wells	90
          Sample Parameters	90
          Adequacy of Handling Procedures	91

GROUND-WATER QUALITY ASSESSMENT PROGRAM	93

     VINE HILL FACILITY ASSESSMENT OUTLINE AND PLAN	94
     BAKER FACILITY ASSESSMENT OUTLINE AND PLAN	96

     GROUND-WATER MONITORING PROGRAMS PROPOSED FOR
       RCRA PERMITS	           100
     VINE HILL FACILITY	          100
     BAKER FACILITY	101

EVALUATION OF MONITORING DATA FOR INDICATIONS OF
  WASTE RELEASE	103

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                        CONTENTS (cont.)
      ORGANIC RESULTS - VINE HILL FACILITY	            103
      ORGANIC RESULTS - BAKER FACILITY	!j 04

 MONITORING WELL LOCATION, NUMBER, AND CONSTRUCTION	107

      LOCATION AND NUMBER	               107
      VINE HILL FACILITY SELF-MONITORING PROGRAM WELLS      107
      VINE HILL FACILITY INTERIM STATUS MONITORING WELLS	111

           Location and Number	111
           Construction	113

      BAKER FACILITY SELF-MONITORING PROGRAM WELLS	      115
      BAKER INTERIM STATUS MONITORING WELLS	116

           Location and Number	11 Q
           Construction	117

 SAMPLE ANALYSIS AND DATA QUALITY ASSESSMENT	121

      INITIAL YEAR OF MONITORING	125

           Vine Hill Facility	125
           Baker Facility	I..'."!."! 126
           Laboratory Performance	127

      MONITORING IN 1986	131

          Vine Hill Facility	131
          Baker Facility	'132
          Laboratory Performance	132

      MONITORING IN 1987 - JANUARY TO JUNE	133

          Vine Hill Facility	133
          Baker Facility	'. 134
          Analysis for California Appendix III Substances	135


REFERENCES
APPENDICES

A    SPECIFIC ANALYTICAL RESULTS - VINE HILL
B    SPECIFIC ANALYTICAL RESULTS - BAKER
                             in

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                           CONTENTS (cont.)
 FIGURES
 1     IT Corporation - Vine Hill and Baker Facility Locations	3
 2     Overlay of February 22, 1984 Aerial Photograph	7
 3     Task Force Sampling Locations at Acme Fill Corporation as part of
         the IT Investigation	19
 4     Vine Hill Treatment Plant Plan	^38
 5     Self-Monitoring Program Well Network	109
 6     Vine Hill Interim Status Monitoring Well  Completion Details	110
 7     Baker Interim Status Monitoring Well Completion Details	112
 8     Interim Status Monitoring Well Network	114
 9     Typical Baker Well Profile (Schematic)	119
 TABLES

 1     Chronology of Applicable Hazardous Waste Management
         Regulations, Permits, etc	5
 2     Water Level Measurements	20
 3     Purging Record - Vine Hill	;	24
 4     Sampling Record - Vine Hill	27
 5     Order of Sample Collection Bottle Type and Preservation List	30
 6     ISCO Meter Verification	33
 7     Surface Impoundments	41
 8     Chronology of Impoundment Construction	43
 9     Embankment  Dimensions - Vine Hill Impoundments	45
 10   Unified Soil Classification System Chart	47
 11    Incoming Waste Constituents Received in Vine Hill Hazardous
         Waste Units	48
 12   Hazardous Waste Storage and Treatment Tanks	"."...57
 13   Fuel/Reagent Storage Tanks	58
 14   Embankment  Dimensions - Baker Impoundments	71
 15   Measured Ranges of Hydraulic Conductivity Values (cm/sec)	79
 16   Federal and State Regulatory Authority for Interim Status Ground-
         Water Monitoring at the IT Vine Hill and Baker Hazardous Waste
         Facilities	84
 17   Selected Organic Constituents Present in  Task Force Samples,
         Vine Hill Facility	105
 18    Selected Organic Constituents Present in  Task Force Samples,
         Baker Facility	106
 19    Self-Monitoring Program Wells - Vine Hill Facility	108
20    Ground-Water Monitoring According to Sampling and Analysis
         Plans for January 1985 to June 1987-Vine  Hill Facility	123
21     Ground-Water Monitoring According to Sampling and Analysis
         Plans for June 1985 to June 1987- Baker.	124
                                 IV

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EXECUTIVE SUMMARY

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                            INTRODUCTION

      Concerns have been raised about whether hazardous waste treatment,
storage and disposal facilities (TSDFs) are complying with the ground-water
monitoring requirements promulgated under the Resource  Conservation and
Recovery Act  (RCRA),* as amended."  In question is the ability of existing or
proposed ground-water monitoring systems to detect contaminant releases from
waste management units at TSDFs.  The Administrator of the Environmental
Protection Agency (EPA) established a Hazardous Waste Ground-Water Task
Force (Task Force) to determine the current compliance status of TSDFs.  The
Task Force comprises personnel  from the Office of Solid Waste and Emergency
Response  (OSWER),  Office of Enforcement and  Compliance Monitoring
(OECM), the National Enforcement Investigations Center (NEIC), EPA regional
offices, and State regulatory agencies.

      This report presents the  results of the  Task Force investigation of  IT
Corporation's Vine Hill and Baker facilities  near Martinez, California with the
following objectives:

            Determine compliance with interim status ground-water monitoring
            requirements of 40 CFR Part 265,  as promulgated under RCRA  or
            the  State equivalent  (where  the  State  has received  RCRA
            authorization)

      •      Evaluate-the ground-water monitoring program described in the
            facility's RCRA  Part  B permit  application for compliance  with
            40 CFR Part 270.14(c)

            Determine if the ground water at  the facility contains hazardous
            waste or hazardous  constituents

            Provide information to assist the Agency in determining if the
           TSDF meets EPA ground-water monitoring requirements for waste
    Regulations promulgated under RCRA address hazardous waste management facility
    operations, including ground-water monitoring, to ensure that hazardous waste or
    hazardous waste constituents are not released to the environment.
    Includes Hazardous and Solid Waste Amendments of 1984 (HSWA)

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             management facilities receiving waste from  response actions
             conducted under the  Comprehensive Environmental Response,
             Compensation and  Liability Act (CERCLA)*

       Each Task Force evaluation will determine if:

             Designated RCRA and/or State required monitoring wells are
             properly located and constructed.

             The  facility  has  developed  and  is  following  an  adequate
             ground-water sampling and analysis plan.

       •      Required analyses have been  properly conducted  on samples
             from the designated RCRA monitoring wells.

             The ground-water quality assessment program outline or plan (as
             appropriate) is adequate.

             The ground-water  monitoring plan  submitted in the company's
             RCRA Part B  application meets the requirements of 40 CFR Part
             270.14(c); however, IT has withdrawn the Part B and has notified
             the State that Vine Hill and Baker will  be closed.

             The ground^ water  at  the .facility contains- hazardous waste  or
             hazardous constituents.   "•-      *   /•*        "   ;
                       •I~_   " •     "—  ~   . - Jf
      The onsite inspections -of "the IT Corporation Vine Hill and Baker facilities
[Figure 1], were conducted from June 2 through 12, 1987 and during the period
of August 4 through 6, 1987. During the latter period, the Task Force observed
IT's  regular  quarterly  RCRA ground-water sampling  procedures.   The
    Regulations promulgated under RCRA address hazardous waste management facility
    operations, including ground-water monitoring, to ensure that hazardous waste or
    hazardous waste constituents are not released to the environment.
    The procedures for planning and implementing off site response actions are specified in a
    May 6, 1985 memorandum from the Acting Assistant Administrator for Solid Waste and
    Emergency Response to Regional Administrators.

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   coirou*
OOfTfO u»
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 inspections were coordinated by NEIC personnel.  Concurrently, the Task Force
 conducted an equivalent investigation of the Acme  Fill Corporation*  facility,
 which is north of and contiguous with the IT Vine Hill facility. In general, the
 investigations involved  review of State,  Federal,  and facility records; facility
 inspection; ground-water sampling and analysis; water level measurements
 and an evaluation of the IT  laboratories, which perform the  ground-water
 sample analyses.

       The Vine  Hill and Baker facilities are located on about 35 and 135 acres,
 respectively,  east of Martinez, California in Contra  Costa County [Figure 1].
 Access to the site(s) is from Marina Vista  road off Interstate 680.  The Vine Hill
 facility is bordered on the north and east by the Acme  Fill Corporation property,
 to the south by the Martinez Gun Club,  and also to the east by marshland and
 Pacheco Creek.  The Baker site is bordered on the north and west by Pacheco
 Creek, to the south by  the Central Contra Costa Sanitary District Treatment
 Plant and to the east by marshland.  Both sites are located on filled tidal flats
 protected by levees. The nearest residential area is about a quarter mile south-
 west of both facilities.

       The Vine  Hill facility has been used for treatment and evaporation of
 chemical wastes since 1967.  IT generates, treats, and disposes  of hazardous
 wastes in  unlined impoundments at  the-Vine  Hill facility  (EPA  ID
 number CAD000094771)  under  a complex series  of  regulations,  permits,
 licenses, and orders issued by several regulatory agencies, predominantly EPA
 Region IX, the California Department  of Health  Services (DOHS), and the
 California  State  and Regional Water Quality Control Boards (SWQCB) and
 (RWQCB), respectively.  Various operating permits related to air emissions were
 also issued by the San  Francisco Bay  Area Air Quality Management District
 (BAAQMD).  A chronology of  applicable hazardous waste management
 regulations, permits, licenses, etc.  from November 1980  to present, was
compiled by NEIC through discussions with the various regulatory agencies
and review of documentation [Tables 1 and 16].
    Hazardous Waste Ground-Water Task Force • Evaluation of Acme Fill Corporation, Martinez
    California: EPA-330/2-88-042, July 1988

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                                  Table 1
            CHRONOLOGY OF APPLICABLE HAZARDOUS WASTE
               MANAGEMENT REGULATIONS, PERMITS, ETC.
                           IT, Vine Hill and Baker

          Effective Dates                       Regulations, Permits, etc.1

 November 19, 1980 - April 5, 1981          40 CFR 2652 ; CHWMR3  (CAC4
                                          Title  22)

 April 6, 1981  - June 3, 1981*              40 CFR 265; CHWMR (CAC, Title
                                          22), Interim Status Document 6

 June 4, 1981 - December 31, 1982        CHWMR (CAC, Title 22), Interim
                                          Status Document

 January 1, 1983 -                         40 CFR 265; ? CHWMR (CAC,
 Title
 September 25,  1983                      22), Interim Status Document

 September 26, 1983 - Present             40 CFR 265, 40 CFR  2Q4;8
                                          CHWMR (CAC, Title 22), Interim
                                          Status Document, Final
                                          Hazardous Waste Facility Permit 9

 1    Various operating permits related to air emissions were also effective during this time period
     but have not been listed here.
 2    Title 40, Code of Federal Regulations, Part 265 (interim status regulations)
 3    California Hazardous Waste Management Regulations (promulgated under the California
     Hazardous Waste Control Act, CHWCA)
 4    California Administrative Code
 5    Date Califomis&eceived RCRA Phase I interim authorization.
 6    Issued by California Department of Health Services
 7    Article 5.5, 25l59.5(b) of the CHWMA, effective January 1, 1983 incorporated all
     regulations promulgated under RCRA, including subsequent amendments.
 8    Final regulations became effective for tank treatment and storage and container storage
     when the State issued IT the final Hazardous Waste Facility permit.
 9    California issued permit for specified treatment and storage operations.


      The Baker facility has been used for treatment (primarily evaporation) of
treated wastewaters since 1970.   IT generates,  treats,  and  disposes of
hazardous waste in unlined impoundments at the Baker facility (EPA ID number
CAD089680250) under the same regulations as the Vine  Hill facility.  The Baker
facility has its own Interim Status Document but  does not have a Hazardous
Waste Facility Permit.

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       The Vine Hill and Baker facilities are approximately one-fourth mile apart
 and are operated in conjunction with each other.  In general, the Vine Hill facility
 receives  liquid wastes and sludges which may contain heavy metals, acids,
 sulfides,  phenols,  formaldehyde, cyanides, oils, and  solvents.  Treatment
 capabilities at Vine Hill include oxidation,  reduction,  neutralization, stripping,
 metals precipitation  and incineration.  The unlined surface impoundments
 receive treated wastes and wastes requiring minimal treatment (e.g., solids
 separation).  A centrifuge is used to facilitate sludge dewatering at Vine Hill.
 The Baker facility receives  almost all of its waste by pipeline from Vine Hill.
 Occasionally, some liquid waste (e.g., bleach) is used directly in the unlined
 Baker surface impoundments for odor  control.   Incinerator ash and surface
 impoundment and tank sludges are shipped to an offsite  landfill (IT  Panoche
 facility at Benicia, California or the Chemical Waste Management, Inc.,  facility at
 Kettleman Hills, California).

       Information regarding early Vine Hill site activity is limited; however,
 aerial  photographs compiled by the  Environmental  Monitoring Systems
 Laboratory (EPA), Las Vegas, of the Vine Hill site taken in July 1958, show that
 most of the site was occupied by two  large unlined  surface impoundments.
 Subsequent  photos show that these impoundments evolved into about 14
 separate units by April 1968.  In December 1972, there were only seven distinct
 units but the number was increased to  eight by 1974. There were still eight
 distinct units  in 1983 but their locations had changed to a configuration that is
 similar to that which  w^s present during  an  NEIC-RCRA  Compliance
 Investigation  in March .*S8£; [Figure 2].*  The IT unlined surface impoundments
 at Baker were constructed  between  1974 and  1980  and  their  current
configuration  is also shown on Figure 2.

      Initial waste handling  activities at  the Vine Hill facility began in the late
 1950's  or early 1960's and, according to IT personnel, involved management of
used oils.  This  activity evolved into  the now  phased-out inactive  IT Oil
Reprocessing facility.  Chemical waste treatment at Vine Hill began  in  October
1967.  Early operations were apparently very similar to current activities, and
    RCRA Compliance Investigation, IT Corporation, Vine Hill facility, Martinez, California: EPA-
    330/2-86-014, September 1986
      «•

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/T VINE HILL
   Lagand:

  LG  Lafoon   (Impoundment)
      Olka
      Standing Liquid
*-—  Drainafla
' • •  Faaead Slta Boundary
                           Approximate Scale, 1 Inch equals 700 fee
      £?2rlty °* February 22. 1984 Aerial Photograph of
      T Vln« Hill and Baker Facilities Martinet, California
                           Figure 2

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                                                                      8

 included waste storage and treatment in tanks and surface impoundments.  In
 1970, IT purchased 135 acres nearby which became the Baker facility and
 comprises  a series  of  unlined  surface  impoundments  used primarily  to
 evaporate wastewater received via  pipeline from the Vine  Hill facility.  All
 surface impoundments at both the Vine Hill and Baker facilities are unlined and
 engineering details were not available except as presented in this report.

       In the early to mid-1970's, IT Vine Hill installed a fume (vent gases from
 tank treatment and storage)  and  liquid waste injection incinerator.   The unit
 basically  replaced an older  "fume only" incinerator  installed  at some prior
 unknown date.  A centrifuge operation for sludge dewatering was added in late
 1984.  In late 1985, IT acquired property immediately southeast of the Vine Hill
 facility known  as  the "Acme property."  There are four inactive surface
 impoundments on this property.

      IT Vine Hill has about 90 employees working 3 shifts, 5 days a week and
 usually one shift on weekends. The facility has an onsite analytical laboratory
 which performs waste acceptance and characterization analyses for this and
 several other IT waste management facilities.  Waste treatment and  disposal
 activities at the time  of this  inspection included storage, treatment and/or
disposal in tanks, surface impoundments and the incinerator and centrifuge.

      IT is subject to compliance with two Cleanup  and Abatement Orders
(85-004 and 86-014) issued by the California Regional Water Quality Control
Board, San Francisco Bay Region.

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              SUMMARY OF FINDINGS AND CONCLUSIONS

      The findings and conclusions presented here reflect conditions existing
at the IT Vine Hill and Baker facilities in June 1987. Actions taken by the State,
EPA Region IX and  IT subsequent  to  June 1987 are summarized in  the
accompanying update.

      Task Force personnel inspected the IT Vine Hill and Baker facilities from
June 2 through June 12, 1987.  From August 4 through August 6, 1987, Task
Force personnel observed quarterly ground-water sampling by  IT to evaluate
whether IT personnel were properly implementing their RCRA sampling and
analysis plan.

GROUND-WATER MONITORING DURING INTERIM STATUS

      Task Force personnel evaluated the interim status ground-water moni-
toring program at  the IT Vine Hill and Baker facilities for the period between
November  1981,  when RCRA  and applicable provisions of the RCRA-
equivalent  California regulations became effective, and June 1987.  The
evaluation  revealed that  no  RCRA-equivalent interim status ground-water
monitoring  program was implemented at either facility until  October  1984.
Some ground-water monitoring had been  conducted starting as early as 1979,
but was not equivalent to the Interim Status Document (ISD) (RCRA-equivalent
State program) and was not based on an adequate sampling and analysis plan.

      Monitoring, as required by RCRA regulations, has not been completed for
the Vine Hill and  Baker monitoring well networks.  A review of facility and
laboratory data records showed that some parameters were not reported for
four quarters  of background  monitoring.   Monitoring,  as  required by the
sampling and analysis plans, was not completed within specified time periods.

Ground-Water Sampling and Analysis Plans

     The most recent of several versions of the RCRA ground-water sampling
and analysis plans (SAPs), which were in effect at the time of the Task Force
inspection for both the IT  Vine Hill and Baker facilities, are dated December

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                                                                     10

 1986. Therefore, 1 year of monitoring data has not been collected under these
 December 1986 plans at the time of the Task Force inspection. The plans are
 identical except for selection of different wells for each facility.  The plans lack
 specific procedures for field instrument calibration and decontamination of
 instruments and equipment between use in different wells.  None of the plans
 indicate which  wells are up and downgradient of specific waste management
 units.

 Sampling and Analysis Procedures

      The IT ground-water field sampling personnel who conducted the RCRA
 quarterly ground-water sampling at both the Vine Hill and Baker facilities did not
 follow the sampling and analysis procedures, as specified in  the  December
 1986 plans and, therefore, did not comply with the requirements of 40 CFR Part
 265.92(c). In addition to not following the  designated sampling and analysis
 plans, the procedures used by IT were inadequate. IT personnel,  conducting
 the sampling, were not familiar with the  new sampling and analysis plan even
 though this was the third quarter since the current SAP was in  effect. Obser-
 vation of the sampling of one high  producing well  revealed that the well was
 purged  with  a  submersible pump from near the bottom (adjacent to the
 screened  interval) and sampled from the top of the water column with a bailer.
 Although  three  column volumes of water were purged from the aquifer, the
 standing column of water in the well prior to purging was not evacuated before
 sampling. Thus, the water which was sampled was  not representative of water
 in the aquifer which was intended for sampling.

      Task Force personnel inspected the IT laboratories at Cerritos, California
 and Export, Pennsylvania; these laboratories perform the interim  status ground-
 water monitoring sample  analyses.  The laboratory evaluations revealed
 problems that  could  affect the quality of  the data  reported.   The  pH,
 conductance, total organic carbon (TOO) and total organic halides (TOX) data
 are suspect because of improper measurement procedures.  Conductance data
 in some  instances may be erroneous.  TOC results actually  represent the
determination of  nonpurgeable organic  carbon  (NPOC) and   excluded
purgeable organic carbon (POC).  The analytical methods  used in some
instances  were  inappropriate for  samples containing percent levels

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                                                                      11

 (10,000 mg/L or greater)  of  dissolved solids.   For some parameters, the
 laboratory could not justify the detection limits claimed,  based on the data
 observed in the laboratory  records.  Furthermore, the detection limits specified
 did not satisfy the  requirements of 40 CFR  265.92.  The  values reported for
 phenols on samples collected at IT Baker, may represent levels that would have
 been detected in blanks.  However, no field or laboratory blanks were analyzed.
 The problems cited  affected the reliability of the data in establishing background
 levels and in detecting releases of waste into the groundwater. The results of
 the laboratory evaluation are discussed in the Technical Report in the "Sample
 Analysis and Data Quality Assessment" section.

 Ground-Water Monitoring Well Network

       The uppermost aquifer and  the hydrogeologic units that need to  be
 monitored at the facilities have not been adequately identified by IT or their con-
 sultants, as required by 40 CFR 265.91 and  40 CFR  270.14(c)(2).  Therefore,
 adequacy of the well  locations (vertical and areal) cannot be verified because
 the ground-water flow zones, degree of hydraulic  interconnection, and the
 direction and rate of ground-water flow have not been defined.

       The ground-water monitoring well networks at IT Vine  Hill and  Baker
 facilities have evolved along with developing hydrogeologic definitions  of the
 area, which are incomplete.   The construction records  are not adequate to
 determine whether the designated monitoring wells are capable of monitoring
 discreet water-bearing zones or whether they produce water from multiple
 zones.  No determination of upgradient and downgradient well locations has
 been made by IT or their consultants.  Ground-water  mounding  has been
 identified beneath some of  the impoundments at both the Vine Hill and  Baker
 facilities.

      Monitoring well construction records do not correlate accurately to field
 measurements of well depths.  For most wells, the "as constructed" records are
 not available.  Thus, it is not possible to determine whether the ground-water
samples are representative  of formation water from specific zones intended for
monitoring.

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                                                                     12

       Some wells produced turbid purge water and samples.  This indicates
 that the wells were improperly constructed or  were inadequately developed.
 Under 40 CFR Part 265.91 (a), it is required that  the facility characterizes water-
 bearing  formations and determine the degree of interconnection,  hydraulic
 gradients, flow directions and flow rates in the uppermost aquifer and any
 interconnected aquifers in order to adequately locate monitoring wells.  Efforts
 to make these determinations have not satisfied the requirements.

 GROUND-WATER QUALITY ASSESSMENT PROGRAM

      IT did not comply  with the ground-water quality assessment program
 pursuant to  40 CFR 265.93(a) or the ISO (Section VIII)  requirements.   This
 program should have consisted of a ground-water quality assessment outline
 and  assessment plan, as necessary. IT did not submit ground-water quality
 assessment  outlines for either the Vine Hill or Baker facilities by November 18,
 1981, as required. IT was issued a Cleanup and Abatement Order (85-004)
 and  required to submit a ground-water assessment outline  for each site by
 February 15, 1985.  It complied with this requirement; however, both outlines
were inadequate.

      The assessment outline for the  Vine  Hill.facility lacks information
concerning:

            Circumstances under which additional  monitoring wells would be
            necessary if the initial phase of the  program reveals the presence
            of ground-water contamination

            How rate and extent of migration of  hazardous constituents will be
            determined

            How the volume/concentration of released contaminants would be
            determined

            Use of an appropriate statistical analysis program

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                                                                       13

              How the facility would be sure that all potential contaminants were
              identified in the plume(s)

              How an assessment monitoring plan, would be developed and the
              sampling frequency would be determined

              Designation of upgradient and downgradient wells

              Which aquifer(s) would be monitored

              Approximate schedules for the time needed to initiate assessment
              sampling, analyses, data evaluation, and report results

              How a  determination would  be made to return  the  facility  to
             detection monitoring if contamination was not confirmed .

       The  Baker  facility has a  document titled "Ground-Water  Quality
 Assessment  Outline-IT Corporation Baker Facility"; however, this document
 does not address an assessment program, as required.  Instead of describing a
 program which would start after statistical analysis of quarterly monitoring data
 triggered assessment, the  outline describes  modifications to the existing
 detection monitoring program.  New wells  are  proposed "to help in early
 detection of  problems," not to determine rate and extent of migration, as
 required during assessment.

       The "assessment outline" describes work that  is not yet completed,
 because of shortfalls of the detection system, rather than steps which will be
 taken  if the detection monitoring system triggers assessment, via the statistical
 analyses of quarterly data. The statistical analysis program described  is used
.only to determine "seasonal  variance" in the  water quality,  and never implies
 that comtaminants may be the cause of water quality fluctuations.  The statistical
 analysis program proposed does not indicate which well(s) will be used for
 background ground-water quality determinations.

       At the time of  the Task  Force  inspection, ground-water  interim status
 monitoring data was  available  which  should  have required IT to prepare  an

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                                                                     14

 assessment plan for the Vine Hill facility.  The September 1986 Abatement
 Order (86-014) required that Vine Hill submit an assessment plan; however, this
 had not been done.

       The 1985 Cleanup and Abatement Order required  IT to submit  an
 assessment plan for the Baker facility. The plan has been submitted but IT has
 not completed implementation of it. Furthermore, the tasks in the assessment
 plan are not based on  the assessment outline, as required in 40 CFR 265.93.
 The implementation of the  Baker assessment plan is in  accordance with
 provisions and time tables specified in the Abatement Orders, which are more
 stringent than those specified in 40 CFR 265.93(d).

 GROUND-WATER MONITORING PROGRAMS  PROPOSED FOR  RCRA
 PERMITS

      The RCRA Part B permit applications for both the IT Vine Hill and Baker
 facilities, submitted to EPA Region IX on August 1,  1983 by IT, do not comply
 with the requirements  of 40 CFR 264.97 and 270.14(c)(2).'  The proposed
 ground-water monitoring programs do  not identify the uppermost aquifer nor do
 they describe which aquifer(s) are hydraulically interconnected and should  be
 monitored.

      The proposed programs do not designate monitoring wells to determine
 background ground-water quality, as required by 40 CFR 264.97, nor do they
 include consistent analytical methods to determine water quality, as  required by
 40 CFR 264.97(d).

      IT proposed detection  monitoring  under 40 CFR 264.98  for both
facilities.  However,  because organic contaminants have been detected in
ground water and soils, the proposed programs should include provisions for
compliance monitoring,  as required under 40 CFR 264.99.
    The State of California was never granted authorization to issue RCRA disposal permits;
    therefore, Federal requirements are cited here.  The State did have brief authority for
    issuing treatment and storage permits [Table 1J.

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                                                                    15

 TASK FORCE SAMPLING AND MONITORING DATA EVALUATION

      Results of the Task Force sampling and  monitoring data evaluation
 indicate that hazardous waste constituents are leaking to the ground water from
 impoundments at both the Vine Hill and Baker facilities.

      Organic and  inorganic  constituents were detected in several wells at
 each of the IT facilities.  Wells  MW-102 and MW-113 at the Baker facility
 exceeded the maximum contaminant level of 1.0 mg/L for barium.  Organic
 analytical results indicate  the presence of volatile and semi-volatile organic
 compounds in Vine Hill monitoring wells MW-203, MW-205, MW-215, MW-222,
 TB-515 and Baker wells MW-101,  MW-125 and a ground-water seep.  Details of
 these findings are discussed in the section of this report titled, "Evaluation of
 Monitoring Data for Indications of Waste Release."

      In addition, ground-water analytical data in the  RWQCB files indicate the
 presence  of contaminants in ground  water, which has leaked  from  some
 impoundments.

 COMPLIANCE WITH CERCLA QFFSITE POLICY

      The EPA offsite policy requires that any treatment, storage, or disposal
 facility (TSDF) used for land disposal of waste from CERCLA response actions
 must  be in compliance with the applicable technical requirements of RCRA.
 Interim status facilities must have an adequate ground-water monitoring
 program to assess whether the facility has had a significant impact on ground-
water quality.  Neither the IT Vine Hill nor Baker facilities have complied with the
technical  ground-water monitoring requirements for waste management
facilities.

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TECHNICAL REPORT

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                                                                    16

                       INVESTIGATIVE METHODS

       The Task Force evaluation of IT Vine Hill and Baker facilities consisted of:

             Reviewing and evaluating  records and documents from EPA
             Region IX, California Department of  Health  Services (DOHS);
             Regional Water Quality  Control Board (RWQCB), San Francisco
             Bay Region; State Water Quality Control Board (SWQCB); and IT

             Conducting onsite facility inspections June 2 through June 12 and
             August 4 through 6, 1987

             Evaluating two offsite  laboratories

             Determining water level elevations in selected wells

             Sampling and subsequent analysis of ground water from selected
            wells

 RECORDS/DOCUMENT REVIEW AND EVALUATION

      Records  and documents from  EPA Region  IX, DOHS, SWQCB, and
 RWQCB were reviewed prior to the  onsite inspection.  Facility records were
 reviewed to verify  information currently  in government files and supplement
 government  information where necessary.   Selected  documents requiring
 further evaluation were copied by Task Force personnel during the inspection.
 Records were reviewed to obtain information about facility operations, locations
 and construction of waste management units and monitoring wells, and  ground-
 water monitoring activities.

      Specific documents  and records  that were  requested and reviewed
included the ground-water sampling and analysis plans, ground-water quality
assessment program outlines, analytical  results from ground-water sampling,
monitoring well construction data and logs, site geologic reports, site operations
plans, facility permits,  unit design,  and operation reports.  Other records
reviewed included selected personnel position descriptions  and qualifications

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                                                                     17

 (those related to the required ground-water monitoring), and operation records
 showing the general types and quantities of wastes disposed of at the facility
 and their locations.

 FACILITY INSPECTION

      A facility inspection was conducted to identify waste management units
 (past and present), current waste management operations and pollution control
 practices, and to verify the location of ground-water monitoring wells.

      Company representatives supplied records and documents, answered
 questions  about documents and explained:  (1) past and present facility
 operations, (2) site hydrogeology, (3) the ground-water monitoring system, and
 (4) the ground-water monitoring sampling and  analysis plans.  Ground-water
 samples are  collected and  analyzed by EPA  contractors.   IT personnel
 demonstrated sampling techniques and were  questioned regarding sample
 collection, handling, analysis, and document control.  The need for the ground-
 water field sampling personnel  to have greater familiarity  with the applicable
 sampling and analysis plan and the need to adhere strictly  to the requirements
 of the plan(s) were discussed with IT management  officials.

 LABORATORY EVALUATION

      The IT laboratories in Cerritos, California  and Export, Pennsylvania per-
 form determinations  for the majority of ground-water parameters for the Vine
 Hill and Baker facilities.  The laboratories were evaluated June 10 to 12,  1987
 and October 20 to 23, 1987 respectively, to assess their ability to receive, han-
 dle and analyze ground-water samples from the IT  facilities.   During the evalua-
 tions, analytical equipment was  inspected and operating and analytical proce-
 dures were  examined for adequacy.  Laboratory records  were reviewed for
 completeness, accuracy and compliance with State and Federal requirements.
 The results of the laboratory evaluation reviews are discussed in the section of
this report titled, "Sample Analysis and Data Quality Assessment."

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                                                                     18

 WATER LEVEL MEASUREMENTS AND SAMPLE COLLECTION

       Sampling activities, at the IT facilities, during the investigation included
 the following:

            Measuring total depth and water levels in 66 monitoring wells, test
            borings and piezometers, including 6 monitoring wells at the Acme
            Fill Corporation facility adjacent to  IT Vine Hill [Figure 3].

            Collecting ground-water samples from 34 monitoring wells, 1 test
            boring and  1  ground-water  seep, and sampling liquid from 3
            surface impoundments, as well as field blanks, equipment blanks,
            and a trip blank for quality assurance/quality control purposes

      •     Recording water levels in four monitoring wells continuously for
            approximately 24 hours

      Task Force  personnel measured water levels in  48 monitoring wells,
 borings, and piezometers surrounding the Vine  Hill and Baker treatment ponds
 [Table 2] to verify past IT data. Wells adjacent to the IT Vine Hill facility and the
 six wells on the Acme Fill property (an adjacent hazardous waste management
 facility) were measured at approximately the same time to determine potential
 ground-water gradients between the Acme and Vine Hill facilities. Additional
 water level measurements were made on the  wells sampled prior to purging
 and sampling to aid in  determining water column volumes.

      Samples were collected from 32 wells to determine if the ground water
 contained hazardous waste or hazardous  constituents.  Wells sampled were
 chosen for their proximity to hazardous waste management areas,  depth of
 completion, wells which historically had shown the presence of hazardous con-
 stituents, when sampled by IT and to provide areal coverage. Wells screened at
different depths and geologic formations were  chosen to sample a variety of
 horizons. Several surface impoundments were sampled to identify the types of
wastes treated onsite and the constituents that may be present in the ground
water.  Wells were  sampled (G-6A, MW-115, MW-116, MW-117, MW-119 and
MW-128) at the Acme facility to determine the quality of the ground water in the

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         V
                      \
                                                             \
                                                               \
                                                                             ~4
                                                                            /
   LEGEND

Property  Boundary
Waste •(•••••••lit Area
Water Levels and Sample*
                              NORTH PARCEL
                                            MWl 15
                                                           ACME
                                                              PARCEL
   MW128
IT VINE HILL
                                            100*
                                                                            IN Mi I
                                  FIGURE 3
                  Task Force Sampling Locations at Acme  Fill
                   Corporation as part of the IT Investigation

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                                             20
         Table 2
WATER LEVEL MEASUREMENTS


Wefl No.

MW-202
MW-203
MW-204
MW-205
MW-206
MW-207
MW-209
MW-212
MW-213
MW-214
MW-215
MW-216
MW-218
MW-219
MW-221
MW-222
MW-227
TB-515
TB-517

G-6A
MW-115
MW-116
MW-117
MW-119
MW-128
Water Level Total Wen Water Table
Depth Depth Elevation (ft.)
(ft)7 (ft) (MSL)*
IT Vine Hill Welts
7.58 112.46 3.82
4.27 32.96 7.25
12.54 36.66 6.92
3.0 33.32 4.02
5.61 87.5 4.26
2.56 31.25 7.72
0.10 38.53 12.78
4.35 42.66 3.02
0.08 36.52 12.47
8.58 39.04 6.92
2.13 46.84 9.77
4.29 68.26 7.34
1.94 44.36 9.75
3.35 96.82 4.05
6.88 63.17 7.09
27.04 35.64 -13.24
15.08 31.85 -12.49
22.23 29.49 -7.40
6.32 35.54 7.53
Acme Wells
29.26 36.44 6.88
4.97 37.54 15.08
2.12 36.95 15.00
6.20 26.59 4.98
4.82 41.29 14.28
5.72 65.50 7.43


Date

6/2/87
6/2/87
6/3/87
6/3/87
6/3/87
6/2/87
6/2/87
6/2/87
6/2/87
6/5/87
6/2/87
6/2/87
6/2/87
6/2/87
6/2/87
6/2/87
6/2/87
6/5/87
6/2/87

6/3/87
6/3/87
6/3/87
6/2/87
6/2/87
6/2/87


Time5

1445
1455
0800
0950
1000
1630
1420
1545
1430
1245
1345
1400
1410
1550
1605
1615
1645
1330
1610

0825
1410
1440
1520
1405
1435
1 Measurement recorded in feet below top of surf ace casing.
2 Elevations recorded in foot abovo/botow moan sea lovoL
3 Rounded to nearest S minutes.

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                                                                               21
                               Table 2 (cont.)

                     WATER LEVEL MEASUREMENTS
Well No.
Water Level
Depth
(ft)'
Total Well
Depth
(ft)
Water Table
Elevation (ft.)
(MSL)*
Date
Time5
IT Baker WPlte
MW-1A
MW-5A
MW-6A
MW-8A
MW-9A
MW-14
MW-15
MW-16A
MW-16B
MW-101
MW-102
MW-103
MW-104
MW-105
MW-106
MW-110
MW-112
MW-113
MW-118
MW-125
MW-126
MW-127
B-124
B-125
B-126
B-127
B-128
B-129
B-130
5.88
5.85
4.21
1.34
5.54
4.35
2.75
4.68
4.83
546
5.33 .
3.31
4.0
7.42
10.12
2.52
9.25
1.40
16.07
22.54
25.32
21.00
11.09
10.07
8.16
14.74
11.75
11.48
25.21
32.31
24.56
23.35
22.75
22.22
21.33
101.92
67.56
44.07
38.00
38.38
26.37
32.04
37.38
29.43
36.15
44.00
33.99
42.73
29.22
36.36
30.16
83.97
64.03
50.66
32.54
88.17
63.33
36.33
8.74
3.4
4.07
6.43
2.91
4.99
4.58
3.67
4.42
3.83
3.81
3.72
5.17
7.43
3.75
10.22
3.01
5.42
-8.74
-16.45
-16.79
-13.11
2.87
3.87
5.56
-0.89
3.13
3.38
-10.43
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
6/8/87
1640
1325
1315
1255
1645
1455
1345
1230
1235
1445
1430
1340
1310
1655
1535
1725
1710
1555
1545
1245
1230
1215
1620
1615
1630
1630
1510
1515
1520
1    Measurement recorded in feet below top of surface casing.
2    Elevations recorded in feet aboveSbetow mean sea level.
3    Rounded to nearest S minutes.

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                                                                      22

 vicinity of the IT facility. The Acme facility has accepted a variety of wastes for
 landfilling including hazardous wastes and, therefore, there is concern as to the
 potential for subsurface migration of  hazardous constituents from the Acme
 facility to IT Vine Hill and vice versa.

       All samples  were collected  by an  EPA contractor (Versar,  Inc., of
 Springfield, Virginia)  and sent to EPA contractor  or NEIC  laboratories  for
 analysis.  Analytical techniques and methods are presented in Appendices A
 and B.   Duplicate volatile  organic  samples  and  splits  of other  sample
 parameters were offered to and accepted by IT. In addition to the  aliquots
 collected for Task Force analysis and sample splits provided to  IT, IT requested
 extra sample volumes for TOC, TOX and anion analysis as well as aliquots  for
 mercury, nutrients and radionuclides. Samples for Task Force  analysis did not
 include nutrients and radionuclides.  These aliquots were collected at 25 wells
 (Vine  Hill - MW-209,  MW-212, MW-219,  MW-214,  MW-204, MW-205, and
 MW-206;  Baker - MW-104, MW-1A,  MW-101,  MW-102, MW-14, MW-110,
 MW-6A, MW-8A, MW-106, MW-15, MW-103, and MW-5A; Acme - G-6A, MW-
 115, MW-116, MW-117, MW-119, and MW-128).  The locations of the Acme
 wells are shown in Figure 3.  The locations of Vine Hill and Baker wells  are
 discussed in the section of this report titled "Monitoring Well Location, Number
 and Construction."

      None of the IT wells were equipped  with pumps; therefore, the EPA
contractor supplied purging and sampling equipment for each well sampled.
Sample collection procedures were as follows:*

      1.     IT personnel unlocked the wellhead.

      2.     The open wellhead was checked for chemical vapors [Photovac
            TIP® and organic vapor analyzer (OVA®)].
    Unless specified differently, the EPA contractors conducted the work.
    Photovac TIP and OVA are registered trademarks and appear hereafter without ®.

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                                                               23
3.    The depth to ground water was measured using an oil/water sonic
      Interface  Probe (Moisture  Control Co.,  Inc. Model  B2220-3)
      [Table 1] and recorded to the nearest 0.01 feet.

4.    The Interface Probe was  lowered through the water column until
      the bottom of the well was reached, and total depth recorded to the
      nearest 0.01 foot.

5.    The Interface Probe was retrieved  from the  well bore.  The cable
      and probe were decontaminated after each use with a pesticide-
      grade hexane wipe, followed by a distilled water  rinse and wiped
      dry.

6.    The well was relocked. The water levels were taken at selected
      wells on the first 2 days of the inspection at  each  facility and then
      locked until they were sampled later in the inspection.

7.    When Task Force personnel  were ready to sample a well,  IT
      personnel reopened the wellhead.

8.    Water level measurements were made, as  discussed  in steps 3
      and 5 above.

9.    Water column volumes were calculated using the  height of the
      water column, well casing radius and a constant.

10.   Three water column volumes  were purged using equipment  as
      indicated in Tables 3 and  4. The purge water was collected in a
      4-gallon  plastic bucket. Purge water was then poured into a drum
      and held for later disposal by IT personnel.

11.   A sample aliquot was collected at the beginning,  middle and end
      of  the purge for temperature, specific conductance and  pH
      measurements.  Table 5 presents sample collection information.

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                                                                 Table 3
                                                           PURGING RECORD

Well
Number

MW203

MW204
MW205
MW206
MW207
MW209
MW212

MW214
MW215

MW216
MW218

MW219
MW222
MW227

TB515

Total Well
Depth1

32.96

36.66
33.32
87.5
31.25
38.53
42.66

39.04
46.84

68.26
44.36

96.82
35.64
31.84

29.5
Top of
Casing
Elevation2

11.4

19.46
7.02
9.87
10.28
12.8
7.37

15.51
11.90

11.63
11.69

7.4
13.80
2.59

14.85
Water
Level
Elevation2

7.25

6.92
4.02
4.26
7.72
12.78
3.02

6.92
9.77

7.34
9.75

4.05
-13.24
-12.49

-7.40
Total Volume
of Water
Purged (Gal.)
Vine
21.75

47
60
160
20
43.5
74

59.5
25.5

124
27

182
13
13
4.5
3.5
3.8


Date
HIM Wells
06/08/87

06/03/87
06/03/87
06/03/87
06/03/87
06/04/87
06/04/87

06/05/87
06/04/87

06/04/87
06/04/87

06/05/87
06/08/87
06/03/87
06/04/87
06/05/87
06/08/87


Time3

0905-0935

0900-1005
1105-1205
1400-1605
1340-1420
1205-1250
1605-1655

1245-1340
0840-0930

0850-1105
0905-0950

1130-1350
0915-1000
0900-0925
0810-0825
1535-1555
0820-0857


Methods/Remarks

Teflon* bailer, well purged dry. yellow
colored water
Teflon bailer
Teflon bailer
Keck pump
Teflon bailer, well purged dry
Teflon bailer, dark green, strong odor
Teflon bailer, greenish color and oily
sheen on water
Teflon bailer
Teflon bailer, well purged dry, greenish
color and sheen on water
Teflon bailer
Teflon bailer, well purged dry, greenish
color, strong sulfide odor
Teflon bailer
Teflon bailer
Teflon bailer, well purged dry
Teflon bailer, well purged dry
Teflon bailer, well purged dry, greenish tinge
1 Measurements recorded in feet below the top of the inner casing by Task Force personnel
2 Elevations recorded in feet above or below Mean Sea Level (MSL)
3 Rounded to the nearest 5 minutes
                                                                                                                                              ro
     Teflon is a registered trademark and will appear hereafter without .

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                                                              Table 3 (cent.)

                                                           PURGING RECORD

Well
Number

G6A
MW115
MW116

MW117

MW119
MW128

MW1A

MW5A
MW6A

MW8A
MW9A
MW14
MW15
MW101


Total Well
Depth1

36.44
36.95
36.95

26.59

41.29
65.50

32.31

24.56
23.25

22.75
22.22
21.33
101.92
38.0

Top of
Casing
Elevation2

36.14
20.05
17.12

11.18

19.10
13.15

14.63

9.25
8.27

7.77
8.45
9.34
7.33
9.28

Water
Level
Elevation2

29.26
4.02
1.04

4.85

4.37
5.75

8.74

3.4
4.07

6.43
2.91
4.99
4.58
3.83

Total Volume
of Water

Purged (Gal.) Date

4.5
26
26.25

18

30
1.2

18

36
22

37
33
13
194
51

Acme Wells
06/03/87
06/08/87
06/08/87

06/05/87

06/04/87
06/04/87
Baker WeMs
06/10/87

06/10/87
06/09/87

06/09/87
06/10/87
06/11/87
06/10/87
06/1 1/87


Time3

0855-0930
0820-0945
0755-0905

1430-1445

0955-1030
1435-1610

1105-1150

1310-1435
0850-0950

1015-1130
1250-1340
1035-1110
0905-1130
1310-1415


Methods/Remarks

Teflon bailer, well purged dry
Teflon bailer, well purged dry
Teflon bailer, well purged dry, yellow silty
purge water
Keck pump, well purged dry, yellow
odiferous purge water
Keck pump, well purged dry
Keck pump

Teflon bailer, water black, turpid. well
purged dry
Teflon bailer, water yellowish brown
Teflon bailer, water yellow. Crew wore
respirators, well purged dry
Teflon bailer, purged to dryness
Teflon bailer, gray water
Teflon bailer, well purged to dryness
Teflon bailer
Teflon bailer, water yellow, sulfur odor,
purged dry
1     Measurements recorded in feet below the top of the inner casing by Task Force personnel
2     Elevations recorded in feet above or below Mean Sea Level (MSL)
3     Rounded to the nearest 5 minutes
ro
en

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                                                             Table 3 (cent)

                                                           PURGING RECORD

Well
Number

Total WeH
Depth'
Top of
Casing
Elevation*
Water
Level
Elevation*
Total Volume
of Water
Purged (Gal.)


Date


Time3


Methods/Remarks
Baker Wells (Cont.)
MW102

MW103
MW104
MW105
MW106
MW110
MW112
MW113
MW125
38.38

26.37
32.04
37.38
29.43
36.15
44.0
33.99
29.22
9.14

7.03
9.17
14.85
13.87
12.74
12.26
6.82
6.09
3.81
*
3.72
5.17
7.43
i
3.74 ,
10.22
3.01
5.42
-16.45
50

20
54
24
38
42
28
43.5
7
06/10/87

06/10/87
06/09/87
06/10/87
06/10/87
06/11/87
06/09/87
06/11/87
06/12/87
1305-1425

0905-0950
1025-1130
0845-0940
1005-1050
1140-1230
0840-0920
0830-1005
0805-0825
Teflon bailer, water yellow-black, well
purged dry
Tellon bailer, well purged dry
teflon bailer, water black
Teflon bailer, water yellow, well purged dry
Teflon bailer, water yellow, well purged dry
Teflon bailer, water yellow, well purged dry
Teflon bailer, well purged dry
Teflon bailer, water black, well purged dry
Teflon bailer, well purged dry
      Measurements recorded in feet below the top of the inner casing by Task Force personnel
2     Elevations recorded n feet above or below Mean Sea Level (MSL)
3     Rounded to the nearest 5 minutes

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                                                                27
                            Table 4
                      SAMPLING RECORD
Well
Number

MW-203
MW-204
MW-205


MW-206
MW-207
MW-209
MW-212
MW-214
MW-215

MW-216
MW-218
MW-219
MW-222

MW-227

TB-515
Field blank
Pond 101

Equipment
blank
Date

06/08/87
06/03/87
06/03/87


06/03/87
06/03/87
06/05/87
06/05/87
06/05/87
06/04/87

06/04/87
06/04/87
06/05/87
06/08/87

06/05/87

06/08/87
06/04/87
06/08/87

06/08/87
- Time*
Vine
1525-1625
1025-1200
1345-1530


1625-1700
1540-1605
0845-0940
1000-1055
1415-1505
1415-1445

1115-1200
1445-1535
1355-1435
1630-1740

0820-0905

1450-1510
0950-1100
1040-1140

0720-0830
Sample
. Number
Hill Wells
MQB439
MQB423
MQB422
MQB425
MQB426
MQB424
MQB427
MQB432
MQB438
MQB434
MQB428

MQB431
MQB429
MQB433
MQB441

MQB437

MQB434
MQB430
MQB442

MQB435
Methods/Remarks

Teflon bailer, dry after TOG
Teflon bailer
Teflon bailer, triplicate
sample

Teflon bailer
Teflon bailer, dry after POX
Teflon bailer
Teflon bailer, matrix spike
Teflon bailer
Teflon bailer, dry after four
extractable organics
Teflon bailer
Teflon bailer, dry after TOX
Teflon bailer
Teflon bailer, dry after three
extractable organics
Teflon bailer, dry after
extractable organics
Teflon bailer, dry after POX
Poured at MW-216
Poured from stainless steel
bucket
Poured through Teflon bailer
Acme Wells
G-6A

MW-115

06/03/87
06/04/87
06/08/87
06/08/87
1550-1630
0820-1020
1130-1150
1550-1605
MQB402

MQB413

Teflon bailer

Teflon bailer

Time rounded to nearest 5 minutes

-------
                                                                    28
                             Table 4 (cont.)

                     SAMPLING RECORD - VINE HILL
Well
Number

MW-116

MW-117

MW-119

MW-128


Date

06/08/87
06/08/87
06/08/87
06/09/87

06/04/87
06/05/87

06/04/87


Time*
Acme
1045-1100
1620-1645
1515-1520
0945-1015

• 1245-1335
0810-1020

1615-1655


Sample
Number
Wells (cont.)
MQB412

MQB415

MQB405
MQB406
MQB407
MQB 409


Methods/Remarks

Teflon bailer

Teflon bailer, sample very
black and sediment filled,
bailer oily
Teflon bailer, triplicate
sample, sample very
green/black
Teflon bailer, matrix spike,
sample is yellow but not
turbid
Baker Wells
MW-1A


MW-5A
MW-6A
MW-8A
MW-9A
MW-14
MW-15


MW-101



06/10/87

06/11/87
06/10/87
06/09/87
06/10/87
06/10/87
06/11/87
06/10/87


06/11/87


06/12/87
1630-1730

1430-1505
1445-1535
1515-1630
1625-1730
1350-1430
1440-1535
1130-1255


1620-1705


0850-0900
MQB457


MQB453
MQB446
MQB448
MQB451
MQB456
MQB447
MQB449
MQB452
MQB464



Teflon bailer, VOA through
metals
TOC through sulfides
Teflon bailer
Teflon bailer
Teflon bailer
Teflon bailer
Teflon bailer
Teflon bailer, triplicate
sample

Teflon bailer, VOA through
extractable organics, TOC,
TOX
Metals, phenol through
MW-102   06/11/87   1555-1645    MQB419
 sulfides

Teflon bailer, VOA through
 extractable organics, TOC,
 TOX
    Time rounded to nearest 5 minutes

-------
                                                                     29
                             Table 4 (cont.)
                     SAMPLING RECORD - VINE HILL
   Well
 Number
 MW-102
 (cont.)
 MW-103
 MW-104
 MW-105
              Date
 MW-106   06/10/87
 MW-110   06/12/87
 MW-112   06/09/87

 MW-113   06/11/87

 MW-125   06/12/87

           06/09/87

           06/09/87

Field blank  06/11/87
Eq. blank   06/11/87
Tims*
Sample
Number
                                                   Methods/Remarks
                           Baker Wells (cont.)
           06/12/87   0805-0830

           06/10/87   1435-1540    MQB454
           06/09/87   1130-1245    MQB443
           06/10/87   1520-1600    MQB455

           06/11/87   1005-1040
                      1055-1145    MQB450
                      0910-0930    MQB420
                      1300-1400    MQB440

                      1045-1205    MQB459

                      1225-1235    MQB460

                      1510-1550    MQB444

                      1405-1445    MQB445

                      0855-0920    MQB461
                      0900-0925    MQB462
G.W. seep  06/11/87   0935-0940   MQB458
                     Teflon bailer, metals and
                      phenol through sulfides
                     Teflon bailer
                     Teflon bailer
                     Teflon bailer
                      VOA through extractable
                      organics, TOC
                      metals, TOX (not enough
                      sample to finish)
                     Teflon bailer
                     Teflon bailer, matrix spike
                     Teflon bailer, well dry after
                      two extractables
                     Teflon bailer

                     Teflon bailer, well dry after
                      two extractable organics
                     Filled bottles directly from
                      impoundment
                     Filled bottles directly from
                      impoundment
                     Poured near staging area
                     Deionized water poured
                      through teflon bailer

                    Seep adjacent to SI2-D1,
                    sample poured from glass
                    beaker
Trip blank  06/11/87   N/A
                                  MQB421    Sample poured in lab
1   Time rounded to nearest 5 minutes.
2   Surface Impoundment

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                                                                     30
                                Table 5
                    ORDER OF SAMPLE COLLECTION
                 BOTTLE TYPE AND PRESERVATION LIST
       Parameter
        Bottle
                                                         Preservative*
 Volatile organic analysis (VOA)
    Purge and trap
 Purgeable organic carbon
 (POC)
 Purgeable organic halogens
 (POX)
 Extractable organics
 Dioxins/furans
 Total metals
 Total organic carbon
 (TOO)
 Total organic halogens
 (TOX)
 Phenol
Cyanide
Anions
Sulfides
  Two 60-mL VOA vials
  Two 60-mL VOA vials
  Two 60-mL VOA vials
  Six 1-qt. amber glass
  Two 1-qt. amber glass
  One 1-qt. plastic
 One 4-oz. glass

 One 1-qt. amber glass
 One 1 -qt. amber glass
 One 1-qt. plastic
 One 1-qt. plastic
 One 1-qt. plastic
HNO3
H2SO4
CuSO4 + H3PO4
NaOH
    All samples were stored on ice
    analytical laboratories.
immediately after collection and during transport to the

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                                                                      31

       12.    Sample  containers were filled for the various parameters in the
             order shown  in  Table 5 using the  equipment indicated in
             Table 3.  All samples  collected from  the  monitoring wells and
             impoundments were filled directly from the bailer or a bucket. Split
             samples were collected by filling one-third of each sample bottle
             for IT and the Task Force, respectively, from the bailer or bucket
             until each bottle was filled.  If the volume in the bailer or bucket
             could not fill one-third of each bottle, the  bailer was divided
             equally between the bottles.

       13.    Samples were placed on ice in an insulated cooler.

       14.    Contractor personnel took the samples, immediately after collec-
             tion,  to  a staging area  where the samples  were  preserved
             [Table 5].

       The sequence  of sample collection  for some  parameters was modified
 when  slow recharge prevented collection  of all aliquots in sequence without
 lapsed time  between aliquots.   In  these cases (Vine  Hill  wells MW-203,
 MW-207, MW-215, MW-218, MW-222, MW-227,  TB-515 and Baker wells
 MW-1A, MW-101, MW-102 and MW-105) organic samples were collected within
 2  hours following purging; the remaining aliquots were collected,  if possible,
 after allowing time for the wells to recharge.

       The  EPA contractor prepared field blanks for each analytical parameter
 group  (e.g., volatiles, organics and metals) twice during the investigation [Vine
 Hill; (near  well MW-216)] and [Baker; (near the sample staging area)] by
 pouring distilled,  deionized  water into sample containers.  Two  equipment
 blanks were poured, both  through laboratory-cleaned Teflon bailers.  One trip
 blank for each parameter group was prepared and submitted to the laboratory
 during the inspection.  The blanks were  submitted with  no distinguishing
 labeling or marking to identify them  as blanks, nor did the samples have any
distinguishing labeling to identify them as  samples.  Hence, the laboratories
could not determine sample locations or whether a sample was a blank or not.
Thus, all aliquots submitted to laboratories for analysis were "blind" to aid in
achieving quality assurance/quality control goals.

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                                                                      32

       In addition to the blank samples, matrix spike and triplicate samples were
 taken for analytical quality assurance/quality control purposes. Two laboratory
 matrix spike samples, each consisting of two duplicate VOA vials and two 1 -liter
 amber glass bottles, were collected (Vine Hill well MW-212 and Baker well
 MW-101).  Three laboratory triplicates of all parameter groups were collected
 (Vine Hill well MW-205, Baker well MW-15, and Acme well MW-119).

       During collection of all samples,  Task Force personnel followed the
 safety procedures  contained in EPA 1440-Occupational Health  and Safety
 Manual  (1986  edition); Agency orders  and applicable provisions of the
 NIOSH/OSHA/USCG/EPA Occupational Safety and Health Guidance Manual.

      At the end of each day, Task Force samples were packaged and shipped
 to either of two EPA contract laboratories or the NEIC laboratory, according to
 applicable Department of Transportation (DOT) regulations (49 CFR Parts 171-
 177).  IT personnel were given receipts for all samples collected.  Task Force
 chain-of-custody procedures were followed during the handling, transfer, and
 shipping of all samples.

      Following collection  of all ground-water samples, Versar installed ISCO®
 meters to continuously record water levels in each of the four monitoring  wells
 chosen [Table  6].   These wells were chosen  by the Task Force for  their
 proximity to the levee along a tidal reach  of Walnut Creek, and represented the
 highest potential for detection  of tidal  influences, if present.  Although  no
 ground-water level  fluctuations  attributable to tidal effects were identified, if
 present, they could affect  the direction and rate of migration of ground-water
 contaminants associated with waste disposal operations at the IT facilities. The
 procedures listed  below were  followed  when assembling,  calibrating, and
 operating the ISCO water level meters.

      1.    Versar personnel assembled the ISCO meters using Model  1870
            meters and 1/4-inch ID (inside diameter) stainless steel tubing.
®    ISCO is a registered trademark and will appear hereafter without .

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                                                               33
                           Table 6
                 ISCO METER VERIFICATION
Date

6/11
6/12
6/12

6/11
6/12

6/11
6/12
6/12

6/11
6/12
6/12
Time

1140
0945
1300

1141
1255

1254
1009
1225

1332
1013
1235
ISCO
Display
(feet)
WellMW-15
1 .026
1.000*
0.987
Well MW-1Q3
0.502
5.160
WellMW-126
1.000
2.109
2.213
WellMW-127
1.002
1.91
1.998
Water
Level
(feet)

2.97
3.03

13.12
8.38

22.13
20.91

18.24
17.25
           Replaced battery and reset to 1.000 display

2.     The meters were calibrated as follows:

      a.     Chart recorder was set to a speed of 3, 4, or 12 inches per
            hour.
      b.     The bubbler was adjusted to release one  air bubble per
            second.

      c.     The end of the stainless steel tubing was  lowered into a
            graduated  cylinder containing distilled water.  The tip of the
            tubing was moved up and down in the water column while

-------
                                                                     34

                  the LED display on the ISCO meter was calibrated for depth
                  of immersion.

      3.    The tubing was lowered into the well to a depth of approximately
            1/2 or 1  foot below the water surface  as indicated by the ISCO
            calibrated display (0.500 or 1.000, respectively).

      4.    The date, time, and ISCO display were recorded on the strip chart.

      5.    The water level was measured with  the  Interface  Probe  and
            recorded.  The probe was decontaminated  according to the
            procedures identified previously.

      6.    The wellhead was sealed with a plastic bag around both the well
            and the  ISCO meter and taped.  The tape was signed by the
            contractor to verify security between water level measurements.

      7.    Steps 4, 5, and 6 above were repeated daily to verify the accuracy
            of the ISCO meters [Table 6).

      One of the four ISCO meters operated intermittently due to battery failure
and measurements were terminated after 24 hours  because other aspects of
the investigation had been completed.

      The ISCO meters recorded water level fluctuations for approximately a
24-hour period. The wells chosen by the Task Force for water level monitoring
had also  been sampled  and were being developed during the Task Force
inspection. The time period between sampling and periods of development and
installation of the water level recorders was not great enough to  record  any
water level fluctuations except those which can be attributed to water  level
recovery.  No tidal effects were observed.

      The average net annual evaporation rate  for the area in 1984 and 1985
was about 30  to 40  inches.  Prevailing wind  direction is to the south  and
southwest.

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                                                                     35

                         FACILITY DESCRIPTION

 WASTE ACCEPTANCE PROCEDURES - VINE HILL

      The laboratory at  the  Vine  Hill  facility performs the waste stream
 predisposal  and truck receiving analyses as well  as monitoring  onsite
 treatment/disposal processes.  Equipment is available for taking samples of
 incoming waste loads as well as for conducting the required determinations, as
 specified in the Waste Analysis Plan.

 Pre-Acceptance

      Prior to accepting  a waste  load for  storage/treatment/disposal,  IT
 personnel obtain a representative sample of each candidate waste stream and
 submit it to the Vine  Hill laboratory for physical and chemical characterization.
 All pre-acceptance analytical results are reviewed by the laboratory supervisor
 for acceptable quality control results.  The pre-acceptance information is used to
 (1) determine whether or not Vine Hill can  handle the waste and (2) compare
 the analytical results from any truck load  to ensure that the waste actually
 received is the same as that approved during the pre-acceptance evaluation.
 When a waste stream is accepted for handling at Vine Hill,  it is assigned a
 waste stream number and each load of the waste is identified by that  waste
 stream number. In this way, IT can control the wastes it receives and determine
 that  wastes  that cannot  be  handled (PCBs  and reactive,  waste)  are not
 accepted.

      The  March 14, 1983 DOHS-approved Vine Hill Waste Analysis Plan
 (WAP)' indicates that at a  minimum pH, normality, density, phase distribution,
 and hydrocarbon vapor pressure (HCVP) are determined on all pre-acceptance
 samples.  These determinations are necessary to obtain a base characteriza-
tion upon which the analytical results from truck loads will be matched to verify
waste identification.   Additional analyses may be conducted, based on identi-
fied characteristics and generator-supplied information, and may include flash-
point, sulfide, cyanide, phenols, and metals.  All oils are reportedly  screened for
    A part of the DOHS-Approved Operations Plan

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                                                                      36

 PCBs and priority pollutant metals.  Fluoride is also reportedly determined on all
 acidic waste to preclude unknown acceptance of hydrofluoric acid, an extremely
 hazardous waste, as  defined  by 22 CAC, Article 11, Sections 66717 and
 66720.

      Pre-acceptance analytical results are recorded on the Hazardous Waste
 Disposal Evaluation form (HWDE) and put together with other information  on
 the waste supplied by the generator (customer evaluation form)  to form the "Job
 Jacket." Job jackets are maintained in the  data processing section of the
 laboratory  near the  truck receiving station.   Normally, the  pre-acceptance
 procedure requires 2 weeks for completion.  On occasion, trucks will arrive with
 loads without the required  pre-acceptance  analyses.  In these cases,  an
 analysis is conducted while the truck waits.  The analysis normally takes about
 4 hours.

 Truck Receiving

      Upon  arrival  of  a waste  load  at  Vine  Hill, verification  of  waste
 characteristics and initiation of a waste tracking process begins.  The shipping
 manifest is turned over to the facility and the truck driver assists in sampling the
 waste (usually opens the tank truck hatch).  The HWPE form from the "Job
 Jacket"  is attached to the manifest and the forms and samples  are given to the
 laboratory personnel  for analyses.  The WAP  requires that the laboratory
 conduct pH, normality, density, phase distribution, and HCVP on these samples.
 Also,  all samples with an organic phase are required to be distilled to identify
 heavier-than-water solvents (usually chlorinated).  Additional analyses, such  as
 metals and spot tests for cyanide, sulfide, and phenols, are conducted  as
 deemed necessary by IT. Analytical results of truck loads are  recorded on the
 Disposal (or Treatment/ Disposal) Location forms.

WASTE TRACKING

      Waste  characterization before  receipt at  a TSDF  and tracking after
receipt are required under both RCRA and State interim  status regulations.
These are important  in determining the constituents that could potentially  be
released from waste  handling  units.  To determine whether IT sufficiently

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                                                                    37


 characterizes  waste it receives and records the disposal location, the Task
 Force reviewed the preacceptance and tracking records for 41  waste loads
 received in either October 1986 or January 1987.


      The records  review indicated that waste acceptance procedures  are
 adequate.  However, Tank Treatment Processing Records are often incomplete.
 No records are kept for several of the tanks and waste loads can often only be
 tracked to their initial unloading  stations.   IT  has entered into a consent
 agreement, dated April 1,  1987, with the State to improve its operating record.


 WASTE HANDLING  UNITS AND FACILITY OPERATIONS


 VINE HILL


      The Vine Hill facility  is a hazardous waste treatment, storage, and
 disposal facility currently using the following waste management units and
 processes [Figures 2 and 4].

            Container storage area - storage of laboratory waste
            Surface impoundments - storage, treatment, disposal
            Tanks - storage, treatment
            Incineration - treatment
            Centrifugation - sludge treatment


      The Baker facility only has surface impoundments.


      Waste materials received at Vine Hill are normally the by-products of
chemical and  manufacturing processes, predominantly  from the following
industries.

            Petroleum products
            Ferrous and non-ferrous metals
            Electronics equipment and components
            Resins, paints and pigments
            Pharmaceutical
            Food processing
            National defense

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FIGURE  4   VINL
THLATMtNT PLANT PLAN
                                                                  ca

-------
                                                                     39

            Metal finishing
            Photo processing
           . Analytical laboratories

      Spill cleanup residue and liquid from the surface impoundments of  IPs
Panoche (formally Benecia) landfill are also handled at this facility.

      Primary treatment processes used at Vine Hill include:

            Cyanide, sulfide, and organic material  (phenol, cresol, formal-
            dehyde, etc.) oxidation
      •     Heavy metals precipitation
      •     Acid-base neutralization  (pH adjustment)
            Solids/oil/water separation
      •     Chromium reduction
            Odor reduction
            Steam stripping
            Incineration
      •     Sludge dewatering (centrifugation and evaporation)
      •     Liquid waste  reduction (evaporation)

      In the fall of 1985,  IT purchased land immediately south of the facility
known as the  "Acme  Property."   The area, formerly owned by Acme  Fill
Corporation, had four surface impoundments (Acme  Ponds).  IT personnel
indicated that, except for the fact that scrap material had been stored there, they
had  no  additional information  about  the past use of this area.   Although IT
indicated they are  not currently using this  property, IT has cleaned up  scrap
material and graded  some of  the land. Closure of the former Acme Property
Ponds is included in the proposed modernization plan for the Vine Hill facility.

      Prior to 1960, Acme used this property for disposal of industrial and
sanitary wastes. The property was leased  to IT in 1960 to use in conjunction
with the Vine Hill facility.  There was an enhanced potential for vertical migration
of contaminants through  the bay mud to the ground water because  the
impoundments were unlined.  In 1970, IT stopped adding wastes to the Acme
property impoundments.

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                                                                     40

       As indicated earlier, IT treats, stores, and disposes of hazardous waste in
 containers,  surface impoundments, tanks, incinerator, and/or by centrifuge at
 the  Vine  Hill facility.   Following is a discussion of the various management
 areas and their operation.

 Container Storage Area

       The IT Vine  Hill container storage area is located on a concrete pad
 inside a  concrete bermed tank containment  area located  near surface
 impoundment 100. It is reported by IT to be used only  to store laboratory waste
 such as spent solvents generated onsite prior to offsite disposal or, rarely as a
 drum  accumulation area  until the containers  can be  emptied  into the
 appropriate  surface impoundment or tank.  Drums are stored on pallets within
 this 3-foot-high bermed area.

 Surface Impoundments

       All  surface impoundments at  both Vine Hill and  Baker are unlined.
 Wastes placed in these impoundments  include  solvents, metals,  phenols,
 cyanide,  sulfides, organics, and other  waste  placed in them for  solids
 separation and/or solar evaporation. Waste is also often pumped from pond to
 pond and all of the impoundments at  both sites  have contaminated ground
 water.

      Vine Hill Facility

      IT currently operates seven unlined surface impoundments* at Vine Hill
for waste storage, treatment, and disposal, as described in Table 7.  Five
additional  inactive impoundments are also described.  An  eighth unit,  102B,
was  used until  about October 1984 when it was filled in and covered with
gravel. According to IT, the area was being retained as a "support facility for
    IT refers to its surface impoundments as ponds and designates them 100 through 106.

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        Table 7

SURFACE IMPOUNDMENTS
     Vine Hill Facility

1
2
3
4
5
Surface
Impoundment
Number
100
101
102A
102B*
103*
104
105
106
201 5
202^
203^
2045
Surface Calculated
Area Depth 1
(acres) (feet)
0.606 9
10.727 9
1.104 8
1.7 6
0.292 8
1.585 10
0.507 8
0.341 9
0.6 7.9
0.7 8.1
1.4 5.6
3.5 5.7
TOTAL CAPACITY
(not including 1 02B)
Capacity2
(gallons)
1,383,109
24,467,612
2,158,338
3,300,000
570,305
4,082,919
990,607
777,314
34,400,000
General
Use Category
Lead containing sludge
General oily/aqueous
waste
Recoverable oily waste
Oily sludges/sludge
dewatering
Acids and bases; low
solids waste
Oil/water mixture
High solids waste
Aqueous; no oils, low
solids waste (Baker
feed)
Inactive
Inactive
Inactive
Inactive
Calculated from given surface area and capacity, includes operating freeboard.
Capacity represents maximum liquid/sludge volume maintaining 2 feet of freeboard.
This impoundment was filled between October 1984 through May 1985.
Pond 103 is reportedly maintained with 4 feet of freeboard to serve as containment for tank 24.
Information concerning these impoundments is from the IT Preliminary Hydrogeological
Assessment Report dated June 1987. ywwy«*«

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                                                                      42
 above  ground  treatment  and  storage"  during  the  1986  NEIC-RCRA
 investigation, which  included  RCRA compliance  other than ground-water
 monitoring."  However, a September 10,  1984 letter from IT to the California
 DOHS indicated the impoundment was "being  converted from functioning as
 direct receipt and storage of materials, to a service of acting as a containment
 structure for additional tankage for plant modernization."  The area was being
 used only for vehicle parking during the Task Force inspection.  The unit (102B)
 was not closed  under an  approved RCRA  closure  plan and DOHS  had
 requested additional information from IT. Similarly, IT has altered  several other
 impoundments without DOHS1 approval, as will be discussed on  the following
 pages.

      The Vine Hill surface impoundments, except for 101  and  former Acme
 impoundments 203 and 204 have a diked northeast side,  and  are basically
 excavations into the area fill.*  The units, except for 102A which is apart from the
 others, are separated by internal dikes of varying widths.  The  interior  walls of
 the units, and some  of the tops of the separation berms,  do not  have any
 protective covering. The outside of the northeast dike of impoundment  101 did
 have vegetative cover during the Task Force inspection.

      IT indicated that impoundments 102A and 101 were  reduced in size in
 May/June 1985 and sometime in 1981, respectively.  This was accomplished by
 placing  and compacting fill  into the impoundments;  sludge/liquid was not
 removed, only compacted/displaced by the added fill.  IT did not report these
 changes to any regulatory agency. A chronology of  impoundment construction
 events for both Vine Hill and Baker is presented in Table 8.

      IT reported that the area  of impoundment  101, an  extension called
 "Charlie's Alley,"  was filled  to "provide mobilization support and storage in
connection with site drilling operations."  During the NEIC inspection, this area
was used for  storage of out-of-service tanks, raw treatment chemicals,  and
     This inspection included review and evaluation of: (1) past and present waste handling
     units and procedures, (2) onsite laboratory procedures, plans and documenttion for waste
     pro-acceptance, identification and verification, (3) selected waste tracking and disposal
     records and documents, and (4) selected facility inspection and personnel training records
     and the facility inspection and training plan.
     The site was previously used as a landfill.

-------
                                                                 43


 miscellaneous equipment.  No further information was available  for these
 "filling" activities.

                               Table 8
           CHRONOLOGY OF IMPOUNDMENT CONSTRUCTION

 Site Plan
    or
 Air Photo
    Date              Vine Hill and Baker Treatment Complex Status

 10-08-52      No impoundments
 05-04-57      Impoundment 102 in place
 07-21-58      Impoundment 104 now in place
 06-08-59      Impoundment T-1 now in place
 07-16-63      Impoundment 101, 105 & 106 (Interconnected) now in place
              Impoundments 201, 202 & 203 (interconnected) now in place
              Impoundments T-5 and T-6 now in place
 08-09-65      Impoundments 204, T-2, T-3 and T-4 now in place
              Impoundments 101, 105 & 106 no longer interconnected
 05-20-69      Impoundment 103 now in place
 09-02-70      No change
 06-04-71      Impoundments 100 now in place
              Impoundments T-2, T-3, T-4, T-5 & T-6 now gone
 03-04-74      Impoundments A (single unit), B and C now in place*
 05-20-76      Impoundment T-1 now gone
              Impoundment 102 divided into 102A and 102B
              Impoundment Area 1 through 4 now in place
              Impoundment E now in place*
 10-10-78      Impoundment D-1 now in place*
 05-15-80      Impoundments 201, 202 & 203 no longer interconnected
              Impoundment A now divided into A-1, A-2, A-3, A-4 and A-5*
              Impoundments D-1 and D-2/D-3 (interconnected) now in place*
 10-22-80      Impoundments D-2 and D-3 no longer interconnected*
              Narrow Arm of Impoundment 101 extending a long south side of
                Impoundment 100 is now gone
 08-03-84      No change
 08-12-86      Impoundment 102B now gone (this impoundment was emptied
                and backfilled with imported fill during the period from October
                1984 to May 1985)

 *   Baker impoundments


      Aerial photographs of the site indicate that 35 feet or more of the  north
portion of impoundment 102A was also filled in between Decembers,  1983

-------
                                                                   44

 and February 22, 1984.  During the Task Force inspection, the area was used,
 at various times, for a roadway and truck parking.  A southern portion of 102A
 was also filled sometime between March 1974 and December 1983.  Current
 (1987)  dimensions for  Vine Hill impoundments  are presented in Table 9.
 Embankment construction materials listed in Table 9 are defined in Table 10.

      Wastes received at Vine Hill for treatment and evaporation  in surface
 impoundments are  normally received in impoundments 102A, 103, 105 or 106
 (102B was also used for direct waste receipts).  From these impoundments,
 waste can  be pumped to any other unit at Vine Hill, as well as to  the Baker
 facility impoundments.  The Vine Hill impoundments are not dedicated  to
 specific wastes or treatment processes but are used interchangeably for storage
 and treatment including  waste dewatering  (evaporation),  waste  phase
 separation, pH adjustment and metals precipitation.  However, as will  be
 described later, some of the impoundments have patterns of "normal" use. The
 high volume of waste receipts necessitates that liquid from the major receiving
 units (impoundments 103, 105, 102A and  106) be moved to impoundments
 101 and 104 as well as to the Baker impoundments  as soon as possible. The
 apparent intent of the Vine Hill impoundments, except for 100 and possibly 101
 and 104, is primary  treatment of the wastewater, while the Baker impoundments
 are used  for final treatment and evaporation.   Table  11  identifies waste
 constituents received in the various Vine Hill surface impoundments and tanks.*

      When sludge in the impoundments accumulates to levels which limit
 liquid  management,  it is  normally  pumped  (submersible  pumps)  to
 impoundment 105 where it is removed and dewatered by an onsite mobile
centrifuge (see Centrifuge Discussion). The centrifuge has also been moved to
some of the other impoundments to remove sludge  directly. IT uses a floating
pump/suction system with a flexible 6-inch pipe to move sludge.

      IT reportedly follows Article 15  (Land  Disposal Restrictions) of the
California Hazardous  Waste Management Regulations  to determine which
incoming wastes are placed  in the surface impoundments and which must be
placed in the tanks.
    From a review of shipping manifests and Disposal Location forms

-------
       TABLE 9

EMBANKMENT DIMENSIONS
VINE HILL IMPOUNDMENTS
Impoundment Embankment
100 a
b
c
d
101 a
b
c
d
e
f
102A a
b
c
d
103 a
b
c
d
104 a
b
c
d
105 a
b
c
d
106 a
b
c
d
Inboard
Height (ft)
13.0
11.6
11.8
10.8
12.0
13.1
12.2
12.5
12.5
11.8
12.5
12.1
12.6
12.0
12.1
13.5
12.3
14.1
13.6
13.7
11.9
12.6
12.4
13.4
12.3
12.1
13.4
13.8
11.5
12.0
Inboard
Slope (H:V)
1.5:1
1.9:1
2.7:1
5.8:1
1.3:1
2.5:1
1.5:1
2.1:1
2.0:1
3.0:1
1.5:1
3.3:1
2.1:1
2.4:1
1.3:1
1.4:1
1.0:1
1.4:1
1.0:1
1.6:1
1.2:1
1.4:1
1.5:1
1.0:1
1.6:1
2.0:1
1.4:1
2.6:1
1.6:1
2.3:1
Outboard
Height (It)
11.9
12.6
0
0
0
10.4
12.9
13.7
13.6
13.8
0
0
0
0
12.3
12.6
0
0
12.5
12.5
13.0
13.5
11.5
11.9
12.1
0
0
11.8
12.4
0
Outboard
Slope (H:V)
1.2:1
1.9:1
2.1:1
1.9:1
1.6:1
1.0:1
2.6:1
-
-
1.6:1
1.4:1
2.0:1
2.1:1
1.5:1
1.4:1
1.6:1
1.7:1
1.3:1
3.0:1
1.5:1
-
Length (ft)
280
130
280
130
630
650
480
530
200
110
170
240
150
250
100
120
120
150
200
320
240
350
160
200
100
170
150
120
150
130
uses
Symbol
CL.SP.GP.GM.GC
ML.SC.GP.CL
SC.CL.SM.CH
CL.GC.SM.GP
CL.ML.SW.GW
CL.SC.CH
CL.SM.GP.GC.SP.GW
CL.SC.SM.ML.CH.GP
CL.GC.SM.SC.ML
GC.SM.CL.GM
CL.GC
GC.SM.ML.CL
ID
\ 1
SM
SC.GP.SM.CL
CL.GC.SM.GP
CL.GP
SC.GP
CL.GC.SM.SC.ML
CL.SC.SM.CH.ML
CL.SP.GP.GM.GC
CG.CL.SM.CH
GC.SM
CL.SM.CH.GC
SC.GP.SM.CL
SC.GP
ML.GC.GP.CL.GM
GC.SM.ML.GP
GC.SM
ML.GP

-------
     TABLE 9 (cont.)
EMBANKMENT DIMENSIONS
 VINE HILL IMPOUNDMENT
Impoundment'
201

202

203
204
Embankment1
a
b
c
d
a
b
c
d
a
b
c
d
a
b
c
Inboard
Height (ft)
9.3
5.5
5.9
6.9
10.0
5.9
8.3
7.1
12.9
10.6
8.2
6.8
8.5
9.8
10.6
Inboard
Slope (H:V)
1.9:1
2.5:1
3.0:1
2.6:1
2.0:1
3.3:1
1.5:1
2.1:1
1.9:1
2.1:1
1.9:1
1.9:1
1.8:1
2.1:1
1.7:1
Outboard
Height (It)
0
7.1
8.7
0
11.4
6.8
9.7
5.5
12.2
4.5
8.5
5.9
8.2
6.3
0
Outboard
Slope (H:V)
2.1:1
2.9:1
2.7:1
1.9:1
1.8:1
2.5:1
1.5:1
5.6:1
1.8:1
3.3:1
1.9:1
2.0:1
Length (ft)
250
190
120
250
220
190
190
190
310
180
330
190
640
500
750
uses
Symbol
SC.CL.ML.GM.OH
(/)
SW.CL.ML
SW.GM.CL.ML
SM.CL.GP.SP
(r)
OH.SM
d)
CL.SM.GC.GW.SC
CL.ML.SM
OH.SM.CL
(1)
OH.SW.SM.CL
CL.SM.ML
CL
                                                                      en

-------
                                                                              47
                                 Table 10
              UNIFIED SOIL CLASSIFICATION SYSTEM CHART
Clean gravels
(little or.no fines)
                            Coarse-Grained Soils

                        GW     Well-graded gravels, gravel-sand mixture, little
                                or no fines

                        GP     Poorly-graded gravels, gravel-sand mixtures,
                                little or no fines

                        GM     Silty gravels; gravel-sand-silt mixtures

                        GC     Clayey gravels; gravel-sand-clay mixtures

                        SW     Well-graded sands, gravelly sands, little or no
                                fines

                        SP     Poorly-graded sands, gravelly sands, little or
                                no fines

                        SM     Silty sands, sand-silt mixtures

                        SC     Clayey sands, sand-clay mixtures
Gravels with fines
(appreciable amount
of fines)

Clean sands (little
or no fines)
Sands with fines
(appreciable amount
of fines)
                     Fine-Grained/Highlv Organic Soils

Silts and clays          ML    Inorganic silts and very fine sands, rock flour,
liquid limit                     silty or clayey fine sands
(less than 50)
                       CL    Inorganic clays of low to medium plasticity,
                              gravelly clays, sand clays

                       OL    Organic silts and organic silty clays of low
                              plasticity

                       MH    Inorganic silts, micaceous or diatomaceous
                              fine sandy or silty soils

                       CH    Inorganic clays of high plasticity, fat clays

                       OH    Organic clays of medium to high plasticity,
                              organic silts

                       PT     Peat, humus, swamp soils with high organic
                              contents
Silts and clays
liquid limit
(greater than 50)
Highly organic
soils

-------
                                                  Table 11

              INCOMING WASTE CONSTITUENTS RECEIVED IN VINE HILL HAZARDOUS WASTE UNITS'
                                                                48
  Pond 102S
  Aluminum hydroxide
  Aluminum phosphate
  Animal fat
  Caustic
  Detergent
  Diesel
  Gasoline
  Lead
  Lubricant
  Machine coolant, oil base
  Metal sludge
  Mud
  Oil
  Paint waste
  Silicate
  Sludge
  Solvent
  Solvent (kerosene based)
  Soybean oil
  Water

  Pond 1Q2B
 Ammonia
 Boiler Wash Sludge
 Boron
 Cadmium
 Calcium chloride
 Carbon
 Caustic liquid
 Chlorine
 Chromium
 Copper
 Corrosive liquid
 Cyanide
 Diesel
 Ferric chloride
 Latex polymer paint
 Lead
 Lime sludge
 Mud
 Nickel
 Oil
 Oil/water separator sludge
 Phosphorous
 Potassium permanganate
 Selenium
 Silver
 Sodium hydroxide
 Sulfur
 Tin
 Vanadium
 White glue (PVA resin)
 Zinc

 Pond 103
Acetic acid
 Acetone
 Acrylic paint thinner
 Alkaline cleaners
 Alkaline liquid
 Alkaline salts
 Aluminum
 Aluminum sulfate
 Amines
 Ammonia
 Ammonium bisulfate
 Ammonium bromide
 Ammonium citrate
 Ammonium feme EDTA
 Ammonium fluoride
 Ammonium hydroxide
 Ammonium thiosulfate
 Anthraquinone-2,6-disulfonic acid
 Antimony
 Arsenic
 Barium
 Bentonite
 Benzene
 Biodegradable soap
 Bismaleimide
 Brine
 Butoxyethanol
 Butyl carbitol
 Cadmium
 Calcium carbonate
 Calcium fluoride
 Calcium hydroxide
 Carbitol
 Caustic brine rinse
 Caustic soda
 Chloroform
 Chlorine
 Chromate
 Chromium
 Cobalt
 Copper
 Copper chloride
 Copper hydroxide
 Copper oxide
 Copper sulfate
 Cyanide
 Cyclohexanone
 Detergents
 Diazinon
 1,2-Dichloroethane
 Diesel
 Dyes (unspecified)
 Ethanolamine
 Ferrous hydroxide
 Ferrous sulfate
Fertilizer
Fluorides
Formaldehyde
Formic add
 Freon
 Galluim arsenic
 Gasoline
 Gravel
 Hydrochloric add
 Hydrazine
 Hydrofluoric acid
 Hydrogen peroxide
 Hydroquinone
 Hydroxzyacetic acid
 Ink sludge
 Inorganic salts
 Iron
 Iron phosphate
 Isodecanes
 Isopropyl alcohol
 Kerosene
 Lacquer thinners
 Latex emulsion
 Lead
 Lead chloride
 Lignon sulphonate
 Lime
 Manganese
 Mercaptan
 Mercaptoaniline
 Mercury
 Methanol
 Methylene chloride
 Methyl ethyl ketone
 Molybdenum
 Monoethanol amine
 Mud
 Muriatic acid
 N-butyl acetate
 Neutral salts
 Nickel
 Nickel hydroxide
 Nitrate
 Nitric acid
 Nitrilotriacetic
 Nitrosodimethylamine
 Oil
 Oil sludge
 Organic bases
 Paint
 Paint skins
 Paint sludge
 Paint thinners
 PCBs (<50ppm)
 Permanganate
 Petroleum solvents
 Phenols
 Phosphates
Phosphoric acid
Phosphorous acid
Polymer solids
Potassium
     Only includes those wastes directly off-loaded into units.  Does not account for waste pumped from other areas
     within the IT facility.

-------
                                                                                                      49
                                               Table 11 (Cont.)

              INCOMING WASTE-CONSTITUENTS RECEIVED IN VINE HH L HAZARDOUS WASTE UNITS*
 Potassium ammonium
 Potassium hydroxide
 Pyroph'osphate
 Rust and scale
 Silica
 Sodium chromate
 Sodium chloride
 Sodium ferrocyanide
 Sodium hydroxide
 Sodium hypochlorite
 Sodium nitrate
 Sodium nitrite
 Sodium sulfate
 Solvents
 Sugar
 Sulfides
 Sulfite
 Sulfur
 Sulfuric acid
 Surfactants
 Tallow
 Tetrachloroethylene
 Thimersal
 Titanium
 Toluene
 Trichloroethane
 Triethanolamine
 Turbine fuel
 Unspecified alcohol
 Vanadium
 Vanadium pentoxide
 Water
 Xylene
 Zinc
 Zinc chloride
 Zinc sulfide sludge

 Pond 105
 Acetic acid
 Acrylic latex paint
 Acrylic resin
 Activated carbon pellets
 Alkaline cleaning compound
 Alkaline sludge
 Alkaline water
 Almond oil
 Alodine sludge
 Aluminum
 Aluminum hydroxide
 Aluminum oxide
 Aluminum phosphate
 Ammonia
 Ammonium iodine
Animal fat
Antifreeze
Arsenic
Barium
Bentonite
 Bismaleimide
 Bleach
 Bordens glue
 Butyl alcohol
 Butyl carbitol
 Cadmium
 Calcium
 Calcium carbonate
 Calcium chloride
 Calcium fluoride
 Calcium hydroxide
 Carbon
 Casein
 Caustic soda
 Chlorides
 Chromium
 Clay
 Cobalt
 Copper
 Copper chloride
 Copper hydroxide
 Copper oxide
 Copper sulfate
 Cresol
 Detergent
 Diesel
 Diesel soaked sawdust
 Enamel paint
 Ferric chloride
 Ferrous sulfate
 Fluoride
 Fluoride salt
 Formaldehyde
 Gasoine
 Glue
 Grease
 Hydrated alumina sludge
 Hydraulic fluid
 Hydrochloric acid
 Iron
 Iron hydroxide
 Kerosene
 Latex paint
 Lead
 Lead chloride
 Lead hydroxide
 Lead oxide
 Lime sludge
 Machine coolant, oil base
 Mercaptans
 Mercury
 Metal sludge
 Mineral oils/spirits
 Molasses
 Molybdenum
Monoethanol amine
Mud
Neutralized acids in lime sludge
 Nickel
 Nickel hydroxide
 Nitrates
 Nitric acid
 Oil
 Organic compounds
 Organic pigments
 Oxalic acid
 Paint sludge
 Paint thinners
 Paper pulp
 Phenols
 Phosphoric acid
 Polyvinyl alcohol
 Pulp slurry
 Rosin resin
 Silane (silicon tetrahydride)
 Silicon
 Silver
 Soda Ash
 Sodium androxide
 Sodium bisulfate
 Sodium hydroxide
 Sodium phosphates
 Sodium sulphate
 Solvents
 Starches
 Styrofoam
 Sugar
 Sulfates
 Sulfides
 Sulfur
 Sulfuric acid
 Tin
 Tin sulfate
 Titanium dioxide
 Trimsol
 Unspecified  volatile residue
 Vanadium
 Vanadium pentoxide
 Villin black liquor
 Water
 Waterbase ink
 Waterbase paint
 Wax emulsions
 White glue (PVA resins)
 Zinc
 Zinc chloride
 Zinc phosphate
 Zinc sulfide

 Pond 106
Alkaline cleaner
Ammonia
Ammonium fluoride
Cumene  hydroperoxide
Grease
Hydrofluoric acid

-------
                                               Table 11 (Cont.)

              INCOMING WASTE CONSTITUENTS RECEIVED IN VINE
                                                                                                     50
                                HAZARDOUS WASTE UNITS'
 Mercury
 Oil
 Organic peroxide
 Polyglycol
 Sludge (unspecified)
 Sulfolane (tetramethylene sulfone)
 Sulfur
 Water

 Tankl
 Acetic acid
 Alodine
 Amines
 Ammonia
 Ammonia hydroxide
 Ammonium fluoride
• Ammonium persulfate
 Arsenic
 Boric acid
 Cadmium
 Caustic
 Chromic acid
 Chromium
 Copper
 Copper sulfate
 Ferric chloride
 Fluoroboric acid
 Fluoride
 Hexavalent chrome
 Hydrochloric add
 Hydrofluoric acid
 Iron
 Iron phosphate
 Iron sulfate
 Lead
Lead fluoborate
Metals
Molybdenum
Nickel
Nitric add
Nonchlorinate solvent
Paint sludge
Paint waste in water
Palladium
Phosphoric acid
Photo chemicals
Polyphpsphoric acid
Potassium persulfates
Sodium ash
Sodium carbonate
Sodium chloride
Sodium dichromate
Sodium hydroxide
Sodium nitrate
Stannous chloride
Sulfamic acid
Sulfonic acid
Sulfuric acid
 Thiourea
 Tin
 Tin fluoroborate
 Toluene
 Zinc sulfate

 Tank 2
 Accelator
 Acetic Add
 Alkaline water
 Aluminum
 Ammonia
 Ammonium fluoride
 Ammonium persulfate
 Arsenic
 Bleach
 Cadmium
 Chromates
 Chromic acid
 Chromium
 Chromium trioxide
 Cobalt
 Copper
 Copper sulfate
 Electro-polish solution
 Ferric chloride
 Fluoroboric add
 Gallium arsenic
 Hydrochloric add
 Hydrofluoric add
 Iron
 Lead
 Nickel
 Nitric acid
 Potassium dichromate
 Selenium
 Sodium dichromate
 Sodium hydroxide
 Sutfite'3 (a Betz product)
 Sulfuric add
 Zinc

 Tank 11
 Acetic add
 Acetone
 Alpha olefln
 Agricultural fertilizer
 Alcohol
 Ammonia
 Ammonium fluoride
 Brine
 Cadmium
 Casein
Caustic soda
Chromium
Dicyctopentadiene
Diemethyl silixane
Diesel
 Enamel paint
 Epoxy acrylate sulfate
 Ethylene glycol monoethyl ether
 Fuel oil
 Gasoline
 Hydrofluoric acid
 Iron
 Isopropanol
 Jet fuel •
 Lead
 Methanol
 Methyl ethyl  ketone
 Naptha
 N-butyl acetate
 Nitrosohexamethyleneimine
 Oil
 Paint thinner
 PCB (<50 ppm)
 Phenols
 Rust and scale
 Silver
 Soap
 Sodium hydroxide
 Sodium nitrate
 Sodium sulfate
 Solvents
 Sulfuric add and lime
 Tetraethyl lead
 1,1,1-trichloroethane
 Unspedfied coolant
 Wastewater (unspecified)
 Zylene
 Zinc

 Tank 12
 Acetone
 Alcohols (unspecified)
 Alkaline detergent
 Ammonia
 Aniline
 Benzene
 Butanol
 Caustic soda
 Chromium
 Combustible liquid
 Copper
 Diesel
 Dipropylaniline
 Formaldehyde
 Gasoline
 Glycol
 Hydrochloric add
 Inks
 Isopropanol
JP-4 fuel
Kerosene
N-butyl acetone
Nitric add

-------
                                               Table 11 (Cont.)

              INCOMING WASTE CONSTITUENTS RECEIVED IN VINE HILL HAZARDOUS WASTE UNITS'
                                                                                                     51
  Oil
  Oil sludge
  Paint sludge
  Paint thinner
  Phenol
'  Phosphoric acid
  Rust and scale
  Silver
  Sludge (unspecified)
  Sodium acetate
  Sodium fluoride
  Sodium hydroxide
  Sodium nitrate
  Solvents (unspecified)
  Sulphuric acid
  Tetraethyl lead
  Unspecified coolant
  Wastewater (unspecified)
  Xylene
  Xylol
  Zinc

  Tank 13
  Acid sludge with metals
  Acids
  Aluminum
  Ammonium persulfate
  Cadmium
  Calcium carbonate
  Carbon
  Caustic (unspecified)
  Chromate
  Chromic acid
  Chromium
  Cobalt
  Copper sulfate
  Fluoroboric acid
  Formaldehyde
  Gasofine
  Grease
  Hydrochloric add
  Hydrofluoric acid
  Iron
  Lactic acid
  Latex emulsion
  Lead
  Lime
  Methylene chloride
  Mud
 Nickel
 Nickel chloride
 Nickel sulfate
 Nitric acid
 Oil
 Phenols
f Phosphoric  acid
 Rust and scale
 Sodium dichromate
 Sodium hydroxide
 Sodium hypophosphite
 Sulfides
 Sulfur
 Sulfuric acid
 Tin
 Vanadium

 Tank 14
 Acetic acid
 Acetone
 Acid sludge
 Ammonium fluoride
 Ammonium nitrate/phosphate
 Ammonium persulfate
 Arsenic
 Cadmium
 Chromic acid
 Chromium
 Cobalt sulfate
 Cresol
 Detergent
 Ethyl acetate
 Ethylene glycol
 Epoxy
 Fluoroboric acid
 Formaldehyde
 Gasolne
 Hydrochloric acid
 Hydrofluoric acid
 Iron
 Isopropanol
 Lactic acid
 Lead
 Machine sump wastewater
 Manganese
 Methyl ethyl ketone
 Methylpyrrolidjnone
 Mud
 Muriatic acid
 Nickel
 Nickel plating solution
 Nickel sulfate
 Nitric acid
 Oil
 Phenols
 Phosphates
 Phosphoric acid
 Printing waste
 Selenium
 Sodium carbonate
 Sodium citrate
 Sodium chloride
 Sodium hydroxide
Sodium hypophosphate
Sodium phosphate
Sodium sulfate
Sulfides
 Sulfuric acid
 Water
 Water-soluble paint
 Wax
 Xylene

 Tank 15
 Ammonia
 Ammonium thiosulfate
 Chromium
 Copper
 Cyanide
 Diesel
 Iron
 Lead
 Mercury
 Nickel
 Phenols
 Potassium cyanide
 Silver
 Sodium copper cyanide
 Sodium cyanide
 Sodium ferrocyanide
 Sodium hydroxide
 Sodium nickel cyanide
 Sodium sulfate
 Sulfite
 Zinc

 Tank 16
 Amines
 Ammonia
 Ammonia hydroxide
 Arsenic
 Carbon
 Chromium
 Copper
 Detergent
 Formaldehyde
 Gasofine
 Grease
 Hatogenated inorganic salts
 of zinc and tin
 Lead
 Nickel
 Nickel sulfate
 Nitric acid
 Oil
 Rust and scale
 Plating waste
 Sodium hydroxide
 Sodium hypophosphate
 Solvents
 Sulfides
 Sulfur
Sulfuric acid
Tank cleaning sludges (sulfides)
Tetraethyl lead

-------
                                               Table 11 (Cont.)

              INCOMING WASTE CONSTITUENTS RECEIVED IN VINE
                                                                                                      52
                                HAZARDOUS WASTE UNITS'
 Vanadium
 Water
 Water-soluble paint
 Zinc

 Tank 17
 Copper
 Cyanide
 Silver
 Water

 Tank 18
 Acetone
 Alcohol
 Algecide and fungicide
 Aluminum
 Ammonia
 Cobalt
 Copper
 Detergent
 Gasoline sludge
 Heavy metals
 Kerosene
 Latex
 Lead
 Leaded gasoline
 Methyl ethyl ketone
 Nickel
 Oil
 Organic Compounds
 Paint
 Paint thinners
 Resin
 Solvents
 Sulfides
 Xylene

 Tank 19
 Acetone
 Alcohols (unspecified)
 Ammonia
 Anilene
 Arsenic
 Brine
 Butyl carbitol
 Butyl cello acetate
 Butyl cellosolve
 Cellosolve acetate
 Chromium
 Detergent
 Diesel
 Epoxy resin
 Ethanol
Gasoline
Hydrochloric acid
Isopropyl alcohol
Mercaptoaniline
Methanol
 Methyl butyl ketone (2-hexanone)
 Methyl ethyl ketone
 N-butyl acetate
 N-butyl alcohol
 Nickel
 Oil
 Organic solvents
 Oxgenated solvents
 Phenols
 Photo-resistant resins
 Pyridine
 Rust scale
 Sodium hydroxide
 Solvents
 Sulfides
 Tetraethyl lead
 Toluene
 Trimethane
 Water
 Xylene

 Tank 20
 Acetone
 Alcohol (unspecified)
 Cresol
 Diesel
 Formaldehyde
 Gasofne
 Jet fuel
 Kerosene
 N-Butyl acetate
 Oil
 Paint residue
 Paint thinner
 Phenol
 Rust and scale
 Sodium hydroxide
 Solvent
 Suifides
 Toluene
 Xylene

 Tank 21
 Acetone
 Ammonia
 Brine
 Carbon
 Cyanide
 Diesel
 Ethyl acetate
 Ethylene dibromide
 Ethylene dichtoride
 Ferrous sulfate
 Flexographic printing waste
Gasoine
Glycol
Hydrocarbon resin
Isopropyl alcohol
 Jet fuel
 Laquer thinner
 Latex paint
 Lead
 Machine sump wastewater
 Methyl  ethyl ketone
 Mineral spirits
 Naphthas
 Nitrosohexamethylenemine
 Oil
 Oil/water vacuum pump waste
 Paint solids
 Paint solvents
 Paint thinner
 Petroleum distillant
 Phenols
 Sodium hydroxide
 Solvents
 Sulfide
 Tars
 Tetraethyl lead
 Tetrahydrofuran
 Toluene
 Unleaded fuel
 Water
 Water-base adhesives
 Water-base inks

 Tank 22
 Gasoline
 Hydraulic fluid
 Oil
 Water

 Tank 24
 Acrolein
 Activated carbon
 Arsenic
 Arsenic sulfide
 Arsenic trisulfide
 Ammonia
 Caustic
 Ethyl glycol
 Rtter aid
 Hydrochloric add
 Methanol
 Nitric acid
 Oil
 Phosphoric acid
 p-picoline
Silicate
Sulfuric acid
Water

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                                                                     53

       Starting in  December 1984,  pH measurements were reportedly taken
 daily of impoundment contents to assist in properly segregating incompatible
 waste. No other routine analytical characterization of impoundment contents is
 conducted Records for 1985 were only 51% complete and for 1986 they were
 67% complete.

       Freeboard  requirements for  the Vine  Hill surface impoundments are
 established at 2 feet or greater by  California Regional Water Quality Control
 Board  Discharge Order 76-68,  California  State regulations  (Article 26,
 Section 67310), the  State-issued  interim status document (issued April 6,
 1981) and Federal interim status regulations (40 CFR 265.222).  Although IT
 requested a waiver from these requirements in August 1984, it had not been
 granted at the time of the Task Force inspection.

       Because these surface impoundments are basically excavations without
 dikes for run-on protection, they receive substantial quantities of rainwater from
 the surrounding facility.  Recently, IT has covered several of the impoundments
 with waterproof covers to collect run-on before  it makes contact with the waste.
 The covers are not removed during warm periods, which impedes evaporation.

      Following is a brief description of each of the impoundments as observed
 during the Task Force inspection.

      Impoundment 1QQ

      Surface impoundment 100 is  used solely for the storage of tetraethyl-
 lead sludge received at Vine Hill between about 1957 and  1970 and collection
 of stormwater runoff.  At least 1 foot of protective liquid  cover is reportedly
 maintained over the sludge by an automatic float valve. When the water level
 drops to about 12  inches, the float drops and opens a valve which adds city
 water to maintain the minimum of 1 foot of water over the sludge.  IT anticipates
 removing this sludge from storage and properly disposing of it in the  near future.

      At the time  of the inspection, this impoundment was covered with a
waterproof cover to prevent run-on to the impoundment.

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                                                                   54

       Impoundment 101

       Surface impoundment  101  is  the  major dewatering (evaporation)
 impoundment at Vine Hill. It receives waste input from the other impoundments,
 as well as from tank processing. An arm of impoundment 101, extending south
 and adjacent  to impoundment 100, known as "Charlie's Alley" was  filled  in
 1981.  This area is currently used to store old tanks, other equipment and drums
 of raw materials.  At the time of the inspection, surface impoundment 101  was
 covered with a waterproof cover to prevent run-on to the impoundment.

       Impoundment 1Q2A

       Impoundment 102A  receives loads of oily waste for phase separation.
 Surface oil is  periodically  skimmed from the impoundment  and sent to the
 adjacent oil reprocessing facility for blending with other oils for resale.  Liquid  is
 also removed from  below  the  surface and pumped  to  other  Vine  Hill
 impoundments for evaporation.  Impoundment 102A was formed sometime
 between March 1974 and December 1983 by dividing a larger impoundment
 (102) into two smaller ones (102A and 102B) by construction of an internal dike.

      Impoundment 102A  was reduced in size  on at least  three occasions
 since it was formed.  IT reported that in May/June 1985 portions had been filled
 in with compacted material. Aerial photographs indicate that at least 30 feet of
 the southeastern portion of the impoundment was filled in sometime between
 1974 and 1983.  This apparently allowed construction of, and access to,  the
 hydrogen peroxide storage area.  A northern portion of at  least 35  feet of
 impoundment 102A was filled in sometime between Decembers, 1983 and
 February 22, 1984.  This filled in area was being used interchangeably for truck
 receiving (parking) and  as  an access roadway during the  1986 NEIC-RCRA
 inspection.  At  the time of the Task Force inspection, this impoundment was
 covered with a waterproof cover to prevent run-on to the impoundment.

      Impoundment 103

     Impoundment 103 is used for direct receiving of low-solids containing
aqueous waste (less than about 10%) and waste from tank treatment.  It also

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                                                                   55

 receives "excess water" (caused by rainwater run-on) pumped from adjacent
 impoundment 100.  The  operation of impoundment 103 was temporarily
 stopped during the 1986 NEIC investigation.  The State required IT to analyze
 sludge and liquid from the impoundment for tetraethyl lead.   A letter dated
 March 20, 1986,  from IT to  the State DOHS, indicated that, although the sludge
 in  impoundment 103 did  contain organic lead, the  aqueous  phases from
 impoundment 103,  as  well as 100,  had less than 10 ppm tetraethyl  lead.
 Operation of impoundment  103 was subsequently continued with the consent of
 DOHS.

       IT also reports that impoundment 103 is the secondary containment for
 tanks  23  and 24 and  indicates  that  a minimum of  4 feet of freeboard is
 maintained on this impoundment for this purpose (see Tank discussion).  Liquid
 level in this impoundment was very low during the  Task Force inspection.

       Impoundment 104

       Impoundment 104 is a major evaporation (dewatering) impoundment at
 the Vine Hill facility.  The unit is not normally used for direct unloading of trucks
 but has received liquid from the tank treatment processes  and adjacent
 impoundment 100.  Liquid  from  any other impoundment can  be pumped to
 impoundment 104 as capacity dictates. At the time of the Task Force inspection,
 this impoundment was covered with a waterproof cover to prevent run-on to the
 impoundment.

      Impoundment  105

      Impoundment  105 normally receives direct receipts  of waste with  high
 solids  content (greater than about 10%) and  sludge from  other  surface
 impoundments. A mobile centrifuge set up to the  west of this impoundment is
used to remove and further dewater the sludge for offsite disposal.  Liquid level
in this impoundment was low during the Task Force inspection.

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                                                                     56

       Impoundment 106

       Impoundment 106 receives aqueous waste directly from trucks and tank
 treatment.  It is normally used to contain liquid just prior to pumping to the Baker
 facility. The centrifuge has been used to dewater sludge from this impoundment
 and centrate from  the centrifuge  operation  is  often discharged to this
 impoundment.

       Impoundments 201. 202. 203 and 204 Former Acme Property (Arme
       Ponds!

       These impoundments are inactive. Some  liquid was in pond 203 during
 the Task Force inspection.  IT plans to construct a  new treatment plant on the
 former Acme  property and  would  close  these  ponds  as part of the
 modernization plan which is subject to approval  by county, State and Federal
 authorities.
Tanks

      During the Task Force inspection, IT reported that they had 15 active
tanks at the Vine Hill  facility used for storage and/or treatment of hazardous
waste [Table 12].  Eight additional tanks are currently out of service (inactive),
many apparently due  to the lack of secondary containment.  Some of these
inactive tanks were used for a solvent recovery operation (distillation), a
solids/or/water separation process, and an  old cyanide treatment operation.
There are also 11 tanks used to store process reagents and fuels [Table 13].
Except for a few exceptions, the hazardous  waste  handling  tanks are not
dedicated to a specific purpose, and thus,  may be used for waste receiving,
storage and/or treatment as capacity and need dictate.

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                                                            Table 12

                                  HAZARDOUS WASTE STORAGE AND TREATMENT TANKS
                                                           IT Vine Hill
Tank
Number
1
2
5
11
12
13a
14a
15
16a
17
18
19
20
21
22
23C
24
_. _ A
25°
26
27
61C
201
251
252
254
255
Approximate
Capacity
(Gallon)
15,282
18,220
10,549
23,018
22,512
22,512
22,512
17,699
17,879
17,879
17,757
17,849
17,879
17,939
17,939
254,672
340,000
8,598
7,200
6,700
493,400
11,780
11,508
10,878
3,192
756
General Use
Waste acid (out of service)
Waste acid (out of service)
Out of service
Waste caustic
Waste caustic
Waste caustic .
Waste caustic
Cyanide treatment
Waste caustic
Cyanide receiving
Waste caustic
Waste solvent
Waste solvent
Waste fuel
Waste fuel
Stripper feed tank
Batch treatment
Waste fuel
Out of service
Out of service
Out of service
Out of service
Out of service
Out of service
Out of service
Out of service
Dimensions
(Dia. and Ht.)
10'0"x26*
10'0"x30'
9Tx22'10"
18'1"x12'
18'0:xinO"
18'0"x11'10"
18'x12'
15'10"x12'1"
15'10"x12'2"
15'10"x12'2"
15'10"x12'1"
15'10"x12'2"
15'10"x12'2"
15'20"x12'2"
15'10"x12'2"
46'6"x20'
42'6"x40t
lO'O-x^'d
9'4"x237"
9'4"x23'7"
49-X351
13.0'6"x12"
9'0"x23'10"
9.0'x22'
6'4"x16'5"
4'2"x9'9"
Shell
Construction
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Mild steel
Lining
Hypalon
Hypalon
None
None
None
None
Americoat 75^
None
Americoat 75
None
None
None
None
Platite
None
None
None
None
None
None
None
None
None
None
None
None
Vapor
Recovery
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Unknown®
No
Yes
Yes
Yes
Yes
b
c
d
e
Tanks 13. 14 and 16 are also used to receive, store and/or treat waste toads containing sutfides. phenols, formaldehyde cresote
mercaptans. etc. and metal precipitation by means of oxidation using 50% hydrogen perooxide.  These tanks are also used for
neutralizing waste acid loads using calcium hydroxide or other caustic (virgin and/or waste) material.
Corrosion-barrier
Note information on tanks 23 and 61 were not included in ITs April 15. 1985 RCRA Part B application submittal.
The April 27. 1984 tank certification indicates that tank 25 is 25 feet in diameter and 10 feet high.
Although IT indicated that this tank was connected to the facility fume incineration system,  the tank certification indicated it is an
atmospheric tank (see text).
en
-vl

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                                                                      58
                                Table 13
                    FUEUREAGENT STORAGE TANKS*
        Tank
       Number
Use
        25A    Diesel fuel (supplemental incinerator fuel)
        D-1     Diesel fuel - for plant equipment
        212    Water storage tank - softened water
        213    Pre-heater tank - softened water
        214    Brine tank - for water softeners
        223    Post scrubber bath - for Phase I incinerator
        203    Alum tank - for oil separator - 5,368 gallons (out of
                 service)
        204    Mixing tanks for NaaS, NaeSaOs, FeSO4 - 500 gallons
        241     Hydrogen peroxide (HaOa) - storage tank - 7,000
                 gallons
        242    HaOa feed tank - 600 gallons
        215A   Caustic holding tank (virgin NaOH) -10,000 gallons

             From April 5, 1985 RCRA Part B completeness check


      General tank treatment processes at IT Vine Hill include:

           Cyanide,  sulfide, and  organic material (phenol, cresol,  formalde-
           hyde, etc.) oxidation
           Heavy metals precipitation
           Acid-base  neutralization
           Chromium reduction
           Solids/oil/water separation
           Odor reduction
      •    Steam stripping


      All of the currently active tanks reportedly vent through an  exhaust fan to
the main (Phase II) facility incinerator.  Negative pressure is maintained on the
tank head space by the fan to assist venting to the incinerator. The incinerator
supplies process heat (steam) back to the treatment facility for steam stripping.


      Tank  treatment  is normally conducted on a  batch  basis  with known
amounts of reagent mixed with the waste. IT reported that, following calculated

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                                                                       59

 times for reaction completion, a waste sample is sent to the laboratory to verify
 that the waste has  been treated below pondable limits.' Although  spot field
 tests can also be conducted to determine the extent of reaction, IT indicated that
 laboratory analyses are always conducted prior to tank discharge.   Following
 treatment and analysis,  waste is discharged to either the onsite Vine Hill surface
 impoundments or the Baker impoundments.  Because many of the tanks  have
 floating suction pumps which cannot pick up the bottom 2 feet of material in a
 tank, some waste from the previous treatment will remain  in the tank after  most
 of the treated waste has been pumped to the impoundments.

      An  operations building, located next to the tank  processing  area,
 contains monitoring equipment and is used as a support and control facility  for
 the treatment plant.

      Prior to unloading a tank truck of waste to a facility tank, the truck driver
 contacts IT personnel at the operations building.  An operator accompanies the
 truck to the appropriate  unloading station and the waste is unloaded.  A copy of
 the Disposal Location form/ filled out by IT to identify and track the  waste, is
 placed on the tank status board in the operations building to identify the  tank
 into which the waste load is received. The tank status board has a set of hooks
 for each tank where the Disposal Location forms are hung.  When  a tank is
 unloaded, the  Disposal  Location forms are removed from the original location
 on the tank status board and either replaced on the board  or correlated with the
 tank and the surface impoundment into which the waste was transferred.

      Waste treatment  in the tanks normally occurs  by recirculating waste
 material in the tank  and injecting  prescribed  amounts  of  reagent into the
 recirculation lines for neutralizing the waste.  Some waste  must be pumped
through several tanks and receive multiple treatments prior  to discharge.  IT
 maintains "Tank  Processing Records" which track some waste movements
between tanks as well as tank discharges to the surface impoundments. IT has
been cited previously for failure to track all wastes more thoroughly.
     'Pondable limits" are reportedly concentrations of specific parameters as identified in
     22 CAC Article 15, Land Disposal Restrictions.
     The Disposal Location forms are completed by the laboratory when the truck is accepted at
     the facility

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                                                                      60
       IT normally uses waste  caustic and  waste acid for pH adjustment;
 however, when waste material is not available, purchased sodium hydroxide or
 hydrochloric acid  is used.  Dry reagents,  such as metal bisulfide for chrome
 reduction; are liquified in mixing tank 240  prior to  addition to. the waste.
 Hydrogen peroxide, used for oxidation reactions is stored in  tank 241 and  put
 into metering tank  242 for measurement prior to contact with the waste.

       Following  is  a  brief description of each tank, and the  associated
 operations.

       Tanks 1 and 2

       Tanks 1  and 2 are  horizontal, hypalon-lined tanks used to receive and
 store acid and chrome waste.  Tank 1 is also used to reduce hexavalent chrome
 to the trivalent state. There are no automatic feed cutoff controls or  high-level
 alarms on these  units to prevent  overfilling.   Available  tank capacity is
 reportedly determined  by maintaining a running total of receipts/removals  on
 the  tank status board in  the operations building and daily manual  level
 determinations of the tanks using a calibrated stick.  Tanks 1 and 2  share the
 same containment area and are set on concrete with no monitoring beneath the
 tanks, although there are daily visual inspections.

       Hexavalent chrome reduction in tank 1 is accomplished  by recirculating a
 metal  bisulfide  solution through  the  tank until the chrome is reduced to the
 trivalent  state.  A  sample is taken to the laboratory and, if analysis  indicates
 satisfactory  reduction (below  the  maximum  level  allowed  in  surface
 impoundments), the waste is discharged to the surface impoundments.  At the
 time of the inspection, tanks 1 and 2 were out of service and had been shipped
 offsite to be relined with a rubber coating.

      TankS

      Tank 5, used for waste acid  receiving  and storage,  has been out of
service, at least since the  NEIC inspection in 1986, reportedly due to lack of
secondary tank containment.

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                                                                       61
       Tanks 11 and 12

       Tanks  11 and 12 are receiving tanks for waste having high levels of
 volatile organic compounds; this is usually alkaline material. Waste is stored in
 these  tanks until pumped to treatment, normally to tank 23 or 24 for eventual
 steam stripping. No formal treatment reportedly occurs in these units. Neither
 tank has automatic feed cutoff control and available capacity is determined by
 daily stick gauging and maintenance of a running tally of receipts/removals.
 These tanks share a concrete containment area with tanks 13 and 14.

       Tanks 13. 14. 16 and  18

       Tanks  13, 14, 16 and 18  receive, store and treat a variety of waste
 usually containing  sulfides, phenols, formaldehydes, creosotes, mercaptans, or
 other organics to  be oxidized.  These tanks can also be  used to neutralize
 acidic  waste  and precipitate metals.  Tanks 13 and 18 are unlined steel tanks
 while tanks 14 and 16 are steel  covered with a corrosion-resistant coating
 (Ameri-coat 75®).

       Tanks 14 and 16 have continuous waste level indicators which read out
 in the  nearby operations building.  Tanks 13 and 18 have Shannon-Jewers®
 floating line level detectors which read out at the tank. IT indicated that none of
 these tanks have high waste level alarms, automatic waste feed shutoff valves
 or pressure and temperature sensors.  Tanks 13 and 14 share secondary
 containment with tanks 15, 17, 19, 20, 21 and 22.

       Organic materials are oxidized and metals precipitated in all four tanks
 by injecting premeasured amounts of  reagents  (hydrogen peroxide, sodium
 sulfide), determined by waste strength,  into the recirculation lines of the tanks.
 Pumps keep the waste circulating through the lines and back into the tanks to
facilitate mixing.  Additionally, tank 14 has a mechanical  agitator for mixing.
Acid neutralization is conducted by one of two methods:   (1) offloading acid
    Ameri-coat-75 and Shannon-Jewers are registered trademarks and will appear hereafter
    without 9.

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                                                                      62

 waste into the tanks, which are reportedly prepared with highly alkaline material
 for protection  of the tank or (2) injecting acid waste from tanks 1  or 2 into the
 recirculation lines followed by subsequent mixing in the tanks.

      Tank 15

      Tank 15 is dedicated  to receive,  store, and treat cyanide-containing
 waste.  The tank is equipped with  a total waste level indicator, with remote
 readout in the operations building, a high-level alarm (audible) and a high-level
 alarm which  automatically closes  the  waste-receiving valves.  Valves  on
 tank 15 are locked  at all times when the tank is inactive.   Tank 15  shares a
 common secondary  containment area with tanks 16,  17, 18, 19, 20, 21 and 22.

      Cyanide is oxidized  in tank 15 with  the  addition  of premeasured
 amounts  of hydrogen peroxide injected into  the tank recirculation  lines.   A
 catalyst, ferrous chloride, is added to  waste that is difficult to treat.

      Tank 17

      Tank 17 is dedicated  to receiving  and storing  of cyanide-containing
 waste.   It is  equipped with an  automatic high/high  level alarm  (audible)
 activated  when the  waste level nears tank capacity.   Waste is pumped from
 tank 17 to tank 15 for treatment.  Tank 17 shares a secondary  containment
 area with tanks 15,16, 18, 19, 20,  21 and 22.

      Tanks 19. 20.21 and 22

      Tanks 19, 20, 21  and 22 are  all receiving  and storage tanks for  waste
 with high concentrations of  volatile organic material to be incinerated  or  steam
 stripped.  Some phase separation of  organics/water/solids occurs in these tanks
 during storage. Waste received and stored in  tanks 19, 20 and 21 is normally
 pumped to tank 22.  Material from the top of tank 22 goes to tank 25 for
 eventual incineration while bottom material from tank 22 is usually pumped to
tank 23 for storage until it can be steam stripped in tank 24.

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                                                                     63
      These tanks all share a common concrete secondary containment area
 with tanks 15, 16, 17 and 18.  None of these units have automatic waste feed
 shutoff valves although tanks 21 and 22 have high-level alarms (audible) for
 overflow protection.   All of the tanks have  Shannon-Jewers float-line  level
 indicators reading out at the tanks.

      Tank 23

      Tank 23 is the receiving and storage tank for waste to be steam stripped.
 This tank normally receives waste from tanks 19, 20 or 21  but can receive
 material  by pumping directly from trucks.  Waste from tank 23 is pumped to
 tank 24 for steam stripping.

      Tank 23 is equipped with a Shannon-Jewers floating-line level indicator.
 There is no secondary containment area surrounding tank 23 and the  area
 immediately surrounding this tank consists of porous gravel and soil,  Leaked
 material  could flow to several areas including north over the process  area
 access roadway to the area of the old impoundment 102B, west into the
 concrete containment area for tanks 15 through  22, and/or east across the
 facility's main roadway and could infiltrate through the ground into underlying
 ground water.  A spill could prevent access to  adjacent tank 24. Information on
 tank23 was  not included in Table  III.2 of IT'S  Aprils, 1985 RCRA Part B
 Completeness  Check submitted to EPA Region IX.   IT  maintains  that
 impoundment 103 provides secondary containment for both tanks 23 and 24.

      Tank 24

      Tank 24 is the steam stripping tank.  It receives waste from the bottom of
 tank 23 and uses steam (from the onsite incinerator) mixed with nitrogen (from
 an onsite storage tank truck) to  strip organics from waste. The  pH of the waste
 can  also  be adjusted in  tank 24  by caustic or  acid  addition.   Following
treatment, the waste is usually discharged to the Baker impoundments.  Fumes
generated from the stripping process are withdrawn by a negative pressure fan
to the incinerator for treatment.  A vent gas oxygen analyzer on the fume gas
collector of tank 24 automatically adjusts nitrogen  input (to the steam) to limit
oxygen concentration in the vent gas to less than about 8% to prevent waste

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                                                                     64

 ignition.  Waste level in tank 24 is monitored continually and automatically with
 readout in the operations building.

       Tank 24 has a high-level alarm (audible) which is activated when waste
 level approaches tank capacity.  If waste level continues  to  rise,  a high/
 high-level detector automatically shuts off the waste feed valve. The tank is also
 equipped with a flame arrester, emergency vents, and automatic steam/nitrogen
 shutoff.

       Tank 24, like adjacent tank 23, does not have a surrounding secondary
 containment area. The area  immediately surrounding tank 24 consists of
 porous gravel and soil. Leaked material would flow over this area spreading in
 several directions including west over the main facility roadway,  eventually to
 impoundment 103 (more  than 100  feet from  tank 24) and  possibly to
 impoundment 100; north over the process area access roadway to  the old
 impoundment  102B area; and east past tank 23  and into the concrete
 secondary containment for tanks 17 through 22 and could infiltrate through the
 ground into  underlying ground waters.  A leak could prevent access to  tank 23
 and to the adjacent nitrogen gas storage tank.

      Tank  25

      Tank  25 is  the waste storage and feed tank to the Phase II incinerator.
 This tank normally receives waste from the top of tank 22. Waste  from  tank 22
 is reportedly sampled and analyzed for waste constituents prior to pumping to
 tank 25.   Tank 25 shares  a concrete containment  area  with tank 25A, the
 incinerator supplemental fuel  (diesel) storage tank, and a fuel feed pump.
 Because the waste feed rate to the incinerator is not continuously monitored, as
 required  by  40 CFR 265.347, periodic waste level determinations in tank 25
 are the only  source of incinerator feed rate information.

      Tanks 26 and 27

      These tanks are no longer in service at IT and have been removed. They
were located just west of tank 24 and were used to store waste for  incineration.

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                                                                      65

       Tanks 30 and 31

       Tanks 30  and 31  were  associated  with  a past cyanide treatment
 (chlorine  addition)  process.  Neither are  currently used for waste  handling.
 Tank 31 was the treatment tank and is currently inactive and empty. Tank 30
 was to be used for cyanide waste storage but was never put into service; it is
 now used to store water as an emergency water supply source.

       Tank 61

       Tank 61  is a large vertical tank located in the northwest portion of the
 site about 15 feet from the western boundary of the IT facility, away from the
 other waste processing units.  As part of the IT Oil Reprocessing facility, it was
 used for  receipt and  storage  of  various waste including those with  high
 concentrations of volatile organics to  be steam  stripped or incinerated,  as
 reported in the 1986 NEIC report.  Waste was pumped between the Vine Hill
 process area and  this tank, as  tank capacity  dictated.   The  secondary
 containment area for this tank consists of a soil/gravel berm of varying heights
 surrounding the tank. A calculation of secondary  containment volume, based
 on  estimated  measurements  of the  bermed  area,  indicates maximum
 containment of less than 3% of total tank capacity.

      Tank 61 was  not represented on the tank status board in the operations
 building and, thus, information on the type and amount of waste in the unit is not
 readily available and apparently not accurately tracked.  Also, freeboard for this
 unit was not noted on the status board or on the daily tank inspection forms.

      Although IT reported that tank 61 was connected with the tank fume
 recovery system at the process plant (and, thus, subject to negative pressure),
the  tank certification of August 25, 1983 [Exhibit E] indicates the tank is under
atmospheric pressure. As a result of a consent agreement between IT and the
State, tank 61 is no longer  in service.

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                                                                      66

       Tanks 251. 252. 254 and 255

       These tanks were used for a solvent recovery operation which is out of
 operation; there is no secondary containment for these units.  All tanks had
 been repaired or replaced and the solvent recovery operation was resumed for
 a short period of time.  At the time of the Task Force inspection, the  solvent
 recovery  system was empty and  not in operation pending approval  by the
 DOHS.

       Temporary Water Collection Tanks

       IT has installed two temporary water collection tanks on the Acme prop-
 erty.  Water collecting on top of covered ponds is tested and, if uncontaminated,
 pumped to the temporary water collection tanks. Contaminated water is placed
 in  tanks  for treatment  or directly into ponds depending  on  level  of
 contamination.

 Incineration

       IT Vine Hill has two  incinerators, a  small 'Phase  I' unit and a larger
 'Phase IP  unit.  While the Phase I  unit can only oxidize limited fumes  (waste
 gas), the larger Phase II  incinerator treats  both fumes and  liquid  waste.
 Currently, the Phase I unit is reportedly used  only when the larger unit is not
 operating.  However, only the Phase II unit has the capacity to handle all of the
 fumes from the tanks and steam stripping in tank 24; IT claimed that the small
 unit is undersized for such operation.

      Phase I Incinerator

      This horizontal, diesel-fueled unit has no temperature controls and little
 information was available regarding its construction. It is piped in parallel with
the larger incinerator and fumes are blown into the unit near the fuel injection
 nozzle.  A packed stack-gas scrubber recirculates  alkaline water to treat
incinerator gas.  No records are kept of incinerator activity although IT reported
that it can normally be assumed that, when the big unit is not operating, the
smaller one  will be manually started and operated  for fume  incineration.

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                                                                       67

 However, IT did indicate that there are times when neither unit is operating. In
 these cases, the vent gas removal system is shut off and tank gas is no longer
 removed.

       Phase II Incinerator

       The Phase II incinerator is the major onsite incinerator. It was built in the
 early to mid-1970's and is used for fume and liquid waste incineration.  A
 tube-type boiler attached to the incinerator captures heat to produce steam for
 the steam stripping operation. Liquid waste is fed to the unit from tank 25  and
 fumes are blown into the incinerator through a manifold near the  waste feed
 injection nozzle at the front end of the unit with a 1,000-cubic-foot-per-minute
 standard blower.

       Based on incinerator  unit blue  prints, this  incinerator is a horizontal,
 single chambered, brick-lined unit with an  inner diameter of about 6 feet
 10 inches and length of approximately 14 feet.  Liquid waste is injected through
 a  multi-orificed air-atomized  burner nozzle at the  front end of the unit.  The
 boiler is attached to the end  of the incineration chamber and is about 14 feet
 long.  Stack gases vent through a 40-foot-high plenum.  There are no stack-gas
 emission controls on this unit. IT reports in their RCRA Part A application that
 the estimated  operating capacity of the unit is 250 gallons per hour.*  Normal
 operating temperature is reportedly between 1500 and  1700 °F.  Electronic
 readout of incinerator  temperature on  March 6, 1986 was 1719 °F.  Startup
 procedures are reportedly as follows.  Diesel fuel is used to raise temperature to
 about 1500  °F.  After about 5 minutes  at steady-state temperature, the waste
 feed supply  is  turned on. The incinerator is reportedly automatically prevented
 from burning waste fuel or tank fumes at temperatures less than about 1200 °F.
 Temperature is reportedly maintained by a series of automatic controls.  High
temperatures cause reduction in waste feed rates, tank fume feed rates and
air/nitrogen mixture injection to tank 24 (to reduce fumes generated by steam
stripping). Temperature probes for incinerator control are located about 12 feet
    IT operating records indicate that waste has been burned at an estimated average rate of 35
    to 40 gallons per hour.

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                                                                     68

 downstream from the burner tip.  This is near the  end of the  combustion
 chamber near the boiler entrance.

       Four continuous monitors relay operating  information regarding plenum
 temperature, stack-gas oxygen concentration, combustion chamber tempera-
 ture and fume gas vent line pressure to a readout board in the operations
 building.  Liquid waste feed rate is  not continuously monitored, although a
 rough  estimate can be determined using changes in waste level in tank 25, the
 waste  feed tank.  Waste levels of tank 25 are only recorded approximately four
 or five times over a 24-hour period while the incinerator is operating.   Liquid
 waste  is incinerated on a semi-batch basis so, when the waste level in tank 25
 gets low, a new batch of waste is pumped in from  the top of tank 22.

       The  waste at various levels in tank 22 is  reportedly  sampled for lead,
 mercury, halogenated compounds, sulfur, and heating value of waste prior to
 discharge to tank 25.  Because waste is  normally blended in tanks 22 and  25
 prior to incineration, the exact time and date of incineration of a particular waste
 load is not known.  Also,  because of this blending, the quality and, thus,
 oxidation characteristics of the waste is not consistent.

 Centrifuoation (Sludge  Dewatering}

       IT uses a mobile centrifuge  to dewater surface impoundment sludge for
 eventual offsite land disposal.  Although the unit has been moved to dewater
 sludges at various  onsite impoundments,  it is normally located adjacent to the
 west side of impoundment 105.   In  this position, it  can treat sludge  from
 impoundments 103, 105, and 106. The centrifuge basically took the place of
 surface impoundment 102B  which  was reportedly used extensively for sludge
 drying.  The centrifuge normally operates 6 days a week, Monday through
 Saturday, 24 hours a day. The unit is operated by IT-Motech, a division of  IT
 separate from the division that operates  the rest of the  Vine Hill facility.
Although  DOHS  reported  that  the centrifuge was   operating  prior  to
 February 24, 1984, the earliest centrifuge  records IT was able to provide  NEIC
were dated  September 1984.

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                                                                      69

       The centrifuge is a flow-through operation.  A submersible pump first
 moves sludge from an impoundment to a grinder (mazorator) to reduce the size
 of sludge particles. The sludge then goes to a variable speed 20-inch-diameter
 centrifuge bowl,  rotating at up to 2,500 revolutions  per minute (rpm),  which
 spins out the liquid or centrate.   The centrate  is returned  to a surface
 impoundment while the sludge cake is continuously  removed by a centrifuge
 conveyor and deposited in a truck for eventual offsite disposal.  Air is  pulled
 through the centrifuge  bowl at about 100  cubic feet per minute  and vented
 through a 2-ton granular carbon filter for emissions control.  An emulsion-type
 polymer can be added  to the  sludge to enhance centrifugation, if necessary.
 The total unit is mounted on a  40-foot truck trailer.  Sludge processing capacity
 is reportedly 250 gallons per minute.

       Information  on centrifuge operating conditions is  recorded on  the
 Centrifuge Operations Log. This includes  sludge  feed rate, bowl speed, oil
 conditions, etc. A Centrifuge Field Analyses Log is used to record information
 on treatment efficiency  (feed solids/centrate solids) and identifies  the surface
 impoundment being treated.   IT reports that there is no sludge sampling to
 determine chemical  and  physical  properties of the sludge,  except for
 determining percent solids of the feed and infrequent pH  measurements.  There
 is no Project Sample Log, as indicated in  the October 15, 1984  Operations
 Plan for this unit.

      Air samples of vent gases are reportedly taken about every 2 weeks with
 Drager tubes to monitor the condition of the  carbon filter. Results are reported
 on one of the  centrifuge logs.  If "detectable  levels"  of phenol  (0.5 ppm),
 benzene (5 ppm), toluene (25 ppm) or hydrogen sulfide (1 ppm) are found, the
 carbon is reportedly changed.

 BAKER FACILITY

      The Baker site is  about 500 feet (across Pacheco Creek) from the Vine
 Hill facility.  It  consists  of a series of  surface impoundments which receive
aqueous waste from Vine Hill as well as directly from generating facilities for
evaporation of liquids.  Waste is transported to the Baker surface impoundments
from Vine Hill via a pipeline.

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                                                                    70

      IT currently operates 11  unlined surface impoundments at the Baker
 facility for solar evaporation of water from effluent pumped from Vine Hill, as
 described in  Table 14.  Four additional unlined  impoundments identified as
 impoundments 1, 2, 3, and 4, located between impoundments C and D-1 have
 been used periodically for waste treatment.  IT would not provide operational
 information concerning Baker because of current litigation concerning the Baker
 impoundments.  Further information is provided in the update to this report.

      The  Baker  surface impoundments,  except for cut-off  walls, keyed fill
 and/or slurry  walls for the east embankment of impoundment D-1, southwest
 corner of impoundment  C,  and portions of impoundments D-2, D-3 and E
 embankments, are levee construction with little excavation.  Some of the levees
 were constructed with Corps of Engineers channel dredgings. The impound-
 ments are separated by internal dikes of differing widths.  The interior walls of
 the impoundments, and some of the tops of the separation berms, do not have
 any protective coverings.

      The following is a brief description of each of the impoundments as
 observed at Baker during the Task  Force inspection.  Ground-water contami-
 nation exists,  as discussed previously.

 Impoundments A-1 through A-5

      Surface impoundments A-1 through A-5 are used routinely as receiving
impoundments at  Baker.  If odor problems are noted, bleach  is sometimes
added by tank trucks to reduce odors.  Waste can  be pumped to any of the
impoundments via  interconnecting  pipelines.  At the time of the inspection,
impoundments A-2 through A-5 were covered with waterproof covers to prevent
run-on to the impoundments.

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                                                                                                         71
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                                                        Table 14 (cont.)
                                                   EMBANKMENT DIMENSIONS
                                                    BAKER IMPOUNDMENTS
Impoundment   Embankment1
 Inboard
Height (ft)
  Inboard
Slope (H:V)
Outboard
Height (ft)
 Outboard
Slope (H:V)
                                                                                             Length (ft)
 uses
Symbol
D-1


D-2

D-3


E

Notes: (1)
(2)
a
b
c
a
b
c
a
b
c
a
b
c
See Figure 4-1
No data available
6.6
6.7
6.8
9.3
9.1
9.4
10.2
9.7
9.9
9.3
8.9
9.5


2.1:1
.1.9:1
1.4:1
2.4:1
1.9:1
2.1:1
4.9:1
1.4:1
2.9:1
3.2:1
1.4:1
2.0:1


10.6
7.8
9.1
7.8
8.0
8.4
7.8
7.1
9.3
9.9
9.2
9.5


1.3:1
2.0:1
1.5:1
1.7:1
1.6:1
2.1:1
1.6:
2.4:
3.2:
2.8:
2.2:
1.9:1


1050
1250
1000
810
700
670
870
750
480
480
620
610


CL
CL
CL
CL.CH
CL.CH
CL
CL.CH
CL
CL
CL
CL.SC.GC
CL


                                                                                                                              ro

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                                                                  73

 Impoundments B and C

      Surface  impoundments  B  and  C are  large  solar evaporation
 impoundments.  At the time of the inspection, several aerators were operating in
 impoundment C.  The aerators can be moved from one impoundment to another
 and are used to help prevent odor problems.

 Impoundments D-1 throuah D-3
      Surface impoundments D-1 through D-3 are used for solar evaporation.
At the time of the inspection, there was a mound of sludge in the corner of each
of these impoundments.  Aerators  were operating in impoundment D-1 and
there was a boom for foam containment in impoundment D-3.

Impoundment E

      Surface impoundment E is normally  used for  solar  evaporation.
However, at the time of the  inspection,  impoundment E was covered with  a
waterproof cover to prevent surface run-on.

Impoundments 1 through 4

      Surface impoundments 1  through 4 are  reportedly used for treatment
impoundment for experiments in odor or foam control.  At the time of the
inspection, there was  liquid in all four  impoundments.   The  liquid  in
impoundment 1 was a deep  maroon color.  IT  personnel  declined to provide
information regarding use of these impoundments because of pending litigation
concerning the Baker site.

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                                                                     74

                         SITE HYDROGEOLOGY

INTRODUCTION

      The  hydrogeological information presented in this report summarizes
data and interpretations derived from IT consultant reports and does not imply
Task Force  concurrence.   Because  of the uncertainties  regarding  well
construction,  hydrogeological site characterization, well testing methods and
duration, and well completion methods, much of the data and IT consultant's
interpretations are questionable.

      The wide range of permeabilities reported for different zones throughout
the facilities  should be considered only as averages  (order-of-magnitude
estimates) for small radii around specific wells and should not be relied upon as
being representative of aquifer characteristics throughout the IT Vine Hill and
Baker facilities.

      To adequately  design and  construct a technically sound integrated
ground-water monitoring system for the IT Vine Hill and Baker facilities, it is
necessary that IT be further required to provide:

      •     Information which establishes credible physical  correlation of
            stratigraphic  units  underlying both  the Vine  Hill  and  Baker
            facilities.  This information  should  include aquifer hydraulic
            response data and interpretations throughout the facilities.

      •     Vertical and horizontal hydraulic communication (or isolation) data
            between  stratigraphic  zones to  establish  the potential  for
            contaminant migration  pathways.  The slug test and pumping test
            data presented by IPs consultants are not adequate to determine
            the  hydraulic interconnection (or isolation) of the saturated
            permeable zones beneath the sites.  Data from longer duration
            pump tests to determine the degree of hydraulic  interconnection
            between aquifer zones should be provided.

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                                                                       75

             Diffinitive  hydraulic head distribution  data to reliably determine
             hydraulic gradients across both the Vine Hill and Baker facilities in
             each of the stratigraphic units present

             Credible points of compliance for each hazardous waste unit for
             both the Vine Hill and Baker facilities

       At the time  of the  Task Force inspection,  IT did not have sufficient
 information available to adequately characterize the hydrogeology of the Vine
 Hill and Baker sites. In August 1987, consultants for IT Corporation submitted a
 hydrogeologic report for the Vine  Hill  and Baker facilities in  response to
 Cleanup and Abatement Order Number 86-014 from the California Regional
 Water Quality  Control  Board, San Francisco  Bay  Region.*  Most of the
 hydrogeological information described in this report is from the October  1987
 revision  of that report.  Information provided in that report is  derived  primarily
 from  logs of borings, test holes, wells, and piezometers drilled between  1978
 and 1987; geophysical and piezocone logs, and aquifer and laboratory tests.

 HYDRQGEOLOGIC UNITS

      The Vine Hill and Baker facilities are located in  Contra Costa County,
 California, in a physiographic province known as the Bay Plain.  The facilities
 are located near the mouth of the Ygnacio Valley, approximately 10,000 feet
 south of Suisun Bay.

      The land surface elevation around  the Vine Hill and Baker  facilities
 ranges from about 0.5 foot [National Geodetic Vertical Datum of 1929 (NGVD)]
to 282 feet NGVD at the top of Vine Hill.  Major water courses near the facilities
include Walnut Creek and Pacheco Creek.  Walnut Creek lies about 500 feet
east of the Vine Hill  facility and is adjacent to the western border of the Baker
facility.  Pacheco Creek, a tributary of Walnut Creek, is  adjacent to the Baker
facility on the western and northern sides.  The confluence of Walnut Creek and
Pacheco Creek is about 50 feet northeast of the Baker facility.  Downstream of
    McCulley, Frick & Oilman, Inc., Hvdrooeoloaic Report. IT Corporation Baker and Vine Hill
    Fadlitios Contra Costa County. California  August 1987, Revised October 1987 Project
    XADGO1.

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                                                                      76

 the confluence, the water course is known as Pacheco Creek.  Both water
 courses are influenced by ocean tides.

      The region around the  Vine Hill and Baker facilities is underlain by
 unconsolidated valley fill of Quaternary age comprising the younger bay mud
 (Qybm*) deposited in the Holocene epoch, and the older bay mud  (Qobm),
 consisting  of estuarine and alluvial deposits of the Pleistocene epoch.  The
 deposits consist of interbedded and interfingered clay, silt, sand,  and gravel.
 Some of the deposits  can  be  correlated over  a broad  area;  some are
 discontinuous.

      In this physiographic  region,  indurated deposits  of  Tertiary  and
 Cretaceous age, known as "bedrock" (Kp) underlie the Quaternary bay mud and
 alluvial deposits. These rocks, including the Panoche and Martinez Formations,
 consist of  sandstone, siltstone,  and/or  shale,  and generally strike to the
 northwest,  dipping steeply to the southwest.  The surface of the bedrock forms
 buried "hills and valleys," over which the Quaternary sediments were deposited.

      Intersecting joint  sets  (fractures  caused  by earth  movements  and
 weathering) have been observed in the Panoche Formation  outcrop west of
 Pacheco Creek.  These  joint sets are  reportedly poorly  developed, but
 potentially  could provide pathways for ground-water flow and contaminant
 migration.

      The  inferred location of the Concord fault is east of the Baker facility
 along the scarp (cliff) on the east side of Walnut Creek.  Right lateral  movement
 along the Concord fault has been observed south of the facilities near Concord,
 California.

      At the  Vine Hill  and Baker facilities the geology may be described as
Quaternary bay mud  deposited  upon the structurally deformed Panoche
     'Informar geologic unit designations used by consultants to IT are:
     Qybm:  Quaternary younger bay mud
     Qobm 1: Upper section of the Quaternary older bay mud
     Qobm:  Quaternary older bay mud
     Kp:     Bedrock (Panoche Formation)

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                                                                      77

 Formation bedrock.  Low hills of the Panoche Formation flank the site on the
 west.

       The contact between the  bedrock and the overlying  bay mud is  an
 "angular unconformity,"  representing  a historical  period  of  erosion and
 weathering of the bedrock prior to deposition of the bay mud. Characteristically,
 portions  of the  upper bedrock  exhibit enhanced permeability  caused  by
 weathering. At Vine Hill, the weathered zone at the top of the bedrock is about
 15 feet thick.

       In  the overlying sediments,  an  unconformity  (erosional  surface)
 separates the Quaternary older bay mud and the overlying younger bay mud.
 These units are characterized by differences in consolidation, grain size, water
 content,  and natural  organic  content  including  peat  beds,  which are
 discontinuous.

       Beneath the Vine Hill and Baker facilities, the older bay mud consists of a
 fining-upward alluvial and estuarine deposit of gravels,  sands, and silty clays.  A
 continuous, firm  silty clay in the upper part of the older bay mud sequence is
 marine in origin and has been informally designated "Qobml."  In the remainder
 of this report, the lower section of the older bay mud is designated "Qobm."

       The Qobm is thicker and more extensive at the Baker facility than at Vine
 Hill.  Maximum thickness of the Qobm is about 180 feet at the north end of the
 Baker facility.  The Qobm contains both an upper and lower sand and gravel
 bed of some lateral extent. The lower sand and gravel bed is thicker, ranging
 up to 45 feet thick, and the upper sand and gravel bed is typically  about 20 feet
 thick.  The upper sand and gravel bed is just below the Qobml  unit.
 Consultants to IT state that these sand and gravel beds, together with minor
 sand  units in the Qybm, are the only units which could be characterized as
 "aquifers," according to the RCRA definition.

      The Task Force hydrogeologists have concluded that the IT Vine Hill and
 Baker  facility sites have not been adequately characterized with  respect to
hydrogeology.  Further, the Task Force concluded  that,  in addition to the
shallow  unconsolidated deposits,  more definition  of  the water  bearing

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                                                                     78
 properties of the upper weathered/fractured bedrock is needed before a
 determination can be  made  as to which  zones are aquifers and how they
 should be monitored. Therefore, ITs consultants' conclusions are untenable.

      The Qobml ranges from 0 to 38 feet in thickness beneath the facilities
 and overlies the Qobm except in isolated areas on the western side of Baker
 and where the Qobm is absent in the area of the bedrock high, which outcrops
 at Vine Hill.

      The Qybm consists of marine to brackish organic clay with sand and peat
 beds of limited extent  Thickness of this unit ranges from 0 feet at the bedrock
 outcrop at the Vine Hill facility to more than 50 feet. The  Qybm contains few
 sand lenses, and  a few sand units occur predominantly along the western side
 of the Baker facility.

      At the surface, some areas of the Vine Hill and Baker facilities have
 received fill material composed of old landfill materials (soils and various types
 of refuse), soil fill placed in old impoundments, and clayey to sandy soils that
 make up the containment dikes around a number of the impoundments.  The fill
 was placed over  the younger bay mud sediments or over  remnants of thin
 outwash sediments deposited by a prior diversion of Walnut  Creek.

 GROUND-WATER FLOW. DIRECTION. AND RATES

      The August 1987 hydrogeologic report does not identify the  uppermost
 aquifer beneath the Vine Hill and Baker facilities for compliance with require-
 ments  in  40 CFR 265.90  and  270.14.  The report does contain hydraulic
 information derived from drilling, boring, and geophysical logs, water level data,
 aquifer tests (slug, packer, and pumping tests) and laboratory permeameter
 tests for the geologic units described.

      The  report states the evaluation of potentiometric (water level) data and
 other hydrogeologic conditions precluded the construction of potentiometric
 maps for the fill, the bedrock or the older bay mud at the  Baker facility. The
ground-water flow direction(s) in these units is poorly understood. The results

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                                                                     79

 of this evaluation do not allow for developing potentiometric head distribution
 maps.

      Water levels and constituent concentrations for wells bordering the IT
 Vine Hill/Acme property  boundary  were compared  to determine  if any
 conclusions could be drawn regarding ground-water flow directions and/or the
 degree of contaminant migration.  The  majority of  water levels cannot be
 compared because the wells are not completed in the same horizons.  The
 remaining data are inclusive.

      Hydraulic conductivities for  the  hydrostratigraphic  units have been
 estimated using slug, packer, pumping and laboratory permeameter test data.
 Representative results of these tests appear in Table 15.

                                Table 15
  MEASURED RANGES OF HYDRAULIC CONDUCTIVITY VALUES (cm/sec)
Hydrostratigraphic
Unit
Fill
Qybm
Qybm/Qobm 1 '
Qybm/Qobm 1/Kp
Qybm/Kp
Qobm 1
Qobm 1/Qobm
Qobm
Kp
Vine Hill
Kv' 2 h
10-8-10-4
10-9-10-6 10-7-
10-6-


10-8-10-5 10-4-

10-8 10-5-
10-7-
Baker
(h5 4

Kv' 2
Kh'
34
10-8-10-4
10-3
10-3


10-3

10-1
10-2
10-9



10-9

10-9
10-9
-10-4



-10-6

-10-2
-10-5
10-7-
10-4
10-4
10-5-
10-4
10-5-
10-5-
10-8-
10-3


TO'4

10-2
10-3
10-3
1   Kvm Vertical Hydraulic Conductivity
2   Permeameter test data
3   Kh • Horizontal Hydraulic Conductivity
4   "Slug" test data (includes ranges of results from pumping tests)
SOURCE: October 1987 revised Hydrogeotogic Report

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                                                                      80

 Bedrock
       According to IT consultants, the structural orientation  (steeply dipping
 beds) and layered sediments of the bedrock precluded drawing equipotential
 lines depicting ground-water levels and flow directions for this unit.  Wells
 drilled into bedrock encountered several stratigraphic horizons.   Hydraulic
 connection or isolation of these horizons has not been adequately determined,
 and adjacent monitoring wells may not be completed  in the same horizon.
 Secondary  permeability from fractures and weathering  of the bedrock may
 influence flow directions and provide for preferential flow paths.  Consequently,
 a potentiometric map may not represent existing conditions.  Flow patterns in
 the bedrock are unknown and flow velocity has not been determined.

 Quaternary Older Bay Mud (Qobm)

       At Vine Hill, the apparent hydraulic gradient across the  facility is toward
 the east-northeast, and the shallow gradient ranges from approximately 0.003
 to 0.007.

       At Vine Hill, the ground-water velocity in the Qobm has been estimated to
 be on the order of 60 to 140 feet per year toward the east.  These figures were
 computed using the formula:

                       :  V = K/P x dH/dL, where:
          **      •      •  *•-  •
        •  *            »- «.     .
               V    = Average linear flow velocity (cm/sec)
               K    = Hydraulic conductivity (cm/sec)
               P    = Effective porosity (dimensionless)
               dH/dL = Hydraulic gradient (dimensionless)

 The estimation assumes a horizontal hydraulic conductivity of 3 x 10'3 cm/sec,
 and an average effective porosity of 0.15.

 Quaternar  Younger Ba  Mud
      At Vine Hill, a ground-water mound may exist near piezometer TB-513,
where relatively high water levels were measured.  Potentiometric levels in the

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                                                                     81

 Qybm at this facility are highest along the northern boundary and decrease to
 the east-northeast and south.

       The potentiometric elevations in the older bay mud at Baker show very
 little gradient and no perceptible sustained flow pattern; therefore, consultants
 to IT conclude that ground-water flow conditions in this unit are stagnant.
       The ground-water flow velocity in the Qybm at Vine Hill has been
 estimated to be about 5 to 6 feet per year.

       The potentiometric elevations in the younger bay mud at Baker show that
 ground-water mounding exists beneath impoundments B, C, and D-1 .  Smaller
 mounds may be present beneath impoundments D-2 and D-3.  Ground-water
 mounds are not evident beneath the A impoundments or impoundment E. The
 presence  of ground-water mounds induce artificial gradients and radial flow
 away from the waste management units.

       A potentiometric high exists in the Qybm at  Baker near impoundment A-5.
 The high is coincident with the dike forming the north and east sides of the A-5
 impoundment.

       At Baker, the ground-water flow velocity (away from the impoundments)
 in the  Qybm has been estimated to^e_ 4 to 5 feet per year;  assuming that the
average horizontal  hydraulic cqndjuctivity.-is 4 x 10"6 cm/sec, the effective
porosity is 0.05, aod $e hydraulic gradtemljs 0.06.
                         >    ' _                  j

      The hydrogeological conditions underlying and surrounding the IT Vine
Hill and Baker facilities have not been adequately characterized for the purpose
of ground-water monitoring.  The purpose of a hydrogeological characterization
of hazardous waste sites is to identify the uppermost aquifer, as defined in
40 CFR Part 260.10, and to determine the direction and rate of ground-water
flow (hydraulic  gradient).    Both  must be  characterized to  enable  the
development of  a  monitoring  well  network,  which complies  with  the
requirements of 40 CFR Part 265.91, or equivalent in the ISO (i.e., monitoring
ground-water quality in the  uppermost  aquifer,  instajlation of at  least one
upgradient  well and three  downgradient wells,  and which are capable of
yielding representative ground-water samples for analysis).  The facilities have

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                                                                       82

not been fully characterized with respect to defining the uppermost aquifer and
ground-water gradients  have  not  been  adequately  defined to establish
direction(s) and rate(s) of ground-water movement and contaminant migration.

      The degree of hydraulic  interconnection between  stratigraphic layers
underlying the IT facilities, and potential preferred paths of pollutant migration
have not been established.  Because the impoundments at the IT facilities are
unlined and are located on top  of old landfill material and underlying poorly
defined strata of differing permeabilities, the potential for pollutant migration is
high; however, it has not been adequately evaluated.

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                                                                 83
   GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS


REGULATORY AUTHORITY


      The regulatory authorities and effective dates that have applied to the IT

Vine Hill and Baker facilities during interim status are listed in Table 16.


REQUIREMENTS AND EVENTS DURING

INTERIM STATUS AT IT VINE HILL AND BAKER
June 6,  1978
March 6,1981
Aprils, 1981
October 19, 1982


August 1, 1983

January 17, 1984
California Regional  Water  Quality Control Board
(RWQCB), San Francisco Bay Region,  issued Waste
Discharge Requirements (WDRs) for the Vine Hill and
Baker facilities; Order No. 78-76.  The  WDRs include
self-monitoring  specifications  and   ground-water
sampling locations.

California Department of  Health  Services  (DOHS)
issued an Interim Status Document (ISO) to IT Baker,
specifying ground-water monitoring requirements and
requiring a ground-water quality assessment outline to
be prepared by November 19,  1981. The ground-water
monitoring requirements in the ISD were in effect until
January 17, 1984.

DOHS issued an ISD to IT Vine Hill specifying ground-
water monitoring and  requiring a ground-water quality
assessment outline to be  prepared by  November 19,
1981. The ground-water monitoring requirements in the
ISD were in effect until January 17, 1984.

IT requested  a waiver  of  the  ISD  ground-water
monitoring requirements.

IT submitted a Part B application for Vine  Hill.

RWQCB granted IT a ground-water monitoring waiver of
the ISD ground-water  monitoring requirements at Vine
Hill  and Baker, provided that  IT implement the self-
monitoring program specified in the WDRs and add EPA
interim primary drinking water standards to the list of
analyses for the next six quarters of monitoring.  The
waiver was in effect until January 16, 1985. As of this
date, the ISD ground-water monitoring requirements no
longer applied.

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                                                                     84
                                Table 16
      FEDERAL AND STATE REGULATORY AUTHORITY FOR INTERIM
       STATUS GROUND-WATER MONITORING AT THE IT VINE HILL
              AND BAKER HAZARDOUS WASTE FACILITIES
      Effective Dates
                                      Regulations, Permits and Orders1
Sept. 19, 1978- Present


Nov. 1980 - Present

March 6, 1981 - Present

Aprils, 1981 - Present

June3,  1981  -Jan. 31, 1986
Jan. 11,1983-Jan. 31,1986
Jan. 16, 1985-Sept. 30, 1986
Feb. 7,1985-Jan. 31,1986
Sept. 30, 1986 - April 15, 1987
April 15,1987-Present
                                 Waste Discharge Requirements (WDRs)
                                 Order No. 78-76* for Vine Hill and Baker

                                 40 CFR 265^; CHWMR (CAC, Title 22)4

                                 Baker Interim Status Document 5

                                 Vine Hill Interim Status Document5

                                 California  had  RCRA  Phase I  interim
                                 authorization; 40 CFR 265 and  CHWMR
                                 (CAC, Title 22) still apply for ground-water
                                 monitoring

                                 California granted interim authorization for
                                 Phase II,  Component  A  (authority to
                                 permits for treatment, storage of hazardous
                                 wastes in tanks, containers,  waste piles
                                 and surface impoundments).

                                 Cleanup  and Abatement  Order No. 85-
                                 004 for Vine Hill and Baker*

                                 California granted an extension of interim
                                 authorization.

                                 Cleanup and Abatement  Order No. 86-
                                 014 for Vine Hill and Baker*

                                 Cease and Desist Order  No. 87-037* 6
     Various permits for operations other than ground-water monitoring were also effective during
     interim status but are not listed here.
     Issued by the California Regional Water Quaity Control Board
     Title 40, Code of Federal Regulations, Part 265 (interim status regulations)
     California Hazardous Waste Management Regulations, California Administrative Code Title 22,
     promulgated under the California Hazardous Waste Control Act
     Issued by the California Department of Health Services
     Issued under the authority of the State of California Toxic Pits Cleanup Act of 1984
2
3
4

5
6

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                                                                   85
 AugusfS, 1984
 September 27, 1984
 Novembers, 1984
January 16, 1985
Februarys, 1985
March 3, 1985
 EPA Region IX issued a Notice of Violation (NOV) to IT,
 citing  ground-water  violations  noted  in  an  ISO
 inspection on April 12 and 13, 1984.

 EPA Region IX  issued  a Determination of Violation
 (DOV), indicating IT was violating the requirements of
 the ISO.

 IT submitted a ground-water monitoring report (by Leroy
 Crandall &  Associates) identifying a ground-water
 mound  beneath ponds C and  D-1  at  Baker,  and
 elevated concentration of chloride and total dissolved
 solids beneath these units. The report also concluded
 that Vine Hill did not have enough wells to establish
 ground-water movement and quality.

 RWQCB issued a Cleanup and Abatement  Order  (85-
 004) to IT to investigate  violations identified by EPA in
 the September 1984 DOV.  The Order required IT to
 submit a ground-water quality assessment outline by
 February 15, 1985, determine the  extent of contamina-
 tion at Baker, certify the  integrity of existing monitoring
 wells, modify and submit  an amended ground-water
 sampling and analysis  plan for  each site,  conduct
 monthly sampling for 6 months and certify the adequacy
 of the ground-water monitoring program for both  the
 Vine Hill and Baker facilities. This Order revoked the
 ground-water monitoring  waiver approved January 16,
 1984.

 IT submitted the first assessment outline to EPA Region
 IX and DOHS for the Baker facility (as Appendix XIII-2 of
the Part B permit application).
IT submitted a
ment Plan."
'Recommended Ground-Water Assess-
ApriU, 1985
IT submitted Part B application revisions for ground-
water monitoring.
September 23, 1985  IT submitted the first assessment outline to  EPA and
                    DOHS for Vine Hill.

October 30, 1985     RWQCB inspection

September 30, 1986  Cleanup and Abatement Order (No. 86-014) was issued
                    on the basis of noncompliance with issues identified in
                    the April and October 1985 inspections.

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                                                                   86

 GROUND-WATER SAMPLING AND ANALYSIS PLANS

      Between May 1983 and May 1987, IT and their consultants prepared and
 submitted nine Ground-Water Sampling and Analysis Plans (SAPs) to meet the
 requirements of  Federal and State laws and  regulations including  U.S. EPA
 regulations at 40 CFR 265.92 and  State regulations at Title  23  California
 Administrative Code (CAC), Chapters, Subchapter 15, Articles.

      IT prepared identical SAPs dated May 3,  1983 for the IT Vine Hill and
 Baker facilities. These SAPs were submitted as  parts of the respective Part B
 permit applications for  each facility on August  1, 1983.  These SAPs were
 determined to be deficient by EPA Region IX. Subsequently EPA issued two
 compliance orders,  one  for each facility (EPA Docket Numbers  RCRA
 09-84-0041 and RCRA 09-84-0042).  In response, IT prepared and submitted,
 on October 29, 1984, revised SAPs for each facility including explanations for
 some deficiencies which  they could  not correct because of inadequate site
 hydrogeologic characterization.  Again, in March 1985, IT submitted essentially
 the same SAPs for each facility along with Part B  Application Revisions.

      In December 1986,  IT revised the SAP  for the Vine  Hill  facility in
 response  to comments by RWQCB,  San Francisco  Bay Region.   Also, in
 December 1986,  IT revised the SAP for the Baker facility to address comments
 made by the RWQCB in their Compliance Monitoring Evaluation (CME) dated
 June 30, 1986. This revised plan  was submitted to fulfill the partial require-
 ments of Task 4,  Cleanup  and Abatement Order (CAO) No. 86-014 pursuant to
 Section  13304 of the California Water Code.

      Another SAP was prepared, dated May 18, 1987, to cover requirements
 of the CAO Field Program at both the Vine Hill and Baker facilities.

      None of the SAPs noted above indicate which well(s) are designated as
 being hydraulically upgradient or downgradient of either the Vine Hill or Baker
facilities. Such designation is required by 40 CFR 265.91 (a)(1)(i) and (ii) and
265.91 (a)(2).

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                                                                     87
       Weaknesses in the plans include items such as the field  instruments
 being calibrated in the laboratory each day before the field sampling personnel
 go to  the field  and no provision is made  to  recalibrate these  instruments
 periodically between sampling stations during the day.  Also, the SAPs indicate
 that the headspace in wells will be checked annually or more frequently, as
 scheduled by the IT Treatment and Disposal  Department.  Annual monitoring of
 the well headspace is too infrequent.  The plans do, however, indicate that the
 headspace air will be monitored prior to any  water level measurement, purging
 or water sampling. This is principally a safety precaution, although it may serve
 as an indicator of contaminant migration. The plans do not include procedures
 for decontamination of instruments  and other downhole equipment between
 use in different wells.

 IT SAMPLE COLLECTION AND HANDLING PROCEDURES

      Task Force staff returned to the IT Vine Hill facility on August 4 and 6,
 1987 to evaluate  ground-water sample collection  and  handling  procedures
 practiced  by  IT  personnel during the routine quarterly RCRA ground-water
 monitoring sample collection  field work.  The evaluation included observing
 water level and well depth measurements, well  purging procedures, field data
 collection  and sample collection, preservation, and packaging.  IT procedures
 were evaluated for technical soundness and for compliance with the sampling
 and  analysis  plan (SAP),  as required by CAC, Title 22,  Article 22, Sec-
 tion 67193 and 40 CFR  Part 265.93.  Task Force staff  noted that in several
 instances, IT personnel did not follow the procedures, as specified  in the sam-
 pling and analysis plan.

      IT personnel, assigned to perform ground-water sampling at the Vine Hill
 and Baker facilities, were also responsible for sampling at other IT facilities and
 for sampling to fulfill specific requirements of a Cleanup and Abatement Order
dated September 30,  1986.   Because there are several SAPs  which were
developed for compliance with differing  requirements,  IT field personnel were
uncertain about which SAP followed the routine RCRA quarterly ground-water
sampling and did not adhere strictly to the requirements of any single plan.

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                                                                    88

       IT officials provided the Task Force with copies of the December 1986
 SAPs for both the Vine Hill and Baker facilities.  However, IT field sampling
 personnel appeared to be unfamiliar with some of the procedures specified in
 the plans.  The SAPs for these  two facilities are identical except for the wells
 which are designated to be measured and sampled at each facility.

 Wellhead Measurements

      At the wellhead, the security cap was removed and an organic vapor
 sensor was used to  determine the presence  or absence  of  potentially
 dangerous volatile organic vapors.  IT personnel then measured the depth to
 water below the top of the internal PVC casing using an electrical oil/water
 immiscible  layer probe  (Marine Moisture  Control,  Model B2220-3, serial
 number 1675).  The instrument was capable of determining the depth to water
 within the accuracy of 0.01 foot as specified in the SAP.  However, the tops of
 the casing in some wells are not  cut evenly and no designated measuring point
 was marked. Therefore, measurements made by different personnel at different
 times may not be strictly comparable.

      An effort was made to sound the depth of the well using the immiscible
 layer  probe and subsequently calculate the fluid (water) column volume in the
 well and to determine whether an immiscible layer was present near the bottom
 of the well.  This calculation is needed to determine the amount of water
 required to be purged from the well prior to sampling.  However, the cable on
 the probe was not long enough to reach the well bottom; hence,  neither of the
 above determinations  could  be made with the instrument used.  IT field
 sampling personnel indicated that this instrument had been leased because the
 one the Company had ordered had not yet been delivered. However, since the
 December 1986 SAP, in which the use of this instrument was specified, there
 should have been two regular RCRA quarterly ground-water monitoring events.
 Furthermore, the field personnel  did not appear to be familiar with the
calibration and operating procedures for this instrument.

      Subsequently,  a Gould submersible stainless steel impeller pump was
lowered into the well,  suspended  on a flexible plastic hose, plastic rope and an
electrical power supply cord.  The total depth of the well was determined by

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                                                                    89
sounding with the suspended pump. The column volume was calculated, the
pump was raised to a position adjacent to the screened interval, just above the
bottom of the well, and purging began.  After purging slightly more than three
water column volumes into storage drums beside the well, the pump, rope,
hose, and cord were pulled from the well and placed in a plastic garbage bag
prior to being decontaminated before use in another well.

      In situ well water quality measurements were measured in the well by
lowering a Martek instrument (MARK XIV) into the well at approximate screen
depth.  This instrument is designed to measure pH, temperature, dissolved
oxygen  (DO), and specific conductance.  IT field personnel indicated that the
instrument had been calibrated at ITs laboratory at the nearby Benicia facility
and they did not recheck or recalibrate the instrument in the field. While making
duplicate measurements the pH readings did not stabilize.  The MARK XIV
parameter measurements before and after sampling in well MW-219 were as
follows:
                           Before               After

         pH                 5.36         5.98
         DO                1.82         2.51
         Temperature       16.2 °C        20 °C, 18.4 °C, 17.3 °C
                                          (three measurements
                                          5 minutes apart)
         Specific
          Conductance   2110            2550
These changes suggest unexpectedly rapid changes in well water quality,
inadequate instrument calibration, instrument instability or inexperienced
instrument operators.  The differences in readings were not resolved in the field.
Eh (oxidation-reduction potential) measurements were not made in the field, as
specified in the SAP.

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                                                                    90

 Purging of Monitoring Wells

      The SAP indicates that dedicated Teflon bladder pumps or Teflon bailers
 with fluorocarbon resin-coated wire or single strand stainless steel wire will be
 used'for well sampling.  The  SAP indicates that if a bailer is used it will be
 dedicated to a specific well and it will remain in the well, suspended from the
 well cap, between sampling  events.  These procedures  were not followed
 during the Task Force inspection.

 Sampling of Monitoring Wells

      Monitoring well MW-219 is a rapidly producing well about 96 feet deep,
 and while observing the purging of this well, the water level drew down only a
 few feet. After the purge pump was removed from the lower (screened) section
 of the well,  a Teflon bailer was used  for sample collection.  Even though three
 column  volumes of water had been  evacuated from the well adjacent to the
 screen,  the samples were  collected  from the top of the water column which,
 most probably, was the same  standing water which occupied the well prior to
 purging.  Thus, the  purpose of purging (to  provide samples  which are
 representative of aquifer water quality) probably was not  accomplished. In
 addition, the in situ well water quality measurements near the bottom of the well
 would not  be  expected to be comparable with laboratory analytical data
 resulting from samples collected from the top (unpurged) portion of the water
 column.

 Sample  Parameters

      The  parameter sampling order observed during the inspection  was
 different than that specified in the SAP.  Samples  were collected  for volatile
 organics analysis (VOA) from the first well (MW-219)  where sampling  was
observed by the Task Force.   However, at a subsequent well (MW-218) IT
personnel indicated that they do not collect VOA samples at the Vine Hill facility
and had been given sample bottles for VOAs by  mistake for sampling of well
MW-219.

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                                                                    • 91

      The SAP indicates that four separate determinations of dissolved oxygen
(DO), pH, and electrical conductance (EC) will be made for each sample and
that temperature and turbidity will  be measured only once for each sample.
These procedures  were not consistently followed by IT field personnel during
the Task Force inspection.

      IT personnel indicated that the sample bottle preparation is provided for
them by their laboratory and usually comes from Export, Pennsylvania although,
on  occasion, some sample containers are provided by staff at the nearby IT
Benicia facility.  The  use of preservatives and sample handling and packaging
practices observed were adequate.

      Although not required in the SAP, no equipment blank samples  were
collected during the  inspection.  Rigorous field  sampling procedures should
include occasional equipment blanks to assure that field equipment cleaning
procedures are sufficient to preclude sample contamination from equipment
which is used repeatedly.  Field blanks were collected but were poured at the
decontamination area rather than adjacent to a well site being sampled, as
specified in the SAP.

      The Groundwater Monitoring  Well Sampling Information form used  by IT
field personnel  during the Task Force inspection was not the same form as
provided in the  SAP.  This form omitted spaces for some field data and had
additional spaces for other data. Either form would be acceptable as long as it
is consistent with the SAP narrative.  The form provided in the SAP is preferable
because  it has more spaces  for field data than the form  used during the
inspection.

Adequacy of Handling Procedures

      At various  times during the inspection, IT field personnel  allowed
downhole equipment,  such as instrument cables and ropes, to touch the ground
or get tangled in weeds.  This practice, although accidental, could lead to the
introduction of foreign (surface) contaminants into wells.

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                                                                    92
      Decontamination of downhole equipment and instruments between use
in different wells was performed at a centralized decontamination pad away
from  sampling  locations  but  was  outdoors  within the  general waste
management area of the Vine Hill facility.  Bailers, ropes, cables, etc. were
washed with tap water and detergent and rinsed twice with tap water. They
were  subsequently  steam cleaned  with  steam  derived  from tap water.
Equipment was then wrapped  in plastic before moving to a well site for use in
sampling. Just prior to using equipment at a well, it was removed from the
plastic wrapping and rinsed with deionized water.  Some of the deionized water
used  for this rinsing during the inspection was labeled,  "Rodgers Purified
Water -  purified by deionization."  Other bottled water, which was also used,
was labeled "Superior Quality Artesian Drinking Water from  Napa Valley."
Whether this water was deionized is unknown.  No  solvents were used in the
cleaning process which would assure  that organic contaminants, which might
be present, were removed.

      To determine the adequacy of the decontamination procedures used by
IT, a set of equipment blank samples  should be collected and analyzed each
day that sampling  is conducted. The equipment blanks should consist of rinse
water from the last rinse before the equipment is used.

      The IT field ground-water sampling personnel were not as familiar with
the SAP provided and the procedures to be followed as they should have been
to assure that representative samples were obtained  or that field measurements
would have the necessary integrity.

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                                                                    93

           GROUND-WATER QUALITY ASSESSMENT PROGRAM

      The  IT Vine Hill  and Baker  facilities were issued Interim Status
Documents (ISDs) on April 6 and March 6, 1981,  respectively.  Section VIII of
each ISO specified the ground-water monitoring requirements, including those
for ground-water quality assessment outline(s), and required the outline to be
prepared by November 19, 1981.

      IT requested a waiver of the ISO ground-water monitoring  requirements
in a letter dated October 19, 1982, citing a low potential for migration of haz-
ardous waste or hazardous waste constituents  from the facility, via the upper-
most aquifer.  These are the only grounds for approval of a waiver request pro-
vided in the ISO [Section Vlll(5)].  RWQCB approved the IT waiver request,  in a
letter dated January 17,  1984, but did not make a  determination  that  a  low
potential for migration of hazardous waste existed.  Instead, RWQCB found that
the Self Monitoring Program, specified under the Waste Discharge Require-
ments (Order 78-76), would satisfy the ground-water monitoring  requirements,
if IT added  the EPA interim primary drinking water standard parameters to the
list of analyses for the next six quarters of monitoring.

      EPA  Region IX inspected the site on April 12 and 13, 1984 and, based
on the  inspection, issued a Notice of Violation on Augusts,  1984 and  a
Determination of Violation  on September 27, 1984 indicating IT was violating
the requirements of the  State ISO.  Following the  EPA  action, RWQCB
determined that the potential for migration of  hazardous waste from the IT
facilities existed and required IT to  fully implement  the ISD  ground-water
monitoring  program as part of  a Cleanup and Abatement Order (85-004)
issued on January 16, 1985, to investigate the violations identified by EPA.

      The Cleanup and Abatement Order required IT to submit a ground-water
quality assessment outline for each site, by February 15, 1985, which complied
with the requirements of 40 CFR Part 265.93(a).  The assessment outline is
required to  describe a more comprehensive ground-water monitoring program
than  the one for interim status detection monitoring and must be capable of
determining:

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                                                                     94
            Whether hazardous waste or hazardous waste constituents have
            entered the ground water


      •     The rate and extent of migration of hazardous waste or hazardous
            waste constituents in the ground water


      •     The  concentrations  of hazardous waste  or  hazardous  waste
            constituents in the ground  water


      The first assessment outlines for the IT facilities were submitted to EPA
Region IX and  DOHS on September 23, 1985 for the  Vine Hill  facility  and
February 8, 1985 for the Baker facility (as Appendix Xlll-2 of the Part B  permit
application). These outlines  were also identified by IT personnel as the most
recent outlines  and were provided to the Task Force by IT in a letter dated
July 24, 1987.  These outlines were evaluated by the Task Force and are very
different, but both are inadequate.


VINE  HILL FACILITY ASSESSMENT OUTLINE AND PLAN


      The outline submitted  for the  Vine Hill facility on September 23, 1985
lacks  information required in  265.93. In addition to the information submitted,
the outline should contain the following:
            Circumstances  necessitating  additional  monitoring wells
            would be  necessary if the initial phase of the program
            indicates contamination.  The outline specifies that  two
            piezometers would be installed in the vicinity of any wells
            with statistically significant pH increases (or decreases).
            The outline,  however, states that  wells  would not  be
            installed because  of the rate  of ground-water movement.
            The outline does not address how these piezometers would
            be used to determine the rate and extent of contaminant
            migration, as required.

            How volume/concentration of released contaminants would
            be determined

            What the facility would dp to  make sure that all potential
            contaminants  are identified  in  the plume.    The  IT
            "Hierarchial Analysis  Protocol" should be included rather

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                                                                    95

            than referenced, since the protocol is referenced as the sole
            means of determining the universe of constituents to be
            analyzed in assessment.  The analytical parameters to be
            sampled should be listed.
      •     How an assessment monitoring plan would be developed
            and what the projected sampling frequency would be
      •     Which aquifer(s) would be monitored
      •     Approximate  schedules for  the time  needed to  initiate
            assessment sampling, analysis, data evaluation, and report
            results. The starting schedule is included but a time frame
            should be given which estimates the  time necessary  to
            complete stated tasks
      •     How a determination would be made to  return the facility to
            detection monitoring if contamination was not confirmed

      The Vine Hill facility was ordered to comply  with the requirements of
Compliance and Abatement Order 86-013 following a May 1985 report by Leroy
Crandall Associates, describing elevated levels of TOO, TOX, phenolics, and
boron in well MW-203. IT responded that assessment was not justified because
they did not believe the facility was the source of the contaminants. The well in
question is on the boundary of the Acme Rll Corporation/IT Vine Hill border and
IT contends that Acme is the source of the contaminants. The September 1986
Cleanup and Abatement Order (86-014) also applied to the contaminants found
on the Vine Hill facility.  The Order required IT to complete an investigation into
the source of the contaminants  and to respond to other violations found during
RWQCB inspections.

      A 1981  DuPont study of Vine Hill impoundment number 100,  revealed
the presence of tetraethyl lead  (TEL). The September 1986 Abatement Order
also required further investigation of the TEL identified in 1981 as well as  the
other contaminants identified in  1985.

      At the time of the Task Force investigation no assessment plan had been
prepared by IT.

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                                                                     96

 BAKER FACILITY ASSESSMENT OUTLINE AND PLAN

      The Baker outline is titled "Ground-Water Quality Assessment Outline-IT
 Corporation Baker Facility," but does not address an assessment program as
 defined  by 40 CFR Part 265.93(a)  or the  ISO  (Section VIII).  Instead  of
 describing a program which would start after statistical analysis of quarterly
 monitoring data triggered assessment, the outline describes modifications to the
 existing  detection  monitoring program.   The outline describes the need for
 additional wells to determine background ground-water quality, evaluate water
 quality beneath the impoundments and monitor deeper zones.  New wells are
 proposed "to help  in early detection of problems," not to determine rate and
 extent of migration, as required during assessment.

      The "assessment outline" describes work that is not yet completed,
 because of shortfalls of the detection system, rather than steps which will be
 taken if the detection monitoring system triggers assessment, via the statistical
 analyses of quarterly data. The outline describes sampling and analysis and
 other detection  monitoring procedures, ending with the need  for statistical
 analysis.  The statistical analysis program described is used only to determine
 "seasonal variance" in the water quality, and never implies that contaminants
 may be the cause of water quality fluctuations.

      The statistical analysis program proposed does not indicate which well(s)
 will be used for background ground-water quality determinations. The outline
 states that the current background well  (MW-112) is inadequate and a new well
 is proposed.  The "assessment outline" prepared for the Baker facility does not
 address any of the  requirements specified in 40 CFR Part 265.93(a),  and is not
 adequate as an assessment outline.

      In  addition, the assessment outline for the Baker facility should  also
contain the following information:

      •     Circumstances necessitating additional monitoring wells would be
            necessary  if  the  initial  phase  of  the  program  indicates
            contamination. The outline specifies that two piezometers would
            be installed in the vicinity  of any wells with statistically  significant

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                                                                     97
            pH increases (or decreases).  The outline, however, states that
            wells would not be installed because of the rate of ground-water
            movement.  The outline does not address how these piezometers
            would be  used to determine the rate and extent of contaminant
            migration, as required.

      •     How volume/concentration  of  released contaminants would  be
            determined

            What the  facility  would do  to make sure that all  potential
            contaminants are identified in the plume.  The IT "Hierarchial
            Analysis Protocol" should be  included rather than referenced,
            since the protocol is referenced as the sole means of determining
            the universe of constituents to  be  analyzed in assessment.  The
            analytical parameters to be sampled should be listed.

            How an assessment monitoring plan would  be developed and
            what the projected sampling  frequency would be

            Which aquifer(s) would be monitored

      •     Approximate schedules for the time needed to initiate assessment
            sampling,  analysis, data evaluation, and  report results.  The
            starting  schedule is included but a time frame  should  be given
            which estimates the time necessary to complete stated tasks

            How a determination would be made  to return the  facility  to
            detection monitoring if contamination was not confirmed

      IT submitted a monitoring report for the  Baker facility on November 8,
1984. The report, prepared by Leroy Crandall and Associates (LCA),  identified
elevated chloride and total dissolved solids (TDS) concentrations in the ground
water, primarily beneath impoundments C and D-1. The report also describes a
ground-water mound  under the impoundments that, according to LCA, closely
corresponded to the chloride concentrations.

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                                                                    98

      Following  review of the report and the EPA inspections, the RWQCB
issued a Cleanup and Abatement Order (Number 85-004)  dated January 16,
1985, which required IT to identify:  (1) the extent of contamination at Baker,  (2)
locate appropriate upgradient wells and (3) certify the adequacy  of the ground-
water monitoring  program for both the Vine Hill and Baker facilities. In response
to the Order, IT submitted both the Assessment Outline (previously discussed)
and a document  titled "Recommended Ground-Water Assessment Plan," dated
March 3, 1985.

      Two inspections  (April 19, 1985 and October 30,  1986)  of  the  IT
facilities were  conducted by RWQCB  personnel and  inspection evaluations
described problems  with  the  sampling and analysis plan,  hydrogeologic
characterization, statistical analysis,  background/upgradient wells, etc.
Inspection evaluations were sent to IT regarding compliance with the ground-
water requirements  (dated  June 19,  1985 and June 30, 1986).   IT had
reportedly complied with most portions of the January  1985 Abatement Order;
however, the additional  non-compliance required issuance of  an  additional
Cleanup and Abatement Order (No. 86-014), dated September 30, 1986.

      IT has not completed implementation of the assessment plan submitted
in March of 1985 for the Baker facility.  The Abatement Orders are the driving
force for evaluation of the contaminants detected at Baker. The tasks have been
modified significantly from those  proposed by IT in the assessment plan. The
tasks  required  in the abatement program include the  aspects required of an
assessment program under RCRA including, all the aspects of an assessment
outline plus:

            The number, location, and depth of wells

            Sampling and analytical methods for those hazardous wastes  or
            hazardous waste constituents in the facility

      •      Evaluation procedures, including any use of previously gathered
            ground-water quality information

      •      A schedule of implementation

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                                                                  99
      The implementation of the assessment (abatement program) program is
in  accordance with provisions and  time tables  specified  in the Abatement
Orders (85-004 and. 86-014).

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                                                                  100
               GROUND-WATER MONITORING PROGRAMS
                    PROPOSED FOR RCRA PERMITS
      Task Force personnel reviewed the ground-water monitoring  programs
proposed in the  RCRA Part B permit applications for both the Vine Hill  and
Baker facilities.  The ground-water monitoring programs proposed for the final
RCRA permits were incomplete on several counts, as described below.

VINE HILL FACILITY

      The original Part B permit application for IT Vine Hill is dated  August 1,
1983. IT submitted a partial revision to EPA on April 4,1985. By the time of the
Task Force investigation in 1987, the ground-water monitoring  program in the
application had  not been  revised to correct deficiencies identified earlier,
although hydrogeologic investigations were continuing.

      The proposed ground-water monitoring program does not identify the
uppermost aquifer or which  aquifer(s) are hydraulically interconnected to  one
another or  need to  be monitored [40 CFR 264.97,  270.14(c)(2)].  The
application does identify several permeable zones but does not provide a basis
for the decision  to monitor given zones.  The  application does not include
determinations of ground-water flow directions and rates [40 CFR 270.14(c)].
Adequate placement of monitoring wells depends upon proper identification of
permeable  ground-water zones and flow directions and rates.  In  light of
hydrogeologic investigations done since the Part B submittal,  IT  needs to
include the more  recent and complete information in the permit application.

      The proposed monitoring program does not designate monitoring wells
for determining the background ground-water quality (40 CFR 264.97).  Neither
does the program include consistent analytical methods for determining water
quality, as required by  40 CFR 264.97(d).

      The  monitoring well  system  proposed in the Part B  application is
insufficient  in that well location  and construction information is general  and
incomplete.   The  application  needs  to  contain specific well  completion

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                                                                    101
information, including well design and the monitored permeable zone for each
well.

      The  ground-water monitoring  program  in  the Part B  application
proposes detection monitoring  (40 CFR 264.98) for  the term of the RCRA
permit.   Considering that organic compounds have been detected in ground
water and in soils,  IT needs to include provisions for compliance monitoring
under 40 CFR 264.99.

      The proposed sampling  and analysis plan does not  mention using
locked containers for samples in the chain-of-custody  procedures. Containers
used for holding samples need to be locked when they  are not in the immediate
presence of the  sample custodian.  Preservatives  used for ground-water
samples need to be  listed in the plan instead of incorporated by reference.

BAKER FACILITY

      The original Part B permit application  for IT Baker is dated August 1,
1983.  IT submitted a partial revision to EPA on April 4,  1985.  At the time of the
Task Force investigation in 1987, the ground-water monitoring  program in the
application  had not been revised a second time; however,  hydrogeologic
investigations were continuing.

      The proposed ground-water monitoring program  does not identify the
uppermost aquifer or which aquifer(s) are hydraulically  interconnected [40 CFR
264.97, 270.14(c)(2)].  IT does identify several permeable zones and presents
an estimated range of permeabilities based  upon "slug" and  laboratory test
data; however, which zones these values represent is not clear. At best, these
data are representative of near-well conditions only.

      Water level data presented in the application  are difficult to interpret
because it is not clear which permeable zone(s) are being monitored by each
well. As a result, the slope(s) and direction(s) of the hydraulic gradients, as
represented, are suspect.

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                                                                    102
      The application presents estimates of flow velocity based on the limited
permeability and water level data.  Although the ranges of flow velocity seem
reasonable for the types of deposits in the area,  the velocities need to be
computed again using reliable data derived from specific, accurately defined
water-bearing zones.

      The proposed  monitoring program does not designate monitoring wells
for determining the background ground-water quality (40 CFR 264.97).

      The monitoring well system proposed in the Baker Part B application is
insufficient in that well location and construction information is incomplete. The
application  includes general well construction specifications which  lack such
details as grout and sand filter pack types and the zone monitored.

      As for Vine Hill, the ground-water monitoring  program in the Baker
Part B application proposed detection monitoring under 40 CFR 264.98 for the
term of the RCRA permit.  Hazardous waste constituents have been detected in
ground-water samples. Therefore,  IT needs to include provisions for compli-
ance monitoring under 40 CFR 264.99.

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                                                                   103
                   EVALUATION OF MONITORING DATA
                 FOR INDICATIONS OF WASTE RELEASE
      This section  presents an analysis of Task Force and  IT Corporation
 monitoring data regarding indications of waste releases to ground water from
 the IT Vine Hill and Baker facility impoundments.  Field and laboratory analytical
 results from samples collected by Task Force (EPA contractors) personnel are
 presented in  Appendices A (Vine Hill) and  B (Baker),  together with an
 indication of the analytical methods used.

      The data indicates that hazardous constituents  are present in the ground
 water in the vicinity of the Vine Hill and Baker surface impoundments.  The
 majority of the constituents identified were not found in the ground water at the
 adjacent Acme Fill Corporation facility; therefore,  these constituents most
 probably have leaked from the IT surface impoundments.   The data for the
 inorganic parameters and indicator parameters (pH, specific conductance, TOC,
 and  TOX) from the Task Force samples correlate well with the historic  data
 reported by IT during interim status monitoring.  Wells MW-102 and MW-113 at
 the Baker facility  exceeded the maximum contaminant level of 1.0 mg/L for
 barium.  Organic results from the Task Force investigation indicate the presence
 of volatile and semi-volatile organic compounds in monitoring wells,  and in the
 surface  impoundments sampled.  The following sections  discuss in  detail the
 findings for the Vine Hill and Baker facilities, respectively.

      In addition,  data in the files of the RWQCB, San Francisco Bay Region,
 show evidence of ground-water contamination due to leakage  from  impound-
 ments at the IT Vine Hill and Baker facilities.

 ORGANIC RESULTS - VINE HILL FACILITY

      Organic compounds  were  detected in  several wells and  a surface
 impoundment at the Vine Hill facility. The designated upgradient/background
 wells MW-216 and MW-219 were sampled during the Task Force investigation
 and found to be virtually free of chromatographable organic compounds.  The
designated downgradient wells MW-203, MW-205, MW-212, MW-215, MW-222,
TB-515  and the surface  impoundment  (pond 101)  contained  organic

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                                                                   104

constituents above the limits of quantitation [Table 17].  No correlation could be
made between the constituents found in pond 101 and those found in the wells.
Samples were not taken from the other surface impoundments during the Task
Force  investigation and  the  facility has  not  historically submitted organic
analytical results as part of interim status, so the source of the constituents in the
wells could not be identified.

ORGANIC RESULTS - BAKER FACILITY

      Organic  compounds  were  detected  in several wells, a surface
impoundment, and a ground-water seep at the Baker facility.  Well MW-112,
designated by the facility as an upgradient/background well, was virtually free of
chromatographable organic  compounds.   Apparently,  downgradient wells
(MW-101 and MW-125),  although not  designated as such  by IT, a surface
impoundment (D-1), and a ground-water seep showed detectable organic
compounds.  The concentration  of benzole acid in the surface impoundment
was  an. estimate because of the  dilution necessary before analysis [Table 18].
The constituents identified in well MW-125  may be indicative of leaks in the A-
series of impoundments or the B impoundment.  Samples were not taken from
these impoundments during the Task Force  investigation and the facility has not
historically submitted organic analytical results as part of interim status, so the
source of the constituents in MW-125 could not be identified.

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                                    Table 17
  SELECTED VOLATILE ORGANIC CONSTITUENTS PRESENT IN TASK FORCE SAMPLES
                                 IT Corporation
                                 Vine Hill Facility
                               Martinez, California
Constituent
- ng/L
1 ,2-dichloroethane
Benzene
Toluene
Vinyl acetate
Phenol
2-methyl phenol
Vinyl chlroide
Xylenes
Trans-1 ,2-dichloroethene
Trichloroethene
4-methylphenol
Ethylbenzene
Chlorobenzene
Well
MW203
ND'
11.
2."
93.
17.
13.
ND
3."
ND
ND
6."
ND
ND
Well
MW205
320.
22."
17."
240.
ND
ND
350.
ND
ND
ND
ND
ND
ND
Well
MW215
ND
6.
2."
ND
8."
ND
ND
13.
ND
ND
ND
ND
ND
Well
MW222
ND
ND
16.
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Well
TB515
ND
ND
9.

ND
ND
9."
13.
8.
1."
ND
6.
7.
Surface
Impoundment
ND
ND
170*
ND
8,000.
ND
ND
ND
160."
26."
680.
ND
ND
ND = Not Detected
Estimated, below LOQ
                                                                                             o
                                                                                             en

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                                       Table 18
     SELECTED VOLATILE ORGANIC CONSTITUENTS PRESENT IN TASK FORCE SAMPLES-
                                     IT Corporation
                                     Baker Facility
                                   Martinez, California
Constituent Upgradient Well
H9/L MW112
Toluene
Acetone
bis (2-Ethylhexyl)
phthalate
Benzoic acid
Phenol
1 ,4-Naphthoquinone
2,4,5-TP
di-n-Butyl phthalate
1.'
ND"
2.'
ND
ND
ND
ND
1.*
Well
MW9A
ND
ND
2.*
ND
ND
7.*
0.28
2.*
Well
MW101
ND
ND
180.
ND
ND
ND
ND
ND
Well
MW125
5.
99.
11.
140.
240.
26.
ND
ND
Pond
C
ND
ND
210.
ND
ND
ND
ND
ND
Pond Ground-Water
D-1 Seep
ND
ND
ND
3,800.
ND
ND
ND
ND
ND
ND
29.
ND
ND
ND
0.7
ND
Detected but estimated, below Limits of Quanatation (LOO)
ND = Not Detected
                                                                                                  o
                                                                                                  en

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                                                                   107


      MONITORING WELL LOCATION, NUMBER, AND CONSTRUCTION


      The monitoring well networks used for ground-water monitoring at the IT
 Vine Hill and  Baker facilities have  changed  significantly over time.  The
 following sections address the monitoring well  networks for each facility and
 respective compliance under both the self-monitoring  and  interim status
 monitoring programs.


 LOCATION AND NUMBER


      The ISO [Section Vlll(1)| and RCRA (40 CFR Part 265.91) requirements
 are  identical regarding the  location and number of monitoring wells, and
 require:

      •     Monitoring wells (at least one)  installed hydraulically upgradient
            (i.e., in the direction of increasing static head) from the limit of the
            waste management area.  Their number, locations and depth must
            be sufficient to yield ground-water samples that are:

                  Representative of background ground-water quality in the
                  uppermost aquifer near the facility

                  Not affected by the facility

            Monitoring wells (at least three) installed hydraulically downgradi-
            ent (i.e., in the direction of decreasing static head) at the limit of the
            waste management area.  Their number,  locations, and depths
            must ensure that they  immediately detect any statistically signifi-
            cant amounts of hazardous waste or hazardous constituents that
            migrate  from the waste  management area  to  the uppermost
            aquifer.


      The facility has not fully complied with these requirements.


VINE HILL FACILITY SELF-MQNITORING PROGRAM WELLS


      The self-monitoring program for Vine Hill  facility is also found in Waste
Discharge  Requirements  Order 78-76  and contains requirements similar to
those for the Baker facility, except required ground-water monitoring wells were
to be located according to specifications in Table 19.

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                                                                     108
                                Table 19
                  SELF-MONITORING PROGRAM WELLS
                             Vine Hill Facility
Well No.                    Description/Specifications
G-18    A well located within 50 feet of the northeast corner of the Vine Hill
         site waste disposal impoundment area.  The depth shall be to the first
         available ground water.
G-19    A well located within 300 feet northerly and 300 feet easterly from the
         northeasterly corner of the Vine Hill site waste disposal impoundment
         area.  The depth shall  be to the first available ground water (formerly
         well C).
G-21     A well located within 800 feet  easterly  and about 300 feet southerly
         from  the northeasterly corner of the Vine Hill site waste disposal
         impoundment area. The depth shall be to the first available ground
         water, (formerly well E).
G-22    A well located within 50 feet of the easterly corner of the Vine Hill site
         waste disposal impoundment area.  The depth shall be  to the first
         available ground water.
G-23    A well located at the southwesterly corner of the Vine Hill  site (in the
         area   described  as   the   "Shell  Oil parcel")  waste  disposal
         impoundment area. The depth shall be to the first available ground
         water.
      Like the wells at Baker, there is  little, if any, information available
regarding the construction of the self-monitoring wells.  A letter from IT to EPA
Region  IX, dated  May  1983, stated that  boring logs were  not  available  for
wells 21, 22, and 23 [Figure 5].   The only available construction information is
depicted in Figure 6.  As-built diagrams are not available for individual wells,
therefore, the adequacy of the wells cannot be evaluated.  Varying lengths of
blank PVC casing  were installed below the screened interval, and the gravel
pack extended through both the length of the screen and the blank casing to  the
total depth of the well.  Multiple  flow zones were  intercepted  using this
construction method.  None of the wells  were designated  as  background/
upgradient.

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                                                         109
                              VINE  HILL FACILITY
                                                      MW4
                              MW6
                           UJ
   LEGEND

mmm Property  Boundar
i »Surface Impound
*  Monitoring Well
                                             700
                                                        1   \
                        FIGURE 5
                SELF MONITORING  PROGRAM
                      WELL  NETWORK

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         llx-fc 1* *> •xMll.d
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                           FIGURE 6
VINE HILL  INTERIM STATUS MONITORING WELL  COMPLETION  DETAILS

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                                                                    111

       Construction records are not available, therefore, a determination cannot
 be made of whether the wells conform to the contractor specifications.  Wells 20,
 22, and 23 were proposed to be abandoned in October 1984.  Well 21 was to
 be retained as a  piezometer, even  though  the May 1983  letter stated  that
 construction information was not available for this well.  Documentation could
 not be located during the Task Force investigation to verify that wells 20, 22,
 and 23 were ever properly abandoned or that wells 18 and 19 were ever drilled,
 as required by the  self-monitoring program.

 VINE HILL FACILITY INTERIM STATUS MONITORING WELLS

 Location and Number

       The ISO and RCRA requirements are the same for the Vine Hill  and
 Baker facilities. Between November 1984 and January 1985, 12 interim status
 wells were drilled at the Vine Hill facility.  The wells were numbered MW-201
 through MW-207 and MW-209 through MW-214.  Wells MW-210 and MW-211
 were  found to be contaminated with oily fill residues  during  construction  and
 were  replaced by wells MW-213 and MW-214, respectively.  None  of the wells
 were designated as upgradient, although the location of the wells were selected
 to "assure that an upgradient well is installed," according to IT reports.

       Additional interim status wells were drilled between October 1985  and
 March 1986.  These wells were numbered MW-215 through MW-219. Wells
 MW-215, MW-216  and MW-218  were designated by  IT as upgradient wells,
 monitoring the bay mud (MW-215  and  MW-218) and sand  and  gravel units
 (MW-216). Well MW-215 was discontinued as  an upgradient well  because
 drilling crews were unable to properly develop the well for sampling.  Figure 7
 identifies the locations of the Vine Hill interim status wells. At the time of the
 Task Force investigation the direction of ground-water flow and the vertical and
 areal extent of the uppermost aquifer (particularly for the fill and bedrock zones)
 had not been characterized, therefore, the location  and  number  of wells
 necessary to monitor the uppermost aquifer, upgradient or downgradient of the
 hazardous waste management areas (as required by 40 CFR Part 265.91  and
the ISO) is not adequate.

-------
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                                                                    113

 Construction

       The construction of the Vine Hill facility wells is similar to that described
 for the Baker facility interim status wells.  There are no as-built construction dia-
 grams available  for wells MW-201 through  MW-207 and MW-209  through
 MW-214.  Well MW-207 was not logged  during drilling because of its proximity
 to well MW-206,  therefore, drilling records are also not available. The well
 completion details provided by IT [Figure 8] do not agree with the available
 drilling logs.   The depths in the construction  records do not agree with the
 drilling logs (e.g., MW-201 and MW-203). There are also no  records available
 regarding the  volumes of filter pack, material, or cement used in construction.
 There are no  records of grain size analyses performed to verify whether the
 selection  of screen size or filter pack  materials are appropriate for the forma-
 tions screened. Wells MW-218 and MW-219 are the only wells with  a justifica-
 tion for the screen slot selected.  The filter packs around the screen  and the
 blank casing sections, extend for 1 to 5 feet above the screened interval. When
 the thickness of formations screened are  added to the zones intercepted by the
 sand pack and blank casing, multiple zones having different compositions and
 water-bearing properties  are  being  sampled for  12  wells  (wells MW-201,
 W-202, MW-204, MW-206, MW-212,  MW-213, MW-214, MW-215, MW-216,
 MW-217, MW-218 and MW-219).

      Additional potential problems with the well construction were identified at
 several wells during Task Force sampling.  Wells MW-203  and MW-209 were
 not  completed with  a  concrete  pad',  treating -1he  potential  for  surface
 contamination  to enter these wells.  Well MW-218 was missing a casing  cap,
 and the surface casing annulus for well MW-213 was filled with water, indicating
 possible leaks in the  casing or other structural  problems. When  measured by
 Task Force personnel, the depth of wells MW-202, MW-203,  MW-204, MW-205,
 MW-206,  MW-207, MW-209, MW-212, MW-213, MW-214,  MW-216, MW-218
 and MW-219 differed more than 0.5 feet shallower or deeper than the depths
 reported in IT construction records indicate.  In summary, numerous wells have
construction problems which  make their use for sampling as interim status
 monitoring wells subject to questions.

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                                                         114
                              MW2 1 9
                                 C HILL  FACILITY
  LEGEND
   ?rop«rty Boun
   Surface Impou
O  Monitoring  W«
                                      Scale
                                      i
                                     0       700
                          FIGURE   8
               INTERIM STATUS MONITORING
                       WELL  NETWORK

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                                                                   115

       Additional wells were drilled at the Vine Hill facility following the 1986
 Cleanup and Abatement Order (wells MW-220 through MW-227).  Information
 describing the drilling, completion, and construction of these wells was not
 available at the time of the Task Force investigation, therefore, the adequacy of
 these wells was not evaluated.

 BAKER FACILITY SELF-MONITORING PROGRAM WELLS

       The self-monitoring  program (Waste Discharge  Requirements Order
 No. 78-76) specified the location, number and approximate depth (to the first
 ground water) of  each monitoring well.  The program  did not specify the
 construction standards for the wells. The  monitoring well network specified in
 the order, consisted of 14 wells numbered G-1 through G-14.  IT installed the
 specified  number  of wells;  however, compliance with the order cannot be
 determined because drilling logs and available maps do not correlate with the
 descriptions given. The  self-monitoring program did not require designated
 upgradient and downgradient wells or statistical analysis of analytical data, as
 required in the ISO and RCRA ground-water monitoring program.

      The construction of the self-monitoring program wells is suspect because
 few details are available regarding the formations penetrated, well construction
 or screened  intervals.  The available well construction data is confusing
 because  boring  numbers  on  the drilling  logs, assigned by the  drilling
 contractors, do not correspond to the monitoring well (MW) numbers assigned
 by IT on the maps.

      Most of the self-monitoring program wells were replaced between 1982
 and 1985 due to damage  (well casings broken) or uncertainties regarding
 construction,  as identified by RWQCB personnel.  Well  number MW-8 was
 abandoned  in 1982;  wells numbered  MW-1,  MW-5  and  MW-13 were
 abandoned in 1984 and wells numbered MW-2, MW-3, MW-4,  MW-7, MW-10,
 MW-11, and MW-12 were replaced in 1985.   Records could  not be located
 regarding the abandonment  of well MW-6 other than that the replacement  well
 MW-6A was drilled in  July of 1985. Each of  the self-monitoring wells were
 reportedly  abandoned by drilling through the entire length of the well, removing
the PVC casing and filling the entire length of the hole with cement grout.

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                                                                  116

 BAKER INTERIM STATUS MONITORING WELLS

 Location and Number

      In May of 1985, IT submitted a report titled "Proposed Ground Water
 Monitoring Program."   The monitoring program consisted of 23 new wells
 (MW-5A,  MW-6A,  MW-8A, MW-9A, MW-15, MW-16A,  MW-16B, MW-17A,
 MW-17B, MW.-18 and MW-101 through MW-110,  MW-112 through MW-114)
 [Figure  6] and two existing wells (MW-1A, which was a replacement for MW-1
 and MW-14). Twelve of the 23 new wells were drilled as replacement wells for
 the self-monitoring program  network and were reportedly completed in the
 same zone and located within  10 feet of the previous wells.  The remaining 11
 wells were newly located wells. In September 1985, five monitoring wells were
 added to the program to assess the extent of contaminant migration in response
 to the Cleanup and Abatement Order No. 85-004.  These wells were numbered
 MW-115 through MW-119 [Figure 8].

      Well MW-112 was intended to be the background/upgradient well for the
 interim status program. This well was  located offsite because of a mounding
 effect documented by IT consultants in the vicinity of the impoundments. At the
 time of  the  submission of the monitoring program proposal, this well  was
 suspected to be inadequate as a background well.  The well is screened in a
 zone which may not correlate with the remaining monitoring wells  drilled in the
 shallow  zone (silty clay/peat zone described by IT as the Bay Mud).

      The 1985 monitoring program proposal suggested that  another well be
 located  on the Vine Hill facility, for monitoring background water quality with
 respect  to the Baker facility.   No well was ever drilled to supply background
 water quality data for Baker. Facility personnel still considered well MW-112 to
 be  the  upgradient well at the time of the second RWQCB Cleanup  and
 Abatement Order (number 86-014), issued September  1986, even  though
 additional concerns arose about whether its location was  also within the
 influence of the ground-water mound created by the surface impoundments.

      The proposal also reported  that there was no upgradient/background
well within the Baker facility boundary for the deep ground-water zone (lower

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                                                                    117
 part of the older bay mud, sand and gravel zone). Well MW-206 on the Vine Hill
 facility was proposed as an alternate well.

       The  proposed ground-water monitoring program (dated  May  1985) is
 inadequate for monitoring the upgradient/background ground-water conditions
 at the Baker facility and, therefore, does not comply with the requirements for
 location and number of upgradient wells. The Cleanup  and Abatement Orders
 issued in January  1985 and  September  1986 also identified the  need to
 determine background water quality at the Baker facility.  At the time of the Task
 Force inspection, IT had  not identified an appropriate upgradient/background
 well or wells.

 Construction

      The interim status monitoring well network was constructed between July
 and November  1984.  The shallow wells (MW-5A, MW-6A, MW-8A,  MW-9A,
 MW-101  through MW-110 and MW-112) were drilled with 12-inch and 8-inch
 diameter hollow stem augers. The wells were sampled at 5-foot intervals with a
 barrel sampler or a modified California Drive sampler.  The 12-inch auger was
 used to make it possible to install and backfill the wells though the annular
 space between the well casing and the auger.

      PVC screen (4-inch diameter) and  blank PVC  casing were installed
 through the augers.  The annular space was backfilled with filter  sand  until the
 sand was a few feet above the top of the screen. A bentonite seal, 1 to  2 feet in
 length, was placed on top of the sand pack.  The boring annulus was then
 backfilled to the  surface with a  grout comprised of  Portland cement and
 bentonite. Steel surface casing, with a locking cap, was emplaced around the
 PVC casing to protect the well. A concrete slab was constructed  around the
 base of the  steel casing to provide a surface seal.

      The deep wells  (MW-15, MW-16A, MW-16B,  MW-17A, MW-17B, and
 MW-18) were drilled using a 4-inch rotary wash drilling method,  utilizing a
biodegradable mud which was  circulated during drilling to stabilize the boring
walls.  This practice may affect subsequent well water sample quality.  Boring
logs were prepared using continuous Shelby Tube samplers for the first 25 feet

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                                                                    118

 and then collected at 5-foot intervals thereafter.  Following completion of the
 logging and  sampling, the borings were reamed to either 8-inch  or  12-inch
 diameters using rotary wash techniques.  The deeper wells were  completed
 with similar materials used for the shallow wells, but were constructed in a mud
 filled hole. Refer to Figure 9 for the construction details (schematic).

       The adequacy of the construction of the interim status wells cannot be
 adequately evaluated because there  are  no as-built diagrams  or driller's
 completion records available for each well.  The summary table prepared for all
 the wells  does not always agree with the boring logs [e.g., the total depths of
 some wells do not agree with the boring logs (e.g., MW-8A, MW-9A, MW-101,
 MW-102,  MW-104, and MW-107)].   Wells numbered MW-8A,  MW-9A and
 MW-15 have conflicting data for depths to the cement grout and the bentonite
 seals.  It is also  unclear how the tops of the sand packs, bentonite seals, etc.,
 were verified from the completion description  and there are no  records
 available  regarding the volumes  of filter  pack material or cement  used in
 construction.  There  are  no  records  of grain-size analyses performed to
 determine whether the selection of screen size  or filter pack materials  are
 appropriate.

      There  is  no construction  information for. wells  numbered MW-1A,
 MW-13A,  and MW-14 and, therefore, the construction of these wells cannot be
 evaluated. Because well MW-14 is one of the original self-monitoring program
 wells, this well also does not have boring logs available and, therefore, the well
 should not be included in the interim status program because the construction
 cannot be verified.

      The screened intervals and  sand pack intervals in  many of the  interim
 status wells are  not appropriate to monitor a single formation.  The screened
 intervals for 16 wells  (MW-8A,  MW-15,  MW-16B, MW-17A, MW-17B, MW-18,
 MW-101, MW-102, MW-103, MW-104,  MW-105, MW-106, MW-109, MW-110,
 MW-112, and MW-114) penetrate zones of multiple permeabilities,  porosities
and composition.  Numerous wells  have more than the specified 2 feet of filter
pack above the top of the screen. Some wells were completed with as much as
9 feet of sand pack above the screened  interval (MW-8A, MW-9A and MW-18)

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                                                                 119
                                             ^	listing  Ground  Surf
                                         4"  I.D.  ABS Solid ?i=e
                                           Screw  Cap
                                             Concrete
                                         Bentonite Plug
                                          Perforated  Section
                                          Pea Gravel
                                          4"  I.D.  ASS Solid Pipe
IT/BAKER  DISPOSAL SITE
MARTINEZ, CALIFORNIA
              FIGURE   9
TYPICAL BAKER WELL  PROFILE  (Schematic)

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                                                                    120

 and, therefore, may produce water from zones, in addition to the intended zone
 for monitoring.

      Additional potential problems were noted for several wells during the
 course of the Task Force collection of water levels and samples, as follows:

            The  total  well depths measured differ as much as +2.57  feet
            (deeper) to -0.6 feet (shallower) from depths reported by IT.  The
            well depths differed more than 0.5 feet from the depths reported in
            the construction records for 11 of the 17 wells measured during
            the Task  Force  inspection (wells MW-5A,  MW-8A,  MW-15,
            MW-16A,  MW-16B, MW-102,  MW-103,  MW-106,  MW-110,
            MW-112, andMW-114).
            The PVC casing was broken on well  MW-16B.
            The  concrete apron around well  16B was  severely  cracked
            creating the potential for contamination from surface sources to be
            introduced into the well.

      The interim status monitoring network is not capable of determining the
 background/upgradient water quality conditions and many of the downgradient
 wells  are suspect because of conflicting/questionable construction data, or
 inability to determine the monitored formation because the screens and/or filter
 packs penetrate more than one flow zone.

      Following the 1986 Cleanup  and Abatement Order (86-014), 12
 additional wells, numbered MW-120 through MW-131, were drilled for the Baker
 facility. These wells were drilled between March and July 1987. At the time of
the Task  Force investigation several of the wells had not been drilled and most
 had not been  fully developed.  Construction records were  not available for
these  wells and the adequacy of the construction and completion of these wells
was, therefore, not evaluated by Task Force personnel.

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                                                                  121

          SAMPLE ANALYSIS AND DATA QUALITY ASSESSMENT

      This section provides an evaluation of the quality and completeness of
 interim status ground-water monitoring data gathered by IT for the Vine Hill and
 Baker facilities between January 1985 and June 1987.  Sampling and field
 measurements during this time period were conducted by IT personnel.  The IT
 Export  laboratory (Export,  Pennsylvania)  was primarily responsible for
 analyzing the ground-water samples for RCRA, State,  and  site specific
 parameters. From 1985 to 1987, IT Export subcontracted the analysis of some
 samples for TOC and TOX  to Kemron  Environmental (Williamstown, West
 Virginia) and the analysis of some samples for radiochemicals were made by IT
 Knoxville  (Knoxville, Tennessee).  In  November 1985, samples  analyzed for
 radiological parameters were sent to Controls  for Environmental Pollution
 (Santa Fe, New Mexico) by IT Export. In 1987, the State parameters for IT
 Baker included the substances listed in  the California Administrative Code,
 Title 23, Appendix III (CAC-Appendix III).  The IT Cerritos laboratory (Cerritos,
 California) analyzed samples from the Vine Hill and Baker facilities for some
 CAC-Appendix III  substances in  1987.   The IT laboratories  in Export and
 Cerritos were evaluated by Task Force personnel  and the findings of those
 evaluations are discussed in  this  section.  During the laboratory evaluations,
 operating  and analytical  procedures  and data records  were reviewed and
 analytical  equipment was inspected.  The  data records  reviewed include
 quarterly monitoring reports and associated internal data reports, raw data, and
 quality control data.

      The laboratory  evaluations revealed problems that could  affect the
 quality of the data  reported. The pH, conductance, TOC, and TOX data may not
 be reliable because of improper measurement procedures and the values  may
 be biased  toward not detecting ground-water contamination. Conductance data
 in some instances may be erroneous.  Total organic carbon (TOC) results
 actually represent  the determination of nonpurgeable organic carbon (NPOC)
 and excluded purgeable organic carbon (POC).  The analytical methods used
 in some instances were inappropriate for samples  containing  percent levels
 (10,000 mg/L or greater) of dissolved solids.  The  detection  limits for some
parameters were either not based on data generated by the laboratory or the
limits were inadequate to detect  contaminants  at low concentrations.  The

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                                                                    122

 values reported  for phenols on samples collected at Baker may represent
 contamination that would have been detected in blanks.  The problems cited
 could affect the reliability of the data in establishing background levels and in
 detecting releases of waste  into the ground water.  These problems  are
 discussed in the following sections.

       This report evaluates data generated under three Sampling and Analysis
 Plans prepared  by IT for  the Vine Hill and  Baker facilities to meet  the
 requirements of Federal  and State regulations (40 CFR 265.92 and California
 Administrative Code,  Title  23, Chapters, Subchapter 15,  Articles).   The
 Sampling and Analysis Plans include different monitoring parameters for each
 facility, but the laboratories performing the analyses for both facilities were the
 same.  Where monitoring requirements  were different, each facility will be
 addressed separately.  The  methods used to determine individual  parameters
 were the same for both facilities. Therefore, the analytical problems cited apply
 to both Vine Hill and Baker.

       The three  sampling and analysis  plans are dated  October 29, 1984;
 May 28, 1985;  and December 1986 [Table 20  and 21] and include the
 development of a  ground-water  monitoring plan covering the current  well
 networks. The plan prepared prior to 1984 describes ground-water monitoring
 for wells (with incomplete drilling and development records) that are no longer a
 part of the current well network.

       Monitoring, as required by RCRA regulations, has not been completed for
 the Vine Hill and  Baker monitoring well  networks.  A review of facility  and
 laboratory data records showed that some parameters were not reported for
 four quarters  of  background  monitoring.  Monitoring,  as required  by the
 sampling and  analysis plans, was  not completed within  some specified time
 periods.

      The  Vine Hill facility  did not complete four quarters of background
 monitoring  for the  drinking  water parameters fluoride and  nitrate [40 CFR
265.92(b)(1) and (c)(1)J.  In 1987,  the Vine Hill facility did not report quarterly
results for fluoride, nitrate, antimony, boron, zinc, color, odor, turbidity,  sulfide,
cyanide,  dissolved oxygen content (DOC), oxidation/reduction potential (Eh),

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                                                                                       123
                                           Table 20

          GROUND-WATER MONITORING ACCORDING TO SAMPLING AND ANALYSIS PLANS FOR
                                  JANUARY 1985 TO JUNE 1987
                                       IT Vine Hill Facility
           Plan:             October 29 1984   _ May 2fl 1985 _   December
           Sampling:          Jan.^June 1985  •   July-Dec. 1985 Jan.-Dec. 1986 *    Jan.-June 1987 c

Parameters Required                                  Testing Frequency Required
RCRA
40CFR265.92(b)(1) Q
40 CFR 265.92(b)(2) Q
40CFR265.92(b)(3) Q
Site Specific
Antimony
Boron
Calcium
Copper
Magnesium
Nickel
Potassium
Zinc
Temperature
Color/Odor
Turbidity
Total Dissolves Solids (TDS)
Total Suspended Solids (TSS)
Suttide
Cyanide
Alkalinity
Chemical Oxygen Demand (COD)
Dissolved Oxygen Content (DOC)
Oxydatbn/Reduction Potential (Eh)
Acetone
n-Butanol
2-Butanol
2-Butanone
Cyclohexanone
Isopropanol
Methylene Chloride
Tetrahydrofuran
Chlorinated Pesticides (>0.05 ppm)
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-------
                                           Table 21

          GROUND-WATER MONfTORING ACCORDING TO SAMPLING AND ANALYSIS PLANS FOR
                                    JUNE 1985 TO JUNE 1987
                                        IT Baker Facility
                                124
           Plan:
           Sampling:

Parameters Required
Mav 28.1985
October 29. 1984   	
Jan.-June 1985 *   July-Dec. 1985 Jani-Dec. 1986 t>e

                       Testing Frequency Required
December 1986*
Jan.-June 1987 d
RCRA
40CFR265.92(b)(1) Q Q • Q '
40CFR265.92(b)(2) Q Q • Q(A) '
40 CFR 265.92(b)(3) Q Q Q(S)
Site Specific
Antimony
Boron - x X
Calcium - XX
Copper - x X
Magnesium - x X
Nickel - x X
Potassium - x X
Zinc
Temperature - x X
Color/Odor -XX
Turbidity - -
Total Dissolves Solids (TDS) - X X
Sutfide
Cyanide . -
Alkalinity - x X
Chemical Oxygen Demand (COD)
Dissolved Oxygen Content (DOC)
Oxydation/Reduction Potential (Eh)
Acetone
n-Butanol •
2-Butanol
2-Butanone
Cydohexanone
Isoprepanol
Methylene Chloride
Tetrahydrofuran
Chlorinated Pesticides (>0.05 pom)
CA - Appendix III
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X rrtqmncy not cftaefr tptdffttl in pian
A Annum?
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(J f£*MWr*!X^tyteM»lb&quart»notb»c*orcurdmon^
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                                                                    125

 and volatile organics, as  specified by the December  1986 Sampling  and
 Analysis Plan.

       The  Baker facility  did not  complete four quarters of background
 monitoring for drinking water parameters (arsenic, barium, lead, nitrate, silver,
 pesticides,  herbicides,  and  radionuclides), nor  for ground-water quality
 parameters (iron  and manganese).  In 1987, the Baker facility did not report
 quarterly results for all the  parameters  required by the  December 1986
 sampling plan.  The parameters not reported were arsenic, barium, lead, nitrate,
 silver, pesticides, herbicides, radionuclides, iron, manganese, temperature,
 color, odor, turbidity, sulfide, cyanide, chemical oxygen demand (COD), DOC,
 and EH.

 INITIAL YEAR OF MONITORING

       RCRA regulations [265.92(c)] require quarterly  monitoring of  all wells
 during the initial year to establish background values.  Quarterly monitoring of
 the upgradient wells must  include quadruplicate measurements for  the  four
 parameters used as  indicators  of  ground-water contamination [40 CFR
 265.92(b)(3), pH, specific conductance, TOC, and TOX].  Quarterly monitoring of
 all wells must include  measurement for the  parameters establishing ground-
 water quality [40 CFR 265.92(b)(2)] and for the parameters characterizing the
 ground water suitable as a drinking water supply [40 CFR 265.92(b)(1)j.

 Vine Hill Facility

 The facility completed  the testing specifically required  in the 1984 and 1985
 Sampling and  Analysis  plans during the initial year of monitoring for all
 parameters  except fluoride and nitrate  [40 CFR 265.92(b)(1), drinking water
 suitability parameters].  The facility had reported two quarters of results for these
 parameters  by December 1985.  The facility did not statistically evaluate the
downgradient indicator  parameters against the upgradient parameters because
 no wells were designated as upgradient.

      In January  1985, Vine Hill  initiated quarterly monitoring pursuant to 40
CFR 265.92(c) on the  RCRA well network consisting of 11 wells numbered

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                                                                   126

 MW-201 to MW-207, MW-209 and MW-212 through MW-214. None of the wells
 were specifically designated upgradient or downgradient at that time.  The
 facility took quadruplicate measurements for the indicator parameters on all
 wells. Beginning in July, the 1985 Sampling and Analysis Plan required that
 the  well samples be analyzed annually for parameters pursuant to State
 requirements (calcium,  magnesium,  potassium,  alkalinity); temperature
 measurements were required quarterly. Additional parameters listed in the May
 1985 plan include: boron, copper, nickel, zinc, color/odor, total dissolved solids,
 sulfide, and cyanide.  The frequency of monitoring for these parameters was
 unclear, therefore, no assessment could be made as to whether monitoring for
 these additional parameters was completed.

 Baker Facility

      The  Baker facility did not complete four  quarterly sampling periods of
 background monitoring for drinking water parameters (arsenic, barium, lead,
 nitrate, silver, pesticides,  herbicides, and radionuclides)  nor for ground-water
 quality parameters (iron and manganese).

      In January 1985, Baker initiated quarterly monitoring pursuant to 40 CFR
 265.92(c).  The Baker RCRA/ISD well network consisted of 25 wells  (MW-1A,
 MW-5A, MW6A, MW-8A, MW-9A,  MW-13A, MW-14, MW-15, MW-16A and B,
 MW-17A and B,  MW-18,  MW-101 through MW-110 and MW-112 through
 MW-114).   The  well  numbered  MW-112 was tentatively designated  as
 upgradient  at that time. Beginning July 1985, 25 wells  (excluding MW-13A)
 were monitored.   This well network consisted of 23  new wells  and 2 original
 wells.  The facility completed four quarters of testing for the RCRA  indicator
 parameters in 1985.  The facility  completed two quarters of testing for the
 ground-water quality parameters and drinking water suitability  parameters in
 1985.  The four  quarters of background monitoring for ground-water quality
 parameters (specifically, iron and manganese) and drinking water parameters
 (specifically, arsenic, barium, lead, nitrate,  silver, pesticides, herbicides, and
 radionuclides) had not been completed by December 1985.  (Background
 monitoring for these parameters had  not been completed by June  1987.)  No
monitoring data could be located for  MW-113 after August 1985.  The facility
began collecting  background monitoring  data  for  MW-117,  MW-118, and

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                                                                   127

 MW-119 in October 1985 (four quarters of data for all RCRA parameters had not
 been collected by June 1987).

       In July 1985,  the  facility began  to  monitor the wells  monthly for
 parameters  pursuant  to  State requirements  (boron, calcium, copper,
 magnesium, nickel, potassium, temperature, color, odor, solids, and alkalinity).
 The frequency of the monitoring required for these parameters was not clearly
 stated in the May 1985  Sampling  and Analysis  Plan and, therefore, no
 assessment could be made as to whether the  monitoring for these State
 parameters was completed.

 Laboratory Performance

      The pH, conductance, TOC, and TOX data reported by the facilities may
 be unreliable because  of improper measurement  procedures.  The  facility
 followed the  1984 and 1985 Sampling  and Analysis plans which describe
 procedures for measuring  pH, conductance, TOC, and TOX in four replicate
 samples instead of taking four replicate measurements from a single sample, as
 required by 40  CFR 265.92(c)(2).  Using the procedure in the facility plans
 affects the statistical evaluation of the analytical data  and, thus, the detection of
 ground-water contamination.  The evaluation of results from four different
 samples could theoretically show larger scatter (because of differences in the
 samples taken)  than the results from  measuring a single sample in replicate.
 The results reported by the facilities  could be biased toward not detecting
 ground-water contamination.

      Field specific conductance values reported  for the  Vine  Hill and Baker
 facilities may be erroneous.  The field value reported for MW-203 (Vine Hill) was
 129,500 ^mhos/cm and the laboratory value (found in the internal  laboratory
 report) was 40,600 ^mhos/cm; the field values reported for other samplings at
 MW-203 in 1985 ranged from 38,000 to 52,000 ^mhos/cm.  Field specific
conductance values reported for Baker well water samples in April 1985 (wells
 MW-14, MW-16B, and MW-103) may  be erroneous.  For example, the  field
conductance values reported were three to four times the values  reported in the
other quarters for most of these wells.  The value reported for MW-16B (Baker)
was 10 times less than the values reported in the  other quarters for this well.

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                                                                   128

 The field value reported for MW-16B was 440 ^mhos/cm while the laboratory
 value was 40,700 ^mhos/cm; the other field values reported in 1985 for this well
 ranged from 31,600 to 52,800 ^mhos/cm. The field value reported for MW-14
 (Baker) was <100,000 jimhos/cm,  while the laboratory value (located in  the
 internal laboratory report) was 61,300 ^mhos/cm; the field values reported for
 other samplings at MW-14 in 1985 ranged from  52,800 to 88,000 jimhos/cm.
 These questionable field values were also  not supported by changes in  the
 levels of the major ions measured for the samples.

      The  results for TOC may be biased low.   The values reported for TOC
 represent only NPOC because of the analytical method used.  The method
 involved acidifying the sample and purging  it with  nitrogen gas before
 determining the organic carbon content.  This procedure results in the loss of
 purgeable  (volatile) organic carbon.  Total Organic  Carbon (TOC) can be
 defined as the sum of NPOC and POC.  In order to indicate that NPOC results
 are equivalent to TOC results, the laboratory must measure POC to establish
 that the level of POC is not a significant contributor to TOC. No volatile organic
 results were located for these samples in  1985 to  indicate that the level of POC
 was not significant.

      The results reported for TOX may be unreliable as an indicator of low
 level ground-water contamination  by halogenated organics.  Some samples
 analyzed contained percent levels of dissolved salts (as indicated  by chloride
 data) which can  contribute to apparent TOX. The TOX values reported were
 based on the detection limit published in  the analytical method and not on the
 limit that was  achievable  in the laboratory for  the samples analyzed.   An
 estimate of the limit achievable for these samples can be calculated using
 chloride levels since, typically, 50 mg/L  chloride could result in an apparent
 TOX of 1 ng/L For example, in Baker well MW-1 A, with average chloride levels
 of 30,000 mg/L, the apparent TOX contributed by chloride could be 0.6  mg/L
 (600 ^g/L); in  Vine Hill well MW-204, with average chloride levels of 25,000
 mg/L The apparent TOX contributed by chloride could be 0.5 mg/L (500 |ig/L).
These values would also approximate the achievable detection limits for these
samples. The values and detection limits  reported for TOX from these wells (in
all quarters) do not appear to reflect the contribution of inorganic chloride and
may be erroneous.  TOX  measurements, using standard methodology, are

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                                                                   129
 inappropriate for determining low level  halogenated organics in samples
 containing percent levels of dissolved salts.  Purgeable organic halide (POX)
 measurements could be used as an  indicator of low level volatile organic
 halides.

       Replicate measurements for TOX on Vine Hill samples were  imprecise.
 This imprecision could have been caused by taking measurements from four
 sample containers instead of from one sample, as the regulations require. For
 example,  well MW-203 showed replicate measurements of 3.5  to 5.2 mg/L in
 June 1985 and 5.9 to 7.9 mg/L in December 1985.

       The results reported for phenols from samples collected at  the Baker
 facility may be unreliable.  No blank sample data were found  to support the
 values reported in 1985. The levels reported may represent contamination that
 could have been detected in blanks. The results reported for Vine Hill samples
 based  on  detection limits less than 0.002 mg/L (chloroform extraction method)
 should be considered unreliable.  The detection limits reported in  1985 were
 not supported by the  levels and variability of blank values.  Blank values, using
 this  method, were  as high as 0.004 mg/L meaning the laboratory could not
 reliably report values less than 0.004 mg/L.

      The chloride results reported for Baker well MW-1A in January 1985 may
 be erroneous. The value of 284,000 mg/L is approximately 10 times the value
 reported for this well in other quarters during 1985.  This questionable value is
 also not supported by a comparable change in conductance.

      The sulfate values in January 1985 for Baker well numbers MW-15 and
 MW-103 may be incorrect. The value reported for MW-15 was 5.6 mg/L, but the
 range of values reported in 1985 for this well was 160 to 260 mg/L  The value
 reported for MW-103  was 240 mg/L; the range of values reported in  1985 was
 <1 to 6 mg/L.

      Some of the  elemental constituents determined using atomic absorption
 (AA) techniques should be considered suspect.  Selected elements were
determined by graphite furnace AA (arsenic, barium, cadmium, chromium, lead,
selenium, and thallium). The other elements (except mercury) were determined

-------
                                                                     130

 by flame AA.  For samples determined by graphite furnace, high  dissolved
 solids  concentrations can  cause so  much  molecular background that the
 analyte signal cannot be reliably distinguished from background.  The method
 of standard addition was not used, when samples were analyzed by graphite
 furnace, to mitigate matrix effects present as a result of high levels of dissolved
 solids.  Arsenic and selenium should have been determined by hydride
 generation flame AA, because this method is more capable of achieving the
 limits required by the regulations in samples containing high concentrations of
 dissolved solids. For samples determined  by the flame technique,  ionization
 interference  can be  significant.   The  high dissolved solids  concentrations
 present in some samples probably interfered with the determinations made by
 flame AA since no ionization reagents  were reportedly used by the laboratory
 during the analyses.

       Some  elemental constituents for Vine  Hill ground-water samples were
 reported at detection limits greater than allowed by the ground-water protection
 limits for wells in the fourth quarter of 1985. In some instances, the results for
 arsenic, selenium, and lead (graphite furnace) from Vine  Hill wells  MW-201,
 MW-202, MW-203, MW-205, MW-206, and MW-214 were  inadequate for
 establishing background levels near or below the  regulatory limits. The results
 showed instances of  silver (flame) being reported at detection limits greater
 than the regulatory limits in wells MW-201, MW-203, and MW-209. The results
 also showed instances of chromium and lead (graphite furnace) being reported
 at the regulatory limits in the fourth quarter.  Thus, background levels near or
 below the regulatory  limit were not reliably established for these elemental
 constituents.

      The results reported for pesticides and herbicides may not be adequate
 for establishing background levels near or  below the  regulatory  limits.  The
 detection limits reported for these parameters are published values and do not
 necessarily represent values achievable in the IT Export laboratory.   The
 methods used to determine these parameters require that the  detection limits
 reported represent what is achievable in  the laboratory.

      The methodology used for determining gross alpha and gross beta  was
inappropriate  for samples containing high  dissolved solids. However, most

-------
                                                                     130

 by flame AA.  For samples determined by graphite furnace, high  dissolved
 solids concentrations can  cause so much  molecular  background that the
 analyte signal cannot be reliably distinguished from background.  The method
 of standard addition was not used, when samples were analyzed by graphite
 furnace, to mitigate matrix effects present as a result of high levels of dissolved
 solids.  Arsenic and selenium should have been determined by hydride
 generation flame AA, because this method is more capable of achieving the
 limits required by the regulations in samples containing high concentrations of
 dissolved solids.  For samples determined  by the flame technique,  ionization
 interference  can be  significant.   The  high dissolved solids  concentrations
 present in some samples probably interfered with the determinations made by
 flame AA since no ionization reagents were reportedly used by the laboratory
 during the analyses.

       Some  elemental constituents for  Vine  Hill ground-water samples were
 reported at detection limits greater than allowed by the ground-water protection
 limits for wells in the fourth quarter of 1985.  In some instances, the results for
 arsenic,  selenium, and lead (graphite furnace) from Vine  Hill wells  MW-201,
 MW-202, MW-203,  MW-205, MW-206, and MW-214 were  inadequate for
 establishing background levels near or below the regulatory limits. The results
 showed instances of  silver (flame)  being reported at detection limits greater
 than the  regulatory limits in  wells MW-201, MW-203, and MW-209. The results
 also showed instances of chromium and  lead (graphite furnace) being reported
 at the regulatory limits in the fourth quarter.  Thus, background levels near or
 below  the regulatory  limit were not reliably established for these elemental
 constituents.

      The results reported for pesticides and herbicides may not be adequate
 for establishing background levels near or  below the  regulatory  limits.  The
 detection limits reported for these parameters are published values and do not
 necessarily represent values achievable in the IT Export laboratory.   The
 methods  used to determine these  parameters require that the  detection  limits
 reported represent what is achievable in the laboratory.

      The methodology used for determining gross alpha and gross beta was
inappropriate  for samples containing  high  dissolved solids. However,  most

-------
                                                                    131

 standard procedures, including those referenced in EPA publications, do not
 reliably meet the ground-water protection limits for gross alpha and beta in the
 presence of high amounts of dissolved solids.  Methodology (Whittaker, 1985)
 has been suggested for analyzing these samples;  it would  be necessary to
 validate its use on these particular samples.

       Some gross alpha and beta results  are also suspect because values
 were reported at detection  limits that are not theoretically achievable in the
 presence of high amounts  of dissolved  solids.  For example, in Baker well
 number MW-1A and Vine Hill well number MW-203 (quarters one and two,
 1985) gross alpha concentrations were reported as not detected at 2 picocuries
 per liter (pCi/L). This detection limit is theoretically not achievable for samples
 like those from  wells MW-1A  and  MW-203, shown  historically to  contain
 dissolved solids at 50,000 mg/L and 30,000 mg/L, respectively.  Using standard
 methodology, it is probably not possible to achieve a detection limit of less than
 100 pCi/L for gross alpha for these samples. Many of the gross beta results
 should also be considered suspect for the reasons just stated.

 MONITORING IN  1986

      RCRA regulations [265.92(c)j require semiannual monitoring  for the
 indicator  parameters (including  quadruplicate measurements on all  RCRA
 wells) and annual monitoring for ground-water quality parameters on the wells
 when background monitoring is complete.

 Vine Hill Facility

      The Vine Hill  facility  completed the  semiannual/annual monitoring in
 1986 for  the wells numbered MW-201  to  MW-207, MW-209 and MW-212
through MW-214 (11 wells).  The facility began background monitoring on three
additional wells numbered MW-216, MW-218, and  MW-219 in  April 1986 and
completed the testing required in April 1987.  The Vine Hill facility reported one
additional quarter of background  monitoring (begun in  1985 on the original
RCRA network of 11 wells) for fluoride and nitrate.  By December 1986, the
facility had completed only three  quarters of background monitoring  (of the
original 11 wells) for these parameters.

-------
                                                                     132

       Vine Hill well water samples were also required to be analyzed annually
  for the same State parameters as  in  1985; this monitoring was competed.  The
  facility reported results quarterly for the  additional parameters listed in the  May
  1985 plan. No assessment was made as to whether monitoring was completed
  for these  additional parameters, because the frequency required by the  plan
  was unclear.

  Baker Facility

       The Baker facility completed the semiannual monitoring for the indicator
  parameters required in 1986.  The facility did not complete the two quarters of
  background  monitoring for ground-water quality and drinking water parameters
  remaining from the 1985 RCRA requirements and, therefore, could not proceed
  to annual  monitoring for ground-water quality parameters.  The facility reported
  results for four out of six (chloride,  phenols, sodium, and sulfate) of the ground-
  water parameters.

       The Baker facility well water samples were also required to be analyzed
  for the same State parameters as in 1985.  The frequency of the  monitoring
  required was unclear for the Baker wells in the  1985 Sampling and  Analysis
  Plan, so no  assessment could be  made as to whether the monitoring for the
  State parameters was completed.  The facility reported results quarterly for the
  State parameters in 1986.

  Laboratory Performance

       In  1986, the elemental constituents (except  arsenic, selenium,  and
 mercury) were  determined after digestion using  Inductively Coupled Atomic
 Emission Spectroscopy (ICP).  The ICP technique is inadequate for meeting
 ground-water protection limits when determining cadmium, chromium, and lead
 in  the presence of high  levels of dissolved solids.   These elements  could
•- possibly be determined by ICP within the regulatory limits by using the method
 of standard additions.  These elements  could potentially be determined  within
 the limits by using graphite furnace  AA with Zeeman background correction, the
 LVov platform or matrix modifiers such as palladium or ascorbic acid.

-------
                                                                     133

       The other findings of field and laboratory procedures discussed  in the
 initial year of  monitoring are also applicable to the  data reported for both
 facilities in 1986, since most procedures and methods did not change.

 MONITORING IN 1987 - JANUARY TO JUNE

 Vine Hill Facility

       RCRA regulations require  semiannual/annual monitoring, as in 1986.  In
 January 1987,  the facility was required by the December 1986 Sampling and
 Analysis Plan to begin quarterly  monitoring for the RCRA parameters and site
 specific parameters.   The site  specific  parameters  include the following
 inorganic and miscellaneous parameters:  antimony,  boron,  calcium, copper,
 magnesium,  nickel, potassium, zinc, temperature, color, odor, turbidity, total
 dissolved solids,  sulfide, cyanide, alkalinity, chemical  oxygen demand (COD),
 dissolved oxygen content (DOC), and oxidation/reduction potential (Eh).  The
 facility was also required to begin quarterly monitoring for the following volatile
 organic parameters:  acetone, n-butanol, 2-butanol, 2-butanone, cyclohexane,
 isopropanol,  methylene chloride, tetrahydrofuran, and chlorinated pesticides
 (exceeding 0.05 ppm).

       Review of raw data records and internal reports at the facility and at IT
 Export  laboratory indicate that one  sampling of semiannual monitoring  for
 RCRA indicator parameters was completed  in 1987  along  with the annual
 monitoring for.RCRA ground-water quality parameters.  The monitoring for site
 specific parameters  was  not completed.  The field  values for color,  odor,
 turbidity, DOC,  and Eh were not  located.  The December 1986 Sampling and
 Analysis Plan requires that samples be analyzed for fluoride, nitrate,  antimony,
 boron, zinc, sulfide, cyanide, and volatile organics in 1987; no records could be
 found to show this.

      The findings of field and laboratory procedures discussed in the previous
years for the IT Export laboratory were also applicable in 1987.

-------
                                                                    134

 Baker Facility

       RCRA regulations require semiannual/annual monitoring as in 1986 if
 background monitoring has been completed.  The facility had completed one
 sampling  of the semiannual monitoring  required for indicator parameters by
 June  1987.   The  Baker facility still had not completed  four  quarters of
 background monitoring for all the ground-water quality parameters (specifically
 iron and  manganese) and drinking  water parameters (specifically arsenic,
 barium, lead, nitrate, silver, pesticides, herbicides, and radionuclides) that was
 initiated in 1985.

       In January 1987, the facility was required by the 1986 Sampling and
 Analysis Plan to begin quarterly monitoring for the RCRA parameters and site
 specific parameters.  The  site specific  parameters  include  the  following
 inorganic  and  miscellaneous parameters:  antimony, boron, calcium, copper,
 magnesium, nickel, potassium, zinc,  temperature, color, odor, turbidity, total
 dissolved  solids, sulfide, cyanide, alkalinity, chemical oxygen demand (COD),
 dissolved  oxygen content (DOC), and oxidation/reduction potential (Eh).  The
 facility was also required to begin quarterly monitoring for the following volatile
 organic parameters:  acetone, n-butanol, 2-butanol, 2-butanone, cyclohex-
 anone, isopropanol, methylene chloride, and tetrahydrofuran.  The facility was
 required to begin annual monitoring for chlorinated pesticides (exceeding 0.05
 ppm) and for the substances in CAC-Appendix III.

      The only sampling .results located for January to June 1987 showed
 complete results for the RCRA  indicator parameters and incomplete results for
 the ground-water and drinking water parameters required by the 1986  plan.
 The ground-water monitoring reports showed that the results listed for the site
 specific parameters were also not complete.  The  report did not include
 measurements for temperature, color, odor, turbidity, sulfide, cyanide, COD,
 DOC, Eh,  nor any organic parameters. However, results for the volatile organic
 parameters were found in the Export laboratory data records for February 1987.
The facility submitted results for the majority of the substances listed in CAC-
Appendix III.

-------
                                                                    135

       The results for the volatile organic compounds reviewed at Export may
 be unreliable.  These organics were analyzed by using gas chromatography/
 mass spectrometry (GC/MS).  The results were tabulated based  on published
 detection limits, not on  limits known to be achievable in the  laboratory.  The
 analytical method used required that the values reported be based on detection
 limits determined by statistically evaluating low level standard data and  blank
 data generated using the same procedures and instruments  used to analyze
 the samples.

      The other findings of field and laboratory procedures discussed in the
 initial year of monitoring are also applicable to the  data reported in 1987, as
 most procedures and methods did not change.

 Analyses for California Appendix III Substances

      The IT Cerritos laboratory submitted analytical results for the majority of
 the substances listed in CAC-Appendix III in a report to the State in June 1987.
 The report contained results for wells  from both Vine Hill and  Baker,  even
 though analysis for CAC-Appendix III compounds were not required at Vine Hill
 by  the December 1986 Sampling and Analysis Plan.   The report covered
 samples  taken at the facilities from January to March  1987. The CAC-Appendix
 III incorporates parameters from  EPA 40 CFR 261, Appendix VIII list of
 hazardous substances  plus additional parameters  listed by the  State  and
 includes  approximately 800 elements and compounds and 70 wastes.  The
 laboratory reported quantitative results  for 50% of the substances listed and
 possible  qualitative results for an additional 20% of the substances listed using
 established and modified standard methods. The remaining 30% of the listed
 materials were not determined because suitable methods could not be found,
 developed  or implemented  or standards  located in  the time allotted  for the
 analyses.  The substances determined  at the Cerritos  laboratory include
 elemental constituents,  anions, sulfide,  cyanide,  volatile, and  semivolatile
 organic  compounds,  chlorinated  pesticides, PCBs, herbicides, amines,
 hydrazines, peroxides, and  formaldehyde.  The Cerritos laboratory personnel
compiled data from other IT laboratories and other private laboratories that
analyzed the samples for dioxins,  aflatoxins,  asbestos, organophosphorous
pesticides,  carbamates,  alcohols, creosote, coal tar, urea, and nitriles.  The

-------
                                                                     136

 problems affecting the data quality of parameters determined at Cerritos are
 discussed in the following paragraphs.

      The elemental constituents determined by graphite furnace AA and ICP
 are suspect in some  instances because the methods were inappropriate for
 samples containing high  levels of dissolved solids.   The  methods  were
 inappropriate for the reasons previously mentioned.  Arsenic, selenium, lead,
 and thallium were determined by graphite furnace, while other elements (except
 mercury, potassium and sodium) were determined by ICP. The laboratory did
 not have a defined method for establishing detection limits when using these
 techniques, as required by the State.  The documentation  of the standards used
 in ICP determinations was not adequately maintained for inspection and review,
 as required by the State.

      The Ion Chromatography determinations of anions were incomplete. The
 strong acid anions (bromide, chloride, fluoride, iodide, nitrite, nitrate, phosphate,
 and sulfate) were determined but were  not  supported by verifiable detection
 limits, as required by the State.  The weak acid anions (i.e.,  formate, acetate,
 and tartrate) were not determined, although required.

      The sulfide and cyanide results may be biased low because of improper
 handling of the samples.  The samples were not checked  for pH upon arrival at
the laboratory to ensure that sufficient preservative had been added  in the field
in order to prevent the loss of these species prior to analysis.

-------
                             REFERENCES
1.   Whittaker, E. L., "Test Procedure for Gross Alpha Particle Activity in Drinking
    Water Interlaboratory Collaborative Study," October 1985

-------
                   APPENDICES





A    SPECIFIC ANALYTICAL RESULTS - VINE HILL



B    SPECIFIC ANALYTICAL RESULTS - BAKER

-------
                              APPENDIX A
                        Specific Analytical Results
                            IT Vine Hill Facility
                           Martinez, California
Table A-1    Sample Preparation, Analytical Techniques and Methods
Table A-2   Organic Results
Table A-3   Limits of Quantitation for Organic Compounds
Table A-4   Total Metal Results
Table A-5   Reid Measurements and General Analytical Parameters

-------
                              APPENDIX A
                            IT Vine Hill Facility
                           Martinez, California

 SPECIFIC ANALYTICAL RESULT.^

      Table A-1  lists the  Sample  Preparation,  Analytical Techniques  and
 Methods used by the contract laboratory (CL).  Table A-2 shows the Organic
 Results for samples in which at least one compound was detected.  Table A-3
 lists the limits of quantrtation (LOQ) achieved for the organic analyses; the LOQs
 for the dioxins/dibenzofurans represent estimated values calculated by NEIC
 using the lowest standard concentration analyzed by the CL.  Table A-4  lists
 metals analysis  results.  Table  A-5 lists  field  measurements and  general
analysis results.

-------
                                                             Table A-1
                                 SAMPLE PREPARATION AND ANALYSIS TECHNIQUES AND METHODS
                                                         IT Vine Hi! Faality
                                                         Martinez, California
    Parameter
                             Preparation Technique
                                                                            Analysis Technique
                                                                                                               Method Reference
      Specific Orpanir Qflnfititllftnlfi
 Vola tiles
 Semi-volatiles
 Pestiddes/PCB
 Herbicides
 Dioxins and
  Diobenzofurans
                       Purge and trap
                       Methylene chloride extraction
                       Methylene chtoride/hexane extraction
                       Diethyl ether exlractkm/methylation
                       Methylene chtoride/hexane extraction
    Non-specilic Qroanfc Parameters
POX                   None
                       Carbon absorption
POC
NPOC
                       None
                       Acidify and purge
       Elemental Constituents
Mercury               We! digestion (or dissolved and total
As. Pb, Se and Tl       Acid digestion lor total
Other Elements         Acid digestion (or total

       Reid Measurements
Conductance          None
PH                    None
Turbidity               None
     General
Gas Chromalography - Mass Spectroscopy
Gas Chromatography - Mass Spectroscopy
Gas Chromalography with Electron Capture Detection
Gas Chromalography with Electron Capture Detection
Gas Chromatography - Mass Spectroscopy
Purgable combusted. Microcoulomelry
Carbon combusted. Microcoulomelry
Purgable combusted. Non-dispersive Infrared
UV PersuMale. Non-dispersive Infrared


Cold Vapor Atomic Absorption Spectroscopy
Furnace Atomic Absorption Spectroscopy
Inductively Coupled Plasma Emission Spectroscopy
                                                            ElectromeUic. Wheatstone Bridge
                                                            Polenliometry
                                                            Nephelometric
CLP Method3
CLP Method
CLP Method
Method 8150*>
Method 8280b
EPA 600/4-84-008
Method 90206
No reference
Method 415 1C
                                                                                                               CLP Method
                                                                                                               CLP Method
                                                                                                               CLP Method
                                                    Method 120.1C
                                                    Method 150.1C
                                                    No reference
Nitrate None
Sulfate None
Chloride None
Nitrite None
Bromide None
Fluoride None
oulfide None
Phenol Automated distillation
Cyanide Manual distillation
a) Contract Laboratory Program. IFB methods
b) Test Methods for Evaluating Solid Wastes. SW846
c) Methods tor Chemical Analysis of Water and Wastes
Ion Chromatography
Ion Chromatography
Ion Chromatography
Ion Chromalography
Ion Chromatography
Ion Chromatography
lodometric. Tilration
Colormelric. Distillation. Automated 4-AAP
Pyridine Pyrazotone Colorimelry


EPA -600/4- 7Q n?n
EPA Method 300.0
EPA Method 300.0
EPA Method 300 0
EPAMelhod 300.0
EPA Method 300.0
EPA Method 300 0
Method 9030^
Method 9066^
Method 90 10^




-------
            TablaA-2

SPECIFIC ORGANIC CONSTITUENTS
        IT Vina HiU Facility
        Martinaz. California
                                                                                              ro
STATION:' MW-1 15
SMONO. MQB413
COMPOUND ng/L ,
Carbon disuNida ND
1.2-Dichlorobanzana ND
Banzana 3. a
Toluana 13.
Xylanas ND
4-Mathyl-2-pantanona ND
Vinyl acalata 84.
di-n-Butyl phlhalala fO
Banzoic acid ND
Phenol 100.
2-Mathylphanol ND
4-Mathylphanol 6. a
2.4-Dimathylphanol ND
LOQ FACTORS6
Volatile IX
Semivolalile 2X
Pasticida IX
Dioxins and Furans NA c
MW-1 16
MQB412
jig/L
ND
ND
ND
ND
ND
ND
ND
ND
ND
2. a
ND
ND
ND

1X
2X
IX
NA c
MW-1 17
MQB415
ML
3. »
ND
ND
5.
ND
M)
ND
3. a
4. a
ND
ND
ND
ND

IX
2X
IX
NA c
MW-1 19"
MQB405
ng/L
2. a
ND
4. a
ND
ND
ND
ND
ND
ID
ND
ND
ND
ND

IX
2X
1X
IX
MW-203
MQB439
M9/L
ND
2.
11.
2.
3.
4.
93.
1.
ND
17.
13.
3
7.

IX
2X
IX
IX


£

a
£
3

a




a





No organic compounds were detected in MW-204. MW-214. and MW-219
' * Monitoring well MW- 1 1 9 was sampled and
averaged for report.
ND Compound was not detected.
a Estimated concentration. Compound was
QuanlHation (LOO).
analyzed in triplicate (MQB405. 406,

detected, but the

b LOO Factor is the factor that the LOQ must be multiplied by to
c Sample not analyzed.

concentration was

407); results were

below the Limit of









correct the LOO for dilutions.

-------
         Table A 2 (cont.)

SPECIFIC ORGANIC CONSTITUENTS
        IT Vin« Hill Facility
        Martinez. California
STATION:
SMONO.
COMPOUND
Chloroform
Carbon disuMide
1.2-Dichloroethane
Vinyl acetate
Vinyl Chloride
Benzene
Toluene
Xylenes
Ethylbenzene
4 Methyl-2-pentanone
di-n-Butyl phthalale
Phenol
2.4.5-TP
LOQ FACTORS6
Volatile
SemiviolatUe
Pesticide
Dioxins and Furans
MW-205'
MQB422
»ig/L
21. a
ND
320.
240.
350.
22. a
17. 4
ND
ND
ND
ND
ND
ND

IX
5X
IX
IX
MW-206
MQB424
HQ/L
ND
2. a
ND
ND
ND
1. a
3. a
ND
ND
ND
ND
ND
ND

IX
2X
IX
IX
MW-207 MW-209
MQB427 MQB432
H9A JioA
ND ND
ND 2. a
ND ND
ND ND
ND ND
1. a ND
ND ND
ND ND
ND 3. a
ND 2. a
ND 2. a
ND ND
NA ND

IX IX
2X 2X
NA c IX
NA c IX
MW-212
MQB438
H9/L
ND
ND
ND
ND
ND
ND
ND
ND
ND
6. a
ND
ND
0.2

IX
2X
IX
IX
MW215
MQB428
H9/L
ND
ND
ND
ND
ND
6.
2. a
13.
3. a
ND
ND
8. a
ND

IX
2X
IX
NA c
MW-216
MQB431
H9/L
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
1. a
ND
ND

IX
2X
IX
1X
' Monitoring well MW-205 was sampled and analyzed in triplicate (MQB405. 406. 407); results were averaged lor report
NO Compound was not detected. '
f ft^f ' ** concentration. Compound was detected, but the concentration was below the Limit of Quantitation (LOO)
b LOQ Factor is the factor that the LOO must be multiplied by to correct the LOQ tor dilutions
c Analysis not requested

-------
         Table A 2 (con!)

SPECIFIC ORGANIC CONSTITUENTS
        IT Vina Hill Facility
        Martinez, California
STATION:
SMONO.
COMPOUND
Carbon disuBide
1.1-Dichloroethana
trans- 1 ,2-Dichloroethene
Trichloroethana
Vinyl chloride
Benzana
Toluene
Xylanas
Ethylbenzene
Chtorobenzene
di-n-Butyl phthalate
Phenol
4-Methylphenol
LOQ FACTORS (b)
Volatile
Semivolatile
Pesticide
Dioxins and Furans
ND Compound was not detected.
MW-218
MQB429
HQ/L
ND
ND
ND
ND
ND
3. a
ND
ND
ND
ND
ND
ND
ND

IX
2X
IX
IX

MW222
MQB441
UQ/L
ND
ND
ND
ND
ND
ND
16.
ND
ND
ND
1. a
ND
ND

IX
2X
IX
NA c

MW-227
MQB437
u.fl/L
3. a
ND
ND
ND
ND
ND
2. a
ND
ND
ND
ND
ND
ND

IX
2X
IX
IX

G-6
MQB402
ug/L
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
2. a
ND
ND

IX
2X
IX
IX

a Estimated concentration. Compound was detected, but the concentration was below the Limit ol Quantitation
b LOQ Factor is the factor that the LOQ must be multiplied by to correct the LOQ for dilutions.
c Analysis not requested




TB515
MQB436
M9/L
H)
1 v~r
8.
1. a
9. a
ND
9.
13.
6.
7
NA
NA
NA

IX
NA c
NA c
NA c

(LOQ).

Surface

Impoundment
MQB442
Ug/L

l\n
160.
ND
Ml
I m./
ND
170.
ND
ND
KJH
tm-f
ND
flOOO



a







U\J\J\J.
680. a

100X
200X
IX
IX












-------
                                           Table A3
                      UMITS OF QUANTITATION FOR ORGANIC COMPOUNDS
                                       IT Vina HM Facility
                                       Martinez. California
                                       MQA
 Volatile Compounds

 Bromomethana
 Oibromomelhane
 Chloromethane
 bdomethane
 Bromodichbromethane
 Dibromochbromethane
 Dichbrodtfluofomelhane
 Trichbroiluoromethane
 Bromoform
 Chbroform
 Carbon tetrachbride
 Carbon disulfide
 Chlorpethane
 1,2-Dibromoethan«
 1  1-Dichloroelhane
 1  2-Dichbfoethane
 1  1,1-Trichbroethane
 1  1.2-Trichloroethana
 1  1,1.2-Talrachbroathana
 1  1,2,2-Tetrachtaroethane
 1  1-Dichloroelhana
 lrans-1.2-0ichloroelhan«
 Trichloroethene
 Tetrachloroelhena
 Methylene chloride
 Vinyl chloride
 1 .2-Dichloropropana
 1 ,2,3-Trichloropropane
 1 ,2-Dibromo-3-chbropropane
 3-Chloropropene
 trans- 1 ,3-dichloropropene
 M-Dichbro-2-butene
 Benzene
 Chlorobenzene
 Toluene
 Xylenes
 Ethylbenzene
2 Methyl- 1-propanol
Acetone
2-Bulanone
 to.
  5.
 10.
  5.
  5.
  5.
  s.
  5.
  5.
  5.
  5.
  5.
 10.
  5.
  5.
  5.
  5.
  5.
  5.
  5.
  5.
  5.
  5.
  5.
  5.
 10.
  5 .
  5 .
  5 .
  5.
  5 .
50.
  5.
  5.
  5.
  5.
  5.
50.
1 o.
10.
 Volatile Compounds (cont.)

 2-Hexanone                     10.
 4-Methyl-2-penlanone            10.
 2-Chloroethyl vinyl ether          10.
 Ethyl cyanide                    so.
 1.4-Oioxane                  5.000.
 Styrene                         5.
 Vinyl Acetate                    10.
 Crotonaldehyde                 so.

 Semi-Volatila Compounds

 Pentachloroethane              10.
 Hexachloroethane               10.
 1.2-Oibromo-3-chloropropana      10.
 Hexachbropropene              10.
 tran«-4-Dichbro-2-butene         10.
 2-Hexanone                     10.
 Acetophenone                   10.
 4-Methyl-2-pentanone            10.
 Aniline                          i o.
 4-Chbroaniline                   10.
 2-Nitroaniline                    so.
 3-Nilroaniline                    so.
 4-Nitroaniline                    50.
 4-Methyl-2-nitroaniline            10.
 3.3'-Dichbrobenzidine            20.
 3,3'-Dimelhylbenzidine           100.
 3.3'-Oimethoxybenzidine          10.
 Benzyl alcohol                   10.
 1.2-Oichbrobenzene              10.
 1.3-Dichbrobenzene              10.
 1.4-Oichbrobenzene              10.
 1.2.4-Trichbrobenzene            10.
 1.2.4,5-Trichlorobenzene          10.
 Pentachlorobenzene              10.
 Hexachlorobenzene              1 o.
 Pentachbronitrobenzene          10.
 Nitrobenzene                    1 o.
 Dinitrobenzene                   10.
2.4 Dinitrotolulena                10.
                                               Semi-Volatile Compounds (cont.)
 2.6-Oinilrotolulene               to.
 N-Nitrosodimethylamine          10.
 N-Nitrosodiethylamine            10.
 N Nitrosomethylelhylamine       10.
 N-Nitrosodiphenylamine and/or
   Diphenylamine                10.
 N-N«roso di n butylamine         10.
 alpha, alpha-
   Dimelhylphenethylamine       50.
 1-Naphthy lamina                10.
 2-Naphthylamine                10.
 bis(2-Chbroelhyl) ether          10.
 4-Chbrophenyl phenyl ether       10.
 4-Bromophenyl phenyl ether       10.
 bis(2-Chbroisopropyl) ether       10.
 bis(2-Chbroethoxy) methane      10.
 Hexachloroethane               10.
 Hexachlorobuladiene             to.
 Hexachbrocycbpentadiene       10.
 bis(2-Ethylhexyl) phthalate       20.
 Butyl benzyl phthalate            10.
 di-n-Butyl phthalate              10.
 di-n-Octyl phthalate              10.
 Oiethyl phthalate                10.
 Dimethyl phthalate               10.
 Acenaplhene                    10.
 Acenaplhylene                  10.
 Anthracene                     10.
 Benzo(a)anlhracene             10.
 7.12-Dimethylbenz(a)anthracene   10.
 Benzo(b)lluoranlhene and/or
  Benzo(k)lluoranthene          10.
 Benzo(g.h.i)perylene             10.
 Benzo(a)pyrene                 10.
 Dibenzo(a.e)pyrene              10. a
Dibenzo(a,h)pyrene              10. a
Dibenzo(a.j)pyrene               10. a
Chrysene                       10.
Dibenzo(a.h)anthracene          10.
Dibenzoluran                    10.
                                                                                                                          M9/L
 Semi-Volatile Compound^ (cont.)

 Fluoranthene                      10.
 Pyrene                           10.
 Indeno (1.2.3-c.d)pyrene           10.
 Isophorone                       i o.
 Naphthalene                      10.
 2-Chbronaphthalene               10.
 2-Methy (naphthalene               1 o.
 Phenanthrene                     10.
 3-Methylcholanthrene              10.
 Methapyrilene                     50.
 5-Nilro-o toluidine                  10.
 o-Tbluidine                        i o.
 2-Picoline                         10.
 N-Nilrosopiperidine                 10.
 Safrole                           10.
 1,4-Naphthoquinone                1 o.
 Pyridine                          i o.
 Methyl Melhacrylale                10.
 Ethyl Methacrylate                 10
 p-Dimethylaminoazobenzene        10.
 4-Aminobiphenyl                   10.
 Pronamide                        i o.
 Isosalrole                         10.
 N-Nitrosopyrrolidine                to.
 Clyclophosamida                   1 o.
 Phenacetin                        10.
 Methyl methane sultonate           10.
 4.4'-Methylene-bis
  (2-chloroanihne)                  10.
 N-Ndrosomorpholine                10.
 Benzoic Acid                      50.
 Phenol                            i o.
 2-Chlorophenol                     1 o.
 2.4-Dichloropheno'l                 10.
 2,6 Dicrilofophenol                 10.
 2,4,5-Trichlorophenol    •          50.
2.4,6-Trichlorophenol.               10.
2.3.4.6 Telfachlorophenol           10.
Panlachlorophenol                  50.
4 Chloro 3 methy.lphanol            10.
 i
en

-------
                                                   Table A3 (coni.)
                                  LIMITS OF QUANTITATION FOR ORGANIC COMPOUNDS
                                                   IT Vine Hil Facility
                                                  Martinez. California
                                                                                                                          I
                                                                                                                         cr>
                           jifl/L
 Semi-Volatile Compounds

 2-Melhylphenol              10.
 4-Methylphenol              10.
 2.4-Oimelhylphenol          10.
 4,6-Dinitro-2-melhylphenol    50.
 2-Nitrophenol               10.
 4-Nilrophenol               50.
 2,4-Oinitrophenol            50.
                              Chlorinated Pesiicides/PCB^

                              Aldrin                         0.05
                              alpha BHC                     0.05
                              beta-BHC                      0.05
                              gamma BHC (Undane)           0.05
                              delta BHC                      0.05
                              Chlordane                      o 5
                              4.4'-ODO                       0 1
                              4.4'-DDE                       o 1
                              4.4--DDT                       0.1
                              Dieldrin                        o.l
                              EndosuNan I                    0.05
                              Endosuttanll                    0.1
                              EndosuMan sulfate               0.2
                              Endrin                         0.1
                              Endrin aldehyde                 0.1
                              Heplachlor                     0.05
                              Heptachlor epoxide              0.05
                              Toxaphene                     1.
                              Methoxychlor                   0.5
                              Endrin ketone                   0 2
                              PCB-1016                      o 5
                              PCB-1221                      o 5
                              PCB-1232                      0 5
                              PCB-1242                      0 5
                              PCB-1248                      0 5
                              PCB-1254                      1
                              PCB-1260                      1.
                              Kepohe                        i.
                              Chlorobenzilale                  1.
                              Isodrin                         o.05
 Qroano-Dhosphale Pesticides

 Phorate                       5.
 Oisulfoton                     5.
 Parathion                     5.
 Famphur                     20.

 Herbicides

 2.4-Dichlorophenoxy
  acetic acid                   1.
 2.4.5-T                       0.1
 2.4.5-TP (Silvex)               0.1
 Chlorobenzilale                1.

 Dioxins/Dibenzolurans

 TCDD(Telra)                  10. b
 PeCDD(Penla)                10. b
 HxCDD(Hexa)                 10. b
 HpCDD(Hepla)                20. b
 OCDD(Octa)                  20. b
 PeCDF(Penta)                10. b
 HxCDF(Hexa)                 10. b
HpCDF(Hepta)                20. b
OCDFF(Octa)                 20. b
a
b
Estimated value; standard not available at the time of analysis.
Estimated value for an individual isomer ol the compound class; calculated by N£!C using the lowest standard concentration analyzed

-------
                                                                           Table A-4

                                                   DISSOLVED AND TOTAL METALS ANALYSIS RESULTS*
                                                                     IT Vina Hill Facility
                                                                     Martinez. California
Station:
SMONo.:
Element
Al
Sb
As
Ba
Be
Cd
Ca
Cr
Co
f\
Cu
Fe
Pb
Mg
Mn
i •-
Hg
Ni
K
Se
Ag
Na
Tl
Sn
V
Zn

Dissolved
Value. ug/L
297.
300. a.b
<3. ft
1.230.
<1.
<2s! ft
2.810.000.
<23.
<7.
144.
<25.
181.000. ft
5.
<.4
<20.
296.000. c
<25. ft
7.
12.400.000.
<10. ft
<32.
19.
19.
MW115
UTR41.1
Total
Value. ug/L
5.600. ft,c
17.
<50. *
1.230. b.c
1.
2.860.00o!
<23.
12
4.380. c
<25. ft
195.000. c
61. c
<4 ft
36.
259.000. c
<25. ft
12.800.000.
<50. ft
<32.
37.
45.

Dissolved
Value. ug/L
58.
<30.
27.
846.
Kl
496.000.
<23.
<7.
65.
12.
474.000.
2.820.
<.4
<20.
158.000.
<25.
4.370.000.
<10.
<32.
62.
68.
MW116
MQB412
Total
Value. ug/L
15.700. ft.c
b <45. ft
895. ft.c
<1
b 
-------
                                                                        Table A 4 (cont.)

                                                     DISSOLVED AND TOTAL METALS ANALYSIS RESULTS
                                                                       IT Vine Hill Facility
                                                                       Martinez, California
 I
oo
Station:
SMONo.:
Element
Al
Sb
As
Ba
Be
Cd
Ca
Cr
Co
Cu
Fe
Pb
MB
Mn
Hg
Ni
K
Se
Ag
Na
Tl
Sn
V
Zn
MW-119*
MQB406 406.407
Dissolved
Value. ug/L
145.
<6. 4ft
20. b
1.800.
<1.
<2. ft
494.000.
11.
<23.
<23.
527.
<20.
1.130,000. ft
1.440.
<.4 ft
36.
219,000. c
<25. ft
<7.
7.330,000.
<10. ft
<32.
<15.
84.
Total
Value. ug/L
3,510. bf
<4.
<10. ft
1.670. bf
<1.
<5. ft
454.000.
<23.
10.
9.340.
<5.
1.270,000.
1,520.
<.4
<20.
198.000. c
<25. ft
<7.
8.090.000.
<50. ft
<32.
27.
35.
Dissolved
Value, ug/L
77.
<60.
15.
2.700.

-------
                Table A 4 (conl.)

DISSOLVED AND TOTAL METALS ANALYSIS RESULTS
               IT Vina Hill Facility
               Martinez. California
Station: MW-205*
SMO No.: MO8422 425 426
Dissolved
Element Value, ug/L
AJ 223.
Sb <30. ft
As ' <10. ft
Ba 68.
Be <1.
Cd <5.
Ca 804.000.
Cr <9.
Co <23.
Cu <7.
Fe 4,380.
Pb <25.
Mg 994.000. ft
Mn 7.280.
l_i *%
Hg <.2 ft
Ni <20.
K 78,300. c
Se <25. ft
Ag <7.
Na 5,830,000.
Tl <10. ft
Sn <32.
V <15.
2n <11.
Total
Value. ug/L
199. fee
<60
<45. ft
78. fee
<1
1.8 ft
787.000.
<23.
6.100. c
<25. fee
982.000. c
8.450. c
<.2 ft
<20.
88.400. c
<25. ft.c
5.690.000. 4
<50.
<32.
<«:
MW-206
MGB434
Dissolved
Value. ug/L
160.
<300. ft
11. ft
552. ft

-------
                Table A 4 (conl.)

DISSOLVED AND TOTAL METALS ANALYSIS RESULTS
               IT Vina HUI Facility
              Martinez. California
Station: MW212
Dissolved
Element Value. ug/L
Al
Sb
As
Ba
Be
Cd
Ca
Cr
Co
Cu
Fe
Pb
Mg
Mn
Hg
Ni
K
Se
Ag
Na
Tl
Sn
V
Zn
a
ft
c
137. *
<30.
<10. ft
79.
<1.
<2. ft
706.000.
11.
<23.
10.800
<20. ft
1.290.000. ft
2.890.
<4 ft
46.
145.000. c
<25. b.c
<7.
6.000.000.
<50. ft
<32.
<15.
14^
Total
Value. ug/L
191. *c
<60.
<10. ft
162. ft.c

<5. ft
741.000.
<23.
SI.OOo! c
<25. ft
1.370.000. c 1
2.610. c
<4. ft
46.
129.000. c
<5. ft
<7.
6.390.000. 6
<50. ft
<32.
<15.
<11.
MW-214
Dissolved
Value. ug/L
151.
<6. ft
<10. ft
61.
lt bias.
Estimated value; interference present cau
itng poi«tt« bias.






-------
                                                                       Table A 4 (conl.)

                                                    DISSOLVED AND TOTAL METALS ANALYSIS RESULTS
                                                                       IT Vina Hill Facility
                                                                      Martinez. California
Station:
SMONo.:
Element
Al
Sb
As
Ba
Be
Cd
Ca
Cr

Co
Cu
Fe
Pb
Mg
Mn
Hg
Ni
K
Se
Ag
Ma
n
Sn
v
Zn
MV
LT
Dissolved
Value. ug/L
55.
<60. ft
28. ft
358.
1
<4 ft
493.000.
.
<23.
1.840.
16.
710.000. ft
4.110.
<.2 ft
<20.
10.600. c
<25. ft
3.750.000.
<10. ft
<32.
15.
V-219 Q.fi
fi*a 	 unftmo
Total
Value. ug/L
120. fee
<60.
<45. ft
318. b.c.
.
<4. ft
438.000.
<9.
<23.
2.420. c
<25. ft
783.000. c
3.530. c
<.2 ft
•<20.
9.690. c
<5. ft
4.100.000.
<50. ft
<32.

Dissolved
Value. ug/L
111.
<60. ft
<10. ft
366.

i
124.000.
<9.
<23.
<45.
80.600. ft
169.
.3 ft
<20.
5.020. c
<5. ft
97.100.
<2. ft
<32. ft
23.
Total
Value. ug/L
5.360. b.c
<10. ft
390. ft.c

<5 ft
111.000.
<9.
<23.
7.
5.220. c
8.3 ft
70.800. c
177.
<2 ft
<20.
5.010. c
<5. ft
88.000.
<2. ft
<32.
59.
SURFACE IMPOUNDMENT
Mnnra
Dissolved
Value. ug/L
<260.
<300.
1,300.
52.

<5.
59.500.
2.220.
<115.
88.
2.100.
<20.
98,200.
3,000.
<1 ft
4.580.
413.000.
<25. ft.c
^")a
10,000.000.
<50. ft
<160.
1.550.
510.
Total
Value. ug/L
589.
44.
1.140. a
57.

<1.
57.600. c
2.280.
97.
203.
2.620. c
<25. ft
89.900.
2.720. c
4.370. c
364.000.
6.6 ft
9.540,000.
<50. ft
<32.
1.390. c
842.
ft     Batch spike sarnple recovery was not witm control InnasindKatr^iposstile bias
c     Esirnated value; interference present causng possible bias
d     Ckftcate analysis not wittin control tmis

-------
           Table A 5

   FIELD MEASUREMENTS and
GENERAL CONSTITUENT ANALYSIS
        IT Vine HiU Facility
        Martinez. California
Station: MW-115
SMONo. MQB413

Parameter Units Value
pH Units 11.0
Conductance umhos/cm 46,900.
Temperature C 21.
Turbidity NTU 72.
FOX ug/L CL 90.
TOX ug/L CL 335.
POC ug/LC 5.160.
NPOC ug/L C 60.000.
Bromide mg/L 58.
Chloride mg/LCI- 18.800.
Nitrate mg/L N <.3
Sullate mg/LS04- 1.380.
Nitrite mg/L <.3
Cyanide ug/L <10.
Phenol ug/L <50.
Sulfide mg/L 290.
Fluoride mg/LF- 32.
* Results of replicate analysis
a) Limit of Detection; not corrected for dilution
MW116
MQB412

Value
7.0
22.000.
20.
116.
<5.
115.
5.300.
42.000.
23.
7.100-
<.3
34.
<.3
<10.
<50.
190.
16.


MW-117
MQB415

Value
6.7
49.000.
NA
130.
3.900.
400.
2.460.
77.000.
50.
18.600.
<.3
630.
<.3
NA
<50.
36.
34.


MW-119*
MQB405
406. 407
Value
6.7
27,600.
20.
208.
4.500.
483.
12,700.
508.000.
35.
11.700.
<.3
22.
<.3
20.
<50.
98.
31.


MW-128
MQB409

Value
6.7
23,600.
19.
128.
<5.
NA*>
15.520.
60.000.
22.
7.300.
<.3
<1.
<.3
<10.
<50.
<1.
17.


MW-203
MQB439

Value
6.7
>20,000.
NA
340.
<5.
NAC
5.670.
93.000.
NAC
NAC
NAC
NAC
NAC
NAC
NAC
NAC
NAC


MW-204
MQB423

Value
6.7
>20,000
19.
.6
<5.
243.
100.
26.000.
50.
14.200.
<.3
2.800.
<.3
<10.
<50.
<1.
30.


MW-205*
MQB422
425. 426
Value
65
>20.000.
21.
77.
131.
502.
8.000.
12.000.
29.
9.500.
<.3
873.
<.3
<10.
<50.
580.
17.





LOD*


22.

5.
5
10.
1.000.
1.
1.
.3
1.
.3
10.
50.
1.
1.


b) Sample not analyzed; sample container broken
c) Analysis not requested









-------
         Table A 5 (cont.)

   FIELD MEASUREMENTS and
GENERAL CONSTITUENT ANALYSIS
        IT Vine Hill Facility
        Martinez. California
Station:
SMONo.
Parameter Units
pH Units
Conductance umhos/cm
Temperature C
Turbidity NTU
POX ug/L CL
TOX ug/L CL
POC ug/LC
NPOC ug/L C
Bromide mg/L
Chloride mg/L Cl-
Nitrate mg/L N
Sulfate mg/L S04-
Nitrite mg/L
Cyanide ug/L
Phenol ug/L
Sulfide mg/L
Fluoride mg/L F-
MW-206 MW-207
MQB424 MQB427
Value Value
6.9 7.4
>20,000. >20.000.
21. 22.
14. 70.
<5. <5.
178. NAto
36,500. 49.400.
23,000. 13,000.
21. NA&
7.200. NAto
<.3 NA^
350. NA*>
<.3 NAb
<10. NAft
<50. NA&
8. NAto
15. NA&
MW-209
MQB432
Value
6.8
20,000.
18.
185.
1,740.
870.
16,700.
110.000.
62.
16.800.
< 3
1 .600.
<.3
<10.
50.
46.
36.
MW-212
MQB438
Value
6.7
18.5000.
'19.
NAC
<5.
820.
9.120.
98.000.
24.
6.400.
<.3
6.000.
< .3
<10.
<50.
34.
22.
MW-214 MW-215 MW 216
MQB434 MQB428 MQB431
Value Value
6.6 7.
>20.000. >20.000.
21. 20.
NAC 380.
<5. 4.940.
185. NAb
210. 25.300.
11.000. NA*>
35. NA*>
10.600. NA*>
< 3 NA^
980. NA*>
<.3 NA*>
<10. NAb
<50. NAft

24. NA^
Value
6.6
18.000.
20.
56.
<5
91.
90.
171.000.
33.
10.200.

890.

<10
<50.

24.
MW-218
MQB429
Value LODa
7.1
>20,000
20.
780.
4.380. 5.
863 S
\J\J*J , J .
23.900. 10.
162.000. 1.000.
NA*>
NA*> 1
NA/) '
1 ^tf\ . o

NAb '
" **• . O
NA^ 10
• »* » I v .
NA^ 50
• »* » %j \j .
NA^ t:
a L«n*t of Detection; not corrected for dilution ~ ' 	 ~ 	 •
b Analysis not requested
c Sample not analyzed






                                                                        I
                                                                        I—»
                                                                        00

-------
        Table A 5 (com.)

   FIELD MEASUREMENTS and
GENERAL CONSTITUENT ANALYSIS
        IT Vine Hill Facility
        Martinez, California
                                                                        I
                                                                       t—'
                                                                       -p.
Station:
SMONo.
Parameter Units
pH Units
Conductance umhos/cm
Temperature 'C
Turbidity MTU
POX ug/L CL
TOX ug/L CL
POC ug/LC
NPOC ug/LC
Bromide mg/L
Chloride mg/L Cl-
Nitrate mgA N
Sulfate mg/L S04-
Nitrite mg/L
Cyanide ug/L
Phenol ug/L
Sullide mg/L
Fluoride mg/L F-
MW-219
MQB433
Value
6.7
>20.000.
19.
26.
<5.
197.
90.
11,000.
21.
6,100.
<.3
188.
<.3
<10.
<50.
130.
15.
MW-222
MQB441
Value
6.6
16.500.
19.
NA*>
<5.
NAC
4,170.
NAC
NAC
NAC
NAC
NAC
NAC
NAC
NAC
NAC
NAc
MW227
MQB437
Value
6.7
14.600.
18.
NA*>
<5.
NAC
18,800.
NAC
NAC
NAC
NAC
NAC
NAC
NAC
NAC
NAC
NAC
G6
MQB438
Value
6.9
1,650.
14.
88.
<5.
74.
160.
61.000.
<1.
153.
.5
38.
<.3
<10.
<50.
58.
2.
Surface
Impoundments
MQB442
Value
NAb
NA&
NA&
NAto
28.600.
12,000.
1.140.
4.420.000.
10.
8.000.
<.3
380.
<.3
50.000.'
9.500.
300.
350.
TB-515
MQB436
Value
7.1
>20,000.
21.
46.
<5.
NAC
2.310.
NAC
NAC
NAC
NAC
NAC
NAC
NAC
NAC
NAC
NAC


LODa




5.
5.
10.
1.000.
1.
1.
.3
1.
3.
10.
50.
1.
1.
a Limit of Detection; not corrected for dilution
b Sample not analyzed
c Analysis not requested















-------
                              APPENDIX B
                        Specific Analytical Results
                             IT Baker Facility
                           Martinez, California
Table B-1    Sample Preparation, Analytical Techniques and Methods

Table B-2   Organic Results

Table B-3   Limits of Quantitation for Organic Compounds

Table B-4   Total Metal Results

Table B-5   Field Measurements and General Analytical Parameters

-------
                              APPENDIX B
                        Specific Analytical Results
                             IT Baker Facility
                           Martinez, California


Table B-1   Sample Preparation, Analytical Techniques and Methods

Table B-2   Organic Results

Table B-3   Limits of Quantftation for Organic Compounds

Table B-4   Total Metal Results

Table B-5   Reid Measurements and General Analytical Parameters

-------
                              APPENDIX B
                             IT Baker Facility
                           Martinez, California

 SPECIFIC ANALYTICAL RFRl II TS~

      Table  B-1  lists the Sample Preparation,  Analytical  Techniques and
 Methods used by the contract  laboratory (CL).  Table B-2 shows the Organic
 Results for samples in which at least one compound was detected.  Table B-3
 lists the limits of quantitation (LOQ) achieved for the organic analyses; the LOQs
 for the dioxins/dibenzofurans represent estimated values calculated by NEIC
 using the lowest standard concentration analyzed by the  CL Table B-4 lists
 metals analysis  results.  Table  B-5 lists  field  measurements and  general
analysis results.

-------
                                                              Table B-1
                                   SAMPLE PREPARATION AND ANALYSIS TECHNIQUES AND METHODS
                                                            IT Baker Facility
                                                          Martinez. California
    Parameter
                         Preparation Technique
      Specific Organic Constituents
 Volatiles               Purge and trap
 Semi-volatiles          Methytene chloride extraction
 Pesliddes/PCB         Melhylene chtoride/hexane extraction
 Herbicides             Diethyl ether extraction/methytation
 Dioxins and            Methylene chloride/hexane extraction
  Diobenzofurans

    Non-specific Qrganic Parameters
 POX                  None
 TOX                   Carbon absorption
 POC                  None
 NPOC                 Acidify and purge

       Elemental Constituents
 Mercury                Wet digestion for dissolved and total
 As, Pb. Se and Tl        Acid digestion for total
 Other Elements         Acid digestion for total

       Field Measurements
 Conductance           None
 pH                    None
 Turbidity               None

     General Constituents
 Nitrate                 None
 Sulfate                 None
 Chloride                None
 Nitrite                  None
 Bromide                None
 Fluoride                None
 Sulfide                 None
 Phenol                Automated distillation
Cyanide               Manual distillation
                                                                            Analysis Technique
                                                        Gas Chromalography - Mass Spectroscopy
                                                        Gas Chromalography - Mass Spectroscopy
                                                        Gas Chromalography with Electron Capture Detection
                                                        Gas Chromalography with Electron Capture Detection
                                                        Gas Chromalography - Mass Spectroscopy
                                                        Purgeable combusted. Microcoulometry
                                                        Carbon combusted. Microcoulomelry
                                                        Purgeable combusted. Non-dispersive Infrared
                                                        UV Persulfate. Non-dispersive Infrared
                                                       Cold Vapor Atomic Absorption Speclroscopy
                                                       Furnace Atomic Absorption Speclroscopy
                                                       Inductively Coupled Plasma Emission Spectroscopy
                                                       Electrometric, Wheatslone Bridge
                                                       Potentiometry
                                                       Nephelometric
                                                       Ion Chromalography
                                                       Ion Chromalography
                                                       Ion Chromatography
                                                       Ion Chromatography
                                                       Ion Chromalography
                                                       Ion Chromatography
                                                       lodomelric. Titration
                                                       Colorimelric. Distillation. Automated 4-AAP
                                                       Pyridme Pyrazolone Colonmelry
                                                                                                            Method Reference
 CLP Method a
 CLP Method
 CLP Method
 Method 8150 b
 Method 6280 b
 EPA 600/4-84-008
 Method 9020 b
 No reference
 Method 415.1 c
CLP Method
CLP Method
CLP Method
Method 120.1 c
Method 150.1 c
No reference
EPA Method 300.0
EPA Method 300.0
EPA Method 300 0
EPAMethod 300.0
EPA Method 300 0
EPA Method 300.0
Method 9030 b
Method 9066 b
Method 9010 b
a
b
c
Contract Laboratory Program. IFB methods
Test Methods for Evaluating Solid Wastes. SW 846
Methods lor Chemical Analysis of Water and Wastes. EPA-600/4-79-020
                   oo
                   I

-------
                                               Table B 2

                                   SPECIFIC ORGANIC CONSTITUENTS*
                                            IT Baker Facility
                                           Martinez. California
                                                                                                                                CO
                                                                                                                                I
                                                                                                                                ro
STATION:
SMONO.
PARAMETER
Carbon bisulfide
Benzene
Xylenes
Acetone
di-n-Butyl phthalate
bis(2-Elhylhexyl) phthalate
Benzoic acid.
Phenol
2.4.5-TP
LOQ FACTORS"
Volatile
Semivolatile
Pesticide
Dioxins and Furans
MW1A
MQB457
na/L
2. a
ND
1. a
ND
2. a
ND
ND
3. a
ND

IX
2X
IX
IX
MW9A
MQB451
MJ/L
ND
ND
ND
ND
2. a
ND
NO
ND
0.28

IX
2X
1X
IX
MW-101
MOB464
M)/L
ND
ND
ND
ND
ND
170.
ND
ND
ND

IX
2X
IX
IX
MW-103
MQB454
H9/L
ND
ND
ND
ND
ND
ND
ND
3. a
ND

IX
2X
IX
NA c
MW-104
MQB443
H9/L
ND
ND
ND
ND
1. a
ND
ND
ND
ND

IX
2X
IX
1X
    No organic compounds were detected in MW-SA. MW-6A, MW-8A. MW-14. MW- IS. MW-102. MW-106 and Surface
    Impoundment C
ND Compound was not detected.
a   Estimated concentration.  Compound was detected, but the concentration was below the Limit of Quantitation (LOQ).
b   LOQ Factor is the factor that the LOQ must be multiplied by to correct the LOQ for dilutions.
c   Sample not analyzed.

-------
         Table B 2 (conl.)

SPECIFIC ORGANIC CONSTITUENTS
         IT Baker Facility
        Martinez. California
STATION: MW-105
SMONO. MQB455
PARAMETER ug/L
Carbon disuNide ND
Benzene ND
Toluene ND
Xylenes ND
Acetone ND
di-n-Butyl phthalale ND
bis(2-Ethylhexyl) phthalate ND
Benzoic acid ND
Phenol 3. a
1.4-Naphthaquinone ND
2.4.5-TP ND
LOQ FACTORS*
Volatile IX
Semh/olatile 2X
Pesticide IX
Dioxins and Furans NA c
ND Compound was not detected.
MW-110
MQB420
ug/L
1. a
ND
ND
ND
ND
ND
ND
ND
ND
ND

IX
2X
IX
IX

MW112
MQB440
ug/L
ND
ND
ND
ND
ND
1. a
ND
ND
ND
ND
ND

IX
2X
1X
NA d

MW113
MQB459
ML
ND
ND
ND
ND
ND
ND
ND
ND
3. a
ND
ND

IX
2X
IX
NA c

MW-125
MQB460
H*
ND
ND
4. a
ND
96.
ND
6.
130.
240.
20.
ND

IX
2X
IX
NA d

a Estimated concentration. Compound was detected, but the concentration was below the Limit of Quantitation
b LOQ Factor is the factor that the LOQ must be multiplied by to correct the LOQ for dilutions
c Sample not analyzed.
d Analysis not requested.




GW
Seepage
MQB458
ug/L
ND
ND
ND
ND
ND
Im-f
ND
24
fc*V .
ND
tun
I m-f
ND
0.7

IX
1 /\
2X
IX
NA c

(LOQ).

Surface
Impoundment D1
MQB444
"9/L
ND
ND
1 V_/
M)
Im-/
ND
MTt
ImJ
ND
KJH
fmJ
320. a
un
ImJ
ND
• m-/
ND

IV
1 A
20X
iy
1 A
IX



                                                                                       CO
                                                                                        I
                                                                                       CO

-------
                                                                            Table B 3
                                                      UMITS OF OAJANTrTATION FOR ORGANIC COMPOUNDS
                                                                         IT Baker Facility
                                                                       Martinez. California
                                                                                                                                                                CO

                                                                                                                                                                -p>
                                                                        H9/L
                                                                                                                pg/L
 Volatile Compounds

 Bromomethane                   10.
 Oibromomethane                   5.
 Chloromethane                   10.
 lodomethane                      5.
 Bromodichbromethane             5.
 Dibromochbromelhane             5.
 Dichbrodifluoromethana            5.
 Trichbrofluoromethane             5.
 Bromoform                        5.
 Chloroform                        5.
 Carbon tetrachbrida                5.
 Carbon disulfida                   5.
 Chbroethane                     10.
 1,2-Dibromoethane                 5.
 1.1-Dichbroethane                 5.
 1.2-Dichloroethane                 5.
 1.1.1-Trichbroethane               5.
 1.1,2-Trichloroethane               5.
 1.1.1.2-Tetrachbroethane          5.
 1.1.2.2-Tetrachbroethane          5.
 1.1-Dichloroethene                 5.
trans-1.2-Dichbroe thane            5.
Trichloroathene                    5.
Tatrachloroathena                  5.
Methylena chloride                 5.
Vinyl chloride                     10.
 1,2-Oichloropropana                5.
 1,2.3-Trichloropropane              5.
 1.2-Dibromo-3-ch!oropropane        5.
3-Chloropropana                   5.
trans-1,3-dichbropropena           5.
1,4-Dichloro-2-butene              50.
Benzene                          5.
Chbrobenzane                    5.
Toluene                           5.
Xylenes                           5.
Ethylbenzane                      5.
2-MethyM-propanol               50.
                                        Volatile Compounds (cpnt.)

                                        Acetone                         10.
                                        2-Butanona                      10.
                                        2-Haxanona                     10.
                                        4-Melhyl-2-penlanone             10.
                                        2-Chloroethyl vinyl ether          10.
                                        Ethyl cyanide                    50.
                                        1.4-Dbxane                  5.000.
                                        Styrene                          5.
                                        Vinyl Acetate                    10.
                                        Crotonaldehyde                  50.

                                        SamJyolalila Compounds

                                        Pentachloroethane               10.
                                        Hexachbroelhane                10.
                                        1.2-Dibromo-3-chbropropana      10.
                                        Haxachbropropana               10.
                                        trans-4-Dichloro-2-butana         10.
                                        2-Haxanona                      10.
                                        Acetophenone                   10.
                                        4-Methyl-2-pantanone             10.
                                        Aniline                          10.
                                        4-Chlofoanilina                .  10.
                                        2-Nitroaniline                    50.
                                        3-Nilfoaniline                    50.
                                        4-Nitroaniline    '                50.
                                        4-Methyl-2-nitroaniline            10.
                                        3,3'-Oichbrobenzidine            20.
                                        3.3'-Oimethylbanzidine           100.
                                        3.3'-Oimethoxybanzidina         10.
                                        Benzyl alcohol                  10.
                                        1,2-Dichbrobenzana             10.
                                        1.3-Dichbrobenzena             10.
                                        1.4-Oichlorobanzana             10.
                                        1,2.4-Trichlorobenzana           10.
                                        1,2,4,5-Trichlorobenzene         10.
                                        Pantachlorobenzena             10.
                                        Haxachlorobenzene              10.
 SamJvolalila Compounds (cont)

 Pentachbronitrobenzene          10.
 Nitrobenzene                     10.
 Oinitrobanzane                   10.
 2.4-Oinilrotolulene                10.
 2.6-Dinitrololulene                10.
 N-Nit/osodimethylamina           10.
 N-Ndrosodiathylamina             10.
 N-Nitrosomathylethylamine        10.
 N-Nilrosodiphenylamine and/or
  Diphenylamine                  10.
 N-Nitroso-di-n-buty lamina          10.
 alpha, alpha-
  Oimalhylphenethylamina       50.
 1-Naphthylamine                  10.
 2-Naphthylamine                  10.
 bis(2-Chbroethyl) ether            10.
 4-Chbrophenyl pheny I ether        10.
 4-Bromophar.yl phenyl ether        10.
 bis(2-Chbroisopropyl) ether        10.
 bis(2-Chbroethoxy) methane       10.
 Hexachbroethane               10.
 Haxachbrobutadiene             10.
 Hexachbrocycbpenladiene       10.
 bis(2-Elhylhexyl) phthalate       20.
 Butyl benzyl phlhalate            10.
 di-n-Butyl phthalale              10.
 di-n-Oclyl phthalate              10.
 Diethyl phthalate                 10.
 Dimethyl phthalale               10.
Acenaplhene                    10.
 Acenapthylene                  10.
Anthracene                      10.
Benzo(a)anthracana              10.
 7.12-Dimethylbenz(a)anthracene   10.
Banzo(b)fluoranthana and/or
  Benzo(k)fluoranthene           10.
Banzo(g.h.i)perylane              10.
Benzo(a)pyrane                  10.
 Semivolalile Compounds (con\ \

 Dibenzo(a.e)pyrene                10.
 Dibenzo(a.h)pyrana     .           10.
 Dibenzo(a.j)pyrana                 10.
 Chrysene         '                10.
 Dibenzo(a.h)anthracene            10.
 Dibenzofuran                      10.
 Fluoranthene  '                    10.
 Pyrene                           10.
 Indeno (1.2.3 c,d)pyrene           10.
 Isophorone                       10.
 Naphthalene                      10.
 2-Chbronaphthalana               10.
 2-Melhylnaphthalana               10.
 Phenanthrana                    < 10.
 3-Melhylcholanthrena              10.
 Malhapyrilene                     50. a
 5-Nrtro-o loluidine                  10.
 o-Toluidina                        10
 2 Picoline                         10.
 N-Nitrosopiperidina                 10.
 Safrola                           10.
 1,4-Naphthoquinona                10.
 Pyndina                           10.
 Methyl Melhacrylale                10.
 Ethyl Melhacrylate                 10.
 p-Dimathylaminoazobenzene        10.
 4-Aminobiphenyl                   10.
 Pronamida                         10.
 Isosalrola                         10.
 N-Nitrosopyrrolidina                • 10.
Clyclophosamida                   10
 Phenacelin                        10.
 Methyl methane sullonale           10.
4.4'-Methylene-bis
  (2-chloroanilme)                  10.
N Nitrosomorpholina                10.
Benzoic Acid                      50.
Phenol                            to.
a     Estimated value: standard not available at the une ol analysis
b     Estinmtd value tar an individual tsomer ol the compound class: calculated by NEIC using the lowest s
                                                                               •d concentration fuiatyiitd by CL.

-------
                                                   Table B 3 (cont.)
                                 LIMITS OF CHJANTITATION FOR ORGANIC COMPOUNDS
                                                    IT Baker Factbty
                                                  Martinez. California
                           M9/L
                                                             MQ/L
 Sumivolalilfl Compound^ (flflnt}

 2-Chlprophenol                10.
 2.4-Dichlorophenol             10.
 2.6-Dichlorophanol             10.
 2.4.5-Trichlorophanol           SO.
 2.4.6-Trichlorophanol           10.
 2.3.4.6-Tatracrilorophanol       10.
 Pantachlorophanol             50.
 4-Chloro-3-m«lhylph«nol        10.
 2-Melhylphenol              10.
 4-Methylphenol              10.
 2.4-Dimethylphenol          10.
 4,6-Dinilro-2-methylphenol    50.
 2-Nitrophenol                10.
 4-Nitrophenol                50.
 2.4-Dinilrophenol             50.
                              Chlorinated Pesticides/PCs^

                              Aldrin                          0.05
                              alpha-BHC                      0.05
                              beia-BHC                       o.OS
                              gamma BHC (Lindane)            0.05
                              della-BHC                       0.05
                              Chlordane                       o 5
                              4,4'-DDD                       o 1
                              4.4'-DDE                       o 1
                              4.4f-DDT                       0.1
                              Dieldrin                         0.1
                              EndosuHan I                    0.05
                              Endosulfanll                    0.1
                              EndosuHan suKaie               0.2
                              Endrin                          o.l
                              Endrin aldehyde                 0.1
                              Heplachtor                      0.05
                              Heplachlor epoxide              0.05
                              Toxaphene                      i.
                              Melhoxychlor                    0.5
                              Endrin ketone                   o 2
                              PCB-1016                       05
                              PCB-1221                       0.5
                              PCB-1232                       0 5
                              PCB-1242                       0 5
                              PCB-1248                       0 5
                              PCB-1254                       1
                              PCB-1260                       1.
                              Kepone                         i.
                              Chlorobenzilate                  1.
                              Isodrin                          o.05
Qraano-phosphate
Phorate
Disullolori
Paralhion
Famphur

Herbicides

2.4-Dichlorophenoxy
  acetic acid
2.4.5-T
2.4.5-TP (Sih/ex)
Chlorobenzilate

Dioxins/Dibenzofufans

TCDD(Tetra)
PeCDD(Penla)
HxCDD(Hexa)
HpCDD(Hepla)
OCDD(Octa)
PeCDF(Penta)
HxCDF(Hexa)
HpCDF(Hepta)
OCDFF(Octa)
                              5.
                              5.
                              5.
                             20.
                              i
                              o.l
                              0.1
                              1 .
                                                                                                        10. fa
                                                                                                        10. b
                                                                                                        10. b
                                                                                                        20. b
                                                                                                        20. b
                                                                                                        10  b
                                                                                                        10. b
                                                                                                        20. b
                                                                                                        20. b
a
b
Estimated value; standard not available at the time of analysis            ''                "             ~~~	
Estimated value for an individual isomer of the compound class; calculated by NEIC using the lowest standard concentration analyzed
                                                                                                                              CO
                                                                                                                               I
                                                                                                                              en

-------
                   Table B-4

DISSOLVED AND TOTAL METALS ANALYSIS RESULTS*
                IT Baker Facility
               Martinez. California
CD

cn
Station: MW-1A
SMONo.: MTR1S7
Dissolved Total
Element Value, ug/L Value. ug/L
Al
Sb
As
Ba
Be
Cd
Ca
Cr
Co
Co
Fe
Pb
Mg
Mn
l i_
Hg
Ni
K
O „
Se
Ag
Na
Tl
Sn
V
Zn

a
b
c
380. 1,480.
<300. • <300.
<10. b <20.
659. 826.
<1. <1
<5. b <5. b
1.930,000. 2,060,000.
<23. <23.
9. <7.
65.800. 105.000.
<25. b <25. b
2.260.000. 2.360.000.
39.900. 42.200. b
<.4 b  t2 and AAV 125
Sample concentration « less fan X al 99% confdence
Dissolved
Value. ug/L
177.
<20.
28. b
174.
<1
IS. b
642.000.
47.
127.000!
<25. b
969.000.
36.900.
<4 b
55.
85.300.
<50.
6.670.000.
<50. b.c
<32.
16.


MW-5A
MQB4S3
Total
Value. ug/L
422.
<300.
44.
230.

<4 b
711.000.
51.
143.000.
<25. b
1.040.000.
40.100. b
<.4 b
57.
80.500.
<7
7.190.000.
<50. 6
<32.
<"•'



Dissolved
Value. ug/L
130. '
<20.
<10. b
254.

<5. b
279.000.
40.
<23.
8.36o'
24. b
640.000.
7.940. b
<4 b
32.
115.000.
<*
3.990.000.
<50. b.c
<32.
24.


MW6A
MOB446
Total
Value ug/L
3.020.
<45.
<50.
508.

<5 b
244.000.
<23.
9.
44.000.
<5. b
732.000.
7.080. b
< 4 t>
<20.
106.000.
<25.
4.660.000.
<50. b
<32.
18.


Batch spike sample recovery was not withn control limits indicating posiuble bias.
Estimated value; interference present causing possible bias.

-------
                                                                     Table B-4 (conl.)
                                                  DISSOLVED AND TOTAL METALS ANALYSIS RESULTS
                                                                     IT Baker Facility
                                                                    Martinez. California
Station:
SMONo.:
Element
Al
SB
*
As
Ba
Be
Cd
Ca
Cr
Co
Cu
Fe
Pb
Mg
Mn
aa_
Hg
Ni
K
Se
Ag
Na
Tl
Sn
V
Zn
^— ™«—*.^— ••—••
Dissolved
Value. ug/L
<52.
<300.
73.
Kl

-------
                                                                       Table 84 (cont)
                                                    DISSOLVED AND TOTAL METALS ANALYSIS RESULTS
                                                                       IT Baker Facility
                                                                      Martinez. California
CD
 I
CD
Station:
SMONo.:
Element
Al
Sb
As
Ba
Be
Cd
Ca

Co
Co
Fe
Pb
Mg
Mn
Hg
Ni
K
Se
Ag
Na
Tl
Sn
V
Zn
	 UQI
Dissolved
Value. ufl/L
105.
<60. •
<10. b
212.
<1.
<.4 b
490.000.
<9.
<23.
84!
<5. b
426.000.
4.000.
<4 b
<20.
8.210.
<50.
2.130.000.
<50. b
<32.
<15.

MW-15*
3447.449.452
Total
Value. ug/L
140.
<60.
203!

824.000.
985. b
< 4 b
<20.
111.000.
<7
5.120.000.
<10. b
<32.
22.
11.

Dissolved
Value. ug/L
92.
<300.
12. b
918.

<5. ti
414.000.
9.
<23.
6.630!
<5. b
889.000.
823.
<.4 b
<20.
139,000.
<25.
5.610.000.
<50. b
<32.
<15
24.
MW-102
MQB419
Total
Value ug/L
300.

32.

5
405.000.

<23.
20.200.
<5. t>
977.000.
728.

<20.
132.000.
<50. c
6.250.000.
<50. b
<32.
17.

»      Sample concentration is less than X at 99% confidence.
b      Batch spike sample recovery was not witin control lunts indicating posable bias.
c      Estimated value: nurterenco present causing possible bins.

-------
                Table B-4 (oonl.)
DISSOLVED AND TOTAL METALS ANALYSIS RESULTS
                IT Baker Facility
               Martinez. California
Station:
SMONo.:
Element
Al
Sb
As
Ba
Be
Cd
Ca
Cr
Co
Cu
Fe
Pb
Mg
Mn
Hg
Ni
K
Se
Ag
Na
Tl
Sn
V
Zn
MW-103
Dissolved
Value. ufl/L
64.
6.4
<50. a,ft
293.
<1.
<4 ft
221,000.
<23.
4.210!
<5. ft
481.000.
1,380.
<4 ft
<2Q.
96.800.
<50.
2.880.000. 3.
<50. ft
<32.
23.
<11.

Total
Value, ug/L
1.520.
<60.
<20.
400.
<1.
<5. ft
198.000.
11.
<23.
14.800
18. ft
561.000.
1.420. ft
<4 ft
21.
84.500.
<25. c '
290.000. 5
<50. ft
<32.
18.
13.

Dissolved
Value, ug/L
138.
<20.
<10. ft
774.
<(
2.8 ft
287,000.
<23.
45'
<25. ft
762.000.
662.
<.4 ft
<20.
131.000.
<25.
.220.000.
<50. ft.c
<32.
<15
<11.
MW-104
MQB443
Total
Value. ug/L
198.
12.
<10
7SO.

-------
                Table B-4 (conl.)
DISSOLVED AND TOTAL METALS ANALYSIS RESULTS
                IT Baker Facility
              Martinez. California
03

I—•
CD
Station:
SMONo.:
Element
A!
Sb
As
Ba
Be
Cd
Ca
Cr
Co
Cu
Fe
Pb
Mg
Mn
LX_
Hg
Ni
K
Se
Ag
Na 3.
Tl
Sn
V
Zn

Dissolved
Value. ug/L
<52.
<300.
<10. b
483.
<1.
<2s! *
288.000.
10.
<23.
333!
<25. *•«
172.000.
355.
<.4
<20.
96.100.
<25.
160.000.
<50. *
<32.
29!
MW-110
MQB420
Total
Value. ug/L
313.
<4.
<10.
530.
Kl

-------
                Table B-4 (conl.)
DISSOLVED AND TOTAL METALS ANALYSIS RESULTS
                IT Baker Facility
               Martinez. California
Station: SURFACE IMPOUNDMENT C
SMONo.: LTftus
Dissolved
Element Value. ug/L
Al <260. •
Sb 560. b
As 950.
Ba 130.
Be 
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                                                                          CO
                                                                          I
           Table B 5

   FIELD MEASUREMENTS AND
GENERAL CONSTITUENT ANALYSIS
         IT Baker Facility
        Martinez. California
STAT. No.
SMO. NO.

Parameter
PH
Conductance
Temperature
Turbidity
POX
TOX
POC
NPOC
Bromide
Chloride
Nitrate
Sulfate
Nitrite
Cyanide
Phenol
Sullide
Fluoride



Units
Units
u mhos/cm
C
NTU
ug/LCL
ug/LCL
ug/LC
ug/LC
mg/L
mg/LCI-
mg/LN
mg/L S04«
mg/L
"9/L
aQ/L
mg/L
mg/LF-
MW-1A
MQB457

Value
6.7
>20,000.
17.
240.
<5.
160.
3,620.
80.000.
56.
16,400.
<.3
1,240.
<.3
<10.
<50.
7.2
34.
MW-5A
MQB453

Value
6.4
>20.000.
16.
180.
<5.
307.
32.
71,000.
36.
10.200.
<.3
670.
<.3
<10.
<250.
<1.
27.
MW-6A
MQB446

Value
6.9
19,500.
18.
198.
<5.
107.
11.
46.000.
20.
6.000.
<.3
66.
<.3
<10.
<100.
<1.
12.
MW^BA
MQB448

Value
7.3
5.800.
18.
24.
<5.
43.
37.
10.000.
3.8
1,380.
<.3
170.
<.3
<10.
<50.
660.
3.6
MW9A
MQB451

Value
6.6
>20,000.
18.
350.
<5.
81.
670.
130.000.
27.
7.250.
<.3
720.
<.3
<10.
<100.
<1.
22.
MW-14
MQB456

Value
6.6
>20,000.
18.
270.
<5.
11,900.
20.
60,000.
49.
22.500.
<.3
2.400.
<.3
<10.
<50.
13.
48.
MW-15'
MQB447,
449, 452
Value
7.0
8.000.
20.
NAb
<5.
74.
20.
5.000.
12.
3.680.
< 3
248.
<.3
<10.
<100.
<1.
68
MW-101
MQB464

Value
6.9
19.500.
18.
48.
<5.
250.
<10.
89.000.
22.
7.600.
<.3
250.
<.3
<10.
<50.
63.
28.



LODa




5.
5.
10.
1.000.
1.
1.
.3
1.
.3
10.
50.
1.
1.
* Average of replicate analyses
a Limit of Detection; not corrected for dilution
° Kamnla i
nnf anak/*&4










-------
        Table B 5 (cont.)

   FIELD MEASUREMENTS AND
GENERAL CONSTITUENT ANALYSIS
         IT Baker Facility
        Martinez, California
STATNO.
SMONO.
Parameter
pH
Conductance
Temperature
Turbidity
POX
TOX
POC
NPOC
Bromide
Chloride
Nitrate
Sullale
Nitrite
Cyanide
Phenol
Sullide
Fluoride

Units
Units
u mhos/cm
C
NTU
ug/LCL
ug/LCL
ug/LC
ug/LC
mg/L
mg/LCI-
mg/LN
mg/L S04-
mg/L
ug/L
ug/L
mg/L
mg/LF-
MW-102
MQB419
Value
7.0
>20.000.
17.
250.
343.
17.
2,270.
111,000.
24.
8,750.
600.
<3
<10.
<50.
42.
24.
MW-103
QB454
Value
6.8
11.500.
19.
90.
<5.
82.
230.
47,000.
14.
4.440.
4.
<.3
<10.
<50.
5.
MW-104
MQB443
Value
NA*>
125.
10.
179.
170.
18.000.
23.
37.000.
29.000.
<.3
<10.
<50.
110.
20.
MW-105
MQB455
Value
6.9
>18.000.
18.
32.
91.
97.
50.000.
NAC
NAC
NAC
NAC
NAC

NAC
NAC
NAC
MW-106
MQB450
Value
6.5
>20,000.
18.
34.
6.560.
1.980.
114.
89.000.
22.
7,900.
192.
<3
<10
<50.
75.
20.
MW-110
MQB420
Value
7.5
>1 1.000.
19.
35.
<5
15.
73.000.
13.
4.600.
270.
< 3
<10
125.
11.
MW-112
MQB440
Value
6.8
> 18. 000
19.
54.
<5
NAC
23.
45.000.
NAC
NAC
NAC
NAC
NAC
NAC
NAC
NAC
NAC
• MW-113
MQB459
Value
6.8
>20.000.
20.
170.
<5
230.
2.620.
174.000.
40
14.400.
< 3
1.000.

10
<50.
g
22.

LODa


5.
10.
1.000.

1.
1.

10
50.
1
1.
a Limi of Detection; not corrected tor dilution • "
b Sample not analyzed
c Analysis not
requested










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                                                                     DO
                                                                     I
        Table B 5 (cont.)

   FIELD MEASUREMENTS AND
GENERAL CONSTITUENT ANALYSIS
         IT Baker Facility
        Martinez. California
STATNo.


SMO NO.
Parameter Units
pH Units
Conductance umhos/cm
Temperature "C
Turbidity NTU
POX ug/L CL
TOX ug/L CL
POC ug/LC
NPOC ug/L C
Bromide mg/L
Chloride mg/L Cl
Nitrate mg/L N
Sulfate mg/L S04>
Nitrite mg/L
Cyanide ug/L
Phenol ug/L
Sulfide mg/L
Fluoride mg/L F-
* Average of replicate analyses
MW-125


MQB460
Value
7.0
19,000.
17.4
150.
1,740.
NAC
3.150.
NAC
NAC
NAC
NAC
NAC
NAC
NAC
NAC
NAC
NAC

GWSEEP


MQB458
Value
NA6
NAb
NA6
NA6
<5.
4.050.
270.
1.135.000.
224.
81.000
<.3
4.800.
<.3
<20.
<50.
<1.
136.

Surface
Impoundment
D1
MQB444
Value
NA*
NAb
NAb
NA*>
<5.
8.000.
600.
12.300.000.
158.
19.000.
<.3
35.000.
<.3
21.000.'
1.450.
360.
600.

Surface
Impoundment
c
MQB445
Value
NA6
NA6
NAb
NAb
<5
8.540.
920.
11,500.000.
133.
37.000.
< 3
29.000.
<3
49.000.'
1.650.
240.
700.





LODa




5.
5.
10.
1.000.
1.
1.
.3
1.
.3
10.
50.
1.
1.

a Limit of Detection; not corrected for dilution
b Sample not analyzed
c Analysis not requested
•










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