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
-------
* 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
-------
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
-------
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
-------
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.
-------
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
-------
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
-------
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
-------
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
-------
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
-------
EXECUTIVE SUMMARY
-------
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)
-------
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.
-------
coirou*
OOfTfO u»
-------
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
-------
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.
-------
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
«•
-------
/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
-------
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.
-------
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
-------
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
-------
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.
-------
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
-------
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
-------
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.
-------
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.
-------
TECHNICAL REPORT
-------
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
-------
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."
-------
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
-------
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
-------
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.
-------
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.
-------
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 ®.
-------
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.
-------
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 .
-------
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
-------
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
-------
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
-------
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
-------
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.
-------
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 .
-------
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.
-------
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
-------
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
-------
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
-------
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.
-------
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.
-------
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«*«
-------
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
-------
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.
-------
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
-------
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.
-------
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.
-------
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
-------
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
-------
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
-------
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.
-------
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.
-------
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.
-------
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
-------
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.
-------
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.
-------
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.
-------
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.
-------
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.
-------
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.
-------
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.
-------
71
co
co
' LU
03 <
LU
CO
O
CO
>.
CO
o>
CO
is
II
O I
IE
CO
co •=
2 o>
e '5
LU
000
—I —' c^c^ -I —i-J —i <->-£ _j _j
oo Si. Si. oooo _J_roo
20
oooo oooo oooo oooo oooo oooo oooo
•«• T- co r» co CM co *- in in o CM o CM co o co o o in en in en co eo co r^ CM
•t n •*-r- CM ^r CM co CM in CM •v co co co co co ^ co CM CM co CM £ co co o en
CM ^ co ^T o r*^ r** co ^* CM co ^ r^ in in co ^ co r*^ in r** r** en oj co co in ^
CM ^ v- ^ CM i- ^ CM CM CO ^ CO CM ^ W CO W CM CM T^ r ^ T^ CM W CM W CM
in CM r-. cn o> in cq CM in CM cp CM r--1- p co in •<>; in CM cot-oco
cb cb cb in ^ cb in cb cbr^r^i^ cb rococo N! cb in in r^o'cdr^
CM CM r»
cb o cb
in co CM op cp ^ op ^ cp in CM r>* f*»o>^tc\j r^.cor»«CM co^fCMcn r^r^-cocvi
*- CM ^ O CM CO W ^ T^ W W W CM CM T-^ CO ^ CM CM CO W T^ r r r T-^ T^ T-^
incM^ui cp CM CM CM op CM i-; in in-^cnp en in r-. CM •* r>. TT i- TJ- rr CM en
en co en co en r^ en co r*- in co co lor^r^cb cb en cb r~ en en en o o'oocn
(0^0*0 CO^ O "O Rt^O'O (OXIUTJ CO 13 O TJ CO J3 O TJ CO X5 O "D
CM
<
CO
<
to
<
O
-------
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
-------
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.
-------
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.
-------
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.
-------
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)
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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.
-------
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.
-------
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
-------
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.
-------
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).
-------
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.
-------
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
-------
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.
-------
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.
-------
• 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.
-------
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.
-------
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:
-------
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
-------
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.
-------
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
-------
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.
-------
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
-------
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).
-------
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
-------
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.
-------
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.
-------
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
-------
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.
-------
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
-------
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
-------
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.
-------
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.
-------
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
-------
rno iir. live CASIIO
MUM lootma CAT
At
CJl
rvc st. I.I in. ii IIHI.%
• — I •
IM-MI 11-1 2.'l I'l.l 1*
^ ~ I NU-llM Mil IKf MWVKYI.II 12
IM-101 " " l«
IM-ll* ... M
IW-lU/ ... „
HM-2II* 11.% 1." II. > H
' IM-llll 11. 1 1.4 !•>.» U.»
• HU-lll |%.l l.\ II. • l« '
im-lil i.« i.n *.u w
IM-211 11. •» 1.* " * 14-1
: WM-21* It.* l.U !)•• I'
»
^*"^~ tt
|»" J|M-|.- I«.M 2.% 21
I'M.% IH4 114 l|%. II 11%. %
20 22 11 11 14
11.4 21. M 4|
21 24 14 |<).%
14 !«.% •«.% I'NI
11. • 24.* U.k 11 .« 41..%
*
It II 11 M 40
14.% |« n II. % 12.1
M 22 11. % U )%
lit.lt 11 42 42.1% 41.%
21.1 14 14 1% 4| .A
11 21 II 19 4n. %
1.
"••- -"•••- »" •'
1 1 « I/ » 1
-I'.1.) ....<»»!. . i'») (•••» n«> no
11 • 4 . -
III. 11 4
14 12 4
42.% •.?% 4 Hi
i*. % • 4 m in ii
Inn *.!% 4 in 12 )|
1*1 • 4 lit In 1 1
4| 12 4 - - -
11 12 4 - - -
1\ 12 4 - -
44 12 4 - - -
4|. % 12 4 |4 11 11.1
41.1 11 4 14 |1 11.1
ID
llx-fc 1* *> •xMll.d
writ IIU-2'M.
FIGURE 6
VINE HILL INTERIM STATUS MONITORING WELL COMPLETION DETAILS
-------
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.
-------
Constitution Details- Interim Status
Wells*
rm>ltCIIVE CASffM
VKIIII 1 OCHHKI CAP | | j
nf^i .
rvc si IP -on CAP 1
CEMCHI OIOCH i 1 »
anuiHHi sum ACS . , 1
V/i!/,
onoui - — •
v////////////////.
9CII 4OPVCBIAMM r
11 21 -
n 21 -
10 20 -
in 20 -
J9 99 -
54 64 - -
10 40 -
>2 42
2 12 -
65 75 -
15 15 16 IP
15 15 1» )•
11 21 24.5 25.5
19.5 29.5
26 16 1H 19
l« 29 11 15
:o 10 12 11
16 26 7? 11
27.5 11.5 4"» %0
74.5 14.5 17. ^ in. 5
1 /•A«l*fAl ftvU ••J'lll\ -
til ( 1 Cpl AC Oil Of rP* • • * f
12 42 42.5 41.5
17 in in
14.5 14.5 16 I/
(II)
71
2)
70
70
09
64
40
42
12
75
4O
4O
K..5
15
41 .5
in
15
41 .5
SI
41 .5
51 .5
'.0
(I..) (
12
17
17
12
n
8
K
t
H
12
12
12
12
17
17
12
12
12
12
12
>
12
17 4
12
In)
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
COMPLETION DETAILS
II. tin* Is Mean £f.i level
Hull'*:
"'llt-li;!.! of I-VC
(7) • ./
' 'in;- HI', nut co
KI 21-5 feel ;
c«slni; NM-.isiirliif poliil iil»>««: K""""' •"»««<•*•
xaiilieil flllt-r *nml
i.l.iceil fru- 14
'"nil II) nut rai.air.K 1 e J 'ulil. lower u.ishrd
(^)llll •,„ A. H. n. IS I/, a 1 /« Ilk mill II' IIOl
f 1 ller
lu 71 .5 fc.-l .
(t*inl; Im-cr l.i-nl out lo ne.il Ol
n .llriTl ly
„..,..! .111.1 IM
no n M 1 vr pol 1 .
• •I -in lit- r.e.il;
...
SCfttn iH) direct l<| ui> ».iil>'V -lull (I).
il-i> r Mini i l-it r i iii> Prrit>r;nn" A |- I ti- liinr'i
ro
ii t \. A»l)tluli.X M.M.'JV 1085.
-------
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.
-------
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
-------
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.
-------
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
-------
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
-------
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)
-------
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)
-------
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.
-------
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
-------
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),
-------
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)
O Quart**
Notraoulrad
A A/YHMjuy
5 SMVVftWHJMy
() FrtOMancy noyirrt by KM* tour quart** ot background™
to RaUpanmatar
a 1 fN«f»-MW (201 through 207, 209, 212 though 214)
Q "
Q
Q
X
A
X
A
X
A
X
Q
X
A
X
A
-
-
wvANi'y AM oaan oomplatad.
Q •
Q(A)
Q(S)
X
A
X
A
X
A
X
O
X
A
X
A
-
-
Q
Q(A)
Q(S)
Q '
Q '.
Q
Q
Q
Q
Q
Q '
Q *>'.
Q lot
Q *>t
Q
Q
Q '
Q '
Q
Q
Q *»'
Q lot
Q f
Q f
Q /
Q /
Q /
Q f
Q f
Q f
Q
c aaauHttromonasampfngapifedalocaiad ^ioampHmamApniw.
d Ofy^ Quartan olbickgmuiti monitoring tor lluo^ and nitn* co^^
a On* ihraa quartan ot background monitoring for lluonda and niniacernplaiadbyOacamoarigef.
t Ptnmmtwt not /wwftarf tt* nti»ftm*tu HM********* M .^M*^*^ j»u ^_ «AA« _j--.
-------
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
Q Qutrttrfy
Notrwqutrwd
X rrtqmncy not cftaefr tptdffttl in pian
A Annum?
s Semiannual^
(J f£*MWr*!X^tyteM»lb&quart»notb»c*orcurdmon^
f<^*^^b»nuj\W4jiMttbfr«mon*itt*nquarWrlyhr2quari»r*iri initial year of manuring.
to FitUotnmanr
* 29wtif.UW(1A,5A.aA.aA. 134. 14. 15. ItAandB. 17AtndB, 19, 101 trough 110, 112 through 114)
oflui^uunv moiuiQiing oogun tor MW117, Homo 119inQcioo*r 1965; four quvion not oornptotttd by Juno 1967.
f^L2^n °' ******* mon'torinO & MR* not cwrptoMrf by Oocombor 1966; not JOMpfaM* lor todHty to ;
h Ai pVevrwMr not roportod for qu^rtorfy monitonng, M nquirod by th* 1966 Sampling tndAnalymiPtan.
1 f^mrmtrtmia^ nnr r^rwimrl erir ^ i •i-»ai t r iT^iin'eniJn • ' «*..-^ ^.— _•__
Q
Q(A)
Q(S)
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
o
S
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
A
A
VOCMd ID
gh
gh
i
*>/
£•/•
*»'/'
i
i
t> i
t>i
annual
-------
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
-------
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
-------
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.
-------
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
-------
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
-------
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
-------
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
•
-------
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
7/West Jackson Boulevard, 12th Floor
Chicago, IL 60604-3590
------- |