EPA-700/8-88-047
                                  EPA-700/8-88-047
                     Ground-Water
                    i,  Ltd.
                   INVIRONMENTAL PROTECTION AGENCY
                   MN
                   (•ounces

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L.

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May 1988                             EPA-700/8-88-047
Hazardous  Waste Ground-Water
Task Force
Evaluation of
Land Reclamation, Ltd.
Racine, Wisconsin
        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                             n «?  "Environmental Protection A««nojr
          STATC OF WISCONSIN       U-S- Jmvironmenua.-i
             or HATUHAL HK.OUIIC.S    Eegion 5, Library (5PL-16)
                             230 S. Dearborn Sti-eet, Room 1670
                             Chicago, IL  60604

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                                 MAY  1988
                UPDATE OF THE HAZARDOUS WASTE  GROUND-WATER
             TASK FORCE EVALUATION OF  LAND  RECLAMATION,  LTD.
The United States Environmental Protection Agency's  (U.S.  EPA)  Hazardous
Waste Ground-Water Task Force, in conjunction with the  Wisconsin  Depart-
ment of  Natural  Resources (WDNR),  conducted  an evaluation  at  the  Land
Reclamation,  LTD. (LRL) hazardous  waste disposal  facility.   Land Reclama-
tion, LTD.  was one of 58 hazardous  waste treatment,  storage  and disposal
facilities investigated by the Task Force  nation-wide.   The Task  Force
effort is in  response to recent concerns as to whether  owners and  opera-
tors of  hazardous  waste  disposal  facilities  are  complying  with  the
Resource Conservation  and  Recovery  Act   (RCRA)  ground-water monitoring
regulations,  and whether the  ground-water monitoring  systems  in place at
the facilities  are  capable  of detecting contaminant  releases from  waste
management units.  Land Reclamation,  LTD. is  located  near Racine,
Wisconsin.  The  on-site  inspection  was  conducted  from  August  4  through
August 8, 1986.

This update of the Task Force evaluation  summarizes  salient  actions  con-
cerning the facility subsequent to the  field  inspection.

On September  23,  1986, a Comprehensive  Monitoring Evaluation  (CME)  was
conducted at  LRL.  The  CME  consisted of an on-site  ground-water  inspec-
tion, conducted  September 23, 1986,  and  a  treatment, storage,  and  dis-
posal (TSD)  facility  inspection  conducted  on  October  1,  1986.    The
findings of the  ground-water  inspection  were  in agreement  with the  Task
Force findings.  The  TSD  inspection found  violations regarding the  in-
stallation of  perimeter drainage  structures,  the  inspection  schedule,
and facility  access control.

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On January 13, 1987, a memo  from  Region V,  William Muno, HWEB, and  Karl
Bremen, SWB to Thomas  Geishecter,  ERRB in  U.S.  EPA Headquarters  recom-
mended that LRL be  nominated  to  the  National  Priorities List  because  of
potential  hazards  and LRL's noncompliance with RCRA.   However,  in November
1987, LRL sent a letter to William Muno as a result  of  an October 8,  1987
meeting with LRL,  U.S.  EPA, and WDNR expressing a willingness  to negotiate
a corrective action order  under RCRA.  The Order is currently  bring  draft-
ed.  As a  result of the letter, action to put LRL on  the National Priority
List (NPL) has ceased  at  this time.

On February 23,  1987, the  Wisconsin Department of Justice amended the  pre-
viouse complaint (see  text of report)  to incorporate  numerous  incidents
where LRL initiated construction activities withour prior WDNR approval.

LRL submitted a RCRA closure plan on January  27, 1987, which was denied  by
the WDNR.   A resubmitted  (August  13,  1987) closure plan is being reviewed
by the WDNR pursuant to NR  181.42(8) (.d).  The WDNR on-December 16,  1987
proposed extensive  modification  to LRL's RCRA monitoring program in a
draft closure and  Long-Term Care  Plan approval  letter.   The WDNR approved
LRL's closure plan on  March 31,  1988.

On August 4, 1986,  the  Wisconsin  Department  of Justice  filed  suit against
LRL in Racine County Circuit  Court.  The  complaint  alleges numerous  vio-
lations of the  State's hazardous  waste, solid  waste,  and  surface water
pollution regulations.   Hazardous waste violations  cited pertain to  clo-
sure and  ground-water  monitoring.   Specific ground-water violations in-
clude:  1) not sampling for  all  parameters  given in NR 181.49(5)(a) (40
CFR Part 265,  Appendix  III, EPA Interim Primary Drinking Water Standards),
2) not establishing background  concentrations within  the first year  of
monitoring, 3)  not  conducting  an annual evaluation   of  well  locations
based on  ground-water  flow  direction,  4)  not  submitting  the  results  of
statistical evaluations,   5)  failure to stabilize  the south  slope,  as
required by NR  181.42(8)(a),  and 6) inaccurate  inspection  logs,   as re-
quired by  NR  181.42(7) (d).   Other action  concerning   LRL  included the
following notices  of noncompliance  (NON)  or notices of violation  (NOV):

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DATE
ACTION
CITATION
8/13/86


8/26/86

9/23/86

10/15/86

10/20/86


12/3/86


2/17/87
NON


NOV

NON

NON

NOV


NON


NOV
5/11/87
NOV
Constructing Hazardous Waste (NR 181)  Closure
Structure without approval

Wastewater Discharge Permit Violations

NR 180 Daily cover and vegetative stress

NR 180 Leachate seeps and vegetative stress

Access control, ground-water data evaluation
Perimeter drainage  control,  and  inspections

Wind blown paper, leachate seeps and access
control

Failure to properly cover waste, constructing
NR 181 Physical/hydraulic barrier without
approval

Wind blown paper
LRL has constructed a sedimentation basin and  run-off  drainage  system  to
collect run-off from  this  site.  This  construction  has  resulted  in the
rechannelling of Gunderson Canal so it  flows  away  from the  site.   Damage
to this new drainage system along the south side of  the  site  has  allowed
leachate seeps to  flow  away  from the  sedimentation  basin  and off  site.
This damage has also  destroyed  a number  of wells in  both the RCRA and
State Solid Waste  ground-water monitoring  networks.

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LRL has  acknowledge,  after testing,  the leachate  collection system  in
Corridor 4 is  not  free flowing.   An  attempt to  clean out  leachate  from
the system indicated a blockage.

Solid waste is presently  being  disposed of in  Corridor  7.   Before  com-
mencing disposal  in this  corridor  a physical/hydraulic barrier was  con-
structed separating Corridor 7  from Corridor  1-6.

Since the Task Force inspection,  the site has  been annexed  by  the  city  of
Racine.  Also,  significant  residential  and  commercial  development has
taken place around the site.  Additional apartments have  been  constructed
directly east of the  hazardous waste  unit  and a  new  commercial shopping
center has been constructed south of the site.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
   HAZARDOUS WASTE GROUND-WATER TASK FORCE
      GROUND-WATER MONITORING EVALUATION
            LAND RECLAMATION, LTD.
           RACINE COUNTY,  WISCONSIN
                   MAY 1988
               JOHN J.  McGUIRE
        PROJECT COORDINATOR,  REGION V
       ENVIRONMENTAL SCIENCES DIVISION
           CENTRAL DISTRICT OFFICE

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                                TABLE OF CONTENTS


                                                                           PAGE
 I.   EXECUTIVE  SUMMARY

     A.   INTRODUCTION                                                        1

         1.   OBJECTIVES                                                      1

         2.   BACKGROUND                                                      3

             a)  History  of  Site                                              3
             b)  Adjacent Land  Use                                            5
             c)  State/Federal  Requirements                                   6

     B.   SUMMARY OF  FINDINGS AND CONCLUSIONS

         1.   COMPLIANCE  WITH INTERIM  STATUS GROUND-WATER MONITORING - WISCONSIN
             ADMINISTRATIVE CODE CHAPTER  NR 181.49  (40 CFR 265  Subpart F)    9

             a)  § 181.49(4)     (§  265.91) Ground-water Monitoring System     9
             b)  § 181.49(4)(h)  (§  265.92) Sampling  and Analysis              9
             c)  § 181.49(5)(d)  (§  265.93) Preparation, Evaluation, and
                 Response                                                   10

         2.   GROUND-WATER PROGRAM  PROPOSED FOR  RCRA PERMIT                   10

         3.   TASK FORCE  SAMPLING AND  MONITORING DATA ANALYSIS                11

         4.   CONFORMANCE WITH  SUPERFUND OFF-SITE  POLICY                      11

II.   TECHNICAL  REPORT

     A.   INTRODUCTION                                                        13

     B.   OBJECTIVES                                                          13

     C.   INVESTIGATIVE METHODS                                              14

         1.   TECHNICAL REVIEW  TEAM                                          15

         2.   LABORATORY  REVIEW TEAM                                          16

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                                                                       PAGE


    3.  SAMPLE REVIEW TEAM AND SAMPLE  COLLECTION                          16

        a) Methods                                                       16
        b) Sample Locations                                              20
        c) Quality Control and Quality Assurance                          21
        d) Custody of Sample Handling                                     22
        e) Scheduling                                                    25

D.  WASTE MANAGEMENT UNITS AND OPERATIONS                                 26

    1.  INTRODUCTION                                                     26
    2.  WASTE MANAGEMENT UNITS                                           28

        a) RCRA Regulated Units                                          28
        b) Pre-Interim Status Units                                       29
        c) Waste Characterization                                        30

           0 Introduction                                                30
           0 Discussion                                                  30

        d) Site Operation                                                33

           0 Waste Disposal                                               33
           0 Leachate Handling/Gas Collection                            33
           0 Surface Water Control and Discharge                          35
           0 Discussion                                                  36

E.  SITE GEOLOGY AND HYDROGEOLOGY                                        36

    1.  INTRODUCTION                                                     36
    2.  HYDROGEOLOGIC UNITS                                              37
    3.  HYDRAULIC CONDUCTIVITIES AND GROUND-WATER  FLOWS                   39

F.  GROUND-WATER MONITORING PROGRAM  DURING  INTERIM STATUS                 45

    1.  REGULATORY REQUIREMENTS                                          45
    2.  GROUND-WATER MONITORING SYSTEM                                   45

        a | Monitoring Well History                                        45
        b) Monitoring Well Location                                       50
        c) Background Ground-Water Quality                                53
        d) Monitoring Well Construction                                   53

    3.  SAMPLING AND ANALYSIS

        a) LRL's Sample Collection Handling,  Preservation
            and Field Measurements                                        55
        b) LRL's Sample Analysis and Data Quality  Evaluation              59

           0 Inorganic Laboratory                                        60
           0 Organic Laboratory                                          62

    4.  GROUND-WATER QUALITY ASSESSMENT  OUTLINE                           63

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                                                                             PAGE
      G.  MONITORING DATA ANALYSIS FOR INDICATIONS OF WASTE RELEASE

              TASK FORCE DATA

              a) Metals Analytical Results
              b) Inorganic And Indicator Parameter Results
              c) Organic Analytical Results
64

65
66
68
REFERENCES
71
APPENDIX A  ANALYTICAL TECHNIQUES AND TABULATED
            SUMMARY OF TASK FORCE OBSERVATIONS
            FOR MONITORING WELLS SAMPLED DURING
            THE INSPECTION
APPENDIX B  EVALUATION OF QUALITY CONTROL ATTENDANT
            TO THE ANALYSIS OF SAMPLES FROM THE
            LAND RECLAMATION, WISCONSIN FACILITY
APPENDIX C  SUMMARY OF LRL's CONTRACT LABORATORY
            PERFORMANCE EVALUATION STUDIES

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                                                                         PAGE


FIGURES

  1.  SITE LOCATION MAP                                                     4
  2.  CHAIN OF CUSTODY RECORD                                              23
  3.  MAP SHOWING SITE OPERATIONS                                          27
  4.  POTENTIOMETRIC CONTOUR IN THE WATER TABLE                            40
  5.  POTENTIOMETRIC CONTOUR IN THE UPPER SAND                             41
  6.  POTENTIOMETRIC CONTOUR IN THE LOWER SAND                             42
  7.  MONITORING WELL LOCATION MAP                                         49
  8.  RCRA MONITORING WELL LOCATION MAP                                    51
  9.  TYPICAL MONITORING WELL                                              54

TABLES

  1.  PREFERRED ORDER OF SAMPLE COLLECTION, BOTTLE TYPE,
       AND PRESERVATIVE LIST                                               19
  2.  HAZARDOUS WASTE ACCEPTED BY LRL                                      31
  3.  LABORATORY PERMEABILITY OF THE OAK CREEK
       SOIL BENEATH LRL LANDFILL                                           44
  4.  CONSTRUCTION DATA FOR LRL's MONITORING WELLS                         46
  5.  COMPARISON OF DISSOLVED METALS DATA
       FROM UPGRADIENT WELLS (6U, 108U) AND
       DOWNGRADIENT WELLS                                                  67

APPENDIX A

  A-l  SAMPLE PREPARATION AND ANALYSIS TECHNIQUES AND METHODS
  A-2  LIMITS OF QUANTITATION FOR ORGANIC COMPOUNDS
  A-3  CONTRACT REQUIRED DETECTION LIMITS AND INSTROMENT DETECTION
        LIMITS (IDL) FOR METALS, INORGANIC AND INDICATOR PARAMETERS
  A-4  SUMMARY OF OBSERVATIONS MADE DURING SAMPLING OF LRL MONITORING
        WELLS
  A-5  SUMMARY OF PURGE DATA COLLECTED FROM WELLS AT LRL

APPENDIX B

  TABLES FOR SITE:  41B LAND RECLAMATION, WISCONSIN

APPENDIX C

  C-l  SUMMARY OF WATER SUPPLY PERFORMANCE
        EVALUATION STUDIES, INORGANICS
  C-2  SUMMARY OF WATER POLLUTION PERFORMANCE
        EVALUATION STUDIES, INORGANICS
  C-3  SUMMARY OF WATER POLLUTION PERFORMANCE
        EVALUATION STUDIES, INORGANICS AND ORGANIC

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                          1.   EXECUTIVE  SUMMARY
A.  INTRODUCTION

    Concerns have recently been raised as to whether the commercial hazar-
    dous waste treatment,  storage,  and  disposal  facilities are in compli-
    ance with the ground-water monitoring  requirements  promulgated under
    the Resource Conservation  and  Recovery  Act (RCRA)*.   Specifically,
    the concerns focus on the ability of ground-water monitoring systems
    to detect contaminant releases from  waste management units  at these
    facilities.   In  response to these concerns, the Administrator of the
    United States Environmental  Protection Agency (U.S.  EPA) established
    a Hazardous  Waste  Ground-Water Task  Force  (Task  Force) to  evaluate
    the level  of compliance at these facilities and address the cause(s)
    of noncompliance.   The Task Force  comprises personnel  from  U.S.  EPA
    Headquarters, U.S.  EPA Regional  Offices, and State  regulatory agency
    personnel.

         1.    OBJECTIVES

    To determine the status of facility  compliance, the  Task  Force is con-
    ducting  indepth facility investigations, including on-site inspections
    with the following  objectives.

         0 Determine compliance with  interim  status ground-water monitor-
          ing requirements  of 40  CFR Part  265 as promulgated under RCRA
          and Wisconsin Administrative Code, Section NR  181.49(5).

         0 Evaluate the ground-water  monitoring program described  in the
          facilities'  RCRA  Part  B  permit  applications for  compliance
          with  40  CFR Part 270.14 (c) and  potential  compliance  with 40
          CFR 264  Subpart F,  Wisconsin  Administrative  Code Section NR
          181.49(6).
     Regulations promulgated under  RCRA  address hazardous  waste manage-
     ment facilities'  operations, including  ground-water  monitoring, to
     ensure that  hazardous  waste constituents  are not released  to the
     environment.

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                                   -2-
    0 Determine if  the  ground-water at  the  facility contains hazardous
      wastes or hazardous  waste  constituents.

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

    0 Provide information  to assist the Agency in determining  if the faci-
      lity meets  EPA  ground-water   monitoring   requirements  for  waste
      management facilities  receiving waste from response  actions conduct-
      ed under the Comprehensive Environmental Response,  Compensation and
      Liability Act (CERCLA,  Public  Law  91-510).  *

To address these objectives,  each Task Force  investigation will determine
if:

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

    0 RCRA (and/or State-required) monitoring wells  are  properly located
      and constructed:

    0 required analyses  have been conducted on samples from the designated
      RCRA monitoring wells;  and

    0 the ground-water  quality  assessment program  outline  (or  plan,  as
      appropriate) is adequate.
* "Procedures for  Planning  and Implementing  Off-Site Response Action";
   Federal Register, Vol. 50,  No. 214, Page  459-463,  November 5, 1985.

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                                   -3-

         2.   BACKGROUND

The thirtieth facility  investigated  by the Task  Force  was the Land  Re-
clamation, LTD.   (LRL)  facility,  located  near  Racine,  Wisconsin  (FIGURE
1). The LRL  facility  is  a  family-owned  waste  management company  that
operates a  solid waste landfill  at  this  site.   The on-site  inspection
was conducted from August 4  through  August 8, 1986, and  was  coordinated
by personnel  from the  U.S.  EPA,  Region  V,  Central  District  Office.
Representatives  of the Wisconsin Department of Natural  Resources  (WDNR),
U.S. EPA Headquarters, and U.S.  EPA  Region V's RCRA Enforcement  Section
also participated in the in the  inspection.  The  investigation, in  gene-
ral, involved review of State,  Federal  and facility  records, the facility
inspection, laboratory evaluation,  and ground-water sampling and analysis.

          a) History  of Site

The LRL landfill  is on  an 81 acre  site,  near Racine, in  the town of  Mt.
Pleasant,  Racine   County,  Wisconsin.   The  site  is  located on  a  north-
south ridge, known as the inner  Lake  Border Moraine, approximately  rang-
ing in elevation from  720  feet on the eastern side  of  the site,  to  680
feet on the western side.   Gunderson  Canal,  an intermittent creek, drains
to the Pike River and is located  on the western side of the ridge of  the
site property.   State Route  31  (South Green Bay Road) is  located approxi-
mately 1/4 mile  east  of the  site.

In 1963, the city  of  Racine  leased the southwest corner  of the site  for
municipal  waste   disposal.   The  Racine Department  of Public  Works  ope-
rated the   site  for  use  by  residents  and  the  city.   Commercial waste
haulers were not  permitted to  use  the  facility.   Waste  disposed of con-
sisted primarily  of residential  solid waste and  incinerator ash from  the
city-owned incinerator.   On  occasions,  foundry  sand was  used as cover
material,  and at  least one local  industry,  indicated in its RCRA  notifi-
cation, that  it   sent  hazardous   waste  to  this  site   in the  1960's.

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                                   -5-
LRL assumed operation of the  city  of Racine landfill  in August 1970,  and
expanded operations to the eastern portion  of  the  site.   This  portion  of
the site was  constructed in phases called  corridors.   At the time  of  the
inspection, six corridors either were filled or in use.  A seventh  corri-
dor was under construction, but did not contain any waste.  Waste defined
as hazardous  and toxic  was first noted as  being disposed  of at  the  site
in June of 1973.

          b) Adjacent Land Use

LRL is located in an area consisting  of a mix of residential, commercial,
and light  industrial  development.   A multi-family  rental  development  is
being constructed on  contiguous property,  east of  the facility.   Single
family residences are  located to the  north and  northeast with a  small
subdivision also located to the south of the property.   A mix  of private
and public water supply systems service these residential  areas.   Develop-
ment plans  call  for continued  extension  of public water supply in the
region.

A regional shopping  center  is  located southeast of  the  property.   Develop-
ment plans call  for  expansion  of this commercial complex to property  adja-
cent to the southern boundary  of the  facility.  Extension of an  existing
public street (21st Street) is  proposed  contiguous  to  the south  property
boundary.  At the time of the  inspection,  the facility  was located  in the
Village of Mt. Pleasant.  Subsequent  development have resulted in signifi-
cant portions of LRL operations  and  adjacent properties  being  annexed  to
the city  of Racine.  Within  1/2  mile of  the  site, are located a high
school, grade school,  and Senior Citizens Housing  Complex.

Open land contiguous to  the north of the facility is being proposed  by LRL
as an expansion  to the existing 81 acres site.   A sand and gravel operation
and utility substation are  on  land contiguous to the west of the  facility.
Manufacturing industries  are located  southwest  of  the facility.

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                                   -6-

          c) State/Federal  Requirements

LRL must meet the requirements  for ground-water monitoring  near  hazardous
waste landfills  given  in Wis.  Adm.  Code  Section NR  181.49  (Groundwater
and Leachate Monitoring  Standards)  (40 CFR  Part 264,  Subpart F and  Part
265, Subpart  F);  Section  NR  181.44  (Landfill  and  Surface  Impoundment
Standards), Wis.  Adm.  Code (40  CFR  265 Subpart  N) and  Sections  NR  181.44
(12) and Section NR  181.42(8) and(9) (Closure and Long  Term Cure)  (40 CFR
265 Subpart  E).  In   addition,  further state requirements  are  found  in
Chapter 140 and Chapter 180 of  Wis.  Adm.  Code.

On August 19, 1980,  LRL filed a notification  of  hazardous  waste activity
for its land disposal  facility  with U.S. EPA.   On November 19,  1980, LRL
filed Part A  of  the  permit  application with U.S. EPA, and thus obtained
interim status.  On  December 10,  1982, WDNR  denied LRL  an  interim  license
under Ch.  NR  181,  Wis.  Adm.   Code, and  required LRL  to   stop  accepting
hazardous waste.   The  license  was  denied  because  LRL did not  meet  the
minimum requirements for interim  license  under  NR  181.42  and NR  181.44
and NR  181.53 Wis.   Adm. Code.   (The WDNR's  denial  was  upheld   by' the
Wisconsin Circuit Court  in July  1983).   The denial  ordered LRL to close
the corridors  containing hazardous  waste,  (Corridors 1  through  4),  by
June 1983.  This had not been  completed at  the time   of the  inspection.

On December 19, 1984, WDNR issued  a Conditional Plan of Operation Apprcval
for solid waste disposal  under  Ch. NR  180,  Wis.  Adm. Code.   The  approval,
among, other things,  required LRL  to submit  plans for a containment  struc-
ture to  be  constructed on  the  south  side  of  the landfill to  intercept
leachate and ground-water which was leaving  the site.   At  the  time  of the
inspection, LRL  had  not  submitted  plans  for the containment structure.
Numerous conceptional  design proposals had  been  prepared  by LRL,  but did
not meet requirements  needed for  the WDNR approval.

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                                   -7-
LRL opted not to pursue obtaining a final RCRA permit for operating  a  haz-
ardous waste landfill  and has not submitted  a Part  B permit  application.
LRL did  not  certify compliance with  applicable ground-water monitoring
and financial responsibility requirements by November 8, 1985.   Although
LRL submitted a  closure plan  on November 25,  1985,  the plan  did not  speci-
fically address  closure requirements for the hazardous  waste  portions  of
the landfill.

As a result of inspections and record reviews, WDNR has issued a  number of
notices of  noncompliance  (NONs)  and  notices of  violations   (NOVs).    In
Wisconsin's enforcement  strategy,  NOVs are more serious than  NONs.   NOVs
and NONs issued on  the given date  follow,  with the  violations cited  are
summarized below:
  DATE

1973-79


4/25/80

12/23/80


2/25/81

4/7/81


5/6/81



4/21/82


8/26/82

10/7/82


10/19/82


11/4/82
  ACTION

   NON


   NON

Proposed Order


   NON

U.S. EPA NOV


   NON



   NON


   NON

   NON


   NON


   NOV
  CITATION

:  Uncontrolled leachate  seeps,  windblown  paper
  and inadequate daily  cover

:  Failure to pay Waste  Management  fund  fees

:  Requires LRL to submit an updated  plan  of
  Operation

:  Failure to pay Waste  Management  Fund  Fees

:  Failure to distribute  contingency  plan  to
  local  authorities

:  Windblown paper,  filling  in  unapproved
  areas, and  failure   to  maintain   leachate
  head levels

:  Failure to met solid  waste  (NR 180)
  Ground-Water Monitoring Requirements

:  Spreading leachate on  exterior access road

:  Failure to meet hazardous waste  (NR 181)
  Ground-Water Monitoring Requirements

:  Violation of hazardous waste  (NR 181)
  Requirements

:  Failure to maintain  leachate  levels and
  cut-back south scope

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  DATE

12/7/82


8/9/83


2/27/84


4/10/84
ACTION

 NON


 NON


 NON


 NOV
10/31/84
12/6/84
5/23/85
 NOV
 NON
 NON
10/9/85
 NON
10/11/85
 NOV
10/16/85  Proposed Special
          Order
     -8-

CITATION

Notice to LRL to terminate leachate recir-
culation

Hazardous Waste (NR 181)  Ground-Water and
Leachate Monitoring Violations

Windblown paper, leachate seeps,  and fill-
ing not  in  accordance with  plan  approval

Leachate head maintenance, not filling in
accordance with plan  approval, maintenance
of NR  181  Ground-Water   discharge  permit
violations

Failure to protect and lock wells,  failure
to maintain NR  181  Ground-Water  Monitoring
Network

Failure to properly abandon inoperable
wells, acceptting non-approved waste
(Racine Sewage)

Failure to submit NR 180  and NR 181 Ground-
Water Monitoring  Results,  failure  to docu-
ment well abandonment.   Failure  to  comply
with conditions of NR 180 Plan of Operation
Approval

NR 181 Violations; inspections, maintenance
of contingency  plan,  development training,
development of  closure  plan,  failure  to
perform Ground-Water Monitoring Data
Evaluation

NR 181 and NR 180 Plan of Operation Condi-
tions

Required Methane Migration Study.

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                                   -9-

B.  SUMMARY OF FINDINGS AND CONCLUSIONS

    1.  Compliance With Interim Status Ground-Water  Monitoring -  Wisconsin
        Administrative Code Chapter NR 181.49(5)  (40 CFR  265  Subpart  F)

        a) $181.49(4) (§265.91) Ground-Water Monitoring System

LRL's  present ground-water monitoring system is inadequate to  meet the re-
quirements of 40 CFR  265  Subpart  F.  Presently, the  RCRA  system  consists
of six wells, two designated as upgradient and four  as  downgradient.   The
existing well system  does  not  meet  the  performance  standard  of immediate
detection of  releases.   Additional  permanent wells  are  needed  and  must
include wells in  all  three water  bearing  zones  located under the  site.

Additional wells are  needed  along the  west  side  of the hazardous  waste
unit.  Presently, LRL  has  not  placed  wells  directly at  the  downgradient
limit of  the  western portion  of  the  hazardous waste  unit  because  this
area has been approved for future filling.

The Wisconsin Department of Natural Resources  (WDNR), pending  closure  plan
approval, will require LRL to define the western  most limit of the hazar-
dous waste unit.

        b) 5181.49(4)(h) (§265.92) Sampling and Analysis

A number  of deficiencies were  noted  in  LRL's Sampling  and Analysis Plan.
Many are  problems that can  be  easily  corrected.   These include analyzing
the samples  within  the  required  holding times,  improving  the  sampling
quality control practices  by including  reagent  blanks, equipment blanks,
and sufficient sample volume so  the  laboratory can perform spike analysis.
Also, LRL  needs  to  better document the  actual sampling  procedures being
used.

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                                   -10-
Th e current laboratory that LRL uses  needs  to  improve  its  overall  quality
assurance/quality control  procedures.  This includes more stringent accep-
tance limits for metal  spike recoveries,  better  calibration curves  for
atomic absorption spectrophotometry, and nitrate analyses.   The  laboratory
needs to finalize  and document the method to  be  used to  perform  metals
analyses by  inductively  coupled plasma  spectroscopy.  Improvements  are
also needed in  the organic laboratory.

        c)  5181.49(5)(d)  ($265.93)  Preparation,  Evaluation, and  Response

At the time of  the inspection,  a March  1986,  statistical analysis  submit-
ted by LRL  indicated  that  four wells LRL describes as  part of the  WDNR
solid waste monitoring system were  in assessment monitoring under  NR  181.
The summary portion of this report  indicated  that  no statistically signi-
ficant increases were  found  in  the RCRA system of  wells.  A  subsequent
review by the WDNR  found that LRL was in error and that there were  statis-
tically significant increases  in  the RCRA wells.   LRL, therefore,  must
prepare an  assessment monitoring  plan  as  required   by  NR  181.49(5)(h)
(40 CFR 265) and resample  the RCRA  wells.

    2.  GROUND-WATER PROGRAM PROPOSED FOR  RCRA PERMIT

LRL did not  file  a Part B permit application.   Therefore,  LRL  must close
the hazardous  waste  unit.  At   the time of  the inspection, LRL had  not
submitted an acceptable closure plan.   In  addition, LRL must comply  with
the ground-water requirements found in  40 CFR Part 265.

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                                   -11-

    3.  TASK FORCE SAMPLING AND MONITORING DATA ANALYSIS

Seven wells indicated  chromium  and  lead  levels  above the limits  given in
Table X, NR 181.49  (5) Wis.  Adm. Code.  (40 CFR Part  265,  Appendix III).
The Table X limits are 50 ug/1 chromium and 50 ug/1  lead.  These  included
wells in both  the  State solid  waste  system and the  RCRA  system.   Wells
affected were 6U (Chromium - 98 ug/1), 14U (Chromium 195 ug/1,  Lead -  108
ug/1), 14L (Chromium 102 ug/1, Lead -  66 ug/1), 40U (Chromium  -  56 ug/1,
54 ug/1), 40L (Chromium - 107 ug/1, 116  ug/1),  29L  (Lead - 51  ug/1),  and
39U (Lead - 165 ug/1).

Two wells had  high  or low pH measurements.   Well  lOU's pH was  6.17  and
Well 39U's pH was 10.45.

Organic analyses of the ground-water monitoring wells indicated that a re-
lease of hazardous constituents  is probably occurring at LRL.   Background
wells did not  detect  any  organic  compounds.   Results  from 39U  found  a
number of organic  compounds  ranging  from 4.8  ug/1  2-Methyl Phenol  to  70
ug/1 Xylene.  These organics  include:  volatile compounds,  acetone,  ben-
zene, trans-1,2dichloroethene, ethyl  benzene,  tetrachlorethene,  toluene,
trichloroethene and  xylene;   the semi-volatile  compounds,  2,4-dimethyl
phenol, 2-methyl phenol,  4-methyl  phenol;  and  the  pesticides,  4-4'-DDD
and dieldrin.

The leachate sample contained high concentration of  metals,  organics,  and
indicator parameters.

    4.  CONFORMANCE WITH SUPERFUND OFF-SITE POLICY

The LRL site does not  have interim status, has  not  applied  for a permit,
and is in the  process  of closing.  Therefore,  this  site can  not  accept
waste generated at superfund clean-up  sites.

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                                   -13-

                          II.   TECHNICAL REPORT
A.  INTRODUCTION

    Operation at hazardous waste  treatment,  storage,  and  disposal  (TSD)
    facilities are regulated  by  the Resource  Conversation and  Recovery
    Act (RCRA P.L. 95-589).  Regulations issued pursuant to RCRA  (40  CFR
    Parts 260 through  265, as modified)  address  waste  site  operations
    including monitoring of  ground-water  to  ensure that hazardous  waste
    and hazardous  waste  constituents   are   not  being  released  to  the
    envi ronment.

    The Administrator of the  U.S.  Environmental  Protection  Agency
    (U.S. EPA)  established a  Hazardous Waste  Ground-Water  Task  Force
    (referred to  hereafter as Task Force)  to evaluate  the  levels   of
    compliance with ground-water  requirements  at  on-site and  commercial
    off-site TSD facilities and address the  cause  of noncompliance.   In
    addition, the Task Force  was to examine the suitability of the  faci-
    lity as  a provider  of treatment,  storage,  or  disposal  services  for
    waste managed by the Agency's  Superfund  program.   The Task Force  is
    comprised of personnel from EPA Headquarters,  Regional offices,  and
    the States.   Currently, 58 TSD  facilities  are  scheduled  for  ground-
    water evaluations.   One  of  these  was  Land Reclamation,   LTD.  (LRL),
    near Racine, Wisconsin.

B.  OBJECTIVES

    The Task Force inspection of LRL was conducted from August  4 to August
    8,  1986, with the objectives of  the  evaluation listed below:

    0  Determine  compliance with requirements of Wisconsin  Administrative
      Code Section NR 181.49(5)  (40 CFR  265  Subpart F)  - ground-water
      monitoring and  the monitoring system's capability of providing  the
      required monitoring  data.

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                                   -14-
    0 Evaluate the  facility's ground-water monitoring program as  described
      in the RCRA Part B permit  application  for  compliance  with  Wis.  Adm.
      Code Chapter   NR  181.51 and  NR  181.55  (40   CFR  Part  270.14)(c).

    0 Evaluate the  facility's potential  compliance with  Wis. Adm.  Code
      Section NR 181.49(6)  (40 CFR Part  264  Subpart  F).

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

    0 Determine if any  ground-water contamination   currently  exists  from
      site operations.

    0 Provide information to assist the Agency  in determining if the TSD
      facilities meet U.S. EPA  ground-water monitoring  requirements  for
      waste management facilities receiving waste from actions  conducted
      under the  Comprehensive  Environmental Response,  Compensation  and
      Liability Act (CERCLA).

C.  INVESTIGATIVE METHODS

    The Task Force  investigation at  LRL  consisted of:

    0 Reviewing  and   evaluating   records  and documents  from  U.S.  EPA,
      Region V, WDNR, and LRL.

    0 Conducting an  on-site  inspection  from August 4 through August  8,
      1986.

    0 Evaluating off-site laboratories contracted by LRL for  analysis  of
      past and present ground-water samples.

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                                   -15-
    0 The sampling  and  analyzing  of ground-water from monitoring  wells,
      a surface water discharge point,  and a leachate sump.

To accomplish the  objectives,  a  facility Evaluation Team was  assembled,
and comprised of  a  Technical  (record)  Review Team,  a Laboratory  Evalua-
tion Team (to evaluate  on-site laboratories and off-site contract  labo-
ratories), and  a  Sample  Collection  Team.   Each  Team  had  individual
responsibilities to achieve the objectives of the Task Force.

    1.  TECHNICAL REVIEW TEAM

The Technical Review Team  was  responsible for  conducting the  evaluation
of the facility  with respect to  applicable ground-water monitoring  re-
quirements.   The  evaluation was  divided   into  six  areas   as  follows:

    0 site history and design
    0 site geology and hydrogeology
    0 ground-water monitoring system
    0 ground-water sampling and analysis
    0 ground-water data quality and  interpretation
    0 waste characterization and operations

Records and documents from U.S. EPA, Region V,  and the WDNR  offices,  were
compiled by the Planning Research  Corporation (PRC)  of Chicago,  Illinois,
under contract with the U.S. EPA.  These documents  were  reviewed prior to
and during the on-site inspection.   On-site  facility records  were reviewed
to verify and augment  information currently in  government  files.   These
records were reviewed to obtain information  on  facility  operations,  con-
struction details of waste management units, and the ground-water monitor-
ing program.  The  facility  was requested to  supply  the  U.S.  EPA with  a

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                                   -16-
copy of selected documents for an in-depth evaluation.   Specific  documents
and records that were reviewed included the facility ground-water sampling
and analysis plan; outline of the facility ground-water quality assessment
program; analytical  results  from  past ground-water sampling; monitoring
well constuction data and boring logs; site geologic  report; site  opera-
tions plan; facility permits; waste management  unit design  and  operation
reports; and operating records  specifing the general  types  of waste,  the
quantities of waste, and location where the waste  was disposed  of  at  the
facility.

    2.  LABORATORY EVALUATION TEAM

The off-site laboratory that analyzed LRL's sample was evaluated regard-
ing its responsibilities under the  LRL ground-water sampling and analysis
plan.   Analytical equipment  and  methods,  and  quality assurance procedures
and records were examined for adequacy.  Laboratory records were  inspected
for completeness, accuracy,  and  compliance with State and Federal require-
ments.  The ability of the  laboratory  to  produce quality  data for the  re-
quired analyses  was  also evaluated.   Later  in  this   report, a   detailed
discussion  of this evaluation   is presented  under "Sample Analysis  and
Data Quality Evaluation".

    3.  SAMPLE REVIEW TEAM  AND SAMPLE  COLLECTION

          a) Methods

Samples for the Task Force evaluation were collected by Versar, Inc.  (here-
after referred to as  Versar), a U.S. EPA contractor, under the supervision
of U.S. EPA personnel.   Teflon®* (perfluoroethylene) bailers, provided by
* Teflon® is  a registered trademark and will appear hereafter without the

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                                   -17-
Versar were used to sample for volatile organic analyses (VOA), purgeable
organic  carbon  (POC),  purgeable  organic halogens  (POX),  extractable or-
ganics,  metals, phenols, cyanide,  sulfate/chloride,  nitrate and ammonia.
Clean sample  bottles  and  preservatives  were  provided  to  Versar  by  a
U.S. EPA  contract  laboratory  for both the Task Force  and  facility split
samples.  Versar also supplied all  the  equipment   and materials necessary
to  manage, handle, field  filter,  document,   and  ship the Task Force sam-
ple.

Prior to  obtaining  water levels,  purging, or sampling,  Versar monitored
the open  well  head for  organic  chemical  vapors  using  a photoionization
detector to ensure the well head  was safe.  After  safety screening, static
water levels  were  measured in 58  wells  for  use  in  the   hydrogeological
evaluation of the  site.  All  water level  indicator units were calibrated
to ensure comparable measurements.

Monitoring well sampling activities were proceeded by purging of the sta-
tic water column, using the Teflon  bailers.   Where possible,  a  volume  of
water equal to three times the water volume present  in the  well  was eva-
cuated before sampling.   When these volumes  could not be  obtained,  the
wells were purged  to  dryness.   Slow recharging wells  were  sampled  when
there was a  sufficient volume of  water to fill  at  least  one  parameter
bottle set, including  split  samples  for LRL.  On some occasions,  this
required purging on  one day and sampling  on  the  next day.   To  obtain  a
sufficient volume of water for all  parameters, it  was necessary  to return
to some wells  on a  number of occasions.

Methods of sample  collection  depended  on  the  nature  of  the  sample site.
All  well  sites were sampled using  a dedicated Teflon bailer  supplied  by
Versar.  In most  cases, well  recharge  rates  were  sufficient  to  allow
sampling immediately after purging.  At  some  wells,  it was  necessary  to

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                                   -18-
wait 2 hours to 24 hours for the well to recharge  sufficiently to  obtain
the desired sample volume.  The bailer and cable used at such wells  were
left on site,  sealed and  kept  under  custody.   Some wells  required  two  or
three visits to obtain the required  sample volume.   Purging and  sampling
data are summarized in Table  A-4 and A-5  in Appendix A.

All sample bottles were  filled directly  from the bailer using a bottom-
emptying device.  Volatile organic  analyses  (VOA)  vials  were filled  as
replicate samples while  other  sample bottles were  filled  proportionally
between U.S.  EPA and facilty containers.  Sample  bottle types, preferred
order of  filling,   sizes  and   preservatives  are  listed   in Table  1.

The surface sample  was collected at  the  location  where LRL  is  required  to
sample their surface discharge, under their Wisconsin Pollution Discharge
Eliminination System  (WPDES)  permit.   Versar  personnel  collected  this
sample by wading into  the stream and  directly filling the sample container
by immersing them in the water.  A  split  was collected  for LRL for  VOA,
POC, POX, and extractable organ.ics.

A sample was taken, using  a  Teflon  bailer,  from one of the LRL  leachate
sumps.  The Versar sampling team, wearing level  B  safety  protection  (i.e.,
SCBA and protective clothing), filled the sample containers,  in the order
given in Table 1.   For safety  reasons, these  samples were  not chemically
preserved, but were  kept  iced during  sample handling  and shipment.  A split
was given to LRL for VOA, POC,  POX,  and  extractable organics.

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                                   -19-

                            IAlii   1

                  PREFERRED ORDER OF SAMPLE COLLECTION

BOTTLE-TYPE, AND
Sampling
Order Parameter
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
Field Measurements *
Volatile organics
Purgeable Organic
Carbon (POC)
Purgeable Organics
Halogens (POX)
Extractable organics
Total metals
Dissolved metals **
Total Organic Carbon
(TOC)
Total Organic Halogens
(TOX)
Phenols
Cyanide
Sulfate and chloride
Nitrate and ammonia
PRESERVATIVE LIST
Bottle-Type
1 -200 nt Plastic
4 -
1 -
1 -
4 -
1 -
1 -
1 -
1 -
1 -
1 -
1 -
1 -
40 mL VOA vials
40 mL VOA vial
40 mL VOA vial
1L amber glass
1L plastic
1L plastic
50 mL glass
1L amber glass
1L amber glass
1L plastic
1L plastic
1L plastic
Preservatives
None
Cool 4°C
No Headspace
Cool 4°C
No Headspace
Cool 4°C
No Headspace
Cool 4°C
HNOs to PH<2
Cool 4°C
HN03 to PH<2
H2S04 to PH<2
Cool 4°C
Cool 4°C
No Headspace
H2S04 to PH<2
Cool 4°C
NaOH to PH>10
Cool 4°C
Cool 4°C
H?S04 to PH<2
                                                            Cool 4°C

 * Field  measurements included pH,  specific  conductance, temperature and
    turbidity.

** Samples  were  filtered before preservation with

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                                   -20-

          (b) Sample Location

Samples were taken  from  the  17   monitoring  wells listed  below,  as  well
as WPDES sample point  001  and  a leachate sump.  Wells being  used by LRL
to report on RCRA compliance  are noted with a R.

                           MONITORING WELLS SAMPLED

                            6U(R)     22U        40U

                            6L        221        40L

                            9U        29U       108L(R)

                           10U(R)     29L       109U

                           14U        30L(R)    110U

                           14L        39U

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                                   -21-

    c) Quality Assurance and Control

Quality assurance and quality  control  (QA/QC)  for EPA contractor  sample
collection, handling and  analysis  was conducted  in  accordance with  the
Hazardous Waste Ground-Water Task Force  -  Protocol  for Ground-Water Eval-
uation (EPA, 1986a)  prepared by the Task Force.   The Sampling Team  review-
ed Versar's procedures during the sample effort to ensure consistency with
the QA/QC and evidence handling requirements.

Versar also prepared  and  submitted to  the contract  laboratories,  three
types of  blanks  during the inspection period.   Field  blanks,  for  all
parameters, were prepared on August  5,  (near  Well  29L), August 7  (near
Well 40U),  and  August  8,  1986 (near  Well  40U),  by pouring  high  perfor-
mance liquid  chromatography (HPLC)  water  into  the  appropriate   sample
containers after the wells  were  sampled.    One set of sample  containers
was filled  with  HPLC  water  at Versar's laboratory,  brought to the site
and submitted for analyses  for each  parameter  as a trip  blank. The trip
blank was  shipped to the laboratory,  with  samples  collected  on August 7,
1986.  On August 5, a  Teflon bailer  was  rinsed  with  HPLC water and  the
water collected in the  appropriate containers  for  submittal  to the labo-
ratory as an equipment  blank.  This rinsing procedure was  conducted near
Versar's supply truck,  which was  parked near the landfill  office building.

Field measurments performed  on  site  included  temperature,  pH, specific
conductance, and turbidity.   All  thermometers  were calibrated  against  a
thermometer traceable to  the National Bureau  of  Standards  (NBS)   stan-
dardized instruments.   Daily calibrations  were performed on each  of  the
pH and conductance  meters to be used on  that day.   Calibration  checks
were performed prior  to each measurement  of  pH  and  conductivity.   The
turbidity samples from  each well were  saved and  all  the days' samples
were analyzed as  a  batch.   The  turbidity  meter  was  standardized  daily,
immediately prior to performing these  tests.

-------
                                   -22-
An added quality control  measure  was  the  inclusion  of  duplicate  sets.  At
Wells 40U and 40L,  two complete sets  (10% of all wells  sampled) of  samples
were collected.  These duplicate samples were  a  quality  control measure of
the sampling method.   This is  different than  the equipment  blank which is
used to assure that sampling was  cleaned  properly.

All sample-contacting equipment which was to be  used on site was  thorough-
ly cleaned, wrapped and sealed in plastic for transport  at  Versar's  labo-
ratory.  Sampling  equipment  (bailers) to  be used  at  the same  site, was
stored in the truck,  in plastic bags,  and under  custody seal.   No sampling
equipment was used at  more  than  one  site.  Used  or contaminated bailer
cable (Teflon  coated  stainless)  or  water level  indicator  tapes  were
cleaned by wiping with a  hexane  soaked tissue,   followed by wiping with  a
tissue soaked with  distilled water.

    d) Custody and  Sample Handling

All samples collected for  the U.S. EPA were  shipped to the contractor  labo-
ratories:  Compu-Chem (organics)  in Research Triangle Park, NC, and Centec
(inorganics) in  Salem,  VA,  in accordance  with applicable Department of
Transportation (DOT)  regulations  (49 CFR Parts   171-177).   Suspected con-
taminated samples were flagged as "medium-level  hazardous"  for laboratory
personnel.  All   ground-water  and surface  water samples were  considered
"environmental" samples.  Each sample shipment was accompanied by a Chain-
of-Custody Record  completed by  Versar personnel.   This form (Figure 2)
identified the  contents  of  the  shipment in  terms  of sample  type,  date,
and time, etc.  The original custody form accompanied  the  shipment.  Sam-
ples taken from the LRL site by U.S.  EPA  personnel  were documented with  a
Receipt for  Samples  forms completed by  Versar  Personnel.  The  originals
were retained by the EPA Field Team Leader.

-------
                                                                    FIGURE  S

                                                            CHAIN OF CUSTODY RECORD
PROJECT NO.
PROJECT NAME
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INOUSTniAI. Y
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-------
                                   -24-
Chain-of-Custody was lost on four sample sets shipped to the contract labo-
ratories on August 7, 1986.   Samples  affected were  from Well 221, 109U, a
field blank, and one of two samples collected  from Well 40L.  During pack-
ing of those samples, the Chain-of-Custody  forms were sealed into the wrong
shipping containers.  Other samples shipped on the same date for Wells 40U,
110U , and duplicate sample from Well 40L and the trip blank  were packed
properly and not affected.  After a discussion among the team members, the
following was done to correct the  problem.

   1.  The lab was  instructed to discard the sample  that  lost custody from
       Well 109U.  Since  the  duplicate  sample for Well 109U retained cus-
       tody, the data is  valid and summarized in  Appendix  B.

   2.  The  lab  was instructed to  discard  the  sample for Well 40L.   On
       August 8, this  well   was   repurged  and  resampled.  A  duplicate
       sample was  also  collected   to  meet the  Task  Force  QA/QC limits
       which require that  10% of all   samples   be taken  in   duplicate.

   3.  The  lab  was instructed to  discard  the  field  blank  collected on
       August 7,  near  Well   109U.   A  replacement  field   blank  was  then
       collected on August  8, near Well  40L.

   4.  Well 22L was not  resampled  and the  data reported in Appendix B, is
       for comparison purposes only.

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                                   -25-

    e) Scheduling

Many logistical  problems,  such as weather, equipment,  and well  performance
affected the time required to obtain the samples, and influenced the se-
quence of sampling.   The  Sampling Team Leader,  in  conjunction with the
Field Team  Leader,  prioritized  the sampling  points  and developed daily
schedules to minimize delays.  Some wells, due to slow recharge,  required
more than one visit to obtain  a  complete  set  of  samples.

Static water levels  were  taken  from 58  monitoring wells and  piezometers
on August 4 and  5,  1986,  for  use in the geological  evaluation.  Purging
and sampling activities were begun on August  4 and completed on August 8,
1986.

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                                   -26-

D.  WASTE MANAGEMENT UNITS  AND  OPERATIONS

    1.  INTRODUCTION

Land Reclamation,  LTD.  (LRL) is located in the south 1/2,  of  the Northeast
1/4, Section 32,  Township 4 North,  Range 22  East, Town of Mount Pleasant,
Racine County,  Wisconsin.   A portion,  in the  southwest corner, was leased
to the city of  Racine and utilized  as  a landfill for  residential, incine-
rator ash and foundry sand wastes  in  1963.   In August 1970, LRL assumed
operation of this  landfill  and expanded disposal  operation to  the east
side of the site.  LRL also  owns 140 acres directly  to the north of the 80
acre parcel evaluated by the Task Force.  The facility has applied to the
WDNR for expansion of the solid waste  operation  into  this area.

Records indicate  that solid and hazardous waste has  been disposed of in
Corridors 1-6 on the east side of  the site,  see Figure 3.   This area has
been defined by LRL  as  the Hazardous  Waste  Unit.   Municipal and Foundry
waste was placed  in the old city of Racine  landfill  on  the  west side of
the site.  In the area between  these two landfills  solid waste was placed
but the exact area is not well  defined.

In 1980, LRL began  the  process to  operate  under the requirements of the
RCRA program.  On August 19, 1980,  the facility submitted a  notification
of hazardous waste activity for its landfill  operation with  the U.S. EPA.
Then, on November 19, 1980, LRL filed a  Part A application  and thus ob-
tained interim status.  The Wisconsin DNR,  on December  10,   1982, denied
an interim  status  license  to  LRL  because  sufficient information had not
been provided.

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                                          27
                                      FIGURE  3
                      MAP    SHOWING   SHI   0 P. I U £ 11 9. H 1
            • i i
                                       • i-
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                              PROPOSED EXPANSION AREA
                                                                                  r
                                                           NORIHERN LIMIT OF OPERATION
S'lULK
PILE

OP CUVEH ;
SU1L .    ^
SWAMPY
AKEA
                                UNDEFINED FILL
OLD
CITY
OP RACINE
LANDFILL
            KEY
             	 Proposal  limit oT waste
     	 v 	 Property  Hue
          x       Northern  limit of operations (During Inspection)
     * Shows where base  of  Corridor 4  Is located, To complete Corridor 4 to ft  grade
       oT 79U feet,  fill  was  placed over Corridors 1, 2, and 3.
     Note:  Map not to scale.

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                                   -28-
Th e denial, issued  by  the  WDNR in December  1982,  required LRL to close
Corridors 1 through 4 by June 1983.  LRL had not filed a Part  B  applica-
tion nor a  certification  of compliance with ground-water monitoring and
financial responsibility requirements  by November  8,  1985.   Therefore,
LRL can  no  longer  accept  hazardous  waste.   The  closure  plan  for  the
facility submitted  by  LRL  on  November  23,  1985,   did  not  specifically
address the  closure of  the hazardous  waste  portion  of  the landfill.

    2.   WASTE MANAGEMENT UNITS

    a)  RCRA Units

Construction of the first phase of the southeast portion of  the site began
in 1970, with  the excavation of Corridor 1.   This  corridor is'approximate-
ly 200  feet wide  and 800 feet to  1000 feet long.  An accurate bottom eleva-
tion was not determined during construction,  and its depth can be estimated
to be 25 feet below grade based on  boring  information taken  during  the in-
stallation of the leachate  head  wells.

Construction of Corridor 2  began  in early 1971.  This  trench  is  approxi-
mately  200 feet wide and 800  feet to  1000  feet long.   As in  Corridor  1,
bottom  elevation was not determined.  The corridor is estimated to be  30
feet to 35 feet deep.

The size of  Corridor 3 is  not  well  documented.   This  corridor was con-
structed in 1975, between Corridors 1  and 2  by excavating until the side
walls of Corridors 1 and 2  collapsed.

Corridors 1, 2,  and 3 were constructed  before the  enactment  of  regulations
requiring recompacted clay  liners  and  leachate  collection systems.  These
corridors were therefore excavated into native clays and are  unlined.  And
as noted above, these units have not been closed.

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                                   -29-
Construction of Corridor 4 was  begun  in 1978.   This  corridor is approxi-
mately 200  feet wide  and  800  feet  to  1000  feet long.  Corridor 4  was
excavated to  a  greater depth than Corridors  1  -  3,  but due to  lack  of
documentation, the ultimate depth is  unknown.   A partial leachate collec-
tion system  was  installed  below grade  in  Corridor 4 only.  During  con-
struction, this corridor was completed to a surface elevation of 790  feet
above mean sea level or approximately 80 feet  above the  surrounding area.
To achieve this  elevation,  which is  40 feet higher  than the first three
corridors, Corridor 4 extended laterally across the  surface  of  the first
three corridors.  As in the other three  trenchs, Corridor 4 was construct-
ed in natural clay and is unlined.

Corridor 5 was the first  truly  "engineered"  trench  on the site.   This  con-
struction was completed in 1980, and  documentation of its design was  sub-
mitted to the WDNR in February 1981.   This  corridor  was  constructed  over
a  five foot thick  recompacted clay base with a leachate collection system.
The corridor  is  approximately  200  feet  wide,  800  feet  long  and 35 to 40
feet deep.

Corridor 6 was  also  a  designed system engineered  and constructed  over  a
five foot thick recompacted clay  liner, and covers an area of  approximate-
ly 4.6 acres.  Construction on this trench  began  in  1985,  and  was still
active at the  time of the inspection.   During  the construction  of  this
corridor, a leachate collection systems  were installed.   This Corridor is
connected hydraulically to Corridor 1-5  and is  an extension of  the hazar-
dous waste unit.

    b) Pre-Interim Status Solid Waste  Management

In 1963,  the city  of  Racine  began  operating a landfill   in the  southwest
corner of the site.  The  city disposed primarily  of municipal and foundry
wastes.   This landfill  is approximately  600 feet  to 700  feet  wide and 800

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                                   -30-

feet to 900 feet  long.   The  municipal  and foundry wastes were  generally
deposited on the  existing ground  surface with  little excavation.  The
base grades of the unit were  not  documented although  the elevation  of the
nearby wetland ranges  from 660 feet to  670  feet  above  mean sea  level.
The unit was  completed in 1970,  to an elevation  of  740 feet above mean
sea level (MSL) or approximately  60 feet  above  the surrounding area.  The
unit does  not  contain  a leachate  collection system  and  was constructed
over natural soils.

Solid waste was also  disposed of in the area between the old city  of  Racine
Landfill and Corridors  1-4.   No  documentation giving  the units size, or
base grade  exists, nor was a  leachate collection system installed.   A num-
ber of borings have  shown that the majority  of waste buried  in  this area
was from the foundry  industry.

    c) Waste Characterization

        0 Introduction

Hazardous waste was disposed of at the LRL site  from the early 1970s until
December 1982.   During  the period  that  LRL  operated under  RCRA Interim
Status, November  1980 to December  1982, hazardous  waste was placed  in the
landfill.  Table   2 shows  the types of waste disposed  of during Interim
Status.

        0 Discussion

      - At the time LRL operated under RCRA Interim Status limited waste
        characterization was  performed on incoming  wastes  (LRL's  Waste
        Analysis  Plan  required that 10%  of liquid wastes received  at the
        facility  undergo finger print analysis).

        Analytical records of these incoming waste characterizations could
        not be produced by LRL.

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                                   -31-

                             I AikI  "L


                    HAZARDOUS WASTE ACCEPTED  BY  LRL  *


EPA I.D.  NUMBER         DESCRIPTION


D001                     Characteristic of ignitability.

D003                     Characteristic of reactivity.

0007                     Characteristic of EP  Toxicity,  Chromium.

D008                     Characteristic of EP  Toxicity,  Lead.

FOOT                     Spent halogenated solvents and  sludges  from
                        degreasing operations and still  bottoms.

F002                     Spent halogenated solvents and  still  bottoms.

F005                     Spent non-halogenated solvents  and still  bottoms.

F006                     Wastewater treatment  sludges from electroplating
                        operations.

F007                     Spent cyanide plating bath solutions  from elec-
                        plating operations.

F008                    Plating bath residues from the  bottom of  plating
                        baths from electoplating operations where cya-
                        nides are used.

F009                     Spent stripping and cleaning solutions  from elec-
                        troplating operations where  cyanides  are  used  in
                        the process.

K001                     Bottom  sediment sludge from  the treatment of waste-
                        water from wood preserving processes  using creo-
                        sote and/or pentachlorophenol.


* Table compiled from manifest, scale house records, and waste  characteri-
  zation records supplied by LRL.

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                                   -32-

                             TABLE 2 (Cont'd)
EPA I.D. NUMBER         DESCRIPTION
P030                    Discarded commercial  chemical  products, off-speci-
                        fication species,  container residues and spill  re-
                        sidues.  P030 listing  is for cyanide (soluble
                        cyanide  salts),  not elsewhere  listed.

U080                    Discarded commercial  chemical  products, off-speci-
                        fication species,  container residues and spill  re-
                        sidues containing  dichloromethane,  (methylene
                        chloride).

U151                    Discarded commercial  chemical  products, off-speci-
                        fication species,  container residues and spill  re-
                        sidues containing  mercury.

U188                    Discarded commercial  chemical  products, off-speci-
                        fication species,  container residues and spill  re-
                        sidues containing  phenol.

U210                    Discarded commercial  chemical  products, off-speci-
                        fication species,  container residues and spill  re-
                        sidues containing  tetrachloroethylene.

U227                    Discarded commercial  chemical  products, off-speci-
                        fication species,  container residues and spill  re-
                        sidues containing  1,1,2-trichloroethane.

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                                   -33-
    - LRL record  keeping during interim  status  was  not adequate to provide
      information on quantities and location of the  hazardous waste accept-
      ed at the  facility.  Task Force comparisons of manifest,  scale  house
      records and waste characterization  records  showed  some discrepancies
      in both quantities and  discrepancies  on waste accepted at  the  faci-
      lity.

    - LRL claims  of total  waste accepted  can not  be substantiated by  their
      records.

    d) Site Operation

       0 Waste Disposal

Hazardous waste was disposed  of in Corridors  3, 4,  and 5.   These  corridors
overlay Corridors 1 and 2,  and are connected hydraulical ly to  Corridor  6.
Hazardous waste  may  have  been disposed  of  in  Corridors  1 and 2  also.
Therefore, all 6  corridors are considered  to  be  one RCRA  hazardous  waste
unit.

Hazardous waste was  disposed  along with municipal  solid waste.   Some  haz-
ardous wastes were disposed of by  digging a trench  in  the  refuse  and  plac-
ing the hazardous waste in the trench.   The  trench was  periodically covered
with refuse  or  clay.   Other  hazardous  wastes  were mixed with  municipal
solid waste  in  the active  area  and then covered with  nonhazardous  solid
waste or clay.  Neither the trench  disposed  waste  nor the co-disposed  waste
were always covered on a daily basis  as required by  the WDNR.

        0 Leachate Handling/Gas Collection

Recent corridors  (5 and 6)  of the  LRL landfill are designed  for  operation
as a  zone-of-saturation  landfill.    Corridors  1  -  4  were  not originally
designed to meet  the zone-of-saturation  conditions.  LRL  is  required  to
monitor and pump  leachate that collects  in  the  landfill, to produce an in-
ward flow gradient for the  ground-water.

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                                   -34-
Leachate collection and removal systems were installed at the base of Cor-
ridors 5 and 6 before  waste  was placed in  those  corridors.  Corridor 4
also contains a partial leachate  collection and removal  system which was
added after filling had begun.   The  location, with  respect to the  base of
Corridor 4, is  not well documented.   A leachate  dewatering  trench  has been
installed on the west  side of  Corridors 1  - 4, and the  west, north, and
east perimeters of the  city  of Racine solid  waste unit.    Certification
documents as to the construction  of  these trenches  had not been submitted
by LRL at the time of the inspection.  In addition to  the leachate  collec-
tion and removal  systems, LRL has installed a  number of wells to  monitor
leachate levels.   Several of  these  leachate monitoring  wells located in
Corridors 1, 2, and  3  also  contain  pumping equipment for the removal of
leachate.  The leachate  removed from  both  collection  systems  and  the
leachate monitoring  wells  is  pumped  to  the  city  of  Racine wastewater
treatment plant.   Current information  indicates leachate heads as  high as
750 feet above mean  sea  level,  about  50  feet  above  adjacent undisturbed
grade.  This  indicates  a likely  outward  gradient at  the  time  of  the
inspection.  LRL   has  not provided  the  WDNR  with  records  on  leachate
pumping.  At time of the inspection, LRL  was installing a gas extraction
system without approval  from  the  WDNR or  U.S.  EPA.   This  system is de-
signed to extract and collect  gases generated from the landfill.   This gas
will be sold to a local industry for energy.

The LRL  site has been  licensed  by the  WDNR for the disposal  of municipal
solid waste and to be operated as a  zone  of saturation site, requiring an
inward gradient induced by leachate  collection.  The contours on  Figures
3, 4  and 5  in the  Site Geology  and  Hydrogeology  Section  show little  evi-
dence of any  inward gradient.   It  is important for LRL  to maintain an
inward gradient  since  wells  along  the south edge  of the site show  that
the disposed landfill waste  intersects both the water table  and the upper
sand seam.   Gas  bubbling  up  in puddles after a rain event, was  noted by
the sampling crew during the inspection along the south  side of the site.
In addition, gas bubbles were noted  in Well SOT when  water level  measure-
ments were taken on August 4, 1986,  by the  Task Force.

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                                   -35-
To assure that the facility is operated as a zone of saturation  site, LRL
needs to pump  leachate  to  reduce head levels and,  at least  annually,  an
evaluation of  ground-water  flow must  be  conducted.   The  facility,  in the
past, has failed  to  submit to the WDNR the  required  annual  ground-water
evaluation.

    0 Surface Water Control and Discharge

Surface water  is  discharged  from  two  locations  at LRL,  a pond  discharge,
and the drainage  way  discharge.   These discharges  are  regulated under  a
Wisconsin Pollution Discharge  Elimination  System  (WPDES)  Permit  Number
WI-0045420-1.  LRL is required to monitor these points  once per week  for
total suspended solids  (TSS),  five day  biochemical  oxygen  demand  (6005),
pH, and chemical  oxygen demand  (COD).   Once per quarter  LRL  must  also
monitor these  discharges   for  arsenic,   copper,  cadmium,  lead,  nickel,
zinc, specific  conductivity,  chloride,   temperature,   ammonia-nitrogen,
nitrate-nitrogen,  and total  Kjeldahl-nitrogen  (TKN).   LRL has  exceeded
the limits of their WPDES permit  a number of times.

Leachate seeps occurring along the site perimeter (particularly the south
slope) have  historically been  released  off-site  with no  collection or
treatment.   At the time  of  the inspection, LRL was initiating  construction
of a sedimentation basin in  the  southwest  corner of the site to contain
site run-off.

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                                   -36-

    0 Discussion

During the inspection, the Task Force noted a number of problems  associated
with the site operation.   These concerns  are  listed  below:

    0 Ground-water contours (see next section) and data submitted  by  LRL
      indicates that LRL  is  not  operating  this  facility  as  an  inward
      gradient, zone-of-saturation  site as required by the WDNR.   Leachate
      heads have  not  been  maintained at  a  level  to induce  ground-water
      into the landfill.   Information indicates  that  leachate head  levels
      are over 50  feet  above  the  water  table adjacent to the  facility
      which would produce an  outward gradient.

    0 The closure plan submitted does not address  the erosion problems  on
      the south  and  east  slopes,   the  construction  of a  cut-off wall
      through Unit 2, the upper sand seam, the problem with methane seeps
      along the  south slope,  future surface  maintenance,  ground-water
      monitoring, the  physical   hydraulic  barrier,  and  the  RCRA cap.

    0 LRL  began  removing material   adjacent  to  the  south  slope without
      authorization from  the  WDNR.

E.  SITE GEOLOGY AND HYDROGEOLOGY

    1.  INTRODUCTION

The LRL landfill is located in  a  glaciated area of gently undulating topo-
graphy formed by low, irregular end moraines  with  slight modification  due
to post-glacial  erosion.   The  regional  land  surface gradient, which  is
controlled by an  uneven  bedrock  surface, slopes  to  the east at 10 feet
per mile.  The land  surface  elevations  range  from 680 feet  above  MSL  at
the Pike River (1/2 mile west  of the site) to 480 feet above MSL at Lake
Michigan.  Modifications  to  the local  topography,   near  the  site, have
occurred due to  sand and  gravel  operations  and  the  landfill  operations
which have created a local  topographic high.

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                                   -37-
Regional  surface water drainage is toward Lake Michigan.   Locally,  surface
water is drained from the site to a wetland adjacent to the west  side  of
the landfill.   This wetland drains  to  the  Pike River, which drains  into
Lake Michigan.

    2.  HYDROGEOLOGIC UNITS

The upper most formation of the  active  portion of  the  site  (eastern side)
is the Oak  Creek Formation of Quaternary age.  It  was deposited on the
west facing slope of the Inner Lake Border moraine, and consists  of  flu-
vial and lacustrine  sediments deposited  proglacially  during  retreats  of
the ice margin.  The  far  western portion of  the  site is underlain by a
proglacial  outwash  or lacustrine  plain.

The Oak Creek  Formation is  110 to 150 feet thick and dips slightly to the
west.   LRL's  geologists  have  identified  seven units  in the  Oak Creek
Formation,  and LRL  has  installed monitoring  wells  in  three  of these
units.  The sands  of  the  Oak Creek Formation  form  local, low-yielding
aquifers.   The units and well series are identified  as follows in order
of increasing  depth:

   1)  The surface  unit,  designated Unit 1,  is a  clay  till  that slowly
      pinches  out as it dips  to  the west.   The unit varies in thickness
      from  4 feet to 42  feet.  LRL  has  installed  wells  in this unit and
      they  are identified as water table  (T series) wells.

   2)  Unit   2  consists  of  fluvial and lacustrine  sands and  silts,  and
      ranges in thickness  from  6  feet  to 27 feet.  LRL  has  installed
      monitoring  wells   in  this  unit and has  identified  them as  the  U
      (upper most aquifer)  wells.

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                                   -38-

   3) Unit 3 is composed of till  and  lacustrine  clay.

   4) Unit 4 is  similar to Unit 2 above and  consists  of sand and silt.
      LRL has installed monitoring wells in  this  unit  which are identi-
      fied as the L  series  (lower aquifer) wells.  This  unit thins  out
      to the east.

   5) Unit 5 is  present  only  under the eastern portion  of  the site and
      consists  of silt  and  clay.  The  unit  ranges in  thickness  from 0
      feet to 17.5  feet.

   6) Unit 6 is  composed  of sands and  silts.   Although found under the
    .  entire site,  this unit at times is difficult to delineate from the
      lower underlying clay, sand,  and silt.

   7) The lowest unit, Unit 7,  is  a  gray clay  with silt and sand seams.

Underlying the  Oak  Creek Formation is the Niagaran  Aquifer.  The Niagaran
is a fossil-reef dolomite  which  forms  the  principal shallow  aquifer in
the area.  This dolomite ranges from 110 feet  to 150 feet below  the ground
surface.  The underlying Maquoketa Shale separates the  Niagaran dolomite
from a  series  of Cambrian  and  Ordovician  sandstones and dolomites which
are pumped extensively for municipal  water  supplies.  All bedrock forma-
tions dip eastward  at about  15  feet per  mile.

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                                   -39-

    3.  HYDRAULIC CONDUCTIVITES  AND GROUND-WATER  FLOW

Ground-water flow in the Oak Creek Formation varies from westerly  to south-
erly.  Ground-water levels  in  the T series of wells indicate flow is west-
ward (see Figure 3) towards the  Pike River, located 500 to  1200  feet west
of the site.  The U series of wells  indicate ground-water flow is  primarily
to the west with a component  of  flow to  the  north  (see Figure 4).  The L
series of wells indicates flow is to the south from a ground-water mound
located in the  northeast corner  of  the site  (see Figure 5).  Water level
measurements taken by  the Task Force on August 4  and 5,  1986, were used to
construct Figures 4,  5,  and 6.  Some variation in ground-water flow direc-
tion may  be attributed  to  excavation,  filling,  and leachate collection.
Horizontal gradients  calculated  from the  data used  in Figures 4, 5, and 6
are 0.019 feet  per foot  for the  Unit 1 water  table  or T wells, 0.023 feet
per foot  for Unit  2  or  U  wells  and 0.012 feet  per foot  for Unit 4 or L
we11s.

The data used to construct Figures 4, 5, and 6, indicates definite downward
gradients.  The saturated thickness of Unit  3 layer  over the upper sand
seam is about 20 feet.  Head differences  between  the T and  U-series wells
indicate the vertical  gradient is about 0.4 ft./ft.  The thickness of the
layer between  the  upper and lower  sand  seams  is  about  10  feet.   Head
difference between the upper and lower sand  seams indicates the vertical
gradient is about 1.7 ft./ft.

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               -40  -
              FIGURE 4
POTENTIOMETRIC  CONTOUR IN THE WATER TABLE
   T  Senes  Wells  8/86
          KEY
  £7  - WELL LOCATION
   14U  - WELL NAME            	
   664  - GROUND-WATER ELEVATION  (FT. ABOVE MSL)

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               -41 -
              FIGURE 5
POTENTIOMETRIC CONTOUR OF THE UPPER SAND
    U  Series  Wells  8/86
             K I Y
   H -  WELL LOCATION
   14U -  WELL NAME
   669 -  GROUND-WATER ELEVATION (FT. ABOVE MSL)

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                 - 42 -
              FIGURE 6   .
POTENTIOMETRIC CONTOUR IN THE  LOWER SAND
  L  Series Wells  8/86
          K E I
 H  -   WELL LOCATION
 18L  -   WELL NAME
 663  -   GROUND WATER ELEVATION (FT. ABOVE MSL)

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                                   -43-
The laboratory  permeabilities  of  the Oak Creek Formation soil units range
from 10~4 cm/sec  to 10~8  cm/sec.   This information,  compiled  by LRL's
geologists,  is  summarized in Table  3.

Ground-water flow  in the Silurian age  domomites is primarily to the east.

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                                      -44-

                                   TABLE    3
                      LABORATORY  PERMEABILITY  OF  THE  OAK CREEK
SOIL UNITS BENEATH LRL LANDFILL *

UNIT
NO.
1
1
2
2
2
2
2
2
2
2
2
2

BORING
NO.
5-48
14-3A
5B
75B
76-9
80-8
81 D
82-9
84
87S
87D
90

PERMEABILITY
(cm/sec)
5X10-8
2X10-8
1X10-6
1.8X10-6
5.8X10-6
3.6X10-4
2.0X10-4
2.2X10-4
7.1X10-6
3.7X10-5
2.1X10-5
6.1X10-5

UNIT
NO.
2
2
2
2
2
2
3
3
4
6
7


BORING
NO.
92S
95D
105
98
101
103
10-5
17-12
14-6B
14C
5C


PERMEABILITY
(en/sec)
1.5X10-5
3.0X10-5
3.2X10-5
1.5X10-5
1.1X10-4
1.1X10-5
3X10-8
5X10-8
2X10-5
1X10-5
6X10-5

*  Source :   Foth  & Van Dyke  and  Associates,  Inc.,  (1987), Closure and Long Term
             Care  Plan for Land Reclamation,  Ltd. Landfill.

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                                   -45-

F.  GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS

    1.  REGULATORY REQUIREMENTS

LRL is  required  to  monitor  ground-water under  the Section  NR  181.49
(Ground-Water and  leachate  monitoring),  Wis.  Adm.  Code,  (40  CFR  Part
265, Subpart F)  for interim  status facilities.   In  addition,  LRL  must
also monitor ground-water to  meet  requirements  of Section  NR 181.44(12)
(Closure of  Facilities  Without  Operating Licenses),  40 CFR  Part  265,
Subpart G, and  Wisconsin  DNR's  regulations  for the  operation  of  solid
waste landfills  in Chapter NR 140 and NR 180,  Wis.  Adm.  Code.

    2.  GROUND-WATER MONITORING SYSTEM

    a) Monitoring Well  History

During September-and October 1975,  LRL installed 18 ground-water monitor-
ing wells.  These  wells and  eight  additional  soil  borings  were taken  as
part of a  feasibility  study  for the future operation of  the  site.   Pre-
sently, only two  of the wells  (6T  and 8T)  remain  in  use as  part  of  LRL's
state solid  waste monitoring  system.  Installation dates and other well
construction data are summarized in Table 4.

In 1976, six additional  ground-water monitoring  wells were installed, two
in March and four  in  August.   Of these six wells, only  three  (10U, 11U,
and 9U) remained  in  use  at the time of the inspection.   All three  wells
are screened in the  upper  sand seam that  LRL has designated with  a "U"
for upper most aquifer.   Well 10U is part of  LRL's RCRA  monitoring system
and is considered  by LRL as  being  downgradient.  The  remaining  two  wells
are part of the state solid waste network.

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                                           TABLE
      CONSTRUCTION   DATA   FOR   LRL's    MONITORING   W E L L S  (a)
ill
).
3T
3U
4U
4L
5T
5U
5L
6T*
6U
6L
7T*
8T*
9U
IOU*
IOL
nu*
I4T
I4U
I4L
I7T
I7U
I7L
1ST
I8U
I8L
I9T
I9U
?2U
?2M
121
DATE
COMPLETED
9/30/82
11/13/80
5/31/85
5/30/85
11/13/80
11/10/80
11/12/80
10/03/75
5/23/85
5/13/85
5/24/85
10/08/75
8/16/76
8/10/76
11/04/80
8/10/76
11/10/80
11/10/80
11/05/80
11/17/80
11/17/80
11/17/80
11/10/80
11/10/80
11/10/80
11/05/80
11/05/80
7/18/84
9/30/82
o/o.n/g9
ELEVATIONS (IN FEET ABOVE MEAN SEA LEVEL (MSL))
TOP OF
PIPE
708.90
708.72
676.76
675.45
709.86
709.92
709.83
724.28
725.51
725.71
722.04
680.11
673.80
681.11
677.55
676.08
688.37
688.40
688.85
729.01
729.51
729.16
697.71
697.75
697.18
727.41
726.44
669.44
671.15
670.56
GROUND
SURFACE
706.84
705.59
672.93
672.75
706.60
706.74
706.73
723.54
723.12
723.86
720.04
677.88
672.20
677.27
675.96
672.42
685.08
685.19
685.49
727.30
727.51
727.40
695.83
695.85
695.80
725.19
725.11
667.28
667.28
£G7 01

TOP OF
SCREEN
697.84
676.59
667.76
635.45
704.60
667.74
626.73
698.54
692.51
638.71
715.04
654.88
668.20
670.77
635.96
667.42
683.08
657.19
631.49
725.30
684.51
627.40
693.83
675.85
620.80
717.19
706.11
659.28
648.28
GOQ 00

BOTTOM OF
SCREEN
687.84
670.59
657.76
630.45
694.60
662.74
621.73
695.04
682.51
634.21
705.04
649.88
658.20
660.27
630.96
657.42
673.08
652.19
626.49
715.30
679.51
622.40.
683.83
670.85
615.80
712.19
700.11
654.28
643.28
COO 00

TOP OF
SAND PACK
698.84
677.59
668.93
637.75
705.60
668.74
628.23
721.04
696.12
641.03
717.04


672.77
636.96

684.08
658.19
632.49

685.51
629.40
694.83
676.85
622.80
719.19
706.11
660.28
649.28
con oo

BOTTOM OF
SAND PACK
687.84
669.59
657.93
617.75
693.60
661.74
620.23
695.04
683.12
633.86
705.04
649.88
668.20
660.27
629.96
657.42
672.08
650.19
625.49
714.30
676.51
621.40
682.83
669.85
614.80
711.19
699.61
653.28
642.28
COO 00

CASING
DIAMETER/
MATERIAL
2.0 PVC
1.0 PVC
2.0 PVC
2.0 PVC
1.0 PVC
1.0 PVC
1.0 PVC
1.25 STEEL
2.0 PVC
2.0 PVC
2.0 PVC
1.25 STEEL
2.0 PVC
2.0 PVC
1.0 PVC
2.0 PVC
1.0 PVC
1.0 PVC
1.0 PVC
1.0 PVC
1.0 PVC
1.0 PVC
1.0 PVC
1.0 PVC
1.0 PVC
1.0 PVC
1.0 PVC
2.0 PVC
2.0 PVC
o r\ r\\ir\
L. .u r vv_.
(a)   -  Information  taken  from well  logs contained in LRL's Sampling and Analysis Plan (SAP)
(*)   -  Well  log not included in  SAP.   Information obtained from other sources supplied by  LRL.

-------
                                               -t/-
                                      I A 1 11   1  (Cont'd)



      CONSTRUCTION   DATA   FOR   LRL's   MONITORING    WELLS  (a)
ELL
).
?9T
?9U*
191
JOT
JOU
30L
39U
101)
iOL
16T
16U
J6L
m
17U
*7L
»8U
18L
J9U
»9L
58T
58U
58L
50T
D8L
39T
39U
39L
10U
DATE
COMPLETED
9/30/82
11/21/83
11/23/83
9/30/82
2/03/84
12/02/83
6/01/84
6/04/85
6/04/85
5/30/85
5/29/85
5/29/85
5/24/85
5/24/85
5/23/85
5/07/85
5/07/85
6/04/85
6/03/85
4/25/85
5/30/85
5/29/85
5/01/85
6/05/85
6/03/85
5/27/85
5/31/85
6/01/85
ELEVATIONS (IN FEET ABOVE MEAN SEA LEVEL (MSL))
TOP OF
PIPE
719.91
719.83
719.80
702.28
702.04
701.99
700.81
673.02
673.41
679.54
678.56
678.58
682.19
682.04
681.77
705.80
705.61
718.99
718.93
675.56
674.89
673.82
692.87
722.18
683.43
681.76
681.49
700.81
GROUND
SURFACE
716.41
716.36
716.11
699.70
699.65
699.53
685.98
670.72
670.81
676.04
676.47
676.61
680.33
680.11
679.84
703.38
703.24
717.22
717.03
672.35
671.89
671.89
690.47
720.53
679.34
679.59
679.51
697.44
TOP OF
SCREEN
701.41
680.86
627.86
693.70
660.95
633.13
675.23
664.02
608.81
671.04
636.06
612.08
672.69
636.54
616.27
673.90
630.71
672.49
629.43
666.46
631.89
606.82
677.87
639.18
674.43
660.26
623.99
679.44
BOTTOM OF
SCREEN
691.41
671.61
622.86
683.70
651.75
628.43
665.98
659.02
603.81
666.54
631.56
607.58
668.19
632.04
611.77
664.70
626.11
667.99
624.93
657.36
626.89
601.82
673.37
630.18
664.43
655.76
619.49
669.44
TOP OF
SAND PACK
702.41
682.76
629.01
694.70
662.95
634.13

664.72
611.81
672.53
638.47
616.11
674.33
639.61
618.84
677.88
633.34
676.72
634.03
669.35
632.89
612.89
680.47
644.53
676.34
662.59
726.51
680.44
BOTTOM OF
SAND PACK
691.41
670.76
619.61
683.20
651.65
628.23
665.73
658.72
602.81
664.53
630.47
601.61
667.33
631.11
604.84
664.38
613.24
668.22
622.03
657.35
623.89
602.89
673.47
629.53
664.34
654.59
614.51
667.44
CASING
DIAMETER/
MATERIAL
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
2.0 PVC
(a)   -  Information  taken  from well  logs contained in LRL's Sampling and Analysis Plan (SAP).



(*)   -  Well  log  not included  in  SAP.   Information obtained from other sources supplied by LRL.

-------
                              -48-
During November  1980,  16  additional  monitoring  wells  were installed.
Five wells were screened at the water table  (5T,  14T,  17T,  1ST,  and
19T); six were  screened  in the upper sand  seam  (3U,  5U,  14U,  171),
18U, and 19U);  and  five  in a  lower  sand seam designated by  LRL  as
the "L" zone  (5L, 10L, 14L, 17L, and 18L).  Presently,  these sixteen
wells are included  in  LRL's  State  solid waste monitoring  systems.

In 1980, LRL also began the practice of  installing nested wells.   As
illustrated in Figure 7, wells were installed near each other (i.e.,
5T, 5U,  and  5L)  and  screened in  different  water  bearing  units.

Five wells were  installed in September 1982.   Three wells were screen-
ed in the  shallow  water  table (3T,  29T, and SOT), one in.the lower
sand seam  (22L)  and one in  a  unit  between  the  U and L  sand seams
(22M).  This latter well (22M)  is included  in  LRL's  RCRA monitoring
system as a downgradient  well.

In late 1983 and early  1984, LRL installed four  additional wells (29U,-
29L, SOU, and SOL).   These  wells were installed as two  sets of nested
wells with  one  well in each set being screened in the upper sand and
the other in the lower sand.   Three  of  the wells (29U,  SOL,  and SOU)
are part  of  LRL's  solid  waste  monitoring   system  are downgradient
well s.

Later in 1984,  (June,  July),  two additional wells were installed (39U,
and 22U).   Both wells were  screened  in the upper zone and are part of
the State solid waste monitoring system.

Finally, from April through June  1985,  LRL  installed 26 wells.  Six
were  screened in the water table (7T, 46T, 47T, 58T, 60T, and 109T);
ten in  the  upper sand (4U,  6U, 40U, 46U,  47U, 48U,  49U, 58U, 109U,
and  110U);  and ten  in the lower sand (4L, 6L,  40L,  46L,  47L,  48L, 49L,
58L,  108L,  and  109L).  Wells  6U  and 108L have  been designated as up-
gradient  and  Well   11OU  as downgradient  RCRA  wells.  The  remaining
wells  are part  of LRL's solid waste  monitoring  system.

-------
                                          49
                                    H G U iil  1
                          RCRA MONITORING  WELL. LOCATION MAP
                                          eo r •
                                      EXPANSION AREA
             , 10U*
             • 10L
 .  f	r-.
                                UNDEFINED FILL
                OLD CITY OF
                RACINE LANDFILL
i IU
   log r
                 * WELLS UES1GNAIEU BY LRL AS RCRA MONITORING WELLS
                ** Wplls 191) and  191" are actually BOO feet east of the eastern boundry.
                  Mils would place Wells off of the map.

               Note:  Not  to scale.

-------
                                   -50-

    b) Monitoring Well  Location

LRL's RCRA ground-water monitoring system consists of  six wells as shown
i n Figure 8.

Upon review of earlier  work  performed  by  LRL's  contractors, the WDNR, the
U.S. EPA, Region V, and  its  own  geological  review of the site, the Task
Force has determined that the present  RCRA ground-water monitoring system
is inadequate to immediately detect a release  of hazardous waste and/or
hazardous waste constituents to the ground-water.  This determination is
based on information summarized below:

    1) The six  wells  in  the RCRA  system are  not sufficient.   A greater
       number of monitoring  points is  required to  provide  for  a  more
       representative  sampling of  potential  contaminant pathways.

    2) The site hydrogeology is complex.  Three  dimensional ground-water
       flow through layered heterogenous  glacial deposits makes determina-
       tion and monitoring of potential contaminant flow paths difficult.

    3) The long period  of landfilling  in the site area since 1963, along
       with the progressive   series of landfill  excavations  and surface
       water diversions,  have created  an area  of  shifting ground-water
       potentials and  flow paths  as well  as multiple areas for influx of
       ground-water contaminants.

    4) All three geologic units presently monitored  by  LRL for the WDNR
       solid waste  program could  be impacted by  a  release from the haz-
       ardous waste unit.  This can be seen  in  wells  along the south side
       of Corridor  1,   where  methane gas has  been detected.   During the
       construction of  Corridors  1  through  5,  the  water table and upper
       sand seam were  removed from  the fill  area.  Therefore, these units
       could be  connected to the  landfill  since Corridors 1  through 4
       were not constructed  using  a recompacted clay  liner.  In addition,
       the water table  and the upper sand seam  are upper most water bear-
       ing zones relative to the  sides of the hazardous waste unit.  The
       lower sand  seam,  however,  is the upper most water  bearing unit
       with respect to  the base of  the hazardous  waste unit.

-------
                                            51

                                   £1QURi   8
                             MUU11UIUHG HELL LOCATION MAP
£2M
                              rUIUHE  EXPANSION AREA
UNDEFINED FILL
              r~
             OLD CITY UP
             RACINE LANDFILL
                                                                                       108L»
              * WELLS DESIGNATED BY  LRL  AS  RCRA MONITORING WELLS
             ** Wells 191) and 19T are  actually BOO feet east of the eastern boundry.
                'this would place Wells off  of the map.
            NOTE I Map not  to  »c*l«.

-------
                                   -52-

    5) In the present RCRA system,  there are only  three  wells  (SOL,  108L,
       and 110U)  along  the  south  edge of  Corridor 1.   All  present  or
       future replacement  wells  along  this  side,  from Well  19U  to the
       series 18 wells,  need to  be included  in the  RCRA  system.  This  is
       needed to detect any releases  from  the side  of fill  into the  water
       table or the upper  sand seam.   Also,  as  can be  seen in Figure  6,
       the piezometric surface of  the  lower sand  seam,  flow is directly
       south in this lower unit.

    6) Only two wells (22M and 10U) along the west  side of the site area
       are included in the RCRA monitoring system.

    7) The two wells that  LRL has designated as upgradient (61) and  108L)
       may be improperly  classified.   The facility's own  data does not
       support LRL's  claim that  6U  and  108L  are acceptable  upgradient
       wells.  Past sampling results  for 6U  have indicated  contaminatfon.
       Figure 6, the ground-water flow contour map  in the lower sand  seam,
       indicates that Well  108L  may  actually be  downgradient.   Well  6T
       also appears, to  be downgradient and  is  possibly contaminated  as
       evidenced by  WDNR  data  showing chloride  concentrations  ranging
       from 9 to 74 mg/1.

It should be noted  that the data shown in Figures 4,  5,  and 6, in the pre-
vious section, illustrating  ground-water  flow directions  in  each  of the
three monitored zones, indicates  that the  flow patterns  are different for
each zone.   Therefore, wells in  a  nest may not  have the same gradient
designation.  For example, of the  three wells  in  the  5  series, Wells  5T
and 5U are downgradient and 5L  is upgradient  of the  hazardous waste  unit.

-------
                                   -53-

    c)  Background Ground-Water Quality

Many uncertainties exist in the determination of background  ground-water
quality at the site.  The  background ground-water  at the site cannot  be
determined only through  examination of existing up  or  downgradient moni-
toring well  locations.  The water  quality  of  each  well must be  compared
to both  the  expected regional  water   quality  data,  landfill  leachate
characteristics,  and possible  contaminant sources other  than the landfill.
An additional  upgradient well  nest (water  table,  upper and  lower units)
is necessary to provide more  complete  determination of background water
quality.

    d)  Monitoring Well Construction

The ground-water monitoring wells at LRL were installed  at  eight different
time periods between 1976 and 1985.  It is difficult to determine  from LRL's
records if well construction  techniques  remained the same  over  these time
periods.  The well  logs included in LRL's Sampling and Analysis  Plan (SAP)
are incomplete with discrepancies in well  details.  Many of the logs do  not
include slot size of the screen, type of sand placed around the screen,  nor
the elevation for either the  top of pipe or ground surface. Also, none of
the logs include  the type of drilling methods used to bore  the hole nor is
a description given of the type  of development  (i.e., pumping  or bailing
a given number of well volumes)  used to clean out the well  after construc-
tion.

Information from the  well  logs shows that,  after  the  hole  was  drilled,
slotted schedule  40 or   schedule  80 polyvinyl  chloride  (PVC) pipe   was
placed in the hole.  Sand  or pea gravel was then placed around and above
the screen section  of pipe.  Above the sand pack, a  bentonite  grout seal
was added.  Near the  surface,  concrete  was added  and a steel  protective
casing was placed around the  upper portion of the well.   A typical moni-
toring well  is shown in  Figure 9.

-------
                    54
                FIGURE  9
    T
    24"
 PROJECTION
    5-0"
6" STEEL CASING
IN POURED CONC.
BENTONITE
  GROUT
    15'
SILICA SAND
                  Z +
                  '•?!
                  '?T

                  ii.
                  T**
                  &
                  *i'
                  *•«
                  »/
                  •T"
                  «^
r
           HINGED COVER

           HASP 8 KEY LOCK

           2"VENTED CAP(PVC)

                      GROUND SURFACE
  #*
  "•*rs-
  m
  -"•£•'•'
  *».*,' •"'
  ST-'O*'

  fi
  &??'
           6" STEEL CASING

           POURED CLASS "B"
           CONCRETE (5 BAG MIX)
           2" DIA. THREADED FLUSH JOINT
           NONSTENCILED SCH. 4O OR 80  PVC
           PIPE
                               6 MINIMUM
                               HOLE DIAMETER
                          -J-
                               10' SLOTTED  SCH 40  OR  80
                               PVC  SCREEN  (10-SLOT)
                               2" THREADED  CAP (PVC)
        TYPICAL MONITORING WELL

-------
                                   -55-

    3.  SAMPLING AND ANALYSIS

    a) LRL's Sample Collection,  Handling,  Preservation  and  Field Measurements

This section will  include  a  review of  LRL's  Sampling and Analyses Plan
(SAP) and observation  made  by the  Task Force of  LRL's  sample handling
procedures.   The review of the SAP  comments applies to the plan present-
ed to the Task Force during the inspection conducted from  August 4 to 8,
1986.  The observation  of LRL's sampling techniques were made on September
23, 1986, during LRL's  quarterly  sampling  event.

A number of deficiencies were noted in  LRL's  Sampling  and  Analyses Plan.
These deficiencies  are  summarized  below:

    0 In a  number  of locations  in the SAP,  LRL mentions using deionized
      water.  Water that has  been only distilled and deionized would not
      be of  sufficient  quality for  equipment  cleaning or  preparation of
      blanks for Volatile Organic  Analysis  (VOA),  Total  Organic Halides
      (TOX), or acid,  base/neutral  organics.   LRL  needs  to  use  a high
      quality water when sampling  for  these parameters.   Also, the purity
      of the water  used needs  to  be documented in the SAP.

    0 The SAP does  not  specify when, where, or how long  after collection
      that the dissolved  metals  samples  are  filtered.    The  filtering
      needs  to be completed as  soon  as possible after sampling.  Oxygena-
      tion and changes  in sample  temperature  (which effects pH) prior to
      laboratory  filtering  may cause  the  precipitation  of some  of  the
      metals,  thus  biasing the  sampling  results.

    0 The SAP  does  not  give the cleaning procedure used to  clean the fil-
      tering equipment  between samples.  This  equipment,  used  to  filter
      dissolved metals  samples,  needs to  be   rinsed with  a good quality
      water  as-well-as  a rinse with nitric  acid.  For further information,

-------
                               -56-
  LRL is referred to references  A  and C of their SAP.  The first refer-
  ence is Standard Methods  for the Examination of Water and Wastewater,
  and the second  is Methods  for Chemical Analysis of Water and Wastes,
  EPA-600/4-79-020.   LRL  should follow equipment  preparation require-
  ments given in these  manuals.

0 On Table 6, page  23  of the SAP  needs to  state  clearly  what specific
  elements or compounds  are  included  with  common  anions,  minerals,
  demand parameters and solids.

0 Holding times  for a  number of parameters given in Table 6 are incor-
  rect.  The parameters, Table  6  holding time,  and the  EPA required
  holding times  are given  below:
        PARAMETER
TABLE 6
  EPA
       Total  Suspended
        Solids (TSS)
28 days
 7 days
       Biochemical  Oxygen
        Demand (BOD)
28 days
48 hours
       PCB and
        Pesticides
28 days
 7 days until
 extraction, 40  days
 after extraction
       Acid, base neutral
        priority pollutants    28 days
                    7 days until
                    extraction, 40  days
                    after extraction

-------
                               -57-
0 The SAP does not discuss how LRL tracks samples  to assure that hold-
  i ng times are  met.

0 Table 6  also states that  sodium thiosulfate  is  added to the VOA and
  fecal coliform samples.   This  compound is  required only if residual
  chlorine  is suspected to  be in the sample.  This  is unlikely to be
  the case  for ground-water,  or  leachate samples.

0 A  typing  error was noted on Table 6.  COP should read COD  (for chemi-
  cal oxygen  demand).

0 Table 6   states that trip  blanks are included for  VOA  samples.  The
  SAP needs  to  state where  these  blanks  are poured.   Trip  blanks
  should be poured  in a  clean laboratory.  Field  blanks  should not be
  poured near a  well.   Field  blanks  are  expecially  important at wells
  located  near high  traffic  areas,  active  landfill areas,  or  near
  leachate  collection points.

0 The SAP   needs  to include a section  on quality assurance (QA)  and
  quality  control  (QC).   The  following  types  of QA/QC  samples  need
  to be added to LRL's sampling  events:

     1) Reagent  or  bottle blanks for metals, TOX, total  organic car-
        bon (TOC),  nutrients, COD,  phenols  and  acid,   base  neutral
        organics.

     2) Equipment  blanks.   After the bailer  is cleaned, high quality
        water should  be  poured  through  a  bailer  and   collected  in
        appropriate sample  containers.   Some of the  water should also
        be  run  through  filtering equipment  for  a  dissolved  metals
        equipment blank.

-------
                             -58-
   3) The SAP  needs to  state that additional  sample  volume be  col-
      lected laboratory spike  and replicate  samples.

   4) Duplicate field samples  need to  be taken.  Therefore,  at 10%
      of the sample points two complete sets  of  samples  need to be
      taken as checks for possible errors due to improper  sampling
      techniques.

Page 24 of the SAP states "wells  are  thoroughly  purged  of any stag-
nant water prior  to sampling".  The  SAP  needs to state what  'thor-
oughly' means.   During the Task Force observation of  LRL's  sampling
in September 1986, the sampling personnel stated  that they  purged a
well until either three  well  volumes  were  removed  or the well  was
dry.  The plan needs to include this  criteria.

On page 31,  step 11  requires that "the container  to  be used  to store
the water sample is to be rinsed with deionized water."  What samples
are stored in this container?   If this  is for the storage of samples
for pH, temperature,  and specific  conductance,   then  it  should  be
stated.

The SAP needs  to  give a description  of the sampling equipment  in-
cluding dimensions  and  materials  of construction.   During   our
observation of LRL's  sampling, we noted their   sampling personnel
used a bailer made of Teflon.

The SAP needs to add the maximum  amount of  time  between purging and
sampling.   Pages  36 and  37  gives  a  purging and  sampling schedule,
but does not give  a maximum time.  During the  September 1986  sampl-
ing event, LRL stated this was  24 hours.

-------
                                   -59-

    0 In the chain-of-custody section, LRL  needs to  document how  samples
      are shipped to the  contract  lab,  including  if samples are  kept  on
      ice and  how  long  after  sampling  they  are delivered  to the  lab.

    0 During the Task  Force  observation  of LRL's sampling technique,  it
      was noted  that  the  sampling personnel  wore  surgical-type  rubber
      gloves. This   needs  to  be  documented  in  the  SAP.   These  gloves
      should not contain  any  talcum powder which  could contaminate the
      samples.

    0 Pages 37 through 39 of the SAP describe LRL's  sampling of  leachate
      and surface water techniques.  This section needs to include LRL's
      preservation  methods,  if  any, for these  samples,  especially  for the
      leachate  samples.   Preservation  of  leachate  samples  with acids
      (such as  nitric  acid for metals preservation) can be very  dangerous.

The above review of  the SAP as well  as the Task Force observation  of LRL's
sampling event  in September 1986,  indicate  that the SAP needs extensive
revisions.   During  the September event LRL's  sample personnel  performed
steps that  are not  documented in the  SAP.   These steps, as  well as the
above deficiencies  need to be included  in a  revised SAP.

    b) LRL's Sample  Analysis and Data Quality  Evaluation

On October  31,  1986, the Task Force Laboratory  Evaluation Team performed
an onsite  evaluation   of  the  CBC-Aqua  Search,  Division  of  Chemo-Bio
Corporation, Oak  Creek, Wisconsin,  pursuant to RCRA ground-water monitor-
ing activities  for LRL.

-------
                                   -60-

    0 Inorganic Laboratory

The purpose of the evaluation was to establish whether CBC-Aqua Search's
standard operating procedures  produce data of acceptable quality. CBC-Aqua
Search analyzed  U.S.  EPA  Water  Supply  and  Water Pollution  Performance
Evaluation Samples to demonstrate  its analytical  capabilities.  The  labo-
ratory was evaluated  for the  following  inorganic parameters:  chloride,
iron, manganese,   sodium,  phenols,  sulfate,  arsenic,  barium,  cadmium,
chromium, lead, mercury, selenium, silver,  fluoride,  and  nitrate.

The following are the  observations  that  were made during the evaluation
and the  recommendations  to  CBC-Aqua  Search  to improve the data quality:

    0 Observation:  The  laboratory  participates   in  the U.S.  EPA  Water
      Supply Pollution Performance Evaluation Studies,  and displays
      consistent  errors  for  inorganic  parameter  analyses  (see Appendix
      C, Tables C-l, C-2).

      Recommendation:  The laboratory should  develop  an  intra-laboratory
      comparison  study  by  periodically  analyzing  EPA  quality   control
      samples.

    0 Observation:  The  quality control  practices for  inorganic chemical
      analyses were reviewed during the  on-site  evaluation.

      Recommendation:  A quality  assurance  program should see that  docu-
      mented approved  methodologies  exist,  that  instrument   calibration
      procedures are appropriate,  that quality control acceptance criteria
      are met prior to reporting of final data and that summarized  quality
      control data are effectively evaluated.

    0 Observation:  The  laboratory acceptance  criteria for metals  spike
      recoveries were between 60%  and 130%.

-------
                               -61-
  Recommendation:   The laboratory acceptance criteria for metal  spike
  recoveries should be between 80% and 120%.

0 Observation:   Calibration procedures for atomic absorption spectro-
  photometers are  inadequate.  The laboratory composes  a calibration
  curve with only  two standard solutions.

  Recommendation:   A calibration  curve  should be composed  using,  at
  minimum, a reagent blank and three standards.

0 Observation:   The laboratory does  not  have an EPA  approval method
  for metals performed  by Inductively  Coupled  Plasma  spectroscopy.

  Recommendation:   The laboratory  should  document  and   finalize  the
  method as soon as possible.

0 Observation:   The  calibration  procedure  for  nitrates by the  Auto
  Analyzer method  is inadequate.   The laboratory composes a  calibra-
  tion curve with  two standard solutions.

  Recommendation:   A calibration  curve  should be composed  by using,
  at a minimum  a reagent  blank and three standards.

0 Observation:   The laboratory does  not  have a  satisfactory  assess-
  ment of their accuracy  and  precision.

  Recommendation:   At  least one duplicate  sample should  be  run  every
  10 samples to  verify  precision  of  analylical methods.   Also,  a
  spike sample  should  be  analyzed routinely, to  verify accuracy  of
  the method.

-------
                                   -62-

    ° Organic Laboratory

The laboratory,  CBC  Aqua  Search,  analyzed  the LRL's  ground-water  and
leachate samples for  total  organic  carbon (TOC), total  organic halide
(TOX), pesticides  (endrin,   lindane,  methoxychlor   and   toxaphene)   and
herbicides (2,4-D and  2,4,5-TP).   In addition,  the  laboratory  analyzed
leachate samples for  pesticides  and PCBs.

The following  observations  were made  during  the  brief  on-site visit:

    0 The laboratory  participated in an inter!aboratory comparison studies
      conducted by  U.S.  EPA  and produced  results  of poor quality.   The
      laboratory performance  evaluation  .results are provided in  Appendix
      C, Table C-3.

    0 The laboratory  test  procedures and  quality  control practices  are
      acceptable.

    0 The laboratory  has never participated in  U.S. EPA Water Supply  per-
      formance evaluation  studies  (interlaboratory  comparison  studies)
      for drinking  water pesticides and  herbicides.

    0 The laboratory  has  not recently  participated in U.S. EPA Water Pollu-
      tion performance evaluation studies  for  pesticides  and it  produced
      unacceptable  results  for pesticides  and  PCBs, when  participating in
      the interlaboratory comparison  studies.

    0 The laboratory  instruments are suitable for the analysis of TOC,  TOX,
      pesticides, herbicides  and PCBs.

-------
                                   -63-

    0 The laboratory does not have an up-to-date log on the precision and
      accuracy data  collected  during the  chemical  analysis  (NOTE:   The
      laboratory should  provide  precision  data  by  relative  percent  dif-
      ference (RPD)  so  that  it  would  be easier to maintain  statistical
      summaries on all precision data collected.  RPD  = ((Amount Found in
      Sample 1 - Amount  Found  in Sample 1  Duplicate)  TOO/  (Amount  Found
      in Sample 1  + Amount Found in Sample  1  Duplicate) 12}}.

    ° The laboratory recently started documenting the  status  of each  ana-
      lytical instrument  in  the  instrument  log  books.  However,  the log
      books do not  provide  any  information  on  the  sensitivities of the
      analytical  instruments on the day  of usage and the number of samples
      analyzed on  each day of usage.

    4.  GROUND-WATER QUALITY ASSESSMENT

The present RCRA monitoring  system is inadequate to detect or assess re-
leases of hazardous waste or hazardous  waste  constituents.  LRL  needs to
improve its monitoring system and its ground-water assessment  procedures.

After the WDNR  initiated enforcement action  against  LRL  for  failing to
statistically analyze the RCRA ground water  monitoring data,  LRL  submit-
ted the  report  "Land Reclamation,  LTD.  Environmental Impact  Monitoring
Plan and Procedures" (dated March  1986).  This  submittal attempts to ex-
plain cause of statistically significant indicators.   The  pH  exceedances
were explained as  cement grout  contamination  of the upgradient wells.
TOC exceedances at  one  well were  attributed to the  wetland  immediately
above this well.   The  report  concludes that  no  significant ground-water
impacts are occurring at the site.

-------
                                    -64-
The report failed  to mention  some  other  statistically  significant  ex-
ceedances.  The  reports  statistics  show  TOC exceedances  for wells  10U
and SOL.  These exceedances  should  have triggered LRL into  performing  a
ground-water quality assessment monitoring as required by  NR 181.49(5)(h).

If the pH values were biased by the  cement  grout  contamination,  the  grout
contamination should also have affected the  specific  conductivity values.
No statistically significant exceedances were noted  for  conductivity  due
to the grout  contamination.   LRL was unable to provide an  acceptable  means
for evaluating the TOX data.  All  background sampling showed that the  TOX
level  was below the analytical  detection limit.  Since the background data
was below detection, LRL  did not attempt to statistically analyze the  down-
gradient wells.  Furthermore,  Well  22U  showed  numerous  samples  above  the
detection limit,  LRL should  have  prepared  a  ground-water  assessment.

G.  MONITORING DATA ANALYSIS FOR INDICATIONS OF  WASTE RELEASE

    TASK FORCE DATA

During the inspection, samples were collected by  U.S. EPA's contractor to
determine if the  ground-water  contained hazardous waste  constituents or
other indicators of contamination.   Water was collected from 17 monitoring
wells, one surface  water location  listed  in LRL's WPDES permit,  and  one
leachate man-hole.  An additional  38 wells  were  measured  for water  level
only to construct ground-water contour maps  shown in  Figures 3,  4, and 5.

Samples collected by the Task Force  shows that a  release of hazardous con-
stituent has probably occurred.

-------
                                   -65-
Most of the detected organic  compounds  do  not  naturally occur in the en-
vironment.  Task  Force  sampling of the upgradient wells  showed  that the
organic compounds were  not  detectable.  However,  Well  39U had many iden-
tifiable and  quantifiable  organic compounds. As  noted below  nine wells
contained lead or chromium  levels above the limits listed  in Table X NR
181.49(5) (40 CFR Part 265, Appendix III).

Field measurements were made by the U.S. EPA contractor, Versar,  Inc., at
the time of sampling for pH, specific conductance and turbidity.   Labora-
tory analysis results were  obtained  from two U.S. EPA Contractor Labora-
tories participating in the Contact Laboratory Program.  Specific organic
compounds were analyzed  at  Compuchem Laboratories, Inc.,  and metals and
other parameters  at  Centec Laboratories.   Table  A-l  gives a  summary  of
analytical techniques  and   reference  methods,  by  parameter,  for  sample
analyses and Table  A-2  gives the  detection  limits  for all organic  com-
pounds.

Standard quality control measures were taken including:  (1) the  analysis
of field and  laboratory blanks  to allow  the  determination  of  possible
contamination due to sample handling,  (2)  analysis  of laboratory-spiked
samples to estimate accuracy,  (3)  analysis of both laboratory and field
duplicates to estimate  precision,  and (4)  the review  and interpretation
of the results of these control  measures, Appendix B.

    a) Metals Analytical  Results

Nine wells contained chromium or lead results above levels given  in Table
X, (50 ug lead,  50  ug/1  chromium) NR 181.49  (5)  Wis. Adm. Code  (40 CFR
Part 265,  Appendix III).  Wells that  contained lead  results above the 50
ug/1  limit given  in  Table  X, were  14U(108 ug/1), 14L (66  ug/1),  29L(51
ug/1),  39U(165 ug/1), and the  leachate  sample (52.2 ug/1).   Wells  found
with chromium above the Table X  limits  of  50 ug/1 were 6U(98 ug/1), 14U
(195 ug/1),  14L(102 ug/1), 40U(56 ug/1),  40U(Dup)(54 ug/1), 40L(107 ug/1),

-------
                                   -66-
and 40L(dup)(116 ug/1).   The laboratory has characterized the lead results
as semiquantitative  due  to deviations in  quality control  requirements.
The chromium results for the above wells  have been rated as  quantitative.
Further descriptions of  data usability and quality control is given below.

A comparison of dissolved metals data (Table  5) for the facility designated
upgradient wells (6U and 108L) with a number of  their downgradient wells,
indicates possible releases of arsenic,  barium,  cadmium,  and  chromium to
the ground-water.

The only  other metals found  in  high concentrations  were those  usually
found in  ground-water (aluminum,  calcium,   iron,  magnesium,   potassium,
and sodium).   All  dissolved  and  total  metals  results are summarized in
Appendix B.

    b) Inorganic And Indicator Parameter  Results

Field measurements were  conducted  by U.S.  EPA's contractor for  pH,  tem-
perature, specific conductance, and  turbidity.  This  data along  with the
remaining inorganic and  indicator parameters are  summarized in Table A-5
of Appendix A.   With  the exception  of  two wells, pH  results were  in the
range of 6.6 to  8.4.  Well  10U had a pH of  6.17  and the pH of  Well  39U
was 10.45.  Specific conductivity ranged  from a  low  of 190 umhos/cm (Well
29L) to a high of 2607 umhos/cm (Well 22L).  Turbidity  results were  less
than 40  NTUs  with  three exceptions,  Well  SOL  (260  NTU),  Well  39U  (100
NTU), and Well  110U (200 NTU).

Inorganic and indicator  parameters varied greatly from well to well.  Gen-
erally, constituents  normally  found  in  ground-water,  (sulfate,  chloride
and bromide) were found  in high concentrations.  Ammonia  varied  from un-
detected to 35 mg/1.  Five wells  had elevated total   phenol  levels,  Well
9U (100 ug/1), 39U (272  ug/1), 40U (105  ug/1),  40U (DUP)  (105  ug/1),  and
the leachate  (1100   ug/1).  Total  organic   carbon  (TOC) concentrations
ranged 2.6  mg/1  (Well 40L)  to 728 mg/1  (leachage).   Both TOC and total
phenols were found in some blanks  above the  detection limit.

-------
                                     -67-
                                 I Aill  1
                    COMPARISON  OF DISSOLVED METALS  DATA  FROM
                UPGRADIENT WELLS  (6U,  108U) AND DOWN6RADIENT  HELLS
UPGRADIENT * DOWNGRADIEN
T *
WELL - CONCENTRATION (ug/1) WELL - CONCENTRATION (ug/1 )
ARSENIC
6.U - ND 40L
108L - ND 109U -
14U -
39U -
29L -
40U -
BARIUM
6U - 77 9U -
108L - 332 10U -
14U -
22U -
29U -
' 39U -
40U -
109U -
1100 -
CADMIUM
6U - ND 22L -
108L - ND SOL
40L
CHROMIUM
6U - 19 14U
108L - 21 22U -
29U -
10.6
6.4
6.3
22.9
6.4
21.0
167
248
247
353
244
848
92
140
169
0.5
3.1
1.2
20
39
27
ND - Not detected above method detection limit.
 * - Well  designated as given by LRL.

-------
                                   -68-

    c) Organic Analytical  Results

With only one exception,  which is given below,  the only volatile organics
found in any of the ground-water samples  were  low levels  of toluene (not
detected to 12 ug/1)  and  acetone (not detected to 48  ug/1).   The  excep-
tion was downgradient  Well  39U,  which  contained the following  organic
compounds.

VOLATILE COMPOUND                                  CONCENTRATION (ug/1)

Acetone                                                      48
Benzene                                                      10
trans, 1, 2-dichlorethene                                    11
Ethyl Benzene                                                14
Tetrachloroethene                                            11
Toluene                                                      12
Trichloroethene                                               8.8
Xylene                                                       70

SEMIVOLATILE COMPOUND                              CONCENTRATION (ug/1)

2,4-Dimethyl Phenol                                          28
2-Methyl Phenol                                               4.8
4-Methyl Phenol                                              21

PESTICIDE COMPOUND                                 CONCENTRATION (ug/1)

4-4' - ODD                                                   12
Dieldrin                                                     15

-------
                                   -69-
These compounds were  all  greater than the values found in the upgradient
well in this  unit.   This  is an indication of  a  release of these consti-
tutents from  the  facility to the  ground-water.   Two other  organic  com-
pounds 1,1  dichloroethane  (2  ug/1)  and  4-methy-2-pentanone  (6.5  ug/1)
were detected  in  Well  39U, .  but  below the  contract  required detection
limits.  For  these  last  two compounds, the  mass  spectral  data indicated
the compound  was   present  above  zero  but  below  the  detection  limit.

For all wells, except 39U, the only semi-volatile organics found were bis
(3-ethylhexyl) phthalate,  and  di-N-butyl  phthalate.  Well  39U contained
2-methyl phenol (4.8mg/l), 4 methyl phenol  (21 mg/1) 2,4-dimethylphenol (28
mg/1) and phenol (by GC/MS) (52 mg/1).  In addition, Well  39U contained a
number of other semi-volatile compounds above zero but below the contract
detection limit (see data in Appendix B).

Of the ground-water  samples,  only  Well  39U indicated the presence of the
pesticides, dieldrin (12 mg/1) and 4-4'-DDD (15 mg/1), data summarized in
Appendix B.

The only organic compounds found  in  the surface water sample, were acetone
(10 mg/1) and di-N-butyl  phthalate (2 ug/1),  see Appendix B.

The leachate  sample  contained  nine  volatile  organics above the detection
limit.   These  were  toluene (1000  mg/1),   acetone (2100 mg/1)  methylene
chloride (230  mg/1),  2-butanone  (2200  mg/1),  1,1   dichloroethane  (220
mg/1),  trans-1,2-dichloroethene  (210  mg/1),  4  methyl-2-pentanone  (210
mg/1),  ethyl  benzene  (120  mg/1),  and  xylenes (420 mg/1).   One compound,
1,1,1  - trichlorethane (53  mg/1)  was  found above zero  but  below  the de-
tection limit.

The leachate also contains three semi-volatile  organics above the method
detection limit and 23 other compounds above  zero but below the detection
limit.   The three compounds found  above  the dectection limit  are  phenol
(by GC/MS)   (190 mg/1), bis(2-ethylhexyl)  phthalate  (110  mg/1),  and  4-
methylphenol (850  mg/1).

-------
                                       -71-

References

    1) WDNR Approval  Letter of Corridor No. 4
        Construction,  September 19,  1978

    2) WDNR Approval  Letter of Corridor No. 5
        Construction,  March 31, 1981

    3) WDNR Corridor  No.  5 Approval  Modification Letter
        November 20,  1981

    4) WDNR Approval  Letter of Corridor No. 6
        Construction,  November 19,  1985

    5) RMT Report Hazardous Waste Management
        Land Reclamation,  Ltd., November 1980

    6) Closure and Long Term Care Plan  for
        The Land Reclamation, Ltd.  Landfill
        Volume I WID  I: 076171008,  Scope I.P. #: 86 L 11
        January 1981  Foth  & Van Dyke and Associates, Inc.
        Milwaukee, WI

    7) Closure and Long Term Care Plan  for
        The Land Reclamation, Ltd.  Landfill
        Volume II, Appendix C

    8) Feasibility IN-field Condition Report to Wisconsin DNR,
        Residuals Management Technology, Inc., March 13, 1981

    9) Land Reclamation,  Ltd., Plan of  Operation
        Appendix Q, Environmental Impact Monitoring Plan and
        Procedures, January 15, 1985 Editrion

   10) Evaluation of  Quality Control  Attendant to the Analysis of
        Samples from  the Land Reclamation, Ltd., Wisconsin Facility,
        Planning Research  Corporation,  December 17, 1986

   11) The Assessment  of the Usability  of the Data Generated for
        Site 41B, Land Reclamation,  Ltd., Wisconsin, Prepared by
        Lockheed Engineering and Management Services, Inc.
        November 3, 1986

   12) Organic Analyses Compu Chem  Laboratories, Inc., Research
        Triangle Park,  NC

   13) Inorganic and  Indicator Analyses, Center Laboratories,
        Salem, VA

-------

           A.I HI H HIA  ^

ANALYTICAL TECHNIQUES AND TABULATED SUMMARY
 OF TASK FORCE OBSERVATIONS FOR MONITORING
    WELLS SAMPLED DURING THE INSPECTION
 LAND RECLAMATION. LTD.. RACINE, WISCONSIN

-------
                                                           - Al  -


                                                         Table  A-l

                                    Sample Preparation and Analysis techniques  and Methods
                                                                                                                                                 r
   Parameter
        Preparation technique                           Analysis  Technique
                                                                                                                  Helhod Reference
                                                                           •••••••••••i
•inductance

-------
o
                                                                   -  A2  -
('
                                                      twin or quMrmrioii rot OKMIC COMPOUNDS
                                                LiMit «f
                                              Quant1 tit la
                                                                                         Licit «f
                                                                                       QuantltAttM
                                                                                                       Li»U of
                                                                                                     QuintiUtion
                                 Csaeounat
                    Acanapntna*a
                    Maiacntai>oatnana
                    l.4-01cf>lerc5«f>i»««
                    2.4-Olnitratalwana
                    2.*-fl1i»itratl'««ai»«
FluarantltaiH)
4-QilerDpn*«yt
                                          vttar
                                         «tft»f
                    •itree«fis«M
                    N-«1troMdfMtny)«»iiM.
                    01-n-vctylpnenaUta
                                         «n«/or
                    Anuiracan*
                    Mnxaf<«
                    ••nzyl
                           •IcsMl
                    2'MatflyliMBlltlMlMW
                    4-«1tr»«n«Hi««
                    2-«*«tnyJnaontn«Un»
                                                   U
                                                   10
                                                   10
                                                   10
                                                   U
                                                   10
                                                   10
                                                   10
                                                   10
                                                   10
                                                   10
                                                   M*
                                                   10
                                                   10
                                                   10
                                                   10
                                                   10
                                                   10
                                                   20
                                                   10
                                                   10
                                                   10
                                                   MA
                                                   *0
                                                   20
                                                   40
                                                   10
                                                   10
                                                   10
                                                   10
                                                   10
                                                   10
                                                   10

                                                   10
                                                   10
                                                   10
                                                   10
                                                   10
                                                   10
                                                   U
                                                   10
                                                   10
                                                   10
                                                   MA
                                                   100
                                                   10
                                                   10
                                                   20
                                                   100
                                                   10
                                                   10
                                                   ICO
                                                    10
                                                    10
                                                    10
                                                    10
                                                    10
                                                   100
                                                   100
                                                                 Cat»oundl
2.4.»-THe»l

I'Cft I mi upaaia I
4-oitrapnano)
2.4>0inlora»«iana
                                        l.2-01ctilaraaUiana
                                        1.1-0 < en I araa tlwna
                                        trant*1.2H)1CAlar*aCtwna
                                        1.2-OlcnU
                                                 i
                                                  enloHd*
                                        1.1.2.2-Tatracnlaraatnana
                                        r*traenlaroatn*na
                                                                            thana
                                          Enonn katon*
                                          Pd-1014
                                          »CS- 1221
                                          •CI-1232
                                          Kt-1242
                                          •C1-12M
                                          •a- us*
                                          Kl-lZiO
o. 55
o. 93
0. 3S
0. 3S
o. as
0. &
0.1
0.1
0.1
O.I
0.:S
0.1
0.1
0. 1
0.1
O.OS
.O.OS
1
O.S
0.1
  .5
 1
 1
0. S
 O.S
 i
 1
                                                             Vinyl  Ollaria*
                                                             Aectana
                                                             2-lyUnana (HCR)-
                                                                         taana  (EDI)
                                         •erylanltrll*
                                         Ctrpon •1»«irta«
                                                             »««yl acetic*
                                                                                  (HtBK)
                                10
                                90
                                20
                                20
                                20
                                 S
                               900
                               100
                               100
                               500
                               900
                                 S
                                 9
                                 9
                                40
                                 9
                                40
                                20
                         *at

-------
                        -A-3-
                   I Alii   A - 3
CONTRACT REQUIRED DETECTION LIMITS (CRDL) AND INSTRUMENT
DETECTION LIMITS (IDL) FOR METALS, INORGANIC, AND INDICATOR PARAMETERS

PARAMETERS

Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmi urn
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesi urn
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc

Ammonia nitrogen
Bromide
Chloride
Cyanide
Nitrate nitrogen
Nitrite nitrogen
POC
POX
Sulfate
TOC
TOX
Total Phenols
CRDL (ug/1)
METALS
200
60
10
200
5
5
5000
10
50
25
100
5
5000
15
0.2
40
5000
5
10
5000
10
50
20
INORGANIC AND INDICATORS
100

1000
10
300

10
5
1000
1000
5
10
IDL (ug/1)

100
3
6
4
4
0.5
93
8
16
12
10
2
238
3
0.2
20
2160
3
10
156
5
21
12

10
50
1000

300
50
100
5
500
1000
5
10

-------
*.- vis. a^^.-va;.
                                 TABLE   A - 4
        SUMMARY OF OBSERVATIONS MADE DURING SAMPLING OF LRL MONITORING WELLS
WELL NO.
     DATE/TIME
                     REMARKS
 6U
    8/04/86
1335 - 1432
  6L
    8/05/86
1042 - 1115
  9U
     8/07/8
     8/08/86
 10U
     8/06/87
1130 - 1145
1510 - 1528
                     1510  -  1528
0850 - 0909
1325 - 1410
 14U
     8/05/86
1150 - 1340
Water clearer than original   purge water,
which  was a tan/brown  color.   LRL given
split for VOA, POC, POX, and  extractable
organics.
On  8/4/86,  while  purging,  the  bailer
separated  from the  sample line.  Bailer
was not recovered  until late in the day,
therefore, well was  completely  repurged
on 8/5/87 before sampling. Water was tan/
brown in color.  LRL given split for VOA,
POC, POX, and extractable organics.
VOA, POC, and POX  taken.  Facility given
split for VOA, POC, and POX.  Extractable
organics, Total and dissolved metals, and
TOC taken.

Extractable  organics, Total metals, dis-
solved metals, and TOC collected. Facili-
ty given split  for extractable organics.

TOX,  phenols, cyanide,  sulfate/chloride
and nitrate/ammonia collected.
Cloudy  and  rainy, Splits given to facili-
ty for  VOA, POC, POX, and extractable or-
ganics.
 Water  slightly  grey  in color.  Had to use
 a  3/4  inch  bailer which made purging  and
 sampling  very slow.   Splits  given to LRL
 for  VOA,  POC, PXO, and extractable organ-
 ics.

-------
                                      -A-5-

                            I A 1 i I   A - 4  (Cont'd)
         SUMMARY OF OBSERVATIONS MADE DURING SAMPLING OF LRL MONITORING WELLS
 WELL  NO.
	  DATE/TIME
                     REMARKS
 14L
     8/05/86
1239 - 1405
 22U
     8/06/86
1605 - 1645
22L
     8/06/86
1702 - 1800
    8/07/86
1020 - 1100
22U
    8/05/86
29L
    8/05/86
1458 - 1526
1542 - 1612
                    1627 - 1637
Water mild grey-brown  in color.  Use of a
3/4 inch bailer made  purging and sampling
slow.  Splits given  to LRL for  VOA, POC,
POX, and extractable organics.
Cloudy and rain.  Well located in a swampy
area.  Water  had  a  mild  brown   color.
Splits given to LRL for VOA, POC, POX, and
extractable organics.
Cloudy and rain.  Well located in a swampy
area.  Well  bailed  dry  at  1600.  After
allowing an  hour for  recharge, there was
only  enough water  for VOA, POC, and  POX
with a split being given to LRL.

Finished collecting remaining  parameters,
including giving LRL a split for extracta-
ble organics. Chain-of-Custody lost during
shipment.
Split given to LRL  for VOA, POC, POX,
extractable organics.
and
A find particulate matter was noted float-
ing on the water surface during the collec-
tion of TOX sample.  A split was  given to
LRL for VOA, POC, POX, and extractable or-
ganics.

Poured first of two field blanks near this
well.  Splits given to  LRL for  VOA, POC,
POX, and extractable organics.

-------
                                             -A-6-

                                   TABLE   A - 4  (Cont'd)
C
               SUMMARY OF OBSERVATIONS MADE DURING SAMPLING  OF  LRL  MONITORING WELLS
e
       WELL NO.
            DATE/TIME
C
        39U
           8/06/86
1232 - 1300
        40U
            8/07/86
1059 - 1142
C
        40L
            8/07/87
            8/08/86
1150 - 1222
1247 - 1331
            8/08/86
       108L
            8/04/86
       109U
            8/07/86
1225
1650 - 1712
1525 - 1606
                     REMARKS
SOL
8/06/86 1010 - 1045


Ral ny and
VOA, POC,

windy. Split given
POX, and extractable

to LRL for
organics.
Extra volume  of samples taken for VOA  and
extractable organics so laboratory can per-
form lab duplicate and matrix spike.  Splits
given to LRL for VOA, POC,  POX,  and extract-
able organics.

Field  duplicate  collected  at this  well.
Therefore,  two complete  sets  of  samples
taken.  Split, including the duplicate, was
given to LRL for VOA, POC,  POX,  and extract-
able organics.
            of Chain-of-Custody of  samples
            iment, lab  was told to  discard
Due to loss
during  shipment
this sample.

Well was repurged and  resampled.  Also,  the
the second  field  duplicate was   collected
here, to replace the duplicate lost at Well
109U.  Splits  given to  LRL for   VOA, POC,
POX, and extractable organics.

Field blank poured near this well.  A split
was given to LRL for VOA, POC, POX, and ex-
tractable organics.
Splits given to LRL for VOA,
extractable organics.
                              POC, POX, and
Well  at edge of road.  Heavy machinery op-
erating   during purging  and sampling.  A
field blank and field duplicate were col-
lected.   Splits were given to LRL for VOA,

-------
                                       -A-7-

                             TABLE    A-4   (Cont'd)
         SUMMARY  OF  OBSERVATIONS  MADE  DURING  SAMPLING OF LRL MONITORING WELLS
 WELL NO.
	 DATE/TIME
                     REMARKS
109U (cont'd)
110U
    8/06/86
1325 - 1343
    8/07/86

Surface Water
    8/08/86
Leachate
    8/08/86
0820


1055
832


1106
1245
Equipment Blank
    8/05/86          1450
                                          POC,  POX,  and  extractable organics.  During
                                          shipment,  Chain-of-Custody was lost on the
                                          field blank  and  one  set  of samples.  The
                                          labs  were  told to  discard these samples.
                                          The duplicate  sample taken from this well
                                          remained under custody and the data is
                                          summarized in  Tables A-4 through A-7. The
                                          second field blank was then collected on
                                          8/8/86 at  Well 40L.
Rainy and windy.  Well purged  dry at 0934.
Well was still  dry at 1030.  Samples collec-
ted for VOA, POC, POX, and part of the ex-
tractable organics. Splits given to LRL for
VOA, POX, POX,  and extractable organics.

Remainder of samples collected.
Collected samples from  surface water near
where LRL takes samples for their NPDES Per-
mit.  Splits given to facility for VOA, POC,
POX, and extractable organics.
              Full  set of samples  taken from one  of  the
              facility's leachate sumps. Sample  team  wore
              level  B safety protection (self-contained
              breathing apporatus and protective cloth-
              ing).   Splits given to LRL for VOA,  POC,
              POX,  and extractable organics.
                     High performance liquid chromatography  (HPLC)
                     grade  water  was  poured  through   a clean

-------
©
                                             -A-8-

                                   TABLE   A - 4  (Cont'd)
                SUMMARY OF OBSERVATIONS MADE DURING SAMPLING OF LRL MONITORING WELLS
        WELL  NO.
             DATE/TIME
                     REMARKS
       Equipment  Blank  (cont'd)
           8/95/86           1450
C.
e
       Field Blank
           8/05/86
       Field Blank
           8/07/86
       Field Blank
           8/08/87
       Trip Blank
           8/01/86
1627 - 1637
1013
1225
1400
C
                     bailer,  and  bottles were filled for all par-
                     ameters  listed  in Table 1.  This was done at
                     the  U.S.  EPA contractor's  truck  which was
                     located  near the entrance to the landfill.
HPLC grade water was poured into sample con-
tainers near Wells 29U,  and 29L, and labeled
as a field blank.  A split was given to LRL
for VGA, POC, POX, and extractable organics.
Field blank  collected near  Well  109U,  but
Chain-of-Custody lost during shipment.   Lab
told to discard sample.
HPLC grade water was poured into sample con-
tainers for all parameters near Well  40L.   A
split was given to LRL for VOA, POC,  POX,
and extractable organics.
At the lab of the U.S. EPA sample contractor,
a full set of sample containers were filled
with HPLC  grade  water.  These  containers
were taken to the site and kept in the con-
tractor's truck  located near  the landfill
entrance. Containers were not open while on
site.  On  8/7/86, these  containers  were
shipped to the laboratory and labeled as a
Trip blank.
O
C:
e

-------
                                                       -A-9-

                                                 lAilil  A - !

                                          SUMMARY OF PURGE DATA COLLECTED

                                                 FROM WELLS AT LRL

WELL
NUMBER


611
6L





9U






10U

14U


MEASURED *
DEPTH OF
WELL (ft)


45.05
89.65



89.65

14.92






20.2

31.87


MEASURED
DEPTH TO
WATER SURFACE
(ft)

17.84
58.00



58.00

6.51






14.17

23.75


ELEVATION
OF WATER
SURFACE
(ft above MSL)

707.67
667.71



667.71

667.29






666.94

664.65


PURGE
VOLUME
CALCULATED
(gal)

13.05
15.19



15.19

4.04






2.95

0.97


PURGE
VOLUME
ACTUALLY
Removed (gal )

13.3




15.2

2 (Dry)






3.0

1 gal



PURGING
DATE


8/04/86
8/04/86



8/05/86

8/07/86






8/06/86

8/05/86


TIME


1145-1432
1035-1113



0830-0941

0920-0948






1240-1250

1010-1045





REMARKS
Water tan/brown in
col or, heavy sediment
Water tan/brown in color
heavy sediment. Lost
bailer at 1113. Recover-
ed bailer at 1745
Repurged 3 well volumes
then sampled
Water had a slight grey
color. Bailer lost dur-
ing purging, but recov-
ered and well purged
dry. Sampling started 2
hrs. later after well
recovered.
Water clear, weather
rainy.
Water slightly grey. 3/4
inch bailer used, purg-
ing and sampling slow.
*  Depth measured  during the inspection and may  not  agree
   with Figures  in Table 4, due to sedimentation.

-------
        o
                                                   -A-10-

                                   lAlil   A - j>   (Cont'd)

                                 SUMMARY OF PURGE DATA  COLLECTED

                                       FROM WELLS AT LRL
WELL
NUMBER
14L
22U
22L
29U
29L
MEASURED *
DEPTH OF
WELL (ft)
61.33
14.77
46.08
46.67
95.60
MEASURED
DEPTH TO
WATER SURFACE
(ft)
25.00
3.83
6.08
22.40
58.65
ELEVATION
OF WATER
SURFACE
(ft above MSLl
663.85
665.61
664.58
697.43
661.15
PURGE
VOLUME
CALCULATED
(gal)
4.36
5.25
19.2
11.6
17.7
PURGE
VOLUME
ACTUALLY
Removed (gal)
4.5
3.0 (Dry)
7 gal
8.0 (Dry)
18.0
PURGING
DATE
8/05/86
8/06/86
8/06/87
8/05/87
8/05/87
TIME
0950-1140
1530-1537
1545-1600
1222-1241
1310-1422
REMARKS
Water had a mild grey/
brown color. Used a 3/4
inch bailer, purge and
sample very slow.
Well in swampy area. Wa-
ter mild brown color.
Weather clody, rainy.
Well purged dry before 3
well volumes removed.
Water was mild/ tan/grey
color, well purged dry.
Weather, rainy. Well in
swampy area.
Slight amount of sedi-
ment. Well purge dry be-
fore 3 well volumes re-
moved.
Water clear.
*  Depth measured during the inspection and  may  not  agree
   with Figures in Table 4, due to sedimentation.

-------
                                                 -A-ll-
                                  IAJLJL!  A -1  (Cont'd)

                               SUMMARY OF PURGE DATA COLLECTED

                                      FROM WELLS AT LRL
WELL
NUMBER
30L
39U
40U
40L
108L
109U
110U
MEASURED *
DEPTH OF
WELL (ft)
74.33
21.08
15.45
63.7
88.77
26.30
31.70
MEASURED
DEPTH TO
WATER SURFACE
(ft)
40.33
13.69
6.75
8.2
61.32
11.51
11.85
ELEVATION
OF WATER
SURFACE
(ft above MSL)
661.66
687.12
666.27
665.21
660.9
669.98
688.96
PURGE
VOLUME
CALCULATED
(gal)
16.2
3.25
4.2
27.5 .
13.2
7.1
10.0
PURGE
VOLUME
ACTUALLY
Removed (gal)
16.7
6.0
4.5
27.5
13.5
7.5
4.0(Dry)
PURGING
DATE
8/06/87
8/06/86
8/07/87
8/08/87
8/04/87
8/07/86
8/06/87
TIME
0920-1007
1008-1023
0494-0959
1152-1243
1600-1630
1420-1437
0920-0934
\
REMARKS
Water slightly turbid.
Weather, rainy and
windy.
Due to heavy tan sedi-
ments, the well was
purged on extra 3 well
volumes before sampling.

First set of samples
taken on 8/8/87 had to
be discarded due to loss
of Chain-of-Custody dur-
ing shipment. This is
second sampling effort.
Water had heavy tan/
brown sediments.
Water contained heavy
tan/brown sediments.
Wei 11 purged dry after 4
gallons removed. Weath-
er, rainy and windy.

*  Depth  measured during the inspection and may not agree
   with Figures  in Table 4, due to sedimentation.

-------
                    A P. f.! N. [).! X.  B.





 "EVALUATION OF QUALITY CONTROL ATTENDANT TO THE ANALYSIS



OF SAMPLES FROM THE LAND RECLAMATION. WISCONSIN FACILITY".



         DECEMBER 18. 1986, PRC ENGINEERING





        LAND RECLAMATION. LTD., RACINE, WISCONSIN

-------
                                            pro
     PRC Engineering                          Planning Research Corporation
     Suite 600
     302 East Wacker Drive
     Chicago, IL 60601
     312-938-0300
     TWX 910-2215112
     Caoie CONTOWENG
     December 18, 1986
     Mr. Anthony Montrone
     Hazardous Waste Ground-Water
       Task Force (WH-562A)
     U.S. EPA
     401 M Street, S.W., Room S-301
     Washington, D.C. 20460

     Dear Mr. Montrone:

          PRC Environmental Management, Inc. are pleased to submit for your review the
     final memcrandum for QA/QC support of Work Assignment No. 548 entitled "Evalua-
     tion of  Quality Control  Attendant  to the Analysis of  Samples  from  the  Land
     Reclamation, Wisconsin Facility."

          If  you have any questions regarding  this submittal, please feel free  to contact
     us.

     Sincerely,

     PRC Environmental Management, Inc.
     Daniel T. Chow
U
     DTC/cvh

     cc:   Nancy Deck (w/1 copy of report)
          Bruce Bakaysa (letter only)
          Barbara Elkus (w/1 copy of report)
          Rich Steimle (w/1 copy of report)
          Paul Friedman (w/1 copy of report)
          Ken Partymiller (w/copy of report)
          Brian Lewis (w/1 copy of report)
          Gareth Pearson (w/1 copy of report)
          Chuck Hoover (w/1 copy of report)
          James Adams, Jr. (w/1  copy of report)
          John McGuire (w/1 copy of report) t/
          Ed Berg (w/1 copy of report)

-------
            PRO Engineering
            Suite 600
            303 East Wacker Drive
            Cnicago. IL 60601
            312-938-0300
            TWX 910-2215112
            Cable CONTOWENG
          pro
          Planning Research Corporation
ENFORCEMENT
CONFIDENTIAL
                        EVALUATION OF QUALITY CONTROL ATTENDANT
                           TO THE ANALYSIS OF SAMPLES FROM THE
                           LAND RECLAMATION, WISCONSIN FACILITY
                                     FINAL MEMORANDUM
                                         Prepared for
                          U.S. ENVIRONMENTAL PROTECTION AGENCY
                               Office of Waste Programs Enforcement
                                    Washington, D.C. 20460
                                      Work Assignment, No.
                                      EPA Region
                                      Site No.
                                      Date Prepared
                                      Contract No.
                                      PRC No.
                                      Prepared By
                                      Telephone No.      :
                                      EPA Primary Contacts:

                                      Telephone No.      :
                      548
                      Headquarters
                      N/A
                      December 18, 1986
                      68-01-7037
                      15-5480-05
                      PRC Environmental
                      Management, Inc.
                      (Ken Partymiller)
                      (713) 292-7568
                      Anthony Montrone/
                      Barbara Elkus
                      (202) 382-7912
G
                               BB2ISED
                                             fif UTi£AT!OH

-------
                                        pro
PRC Engineering
Suite 600
303 East Wacker Drive
Cnicago, IL 60601
312-938-0300
TWX 910-2215112
CaDle CONTOWENG
Planning Research Corporation
                                MEMORANDUM
 DATE:        December 17,  1986

 SUBJECT:     Evaluation of Quality Control Attendant to the Analysis of Samples
               from the Land Reclamation, Wisconsin Facility

 FROM:        Ken Partymiller, Chemist
               PRC Environmental Management

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

 TO:           HWGWTF: Tony Montrone*
               Garcth Pearson (EPA 8231)*
               Richard Steimle*
               Ed Berg (EPA 8214)*
               James Adams, Jr., Region V
               John McGuire, Region V
               Brian Lewis

     This memo summarizes the evaluation of the quality control data generated by
 the  Hazardous  Waste  Ground-Water Task   Force  (HWGWTF)  contract  analytical
 laboratories (1).   This evaluation  and  subsequent  conclusions pertain to the data
 from the Land Reclamation, Wisconsin sampling  effort by the  Hazardous Waste
 Ground-Water Task Force.

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

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

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

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

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

 I.    Site Overview

      The Land Reclamation facility  is located in Racine, Wisconsin.  The landfill is
 on an  eighty-one acre site and  has  been in operation  since  1970.  The landfill is
 situated on a glacial  ridge which consists of  silty-clay loam containing little  sand or
 gravel  so contaminant migration is  expected to be  slow.  Hazardous wastes were
 accepted at the facility until  1982.  Types of hazardous wastes accepted, according
 to the  facility's Part A  Permit  Application, include ignitable wastes, metals, spent
 halogenated solvents, non-halogenated solvents, electroplating  wastes, pickle  liquors,
 ethylhexylphthalate,  tetrachloroethylene, and trichloroethane.   The facility  is  in
 Detection Monitoring which  means  that  there  has been no  indication  of  leakage
 from the site according  to the data submitted by  the  facility.  Some  violations of
 Interim Status standards  have occurred including problems with the adequacy of the
 ground-water monitoring  system and several of the Federal Facility Standards.

      An old city  landfill is located  next to  the hazardous waste site.  This  unlined
 landfill may have accepted hazardous wastes. Contamination from  this site  may be
 impacting  some  of  the  Land Reclamation  wells as contamination  has been  seen
 previously at some of the wells located  between the two sites.  Some  of the Land
 Reclamation up-gradient wells have  shown  possible contamination and may not be
 true "up-gradient" wells.

      Twenty-five field  samples  including two  field blanks  (MQO560/QO560 and
 MQO577/QO577),   one   equipment   blank  (MQO559/QO559),   one  trip    blank
 (MQO796/QO796), and two pairs  of duplicate  samples (well 40U, MQO569/QO569 and
 MQO570/QO570 and  well 40L, MQO578/QO578 and MQO579/QO579) were collected at
 this  facility.   Sample MQO580/QOS80 is  a  medium  concentration leachate  sample.
 Sample MQO576/QO576  is a low concentration  surface water  sample.  All  other
 samples were low concentration ground-water  samples.

 II.   Evaluation of Quality Control Data and Analytical Data

 1.0  Metals

 1.1   Performance  Evaluation Standard?

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

-------
 1.2   Metals OC Evaluation

      Total  and dissolved metal spike recoveries were calculated  for  twenty-three
 metals spiked  into six low concentration  ground-water samples (MQO558, 563, 569,
 570,  578, and  579) and one medium concentration  leachate sample (MQO580).  Not
 all metals were spiked into each of these  samples and separate samples were  spiked
 for the  total and dissolved  metal  ground-water samples.   Nineteen of the twenty-
 three total  metal  average spike recoveries and all seventeen of the dissolved  metal
 average  spike recoveries from the  low concentration ground-water samples were
•within   the  data  quality  objectives  (DQOs)  for  this   Program.    In  the  low
 concentration  ground-water  samples,  the  total  selenium  and  silver  average  spike
 recoveries were outside DQO with values  of 47 and 332 percent, respectively.  The
 total  aluminum and   iron spike  recoveries  were  not calculated  as the  sample
 concentrations of these metals were greater than four times  the  concentration of
 the spike. Various individual metal spike recoveries from  the ground-water samples
 were  also outside  DQO.  These are listed in  Table 3-2a of Reference 2 as well as in
 the following Sections.  A listing of which  samples were spiked for each analyte is
 also available in Table  3-2a  of Reference 2.

      Nineteen of  the twenty-three  total metal  spike recoveries and  twelve of the
 seventeen dissolved  metal spike recoveries from the medium concentration leachate
 spiked  sample  (only  the single sample  was  spiked) were  within DQO.   In the
 leachate sample the  total selenium and dissolved silver spike recoveries  were outside
 DQO with values of 46  and  64 percent.  The total aluminum, iron, and  lead, and
 dissolved  iron, magnesium,  potassium,  and   sodium  spike  recoveries  were not
 calculated because the  sample concentrations of these metals were greater than four
 times the concentration of the spike.

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

      The calculable  average relative percent  differences (RPDs) for metallic analytes
 in  ground-water samples, except total  chromium and  lead and  dissolved  aluminum
 and iron, were within Program DQOs.  The calculable RPDs for all metallic analytes
 in the leachate sample, except total aluminum, were  within the DQOs.  RPDs were
 not calculated for about one-half of  the  metal analytes because the  concentrations
 of  many of the metals in the field  samples used for the  RDP determination were
 less than the CRDL.

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

      No  contamination  was   reported in  the  laboratory  blanks.   A trip   blank
 (MQO796) contained 25 ug/L of total chromium and  an equipment blank (MQO559)
 contained 11  ug/L  of  dissolved  chromium.  Both  of these  values  are  above  the
 CRDL.

 1.3   Furnace Metals

      The graphite furnace  metals (antimony, arsenic,  cadmium, lead, selenium, and
 thallium) quality control, with exceptions, was acceptable.

      Duplicate injection  precision for antimony was poor  for samples MQO558, 578,
 579, and  580Dup (the  duplicate leachate analysis). All total and dissolved antimony
 results should be considered quantitative.

-------

      The  total arsenic spike recovery for sample MQO563 was outside DQO with a
 recovery  of  66  percent.   The  method of  standard addition  (MSA)  correlation
 coefficient for dissolved  arsenic in sample MQO570 was outside control  limits.
 There  was suspected  interference in this  analysis  due to the  presence  of large
 concentrations of sulfate.  Dissolved arsenic results for this sample (MQO570) should
 not be used.   All dissolved arsenic  results, with the  exception of sample  MQO570,
 should be considered quantitative. Due to variable total arsenic spike recoveries, all
 total arsenic results should  be considered semi-quantitative.

      The  cadmium results, recorded on  Form  3,  for three continuing  calibration
 blanks (CCBs)  were slightly different  than the values reported in the raw data.
 This has  no  impact on data quality.   All  cadmium results should be  considered
 quantitative.

      The  correlation  coefficient  for  the MSA  analysis of  total  lead  in sample
 MQOSSODup was outside of DQO.  Laboratory duplicate RPDs or absolute differences
 for total  lead  in samples MQO563 and 578  were  outside DQO.   The duplicate
 injection relative standard difference (RSD) for dissolved lead in sample MQO563Dup
 was outside DQO.   There were  deviations in the  control limits  for one set  of
 continuing calibration verifications (CCVs) and CCBs for  the lead analysis.  Samples
 MQOS60, 561,  563, 566, and 568 were run after the unacceptable CCV and CCB and
 total lead results for  these  samples  should be considered semi-quantitative.   All
 dissolved  lead results should be  considered  quantitative  and all total lead  results
 should be considered semi-quantitative.

     The selenium spike recoveries for samples MQO563,  579, and 580  were outside
 DQO with recoveries of 57, 36, and  46  percent, respectively. . There is no apparent
 reason for these unacceptable recoveries.  All  dissolved selenium results should  be
 considered quantitative  and, due  to poor spike recoveries, all total selenium results
 should be considered qualitative.

     All total and dissolved thallium results shoulo* be considered quantitative.

 1.4  ICP Metals

     Two   of  the  sampling   blanks   contained   chromium   contamination   at
 concentrations  greater than  the CRDL.  Equipment blank MQO559 contained  11  ug/L
 of dissolved chromium and  trip  blank MQO796 contained 25 ug/L of total  chromium.
 The apparent  chromium in  the equipment blank may have been the result of a high
 bias noted in  the chromium results on its analysis date (see  the following comment).
 Due to the chromium  contamination  found in the trip blank, the  total  chromium
 results for samples  MQO552, 554, 555,  561,  562, 563, 565, 566,  568, 575,  and 576
 should be considered unusable.

     The  low  leve^twice CRDL)  linear  range checks  for chromium, copper, silver,
 and zinc had  poorT£coverie~s.  Theflow  level linear range xiheck is an analysis of a
 solution with  elemental concentrations near the detection  limit.   The  range  check
 analysis shows the accuracy which can be expected by the  method for results near
 the detection  limits. The accuracy reported for these elements is not unexpected.
 Total chromium, silver, and zinc  results for samples  MQO553, 555, and 580  were
 affected  and should be  considered to be biased high.   All  dissolved copper, silver,
 and zinc  results for all samples   should  be  considered  to  be biased  low  and  all
dissolved chromium results should be considered to be biased high.

     Individual spike recoveries were outside DQO  for dissolved  calcium  in sample
MQO563  (126  percent),  dissolved  silver  in  sample MQO580 (64 percent),  and  total

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silver in samples MQO563 (332 percent) and 578 (332 percent).  Low spike recoveries
usually indicate results  which are  biased  low and  high spike recoveries  usually
indicate results which are biased high.

     The ICP serial dilution  results were  not within 10 percent  of the  original
determination for barium in sample MQO563 and for iron and  magnesium in sample
MQO580.  Poor serial dilution results can be an indication of physical interferences
in the analyses.  At  this facility, the interference is  most prevalent in the leachate
sample  (MQO580)  which  contains high concentrations of  dissolved  solids.   Such
interferences  usually  yield results with a negative  bias  and  thus a  low recovery.
.Sample MQOS63, however,  did  not  contain high  levels of  dissolved solids and
therefore the poor barium results cannot be attributed to physical interference.

     Laboratory duplicate results  for  dissolved aluminum  and  iron  and  total
chromium in sample MQOS63 and aluminum  in sample MQOS80  were outside DQO.

     Duplicate  injection RSD results for  calcium,  iron,  manganese, and  zinc  in
samples MQO578 and 579 were all outside DQO.

     All beryllium, cobalt, copper, manganese,  nickel, potassium, sodium, vanadium,
and  zinc  results should  be  considered quantitative.   Aluminum,  barium,  calcium,
chromium, iron,  magnesium, and silver results, with exceptions listed  below, should
also  be considered quantitative.   The  low level positive chromium results with
exceptions, the medium level results  for dissolved iron, magnesium, and silver, and
the low level results for dissolved barium,  calcium,, and  iron  should  be considered
semi-quantitative.  The  medium  level results for total  aluminum,  the low  level
results  for  dissolved  aluminum,  and  the  low level  results  for silver  should  be
considered qualitative.  Total chromium results for samples MQO552,  554, 555, 561,
562,  563,  565, 566, 568, 575, and  576 should be considered unreliable due to  blank
contamination at similar concentrations.

1.5  Mercury

     No problems were detected with the mercury data.  All mercury  results should
be considered quantitative with an acceptable probability of false negatives.

2.0  Inorganic and Indicator Analvtes

2.1   Performance Evaluation Standard

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

2.2  Inorganic and Indicator Analvte OC Evaluation

     The  average spike recoveries of  all of the  inorganic and indicator analytes,
except for ammonia nitrogen in the leachate sample, were  within the accuracy  DQOs
(accuracy DQOs .have not been established £j^ bromide and-nitrite nitrogen matrix
spikes).   The ammonia nitrogen  spike%ecdVery was 114 percent  in the  leachate
sample. The bromide and nitrite nitrogen spike recoveries were 92 and  100 percent
in the ground-water  samples  and 98  and 94 percent in the leachate sample.   The
recoveries for all inorganic and indicator analytes are acceptable.

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

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

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

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

 2.3  Inorganic and Indicator Analvte Data

      The QC standards  for  cyanide were not analyzed  in  conjunction with  the
 sample  analyses  but  were  run three days earlier.   All  cyanide results  should  be
 considered qualitative  with  an  acceptable probability of false negatives.

      Nitrate nitrogen  was  detected in the trip blank (MQO796)  at 9 ug/L.  As a
 HWGWTF convention, all results greater than ten times  the highest sampling blank
 concentration or less  than the detection  limit  are considered  quantitative (unless
 there are other  problems with the  data).  Results greater than five but less  than
 ten times the highest concentration  of sampling blank contamination are considered
 qualitative  and   all other  data are considered  unusable.   Therefore, the nitrate
 nitrogen results  for sample  MQOS69 should be considered qualitative.   Other results
 are listed below.  The holding times for the nitrate nitrogen analyses ranged from 2
 to 6 days from receipt of samples most  of which are longer than the recommended
 48 hour holding time for unpreserved samples.  The final calibration verification (a
 CCV) for  nitrate  nitrogen (120 percent) was  above  the DQO.   The  analytical
 instrument  should  have  been  recalibrated  and  the calibration  reverified before
 proceeding with  the sample analyses.  Results  for  samples MQO565, 569, 575, 576,
 577, 579, and 580 were  affected and should  be considered to be  biased high.   The
 field duplicate precision for one of  the  two duplicate pairs (MQO569/570) was poor
 (50 ug/L of nitrate nitrogen detected in one sample {the CRDL is  300 ug/L), 1110
 ug/L  detected in the  other).   The comparative  precision of  the  field  duplicate
 results  is not used  in the evaluation of  sample  results  as  it is  not possible  to
 determine the source  of this imprecision.  Field duplicate  precision is  reported for
 informational  purposes only.   All  nitrate nitrogen results, with the exceptions  of
 sample MQO569  mentioned above which  should be considered qualitative and sample
 MQO579 (see sulfate or chloride comment on  this sample) which should not be  used,
 should be considered to be semi-quantitative.

      The holding times for the nitrite nitrogen analyses ranged from  2 to  6  days
 from receipt of  samples which is generally longer  than  the recommended 48  hour
 holding  time for unpreservecL  samples.   The  laboratory did not analyze an initial
calibration   verification   (ICV) at *lhe  beginning -~of  the"  nitrite nitrogen  ion
chromatography analytical batch, as  required. The nitrite  nitrogen results should  be
considered to  be semi-quantitative except for .sample' MQO579 which should not be
used (see sulfate^ or chloride  comment oh this sample).

     The final CCV for chloride (336 percent) was  above the DQO.  The analytical
instrument  should  have been  recalibrated and the  calibration reverified  before
proceeding  with  the sample analyses.  Results for  samples  MQO565, 569,  575, 576,
577, 579, and  580 were affected and should be considered to be biased high.  The
chloride field  duplicate precision for both of the duplicate pairs (MQO569/570 and
MQO578/579)  was poor  (280,000 versus  190,000 ug/L in  the first  pair and  5900

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 versus  no chloride detected in the other).  These results were not used  in the data
 usability determination as the results may only  be  a reflection of poor  duplicate
 sampling techniques.  Field duplicate precision is reported for informational purposes
 only.  In the case of the sample MQOS79 from  the second field duplicate pair,  no
 ion  chromatography (1C) analytes  (nitrate  and nitrite nitrogen, chloride, bromide,
 and sulfate)  were detected although other 'inorganic and  indicator elements were.
As the  1C analysis,  for  all five 1C  analytes,  is performed  on a  sample from a
 separate  sample bottle, this' indicates that something was  wrong  with either the
 sampling or analysis of this 1C sample.  Chloride was detected in the trip blank at
 a concentration of 2200 ug/L.  As a HWGWTF convention, all results greater than
Ten times the highest sampling blank concentration or less than the detection limit
-are considered quantitative (unless there are other problems with the data).  Results
 greater  than  five but  less than ten  times the  highest  concentration of  sampling
 blank contamination  are  considered qualitative  and  all  other  data are considered
 unusable.   Therefore, chloride  results for samples MQOS53 should be considered
 qualitative  and results for samples MQOS54, 555,  556, 557, 558, 561, and 578 should
 be considered  unusable.   The chloride results  for  all other  samples should  be
 considered semi-quantitative with the exception of sample MQO579 which should not
 be used  because of the above mentioned problem with that sample.

      The laboratory did not analyze an ICV at  the  beginning  of  the bromide ion
 chromatography  analytical batch, as required.   Bromide was detected  in the  trip
 blank at a  concentration of 60 ug/L.  As a HWGWTF convention, all results  greater
 than  ten times  the highest sampling blank  concentration or less  than the detection
 limit are considered  quantitative (unless there  are other problems  with the data).
 Results  greater  than five  but less than ten times  the  highest concentration  of
 sampling blank  contamination are  considered  qualitative  and  all  other  data  are
 considered unusable.  Bromide results for samples  MQO553,  562, 578, and 579 should
 not  be  used.   The  bromide  results  for  sample MQO567  should  be  considered
 qualitative. AH other bromide results should be considered to be semi-quantitative.

     The final  CCV for sulfate (260 percent) was above  the  DQO.   The instrument
should have been recalibrated and the calibration,reverified before proceeding with
the sample  analyses.   Results for samples MQO565, 569, 575,  576, 577, 579, and  580
were  affected and should be considered  to  be biased  high as a  result.  The  sulfate
field   duplicate  precision  for  both  of  the  duplicate  pairs  (MQO569/570 and
MQO578/579) was poor (140,000  versus  105,000  ug/L  in the  first pair and 180,000
versus no sulfate detected in  the other).  These results were not used  in  the data
usability  determination  as the results  may  only be a reflection of poor duplicate
sampling techniques.   In  the  case of the sample MQO579  from the second field
duplicate pair, no ion chromatography (1C) analytes,  including sulfate, were detected
although other inorganic and  indicator elements  were. As the 1C analysis, for all
five 1C  analytes, is  performed on  a  sample from a separate  sample  bottle, this
indicates that something was wrong  with either  the sampling or analysis of this  1C
sample. The sulfate results, as mentioned above, should be considered quantitative
with the exceptions of samples J4QO565,  569, 575, 576, 577, and 580 which should  be
considered semi-quantitative antrcampl* MQO5JS. which^1houid1|bl bejwed.
                       -._      ._             •**•""
     One of two ammonia nitrogen ICV^and two CO^were outside of  DQO. The
ammonia  nitrogen  field  duplicate precision  for   one  of   the  duplicate  pairs
(MQO569/570) was poor (35,000 versus  27,000 ug/L).  These  results were not used in
the data usability  determination  as the  results  may  only be  a reflection of poor
duplicate sampling techniques. ^&\ ammonia Nitrogen results .-should *e  considered
semi-quantitative.      "

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      Total phenol contamination was found in one of the field blanks (MQO577) and
 the trip blank  (MQO796) at concentrations of 20  and 96 ug/L.   These values  are
 above the total phenol  CRDL of  10  ug/L.  Based upon HWGWTF conventions, all
 total  phenols  results greater than 10  times  the  highest  concentration  of total
 phenols  in the sampling blanks or  less  than  the detection  limit "are.considered
 quantitative.  This includes  samples MQO554, 555, 557, 558, 559, and 560. All total
 phenols  results  greater than five but less  than  ten  times the highest concentration
 of sampling blank contamination are considered qualitative and all other data  are
 considered unusable.   Total phenols  results  for all  other  samples (than  the  six
^mentioned above) should  not be used.
 i
      One  of two field blanks (MQO560) contained TOC at a concentration  of 1200
 ug/L which is above the CRDL of  1000 ug/L. Again,  as a HWGWTF convention, all
 TOC results greater that ten times the highest field blank concentration or less
 than the detection  limit should be considered quantitative.  TOC results for  samples
 MQO553, 559, 563, 568, 569, 570, 577,  580, and 796  should be, therefore, considered
 quantitative.  All TOC results greater  than five but less than ten  times the highest
 concentration of sampling blank contamination are considered qualitative  and  all
 other data are considered unusable. The TOC results for samples MQO557, 561, 562,
 565, and 576 should be considered qualitative, and all other TOC should not be used.

      ICV and CCV standards for POC  were not analyzed. A POC spike solution was
 run twice during the analytical  batch but the "true"  value  of the spike  was not
 provided by the laboratory.  EPA  needs to supply the inorganic laboratory with a
 POC calibration verification solution.  Until then, the instrument calibration  can not
 be assessed.   One  of  two sets of  field duplicates  (MQO569/570) showed poor
 precision  with  POC  concentrations of no  POC  reported  and  380  ug/L.  The
 comparative precision of the field duplicate results is  not used in the evaluation of
 sample data as  it  is not  possible to determine the source of  this imprecision.  Field
 duplicate  precision  is reported for informational  purposes  only.   The POC results
 should be considered qualitative.

      The TOX analysis  was run over a period  of.five days.  Final CCVs and final
 CCBs were not run at the end of each  days' analytical batch.  From the information
 on the laboratory  work sheets  it was not clear whether an ICV  and a ICB were run
 at  the beginning of one  of  the five day's  analytical batches. Sample MQO580, the
 leachate sample, contained a high  concentration of chloride (690,000  ug/L) which
 may  have  enhanced the  TOX results for this sample.   The results of one  pair of
 field duplicates  (MQO569/570) showed poor precision with TOX  concentrations of 54
 and 71 ug/L.  The comparative precision of the field duplicate results is not  used in
 the evaluation of  sample  data as it is not possible to determine the source  of this
 imprecision.  Field duplicate precision is reported for  informational purposes only.
 The TOX  results should  be considered quantitative except  for  the  samples where
 insufficient calibrations  were performed.   Samples  with  insufficient calibrations
include MQO552, 554, 556,  557,  560,  563,  568, 577, and 579 and  results for these
samples should be considered semi-quantitative.

     One of the.  two  sets  of POX field duplicates  (MQO569/570)  showed poor
precision with m> 3»OX tf^fcected  in one-^jmple and  15 ug/L detected in the other.
The comparative precision-of the field duplicate results is not used in the evaluation
of  sample  data  as  it  is  not possible  to determine the source1 of  this imprecision.
Field  duplicate precision  is reported for informational  purposes only.   The holding
times for samples MQO553 and 554 was eight days which exceeded the recommended
holding time of seven days.  POX results should be considered quantitative except
for samples MQO553 and 554 which should be considered semi-quantitative.

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 3.0   Oryanics and Pesticides

 3.1   Performance Evaluation Standard

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

 3.2   Organic OC Evaluation

 *    All matrix spike average recoveries were within established Program DQOs for
 accuracy.  Individual matrix spike recoveries which were outside the accuracy DQO
 will  be discussed  in  the appropriate Sections  below.   All surrogate  spike  average
 recoveries were within DQOs  for accuracy with  two exceptions.   Surrogate  spike
 recoveries  which  were  outside  the  accuracy DQO  will  be discussed  in  the
 appropriate Sections below.

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

      All organic analyses were performed as requested.

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

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

 3.3   Volatiles

      Quality control data indicate that volatile  organics were determined acceptably.
 The chromatograms appear  acceptable.  Initial  and continuing calibrations,  tunings
 and  mass  calibrations,  blanks, matrix spikes and  matrix spike  duplicates,  and
 surrogate spikes are acceptable.

     Estimated  method  detection limits were CRDL  for all  samples  except  QO580,
 the  leachate  sample,  which was  15  times  CRDL.   Dilution of this sample  was
 required.

     Laboratory blank  *860809, analyzed  on  8/9/86,  was  analyzed prior  to  the
 continuing  calibration  standard.   This did not  affect  the results  of the  data
 evaluation.

     The  volatile*  data are acceptable.   The  volatile compound results should be
considered  quantitative  with the exception of  the leachate sample (QO580) which
should  be  considered semi-quantitative  due  to an  increased probability  of  false
negative results.  The probability  of  false  negative rdftults for all other samples is
acceptable.

3.4   Semivolatiles

     Initial and continuing calibrations, tuning and  mass  calibrations, blanks, holding
times,  and chromatograms  were acceptable  for the  semivolatiles.  Some problems
were encountered with  matrix spike/matrix  spike duplicate  recoveries and surrogate
recoveries.

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      Contamination  was  detected   in   three   laboratory  blanks  (GH09623A21,
  GH0958SOC21, and GH095523C21).  The blanks contained di-n-butylphthalate  at less'
  than the CRDL.

      The matrix  spike  duplicate  (MSD)  recovery  of 4-nitrophenol' (9 "percent)  in
  sample QO578  was below the DQO of  10 to 80  percent.  The relative  percent
  differences (RPDs) between, matrix spike and  MSD recovery  of 4-nitrophenol  in
  sample QO578 and phenol in sample QOS63 were above DQO.

^    The  surrogate  percent  recoveries  for  phenol,  2-fluorophenol,  and   2,4,6-
 ttribromophenol  in sample QO562 (no recovery for  any of the three  acids) and  for
-'phenol and 2-fluorophenol in sample QO562RE (reextracted sample, 8 and 6 percent
  recoveries) were below their respective DQOs.

      The semivolatile data  are acceptable  and the results  should  be  considered
  quantitative for  all  samples except  QO580  which  should be  considered  semi-
  quantitative due  to  increased  probabilities  of false negatives and  for the acid
  fraction  results for sample QOS63 which should be considered unreliable due to poor
  acid recovery.   Estimated method  detection  limits are twice CRDL for all samples
  except QOS80  which  is  10 times CRDL.  The probability  of false  negatives  is
  acceptable for all samples with  the  exception  of  QO580  due  to raised  detection
  limits caused by dilution where the probability of false negatives  is increased.

  3.5    Pesticides

      The initial  and  continuing  calibrations,  blanks, matrix  spike/matrix  spike
 duplicates, surrogate spikes, and holding times for pesticides were  acceptable.   Some
 of  the  pesticide  chromatograms  appear   to contain  non-pesticide or  unidentified
 peaks.

      The estimated method detection  limits  for  the  pesticides fraction were CRDL
 for  all samples.  The  pesticides results should  be considered  qualitative.  There  is
 an  enhanced probability  of  false  negatives  (unre'covered pesticides in the sample)
 based upon the clean-up method used by the laboratory.

 III.  Data Usability Summary

 4.0   Graphite Furnace Metals

 Quantitative:       all total and dissolved antimony, cadmium, and thallium results;
                    all  dissolved  lead,  selenium,  and  arsenic  (except  MQO570)
                    results
 Semi-quantitative:   all total arsenic and lead results
 Qualitative:         all total selenium  results
 Unreliable:         dissolved arsenic results for sample MQO570

 4.1   ICP Metals

 Quantitative:       all  beryllium,  cobalt,-copper,   manganese,  nickel, potassium,
                    sodium, vanadium, and zinc results; aluminum, barium, calcium,
                    Chromium, iron, magnesium, and silver results with exceptions
                    listed below
 Semi-quantitative:   dissolved  iron,  magnesium, and  silver results  for  sample
                    MQO580  (leachate sample);  all  dissolved barium,  calcium, and
                    iron  results except for sample MQOS80; total  chromium results
                    with  exceptions listed  below

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 Qualitative:


 Unreliable:


 4.2  Mercury

 Quantitative:

*«
               total silver results except for sample MQO580;  total aluminum
               results for sample MQO580; dissolved aluminum results  for all
               samples except MQO580
               total chromium results for samples MQO552, 554, 561, 562, 565,
               563, 566,  568, 575, and 576
               all mercury results
Inorganic and Indicator Analvtes
 Quantitative:
 Semi-quantitative:
 Qualitative:
 Unreliable:
 Unusable:
 4.4  Organ ics
 Quantitative:
Semi-quantitative:
Qualitative:
Unreliable:
               sulfate,  TOX, and  POX results with  exceptions; total phenols
               results for  samples  MQO554, 555,  557, 558, 559, and 560; TOC
               results for  samples  MQO553. 559,  563, 568, 569, 570, 577, 580,
               and 796
               all  ammonia  nitrogen   results;  bromide,   chloride,  nitrate
               nitrogen, and nitrite nitrogen  results  with exceptions;  sulfate
               results for  samples  MQO565, 569,  575, 576, 577, 579, and 580;
               TOX  results  for samples MQO552, 554, 556, 557. 560, 563, 568,
               577, and 579; POX results for samples MQO553 and 554
               all POC results;  chloride results  for  sample  MQO553;  nitrate
               nitrogen results for  sample MQO569; bromide results for sample
               MQO567; TOC results for samples MQO557, 561, 562, 565, and
               576
               all cyanide  results
               all ion  chroma tography (nitrate and nitrite nitrogen, chloride,
               bromide, and sulfate)  results  for  sample MQO579; chloride
               results for  samples  MQO554, 555,  556, 557, 558, 561, and 578;
               bromide  results  for samples  MQO553,  562,   and   578;  total
               phenols  and TOC  results with exceptions
                                           sample  QO580;  all  semivolatile
                                           and the acid fraction  of  sample
all  volatiles  results  except
results except sample QO580
QO563
volatile and semivolatile results for sample QO580
all pesticides results
semivolatile acid fraction results for sample  QO563
IV.  References

1.   Organic Analyses:

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

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     Inorganic and Indicator Analyses:

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

 2.   Draft Quality Control  Data Evaluation 'Report (Assessment of the Usability of
*    the  Data Generated) for site 4IB,  Land Reclamation, Wisconsin,  11/4/1986,
 t    Prepared by Lockheed Engineering and Management Services Company, Inc., for
     the US EPA Hazardous Waste Ground-Water Task Force.

 3.   Draft Inorganic Data Usability Audit Report and Draft Organic Data Usability
     Report, for  the  Land Reclamation, Wisconsin site, Prepared  by Laboratory
     Performance Monitoring Group, Lockheed Engineering and Management Services
     Co., Las Vegas, Nevada, for US EPA,  EMSL/Las Vegas, 11/4/1986.

 V.   Addressees

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

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

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

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

 James Adams, Jr.
 Quality Assurance Office
 US Environmental Protection Agency
 230 South Dearborn Street
 Chicago, IL 60604

 John McGuire
 US Environmental Protection Agency
 230 South Dearborn Street
 Chicago, IL 60604

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Brian Lewis
c/o Department of Health Services
1219 K Street, First Floor
Sacramento, CA  95814

Paul Friedman
Characterization and Assessment Division, OSW (WH-562B)
US Environmental Protection Agency
401 M Street S.W.
Washington, DC  20460
*••"
Chuck Hoover
Laboratory Performance Monitoring Group
Lockheed Engineering and Management Services Company
P.O. Box 15027
Las Vegas. Nevada  89114

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PRO Engineering
Suite 600
302 East Wacker Drive
Chicago. IL 60601
312-938-0300
TWX 910-2215112
    CONTOWENG
prc
Planning Research Corporation
December 18, 1986
Mr. Anthony Montrone
Hazardous Waste Ground-Water
  Task Force (WH-562A)
U.S. EPA
401 M Street, S.W., Room S-301
Washington, D.C.  20460

Dear Mr. Montrone:

     PRC Environmental Management, Inc. are pleased to submit for your review the
final memorandum for QA/QC support of Work Assignment No. 548 entitled "Evalua-
tion of. Quality  Control  Attendant to the  Analysis of  Samples from  the  Land
Reclamation, Wisconsin Facility.".

     If you have any questions regarding  this submittal, please feel free  to contact
us.

Sincerely,

PRC Environmental Management, Inc.

Daniel T. Chow
DTC/cvh

cc:   Nancy Deck (w/1 copy of report)
     Bruce Bakaysa (letter only)
     Barbara Elkus (w/1 copy of report)
     Rich Steimle (w/1 copy of report)
     Paul  Friedman (w/1  copy of report)
     Ken Partymiller (w/copy of report)
     Brian Lewis (w/1 copy of report)
     Gareth Pearson (w/1 copy of report)
     Chuck Hoover (w/1 copy of report)
     James Adams, Jr. (w/1 copy of report!
     John McGuire (w/1 copy  of report) v
     Ed Berg (w/1  copy of report)

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PRC Engineering
Suite 600
303 East Wacker Drive
Cnicago. IL 60601
312-938-0300
TWX 910-2215112
Cafcie CONTOWENG
          pro
          Planning Research Corporation
ENFORCEMENT
CONFIDENTIAL
            EVALUATION OF QUALITY CONTROL ATTENDANT
               TO THE ANALYSIS OF SAMPLES FROM THE
               LAND RECLAMATION, WISCONSIN FACILITY
                         FINAL MEMORANDUM
                             Prepared for
              U.S. ENVIRONMENTAL PROTECTION AGENCY
                   Office of Waste Programs Enforcement
                        Washington, D.C. 20460
                          Work Assignment (Jo.
                          EPA Region
                          Site No.
                          Date Prepared
                          Contract No.
                          PRC No.
                          Prepared By
                          Telephone No.      :
                          EPA Primary Contacts:

                          Telephone No.      :
                      548
                      Headquarters
                      N/A
                      December 18, 1986
                      68-01-7037
                      15-5480-05
                      PRC Environmental
                      Management, Inc.
                      (Ken Partymiller)
                      (713) 292-7568
                      Anthony Montrone/
                      Barbara Elkus
                      (202) 382-7912
                    WILEStD ffCfJC ROBUST PREPARED
                    » AK7U ATIJrJ  OF UTiSATICH

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PRC Engineering
Suite 600
303 East Wacker Drive
Chicago. IL 60601
312-938-0300
TWX 910-2215112
Cable CONTOWENG
prc
Planning Research Corporation
                                 MEMORANDUM
 DATE:         December 17, 1986

 SUBJECT:      Evaluation of Quality Control Attendant to the  Analysis of Samples
                from the Land Reclamation, Wisconsin Facility

 FROM:         Ken Partymiller, Chemist
                PRC Environmental Management

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

 TO:            HWGWTF: Tony Montrone*
                Gareth Pearson (EPA 8231)*
                Richard Steimle*
                Ed Berg (EPA 8214)*
                James Adams, Jr., Region V
                John McGuire, Region V
                Brian Lewis

      This memo summarizes  the evaluation of the quality control data  generated by
 the  Hazardous  Waste  Ground-Water  Task  Force (HWGWTF)   contract analytical
 laboratories (1).  This evaluation  and subsequent conclusions  pertain to the data
 from the Land Reclamation, Wisconsin sampling  effort  by the Hazardous Waste
 Ground-Water Task  Force.

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

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

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

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

 Preface

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

 I.    Site  Overview

      The  Land Reclamation  facility is located in Racine, Wisconsin.  The landfill is
 on an  eighty-one acre site  and has been in operation since 1970. The  landfill  is
 situated on a glacial ridge which consists of  silty-clay loam containing little sand  or
 gravel  so contaminant migration  is expected to be slow.   Hazardous wastes  were
 accepted at  the facility until 1982. Types of hazardous wastes  accepted, according
 to  the  facility's Part  A Permit Application, include ignitable wastes,  metals, spent
 halogenated  solvents, non-halogenated solvents, electroplating wastes, pickle liquors,
 ethylhexylphthalate,  tetrachloroethylene,  and trichlorocthane.   The  facility is   in
 Detection  Monitoring  which  means that there  has  been  no indication  of leakage
 from the  site  according to  the data  submitted by  the  facility.  Some violations of
 Interim Status standards have occurred including problems with  the adequacy of the
 ground-water monitoring system and several of the Federal Facility  Standards.

      An old city  landfill is  located next to the hazardous waste site.  This unlined
 landfill may have  accepted  hazardous wastes. Contamination from this site may be
 impacting some  of  the  Land Reclamation wells as contamination  has  been  seen
 previously at some  of  the wells located between the two  sites.  Some of the Land
 Reclamation up-gradient wells have shown possible  contamination and may  not  be
 true "up-gradient" wells.

     Twenty-five  field samples including two  field blanks (MQO560/QO560 and
 MQO577/QO577),   one  equipment  blank  (MQO559/QO559),   one   trip   blank
 (MQO796/QO796), and  two pairs of duplicate samples (well 40U, MQO569/QO569 and
 MQO570/QO570 and  well 40L, MQO578/QO578 and MQO579/QO579) were  collected at
 this facility.   Sample  MQO580/QO580  is a medium concentration leachate sample.
 Sample  MQO576/QO576  is a low  concentration  surface  water  sample.   All  other
 samples were low concentration ground-water samples.

 II.   Evaluation of Quality Control  Data and Analytical Data

 1.0   Metals

 1-1   Performance Evaluation  Standard;

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

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1.2   Metals OC Evaluation

     Total and  dissolved metal spike recoveries  were calculated for twenty-three
metals spiked into  six low  concentration ground-water samples (MQO558,  563, 569,
570, 578,  and 579)  and one medium  concentration leachate sample (MQO580).  Not
all  metals were spiked into  each of these samples and separate samples were spiked
for the total and dissolved metal ground-water samples.  Nineteen  of the twenty-
three total metal average spike recoveries and all seventeen of the  dissolved metal
average spike recoveries  from the low  concentration ground-water samples  were
within  the  data  quality  objectives (DQQs)  for  this  Program.    In  the  low
concentration  ground-water samples, the total  selenium and  silver  average spike
recoveries were outside DQO with  values of 47 and  332  percent,  respectively.  The
total  aluminum  and  iron  spike  recoveries  were  not  calculated  as the  sample
concentrations of these metals  were  greater than four times  the concentration  of
the spike.  Various individual metal spike recoveries  from the  ground-water samples
were also  outside DQO.  These are  listed  in Table 3-2a of Reference 2 as well as in
the following Sections.  A listing of  which  samples were spiked for each analyte is
also available in Table 3-2a of Reference 2.

     Nineteen of the  twenty-three total  metal  spike recoveries and  twelve of the
seventeen  dissolved metal spike recoveries from the  medium concentration  leachate
spiked sample  (only  the single sample  was spiked) were  within  DQO.    In  the
leachate sample the total selenium and dissolved silver spike recoveries were outside
DQO with values of  46 and 64 percent.  The total  aluminum, iron, and lead, and
dissolved  iron,   magnesium, potassium,  and  sodium  spike   recoveries were  not
calculated because the sample concentrations of these metals were greater than four
times the concentration of the spike.

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

     The calculable average relative percent differences (RPDs) for metallic analytes
in ground-water  samples, except total chromium 'and lead  and dissolved aluminum
and iron,  were within  Program DQOs. The  calculable RPDs for all metallic analytes
in the leachate sample, except  total aluminum,  were  within the DQOs.  RPDs  were
not calculated for about  one-half of the metal analytes  because  the concentrations
of  many of the  metals in the field  samples used  for the RDP determination  were
less than the CRDL.

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

     No contamination  was  reported  in  the  laboratory  blanks.   A  trip blank
(MQO796) contained 25 ug/L of total chromium and an equipment blank (MQO559)
contained  11  ug/L of dissolved chromium.   Both  of these  values  are above the
CRDL.

1.3   Furnace Metals

     The  graphite furnace  metals (antimony, arsenic, cadmium, lead, selenium, and
thallium) quality control, with exceptions, was acceptable.

     Duplicate injection precision for antimony was  poor for  samples MQO558, 578,
579, and 580Dup (the duplicate leachate analysis).  All total and  dissolved  antimony
results should be  considered  quantitative.

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      The total arsenic spike  recovery for sample MQOS63 was  outside DQO with a
 recovery of  66  percent.   The  method of  standard addition  (MSA)  correlation
 coefficient for  dissolved arsenic in sample MQOS70 was  outside  control  limits.
 There  was suspected  interference  in this  analysis  due to  the  presence of  large
 concentrations of sulfate. Dissolved arsenic results for this sample (MQO570) should
 not be used.   All dissolved arsenic  results, with the  exception of sample MQO570,
 should be considered quantitative. Due to variable total arsenic spike recoveries, all
 total arsenic results should be considered  semi-quantitative.

      The  cadmium results,  recorded on  Form  3,  for three  continuing  calibration
 blanks (CCBs) were slightly different  than' the values  reported in  the  raw  data.
 This has no  impact on  data quality.   All  cadmium  results should  be considered
 quantitative.

      The  correlation  coefficient for  the MSA  analysis of  total  lead  in  sample
 MQOSSODup was outside  of DQO. Laboratory duplicate RPDs  or absolute differences
 for total  lead  in samples MQO563  and 578  were  outside  DQO.    The  duplicate
 injection relative standard difference (RSD) for dissolved lead  in sample MQO563Dup
 was  outside DQO.   There  were deviations in the  control  limits  for one  set  of
 continuing calibration verifications (CCVs) and CCBs for  the  lead analysis.  Samples
 MQO560, 561, 563, 566, and  568  were run after the unacceptable CCV and  CCB and
 total lead results  for  these  samples  should be considered semi-quantitative.   All
 dissolved lead results  should be  considered  quantitative  and all total  lead  results
 should be considered semi-quantitative.

      The selenium spike  recoveries  for samples MQO563,  579, and 580 were outside
 DQO with recoveries of  57, 36, and  46  percent, respectively.  There is no  apparent
 reason  for these  unacceptable recoveries.  All  dissolved selenium results  should  be
 considered quantitative and, due  to poor  spike recoveries, all total selenium  results
 should be considered qualitative.

      All total and dissolved thallium results should be considered quantitative.
                                               t
 1.4   ICP Metals

      Two   of   the  sampling   blanks    contained   chromium   contamination   at
 concentrations greater than the CRDL.  Equipment blank MQO559 contained 11 ug/L
 of dissolved chromium  and trip blank MQO796 contained 25 ug/L of total chromium.
 The apparent  chromium in the equipment blank may  have been  the result  of  a high
 bias noted in  the chromium results on its analysis date (see the  following comment).
 Due  to the chromium  contamination  found  in the  trip blank,  the  total chromium
 results  for samples  MQO552, 554, 555,  561,  562, 563,  565, 566, 568,  575, and 576
 should be considered unusable.

      The low  level  (twice CRDL) linear  range  checks for chromium, copper, silver,
 and zinc had  poor recoveries.  The low  level linear  range check is an analysis of a
 solution  with  elemental concentrations near  the detection limit.  The range check
 analysis  shows the accuracy  which can be expected  by the  method for results near
 the detection  limits. The accuracy reported for these elements is not unexpected.
 Total chromium, silver, and  zinc results  for samples MQO553, 555, and  580 were
 affected and should be considered to be  biased high.  All  dissolved copper, silver,
 and  zinc results  for all  samples should  be considered to be  biased  low and all
 dissolved chromium  results should  be considered to be biased  high.

     Individual spike recoveries were outside DQO  for dissolved calcium in sample
MQO563 (126  percent), dissolved  silver  in sample MQO580 (64 percent),  and total

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 silver  in samples MQOS63 (332 percent) and 578 (332 percent).  Low spike recoveries
 usually indicate results  which are  biased  low and high  spike  recoveries usually
 indicate results which are biased high.

     The ICP serial dilution results were  not within  10  percent of the  original
 determination for barium in sample MQO563 and for iron and magnesium in sample
 MQOS80.   Poor serial dilution results can be an indication of physical interferences
 in the analyses.  At  this facility, the interference is most prevalent in the  leachate
 sample (MQO580)  which  contains  high concentrations  of  dissolved solids.  Such
 interferences  usually  yield results  with a negative bias and  thus a low  recovery.
 Sample MQO563, however,  did not  contain high  levels  of  dissolved  solids  and
 therefore the poor barium results cannot be attributed to physical interference.

     Laboratory  duplicate results  for  dissolved  aluminum  and  iron  and  total
 chromium in sample MQO563  and aluminum in sample MQO580 were outside DQO.

     Duplicate  injection RSD results for calcium,  iron, manganese, and  zinc in
 samples MQOS78 and 579 were all outside DQO.

     All beryllium, cobalt, copper, manganese, nickel, potassium, sodium, vanadium,
 and  zinc  results should  be  considered quantitative.  Aluminum,  barium, calcium,
 chromium, iron,  magnesium, and silver results, with exceptions listed below, should
 also  be  considered  quantitative.    The  low  level  positive chromium results with
 exceptions, the medium level  results for dissolved iron,  magnesium, and  silver,  and
 the low level results for dissolved  barium, calcium, and iron  should be  considered
 semi-quantitative.  The  medium  level results for  total aluminum,  the  low level
 results  for  dissolved  aluminum,  and  the low  level  results  for  silver  should  be
 considered qualitative.   Total  chromium  results for samples MQO552, 554, 555, 561,
 562,  563,  565, 566, 568, 575,  and  576 should be considered  unreliable due  to  blank
 contamination at similar concentrations.

 1.5   Mercury
                                               i
     No problems were detected with the mercury data.   All mercury results should
 be considered quantitative with an acceptable  probability  of false negatives.

 2.0   Inorganic and Indicator Analvtes

 2.1   Performance Evaluation Standard

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

2.2   Inorganic and Indicator Analvte OC Evaluation

     The  average spike recoveries of  all of the inorganic and  indicator  analytes,
except  for ammonia nitrogen in the  leachate sample,  were within the accuracy  DQOs
(accuracy  DQOs  have not been established for bromide  and nitrite nitrogen matrix
spikes).   The ammonia nitrogen  spike recovery was 114  percent  in the  leachate
sample. The bromide  and nitrite nitrogen spike recoveries were 92 and 100 percent
 in the  ground-water  samples  and 98  and 94 percent in  the leachate sample.   The
recoveries for all inorganic and indicator analytes are acceptable.

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

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

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

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

 2.3   Anorganic and Indicator Analvte  Data

      The QC  standards for cyanide were  not  analyzed in  conjunction  with the
 sample analyses but  were run three  days  earlier.   All cyanide  results  should be
 considered qualitative with an acceptable probability of false negatives.

      Nitrate nitrogen was detected  in the  trip  blank (MQO796)  at  9 ug/L.   As a
 HWGWTF convention, all results  greater than ten times the highest sampling blank
 concentration or  less than the  detection limit  are considered  quantitative  (unless
 there are other problems with the data).  Results  greater  than  five but  less  than
 ten times the highest concentration of sampling  blank contamination are considered
 qualitative  and  all  other data are  considered  unusable.   Therefore,  the  nitrate
 nitrogen results for sample MQO569 should be considered qualitative.  Other results
 are listed below.  The holding times for the nitrate  nitrogen analyses ranged  from 2
 to 6  days from receipt of samples most  of  which are  longer than  the recommended
 48 hour holding time for unpreserved samples.  The final calibration verification (a
 CCV) for nitrate nitrogen (120  percent)  was  above  the  DQO.   The  analytical
 instrument  should have  been  recalibrated  and  the  calibration  reverified  before
 proceeding with the  sample analyses.   Results for  samples  MQO565, 569,  575,  576,
 577,  579, and 580  were affected  and should be  considered to be  biased high.   The
 field  duplicate precision  for one of the  two duplicate pairs  (MQO569/570)  was  poor
 (50 ug/L of  nitrate nitrogen  detected in one sample (the CRDL is 300 ug/L},  1110
 ug/L  detected in  the other).  The  comparative precision  of  the  field  duplicate
 results  is not  used  in  the  evaluation of  sample results as  it is not possible to
 determine the source  of  this  imprecision.  Field duplicate precision  is reported for
 informational purposes  only.  All nitrate nitrogen  results,  with the exceptions of
 sample MQO569 mentioned above  which  should be considered qualitative and  sample
 MQO579 (see sulfate  or chloride comment on this sample) which  should not be used,
 should be considered  to be semi-quantitative.

      The holding  times for  the  nitrite nitrogen  analyses ranged from 2 to 6  days
 from  receipt of samples  which is generally longer  than the recommended 48  hour
 holding time for  unpreserved  samples.   The  laboratory did not  analyze  an initial
 calibration  verification  (ICV)  at  the  beginning  of   the   nitrite  nitrogen  ion
 chromatography analytical batch, as required.  The nitrite nitrogen results should be
 considered to be semi-quantitative except for sample MQO579 which should  not be
 used (see sulfate or chloride comment on this sample).

     The final CCV  for chloride  (336  percent) was above the  DQO.  The analytical
instrument should have  been recalibrated  and the  calibration reverified  before
proceeding with the  sample  analyses.  Results for samples  MQO565, 569,  575,  576,
577, 579,  and 580 were  affected and  should be considered  to  be biased  high.   The
chloride  field duplicate  precision  for  both of the duplicate pairs (MQO569/570  and
MQO578/579) was  poor (280,000  versus 190,000 ug/L in the first  pair and 5900

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versus no  chloride detected in  the  other).   These results were not used in the data
usability  determination as the  results may only be  a reflection of poor  duplicate
sampling techniques.  Field duplicate precision is reported for informational purposes
only.  In the case of the sample MQOS79  from  the second field duplicate pair,  no
ion  chromatography  (1C) analytes  (nitrate  and  nitrite nitrogen, chloride, bromide,
and sulfate) were detected although other inorganic and  indicator elements were.
As the 1C analysis,  for  all five 1C  analytes,  is  performed  on a  sample from a
separate sample  bottle,  this indicates that something was  wrong  with either  the
sampling or  analysis  of this 1C sample.  Chloride was detected in the  trip blank at
a  concentration of 2200  ug/L.   As  a HWGWTF  convention, all  results greater than
ten times  the highest sampling  blank concentration or less than the detection limit
are considered quantitative (unless there are other  problems with the data).  Results
greater than five but less than ten  times the  highest  concentration  of  sampling
blank  contamination  are  considered qualitative  and  all  other data are considered
unusable.  Therefore,  chloride  results for samples MQO5S3  should  be considered
qualitative and results for samples  MQO5S4, 555, 556, 557,  558,  561, and 578  should
be considered unusable.   The chloride  results for  all  other  samples should  be
considered semi-quantitative with the exception of sample MQO579 which should not
be used because of the above mentioned problem with that sample.

     The laboratory  did not analyze an ICV at the  beginning  of  the  bromide  ion
chromatography  analytical batch, as required.   Bromide  was detected in the  trip
blank  at a concentration of 60  ug/L.  As a HWGWTF convention, all results  greater
than ten times the highest sampling blank  concentration or less than  the  detection
limit are  considered  quantitative (unless there are other problems with  the data).
Results greater  than five  but less  than  ten  times  the  highest concentration  of
sampling  blank  contamination   are  considered  qualitative  and  all  other  data  are
considered unusable.  Bromide results for samples MQO553, 562,  578, and 579  should
not  be  used.    The   bromide  results for  sample  MQO567  should be considered
qualitative.  All other bromide results should be considered to be semi-quantitative.

     The final CCV  for sulfate (260 percent) was  above the  DQO.  The instrument
should have  been recalibrated and the calibration, reverified before proceeding with
the sample analyses.  Results for samples MQO565, 569, 575,  576, 577, 579, and 580
were affected  and should be considered  to be biased  high  as  a  result.  The  sulfate
field   duplicate  precision  for  both  of  the  duplicate  pairs  (MQO569/570 and
MQO578/579) was poor (140,000 versus 105,000 ug/L  in  the  first pair  and 180,000
versus  no  sulfate detected in the other).   These results were  not used in the data
usability determination  as the  results may only be a reflection of poor  duplicate
sampling  techniques.    In the  case  of the sample  MQO579 from the  second field
duplicate pair, no ion chromatography  (1C) analytes, including sulfate, were detected
although other inorganic and indicator elements were.  As the  1C  analysis, for  all
five 1C  analytes, is  performed on  a sample  from a separate  sample bottle, this
indicates that something  was wrong with either  the sampling or analysis of this  1C
sample. The  sulfate results, as  mentioned above, should be  considered  quantitative
with the exceptions of samples MQO565, 569, 575, 576, 577, and 580  which should be
considered  semi-quantitative and sample MQO579  which should not be used.

     One of  two ammonia nitrogen  ICVs and two CCVs were outside of DQO. The
ammonia   nitrogen  field  duplicate  precision  for  one  of  the  duplicate  pairs
(MQO569/570)  was poor (35,000  versus 27,000 ug/L).  These results were not used in
the data usability determination as the  results  may  only  be a  reflection of poor
duplicate sampling techniques.   All  ammonia  nitrogen results  should  be considered
semi-quantitative.

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      Total phenol contamination was found in one of the field blanks (MQOS77) and
 the trip  blank (MQO796) at concentrations  of  20 and  96  ug/L.  These values are
 above the  total  phenol CRDL  of  10 ug/L.  Based  upon HWGWTF conventions, all
 total  phenols results  greater  than  10 times  the  highest concentration  of  total
 phenols  in  the  sampling blanks  or less  than  the detection limit are. considered
 quantitative.  This includes samples MQOSS4, 555, 557, 558, 559, and  560.  All  total
 phenols  results greater  than  five  but less  than  ten  times the highest concentration
 of sampling blank contamination  are considered qualitative and all other data are
 considered  unusable.    Total phenols results for all other  samples  (than the six
 mentioned above) should not be used.

      One of two field  blanks (MQO560) contained TOC at a concentration of  1200
 ug/L which is above the CRDL of 1000 ug/L.  Again, as a HWGWTF convention, all
 TOC results greater that ten times the  highest  field  blank  concentration or less
 than the  detection limit should be considered quantitative.  TOC results for samples
 MQO553, 559, 563, 568,  569,  570,  577, 580, and  796  should  be, therefore, considered
 quantitative.  All TOC results greater than five but less than ten times  the highest
 concentration  of sampling blank  contamination are considered  qualitative and all
 other data  are considered unusable.  The TOC results for samples MQO557, 561, 562,
 565, and 576 should be considered qualitative, and all other TOC should not  be used.

      ICV and CCV standards for POC were not  analyzed.  A POC spike solution was
 run twice  during the  analytical  batch but  the "true"  value of the spike was not
 provided  by  the laboratory.  EPA needs to  supply the inorganic laboratory with a
 POC calibration  verification solution. Until  then, the instrument calibration can not
 be assessed.   One  of  two  sets  of field  duplicates  (MQO569/570) showed  poor
 precision  with  POC  concentrations of no POC  reported and 380  ug/L.   The
 comparative precision of the field duplicate  results is not used in the evaluation of
 sample data as it is not possible to  determine the source of this imprecision.   Field
 duplicate precision  is  reported for  informational purposes only.  The POC results
 should be considered qualitative.

      The TOX analysis was run over a period of five  days.  Final CCVs and  final
 CCBs were not run at the end of each days'  analytical batch. From the  information
 on the laboratory work sheets it was not clear whether an ICV and a ICB  were run
 at  the beginning of one of the five day's  analytical batches.  Sample MQO580, the
 leachate sample, contained a high concentration of  chloride (690,000 ug/L) which
 may  have enhanced the TOX results for this  sample.   The results of one pair of
 field duplicates (MQO569/570) showed poor precision with TOX concentrations of 54
 and 71 ug/L.  The comparative  precision of the  field duplicate results is not used in
 the evaluation of sample data as  it is  not possible  to determine the source of this
 imprecision.  Field duplicate precision  is  reported for  informational purposes  only.
 The TOX results should be  considered quantitative  except for  the samples where
 insufficient  calibrations were performed.    Samples  with  insufficient  calibrations
 include MQO552, 554,  556, 557, 560, 563,  568,  577, and 579 and  results  for these
 samples should be considered semi-quantitative.

     One  of  the two  sets of  POX field  duplicates (MQO569/570) showed   poor
 precision  with no POX  detected in one sample  and  15 ug/L  detected in the other.
 The comparative  precision of  the field duplicate  results is not used in the evaluation
 of  sample  data as it  is  not  possible to determine the  source of  this imprecision.
 Field  duplicate precision is reported for informational purposes  only. The holding
times  for samples MQO553 and 554 was  eight days which exceeded the recommended
holding time of seven days.   POX results should be considered quantitative except
for samples  MQO553 and 554 which should be considered semi-quantitative.

-------
 3.0   Organics and Pesticides

 3.1   Performance Evaluation Standard

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

 3.2   Organic OC Evaluation

      AH matrix spike average recoveries  were within established Program DQOs for
 accuracy.  Individual matrix spike recoveries'which  were outside the accuracy DQO
 will  be  discussed  in the appropriate Sections  below.   All surrogate  spike  average
 recoveries were within DQOs  for accuracy with  two exceptions.   Surrogate spike
 recoveries  which  were  outside  the  accuracy  DQO will  be  discussed  in  the
 appropriate Sections  below.

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

      All organic analyses were performed as requested.

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

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

 3.3   Volatiles

      Quality control data indicate that volatile  organics were determined  acceptably.
 The chromatograms  appear  acceptable.  Initial  and  continuing calibrations,  tunings
 and  mass calibrations,  blanks,  matrix  spikes  and matrix spike  duplicates, and
 surrogate spikes are acceptable.

      Estimated  method  detection limits  were CRDL for all samples except  QO580,
 the  leachate  sample, which  was  15  times  CRDL.   Dilution  of this sample was
 required.

      Laboratory blank  #860809, analyzed  on  8/9/86,  was  analyzed prior   to  the
 continuing  calibration  standard.   This  did not  affect  the  results of  the data
 evaluation.

     The  volatiles  data are acceptable.   The  volatile compound  results  should be
 considered quantitative  with the exception of  the leachate sample  (QO580)  which
 should be  considered semi-quantitative  due  to an  increased  probability of false
 negative  results. The probability of false  negative  results  for all  other  samples is
 acceptable.

 3.4   Semivolatiles

     Initial and continuing calibrations, tuning and mass calibrations, blanks, holding
 times,  and chromatograms  were  acceptable  for  the  semivolatiles.   Some problems
were encountered with matrix spike/matrix  spike duplicate recoveries and surrogate
recoveries.

-------
     Contamination  was  detected   in   three   laboratory  blanks   (GH09623A21,
 GH095850C21, and GH09SS23C21).  The blanks contained di-n-butylphthalate at less
 than the CRDL.

     The matrix  spike  duplicate  (MSD)  recovery  of 4-nitrophenol  (9. percent)  in
 sample QOS78  was  below the DQO of  10 to  80  percent.   The relative  percent
 differences (RPDs) between  matrix spike and  MSD  recovery of 4-nitrophenol  in
 sample QOS78 and phenol in sample QO563 were above DQO.

     The  surrogate  percent  recoveries  fqr  phenol,  2-fluorophenol,  and  2,4,6-
 tribromophenol  in sample QOS62 (no recovery for  any of  the three  acids)  and for
 phenol and 2-fluorophenol in sample QO562RE (reextracted sample, 8 and 6 percent
 recoveries) were below their respective DQOs.

     The semivolatile  data  are acceptable  and the  results  should   be  considered
 quantitative   for  all  samples except  QO580  which  should  be  considered  semi-
 quantitative  due  to  increased probabilities  of  false negatives and for the  acid
 fraction  results  for sample QOS63 which should be considered unreliable due to poor
 acid recovery.  Estimated method  detection  limits are twice CRDL  for all  samples
 except QO580 which is   10 times CRDL.   The probability  of false negatives  is
 acceptable for  all samples with  the exception  of QOS80  due to raised detection
 limits caused by dilution where the probability of false negatives is increased.

 3.5   Pesticides

     The initial  and continuing  calibrations,  blanks,  matrix spike/matrix  spike
 duplicates, surrogate  spikes, and  holding times for pesticides were acceptable.  Some
 of  the pesticide  chromatograms  appear  to  contain  non-pesticide or unidentified
 peaks.

     The estimated method detection limits for the  pesticides  fraction were CRDL
 for all samples.   The pesticides  results  should be considered qualitative.  There is
an  enhanced  probability  of  false  negatives  (unfecovered pesticides  in the  sample)
based upon the clean-up method used  by the laboratory.

III.  Data Usability Summary

4.0  Graphite Furnace Metals

Quantitative:        all total and dissolved antimony, cadmium, and thallium results;
                    all  dissolved  lead,  selenium,  and  arsenic (except  MQO570)
                    results
Semi-quantitative:    all total arsenic and lead results
Qualitative:         all total selenium results
Unreliable:          dissolved arsenic results for sample MQO570

4.1   1CP Metals

Quantitative:        all  beryllium,  cobalt,  copper,  manganese,  nickel,  potassium,
                    sodium,  vanadium, and zinc results; aluminum, barium, calcium,
                    chromium, iron, magnesium, and  silver results with  exceptions
                    listed below
Semi-quantitative:    dissolved  iron,  magnesium,  and silver  results  for  sample
                    MQOS80 (leachate sample);  all dissolved  barium, calcium,  and
                    iron  results  except for sample MQO580; total chromium  results
                    with exceptions listed  below

-------
Qualitative:


Unreliable:


4.2  Mercury
total silver  results  except for sample  MQOS80; total  aluminum
results for sample MQOS80;  dissolved aluminum results for all
samples except MQO580
total chromium results for samples MQOSS2, 554, 561, 562, 565,
563, 566, 568, 575, and 576
Quantitative:        all mercury results

4.3  Inorganic and Indicator Analvtes
Quantitative:
Semi-quantitative:
Qualitative:
Unreliable:
Unusable:
4.4  Oreanics
Quantitative:
Semi-quantitative:
Qualitative:
Unreliable:
sulfate, TOX, and POX  results  with exceptions; total  phenols
results for samples MQO554,  555, 557, 558,  559, and 560; TOC
results for samples MQO553,  559, 563, 568,  569,  570, 577, 580,
and 796
all   ammonia  nitrogen  results;  bromide,   chloride,  nitrate
nitrogen,  and nitrite nitrogen results with  exceptions; sulfate
results for samples MQO565,  569, 575, 576,  577,  579, and 580;
TOX  results  for samples  MQO552, 554, 556, 557,  560, 563, 568,
577, and 579; POX results for samples MQO553 and 554
all POC results;  chloride results for sample  MQO553; nitrate
nitrogen results for sample MQO569;  bromide results for sample
MQO567;  TOC results for samples MQO557, 561,  562, 565, and
576
all cyanide results
all ion  chromatography  (nitrate  and nitrite nitrogen, chloride,
bromide,  and sulfate)  results  for  sample  MQO579;  chloride
results for samples MQO554,  555, 556, 557,  558,  561, and 578;
bromide  results  for samples  MQO553,  562,  and  578;  total
phenols and TOC results with exceptions
                             sample  QO580;  all scmivolatile
                             and the acid fraction  of sample
all  volatiles  results except
results except sample QO580
QO563
volatile and semivolatile results for sample QO580
all pesticides results
semivolatile acid fraction results for sample QO563
IV.  References

1.    Organic Analyses:

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

-------
     Inorganic and Indicator Analyses:

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

2.    Draft Quality Control Data Evaluation Report (Assessment of the Usability of
     the Data Generated)  for  site  4IB, Land  Reclamation,  Wisconsin, 11/4/1986,
     Prepared by Lockheed Engineering and Management Services Company, Inc., for
     the US EPA Hazardous Waste Ground-Water Task Force.

3.    Draft Inorganic Data Usability Audit Report and Draft Organic Data Usability
     Report, for the Land Reclamation, Wisconsin site,  Prepared by  Laboratory
     Performance Monitoring Group, Lockheed Engineering and Management Services
     Co., Las Vegas, Nevada, for US EPA, EMSL/Las Vegas, 11/4/1986.

V.   Addressees

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

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

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

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

James Adams, Jr.
Quality Assurance Office
US Environmental Protection Agency
230 South Dearborn Street
Chicago, IL 60604

John McGuire
US Environmental Protection Agency
230 South Dearborn Street
Chicago, IL 60604

-------
Brian Lewis
c/o Department of Health Services
1219 K Street, First Floor
Sacramento, CA  95814

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

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

-------
              APPENDIX  1

Contract Required Detection Limits and
Instrument Detection Limits for Metals,
  Inorganic, and Indicator Parameters
                 Al-1

-------
                                TABLE Al-1

             CONTRACT REQUIRED DETECTION LIMITS AND INSTRUMENT
     DETECTION LIMITS FOR METALS, INORGANIC, AND INDICATOR PARAMETERS
Parameter
Metals
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Inorganic and Indicators
Ammonia nitrogen
Bromide
Chloride
Cyanide
Nitrate nitrogen
Nitrite nitrogen
POC
POX
Sulfate
TOC
TOX
Total Phenols
CRDL

200
60
10
200
5
5
5000
10
50
25
100
5
5000
15
0.2
40
5000
5
.10
5000
10
50
20

100

1000
10
300

10
5
1000
1000
5
10
IDL

100
3
6
4
4
0.5
93
8
16
12
10
2
238
3
0.2
20
2160
3
10
156
5
21
12

100
50
1000

300
50
100
5
500
1000
5
10
concentrations are in yg/1
                                   Al-2

-------
                                APPENDIX 2

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

Sample numbers are designated by the organic and corresponding inorganic
sample number.  Organic sample numbers are preceded by the prefix "Q;"
inorganic sample numbers are preceded by the prefix "MQO."
                                   A2-1

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

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

B    This flag is used when the analyte is found in the blank as well as
     a sample.  It indicates possible/probable blank contamination and
     warns the data user to take appropriate action.
GW « ground-water
SW * surface-water
low and medium are indicators of concentration.
                                   A2-2

-------
  SITE:    MI* LANP RECLAMTIM* vi
  CASE mi   6277-L-1944HO

  SANPLE w:
  SAMPLE LOCATION:
  SAKPLE TYPE:
W560/JWC560  fl0577/«90377   B055?/«0re5?   Q07W/MQ07W
                                                          KLL 40U
FIELT MJC     FIDJ« ILK      EWIP, PJf     TRIP BLK       WPLICATE
  VW    TOLUENE
         ACHONE
         lETHTLEffi CHLORIK
         2-BUTMONE
         KKZEHE
         Irl-DICHLOROETHWC
         Mfl-TRICHLOROETHAfE
         TETRACHLOROETffiHE
         TRAHS-1 »2-DKHLOROETffiNE
         TRICHLOROETHENE
         4-OHYL-2-PEKTANONE
         ETHYL BENZENE
         XYLENES

  SEHI-   PHENOL
  WW     *!S(2-£THYLOrL)PHTHALATE
         PIETHYLPHTHALATE
         n-#-FUTYL PHTHALATE   '
         2HETHYLPHENOL
         4HETHYLPHENOL
         2»4-IIIMETHYLPHENOL
         NAPHTHALENE

 PEST/   PIEURIN
 PCB     4-4 '-TOP

 TIC-    TETPJ«YIIROFURAN
 VOA     KETHAH£> TRICHLOROTLUORO
         UNKNOUN

 TIC-    ETHANE? M-OXYBIS
 SEMI-   BEKZENEf 1.2-MOHYL
 VOA     BEKZENEr li3-PIfETHYL
         BEN2ENEACETIC ACIB
         PHENQLf TETRA«ETHYLBUTYL
         2-fRDPANOLrfETHOXY SUBSTITUTED
         OANOIC ACID
         HEXANOIC ACIP» METHYL SUBST,
         OCTAttJIC ACIP
        BEK2ENEPROPAWIC ACID
        1MNOUN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        mourn
        UNKNOWN
        UNKNOWN
        UNKNOWN
        tMNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
                      1.7 J
                      2.2 J
1.7 J
                7 J


              2.B J
                                                                 2,2 J
                                                        I (PUR W2) 11J
                                                                 25 J
                                                                 20 J
ALL CONCENTRATIONS IN U2./L
                                                         A2-3

-------
ro
                                 -Ifc'S
r» rj t-» r>

t«* j5 P S
je o n *
M
*-«
S
                                                                                                   S         =38
                                                                                                   »-*»-•     3c  so »-« m
                                                 3 S 2 8

                                                 f^ S »-4 »-*
                                                               -
                                                          •— I^M
                                                          »- JJ
II
                                                                                                             l/l
                                                                                                             S
                                IO '—

                                !t o
                                                              2
                                           »>.
                                                                                                                                                                                                                 »•»
                                                                                                                                                                                                                 e
                                                                                                                                                                                                                 s


-------
SITE:    MIF LAM*
CASE NO:  6277-L-l»44HB
                               HI
SAWPLE NO:
SAW! LOCATION:
SAHPLE TYPE:
SODIUM
TWLLIIW
VANADIUM
ZINC-
IN9R6. AfttONlA NITROGEN
-INPIC. IR0MIDE
CHLORIDE
CYANIDE
NITRATE NITROSEN
NITRITE NITROGEN
PO:
WX
SULFATE
TOC
TOTAL PHENOLS
TOX
CARBONATE
BICARBONATE
QD560/HQOSM
FIELIIKJC
502












1200




B0577/HQ0577 QK59/WOG55?
FIEU ILK EQUIP. ILK
1 535 1 465
1
1
1
1
I
1
1
1
1
1
1
1
1
20 1
1
1
1
W7W/HQ0796
TRIP ILK
733




60
2200

9





96



D056?/HQ056?
VELL m
DUPLICATE
36*000 1
-

72
35000
4800
280000

50



140000
41000
105
54


ALL CONCENTRATIONS IN uS/L
                                                         A2-5

-------
  CASE NO!  6277-L-1W4HO
SAffLEMOJ
SAMPLE LOCATION:
SAMPLE TYPE!
VOA TOLUENE
ACHONE
HETHYLENE CHLORIDE
2-BUTANONE
BENZENE
Ifl-MCHLDRDETHANE
Itlil-TRICHLOROETHANE
TETRACHLOROETHENE
TRANS-1.2-DICHLOROETHENE
TKICHLOROETHENE
4-HETHYL-2-PENTANONE
ETHYL BENZENE
XYLENES
SEMI- PHENOL
VOA BIS(2-£THYLHEXYL)PHTHALATE
DIETHYLPHTHALATE
rUf-BUTYL PHTHALATE
2-METHYLPHENDL
4-HETHYLPHENOL
2f4-DIMETHYLPHENOL
NAPHTHALENE
PEST/ ME3JRIN
PCB 4H'-DDD
TIC- TETRAHYPROFURAN
VDA H£THAN£j TRICHLOROFLUORO
UNKNOWN
TIC- ETHANEf 1»!-OXYBIS 1
BEffl- BENZENEf lf2-DIKETHYL
WA BENZENI. 1»3-MKETHYL
BENZENEACETIC ACID
PHENOL* TETRA«ETHYLJilITYL
2-PROPANOLrMETHOXY SUBSTITUTED
HEXANOIC ACID
HEXANOIC ACIDr METHYL SUBST.
OCTANQIC ACID
BEHZENEPROPANOIC ACID
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
M570/HW570
VELL 40U
WPLICATE


























(PUR 9£5) 12J









7 J
It J










BC57B/HOOS78
VQ1 40L
WPLICATE
















































KJ579/HQ057?
VELL 40L
WPLICATE


























§





















K?552/f«!522
VELL 61
GV-LOV
















































K553/WKS53
VELL 61)



""












































ALL CONCENTRATIONS IN uS/L
                                                       A2-6

-------
KJ


•vl
*— » in
        Ml


        I
          to
        s

        »— 10
        Jk 0

                                 5


                                  •*•  M **
                                  !8  Q W

                                                        K,

                                            «
                                                                                             @;
                                                                                           P
!*
2§
?1?!
                                                                                          ?gi5
                                                                                          i^

-------
  SITE:    HIP LAW RECLAMATION* HI
  CASE »:  A277-1-1944HQ
SAMPLE NO!
SAMPLE LOCATION:
SAMPLE TYPE:
B0570/MQ0570
HELL 400
DUPLICATE
fl0578/fW057e
HELL 40L
DUPLICATE
HELL 40L
DUPLICATE
90552/WQ0522
HELL 6L
6«KOU
HELL 6U
W-LW
         somufl

         THALLIIW
         VMMDItW
         ZINC.

  INORG.  AWONIA NITROGEN
  INPIC.  BROHIDE
         CHLORIDE
         CYANIDE
         NITRATE NITROGEN
         NITRITE NITROGEN

         POC
         POX
         SULFATE
         TOC
         TOTAL POOLS
         TOX

         CARBONATE
         BICARBONATE
I      2194000   I
          63

       27000
        4700
      190000

        1110
         260
          15
      1050W
       34000
         105
          71
 two    i
   212

   120
    70
  5900
                        50
180000
  2600
    4B
96100   I



   64

  200
 2700
   SB
 21100   I



    18"



 36000

   480
 27300   I
207000
  3500
    60
     7
                                100
                              9000
240000
 12000
    36
     7
:- ALL CONCENTRATIONS IN uS/L

-------
SITE:    *4i* LAN? ECLA«ATIW> HI
CASE «:  £277-i-l«44HO

SAfflE KO:                            W554/«K554
SAfni LOCATION:                      HELL mi
SAMPLE TYPE:                          BHW
                                                    OQ535/MQ535
                                                    HELL 2w
                                                    6V-UW
      HELL 14U
      BH.W
HELI 14L      HELL »L
              6V-LPW
 VM    TOLUEfC
        ACETOHE
        «ETHYL£« CHLORIDE
        2-KJTAtWttE
        PEKZEffi
        lil-DICHLOROETHANE
        1»1»1-TRICHLOROETHAHE
        TETRACHLOROETI€NE
        TRANS-1 .2-PICHLKOETIQE
        TRICHLOROETHEHE
        4-flETHYL-2-PEHTANO«E
        ETHYL BEHZEME
        XYLEHES

 SEMI-   PHENOL
 VOft    BISC2^THYLHEXYL)PHTHALATE
        PIETHYLPHTHALATE
        DI-K-BUTYL PHTHALATE
        2-tOHYLPHEWJL
        4-HETHYLPHENOL
        2>4-MHETHYLPHENOL
        NAPHTHALENE

 PEST/   PIEURIN
 PCB    4-4 '-HDD

 TIC-    TETRAHYIifiDFURAN
 m    HETHAKtf  TRICHLDKFLUORO
        UNKNOWN

 HC-    ETWrfE.  1,1-OXYBIS
 SE»-   KGENE*  1»2-PI«£THYL
 VOA     BEK2EN£»  1.3-MHETHYL
        BEHZEfEACETIC ACIB
        PHENOLf TETRAJETHYLBUTYL
        S-PWPAfffiL.IETHOXY SUPSTITlfTO)
        otfioic  A:IP
        HEXANOIC  ACIDi METHYL SUBST,
        OCTANDIC  ACIB
        BEHZEKEPROf A«IC ACID
        UNKKOUN
        UNSOWN
        UNKNOVN
        UNKNOWN
        UNKNOWN
        UNSOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
        UNKNOWN
15 J
                            9.8 J
                            4.6 J
ALL CONCENTRATIONS IN ufi/L
                                                         A2-9

-------
  SITE:    HI* LAW KCLAMTIM. HI
  CASE NO!  6277-1-1944HO
CAMP* r wn«
•Mil! LL HUt
SAMPLE LOCATION:
SAMPLE TYPE:
W554/H80554
KLL 106L
W-LOW
90555/MQKS
KLL 29U
RH.W
fiK56/«Q0556
KLL 14U
BH.W
WELL 14L
BKOV
K55B/HW558
IS129L
RH.OW
         UNKNOWN
 TOTAL
 KTALS  ANTHKWY
         tfSENIC
         mm
         lERYLLIlW

         CAMIUM
         CALCIUM
         CHRONIUH
         COBALT
         COPPER

         IRON
         LEAP
         HAGNESIUM
         NANGAftESE
         OCURY

         HICKEL
         POTASSIUM
         SELENIUM
         SILVER
         somuM

         THALLIUM
        VANADIUM
        ZIN:

HIS     ALLWHUM
KHALS  A«TI«0«Y
        ARSENIC
        BARIUM
        BERYLLIUM

        CA9MIUM
        CALCIUM
        CHROMIUM
        COBALT
        COPPER

        IRON
        LEAD
        MA5NESIUM
        MANQAKESE
        NICKEL
        POTASSIUM
        SELENIUM
        SILVER
1B700


123


97500
34


10900
12.4
51300
30B

3940
11400

42


332
71200
21

24
3B100
37
2120
20000

13.4
352


391000
45
25
46
36000
19,2
219000
1400
62
9860
24BOO
4B
172


244
141000
27


104000
345
2970
156000

27,6
751
6
0,7
422000
195
56
107
152000
ioe
231000
1960
172
41000
15600
242
' 406

6,3
247
68400
20


41BOO
154
4010
89000

16,4
462
3

44BOOO
102
36
54
76100
66
254000
2310
Bl
20400
46100
114
IBS
156

328
31900

11
57
15000
63
1B90
1 66600
1
29
404
3

1160000
«7
40
E3
101000
51
560000
4750
109
23600
21100
135
262

6,4
250
22100
10


25300
10
34BO
ALL CONCEHTRATIWS IN us/L
                                                        A2-10

-------
  SITE:    MIP uw* RECLAMATION.
> CASE WJ  6277-L-1944HQ
SAMPLE NO:
SA#t£ LOCATION;
SAJHI TYPE:
SODIUM
VANADIUM
ZINC-
INORG, ANHOHIA NITROGEN
•INMC, PROMDE
CHLORIDE
CYANIDE
NITRATE NITROGEN
NITRITE NITROGEN
POC
POX
SL'LFATE
TOC
TOTAL PHENOLS
TOX
CARBONATE
BICARBONATE
«0554/»Wre54
VEII mi
64H.OV
14900

272


2100





30000
4500

21


KBS5/HK3S5
WELL 29U
W-LW
1 21600




6700



1900
9
35000
2800




K556/HK556
WELL 141'
13SOO

lie
300

5300





70000
3900
10
8.8


B5537/HOOS57
VEii 14L
51400

242"
200

800





30000
7400

6.3


BC558/H0055B
W129L
9H.W
31500 1

65
400

1300





7100
3700

8.2


  ALL CWCENTRATIDNS IN «s/L
A2-11

-------
 •  SITE!    *41F LAW RECLAHATIW,
a  CASE HO!  *277-L-1944HQ
sm£ M:
SAMPLE LOCATION?
SAMPLE TTPE:
VOA . TOLUEKE
ACETONE
METHYLEKE CHLORIK
2-IUTANONE
BENZEHE
Ifl-MCHLDROETHANE
Ifl.I-TRICHLOHETHANE
TETRACHLDROETHENE
TRAKS-1 »2-PICHLOROETHENE
TRICHLDRDETHENE
4-METHYL-2-PENTANONE
ETHYL BEKZEKE
XYLEfES
SEMI- PHENOL
VOA I!S(2-ETHYLH£XYL)PHTHALATE
BIETHYLPHTHALATE
M-K-BtJTYL PHTHALATE
2-METHYLPHENDL
4-METHYLPHENOL
2»4-I!IMETHYLPHENOL
HAPHTHALEHE
PEST/ PIELMIN
PCB 4-4 '-DDK
TIC- TETRAHYMOFURAN
VOA HETHA«E» TRICHLOROFLUORO
wmm

TIC- ETHA»E» hl-OXYBIS
SEMI- JEKZEHEf 1.2-JIMHHYL
VOA JECDSf 1J3-MMETHYL
FEHZENEACETIC ACID
PHEWLf TETRAJETHYLBIJTYL
2-PROPAWLfKETHOXY SUPSTITUTED
HEXAMOIC ACID
HEXANOIC ACID» METHYL SUBST,
OCTAWJIC ACID
BEHZEHEPROPANOIC ACID
wmm
IMNOUN
IMNOUN
WKHWN
wmw
WK.MWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
B0561/M00561
HELL 30L
&H.OU














2.4 J









(PUR 943) * J

























Q3562/MQ05i2
HELL 110U
&H.OV





































31 J
34 J











B05£3/MQfl5i3
HELL 3?U
W-LW
12
48


10
2 J

13
11
8.6
6.5 J
14
70
52



4.8
21
28
2.2 J
12
15
(PUR ?21) 1BJ

11 J
t

KPUR B68) 24J
(PUR ?24) 2?J
(PUR 884) 47J
(PUR 883) 27J
(PIR912) 11CJ




140 J
17 J
25 J
28 J
96 J
23 J
15 J
21 J
1? J
14 J
20 J
410 J
17 J
60565/M0545
HELL 9U
6*HW



_












5,6 J

































W5WHOC566
HELL 10U
6H.OV


3 J


































































































   ALL CONCENTRATIONS  IN ug/L

-------
                                                                                                     '-}
i    gg^
Si      ss
         if
                          S
                          "

                                        i
                                            ts
                                            a
                                                      3 J3 13 3
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                              so — t •— = S


                                                       CM
                53
                                                                   oiio -vi *.
                                                                   c«4 O •  ^
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53
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a

                                                                                                                  *
!•  I

-------
SITE:
CASE W!  6277-L-1944*

SAMPLE in:
SAJPLE UJCATION:
SAHPLE TYPE:
                                vi
                                       KJ561/«fl0561   KJ562/NQ0562   QC563/tffl0563   W565/WC565
                                       «EU SOL       HELL 110U      WELL 39U       YELL  91!       KLL  10U
                                       ftKW         G*-LDV         RKW         &H.W         ftHW
 INORG.
 INPIC.
SODIUH

THALLIUM
VAMAIIUft
ZINC

AHHONIA NITROGEN
BROHIPE
CHLORIDE
CYANIDE
NITRATE NITROGEN
NITRITE NITROGEN

PO:
POX
SULFATE
TOC
TOTAL PHENOLS
TOX

CARBONATE
BICARBONATE
                                       I
                                            33800
30300   I
10200   I
                                                                                         66300
                                                                                                       26300   I
1
1
1 155
1 200
1
1 1200
1
1
1
I
1
1 2BOOO
1 6600
1 10
r
i
i


73
110
BO .
42000





126000
5500
20
15


499
24000
2200
100000
63


6700
62
4300
67000
272
99


99-
3800
3100
152000

1320



315000
9200
100
20
v

202
1600
5100
47000

2200



43BOOO
1100
15
14
ALL CONCENTRATIONS  IN us/L

-------
SITE: MI* LAW RECLAMATION, vi
CASE NO: 6277-L-1944HC
SAMPLE «:
SAMPLE LOCATION;
SAMPLE TYPE:
VOA TOLUENE
ACETONE
METHYLENE CHLORIDE
2-WTANONE
BENZENE
1.1-DICHLOROETHANE
1.1.1-TRICHLOROETHANE
TETRACHLOROETHENE
TRANS-1 .2-DICHLOROETHENE
TRICHLOROETHEHE
4-METHYL-2-PENTANONE
ETHYL BENZENE
XYLENES
SEMI- PHENOL
VOA BISC2-ETHYLHEXYDPHTHALATE
PIETHYLPHTHALATE
DI-K-BITYL PHTHALATE •
2-MTTHYLPHENDL
4-METHYLPHENDL
2.4-PIMETHYLPHENOL
NAPHTHALENE
PEST/ DIELDRIN
PCI 4-4 '-BDP
TIC- TETRAHYKDFURAN
VOA METHANE. TRICHLOP.OFLUORO
UNKNOWN
TIC- ETHANE. 1.1-OXYPIS
SEMI- BENZENE. 1.2-DIMETHYL
VOA BENZENE. l.MIMETHYL
BEKZENEACETIC ACID
PHENOL. TETRAJCTHYLBUTYL
2-PROPAN9L.METHOXY SUFSTITUTEII
HEXANOIC ACID
HEXANOIC ACID. METHYL SUBST,
OCTANQIC ACID
BEKZENEPROPANOIC ACID
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN

UNKNOWN
Uruultnrri

UNKNOWN
UNKNOWN

UNKNOWN
UNKNOWN

UNKNOWN
UNKNOWN
UNKNOWN
KU 22L
GV-LOU














2,4 J































KLL22U
6W-LOW














4 J
















10 J














KJ575/HQ0575
NELL 109U
6W-LOW














2.4 J











'




12 J
61 J














B576/MW376

10


*











2 J














1
1
I
!














Q05eO/W£580
LEACHATE
1000
2100
230
2200

220
53 J

210
4teA V
210
ion
• •»v
420
190
110
25 J
14 J
• ' W
31 J
B50
12 J
16 J








PUR911) 620J

PUR919 10500J
PUS958 10500J
PUP. 854 4700J
PUR 904 2600J
4400 J
2700 J
1?00 J
320 J

440 J
140 J
• TV W
*.. to
t 1 ft 1
AAV J
76 J
B70 J

140 J
•14 l
71 J
120 J
ALL CONCENTRATIONS IN ua/L
                                                      A2-15

-------
s

1
g
        K
                a
                                             3? •=»
                                             QK
                                             ft
                                                             3 2E
                                                             o *~*
                                          f-»
                                          Jo
                            s
                       *§   !J
                                  tjj
                                  «3l
                                  <>J
                                                        KJ
                                           »
a

co *^
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»-•
•^| ** r=> fO *9 »-» t>»
•^ k^ ^S u» *2 *^ ^
^^ to "^ ^^ ^^ ^^ "^^
>-*
m '£
m '£ tn S oJ o ^1
•-• O. M M »"•
IO Ul ^1 »-* «> •*• **
[x b|°'^4''J K*S «9 0
!» c*>i a *w o *^l
• o i3 •*» --j S> -•>• >^5 •» ~>»
•» ^ >-* t^ ^ «^ tJI t3 «^ «»
                                                                                             y
                                                                                                           5
                                                                                                             t  \.

                                                                                                           3
                                                                                                     |*S
                                                                                                     8Mi
                                                                                                     0
                                                                                                     SE »—

-------
•    SITE:    MII LAW RECLAMATION.
;    CASE NO!  4277-l-l»44HQ
SAMPLE NO:
SAMPLE LOCATION:
SAMPLE TYPE:
SODIUM
VANADIUM
ZINC'
.INOR6, AMMONIA NITROGEN
INPIC, BROMIDE
CHLORIDE
CYANIDE
NITRATE NITROGEN
NITRITE NITROGEN
POC
POX
SULFATE
TOC
TOTAL PHENOLS
TOX
CARBONATE
BICARBONATE
Q0567/HQ0567
HELL22L
6V-LW
1 72400

60

300
37000




115000
3500
24
12


Q0568/MQQ56S
HELL 22U
OH.OU
1 235000

128
1200
6000
400000




165000
21000
35
34


Q0575/MB0575
HELL 1091)
OHM
1 13900

75
BOO

53000




145000
3000

7


SV-LW
1 23100

25
200

150000
ioeo
260
100

4B8000
BOOO
58
14


M5BO/MQKBO
LEACWATE
1 625000 1


145000
B500
Hw W
690000


4700

16000
72BOOO
1100
790


  ALL  CONCENTRATIONS IN us/L

-------
              APPENDIX  1

Contract Required Detection Limits and
Instrument Detection Limits for Metals,
  Inorganic, and Indicator Parameters
                 Al-1

-------
                                TABLE Al-1

            CONTRACT REQUIRED DETECTION LIMITS AND INSTRUMENT
     DETECTION LIMITS  FOR METALS,  INORGANIC,  AND INDICATOR PARAMETERS
Parameter
Metals
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Inorganic and Indicators
Ammonia nitrogen
Bromide
Chloride
Cyanide
Nitrate nitrogen
Nitrite nitrogen
POC
POX
Sulfate
TOC
TOX
Total Phenols
CRDL

200
60
10
• 200
5
5
5000
10
50
25
100
5
5000
15
0.2
40
5000 .
5
10
5000
10
50
20

100

1000
10
300

10
5
1000
1000
5
10
IDL

100
3
6
4
4
0.5
93
8
16
12
10
2
238
3
0.2
20
2160
3
10
156
5
21
12

100
50
1000

300
50
100
5
500
1000
5
10
concentrations are in vg/1
                                   Al-2

-------
                                APPENDIX 2

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

Sample numbers are designated by the organic and corresponding inorganic
sample number.  Organic sample numbers are preceded by the prefix "Q;"
inorganic sample numbers are preceded by the prefix "MQO."
                                   A2-1

-------
'v, , v ;>.-, ft ••*»-,
                                    TABLE KEY
        Value without a flag indicates a result above the contract required
        detection limit.                                         "  '

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

   B    This flag is used when the analyte is found in the blank as well as
        a sample.  It indicates possible/probable blank contamination and
        warns the data user to take appropriate action.
   CW * ground-water
   SW • surface-water
   low and medium are indicators of concentration.
                                      A2-2

-------
SITE:    » REOJWATIW* vi
CASE WJ  627M-1»44HQ
SA*LI NO:
SWPIE LOCATION!
SAMPLE TYPE:
Q0560/HK560   B0577/KKJ577   W35'/«B55?   07M/MB7M

FIELT ILK     FIEU H.K     EQUIP, KJC    TRIP UK
                                                                                             Rii 40U
                                                                                             MPLICATE
VOA     TOLUEffi
        AKTWC
        K7HYL£« CHLORIK
        2-IUTAHOKE
        KKZENE
        IfJ-JIDtOROETHANE
        IJil-TRICHLOROtTHAtE
        THRAWLOROETJCKE
        TRAKS-JiMIICHLDROETHEKE
        TRIDLDROHHENE
        4-OHYL-2-PE»fTANDfE
        ETHYL BEHZEHE
        XYLEffiS

SBB-   PHENOL
VOft     PIS(2-rrHYLJEXYL)PHTHALATE
        METHYLPHTHALATE
        W-ff-BUTYL PHTHALATE   '
        2-KTHYLPtOIOL
        4-HTrHYLPHEHOL
        2f4-PINETHYLPHENOL
        NAPHTHALENE

PEST/   PIELUPJK
PCB     4H'-MIIt
TIC-
VOft
TIC-
SEUI-
VOA
       GTHA»£» TRICHLOROrLUORO
       IMNOtfN

       ETHAHEr M-OXYBIS
       BEKZENEf li2-PieTHYL
       BECENE* lf3-WHETHYL
       BEHZEfEACEflC ACI5
       PHENQLt TETRAHETHYUinTL
       2-PROPANOLfKTHOXY SUPSTITirrEB
       OANDIC ACID
       H£XA«OIC ACIP. METHYL SVBST,
       OCTANOIC ACID
       BEKZEtEPROPAHOIC K.
       UNKNOWN
       UNKNOWN
       UNKNOWN
       UNKNOWN
       UNKNOWN
       UNKNOWN
       UHKHOWN
       UNKNOWN
       UMK.U.OWN
       UNKNOWN
       UNKNOWN
       UNKNOWN
       UNKNOWN
                                                          1.7 J
                                                          2.2 J
                                    1,7 J
                                                    7 J


                                                  2,8 J
                                                                                                    2.2 J
                                                        I (PUR M2) 11J
                                                                                                      25 J
                                                                                                      20 J
ALL CONCENTRATIONS IN tS/L
                                                        A2-3

-------
         MU
SAMPLE NO:
smE LOCATION:
SHPIETYPT:
 W560.1IK5M   W577/HK57?   «K3!/HKJ3S?   BQ7WHB07M   B56?/HR56?
                                                         KLL40U
 FIELD ILK      FIELf ILK      EV.'IP. ILK     TRIP ILK       WPLICATE
       VNQRWN
I
                                                  I
I
I
 TOTAL   ALUMINUM
 fCTALS  ANTIMONY
        ARSENIC
        BARIUM
        BERYLLIUM

        CAMUWf
        CALCIUM
        CHROMIUM
        COBALT
        COPPER

        IRON
        LEAP
        MAGNESIUM
        KANEANESE
        MERCURY

        HIDE.
        POTASSIUM
        SELENIUM
        SILVER
        SODIUM

        THftLLI'JM
        VANADIUM
        ZIN:
 METALS  ANTIMONY
        ARSENIC
        BARIUM
        BERYLLIUM

*       CADMIUM
        CALCIUM
        CffiDMIUM
        COBALT
        COPPER

N       IRON
        LEAD
        MAN&AHESE
        IERCURY

        NICKEL
        POTASSIUM
        SELENIUM
        SILVER
                                            100
                                            519
                                            no
                      42?
                       144


177




*
11?

135
11



.

320
25
26


55fi



30?



30700
410
147000
56
18
46
36200
724
52
5?300
354000
57
173

21
101000
18
26
72100
264
5*400
     CONCENTRATIONS  IN US/L
                    A2-4

-------
  SITE:    MIF LA» RTCIAMATIONI  vi
  CASE «:  t277-l-1944tt
                                                                BK59/MM559
smi LOCATION:
smE TYPE:
SODIUH
THALLIUH
VANADIUM
ZINC-
INORB, AHMDNIA NITROGEN
2NPIC. WWSIlg
CHLORIK
CYANIDE
NITRATE NITR05EN
NITRITE NITROGEN
POT
POX
SULFATE
TO:
TOTAL PHENOLS
TOX
CARBWWTE
BICARBONATE
nuu
1 502







1200


FIH* H*
1 535







20


EQUIP. UK
1 485










TRIP ILK
1 733



to
2200
9


ft


KLL 40U
MPUCATE
1 3MOOO 1
-

72
35000
4900
280000
50


140000
41000
105
54


AU CONCENTRATIONS IN uS/L
                                                     A2-5

-------
    CASE NO!  *277-i-l*44HQ
    SAMPLE LOCATION:
    SAW! TYPE:
                             fQ570/MX£?C   OG578/NQ0578
                             HELL 4011       HELL 40L       KLL  40L
                             MPLICATI      WPLICATE      BUPL1CATE
                                                                        BSO/IW522   K553/WE553
                                                                        HELL «.       KLL 6U
    saa-
    VOA
    TIC-
    VOA
    T!C-
    SEKI-
    VOA
    VDA
j>           *CHO«E
                     CHLORIDE
            2-FUTAKOKE
            1KKZEKE
           :ltlil-TRICHLOROETHAN£
->         •TtTRACHLORDETHENE
CTHYL BENZENE
XYLECS

I1EHOL
fIS(2-£THTLIOYL)PHTHALATt
METHYLPHTHALATE
n-«-BUTYL PHTHALATE
IHOHYLPHENOL
4HETHTLWB10L
2f4-MHETHYLPHENDL
NAPHTHALENE
    PEST/   BIELPP.IN
    PCS     4H'~BBD
TETRAHYreOFURAN
lETHANrr TR1CHLOROFLUORO
UNKNOUN
   MEi  lil-OXYFIS
BENZENE* liMIIETHYL
BENZENE. IfS-MJOHYL
BEKZENEACniC ACID
PHENDL>  TETRA«ETHYLBUTYL
2-PROPANOL»HETHOXY
OANOIC ACIH
OANOIC ACIDr ICTKYL SUBST,
OCTANDIC ACIP
BENZENEPRDPANOIC ACID
UNIWOUH
UNKNWK
UNKNOWN
UWN9WN
UNKNDVN
UfulNjlm
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
I (PUR
                                       12J
                                                   7  J
                                                  li  J
    ALL CONCENTRATIONS  IN u*/L
                                                A2-6

-------
F
N)
     tn jn 3 a:
     »-« rn g »-•



     S S'J? P
         S

         §
         fr«



         12
                                         B

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                i     ~*jsi          s   *  i   "•«*
                              S w
W  ££
•o  -o o
  S   VJ



* 3 " H
                      a
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     5
                                                      3
           o*
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»-••>»  Q>

•« «5 KJ •»
                                    ^
                                    K*
                                    13
                                              y S
                                              -o K»
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                                      £    5

                                      —«    M »r

                                      S    It
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                                                            ii
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                                                                                                          •

-------
 SITE:    HIP UWF RI:UWATIDK» HI
 CASE NO:  <277-i-W4W
SAtni m:
SAMPLE LOCATION:
smETW:
SODIUH 1
THALLIUM
VMMPIW
ZIIC.
WORG, MKOKIA NITROGEN
JNPIC, IRWllgE
CHLQKIK
vimiK
KITRATE KITROeEN
NITRITE KITR06EN
PO:
rox
SULFATE
TOC
TOTAL ttOKLS
TOX
CARfONATE
BICAPJONATE
BC570/HBC570
«Q1 400
W1ICATE
3*4000 1


63
27000
4700
190000

1110

380
15
105000
34000
105
71


Kn/D/flthR/v
VEIL 401
MPLKATE
84WO 1


212
120
76
WOO


50


180000
2600
46



KU 401
HFLICATE
9A100 1


84
200







2700
56



QD552/MC522
VSltL
21100 1


18"

36000

460



207000
3500
£0
7


NQI 6U
BV-LN
27300 1
"



100
woo





240000
12000
36
7


-K± CONCENTRATIONS IN uS/L

-------

SITE:    Mi! LAW RECLAMATION.
CASE w:   c7?-t-i»44HO

SAMPLE MO:
SAMPLE LOCATION;
SAMPLE TYPE:
                                      W554/HK354
                                      HELL 308:
                                      6V-LOV
                                                   Q0555/HK555
                                                   HELL 2W
                                                   6V-LOV
NELL HU
6H.W
QC557/W0557
HELL ML      MELL 29L
6V-LOW        AH.N
VOA
SEMI-
VOA
        TOLIEfC
        ACETWC
        fCTHTLEC CHLORIDE
        2-WTAMOKE
        KHZEfi
        M»l-TRIDC.OROnHAHE
        TRAHS-diMICHLOROETHEfE
        TRICHLOROETHEHE
        4-CTHYL-2-PEKTAWMC
        ETHYL KCENE
        XYLECS

        PHENOL
        PIS{2-£THYLHDCYL)PHTHALATE
        METHYLPHTHALATE
        DUf-RJTYL PHTHALATE  •
        2HOHYLPHEWIL
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-------

  SITE:    HIP LAW
  CASE NO:  C77-L-1W4W
arinrii KVi
SAMPLE LOCATION:
SAMPLE TYPE:
VGA TOLUENE
ACETONE
ICTHTLEfE CHLORIDE
2-BUTANONE
KKZENE
Itl-DICHLOROETHANE
1»1.1-TRICHLOROETHAKE
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 SITE:    MII LAW RECLMMTIONI vi
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-------
SUMMARY OF LRL's CONTRACT LABORATORY PERFORMANCE EVALUATION STUDIES

-------
                                  1 Alii

               SUMMARY OF WATER SUPPLY  PERFORMANCE EVALUATION STUDIES
INORGANICS

Parameters
Arsenic

Barium

Cadmium

Chromium

Lead

Mercury

Selenium

Silver

Nitrate

Calcium
Sodium

7/86
IN
2A
IA
2A
IN
2N
IN
2A
IN
2N
IN
2N
IA
2N
IN
2A
IA
2A
IA
IN

1/86
A
N
D
D
N
N
N
A
A
N
A
N
A
A
D
D
A
A
D
D

7/85
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
A
A
A
N

1/85
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
A
A
D
A

7/84
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
N
N
N
A

7/83
N
N
N
N
N
A
N
A
A
N
A
A
A
A
N
N
A
A
D
D

1/83
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
A
N
D
D
A - Acceptable
N - Not Acceptable
1 - Concentrate  1
C - Check for Error
D - Data not Reported
2 - Concentrate 2

-------
              SUMMARY OF  WATER  POLLUTION  PERFORMANCE  EVALUATION  STUDIES
INORGANICS

Parameters
A lu ni mum

Arsenic

Beryllium

Cadmium

Cobalt

Chromium

Cooper

Iron

Mercury

Manganese

Nickel

Lead

Selenium

Zinc


5/86
IA
2A
IA
2A
IA
2A
IA
2A
IA
2A
IA
2A
IA
2A
IA
2c
IA
2A
IA
2A
ic
2N
IA
2A
IA
2A
IA
2A

11/85
D
D
A
A
D
D
A
A
D
D
A
A
N
N
N
A
A
A
A
N
N
A
A
A
C
N
N
C

5/85
N
C
A
N
D
D
A
C
N
N
N
A
N
N
A
A
A
N
A
A
A
A
C
A
A
C
C
A

11/84
D
D
A
A
D
D
A
A
D
D
A
N
A
A
A
A
N
A
D
D
A
A
A
A
N
A
A
N

5/84
D
D
A
A
A
A
A
A
A
C
A
A
A
A
A
A
N
D
A
A
A
A
A
A
A
A
A
A

12/83
N
C
N
N
A
A
A
A
A
A
A
A
A
A
N
D
A
A
A
A
A
A
N
N
N
N
N
A
A - Acceptable
N - Not Acceptable
1 - Concentrate 1
C - Check for Error
D - Data not Reported
2 - Concentrate 2

-------
                               TABLE   C-2  (Cont'd)
SUMMARY OF
WATER POLLUTION PERFORMANCE
EVALUATION STUDIES
INORGANICS


Parameters
Calcium

Magnesium

Sodium

Potassium

Chloride

Sulfate

Ammonia-Nitrogen

Nitrate-Nitrogen

TOC

Total Cyanide

Total Phenol ics

Spec. Cond.


5/86

IA
2N
IA
2A
IN
2N
1C
2C
IA
2A
IA
2A
IN
2N
IA
2A
IA
2A
IA
2A
IA
2A
IA
2A

11/85

A
N
N
N
N
N
N
N
N
N
N
N
A
C
A
A
A
A
D
D
A
A
D
D

5/85

N
N
N
A
N
N
C
A
A
A
A
A
N
N
A
A
A
A
N
N
D
D
A
A

11/84

D
D
D
D
D
D
D
D
D
D
D
D
D
D
C
C
D
D
D
D
D
D
A
A

5/84

N
N
A
N
A
A
A
A
A
A
A
N
D
D
D
D
A
A
N
N
D
D
N
N

12/83

A
A
A
C
N
N
A
A
A
A
A
- A
A
A
N
A
D
D
N
N
D
D
A
C
A - Acceptable
N - Not Acceptable
1 - Concentrate 1
C - Check for Error
D - Data not Reported
2 - Concentrate 2

-------
                  I AikI   C-3
SUMMARY OF WATER POLLUTION PERFORMANCE EVALUATION STUDIES
INORGANICS AND OR6ANICS *
i
"PARAMETERS

SAMPLE REPORT TRUE
NUMBER VALUE VALUE**

ACCEPTANCE
LIMITS

WARNING PERFORMANCE
LIMITS EVALUATION
DEMANDS IN MILLIGRAMS PER LITER:
COD
TOC
5-DAY BOD
1 31 47.0
2 54 78.8
1 20 18.4
2 34 30.9
1 23 31.1
2 39 52.1
31.0- 59.0
54.7- 93.6
10.7- 26.3
19.8- 41.7
18.3- 42.9
31.3- 71.1
34.6- 55.4 CHECK FOR ERROR
59.7- 88.6 NOT ACCEPTABLE
13.0- 23.9 ACCEPTABLE
23.1- 38.4 ACCEPTABLE
21.4- 39.8 ACCEPTABLE
36.3- 66.1 ACCEPTABLE
PCBs IN MICROGRAMS PER LITER:
PCB-AROCLOR 1242
PESTICIDES IN
ALDRIN
ALDRIN
DDE
DDT
HEPTACHLOR
HEPTACHLOR EPOXIDE
1 2.0 1.14 D
MICROGRAMS PER LITER:
1 0.67 0.455
2 1.0 0.683
1 0.70 0.181
2 2.7 0.906
1 0.25 0.074
2 2.8 0.662
1 1.4 0.251
2 0.58 0.670
1 1.1 0.602
2 0.31 0.226
1 1.6 0.764
2 0.44 0.176
.L. - 2.36

.124- .612
.186- .888
.0913- .275
.431- 1.22
.0393- .152
.284- .955
.0816- .402
.293- .960
.151- .870
.0710- .316
.332- 1.05
.103- .251
* WATER POLLUTION STUDY (WPS) 012 5/24/84
** BASED UPON THEORETICAL CALCULATIONS, OR A REFERENCE
D.L. STANDS FOR DETECTION LIMIT
.320- 201 ACCEPTABLE

.187- .548 NOT ACCEPTABLE
.277- .797 NOT ACCEPTABLE
.116- .250 NOT ACCEPTABLE
.534- 1.12 NOT ACCEPTABLE
.0540- .137 NOT ACCEPTABLE
.373- .865 NOT ACCEPTABLE
.124- .359 NOT ACCEPTABLE
.382- .871 ACCEPTABLE
.245- .776 NOT ACCEPTABLE
.104- .283 CHECK FOR ERROR
.413- .951 NOT ACCEPTABLE
.122- .231 NOT ACCEPTABLE
VALUE WHEN NECESSARY.

-------

                                    I A i L. I   C-3 (Cont'd)



                   SUMMARY OF WATER POLLUTION PERFORMANCE EVALUATION STUDIES



                                            ORGANICS
€
PARAMETERS
SAMPLE REPORT TRUE
NUMBER VALUE VALUE*
PESTICIDES IN MICR06RAMS PER LITER:
CHLORDANE 5 20 9.28
6 4.4 2.16
V. ORGANICS IN MICROGRAMS PER LITER:
1,2 DICHLOROETHANE
1,1,1 TRICHLOROETHANE
TRICHLOROETHENE
TETRACHLOROETHENE
CHLOROBENZENE
PURGEABLES IN
BENZENE
ETHYLBENZENE
TOLUENE
1
2
1
2
1
2
1
2
1
2
MICROGRAMS
1
2
1
2
1
2
42
12
108
20
107
10
25
14
91
43
PER
6.2
40
18
65
22
54
32.1
6.43
79
13
96
7.
.6
.9
.0
20
32.9
8.78
87.
34.
LITER:
8
6

6.40
48.3
13.
55.
17.
51.
0
1
4
1
ACCEPTANCE
LIMITS
3.94-
1.03-
19.4-
2.91-
48.8-
7.87-
61.5-
3.19-
19.0-
4.57-
52.2-
19.9-

2.40-
26.5-
7.11-
30.7-
9.55-
28.2-
12.3
3.11
46.1
9.86
112
20.
121
11.
45.
13.
125
49.

10.
71.
19.
80.
25.
69.
•
5
•
4
5
1
•
9

6
4
3
9
8
6
WARNING
LIMITS
5.05-
1.30-
23.1-
3.83-
57.5-
9.61-
69.4-
4.31-
22.6-
5.73-
62.5-
24.2-

3.59-
33.1-
8.86-
37.4-
11.9-
33.7-
11.2
2.83
42.5
8.94
103
18.
113
10.
41.
11.
115
45.

•
8
•
2
9
9
•
7

9.36
64.9
17.
74.
23.
64.
5
2
4
1
PERFORMANCE
EVALUATION
NOT ACCEPTABLE
NOT ACCEPTABLE
ACCEPTABLE
NOT ACCEPTABLE
CHECK FOR ERROR
CHECK FOR ERROR
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
NOT ACCEPTABLE
ACCEPTABLE
ACCEPTABLE

ACCEPTABLE
ACCEPTABLE
CHECK FOR ERROR
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
              BASED  UPON THEORETICAL CALCULATIONS,  OR A REFERENCE VALUE WHEN NECESSARY.

-------

TAB
L E C-3 (Cont'd)


SUMMARY OF WATER POLLUTION PERFORMANCE EVALUATION STUDIES
INORGANICS AND ORGANICS *

"PARAMETERS
MINERALS
FLUORIDE
SULFATE

SAMPLE REPORT
NUMBER VALUE

TRUE ACCEPTANCE
VALUE** LIMITS

WARNING
LIMITS

PERFORMANCE
EVALUATION
IN MILLIGRAMS PER LITER: (EXCEPT AS NOTED)
1 1.5
2 0.9
1 140
2 8.0
1.30 1.12- 1.45
0.822 .670- .921
131 111.- 148.
7.00 4.14- 9.65
1.16- 1.41
.703- .889
115.- 143.
4.86- 8.93
NOT ACCEPTABLE
CHECK FOR ERROR
ACCEPTABLE
ACCEPTABLE
NUTRIENTS IN MILLIGRAMS PER LITER:
AMMONIA-NITROGEN
NITRATE-NITROGEN
1 5.1
2 1.6
1 0.18
2 0.81
KJELDAHL-NITROGEN 1 3.5
2 8.7
TOTAL PHOSPHORUS
DEMANDS
COD
TOC
PCBs IN
'PCD AROCLOR 1016
1 6.8
2 1.2
IN MILIGRAMS PER LITER:
1 31
2 29
1 52
2 12
MICROGRAMS PER LITER:
2 5.0
3.10 2.42- 3.72
0.896 .652- 1.16
0.152 .0788- .234
0.752 .565- .923
2.20 1.39- 3.14
10.5 7.75- 12.7
7.10 5.57- 8.65
1.20 .892- 1.57

128 99.9- 145.
30.2 18.1- 39.6
50.5 37.7- 61.9
11.9 7.00- 17.3

D.L.- D.L.
1 * WPS-014 5/24/85
** BASED UPON THEORETICAL CALCULATIONS, OR A REFERENCE
D.L. STANDS FOR DETECTION LIMIT
2.58- 3.56
.714- 1.10
.0970- .215
.609- .879
1.61- 2.92
8.38- 12.1
5.95- 8.27
.975- 1.49

106.- 140.
20.9- 36.8
41.0- 58.6
8.55- 15.7

D.L.- D.L.
VALUE WHEN
NOT ACCEPTABLE
NOT ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
NOT ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE

NOT ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE

NOT ACCEPTABLE
NECESSARY.

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                                    I A i k I   C-3 (Cont'd)
                    SUMMARY  OF  WATER POLLUTION PERFORMANCE EVALUATION STUDIES
6=
INORGANICS AND ORGANICS *



SAMPLE REPORT TRUE ACCEPTANCE
PARAMETERS NUMBER VALUE VALUE** LIMITS
NUTRIENTS IN MILLIGRAMS PER LITER:
NITRATE-NITROGEN 1 0.32 0.300
2 2.6 2.50
KJELDAHL-NITROGEN 3 0.50 0.300
4 5.2 5.00
TOTAL

COD
TOC
5 -DAY

PHOSPHORUS 3 0.15 0.100
4 3.3 3.00
DEMANDS IN MILLIGRAMS PER LITER:
2 290 238
1 8.5 8.98
2 97 94.2
BOD 1 80 3.85
PCBs IN MICROGRAMS PER LITER:
PCB-AROCLOR 1016 1 5.0 5.72
PCB-AROCLOR 1254 2 6.1 5.50

VOLATILE HALOCARBONS IN MICROGRAMS PER
1,2 DICHLOROETHANE 1 120 103
2 23 15.5
*
**
D.L.
WPS-015 11/27/85
BASED UPON THEORETICAL CALCULATIONS
'STANDS FOR DETECTION LIMIT
.207- .392
1.93- 3.04
D.L.- .803
3.31- 6.44
.0530- .157
2.37- 3.73

185.- 272.
6.01- 12.0
70.0- 112.
1.52- 5.75

2.08- 8.68
2.49- 7.19
LITER:
71.8- 137.
9.89- 21.6
, OR A REFERENCE

WARNING
LIMITS
.229- .370
2.06- 2.91
.0034- .693
3.69- 6.06
.0656- .145
2.54- 3.56

196.- 261.
6.82- 11.1
75.6- 107.
2.04- 5.22

2.97- 7.80
3.09- 6.60

80.2- 128.
11.4- 20.1
VALUE WHEN

PERFORMANCE
EVALUATION
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
CHECK FOR ERROR
ACCEPTABLE

NOT ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
NOT ACCEPTABLE

ACCEPTABLE
ACCEPTABLE

ACCEPTABLE
NOT ACCEPTABLE
NECESSARY.
c.
c-

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I A i k I   C-3 (Cont'd)
SUMMARY OF WATER POLLUTION PERFORMANCE EVALUATION STUDIES
ORGANICS *
*
" "PARAMETERS

SAMPLE
NUMBER

REPORT
VALUE

TRUE
VALUE**




ACCEPTANCE
LIMITS



WARNING
LIMITS

PERFORMANCE
EVALUATION
PCBs IN MICROGRAMS PERLITER:
: PCB-AROCLOR 1016
1
2
VOLATILE HALOCARBONS IN
1,2 DICHLOROETHANE
CHLOROFORM
1,1,1 TRICHLOROETHANE
TRICHLOROETHENE
CARBONTETRACHLORIDE
TETRACHLORDETHENE
BROMODICHLOROMETHANE
i
DIBROMOCHLOROMETHANE
.BROMOFORM
r^
METHYLENE CHLORIDE
t •
1
2
1
2
1
2
1
2
1
2
1
2
1
2
1
2
1
2
1
2
2.5
3.1

MICROGRAMS PER
30
92
5.9
100
15
49
26
110
22
65
21
100
21
92
19
no
70
46
26
91
25.8
77.3
6.04
84.5
14.8
44.3
22.5
100.2
18.5
52.9
16.9
84.7
15.6
65.7
19.1
95.6
50.6
30.4
20.5
63.8
. * WPS-016 5/23/86
** BASED UPON THEORETICAL CALCULATIONS,
D.L. STANDS FOR DETECTION LIMIT
D.L
D.L
LITER
17.
46.
• "
• "
•
•
7-
6-
3.27-
57.1-
10.
28.
14.
58.
11.
33.
10.
51.
10.
44.
11.
64.
28.
14.
10.
30.
2-
0-
0-
8-
1-
0-
6-
3-
8-
4-
5-
7-
1-
5-
8-
6-
D.L
D.L

32.
108
•

8
8.55
no.
20.
62.
30.
137
26.
76.
22.
109
21.
92.
28.
142
75.
49.
30.
93.
7
5
0
0
2
5
2
9
9
1
0
0
0
OR A REFERENCE
D.L.-
D.L.-

19.6-
54.2-
3.95-
63.8-
11.5-
32.3-
16.0-
68.5-
13.0-
38.4-
12.1-
58.5-
12.1-
50.5-
13.7-
74.4-
34.0-
18.8-
13.2-
38.4-
D.L
D.L

•
•

30.9
100.
7.87
103.
19.4
58.2
27.
127
24.
70.
21.
102
19.
86.
26.
132
69.
44.
27.
85.
9
•
1
8
0
*
8
8
7
•
2
7
6
2
VALUE WHEN
NOT ACCEPTABLE
NOT ACCEPTABLE

ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
CHECK FOR ERROR
CHEDK FOR ERROR
ACCEPTABLE
ACCEPTABLE
CHECK FOR ERROR
CHECK FOR ERROR
ACCEPTABLE
CHECK FOR ERROR
NECESSARY.

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,., protection

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