EPA-700/8-88-048

 May 1988                             EPA-700/8-88-048
Hazardous Waste Ground-Water
Task Force
Evaluation  of
Rollins Environmental Services
Bridgeport,  NJ.
              United States Environmental Protection Agency
   LoS protect our eanh
              Department of Environmental Protection


$t*t* ot fttto Jersey

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May 1988

Update of the Hazardous Waste Groundwater Task Force evaluation of Rollins
Environmental Services (NJ), Inc., Bridgeport, New Jersey


The United States Environmental Protection Agency's Hazardous Waste Ground
Ground Water Task Force (HWGWTF) and the New Jersey Department of Environ-
mental Protection NJDEP conducted an evaluation of the compliance of Rollins
Environmental Services (NJ), Inc. (RES) with the interim status and ground
water monitoring requirements of the Resource Conservation and Recovery Act
(RCRA) as adopted by New Jersey.  RES is one of the 59 commerical and non-
commercial hazardous waste treatment, storage and disposal facilities to be
evaluated.  The on-site inspection was conducted over an eleven-day period
from  February 9 to February 19, 1987.

In the 1970s, various hazardous constituents were released to the soil,
ground, and surface water due to spills and the operation of unlined sur-
face  impoundments.  These releases resulted in NJDEP's issuance of an
Administrative Consent Order (ACO) to RES in 1981.  The ACO required
sitewide ground water monitoring and decontamination procedures.  Many of
the surface impoundments were closed under this Order.  Only 8 unlined
storage surface impoundments (L-series lagoons) and 2 concrete lined treat-
treatment surface impoundments (basins B-206 and B-207) remain.

The Task Force conducted an in-depth on-site investigation of RES.  The
evaluation focused on (1) determining if the facility was in compliance
with applicable regulatory requirements and policy, (2) determining if
hazardous constituents were present in the ground water, (3) providing
information to assist EPA in determining if the facility meets the EPA
requirements for facilities receiving waste from response actions conducted
under the Comprehensive Environmental Response Compensation and Liability
Act (CERCLA).

The site evaluation conducted in February 1987 revealed violations of RCRA
and New Jersey hazardous waste regulations.  In summary, these included an
inadequate ground water monitoring assessment program to meet compliance
with RCRA and New Jersey regulations, inadequacies in RES' interim status
ground water sampling and analysis procedures, deficiencies in on-site
laboratories and violations of waste management practices and records
maintained at RES.

Although RES has been following the 1981 State ACO, based on the Task Force
findings the following actions will  be required by RES:

     1.  RES must upgrade its existing site-wide ground water monitoring
         system to accurately assess on-and off-site soil, ground and
         surface water contamination.  RES must expand its sampling of
         the horizontal  and vertical  extent of ground water contamination.
         In particular the north marsh area, the south marsh area, and
         the shallow artesian zone throughout the site require more
         samp!ing,

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     2.  Revise the current ground water sampling and analysis plan to address
         the deficient procedures, methods and quality analysis/ quality
         control  programs as outlined in the Task Force Report, and

     3.  Address  deficiencies found in current waste management practices
         and records maintained at the facility.

On August 21, 1987, EPA and RES entered into a 3008(h) Administrative
Consent Order.  This Consent Order requires RES to correct the deficiencies
found in the ground water assessment program and  ground water sampling and
analysis plans (items 1 and 2).  Pursuant to the  Consent Order, RES sub-
mitted a draft workplan in December 1987 to conduct a site-wide RCRA
Facility Investigation (RFI).  The workplan when  approved by EPA and NJDEP
will require the  facility to accurately assess on- and off-site soil,
ground, and surface water contamination.  The Consent Order also requires
RES to conduct Corrective Measure studies and to  implement Corrective
Measures based on the findings of the RFI.  RES violations pertaining to
waste management  practices and record keeping (item 3) detailed in the
Task Force Report have been corrected.  The State issued the Notice of
Violation (NOV) to RES on May 28, 1987.  The facility came into compliance
on June 28, 1987.  Based on the latest EPA off-site policy and the entering
into the 3008(h)  Consent Order, EPA determined that RES is eligible to
receive waste from response actions taken under CERCLA.

RES submitted closure/post-closure plans for the  8 unlined surface impound-
ments and 2 concrete lined treatment surface impoundments (B-206 and B-207)
on May 15, 1986.   RES is required to cease introducing waste into these
units on or before November 8, 1988 and replace the surface impoundments
with above ground tanks.  On February 25, 1988 NJDEP issued RES a technical
Notice of Deficiency (NOD) for its closure and post-closure plans.  Following
RES' response to  the NOD, NJDEP issued RES a draft closure plan modification
and approval for the 10 surface impoundments in the form of a NJPDES/DSW
draft permit.  On March 30, 1988, NJDEP public noticed this draft closure
approval.

EPA and NJDEP public noticed a RCRA permit on May 23, 1988.  The RCRA
permit contains NJDEP's RCRA operating permit and EPA's permit pursuant to
the Hazardous and Solid Waste Amendments of 1984 (HSWA).  NJDEP's RCRA
operating permit contains operating conditions for the incinerator, tanks
and container storage areas, while EPA's HSWA permit incorporates the
August 21, 1987,  3008(h) Consent Order.

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ACKNOWLEDGEMENTS

It is a pleasure to acknowledge the particular assistance of my co-worker
Jeffrey Gratz, who contributed immensely in evaluating RES' ground water
monitoring program.  In addition, I would like to acknowledge the assistance
of the following personnel  who provided information and technical guidance:
Al Neshiewat, Tom Solecki, Joe Cosentino, Lou DiGuardia, Fred Haber, Brian
Lewis, Carol  Casazza, Thomas O'Keeffe, Tracy Wagner, Jack Allen, and Dave
Zervas.  Lastly, I wish to thank the personnel of Rollins Environmental
Services (NJ) on behalf of the Task Force team for assisting us during the
inspection, from February 9 to 19, 1987.
                                  Samuel I. Ezekwo
                                  Project Coordinator
                                  U.S. Environmental Proctection Agency
                                  Region II
For further information regarding this report please contact:
           Hazardous Waste Compliance Branch
           U.S.  Environmental  Protection Agency
           Region II
           26 Federal  Plaza
           New York, New York   10278

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              UNITED STATES  ENVIRONMENTAL PROTECTION AGENCY
                 HAZARDOUS WASTE  GROUND WATER TASK FORCE
GROUND WATER MONITORING  EVALUATION
Rollins Environmental  Services  (NJ),  Inc,
Bridgeport, New Jersey
May 1988
Samuel I. Ezekwo
Project Coordinator
U.S. Environmental Protection  Agency
Region II
                                      '.;. Frwironmentil  Protection Agency
                                     ~. ;•-.; .jr. 5,  Library (5PL-16)
                                     r-6 2. Dearborn Street, Room 1670
                                     C ..oago, IL   60604

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                                        11


                                     CONTENTS


 I.   EXECUTIVE SUMMARY

     A.  Introduction 	1

     B.  Summary of Findings and Conclusions 	2

         1.  Ground Water Monitoring Program During Interim Status  	5

         2.  Ground Water Sampling and Analysis Plan 	6

         3.  Audit of Currently Used Laboratories 	7

         4.  Task Force Well Sampling Data Analysis 	7

         5.  Compliance Evaluation Inspection 	8

II.   TECHNICAL REPORT

     A.  Regulatory Requirements 	9

         1.  New Jersey Department of Environmental  Protection
             Responsibilities 	10

         2.  Environmental  Protection Agency's Responsibilities 	10

     B.  Investigative Methods and Procedures 	11

         1.  Records/Documents Review 	11

         2.  Comprehensive  Ground Water Monitoring Evaluation 	11

         3.  Ground Water Sampling and Analysis 	12

         4.  Evaluation of  On-Site and Off-Site Analytical Labs 	13

         5.  Comprehensive  Evaluation Inspection 	13

     C.  Facility Description and Operation	14

         1.  General  Information 	14

         2.  Description  of Facility Operations 	14

         3.  Solid  Waste  Management Units  (SWMUs)  	15

     D.   Ground  Water  Monitoring Program During Interim Status	17

         1.  RES Compliance History 	17

             a.   Early Plant History - 1970s  	17

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                                   m

        b.  Events Surrounding the 1981 Administrative  Order	17
        c.  Part B Submittal and LOIS Certification  	24
        d.  Situation at the Time of Task  Force  Inspection  	27
    2.  Regional Setting 	28
        a.  Physi ography 	28
        b.  Geologic Setting	28
        c.  Hydrogeologic Setting 	33
    3.  Site Hydrogeology 	40
        a.  General Overview-  Geology	40
        b.  General Overview-  Hydrogeology	42
        c.  Hydrogeology and RES' Ground Water Monitoring Program	43
    4.  Ground Water Quality 	50
        a.  General Overview 	50
        b.  Ground Water Quality and the RES Ground  Water
            Monitoring Program 	50
    5.  Discussion 	65
    6.  Conclusions and Recommendations 	74
    7.  References 	77
E.  Ground Water Sampling and Analysis Plan 	79
F.  Audit of Currently Used Laboratories	84
    1.  RES Laboratory 	84
    2.  Environmental Testing and Certification  Laboratory  	86
G.  Ground Water Sampling Activities at RES	87
H.  Task Force Well Sampling Data Analysis 	90
    1.  Inorganic and Indicator Parameters 	90

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                                          1v
          2.   Metal  Analyses Results 	92

          3.   Organic  Analyses Results 	94

          4.   Dioxin/Furans Analyses Results 	98

      I.   Compliance Evaluation Inspection 	99

          1.   Facility Description and Operations 	99

          2.   Hazardous Waste Storage 	99

          3.   Other  Storage Tanks 	100

          4.   Incinerator 	101

          5.   Waste  Analysis Plan 	102

          6.   Closure  Plan 	103

III.   APPENDICES 	104

      A.   Tables of  Schedule of Task Force Sampling Activities,
          Physical  Characteristic of Ground Water Monitoring Wells,
          and Task  Force Sampling Data 	105

      B.   Evaluation of Quality Control  Attendant to the Analysis
          of  Samples from the RES Facility, New Jersey 	141

      C.   Inventory  of Hazardous Waste On-site During Task
          Force Evaluation 	157

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                              LIST  OF  FIGURES


 Figure

 1.   Location of  RES  (NJ)  in  Logan  Township, Bridgeport,  N.J	4

 2.   Location of  RES  (NJ)  facility  with  respect  to  (a)  the  Delaware
     River  and  surrounding  townships and (b) counties within  the  State
     of  New Jersey.   From  RES (1985) and Hardt  (1963)	18

 3.   RES facility map -  1972  	19

 4.   RES facilitymap -  1980  	21

 5.   New Jersey Coastal  Plain and  fall  line.  From  Zapezca (1984)	29

 6.   Drainage basins  in  the New  Jersey Coastal  Plain.   From Volwinkel
     and Foster (1981)	30

 7.   Generalized  hydrogeologic cross-section  showing  dipping  bedrock
     (pre-Cretaceous) and  unconsolidated sediments  in the New Jersey
     Coastal  plain.   From  Walker (1983)	31

 8.   Generalized  structure  contour  (altitude  in  feet; datum is mean  sea
     level) on  pre-Cretaceous bedrock  surface  in the  New  Jersey Coastal
     Plain.  From Parker et.  al. (1964)	32

 9.   Diagrammatic representations  of depositional  environments which
     existed during  the  emplacement of Cretaceous  and younger sediments
     in  the New Jersey Costal plain.   From Owens and  Sohl (1969)	34

10.   Geologic and hydrogeologic  units  of the  New Jersey Coastal Plain.
     From Zapezca (1984)	35

11.   Generalized  structure contour (altitude  in  feet; datum is mean  sea
     level) on  top  of the  Magothy formation along  with  isopachs of the
     combined  Potomac Group,  Raritan  and Magothy formations.   From Parker
     et. al. (1964)	37

12.   Major ground water  withdrawls from the New Jersey  Coastal Plain,
     1958-1978.  From Volwinkel  and Foster (1981)	39

13.   Site specific  geology and geomorphology at RES.   From NJDEP (1983)..41

14.   Water table  contour maps (altitude in feet; datum  is mean sea
     level) for (a)  March, 1972  and (b)  November, 1975	44

15.   Hydrogeologic  cross section.   From Geraghty and  Miller (1982)	47

16.   Water quality in southwestern New Jersey.   From  Hardt (1963) and
     Fusillo et.  al.  (1984)	51

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                                     VI
                          LIST OF FIGURES (CONT.)
 Figure
17.   Total  dissolved solids (TDS) contours at RES for (a) 1972
     and (b) 1975 	54

18.   Total  dissolved solids (TDS) contours at RES for (a) 1977
     and (b) 1978 	55

19.   Total  dissolved solids (TDS) contours at RES for (a) 1984
     and (b) 1986 	61

20.   Vertical resistivity profiles for selected locations at RES.
     From Geraghty & Miller (1972) 	67

21.   Geologic cross-sections with total dissolved solids (TDS) data
     at RES.  From Geraghty & Miller (1972) 	68

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                                      VII
                                 LIST OF TABLES


   Number

   1.  Total Dissolved Solids (TDS) Concentrations at  RES,  1972-1980	57

   2.  Sampling Wells and Parameters at RES as Part of (a)  the  1981  AGO
       and (b) the Unsigned 1983 AGO	58

   3.  Inorganic and Indicator Parameter Analyses  	91

   4.  Appendix IX Metals (Total and Dissolved)  	92

   5.  Volatile and Semi-volatile Constituents 	95

   6.  Dioxin/Furan Results 	98

 A-l.  Outline of Ground Water Monitoring Activities Conducted  by
       the Task Force 	106

 A-2.  Summary of Analytical Parameters Sampled  by the  Task  Force
       at Rollins Environmental Services 	107

 A-3.  Well  Contruction Details for Wells at Rollins Environmental
       Services (NJ), Inc., Logan Township, New  Jersey	108

 A-4.  Water Table Measurements Taken by the Task  Force at  RES  	113

 A-5.  Duplicate Water Level Measurements Taken  by the  Task  Force  	115

 A-6.  Physical Characteristics of Wells Measured and  Sampled by
       the Task Force at Rollins Environmental Services 	116

 A-7.  Results of Air Monitoring at Ground Water Monitoring  Wells
       Sampled by the Task Force at RES 	117

 A-8.  Field Measurements Conducted by the Task  Force  at RES  	118

 A-9.  Results of Inorganic and Indicator Type Analyses	120

A-10.  Results of Total  Metals Analyses 	123

A-ll.  Results of Dissolved Metals Analyses 	126

A-12.  Results of Volatile Organic Analyses 	129

A-13.  Results of Semi-volatile Organic Analyses 	133

A-14.  Tentatively Identified Compounds Requiring Confirmation
       Using Authentic Standards 	137

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                                    -1-



                           I.    Executive Summary


A. Introduction

   In 1965 Congress passed the Solid Waste Disposal  Act, the first federal
   law to require safeguards and encourage environmentally sound methods  for
   disposal  of household, municipal, commercial  and  industrial  refuse.   Con-
   gress amended this law in 1970 by passing the Resource Recovery Act  and
   again in  1976 by passing the Resource Conservation and Recovery Act  (RCRA),
   As the knowledge about the  health and environmental  impacts  of waste dis-
   posal increased, Congress revised RCRA, first in  1980 and again in 1984.

   RCRA, including its 1984 amendments, is divided up into subtitles.  Sub-
   titles C, D, and I set forth the framework for EPA's comprehensive waste
   management programs: hazardous waste management,  solid waste management
   and toxic waste and petroleum products stored in  underground tanks.
   Parts 260 through 262, Part 263, Parts 264 and 265 of 40 CFR set require-
   ments for the generation, transportation, storage or disposal  of hazardous
   wastes respectively.  The regulations for treatment, storage and disposal
   facilities (TSDF) are divided into two sets,  one  for interim status  and
   the other for permitted TSDF's.   The interim  status  regulations are  found
   in 40 CFR Part 265, while the permit regulations  are found in 40 CFR Part
   264.

   Section 3006 of Subtitle C  of RCRA allows the EPA to authorize the State
   hazardous waste program to  operate in the State in lieu of the Federal
   Hazardous Uaste Program.  The State of New Jersey received final authoriza-
   tion on February 21, 1985.   This authorization does  not include program
   elements  under HSWA.

   EPA has recognized that although the basic ground water monitoring require-
   ments have been in existence since 1980, some of  the commercial  TSDFs
   have not  achieved compliance.  Adequate monitoring of the waste management
   units is  important in order to determine whether  the existing units  are
   releasing hazardous contaminants into the ground  water.  Accordingly,  the
   Administrator established a Task Force to evaluate the compliance status
   and determine the causes of poor compliance.   The Task Force was charged
   to conduct in-depth onsite  investigations of  commercial TSDFs with the
   following objectives.

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

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

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

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                                    -2-
   0 Provide information  to  assist the  Agency in  determining  if  the  TSDF
     meets the EPA ground water monitoring  requirements  for waste  management
     facilities receiving waste from  response actions  conducted  under  the
     Comprehensive Environmental  Response,  Compensation  and Liability  Act
     (CERCLA), Public Law 91-510

   0 Identify significant ground water  management,  technical  and compliance
     problems, and take enforcement or  other administrative actions  to
     correct the problems

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

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

   0 Designated 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.

The TSDF investigated by the Task Force was Rollins Environmental  Services
(NJ) Inc. (RES) located along the eastern bank of Raccoon Creek  in Bridgeport,
New Jersey (Figure 1).  RES' EPA indentification  number  is NJD053288239.
The facility has also operated under  the name of  Rollins Purle,  Inc.   The
on-site inspection was conducted from February 9  through February  20,  1987,
and was coordinated by staff of EPA Region  II.  In  general, the  investigation
involved reviews of State, Federal and  facility records, facility  inspection,
laboratory evaluation, and ground water sampling  and analysis.

The 78-acre commercial treatment, storage and disposal  facility  has  been  in
operation since 1969.  RES accepts a  wide range of  hazardous  wastes.
Primarily, the wastes are received in gaseous, liquid  and solid  form;
however, RES also stores sludges and  slurries.  Incineration  is  the  only
commercial operation at the  facility.  Incinerator  ash,  formerly landfilled
on-site, is now transported  elsewhere.   Eight unlined  surface impoundments
receive scrubber wastewater  from the  incinerator  for cooling  and storage
before discharge to Raccoon  Creek.  The facility  also  uses two concrete
lined surface impoundments for biological treatment of contaminated
ground water from 18 pumping wells on-site.

The facility notified EPA in November 1980  that it  is  conducting the  following
hazardous waste activities:

   0 Transportation of hazadous wastes;
   0 SOI - storage in containers;

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                                    -3-
       0  S04  -  storage  in  surface  impoundments;
       0  T01  -  treatment  in  tanks;
       0  T02  -  treatment  in  surface  impoundments;
       0  T03  -  incineration

   RES  certified  Loss of  Interim  Status  (LOIS) compliance  with  the  applicable
   ground water monitoring requirements  for  the  10  regulated  units  at  the
   facility in  November 8, 1985.

   Task Force Participants

   The  USEPA  -  II Project  Team  included  Samuel Ezekwo,  Environmental  Engineer,
   Hazardous  Waste  Compliance Branch;  Jeffrey  Gratz,  Hydrogeologist,  Hazar-
   dous Waste Compliance  Branch;  Ataliah Nesheiwat, Environmental  Engineer,
   Hazardous  Waste  Facility  Branch;  Tom  Solecki; Environmental  Engineer,
   Hazardous  Waste  Compliance Branch;  and from the  Environmental  Services
   Division,  Joseph Cosentino,  Environmental  Scientist;  Louis DiGuardia,
   Geologist; and Fred  Haber, Quality  Assurance  Specialist.   Representing
   the  State  of New Jersey for  the  Task  Force  investigation were  Tracy
   Wagner, Hydrogeologist, Ground-Water  Quality  Management; Jack  Allen,
   Environmental  Specialist, Southern  Region Enforcement.   Representing  EPA
   Headquarters was Brian  Lewis,  Hydrogeologist.  Richard  Deluca,  David
   Billo, Mark  Lewis and  William  Naughton were the  contract sampling  team
   from Alliance  Technologies Corporation.

B. Summary of Findings  and Conclusions

   The  findings and conclusions presented in this  summary  and report  reflect
   conditions existing  at  the RES facility in  February  1987.   Subsequent
   actions taken  by the facility, the  State, and Region  II since  the
   investigation  are summarized in  the acompanying  update  memorandum  attached
   to this report.

   In summary,  the  Task Force has determined that:

       0   The interim status ground  water monitoring  and waste  management
          programs  were inadequate and did not comply with some of the
          requirements  of the New Jersey Administrative  Code  (equivalent  to
          40 CFR, Part  265).  In  particular, this  investigation finds the
          scope of  RES' assessment program insufficient  to adequately
          define  the rate  and extent of  migration  of hazardous  waste  or
          hazardous waste constituents into  the  ground  water.

       0   The ground water monitoring  program proposed  in  RES'  1985 Part  B
          permit  application and  subsequent  revisions up to the time  of  the
          inspection were  deficient  with the requirements  of  40 CFR 270.14(c)
          (specifically with respect to  ground water  contamination assessment)
          and require modification.

       0   The Task  Force  investigation confirmed that the  ground  water at  the
          facility contains  elevated levels  of hazardous waste  constituents
          above background levels.   The  ground water  contamination is present
          in the water  table zone and, to a  much lesser  degree, in the deeper,
          but hydraulically  connected  shallow artesian  zone.

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                                 -4-
                     KNMMMOVE WATVM »wm.r co.
                        •mooeporr OIVISIOM
              IROUJNS ENVIRONMENTAL SERVICE (NJ.) INC
             /f-^f^l I-OGAN TOWNSHIP PLANT       \
Location  of RES  (NJ) in  Logan
Township.  Bridgeport, N.J.

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                                 -5-
   0  Prior  to  the  time  of  investigation,  the  facility was considered
     unacceptable  to  receive  hazardous  waste  from  response  actions  conducted
     under  CERCLA  owing to  (1)  known  releases of hazardous  waste constituents
     into the  environment  and  (2)  non-compliance with applicable ground water
     monitoring  regulations.   The  findings  of the  Task  Force  investigation
     confirm RES'  unacceptabilMy  in  receiving  hazardous waste  from CERCLA
     response  actions.

   0  RES certified LOIS compliance with the interim  status  ground water
     monitoring  regulations  in  1985 and was not considered  in significant
     non-compliance before  the  investigation.   RES has  followed the 1981
     State  AGO and, as  a result, has  installed  numerous monitoring  wells at
     various depths throughout  the site.   However, the  Task Force evaluation
     noted  a number of  violations  of  interim  status  standards which included
     deficiencies  in  waste  management practices and  ground  water Sampling and
     Analysis  Plan requirements.   The following is a more detailed  discussion
     of investigation findings  and conclusions.

1.  Ground Water  Monitoring  During  Interim Status

   RES documented  ground water  contamination  beneath its facility soon after
   operations  began in  1969.   The  first ground  water assessment study was
   submitted in  early 1972,  and by the  end  of the  same  year,  RES had installed
   25 wells, 6 of  which were  part  of  a  pumping  system.  The purpose of the
   pumping  system  was to intercept, pump, and decontaminate the underlying
   ground water.   RES continuously upgraded this abatement  system through
   agreements  with EPA  and  NJDEP,  a signed  1981 Consent Order with  NJDEP, and
   an unsigned 1983 Consent  Order  with  NJDEP.   RES' monitoring  system remains
   essentially unchanged since  1983 except  for  the addition of  several wells
   pursuant to a NJDEP  request  and RCRA requirements.   Currently, RES samples
   regularly from  approximately 55 monitoring wells.  The facility's abatement
   system utilizes 17 pumping  wells intermittently which pump an average of
   125,000  gallons per  day  of  contaminated  ground  water.

   In the late 1970s, as a  result  of  plant  modifications and  pressure from the
   regulatory  community, RES  began to scale down its operations and close
   many of  its hazardous waste  management units.   The only  remaining
   operational sources  of contamination are RCRA units.  These  include the 8
   unlined  L-series lagoons  and concrete-lined  treatment units, Basins B-206
   and B207.  While RES acknowledges  that the L-series  lagoons  leak contaminants
   into the ground water,  it contends that  the  other two RCRA units which are
   concrete-lined, adequately  contain wastes.   However, because these units
   treat the same  contaminated  ground water which  underlies them, a detection
   monitoring  program can not  detect  a  release  of  hazardous waste or hazardous
   waste constituents from  these units.    All 10 RCRA units, therefore, are
   in an assessment monitoring  program  which  is part of a larger site-wide
   assessment/corrective action program pursuant to a 1981  State ACO.  It
   should be noted that the  RCRA land disposal  units will cease accepting
   waste prior to  November,  1988.

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                                -6-
   While  RES  has  been  following the 1981 State AGO (and later updated their
   program  in accordance with an unsigned 1983 AGO), this investigation finds
   the  scope  of  RES' assessment program insufficient to adequately define the
   rate and extent of  migration of hazardous waste or hazardous waste con-
   stituents  or  their  concentrations in the ground water as required under
   40 CFR §265.93  (d)(4).  While the facility has installed numerous monitoring
   wells  at various depths throughout the site, several deficiencies in the
   system cause  it to  be inadequate to fully delineate the contaminant
   plume(s).   For  example, monitoring wells have been installed at RES for
   the  past 18 years yet are highly variable in quality.  Construction details
   for  many wells  are  incomplete or non-existent.   Some of the wells in the
   South  Marsh Area were driven as well points and were not meant to be used
   for  rigorous  ground water monitoring.  Poor well installation (inadequate
   annular  seals)  in some of the MA-series wells may, in fact, be a
   contributing  factor to deep ground water contamination in the North Marsh
   Area.  Also,  the sampling parameters which RES uses to define the
   contaminant plume (although specified in the 1981 State AGO) are
   insufficient  to delineate the extent of ground water contamination,
   particularly  with respect to organic constituents.

   This Task  Force recommends that RES significantly expand its sampling and
   analysis plan  to include specific organic constituents.  The horizontal
   and  vertical  extent of comtamination must be determined by using both
   organic  and inorganic parameters.  Specific areas which require more
   rigorous sampling include the North Marsh Area, the South Marsh Area, and
   the  shallow artesian zone (a deeper water-bearing zone) throughout the
   site.  Wells  of poor construction quality should be sealed and data
   collected  from  them be used in this context.  A future change to the plant
   site includes  the closure of the L-series lagoons which is to be initiated
   at the end of 1988.  Because their closure will affect ground water flow
   in the area (the L-series lagoons have acted as a ground water mound),
   this change should  be modeled now so that the abatement system can be
   modified as lagoon  closure occurs.  While the pump and treat abatement
   system has been a very positive element in RES' site-wide corrective
   action program, it  may also require modification once the full extent of
   ground water  contamination has been determined.   Finally, all previous
   data,  which include a wealth of well logs, well tests, and ground water
   analyses,  should be fully integrated with future work so that a clearer
   picture  of hydrogeology and ground water/soil contamination and,
   consequently, a more efficient and effective corrective action program at
   RES  can  be developed.


2.  Ground Water  Sampling and Analysis Plan

   Deficiencies  were  found in RES' sampling and analysis plan dated January,
   1987.  These  deficiencies vary from initial safety considerations at the
   wellhead to  inadequate analytical methods for TOX.  The plan lacks suffi-
   cient  detail  in explaining the methods used to detect immiscible contaminants

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                                 -7-


   and ensuring well  integrity (measurement  of total  depth  to monitor
   silting).   Deficiencies are noted  in  other  areas  of the  plan  such as
   purge methods,  field measurements, recordkeeping,  sampling,
   chain-of-custody,  well  construction,  and  analytical  methods.   Adequate
   cleaning procedures  for sampling equipment  must  be outlined and  the
   use of trip blanks needs to be detailed.


3. Audit of Currently Used Laboratories

   The evaluation  of  the analytical work of  the laboratories being  used
   by RES at  the time of this  investigation  is included in  the technical
   report.  Inadequacies were  found  in the  following  areas:

   a. RES' procedures for determining TOX levels is  inappropriate.   The
      methods being applied can miss  certain groups  of halogenated
      compounds and lack sensitivity  of  the  method  EPA considers  as
      appropriate  for TOX measurement (Method  9020  of SW-846).

   b. RES uses an  arbitrarily  chosen  detection limit  of 1 mg/1 for  TOX and
      does not report amounts  measured that  are under 1 mg/1.  Such practice
      does not allow  the data  user to identify or measure changes that
      occur when total  levels  present are less than  1 mg/1.

   c. The level  of quality assurance  and quality control practiced  in their
      TOX determinations does  not provide adequate  confidence in  the relia-
      bility  of the data for the compounds that are  determined by the RES
      procedure.


4. Well  Sampling Data Analysis

   Data  generated  as  a  result  of ground  water  sampling  by the Task  Force
   confirm ground  water contamination beneath  the RCRA-regulated  L-series
   lagoons and much of  the rest of the 78-acre facility.  Ground water from
   23 monitoring wells  was analyzed for  Appendix IX constituents.   The
   highest levels  of  contamination were  found  at wells  around the L-series
   lagoons, the Central  Plant  Area and in the  vicinity  of Well MA-1 in the
   North Marsh Area.   Contamination is not limited  to the upper  reaches of
   the water  table zone; the deeper wells in the North  Marsh Area showed
   contamination (particularly organics)  as  well.  Of the three  "shallow
   artesian zone"  wells  sampled in the deepest water-bearing zone at
   RES,  only  1 showed any significant levels of contamination.

   Monitoring  wells around the L-series  lagoons  showed  ground water with the
   highest concentrations  of dissolved solids.   For instance, the highest
   concentrations  of  the cations  calcium  (515  ppm) and  magnesium  (299 ppm) were
   found at Well 25,  near  the  northwest  corner of the L-series lagoons.  Sodium

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                                 -8-
   concentrations were very high in both the L-series  lagoon area (738 ppm -
   Well 25) and in isolated spots in the North Marsh  Area  (1,570 ppm - Well
   MA-2D).  The same is true of potassium (19.7 ppm -  Well  25,  54.4 ppm -
   Well MA-2D).  Total and dissolved metals  were high  along the periphery  of
   the L-series lagoons and at nested wells  MA-1 and  MA-2  in the North Marsh
   Area.  The highest nickel (150 ppm) and vanadium (.311  ppm)  concentrations
   were found in MA-2D.  Barium (.121 ppm),  iron (151  ppm)  and  manganese
   (2.44 ppm) concentrations were highest in MA-IS.

   While inorganic contamination is widespread at the  site, organic
   concentration is predominant in the North Marsh Area  (near MA-1  and
   MA-2) and in the Central Plant Area (Well 17).  For example  MA-IS contained
   the ground water with the highest concentrations of benzene  (3,100 ug/1),
   4-chloraniline (27,000 ug/1), toluene (1000 ug/1),  napthalene (1,000 ug/1)
   and other organics.  Well 29 was contaminated with  some  of the following
   organic constituents: trichloroethene (230 ug/1),  2,4 dichlorophenol
   (170 ug/1), and bis(2-chloroethyl) ether  (200 ug/1).  Shallow artesian  zone
   Well DP-5 was contaminated with 1,2-Dichloropropane (180 ug/1) and
   trichloroethene (20 ug/1).  Low levels of furans were found  in MW4 (HpCDF -
   20.1 ppt).  Many organic compounds were tentatively identified and need to
   be confirmed by using authentic standards for those specific compounds.

   The ground water analytic results  confirmed the presence of  organic and
   inorganic contamination in the ground water beneath the  RES  site.  The
   RCRA regulated L-series lagoons as well as various  solid waste management
   units (SWMUs) and hazardous waste  spills  on the site  have probably
   contributed to the degredation of the ground water.


5. Comprehensive Evaluation Inspection

   Observations of waste management procedures and a review of  records
   maintained at RES identified several  Class I and Class  II violations.
   These include:  labels not visible on a small  number  of  drums  on both pad
   #1 and pad #2; no waste analysis plan for outgoing  wastes; inspection
   schedule does not identify all  areas/items to be investigated  during  the
   inspection (Kiln ash area, sumps and  storage areas  where hazardous
   waste is stored for less than 90 days); inadequate  aisle space for four
   containers on drum pad #1; no written agreements designating primary
   emergency authority to a specific  police  or fire department; no  agreements
   with others to provide support to  the primary emergency  authorities;  no
   agreements with local  fire departments to inspect the facility on a
   regular basis with at least two inspections annually; contingency plan
   did not list addressess and phone  numbers (home) of all  persons  qualified
   to act as emergency coordinators to  include primary and  secondary; and  the
   closure plan did not adequately include decontamination  procedures during
   closure for drum pad #2 and Kiln ash  storage area.   Inspection of surface
   impoundments did not include inspection for the leaks, deterioration or
   failure in the impoundments.

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                                   -9-


                         II.   Technical  Report


A.  Regulatory Requirements

    In 1965, the Solid Waste  Disposal  Act was passed with the primary purpose
    of improving solid waste  disposal  methods.  It was amended in 1970 by
    the Resource Recovery Act, again in  1976 by the Resource Conservation
    and Recovery Act (RCRA).

    RCRA was enacted by PL 94-580, October 21, 1976; 90, 42 U.S.C. 6901
    et. seq.; amended by PL 95-609, November 8, 1978; PL 96-463, October 15,
    i960; PL-96482, October 21, 1980; PL96-510, December 11,  1980; PL
    97-272, September 30, 1982; PL-98-45, July 12, 1983; PL 98-371, July
    18, 1984; PL98-616, and November 8,  1984.

    The Resource Conservation and Recovery Act is currently divided into
    nine Subtitles, A through I.  Subtitles C, D and I lay out the framework
    for the three programs that make up  RCRA.

    Subtitle C of the Act establishes a  program to manage hazardous waste from
    cradle to grave.  The objective of this program is to assure that hazardous
    waste is handled in a manner that protects human health and the environ-
    ment.  The regulations are found in  the Code of Federal Regulations (CFR),
    Title 40, Chapter I, Subchapter I, Parts  264, 265 and 270.  As a result
    of the Hazardous & Solid Waste Admendments of 1984 (HSWA), new standard
    for treatment and disposal of restricted waste became effective on
    November 8, 1986.  These regulation  are found in 40 CFR Part 268.

    Section 3006 of Subtitle C of RCRA allows EPA to authorize a State hazardous
    waste program to operate in a State  in lieu of the Federal Hazardous
    Waste Program.  Under this section,  States could either apply for
    interim or final authorization.   Interim authorization is received in
    two phases: Phase I and Phase II.  Upon the State implementing a
    program "substantially equivalent" to the RCRA program the State can
    apply for final authorization, a program  equivalent to, and no less
    stringent than the Federal Program.

    The State of New Jersey received  Phase I  interim authorization on February
    2, 1983.  Phase I allowed them to operate the regulations covering 40
    CFR Parts 260 through 263, and 265.    Phase IIA and IIB interim authoriza-
    tions were granted to New Jersey on  April 6, 1984.  However, since
    New Jersey's application for Phase IIA and Phase IIB interim authorization
    was submitted after the deadline for  inclusion of surface impoundments
    (January 26, 1983), their interim authorization only included the
    responsibility for permitting storage and treatment in tanks, containers,
    and incinerators.  Phase II usually covers 40 CFR Parts 124, 264, and
    270.

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                                  -10-
    New Jersey  applied  for  permitting authority of land disposal  facilities
    on  August 3,  1984.   Their  revised and complete application  for  final
    authorization  was submitted  on  August 20,  1984.   EPA  published  its  intent
    to  grant final authorization effective on  February 21,  1985.  This  authori-
    zation  did  not include  authorization for the  Hazardous  &  Solid  Waste
    Admendments.

    New Jersey's  RCRA program  is run  primarily by Division  of Waste Management.
    However, since ground-water  protection is  delegated to  Division of  Water
    Resources,  they  take primary responsibility for  RCRA  ground-water  issues.
    New Jersey's  program is more stringent than the  Federal  program in  the
    following aspects:
        o
          Waste  oil  is  listed  as  a  hazardous  waste,  consequently, more
          facilities are  regulated;

        0  No  exemptions are  provided  from  the ground water  monitoring
          program;

        0  No  waivers are  granted  during  the  interim  status.


1.   New Jersey Department of Environmental  Protection Responsibilities

    NJDEP  is  responsible  for permitting  treatment,  storage, and  disposal  (TSD)
    facilities within the State of  New Jersey's  borders  as  well  as  carrying
    out the other aspects of the  RCRA program.  NJDEP is also  responsible for
    enforcement.  Further, NJDEP  must assist  EPA in  the  implementation  of the
    Hazardous and Solid Waste  Amendments of 1984 (HSWA).

 2. Environmental Protection Agency's Responsibilities

    EPA provides the State of New Jersey with Federal funding.   EPA regularly
    evaluates New Jersey's administration  and enforcement of its hazardous
    waste  program to ensure that  the  authorized  program  is  being implemented
    consistent with RCRA.  EPA also retains  the  right to conduct inspections
    and request information under Section  3007 of RCRA,  and to  enforce  certain
    provisions of New Jersey State  law.   Currently,  under Section 3006(g) of
    RCRA,  42 U.S.C. 6226(g), the  new  requirements and prohibitions  imposed
    by HSWA take effect in authorized States.  EPA must  carry out these
    requirements until  the States are authorized for HSWA.   Therefore,  EPA
    will administer HSWA  in New Jersey until  New Jersey  applies  for and
    receives authorization for HSWA.   Therefore, EPA's direct responsibilities
    include:
            0 Waiver requests;
            0 Solid Waste Management Units (SWMU);
            0 Land Disposal  Restriction; and
            0 Corrective Action

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                                    -11-
B. Investigation Methods and Procedures


    The Hazardous Waste Ground Water Task Force Investigation of RES facility
    consisted of:

        0 Reviewing and evaluating records and documents from EPA Region II,
          New Jersey Department of Environmental  Protection and RES (NJ);

        0 Conducting a Compliance Evaluation Inspection (i.e., visual  inspec-
          tion of waste management units, operation,  manifests);

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

        0 Sampling and analyzing data from selected  ground water monitoring
          wells.

        0 Conducting a Comprehensive Ground Water Monitoring Evaluation (CME).

    1.  Records/Documents Review

       Records and documents from EPA Region II and  the New Jersey Department
       of Environmental  Protection offices compiled  by an EPA contractor, were
       reviewed prior to and during the on-site inspection.  On-site facility
       records were reviewed to verify and supplement information currently in
       Government file.   Documents requiring further  evaluation were copied by
       the Task Force during the inspection.  Information regarding facility
       operation, construction details of waste management units and ground-water
       monitoring program were reviewed.

       Specifically, records and documents that were  reviewed included the ground
       water sampling and analysis plan (s), outline  of the facility ground water
       sampling, monitoring  well  construction data and logs, site geologic report,
       site operation plans, facility permits, waste  management unit design and
       operating records showing the general types,  quantities and location of
       wastes disposal  of at the facility.

       Generally, records and documents were also reviewed to address  compliane
       with administrative,  non-technical  and technical  requirements of 40 CFR
       Part 265, Subparts B  through R and the New Jersey Administrative Code
       7:26-6,7,8,9 and  11 et seq.

    2.  Comprehensive Ground  Water Monitoring Evaluation

       This evaluation composed of an office and  field evaluation.  The emphasis
       was to determine  compliance with the Federal and State of New Jersey
       interim status ground-water monitoring requirements (40 CFR Part 265
       Subpart F and N.J.A.C. 7:14A - 6.1 _ejt _se_£.)•   Compliance with the require
       ments of 40 CFR Part  264 Subpart F was also investigated.

       All  existing records  and documents from NJDEP  and EPA - Region  II were
       compiled by a contractor working for EPA - Headquarters.

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                                 -12-


   Each participating group (Region, State and Headquarters)  reviewed the
   materials prior to the on-site inspection to generate information covering
   the following:

     0 Probable areas of noncompliance with 40 CFR Part 265 Subpart F
       requirements;

     0 Probable existence and nature of contamination of the  ground water;

     0 Other shortcomings in monitoring system design and operation;

     0 Validity and comprehensiveness of existing data;

     0 Useful  activities to be conducted during the site inspection;

     0 Effectiveness of corrective action or closure operations.

   Several  meetings were held between EPA-Region II and NJDEP to  discuss
   the site and choose sampling locations for the inspection.  Site
   reconnaissance was conducted to verify the practicality of the inspection
   strategy and familiarize the Task Force members with RES facility.

   Twenty three of possible 130 wells were selected for sampling.  One field/
   equipment blank was taken per day of the inspection.

   The "Characterization of Site Hydrogeology Worksheet" from the draft ver-
   sion of the RCRA Ground Water Monitoring Technical  Enforcement Guidance
   Document was used as a guideline for the office evaluation.   The Work-
   sheet questions were answered using the Part B and any supporting docu-
   ments supplied by RES.  Further, several  interviews were conducted per-
   taining  to  hydrogeology and the ground water monitoring system.   One of
   these interviews was conducted on Tuesday February 17, 1987  where RES
   was represented by their hydrogeological  consultant,  Geraghty  &  Miller, Inc,

3.  Ground Water Sampling and Analysis

   During the  inspection, Task Force personnel  collected samples  for analysis
   from twenty three ground water monitoring wells to determine if  the ground
   water contains hazardous waste constituents  or other  indications of con-
   tamination.  Wells were selected for sampling principally  in areas where
   records  show or suggest that ground water quality was affected by hazardous
   waste management activities.

   All  wells were purged of at least three well  casing volumes  of water with
   either a teflon bailer, stainless steel  bailer or a stainless  steel  sub-
   mersible (grundfos sp-2).   The grundfos pump used to  purge three wells was
   field decontaminated between each use by operating  the pump  in a de-ionized
   water and non-phosphate soap solution, followed by operation in  de-ionized
   water as a  rinse.   The outside of the pump and the  first ten feet of cable

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                                 -13-
   were then wiped down with hexane and allowed to dry.   All  other purging
   and sampling equipment was laboratory cleaned and  prepared prior to use.
   Purge water was measured for pH, temperture, and conductivity at the be-
   ginning, middle and end of purging.   All  samples were collected with a
   teflon or stainless steel bailer.

   Twelve field/equipment blanks were also taken during  sampling at RES.
   Following the collection of the samples,  EPA's contractor, Alliance,
   placed the samples in coolers containing  ice.  Samples were preserved,
   and if necessary, filtered upon return to the staging area.  Packaging
   was conducted in accordance with applicable Department of  Transportation
   regulations for shipment to the EPA contract laboratories.  As
   required under RCRA (40 CFR 265.92(a)(4)) , receipt for samples were
   offered to and signed by facility personnel.  Samples were split
   with the facility.


4. Evaluation of On-site and Off-site Analytical Labs

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

5. Compliance Evaluation Inspection

   The Compliance Evaluation Inspection conducted in  February, 1987, included
   identifying past and present waste management units and reviewing waste
   management operations.  The units were reviewed to  address the technical
   requirements of 40 CFR 265 Subpart I-R and  N.J.A.C. 7:26-9,11 et seq.

   The inspection procedures to verify  compliance with these  Subparts included  a
   series of checkpoints and documentation,  and use of the New Jersey RCRA
   inspection checklist.

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                                -14-
C.  Facility Description

     1.  General  Information

        In 1970  Rollins-Purle,  Inc.  began  operation  of a  waste disposal  at
        Bridgeport, New Jersey.   Following a  number  of reorganizations,  the
        owner-operator is now known  as Rollins  Environmental  Services  (NO)
        Inc., a  New Jersey Corporation.   Rollins  Environmental  Services  (RES)
        with head offices in Wilmington,  Delaware,  is  a publicly-held  company
        with shares traded on the  New York Stock  Exchange.

           Facility Address:  Rollins Environmental  Services  (NJ)
                              Route  322 and Route 295
                              Bridgeport  N.J. 08014

           Mailing Address:   Rollins Environmental  Services  (NJ)
                              P.O.  Box 337
                              Bridgeport  N.J. 08014

           Telephone Number:  (609)  467-3100

           Facility Contact:  Donald J.  Frost
                              Technical Manager

           Facility Owner:    Rollins Environmental  Services

           Facility ID #:     NJD  053 288  239

           Type  of Operation: Transportation, storage, treatment and
                              disposal of  hazardous  waste

 2. Description  of Facility Operations

    A general description of the facility  operations will be  given here.
    A more detailed description  of each waste management  unit can  be found
    in the RCRA  inspection report.

    RES is a 78-acre commercial  treatment, storage  and disposal  facility
    located in Bridgeport, New Jersey.   The facility has  been in operation
    since 1969.   RES'  incinerator  was built in  1969  and commenced  operation
    in 1970.  The facility accepts  a wide  range of  hazardous  waste: pesti-
    cides - DDT  and Lindane; halogenated aliphatic  hydrocarbons; monocyclic
    aromatics; phthalate esters; polycyclic aromatics; ketones; alcohols;
    and miscellaneous  volatiles  (acrolein, ethylether, and, acrylonitrite).
    Incineration is the only commercial operation at the  facility.  The
    biological treatment system  is  used  for the treatment of  wastes generated
    on site (contaminated ground water and sanitary  wastes).   Besides  the
    biological treatment system  impoundments  (B-206, B-207),  all other
    treatment units have been discontinued.  RES  (NJ)  is  the  only commercial
    hazardous waste incinerator  facility  in Region  II.

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                                  -15-
   In  December,  1985,  the  facility  submitted  a  revised  Part A application
   for the  following  processes:
       Unit

       SOl-storage  in  containers

       S02-storage  in  tanks

       S04-storage  in  surface  impoundment

       TOl-treatment  in  tanks

       T03-Incineration
                Capacity

                121,550 gallons

                406,000 gallons

                3,000,000 gallons

                6,813,300 gallons/day

                19.7 tons/hr
   Currently,  RES  operates  the  incinerator  under  interim status  regulations.
   Wastes  are  incinerated  in  gaseous,  liquid  and  solid  form.   Incinerator
   ash,  formerly landfilled on-site, is  now transported to secure hazardous
   waste landfills elsewhere.   Eight interconnected  unlined surface  impoundments
   (called L-Series lagoons)  receive scrubber wastewater from  the incinerator
   for cooling.  Two concrete lined biological  treatment surface impoundments
   are used to treat contaminated  ground water  from  18  pumping wells on-site.
   All 10  units are RCRA regulated and discharge  to  Raccoon Creek under the
   terms of RES's  NJPDES permit.   RES  plans to  close all its RCRA surface
   impoundments.   A closure/  post-closure plan  was submitted for all
   process water discharge  lagoons.  Above  ground tanks will be  installed
   to  replace  the  10 storage  and treatment  surface impoundments.


3.  Solid Waste Management  Units  (SWMUs)

   Solid waste management  units  include  any discernable waste  management unit
   from  which  hazardous  constituents may migrate, irrespective of whether the
   unit  was intended for the  management  of  solid  or  hazardous  wastes.  The
   following type  of units  are  therefore included in the definition of SWMUs:
   landfills,  surface impoundment, waste piles, land treatment units, incine-
   rator,  injection wells,  tanks (including 90  days  accumulations tanks),
   container storage areas  and  transfer  stations.  In addition to these types
   of  units, certain areas  associated  with  production processes  at facilities
   which have  become contaminated  as a result of  routine, systematic and
   deliberate  releases of  wastes,  are  also  considered to be solid waste
   management  units.  A  product may become  a  waste if it is abandoned or
   discarded.

   The SWMUs identified  by  NJDEP and EPA at the site include:

      ff of Units           Descriptions
           11
Unlined lagoons closed as a landfill  in  1978
(NJDEP approved closure)

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                              -16-
# of Units           Description
2                    Cemment vaults containing  3695  cubic  yards
                     of drummed arsenic salts.

15                   Lined surface impoundments closed  in  1978
                     (NJDEP approved closure)

21                   Tanks to store various aliphatic aromatic,  in-
                     cluding PCBs.  Destroyed  by fire in  1977

1                    Trickling filter unit, used to  treat  contaminated
                     ground water, closed in 1979

2                    Container storage pads, in operation  from 1973-1978

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                                 -17-
D.  Ground Water Monitoring Program During Interim Status

1.  RES Compliance History


    a. Early Plant History - 1970s

    Rollins Environmental Services (RES) was constructed in 1969 as a disposal
    site (Figure 2) for a wide range of of industrial  process wastes.  Several
    processes employed at the site, which included incineration, biological
    and physical-chemical treatment and landfill ing, were applied to the
    disposal of various classes of wastes.  Throughout the 1970s the facility
    incurred numerous operational  problems and was subject to almost continuous
    modification.  By 1971, approximately 18 basins of varying sizes and
    construction quality were developed on the site (Figure 3).   Initially six
    of these basins were clay lined; these included receiving and neutra-
    lizing basins as well as the organic filter beds which were  supposed to
    provide biological degradation of organic wastes.

    It became apparent in 1971 that the basins were leaking and  causing
    contamination of the ground water.  The first confirmed evidence of
    ground water contamination at  RES was gathered in  1971.  Analyses of
    samples from shallow monitoring wells at the  site  showed elevated levels
    of acidity, total dissolved solids, nitrates, and  metals.  The facility
    was ordered by the State to commence decontamination activities on
    October 20, 1971.  In reports  dated April, 1972 and October, 1972, RES'
    consultants, Geraghty and Miller, Inc., provided results of  a ground
    water contamination study and  submitted a proposed abatement program.  By
    this time RES had installed approximately 25  wells, all of which were
    screened in the water table aquifer.  Six of  the wells were  abatement
    wells for the purpose of intercepting, containing, pumping and decontami-
    nating ground water.   This abatement program, the  details of which are
    sketchy, presumably began shortly after a second State Order was issued
    on October 20, 1972.   It was also agreed that RES  would initiate a program
    to reline (with concrete, soil-cement and plastic) or eliminate the
    unlined basins at the facility.

    The ground water remediation program continued through the 1970s.  In
    1975, deeper wells were installed to monitor  the shallow artesian zone.
    Wells were continually added to the monitoring system.  Evaluations were
    made on the abatement system in 1975 and 1978 by Geraghty and Miller,
    Inc.  Based on their recommendations, the system was modified with the
    addition of more abatement wells.   A more detailed discussion on the
    history of RES'  ground water monitoring system will  be presented in
    subsequent sections.


b.  Events Surrounding the 1981 Administrative Consent Order

    In December of 1977,  a fire and explosion occurred in the tank farm area
    of the facility. Eighteen of thirty-one tanks were destroyed.  Corrective

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                                       -18-
(a)
(b)
      Figure 2.  Location of RES (NJ) facility with respect to  (a) the Delaware
                 River and surrounding townships and  (b) counties within the
                 state of New Jersey.  From RES  (1985) and Hardt  (1963).

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ro
U)
                                                                                        • E    Well Location
                                                                                       • ——    Active Facility Boundary
                                     Rollins  Environmental Services Facility Map - 1972

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                              -20-
actions included the removal  of the top foot of soil  in the area as  well
as the removal  of approximately 120,000 gallons of contaminated  liquids
and firewater.   As a result of the incident various organic contaminants
were released to ground and surface water.   Organic contamination is most
prevalent near  the North Marsh Area with the highest contamination being
found in water  samples from Well  4A.  As a  result of the explosion and
fire, NJDEP ordered RES to cease  operation  in 1977.  On June 9,  1978,
Rollins was issued a reopening Order.   To comply with the Order, RES was
required to submit annual  ground  water reports and submit closure plans
for the B-series units (now the Basin  Closure Area) in the northeastern
portion of the  facility.  NJDEP began  monthly Inspections at the facility.

Between 1970-1974 an "arsenic dump" (Figure 3) was in operation  adjacent
to B-202G in the Basin Closure Area.  The facility contends that this
area is a "vault" lined in concrete where sealed drums of arsenic were
disposed.  An internal NJDEP memo dated March 4, 1980 noted that there
were no wells in the immediate area.  It was recommended that a  ground
water monitoring well  be installed in  the "immediate vicinity of the
arsenic dump in order  to monitor  possible ground water contamination."
In June, 1980,  RES submitted arsenic analyses from wells south of basin
B-202G.  Although sampling results indicated that there were arsenic
levels above background (0.36 ug/1 at  Well  G) at the facility, it could
not be shown that the  contamination was directly attributed to the arsenic
vaults.

On September 22, 1980, RES was issued  a Temporary Operating Authorization
(TOA) requiring the facility to discontinue disposal  of hazardous wastes
into Basins B-202G and B-205C (Figure  4).  RES contested this decision and,
as a result, an Administrative Consent Order was entered into on October
29, 1980, by the facility and NJDEP.  The Order included the following
specific requirements:

1) RES was to discontinue depositing waste  materials in any basin or
   land depression except for B-202G and B-205C which were subject to
   the terms and conditions of the Order.  RES could continue to deposit
   incinerator scrubber sludges in settling lagoons (L310-L317)  in
   compliance with their then current NJPDES discharge permit.

2) RES was to repair the existing liner of B-205C and place an impermeable
   liner on top of material in the basin.  These tasks were to be completed
   by December 31, 1980.  During this time  B-202F was to be used as an
   interim storage location.  After reparations all wastes which had
   accumulated in B-202F were to be transferred back to B-205C.   RES was
   also to repair B-202G.

3) All wastes placed  in B-205C subsequent to September 22, 1980, would
   be subject to a solidification/stabilization process.  The Order set
   out a work schedule with compliance dates for the development and

-------
(D
                                                                             Well Location

                                                                             Active Facility Boundary
                                                                                                                     i
                                                                                                                    to
                               Rollins Environmental Services Facility Map -  1980

-------
                               -22-
   implementation of this process.   This would all  be incorporated into
   a phased closure of the Basin Area  which would  take several  years.

4) A formal Basin Closure Plan was  to  be submitted  to NJDEP by December
   1980, for approval.

RES submitted a Basin  Closure Plan  prepared by Geraghty and Miller
to NJDEP on June 27, 1980.  It was  subsequently revised and resubmitted
on June 12, 1981 along with a Plan  by  Weston (for  engineering and
design).  These plans  incorporated  the on-going solidification process
outlined in the compliance schedule of the October  29, 1980 ACO.
NJDEP reviewed the plans and proposed  minor modifications.   These
minor modifications were incorporated  into an addendum dated July 22,
1981.  The Basin Closure Plan was a phased plan whereby the basins
would be closed in sequence.  Those basins which lay in the water
table would have the waste removed  and stabilized,  a soil  base
installed, and wastes  redeposited by compaction.  A polyethylene  cap
would cover the Basin  Closure Area  followed by a flow zone  and
vegetation.  Ground water monitoring and neutron probes were to be the
major method by which  the adequacy of  the closure  would be  measured.
The purpose of the cap was to inhibit  the infiltration of surface
water into the closed  basins.  This would reduce the quantity of
leachate generated from the basins  and aid in overall ground water
decontamination at the site.  Although neutron tubes are in the ground,
the neutron probe program is still  non-existent and ground  water
monitoring around the  area is inadequate.

On September 23, 1981, NJDEP issued an Administrative Order to RES which
addressed the entire ground water monitoring program at the site.  This
order included the following specific  requirements:

1) RES was required to complete an  investigation of ground  water
   contamination found in the North Marsh Area by September 30, 1981.
   Wells were to be installed as part  of this study (the MA series).
   New abatement wells were proposed (30 series).
2) RES was required to install four monitoring wells (AV series)
   monitor the arsenic vaults by September 30, 1981.
                                                              to
3)
4)
RES was to conduct a pump test;
installed through this Order).
utilizing Well  DP4 (a well  to be
RES was to change their monitoring well  configuration by sealing some
wells that were no longer used and adding wells in locations where
information was lacking or where wells of poor construction quality
were to be replaced.

-------
                                  -23-
 5)  RES  was  to  plan  and  implement  an  abatement  system  such  that  the  abatement
    wells  yielded  sufficient  ground water  to maintain  a  hydrologic barrier
    to  prevent  off-site  migration  of  contaminants.   The  Order outlined
    some specific  conditions  of  the planned system.  The yield was not  to
    be  less  than  15  gpm  for any  well  and a pumping  schedule was  to be
    supplied.   RES was to  implement the system  by March  1,  1982.

 6)  RES  was  required to  sample specific wells for specific  parameters.
    28  wells were  to be  sampled  quarterly  for TDS,  TOC,  pH  and TOX.   19
    wells  were  to  be sampled  on  an annual  basis for an expanded  list
    which  included the above  parameters along with  these additional
    parameters: arsenic, cadmium,  chromium (total), copper, lead,  zinc,
    nitrate  as  nitrogen  and phenol.   15 wells were  to  be sampled  quarterly
    for  arsenic and  4 wells quarterly for  PCBs.

 7)  RES  was  to  incorporate the new marsh wells  into this monitoring  program
    if  contamination was found.

 8)  RES  was  to  continue  to submit  annual ground water  monitoring  reports.

 9)  RES  was  to  implement the  Basin Closure Plan as  described in  the  Geraghty
    and  Miller  Basin Closure  Plan  of  June  12, 1981, the  Westin Basin Closure
    Plan of  June  12, 1981  and the  addendum to the RES  Basin Closure  Plan of
    July 22, 1981.  These  plans  would be implemented after  approval  by  the
    Delaware River Basin Commission which  reviewed  the ground water  aspects
    of  the plan.   RES was  still  responsible for submitting  a specific monitor-
    ing  plan for  NJDEP approval.

10)  RES  was  to  implement a program to "Characterize Waste  Through  Ground
    Water  Monitoring" by sampling  5 wells  in the Basin Closure Area. RES
    was  to submit  this report by October 31,  1981.

 On  September 30,  1981 RES submitted  a report,  "Investigation of  Ground
 Water  Quality  Conditions  in  the Marsh Area in  the  Northwest Corner  of  the
 Rollins Environmental Service  Plant, Bridgeport, New  Jersey."   The  report
 addressed the  requirements of the above Administrative  Order.   Wells to
 monitor contamination near the  arsenic vaults  were also installed;  however,
 two of the  wells  were not installed  according  to required  specifications
 and had to  be  redrilled.  RES  installed Well DP4 on October 5th  and 6th
 and conducted  a  well test on October 15th and  16th.  On November  23, 1981,
 Rollins and NJDEP entered into  an Administrative Consent  Order.   This
 order  addressed  some of the  submittals of September 30, 1981 and  also
 made some stricter  requirements for  sampling parameters.   Otherwise it
 was similar to the  previous  AO.   It  included the following:

 1)  RES  was  required to  replace  monitoring wells AV-3  and  AV-4 which were
    installed improperly around  the arsenic vaults.

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                                  -24-
   2)  By  November  6,  1981, RES was to submit the findings of the shallow
      artesian well test.  The purpose of the well test was to determine
      the extent of hydraulic connection between the water table aquifer
      and the shallow artesian zone as well as aquifer characteristics of
      the shallow  artesian zone.

   3)  RES was to sample  23 wells for the expanded list of parameters referred
      to  in  the previous Order.  This included the deep wells which were
      previously only to be sampled for TDS, TOC, pH and TOX.  Besides
      these  changes most conditions of this Order were similar those of the
      Administrative  order outlined above.

   Subsequent to the  Order, several revisions were made based on yearly
   ground water reports  and the Abatement Well Testing Program Report of
   August, 1982.   More abatement wells were added in 1982 and 1983 and
   pumpage rates were again revised.  On August  1, 1983 a new draft
   Administrative  Consent Order was circulated for comment.  This Order
   was never finalized;  however, RES contends that they presently follow
   the intent of the  Order in good faith.  By mid-1983 eleven additional
   abatement wells were  added to the system.  The efficiency of each
   well was  evaluated and new pumping rates were determined.  By June,
   1983,  RES was averaging a monthly pumping rate of 40 gallons per
   minute.  Soon after the draft 1983 Order was  issued, the pumping rate
   was increased to 100  gallons per minute.

   On  September 11, 1984, RES met with the State to again modify their
   ground water monitoring program.  This modification, however, which
   included  the deletion of some wells from the  sampling program and the
   addition  of others was not agreed upon and never followed.  The
   monitoring/abatement  system has not changed dramatically since 1983
   when the  system was upgraded.  By 1983 all wells in the Basin Closure
   Area were removed  because of closure operations.  On October 16, 1983,
   NJDEP  prepared  an  "Environmental Assessment"  of RES.  The original
   purpose of developing this extensive document was to address the
   issue  of whether or not PCBs could safely be  incinerated at the RES
   site.   With time,  however, the  project expanded and became an in-depth
   study  of all aspects  of the environment (air, surface water, ground
   water) which could be affected  by any past and present operations at
   the facility.   The report concluded that while contamination existed
   in  the water table aquifer  (shallow aquifer)  and minor contamination
   existed in the  shallow artesian  zone  (deeper  aquifer), the remediation
   efforts underway at the facility  (expanded abatement system and Basin
   Closure)  "should produce  positive results  in  the future."


c. Part B Submittal and  LOIS  Certification

   In  March, 1985, RES submitted a  RCRA  Part  B application which addressed
   ground water monitoring requirements  at surface  impoundments.   RCRA
   regulated surface  impoundments  (units which accepted waste on or after

-------
                              -25-


November 19, 1980) included the unlined L-series lagoons and biological
treatment surface impoundments B-206 and B-207.   On May 2, 1985, NJDEP
informed RES that they did not have an adequate  ground water detection
monitoring program pursuant to 40 CFR 265.90 and N.J.A.C. 7:14A-6.3.
Although NJDEP recognized there were many existing monitoring wells at the
facility, RES was still  required to implement a  separate ground water
detection monitoring program for the RCRA impoundments per N.J.A.C. 7:14A-6.3.
RES was warned that if they did not comply with  these requirements they
would not be able to certify compliance by November 8, 1985 (the LOIS
deadline) and their Interim Status would be terminated.

RES responded on May 17, 1985, by referring to the 1981 AGO.  They described
the specific requirements of that Order as an Alternative Monitoring Program
which they felt complied with the NJDEP's request.  RES, however, installed
new wells around the B-206 and B-207 impoundments to satisfy one of the
specific requests of NJDEP's May 2 letter.

On August 20, 1985, NJDEP issued a formal Notice of Deficiency (NOD) in
response to RES' March, 1985, Part B application submittal.  RES resub-
mitted the Part B application in December, 1985.  On December 3, 1985 a
LOIS (Loss of Interim Status) inspection took place at the facility.  As a
result of the inspection, RES was found to satisfy the minimum requirements
of LOIS for both ground water monitoring and financial responsibility.  It
is important to note that, even though they passed the ground water
inspection for minimum physical compliance (1 upgradient well, 3 downgradient
wells), it was not an evaluation of the technical adequacy of the system.
On April 17, 1986, NJDEP sent an NOD to the facility in response to RES'
latest Part B submittal.  The State found RES' application deficient with
respect to ground water monitoring requirements.  The State requested the
submission of closure plans for the L-series lagoons and the biological
treatment surface impoundments B-206 and B-207.   The following is an
outline of the specific ground water deficiencies and the request for
information:

1) Interim Status ground water monitoring data:

   -  a request for information regarding statistical analyses

   -  a sampling and analysis plan

2) Topographic map

   -  a need to submit a topographic map which delineates the hazardous
      waste management area and points of compliance for the L-series
      lagoons and B-206 and B-207.

3) PI ume description

   -  RES should provide a description of any plume of contamination
      entering the ground water.  NJDEP deemed the total dissolved solids
      (TDS) contour which had historically outlined contamination to be
      inadequate.

-------
                                 -26-
4) Ground water monitoring program

   -  RES needs to implement an adequate detection  monitoring  program
      to determine whether B-206 and B-207 are leaking.   The  program
      has to take into consideration the types of hazardous material  in
      the impoundments and their effects on liner materials.

   -  A corrective action program now being implemented  is  inadequate.
      RES must determine the rate and extent of contamination  at the
      site.  This includes an evaluation of each hazardous  constituent
      (only indicator parameters were used in the past)  found  in the
      ground water.

RES responded to the NOD on May 15, 1986.  Their submittal  also  included
an Interim Status Facility Partial Closure and Post-Closure  Plan for all
RCRA surface impoundments.  In their response, RES  delineated  30 wells  to
be used as a part of a long-term assessment program.  These  wells would  not
monitor a specific RCRA unit, as RES contended several  plumes  at the site
could not be differentiated; therefore, the system  would consider the
entire plume area.  This new monitoring program was a significant revision
from the program in the NJDEP 1981 Consent Order which  required  RES to
monitor 45 wells.  RES contended that the analytical  suite  would be expanded
to make the new system a more efficient and effective one.   RES  argued
that a statistical analysis was unnecessary as the  facility was  in a State
Corrective Action Program and, although it argued that  B-206  and B-207
were not leaking, the facility would treat these units  as if  they were
(i.e., these units would be in Corrective Action as well).

With respect to NJDEP's request for information concerning  site  hydrology,
RES referred the State to reports prepared as a result  of a  shallow artesian
zone well test in October, 1981, water table zone well  tests  in  July, 1982,
and assorted well logs.  RES sent a new topographic map  delineating RCRA
regulated units and points of compliance.  In response  to NJDEP's request
for RES to identify the concentraction of each of the hazardous  consti-
tuents in the contaminant plume, RES developed a new analytical  sampling
suite for interim status wells.  RES contended that,  although  they felt
that they had adequately delineated the plume in accordance  with the 1981
AGO, they would agree to "supplement this information."

At the time the response to the NOD was sent (May,  1986), RES  was almost
finished with closure of its Basin Closure Area.  RES reviewed what had
been done to date:  closure of Category A (basins B-204, B-210,  B-211,  and
the arsenic vault), Category B (basins B-202E, B-202F),  and  Category C
(basins B-201, B-202A through D, B-202G, B-203).  RES contended  that all
waste was stabilized using pozzolanic material  and  raised 2  feet above
the maximum anticipated ground water elevation.  A 60 mil polyethylene
liner was place over Category B and C basins.  In May of 1986, RES was

-------
                                 -27-
   placing a final  cover of top soil  and seed; closure was completed by the
   end of June, 1986.   RES believes that closure of the L-series lagoons and
   B-206 and B-207, along with operation of the ground water abatement system,
   will "further enhance the improvement in ground water quality".
d. Situation at the Time of the Task Force Inspection

   Presently, the biological  treatment system (B-206, B-207)  receives on-site
   generated sanitary wastes and ground water captured by the on-site abate-
   ment well system.   After treatment this waste is fed into  the L-series
   lagoons and discharged to Raccoon Creek under a NJPDES Permit after
   being combined with scrubber effluent in the cooling process.  Closure
   plans are currently being reviewed for both the L-series lagoons and
   B-206 and B-207.  Under Federal  regulations these units cannot accept
   any waste after November 8, 1988.  RES has submitted plans for above
   ground tanks to replace these units as well as plans to install  storm
   water retention basins.

   In May, 1985, the State issued a draft modification to the existing
   NJPDES discharge permit which included ground water monitoring.   The
   draft permit went through the public comment stage but has not been
   sent to RES for final ization.  There are some major differences  between
   the State's monitoring plan and that supplied by RES in their NOD
   response.  Currently, RES is following neither plan.  The  Facility is
   conducting a ground water program pursuant to the November 1981  AGO
   along with modifications made in 1983.

   In November, 1985, RES added 8 wells to the monitoring system as to comply
   with the LOIS requirements.  Although RES has been in compliance with
   the 1981 State ACO along with subsequent revisions, the facility has
   still not adequately addressed the rate and extent of contamination at
   the site pursuant to 40 CFR 265.93(d).

-------
                                   -28-


2.   Regional  Setting


    a. Physiography

    New Jersey may be divided into  four  physiographic  provinces:   Valley
    and Ridge, Appalachian  Highlands,  Piedmont,  and  the  New Jersey
    Coastal  Plain.  Rollins Environmental  Services lies  within  the New
    Jersey Coastal Plain, a province which encompasses  4,200 square
    miles and extends from  Raritan  Bay to  the  northeast  to  Delaware Bay
    to the southwest (Gill  and Farlekas, 1984).   It  is  bounded  to  the
    east by the Atlantic Ocean and  to  the  west by the  Fall  Line, a
    geologic  contact zone between the  consolidated rocks of the Piedmont
    and Highlands and the unconsolidated sediments of  the Coastal  Plain
    (Figure 5).  The New Jersey Coastal  Plain  is part  of the larger
    Atlantic  Coastal Plain  that extends  from Florida to  Newfoundland
    and eastward to the edge of the Continental  Shelf  (Zapecza, 1984).

    Another physiographic feature is the drainage divide (Figure 6).
    Approximately 55% of the stream flow within  the  New  Jersey  Coastal
    Plain drains in an easterly direction  into Raritan  Bay and  the
    Atlantic  Ocean while 45% flows  toward  the  Delaware  River and  Delaware
    Bay (Vowinkel , ^t al.,  1981).  Rollins, which is only 2.5 miles
    from the  Delaware River, lies within the Delaware  River Drainage
    Basin.


 b. Geologic  Setting

    The New Jersey Coastal  Plain is underlain  by a wedge of unconsolidated
    sediments that thickens seaward, from  a thin veneer  at the  Fall Line
    and Delaware River to a thickness  of over  6,000  feet at the tip of
    Cape May  County, New Jersey (Richards, Olmsted,  and  Ruhle,  1962)
    (Figures  7 and 8).  The bedrock surface of this  wedge dips  yently
    to the southeast at 10  to 60 ft/mi.

    Unconsolidated sediments of the Coastal Plain range  in age  from Cretaceous
    to Holocene.  For the most part, these sediments are composed  of clay,
    silt, sand, and gravel  whose depositional  environment ranges  from
    continental to marine-type.  The  initial deposition  of these  sediments
    began during the Late  Jurassic  or  Early Cretaceous  during the  early
    stages of the formation of the  Atlantic Ocean.   Deposition  was
    directly influenced by  basement highs  and  lows which formed as a
    result of block-faulting during intial sea floor spreading.  Basement
    consists  of gneiss and  schists  (Wissahickon  Formation)  of Precambrian
    age.  The contact between bedrock  and  the  overlying  unconsolidated
    sediments is usually defined by a  saprolite  or weathered zone
    (Zapecza, 1984).

-------
                                    -29-
                                               10     20    30MILE3
                                                I       I      i
                                               ^^^^^^^^^^^^^^^^^^^^^
i—i—T—r	•
0  10 20  90 KILOMETERS
                        I
Figure  5.   New Jersey Coastal Plain and fall line.  Fran Zapezca  (1984)

-------
                                 -30-
         EXPLANATION
            Major Streaia Divide



         ""  Drainage Divide
                      s .**- /
    —\    f  ^
4«• .„ \	<,
Figure 6.  Drainage basins in the New Jersey Coastal Plain.   From Volwinkel and
          Foster (1981).

-------
                                               -31-
                                                             Atlantic City

                                                                  A'
level
                                                                                  EXPLANATION


                                                                                 Composite confining layer
                                                                                 and minor  aquifer


                                                                             rSf Confining layer
      Not to scale
     Figure 7.  Generalized hydrogeologic cross-section showing dipping bedrock (pre-Cretaceous)  and
               unconsolidated sediments in the New Jersey Coastal Plain.  From Walker  (1983).

-------
                                       -32-
                                                                          T4»OO'
                                                                     Q#*   S

                                                                ''      f
                                                               Altitadt of mil

                                                            Valnn muulMi to numt S f«*t.
        r*   I
     z.    (/
                                    ,'-'  } .'-' J.<*&
   fm-   I      ^——--

       I    -x       '
          ,
       I  '       f

        '
                                                  G«n»r*llied atrarturc contour  on vn-
                                                   Crttacmui bedrock tortice. Altitude in
                                                   feet: datunt » mnn M* 1'vei. contour
                                                          f«t.
                                                          Mwine »nd
                                                        (4) Kumu*Mn. Sl*ojtht*r. Hulme.
                 «  ;  / /  /   >
                                                                                      JO'
               VH/I  #
Figure 8
   Generalized structure contour (altitude in feet; datum is rnean sea level)
"   oT^e-Setaceous bedrock surface in the New Jersey Coastal  Plaxn.

   Fran Parker et  al.  (1964).

-------
                                 -33-


   the oldest group of sediments deposited on the Precambrian Wissahickon
   Formation consists of Cretaceous continental  deposits of the Potomac
   Group.  This unit consists of alternating clay, silt, sand, and gravel
   and is a major part of the thick sedimentary wedge in extreme southern
   New Jersey.  The overlying Raritan Formation consists of continental-
   deltaic deposits which are 1ithologically similar to the underlying
   Potomac Group sediments.  At depth, however, these sediments contain
   glauconite and fossils which suggests a none-marine influence.   The
   Magothy Formation unconformably overlies the Raritan Formation  and can
   be described as a transgressive sequence.  It consists primarily of
   beach sands and other associated near-shore marine sediments (Parker et
   al. 1964).  These three, generally non-marine units, make up approximately
   half the total thickness of coastal plain deposits in New Jersey.

   Upper Cretaceous and Tertiary sediments overlying the Magothy Formation
   were deposited in beach to outer shelf environments caused by alternating
   transgressive and regressive seas (Owen and Sohl, 1969).  Glauconite in
   association with fine-grained sediments are generally recognized as being
   indicative of an outer shelf environment.  Coarsening-upward sequences,
   often overlying glauconite rich units, are indicative of transgressive
   deposits which formed during major incursions by the sea.  This mostly
   marine strata of Late Cretaceous and Early Tertiary age (pre-Miocene)
   ranges in thickness from about 400 feet near outcrop locations  to more
   than 1,000 feet near the New Jersey shore (Richards et al., 1962).

   The long period of marine incursion ended with the deposition of the
   Cohansey Sand, a non-marine deltaic unit (see Figure 9 for a generalized
   description of deltaic and shelf transgressive and regressive sequences).
   Continental deposition continued through Late Tertiary and Quaternary
   times with recorded thicknesses of up to 1,000 feet in southeastern New
   Jersey.  Many of the later units (Beacon Hill, Bridgeton, Pensauken, and
   Cape May Formation) are primarily comprised of fluvial  sands and gravels.
   A series of complex Quaternary deposits form a thin veneer over the older
   sediments and are generally less than 50 feet thick.   Holocene  age deposits
   of alluvium are present along the flood plain of the Delaware River and
   its tributaries.  Pleistocene deposits of possible glacial  origin (glacial
   outwash streams and channels) as well  as fluvial/marine deposits extend
   beneath the Delaware River (see Figure 10 for a description of  geologic
   and hydrogeologic units in the New Jersey Coastal  Plain).


c. Hydrogeologic Setting

   The sediment wedge of the New Jersey Coastal  Plain comprises one interra-
   lated aquifer system that includes several  aquifers and confining units.
   The boundaries of aquifers and confining beds may not necessarily corres-
   pond to geologic formations  because formations may be divided into several
   hydrologic units and may change in physical  character laterally (which
   affects their hydrologic characteristics).   There  are five major aquifers
   in the New Jersey Coastal  Plain:  Potomac-Raritan-Magothy aquifer system,

-------
                                                   -34-
(a)

I


*

OUt|«
MNC*
MfMSNOftt
GUI'
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SlM*OUCOUS
«,.«.«






f
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* 1 ' *
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         CTCU MO |
                                '"


II  !J!
                                           V  j
                                   lii!
ill     fl
I
(b)
                                                CIPlAltTION
C
0 B«cl<—
C TopMt d«n»
 Hewn l»u"' S*«
                                 — ttwittfl Formaiiefi
                             i— Hindu w* M« CoMOMT S«M
                                                         C NMnkmiu* — Mount Uu* md R«d Bw* S««* m< Vmc
                                                           MiMMywi •< HKtanod formBKxn
                                                         H lnn«f Ihttt — MtfttwtNiItt formilion Woodbunf C%.
                                                                Fotnulnm
                                                         I. Ouwmwll — MmlwiMlt MmluMoM. Itoniiiit t
                                                          md Horntfllovn S*«<4 Idd M*nn«y«A Fomwtion
                                                         J OMitMiklWixilInn — RI>I<«I •"< NifMtit
      Figure 9.   Both  (a) and  (b)  are diagranmatic representations of depositional
                   environments which existed  during the  emplacement of Cretaceous  and
                   younger sediments in the New Jersey Coastal Plain.  From Owens and
                   Sohl  (1969).

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                                             -35-
SYSTEM
Quaternary
Tertiary
Cretaceous
i

SERIES
Holocene
Plelstocen
Miocene
Eocene
Paleocene





Upper
Cretaceous





.over
Cretaceous
Pre- Cretaceoua
GEOLOGIC
ONIT
Alluvial
deposits
Beach tend
Cape May
Formation
Pensauken
Formation
Brldgeton
Formation
Beacon Rill
Gravel
Cohansey Sand
Klrkvood
Form* t Ion
Plney Point
Formation
Sbark Klver
Formation
Msnaaquan
Formation
Vincentovn
Formation
Horneratovn
Sand
Tlnton Sand
tad Bank Sand
Naveaink
Formation
Sand
Wenonah
Marahalltovn
Fonucinn
Engllahtovn
Formation
Boodburv Clav
Merchantvllla
Formation
Magothy
Formation
tar It an
Formation
Potomac
Group
Bedrock
LITHOLOCY
Sand, lilt, and black mud.
Sand, quartz, light-colored, medium- to
Sand, quarts, light-colored, heterogeneous,
clayey, pebbly.

Gravel, quarts, light colored, sandy.
Sand, quarts, light-colored, medium to
coarse-grained, pebbly; local clay beds.
Sand, quarts, gray and tan, Tery fine* to
medium-grained, micaceous, and dark-
colored diatomaceous clay.
Sand, quarts and glauconite, fine- to
coarse-grained .
Clay, lilty and sandy, glauconltlc, green,
gray and Brown, flned-grained quarts send.
Sand, quarts, gray and green, fine- to coarse-
grained, glauconltlc, and brovn clayey, very
fossillf erous. glauconite and quarts
~.1~.r-n4 r.
Sand, clayey, glauconltlc, dark green, fine-
to coarse-grelned .
Sand, quarts, and glauconite, brovn and gray,
fine- to coarse-grained, clayey, micaceous.
'Sand, clayey, silty, glauconltlc, green and

coarse-grained, slightly glauconltlc.
Sand, very fine- to fine-grained, gray and
Clay, silty, dark greenish gray,
elsuconltlc auartz sand.
Sand, quarts, tan and gray, fine- to medium-
grained; local cley beds
Clay, grey and black, micaceous silt.
black; locally very fine-grained quarts
and glauconltlc sand.
Sand, quarts, light-gray, fine- to coarse-
grained; local beds of dark-gray llgnltlc clay.
Sand, quarts, light-gray, fine- to coarse-
grained, pebbly, arkoslc. red, white and
variegated clay.
Alternating clay, silt, aand, and gravel.
Precambrlan and lover Paleozoic crystalline
rocks, metamorphlc achlat and gneiss; locally
Triaaalc basalt, sandstone and shale.
HYDROGSOLOC1C
UNIT

Undlfferen-



Kirkvood-
Cohansey
aquifer
system

confining bed
• _____...
i^o^Crande^ w_-_bz
confining bed
Atlantic City
BOO -foot san

Plney Poin
aquifer
•8
JB
ft
£ Vincentovn
*£ aquifer
o
u
V
Al
i__ - 1-
Jl Red Bank
1 land

WcnonAh-
Hount Laurel
aquifer
Wenonah
confining bed
Engl ishtown
aquifer
system
Merchantville-
foodbury
confining bed
upper
g t aquifer
•J "3 conf bd
* « * middle
jj*;. aquifer
5 SJ, * conf bd
** lover
aquifer
Bedrock
confining bed
HYDROLOCIC CHARACTERISTICS
Surficial material, often
hydraulically connected to
underlying aquifers. Locally
of yielding large quantities of
water.
A major aquifer system.
Cround-vater occurs generally
under water-table conditions.
In Cape May County the
Cohansey Sand is under
artesian conditions.
along coast and for a short
distance Inland. A thin water-
> bearing sand occurs vlthln the
middle of this unit.
A major aquifer along the coast.
Allowsy Clsy member or equivalent
Yields moderate quantities of
water locally.
Poorly permeable aedlments.
Yields small to moderate
quantities of vater in and
near its outcrop area.
Poorly permeable aediaents.
Yields small quantities of vater
in and near Its outcrop area.
Poorly permeable sediments.
A major aquifer.
A leaky confining bed.
A major aquifer. Two sand unit*
in Honmouth and Ocean Counties
A major confining be>d. Locally
the Merchanmlle Pm. may
contain a thin water-bearing
aand.
A major aquifer system. In the
northern Coastal Plain the upper
Old Bridge aquifer and the middle
aquifer is the equivalent of the
Farrlngton aquifer. In the Dele.
River Valley three aquifers are
recognized. In the deeper sub-
surface, units below the upper
aquifer are undifferentiated.
No wells obtain water from
these consolidated rocks,
except along Fall Line.
  tlo Grande water-bearing son*.

  ------ Minor aquifer not mapped in this
Figure 10.  Geologic  and hydrogeologic units of the New Jersey Coastal Plain.
             Fran Zapezca (1984).

-------
                              -36-
Englishtown aquifer, Wenonah-Mount Laurel  aquifer,  Lower  "800-foot"  Sand
aquifer of the Kirkwood Formation  and  the  Kirkwood-Cohansey aquifer
(Vowinkel and Foster, 1981).

In New Jersey, sediments of the Cretaceous Potamac  Group, Raritan, and
Magothy Formations are usually described as one  aquifer unit or  as an
aquifer system (Zapecza, 1984) because the individual  formations are
1ithologically indistinguishable from  one  another over large areas of the
southern Coastal  Plain (see Figure 11  for  a description of extent, thick-
ness, and subsurface configuration).   In the region between Trenton  and
Delaware Bay, the aquifer system can  be divided  into five units:  three
aquifers, designated lower, middle, and upper,  and  two confining beds.
In the study area, which lies in Gloucester County, however, these sub-
divisions are not apparent.

The important aquifer systems in Gloucester County  are the Potomac Group
and Raritan-Magothy Formations (Cretaceous), the Wenonah  Formation and the
Mount Laurel Sand (Cretaceous), Vincentown Formation (Tertiary), Cohansey
Sand (Tertiary)  and the Cape  May Formation (Quaternary).   Of the water
bearing formations, the Potomac Group  and  the Raritan  and Magothy Forma-
tions contain the most productive  aquifers in Gloucester  County.  The
system yielded over 25 million gallons per day  in 1978 in Gloucester County
(Volwinkel  and Foster, 1981).  Regional aquifer  tests  indicate  transmis-
sivities upwards  of 30,000 gpd/ft  and  storage coeffecients ranging from
.000033 to .004  (Meisler in Gill et_ al., 1976).  This  aquifer system,
which crops out  in a narrow 3 to 5 mTTe wide band adjacent to the Delaware
River in southwestern Jersey (Figure  11),  is the most  heavily pumped system
in New Jersey.

The geohydrology is more complex within the outcrop area  (western Gloucester
County) than downdip of it (Fusillo et_ aj_., 1984).   In the outcrop area,
confining units  are thinner;  thus, hydraulic connections  between aquifers
is more likely.   Numerous lenses of sand and clay occur locally.  In much
of the outcrop area, the Cretaceous aquifer system  is  overlain  by a  thin
veneer of post-Cretaceous deposits, most of which are  hydraulically
connected to the  underlying aquifer.   The  aquifers  in  Gloucester County
are recharged by precipitation entering the uppermost  aquifer through
outcrops and overlying permeable units. Ground  water  is  generally dis-
charged to streams and wells, leakage  to other  aquifers,  and evapotran-
spiration.

Precipitation, the source of all freshwater inflow  to  the Coastal  Plain,
averages 44 inches per year in Gloucester  County.   A large percentage of
streamflow runoff is derived  from  ground water  discharge  into stream
channels.  The upper geologic units are able to  transmit  large  quantities
of water downward to the saturated zone.   In the outcrop  areas  of the
Potomac-Raritan-Magothy aquifer system where the system is unconfined,
the recharge to  ground water  is 12 inches  per year  (Farlekas, 1979).
Variations in recharge are a  result of the slope of the land surface,
permeability of the sediments, and the degree of urbanization.

-------
                                                     -37-
TfOO'
                                                 TS'OO'
                                                                                                  T4»00'
                                                      *7^?//*&&
                                                      X«*V  /^  /  /  /    s   /. '"
                                               "/,///  *-<*°y*-l
                                               /*. /  /  f     /  /I •**
                                               xV   / ^.-^r*
                                               ^x^^.^-x  /  •
                                                                 Vxx5"/   !
                                                                  X-1^ ^-isw    j
                                                                                    KCPI^NATION

                                                                                        O -080

                                                                                      Wdl

                                                                                       Weil  nb»vnt.
                                                                          fwrt. Datum tt ascui w* ivvvj.  VnJuuH roundvd
                                                                        to iwmmK ^ f*«t.
                                                                       Genemittrd atnjcturv eontnur. on top nf Mncnttiy fnr-
                                                                        muian vxecpt for HI dfflnv«t urcms, whcr« th* Mnirathy
                                                                        ix believM to be «b«%nt *nd tiw contmir* urc nn t^>it
                                                                        of :h* Kcriuin Fam»tinn. Altitud* in fcvt; datum in
                                                                        mean m level, contour  intervfti 100  fi-rt.
                                                                                                              30'
                                                                                                              WOO
                                                                                                   2000
                                                                                   GenenUUed iioiweh
                                                                      Itopnelw obCaiiMd by intiraoUtion from contour* nn top
                                                                        of prv-Cr*t«eeou* roekc and  eontour*  an tnp of
                                                                        Mavothy or Bjuritan fornumon. interval, iOO fwt.
                                                                                       Outcrop

                                                                      Includ« outcrop of Rjlritan ind Mmjrothy FormiKinnn in
                                                                        Ne* Jrntr and Delaware, and «tu Patuxent and
                                                                        Pt£ap*eo formation* in Delaware. In pfacv*. concealed
                                                                        by Quaternary depoutt.
                                                                                                             -SO'
  Figure  11,   Generalized structure contour  (altitude in  feet; datum is  mean sea level)
                 on top of  the  Magothy formation  along with  isopachs of the combined
                 Potomac Group, Raritan and Magothy  formations.   From Parker et al.  (1964)

-------
                              -38-
Ground water withdraw!s by man have modi fed the natural  hydro!ogic cycle
in the Coastal  Plain by increasing the rate of outflow from the system to
the ocean.  Induced recharge and salt encroachment are a result of the
changes in flow direction.   Ground water  withdrawls from the Potomac-
Raritan-Magothy aquifer system have almost doubled from 45 billion per
year in 1956 to close to 90 billion gallons per year in 1978 (Figure 12).
This has resulted in ground water level  declines of 1.5 to 2.5 ft/yr from
1966 to 1976 (Luzier 1980).  Chloride concentrations, a function of
saltwater encroachment from extensive ground water withdrawls as well as
contamination from vertical leakage, has  leveled off in recent years.
Chloride concentrations in western Gloucester County range from 0.4 to
177 mg/1 in the Potomac-Raritan-Magothy aquifer system (Schaefer, 1983).

-------
                                        -39-
    160
c
<

>!   120
0
z
o

I!   90
z
o
2   6°

0
.1

<
K
Q
X
     30
                                                                \
                                                                                  410
                                                                                 328
                                                                                 246
                                                                                 164
82
                                                                                        a
                                                                                        tu
                                                                                        0.

                                                                                        CO
                                                                                        z
                                                                                        o
                                                                                        z
                                                                                        o
                                                                                        z

                                                                                        o
                                                                                        oc
                                                                                        o
                                                                              1980
                                       EXPLANATION
                        Total
                              Aquifer

                  O  = Potonac-Raritan-Magothy System

                  A  = Englishtown

                  EJ3  = Wenonah-Mount Laurel

                  Q  = Lower "800-foot" Sand of the Kirkwood Formation

                  f  = Kirkwood-Cohansey
    Figure 12.  Major ground water withdrawls from the New Jersey Coastal Plain,

                1958-1978.  Fran Volwinkel and Foster  (1981).

-------
                                 -40-
3. Site Hydrogeology

   Much of the information in this and the next chapter has  been  derived
   from information provided by RES'  consultants,  Geraghty and  Miller,
   Inc., to EPA and NJDEP.  These submittals include yearly ground  water
   monitoring reports, pump test reports,  drilling project reports, etc.
   Another important document used for this report is the  Environmental
   Assessment of the Rollins Environmental  Services (RES)  NJ Hazardous
   Waste Management Facility, Logan Township, New Jersey prepared  by
   NJDEP in October of 1983.   These submittals along  with miscellaneous
   inspection and sampling reports form the basis of  the site  specific
   portions of this report.   This section and the next  section,  "Ground
   Water Quality", are summaries of these submittals  and are not critiques
   of their quality.  A critical analysis of the available information
   will be provided in the "Dicussion"  section (Section 5).


a. General Overview - Geology

   RES is located along the  eastern banks of Raccoon  Creek in  northwestern
   Gloucester County, New Jersey (see Figure 2).  Raccoon Creek  dis-
   charges into the Delaware  River approximately 2.2  miles northwest
   of the facility.  The northeastern portion of the  facility  is 10 to
   20 feet above sea level.   The central  portion is characterized  by
   the southward sloping terrace which  is underlain by  sandy clay  and
   sand.  To north and south  lie marshlands which consist primarily of
   organic silts, muck, and  peat.

   The stratigraphy at the RES site is  complex (Figure  13).   Basement  rock
   is the Wissahickon Formation.  Above the Wissahickon Formation  lies
   an unconsolidated group of sediments ranging in age  from  Early
   Cretaceous to Recent.  The expected  depth to the Wissahickon  Forma-
   tion is approximately 250  feet below sea level  at  the site  (NJ
   Geol.  Survey Rep. 4); the contact between it and  the overlying
   unconsolidated sediments  is believed to be a weathered mica schist
   (saprolite).  A regressional  period  during the Jurassic probably
   caused erosion of the Wissahickon surface and its  redeposition  as a
   veneer of disaggregated material  up  to 30 feet thick.  This veneer
   of sediments is encountered in wells drilled through Coastal  Plain
   material into the Wissahickon Formation.  Highland areas  to the north
   and east were the provenance for sediments deposited during the
   Cretaceous and Quaternary  Periods.  The Raritan Formation in  the
   vicinity of RES is characterized by  light colored  sands and silty
   clay thought to represent  river channel  and floodplain depositional
   environments of the Cretaceous Period.  As will be is discussed
   later, there is no strong  evidence to  suggest the  existance of  any
   continuous clay layers beneath the site area.  While clay does
   exist, thicknesses and elevations are  not consistent among  well
   logs.  It is not certain whether the Cape May Formation,  often
   indistinguishable from the underlying  Raritan Formation,  is present
   at the RES site.  Cape May sands and clays are washed or  wind blow
   sediment of non-glacial origin which are usually found on low
   terraces and plains.

-------
                                                     -41-
 (a)
(b)
                                                                                          fCAtC - Ii3«00
                                                                                         (I Inch-300 ft.)
                      GEOLOGIC CROSS-SECTION-ROLL INS ENVIRONMENTAL SERVICES
             R  O
                                              tmt
 n

 ?o

 to

 O

 •O



-I-JO
                                                             Dlfi of MdlBtst mitt vtthln thlf tattt «r«« rcfttct
                                                             leeit vitUklltty of itdlxnc coBpoaltlo* ratkir than
                                                             the *«*rall louthciitwird dlf chiracttriftle of tht
                                                             Htv Jtrtiy Ceiitit riain for«*tlont.
  Figure 13.   Site specific  geology  and  gecmorphology at RES.   Fran NJDEP  (1983)

-------
                                -42-
   Recent  deposits  are  related  to the  flooding of  Raccoon Creek Valley
   during  the  post-glacial  rise in  sea  level.  These sediments can  be sub-
   divided into  a  basal  sand, an  intermediate clayey sand, and overlying
   silts and muck.   These  differences  are  a  result of depositional  environ-
   ment, the coarser material being deposited in stream channels or along
   estuary shorelines and  the finer silts  being deposited offshore  in quieter
   water.   Organic  silts,  mucks,  and  peats were deposited in adjacent marsh
   areas,   all  of  these recent  sediments slope towards Raccoon Creek.


b.  General Overview - Hydrogeology

   The Cretaceous  through  Quaternary  age deposits  have been divided into
   three waterbearing zones at  the  RES site:  the  water table  zone, the
   shallow artesian zone,  and the deep artesian zone.  Because of the deep
   artesian zone's  naturally poor water quality it will not be discussed
   further.  The water  table zone is  an unconfined aquifer which is recharged
   by precipitation through the overlying  Recent sediments.  Topographic
   low areas  such  as streams and  marshes are ground water discharge points.
   The top of  the  water table average 1 to 3 feet  above sea level ;  the  zone
   is generally 25 to 30 feet thick and, locally,  45 to 50 feet thick.
   Differences in  thickness are a function of the  irregular occurrence  of
   clay layers and lenses  and differences  in topography.  The  zone  is
   generally thicker in the North Marsh Area.

   The shallow arstesian zone  is  a  deeper  aquifer  at the  RES site.   It  is
   semi-confined since  a continuous clay confining unit does not exist
   immediately above the unit throughout the site.   The shallow artesian
   system is recharged  by vertical  leakage from the water table zone.
   Minor contamination  in  the  shallow artesian  zone  is  further evidence
   that the water  table zone directly recharges this zone.  The downward
   component of flow may be reversed  locally with  heavy  pumpage  in  the
   water table zone.  The  shallow artesian zone discharges to  Raccoon
   Creek.  Because of the  variable  vertical  and  horizontal extent  of  clay
   layers and lenses, the  top of the  shallow artesian  zone  is  difficult
   to determine.  According to  RES' consultants,  the top  of the  zone  lies
   68 to  73 feet below  sea level.  Its thickness,  as determined  from  one  log
   of an  abandoned production well, is approximately 53  feet.

   RES  performed short-term well  tests in  1982  on  both  abatement  and  artesian
   zone wells.  The  range of calculated transmissivities  in  the  water table
   zone is 3,000 gpd/ft to 27,000 gpd/ft with corresponding  hydraulic con-
   ductivities of 150  gpd/ft2 to 625  gpd/ft2.  The higher conductivities
   and  transmissivities are for ground water in  the  North Marsh  Area  where
   the  sandy units are generally coarser and thicker.   In a  long-term well
   test on shallow artesian well DP4  it was determined  that  there  is  some
   interconnection between the  water  table zone  and  the  shallow  artesian
   zone.   The calculated  hydraulic  conductivity in the  shallow artesian zone

-------
                                   -43-


   is 1,700 gpd/ft2 while, based on an aquifer thickness of 53 feet, the
   transmissivity of the zone is 90,000 gpd/ft.  Because of the complex
   geology, it is difficult to correlate these local  saturated zones to
   regional hydrogeologic formations.  The shallow artesian zone may correlate
   to the upper reaches of the Potomac-Raritan-Magothy system while the
   water table zone is probably equivalent to the later Quaternary desposits.
   It should be emphasized that geologic and hydrogeologic  information
   regarding the shallow artesian zone comes from only 5 deep wells.  Its
   thickness, which is used to determine the zone's transmissivity, derived
   from the drill log of one out of service production well.

   The following section contains a much more detailed discussion of site
   hydrogeology.  It is essentially a synopsis of 15  years  of ground water
   investigations by RES'  consultants, NJDEP, and EPA.  The focus will  be on
   specific work done at the site and how it has  affected our understanding
   of the area.  It will  also describe the scientific basis from which many
   of these findings were derived.  A more critical  approach to the same topic
   will  the main concern of the "Discussion" section  (Section 5).


c. Hydrogeology and RES'  Ground Water Monitoring  Program

   In February, 1970, RES (then known as Rollins-Purle, Inc.) drilled a deep
   production well  and several shallow observation wells.  The production
   well  was 290 feet deep and drill logs describe bedrock at 270 feet.   To
   this day, the production well  (now sealed)  is  the  only well  to have
   penetrated the whole unconsol idated sedimentary sequence and the underlying
   Wissahickon Formation.   In February, 1972,  RES contracted Geraghty and
   Miller, Inc. (G & M) to study the ground water conditions at the facility.
   G & M submitted a report in April , 1972, describing ground water conditions
   and hydrogeology.  As  part of this project wells were installed at 18
   locations (designated A through Q), and at each location, one or more such
   wells were screened at  depths ranging from 5 to 30 feet.   Using the
   results of this testing program and using well  logs from previous production
   and observation wells,  G & M concluded that "the western portion of the
   facility consists of predominantly clay grading to sand  to the east  and
   that shallow sands are  underlain by a more or  less continuous clay
   zone."  Most sediments  were generally of low permeability.

   Water level  measurements in the shallow wells  show lateral movement  of
   ground water from the  vicinity of Well  C, northwest, toward Raccoon  Creek
   and the North Marsh Area (Figure 14a).   These  levels are significant in
   that there are true static water levels since  no abatement wells were
   yet in place and the production well  was not yet  in operation to affect
   measurements.  There is already evidence of some mounding near Well  C
   which may have been due to activities at the "organic filter pad", now
   part of the  Basin Closure Area.  Using the  ground  water  elevation data
   from various well points, G & M calculated  a hydraulic gradient of
   0.0025.

-------
                                                          -44-
(a)
(b)
                                                                             • I   Mkll location

                                                                         — . —   Active rtdllty Bcundny

                                                                           7 —  Hater Table Oxitours - March 1972
                                                                                          in feet
                                    Rollins Environmental Services Facility Map - 1972
                                                                             Hell Location

                                                                             Active Facility Boundary
                                                                             Water Table Contours - Ncv 1975
                                                                                        in feet
                                     Rollins Environmental S^rvirfs Fncility Mnp - 19HO
    Figure 14.   Water  table  contour maps  (altitude  in  feet;  datum is mean  sea level)
                                              	3  /i» \  T>T_-_-. j _.^T .. .-L-

-------
                              -45-


After assuming a low permeability of 100 gpd/ft^ (hydraulic conductivity)
and a 10 foot upper aquifer thickness (now called the "water table zone"),
G & M calculated the discharge to Raccoon Creek to be approximately 5,000
gpd.  Because wells were screened at different elevations (at the same
location), vertical gradients could be estimated.  G & M concluded that
"there is some order of downward component of flow."  As a result of the
initial evaluation, 6 abatement wells (Wells 20 through 25) were installed
to form a barrier against the movement of contaminated ground water
towards Raccoon Creek.  The implementation program called for each abate-
ment well to be pumped for 12 hours per day at a rate of 20 gpm to yield
14,400 gpd.  According to G & M, this rate would be well over the estimated
ground water discharge (5,000 gpd) into Raccoon Creek.

In October, 1975, DPI and DP2 were installed to monitor the shallow arte-
sian zone.  A short-term well test was conducted on each abatement well
to determine whether clogging had occurred within the well screens.  As a
result, redevelopment was initiated; however, well  efficiency did not
improve sufficiently.  Static water level measurements were taken which
more clearly delineated a ground water mound centered beneath basins
B-202A and B-201 (Figure 14b).  During this study G & M recommended that
4 more wells be added to the abatement system.  They were installed in
April-May, 1976, and designated 20A, 20B, 26 and 27; thus, the number of
wells in the abatement system increased to 9.  Concurrently, the pumping
rate was increased to 22,000 gpd.  Ground water pumped by the abatement
wells was discharged into a common collection system and then piped into
the equalization basin B-206 for biological treatment.  All 9 wells are 4"
diameter with 10 feet of screen installed in the water table zone.  They
were drilled 20 to 25 feet from ground surface corresponding to 15 to 20
feet below sea level.  These newer wells were constructed of PVC; the
first 5 wells, however, were constructed of fiberglass.  Composition of
the original  well  points is uncertain as many of the logs no longer exist
and many of the wells have been pulled out of the ground.

Also part of this project was the installation of 6 monitoring wells
(R-W).  A well  test was conducted, utilizing the Main Production Well  for
pumping and using DPI, DP2, and 17 as observation wells.  The purpose of
the test was to determine the transmissivity of the shallow artesian
zone.  The pump test lasted 100 minutes during which time the Main
Production Well  was pumped at a constant rate of 190 gpm.  Drawdown at
DP2, 14 feet from the Main Production Well, was 5 feet; drawdown at DPI,
950 feet away, was 0.06 feet; there was no measured drawdown in Well  17
which is 500 feet away and screened in the water table zone.  From these
results G & M calculated the transmissivity of the  shallow artesian zone
to be 16,000 gpd/ft.  Continuous water level  recorders were installed  in
DPI, DP2, and Well  17 to determine the hydraulic gradient between the
water table and shallow artesian zone.  This was done over the period
January 29 to Febuary 5, 1976, prior to the well  test.   Tidal  effects
were evident (1 to 2 feet)  in Wells DPI and DP2; these effects were
negligible in Well  17.  Due to maintenance problems, the pumping/abatement

-------
                              -46-
system was not in operation during early 1978; therefore,  the  March,  1978,
water table map represents approximate natural flow conditions.   Mounding
is apparent near basins B-210, B-211, and B-212.

In order to determine ground water flow direction  in the  shallow artesian
zone, RES installed a third deep well (DPS)  in 1979.  From the three  deep
wells it was determined that ground water flow in  this  zone is towards
the west, to Raccoon Creek.  The screened interval  of DPS  is shallower
(531- 63' bsl) than the previously installed wells, DPI and DP2  (75'- 85'
and 72'- 82' bsl respectively).  Because of contamination  in the northern
section of the facility, two more abatement wells  (28 and  29)  were also
installed, increasing the total number of abatement wells  to 11.

In the summer of 1981, as part of an investigation  into possible contami-
nation in the North Marsh Area, RES installed 11 well  clusters (3 wells -
shallow, intermediate, and deep, in 11 locations).   The wells  are 1.25  to
1.50 inches in diameter and constructed of PVC. Well  screens  are 5 to  10
feet in length and are all located in sandy units  at depths between 2 and
67 feet below sea level.  The following summer (1982)  water level  measure-
ments from the marsh wells (called the MA series)  were  used along with
measurements from older wells in the Basin Closure  Area to construct  a
hydrogeologic cross-section.  RES' consultants determined  that there  is a
downward component of ground water flow beneath the Basin  Closure Area
and an upward component in the North Marsh Area (Figure 15).

RES' ground water monitoring system changed significantly  in late 1981,
when, as part of a Consent Agreement signed  with NJDEP, RES was  required
to more adequately define site hydrogeology and to  upgrade the existing
abatement system.  Pursuant to the Order, RES conducted a  shallow artesian
well test and a series of short term well tests on  all  abatement wells.
The purpose of the shallow artesian well test was  to determine the trans-
missivity and storage coefficient of the shallow artesian  zone,  the
leakage rate of any overlying confining unit, and  the probable effect of
pumping the shallow artesian zone on the water table aquifer.   A new  well,
DP4, was installed as the pumping well.  Observation wells included AVI,
AV2, W7, Wll, W12, W18, U, DD, BB, II, EE, R, 11,  DPI,  DP2, DPS, and  DP5,
(another new well).  DP4 was pumped at constant rate (300  gpm) for 29.5
hours.  Stevens automatic water level recorders were used  at all the  deep
wells.  All data was presented on semi-log paper,  and results  from DPS
were used to calculate aquifer parameters.  DPS was chosen because it is
minimally influenced by tides.  Unfortunately, DPS is not  in the RES  waste
management area.  Quantitative results were determined  by  curve  matching
DPS data to leaky artesian type curves of Walton,  1970.  The transmissivity
of the shallow artesian zone was determined  to be  90,000  gpd/ft  with  a
storage coefficient of 4.6x10"^, and leakage from  the confining  unit  was
determined to be 9.7x10-3 gpd.  The horizontal permeability of the shallow
artesian zone was 1,700 gpd/ft?, and the vertical  permeability of the
confining unit, 0.068 gpd/ft2; permeability data was determined  using an

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                                                                -47-
a
e   .»
                                                                                                                                                SS9
                                                                                                                                                     - 10


                                                                                                                                                     -to

                                                                                                                                                     -10


                                                                                                                                                     -40


                                                                                                                                                     -io

                                                                                                                                                     -to
                           EXPL  ANATION
        b;;^;:l  ORGANICS

        [_	J  S»NO trim TO MEDIUM)
WELL CLUSTER
^ll•n >
M«M .
•tig .
                                        Nolt-:   Fhis section  is nut corircted for  dnlsolrophy.  As the vrrtital
                                               peimeablllty  of the unconsolIdiltd depot its  Is significantly less
                                               lhan the horizontal permeability,  th« vertical flow component
                                               shown in the  section is exaggerated.
HOLLO*
INTCMMOIATI
— ri
..' V| SAND (MEDIUM
•?) 0*»VEL

: — -|
-V'[ CL»t
• • 1
•1 IILT



TO COARSE 1
ft
SCREEN /
INTERVALS 4-4
	 	 DIRECTION Of OROUNOWATER \ ,
FLOW PARALLEL TO PLANE OF \ (
SECTION \J
H
» 	 DIRECTION Of OMOUNOwATIR I
FLOW OBLIQUE TO (OUT OFI

IO9-

1 25-


1 27—

PLANE OF SECTION
is-—"""
                                                                          - SEPTEMBER 7. IM2 WATER-LEVEL
                                                                           ELEVATIONS, IN FEET RELATIVE TO
                                                                           MEAN SEA LEVEL
                                                                           LINE OF EOUAL WATER-TABLE ELEVATION
                                                                           IN FEET RELATIVE TO MEAN SEA LEVEL
                                                                           (DASHED WHERE  INFERRED)
                                                            Hydrogeologic Cross-section from
                                                            Geraghty and  Miller,  Dec.,  1982
                                                                 Figure  15

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                              -48-
quifer thickness of 53 feet and a confining unit thickness  of 7 feet.
An analysis of this data will  be included in the "Discussion" section
(Section 5).  The rest of the test results were used for qualitative
purposes only.  Pumping of shallow artesian well DP4 caused a drawdown in
water table wells AVI, EE, W12, II and 11.  Based upon these results,  RES
concluded that there is a hydraulic connection between the  two aquifer
zones.  The amount of drawdown was variable, probably due to the hetero-
geneity of subsurface geology.  Some water table wells actually showed a
rise in water levels during pumping.  This could not be accounted for.
Most of the shallow wells used for this well test were sealed during the
closure of the basins in the northern portion of the facility.  Of the 13
water table zone wells, only 6 (DD, GG, R, U, II, and W18)  remain.

Also as part of the Order with NJDEP, RES was required to re-evaluate  the
contamination abatement program.  In August, 1982, G & M submitted the
project report, Abatement Well Testing Program and Design erf Pumping
Schedule.  The specific purpose of the program was to "determine pumping
rates required to alter the ground water flow system sufficiently to
create a pumping barrier to the flow of contaminated ground water off the
property and to establish an operational pumping schedule for RES' subse-
quent use." Abatement wells 20 through 25 were tested as were new wells
30 through 33.  The general approach was to pump one well for 6 hours,
after which a second well would be turned on.  The first well would
continue to be pumped for 6 more hours (12 hours total).  It would then
shut down and a third well started.  This alternating procedure would
continue through the entire test.  Positive displacement pumps were used
for testing the old abatement wells (20 series), while submersible pumps
were used in the new 30 series wells.

The purpose of using this alternating sequence for the pump tests was  to
determine the mutual drawdown produced by each well pair midway between
them and the discharge rates required to obtain these drawdowns.  Drawdown
values were plotted for individual wells against time, and drawdowns for
several wells were plotted against distance (the values for drawdown vs.
distance were taken after 12 hours of pumping).  Distance-drawdown graphs
were used to determine the storage coefficient and transmissivity of the
zone being pumped.  By checking the amount of pumpage needed in the field
to produce the required drawdown against those results from an equation
from Todd (1959) describing drawdown adequacy between two wells, maximum
required discharge rates were determined.  Field data was used in Todd's
formula; hydraulic conductivity values were derived from transmissivities.
Through this process, the minimum drawdowns required to keep contaminants
from migrating off-site were determined.  These results, along with field
derived hydraulic gradients, formed the basis for a revised pumping
schedule.  Based on the results, 2 more abatement wells were drilled (34
and 35), and total daily pumpage increased to approximately 140,000 gpd.
Transmissivities ranged from 13,000 gpd/ft to 27,000 gpd/ft in the North
Marsh Area (where the new 30 series wells are located) to 3,000gpd/ft to
8,200 gpd/ft in the Central Plant Area  (where the older 20 series wells

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                              -49-
are located).  RES determined that water table zone thickness in the North
Marsh Area is 30 to 40 feet and decreases in the Central  Plant Area to 15
to 25 feet.  A more detailed discussion of test methods,  interpretations,
and underlying assumptions, will  be presented in Section  5.

The pumping schedule originally designed and implemented  through the 1982
Abatement Well Report is the one currently being used.   Approximately 4
million gallons of contaminated ground water per month  are pumped into the
RES water treatment facility and, from there, discharged  into Raccoon Creek
under a NJPDES Permit.

In June, 1985, RES installed 8 wells around the RCRA regulated units,
basins B-206 and B-207, to satisfy Interim Status ground  water monitoring
requirements.  Two wells (LI and L2) were installed in  June, 1986, to
monitor the south side of the L series lagoons.  These  wells were all in-
stalled with PVC, are 4 inches in diameter, and are screened in the water
table zone (between 0' and 20' below sea level).  Drill  logs indicate
that the area is underlain by coarse to fine sand with  some  silt and clay
lenses.

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                                   -50-
4. Ground Hater Quality


     a. General Overview

     Soon after RES began operations in 1969, ground water contamination
     beneath the facility became evident.   By the end of 1972,  RES had
     installed 25 wells in the water table zone.   Six of these  wells
     were part of a pumping well system whose purpose was to intercept,
     pump, and decontaminate the ground water.  Since October 1971, when
     the State first ordered RES to commence ground water decontamination
     activities, efforts have been made to monitor and control  the
     extent of ground water contamination  at the  site.  Early in the
     history of site investigations, RES determined that total  dissolved
     solids (IDS) was a good indicator of  ground  water quality.   Historically,
     RES has used IDS values below 500 mg/1  to define background levels
     and values above 500 mg/1 to represent contaminated ground  water.
     Through the years, RES has used IDS along with several  parameters
     (e.g. TOX, TOC) and specific inorganic constituents (e.g.  Fe, Cd,
     Cr) to define the boundaries of ground water contamination.

     In early 1982, a substantial amount of organic contamination was found
     as a result of a comprehensive waste  characterization study.  This
     was the first study in which specific organic contaminants  were
     analyzed rather than broad parameters such as total organic carbon
     (TOC) and total halogenated carbon (TOX).  These parameters continued
     to be used in ground water investigations, however, since  RES con-
     tended that wells contaminated with specific organic constituents
     were all within the plume defined by  the organic parameters and the
     500 mg/1 TDS boundary.  Trace organic contamination was found
     during an investigation in 1984 and confirmed again in 1985 and
     1986 in Well DP5 which penatrates the shallow artesian zone.  Deep
     wells within the water table zone also show  organic as well as inorganic
     contamination.

     Background ground water quality data  has been collected mostly from
     public water supply wells in the area as well as from the  now sealed
     Main Production Well at the facility (Figure 6).  Data from these
     these wells supports the conclusion that ground water in the water
     table zone and shallow artesian zone  has been affected by  activity
     at the RES site.  The range of TDS in uncontaminated ground water
     from the Upper Potomac-RaritanMagothy aquifer range from 30-200ppm
     (Parker et al., 1964) while chloride  concentrations in the  lower
     reaches o7 TKe aquifer system (200-270 feet  below sea level at the
     RES site) range from 250 mg/1 to 27,000 mg/1 (Walker, 1983).  The
     lower reaches of the system are known to be  slightly brackish in
     nature and the zone is not used for drinking water purposes.

  b. Ground Water Quality and The RES Ground Water Monitoring Program

     Background ground water quality in the area  surrounding the RES site is
     good.  Several drinking water supply  and production wells  in the region

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         —Minimum, median, and maximum values of physical characteristics and
                            chemical constituents.
        [Concentrations in milligrams per liter of dissolved constituent
                              except as noted.]

                                   Number
                                    of
           Parameter                samples   Minimum    Median      Maximum

Temperature (*C)                      860     8.9        11-5         24.0
Specific Conductance, field (umhos)    668    39         350         5,820
Specific Conductance, lab (umhos)   1,600    32         307         6,000
pH, field (units)                     452     3-9         6.7          8-9
pH, lab (units)                       744     2.8         6.9          9-4
Alkalinity, field  (as CaCO,)          421     0          75         1,580
Alkalinity, lab (as CaCO,)            382     0          54          315
Dissolved oxygen                      137     0           0.3         10.4
Hardness (as CaCO,)                 1,004     0          55          570
Hardness, noncarbonate (as CaCO,)     990     0           2          569
Sodium                               951     1.4        12         1,000
Potassium                            940      .1         4.1        100
Calcium                              971      .1        15          160
Magnesium                            967      .1         4.4        100
Sulfate                            1,034     0          17         1,700
Chloride                           2,359      .6        20         1,900
Fluoride                             685     0           0.1          6.2
Silica                               965     0           9.1         53
Nitrate nitrogen (as N)               365     0           0.18        18
Nitrate nitrogen (as NO,)             575     0           0.6        198
Amnonia nitrogen (as N)               14?     <.01         0.25        25
Ammonia nitrogen (as NH.)             146      .01         0.32        32
ftmonia and organic nitrogen (as N)    147     <.1         0.5         28
Nitrate and nitrite nitrogen (as N)    39"     0           0.1         18
Orthophosphate phosphorus (as P)      516     0           0.06         3-2
Iron, total (ug/L)                    523     0         1000       171,000
Iron, dissolved (ul/L)                479     0         1000       460,000
Manganese, total (ug/L)               »82     0          80        24,000
Manganese, dissolved (ug/L)           477     0          77        15,000
Alumlnun (ug/L)                       193     0         *IOO        18,000
Arsenic (ug/L)                        160    <1  '        <1           11
Barium (ug/L)                         260     0          70          410
Berylliun (ug/L)                      259     <-3        <1            8
Cadmium (ug/L)                        276     0           2          120
Cobalt (ug/L)                         275     0          <3          280
Copper (wg/L)                         278     0         <10          930
Chromium (ug/L)                       171     0         <10          880
Chroalum, hexavalent (ug/L)           148    <1          <1          130
Lead (ug/L)                          263     0         <10           47
Lithium (ug/L)                        270     0           7          200
Molybdenum (ug/L)                     257      .5       <10           60
Strontium (ug/L)                      270    <1         325         4,400
VanadlUB (ug/L)                       257     2          <6           20
Zinc (ug/L)                          282     0          12         1,700
Dissolved organic carbon              409     0           1.4        108
Dissolved solids (residue on
  evaporation at 180*C)               973    25         136         3,910
Dissolved solids (sum of              945    26         132         3,220
  constituents)
                                                                                                                                                  EXPLANATION
                                                                                                                                 l
                                                                                                                                                                                 I
                                                                                                                                                                                Ul
Figure  16.   Water  quality in  southwestern  New  Jersey.    From  Hardt  (1963)   and  Fusillo et  al.   (1984) .

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                              -52-
are screened in the same general  hydrogeologic horizon  as  the  shallow
artesian wells on the RES site.   Thus, data  from  the off-site  wells  are  a
good example of background water  quality of  the shallow artesian  zone at
RES.  There is no comparison data for wells  at the  RES  site  screened in
the water table zone.  However,  it is believed that background water
quality is quite similar.  Specific conductance values  at  the  nearby (1-2
miles) Penns Grove Water Company  (supplying  the town of Bridgeport),
Pureland, Monsanto and other production wells, average  100-500 micromhos.
Dissolved solid totals average around 100 ppm at  Penns  Grove and  other
nearby wells.  Nitrate levels (as N) can reach 11 ppm.   These  relatively
high levels may be due to farming in the region.   Iron  and manganese
levels are also high; but this appears to be a function of natural  condi-
tions in the Raritan-Magothy aquifer system.  Dissolved iron concentrations
of greater than Ippm (10 times New Jersey drinking  water standards)  and
manganese levels of 0.1 ppm are  not uncommon.  Volatile organic concen-
trations for all wells in the vicinity are below  1  ppb.

In RES'  first investigation of ground water  contamination  during  1972,
their consultant (G & M) utilized earth resistivity and chemical  analysis
of ground water to delineate the  contaminant plume.  The resistivity
method depends upon conductance of an electical  current through the
subsurface after a specific voltage has been applied.  Ground  water  with
a high level of ionized constituents has a lower  resistivity (greater
conductivity) than does water of  low mineral content.  RES'  consultants
determined, that although other  factors such as geology and  saturation
may be important factors that affect resistivity, most  of  the  resistivity
contrasts can be attributed to the chemical  quality of  the ground water.
Because these measurements are not dependent upon specific constituents,
the results can be qualitatively  related to  TDS,  a  parameter which  RES
has used to track contamination  for the past 15 years.

In the resistivity evaluation, a  Wenner electrode configuration was
used.  This configuration requires four electrodes  to be placed in  the
ground equadistant from each other and in a  straight line.  An electrical
current is applied to the ground  through the outer  two  electrodes and the
potential drop across the inner  electrodes is measured.  By  increasing
the electrode spacing, the depth  being examined is  increased by an  equal
amount.   19 vertical profiles were made at the site, with  each vertical
profile consisting of 17 electrode spacings  which increased  from  3  to 51
feet in increments of 3 feet.  RES also made 79 fixed depth  measurements
using an electrode spacing of 51  feet which  RES decided was  of sufficient
depth to include possible contamination.  RES'  consultants determined
that the results of the study were "conclusive enough to permit the
delineation of a zone of highly mineralized  ground  water"  at the  site.
Areas of highly mineralized ground water (high TDS) were inferred from
resistivity levels below 400 to  600 ohm-feet.  Groundwater beneath  the
center of the site showed resistivity levels as low as  100 ohm-feet.
Based on RES' initial interpretation of the  data, ground water quality
was not affected beyond the immediate area of the facility and contami-
nation did not extend deeper than a maximum  of 28 feet  below land surface.

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                                -53-
RES1 consultants used chemical  analyses (the IDS parameter in particular)
as a verifier of the resistivity data.   100 samples were collected from
75 well points on the site.  Chemical  parameters analyzed included:  IDS,
volatile organics, chemical oxygen demand (COD), pH, copper, chromium,
magnesium, zinc, and nickel.  Early in  the study RES determined that no
specific constituent could be used as  a reliable indicator of ground water
contamination.  The IDS parameter, however, was a good signature for
highly mineralized water.   Using values of 500 ppm IDS or more to repre-
sent contaminated ground water, RES considered the results consistent
with those of the resistivity study.   The facility concluded that, based
on resistivity data and TDS values, contamination did not extend deeper
than a maximum of 28 feet  below land  surface and that the plume was
confined to the facility boundary (Figure 17a).  It was through this
study that abatement wells were first  suggested as a possible remediation
technique; an abatement program was intiated six months later.  The
highest levels of contamination were  found adjacent to the collection
and equalization ponds (what are now  the L-series lagoons) where TDS
values of 15,000 ppm were  recorded.  Wells 13, 14, and 15 all  showed
very high levels of copper, chromium, magnesium, and zinc.  Copper
levels in Well 13 were as  high  as 135  ppm while Well 15 showed total
chromium values of 150 ppm.  Most of  the metal contamination was probably
due to leakage from surface impoundments in the central  area of the
facility which are no longer in existence.

 As part of the 1972 contamination study program, RES installed 6 abatement
 wells adjacent to the L-series lagoons.  The purpose of these wells was
 to capture contamination  emanating from the Central Plant Area.   During
 a 1975 investigation high TDS  level  indicated localized spreading of
 contaminated ground water in the vicinity of Well  4 (Figure 17b).   Four
 additional  abatement wells were installed in this area  to further control
 the migration of contaminants.   TDS values from June 1977 (Figure 18a)
 were very high beneath Basins  111, 112, 114 and 115 in  the  Central  Plant
 Area and around Abatement Well  21. By April, 1978, ground  water contami-
 nation appeared to be significant around the total  Central  Plant Area
 rather than  the specific  area  outlined in the 1977  data interpretation
 (Figure 18b).  TDS levels were still very high (9,000 ppm)  beneath
 Basins 111,  112,  114, and 115.   Another area of concern became the
 Basin Closure Area where  readings of 32,000 ppm TDS were recorded at
 Well  EE.   These high concentrations were believed  to be the result of
 leakage of high temperature waste from basin B-202G.  TDS values increased
 dramatically in Wells 4 and Y  as  well  possibly as  a result  of leakage
 from basin  B-202G or from contaminant  releases during  the fire/  explosion
 of December  of 1977 which occurred in  the area.   Basins  111,  112,  114,
 and 115 were removed in late 1978.  Based on 1979  results,  ground  water
 quality in this area improved.   Wells  5 and  J, which showed  levels
 between 5,000 and  7,000 ppm in  1978, showed  decreases  in  1979 to  200
 and to 300  ppm respectively.

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                                                  -54-
                                                                          •tell loatlon
                                                                          Actim racUity Bnndciy
                                                                          TCE Odntcurs (in ppn) • Harcil 1972
                                                                                        N
                                                    Feet
                                                                   S"oo —
•toll location
Actlm FKUlty ftankiy
TOS Centaur* (in ppn) - 1975
                                                                                        N
                              Rollins Brvixonnental Services Facility Map - 1972

Figure 17.   Total dissolved solids  (TDS)  contours  at RES for  (a)  1972  and
                (b)  1975.

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                                                   -55-
(a)
                                                            •      Hell Location
                                                         — - 	   Active Facility Boundary
                                                         — SOO —   TOS Contours (in ppn) - 1977
(b)
                                                            •      Hell Location
                                                         — - —   Active Facility Boundary
                                                         — SOO —   TOS Contours (in ppn) - 1978
                               Rollins Envirrwmental Son/ires Facility Mnp - 1980
Figure 18.   Total dissolved  solids  (TDS) contours at RES for  (a)  1977 and
                (b)  1978.

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                                -56-
Other than these particular areas, the extent of ground water contamination
did not change significantly (see Table 1 for a  summary of IDS data
through 1980).  In June, 1980, RES submitted ground  water data from  south
of a location where sealed drums of arsenic  were stored between 1970-1974,
known as the "arsenic vaults."  Well  G showed arsenic concentrations of
0.34 mg/1 , well over the maximum allowable concentrations of 0.05 mg/1.
Also during this time period RES submitted Basin Closure Plans for the
B-series lagoons/impoundments.  Even with improved waste management
practices  (many of the surface impoundments  in the Central  Plant Area
were removed) IDS levels were still  very high in 1981.   The highest  levels
of total dissolved solids centered around the Basin  Closure Area and the
L-series lagoons with localized high levels  (17,000  ppm TDS) found in the
North Marsh Area at Well 4.  In the fall  of  1981, RES installed clusters
of monitoring wells in the North Marsh Area  (MA series); preliminary
results did not show contamination.

The first  study undertaken at the RES site to analyze the ground water  for
specific organic constituents was initiated  in October, 1981.  Ground water
samples were collected from monitoring wells II, W6, W7, EE2 and 29.
These wells were all located in and around the Basin Closure Area.  Analyses
included Priorty Pollutants, metals, cyanide, and phenols.   Volatile or-
ganics were evident in all 5 wells.   Benzene, TCE, 1,2,-dichloroethane,
toluene, and ethylbenzene were all present in significant quantities.  High
values included:  2,850 ppb benzene at W7; 1,930 ppb benzene at W6;  2,032
ppb 1,2,-dichloroethane at EE2; 353 ppb TCE  at 29; 208 ppb toluene at II;
and 408 ppb ethylbenzene at W7.  Of the five wells,  ground  water from II
was least  contaminated with volatile organics.  Ground water from W6, 29
and W7 showed evidence of base neutral organic contamination:  469 ppb
N-nitrosodimethylamine at W7; 246 ppb bis (2-chloroethyl) ether at 29;
and 22 ppb 1,2-dichlorobenzene at W6.  W7 contained  the highest total
concentration of base-neutral organic compounds.  Acid extractable compounds
were most  prevalent in ground water from wells W7 and 29:  1,925 ppb
2,4-dichlorophenol at W7; 1,593 ppb phenol at W7; 1,191 ppb 2,4-dimethyl-
phenol at  29; and 1,220 ppb phenol at 29.  Once  again, the highest values
were recorded at W7, downgradient of B-202,  within the Basin Closure
Area.  Until 1970, liquid wastes were deposited  in unlined basin B-202.
Subsequently, the basin was used for acid neutralization sludges.  Waste
management practices, particularly in and around B-202, are believed to
have been  a major cause for the ground water contamination intercepted  by
the above  wells.  Arsenic levels were also very high in W7 (2.05 ppm).
Contamination could have been the result of  metal plating waste treatment
processes  in B-202 or leakage from arsenic vaults to the north of B202.
TDS values were also very high in the Basin  Closure  Area, ranging from
10,529 ppm in W6 to 16,219 ppm in EE2.

By entering into an AGO on November 23, 1981, RES, for the first time,
became subject to a specific ground water monitoring program with the
intention  of assessing the extent of ground  water contamination at the
site.  The monitoring wells utilized sampling parameters and a time
schedule for sampling which are presented in Table 2.  Unfortunately,

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                                             -57-
                       TDS CONCENTRATIOHS AT RES,  1972-1980  (ppm)
Well
1
3
4
5
6
11
12
13
14
15
16
17
B
C
E
F
G
H
I
J
K
P
Q
20
21
22
23
24
25
R
S
T
D
V
W
z
20A
20B
26
27
28
29
EE
HE
AA
DD
II
March1
1972
245
365
200
150
150
1,350
5,100
2,700
1 ,800
5,000
1 ,400
1 ,000
135
147

1 ,583
1,022
1,324
2,700
775
535
448
52
300
2,500
1,500
1 ,000
730
235


















19761

1,000
575

1 ,100
4,500
2,500
5,000
1 ,500
15,000
1,500
3,700
234
496



1,578
1,792
1,924
487
733
266
500
3,200
700
1,595
2,500
500


















19772


1,378
9,096

2,246
1,396
12,181
3,911
25,397
1,000
3,532
79
247
70


1,620

4,564
1 ,050
214
130

15,662
16,804
5,986
5,565
4,919
617
266
264
109
100
255

2,917
1 ,456
921
3,360







April
1978


3,315
9,596

1 ,950
1 ,482
2,115
3,522
9,116
1 ,987
2,369
197
392





6,106
1,529
257


4,543
525
3,831
3,655

325
222
268
102
1 29
197

356
826
719
857







March
1979


2,417
239



511
2,732
26,310

1,922












2,791
1,293
2,351
1,502
1 ,145
324

283
130
144
166
466
1 ,041
237
2,177
1 ,511


31 ,562
164
447
579

19803


8,376




475
2,042
5,610
2,380
6,033
179
210







362


5,827
1,947
2,232
4,207
4,080
754

250
111
124
265

640
1 ,340
1 ,097
1 ,093
2,460
3,303
15,350
261

268
1,095
1.  Values  are  average from samples taken during 1975  and January, 1976.
2.  Values  are  from  samples taken in January, February,  and March.
3.  Values  are  averages from samples taken during 1980.
                                    Table 1

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                                          -58-
(A)                      SAMPLING WELLS  MJD PARAMETERS  AT  RES -  1981 AGO


      Wells Sampled          Wells Sampled          Wells  Sampled          Wells Sampled
        Quarterly               Yearly             Quarterly for          Quarterly for
                                                   	PCBs                  Arsenic
       2 Ob   28                 DP1    R
       21    29                 DP2   U                  14                  29    W12
       22     4                 DP3   W                  21                  EE1   W17
       23    EE3                DP4   CC                 22                  EE2   AV-1
       24    HH                 TJP5   DD                 322-2               II    AV-2
       25                       11     EE1                                    4     AV-3
       26                       12    EE2                                    11    AV-4
       27                       13    II              .                      12    DP3
                                14    MW1                                    Ml 1
                                B     MW3
                                C     MW5
                                P4

      Parameters              Parameters

         TDS                   TDS  Cd
         TOC                   TOC  Cr
         pH                    pH   Cu
         TOX                   TOX  Zn
                               As   Pb
                               Phenols
                               MO3-N


(B)                 SAMPLING WELLS AND PARAMETERS AT RES - 1983  AGO (unsigned)


                   Wells  Sampled           Wells Sampled          Wells Sampled
                     Quarterly                Yearly             Quarterly for
                                                                     PCBs
                     20b     25              DPI    P4
                     21-a   4               DP2    R                  14
                     22      HH              DP3    D                  21-a
                     23      35              DP4    W                  22
                     24                      DPS    CC                 322-2
                     305  and D              13     DD
                     31S  and D              1411
                     32S  and D              B     MW5
                     33S  and D              C     W21
                     34S  and D              MW1    W23
                                            MW3
                                            MA6S,I,D
                                            MAI OS,I,D
                                            MA11S,I,D

                    Parameters              Parameters
                       TDS                    TDS   Cd
                       TOC                    TOC   Cr
                       pH                    pH    Cu
                       TOX                    TOX   Zn
                                             AS
                                             Phenols
                                             M03-H
                                     Table 2

-------
                                -59-


the Order did not specify provisions to sample wells  for organic  consti-
tuents besides the broad based indicators - TOC and TOX.  The Order did,
however, require that 15 wells be sampled quarterly and 17 annually for
arsenic.  Five wells screened in the shallow artesian zone were in place
by this time and were part of the monitoring program.  By March,  1982,
RES was operating with both the 30-series and 20-series abatement wells.
The older 20-series system is adjacent to the L-series lagoons and the
30-series wells (screened in both shallow and deeper  levels of the water
table zone)  intercept contaminated ground water from  the Basin Closure
Area and North Marsh Area.

Results based on the new monitoring program through 1983 were not signifi-
cantly different than results up to that time.  For the first time,
however, arsenic analyses were being performed over a wide area.   Arsenic
contamination was most prevalent in the Basin Closure Area and the North
Marsh Area.   The highest recorded arsenic values were from EE3, near
B-202, and the arsenic vaults which showed concentrations in 1982 of 1.02
ppm, 20 times the drinking water standard of 0.05 ppm.  Other values in
the Basin Closure Area included:  0.13 ppm at W12, 0.69 ppm at EE2, 0.18
ppm at AVI and 0.13 ppm at AV3a.  In the North Marsh  Area, downgradient
of the Basin Closure Area, values were:  0.50 ppm at  MA10I, 0.85  ppm at
31D, 0.35 ppm at 330, and 0.49 ppm at 29.  While it cannot be certain
whether arsenic contamination is a result of leakage  specifically from
the arsenic  vaults, it appears reasonably certain that contamination
is from the  Basin Closure Area in general.  Closure of the basin  area,
which includes all B-series impoundments, began in 1982 and was completed
in 1986, prior to the Task Force Inspection.

TOX values,  a broad indicator of organic contamination, were relatively
high in the  North Marsh Area in 1982, especially around Well 4a where
levels reached 33.3 ppm.  Maximum allowable ground water concentrations
for TOX are  0.05 ppm.  High levels were also found in Wells 29, MW5 and
HH.  Unfortunately RES used (and still uses) sampling methods whose
detection limits are above drinking water standards;  thus a true  picture
of organic contamination is not available.  The same  is true for  lead.
The detection limit of 0.2 ppm is well above the drinking water standard
of 0.05 ppm.  Even so, elevated levels of lead were found in the  North
Marsh Area (1.4 ppm at MA10S) at up to 20 times the drinking water standard.
Elevated levels of chromium and copper were also found in the North Marsh
Area during  the 1982 studies.  Chromium contamination was most prevalent
at Wells MA10S, I, and MA11S where values of up to 1.46 ppm were  recorded.
Minor copper contamination also exists in the North Marsh Area; values of
1.10 ppm and 1.04 ppm were recorded at Wells MA10I and 31S respectively.

A revised AGO was issued in August, 1983.  Although the ACO was never
signed, RES  adhered to its ground water monitoring program (Table 2).  It
differed from the 1981 program in that many of the wells in the original
sampling program, because of basin closure, were replaced by wells in the
North Marsh  Area (the MA-series and 30-series wells).  Also, in the 1983
Order, quarterly analyses for arsenic were no longer  required.

-------
                                -60-
Arsenic remained a parameter for yearly sampling,  however.   This  monitoring
program did not change appreciably through  1985.   Annual  surveys  for  both
1984 and 1985 concluded that the "extent of contamination in the  water
table zone (remains)  virtually unchanged."

In 1984 the 500 mg/1  IDS contour, which RES has  used  to  define  ground water
contamination, moved  northward into the North  Marsh Area, possibly as a
result of pumpage from the 30-series wells.  Otherwise,  IDS  levels did
not change significantly (Figure 19a).   As  in  1981-1983, TOX detection
limits were above drinking water standards; thus,  this  indicator  did  not
adequately delineate  organic contamination.  TOX levels  greater than  1
mg/1 were found in Wells 20B, 4a, 24 and 25 (1.2 ppm.,  4.9 ppm, 2.6 ppm,
and 1.3 ppm respectively, were detected).   These high values appeared in
both the North Marsh  Area and along the northern boundary of the  L-series
lagoons.  Phenol, chromium and arsenic  contamination  was confined to  the
same area cited above.  Arsenic levels  of 0.12 ppm and  0.10  ppm were
detected in Wells 34S and MWla respectively, and 2.50 ppm chromium was
detected at 30S.  High cadmium levels were  recorded in  wells adjacent to
the L-series lagoons.  It is important  to note that both inorganic
(metals, TDS) and organic (TOC, TOX) parameters  indicated that  contaminat-
ion was present in the deeper ground water  zones of the  North Marsh
Area, at levels 40-70 feet below land surface.  RES'  consultants  inter-
preted this zone to be deeper portion of the water table zone.   In 1984,
the shallow artesian  zone wells (DP1-5) continued  to  yield uncontaminated
ground water with TDS levels averaging  under 200 ppm.

The ground water monitoring program did not change during 1985  and conclu-
sions regarding ground water contamination  remained essentially the same.
TDS distribution remained constant.  Very high concentrations continued
to be detected adjacent to the L-series lagoons.  Because basin closure
(B-series Basins) included the removal  of all  wells  in  the area,  ground
water quality beneath this area could not be determined.  Levels  of
inorganic and organic contamination remained close to levels observed in
1984.  Unfortunately, the analytical detection limit  for arsenic  increased
from 0.10 to 0.1, above drinking water standards.   Therefore, values
attained in 1985 are not meaningful.  For the first  time, ground  water
from one of the shallow artesian wells (DP5), showed  minor amounts of
l,2dichloroethane and trichloroethylene contamination.   After resampling,
these results were shown to be representative of ground water conditions.
Ground water from other deep wells continued to be of good quality.  RES'
consultants conducted an electrical earth resistivity survey as required
by the 1981 AGO.  RES concluded that the results confirmed those  of the
ground water study.  Multiple depth measurements were made by varying
electrode spacing from 20 to 100 feet, in 20 foot increments.  It is
interesting to note that even at a 100 foot spacing   (which describes
resistivity at a depth of 100 feet), very low resistivity measurements
were recorded  (40 to 100 Ohm/feet) implying highly mineralized  ground
water at depth.

-------
                                                            -61-
 (a)
                                                                            Basin Clocuxv Area      t i
                                                                        (waste stahiliMd and caffed)  \ I
                                                                 	    Activ. Facility Boundary


                                                                 ^iOO —  TD6 Contours (in feet) - 1984
              Rollins Environmental Servlde*
              Facility Map - 1987
                                                       ftet
(b)
              toll in* Diviromental Service*
              Facility Map - 1987
                                                                            Well Location
                                                                             (not all well* show)
                                                                 —— - —   Activ* Facility Boundary

                                                                            IDS Contours (in feet) - 1986
                                                       Feet
Figure 19.   Total  dissolved solids  (TDS)  contours  at RES  for  (a)  1984 and
                  (b)  1986.

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                                  -62-
  In 1985,  RES  was  also  attempting  to  comply with  RCRA  Part B  Permit appli-
  cation  requirements  as  well  as  Interim  Status  (40 CFR 265) regulations.
  RES had been  operating  10  RCRA  "regulated units":   the 8 L-series lagoons,
  B-206,  and  B-207.   As  required  under Interim Status,  RES must monitor these
  units in  order  to  ascertain  whether  they are leaking  contaminants into
  the ground  water.   After a technical  NOD was issued in August 1985,  RES
  resubmitted their  RCRA Part  B application in December and specified  that
  8 wells (new  wells W24 through  W31)  would monitor basins B-206 and B-207.
  RES claimed that  these  units were not leaking  and requested  that  NJDEP
  place them  in a Detection  Monitoring Program.  The  RCRA wells were to be
  sampled for parameters  and at a frequency already specified  in the unsigned
  1983 ACO  ground water  monitoring  program (see  Table 2).  Because  of
  acknowledged  ground  water  contamination, RES also requested  that  NJDEP
  place the rest  of  the  site in a Corrective Action Program.   This  program
  consisted of  the  17  pumping  wells already in operation (the  30-series and
  20-series wells).   RES'  "Interim  Status" wells would  include those sampled
  from 1983-1985  (in compliance with the  1983 ACO) along with  wells W24-31
  around  B-206  and  B-207.

  In another  technical  NOD,  dated April 17, 1986,  in  reference to RES'
  revised RCRA  Part  B  application,  NJDEP  indentified  specific  deficiencies
  particular  to the  RES  ground water program.  With regard to  ground water
  quality,  some of  these deficiencies  included:

1)  the results of  any statistical  analysis performed to date, and  a
    description of  the procedure  used  needs to be  provided, especially for
    the detection monitoring system around surface impoundments B206 and
    B207.  The  current system  does  not meet the  requirements of N.J.A.C.
    7:14A-6.15.

2)  RES should  provide a decription of any plume of contamination that has
    entered the ground water from the  facility including:  (a)  the plume
    delineated  on the  topographic map  required under  N.J.A.C.  7:26-12.2(e)13
    and,  (b)  indentification of the concentration  of  each  hazardous consti-
    tuent listed  in  N.J.A.C. 7:26-8.16 throughout  the plume or identification
    of the  maximum  concentrations of each hazardous constituent listed in
    N.J.A.C.  7:26-8.16 in the  plume.

3)  In accordance with N.J.A.C. 7:26-12.2(g)5, RES must provide detailed
    plans describing the proposed ground  water monitoring  program to be
    implemented to  meet  the  requirements  of N.J.A.C.  7:14-6.15(h).

4)  RES must submit sufficient information, supporting  data, and analyses
    used  to establish  a  corrective  action program  which meets  the require-
    ments of N.J.A.C.  7:14A-6.15(k) and includes the  extent and concentrations
    of constituents  in N.J.A.C. 7:268.16  and concentration limits for  each
    hazardous constituent found in  the ground water as  set forth in N.J.A.C.
    7:14A-6.15(e).

-------
                                -63-
The facility realized that, because the entire site was contaminated and
B-206 and B-207 were downgradient of the contaminated areas and because
B-206 and B-207 contain the same contaminants as does the ground water
flowing beneath it, statistical analysis of upgradient and downgradient
wells would not be able to show whether or not the basins were leaking
as required by a Detection Monitoring Program.  For this reason RES
decided to proceed as if the basins were leaking contaminants into the
ground water and include them in a State Corrective Action Program for
the entire site.

RES admitted that it did not have enough data to delineate the contaminant
plume with respect to all constituents found in the ground water.  It did,
however, propose a new monitoring plan which would take into account
specific organic constituents.   Based on IDS data already submitted, RES
gave a general estimate of plume size:  2,300 feet long, 1,400 feet wide
and 25 feet thick.  RES contended that based upon analyses following the
new monitoring plan, the facility would be able to delineate the plume
for specific parameters and be able to change the abatement system accord-
ingly.  A significant portion of the NOD dealt with RES' interpretation
of the local hydrogeologic regime, an interpretation which NJDEP believed
to be inadequate.  RES' response was essentially a summary of much of the
information discussed in the preceding Section 3 on Site Hydrogeology.  A
critical analysis of RES interpretations of hydrogeologic data and histor-
ical ground water quality data will follow in Section 5.

Because NJDEP never gave a formal response to the new monitoring plan pro-
posed by RES, the facility continued the monitoring plan as specified in
the unsigned 1983 AGO (with the addition of Wells W24-31).  In the summer
of 1986, EPA sampled 9 wells at the facility.  All samples were collected
in accordance with EPA, Region II protocol, and all samples were split
with RES personnel.  Results of total metal analyses indicated that
arsenic and chromium contamination continued to be a problem at the site.
Four of the 9 wells showed contaminant concentrations above drinking
water standards (0.14 ppm at Well 31D and 21 ppm Cr at Well 15).  Zinc,
lead, and copper contamination was found in isolated areas.  Results of
organic analyses (volatiles and non-volatiles) indicated substantial
organic contamination in Wells 4A, 15, 31D, 31S, II and 24.  Approximately
30 organic compounds were detected.  The highest values of organic contam-
inants were detected in Well 4A, an area of known organic contamination.
Results from Well 4A included:  18 ppm toluene, 7.7 ppm TCE, 5.1 ppm
napthalene, and 1.2 ppm ethylbenzene.  While this was not meant to be
comprehensive plume analysis, it did show the need for much more rigorous
sampling and essentially confirmed EPA results.

Prior to the Task Force Investigation, RES submitted its 1986 Annual  Ground
Water Report.  As mentioned above, sampling locations and parameters had
not changed significantly from preceding years.  Interpretations were
also similar to those of the previous 4 years.  The report concluded that

-------
                                -64-
ground water contamination remains,  for the most part,  confined  to the
site and can be defined by the 500 mg/1 IDS contour (see Figure  19b).
Exceptions include Wells R and AV2 which show some organic contamination.
In the 1986 data analysis, detection limits were lowered for arsenic and
lead to below drink water standards, thereby making the data more meaning-
ful and conclusive,  results were similar to those of the EPA study from
the previous summer.

Chromium contamination continues to be evident in the North Marsh Area
(although levels exceeding drinking water standards have been observed
in the Central Plant Area as well - as seen in Wells 14 [0.07 ppm] and
MW3a [0.05 ppm]).  Organic contamination was again detected in shallow
artesian well DP5.  RES recommended that DP5 be sampled for VOCs on a
quarterly basis to determine the concentration for these compounds.
Twenty-one ground water samples were taken as part of the Ground Water
Task Force and analyzed for the full "Appendix IX" sampling suite.
Results are presented in another section.

-------
                                 -65-
5.   Discussion

    Rollins  Environmental  Services  (RES)  began  operation  in  1969;  soon
    after,  the facility documented  ground  water contamination  beneath
    the plant site.   The first  ground  water  assessment  study was submitted
    in early 1972.   Using  Total  Dissolved  Solids (TDS)  as  an indicator
    of contamination, RES  and their consultants, Geraghty  and  Miller,
    continued through the  next  10 years  to monitor  what they considered
    the contaminant  plume  and to abate the spreading  of contaminants by
    installing pumping wells on  the site.  In November  of  1981, RES and
    NJDEP entered  into a Consent Agreement whereby  RES  would institute a
    more formal  plan  to describe site  hydrogeology  and  assess  ground
    water contamination.  Specific  organics  were first  detected in the
    ground  water beneath the RES site  as  a result of  a  study conducted
    in early 1982.   These  finding were confirmed in subsequent analyses
    performed in 1985, 1986, and most  recently, during  the 1987 Ground
    Water Task Force  Investigation.  RES,  however,  still uses  TDS  as the
    parameter to define the boundary of  ground  water  contamination.  The
    facility has been submitting annual  reports for the last 5 years
    which describe the progress  of  the contamination  abatement program.
    According to RES, the  contaminant  plume, as defined by TDS, continues
    to remain confined to  the facility boundary.  RES concludes that the
    extent  of ground  water contamination  remains virtually unchanged
    since 1983 and maintains that their  ground  water  pumping system
    (which  has also  remained the same  since  1983) is  "effectively  limiting
    contaminated ground water to the site."

    There are currently 123 ground  water monitoring wells  in or around
    the perimeter of  the RES site.   81 of  these wells are either currently
    used in  a monitoring program or have  been used  for  periodic sampling
    within  the last  few years.   The number of wells whose  integrity has
    been maintained  through the  years  and  whose construction quality and
    maintenance can  insure precise  and accurate sampling results is sign-
    ificantly lower.   Much of the work concerning hydrogeology, plume
    assessment, and  ground water contamination  abatement at  the RES site
    has been produced as a result the  1972 study and  the studies submitted
    in 1981-1982 as  part of
    the 1981 AGO requirements.

    The April  1972 study,  RES'  first attempt to characterize site  hydro-
    geology  and define the extent of contamination, became the basis and
    reference report  for subsequent work.  As mentioned in the previous
    chapter, the study consisted of an earth resistivity survey and the
    installation of monitoring wells in the  water table aquifer.   Test
    drilling was carried out simultaneously  with  the  resistivity survey
    to provide the control necessary to substantiate  the validity of the
    method.   Apparent earth resistivity is controlled primarly by  the
    types of sediments in  the subsurface,  the degree  of saturation of the
    sediments, and the concentration of conducting  ions within the
    ground  water.  Thus, an understanding  of the  subsurface  is extremely
    important, especially  at a especially  at a  site such as  RES where

-------
                             -66-
the underlying stratigraphy is  quite  complex.   RES  used curves of apparent
resistivity vesus depth and cumulative  resistivity  versus depth to  inter-
pret the data.  600 to 800 Ohm-feet was used as  a cutoff value to indicate
zones of possibly high levels of mineralized waters  (with readings  below
600 Ohm-feet signifying possible ground water  contamination).  Through
this program, RES concluded that contamination did  not extend beyond  the
facility boundary and did not exist deeper  "than a  maximum  of 28 feet
below land surface."  However,  upon review  of  the vertical  resistivity
profiles, these conclusions are not readily apparent.  Final conclusions
were reached by interpreting cumulative resistivity curves  instead  of the
600 to 800 Ohm-feet cutoff values.  A series of  straight lines were drawn
through points in the profiles.  Changes in slope represented change  in
geology or ground water quality.  For example, a decrease in slope  may
signify a decrease in ground water  quality.

Examples presented in Figure 20 a,b,c show  the highly subjective nature
of these interpretations.  In  Profile RP5,  RES'  consultants highlighted
a decrease in slope within 10 feet of land  surface  and determined it  to
signify a zone of highly mineralized  ground water.   However, one could
draw a straight line through the whole  set  of  points and interpret  there
to be contamination to a depth  of 48  feet below  land surface; apparent
resistivities below 600 ohm-feet are  through the entire vertical sequence.
In RP6, resistivity decreases down  to a depth  of 51 feet.   RES, however,
concluded that, based on its interpretation of cumulative resistivity,
contamination was only evident  between  depths  of 9  and 27 feet below  land
surface.  All resistivity readings  in RP7 show low  levels through a depth
of 51 feet.  By plotting slope  changes  in cumulative resistivities, RES'
consultants concluded that contamination was only present between 3 and
21 feet below land surface.  This interpretation, again, is highly  sub-
jective.  Theoretical methods  of interpretation  such as curve matching
might have aided in the study.   With  the help  of geologic logs, field
data could be plotted and compared  with master curves developed for a
number of resistivity layers with defined ratios of resistivity and thick-
ness.  With more control on geology,  a negative  resistivity departure
method could have been used to  correct the  data  and provide more meaningful
interpretations.

17 wells were installed as part of the 1972 study.   Based on the drill
logs from these wells, 2 geologic cross-sections were developed (Figure
21a).  According to RES interpretations, a  "more or less continuous"  clay
zone exists beneath the tract  and that the  top of this clay ranges  from  +3
to -18 feet in elevation.  Upon review of the  logs, the  interpretation of
a continuous clay layer appears unsubstantiated. There are clay lenses
throughout the site; however,  they do not appear to be laterally continuous.
Several of the logs show sand  to sand with  some  clay through entire
borings  (Wells D, F, and P).  Temporary well  screens were  set  at various
depths in several wells to obtain vertical  profiles of total dissolved
solids (TDS)  (Figure 21b).  Of the 16 wells that were  profiled,

-------
                                  VERTICAL RESISTIVITY PROFILE


                                               HP 5
                      igrtly mineralized

                        ground water
 'f 400

-s
je

 *


| 200
 4»
 g
<    o
                                                            36



                                 VERTJCAL RESISTIVITY PROFILE



                                              RP6
                                                                      42
48
                                                                      42
                                                                               48
                                  VERTICAL RESISTIVITY PROFILE


                                              RP7
                                           'Highly mineralized

                                               ground water
                        12       IS       24       30       36       42

                        Ovpfh Ulow Und wrfoc«,  In fe«t UlKtrede (facing)
                                                                               48
                                                                                         6  •?


                                                                                            •I
                                                                                             c
                                                                                          4 2
                                                                                             •»

                                                                                             e

                                                                                            ^
                                                                                             c

                                                                                          2
                                                                                            o

                                                                                            "x
                                                                                         4  =
                                                                                            V*

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                                                                                                    CN
                                                                                                    r-
                                                                                                    CTi
                                                                                                    I
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                                                                                                    I
                                                                                                     8
                                                                                                    o
                                                                                                    (N

                                                                                                     0)

-------
                                                      -68-
                        Geologic  Cross-sections with TDS Data at  RES - 1972
         NW
   -lOf-
   -»h
3  -»u
-i
 .   30r
I   29-

               T.D.
         SW
 1ft-

 0

-10-

-20

-X

 X

 20

 10

 0

 -10

 -20

 •:

                                                                                                        T.O.
                                                                         T.O.
1535
1731
X255
                  I77J
                  12771
                  12)4
                                    3*000
                                    13*000   I54J
                                            1158
                                                         2421
-IHS3 	

1877
1 448
1334
1332
Z247
"TTot
174 •
'140,
34*
278
300





 30

 20

 10



-10

-20-

-30
          SW
1700
1585
I«4
„

11777
1763
I 3411
11030

1396
11324
1545
1358
1315
_BU«1 	
3087



                                                     13

                                                            C   ~™7
                                                            |2W7     419|
                                                                                        1022
                                                                              1577
                                                                              1322
                                                                                                         149
                                                                                                         152
                                                                          1422
                ]  Woll moon totring

                T  Tompony Mil Kroon toHlng

               731 Totol diMlTCrf toll* In porn por million

                  Datum: «IO foot at Inclnorator pod
                                                                                    500
                                                                         Feet
    Figure 21.   Geologic cross-sections with total  dissolved solids  (TDS)  data
                   at RES.   From Geraghty & Miller  (1972).

-------
                                -69-
11 of them showed a decrease in IDS below 500 ppm 10 to 20 feet below land
surface.  However, for several  wells near unlined surface impoundments,
IDS levels remained well  above 500 ppm below depths of 20 feet.

RES determined that the ground water discharge from the facility boundary
to Raccoon Creek was on the order of 5,000 gallons per day.  While the
cross-sectional  area and  hydraulic gradient (2,000 ft and .0025 respectively)
are reasonable values, the estimated hydraulic conductivity and unit thick-
ness may be inaccurate.  Because of the thick clay layers adjacent to
Raccoon Creek, RES assumed a low permeability of 100 gpd/ft^.  There are,
however, areas adjacent to the creek where permeabilities are probably
substantially higher.  Logs of Wells 25, MW7, K, and DP2, all adjacent to
Raccoon Creek, show thick sand layers.  Hydraulic conductivity values at
some shallow wells are greater than 1,000 gpd/ft^.  Another parameter,
the average thickness of  the shallow deposits affected by contamination,
which RES calculated as 10 feet, is also quite conservative.  The thick-
ness, based on the data in the 1972 report, is at least 20 feet in many
areas, and from later data from the North Marsh Area, the thickness of
contaminated sediment may be as high as 40 to 70 feet.  Discharge to
Raccoon Creek may be over 100,000 gpd from the water table aquifer.

The RES abatement system  improved through the 1970's as more wells were
installed and pumpage rates were increased.  Major changes to the monitoring
program occurred as a result of the November, 1981, AGO.   A shallow
artesian zone well test carried out in October, 1981, was designed to
characterize the hydrologic properties of the shallow artesian zone and
the degree of connection  to the water table zone.  The results of this
test are presented in Chapter 3.  Generally, water table  wells to the
south of DP4 (the shallow artesian well which was pumped) showed some
drawndown while those to  the southeast did not.  The test was run primarily
for qualitative purposes; the conclusion that there is a  hydraulic connec-
tion between aquifers in  the Basin Closure Area is a valid one.  Unfortu-
nately this type of test  was not run in the Central Plant Area where most
of the contamination problems exist.  However, an inherent problem in
running this test in a contaminated area is drawing down  contaminated
ground water into an uncontaminated aquifer.  Background  water level
readings were not taken in some wells; because of the low drawdown in
these wells, spurious conclusions may have been reached.   Results from
the EE series wells, 30 feet from the pumping well and screened at
different levels in the water table zone, are excellent evidence of the
connection between the two aquifers.  EE2 (screened at 26-30 feet) and
EE3 (screened at 33-39 feet) showed close to a foot of drawdown.  Drawdown
was observed only 10 minutes after pumping of DPS began.   This is a very
quick response and a very large drawdown in a zone which  RES contends is
separated from the shallow artesian zone by 7 feet of low permeability
clay.  In the area of the EE series wells, the aquifer acts almost
unconfined from the "water table zone" through the "shallow artesian
zone."  The well log of DP3, however, shows 6-8 feet of "stiff" clay at
48 to 56 feet below land

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                                -70-
surface.  If this clay layer is  continuous  in  the  southern  part  of  the
facility, it may explain why water table  wells in  that  area do not  show
appreciable drawdown.   The well  test should have  proceeded  for more than
29 hours to determine  delayed yield effects.

The quantitative results of the  well  test are  tenuous.   The transmissivity
(90,000 gpd/ft) and storage coefficient (4.6 x 10~4)  were derived  from
leaky artesian type-curves.  However, it  is not certain what assumptions
were considered in using the curves.  DP4 is a partially penetrating well;
this characteristic might have affected the results  if  not  taken into
consideration.  The aquifer characteristics are probably more complex
than those assumed using simple  leaky artesian type-curves.  Well  logs do
not support a 7 foot confining layer of any lateral  continuity.   The
aquifer thickness is derived from one well  log, that  of the sealed  Main
Production Well.  According to the abbreviated geologic log of the  Main
Production Well, a sandy/gravel  unit, presumeably the shallow artesian
zone, exists between 36 and 92 feet below land surface.  Based on  the
heterogeneous quality of the subsurface described  in  other  logs, it is
highly unlikely that the shallow artesian zone is  53  feet thick  through-
out the entire site.  In the North Marsh  Area, many  of  the  water table
zone wells are screened below a  depth 36  feet placing them, stratigraph-
ically, in the shallow artesian  zone with no intervening confining  layer.

On August 2, 1982, in  order to design a more adequate pumping program at
the facility, RES ran  a number of short term well  tests in  the water
table zone.  As described in Chapter III, an alternating sequence  of
pumping wells was used whereby each well  would be  pumped for 12  hours
with 6 hours overlap between the time one well would  be turned on  and the
previous one turned off.  Distance-drawdown graphs were made for each
pumping well after 12 hours of continuous pumping.  Using these  graphs,
drawdowns at midpoints (between  two pumping wells) were determined.  For
adjacent pumping wells the midpoint drawdown measurements were added and
the resulting value represented  the minimum drawdown  between two pumping
wells.  If there was no drawdown at the midpoint,  RES concluded  that
another abatement well would be  needed.  Field determinations were  matched
with formula calculations.  Calculations  based on  Jacob's straight  line
method were used to determine transmissivity, storativity
conductivity.  A formula from a  text book by Todd  (1959),
Hydrology, was used to check the adequacy of the  drawdown
range between two wells:
                                                   and hydraulic
                                                   Ground Water
 Q=
 k=
  =
 r=
hu=
h
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                                -71-


If the discharge rates determined from Todd's formula were greater than
discharge rates in the field, abatement wells would have to be added to
the system.

Both the field methods and formula calculations contain flaws.  The
superimposed "midpoint" drawdown between two pumping wells were obtained
by assuming that the two wells were pumping for the same 12 hour time
period.  This, however, was not the case.  In RES'  sequential  pumping
scheme, two adjacent wells would pump simultaneously for only 6 hours.
No steady state was reached since during that time  period the midpoint
observation well was affected by starting up one of the wells.  The
observation wells may have been influenced by the residual drawdown effects
from other pumping wells and natural diurnal effects.  The midpoint values,
important field measurements that determine the pumping zone of influence,
may, as a result of this test method, be higher than they should be.

The flaws in the formula calculations used to check the field results are
serious because they are based on fallacious assumptions.  RES used Jacob's
straight line method (for a discussion of this method, see Kruseman and
DeRidder, 1970) to determine values for transmissivity (T) and storativity
(S).  However, using this method in a unconfined aquifer usually requires
that the aquifer be pumped for greater than 12 hours in order that u <
0.01 (u is a parameter within the Theis equation).   Delayed yield affects
of the water table aquifer, which are needed to calculate T and S, are
not taken into consideration.  However, even if delayed yield occurs
during the 12 hours of pumping, it would be masked  by the effects of
turning off one of the pumping wells.  Todd's formula is also based on
strict assumptions.  This formula which describes a minimum Q (flow rate)
to produce drawdown between two pumping wells, assumes fully penetrating
pumping wells and steady state conditions.  Both of these conditions are
not met in this study.  Values used in the equation are suspect.  After
review of appropriate well logs, aquifer thickness  calculations appear
to be unsubstantiated.  Because of continuous pumping at the facility,
static water level  measurements are difficult to obtain.  The values that
RES uses are estimates in many cases and are not based on field data.
Because of a lack of sound geologic and hydrologic  information at the
site, the pumpage rates that RES had determined to  be necessary to confine
contaminated ground water to the site may be inadequate.

Another purpose of the above study was to establish a schedule for inter-
mittent pumping once required pumping rates were determined.  In comparing
static water levels and induced water levels near abatement wells, RES
computed how much time a well could be turned off and still contain "a
drop of water" within its cone of drawdown.   For example, if a pumping
gradient is 12 times steeper than the natural  gradient, by pumping a well
for 1 day and leaving it off for 12 days, theoretically, contaminated
ground water will  not leave the capture zone.  Once again, however, the
values used in the  calculations are suspect.   Static water level gradients

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                                -72-
are often estimates and induced  drawdown  gradients  may  be  affected  by  other
pumping wells.   Also, the  assumption  that this  scheme works  is  a  theore-
tical one, not  based on any field  studies.  RES concludes  that  the
average total  pumping rate in  this alternating  pumping  scheme should be
97 gpm (140,000 gpd) to effectively maintain an adequate  pumping  barrier
to confine ground water contamination to  the site.   However,  upon review
of the data used to make these calculations, this  pumping  scheme  may
need substantial revision.  Moreover, the system has been  developed to
prohibit contamination from leaving the site; it is a passive system.
It is not designed to actively remediate  contamination.

Since 1972, when ground water  contamination beneath the  facility  was first
documented, RES has used total dissolved  solids (IDS) as  the  parameter
to define the limits of the contaminant plume.   Substantial  organic con-
tamination was  detected in 1981.  RES contends  that the  extent  of organic
as well as arsenic and heavy metal contamination is also  "confined  to  the
RES site and that the 500 mg/1 IDS line accurately describes  the  extent
of ... contamination."   The facility concludes  that,  "based  on indicator
parameters (IDS, TOC, TOX, and phenols),  the extent of  contamination in
the water table zone is virtually unchanged since  [1983],  indicating that
continued pumping of the abatement well system  is  effectively confining
contaminated ground water to the site."

For the most part, IDS levels  have not changed  substantially through time.
There does, however, appear to be some migration of highly mineralized
water toward the North Marsh Area.  The highest levels  are recorded ad-
jacent to the unlined L-series lagoons.  While  the lagoons are  known to
be leaking, some of the very high readings may be  a function of induced
recharge of the nearby pumping wells.  In its annual submittals,  RES
appears to interpret data with an obvious bias.  If TDS levels  are  in-
creasing at a certain well, RES contends  that nearby abatement  wells are
responsible by drawing in and  capturing contaminated ground  water (thereby
temporarily increasing contamination  in the observed area).   If TDS
levels are decreasing at a well, RES  contends that the  abatement  system
has adequately reduced contamination  in that area.   Thus, by following
RES' philosophy:  if TDS levels are higher, the abatement system  is
working; if TDS levels are lower, the abatement system  is also  working.

As mentioned previously, detection limits for some parameters (lead,
arsenic and TOX) have been higher than the respective drinking  water
standards.  In the  1986 annual survey, lead and arsenic detection limits
were lowered to appropriate levels; however, TOX detection limits of  1 ppm
were still inadequate.  50 ppb total  volatile organics  is a  standard
operating base level signifying contamination.   During  1986 and 1987 more
rigorous evaluations were made of RES ground water  quality problem.  A
Comprehensive Ground Water Monitoring Evaluation (CME)  in 1986  as well as
this Task  Force  have found significant organic contamination at the site.

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                                -73-
Highly mineralized ground water (signified by high IDS)  is  most  prevalent
adjacent to the L-series lagoons.   Ground Water contaminated  with metals
in the North Marsh Area near Well  4A.   Organics are also found  in the Main
Plant Area.  Very little monitoring has been done  in the South Marsh
Area.  This area is of importance  as it is downgradient  from  the leaking
L-series lagoons and may act as a  contaminant pathway to Raccoon Creek.

Sampling for volatile organic compounds by RES in  1986 resulted  in the
detection of several organic compounds in low concentrations  at  Well  DPS
which is screened in the shallow artesian zone.  DPI has a  relatively
high phenolic concentrations (0.10 ppm) and all of the deep wells show
elevated nitrate levels.  The deep wells in the North Marsh Area, which
may be directly connected or a part of the shallow artesian zone in that
area, show contaminant concentrations  similar to those of shallow wells
in the same area.  Because these wells are screened as deep as 70 feet
below land surface, there are implications of significant pathways for
the downward migration of contaminants in North Marsh Area.  Even at  a
depth of 70 feet, sand is encountered.

While the 500 ppm TDS line may delineate the boundary of highly  mineralized
water, it cannot be used to define the extent of organic or heavy metal
contamination - there is no causal  relationship between  high  TDS and  or-
ganics or metals.  These "plumes"  of contamination are centered  in
different areas and because the hydrogeologic regime is  complex  (and
certainly not simplified by the alternating pumping sequence), direction
of flow may be different as well.   Wells MA10, MA11, E and  AV2,  which all
lie outside the 500 ppm TDS contour line, show metal and/or organic
contamination.  It is uncertain whether there is organic or metal  con-
tamination within the South Marsh  Area as this areas has not  been adequately
monitored.

As RES'  monitoring program becomes more complex,  especially  now that organic
contamination must be assessed, the integrity of the existing well  system
becomes more important.  Some of the wells on site, such as the  W-series
in the South Marsh Area, are well  points and were  not meant for  rigorous
ground water monitoring.  During the inspection, caps were  off wells  (MWla)
and other were bent (Well 15).  In  the North Marsh Area, the  inspection
team members were able to lift some of the MA-series wells  (MA10, MA11)
out of the ground manually.  Wells  MA-5I through MA-11I  and D were not
constructed properly.  The annular spacing was filled with  drill  cuttings.
This may develop a vertical pathway whereby contamination in  the shallow
zone may enter deeper zones.  In some  of the deep  MA-series wells, contami-
nation is pronounced.  Poor well construction may  be a contributing factor
to ground water degredation at depth in the North  Marsh  Area. Some of
the wells which were installed at  the  facility during the early  and mid
1970s are not supported by adequate well  logs and  construction details
and, therefore, should not be used  in  a long-term  sampling  assessment or
corrective action program.

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                                    -74-
6. Conclusions  and  Recommendations

   The RES facility has  been  in  operation  for  18 years.   In  the early  1970s
   RES treated, stored,  and/or disposed  of hazardous waste  in  surface  im
   poundments,  basins, landfills, etc. throughout most of the  78 acre  site.
   Many of these units were  unlined  and  probably the source  of organic  and
   inorganic contamination to soils  and  the underlying water table aquifer.
   RES began to scale down their operations in  the  late  1970s  by closing
   and backfilling  many  of the units in  the Central  Plant Area.  In  1986,
   RES completed hazardous waste stabilization  and  final capping of  the
   B-series basins  (Basin  Closure Area)  in the  northern  portion of the
   facility.  Currently, RES  only incinerates  hazardous  waste.  Residue
   from this process is  manifested off-site as  a hazardous  waste.  Pretreated
   scrubber effluent is  sent  to  the  RCRA regulated  L-series  lagoons.   After
   cooling, the water is discharged  to Raccoon  Creak under  the limitations
   imposed by a NJPDES permit.   The  only other  regulated units at the  site
   are basins B-206 and  B-207, both  part of a  biological treatment system
   which only accepts on-site generated  sanitary waste and  ground water
   captured by the  contamination abatement well system.  This  water  is  also
   discharged to Raccoon Creek via the L-series lagoons. Closure plans for
   B-206 and B-207  and the L-series  lagoons have been submitted to NJDEP
   and EPA.  RES intends to  replace  these  units with above-ground tanks.

   The unlined  or clay-based  L-series lagoons  are known  to  be  leaking  highly
   mineralized  water into  the underlying water  table zone.   It is not  certain
   if B206 and  B207 are  leaking  as they  accept  the  same  contaminated ground
   water which  underlies the  units.   Waste stabilization and capping of the
   Basin Closure Area was  recently completed.   These actions were designed
   to minimize  ground water  contamination  in the future. Besides these
   specific areas,  other sources of  ground water contamination must  be
   generalized  to include  much of the Central  Plant Area where waste was
   stored and/or treated.

   RES began to study ground  water contamination in 1972; however a  formal
   monitoring and plume  assessment plan  was not instituted  until November,
   1981, through a  signed  Consent Order  with the State.   Although the  facility
   has installed close to  200 wells  in and around the site  (not all  are
   currently in use or operable) and has a ground water  abatement system  in
   place, RES'  current assessment program  has  not adequately definded  site
   hydrogeology or  the rate  and  extent of contamination  beneath the  site
   pursuant to  265.93(d).  Two generalized cross-sections were developed  in
   1972 as part of  their first report.   The only other cross-sections  were
   drawn in 1982 to show the  existence of a vertical downward  ground water
   flow gradient at the  site.  RES contends that there are  two discrete
   aquifers beneath the  facility:  a water table zone and a  shallow  artesian
   zone.  Review of well logs does not support  this view.   Site geology is
   very complex; RES must  use available  data to adequately  characterize the
   subsurface.   Additionally, more exploratory drilling  should be done.

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                                 -75-
Down hole geophysics should be used at existing wells where possible and
at all future wells for the same purpose.

Well tests of 1981 and 1982 were not adequate to characterize the hydrologic
regime at the site.  Longer term well tests, 48 to 72 hours, need to be
performed in the water table aquifer so that hydraulic effects during and
after delayed yield can be evaluated.  Any well used for pumping or obser-
vation must be evaluated for construction integrity and must be supported
by adequate well logs.  Well tests in the shallow artesian zone is a more
tenuous proposal because of the possible induced downward migration of
contamination associated with the tests.  Pumping the shallow aquifer
as a means of stressing the shallow artesian zone should be considered.
Transmissivity and storativity values of the shallow artesian zone north
of the Basin Closure Area are reasonable; values for the water table zone
are more suspect.  Information from current geologic logs or new drilling
projects must be integrated into the interpretation of well test results.
Static water level gradients from the water table and shallow artesian
zones, aquifer thickness, and the extent and thickness of clay lenses or
layers, are all parameters which have not been adequately evaluated.  RES
should drill more deep wells on the site; the 5 existing ones are not
enough to understand ground water flow and other hydrogeologic character-
istics of the shallow artesian zone.

General parameters such as IDS, TOX, phenols, and metals have been used
by RES to define the extent of ground water contamination since 1972.
These parameters, by themselves, are not adequate as they do not consider
the specific organic contaminants detected at the facility.  Even the
TOX parameter, which is a general parameter for organic contamination,
has not been used properly, as the detection limit has been higher than
the drinking water quality standard.  RES did submit a new sampling
program containing a more rigorous list of parameters to the State in
1986 but this was not agreed upon and was never implemented.  RES must
implement a program which tests for specific constituents detected in
the Task Force sampling inspection and previous sampling efforts and
must define the rate and extent of contamination based on this more
comprehensive list of parameters.  This will entail  the installation of
new monitoring wells.

Specifically, contaminant information is lacking in the South Marsh Area,
the shallow artesian zone in the Central  Plant Area, and the northern
extent of the North Marsh Area where contamination had been found to a
depth of 70 feet.  RES contends that this is a deeper portion of the
water table zone.  RES must show that this is not actually an extension
of the shallow artesian zone.   RES must also define the vertical  extent
of contamination; 70 feet is only the depth of the deepest well  in the
area.   Earth resistivity profiles suggest highly mineralized water may
exist to depths of 100 feet.  Values obtained using a 100 feet electrode

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                                -76-


spacing are very low (40-100 Ohm-feet)  around  the  L-series  lagoons  and
the Central Plant Area.   Resistivity  information should  be  thoroughly
integrated with geologic  interpretations.

Capping and stabilization of waste  in the  Basin  Closure  Area  was  instituted
to permanently reduce leachate  seeping  into  the  ground water.   While an
immediate amelioration of water quality is not expected, improvement in
ground water quality over time  should be observed.   Specific  well locations
should be considered to monitor ground  water flow  beneath the  Basin Closure
Area.  These locations would also be  part  of an  overall  sampling  program.
In order to adequately monitor  the  area, deeper  wells must  be  installed
and the integrity of existing ones  must be checked.   Neutron  probes,
already part of RES' original plan  for  Basin Closure, should  be used to
determine the moisture content  below  the cap.  Care  must be taken in the
interpretation, however,  as the variable chemistry of the waste consti-
tuents may affect the results.   These are  all  tools  to assess  the effec-
tiveness of Basin Closure.  They should be incorporated  in  a  plan which
describes how RES will determine whether Basin Closure procedures are
adequate to mitigate ground water contamination.

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                                   -77-
7.  References

    In addition to Quarterly and Annual  Ground Water Reports, Aquifer and
    Contamination Evaluation Reports by RES'  consultants, Geraghty & Miller,
    and State and Federal  Inspection Reports, the following is a list of
    references  used in this evaluation:

    Bauersfeld, W.R., Moshinsky, E.W., Pustay, E.A., and Schaefer, F.L., 1985, Water
       Resources Data, New Jersey Water  Year  1984 Volume 2, Delaware River Basin
       And Tributaries to  Delaware Bay:   U.S. Geological Survey Water-Data Report
       NJ-84-2.

    Fusillo, T.V., Hochreiter, J.J., and Lord, D.G., 1984, Water-Quality Data for
       the Potomac-Magothy Aquifer System in  Southwestern New Jersey 1923-83:
       U.S.  Geological Survey Open File  Report 84-737.

    Gill, H.E., and Farlekas, G.M., 1976, Geohydrologic Maps of the Potomac-Magothy
       Aquifer  System in the New Jersey Coastal  Plain:   U.S. Geological  Survey
       Hydrologic Investigations Atlas HA-557.

    Hardt, W.F., 1963, Public Water Supplies  in  Gloucester County, New Jersey.:
       U.S.  Geological Survey Water Resources Circular  No.9.

    Johnson, D.W., 1931, Stream Sculpture of  the Atlantic Slope:  New York,
       Hafner Publishing.

    Luzier,  J.E., 1980,  Digital  Simulation and Projection of Head Changes in the
       Potomac-Raritan-Magothy Aquifer System, Coastal  Plain, New Jersey:  U.S.
       Geological  Survey Water-Resources Investigation  Report 80-11.

    New Jersey  Department  of Environmental  Protection,  1983, Environmental  Assessmen
       of the Rollins Environmental  Services  (RES)  NJ Hazardous Waste Management
       Facility, Logan Township, New Jersey:  Trenton.

    Olmstead, F.H., Parker, G.G., Heighton, W.B., Perlmutter, N.M., and  Cushman,
       R.V., 1959, Ground-Water Resources of  the Delaware River Service  Area, vn_
       U.S.  Geological Survey, Delaware  River Basin Report, Volume VII,
       Appendix N, 1960.

     Owens,  J.P., and Sohl , N.F., 1969,  Shelf and Deltaic Paleoenvironments in the
        Cretaceous-Tertiary Formations of the New Jersey Coastal  Plain,  jij^
        Subitsky, Seymour, ed., Geology  of Selected Areas in New Jersey  and
        East Pennsylvannia and Guidebook of Excursions:  Geological  Society of
        America, November, 1969.

    Parker,  G.G., Hely,  A.G., Heighton,  W.B., and Olmstead, F.H., 1964,  Water
        Resources of the Delaware River  Basin:  U.S.  Geological  Survey Professional
        Paper 381.

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                                -78-


Richards, H.G., Olmsted, F.H., and Ruhle, J.L., 1962, Generalized Structural
   Contour Maps of the New Jersey Coastal Plain:  New Jersey Geological
   Survey Geological  Report Series No.4.

Schaefer, F.L., 1983, Distribution of Chloride Concentrations in the Principal
   Aquifers of the New Jersey Coastal Plain 1977-81:  U.S. Geological  Survey
   Water-Resources Investigations Report 83-4061.

Volwinkel, E.F., and Foster, U.K., 1981, Hydrogeologic Conditions in the
   Coastal Plain of New Jersey:  U.S. Geological Survey, Open File
   Report 81-405.

Widmer, K., 1964, The Geology and Geography of New Jersey:  The New  Jersey
   Historical  Series Volume 19:  New Jersey, D. Van Nostrand Company.

Zapezca, O.S., 1984, Hydrogeologic Framework of the New Jersey Coastal  Plain:
   U.S. Geological Survey Open-File  Report 84-730.

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»
                                  -79-


E.  Review of RES'  Ground  Water Sampling  and  Analysis  Plan

   The sampling  and  analysis  plan  titled "Groundwater Sampling  Protocol
   dated January 1987,  was  reviewed  to determine  compliance with  40  CFR  §
   265.92 and the Administrative  Consent Order  administered by  NJDEP.  The
   following inadequacies exist and  should  be corrected  in a  revised
   sampling and  analysis  plan:

   Safety

   The plan should provide  a  provision for  air  monitoring above the  well
   heads in order to determine the potential  for  fire, explosion, and/or
   toxic effects on  the workers.   This segment  should include the type of
   air monitoring device  (i.e., OVA, HNU, detection  tubes, explosimeter,
   etc.), a detailed description  of  the  calibration  procedures, and
   procedures for its use in  the  field.

   Protective gloves should be worn  when performing  ground water  monitoring
   and sampling  activities  (i.e.,  nitrile,  viton, neoprene).

   Field Measurements

   The present Sampling and Analysis Plan uses  a  chart of total measurements
   taken at the  time of well  installation.   The plan  should contain  a
   provision for measuring  total  depth of each  well.   This measurement can
   be used to check  the structural  integrity of the  well  (i.e., whether  or
   not the well  has  silted  in).

    A permanent  and  easily  identified reference mark  from which water level
    and total depth  measurements  are taken  should be  installed  on each well.
    The reference points  should be established  by a  licensed  surveyor.

    Duplicate water  level measurements on every fifth well should be taken
    to check accuracy of  measurements.

    The plan does not contain provisions for the  detection and  sampling  of
    immiscible contaminants (floaters and sinkers) in the groundwater.
    The plan should  specify in detail, the  device as  well as  the  construction
    material and procedures for detecting, measuring, and sampling both
    light and heavy  phases.

    The plan should  provide identification  by ID  # of all field instruments
    in order to  verify  calibration procedures.

    Backup equipment should be available if  equipment malfunctions.  All
    in-situ parameters  should be measured immediately upon sampling.  It
    is not acceptable to  bring the sample back  to an  in-house laboratory
    in order to  perform the analysis.

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                                -80-
Calibration standards should  be dated  (i.e.  pH  buffers,  specific  conductivity
standards).  They all have  specified  shelf lives.

Purge Methods

In the decontamination procedure of the  centrifugal  pump,  the  plan  should
include a procedure for the cleaning  of  the outside  of the intake line
which comes in direct contact with the water being  removed.

There are no provisions in  the plan on the use  and  construction material
of the hand pump used by RES.  Details need to  be  provided.

During purging of the well, in-situ parameters  of  the  purged water  should
be used to measure purging  efficiency and to ensure  that all stagnant
water in the well has been  replaced by fresh formation water.

Purged water from all the wells sampled  must be collected  for  proper
disposal.  The disposal procedures should be specified in  detail.

Recordkeeping

All field and laboratory measurements should be recorded in  a  numbered  and
bound notebook with non-soluble ink.   This includes  measurements  recorded
on 'Water Sampling Logs'.

The Water Sampling Logs should be expanded to include  the  following
information: condition of the well (i.e., rust  present,  bent casing,
label missing, etc.), air monitoring  device readings,  sample character-
istics (i.e., odor, color,  turbidity, presence  of  non-aqueous  liquids,
etc.) and sampling time (begin/end).

Sampling

In wells using dedicated submersibles, sufficient  time must  be allowed
for ground water to stabilize prior to sampling.  Pumps  cause  volatil-
ization and produce pressure differentials which result in variability in
the analysis of pH, specific conductivity, metals  and  volatile organics.

Sampling utilizing an in-line tap on the submersible should  be eliminated
and replaced with sampling  by bottom loading stainless steel or  teflon
bailers.

Filtering for dissolved metals should be specified in  the  plan as being
performed immediately after sampling.

Filtering procedures for dissolved metals should be expanded to  include
cleaning apparatus with 10% HN03 solution and D.I. water prior to
sample filtration.

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                                -81-


Sample containers should  be  labeled  to  identify  if  preservations  have
been added to avoid overfilling.   Preservation of the  sample  should  be
verified with pH paper to see if the  required amount of  preservative
has been added.

The plan lists the order  of preferred, sample collection  for various
parameters.  TOX and TOC  should be moved  up to numbers four and  five,
respectively, since they  typically contain  volatile components.

The plan describes what EPA considers to  be an inadequate  cleaning
procedure for sampling equipment.  The  following should  be done  in  the
order detailed below:

Wash and brush with hot tap water and nonphosphate  detergent; rinse  with
tap water, 10% nitric acid,  tap water,  methanol , hexane, deionized  water
(demonstrated analyte free); air dry; wrap  in aluminum foil,  shiny  side
out.  All solvents, including acids,  must be reagent grade.

For those sampling events where only organic parameters  are being analyzed,
the nitric acid rinse can be skipped.  If only metals  are  being  analyzed
the methanol  and hexane rinses can be skipped.

The plan needs to describe cleaning  procedures for  sample  containers as
well as laboratory glassware.  For samples  analyzed for  metals,  the
following should be done, in the order  detailed  below, for containers
and glassware:

Uash with hot tap water and  nonphosphate  detergent; rinse  with 1.1
nitric acid,  tap water, 1:1  hydrochloric  acid, tap  water,  deionized
water (demonstrated analyte  free).  All acids must  be  reagent grade.

For samples analyzed for  organics the following  should be  done,  in  the
order detailed below, for sample containers as well as laboratory
glassware:

Wash with hot tap water and  nonphosphate  detergent; rinse  with tap
water, methanol, hexane,  deionized water  (demonstrated analyte free).
All solvents  must be reagent grade.   All  glassware  (sample or laboratory)
for volatiles must be muffled at 105°C  for  a minimum of  one hour.

All sample containers and laboratory glassware must be sealed and stored
in a clean environment.  The cleanliness  of each batch of  precleaned
items must be verified by laboratory analysis.   The procedures should be
detailed in the plan.

Any specialized cleaning, eg., TOX containers muffled  at 400°C,  should  be
detailed.

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                                -82-
The use of trip blanks  needs  to  be  detailed.   One trip  blank per day of
sampling, or every twenty samples,  whichever  is more  frequent, should be
used.  A trip blank only needs to be  used  if  samples  are  being taken and
analyzed for volatiles, including TOX and  TOC.  A trip  blank only needs
to be analyzed for those volatiles  being sampled for  at a  site.

A trip blank is defined as a  sample container that  is filled with demon-
strated analyte free water; transported  to the site and handled like a
sample without opening  the container; and  returned  to the  laboratory for
analysis.

Chain of Custody Procedures/  Packaging and Shipping

The plan describes chain of custody procedures for  analysis of samples by
the on-site RES laboratory.  However, it does not provide  any information
about procedures for samples  shipped  to  off-site contractor laboratories.
Such information such as use  of  sample seals  and chain  of custody forms
should be addressed in  detail in the  plan.

Include a copy of the chain of custody seal and form  as an attachment to
the plan.

A section on sample packaging and  shipment (as per  DOT  regulations)  to an
outside laboratory should be  incorporated.

Well Construction

On a number of wells (PVC material  construction)  the  well  caps could only
be removed with considerable  effort,  or not at all, preventing the  taking
of water level measurements and/or  sampling.   It  is recommended  that
holes be punched in the caps  or  gas vents  be  installed  to release air
pressure from built up gas which may become trapped,  providing easy
removal of the cap.

On a number of wells (most notably the MA-11  series)  no concrete  collars
were seen and water was visibly present between  the well  casing  and outer
protective casing.  In some cases,  due to  the difficulty in  removing the
well cap, it was possible to  physically move  the  well by lifting  it.
These observations  lead us to question the structural integrity  of  the
well construction,  in  particular, the annular seal  which prevents  the
migration of contaminants to the sampling  zone from the surface  or  interm-
ediate  zones.  These problems question the monitoring well program's
ability to detect  contamination from discrete zones  (shallow,  intermediate,
and  deep).

Protective bumpers  should  be installed on all on-site wells  where daily
activity could damage  the well  (i.e., Well 13 -  bent casing).

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                                -83-
Permanent labels, protective casings,  and locks should be installed  on
all monitoring wells.

RES should implement a monitoring well  inspection program.   This program
should incorporate a log of information such as: casing condition,  labels
installed, locks installed, etc.

Analytical Methods and Associated Quality Control

As a general  comment, the plan, including the document titled  "Quality
Assurance Program" dated March 10, 1986, fails to provide adequate  details
of the quality control that is specific to ground water monitoring  analyses,
Additionally, important details of certain analytical  methodology are
missing.  Most of the comments below focus on the inadequacies of actual
practice observed by us or explained to us.   Most of the problems could
not be identified by reviewing the plan.  All problems regarding actual
practice and lack of detail need to be corrected.

Both the analytical methodology and associated quality control used  for
total  organic hydrocarbon (TOX) analysis are inadequate.  Additionally,
the details of actual quality control  practice are lacking  and the  analy-
tical  methodology described for TOX analysis does not reflect  actual
practice.

The methodology being used can miss entire groups of halogenated compounds
and result in significantly lower values and higher detection  limits than
the method EPA considers as appropriate for TOX determination, Method
9020 of EPA's SW-846.  Also, the level  of quality control  being practiced
does not provide adequate confidence in the reliability of  the data  for
the compounds that are determined by the methodology being  used.  (See
the Laboratory Audit Section of the report for further details on this
matter.)

For all ground water monitoring parameters,  the plan needs  to  provide
detection limits and their method of determination.  Simply referencing
EPA analytical methods is not sufficient.

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                                -84-
F. Audit of Currently Used Laboratories

As part of the HWGWTF's investigation of RES,  an  audit was  performed  by
EPA Region II on April  15, 1987,  of the RES Laboratory located  in  Bridge-
port, New Jersey.  Part of this  audit focused  on  those problems  identified
in an NODE? audit, pursuant to  the Regulations Governing  Laboratory
Certification and Standards of  Performance, N.J.A.C.  (7:18),  performed
on January 13, 1987.   These regulations currently do  not  directly  govern
analytical work performed under  RCRA.  However, that  audit  did  cover
RCRA parameters in the  matrix of interest that are analyzed under  other
programs.  This audit focused on the RCRA analytical  work not covered in
the NJDEP audit.

Environmental Testing and Certification Corporation (ETC),  located in
Edision, New Jersey has been contracted by RES to perform analyses of
well samples for RCRA's "Appendix IX" parameters.  ETC was  audited in July,
1985, by the National Enforcement Investigation Center (NEIC) and  in  April,
1986, by the Quality Assurance  Office of EPA,  Region  V.  The  findings as
they pertain to this  investigation are presented  below.

It should be noted that the selection of ground water monitoring parameters
being sampled for and analyzed  by RES is based on an  NJDEP  Administrative
Consent Order.  The RES parameters are:  pH, total dissolved  solids
total organic carbon, nitrate,  phenol, arsenic, cadmium,  chromium,
copper, zinc, lead, polychlorinated biphenyls  and total halogenated
hydrocarbons (TOX).

1. RES Laboratory

   Several inadequacies were found involving the  use  of inappropriate
   analytical methodology for analyses of TOX  and the failure to follow
   the quality control  procedures  contained in the subject analytical
   methodology referenced for TOX analysis in  RES' Ground Water  Sampling
   Protocol.  Additionally, the  analytical methodology itself that is
   used by RES differs  from that which is referenced  in RES'  protocol.
   The details regarding these  matters are highlighted below.

   RES' Ground Water Sampling Protocol references EPA Methods 601  and 608,
   40 CFR 136, for TOX analysis.   The appropriate method  for  TOX analysis
   is Method 9020 form EPA's Test Methods for  Evaluating  Solid  Waste  (SW-846).

   Method 9020 is a method involving carbon adsorption with a microcoulometric
   titration detector.   This method determines all organic  halides con-
   taining chlorine, bromine, and iodine that  are adsorbed  by granular
   activated carbon under the conditions of the method.

   Method 601, as prescribed in  40 CFR 136, involves  purge  and  trap gas
   chromatography with a halide-specific detector.  It determines  29  purge-
   able aliphatic halocarbons.   The RES laboratory uses a flame ionization
   detector.  The flame detector can determine a  wider range  of compounds,
   but is less sensitive than a  halide specific detector.  Consequently,
   low levels (ugs/1 range) of  individual halocarbons can be  missed with
   the flame detector.

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                              -85-


Method 608, as precribed in 40 CFR  136,  involves  methylene  chloride
extraction, gas chromatography, and an electron capture detector.   It
determines certain organochlorine pesticides  and  PCBs.   The RES  laboratory

uses methylene chloride extraction, gas  chromatography, and a  Hall detector.
The use of a Hall  rather than electron capture detector can determine  a
wider range of non-purgeable halocarbons.   However,  the Hall  is  less
sensitive than an  electron capture  detector.   Additionally, certain
groups of compounds, such as the chlorophenols, are  missed  using the  608
extraction procedure.

RES quantitates TOX using total peak areas.  Detection  limits  for individual
compounds are based solely on the linear regression  intercept  of the  halo-
carbon standards.   For purgeables the lowest  standard used  is  270 ug/1 and
for nonpurgeables  it is 50 ug/1.  Additionally, a 1  mg/1 detection limit
is used when reporting actual TOX,  which is based solely on the  limit  re-
ported by the laboratory originally doing  TOX for RES.   Concentrations
determined that are less than 1 mg/1 are reported as "less  that  1 mg/1".

It should be noted that until 1984, SR Analytical in Cherry Hill, New  Jersey,
was contracted by RES for TOX analyses and apparently used  the analytical
methodology currently being used by RES.

Regarding quality control procedures, many of those  prescribed in EPA
Methods 601 and 608 are not being used by RES.  Regarding both Methods
601 and 608, the following inadequacies exist:

a. External QC check samples are not being used.

b. Calibration check standards are allowed to be out by as  much  as 20%
   without action  being taken.  The action limit prescribed in Methods
   601 and 608 is  10%.  For Method 601, RES has been out by as much  as
   20%; for Method 608 RES has been out by more than 10%.

c.  No checks are  made on the validity of standards  being used.

d. Laboratory duplicates are not used; a form of field  duplicates
   are used.

e. Surrogates are  not used.

f. Control charts  for precision and accuracy  are formulated based
   on TOX rather than on individual methods and parameters.

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                                   -86-
   g.  Data validation  procedures  are  not  well  established  in
      terms of the appropriate  control  charts  and other  quality
      control  measures for  determining  the  validity of data based
      on specific criteria.

   Regarding Method 608,  the  following  additional inadequacies exist:

   a.  An initial  demonstration  of capability to  perform  the method
      was not performed.

   b.  A holding time of 14  days for  sample  extraction is typically
      being used  rather than  the  7 days required by 40 CFR 136.

   Regarding good laboratory  practices  in general , written standard  operating
   procedures do  not exist  for  any analysis performed as part of  RES'  ground
   water monitoring program.

   Additionally,  systems  audits are  not performed by RES on any of the TOX
   or  PCB analytical  work performed  as  part of the RES ground water  monitoring
   program.

   Regarding problems  identified  by  NJDEP during their January 1987  audit,
   all have been  corrected  with the  following  exceptions:

   a.  A log book  for documenting  sample digestions has been
      established, but does not yet  include information  on pH checks.

   b.  ICAP interference check samples have  been  ordered, but have
      not yet been received.

2. Environmental  Testing   and  Certification Corporation (ETC) Laboratory

   The audit by NEIC in July, 1985,  and again  by the Quality Assurance
   Office of EPA, Region  V  in April,  1986,  revealed several inadequacies.
   Most of the inadequacies do  not apply to the  parameters of interest
   in  this RES investigation.  However, those  few difficiencies pertinent
   to  this investigation  were corrected prior  to the Task  Force study.

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                                    -87-
G. Ground Water Sampling Activities at RES

   On February 9-19, 1987, the Ground Water Task Force sampled for Appendix IX
   constituents at Rollins Environmental  Services (RES), Bridgeport, New
   Jersey, in order to determine if the hazardous waste disposal, storage,
   and treatment activities conducted at this site and regulated by the
   Resource Conservation and Recovery Act (RCRA) have impacted the quality
   of ground water underlying this facility.  The field sampling participants
   were as follows:

   EPA Region II- ESP

     Louis DiGuardia, Geologist
     Joseph Cosentino, Environmental  Scientist

   EPA Sampling Contractor - Alliance, Inc.

     Richard DeLuca
     David Billo
     Mark Lewis
     William Naughton

   Rollins Environmental Services (RES)

     Mark Owens
     Thomas Smith

The following EPA contractor laboratories were utilized by the Task Force:

     Centec Analytical
     2160 Industrial Drive
     Salem, Virginia 24153

 for total  metals, dissolved metals,  cyanide, POC, POX, TOC, TOX, phenols,
 anions, sulfides, carbonates and bicarbonates.

     EMS I
     4765 Calle Quetzal
     Camavilla, CA  93010

 for VOA, BNA, Pesticide/PCB, and Herbicides.

     Compu  Chem Laboratories
     3308 Chapel  Hill/Nelson Highway
     Research Triangle  Park, NC  27709

 for Dioxins.

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                                 -88-
The sampling procedures followed during the inspection were those described
in the Work/QA Sampling Plan for the Ground Water Task Force Inspection
Plan at RES.  Safety equipment, utilized by all  members of the  Task Force,
consisted of surgical  gloves, neoprene gloves,  saranac tyvek,  safety
boots/ shoes, disposable booties, protective coveralls, cartridge re-
spirators and SCBAs.  All  Task Force activities  at RES were conducted  by
the Task Force contractor, Alliance, Inc.  RES  elected to receive splits
of all samples collected by the Task Force.  The order of sample collection
and the preservation methods and parameters for  which the samples were
analyzed are summarized in Tables A-l and A-2.

During the inspection, samples were collected from 21 ground water monitoring
and abatement wells.  Of these wells, 18 were screened in the  water table
zone and 3 were screened in the shallow artesian zone.  Table  A-3 is a
list of well specifications for RES'  ground water monitoring wells supplied
by their consultant, Geraghty & Miller.

Before and after sampling  activities, full  rounds of water level measurements
were taken (from wells which were sampled as well as other wells at the
site) with a water level indicator/sounder to the top of the PVC casing,
using the measuring point  from which RES makes  its routine ground water
measurements (Table A-4).   The water level  indicator was decontaminated
between wells with isoproponal and deionized water and air dried.  Duplicate
water level measurements were taken at a representative number  of wells
to check measurement procedures.  Differences between measurements ranged
from 0.0 to 0.11 ft. and were considered to be  within an acceptable
range (Table A-5).

After the initial  round of water level  measurements was taken,  a water
level measurement  was  taken at each well that was sampled (Table A-6).
Prior to and throughout sampling activities, the air space above and around
the well head was  measured with air monitoring  equipment in order to determine
the need for respiratory protection.  These instruments included an organic
vapor analyzer (OVA),  a photoionization detector (HNU), and a  geiger counter.
Table A-7 presents the results of air monitoring obtained at each well.
An interface probe was used to determine the presence of immiscible layers.

Purging and sampling of Wells AV-2, S, MA-3S, 17, MW-4A, W27,  W24, W29,
MA-IS, and L-2 was performed using dedicated bottom loading teflon bailers.
For Wells 29, 25 and 21A,  purging was performed  using the facility's
dedicated submersible  pumps with sampling performed using bottom loading
teflon bailers.  Wells MA-9S, MW-4A, MA-8D, and  MA-11D were purged and
sampled using dedicated one-inch bottom loading  stainless steel  bailers.
For wells screened in  the  shallow artesian zone  (DP-1, DP-2 and  DP-5), a
portable stainless steel submersible pump (Label  SP-2) supplied  by
Alliance was utilized.  Sampling was performed  using a bottom  loading
teflon bailer.

The portable submersible pump (SP-2) utilized by the Task Force  was constructed
of stainless steel with a  PVC coated electrical  cable and discharge line.

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                                -89-
Decontamination between wells consisted of a tap water non-phosphate
detergent wash and triple deionized water rinse of the internal  system,
with a similar cleaning followed by an acetone and hexane rinse  and air
drying for the outside pump, discharge line, and electrical  cable.  All
decontamination and purge water was collected by RES in 55-gallon drums
for treatment in their unit treatment facility.  The bottom loading teflon
and stainless steel bailers were cleaned and rinsed prior to entering
the field.  This procedure consisted of a thorough hot water and non-
phosphate detergent wash followed by successive rinses with deionized
water, acetone and hexane.  After being air dried, the bailers were
wrapped in aluminum foil (treated side out).  Cleaning procedures were
verified by taking equipment blanks for each batch cleaning of bailers
and the SP-2 submersible pump.

In-situ measurements were taken for pH, specific conductivity, and temperature
and are summarized in Table A-8.  Instrument calibration was performed
before the start of field activities and prior to the taking of  field
measurements.  Samples were preserved upon completion of sampling at
each location.  The samples for dissolved metals were returned to a RES
in-house laboratory for filtering by EPA personnel.  The following
procedure was employed: the sample was pre-filtered with a 5.0 urn glass
fiber filter followed by filtering with a .45 urn filter and then preserved
with HNCh.  Cleaning of the apparatus consisted of a deionized water
rinse followed by nitric acid rinse and final deionized water rinse.

Upon completion of daily sampling activities, the samples were packaged
in accordance with applicable Department of Transportation (DOT) regula-
tions for shipment to the appropriate EPA contractor laboratories.  RES
was issued a receipt for all  samples collected by the Task Force and
returned it with a signature from an authorized representative.

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                                     -90-
H. Task Force Sampling Data Analysis

   The data for ground water samples  taken  at  RES  Ground  Water  Task  Force
   between the period February 9-19,  1987,  are presented  in  Appendix  A,  Table
   A-9 through A-14.   Twenty-one  field  samples plus  nine  volatile  sample
   blanks (001, and 100 through 107)  were collected  at  the  facility.   The
   samples included seven field blanks  (101,  100,  102,  103,  105,  106, and
   107), three equipment blanks (104, MQA-738, and MQB-001),  a  trip  blank
   (MQB-002), two  pairs of duplicate  samples  (Well MW-4A, samples  MQA-736/
   MQB-736 and MQA-743/MQB-743 and  Well  29, samples  MQA-739  and MQB-011),
   and twenty-one  other field samples.   Field  measurements  for  pH, specific
   conductivity, temperature and  turbidity  are presented  in  Table  A-8.

   All data for inorganic and indicator  parameters as well  as metals  (total
   and dissolved)  are tabulated in  Tables A-9, A-10  and A-ll, respectively.
   For organics, only those compounds which were detected in  at least one
   of the wells are listed.  Data for organic  analyses  are  presented  in
   Table A-12 for  volatiles and Table A-13  for semi-volatiles.  The  results
   of field and equipment blanks  can  be  found  in the raw  data packages from
   the respective  laboratories.   Data qualifiers for Tables  A-9 through
   A-14 are presented in a key in front  of  Table A-9.   An evaluation  of
   data quality control  is attached in  Appendix B.

1. Inorganic and Indicator Parameters

   All carbonate,  bicarbonate, nitrate,  and nitrite  sample  results were
   rejected since  the laboratory  exceeded sample holding  times.   Because of
   total  organic halogen (TOX) contamination found in an  equipment and field
   blank, only TOX results ten times  the level  of contamination or greater
   were considered acceptable for data  presentation.  Sulfide values  were
   rejected due to blank contamination.

   In general, the highest levels of  indicator parameters were  found  in
   samples from Wells MA-IS, 29,  MA-2D,  W-24,  and 17.   The  highest concen-
   tration of TOX  were found in MA-IS (21,300  ug/1), 29 (5,380  ug/1), MA-2D
   (4,100 ug/1) and 17 (574 ug/1).  Purgeable  organic halogens  (POX)  concen-
   trations generally correlated  with TOX values with the exception of
   MA-2D, where POX was  found to  be 11,000  ug/1 and  TOX to  be 4,100 ug/1.
   Purgeable organic  carbon (POC) and total organic  carbon  (TOC) values
   ranged from 42  ug/1  to 28,000  ug/1, and  1,700 ug/1 to  267,000 ug/1
   respectively.  Total  phenol  concentrations  were present  in the  highest
   concentrations  in  Wells MA-IS  (5,000  ug/1), 29 (888  ug/1), and  MA-2D
   (888 ug/1).

   Among the inorganic constituents analyzed,  bromide was found to be
   present in the  highest concentration  in  21A (30 mg/1).   Chloride and
   sulfate were present  at the highest concentrations in  Well 25 with
   values of 2,250 mg/1  and 2,700 mg/1,  respectively.   Fluoride was found

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                              -91-
in the highest concentration in Well  MA-IS at a  value of 16 mg/1.   Table
3 summarizes the range of concentrations of inorganic and indicator
parameters which were found in ground water samples collected by the Task
Force at RES.   Result of inorganic and indicator parameter analyses from
samples obtained from individual  wells are presented in Appendix A,
Table A-9.
        Table 3 - Inorganic and Indicator Parameter Analyses
Parameter

Bromide
Chloride
Fl uoride
Sulfate
Number of Wells
Constituent Present
6
23
10
22
Range of Concentrations
Present (mg/1 )
2.3 - 30
21 - 2250
1 - 16
12 - 2700
Parameter
POC
TOC
Phenols, totals
POX
TOX
Number of Wells
Constituent Present
23
21
3
12
4
Range of Concentrations
Present (ug/1)
42 - 28000
1700 - 267000
888 - 5000
6 - 11000
574 - 21300

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                                  -92-
2. Metals Analyses Results

   Reported detection limits  are  contract required  detection  limits  (CRDL)
   or lower for all  metals.   Dissolved  arsenic  data for  samples  MQA-739 and
   MQA-741, total  cadmium samples for MQB-008,  MQB-010,  MQB-025, and  total
   antimony for MQA-774 were  rejected due to  correlation coefficents  for the
   method of standard addition  (MSA)  being below data  quality objectives.
   Dissolved and total  mercury  data  for samples MQB-012, MQB-013, MQB-014
   and MQB-015 were  rejected  due  to  failure in  obtaining maxtrix spike
   recoveries because of unknown  salt interferences.   Dissolved  selenium
   data for samples  MQB-006 and MQB012  were rejected due to duplicate injec-
   tion precision  being above DQO.   Total  cyanide data  for samples MQB-001
   and MQB-010 were  rejected  due  to  high sulfide interference in the  matrix
   spike recovery.  Table 4 summarizes  the range of concentrations of
   Appendix IX metals (total  and  dissolved) which were  found  in  the  ground
   water samples collected by the Task  Force  at RES.   The results of  metal
   analyses from samples obtained from  individual wells  are presented in
   Appendix A, Tables A-10 and  A-ll.

               Table 4 - Appendix IX  Metals (Total  and  Dissolved)
Metal
Constituent
Aluminum
Arsenic
Barium
Beryl! ium
Cadmium
Cal ci urn
Chromi urn
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodi urn
Vanadium
Zinc
Cyanide
TOTAL
Number of Wei 1 s
Constituent
Present
22
13
23
8
6
23
15
10
20
23
22
23
23
7
10
23
23
15
23
3
Range of
Concentrations
(ug/1)
190 - 360000
7.8 - 472
32 - 1040
2-25
.6 - 7.5
6390 - 451000
18 - 7880
20 - 122
12 - 4890
386 - 438000
4.1 - 192
2100 - 256000
69 - 2140
.3 - 3.7
26 - 184
2320 - 48300
3070 - 1710000
17 - 1100
19 - 1350
40 - 80





















DISSOLVED
Number of Wells
Constituent
Present
16
5
23
1
4
23
ND
3
6
21
6
23
23
ND
1
23
23
4
21
NA
Range of
Concentrations
(ug/1)
44 - 820
7.5 - 264
31 - 121
3
1.0 - 6.9
7600 - 515000
ND
21 - 35
8-74
27 - 151000
2.4 - 40
2380 - 299000
35 - 2440
ND
150
2600 - 54400
3020 - 1570000
14 - 311
16 - 162
NA
 ND -  Not Detected
 NA -  Not Analyzed

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                               -93-


a. The following metals results were  noted  in  the  water  table  zone:

   Total  Metals

   The highest concentrations for aluminum, barium,  beryllium,  cadmium,
   chromium, cobalt, copper, iron, lead,  manganese,  nickel,  potassium,
   sodium, vanadium and zinc were found  in  Wells  MW-4A and  17.

   Arsenic, calcium and magnesium were  present in  the  highest  concentrations
   in Well 25.

   Cyanide was present in the highest concentrations in  Wells  MW-4A  and  25.

   Dissolved Metals

   Arsenic, calcium, magnesium, nickel,  potassium  and  vanadium were  present
   in the highest concentrations in  MA-2D and  25.

   Barium, iron, and manganese were  present in the highest  concentrations
   in MA-IS.

   Beryllium was present in the highest  concentration  in MA-11D.

   Cadmium was present in the highest concentration  in W-29.

   Cobalt and zinc were present in the  highest concentrations  in  MA-8D.

   Lead was present in the highest concentration  in  MA-2S.

b. The following metals were noted in the shallow  artesian  zone:

   Total  Metals

   Aluminum, calcium, cobalt, copper, magnesium,  potassium,  and zinc were
   present in the highest concentrations  in DP-5.

   Iron, lead, manganese, and sodium were present  in the highest
   concentrations in DP-1.

   Barium and cadmium were present in the highest  concentrations  in  DP-2.

   Dissolved Metals

   Aluminum, calcium, cobalt, copper, lead, magnesium, potassium, and zinc
   were present in the highest concentrations  in  DP-5.

   Iron, manganese, and sodium were  present in the highest  concentrations
   in DP-1.

   Barium and cadmium were present in the highest  concentrations  in  DP-2.

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                                  -94-
3. Organic Analyses  Results

   All  pesticide and herbicide analyses  did  not pass  QA/QC review and were
   rejected.   The analytical  laboratories  exceeded  the  volatile  holding
   times of seven days  for all  volatile  samples; therefore, all  results
   from volatile samples  will  be  considered  qualitative.   Acetone contamination
   was  found  in  sampling  blanks 001,  100,  101,  102,  103,  104,  105, 106, 107,
   MQA-738, MQB-001  and 002.   All  acetone  results were  rejected.   Methylene
   chloride contamination was found  in sampling blanks  103, 104,  MQA-738,
   MQB-001 and 002.   All  methylene chloride  results were  rejected.  Laboratory
   method blanks MB-2 and MB-4 contained bis(2  -ethyl hexyl) phthalate contam-
   ination at concentrations  of 3 and 4  ug/1.   All  positive bis(2-ethylhexyl)
   phthalate  data were  rejected.   Table  5  summarizes  the  occurrence  and range
   of Appendix IX organic constituents found in the ground water  samples
   collected  by  the  Task  Force  at RES.   Results of  organic analyses  from
   samples obtained  individual  wells  are presented  in Appendix  A, Tables  A-12
   and  A-13.

                Table 5  - Volatile  Constituents
Parameter
(ug/1)
Benzene
2-Butanone
Carbon DiSulfide
Carbon Tetrachloride
Chlorobenzene
Chi oroform
1,1 - Dichloroethane
1,2 - Dichloroethane
1,2 - Dichloropropane
Ethyl benzene
2- Hexanone
Tetrachloroethene
Trichloroethene
1,1,1 - Trichloroethane
Trans - 1,2 - Dichloroethene
Toluene
Total Xylene
Vinyl Chloride
1,2 Dibromoethane
Number
of Wells
Consti tuent
Present
8
2
1
1
6
6
7
6
1
6
1
5
5
5
7
8
4
7
1
Range of
Concentrations
Present
7 - 3100
41 - 1300
990
7
7 - 360
2 - 700
2 - 510
20 - 300
6
1 - 720
1100
2-41
94 - 230
1 - 860
3 - 1600
2 - 10000
9 - 2800
1 - 1000
11

-------
                     -95-
Table 5 (cont.) - Semi-volatile Constituents
Parameter
ug/1
Acenaphthene
Benzoic Acid
Bis(2-chloroethyl ) Ether
2 - Chlorophenol
4 - Chloroanil ine
1,2 - Dichlorobenzene
1,3 - Dichlorobenzene
1,4 - Dichlorobenzene
2,4 - Dichlorophenol
2,4 - Dimethyl phenol
2 - Methyl phenol
4 - Methyl phenol
2 - Methyl naphthalene
Naphthalene
Phenol
Phosphorictriamide, Hexamethyl
1,2,4 - Trichlorobenzene
Acetophenone
Anil ine
2 - Hexanone
4 - Methyl - 2 - Pentanone
Pyridine
0 - Toluidine
Number of Wells
Constituent
Present
1
1
5
1
3
4
3
3
3
2
1
3
2
3
3
1
1
1
2
1
1
1
2
Range of
Concentrations
Present
1
340
1 - 200
10
2000 - 27000
2 - 93
4 - 5
8-31
47 - 170
180 - 970
11
34 - 2100
47 - 100
110 - 1000
1 - 380
13
6
410
150 - 1700
77
330
200
960 - 2700

-------
                                    -96-
   a.  The following organic results are noted in the water table zone:

      In general , the highest concentrations of hazardous organic constituents
      were found  in the samples from monitoring wells MA-IS, 29, MA-2D, 17
      and 24.  Well MA-IS contained the highest levels of the following
      compounds:
0 benzene
0 2-butanone
0 chlorobenzene
0 chloroform
o
  1,1 - dichloroethane
0 1,2 - dichloroethane
0 ethyl benzene
0 2- hexanane
0 1,1,1 - trichloroethane
0 trans - 1,2 Dichloroethene
0 toluene
0 total xylene
3100  ug/1
1300  ug/g
360   ug/
      ug/1
      ug/1
700
512
300
720
      ug/1
      ug/1
1100  ug/1
860   ug/1
1600  ug/1
1000  ug/1
2800  ug/1
vinyl  chloride
4-chloroaniline
1,2 dichlorobenzene
1,4 dichlorobenzene
2,4 dimethyl phenol
4-methylphenol
2-methylnapthalene
naphthalene
aniline
4 methyl-2-pentanone
pyridine
0-toluidine
1000  ug/1
27000 ug/1
93    ug/1
31    ug/1
970   ug/1
2100  ug/1
100   ug/1
1000  ug/1
1700  ug/1
330   ug/1
200   ug/1
2700  ug/1
      Well 29 contained the highest levels of:
      0  trichloroethene (230 ug/1),
      0  benzoic acid (340 ug/1),
      0  bis (2-chloroethyl) ether (200
      0  2 chlorophenol  (10 ug/1),
      0  2,4 dichlorophenol (170 ug/1),
      0  phosphorictriamide, hexamethyl
         concentrations of:

  chlorobenzene               69  ug/1
  chloroform                  440 ug/1
  1,1 - dichloroethane        45  ug/1
  1,2 dichloroethane          120 ug/1
  tetrachloroethane           27  ug/1
  1,1,1 - trichloroethane     330 ug/1
  trans - 1,2 dichloroethen   51  ug/1
  toluene                     570 ug/1
  total xylene                190 ug/1
  vinyl chloride              35  ug/1
          ug/1)
          (13 ug/1), and the second highest
                4-chloroaniline
                1,2 dichlorobenzene
                1,3 dichlorobenzene
                2,4 dimethyl phenol
                4-methylphenol
                2-methylnaphtha! ene
                naphthalene
                phenol
                aniline
                0-toluidine
      Well MA-2D contained the highest levels of:
         carbon disulfide
         2- methyl phenol
         phenol
     990 ug/1
     11  ug/1
     380 ug/1
2000
38
4
180
160
47
140
370
150
960
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1

-------
                                   -97-


   Well  24 presented the highest level  of carbon tetrachloride (7 ug/1).

   Well  17 contained the highest concentration of:

     0  tetrachloroethene         41  ug/1  and
        1,2,4 - trichlorobenzene  6   ug/1
   1,2 Dibromoethane was present in the highest concentration in well  MA-8D,
   2-hexanone in MW-4A (77 ug/1) and 1,3 dichlorobenzene in MW-27 (5 ug/1).

b. The following organic results are noted in the shallow artesian zone:

     Hazardous organic constituents were detected only in samples from
     Well  DP-5, located at the southeastern corner of RES.   The sample
     from DP-5 indicated concentrations of:

     0  benzene                   7   ug/1
     0  carbon tetrachloride      1   ug/1
     0  chloroform                5   ug/1
     0  1,1 - dichloroethane      10  ug/1
     0  1,2-dichloroethane        180 ug/1
     0  tetrachloroethene         2   ug/1
     0  trichloroethene           20  ug/1
     0  trans-l,2-dichloroethene  4   ug/1
     0  vinyl  chloride            8   ug/1
     0  bis(2-chloroethyl)ether   1   ug/1

-------
                                 -98-
4. Dioxin/Furans Analyses Results

   Table 6 summarizes the results of the dioxin/furans analyses  on ground
   water samples obtained by the Task Force at RES.   The only detected
   concentrations were found in the water table zone from Well  MW-4A
   (sample # MQA-736).  Duplicate analysis MW-4A DUP (sample # MQA-743),
   showed similar concentrations.
                    Table 6 -  Dioxin/Furan Results
Parameter
(parts per trillion)
TCDD
PeCDD
HxCDD
HpCDD
OCDD
TCDF
PeCDF
HxCDF
HpCDF
OCDF
MW-4A
MQA-736
U
U
U
U
U
1.54
U
3.86
20.1
17.3
MW-4A(DUP)
MQA-743
U
U
U
U
6.26
1.87
3.34
11.9
26.5
19.5

-------
                                  -99-


I.  Compliance  Evaluation  Inspection


    1.  Facility Description  and  Operations

       RES is  a commercial treatment  storage and disposal  facility  situated
       on a 78 acre  tract in Bridgeport,  Logan  Township,  N.J..   This  facility
       accepts a wide  range  of hazardous  waste  for  treatment:   pesticides,
       halogenated aliphatic hydrocarbons, monocyclic  aromatics,  phthalate
       esters, polycyclic aromatics,  ketones, alcohols  and miscellaneous
       volatiles.  Explosive wastes  (DOT  Clases A,  B,  and C),  radioactive
       wastes, and  PCB wastes are  not accepted  at the  facility.   Incineration
       is the  only commercial operation at RES.

       Currently, RES  operates the incinerator  under  interim  status regulations,
       Wastes  are incinerated in gaseous, liquid and  solid form.   Incinerator
       ash, formerly landfilled  on-site is now  transported to  secure  landfills
       elsewhere.  Scrubber  water, from the venturi scrubber  system is  pre-
       treated in an on-site treatment system.  This  system consists  of
       Neutralization  Tanks, clarifier and centrifuge.   The solids  generated
       are transported to a  secure landfill off-site.   The resulting  super-
       natant  is discharged  to a series of unlined  surface impoundments.
       These eight  L-series  surface  impoundments serve  as a cooling system
       before  discharge to the Raccoon Creek.   Two  lined  biological treatment
       surface impoundments  (B-206 and B-207) receive  contaminated  ground
       water from eighteen pumping wells  on-site.   Basin  B-206 is used  for
       equalization  and preaeration  while B-207 is  used for activated sludge
       treatment.  The treated water effluent is pumped to the L-series
       surface impoundment for ultimate discharge to  Raccoon  Creek.   All ten
       surface impoundments  are  RCRA regulated  units  From these impoundments,
       water is discharged to Raccoon Creek under the  terms of RES' NJPDES
       Permit.

    2.  Hazardous Waste Storage

       Drum Pad #1:  This pad is located  approximately fifty  feet north of
       tank farm #1.  The pad consists of a roof-covered  concrete surface
       surrounded by a concrete  containment sump.   Steel  drums as well  as
       fiber drums,  both  stacked two  high, are  stored  in  this  area.   The
       maximum allowable  quantity to  be stored  is 450,  55-gallon  drums. This
       pad area is approximately 4200 square feet.  The physical  inspection
       revealed a small number of drums inadequately marked.   In  the  center
       rear portion  of this  drum pad  were located several  drums between
       which was inadequate  aisle space.  Drum  Pad  #  2:  This  pad is  located

       Drum Pad # 2:  This pad is  located adjacent  to  the guard shack near
       the main gate entrance.   This  pad  consists of  a  concrete slab  with
       concrete curbing as containment.   Only steel drums are  stored  in this
       uncovered area.  Drums are  stored  on pallets,  stacked  one  high.  This
       pad area measures  approximately 7200 square  feet.   The  physical
       inspection revealed a small number of drums  inadeqautely marked. The
       concrete slab had  numerous  small cracks  throughout.

-------
                                -100-
   The drum pad  inventory for  both  Pad  #  1  and  Pad  #  2 can  be  found  in
   Appendix C.

   Phase # 1 Tank Farm:   This  consists  of four  steel  storage tanks.   This
   phase was construted  in 1978,  following  the  destruction  of  the  former
   tank area by  fire  and explosion  in  1977.   Tank descriptions are as
   follows:
   Tank # T-301
   Tank # T-302
   Tank # T-303
   Tank # T-304
7,000 gal.
7,000 gal.
20,000 gal
20,000 gal,
capacity - receiving
capacity - receiving
 capacity - blend
 capacity - blend
   All  four tanks  are equipped  with  mechanical  agitators  and  pressure  relief
   rupture disks.   Containment  provided  for  each  tank  consists  of  a  cement
   pad  and cement  dike approximately four  feet  in height.

   Phase # 2 Tank  Farm:   This consists of  three steel  storage tanks  and  is
   located south of Phase #  1 tank  farm.   Tank  descriptions are as follows:

   Tank # T-308 -  30,000 gallon capacity - storage
   Tank # T-310 -  20,000 gallon capacity - thermalox  storage
   Tank # T-311 -  30,000 gallon capacity - storage

   Tank # T-310 contains RES designated  "Thermalox" aqueous waste  containing
   approximately 90% water.  Phase  # 2 tanks are  also  equipped  with  mechanical
   agitators and pressure relief rupture disks.  Containment  provided  for
   these tanks  consists  of a cement  pad  and  cement diking.  At  this  time a
   VC.O exists  in  Phase  # 2  tank farm where  former Tank #  T-312 was  located.
   This tank was removed from site  in 1986.

3.  Other Storage Tanks

   Tank # T-103:  This provides 20,000 gallon capacity for the  storage of
   RES  designated  "Thermalox" material.  This tank is  located outside  of
   the  two tank farm areas.  There  is no pipe connecting  this tank and the
   tank farm areas.  Containment for this  tank  consists of a  cement  pad
   with a cement curbing.

   Tank # T-323:  This is a  large,  150,000 gallon capacity steel  storage
   tank for bulk storage of  hazardous waste.  It  is located on  the Eastern
   part of the  site away from the main facility.   There is no piping connecting
   this tank to either tank  farm or  the  incinerator.   Containment  consists
   of a pad and a  berm constructed  of clay like material.

   All  hazardous waste tanks are blanketed with nitrogen  in order  to reduce
   fire hazard.

-------
                              -101-
4. Incinerator

   The incinerator in use at RES consists  of a  rotary kiln  and operates
   under negative pressure in order to  reduce fugitive emissions.   Incine-
   rator controls incorporate a series  of  automatic  fuel  cut-off systems
   which shut down operations if any of the following conditions occur:

         - Hot duct temperature falls below 2,000° F
         - Loss of flame as measured by fire eye flame sensors
         - Induction draft fans Axial vibration above 7 mils
         - afterburner draft below 6 inches of  water
         - quenched gas temperature above  15 inches  of water
         - water flow to the saturator  spray nozzels below  400 g.p.m.
         - water flow to the saturator  shelf below 100 g.p.m.
         - water flow to the absorber below 2000 g.p.m.
         - power failure
         - CO concentration in the stack above  80 ppm
         - oxygen concentration in the  hot duct below 3%
         - scrubber differential pressure  below 40 inches of water

   Additional control room monitoring instrumentation includes:

         - scrubber effluent PH
         - rotary kiln crossover duct temp
         - induction draft and forced fan  amperage
         - target wall temperature
         - loodby refractory temperature
         - instrument air pressure

   The physical inspection of the incinerator was conducted on February 13,
   at approximately 1340 hours.

   Two waste streams are generated from the incinerator operation.  Kiln
   ash: This is a solid removed via a metal cart. The area  where the cart
   is staged is a concrete pad with concrete walls.   This pad  slopes
   downward towards the incinerator to  facilitate movement  of the cart
   between the rotary kiln and the 30 cubic yard roll-off used for the
   storage of the kiln ash.  Cracks were noted  in this pad.  The roll-off
   is located within a containment area approximately fifty feet north of
   the incinerator.  The containment consists of a concrete pad (with  sump)
   and concrete curbing.  A sheet metal roof structure provides protection
   from rain water entering the containers.  This area is sized to contain
   two roll-offs.  At the time of the inspection, rain water was noticed  in
   this containment area.

   Scrubber Sludge:  This is the solid  generated from the scrubber water
   treatment system.  Material is deposited in  a 30  cubic yard dump trailer
   after the final treatment process (centrifugation).  This containment  area
   consists of a concrete pad concrete  curbing  and a sheet  metal roof.  Area
   provides storage for one trailer.

-------
                                 -102-
   RES has  ten  surface  impoundments  (B-206, B-207 and 8 L-series lagoons)
   which are  regulated  under  RCRA and  subject  to ground water monitoring
   requirements.

   B-206:   This is  a  concrete  lined  basin  for  equilization and preaeration
   of contaminated  ground water.  The  holding  capacity of this basin is
   approximately 475,000 gallons.

   B-207:   This is  an asphalt  lined  basin  for  the activated sludge treatment
   of contaminated  water received from B-206.   The  holding capacity of
   this basin is aproximately  240,000  gallons.

   L-series lagoons:  These are a series of eight (8) unlined surface
   impoundments located along  southwest border of the facility.  These
   units receive scrubber water from the on-site scrubber wastewater treatment
   plant.   All  lagoons  are  interconnected  to allow  the water to  pass from
   one to  another for cooling.  Prior  to the installation of the scrubber
   water treatment  system these lagoons were utilized for the settling of
   particulate  matter.  Now they serve only for cooling and storage; however,
   this water is still  hazardous by  definition.  The clarified overflow
   from the ground  water treatment system  is discharged to L-311.  Current
   regulations  will  require that these lagoons cease operation by November
   8, 1988.  The facility is  replacing all the lagoons with above-ground
   tanks.

5. Waste Analysis Plan

   The Waste  Analysis Plan  in  use at RES at the time of the inspection
   pertains to  only incoming  waste streams (plan was amended on  2/19/83 to
   include outgoing waste streams).

   Prior to accepting any hazardous  waste  for  transportation, storage, or
   treatment, RES requires  a  completed waste data sheet from the generator.
   This data  sheet  includes the following  information:  heating  valve,
   halogen content, pH, metals content, organic constituents, PCB's ash
   content, flash point sulphur, and viscosity.

   The initial  waste evaluation is repeated at least every two years or if
   the process  or operation generating the waste has changed or  if the
   incoming waste shipment  does not  match  the  waste description  or manifest.
   If the generator is  unable  to provide the necessary data, RES will
   analyze a  representative sample of  the  waste to  obtain the information.

   Based on the information contained  in this  waste data  sheet,  RES' Safety
   and Technical departments  prepare a waste safety sheet.  This is done
   for every  waste  stream prior to acceptance. This is an internal document
   which lists  the  chemicals  in the  wastestream along with information
   pertinent  to its handling.   Other information on this  waste data sheet
   includes storage, treatment or  incineration

-------
                                 -103-
   methods  required,  associated  hazards,  limits  of  compatabil ity,  personnel
   protective  equipment  required,  fire  protection details,  reactivity  and
   spill  response  procedures.   These  waste  safety sheets  are  available at
   all  locations where the  waste  stream is  handled.   Each waste  stream is
   assigned a  RES  designated  code.

   Upon arrival  of the waste  material at  the  facility and prior  to  unloading,
   the  waste is  sampled  and analyzed.   If the  waste is  within  the  contracted
   test parameters the chemist  will establish  a  course  of action for the
   disposal  as per the waste  safety sheet.   Prior to  discharging liquid
   waste, samples  undergoe  additional compatability testing to insure  that
   a reaction  will  not occur.

   Additionally, all  blends are  checked for heating value (BID), halogens,
   sulphur, metals, ash, pH,  viscosity, and flashpoint.   At the  time of in-
   spection, the waste analysis  plan  was  not  checked  for  compliance 40 CFR
   Part 268.

6. Closure  Plan
   The closure plan  in  place at RES  at  the  time  of the  inspection  was  not
   adequate.   The  plan  included procedures  for the decontamination and removal
   of a trickling  filter system and  two neutralization  tanks.   These  units
   are no longer on-site.   The  closure  plan should be amended  to reflect
   the present day situation.   As  noted previously in this  report, cracks
   were noticed in Drum Pad #  2's  concrete  pad and the  concrete  pad under
   the kiln ash cart area.   A soil sampling plan which  includes  these  areas
   should be  part  of the closure plan.   The general  decontamination procedures
   specified  in the  closure plan should include  adequate  information  to
   insure complete decontamination.

-------
                     -105-
                  APPENDIX A

Tables of Schedule of Task Force Sampling Activities,
Physical  Characteristics of Ground Water Monitoring
Wells, and Task Force Sampling Data

-------
                               -106-


                             Table A-l


Outline of Ground Water Monitoring Activities Conducted by Task Force


    Date                Well                    Activity

    2/9                 Water level  measurements taken.  Equipment
                       preparation.

    2/10                Well  AV-2          purged/sampled/trip Blank
                        Well  S             purged/sampled
                        Well  MA-3S         purged/sampled
                        Well  29            purged/sampled/field blank

    2/11                Well  MA-9S         purged/sampled/field blank
                        Well  17            purged/sampled
                        Well  MW-4A         purged/sampled/duplicate

    2/12                Well  MA-2D         purged/sampled/matrix spike
                        Well  MA-2S         purged/sampled/field blank
                           25              purged/sampled

    2/13                   21A             purged/sampled
                          W27              purged/sampled/Field Blank

    2/16                  DP-2             purged/sampled/matrix spike/field  blank
                          MA-8D            purged/sampled/equipment  blank

    2/17                  W24              purged/sampled/equipment  blank
                          DP-5             purged/sampled/field blank

    2/18                  W29              purged/sampled/field blank
                          MA-11D            purged/sampled
                          MA-IS            purged/sampled

    2/19                  DP-1             purged/sampled/field blank
                          L-2              purged/sampled

                          Water level measurements  taken.

    2/20            Closeout  meeting with  Rollins  Environmental  Services

-------
                                 -107-
                               Table A-2
    Summary of Analytical  Parameters Sampled by The Task Force at RES
     Analysis

Volatile Organics (VOA) Purge and Trap
Purgeable Organic Carbon (POC)
Purgeable Organic Halogens (POX)
Total  Organic Carbon (TOC)
Total  Organic Halogens(TOX)
Extractable Organics
a)  Acid, Base, Neutral
b)  Pesticides/PCB
cj  Herbicides
Dioxin/Furans
Total  Metals
Dissolved Metals
Phenols
Cyanide
Anions
Sulfide
Bottle
Preservation
    Code
40 ml VOA Vials
40 ml VOA Vials
40 ml VOA Vials
40 oz Wide Mouth Glass
1 1 iter Amber Glass
1 liter Amber Glass
1 liter Amber Glass
1 liter Plastic
1 1 iter Plastic
1 liter Amber Glass
1 liter Plastic
40 oz. Wide Mouth Glas
1 liter Plastic
1
1
1
1
1
1
1
3
3
2
4
6
5
Bottles

    2
    1
    1
    1
    1
    6
                               2
                               1
                               1
                               1
                               1
                               1
                               1
Preservation Methods

1) Ice
2) H2S04 <2
3) HN03  <2
4) NaOH  >10
5) Zinc acetate followed by NaOH>10
6) Unpreserved except for samples containing sulfides,* if so add lead acetate
   until all lead sulfide has precipitated, filter out precipitate and preserve
   sample with acetic acid.
*  Test for sulfides with lead acetate paper wetted with acetic acid.

-------
                                   -108-
Table~A-3  Well Construction Details for Wells at Rollins Environmental Services
          (NO), Inc.. Logan Township, New Jersey.  (From Geraghty & Miller)
Screened Interval
Well
No.
Permit
Number
(feet below
land surface)
(feet
relative to
mean sea level)
Height of
Measuring
Point
(feet
above
land
surface)
Elevation
of Measur-
ing Point
(feet rel-
ative to
mean sea
level)
Casing
Diameter
(inches)
Water-Table Aquifer
4a
13
14
15
16**
17
20A
20B
21a
22
23b
24
25
26
27
28
29
30S
300
31S
310
32S
320
*
F30-8
F30-9
F30-10
F30-11
F30-12
F30-14
F30-15
30-2834
30-1305
*
30-1301
30-1303
F30-21
F 30-22
F30-23
F30-24
30-7631
30-2632
30-2633
30-2634
30-2635
30-2636
18.5
8
7
12
8
11
3
15
10
9.7

9.7
9.7
15
15
15
15
10
40
10
40
10
40
to 14
to 26
to 22
to 26
to 23
to 25
to 13
to 25
to 25
to 19.7
»
to 19.7
to 19.7
to 25
to 25
to 25
to 25
to 40
to 70
to 40
to 70
to 40
to 70

1
2
- 3
- 2
- 4

-11
- 4.1
- 4.1

- 5.4
- 5.8
- 8
- 8
- 7
-10
- 7
-37.9
- 4.4
-34.4
- 6.5
-36.4
.
to -17
to -13
to -17
to -17
to -18
_
to -21
to -19.1
to -14.1
»
to -15.4
to -15.8
to -18
to -18
to -17
to -20
to -37.7
to -67.9
to -34.4
to -64.4
to -36.5
to -66.4

3.26
1.26
2.48
2.79
2.85
0.0
0.0
1
0.0
*
0.0
0.0
0.0
0.0
0.0
0.0
1.97
1.94
0.97
1.88
1.33
1.28
*
12.65
10.09
11.57
9.29
9.84
—
4.17
6.93
5.63
*
4.30
3.44
7.48
6.78
7.77
5.43
4.23
3.95
6.53
7.52
4.83
4.91
2
4
4
4
4
4
4
4
6
4
*
4
4
4
4
4
4
6
6
6
6
6.
6
    Data to be obtained
    Bent at an angle

-------
                                      -109-
Table_A»2  (Continued)
Well
No.
33S
33D
34S
340
35S
20b-1
21-1
22-1
23-1
24-1
25-1
322
322-1
B
C
E
L
R
S
T
U
W
Y*»
H2
H3a
H4a
Permit
Number
30-2637
30-2638
30-2842
30-2841
30-2840
30-2683
30-2684
30-2685
30-2686
30-2696
30-2695
30-2433
30-2513
F30-25
F30-26
F30-27
30-2481
F30-33
F30-34
F30-35
F30-36
F30-38
F30-81
F30-66
*
30-3407
Screened
(feet below
land surface)
10 to 40
40 to 70
20 to 40
40 to 63
12 to 40
10 to 13
13.5 to 16.5
19.5 to 30
12.5 to 15.5
18 to 28
18 to 28
5 to 25
2 to 22
24 to 29
30 to 35
18 to 20
5 to 15
18.9 to 21.4
27 to 29.5
14.4 to 16.9
19.7 to 22.2
19.9 to 22.4
10 to 12
7.3 to 9.3
12.5 to 14.5
14 to 19
Interval
(feet
relative to
mean sea level)
- 4.8 to -34.8
-34.6 to -64.6
-16.2 to -36.2
-37.1 to -60.1
- 8.9 to -36.9
_
-
-
_
-
-
3 to -16
5 to -15
-16 to -21
-20 to -25
-
^
-14 to -16
-22 to -24.5
- 7.1 to - 9.6
2.4 to - 0.1
-11.3 to -13.8
- 8 to -10
-0.5 to - 2.5
- 5.6 to - 7.7
-
Height of
Measuring
Point
(feet
above
land
surface)
2.35
1.93
2
2
3
»
-
-
_
-
-
2.23
2.20
1.32
0.0
-
^
1.79
2.59
1.70
-0.10
2.07
2.97
2.11
2.65
2.14
Elevation
of Measur-
ing Point
(feet rel-
ative to
mean sea
level)
7.56
7,34
5,81
4.89
6.10
6.51
7.09
7.52
9.10
7.42
7.03
10.53
9.07
9.01
9.55
4.88
6.33
6.74
7.56
8.99
22.01
10.72
5.33
8.94
*
9.16
Casing
Diameter
(inches)
6
6
6
6
6
• 1.25
1.25
1.25
1.25
1.25
1.25
2
2
2.5
2.5
2.5
2
2.5
2.5
2.5
3
2.5
1.25
1.25
1.25
2
 *  Data to be obtained
**  Bent at an angle

-------
                                    -110-
TableA-3  (Continued)
Screened Interval
Well
No.
K1
K2
P4
W15a
W17
W18
W19
W20
W21
W22
W23
W24
W25
W26
W27
W28
W29
W30
W31
X1
X2
AA
BBa
CC
DO
Permit
Number
F3G-30
F30-69
F30-80
»
F30-63
F30-64
F30-65
30-2518
30-2519
30-2520
30-2521
*
*
*
*
*
*
*
*
F30-70
F 30-71
F30-72
*
F30-39
F30-40
(feet below
land surface)
8
14
17
6.
9.
10.
10.
6.
19
8.
19








10
4.


18
15
.4 to 10.4
.3 to 16.3
.5 to 19.5
8 to 16.8
9 to 19.9
1 to 20.1
1 to 20.1
5 to 11.5
to 24
5 to 13.5
to 24
*
*
*
*
*
*
*
»
to 12
9 to 6.9
.
*
to 20
to 19
(feet
relative to
mean sea level)
0.5 to - 1,5
- 5.7 to - 7.7
- 9 to -11
4.7 to - 5.3
- 0.9 to -10.9
2.9 to - 7.1
6.8 to - 3.2
- 5.6 to -10.6
-18 to -23
- 7.9 to -12.9
-19 to -24
*
*
*
*
*
*
*
*
—
-
_
*
-12 to -14
1 to - 3
Height of
Measuring
Point
(feet
above
land
surface)
1.68
2.14
1.71
3.68
3.66
3.25
0.42
2.00
1.93
2.68
2.67
*
*
*
*
*
*
*
»
_
-
3.63
*
1.35
1.00
Elevation
of Measur-
ing Point
(feet rel-
ative to Casing
mean sea Diameter
level) (inches)
10.59
10.75
10.24
*
12.71
16.20
17.34
2.89
2.98
3.33
3.14
*
*
»
*
*
*
»
*
5.09
6.04
5.42
*
7.51
16.53
1.25
1.25
1.25
1.25
1.25
1.25
1.25
2
2
2
2
*
*
*
*
*
*
*
*
1.25
1.25
1.25
*
2
2
*  Data to be obtained

-------
                                   -Ill-
Tab leA-3 . (Continued)
Well
No.
FF
GG
HH
II
AV2
MA1S
MA1I
MA 10
MA2S
MA2I
MA2D
MA3S
MA3I
MA30
MA4S
MA4I
MA4D
MA5S
MA5I
MA5D
MA6S
MA6I
MA60
MA7S
MA7I
MA7D
MASS
MA8I
MA 80
Permit
Number
F30-74
F30-75
F30-77
F30-43
30-2515
30-2484
30-2483
30-2482
30-2487
30-2486
30-2485
30-2608
30-2607
30-2606
30-2611
30-2610
30-2609
30-2490
30-2489
30-2488
30-2493
30-2492
30-2491
30-2496
30-2495
30-2494
30-2499
30-2498
30-2497

Screened
(feet below
land surface)
16.9
10.7
3.6
3
13
5
25
57
5
25
59
5
30
45
10
35
60
5
27
50
6
11
49
15
24
52
8.5
25
39
to 19.9
to 13.7
to 6.6
to 37.5
to 23
to 10
to 35
to 67
to 10
to 35
to 69
to 10
to 40
to 60
to 15
to 50
to 70
to 10
to 37
to- 60
to 11
to 21
to 59
to 20
to 34 •
to 62
to 13.5
to 35
to 49
Interval
(feet
relative to
mean sea level)

- 2.3

4.9
5
- 3
-23
-55
- 3
-23
-57
- 2
-27
-42
- 5
-30
-55
- 3
-25
-48
- 4
. - 9
-47
-13
-22
-51
- 6.7
-23
-37
.
to - 5.3
—
to -29.6
to - 5
to - 8
to -33
to -65
to - 8
to -33
to -67
to - 7
to -37
to -57
to -10
to -45
to -65
to - 8
to -35
to -58
to - 9
to -19
to -57
to -18
to -32
to -61
to -11.7
to -33
to -47
Height of
Measuring
Point
(feet
above
land
surface )
.
2.66
—
1.97
2.10
0.85
3.17
3.46
1.35
1.17
3.00
1.18
1.75
1.58
2.89
2.75
2.60
1.58
1.55
1.93
1.80
1.70
1.86
1.37
1.32
1.40
1.55
1.00
1.07
Elevation
of Measur-
ing Point
(feet rel-
ative to
mean sea
level)
6.67
11.07
5.08
9.88
20.31
2.53
4.84
5.10
3.23
3.24
5.10 '
4.28
4.89
4.23
7.77
7.67
7.40
4.01
4.03
4.38
3.78
3.76
3.82
2.89
2.92
2.73
3.39
2.89
2.60
Casing
Diameter
(inches)
1.25
1.25
1.25
2
2
2
2
2
1.25
1.25
1.25
2
2
2
2
2
2
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
. 1.25
1.25

-------
                                     -112-
TableA-3  (Continued)
Screened
Well
No.
MA9S
MA9I
MA9D
MA10S
MA10I
MA10D
MA11S
MA11I
MA11D
MW1a
MW2a
MW3a
MW4a
MW5
MW6
MW7
DP1
DP2
DP 3
DP4**»
DP5
Permit
Number
30-2507
30-2506
30-2500
30-2510
30-2509
30-2508
30-2573
30-2512
30-2511
*
30-3408
30-3409
*
30-2438
30-2439"
30-2697
30-1472
30-1471
F30-44
30-2539
30-2522
(feet below
land surface)
7.5
19
59
5
19
49
5
19
45
1
2
2
1
3
1
20
80
80
75
95
78.5
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
12.5
29
69
10
29
59
10
29
55
26
20
20
21
28
29
30
90
90
85
125
88.5
Interval
(feet
relative to
mean sea level)
- 4.9
-16
-57
- 4
-18
-48
- 4
-18
-44
5


8
6
7

-75
-72
-53
-83
-71
to
to
to
to
to
to
to
to
to
to
-
-
to
to
to
-
to
to
to
to
to
- 9.9
- 26
- 67
- 9
- 28
- 58
- 9
- 28
- 54
- 20


- 12
- 19
- 21

- 85
- 82
- 63
-113
- 81
Height of
Measuring
Point
(feet
above
land
surface)
2.37
0.75
0.95
1.50
1.05
1.90
2.17
1.75
1.70
1.85
1.69
2.78
0.80
1.00
1.80
-
2.48
2.13
0.05
1.53
1.63
Elevation
of Measur-
ing Point
(feet rel-
ative to
mean sea
level)
5
3
3
2
1
2
3
2
3
*
7
10
*
9
9
10
7
10
22
13
9
.02
.30
.23
.38
.99
.98
.39
.97
.01

.75
.02

.52
.59
.67
.58
.62
.05
.13
.13
Casing
Diameter
(inches)
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
1.25
2
2
2
2
2
2
1.25
4
4
4
8
6
Note;  Wells DP1, DP2, DP3, DP4, and DPS are  screened  in  the  shallow  artesian
       aquifer
***
     Data to be obtained
     Screen diameter = 6  inches

-------
                              -113-
                            Table  A-4
       Water  Level  Measurements  Taken  by the  Task Force at RES
Well
No.
TT
DP-4
AV-2b
DP-3
S
P-4
MW- 1 A
np-R
W29
W30
W31
W28
14
W15A
322
21A
MW-2A
22
W27
23b
W24
W25
13
MW-3A
24
17
MA-7S
MA-7D
MA-2S
MA-2D
MA-3S
MA- 3D
29
MA- 10
MA- IS
4A

Static
2/19/87
DRY
9 98
15.94
19 15
5.85
8 27


7.90
8.09
8.33
7.96
7.74
11.71
8.67
4.73
5.46
3 73
4.55
6 57
7.27
11.83
10.68
7.34
2.62
7.91
1.99
1.82

3.42
4.36
2.80
3.82
2.78
1.31
2.60

True
Water
Level

3 15
4.37
2 90
1.71
1 97


2.43
2.43
4.06
2.93
2 35
*
1.86
2.20
2.29
1 Q
1.96
*
1.76
1.94
1.97
2.68
1.68
1.93
0.90
0.91

1.68
-.08
1.43
1.61
2.32
1.22
*

Static
2/9/87

Q gg a
15.77 a
19 89 a
5.99 a
9 07 a
4 ?o a
7 1 n a
/ . 1U
7.23 a
7 93a


11 42a
8 17a
5 57a

4.10
6.10a
12 75a



8.70a
2.29
1.21
1 7£
1. / j
2.50
3.79
2 21
3.46
2.54
1.08
2.29

True
Water
Level

3 44
4.54
216
1.57
1 1 7
*
o r\o
L, UJ
3.10
4 46


*
2 36
2 18

2.41
2.43
1 02



1.14
0 6
1 52
In Q
.q-o
2.6
0.49
? n?
1.97
2 56
1.45
*

Static
Sampling


15.81
5.44

7 A 1
/ .41
7.43





4.42

4.10
7.14



7.49

1-j r
. /b
2.56
3.74
3.37
1.11

True
Water
Level


4.50
2.12

1 7O
1. / L
2.90





2.51

2.41
1.89



2.35


.48
2.54
0.54
2.06
1.42

Sampl ing
Date


2/10
2/10

O/17
Hii
2/18





2/13

2/13
2/17



2/11


2/12
2/12
2/10
2/10
2/18

Measurements taken to top of PVC (inner) casing unless otherwise qualified

 a - Measurements taken by Alliance to top of protective casing
 b - Upgradient well
 * - data to be obtained

-------
                              -114-

                          Table A-4 (Cont.)


       Water Level Measurements Taken by the Task Force at RES
Well
No.
28
MA-8S
MA-8D
MA-4S
MA-4D
MA-9S
MA-9D
MW-6
R
25
MW-4A
MW-7
26
MA-11I
MA-11D
DP-2
DP-1
L-2

Static
2/19/87
6.38
2 81
1.55
6 64
6 15
3.79
3 74
7 «9
4 30
Pumping
8.73
9.19
6.08


True
Water
Level
1 39
0 58
1.05
1 13
1 25
1.23
- 51
1 70
2 44
*
1.48
1.40













Static
2/9/87
6 29
2 87
1.71
7 23
8 92
5.00
5 40


4.02
6.97-
10.33
7.88
1.81
0.80
11.21


True
Water
Level
1 48
R?
0.89
n Rd

0.02
-217


-.58
*
0.34
-.4
1.16
2.21
-.59













Static
Sampling


1.87

4.59


3.52
6.90
1.79
10.25
6CC
. 03
C Of)
0. L.\J
True
Water
Level


0.73

0.43


-.08
*
1.22
.37
no
. yj

Sam pi ing
Date


2/16

2/11


2/12
2/11
2/18
2/16
9 / 1 O
C.I i y
71 1 Q
el iy











Measurements taken to top of PVC (inner) casing unless otherwise specified

a - Measurements taken by Alliance to top of protective casing
b - Upgradient well
* - data to be obtained

-------
                                     -115-
                                   Table  A-5
              Duplicate  Water  Level  Measurements  Taken  by the  Task  Force
Well
Number
MA-2S3
4Aa
MA-8Da
26a
MW-24b
322b
322C
17C
Deptf
Water
1
1.75
2.3
1.73
8.21
6.91
—
8.67
7.91
i to
ft.)
2
1.75
2.25
1.71
7.875
6.90
--
8.67
7.91
Depth to
u Water
Difference
(ft.)
0.00
0.50
0.02
0.335
0.01
--
0.00
0.00
Total
Depth(ft.)
1
8.73
19.04
49.83
24.75
--
26.77
--
--
2
8.73
19.08
49.81
24.79
--
26.66
--
--
Total
Depth
Difference
(ft.)
0.00
0.04
0.02
0.04
--
0.11
--
--
Time
Between
Measurements
Immediate
it
ii
H
M
H
M
H
Date
2/9/87
2/9/87
2/9/87
2/9/87
2/9/87
2/9/87
2/19/87
2/19/87
    -  No duplicate measurements taken

a   - Distance measured in feet from top of casing.  Team:  DiGuardia/DeLuca
b   - Distance measured in feet from top of protective casing. Team: Lewis/Naughton
c   - Distance measured in feet from top of casing.  Team:  DiGuardia/Lewis/Naughton

-------
                                  -116-
                                Table A-6
 Physical Characteristics of Wells Measured and Sampled by Task  Force at
 Rollins Environmental Services
Well
No.
* AV-2
S
MA-3S
* 29
MA-9S
17
MW-4A
MA- 20
MA-2S
25
* 21A
W27
DP-2
MA-8D
W-24
DP-5
W-29
MA-11D
MA- IS
DP-1
L-2
Total
Depth
(ft.)
22.9
29.78
13.29
25.0
13.69
20.64
24.25
67.70
8.75
19.70
25.00
24.85
89.53
49.02
25.48
88.43
26.64
55.25
13.93
93.56
14.51
Static
Water Level
(ft.)
15.81
5.44
3.74
3.37
4.59
7.49
6.90
2.56
1.75
3.52
4.42
4.10
10.25
1.87
7.14
7.41
7.43
1.79
1.11
6.65
6.20
Casing
Diameter
(in.)
2
4
2
4
1.25
4
2
1.25
1.25
4
6
4
4
1.25
4
6
4
1.25
2
4
4
Volume
in column
(gal.)
1.2
9.0
1.6
14.0
.59
8.5
2.85
5.97
.65
10.08
30.20
13.4
50.8
4.8
12.0
116.0
12.5
5.45
2.1
55
5.4
Volume
Purged
(gal.)
3.8
27.0
5.0
56.0
2.0
26.0
9.0
18.0
2.0
42.0
94.0
45.0
155.0
15.0
38.0
360.0
38.0
16.5
7.0
170.0
16.25
* Upgradient
* Abatement Well - no total
                            depth
+ All  measurements taken from top of casing

-------
                                  -117-
                                Table A-7
 Results of Air Monitoring at Ground Water Monitoring Wells Sampled by the Task
 Force at RES



Well
Number

AV-2
S
MA-3S
29
MA-9S
17
MW-4A
MA-2D
MA-2S
25
21A
W27
DP-2
MA-8D
W24
DP-5
W29
MA-11D
MA- IS
DP-1
L-2
OVA
Readings
(ppm)


background
*
*
*
*
*
*
*
*
*
3.5
2.0
4.0
5.0
4.0
*
*
*
*
*
*
*

wel 1
*
*
*
*
*
*
*
*
*
18
2.0
>100.0+
5.0
4.0
*
*
*
*
*
*
*
HNU
Readings
(ppm)


background
0.3
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.2
0.4
0.4
0.5
0.4
0.2
0.3
0.2
0.3
0.4
0.6
0.4

well
0.3
0.4
13.0
0.4
1.2
0.5
0.4
40.0+
0.4
0.2
0.5
0.4
0.5
0.8
0.7
0.3
0.3
0.3
20.0+
0.6
6.0
Geiger
Readings
(mrems/hr)


background
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02

well
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02

0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02


Interface
Probe


Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
* OVA not operational
+ Reading obtained upon purging well

-------
                                    -118-
                                  Table A-8
             Field Measurements Conducted by the Task Force at RES
Sample
Location
AV-2
S
MA-3S
29
MA-9S
17
MW-4A
MA- 20
MA-2S
25
21A
W27
DP-2
MA-8D
W24
DP-5
W29
MA-11D
MA- IS
DP-1
L-2
Temperature
(C°)
11.2
12.9
10.1
14.5
11.0
9.8
7.2
12.3
10.1
12.9
15.0
11.0
13.8
11.2
13.0
11.9
7.8
11.2
12.0
9.7
13.7
pH
(S.U.)
6.1
4.5
5.2
6.0
5.6
6.3
6.8
6.9
6.1
6.7
6.2
6.8
4.7
6.2
6.9
4.1
6.4
6.0
6.3
6.3
6.3
Specific
Conductivity
250
500
650
1200
300
475
260
11600
1300
10500
5250
3250
230
480
3000
575
540
340
1225
330
2750
Turbidity
(NTU)
6.2
20
15
30
>100
42
>100
NA
>100
>100
20
>100
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA - Not analyzed

-------
                          -119-


              Key to Results of Sample Analysis


J    -  Compound present below the specified detection  limit

N    -  Indicates spike sample recovery is  not within control  limits

*    -  Indicates duplicate analysis is not within  control  limits

S    -  Indicates value determined by Method of  Standard  Addition

U    -  Compound was analyzed but not detected

()      If the result is a value greater than or equal  to the  instrument
        detection limit but less than the contract  required detection  limit

—  -  data did not pass QA/QC review

-------
                                                   -120-
Table A-9  Results of Inorganic and Indicator Type Analyses
                                              Water Table Aquifer
Parameter
mg/1

Bromide
Chloride
Fluoride
Sul fate
MA-8D
MQB-003

U
35
U
58
MA-3S
MQB-005

U
126
U
40
29
MQB-006

2.3
153
1.1
17
MA-2S
MQB-007

U
195
2.2
58
S
MQB-008

U
24
U
18
MA-9S
MQB-009

U
33
U
28
AV-2
MQB-010

U
4.5
U
48
W-29
MQB-011
(DUP)
U
23
1.0
69
MA-2D
MQB-012

U
1300
U
620
Parameter
ug/1
POC
TOC
Phenols,
total
POX
TOX
MA-8D
MQB-003
980
1800
U
U
—
MA-3S
MQB-005
3300
10000
U
11
—
29
MQB-006
4540
42000
888
3330
5380
MA-2S
MQB-007
76
16000
U
U
	
S
MQB-008
U
1600
U
U
—
MA-9S
MQB-009
78
8000
U
18
—
AV-2
MQB-010
224
1800
U
U
—
W-29
MQB-011
(DUP)
1420
10000
U
6
—
MA-2D
MQB-012
4400
204000
888
11100
4100

-------
                                                    -121-
Table A-9 (Cont.)  - Results of Inorganic and Indicator Type Analyses
                                             Water Table Aquifer
Parameter
mg/1
Bromide
Chloride
Fluoride
Sulfate
25
MQB-013
U
2250
U
2700
21A
MQB-014
30
1760
13
375
L-2
MQB-025
25
1160
14
180
MW-4A
MQA-736
U
21
2.1
16
W-29
MQA-739
U
22
U
69
MA- IS
MQA-741
11
298
16
U
17
MQA-742
U
43
1.6
103
MW-4A
MQA-743
(DUP)
U
40
1.5
30
MW-27
MQA-744
5.3
760
6.9
320
Parameter
ug/1
POC
TOC
Phenols,
total
POX
TOX
25
MQB-013
42
16000
U

26
—
21A
MQB-014
75
6200
U

14
—
L-2
MQB-025
48
9400
U

U
—
MW-4A
MQA-736
83
268000
U

U
—
W-29
MQA-739
980
10000
U

U

MA- IS
MQA-741
28000
267000
5000

7400
21300
17
MQA-742
1380
13000
U

393
574
MW-4A
MQA-743
(DUP)
97
206000
U

U
—
MW-27
MQA-744
1400
9800
U

19
—








-------
                                    -122-
Table A-9 (Cont.)  - Results of Inorganic and Indicator Type Analyses
      Water Table Aquifer
Shallow Artesian Aquifer
Parameter
mg/1
Bromide
Chloride
Fluoride
Sulfate
W-24
MQA-745
4.5
790
U
280
MA-11D
MQA-749
U
30
U
60
DP-2
MQB-004
U
32
U
12
DP-1
MQB-026
U
75
U
9.2
DP-5
MQA-750
U
68
U
112
Parameter
ug/1
POC
TOC
Phenols,
total
POX
TOX
W-24
MQA-745
3000
15000
U
103
	
MA-11D
MQB-749
1160
1700
U
U
—
DP-2
MQB-004
26
U
U
U
DP-1
MQB-026
44
U
U
U
DP-5
MQA-750
280
3000
U
131

-------
                                                    -123-
Table A-10 - Results of Total  Metals Analyses
                                             Mater Table Aquifer
Parameter
ug/1
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromi urn
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Tin
Vanadium
Zinc
Cyanide
Cyanide(DUP
MA-8D
MQB-003
1770*
U
U*
(116)N
U
UN
35300
U
(22)
(24)
2580N
5.6N
15900N
596
UN
(29)
12300
UN
U
18400
UN
U
U
123
—
i NA
MA-3S
MQB-005
28500*
U
(7.8)*
(137)N
(2)
UN
33600
120
U
89
30100N
19N
14300N
198
2. IN
(29)
(4190)
UN
U
54000
UN
U
136
69
UN
NA
29
MQB-006
447*
U
57*S
(50)N
U
UN
50300
20
U
26
17500N
UN
18300N
1340
UN
U
8200
UN
U
77100
UN
U
(17)
43
UN
NA
MA-2S
MQB-007
30200*
U
13*S
208N
(2)
(.6)N
36600
65
(20)
(24)
40200N
31N
23400N
791
.3N
(30)
6220
UN
U
93100
UN
U
(42)
93
—
NA
S
MQB-008
661*
U
U*
(78)N
U
—
24600
U
U
48
1510N
(4.1)N
20400N
228
UN
U
(4220)
UN
U
7680
UN
U
U
82
UN
NA
MA-9S
MQB-009
7160*
U
U*
(46)N
U
(.6)N
42000
25
U
40
31700N
25N
7260N
539
3.7N
(26)
6630
UN
U
11600
UN
U
304
59
UN
NA
AV-2
MQB-010
55400*
U
18*
274N
(3)
—
12900
163
21
191
61100N
26NS
7950N
669
UN
(26)
18600
UN
U
(3070)
UN
U
403
97
UN
NA
W-29
HQB-011
(DUP)
1620*
U
23*S
(59)N
U
UN
56200
22
U~
69
21400N
17NS
28500N
751
UN
U
5230
UN
U
21300
UN
U
U
43
UN
NA

-------
                                                     -124-
Table A-10 (Cont.) - Results of Total  Metals  Analyses
                                              Uater  Table  Aquifer
Parameter
ug/1
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesi urn
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thall ium
Tin
Vanadium
Zinc
Cyanide
Cyanide(DUP
MA-2D
MQB-012
8290*
U
394*S
(52)N
U
UN
145000
18
(27)
(16)
7990N
46NS
176000N
287
—
167
48300
UN
U
1710000
UN
U
292
92
—
i NA
25
MQB-013
5600*
U
472*S
(116)N
(2)
UN
451000
440
U
294
99700N
(26)N
256000N
719
—
U
17200
UN
U
820000
UN
U
(22)
204
45
50
21A
MQB-014
1130
U
43*S
(68)N
U
UN
306000
101
U
U
13900N
6.5N
196000N
98
—
U
15100
UN
U
482000
UN
U
U
38
UN
NA
L-2
MQB-025
14000*
U
U*
(123)N
U
	
278000
29
U
36
19900N
25N
167000N
475
—
U
11600
UN
U
405000
UN
U
(38)
53
UN
NA
MW-4A
MQA-736
360000*
U
U*
1040N
25
(2)N
58600
1640
122
1680
438000N
51N
31900N
2140
1.4N
184
34900
UN
U
7980
UN
U
1100
1280
80
87
W-29
MQA-739
2770*
U
22*S
(45)N
U
UN
53600
19
U
61
21400N
13N
28000N
743
UN
U
5240
UN
U
21100
UN
U
U
31
UN
NA
MA- IS
MQA-741
U*
U
88*S
(59)N
U
UN
6390
U
U
U
7200N
21NS
(2320)N
178
.3N
U
(2740)
UN
U
71100
UN
U
U
(19)
UN
NA
17
MQA-742
7650*
U
62*S
(106)N
(2)
(7.5)N
78400
7880
66
4890
279000N
130N
13700N
2040
.4N
153
13800
UN
U
47400
UN
U
(46)
1350
UN
NA

-------
                                                    -125-
Table A-10 (Cont.) - Results of Total  Metals Analyses



                      Mater Table Aquifer
Parameter
ug/1
Al uminum
Antimony
Arsenic
Barium
Beryl 1 i urn
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Tin
Vanadium
Zinc
Cyanide
Cyanide(DUP
MW-4A
MQA-743
(DUP)
215000*
U
(8.1)*
715N
17
(l.l)N
51000
1230
83
1230
293000N
192N
22300N
1600
IN
118
22400
UN
U
7610
UN
U
754
886
40
40
MW-27
MQA-744
5350*
—
27*
(69)N
U
UN
201000
U
U
150
13600N
24N
145000N
604
UN
U
10000
UN
U
295000
UN
U
U
78
UN
NA
W-24
MQA-745
1570*
U
U*
(32)N
U
UN
218000
U
(20)
(12)
50400N
29N
89400N
1900
UN
U
11800
UN
U
222000
UN
U
U
29
UN
NA
MA-11D
MQA-749
17700*
U
U*
(125)N
5
UN
36200
71
(30)
141
13300N
23NS
19100N
459
UN
(26)
14000
UN
U
6410
UN
U
(37)
168
UN
NA
Shallow Artesian Zone
DP-2
MQB-004
322*
U
U*
(105)N
U
(3.2)N
6880
U
U
(14)
386N
14N
(2780)N
116
UN
U
(2320)
UN
U
18700
UN
U
U
36
UN
NA
DP-1
MQB-026
(190)*
U
U*
(58)N
U
UN
5740
U
U
U
7250N
16N
(2100)N
176
UN
U
(2520)
UN
U
61500
UN
U
U
34
UN
NA
DP-5
MQA-750
1840*
U
U*
(79)N
U
UN
16800
U
(20)
28
538N
ION
18500N
69
UN
U
5550
UN
U
56200
UN
U
U
59
UN
NA
1

-------
                                                    -126-



Table A-ll - Results of Dissolved Metals Analyses



                                             Water Table Aquifer
Parameter
ug/1
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Tin
Vanadium
Zinc
MA-8D
MQB-003
(44)
U
UN
(119)
U
U
37800
U
(35)
UN
920
UN
17800
656
UN
U
15000
UN
U
20600
UN
(40)
(14)
162
MA-3S
MQB-005
(49)
U
UN
(61)
U
U
32700
U
U
(8)N
2120
UN
12200
136
UN
U
(3360)
UN
U
55100
UN
U
U
30
29
MQB-006
(72)
U
52NS
(39)
U
U
53500
U
U
UN
11400
UN
20200
1450
UN
U
9330
—
U
84600
UN
U
(15)
(17)
MA-2S
MQB-007
(55)
U
UN
(101)
U
U
36600
U
U
UN
13100
40N
22500
715
UN
U
5810
UN
U
107000
UN
U
U
25
S
MQB-008
434
U
UN
(75)
U
U
26100
U
U
52N
U
5.4N
22500
216
UN
U
5120
UN
U
8450
UN
U
U
110
MA-9S
MQB-009
(52)
U
UN
(44)
U
U
44200
U
U
UN
89
UN
7880
503
UN
U
7510
UN
U
13800
UN
U
U
50
AV-2
MQB-010
U
U
UN
(62)
U
(1.4)
11000
U
U
UN
3870
5.3N
5640
491
UN
U
18800
UN
U
(3020)
UN
U
U
29
W-29
MQB-011
(DUP)
U
U
(7.5)NS
(52)
U
6.9
60700
U
U
UN
19000
UN
32100
831
UN
U
5710
UN
U
24100
UN
U
U
(19)

-------
                                                    -127-



Table A-ll (Cont.)  - Results of Dissolved Metals  Analyses



                                             Water Table Aquifer
Parameter
ug/i
Al urn in urn
Antimony
Arsenic
Bari urn
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Tin
Vanadium
Zinc

MA-2D
MQB-012
(44)
U
264NS
(54)
U
U
155000
U
U
UN
238
UN
196000
296
—
150
54400
—
U
1570000
UN
U
311
31

25
MQB-013
(142)
U
56NS
(88)
U
U
515000
U
U
(11)N
11300
UN
299000
773
—
U
19700
UN
U
738000
UN
U
(15)
55

21A
MQB-014
820
U
UN
(74)
U
U
358000
U
U
UN
3310
UN
236000
121
—
U
18800
UN
U
579000
UN
U
U
(16)

L-2
MQB-025
245
U
UN
(87)
U
U
284000
U
U
UN
4640
UN
170000
429
—
U
9530
UN
U
421000
UN
U
U
21

MW-4A
MQA-736
(60)
U
UN
(48)
U
U
37500
U
U
UN
U
UN
6170
35
UN
U
5290
UN
U
9270
UN
U
U
U

W-29
MQA-739
U
U
___
(52)
U
U
58600
U
U
UN
16600
UN
30500
779
UN
U
5480
UN
U
22500
UN
(38)
U
(19)

MA- IS
MQA-741
U
U
— — —
(121)
U
U
57400
U
U
UN
151000
UN
13400
2440
UN
U
11700
UN
U
132000
UN
U
U
41

17
MQA-742
280
U
UN
(31)
U
U
70000
U
U
UN
11700
(2.4)N
12700
1040
UN
U
13100
UN
U
32000
UN
U
U
92




























-------
                                                    -128-



Table A-ll (Cont.)  - Results of Dissolved Metals Analyses



                     Water Table Aquifer
Shallow Artesian Zone

Parameter
ug/1
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Tin
Vanadium
Zinc
MW-4A
MQA-743
(DUP)
339
U
UN
(61)
U
U
37100
U
U
UN
(98)
UN
5960
47
UN
U
5460
UN
U
8620
UN
U
U
28
MW-27
MQA-744
(187)
U
20N
(49)
U
U
221000
U
U
UN
7820
UN
161000
628
UN
U
12200
UN
U
315000
UN
U
U
29
W-24
MQA-745
U
U
UN
(32)
U
U
236000
U
U
UN
40300
UN
102000
2150
UN
U
14300
UN
U
244000
UN
U
U
36
MA-11D
MQA-749
620
U
UN
(86)
(3)
(1)
34900
U
(21)
74N
(41)
UN
16800
368
UN
U
13100
UN
U
5700
UN
U
U
124


























DP-2
MQB-004
U
U
UN
(113)
U
(2.5)
7600
U
U
(11)N
(27)
12N
(3230)
129
UN
U
(3070)
UN
U
20400
UN
U
U
50
DP-1
MQB-026
U
U
UN
(59)
U
U
6440
U
U
UN
7270
UN
(2380)
178
UN
U
(2600)
UN
U
70700
UN
53
U
U
DP-5
MQA-750
456
U
UN
(100)
U
U
18200
U
(25)
(21)N
(84)
28N
21000
76
UN
U
6670
UN
U
62700
UN
U
U
110

-------
                                                   -129-
Table A-12 -  Results of Volatile  Organics  Analyses
                                            Water Table Aquifer
Parameter
ug/1
Ar P 1" n n P
Benzene
2-Butanone
Carbon Disulfide
Carbon Tetrachloride
Chlorobenzene
Chloroform
1,1-Dichloroethane
1,2-Dichloroethane
1,2-Dichloropropane
Ethyl benzene
2-Hexanone
Mp1"hvlpnp rhlnrirlp

Tetrachloroethene
Trichloroethene
1,1,1-Trichloroethane
Trans- 1,2- Die hi oroethene
Toluene
Total Xylene
Vinyl Chloride
1,2-Dibromoethane
TV* l r hi n i*n fl iiny*nniP"t'hanp

HA-8D
MQB-003

U
12
U
U
U
U
U
U
6
U
U


U
U
U
U
U
U
U
11


MA-3S
MQB-005

U
U
U
U
U
U
U
U
U
U
U


U
U
U
U
U
U
U
U


29
MQB-006

530
U
U
U
69
440
45J
120
U
73
U


27J
230
330
51
570
190
35J
U


MA-2S
MQB-007

U
U
U
U
U
U
U
U
U
U
U


U
U
U
U
U
U
U
U


s
MQB-008

U
U
U
U
. U
2J
U
U
U
U
U


U
U
U
U
U
U
U
U


MA-9S
MQB-009

U
U
U
U
U
U
U
U
U
U
U


U
U
U
26
U
U
U
U



-------
                                                    -130-
Table A-12 (Cont.) -  Results of Volatile Organics Analyses
                                             Water Table Aquifer
Parameter
ug/1

Acetone
Benzene
2-Butanone
Carbon Disulfide
Carbon Tetrachl oride
Chlorobenzene
Chloroform
1,1-Dichloroethane
1,2-Dichloroethane
1,2-Dichloropropane
Ethyl benzene
2-Hexanone
M4-U1 ^ t* 1 'A
netnyiene unioriae
Tetrachl oroethene
Trichloroethene
1,1,1-Trichloroethane
Trans- 1,2-Dic hi oroethene
Toluene
Total Xylene
Vinyl Chloride
1,2-Dibromoethane
•f ' U 1 -Cl 4- U
incni oroT I uororoe inane
AV-2
MQB-010


U
U
U
U
U
U
U
U
U
U
U


U
U
U
U
U
U
U
U


W29
MQB-011
(DUP)


U
U
U
U
U
U
U
U
U
U
U


U
U
U
U
2J
U
U
U


MA-2D
MQB-012


1800
41J
990
U
310
U
38J
U
U
190J
U


U
U
U
U
62J
610
U
U


25
MQB-013


U
U
U
U
U
U
U
U
U
U
U


U
U
U
U
U
U
U
U


21A
MQB-014


U
U
U
U
U
U
U
U
U
U
U


U
U
U
U
2J
U
U
U


L-2
HQB-025


U
U
U
U
U
U
U
U
U
U
U


U
U
U
U
U
U
U
U



-------
                                                    -131-



Table A-12 (Cont.)  -  Results of Volatile  Organics  Analyses
                                             Water Table Aquifer
Parameter
ug/1

Benzene
2-Butanone
Carbon Disulfide
Carbon Tetrachloride
Chlorobenzene
Chloroform
1,1-Dichloroethane
1,2-Dichloroethane
1,2-Dichloro pro pane
Ethyl benzene
2-Hexanone

iMcLiiy i ciic i/iii uriuc
Tetrachloroethene
Trichloroethene
1,1,1-Trichloroethane
Trans-1 ,2-Dichloroethene
Toluene
Total Xylene
Vinyl Chloride
1,2-Dibromoethane
•T-- _l_T -.„-. £~\ , , — u* ,-. m s-v 4- It r\ *\ <-v
incnioroTi uo rofuc inane
MW-4A
MQA-736

U
U
U
U
U
U
U
20
U
U
U

U
U
U
U
U
U
U
U


W-29
MQA-739

U
U
U
U
U
U
U
U
U
U
U

U
U
U
U
U
U
U
U


MA- IS
MQA-741

3100
1300
U
U
360J
700
510
300J
U
720
1100

U
U
860
1600
10000
2800
1000
U


17
MQA-742

16
U
U
U
31
33
9
U
U
8
U

41
120
150
12
2J
U
U
U


MW-4A
MQA-743
(DUP)

U
U
U
U
U
U
U
20
U
U
U

U
U
U
U
U
U
U
U


MW-27
MQA-744

30
U
U
U
7
U
20
U
U
U
U

U
U
U
30
U
U
20
U



-------
                                                    -132-



Table A-12 (Cont.) -  Results of Volatile Organics Analyses
                  Water Table Aquifer
Shallow Artesian Zone
Parameter
ug/1

Acetone
Benzene
2-Butanone
Carbon Disulfide
Carbon Tetrachloride
Chlorobenzene
Chloroform
1,1-Dichloroethane
1,2-Dichloroethane
1,2-Dichloropropane
Ethyl benzene
2-Hexanone
M£\ 4- k\ \/1 ^ n ^ f*l*iT n v* i H o
pietnyienc Lnioriuc
Tetrachloroethene
Trichloroethene
1,1,1-Trichloroethane
Trans-l,2-Dichloroethene
Toluene
Total Xylene
Vinyl Chloride
1,2-Dibromoethane
T •! *i U "1 **. u**\ -G~\ n\s*ngTf>r\4-V\ir\f\
i ncn i oroT i uo ronictnane
W-24
MQA-745


38
U
U
7
13
4J
9
23
U
6
U


6
94
29
32
4J
9
16
U


MA-11D
MQA-749


U
U
U
U
U
U
U
U
U
U
U


U
U
U
U
U
U
U
U


DP-2
MQB-004

U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
7J
U

DP-1
MQB-026

U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U

DP-5
MQA-750

7
U
U
U
U
5
10
180
U
U
U
2J
20
U
4J
U
U
8J
U


-------
                                                   -133-



Table A-13 -  Results of Semi-Volatile Organics Analyses
                                            Water Table Aquifer
Parameter
ug/1
Acenaphthene
Benzoic Acid
Bis(2-chloroethyl )ether
Bis(2-ethylhexyl )phthalate
2-Chlorophenol
4-Chloroaniline
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
2,4-Dichlorophenol
2, 4-Dimethyl phenol
2-Methyl phenol
4-Methyl phenol
2-Methyl naphthal ene
Naphthalene
Phenol
MA-8D
MQB-003
U
U
U


U
U
U
U
U
U
U
U


U
U
U
Phosphorictriamide.Hexamethyl U
1,2,4-Trichlorobenzene
Acetophenone
Aniline
2-Hexanone
4-Methyl -2- Pentanone
Pyridine
0-Toluidine
U
U
U
U
U
U
U
MA-3S
MQB-005
U
U
U


U
U
U
U
U
U
U
U


U
U
U
U
U
U
U
U
U
U
U
29
MQB-006
U
340
200


10
2000
38
4J
8J
170
180
U


47
140
370
13
U
410
150
U
U
U
960
MA-2S
MQB-007
U
U
U


U
U
U
U
U
U
U
U


U
U
U
U
U
U
U
U
U
U
U
s
MQB-008
U
U
U


U
U
U
U
U
U
U
U


U
U
U
U
U
U
U
U
U
U
U
MA-9S
MQB-009
U
U
U


U
U
U
U
U
U
U
U


U
U
U
U
U
U
U
U
U
U
U

-------
                                                    -134-
Table A-13 (Cont.) -  Results of Semi- Volatile  Organics  Analyses
                                             Mater Table Aquifer
Parameter
ug/1
Acenaphthene
Benzoic Acid
Bis(2-chloroethyl )ether
f-i«/rt -.iL..i1 L« x-\ i* t il \ r\ Uv ^ t» -4 1 n +• n
Bi s(2-ethyl hexyl )pntna late
2-Chlorophenol
4-Chloroaniline
1, 2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
2,4-Dichlorophenol
2, 4-Dimethyl phenol
2-Methyl phenol
411 — . i L i 1 n Uin v* *> 1
-Methyl pheno I
2-Methyl naphthalene
Naphthalene
Phenol
AV-2
MQB-010
U
U
U

U
U
U
U
U
U
U
U

U
U
U
Phosphorictriamide.Hexamethyl U
1, 2, 4-Tric hi orobenzene
Acetophenone
Anil ine
2-Hexanone
4-Methyl-2-Pentanone
Pyridine
0-Toluidine
U
U
U
U
U
U
U
W29
MQB-011
(DUP)
U
U
U

U
U
U
U
U
U
U
U

U
U
U
U
U
U
U
U
U
U
U
MA-2D
MQB-012
U
U
U

U
U
U
U
9J
260
U
11J

U
110
380
U
U
U
U
U
U
U
U
25
MQB-013
U
U
U

U
U
U
U
U
U
U
U

U
U
U
U
U
U
U
U
U
U
U
21A
MQB-014
U
U
U

U
U
U
U
U
U
U
U

U
U
U
U
U
U
U
U
U
U
U
L-2
MQB-025
U
U
U

U
U
U
U
U
U
U
U

U
U
2J
U
U
U
U
U
U
U
U

-------
                                                    -135-
Table A-13 (Cont.)  -  Results  of  Semi-Volatile  Organics  Analyses
                                             Water  Table Aquifer
Parameter
ug/1
Acenaphthene
Benzoic Acid
Bis(2-chloroethyl )ether
Bis(2-ethylhexyl )phthalate
2-Chlorophenol
4-Chloroaniline
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
2,4-Dichlorophenol
2,4-Dimethyl phenol
2-Methyl phenol
4-Methyl phenol
2-Methyl naphtha! ene
Naphthalene
Phenol
MW-4A
MQA-736
U
U
U


U
U
U
U
U
U
U
U


U
U
U
Phosphorictriamide.Hexamethyl U
1,2,4-Trichlorobenzene
Acetophenone
Aniline
2-Hexanone
4-Methyl -2-Pentanone
Pyridine
0-Toluidine
U
U
U
U
U
U
U
W-29
MQA-739
U
U
U


U
U
U
U
U
U
U
U


U
U
U
U
U
U
U
U
U
U
U
MA- IS
MQA-741
U
U
U


U
27000
93
U
31J
47
970
U


100
1000
U
U
U
U
1700
U
330
200
2700
17
MQA-742
U
U
U


U
U
5J
U
U
U
U
U


U
U
U
U
6J
U
U
U
U
U
U
MW-4A
MQA-743
(DUP)
U
U
U


U
U
U
U
U
U
U
U


U
U
U
U
U
U
U
77
U
U
U
MW-27
MQA-744
U
U
2 J


U
U
U
5J
U
U
U
U


U
U
U
U
U
U
U
U
U
U
U

-------
                                                -136-



Table A-13 (Cont.) -  Results of Semi-Volatile Organics Analyses
                   Water Table Aquifer
Shallow Artesian Zone
Parameter
ug/1
Acenaphthene
Benzoic Acid
Bis(2-chloroethyl )ether
Bis(2-ethylhexyl )phthalate
2-Chlorophenol
4-Chloroaniline
1,2-Dichlorobenzene
1, 3- Dichl orobenzene
1,4-Dichlorobenzene
2,4-Dichlorophenol
2, 4-Dimethyl phenol
2-Methyl phenol
4-Methyl phenol
2-Methyl naphthalene
Naphthalene
Phenol
W-24
MQA-745
U
U
3J


U
160
2J
4J
U
U
U
U


U
U
U
Phosphorictriamide.Hexamethyl U
1, 2, 4-Tr ic hi orobenzene
Acetophenone
Anil ine
2-Hexanone
4-Methyl -2-Pentanone
Pyridine
0-Toluidine
U
U
U
U
U
U
U
MA-11D
MQA-749
U
U
U


U
U
U
U
U
U
U
U


U
U
U
U
U
U
U
U
U
U
U
DP-2
MQB-004
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
DP-1
MQB-026
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
DP-5
MQA-750
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U

-------
                                     -137-
 Table  A-14  -  Tentatively Identified  Compounds  Requiring  Confirmation Using
              Authentic  Standards
 Well  #

 MA-3S
 Sample  #

 MQB-005
      Compounds
Concentration, ug/1
 29
 MQB-006
MA-2 5
MA-9S




AV-2

W-29 (DUP)
MQB-007



MQB-008



MQB-009




MQB-010

MQB-011
 Tetrahydrofuran                          800
 Cyclohexanone                           400J
 Unknown  BNA                              10J
 Unknown  BNA                              200
 Unknown  BNA                              10J

 Thiobismethane                          300J
 Unknown  VOA                              80J
 Ethyl benzene                             70J
 Xylene                                  200 J
 Xylene                                   70 J
 Unknown  BNA                              80J
 C9H10 Substituted  Benzene               100J
 2-chloroaniline                        4700J
 1,3-Pentanediol ,2,2,4-Trimethyl          800
 Unknown  BNA                             5000
 Unknown  BNA                              400
 Unknown  Chlorinated Compound             400
 Benzene(Butoxymethyl )                    500
 X,Y-Dichloroanil ine                     1000
 Naphtha! ene, 1-methyl-                    370
 Unknown  BNA                              300
 X,Y-Dichloroanil ine                     5000
 X,Y-Dichloroaniline                     3000
 Unknown  Chlorinated Compound            600
 Phenol ,4-(l-methyl-l-phenylethyl-)     1000
 Sulfur Mol. (58)                     20000

 Cyclohexanol                             600
 Butyrolactine                            80
 Unknown                                 200

 Unknown  BNA                            1000
 Unknown  BNA                             200
 Unknown  BNA                             100

2-Propanol, 1-methoxy- (VOA)             50
 Unknown  BNA                             800
Unknown BNA                             200
HEMPA BNA

Unknown BNA
Unknown BNA                            600

-------
                                   -138-

Table A-14 (Cont.) - Tentatively Identified Compounds Requiring Confirmation Using
                     Authentic Standards
Well #        Sample #            Compounds            Concentration, ug/1

MA-2D         MQB-012        Benzene .ethyl                       100J
                             Xylene                             200J
                             Cyclohexanol                        100J
                             Xylene                             100J
                             Unknown                            500J
                             1,2,4-Trithiolane                 2000J
                             2-chloroaniline                  20000J
                             Unknown BNA                        100J
                             Unknown BNA                         60J
                             1,3,5-Trithiane                   1000J
                             Unknown BNA                        600J
                             Unknown BNA                       1000J
                             Unknown BNA                        800J
                             Unknown BNA                        300J
                             1,2,4,6-Tetrathiepane              600J
                             Unknown BNA                        300J
                             Unknown BNA                        100J
                             Unknown BNA                        400J
                             Unknown BNA                        400J
                             Unknown BNA                        200J
                             Unknown BNA                         90J

25            MQB-013        Cyclohexanol                        100J
                             Butyrolactone                       10J
                             Unknown BNA                         10J
                             Unknown BNA                         10J
                             2,5-Cyclohexadiene-l,4-dione,
                             2,6-bis(l,l-dimethylethl)           20J
                             Phenol ,2,4-bis(l,l-dimethylethyl)   10J

21A           MQB-014        Unknown BNA                         40J
                             Sulfur Mol. (S8)                   400J

1-2           MQA-025        Unknown BNA                         40J
                             Unknown BNA                         30J
                             Unknown BNA                          8J

MW-4A         MQA-736        Unknown BNA                         30J
                             Butyrolactone                       10J
                             Unknown BNA                         100
                             Unknown BNA                         20J
                             2,5-Cyclohexadiene-l,4-dione,
                             2,6-bis                            100J
                             Unknown BNA                         200

-------
                                   -139-

Table A-14 (Cont.) - Tentatively Identified Compounds Requiring Confirmation Using
                     Authentic S§andards
Well #        Sample #            Compounds                Concentration, ug/1
W-29          MQA-739        Unknown BNA                           70J
                             Unknown BNA                           20J
                             Unknown BNA                          100J
                                                                    9J

MA-IS         MQA-741        Methylmercaptan                     4000J
                             Xylene                               400J
                             Unknown BNA                          500J
                             Benzofuran                           200J
                             C9H10 Substituted Benzene            700J
                             C9H10 Substituted Benzene            2000
                             Benzenamine,2-chloro-              357200
                             X,Y-dichloroaniline                  5000
                             X,Y-dichloroaniline                 30000
                             X,Y-dichloroaniline                 10000
                             Unknown Chlorinated Compound         2000
                             Unknown Chlorinated Compound         2000
                             Unknown Chlorinated Compound         2000
                             Tributyl Phosphate                   2000
                             Unknown BNA                          2000
                             Unknown BNA                          3000
                             Unknown BNA                          3000

17            MQA-742        Dichlorodifluoroethane                100
                             Ethane,l,2-dichloro-l,l-difluoro      200
                             Unknown BNA                            80
                             Trichloro-difluoro ethane            1000
                             Cyclohexanol                          600
                             2,5-Cyclohexadiene,l-4-Dione,6-Bis
                             (1,1-dimethylethyl)-                  300
                             Unknown BNA                           100
                             Unknown BNA                           200
                             Unknown BNA                           400

MW-4A         MQA-743        Cyclohexanol                          700
(DUP)                        Unknown BNA                           400
                             Unknown BNA                           200
                             Unknown BNA                            80
                             2,5-Cyclohexadiene-l,4Dione,2,6-bis
                             (1,1-dimethylethyl)-                 1000
                             Unknown BNA                           200
                             Unknown BNA                           500

-------
                                   -140-


Table A-14 (Cont.) - Tentatively Identified Compounds Requiring Confirmation Using
                     Authentic Standards
Well #        Sample §            Compounds             Concentration, ug/1
MW-27

W-24








MA-11D
DP-2
DP-1
DP-5

MQA-744

MQA-745








MQA-749
MQB-004
MQB-026
MQA-750

HEMPA
Unknown BNA
Ethyl ether
Unknown VOA
Unknown BNA
Unknown BNA
2-chloroanil ine
Unknown BNA
Unknown BNA
HEMPA
Unknown BNA
Unknown BNA
Unknown BNA
Unknown BNA
HEMPA
Unknown BNA
10J
40J
30J
200
30J
40J
2100
100
600
200
90
800
700
400
200
600

-------
                 -141-
               APPENDIX B



Evaluation of Quality Control Attendant



to the Analysis of Samples from the RES



Facility, New Jersey

-------
pro
Planning Hesearcn CoroorEiion
                             -142-
           EVALUATION OF QUALITY CONTROL ATTENDANT
                TO THE ANALYSIS OF SAMPLES FROM
                   ROLLINS FACILITY, NEW JERSEY
                        FINAL MEMORANDUM
                             Prepared for
             U.S. ENVIRONMENTAL PROTECTION AGENCY
                  Office of Waste Programs Enforcement
                         Washington,D.C. 20460
JJRBf* «r ?"s
                         Work Assignment No.
                         EPA Region
                         Site No.
                         Date Prepared
                         Contract No.
                         PRC No.
                         Prepared By
                         Telephone No.
                         EPA Primary Contact
                         Telephone No.
549
Headquarters
N/A
June 30, 1987
68-01-7037
015-0549-1003
PRC Environmental
Management, Inc.
(Ken Partymiller)
(713) 292-7568
Rich Steimle
(202) 382-7912

-------
                                 -143-
MEMORANDUM

DATE:    June 30, 1987

SUBJECT: Evaluation of Quality Control Attendant to the Analysis of Samples
          from the Rollins Environmental, New Jersey, Facility

FROM-    Ken Partymiller, Chemist
          PRC Environmental Management

THRU:    Paul H. Friedman, Chemist*

TO:       HWGWTF:  Richard Steimle, HWGWTF*  .
          Gareth Pearson (EPA 8231)*
          Fred Haber, Region II
          Brian Lewis, HWGWTF
          Sam Ezekwo, Region II
     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 Rollins Environmental, New Jersey sampling effort by the Hazardous Waste
Ground-Water Task Force.

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

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

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

*  HWGWTF Data Evaluation Committee Member

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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 (2-5).  Questions generated in the interpretation of these data
relative to sampling and analysis should be referred to Rich Steimle of the
Hazardous Waste Ground-Water Task Force.

I.    Site  Overview

     The  Rollins Environmental facility is located in Bridgeport, New Jersey, and
covers approximately 78 acres.  It has been in operation since 1969. The facility
has a landfill (now closed), a surface impoundment (closed), an incinerator (in
operation), and RCRA lagoons which take scrubber wastes from the incinerator.
These lagoons are suspected of leaking and are under a corrective action order.
The facility landfill was excavated about 5 or 6 years ago to solidify the wastes and
raise them above the water table by placing a  sand bed under the wastes.

     There is an upper (25-30 feet deep) aquifer, a middle (68-73 feet  deep) semi-
confined  aquifer, and a large regional aquifer under  the site.  Both the upper and
middle aquifer are being pumped and  the water- treated to remove contamination.

     Twenty-five  field samples (sample numbers preceded by an MQA or MQB) plus
nine volatile sampling blanks (001, and 100 through  107) were collected at this
facility.  The samples  included seven field blanks (001,  100, 102, 103, 105, 106, and
107), three equipment blanks (104, MQA738, and MQB001), a trip blank (MQB002),
and two pairs of duplicate samples (well MW4A, samples MQA736/MQB736 and
MQA743/MQB743 and well W-29, samples MQA739 and MQB011) as well as 18 other
field samples.  All samples were designated as low concentration ground-water
samples.  All samples were analyzed for all HWGWTF Phase 3 analytes with the
exception of samples 001, and  100 through 107 which were only analyzed volatiles.

II.   Evaluation of Quality Control Data and Analytical  Data

 1.0   Metals

 1.1   Metals  OC Evaluation

      Total and dissolved metal spike recoveries were calculated for twenty-four
 metals spiked into two samples (MQB004 and 012). Nineteen total metal average
 spike recoveries from these samples were within  the data quality objectives (DQOs)
 for this Program.  The total barium, iron, magnesium, mercury, and thallium average
 spike recoveries were outside the DQO with values of 63, 134,  68, 50, and 74
 percent, respectively.  One of the total aluminum spike recoveries and one of the
 total iron spike recoveries were not calculated because the sample results  were
 greater than four  times the amount of spike added.  Nine individual total metal
 spike recoveries were  also outside DQO. This information is listed in  Tables 3-la
 and 3-2a  of Reference 2 as well as in  the following Sections.

      Twenty-four dissolved metals were also spiked into two samples (MQB004 and
 012).  Twenty-two of the twenty-four  dissolved metal average spike recoveries were

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 within the data quality objectives (DQOs) for this Program.  Dissolved mercury and
 thallium average spike recoveries were outside DQO with values of 50 and 68
 percent.  Eight individual dissolved metal spike recoveries from these samples were
 also outside DQO.  One each of the dissolved calcium, magnesium, and sodium spike
 recoveries  were not calculated because the sample results were greater than four
 times the amount of spike added.  This information is listed  in Tables 3-lb and 3-2b
 of Reference 2 as well as in  the following Sections.

     The calculable average  relative percent differences (RPDs) for all metallic
 anaiytes, with the exceptions of total aluminum and arsenic,  were within Program
 DQOs.  RPDs were not calculated for about two-thirds of the metal anaiytes  because
 the concentrations of many of the metals in the field samples used for the RPD
 determination were less than the CRDL and thus were not required,  or in some
 cases, not possible to be calculated.

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

     No sample contamination  involving the metallic anaiytes was reported in the
 laboratory  or field blanks.

 1.2   Furnace Metals

     The quality control for the graphite furnace metals (antimony,  arsenic,
 cadmium, lead, selenium, and thallium) was generally acceptable.

     The total  cadmium and lead and the dissolved arsenic, selenium, and thallium
 matrix spike recoveries for spiked sample MQB004 were outside DQO with values of
 140, 162, 136, 145, and 68 percent, respectively.  The total selenium, thallium, and
 lead and the dissolved arsenic, lead, and thallium matrix spike recoveries for spiked
 sample MQB012 were outside DQO with  values of 63, 36, 71,  73, 47, and 68 percent,
 respectively. All results for these metals should be considered semi-quantitative at
 best except for the total and  dissolved lead results which should be considered
 qualitative.

     The correlation coefficients for the method of standard addition (MSA) analysis
 of total antimony in sample MQA744 and total cadmium in samples MQB008, 010, and
 025 were below DQO. The correlation coefficients for the MSA  analysis of
 dissolved arsenic in samples MQA739 and 741  were also below DQO.  The total
 cadmium result for sample MQB010 and the dissolved arsenic result for sample
 MQA741 should be considered qualitative.  All other results for the samples and
 anaiytes mentioned in this paragraph should not be used.

     MSA  analyses should have been performed on total cadmium in sample MQA775
 and on dissolved lead in samples MQA773 and 783. Results for these metals in
 these samples should be considered semi-quantitative at best except for dissolved
 lead in sample MQA773 which should be considered qualitative.

     The precision  for the duplicate injection of dissolved selenium in sample
MQB012 was above DQO.  Dissolved selenium results for this sample should not  be
used.  The  analytical (laboratory) spike recovery for dissolved selenium in sample
MQB006 was below DQO.  Dissolved selenium results for this sample should be
considered  qualitative. The analytical spiked sample results for dissolved selenium
in sample MQB012 were 32 percent above the calibration range.  This had  no  affect
on data usability as the dissolved selenium result for this sample was already  judged
unusable.

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     The duplicate RPD value for total arsenic in sample MQB012 was above DQO.
Total arsenic results should be considered semi-quantitative.

     A continuing calibration verification (CCV) and a continuing calibration blank
(CCB) for cadmium were not analyzed after the analytical instrument was
recalibrated.  Both a CCV and a CCB should have been run on the recalibrated
instrument.

     CCVs were reported by the laboratory as failed in the analyses for total and
dissolved arsenic and total lead. In some cases the laboratory failed to provide
recalibration, CCV, CCB, and/or raw data.  In other cases the CCVs were not
within DQO limits.  As a result, total arsenic results for samples MQA745, 749, 750,
and MQB004; dissolved arsenic results for samples MQA749 and MQB004; and total
lead results for samples MQB013 and 014 should be considered semi-quantitative, at
best.  Also, dissolved arsenic  results for samples MQA741, 743 and MQB012 and total
lead results for samples MQA736 and MQB009 should be considered qualitative.

     Field duplicate results for dissolved cadmium in duplicate field sample pair
MQA739/MQB011  and for  total lead in pair MQA736/743 were excessive.  The
comparative precision  of field duplicate results is not used in the evaluation of
sample results.  It is not possible to determine the source of this imprecision. The
poor precision may be reflective of sample to sample variation rather than actual
sampling variations. Therefore, field duplicate precision is reported for
informational purposes only.

     All dissolved antimony  and cadmium results should be considered quantitative.
Total antimony results should be considered quantitative with an exception listed
below. AH total and dissolved antimony and total arsenic results should be
considered semi-quantitative.  Dissolved arsenic, total cadmium, and total and
dissolved selenium results, all with exceptions, should also be considered semi-
quantitative.  All total and dissolved lead results, dissolved arsenic results for
samples MQA741, 743, and MQB012, total cadmium results for samples MQB008 and
025, and dissolved selenium results for sample MQB006 should be considered
qualitative.  Dissolved arsenic results for sample MQA739, total antimony results for
sample MQA744, total cadmium results for samples MQB008 and 025, and dissolved
selenium results for sample MQB012 should not  be used. The usability of all
graphite furnace analytes is summarized in Section 4.0 and 4.1 at the end of this
Report.

1.3   ICP Metals

      The matrix spike recoveries for dissolved copper and total barium and
magnesium in sample MQB012 and total iron in sample MQB004 were outside DQO
with recoveries of 74, 27, 46, and  134 percent, respectively. As a rule, high spike
recoveries indicate a high  bias in  the data and low recoveries indicate a low bias.
Dissolved copper and  total iron results should be considered semi-quantitative.
Total  barium and  magnesium results should be considered qualitative.

      The low level (twice  CRDL)  linear range check for all dissolved beryllium,
chromium, cobalt, nickel, silver, and vanadium results and certain of the results for
total beryllium, chromium, cobalt, copper,  nickel, silver, vanadium, and zinc
exhibited low recoveries.  Also, certain of  the total manganese and all of the
dissolved zinc results exhibited high recoveries. See Section B5 of Reference 3 for
a detailed listing of analysis dates, samples affected, and biases. The low level
linear range check is an analysis of a solution with  elemental concentrations near

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the detection limit. The range check analysis shows the accuracy which can be
expected by the method for results near the detection limits. The accuracy
reported for these metals is not unexpected.

     The duplicate injection RPD for total aluminum in sample MQB012 was greater
than DQO (8290 ug/L was reported in the  initial analysis and 3980 ug/L in the
duplicate analysis). Total aluminum results should be considered qualitative.

     Sodium results for samples MQB012 and 013 exceeded the linear calibration
range. These samples were  diluted and rerun so there was no affect on the data
usability.

     Precision  results for total and dissolved aluminum and total barium, beryllium,
copper, iron, lead, magnesium, manganese,  vanadium, and zinc in field  duplicate
sample pair MQA736/743 were excessive.  The comparative precision of field
duplicate results is not used in the usability evaluation of sample results. It is not
possible to determine the source of this imprecision. The poor precision may be
reflective of sample to sample variation rather than actual sampling variations.
Therefore, field duplicate precision is reported for informational purposes only.

     All total and dissolved beryllium, calcium, chromium, cobalt, manganese, nickel,
potassium, silver, sodium, tin, vanadium, and zinc results should be considered
quantitative. Dissolved aluminum, barium, iron, and magnesium and total copper
results should also be considered quantitative.  Total iron and dissolved copper
results should be considered semi-quantitative. Total aluminum, barium, and
magnesium results should be considered qualitative. The usability of all total  and
dissolved ICP metal analytes is summarized in Section 4.2 and 4.3 at the end of this
Report.

1.4  Mercury

     It was not possible to recover the total and dissolved  mercury matrix spikes
from sample MQB012 due to unknown salt interferences.  The total and dissolved
mercury results for samples MQB012, 013, 014, and 025 were affected and should  not
be used.

     Precision  results for total mercury in  field duplicate sample pair MQA736/743
were excessive. The comparative precision of field duplicate results is  not used in
the usability evaluation of sample results.  It is not possible to determine the
source of this imprecision.  The poor precision may be reflective of sample to
sample variation rather than actual sampling variations.  Therefore, field duplicate
precision is reported for informational purposes only.

     All mercury results should be considered semi-quantitative with the exceptions
of both total and dissolved results for samples MQB012, 013, 014, and 025 which
should not be used.

2.0  Inorganic  and Indicator Analvtes

2.1   Inorganic  and Indicator Analvte PC Evaluation

     The average spike recoveries of all of the inorganic and  indicator  analytes,
except for  cyanide, were within the accuracy DQOs. Accuracy DQOs have not  been
established for  the bromide, fluoride, nitrite nitrogen, and sulfide matrix spikes.

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

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

     No laboratory blank contamination was reported for any inorganic or indicator
analyte.  TOX contamination was found in equipment blank MQBOOl and field blank
MQA738 at concentrations of 23 and 45 ug/L.  The TOX CRDL is 5 ug/L.

2.2   Inorganic and Indicator Analvte Data

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

     High levels  of sulfide in sample MQB012  appear to have interfered with  the
matrix spike recovery  of cyanide from this sample.  Therefore, cyanide results for
samples MQBOOl, 007,  and 012, which had high levels of sulfide, should not be used.
All other  cyanide results should be considered  qualitative.

     The spike recoveries for nitrate nitrogen from sample MQB012 and for sulfate
from sample MQB004 were outside DQO with recoveries of 115 and 70 percent.  All
results for these analytes should be considered semi-quantitative.  Between the
second and third CCVs of the first of  the ion chromatography (bromide, chloride,
fluoride, sulfate, and nitrate and nitrite nitrogen) analytical batche, an excessive
number of samples were run. Therefore, all ion chromatography results for samples
MQA738, 745,  750, and MQB004 should be considered semi-quantitative. The holding
times for the nitrate and nitrite nitrogen analyses ranged from 4 to 13 days from
receipt of the samples which is longer than the recommended 48 hour holding  time
for unpreserved samples. All nitrate and nitrite nitrogen results should be
considered semi-quantitative. Precision results for chloride, fluoride,  and  sulfate in
field duplicate sample pair MQA736/743 were  excessive.  The comparative precision
of field duplicate results is not used in the usability evaluation of sample results.
It is not possible to determine the source of this imprecision.  The poor precision
may be reflective of sample  to sample variation rather than actual sampling
variations.  Therefore, field  duplicate  precision is reported for informational
purposes only.  In summary,  bromide, chloride, and fluoride results, with exceptions,
should be considered quantitative.  All nitrate and nitrite nitrogen and sulfate
results and bromide, chloride, and fluoride results  for samples MQA738, 745, 750,
and MQB004 should be considered semi-quantitative.

      Precision results  for TOC in field duplicate sample pair MQA736/743 were
excessive.  The comparative  precision of field duplicate results is not  used in the
usability  evaluation of sample results.  It is not possible to determine  the source of
this imprecision.  The poor precision may be reflective of sample to sample
variation rather  than actual  sampling variations.  Therefore, field duplicate precision
is reported for informational purposes only. All TOC results should be considered
quantitative.

      Calibration verification standards for POC were not analyzed.  A POC spike
solution was run during the  analytical batch but the "true" value of the spike was
not provided by  the laboratory.  EPA needs to supply the inorganic laboratory with
a POC calibration verification solution. Until then, the instrument calibration can
not be assessed.  The POC holding time ranged from 4 to 13 days.  Although the

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 EMSL/Las Vegas data reviewers recommend a seven day holding time, the laboratory
 has been instructed by the EPA Sample Management Office that a 14 day holding
 time is acceptable.  Precision results for POC in field duplicate sample pair
 MQA739/MQB011 were excessive.  The comparative precision of field duplicate
 results is not used in the usability evaluation of sample results. It is not possible
 to determine the source of this imprecision. The poor precision may be reflective
 of sample to sample variation rather than actual sampling variations. Therefore,
 field duplicate precision is reported for informational purposes only. The POC
 results should be considered qualitative.

     The TOX matrix spike recovery from sample MQB012 was high with a value of
 128 percent.  Due to this all TOX  results should be considered semi-quantitative at
 best.  TOX contamination was found in equipment blank MQB001 and field blank
 MQA738 at concentrations of 23 and 45 ug/L.  The TOX CRDL is 5 ug/L.  As a
 HWGWTF convention, all positive TOX results five times the higher concentration or
 less should not be used, all TOX results between five and ten times the higher of
 the concentrations should be considered qualitative, and all results ten times the
 level of contamination or greater, as well as all negative results, should be
 considered quantitative (semi-quantitative in this case due to poor spike recovery).
 Therefore, TOX results for samples MQA738, 741, 742, MQA001, 006, and 012 should
 be considered semi-quantitative, TOX  results for samples MQA745 and 750 should be
 considered qualitative, and all other TOX results should not be used. Additionally,
 high chloride concentrations in samples MQA744, 745, MQB012, 013, 014, and 025
 may have enhanced the TOX concentration measured in those samples.  The TOX
 holding time ranged from 3 to  13 days. Although  the EMSL/Las Vegas data
 reviewers recommend a seven day holding time,- the laboratory has been instructed
 by the EPA Sample Management Office that a  14 day holding time is acceptable.

     Precision results for POX in  field duplicate sample pair MQA739/MQA011 were
 excessive. The comparative precision of field duplicate results is not used in the
 usability evaluation of sample results.  It is not possible to determine the source of
 this imprecision.  The poor precision may be reflective of sample to  sample
 variation rather than actual sampling variations.  Therefore, field duplicate precision
 is reported for informational purposes only. All POX results should be considered
 quantitative.

     Samples were analyzed for both carbonate and bicarbonate. The analytical
 protocols for these analytes require 24 hour holding times which are nearly
 unobtainable using the EPA contract laboratory program (CLP) shipping methods.
 Alkalinity results for these samples should be considered qualitative while the
 carbonate and bicarbonate results should no be used due to the excessive holding
 times.  The HWGWTF is Devaluating the holding time requirement.

 3.0   Organics and Pesticides

 3.1   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, with the exception of the herbicide
surrogates which  were not required or  analyzed, were within DQOs for accuracy.
Individual surrogate spike recoveries which were outside the accuracy DQO will be
discussed in the appropriate Sections below.

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

     All average surrogate spike RPDs were within DQOs for precision.  No
surrogate standard was used or required for the herbicide analysis.

     Requested analyses were performed on all samples submitted to the laboratory.

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

     Detection limits for the organic fractions are summarized in Reference  4 as
well as the appropriate Sections below.

     Organic sample identification numbers MQA025 (well L-2), 026 (well DP-1),
MQB736 (well MW4A), and  743 (well MW4A, duplicate)  correspond  to inorganic and
dioxin sample numbers MQB025, 026, MQA736, and 743. In this report the sample
numbers used  for the inorganics and dioxins will be used throughout and all organic
sample numbers will be corrected to the inorganic and dioxin numbers.

3.2   Volatiles

     The analytical laboratory exceeded the volatile holding time of seven days for
all of the volatile samples.  Holding times  ranged  from  3 to 42 days in excess of
the seven day holding time.  Negative volatile results for all samples should be
considered unreliable because of this. Positive volatile  results should be considered
qualitative.

     Acetone  contamination was found in sampling blanks 001, 100, 101, 102, 103,
104, 105, 106, 107, MQA738, MQB001, and 002 at concentrations ranging from 1 to
106 ug/L.  Additionally, acetone contamination was found in laboratory (method)
blanks MB-5  through MB-8 at concentrations of 1  to 3 ug/L.  The acetone CRDL is
10 ug/L.  The source of this contamination is not  known. All positive acetone
results should not be used due to  this blank contamination.

     Methylene chloride contamination was found in sampling blanks 103, 104,
MQA738, MQB001, and  002 at concentrations ranging from 1 to 5 ug/L.
Additionally, laboratory (method) blanks MB-1 through MB-4 and MB-6  through MB-
9 contained methylene chloride contamination.  This common laboratory contaminant
was present at concentrations of 1 to 3 ug/L.  The methylene chloride CRDL is 5
ug/L.  The source of this contamination is not known.  All positive methylene
chloride results, except those for sample MQB006, should not be used due to  this
blank contamination.

     Trichlorofluoromethane was found in sampling blank MQA738 at  a concentration
of  1 ug/L  and l-methoxy-2-propanol was found in sampling blank 001 at a
concentration of  6 ug/L. These results have no impact  on data quality  as these
compounds were  not found in any field samples.

     Estimated method  detection limits were CRDL for all samples except MQA741,
MQA005, and 012 which were 100, 20, and 33 times CRDL, respectively.  Dilution of
these samples was required due to the high concentration of organics. The volatile
compound negative results, with exceptions listed  below, should be considered
unreliable due to excessive holding times.  All positive  methylene chloride results,
except for sample MQB006, and all positive acetone results should  not be used due

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to laboratory (method) blank contamination.  The probability of false negative
results is unknown due to the lengthy holding times of the samples.  The positive
volatile results are probably not an artifact of the lengthy holding times and thus
probability of false positives is acceptable and the positive volatile results should be
considered qualitative and biased low.

3.3  Semivolatiles

     Initial and continuing calibrations, tuning and mass calibrations, matrix spikes
and matrix spike duplicates, surrogate spikes, and chromatograms were acceptable
for the semivolatiles.

     The analytical  laboratory exceeded the semivolatile 40 day holding time
between extraction and analysis for all  but two (MQB005 and 008) of the samples.
Holding times ranged from 5 to 25  days in excess of the permitted 40 day holding
time between extraction and analysis. Semivolatile results for these samples should
be considered  semi-quantitative at best.

     The acid surrogate spike recoveries for  phenol-D5, 2-fluorophenol, and 2,4,6-
tribromophenol from samples MQA778 and 778RE (its reanalysis) ranged from no
recovery to 4 percent recovery.  These results are outside DQO.  The acid fraction
results for sample MQA778 should be considered unreliable.

     Two of the semivolatile laboratory (method) blanks, MB-2 and MB-4, contained
bis(2-ethylhexyl)phthalate contamination at concentrations of 3 and 4 ug/L.  The
bis(2-ethylhexyl)phthalate CRDL is 10 ug/L.  No.positive bis(2-ethylhexyl)phthalate
results should  be  used. Cyclohexanol, 4-methylphenol, and a trichloro-1-propene
contamination was also detected in  MB-2 at concentrations of 9, 11, and 8 ug/L.  4-
Methylphenol results for sample MQB012 should not be  used due to this
contamination.

     The organic analytical laboratory failed to perform an adequate number of
semivolatile method  blank  analyses.

     The terphenyl-D14 (in sample  MQA741), 2-fluorobiphenyl (in sample MQB004),
and phenol-D5 (in sample MQA736) surrogates were out of DQO. This caused no
impact on data usability.

     Samples MQA741 and MQB012 were diluted by a factor of 10 prior to analysis.
Due to a dilution factor of 2.0 for all other samples, the estimated detection limits
for the semivolatiles were approximately twice the CRDL.

     The semivolatile data are acceptable and the results should be considered semi-
quantitative for all samples with exceptions.  Results for samples MQB005 and 006,
with the exception of the bis(2-ethylhexyl)phthalate results, should be considered
quantitative. All positive bis(2-ethylhexyl)phthalate results and 4-methylphenol
results for sample MQB012 should not be used due to laboratory blank
contamination.

3.4   Pesticides

     The analytical laboratory exceeded the pesticide 40 day holding time between
extraction and analysis for all but two (MQB002 and 014) of the samples.  Holding
times  ranged from 3 to 9 days in excess  of the permitted 40 day holding time
between extraction and analysis.

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     Dieldrin was detected in sample MQA739 at a concentration of 0.117 ug/L but
was not reported in that sample by the laboratory.

     Dieldrin and kepone were reported in sample MQB012.  These may be false
positives as the peaks specified fay the laboratory to be representative of dieldrin
and kepone had retention times slightly outside the laboratory established, retention
time windows.

     A large injection peak was present in the laboratory (method) blank
chromatograms.  This peak may have interfered  with  the detection of alpha- and
beta-BHC.

     Many pesticides in the internal standards and evaluation mixes were outside
the retention time windows established by the laboratory.

     The dibutylchlorendate retention time shift was outside DQO for 45 standards
and samples.

     Sample  MQA741 was diluted by a factor of 10 and thus the detection limit for
the pesticide fraction in this sample is 10 times  the CRDL.  The estimated  method
detection limits  for all other pesticides analyses  is the CRDL. The pesticides
results should be considered qualitative with the exceptions of samples MQA739, 741,
and MQB012 which should be considered unreliable.

3.5  Herbicides

     The herbicides for which the laboratory analyzed include only 2,4-D, 2,4,5-T,
2,4,5-TP, chlorobenzilate, phorate, disulfoton, parathion,  and famphur.

     No surrogates were included for the chloro- or phospho-herbicide results.

     The quality of the chloro-herbicides chromatograms was not sufficient  to allow
the tentative identification and confirmation of these compounds.  Several field
samples were reported to contain  chloro-herbicides. However, numerous chloro-
herbicide peaks were observed in the method, field, and  trip blank chromatograms.
The tentative identification and quantification of chloro-herbicides in all samples
should be considered unreliable due  to this blank contamination.

     The detection (DBS) and confirmation (DB1) columns used by the laboratory for
the phospho-herbicide analyses were too similar  to allow adequate confirmation.
Because of this all positive phospho-herbicide results  (only disulfoton and parathion
results reported for sample MQA741) should  be considered unreliable.  Negative
phospho-herbicide results should be considered qualitative.

     The laboratory failed to use  the 3-point external standard calibration method
for all herbicides. A one point method was used.

     Method 8150 is not adequate for the determination  of chlorobenzilate.
Chlorobenzilate could be more accurately determined by  using the pesticide method.
Chloro-herbicide standard chromatograms were specified by the laboratory to be
representative of the four chloro-herbicides for  which the laboratory analyzed.
However, five peaks were observed in the chromatograms.  The fifth peak may have
arisen from the  derivatization of  chlorobenzilate.  There is the  possibility that both
the methyl and ethyl esters of chlorobenzilate are formed when  using Method 615.

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     The negative phospho-herbicide results should be considered qualitative due to
the lack of surrogates.  The positive phospho-herbicide results should be considered
unreliable due to the lack of surrogates and inadequate confirmational column
analysis.  The chloro-herbicide results should be considered unreliable due to blank
contamination and the absence of surrogate analyses. The estimated method
detection limits were the CRDL for the herbicides.

3.6   Dioxins and Dibenzofurans

     Dioxin and dibenzofuran spike recovery from the two native spiked samples
ranged from 88 to 136 percent which is considered to be acceptable accuracy.  One
of these samples was inadvertently spiked twice.  No performance evaluation
standard  was required or evaluated for dioxins and  dibenzofurans. The target
analytes were detected in the duplicate field samples for monitoring well 4A so
precision (RPD) information was available for these samples.  Target analytes were
not detected in the laboratory duplicate samples so laboratory precision could  not
be evaluated.  Required dioxin/dibenzofuran analyses  were performed on all samples
submitted to the laboratory.  No dioxin or dibenzofuran contamination was found in
the laboratory (method) or field blanks.  Diphenylether interference (at m/z ratio
410) was  observed in the PeCDF window for sample MQQA736.

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

     The recovery of the internal standard for-carbon-13 labeled 2,3,7,8-TCDD from
one of the standards was above DQO.

     The resolution between carbon-13 labeled 1,2,3,4-TCDD in the recovery
standard  and 2,3,7,8-TCDD in  the internal standard  was above DQO.

     Samples MQA736, 739, 742, MQB003, 004, 006,  012, 025, and method blank
CC# 120767 did not meet the DQO requirement for resolution of the percent valley
being less than or equal to 25 percent. The results for these samples should be
considered semi-quantitative at best.

     The dioxin and dibenzofuran results should be considered to be semi-
quantitative. The probability of false negative results is acceptable.  OCDD, TCDF,
PeCDF, HxCDF, HpCDF, and OCDF were detected in  the duplicate field samples
collected from well 4A.

-------
                                 -154-
III.  Data Usability Summary

4.0  Graphite Furnace Metals. Total

Quantitative:        antimony results with exceptions
Semi-quantitative:   all arsenic and thallium results; cadmium and selenium
                    results with exceptions
Qualitative:         all lead results; cadmium results for sample MQB010
Unusable:           antimony results for sample MQA744; cadmium results for
                    samples MQB008 and 025

4.1   Graphite Furnace Metals. Dissolved

Quantitative:        all antimony and cadmium results
Semi-quantitative:   all thallium results; arsenic and selenium results with
                    exceptions
Qualitative:         all lead results; arsenic results for samples MQA741, 743,
                    and MQB012; selenium results for sample MQB006
Unusable:           arsenic results for sample MQA739; selenium results for
                    sample MQB012

4.2  ICP Metals. Total

Quantitative:        all beryllium, calcium, chromium, cobalt, copper,
manganese, nickel, potassium, silver, sodium, tin,                        vanadium,
and zinc results
Semi-quantitative:   all iron results
Qualitative:         all aluminum, barium, and magnesium results

4.3   ICP Metals. Dissolved

Quantitative:        all aluminum, barium, beryllium, calcium, chromium, cobalt,
                    iron, magnesium, manganese, nickel, potassium, silver,
                    sodium, tin, vanadium, and  zinc results
Semi-quantitative:   all copper results

4.4  Mercury

Semi-quantitative:   mercury results with exceptions
Unusable:           total and dissolved mercury results for samples MQB012,
                    013, 014, and 025

4.5  Inorganic and Indicator Analvtes

Quantitative:        all sulfide, total phenols, TOC, and POX results; bromide,
                    chloride, and fluoride results with exceptions
Semi-quantitative:   all nitrate and nitrite nitrogen and sulfate results;
bromide, chloride, and fluoride results for samples MQA738,
745, 750, and MQB004; TOX results for samples MQA738, 741,                 742,
MQB001, 006, and 012
Qualitative:         all POC and alkalinity results; cyanide results with
                    exceptions; TOX results for samples MQA745 and 750

-------
                                  -155-
Unusable:
4.6  Oreanics
Quantitative:
                     TOX results with exceptions; cyanide results for samples
                     MQBOOl, 007, and 012; all carbonate and bicarbonate results
                     semivolati\e results for samples MQB005 and 006 with
                     exceptions listed below
Semi-quantitative:    semivolatile results with exceptions
Qualitative:          positive volatile results; pesticide results with
exceptions; phospho-herbicide results with exceptions
Unreliable:           negative volatile results with exceptions;  pesticide
results for sample MQA739, 741, and MQB012; all chloro-
herbicide results; disulfoton and parathion (phospho-                     herbicides)
Unusable:            all positive methylene  chloride (a volatile) results,
except for sample MQB006; all positive acetone (a volatile)
results; 4-methylphenol (a semivolatile) results  for sample
MQB012; all  positive bis(2-ethylhexyl)phthalate (a
semivolatile) results

4.7   Dioxins and  Dibenzofurans

Semi-quantitative:    all dioxin and dibenzofuran results

-------
                                  -156-

IV.  References

1.    Organic Analyses:   EMSI
                        2421 West Hillcrest Drive
                        Newbury Park, CA 91320
                        (805) 388-5700

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

     Dioxin/Dibenzofuran Analyses:
                        CompuChem Laboratories, Inc.
                        P.O. Box 12652
                        3308 Chapel Hill/Nelson Highway
                        Research Triangle Park, NC  27709
                        (919) 549-8263
2.    Draft Quality Control Data Evaluation Report (Assessment of the Usability of
the Data Generated) for Case G-2363HQ, Site 49, Rollins, NJ, 5/26/87, 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, for Case G-2363HQ, Rollins
Environmental, NJ, Prepared by Laboratory Performance Monitoring Group, Lockheed
Engineering and Management Services Co., Las Vegas, Nevada, for US EPA,
EMSL/Las Vegas, 5/27/1987.

4. Draft Organic Data Usability Audit Report, for Case G-2363HQ, Rollins, NJ,
Prepared by Laboratory Performance Monitoring Group, Lockheed Engineering and
Management Services Co., Las Vegas, Nevada, for US EPA, EMSL/Las Vegas,
5/27/1987.

5. Draft PCDD/PCDF (Dioxin/Dibenzofuran) Usability Audit Report, for Case G-
2363HQ, Rollins Environmental, NJ, Prepared by Laboratory Performance Monitoring
Group, Lockheed Engineering and Management Services Co., Las Vegas, Nevada, for
US EPA, EMSL/Las Vegas, 5/21/1987.

-------
                                  -158-
Page No.
02/09/87
                   ROLLINS ENVIRONMENTAL SERVICES (N!J) .  INC.
                                GHDP INVENTORY
                                  BY L NUMBER
WfiSTE ROW OTY LOB     MANIFEST
CODE          NUMBER
TOTftL  GTY BTU
POUNDS REC
REC
                                                          TRTMENT COMMENT
10014
10019
10063
10076
10130
10147
10137
4146
4571
5110
5110
5122
5122
5122
5152
5256
5359
5381
5415
5552
5603
5667
5706
5752
6215
6216
6271
63OO
6321
6321
6323
6366
6402
,648O
648O
6551
66 1O
6610
6674
6715
6763
6763
6769
6769
6769
6821

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14



11
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15
17
13
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17
5
10
18
14
17
8
7
8
13
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3713
0222
3915
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1883
7783





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276
3621

429
3O37


6721



294
493



4157




3786
                             NJQ0204254 5OOO    10  930O  E
                             NJ00203687 1665    5   139OO V
                             NJftO 193942 200(1)0   46  2000  E
                             PftB2919921 328O    11  159OO V
                             NJft0250S37 1335O   21  64OO  E/R/
                           502
                             NJftO168571 63O
                             N/O        ISO
        1    2OOO  R/K
        1    SOOO  V
                             N/0
N/fi
                                         1    2OOO  R/K
                             NJW023SO6S  5222   i->  3.6900 V

                             N/ft         N/fl    N/tt 117OO R/K
                             NOJO178352  32497  72  151OO R/K
                             NJO0239354  122S   £9  30OO  T'/K

                             NJftO134433  1698O  77  11735 R/K
                             NJ00167158  412    1   93OO  V
                             NJOO16685O  1834   64  2OOO  V
                             NJOO121825  7O45.
                             MJOOO84128  1069£
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        23   157OO V
                                             230OO R/K
                             NJ0018O220 548
            4700  V

-------
                                    -159-
Page No.      £
OS/09/87
L#
           ROLLING ENVIRONMENTAL SERVICE'S (NJ).  INC.
                         GHDP INVENTORY
                           BY L NUMBER

WRSTE ROW QTY  LflB    MANIFEST   TOTftL   CITY BTU   TRTMENT  COMMENTS;
CODE           NUMBER            POUNDS REC
                                 REC
V
6823
6861
6899
6899
6933
6972
6973
6973
7O10
7O1O
7143
7170
7185
7330
7372
7387
7428
7483
7484
7484
7487
7489
7492
7497
75O6
75O6
7519
7555
756G
757O
7571
7571
757 1
7571
7-577
7594
7596
76O7
7612
7612
7621
7632
7640
7650
7656
7656

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2140O R/K


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-------
                                     -160-
Pagtj No.
02/O9/87
                   ROLLINS ENVIRONMENTAL SERVICES  (NJ).  INC.
                                GHDP INVENTORY
                                  BY L NUMBER

       WOSTE  ROW  QTY LflB    MANIFEST   TOTttL   QTY BTU   TRTMENT COMMENTS
       CODE           NUMBER            POUNDS  REG
                                        REC
7657
7658
7658
7662
7666
7669
7671
7679
7685
7685
7686
77O3
7703
7726
7733
7738
7742
7765
7770
7775
7811
7816
7818
7B38
7838
7838
7855
7866
7866
7866
7867
7868
7868
7869
7869
7869
7872
7872
7872
7896
7926
7953
7954
7956
7967
7967


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12
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11
17
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5
11
13
13
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13
£
3
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9
9
11
2
11
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17
17
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3871
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-------
-161-
Page No.
02/09/87
5
ROLLINS ENVIRONMENTfiL SERVICES
GHDP INVENTORY

-------
Page No.
02/09/87
                                    -162-
                  ROLLINS ENVIRONMENTAL SERVICES
                                GHDP INVENTORY
                                  BY L  NUMBER

-------
    •  . '                 '          -163-
Page No.     7
02/09/87
                  ROLLINS  ENVIRONMENTflL SERVICES (NJ) .  INC.
                                GHDP INVENTORY
                                  BY L NUMBER

L#     WflSTE ROW QTY LflB    MflNIFEST   TOTflL  QTY BTU   TRTMENT COMMENTS
       CODE          NUMBER             POUNDS REC
                                        REC
fc
8965
8971
9O47
9091
9117
9151
9189
9£42
9£42
9243
9£49
9249
9287
9288
9311
9311
9352
9409
9409
9409
9442
9456
9475
9485
9486
9486
9521
9533
9556
959O
9607
96O8
9612
9527
9627
9627
9,640
9642
9642
9741
9742
9746
975O
9797
9797
9812

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16
16
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13
18
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7
11
7
11
7
15
15
16
18
7
12
2
£
a
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13
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4
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9
12
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14
6
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18

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4046
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-------
Page No.
02/03/87
6
                                     -164-
     ROLLINS ENVIRONMENTflL SERVICES
                  GHDP  INVENTORY
                    BY  L  NUMBER
                                                   (NJ) .  INC.
L#     WftSTE  ROW  QTY  LflB    MANIFEST   TOTflL  CITY  BTU    TRTMENT COMMENTS
       CODE           NUMBER            POUNDS REC
                                        REC
9845 T
9893 X
9893
9929 I
9973 I
B2358
H20
H2OFM
J1OO
NJDEP
NJDEP
NJDEP
TflC4£
UN50O
UNK
UNK17
UNK2
UNKA6
UNK46
UNK5
UNK55
UNK6
UNK6
UNK8
UNK8
UNK99
W H£O
WttDE
WftDE
WfiDE
WODE
WftDE
«•** Total
7
3
18
18
18
16
7
13
17
12
IB
17
5
16
8
13
9
11
15
12
15
11
13
8
11
18
8
12
13
14
15
18
***
1 £813
1 3484
£
£ 35OO
£ 334O
3-
1
2
1
4
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1
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                  •***

-------
-165-
Page No.
02/09/67
3



ROLLINS ENVIRONMENTAL SERVICES


L# WASTE
CODE

9181
9181
9181
9iS3 P
9189
S258
9287
9311
935O
9537 T
9554
9598
9658 N
9687 T
9823 I
9823
9852
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TYPE ROW
DRUM

4
4
6
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6
5
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FIBER 5
FIBER 5
4
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FIBER 6
FIBER 5
4
5
DRUM PAD INVENTORY
BY 1. NUMBER
LfiB MANIFEST TOTAL
NUMBER POUND
REC.



2351 NJftO. 127433 1576O





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358 £000 K





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                           TRTMENT  COMMENTS

-------
-166-
Page No.
02/09/87



L# WftSTE
CODE

8028
8i£l
8127
8.182
818£
8278
83O2
8310
8337
8339
8339
8339
8347
8372
8402
842O
8420
8444
8456
8480
848O
8500
6584
864O
6663
8677
8716
8718
872G
8741
8743
8769
8778
8791
8890
8«9O
8903
89O5
8938
8963
9023
9048
9O85
9085
9121
9135 C
2

ROLL


TYPE ROW
DRUM

FIBER 3
-~i
l_
6
o
iH
o
6 .

1
7
5
6
7
1
ij.
5
2
4
6
4
1
6
;2
£1
4
2
6
4
5
FIBER 3
7
iZ.
G
.6
iZ.
O
6
G
4
6

5
4
FIBER 1
FIBER 3
6



INS ENVIRONMENTflL SERVICES
DRUM PflD INVENTORY
BY L NUMBER
LfiB MANIFEST TOTfiL
NUMBER POUND
REG.



INNERPLflNT


N/O N/O N/ft











3678 NJO0055206 36650



5881 95OO
6O37 INNER PLttN flLL.


6O65 NJOOO65753 9OO
4972 NJfiOO 14438 13.1 GO





2445 NJftO 166224 42OO
3??O3 NJflO£02846 16251





1168 NJft018O187 19O8



23O8 NJOO 164228 4OO
0224 NJ00239774 N/tt


(NJ). INC.


QTY BTU TRIM
REC




1 14400 K


N/R N/fl R/K





/ '
4





62 6500 V



2 8OOO R/K
fiLL £1000 K


2 150O R/K
B 9500 R/K





14 2OOO R/K
221 N/tt I'v/t:





4 16300 K



1 2OOO R/K
15 1180O R/K
                                TRTMENT COMMENTS
                                          INTIIRPL

-------
-167-
Page No.
02/09/87
1
ROLLINS ENVIRONMENTOL SERVTCES
DRUM POD INVENTORY
(NJK
INC.

BY L NUMBER
L# WOSTE
CODE
j_
10026 T
10053 P
10076
10076
10114
4047
4149
4493
4619
525O X
5252
5608
5799
6097
6215
6215
6216
6321
61500
6618
6769
6850 I
6899
7178
7386
7389
7455
7539
7577
7587 T
7588
7588
7628
7659
7685
77O3
i

7706
7706
7725
7803 C
7867
7869 I
7886
""7 f^ rt cr
TYPE
DRUM


FIBER


STEEL
FIBER

FIBER





FIBER




FIBER








FIBER

FIBER
FIBER
FIBER





FIBER
FIBER

POILS



ROW


2
5
•*-|
L..
5

3-

3
6
5
£
2
•2
3
5
6
6
4
1
1
6
6
2
4
4
5
5
3
4
3
5
5
.tv
6
1
7

1
3
6
5
6
a
2
LOB
NUMBER

3759
3731
3915


0288
O052
020 1
3962
3977



3974
3620

3621
OOG7


1 558
396O







3726
1749


1958
3871
3394



7637
1750
3782
2O62
1693
MONIFEST


NJOO 140803
NJOO 132228
NJOO 193942


NJ002O1885
NJOO23S88
N/O
NJOO 193475
NJ001£70£5



NJOO 1934 15
NJ00239354

NJO0239354
NJOO 137746



NJOO 13475







NJOO 132228
NJOO 132227


NJOO2123O7
N/fl
NJ00223132




NJOO 132227
NJOO 182456
NJOO 151 007
NJOO 183976
TOTOL
POUND
REC.
530
60
2020O


2024O t
1498O*
572 .
5346
i 350



3070
1557;:1

1225
N/O


20OO
738







346
1202


1 800
N/O
12312



200O
239
1 3055
274
23140
QTY
REC

1
4
JL



88
33
4
33
13



14
L.'. ^J

29
.1.


4
4







i
5


9
IS
27



8
5
40
1
i'-
BTU


1 1 200
2000
2(500


4OOO
1O7OO
4400
139OO
166OO


4
104OO
111OO

3000
78OO


1 7OO
2OOO







47OO
137OO


920O
SO 00
154 GO



4600

111 OO
137OO
62OOO
TRTMENT COMMENTS


V
K
tv


KILN
R/K 3DR/HR
K
K
V



K
R/K
•
R/K
V


R/K
V







V
K


K
V
V OCRYLONIT
R


K
R/K
R/K LOBCDVERO
G
R/K
V

-------
                                                               -168-
 J.  EQUIPMENT —  Complete the following table for each piece of equipment involved in the use, manufacture, storage, handling, or generation of the
    EHS as described in Section E2. Equipment should include all storage and process vessels. Use the codes indicated on the bottom of Page 2 where
    necessary.
EQUIPMENT
DESCRIPTION
l. Storage Tank
2. Storage Tank
. 3. Storage Tank
1 4. Storage Tank
5. Storage Tank
6. Storage Tank
Tank Trailer
7- Unloadi nq Pump
Incinerator
8- Feed Pump
9, Storage Tank
10. Tank Pump
DESIGNATION
"rioi^
noz.""* .
Vf303
* T304' *
T308
T310
P301/302
P307/308
T323
P362
DISTANCE TO
NEAREST
PROPERTY LINE
(Ft.)
280
295
250
280
370
390
280
280
810
810
EQUIPMENT SIZE
Captclty
7000
7000
20000
20000
30000
20000
NA
NA
150,000
NA
Avenge






240
50


Maximum










Unit.
GAL
GAL
GAL
GAL
GAL
GAL
GPM
GPM
GAL
GPM
AGE
OF
EQUIPMENT
lYri.l
8
.8
8
8
1
7
3
3
2
7
EXISTING
AIR POLLUTION
CONTROL DEVICE
Pipe Away Con-
servation Vent
Pipe Away Con-
servation Vent
Pipe Away Con-
servation Vent
Pipe Away Con-
servation Vent
Pipe Away Con-
servation Vent
Pipe Away Con-
servation Vent
NA
NA
Carbon Absorp-
tion Unit '
NA
PERMIT OR !
CERTIFICATE NO
68328 j
68328 f
68328
68328
68328
68328
NA
NA
68328 :
i
j,





NA
COMMENTS




<





                                                                                                                                                  fe

                                                                                                                                                  I
                            T 3M


                           T">O J
Jo ,000
  .t.
Ax— ,\f>r.
                                                      310, 3u, »-«,  T.oj}

-------
                                          -169-
                                 TANK FARM PPMP/QAITGE SHEET
                                                                  DAI BUDIHQ 2300:.2Ll'
I  TANK  ! GALLONS/  I
INPMBER,
i
         PERCENT  J
                       CONTENTS
                   I
                                         2300
                                           » Gal.
                                           I
                      0700
                       I Gal
              1500
               I  Gal
                                                                                  2;
                                                         I
I  T-301
            60
                                           I
                                                        !
                                     i /»r i
XJfc
    3O2
            60
                   \\
           200
                                                               -LJ
           200
                                                                      i/oyoo j  
-------