August 1986                EPA-330/2-86-009
      ^Hazardous Waste Ground-Water
       Task Force
       Evaluation of
       GSX Services  of South Carolina, Inc
       Genstar Corporation
       Pinewood, South Carolina
                           g S. Environmental Protection Agency
                           Region 5, library JPI-12J)
                           77 West Jackson Boulevard, IZtn
                           Chicago,"- 60604-3590
&EPA
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

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                              August 6, 1986
        UPDATE OF THE HAZARDOUS WASTE GROUND-WATER TASK EVALUATION
             OF GSX SERVICES OF SOUTH CAROLINA, INC.  FACILITY

     The United States  Environmental  Protection Agency's Hazardous Waste
Ground-Water Task  Force ("Task  Force"),  in conjunction  with  the South
Carolina Department of Health and Environmental Control (SCDHEC), conducted
an evaluation of the ground-water monitoring program at the GSX Services of
South Carolina, Inc.  hazardous  waste disposal  facility.   The onsite field
inspection was  conducted over  a 2-week period  from October 29 through
November 7, 1985.   GSX  is one of 58 facilities that  are being evaluated by
the Task Force.  The GSX facility is  located approximately 40 miles south-
east of Columbia,  South Carolina near the towns  of  Pinewood and Rimini.

     The purpose of the Task Force evaluation was to determine the adequacy
of GSX's  ground-water monitoring system in  regard  to State and  Federal
ground-water monitoring requirements.  Specifically, the  objectives of the
evaluation at GSX  were to:

          Determine compliance with the State equivalent of 40 CFR Part 265
          interim status ground-water monitoring requirements

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

          Determine  if  hazardous or  hazardous waste  constituents  have
          entered  the ground-water at the facility

          Provide  information to assist EPA in determining if the facility
          meets EPA requirements for waste management  facilities  receiving
          waste from Federal Superfund response actions

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     Although GSX has completed some aspects of the requisite hydrogeologic
investigation,  a  number of critical elements  are  missing.   The facility
must  provide additional  information  regarding the  local  stratigraphy,
hydraulic gradients  and hydraulic interconnection of various  zones.  The
above information must be known before the adequacy of the number, placement
and  screened intervals  of the wells which  make up the GSX  ground-water
monitoring system can be affirmed.

     On January 16,  1986,  GSX submitted the previously omitted section of
its Part B application that addressed the South Carolina State ground-water
monitoring requirements  [R.61-79.270.14(c)].   The  revised application has
been  reviewed by  SCDHEC and  EPA and was  found  to be deficient.  On July 7,
1986, SCDHEC  issued  a Notice of Violation and a Notice of Deficiencies to
GSX.  GSX is required to respond to this Notice of Deficiencies on or before
August 8, 1986.   The Notice  of Violation contains a draft administrative
consent order that requires,  among other things, that GSX conduct a  hydro-
geologic study to fully characterize the uppermost aquifer at the facility.

     The analytical  results  of the ground-water samples collected by the
Task Force show the presence of trace concentrations of nickel in six moni-
toring wells  and  the French drain.  No other hazardous waste constituents
were positively identified in the samples.

     In a meeting on June 16, 1986, GSX notified SCDHEC that the presence
of trace amounts of volatile organics (trans 1,2-dichloroethylene at 11 ug/L,
and 1,2-dichloroethane  at 10  MS/I-) had been confirmed in samples collected
from  an old  monitoring  system well, 2D.  Subsequent sampling of monitoring
wells and piezometers in the  area of well 20 has not revealed any organics
in any of the new monitoring  system wells.  To date, the highest organic
concentrations have  been measured in an  unused production well  (PW-4) that
appears to be upgradient of the regulated units.  On June 30, 1986, GSX and
SCDHEC entered into an Administrative Consent Order that governs the imple-
mentation of an expanded ground-water quality assessment program to determine
the rate and extent  of  the contamination, the  source of the  contamination,
and remedial action alternatives.

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     An expanded  assessment  plan was  submitted to  SCOHEC and Region IV EPA
on July 1, 1986 and, as amended July 15, was approved by SCDHEC on July 24,
1986.

     The three phase plan has been implemented and interim progress reports
are  due on August 29,  1986 and October  15,  1986.   A  final  report  is  due on
December 15,  1986.   Currently, there  appears to be no immediate threat to
public health or the environment.

     The violations regarding the erosion of the cover for Section I, cell E,
and  the grid map  problem noted during the Task Force inspection have been
referred to SCDHEC for action.

     This completes  the Hazardous Waste Ground-Water Task  Force evaluation
of the GSX Services of South Carolina, Inc.  facility.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUND WATER TASK FORCE
EPA-330/2-86-009

GROUND-WATER MONITORING EVALUATION

GSX SERVICES OF SOUTH CAROLINA, INC.,
GENSTAR CORPORATION
Pinewood, South Carolina

August 1986
Alan E. Peckham
Project Coordinator
National Enforcement Investigations Center

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                                 CONTENTS


EXECUTIVE SUMMARY

INTRODUCTION 	     1

  BACKGROUND 	     3

SUMMARY OF FINDINGS AND CONCLUSIONS  	     8

COMPLIANCE WITH INTERIM STATUS GROUND-WATER MONITORING - R.61.79.265
  SUBPART F	     9

  GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS  	     9
    Ground-Water Monitor System  	     9
    Site Hydrogeology  	     9
    Ground-Water Sampling and Analysis Plan  	     9
    Ground-Water Assessment Program  	    10
    GSX Contractor Laboratory Evaluation 	    10

  GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT 	    10
  TASK FORCE SAMPLING AND MONITORING DATA ANALYSIS 	    11
  FACILITY OPERATION 	    11
  COMPLIANCE WITH SUPERFUND OFFSITE POLICY 	    13


TECHNICAL REPORT

INVESTIGATIVE METHODS  	    13

  RECORDS/DOCUMENTS REVIEW AND EVALUATION  	    13
  FACILITY INSPECTION  	    14
  LABORATORY INSPECTION  	    14
  GROUND-WATER, SURFACE WATER AND LEACHATE SAMPLING
    AND ANALYSIS	    14

WASTE MANAGEMENT UNITS AND OPERATIONS  	    16

  WASTE MANAGEMENT UNITS	    16

    Landfills	    16
    Treatment	    22
    Storage	    23

  FACILITY OPERATIONS  	    23

    Leachate Collection  	    23
    Incoming Hazardous Waste Handling  	    24
    Maintenance of Landfill Cover  	    26

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                             CONTENTS (cont.)


SITE HYDROGEOLOGY	    28

  HYDROGEOLOGIC UNITS  	    28
  GROUND-WATER FLOW	    30

GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS  	    33

  REGULATORY REQUIREMENTS  	    33

    Permit IWP-145 	    34
    R.61-79 Part 265, Subpart F	    34

  GROUND-WATER SAMPLING AND ANALYSIS PLAN  	    38

    November 17, 1981 SAP	    38
    August 25, 1983 SAP	    38
    October 25, 1985 SAP	    38

  MONITORING WELLS 	    39

    Well Construction - Old System   	    39
    Well Construction - New System	    44
    Well Locations  .....'	    48

  GSX SAMPLE COLLECTION AND HANDLING PROCEDURES  	    48

  GROUND-WATER ASSESSMENT PROGRAM AND OUTLINE  	    49

    Section I	    49
    Section II	    50
    Ground-Water Assessment Results  	    50

  GROUND-WATER STUDY PLAN  	    51

GROUND-WATER MONITORING- PROGRAM PROPOSED FOR RCRA PERMIT	    52

  TASK FORCE SAMPLE COLLECTION AND HANDLING PROCEDURES 	    52

GSX LABORATORY EVALUATION  	    59

  ONSITE LABORATORY FINDINGS 	    59

  CONTRACTOR LABORATORY FINDINGS 	 .....    60

  MONITORING DATA ANALYSIS FOR INDICATIONS OF WASTE RELEASE  	    64


REFERENCES

                                     a

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                             CONTENTS (cont.)
APPENDICES
A    TASK FORCE ANALYTICAL RESULTS
B    LANDFILL EXCAVATION AND OPERATIONAL PLANS

FIGURES

 1   Pinewood Location Map 	      4
 2   Waste Management Areas  	      5
 3   Ground-Water Monitoring Well Locations  	     29
 4   Ground-Water Monitoring Well Location (Old System)  	     40
 5   Ground-Water Monitoring Well Location (New System)  	     41
 6   Typical Well Construction (Old System)  	     45
 7   Typical Well Construction (New System)  	     47


TABLES

 I   Industrial Landfill Permit IWP-145 Parameters 	     35
 2   SCDHEC Minimum Analysis 	     35
 3   SCDHEC Comprehensive Analysis 	     36
 4   Proposed Secondary Drinking Water Parameters  	     36
 5   Interim Primary Drinking Water Standards  	 .     37
 6   EPA Parameters Establishing Ground-Water Quality  	     37
 7   EPA Parameters Used as Indicators of
     Ground-Water Contamination  	     38
 8   Wells Designated for Ground-water Monitoring During
     Interim Status at the GSX Facility	     42
 9   Monitoring Well Construction Data (Old System)  	     43
10   Monitoring Well Construction Data (New System)	     46
11   Statistical Differences for Section II Wells  	     50
12   Sample Collection Data	     53
13   Locations and Receivers of Samples Other Than GSX	     54
14   HNU Readings at Leachate Collection Sump	     57
15   Order of Sample Collection, Bottle Type and Preservative
       List	'	     57
16   Location of Field Blanks	     58
17   Analytical Procedures 	     62
                                    iii

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EXECUTIVE SUMMARY

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                               INTRODUCTION

     Concerns have  recently been  raised about whether  hazardous waste
treatment, storage  and  disposal  facilities (TSDFs) are In compliance with
the ground-water  monitoring requirements  promulgated  under the Resource
Conservation and Recovery Act (RCRA)*.  Specifically, the concerns focus on
the ability of ground-water monitoring systems to detect contaminant releases
from waste management units at TSDFs.  In response to these concerns, the
Administrator of  the  Environmental  Protection Agency (EPA) established a
Hazardous Waste Ground-Water Task Force (Task Force) to evaluate compliance
at TSDFs  and address  the cause(s)  of noncompllance.   The Task Force  is
comprised of personnel  from the EPA Office of  Solid Waste and Emergency
Response  (OSWER), the National  Enforcement Investigations Center  (NEIC),
EPA Regional  Offices  and  State  regulatory agencies.  To determine the
status of compliance, the  Task Force is conducting in-depth onsite inves-
tigations of TSDFs.

     The objectives of these evaluations are to:

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

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

          Determine if the  ground water  at the  facility  contains  hazardous
          or hazardous waste constituents
     Regulations promulgated under RCRA address hazardous waste management
     facility operations,  including ground-water monitoring, to ensure that
     hazardous waste  constituents are not released to the environment.

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

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

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

          Designated RCRA- and/or State-required monitoring wells are prop-
          erly located and constructed

          Required analyses  have been conducted  on  samples  from  the  desig-
          nated RCRA monitoring wells

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

          Recordkeeping and  reporting procedures for  ground-water monitor-
          ing are adequate

     The GSX Services  of South Carolina-Genstar Corp.,  Pinewood facility
(GSX) onsite inspection  was  conducted from October 29 through November 7,
1985.  The  inspection was coordinated  by personnel  from  NEIC,  a field
component of  the Office  of  Enforcement and Compliance Monitoring.   In
general,  the evaluation  involved  a review of State,  Federal and facility
records,  a facility  inspection, a laboratory evaluation and ground-water
and landfill  leachate sampling and analysis.
     EPA policy, stated  in the Way 6, 1985 memorandum from Jacfc McGraw on
     "Procedures for Planning  and Implementing Offsite Sesponse", requires
     that TSDF's receiving CERCLA  wastes be in compliance with applicable
     RCRA ground-water monitoring requirements.

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BACKGROUND

     The GSX  Pinewood facility is located approximately 40 miles southeast
of Columbia, South Carolina near  the towns of Pinewood  and  Rimini [Figure 1].
The site is bordered  by agricultural land and is adjacent to and hydraulically
upgradient of  Lake  Marion, a major recreational  lake.   Mining of opaline
claystone and  waste  disposal  are  the principal  operations  conducted at the
site.

     The origin  of  the site is rooted  in the discovery of large opaline
claystone deposits  in the area.  The material,  after processing (drying,
crushing and sizing), is commonly known as fuller's earth or, more generic-
ally,  "kitty  litter".  During mining, a surficial  sand layer  is removed to
expose the claystone.  The opaline claystone is underlain by sands, silts
and  clays  of  the  Sawdust Landing  member of the Rhems  formation.   The
Sawdust Landing is, in turn, underlain by sands and clays of the Upper Black
Creek Formation, the  regional aquifer.

     The facility covers  approximately  276 acres, of which 25 acres is a
landfill known as Section  I,  which  has  undergone partial closure.   Part of
the remainder  of the  site  is devoted to the mining and  processing of opaline
claystone.   The  excavations produced by mining  are used as  landfill  areas.
The  total  landfill  area  including all  of Sections I  through  IV is 125
acres.

     Hazardous waste  activities at GSX  include the landfill operations, a
drum storage area,  drummed and bulk liquid solidification, and burning of
waste oil which is regulated by the State.  Two distinct landfill areas are
located at the site  [Figure 2].  The oldest, Section  I, has  five  cells
which have undergone  partial  closure (cells  A  through E).  The operating
area, Section  II, has two  cells in  the  process  of partial  closure (cells A
and B), a cell in operation (cell C), a proposed cell (cell D)  and a series
of proposed future cells.

     Mining of the claystone  began in  1972  by Bennett Mineral Company
(Bennett) under  a  lease agreement with  a  local  farmer. In July 1977, an

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             Figure 1
         LOCATION  MAP
          GSX Services
Pinewood, South  Carolina Facility
      Scale:
                     10     20
                    miles

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application  for  waste disposal  was submitted  by  Bennett to the  South
Carolina  Department  of Health  and Environmental Control  (SCDHEC).   The
concept was  to  utilize off-specification fuller's earth  as  an  absorbent,
mix it with  waste,  and place this  mixture  in  the mined-out  excavation to
act as fill  material  during reclamation of  the mined area.   A layer of
undisturbed  claystone  is  left in place in the bottom of the excavation to
act as  a barrier to  downward liquid movement.  Since  the sides  of  the
excavation were  within the  claystone formation it  was assumed lateral
movement would also be impeded.

     An Industrial Waste  Permit (IWP-145)  was issued by SCDHEC to Bennett
in November 1977, and disposal of hazardous waste began.  Bennett handled a
relatively small  amount of  waste before the  operation was  obtained by
Services  Corporation  of America  (SCA)  in  April  1978.  SCA  obtained  the
lease and began  to  renovate the  Bennett disposal area by digging up the
buried waste  and  placing  it in  a  newly constructed  lined trench.   SCDHEC
transferred  Permit IWP-145  to SCA in April  1978 and re-issued  it  in  July
1979.

     SCDHEC  was  granted RCRA Phase I interim authorization in February
1981,  which  allows  the State to  enforce  State-promulgated regulations
(R.61-79.124 through R.61-79.270) in lieu of Federal  regulations promulgated
under RCRA (40 CFR Parts 260 through  263 and 265).   RCRA  activities at the
site have, therefore, been effectively governed by State regulations  except
for a 3-month dual  Federal-State regulation period (November 1980 through
February 1981).

     Phase II, A and B interim  authorization was granted  in  November  1982,
allowing the  State to  issue RCRA permits  for  storage in tanks and con-
tainers and for treatment in tanks and by incineration.  The State received
final  authorization on November 8,  1985 for  all  aspects of RCRA except for
the 1984 amendments.

     A Part  B RCRA  permit application was submitted on August 25, 1983 by
SCA.   Subsequently,  several  revisions have been submitted as a result of
EPA Region IV and SCDHEC reviews.

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     GSX purchased  the  lease in November 1984, thereby obtaining the site
operations.  A provision  in the lease will deed the landfill areas to GSX
once disposal operations have ceased and closure is completed.

     GSX submitted another revised Part B application on September 6, 1985.
This revised application was reviewed as part of the Task Force evaluation.

     On February 25, 1985, EPA Region IV issued a Compliance Order and Con-
sent Agreement (Docket  No.  85-11-R) to GSX which outlined a  schedule for
implementing a ground-water study program.  On April 4,  1985,  a Partial
Agreement  and Order On  Consent (Docket No. 85-11-R) was agreed  to by EPA
Region IV  and GSX.   On  January 13, 1986,  a final  agreement  and Order On
Consent was agreed to by EPA, Region IV and GSX.

     SCDHEC issued GSX a Notice of Violation (NOV) following a state inspec-
tion on May  3,  1985 for,  among other  items,  allowing leachate to reach
excessive  levels in  sumps  in the Section  I landfill.   An Administrative
Consent Order (85-64-SW) was agreed to on September 6, 1985,  which resolved
all issues in the  NOV and required a  study to determine if the  excessive
leachate levels  had damaged the landfill's liner system.

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                                                                         8
                    SUMMARY OF FINDINGS AND CONCLUSIONS

     Task  Force  personnel  investigated  the interim status  ground-water
monitoring program  at  the GSX  Pinewood facility  for  the  period March  1980,
when the  applicable provisions of the State regulations became effective,
through November 1985.   The investigation revealed the ground-water monitor-
ing program has undergone three changes since 1980.

     Two monitoring well  systems  were replaced  by a single  new system  in
the fall  of  1985,  as required by  the April 4, 1985  Partial  Agreement and
Order on  Consent between GSX and  EPA.  This new  system will  be expanded as
the site expands.

     At the time of the Task Force inspecton,  the facility Part B submittal
omitted a  ground-water monitoring  program  due to ongoing hydrogeologic
investigations.  Thus,  at  the  time of the  inspection, the  Part B permit
application was not in compliance with the State regulation R.61-79.270.14(c).
Subsequent to  the  inspection,  GSX has submitted a revision  to the  Part B
application  on January 16, 1986  which addresses  the  R.61-79.270.14(c)
requirements.  This revision is presently under review.

     The analytical results of ground-water samples collected by the Task
Force during the  inspection  show the presence of trace  concentrations  of
nickel  in  six  monitoring  wells and the French drain.   The  source of the
nickel  in ground-water samples should be further investigated.

     Other than nickel, no  hazardous or"hazardous waste constituents were
positively identified  as  a  result of analysis of samples collected by the
Task Force during the inspection.

     Under current EPA policy,  if an offsite TSDF is used for  land disposal
of waste  from  a  Superfund-cleanup of a CERCLA site, that site must be  in
compliance with  the applicable technical requirements of  RCRA.  Interim
status  facilities must  have an adequate ground-water monitoring program to
assess  whether the  facility  has  had a significant impact on  ground-water
quality.

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     The findings of the Task Force evaluation, as outlined in this report,
may  have  a bearing  on  the  ability of  the GSX site to further  accept CERCLA
cleanup wastes.

COMPLIANCE WITH INTERIM STATUS GROUND-WATER MONITORING - R.61-79.265
SUBPART F

Ground-Water Monitoring System

     The monitoring wells  installed as part  of the  two early monitoring
plans  were deemed  inadequate as  they were too few  in  number,  were not
located  immediately downgradient  of the waste management  areas  and were
constructed in such a manner that it was not clear which zone(s) were being
monitored.

     Some  of  the  new stainless  steel ground-water monitoring system wells
installed  in  the  fall  of 1985,  had  not  been  fully developed at the  time  of
the  field  inspection.   Data from five  of  the 20  monitoring wells sampled
during the inspection may  be  questionable  due  to  lack  of  full well
development.

Site Hydrogeoloqy

     GSX has  failed to fully characterize the hydrogeology of  the  site,
including  characterization  at the  uppermost aquifer beneath  the site.
Therefore, GSX has not provided a sufficient Part B application,  as  required
by South Carolina Hazardous Waste Management Regulation R.61-79.270.14(c)(2).

     Whether  all  of the designated downgradient  ground-water monitoring
system wells  are immediately downgradient of hazardous waste management
areas depends  on  the interpretation of  water  level measurements  from which
piezometric surface depictions  are  drawn.   Depending on the selection of
wells from which water level measurements are taken for piezometric surface
depictions, the apparent ground-water flow directions may differ.  Until
this issue  is  resolved in  a rigorous manner, the ability of certain down-
gradient wells to immediately detect a release is in doubt.

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                                                                         10
Ground-Water Sampling and Analysis Plan

     The plan  covering  the  new  system  was  developed  in  two  phases,  a  draft
in July 1985 and a final in October 1985.  This plan corrected many previous
inadequacies,  but  two  remained.   These are:  (1) no method was identified
for  the  analysis  of total  organic halogen (TOX) and (2)  more than one
method was  identified for  the  analysis  of organic compounds.  Only  one
analytical  method  should be  specified and followed so that  statistical
comparisons of results can be made.

Ground-Water Assessment Program

     Sampling of the old ground-water monitoring systems placed the facility
in the assessment  phase of  the  Subpart F requirements [R.61-79.265.93(d)].
The  initial  assessment  report found that  no  hazardous  waste  constituents
were identified from samples collected from the old ground-water monitoring
system.  Initially, GSX proposed to return to detection monitoring.   However,
after discussions  with  SCDHEC,  GSX has decided to remain in an assessment
phase for the remainder of interim status.

GSX Contractor Laboratory Evaluation

     The evaluation of GSX's offsite contractor laboratory, Davis and Floyd
of Greenwood, South Carolina, identified the following minor problems:  (1)
they do not have statistically defined limits of  detection,  (2)  quality
control for  some parameters was incomplete for the samples collected just
before the site visit,  due to the rush to get the samples analyzed prior to
the  EPA inspection (quality control measures  are lacking for  several  para-
meters),  (3) samples for metals analysis should not be filtered as this may
bias the results low.   Filtering of samples, as done by GSX, is inconsis-
tent with the  methods  used to determine the adequacy of ground-water as a
drinking water supply and (4) calibration procedures are inadequate.

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                                                                         11
GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT

     The  ground-water  monitoring information  provided  in the August 25,
1983 Part B  application was  limited  to  data  from  the  old  nine  well  System.
Due to the inadequacies in the old system, the requirements [R.61-79.270.14
(c)] could not  be adequately addressed.  Because of the ongoing modifica-
tion to  the  ground-water  monitoring system,  the September 1985 Part B
application  omitted  ground-water monitoring  information.   However, the
January 16,  1986  revision  to the Part B application utilized the recently
obtained  hydrogeologic information  to discuss  the [R.61-79.270.14(c)]
ground-water monitoring requirements.

TASK FORCE SAMPLING AND MONITORING DATA ANALYSIS

     During  the  inspection,  Task  Force  personnel  collected  samples  from  20
ground-water monitoring  wells,  three  leachate collection sumps and the
surface discharge  of a shallow ground-water  collection  system.   The sampl-
ing was done and analyses  were made to determine if the ground water con-
tains  hazardous  or hazardous waste  constituents  or other  indicators of
contamination.    The  monitoring  wells were prepared for sampling by GSX
personnel, then  all  samples  were collected by the  Task Force  contractor
(VERSAR, Inc.).

     Analyses of  samples collected  by the Task Force do not indicate that
ground-water has been contaminated as a result of waste disposal activities
at the the site;  however,  the source of  trace concentrations  of nickel,
found in the  French drain and six monitoring well  samples, should be further
investigated.

FACILITY OPERATION

     For all  landfill  cells  constructed, there is inadequate documentation
describing how the units  were constructed and/or closed.  No as-built draw-
ings were available to Task Force personnel  during the investigation.  Con-
struction certifications are  available  from  the contractor who built each
cell, but GSX did not  have a complete  record  of  these  at the  site  during
the Task Force  inspection.

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                                                                         12
     Grid location maps for the landfill Section I, cells A and B, were not
drawn correctly.   GSX operating  personnel  used a different numerical/
alphabetical  system  from what had been  originally proposed to designate
grids.  The  landfill  operation  records  contain  the system  used  by GSX  and,
therefore, the maps  must  be  redrawn  to  correctly identify  placement  of the
waste.

     GSX has failed to adequately maintain the cover material on Section I,
cell  E.  This failure to  control  erosion of the cover  could  enhance  liquid
migration from precipitation into the closed cell.

COMPLIANCE WITH SUPERFUND OFFSITE POLICY

     Although GSX has completed some aspects of the requisite hydrogeologic
investigation, a  number  of critical elements are  missing.   The facility
must  provide additional   information regarding the  local  stratigraphy,
hydraulic gradients  and  hydraulic interconnection  of  various zones.   The
above information must be known before the adequacy of the number, placement
and  screened intervals of the wells which make up the GSX  ground-water
monitoring system can be affirmed.

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TECHNICAL REPORT

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                                                                         13
                           INVESTIGATIVE METHODS

The Task Force evaluation of the GSX site consisted of:

          Review and evaluation of records and documents from EPA Region IV,
          SCOHEC and GSX

          A facility onsite  inspection  conducted October 29  through  Novem-
          ber 7, 1985

          Onsite and offsite analytical laboratory evaluations

          Sampling and subsequent analysis and data evaluation for selected
          site ground-water and leachate monitoring systems and of a shallow
          ground-water zone

RECORDS/DOCUMENTS REVIEW AND EVALUATION

     Records and documents from EPA  Region  IV and the  SCOHEC offices,  com-
piled by an  EPA contractor,  were reviewed prior to the onsite inspection.
Onsite facility records  were reviewed to verify information currently in
Government  files  and  to supplement this  information  where  necessary.
Selected documents requiring in-depth  evaluation were copied by the Task
Force during the  inspection.   Records  were reviewed to include evaluation
of facility operations, construction of waste management units, and ground-
water monitoring activities.

     Specific documents  and records reviewed and evaluated  included the
ground-water sampling  and analysis plan, outline of a  ground-water quality
assessment program,  analytical results  from  past  ground-water sampling,
monitoring well construction data and  logs, site geologic reports,  site
operations plans,  facility permits, unit  design and  operation reports,
selected personnel position  descriptions and qualifications  (those related
to the required ground-water monitoring) and operating records showing the
general types and  quantities of wastes  disposed of  at the  facility and
their locations.

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                                                                         14
FACILITY INSPECTION

     The  facility  inspection, conducted  October 29 through  November 7,
1985, included identification of waste management units, identification and
assessment of waste  management operations and pollution control practices
and  verification of  location  of  ground-water monitoring wells and  leachate
collection systems.

     Company representatives were interviewed to identify records and docu-
ments of  interest,  answer questions about the documents  and explain (1)
facility operations  (past and present), (2)  site hydrogeology,  (3)  ground-
water monitoring system rationale, (4) the ground-water sampling and analysis
plan  and  (5) laboratory  procedures  for  obtaining  data on ground-water
quality.  Because  ground-water samples were  analyzed by an  offsite  labora-
tory, personnel  from these  facilities  were  also  interviewed regarding
sample handling and analysis, and document control.

LABORATORY EVALUATION

     The onsite  and offsite  laboratory facilities  handling ground-water
samples were evaluated  regarding their respective responsibilities  under
the GSX ground-water sampling and analysis plan.  Analytical  equipment  and
methods, quality assurance procedures  and documentation were examined for
adequacy.   Laboratory records were inspected for completeness, accuracy and
compliance with State and Federal requirements.   The ability of each labora-
tory  to  produce quality  data for the required  analyses  was evaluated.

GROUND-WATER. SURFACE WATER AND LEACHATE SAMPLING AND ANALYSIS

     During the onsite  inspection,  the Task Force collected  ground-water
samples from GSX ground-water monitoring  wells  and leachate  samples from
leachate collection sumps in the landfills.   A sample was also taken of the
shallow ground water as it flowed out of a  pipe from  a  French drain in
order to characterize ground-water  quality  in this shallow zone.   Samples
were taken by an EPA contractor and sent to EPA contractor laboratories for
analysis.   Splits  of all  samples  were provided to GSX.   EPA Region IV

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                                                                         15
requested and received six  sample  splits  and  SCOHEC  requested  and  received
four sample splits for independent analysis.  The NEIC received and analyzed
three split samples.  Data  from  sampling  analysis were  reviewed  to further
evaluate the GSX ground-water monitoring program and identify possible con-
taminants in the  ground  water.   Analytical results  from  the samples  col-
lected for the Task Force are presented in Appendix A.

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                                                                         16
                   WASTE MANAGEMENT UNITS AND OPERATIONS

WASTE MANAGEMENT UNITS

     This  portion of  the  report  describes the  design,  construction,
operation  and management  of waste disposal units  and waste handling and
disposal practices  at the  GSX-Pinewood,  South Carolina facility.   This
discussion is presented  here to provide a  framework  for  assessing waste
disposal unit integrity, explain the types and placement of wastes disposed
of at GSX  and  serve as a  reference to  assist  in  evaluating the  potential
for ground-water contamination in the event that leakage occurs and threatens
to degrade ground-water  quality.   Appendix B contains  the  excavation  and
operational plans for landfill Sections I and II.

Landfills

     In early 1978 Bennett began waste  disposal activities  at  the  site.  A
mixture of waste  and fuller's earth was placed in excavations produced by
claystone  (fuller's earth) mining in the area which is now  landfill Section
I.  Appendix B,  Figure B-l shows the Mingo Mine Excavation  Plan.   That area
in the  excavation,  designated as Section I, is the location of landfill
Section I.  The mined area was initially quite extensive and  portions to
the east of Section  I have been graded  during  construction  of  roads, berms
drainage ditches  and other activities associated with  landfill ing opera-
tions.   The extreme  eastern portion of the excavation  is still  below  the
original surface grade.   Soils found on the site served as  the construction
material for  these activities.  An approximately  10-foot-thick  layer of
claystone  was left intact  after mining  to serve as  a  base for  the  landfill
area with  the low point of the landfill floor being approximately 30 feet
below the  original surface grade.  Cell A of Section  I  began at  the toe  of
the northwest slope  of  the excavation  and  construction of  other cells in
Section I were developed in sequence from cell  A through cell E in a south-
easterly direction.

     Upon  obtaining  the  property  in April 1978, SCA began  to renovate the
disposal area, moving the  small amount  of waste present to  one area within
the excavation.    One-half  of  cell A was constructed and the waste  moved  to

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                                                                         17
that area.   The  other half of cell A was then constructed and disposal by
SCA began in late 1978.

     Construction of  the  base  of each  cell  in Section  I  remained constant.
After excavation  (mining) of the opaline claystone, cell construction was
                                                                  _7
carried out by placing a  5-foot  layer of clay, [permeability of 10   centi-
meters-per-second (cm/sec)],  over the residual  claystone.   The clay was
also extended  on  the east and west  sides  of the cell at  a  slope of 1:3
                                                    A
(rise to  run).  A 0.030-inch (30 mil)  thick Hypalon liner was  placed  over
the clay to cover the base and sides.  A 1-foot by 2-foot trench was dug at
or near surface grade on  the sides, for anchoring the liner.   A 2-foot soil
layer was placed  on the  liner,  also at a 1:3 slope on the sides and base.

     As the  liner was laid, it was extended beyond where the cell separa-
tion berm would be  placed.  The  berm was constructed of  clay at a slope of
1:2 with  the  top  serving as an  access  road.   The width of this road was
usually 15 feet.  The liner extension was  placed into the bottom berm at
its outside  surface.   Prior to building the adjacent cell, a small  cut was
made into this  separation berm  to expose  the liner which  was then  seamed
and glued to that cell's  liner.  The other end of the liner was also extended
beyond that  cell's  separation  berm to  provide a  seam and glue area  for the
next cell's liner.

     Each lift of waste is approximately 10 feet, including a soil  cover.
Once a lift  was  completed, the  berms were  extended upward for the  next
waste layer.

     A leachate collection  system and sump were  placed  in each subcell.
The design  of the  leachate collection systems  changed  with each newly
constructed cell  in Section I.   Additional collection piping was  added
beginning with  cell C.   High  density  polyethylene (HOPE)  pipe was  used
instead of the clay pipe, beginning with cell D.
     Hypalon is  a registered trademark and  appears  hereafter without 6.

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                                                                         18
     The floor  of  each subcell generally sloped  2% toward the collection
system to enhance liquid migration to it.  The collection system piping was
also sloped 2% toward the sump to allow liquid travel to it.

     The sumps  consisted of  a  cement base built  into the soil  layer  on the
base of  the  subcell.   A cement riser was placed on the cement base and
leachate collection  lines  radiated from  it.   As  each new lift  of waste was
deposited, new  sections of  cement  riser were added to  extend the sump
access.  For both cells A and B, the sumps were located near the north edge
of the subcells.   For cells  C, D and  E,  the sumps were located near the
center of each subcell.

     Once the cell  was filled, 1 foot of soil sloped at a  10% grade, was
placed to act as a cover at cell A.   A 30-mil Hypalon liner was placed over
the soil  and seamed and glued to the 30-mil  line extending from beneath the
waste.   A compacted  clay  layer (permeability of 10    cm/sec)  was  placed
over the liner  followed by a soil cover 18  inches thick at  a 15% slope.  A
change in state  requirements altered the cover's slope to  8%  for  each of
the subsequent cells.

     Clay berms  for  dividing the cell into subcells were constructed into
the soil layer  so they  sat on  top of the liner.  Berms were sloped 1:1 and
were not designed to act as roadways even though the top width was approxi-
mately 8 feet.   Cell A in Section I  was designed for four disposal  subcells;
one each for disposal of oxidizer, alkaline,  organic and acid  wastes.  The
expected market  for oxidizer waste  did not  materialize;  therefore,  this
subcell was also used for organic wastes'.

     Cell B in Section I initially was designed to have four subcells.  The
separation berm  between cells  A and B was to be removed allowing leachate
to drain into the sumps in cell A.    Instead, only three major and one minor
subcells were built  (see  Appendix B, Figure B-2) and sumps were placed in
the major subcells.

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                                                                         19
     The minor  subcell  was a triangle-shaped area on the west side of the
cell and was  formed when the major  subcell  separation berms were angled
between the berms  in cell A and those to be constructed in future cell C.
The separation berm between subcell A-4 and the triangle area was excavated
to  form a  trench,  approximately 2  feet wide which extended  from  the top of
the separation berm to the landfill floor.  Filter fabric was placed on the
bottom and sides of the  trench  and crushed stone  was  placed to a height of
approximately one  lift  of waste.  Additional filter  fabric was  placed on
top of the stone  and the remainder of the trench was backfilled with clay
to  its original  height.   The floor of the triangular area was sloped to
allow drainage into subcell A-4 through the trench.

     Only  one  lift of material  was placed in the triangle  area  which was
then covered with  a clay cap.   The top of this  cap then  served as the base
for what was now an extension of subcell  B-3.   This extension area drained
to  the leachate collection sump in that subcell.   Appendix B, Figure B-13
is a cross-sectional depiction of cell B showing the covered area described
above.

     A change was  made  on the  cover  of cell C, and was  also used for all
subsequent cells in Section  I.   A  20  mil  cover  liner  was used instead of  a
30 rail  liner.

     Cell   E was built in two stages  with a temporary berm  separating the
working area from future working areas.   The drain system was extended into
the next area  to  be worked and inflatable plugs prevented movement in the
drains  in either direction.

     As each  cell  was installed,  surface runoff  was  diverted through a
ditch running  along the  east  and west  sides  and the separation berm.
Runoff followed drainage channels  to a low  area  northwest of Section I
which,  in  turn, drains  to Lake Marion.   Surface runoff from the  claystone
processing and drum solidification areas drains  to a channel  which also
empties into the low area.

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                                                                         20
     The shallow  water-bearing  sand layer presented a problem as constant
pressure against the clay berm and liner could force liquid into the cells.
A French drain  was installed (see Appendix  B,  Figure  B-12, Ground-Water
Collection  System Location Map)  around  Section I which diverts  shallow
ground  water.   The drain  runs  along the south, east  and  west sides of
Section I  and  is  constructed of 6-inch perforated pipe placed in a trench
which is excavated into the opaline claystone  layer and then backfilled
with gravel.  A filter fabric is placed on  top of the gravel and coarse
sand placed  on  the fabric.  The  drain discharges  to a low area  northwest of
Section I.

     The cells  for Section II  are  also  placed in a mining  area  to the
northwest  of Section  I.  This section  is being built into  a hillside which
runs along the north edge of the property.   As the claystone is removed, an
excavation  is produced,  leaving approximately 10 feet  of undisturbed clay-
stone to form the  base.  The excavation  is approximately 60 feet below the
top of the claystone after the overburden has been removed.  As the shallow
water-bearing sand is removed to expose the claystone,  a ditch collects the
shallow ground water and directs it away from the open  excavations.   As the
excavation expands  to  the  north,  this ditch will follow it to divert the
shallow ground  water.   The ditch discharges to a low area west of Section
II which drains to Lake Marion.

     In Section II, cells  A and B have a base consisting of 5  feet  of com-
                                _•/
pacted clay  (permeability  of  10   cm/sec), an 80-mil  HOPE liner,  9 inches
of soil  and 1  foot of sand.   The leachate  collection system  layout is
similar to  Section I,  cells C through  E.• The cover will consist of 1 foot
of soil  over the waste, a 30 mil HOPE  liner, 2 feet of  clay and 6 inches of
topsoil.  At the  time  of the Task Force  inspection, the HOPE liner was
being installed.

     The leachate  collection system  design in Section  II differs from that
used in Section I.  The sump itself is depressed approximately 5 feet below
the grade  of the  fill.  The 5-foot  compacted clay base  layer  follows the
depression, so that the layer is continuous.

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                                                                         21
     Section  II,  cell  C,  has the first  leak detection system between  two
liners.  Construction  of  this and subsequent cells  consists  of 3  feet of
                                  _7
compacted clay  (permeability of 10    cm/sec), an  80  mil  HOPE  liner,  a  leak
detection system,  5 feet  of recompacted clay,  an 80  mil  HOPE liner,  a
1-foot coarse sand  layer,  filter fabric and 1  foot  of soil on which the
waste is placed.  All material  is sloped to  follow the grade in each subcell

     The leak detection system  consists of approximately 12 inches of sand,
and has  a perforated HOPE pipe within  it which is connected  to a  sump  at
the side slope  of the cell  area.  A  pipe within  the 5-foot clay layer  on
the side slopes runs to the  surface.

     A review of  landfill  construction records indicated that no as-built
drawings exist  for  Sections  I  or II.   Certification letters from the con-
struction contractors  exist which state that the  units were built in
accordance with construction drawings.   Many of these letters are missing
from the GSX  onsite files and  attempts  have been made by  GSX to get them
from the contractor.   This was ongoing at the time  of the investigation.
The absence of as-built drawings led to confusion on how Section I, cell B,
was actually  constructed.   During  the review of the construction drawings
for cell B, GSX onsite personnel offered more than one version on how the
triangular area was treated.  GSX has a construction certification letter
describing how the triangular area in this cell  was filled and then closed,
but the  accompanying drawings  were  not available  at  the  time of the
inspection.

     GSX has  chosen to treat the filled cells (those  no longer receiving
waste) as under partial  closure.   At the time of the  purchase,  Section I
had a cover placed  on it which was to  undergo  a year of settling.  This
partial closure phase  began  in the spring of 1984.   Section  I has since
been graded and seeded for a final cover.  Section II,  cells  A and B, were
receiving the cover liner  during the inspection and soon will receive the
final  soil cover.   GSX intends  to commence facility  final  closure  when  the
site can no longer  accept waste (i.e.,  all  cells are  filled).  This  is
being done so  the entire site will be monitored during post-closure and  not
each cell or section.  This  is  addressed in the site's closure/post-closure
plan,  which is a portion of  the Part B application.

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                                                                         22
Treatment

     Bulk liquid  Is  solidified  In  one  of two  open,  below grade  tanks.  The
tanks are split  In half heightwise and placed horizontally in below grade
vaults.   The  vaults  can  be  entered for inspecting the  tanks through a man-
hole.  This operation  is to be  upgraded as  described in  the Part B submit-
tal and will handle approximately 90,000 gallons per day.

     Bulk liquid  which  has  been tested for  solidification capabilities
prior to  its  acceptance  is brought to  the  tanks and pumped in  on a batch
basis.  Pozzolanic material,  a  mixture which includes fuller's earth, is
added in  amounts  determined by  laboratory  testing  or  past experience.  A
backhoe then mixes the material  and a sample  is taken to test its structural/
absorbtion  properties.   For hazardous waste  containing  greater than  10%
liquid,  a compaction test is performed as well as a paint filter test.   The
compaction test involves the sample withstanding 50 pounds-force-per-square-
inch in order  to  pass.  This requirement was imposed  by EPA, Region IV.
All other landfilled materials  containing  liquids  must  be  tested  by  the
paint filter method  before  landfill ing.  This is done to comply with the
liquid landfill ban Imposed by the 1984 RCRA amendments.

     GSX also  performs a test to determine if  the  landfill  material  can
withstand equipment  being  driven on it.  Nonhazardous waste and hazardous
waste not containing organics 1s tested by taking a 3/4 inch diameter rod
that is 24  inches long and attempting to push it into the sample.   If the
rod goes 1/4 inch or less into the sample,  the material can withstand 1,000
pounds-force-per-square-inch and is landfilled.

     Adding pozzolanic material and mixing continues  until  the material
passes the  applicable  test(s).   The material  is  then landfilled in the
appropriate subcell.

     Drummed liquid  waste  is solidified by employing a screw mixer system
on a batch basis.   This system consists of  two feed hoppers, for liquid and
absorbent,  a  screw mixer and a drum feeder.   Liquid  from  the  drums  is
drained into one  of  the  mixers' hoppers.   Sorbent  material is  then added

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                                                                         23
through another  hopper based on  either laboratory tests or  experience.
Each of the  three subcell materials (acids,  bases, organics) has  Its  own
process line.  The purpose of this process Is not to produce  a structurally
sound material but  one In which liquid 1s adequately absorbed.  The mixed
material, is then placed 1h drums for placement in the appropriate subcell.

     Each drummed liquid process area  has  its  own drain and collection
system  leading  to a buried 10,000-gall on  tank.   These tanks  are  pumped
periodically and the fluid treated prior to landfill ing.

Storage

     The  facility has the  capability  to  store  up to 2,000  containers
(55-gallon drums) of  hazardous waste.   The  storage  is  needed  to accumulate
enough material  for operation of the  drummed solidification operation.
Material  arriving onsite  is sent to a roofed, two-sided, enclosed, cement
floored area.  The  drums  of material are segregated by organics, acids and
bases.   The  floor is  divided into areas,  each of which has its own drain
and collection system  which drain to 600-galIon buried tanks.  These  are
periodically pumped and treated for disposal onsite.

FACILITY OPERATIONS

Leachate Collection

     Operations at  the landfill,  in addition to waste disposal and place-
ment of lift cover,  Include the removal- of  leachate  from the collection
system on a  periodic  basis.  Leachate  levels are  recorded  daily at each
subcell's sump and  the volume calculated.  The daily  leachate report shows
the liquid level  and  the corresponding volume,  but the volume of leachate
pumped is not recorded.  This pumped volume would also include fluid drained
from the  collection lines and that which enters the collection system  from
the subcell  floor.  Accumulated  rainwater from the open cell and pumped
leachate  are  collected onsite.  This liquid  is either  solidified onsite or
shipped offsite to OuPont, Oeepwater, New Jersey for treatment.  The volume
solidified onsite is dependent on the excess solidification capacity

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                                                                         24
available.   In  nearly all cases, the  leachate and rainwater Is  shipped
offsite for treatment as excess capacity is not available.

     During an inspection on February 25, 1985, State inspectors found that
leachate  levels  in  some sumps of Section I reached  or  exceeded 15 feet.
This issue was addressed in a notice of violation from SCDHEC, dated May 3,
1985.  As part  of a State consent order, SCDHEC required daily monitoring
of leachate  levels,  removal  of leachate in excess of 3 feet and submittal
of a study  to determine if the liner  system  had been compromised by the
excessive levels.  A  report  dated October 29, 1985 was prepared  by a GSX
consultant which concluded that no damage occurred to the liner system as a
result of high leachate levels.

     Leachate has been  pumped mostly from Section I, cells  A and E,  and
Section II,  cells A  and B.  Section I,  cell  A, accepted  liquids  and this
could account for the volumes generated.  Section I,  cell E and Section II,
cells A and  B,  all  were in use within the year preceding the Task Force
inspection and  precipitation was accumulating in the  open  subcells  of
Section II during the inspection.  This  could also account for  part of  the
volume generated.

Incoming Hazardous Waste Handling

     Waste composition  (characteristics) to  be  handled  at  the site  is
reviewed by  the  SCDHEC  prior to its acceptance.   The waste generator will
fill out  a  State authorization report and send.it to GSX and SCDHEC.   The
State will review the form and may disapprove it for handling.  The authori-
zation report is to be submitted to the State at least 15 days prior to the
first shipment.   In the past,  SCOHEC issued disposal permits, but none  are
issued at present.

     GSX,  meanwhile, reviews  the  authorization report along with a sample
of the waste from which a  fingerprint  analysis is developed.  This is kept
in the generator file for future use if the waste is accepted.

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                                                                         25
     The facility  accepts  a wide  variety  of  wastes  such  as  oils,  solvents,
sludges, manufacturing  by-products, paints,  Inks,  spent pickle  liquor,
plating wastes, acids, caustics and organic chemicals.  Wastes not accepted
at the  facility  are PCBs,  dioxln containing wastes (RCRA waste codes F022
through F028), RCRA waste  code  K099 (untreated wastewater from the produc-
tion of 2,4-0),  radioactive  material,  explosives, oxidizers, cyanides and
flammable materials.

     The site  is  limited to  135,000 tons of  hazardous  waste to be land-
filled each year.  This is a requirement found in the South Carolina Hazard-
ous Waste Management Act, as amended.

     When a generator  is ready to ship waste, GSX 1s contacted and a work
order is issued.   Upon  arrival  at  the front  gate,  the manifest and work
order are checked by the guard.   The load is directed to the scale where it
1s weighed and sent on to the  staging area.  The manifest  and work order
are given to the GSX traffic clerk for review.  The manifest is also reviewed
by a full-time onsite State inspector.  A sample  is taken and analyzed  for
fingerprint matching.  If  the  paperwork is correct and  the waste matches
its fingerprint, the State inspector and  the  lab  approve its unloading.  A
site authorization  form  is filled out in which the lab will designate the
subcell  location and notify the landfill supervisor that a load is available
for disposal.   Bulk and drummed liquid is sent to the solidification process
for treatment  and  the authorization form  identifies the  relative amount of
absorbent to  use.   The  form  also Identifies the subcell to  accept the
waste.

     Landfill  waste is issued  a grid location by landfill  personnel based
on the  unit's current operation.   The grid  location is written  on the
authorization form and given to the traffic clerk.

     In the event  that off-specification waste is found, the generator is
called for instructions.   If waste is rejected, it is sent back or directed
to the alternate TSD identified on the original manifest.  A letter is sent
with the manifest  explaining  what has occurred and outlines the generator

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                                                                         26
instructions.  The  letter Is also sent to the generator for his signature
and return  but the waste is  not  held at the site pending receipt of the
signed letter.

     A review of  records was conducted for  the  period 1980  through  1985.
These  consisted  of the  State authorization reports,  facility  unloading
authorizations, fingerprint analyses and cell receiving reports.  Some fin-
gerprint analyses  for 1980 were not found.  The site  is presently placing
all records in computer files for easier access.  Tracking of the waste was
readily  followed  by  the  forms  and compared to  the  landfill  grid maps.
Problems were found in Section I, cells A and B, as the grid maps did not
match  the  unloading authorization grid locations.  The problem was caused
by the use of maps which were based on the system proposed to be used.  The
unloading authorization  form used a  system followed  by landfill personnel.
The maps showed  cell  A had  grids  1  through 6, while  cell B had grids  1
through 4.   Personnel numbered  the grids in cell A, 1 through 5 and those
in cell B, 6 through  8.  The proper numbering system map is to be drawn for
cells A  and B and kept onsite.   An  explanation 1s to be  attached to it
describing why changes were made.  This map will accompany the deed restric-
tion once the site is closed.

     The failure  to maintain an  accurate map or  diagram of the  location of
each disposal  location  is a  violation of R.61-79.265.73(b)(2),  265.119  and
265.309.   Due  to  errors in properly  recording the grid locations used  in
Section I, cells A and B, GSX could not identify the location of waste dis-
posal through  the use of their operating  record.  As  a result, GSX  would
provide a  faulty  record  of waste  disposal  to the local zoning authority or
the agency with jurisdiction over land use.

Maintenance of Landfill Cover

     Severe erosion problems were noted during the Task Force investigation
at the cover for Section I, cell E.  The cover had been seeded but vegetation
had not  begun to  grow.   As a result,  precipitation and runoff were causing
portions of  the  cover to wash away  to the southern portion of the  cell
area.  Erosion of the cover will  reduce its effectiveness in preventing

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                                                                         27
downward migration of liquid into the closed cell.  This  has the potential
for increasing liquid migration  from the cell  into the ground water.   The
failure to adequately maintain the cover and minimize erosion is a violation
of R.61-79.265.310(a).

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                                                                         28
                             SITE HYDROGEOLOGY

HYDROGEOLOGIC UNITS

     A detailed  characterization  of the site hydrogeology was in progress
at the time of the Task Force inspection, although more general hydrogeolgic
descriptions had  been  done.  GSX  was  attempting  to  identify  the most prob-
able paths of potential contaminant migration from landfill units to ensure
that new  monitoring  wells were located properly.  This section presents a
general description of the hydrogeology in the vicinity of the GSX facility.
The  hydrogeological  and  ground-water  flow  discussion in this report  is
based on  findings reported by GSX consultants, AWARE Incorporated of West
Mil ford, New Jersey (AWARE).  Figure 3 identifies the locations of previous
site characterization work and all monitoring wells.

     The  facility sits on the South Carolina Coastal  Plain,  which consists
of layered sedimentary deposits.   These deposits thicken  in a wedge-like
fashion to the  southeast toward the ocean.  This wedge  of sediments lies
unconformably on  the Piedmont basement rock.

     The  first group of  rock formations above the  bedrock is the Lumbee
Group consisting  of, from lower to upper, the Middendorf, Black Creek and
Peede Formations.  The Middendorf Formation is mostly kaolinite and quartz
sand with clay  units,  and includes numerous aquifer  zones.   The depth to
the top of the  Middendorf is approximately 600 feet at the GSX site.   The
town of Pinewood  taps the Middendorf as a water supply with a well  screened
in the  interval   between  700  and  750  feet below land surface;   No test
drilling at the site has penetrated this formation.

     The  Black  Creek Formation overlies the Middendorf  and   consists  of
clays,  shales and sands.   The sand zones serve  as  major aquifers for  the
area.  The clay  and  shale zones act as aquitards.   The depth to the top of
the Black Creek  ranges from about  80  feet  to  about 140 feet at the GSX
site.  The upper portion  of the Black  Creek is utilized  by several produc-
tion wells at the GSX site.

-------
                                                                                                                  FIGURE  3
LEGEND
  NOTE  TOPOGRAPHY OfVELUPCO  tOOM it*ปL
  StPT  1981  Blf  AlP. "MOfOGRAPMlCS  iNC .COMPILED Bป'OP
PROPERTY UHC

KM GROVNO-IMTCD NONITOR1NG STSTCM HELL
TEST BORING LOCAIION
1-1 IMRU B-7 DRILLED IซI7H IS PART 01  INITI
HrtWOGtULOCIC INVtSIIUA-IQN
8-8 THOU e-li ORILUU 1479 CONHRfMTOHT U0ซ4
PUT Or AB[A A. 8, C UIMGN
6-17 Thau 1-20 DRIUtU 1980 CONflWWIOBt BO1
PAST Of ARIA D AND t UCS1GN
8-21 IH8U B-S3 OeiLLCO AS PART OF HiOaOGEOU,
INVESTIGATION PERrORHCC SEPT  • OCT   1981
B-67 MILLฃ0 AS PART Of HTOROGEOlOGIC INVES.
CONDUCTED WRCH 1982
S-68 THOU ป•79 DRILLED AS PART OF HVOMOCEOL
INVESTIGATION CONDUCTED AUGUST. 1982
B-80 EIPLORATORT BODING DRILLED Hป"  1983
B-81 THRU B-84 DRILLED NOV  1983

TEST PIT LOCATION
TP-I THRU TP-32 DUG 1978 AS PART Or  INITIAL
INVESTIGATION.
TP-33 THRU TP-52 DUG AS PAOT OF ON-SITE UA
INVESTIGATION DEPORT OCT  1979.
TP-53 AND TP-S4 DUG AS PART OF HIOKOGEOLOGI
INVESTIGATION CONDUCTED AUGUST. 1982

WELL LOCATION
DRILLED 1978 AS PART OF INITIAL HfDROGEOLOG

CORE BODING LOCATION
DRILLED ป1 OR  PAUL BENNETT 1972

AUGER BODING LOCATION
DRILLED Br DR. CAUL BENNETT 1972.
    ปUป>    EXPOSURE LOCATION  1972

    .vป     BORINGS 2-0. 3-D.  4-D. AND B-S SERVE AS GRO
    ^      NONITODING WELLS UPGRADED SEPT  1981
            WRINGS 5-0 THRU 9-0 DRILLED NAT/JUNE 1983.
            GROUND HATER MONITORING WELLS
    -wtu-J
                                                 El
                                                                                          GROUND-WATER
                                                                                  MOMTORJNG WELL LDCAHONi

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                                                                         30
     The second  group  of  rock formations  overlying the Lumbee Group is  the
Black Mingo Group consisting solely of the Rhems Formation at  the GSX site.
The Rhems overlies the Black Creek Formation and 1s divided into the Sawdust
Landing and  the  Lang Syne members  (lowermost  and  uppermost,  respectively).

     The Sawdust Landing member averages about 30 feet in thickness  through-
out the site and consists of  sands,  silts and clay beds.  The top  of the
Sawdust Landing is between 20  and 120 feet below the natural surface at the
GSX site and slopes to the east and northeast across the site.  The Sawdust
Landing has  been  the focus of ground-water monitoring during the interim
status ground-water  monitoring program and is considered by GSX to be the
uppermost aquifer beneath the landfill facility for the  purpose of  meeting
ground-water monitoring requirements.

     The Lang  Syne member overlies the Sawdust Landing member and contains
the massive  opaline  claystone unit in which trenches are excavated during
mining of fuller's earth.   At  least a 10-foot thickness of this material is
left in place  below  the bottoms of the trenches.    This layer  is intended
to serve as the base of and a  natural geologic backup system for the trench
and liner  systems which  serve as the individual  waste  disposal  units.

     A surficial  Red Sand Unit mantles portions of the site and is partially
saturated with ground water under natural  conditions.   This unit is stripped
off prior to mining  of fuller's earth and subsequent construction of waste
disposal cells.  Along the upgradient periphery of  Section I,  this  unit  is
drained by a French drain.  A ditch along the upgradient side of Section II
diverts drainage, from this unit away from working areas.

GROUND-WATER FLOW

     Ground-water flow across the site, as described by AWARE,  is generally
in a southwesterly direction  with  the recharge areas being east and north-
east of the  site and the  ground-water discharge area being in the vicinity
of Lake Marion to the west and southwest of the site.

-------
                                                                         31
     AWARE reports  in  situ hydraulic testing results using recovery tests
                                                                        _4
in wells  for  permeability of the Upper  Black Creek range from 1.2 x  10
                  .4
cm/sec to 8.0 x 10-   cm/sec having a geometric mean permeability from three
                        .4
tests of  about  2.3  x 10   cm/sec.  Results of permeability testing in the
                                    .7                    _s
Sawdust Landing  range  from 1.7  x 10   cm/sec to  2.2 x  10   cm/sec  and have
                                               .6
a geometric mean permeability of about 6.6 x 10   cm/sec.
     GSX's hydrogeologic  investigation  reports were  prepared  by  their  con-
sultants  AWARE.   The Task  Force came  to  the  following conclusions and
recommendations as a result of the review of these reports.

     1.   GSX has failed to fully characterize the hydrogeology of the site
          particularly with respect to:
          a.    Continuity  or discontinuity  of individual  stratigraphic
               units within  the  Sawdust Landing and the Upper Black Creek
          b.    Hydraulic  interconnection  or isolation of  permeable  zones
               within the Sawdust Landing and the Upper Black Creek includ-
               ing differences  in vertical  hydraulic head distribution
               between zones
          c.    Hydraulic gradients, time  of travel and dispersion charac-
               teristics in  the  permeable zones of  the  uppermost aquifer
     2.   GSX has failed to verify the  lower limit of the  uppermost aquifer

     The  failure  to  fully characterize  the  site hydrogeology  and to  verify
the lower limits  of  the uppermost aquifer,  as  required,  will  result  in the
facility  being unable  to  fully comply  with  Part B  requirements  found at
R.61-79.270.14(c).

     The  above  information must  be provided before  the adequacy  of the
ground-water monitoring system can be affirmed.

     It is the consensus  of the Task Force that GSX Services, Inc. should
be required to:

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                                                                    32
1.   Adequately  characterize the geology of the  site,  at a minimum

     a.   Define  the  vertical  and lateral extent  of the sand units
          within  the  Sawdust Landing member of  the Rhems Formation

     b.   Further define  the areal  extent and continuity of the clay
          unit at the base  of the Sawdust Landing  member that  the GSX
          believes  Is the unit  that  segregates  the Sawdust Landing
          from deeper aquifers.

2.   Adequately characterize the ground-water  hydrology of the site,
     at a minimum

     a.   Install a series  of  geographically  positioned piezometer
          clusters  across the entire  site into all sand units within
          the Sawdust Landing member and, if necessary, into the Upper
          Black Creek Formation to determine the head relations

     b.   Conduct a sufficient number of pump tests across the site to
          determine if  interconnection exists between the Sawdust
          Landing member and the Upper Black Creek Formation

     c.   Define and  maintain a  record of the hydraulic  head in frac-
          tured zones  of  the opaline  claystone as  part of the  program
          of installing piezometer clusters adjacent to  the downgrad-
          ient sides of Sections I and II.

3.   Provide all  previously requested data which  was not submitted
     with the December 1985 hydrogeologic report

4.   As a  result of  the  site  characterization studies, define the
     uppermost aquifer

5.   Present a modified ground-water monitoring system.

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                                                                         33
           GROUND-WATER MONITORING PROGRAM DURING INTERIM STATUS

     Ground-water monitoring  at the GSX facility has been conducted under
State  interim  status  regulations and the requirements  of a  State  hazardous
waste  permit.   The  following is an  evaluation  of  the  monitoring program
between November  1981,  when the ground-water monitoring provisions of the
RCRA regulations  became effective,  and November 1985, when the Task Force
investigation was conducted.  This section addresses:

     1.   Regulatory requirements
     2.   Ground-water sampling and analysis plan
     3.   Monitoring wells
     4.   Sample collection and handling procedures
     5.   Sample analysis methods and data quality
     6.   Ground-water  quality  assessment program  (implemented in 1985)

REGULATORY REQUIREMENTS

     Ground-water monitoring at the site has been regulated by three sources.
(1) Industrial Wastewater Permit-145 (IWP-145) conditions, (2) South Carolina
Hazardous Waste Management Regulations prior to June 1984 and (3) the State
equivalent of  40  CFR  Part 265,  Subpart  F.   Permit  IWP-145  references  the
State regulations and for the purpose of this report, the State regulations
prior to June 1984, will be discussed with the permit.

     The State of South Carolina received RCRA Phase I interim authorization
in February  1981.   At that time, the State regulations became enforceable
in lieu of  the Federal  ones.  These regulations (South Carolina Hazardous
Waste  Management  Regulations R.61-79)  were  revised in  June  1984 to be
essentially  equivalent  to the  Federal  regulations.   The State interim
status  ground-water monitoring  requirements  are found  in  R.61-79.265,
Subpart F.

     After November 19, 1981, Permit IWP-145 and RCRA ground-water monitor-
ing programs  followed  a separate but parallel  track.  Beginning  with  SCA
and continuing  with GSX,  the site has been responsible for complying with
the above programs which, at some times, overlapped.

-------
                                                                         34
Permit IWP-145

     Ground-water monitoring  began  at  the  site with  the  SCDHEC  issuance  of
Permit IWP-145 to  SCA on April 10, 1978.  Monthly monitoring consisted of
sampling and  analysis  for pH, total organic carbon (TOC), chemical oxygen
demand (COD)  and parameters to be determined by  SCDHEC,  based on  the  types
of waste disposed.

     The July 11,  1979  reissuance  of the permit required the sampling and
analysis of those parameters in Table 1.  These parameters were to be moni-
tored on a  monthly basis except for the presence of organic constituents,
which were  monitored  quarterly.  SCA also  agreed to  sample and  analyze for
those parameters in Tables  2  through 4.   These  parameters were monitored
quarterly.   Monitoring for all parameters in Tables 1 through 4 ceased when
the site found a statistical difference in the RCRA ground-water monitoring
wells.

R.61-79 Part 265. Subpart F

     RCRA ground-water monitoring  at  the site was regulated by the South
Carolina equivalent regulations  to  40  CFR Part  265, Subpart F.   Tables  5
through 7 outline  the parameters which were to  be  sampled and analyzed.
All the parameters were  to  be monitored quarterly for 1 year to establish
background  concentration  for   each  parameter.   During the  period, four
replicate measurements  were to  be  obtained for each  parameter at each
sampling event.

     After the first  year,  Table 7 parameters were  to be monitored semi-
annual ly,  while Table 6 parameters were to be monitored annually.

-------
                                                          35
                 Table 1

       INDUSTRIAL LANDFILL PERMIT
           IWP-145 PARAMETERS
Water level
Specific Conductivity (mho/cm)
Total dissolved solids (rag/2)
PH
Concentration of Nickel (mg/2)
Concentration of Phenolic compounds (mg/2)
Concentration of Chromium (mg/2)
Concentration of Lead (mg/2)
Concentration of Mercury (mg/2)
Concentration of Arsenic (mg/2)
Concentration of Cadmium (mg/2)
Concentration of Endrin (mg/2)
Concentration of Methoxychlor (mg/ฃ)
Concentration of Copper (mg/2)
Concentration of Zinc (mg/2)
COO

Presence of organic constituents as deter*
mined by scanning by gas chromotography (to
bซ don* quarterly)
                   Table 2

           SCOHEC MINIMUM ANALYSIS
    Specific conductivity mho/cm @ 25ฐC.
    Temperature ฐC.
    Total dissolved solids (TOS) mg/2
    Chloride mg/ฃ
    PH
    Dissolved organic carbon (DOC) mg/2
    Two principal metals mg/2
      (found largest quantities or which
      best serve as indicators)

-------
                                                               36
                        Table 3

              SCDHEC COMPREHENSIVE ANALYSIS
SCDHEC minimum analysis
Plus EPA interim primary drinking water standard*
Plus EPA proposed secondary drinking water standards
Plus concentration of Beryllium mg/ฃ
Plus concentration of Cyanide mg/ฃ
Plus concentration of Nickel mg/ฃ
Plus concentration of phenolic compounds (as phenol) mg/ฃ
Plus presence of organic constituents as determined by a
     scanning by gas chromatography

*    Except radioactivity levels
                        Table 4
                  PROPOSED SECONDARY
               DRINKING WATER PARAMETERS

                    Chloride
                    Copper
                    Foaming agents
                    Iron
                    Manganese
                    Sulfate
                    TDS
                    Color
                    Corrosivity
                    Odor
                    PH

-------
                                                            37
                   Table 5

   INTERIM PRIMARY DRINKING WATER STANDARDS

    Parameter

Arsenic                        0.05 mg/2
Barium                         1.0 mg/2
Cadmium                        0.01 mg/2
Chromium                       0.05 mg/2
Fluoride                       1.4-2.4 mg/2
Lead                           0.05 mg/i
Mercury                        0.002 mg/i
Nitrate (As N)                 10 mg/S.
Selenium                       0.01 mg/2,
Silver                         0.05 mg/2
Endrin                         0.002 mg/2
Lindane                        0.004 mg/2
Methoxychlor                   0.1 mg/2
Toxaphene                      0.005 mg/2
2,4-D                          0.1 mg/2
2,4,5-TP Si 1 vex                0.01 mg/2
Radium                         5pCi/2
Gross Alpha                    15pCi/2
Gross Beta                     4 millirem/yr.
"Turbidity                     1 NTU
Coliform Bacteria              1/100 m2

*    Turbidity is applicable only to surface
     water supplies.
                     Table 6

                 EPA PARAMETERS
        ESTABLISHING GROUND-WATER QUALITY

                   Chloride

                   Iron

                   Manganese

                   Phenols

                   Sodi urn

                   Sulfate

-------
                                                                         38
                                 Table 7
                     EPA PARAMETERS USED AS INDICATORS
                     OF GROUND-WATER CONTAMINATION
                     PH
                     Specific Conductance
                     Total organic carbon
                     Total organic halogen
GROUND-WATER SAMPLING AND ANALYSIS PUN

     Three Ground-Water Sampling and Analysis Plans (SAP) have been prepared
in response to RCRA requirements.  These are:  (1) an SAP dated November 16,
1981, which covered  landfill  Section I, prepared by SCA, (2) an SAP which
was  a  part of the Part B  permit application submittal dated August 25,
1983, which covered  landfill  Section II, prepared by  SCA,  (3) a sampling
and analytical protocol included in the "Interim Status Ground-Water Monitor-
ing Plan" (October 25, 1985) for the new system.

November 16. 1981 SAP

     This SAP was designed  to  sample the ground water  at  the  section which
was the only hazardous waste management landfill in existence at that time.
Monitoring under this  SAP  began in January  1982.  This SAP also outlined
Permit IWP-145 and other state imposed monitoring requirements.

August 25. 1983 SAP

     This SAP was designed to sample the ground  water at the Section II
landfill which was starting up.  Monitoring under this SAP began in October
1983.

October 25, 1985 SAP

     This plan was formally submitted by GSX as the  SAP to  be followed  for
subsequent sampling at  the new wells.   Monitoring under this SAP began in
October  1985.   The  entire  site  would  be sampled as one  entity  and the

-------
                                                                         39
previous  SAPs  were discontinued.  Many  deficiencies  from previous plans
were corrected, but the following deficiencies remained:

          There  is  no identified  method of  analysis  for total organic
          halogen.

          More than  one  analytical method is  listed for organic compounds.

     The SAP included the operation of the new Well Wizard  sampling device.
The SAP  did not  include  a  ground-water assessment plan  outline  because  GSX
had already developed a Ground-Water Quality Assessment Plan and was in the
assessment mode.

     The monitoring  systems  initially placed  around Sections  I  and II were
to be  sampled  concurrently with  the  new  one for  a 6-month period ending in
May 1986.   Plans  for the abandonment of the old  system wells will  then be
implemented upon SCDHEC approval.

MONITORING WELLS

     Prior  to  1985, there were  two well  systems,  totaling nine wells,
designated  to  monitor  ground water around the Sections I and II landfills
[Figure 4].  The  existing  RCRA ground-water monitoring system  at  the GSX
site consists  of 29 wells which were  installed  during 1985 [Figure 5].
These 29 wells replace the nine wells for purposes of ground-water monitor-
ing because  the old  systems  were judged  to be  inadequate.   In this report,
these systems shall be referred to as the "old" and "new" monitoring systems
[Table 8].

Well Construction - Old System

     Well construction details of the old monitoring system, including Sec-
tions I  and II, appear in  Table  9.   The  annular  space  opposite  the screens
     Veil Wizard  is a registered  trademark and will be shown  hereafter
     without the 9.

-------
                                      40
                                        v
                                        I
                                        9
                               (•

                               "Z
                                01
                                e
                                o
                               X
CA
                           ป   1

                           n
                           J   o
                           u.  -J

-------

-------
                  Table 8

WELLS DESIGNATED FOR GOUND-WATER MONITORING
 DURING INTERIM STATUS AT THE GSX FACLITY

Well

B5
20
3D
40
5D
60
7D
80
90

MW-1
MW-2
MW-3
MW-4
MW-5
MW-6
MW-7
MW-8
MW-9
MW-10
MW-11
MW-12
MW-13
MW-14
MW-15
MW-16
MW-17
MW-18
MW-19
MW-20
MW-21
MW-22
MW-23
MW-24
MW-25
MW-26
MW-27
MW-28
Dates of Active Area
Monitoring Monitored
Old System
Section I
Section I
Section I
Section I
Section II
Section II
Section II
Section II
Section II
New System
Section II
Section II
Section I
Section I
Section I
Section I
Section I
Section I
Section I
Section I
Section I
Section I
Section I
Section I
Section I
Section I
Section I
Section II
Section II
Section II
Section II
Section II
Section II
Section II
Section II
Section II
Section II
Section II
Monitoring
Designation*

Upgradi ent
Oowngradi ent
Downgradient
Downgradient
Upgradi ent
Oowngradi ent
Downgradient
Downgradient
Downgradi ent

Upgradi ent
Upgradi ent
Upgradi ent
Upgradi ent
Downgradi ent
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradi ent
Downgradi ent
Downgradi ent
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradient
Downgradi ent

-------
43






















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-------
                                                                         44
In Section I wells is filled with a gravel pack (unspecified) overlain by a
bentonite pellet seal, grout and miscellaneous backfill to near the surface
[Figure 6].  The  cement surface seals are about 1 foot deep.  The annular
space opposite  the  screens in Section II wells  is  filled with pea gravel
overlain by a 1- to 3-foot bentonite pellet seal and cement bentonite grout
to the surface.

     Each well, in  the old system, had  an  air lift device installed for
sampling and was cleaned of sediment prior to use.  The cleaning or develop-
ment stage  involved  agitating  the well water  volume to  suspend sediment  so
it could be removed.

     Tests were also done at the time of construction of the old wells to
identify the maximum air pressure to be used so that the sample would not
be altered  (e.g.,  aerated or degassed).   The  goal was  to obtain the most
volume of water with the least injected air pressure.

Well Construction - New System

     The new monitoring system consists of 29 wells including four upgradient
wells (MW-1 through  -4)  and twenty-five downgradient wells  (MW-5 through
-28 and MW-23A).  Well  construction details of  the new system appear in
Table 10.   A diagram of the typical well construction  for the new wells
appears in Figure 7.

     All of the new  wells are constructed of 2-inch stainless steel  (Type
316) pipe with 10-foot stainless steel (Type  316) screens.  Coarse sand  in
the annular space opposite the screen generally  extends above the screen 1
to 3 feet.   A bentonite seal, approximately 4 feet thick, overlies the sand
pack, which is  overlain by cement  and bentonite grout extending to the
ground surface.  A concrete pad is  constructed around the well at the  sur-
face and provides additional protection  against  downward migration of  sur-
face runoff.

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                                                         45
                          •*— PVC (4-in.)
                              •CEMENT 86NTONITE
                               GPOUT
                FIGURE 6


TYPICAL GROUND-WATER MONITORING WELL

                OLD SYSTEM
            Revised from AWARE, Inc.

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                                                                                                                     46
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                                                                 47
       LOCXINO CAP-
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                     FIGURE 7

TYPICAL  GROUND-WATER MONITORING WELL

                   NEW SYSTEM
              .Revised .from AWARE, Inc.

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                                                                         48
Well Locations

     Locations of  the  old monitoring wells will  not  be  discussed  because
these wells  are being  phased out  of  the  interim  status monitoring  program.
Only the locations of the new wells are discussed here.

     Regarding the new monitoring well  system,  additional hydrogeologic
study may  indicate various  water-bearing zones are interconnected and the
wells may, therefore, not be screened in appropriate units.  In the case of
interconnected water-bearing zones,  well clusters may need to  be placed to
monitor each zone.

     MW-1 and MW-2 are intended to provide upgradient background  ground-
water quality data for Section II.  MW-3 and MW-4 are intended to fulfill
the  requirement  for this data with  respect to Section  I.  Locations of
these wells  seem  generally  appropriate.  However, additional stratigraphic
and  hydrogeologic  information  is  needed to  assess  whether the screened
intervals in these wells are correlative, both geologically and hydraulically,
with the  intervals selected for  monitoring  in  the downgradient wells.

     Downgradient  monitoring well  locations  are at the  limits of  the two
hazardous waste management  areas  (Sections I and II) and their areal dis-
tribution is probably  adequate with respect to  the point of compliance.
Additional information concerning the local stratigraphy, hydraulic gradients
and possible hydraulic interconnection of zones within the Sawdust Landing,
and possible hydraulic interconnection between the Sawdust Landing and the
Upper Black  Creek  is  needed.   Then, a determination can be made regarding
the suitability of the screened intervals to provide the required assurance
that the ground water is being adequately monitored.

GSX SAMPLE COLLECTION AND HANDLING PROCEDURES

     The Task Force did  not observe sample collection and handling by GSX
during the inspection because GSX had completed the first round of sampling
for the new  monitoring system  just prior to the  Task  Force visit.  GSX did
purge the  wells  in order for  the Task Force  to  take samples.  The GSX

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                                                                         49
purging  procedure  is discussed  together with  the Task  Force  sampling
procedure in a following section of this report entitled  "Task  Force Sample
Collection and Handling Procedure."

GROUND-WATER ASSESSMENT PROGRAM AND OUTLINE

     As part of the ground-water monitoring program, SCA  had found statisti-
cal differences at one monitoring well at Section  I and at all  downgradient
wells at  Section  II.   These two events occurred at different times due to
the  differing operation  periods  for each  section.   As required by
R.61-79.265.93, a ground-water quality assessment plan (dated  June 1985)
was submitted in response to the failure of this statistical evaluation for
Section II.  The assessment called for sampling of the old nine well system
for 40 CFR Part 261, Appendix VIII constituents.  This sampling was conducted
during August 1985.   This assessment program was being conducted concurrently
with the  hydrogeologic  assessment  required  by  the  EPA  Compliance Order  and
Consent Agreement.

Section I

     Quarterly background sampling for the RCRA interim status  requirements
began in  March  1982.   In October  1983,  the first  semi-annual  sampling  of
ground-water contamination  indicators was done for comparison  to the first
years'  sampling results.  The results were submitted to the State who found
an improper statistical method had been used.  The proper calculations were
done and  submitted to the State  in May 1984.   Statistical differences were
found at  well  B5  for pH and total organic halide  (TOX);  at well 20 for pH
and at well 30 for pH and specific conductance.

     Based on these  results,  SCA resampled the wells  in  August 1984 and
could not confirm the  statistical  differences for any parameters in wells
20 and  3D or  for TOX in B5.   A  difference  for pH  in 85 was  confirmed but
was attributed to differences  in analytical results and  one high  sample.
In June 1984,  SCA also sampled and analyzed the monitoring  wells  for EPA
priority pollutants.   No detectable levels were found for any of the wells.
SCA, therefore, concluded  no  statistical difference in water  quality was

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                                                                         50
found, but  decided to  enter the ground-water assessment phase at the site.
A ground-water assessment plan  (GWAP) was submitted to  SCOHEC  In June 1985.

Section II

     Quarterly  background  data  gathering began for Section II wells  in
October  1983 and  continued for 10 months.   Replicate  samples were not
collected during  the  period which ended in July 1984.  Only indicators of
ground-water contamination  were analyzed during the period.   This  10-month
period served  as  background for the system.  The upgradient well  (50) was
further sampled quarterly  (on 1/84, 7/84 10/84 and  1/85) utilizing four
replicates at each sampling.

     The  Section  II  system was  then  statistically  evaluated against the
upgradient  well  for Section I  (B5) and  against the upgradient well  for
Section II  (D5).   Each downgradient well  in Section II was also evaluated
against its  own background.  Table 11 shows where statistical differences
were found when comparisons were made.  A resampling was done  in'March 1985
and many of the differences were attributed to  laboratory errors.

                               Table 11
         STATISTICAL DIFFERENCE FOR LANDFILL SECTION II WELLS
                        Comparison to
Well         Well B-5                 Well 5-0              Own Background
 6D    TOC                    None                      None
 70    TOC, pH,
       Specific conductance   pH Specific conductance   Specific conductance
 80    Specific conductance   Specific conductance      Specific conductance
 9D    Specific conductance,  Specific conductance      None
         TOC
Ground-Water Assessment Results

     As a  result of  the ground-water  assessment of the site,  all  Section  I
and II monitoring  wells  were sampled and  analyzed for applicable 40 CFR
Part 261,  Appendix VIII Hazardous Waste  Constituents  in August 1985.  This
effort did not show detectable  levels  of the chosen  constituents.   GSX
originally  proposed  to return  to  detection  monitoring;  however, after

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                                                                         51
discussions with  SCOHEC  personnel,  GSX elected to remain in an assessment
mode for the remainder of interim status.

GROUND-WATER STUDY PLAN

     As a result of interim status inspections conducted by both~SCDHEC and
EPA region  IV,  SCDHEC  requested  that GSX  prepare  a ground-water study plan
(GWSP).  A plan was submitted in October 1984, was found to be deficient by
SCOHEC and was subsequently revised.

     The GWSP was  designed  to better define  the ground-water system  at  the
site and to replace the  wells around Sections  I and  II.   It further  recog-
nized  the need  to upgrade the monitoring  system  at  Section I, since the
system was not meeting the requirements of R.61-79.265.91 (a)(2).

     EPA Region  IV issued a Compliance Order and  Consent  Agreement (Docket
No.  85-11-R) on February 25, 1985, to GSX to outline a schedule for imple-
menting the GWSP  agreed  upon between GSX  and  SCOHEC.   On April 4, 1985,
Partial Agreement  and  Order on  Consent (Docket No.  85-11-R) was agreed to
by EPA Region IV and GSX.

     The plan followed four phases, the first of which determined whether
the existing wells were  properly placed and also consisted of a review of
past sampling data.  Phase II consisted of installing piezometers to better
define ground-water flow paths,  both laterally and vertically,  in the Saw-
dust Landing.   Phase  III consisted of locating additional wells and pre-
paring a ground-water monitoring plan.  Phase  IV  consisted of  implementing
the new ground-water monitoring  plan.  It should  be  noted that this  hydro-
geologic assessment was being conducted at the same time as the ground-water
quality assessment program required by R.61-79.265.93.

     The new  monitoring  plan was developed  in October 1985.   This  plan
defined the monitoring system  evaluated  during the inspection [Figure 5].

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                                                                         52
         GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT

     A ground-water monitoring section was not Included In the September 6,
1985, Part  B submittal  because of the ongoing hydrogeologic studies.  GSX
stated In  Its  Part B transmlttal letter that revisions were to be made to
the ground-water monitoring section of the August 25, 1983 Part B submittal.
Until this  revised section  of the Part B application  Is evaluated, no
assessment of the adequacy of their program can be made.

     The ground-water monitoring system that has been proposed for the RCRA
permit  Is  that system described  In  the October 25, 1985 Interim  status
ground-water monitoring  plan.   The 29  wells  described  by the plan  were
Installed In August-September  1985 and were sampled as  part of the Task
Force effort.  This is the new system described in the Ground-Water Monitor-
ing Program  During  Interim  Status  section of this  report.  Deficiencies  in
this plan are also described in that section.

TASK FORCE SAMPLE COLLECTION AND HANDLING PROCEDURES

     This section describes  the  well  evacuation and ground-water sampling
procedures followed during  the site inspection.  GSX contractors measured
water levels and  purged  the wells scheduled for  sampling.   Samples were
collected by an  EPA contractor for GSX and the Task Force to determine if
the ground water contained hazardous waste constituents or other indicators
of contamination.  Task  Force  personnel observed all sampling procedures.

     Water samples were  collected from 20 monitoring wells  and a French
drain [Table 12, Figure 5].   Selection of wells for sampling was based upon
well locations to  provide areal  coverage both upgradient and downgradient
of Sections I and II, giving special attention to monitoring wells in close
proximity to the downgradient sides of the older waste disposal units.  The
French drain  receives shallow ground-water discharge mixed  with surface
runoff during and following storms.

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                                                                             53
                                  Table  12
                          SAMPLE COLLECTION DATA
Sample Point
MW-1**
MW-3**
MW-6
MW-8
MW-10
MW-11
MW-12
MW-13
MW-14
MW-15
MW-17
MW-19**
MW-20**
MW-21**
MW-22
MW-23
MW-23**
MW-24
MW-25
MW-26**
French drain
Organic
Leachate
Alkaline
Leachate
Acid Leachate
Samplinq
Date
10/31/85
11/06/85
11/06/85
11/06/85
10/31/85
11/05/85
10/30/85
10/30/85
10/30/85
11/07/85
11/07/85
11/05/85
11/01/85
11/07/85
11/05/85
11/04/85
11/04/85
11/04/85
1V04/85
11/05/85
10/29/85
11/01/85
11/01/85
11/01/85

Time*
0935
0905
1200
1105
1155
1015
1505
1000
1310
1100
0950
0755
1700
0915?
0835
0845
0840
1015
1145
1205
1400
0935
1305
1305
Remarks
Sample clear
Sample slightly turbid
Sample clear
Sample clear
Sample clear
Sample clear

Sample clear
>
Sample silty and grey
Sample turbid
Sample turbid
Sample clear; well dewatered;
parameters collected - 4 VOAs,
POX, POC, 2 extractable organics
Sample clear
Sample clear
Sample grey, silty; well de-
watered; parameters collected -
4 VOAs, POC, POX, 2 extractable
organics
Sample clear; triplicate poured
at this well
Sample clear
Sample clear
Sample clear; well dewatered;
parameters collected - 4 VOAs,
POX, POC, 2 extractable organics,
500 mฃ for total metals
Sample clear
4-way split: Task Force, GSX,
EPA Region IV, NEIC; straw-
colored, aqueous in nature
Black-colored with oil sheen
Straw-colored with oil sheen
 *   Time  field  measurements and  filling bottles commenced,  rounded to
     nearest 5 minutes
**   A period of recharge was allowed before sampling, due to dewatering.

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                                                                         54
     Three  leachate  samples were  collected to determine their chemical
characteristics and provide a  basis for assessing whether constituents in
the  leachate  have leaked  into and contaminated  the ground-water.   The
chosen  leachate  collection sumps represent waste  cells  containing acid,
alkaline and organic  hazardous wastes.   Specific sumps  sampled and waste
types represented are  shown in Table 12.   Locations  of the sumps are shown
on Figure 5.

     GSX received replicate samples of volatile organic samples and split
samples for all  other parameters for each  sampling  station.  Sample sets
for  selected  points  were  provided to  EPA Region IV,  SCOHEC and  NEIC
[Table 13].   One  set  of field  blanks was  poured  each  day,  for the Task
Force, by the EPA contractor at locations specified by the Task Force.   The
first week  of  sampling, a set of  field blanks was poured for GSX at the
French drain and  the  second week at MW-19  for  a total of two sets of field
blanks for the facility.  Water used to pour the blanks was HPLC Lot #855905.
One triplicate was taken  from  MW-23A for quality assurance/quality control
(QA/QC) purposes.

                                Table 13
                    LOCATIONS AND RECEIVERS OF SPLIT
                         SAMPLES OTHER THAN GSX
                Location                 Receivers
                  MW-11            Region IV, SCOHEC
                  MW-13            Region IV, NEIC, SCDHEC
                  MW-14            Region IV, SCDHEC
                  MW-22            Region IV, SCDHEC
              French drain         Region IV, NEIC
              Organic leachate     Region IV, NEIC

     All sample bottles and preservatives were provided by  an  EPA contract
laboratory.   Samples were collected using the following protocol:

     a.    GSX personnel determined depth to ground water

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                                                                         55
     b.   GSX calculated height and volume of the water column
     c.   GSX and Task Force personnel calculated three water-column volumes
     d.   GSX personnel  purged the calculated three water-column  volumes
          (less if the well dewatered).
     e.   Prior to sampling (immediately after purging or after a period of
          necessary  recharge),  the EPA sampling contractor monitored  the
          open well  head for chemical vapors (HNlr) and radiation.
     f.   EPA contractor collected a sample aliquot and made field measure-
          ments (water temperature, specific conductance and pH).
     g.   EPA contractor filled VGA vials, then filled the remaining sample
          containers in the order shown on Table 14.
     h    EPA contractor placed samples  on ice in  an  insulated  container
          immediately after filling the bottles.

     The  first  step in  the ground-water well  sampling  procedure is to
measure the depth to water from a reference point at the wellhead.  At GSX,
that reference is a  known elevation at the top of the well casing cap.   GSX
personnel used a Well Wizard water level meter  (Model  6000) to measure the
depth to water.   The meter probe was rinsed with distilled water before and
after measuring water levels.

     The water level meter used for this exercise was clean and kept pro-
tected from potential outside  contamination.  GSX was  able to make  repeat-
able measurements to within .01 foot.

     The next step  in  the sample collection procedure is to calculate the
volume of water  to  be  purged.   The water-column  volume  of a well is the
volume of standing water in the well and is calculated using the  depth-to-
water measurement, total well  depth  (from construction records)  and  casing
radius.  GSX calculated the water-column volume properly.

     For the purposes of the Task  Force, the water-column volume  is  multi-
plied by three to  compute the  intended purge volume.  The volume  is then
8    HMJ is a registered trademark and appears hereafter without 8.

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                                                                         56
measured as  water flows from the well.  In all cases, the Task Force used
standard field  measurements  (temperature,  pH,  specific conductivity) to
judge the representativeness of the ground water prior to sampling.

     GSX purged  the  wells  using  a  gasoline-fueled  Briggs  and Stratton air
compressor (Model  SAE  J607,  3hp, 127cc)  to  power a dedicated positive dis-
placement Well Wizard  bladder pump.   The ground water  was evacuated  to  a
large barrel at the wellhead.  None was allowed to  run off onto the ground.
The volume measurement and purging procedures were  satisfactory.

     GSX indicated that the Teflon ground-water discharge  line used for
sampling is  cleaned  with isopropanol  and distilled water prior to pumping
the well.  The  tubes are stored individually in aluminum foil until  ready
for use.   The clean tubes  are attached to the well  head after purging
immediately prior to sampling.

     After purging,  the EPA contractor commenced  the sampling procedure.
No chemical  vapors or radiation were  detected  at.any of the wellheads.
Sample containers  were filled directly from the discharge line.   Parameter
by parameter, the sampler  filled the  sample  container  for the Task Force
and for the GSX contract laboratory.   Step  'g' above was modified at  sampl-
ing  stations where  EPA Region  IV,  SCOHEC and NEIC received  samples
[Table 13].

     At the  French drain,  all  sample bottles  except VOA*  vials were filled
directly at  the  surface.   To fill  VOA vials, an intermediate glass beaker
was used.  The  same  sequence of filling sample containers  was followed.

     Leachate samples  were  collected  using a stainless  steel dipper.  To
fill  the VOA vials,  leachate was poured  first into clean  (dedicated)  glass
beakers, then into the vials.  The remaining bottles were filled directly
from the dipper through a clean glass funnel.   HNU  readings  at the  leachate
sumps appear in Table 14.
     Briggs and Stratton  is a registered trademark  and appears  hereafter
     without 9.
     Volatile organics analysis

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                                                                         57
                             Table 14
           HNU READINGS AT LEACHATE COLLECTION SUMPS
 Location        Subcell      Background,  ppm     Inside  Manhole,  ppm
Section I
Trench A
Section I
Trench A
Section
Trench A
Organics

Acid

Alkaline

.6

.8

.8

1.0

1.8

1.0

     After  sampling  was  completed at a well,  EPA contractor personnel  took
the  samples to a staging area where a turbidity measurement was taken and
one  of  the  two sample  aliquots  for dissolved  metals  analysis was  filtered.
In  addition,  metals, TOC, phenols,  cyanide,  nitrate and ammonia samples
were preserved [Table 15].  Leachate samples were not preserved.

                                  Table 15
                        ORDER OF SAMPLE COLLECTION
                     BOTTLE TYPE AND PRESERVATIVE LIST
     Parameter                            Bottle                Preservative
Volatile Organic Analysis (VOA)
  Purge and trap                      2 60-mA VOA vials
  Direct inject                       2 60-mฃ VOA vials
Purgeable Organic Carbon (POC)        1 60-mฃ VOA vial
Purgeable Organic halogens (POX)      1 60-mฃ VOA vial
Extractable Organics                  4 1-qt.  amber glasses
Total Metals                          1 qt. plastic                HN03
Dissolved Metals                      1 qt. plastic                HNOj
Total Organic Carbon (TOC)            4 oz. glass                  HiS04
Total Organic Halogens (TOX)          1 qt. amber glass
Phenols                               1 qt. amber glass            H.jS04
Cyanide               .                1 qt. plastic                NaOH
Nitrate/ammonia                       1 qt. plastic                H^S04
Sulfate/chloride                      1 qt. plastic
Radionuclides (NEIC only)             4 1-qt.  amber glass

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                                                                         58
     At the  end  of the day, samples  were  packaged  and  shipped to  the  two
EPA contract  laboratories,  the EPA Region IV Environmental Services Divi-
sion  and  NEIC laboratories  and the  SCDHEC  laboratory, as appropriate.
Samples were  shipped  according to applicable Department of Transportation
regulations  (40 CFR Parts  171-177).   Aqueous  samples  from  monitoring wells
and the French drain  were  considered  "environmental"  and those from leach-
ate collection system sumps were considered "hazardous" for shipping purposes.

     Each day of  sampling,  the EPA contractor prepared  field  blanks at one
location  for each parameter group (e.g., volatile organics,  metals).
Blanks were  poured at locations listed in Table  16.   The GSX contractor
laboratory  received  a set  of  blanks  poured  at the French drain and at
MW-19.

                                Table 16
                       LOCATIONS OF FIELD BLANKS
Date
10/29/85
10/30/85
10/31/85
11/01/85
11/04/85
11/05/85
1V06/85
11/07/85
Time*
1400
1345
0955
1605
0945
0730
0805
0830
Location
French drain
MW-14
MW-1
MW-20
MW-23A
MW-19
MW-3
MW-21
              *    riffle rounded to nearest 5 minutes

     Samples were  analyzed by  the EPA  contractor  laboratories for the
parameter groups shown  on Table 15.  In  cases  where the well dewatered,
only the parameter groups listed  in Table 12  under  remarks,  were obtained.

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                                                                         59
                        GSX LABORATORY EVALUATIONS

     The GSX  onsite  laboratory was  evaluated on November 4,  1985 to assess
their capability  to  receive,  handle and inspect samples of  incoming waste
loads.  During the laboratory inspection Mr. John Perna, Laboratory Manager,
provided information concerning the laboratory operation.

     GSX contracts with  Davis and Floyd,  Inc.  (D&F)  of Greenwood, South
Carolina for  analysis  of  ground-water  samples  from  monitoring  wells at  the
Pinewood facility.   The D&F laboratory assessment was  made,  as part of  the
GSX inspection, during the period November 5-7, 1985 and included assessment
of  the  laboratory's capability to  collect,  receive,  handle and analyze
ground-water samples for GSX.   D&F personnel contacted during the assessment
included E. Carl  Burrell, Laboratory Director; John H. McCord,  Laboratory
Supervisor and Quality Assurance  Coordinator and Gerald T. Smith,  Analyst.

ONSITE LABORATORY FINDINGS

     The onsite laboratory  at GSX has a written Waste Analysis  Plan (WAP)
as  required by  R.61-79.265,  Subpart B.  The laboratory has  the  personnel,
equipment and space  necessary to complete representative  checking of all
waste loads received.  All waste accepted by the facility is accompanied by
a manifest which references a "Waste Product Survey" (WPS) form.  This  form
lists the results of the  physical and  chemical  analyses of the waste, done
prior to acceptance by GSX.   The "Waste Product Survey" form for each waste
is filed at GSX.   Trucks are stopped at the laboratory and held  in a parking
area until representative samples of the waste load are taken and analyzed.
The samples are analyzed to determine if they are organic, acid  or alkaline
so that the waste can be routed to the appropriate cell of the landfill for
disposal.   Samples are checked to determine if any excluded wastes are  pre-
sent in the load.   The samples are also analyzed for parameters that were
selected from the "Waste  Product  Survey" form  that  would allow the labora-
tory to state, with some certainty,  that the waste received  at that time is
the same waste that  GSX agreed  to accept in  the first  place.   The analysis
results are recorded on  the "Sample Evaluation  and Material Description"
(SEMD) form.  These  forms are also filed  at GSX.   Different  wastes from

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                                                                         60
the same company, but a different company site has a separate pre-acceptance
form.  Samples  of  wastes  are labeled and stored in the onsite laboratory.

CONTRACTOR LABORATORY FINDINGS

     During the  inspection  of D&F,  NEIC  personnel  used the  sampling  of  new
wells  in  October 1985 to document  continuity  between  sampling,  chain-of-
custody, analytical  methodology,  quality control and data reporting.  The
samples collected in October did not serve as quarterly samples because the
wells  were  new  and  had  not  been developed at that  time.   The  samples taken
from GSX were  analyzed  for background levels  of the parameters  listed  in
R.61-79.265.92 plus volatile, semivolatile and pesticide priority pollutants.

     Sampling is done by D&F employees who function as samplers and  analysts.
Each sampler must qualify in the field under the supervision of experienced
samplers.   The  sampling protocols for each client  are  compiled in a  manual
entitled,  "Groundwater Sampling and Analysis Plan."  D&F is assisted at GSX
by a person experienced in the use of a Well  Wizard pump.  Sample containers
leave  D&F with preprinted labels applied and arrive at GSX organized accord-
ing to well  site and parameter type.  The preprinted  labels do not have
unique numbers.  A  chain-of-custody form is filled in by D&F at each well
site.   Each  sample  is  identified by its well  designation  and analyses
required.    Samples  arriving at the  laboratory  are received by a sample
custodian and recorded  in  the D&F sample log.   Sample containers for each
well site are assigned a laboratory number.   Samples are logged into param-
eter books  so  that  analysts are aware of what  samples  are  to be analyzed
next.

     Specific conductivity and pH were determined in the field.   Temperature
correction of the results was not conducted.   Samples  collected  for  metals
were filtered before analysis, thereby generating data for dissolved metals
instead of  total.   Drinking water standards are based,  however, on  total
metals.  Therefore,  the GSX analytical  methods are not consistent  with
those  required  for  drinking water supplies.   The  chief  objection is that
for drinking  water parameters  to be determined [R.61-79.265.92], total
metals and not dissolved metals are required.

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                                                                         61
     D&F analyzed  water  samples  from  GSX  using  the  methods  listed in  Table
17. There  is  a single GCMS used to analyze VGA's, base/neutrals  (BNs) and
acids.  The instrument  is set up to run VOAs first, then BNs, then acids.
BNs and  acids are  also  run on GCFID,  if  necessary,  to avoid exceeding
holding times.  D&F has a service contract on their GCMS.  They can usually
get service in 2 days.

     All instruments  were in  working order at the time of the inspection.
Samples are received  and extracted in the same room.  Organic samples are
extracted on an open bench.  A single hood is operational in the  extraction
laboratory and is located at the far end of the room.

     The VGA  and BNA  results  of the  samples  analyzed showed methylene
chloride, acetone,  MEK,  toluene  and phthalates in the samples and blanks.
Therefore, the results are not reported.

     The QC/QA procedures used at D&F are outlined in their manual, "Labora-
tory Quality  Control  Manual."  No VGA matrix spike  compounds were added  to
a  real  sample, so  no conclusion can be made about method  accuracy and
precision for  the  samples analyzed.  Spike compounds  were  added  to blank
water; the  analytical  results  from these  spiked  blanks were acceptable,
demonstrating that the laboratory is capable of obtaining acceptable analyt-
ical results  using  the VGA  method.  Surrogate spike results were  generated
for BN base/neutral extractables and acid; the results were acceptable.  No
other spikes  or  duplicates  were  run for BN and acids because the analysis
request was scheduled as a rush job  according  to instructions from GSX.
Limits of detection (LODs)  were  estimated by extrapolating standard  ref-
erence compounds downward.  LODs were estimated at  2X  background.  Histor-
ically, D&F does maintain Control  Limit Charts that are  used  to  evaluate
spike recoveries.   D&F  has  documentation of regular participation in  the
EPA Performance Evaluation Program in 1985.  Halomethane results  of 7/10/85
were not  acceptable at  low concentrations,  but were acceptable  at high
concentrations.  Pesticide results of 7/10/85 were acceptable.  The phenoxy
herbicide results of 1/4/85 were acceptable.   D&F did not extract laboratory
blanks for  each day  of  extracting samples.   One laboratory  blank was
extracted for  each  batch  of samples regardless  of how  many  days  it took  to

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                                                  62
         Table 17
   ANALYTICAL PROCEDURES
Parameter       Method (SW-846)1
Arsenic
Barium
Beryl 1 1 urn
Cadmi urn
Chromium (T)
Copper
Iron
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Sodi urn
Zinc
Phenols
Endrln
LI ndane
Methoxychlor
Toxaphene
2,4-D
2,4,5-TP (Sllvex)
Cyanides
TOH
TOC
Sul fides
Sulfate
VGA GC/Ms
SNA GC/Ms
7060 or 7061
7080 or 7081
7090 or 7091
7130 or 7131
7090 or 7091
7210 or 7211
7380 or 7381
7420 or 7421
7460 or 7461
7470 or 7471
7520 or 7521
7740 or 7741
7760 or 7761
7770
7950 or 7951
9065
8080
8080
8080
8080
8150
8150
9010
9020
9060
9030
9035
8240
8280
 'Test Methods  for Evaluating
 Solid Waste,  Physical Chemical
 Methods"; US SPA;  July 1982;
 SW-846;   2nd  edition  and
 revision

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                                                                         63
extract a batch.  Batch size was determined by how many samples were listed
on organic extraction bench sheets.  The laboratory was not using decafluoro-
triphenylphosphine or  bromoflurobenzene  to calibrate the GCMS at the time
of the Task Force inspection.

     While both  flame  and furnace atomic absorption techniques are listed
in Table  17,  discussion  with  laboratory personnel  indicated that  flame
atomic absorption spectroscopy techniques are used for all elemental analyses
other than arsenic  and selenium.   The detection limits for lead, chromium
and cadmium cannot achieve reliable results near the drinking water limits,
using the flame spectroscopic technique.   Arsenic and selenium are determined
using a hydride  generation method.  Spiked samples have not been analyzed
and,   therefore,  possible  matrix  interferences  have not been evaluated.

     The analytical  procedure  for TOC is  incomplete  because  the results
represent only  nonpurgable organic  carbon.   Samples are  acidified and
purged with nitrogen gas  prior to determination of organic carbon, which
results in the  loss  of purgable (volatile) organic carbon.  Analysis must
be made for purgable and  nonpurgable organic carbon and the concentrations
summed to calculate a result for total  organic carbon.

     Quality control for  cyanide  determination  is not fully characterized
by the inclusion of  spiked samples.  Matrix interferences  which may create
systematic bias  in the  results are not determined.  The lack of sufficient
glassware is given as the only reason.

     The distillation of  phenol in order to remove matrix  interferences is
employed only if the samples are "colored."  Chemical  interferences are not
necessarily manifested  by physical appearance.   A consistent approach is
needed to eliminate indiscriminate selection of methodology.

     Limits of detection are established in all  of the analytical procedures
by estimation of twice  the background noise level.  Practically, this is a
subjective technique and  a more statistical approach  needs to be employed.

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                                                                         64
         MONITORING DATA ANALYSIS FOR INDICATIONS OF WASTE RELEASE

     Tabulation,  evaluation and  interpretation  of analytical  data for
samples collected during the inspection and analyzed by EPA contract labor-
atories is  discussed,  in detail, in Appendix  A.   Splits  of six of these
samples were  provided  to the  EPA Region  IV  laboratory  for analysis.  These
stations were  the French drain, MW-13, MW-24, MW-19, MW-22 and a leachate
sample.  Inorganic  chemical constituent  analyses of these samples indicate
the presence  of common naturally occurring  cations and anions.  Because of
the newness of the ground-water monitoring system being  evaluated,  it is
not appropriate to attempt  to  undertake  a statistical  comparison of  upgra-
dient  and  downgradient ground-water quality.  This comparison should be
made as soon  as one year of quarterly sampling and analytical results are
available from the new system of wells.  Evaluation of  the EPA contract
laboratory  data from  samples  collected  by the Task Force indicate the
presence of nickel  in samples  from  six  monitoring  wells  and  the French
drain.   The source  of  nickel  in these  samples  should be determined and the
first  year  of  quarterly  sampling and analysis of  the new ground-water
monitoring  system wells should  be  completed  to confirm  whether  or not
ground water at the facility contains hazardous waste constituents resulting
from waste disposal activities.

     A number of the newly-instailed wells were in a well-development stage
during the  Task Force inspection.  GSX  was  pumping  the  wells to remove
fluids introduced  during drilling and  to increase well efficiency.   Turbid
ground-water discharge was  observed in some wells as  were changing  water
quality parameters  (pH and specific conductivity).  Anomalously  high pH
values were observed  in some  wells (e.g.,  MW-26, pH 11.5; MW-20, pH 10).
The Task Force considers the  changing and  anomalously high  values  to be
typical characteristics  of  ground-water  discharge from developing wells.
The turbidity,  specific  conductivity and pH levels will  probably decrease
and stabilize with time.  Stabilization of these parameter values should be
noticeable  in  data  from  subsequent  sampling events as  more water is  pumped
from each well.

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                                REFERENCES
1.   AWARE, Inc., May 30, 1985.  Draft Groundwater Assessment - Supplemental
     Hydrogeologic  Investigation,  prepared  for GSX  Services of  South
     Carolina, Inc., Pinewood, South Carolina

          Vol. I:   Hydrogeologic Report

          Vol. II:  Appendix A - Test Boring and Geophysical Logs
                    Appendix B - Logs of  Test Borings and Test Pits  from
                      Previous Investigations
                    Appendix C - Permeability Data

          Vol. Ill: Appendix D - Water Quality Data
                    Appendix E - Ground Water Monitoring Plan for the SCA
                      Pinewood facility

2.   AWARE, Inc.  (revised),  July 2,  1985, Ground-water Assessment Plan -
     Pinewood Facility, June 6, 1985 - prepared and certified by Michael  R.
     Brothers

3.   AWARE, Inc., July 8, 1985, Draft Groundwater Monitoring Plan; prepared
     for GSX Services of South Carolina, Inc.

4.   AWARE, Inc.,  August 14, 1985,  Additional Hydrogeologic Data -  GSX
     Services of South Carolina,  Pinewood Facility

5.   AWARE, Inc.,  September 12,  1985,  Groundwater Assessment Report -
     Pinewood Facility

6.   AWARE, Inc., November 6, 1985, Phase IV Hydrogeologic Report:  Prepared
     for GSX of South Carol in*

7.   AWARE, Inc.,  December  13, 1985, Groundwater Assessment • Supplemental
     Hydrogeologic Investigations,

          Vol. I:   Hydrogeologic Report

          Vol. II:  Appendix A • Test Boring and Geophysical Logs

          Vol. Ill: Appendix B - Logs of  Test Borings and Test Pits  from
                    Previous Investigations
                    Appendix C - Permeability Determinations

          Vol. IV:  Appendix D • Summary of Laboratory Test Results
                    Appendix E - Ground-Water  Monitoring Plan for the SCA
                      Pinewood Facility

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                           APPENDICES

A    TASK FORCE ANALYTICAL RESULTS
B    LANDFILL EXCAVATION AND OPERATIONAL PLANS

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         APPENDIX A



TASK FORCE ANALYTICAL RESULTS


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                                                                         A-l
                                Appendix A
         ANALYTICAL TECHNIQUES AND RESULTS FOR TASK FORCE SAMPLES
                           GSX SERVICES FACILITY
                         Pinewood, South Carolina

     The following discusses analytical techniques, methods and results for
water and  leachate  samples  collected by  the  Task  Force  at the  GSX  Services
facility,  Pinewood,  South Carolina.   Water sample analyses  and results  are
discussed  in  the  first section; the  second section addresses the leachate
analyses and results.

     Field  measurements  on water samples, including  conductance,  pH and
turbidity were made by the EPA sampling contractor at the time of sampling.
No field measurements were made for the leachate samples.  Laboratory anal-
ysis results were obtained from two EPA contractor laboratories (CL) partici-
pating in the Contract Laboratory Program (CLP).  One CL analyzed the samples
for  organic compounds while  the other  analyzed  for metals  and other
parameters.

     Standard quality  control measures were  taken including:   (1)  the ana-
lysis of field and  laboratory blanks  to  allow distinction of possible con-
tamination due to sample handling, (2) analysis of laboratory spiked samples
and  performance evaluation  samples  and comparison of the CL results with
split sample  results  from other  laboratories  to estimate accuracy,  and  (3)
analysis of laboratory duplicates and field  triplicates to  estimate preci-
sion.  The performance evaluation samples were samples of  known analyte
concentrations prepared by the EPA Environmental Monitoring Systems Labora-
tory, Cincinnati, Ohio.  The  Region  IV  laboratory analyzed split  samples
from wells  MW-11, MW-13, MW-14 and  MW-22,  the  French drain  and  the
Section I-A organic disposal cell leachate.   The  State  laboratory  analyzed
split samples from wells MW-11, MW-13, MW-14 and MW-22.   Split samples from
well MW-13, the French drain and the  Section I-A organic disposal cell leach-
ate were analyzed by NEIC.

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                                                                         A-2
     Table A-l provides a summary, by parameter, of the analytical techniques
used by the CLP laboratories and the reference methods for the sample analyses.
The CLP results are reported in the data tables and the split sample results
from the  other  laboratories  are  discussed  where  applicable  in  establishing
the reliability of the CLP results.

WATER SAMPLE ANALYSIS RESULTS

Specific Organic Analysis Results

     Less than 2 ug/L of 1,1,1-trichloroethane was found in the sample from
well MW-23.  This compound was not detected in any of the blanks and examin-
ation of  the  chromatograms  and mass spectra  confirm  the presence  of this
compound  in the  sample  analyzed.   None  of  the organic compounds determined
were detected above  blank levels in other monitoring well  samples or the
French drain sample.   Table A-2 contains the  limits of quantitation for the
analysis  for  the  volatile,  semivolatile and  pesticide organic compounds.
Based on the matrix spike data, the volatile  organic  limits of quantitation
are reliable to within a factor of two, the neutral extractable organic and
pesticide limits  are  reliable  to within factors of  2 to 4 and the acid
extractable organic limits to within factors  of 2 to 10.

     The  CL determined  1,4-dioxane by both direct injection and purge and
trap.   The results did  not agree qualitatively or  quantitatively.  No 1,4-
dioxane was detected in the samples form MW-23A by the purge and trap meth-
od, while the direct injection method found  concentrations of 25,000 ug/L
and 4,000 ug/L  of 1,4-dioxane  in 2 of  the 3 samples collected from well
MW-23A.   The 1,4-dioxane was not detected  in  the third MW-23A sample.  The
well MW-23A sample was  found to contain only  1 mg/L organic carbon which
does not substantiate the presence of the  large 1,4-dioxane concentrations.
Direct injection  chromatograms for some of  the  blanks show interference
near the  retention time for 1,4-dioxane for  masses 58 and 88  (the masses
used to monitor  1,4-dioxane).   Further, none of the direct injection com-
pounds in the performance evaluation sample were detected by the CL.

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                                                                         A-3
Because of  the  apparent erroneous direct  injection  analysis  results,  the
direct injection compounds should be considered to have not been determined.

     Methylene chloride, acetone and 2-butanone were detected in all labora-
tory and  field  blanks.   Bis(2-ethylhexyl)phthalate  and di-n-butylphthalate
were also detected in the laboratory blanks.  None of  the sample concentra-
tions for  these compounds  exceeded the  upper  99% confidence  limit of  the
blank values after subtraction of the average blank contaminant concentration.

     None of  laboratories that analyzed  split  samples  detected  any compund
above blank levels in the well samples or the French drain.  The direct in-
jection and herbicide  analyses were not performed by  the laboratories for
the split samples.

      Metals Analysis Results

     The dissolved and  total  metals  results for the  groundwater monitoring
well samples  and  the French drain sample  are  reported in  Table A-3.   The
accuracy of each detectable value is footnoted in the  table.

     Besides  zinc,  the  only  other priority pollutant element detected
frequently was nickel.   Nickel was detected in samples from six of the wells
and  the French drain.   In many of these samples the nickel was in a dissolved
form.   Control  measures indicate  the reported  nickel results  are reliable.
Further, split  sample  results from NEIC and Region  IV for well MW-13  and
French drain  agreed  to  within a few parts per billions of the reported CL
values for nickel.

     The dissolved elemental  concentrations for many  of  the  samples are
biased high.  Mismatching of  the calibration standards acid matrix to the
dissolved preserved  sample acid matrix was  the cause of the bias.   In  com-
parison to  split  sample results the bias does  not exceed 20%  for the major
and trace elements with the exception of  zinc. Zinc contamination due to
sample handling was  evident  as many of  the dissolved  zinc concentrations
were greater  than the total zinc  concentrations." For  example,  a dissolved
zinc concentration of 88 ug/L was reported for well MW-17 while the total
zinc was reported as 33 ug/L.   Further, one of the total zone spiked samples

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                                                                         A-4
had a recovery of only 22%.  Therefore, zinc concentrations are not reported
in the data tables.

     Although antimony was determined,  the  results were  unreliable  and are
not reported.  The  lower  99% confidence limit  for the  spike  recoveries was
below zero.  The low antimony spike recoveries may be related to the spiking
standards  use by  the CL.   Tin spike  recoveries  were  also low, however,
little variability was observed in the spike recoveries indicating a problem
with the  spiking  standard mix.   No tin was detected and the tin detection
limits have been raised to reflect the  low spike recovery.

     The  split sample  results,  in general, agreed to within 20% of the CL
results.

     General Analysis Results

     The  field  measurements for  conductance,  pH and  turbidity and the
results of other analytical testing for groundwater monitoring well samples
and the French drain sample are reported  in Table A-4.   The  reliability  of
each detectable value is footnoted in the table.

     The performance evaluation sample had true pH of 7.1 which is what was
obtained by the field crew.  Based on past comparisons with concurrent field
measurements, the pH values  are indicated to be reliable to within 0.5 pH
units.

     The  conductance values are  not very reliable.  The  performance eval-
uation sample has  a true  conductance of  552  umhos/cm  and  the field crew
obtained a value of 330 umhos/cm after temperature and cell constant correc-
tions.  The bias would appear to be negative based on the performance evalua-
tion sample  result,  however, comparison with split sample  results obtained
by NEIC indicates the error is not  systematic.  After  temperature and cell
constant  correction  values of  430 umhos/cm and 390 umhos/cm were obtained
or samples  from well MW-13 and French drain using the field crew measure-
ments.   NEIC obtained  values  of 310 umhos/cm  and 320  umhos/cm for split

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                                                                         A-5
samples from  well  MW-13 and the  French  drain,  respectively.   Data tables
indicate that reported conductance values are probably reliable to within
about 200 umhos/cm.

     For a number of the well samples, the reported purgable organic halogen
(POX) values  are  greater than the  respective  total  organic halogen (TOX)
values.   For  example,  a POX value  of  114 ug/L was reported for the well
MW-24 sample  while  the TOX was reported by  the CL as  non-detectable  at 5
ug/L.  Review of  the TOX data found  the detection limit was actually 30
ug/L based on the standard deviation of  the blanks.  The spiked sample data
and the performance evaluation sample values show  no indication of substan-
tial bias  for either determination.  NEIC determined  POX for  well MW-13
and the French drain samples and values  of 10 ug/L and 3 ug/L were obtained,
respectively.  The  CL  reported POX values of 11 ug/L for well  MW-13 sample
and less than 5 ug/L for the French Drain sample.  The positive POX values,
however, are  not  supported  by the specific organic analyses as no  organics
were detected  in  the wells. These anomalies cause the POX and TOX data to
be suspect and they are indicated as such in the data tables.

     Although  purgable organic carbon (POC)  was determined, the results
were determined to  be  unreliable and are not reported.  The CL reported a
value for  the performance evaluation  sample  that was about  15% of  the  true
value.

     The non-purgable  organic  carbon  (NPOC)  values are biased high by as
much as a factor of 2.   This was determined by comparison of the CLP values
to the split  sample values  obtained by  NEIC, Region IV and the State. For
example, the  CLP  reported  a value  of  3.8 mg/L  for the  French  drain while
NEIC and Region  IV  obtained a value  of  1.7  mg/L .   For samples  from well
MW-14,  the CLP reported a NPOC value  of  3.8  mg/L,  while Region IV  reported
1.9 mg/L and  the  State reported 1.2 mg/L.  The  CL  NPOC  values  are  reported
in the data table and are indicated to be biased high.

     The chloride values are biased high by  as  much as a factor of two.
The CLP chloride values were always higher than those obtained by Region IV
or NEIC.   For example, the  CLP reported a value of 7 mg/L  for the French

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                                                                         A-6
drain while Region IV reported 4.5 mg/L and NEIC reported 4.4 mg/L   The CL
chloride values are  reported in the data tables  and  are indicated to be
biased high.

     Samples collected  for  nitrate analyses were perserved with sulfuric
acid which is appropriate only when distinction between nitrate and nitrite
is not  needed.  Samples  collected  for  nitrate  analysis should be cooled to
4ฐ C. and analyzed within 48 hours a collection.  Further, the colorimetric
method  used  is  subject  to positive interferences that were apparently not
compensated  for by  the  CL procedure.   This  is  indicated  in comparison of
the CL  results  to the split  sample results  obtained by NEIC, Region  IV and
the State.   For example, the CL reported a nitrate value of 0.56 mg/L for
the sample from well MW-13,  while  NEIC and  Region IV  found less than 0.05
mg/L and the State reported 0.02 mg/L.   NEIC analyzed samples by ion chroma-
tography that were  cooled to 4'C and acidified.  No nitrite was detected.
Region IV determined nitrate plus nitrite.   Thus the CL nitrate results are
biased  hugh  due to  interferences other than nitrate.   The nitrate results
are unreliable and not reported in the data table.

LEACHATE SAMPLE ANALYSIS RESULTS

     Specific Organic Analysis Results

     Table A-5  reports  the organic constituent analysis  results  for the
three leachate samples.   Large amounts of volatile and semi-volatile organic
compounds were detected  in all three leachate samples.

     Although, 1,4-dioxane was detected by the CL in samples from the alka-
line leachate and the acid  leachate, the results  could not be confirmed as
discussed above and thus the results are not reported.

     In consideration of the different dilutions analyzed, thus different
detection limits,  fairly good agreement was obtained between the split sample
analyses performed  by NEIC and Region IV and  reported  CL values for the
organic leachate samples.   Generally  the volatile organic concentrations

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                                                                         A-7
agreed to within a factor of 2 while the extractable organic concentrations
generally agreed to within  a  factor of 3.    Vinyl  chloride was detected by
the CL and  Region  IV but not by NEIC.  NEIC found 180,000  ug/L 2-propanol
while the CL and Region IV did  not analyze the sample for this compound.
NEIC also detected  three pesticides below  the  CL  detection limits.   NEIC
found 3  ug/L aldrin,  37 ug/L dieldrin  and  19  ug/L heptachlor.   Region  IV
reported 10 ug/L dieldrin.

     Metals Analysis Results

     The dissolved and  total  metals results for the  leachate  samples are
reported in  Table A-6.   Depending on the suspended matter  compositon, the
values reported  for  certain elements may not represent "total" concentra-
tions.    If  the  suspended matter is  siliceous,  then  values for aluminum,
calcium, magnesium, potassium and  sodium  are not "total"  because the  sili-
cate matrix   was not dissolved.  The heavy  metal results  would approximate
"total".concentrations  because  they are usually absorbed and  are not en-
corporated in the silicate matrix.

     In camparison to the split sample results the CL total values reported
for the  organic  leachate are biased low.   The  CL  dissolved values  are  in
much better  agreement with  the total value's found by  NEIC and Region IV.
There was very little difference between the dissolved and  total values  for
the split sample analyses.   Other than zinc, nickel was  the only priority
pollutant element detected  at significant concentrations.   NEIC found 1200
ug/L total  nickel,  Region IV reported 1000 ug/L  and the CL reported 780
ug/L total  nickel and  982 ug/L dissolved nickel  in the  organic leachate
sample.   The  CL reported nickel  concentrations of  about 3000 ug/L and
20,000 ug/L respectively for the alkaline and acid leachate samples.

     Although mercury was determined,  the values were  determined to be  un-
reliable because a spike recovery of only 10% was obtained.  Mercury values
are not  reported.  Interference  also precluded  accurate determinations  for
arsenic,  selenium and thallium.

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                                                                         A-8
     General Analysis Results

     Table A-7 reports the results of other testing for the leachate samples.

     The calculated  POX  from the specific volatile organic results  for the
organic  leachate  was 60,200  ug/L.  The measured POX was 53,300 ug/L while
the measured TOX  was only 45,400 ug/L.   This  indicates  the POX values  have
less  of  a  negative  bias  than  the TOX values. A substantial  difference,
however, exists  in the calculated POX of 18,200  ug/L  for  the  acid leachate
and the measured  POX of 92,000 ug/L.  The measured TOX  for this  sample was
33,800 ug/L.   Based on  the organic carbon measurements, the acid leachate
contained about  fifteen  times the organic matter  as  the  organic  leachate
which may add  some validity  to the POX  being  higher.  If  the  POX  is not in
error, then the  specific organic analyses were not sensitive to the halo-
genated compounds that comprise  the POX, or the concentrations are biased
low or there may  have been difficulty in obtaining representative samples.
The measured POX  of  less than 50 ug/L for the alkaline leachate is  in agree-
ment  with  specific organics  results where no halogenated compounds were
detected.  The measured TOX for the alkaline leachate was 11,800 ug/L which
indicates that the specific organic analyses were not sensitive to  the halo-
genated compounds that comprise the TOX.

     As discussed above  POC  and nitrate were  determined,  but the results
have been determined to be unreliable and thus are not reported.  The ammonia
and NPOC split sample results for the  organic  leachate are in agreement
with CLP values.  Split sample values differed by less than 5% for  NPOC and
less than 15% for ammonia.

     The CL reported a chloride value of 8910 mg/L for the organic  leachate
while Region IV  reported 9100 mg/L.  NEIC found only 5000 mg/L chloride,
however,  8000  mg/L bromide was also present  in  the sample.  The CL and
Region IV  used a  titration  that does not distinguish between  chloride,
bromide or iodide.  NEIC used ion chromatography for the anion analyses and
the presence of  bromide  was  also confirmed by plasma source mass spectro-
scopy.  The  total milliequivalences of  chloride  reported by the CL and

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                                                                         A-9
Region  IV were 251  meq/L and  257 meq/L,  respectively.   The chloride
concentration  found  by NEIC is equivalent  to  140 meq/L while the bromide
concentration  is  equivalent to 100 meq/L.  The total  halide found by the
laboratories was  equivalent.   Thus it is likely  that chloride values  for
the other two  leachate samples also include substantial portions of bromide.
The bromide to chloride ratio in the organic leachate  is unique when compared
to a  freshwater  ratio of about one part bromide to 300 parts  chloride.
Because bromide and chloride have high mobility, this  unique ratio may be a
good  indicator for future ground-water monitoring to detect possible leakage
of the disposal cells.

      Total bromine as determined by plasma source mass spectroscopy for the
NEIC  split  samples  from well MW-13 and the  French drain  was 44 ug/L and 82
ug/L, respectively.   Using  NEIC chloride values  for  these samples, total
bromine to  chloride  ratios  of one to 89 and one to 54 were calculated for
the samples from  from well MW-13 and the French drain, respectively.   Samples
from  upgradient wells were  not available for analysis by NEIC to  determine
the naturally occuring ratio in the near vicinity.

      None of  the laboratories  detected  cyanide in the  organic  leachate
samples.  However, the CL values  for the other two leachate samples may be
unreliable because the holding time of 14 days was exceeded.

      The  sum of  the  phenolic compounds  detected  by  the specific organic
analyses was 2820 ug/L for the organic leachate, 3400  ug/L for the alkaline
leachate  and 10,600  ug/L  for the acid leachate.  Because of the generally
low recovery obtained by  the specific organic analyses, one  would expect
these totals to be biased low.   However, these values  compare well with the
colorimetrically measured values reported in Table A-7.  Region IV obtained
a colorimetric phenol  concentration  of 1400 ug/L for the organic leachate
while the CL reported 2500 ug/L.  Further, the CL obtained a spike recovery
of 160%.  Comparison  with the  Region IV  value  and the high spike  recovery,
would seem  to  indicate a  high  bias in the CL values  which  is  contradictory
to the  conclusion that would be drawn from the comparison with the sum of
specific phenolic compounds concentrations.   These discrepancies may be due

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                                                                         A-10
to the inablility  to  obtain a representative sample.  The phenol data for
leachates are Indicated to be reliable to within a factor of two.

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                  Taola A-2

LIMITS OF QtMNTITATION ซ• MGMIIC COMPOUNDS
       GSX SERVICES OF SOUTH CAMLIN*
          Unmood. Sautli Caraltna
U1ซ1t af Uojlt of Halt af
Quant1tat1an Quant1tat1on Quant 1tซt1 on
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                                   Table A-5

                  Organic Analysis Results  for  the  Leachate  Samples
                         GSX Services  Facility,  Plnewood,  SC
Station:
Compound (a)
Methyl ene chloride
Bromodlchloromethane
Chloroform
Carbon tetrachlorlde
Carbon dlsulflde
1 ,2-01bromoethane
l,l-01chloroethane
1,2-Oichloroethane
1,1,1-Trlchloroethane
1 ,1 ,2-Tr1chloroethane
1 ,1 ,2,2-Tetrachloroethane
Vinyl chloride
l,l-01chloroethene
Trans-1 ,2-d1chloroethene
Trlchloroethene
Tetrachloroethene
1,2-Olchloropropane
Benzene
Chlorobenzene
Ethylbenzene
Toluene
Xylenes
Acetone
2-Butanone
4-Methyl-2-pentanone
Styrene
Aniline
Benzyl alcohol
81s(2-ethylhexyl)phthalate
Butyl benzyl phthalate
01-n-butylphthalate
Olethylphthalate
01methylphtha1ate
Acenaphthy lene
Olbenzofuran
Fluorene
Isophorone
Naphthalene
2-Methylnapthalene
Phenanthrene
Benzole acid
Phenol
2-Chlorophenol
o-Cresol
p-Cresol
2, 4-01methyl phenol
2.4-0
LOQ Factors (d)
Volatlles
Adds
Base/Neutrals
Pesticides
Herbicides
Add
Leachate
2000.
360. c
7900.
310. c
2500.
2200. c
NO
NO
NO
NO
230. c
HO
NO
370. C
370. C
1200.
260. c
6600.
27000.
6700.
13000.
51000.
700000.
20000.
4700.
NO
NO
17000.
NO
490.
NO
2100.
2200.
NO
NO
NO
NO
2500.
NO
NO
24000.
8300.
NO
NO
NO
2300.
84.

200X
40X
40X
100X
100X
Alkaline
Leachate
NO b
NO
NO
NO
NO
NO
NO
NO
NO
NO
640. C
NO
NO
190. C
NO
NO
NO
6900.
NO
29000.
25000.
130000.
11000.
NO
3400.
43000.
53000.
NO
700. c
NO
HO
NO
NO
NO
NO
NO
NO
35000.
460. C
NO
NO
NO
NO
NO
3400.
NO
NO

200X
400X
200X
100X
100X
Organic
Leachate
1000.
NO
NO
NO
NO
NO
570.
3100.
15000.
11000.
NO
2700.
380. C
6900.
4500.
34000.
NO
1600.
1300.
NO
5600.
NO
78000.
11000.
2400.
NO
NO
100.
93. c
NO
31. c
NO
MO
50. c
32. c
38. c
430.
360.
77. c
53. c
1000.
780.
130.
140.
690.
77. c
NO

100X
20X
20X
100X
100X
a) Concentrations are fn ug/L.
b) NO Indicates not detected at LOQ given  1n Table A-2  after multiplication
   by LOQ factor.
c) Values are estimated.  Mass spectra matched  compound Identified  but  the
   concentration Mas less than LOQ.
d) LOQ factor 1s the factor the LOQs given Table A-2  are  to be  multiplied by
   to correct LOQ values for the analysis  dilution.

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                                      FIGURE B-5
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Leachate Collection Lateral .Construction
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-------
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U.S. Environmental Protection Agency
Region 5, library (ft., i 2j)
77 West Jackson Boulevard, 12th Floor
Chicago, IL  60604*3590

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