November 1986
EPA-330/2-87-001
Hazardous Waste Ground-Water
Task Force
Evaluation of
Uniform Tubes, Inc.
.Collegeville, Pennsylvania
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
-------
1
jf\ '
1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
November 23, 1986
UPDATE OF THE HAZARDOUS WASTE GROUND-WATER TASK FORCE
EVALUATION OF UNIFORM TUBES, INC.,
CDLLEGEVILLE PENNSYLVANIA
The United States Environmental Protection Agency's Hazardous Waste
Ground-Water Task Force (Task Force) conducted an evaluation of the ground-
water monitoring program at the Uniform Tubes, Inc. (UTI), hazardous waste
treatment and storage facility in Collegeville, Pennsylvania, The onsite
field inspection was conducted during the period of April 8 to 11, 1986. UTI
is one of 58 facilities that are to be evaluated by the Task Force. The
purpose of the Task Force evaluations is to determine the adequacy of a
facility's ground-water monitoring program in regard to the applicable State
and Federal ground-water monitoring requirements. The Task Force effort came
about in light of the recent concerns as to whether operators of hazardous
waste treatment, storage and disposal facilities are complying witn the State
and Federal ground-water monitoring regulations.
The evaluation of the UTI facility focused on determining (1) if- the
facility was in compliance with applicable regulatory requirements and policy,
and (2) if hazardous waste consituents were present in the ground water. The
inspection revealed that UTI was not fully complying with applicable interim
status ground-water monitoring requirements and that ground-water samples Iron,
onsite wells contained hazardous waste consituents, This update provides
information on ground-water related activities by UTI, EPA Region FIT and the
Pennsylvania Department of Environmental Resources (DER) since the Task Force
inspection.
In May 1986, personnel from UTI, EPA Region III and DER met to discuss
the revised work plan for a subsurface investigation at the facility. The
work plan was initially submitted in February 1986 and was evaluated by the
-------
j Task Force, The plan was subsequently revised, approved by the State and
implemented in June 1986, The investigation included sampling and analysis
iof soil and soil gas, and installing additional monitoring wells. The results
of that investigation should be provided to EPA Region 111 and DER in January
1987,
| EPA Region III is working with UTI to address noncompliance with interim
status requirements tor the ^round-water monitoring program and ground water
I contamination.
J UTI has decided to close the regulated units (surface impoundments) and
' has withdrawn its RCRA Part B permit application. A closure plan and several
1 revisions have been submitted to the State for approval. A final plan was
approved by the State in September 1986. UTI plans to close the impoundments
during the spring of 1987. Construction of a separation unit to replace the
J impoundments is scheduled to be completed by Ja.nu3.ry 1987,
i This completes the Hazardous Waste Ground-Water Task Force evaluation of
the Uniform Tubes, Inc., facility.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGEND
HAZARDOUS WASTE GROUND-WATER TASK FORCE
EPA-330/2-87-002
GROUND-WATER MONITORING EVALUATION
UNIFORM TUBES, INC,
Collegeville, Pennsylvania
November 1986
Steven W. Sisk
Project Coordinator
National Enforcement Investigations Center
-------
CONT[NTS
E>':CL'Iv'E SUMMAP^
SUMMARY OF FINDINGS AND CONCLUSIONS . . 6
GROUND-WATER MONITORING DURING INTERIM STATUS , &
Ground-Water Sampling and Analysis Plan ,,,,., 6
Sampling and Analysis Procedures , . , ....... 7
Monitoring Well Network ... ...... 8
Assessment Program Outline and Plan , . 9
TASK FORCE SAMPLING AND MONITORING DATA EVALUATION . , . . . 10
TECHNICAL REPORT
INVESTIGATION METHODS ..... 14
RECORDS/DOCUMENTS REVIEW . , 14
FACILITY INSPECTION ...... , . ,15
LABORATORY EVALUATION ...... , ......... 15
SAMPLE COLLECTION AND ANALYSIS ........ 15
FACILITY DESCRIPTION . . ..... . . 22
PROCESS OPERATIONS ...... . . - 22
WASTEWATER PRETREATMENT FACILITY ... . 24
PRE-RCRA SOLID WASTE MANAGEMENT UNITS .... 27
Concentrated Acid Storage Tank ... , 27
Original Spray Field . . .... . 27
Original Wastewater Treatment Facility . ... 29
Cesspools and Septic Tanks ..... . . . ' . , . . 29
Naphthol Storage Tanks ....... ............ 29
TCE/TCEA Storage Tanks ....... . . ..... 30
GROUND-WATER REMEDIATION SYSTEM .... , 30
Stripping Tower ..... 31
Spray Field ..... , 31
SITE HYDROGEOLOGY . . .... 34
HYDROGEOLOGIC UNITS ........... ,35
GROUND-WATER FLOW DIRECTIONS AND RATES , 3?
GROUND-WATER MONITORING DURING INTERIM STATUS 42
REGULATORY REQUIREMENTS . ..... . . 45
GROUND-WATER SAMPLING AND ANALYSIS PLAN ... 48
MONITORING WELuS ....... . 50
Well Construction ... .... ....... 53
We11 Locations ... .... 55
UTI SAMPLING PROCEDURES . . , ... ,56
water Level Measurements ... ... 56
Purging ........ ... ..... 57
Sample Collection . 58
Snipping and Chai n-cf-Custody ... 59
-------
COMTEK'S (cent )
SAMPLE ANALYSIS AND DATA OUALJTV EVALUATION . 60
Interim Status Analyses . , 69
GROUND-WATER QUALITY ASSESSMENT PROGRAM OUTLINE AND PROGRAM 65
Assessment Outline . . , . . ,66
Assessment Program Plan 67
EVALUATION OF MONITORING DATA FOR INDICATIONS OF WASTE RELEASE ... 69
APPENDICES
A BORING LOGS FOR UTI WELLS
B GROUND-WATER QUALITY ASSESSMENT OUTLINE AND PROGRAM PLAN
C ANALYTICAL TECHNIQUES AND RESULTS FOR TASK FORCE SAMPLES
D UTI MONITORING DATA FOR JULY AND SEPTEMBER 1985
FIGURES
1 Site Location Map , , , , , 2
2 Waste Management Area and Adjacent Wells , 11
3 Task Force Sampling Stations .,,.., , 16
4 UTI Plant Layout , ........... 23
5 Wastewater Pretreatment Facility , . , , 25
6 Pre-RCRA Solid Waste Management Units 28
7 Ground-Water Remediation System ,...,,... 32
8 Regional Flow Map by Weston , ........... . . , 38
9 Spill Monitoring wells .,......,.,.. 51
10 Interim Status Monitoring Wells , , . ,.,,.. 52
TABLES
1 Selected Inorganic Data from Task Force Samples, .....,.., 13
2 Decontamination Procedures , . . . . ...... 18
3 Purging and Sampling Data 20
a Order of Sample Collection,, Bottle Type and
Preservation ust , , . . 21
5 Depth-to-Water Data . , 40
6 Timeline of Activities Related to Ground-Water Monitoring . , 44
7 State and Federal Counterpart Interim Status Regulations . . , . 46
8 Construction Details for Interim Status Wells .... 54
9 Ground-Water Monitoring Parameters and Frequency 61
10 Organic Compounds in Task Force Samples 70
11 Selected Inorganic Data from Task Force Samples ........ 71
-------
EXECUTIVE SUMMARY
-------
-------
INTRODUCTION
Concerns have recently been raised about whether hazardous waste
treatment, storage and disposal facilities (TSDFs) are complying with the
ground-water monitoring requirements promulgated under the Resource Conser-
vation and Recovery Act (RCRA)*, In question is the ability of existing or
proposed ground-water monitoring systems to detect contaminant releases
from waste management units, To evaluate these systems and determine the
current compliance status, the Administrator of the Environmental Protection
Agency (EPA) established a Hazardous Waste Ground-Water Task Force (Task
Force), The Task Force comprises personnel from the EPA Office of Solid
Waste and Emergency Response, Office of Enforcement and Compliance Monito-
ring, National Enforcement Investigations Center (NEIC), Regional Offices
and State regulatory agencies. The Task Force is conducting in-depth,
onsite investigations of TSDFs with the following objectives:
Determine compliance with interim status ground-water monitoring
requirements of 40 CFR Part 265, as promulgated under RCRA or the
State equivalent (where the State has received RCRA authorization)
Evaluate the ground-water monitoring program described in the
RCRA Part B permit application, submitted by the facility, for
compliance with 40 CFR Section 270.14(c)
Determine if the ground water at the facility contains hazardous
waste or constituents
Uniform Tubes, Inc. (UTI) is located in Collegevilie, Pennsylvania
[Figure 1], which is about 20 miles northwest of Philadelphia, The onsite
inspection was conducted from April 8 through 11, 1986 and was coordinated
by NEIC personnel.
Regulations promulgated under RCRA address TSDF operations, including
ground-water monitoring to ensure immediate detection of any hazardous
waste or constituents released to the environment.
-------
Figure 1
Site Location Map
Uniform Tubes,Inc. Facility
Collegeville, PA
•• ?->v-"/•' '••••• > - 7^-j^ in
•-. '^X;^ - /•.--- T : V-^^tf / - \
^'^4^^. _X cC
\ / -' *"'^>4i;./coii«»7m;-^^\-'•.';>\\ ../-"Y ,- -,' '..rvV-11 -
•" "' "'"' ' '
SftfS^Rs§'^^Sfete -
'fC^C/y'' '_^>l -^-y ^7^••"'^~r^''---?* '•*..-*'i-'^''~*t: *•/ 'r^\
•Xi'.Hv'V.^X^^'- -^-^i <
-------
UTI pretreats process wastewater in two waste management units (surface
impoundments), which are subject to RCRA ground-water monitoring require-
ments. The Company plans to close these units and withdraw its permit appli-
cation for a RCRA permit. Consequently, the ground-water monitoring program
proposed in tne Part B application was not evaluated for compliance with 40
CFR Section 270.14(c).
During the inspection, Task Force personnel evaluated compliance with
the interim status ground-water monitoring requirements of 40 CFR Part 265
and the Pennsylvania equivalent regulations [25 PA Code Section 75,265(n)],
The adequacy of the ground-water sampling and analysis plan, monitoring
well construction and location, analysis of samples taken from the interim
status monitoring wells and the ground-water quality assessment program
outline and plan were evaluated. Information was also obtained on present
and past solid waste management units to aid in evaluating the well network
and interpreting ground-water monitoring data. The evaluation involved a
review of State, Federal and facility records; facility and laboratory
inspections; and collection and analysis of samples from ground-water moni-
toring wells, one of the surface impoundments and a stripping tower,
UTI manufactures high-precision, small-diameter metal tubing and tubular
parts at the Collegeville plant. The plant property was purchased by the
Company in 1964. At that time, the plant area and surrounding property
were farmland. The plant area was subsequently developed into a 40-acre
industrial complex and is now surrounded by a residential area.
The pretreatment system for process wastewater comprises a control
building, three tanks, and two surface impoundments; the latter are used as
settling basins. The pretreatment system effluent is discharged into the
Collegeville-Trappe Municipal Authority sewer system. Solids from the set-
tling basins are periodically removed and taken to the Waste Conversion
facility in Hatfield, Pennsylvania.
Interim authorization was delegated to the Pennsylvania Department of
Environmental Resources (DER) in May 1981. Final authorization was dele-
gated in January 1986. Consequently, the surface impoundments have been
-------
operated under State interim status requirements (State and EPA ID No.
PAD002344463) since May 1981,
Between July 1981 and November 1983, no ground-water monitoring, pur-
suant to DER interim sta'.us requirements, was conducted by DTI. During
this period, the Company was seeking an administrative waiver from DER and
EPA for the treatment system from the RCRA program and the associated
ground-water monitoring requirements. Waiver requests and government
responses are not completely documented in DER and EPA files; however, a
waiver was apparently sought, at various times, on the grounds that (1) the
treatment units composed a totally enclosed treatment system, (2) the State
deleted the waste sludge (but not the liquid) in the impoundments from the
list of hazardous wastes* and (3) the wastes in the impoundments were not
hazardous.
The 1983 monitoring network comprised four wells designated by a "UTM"
prefix. These wells were part of an eight-wel" network installed in 1977
because of a solvent release attributed to underground solvent storage tanks
on the northwestern part of the plant property, The solvents identified in
the ground water were trichloroethylene (TCE) and 1,1,1-trichloroethane
(TCEA), which were used by UTI for degreasing metal parts. Following instal-
lation, the well closest to the solvent tanks, UTM 1, was used to extract
contaminated ground water for treatment. The other seven wells installed
primarily on the western and southern parts of the UTI property, were used
by the Company to identify the extent of contamination and monitor the
cleanup. Only one of the UTM wells (UTM 3) was near the surface impound-
ments and it was not close enough to satisfy State regulations. The extrac-
tion well continues to be used for removing contaminated ground water. The
extracted water is passed through a stripping tower. When air temperatures
are above freezing, usually from March to November, stripping tower effluent
is pumped to an onsite area, near the surface impoundments, where it is
Sludge from lime treatment of pickling liquor (hazardous waste number
K063) was deleted in September 1982. The supernatant, however, is
spent pickling liquor (technically) and is still subject to the State
interim status requirements.
-------
sprayed into the air for further stripping of the volatile solvents. During
cold weather, the effluent is discharged into a small unnamed tributary to
Perkiomen CreeK.
In 1984, DER personnel concluded that the four UTM wells were not ade-
quate for monitoring the impoundments, pursuant to the interim status require-
ments, and they issued a Notice of Violation on December 11. After a series
of meetings between DER and DTI personnel in early 1985, the Company agreed
to install four monitoring wells adjacent to the impoundments. The new
wells, designated as RCRA 1 through 4, were installed in June 1985.
In July 1985, DTI initiated interim status monitoring on the four new
wells. These wells were sampled in July and September 1985 for organic and
inorganic constituents. Very high concentrations of TCEA (up to 96 mg/L)
and TCE (up to 38 mg/L) were identified. These concentrations are similar
to those associated with the solvent release from the underground storage
tanks (described above); however, the source(s) of the solvents in the RCRA
wells has not been determined. In November 1985, DER directed UTI to
discontinue routine interim status monitoring and initiate an investigation
to determine if the impoundments were leaking. As a result, only two quar-
ters of monitoring have been conducted for the interim status program,
A work plan for a subsurface investigation in the vicinity of the impound-
ments was submitted to DER in February 1986 and was under review during the
Task Force inspection. The work plan is now considered to be a ground-water
quality assessement program plan by DER and UTI, and was evaluate;: as such
by the Task Force.
UTI submitted a RCRA Part B application to EPA in April 1983 for the
pretreatment system. Although the effluent goes to a publicly-owned treat-
ment works (POTW), the surface impoundments precluded an exemption from the
State interim status requirements. Following the Part B submittal, the
Company decided to close the impoundments and withdraw the Part B. A clos-
ure plan and several revisions were submitted to DER and EPA. A revision
dated December 1985 was being reviewed during the Task Force inspection.
-------
SUMMARY OF FINDINGS AND CONCLUSIONS
!
The findings and conclusions presented reflect conditions existing at
! the facility in April 1986. Actions taken by the State, EPA Region III and
UTI subsequent to April are summarized in the accompanying update.
i
GROUND-WATER MONITORING DURING INTERIM STATUS
I Task Force personnel investigated the interim status ground-water moni-
toring program at UTI for the period between November 1981, when applicable
1 provisions of the Pennsylvania regulation became effective, and April 1986.
The investigation revealed that no interim status monitoring program was
1 implemented until November 1983. Further, no concurrent sampling and analysis
'• plan, specifically for interim status requirements, was submitted for the
, required DER approval. After two quarters of monitoring, DER required that
j new wells be installed to replace the existing monitoring well network.
Following installation of these wells in 1985, interim status monitoring
I was initiated on them.
1
A sampling and analysis plan for interim status monitoring was submitted
to DER in February 1985. In response to DER comments, the plan was revised
and resubmitted in May 1985, Although the plan did not receive the required
written approval, it was implemented on new wells installed in June 1985,
The Task Force evaluated the program implemented during the summer of 1985
and determined it to be inadequate. Program components, including the
ground-water sampling and analysis plan and procedures, monitoring we'll
network and the assessment program outline and plan, did not comply with
DER requirements,
Ground-Water Sampling and Analysis Plan
The ground-water sampling and analysis plan submitted in May 1985 is
inadequate and does not comply with State regulations [75.265(n)(7)]. The
plan does not adequately detail the procedures followed for sample collec-
tion, sample preservation and shipment, analytical procedures or chain-of-
custody control.
-------
For example, the plan did not specify methods and equipment used for making
water-level measurements; calculating purge volumes; purging anc sampling
the wells; and making field measurements for temperature, pH and specific
conductance. Neither does the plan address calibration of the field meters.
The plan indicates that some sample aliquots will be preserved by adding
acid until a specified pH is achieved, but does not explain how the pH will
be determined. Regarding chain-of-custody procedures, the plan states only
that U.S. EPA procedures will be followed.
The plan does not contain a sampling schedule, which is necessary
because monitoring frequencies and parameter requirements change after the
first year. Without a guide (schedule) for sampling in the plan, it is
deficient.
Sampling and Analysis Procedures
The contractor personnel conducting the interim status sampling for
DTI did not follow the sampling and analysis procedures submitted in the
1985 plan and, therefore, did not comply with State regulations [75.265-
(n)(7)]. For example, the plan states that at least five well volumes will
be purged from each well before sampling. Sampling records indicate that
no more than three casing volumes were ever evacuated. Measurements for
pH, specific conductance and temperature were to be made in the field, but
they were made in the laboratory instead. Consequently, the holding time
for pH was exceeded. The plan indicates that equipment blanks, trip blanks
and duplicate samples will be taken; however, field data sheets 0.0 not indi-
cate that the blanks were collected. Laboratory records indicate that a
duplicate sample was taken during one of the two quarterly sampling events,
Discrepancies and errors were also found between the specified and
actual sample preservative and analytical methods. The plan states that
nitrate samples are to be preserved with hydrochloric acid and analyzed by
EPA Method 352.2. Another EPA method was actually used and the sample
should only have been cooled to 4° Celsius (C) rather than preserved with
acid.
-------
For phenol analysis, the plan specified EPA Method 420.1 and preservation
by cooling to 4° C, According to the referenced method, the samples should
be preserved with phosphoric acid and copper sulfate, but they were not.
Likewise, samples for radium analysis were not preserved; nitric acid should
have been added. Improper preservation can result in sample degradation
and biased results.
Task Force personnel inspected the laboratory contracted by UTI, which
conducts the interim status analyses on ground-water samples. The inspec-
tion revealed that many of the analyses were not performed as required by
State regulations [75.265(n)(8)]. Further, most of the reported analytical
data are biased and inaccurate. Biases due to sample handling, analytical
procedures and quality control methods were found for most of the parameters.
Monitoring Well Network
Construction procedures for the four monitoring wells installed in
June 1985 were adequate; however, several deficiencies were found in the
completed wells. -The length of the surface casing (5 feet) was only half
of that required by State regulations [75,265(n)(6)] and the casing was not
marked with the well designation [75.265(n)(5)]. Construction records do
not clearly indicate whether sufficient grout was placed in the annular
space to prevent surface water from entering the well bore. Concrete aprons,
installed around the wellhead to drain surface water away from the well,
were broken at all four wells. Two of the we'lls (RCRA 2 and 4) produced
turbid water when sampled by Task Force personnel, thereby suggesting defi-
ciencies in the sand pack installed around the screen or well development.
The adequacy of the well locations (vertical and area!) can not be
completely evaluated because the ground-water flow zones and direction have
not been adequately defined. Consequently, the uppermost aquifer and the
hydrogeologic units that need to be monitored at the facility have not been
identified. Ground-water flow directions have been interpreted, by a UTI
consultant, from two different well networks constructed at the site with
conflicting results. Water level measurements made in the original monitor-
ing network wells suggested a southeasterly flow direction. Water levels
-------
measured in the second (current) monitoring network wells, which were between
50 and 150 feet shallower than the wells in the original network, suggest a
northwesterly flow direction- Data on the site hydrogeology indicate that
the hydraulic continuity between the zones monitored by the various wells
is ptobably limited, thereby rendering comparisons of water level data
inconclusive.
Assessment Program Outline and Plan
An outline for a ground-water quality assessment program was required
[75,265(n)(13)] by November 19, 1981. UTI first submitted an outline in
April 1983 as part of the Part B application. A second outline, prepared
to satisfy the interim status requirements, was submitted to DER in February
1986. Neither outline received the required written approval from DER,
State regulations require that the outline describe a more comprehensive
ground-water monitoring program capable of determining:
Which hazardous waste or hazardous waste constituents have entered
the ground water
The rate and extent of migration of hazardous waste or hazardous
waste constituents in the ground water
The concentration of hazardous waste or hazardous waste constitu-
ents in the ground water
Abatement alternatives for any ground-water contamination attrib-
utable to the hazardous waste management facility
The outline does not comply with State regulations [75,265(n)(13)]
because:
It does not address how the rate and extent of migration of haz-
ardous waste or constituents will be determined
-------
10
It does not address abatement of ground-water contamination
It was not submitted to DER for approval until February 1986
Samples collected from the UTI monitoring wells in July and September
1985 contained elevated levels of volatile orgam'cs, chromium and dissolved
solids. In November 1985, DER recommended that the source of the contamin-
ants be identified through subsurface investigations. UTI subsequently
submitted a "Work Plan for Subsurface Investigation" in February 1986,,
This plan, which was under review during the Task Force inspection, is con-
sidered to be a ground-water quality assessment program plan by both DER
and UTI.
1
The work plan was reviewed by Task Force personnel and found to be
inadequate. It did not contain either abatement, procedures or an implemen-
, tation schedule as required by State regulations [75.265(n)(15)]. Further,
the design for proposed monitoring wells was deficient. If constructed as
proposed, the open well bores would intersect several water-bearing zones
and provide avenues for cross-zone migration of contaminants. Collapse of
! another similarly constructed well at the site suggests that a casing and
screen (which were not included in the proposed design) are necessary to
maintain the integrity of the borehole in the rronitored zone. Further, the
proposed depths were intermediate between the deeper wells for the remedia-
; tion system and the shallower RCRA wells. Wate- level data from these wells
may not aid in defining the ground-water flow direction because of vertical
hydraulic discontinuities at the site.
TASK FORCE SAMPLING AND MONITORING DATA EVALUATION
During the inspection, Task Force personnel collected samples from
I eight ground-water monitoring we'lls, a surface impoundment and the effluent
I
from a stripping tower constructed as part of a ground-water remediation
system [Figure 2]. The well samples were collected to determine if the
ground water contained hazardous waste or constituents. The surface
-------
x
H
s
If!
o
c
V
w
3 !
S:
.
.2 -
? £
* s
-» I
e
*
-------
12
impoundment and stripping tower were sampled because they are potential
• contaminant sources, Monitoring data from Task Force samples were evaluated
together with previous DTI data.
Task Force and DTI data indicate the presence of trichloroethene (TCE)
and 1,1,1-trichluroethane (TCEA) with high concentrations (i.e., greater
than 1,000 ug/L) in six of the eight wells sampled by the Task Force (RCRA 1,
2, 3, 4 and UTM 1 and 3), The other two wells (UTM 5 and 8) also had detect-
able TCE and TCEA, but at much lower concentrations. All but one of the
concentrations in these two wells (TCE at 77 MS/I- in UTM 5) were at or near
the limit of quantitation. The source of these compounds is probably a
solvent release, which was discovered in mid-1977. In late 1977, UTI
installed a remediation system to clean up the affected ground water.
Inorganic data from the Task Force samples suggest leakage from the
surface impoundments. Data for selected parameters present in high concen-
trations in the impoundment samples during the inspection are compared
[Table 1] to data for wells having elevated concentrations (relative to
concentrations in the other wells) of these chemicals. Data from the strip-
ping tower discharge are also included for comparison because they are prob-
ably indicative of parameter concentrations in recharge to ground water
from the nearby spray field,
In Table 1, the parameter concentrations for the respective wells are
listed in decreasing order from left to right. The pattern of elevated
concentrations suggests a southeasterly migration of chemicals from the
impoundments.
-------
Table 1
SELECTED INORGANIC DATA FROM TASK FORCE SAMPLES*
Parameter
Chromium**
Cyanide**
Sulfate***
Sodium***
Magnesium***
Sett! ing
Basin 2
2,840
53
1,250
268
263
Stripping
Tower
58
<10
28,5
11.5
7.6
RCRA 2
1,280
20
500
37,4
44,7
RCRA 3
246
<10
500
45,0
46.1
UTM 3
395
<10
250
28.4
25,3
RCRA 4
8
<10
44
17,4
16,9
* Data are from wells adjacent to the surface impoundments
** Concentrations are in micrograms per liter fug/I)
Concentrations are in milligrams per liter (mg/L)
***
-------
TECHNICAL REPORT
-------
INVESTIGATION METHODS
The Task Force investigation of the Uniform Tubes, Inc., facility
comprised:
Reviewing and evaluating records and documents from EPA Region III,
DER and UTI
Conducting an onsite facility inspection April 8 through 11, 1986
Evaluating the offsite contract analytical laboratory
Sampling and analyzing data from ground-water monitoring wells, a
surface impoundment and the stripping tower effluent
RECORDS/DOCUMENTS REVIEW
Records and documents from EPA Region III and the DER offices were
reviewed prior to and during the onsite inspection to obtain information on
facility operations, construction details of waste management units and the
ground-water monitoring program. Additional DER and EPA records were copied
and reviewed by Task Force personnel before the onsite inspection. Onsite
facility records were reviewed to verify information where necessary.
Selected Company documents requiring further evaluation were copied by the
Task Force during the inspection.
Specific documents and records that were reviewed included the ground-
water sampling and analysis plan; outline and plan for the ground-water
quality assessment program; analytical results from past ground-water sam-
pling; monitoring well construction data and logs; site geologic reports;
site operations plans; facility permits; waste management unit design and
operation reports; and operating records showing the general types, quan-
tities and locations of process waste sources at the facility.
-------
-------
15
FACILITY INSPECTION
An onsite facility inspection was conducted to identify waste sources,
waste transport, waste management units (past and present), pollution control
practices, surface drainage routes, and to verify the location of ground-
water monitoring wells. Company representatives and contractors provided
information on and explained: (1) facility operations (past and present),
(2) site hydrogeology, (3) the ground-water monitoring system and (4) the
ground-water sampling and analysis plan.
LABORATORY EVALUATION
Weston Laboratory in West Chester, Pennsylvania, analyzes all ground-
water samples for DTI and was evaluated regarding its ability to produce
quality data for the required analyses. Analytical equipment and methods,
quality assurance procedures and records were examined for adequacy, Labo-
ratory "records were inspected for* completeness, accuracy and compliance
with State and Federal requirements. The sample handling, analysis and
document control procedures followed were discussed with laboratory personnel,
SAMPLE COLLECTION AND ANALYSIS
The sampling portion of the investigation involved two activities:
(1) measuring water levels in all wells onsite and (2) sampling eight wells,
one active surface impoundment and effluent from a stripping tower [Figure 3].
Water level measurements were taken in an attempt to determine the direction
of ground-water flow. Those wells, designated by the "LJTM1' prefix, are
deep wells (ranging from 65 to 150 feet) constructed in 1977 for monitoring/
recovery of contaminated ground water following a solvent release discovered
that year. The remaining wells are designated by UTI as "RCRA" monitoring
wells. These were installed in'1985 adjacent to the surface impoundments.
The stripping tower is associated with the cleanup of the solvent release
and discharges water to a drainage channel in the vicinity of the RCRA wells.
The wells were sampled to determine if and to what extent the ground water
contains hazardous waste or constituents. The surface impoundments and the
-------
16
\
\
WASTEWATER
PRETREATMENT FACILITY
TOWfK
SURFACE
IMPOUNDMENTS
FIGURE 3
TASK FORCE SAMPLING STATIONS
-------
17
stripping tower effluent were sampled because of the potential to release
hazardous waste or constituents to the ground water,
Duplicate volatile organic samples and splits of total metals, dissolved
metals and specific conductance samples were provided to UTI, EPA Region
III was provided the same duplicate and split samples with the exception of
the aliquot for specific conductance, which was not requested,
Only one of the facility wells (UTM 1) was equipped with a pump, UTM 1
is equipped with a submersible pump, which continuously discharges 75 gallons
per minute (gpm) to the stripping tower, pursuant to a State cleanup direc-
tive related to the solvent spill. Samples were collected by an EPA con-
tractor for the Task Force, UTI and EPA Region III using the following
procedures,
I. UTI contractor (Weston) unlocked the wellhead.
2. EPA contractor monitored open wellhead for chemical vapor (Photovac
TIP®) and radiation.
3, EPA contractor measured depth to ground water using an oil/water
sonic Interface Probe (Moisture Control Co. , Inc. , Model No
B2220-3),
4, EPA contractor lowered the Interface Probe through the water
column until total depth was reached,
5. EPA contractor retrieved the Interface Probe from the well bore
and decontaminated the cable and probe using procedures outlined
in Table 2.
Photovac TIP and Interface Probe are registered trademarks and vill
appear hereafter without §.
-------
DRAFT 09/22/86 18
Table 2
J DECONTAMINATION PROCEDURES
^ Equipment* Decontamination Method
• Submersible pump, tubing, ropes Cleaned after each use with a non~
and wire phosphate soap and rinsed with tap
I water
Interface probe Cleaned after each use with a pesti-
, cide grade hexane wipe, followed by a
; rinse with distilled water and wiped
dry
1 Filtering apparatus Cleaned with 1:1 nitric acid diluted
i with distilled water and rinsed with
distilled water
| , - - -- : - , - —
* Bladder pumps and Teflon bailers were pre-cleaned before the inspec-
tion; none were reused during the inspection, therefore, none had
to be decontaminated.
3
6, EPA contractor sealed the well with a, custody seal, (The water
•; levels were taken at each well on the first day of sampling and
then sealed until sampled later in the inspection.)
7, Task Force personnel calculated water- column volumes using height
of water column and well casing radius,
8, When the Task Force was ready to sample the well, the EPA con-
tractor broke the custody seal.
9, EPA contractor purged three water-column volumes using a 4-gallon
plastic bucket (marked in quarts). Table 3 indicates the method
of purging each well. Purge water from the UTM wells was dis-
charged directly into the municipal sewer* and water from the
RCRA wells was discharged into the surface impoundment.
i
Permission was granted by the Municipal Water and Sewer Authorities,
UTI and the PA-DEK Bureau of Solid Waste for the disposal of purge
water in this manner.
-------
IS
10, EPA contractor collected a sample aliquot and made fieTc
measurements for temperature, turbidity, specific conductance and
ph.
11. EPA contractor filled sample containers using both the methods
and order specified in Tables 3 and 4, Split samples were col-
lected by filling one-third of each bottle for the Task Force,
facility and Region III bottles, respectively, This process was
repeated until each bottle was filled. If the bailer could not
fill a third of each bottle, one-third of the bailer was used per
bottle,
12. Samples were placed on ice in an insulated cooler.
13, EPA contract personnel took the samples to a staging area where
the dissolved metals aliquot was filtered. In addition, total
metals, TOC, phenols, cyanide and nitrate/ammonia samples were
preserved [Table 4],
When additional samples were collected for quality control purposes
(NEIC duplicate and contract laboratory triplicate), step numbe1- 11 above
was modified NEIC sample containers were filled following collection o*
Task Force, UTI and Region III aliquots; the laboratory triplicates were
filled in senes followed by the UTI and Region III samples. In each case,
procedures were followed for collection of split samples.
When the active surface impoundment (settling basin 2) and stripping
tower were sampled, steps 2, 10, 11, 12 and 13 were followed in their respec-
tive order. The impoundment sample was taken by the EPA contractor at the
northeastern corner of the impoundment near the discharge manifold, Sample
bottles were filled just below the water surface. The stripping tower sample
was collected from the collection tank overflow pipe.
-------
20
j£
k.
re
E
0.
O
.C
Q
-
i]
ro
s- ^ cr
CL.
|
•-- *-'
>lf "^
IE •—
a re
fcS
Is
c.
e
r—
Q,'
j_i
ft
w
•— • a
a> E
*->
c
o-. e
d. —
O
• ~ a
U E
13 0
C ~
) — —
^.
S
»-*
U">
^
OD
0— -
o
_^
1
e &
t ' —
„, .-
re a-
t *1
*c i ro
_ t
• -t»J i-
*- *x. o
o> ^->^-
nr® m
10 I/)
o c
O i-
^"0.2
10
*~*
,_,
0
s
CD
»—(
~^
O
u
i
> -^
c
ET. E
= E
o
CM .. Q.
- I- E
Q. re u
^ •— tr-
ie s-
— 0. O
CC •— »J
CD
^J
^
= | |^
2 t- — »
C *J fl. U
£ o 2 g
1^ i/1
^H m
i—* »2
i i
o o
S 3
CO CO
!—> O
^ x~
o o
w fc
i *J 1C *->
c: » c
cr. E a.' e
a. 3 33
o a o
. -L-& .-t
C. c. OJ — Q.--
D. CL re u o. u
^ Ti; •— ^ ^ ^r
CC CD >— *• CO *J
^,
m
000 0
•— — O f-l
ooo w
<-l O O C
CO 00 CC CO
CT' O — 1 O
ooo o
f-) «•
£ g
i
c o
a^ "i 7
Q- E '
E _ cr
4_> O Q^
C £) k.
°~ e "£ -H tZ ^
flj O TO T 10
t, w (t;
TO > C C C
•£. C O O O O
SSf 5 5 J
liT^ t^ C3 ^^
f*i O fO O
O S ^H S
it t i
O U") u^ O
Is s §
CO CO CO CO
CTi ^^ C^ O
~^ ~v -^, ^.
o o o o
>,
= §"- f- t-
3 a. o. o. o. o. a.
C >r- -r- —
4—' -^* .^> '^ >^- <^ »»— "
C i- C k. C k, C
UE UE o> ai
<— en — o •— o i— o
» fC «. u 1-
- c. ^J _f^[ ,^ _g^ ^ _Q 4_J
acr ECTQ, Ecno» Ecra
t- X; i- j .c i-- 1 £; i- >
or 3~o, ~3c^ — 3 a
z a ^ a ^ "-^ a ^ >-r) a ^
*-t V O
^ <•
»
w
iS^S s ?
Q 7-P4 f—^ T— t ^^ ^^
till 1 1
in p-t c\j *— ( ^- esj
O ^— « »™^ «-^ *M »— 1
GC CO
o cr
•-i 0
O 0
^ r^ ^! 00
ac at xi
5
0.
•o
~_
k, n
C, <-J
r" °
IV
n
% 5
*•- •!
K (i
*3 «j
5 *
"S 2
•c o
Cj *J
o
a E
s; 0
L, L.
**-a
V,
it "C
k
C C »
i C 5
(^ 4J 4J
O «
«J C
w Ifl ff)
C « «j »
« k c e
Se-tl
o i
*j a. o o
"8 e -o -o
*ty "S tt ft)
n ee
0 ~i P P
st n & £.
- !M « T
-------
Table 4
ORDER OF SAMPLE COLLECTION,
BOTTLF TYPE AND PRESERVATIVE LIST
Parameter
Bottle
Preservative*
Volatile organic analysis (VOA)
Purge and trap
Direct inject
Purgeable organic carbon (POC)
Purgeable organic halogens (POX)
Extractable organics
Pesticide/herbicide
Dioxin
Total metals
Dissolved metals
Total .organic carbon (TOC)
Total organic halogens (TOX)
Phenols
Cyanide
Ammonia
Sulfate/chloride/nitrate
Radionuclides (NEK only)
2 60-mi VOA vials
2 60-ml VOA vials
2 60-m£ VOA vials
2 60-m£ VOA vials
4 1-qt. amber glass
2 1-qt. amber glass
2 1-qt. amber glass
1 1-qt. plastic
1 1-qt. plastic
1 4-oz. glass
1-qt. amber glass
1-qt. amber glass
1-qt. plastic
1-qt. plastic
1-qt, plastic
4-qt. glass container
HN03
HN03
H2S04
CuS04 + H3 P04
NaO:
All samples were stored on ice
the analytical laboratories.
after collection and during transport to
-------
22
FACILITY DESCRIPTION
Task Force personnel obtained information on past and present
manufacturing and waste treatment operations and a ground-water remediation
system to identify potential sources of hazardous waste releases and aid in
interpreting ground-water monitoring data, The information is summarized
in this section,
PROCESS OPERATIONS
UTI manufactures high-precision, small-diameter metal tubing and tubular
parts at the Conegeville plant, which is operated as a "job shop" for these
products, The plant includes three interconnected buildings designated as
Plants 1 and 2 and the Annex [Figure 4]. Plant 1 was built in 1964 and
expanded in 1965. Plant 2 was built in 1973 and the Annex, which connects
Plant 1 to Plant 2, was added in 1978. Plant 1 is used for making small
and intermediate sizes of tubes and Plant 2 is used for making larger tubes.
The Annex area is used for inspecting final products, storage, packaging,
shipping and receiving.
Plants 1 and 2 are divided into areas for drawing tubing, fabricating
parts and ancillary processes. For most products, feedstock tubing is suc-
cessively drawn through a series of dies, with intermediate processes, to
reduce the diameter; then it goes through final processing or is fabricated
into parts, The feedstock tubing, usually 3/4-inch diameter, can be made
of an alloy or pure metal. The ancillary processes include cleaning (solvent,
acid or alkaline degreasing), annealing (softening), pickling (acid etching)
and tumbling (polishing).
Process wastewater from three pickling operations (Plants 1 and 2),
ground water collected in a foundation sump (Plant 1) and liquid discharged
to a floor drain (Plant 1) are pretreated onsite in the hazardous waste
management units, as discussed below, before discharge to the municipal
sewer system. Pickling is an intermittent operation and involves immersion
of tubing into one of several acid-solution baths (typically 15% acid).
Most pickling is done with hydrochloric, hydrofluoric, nitric and sulfunc
-------
FI..I Dr.l.» PLANT 1
INTERMEDIATE TUBE MILL
FIGURE 4
UTI PLANT LAYOUT
-------
24
acid, and some is done with chromic acid. Following the pickling bath, and
depending on the type of acid in the bath, the tubing is rinsed in one to
three flow-through rinse tanks, The spent pickling solutions and rinse
tank effluents are routed to the wastewater pretre^tment system through
I separate sewer Tines made of 3-inch polyvinyl chloride (PVC) pipes,
Plant 1 has a foundation sump, near the degreaser unit, which discharges
to the pretreatment system. A floor drain in the Plant 1 drawing area is
r, also connected to the pretreatment facility. The floor drain is not close
to any source of waste liquid and is reportedly not frequently used,
s Drains to the sewer lines for the pretreatment system are also used,
i as needed, for other liquids. For example, during the Task Force inspection,
, rain was leaking through the roof in Plant 2 and the rainwater was being
routed along a temporary drainage way, made of plastic sheets, to the rinse-
l water effluent line in the adjacent pickling area.
* WASTEWATER PRETREATMENT FACILITY
The wastewater pretreatment facility [Figure 5] is southeast of Plant 2
and is surrounded by a chain-link fence. It consists of three treatment
tanks, a control building and two surface impoundments, which are used as
settling basins. The facility was constructed in 1969 to treat spent pickle
liquor and associated rinsewater (EPA hazardous waste number K062, as defined
in 40 CFR §261.32). Effluent from the facility is discharged to the
Collegeville-Trappe Municipal Authority wastewater treatment plant.
1 The three circular treatment tanks are below grade and are 15 feet, in
, diameter by 7 feet deep. The walls of each tank are 6-inch-thick reinforced
* concrete (gunite) and have a polyester resin coating on the interior surface.
Each tank holds 6,000 gallons (with 2 feet of freeboard) and has an agitator
i for mixing the wastewater with treatment chemicals. Four-inch PVC pipes
interconnect the tanks at the 2-foot freeboard level to prevent overfilling.
\ Each tank also has an overflow float switch connected to a central alarm.
1
-------
25
CONTROL
BUILDING
TREATMENT TANK 3
D
Q^——"^-T R E A T M E N
EATMENT TANK 1
T TANK Z
\VALVE
BUILDING
\
\ SETTLING BASIN 1
\
\
\
\
\
SUMP Q
\
\
SETTLING BASIN 2
\ _ * _ /
\
\
\
\
Scale: I equals appro*. 20'
FIGURE 5
WASTEWATER PRETREATMENT FACILITY
-------
26
The control building is used for storing chemicals and has equipment
' for adding those chemicals to the treatment tanks and transferring treated
' wastewater to the surface impoundments, A pump is used to recirculate the
"iquids in the tanks wMle treatment chemicals are added. Two SB-gallon
i polyethylene tanks with mixers are connected to the recirculation system
ahead of the pump. Chemicals used to treat the pickling wastes include
lime (acid neutralization/metals precipitation), sodium metabisulfite
(chromate destruction) and sulfuric acid (pH adjustment). The building has
i a concrete floor with a sump. A float switch in the sump activates a pump
which discharges to Tank 2,
* The two surface impoundments are used as settling basins for metal
I hydroxide sludges resulting from the treatment process. They are desig-
I nated as settling basins 1 and 2 and were originally constructed in 1969 as
unlined impoundments. In 1975, each basin was lined with 4 inches of con-
i crete reinforced with wire mesh, installed above a 4-inch-thick stone base.
I
The concrete was coated with a polyester resin. Numerous cracks have devel-
f oped in the concrete walls, which were observed to extend below the water
line. Some cracks have been repaired; however, the repairs were inadequate
i because the material used to fill the cracks was also cracked.
i
I The capacity of each surface impoundment is 58,000 gallons (with 2
feet of freeboard). The surface area dimensions are 80 feet by 45 feet and
the bottom (10 feet below the surface) dimensions are 40 feet by 5 feet.
Treated wastewater enters each impoundment through a 12-foot-long perfor-
ated distribution pipe that is positioned horizontally along the west end
of each impoundment, 6 feet above the bottom. The effluent flows through a
v similar pipe at the east end to a 2-inch PVC pipe, then into a 2-foot-
j diameter precast concrete sump. Water is pumped from the sump to the muni-
4 cipal sewer system by a 20 gpm pump in a lift station at the east end of
, the center dike between the two impoundments. The pump is activated by a
[ float switch in the sump. A drain from the lift station to the ground
surface was plugged in 1984.
-------
27
PRE-RCRA SOLID WASTE MANAGEMENT UNITS
DTI operated several solid waste management units (SWMUs) that were
closed before November 19, 1980 (effective date of RCRA regulations)
[Figure 6]. These units are potential sources of hazardous waste or con-
stituents that could be released to ground water. Consequently, Task Force
personnel obtained information on the following SWMUs previously operated
by UTI.
Concentrated acid storage tank
Original spray field
Original wastewater treatment facility
Cesspools and septic tanks
Naphthol storage tanks
TCE/TCEA storage tanks
Concentrated Acid Storage Tank
A storage tank for concentrated acids (spent pickling solutions) was
built in 1969 as part of the current wastewater pretreatment facility, The
tank was constructed to be similar to the treatment tanks described previ-
ously. It is located just north of the control building, was used only to
store spent pickling solutions for offsite transport and disposal. UTI
subsequently modified the treatment facility to accomodate the spent pickling
solution in addition to the rinsewater. The concentrated acid tank was
emptied and backfilled. No samples were taken or tests conducted to deter-
mine if the tank had leaked.
Original Spray Field
From 1969 until 1973, when the treatment system was connected to the
municipal sewer system, treated process wastewater was discharged onto a
spray field located about 150 feet south of settling basin 2. Ten thousand
gallons per day (gpd) of effluent was piped to the field and sprayed from
four nozzles over an area of about three-quarters of an acre. UTI has no
monitoring records of the effluent or original spray field.
-------
-------
In 1973, the spray system was dismantled. The site of the original
spray field is now covered by fil1 As discussed below, a second spray
field was constructed as part of the ground-water remediation system.
Original Wastewater Treatment FarTMty
The original wastewater treatment facility was built in 1963 when
Plant I was constructed, This facility was phased out in 1969 when the
current pretreatment facility went on line. It was located just north of
the area occupied by the Plant 2 pickling area. Plant 2 was constructed
over the site. Treatment units included a concentrated acid tank, a dilute
acid (rinsewater) tank and an unlined lagoon. Construction and operational
details of the original wastewater treatment facility were not available
from LJTI personnel during the Task Force inspection.
Before Plant 2 was constructed, sludge in the lagoon was excavated and
buried just north of the lagoon. The acid tanks were emptied and collapsed,
then the entire area was backfilled and graded.
Cesspools and Septic Tanks
Cesspools, septic tanks and a leach pit composed the UTI sanitary
system before connection to the municipal sewer in 1973. UTI personnel
interviewed during the Task Force inspection did not know whether process
water or other waste liquids (e.g., solvents, etc.) were disposed of in
this system. Some of the containment units were concrete, others were
steel; construction details of the former system are incomplete Liquids
in the cesspools, septic tanks and leach pit were pumped out by a UTI con-
tractor, then the units were backfilled.
Naphthol Storage Tanks
Three naphthol tanks were installed in 1963 when Plant 1 was constructed.
All three were outside, underground and to the east of Plant I. A 550-gallon
tank was used to store clean naphthol, while two 5,000-gallon tanks were
-------
used to store recycled and spent naphthol. In 1978, two new above-grouna
tanks were installed to store new and spent naphthol. Subsequently, the
two 5,000-gallon underground tanks were excavated and disposed of and the
excavation area was backfilled with soil. The remaining 550-gallon tank is
currently used as a catchment tank for any spilled naphthol. This tank was
leak tested in 1984 by a private contractor and certified tight. UTI has
conducted no monitoring of soil or ground water in the immediate vicinity
of the three underground tanks to determine if any naphthol had been
released,
TCE/TCEA Storage Tanks
f Three underground tanks for solvent storage were installed during the
, construction of Plant 1 in 1963, Each tank was constructed of steel and
t held 550 gallons. They were located outside at the northwest end of the
building. The tanks were initially used for storing clean, recycled and
spent TCE, In 1965, the Plant 1 building was extended over the three TCE
tanks; use of the underground tanks did not change. In 1975, DTI discon-
tinued using TCE in the degreasing operations and began using TCEA. The
; TCE was removed from the three storage tanks and replaced with TCEA.
In 1978, an outside tank storage area (above grade) was completed which
included a 2,000-gallon and a 1,000-gallon tank for clean TCEA. A
1,000-gallon tank in the degreaser pit was used for storage of recycled
TCEA. The three original storage tanks were abandoned and backfilled. No
leak (.integrity) tests were conducted on the tanks nor was there any monitor-
ing conducted for indications of leaks. However, in 1977, ground water
beneath the site was found to contain both TCE and TCEA. As a result, the
State required UTI to construct and operate a ground-water remediation system,
' which is discussed below.
GROUND-WATER REMEDIATION SYSTEM
In 1977, a remediation system was constructed by UTI to-extract and
treat ground water contaminated by TCE and TCEA. The presumed sources were
| the underground solvent storage tanks. The system was operating during the
-------
31
Task Force inspection and included an extraction well (DIM 1), an air-stripping
tower and a spray field [Figure 7]. Ground water is pumped from DIM 1 to a
wet well near the southeast corner of settling basin 2, then to the stripping
tower and, finally, to the spray field, all of which are described below.
Stripping Tower
The stripping tower, located just east of the wet well, was placed
into operation in 1980. Before it was installed, the ground water was pumped
directly to the spray field from the wet well. The stripping tower is a
20-foot column mounted on a pre-cast concrete tank supported by a 2-foot-thick
concrete base. The column is constructed from a 42-inch (inside diameter)
fiberglass-reinforced pipe with a 5/16-inch-thick wall. It is packed with
2-inch-diameter polypropylene rings. Air is drawn from the headspace at
the top of the column, which has a sealed cover, by a 2,900 cubic-feet-per-
minute (cfm) blower which exhausts to the collection tank. The concrete
collection tank under the tower holds about 1,150 gallons and is equipped
with a float-activated submersible pump.
Water in the wet well is pumped through a 4-inch PVC pipe to the inside
of the stripping tower near the top. As the water trickles down through
the column to the collection tank, air is drawn upward by the blower When
temperatures are above freezing, generally from March through November,
water in the tank is pumped to the spray field via 2-inch iron and PVC pipes
During colder weather, the pump is turned off and water is discharged to an
adjacent drainage channel through an overflow pipe,
Spray Field
The spray field is 50 feet east of the stripping tower and is about
one-half acre in size. Two parallel distribution pipes, about 60 feet apart,
carry water to the risers. Each riser consists of a horizontal pipe,
supported about 4 feet above the ground, with spray nozzles at each end.
One of the distribution pipes is connected to four risers with approximately
120 feet between the first and last; the other pipe is connected to five
-------
r
u
<
c
Is
2
C
K
C
-------
33
risers, with about 120 feet between the first and last. The risers are
designed to spray 10 gpm at 55 psi cf pressure,
The spray field was very boggy during the inspection. The soft, water-
logged ground was covered with vegetation. Cattails up to 6 feet tall were
growing in the spray field and were more dense in the southeastern (down-
gradient) end. Small erosion channels were observed throughout the spray
field. These drain to the drainage channel that also receives overflow
from the collection tank at the base of the stripping tower.
The channel drains to a runoff detention basin about 250 feet south-
east of the stripping tower. The basin has a capacity of about 2.75 acre-
feet and is surrounded by a chain-link fence, It is unlined and was exca-
vated in 1978 as a condition of the State building permit for the Annex
connecting Plants 1 and 2. It was designed to control rainwater runoff
from the plant roof and parking lots,
Effluent from the detention basin passes through a control structure
then through a culvert. The culvert passes under 5th Avenue and empties
into an unnamed tributary of Perkiomen Creek. UTI does not have a National
Pollutant Discharge Elimination System permit for the discharge from the
basi n.
-------
34
SITE HYDROGEOLOGY
Information presented in the Part B application and other documents on
the hydrogeology of the UTI site is limited. Site-specific information was
developed principally by a UTI consultant, Roy F. Weston, Inc. (Weston)
during (1) the installation of a monitoring/recovery well system in 1977 to
clean up a solvent release attributed to underground storage tanks, (2) the
preparation of the Part B permit application in 1983, and (3) the installa-
tion of four shallow interim status monitoring wells in 1985. The following
infortnation was derived primarily from Weston reports and discussions with
Weston personnel.
Underlying the UTI site is a soil identified as the Readington Silt
Loam by the U.S. Soil Conservation Service, This soil is typically a reddish-
brown to dark-brown silt loam weathered from shale, siltstone and sandstone.
The Soil Conservation Service characterizes this as a deep, moderately well-
drained soil. Usually at a depth of 15 to 22 inches, the subsoil is a very
firm, reddish-brown silt loam or silty clay loam that is streaked and mottled
(indicating wet conditions) with a greyish color, The permeability of this
soil varies from moderately rapid at the surface to moderately slow with
depth. Likewise, the quantity of shale fragments increases with depth and
the shaley material grades to bedrock, The silt loams and weathered mate-
rial beneath range in thickness from 7 to 23 feet on the site.
The underlying bedrock consists primarily of reddish-brown shales,
mudstones and siltstones of the Brunswick Formation, which ranges from 9,000
to 16,000 feet in thickness. The Brunswick Formation is a member of the
Newark Group of late Triassic Age. A few thin beds of green shale and brown
shale are present and are composed primarily of feldspar, illite, chlorite,
quartz and calcite. Regionally, the rocks are a series of overlapping lens-
shaped units that are discontinuous in all directions along the bedding
plane.
-------
35
The bedrock has low primary permeability (i.e., intergranular
permeability). Most of the ground-water movement within these rocks follows
secondary openings such as fractures and joints, Ground water flows primar-
ily through the nearly vertical joint planes which intersect at various
angles throughout the beds and provide an interconnected series of channels.
The fractures and joints substantially increase the otherwise low permeabil-
ity of bedrock. The density of these fractures results in area! variations
in permeability. Joints in the formation are also commonly partially filled
with calcite and quartz. Occasionally barite and pyrite are also present.*
In the Brunswick Formation, the regional strike of the beds is northeast
and they dip northwest 5 to 15 degrees. The formation is also reported to
be more permeable along the strike than across it. Weston personnel reported
that there are three major joint sets running north-northeast, northeast
and northwest, which have nearly vertical dips (80 to 90 degrees).
HYDROGEOLDGIC UNITS
To date, the uppermost aquifer and the hydrogeologic units that need
to be monitored at the facility have not been adequately identified. The
following describes site characterization work done to date toward identi-
fying these units and the shortcomings of that work,
Under the RCRA interim status requirements, the uppermost aquifer must
be monitored [265.90(a)]. An "aquifer" is defined [260.10] as a "geologic
formation, group of formations or a part of a formation capable of yielding
a significant amount of ground-water to wells or springs", The "uppermost
aquifer" is defined as "the geologic formation nearest the natural ground
surface that is an aquifer, as well as lower aquifers that are hydraul icany
interconnected within the facility's property boundary".
Stanley M. Longwill and Charles R. Wood, "Ground-Water Resources of
the Brunswick Formation in Montgomery and Berks Counties, Pennsylvania",
Pennsylvania Geological Survey, Bulletin W22, 1965. pp 6-11
-------
36
State regulations [75.265(n)(l)] require a "monitoring system capable
of determining the facility's impact on the quality of any ground-water
system which the facility has the potential to affect,"
During construction of both the UTM wells in 1977 and the RHA wells
in 1985, there was no indication of saturated zones in either tne soil or
weathered zones. Ground water was encountered below the bedrock surface in
all borings. Logs of the borings are presented in Appendix A.
There were at least four major water-bearing zones penetrated in drill-
ing the UTM wells, They were all composed of the dark reddish-brown shale
and yielded between 4 and 125 gpm. These water-bearing zones were encountered
at depths greater than 40 feet below the surface and had greater yields
with increasing depth. Whether these water-bearing zones have vertical
hydraulic connections has not been determined.
Vertical hydraulic discontinuities within the fractured bedrock are
suggested by the shallower RCRA wells, which complicate the identification
of appropriate monitoring zones. The borings for the RCRA wells were
reportedly advanced until water was encountered, then an additional 20 feet
was drilled before the screen and casing were installed. Wells RCRA 3 and
RCRA 4 are 40 feet apart, at nearly the same surface elevation (0.6 feet
difference), yet they were completed to depths, of 45 and 78 feet deep,
respectively. Depths to water of 31 (RCRA 3) and 58 (RCRA 4) feet were
measured during the Task Force inspection, which indicate that the driller
was able to follow the design criteria. The large difference in water levels
between tnese wells, which had been reported previously, has not been
explained by the Company consultants and testing has not been conducted to
determine whether the RCRA wells monitor hydraulically interconnected zones.
Both vertical and area! hydraulic discontinuities are suggested by
well yield data. Testing conducted during installation of the RCRA wells
yielded an average of less than 2 gpm. Well RCRA 1 had the highest yield
of approximately 3 gpm and the water level recovered quickly after develop-
ment. The other RCRA wells were pumped dry and then recovered very slowly.
-------
37
With the wide range of depths at which ground water was encountered in the
RCRA wells and the varied yields, Weston suggests that, at shallow deptns,
the distribution of joints and fractures is erratic.
During the installation of the deeper UTM wells, damp zones were iden-
tified between 25 and 40 feet below the surface and measurable yields (e.g, ,
greater than 2 gpm) were obtained between 40 and 75 feet. Beyond 75 feet,
water production increased significantly (up to 110 gpm),
In summary, additional investigation is necessary to define the hydro-
geologic units beneath the facility and the degree to which they are hydraul-
ically interconnected. Based on the investigation, the uppermost aquifer
can be better defined and appropriate monitoring zones can be identified,
GROUND-WATER FLOW DIRECTIONS AND RATES
Ground-water flow directions have not been adequately determined for
the facility and previous investigations have yielded conflicting conclu-
sions. Therefore, the locations of upgradient and downgradient monitoring
wells, relative to the waste management units, cannot be determined without
further study,
Water level measurements made in the L'TM wells in 1977, before recovery
well UTM 1 began pumping, suggest that ground water flows to the southeast
toward Perkiomen Creek [Figure 8] with a gradient of about 0.009 feet/foot
or 48 feet/mile. A pump test conducted on UTM 1 after construction yielded
a transmissivity value of 3,000 gpd/foot and storativity values in the range
of 10-3 to 10-4. Based on these limited data, the ground-water flow rate
was calculated to be about 0.07 feet/day.
The southeasterly flow direction determined from the UTM wells was
used to site the new upgradient and downgradient RCRA wells. However, mon-
itoring of the RCRA wells during the summer of 1985 revealed that ground-
water flow (as reinterpreted by Weston) was to the northwest from the spray
-------
\
\
c:
o
; ec f* c
8! S i
I 5 «
E 3 S
-------
39
field through the surface impoundments toward the recovery well. The
recovery well, the spray field and normal seasonal variations in water leveU
are potential causes of this apparent flow reversal,
Weston investigated the effects of the recovery well (DIM 1) on the
grcjnd-water flow system by conducting a pump test in October 1985, The
pump test indicated only very localized effects (significant only at UTM 2
and UTM 4) with influences primarily within about 800 feet northeast-
southwest (along strike) and 300 feet northwest-southeast (along dip) of
the well. The RCRA wells and UTM 3 showed noticeable water level changes,
but were less than 0,2 feet. Weston summarized that the small water level
fluctuations indicate that UTM 1 is not primarily responsible for the shape
of the water table in the vicinity of the RCRA wells.
The effects of recharge from the spray field on ground-water flow have
not been investigated by the Company; however, data suggest that investiga-
tion is warranted. The spray field is located just east of the impound-
ments [Figure 7] and is roughly 160 feet wide by 100 feet long. Contami-
nated water from UTM 1 (recovery well) is piped to the stripping tower then
to the spray field. Approximately 75 gpm of treated water is applied to
the spray area, weather permitting, as discussed in the Facility Description
section.
During the onsite investigation, which occurred in late winter, Task
Force personnel made water level measurements on both RCRA and UTM wells.
The results are summarized in Table 5 and compared to Weston data for July,
August and September 1985. Water levels in wells RCRA 1 and 4 were higher
than when measured during the previous summer; water levels in wells RCRA 2
and 3 were about the same.
Water level measurements made in the UTM wells by the Company in 1977
and by Task Force personnel in 1986 revealed areas of the facility that
need to be further investigated in order to adequately characterize ground-
water flow directions. Task Force and Company data indicate the presence
of a significant ground-water depression encompassing well UTM 1 and nearby
-------
.— I
ro
f~-
ro
4^
ro
Q
C
O
4->
m
OJ
2;
'j
^
O.
O
1—
,«-
,__
QJ
,
ro
O
1 —
s)
O
f->
rc
>
o>
1 —
1 1
—
OJ
>
QJ
1
1
i-
QJ
•*->
ro
^
C
o
>r—
4-"
ro
>
QJ
_jj
—-
OJ
>
QJ
, ]
1
i-
QJ
-4_>
rc
^^
CT
C
i r—
l/l
ro
CJ
OJ
^J
ro
<+-
i_
°^
LO
IN
/~-^
) i
>f-
*—'
_c
^J
Q.
OJ
a
^__
OJ
^£
UD
CO
"\
CO
o
^\
»^J-
o
oo
^
cn
o
LO
CO
*\
i— H
O
oo
o
LT>
00
^ —
CsJ
i— 1
•^^
r —
o
^
^
c
>r—
+J
rc
>
a
F— »
t_^_
UO
oo
i—i
ro u2
<3- cn
00 <— 1
r-~- cn
i— 1 r— 1
r*^ IJD
0 1—1
r-» i— i
ro ro
Csj csj
CO O
CO 1C
«3- O
00 lT>
i— ( csj
cc a:
C 3 C.3
ce cc.
ro LO ^JZ; !-JD
CO O
^~
r-
^3- C5
O CsJ
CSJ
r—t
r-. ro r-H
cn ro
• . tJD
o oo o
CD UD rsj
CsJ i — 1
tn^-o cn ^j-
CSj r-< r~( rt ^H r-(
ro *3-
c5trs:2:s:s:2:E2:2:
LJCJI — r— 1 — 1 — 1 — h- 1 — H-
Qi Cc; O ID ^ Z5 ^ ^5 ZD ^)
«
&N
_c
VI
ns
U
Q)
U
as
*i-l
(H
^J
M
Ol
^
4J
H^
O
a
0
4J
£>
(B
4J
c
ft)
*
+J
(-,
0
4-*
a;
5
•H
a
73
^)
t-
3
to
«B
Q)
£
CSl
' — <
a>
>
S
Q
^2
(Xj
^
Ci;
O)
c
*M
73
C/
u
c
a>
QJ
^
^
U«3
c
0
'^
4~J
«
>
(J)
p— <
u
°0
10
•to
c
1
s
^
(H
S
J
•i
0
J=
g ^
•D
C
u
f4)
(^,
fc
4J
ro
Tr
^J
f — t
'H
"^4
re
g
o
H_
to
Q)
^J
'^j
«
^
to
•H
J=
'W
-------
wells UTM 2 and UTM 4, which is probably due to operation of the recovery
we1! The 1977 data suggest the presence of elevated ground-water levels
in the vicinity of wells UTM, 3 and UTM 8. Neither of these is addressee, in
reports by Weston.
Task Force data suggest that an elevated water level is still present
at UTM 3 when compared to the RCRA and other UTM wells. Construction records
indicate that UTM 3 was drilled to a depth of 146 feet; however, measurements
made by Task Force personnel revealed a depth of about 65 feet. Whether
the borehole totally collapsed or is only partially obstructed is not known.
Consequently, the monitored zone that the water level represents is unknown,
Although the nature of the geologic deposits underlying the site is
known, the site hydrogeological characterization is inadequate. Hydraulic
testing of the monitored zones is needed to determine whether they are
hydraulically interconnected. The seasonal variations in the use of the
spray field and drainage channel, and their potential effects on ground-
water elevations and flow direction in the aquifer need to be investigated
-------
42
GROUND-WATER MONITORING DURING INTERIM STATUS
Ground-water monitoring at the Uniform Tubes facility has been conducted
entirely under State interim status regulations. The Commonwealth of Pennsyl-
vania enacted Subchapter D of the Solid Waste Management <\ct on November
28, 1980 with an effective date of November 18, 1980, one day before the
Federal RCRA regulations were effective. EPA approved the Pennsylvania
interim status program (Part 265 equivalent) on May 26, 1981 and granted
final authorization (Parts 264, 265 and 270 equivalents) on January 30,
1986.
DTI did not have a RCRA ground-water monitoring program for the impound-
ment between November 1981, when applicable provisions of the State regula-
tions became effective, and November 1983. Between July 1981 and about
mid-1983, UTI was seeking an administrative waiver from DER and EPA for the
waste pretreatment system from the RCRA program and the ground-water monitor-
ing requirements. Although not completely documented in DER and EPA files,
the process apparently began with a July 28, 1981 submittal to EPA indicating
that the treatment system was a totally enclosed treatment facility (TETF)
and, therefore, did not require a RCRA permit. EPA responded in a Decem-
ber 9, 1981 letter, which stated that the treatment system would not qualify
as a TETF and requested that a corrected Part A oe submitted.
DER notified UTI in September 1981 that the Department was developing
criteria and standards for TETFs and would be able to grant a permit by
rule to such facilities after November 30. UT] apparently requested TETF
status from DER because a denial letter was sent to the Company on August 23,
1982. The letter indicated that UTI had two alternatives for obtaining
TETF status. These included (1) enclosing the treatment tanks and (2) either
closing the impoundments or getting the hazardous wastes in them delisted.
In September 1982, DER deleted sludge froir, lime treatment of spent
pickling liquor (hazardous waste no. K063) from its list of hazardous wastes.*
Because the supernatant is, technically, spent pickling liquor (haz-
ardous waste number K062) the impoundments are still suiject to the
State interim status requirements.
-------
A State inspection report dated May 4, 1983 indicated that, although the
sludge in the impoundments naa been aeiisted, the contents of the UTI
impoundments should be tested for Ep toxicity. According to UTI records,
an ED toxicity test was conducted on a sludge sample collected from the
impoundments on July 19, 1983, The test results, which were sent to UTI in
September 1983 reportedly indicated that the sludge was not EP toxic.
Neither UTI, DER or EPA records indicate that the results were sent to the
regulatory agencies. In any event, interim status ground-water monitoring
was initiated in November 1983,
A State inspection report dated March 29, 1984 indicated that UTI was
in noncompliance with ground-water monitoring requirements and specified
the need for at least four new monitoring wells.* On December 11, 1984,
DER issued UTI a Notice of Violation for ground-water monitoring, At that
time, the State required UTI to discontinue use of the UTM wells and required
development of a plan for a new monitoring network. In conjunction with
their plan for the new wells, UTI submitted a sampling and analysis plan
(monitoring plan). This plan, submitted in May 1985, was verbally approved
by DER and implemented. Samples were collected from the new (RCRA) wells
in July and September 1985 using methods outlined in that plan, A timeline
of these and other events related to ground-water monitoring is presented
in Table 6.
The following is an evaluation of the monitoring program between May
1985 and April 1986, when the Task Force investigation was conducted. This
section addresses:
Regulatory requirements
Ground-water sampling and analysis plan
Monitoring wel1s
Sample collection and handling procedures
Ground-Water Quality Assessment Program Outline and Plan
State reports on eight previous interim status inspections of UTI con-
ducted between Nay 1981 and November 1983 indicated that the facility
was in compliance with ground-water monitoring requirements.
-------
Table 6
TIMELINE OF ACTIVITIES RELATED TO GROUND-WATER MONITORING
EPA/DER Activities
Year
UTI Activities
1969
II
1973
1974
1975
Earthen impoundments
Impoundments lined
1976
1977
10 /
UTM wells constructed
to monitor/recover
solvent spill
PA DER Hazardous Waste Regu-
lations effective
EPA RCRA Regulation effective
DER delegated interim
authorization
1980
11/18
11/19
1981
Q5/
Weston notified of interim status 05/26
requirements (DER)
Ground-Water Assessment Outline
and Monitoring Program due
(DER/EPA)
EPA denies TETF status
DER denies TETF status
DER requests Part B application
07/28
11/19
12/09
1982
08/23
10/27
1983
04/14
UTI requests TETF
status fror EPA
Part B application
submitted
-------
Table 6 (cont.)
EPA/DER Acti
No decision
v i t i e s
on need fo» Ground-
Year
11/07
I2/2C
UTI Activities
Initial Quarter
Ground-Water Mon.
Water Monitoring (DER)
NOV-Must monitor, must construct
new wells (DER)
Must submit Closure Plan, can
not return Part B until
Closure plan approved (DER)
1984
04/30
12/11
12/14
12/23
1985
05/22
06/10-17
097
Second Quarter
Ground-Water Mon.
Closure Plan Submitted
Samp!ing and Analysis
Plan for new RCRA wells
New RCRA wells
constructed
1st quarter Ground-
Water Mon. Report
10/
2nd quarter Ground-
Water Mon. Report
Ground-Water assessment/
abatement outline required
(DER)
11/19
DER Directs UTI to discontinue
quarterly Monitoring-need
further studv
DER delegated final
authorization
III
12/15
1986
01/30
Decides not, to ootaii
Part B
Ground-water Task Force
Inspection
02/
02/13
04/08
Ground-Water Assess-
ment Outline submitted
Work plan submitted for
additional study
(Assessment Program)
-------
4b
REGULATORY REQUIREMENTS
The Pennsylvania requirements for ground-water monitoring during interim
status are contained in Section 75,265(n) of t~e Solid Waste Management
Act. They are similar in scope but more stringent than the RCRA Part 265,
Subpar* F interim status requirements. Regulation counterparts are shown
in Table 7,
Table 7
STATE AND FEDERAL COUNTERPART INTERIM STATUS REGULATIONS
Pennsylvania State
Regulation
Subpart Title* Section 75.265(n)
Applicability
Ground-water monitoring
system
Sampl ing and analysis
Preparation, evaluation
and response
Reporting and recordkeeping
(1), (2)
(3), (6)
(7), (12)
(13), (17)
(18), (19)
RCRA Regulation
40 CFR Part
265,90
265,91
265.92
265.93
265.94
* Subpart titles are given for RCRA regulations; the State does*
not have subparts identified.
The State "egulations are more stringent because they require:
1. A monitoring system that evaluates the impact of a facility on
any ground water, not just the uppermost aquifer [75.265(n)(l)]
2. Monitoring well locations to be approved by the Department
[75.265(n)(3)(iii)]
3, Design specifications that provide for protecting the monitoring
wells from damage by heavy equipment or vandals, including:
a. Steel surface casing
(1) Several inches larger in diameter than the monitoring
well
-------
47
(2) At least 10 feet in length
(3) At least 1 foot above final grade and at least several
i riches above the monitoring well casing
(4) Grouted with a cement collar at least 3 feet deep to
hold it firmly in position
b. A cap on the monitoring well casing which allows the moni-
toring well to be locked [75. 265(n)(6)( i-i i)]
4. Ground-water sampling and analysis plans to be submitted to the
Department, when requested, and a copy retained at the facility
[75,265(n)(7)j
5. Additional monitoring requirements to those specified in 265.92
(b)(2) and (3), if requested by the DER [75.265(n)(8)(i i )(G) and
6. Results of analyses for ground-water quality parameters
[265. 92(d)(l)] to be submitted semiannual^ instead of annually
7. Results of analyses for ground-water contamination parameters
[265. 92(d)(2)] to be submitted quarterly instead of semiannual^
8. The ground-water quality assessment outline o* 265.93^") to be
submitted to the Department for written approval and a copy retained
at the facility [75. 265(n)(13)]
9. The assessment outline, in addition to the requirements of 265.93(a)
to include details of abating any ground-water contamination
attributable to the facility [75.265(n)(13)(iv)3
10. Abatement procedures to be included in the assessment plan [75,265
(n)(15)(ii)(D)] and submitted to the Department for approval
[75.265(n)(15)(vi)(C)j
-------
11. Any changes in the monitoring system |265.93(f)j to be submitted
to the Department for written approval before construction begins
[75.265(n)(17)]
12. The annual monitoring reports specified in 265. 94(a)(2)(ii), to
be submitted semiannually [75,285(n)(18)(ii)]
13. Quarterly reports, if there is a significant difference found in
the upgradient weH(s) [75.265(n)(18)(c)]
14, Quarterly results of ground-water surface elevations rather than
annually (on March 1) as specified in 265.94(a)(2)(iii) [75,265(n)
(18) (D)]
15, A facility to submit records to the Department in addition to
keeping records at the facility for review [75.265(n)(19)(i)]
16. Submission of a report containing results of the ground-water
quality assessment program to the Department by January 31 (rather
than March 1) which includes, in addition to the requirements of
265.94(b)(2), the volumes of hazardous waste constituents removed
from the ground-water using the abatement procedures [75.255(n)
GROUND-WATER SAMPLING AND ANALYSIS PLAN
The ground-water sampling and analysis plan submitted by UTI in May
1985 is inadequate and does not comply with State regulations [75.265(n)(7)].
The regulations require an owner/operator to develop and follow a sampling
and analysis plan which includes procedures and techniques for: (1) sample
collection, (2) sample preservation and shipment, (3) analytical procedures
and (4) chain-of-custody control. The May 1985 plan addresses each of these
required areas, but many necessary details are omitted.
-------
The section on sample collection procedures does not specify the types
of equipment used to measure water levels and purge each of the wells. Nor
does it address how often the well depths are measured for the purpose of
determining total water column heights in purging. It does not indicate
whether the sampling equipment is dedicated to the site and/or individual
wells, nor does it address disposal of the purged water and the method of
filtering samples. The section addresses making field measurements for
temperature, specific conductivity and pH; however, procedures are not
included for making these field measurements or for calibrating the instru-
ments. Also, no procedures are described for making the required quadrupli-
cate measurements for the indicator parameters.
The plan does not contain a sampling schedule, which is necessary because
monitoring frequencies and parameter requirements change after the first
year. Without a guide (schedule) for sampling in the plan, it is deficient.
The sample preservation methods in the plan are contrary to EPA recom-
mended methods for the preservation of nitrate samples. The plan indicates
that hydrochloric acid is used rather than cooling the sample to 4° C, a=s
recommended by EPA. The samples taken for radium and phenols also require
preservation, yet the table listing sample preservatives in the plan does
not indicate this. Radium samples need to be preserved with nitric acid tc
a pH of less than 2. Phenol samples need to be preserved either with one
gram of copper sulfate per liter of sample and phosphoric acid to a pH of
less than 4 or with sulfuric acid to a pH of less than 2. The plan does
not indicate the method of verifying that samples have been preserved to
the appropriate pH.
The analytical procedures are cited as EPA or Standard Method numbers.
The specific methods need to be listed because these methods have alternate
subparts that can yield significnntly different results. Both the chain-of-
custody procedures and the custody forms need to be included in the plan
rather than referenced.
-------
50
Quality assurance and quality control procedures should also be included
rather than referenced, The Weston "procedures for ensuring the collection
of samples representative of ground-water quality" should be detailed.
In summary, the plan is not sufficiently detailed to ensure consistent
sampling methods or collection of representative imples, It needs to be
revised before additional sampling is conducted,
MONITORING WELLS
UTI has conducted ground-water monitoring since 1977 at its Collegevilie
plant. Eight monitoring wells were installed on the property in October
1977 [Figure 9] for assessing the extent of TCEA and TCE that had entered
the ground water, probably as leakage from the underground storage tanks.
The initial RCRA ground-water monitoring network for UTI was proposed
with the Part B application in October 1983, The monitoring proposal desig-
nated four of the UTM wells for interim status monitoring. These wells
were:
Upgradient UTM 1
Downgradient UTM 3
UTM 5
UTM 6
After the second quarterly samples were collected (March 1984), DER
personnel determined that the locations of these wells (400 to 800 feet
away from the waste boundary) were not appropriate for monitoring the surface
impoundments. Following the DER determination UTI submitted a plan for
four new wells to be constructed adjacent to the pretreatment facility.
The well construction plan was included in the May 1985 ground-water sampling
and analysis plan, which was verbally approved by DER, The new wells, desig-
nated as RCRA 1 through 4, were constructed in June 1985 [Figure 10]. DER
personnel observed construction of several of the wells,
-------
\
\
vn.STCM.ATtn
PRE7REATMEM fACJLITY
V)
"3
CO
9- Z
& *W
5.2
.'T* ^"
5
2
-------
en
.
2 e *
= 3
C/5
UJ
'
-------
Well Construction
The RCRA-series wells were constructed between June 10 and 17, 1985
with an air-rotary rig, using a percussion hammer bit, The bit was cooled
with water added during drilling. Drilling and construction logs were main-
tained by a Weston geologist; copies of these logs are in Appendix A, The
depth drilled was determined by the location of the first saturated zone.
When the first saturated zone was encountered, the driller drilled an addi-
tional 20 feet and stopped.
The wells were completed using 4-inch-diameter, Schedule 40 PVC casing
with a 20-foot PVC well screen having 0,20-inch slots, All casing and screens
had threaded connections; adhesives were not used. The annular space around
the screen was filled with a filter pack of fine to medium-grained gravel,
The filter pack was extended from the bottom of the well bore to a level
about 5 feet above the top of the screen. A bentonite seal, approximately
2 feet thick, was emplaced above the filter pack, The remainder of the
annular space was pressure grouted with a bentonite-portland cement mix. A
6-inch-diameter steel surface casing, 5 feet long, was set into the grout
around the outside of the PVC well casing, The surface casing was equipped
with a locking cap to prevent unauthorized access. Following construction,
the wells were developed using compressed air, Additional construction
details are presented in Table 8.
Although the construction was generally adequate, some problems were
found during the onsite inspection and records review. The surface casing
was only 5 feet long instead of the minumurr, of 10 feet required by State
regulations [75.265(n)(6)]. The September 1985 (post-construction) monitor-
ing report and the drilling logs indicate that an 8-inch diameter surface
casing was installed; however, 6-inch casing was actully used. The surface
casing is supposed to be marked with the well designation [75.265,(n)(5)];
however, none of the wells were so marked.
Construction records indicate that the annular space in each well was
pressure grouted, but do not indicate whether there was a surface return
-------
i
i'
1 ("O
1 +•>
re
i-
•4-)
U1")
|
t
00
_j
— i
LU
00
1 — •
S- S-
QJ QJ
*-> -t->
i— C
>p~ t— *
U_
•X
"O -K
QJ r—
c ro
QJ >
QJ !-
S_ QJ
O •*— '
OO E
1—1
^
?— -X
ro .1 —
4— •+->
0 Q.
h~~ QJ
C3
QJ
^j
ro
Q
r—
r—
oj
^E
I " ?
"O
OJ
S—
O
4-J
•i —
C
o
2EZ
C
E
OJ
L ^
r^
^™N
4_J
l+_
V-X
^— *s
^— >
'4—
v-^
^ — -
4-J
4—
'•^^
"S
*J
QJ
1-
I
C •— Q.
0 ^— C
*J . — C
U"l > r— .*-)
1 ' ^_ (^
•— -a •*->
•f— r—
Ul '4— " —
O CO
C
a* ^ c
C^ 0 5
S- 0 C
O^1-*— i—
I -O
>-, 4-> t
(^ u^ "^
S- ro Q;
CD "~~ i-
ao
00
CM
oo
t
LD
r-
en
^~
Cs)
co
i
^>
C\J
{£}
oo
co
LT)
00
CM
^
0 | O
S- j ^H
QJ
-C <£
E
Q^
Jw C.J
z a:
1 >>
C C rC' i — • —
0 Or— -^ U
-*-J -W cj u-i
to un cj
+j *j c c e
"— ••— O Of)
to u~, S- S-.
jO -O ' —
-^) >^ 1 j ^_)
rc rc "O T3 •'— ~C
S- s- QJ OJ 5 c
o; CD i- s- ro
QJ in
^i ^; ,c jc c
t- t- +J S- O "O
rc ro 5f— rc *J c
O Q ^ CD in ro
ai oo C»T
CM upi ro
O O O
CTl OO CO
*^° ^" f^-
1 ! !
OO CD O
J^
O
to
QJ
a.
o
o
•^
•t
c
0
•to
c
s
0
] (D
CM r*» O ! +J
CM i— 1 LO
O -£>
o o o
CM OO ^-
^C *£. *£
a: cc oi.
c_> cj o
i*>" p^ ry
g
•H
s
J^
' Q)
~- a> a.
•3; o
r"^ **-< O
•M (H O
*^J J3 **-*
C W "
QJ U
a."o -H
1 — O O
S^ 1
C7i CO
o a — i
—l O
»^^ i^
CTi ^
C -Q t>
-i C
<-~t -^ -^
-M
W C 0>
QJ QJ "O
3t Si
s -^ ^
O QJ Q^
SH ^ S
«0 S -H
to QJ QJ
»— 1 «—( >-H
?*-( »^^ r-H
•t < "C
*: -k •*:
•k -k
-k
-------
of grout. The purpose of the grout is to seal the annular space. Unless
an excess of grout is used, as would be indicated by a surface return, the
adequacy of the seal is questionable and surface water may enter the well,
The concrete aprons around the wellheads, which are supposed to drain sur-
face water away, were broken at all four wells,
Two of the wells sampled during the Task Force inspection (RCRA 2 and
4) produced very turbid water. This suggests possible deficiencies in the
sand pack or well development. The problem needs to be identified and
corrected.
Well Locations
The location of the RCRA wells was based on the hydrogeologic data
gathered from the UTM wells. Since the ground-water flow direction was
interpreted as being to the southeast, RCRA 1 was designated as the upgra-
dient well and wells RCRA 2, 3 and 4 designated as the downgradient wells
Data gathered since the completion of these wells suggest that the
area! locations may not be appropriate. If ground-water flow in the upper-
most aquifer is to the northwest, as reinterpreted by Weston, then well
RCRA 1 is no longer an upgradient well and is not located at the perimeter
of the waste management area, as required for a downgradient well [75,265
(n)(4)]. In addition, well RCRA 2, if now an upgradient well, is probably
too close to the impoundment to represent background conditions. As indi-
cated in the Site Hydrogeology section, however, ground-water f'iov, direction
have not been adequately determined. Further investigation is necessary
before the adequacy of the well locations can be determined.
The vertical locations of the well screens are also questionable because
they are probably not monitoring the same aquifer zones (see Site Hydrogeol-
ogy section). As a result, the water level data are not comparable for the
purpose of determining flow directions and satisfying the requirements for
-------
the annual report. In the annual report, UTI must determine if the criteria
for locating the monitoring wells (i.e., upgradient and downgradient) con-
tinues to be satisfied [75.265(n)(17)].
UTI SAMPLING PROCEDURES
A UTI contractor, Weston, samples the wells for the required interim
status monitoring, Weston was asked to demonstrate their sampling protocol
for Task Force personnel, This request was declined; however, a verbal
explanation of the procedures used at UTI was provided. Some of the sampl-
ing procedures are inadequate and the plan, in several instances, is not
strictly followed, as required by State regulations [75.265(n)(7)]. The
following was derived from the explanation provided by Weston and a review
of field data sheets from sampling during July, August and September 1985.
Water Level Measurements
To determine the volume of water in the well casing for calculating
purge volumes, water level measurements are taken at each well. Weston
uses a Soil Test Water Level Indicator, Model QR-760A, when taking water
level measurements. This Water Level Indicator consists of a reel with a
control panel, cable and sensor When the sensor makes contact with water,
the needle on the control panel ammeter shows an inflection from zero. The
cable is marked every 5 feet. The cable is lowered into the well until the
probe reaches the water. The probe is raised and lowered until the exact
point of contact is determined. The cable at the top of the PVC tubing is
pinched by the sampling contractor and the distance from the bottom of his
fingers to the next higher cable marker is measured with a ruler; this
measurement is subtracted from the cable marker to determine the water level.
Following the measurements at each well, the first 5 feet of cable and the
probe are decontaminated with distilled deionized water.
The method for water level measurement is generally acceptable; however,
this type of water level indicator requires some interpretation of where
the water level is located. The relative inflection of the ammeter needle
-------
b/
can change from well to well and may be influenced by water cascading or
dripping into the hole. The precision and accuracy of the water level meas-
urements is questionable. In addition, the entire length of the cable enter-
ing the well needs to be decontaminated after use to allow for rubbing against
the well bore, etc. The water level markers (imbedded in the insulated
cable) should also be checked periodically to determine if the wire has
stretched. Weston followed the approved plan for measuring water levels,
Purging
Monitoring records indicate that the wells were purged of about three
water column volumes before sampling. The volume of water in the casing is
determined by first calculating the height of the standing water in the
casing by subtracting the depth-to-water measurement from the total well
depth (from construction records). Next, the volume is calculated by mul-
tiplying the water column height by a gallons-per-foot-of-casing conversion
factor.
®
Weston uses a Grundfos submersible pump, model SP-2-7, for purging
The pump is decontaminated with Alconox solution and rinsed with deiom'zed
water prior to each well entry. The pump is lowered into the well using
whatever rope is available. If nylon rope is used, it is soaked in deion-
ized water between each well. If hemp rope is used, it is discarded after
one use.
The volume of water purged is calculated from the estimated pump
discharge rate and length of pumping time. The pump discharge rate is
reportedly calculated from the time required to fill a 5-gallon bucket dur-
ing purging; however, this is not indicated on the monitoring records.
Purged water is discharged to the ground adjacent to the well. Because
this water may contain hazardous waste or constituents, it needs to be
disposed of in a more environmentally sound manner.
Grundfos is a. registered trademark and will be shown hereafter
without €.
-------
58
In addition, the sampling plan was not fo'lowed. The plan indicates
that at least five times the calculated casing volume is to be purged. In
no case, were more than three casing volumes purged from any well; some had
less than three volumes removed on different dates,
Sample Collection
After purging the wells, each is sampled using a 700-cubic-centimeter,
bottom-loading, Teflon Galtek bailer. The bailer cord is similar to tnat
used for lowering the pump. If nylon cord is used, it is soaked in deionized
water between samples and reused. If hemp is used, it is discarded after
use in one wel1,
Weston does not use a specific order when sampling the wells. Determin-
ing which well is sampled first is more a matter of logistics. Likewise,
they have no set order when filling the sample bottles. If the sample is
turbid, they will first collect an aliquot for metals to allow time for
filtering, then collect inorganics, extractable organics and, finally,
volatile organic samples.
The metals samples are collected in one bottle then taken to the treat-
ment building where they are filtered using a 47-mm-diameter (0.45 micron)
MF~mi11ipore filter and glass (300 ml) filtering apparatus. They are
filtered into a second bottle already containing the preservative, nitric
acid. The preservatives for metals and organics are put in the bottles in
the lab p""ior to sampling.
According to the field sheets, measurements for pH, temperature and
specific conductivity were not performed due to the unavailability of
equipment.
Upon completion of sampling at a well, the bailer is rinsed with
deionized water and then reused at the next well.
-------
The sample collection methods need improvement. Dedicated bailers and
rope need to be used for each well when sampling. Rinsing the bailers bet-
ween each well is probably not sufficient to remove contaminants at the
levels found in some wells. Also, the random order of sampling needs to be
improved now that contaminant concentrations in each well are known. If
one bailer is to be used, sampling needs to start at the least contaminated
well and progress to the most contaminated well. According to EPA methods,
pH measurements should be made immediately after the sample is collected.*
There are a number of discrepancies between the methods outlined in
the sampling plan and those followed by Weston samplers, The sampling plan
states that field measurements are to be made for temperature, pH and spe-
cific conductivity. Field data sheets indicate that no field measurements
were taken. The results presented for these parameters were measured in
the lab. The plan also states that a variety of quality assurance/quality
control samples will be taken by the samplers. These include: (1) dupli-
cate well- samples, (2) trip blanks and (3) field equipment blanks taken
each quarter. Field data sheets indicate that one duplicate sample was
taken in July but none of the blank samples is mentioned in the notes for
either quarter.
Shipping and Chain-of-Custody
Chain-of-custody forms are filled out before submission of the samples
to the lab. Weston personnel stated that they follow EPA procedures for
chain-of-custody. Samples are logged in at the Weston lab and custody forms
are signed over at that time. Samples are packed in coolers with ice and
vermiculite and taken to the lab the same day the samples are taken. Copies
of the chain-of-custody forms were not provided; therefore, whether the
sampling plan is followed could not be determined.
40 CFR Part 136, Table II
-------
60
SAMPLE ANALYSIS AND DATA QUALITY EVALUATION
This section provides an evaluation of the quality and completeness of
interim status ground-water monitoring data gathered by Uniform Tubes between
November 1981 and April 1986. Analytical procedures for required interim
status monitoring parameters and data quality were evaluated through a labo-
ratory inspection and review of documents containing the required monitoring
data. Previous monitoring data revealed that volatile organic compounds
were present in the ground water adjacent to the waste management units.
As a result, DER was requiring the Company to implement a ground-water qual-
ity assessment program. Consequently, the laboratory inspection included
an evaluation of analysis procedures for volatile organics.
Analyses for interim status and assessment monitoring are done by a
UTI contract laboratory, Weston Analytical Laboratory of Lionville, Penn-
sylvania. The Weston laboratory was evaluated concurrently with the onsite
inspection of the UT! facility. The evaluation involved reviewing laboratory
operating and analytical procedures, internal data reports, raw data and
quality control records; interviewing key laboratory personnel and inspecting
laboratory -facilities and analytical equipment.
Interim Status Analyses
The evaluation revealed that UTI has not completed the first year of
quarterly monitoring or statistical analysis of analytical parameters, as
required by 75.265(n)(8); only two quarters of monitoring had been completed.
The analysis of both laboratory results and reported results indicates the
data are neither accurate nor complete. In addition, inconsistencies were
found between reported parameters and those actually analyzed.
Table 9 indicates the parameters required for analysis during the first
year of monitoring, as required in Section 75.265(n)(8), and the extent to
which UTI has performed the required analyses, The facility is required to
monitor parameters for drinking water quality, ground-water quality, and
indicators of contamination (indicator parameters) quarterly during the
-------
Table 9
GROUND-WATER MONITORING PARAMETERS AND FREQUENCE
Monitoring First Quarter Second Quarte
Frequency Analyses Analyses
Required Parameters (first year) (July 1985) (Sep. 1985)
Drinking Water Quality
75.265(n)(a)(i) Quarterly
Arsenic X
Barium X
Cadmium X
Chromium X X
Fluoride X
Lead X
Mercury X
Nitrate (as N) X X
Selenium X
Silver X
Endrin
Lindane
Methoxychlor
Toxaphene
2,4-D X
2,4,5-TP (Silvex) X
Radium X
Gross Alpha , X
Gross Beta X
Turbidity X
Coliform Bacteria
Ground-Water Duality
7S.265(n ' (Sj ( n) Quarterly
Chloride X
Iron
Manaanese
Phenols X
Sodium X
Sulfate X X
Indicators
75.265(n)(8)(iii.) Quarterly
pH X1 X1
Total Organic Carbon (TOC) X!
Total Organic Halogen (TOX) X1
Specific Conductance X1 X1
1 Reported only single measurements for upgradient veil instead of
quadruplicates as required
-------
first year for both upgradient and downgradient monitoring wells. In
addition, quadruplicate measurements were to be taken for the upgradient
well for indicator (pH, TOC, TOX, specific conductivity) parameters.
Drinking Water Quality Parameters
Analytics1 results for the drinking water parameters reported to DER
for samples collected in July and September 1985 did not include endrin,
lindane, methoxychlor, toxaphene and turbidity in July, In September, the
only drinking water parameters reported were chromium and nitrate.
Several problems with the reported data were found, Analytical results
for metals were reported as total metals for the samples collected in Sep-
tember; however, the samples were filtered in the field. The results should
have been reported as dissolved metals. Consequently, the reported metals
concentrations are probably biased low. In addition, none of the metals
samples were spiked for determining the accuracy of the data. Therefore,
the analytical bias of the reported results is unknown. Arsenic, silver
and selenium were analyzed by flameless atomic absorption spectroscopy using
a calibration curve rather than a standard additions method. By using only
the calibration curve, commonly encountered matrix effects are not accounted
for, which results in erroneous data. Chromium, copper, cadmium, nickel,
barium, beryllium, lead, antimony, thallium and zinc were analyzed by induc-
tively coupled argon plasma (ICAP). Mercury was analyzed by cold vapor
atomic absorption.
The sampling and analysis plan states that nitrates will be analyzed
using EPA Method 352,2. Laboratory records indicate they used the EPA ion
chromatography method, number 300.0, for which samples should not be pre-
served. However, Weston field personnel preserved the samples with hydro-
chloric acid. Addition of acid to samples for nitrate analysis causes
nitrite to convert to nitrate. Consequently, the analytical results repre-
sent the nitrate plus converted nitrite concentrations and are probably
biased high.
-------
63
The accuracy and precision of duplicate spikes of 2,4-D and 2,4,5-TP
added to blank water were not acceptable. The percent recovery of the he>-b-
icides from one spike was 130-160%; the percent recovery of the herbicides
from the duplicate spike was 60-90%, The high percentage recovery appears
to be due to a chromatographic interference. The spikes were not rerun
because no herbicides were detected in the samples.
Radium samples were not preserved; however, EPA methods recommend pres-
ervation with nitric acid to a pH of less than 2, Consequently, the reported
results for radium are probably biased low,
Ground-Water Quality Parameters
Analyses for the ground-water quality parameters were incomplete. In
July 1985, analyses were not performed for iron and manganese. In Septem-
ber 1985, sulfate was the only chemical analyzed for in this group.
Phenol samples were not preserved; however, EPA methods recommend pres-
ervation with either (1) sulfuric acid to a pH of less than 2 or (2) phos-
phoric acid to a pH of less than 4 and 1 gram of copper sulfate per liter
of sample. Consequently, the results for phenol are probably biased low.
Indicator Parameters
Data submitted for indicator parameters were incomplete and the accuracy
is suspect. Quadruplicate measurements must be made each quarter for the
indicator parameters. The interim status monitoring data reported to DER
for July 1986 contained only one value for each parameter. Laboratory
records revealed that quadruplicate measurements were made on samples col-
lected on July 12 and 17 and August 1; however, only one of the 12 values
for each parameter was reported for each well.
The laboratory records also indicated a significant variation in pH
values from one sample date to the next for the wells. For example. pH
values of 5.3 and 7.6 were reported for samples collected from well RCRA 3
-------
on July 12 and 17, respectively. The pH data may be biased because of
excessive holding times between sampling and analysis. For example, pH
samples collected on July 17, 1985 were not analyzed until July 26, 1985.
EPA metnods recommend that pH measurements be made immediately after collec-
tion (i.e., within 15 minutes).
The total organic halogen (TOX) results are biased low. The amount of
halogen measured by volatile organics analysis (VOA) in the monitoring wells
during July 1985 was markedly higher than that measured by the TOX analysis,
For example, the volatile organic results for the sample taken at RCRA 2
contained more than 100 mg/L halogen, but the corresponding TOX result was
only 58.4 mg/L. The cause for the low TOX result could not be determined
from available information; however, inconsistencies were found..between the
EPA method for TOX analysis followed by Weston and actual laboratory
practices.
For example, bottles for TOX samples were not baked before .use to "burn
out" halogenated organics and other compounds. The EPA method being followed
by Weston (Method 9020, EPA SW 846) specifies that the TOX sample bottles
are to be baked at 400° C. Further, instrument and reagent blanks were not
being run in duplicate, as specified by the EPA method. Calibration standards
analyzed concurrently with samples did not agree within 3%, as specified in
the EPA method. As a result, the reported detection limit of 5 ug/L should
have been at least 13 ug/L, based on the variance observed in the blanks.
The reported concentrations for total organic carbon represent only
nonpurgeable 'organic carbon (NPOC) because of the analytical method used.
The method involves acidifying the sample and purging it with nitrogen gas
before determining the organic carbon content, which results in the loss of
purgeable (volatile) organic carbon. Thus, the results as reported for TOC
are biased low.
Reported specific conductivity measurements are approximately 15% low
because no correction was applied to the cell constant for measured versus
theoretical conductivity of chemical standards.
-------
Volatile Organic Analyses
Volatile organic analyses of ground water from the UTI facuity have
been performed by the Weston laboratory since the solvent release was discov-
ered in 1977, In early 1986, DER required UTI to conduct a ground-water
quality assessment program relative to the surface impoundments. Conse-
quently, the analytical procedures for volatile organics were evaluated.
The inspection revealed that no corrections were being made to the
analytical results for volatile organics measured in the blanks. In several
of the samples collected in July 1985 for volatile organic analysis (VOA),
compounds such as chloroform, methylene chloride, 2-butanone and acetone
were reported at levels similar to those found in the blanks. If the blank
values had been subtracted, these compounds would have been "non-detected11,
The Weston laboratory does not systematically track sample holding
times. A review of sample collection and analytical dates revealed that
holding times are sometimes exceeded. Exceeding holding times before
analysis can result in biased results.
GROUND-WATER QUALITY ASSESSMENT PROGRAM OUTLINE AND PROGRAM
State regulations [75.265(n)(13)] require a facility to prepare and
submit an outline of a ground-water quality assessment and abatement program
for written approval by the Department before November 19, 1981. The outline
must describe a more comprehensive ground-water monitoring program than the
one for routine interim status monitoring and be capable of determining:
1. Which hazardous waste or hazardous waste constituents have entered
the ground water
2, The rate and extent of migration of hazardous waste or hazardous
waste constituents in the ground water
-------
66
3. The concentrations of hazardous waste or hazardous waste
constituents in the ground water
4, Abatement alternatives for any ground-water contamination attribut-
able to the hazardous waste management, facility
Assessment Outline
The first assessment outline was submitted to DER in 1983 in the Part B
application. The State reviewed this submission for compliance with the
interim status requirements and found it to be inadequate, primarily because
it specified use of only the UTM wells, which were installed as part of the
ground-water remediation system. A second outline was submitted to DER in
February 1986, which is still under review,
The assessment outline submitted in February 1986 is a two-page docu-
ment [Appendix B]. It describes a more comprehensive ground-water moni-
toring program; however, the outline does not relate directly to the require-
ments stated above. Although the outline was developed after contaminants
i
were detected in ground water and is more specific about actions to be taken,
it needs to address the following items which are either omitted or are not
clearly indicated:
How data triggering assessment would be evaluated to confirm
apparent contamination
Circumstances under which additional monitoring wells would be
necessary if the initial phase of the program indicates
contamination
How volume/concentrations of released contaminants would be
determined
How the rate and extent of contaminant migration would be
determined
-------
how the facility would De sure that all potential contaminants
were identified in the plume
How a monitoring plan wouia be developed and the projected
sampling frequency
Which aquifer(s) would be monitored
How data would be evaluated to determine when/if the facility
could return to regular monitoring, as specified by 75.265(n)(18)
What restoration, reclamation or recovery of ground water would
take place on site, as required for State abatement requirements
[75.265(n)(13)(iv)]
Approximate schedules for the time needed to initiate assessment
and abatement sampling, analysis, data evaluation and report
evaluation
Assessment Program Plan
UTI reported elevated levels of volatile organics, chromium ana
dissolved solids in the four RCRA wells in July 1985 (first quarter of
monitoring). Analysis of samples taken in September verified the presence
of contaminants in the wells. In November, DER directed UTI to discontinue
routine interim status monitoring and recommended adcitional subsurface
investigation to determine the source of the contaminants In February
1986, DER received a document titled "Work Plan for Subsurface Investigation
from UTI. This plan was considered to be an assessment program plan DV
both DER and UTI and was under review at the time of the Task Force
inspection.
State regulations [Section 75.265(n)(15)] require an assessment and
abatement plan to be submitted, based on the assessment outline, which spe-
cifies: (1) the number, location, size and depth of wells; (2) sampling
and analytical methods used to identify hazardous waste or constituents;
-------
(3) evaluation procedures, including use of any previously gathered
ground-water quality information; (3) abatement, procedures and (5) a sched-
ule for program implementation.
The February Work Plan was reviewed by the Task Force and found to be
inadequate. Since the plan is based on the outline discussed previous'y,
it has similar problems. The major problems include the lack of both abate-
ment procedures and the schedule of implementation, as required by State
regulations [75.265(n)(15)].
In addition, the monitoring wells are inadequate as proposed. The
monitoring wells, as designed, do not appear to monitor a single zone.
Since contamination is already known to be present, these new wells may
provide additional avenues for cross-zone migration of contaminants. The
proposed wells will have surface casing down to a depth of 5 feet below the
surface of the bedrock; the remainder of the well is designed to have an
open borehole. As discussed in the Site Hydrogeology section, several water
bearing zones were encountered during the construction of the UTM wells.
Several of these water-bearing zones are likely to be penetrated between
the bottom .of the surface casing and the proposed 100-foot depth of the
wells. Water levels measured in these wells will be composites of the
water-bearing zones encountered, which may not relate directly to those
measured in other site wells due to vertical and lateral hydraulic discon-
tinuities. Consequently, the direction of ground-water flow may still not
be adequately defined.
The new wells are designed to be constructed in a manner similar to
the UTM wells. One of the UTM wells (UTM 3) collapsed; therefore, wells
constructed without screens and sand/gravel packs may not be able to main-
tain borehole integrity, as required by State regulations [75.265(n)(5)].
-------
EVALUATION OF MONITORING DATA FOR INDICATIONS OF WASTE RELEASE
This section presents an analysis of both Task Force and UTI monitoring
data regarding indications of apparent leakage from the waste management
units. Analytical results from and methods used on samples collected by
Task Force personnel arp presented in Appendix C.
Task Force data indicate the presence of volatile organic compounds at
high concentrations (greater than 1,000 pg/L) in six of the eight wells
sampled [Table 10]. Samples from the other two wells (UTM 5 and 8) also
had detectable volatile organics but at much lower concentrations. All but
one of the concentrations (TCE in UTM 5) in these two wells were at or near
the limit of quantitation.
Well RCRA 2 had the highest concentrations of volatile organics followed
by wells RCRA 1, RCRA 4, UTM 1 (extraction well), RCRA 3 and UTM 3. All
but well UTM 1 are near the waste management units (surface impoundments).
This pattern is also indicated by Company monitoring data derived from
samples from the RCRA wells and UTM 3 collected in July and from all wells
in September 1985 [Appendix D]. Samples from wells RCRA 1 and 2 had much
higher concentrations of TCE and TCEA than UTM 1, which is the extraction
well located near the old solvent tanks. The reason for these concentration
differences could not be determined from the information reviewed
TCE and TCEA were also detected in the surface impoundment sample, but
at much lowe>" concentrations than in samples frorr the adjacent wells. The
presence of these compounds was not expected based on the review of waste-
water sources to the pretreatment system (see Facility Description section)
These compounds were detected in the impoundments by weston in early 1986,
which prompted an in-house investigation to identify the source. In March
1986, Weston analyzed samples f*"om the Plant 1 sump, which discharges to
the pretreatment system and found TCE at 25,000 pg/L and TCEA at 48,000 pg/L,
The sump is near the abandoned underground TCE/TCEA storage tanks (see
Facility Description section).
-------
•K
CO
UJ
— 1
0-
co
UJ
cs:
O
u_
i^
uo
0.
»
kD ^* O^
r-H
Q O O a O Q Q
z o o z o z z
O CT1 CM
r. r ~
i^D ^O O"i
i— 1
•K
•^ -^
•K -K
C2 CD O O O C2 Q
Z O O P- O Z Z
O ^~* rH O
,. f r.
O UO CM
CM T— >
QJ
QJ
Q, JE
C +J
TO QJ
QJ JC OJ O OJ
c *-: c s- aj "a
TO a QJ o c "—
-C C ,C r- OJ OJ t-
+J 1- +J J^ C J^ O
QJ O QJ CJ QJ 4~* r —
OP— O •-- -C OJ -C
S- JZ. S- C3 *J O U
O U O 1 QJ i-
i— -r— i — CM O O QJ
jz s- ^: » s- i — c
u i— o i— i ox: aj
•r- ] -i- 1 U i —
r— i (-H C^ j
1 1 C U S- JZ
i— H rH <™1 TO "— ^-^ *-^
S- S- QJ QJ
i— < rH v— ' 'r— >— t— S
*-*
o _e
<+- C
t- Z!
Z! O
CO CL
E
CT
r~
£„
a. QJ
CL >
•r- O
5- t—
+J
oo
iy
H-
— '
ij")
s:
i—
^D
m
y
h*~
r=
r~4
y"
t—
ZD
"D
C
3
O
CL
E
O
c ^
•K
aooon->oot=roo
zcozzLnz'S-csizz
CM r— 1
/^^ ^D f^ j^2 CT^ /-*i r*^i f — i r~i r^
*3^ 2T, iZT rH "2*" "^ 21 ^S "^
•K -K * 4<
* * •»< -K
•K ^ "K ^C
^7^ co <~^> «^" CQ co f*"*! f~*\ ro ^"^
^^ "^ ^* ~^ "3*
f~*i CO f"*> i^^ r^* ^^ f~^ f~^ r*~\ <^>
z z r-zzzzz
* * *
•K * *
* * *
r*^ CD co f~> cr> <«o f ^ <^^ r~^ cz3
*~H c~ ~i t f^ p^. f^ r— 4 -^" ^^ ^f t-^
CO rH CO
*• ^
rH v— t
*
*
*X
QOOCiCDC2OC3OO
^002^02:^2:^^:
U""5 r— ( kjO
*. „
CNJ r*^*
QJ QJ JZ
TO QJ C +-> CL
QJ -C QJ O O TO
C+JCS- QJ C i — ' — •
TOQJQJO C TOTO-—
-COJZr— OJOJ 4->JZ>-i
4-^ i- *-> JZ r" c~ c 4-> X
QJ O QJ LJ QJ 4-* QJ JZ QJ
O r^ O •»— JZ QJ Q. CL -C
S- JZ S- Q 4-> O 1 >—
OUOIQJt- CSJi — >v
i — T-.— CMOO i >>^;
JZS--C - S- r- r— *J +J
U r— UrH OJZ QJ >,3UJ
•r- 1 -r- 1 1 U C JZ CO 1
C3 '•H C3 ^ JZ TO O 4-> 1 CM
I * 1 c~ (_j ^ ^) QJ c *^-^
rH rH rH TO *r— *-> QJ y | t/1
- S- t QJ U 1 •>- -r-
rHrHrHI — i — r— <£ ^J" "D J3
"5
Cr.
3..
^— ^
k
0)
4J
•H
\
O
+J 4J
It! U t!
k <3? QJ
4-' +J +0
C! tt) TO
-------
The inorganic data from the Task Force samples suggest leakage from
the impoundments. Data for selected parameters present in high concentra-
tions in the impoundment sampled during the inspection are compared in
Table 11 tc data for wells having elevated concentrations (relative to con-
centrations in the other wells) of these chemicals. Data from the stripping
tower discharge are also included for comparison because they are probably
indicative of parameter concentrations in recharge to ground water from the
nearby spray field,
In Table 11, the parameter concentrations for the respective wells are
listed in decreasing order from left to right. The well locations are shown
on Figure 3, The pattern of elevated concentrations suggests southeasterly
migration of chemicals from the impoundments.
TABLE 11
SELECTED INORGANIC DATA FROM TASK FORCE SAMPLES*
Parameter
Chromium**
Cyanide**
Sulfate***
Sodium***
Magnesium***
Settling
Basin 2
2,840
53
1,250
268
263
Stripping
Tower
58
<10
28.5
11.5
7,6
RCRA 2
1,280
20
500
37.4
44.7
RCRA 3
246
<10
500
45.0
46.1
UTM 3
395
<10
250
28.4
25,3
RCRA 4
8
<10
44
17.4
16.9
* Data are froze wells adjacent to the surface impoundments
** Concentrations are in micrograms per liter (ugr'L)
*** Concentrations are in milligrams per liter (mg/L)
-------
APPENDIX A
BORING LOGS FOR UTI WELLS
-------
APPENDICES
A BORING LOGS FOR UTI WELLS
B GROUND-WATER QUALITY ASSESSMENT OUTLINE AND PROGRAM PLAN
C ANALYTICAL TECHNIQUES AND RESULTS FOR TASK FORCE SAMPLES
D UTI MONITORING DATA FOR JULY AND SEPTEMBER 1985
-------
Hole N o • __."-
location i
Decth of Water Tac^e
.-.; _ e
I 0-
5'
3'
5'
7'
21'
£0'
79(
S51
SI'
96'
110'
146'
^ark to reddish brown( 10R3.5/5) Silt loan
Dark to reddish brown (10H3.5/5) Shaley
silt loam
Pale to moderate red (5H5.5/3) Silty shale
Pale red to greyish red purple (5H?5/2)
Silty shale
Dark red broira (10R3A) Shale
Greyish red (5H4/2) Fine grained zicaceous
sandstone (calcite en fracture); some
li^nnite in oxidized
Greyish red (5P-4-/2)
Greyish red (5?-4/2)
Greyish red (10HA/2) Llicac-eous siltstone
u.uc.stone
Siltstcne
reyish red
2 Micaceous siltstcne
with few calcite stringers
Dark reddish brc~ (1CP-3/4) ihale
v.ater
Damp at 39'; moist t:
wet at 51'
Water at 77' (It ~-
Water at 79' (1C ^.~
Vrater at 56' vl5g7-'
7/ater at 119' (20;
Water at 121' (3C.
gpm) at be
Water sample blown froa bottom.
Water sa=ple bailed at _ end cf drilling
-------
A-2
3QY r, '-.ES'CN
i
Borehole No.
Locat i on
UTM- ! _ I'Cont i nued)
UTI
Depth of Water Table
Date Or i'I led :6-27 Cctcbe
?roject
3 . I. S.
'767-001
LOG
Deoth Zone ft,' 'hickness fft.) Oescriotion
1**6-151
151-153
153-160
160-16*
'Sn-176
176-178
178-186
l86-'97
197-200
200
5
2
7
1+
12
2
8
l '
3
Gray, red and tan shale w' c^
Calcice fracture Healings.
Fracture -- Total discharge
now 125 gpf-
Gray, red and tan shale with
Calcite fracture healing?.
Gray, red and tan shale w th
two $ma ! i f 'ac tures at
162 and 163.
*ed s'aie softer t " a n t n e
red , g ray sha 1 e .
^ed, gray s^ale.
L i ghcer g-ay sha 1 s; srsl 1
fracture at 178.
5 ~cwn , gra/ snale, $~al i
fracture at 186; cuttings are
occasionally iron stained.
E, rown, red sha 1 e wi th a
srral 1 f rac ture at '97.
End wi th •> 100 gpm.
Set 20 ft. of 6" surface
casing with drive shoe and
grout .
-------
T i»*\ /"»
j-v-G
Hole No
Location NZ of Tar.>s
Date -rilled lC/=/
Project TT:
Depth of Water Table
Casing in Hole
Froa
To
0
1«
4'
91
2'
O1 •
0'
Cf
0'
•- 1
5'
2'
5'
0'
2'
4'
6'
'^ 1
w
5'
1'
4'
9'
12'
20'
40'
50'
70'
30'
105'
122'
125'
130'
132'
134 '
136'
i K r, i
J.-T-J
145'
146'
1
Moderate reddish brows (10R4/6) Silty clay
Moderate Brown (5YH4/4) Clay loam
Moderate Ero^n (5YS3.5/4) Silty loan
Dark reddish brown (10R3/4) Shaley silt
loan
Pale to dark reddish bro?ra (10R4/4) Shale
Dark reddish brown (10=3/4) Shale
Greyish red (5R4/2) Silty shale
Dark reddish brown (10R3/4) Shale
Greyish red (5R4/2) Silty Shale
Dark reddish broirn (13P.3A) Shale
Greyish red (5R4/2) Silty shale
Pale greyish red purple (5HP5/2) Pine
grained nicaceous sandstone
Pale greyish red purple (5HP5/2) " . r*
£ * j u.j w w*-6 *
Grey (K6) Shale
Bluish grey (536/1) Shale'
Brown (5YR3A) Shale
Alternating greyish red (5H4/2) to greyish
purple (5P4/2) Shale
iilcdiun to mediuzi dark grey(N4.5) Shale
Greenish grey (5G6/1) Very fine grained
quartz sanaaxone.
Water easple at 46'
Water sample clown from bottoa
Water sanple bailed at end of drilling
Wet at 22' ; sewage :::
Danp at 30': sewage czr
Sanple at 30' and at
46' soil
Water at 72' (lgp~;
TJ&ter at 122-127'
(60-70 gpn)
-------
Hole :>o.
UT -i
Location last of rcr.ls
Depth of Water Table 2~'1C"
Date Drilled
Project
Casing Ln. Hois
Description
0
4'
8'
12'
23s
23'
60'
62'
67'
63'
70-
4'
8'
12'
23'
28'
60'
62'
67'
63'
70'
i w
71'
iioderata brownish red (10R4/6) Silt loam
Dark Reddish brown (1033/4) Silt loam
Dark reddish brown (1033/4) Shaley silt
loam.
Dark reddish brown (1C33/4) Shale
Greyish red (534/2) Shala
Dark reddish brown (1033/4) Shale
Olive grey (5Y4/1) Shale
Greyish red purple (53?4/2) Siltstone
Greyish red (534/2) Fine grained, bedded
sandstone.
Pale red to g~eyis'i ^~ed purple (si3P5/2)
Very fine grained sandstone.
Dark reddish brown (1033/4) Very fir.*
Damp at 25'
'.Vet aeasi 32' -
Wet at 39'
7/ater at 40' (
Water at 67' (
Water at 68' (
SO1
32'
87'
S51
100'
'
SO'
32'
37'
95'
100'
145'
grained ferruginous sandstone, Vuggy
•-gossar.y appearance en bedding plane
fractures
Greyish red purple (53P4/2) Very fine
groined sandstone
Dusky red (533/2) Shale
Greyish red purple (5H?4/2) Very fine
grained suidstone
Light bluish to greenish grey (536.5/1)
sandstone. Li^onite or. fractures
Greyish red (1034/2) i-icaceoua ferru-
ginous siltstone.
Moderate to dark reddish brown (1033.5/5)
Ferruginous shale. Li^onite in oxidized
•*«•
vugs.
Water sarpS at 40'
Water ssuiple at bottom
Water bailed at bottom
Water at 95' C.CCgp=
'.Vater at bottom!. 125.~
-------
J
r.oj.8 .NO,
Location ___
Depth of T/ater Table dl' 6"
Date -n:
r"*"11 *• /**, *• rt ^* •*•
*, ^ w e ^ »
Caeine ir.
ole
Description
0
1'
4'
7s
12'
22'
33'
45'
6C1
1C5'
11
125'
4'
7'
12'
22'
33'
45'
60'
105 '
1111
125'
"! ' •
it O
Uoderate to dark trcwr, (5YH4/4) Orgorxic
silt loam.
Moderate reddish crown (10R4/6) Silty
clay loaa.
Moderate Erowa (SYR4/4) Silt loam
Dark reddish brown (10R3/4) Sheley silt
loam.
Greyish red (5?,4/2) Siltstone
Greyish red purple (5HP4/2) Siltatone
Dark reddish brown (10H3/4) Silty shale
Greyish red (5^4/2) Silty shale
Dark reddish brov,- (10R3/4) Shale
Greyish red purple (5HP4/2) Fine
grained sandstcns
Dark greyish red (5~o.3/2) ' Shale
Dark reddish bro-.vn (10H3/4) Shale with
calcite stringers
V/ater sample afl05'
?/ater sample blown from bottom
Water s&scle bailed at end of
drilling
Danp spot at 53'
Water at 1C5' C
V/ater at 117' (2
Water at 132' (3
-------
^HHV^ Hole no. UT - 5 Date Zr^l"»i --,--
^HV^ location 200' 5 of :o . 3 Project VTI
^F^ Depth, of Water Table _ 33' 6" Casing in Hole __ :T
?mm Ta Descriction Comments
0
4'
6'
7'
9'
16'
13'
24'
27'
30'
36'
43'
4c
52'
55'
60'
69'
127'
134'
135'
139'
140'
4'
6'
7'
9'
16'
IS'
24'
27'
30'
35'
41'
46'
52'
55'
60'
69'
127'
134'
135'
139'
140'
146'
Moderate 3rorm( 5Y23/4) Clay loam
Moderate reddish brown (1034/6) Hard
clay loam.
Dark reddish brown (10H3/4) Clay loam
Dark reddish- brown (10H3/4) Silt loam
Dark reddish brown (10H3/4) Shaley silt
loam.
Lladerate brown (5Y33/4) Shale
Greenish grey (5GY6/1) Siltstone
Light olive grey (5Y6/1) Siltstone
Dark yellowish brown (10YH4/2) Siltstone
Greyish red (5H4/2) Siltstone
Dark reddish brcr.-n (1CR3A) Shale
Greyish red (5R4/2) Micaceous siltstone
'-lode rate Srowa (5YH3/4) Shi-le
Dusk yellowish brovm (10YR2/2) Shale
Greenish red (5R4/2) Siltstone
Medium grey (^5) to greyish red
Very fine grained sandstone
Dark reddish brown (10R3/4) Shale
Greyish red (5R4/2) Siltstone nossibly
argillite (well ind-^ated)
Greyish red micaceous ferruginous bed-
ded siltstone.
Greyish red (5R4/2) Siltstone with few
small seams of interbedded greenish
grey (5GY6/1) siltstone.
Dark reddish brown (10R3/4) Siltstone
Greyish red (5R4/2) Siltstone
(areillite?)
Water sample at 41'
Water sample blown from bottom
Water sample bailed at end of drill
Damp spot at 32'
Water at 41' (lg
Water at 77' ( 4g
7/ater at 131' (7
. •
Water at 139' (1C
lag
-------
ROY P, WESTON
lC LOGS OF BOREHOLES
Borehole No. UTH- 6
Location UT1
_ -Depth of Water Table 30
.(ft.)
Date Drilled 31 Octsbe.-
Project 1767-OQi
B. L. S.
Deoth Zone (ft.)
LOG
Thickness (ft.)
Oeicr!otion
o -11
11-20
20-23 -
20-57
57
57-60
60-146
11
9
3
37
3
86
• Regol I th of red shale
. fragments.
Soft red shale.
Harder red, brown shale.
Soft rtd, brown shale.
Small fracture
Red brown shale
Hud, no flowing water;
red, brown shale fractures
at 68, 91, Ik), 1<*3, 1^.
Set 11 ft. of 6" surface
casl ng wl th grout.
-------
ROY F, WESTQN
STRATI GRAPHIC LOGS OF 3CREHOLF
Borehole No,
Locat i on
U TH - 7
UTI
Depth of Water Table
Depth Zone (ft.)
30
(ft.
Date Or i 1 led 28 Occooer 19V7_
Project
B, L. S,
LOG
Thickness (ft.
Oescr i otion
0- 2
3- 8
9-30
31-3^
35-55
56-85
86-92
Water samples no
t
End drill i no
2
S
21
3
20
29
h
6
: taken.
it *: 20 o.m.
D.T.W, 33.5 kt 4:45 p.m.
I
Sol 1.
i
Weathered red clay; very
f i ne grai ned , t
Predominately red clay;; 2"d
siltstones interbedded w th i
gray siltstones (harder :kci '
red) .
i
Predominately gray beds v/i t-
red layers between.
^
Red shales and brown mic.iceous
siltstones. No grain beds
noted. ^*S-55 - homogeneous
red shale; very fine graines.
Same 1 i thology wii th stltstones
and sandstones (fine era necP
becoming more pr«dominat«.
Fractures noted In this i.ection
but no free water. Calcite
deposits on cuttings.
Fracture zone of same litholoc
Free water at 36". Q. » L-Q-+5
g/m very quickly after rsacning
86'.
88' Large fracture
Damp spots - 30' , 55' , 7B1 ,
Wat«r - 861 .
-------
RCY F, WEST ON
STRAT (GRAPHIC LOGS CF BOREHOLES
Borehole No,
Locat i on
^
UTi
Depth of Water Table
25-26
(ft.
Date Drilled 26 October
Project
B. L. S. .
Depth Zone (ft.)
LOG
Thickness (f t .J_
Oescr i ptj_on_
0-10
Brown/gray topsoil loam.
11-20
90
Red and gray siltstone.
21-26
Dark brown P.O. Sandstone,
27-93
66
Interbedded micaceous scltst;
mudstones and some sandstone
Predominately red with some
gray and brown.
9^-105
1 1
Harder sandstone -- fine era
Brown - micaceous.
0*6 g/m.
1C6-115
Brown sandstone - frsc:.rec
throughout (106-107 greace-
fracturing). Calcite trace;
on rran y p i eces ,
116-H+5
Interbedded red sMtstones a
brownish * i re-g ra i nee sancs'.
Numerous fractures noted.
118' - i*G g/m - Q
End -
Sample #1 - Ai
Sample #2 - Ba
Fi rial" Q. « 60-6^
End Dr ? 1 1 i nq
. 0,T.W. - 36.
Blown 130'
ler at end - 1^5
g/rn
at 1:55 P.m.
]T' at >+: 20 p,m,
Predominately the red siltstcres
with grays and browns notec
i ntermi ttently.
-------
A-10
WELL LOG
WtH
t\
1767-09-01
Drill Cf"~T*"r-- qronkoviejr—
C. Brookover __ F*ld Boo* No_
»Ug.n- 6/12/85 E~< 6/12/85 Log
fry Inhn Crnmer
Jot) NO.
Drillinfl Mtlhod —
Sampling Method
Casing Sue
' Typtotrich- Gravel (tr'p rock " V' to 3/4":LT*p*Q<
6/21/85
4" PVC
. Scrwn
20 (CJ.OfiA)
Slots _ Jo«nt
LOCt1
B«ntonit«
Emplacement Metho
Development Method Worthington Air Cotr.re^
- , Date Developed: 6/19/85: 180oi.it/ir.inWorthington
Total Run" Time: 48 min; *WLt (init^ water)
Gallons
Compressor:
57.23 feet: TD§(depth t<^ bottom of
scree
DtscripVion
Dark red brovm CLAY, mod. silty,
slightly to raod. cohesive,
saturated.
Siltstone very dark red brown,
60X clay, sand?, slightly
Siltstone, dark red browi), less
clay (10-15*)? trace sand,
slightly moist.
Snail V aax. re
chips beccmir.g, a:
Less clay (10, •
sooe sand.
Angular
3/4".
Siltstone, red brown to gray,
sor.e clay (10%)
Siltstone, red brown to gray,
sone clay (iO%?)
1 *W1 , (measured ,froa top of casing
3/4" cax, chip
fine particles
Larger,
cuttings
over t"
-------
No
#1
U.T.I.
Job No
LOO By
Johft"
Description
w
*
6/12/85
' ; r s ; Water
•
Bottom of
Screen82'5"
4MMHH^M^«
f
-»:
—
-
2*
-
—
—
3-3
-
-
™
-
jj-
—
^
1°
--
.T j
b
9
10
11
12
13
14
15
16
17
IS
f
38-
39
43
48
53
58
63
68
73'
78
83'
r
1
f
Siltstone, red brovn to lighter
gray, some clay (10-202),
Siltstone, red brown to lighter
gras , less clay ('vlG*:) .
Siltstone, sandy, silvery blue
gray with dark red brovr, clay
(30-40i), moist.
S i 1 1 s t or. e , s ame ^ , less moisture1,
less clay (^20-25"/.).
Siltstcr.e, more sand (fn.-oed.),
oed. to dark silvery gray,
L
•
Essentially the
same .
Avg. 1" max. car::
cle size , ger.er i 1 .
1/4" and stnalier
particles.
Mavbe less ss- -,
gray-green-biuc
color in some i - -
particles ,
Overall appears- :e
of samples is earn
r*d brown contair-
ing from "^55i t; \~.'
clay *t Che boctcr
of the hole, a-J.
saturated.
-------
WELIJ.5G
No
-------
e
0
0.
f-!3
«=j w
Well Construction Summary
Ljacalnn or
fcwvtton Ground Level
Top of
Drilling Summary:
Total P*r*h Drilled to 82.83*
8"
G«orge Brookover
Schraom
Air Rotary
Water
surface Casing _5' length 8" diameter
Well Design:
Basis Geologic Log * Geophysical Log_
Casing Slrmg(s) C*Casing S = Screen
±2*i'- 62.4' .Ci
62.41. 82.4' SI
4" diameter PVC
Screen
PVC Screen, No.
20' of Schedule 40.
,02 In
Centraiizirs.
Filler Materai Gravel (Trap_Rock - V -
3/4") bottom of hole to 57.42' dept
Cement _
Type 1-15 bazs
'Stone Portlanf Cement
Construction Time Log:
Stan
Tas*
eopnys Logging
Casmg
65' Schedule
40 PVC
Q' PVC Sereer
ef PUcement
Cementing
Development.
Other
W!
6/12
6/12
6/12
6/13
6/19
0955
1615
1630
0900
1104
Fini
6/12
6/12
6/12
6/13
6/19
Time
_1600
102C
Well Development: '
Date: 6/19/85; 180 cu Jt/t?in Worthinj
«c-j
Air Compressor; Total Run Time: 48 c..-
HTj^ (initial vater level) - 57.23 ft,
TD (depth to bottos of screen,' »
*WL< (Measured frott top of casing
- T.O.C.)
Comments:
40 Ibs, cf bentcr.ite usedL
-------
A- 14 VMMLtt
WELltOG -«9«-l-oil_
^. ,. ^~ RCRA t2 tyillCftfrri^r SrBfihQv^r Laefcy •IjVm Tramfr
^. .. U.T.I. tvm«f C. Brookover f^ld ftft^k KJa
1767-09-01 B.1*fuQ^6/U/85 p^6/14/85 i^ ft.,. 6/ 2 1/85
r, •itrnll.ttiMl Air R9tarv ••gSchrajam
Drtlling Mtr>OQ- ' ^*»* ' *
&*mfilme Mtlhod Gr»l No 8*mpiti_4i!_
loci.' of
" pvc
8«ft
. p! ptck Gravel (Trap Rock- k" to 3/4"! Typ*. tf g*»iBentonite & Grout (neat
Emp!.ctm*ni Method..,. shoveled ln Empltctm.nt Me** Grout ™L
25' 48' to 23' »»«f~f' Bentonite 2' (to 21') grout to s
lOtfVB' ______—— ; — ~
Development Method «°rtV.ington Air Compressor , . , Oi1lwi Remo,^^-.
r ... Date developed: 6/19/85; ISO cu.ft/«in Worthington Air Compressor __J_
Commtli"Total Run Time: 29 min; WLj (initial water level) - 3«.47ft;
_m hnrrnn nf ^ftpf^^ - 48 . — _„___—
Description
•T.O.V.Z.
**T.O,R.
Very dark red brown CLAY, silty,
only slightly cohesive, moist, son*
small (to 1/4") silt particles.
Dark red brown CLAY, very silty
with siltstone pebbles to 1" max.
average size mixed iru
Siltstone , sandy (ned-fine grained
silvery gr«y with pink dusting of
clay (20 - 302 clay gray brown in
30' sample)
6/14/85
First Water
Bottom of
Screen at 48.
TD49'
Siltstone very sandy, dense, hard,
dark silvery gray, some («pprox.
10 -20%)red brovn clay.
Siltstone verging onto a sand-
stone (actually a siltstone with •
high percentage of medium grained
sand} ,very dark gray, dense and
very hard, some to very little red
brown clay.
NOTE: WL. (Measured from top of
1 casing - T.O.C.)
* Top of weathered Zone
** Top of rock
Siltstone pet
go from rour.d,
angular
Less dust cc-:
from hole at
Moisture fel:
sample at 30 ' ,
At %34' war.e
coming into th<
hole. (Harm-
ing at 33' j. ,
Cutting size
less.
-------
£
t
V
l->
4>
t»
V
F*4
o
u
i
9
u
c
«
sn
u
£
H
e
v.
c
W
1
Monitor Well Installation PIW^TOO»| John Cramer
i •
21
23
y E
i.
t
,'• — '
> ~-
' _-^_* '.
•"--_ ).
. -~~~ c
• - ;
«7
r*w«
Well Constru(
a
L.pe«lOn p< C«yflt . „ ,
Drilling Summary:
Tnlai P*pif !>am«l«r ,, 8" ..
DfiUar Brookover Well Drilling Co,
George Brookover
D,O Schratma Air Rotary
fiit(»)
Qrilli^Q ^lu'fl A^r Korarv
Wa t(» r
<;urtar* flawing S' 1p"P-h 8" diatneter
Well Design:
Basis Geologic Log ^ Geophysical Log_
Casing Slnng(s) C^Casmg S« Screen
+2' - 28* C,
?R' - A8' S.
I
- -
~ ~ — .
• •
rj<.,pio r, 30' Schedule 40
A" diameter PVC
r 5
e-.*.« c, 20' of Schedule 40 PVC
SCf"n S .cre'er.;Nc.-20 (C.C2 ir. - ' "
'ilots.
S?
C^nt't^rf s
Frtr. y,,.,.r, Gravel ("Trap Rock" -
1/V' - 1/4"> botr<7ir> of hole to 22.83
C^mfni l^pycror,* PnfrlanH depth
Cement Type I - 11 bags
Qt»>ef
:tion Sun
E*v«ion Ground
Top 01 (
Contraction
Task
QfiMmg
Geophy* Logging
Casing
30' Schedule
40 PVC
£0' PVCScreer
Fmer Placement
Cementing
Otvttopmenj
Other
v»til
n<,f*f< t ..
imary
Hv»
Ul-rvo
rime L
Su
?m
6/H
6/14
6/14
f./iy
A/19
.09:
in
Time
1045
1420
16_15
Ift^S
0945
F.-vi-
.Daijf T-
15oi
6/H I-'
6/u u:
6/U If.
k 1 \L
6/19 1C
1
Well Development:
Date: 6/19/85; 180 cu . in ,
Worthingcon Air Compressor
Total Run Tioje: 29 trir. ,
Wl. (initial water level) • 3£.-
TD* (depth to bottotr of screen
*WL (Measured frott top of casi".
A T.O.C.)
Comments.
30 /''s cf
ber.tcrite use:
VTTI^
-------
WELL LOG
W»M Nft RCRA »3
*li§nt U-T<1'
Inh Nn 1767-0"?-™
Ciritlino Wt1hOd_,,- ^r.-
S*.mplir.Q Method Grab
C*»ing S*ze tnd Type _
Tyj^otPirh Gravel
Emplacement Method
Interv.. 25'4", 42
Y^J
CVi'iOfrT^y' Brookover
CVitt^C. Brookover f
p.l»R*g»rv 6/1 7/85 Erwi <
Rotary
Ma Si
4" PVC. Seff.nS
fTrao Rock 1/4" to 1/2")
i Shoveled in
'4" to 17'
UX4ASNJ
P«9*_J — o«_J
Lee m John Crtoer
4lijf IJfcv* Na
5/17/85 ingn.,.6/
R.0
TD't^
No. 20(0,02 in)
21/85
Schraum
MntTvO«Thre*d Pin*l««nfh ?0'
Type e>* *rt»l Bent onite & Grout (neat cement')
Emplacement
lnt»rvnlBenton
Method Grout was pumped in.
ite 2' (to 15'), Grout tc sur
p^ . .11 ^^< Worthington Air Coapressor
Development MeO^oo —. —
GiHoni
ron»f^, Pate Developed: 6/19/85. 180 eu.ft./mln. Vorthington Air Compressor; . , ^
Total Run_Time^ 58 «in.. VL^^ (initial water levell_?_ 33.35'; TP^ (depth to bottom of scree-
/*/ A
**/ /*
*T.O.W.2.
u~~ 1 !• •"
**T.O.R.
6/17/85
First Water
Ii
•»
m
•^
•
*e
m
m>
•c
»
ifc
»
k
«^
M
v
—
r
r*
^
1
2
3
4
5
6
7
8
//
"A
5'
10'
15'
17'
ZO'
22'
25'
30
»
y
/
/ Description
Dark red brown CLAY, moderately
silty, slightly cohesive, tnoist.
Dark red brown CLAY, silty with
lumps of Siltstone, The number of
siltscone lumps increase with
depth.
Siltstone, with shale, yellow-gray
cast over dark gray nixed shale
particles and clay.
Siltstone, dark gray with ^50Z red
brown, mod. cohesive clay mixed in
Siltstone, red bra., with ^OZ
silty mod. cohesive saturated
gray-green clay with a pink tint
and some coarse sand.
*Top of weathered zone
/Remark^
' 1
!
1
Rounded lumps of
•iltitone be:oo« c
angular and sere ^
numerous. j
I
f
<
9
I
!
!
Siltstone chips
(cuttings) .
l
Froa 30 to :5' dn
with more silest-v.
chips. |
-------
RCRA #3
U.T.I.
1767-09-01
log fcy_Johr. Crtre
Dttcrtption
«
i
V
I
1
\
i
1
\
I
1
1
1
- w
Bottom of
Screen at
42'11"
TD 43' "
•MM
£
»
•W
•
-i
Cfr
tm
—
^^•t>
—
t
^-
i
—
9
10
11
35'
43'
Siltitone, red-brown gray with
•bout 40Z red brown, aod. co-
hesive, iaturated clay mixed in.
Siltstone, moderately to very
tandy, red brown with »hiny
flecks, 30 to 40Z red-brown clay.
Siltitone peb>- 'ess
chips to a little
over 1" ma*.
•
Siltstone chips
measure up to i"
average size,
-------
A- 1 Q
0-
I —
Well
Well Construction Summary
Locator* or Coxd*
Ltvti.
Top o< Casing.
Drilling Summary:
Tolil r^pih Drilled to 43'
Construction Tlmt Log:
D«m«ttr
Brookov«T Wall Drilling Co,
Rrookover
Rig _
Bit(S).
Schratmn Air Rotary
Task
Oiling
Drilling Fluid.
Air Rotary
Water
Casing.
Well Design:
Basis Geobgic Log T Geophysical Log
Casing Stnng(s) C = Casing S = Scr**n
4* -22.9' Cl
Geophys Logging
Casing
Fitter Placement
Cemeniing
Casing
24.9' Schedule 40
4" diameter PVC
Date
985
6/17
&UL
6/17
illl
6/19
6/19
Tim«
1115
.9J-5
./I 7
1310
1405
1455
1343
MM^^^M
1343
Tir
1 ,
17
6/l_9_
15
C2.
Screen
2Q' of Schedule 40 PVC
Screen, No. 20(0.02 in) slots
S2
Well Development:
Date: 6/19/85; ISO cu.ft./nin.
V?orthington Air Cogrpressor
Total Run Time: 58 min.
UT (initial water leveH - 33.35
C«niralizers,
Fitter Materal Gravel ("Trap Rock" .
l/4"-3/4") bottoc of hole to 17'deptt
cfnn* Pnrr 1 anrf r*o*ft* H f
TD (depth to bottog of .screer,} ;
' 42.9' ~
*>i1.J (measured from top cf eas•.-
Comments:
50 Ibs. of bentonite
T.
Type 1-5 bags
Otner,
-------
WELL LOG
Wetl Ho .. KCRA tk M- £rai £
j^N« 1767-09-01 D.UR
0,111,00 MtMhftff Mr rottry
Sampling Method -Gr«b.
Page— I — e< 2 __
/srt^any'Brookoye^L. Lag Py John Cramer
r G. Brookover Fttld Rook Wo
*gan 6/10/85 £^6/11/85 ^ag ft*tf 6/21/85
Bio Schrana
Un**mpl« 15
Casing Sat and Type *1IX£
Type Of Par1- Gravel (trap rock - V - 3/4"")
Emplacement u»»ftd Shoveled in
interval 26',_76' to_50' depth
• Type
Domt TyptThrpii1_ Pipe Length J£__
Bentonite and ftrout
Development Method Worthington Air Compressor
Emplacement Method Gr°ut v«s pumped i
Interva! Rentonite 2' (to 48* depth)sur:^e
Gallonj
Commentj Pate developed: 6/19/85; 180 cu. ft/min. Vorthington Air Compressor;
Total Run Time:*33 Bin., VL ± (initial vater level) - 69.05 ft.; TD^
C° boctoc
///m////
Top of
w e-at.be re d___
zone
Transition
* o bedrock
**
T.O.R.
WM^^
6/11/85
First "Cater
**Top of
rock
— (.
"" C
^iC
-, ,
•^.
"or
•M*.
»
=21
V
Af
»
^
*
^!
•
w
•*(
^
^
^
-
"
-
^5
I
I6
-
-
1
2
3
4
5
6
10
11
12
13
i /
Iv
15
r
J-9
12'
17'
18'
20-
21
23-
24
26
28
33-
34
40'
41'
43'
C A
50-
51'
59-
bO
/ Description / Rtm«rks
Dark reddish brown CLAY
Dark reddish brown CLAY, very
silty, with a few siltstone peb-
bles to V size. More rounded
siltstone pebbles to 17' depth.
Siltstone reddish tan with some
clay in che upper 1' to little or
no clay at 20 ft.
Siltstone, light, reddish gray-
green, some shale or clay.
Siltstone, toed, gray to reddish
tan, some clay (10-205).
Siltstone, dark red-brown with
more clay (30-40X) .
Siltstone, dark red-brown with
same amount of- clay containing
some (5-10X) fine to »*d. »and.
7 ' top' of weaker
zone .
Siltstone chips a
round ,
Siltstone cutti-,i
are more ar.g.^a-
Siltstone ch-.p-
flattened and a-.
i»0 ' Change of cc,
mod. gray si it sec
with some clay.
Small to k" max.f
and angular cut t :
Driller added vat
to hole at 50',
Essentially the s
but some sand,
-------
WELL
NO
U.T.I,
Log By.
Bottom of
Screen 76!
ID 78'
Dttcriptio*
NOTE: VL^ (memsured from top
of casing - T.O.C.)
-------
t *
o.
, =
3
H' >-
u C
7
Well Construction Summary
Location c* Ccex<5s
Ground Lev»i_
Top o< Casing
Drilling Summary:
Total P*r*n Drilled to 78'
Ekxehoi* Damtttr.
8"
rv.ii»f Brookover Well Drilling Co.
G«orge Brookover
Bit(s).
1
hammer bit
Fluid.
Air Rorarv
Construction Time Log:
Sun
Water
Solace Casing 5' length 8" diameter
Wei! Design:
Basis Geofc>g>c Log_X_ Geophysical Log
Casmg Sinng(s) C = Casing S* Screen
42' - 56' Cl
Casmg
Screen,
58' Schedule 40
4" diameter PVC
C2.
c, 20' of Schedule 40 PVC
Screen, No. 20 (0.02 in)ilots
Task
DnHing
Geophys Logging
Casing
^' Sched 40
FVC
?n» PVC Scree
Fate' Placement
Cementing
Development,
Other
Dite
985
6/10
6/11
6/11
6/11
6/19
•
Tim«
1CH7
132S
1340
1600
1243
,
Date
1985
6/11
_ ,
kj\\
6/11
6/11
6/19
Time
_
^
ROC
no;
15 1C
Well Development:
pate Develooed: 6/19/85
180 cu. ft/min Vorthington Air
Compressor; Totil Run Time: 33 min.;
*^-L (initial water level) • 69.C* f: '
TI>f (depth to bottom of screen) • ~t'
S2.
VL ftaeasured fros top of cas:
1^' - T.O.C.
Comments:
Fmer Material
Gravel (Trap Rock -
to 3/4") bottoc of hole to 50' depth
Cement _ v>v«;'nnp Pnrrla^H
Type 1-16 bags
-------
I
c
f
I
I
APPENDIX B
PART 1: ASSESSMENT OUTLINE
PART 2: ASSESSMENT PLAN
-------
-------
I
I
c
r
i APPENDIX B
PART L: ASSESSMENT OUTLINE
L
I
-------
GROUND-WATER ASSESSMENT PROGRAM
UNIFORM TUBES, INC,
COLLEGEVILLE, PA
INTRODUCTION
In compliance with Federal Register, Volume 45, No. 98,
pages 33194 and 33195, Monday, May 19, 1980, Rules and
Regulations, the following outline of a ground-water quality
assessment program (see outline in Appendix A) has been
developed by WESTON for Uniform Tubes, Inc., Collegeville,
Pennsylvania. This plan is to be kept at the facility.
BACKGROUND
Presently, there are twelve on-site monitor wells at Uniform
Tubes, Inc. Eight of the wells are designated UTM-1
(Uniform Tubes, Inc. Monitoring Well) through UTM-8 as indi-
cated in Figure 1. These eight wells were installed in
October of 1977 as part of an initial groundwater monitoring
and recovery program, which continues at present.
The remaining four shallower wells were installed in June of
1985 as part of a Resource Conservation and Recovery Act
(RCRA) ground-water monitoring program around the two waste
treatment settling basins (Figure 1). These wells have been
designated RCRA monitoring wells (RCRA-1 through RCRA-4) in
Figure 1.
Ground water flow direction is variable. It is westerly in
the vicinity of the four RCRA wells - apparently part of a
convergent flow to pumping well UTM-1 from an apparent area!
extent bounded by UTM-3, UTM-5, and UTM-8. RCRA-2 is the
upgradient well in the localized flow regime of the RCRA
wells . There is an apparent southwesterly flow from the
vicinity of the RCRA wells and UTM-3. There is a
southeasterly flow vector from near UTM-6 and UTM-7.
Water level data was collected on all on-site wells and one
off-site well (Collegevilie-Trappe Authority Well CT-8)
during September and October of 1985. Earlier (1977-1978)
water level data had been collected from just the UTM wells.
The previously described on-site wells and four proposed
additional wells (recommended in October 1985 report
entitled "Groundwater Monitoring Program - Supplement No.
1") will be used in the ongoing ground-water assessment
program at UTI. The approximate locations of the four
proposed wells are shown in Figure 1. These wells will
penetrate the subsurface to at least 100 ft. to more
completely define the flow regime and potential contaminant
migration .
A list of existing monitor wells is shown in Table 1=
-------
1-2
•I
II
£
-2-
-------
TABLE 1
MONITOR WELLS
UNIFORM TUBES, INC
CQLLEGEVILu£, PA
Well
UTM-1 (pumping well,
approx. 75 gpm)
UTM-2
UTM-3
UTM-4
UTM-5
UTM-6
UTM-7
UTM-8
Depth Below
Ground Surface
(ft. )
Sounded Sept, 1985
200
146 »00
64,67
146 .00
(taken from log)
150.00
156.09
92.6
144,60
RESOURCE CONSERVATION AND RECOVERY ACT WELLS
(RCRA WELLS)
Well
RCRA-1
RCRA-2
RCRA-3
RCRA-4
Depth Below
Ground Surface
( ft . )
86
49
43
78
-3-
-------
B-4
Sampling Method
The initial step, prior to sample collection, will oe to
measure the depth to ground-water level, in each well, and
calculate the ground-water elevation. An electric water
level probe or other accurate means of deptn measurement
will be used for tne water level measurements. These data
along with the date and time of each measurement will be
recorded and filed.
Prior to sample collection, each of the monitor wells will
be pumped so that a quantity of water, equal to three times
(3x) the volume of water standing in the well is removed,
All samples taken for metals analysis will be field-filtered
to remove all material that cannot pass through a 0.45
micron filter.
The samples will be stored in the specified containers, see
Table 2, and analyzed within the specific "holding times" of
the respective sample parameters. The sampling equipment
should be washed with available public water supply and
alconox, then rinsed in distilled/deioni zed water several
times between well samples.
PARAMETERS FOR ANALYSIS '
The four RCRA wells have been sampled for required RCRA pa-
rameters. All on-site wells have been sampled for the param-
eters found to be of primary concern in the RCRA wells.
These parameters include volatile organic compounds*, nitrate
(as nitrogen), sulfate, specific conductivity, pH, chromium,
copper, and nickel. The ground-water samples to be collect-
ed from the existing and additional on-site monitoring wells
during subsequent sampling periods will be analyzed for the
same parameters. Ground-water samples will be analyzed for
volatile organic compounds (VGA's) using a gas
chromatographic technique under EPA Method 601 and 602.
Table 2 contains the EPA sampling and analytical methods for
the remaining required parameters .
The previous analyses will aid in defining the migration, ex-
tent and degree of contamination under the site area.
-4-
-------
I c; _.
<: o
S3-
= 51
— -a -
» — i-
fl C
I r '
9)1
o
s
a
ct
£
y}
Vi X
Z M
O f-
<- I
U *
i. •-
U J
Qv CJ
f-
i 2
r 2
z
<
VI
CJ
•« OB
r o
58
I!
E S;
C —'
- 01
X >
a
0
.c
• Of
« M
US »«l
-< c
IB i o L. 8
c-i > C 'J
cni £
-i O
*l
^ v
e
i
%
o
— «
a —
-------
APPENDIX B
, -*^5>-«i(is<. ----
PART 2: ASSESSMENT PLAN'
t
r
L
f,tv -.»"W.^ kudfrju^g^?;^ **•* ?•-'
,^^7-, . *- , >r»>~
-------
-------
D"0
APPENDIX A
GROCJNDWATER Q'JAI ITY ASSESSMENT PLAN OUTLINE FCS
UNIFORM TUBES, INC.
COLLEGEVILLE, PENNSYLVANIA
I. INTRODUCTION
A, Background
1. Well depth, origin, and evolution under the
changing regulations,
B, Purpose
II. FACILITY AND LOCATION
A. Map of location
B. Site location
C. Well locations (existing and planned)
D, Water level data
E. Well draw down data
III. EXISTING MONITORING PROGRAM
A, Review of existing plan
B. Compilation of all existing monitoring data
IV , ADMINISTRATIVE ACTION
A. Description of immediate action to be taken
1. Installation of additional on-site
monitor wells.
2, Resampling of the monitoring
wells .
3. Review of the resulting analysis.
-------
B. Sequence of notification and deadlines
1. Pennsylvania Department of
Environmental Resources (DER)
2. U.S. Environmental Projection Agency
(EPA), Region III.
EXPANDED MONITORING PROGRAM
A. Expanded testing of existing wells
1. GC-MS scan of possible pollutants.
2. Atomic absorption scan for metal
contaminants „
B. New monitoring wells
1, Review possible direction and depth
of plume migration.
2, Review location of existing
monitoring wells.
C. Expanding analytical parameters
1, Modification of analytical proce-
dures to address specific sample
conditions .
2. Quality control procedures for
delineation of possible interfering
substances .
D. Schedule for additional analytical result reporting
1, List of regulatory age-cies and
specific authorities to be
contacted .
2. Format for reporting the additional
analysis .
-2-
-------
Determination of the rate and extent of
groundwater contamination
1. Review all data to determine the
direction and extent of plume
migration ,
Concentration of the hazardous waste constit-
uent (s) contaminating the groundwater.
Comparison of upgradient and downgradient well
results.
VII. SCHEDULE FOR IMPLEMENTATION OF THE ASSESSMENT PROGRAM
A. Phase I
B. Phase II
C, Phase III
Resample for those parameters which
exceed the ground water contamina-
tion requirements.
Reassess the existing groundwater
monitoring plan and assess the fu-
ture needs as specified in the
ground water assessment plan,
Final report and proposed correc-
tive actions .
-3-
-------
WORK PLAN FOR SUBSURFACE INVESTIGATION
IN VICINITY OP SETTLING BASINS
UNIFORM TUBES, INC,
COLLEGEVILLE, PENNSYLVANIA
1.0 INTRODUCTION
1.1 Background
In September 1985, Uniform Tubes, Inc., (UT1) submitted, a report
to the Pennsylvania Department of Environmental Resources (DER)
summarizing the implementation activities performed in accordance
with the ^R February 1985 Groundwater Monitoring Plan for the
existing "* surface.. __ impo-otidments at the UTI facility near
Collegeville, Pennsylvania, The report presented the purpose,
objectives and construction details of four (4) additional RCRA
monitor wells approved by DER and installed at the site in June
1985; groundwater geology and flow characteristics encountered at
the site both during and after the well installation operations;
and the results and findings of chemical analyses performed o
samples obtained from the on-site wells to assess groundwater
quality at the site. In general, the report concluded that the
groundwater in the immediate vicinity of the surface impoundments I
contained elevated levels of chlorinated organics, chromium and '
dissolved solids.
Based on the preliminary findings and recommendations provided j
within the September 1985 report concerning groundwater quality
at the UTI site, further activities were conducted at the site to t
collect supplemental groundwater data using all existing on-site '
wells and and a nearby municipal well. The additional
information obtained from these wells provided a somewhat better
definition of the areal extent anc3 possible source (s) of I
contaminants (by parameter) and the effects of on-site recovery '
well UTM-1 on groundwater flow direction at the site in general
and in the immediate vicinity of the surface impoundments. A f
report was subsequently submitted to DER in October 1985 which j
presented the results and findings of the supplemental
activities. The report recommended that additional subsurface
investigation, including the excavation of test pits and
installation of additional monitor wells, be conducted to (1)
further define the groundwater flow system beneath the eastern
portion of the UTI property (near the surface irapoumiine-fttsH- and'
(2) identify the source(s) and extent of the contaminants '
encountered in the RCRA monitor wells.'
(
1.2 Scope of Work
This document contains the work plan for additional subsurface
investigation in the vicinity of the existing surface
impoundments. The primary elements of the plan are:
-------
D- iu
o Excavate approximately six (6) to ten (10 >
test pits around the perimeter of the two
existing settling basins (surface
impoundments) at preliminary locations shown
in Figure 1-1. These test pits will oe
excavated to determine the presence of
contaminants in the unconsoiidated materials
above tlie underlying bedrock. The proposed
locations of four supplemental monitor wells
will be finalized based on the data (logs)
obtained from these test pits.
o Install "four (4) additional on-site monitor
wells to the east, southeast and west of the
existing settling basins. Preliminary
locations for these monitor wells are shown in
•~~ "Figure 1-1, The wells will be installed to
determine possible source(s) of the elevated
contaminant levels detected in the RCRA
monitor wells and potential migration pathways
for contaminants; to further define the area
groundwater flow regime(s); and to define
possible receptors of contaminated
groundwater.
o Clean out monitor well UTM-3 to its original
depth of 150 feet. This operation will be
carried out concurrently with the drilling of
the new monitor wells.
o Collect and analyze groundwater samples from
the new wells and previously-sampled wells for
a. set of indicator parameters, similar to
those examined for during the September 1985
investigation, Results from supplemental
sampling and analysis will be evaluated in
conjunction with previously-collected data to
define the movement, extent and degree of
subsurface contamination in the site area.
2,0 SOILS INVESTIGATION
2.1 Test Pit Excavation and Sampling
Test pits will be excavated to screen for contaminants in the
soil profiles surrounding the settling basins. Approximately,
six (6) to ten (10) test pits will be excavated to the north,
east, south, and possibly west of the basins. Proposed locations
for these test pits are shown in Figure 1-1. The findings from
the initial six (6) test pits will be used to determine whether
more than six (6) test pits are needed and whether subsequent
test pits will be relocated to locations different than those
shown in Figure 1-1 to delineate the depth and areal extent of
contamination in the soil.
-------
-------
B-12
«0
o »
X X
ij
cli
Ol
§Z
MOW
5S5
2 • H
a.
5
tn
to
>•
-
s >
(- t
C MO
*. Z
< D
a.
Hi
ta
wl
E!
El
U
Zi
H
01
Ul
o u
o o
0
0
o
o. -
C, rj
IT ^>
- O - E
E - - C
0 f
-— C.
>• r —
x PI 2 >
~ Z! C-
z <
I- Si O 4
X 01 u- 6.
n
L.
cr
o
k:
a. te
Ic
r,
k.
O
B ~
K 1C
c.
1C
SI
Kl t, "C
fel -ii
51 w c o
: f *L -
'.
a
a
c
c
O
-------
8-13
Each test pit will be excavated to bedrock or to the limitation
of the backhoe (about 10 to 12 feet below grade) used foi
excavation. Based on the data contained in existing well logs,
the depth to bedrock in the vicinity of the settling basins is
expected to be approximately ten feet. Each test pit will D€
provided with adequate side slopes or shored and braced ir
accordance with applicable OSHA guidelines. According tc
available drawings, the settling basins were excavated to a depth,
of 10 feet below grade or to about bedrock.
During excavation of the test pits, a WESTON geologist will loc
each test pit, recording a description of soil composition,
texture, color and possible visual evidence of contamination.
i
In addition to recording a log of the test pits, the geologist
will conduct air monitoring with field equipment sucn as a
p&otoion-ization detector (PID) and/or organic vapor analyzer
(OVA). Each soil horizon will be monitored as soon as it is
exposed. Where ambient contaminant measurements exceed
background levels, selected samples of the exposed soil horizon i
will be collected expediently to minimize the loss of volatile:*
to the atmosphere . The depth and description of each
contaminated horizon (based on field measurements/observations
will be recorded and collected samples will be submitted, alonq
with chain-of-custody documentation, to the WESTON analytica^
laboratories in Lionville, PA. j
Each test pit will be backfilled immediately after excavation and
evaluation have been completed, Tne backhoe shovel will b
-------
1 B-14
• o To supplement the existing monitor wells and
i ' collect additional subsurface stratigraphic
and water level data.
The new wells, along with the previously-sampled wells, will be
utilized to more completely define the site groundwater
hydrogeology. Construction data for the proposed monitor well
are presented in Table 3-1 and Figiue 3-1. The new wells will be
l 6 inches in diameter and approximately 100 feet deep. Each well
will be constructed of standard steel well casing grouted at
i least 5 ft. into bedrock and the remainder of the borehole will
be left open. The borings for the wells will be drilled with
air rotary drilling equipment.
After completion of each boring and installation of the steel
casing, fche annular space around the steel casing will be filled
with a neat cement-bentonite grout (5:1), At least 2 ft. of
stick-up above ground surface will be provided for the steel well
casing. A locking cap will be installed over the top of the
steel well casing as shown in Figure 3-1. The borings will be
logged by a WESTON geologist, who will also prepare construction
summaries for each of the wells,
After installation, the wells will be developed by surging with
compressed air and pumping to remove sediment within the wells.
4
The tops of the well casings will be surveyed and referenced to
i the same coordinate system as the existing wells. Groundwater
' elevations will be determined for the new wells and all
previously-installed wells. The elevations of groundwater in the
f monitor wells will be used to determine the groundwater flow
1 direction(s) at the site,
*
3.2 Groundwater Sampling and Analysis
i
Groundwater sampling will be performed after the newly-installed
monitor wells have been properly developed and allowed tc
f stabilize for approximately one calendar week. Table 3-2
presents the sampling specifications for the analytical
parameters for testing of samples collected from each well.
Sample containers and preservatives will be prepared by WESTON's
laboratory,
Prior to collecting samples from each on-site well and the
. Collegeville Trappe Authority Well No. 8 (CT-8), water levels,
i will be measured and a minimum of three well volumes will be
purged from each well by pumping qr bailing. This procedure
, will be used to obtain a representative sample of water from eacn
well. The field procedures used for purging each monitor well
will include the following:
o Prior to placing any pumping or bailing
equipment into the well, scrub the equipment
with an Alconox solution and rinse with
i distilled water .
-------
5-15
TABLE 3-1
MONITOR WELL SUMMARY
UNIFORM TUBES, INC.
COLLEGEVILLE, PA
WELL
NO.
UTM-9
UtM-10
UTM-11
UTM-12
DEPTH
(Feet)
100
100
100
100
CASING
MATERIAL
Steel
Steel
Steel
Steel
WELL
DIAMETER
6 inch
6 inch
6 inch
6 inch
(1)
All wells to be cased 5 ft, into bedrock.
The remaining length of each well is to be
left as an open hole.
-------
6-16
B.
B5
<
1 .
X O
O - a.
K
» „• :
CQ K
O B J
a
z
a.
K!
V
y;
Ui
a
a.
«
•«>
C
Z'
t-
z
O1
*•
5 w i
5§
£ d
X >
M
k K
5S-:
H
B9 »«l
M
H
K
|
a.
fsj
O
*£>
•c
c
c
_
c
*
•9
*c
10
V
c— •
U
0
^
„_
§
U
1
: T r
c ~ ~
c a c
— D —
>_ «• >
1 ,-,
- i a
c c c.
r*. — «
«
— >
E
k4
O 01
w a
j;
W
W
-
8
>
0.
& *O
— o £
Tec
C « C.
"S 21 S
> C U
«- ^i ! f»
» t
O C «
O 0 -•
f^ 1*1 IN
K tt
W « £
3 X *J
o « e i
£ t3 0 I
K ec
» IN -jr
»N
U U v
COX
» •» a
i
* « . '
r— f^ ^
O 0 C
o o z
CJ CJ S
^ ^
O C '
»
£.&.£.
U U t
0) D C
*J •*-> I-1
"^ ^* ^*
fi ^W --
c. c. c.
§ § S .
U U U
5
»
e
t a =
ic e — E
k. w_ c 0
— 3 C £
Z U) Z U
^ IN
o a-
r^ v
*N *N
' 1
1 i
c
o
o
i
o
U
Qj
a.
E
i ' 1C
V
t
C
£
>•
^
k.
O
_
i ' E
^_
C
S1
c.
e
.C
_
2
O
IT ,C
V T
^«
— C
U" O
I1 *-
i C
i i C >
a
V V
e-
oi a
rt SJ
a -
a
1 E
1C
S. 0".
w ^~
c, a,
a ^
§• ,;' - -
o z - —
.
a
«j
^
3
9)
•c
C
0.
IT
^
M
C
^
•^
~
W(
0
-.
J
£
a
^
1
c
ff
C
C1
~
E
e
L,
a
-
T1
j~4
i
C
O
m
*-
-------
FIGURE 3-1
Monitor Well Specifications
STEEL C*r —
WITH PADLOCK
BORE HOLE
STEEL
/ w
• CEMENT-BENTONfTE 5ROUT
r
BEDROCK
"/ CASING (5 SET 5 ft, (NTQ THE BEDROCK
-------
B-18
o Before purging, measure and record the depth
to water from the measuring point on the well
cas ing.
o Calculate the volume of water to be purged
from the well based on the amount of standing
water in the well casing.
o Purge the well by pumping or bailing at least
three times the calculated volume of standing
water in the well casing,
Sample collection activities will consist of the following
procedures:
,„ o -Inspect sample containers and chain-of-custody
forms and check for consistency with well
number, if previously marked. If not, label
the container in accordance with
chain-of-custody and laboratory procedures,
o Decontaminate bailer by scrubbing with Alconox
solution and rinsing with copious amounts of
deionized water,
o Retrieve water sample(s) from the well using
the clean bailer.
o Rinse each sample container and cap with
appropriate sample before filling, unless the
container contains preservative,
o Add preservative, if appropriate, to sample
container(s ) .
o Add sample and secure the cap on the sample
container(s) . Each VOC sample container
should be filled in accordance with WESTON
sampling procedures so that no bubbles are
present in the container.
o Collect a grab sample from the well for
immediate field measurement of temperature, pH
and conductivity; record the results in the
daily log,
o Enclose each sample container in a "Zip Loc"
bag; place the sealed container in a thermal
chest; pack with sufficient ice to provide for
cooling to 4°C.
o Wash and rinse the bailer and fill with
deionized water; collect a sample of rinse
-------
-------
water in a blank container for quality control
analyses.
o Prepare the chain-of-custody form and proceed
to the next sampling (well) location.
3. 3 Sample Handling and Preservation
The following sample handling and preservation procedures wii:
used at UTI:
o Acidify soluble metals samples with 2 ml o.f
1:1 nitric acid to a pH of <2, after field
filtration to remove sediment.
-" o ""For inorganic parameters, collect proper
sample size; eliminate or minimize sediment in
samples.
o Measure conductivity and pH in the field,
o Collect, preserve and analyze organic
parameters in accordance with EPA procedures
and requirements,
Samples will be placed in thermal chests, packed with ice and
transported immediately after completion of sampling to the
laboratory.
3.4 Quality Assurance
Sampling personnel will implement routine quality assurance
procedures for the collection of representative groundwater
samples and production of high quality analytical data. Analyse;;
will be performed in accordance with the WESTON analytica.
laboratory quality assurance/quality control procedures.
3. 5 Chain-of-Custody Procedures
Sampling personnel will follow EPA chain-of-custody and
recordkeeping procedures to maintain the integrity of ad i
samples.
3. 6 Sample Packaging and Shipment
*
Sample packaging procedure will comply with Department of
Transportation requirements for -shipment of environmental
samples. Individual samples will be sealed in "Zip Loc" plastic
bags and placed in a thermal chest to cool the samples to 4°C.
When the chest contains the requisite number of sample containers
or is full of containers, vermiculite will be placed in the spsice
between the sample containers to provide cushioning during
transport and to act as an absorbent in the event a sample bottls
is accidently broken.
-------
8-20
4.0 RESULTS AMD FINDINGS
The data collected and findings reported daring test pit
excavation, monitor well installation and sampling effort will ce
summarized in a report, whicn will subsequently be rade availacle
to the Pennsylvania Department of Environmental Resources >'2ER,
and the Environmental Protection Agency i£PA}_ Tne raport will
include the following:
o Presentation of soil profile descriptions for
the test pits,
o Tabulation of analytical results of soil
samples taken from the test pits,
o Discussion of findings made from test pit
._ -excavations and how these findings were used
to select the final locations of the proposed
monitor wells,
o Graphical display of water level data from the
sampling effort for on-site monitor wells and
CT-8.
o Tabulation of analytical results for on-site
monitor wells and CT-8,
o Plotting of concentration values to display
concentration density maps (by parameter) in
plan view.
o Comparison of groundwater flow pattern and
water quality results with results from
previously-obtained information.
o Discussion of potential contaminant source(s)
and migration patterns, e.g., movement
direction(s) and approximate rate,
Recommendations will be presented based upon the findings of the
investigation.
-------
f
ANALYTICAL TECHNIQUES AND RESULTS FOR TASK FORCE SAMPLES
r
i
-------
c-i
prc
PRC Engineering
r C *"> C jfrJO'
EVALUATION OF QUALITY CONTROL ATTENDANT
TO THE ANALYSIS OF SAMPLES FROM THE
UNIFORM TUBES, INC, FACILITY
COLLEGEVILLE, PENNSYLVANIA
FINAL MEMORANDUM
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Waste Programs Enforcement
Washington, D.C, 20460
Work Assignment No
EPA Region
Site No,
Date Prepared
Contract No,
PRC No
Prepared By
Telephone No,
EPA Primarv Contact
Telephone No.
548
Headquarter;
\ A
August 21, 1986
68-0'--C3~
15-5480-10
PRC Environment
Management, inc
(Ken P a r t > m H 1 e r
713/292-7568
Anthon> Mor,r^cr
Barbara Elkus
202'382-79i:
,~\
L
-------
C-2
MEMORANDUM
DATE: August 22, 1986
SUBJECT Evaluation of Quality Control Attendant to the Analysis of Samples
from the Uniform Tubes, Inc. Facility, Collegeville, Pennsylvania
FROM. Ken Partymiller, Chemist
PRC Engineering
THRU; Paul H, Friedman, Chemist*
Studies and Methods Branch (WH-562B)
TO' HWGWTF Ed Berg (EPA 8214)"
Jo Ann Duchene (ICAIR)'
Tony Montrone*
Gareth Pearson (EPA 8231)*
Richard Steimle*
Charles Jones, Jr., Region III
Pat Krantz, Region III
This memo summarizes rhe evaluation of the quality control data generated b>
the Hazardous Waste Ground-Water Task Force contract analytical laboratories (1 ).
This evaluation and subsequent conclusions pertain to the data from the Uniform
Tubes, Inc. facility, Collegeville, Pennsylvania sampling effort by the Hazard-ous
Waste Ground-Water Task Force,
The objective of this evaluation is to give users of the analytical data a more
precise understanding of the limitations of the data as well as their appropriate use
A second objective is to identify weaknesses in the data generation process for
correction This correction may act on future analyses at this or other sites
The evaluation was carried out on information provided in the accompanying
quality control reports (2-3) which contain raw data, statistically transformed da>2
and graphically transformed data,
The evaluation process consisted of three steps. Step one consisted of
generation of a package which presents the results of quality control procedures,
including the generation of data quality indicators, synopses of statistical indicasors.
and the results of technical qualifier inspections. A report on the results of the
performance evaluation standards analyzed by the laboratory was also generated.
Step two was an independent examination of the quality control package and the
performance evaluation sample results by members of the Data Evaluation
Committee, This was followed by a meeting (teleconference) of the Data Evaluation
Committee to discuss the foregoing data and data presentations, These discussions
were to come to a consensus concerning the appropriate use of the data within the
context of the HWGWTF objectives. The discussions were also to detect and discuss
specific or general inadequacies of the data and to determine if these are
* HWGWTF Data Evaluation Committee Member
-------
C-3
! correctable or inherent in the analytical process.
, Preface
The data user should review the pertinent materials contained in tn»
accompanying reports (2-3) Questions generated in the interpretation of these da -.
relative to sampling and analysis should be referred to Rich Steimlc of the
I Hazardous Waste Ground-Water Task Force,
1- Site Overview
I
Uniform Tubes, which is located in Collegeville, Pennsylvania, manufactures
high precision, small diameter, tubing and tubular parts. The facility contains, on
site, several impoundments which treat facility wastes. These wastes include piCKie
liquor, dilute hydrofluoric, hydrochloric, sulfunc, chromic, and nitric acids, and
various organics in settling basins and tanks. In 1978 there was a release due to a
leak in an underground storage tank at the facility, The contaminated groundwater
at the facility is being pumped and treated as a result The contamination included
1,1,1-trichloroethanc and trichloroethcne. The geology of the site is soil over
weathered bedrock. The soil is a silty clay material between seven and 25 feet
deep. The bedrock is composed of layers of shale and mudstone. The water levels
in the wells are between 30 to 50 feet below the surface which places the
contaminated aquifer in the bedrock where it is more difficult to recover than if it
* was in the soil
i
Seventeen samples including a stripping tower sample, a surface impoundment
, sample, ten low concentration ground water samples (including a triplicate sample!,
{ two field blanks, two equipment blanks, and a trip blank were collected at this
facility Four of five field, equipment, and trip blanks were used for spikes or
duplicates for one or more parameters.
t
II- Evaluation of Quality Control Data and Analytical Data
1.0 Metals
l 1 Performance Evaluation Standards
' No metals performance evaluation (PE) standards were analyzed for this
sampling effort.
1.2 Metals OC Evaluation
Fifteen of 23 total metal average spike -ecovenes were wuhm the data qualit\
objectives (DQO) for this Program. No spike sample recoveries were reported for
i total tin The average percent recoveries were high and above the DQO for total
* antimony (average percent recovery of 123 percent), calcium (115 percent),
magnesium (112 percent), manganese (116 percent), sodium (114 percent!, and 2in;
t (119 percent). The average percent recoveries were below the DQO for total
, mercury (83 average percent recovery) and thallium (70 percent). No dissolved
metal samples were analyzed. All reported laboratory control standard (LCS)
recoveries were wuhm DQO. The average relative percent differences (RPDs) for
all parameters were within the DQO
Required analyses were performed on all metals samples submitted to the
i laboratory Dissolved metal analyses were cancelled for all samples No samples
-------
C-4
were analyzed for tin. No PE samples or PE blanks were supplied for analysis for
this facility.
No contamination was reported for laboratory blanks. Trip, equipment, and
field blanks show metal contamination involving one or more of the following:
aluminum, calcium, iron, and/or sodium at concentrations as high as 1140 ug/L (see
Appendix 1, Reference 3).
Reported detection limits (DL) are contract required detection limits (CRDL1 or
lower for all metal parameters except total mercury in samples MQO457, 493, and i
499 where the DL is four to ten times CRDL. >
1.3 Furnace Metals
One of three thallium and two of three selenium and antimony matrix spikes !
were outside DQO. The thallium matrix spike recoveries were low and thus the
thallium data is likely to be biased low. The antimony matrix spikes were high and ,
thus the antimony data is likely to be biased high, [
The arsenic, cadmium, and lead data should be considered quantitative. The
selenium, antimony, and thallium data, for reasons mentioned above, should be i
considered semi-quantitative.
1,4 ICP Metals
No initial calibration blank was analyzed prior to the beginning of the first
ICP run as required.
Serial dilution results for chromium in sample MQO499 and calcium in MQO452
were outside of DQO limits. Physical or chemical interferences were unlikely. Data
from these samples should be considered semi-quantitative for chromium and [
calcium, respectively. High dissolved solids concentrations in samples MQ0453, 45".
and 497 may have been high enough to cause physical interferences m the ICP,
The results for these three samples may be biased low and should be considered {
semi-quantitative. j
The overall spike recoveries for zinc were biased high. One zinc spike
recovery was outside DQO. The zinc data may be biased high and should be J
considered to be semi-quantitative. '
The chromium and manganese percent recoveries for the low level linearity *
range checks (this was the first case where the laboratory used the new ICP
protocol requiring a calibration standard at twice CRDL) were very low. Chromium
data below 230 ug/L (samples MQO449, 450, 452, 454, 455, 456, 459, 460. 493, 494,
496, 497, and 498) should be considered to be biased low by 60 to 100 percent (0 to
40 percent recovery). Manganese data below 300 ug/L (samples MQO449, 450, 4.52,
453, 454, 455, 456, 459, 460, 493, 494, 496, 497, and 498) should be considered to be
biased low by 30 to 40 percent (63 to 67 percent recovery.
High sulfate concentrations were present in some of the samples but it does
not appear to have biased the barium results. The barium spike data were within
DQO limits for a matrix spike run on sample MQO453'although the sulfate
concentration was 1250 mg/L
Aluminum, barium, calcium, chromium, cobalt, copper, iron, magnesium,
manganese, nickel, potassium, silver, sodium, and vanadium data, with exceptions
-------
r - ^
noted below, should be considered quantitative. Data for chromium in sample
MQO499 and calcium and zinc in MQO452 should be considered semi-quantitative
Manganese in samples MQO449, 450, 452, 453, 454, 455, 456. 459, 460, 493, 494. 496
497, and 498 and chromium in samples MQO449, 450, 452, 454. 455, 456 459. 460.
493, 494, 496, 497, and 498 should be considered qualitative.
1 5
One of three matrix spikes was outside DQO for mercury. The mercury results
should be considered quantitative.
2,0 Inorganic and Indicator Parameters
2 l Performance Evaluation Standard
No inorganic or indicator parameter PE samples were analyzed for this facilits
2.2 Inorganic and Indicator Parameter OC Evaluation
For the inorganics and indicator parameters, the average percent recoveries
were within the accuracy DQO's for all parameters. This indicates good recoveries
of these analytes. Accuracy DQO's have not been established for bromide and
nitrite. Three individual sample recoveries were outside the accuracy DQO (sulfate
in sample MQO460 and cyanide and POX in sample MQO459). All LCS recoveries
reported for inorganic and indicator parameters were within Program DQO's,
Average RPD's for all parameters were within Program DQO's, Precision DQO's
have not been established for bromide and nitrite
Analyses for all parameters were performed on all samples, including the
bromide and nitrite analyses which were added by a contract modification, No
laboratory blank contamination was reported for any inorganic or indicator
parameter. Contamination in field blanks is reported in Appendix 1, Table Al-1 of
Reference 3 and involves low levels of one or more of: sulfate, total phenols, TOX,
and/or POX. All reported detection limits are CRDL or lower except for total
phenols in sample MQO496 (DL two times CRDL) and nitrate nitrogen in samples
MQO454 and 49' (DL 17 and 167 times CRDL, respectively) CRDL's ha%e p.cr •-s-
been established for bromide and nitrite,
2 3 Inorganic and Indicator Parameter Data
Four of five field, equipment, and trip blanks were used for spikes or
duplicates for one or more inorganics and indicator parameters. The traffic reports
shipped with the samples to the laboratories were supposed to indicate which
samples were blanks but did not do so on the inorganics traffic reports
The ion chromatography (1C) spectra look clean and are acceptable The
laborator> has some problems with change over to new equipment which has lead t:~
confusion about analysis dates. It was not possible to verify whether the quality
control (QC) parameters for the 1C analysis for nitrate nitrogen, chloride, sulfate,
bromide, and nitrite were run in conjunction with the samples as required. The
laboratory claims that they were but the analyses dates were not recorded due to
the equipment change over. Enforcement use of the 1C data is not recommended
although the data is acceptable.
It is unclear whether the laboratory calibrated their instrument prior to the
cyanide analysis as required It is possible that a recommended holding time of 48
-------
C-6
hours for unpreserved nitrate nitrogen samples was exceeded as the holding time
prior to this analysis was 23 days. The sulfate spike recovery for sample MQO460
was outside the DQO,
Samples MQO496, 497, and 498 were triplicate samples from the same well
The sulfate and chloride results from sample M.Q0497 are much higher (by factors
of 10 and 35, respectively) although all the other data agrees with the d'ta from
the other two triplicate samples. TOX results for sample MQO496 wer^ substantial^
higher than those for the other two triplicate samples indicating poor precision for
the method.
The laboratory should run their TOC calibration verification- standard and blariK
every 10 samples as well as at the beginning and end, of the series of analyses.
This is not being done. No TOC instrument calibration data were reported on the
raw data. The laboratory should perform daily calibrations before each analysis.
No POC initial calibration verifications or continuing calibration verifications
were analyzed to verify the calibration. The POC holding times were 12 to 14 days ^
The recommended holding time is seven days,
TOX data for samples containing chloride concentrations greater than 500 Tig L ,
should not be used due to interferences from the chloride. Samples containing high '
chloride concentrations include MQO453 and 497,
»
Two of three RPD's for POX were slightly above DQO although the average |
RPD was within DQO. Holding times for POX ranged from one to 14 days with a
recommended holding time of seven days. No continuing calibration verification or
continuing calibration blank was run at the end of the POX analyses run, as I
recommended. This affects samples MQO496, 497, 498, and 499,
Recommended holding time for unpreserved nitrite samples is 48 hours, I
Holding times for the nitrite analysis was approximately 23 days.
The inorganic and indicator parameter data should be considered acceptable j
and quantitative for ammonia nitrogen, total phenols, TOX (with two high chlor-.de i
exceptions), and bromide The data should be considered acceptable and scmi-
quantitativc for cyanide, nitrate nitrogen, sulfate, TOC, POX, and nitrite. As
previously mentioned the nitrate nitrogen, chloride, sulfate, bromide, and nitrite 1C I
data lacks verification that QC was performed on the same dates. POX data
correlates well with the sum of the individual chlorinated volatiles found in the
samples. The POC data should be considered unreliable due to the lack of any
verifications.
3,0 Organic? and Pesticides
3.1 Performance Evaluation Standard
No organic PE samples were analyzed for this facility,
3.2 Organic OC Evaluation
All average percent recoveries for organic parameters were within Program
DQO for accuracy and for precision (DQO's for 2,4-D, 2,4,5-T, the dioxins, and
various surrogates have not yet been established) for matrix and surrogate spikes.
Two samples had acid surrogate recoveries below DQO for phenol and 2-
fluorophenol (samples QO495, 495RE, 499, and 499RE) and for 2,4,6-tribromophenol
-------
(sample Q0495RE) No average RPD or surrogate spike RPD, for any compound ua-
outside Program DQO
One laboratory blank (CC8604PC03) associated with samples QO495, 496, 49"
498, and 499 contained acetone at 10,2 ug-L (the acetone CRDL is 10 ug LI. \\i
other blanks either contained no detectable contamination or acetone at
concentrations below. CRDL and ranging from 3 8 to 9,8 ug, L,
All organic analyses were performed as requested. All detection limits were
CRDL or lower except for the following, Nine samples (QO4S3, 454, 457, 493, 495,
496, 497, 498, and 499) required dilutions of the volatiles fraction resulting in DL's
of 1,5 to 500 times CRDL, For all semivolatile samples the DL's are two times
CRDL except for di-n-butylphthalate in samples QO460 and 494 and bis(2-
cthylhcxyl)phthalate in sample QO499 where the reported DL's are CRDL, Dioxm
analyses were performed on all of the samples in this case. The percent recovers
for dioxin spikes ranged from 89 to 109 percent but no dioxms were found in any
samples. No contamination was reported in any of the dioxin blanks. Overall, the
QC data are acceptable.
3.3 Voiatiies
Quality control data indicate that volatile organics were run acceptably. The
chromatograms appear acceptable. The spikes and surrogates are acceptable.
Acetone was detected in four blanks at concentrations ranging from 3 8 to 10,2 ug L
(CRDL equals 10,0 ug/L for acetone). This raises questions about acetone
contamination and makes low level positive results for acetone unreliable As
mentioned above, dilutions were required on nine samples containing high levels of
1,1,1-trichloroethanc and trichloroethenc. These dilutions resulted in elevated
detection limits and the possibility of false negatives for these samples. Samples
involved and the new detection limits are: QO453 (DL 2.5 times CRDL), QO499
H 14), QO495 (10), Q0454 (40), QO493 (50), QO498 (100), Q0496 and 497 (143), and
QO45r(500),
The volatiles data are acceptable. Data for compounds present at
concentrations near the DL should be considered semi-quantitative while data for
compounds present at higher concentrations should be considered quantitame T~;
probability of false negative results is significant in the above mentioned samples
with elevated detection limits.
3,4 Base/Neutrals and Acids
Matrix spike results for both the base/neutral and acid fraction are acceptacle
Base/neutral fraction surrogates are also acceptable. Acid fraction surrogates,
including phenol-D5, 2-fluorophenol, and 2,4,6-tribromophenol, in samples QO4Q5
495RE, 499, and 499RE had recoveries ranging from zero to seven percent. The
semivolatile blank was slightly below DQO for 2-fluorobiphenyl recovery. The
chromatographic quaht> for the senmolatiles is acceptable.
No semivolatiles were positively identified in the samples from this facihts
Overall, the semivolatile data are acceptable and should be considered semi-
quantitative for the base/neutral fraction and suspect but usable for the acid
fraction (due to predictably low recoveries on phenols). Estimated detection limits
were twice CRDL on the semivolatiles.
-------
C-8
3 5 Tentatively Identified Compounds
Several tentatively identified compounds (TIC) were reported at high
concentrations. While there is little doubt that non-HSL organics are present in
these samples, the confidence in the identification of the actual chemicals is m
question and needs to be cla*ified by the data users.
3,6 Pesticides and Herbicides
There were few obvious laboratory analytical problems with the pesticides or
herbicides. Average recoveries are excellent with relative standard deviations of
about ten percent. The chromatographic quality for both pesticides and herbicides
look generally clean and acceptable. Dilutions/concentrations appear to be properly
performed. The duplicate precision and the average percent recovery for the matrix
spike compounds are acceptable.
No pesticides or herbicides (other than spikes) were found in any of the
samples. The pesticides data should be considered qualitative and usable with an
acceptable probability of false negatives. The herbicides data quality should be
considered qualitative with an acceptable probability of false negatives. The
achieved method detection limit is CRDL for both the pesticides and herbicides.
3,7 Dioxins and Dibenzofurans
Recoveries of dioxin spikes by the organics laboratory appear to be nearly
quantitative (89 to 109 percent). Response factors for several dioxin spike
compounds were outside CLP (but not Method 8280) criteria. Problems with
chromatography are suspected due to split peaks for the octachlorodibenzo-p-dioiin
spike compound.
Based upon past PE samples, a significant problem, possibly adsorption of the
dioxins and dibenzofurans to the walls of the sample bottle, is probably affecting
(diminishing) the concentration of the dioxins, if any dioxins are present, in the
field samples. Although no dioxins were detected in the field samples, the
probability of false negatives is not acceptable. Based upon data from past
facilities, the detection limits for the dioxins in field samples should be considered
to be approximately 500 ppt and it is probable that no dioxins were present above
this level in the samples from this facility. The dioxins data should be considered
unreliable.
-------
C-9
III. References
1 Organic Analyses CompuChem Laboratories, Inc
PO Box 12652
3308 Chapel Hill/Nelson Highv-a>
Research Triangle Park, NC 2"'09
(919) 549-8263
inorganic and Indicator Analyses'
Centec Laboratories
P.O. Box 956
2160 Industrial Dnve
Salem, VA 24153
P03) 387-3995
2, Hazardous Waste Ground-Water Task Force Laboratory Data Quality Control
Evaluation Report for Uniform Tubes, Inc., Collegeville, Pennsylvania, 7/31(actuall>
July 23rd)/1986, Prepared by Life Systems, Inc., Contract No. 68-01-7037, Work
Assignment No. 549, Contact: Timothy E, Tyburski, Prepared for US EPA, Office of
Waste Programs Enforcement, Washington, DC,
3." Revised Draft Inorganic Data Usability Audit Report and Draft Organic Data
Usability Report, for Site *16, Uniform Tubes, Prepared by Laboratory Performar.ee
Monitoring Group, Lockheed Engineering and Management Services Co., Las Vegas,
Nevada, for US EPA, EMSL /Las Vegas, 7/23/1986 and 7,22/1986,
-------
C-10
c —.
u
4>
4>
cr:
0
f;
4i
4>
cr
C
OJ
>.,
TO
C
)n Technique
—
ro
•O
0.
0)
Parameter
o o
^ TD ^ "O "O LO CD
O O O C O *— CXf
X X X X X ^0 0
CL a. a. CL a. +•> *•>
— 1 — J _J — * — 1 41 QJ
c c c
o o o
-*-J -tJ J-J
u w u
4* OJ QJ
*J *J *-J
a> a- a>
0 0 O
L.
0 c 4* 01
0 V. k.
>> S-.'*"" >«> S 3 3^
Q. Q. +•» O. *•* *J O.
o o "o o a, a. o
o o c c o
i_ S- O L. C C U,
<_» *_* «- *J 0 0 *J
o. o. E Q. o u a.
X X *» X £ £ X
0.0,0.0.0.0.0.
TO TO TO TO TO TO TO
O O O O O O O
E E E E E E E
O O O O O Q O
rC TO TO 'C TO TO TO
» extraction
>/hexane extraction
ictlon/methylatlon
"/hexane extraction
~O "O fc. T3
O l_ 1- *. U
k. <-> JC JC L- ,C
•*-• O> O U QJ U
c e *•- e c at c
a « ,•—
*J U. U. .«_• j-> 4- -J
wi 3 •*- a> c> -^ oj
c o_ o x X a X
o
CJ
u
c
TO t/>
rj. >s> a: c
t_ a ;_' 'c
0 — CL L.
^~ -^ -a 3
u "t-1 vi u" c *-
^- ^ TO 4) O «3 O
•^ 41 •— *O 13 Ni
f~ f— C •*" **- ^ C
(_; — > u O C QJ
4 — > \ — — •*- d
o. re ••— jj .0 K —
i/l i— E ^ i- O C3
O 4" (U 41 •*-
> t/> Q. Z O
0 0
4- 4>
2: x
a. a.
Q.
0
U >•,
o o
^J 'J-.
u 0
a; t.
Q,*J
c a.
Absorpt i(
sorption *
*-> ^
E
«3T E
0
E
QJ
UJ
L.
4>
£
4^
O
— j-^ a.
o o c
(Sj iT) OJ
CJ
o o a.
£ JT u
a-
a*
I
eatstone t
$
4-> 41 .*->
E 0 E
C — 0
4> *•» O.
— CO/
F ield Measurements
Conductance None
pH None
Turb idlty None
CO O
1 CNJ
«J" O
O T3
.C
a. Of
GJ w
E *J
O 4J
'3 o
o , Microcc
Microcou
w T)
O vn
E =
u E
O
73 TO
C
-i-
o.
t. o
E
TO C
U O
t a, J2
Q. C W
O «
*-• X O
c
TO
CT
I-'
4'
a
c
c>
Z X X
o o
a. H-
a/ «
c u^
«*- -o
4) O
O 41
Infrared f<
red f
Q. >
d, Non-dl5
n-dlspers
i/i
JD O*
E —
u *^
4- 3
cno,
4J
w
o.
c
i>
c, -c
c •*•
o u
Z <
t_J O
o o.
Q. Z
General Const ituents
LO O O
—» o. a.
OJ _J 1
rnatant ^
C
C
a.
« ti
o « a
ent iometrj
y of supei
y of super
0 CL Q.
2 g1?
u E E
OJ O O
^< X *J
0,' OJ HJ
sss
333
ro « TO
a. a. a.
3J
fD QJ -C
«- -a -^
c ••- i_
o E 0
£ u jc
^ !t
U 4) I
0 — il
oca
O f)
a/ c n
c e u
— < a
O 1 U
•, i!
— i_ n
it
n
u
n
ii
u
c ti
O M
— — n
TO - ii
»— (/i a
t/> M
•o o> •
*-> K
^- TO rt
(0 3 R
X < B
11
R
n
D
u
n
QJ ti
-O >— rl
T~ C 11
ecu
TO 41 a
>vXi n
tj a. a
0
S
G
O
UJ
vO 41
^r *j
CO
"O
T: 4-
C *-' 1-
a. 3 *
-o "^
u. *- O
i-.i O
a) Contrart i ^hor^tory P^
bj Test Methods for Evalu
cl Methods for Chemical A
-------
et o
o
— 2:
QC O^
Of O
cr
— r
oc o
o-
*— 3:
F— >
« Qj
C Cr
at Q.
w w
o o
O ^-
c u c i c. i- d *- c c.
C-- — — o, CC CC-'C^T'C
C,CV£ -W-— ^ ^- ^- t- —
£ I -ICUU >~E^W
^j —i —.. — c — 4-> O'OC.QJtU
CJ ,-^J
c: O
o 3:
a.
E
• o o • c o c c; c
c -c
c -c
' O C O O O
<
*-L.*J^CJ= C*JX
a>oai^>OJ-^> QJ Ji a
•— u c ^ cc
T) c -"
G. — o
-c c
C •*- —
C E J
t-0
a; a; i ^ c? o
t- i •- — C > >
«T XT T5 .C »J
-------
-------
C-12
Table C-3
LIMITS OF QUANT:~ATION FOR QRGAMC COMPOUNDS
UNIFORM *UBES, INC
Col'egevilie, Pennsylvania
I 'Ift Of
Quantisation
(wg/U
Vo'atile Compounds (.Purge & Trap)
Bromomethan*
C^ i croniethane
Bromodicnloromethane
Oibrowochloroawthane
Bromofom
Chloroform
CarDon tetrachloride
Carbon disuKide
Chloroethane
1.1-Oichloroethene
l,2-01chloroethane
1,1,1-Trichloroethane
1,1,2-TricMoroetnane
1,1,2,2-Tetracnloroetnane
1,1-OicMoroethant
trans-l,2-Qichioroeth«ne
Trichloroethene
Tetrachloroethene
Methylene chloride
Vinyl ch'c-ide
1.2-Qichlorooropane
ci$-i,3-Dichloraprapene
trans-l,3-DicMoropropene
Chlorobenzene
Ethylbenzene
Toluene
V enes
Acetone
2-Bjtanone
C'-exa^cne
4-Metny!-2-pentanone
2-Chloro«thy' vinyl ether
Styene
vnyl acetate o
Crotons'dehyae °
1.2-Dibromo-3-cMoroprooane
1 1,1,2-Tetracnloroetnane
i^-O^romoetnane
1 2 , 3*Tnch'oroD>"ODane
i,4-Oicriloro-2-butene
Tr! cnloro? ^uorometnaoe
Acro'ein
Acryloni tn le
Volatile Compounds (DAI)
Acrylomtrile
1,4-Oioxane
AHyi a iconol
Ethyl cyanide
isobutyl alcohol
Acrolein
Methyl Methacrylate
10
10
5
5
5
5
5
5
10
5
5
5
5
5
5
5
5
5
10
10
5
5
5
5
5
5
5
5
10
10
1C
10
10
5
10
50
20
20
5
5
20
5
50
50
50
100
50
100
100
25
100
100
50
Setm -Vo' at! le Compounds
Aniline 20
4-CMoroan:' >nj 20
2-Nitroani 1 me 100
3-Nitroaniline 100
4-Nitroaniline 100
Benndme 100
3,3' -D'Chlorobenzidme 40
Benzyl alcohoi 20
Benzyl chloride 40
1,2-Oichlorobenzene 20
1.3-Oicnloroberuene 20
1,4-Oichlorobenzene 20
1.2 l-T^c^orcbenzene 20
1,2,4,5-Tetracniorobenzene 40
1,2,3,4-Tetracnlorobenzene 40
Pentachlorobenzen* 40
Hexachlorobenzene 20
Pentacn'oromtroDenzene 40
Nitrooenzene 20
2,4-Oinitrotoluene 20
2,5-Dinitrotoluene 20
N-Nitrosodimetny.amine 20
N-Nitro5odipnenyla«ine* 20
N-Nitrosoaipropyiamine 20
bis(2-Chloroethyl) ether 20
4-Chloropnenyl pnenyl ether 20
4-Bromophenyl phenyl ether 20
31 s(2-^'o'-oisopropy1) etner 20
Disi2-Chloroethoxy) methane 20
Hexachloroethane 20
Mexachlorobutadiene 20
Hexacnlorocyclopentadiene 20
bis(2-Ethylhexyl) phthalite 20
Butyl benzyl phtha^te 20
d'-n-Sutylpnthalate 20
di-n-Octylphthalate 20
Oietnylphthalate 20
D-metny'pnthalate 2C
Acenap'htnene 20
Acenaphthylene 20
Anthracene 2C
Benzo(a)anthracene 20
Benzo(fc)fluoranthene and/or
Ben:o(k)fluoranthene 20
Benzo(g,h ilperylene 20
Benzo(a)pyrene 20
Chrysene 20
Oibenzo(a,h)anthracene 20
Dibenzofuran 20
Fluoranthene 20
Fluorene 20
Indeno(l,2,3-c,d)pyrene 20
laOpncrcne 20
Naphthalene 20
2-Chloronaphthalene 20
2-Methy!naphthalene 20
Phenanthrene 20
Pyrene 20
5-Nitro-o-toluidine 40
Semi-Volatile Compounas (cent
N-mtrosodiethylamine
Acetopnenone
N-ni trosodipiperidme
Safrole
1,4-Napthoqumone
2,3 ,4,6-Tetrachlorophenol
2-Napthylanine
Pyridine
Pentachloroethene
1,3,5-trinitrobenzene
Ethylmethacrylate
o-Toluidine hydrochloride
2 ,5-D1 ch'oroohenoi
p-Dimethy laffiinoazobenzene
1,2,3-Tnchlorobenzene
1,3,5-Trichlorobenzene
l,2,3,5-Tetrachloroben:ene
Ethyl-methanesul fonate
aipna. aipna-
Dimetnylphenethyldinine
Methapyi lene
7,12-Dimetnylbeniantnracene
Benzsl chloride
Z'nophos
<-Aninobiphenyl
Tetraethyldithiopyro-
phosphate
3,3 -Oimethylbenzidiie
Pronaroi ae
Chlorobenzilate
0-henyened-a^^e
it-?henyieneaiamme
-
Isosafrole
N-Ni trosopyrro 1 'di ne
Aramite
Diallate
Benzotnchlonae
Ni trosmethylethy lam'ie
N-N'trsso-di-N-butyiamine
Cyclophosphaaioe
Hexachloroprapene
Phenacetin
Re so re 'no!
Oimethoate
4,4 Methy '618-01 s
(2-chloroaniline)
Paraldehyde
Methyl metnane sulfonate
N-nitrosonorpholine
1-Naphthylamine
1 ,2-Di pheny 1riyc"a:lne
Benzoic acid
Phenol
2-Chlorophenol
2,4-rjichlorophenol
2,4,5-Trichlorophenol and/or
2,4,6-Trichloropneno
20
10
40
40
40
40
40
40
40
1C
40
40
40
10
40
40
40
4C
4C
4C
4Q
40
4C
4C
4C
"-'.
4C
4C
4f
4C
4C
40
',60
40
let
40
40
40
40
40
*C
40
40
20
20
20
-------
C-l
Tab!e C-3 (com
Seir - vo ! at • ' e Compounds (
PeitacMorop^enol
4~Cn^oro- j-irie t*i) t pfveno f
2 ~Metny i pnenc'
4-Ketny 'phenc :
2 ,4-Cimethy tpheno '
4 , 6-C'initro-2-melny • pheno
2-Ni tropnenc I
4-Nitroph?no'
2 4-Diiifopheno!
nut o'
Quant' tat ' on
(pg/ i.;
con '
100
20
C J
2
-------
C-14
z e^
>— a-.
o
,
I V
*- o
QJ
«
5»
tJ "C ^ -J U U 4J
i^> «!T
>—• — • ^o VO "^ <-^ — « r— csi ^o "-"O >-• t^j 5— «
^-v^nv^nv vr=oV ^-»vvO
V oj f* fsj •— '
^ ^-«
O f^. O O LD O O
O W ** (SJ r*"i ""• O
CTS co v *r
O 3
^- o- •—
O ^D
O CS(
*» i- O
(TJ E O,
w "•"
*j ^- O-
« W C ••—
* o -c
0; c u c
3 a; -—
i— > C
OCO —"
a w
o
—• o-
CO O f-» tSJ
OrflOO 10^*^
u E
£ C ^
c? a. %-
u. Q. u a,1
*L
-------
— ~- CO
*T O CC
.
O — u
, !_> C "^
^ C T3
a- c *- c
z: G- *-
-- > c
E *J c
« c o *o
W « C
w1 W C
— QJ >^-<-
S. C. "
T- (^ > 4-
-------
C-16
00 — ^-
O O
O O
CC O
O O O O S3 O CSJ
tO CC LT ^ O CSJ —•
-M ^ ^
••- o >—
= EZ
(—3 LJ LJ (J
E E O- 0- =
£ E (
01
°
1J
X X
O O
a. i—
O O
O CL
a. z
i- 1_ ^ •^ fC -— O
E O fc- V, i*- C C
o ^- *j *j »— «o a>
W £ *- -^ '3 >s£
ec t_) z z co
-------
C-17
o.
E
LO O
fs^ (J-l
f-t (SJ
O O O I
EEC?
(^ C
=> -•-
•o ,0
-------
« * APPENDIX D .:,,
UTI MONITORING DATA FOR JULY AND SEPTEMBER 1985
r
-------
r^
y
5
*
i
ffl ^
fc" * '
U w* IB ^
25 2»
*C M &
o« JM u
LJ Z fl -*•
i£ z 13 — (N
ig y> i
fc -11 * s
c, £«; o c £
05 -5 0 >-
g ~ U Oi
^ f* ' —
s 2 *.£ 7
K 0 *j x
* -^ * 3
• ^. c
S^E
P . c °
>-, v; x -
r»
. in
l£ O
W
r-' o
r-' o
in
CD
r-' o
o
V v V
0
1
0
0
o
o
o
o
o
in
8
o
o
o
o
^ ^
t 9
O4 F^ Z
*o
r- r»
m « g
r<<
fN 0 O
^«
f-4 V
^^ 90 ^^
>n IN
^ 0
^^ ^o< 2
^* P
c
c
'.
^
i.
u
i
ft
u •
in
rs — •
i \ E
W W 2S ^^
c
,-v
x
*u
K
""
U
'c
5.
E"
o
E
—
f,
&
^.
5
o
"c
£
O
IB
—
i
"5
"i
c
o
^
c
Col on i
—
s
C
„
^.
-
%
w
f
g
p
«v
S c - f
8 ^5-
-------
a,
S S S 2£ 3S2SSS3S
J —•_ O
8.
«
i
i)
25
o
r-
m
0>
x
i
•J
-J £
< F a ?
§ I ^ =
2
i
P X S
X M -,
o 2 i-
2. M <
SSSS2SS9SSSSSSS
Ul
"i IN o o in o o c10 o o
.15 ^ ^4 — -« rs -« in
OOU^CO
* -
s §
tn
m
I 1 5
3 - ;
jj | S
A r, *
§
I
~ 41
S £ fc.
-------
in
x
£
5
i
cc
„
1
h
>;
*
S
*•*
Z
^
5
g
2
M
S
ENNSYLN&NIA
7/12/85 7/17/85 7/1 2/
RGRA-3 RCRA-4 UTH-3
o. m
00 (S
X. !
% ~ - p
"" "•*• r» £
i s
g .S
§~ IB in
AJ 00 ^
3 x i
c ™ *S
C h
2 § 2 § S S
2 2 2 | 2 2
S!N Q O
»
>*»
0 O
r* o
*.
1
k.
f
I
I
w
T
cr
|
r
o o
o o o o o o
- — — — — o
oooooocc
ooooococ
c c
o c
fi 3
i
•»
J
4J
s^
I
s
l_
3
8.
>w
Chloroform
i
1,1 Dichloroetl
1
1,2 Dlchloroetl
u
X
i
c.
>.
1,1 Dlchloroetl
-s
««^
u
0
*-4
6
1
1
^
x
Tet rachloroeth
i
u
0
_u
Q
a
I
(N
••«
u
ethylene (t-DC
oetFvsnp
1,1,1 Trlchlor
i
Trichloroethyl
Vinyl chloride
Acetone
Chi or owe thane
ilor ide
2-But»none
Carbon Tetracti
Toluene
K^r^n '•^^JTWl
I &
2 5
-------
in
OD o
'
in
CO (N
X I
S z
Z Z
SU*>
^
(M
in
a -i
x i
i i
w
jj
J
OOO OOC5CCO
c o o o
5 ^ ^. -.
.5
83
?l
0!
*
O
A
5 5 5
t-i H $ "O
i 2 I a,s
-------
in
CD
oc
(S
2 i 8
o o
o -«
•M V
v
w
ft)
/17/85
CRA-4
•D »n
S S S
S
in
So o
O -H
»-l V
V
q.f
?? . ^
in
ac >-•
"V i
S S i
00
in
9 (N
si
O *- - <5
^- r*t eN r<(
i i
.5
I-
C ^
e u
ff i c
e T +
~* ** j
0.^ S
1
6
pha
ta
28
a5
li-
£ c u 2
-------
D-6
in
00
X.1
C^ M ^
* * I
p 1*1 P* g
4-T-H^ Z
•4 in !-'
fifiUfi
ao (N
in *+
oo i
J
o <-.
. . 0 _
>-« IM *a
01 $
i is
i
•I
£2
«|.oo
I (N Q, JjJ (N
e •« *j 7 < oa 7
= M i §.. i
*"* I =3 P 53
• c M « 4
£ £ 3 <3 2
r.:i
—•«»—.
1 e ef
K O O «
(N
legal leǤ
^
la
3 -
^
31
s= :
«
£
«8
-------
i
1
r*
i
2
in
4
«
i
^|
.2 i
i
=! ;
i: i
— >
0 t
— *
t! i
is
*i -
rr
^
1 7
c K
I
*N
1
1
I
•
\ 9* r* +* m m **
I V V V
1
'S P* P* O » «
IV V V P« * #*
,
'
e o O e » *•»
V V V V
p- f*t i* o o r*
»> v v n* O v
IN « *N -• «* in
V V V ^ ^^
*N fN — Q O *
V V «- * *
e — *r o e ^i
""*'*;£ S ^
< v S 2 g 7
*>* « >*
X 0 2 | | ?
— ^
O K v* O O *V
ff> fr C C v
•w V
^ ^* c o o r*
+ r* <* ^ e v
>*•• • r*>
fN
C c w e c o
1 ^ a 1 1 "•
a *
gu^ o o e ***
c « o S v
IN C
?
» C
g 1
: | ,
J i i I
^ - s 1 6
t i f 5 i
IIs I 1
M!!h
T L. A
«T<***C^ OOC
v — * v
«• «•, O i/"> rf^
*n r- e e * o c c
v **« jr v v v v
—» « O w" tf^
^ « p» e ^- o c o
V f*t — V V V V
« j*. C ^ ir
*r — tn O *i C?v
v r* ** v
r*
« • *"!'*.
• • e • e
w* e » e *• v ^.v v
v ^ - V « W
t^ p. ""—
- r 5 2, s
m ** « o « e e o
v rx ** v
fX
H * ?S ^ &
w »r *N © w- o C o
fN O — V V
— IT
«- f* O ^ ^
— f* V V V
«
«. m S »r ir
»r r- « d P* e © e
» f*. v V V V
M •*> O W^ U*
<"* */•< ^ e ?^ o o e
CN ^ V V V V
vT
— » 0 *T> W"
o w° o o *r o e e
" S g v v
^ •» i— ^r ^
o o © o ^ — ' c e
<-?*&• ^ v
— c
C C
fS —
— m C — IT
^ r- * o r-.' e c e
^ ^ ^ v v
_
«
! H 1
!; ii i
- ; . i i : i i
|.5»tii-i IT
F • -. i 1 ; 5 i ? !
6
JT
C
C
x
]
•
1
v
**>
o
1
t
!
0
1
^
£
1
*
N.
i
r
1
x ^
li
ffi
"S2
Jcc
?: .
»» - v>r"lr rtmfcM
M - r*+-r1 Inn UxM
I . nr4i«rllon l.lmll
a-
X!
Q.
CJ
•c
c
c.
E
*l, -• i _- - f £
V 1
-------
|