March 1987                  EPA 700/8 - 87 - 006

Hazardous Waste Ground-Water
Task Force
Evaluation of
E.I. DuPont DeNemour and Company
Deepwater, New Jersey
      UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
   NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION

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   j     UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                REGION I I
                             26 FEDERAL PLAZA
                         NEW YORK NEW YORK  1O278
 March  1987

 Update  of the  Hazardous Waste Ground-Water Task Force evaluation of E.I.
 DuPont  DeNemour and  Company  Inc., Deepwater, New Jersey.

 The  United  States  Environmental Protection Agency's Hazardous Waste
 Ground-Water Task  Force and  the New Jersey Department of  Environmental
 Protection  conducted  an evaluation of the compliance of E.I. DuPont
 Nemours and Company  Inc. with the interim status and ground-water monitoring
 requirements of the  Resource Conservation and Recovery Act  (RCRA)  as
'adopted by  New Jersey.  The  Task Force effort came  about  in light of
 concerns over  the  extent to  which operators of, hazardous  waste
 land disposal  facilities are complying with applicable ground-water
 monitoring  regulations.  The on-site  inspection was conducted over a two-
 week period from March 31, 1986 to April 11, 1986.  DuPont  is one of 58
 facilities  that are  to be evaluated by the Task Force.

 The  purpose of the Task Force evaluation is to determine  the adequacy of
 ground-water monitoring programs at land disposal facilities in regard to
 applicable  State and  Federal ground-water monitoring requirements.  The
 evaluation  focused on (1) determining if the facility was  in compliance
 with applicable regulatory requirements and policy  (2} determining if
 hazardous constituents were  present in the ground water (3) providing
 information to assist EPA in determining if the facility  meets the EPA
 requirements for facilities  receiving waste from responsp  actions conducted
 under the Federal  CERCLA Program.

 The  site evaluation  conducted in March - April 1986 has revealed violations
 of RCRA and New Jersey Hazardous Waste regulations.  In summary, these
 include, inadequate  programs to meet  compliance with RCRA  and New Jersey
 groundwater monitoring regulations.   Inadequacies in Duponts interim
 status  ground-water  sampling and monitoring procedures, deficiencies in
 both on-site and off-site analytical  laboratories, and violations of
 current waste  management practices and records maintained  at Dupont.

 Based on the Task  Force Report and findings the following  actions will be
 required by Dupont:

     1.  All zones of the uppermost aquifer (Glacial aquifer zones and
         Potomac-Raritan-Magothy aquifer zones) will be monitored by
         background  and downgradient wells place accurately for all
         hydrologic conditions;

     2.  Better define the rate and extent of migration of hazardous waste and
         hazardous waste constituents in the Glacial aquifer and Potomac-
         Raritan-Mogathy aquifer system;


     3.  Obtain  porosity, permeability  hydraulic conductivity, transmis.-
         sivity, storage coefficient, specific capacity, and transient
         ground-water flow gradients in the Glacial  aquifer and the
         Potamic-Raritan-Magothy aquifer system, both vertically and
         hori zontally;

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     4.  Develop ground-water flow nets  and  hydrogeol ogi c  cross-sections
         to illustrate the relationships between  the  aquifers  and  the
         effects of the unlined RCRA units  and  surface  water  at  the  site;

     5.  Better define the centers of pumping and the  areas  of influence  of
         the cones of depression;

     6.  Develop an assessment monitoring program for  Chemical  Waste "C"
         Landfill  and revise the existing assessment  program  for the Waste
         Water Basins/Ditch system.   An  assessment monitoring  program
         plan has  been submitted to  the  State for area  I  o"'  the  Chemical  Waste
         "C" Landfill.  This plan  is currently  under  review;
     7.  Revise current ground-water sampling and  monitoring  plan  to
         address the deficient procedures,  methods and  quality  Analysis/
         quality control  programs as outline 1n the Task  Force
         Report; and

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


A current Draft Administrative Order prepared by  the State  of New  Jersey
incorporates the deficiencies found in  the  Ground-Water Sampling and
Analysis plan, (item 7),  and violations pertaining to Waste Management
Practices and Recordkeepi ng (item 8).   After the  Task Force inspection,  DuPont
began drilling new monitoring wells along the western periphery of the  site.
Seven 4-inch monitor wells were drilled along with twenty-eight 2-inch
observation wells. -Aquifer tests were  performed  to better  define  the
hydrogeol ogi c regime in that region of  the  site.   This  work was performed
in order to address the defiencies outlined by NJDEP in a technical
notice of deficiency (NOD) for the ground-water portion of  the  Part  B
application.  This NOD was issued on December 31,  1985.  NJDEP  is  expecting
a report on these aquifer tests.  In addition, Dupont has submitted  data
in December of 1986 which may address  deficiencies outlined above  (1-6).
This data was submitted in response to  a USEPA Region II  request for
additional information for an exemption from the  Minimum  Technological
Requirements (retrofitting surface impoundments),  under Section 3005(j)(13).
This data is presently under an admi ni stati ve and  technical review.   This  draft
Administrative Order will  be issued final by the  State  requiring E.I.  DuPont  to
address items 7 and 8 and outstanding  deficiencies not  addressed in  these
recent submittals (items  1 through 6).

DuPont submitted closure/post-closure  plans for the "A" and "C" Basins  on
August 15, 1986.  The closure/post-closure  plans  for the  Process Water
D^tch System were submitted on November 3,  1986.   The proposed  closure
plan for the "A" Basin is to stabilize  the  sediment, consolidate the
'stabilized sediments into a smaller area, and use  the remaining area  as  a
settling basin for the Waste Water Treatment Plant's effluent.   The "C"
Basin closure plan involves the removal and recovery of the lead-laden
basin sediments.  Residual contamination will be  removed  to a lead level
agreed upon by NJDEP.  The closure of  the Process  Water Ditch System

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Involves the installation of an overhead transfer system,  collection  and
disposal of the approximately 2000 cubic yards  of dinitrobenzene  and  25
cubic yards of nitronaphthalene contaminated  sediments  from  the ditch
system, and sampling and analysis  to determine  further  removal,
decontamination, and/or disposal  of materials in  the  ditches,  and the
design and implementation of a ground-water monitoring  program.   On
February 20, 1987, NJDEP responded to DuPont's  closure/post-closure plans.
The plans for "A"  Basin need administrative and technical  revisions while
the "C" Basin plans were approved  with additional sampling recommended by
NJDEP.  The Process Water Ditch System plan was approved  for its  phase 1
program.  The phase 1 results will determine  the  next  steps  of the plan.

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ACKNOWLEDGEMENTS

It is a pleasure to acknowledge thp assistance of the following  personnel
who provided information and technical  guidance:   Charles  Anderson,  Fred
Haber. Sandy Hurd, Sharon Jaffess,  Brian Lewis,  Nicholas Magriples,  Ton Moy,
Erwin Rutkowski , Tom Solecki, Jim Tesoriero,  and  Dave Zervas.   Additionally,
we wish to thank the personnel  nf E.I.  Dupont in  assisting us  during thp
period of March 31 - April  11,  19H6.
                                        Rogen W.  Enm s
                                        Project  Coordinator
                                        U.S.  Environmental Protection  Agency
                                        Region II
For Further information  regarding  this  report  please  contact:
          Hazardous  Waste  Compliance  Branch
          U.S.  Environmental  Protection  Agency
          Region  II
          26 Federa1  Plaza
          New York   New  York   10273

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               UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                  HAZARDOUS WASTE GROUND-WATER TASK FORCE
EPA-700/8-87-008
GROUND-WATER MONITORING EVALUATION

E.I. Dupont De Nemours & Co.
Deepwater, New Jersey
March 1987
Roger W. Ennis
Project Coordinator
U.S. Environmental Protection Agency
Region II

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                                  CONTENTS






 I.  EXECUTIVE SUMMARY




       A.  Introduction 	1




            1.  Task Force Objectives 	1




            2.  Participants 	2




       B,  Summary of findings and Conclusions .. •.	3




            1.  Ground-Water Monitoring Program During Interim Status  ...3




            2.  Ground-Water Sampling and Monitoring procedures	5




            3.  Well Sampling Data Analyses	6




            4.  Corrective Action Program	7




            5.  Audit of Laboratories	8




            6.  Comprehensive Evaluation Inspection 	8




II.  TECHNICAL REPORT




      A.   Regulatory Requirements 	9




      B.   Investigative Methods and Procedures 	11




           1.  Records/Documents Review	11




           2.  Comprehensive Evaluation Inspection 	12




           3.  Comprehensive Ground-Water Monitoring Evaluation 	13




           4.  Field Sampling 	13




           5.  Evaluation of On-Site and Off-Site Analytical Labs  	23




      C.   Facility Description and Operation	24




           1.  General Information 	24




           2.  Facility Background	24




      D.   Hydrogeology 	29




            1. Study Area	30




            2. Reg ional Sett ing	31




               a.  Structural Setting	31




               b.  Rock Units	 ...36




               c. Hydrogeologic Setting	36




                                       ii

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   d. The Delaware River Basin..	40

   e. The Coastal Plain	40

   f. The Delaware River and Salt-Water Intrusion	42

   g. The Hydrologic System	42

3.  Chambers Works Setting	45

   a. Quaternary Deposits	45

   b. Cretaceous Deposits	48

4.  The Original Ground-Water Flow Regime	—	50

5.  The Altered Ground-Water Flow Regime.	51

6.  Ground-Water Monitoring Requirements	.63

   a. New Jersey Ground-Water Regulatory History	64

   b. The Resource Conservation and Recovery Act of 1976........65

   c. The New Jersey Department of Environmental Protection and
      the Resouce Conservation and Recovery Act of 1976	65

   d. New Jersey Department of Environmental Protection's
      Responsibilities	66

   e. United States Environmental Protection Agency's
      Responsibilities	66

   f. DuPont's Ground-Water Monitoring Program Prior to the
      Environmental Laws	67

      i .  Overview	67
     ii.  Monitor Wells M-l through M-29	67
    iii.  Discovery of Ground-Water Contamination	67
     iv.  Contamination, Additional Ground-Watei Monitoring and
         Early Remediation Efforts	,	68
      v.  Annual Progress Reports	.,	69
     vi.  The Monitor and Interceptor Well Network	69

   g. DuPont's Ground-Water Monitoring Program's Adaptation to
      NJPDES	73

   h. DuPont's Ground-Water Monitoring Program's Adaptation to
      RCRA			77

      i .  Introduction	77
     ii.  Ground-Water Monitoring Events	..78
                           111

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             (a) The Interim Status Ground-Water Monitoring Program....90
             (b) The Interim Status Ground-Water Monitoring Program's
                 Evolution into the 40 CFR Part 264 Ground-Water
                 Monitoring Program	98

      7. Results and Discussion	104

      8. References	119

E. Ground-Water Sampling and Analysis Plan	122

F. DuPont's Ground-Water Sampling Activities	125

G. Audit of Laboratories	127

      1. DuPont Laboratory	127

      2. Environmental Testing and Certification Laboratory	128

H. Task Force Sampling and Monitoring Data Analysis	129

      1. Ground-Water Sample Analyses Results	129

      2. Inorganic and Indicator Type Parameter Results	129

      3. Metals Analyses Results	130

      4. Organic Analyses Results	...131

      5. Leachate and Surface Water Analyses Results	132

      6. Landfill Monitoring Wells	134

      7. Delaware River Wells	135

      8. Potomac-Paritan-Magothy Aquifer System Wells	136

      9. Interior Monitoring Wells	137

      10. Key to Results of Sample Analyses	139


I. Comprehensive Evaluation Inspection	161

      1. Waste Management Units/Observations	161

         a. Pet Chem Container Storage Area	161

         b. Pet Chem Rubble Container Storage	161
                                 IV

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              c.  Chemical Waste  Container  Storage Area....,,	..162




              d .  PPD Waste Container  Storage	 162




              e .  PPD Area Waste  Container  Storage	162




              f.  Telomer  "A"  Container  Storage.	162




              g.  Freon  Spent  Catalyst Container  Storage...	163




              h.  Tank Storage, Chemical Waste  Management Area	163




              i.  Nitrocellulose  Waste Pile	163




              j.  Telomer  "A"  Waste  Treatment Tank	..163




              k.  FR-1 Hazardous  Waste Incinerator		... 163




              1.  Thermal  Treatment	164




              m.  Surface  Impoundments,  "A" Basin	......164




              n.  Surface  Impoundment, "B"  Basin	....165




              o.  Surface  Impoundment, "C"  Basin.	....165




              p.  Landfill "C"	165




              q.  Waste  Water  Treatment  Plant	.167




              r.  White  Products  Area  (A,B,C)	167




              s.  Building 4066	167




              t.  Jackson  Laborator ies	168






           2.  Review and  Evaluation of  Facility  Records	169




              a.  Waste Analyses  Plan	169




              b.  General  Comments of  Closure  Plan/Cost Estimates	169




              c.  Individual Unit Comments	170






III.   APPENDIX




       1. Hazardous Waste Ground-Water  Task Force Sampling Parameters

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                                FIGURES


Number

    1. DuPont Chambers Works Waste Management Units	,.	27

    2. Chambers Works and Carneys Point Works	28

    3. Locality of the Chambers Works Facility	30

    4. Physiographic Provinces of New Jersey	32

    5. Location of the Delaware River Basin	32

    6. The Fall Line	33

    7. The Coastal Plain's Drainage Divide	33

    8. Typical Section through the Coastal Plain  (NW - SE)	34

    9. Stratigraphic Section showing Transgressive/Regressive Cycles	.35

   10. Composite Diagram of the Depositional Environments	36

   11. The Wisconsin Glacial Cycle in New Jersey	37

   12. Major Ground-Water Withdrawals from the Coastal Plain of New Jersey
       by Aquifer, 1956 - 1978	,	41

   13. Outcrop of the Potamic-Raritan-Magothy Aquifer System	43

   14. The Hypothetical Salt Water/Fresh Water Interface and Theoretical
       Flow Pattern in the Potamic-Raritan-Magothy Aquifer  System	44

   15. Coastal Plain and Surficial Geology in Salem County	46

   16. Leggette, Brashears, & Graham, Inc. (LGB)  General Stratigraphic
       Interpretation of the Chambers Works site	47

   17. Generalized Prepumping Potentionetrie Surface of the Potamic-
       Raritan-Magothy Aquifer System (1900)	53

   18. Generalized Potentiometric Surface of the  Potamic-Raritan-Magothy
       Aquifer System for 1956	54

   19. Generalized Potentiometric surface of the  Potamic-Raritan-Magothy
       Aquifer System for 1968	55

   20.  Potentiometric Surface Maps for the Shallow and Deep  Potomac-
        Raritan-Magothy Aquifers at the Chambers  Works	...56

   21.  Potentiometric Surface Maps for the Highest Water  Levels  in
        the Shallow Glacial Zone  (1977 & 1985)	....57
                                        VI

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                                 TABLES
Number
    1. Rationale for Task Force Sampling Locations	.14

    2. Monitoring Well Specifications	16

    3. Physica1  Characteristics of Wells Measured and Sampled by
       The Task Force	17

    4. Outline of Ground-Water Monitoring Activities	...18

    5. Results of Air Monitoring at Ground-Water Monitoring Wells	20

    6. Summary of Analytical Parameters Sampled	 „	22
                                           s
    7. Geologic Units of the Coastal Plain Physiographic Province	38

    8. Hydrogeologic Units of the Coastal Plain Physiographic Province........39

    9. N.J.A.C.  7:14A-6.4(b)l	79

   10. Appendix VIII Constituents found at or in Excess of 10 ppb at the
       Assessment Monitoring Wells	89

   11. Well Construction Specifications for Interim Status Ground-Water
       Monitoring Wells at the Waste Water Basins	95

   12. Well Construction Specifications for Interim Status Ground-Water
       Monitoring Wells at the Waste Water Basins (Assessment)	96

   13. Well Construction Specifications for Interim Status Ground-Water
       Monitoring Wells at the Chemical Waste "Cn Landfill	97

   14. Results of Inorganic Analyses of Ground-Water Samples for
       Shallow Glacial Aquifer Zone Wells	,...140

   15. Results of Indicator Type Analysis for Shallow Glacial
       Aquifer Zone Wells	140

   16. Results; of Inorganic Analyses of Ground-Water Samples for
       Middle and Deep Glacial Aquifer Zone Wells...		....141

   17. Results of Indicator Type Analysis for Middle and Deep
       Glacial Aquifer Zone Wells	141

   18. Results of Inorganic Analyses of Ground-Water Samples for
       Shallow Potomac-Faritan-Magothy Aquifer Zone Wells	142

   19. Results of Indicator Type Analysis for Shallow Potornac-
       Raritan-Magothy Aquifer Zone Wells	..142
                                        VI1

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20.  Results of Metals Analyses of Ground-Water Samples for Shallow
     Glacial Aquifer Zone Wells	143

21.  Results of Metals Analyses of Ground-Water Samples for Middle
     and Deep Glacial  Aquifer Zone Wells	144

22.  Results of Metals Analyses of Ground-Water Samples for Shallow
     Potomac-Raritan-Magothy Aquifer Zone Wells	145

23.  Results of Organic Analyses of Ground-Water Samples for
     Shallow Glacial Aquifer Zone Wells	146

24.  Results of Organic Analyses of Ground-Water Samples for Middle
     and Deep Glacial  Aquifer Wells	148

25.  Results of Organic Analyses of Ground-Water Samples for
     Shallow Potomac-Raritan-Magothy Aquifer Zone Wells	150

2fi.  Results of Inorganic Analyses of Leachate and Surface Waters	152

27.  Results of Other  Sample Analyses of Leachate and Surface
     Waters..	152

28.  Results of Metals, Leachate and Surface Water Samples	153

29.  Results of Organic Analyses of Leachate and Surface Water
     Samp IPS	...-.154

30.  Analytical Field  Measurements Conducted at E.I.  DuPont	155

31.  Tentatively Identified Compounds Requiring Confirmation Using
     Authentic  Standards	156

32.  Occurence  of Hazardous Metal  Constituents in Ground-Water
     Samples from E.I. DuPont	130

33.  Occurence  of Hazardous Organic Constituents in Ground-Water
     Samples from E.I. DuPont	132
                                    VI 1 1

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                            I. Executive Summary


A..  Introduction

The Resource Conservation and Recovery Act (RCRA) , an amendment to the Solid
Waste Disposal Act, was passed in 1976 to address the safe disposal of the
huge volumes of municipal and industrial solid waste generated nationwide.
It has been amended twice since 1976, once in 1980 and roost recently on
November 8, 1984.  This act is currently divided  into nine subtitles.  Sub-
titles C, D, and I lay out the framework for the  three programs that make up
RCRA: the hazardous waste management program, the solid waste program and the
underground storage tank program, respectively.

Subtitle C of the Act establishes a program to manage hazardous waste from
cradle to grave.  Subtitle C regulations set requirements for the generation
(40 CFR Parts 260 through 262), transportation  (40 CFR Part 263) and treatment,
storage or disposal, of hazardous wastes (40 CFR  Parts 264 and 265).  EPA
divided the regulations for treatment, storage, and disposal facilities
(TSDF) into two sets, one for interim status TSDF's and the other for
permitted TSDF's.  The interim status standards are found in 40 CFR Part
265, while the permit standards are found in 40 CFR Part 264.

Section 3006 of Subtitle C of RCRA allows the EPA to authorize State
hazardous waste programs to operate in the State  in lieu of the Federal
Hazardous Waste Program.

The State of New Jersey received final authorization on February 21, 1985.
This covers 40 CFP Parts 260 through 265 for the  base RCRA program, but does
not include new program elements under the Hazardous and Solid Waste Amendments
of 1984 (HSWA).

Recent U.S. Environmental Protection Agency  (EPA) studies reveal that
some hazardous waste facilities may not be complying adequately with certain
Federal and State requirements of this subtitle,  specifically, subpart F,
ground-water monitoring requirements to monitor their sites for evidence
of ground-water contamination.  Those standards consist of:

0 Developement and installation of a monitoring' system;

0 Background monitoring;

0 Routine monitoring and evaluation;

0 Conducting assessments; and

0 Reporting.

As a result of these findings, the Administrator  of the Environmental
Protection Agency  (EPA) established a Hazardous Waste Ground-Water Task
Force  (Task Force).  This Task Force is comprised of personnel  from  the
EPA office of Solid Waste and Emergency Response  (OSWER), Regional
offices and state regulatory agencies.  The  task  force will be conducting
in depth on-site  investigations at land disposal  facilities with the following
objectives:

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

2.  Evaluate the ground water monitoring program described in the  facility  s
    RCRA Part B ppnmit application for compliance with 40 CFR Part 270.14(c)

3.  Determine if the ground water at the facility contains hazardous  waste
    constituents

4.  Provide information to assist the Agency i'n determining if the TSDF
    meets the EPA ground-water monitoring requirements for waste management
    facilities receiving waste from response actions  conducted under  the
    Comprehensive Environmental Response, conpensation and Liability  Act
    (CERCLA), Public Law 91-510)**

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

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

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

0 Designated RCRA and/or State-required monitoring wells  are properly
  located and constructed;

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

° The ground-water quality assessment program outlinp or  plan  as  appropriate
  is adequate.

This report presents findings and conclusions of a Task Force evaluation
of the E.I. Dupont De Nemours & Co. Inc operation in  Deepwater New Jersey
conducted from March 31, thru April 10, 1986.

Task Force Parti cj_pants

The USEPA-II Project Team included Sharon Jaffess, Hydrogeologist/New Jersey Hazardous
Waste Facilities Section, Rogpr Ennis and Thomas Solecki, Environmental Engineers/
New Jersey Hazardous Waste Compliancp Section  and from the Environmental  Services
Division, Nick Magriples, Environmental Engineer, Joseph  Consentino,  Environmental
Scientist, and Fred Haber, Quality Assurance Specialist.   Representing the  State
of New Jersey for the Task Force investigation were Sandra Hurd, Hydrogeologist/Bureat
of Ground-Water Quality Management, David Zervas, Environmental Engineer,  Bureau  of
Case Management,  and Erwin Rutkowski , Environmental Engineer, Southern Region
Enforcement.  Task Force assistance and coordination  were provided by Brian Lewis.
Engineering Geologist, State of California, on assignment to USEPA.   Julianne  Howe,
Richard Roat, David Billo, and Jim Thomas were the contract sampling  team  from G3A.

** EPA policy, stated in a May 6. 1985 memorandum form Jack McGraw on
   "Procedures for Planning and Implementing Off-Site Response", requires
   that TSDF's receiving CERCLA waste be in compliance with applicable RCRA
   groundwater monitoring requirements.

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B. SUMMARY OF FINDINGS AND CONCLUSIONS

The findings and conclusions presented in this summary and report reflect
conditions existing at the E.I. DuPont de Nemours & Company's Chambers Works
facility in April 1986.  Subsequent actions taken by the facility, the State,
and Region II since this investigation are summarized in the accompanying update
memorandum attached to this report.

In summary, the Task Force has determined that:

1.   The interim status ground-water monitoring program is not in compliance
     with some of the ground-water monitoring requirements of the New Jersey
     Administrative Code (equivalent to 40 CFR, Part 265) .

2.   Various technical components of the ground-water monitoring program
     described in the facility's RCRA, Part B application have been found
     deficient with the requirements of 40 CFR, Part 270.14(c), and require
     modification.

3.   The Task Force sampling confirmed that ground water at the facility
     contains elevated levels of hazardous waste constituents above back-
     ground levels.  Such levels were found in the Potomac-Raritan-Hagothy
     aquifer system, which is a source of drinking water.   Further investigation
     is needed to adequately determine the scope and extent of contamination.

4.   Prior to the time of the inspection, the facility was considered to have
     no significant Class I violations, and as a result, was eligible to
     receive waste from clean-up actions under CERCLA.  However, under
     the Super fund Reauthorization Amendments and the Task Force findings,
     the facility is not eligible to receive waste from clean-up actions under
     CERCLA owing to known releases of hazardous waste constituents into
     the environment and non-oompliance with applicable ground-water monitoring
     regulations.  CuPont certified LOIS compliance with the interim status
     ground-water monitoring requirements for two regulated units, the
     Chemical Waste "C" Landfill  (detection monitoring program) and the
     Waste Water Basins/Ditch System  (assessment monitoring program) in
     October, 1985.

5.   At the time of the inspection, the facility was not considered in
     significant non-compliance.  However, after the Task Force inspection,
     a number of violations of the interim status standards were initially
     identified, including deficiencies in current waste management practices
     and deficiencies  in the Ground-Water Sampling and Analysis Plan.

Ground-Water Monitoring During Interim Status

The Task Force has determined that various technical components of the
programs require modification and therefore, the programs do not meet
compliance with RCRA interim status regulations. The basis for  this deter-
mination is outlined below.

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Borings at the Chambers Works facility indicate a complex, sequence of
alluvial and tidal marsh deposits, fluvioglacial deposits, and marine
cyclic deposits.  Tine lithologic information contained in the borehole logs
was very general and the mineralogy, petrography, and geochemistry of the
geologic units are therefore not defined.  Consequently, the effects of
contaminated ground water on the confining properties of the clay and silt
units are uncertain.  In addition, permeability and porosity can only be
estimated resulting in general assumptions about the hydrologic properties
of the geologic units.  Despite this, a general depiction of the subsurface
has been ascertained with aid from the published literature.

Well construction details on well logs do not fully correspond with the
construction details submitted in the original Part B application. , Unknown
and possibly inadequate standards for well design and construction may be
resulting in:  insufficient ground-water flow to the well for sampling, the
passage of formation materials (turbidity)  into the well, and the degradation
of long-term structural integrity required for RCPA monitoring wells.
Drilling and well installation must utilize both a licensed driller and
geologist and complete, detailed "as-built" well diagrams and borehole
logs.  Current borehole drilling and well installations are meeting State
of New Jersey well drilling and construction requirements (N.J.A.C. 7:14A-
6.13) .

TV\e geologic environment gives rise to a complex multi-aquifer system.
The natural ground-water flow regime has been altered as a result of
the regional pumping of the Potomac-Rantan-Magothy system aquifer and the
site-wide pumping of the Glacial aquifer.  Changes in pumping centers alter
flow paths and gradients.  This complex hydrologic system warrants a more
comprehensive ground-water monitoring program than exists at the facility.
The system of RCRA and NJPDES wells at the Chambers Works does not provide
adequate data on every aquifer zone and the interrelationships between
these zones.  Consequently, accurate placement of background (upgradient)
and downgradient wells for all hydrologic conditions was not achieved.  To
achieve such accuracy, the following characteristics must be defined for
the geologic units comprising the shallow, middle, and deep Glacial aquifers,
and the Potomac-Raritan-Magothy aquifer system: porosity, permeability,
hydraulic conductivity, transmisssivity, storage coefficient, specific
capacity, and transient ground-water flow gradients.  A lack of potentiometric
data in aquifer zones both vertically and horizontally at the site underscores
the need for additional piezometers and/or wells.  Using the additional
hydrologic data, ground-water flow nets and hydrogeologic cross-sections
should be constructed to illustrate the relationships between the aquifers
and the effects of the unlined RCRA units and surface water at the site.
In addition, centers of pumping must be defined and the areas of influence
of the cones of depression must be further identified.  Cnly at this point can
accurate detection and assessment monitoring points be verified and/or
established.  All zones of the uppermost aquifer under all hydraulic conditions
must be monitored.  Additional background wells must be installed in these
zones (middle and deep Glacial aquifers and shallow Potomac-Raritan-Magothy
aquifer zone) along with corresponding downgradient wells in positions
adequate for detection and/or assessment programs (see further discussion

-------
below) .  The Task Force recommends the incorporation of NJPDES wells with
adequate construction and records to be incorporated into the RCRA system
if found to be in proper locations.  For those localities where no NJPDES
wells can be used, new wells must be installed.  Only at this stage can the
rate, extent, and concentration of contaminant plumes be identified in the
assessment program and the immediate detection of a release be monitored in
the detection program.

The Chemical Waste "C" Landfill was in detection mode at the time of the Task
Force inspection.  Four wells screened in the shallow Glacial aquifer comprised
the RCRA system.  The Task Force found that the number of wells designated as
the RCRA system was inadequate.  All zones of the uppermost aquifer must be
monitored by background and downgradient wells placed accurately for all
hydrologic conditions.  In addition, the Task Force sampling showed significant
amounts of landfill-type waste found in RCRA downgradient well M-204.  Therefore,
the landfill should have been in assessment monitoring.

The Waste Water Basins/Ditch System unit was in assessment mode at the time
of the Task Force inspection.  The designated RCRA wells include fourteen
wells, the majority in close proximity to the Waste Water Basins.  Nine of
the fourteen wells are screened in the shallow Glacial aquifer, including the
two backgound wells.  Tnis program is inadequate for RCRA.  As in the case of
the landfill, ground-water monitoring for the Waste Water Basins and their
regulated extensions, the ditches, must include background and downgradient
wells screened in all portions of the uppermost aquifer and placed in locations
valid for all hydrologic conditions.  In addition, the fourteen designated
RCRA wells are not adequate for monitoring the ditch system which is over
319,000 square feet.  The current assessment program, has not defined the rate
and extent of migration of the hazardous waste or hazardous waste constituents
or their concentrations in the ground water as required under §265.93(d)(4).

Ground-Water Sampling and Monitoring Procedures

Inadequacies were found in E.I. Dupont's sampling and analysis plan, dated
June 1, 1982.  These deficiencies include a lack of detail procedures for
obtaining physical measurements prior to sampling, ensuring proper well
evacuation, detecting immiscible contaminants, measuring field parameters,
decontaminating equipment, and following a chain-of-custody.  Also inadequate
information is provided regarding analytical procedures, the facility's and
facility contractor's quality assurance/quality control program(s) and
procedures used to determine statistical increases over background measurements.
Incorrect sajriple containers preservation methods, and holding times are
provided for several parameters.

An oversight of Dupont's ground-water monitoring contractor, W.C. Services, was
conducted on April 7, 1986.  Numerous deficiencies were noted with regard to
sampling procedures and equipment used.  Also, in most instances, the proce-
dures used in the field were not described, or in some cases, even mentioned
in the sampling and analysis plan.  As the sampling and analysis plan and
procedures instituted were deficient, data generated from past monitoring
should be considered questionable.

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Well Sampling Data Analysis

Data generated from the monitoring wells sampled by the Task Force around the
landfill seem to indicate  that ground-water contamination is occurring in the
vicinity of area 1 of the landfill, in particular, the west side.  The highest
levels of  aluminum (3008 ug/1), barium  (2200 ug/1), beryillium  (50 ug/1),
chromium (225 ug./l), cobalt  (515 ug/1), copper  (260 ug/1), cadmium  (2.1
ug./l), nickel (416 ug/1), silver  (42 ug/1), vanadium  (527 ug/1), and cyanide
(43 ug./l)  were found in this area.  Hazardous organic constituents  (11),
ranging from 2.6 ug./l of 2-nitronhenol to 140 ug./l of n-nitrosodimethylamine
were also found in the dowr.gradient well sampled near area 1. Migration of
these contaminants appears to be towards the Delaware River, as Dupont's
shallow Glacial zone potentiometric map (figures 21 & 22) reveal ground-water
movement in that direction at the west side of the landfill.

Other monitoring wells sampled near the Delaware River indicate elevated
levels of aluminum (19600 ug/1) , chromium  (82 ug/1), cobalt  (66 ug/1) , lead
(37 ug/1),  mercury (1.75 ug/1), and zinc (364 ug/1).  Several hazardous organic
constituents were detected, ranging from   2.5 ug/1 for toluene to 2000 ug/1
for 1, 2-dichloroethane.  Physical observations and field measurements in two
wells in this area seem to indicate the presence of a floating hydrocarbon
layer.

Ground-water samples obtained from monitoring wells screened in the shallow Potomac-
Rar itan-Magothy aquifer zone  indicate the presence of several hazardous organic
constituents ranging from benzene  (1.6 ug/1) to acetone  (140 ug/1).  Elevated
levels of lead (61.8 ug/1), and barium (193 ug/1), were also discovered in
these samples.  The majority of these constituents present in the shallow Potomac-
Raritan-Magothy aquifer zone parallel those present in the Glacial aquifer
(see above).  In addition, vertical flow gradients  indicate the possibility
of flow from the Glacial aquifer to the Potomac-Raritan-Magothy aquifer zone.

The highest concentrations of contaminants were  found in ground-water samples
from the shallow Glacial aquifer of the interior portion of the plant.  The
middle and  deep Glacial aquifers showed similar levels of contamination, rela-
tive to each other.  Monitoring wells along the property boundary indicate
the presence of hazardous constituents similar to those found in other wells
sampled by the Task Force.  However, due to the various interceptor pumps
being used  at any one time, it is difficult to say whether the contaminants
are being drawn outward from the center of the plant or inward from contami-
nation which had migrated off-site.  Further investigation of possible off-site
migration of contamination at the southeast property boundary is necessary.

This widespread ground-water contamination on-site is occur ing from the
Waste Water Basins/Ditch System, landfill, and past practices.  Factors that
predominate are the similarities and widespread distribution of the organic
contaminants in the monitoring wells, including those screened in the shallow
Potomac-Raritan-Magothy aquifer zone.  The majority of these contaminants
parallel those present in the leachate from the landfill which is a "fingerprint"
of the previous and present types of chemicals used at the facility and the
types of wastes generated on-site and entering the ditch system.

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NJDEP, EPA, and DuPont agreed upon an Appendix VIII sampling program in May,
1985 to more effectively characterize the ground-water contamination on-site.
The Appendix VIII sampling results were transmitted to EPA in January, 1986.
These showed 43 constituents in excess of 10 parts per billion (ppb).  For
example, well M-32 had Freon-TF at 52 ppb and the composite sample from wells
M-l, M-2, and M-3 showed 40,500 ppb of chlorobenzene.  The Task Force has
determined that this Appendix VIII sampling program must be modified.  The
current program only monitors the Glacial aquifer.  Federal and State
regulations require the full extent and rate of migration of hazardous waste
and hazardous waste constituents be defined.  This can only be accomplished
through an assessment program which includes monitoring wells in the Potomac-
Far itan-Magothy aquifer system.

Cbrrective Action Program

E.I. DuPont submits annual progress reports on their site-wide corrective
action program every March.  The latest available report, March, 1986, details
the results of 1985.  This most recent report concludes that the pumping
program works overall but requires adjustment in the shallow Glacial zone
along the western boundary of the site (the Delaware River).  The Task Force,
however, has determined that the corrective'action program requires modifications
beyond those cited in the March, 1986 report.  First, the data supporting
DuPont's claims of the overall effectiveness of the pumping program must be
expanded.  That is, ground-water flow has been most accurately defined in the
shallow Glacial zone along the southern and eastern regions of the site.
West of the Chemical Waste "C" Landfill and Waste Water Basins along the
perimeter of the Delaware River, few data points exist for measuring ground-
water levels or ground-water quality.  There is" also a lack of data in the
region north and east of the Chemical Waste "C" Landfill as well as northeast
of the Waste Water Basins.  The middle and deep zones of the Glacial aquifer are
more poorly defined in all of these sectors.  The Potomac-Paritan-Magothy
aquifer system has even fewer water level or ground-water quality monitoring points,
In a hydrogeologic system as complex as this one, ground-water flow directions
and the interrelationships between aquifer  zones must be quantified better
and include data for the changing patterns due to the changing centers of pumping.

The Task Force has determined that DuPont must monitor both the Glacial
aquifer and the Potomac-Raritan-Magothy aquifer system and define the
hydrogeologic parameters for all zones.  Ground-water flow nets and hydrogeologic
cross-sections must be constructed and the transient ground-water flow
gradients must be determined.  Once this information is known, then accurate
determinations of the effects of the corrective action program can be made.  At
this point any modifications needed can be established.

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Audit of Laboratories Used by DuPont

Itie evaluation of the analytical work of the laboratories being used by
DuPont at the time of the investigation is included in the technical report.
Inadequacies were found in the area of parammeter selection which result in
the generation of improper information in terms of regulatory compliance.
Inadequacies were also found in the application of analytical methods which
result in the generation of questionable data for certain parameters.

Several creditable laboratory practices were worth noting, including calibration
procedures and the use of standard operating procedures, control charts, and
sample preservation checks.  Additionally, the DuPont laboratories are certified
by the State of New Jersey for various analytical activities.

Comprehensive Evaluation Inspection

Observations of current waste management practices and a review of records
maintained at DuPont have identified several Class I and Class II violations.
T^iese included the failure to date drums (accumulation start dates)  at gener-
ator satellite storage areas, the presence of open drums, the failure to
conduct daily inspections, the failure to maintain adequate aisle spacings,
an inadequate closure plan, an inadequate waste analysis plan, and violations
of DuPont's Temporary Operartmg Authorization (TOA) .

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                           II. Technical Report


A.  Regulatory Requirements

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

RCRA was enacted by PL 94-580, October 21, 1976; 90 Stat. 95, 42 U.S.C.
6901 et seq.; Amended by PL 95-609, November 8, 1978; PL 96-463, October 15,
1980;" PL 96-482, October 21, 1980; PL 96-510, December 11, 1980; PL 97-
272, .September 30, 1982; PL 97-375, December 21, 1982; PL 98-45, July 12,
1983; PL 98-371, July- 18, 1984; PL 98-616, and November 8, 1984.

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

Subtitle C of the Act establishes a program to manage hazardous waste from
cradle to grave.  The objective of this program is to assure that hazardous
waste is handled in a manner that protects human health and the environment.
The regulations are found in the Code of Federal Regulations  (CFR) .  Title
40, Chapter I, Subchapter I, Parts 264, 265 and 270.

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

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

New Jersey applied for permitting authority of land disposal facilities
on August 3, 1984.  Their revised and complete application for final
authorization was submitted on August 20, 1984.  EPA published its intent
to grant final authorization effective on February 21, 1985.

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New Jersey's RCRA program is run primarily by Division of Waste Management.
However, since ground-water protection is delegated to Division of Water
Resources, they take primary responsibility for RCPA ground-water issues.
New Jersey's program is more stringent than the Federal program in the
following respects:

1.  Waste oil is listed as a hazardous waste, consequently, more facilities
    are regulated;

2.  No exemptions are provided from the ground-water monitoring program;

3.  No waivers are granted during interim status.
New Jersey Department of Environmental Protection Responsibilities

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

EPA provides the State of New Jersey with Federal funding.  EPA regularly
evaluates New Jersey's administration and enforcement of its hazardous waste
program to ensure that the authorized program is being implemented consis-
tant with RCPA.  EPA also retains the right to conduct inspections and
request iniformation under Section 3007 of RCRA, to take enforcement action
under Sections 3008, 3013, and 7003 of RCRA, and to enforce certain pro-
visions of New Jersey State law.  Currently, under Section 3006(g; of RCRA,
•42 U.S.C. 6226(g), the new requirements and prohibitions imposed by HSWA
take effect in authorized States.  EPA Must carry out these requirements
until the States are authorized for HSWA.  Therefore, EPA will administer
HSWA in New Jersey until New Jersey applies for and receives authorization
for HSWA.  Therefore, EPA's direct responsiblities include:

      1. Waiver requests; and

      2. Solid Waste Management Units (SWMU).
                                      10

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B.  Investiqation Methods and Procedures
The Hazardous Waste Ground-Water Task Force Investigation of the E.I. Dupont
De Nemours & Company Facility Consisted of:

1. Reviewing and evaluating records and documents from EPA Region II, New
   Jersey Department of Environmental Protection and E.I. Dupont;

2. Conducting a Compliance Evaluation Inspection (i.e., visual Inspection of
   Waste Management units, operation);

3. Evaluating on-site and off-site analytical laboratories;

4. Sampling and analyzing data form selected ground-water monitoring wells and
   leachate pumps, "Field Sampling";

5. Conducting a Comprehensive Ground-Water Monitoring Evaluation  (CME).
Records/Documents Review

Records and documents from EPA Region II and the New Jersey Department of
Environmental Protection offices compiled by an EPA contractor, were reviewed
prior to and during the on-site inspection. On-site facility records were
reviewed to verify and supplement information currently in government files.
Selected documents requiring further evaluation were copied by the Task Force
during the inspection.

These records and documents were reviewed to address the administrative, non-
technical and technical requirements of 40 CFR Parts 265, Subpart B through
R and the New Jersey Administrative Code N.J.A.C. 7:26-6,7,8,9 and 11 e_t seq.

40 CFR Subparts B through E address the administrative and non-technical
requirements to ensure that owners and operators of TSDs establish the
necessary procedures and plans to run a facility properly to handle emergencies
or accidents.  These subparts included:
40 CFR Subpart
      B
N.J.A.C. Subchapter
      C

      D
        9

        9
Subject

General facility standards

0 Waste analysis
0 Security
0 Inspections
° Training
0 Ignitable, reactive or
  incompatible wastes

Preparedness and Prevention

Contingency plans and emergency
procedures
                                      11

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40 CFR 265, Subparts F-R, are the interim status technical requirements to
minimize the potential for threats resulting from hazardous waste treatments
storage, and disposal.
      subparts evaluated included:

40 CFR Subpart    N.J.A..C. Subchapter          Subject

      F                   6                    Ground-Water Monitoring Requirements

      G                   9                    Closure, post-closure requirements

      H                   9                    Financial requirements

      I-R                 9&11                 Record and document requirements
                                               factored to specific waste management
                                               methods  (i,,e. contains, tanks, surface,
                                               impoundments, incinerators...)

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



Comprehensive Evaluation Inspection

The compliance Evaluation Inspection conducted in April 1986 included
identifying waste management units and reviewing waste management
operations.

These items were reviewed to address the technical requirements of
40 CFR 265 Subparts I-R and N.J.A.C. 7:26-9,11 e_t seq.  These subparts
evaluated included:

40 CFR Subpart                             Subject

      I                                   Containers

      j                                   Tanks

      K                                   Surface Impoundments

      N                                   Landfills

      O                                   Incinerators

      p                                   Thermal Treatment
                                       12

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


Comprehensive Ground-Water Monitoring Evaluation

This portion of the investigation was composed of an office evaluation.
Tne objective was to determine compliance with the Federal and State of
New Jersey interim status ground-water monitoring requirements  (40 CFR
Part 265 subpart F and N.J.A.C. 7:14A-6.1 et. seq.) and potential compliance
with the requirements of 40 CFR 264 Subpar~F" and State of New Jersey re-
quirements.

Records and documents from NJDEP and EPA-II were compiled by an EPA-HQ contractor
Those specifically relating to hydrogeology and ground-water monitoring were
reviewed prior to the on-site inspection.  Several meetings were executed
between EPA-II and NJDEP hydrogeologists to discuss the site and choose
optimal sampling locations for the inspection.  Tne hydrogeologists selected
15 of the possible 157 wells, two surface water localities, and 2 leachate
sump pump localities.  Tne original 15 wells chosen are:  M-12, M-13, M-14,
M-22, M-25, M-59, M-63, M-64, M-67, M-91, M-92, 204, 241, 252, and 291.
These choices were made based on vertical and horizontal spatial distributions
and construction integrity (Table 1).  Several pre-task force site visits
occurred in order to familiarize all involved personnel with the Chambers
Works facility.

The "Characterization of Site Hydrogeology Worksheet" from the draft version
of the RCRA Ground-Water Monitoring Technical Enforcement Guidance Document
was used as a guideline for the office evaluation.Tne worksheet questions
were answered using the Part B and any supporting documents supplied by
DuPont.  Further, three interviews were conducted pertaining to hydrogeology
and the ground-water monitoring system.  Tne first was conducted on Thursday,
April 3, 1986 where DuPont was represented by their hydrogeological consultant,
G. Sidney Fox, vice-president of Leggette, Brashears, & Graham, Inc.  The
second was on Friday, April 4, 1986 with DuPont employee, John Curry.  Tne
last interview was on Thursday, April 10, 1986 with G. Sidney Fox.  The
interviews are recorded in the hydrogeologist's log book.


Task Force Field Sampling

Sampling was conducted at E.I. DuPont, Chambers Works by the Task Force
in order to determine;  if the hazardous waste disposal, storage and
treatment activities conducted at this site and regulated by the Resource
Conservation and Recovery Act have impacted the quality of ground water
underlying this facility, and in general, if the ground water at the
facility contains hazardous waste constituents or other indicators of
contamination from past/present facility activities.  Tne Task Force's
contractor, Alliance Technologies (formerly GCA), collected samples from 17
ground-water monitoring wells, two of the landfill's leachate collection
sumps, and two bodies of surface water.  Table 2 shows the monitoring well
                                      13

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          Table  1.  Rationale for Task Force Sampling Locations
 Shallow qlacial aouifer wells:               K14, M47, M64,  M67, H70, 204,  241, 252

 Medium qlacial aouifer wells-                M3  M13, M63. 291

 Deep qlacial aquifer wells:                  Ml, M12, M18, M21

 Shallow Raritan-Magothy aouifer wells:       M45C, M94, M92

 RCRA wells (landfill):                       252 upqradient, 204 & 241 downgradient

 VfcUs previously sanpled for Appendix VIII-  Ml  M3 .  M47, M67

 Wells close to wastewater basins:            M12, M13, M14,  M47, M63, M64

 Wells close to landfill-                     252  204  241,  291

 Wells acting as background:                  252, M92(?)

 Shallow well near an unlined ditch:          M70

 Perimeter wells near residential area:       M18, K21, M94

 Perimeter wells near Delaware River-         M63. M64
 *In addition, 2 leachate samples will be taken from the "C" landfill,
  the Area I leachate system and the Area II/III leachate system.
**
  An allowance may be mado for surface water sarrples as well.
                                         14

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specifications for the nineteen wells which were originally chosen to be
sampled.  Table 3 shows the physical characteristics of the wells
measured during the sampling activities conducted by the Task Force.
Table 4 presents an outline of ground-water monitoring activities
conducted by the Task Force at E.I. DuPont during the period March 31,
1986 through April 10, 1986.  This includes the order of well purging
and sampling, as well as the equipment used, and the type of quality
control samples taken to ensure reliable data.

Due to the lack of information available for well CP6-1, it was eliminated
from the sampling list and replaced by well M-92.  Well numbers M-67 and
M-70 were both eliminated due to time and sampling limitations.

Prior to evacuation of the standing water in the well casing, air
monitoring activities were conducted to determine if there was a need for
respiratory protection.  The instruments used included;  an organic vapor
analyzer (OVA), a photoionization detector  (HNU), and a Geiger counter.
Table 5 presents the results of the air monitoring data obtained at each
well.  An interface probe was used to determine the presence of an
immiscible phase.  A very thin floating layer was detected at well M-64
only.

All water level measurements were taken with a level indicator/sounder.
After removal from, the monitoring well, the probe and line were rinsed with
isopropanol and deionized water.  Due to problems with the available
equipment and the large volumes of water that needed to be purged, ESD
provided two submersible pumps and several four inch bailers.  This
deviation from the project plan protocol was necessary to allow the
completion of the Task Force's sampling assignment in the time allotted.
Even with this equipment, it was occasionally necessary to use more than
one pump in a well at once, in order to purge three casing volumes in a
reasonable amount of time (see Table 5) .

The submersible pumps were constructed of all stainless steel, with a
viton "impeller", and Teflon" wrapped wires.  Decontamination between
wells consisted of a non-phosphate soap and water flushing through the
internal system, and a similar type cleaning, including an isopropanol
rinse, on the outside of the pump and line.  The four inch teflon bailers
were cleaned/rinsed at EPA's Edison laboratory prior to their use in the
field.  The cleaning/rinsing procedure consisted of a thorough washing
with hot water and a non-phosphate detergent, followed by successive
rinses with acetone and methylene chloride.  After being air dried, the
bailers were wrapped in aluminum foil.

Three volumes were purged from all of the monitoring wells except for M-64
and M-92.  M-64 was purged to dryness after approximately two volumes, and
was sampled after recovery.  M-92 was purged till two volumes had been
removed and the pH, temperature, and specific conductivity field
measurements had all stabilized.
                                    15

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Table 2.  Well Construction Specifications  for Monitoring Wells  Sampled
          by the Task Force
Well
NO.
Ml
K3
M12
M13
M14
HIS
K21
M45c
M47
M63
M64
M67
M70
M94
CP6-1
204
241
252
291
Total
Depth
(Ft. )
119
68
90
57
21
109
112
186
22
36
15
18
20
198
180
21
20
20
70
Ground
Elev.
(rt. )
c.w.
8.79
8.86
7.74
7.79
7.93
7.05
10.85
15. 17
8.54
-
-
—
-
7. 18
8.20
8.80
6.70
5.91
—
Top of
Casing
(Ft.)
Datum
10.19
9.76
8.04
8.59
11.03
9.05
12.35
16. 17
9.14
10.04
10.72
~
11.85
8.89
11.38
10.89
8. 10
8.70
1 1 .78
Casing
Diam.
(In.)
6
6
6
6
6
6
6
6
6
6
6
6
6
6
4
4
4
4
6
Screened
Interval
C.W. Datum/
FT. BGL
100-105/
109-1 14
55-60/ -
- /85-90
- /S2-57
8-13/15.5-
21
97-102/ -
96-101/ -
166-171/ -
7-12/ -
22. 4-27. 4/
31-36
1.4-6.4/
10-15
4-9/13-18
5-10/15-
20
186-19V
193-198
—
2-1 2/-
4-14/10-
20
4-14/-
50-60/60-
70
Screen/
Casing
Mat' 1
304SS/
Steel
304SS/
Steel
304SS/
Steel
304SS/
Steel
304SS/
Steel
304SS/
Steel
304SS/
Steel
304SS/
Steel
304SS/
Steel
304SS/
Steel
304SS/
Steel
304SS/
Steel
304SS/
Steel
304SS/
Steel
—
we/
PVC
PVC/
PVC
PVC/
PVC
we/
pvc
Scr«en
Length/
Slot Size
(Ft. )
S/-
5/-
5.4/.030
5.4/.030
5.4/.030
5/-
5/-
S/-
5/.020
5/.020
5/.020
5/.020
5/.020
5/-
~
10/.020
10/.020
10/.020
10/.020
Static
Water Level
(Ft. )/Date/
Datum
2.25/4-S2/
C.W,
.7/6-66/
C.W.
2.3/4-S2/
C.W.
2.6/6-66/7
S.6/6-66/
C.W.
—
—
32.67/4-B2/
C.W.
-
-
~-
4.8/7*B4/
c.w.
~
37.4/4-S2/
C.W.
••
2.9/1-85/
C.W.
3.4/1-8S/
C.W.
4.7/10-81/
C.W.
—
Date
Instal.
6/66
6/66
2/67
2/67
2/67
—
—
6/79
9/72
8/84
8/84
7/84
10/84
"~
~
1/85
9/78
10/81
9/78
                                       16

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Table 3.  Physical Characteristics of Wells Measured and Sampled by
          Task Force at E.I. DuPont  (3/31/86 - 4/10/86)
Well
No.
Ml
M3
Ml 2
Ml 3
Ml 4
Ml 8
M21
M45C
M47
M63
M64*
•
M92
M94
204
241
252
291
Total
Depth
(ft.)t
114.48
68.80
76.30
54.44
24.57
109.14
113.48
187.70
20.56
39.08
17.23
197.52
198.82
22.76
21.62
22.89
70.82
Static
Water Level
(ft.) t
15.88
14.56
15.42
15.41
11.60
14.33
17.88
55.69
11.41
12.10
8.29
57.50
53.27
7.72
5.36
4.50
10.91
Casing
Diam.
(in.)
6
6
6
6
6
6
6
6
6
6
6
6
6
4
4
4
6
Volume
in Column
(gal.)
145.0
79.6
84.0
57.3
19.0
139.0
138.0
194.0
13.3
39.6
25.0
205.0
214.0
9.6
10.3
12.0
87.0
Volume
Purged
(gal.) |
435.0
240.0
!
268.0
1 !
180.0
57.0
417.0
420.0
582.0 '
40.0
120.0
40.0
410.0
'
642.0
30.0
31.8
36.0
261.0
     t  All measurements taken from top of casing
     *  Very thin immiscible layer detected
                                  17

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Table 4. Outline of Ground-Water Monitoring Activities Conducted by
         Task Force at E.I. DuPont (3/31/86 - 4/10/86)

   Date                            Activity

   3/31         equipment preparation

   4/1          Well 204-  purged/sampled  (2n bailer)t
                Well 241-  purged/sampled/field blank/facility
                           split (2" bailer)t
                Well 291-  start purge;  stopped due to
                           miscalculation of purge volume

   4/2          Well 291-  purged (ESD submersible pump)/
                           sampled (2n bailer)
                Well  13-  purged (ESD submersible pump)/
                           sampled (2n bailer)
                Well  14-  purged/sampled/fleld blank  (2n bailer)t

   4/3          Well 252-  purged/sampled/facility split
                           (2n bailer)t
                Well   3-  purged (ESD submersible pump)/
                           equipment blank/sampled/  •
                           field blank (2" bailer)
                Well  47-  purged/sampled/duplicate
                           (2" bailerjt
                Well   1-  start purge;  stopped due to submersible
                           pump failure

   4/4          Well  63-  purged (ESD submersible pump)/
                           sampled/field blank  (2" bailer)
                Well  64-  purged/sampled  (2n bailer)t

   4/7          Well  21-  purged (ESD submersible pump)/
                           sampled/field blank  (2" bailer)
                Well  18-  purged (ESD submersible pump)/
                           sampled (2" bailer)

   4/8          Well  92-  purged (combination of ESD submersible
                           pump and GCA bladder pump)tt/
                           sampled/field blank  (2" bailer)
                Well  94-  purged (combination of ESD submersible
                           pump and extended 4" bailer)/
                           sampled (2" bailer)

   4/9          Well   1-  purged (ESD extended 4" bailer)/
                           sampled (2" bailer)t
                Well 45c-  purged (combination of two ESD
                           submersible pumps)/
                           sampled/duplicate/field blank  (2n bailer)
                                                            cont.
                                  18

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    Table 4. (cont.)


        Date                              Activity

        4/10           Well  12-  purged (BSD submersible pump)/
                                  sampled (2" bailer)
                       Surface, water sample $1 *
                       Surface water sample #2 **
                       Leachate sump £1 (facility split)***
                       Leachate sump £2****
   t  seperate bailer used for purging and sampling
  tt  only two casing volumes purged at this well  (see report)
   *  located at northwest corner of landfill
  **  located at northwest corner of dredge material
 ***  located at southwest corner of landfill
****  located at southeast corner of landfill
                                      19

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Table 5.  Results of Air Monitoring at Ground-Water Monitoring Wells
          Conducted by Task Force at E.I. DuPont  (3/31/86  -  4/10/86)
|Well
No.

Ml
M3
Ml 2
Ml 3
Ml 4
Ml 8
M21
M45c
- M47
M63
M64
M92
M94
204
241
252
291
CVA
readings
(ppm)
background
3
3
3
3

3
3
2
2
3
3
3
2
2
2
2
2
well
3
3
3
3
3
3
3
2
2
6
3
3
2
2
	
2
2
2



HNU
readings
(ppm)
background
0.2
i 0.2











0.2
0.2
0.2
0.2
0.2
_
0.2
0.2
0.2
0.2
_
1 0.2



0.2
0.2
0.2
well
9-20
5
0.2
9
10
0.2
0.2

0.5
4
2
0.2
_
0.2
0.2
3
0.2



















Geiger
readings
(mrems/hr)
background
0.02
0.02
well 1
0.02
0.02
1
0.02 I 0.02
0.02
0.02
0.02
0.02
0.01
0.01
0.02
0.02
0.01
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.01
0.01
0.02
0.02
0.01
0.02
0.02
0.02
0.02
0.02
                                  20

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Leachate was collected from Sump £200  (Area I of landfill, southwest corner)
and Sump $274  (Area II and III of landfill, south side).  All leachate
samples were collected on the final day to prevent possible cross-
contamination of any ground-water samples.  Samples from M-12 and the
surface waters, were taken on the morning of the same day, however they were
packaged and sealed prior to handling any leachate samples in the afternoon.


GCA wore self-contained breathing apparatus (SCBA) and protective clothing
during the sampling.  All other persons present wore full-face respirators.
Samples were collected directly from a wide-mouthed tap after having initially
allowed flow through to clear the line of any stagnant liquid.

Surface water samples were collected from two locations on the site;  the
northwest corner of the landfill, south of Well 252, and the northwest
corner of the dredge landfill.  Samples were grabbed directly in the proper
containers from the upper portion (6 inches) of the body of water.
Field blanks were taken each day during the survey.  One equipment blank was
taken to determine if there was any contamination of the sample due to the
equipment.

The sampling procedures followed were those described in the Work/
Quality Assurance Sampling Plan for the Ground-Water Task Force Inspection
Plan at E.I. DuPont.  All sampling was conducted using teflon bailers
equipped with bottom emptying valves.  Samples were collected for the
analytical parameters summarized in Table 6 and analyzed by EPA contractor
laboratories.

Following the collection of the samples, GCA placed the samples in coolers
containing ice.  Samples were preserved, and if necessary filtered, upon
return to the staging area.  Packaging was conducted in accordance with
applicable Department of Transportation regulations for shipment to the
EPA contract laboratories.  As required under RCRA, receipt for samples
were offered to and signed by facility personnel.  Samples were split with
the facility at well numbers 252 and 241, and leachate sump #1.
                                    21

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Table 6.  Summary of Analytical Parameters Sampled for by Task Force
          at E.I. DuPont (3/31/86 - 4/10/86)
            Volatile  Organics  Analysis  (VOA)  Purge and Trap
            Volatile  Orga-nics  Analysis  (VOA)  Direct Injection
            Purgeable  Organic  Carbon  (POC)
            Purgeable  Organic  Halides  (POX)
            Extractable  Organics
            Pesticides/Herbicides
            Di oxin
            Total Metals
            Dissolved  Metals
            Total Organic  Carbon
            Phenols
            Cyanide
            Nitrate &  Ammonia
            Sulfate &  Chloride
                                       22

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Evaluation of Onsite and Offsite Laboratories
The onsite and offsite laboratory facilities handling ground-water samples
were evaluated regarding their respective responsibilities under the Dupont
ground-water sampling and analysis plan.  Analytical equipment and methods,
quality assurance procedures and records were examined for adequacy.  Lab-
oratory records were inspected for completeness, accuracy and compliance
with State and Federal requirements.  Tr\e ability of each laboratory to
produce quality data for the required analysis was also evaluated.
                                      23

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Facility Description and Operation


General Information

E.I. DuPont de Nemours & Company, Incorporated (DuPont, Chamber Works)
operates a 737 acre treatment, storage and disposal facility located at
the base of the Delaware Memorial Bridge in southern New Jersey.  It is
in both Pennsville and Carney's Point Townships.
Facility Address:     E.I. DuPont De Nemours & Company Inc,
                      Chambers Works
                      Deepwater, New Jersey 08023

Telephone Number:     609 - 299 - 5000

RCRA Contact:         Alfred Pagano, Ph.D
                      Consulting Associate

Facility I.D. Number: NJD 002385730
Facility Background

The facility traces its history back to the turn of the century and slightly
before.  Its products have been associated with the two major World Wars in
the defense area, as well as U.S. products areas as a consequence of the
wars (i.e. dyes, synthetics, textiles, etc.)

During the 1970's a major waste water treatment plant (WWTP) was constructed
primarily to handle on-site generated wastes; a major portion of which was
dedicated to dye-stuff manufacturing which ceased about the time of the WWTP
construction.  Excess capacity presently exists.

At the present time DuPont Chambers Works is a major manufacturer of
organic chemicals and organic intermediates utilizing nearly 2000 separate
chemical processes.  Approximately 750 finished products are manufactured
including: floor mated hydrocarbons  (freons), petroleum chemicals (tetra-
alkyl lead), elastomers  (vitron and hytrel), aromaties  (phenylene diamines)
and other speciality chemicals.  The facility has an overall storage capacity
of approximately 600,000 barrels and a transfer capacity of 200,000 barrels
per day.

Numerous treatment, storage and disposal activities are carried on to handle
on-site generated waste from the manufactuing operation with the major unit
being the WWTP.  Additionally, this facility accepts hazardous  (manifested)
and non-hazardous waste for treatment, storage and disposal at Chambers from
other DuPont intra-company sites.  As a result of on-site waste disposal
capabilities, DuPont, as a generator, does not usually manifest waste off-site,
Areas where off-site manifesting occurs are usually when the waste is being
recycled by a non-DuPont facility to secure recovery of a constituent in the
waste.
                                      24

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The commercial operational DuPont  (acceptance of manifested off-,
hazardous waste from non-DuPont sources) involves the operaticr.
This seven day per week 24 hour per day operation also receive::  •
classified as non-hazardous per straight bills of lading.  The c:
i'zed hazardous waste treated in this unit consists of bulk aque-:
able organic and inorganic solutions with a single phase charact:

WAste is recieved at DuPont via ships, railroad cars, tar.!: true'-"
On-site waste is carried primarily by unlined or partially line?.
systems which are detailed as follows:
    "A" System - This system receives contaminated process,  sani
    ceptor well water, and storm water to be  fed to  the W.sTF.   ".
    has an un lined surface impoundment intended to handle  high  v
    water, WWTP bypass and potential spills.
    "B" System - This system receives cooling water, non-cor.tar:
    water , and WWTP effluent.  This system has an unlined  surfs:
    for solids settling prior to river discharge under  an  NPCE^

    "C" System - This system receives lead contaminated  water  v,"
    into an unlined surface impoundment.  The effluent  from  t~.-.
    is fed into the "A" system.
    "D" System - This system receives cooling  water  and  non
    storm water for direct discharge.

    "E" System - This system delivers treated  water  effluen
    to the "B" basin.

    "F" System - Tnis system carries storm water which  is  d
    directly to the river.
Various manufacturing areas which  fed these  systems  include

       Area                                System

Arcmatics - East                              A-3
Aromatics - West                              A-3
Speciality Chemicals - East                  A-B
Speciality Chemicals - West                  A-B
Polymer Products                             A-B
Freon                                        A-B-D
Petroleum Chemicals                          A-B-C-D
  Logistics                                  B
  Utilities                                  A-D
Laboratories                                 A-B
DuPont Chambers Works  is  presently  operating  under  federal inter
status and New Jersey  temporary  authorization issued 6/27/80 arr
extended  indefinitely  12/29/82.   This  facility is currently in t.
process.  The Part  B  was received August 11,  1983.

                                       25

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line facility notified EPA and filed a Part A application on November  5,  1980
for the following RCRA regulated activities.

    0  Generation of Hazardous Waste
    0  Transportation of Hazardous Waste
       SOI (Storage in containers) 600,000 gallons
       S02 (Storage in tanks) 200,000 gallons
       S03 (Waste Pile) 2,500 cubic yards
       S04 (Storage in surface impoundment) 91 000,000 gallons
    0  D80 (Disposal in Landfil)  420 Acre feet
       T01 (Treatment in tank) 50 millions gallons per day
       T02 (Treatment in surface impoundment 5.6 milion gallons per day
       TO3 (Treatment by incineration) 5 tons per hour
       TO4 (Thermal Treatment) 6 tons per hour
                                      26

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     Figure 1.  DuPont  Chambers Works  Waste Management Units
DUPONT CHAMBERS WORKS
SCALE  1:24000
OCTOBER 1980
                                           LE8EHD

                                           /. LEXICAL tASTt r'UK?ILL-IS'ACRES
                                           I UTILITIES HSTif/LE-IACK
                                           3 tASTt I AT EX TXEATttEXT PiAJlT (TJTPHS ACRES
                                           4 rrrf T IASiHI ACRES
                                           5 ni? n
                                           f FiEott Enn.
                                           r KKXEX n
                                           I PtTUE* Ft-tS FWJ& (THEKMAL
                                                                          FT.
                                                    USJE Ft-I IICIkERAW-SS'IX'
                                             CNE*I;AL HSTE TutsToiusE'SC'ix1
                                             H>C LAI HSTE ttKUlXES SMAiE-K'IX'
                                             m ME* HSTE COKTMEK STQRASE-SO'130'
                                             KKHEX XXUIHER SKWf-X 'ISC'
                                             AT-/ TELQKEK T JK[*TX[XJ-X'ZX'
                                             X-r JliOMEF. V UKniKER SWiUSt-S'IlS'
                                             FfEOXa Sff/rUTALT5JCOtWXEtSTDKAZE-
                                             ICC'IK'
                                             ME AS VHST DISPOSAL
                                             AK[i Off AST 7KEATXEKT
                                                 Of FUTURE BtSKSAL
                                     27

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Figure 2.  Chambers Works and Carneys Point Works
                                CHAMBERS  WORKS
                                       AND
                             CARNEYS   POINT  .WORH

-------
HYDROGEOLGY
                  29

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Figure  4.   Physiographic Provinces  of  New  Jersey
      fro* Ow*n>, J.f. mr\t X.T.  lohl, ShtH «n<)
IB  th» Ci-«C«c«Mj«-Ttrtl»r7 For««tlon» of ttx K«v
IE  tS< C->clor» if Witcl»
-------
Figure 6.  The Fall I
 Figure 7.   Trie Coastal  Plain's  Drainage  Divide
                        -v!k^"""-^-"-*\'"-*,, v-
                      *-°£f\ A.--—--T   *  \

-------
      Figure  8.   Typical Section  through  the  Coastal  Plain  (NW-SE)
   Adapted from:   USCS Miscellaneous Geologic
   Investigations  Hap I-514-B, Engineering Geology
   of the Northeast  Corridor Washington, D.C., to
   Boston, Massachusetts:   Coastal Plain and
   Surficial Deposits,  1967
Teh     Cohansey Sand
Tkw     Kirkwood Formation
Troq     Hanasquan Formation
Tvt     Vincentovn Formation
Tht     Hornerstown Sand
Krb     Red Bank Sand
Kns     Navensink Formation
Kml     Mount Laurel Sand
Kw      Wenonah Formation
Krat     Marshalltown Formati
Ket     Englishtovn Formatio
Kwb     Woodbury Clay
Kmv     Merchantville  Format
Kmg     Magothy Formation
Kr      Raritan Formation
Kp      Potomac Group
         CONTOUR INTERVAL 100 FEET
WITH SUPPLEMENTAL CONTOURS AT 5O-FOOT INTERVALS
            DATUM IS HLAN &£A LEVEL
                                                                                                                LJvtu
                                                         34

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Figure  9.    Stratigraphic Section  showing  Transgressive/Regressive Cycles
                                                   DCtT»
                   C**»*>n
                    S*«g
                   *v**ooa
                   tvnv.v
                   m^ftavf
                   Ivtia-
                   Ho"^^ro""
                     i>"C
                    >U^^'"-
                    for "»'.up",
                    for^t^O'
                     • f.Ur-
                    formal ,or
                                                                       SHELF
                                                         35
 rni  Owen,  J.  «nd Sohl,  N.,  Shelf a™"
Dsltaic PaJeoenvircrnerrLs  in the
Cretaceaus-Tartiary Fonrations of the
Coastal Plain,  in  Geology of Selected
Areas in New Jerse>- and Eastern Pennsylvania
and GuidebooV, of Excursions, S. Subitztcy,
Editor, USGS, 1969.

-------
Rock  Units

Table 7 depicts all units in the  Coastal  Plain,  from oldest to youngest
providing age,  lithology, and  thickness.   This regional  information  is an
essential part  in the comprehension of the Chambers Works  site subsurface
and  its relationship to the surrounding communities.
Hydrogeologic  Setting

Table  8 depicts the hydrogeologic units of the Coastal Plain from
oldest to youngest.  Hydrogeologic properties under confined and
unconfined conditions  are provided.  These properties are  an integral
part  in the comprehension of the original ground-water flow regime  at
the site and  its adaptation to  the pumping of water supply wells in
the surrounding area and the interceptor  well system set-up by
Leggette, Brashears, Graham & Company, Inc.
Figure 10.  Composite  Diagram of the Depositional  Environments
                                      tXPL»H»IIOH
                                                                       B>nk
C O**'b*nh Hoodbjv" — Rmtan md M«got*T f°'rr



 M  n! 1  '»1 ^ind
f BoMO1^!^ d^Mi —
                                                  H lnn»t 4h«H — Mfrchinl«.ll«
                                                    irKj Wfnonih Fo"^Jt'0<3 Kiftiwood Fofm*iioo\
                                                  I  Outr S**^ ~~ H*»ch*rttv«tt«
                                                    »nd Ho^'e'stcNm Sjnd »«<1
                                                  J
                                                      Pron: Cfcen, J. «nd Sohl, N.,  Sfelf «nd
                                                      Dffltaic Pa_lecenvironnenT_s in the
                                                      Cret-aoecus -Tertiary Format-icris of the
                                                      Coastal Plain, in Geolog>- of Selected
                                                      Areas in Nev ,3er&e>' and Eastern Pennsylvania
                                                      and andeboof; of Excursions, s. Subitz)rv,
                                                      Editor, USGS, 1969.
                                          36

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Figure 11.  The Wisconsin Glacial Cycle in New Jersey
From:  Widmer, Kemble,  1964,  The Geology and Geography of New Jersey,  Volume 19,
       The New Jersey Historical Series.
                                       37

-------
Table  7.     Geologic  Units   of  the   Coastal  Plain   Physiographic  Province
                                                                                                                     TOO ar*J  »OC  ft.
                                                               of ci»vwv  tilt
                                                                               d  l«p-l^*t«; cl*v i«i  »ilt
                                                                                 tllrlnlt*   C»t»miv« dtf
                                                             n US UMC«  rWw  C< Oa r* -CO I O
                                                             or»3 ou*rrLi  **-fl Me* and c
                                                             «r»U CMa'ly  MeUn.lt* and
                                                             C 1»*"WV  ll.t  arC  1 itfMlV
                                                            ta m ••**!; •*c**-ta  Q*
                                                            tt*'  acrtaLm Uroa
lh*lt.  fcanjp* tTC» IX ft ffBMLT
Ifcarltar-  fcy to aa llttla am 10  ft.
Ik* -JT*  aa TOO ft Ln i
                                                                                                 »le»c»oja oua.ru
feottury Cav
                                                                                            d*rt-cnr*  till- »o
                                                                                          tv l^\n«t«d at  too
     etTaa'R ft In wawt-oantj-a 1
       Ln  pub*ur(aa
       1» ft.
                                                                  lr« Ewrlt*.  Ci *v Ocy h«nt*ly llltt*.
                                                          Cia-jcrr-itic ouarrj  §*rt   i* poutn—a-at * -J . .  tMcK,
                                                          dar» Clavwv Bill.   Silt ba«S» contJln oomtdwrafcl
                                                                                    *r\ oolorwd  ^wrv  to»aillf*rcwi
                                                                      " -J   « a .  f«lorly  as «r>«nt
                                                                            "-vrlt* txm**i
                                                                                                            Hi*-     |oLncf*a« out n*aj- D»La*»ra Rlwar.
                                                                                                          it**  to
                                                                                                 ar«t*;v  to w»l
                                                                                                                    "1 imt rpma ' frcii M to 1TO  ft
                                                                                             » r«i.  W~Ty~ Vll ty  an^
                                                                               d*r* or-rv   Ul i^iter clay
Ud bar* '
(Und
                               Tintar larB^
                                                                                                       da Of  wdL'
                                                                                         aro^ a-ndy lilt  Tc th*
                                                                                         rly port**!, »tc*c«x»
                                                                                         ac»r paver plrwr»i»j ill
                                                                                                       tilt
                                                                                                                        wjct- aa 1?C ft.   Orit  (to
                                                                                                                        iLar for arts' acoraclacla
                                                                                                                     dLaxarca In tn*
                                                                           finr~  tc
                                                          aivcvt all olaodT>lta,  Out
                                                          Cmir*  Slll-clav tr*ctt^ i n'ia  f  • Ll lea o* •neat. Leu m»a.i  tn
                                                                                                     ^T"
                                                                               «l t>
                                                                                               f or
                                                                                                                       i i£X.aoa CD ?K ft Ln
                                                                   •» 1 1 -O* f 1 n«d c*\-nnal_i  Lfl *and  dart, tfile* .
                                                                    tilt-dry t»d»  lf>  aourt,-,. «*rt! u arkoalc t
                                                                   CJ»« Lf> or*^l «• 1 1 -rc"*-**«d ,  ;a«a tr*w J* tn
                                                                    «jaUy owam and  cxuLrt-ilta  w^tff twta»orc*\ic
                                                                      cla>— allt
                                                          i U* i and T» rTaca L^TCW  ta   Clav, milt, aar-
                                                          |pc*tt*ra<: tKuJcSam «w  »jc* am 4 ft in dLawi*T,  Ln fllf fan-Lnn j ft &ana»U' D» 1—«p* Pry.  »*y t
                                                                 ,lcr«  or»wal  ar<  aouJarra »o*t ac^ra«m r»«r tf>a      |tn*r IOC ft •
                                                                 of «»>cr ri*»r« Sortlna fair to oaod  paodLrc
                                                          •acallarrt Lo ocotj, ocyw^Uy t-Mc*. horl*CTtai i a^^rtf and  ailtl
                                                                    crcatN—atLT*tin*d cLav CaOi M^MIW* «rtj
                                                          tf 1 accr-11 rkx^».  Ct-»v%:  we)  bcxJdwrt *ary ^ cc black.  O^'i nM'tiv owwcljL*
                                                             •rtlficiil  fill.

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      Table  8.   Hydro-geologic Units of  the  Coastal Plain Physiographic Province

mm
Potonac
Croun
Ran tan
Formation
Haoothy
Formation
Hatawan
Forratior
herchfntville
Fomation
Woodbury
Clav
Enclishtcv-T,
Forr\ation
Karshalltown
Ft> motion
Wenorvih
Formation
»tount Laurel
Sand
-•^vesinK
jmation
~T»ed Ra-^v <^iti
Tintor F-arr',
Homers town
Sa-*!
Vinofntown
Po mat ion
Hanasnuan
Formation
Kirtrwooc!
Pomation
CoHans^y
Band
Car* nay
Fo motion
Harsh, Swarp,
• nd Estuary
Deposits
GF>~AL ?
W^_L YIE1J1
G/M
3-1900 R
^nn M
10-3900 R
500 M
10-100 P
•7-180 R
37 H
0-10 R
KD
5-520 R
100 M
NT)
1-5 P
2 M
5-300 R
TOO M
NT)
2-25 P
N*D
0-5 P
KT)
3-fO P
S-Bftfl R
200 M
10-2000 P
500 M
s-ioon R
NT)
JTTfC'JX-" D~»
CDT'-F.Pn?.",.
G^D^TT2
29^-2170 P
IftDO M
200-2000 R
1000 H
56-740 R
100-200 p
.02-1S P
.002-. 2 R
50-300 P
.002-3 P
n.f-7 p
40-160 P
.03-15 P
1-100 P
NT;
.02-15 R
10
0.3-120 R
6 M
110-1100 P
250-3000 R
1000 M
300-1000 P
0.1-2 R
.-^:TIC»"
SP . CAP -
C/V/FT
2.4-86 R
21 M
10-44 R
20 M
KD
.?-9.c> R
1 .5 P
sn
KD
KD
KD
KD
NT)
NT)
KD
N-'
KD '
KD
0.2-1.2 P
O.f p
1.2-17.5P
8.2 H
5-40 p
20 M
0.3-20 R
rro
V*T= -
PP.Y1EU3
%
15-20 R
3S-20 R
5-15 R
10-1? P
5
2
10-15 P
5
8-10 P
10-15 P
S-10 R
S-P P
NT1
5-10 p
5
5-10 P
6-10 R
19-23 R
17-23 P
20-30 P
'>f^ CTfrDTTlCKc
FR£EWVTEF
CCfTO.T G/>Tj3
20-40 p
30-40 R
10-30 R
20-24 p
10
4
20-30 R
10
16-20 P
20-30 R-
10-20 R
10-16 P
NTJ
10-20 R
10
10-20 R
16-20 R
3R-46 P
34-46 P
40-80 R

OPJUCTS
Indivi&jal »crjifert ranae fro- a few
feet to 100 ft in thickrwss: clay
levers locally thict. »nd functiesr. as
confjniro beds.
Individual »ouifers rano» frcr a few
f^et to 80 ft in thickness: water
occurs postly urvVr fciXesiar,
conditions. Clry v^its locally thick
a-xi function «s cxr'.fir.inc beds.
KxJerate to hlahly permeailp: yields
lame Quantities of water frcr- teverfl^
tones.
Functions as a minor Bcrji^er where
sand nr^d or i nates.
Functions nainly as a cor, f"i nine d*^
capAble of trams-ittinc sianificant
CTjantities of water where t liable-
differences in head exist between
the overlvinc and urderlvirc a~j;fers.
functioris as • confininc bed. Pinches
out northeast of Woodstow^, .
Minor aajifer: abeent in »outhenmos.t
and westerrrost Sew Jersey.
Functions as > confiniro bed. CVerlics
the Vibodb'jrv Clay in Baler County.
Extensive minor aouifer with nount
Laure! Said .
Manor •ouifer.
Leaky confininc bed- perr«aiilitv
Increases to • maxirn-j' in Saler Cou"itv.
Absent wouthwest of Amevtowr,.

Fuhctions primarily as a confir.ina
bed over artesian acrjifers.
Minor acrjifer in »outhwestfirn New
Jersey.
Prunarily • confinirc bed. Locally
su-oMes mall yields to domestic we} Is
Includes at least two «innificant
•ouifers which yield moderate to laroe
Kunol ies.
Linconsolidatcd thick pemeable »crj:fer.
chiefly confined with direct rechan>>-
locally artesian.
Water occurs mainly under water-table
conditions. Direct r»charoe fror
precipitation. Clay layers in «ui>-
•urface act as confininc beds, causinc
artesian conditions locally:a pro-is-.nc
aouifer in the »oothe.rTi Delaware Bassn.

M  HED1AS
    •d fror,-
USCS Miscellaneous  Geologic Investigations Ms? 1-514-B,^Engineering Geology
of the Northeast Corridor Washington, D.C.,  to Boston,  	-1""•
Coastal PI air, and S-^rficial Deposits, 1967
                                                    39

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The Delaware River Basin


The Delaware River Basin covers 12,865 square miles  (Parker, e_t .al_., 1964).
The original source of ground water within its formations  is precipitation
(Olmstead, et_.aJL., 1960).  Recharge occurs by infiltration at the land
surface.  Tne average annual precipitation, evapotranspiration, and runoff
for the years 1921-50 are 44 inches/year, 23 inches/year, and 21 inches/year
respectively.  During the 1950's, about 6.1 billion gallons per day  (BCD)
of surface water and ground water was withdrawn from the basin collectively;
95% of this being surface water from streams, lakes, and reservoirs  (Parker, et.al.
1964).  Ground-water withdrawal amounted to 343 MGD in 1955  (Parker, et..al_. , T96"4T.
Natural ground-water discharge occurs at the relatively low parts of out-
crops of aquifers (along rivers, streams, marshes, and swamps) throughout
the basin and total discharge including evapotranspiration approximates
10 BCD (Parker, et.aJL. , 1964} .  Only where excessive pumping reverses
the natural ground-water flow scheme do streams act as recharging locations
rather than discharge points (Olmstead, et.al., 1960).
The Coastal Plain


The Coastal Plain accounts for 2,750 miles of the Delaware River Basin.
For the period between 1941-78, average annual precipitation,  evapotranspiration,
and runoff is 44 inches/year and 20 inches/year respectively  (Vowinkel, et.al.,
1981).  Since ground water accounts for 80% of the Coastal Plain's water
supply (Vowinkel in Walker, 1983), it is evident why there is  an upward
trend in ground-water withdrawal.  By 1978, pumpage in the Coastal Plain
exceeded 270 MGD (Walker, 1983).  This increasing trend  is reflected
in the water levels of the confined aquifers.  According  to the U.S.
Geological Survey Water-Data Report NJ-84-2, there was a  net decline  in
water levels except in the northern section of the Coastal Plain where
1984 levels in the Potcmac-Raritan-Magothy aquifer system and  the Englishtown
aquifer leveled off (Bayersf ield, et.jal^., 1985).  The available Coastal
Plain ground-water supply was derived in the 1960 Delaware River Basin
Report, about 1,600 MGD  (Olmstead, et.a_l., 1960).  The majority of this'
ground water is found in the following hydrogeologic units:  the Potomac-
Raritan-Magothy aquifer system, the Englishtown aquifer,  the Wenonah-Mount
Laurel aquifer, the Kirkwood aquifer, and the Cohansey aquifer.  Figure 12
shows the major ground-water withdrawals from the Coastal Plain between 1956
and 1978.  The Potomac-Rantan-Magothy aquifer system is  the major source of
ground water.
                                      40

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Figure 12.  Major Ground-Water Withdrawals  from the Coastal Plain of
            New Jersey by Aquifer,  1956  -  1978
          «*•
        ^
        t
          • e
          •t
        t
                                                 \/
                              1111
                                       «(TO
                                                 l*rt
                                                          1*10
                                   TEA*
               t> *
From:  Vowinkel, E.F.  & W.K.  Foster,  1981,  Hydrogeologic Conditions in the
       Coastal Plain of New Jersey,  USGS Open-File Report 81-405
                                       41

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The Delaware River and Salt Water Intrusion


The Delaware River enters the Coastal Plain when it crosses the Fall Line
at Trenton, New Jersey.  Where it crosses the Fall Line, the river becomes
tidal, and fresh water and salt water mix in its lower reaches  (Parker, et.
al., 1964).  Maximum rates of tidal flow at the Delaware Memorial Bridge exceed
the fresh water discharge of the river entering the tidal sector  (Miller, et.
al., 1962).  Observations at the Delaware Memorial Bridge show great variations
in specific conductance values which show a strong correlation to the tide; as
the tide comes in, specific conductance increases, as the tide goes out, specific
conductance decreases  (Miller, et. al., 1962).  Where the river flows over the •
outcrops of the Early Cretaceous Coa~stal Plain formations (fig. 13) these
aquifers are recharged with river water (Parker, et. al., 1964).  Figures 7,
12, & 13 show that the latter occurs in a region of high volume ground-water
withdrawal as well as in the vicinity of the Chambers Works site.  The significance
is demonstrated in the observation that ground-water withdrawal induces
recharge from surface water bodies (rivers, streams, lakes, etc.)  (Parker,
et.al., 1964).  Therefore, saline water replaces the pumped fresh water in the
"aquTfers.  Salt water encroachment into the aquifers differs due  to-natural
conditions as well.  In general, salt water extends farthest inland in the
lowest aquifers (Olmstead, et.al., 1960).  Figure 14 shows the hypothetical
salt water/fresh water interface.  It must be noted that salt water content
and total dissolved solids (TDS) content show a relationship.  Matthess  (I982j
determined that TDS in mg/1 in fresh water could be estimated by multiplying
the specific conductance of the water in uS/cm* by the factor 0.65.  The
specific conductance of an aqueous solution of one or more salts  is made up
of the conductances of the individual cations and anions.  A background value
for total dissolved solids may be derived from the work performed by Parker &
others (1964); the range in dissolved solids in uncontaminated ground water from
the Early Cretaceous aquifers was 30 - 200 ppm (1964).  Chloride concentrations
in the lower Potomac-Rantan-Magothy aquifer range from 250 mg/1  to 27,000 mg/1
(Luzier in Walker, 1983).
The Hvdroloaic System
As seen in table 8, the hydrologic table, the Coastal Plain is actually
one interrelated hydrogeologic system.  Due to its structural and
depositional settings, it is a series of alternating aquifers and
aquitards.  The Quaternary deposits usually display water-table conditions
although silt and clay lenses may cause local confining conditions.  Due
to the wedge-shape of the Coastal Plain, the artesian aquifers of Tertiary
and Cretaceous age receive direct recharge at their outcrops and from
infiltration of water percolating through Quaternary deposits unconformably
overlying them.  Tnis system was originally saturated with salt water,
a fact of its mostly marine depositional environment  (OLmstead, et. .a_l., 1960)
With time, the system was flushed out with fresh water.  As previously
discussed, salt water intrusion is both a natural and man-induced phenomenon.
* uS/cm = micro Siemens (formerly mho) per centimeter

                                      42

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 Figure 13.  Outcrop  Area  of  the  Potomac-Karltan-Magothy Aquifer System
              (Recharge/Discharge  Zone)  along the Delaware River
       PENNSYLVANIA
   •z.
   o
                                        NEW  J E R S E
                                                        OUTCROP AREA OF THE
                                                        POTOMAC-RARITAN-MAGOTHY
                                                        AQUIFER SYSTEM
                                                          10
                                                 10 Ml
                                                    Cgrinrnrii. I,--.,
                                                          f ^f
Adapted from:
Parker, G.G., A.G. Hely, W.B.  Keighton,  F.H.  Olmsted, & others, 1964,
Water Resources of the Delaware  River Basin,  USGS Professional Paper 38
                                        43

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  Figure 14.  Trie Hypothetical Salt Water -  Fresh Water Interface &
              Theoretical Flow Pattern in the Potomac-Raritan-Magothy
              Aquifer System
                                                     INTERFACE BETWEEN
                                                     FRESH & SALT  WATER

                                                     PIEZOMZTRIC CONTOURS

                                                 >>   FLOW LINE
Adapted from:
Parker, G.G, A.G. Hely, W.B. Keighton, F.H. Olmsted,.& others, 1964,

Water Resources of the Delaware River Basin, USGS Professional Paper 38
                                         44

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                      CHAMBERS WORKS SETTING
The hydrogeology specifically pertaining to the Chambers Works site
has been derived from information submitted to EPA and NJDEP by
DuPont and a literature search.  DuPont gathered hydrogeological
information by a number of workers:  a DuPont geologist in the 1960's,
a well drilling company (W.C. Services  [formerly A. C. Schultes]) from
the 1960's through the 1980's, and the consulting firm Leggette, Brashears,
& Graham, Inc. (LEG) from the 1970's through the 1980's.
Quaternary Deposits
As depicted on figure 15, the surficial geology of Salem County, the
Chambers Works was built on marsh and swamp deposits and glacial outwash
(Cape May Formation).  Approximately 15 ft of fill was placed over the
natural sediment  (Curry, pers.comm.).  USGS reports the marsh and swamp
deposits to achieve a maximum thickness of 15 ft.  The Cape May Formation
is reported to be 100 ft thick in northern Delaware.  These reports
correlate with the information submitted by DuPont.  LEG reported the
deposits underlying the Chambers Works to attain a thickness of 120 - 130
ft and exist as highly permeable stringers and lenses of sand and gravel
interfingered with silt and clay zones (LEG, 1981).  Figure 16 is the LEG
general statigraphic interpretation of the site.  It correlates with
Minard's interpretation of Penns Grove; an ancient valley in the Delaware
cut into the Cretaceous Raritan Formation presently filled with Quaternary
glacial/interglacial sediments (1969).
The uppermost sands are directly -recharged by local infiltration at the
land surface with eventual permeation into the deeper zones.  LEG reports
true water-table conditions to a depth of 40 ft and semi-artesian
conditions encountered from 40 - 120 ft (LEG, 1981).  This meshes well
with the USGS description of the Cape May Formation; direct recharge,
water-table conditions in general but local artesian conditions due
to clay lenses.
An important hydrologic factor in this area is that the marsh and swamp
deposits may serve as portals for salt water encroachment into underlying
aquifers where the hydraulic head has been lowered below sea level
by pumping  (Parker, et. al., 1964).  Salt water intrusion in the Glacial
aquifer zones has not been considered a factor by DuPont.  The effects
are important on a chemical basis, as salt water influences the TDS
content of the ground water.
                                      45

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Figure 15.   Coastal Plain and Surficial Geology in  Salem  County
                                                 CONTOUR INTERVtL 1OO FEET
                                            SUPPLEMENTAL CONTOURS AT Kt-fOOT INTERVALS
                                                    O*TU« IS XCtM SU LEVEL
                                                              POTOMAC GROUP


                                                              HAGOrm' FORMATION


                                                              MERCRANTX'ILLE FORMATION

                                                              ENG1.ISHTOVS FORMATION


                                                              MARSIIALT-TOUN FORMATION


                                                              WENONAH FORMATION


                                                              WOODBURY CLAY
                                                              ALLUVIUM: sand, silt,  clay,  gravel,
                                                                        & organic material
                                                              LOWLAND DEPOSITS: terrace  deposits
                                                                      overlying Coastal  Plain
                                                                      deposits and bedrock;
                                                                      Base 0 to  -200(7)  ft
                                                                      elevation

   Adapted froa:  USCS Miscellaneous Geologic Investigation*  Map  I-5H-B, 1W7,  Ingineering Geology
   of the Northeast Corridor  Washington, D.C., to Boston,  MA.:  Coastal Plain and Surficial  Deposits
                                                   46

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Figure 16.  Leggette,  Brashears,  & Graham,  Inc.
           General Stratigraphic Interpretation of  the Chambers
           Works facility
                   .-.GLACIAL  DEPOSITS
                      E. I. du Pont de Nemouri 6  Co., Inc. .^
                     CHAMBERS  WORKS,  DEEPWATER. N.J. '*>.

                     SCHEMATIC   GEOLOGIC   PROFILE ' OF ^
                  DIPPING    COASTAL  PLAIN  SEDIMENTS  .ON
                 BEDROCK   FLOOR,   SOUTHEASTWARD <•
               DELAWARE   RIVER  AT DEEPWATER
                                    47

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Cretaceous Deposits
Figure 15 depicts the surficial geology and outcrop areas of
the Coastal Plain formations in Salem County.  As shown,
directly beneath the Quaternary deposits  (alluvium and lowland
terrace deposits) are the Early Cretaceous formations which
comprise a major aquifer system in the Coastal Plain.  This
is the Potomac-Raritan-Magothy aquifer system.

Gill and Farlekas defined three major zones in this aquifer
system underlying the approximately 400 square miles southwest
of Trenton adjacent to the Delaware River  (Walker, 1983) .
These are delineated as shallow, middle, and deep.  The deep
and middle zones lack a confining unit in places adjacent to
the Delaware River (Gill and Farlekas in Walker, 1983). LBG's
interpretation of this system corresponds; they define only
a shallow and deep aquifer for the Potomac-Raritan-Magothy
aquifer system at the Chambers Works.

Table 7 and table 8 provide the general lithologic and
hydrologic data for the Potomac-Raritan-Magothy aquifer
system.  Specifically, the deep aquifer is composed of
undifferentia ted sand, gravel, silt, and clay of the Potomac
Group and Raritan Formation.  It lies unconformably on pre-
Cretaceous bedrock which acts as a confining unit  (Walker,
1983). The upper confining unit is the Woodbridge Clay Member
of the Raritan Formation, a thick sequence of silt and clay
(Farlekas in Walker, 1983).  The shallow aquifer is mainly the
Magothy Formation; sand and clayey silt.   Its lower confining
unit is the Woodbridge Clay Member of the Raritan Formation
while its upper confining unit is the Merchantvilie Formation
and Woodbury Clay.

The Potomac-Raritan-Magothy aquifer system yielded 50 billion
gallons of water in 1967 in Salem, Gloucester, Camden , and
Burlington counties (Gill, et.al., 1976).  Aquifer tests in
Burlington, Camden, and Gloucester indicate transmissivity
ranging from 2,300 to 31,000 ft^ per day and a storage
coefficient ranging from .000033 to .004  (Meisler in Gill,
ejt.aJL., 1976).  According to Gill (1976) this aquifer system
is the most heavily pumped in New Jersey.

DuPont contends that industrial contamination only threatens
the aquifers of the uppermost 120 - 130 ft (the Glacial
aquifers).  The company has concluded from their data that no
hydraulic connection exists between the uppermost units and
the Potomac-Raritan-Magothy aquifer system.  However, the
known confining unit for the shallow aquifer of this system, the
Merchantvilie Formation, does not exist at the Chambers Works
site (figures 15 and 16).  It is possible that confining
zones exist within the Glacial aquifer and the Magothy.
Formation. However, these zones have not been proven to be
impermeable or ubitquitous throughout the site.  Walker  (1983)
has also determined that in some localities, the deep Potomac-

                            48

-------
Raritan-Magothy aquifer may receive recharge vertically
through the leaky confining unit between the middle and deep
Potomac-Raritan-Magothy aquifers; potentiometric heads in the
middle and deep zones are similar and are generally lower
than the heads in the shallow aquifer.
                             49

-------
Glacial Aquifers

The natural ground-water flow in these deposits has not been
specifically defined in the literature.  It can be postulated
that ground water originally flowed from topographic highs to
topographic lows with recharge from infiltration of precipitation.
Where these systems are hydraulically connected to other aquifers
or surface water systems, flot? would be affected by the properties
of these other systems.
              THE ALTERED GROUND-WATER FLOW REGIME
In general, ground water flows from outcrop areas and from
downdip regions of the aquifers toward the major cones of
depression.  In some localities, the flow directions are
toward natural discharge points (Walker, 1983).

The 1956 Gill and Farlekas (1976)  map shows the effects of
artifical ground-water discharge by pumping (purge)  wells.  The
pumping of the ground water created cones of depression causing flow
radially inward toward these wells.  Areas of heavy ground-water
use are at the centers of the cones of depression.  Continuous
and higher capacity pumping has created a larger cone of
depression influencing a larger region as shown in the 1968 map.

At the Chambers Works, LEG has produced potentiometric surface
maps for the upper and lower Potomac-Raritan-Magothy aquifers
in the annual progress reports for their "corrective action
program." The 1985 report, as illustrated in figure 20,
indicates that ground water in the deep aquifer travels
northwesterly, towards the Delaware River.  The shallow
aquifer's flow is towards the south with both a southwesterly
and southeasterly component.

LEG has also produced potentiometric surface maps for each of
the three zones of the Glacial aquifer.  Maps were constructed
using the highest and lowest water levels for each zone.
Figures 21 through 26 compare the 1977 flow regime with the
1985 flow regime.  Generally, the maps portray the influence
of the cones of depression on each Glacial aquifer zone due
to the various wells used for purging and their pumping
capacities through time.  In all cases the cones of depression
are of greater extent in 1985 than in 1977 due to the capacity
purged from the wells along with the length of time the
"corrective action program" has been running.
                            51

-------
KEY FOR FIGURES 17 THROUGH 26
     OUTCROP OF POTCMAC-RARITAN-MAGOTHY AQUIFER SYSTEM
     POTENTICMETRIC CONTOUR
     DOWNDIP LIMIT OF FRESH 'WATER (LESS THAN 250 mg/1 CHLORIDE
     CONCENTRATION) OF THE LOWER AQUIFER IN THE SYSTEM
                            PENNS GROVE

                            CARNERYS POINT

                            CHAMBERS WORKS
                  52

-------
    Figure 17.  Generalized Prepumping (1900)  Potentiornetric Surface of the
               Potentiometric Surface of the  Potomac-Rantan-Magothy
               Aquifer  System
                                    ON
                  SCAif   i
Adapted from:  Gill,  H.E.  4 G.M. Farlekas,  1976, Ceohydrologic  Maps of the Potomac-Raritar
•tegothy Aquifer System in  the H.J. Coastal  Plain, USGS Atlas HA-557

                                          53

-------
 Figure  18.  'Generalized Potentiometric Surface of  the Potomac-Raritan-Magothy
             Aquifer  System  for  1956
                                  ' O
Adapted from: Gill, H.E. t G.M. Farlekas,  1976,  Geohydrologic Maps  of  the  Potomac-Raritai
Ugothy Aquifer System  in the N.J.  Coastal  Plain,  USGS  Atlas HA-557
                                           54

-------
   Figure 19.  Generalized Potentiometric Surface of the Potomac-Rantan-Magothy
               Aquifer System for 1968
                      f •'  f '
Adapted from;  Gill, H.E. 4 C,
Hagothy Aquifer System In the
i. Farlekas, 1976, Geohydrologie Maps of  the  Potomac-Rsrita
I.J. Coastal Plain, USGS Atlas HA-557
                                            55

-------
Figure 20. Potentionetric Surface Maps  for  the  Shallow and Deep Potomac-
           Raritan-Magothy Aquifer  Zones  at the Chajnbers Works (LEG)
I  ' I    1    1    I    1    1    I    1

                                         56

-------
Figure 21. Potentlometric Surface Maps  for  the  Highest Water Levels  in  the
           Shallow Glacial Zone  (1977 &  1985)  (LEG)
                                                                 I    I    I    I     I
            inn. •
           it »rf. MM! M •*•«.
                                            57

-------
Figure  22.  Potentiometnc  Surface Maps for the  Lowest Water Levels in the
             Shallow Glacial Zone  (1977 & 1985)  (LBG)
   ftf 9*1 It ttV i • (Ml
      !•»« M  I n, W»l» ••
     v» nc rwtMRi* *cu.i

       •-•(• f*» •»•
       •••*» »•« •»•
            > >«« tm
'     I
                                                                    III     I    f
                                             58

-------
Figure  23.   Potentiometric  Surface Maps  for  the Highest Water Levels in  the
             Middle Glacial  Zone (1977 &  1985;  (LEG)
      ••»« ir»tl • •!••«,( *LMU4
        t.r*...
                                           59

-------
Fiqure 24.  Potentionetric Surface Maps for the lowest Water levels  in  the
  9         Middle Glacial Zone  (1977 & 1985)  (LEG)
                                            60

-------
Figure  25.   Potentiometric  Surface Maps for  the  Highest Water  Levels in the
             Deep Glacial  Zone  (1977 & 1985)  (LEG)
     •mint MTI« iivti » MI*
       I* >«M • IWT UICI ••
                   «tu.f
                                           61

-------
Figure 26.  Potentionetrie Surface Maps  for  the Lowest Water Levels in the
            Deep Glacial Zone  (1977 &  1985;  (LEG)
                                        62

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GROUND-WATER MONITORING REQUIREMENTS
                    63

-------
              NEW JERSEY GROUND-WATER REGULATORY HISTORY


On May 6, 1970, the Solid Waste Management Act became effective.  It was
authorized by the New Jersey Statutes Annotated (N.J.S.A.) 13:1E.  It
was amended in 1975.  Under this Act, the New Jersey Department of Environ-
mental Protection (NJDEPj established its Division of Waste Management (DWM;
and promulgated the regulations under the New Jersey Administrative Code
(N.J.A.C.) Title 7, Volume C, Subtitle F, the Hazardous Waste Regulations
(N.J.A.C. 7:26-1, 4, 7-13A).  Ground water is specifically regulated under
N.J.A.C. 7:26-9.5.

In 1976, New Jersey passed the Spill Compensation and Control Act.  This
Act was the model for the Federal Government's Act, the Comprehensive
Environmental Response, Compensation, and Liabilility Act  (CERCLA) of
1980.

Passage of the Water Pollution Control Act occurred on April 25,  1977.
This Act was authorized by N.J.S.A. 58-.10A-1.  Under the Water Pollution
Control Act, the NJDEP promulgated the regulations under N.J.A.C. 7:14
which were filed and became effective on July 27, 1977.  Prior to passage
of this Act, rules governing the protection of ground water were established.
These are found under N.J.A.C. 7:9 and 7:10.  N.J»A.C. 7:9 was adopted
pursuant to the authority of N.J.S.A. 26:2E-1 e_t seq.« 13:1D-1 e_t seq.,
58:10A-1 et seq., and 58:11A-1 et seq. and was filed and became effective
prior to September 1, 1969.  N.jTATC. 7:10 was adopted pursuant to the
authority of N.J.S.A. 58:11-1 et seq. and was filed and became effective
prior to September 1, 1969.  Amendments to N.J.A.C. 7:10 were adopted pursuant
to the authority of N.J.S.A. 13:lD-l et seq., 58:12A-1 et seq., and 58:12A-1
et seq. and were filed and became effective on July 13, 1979, as  R.1979x3.271.
Under N.J.A.C. 7:9 and 7:10, regulations exist for ground-water quality standards,
sealing abandoned wells, and primary and secondary drinking water standards.
Also, N.J.A.C. Title 7, Subtitle D established the NJDEP's Division of Water
Resources (DWR;.  Since the Water Pollution Control Act was passed to enable
the NJDEP to control waiter pollution, create a pollutant discharge elimination
system, provide penalties, and grant rule-making authority, the regulations under
N.J.A.C. 7:14A were created, in addition to N.J.A.C. 7:9, 7:10, and 7:14.
N.J.A.C. 7:14A is the New Jersey Pollutant Discharge Elimination  System  (NJPDES).
It was promulgated under the authority of N.J.S.A. 58:10A-1 et seq., 58:11A-1
et seq., 58:11-49 et seq., 58:10-23.11 et seq., 58-11-18.. 10 et seq., 13:1D-1
et seq., 13:1E-1 et seq., 58:4A-5, 58:4A-4.1, and 58-.12A-1 et seq.  Note
that under NJPDES, discharge of pollutants to both surface water  and ground
water are regulated.  Furthermore, New Jersey defines "Waters of  the State" as

     the ocean and its estuaries, all springs, streams and bodies
     of surface or groundwater, whether natural or artificial,
     within the boundaries of this State or subject to its
     jurisdiction.
                                      64

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           THE RESOURCE CONSERVATION AND RECOVERY ACT OF 1976
The Resource Conservation and Recovery Act of 1976  (RCRA) was enacted by
PL 94-580, October 21, 1976; 90 Stat. 95, 42 U.S.C. 6901 et seq.; Recodified
as 42 U.S.C. 6901 et seq.; Amended by PL 95-609, November 8, 1978; PL 96-463,
October 15, 1980; PL 96-482, October 21, 1980; PL 96-510, December 11, 1980;
PL 97-272, September 30, 1982; PL 97-375, December  21, 1982; PL  98-45, July
12, 1983; PL 98-371, July 18, 1984; PL 98-616, November 8, 1984.

Under Subtitle C, Hazardous Waste Management, the United States  Environmental
Protection Agency (EPAj is provided with the authority to regulate hazardous
waste management facilities.  The regulations are found in the Code of
Federal Regulations  (CFR), Title 40, Chapter I, Subchapter I, Parts 260
through 270.
                             NJDEP AND RCRA


Although RCRA was created in 1976, the EPA did not codify the regulations until
1980.  As described previously, NJDEP was already running a ground-water protection
program under the Solid Waste Management Act, the Spill Compensation and Control
Act, and the Water Pollution Control Act, under the Divisions of Waste Management
and Water Resources.  Note that many of the ground-water programs were established
before 1969 prior to the Acts.  As EPA codified the regulations under RCRA, the
State of New Jersey began amending their Acts to be equal to or to be more stringent
than the RCRA regulations in order to become authorized under Section 3006 of Subtitle
C of RCRA.  Section 3006 allows the EPA to authorize State hazardous waste programs
to operate in the State in lieu of the Federal Hazardous Waste Program.


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

New Jersey applied for permitting authority of land disposal facilities on August
3, 1984.  Their revised and complete application for final authorization was
submitted on August 20, 1984.  EPA published its intent to grant final authorization
to New Jersey on November 28, 1984.  New Jersey's final authorization became
effective on February 21, 1985.

New Jersey's RCRA program is run primarily by DWM.  However, since ground-water
protection is delegated to DWR, DWR takes primary responsibiity for RCRA ground-
water issues.  New Jersey's program is more stringent than the Federal program
in the following respects:
                                     65

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     1. Waste oil is listed as a hazardous waste;

     2. Consequently, more facilities are regulated;

     3. No exemptions are provided from the ground-water monitoring program; and

     4. No waivers are granted during interim status.
                      NJDEP'S RESPONSIBILITIES
NJDEP is responsible for permitting treatment, storage, and disposal  (TSD)
facilities within the State of New Jersey's borders as well as carrying out
the other aspects of the RCRA program.  NJDEP is also responsible for enforcement.
Further, NJDEP must assist EPA in the implementation of the Hazardous and Solid
VJaster Amendments of 1984  (HSWA) .
                       EPA'S RESPONSIBILITIES


EPA provides the State of New Jersey with Federal funding.  EPA regularly
evaluates New Jersey's administration and enforcement of its hazardous waste
program to ensure  that the authorized program is being implemented consistent
with RCRA.  EPA also retains the right to conduct inspections and request
information under Section 3007 of RCRA, to take enforcement action under Sections
3008, 3013, and 7003 of RCRA, and to enforce certain provisions of New Jersey
State law.  Currently, under Section 3006(g) of RCRA, 42 U.S.C. 6226(g), the
new requirements and prohibitions imposed by HSWA take effect in authorized
States.  EPA must carry out these requirements until the States are  authorized
for HSWA.  Therefore, 'EPA will administer HSWA in >3ew Jersey until New Jersey
applies for and receives authorization for HSWA.  Therefore, EPA's direct
responsibilities include:


     I. Waiver requests;

     2, Solid waste management units (SWMU).
                                     66

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DUPONT'S GROUND-WATER MONITORING PROGRAM PRIOR TO THE ENVIRONMENTAL LAWS
Overview


Manufacturing began at the Chambers Works in the early 1900's.
The plant's operations during the early years were located in
close proximity to the Delaware River, along the southern and
western boundaries of. the property.  Powerhouse # 1, the first building
constructed at the plant, was built upon the highest point of the
property at the time.  As manufacturing and consequently, employment
increased, the plant expanded and was built out in an easterly
direction.  Since the property was originally a marsh it had to be
artificially filled-in.  The artificial fill was a mixture of river
dredgings and industrial waste sludges and solids (LEG,  1971).  There
was no hazardous waste disposal technology during that time.
Monitoring Wells M-l through M-29


In 1966, DuPont acknowledged the potential problems of the waste
disposal practices followed at the Chambers Works throughout
the years.  A DuPont geologist was given a project to determine
the hydrogeology at the Chambers Works plant.  From 1966 to
1969, twenty-nine shallow observation wells were drilled near
the southeast and northeast property boundaries.  Unfortunately,
only the driller's logs are available for study today.  Gamma
ray logs are reported to have been taken by H.E. Gill, a New Jersey
State geologist (J. Curry, pers. comm. ) .  The drillers' logs do not
indicate the use of a standard soil classification system or provide
the necessary detail for a hydrogeologic study.
Discovery of Ground-Water Contamination


In 1969, a private water supply well adjacent to the Chambers
Works' eastern corner yielded Chambers Works' characteristic
waste.  DuPont hired the consulting firm LEG to evaluate the
problem and assist in planning a method to control the migration
of contaminants.
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Contamination, Additional Ground-Water Monitoring, and Early
Remedlation Efforts
From 1970 through 1971, additional wells were installed under the
supervision of LEG.   These are:  M-30 through M-45, M45A, M46,
101, 102, 105, and 107.  All were logged by a qualified geologist
and contain the information necessary for an accurate subsurface
geologic description and interpretation.  LBG submitted a report,
"Results of Test Drilling and Pumping Tests with Recommendations
for an Interceptor Well System, Groundwater Contamination Project
Chambers Works, Deepwater, New Jersey," to DuPont in January,
1971.  This report described what LBG considered to be the problem:


     1. Most, if not all, of the surficial plant area is highly
        contaminated, with some wastes currently escaping beyond
        plant boundaries in directions to the east, southeast, and
        northeast.

     2. Existing disposal methods are hydrologically undesirable
        and should be stopped.

     3. The migration of polluted groundwater to areas beyond
        the property could be stopped by pumping from interceptor
         (waste recovery) wells constructed along plant boundaries.
        At. the same time, such pumpage would cause some escaped
        water to move back into plant wells.

     4. An interceptor system of wells could control groundwater
        contamination and be more practical and less expensive
        than an impermeable boundary around the plant or an
        interceptor ditch or gallery.

     5. Pumping from plant wells at locations beyong plant
        boundaries, such as Ranney wells 1, 2, 3, and 4, should
        be stopped and an equivalent supply furnished by new
         interceptor wells.

     6. Existing groundwater contamination will take years to
        correct, and adequate containment will involve continuous
        pumping of interceptor wells.  Existing centers of high
        contamination on the surface should be graded and sealed
        over to minimize continuing leaching of the stored wastes.
        Ditches should be lined to prevent, losses of wastes  into
         the shallow sediments.
                            68

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The report further described the solution LEG recommended:

     ...a pattern of wells to prevent migration of
     contaminated groundwater beyond plant property
     can be accomplished by  imposing a widespread cone
     of depression beneath the plant.  The combined
     cone of depression of several wells must be
     sufficiently deep and wide to reach all plant
     boundaries and form groundwater gradients
     inward toward pumping wells...the reversal of
     gradient should be maximum in the areas where
     migration beyond the plant boundaries has already
     occur red...the objective is not only to stop
     further migration but to reclaim some of the
     contaminated water now  underlying properties
     adjacent to the plant.

This interceptor well pattern was ultimately determined by
LBG's pumping test data and  interpretations of the hydrology
and geology.  This recovery  system began operating in 1973.


Annual Progress Reports

Starting in 1975, progress reports of the contaminated ground-water
recovery system were submitted to DWR and the Delaware River
Basin Commission (DRBC).  The reports submitted in March 1978
(the report discussing the events of calendar year 1977) through
March 1986 are currently available in EPA-II offices.
The Monitor and Interceptor Well Network

The summaries from the Annual Progress Reports demonstrate that
the LBG "corrective action program" continuously changed through
time as warranted.  On-site, as well as off-site wells, were
installed for monitoring the progress of the "corrective action
program."  Even as the RCRA regulations became effective, the
"corrective action program" continued on its course.  Ultimately,
DuPont molded the "corrective action program's" monitor well
system, along with the monitor wells installed under the auspices
of the Solid Waste Regulations of New Jersey, N.J.A.C. 7:26-1
e_t seq.,  to fit the 40 CFR Part 265 Subpart F ground-water monitoring
regulations.  This being the case, it is important to note the
well drilling and installation sequence:

     1966-1969:  M-l through M-29

          1970:  M-30 through M-45, M-45A, M-46, I-1Q1

          1971:  1-105, 1-107

          1972:  M-47, M-48, 1-103
                            69

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           1973:  M-49, M-50, M-52 through M-56

           1978:  M-239 through M-244, M-291

           1979:  M-45B, M-45C, M-45D, M-292, M-293

           1980:  M-91, M-92

           1981:  M-93, M-94 , I-102A, M-215, M-218, M-245 through M-250,
                  M-252, M-59, M-60, M-61

           1984:  M-62 through M-70, I-103A, 1-108

           1985:  M-201, M-204, M-220, M-240A

           1986:  M-253, M-255, M-257, T-10, T-ll, T-12, T-20, T-21,
                  T-30, T-31

           Date Unknown:  1-102, 1-104



Note that the wells drilled  in the mid-1980's had a dual purpose:

          1*  Monitoring points for the "corrective action
             program"; and

          2.  RCRA monitor wells for detection and assessment
             monitoring programs.
Figure 27 is a site map of the entire Chambers Works showing
all known on- and off-site wells.  Note that A number of additional
wells are located on the map.  Many abandoned wells  (which may not
have been properly abandoned) are still in existence but their
construction details and locations are unknown (J. Curry, pers.
comm.).  The "WS" well series were originally injection wells.
They became plant water supply wells.  They were inactivated for
water supply purposes when the interceptor well program started
(J. Curry, pers. comm,,).  The "DW" well series were wells used
for drinking water at the Chambers Works.  These were inactivated
for that use when DuPont became aware of the contamination problem.
Today, the source of drinking water on the plant is the Salem
Canal.  The Chambers Works' drainage system is designed and
installed to prevent contaminated storm runoff or other waste water
from draining into the canal.  The "R" well series are known as
Ranney wells; off-plant monitor wells.  The "CP" well series are
the Carneys Point wells.  Carneys Point was originally the site
of a DuPont explosives manufacturing plant.  It was run as a
separate entity from the Chambers Works.  Today, Carneys Point is
part of the Chambers Works property.  The "CP" wells were used
for water supply.  Today some are used for monitoring purposes.


                               70

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Figure  27.   Well Location Map
                                     ot'"" PLANT
                                          BOUNDARY
               71

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As indicated, the entire universe of on- and off-site wells
have been used throughout the Chambers Works' history for
multiple purposes:  drinking water supply, manufacturing water
supply, monitoring, purging, and injection.  Parts of this
universe have been adapted for various State of Nev, Jersey and
Federal regulatory requirements.  The following sections will
describe the various adaptations, changes, and evolution of the
ground-water monitoring system from its LEG "corrective action
program" to the State of New Jersey pre-RCRA ground-water monitoring
system to the RCRA interim status system and to the proposed
Part B Permit ground-water monitoring system.  It rrust be noted
that many of the regulatory actions took place concurrently
with NJDEP and EPA.
                                 72

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DUPONT'S GROUND-WATER MONITORING PROGRAM'S ADAPTATrON TO NJPDES
Pursuant to N.J.A.C. 7:26-1.4. an "existing facility" means

          a hazardous waste facility which was in
          operation, or for which construction had
          commenced, on or before November 19, 1980.
          Construction had commenced if the owner or
          operator had obtained all necessary Federal
          permits as well as any permit required by
          the Division's
          Adrr. inistration
predecessor Solid Waste
(SWA)  and either:
          1. A continuous physical, on-site
             construction had begun; or

          2. The owner or operator had entered
             into contractual obligations - which
             could not be cancelled or modified
             without substantial loss - for the
             construction of the facility to be
             completed within a reasonable time.
The Chemical Waste "C" Landfill was authorized as an existing
facility by the SWA in January, 1975.  It received the
Certificate of Approved Registration Number 1713F.  The SWA
issued a number of directives regarding requirements during the
calendar year 1979.  DuPont requested changes as well.  Ultimately,
the SWA established the following ground-water monitoring requirements
on April 6, 1982:

          1. Sampling shall occur quarterly at ground-water
             monitoring wells; and

          2. Each analysis shall be performed for the following:

             A. surfactants,

             B. phenolics,

             C. color,,

             D. chemical oxygen demand (COD),

             E. total dissolved solids (TDS),

             F. total organic halogens (TOX), and
             G. pH.
                                 73

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In a letter dated March 29, 1982, DuPont submitted an application
for a NJPDES Permit for the "A" and "B" Sanitary Landfill,
NJSWA Registration Number 1713B, pursuant to N.J.A.C. 7-.14A-10.12.
The SWA responded to the Chambers Works in a letter dated April
6, 1982.  This letter advised the company that the Chemical
Waste "C" Landfill, NJSWA Registration Number 1713F, is subject
to the ground-water monitoring requirements pursuant to the NJPDES
regulations (N.J.A.C. 7-.14A-1 e_t seq.)  as well.  Additionally,
the SWA directed that the ground-water monitoring requirements
established for the Chemical Waste "C" Landfill are to be followed
during the interim period pending the  issuance of a NJPDES permit.
The DWR issued a letter to the company on November 23, 1982
delineating DWR's actions based on N.J.A.C. 7:14A-1.4(c):

       Whenever a facility or activity has more than
       one type of discharge covered by this chapter,
       processing of two or more applications for those
       permits should to the extent practicable as
       determined by the Department be consolidated.
       The first step in consolidation is to prepare
       each draft permit at the same time.

That is, DWR proceeded with consolidating all ground-water discharges
into one NJPDES permit:  "A" and "B" Sanitary Landfills,  Chemical
Waste "C" Landfill, Waste Water Basins, Nitrocellulose Waste
Pile, and the unlined ditch system.  Concurrently, DWR constructed
an Administrative Consent Order (ACO)  which would eliminate the
discharges from the unlined ditches.  Therefore, the consolidation
approach along with the ACO would permit all ground-water discharges
remaining in existence at the plant while addressing the elimination
of the others (unlined ditches).

Under the conditions of the Initial Interim NJPDES Permit, the
Chambers Works must monitor ground-water quality by operating and
maintaining ground-water monitor wells at specific locations on
the plant.  These locations were chosen to enable DuPont to determine
the followi ng:

       1. Leakage of contaminants from the Waste Water Basins,
          Chemical Waste "C" Landfill,  "A" and "B" Sanitary
          Landfills, and Nitrocellulose Waste Pile;

       2. Progress of the LEG "corrective action program";

       3. Contaminant leakage from the unlined ditch system; and

       4. Ground-water quality off-site.

Therefore, the monitor wells chosen for the NJPDES permit are
located either in close proximity to a unit, adjacent to the
plant's property boundaries, or off-site in the neighboring
communi ties.
                                 74

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 Six  wells  in  the  vicinity  surrounding  the  Waste  Water  Basins
 were designated  as  NJPDES  monitor  wells.   These  are:   M-12,
 M-13,  M-14, M-48, M-53,  and  M-59.

 Seven  wells in close  proximity  to  the  Chemical Waste  "C"
 Landfill were designated as  NJPDES monitor  wells.   These  are:
 M-60,  M-61, M-204,  M-241,  M-243, M-249,  and  M-252.

 Nine wells  located  near  the  "A" and  "B"  Sanitary Landfills were
 designated  as NJPDES  monitor  wells.  These  are:   M-S,  M-8, M-ll,
 M-17,  M-29, M-38, M-41,  M-44, and  M-56.

 Eighty-six  wells, located  along the  plant's  perimeter  or  off-site
 were designated  as  NJPDES  monitor  wells.   These  are:   M-l  through
 M-4, M-6, M-7, M-9  through M-13, M-15,  M-15A, M-16, M-18  through
 M-28,  M-30  through  M-37, M-39,  M-40, M-42,  M-43,  M-45B, M-45C,
 M-45D,  M-46,  M-47,  M-49  through M-55,  M-91  through  M-94,  M-101,
 M-107,  R-4, R-7,  CP-1 through CP-7,  CP-Ranney, WS-1,  WS-1-1,
•WS-1-2, WS-1-3,  WS-2, WS-2-2, WS-2-3,  WS-2-4, WS-2-5,  WS-3,  DW-8,
 Layne  £1, Pennsville  1,  PTWD2,  PTWD4,  PTWD5, AEC2,  AEC3,  AEC5,
 AEC6,  CL1,  CL2,  and CL3.

 The  directives of the Initial Interim  NJPDES Permit require
 ground-water  monitor  wells as specified  in  N.J.A.Cs 7:14A-6.13:

        A well drillers permit,  as  required  by NoJoS.A.
        58:4A-1 e_t se q. ,  shall be obtained  prior  to  the"
        installation of any ground-water  monitoring  well =
        A clear and  accurate  record or  base  map providing
        the  monitoring well locations,  depths, elevations
        and  achievable pumping rates  must be  kept at the
        facility  by  the owner  or operator and be  available
        to  the Department.

        Wells  must be  capped  to  prevent  precipitation  from
        entering  the well bore hole or  introduction  of
        extraneous material and  substances  into the  well
        which  can  invalidate  analytical  results.   All
        monitoring wells  must  be cased  in a  manner that
        maintains  the  integrity  of  the  monitoring well  bore
        hole.  Wells must be  screened and packed  with  gravel
        or  sand where  necessary  to  enable sample  collection
        at depths  where appropriate.  The annular space
        (i.e.  the  space between  the bore hole and well  casing)
        above  the  sampling  depth must be sealed with a  suitable
        material  (e.g. cement grout or  bentonite  slurry)  to
        prevent contamination  of samples and  ground  water.

        The  elevation  of  the  top of the well  casing  for each
        ground-water monitoring  well shall  be established  and said
        elevation  shall be  permanently  marked on  the well  casing.
        The  elevation  established  shall be  in relation to  the New
        Jersey Geodetic Control  Survey  datum.   Each  monitor well
        casing shall be permanently marked  with a number  to be
        assigned  or  approved  by  the Department.

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Further, the Initial Interim NJPDES Permit provides that if
the ground-water monitor wells do not meet the standards of the
permit, they must be replaced with new wells which meet DWR
standards.

The ground-water monitoring requirements for the Chambers Works
are detailed in the Initial Interim NJPDES Permit.  During the
time period of NJPDES permit development, the State of New Jersey
was working towards obtaining their authorization for running the
RCRA program.  Therefore, the Initial Interim NJPDES permit
requirements are derived from N.J.A.C.  7:14A-1 e_t seq. , which
are written so as to be equivalent to, or more stringent than,
the Federal ground-water monitoring requirements under 40 CFR
Part 265.  That is, the data generated through the Initial Interim
NJPDES Permit is used to evaluate the Chambers Works' compliance
with subchapter 6 of the NJPDES regulations, N.J.A.C.^ 7:14A-1 e_t
seq. including sections 6.1 through 6.6.  These NJPDES regulations
are at a minimum, the equivalents of 40 CFR 265.90 through 265.94.

The final NJPDES permit to be issued will have the equivalent, or
more stringent, ground-water monitoring requirements than the RCRA
permi t.
                             76

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DUPONT'S GROUND-WATER MONITORING PROGRAM'S ADAPTATION TO RCRA
Introduction
As previously discussed, NJDEP and EPA-II had varying and changing
roles in the implementation of RCRA through time.  As of February
2, 1983, NJDEP was responsible for the implementation of 40 CFR Parts
260 through 263 and 265.  On February 21, 1985, New Jersey received
final authorization and was additionally responsible for 40 CFR Parts
124, 264, and 270,.  A Memorandum of Agreement (MOA) between the State
of New Jersey's NJDEP and EPA-II was drafted to establish policies,
responsibilities, and procedures pursuant to 40 CFR 271.8 for the
State of New Jersey Hazardous Waste Program authorized under Section
3006 of RCRA and to set forth the manner in which NJDEP and EPA-II
coordinates in the
procedures used by
Part B application
Addendum to the FY
that all aspects of
State's administration of the State program.  The
the Region and the State for handling the RCRA
are outlined in the Cooperative Arrangement
'83 MOA.  Through this MOA, the Region ensures
 the RCRA program are addressed properly.
                              77

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Ground-Vater Monitoring Events


The DuPont Part A  application was  submitted  to  EPA-II  In  a
letter dated November  11,  1980  In  accordance with  40  CFR  Part
122.  From this point  on,  the Chambers Works was required to
fulfill the Interim  status  ground-water aonltoring  requlrenents.
In a letter dated  October  6,  1982,  EPA-II  and NJDEP »ade  the
following agreement:   due  to  the similarity  between the  State
and Federal regulations applying to closure/poct-closure
plans, NJDEP would conduct  the  technical review.   EPA-II  will
approve, disapprove, or modify  the  submitted plans  based
upon the State's evaluation.  A Joint  public notice will  be
issued by EPA-II in  accordance  with 40 CFR 265.112(d)  and the
applicable State regulations.   NJDEP will  reipond  to  comments
submitted during the public notice  period  with  input  from EPA-II.

EPA-II requested submission of  the  Part B  application  in  a
letter dated February  4,  1983.

On February 22, 1983,  DuPont  submitted the ground-water
aonitoring Information pursuant to  40  CFR  265.94(a)(2 ) (11 )  and
(ill) for the Chemical Waste  "C" Landfill  and the  Waste  Water
Basins.  That Is,  In order  to satisfy  the  Federal  interim
status ground-water  monitoring  requirements, the Chambers
Works adapted the  LBG  "corrective  action"  ground-water
wonitoring program in  a similar fashion to the  NJPDES  adaptation
previously discussed.  In  this  case, however, for  RCRA interim
status, two separate ground-water  monitoring system;  were
delineated.  One system is  located  at  the  Chemical  Waste  "C"
Landfill while the other  Is located at the Waste Water Basins.
These two ground-water monitoring  systems  were  originally
described in the ground-water monitoring plan submitted  to
EPA-II on July 29, 1982.   A review of  this ground-water
•onitoring plan was  rendered  by Ertech Atlantic, an EPA-II
contractor.  Ertech  Atlantic  also  performed  a site Inspection
at the Chambers Works  on  November  18,  1982.  The report  on
the ground-water monitoring plan and site  inspection  was
transmitted to EPA-II  on  February  24,  1983.  Ertech Atlantic
determined the following:

    1. DuPont Is In  compliance  with 40 CFR Parts 265.90
       through 265.94  (DO  regulatory deficiencies), and

    2. two technical deficiencies  exist:

       a. designated downgradient  wells were actually upgradient
          of the landfill  and not  capable  of detecting contaminants
          fron the unit during  and shortly previous to the  tite
          Inspe ct ion ,  and

       b. the outline  of  the  ground-water  quality  assessaent
          program  (CWQAP)  does  not describe  a taore comprehensive
          program  to determine  whether contaminants are entering  the
          ground water from the monitored  facilities, although the
          determinations  required  under  40 CFR  265.93(a) are  discussed

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Ertech Atlantic was satisfied that the locations of the landfill
wells were satisfactory at the start of the ground-water monitoring
program and became inappropriate durinq the course of the year.
Evaluation of the ground-water elevation  [40 CFR 265.93(f)j  to
assess the locations of the wells is not required before the
initial year's sampling has been completed.

DuPont used the Ertech Atlantic review to chanqe their ground-
water monitoring plan.  These chanqes were made in the Part B
application, Subpart E, Exhibit A which was submitted to EPA-II
on August 12, 1983.

DuPont submitted the results of the f-irst semi-annual sampling
for ground-water indicator parameters on June 17, 1983 as
required by 40 CFR 265.93(d) and statistically compared the
parameters to background analytical data as required by 40 CFR
265.93(b).  However, the company arqued that the Student's t-test
at the 0.01 level of significance was too sensitive and gave
many false positive results.  They preferred the t-test
recommended by the CMA, Comments-Docket 13004, November 23, 1982.
Despite the problems the company found with the required t-test,
they proposed the NJPDES permit qround-water programs to be used
for the RCRA Part B permit; these programs to be submitted
in lieu of the ground-water quality assessment proqram plan as
required under 40 CFR 265.93(d)2.  NJDEP ultimately approved the
use of the CMA statistical t-test for use at the Chemical
Waste "C" Landfill's qround-water monitoring system on December
4, 1985.  This approval was based on the technical decision
of Barnes Johnson, the EPA Headquarter's statistician.  The
following requirements were mandated for the Chemical Waste
"C" Landfill:

     1. Samplinq M-204, M-241, M-243, and M-252 quarterly for
        TOC, TOX, pH,  and specific conductance with
        replicates from each downgradlent well; and
four
        Samplinq the latter wells tor tne parameters listed in
        N.J.A.C. 7:14A-6.4(b)1 to determine water quality yearly
        These parameters are follow in table 9.
                 Table 9.  N.J.A.C. 7;14A-6.4(b)1
As
Ba
Cd
Cr
F
Pb
Hq
Se
Aq
NO - N
3
NH - N
4
SO
4
Fe
Mn
Na
Cl
Phenols
Lindane
Methoxychlor
Toxaphene
2,4 D
Coliform Bacteria
Toxaphene
2 ,4 ,5-TP Silvex
Endrin
Rad ium
Gross Alpha
Gross Beta

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Pusuant to the State of New Jersey's Phase I interim authorization
on February 2, 1983 and the FY '83 MOA between EPA-II and NJDEP,
DWR and DWM were charqed with implementinq the regulations of
New Jersey's hazardous waste proqram in lieu of Phase I of
the Federal hazardous waste proqram (40 CFR 260 throuqh 263 and
265).  NJDEP notified the Chambers Works of the latter information
in a letter dated August 15, 1983.  Further, DWR instructed the
Chambers Works that all ground-water monitorina reports required
under 40 CFR Part 265 Subpart ^ and previously submitted to
EPA-II must be sent to DWR including:
     1. Quarterly reports generated by the facility during the
        first year of ground-water monitoring as required under
        40 CFR 265.92;

     2. A map showing the location of all hazardous waste management
        units requirinq qround-water monitoring including location
        of all ground-water monitor wells,, identifying all
        upgradient and downgradient wells;

     3. On-going ground-water monitoring reports;

     4. Notifications reguired under the ground-water guality
        assessment program;

     5. Notification and description of the alternative assessment
        ground-water monitoring system (if the facility reguests an
        alternative system); and

     6. Any other reguired correspondence concerning ground-water
        quality.
A revision to the Part B application was transmitted to EPA-II
and NJDEP on September 26, 1983.  NJDEP notified EPA-II .
that they were conducting a completeness review of the Part R
application.  EPA-II and NJDEP responded to the revised September 26
1983 Part B application with a "preliminary review" (administrative
notice of deficiencey  [NOD]) on January 25, 1984.   The following
comments were provided to the Chambers Works regarding the ground-
water monitoring programs:

     1. DuPont informed EPA-II on May 10, 1982 that the company
        relied on a long-standing study conducted by LBG and
        data from existing wells to determine the location of
        qround-water monitor wells.  Please provide EPA with
        some documentation or information which will allow EPA
        representatives to assess whether the placement of the
        wells at the Chemical Waste "C" Landfill and the Waste
        Water Basins conforms with the regulatory requirements.
                            80

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2. For each facility, indicate, precisely and in detail,
   the technical basis for believing that the wells
   installed by DuPont will, as reauired by 40 CFR
   265.91(a.) :

   A. Yield ground-water samples that are representative
      of background ground-water guality in the uppermost
      aguifer near the facility;

   B. Yield ground-water samples that are not affected
      by the facility; and

   C. Immediately detect any statistically significant
      amounts of hazardous waste or hazardous waste
      constituents that migrate from the waste management
      area to the uppermost aguifer.
3. Please describe, in detail, the manner of installation
   of all the monitor wells being relied upon to
   satisfy RCRA reguirements.
4. Please describe why DuPont feels the wells referred
   to in paragraph three have been "cased" and the
   annular space "sealed", as reguired by 40 CFR 265.91(c).


5. On May 10,  1982 DuPont informed EPA that it had
   commenced the sampling and analysis of ground-water
   samples,  as reguired by 40 CFR 265.92.  Please describe
   the procedures and technigues for (1)  sample collection,
   (2) sample  preservation and shipment,  (3) analytical
   procedures, and (4) chain of custody control.
   [Instead  of describing these procedures, DuPont may
   send EPA  a  copy of the ground-water sampling and analysis
   plan, reguired to be kept at each facility pursuant
   to 40 CFR 265.92(a)].
6.  Has Dupont prepared an outline of a more comprehensive
   ground-water monitoring program, as reguired by 40 CFR
   265.93 ?  If so, please submit that outline to EPA and
   indicate why the proposed program satisfies 40 CFR
   265.93(a) (1) ,  (2 ) ,  and (3).
   During the June 9,  1982 inspection Mr.  Al Pagano of
   DuPont indicated that ground-water testing had
   demonstrated that primary drinking water standards
   were being exceeded at the site.  This  being the case,
   DuPont should submit the guarterly analyses in accordance
   with 40 CFR 265.92  and 265.94.
                       81

-------
        Since DuPont knows that qround-water contamination
        exists and since Dupont is apparently already engaged
        in a well pumping proaram to control leachate migration,
        and alternate ground-water monitoring system as described
        in 265.90(d) appears to be appropriate, and DuPont
        might wish to consider submitting such a plan to
        EPA-II.  The alternate system would be used to
        determine the rate and extent of around-water contamination
        and allow the effectiveness of the leachate control
        system to be determined.
On March 3, 1984, DuPont reauested, to EPA-II, an additional
45 days to respond to the "preliminary review."  FPA-II
responded to this reguest on April 20, 1984, grantina them
the extension.
On April 16,1984, the Chambers Works' response to the
"preliminary review" was submitted to EPA-II.  The
following section contains this response.
                            82

-------
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-------
On July 27, 1984, NJDEP notified the Chambers Works that they
had also conducted a review of the RCRA Part B application to
determine compliance with the State hazardous waste management
regulations, N.J.A.C. 7:26-1 et seg. since the State permit
application applies to the entire facility (surface impoundments,
landfills, incinerators, container storage, tank storaqe, and
tank treatment).  They further clarified EPA-II's role
in reviewing the Part B application; a review of the land
disposal portion only (surface impoundments and hazardous waste
landfill.  This notification contained an NOD as well.  The
following comments are applicable to the ground-water monitoring
portion:
     1 .
For a facility where contamination has entered the
ground water, it is reguired that a description of
the plume of contamination which has entered the
ground water t'hat:
        A. Delineates
           map; and
              the extent of the plume on a topographic
        B. Identifies the concentration of each Appendix VIII,
           of 40 CFR 261, constituent throughout the plume or
           identifies the maximum concentrations; of each Appendix
           VIII constituent in the plume.

       ,  It is also required that:

         A. A characterization of the contaminated ground water,
            including concentrations of hazardous constituents;

         B. The concentration limit for each hazardous
            constituent as set forth in N.J.A.C. 7:14A-6.1;

         C. Detailed plans and an engineering report describing
            the corrective action to be taken; and

         D. A description of how the ground-water monitoring
            program will demonstrate the adequacy of the
            corrective action.
On August 21, 1984, NJDEP held a meeting with DuPont.
At this time, NJDEP notified the company that the NJDEP
NOD on the land disposal .portion of the Part B application
supercedes the EPA-II NOD.  In addition, NJDEP told the
company to submit the following by September 14, 1984:
                            86

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     1. Appendix VIII sampling locations (monitor wells);

     2. Freauency of sampling and reporting;

     3. Parameters to be monitored after contaminants are
        identified;

     4. Corrective action plan; and

     5. Location, sampling, and analysis of the Potomac-Raritan-
        Magothy aguifer system wells.
On October 10, 1984, NJDEP informed the Chambers Works that the
Part B application is administratively complete based on their
submittals of September 14 and 28, 1984.  The Chambers Works'
responses pertinent to ground-water monitoring are as follows:

        It was agreed in our meeting on 21 August 1984
        that we would submit an alternative proposal
        with the assistance of our consultant
        hydrogeologist to answer the following guestions:

             1. What constituents are in the ground water?
             2. Is the Raritan aguifer being protected?
             3. Does the Raritan clay layer extend down-
                stream of Chambers Works?

        We are proposing to submit this alternative proposal
        by 1 December 1984.  Prior to submittal, we suggest a
        meeting between our consultant hydrogeologist and NJDEP
        and EPA geologists to review our draft proposal.
NJDEP informed the Chambers Works, on October 27, 1984, that
they must comply with N.J.A.C. 7:26-10.6 as applied to the
existing lagoons which receive hazardous waste.
                            87

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NJDEP informed the company that if they could not comply with
these regulations, the Waste Water Basins would have to close
at the time the Part B is issued.


In response to NJDEP's notification that the Chambers Works must
comply with N.J.A.C. 7:26-10.6, DuPont took the following actions

     1.  On February 18, 1985, they reauested NJDEP to delist the
        "B" Basin; and

     2.  On February 25, 1985> they reguested EPA-II to grant
        waiver from the double-liner reguirements for the
        Waste Water Basins and reguested a meeting with EPA-II.
EPA-II and DuPont met on April 4, 1985 to discuss the waiver
request.  It was brought to the company's attention that EPA
headquarters must be involved.  Waivers under Section 3005 of
the RCRA amendments are not yet responsibilities delegated to
the EPA regional offices.  The Chambers Works and EPA-II
contacted EPA Headguarters on the matter.  The waiver reguest
is presently being evaluated; EPA-II is workino with DWR, DWM,
and headquarters.
NJDEP transmitted their response to the "B" Basin delisting
reguest on April 24, 1986.  The reguest was denied due to the
fact that the "B" Basin is separated from the "A" and "C" Basins
by only a soil berm.  NJDEP considers it likely that the waste
from "A" and "C" Basins have mixed with the waste in "B" Basin
since the soil berm is not an impermeable barrier.  There is
the potential for escape of pollutants to the environment via
effluent from this unit.
The Appendix VIII sampling issue was finally resolved during
a .joint meeting on May 8, 1985.  The participants were DuPont,
NJDEP, and EPA-II.  A modified sampling program was agreed
upon which would effectively characterize the contaminated
ground water at the site.  The following wells were chosen as
sampling points for the 40 CFR Part 261 Appendix VIII
constituents:  R-5, 1-108, M-47, M-67, M-32, M-l , M-2, and
M-3.  Table 12 contains the pertinent well construction details
of these wells.  The samples from M-l, M-2, M-3 would be
combined for a composite sample.  The results of the sampling
were sent to EPA-II in a letter dated January 17, 1986.  A
summary of the results follows in table 10.  NJDEP had notified
the Chambers Works on June 20, 1985 that submittal of the
Appendix VIII data would complete the ground-wciter portion of
the Part B permit application administratively.
                            88

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Table 10 Appendix VIII Constituents in Excess of 10 ppb
                            APPENDIX VIII SAMPLING POINTS
CONSTITUENTS
Benzene
Chlorobenzene
Toluene
Aniline
Chloroanaline
1,2 Dichlorobenzene
1,3 Dichlorobenzene
1,4 Dichlorobenzene
m-Dinitro benzene
2,4 Dinitrotoluene
2,6- Dinitro toluene
N i trobenzene
o-Toluid i ne
N-nitrosopvrolidine
Freon-TF
Tnchloroethylene
1,2,4 Tr i chlorobenzene
Chloroform
1,2 Dichloroethane
1,2 Trans Dicholoroe thylene
Methvlene Chloride
Tetrachloroethylene
Trichlorofluoroethvlene
Napthalene
1-Napththylamine
5-Nitro-o toluidine
Calcium
Iron
Potass ium
Sodium
Stront ium
Arsen ic
Lead
Osmium
Chromium
Cyanide
Nickel
Vanadium
Zinc
Phenol
Benzoquinione
Vinyl Chloride
Aluminum
M-47
316
1340
99
99
513
1580

23
2380
2580
783
599
414













38800
45600
6900
115000
190












M-32
12
528



236







77
52
26
16









8800
700
2000
2900













1-108
575
2670
81
667

930

102

13


470

3600
1210

929
1470
611
267
404
699
41
75
194
98900
397000
7900
667000
620

200
630









R-5
587
5950
200
12800
3710
8820
316
945



20800



88
655
392


227





48300
74200
6600
135000
230












M-67
651
5560
4840
225

1330

155
152
2550
29100
37
814













126000
48900
6100
352000
320



20
33
150
60
1390
35


71500
M 1,2,3
2620
40500
444
16900 I
15060
24400
200
777

76

455
6600

978 |
1600

522
1720
306
833
256

43


65500
69600
23000
412000
300
41



174 ••

150
180 .
49
423
180
900
                         89

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On June 26, 1985, DuPont submitted a revised Section E (ground-
water monitoring portion) of the Part B application.


        The Interim Status Ground-Water Monitoring Program


DuPont certified compliance with 40 CFR 265 Sufcpart F ground-
water monitoring reauirements on October 31, 1985.  This
certification fulfilled the Loss of Interim status provision
(LOIS) of the Hazardous and Solid Waste Amendments of 1984 (HSWA)
[Section 3005(e)(2) of RCRA as amended].  LOIS required all
interim status land disposal facilities to apply for a final
determination regarding a permit and certify compliance with all
applicable ground-water monitoring and financial responsibility
requirements by November 8, 1985.  Interim status would terminate
on this date for failure to meet these requirements and affected
facilities would have to stop introducing wastes into RCRA units
on November 8, 1985.

As of the certification date, the interim status qround-water
monitoring program at the Chambers Works was composed of two
separate systems.  One system is located at the Waste Water
Basins while the other exists at the Chemical Waste "C"
Landfill.  A description of these systems follows.


Waste Water Basins:

The Waste Water Basins are three unlined contiguous surface
impoundments, labeled "A," "w," and "C."  The three surface
impoundments are separated by dikes.  However, the dikes are
not impermeable.  Therefore, the three surface impoundments
are monitored as a single RCRA unit.  Each surface impoundment
serves a specific function as follows:

     1. "A" Basin encompasses an area of 16 acres and is actually
        an extension of the ditch system used to carry the
        process wastes to the Waste Water Treatment Plant  (WWTP).
        The basin itself is functionally an excess flow storage
        basin.  Approximately 5% of the 44 million tons of
        wastewater generated on-site flow through the basin.
        This wastewater consists generally of corrosive material,
        spent haloqenated and non-halogenated solvents, and
        wastewater treatment sludges form electroplating operations.
        The dike which separates "A" Basin from "B" Basin  is
        composed of compacted fill and capped with bituminous concrete
        The basin's other dikes are composed of compacted  gravel.

     2. "B" Basin covers an area of 17 acres.  It acts as  a
        containment area for once through cooling water and final
        effluent from the WWTP.  The liguid contained in the
        basin is eventually discharged to the Delaware River as  it
        is classified as non-hazardous.  Dike construction is
        is identical to that of "A" Basin.
                            90

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     3. "C" Basin is composed of three acres.  It is used to
        contain treated process waste water from the lead
        recycle and recovery process units in the petrochemical
        plant.  Treatment includes pH adjustment for minimum
        solubility of lead inorganic salts and sodium borohydride
        treatment to reduce any soluble ionic, organic lead species
        to lead metal.  From this point, the liquid portion is
        pumped to "A" Basin and eventually to the WWTP.   Solids are
        periodically dredged form the basin bottom and dewatered.
        After dewatering, these solids are either passed through
        a reverbatory furnace for decontmination and lead recovery
        or landfilled.  In 1984, about 2.3 million tons  of waste
        water was discharged to the basin.  Dike construction is
        identical to the other basins.


Physically connected to the Waste Water Basins and therefore a regulated
extension of the unit, is a ditch system.  This ditch system carries
contaminated waste water,'storm water, and non-contact cooling water.
Approximately 319,000 ft2 of this system is unlined and  contaminated.
As of December 1981, 104,500 ft2 had been replaced.  In  1983, NJDEP
Jecided to issue one NJPDES permit for all discharges to ground
water.  Eighty-six NJPDES wells currently monitor the ditch system.
An Administrative Consent Order (AGO) was written by NJDEP which included

        1. A schedule for lining or eliminating all unlined ditches
          and basins,' and

        2f A reauirement for the interceptor wells to pump a minimum
         'of 1.5 million gallons per day (HGD) and submit monthly
          ground-water reports .


Due to the promulgation of HSVJA, NJDEP never signed the  AGO.  The
schedule for lining or eliminating the ditches and basins does not
coincide with the Federal requirements for retrofitting  by November
8, 1988.  Despite this, DuPont has been following the mandates of
the order.   Nevertheless, without an enforceable agreement such as
a signed AGO, DuPont is in violation of the Water Pollution Control
Act, N.J.S.A. 58:10A-1 et seo. for discharginq pollutants into
unlined ditches and basins, from which the pollutants may flow into
the ground waters of the State.   In addition, the eighty-six NJPDES
wells have  not been cited for RCRA purposes.


Fourteen wells in the vicinity surroundinq the Waste Water Basins
were designated as the PCRA interim status ground-water  monitoring
wells.  These are:  M-l, M-2, M-3, M-14, M-32, M-47, M-48, M-59, M-60,
M-61, M-67,  R5, and 1108.  The following describes the interim status
system in detail:


                                   91

-------
a. Background Wells:

   Two background wells are designated  for  the  KCRA  interim
   status ground-water monitoring  program.  One, M-53, is
   located approximately 750 ft from the  western side of "C"
   Basin, at plant coordinates North 5421,  East 2605.  It was
   originally designated as the upgradient  well for  the
   detection monitoring program.   With  the  on-set of the
   assessment program, M-32 was chosen  as a background well  in
   addition.  It is located approximately 4500  ft southeast  of
   the "A" Basin, at  the boundary  of the  plant's property.
   Both M-53 and M-32 have  mild steel casings and 304 stainless
   steel screens.  The screen fittings  are  unknown in M-32.
   M-53 is fit with "MPT" at the top, and a point fitting at the
 .  bottom.  M-53's screen is set from -9  ft to  -14 ft CWD.   The
   driller reports the screened interval  to have a lithology of
   "white and black sand" and "stones."  M-32 is screened from
   -5 ft to -10 ft CWD which is an interval described by the
   geologist as "sand, fine to medium,  yellow to reddish-brown,
   and clay, yellow and greenish-gray;  trace mica."  M-53 has a
   screen slot size of .015 inch and M-32 has a screen slot  size
   of .030 inch.  Both were drilled using mud rotary and developed
   by air lift.  The  filter pack material for both wells is
   unknown.  The annular sealant for M-53 is an unidentified
   cement and is unknown for M-32.

b. Downgradient Wells:

   The original wells chosen as downgradient from the Waste  Water
   Basins are M-14, M-48, M-59, M-60, and M-61.  The additional
   assessment wells chosen  are M-l, M-2,  M-3, M-47,  M-67, R5,
   and 1108.  M-14, M-48, M-59, M-60, and M-61  are all located
   along the perimeter of the "A"  Basin.  M-l,  M-2,  and M-3  are
   located approximately 2875 ft southeast  of the basins.
   M-47 is located 500 ft cast of  the basins.   M-67  is 11"25  ft
   south of the basins.  R5 is 3000 ft  south of the  basins.
   1108 is located 750 ft south of the  basins.  All  wells were
   drilled by mud rotary and developed  by air lift.  All
   casings are composed of  mild steel except for 1108, which
   is 316L stainless  steel.  All screens  are composed of 304
   stainless steel except for M-67 and  1108 which are 316L
   stainless steel.  M-47,  M-48, M-59,  M-60, M-61, and M-67
   have screens with  .020 inch slot size.  M-l, M-2, M-3 and
   M-14 have .030 inch slotted screens.  1108 has a  .045 inch
   slotted screen and R5 has a .060 slotted screen.
                              92

-------
  Chemical Waste "C" Landfill:
  The "C" Landfill is composed of three areas of five acres each with
  contiguous sides.   The areas are labeled I, II, and III and were constructed
  through time as needed.
      Area I was constructed in 1975 and filled-in in late 1978.   Its major
      design features include a single 30 mil "Hypalon" liner, a 0.3% slope,
      and a leachate system to pump leachate to the WTP.   The ton of Area I
      was covered with 2 feet of clav of 1 X 10-7 cm/sec permeability,
      12 inches of topsoil, and seeded.  The East slope was covered with 2 feet
      of 1 X 10-7 cm/sec clay and the South, North, and West slopes with
      1 1/2 feet of 1 X 10-5 cm/sec clay, covered with 1 foot of topsoil
      and seeded.
 II:   Area II was constructed adjoining Area I in 1978.   The major design
      provisions are:   installation of a double 30 mil "Hypalon" liner with
      a layer of sand  between the liners and 6 inches of sand and 6 inches
      of gravel on top of the liner, provisions for detection of leaks in the
      upper "Hypalon"  liner, provisions for collecting and pumping of leachate
      and rain run-off with the present system, and provisions for a 0.3%
      continuous slope.  Placement of sludge on this area began in January,
      1979.  Dikes around the second lift were built in  1981.
Ill:   Revision to the Closure Plan "C" Landfill on September 28,  1984 projects
      that the final cover on Area III will consist of 2 feet of  clay with a
      maximum permeability of 1 X 10-7 on/sec overlaid with 30 mil reinforced
      "Hypalon" liner, overlaid with 12 inches sand ASTM C144, overlaid with
      "Typar," overlaid with 18 inches earth fill SM or SC material,  overlaid
      overlaid with 6 inches topsoil that is seeded with grass seed.   (The
      identical final cover will be constructed on Area II).  Also on Area
      II as well as Area III, the side slopes wwill be constructed with 2
      feet of clay with maximum permeability of 1 X 10-7 cm/sec overlaid
      with 30 mil reinforced "Hypalon" liner, overlaid with 18 inches earth
      fill SM or SC material, overlaid with 6 inches topsoil that is  seeded
      with grass seed.
  The "C"  Landfill is monitored by four RCRA wells,  M-204,  M-241,  M-243,  and
  M-252.   A letter dated June 24,  1984, (comments on the Chambers  Works public
  notice  for NJPDES permit),  noted the replacement of M-239 with M-241.  The
  following describes the interim status system in detail:
                                        93

-------
   a. Background VJells:

      One background well has been designated  the RCRA  interim
      status ground-water monitoring  well,  H-252.  M-252 is
      located at plant coordinates North  8900,  East 7130.
      It is approximately 250 feet north  of the landfill's Area
      I.  Its total depth (measured from  around surface) is 20
      feet (ft).  It is screened  from -4  ft to -14 ft Chambers
      Works datum (CWD).  The driller completed the geologic log
      and reports the screened interval to  consist of sand.


   b. Downgradient Wells:

      Three wells are designated  as RCRA  downcjradient wells, M-204,
      M-241, and M-243.  M-204 is located at plant coordinates North
      8100, East 6900 on the southern perimeter of the  landfill,
      Area I.  Its total depth is 21  ft and it is screened at -2 ft
      through -12 ft CWD.  The driller reports the screened interval
      to consist of fine brown, gray  sand and  red sand.  M-241 is
      located at plant coordinates North  7670r East 7390 on the
      the southern perimeter of the landfill,  Area II.  Its total
      depth is 20 ft and it is screened at  -4  ft to -14 ft CWD.  The
      driller does not provide a  lithology  for the screened interval,
      M-243 is.located at plant coordinates North 7560, East 7540
      on the southern perimeter of the landfill bordering areas
      II and III.  Its total depth is 20  ft and it is screened
      at 0 ft to -10 ft CWD.  The driller reports the screened
      interval to consist of sand.


All wells were drilled using the  mud  rotary method and  are
constructed entirely of polyvinylchloride (PVC).  M-252 and M-204
have 4 inch casing and screen diameters.  M-241 and M-243 have 8 3/4
inch casing diameters and 4 inch  screen diameters.  All top
fittings of screens are coupled with the  exception of M-204 which
has a fitted joint.  The bottom fittings  of all wells have caps
with the exception of M-204 which has a fitted joint.   All filter
packs are composed of gravel II.   All annular  sealants  are cement
with the exception of M-204 which has unidentified pellets.  The
cement type is unidentified.  All wells were developed  by air
lift.  All screen slot sizes are  .020 inch.
                               94

-------
 Table 11.   RCRA Monitoring  Wells  - Waste Water  Basins
WELL #
DATE INSTALLED
PLANT COORDS'
North
East
DRILLING
METHOD
LOGGER
GEOPHYS LOGS
GROUND ELEV*
TOTAL DEPTH
CASING:
Maternal
Length
Di ameter
Top Elevation*
SCREEN:
Mat'!
Length
Di ameter
Slot
Top Elevation*
Bot Elevation*
Top Fitting
Bot Fitting
FILTER PACK:
Type
Si ze
ANNULUS:
Materi al
Quantity
DEVELOPMENT
STATIC WATER:
Level t
Date
53
12/73
5421
2605
MUD
ROTARY
DRILLER
-
6.73'
21'0"
STEEL
15'7"
2"
7.53'
304SS
5'7"
2"
.015"
-9
-14
MPT
POINT
«•
-
CEMENT
2 BAGS
AIR
LIFT
3.8'
3/86
14
2/2/67
4701
4590
MUD
ROTARY
DRILLER
-
7.93'
20' 11"
STEEL
19'6"
6"
11.03'
304SS
5'5"
6"
.030"
-8
-13
T-C
7
7
?
?
7
AIR
LIFT
-4.7'
3/86
48
9/9/72
5618
3073
MUD
ROTARY
DRILLER
-
9.10'
21'6"
STEEL
16'0"
6"
9.801"
304SS
5'0"
6"
.020"
-7
-12
FIPT
MIPT
GRAVEL
#1
?
?
AIR
LIFT
-2.23'
3/86
59
10/28/8T1
4830
5180
MUD
ROTARY
DRILLER
-
8.95'
19'6"
STEEL
16 '0"
6"
11.48'
304SS
5'0"
6"
.020"
-6
-11
FPT
PLATE
GRAVEL
7
CEMENT
2 BAGS
AIR
LIFT
-1.4'
3/86
60
10/29/81
4795
5900
MUD
ROTARY
DRILLER
-
8.12'
21!0"
STEEL
18'0"
6"
10.35'
304SS
5'0"
6"
.020"
-8
-13
FPT
PLATE
GRAVEL
#1
CEMENT
2 BAGS
AIR
LIFT
-1.97'
3/86
61
10/81
4400
6290
MUD
ROTARY
DRILLER
-
7.93'
21'0"
STEEL
18'0"
gTT—
9.951"
304SS
5'0"
6"
.020"
-8
-13
FPT
PLATE
GRAVEL
#1
CEMENT
2 BAGS
AIR
LIFT
-.42'
3/86
KEY;
     *
     t
none
Chambers Works Datum = USGS Datum +3.?6 ft
water level  above or below Chambers Works Datum
                                     95

-------















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96

-------
Table 13.  RCRA Monitoring  Wells  -  Chemical  Waste  "C"  Landfi
WELL *
DATE INSTALLED
PLANT COORDS:
North
East
DRILLING
METHOD
LOGGER
GEOPHYS LOGS
GROUND ELEV*
TOTAL DEPTH
CASING:
Material
Length
Di ameter
Top Elevation*
SCREEN:
Mat'l
Length
Di ameter
Slot
Top Elevation*
Rot Elevation*
Top Fitting
Bot Fitting
FILTER PACK:
Typp
Size
ANNULUS:
Mat^ri al
Quantity
DEVELOPMENT
STATIC WATER:
Levpl t
Date
252
10/28/81
8900
7130
MUD
ROTARY
DRILLER
-
5.91'
20'0"
PVC
12'6"
4"
8.70'
PVC
10'0Tr
4"
.020"
-4'
-14'
COUPLING
CAP
GRAVEL
FU 1
CEMENT
2 BAGS I
AIR
LIFT
4.52'
3/86
204
1/29/85
8100
6900
MUD
ROTARY
DRILLER
-
8.80'
21'0"
PVC
13'0"
4"
10.32'
PVC
lO'O"
4"
.020"
-2'
-12'
F.J.
F.J.
GRAVEL
#1
PELLETS
25 BAGS
AIR
LIFT
3.37'
3/86
241
9/20/78
7670
7390
MUD
ROTARY
DRILLER
-
6.70'
20 '0"
PVC
12'0"
8 3/4"
8.10'
PVC
10!0"
4"
.020"
-4'
-14'
COUPLING
CAP
GRAVEL
#1
CEMENT
5 BAGS
AIR
LIFT
2.92'
3/86
243
9/20/78
7560
7540
MUD
ROTARY
DRILLER
-
10.60'
20 '0"
PVC
12 '0"
8 3/4"
12.63'
PVC
10 '0"
4"
.020"
0'
-10'
COUPLING
CAP
GRAVEL
#1
CEMENT
5 BAGS
AIR
LIFT
3.01
3/86
 KEY:
     none
     Chambers Works Datum = USGS Datum +3.26 ft
     water level  above or below Chambers Works  Datum
                                     97

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The Interim Status Ground-Water Monitoring Program's Evolution
'into the 40 CFR Part 264 Ground-Water Monitoring Program
NJDEP sent a technical NOD for the around-water portion of the
Part B application to the Chambers Works on December 31,
1985. The reaulations which were not adequately technically
addressed according to the NOD are:

     1. N.J.A.C. 7:26-12.2(g)lb;

     2. N.J.A.C. 7:26-12.2(a)lc;

     3. N.J.A.C. 7:;26-12.2(q)ld;

     4 . N.J.A.C. 7:26-12,2(q)6a;

     5. N.J.A.C. 7:26-12.2(q)6b(i);

     6. N.J.A.C. 7:26-12.2(g)6b(iii);

     70 N.J.A.C. 7:14A-6.15(i);

     8. N.J.A.C. 7:26-12.2(q)7c;

     9. N.J.A.C. 7:26-12.2(q)7d;

     10. N.J.A.C. 7:26-12.2(q)7e;

     11. N.J.A.C. 7:26-12.2(q)7f;

     12. N.J.A.C. 7:14A-6.15(j);

     13. N.J.A.C. 7:26-12.2(q)8a;'

     14. N.J.A.C. 7:26-12.2(q)8b;

     15. N.J.A.C. 7:26-12 . 2(g)8c; and

     16. N.J.A.C. 7:14A-6.15(k).



NJDEP provided  the following comments  to  the  company;

     1. It.  is necessary  to submit  the  design  and  description
        of  each of the following wells:   M-l,  M-2,  M-3,  M-14,
        M-32, M-47, M-48,  M-53,  M-59,  M-60, M-61,  M-67,  R-5,
        1-108,  M-204, M-241, M-243,  and  M-2520  This  information
        shall include:   screen  depth,  casing  ard  screen  materials,
        screen  length, well  diameter and  borehole logs if available


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2. It is necessary for the permit application to include
   copies of all ground-water data obtained during the Interim
   Status period.  Quarterly samplina results for indicator
   parameters:  specific conductance, TOX, TOC,  and pH for
   the wells in detection monitorina (M-204, M-241, M-243,
   and M-252) for 1984 and 1985 should be submitted.

3. Results of all statistics reauired during Interim Status
   and a description of the procedure used.  Student-t results
   for the parameters and wells mentioned in item 2 shall be
   submitted for the years 1984 and 1985.

4. The indicator parameters proposed are not sufficient to
   monitor potential ground-water contamination  emanating from
   the landfill.  The following additional sampling are being
   proposed by the technical reviewer:  all priority pollutants
   except for pesticides twice per year for wells M-204, M-241,
   M-243, and M-252.  Continue to monitor for specific
   conductance, pH,  TOX, and TOC on a quarterly  basis.  As
   reauired by 7:14A-6.15 a student-t test shall be used on the
   four indicators mentioned above.

5. The contaminated  ground water surrounding the "A," "B," and
   "C" Basins has not been adequately characterized.  Additional
   wells are necessary between well M-53 and the Delaware River
   to determine the  direction of ground-water flow and the extent
   and degree of contamination.  New well locations to remedy
   this situation shall be proposed.  The Department recommends
   that J. Tesoriero of the Bureau of Ground Water Quality
   Management be contacted prior to drilling to  insure the
   proper location of the wells.  Also, well M-32 was intended
   to serve as a background well with which the  others could be
   compared.  This well is contaminated based on the recent
   N.J.A.C. 7:26-8.16 sampling (received December 1, 1985).
   DuPont must propose a new background well or  identify the
   source of the contamination of well M-32 as other than
   DuPont.

6. DuPont's proposed list of hazardous constituents for which
   compliance monitoring will be undertaken is grossly inadequate,
   The list of hazardous constituents for which  compliance
   monitoring will be undertaken must be in accordance with
   N.J.A.C. 7:14A-6.15(h) and 6.15(1).  As such  this list
   shall include all parameters in N.J.A.C. 7:26-8.16 (40 CFR
   Part 261, Appendix VIII) which are identified in the
   ground water.

7. Concentration limits must be proposed for each parameter
   on the list of hazardous constituents for which compliance
   (and corrective action) monitoring will be undertaken.
   These limits will be based on the criteria set forth in
   N.J.A.C. 7:14A-6.15(e).  Include a justification"for
   establishing any  alternate concentration limits.
                          99

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       The prooosed sampling, analysis and statistical comparison
       procedures need to be revised to include the additional
       parameters identified in item 6.

       The corrective action plan is deficient in the followina
       area:  it is likely that contaminated ground water in the
       shallow Glacial aauifer west of the equalization basins is
       not (and will not soon be) affected by the current pumpinq
       plan.  Recently installed interceptor well 108 affects the
       medium and deep Glacial aquifer but not the shallow.   The
       pumpinq proqram should be modified to address this situation
       The proper location of this new interceptor well will be
       aided by the installation of additional monitorinq wells
       (item 5) in this area.
NJDEP received the Chambers Works'  response to the December 31, 1985
ground-water technical NOD on March 15, 1986.   The responses are as
follows (and were incorporated into the RCRA Part B application):

    1. The additional information on the design and description
       of the monitorinq wells has been added to our RCRA Part
       B application as Exhibit F.

    2. The Quarterly sampling results for the indicator parameters
       for the "C" Landfill wells for 1984 and 1985 have been
       added to our Part B application as Exhibit G.

    3. The Student-t test results usinq the statistical methods
       recommended by the CMA have also been included in our
       Part B application as Exhibit G on paqe 9 of 9.  The use
       of the CMA Student-t test was approved in the letter from
       J.J. Trela to A.J. Boettler dated December 4, 1985.  The
       oriqinal backqround data for the upgradient well M-252 are
       for the period November 1, 1981 to December 31, 1982 as
       previously included in our Part B application in Exhibit A.
       The Student-t test results showed hiqh, significant t values
       for the 1984 and 1985 results from wells M-204 and M-252.
       The significance of these hiqh results Ls discussed in the
       letter from A.M. Pagano to F. Coolick dated February 26,
       1936 and on revised paae E-15 of our Part B application.

    4. Quarterly sampling of the four RCRA wells at "C" Landfill
       for the indicator parameters?  pH, specific conductivity,
       TOC, and TOX will be continued.  Four replicate measurements
       will be run annually based on the letter from J.J. Trela
       to A.J. Boettler dated February 26, 1986.  The significance
       of the results will be determined usinq the CMA Student-t
       test.
                              100

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   These indicators will be adeauate to follow the Quality
   of the ground water.  An annual scan for priority pollutants
   except pesticides will also be run.   Paqe E-14 of the Part
   B application has been revised accordingly.

   A priority pollutant scan was run in conjunction with an EPA
   sampling inspection on March 5, 1985.  The only constituents
   which were above the minimum detection limits were bis
   (2-ethylhexyl)  phthalate at less than 20 ug./l and napthalene
   at less than 3  ug./l as shown in,new Exhibit H of our Part
   B application.
5. As discussed with J. Tesoriero, a set of monitor wells will
   be installed alonq the Delaware River to access the ground-
   water flow and duality.  These wells include two wells that,
   are between M-53 and the river.  Page E-19 of our Part R
   application has been revised accordingly.

   Additional samplina of M-32 was done on December 16, 1985 and
   the results indicate the constituents with previously high
   values were not detected.  Thus, M-32 can continue to serve
   as the background well.


6. As discussed in our RCRA Part R application as revised paae
   E-21, s.ix well samples were analyzed for Appendix VIII
   constituents and the results were submitted to NJDEP on
   December 19, 1985.  The list of constituents found in
   these samples have been added to our Part R application.

   Although a large number of constituents were found, the
   history of analytical results for the past years shows very
   little change in these wells.  Quarterly analysis of all
   constituents found is not reasonable or justified.  We
   will continue Quarterly sampling for the indicator parameters
   and add the annual analysis for the Appendix VIII constituents.
   Paces E-21 and E-22 of the Part B application have been revised
   accord ingly.


7. Our goal concentration limits, for our corrective action
   program, will be based on the criteria set forth in N.J.A.C.
   7:14A-6.15(e).  If limits have not been specified by the
   NJDEP, the concentrations found in our background well M-32
   will be used.  Concentration limits based on these criteria
   are listed in new Table VIII pages E-21a and b of our Part
   B application.  Also page E-23 has been revised accordingly.


8. The Sampling, Analysis, and Statistical Procedures in our
   Part R application page E-28 have been revised to include
   the hazardous constituents discussed in item 6 and listed in
   our Part B application as Table VIII on E-21a and b.
                          101

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     9. As discussed in item 5,  additional monitor wells are being
        installed alonq the Delaware River to study the possible flow
        of contaminated around water toward the river.   Based on
        the results of analytical data and Dumping tests on three
        wells, the corrective action plan will be modified and
        additional interceptor wells installed as reguired.
NJDEP responded to the Chambers Works'  March 15,
March 27, 1986 with the following:
                                       1986  reply on
     With regard to item 5,  the location and number of additional
     wells proposed by DuPont to monitor the possible migration
     of contaminants towards the Delaware River meets with
     Department approval.  All seven wells should be installed
     within 45 days of this  letter.  Please contact this Bureau
     seven days prior to the installation of these wells.   while all
     of the remaining items  in our December 31, 1985 Technical NOD
     have been adeauately addressed, several additional area of
     concern need further information to complete this application.
          1
   M-243 at the "C"  Landfill has a water level higher than
   M-252 the intended upgradient well,   DuPont is reauired
   to assess this situation and determine the adeguacy
   of M-243 as a downgradient well.   To facilitate the
   review of the hydraulics of the landfill area DuPont
   is reauested to submit water level data for all the
   wells surrounding the "C" Landfill on a monthly schedule.
   The submission of this data should continue at this
   freguency until this matter has been resolved^

2.  Water level data  for the rest of  the wells on the site
   should be submitted to this Bureau on a guarterly
   schedule.  This information is reauested for the purposes
   of evaluating the adeguacy of the existing purge well
   system.
The Chambers
1986.  Their
   Works responded to the NJDEP's latter reply on May 12
   response to the items mentioned are as follows?
        Boundary Wells -- Four of the seven Delaware River monitor
        wells and all twelve 2-inch observation wells have already
        been installed.  The remaining three monitor wells will
        be installed within a few weeks after their well screens
        are received.  Because these wells will be used for future
        pump tests, the screens were not ordered until soil checks
        the observations wells were made to determine the maximum
        screen slot sizes.  S. Furda plans to visit the "plant
        while these wells are being installed.
                                                         of
                              102

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     2. Well Water Level Data -- Our data clearly shows that the
        water level of M-243 is definitely lower than our upgradient
        well M-252.  Thus, we reauest your approval to reduce the
        freauency for submitting monthly water level data for the
        "C" Landfill wells from monthly to guarterly.  Further,  .
        we reauest your approval to reduce the freguency for the
        other plant wells from guarterly to annually.  As S. Furda
        and A.J. Boettler have discussed, the first guarter "C"
        Landfill well levels will be submitted directly to S. Furda
        in a separate letter in the next few weeks rather than be
        attached to this letter.

                                                                *
In response to the May 12, 1986 reguest by DuPont to submit
ground-water level data for the Chemical Waste "C" Landfill wells
and the other plant wells on a guarterly and yearly basis, respectively,
the NJDEP approved it on May 19, 1986.  However, it was approved
based upon well water level data showing monitor well M-243 to be a
truely downgradient well.  In addition, NJDEP made the determination
that the Part B application is technically complete based on the
Chambers Works' responses to the NOD's.


Prior to a technically complete Part B application, NJDEP had
notified DuPont as to what the 40 CFR 264 (N.J.A.C. 7:14A-6.15)
ground-water monitoring program would be (February 26, 1986).  This
program is based on the interim status ground-water monitoring data
and the ground-water data submitted in the Part B application.
Therefore, as of February 26, 1986, the proposed Part R ground-water
monitoring program is a dual program; one system located at the
Waste Water Basins and the other system located at the Chemical
Waste "C" Landfill.  The programs are:

     1. Waste Water Basins:  Compliance and Corrective Action Monitoring

     2. Chemical Waste "C" Landfill:  Detection Monitoring

These programs are described in the March 15, 1986 revision of Section
E of the Part B application.
                                   103

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                       RESULTS AND DISCUSSION


The previous sections detail the complex regulatory history of
the RCRA and NJPDES programs, the resulting intricacy of EPA-II's
and NJDEP's roles, and the evolution of the Chambers Works' ground-
water monitoring programs.  As described,  EPA-II and NJDEP found
both ground-water monitoring systems to be in compliance with the
minimum reguirements of the interim status nround-water monitoring
regulations.  Where technical inadeguacies existed, NJDEP and/or
EPA-II prepared NOD's.  As part of the HWGWTF evaluation, the
"Characterization of Site Hydrology Worksheet" from the draft
version of the RCRA Ground-Water Monitoring Technical Enforcement
Guidance Document was utilized as a guide for establishing the
technical adeguacy -of the interim status programs.   The worksheet
answers are provided in the hydrogeologist's log book.  The
conclusion reached from the worksheet is that the sum total of
all hydrogeologic work carried out from 1966 to 1986 enable the
reviewer to gain a basic understanding of the site  hydrogeology.
A direct result of DuPont's early initiative in establishing a
ground-water monitoring and corrective action program is that all
of its components do not meet all of the standards  in present EPA
guidelines (see worksheet).  The Task Force inspection must view
those components as current inadeguacies.

The deficiencies arise from the complexities of the hydrogeology
at the site.  For RCRA ground-water monitoring purposes, it is
essential to identify the most likely zones of contaminant
migration, including both horizontal and vertical flow paths.
This insures proper well placement for the immediate detection of
contaminant leakage in detection monitoring and the identification
of the rate and extent of contaminant plumes in assessment
monitoring.  Due to the existance of one hundred and eight New
Jersey Pollutant Discharge Elimination System (NJPDES) wells,
DuPont meets physical compliance with the intent of the minimum
RCR^ interim status ground-water monitoring regulations.  The
technical problems inherent in the hydrogeologic nrogram are
described below and reflect Task Force evaluations  of the on-going
detection, assessment, and corrective action programs.

Hydrogeology

The hydrogeologic site investigation at the Chambers Works has
been an on-going process since 1966 when the first monitor wells
were drilled.  However, it has never been a formalized, phased
study as recommended  in the EPA manual 330/9-81-002, "Ground-Water/
Subsurface Investigations at Hazardous Waste Sites,,"  Instead,
over the years, as monitor wells were drilled and  Installed, bore
logs were recorded.  The  lithologic  information contained  in the
bore loqs is very general and the mineralogy, petrography, and
geochemistry of the geologic units are not defined.  Conseguently,
the effects of contaminated ground water on the confining  properties
of the clay and silt units are unknown, permeability and porosity
are unknown (although two aguifer tests were performed which


                                  104

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provide estimates for some regions of the uppermost aquifer), and
since no grain size analyses were documented on the loqs , the
selection of appropriate screen slot sizes is Questionable.
Despite this, a general depiction of the subsurface has been
ascertained with aid from the published literature.

The subsurface is a complex sequence of recent alluvial and tidal
marsh deposits, Pleistocene fluvioqlacial deposits, and Cretaceous
marine cyclic deposits.  These sedimentary environments show
variable lateral discontinuity and qive rise to a multi-aquifer
system.  Superimposed on the naturally complicated multi-aquifer
ground-water flow regime is a two-fold alteration.  This is the
regional pumping of the Cretaceous aquifers and the site-wide
pumping of the Quaternary aguifers.  The regional pumping has
created widespread cones of depression which are reported to
elicit a forty to fifty foot decrease in head level from the
natural head level.  The site-wide pumping system utilizes three
to six interceptor wells which combine to discharge 1.5 million
gallons per day (MGD).  Flow paths and gradients are dependent
upon which interceptor wells are in use.  These paths and gradients
will vary when the centers of pumping change. -Other fluxes are
created by the unlined basins, unlined ditch system, the Delaware
River, Henby Creek, Whoopinq John Creek, and the Salem Canal.

DuPont attempted to define this hydroloqic system through two
aquifer tests.  The first was conducted in 1971 and the second
in 1982.  The third was performed post-Task Force and the results
have not yet been transmitted to EPA-II.  The 19"7! test concentrated
soley on the Glacial aquifer system, shallow, middle, and deep
zones.  The test wells were 1-101, 1-102, and R-5.  The results
demonstrated interconnection of the three zones, although the
interconnections varied.  An example of the variation is shown in
the contrasting results for wells 1-101 and 1-102.  Note that
1-101 and 1-102 are located twenty-five feet apart.  1-101 is
screened in the deep zone.  The pumping from this zone did not
affect the observation wells screened the the shallow or middle
zones.  However, 1-102, screened in the middle zone, affected
these same observation * we 11s in the shallow and the deep zone.
Therefore, in some areas, the three zones are interconnected.

The 1982 aquifer test was performed using two test wells, WS-2 and
WS-3 in two separate 72 hour tests.  WS-2 is screened in the shallow
Potomac-Raritan-Magothy aquifer zone while WS-3 is screened in
the deep Potomac-Raritan-Maqothy aquifer zone.  Observation wells
for the tests were screened in the deep and shallow Potomac-Raritan-
Magothy aquifer zones and the deep Glacial zone.  The test using
WS-3 did not create drawdown in the deep glacial or shallow
Potomac-Raritan-Magothy aquifer wells.  The test using WS-2 gave
DuPont's consultant (LBG) the conclusion that there is no inter-
connection between the shallow and deep Potomac-Raritan-Magothy
and deep Glacial aguifers.  However, the report further describes
a situation which indicates partial clogging of the well screens
at both test wells.  In 1966, the average pumping rate of WS-3
was 600 GPM.  Its 24 hour specific capacity was 4.4 GPM/FT DD.


                                  105

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 In  1982,  the  Dumping  rate was 491 GPM with a 24 hour specific
 capacity  of 2.4 GPM/FT DD.   In  1965, WS-2 yielded a 24 hour
 specific  capacity of  19 GPM/FT  DD.  In  1982 the 24 hour specific
 capacity  was  9.8 GPM/FT DD.  Therefore, these aauifer tests may
 not  be  representative of the true aauifer characteristics due to
 partial cloqainq of the screens.  The hydraulic or lack of hydraulic
 interconnection between the  Glacial aauifer system and the Potomac-
 Raritan-Magothy aauifer system  cannot,  as yet, be adequately
 determi ned.

 These aquifer tests,  along with  the general geologic information,
 is enough to  indicate the presence of aguitards and possibly aauicludes
 However,  the  extent and characteristics of these ccnfining units
 and  lenses have not been sufficiently defined for RCRA ground-
 water monitoring purposes.   In  addition, although a total of
 approximately 157 wells (RCRA and NJPDES) existed on site at the
 time of the Task Force inspection, these do not provide adeauate
 data on all portions  of the  uppermost aauifer.  Ground-water flow
 has  been  most accurately defined  in the shallow Glacial zone
 along the eastern and southern  reqions  of the site, particularly
 southeast of  the Waste Water Basins.  However, the shallow Glacial
 zone's  flow is not defined west  of the  "C" Landfill and Waste
 Water Basins  alonq the perimeter  of the Delaware River.  There  is
 also a  lack of data in the region north and east of the "C"
 Landfill  as well as northeast of  the Waste Water Basins.  The
-middle  and deep Glacial aauifer  zones are more poorly defined in
 all  of  these  sectors.  The Potomac-Raritan-Magothy aquifer system
 has  even  fewer water  level monitorinq points.  Of note is post-Task
 Force well installation on-site,  alonq  the Delaware River, to better
 define  the hydrology  and modify  the corrective action program.

 This complex  hydroqeologic system warrants a more comprehensive
 ground-water  monitoring program  than the minimum RCRA interim
 status  system would provide.  Accurate  well placement for both
 detection and assessment monitoring is  dependent upon precise
 hydrogeologic data.   In a hydrologic system where centers of
 pumping change, the ground-water  monitoring system must be all
 encompassing  or pliable enough  to adjust to changes, in ground-
 water flow directions.  Upgradient (background) and downgradient
 well placements must  be valid for all circumstances;.  At the time
 of the  Task Force inspection, flow directions and interrelationships
 between aguifer zones were not  quantified for the changing
 situations.   This problem is documented at the "C" Landfill's
 backqrond well, M-252.  On various occasions, M-252 was found to
 have lower head elevations than a designated downgradient well.
 Remeasurements at other times would show no problem with the
 designated upqradient and downqradient  wells.  It is possible
 that different interceptor wells  were operating on these different
 occasions, changing the hydraulic gradients.  A derivative of
 this problem  may be the significant CMA Student's t-test results
 at  this well. Currently, technical notice of deficiencies  (NOD)
 on  the  Part B application has addressed the problem at M-252 by
 reguiring DuPont to check water level data more frequently.  This
 is  inadequate and must be amended to include a complete hydrogeoloqic

                                  106

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study of the interrelated aauifer zones and changes created due
to changes in Dumping conditions.  Of note is a current study
underway due to an information reauest from EPA-II with regard to
a HSWA waiver request.

Detection Monitoring Program

The "C" Landfill was in the detection monitoring mode at the time
of the Task force inspection.  Four wells surrounding the landfill
were designated the RCRA wells.  The ungradient well is M-252 and
the downgradient wells are M-204, M-241, and M-243.  All are
screened in the shallow Glacial zone.  Since the shallow Glacial
zone constitutes only one zone of the uppermost aguifer, additional
upgradient and corresponding downgradient wells must be installed
to enable monitoring of the entire uppermost aguifer.  As a result,
the Task Force has determined that the landfill should be in the
assessment mode due to significant landfill waste contaminants
found in downgradient well M-204.  Inspection of past records
found that both M-252 and M-204 failed the Student's t-test and
CMA Student's t-test in 1983, 1984, and 1985.  However, it wasn't
until 1985 that EPA-HQ approved the use of the CMA test.  Since
that time, DuPont reguested a delisting of Area I of the landfill
on the basis that it was closed in 1978.  Along with the delisting
request, DuPont submitted a Ground-Water Quality Assessment
Program plan for Area I since their consultants determined that
the failed student's t-tests at M-204 was caused solely by leakage
from Area I.  Currently, NJDEP is evaluating the delisting request.
The consequence of this determination will either triqqer the
entire landfill into assessment monitoring or keep areas II and
III in detection while Area I will be treated as a solid waste
management unit (SWMU) and undergo corrective action under the
authority of HSWA.

In addition to the detection monitoring program, 18 additional
wells are monitored under the auspices of the NJPDES Permit.
four wells were also installed as part of the Ground-Water Quality
Assessment Program plan.  All of these wells are screened in the
shallow Glacial zone except for three which are screened in the
middle Glacial zone.

The Task Force's findings indicate a need for DuPont to monitor
all zones of the uppermost aquifer under all hydraulic conditions.
Additional background wells must be installed in these zones
(middle and deep Glacial aquifers and shallow Potomac-Raritan-
Magothy aguifer) along with corresponding downqradient wells in
positions adequate for detection monitorinq and/or assessment
moni toring.

Assessment Monitoring Program

The Waste Water Basins/Ditch System unit was in the assessment
mode at the time of the Task Force inspection.  The original
wells chosen as the downgradient RCRA wells, M-14, M-48, M-59,
M-60, and M-61, are all screened in the shallow Glacial zone, as

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is the original background well, M-53.  Additional downqradient
wells, M-l, M-2, M-3, M-47, M-67, R5, and 1108, and a background
well, M-32, were cited as RCRA wells when the unit triggered into
assessment monitoring.  These wells were chosen in an agreed upon
modified sampling program submitted in lieu of a Ground-Water
Quality Assessment Program plan as reauired under §265.93(d)2
between DuPont, NJDEP, and EPA-II.  This modified sampling program
also included the use of the NJPDES permit ground-water monitoring
programs.  The background wells are screened only in the shallow
glacial zone.  Only M-47 and M-67 of the designated assessment
wells may be used to compare ground-water guality.  Again, this
is only one zone of the uppermost aguifer.  The Task Force
recommends the incorporation of the 86 NJPDES wells with adeguate
construction and records into the RCRA system.  All aauifer zones
must be represented bv background wells and downgradient wells
and must be valid for all the possible hydrologic circumstances
(changing centers of pumping).  Only when the system meets those
criterias, can the assessment program adeguately define the rate
and extent of contaminant migration.
Well Construction

At the Chemical Waste "C" Landfill, all RCRA wells were drilled
using the mud rotary method and are constructed entirely of
polyvinylchloride (PVC).  M-252 and M-204 have 4 inch casing
screen diameters.  All top fittings of screens are coupled with
the exception of M-204 which has a fitted joint.  The bottom
fittings of all wells have caps with the exception of M-204 which
has a fitted joint.  All filter packs are composed of gravel #1.
All annular sealants are cement with the exception of M-204 which
has unidentified pellets.  The cement type is unidentified.  All
wells were developed by air lift.  All screen slot sizes are .020
inch,.  The bore logs were written by the driller in all cases.

At the Waste Water Basins, all RCRA wells were alsc drilled using
the mud rotary method.  Al_l wells are cased with mild steel with
the exception of 1108 which is cased with 316L stainless steel.
All well screens are composed of 304 stainless steel except for
M-67 and 1108 which are 316L stainless steel.  M-53 is a 2 inch well
M-32 is a 4 inch well, R5 and 1108 are 12 inch wells, and the
remainder are 6 inch wells.  The top and bottom fittings of the
screens vary according to the wells as do the slot sizes.  Slot
sizes vary from .015 inch to .060 inch.  Filter pack materials,
where reported, are either gravel #1 or gravel #2.  The annular
sealants, where reported, are either an unidentified cement or
unidentified pellets.  As at the landfill, the wells were developed
by air lift.  The bore logs were written by the driller in all
cases with the exception of M-32, M-67, and 1108.  In addition a
geophysical log (gamma ray) exists for 1108.
                                  108

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Mud rotary is an acceptable technique for drilling in unconsolidated
glacial formations.  However, the muds may affect ground-water
guality and borehole samples.  The mud used when drillina these
RCRA wells was not identified on the well log.  Therefore, its
effects on ground water and borehole samples has not been
guantified. For future mud rotary drilling, it is recommended
that the mud is identified and its effects on ground water and
borehole samples is ascertained.  In addition, a gualified
geologist or geotechnical engineer must be present to log the cores.
At this site, since a driller did the majority of the logging,
specific and accurate lithologies were not obtained.  In addition,
since no grain size analyses were documented as being performed,
the selection of appropriate screen slot sizes is guestionable.
Field measurements obtained by the Task Force prior to collecting
groung-water samples (depth to well bottom, top of casing to
ground level, water level) show the possibility of either an
error in the reported well depths or the silting in of some well
screens. The silting in of well screens indicates a poor choice
in screen slot size.  However, re-development of such a well
prior to sampling could be a corrective measure to be used in all
future sampling events.

Well construction details on well logs do not fully correspond
with the construction details submitted in the original Part B
application. The well logs indicate gravel #1, gravel 12, unidentified
cement and pellets as filter pack material.  The Part B describes
all filter packs as washed, coarse sand.  The well logs indicate
cement or pellets as the annular sealant.  The Part B reports
bentonite seals.  The well logs show either PVC casings with PVC
slotted screens or mild steel casings with stainless steel slotted
screens.  The Part B diagrams illustrate all screens to be
constructed of PVC.  The screen slot sizes in the Part B diagrams
are uniformly .020 inch.  The well logs show slot sizes varying
from .015 inch to .060 inch.  Future drilling and well installation
must utilize both a licensed driller and geologist and complete,
detailed "as-built" well diagrams and borehole logs.  A Part B
ground-water section re-submission was received by EPA-II after
the Task Force inspection.  Instead of the original Part B well
construction figures were the original well logs completed in the
field.  However, the problems with these logs still exist.
Despite this, these wells are intact and yield sufficient water
for sampling.  Future wells must be installed to present RCRA
standards with specific and detailed "as-builts."

Appendix VIII Water Quality Data

DuPont contends that the uppermost 120' - 130' of the site's
subsurface is contaminated with industrial hazardous waste and
hazardous waste constituents.  This contamination has been addressed
by DuPont, starting with their hydrogeologic investigation in
1966.   However,  the 1977 annual progress report gives an account
of contamination in the shallow Potomac-Raritan-Magothy aguifer
zone.   Monitor wells M-45 and M-45A exhibited increased TDS.
DuPont believed that the cause was the migration of contaminated

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Glacial aauifer system water through corroded well casinqs of
abandoned and existing Potomac-Raritan-Magothy aguLfer wells
and/or through improperly sealed annular spaces of these wells.
DuPont pumped M-45A for about 60 days in 1978 with the assumption
that if corroded casings/leaky seals were responsible, continuous
pumping would recover the contaminants.  After the 60 days,
however, TDS in M-45A remained high (563 mg/1).  DuPont sealed
both M-45 and M-45A since the integrity of the casxngs could
not be verified by them.  Subseguently, M-45B, M-45C, and
M-45D were installed.  M-45B is screened in the deen Potomac-
Raritan-Magothv aguifer zone while both M-45C and M-45D are
screened in the shallow Potomac-Raritan-Magothv aguifer zone.
M-45C came up with elevated levels of TDS, TOC, DOC, and TOX.
High TDS values found in M-45B were not accompanied by high
TOC, DOC, and TOX values.  DuPont decided that M-43B's elevated
TDS was did not indicate industrial contamination.  The DOC
and TOX values in M-45B were at background levels ( TDS <_ 200
mg/1, TOX £0.1 mg/1, DOC £ 10 mg/1).  TDS values nust be
analyzed with TOC, DOC, and TOX because in a region influenced
by s.alt-water encroachment, TDS values may reflect levels of
salts in the ground water from natural sources.

The latest available progress report, 1985, still reports
contamination at M-45C, but a decreasing trend.  In 1983, TDS
was at 1265 mg/1 while in 1985 it was at 839 mq/1.  DOC
declined from 32 mg/1 in 1982 to 18 mg/1 in 1985.  TOX
decreased from 1.1 mg/1 in 1982 to 0.6 mg/1 in 1985.  M-45B
and M-45D do not show any evidence of industrial contamination«
DuPont therefore concluded that M-45C is contaminated by
lateral movement of contaminants from abandoned and unsealed
wells. Interestingly, WS-1, WS-1-1, WS-1-2, WS-1-3 screened
in the shallow Potomac-Raritan-Magothy aguifer zone have
shown increasing trends in TDS, DOC, TOX, and chloride.  DOC
and TOX values are below background but DuPont reports that
the TDS increase due to the chloride increases from salt-water
intrusion from the Delaware Estuary, correlating with this
worker's conclusion of the effects on salt-water encroachment
at this site.  Similar trends appeared at WS-2 and its observation
wells.  Deep Potomac-Raritan-Magothv aguifer zone well M-93 had a
high TDS value but the screen became clogged and DuPont had  it
sealed.  Shallow Potomac-Raritan-Magothy aguifer zone well M-92
also had an increase in TDS between 1983 and 1984, 235 mg/1
to 550 mg/1.

It is evident at this site, which is hydraulically influenced
by the Delaware Estuary, that TDS cannot be used as an indicator
of industrial contamination on its own merits  TOCr DOC, and/or
TOX must also be evaluated.  It must be noted that DuPont uses
TDS alone to illustrate the effects of the corrective action
program on the site in their letter to EPA-HO reguesting a
waiver on 1/17/86.  Despite the guestions raised about the
indicator parameters and what they actually show,  it  is apparent
that the shallow Potomac-Raritan-Magothy aguifer zone in the
region of M-45C, WS-1, and WS-2 show the possibility  of industrial
contamination,.  This possibility can only be verified by sampling

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for actual DuPont characteristic hazardous waste or hazardous
waste constituents as was done by the Task Force.  The assessment
program currently in phase on the site should have included
shallow Potomac-Raritan-Maqothy aquifer zone wells, and even a
deep Potomac-Raritan-Maqothy aquifer zone well. If industrial
contamination is in fact found, then these specific contaminants
and their concentrations can be used to identify the source and
flow path of the plume.  This would also help in the determination
of whether the Potomac-Raritan-Maqothy aquifer system is hydraulically
connected naturally, or by man-made mechanisms such as improperly
abandoned wells.

Corrective Action

The interceptor well corrective action proqram was initially
designed to remediate the effects of previous company practices.
Present Agency concerns reflect all contamination, whether from
past practices and SWMU's or operatinq RCRA interim status units.
NJDEP and DRBC are in receipt of twelve annual reports from
DuPont which evaluate the interceptor well corrective action
proqram.  An in depth inspection of the latest report will provide
the company's case for the effect of their proqram; the interceptor
well system effectively contains and removes contaminated qround
water from the Glacial aquifer zones within the property boundaries
of the Chambers Works.

The followinq summarizes the pertinent points made in the
1985 Annual Proqress Report:

    1. The flow of ground water in the shallow Glacial zone
       throughout a major portion of the Chambers Works is
       controlled by I102A and I103A.  That is, ground water
       flows towards these wells in the northern, eastern, and
       most of the southern sections of the plant.  However,
       there is westerly flow alonq the Delaware Estuary and
       some southerly flow west of the dam on Salem Canal.
       Therefore, in an area of approximately 0.2 square mile,
       ground-water flow in the shallow zone appears not to be
       captured by the interceptor well system.

    2. The flow of qround water in the middle and deep Glacial
       zones is adequately controlled over the entire Chambers
       Works area by the operation of I102A, I103A, and R5.

    3. 1106 and 1108 have no measurable effect on the shallow
       Glacial aquifer zone.  However, 1108 has a considerable
       effect on the middle and deep Glacial aquifer zones.

    4. Data for the "C" Landfill wells show that the cone of
       depression caused by the inerceptor well system extends
       in a northerly direction at least as far as that unit.
                                  Ill

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 5, Background indicator parameter values:   TDS _< 200 mg/1,
    DOC <_ 10 mq/1,  TOX £ 0.1 mg/1.

 6. M-22 and M-40 (middle Glacial zone)  show increasing
    TDS trends which contrast with the results for other
    peripheral wells.

 7. Nearly all interior wells continue to exhibit relatively
    high levels of  contamination.  However,  CP-5 shows background
    levels for the  indicator parameters.   M-l, M-49,  M-9,  M-10,
    and M-ll show declining trends.  M-12,  M-13,, and  M-14  show
    increasina trends  in TDS, DOC, and TOX.   These trends  are not
    meaningful, however, since pumpage of the  interceptor  well
    system moves ground water from place  to  place and causes
    various chemicals  to move also.

 8. The eight wells located outside plant boundaries
    continue to show background levels of the  contaminant
    indicator parameters.

 90 A comparison of 1970 and 1985 TDS contour  maps shows
    the positive effectiveness of the interceptor well system.

10, Conditions of the  Potomac-Rar'i tan-Magothy  aouifer system:

    a. Seven additional wells were installed since 1979, three
       in the deep  zone (M-45B, M-91, M-93 )  and four  in the
       shallow zone (M-45C, M-45D, M-92,  M-94 )

    b. Although there  were no changes in  the Atlantic City
       Electric Company's (ACEC)  pumping, the  focus of shallow
       zone ground-water flow has shifted from the ACEC well
       field to an  area somewhat  to the east.   It is  tentatively
       concluded that  there have  been errors in measurement.

    c. M-4SC (shallow) is the only well which  has consistantly
       shown evidence  of contamination by industrial  chemicals.
       However, since  1983, there has been a reduction in  TDS,
       DOC „ and TOX.  M-45B and M-45D show background levels.
       The conclusion  is that M-45C is being contaminated  by the
       lateral movement of contaminants from abandoned and unsealed
       wells.

    d. WS-1, WS-1-1, WS-1-2, WS-1-3  (shallow)  show increasing
       trends in TDS,  DOC, TOX, and chloride.   DOC and TOX
       are within background range.  The  TDS increase may  be
       almost entirely the result of chloride increases due to
       intrusion from  the Delaware Estuary.

    e- WS-2, WS-2-1, WS-2-2, WS-2-3, WS-2-4, WS-2-5 show increases
       in TOX.  Only WS-2 and WS-2-1 are  above background   (0.16 and
       0.65 respectively).  WS-2-4 shows  a large increase   in TDS
       as well as a similar increase in chloride.
                               112

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       f. M-93 (deep)  showed a very high TDS then became clogged.
          It was subsequently sealed.

       g. The off-plant Potomac-Raritan-Magothy aquifer zone wells
          remain uncontaminated.


Therefore, the company has concluded  that their program is working
overall, needs adjustment in the  shallow Glacial zone in a 0.2
square mile area of the plant, and no work need be done
regarding the Potomac-Raritan-Magothy aquifer system.  It is
the contention of the  Agency that the data available at the time
of the Task Force investigation does  not indicate that the corrective
action program is working overall.  The Agency cannot make any
assumptions on inconclusive data.  A  number of discrepencies appear
between the scientific philosophies followed by the company
in the twelve annual reports.  These  are as follows:

       1. Ground-water level contour  maps are drawn with the same
          precision for each aquifer  zone.  However, different
          numbers of data points  exist for each zone.  That is,
          122 wells were measured.  About 46 of these monitor the
          shallow Glacial zone, about 19 monitor the middle
          Glacial zone, and about 18  monitor the deep Glacial
          zone (these  figures represent 82.8% of the 122 wells
          measured in  March, 1986; 17.2% of the wells could not
          be identified by aquifer zone) .  The contour maps for
          the shallow  Glacial zone are the most accurate for this
          reason.  The middle and deep Glacial zones require more
          interpolation as do the contour maps for the shallow
          and deep Potomac-Raritan-Magothy aquifer zone wells (15
          and 3 wells  respectively).

       2. No attempt at defining  vertical gradients is made, other
          than discounting the interconnections between the zones
          by the two aquifer tests (see previous section) .

       3. TDS is used  as the indicator parameter for industrial
          contamination in some cases and not in others.  Salt water
          intrusion (increasing chloride content) is considered a
          factor affecting TDS levels only in the Potomac-Raritan-
          Magothy aquifer system.  However, it is the contour maps for
          the middle and deep Glacial aquifer zones where recharge from
          the Delaware Estuary is depicted.  Further, TDS trends have
          been used throughout the reports to demonstrate the effectivene
          of the corrective action  program.  The latest report instructs
          the reader to discount  the  TDS trends in the interior wells
          due to the pumping while using it as an indicator for the
          peripheral and off-site wells.  Up until that report, it was
          understood that the peripheral wells were also affected by
          the pumping.  The company must explain how TDS' trends are
                                  113

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        reliable at the plant's property boundaries and not at the
        plant's interior; the contour maps show radial flow, inward
        toward the pumping wells, affecting all areas of the system
        in the same physical manner.  As stated in the previous
        section, TDS cannot be used alone as an indicator of industrial
        contaminati on.
Since it has been determined that the TDS contour maps
cannot be used solely to determine the effectiveness of the
corrective action program, some other overall method must
be utilized.  This niethod must include examining the purge
well volumes, the areas of influence of the cones of depression,
and the concentrations and locations of the hazardous waste
and hazardous waste constituents.  This method should have been
incorporated into the assessment monitoring program and is
ciddressed in a post-Task Force technical NOD from EPA-II to DuPont
in response to the waiver request.

It is evident from figures 21 through 26 that through time,
the cones of depression influenced larger sectors on- and off-
site.  This effect is due to both an increase in purge volumes
(almost double from 1977 to 1985) and the time span the purge
wells have been operating.  The purge wells, according to the
theory of this corrective action program, should be pulling
contamination in from off-site tha't previously escaped, and
keep more recent contamination from escaping.  Since TDS doesn't
provide sufficient informtion on this, it is obvious that the
DuPont characteristic waste must be looked at.  This Task Force
has two ways of looking at this.  One is throuch an Appendix
VIII sampling performed by DuPont as part of their assessment
monitoring requirements and the other is through the independent
sampling program carried out by the Task Force=

Table 10 provides the Appendix VIII constituents found at or
in excess of 10 ppb at the assessment monitoring wells.  For
ease in evaluation these constituents have been subdivided
into the following groups:  benzene and benzene derivatives,
ionic metals, other metals, nitrated hydrocarbons, and chlorinated
hydrocarbons.  Each constituent was then plotted up on a bar
graph to illustrate its location and concentration in the
glacial aquifer system.  Unfortunately, no sampling points
exist for this study in the Potomac-Raritan-Magothy aquifer
system.  The following summarizes what was foundt
                                  114

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                Benzene ft Benzene Derivatives

a. Toluene achieves its highest concentration at the shallowest
   sampling point (M-67)  and occurs with benzene and phenol;

b. Off-site well, M-32, only has benzene;

c. Purge well 1108 intercepts benzene, toluene,  and naphthalene;

d. Purge well R5 intercepts benzene and toluene;

e. The deepest sampling point, the M-l, M-2, & M-3 composite (M123)
   shows all five constituents:  benzene, toluene, naphthalene,
   phenol, and p-benzoquinone; and

f. Benzene and toluene exist together at M-47.
                       Ionic Metals

a. Sodium achieves its highest concentration at purge well 1108;

b. Sodium exists at the highest concentrations at all sampling
   points except for M-32, the off-site well;

c. Calcium exists at all sampling points as well and achieves
   its highest concentration at purge well 1108;

d. Calcium is the second most prevalent in concentration of the
   ionic metals at all wells but M-32, where it is the highest
   concentrated ionic metal;

e. Potassium exists at all sampling points and is the third
   highest in concentration at all points;

f. Potassium achieves its highest concentration at the deepest
   sampling point, M123;

g. Strontium shows up at all sampling points but M-32, the off-site
   well ; and

h. Osmium only shows up at purge well 1108.
                              115

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                     Other Metals

a. Iron exists at all sampling points, existing at its
   highest concentration at purge well R5;

bo Arsenic exists at only the deepest sampling point, M123;

c. Lead occurs only at purge well 1108;

d. Chromium occurs only at the shallowest sampling point;

e. Cyanide exists only at the deepest (M123)  and shallowest
   (M-67)  sampling points;

f. Aluminum exists at only two locations, the deepest (M123)  and
   the shallowest (M-67) sampling points.  Its concentration is
   highest in the shallow zone ;

g. Nickel  occurs only at the shallowest sampling point,  M-67;

h. Vanadium exists at only the deepest (M123) and shallowest (M-6~?)
   sampling points; and

i. Zinc occurs only at the deepest (M123) and shallowest (M-67)
   sampling points.


                  Nitrated Hydrocarbons

a. Aniline occurs at all sampling points except for the
   off-site well, M-32;

b. m-Dinitrobenzene occurs at M-67 fi. M-47 only;

c. 2,4 Dimtrotoluene occurs at only the shallowest sampling point,
   M- 6 7 ;

do 2,6 Dinitrotoluene occurs at its highest concentration  at
   the shallowest sampling point  (M-67).  The only other place
   it occurs is at M-47;

e. Nitrobenzene occurs at M-47, purge well R5, and the 'deepest
   sampling point, M123o  Its highest concentration is at  purge
   well R5;

f. o-Toluidine occurs at all sampling points except for  R5
   and M-32.  Its highest concentration  is at the deepest  sampling"
   point,  Ml 23;

g. N-nitrosopyrolidine occurs at off-site well M-32 only;

he 1-Naphthylamine occurs at purge well  1108 only? and

i<, 5-Nitro-o-toluidine occurs at purge well,  1108 only.

                              116

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             Chlorinated Hydrocarbons

a. Chlorobenzene occurs at all sampling points;

b. Chloroaniline occurs at M-47, R5, and M123;

c. 1,2 Dichlorobenzene occurs at all sampling points;

d. 1,3 Dichlorobenzene occurs at the deepest sampling points only,
   purge well R5 and M123;

e. 1,4 Dichlorobenzene occurs at M-67, purge well 1108,
   purge well R5, and M123; that is, the shallowest and the
   deepest sampling points;

f. Freon-TF occurs at off-site well M-32, purge well 1108, and
   M123;

g„ Trichloroethylene also occurs at M-32, 1108, and M123;

h. 1,2,4 Trichlorobenzene occurs at M-32 and purge well R5;

i. Chloroform occurs only in the deeper sampling points,
   purge wells R5 and 1108, and M123;

j. 1,2 Dichloroethane also shows up at only the deeper sampling
   points; at purge wells 1108 and R5;

k. 1,2 Trans Dichloroethylene occurs only at the deeper sampling
   points; at 1108 and M123;

1. Methylene chloride occurs only at the deeper points, purge wells
   1108 and R5,  and M123;

m. Tetrachloroethylene occurs only at 1108 and M123;

n. Trichlorof1uoroethylene also occurs at only 1108 and M123; and

o. Vinyl chloride only shows up at M123.
                              117

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The limiting factors of data collected for a study performed
during this type of corrective action are evident when trying to
evaluate the results.  As standard, the data set represents the
ground water matrix only at the one fraction of time that the
data was collected.  As only specific to this data set from this
site, it is dependent upon the number, location, and purge volumes
at that fraction of time.  With this in context, the data will be
broken down further:


             Off-Site Well(N-32)/Shallow Glacial Zone


    1. Benzene is the only contaminant from the benzene and
       benzene derivatives group;

    2. All listed ionic metals are found except for osmium;

    3. Iron is the only other metal found;

    4. Of the nitrated hydrocarbons, only N-nitrosopyrolidine is found;

    5. Of the chlorinated hydrocarbons, only 1,2 dichlorobenzene,
       chlorobenzene, freon-TF, 1,2,4 trichlorobenzene , and
       trichloroethylene are found; and

    6. The benzene and benzene derivative group, the ionic and
       other metals group, the chlorinated and nitrated hydrocarbon
       group where in existance at the off-site well, are at a
       considerably lower concentration than at the on-site wells  (exce]
       N-nitrosopyrolid me which is found only at the off-site well).
    From this one data set, the conclusion is that the pumping system
    is working to some degree in the shallow glacial zone at the
    site of M-32.  Nothing can be ascertained about the middle
    and deep Glacial zones or the Potomac-Raritan-Magothy aquifer
    system from this data on the shallow Glacial zone at the site of
    M-32.

    With the application for the double-liner waiver request for the
    Waste Water Basins, EPA-II demanded that DuPont perform a more
    comprehensive study to show the effectiveness of their "corrective
    action program" in order to demonstrate compliance with the
    requirements of section 3005(j)(13).  As previously stated, this
    was the technical NOD in response to the DuPont letter to EPA-HQ
    of 1/17/86.
                                   ,18

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Bauersfeld, W.R., Moshlnsky, E.W., Pustay,  E.A.,  and  Schaefer,  F.L.,
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  societies, November 1969, Annual  Meeting,  Atlantic  City,  New Jersey,
  New Brusnwick, New Jersey,  Rutgers  University  Press.

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

Owens, J.P., and Sohl, N.F.,  1969, Shelf and Deltaic  Paleoenvironments
  in the Cretaceous-Tertiary  Formations  of  the New  Jersey Coastal Plain,
  in Subitsky, Seymour, ed.,  Geology  of  Selected Areas  in New  Jersey
  and Eastern Pennsylvania and  Guidebook of  Excursions:   Geological
  Society of America and associated  societies, November 1969.  Annual
  Meeting, Atlantic City, New  Jersey, New Brunswick,  New  Jersey, Rutgers
  University.

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

                                     120

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Rowley, V.R., 1969, Soil Survey of Salem County, New Jersey:   U.S.
  Department of Agriculture, Soil  Conservation Service.

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

U.S. Geological Survey, 1967, Engineering Geology of the Northeast
  Corridor,  Washington. D.C., to Boston, Massachusetts:  Coastal  Plain
  and Surficial Deposits,  U.S. Geological Survey Miscellaneous Geologic
  Investigations Map I-514-B.

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

Walker, R.L., 1983, Evaluation of  Water  Levels in Major Aquifers of  the
  New Jersey Coastal Plain:  U.S.  Geological  Survey,  Water-Resources
  Investigations Report 82-4077.

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

Zappcza. O.S.,  Hydrogeologic Framework of the New Jersey Coastal  Plain:
  U.S.  Geological  Survey Open-File Report 84-730.
                                     121

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Review of DuPont's Sailing and Analysis Plan
A review of DuPont's ground-water sampling and analysis plan,  titled "RCRA
Ground Water Monitoring Plan, Chambers Works,  E.I.  Dupont de Nemours &
Co», Inc." and dated June 1, 1982, has been conducted tc determine
compliance with 40 CFR §265.92 retirements.

Although Dupont is operating under a New Jersey Department of  Environ-
mental Protection (NJDEP) approved ground water assessment proaram,  the
sampling and analysis plan itself does not meet the reouirements of
§265.92.  The plan does not adeouately describe the samplina and analysis
program of the facility in that little information is provided regarding
specific details of how the facility tries to assure the quality of  its
ground water data.  Detailed below are the inadeouacies of the plan:
         The plan states that water levels are determined once per
         month in all wells.  In order to determine proper purge volumes,
         this should be done at the time of sampling.  However, as long
         as five volumes are being purges, as stated in the plan, the
         reguired quantity of water will be removed in any event.

         The plan does not include procedures used for measuring static
         water level elevations and total depth of wells.  The plan
         needs to provide the device and procedure used for measuring
         water levels.  A steel tape or an electronic device, capable
         of measuring to   0.1 foot, must be used.  This is critical at
         a site such as this where there is a small hydraulic gradient
         present.  Decontamination procedures used for the device between'
         wells also need to be specified.

         The plan also should contain provisions for measuring total depth.
         Aside from being used to calculate nurge volumes, this measur-
         ement can be used to check the structural integrity of the
         well, i.e., determine whether or not the well has silted in.

         The plan states that 20 grn submersible pump is used to purge
         wells prior to sampling.  A detailed description of the type
         of pump and its material of construction needs to be provided.
         Decontamination procedures for evacuation eguipment also need
         to be provided.

         Additionally, the plan needs to describe procedures that ensure
         all stagnant water in the wells is being replaced by fresh
         formation water.  Procedures also need to be provided for the
         sampling of low recovery wells.

         The plan does not contain provisions for detecting  immiscible
         contaminants in the ground water, such provisions are necessary
         since the permittee manages wastes of this type.  The plan
         needs to include the device, as well as the procedures, used
         for sampling and detecting such contaminants.

                                      122

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4.  The same submersible pump apparently is used for sampling wells
    as is used for purqinq wells.  As previously mentioned, .the plan
    needs to fully describe the type of pump and its materials of
    construction.

    Additionally, no consideration apparently is given to the use
    of a dedicated sampler, and decontamination procedures are not
    described.  These matters need to be addressed fully in the
    plan.

5.  The plan must, but does not, include procedures for minimizing
    the degassing of sample during collection and minimizing the
    contamination of equipment prior to insertion into the well.

6.  The plan states that samples will be collected in the proper
    containers and preserved according to the recommendations in
    "Procedures Manual for Ground-Water Monitoring at Solid Waste
    Disposal Facilities", EPA/530/SW611, August 1977.  Current
    Region II EPA policy on ground-water monitoring is that, with
    the exception of the holding time for specific conductance,
    Table II of 40 CFR Part 136, "Guidelines Establishing Test Pro-
    cedures for the Analysis of Pollutants Under the Clean Water
    Act", needs to be used for container, current EPA policy is
    that it is be measured immediately at the time of collection
    in the field.

    Also, for total organic halide analysis, an amber glass container
    with Teflon-lined septum should be used and the maximum holding
    time is seven days.  Headspace in the container must be eliminated
    to protect samples against the loss of volatiles.

7.  The plan describes chain-of-custody procedures for samples analyzed
    by on-site Dupont laboratories.  However, it does not provide any
    information about procedures, e.g., the use of sample seals, for
    samples shipped offsite to contract laboratories.  Such information
    needs to be provided in the plan

8.  The plan states that analytical procedures will be those approved
    by EPA, and described in EPA/600-4-79-020, March 1979 or other
    EPA approved alternate methods.  This information is inadeguate.
    The plan must reference specific methods used, not entire documents.
    The plan also states that analytical methods used are provided in
    Table TV.  The information provided in Table IV is inadequate in
    that the methods listed have Dupont identification numbers and
    no other distinguishinq characteristics, such as the EPA methods
    that they represent.  The plan needs to provide either a complete
    method description or a specific EPA method reference, includinq
    method of sample preparation, for each parameter analyzed. -

9.  The plan does not provide any details of the facility's and facility
    contractor's quality assurance/grjality control proqram(s) for

                                 123

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    sampling and analytical  activities.   At a minimum,  information
    needs to be provided regarding:

    a.   QA oraanization and  responsibilities;

    b.   Procedures used to assess the completeness of data;

    c.   Procedures used to assess the precision,  accuracy,  and overall
        reliability of data,  e.g.,  freguency and  types  of spikes,
        the use of surrogates,  duplicates .(field  and lab),  freguency
        and types of blanks

        (e.g.,  laboratory glassware,  sample container,  trip,  eouipment,
        etc.),  internal and  external  oerformance  evaluation samples,
        and systems audits;

    d.   Calibration and guantifications  procedures;

    e.   Data validation and  corrective action procedures;

    f.   Preventive maintenance  of instruments and equipment;

    q.   Education, training,  experience  requirements  for personnel
        involved in analytical  and sampling activities; and

    ho   Fie 1-d and laboratory documentation processes.

    It  should be noted that  the facility is responsible for the quality
    of  all of its ground-water  data,  whether it is generated by the
    facility or its contractor(s).

10.  The plan does not provide any information on  the  procedures used
    to  determine statistically  significant increases  (and decreases,
    in  the case of pH) over background measurements.   The statistical
    procedures must be detailed fully in the plan.
                                 124

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Review of E.I. DuPont's Ground-Water Sampling Activities
On April 7, an oversight of E.I. DuPont's contractor, W.C. Services, was
conducted by ESD personnel to determine what technioues are actually being
used to monitor the ground water.

The contractor used a truck with a submersible pump on a pulley system to
purge/sample the wells.  The.truck was backed up to the well and the pump
lowered to either as far down as the hose allowed (100 feet), or to the
bottom of the well.  Throughout the purging/sampling, the truck was idling
with the exhaust only several feet away from the well casing.

The oump was a three wire submersible from Franklin Electrical, rated at
20 gallons per minute.  It was approximately three feet long, constructed
of steel, and was attached to a thick rubber hose, through which the
groundwater was pumped.  There was black electrical tape around the top of
the pump, leading to the hose for several feet.  The pump intake was
rusted, and the internal wires were all exposed.

As mentioned previously, purging was conducted with the pump either set at
the bottom of the well, or to the maximum length of the hose.  Tables are
provided to the contractor with the time necessary to remove five volumes
from each of the wells.  These tables are based on static heads and well
depths measured some time previously.  If a well is pumped dry, it is
sampled upon recovery.  Upon completion of purging, the well was then
sampled immediately through the same pump and at the same depth in the well.
The samples were drawn from a tap off the pumping system.  These included
two POA (puroeable organics) vials, one plastic juo for;  pH, specific
conductivity, total dissolved solids, dissolved organic carbon and
chlorides, and one glass jar for TOX.  No field measurements were conducted
on-site.  Samples were kept on ice in the back of the truck with the rest
of the sampling containers.  If necessary, they are pre-preserved, according
to the contractor.  All samples are held in the vehicle until the end of the
day when monitoring activities have been completed.  This usually takes
approximately eight hours.  The pump was then raised from the bottom of the
well and lowered into the next well without any type of cleaning or rinsing
in between wells.

The contractor demonstrated how the wells are measured monthly.  A device
with a beeper, which sounds when the water level is reached, was used for
static levels.  Total depth measurements were not made.  E.I. DuPont
provides this from information developed when the wells were installed.

Within the above mentioned procedures, the following problems were noted:

 1. Total depth measurements of the well were not taken.  Aside from being
    used to calculate purge volumes, this measurement can be used to check
    whether or not the well has silted in;

 2. The positioning of the contractor's truck near the well casing may
    introduce exhaust fumes into the system;
                                    125

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3. Placement of the submersible pump at the bott.cn of the well may result
   in not all of the stagnant water being removed fran the casing of a
   fast recharging well, thus resulting in a sample not representative of
   the aquifer.  The water should be drawn frcn above the screen, in the
   uppermost part of the water column, to ensure fresh water from the
   screen will move upward;

4. Pumping at a rate of 20 qpm may result in the well going to drvness,
   and in turn, possibly recharging at a rate which causes the formation
   water to vigorously cascade down the intake screen and accelerate the
   loss of volatiles.  This would also result in a drawdown of the water
   level in the aguifer around the well, thus causing the sample to not
   be representative of the ground water at the screened portion of the
   well;

5. The submersible pump and its attachments were made of improper
   materials.  Rusted metal, exposed wires, rubber hose and black
   electrical tape are all routes of possible contamination to the water
   in the; well casing.  This is an important factor since the same pump
   was used to obtain the samples from the wells;.  There was no
   decontamination of any kind between the wells.  Use of this type of
   submersible pump introduces variability in the analysis of pH, specific
   conductance and volatile organic samples.  A].so, samples are drawn with
   the pimp sitting at the bottom of the well;

6. Sufficient time was not allowed to allow the water to stabilize in the
   well casing prior to sampling;

7. specific conductivity, pH, and temperature were not measured in the
   field..  This is necessary since these parameters are pressure and
   temperature sensitive.  Although specific conductivity is relatively
   stable, it is recommended that it be determined in the field; and

8. Purge water removed from the wells was pumped directly to the ground.
                                   126

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Audit of Currently Used Laboratories

As part of the HWGWTF's investigation of Dupont, an audit was performed in
May 1986 on Dupont's Laboratories located in Deepwater, New Jersey.  These
laboratories have performed all past Dupont analyses and will continue to
perform analyses of the drinking water suitability parameters (arsenic, barium,
cadmium, chromium, lead, mercury, selenium, silver, fluoride, nitrate, endrin,
lindane, methoxychlor, toxaphene, 2,4-D, and 2,4,5-TP); parameters establishing
ground water cruality (chloride, iron, manganese, phenols, sodium, sulfate);
and parameters used as indicators of ground-water contamination (pH, specific
conductance, total organic carbon [TOC], total organic halogen [TOX]).  This
audit was performed in order to determine the reliability of the analytical
work currently being performed as part of Dupont's ground-water monitoring
program.

Additionally, Environmental Testing and Certification Corporation (ETC),
located in Edison, New Jersey has been contracted by Dupont in the past and
apparently will continue to be contracted in the future to perform analysis
of well samples for RCRA's "Appendix VTII" parameters.  Due to the fact that
ETC was audited in July 1985 by EPA's National Enforcement Investigation
Center (NEIC), it was not audited during this Dupont investigation.  However,
the deficiencies found during NEIC's audit were  investigated for correction,
as part of this Dupont investigation.  The findings are discussed later in
this section.
Dupont Laboratories

Several inadequacies were found in the areas of parameter selection and
application of analytical methods.

Samples analyzed for metals presently are filtered, and in the past have been
filtered, prior to analysis.  Consequently, dissolved rather than total
metals have been determined.  This practice may result in data biased low and
is contrary to EPA policy of analyzinn and reporting both total and dissolved
metals.  Similarly, all pesticide analyses have been performed on filtered
samples and dissolved organic carbon is analyzed rather than total organic
carbon.  The samples are and have been filtered with a .45 micron filter
prior to analysis.  This is unacceptable.

We explained to Dupont personnel that all metal, TOC, and pesticide work must
be done on non-filtered samples.

Regarding analytical methods, the carbon column capture efficiency is not
checked as part of the TOX analyses procedure.  This check is included in
the laboratory's written standard operating procedure for TOX and is an EPA
method reguirement.  Standards are not run through the carbon column process,
so analyses of standards do not serve as checks.
                                      127

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Based on records observed by us, the TOX method requirement, that the second
column results cannot be greater than 10% of that recovered on the first
column, was not beinq followed at the time of the inspection.  Apparently, an
observed amount of over 200 uq on the second column is used as the criterion
for a breakthrough problem.  This is not acceptable.  The EPA method require-
ment of 10% needs to be followed.

Also, the 5 uq/1 detection limit reported by Dunont for TOX cannot be correct
since the data observed by us indicate that approximately 10 uq/1 appears to
be a routine amount of blank contamination.  Additionally, based on the data
observed by us, approximately +_ 5 uq/1 appears to be the; routine variation in
precision.

The use of a volatile orqanic standard is not used by Dupont in its TOX
analysis.  This is not an EPA method reouirement, but we recommend that one
be incorporated into the method.

Reqarding the measurements of pH and specific conductance, Dupont attempts to
measure these parameters within six hours of sample collection.  Measurement
within the same day reportedly is the absolute maximum holding time.  EPA
policy is that both of these measurements be made, immediately, at the time
of sample collection.  We clearly explained this policy to Dupont personnel.

A quality control manual was not available at the time of our audit, as it
was in the process of beinq revised.

Several creditable laboratory practices are worth noting:

1. A five point calibration is used for metal and orqanic analyses;
2. Standard operatinq procedures exist for most activities;
3. Control charts are used routinely; and
4. Sample preservation checks are performed and recorded.

Additionally, the physical facility is excellent and the laboratories are
certified by the State of New Jersey for various analytical activities.

Environmental Testing and Certification Corporation (ETC_)_

During NEIC's audit of ETC in July 1985, several inadequacies were found.
Most of these inadequacies do not apply to the parameters of interest in
this Dupont investigation.  The inadequacies that do relate to work per-
formed by ETC for Dupont essentially were investigated by us and no problems
currently exist.

It should be noted that, due to the difficult nature of the analyses involved,
some of the RCRA Appendix VTII parameter work performed by ETC is considered
by EPA as developmental.  Consequently, our assessment of this work has not
resulted in the notinq of problems with ETC's activities.
                                      128

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TASK FORCE SAMPLING AND MONITORING DATA ANALYSIS
GROUND-WATER SAMPLE ANALYSES RESULTS

Ground-water samples taken at E.I. Duoont, Chambers Works, by the Task
Force were analyzed for the parameters listed in Appendix 1.  Although
samples were collected for dissolved metals, they were not analyzed.
None of the samples were analyzed for tin.  Two field duplicates were taken
during the survey (M-l and M-47) and are both tabulated in Tables 14 and 16.
The results of the field and eouipment blanks can be found in the raw data
sheets from the respective laboratories.  Measurements for pH, temperature,
specific conductivity, and turbidity were taken in the field and are presented
in Table 30.

All data for inorqanics, metals, and indicator type parameters are tabulated.
For the orqanics, only those compounds which were detected in at least one of
the wells are listed.  The data Qualifiers used for Tables 14 through 30 are
listed in a key at the beginning of the tables.  All results reported as rtU"
were analyzed for but not detected.  However, some of the detection limits
were higher than normal due to dilutions or interferences (referenced from
laboratory data sheets).  Some of these samples were also outside of control
limits for the spike recovery (represented by "UN").  If the detection limit
was estimated, this was Qualified with a "UJ".
Inorganic and Indicator Type Parameters Analyses Result

Tables 14 through 19 summarize the results of the inorganic and indicator type
parameters analyses on ground-water samples obtained from monitoring wells at
the Chambers Works facility.  All of the nitrate and nitrite sample results
were rejected due to holding times having been exceeded.  Sulfate and chloride
values were estimated high due to spike recoveries outside of the established
limits.  Bromide values were all estimated due to the lack of adequate QC
data.  TOC and ammonia values were all estimated due to the laboratory's use
of field blanks for spike recoveries.  All POC sample results (high and low
level) were rejected due to inadequate OC data and holding times having been
exceeded.  TOX values for four of the samples (MOA030, 037, 047, 050) were es-
timated low due to POX values having been found at higher levels.  Samples
for TOX (3) and Phenols (3) were rejected due to high levels of contamination
in the corresponding equipment and/or field blanks.

In general, the highest levels of inorganic and indicator type parameters were
found in the samples from wells near the centers of  the interceptor pumping
system (M-l, M-3, M-12, and M-14).  These wells cover the whole spectrum of
the Glacial aquifer, but are primarily situated in the middle and deep portion
of the aquifer.  Although the highest level of TOX contamination was found in
the sample from M-14 (46,200 ug/1), the levels of TOX found in samples from
M-l and M-3 may actually be higher than shown (see previous paragraph).
                                      129

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The sample from monitorinq well 204, downgradient from Area I of the landfill,
had the third hiqhest concentration of TOC found in any of the ground-water
samples (66 ,,000 ug/1) .

The hiqhest levels of total phenols were found in samples from M-l (MQA047 -
258 uq/1, MOA048 - 314 uq/1) and M-47 (242 uq/1).  Notable concentrations of
TOC (16,000 ug/1) and total phenols were found in the sample from M-45c,,


   Metals Analyses Results

Tables 20 through 22 summarize the results of the metals analyses on ground-
water samples obtained from monitorinq wells at the Chambers Works Facility.
Reported detection limits (DL) were contractor required detection limits
(CRDL) or lower for all metal parameters except total arsenic, mercury and
thallium.  Reported DL's for mercury were 1.5 to 5 times CRDL in twelve
samples, and for arsenic and thallium they were 5 times CRDL in one sample
MQA041).  Lead values were all estimated due to apparent interference from
excessive levels of chloride and sulfate.  There is a negative bias of 40%
or more if detectable, and a higher than indicated detection limit if non-
detectable.  Samples for mercury (6), iron (4), barium  (4), sodium (2) and
manganese (1) were rejected due to high levels of contamination in the
corresponding eouipment and/or field blanks.

Elevated concentrations of some Appendix VIII metals (total) were found in a
number of ground-water samples.  Table 32 charts the occurrence of these metals
in the samples taken by the Task 'Force.


Table 32 : Occurrence of Hazardous Metal Constituents in Ground-Water Samples
           Metal
        Constituent
    # of Wells
Constituent Present
Range of Concentrations
    Present (ug/1)
Barium
Lead
Chromium
Mercury
Beryllium
Ant imonv
Arsenic
Cadmium
Nickel
Silver
14
6*
5
3
3
2
2
2
2
2
8.0
2.3
10
0.2
4.0
5.8
12
2.1
27
13
- 2200
- 61.8
- 225
- 1.75
- 50 |
- 31.2
- 12.4
- 3.7
- 416
- 42
        * - May be present in other wells also (see above paragraph)
                                      130

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The following rpsnlts were also notpd

1. Barium was present at all  levels o* the niacial aquifer and tn
   shallow Potomac-Ra ri t an-Magothy (PRM) aquifer zone

2. Lead was present In the highest concentrations in the dnep Glacial  aquifer
   and in the shallow PRM aquifer ?one (aside from M-63 and M-64 located near
   the Petrochemical area)

3. Chromium was present in the Mghest cone ntraion in the shallow Hl
   aqui
4. Mercury was present in the highest concentration in M-64

5. Beryllium was present in the highest concentration in Well 204;

6  Antimony and arsenic were prpsent in thp highest concpnt rat i on in M-3

7. Cadmium was present in the highest concentration i n M-6^:  anrl

8. Nickel and silver were present in thp highest concentrations  in Well  204.

Of the non-Appendix \'III metals   aluminum (I?), manganese (17)., and zinc (12)
were present at the greatest number of wells.   Aluminum concentrations ranged
from 1?7 ug/1  (M-13) to 19.600 ug/1 (M-63). with the highest  concentrations
occurring in the shallow Glacial  aquifer.   Manganese concentrations ranged
from 278 ug/1  (M-Q4) to 19,800 (M-63). with high concentrations  occurring at
all IPVP!S of the Glacial aqirfer.  Zinc concentrations ranged from IP ug/1
(M-47) to 406 ug/1  (Well ?91 ) , with the highest concentrations occurring in the
shallow Glacial  aquifer- hut the  majority  of the points were  present in  the
de 'p Glacial and shallow PRM aquifer zones.


   Organic Analyses _Results

Tables 23 through 25 summarize the results of  organic analyses nn ground-wa* er
sample^ obtained from monitoring  wells at  the  Chambers Works  Facility   Re-
ported DL's WPTP PRPL or lower for all organic parameters pxcppt those men-
tioned hplow.   The reported DL for spmi - vol at i le compound^ was 2 times CRDL
in al '  samples except OU34  113?. 1141. M47, 1148  1151.  In thpse samples
the DL was 10 to 200 times CRDL.   For seven samples (01134, 1137-113P, 1147.
1148, 1151)  the reported DL for  all  pesticides was ? to 4 times CRDL.  The
reported DL for volatile organics was from ? to 500 times CRDL in seven
samples (01125  1134. 1137. 1141, 1147, 1148.  and 1151)   Semi -volati le  or-
ganic results  for four samples (01147  114R, 1153.  1155) were estimated  due
to inadpquate QC information   Blank  contamination  of any significance was
not found in thp organic scans.

In general, the highest levels of hazardous organic constituents wpre found
in the1 samples from monitoring wells  near  the  centers of the  interceptor
pumping system (M-l , M-3, M-12, M-13.  M-14)   Thp samplp  rom M-l  (deep
Glacial aquifer)  ndicatpd the highest concentrations of acetone (1100 ug/1).


                                      131

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trichloroethene (870 ug/1),  benzene (12,000  ug/1),  toluene  (260  ug/1 )  and o-
toluidine hydrochlonde (4,000 ug/1)  and  the second highest  concentrations
of chloroform (220 ug/1),  chlorobenzene  (15,000 ug/1),  1,4  dichTorobenzene
(760 ug/1), 4-chloroaniline  (3,300 ug/1),  and aniline  (6700  ug/1).   The
sample from M-3 indicated  the  highest concentrations of  chlorobenzene
(79,000 ug/1), 1,4 dichlorohenzene (1,000 ug/1),  1,2 dichlorobenzene
(34,000 ug/1), 4-chloroaniline (11,000 ug/1, and  aniline (12,000 ug/1).
M-12 (deep Glacial aquifer)  and M-14  basically had  similar  constituents
present, however, at lower levels  in  most cases.  The  ground-water  sample
from M-l contained low level  concentrations  of two  pesticides; Beta-BHC
(1.6 ug/1), and Delta-BHC  (.71 ug/1).  M-14  indicated  low level  presence
of two herbicides; Dichloroprop (9.0  ug/1),  and 2.4-D  (9.7  ug/1).

The majority of the hazardous  organic constituents  were  found  in ground-
water samples from the shallow and middle Glacial aquifers.   Table  33  charts
the occurrence of these Appendix VIII constituents  in  the ground-water
samples taken by the Task  Force.


Table 33: Occurence of Hazardous Organic  Constituents  in Ground-Water  Samples
Organic
Constituent
Chlorobenzene
1 ,2-Dichlorobenzene
4-Chl oroani 1 ine
Benzene
o-Toluidine hydrochl oride
Acetone
Tri chl oroethene
Tol uene
1,4-Di chl orobenzene
Ani 1 i ne
Chl orof orm
1 ,2-Di chl oroethane
# of Wei Is
Constituent Present
12
11
11
10
9
8
7
6
6
5
4
4
Range of Concentrations
Present (ug/1)
10 - 79,000
7.2 - 34,000
4.2 - 11,000
1.6 - 12,000
9.0 - 2,500
7.5 - 1,100
5.3 - 870
2.5 - 260
2.4 - 1,000
3.2 - 12,000
2.8 - 270
16 - 470
LEACHATE AND SURFACE WATER ANALYSES RESULTS

Leachate and surface water samples taken at E.I.  DuPont  were analyzed  for  the
same parameters as the ground-water samples, except for  the field  meas-
ments*  Results are presented in Tables 26 through 29,   The leachate  results
indicate high TOC values, as was to be expected from this  type of  sample.   The
corresponding TOX values however, were relatively low..   Sump #274,  from  Areas
II and III, showed higher TOC and TOX concentrations than  Sump #200 from Area  .
Magnesium, sodium, and potassium were present in  the highest concentrations.
                                      132

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All  other metals were detected in the samples  except  for  aluminum,  beryllium,
cadmium, mercury, silver,  and  thallium.   The  organic  hazardous  constituents
found in the leachate (Table 29)  parallel  those found in  the  majority  of  the
monitoring wells, including Well  204.

Two surface water samples  were collected  at  the facility.   Acetone  (8.9 ug/1 )
and o-toluidine hydrochloride  (12 ug/1) were  detected.  Additional  studies
are necessary to determine the relationship  between  surface water and
ground water at the site.
                                      133

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                                DISCUSSION


LANDFILL MONITORING WELLS

Well 204 revealed the highest level  of  contamination  with  respect to  TOC
(66,000 ug/1 ) and TOX (1,310 ug/1).   Monitoring  wells 291  and  241 both
revealed higher than background values  for TOC and  TOX.  Upgradient well  252
indicated a sample concentration for TOC  of 3500 jg/1 .   The  data  for  TOX  was
invalidated for Well 252 due to blank contamination.   The  significance  of
these increases in concentration relative to background  can  not be  fully
assessed without a statistical  analysis.   It should be noted that Well  291
is 70 feet deep, whereas the other wells  are approximately each 20  fpet deep
Also, Wells 204 and 291 are adjacent to Area I of the landfill  (inactive
since 1978),  whereas Well 241 is adjacent to Area II.

Well 204 also showed indications of  the highest  levels of  aluminum  (3800
ug/1), barium (2200 ug/1), beryllium (50  ug/1),  chromium (225  ug/1),  cobalt
(515 ug/1), copper (260 ug/1),  cadmium (50 ug/1), nickel  (416  ug/1),  silver
(42 ug/1), vanadium (527 ug/1), zinc (264 ug/1)  and cyanide  (43 ug/1);  with
the exception of the zinc level (406 ug/1) at Well  291,,  Arsenic, barium,
and mercury were found at lower levels  at Well 241.  Calcium,  magnesium and
sodium were found at high levels in  most  of the  monitoring wells  at this
site, however this to be expected in a  saline environment  such as is  pre-
sent underneath the Chambers Works facility.  It should  also be noted that
the primary sludge buried in the landfill (53,000 tons/year) is mostly  made
up of calcium and magnesium oxides,  and that the wells around  the landfill,
in particular Well 2(34 and 252, had  the highest  concentrations (with  the
exception of  two wells near the Delaware, M-63 and  M-64) of  these two metals.

The upgradient well (252), and  Well  241,  showed  no  quantification of  any
specific organic compounds.  Table 31 lists several tentatively identified
compounds found in these wells; however,  confirmation would  require the
use of authentic standards.  Well 291 indicates  the presence of acetone
(120 ug/1).  Well 204 contained the  greatest indication  of hazardous  or-
ganic constituents (11), ranging from 2.6 ug/1 of 2-mtrophenol to  140
ug/1 of n-nitrosodimethylamine  (see  Tables 23 and 24  far summary  of  results).

Figure 21 (High Water Levels in Shallow Glacial  Zone), the most ac-
curate potentiometn'c map constructed by  DuPont's, contractor due  to the
number of wells available for measurement, Indicates  that  ground-water  move-
ment is towards the Delaware River on the west side of the landfill  (highest
contamination relative to background).

Based on this data it seems that ground-water contamination  is occurring  in
the vicinity  of Area I of the landfill  (single liner), in  particular  the  west
side, and that migration is towards  the Delaware River.  Data  generated east-
ward of Well  204 show minimal signs  of contamination  at  this time.   However,
leachate sampling results from areas II and III  indicate higher organic con-
centrations at this point.  It  is recommended that  additional  pie-zometers
be installed  to better delineate ground-water flow  directions  in  the
vicinity of the landfill.
                                      134

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DELAWARE RIVER WELLS

Two monitoring wells, M-63 and M-64, located on thp west side  of the  fa-
cility, adjacent to two tanks containing sulfuric acid (TS-34, TS-36)  and
another spries of tanks containing No. 6 fuel  oil, were sampled.  The
facility's wharf is situated due west of these wells.

The ground water removed form M-64, the shallower of the two wells (15 feet).
was pitch black in color throughout evacuation and sampling.  Prior to evac-
uation, a thin, immiscible layer was detected  using the interface probe.
The sampling team was required to don respirators due  to indications  of or-
ganic vapors using air monitoring equipment.  Analytical  results (see  Table
18) indicate slightly elevated levels of TOC (6500 ug/1), however, relatively
low values of TOX (46 ug/1).  Quantification of speci.fic hazardous organic
constituents ranged from 2.5 ug/1 of toluene to 64 ug/1 of 1,2 -Dichloroethane.
The highest levels of chromium (82 ug/1), mercury (1.75 ug/1)  and zinc (364
ug/1) were found in M-64; not including wells  sampled  from around the  landfill
(see Table 24).  M-64 also contained the second highest concentration  of
aluminum (4,050 ug/1), and the third highest concentration of  lead (34.8  ug/1).

The ground water removed from M-63 (36 feet deep) was  greyish, with a  strong
organic type odor.  Once again,  respiratory protection was warranted  for  the
sampling personnel.  Analytical  results indicate higher levels of TOC  (13,000
ug/1) and TOX (10,000 ug/1) at this location as compared to M-64.  Quantification
of specific hazardous constituents was considerably higher; ranging from
14Q ug/1 of benzene to 2,000 ug/1 of 1,2-Dichloroethane.  The  sample  from M-63
also contained the highest levels of aluminum  (19,600  ug/1) and cobalt (66  ug/1),
and the second highest levels of lead (37 ug/1); not including wells  sampled  from
around the 1andfi11.

M-63 had the highest level of iron present in  any of the wells (937,000 ug/1).
almost 4 times that of the next  highest concentration.  The iron content  in
M-64 was 156,000 ug/1.  Field measurements at  both M-63 and M-64 indicated
a low pH; 4.60 and 5.40, respectively.  Samples from M-63 also had the
highest readings of specific conductivity (4,000 umhos/cm) and the lowest reading
of turbidity (11.1 NTU).  These  facts seem to  indicate that a  larger  percentage
of the metals present in the ground water at this location are in a dissolved
state.

Ground-water movement in the shallow aquifer at the location of M-64  is unaf-
fected by the intercpptor pumping system, and  thus flows in a  westerly dir-
rection towards the Delaware River.  It is recommended that additional
studies be conducted in this area to define possible migration of hazardous
constituents towards the Delaware River.  Physical observations (color,
odor, and an immiscible layer),  along with the presence of several  hazardous
organic constituents, tend to point to a floating hydrocarbon  in that  area;
either from the nearby storage tanks or the petrochemical products area.
Records show that a past disposal area was located approximately 400  feet
south-south east of M-64; in the vicinity of TEL-563.   Although flow  is
towards the Delaware River, the  influence of the tide  may be spreading the
floaters parallel to the shore.
                                      135

-------
There is some question as to the  reliability  of  ground-water  flow  information
in the middle glacial  aquifer (lack  of  data  points),  and  to what extent
contaminant movpment is influpncpd  in the  screened  interval of M-63.  The
conditions described above seem to  indicate  high percentages  of dissolved
metals in the ground water, which may be  flowing in a  westerly direction.


POTOMAC-RARITAN-MAGOTHY AQUIFER WELLS

Three monitoring wells screened in  the  shallow Potomac-Raritan-Magothy  (PRM)
aquifer zone were sampled (M-45c, 92, 94).   Task Force sampling verifies
the presence of contamination at  M-45c,  as does  data  generated in  the
past by E.I. DuPont.  Results indicate  a  TOC  concentration of 16.000 ug/1
(TOX data invalidated).  Quantifcation  of  specific  hazardous  organic
constituents (15) ranged from 2.0 ug/1  of  di-nbutylphthalate  to 83 ug/1
of chlorobenzene.  The majority of  the  organic constituents found  are
typical of those present in the Glacial  aquifer (see  Table 33 - Occurrence
of Hazardous Organic Constituents).   The  highest concentration of  lead
(61.8 ug/1), and the second highest  concentration of  barium (193 ug/1)
were found at M-45c.

M-92 and M-94 both showed indications of  the  presence  of  hazardous organic
constituents: M-94 more so than the  former.   The TOX  concentration of the
sample from M-94 was 107 ug/1.   Quantification of specific hazardous organic
constituents (7) ranged from 1.6  ug/1 of  benzene to 38 ug/1 of 1.2-dichloro-
benzene.  Once again,  the majority  of the  constituents are typical  of those
present ir the Glacial aquifer.  The sample  from M-92  nad an  acetone "concen-
tration of 140 ug/1.

The following organic  hazardous constituents  were found in the samples  only
from the PRM aquifer;  1,4-napthaquinone,  bis-(2 chloroethyl)  ether,  2,4-
di ni troto'l uene, bis (2-ethylhexyl phthalate), and o and p phenylenedi ami ne.

Of the current EPA Interim Primary  Drinking  Water Standards the only parameter
of concern at this time in the  shallow  PRM aquifer  is  lead  (61.8 ug/1).
The analytical results indicate a negative bias of  40% for  lead  (see Metals
Analyses Results).  The Drinking  Water  Standard is  50  ug/1.   Appendix F of
"Regulations Implementing the New Jersey  Water Pollution  Control Act"
(N.J.S.A. 58:10A) entitled, "Values  for the  Determination of  NJPDES
Permit Toxic Effluent  Limitations"  lists  requirements  for drinking water  in  New
Jersey.  One of the parameters  Total  Volatile Organic;; (TVO)  has a limitation
of 50 ug/1. However, there are  not  any  final  standards as of  yet.   Incidentally,
concentrations of TVO in all three  of the monitoring  wells  sampled in the
shallow PRM aquifer, a drinking water  source, exceed  50 ug/1.

Both M-92 and M-45c are located in  the  central area of the  facility.  M-94  is
situated on the southeast border.  The  constituents of M-94 are  similar to
those of M-18 and M-21 above it.  but at  lower concentrations.  It  also  contained
2,4-dinitrotoluene, and bis (2-ethylhexyl  phthalate).   Ground-water movement  in
the PRM aquifer at this time seems  to  have shifted  from a southwesterly to
a southeasterly direction.  However, more monitoring  points  (piezometers)  are
needed to better define the ground-water flow of the PRM aquifer beneath  the  sne,
It is also necessary to delineate the  rate and extent  of  contamination  in  the
PRM aquifer,
                                      136

-------
 INTERIOR MONITORING WELLS

 The remainder of the monitoring wells sampled were all  situated in the vicinity
 of the central area of the facility (M-l, 3, 12, 13, 14  47).  with the exception
 of M-18 and M-21.  Both of these wells are located on the southeast boundary
 of the facility, npar the town of Deepwater.

 M-18 and M-21 are screened in the deep Glacial  aquifer, approximately  700
 feet apart from each other.  Of the two, M-21 indicated the higher levels
 of TOX contamination (1,060 ug/1).  Quantification of the hazardous organic
 constituents  (12) in M-21, ranged from 4 ug/1 of 2-chlorophenol to 350 ug/1
 chlorobenzene.  The sample from M-18 showed fewer of these constituents (4)
 and at lower  concentrations; but of the same ones.  All of the organic
 constituents  found in these two wells are similar to those found in other
 wells in the  facility and the leachate.  Concentrations of metals in these
 samples wer^  lower than in M-94 (shallow PRM aquifer zone).

 As was discussed previously  the interior wells (M-l, 3, 12, 13, 14),  were
 thp most highly contaminated wells on-site.  At the M-12, 13,  14 cluster,
 the highest levels of organic contamination occurred in the screened portion
 of the shallow Glacial aquifer.  Contamination  levels were similar in  both the
 middle and deep Glacial aquifers.  At the M-13, cluster, organic contamination
 was highest in the deep aquifer, although contaminant levels were also very
 high in the middlp aquifer.  Results of metals  analyses indicate that  these
 contaminants  are distributed mostly in the middle and deep Glacial aquifers.

 M-47, screened in the shallow aquifer, is located approximately 500 feet  due
 east of the Waste Water Basins and 250 feet northwest of interceptor- pump
 103-A.  Sample results indicate relatively low  levels of TOC (6300 ug/1)
 and TOX (1180 ug/1).  The total phenol concentration (242 ug/1) was the
 second highest found at the site.  Low levels of chromium (9 ug/1) and zinc
 (28 ug/1) were also found.  Quantification of hazardous organic constituents
 (9) in M-47 ranged from 2.2 ug/1 of 2,4-dimtrotoluene  to 40 ug/1 of chloro-
 benzene.  Duplicate results fro 4-chloroani1ine were 75 ug/1 and 23 ug/1.

 Ground-water movement at M-47 is influenced by  interceptor pump 103-A  towards
 the east.  Past reports seem to indicate the possibility of "exfiIt ration"
 from thp Waste Water Basins into the cone of depression caused by Int-103A.
 If this is the case, M-47, which is directly in the path of the ground-water
 flow, is an indicator of the contamination migrating from the  Waste Water
 Basins into the ground water.

 Aside from the area around the landfill, it is  difficult to assess the
 source(s) of ground-water contamination and its movement due to the effect of
 the pumping for contaminant removal.  This is true at both the interior portion
 of the plant, as wpll  as the property boundary  wells on the east
 side.  Ground-water contamination in the plant  area may be occurring from
 the ditch system or from past practices, or both; this  is difficult to
 determine.   However, two factors that  predominate are the similarity and
wide spread distribution of the organic contaminants in the monitoring wells,
 including those screened in the shallow PRM aquifer zone. Vertical gradients
 seem to indicate possible flow from the Glacial  aquifer to the shallow PRM
 aquifer zone.  The majority of these contaminants parallel  those present

                                      137

-------
In the leachate from the landfill,  which  is  a  "fingerprint" of the previous
and present types of chemicals  used at  the facility, and the types of
wastes generated on-site and  entering the ditch  system; prior to flowing
to the waste water treatment  plant.
                                      138

-------
              Key  to  Results  of  Sample Analysis


  J   -   estimated  value  due to the  presence  of interference

  M   -   duplicate  injection results  exceed control  limits

  N   -   spike  sample  recovery is  not within  control limits

  S   -   value  determined by Method  of Standard Additions

  U   -   parameter  analyzed, but  not  detected

 II   -   indistinguishable  isomers

 na   -   parameter  not  analyzed

  +   -   correlation coefficient  for  Method of Standard Addition
        is  less  than  0.995

  *   -   high  relative  percent difference  (RPD) values

•--   -   data  did not  pass  QA/QC  review
                           139

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Table 30 :  Analytical  Fipld Measurements Conducted at E.I.  Du Pont



















(3/31/86 - 4/10/86)
Sample Location
Well #1
Well #3
Well #12
Well #13
Well #14
Well #18
Well #21
Well #45-C
Well #47
Well #63
Well #64
Well #92
Well #94
Well #204
Well #241
Well #252
Well #2
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        Table 31  : Tentatively Identified Compounds Requiring Confirmation Using
                   Authentic Standards
Sample
Location

Well 21
Well 63
Well 64
Well 18
Well 291
Sample #

 1124
                 Compounds
 1125
 1128
 1129
 1132
Well 252
 1133
Benzene, Chloro-
Benzenamine, 2-Chloro-
Benzenamine, 4-Chloro-2-Methyl-
3,6,9,12-Tetraoxahexadecan-l-Ol
Ethane, 1,2-Dichloro
Butane, 2-Methyl
Ethane 1,1-Dichloro-2, 2-Difluoro-
Ethene  Trichloro
Benzene, l,3-Bis(Tnfl uoromethyl )-
  (Scan No. 528)
Benzene, 1,3-Bi S (Tn f 1 uoromethyl )-
  (Scan No. 540

Ethane, l,l'-0xybis-
Benzene, Chloro-
3,6,9.12,15-Pentaoxanonadecan-l-Ol

Ethane, l.l'-Oxytns-
Ethane, 1,1' -Thiobis-
Sulfur Dioxide (DOT)

Benzene, Chloro-
Azindine,  1-Hexyl-
Ethanol, 2-(2-Butoxyethoxy)-
Benzothiazole
Ethanol, 2[2-(2-Butoxyethoxy)Ethoxy]-
2(3H)-Benzothiazolonp
3,6.9.12-Tetraoxahexadecan-l-Ol
4 Penten-2-OL

4-Penten-2-01
Ethane, l,l,'-0xybis
Ethanol, 2-(2-Butoxyethoxy)-
3,6.9,12 15-Pentaoxanonadecan-1-01
  (Scan No. 953)
3,6,9,12,15-Pentaoxanonadecan-1-01
  (Scan No. 1041)
3,6,9,12,15-Pentaoxanonadecan-l-Ol'
  (Scan No. 1131)
3,6,9,12,15-Pentaoxanonadecan-l-Ol
   (Scan No. 1298)

2-Piperidinecarboxylic Acid, 1-Formyl-
__    Concentration, uq/L

              320
              530
              110
              2,100
              240
              15
              49
              20

              13

              25

              2,100
              220
              110

              400
              50
              12

              24
              15
              270
              12
              12
              27
              7,200
              7

              6
              190
              16

              80

              2,000

              10

              120

              26
                                                                            conti nued-
                                              156

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Sample
Location

Well  13
Sample

 1134
                Compounds
Well 204
 1136
Well 3
 1137
Ethane, 1, 2-Di chloro-1 ,1,2,-Trifluoro-
Ethane, l.l'-Oxybis-
Benzene, Chloro-
Ethanol , 2(-(2-Butoxyethoxy)-
Benzeneamine, 4-Chloro-2-Methyl-
Benzenamine, 2 ,3-Dicholoro
Benzenamine,2,4-Dichloro-
Benzenamlne, 4 (4Morpholinyl)-
Benzenamlne
Benzenamine, 3-Methyl-
Benzenamine, 2-Chloro

Methanamine, N-Methyl-N-Nitro-
2,5-Cyc1ohexad"iene-l,4-Dione
Piperidine, 3,5-Dimethyl-
Furan, Tetrahydro-3-Methyl-
Benzene, 1-Methyl-2-Nitro-
IH-ImiddZole, 4,5-Dihydro-2-Methyl-
IH-Indole,  2,3-Dihydro-1,2-Dimethyl -
2-Pentanamine, N-Ethyl-4-Methyl-
Benzenamine, 2 ,3-Dichloro-
2-H-Indol-2-One, 1,3-Dihydro-3,3-Dimethyl -
Benzo[B]Thiophene, 7-Ethyl-2-Methyl -
Benzenemethanamine, 4-Methyl-
Benzene, 1-Methyl-4-(l Methylethyl)-2-N1tro-
Piperazlne, 2-Methyl-
Butanedlotlc Acid, Phenyl-, Dimethyl Ester
1-Indanone. 5,6-Dlmethyl-
2H-l-Benzopyran, 3,4-Dihyaro-
1H-Indole-1-Acetaldehyde, 2,3-Dihydro-
  3,3-Methyl-2
Hydrocarbon
Hydrocarbon Substitute

Ethane. 1,1,2-Trichloro-1,2,2-Trif1uoro-
Methane, Dlchloro-
Ethane, 1,1,2-Trichloro-l ,2 2-Trifluoro-
Ethene, Trlchloro-
Benzene, Chloro- (Scan No. 524)
Benzene, Chloro- (Scan No. 402)
Benzenamine
Benzenamine, 2-Chloro-
C_oncentrafjo_ns,  ug/L

        11
        32
        220
        250
        300
        88
        140
        140
        1,600
        650
        1,400

        580
        33
        13
        27
        48
        560
        19
        31
        16
        22
        150
        18
        12
        4
        5
        35
        6

        39
        390
        16

        3,700
        700
        400
        100
        100
        66,000
        8,300
        5,200
                                                                            continued-
                                              157

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Sample
Location

Well 47
            Sample

             1138
                 Compounds
Well 47
             1139
Well  14
             1141
Well 241     1143
Surface
Water #}
             1144
Surfacp
Water #2     1144RE
Ethane, 1,1,2-Trichloro-1,2,2-Trifluoro-
Benzene, Chloro
1,4-Cyclohexanedione
Benzenami ne
Benzenamine, 3-Methyl-
Benzenamlne, 2-Chloro-
1,3-Dioxane, 4,6-Bis(2,2-Dimethylpropyl)•
Benzenp, 1-Methyl-2-N1tro-
Pyn'dine, 2-Chloro-6-Methyl-
Bpnzene, 1-Methyl-3-Nitro-
Benzene, l-Chloro-2-Nitro- (Scan No. 687
Benzene, 1-Chloro-2-Nitro- (Scan No. 693'.
Benzene, 1-Chloro-2-Nitro- (Scan No. 70CT
Benzene, 1,2-Dichloro-4-Nitro-
Benzenamine, 2,4-Dichloro-

Ethane, 1,1,2-Tri chl oro-1,2,2-Tn fluoro-
Benzenp, Chloro-
Benzenarm ne, 3-Methyl-
Benzenamine, 2-Chloro-
1,3-Dloxane, 4 ,6-Bis(2,2-Dimethylpropyl)•
Benzene, 1-Methyl-2-Nitro-
         1-Metnyl-3-N1tro- (Scan No,
         1-Methyl-3-Nitro- (Scan No,
         l-Chloro-2-Nitro- (Scan No,
         2-Chloro-2-Nitro- (Scan No,
         l-Chloro-2-N1tro- (Scan No,
                       Benzene,
                       Benzene,
                       Benzene,
                       Benzene,
                       Benzene,
                       Benzene,
                       Benzenamine, 2,3-Dichloro-
                                                            669;
                                                            679'
                                                            687'
                                                            693;
                                                            700'
                                 ,2-Dichloro-4-Nitro
Ethane, 1,1,2-Trichloro-1,2 ,2-Trifluoro-
Benzenamine,  3-Methyl-
Benzenamine,  2-Chloro-
             4-Chloro-2-Methyl-
             2,3-Dichloro- (Scan No. 733)
             2 3-Dichloro- (Scan No. 770)
                       Benzenamine,
                       Benzenami ne,
                       Benzpnami ne,
                       Piperidine, 1-Ethyl-2-Methyl- (Scan No. 410)
                       Benzene, Methyl-
                       Plperidine, 1-Ethyl-2-Methyl- (Scan No. 513)
                       2-Piperidinecarboxylic Acid, 1-Formyl-
                       1.4-Cyclohexanedione
                                                                        Concentration,

                                                                                64
                                                                                51
                                                                                11
                                                                                25
                                                                                77
                                                                                780
                                                                                16
                                                                                960
                                                                                96
                                                                                45
                                                                                12
                                                                                99
                                                                                1,900
                                                                                220
                                                                                41

                                                                                52
                                                                                36
                                                                                72
                                                                                690
                                                                                15
                                                                                970
                                                                                59
                                                                                42
                                                                                11
                                                                                94
                                                                                1,800
                                                                                220
                                                                                39

                                                                                120
                                                                                1,000
                                                                                2,200
                                                                                3,400
                                                                                12,200
                                                                                2 800

                                                                                28
                                                                                12
                                                                                27
                                                         22


                                                         27

                                                     continued
                                              158

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Sample
Location    Sample I	Compounds	.Concentration, ug/'

Well 92      1146      Thiazole, 2-Ethyl-4-Methyl-                              17
                       Ethanol , 2-(2-Butoxyethoxy)-                             240
                       2(3H)-Benzothiazolone                                    10
                       3,6,9,12-Tetraoxahexadecan-l-Ol                          5,300

Well 1       1147      Ethanol, 2,2,2,-Trifluoro- (Scan No. 127)                5,300
                       Ethane, 1,2-Dichloro-1,1-Difluoro-                       1,200
                       Ethane, 1.1-Dichloro-2,2-Dif1uoro-                       1,700
                       Ethanol, 2,2,2-Trifluoro (Scan No. 112)                  21,000
                       Chlorobenzene                                            5,400

Well 1       1148      Ethanol, 2,2,2-Tn f luoro- (Scan No. 126)                 6,500
                       Ethane, 1,2-Dichloro-1,1-DIfluoro-                       1,700
                       Ethane, 1,1-Dichloro-2,2-Difluoro-                       2,50U
                       Ethanol, 2 ,2 ,2-Tn fl uoro- (Scan No. 112)                 23,000
                       Benzenp, Chloro-                                         7,600
                       Benzenarmne, 4-Chloro-2-Methyl                           1,400

Well 94      1149      Benzenamide, 2-Chloro-                                   11
                       Benzene, Chloro                                          13

Well 45-C    1150      Ethane 1,2-DiChloro-                                     71
                       Ethane, l,l'-0xybis-                                     12
                       Ethane, 1,1-Dichloro-2,2-Difluoro-                       15
                       Ethane, 1,1'-Thiobis-                                    7
                       Benzene, Chloro-                                         43
                       Benzamine,   4-Chloro-2-Methyl-                            32
                       1,3-Benzenediamine, 4-Methyl-                            30
                       Benzamine,   4-Methyl-                                     10
                       Benzenamine, 4-Ethoxy-                                   15
                       Benzamine,   2-Chloro-                                     220

Well 12      1151      Methane, Dichlorofluoro-                                 10
                       Ethane. 1,1,2-Trichloro-1,2,2-Trifluoro-                 36
                       Benzene, Chloro-                                         150
                       Benzenamine, 2-Chloro-                                   990
                       Ethanol. 2-(2-Butoxyethoxy)-                             800
                       Benzenamine, 4-Chloro-2-Methyl-                          160
                       Benzenamine, 2,6-Dichloro-                               32
                       Benzenamine, 3,5-Dichloro-                               36
                       Benzenamine, 4-(4-Morpho1inyl)-                          25
                       3,6,9,12,15-Pentaoxanonadecan-l-OL                       2.80C


                                                                            continuecl-
                                              159

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 Sample
 Location

 Leachate
.Sump  #1
Sample I


 1154
                 Compounds
 Leachate
 Sump  #2
 1155
Phenol
Benzene, Chloro-
Methanarm ne. N-Methyl-N-Nitro-
Benzenamlne, 2-Chloro-
Benzenami ne, 3,4, Dimethyl-
1,3-Diazabicyclo [3.1.0]Hexane
Benzeneacetlc Acid
Benzene, l-Chloro-2-Nitro
L-Threonlne, Ethyl Ester
Benzenamine, 2,3-Dichloro- (Scan No. 718)
Benzenamine, 2 ,3-Dichloro- (Scan No. 760)
Benzo[B]thiophene, 7-Ethyl-2-Methyl-
IH-Indole-l-Acetaldehyde, 2,3-
  Dihydro-3,3-Dimethyl-2
Ethanol
Benzenemethanol, .Alpha.-(1-Aminoethyl)-,
  [R-(R*,S*)]-
2-Propanol
Acetamide, N.N-Dimethyl-
Phenol
Benzenami ne
Benzene, Chloro-
Propanedi oi c Acid
Hexanoic Acid, 2-Methyl-
Hexanoic Acid
Oxirane, 2,3-Bis (1-Methylethyl)-, Trans-
Hexanoic Acid, 2-Ethyl-
B^nzenamine, 2-Chloro-
1,3-Pentanediol , 2,2,4-Trimethyl -
Benzeneamine, 2,6-Dimethyl-
Renzenacetic Acirt
Benzeneamine, 2-Chloro-4-Methyl-
Benzenepropanoic Acid
Benzenamine, 2 ,3-Dichloro-
1,3-Benzenediamine,  4-Methyl-
Cyclopropanecarboxylic Acid, 3-(2,2-Dich1oro-
  ethenyl)
Benzenamine, 3,4-Dichloro-
Phenol, 3,4,5-Trimethyl-
l,2.4-Triazolo[4,3-B]Pyridazine, 6-Chloro
Pentane, 1-Propoxy-
Hexanoic Acid
Concentration,  uq/1
        2,000
        4 200
        2,300
        14,000
        2,400
        1,600
        680
        810
        1,200
        470
        920
        1,800

        3,200
        2,000

        14,000
        10,000
        4,000
        2,000
        1,000
        3,700
        13,000
        5,900
        2,200
        1,700
        13,000
        10,000
        8,700
        3,200
        8,000
        2.000
        3,200
        2,200
        1,000

        450
        2,200
        430
        460
        4,100
        2,300
                                               160

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I. Comprehensive Evaluation Inspection
This section presents observations made in a review of E.I. DuPont's
facility operation in accordance with 40 CFR Part 265 Subparts B,
C, D, G, R and New Jersey subchapters 7,8,9 and 11.

These requirements address the administrative non-technical and
technical regulations and included a visual obeservation of current
waste management units and a review and evaluation of records main-
tained at the facility
1.  Waste Management Units/Observations
Pet Chem Container Storage Area  (SOI)

This container storage area is used for holding lead flue dust prior
to shipment off-site.  The containers used for storage are made of re-
inforced cardboard, with a polyethylene bag on the inside and outside.
The material is shaken from the baghouse filters directly into the
containers in a enclosed system.  The baghouse filters are maintained
at a temperature warm enough to prevent any water formation.

The lead fule dust is shipped to a secondary refiner for further process-
ing.  In the past, shipments were made to Brazil, Italy and West
Germany.

The surface area is approximately 1900 square feet (60*x 30').  The surface
is black top.  No secondary containment was observed; however, the area
was graded so runoff enters the lead recovery ditch system.

At the time of the inspection the following was noted:

    0 161 Palletized cardboard gay lords (2000 Ibs. each) with plastic
      (not stacked) Waste number-K069
    0 Adequate aisle space
    0 Containers in good condition
    0 Inspections being accomplished daily

Pet Chem Rubble Container Storage - has a surface area of approximately
27,000 square feet (265'x 105', 35'x 60').  The surface is crushed stone.
No secondary containment observed; however, the Part B describes this
area as follows: "...constructed by excavating to a depth of 30" and
backfilling with 6 oz.  sheet of Typer, 4 1/4" layer of crushed stone
and 1 1/2" layer of crushed limestone (top).  The area is sloped in the
northern direction with a 8" PVC pipe at the lower elevation which feeds
to the "A" ditch."

At the time of the inspection the following was noted:

    0 Two storage areas were observed:
                                    161

-------
      - 112 Palletized cardboard gay lords (2000 Ibs each) with plastic
        covers.  Waste number-K069

      - 8  (55) gallon containers (UN 1325) waste oil

    0 No daily inspection of waste oil storage

Chemical Waste Container Storage Area - The Chemical waste container
storage area  is divided into three principal sections:  Area A-drum
and truck trailer storage and areas B and C (truck spots).  In con-
tainer storage area "A" both liquids and solids are stored.  This
area has a surface area of approximately 23,000 square feet of
actual storage space for 55 gallon drums and approximately 7200
square feet for six truck pads.  Area A was divided into  five
sections:  Area A-l (limited access area) can hold 300 drums, Area
A-2 (Liquid storage area) 2,940 drums, Area A-3 (solid storage
area)  4,080 drums, and Area A-4 (staging area) 3,360 drums.  Total
drum storage capacity is approximately 10,680 drums.  Area A-5 is
for 6 tank tractor spots.

At the time of the inspection the following was noted:

     0 1017 (55) gallon containers in storage
     0 Staging area waste not segreated by waste type  (i.e. 18 drums
       formic acid, 4 drums phenols, 2 drums solvents.  Waste was
       received on 3/4/86 and was observed in storage on 4/3/86.

     0 Approximately 29  (55) gallon containers did not have manifest
       labels, of these; 8 were known to have corne from Finish &
       Fabricated Products Division, DuPont, Philadelphia.

     0 Overall area appeared to be extremely clean and properly monitored.

PPD Lab Waste Container  Storage - This unit is described in Part A as
a 50'x 30' area.This unit was delisted 4/13/83 as a protective filer.

PPD Area Waste Container Storage - This unit is described  in Part A as
a 50'x 30' container storage area.  This unit was delisted on 4/13/83 as
a protective filer.

Tfelomer "A" Container Storage - had approximately 800 square feet of
covered storage in building 1050.  Closure for this unit was approved
on 1/23/86.  No waste was observed in storage, floor area  appreared to
be clean and sloped toward a central drain.  Final closure pending results
of wipe test and a Professional Engineer  (PE) and facility certification
of closure.
                                       162

-------
Freon Spent Catalyst Container Storage - waste was previously stored in
a 5916 gallon vessel (railroad car) and considered D003/D004.  Closure was
approved by NJDEP on 1/23/86.

Tank Storage  (502)

Chemical Waste Management Area

Two tanks are presently in use at the Chem Waste Management area.  These
include TS-1  (10,000 gallons) and TS-2 (7,000 gallons) for storing waste
amines and waste solvents respectively.  Tanks are unlined and constructed
of carbon steel.  Tank  (TS-7) is out and Tank  (TS-1) has been permanently
removed.  Approximately a 1' dike with a sump was observed around the tank
storage area.  Weekly and daily inspections are being accomplished.

Nitrocellulose Waste Pile (S03)
The waste pile consists of residues from past nitrocellulose production.
The waste is ignitable when moisture free.  This unit  is currently under
closure.  A large fenced area in a remote section of the facility was
observed.  The closure plan for this unit was approved in 1/83 and the
last annual report was prepared in 1/86.  Closure involves tiling soil,
allowing it to dry and igniting it.

Treatment in Tanks (T01)
Telomer "A" Waste Treatment Tank.  This treatment tank on the second floor
of building 1205 is a 840 gallon vessel used to neutralize waste generated
at Packersburg (DuPont) during the manufacturing of Telomer "A".  The
spent catalyst major constituent is antimony pentafloride.  The precipitate
from this process is drumed and landfilled and the filtrate is sent via
the ditch to the WWTP.  The reaction is run as a batch.  At the time of  the
inspection, no waste was being treated.  All paper work was in order.

Incineration (T03)
FR-1 Hazardous Waste- Incinerator -  The incinerator is used to destruct
liquid wastes generated at the permittee's facilities.  The combustion
furnace is a horizontal cylindrical steel chajober lined with firebrick.
The burner is supplied by fuel lines and an atomizing steam line.  The
high pressure steam is used to atomize the waste liquid as it exits the
burner nozzle.  Combustion air is supplied to the burner nozzle via a
windbox.  On the other end, combustion gases pas through an ash trap to
a countercurrent gas. scrubber.  Any ash and liquid solution from the
trap is collected in a sump and overflows to a collection ditch.  Solids
are disposed of in the landfill. Flue gas is then subjected to a jet
scrubber and an electrostatic precipitator prior to being emitted into
the atmosphere.

Liquid waste from on-site activities include spent halogenated and non-
halogenated solvents, corosive wastes, lead contaminated wastes and a
wide variety of "U" and "P" wastes.  In 1984, over 740 tons of this
                                     163

-------
liquid waste were burned.  Off-site E.I. DuPont wastes accounted for
approximately 475 tons.  The chemical wastes are brought to the area
in either drums, trailers or tanks.  These are then preregistered with
the proper authorities, and stored prior to burning.  Wastes are fed
from storage tanks and tank trailers.

At the time of the inspection, the incinerator was not in operation.  A
paperwork review and visual inspection was accomplished.  Waste analysis
calls for spot BTU, ash and chlorides for feeds.  The facility recently
started testing for mercury and lead.  Record for waste analysis only
go back six months.

Ethyl Chloride Incinerator - The ethyl chloride waste incinerators  (FR-1A
and FR-1B) are operated as a unit.  One is kept in a standby mode while
the other is operating in case of failure.  This is necessary since the
ethyl chloride process is partially dependant on the incinerator's
availability to destruct the waste stream.  Each incinerator is connected
to the two scrubbers used for reducing the acidic combution products and
particulate matter.

The combustion furnace is a horizontal steel chamber lined with firebrick.
The burners are supplied by natural gas, waste fuel lines and an atomizer.
The waste fuels contain constituents such as nitrotoluene, chloromtro-
benzen and chlorodinitrobenzene.  A primary air blower provides combustion
air to the burner wind box and the secondary air blower is controlled by
the burner chimney temperature.

A record review and visual inspection was performed.  Waste analysis does
not address BTU value.  The facility applied for delisting of this unit
on 4/4/86..  At the time of the inspection, all equipment was operating.

Thermal Treatment T04

The thermal treatment unit consist of a furnace, afterburner, cooler and
baghouse.  This unit is authorized to decontaminate DuPont tanks, process
vessels, drums and piping.  The item(s) to be decontaminated are heated
to a sufficiently high temperature and length of time to decompose or
volatize any organics.  Vapors and particulates flow from the furnace to
an afterburner where oxidation takes place.  Particulates  (lead dust)
are collected at the baghouse.  All equipment was operating at the  time
of the inspection.

Surface Impoundments

The permitte has three surface impoundments  (Basins A,, B and C) which are
regulated under RCRA and subject  to groundwater monitoring requirements.

"A" Basin - This basin encompasses approximately 16 acres of water  surface
and has a circumference of  2600 feet.   The  impoundments water surface
elevation is at an average of  3.1" with a hard pan  at the bottom of -3.5'.
Dikes on  the southerly and easterly  sections are composed of compacted
gravel approximately 3 1/2' deep,  receives water from the "A" ditch which
is utilized as an  excess flow  basin  to  handle heavy rainfall and DOC
concentration.  Freeboard was  adequate  at  the time of the inspection.

                                      164

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 "B"  Basin - This basin,  with a circumference  of  3500',  encompasses  approxi-
 mately 17 acres of water surface and  is approximately 4'  deep.  The  hard  pan
 bottom composed of sand  and clay is at an  average elevation of  -3.5'  and the
 water  surface has an average elevation of  7.2'.  The dike  construction is the
 same as A basin.  The water which enters this unit consist of noncontact
 cooling water and effluent from the WWTP.   Discharge from this  basin  is
 to the Delaware via a 78"  line.  Freeboard was adequate at the  time of
 the  inspection.

 "C"  Basin - This basin,  put in service in  1970,  encompasses approximately
 3 acres of water surface.  The water surface has  an elevation of approximately
 10.4'  and the bottom elevation is -3.5'.  The basin is approximately  18'
 deep.   The approximate dimensions are 225'x 800'x 250'x 600'.  This basin
 receives process water (pretreated ph-adjusted)  from the  Petchem area.
 Within this area some precipitation,  coagulation and settling of lead
 metals or salts occur classifying this unit as a treatment impoundment.
 The  extent of additional reactions in this impoundment has not  been
 quantified. However, since some reaction and  physical seperation pro-
 cesses occur, this basin is considered a treatment impoundment. The unit
 is dredged which facilitates the recovery  of  lead.  Water from  this
 basin  is pumped to the "A" ditch and  then  to  the WWTP.  Freeboard was
 adequate at the time of  inspection.

 At the present time this facility is  operating three surface impoundments -
 with a capacity of approximately 91,000,000 gallons.

 Chemical Waste "C" Landfill

 The  Chemical Waste "C" Landfill consists of three areas of approximately five
 acres  each with adjoining  sides.  Waste solids from the wastewater  treatment
 plant  and bulk waste solids from manufacturing operations at Chambers Works
 and  other E.I. DuPont facilities are  landfilled  at this site.

 About  80 tons of sludge  are removed daily  from the treatment plant, filtered
 and  landfilled in the "C"  landfill.  The sludge  contains  high concentra-
 tions  of magnesium and calcium from primary neutralization, and organic
 wastes and precipitated  heavy metals,  the sludge is classified by  the type
 of wastes which flow through the treatment plant; spent solvents, treatment
•sludges from electroplating operations, cyanide  plating bath solutions,  and
 sludge and tank bottoms  from the petroleum refining industry.  In 1984,  over
 70,000 wet tons of primary sludge were removed from the treatment plant.

 Bulk waste solids from manufacturing  operations  include;  dry hazardous and
 non-hazardous chemical waste, contaminated equipment and  containers,  oil,
 spill  clean-up wastes and  oil sludges.  Typical  drummed wastes  inlcude
 organic residues, tars,  inorganic salts, cyanates, resins and waxes,
 laboratory samples, organometalics, incinerator  ash, and  ditch  cleanings.
 On-site manufacturing operations, laboratory  research and general house
 cleaning resulted in the generation of 116 tons  of a wide variety of  haz-
 ardous waste (89 tons of this material was liquid laboratory packages).
 The  waste received from  off-site E.I. DuPont  facilities for landfilling
 consists of mainly corrosive solids.

                                      165

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This first area, Area I, was constructed in 1975,  Major design features
of area I included:

      0 30 mil. "Hypalon" liner

      0 0.3% slope

      0 Leachate collection and pumping system

      0 Ground-water monitoring wells

Area T was filled in 1978.  At which time, the landfill was covered
with 2 feet of clay with a permeability of 1 x 10"7 cm/sec followed by
12 inches of top soil.  The cover was then seeded,,  The East slope,
which is contiguous with area II, was covered with 2 feet of clay with
a permeability of 1 x 10~7 cm/sec.  The South, North and West slopes
were covered with 1.5 feet of clay with a permeability of 1 x 10"'
cm/sec, all of area I was then covered with 1 foot layer of top soil
and seeded,

The second five acre section, Area II, was constructed adjoining Area
I in 1978.  Major design features include the following:

     0 Double 30 mil. "Hypalon" liners with provision for leak
       detection in the upper liner.  The bottom liner slopes
       to a separate sump for leak detection.

     0 0.3% continuous slope

     0 6 inches of sand and 6 inches of gravel above the top liners.
       Dae to poor drainage a 20 foot section of the sand was
       renxDved and replaced with gravel to improve drainage at the
       South end of the area.

     0 Leachate collection and pumping system

     0 Ground-water monitoring wells

The placement of wastes into this area started in 1979.  The second
lift was constructed in 1981.

At the current rate of disposal, there is approximately 58 months of
landfill life left.  Leachate from the landfill  is sent to the WWTP.  Lifts
are approximately 8' and II1 high.  Cover and operating records appeared  to
be adequate.
                                      166

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 Waste Water Treatment Plant (WWTP)

 The WWTP is currently operating at  approximately 30 mgd.   The commercial
 part of the operation accounts for  less than 1% of the flow; however, this
 comprises approximately 1/2 of the  RCRA treated waste and a higher percen-
 tage of TSS.  The WWTP is operating under New Jersey Pollutant Discharge
 Elimination System (NJPDES)  permit  £0005108.  The flow in the plant is as
 follows:  tank trucks pump waste into concrete lined pump pits (approximately
 100 trucks/day).   Water then enters the plant to one of 3 neutralizer tanks.
 From this point the flow passes by  a flow splitter, then  to one of 4 floculators
 and primary clarifiers.  The influent then goes to another flow splitter and
 one of three aeration tanks.  Flow  then passes to another splitter where it
 is divided between two secondary layers (secondary clarifiers).  The supernantant
 is the treated ^0. Tanks are constructed of steel or prestressed concrete.

 Capacities of the major components  of this system are:

     0  Neutralizers (3) 215,000 gallons
     0  Flow Splitter 28,900 gallons
     0  Primary Clarifiers (4j  1,000,000 gallons each
     0  Aerators (3) total volume 4,624,000 gallons full,  26,400 gpm.
     0  Secondary Clarifiers (2) 2,800,000 gallons each
     0  Sludge Storage Tanks (2) 94,933 gallons
     0  Sludge Feed Tank 10,600 gallons


 Storage Areas Less Than 90 Days

 Numerous areas within the plant store waste for less than 90 days.  Five
 areas of these were chosen for inspection.  Three of five were found to be
 storing hazardous waste out of compliance with New Jersey Hazardous Waste
v Regulations.

 White Products Area (A, B, C), inspected 4/18/86

     -  Waste in storage consisted of 3 (55) gallon drums  of D001
        (characteristic - ignitable  waste) placed in storage on 4/7/86.

     -  Weekly inspections being performed

     -  Reportedly generates/stores  30/40 drums/2 weeks.

 Building 4066, inspected 4/10/86

     -  Waste in storage consisted of 55 gallon drums:

        -  14 drums of nitro toluene/benzene
        -  3 drums Para Choroaniline (P024), accumulation  start dates
           2/23/86, 3/21/86, 2/23/86
           4 open drums unlabeled looked like PO24
        -  4 drums, P024, no accumulation start dates
                                      167

-------
       -  No  daily inspections
    Jackson Labs,  Inspected 4/10/86

       -  Waste in storage consisted of approximately (200)  55 gallon
          drums

       -  Approximately (100)  55 gallon drums consisting of K025, P077,
          U133 with accumulation start dates 3/19-3/24 stored on a flat
          bed truck

          8 drums  (lab packs)  of which 2 were open,,  i.e. rings missing,
          with accumulation start dates of 3/19-4/1/86

          4 rusted unknown drums including 1 overpack leaking, no
          label and open

          No daily inspection

       -  Inadequate aisle space.  Drums (approximately 100) were stored
          4x3 pallets and 3 high on asphalt

       -  Drums reportedly are stored a "couple of months".
Landfill (non-hazardous) - Itiis landfill was inspected to insure that only
non-hazardous waste was being disposed at the site.  No hazardous waste was
found at the site.
                                    168

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2.  Review and Evaluation of Facility Records


Waste Analysis

Tne Waste Analysis Plan (WAP) used at DuPont can be divided into three
different plans including; a WAP for DuPont Chambers Works waste, intra-
company waste and outside business (commercial) waste.

    0  WAP - DuPont Chambers Works - All generators of waste have their own
       WAP.  In most cases these plans are complete with the exception of
       insuring a generator take into account the Appendix VIII constituents.
       Any generator specific comments are contained with the section
       titled "Unit Description".

    0  WAP - Intra-Company Waste - This plan is a combination of Chambers
       Works WAP and Outside Business WAP.

    0  WAP - Outside Waste Business - This facility has extensive
       operating procedures to insure that only waste for which the facility
       is authorized and capable of handling is accepted.  Important features
       of this plan include seal security program, sampling all shipments,
       complete waste analysis comparisons on early shipments.  The business
       can be broken down into two phases acceptance protocol with the customer
       completing a waste characterization questionaire.  Information on this
       questionaire include PCRA hazardous waste number, major components and
       process generating the waste.  Dupont then collects a sample and analyzes
       it.  A decision is then made whether to accept or not to accept this
       waste.  If the waste is accepted, specifications and a contract are
       drawn up.  At this point, delivery and disposal takes place.  Delivery
       involves scheduling tank trucks at thirty minute intervals for dumping
       into the ditch.  Trucks are weighed and sample manifests are checked.
       The first delivery of a waste stream involves extensive analysis.
       Future deliveries of the same waste only require analysis such as DDL,
       TSS, and total acidity.  The only problem noted with this plan is that
       it does not address Appendix VIII constituents.  It addresses priority
       pollutants


Closure Plan/Cost Estimate Review (Interim Status)

General Comments

    0  Milestone chart and cost estimate needed for closure of the entire
       facility,  (i.e. Certain units must be closed after other units.
       The sequence of closure will greatly effect the cost estimate.)

    0  Decontamination procedures for most units are too vague (i.e. methods
       of decontamination, test parameters to insure decontamination is
       complete, soil sampling plans etc.)

    0  Certification of closure by an independent registered professional
       engineer and the owner or operator must be submitted to the NJDEP
       for all units.  Additionally, cost estimates for certification must

                                    169

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       be taken into account.


    °   Closure cost estimates  not broken down adequately to allow for
       analysis of cost estimate adequacy.

    0   Closure of the ditch system not addressed  in closure plan.

Individual Unit Comments

    0   Landfill

       -  Parameters to test to insure decontamination is complete.

    0   FR-65 and Rubble Storage Area

       -  Methods to insure decontamination is complete for unit, decon-
          tamination equipment and grounds  (i.e., soil sampling plan,
          parameters, wipe test, etc.).

       -  Maximum inventory of drummed waste and  cost of disposal (is  the
          drummed waste going  to be landfilled at DuPont?)

    0   Pet Chem Area/Lead Flue Dust Storage Area

       -  Maximum inventory of waste, cost  of disposal (at closure the
          plan reports that the area will contain no hazardous waste;
          however, in the Milestone Chart,  "Step 2" states, "Sample and
          analyze storage material".

       -  Methods to insure decontamination is complete for decontamina-
          tion equipment and grounds (i.e.  soil sampling plan, parameters,
          wipe test) .

    0   Chem Waste Area, FR-1 Incinerator, Container and Tank Storage

       -  Method and procedures used to decontaminate the FR-1 incinerator,
          all tanks loading and unloading areas,  containers storage area,
          sumps, etc.

       -  Method and procedures used to insure decontamination is complete
          (i.e. wipe test, soil sampling plan, parameters).

       -  Cost estimate for closure of this  unit not delineated sufficiently
          to allow review.

       -  Ethyl Chloride Incinerator

          -  Method and procedures used to decontaminate equipment grounds.

          -  Method and procedures used to insure decontamination is complete
              (i.e. soil sampling plan, wipe test)
                                    170

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-  A & B Basins
      Soil sampling plan and parameters which will be used to test
      underlying soil
   WWTP
   -  Parameters and test method for all equipment, grounds, etc.
      to insure decontamination is complete.
                             171

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APPENDIX 1
      1U7-02-8
       67-64-1
      1U7-13-1
       71-43-2
       75-27-*
       75-25-2
       74-B3-9
      108-90-7
       75-00-3
      110-J5-8
       67-66-3
       74-87-3
       96-12-8
      124-46-1
      106-93-4
       75-34-3
      107-06-2
      156-60-5
      156-60-5
       75-09-2
       78-d7-5
   10061-01-6
   10061-02-6
      123-91-1
      100-41-4
       78-93-3
      110-H6-1
      100-42-5
       95-94-3
                                                     TOC
         CASRN   Substance
                 e240
Acrolein                     ^
Acetone                      A
Acrylonitrilc              '  A
Benzene                      A
Brcnodichlorcnethane         A
Broraoform                    A
Brofiocnethane                 A
Chlorobenzene                A
Chloroethane                 A
2-Cnloro«thyl vinyl «th«r    A
Chloroform                   A
Cnlorooeth^ne                A
l,2-Dibramo-3-chloropropane  A
Dibroraocnloromethane         A
1,2-Dibraccoethane            A
1,1-Dichloroethane           A
1,2-Oichloroethane           A
tran»-l,2-Dichloroethene     A
1,2-Dichloro«thene           A
Oichloromethane              A
1.2-Dichloropropane          A
cis-1.3-Dichloropropene      A
tran*-l,3-Dichloropropene
l(4-0ioxane                  A
Ethylbenzene                 A  D
Methyl «thyl ketone (MZK)    A
Pyridine                     A
Styrene                      A
1,2,4,5-Tetrachlorob«nzen«   A
1,2,3,4-T«trachlorob«nz*ne   A  D

-------
  (METHOD   6240  (continued)
 79-34-5   1,1,2.2-7etrachloroethane
127-1S-4   Tetrachloroethene
 56-23-5   Tetrachlororaethane
10B-63-3   Toluene
 7.5-25-2   Tribroinorae thane
120-82-1   1,2,4-Trichlorob«nzene
 7.L-55-6   1,1,1-Trichlorcxtha.ne
 79-00-5   1,1,2-Trichloroethane
 79-01-6'  Tricnloroethene
 715-01-4   Vinyl chloride
                                   A
                                   A
                                   A
 79-06-1
624-63-9
Acrylajaide
Zsocyanic acid
A
A.

-------
HE7HOJ B240-DI

123-91-1   1.4-Dior*ne
107-02-3   Acrolein
107-13-1   Acrylonitrile
 79-06-1 .  Acryla
110-42-5   Pyridine

-------
            jrs t a-ce
            ti270
  83-32-9   Acenaphthene                      JV  D
 208-96-8   Acenaphtalene                     A  D
  62-53-3   Aniline                           A  D
 120-12-7   Anthracene                        A  D
  56-55-3   3enz[ajanthracene                 A
  92-87-5   Benzidine                        A
  56-55-3   Benzo(a)anthracene               A
 205-99-2   Benzo[bjflooranthene             A
 207-Od-9   Benzo[X]fluoranthene             A  D
  50-32-8   BenzoLa3p/r«ne                   A
 191-24-2   Benzo[g,h,i]peryl«ne             A  D
 100-44-7_  Benzyl chloride                  A
 111-91-1"  Bii(2-chloroethoxy)m*thane       A
 108-60-1   Bi»(2-chloroi»opropyl) «ther     A
 117-81-7   Bi«(2-«thylhexyl)phthalat«       A
 101-55-3   4-Broiaophenyl phenyl »th«r       A
  813-68-7   Butyl benzyl phthalate           A
 106-47-8   p-Chloroaniline                  A
  59-50-7   p-Chloro-m-cre»ol                A
  91-58-7   2-Chloronaphthalene              A
  9!>-57-8   2-Chlorophenol                   A
700!>»72-3   Chlorophenylphenyl «ther         A  D
.218-01-9   Chry*ene                         A
  53-70-3   Dibenz[a,hjanthracene            A
 132-64-9   Dibenzofuran                     A  D

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           B270  (CDST'D)

100-01-b   <*-iN*itroar.iline                    A
 98-95-3   Nitrobenzene                      A
 Bb-75-5   2-Nitro?henol                     A  D
100-02-7   4-Nitrophenol                     A
 62-75-9   N-Nitro»oditnethylajaine            A
621-64-7   S-Nitro»oiipropyl«jtine            A
60d-93-5   Pentachlorobenzcne                A
 b2-6B-B   Pentachloronitroberxzene (PCNB)    A
 87-B6-5   Pentachlorophenol                 A
120-12-7   phenanthr«nc                      A  D
108-95-2 - Phtnol                            A
129-00-0   pyr«nc                            A  D
 95-94-3   1,2,4,5-T«trachlorobenrtne        A
           1,2,3,4-Tetr*chlorob«nz«n«        A  D
120-82-1   1,2,4-Trichlorobenr.ene            A
 95-95-4   2,4,5-Trichloroph«nol             A
 88-06-2   2,4,6-Trichlorophenol             A

          •2,3,7,8-Tetrachlorodibenro-
           p-dioxin
           •Scanned for but no standard available

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   MITHOD   62 70(COST'D)
  84-74-2
  *5-50-l
 541-73-1
 106-46-7
  91-94-1
 120-83-2
  94-75-7
  64-66-2
 105-67-9
 131-11-3
 534-52-1
  51-28-5
 121-14-2
 606-20-2
 117-8-4-0
 122-39-4
 206-44-0
7782-41-4
  87-68-3
  77-47-4
  67-72-1
 193-39-5
  78-59-1
  95-48-7
 106-44-5
  91-20-3
 Di-n-butyl  phthalate
 1,2-Dichlorobe.irenc
 1,3-Dichlorobenzene
 1,4-Dichlorobenzene
 3,3'-Dichlorobenizidine
 2,4-Dichlorophenol
 2,4~Dichlorophenoxyacetic  acid
 Diethyl  phthalate
 2,4»Diraethylph«nol
 Dinmthyl phthalate
 4,6-Dinitro-D-cr«»ol
,2,4-Dinitrophenol
 2«4-Dinitrotolu«ne
 2,6-Dinitrotoluene
 Di-n-octyl  phthalate
•Diphenylamine  .
 Fluoranthtne
 Floor«ne
 Hexachlorobutadiene
 H«xachlorocyclop«ntadiene
 Hexachloroethane
 Indeno(l,2,3»cd)pyr«ne
 Icophorone
 2-Methyl Phenol
 4-««thyl Phenol
 Naphthalene
A
A
A
A
A

A
A
A
A
A
A

A
A
A  D
A  D
A  D
A
A
A
A
A  D
A  D
A     (CRSSOLS) D
A

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 METHOD 8080

 Aldrin                                    A
 Alpha BHC                                 K
 Beta  BHC                                 A
 Delta *BHC                                 A
 •Camna BHC (Lindane)                        A
 Chlordane                                 A
 4,4'-DDD                                  A
 4,4'-DD£                                  A
                                           A
                                           A
 Endosulfan I                              A
 Endosulfan II                             A
 Endosulfan Sulfate                        A
 Endrin                                    A
 Endrin alde'hyde                           A
 Heptachlor                                A
 Ktptachlor «poxide                        A
 rfethoxychlor                              A
 Toxaphene                                 A
• PCB-1016                                  A
 PC3-1221                                  A
 PCS-1232                                  A
 PCB-1242                                  A
 PCB-1243                                  A
 PC3-1254                                  A
 PCB-1260                                  A

-------
Appendix VIII

METHOD   €010

Aluminum                                   B D
Barium                                     B
Beryllium           •                       B
Boron                                      B D
Cadmium                                    B
Chromium                                   B
Iron                                       B D
L«ad                                       B
Nickel                                     B
Thallium                                   B
Vanadium                                   B D
Zinc                                       B D
Selenium*                                  B
Arsenic''                                   B
•These elements are not approved for 6010 but they are approved for
 CLP metals 1C? method.  The CLP netals ICP method is identical to
 •the 5W-846/6010.
Method 7470

Mercury                                    B

-------
Appendix VIII METALS   (3 status but determine-d  in  Pha»e  I)

METHOD   6010

Aluminum                                   B D
Barium                                     B
Beryllium                                  B
Boron                                      B D
Cadmium                                    B
Chroctiua                                   B
Iron                                       B D
Lead                                       B
NicXel                                     B
Thallium                                   B
Vanadium'                                  B D
Zinc                                       B D
Selenium*                                  B
Arsenic*                                   B
*The*e elements ajre not Approved for 6010 but they are approved for
 CLP metals ICP loethod.  The CLP neta.lt ICP method it identical to
 the SW-846/6010.

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        CAS.-»;  Substance

       METHOD   8240
      75-15-0
    4170-30-3
     764-41-0
      75-71-8
      75-35-4
   10061-02-6
      57-14-7
     591-78-6
   •   74-86-4
Carbon diaulfide              13
Crotonaldehyde                B
1.4-Dichloro-2-butene         13 D
Dichlorodifluoromethane       B D
1,1-Dichloroethene            IB
trani-1,3-Dichloroprop«ne
ci»-l, 1-Dimethylhydrazine     IB
Kexanone                      B
lodontthan*                   0
P«nt«chloro«th».n«             B
1,2, 3, 5-T«tr»chlorobenzene    IB D
  HETHOD   8240 (continued)

630-20-6   1,1,l,2-T«tr*chloro«th*ne
 75-70-7   Trichlororn«th*nethiol
 96-18-4   l,2,3-Trichloroprop*ne
 95-35-4   Trinitroc>«ni«n*
 75-01-4   Vinyl Acetate

 75-05-8   Ac*tonitril«
 75-69-4   Fluorotrichloromethane
542-75-6   1,3-Dichloroprop«ne
                              B
                              B
                              B
                              B    (1.3.5-)
                              B D

                              B
                              B
                              B D
                              B

-------
   MtTHOD   B270(C^T'U)
  67-65-0   2,6-Dichloroph«nol                 B
  60-11-7   p-Dirðylairu.noaz.obenz«ne          B
  57-97-6   1,12-Dijnethylbenz[a]anthracene     B
 122-09-B   *lpha, alpha-DiraethylphenethylaJsine B
 122-66-7   1,2-Diphenylhydrazine              B
  97-63-2   Ethyl methacrylate                 B D
  62-50-0   Ethyl nethanesulfonat*             B
1B8B-71-7   Hexachloroprop«ne                  B
 120-58-1  * I»osafrole                         B
 146-B2-3   Melphalan                          B
  91-BO-5   H*thaperyl«n«                      B 0
  79-22-1   Methyl chlorocarbonat*             B D
 101-14-4   4,4'-««thyl«ne-bi«-(2-chloroanilin«)    B
 108-10-1   4-«ethyl-2-p«ntanon«               B D
  66-27-3   Mtthyl methanesulfonat*            B
  91-57-6   2-««thyl Napthalene                B D
  56-04-2   Hethylthiouracil                   B
 130-lb-4   1,4-Naphthoquinone                 B
 134-32-7   1-Naphthylanine                    B
  91-59-8   2-^aphthylajuine                    B

-------
     J AS .=.-.'  S j DS t a r, r e
    WITHCD   e270
   9d-d6-2   Acetophcnone                      B D
17364-30-6   2-Acetyla.iiinofluorene             B
   92-67-1   4-Aainofciphenyl                   B
 2763-96-4   5-(X.tinom*thyl )-3-i«oxazolol      B
  140-57-4   Ara^ite                           B
  108-98-5   Benz«nethiol                      B
   65-B5-0   Benzole Arid                      B D
  106-51-4  f p-Benzoquinone                    B D
  100-51-6  " Benzyl Alcohol                    B D
   68-85-7   2-*«c-Uutyl-4,6-dinitroph«nol     B D
  542-76-7   3-Chloropropionitrile             B
  131-89-5   2-Cyclohexvl-4,6-dinitrophenol    B
  226-36-6   Dibenz[ft,hjacritiin«               B

-------
    .'1£7.-iOD   8273  (COST'S)

   63.74.4   2-N'itroaniline                      B  D
   99-09-2   3-Hitroaniline                      B  D
  924-16-3   N-Nitrotodi-n-butylajnine        •    B
 lllfc-54-7   N-Nitrosodietha.nolanine             B
   55-18-5   N-Nitro»odi€thylaaine               B
10595-95-6   N-Nitroso.nethylethylajru.ne           8
  615-53-2   N-Nitro*o-iJ-methylurethane          B
   59-89-2   N-Liitrotoroorpholine                 B
  100-75-8   N-Nitrosopiperidine                 B
  930-55-2   N-Nitro*opyrrolidine                B
   95>»55-2   5-;N*itro-o-toluidin«                 IB
   76-01-7"  Pentachloroethane                   B
   t2-44-2   Phtn»c«tift                          IB
  109-06-8   2-Picoline                          IB  D
   94.59-7   SafrolB                             B
             1, 2, 3, 5-T«tr*chlorobe.iz«ne          B  D
   58-90-2   2(3,4,6-Tetrachlorophenol           B
  636-21-5   6-Toluidine hydrochloride           B
   75-70-7   Tnchlororoethanethiol               B
   95-35-4   Trinitrobenxene                     13
  126-72-7   Tri«(2,3-dibroraopropyl) pho«phmt«   B
   61-82-5   Ajnitrole                            13
  504-24-5   4-AninopyriJine                     13
   9(3-07-7   Benzotrichloro.de                    13
  357-57-3   Brucine                             13
 1338-23-4   2-Butanone peroxide                 H
  510-15-6   Chlorobenzilate                     13
  106-89-8   l-Chloro-2,3-epoxypropane           B

-------
 3270  (CCN'T'D)
,    So-18-0
  2303-16-4
   311-45-5
    55-91-4
    60-51-5
   119-90-4
   119-93-7
    77-78-1
   298-04-4
   541-53-7
    96-45-7
    62-74-8
    64-16-6
    70-30-4
 .   53-86-1
16752-77-5
    75-55-6
    56-49-5
    70-^5-7
    56-57-5
   684-93-5
   145-73-3
   123-63-7
   108-45-2
  1120-71-4
   10d-46-3
    57-24-9
  J689-24-5
    7d-00-2
   126-72-7
   108-31-6
   123-33-1
   109-77-3
    dl-81-2
 Cyclophosphajnide                   B
 Diallat*                        '   B
 0,0-0i«thylpho$phoric acid         B
 Di-i»opropylfluorophosphate (DFP)   B
 Diraethoat*                         B
 3,3'-Dimethoxybenzidine            B
 3, 3'-Diiaethylbenzidin*             fi
 Dimethyl »ulfat«                   B
 Disulfoton                         B
 2,4-Dithiobiur«t                   B
-Ethyl«nethiour«a                   B
 Fluoroacetic acid          (Salt)   B
 Formic acid                        B D
 Bexachlorophtnc                    B
 Zndometacin                        B
 Mcthomyl                           B
 2-W«thylariridine                  B
 3-M«thylcholanthr«ne               B
 S-Wethyl-N'-nitro-N-nitrosoguanidine
 4-Nitroquinoline-l-oxid«           B
                                    B
                                    B
                                    B D
                                    fi D
                                    B
                                    B
                                    B
                                    B
                                    B
                                    B
                                    B
                                    B D
                                    B
                                    B
                                         B
Endothal
Paraldehyde
Phenylenedia,tiine     (o,m,p)
1,3-Propane sultone
Resorcinol
Strychnine
Tetraethyldithiopyropho»phate
Tetraethyl l«ad
Tri» (2, 3-dibrcraopropyl) phosphate
Kaleic Anhydride
Haltic hydra^ide
Malononitrilc
Warfarin

-------
ri£7HOD B240-DI

107-18-6   Allyl alcohol                      B
100-51-6   Benxyl alcohol                     B D
 75-d7-6   Chloral                            B D
           Chloroacttal Jchyde                 Et
460-19-5   Cyanogen                           B
           Dichloropro]>anol                   B
           Ethyl Cyanicl*                      B
 75-21-d   Ethyl«ne Oxide                     B
765-34-4   Clycidylald«hyde                   B
302-01-2   Hydrazine                          B
 78-83-1   Iiobutyl alcohol                   B
126-i39-7   Hethacrylonitrile                  B
 6J-34-4   Methyl hydraiinc                   B
 75-86-5   2-Wethyllact.onitrile               B D
 **0»62-6   Methyl methacrylat*                B.
107-19-7   2-?ropyn-l-ol                      B

-------
rtETHOD 3080

Kepone
           METHOD 6150          H«rbicid«§
           2,4,5-T                        B
           Dinoseb                        3

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