May 1987                     EPA-700 8-87-015
 SEPA
 Hazardous Waste Ground-Water
 Task Force
 Evaluation of the
 IT Panoche Facility
 Benicia, CA
US Environmental Protection Agency

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                                      EPA-7008-87-015
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS  WASTE GROUND WATER TASK FORCE
                      GROUND WATER MONITORING EVALUATION
                          IT PANOCHE DISPOSAL FACILITY
                              BENICIA, CALIFORNIA
                                    May  1987
                                 Hannibal Joma
                                 Project Leader
                     U.S.  Environmental Protection Agency
                                    Region  9
                            U.S. Environmental Protection Agency
                            77 West Jackson Boulevard, 12th floor
                            Chicago, IL  60604-3590

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                                CONTENTS

I.   Executive Summary

     A.  INTRODUCTION                                                1
     B.  OBJECTIVES                                                  1
     C.  INVESTIGATION METHODS

          1.  Sampling Program                                       2
          2.  Records Review                                         2
          3.  Facility Inspection                                    3
          4.  Facility Sampling Audit and Laboratory  Evaluation      3

     D.  TASK FORCE PARTICIPANTS AND ROLES                           4
     F.  SUMMARY OF FINDINGS AND CONCLUSIONS                         4

          1.  Contamination in Ground Water and Potential  Impact
                on Surface Water and Soil                            5

               1.1  Statistical Analysis Results                     5
               1.2  HWGWTF Analysis Results                          5

          2.  Compliance with §265 and §264 (40 C.F.R.)

               2.1  Evaluation of Construction of Monitoring Wells   8
               2.2  Evaluation of Detection and Assessment
                      Monitoring                                     8
               2.3  Evaluation of Upgradient Background Wells       10
               2.4  Ground Water Sampling and Analysis              10

          3.  Additional Information Requirements,  §270(40 C.F.R.)

               3.1  Hydrogeologic Characterization                  11

          4.  Compliance with Superfund Off-Site Policy             13
          5.  Facility Sampling and Laboratory Audits

               5.1  Results of HWGWTF Sampling Audit                14
               5.2  Results of HWGWTF Laboratory Audits             15
                                                      •
II.   DATA REVIEW

     A.  SITE DESCRIPTION AND ADJACENT WATER/LAND USE               17
     B.  WASTE MANAGEMENT UNITS AND FACILITY OPERATIONS             17

          1.  Background                                            18
          2.  Wastes Managed by the Facility                        19
          3.  Surface Impoundments                                  20
          4.  Landfills                                             20
          5.  Bio-Areas                                             21
          6.  Waste Piles                                           22
          7.  Drum Buria/1' .A^eas ,,* •-, ,  ,,*,,,,,  , = t>                     22
          8.  Current Status "of .".Operattprii ; at/'the Facility

               8.1  Landfill Expansion;'* /, ']t*' ei\                    22
               8.2  Drum Burial' iCrea A.sfse"sVmVnt''                    25

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C.  SITE  PHYSIOGRAPHIC SETTING,  TOPOGRAPHY                    25
D..  SITE" GEOLOGIC/HYDROGEOLOGIC, AND  STRUCTURAL SETTINGS

      1.   Geological  Setting                                    26
      2.   Hydrogeologic Setting                                 28
      3.   Structural  Geology                                    30

           3.1  Need  for Additional  Fault  Investigations        30

E.  GROUND WATER'MONITORING SYSTEM                             33

      1.   Well Design and Development/Well  Information          34
      2.   Evaluation  of Detection Ground Water Monitoring
           System                                              45

           2.1  Construction Evaluation                         45
           2.2  Location Evaluation                             47

      3.   Aquifer Test/Identification  of Lower Boundary         48

F.  CONTAMINANT PLUMES, FACILITY'S  ASSESSMENT MONITORING
      PLANS                                                    50

      1.   Area West,  Southwest of Ponds 12-16                   51
      2.   North Drum  Burial Area                                53
      3.   Ponds 0, P  and Q Area                                 54
      4.   Area South  of Ponds 1 and  2                           54

G.  EVALUATION OF FACILITY'S ASSESSMENT PLANS

      1.   Ponds 12 Through 16                                   55

           1.1  Additional EPA Requests                         56

      2.   South of Ponds 1 and 2                                57

           2.1  Additional EPA Requests                         53

      3.   Ponds 0, P, Q, and Solid Waste Management Unit  61     59

           3.1  Additional EPA Requests                         59

      4.   North Drum  Burial Area                                61

      5.   South of Pond 8 Series                                61

      6.   Summary of  Evaluations Regarding Detection and
           Assessment Monitoring                               62

H.  SUMMARY OF STATISTICAL ANALYSIS PERFORMED ON FACILITY'S
      DATA, AND PWGWTF SAMPLING RESULTS

      1.  Ground Water Statistical Results                      63
      2.  HWGWTF Ground Water Sampling Results                  65
      3.  HWGWTF Surface Water and Soil Sampling Results        66

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     I.  REVISIONS REGARDING SAMPLING AND ANALYSIS PLANS
     J.
 1. -Ground Water Sampling and Analysis
 2.  Surface Water and Soil Sampling

EVALUATION OF STATISTICAL METHODOLOGY PROPOSED BY
  IT CORPORATION FOR THE PANOCHE FACILITY
REFERENCES

ATTACHMENTS

     Attachment A

     Attachment B

     Attachment C

     Attachment D


     Attachment E

     Attachment F
                                                                   67
                                                                   68
68

69
TABLES

     Table 1

     Table 2

     Table 3


     Table 4


     Table 5

     Table 6

     Table 7

FIGURES

     Figure 1

     Figure 2
           IT Panoche Sampling and Documentation Report

           IT Panoche Ground Water Sampling Audit

           IT Panoche Laboratory Audit Report

           Review of the Statistical Methodology Proposed by
             IT Corporation for the Panoche Facility

           Chronology of Ground Water Enforcement Actions

           Ground Water Investigations Underway at IT Panoche
             Pursuant to RWQCB Cleanup and Abatement Order.
           Addiditonal Activities Required by EPA as a Result
             of the Task Force Report.
      Beneficial Water Use in the Vicinity of IT Panoche Facility

      General Characteristics and the Wells in Each Cluster

      ANOVA Test Results for the Indicator Parameters Between
        Background Well (MW-16) and Other Selected Wells

      Average Concentrations (mg/L) of Selected Indicators in
        Wells MW-16,  MW-35 Through MW-39

      HWGWTF Ground WAter Monitoring Data, August 1986

      HWGWTF Surface Water Quality Data, August 1986

      HWGWTF Soil Quality Data, August 1986



       Site Location Map

       Borehole Location Map (including Location of Waste
         Management Units)
     Figure 3   Expansion Project Plan

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Figure 4 .. Project Cross-Section



Figure 5   Regional Physiographic Map



Figure 6   Geologic Map of the Panoche Facility



Figures 7A-7E   Geologic Cross-Sections



Figure 8   January Ground Water Contour Map



Figure 9   August Ground Water Contour Map



Figure 10  Watershed Boundaries



Figure 11  Top of the Unweathered Bedrock Contour Map



Figure 12  Air Photo Lineament Interpretation Map



Figure 13  Log of Trench T-79



Figure 14  Log of Trench T-43



Figure 15  Typical Shallow Well Construction



Figure 16  Typical Deep Well Construction



Figure 17  Seeps and Soil Samples Location Map



Figure 13  Location of Proposed Wells at the North Drum Burial Area

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I.   EXECUTIVE SUMMARY

     A.   Introduction

              Resource Conservation  and Recovery  Act  (RCRA P.L.  95-580),
         regulates  the operation  of  hazardous  waste treatment,  storage
         and disposal facilities  (TSDFs).  Regulations  promulgated  pur-
         suant to RCRA (40 C.F.R.  Parts 260  through 265,  effective on
         November 19,  1980 and subsequently  modified)  address  hazardous
         waste site operations including monitoring of ground  water to
         ensure that hazardous waste constituents are  not released to
         the environment.  The  regulations  for  TSDFs are implemented
         (for EPA administered programs) through  the hazardous waste
         permit program as outlined  in  40  C.F.R.  Part  270.

              The Administrator of the  Environmental Protection Agency
         (EPA) established a Hazardous  Waste Ground Water Task Force
         (Task Force)  to evaluate the level  of compliance with ground
         water monitoring  requirements  at  commercial off-site  TSDFs and
         address the causes of poor  compliance. The Task  Force is  com-
         prised of  personnel from the EPA  Headquarters core team,  the
         Regional Offices  and  the States.

     B.   Objectives

              The primary  objectives of the  inspection at IT Panoche were
         to  evaluate:

              "  Compliance with  the regulations  in 40 C.F.R.,  Part 265,
                 Subpart F, "Interim Status  Standards  for Ground Water
                 Monitoring",  and potential  compliance with the rules set
                 forth in  Part 264,  "Standards for Owners and  Operators
                 of Hazardous  Waste  Treatment,  Storage, and Disposal
                 Facilities" and  Part 270, Subpart B,  Section  270.14(c),
                 "Additional Information Requirements."
                 *
              *  Potential contamination in  the ground water.

              0  Compliance with  ground water  aspects  of  the Superfund
                 off-site  policy.

              The IT Panoche facility has  received wastes from Superfund
         Sites where response  actions are  being conducted under  the Com-
         prehensive Environmental Response,  Compensation  and Liability
         Act (CERCLA - P.  L. 96-510). Under  current policy,  specific
         land disposal units used for Superfund Wastes must be in  compli-
         ance with  the Part 265 ground  water monitoring requirements,*
         and new provisions of Superfund Amendments and Reauthorization
         Act of 1986 (SARA).
        * May 6, 1985 memorandum from Jack McGraw on  "Procedures  for
          Planning and Implementing Off-site Response" or constituents
          that have migrated from the waste management area to the
          upper-most aquifer underlying the facility.

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                              -2-
  .. More specific objectives of the investigation were to determine
    if:

    1.  The ground water monitoring system can immediately detect
        any statistically significant amounts of hazardous waste

    2.  Designated RCRA monitoring wells are properly located and
        constructed (to the extent possible).

    3.  IT Panoche has developed and is following an adequate plan
        and procedures for ground water sampling and analysis.

    4.  Required analyses have been conducted on samples from the
        designated RCRA monitoring wells.

    5.  The ground water quality assessment program plan is
        adequate.

    6.  Recordkeeping and reporting procedures for ground water
        monitoring are adequate.

         To accomplish these objectives, the Task Force investiga-
    tion was divided into several discrete phases. These included,
    a ground water and soil sampling program, laboratory audits, a
    sampling audit, facility inspection and a complete record review.

C.   Investigation Methods

     1.  Sampling Program

              The sampling program (from August 13,  1966 through
         August 29, 1986) involved ground water sampling of 32
         facility wells, 6 ground water seeps, and one soil sam-
         pling. Peter Rubenstein of EPA Region 9 Field Inspections
         Section conducted the sampling with the Task Force sampling
         contractor Versar Inc. Sampling documentation report is
         included as attachment A of this report*

     2.  Records Review

              Records were reviewed at IT Panoche to verify infor-
         mation currently in Government files and to supplement
         them with any new information. The facility records were
         reviewed regarding waste types and volumes received,
         design and construction of waste management units, and
         ground water monitoring.

              Specific documents and records of interest included
         the ground water sampling and analysis plan, the ground
         water quality assessment program, analytical results from
         past ground, water sampling, monitoring well location,
         construction data and logs, reports of site hydrogeological

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                         -3-
    conditions,  site operation plans, facility permits, unit
    'design reports,  position description,  and qualifications
    of selected personnel including experience and training
    (relating to the required ground water monitoring), and
    operating records showing the general types and quantities
    of waste disposed of at the facility and their locations.

3.  Facility Inspection

         The facility inspection (concurrent with sampling
    event) assessed the waste management operations and pollu-
    tion control practices, including surface drainage and
    leachate management. The inspection also included identi-
    fication of pre-RCRA (i.e., before November 19, 1980)  waste
    management units and their potential impact on ground water
    quality. The locations of all designated RCRA monitoring
    wells, their depths, construction materials and security
    were verified.

4.  Facility Sampling Audit and Laboratory Evaluation

         Another field investigation portion of this program
    was the audit of the facility's sampling procedures.
    During the first two weeks of May, 1986, the facility
    conducted their required quarterly sampling for RCRA and
    State permitting. Task Force personnel observed and
    critiqued the facility's sampling and shipping procedures
    during that time. The sampling audit report for this
    portion of the program is included as attachment B.

         Laboratory audits of two of the facility's off-site
    labs were conducted by regional chemist, Kevin Wong. The
    first audit was conducted on IT's predisposal waste
    analysis lab,, located at the IT Vine Hill Facility in
    Martinez, California, on March 3rd and 4th, 1986. The
    second audit was conducted at IT's laboratory in Pittsburg,
    Pennsylvania, on May 12th and 13th, 1986. The last audit
    was conducted on IT Panoche oil-site lab on August 27th,
    1986. The lab audit reports are included as attachment C
    of this report.

         The off-site laboratories were evaluated regarding
    their respective responsibilities under the ground water
    sampling and analysis plan and predisposal waste analysis.
    Analytical equipment and methods, quality assurance
    procedures,  and documentation were examined for adequacy.
    Laboratory records were evaluated for completeness,
    accuracy, and compliance with State and Federal require-
    ments. The ability of each laboratory to produce quality
    data for the required analyses, and its past documented
    history of doing so, were evaluated.

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                              -4-


D.  Task Force Participants and Roles

    Dan Sullivan - EPA HQ, Core Team Representative.
    Peter Rubenstein - EPA Region IX, Sampling Program Leader.

    Kevin Wong - EPA Region IX,  Audited On-site and Off-site
    Facility Laboratories.

    Donn Zuroski - EPA Region IX, Sample Team Member.

    Hannibal Joma - EPA Region IX,  Project Leader.

    Darcy Higgins, John Hatcher,  Alicia Fleitas,  Don Paquete,
    Mark McElroy, Dan Campbell,  Randy Vanhoozer - Versar Inc.,
    Sample Team Members.

    Additionally, Dennis Parfit,  SWRCB - Patti Barni, DOHS,  and
    Wil Bruhns,  RWQCB were present  on-site occasionally during
    the interviews of the facility's personnel.

E.  Summary of Findings and Conclusions

         The results .of the HWGWTF  investigation at the IT Panoche
    Facility are discussed in the following paragraphs. The
    evaluations deal with the primary objectives of the investigation
    which were:

     1.  Contamination in the ground water.

     2.  Compliance with "Interim Status Requirements", $265
         (40 C.F.R.), and "Standards for Owners and Operators  of
        ' Hazardous Waste Treatment,  Storage and Disposal Facilities",
         §264 (40 C.F.R.).

     3.  Compliance with "Additional Information Requirements",
         §270 (40 C.F.R.).

     4.  Compliance with Superfund  off-site policy.

     5.  Facility sampling and laboratory audits.

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                               — 5 —
1.   Contamination in Ground Water and Potential Impact on Surface
    Water and Soil;

1.1  Statistical Analysis Results

          The results of statistical analysis performed on IT's
     data, by EPA's  contractor,  indicate that relative to the
     background, the ground water in the alluvium and weathered
     bedrock is contaminated and there is a possibility that ground
     water in the upper unweathered bedrock is contaminated as
     well. Statistical analysis  shows that 29 wells,  screened in
     alluvial and/or weathered bedrock,  are contaminated by indi-
     cator parameters (chloride,  sulfate, total organic carbons,
     total organic halogens/ and specific conductance), and various
     heavy metals.  These wells  are:  MW-1, MW-2B,  MW-7,  MW-10,
     MW-13,  MW-14, MW-17, MW-21,  MW-22,  MW-25, MW-26,  MW-27, MW-28,
     MW-29,  MW-31, MW-34, MW-41,  MW-43,  MW-45, MW-46,  MW-47, MW-48,
     MW-49,  MW-51, MW-52, MW-53,  MW-56,  C2 and C6.

          Contamination of ground water  in the upper  unweathered
     bedrock is implied by the data but  not proven due to lack of
     sufficient number of deep monitoring wells downgradient from
     the waste management units  for adequate correlations.

          The analysis indicates MW-35 and MW-37,  which are
     screened in upper unweathered bedrock, show evidence of
     chloride contamination. Monitoring  well MW-39, which is
     screened in deep unweathered bedrock, shows elevated levels
     of sulfate, TOG, TOX and specific conductance relative to
     the background  well (MW-16).

1.2  HWGWTF Analysis Results;

     Ground Water Sampling Results

          GWTF data  confirm the above results and,  additionally, the
     analyses indicate monitoring wells  MW-11, MW-46,  MW-7, MW-49,
     MW-48 and MW-51 show positive results for volatile organics.

        '  MW-7 indicated 0.0069 ppm of  tetrachloroethene;

        '  MW-11 indicated 0.0038 ppm of chloroform,  0.0012 ppm
           of 1,2-dichloroethane, 0.0015 ppm of trans-1,2-
           dichloroethene, 0.0038 ppm of 1,2-dichloropropane,
           0.0093 ppm of 4-methyl-2-pentanone, 0.0018 ppm
           of 1,1,1-trichloroethane, 0.0084 ppm of TCE and
           0.0016 ppm of 1,2-dibromoethane.

        •  MW-46 indicated 0.0072 ppm of 1,2-dichloroethane,
           0.0056 ppm of trans-l,2-dichloroethene and
           0.0054 ppm of TCE.

        •  MW-48 indicated 0.0066 ppm of TCE;

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                           -6-


     *-- MW-49 indicated 0.0019 ppm of chloroform and

     0  MW-51 indicated 0.11 ppm of tetrachloroethene.

     In addition some of these wells tested positive for
other volatile organic compounds like benzene, carbon
tetrachloride, 1,1 dichloroethane and freon at levels
below the generally accepted detection limits.

     All the wells (31 monitoring wells,  one piezometer)
that were sampled by GWTF showed at least one inorganic
indicator or heavy metal value above background (except
MW-9A). The maximum concentrations were:

- chloride:             36,200     ppm       MW-49
- TOX:                       0.675 ppm       MW-49
- Nitrate nitrogen:         67.50  ppm       MW-46
- Sulfate:               1,130     ppm       MW-39
- Amonia nitrogen:           2.10  ppm       MW-36
- Bromide:                  60     ppm       MW-21
- TOG:                     212  .   ppm       MW-17

     With respect to metals, the following is a list of the
maximum concentrations detected for metals where the background
value was exceeded:

- Barium:                    6.29  ppm       MW-49
- Calcium:               9,590     ppm       MW-49
- Cadmium:                   0.134 ppm       MW-49
- Cobalt:                    0.758 ppm       MW-49
- Copper:                    0.107 ppm       MW-49
- Magnesium:             4,490     ppm       MW-49
- Manganese:               880     ppm       MW-49
- Nickel:                    1.64  ppm       MW-49
- Potassium:                21.8   ppm       MW-49
- Vanadium:                  0.129 ppm       MW-49
- Aluminum.:                 16.60  ppm       MW-47
- Iron:                     15.40  ppm       MW-47
- Sodium:                1,100     ppm       MW-17
- Selenium:                  0.029 ppm       MW-14
- Arsenic:                   0.03  ppm       MW-8
- Lead:                      0.004 ppm       MW-4
- Silver:                    0.042 ppm       MW-1

     Five of the wells sampled by the GWTF (MW-4,  8, 11, 42
and 50) were grouped as wells with generally low chloride
concentrations by the statistical analysis. However, the
more recent GWTF results (relative to IT's data used for
statistical analysis) indicate that these wells show at least
one indicator parameter or heavy metal value above background
concentrations.  In addition, MW-11, showed positive results
for volatile organics (as it was discussed earlier).

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                           -7-
Surface Water and Soil Sampling Results;

     Six surface water (seep) samples were collected at the
vicinity of the site, outside of the waste management area.
Two seeps (#1 and #2) were collected in the quarry approximately
1800 feet east of the facility. Seep #3 was taken from a
tributary northwest of seep #2 approximately 1000 feet away.
Seep #4 was taken roughly 1000 feet downgradient from MW-22.
Seep #5 was collected 250 feet west of MW-4 in a tributary,
and seep #6 was collected from a tributary north of MW-4,
roughly .JL 2 00 feet away.

     Samples from the seeps indicated some concentrations
for indicator parameters (e.g., chloride up to 360 ppm),  and
metals  (e.g., aluminum up to 55 ppm, chromium up to 0.054 ppm).
At one location (seep 15) 0.36 ppm of Bis(2-Ethyl-hexyl)
phthalate was detected also. However, due to lack of back-
ground upgradient surface water data, no conclusion about
contamination can be reached from this data.

     Three soil samples'  (two duplicates and one attempted
background sample) were collected from one location, in
a tributary, approximately 340 feet east of the eastern
facility fence where monitoring well's MW-27, MW-47 and
MW-5 are located.

     The duplicate soil samples indicated some levels
of volatile organics (e.g., 2 butanone:0.014 ppm, and
toluene: 0.007 ppm). The GWTF attempted to collect a back-
ground sample, which was found to contain measurable levels
of total xylene (0.169 ppm), ethyl benzene (0.066 ppm) and
other organics. Therefore,  it could not be used as a
background sample. The soil samples also indicated some
level of concentrations for metals  (e.g., aluminum up
to 17.2 ppm, barium up to 0.341 ppm).

     In general, adequate assessment of the seep and soil
sampling data, obtained by HWGWTF,  is not possible due to
having only one sample data point, and lack of background
data.  Therefore no definite conclusions regarding contami-
nation can be made. However, due to the detection of
pollutants in both the soil and surface water seeps, a
surface water and soil sampling investigation is needed
at the  areas where seeps and soil samples were collected
by the GWTF.

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                               -8-


2.   Compliance with §265 and §264 (40 C.F.R.)

2.1  Evaluation of Construction of Monitoring  Wells;

          The results of the GWTF investigation indicate that the
     majority of existing monitoring wells at  the Panoche Facility
     are constructed properly.  However,  there  are several wells
     at which design adequacy needs to be further investigated.
     Several of the., monitoring wells produced  high to very high
     turbid ground water samples. These wells  are:  MW-4, MW-7,
     MW-11,  MW-14,  MW-22,  MW-25,  MW-29,  MW-31,  MW-47,  and MW-49.
     These wells need to be redeveloped and if the turbidity is
     due to improper construction,  they should be replaced.  The
     following monitoring wells need to be replaced because of
     inadequate construction: MW-17 and MW-18  south of ponds 12
     through 13A,  and MW-15 which is located at the southwest
     corner of pond 17.

2.2  Evaluation of Detection and Assessment Monitoring;

          Evaluation of  the facility's detection and assessment
     ground water  monitoring indicates that additional wells at
     the compliance points (§264.99(b) 40 C.F.R.) and downgradient
     from the waste management units are needed. The major
     deficiencies  of the assessment and detection monitoring
     systems are:

          *  lack  of sufficient and adequate shallow wells with
             appropriate screen intervals for  detection of volatile
             organics,

          *  lack  of sufficient wells to effectively monitor all
             the possible flow paths (relatively extensive faults
             and fractures),

          *  lack  of sufficient wells at several locations,
             specifically south of ponds 1 and 2, south of pond 2B
             and west of ponds 12 through 13A,  to monitor the full
             length of the aquifer,  and

          *  lack  of sufficient wells to determine the rate and
             extent of the plumes (vertically  and horizontally)
             within reasonable time period and to accurately define
             waste constituents in ground water.

          Therefore,  it  is necessary to expand on the existing
     assessment monitoring systems throughout  the facility and
     also include  two additional areas to the  assessment program.
     One area is south of pond 8 series (SB-4  cluster) where
     evidence of organic vapors (20-30 ppm) in the deepest piezo-
     meter (SB-4A,  271 feet deep) have been detected by photovac
     organic vapor analyser while taking water level measurements.

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                           -9-
This could be indicative of contaminant migration down into
the deep unweathered bedrock. The facility should investigate
the area and confirm the air monitoring results (at the
well heads) performed by the GWTF. If the results are
positive, the facility should submit plans regarding the
installation of assessment monitoring wells,  and geologic/
hydrogeologic investigation of the area (including fault II).
The other area is the upper drying area 61 located at the
facility boundary southeast of ponds 0, P, and Q.  This
diked waste management unit was used for the dewatering of
waste sludges. Several wells downgradient, east southeast
and souih of this unit are contaminated. These wells are
MW-47, MW-27, and MW-4S. Unit 61 has not been addressed
by the facility in their assessment program.  Therefore,  EPA
is requesting these two areas to be added to the existing
assessment monitoring plans at the site.

     The expansion of the overall assessment monitoring,
requested by EPA, asks for installment of several additional
monitoring wells at the contaminated areas. These areas are
south, southwest, west and northwest of ponds 12 through 16;
east of ponds O, P, Q; east, southeast and south of upper
drying area 61; south of ponds 1, 2 and rainwater collection
pond 2B; and south of pond 8 series.

     Rain water collection pond 2B is located at the southern
part of the facility in a drainage area where most of the
ground water discharges. As the ground water discharges
into the central and south-central part of the site, it
becomes contaminated due to contact with sludges that exist
beneath the area. Some of this contaminated ground water
might be discharging into pond 2B (a non-RCRA unit).
Therefore, the facility with the aid of piezometers and
monitoring wells should provide vertical and horizontal flow
nets and determine whether the ground water beneath the pond
has vertically upward gradient. Also, as part of the assess-
ment program for this area, the facility should collect some
samples from the sediments and/or sludges at the bottom of
pond 2B. A complete GC/MS analysis should be performed
utilizing methods 8240 and 8250 (SW-846) for volatile and
Semi-volatile organics. EP toxicity test should also be
performed on the samples.

     It should be noted that the number and location of
monitoring wells proposed by GWTF are not by any means final,
and the proposal does not imply that it will make the assess-
ment monitoring systems complete. Further along assessment
program there might be a need for additional monitoring wells
in order to be able to fully define the periphery of the plumes.
The proposed locations and screen intervals are chosen primarily
based on complex and extensive faulting and folding structures
at the facility/proximities, and lack of adequate and effective
ground water monitoring in specific areas.

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                                -10-
2.3  Evaluation of Upgradient Background Wells;

          The only acceptable upgradient background well is MW-16
     which is located at the most northern part of the facility,
     at the highest elevation relative to all other monitoring
     wells and the waste management units.

          EPA does not consider the locations of other background
     wells (proposed, by the facility)  to be adequate for this
     purpose. These wells are MW-23,  MW-22 and MW-20.

          Monitoring well MW-23 is located in a depression and
     natural discharge zone east-southeast, and relatively down-
     gradient of the north drum burial area. MW-22 is  located in
     a tributary outside of the waste management area  boundary and
     downgradient from ponds, 0, P and Q. This well apparently
     has detected the edges of the plume which has originated from
     ponds 0, P, and Q. Monitoring well MW-20 (2500 feet south of
     the facility) has somewhat different ground water quality
     compared to MW-16, therefore it should not be used as a back-
     ground well representing the ambient water quality at the
     site.

          It is recommended that the facility should install
     additional upgradient background well(s) in the vicinity of
     MW-16 or higher up the elevation. The additional  upgradient
     well(s) could be screened in weathered and also deep
     unweathered bedrock at different locations so that more
     information regarding spatial and vertical variability in
     ground water quality would be collected.

2.4  Ground Water Sampling and Analysis;

          In order to assess fully whether annual seasonal variation
     is occuring samples from all the wells should be  obtained
     during the months of February, April, July, October and
     December. The sampling plan should be revised to  include the
     Appendix VIII or IX compounds so that the maximum concentration
     of hazardous waste constituents at the contaminated areas be
     defined.

          In addition,  metals, e.g.,  As, Cd, Cr, Cu, Pb and Zn
     should be analyzed by graphite furnance techniques rather
     than atomic absorption or inductively coupled plasma methods.
     This will lower the detection limit and allow the introduction
     of match for statistical analysis.

          There are some geochemical processes which control the
     mobility of certain parameters and which should be identified
     in a future analysis. Anaerobic reactions, disproportionation
     reactions (which may result in one product being  oxidized,
     the other reduced),  protonation reactions (which  may affect

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                               -li-


    the PH of the ground water) and chelation reactions (which
    may increase the solubility of cations through complication
    with organic acids)(  are reactions which will tend to enhance
    metal solubility.  In addition,  previous studies (Baedecker
    and Back, 1979)  have shown that acetic acid can contribute
    a significant proportion of the alkalinity (as organic acid
    anions).  Therefore,  the alkalinity of ground water at the
    facility should  be included in future statistical comparisions
    and acetic acid  analyzed in future sampling rounds. The mean
    alkalinity (414  ppm)  is significantly higher than that found
    in MW-16 (367 ppm).  Also,  turbidity for all wells should be
    measured during  each sampling phase.

         The levels  of concentrations of  contaminants and hazardous
    waste constituents should be defined at the compliance points,
    and at the points  of exposures (for contaminations outside
    of the facility  boundary). Appendix VIII or IX compounds
    will be sampled  twice a year, during  dry and wet seasons,  for
    3 years.  The water levels for all the monitoring wells and
    piezometers should be recorded during every sampling phase,
    and the depth of wells should be sounded and recorded.


3.  "Additional Information Requirements,  $270 (40 C.F.R.)

3.1  Hydrogeologic Characterization

         There are several areas at the fault zones where further
    investigations are needed since not enough data exist to
    identify the nature of these fault zones, their relationship
    with the waste management units and their hydrogeological
    characteristics.

         One area of concern is the fault which apparently inter-
    sects both'faults I (previously fault A) and VI (previously
    fault H), trends in an east-westerly direction, traversing
    through pond Q and continues along the drainage east-northeast
    of the facility, toward the Green Valley Fault. Monitoring
    well MW-22, which has shown evidence of contamination, apparently
    is located at or very close to the fault plane. Higher up
    in elevation along the trend of this fault, approximately
    400 feet east of 'pond Q, trench 79 is excavated. Log of
    trench 79 indicates numerous short and discontinuous fractures
    in alluvium/colluvium deposits of Holocene age immediately
    above a sheared  and fractured zone in bedrock. The origin of
    these fractures  needs to be explained to see whether they are
    related to the displacement or shearing of bedrock. Also,
    information regarding the hydraulic properties of this fault
    is needed.

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                           -12-
     Ldg of trench 43, approximately 300 feet northwest of
the north drum burial area indicates that the Domengine
Sandstone (pre-Quaternary of Eocene age), is deposited on
top of the residual soil mantle deposit. The residual soil
horizons at the site are usually dated as late Quaternary
(Holocene age), and mapped as units deposited on top of the
Holocene and early Quaternary alluvium deposits. Assuming
this specific soil horizon is the oldest relative to other
soil mantle deposits and of early Quaternary (approximately
2 m.y. old),  the existance of the Domengine Sandstone (approx-
imately 45 m.y. old) on top of this soil horizon needs to
be explained by the facility. Since fault I passes beneath
the north drum burial area, and trench 43 is in the vicinity
of this fault,  the facility should under more scrutiny,
investigate the fault zone, its hydraulic properties, and the
stratigraphy of the area by additional trechning and coring.

     The other areas of concern where more investigations are
needed include:

     *  Suspected joint or fracture east of the facility
        which apparently trends along a prominant drainage
        and runs under the solid waste management unit 61;

     *  Southern portion of fault I in the vicinity of south
        eastern boundary of the facility;

     *  Intersection of faults II and V, south of pond 2B,
        and the fault plane and shear zone in that vincinity.

     The existing data at certain locations at the site
indicate that the unweathered bedrock is hydraulically
connected to the upper weathered bedrock. Fluctuations of
the water level in deep wells (screened in unweathered bed-
rock) during wet seasons, and evidence of possible vertical
migration o£ contaminants into the unweathered bedrock (SB-4
cluster area,  and ponds 12 through 13A area) reinforce this
possibility.  In order to evaluate this further the facility
has proposed performing pump tests,  at several locations
throughout the site. The proposed field test locations are:

     *  area immediately west of pond 13A (MW-35 & 36)

     •  area north-west of pond 14 (MW-38 & 39)

     0  area south of pond 8 series (SB-4 cluster)

     "  area east of pond 1 (SB-5 cluster)

     *  area east of pond 2B dam (SB-3 cluster)

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                               -13-
         In addition to the above locations, EPA is requesting
    the facility to add two other locations to the pump test
    program (including installation of two new deep wells).
    These locations are:

         0  area east of  ponds 0, P, and Q (MW-50,51,  and new
            deep well)

         0  area south of ponds 1 and 2 (MW-24,46,  and new
            deep well)

    Also, at the locations proposed by the facility, EPA is
    requesting the addition of some of the existing and new wells
    to the pump tests; these additions are:

        •  new shallow well in the vicinity of MW-35,36

        *  monitoring well MW-10 and new shallow well, close to
           SB-8, in the vicinity of MW-38, 39

        *  monitoring well MW-41 in-the vicinity of SB-5.


4.  Compliance with Superfund Off-Site Policy;

    The key provisions of the off-site policy require that:

        *   A facility chosen to receive hazardous substances
            from CERCLA removal and remedial action, must not
            have any significant violations or other physical
            conditions which may pose a significant threat to
            human health  and the environment.

        *   A facility with significant violations or problems
            may receive CERCLA waste only if the EPA or the'State
            has a compliance agreement in place with the facility
            tp correct all deficiencies and the unit used does
            not cause or  contribute to significant problems at
            the facility.

        *   Land disposal facilities either:  (1) meet the minimum
            technical requirements  (e.g., double liner etc.)
            established by the Hazardous and Solid Waste Amendments
            (HSWA) Of the 1984, or  (2) establish that disposal in
            the existing land disposal unit is protective of human
            health and the environment.

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                               -14-
         Farthermore,  based on new provisions of Superfund Amend-
    ments and Reauthorization Act of 1986 (SARA),  CERCLA wastes
    may be transfered to a land disposal facility only if the U.S.
    EPA and the State determine that both of the following require-
    ments are met:

         8  The unit to which the hazardous substance or pollutant
            or contaminant is transfered is not releasing any
            hazardous waste,  or constituent thereof,  into the
            ground water,  surface water or soil.

         * "All such releases from other units at the facility
            are being controlled by a corrective action program
            approved by the Administrator under Subtitle C of the
            Solid Waste Disposal Act.

         Based upon EPA's evaluation of available information,
    IT Panoche facility is currently ineligible to receive wastes
    for land disposal from response actions taken under CERCLA.
    The facility fails to meet the above provisions according to
    EPA's records (i.e. permit applications,  enforcement actions,
    inspection reports, and ground water monitoring data) and
    results of HWGWTF investigaiton.


5.   Facility Sampling and Laboratory Audits

5.1  Results of HWGWTF Sampling Audit;

         The following are HWGWTF recommendations  regarding the
    inadequacies of facility's routine sampling procedures and
    protocols:

         *  Field notes should identify all values used to
            calculate purge volumes.

         *  The electrical water level sounders should be
            calibrated on a regular basis.

         *  Well depth should be measured prior to purge on all
            wells where there may be a silting problem.

         *  Braided ropes and cables used to raise and lower the
            pumps and bailers can not be properly decontaminated
            between wells. They should be used one time only or
            replaced with a cable which can be adequately cleaned.

         *  The silicon tubing used in the bladder pumps should
            be more carefully cut and placed on the pumps.

         •  Samples should be collected at the screened interval
            whether the sample is collected with a pump or a
            bailer.

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                                -15-
          *   The volatile parameters should be collected as soon
            "as  possible after the completion of the purge to
             minimize the loss due to volatilization.

          •   Extractable organic samples should be collected in
             amber bottles to minimize the effects of sunlight.

          •   TOG and TOX samples should be collected in separate
             containers.

          0   ^28203 should not be used as a preservative in any
             of  the organic samples collected at this site.

          *   The laboratories doing coliform and Cr+6 analyses for
             IT  Panoche should document date and time when the
             analyses are initiated and completed. Chain-of-
             custody should be documented for the coliform which
             are transferred from one lab to another.

5.2  Results of  HWGWTF Laboratory Audits

     IT Analytical Services

          The laboratory generally has a number of QA/QC areas
     which need  to be modified or improved upon. Although none
     of these areas will singularly jeopardize the quality of
     data generated by the laboratory, it is conceivable that,
     in combination, they can cause significant problems. It
     is therefore strongly recommended that these concerns be
     addressed and corrected at the earliest opportunity. First
     and foremost, laboratory management must finalize and imple-
     ment their  QA plan.  Second, the laboratory should accelerate
     its development of a centralized computer program, and develop
     QC data acceptance limits. Lastly, documentation of records
     needs to be maintained and reviewed. In summary/  if the
     laboratory  continues to maintain its current standard of
     operation,  positive attitude, and initiates the recommended
     corrective  action, it is expected that the laboratory can
     satisfactorily analyze groundwater samples and generate data
     of acceptable quality.

     IT Vinehill Laboratory;

          The focus of this audit was to ascertain whether the
     IT Vinehill Laboratory has been conducting pre-disposal
     analyses correctly, and to determine if data generated for
     the IT Panoche facility is of adequate quality. In these
     terms,  it is felt that this  laboratory has the appropriate
     instrumentation, adequate facilities and qualified personnel
     to satisfactorily conduct pre-disposal analyses. With the
     exception of certain deficiencies, the laboratory generally
    'utilizes the correct analytical  procedures for pre-disposal

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                           -16-
analyses. Conceptually, the QA program is appropriately
comprehensive and quite detailed. However, although the
laboratory is organizationally stable and has established
a technically sound foundation, it is apparent that a number
of deficient areas need to be addressed. Specifically,
management needs to better diseminate their technical exper-
tise and QA philosophy to all laboratory staff. Also,
there appears to be a lack of consistency in the manner
the laboratory.conducts pre-disposal analyses versus truck
receiving analyses. This was clearly apparent based on the
discrepancies in truck receiving analyses summarized in EPA's
NEIC RCRA Compliance Inspection Report (Sept. 1986). Lastly,
greater emphasis has to be placed on ensuring that proper
documentation is maintained throughout each facet of analyses,
If discrepancies are noted, the laboratory should establish
a mechanism to either resolve these differences,  or have a
system to substantiate the rationale for supporting these
discrepancies.

IT Panoche Fingerprinting Laboratory;

     Despite the relatively small scale of operation existing
at the IT Panoche facility, there still exists a very
good standard of work performed by the staff chemist at
the laboratory.  The profiles of waste currently deemed
acceptable for  disposal at the site are well defined by IT,
therefore it is an unusual occurance for the laboratory to
receive a waste load which cannot be adequately characterized.
General laboratory practices are acceptable and staff are
well experienced. Based upon the findings of this audit,
fingerprinting data generated by this laboratory is expected
to be satisfactory specifically for the type of wasteloads
presently accepted at the site. However, should the quantity
and profile of  future wasteloads increase or change as a
result of expanded disposal capacity at this site,  then the
lab should be re-evaluated for any new additional screening
analyses. In addition, these modifications should be
adequately and  appropriately reflected in a revised waste
analyses plan.

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                                   -17-
II.   DATA REVIEW

     A.  ,Site Description and Adjacent Water/Land Use

              The Panoche Facility is situated two miles northeast of
         the City of Benicia in Solano County (Figure 1).  The facility,
         which lies within an unnamed drainage,  is located in a north-
         west trending range of hills northwest of a tidal flat area
         along Suisun Bay. Thick deposits of marine sedimentary rock
         units underlie the facility.

              Elevations at the Panoche Facility range from about 250
         feet in, the bottom of the valley along the southern boundary to
         about 840 feet along the northern boundary. Over 2,000 acres
         surrounding the facility owned by IT Corporation. About 250
         acres of the site are under interim status as a TSDF,  but only
         150 acres are being used for treatment,  storage,  and disposal
         of hazardous waste.

              The site occupies parts of three small drainage basins.
         These basins are:  The Paddy Creek Basin to the West,  the lower
         Sulphur Springs Creek Basin to the South, and the Goodyear
         Slough Basin to the north and east.  For the location of bene-
         ficial water use and developed springs refer to Figure 1 (for
         more information also see Table 1). The western part of the site
         drains into Paddy Creek, which joins Sulphur Springs Creek below
         the outlet of Lake Herman,  and eventually discharges into the
         Suisun Bay.  Lake Herman which is located a little over a mile
         southwest of the site boundary is part of the Upper Sulphur
         Spring Creek Basin and is a backup water supply for Benicia.
         The area receives about 17 inches of rain a year, and the
         potential evaporation rate is about 66 inches per year.

              Surface water flow is directly related to seasonal
         variation in precipitation.  The wet season usually extends
         from November through March, and the remainder of the year is
         generally dry.

              Current and past water uses within about one mile of the
         site include domestic water supply, range for live stock, and
         quarrying.  Surface water and ground water also support native
         vegetation and wet lands.  One mile of the site the total
         domestic use is about one acre-foot per year (supplement to
         Part B permit application) There is one user in Paddy Creek
         Basin, and three houses and one stock well in Goodyear Slough.
         There are no known users in Lower Sulphur Springs Creek.

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                              -18-


B.  Waste-Management Units and Facility Operations

     1.  Background

          The IT Panoche Facility consists of over two thousand
     (2000) acres,  which only 150 acres are being used for waste
     management practices under interim status.  The site consists
     of solar evaporation ponds, ponds for neutralization, waste
     piles, landfill and storage containers.  The facility is
     operating as a Class I waste disposal site under an interim
     status document issued by CA DOHS under Section 25200.5 of the
     California Health and Safety Code.  Prior land use in this area
     was livestock grazing.  In 1968 the J&J Company began using the
     land for waste disposal, and in 1974 IT Corporation acquired
     the site.

          When the initial RCRA permit application was filed
     (August 8,  1983), the facility had forty-four (44) surface
     impoundments,  a landfill,  three waste pile areas, and two land
     spray areas.  During the period of 1984 to present, most of
     the ponds have been taken out of service and several have been
     lined (Ponds 0 and P).

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                         -19-
2.  Wastes Managed by the Facility

     The table below lists the types and the amount of waste
which were handled from 1980-1985, in 1000's of tons:

Waste Group               1980   1981   1982  1983   1984  1985

Acids and Alkalines       45.8   37.2   18.9   17.3   18.3  17.1
Oily Wastes,'Floes, Paint 15.9   30.5   10.4    4.4    3.8   8.4
Pesticides                 0     16.9   19.0    000
Heavy .Metal Sludges        9.4   14.5    2.0   10.1   11.3  16.2

Contaminated Soils        17.1   18.7   24.3   54.1   62.2  73.7

Other                      7.9    6.7    9.1   57.3  120.1  53.9

               Totals      96.2  124.5   83.7  143.2  215.7 169.3

     The specific types of hazardous waste handled by IT Panoche
facility included  Acid solutions with/without metals,  alkaline
solutions with/without metals, aqueous solutions with organic
residues, metal sludges,  spent catalyst organic and inorganic
solid wastes,  halogenated and hydrocarbon solvents, waste and
mixed oil,  pesticide rinse water, tank bottom and still bottom
wastes, polychlorinated biphenyls and material containing
PCB's, organic liquids/solids with halogens, organic liquids
with metals, phosphate and sulfer sludges,  paint sludge, sewage
sludge, tetraethyl lead sludge, laboratory waste chemicals,
degreasing sludge, fly ash and bottom ash,  bag house waste, gas
scrubber waste, empty pesticide containers, polymeric waste and
organic monomer waste.  IT Panoche facility has also taken soil
contaminated with heavy metals, (e.g. lead, arsenic, copper,
cadmium), from superfund sites.

     Solid wastes were disposed directly into the landfill, and
surface impoundments were normally used for solar evaporation,
infiltration and concentration of liquid wastes.  According to
the facility,  sometimes during extreme drying conditions such
as a high pressure system built up over the Great Basin area,
some liquids were discharged onto landfill or land treatment
areas which according to IT provided moisture to aid in main-
taining soil texture and compaction, as well as dust control.
The facility also asserts that liquid wastes that were dis-
charged into the landfill or land application areas were
"immediately" upon discharge mixed with "clay material" to
render them able to pass the free liquid test for hazardous
waste landfills.

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                         -20-
3.  Surface Impoundments

     None of the surface impoundments at the facility are lined,
except for ponds 0 and P. The only active surface impoundments,
which are accepting wastes are ponds 0, P, and ponds 17 and 18.

     Ponds 0 and P (1,2,3) are retrofitted and are composed
of two linings consisting of an upper synthetic liner and a
lower composi-te synthetic/clay liner. A leak detection layer
is located between the two liners. All pond bottoms have
possitive drainage to the leak detection sumps. The types of
waste-disposed at these ponds are Titanium Oxide Acid waste,
which are produced as a result of paint pigment production.

     Ponds 17 and 18 previously have received oil refinary
and petrochemical wastes, drilling muds and sewage sludges.
Pond 17 currently is used as a truck wash out area and pond
18 receives sludges that do not pass the paint filter tests.

     Since November 1985 no surface impoundment has received
any off site waste (except 0, P, Q and 17, 18). All the other
ponds have been taken out of service, and are either capped or
they are in the process of stabilization and solidification.
Ponds 12-16 were dried, and according to the faci.lity,  contami-
nated materials were excavated and disposed of in the landfill.
The ponds were then filled with local borrow material.  The
other ponds, 4,5,6 and 19 series located in the central area,
were also stabilized, dried and then contaminated material were
disposed of in the landfill. The rest of the ponds south and
southwest of central area (1-3 and 7-11) and pond Q north-east
of the facility are in the process of stabilization and
solidification.

     All the primary surface impoundments (ponds 12-18,  and
0, P, Q) were designed to cascade by piping system to a series
of lower ponds which allowed the operator to maintain the
required pond freeboard and also served to increase the
surface area of liquid for solar evaporations. Due to this
cascading system there are no records of liquid waste transfer
from pond to pond.

     There is also a final containment pond (pond 2B),  which
is used to store stormwater runoff from non-disposal areas
within the site and also used to contain accidental spills
and overflows from waste ponds. This pond is located at the
southern end of the site in the main drainage basin south of
central area. An earth dam which its core is Keyed into the
bedrock contains this pond. The discharge of treated water
from pond 2B is covered under NPDES permit.

4.  Landfills

     Landfill areas include the "area 5" landfill whicn
occupies approximately 15 acres, and former landfill area
located south of pond 17 that was closed in October 1980
(approximately 5 acres).

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                         -21-
     The area 5 landfill which was the only active unit for
receiving solids after October 1980, ceased accepting waste on
July 4th 1986. The Part A application submittals of November
1981 identifies the design capacity of the landfill to be 300
acre/ft. The revised Part A submitted the same year included
the future expansion of 12000 acre/ft. In the report of waste
discharge submitted in September 1985, the reported capacity
was 520 acre/ft and 12000 acre/ft (future expansion).  In late
July 1986 IT met with CADHS regarding exceeding the allowed
design capacity and informed the agency that they have stopped
accepting waste for landfill disposal as of July 4th 1986.

     The types of hazardous wastes accepted for landfill
disposal during the active period of the unit included solid
hazardous waste from industrial sources, de-watered sludges
from the bio-area, contaminated soils (including CERCLA
wastes), and contaminated sludges. There are no discrete
landfill cells, solid wastes were mixed with soil and applied
over the entire working face rather than deposited directly
into cells and covered. Run-on from the upper portions of the
canyon is diverted away from the landfill by a drainage channel
constructed at the northern limit of the waste disposal area.
Stormwater run-on is diverted to a side canyon and is impounded
in a stormwater retention pond (pond T).-A stormwater reten-
tion pond (pond N) is also maintained in the upper canyon
(designated N-Canyon). Run-off from active portions of the
landfill is collected in a subdrain system that previously
discharged to pond 6 series. From the time those ponds were
out of service, contact water is being directed to ponds 1
and LA.

5.  Bio- Areas

     There are seven disposal areas designated as bio-areas
1, 2,  3, 8, 13A, bio-spray area and upper drying area (area
61).  Bio-area 1, was cleaned in 1983 and has not been used
since then. Liquids from pond 1 (contact water) were pumped
to a sprinkler system in the bio-spray area located in the
central area.

     The bio-areas were diked and used for the dewatering of
waste sludges. Wet sludges from the petroleum refining indus-
try and sludges excavated from on-site ponds were deposited
inside the disposal areas, graded to promote drainage of free
liquids and allowed to dry prior to landfilling. Run-off from
sludges were collected in downslope collection sumps. The bio-
areas, should not be considered as land treatment areas, since
the reported function of these areas is to reduce the volume
of free liquids in the waste and not to make the waste less
hazardous or non-hazardous by biological degradation. According
to the facility, none of these bio-areas have been active since
late 1985.

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                         -22-
6.  Waste Pile

     Waste handling practices included the deposition of
waste material at a pre-designated unloading area. A waste
load received at the landfill site was mixed with previously
deposited waste material. The comingling of two or more
incompatible waste streams and not having adequate control on
the separation of these wastes had caused several incidents of
fires in the-waste pile area. One stock pile area (designated
17 p) is located at the former landfill area south of pond 17,
and has not received any waste since March 1986. The other
waste"pile areas (Q, P and PI) are currently used for drying
acid neutralization sludge/solid associated with ponds O and P.

7.  Drum Burial Areas

     There are five (5) closed drum burial areas at the facil-
ity. One area is located about 200 feet northwest of pond 18,
and is covered with top soil and vegetation. The other burial
cell areas are scattered throughout the site. One area is
south of pond 17 (from landfill) which is capped. One area is
adjacent to the area 5 landfill and pond 18. Another burial
area is located to the west of pond 1A (central area),  and. one
is situated about 200 ft north of pond P. Approximately 4000
drums,  are buried in 19 trenches at these burial areas.

     For a detailed map and the location ot all the hazardous
waste management units see figure 2.

8.  Current Status of Operations at the Facility

     Currently the facility is involved in major technical
investigations regarding the landfill expansion project and
assessment of the drum burial areas.

8.1  Landfill Expansion

     The proposed landfill will cover an area of 118 acres
and have a total volume of 20,070,000 cubic yards (12,440
acre-feet),  including liners, leachate collection system,  and
closure cover. It is anticipated that this configuration will
be achieved in approximately 35 years based on annual receipts
of 540,000 cubic yards. The foundation system will consist of
two major portions: bottom and slope, the liner system at
the "bottom" portion will consist of a minimum of 2 feet of
clay (permeability of 1x10-7 or lower) covered with secondary
synthetic liner, leak detection system, primary synthetic
liner,  leachate collection system, geotextile and final soil
cover (minimum 6"), respectively. The liner system on side
"slopes" steeper than 3H:1V will consist of synthetic,  and clay
liner with no leachate or leakage collection layers (slopes
less steep than 3H:1V will have the leachate collection system)

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                         -23-
     The runoff control system in the expanding landfill will
be network of ditches which will collect water from each land-
fill bench. The system will divert water off the landfill and
will be discharged into either a retention pond or a natural
drainage channel. Runoff water from active areas of the
landfill will be discharged into pond 1 down gradient of the
landfill area.

     The modified run-on control is a diversion-system which
should prevent surface water from the surrounding hillsides
from running onto the landfill. Water will be intercepted by
ditches and lined channels and divert laterally to discharge
into pond T. Pond N will be used as storage for reducing the
peak of the hydrograph. Following storms,  the water in pond N
will be pumped out to the channel leading to pond T using
portable pumps.

The proposed landfill expansion will ultimately fill the site
to an elevation of approximately 640 feet. The foundation
including all the liner and drainage control systems will be
constructed on top of the bedrock, alluvium/colluvium, and
artificial fills (including waste), depending on the different
locations at the central area.

The physical setting of the landfill (as it was mentioned
earlier) is at the discharge area in the valley. Therefore, it
is recommended that the facility should consider and evaluate
the diversion of ground water in the N Canyon and along the
northern limits of the landfill. This diversion (e.g. cutoff
wall and drainage by gravity) will reduce the amount of ground
water discharge beneath the central area (future landfill)
considerably. This will reduce the amount of contaminated
ground water  (by contact with sludge beneath the central area)
which has to be collected by the cutoff/collection trench,
proposed by the facility, north of pond 2B.

The other major component of the expansion^project is the
treatment/stabilization unit, and water management system.
The purpose of the treatment/stabilization unit is to pretreat
wastes prior to landfill disposal. The unit will treat and
stabilize both liquid and solid waste receipts by mixing waste
with neutralizing and stabilizing agents,  such as lime, kiln
dust, and cement. The water management system will divert,
collect, convey and manage water originating as rainfall and
water used to decontaminate equipment. The system involves
drainage and sediment control structures and will consist
of collection sumps, storage tanks, surface impoundments
for storing water, or solar evaporation unit, and a water
treatment system. For the plan of the proposed facilities
and the project cross-section, see figures 3 and 4.

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                         -24-
     "Eventually, the project construction will place  the  onsite
waste into the landfill. The following table identifies the
disposition of existing waste management units:
Waste Management
    Units	

61, 0, P, PI, P2, P3
Q, QP

1, 1A, 2, Bio2, 3,
Bio3, "4, 5, 6, LA,
6B, 6C, 7, 8, 8A,
8B, Bio8, 9, 9r, 10,
lOr, 11, llr, 16,
19, 19A, 19B, 19C,
19D, 20, 21, 22.

Area 5, 17, 17P, 18
     Disposition
Closed by waste management unit
removal and disposal in lined
landfill.
Existing facilities removed and
retrofitted.  Removed waste
disposed on lined landfill.
Closed in place.
     The following table identifies the current waste manage-
ment units expected to continue in active operation pending
permits:
Waste Management
    Unit	;_

Treatment Units;

*  pH adjustment and Acid
   neutralization units,
   Baker tanks.

*  Carbon treatment unit,
   Baker tanks.

Surface Impoundments:

•  Ponds 1, 1A, 2, 8, 17,
   18 and Q.
   Ponds O, P, Pl-3
             Use
Waste Pile:
   Waste pile QP
Storage, neutralization, metals
precipitation of acidic liquid/
sludges.

Storage and treatment of
potentially contaminated water.
Receipt of sludge waste and intra-
site transfer of sludge and liquid
waste; receipt of truck washout
water and contact water.

Receipt of liquid acid waste/-
receipt of sludge waste and intra-
site transfer of sludge and liquid
waste; receipt of truck washout
water and contact water.
Drying and stockpiling acid
neutralization sludge/solids
associated with Ponds 0 and P.

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                              -25-
     Landrill;

     0  Area 5                    Disposal of solid waste.

     8.2  Drum Burial Area Assessment

         The facility has completed the preliminary assessment of
     possible remedial actions regarding the five drum burial areas
     at the site. ..The investigation weighs and compares the feas-
     ability and risks involved in excavation and removal, and a no
     action alternative which suggests the drums should stay buried.
     Further investigations are underway and the regulatory agencies
     are reviewing and deciding on possible remedial actions.

C.  Site Physiographic Setting, Topography

         The regional physiographic setting for the Panoche Faci-
    lity includes the Coast Ranges and Great Valley of California
    physiographic provinces (Figure 5). The Panoche Facility lies
    entirely within the Coast Ranges province while the western
    limit of the Great Valley province lies about 2 miles east of
    the facility.

         in the region of the facility the Coast Ranges Province is
    about 50 miles wide. The province consist of a group ot nearly
    parallel, northwest trending mountains, ranging in elevation
    from 2,000 to 4,000 feet, with intervening valleys. Topography
    rises abruptly at the western limits, with steep cliffs and
    narrow wave-cut terraces along the coast. On the eastern limits,
    the border with the Great Valley is also relatively abrupt. The
    Suisun, San Pablo, and San Francisco Days are also prominent
    features in the region of the Panoche Facility.

         The Graat Valley of California Physiographic Province is
    located directly east of the Coast Range, its western limit
    being just east of the Panoche Facility. The northwest trending
    valley is about 400 miles long from north to south and averages
    about 50 miles in width. In the region of the facility the
    Great Valley has elevations that range from sea level to less
    than 400 feet and the valley surface general slopes towards
    San Francisco Bay from the north, east, and south.

         The group of low, northwesterly trending hills immediately
    west and north of Suisun Bay defines the area for the site
    vicinity. The western two-thirds of the site vicinity is
    characterized by small hills, or low mountains, and intervening
    valleys. Elevations in the vicinity range trom near sea level
    in the area of Suisun Bay and Carquinez Straits to about 1,100
    feet in the hills about 2 miles north of the Panoche  Facility,
    while more local relief is on the order of 500 to 600 feet.

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                              -26-


    The eastern one-third of the vicinity is essentially flat lying,
    occupied by Suisun and Grizzly Bays and their surrounding swamp
    and salt water marshes, and elevations are near sea level.

         Drainage pattern varies over the upland portion of the
    site vicinity. The southwest flowing Paddy Creek drains the
    vicinity at the western side of the Panoche Facility,  and
    joins the Sulphur Springs Creek drainage system downstream from
    Lake Herman. 'The area to the north and east of the Panoche
    Facility drains primarily east and northeast to the swampy
    lowlands adjacent to Suisun Bay.  Except tor the western-most
    portion of the Panoche Facility that drains into Paddy Creek,
    drainage from the facility is included with these eastern
    drainage to Suisun Bay.

D.  Site Geologic/Hydrogeologic, and Structural Settings

    1.  Geological Setting

             The site, as mentioned earlier, is located at the head-
        waters of an unnamed drainage valley which trends  south-
        easterly for about one and one half miles to the tidal flat
        area of Suisun Bay. Elevations within the facility range
        from 250 feet at the bottom of the valley to 840 feet along
        the north property boundary.  The surrounding terrain is
        hilly with slope gradients locally as iiigh as 42 percent.

             Prior to start of development of the Panoche  facility
        in 1968, the area was covered by a soil mantle supporting
        a grassy vegetation. Natural bedrock exposures are found
        only in some parts of intermittent stream channel  bottoms
        and along the tops of hills were resistant sandstone beds
        are sometimes exposed. Geologic materials at the site are
        divided into two major categories:

              (1)  Pre-Quaternary Units, and

              (2)  Quaternary deposits.

             Two pre-Quaternary bedrock units are found at the site;
        the Panoche Formation of Late Cretaceous age and the younger
        Domengine Sandstone of Eocene age. The majority of the site
        is underlain by the Panoche Formation, and a small area of
        the facility, chiefly to the higher elevation, in the
        northern part, is underlain by the Domengine Sandstone.

             The Domengine Sandstone consists of very thickly
        bedded to massive, uncemented, relatively clean, fine
        grained quartz rich sand. The color is commonly white with
        yellowish iron staining along fractures and joints. The
        base of Domengine Sandstone is marked by thin interbed,
        of greenish gray tuffaceous shale and carbonate cemented
        sandstone containing oyster shell remains, indicating a

-------
                      -27-
mudh shallower marine environment than Panoche Formation.
The Domengine Sandstone overlies the Panoche formation.
The contact between the two formations forms an angular
unconformity, which indicates that the Domengine Sandstone
was deposited after deposition, deformation and folding of
the Panoche Formation. The Domengine Sandstone that may
have existed in the area of the facility largely has been
removed by erosion. It occurs as isolated outliers at
the higher- elevations at the facility, and it has not been
explored in the facility region. Also, its waterbearing
characteristics have not been investigated in detail.

     The Panoche Formation consists of interbedded shales,
mudstones, siltstones, sandstones, and lenses of conglom-
erate that were deposited in a marine sedimentary basin.
Thickness of this formation has been estimated as 20,000
feet (Bishop, 1970) to 25,000 feet (Payne, 1962) in two
areas southwest of the site vicinity. On a regional scale,
the Panoche Formation has notable lateral variations in
lithology, caused by facies changes and topographic irregu-
larities within the depositional basin, induced by regres-
sions and transgressions of the late Cretaceous sea.

     At the facility, weathering affects the Panoche For-
mation to a depth of 20 to 50 feet below the top ot the
bedrock. The severely weathered shale and shaly siltstones,
cored at the facility, typically exhibit heavy spheroidal
and concoidal fracturing and iron oxide staining. Panoche
Formation Sandstones also exhibit heavy iron oxide staining
locally. The weathered portions of the bedrock also are
characterized by open joint and bedding planes. Below about
40 to 50 feet, the majority of the rock is fresh. In some
places, the contact between weathered and unweathered rock
is abrupt but in many cases it occurs as a transition over
several feet.

     Three types of Quaternary deposits are found in the
study area: Alluvium, mass movement deposits, and a resi-
dual soil mantle.

     Alluvium is deposited primarily in the bottom of the
main drainage valleys. The alluvium consists of sandy clays
and silts with variable thicknesses of silty gravels with
cobbles at the base of the deposit. Quaternary alluvium was
found in the upper parts of MW-1,2B, 28, and 29 with thick-
nesses ranging from 2 1/2 to 20 feet.

Several mass movement deposits are mapped at the vicinity
of the facility boundry. These mass movements are identi-
fied on the basis of analyzing new sets of color and color
infrared aerial photographs and interpretation of the
preexisting subsurface data. Trench logs of some ot

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                          -28-
    the landslide area exhibit slope parallel shear planes and
    irregular bedding attitudes and shear patterns which are
    indications of mass movements. Also at some of the areas
    (areas underlying MW-17,  MW-18, MW-19, MW-13, MW-26, and
    MW-31) landslides are located above the fault zones (see
    Figure 6).  The fault zones are recognizable in boring and
    trench logs by clay gouged zones and almost vertically
    dipping bedding close to these zones. It is not clear
    wheather -these landslides are triggered by the movement
    along the faults or due to excess weight of weathered
    material which exceeded its resistance to shearing (which
    in--turn migh have been reduced by an accession of soil
    water). Residual soil consists of highly plastic, clayey
    silt and sand which grades into severely weathered bedrock.
    The soil is thinnest along ridges and hill crests (one to
    two feet thick) and becomes thicker at the base of slopes
    or in saddles. The soil in most locations, is highly struc-
    tured with  prismatic soil columns produced by shrinking
    and swelling of the soil during the dry and wet seasons.
    The soil also contains evidence of slope-creep which is
    imperceptible flow of colluvium. For geologic map and
    cross sections, see figures 6 and 7A through 7E.

2.  Hydrogeologic Setting

         Two water bearing zones have been identified by the
    facility. The principal water-bearing unit is the
    weathered,  uppermost zone of the Panoche Formation and in
    some places, the overlying alluvium and fill. Ground water
    also occurs at greater depths within the unweathered bed-
    rock. The permeability tests have shown that water in this
    zone is less mobile and,  in terms of water storage per unit
    volume of rock, comprises a much smaller supply.  Field
    permeability tests (packer tests) indicate that the
    weathered bedrock has permeabilities in the range of 1X10-4
    cm/sec to 6X10~6 cm/sec.  The unweathered bedrock, depending
    on interbedding and the extensiveness of the fractures, has
    permeability valued ranging from < 1.8X10~5 cm/sec (shale
    interbedded sandstone) to 2.2 x 10~9 cm/se c (clayey,  silty
    shale).

         Ground water contour maps (see Figures 3 and 9)
    reinforce the fact that the flow gradients in the shallow
    weathered bedrock are generally parallel to the surface
    topography.

         The ground water contour maps generated by GWTF have
    been constructed using the January and August water levels
    of shallow  monitoring wells and piezometers. These contour
    maps indicate the approximate flow patterns during wet
    (January) and dry (August) seasons. The bull's eyes on the
    contour maps are probably due to mounding of the seepage due

-------
                      -29-
t<3- the leaking ponds. The mounding north-west of the maps
is where ponds O, P, and Q are located. The more extensive
mounding, on August contour map, is located in the central
and western part of the central area.  During the wet
seasons in 1986 extremely heavy rain storms occured, Which
caused the ponds at IT Panoche to get  overfilled. The
mounding seen on the map could be the  reflection of the
excessive leakage of the ponds due to  those rain storms.

     Figure 10 snows the prominant hydrogeological divides.
These watershed boundaries influence the ground water flow
patterns which overally are in three directions. Most of
the ground water, flows through the central area and exits
the facility through the southern boundry and Pond 2B area;
the rest of the flow is toward east-southeast and west.
The watershed boundry that starts at southern most corner
of the facility and trends northeast,  could be mostly
due to the fault II and partly due to the intersection of
fault II and V at southern corner of the facility (south
of Pond 2B). Figure 11 shows the elevations of top of the
unweathered bedrock beneath the facility. It is apparent
that these elevations overally follow  the surface topography
which reinforces the general directions of the ground water
flow in the overlying weathered bedrock.

     Ground water also occurs at deeper zones in unweathered
bedrock. The formation mainly consists of fresh clayey
matrix where the porosity is relatively high and the
specific yield is considerably low. Considering the higher
permeability values of the weathered bedrock (1 or more
orders of magnitude higher than unweathered bedrock) and
higher specific yield, most of the infiltration is being
confined to the weathered zone. However, the unweathered
Panoche Formation does yield small and large quantities of
water, mainly from fractured zones, throughout the facility.
Although these appear to be scattered zones as the explora-
tory borings indicate, hydraulic gradients at several loca-
tions (SB-4 and SB-5 clusters) between shallow and deep
piezometers, and fluctuation of water levels in deep wells
during wet seasons, indicate the unweathered bedrock might
be hydraulically connected to the weathered zone. If that
is so the unweathered bedrock is part of the uppermost
aquifer. Details of facility's proposal on determination of
base of the uppermost aquifer and fiPA's additional requests
are discussed in section E3. EPA has defined the uppermost
aquifer as the geologic formation, group of formations, or
part of a formation that is the aquifer nearest to the
ground surface and is capable of yielding a significant
amount of ground water to wells or springs (40 C.F.R.
§260.10) and may include fill material that is saturated.
If zones of saturation capable of yielding significant
amounts of water are  interconnected, they all comprise  the
uppermost aquifer.

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                         -30-
3.   Structural Geology

 ..-•-•-      As discussed earlier ground water contours and flow
    gradients in the shallow weathered bedrock, are generally
    parallel to the surface topography. The ground water
    movement is also influenced by the faults and other
    secondary fractures at the site.  Faults are important
    because clayey gouge zones can serve as ground water
    barriers while the fractured rock along the fault can allow
    more rapid ground water movement parallel to the fault
    plane.  The facility has conducted investigations which
    consisted of borehole sampling,  trench excavations, aerial
    photo interpretation and literature search, and has identi-
    fied numerous faults at or near the facility boundry.
    Figures 6 and 12 provide the locations of these faults and
    secondary fractures at the facility and their regional
    settings. Six fault zones and their associated fractures
    have been identified at the facility (I through VI).
    These extensive faults are generally parallel to the Green
    Valley Fault which its strike trends North-Northwest, and
    at closest distance it is about 2,000 feet from northwest
    corner of the facility.

         Except for Green Valley-Concord fault, the age of
    movements for the six continuous faults that traverse the
    Panoche Facility, and those faults within 3,000 feet of the
    facility permitted boundry, have not been assessed. The
    difficulty is due to not being able to establish absolute
    age for landslides, alluvial,  and residual soil deposits.
    According to the facility, the geomorphic and topographic
    expression along the traces of the faults,  historic and
    recorded seismicity of the region,  site vicinity and
    facility, and trench exposures indicate that the faults
    have disrupted the bedrock materials only,  and it may be
    interpreted that the faults through the facility probably
    have not moved during the Holocene time.

     3.1  Need for Additional Fault Investigations

               There are some areas at the fault zones where
          further investigations are needed since not enough
          data exist to identify the nature of these fault
          zones,  their relationship with the waste management
          units and their hydrogeological characteristics.

               One area of concern is the zone associated with
          fault I (see Figure 12). This fault apparently
          intersects both faults I (previously fault A) and VI
          (previously fault H), trends in an east-westerly
          direction traversing through pond Q and continues
          along the drainage north east of the facility, toward
          Green Valley fault. The ground water contours indi-
          cate that the flow would be parallel to this fault

-------
               -31-
along the drainage where well MW-22 is located.
The boring log indicates highly fractured bedrock
(sandstone),  with beddings dipping 60 degrees from
horizontal. This indicates that the fault might be
very close to this well (this is important because
MW-22 has shown evidence of contamination).  Higher
up in elevation along the trend of this fault,
approximately mately 400 feet east of pond Q,
trench 79 was excavated. The log at trench 79
indicates numerous short and discontinuous fractures
in alluvium/colluvium deposits of holocene age
immediately above a sheared and fractured zone in
bedrock and filled with caliche salts. The origin
of these fratures are not explained,  and since they
are directly above the fractured zone in the bedrock,
they might be related to the displacement and or
shearing of bedrock, however minor (see Figure 13).
Also, information regarding the hydrological
properties of this fault is needed.

     Log of trench 43 (about 300 feet northwest of
the north drum burial area) indicates that the
Domengine Sandstone (Pre-Quaternary of Eocene age)
is deposited on top of the residual soil mantle
deposit (Figure 14, D on top of C). The residual
soil horizons at the site are usually dated as late
Quaternary (Holocene age), and mapped as units
deposited on top of the Holocene and early Quaternary
alluvium deposits. Assuming this specific soil
horizon is of early Quaternary (approximately
2 m.y. old),  the existance of the Domengine Sandstone
deposit (approximately 45 m.y. old) on top of this
soil horizon needs to be explained. The available
data presents some discrepencies,  gaps, and problems
which should be refined and explained. Since the
contaminant plume has been detected in this area,
and the most probable flow path is the drainage area
(along the fault), the facility should (under more
scrutiny) investigate the fault zone site hydraulic
properties, and the stratigraphy of the area by
additional trenching and coring.

     The other area of concern is a suspected joint
or fracture east of the facility which apparently
trends along a prominent drainage and runs under the
solid waste management unit 61. It seems that well
MW-47, which has shown higher elevations of total
metals, than background, is located very close to
this suspected fracture. The boring log from MW-47
indicates fractured weathered shale, and a fractured
plan at depth of 29.5 feet in the fresh bedrock.

-------
               -32-
Besides this boring, there is no other data to
evaluate this tracture. This fracture along tne
drainage could be a pathway for migration of contami-
nants, therefore it should be further investigated.

     Another area where sufficient data does not
exist is the southern portion of fault I. Trenching
or boring should be done to expose the fault if
pos.sible and to investigate its relative age of
movement.  According to the facility, trench 36 has
exposed the fault north of the facility, beyond the
boundry, and no evidence of faulting being extended
into the soil mantle layer, exists. However the
southern portion of the fault has not been investi-
gated.  Since this is a major fracture that traverses
the entire site through the central area, it needs to
be investigated in more detail.

     The last area of concern is the intersection
at two other major faults  (II and V previously B and
E) at the facility, south of pond 2B (Figure 6).
This area is the main drainage location for the
entire central area. Recharge to the fill, alluvium
and weathered bedrock flows through this drainage.
Two monitoring wells MW-14 and MW-25 are located
about 400 feet and 600 feet down gradient from the
dam respectively. Not much of information regarding
these faults is available in the boring logs at
MW-14 and MW-25. Boring log of MW-25 indicates a very
soft sandy siltstone at about 44.5 feet in tne fresh
bedrock. The static water levels and the screen
intervals indicate that there is a saturated zone of
more than 60 feet, starting in weathered bedrock (9
feet below the ground surface) and extending 45 feet
down into the slightly weathered bedrock (MW-25 is
screened from 25 to 35 feet and MW-14 is screened
from 40 to 70 feet). The boring logs do not indicate
any significant latteral lithological changes between
these two wells and the gradient of ground water is
about 0.05. No data on the hydraulic conductivity at
this area is available. Considering the extensiveness
of the aquifer at this location and the existance of
two major fractures, it is necessary to perform
permeability tests and determine the rate of ground
water movement at this area.  These faults, (II and
V, south of pond 2B) should be investigated by
coring,  and if applicable by trenching and to deter-
mine whether MW-14 is monitoring the fault plane.

-------
                                  -33-
    E.  Ground Water Monitoring System;

             Since 1984 IT has been conducting extensive geological and
        hydrogeological investigations at the requests of the regulatory
        agencies. The activities have generated tremendous amount of
        borehole logs from some 200 exploratory drillings, installation
        of piezometers and monitoring wells. Over 80 trenches have
        been excavated to identify the structural geology of the site.
        During the GWTF investigation there were 56 monitoring wells
        throughout the site.

             The following table identifies the waste management units
        and the set of monitoring wells associated with those units.
        Figure 2 provides the locations of all the monitoring wells and
        other geotechnical and geochemical bore holes.
Monitoring Well »
Waste Management Units
Location at the Site
24, 46, 52, 25, 14*,
8, 42
1, 1A, 2, Bio2, 3, Bio3
7, 8, 8A-C, 2B

4, 5, 6, 6A-C, 9, 9R, 10
10R, 11, 11A, 11R, 19,
19A-D, 20-22, existing
landfill.
Lower Valley Area
                                                  Central Area, Terrace
                                                  and Area 5 landfill
54, 2B, 17, 28, 33,
(35-37)*
12, 13, 13A
West - Southwest
10, 34, 4, 13, 26,
31, 38*,39*, 56
14, 15, 16. 13A
West
15, 11
17, 17P, 18, previous
landfill, previous drum
burial area
North - Northwest
40-49, 50, 51, 53,
55, 5, 7, 21, 27, 22
0, P, Q, previous solid
waste management unit 61
North - Northeast,
East
*  Deep monitoring wells, screened in the fresh unweathered bedrock.

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                              -34-


1.   Well Design and Development/Well Information

          The wells at the facility were drilled initially with
    8-inch O.D. hollow stem augers and were sampled at intervals of
    five feet or less. Some of the wells were reamed with 12-inch
    diameter hollow stem augers before casing installation.  The
    casings used are 4-inch,  schedule 40 pvc with flush threaded
    joints.

          Since the monitoring wells at the site are producing
    mainly from fracture flow in the weathered/unweathered bedrock,
    the standard methods for  sizing the filter pack and slots were
    not considered to be applicable by the facility. Therefore,
    wells were constructed using a standard design which according
    to the facility had been effective based on past experience.

    This design has utilized 0.020-inch manufactured slotted casing
    and No.3 Monterey sand. The monitoring wells,  after the instal-
    lation of the well casing and filter pack,  were sealed by 1  to 2
    feet of bentonite pellets on top of the filter pack material,
    and the remainder of spacing between well casing and the bore
    hole were sealed by cement grout all the way to the ground
    surface. A protective steel casing with a cap and lock were
    installed at the end. Figures 15 and 16 show typical shallow
    and deep well construction details.

    Developing the monitoring well was performed utilizing the gator
    (vacuum) truck to suck monitoring well dry. For wells that did
    not clear up by this process, a surge block was used to create
    surging motion to develop the sand pack around the well screen,
    and also where appropriate an air compressor and metal pipe were
    used to bubble air through water in the screen to develop the
    sand pack.

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                                   -45-


          Th e following monitoring wells have been replaced by new wells:

          -  MW-1,  plugged and replaced by MW-54 (after GWTF investiga-
             tion) .

             MW-2A,  plugged and replaced by MW-2B.

          -  MW-3/  being used as a piezometer,  and is replaced by MW-26.

             MW-6,  being used as a piezometer,  and is replaced by MW-27.

          -  MW^12,  plugged and replaced by MW-53.

             MW-19,  plugged,  no replacement.

          -  MW-30,  plugged,  and replaced by MW-33.

          -  MW-32,  replaced by MW-34.

          -  MW-45,  plugged and replaced by MW-52.

     IT, after a recent review of the facility's ground water monitoring
     system, has proposed additional wells for replacements and/or plug-
     gings which are as follow:

     Wells to be plugged,  without replacement:   C-3,  C-4, C-5, and MW-18.

     Wells to be replaced and then plugged:  C-l, C-2, C-6.

     Wells to be replaced and retained as peizometers:  MW-41, iMW-48,
     MW-53, and MW-56.

     The facility should submit complete detail regarding the plugging
procedures including the new list of monitoring wells which have been
abandoned.

     2.  Evaluation of Detection Ground Water Monitoring System.

              The results of the Ground Water Task Force investigation
         indicate that majority of monitoring wells at the Panoche Faci-
         lity are located and constructed properly. However, there are
         several wells which their design adequacy need to be further
         investigated. Also several locations throughout the site need
         to be investigated and new monitoring wells installed. The
         following discussions bring the inadequacies and problems to
         attention,  and recommendations which the  facility should con-
         sider and undertake.

          2.1  Construction Evaluation

                    During the GWTF sampling event, some of the wells
               indicated high to very high turbidity values ranging  from
               6.1 NTU to 102 NTU (maximum acceptable limit is 5 MTU).

-------
                    -46-
The facility should utilize the decision flow chart
(Figure 3-4, RCRA Ground Water Monitoring Technical
Enforcement Guidance Document) to evaluate well construc-
tion and development. If the end result indicated that
there are no organics in the turbid ground water samples,
then the wells are constructed and/or developed impro
redevelop the wells, using appropriate method(s) and if
the problem is not solved, the wells should be replaced.
The following table identifies these wells and their
turbidity values;

-'  MW-4           Turbidity, NTU           25
   MW-7           "          "             60
   MW-11          "          "             25
   MW-14          "          "             20
   MW-22          "          "             36
   MW-25          "          "             28
   MW-29          "          "             102
   MW-31          "          "             36
   MW-47          "          "             38
   MW-49          "          "              6.1

     There are four monitoring wells (MW-17, 18, 19 and
37) south of ponds, 12, 13 and 13A which are installed
in a drainage that runs south west. MW-17 is not an
acceptable monitoring well because it has 30 feet of
screen which is hand sawn and the slip couplings are
attached by metal screws. MW-18 has a gravel pack which
extends up to two feet below the surface, and the facility
has proposed to plugg it. MW-19 was damaged and it is
abandoned. The only acceptable well in this area is MW-37
which monitors the unweathered bedrock. Therefore,
several shallow monitoring wells should be installed to
replace some of these wells. The screen intervals should
monitor the upper and lower parts of the saturated zone.
The shallower wells must be screened at the ground water
level for adequate detection of volatile organics.  It
should be brought to the attention that althought contami-
nation has been detected in this area (and further down-
gradient) the replacement of these monitoring wells are
imperative for the purpose of compliance point monitoring
and hence for demonstrating the effectiveness of the
future corrective actions.

     Immediately to the southwest corner of pond 17, and
the old landfill (17P), there is monitoring well, MW-15.
This well has 50 feet of screen (from 12 to 62 feet)
which monitors two different lithologies. The top 20 feet.
is consisted of interbedded silty sandstone and clayey
siltstone, and the bottom 30 feet is sandy siltstone.
The depth to water typically is about 30 feet. Such a
long well screen will not be able to detect contaminants
concentrated at a particular depth. A contaminant may

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                         -47-
     .be concentrated at a particular depth because of its
     physical/chemical properties,  and/or hydrologic factors.
     In this situation,  a longer well screen can permit
     excessive amounts of dilution which may prevent the
     detection of statistically significant changes in indicator
     parameters.  The diluted concentration of contaminants may
     be below detection limits of the laboratory method being
     used.  However,  it should be noted that the fluctuating
     potentiometric  surfaces at the site (couple of feet) and
     also the low hydraulic conductivities, some times necessi-
     tates  the use of longer well screens at some locations at
     t-he site. However,  screens more than 20 feet are too long
     to adequately detect contaminants and maintain chemical
     resolution vertically. Therefore, MW-15 should be
     replaced by two wells.

2.2  Location Evaluation

         The site,  as discussed earlier, has a very complex
     geology which is caused by closely spaced fractures,
     faults, tight folds and variable lithologies within three
     dominant facies. The hydraulic gradient and the flow
     paths  are highly influenced by the complex structure of
     the site, the adequate monitoring system should intercept
     all the potential pathways for contaminant migrations.
     Considering the above factors, the horizontal and vertical
     spacings of some of the monitoring wells at the Panoche
     Facility are not adequate.

          South-southwest of pond 12, between MW-54 (previously
     MW-1)  and the cluster of wells that was just mentioned,
     a distance of about 300 feet is not being monitored. The
     ground water contours indicate relatively steep hydraulic
     gradient (approximately 0.25)  at this location, also the
     existance of a  relatively extensive fracture has been
     revealed by trench T-l (see Figure 6). The fault
     apparently runs parallel to the facility boundary and is
     located in a saddle. Therefore, the fault plane in this
     area needs to be monitored. If the saturated weathered
     zone is up to 20 feet at this location one fully penetra-
     ting well is sufficient. If the saturated zone is more
     than 20 feet, two wells will be required, to monitor the
     top and the bottom portions of the weathered bedrock.

          The area west of pond 13A  (the compliance point) is
     being  monitored by two deep wells, MW-35 and MW-36. These
     wells  are screened from 75-85 feet and 110-125 feet res-
     pectively. During wet seasons, in well 35, depth to water
     is typically 63 feet and during dry seasons it is about
     66 feet. At well 36, depth to water during wet seasons is
     about 81 feet and during dry seasons  it is around 86 feet.
     None of these two wells are monitoring the uppper portion

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                              -48-
          of the aquifer at the water level,  therefore they are not
          adequate to detect volatile organics.  The facility should
          install one monitoring well close to wells 35 and 36 with
          the screen interval monitoring the  upper portion of the
          aquifer.

               There is one monitoring well,  MW-16,  which is accept-
          able by. EPA as a background well. MW-16 is an upgradient
          background well which is located at the most northern part
          of the facility. It is completed in the upper unweathered
          bedrock and the screen interval is  from 29 to 44 feet.
          During the dry season the water level  is typically 10 to
          12 feet, and in the wet seasons it  rises to about 4 to 5
          feet.

               EPA does not consider the locations of other back-
          ground wells (proposed by the facility) to be adequate
          for this purpose.  These wells are MW-23,  MW-22 and MW-20.

               Monitoring well MW-23 is located  in the N Canyon,
          a natural discharge area, and it is east-southeast and
          relatively downgradient of the north drum burial area
          (Figure 2).

               Monitoring well MW-22 apparently  has detected the
          plume which has originated from ponds  0,  P and Q.

               Monitoring well MW-20 (2500 feet  south of the facil-
          ity) has somewhat different ground  water quality compare
          to MW-16,  therefore it should not be used as a background
          well representing the ambient water quality at the site.

               It is recommended that the facility should consider
          to install additional upgradient background well Is) in
          the vicinity of MW-16 or higher up  the elevation.  The
          additional upgradient well(s) could be screened in weathered
          and also deep unweathered bedrock at different locations
          so that more information regarding  spatial and vertical
          variability in ground water quality would be collected.

3.   Aquifer Test/Identification of Lower Boundary

         The identification of the lower boundary is an essential
    facet of the physical characteristics of  the upper-most aquifer
    at the facility. Therefore, as part of the study and expansion
    of ground water monitoring system, the facility has proposed to
    further investigate and determine the base of the upper-most
    aquifer,  by compiling and evaluating reports of groundwater
    occurance, existing permeability data, geochemistry of ground-
    water in weathered and unweathered zones, and also by conducting
    feild tests  and installing additional wells.  The field test
    program would allow some initial evaluations of connections

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                                   -49-
         between water producing zones. The following table briefly
        .describes the field test locations and new wells proposed by
         the facility, and also the additional locations and monitoring
         wells which EPA is requesting from the facility:
Well No.s

MW-35, 36, and
(New shallow well,
  see P 48)*

MW-38, 39, 10*
(New shallow well
 close to SB-8)*

Piezometer Nest
SB-4

Piezometer Nest
SB-5, and MW-41*
Completion Intervals

75-85, 110-125, and
(Top of the saturated
  zone at G.W. level)

66-76, 129-158, 26-51,
and (Top of the saturated
zone at G.W. level)

34-44, 201-211 & 261-271
86-96, 119-129, 201-271,
and 26-36
                   Additional
Facility Proposal  EPA Request
SB-3 & (new shallow  131-151 & 30-40 (proposed)
  well)
MW 42 & (new deep
  well)

MW-51*, 50*, (new
  deep well)*
13-23 & (to be determined)
18-28, 18-28, (first water
bearing zone or fracture
in unweathered bedrock)
        X
MW-24*, 46*, & (New    40-50, 51-61,
  deepwell)*         (to be determined)

     * New wells, and/or existing wells which EPA is requesting to be
       added to  the pump or bailer tests.
              The following paragraphs explain why the new locations
         and installation of additional monitoring wells, for the  field
         tests, are requested by EPA:

              The area east of ponds O, P and Q is monitored by several
         shallow monitoring wells  (MW-49, 50, 51, 53). There are no deep
         wells for monitoring the  unweathered bedrock specifically at
         the fault VI zone. Based  on the maps provided by the facility
         MW-51 appears to be close or at the fault zone. Therefore, the
         proposed new deep monitoring well  (by EPA) at this location is
         necessary for evaluation  of any connection between weathered and
         unweathered bedrock and the hydraulic conductivity values at the
         fault zone.

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                              -50-
         The area south of the central area,  south of ponds, 1 and
    2,  has not been investigated adequately for the depth of the
    uppermost aquifer,  for identifying the fault zone (fault V)
    accurately/  and for the geologic and hydrogeologic characteris-
    tics of the unweathered bedrock. The facility should provide
    information and adequate data regarding the extent of the upper-
    most aquifer,  any potential connection with deeper water bearing
    zones, the characteristics of the fault zone and its exact trend
    and location..

         The scope of work for field tests will begin with slug
    test on" each well.  Following the slug tests, pumping tests
    will be run in the deep wells to further evaluate possible
    hydraulic connections and to measure water producing properties
    of these zones. The pumping tests and the frequency of measure-
    ments should be adequate enough to generate the "time-drawdown"
    curve(s) for shallow and deep wells.

         In brief,  the proposed locations for new wells by EPA are
    essential to reduce the existing data gaps, and better compre-
    hend the possible pathways, where preferential flow might occur.
    These wells will also provide more information regarding the
    existing contaminant plumes and will be part of the assessment
    monitoring system and delineation study of the plumes which are
    discussed in the following sections.

F.  Contaminant Plumes, Facility's Assessment Monitoring Plans

         In February 1984, the facility notified CA RWQCB indicating
    that contaminant have migrated offsite, down gradient from ponds
    12-13 and remedial action was initiated.  Data showed monitoring
    wells MW-2A, MW-2B, MW-10, MW-13, MW-17,  and MW-18 have been
    effected and that contaminants have migrated outside of the
    designated disposal areas, possibly from pond 12 through 16.
    Also, the geotechnical information submitted in July 1984 and
    subsequent water quality data from wells f MW-7 and MW-21 in
    October 1984,  indicated that wastes and/or waters that have
    contacted wastes were present outside of the designated disposal
    area. These wells are downgradient from ponds O,  P,  and Q,
    therefore it appeared that these ponds are contributing to this
    situation. Under the interim status groundwater monitoring
    program the facility started the assessment of the ground water
    contamination and remedial works.

         According to the facility, remedial actions at ponds 12-16
    commenced by not disposing liquid waste in those ponds any more,
    and by drying and removal of all the sludge and capping the
    ponds. Therefore, the head was eliminated and the source of the
    plume was removed.  A french drain system was also installed
    south of ponds 12-13 to collect the seepage. The sludges were
    also removed from ponds 0 and P and after double lining started
    accepting liquid wastes. The facility also asserts that,
    pond Q has not received any liquid wastes since November 1985.

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                          -51-
     In order to determine the extent of contaminant migration
from the ponds. The facility have been conducting investiga-
tions which are atill on going. The investigations consisted
of excavation of trenches to locate and characterize suspected
fault zones. Characteristics of these zones at greater depths
were investigated with boreholes and continuous cores. Combina-
tion of geologic logging of the cores, borehole geophysical
logging and in situ permeability testing were used to evaluate
subsurface conditions and flow paths. The vertical extent of
chemical migration into the soil was investigated below the
ponds by drilling, sampling and chemical analyses. Also,  in
mid-198-6 the facility identified another area, north drum burial
area, where contamination has been detected in ground water.
Analysis of samples taken by GWTF during field investigation,
have verified the existance of these contaminant plumes.  Two
additional areas of concern (pond 8 series and SWMU 61) have
been identified by the GWTF where the facility should inves-
tigate and assess the problems. These two areas are discussed
in section G (Subsections 3 and 5).

 1.  Area West, Southwest of Ponds 12-16

          The facility has conducted investigations to identify
     the vertical and horizontal extent of the contaminant
     migration.

          Vertical extent of contaminant migration into the soil
     beneath the ponds has been interpreted chiefly from the
     results of the pond borings. Chloride concentrations were
     interpreted by the facility to indicate the maximum depth
     of chemical migration. Depths to the first samples with
     concentrations at background levels are:

     Pond 13           47 Feet

     Pond 14           44 Feet

     Pond 15           37 to 48 Feet (results from 3 borings)

     Pond 16           33 Feet

     Waste Pile 13A    36 to 48+ Feet (results from 2 borings)

          A maximum depth for pond 12 was not determined because
     of contamination of soil samples during sampling.

          According to the facility, the maximum depths at which
     elevated TOG and oil and grease concentrations were found
     in the soil are as follows:

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                         -52-
                      TOC              Oil and Grease

    Pond 12           17                  17

    Pond 13           NE                  22.5

    Pond 14           0-22*               0-22*

    Pond 15  .         NE                  0-13b

    Pond 16           17.5                NE

    Waste Pile 13A    NE                  13.5-19.5 (two borings)

NE - No elevated value

a  = Elevated value found in one out of two borings.

b  = Elevated value found in two out of three borings.

     According to facility, because of high variability at metal
concentrations and lack of trends, a definite migration depth
for all metals could not be determined with certainty. However,
some conclusions were drawn from chemical results about the
vertical migration potential of various metals.

     Elevated nickel and Zinc concentrations were found at 8.5
feet in pond 16. Elevated lead concentration were observed to
a maximum depth of 54 feet. However, the facility questions
the elevated value of lead at this depth since it is below the
maximum depth of chloride migration in pond 13.

     Investigations performed by the facility to identify the
horizontal extent of the contaminant migrations have indicated
that the ground water has been affected by contaminants in
monitoring wells 17, 18, 2B, 23 and 29. The ground water
contamination was characterized by high concentrations of
parameters including chloride,  and total disolved solids (TDS) .
As the ground water moves towards the west these parameters
show a decrease in concentrations. Further north, west of
pond 14, elevated chloride, sulfate and TDS are detected in
MW-13 and down gradient wells C-4, MW-31. South of pond 12,
wells C-2 and MW-1 (replaced by MW-54) show elevated values
of parameters including chloride, sulfates,  and TDS.

     Corrective measures have been taken by the facility
to remedy the seepage of contaminated fluid from ponds 12
through 16. In 1984, ponds 12 through 16 were drained and
bottom sludges were removed. The pond area,  were capped with
two- to four-foot layer of compacted, clean, clayey fill to
prevent infiltration. In 1981,  at the southwest toe of the
pond 12 dike, a 100 foot long subsurface drainage trench was

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                              -53-


     installed,  as part of  the stability of  the containment struc-
     ture,  to collect fluids  seeping  through dike  material and
     return these fluids to the pond.  In April 1984 two other
     subsurface  drainage trenches  were added,  one  located along
     the toe of  the containment dike  on the  northeast of ponds,
     12 and 13,  and the other along the south side of pond 12.
     South west  of ponds 12 and 13, a 12-inch diameter recovery
     well with a submersible  electric pump was installed in April
     1985.  The initial rate of recovery was  5.2 gallons per hour,
     which it dropped to 0.5  gallons  per hour after couple months.

2.   North Drum  Burial Area

          In mid 1986, a field investigation was initiated to assess
     the level and extent of  leachate migration away from the burial
     cells. Eight boreholes were drilled at  the drum burial area.
     Seven of them were positioned downdip and downslope of the
     burial cells and one borehole (ND-7) was positioned upslope and
     updip of the area to provide  background information.  Depths
     of these boreholes were in the order of 34 to 39 feet except
     in ND-7 were the borehole is  49  feet deep (Figure 2). The
     results of  the chemical analyses of the soil  and rock composites
     have detected low levels of certain volatile  organic compounds
     as well as  low levels  of some priority  pollutant metals and
     occasional  traces of phathalates.

          The results of priority  pollutant  metal  analysis indicated:
            Arsenic up to 43 ppm (ND-8)
            Chromium up to 68 ppm (ND-8)
            Copper up to 69 ppm (ND-3)
            Lead up to 7 ppm (ND-4)
            Nickel up to 84 ppm (ND-4)
            Zinc up to 100 ppm (ND-4)
          These results are less than the Total Threshold Limit
     Concentration (TTLC)  values.

          Detected volatile organcis were:

          • Carbon tetrachloride 1.3 ppm (ND-S)
          • Chlorobenzene 0.013 ppm (ND-2)
          • Chloroform 1.9 ppm (ND-8)
          • 1,2-Dichloroethane .0185 ppm (ND-8)
          • Trans-l,2-Dichloroethene 0.26 ppm (ND-8)
          « 1,2-Dichloropropane 0.25 ppm, average value,  (ND-8)
          • Methylene chloride up to 66 ppm (ND-8)
          • Tetrachloroethene up to 3 ppm (ND-8)

          These concentrations were detected at depths of about
     32 feet (ND-8) and 20 to 30 feet (ND-2).

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                              -54-
          .Monitoring well,  MW-11 and upgradient well MW-16 were
     sampled also.  Elevated amounts of chloride (250 ppm),
     nitrate (22 ppm),  TDS (1200 ppm), Spec. Cond. (1910 umhos/cm),
     Sulfate (200 ppm)  and TOG (4.25 ppm) in MW-11, relative to
     MW-16, indicate that the ground water has been affected by
     leachate from the  north drum burial area.

3.   Ponds 0, P and Q Area

          The results of the preliminary investigation of the soil
     chemical analytical work and ground water quality performed in
     early 1985 indicated that soil and groundwater in the vicinity
     of ponds 0, P, and Q have been contaminated.  The following is
     a summary of vertical and lateral extent of contamination
     reported by the facility.

          The soil samples indicated acidic pH values (2.05-4.30)
     usually to a depth of about 21 feet. However, in PB-104 pH
     value of 4.30 was  identified at depth of 50 feet. Elevated
     chloride concentrations and elevated trace element concentra-
     tions were mostly  related to areas and depths where acidic
     pH values were observed.

          Most of the soil samples from soil borings,  showed alka-
     line pH values ranging from 7.10 to 9.20. These alkaline pH
     values were mostly observed at depths greater than 30 feet to
     a maximum depth of 55 feet (PB-107).

          Lateral extent of migration of plume chiefly was indicated
     by elevated TDS (most notably chloride),  and  elevated levels of
     specific conductance.  South of the ponds as far as MW-42 has
     been effected by plume migration. Monitoring  well C-6,  north-
     east of the ponds  area has shown moderately elevated chloride
     and specific conductance values. These values showed decrease
     in levels in MW-22, which is located downgradient from C-6.
     Initial investigation of the pond 0, P, and Q area involved
     drilling boreholes to obtain soil and rock samples in the pond
     area and performing electromagnetic and resistivity surveys in
     the area surrounding the ponds. Additional monitoring wells
     were installed to  monitor the effected ground water. The
     ground water monitoring is still ongoing and  the facility is
     in the process of  compiling and analyzing additional water
     quality data.

4.   Area South of Ponds 1 and 2

          By letter to  the Regional Water Quality  Control Board
     dated September 30, 1985, IT indicated that seepage to the land
     surface had been detected in the area south of ponds 1 and 2.
     The letter described a plan for installation  of shallow collec-
     tion trenches which were completed by April,  1986. Seepage was
     later observed downslope from these trenches  in the area between
     trenches and unit  2B.  The collection trenches were extended
     and deepened during the fall of 1986 to capture this seepage.

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                              -55-


          Monitoring wells MW-24 and MW-46,  produced samples that
     suggested mixing of ground water with leachate from waste
     materials.  Measured chloride concentrations in water samples
     from alluvial fill, ranged from 1,400 to 3,000 ppm during the
     period November, 1984 to April 1986.  The range in measured
     chloride concentrations in samples from MW-46,  completed in
     the base of the alluvial fill in the  same location was 7,700
     to 8,300 ppm during the period October,  1985 to April 1986.

          The facility is in the process of determining the vertical
     and horizontal extent of waste constituent migration in ground
     water.. For the area south of ponds 1  and 2,  the work will
     involve identifying waste materials in the underlying fill in
     addition to establishing effects on ground water quality. The
     scope of work includes: Conducting electromagnetic and resis-
     tivity surveys to outline areas of anamolous conductivity
     values in ground water; auger six to  eight boreholes between
     ponds 1, 2, and 2B and taking core samples (every 5 feet) for
     chemical analyses; converting selected boreholes to monitoring
     wells, the wells will monitor the alluvial materials, weathered
     bedrock, and unweathered bedrock.

G.   Evaluation of Facility's Assessment Plans

 1.   Ponds 12 through 16

          The facility in conjunction with the requirements of"
     the RWQCB has proposed additional Investigation regarding
     assessment of contamination plume in the vicinity of ponds 12
     through 16. The investigations include:

     1-  Water quality analysis by comparisons of samples from
         surface sampling, shallow and deep wells.

     2-  Review of fluid migration by further evaluation of
         mechanics and paths of fluid migration.  Most recent sub-
         surface data will be combined with previous information
         and new detailed cross sections,  addressing potential
         pathways, will be developed.

     3-  Hydrologic characteristics of the Paddy Creek watershed
         will be evaluated further which will include evaluation
         of seeps, springs, and surface and ground water quality.

     4-  Three new monitoring wells will be installed to  inves-
         tigate possible effects of plume migration on ground
         water in the Paddy Creek drainage, these wells will be
         placed:

           •  Upstream of the confluence of tributaries, that
             originate  in the ponds 12 through 16 area,

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                         -56-
     '  East side of Paddy Creek,  few hundred feet downstream
        Of MW-56,

     *  East side of Paddy Creek,  downstream of the tributary
        containing MW-28 and MW-29.

     The proposed locations of the three monitoring wells in
the vicinity of Paddy Creek is suitable,  however they are not
sufficient for delineation of the existing plume.  Additional
monitoring wells should be installed in the effected area to
fully characterized the extent and rate of the contaminant
plume.

1.1  Additional EPA Requests;

     The following paragraph identify the locations where EPA
is proposing the additional monitoring wells should be
installed.

     *  One shallow well should be installed downgradient
        from MW-39 at the fault IV zone,  approximately half
        way between Paddy Creek and MW-39. The screen
        interval should be placed at the ground water level
        in the fractured bedrock.

     *  A monitoring well should be installed close to
        shallow well MW-26, at the fault II zone.  The
        screen interval should be placed in the fractured
        bedrock to monitor the fault plane (the screen
        should be placed immediately below the MW-26 screen
        interval). This new well will provide additional
        information about fault II and its effect  on hori-
        zontal and vertical component of the ground water
        flow.

     *  The shallow well proposed to be installed  in the
        vicinity of deep wells MW-35 and MW-36 (see P.48)
        will provide information regarding the concentra-
        tion and possible contamination of ground  water by
        volatile organics (MW-35 and MW-36 are not adequate
        to detect volatile organic contaminants).  The
        screen for the shallow well should be placed at
        the water table to monitor the top portion of the
        saturated zone. (MW-35 monitors to interval from
        75 to 85 feet and water level is usually at about
        63 to 66 feet, therefore,  about 10 to 12 feet of
        the upper saturated zone is not being monitored).

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                              -57-
          0   MW-33 in the dry season does not produce sufficient
             amount of water for sampling.  The screen interval
             is from 23.5 to 33.5 feet and the depth to ground
             water level fluctuates  from 24 to 30 feet.  Since
             the location of this well is important for plume
             delineation in the vicinity of Paddy Creek,  another
             monitoring well should  be installed in this area.
             The new well should monitor the deeper zone below
             the clay gouge identified at the bottom of MW-33.

          *   The replacement wells in the vicinity of MW-17,
             MW-18, and MW-19 (proposed by EPA,  see P.46),
             will provide information regarding the extent
             and level of contaminants,  specifically volatile
             organics. In addition deep monitoring wells are
             required to initiate the study of vertical extent
             of ground water contamination in the proximities
             of MW-17, MW-19 and also MW-2a and 2b.

          *   Proposed new monitoring well (proposed by EPA,
             see P.47) west of MW-54 in the saddle where an
             extensive fracture exists (in the vicinity of  T-l
             and T-S), should be included in the assessment
             program regarding the extent of contamination  from
             ponds 12 through 13A. Another shallow monitoring
             well (screened at the G.W.  level) should be installed
             south of MW-1 in the same tributary. MW-1 has  shown
             evidence of contamination therefore the extent of
             the plume in this area  must be investigated.

2.   South of Ponds 1 and 2

          The scope of work to investigate contaminant plume
     south of ponds 1 and 2, proposed by the facility,  include:

          1-  Containment of surface seeps south of ponds,

          2-  Conducting surface geophysis (EM and resistivity)
              in the area between ponds  1 and 2 pond 2B.

          3-  Drilling 7 boreholes between ponds 1 and 2 and
              pond 2B for geochemical analysis.

          4-  Converting 3 of the borings to wells capable  of
              monitoring the alluvium and weathered bedrock.

          5-  Defining the areal extent of solid waste materials
              in the area and southward extent of waste constituent
              migration in the ground water.

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                         -58-
2.1  Additional EPA Requests

     None of the existing wells south of ponds 1 and 2, namely
MW-24, MW-46, and MW-52 are adequate for detection of volatile
organics in the ground water. All these wells monitor the
mid or lower portion of the saturated zone in the alluvial
deposits. In the vicinity of MW-24 and MW-46, 30 to 40 feet of
upper saturated zone is not being monitored.  In the vicinity
of MW-52 the unmonitored upper portion is about 9 feet. There-
fore, several shallow wells south, southeast, and southwest of
ponds 1 and 2 (at the compliance point) are required to monitor
effectively for volatile organics. In addition deep monitoring
wells are required to monitor the weathered and unweathered
bedrock. Furthermore, the trend of fault V and its depth must
be identified and the fractured bedrock in the fault zone
should be monitored. In brief, the proposed 3 monitoring
wells are not sufficient to initiate the plume assessment and
to characterize the aquifer south of ponds 1 and 2. There is
indication that fault V strikes north northwest and passes
beneath pond 2. Fault II strikes northwest; it passes close
to southwest corner of pond 2 and runs parallel to pond 8
series. In addition couple other monitoring wells are required
to be installed downgradient from MW-52, MW-46 and/or MW-24,
closer to pond 2B.

     Due to physical setting of the site most of the ground.
water discharges into the drainage basin in the central and
south of the facility. The ground water at this drainage area
becomes contaminated due to contact with sludges that exist
beneath the central area. The facility with the aid of piezo-
meters and monitoring wells should construct flow nets for the
area of pond 2B and determine whether the ground water beneath
this pond has vertically upward or downward gradients. If
there is an upward gradient, some of the contaminated ground
water might be discharging into the pond 2B.  Therefore, as an
integral part of the assessment program for this area, the
facility should also collect some samples of the sediments
and/or sludges from the bottom of pond 2B. A complete GC/MS
analysis should be performed utilizing methods 3240 and 3250
(SW-S46) for volatile and semivolatile organics. EP toxicity
test should also be performed on the samples. Furthermore,
the assessment program for the area south of ponds 1 and 2
should be expanded to south of pond 2B. MW-25 and MW-14 have
both detected elevated levels of heavy metals, and indicator
chemicals (Table 5). None of these two wells are screened
at the water table,  so they are not adequate for detecting
volatile organics. The facility should install shallow wells
south of pond 2B to further investigate the possible extent
and rate of the plume. Apparently wells 14 and 25 have begun
to detect the edge of the plume which has originated from the
central area and south of pond 1 and 2.

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                             -59-
3.   Ponds 0,  P,  Q and Solid Waste Management Unit 61

         The directions of contaminant migration from these ponds
    (0,  P,  and Q) are toward south,  southwest,  southeast,  and east
    The proposed supplemental work on the ground water monitoring
    program include:

         1-  Drilling deeper boreholes at 7 of  the 12 original
             locations: PB-102 through PB-106,  MW-44 and MW-49
             (For locations see Figure 2),  and

         2"-  Replacement of wells C-6,  MW-41, MW-48,  MW-53,  MW-12.

    3. 1   Additional EPA Requests

         Existing monitoring network south of ponds O, P,
    and  Q and the proposed supplemental work are adequate for
    characterizing the extent of the plume,  south of the ponds,
    inside the facility boundry. East-southeast migration of
    the  plume is being monitored by monitoring  wells MW-51 and
    MW-50.  The screens are placed in a way so that little more
    than half of the lengths monitor the weathered bedrock and
    the  bottom protions monitor the unweathered bedrock (screen
    intervals are from 18 to 28 feet),  the peizometer level in
    this area in dry seasons drops to approximate depths of 23
    to 25 feet,  which is almost at the contact  of weathered and
    unweathered bedrock. In MW-50 water table drops to about
    26 feet,  leaving only 2 feet of water column in the screen.
    In brief, more monitoring wells are required in this area
    to monitor the upper portion of the unweathered bedrock. A
    well could be placed in the vicinity of MW-50,  and screened
    approximately from 25 to 30 feet.

         Another set of monitoring wells are required in the
    vicinity of PB-107, outside of the facility boundary,  east of
    MW-50.  As discussed earlier (see P.54)  alkaline pH values
    (7.10 to 9.20) were observed at depths of .30 to 55 feet in
    PB-107 The borehole is located almost on top of a ground water
    divide, where the flow probably changes directions in two
    opposite paths. One direction could be northeast towards the
    tributary containing MW-22, and the other south-southwest,
    toward MW-27, MW-6 and the tributary which  originates in
    this area. This tributary probably reflects the trend of a
    possible fracture (Figure 12). One monitoring well should be
    installed in each of these flow paths,  northeast and southwest
    of PB-107. The top of the screens should be placed at the
    ground water level (in weathered or unweathered bedrock).
    Another well should be installed at or close to PB-107 and
    screened in the fracture zone where high pH values were
    detected.

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                          -60-
   . ; Tributary containing MW-22  is  the  reflection  of  a  major
 fracture that connects the Green Valley  fault  to fault  I  (pre-
 viously A) at the  facility (see Figure  12). Since  MW-22 has
 shown evidence of  contamination, additional shallow monitoring
 wells should be installed further downgradient from MW-22 in
 the drainage for defining the horizontal extent of the plume
 and for studying the rate of that plume.

     Deep monitoring wells are required  in the vicinity of
 MW-49, and MW-51 to monitor the unweathered bedrock and to
 define vertical extent of contamination  in groundwater.
 The deep well close to MW-51 will also provide information
 regarding fault VI, fractured unweathered bedrock  in that
 zone, and possible connection between unweathered  and upper
 weathered bedrock.

     Solid waste management unit (SWMU) 61, southeast of ponds
 0, P, and Q has not been addressed by the facility in their
 assessment program. This SWMU could be another or  the main
 source of contamination for monitoring wells MW-47, MW-48, and
 MW-27. These wells are down gradient from SWMU 61,  at the foot
 of the ridge where SWMU 61 is located (see Figure  2). The
 facility should investigate the possibility of this unit as a
 source. Preliminary geochemical borings for sampling of the
 soil beneath SWMU 61 is necessary. The ground water levels
 should be noted and the gradient between the piezometric surface
 beneath the SWMU and the monitoring wells MW-47,  MW-S, MW-27,
 and MW-48 must be established.  The ground water chemistry
 beneath the SWMU 61 and the above monitoring wells should be
 correlated.

     Potential directions for possible plume migration from
 SWMU 61 would be toward south and southeast. Monitoring well
 MW-48 is almost at the southern tip of the unit.  Monitoring
 wells MW-47,  MW-5 are located east and downgradient from the
 unit, and MW-27 is further downgradient, southeast of the unit.
 The facility should assess the area and submit the results of
 evaluation regarding SWMU 61 and the possibility of it being a
 source of contamination for the mentioned monitoring wells.
 Furthermore the extent of the existing contamination east and
 south of this SWMU must be investigated. Additional shallow
 monitoring wells are required to monitor: 1) the tributary
 trending east between MW-5 and MW-27,  and 2) the area turther
 downgradient from MW-48,  toward south,  along the facility
boundary.

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                              -61-
4.    North- Drum Burial Area

          The geology and hydrogeology of this solid waste
     management unit are not studied as well as other areas at the
     Panoche facility. As discussed earlier a recent subsurface
     investigation of the area was conducted to obtain preliminary
     information.  A total of eight boreholes were drilled,  and
     the facility has proposed to install a total of fifteen moni-
     toring wells--inside and at the perimeter of the drum burial
     area (Figure 18) to assess the extent of leachate into the
     ground water. This system of wells will monitor both the
     weathered and unweathered bedrock including the fault line
     (fault I) which passess beneath the burial area. The boring
     and monitoring wells will also provide information regarding:
     Ground water levels to define flow directions and rates,
     stratigraphy and piezometric heads on either side of the
     fault line to assess the impacts of the fault on the hydro-
     geologic regime, water quality data to define potential
     contaminant migration.

          The scope of work is adequate for preliminary assessment
     program, although the facility has not defined specifically
     how-deep the ground water monitoring wells will be installed
     at various locations. One issue of concern is the location of
     MW-23 which is located at the natural depression and drainage
     area called the N canyon. The facility is considering MW-23
     an upgradient background well relative to the facility's waste
     management units. However, this well is located east-southeast
     and relatively downgradient from the north drum burial area
     (Figure 2). Since local and secondary ground water flow paths
     from the burial area could effect the ground water at MW-23,
     EPA will not accept this well as a suitable upgradient back-
     ground well.  Due to its location, MW-23 should be included
     in the assessment monitoring program of the burial area.

5.    South of Pond 8 Series

          During the GWTF field investigation, as part of the pro-
     gram, piezometer nest 4 (4A, 4B, 4C) were sounded for ground
     water level recordings. Piezometer 4A is the deepest well.
     It is screened from 261 to 271 feet, and the screened interval
     is placed in shale with thin sandstone interbeds. Piezometer
     4B is the intermediate well which is screened from 201 to 211
     feet. It also is screened in the same lithology as 4A. Piezo-
     meter 4C is the shallow well and is screened from 34 to 44 feet
     in the shale. The top 1 or 2 feet of the screen is in the
     limestone interbeded with shale.

          Before the sounding, as part of the project plan, the
     piezometers were screened, at the well head, for any organic
     vapors using a photovac. After the well cap was removed,  the
     probe of the photovac was inserted into the well head and
     readings were recorded. Piezometer 4A readings  indicated

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                              -62-
     high-values of organic vapors, 20-30 parts per million (ppm).
     Well 4B reading indicated 2 ppm and well 4C,  1.5 ppm. The
     photovacs were calibrated daily for background ambient air
     which the values ranged from 0 to 0.5 ppm.

          The high values of organic vapors in piesometer 4A indi-
     cate that the ground water is contaminated and that contamina-
     tion has possibly migrated vertically into the unweathered
     bedrock to depths of 200 feet or more. These  piezometers are
     placed in one borehole and the specifics on the construction
     of these wells are not available. Very little is known about
     the geology and hydrogeology of this area,  except the existence
     of fault II which apparently runs very close  to SB-4 cluster.
     The facility should investigate the area and  confirm the air
     monitoring results (at the well heads) performed by the GWTF.
     If the results are positive, a plan should be submitted regard-
     ing geological and hydrogeological investigation of the area
     including plans for installation of monitoring wells in clusters
     and along the fault. Monitoring wells, the ones in cluster(s),
     should not be placed in a single borehole.

6.    Summary of Evaluations Regarding Detection and Assessment
     Monitoring

          In brief, evaluation of the facility's ground water
     monitoring systems and the assessment program indicates that
     additional wells at the compliance points ($244.99(b)  40 CFR)
     and down gradient from the waste management units are neeaed
     (as specified in the report).  The major deficiency of the
     detection monitoring system is the lack of  adequate shallow
     wells with appropriate screen intervals,  for  detection of
     volatile organics.  At several  locations,  specifically south  of
     ponds  1 and 2,  south of pond 2B,  and west of  ponds 12 through
     13A, where contamination has been detected, full  length of the
     saturated zone in alluvial deposits and weathered bedrock is
     not being monitored.  The assessment program (overall)  lacks
     sufficient monitoring wells to effectively  and within reasonable
     time period delineate the extent of the plumes (vertically and
     horizontally),  and to accurately define the concentrations of
     hazardous waste constituents in ground water.

          It should be noted that the number and location of
     monitoring wells proposed by the GWTF are not by  any means
     final.  Also,  the proposal does not imply that it  will make
     the assessment monitoring systems,  complete.  Further along
     the assessment program there might be a need  for  additional
     monitoring wells in order to be able to fully define the
     periphery of the plumes.  The proposed locations and screen
     intervals are chosen primarily based on complex and extensive
     faulting and folding structures at the facility/proximities,
     and lack of adequate and effective ground water monitoring in
     specific areas.  The exact locations and screen intervals  are
     subject to change depending on accessibility  and  variations
     in field conditions.

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                              -63-


H.  Summary of Statistical Analysis Performed on Facility's Data,
    and HWGWTF Sampling Results

    1.  Ground Water Statistical Results

             The following is a brief summary of the results of
        statistical analysis performed on IT Panoche's ground water
        data (1984-1986)  by, Camp Dresser and McKee (CDM),  EPA's
        contractor*

        0  Local seasonal precipitation patterns appear to be
           correlative with changes in ground water levels within
           the shallow aquifer and in deeper unweathered zone
           which implies  hydraulic connection between weathered
           and unweathered bedrock. Time-series analysis of ground
           water chemistry did not identify a seasonal pattern due
           to insufficient data over an annual cycle during and
           after periods  of significant recharge.

        "  The number of  parameters (35) measured in ground
           water from the IT Panoche site was reduced to a more
           manageable set by using correlation statistics and
           factor analysis. Briefly, the goal of factor analysis
           is to explain the relationships between variables by
           the presence of a few factors. The objective of using
           factor analysis was to select a set of indicator para-
           meters which would describe most of the variance in
           the data set.

        0  Cluster analysis was employed to classify the IT vari-
           ables into more or less homogeneous groups so that
           inter- and intra-group relations become apparent.
           Cluster analysis was used in conjunction with factor
           analysis to select indicator parameters and to group
           wells based on their water analyses. Five groups,
           based on the specific conductivity and cl:SO4 ratio,
           were distinguished. Table 2 summarizes the general
           characteristics and the wells in each group.

        *  Analysis of variance (ANOVA) was used on the IT-Panoche
           site data to test for differences in analyte populations
           between specified wells. ANOVA techniques test for
           differences in sample means by comparing them with the
           variance. The ANOVA routine was less prone to false
           positive conclusion error in this survey (probability
           of error was 0.01). For the situation in which two
           wells are compared, ANOVA is equivalent to the students
           T-tests; both accept or reject the hypothesis identically

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                    -64-
 MW-20 was  compared with MW-16 to identity whether MW-20
 could be used as  a background well.  The  comparison
 indicated  TOX and TOG appear similar while Cl,  Sp.
 Cond.,  and 804 are representative of different  popula-
 tions (Table 2-8,  Appendix B,  CDM report).  Based on
 this  analysis MW-20 should not be considered  represen-
 tative of  ambient water quality conditions  in the IT
 Panoche watershed.

 Well  MW-14 (south of pond 2B)  which  represents  cluster
 1  was  compared to the background well, MW-16. The
-analysis of variance (ANOVA,  see Table 3)  indicates
 that  TOC and TOX  are similar  while CA, Cl,  SO4/  and Sp.
 Cond.  come from different polulations. This suggests
 the existance of  a subsurface C1/S04 plume. The con-
 clusion is that the water quality of wells  in cluster  1,
 namely 2B, C6,  MW-7,  MW-13,  MW-14, MW-17,  MW-21,  MW-28,
 MW-45,  MW-49,  MW-53,  and MW-56 are degraded significantly
 from  ambient water quality.

 Comparison of background well (MW-16) with  well MW-22,
 cleanest water quality in cluster #3, indicates pre-
 sence  of contamination beyond the boundary  of waste
 management area.  The ANOVA test (Table 3)  indicated that
 Ca, Cl and 804 differ while the Sp.  Cond.,  TOC  and TOX
 are similar.  By inference this suggests  that  all areas
 represented in cluster #3 are contaminated  by leachate.
 These wells are MW-10,  MW-22,  MW-27,  MW-25, MW-29,  MW-34,
 MW-41,  MW-43,  MW-46,  MW-48,  MW-51, and MW-52.

 MW-31  was  selected from cluster 14 for comparison with
 the background (MW-16)  water  quality. The ANOVA results
 indicate (Table 3)  exceeding values  for  Chloride,
 Spec.  Cond.,  Ca,  and TOC relative to the background.
 The conclusions from this test are that  the wells in
 cluster #4 (MW-1,  MW-26,  MW-31,  MW-47, and  C2)  exhibit
 contamination and that chloride and  some organic cons-
 tituents migrating off site to the west  and south.

 Cluster 12 consists of the background well  MW-16 and
 four  of the five  deep unweathered bedrock  wells (MW-36
 through MW-39). These wells are characterized by a
 specific conductivity generally between  1500-5000 us/cm
 and generally low cl and SO4.  Cluster #5 may  be gene-
 rally characterized by low concentrations  of  Cl and 804
 and by a low Sp.  Cond.   (<1000 us/cm). Two wells from
 clusters #2 and #5 (MW-39 and MW-35,  respectively) were
 compared with background conditions.  The results indi-
 cate  the upper unweathered bedrock has significantly
 more  chloride than either background or  deep  unweathered
 bedrock. This implies vertical migration of chloride
 through alluvium  and weathered bedrock  in the vicinity
 of ponds 13 and 13A based on the ground  water chemistry
 at wells MW-35 through MW-39 (see Table  4).

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                              -65-
2.   HWGWTF. Ground Water Sampling Results

         The following summary explains the analytical results for
    the ground water samples collected by HWGWTF in August 1986.

        '  All wells that were sampled showed at least one inor-
           ganic indicator or total metal value above background
           (except MW-9A). The maximum concentration for chloride
           was 36,200 ppm (MW-49),  Sulfate up to 1,130 ppm (MW-39),
           TOG up "to 212 ppm (MW-17),  TOX up to 0.065 ppm (MW-49),
           nitrate nitrogen up to 67.5 ppm (MW-46),  amonia nitrogen
           .up to 2.10 ppm (MW-36),  and bromide up to 60 ppm (MW-21).

           As for metals, in general,  detection of relatively high
           levels of aluminum up to 16.60 ppm (MW-47),  barium up
           to 6.29 ppm (MW-49),  calcium up to 9,590 ppm (MW-49),
           iron up to 15.4 ppm (MW-47),  manganese up to 880 ppm
           (MW-49),  potassium up to 21.8 ppm (MW-49),  sodium up
           to 1,100 ppm (MW-17),  vanadium up to 0.129 ppm (MW-49),
           and magnesium up to 4,490 ppm (MW-49) were reported.
           Chromium which has been identified as one of the indi-
           cator chemicals by seasonality and statistical analysis,
           show four low level hits: MW-9B (0.007 ppm),  MW-17
           (0.008 ppm), MW-39 (0.006 ppm), and MW-52 (0.006 ppm).
           However,  chromium data for 15 (15 out of 30)  of the
           monitoring wells were reported as unreliable according
           to QA/QC.  Therefore,  due to insufficient data,  adequate
           assessment of chromium can not be conducted.

        *  Monitoring wells MW-7, MW-11, MW-46, MW-48,  MW-49 and
           MW-51 showed some level of concentration for volatile
           organic compounds. Monitoring well MW-7 indicated
           0.0069 ppm of tetrachloroethene. MW-11 indicated
           0.0038 ppm of chloroform, 0.0012 ppm of 1,2-dichloro-
           ethane, 0.0015 ppm of trans-1,2-dichloroethene,  0.0033
           ppm of 1,2-dichloropropane, 0.0093 ppm of 4-methyl-2
           pentanone, 0.0018 ppm of 1,1,1-Trichloroethane,  0.0084
           ppm of TCE and 0.0016 ppm of 1,2-dibromoethane.  MW-46
           indicated 0.0072 ppm of 1,2-dichloroethane,  0.0056 ppm
           of trans-1,2-dichloroethene and 0.0054 ppm of TCE.
           MW-48 indicated 0.0066 ppm of TCE. MW-49 showed 0.0019
           ppm of chloroform and MW-51 indicated 0.11 ppm of
           tetrachloroethene. In addition these monitoring wells
           showed positive estimated values for other volatile
           organic compounds (Table 5).

        *  TOX and chloride which have been identified as indi-
           cator chemicals by seasonality and statistical analysis
           for wells MW-11 (Tox: 0.254 ppm, chloride: 293 ppm)
           and MW-46  (Tox: 0.276 ppm, chloride: 11,300 ppm) fall
           in the same range as the data obtained by IT Corpora-
           tion for these two wells. Table 5 also shows that
           wells MW-46 and MW-11 (respectively) have relatively
           higher concentrations of nitrate nitrogen than other
           wells sampled by HWGWTF.

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                              -66-
        •  Wells MW-7 and MW-49,  for indicator chemicals, show
           relatively high concentrations of chloride (MW-7:
           14,300 ppm,  MW-49:  36,200 ppm).  These concentrations
           also fall within the range of concentrations reported
           for the IT Corporation data analysis. Furthermore,
           both wells show some level of TOX concentration,
           MW-7 (0.119 ppm),  and MW-49 (0.675 ppm).  TOX for
           well MW-46 also falls  within the range of the concen-
           tration level reported by IT data.

         In. brief,  the statistical analysis of the IT Panoche
    ground" water data indicates that monitoring wells in clusters
    1,  3 and 4 are contaminated by the plumes. These wells are:

         '  Cluster 1:   MW-7,  MW-13,  MW-14, MW-17, MW-21, MW-28,
                        MW-45,  MW-49, MW-53,  MW-56,  MW-2B, C6

         0  Cluster 3:   MW-10,  MW-22, MW-25,  MW-27,  MW-29, MW-34,
                        MW-41,  MW-43, MW-46,  MW-48,  MW-51, MW-52

         '  Cluster 4:   MW-1,  MW-26,  MW-31, MW-47, C2

         The analysis of ground water samples taken by the HWGWTF
    confirms the above results. Although, wells in clusters  2 and 5
    are generally "cleaner" than  the wells  in the other clusters,
    the more recent GWTF sampling results (relative to the facility
    data used for statistical  analysis) indicate several of  the
    monitoring wells in these  two clusters  are affected and  that the
    ground water quality has been degraded  relative to the ambient
    ground water. These monitoring wells are: MW-4 (cluster  5),
    MW-11 (cluster 5),  MW-24 (cluster 2), MW-36 (cluster 2),  MW-39
    (cluster 2), MW-42 (cluster 2) and MW-50 (cluster 5). The
    statistical analyses have  also indicated that MW-35 (cluster 2)
    and MW-37 (cluster 5), which are screened in upper unweathered
    bedrock,  show evidence of  chloride contamination.

3.   HWGWTF Surface Water and Soil Sampling  Results

         Six surface water (seep) samples were collected at  the
    vicinity of the site. Two  seeps (#1 and #2) were located in the
    quarry approximately 1800  feet east of  the facility. Seep ?3
    was taken from a tributary northwest of seep #2 approximately
    1000 feet away. Seep #4 was taken roughly 1000 feet downgra-
    dient from MW-22. Seep #5  was collected 250 feet west of MW-4
    in  a tributary, and seep  6 was collected from a tributary north
    of  MW-4,  roughly 1200 feet away.

         In all samples but one (seep #3),  estimated concentration
    levels of acetone were detected.  Relatively elevated levels
    of  chloride,  nitrate nitrogen,  and sulfate were detected in
    almost all the  samples (compare to background ground water
    quality). As for metals, generally elevated levels of aluminum,
    barium,  calcium,  iron, magnesium, manganese,  potassium,  and
    sodium were detected for all  samples.

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                              -67-
         Three soil samples were collected from one location
    approximately 840 feet  east  of  MW-27 in a tributary (For
    locations of seeps & soil samples see Figure 17).  The soil
    samples were analyzed for VOA,  Semi VGA,  TIC-Semi-VOA,  and
    total metals. The assumed background soil sample (MQ0870)
    showed hits for 2-butanone,  benzene,  ethyl benzene,  1,1,1-TCE,
    toluene,  and total xylene.  In general,  all soil samples were
    showing some l.evels of  concentration of 2-butanone,  and toluene.
    As for metals,  most of  the metals analyzed for were detected
    except antimony,  cadmium,  and thallium.

         Almost all the wells,  soils,  and two of the seeps  showed
    greater than zero concentration of methylene chloride.  How-
    ever,  most of concentration  levels were indicated as estimated
    values (J). This  compound was also found in blank samples
    indicated by flag B. Therefore,  methylene chloride,  based  on
    this round of sampling  should not be considered as a chemical
    of concern. Tables 5 through 7,  present the complete analysis
    results of ground water,  surface water and soil samples.


I.   Revisions Regarding Sampling and Analysis Plans

     1.   Groundwater  Sampling and Analysis

              In order to assess fully whether annual seasonal
         variation is occuring,  samples from all the wells  should
         be obtained during the months of February, April,  July,
         October and  December.  The sampling plan should be  revised
         to include the Appendix VIII or IX compounds so that  the
         maximum concentration of hazardous waste constituents at
         the contaminated areas be defined.

              Metals, e.g., As,  Cd,  Cr, Cu, Pb and Zn, should  be
         analyzed by  graphite furnace techniques rather than atomic
         absorption or inductively coupled plasma methods.  This
         will lower the detection limit and allow the introduction
         of match for statistical analysis.

              There are some geochemical processes which control
         the mobility of certain parameters and which should be
         identified in a future analysis. Anaerobic reactions,
         disproportionation reactions (which may result in  one
         product being oxidized, the other reduced), protonation
         reactions (which may affect the PH of the groundwater)
         and chelation reactions (which may increase the solubility
         of cations through complication with organic acids),  are
         reactions which will tend to enhance metal solubility.
         In addition, previous studies (Baedecker and Back, 1979)
         have shown that acetic acid can contribute a significant
         proportion of the alkalinity  (as organic acia anions).
         Therefore, the alkalinity of groundwater at the IT Panoche

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                              -68-
         facility should be included in future statistical compari-
         sons and acetic acid analyzed in future sampling rounds.
         The mean alkalinity (414 ppm) is significantly higher
         than that found in MW-16 (369 ppm). Also,  turbidity for
         all wells should be measured during each sampling phase.

              The levels of concentrations of contaminants
         and hazardous waste constituents should be defined at
         the compliance points,  and at the points of exposures
         (for contaminations outside the facility boundry).
         Appendix VIII or IX compounds will be sampled twice a
         year during dry and wet seasons for 3 years. The water
         levels for all the monitoring wells and piezometers
         should be recorded during every sampling phase,  and the
         depth of wells will be  sounded and recorded.

     2.  Surface Water and Soil  Sampling

              Due to the detection of several inorganic indicators
         and metal constituents  in surface water, and also due
         to the detection of some volatile organics in the soil
         samples, a surface water and soil sampling investigation
         is needed.

J.  Evaluation of the Statistical Methodology Proposed by
    IT Corporation for the Panoche Faciltiy.

         Generally, the use of Analysis of Variance (ANOVA) offered
    by IT Corporation and the interest in obtaining "true" replicate
    samples are reasonable. However,  the details of the ANOVA
    approach are unacceptable because upgradient concentrations are
    not compared with downgradient concentrations and because dif-
    ferences among wells and individual well comparisons are not
    tested as part of the approach.

         The method which IT is  proposing to use does not concider
    contamination that might be  present in the ground.water before
    the ground water flows under the hazardous waste management
    unit (HWMU) of concern.

         IT proposes an ANOVA based method which will indicate
    contamination when there is  a significant well by time inter-
    action. In simple terms this means that the HWMU will trigger
    when there is an indication  that all wells do not behave in the
    same pattern relative to one another over time. The conclusion
    is that using a significant  well by time interaction as the
    triggering threshold can result in both false positive and
    false negative results at a  higher than anticipated rate.

         The more detailed evaluation of the facility's methodology
    is included in attachment D  of this report.

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                             -69-
                          REFERENCES
Data Analysis Report for Technical Support of IT Panoche Facility
  Hazardous Waste Ground Water Task Force Investigation, Camp
  Dresser & McKee,  March 27,  1987.

Beneficial Use Study,  IT Benicia Facility, Benicia,  Solano County,
  California, Leroy Crandall and Associates,  May 13,  1985.

IT Panoche Ground Water Sample Plan, Peter Rubenstein,  USEPA
  Region 9, August 1986.

Project Plan, Hazardous Waste Ground Water Task Force,  IT Panoche
  Facility, Solano County,  California,  Hannibal Joma USEPA
  Region 9, July 1986.

IT Panoche Laboratory Audit Report, Kevin W.  Wong,  USEPA Region 9,
  September 1986.

IT Panoche Ground Water Sampling Audit, Peter Rubenstein, USEPA
  Region 9, December 1986.

EPA Internal Memorandum on "Review of the Statistical Methodology
  Proposed by International Technology Corporation for the
  Panoche, California Hazardous Waste Disposal Site."
From Barnes Johnson to Hannibal Joma, March 27, 1987.

-------
ATTACHMENT A

-------
            ATTACHMENT  A
U.S.. Environmental Protection Agency
              Region 9
  National Ground Water Task Force
             IT PANOCHE

 SAMPLING AND DOCUMENTATION REPORT
          Peter Rubenstein

           February 1987

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                         TABLE OF CONTENTS

                                                           Page

Introduction  	       1
Field Work  Completed
Modifications, and  Clarifications of the
Sample Plan  	
Validity of Data  Based on Field Conditions 	      11




Appendix A:   IT Panoche Ground Water Sample Plan


Appendix B:   Field  Data Organized by Sampling Point
Appendix C;   Documentation of EPA Samples Collected
              at IT Panoche, 8/18/86 - 8/27/86
              : The anocndicVs A, B, and C are not included in this
               report. Tttey ar* available in the E.P.A's fHe.

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                          LIST OF TABLES

Table
         EPA, VERSAR, and State of California
         Personnel Participating in the 8/18 - 8/28
         EPA Sampling Effort at IT Panoche.
         Samples collected each day at IT Panoche,
         sorted by agency, parameter, identifying
         the sample f and the number of sample
         containers per parameter.
         Wells sampled by EPA with less than 3 casing         8
         volumes removed during the purge process.
         Wells sampled by EPA with a time lag of
         greater than 3 hours between purge completion
         and sample collection.
         Wells sampled by EPA which included aliquots
         for o-rganolead analysis.
         Wells sampled by EPA which included aliquots
         for Appendix 8 compounds.

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                           INTRODUCTION
     The ground water sampling component of the Hazardous Waste
Ground Water Task Force investigation at IT Panoche was conducted
August 18-28, 1986.  The major objective of the fieldwork was to
determine if contaminants could be detected in wells on the site.
EPA with its contractor, VERSAR, sampled 30 monitoring wells, 1
piezometer, and 7 seeps.  A total of 53 samples; including Quality
Assurance replicates, performance evaluation,  and blank samples
were collected by the EPA.  The facility accepted an offer for
replicate samples.  The California Regional Water Quality Control
Board (RWQCB) and Department of Health Services (DHS) declined an
offer for replicate samples.

     The field activities were based upon a Sample Plan, dated
August, 1986 and prepared prior to the investigation.  It is
included as Appendix A of this Documentation Report.  Modifica-
tions to the Sample Plan protocols were made in the field when
necessary and were documented in the field notes of the EPA and
VERSAR personnel.

     The EPA ground water samples were .shipped to Compu-Chem
Laboratory for organic analyses, Centec Laboratory for inorganic
analyses, and the CA DHS Hazardous Materials Laboratory in
Berkeley for analyses of the organolead and radionuclide para-
meters.  The soil samples were shipped to California Analytical
Laboratory for inorganic analyses and Western Research Institue
for organic analyses.

     The analytical results for the samples collected will not be
included in this report.

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                       FIELD WORK COMPLETED
     A sampling audit was conducted in May, 1986 as part of the
overall Task Force Investigation.  At that time an effort was
made to identify the location of the wells and to determine what
special purge or sampling equipment might be necessary to complete
the EPA sampling effort in August.  Hannibal Joma, Donn Zuroski,
Randall Breeden, and Peter Rubenstein of EPA were escorted by the
IT Environmental Monitoring Team during this initial investigation.

     The EPA and VERSAR sampling teams arrived on site on August
18, 1986, to begin the field investigation.  Sampling was conducted
according to the methods and protocols specified in the EPA
Region 9 "IT Panoche Ground Water Sample Plan", dated August, 1986,
and included as Appendix A to this report.

     Personnel from the EPA and agencies of the State of California
were also on site at various times during the samapling event to
assist and observe the field investigation.  Table 1 identifies
all of the EPA,- VERSAR, and State of California personnel who
participated in this field effort.

     On the first day in the field, August 18, the staging area
and equipment were set up and initial measurements of depth to
water were taken.  Interface probes were used to determine if any
immiscible liquids were present as the wells were sounded.

     Purge and Sampling of the wells began on August 18 and
all EPA fieldwork at the site was concluded on August 28.

     IT Panoche assigned staff to escort the Task Force, unlock
the wells, and accompany the EPA and VERSAR personnel while at the
wellhead.  After sampling was completed at each well IT personnel
relocked each well.  As each sample set was packaged for shipment
IT personnel received custody of the appropriate replicates.

     Table 2 summarizes the samples collected on a day by day
basis and sorted by agency.  The samples are identified by well
location, sample number, and type of QA/QC sample when applicable.
Total depth, depth to water, the purge/sample sequence, purge and
sampling method, field parameters, and sample numbers are presented
in Appendix B of this documentation report.
                               -2-

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Table 1:  EPA, VERSAR, and State of California Personnel
          Participating in the 8/18 - 8/28 EPA Sampling Effort
          at IT Panoche.
AGENCY
NAME
DATES ON SITE
EPA
Hannibal Joma
Peter- 'Rubenstein
Donn Zuroski
Dan Sullivan
Kevin Wong
Ted Bucklin
Anthony Montrone
Peter Usbee
Judy Cook
Daniel Horgan
Mitch Kaplan
Kathleen Shimroin
Frances Schultz
Barbara Walsh
William Weis
 8/18 •
 8/18 •
 8/18 •
 8/18 •
 8/27
 8/18,
 8/18
 8/18
 8/22
 8/22
 8/22
 8/22
 8/22
 8/22
 8/22
8/27
8/28
8/27
8/27

8/28
VERSAR
Darcy Higgins
Dan Campbell
Alicia Freitas
John Hatcher
Mark McElroy
Don Paquette
Randal Vanhoozer
 8/18
 8/18
 8/18
 8/18
 8/18
 8/18
 8/18
8/27
8/27
8/27
8/27
8/27
8/27
8/27
CA DHS
Ed Leivas
Patti Barni
 8/18
 8/18
SWRCB
Dennis Parfit
 8/25
                               -3-

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     VERSAR personnel did all of the EPA sample collection and
handling to insure that the actual procedures were consistent for
each sample.  VERSAR provided all of the sampling equipment,
identified in an appendix to the Sample Plan (see Appendix A).
The equipment was decontaminated prior to shipment to the site
according to the protocols established in the "Revised Draft
Protocol For Ground-Water Inspections At Hazardous Waste Treatment,
Storage And Disposal Facilities" dated April 1986.

     Immediately after filling the containers at a sampling point
VERSAR personnel would return to the staging area where they
measured turbidity and filtered and preserved those samples as
required.  All samples were kept on ice from the moment of
collection.

     The EPA and DHS samples/ identified in Table 2, were shipped
on the day of or day following collection.  The samples were
shipped by Federal Express with next day delivery to the
laboratories.

     The EPA samples were sent to the EPA Contract Lab Program
(CLP) and DHS laboratories for analysis.  Centec Laboratory in
the CLP conducted the inorganic analytical procedures on the
ground water samples; total metals, phenols, cyanides, NH3, NC>3,
804, Cl, purgeable organic carbons (POC), purgeable organic
halides (POX), total organic carbons (TOO, and total organic
halides Cr,OX).-  Compu-Chem laboratory in the CLP conducted all of
the organic analytical procedures on the water samples; Volatile
organic analyses (VOAs), extractable organic compounds, pesticides,
herbicides, and dioxin.  California Analytical Laboratory in the
CLP conducted the inorganic analyses on the seep and soil samples.
Western Research Institute in the CLP conducted the organic
analyses on the seep and soil samples.  The DHS laboratories in
Berkeley conducted the analyses for the organolead and radionucliide
parameters in the ground water samples.  Custody of the IT replicate
samples was tansferred to the IT on the day of or the day following
collection.

     Sample Traffic Reports, Chain of Custody Forms, Receipts for
Samples, and photographs were used as part of the documentation
of the EPA sampling effort.  Appendix D includes copies of the
all of the documentation paperwork.  These forms are arranged in
chronological order.  The photographs are on file EPA Region 9.
                               -7-

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       MODIFICATIONS AND CLARIFICATIONS TO THE SAMPLE PLAN


     The procedures presented in the Sample Plan, Appendix A,
were modified in the field at some sampling points.  These modi-
fications are identified below by appropriate section of the
Sample Plan.


Section 1

     Piezometer SB-3 was added to the wells to be sampled because
of a notation in the drilling log that grease had been found in
the soils during the boring of the piezometer.

     Replicate samples were not collected from any wells for
analysis by California state agencies.


Section 2.1

     A safety survey was not conducted at a number of the wells
as they were initially inspected.  There was only one set of
survey equipment and two teams.  The second team did the initial
inspections and depth to water measurements while wearing
appropriate safety gear.  Later, prior to beginning the purge
process, the wells were monitored with the appropriate safety
equipment and a decision made whether the Investigation teams
could downgrade to Level D safety protection.  A determination
was made that Level D was appropriate at each well.


Section 3.2

     The wells identified below in Table 3 did not have 3 casing
volumes of water purged from them prior to sampling.  Asterisks
indicate those wells which were purged dry.


     Table 3:  Wells sampled by EPA with less than 3 casing
               volumes removed during the purge process.


               2B             22*            47*
               7*             29*            48*
               8*             41*            49
               10*            42*            50*
               14*            43*            51
               16*            46*            SB3*
                               -8-

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     The time lag between the completion of the well purge and the
collection the of volatile samples from the wells identified in
Table 4 was greater than 3 hours.


     Table 4:  Wells sampled by EPA with a time lag of greater
               than 3 hours between purge completion and sample
               collection.
               7
               14
               41
43
48
49
50
51
SB3
     All purge water was put into drums for later disposal by the
site operators at IT Panoche.
Section 4

     Many of the wells at the site did not recover as expected.
a result full parameter sets could not be collected from them.
The wells from which organolead aliquots were collected are
identified in Table 5.  The wells from which Appendix 8 aliquots
were collected are identified in Table 6.
                                   AS
     Table 5:  Wells sampled by EPA which included aliquots
               for organolead analysis.
               1
               2B
               7
               11
39
41
42
43
46
48
49
52
     Table 6:  Wells sampled by EPA which included aliquots
               for Appendix 8 compounds.
               1
               4
               7
11
16
17
31
46
49
Section 4.1

     Replicate samples were not collected for state agencies
                               -9-

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Section 4.2

     The field parameters of pH, temperature, and electrical
conductivity (EC) were not collected in quadruplicate at the
start and upon completion of sampling at wells 20, 47, 48, and 51
due to a lack of water.

     The pH at well 9B was estimated using pH paper due to
equipment failure.  Turbidity was not measured at wells 42 and 50


Section 4.4
     The pH at all 7 of the seeps was estimated using pH paper.


Section 7.0

     The only field equipment used for ground water sampling
which needed to be decontaminated on site was the water level
indicator (sounder) and the PTFE-coated stainless steel cable
used with the bailers.  As the lines were drawn out of the well
they were wiped with a Kimwipe* soaked with Hexane followed with
a Kimwipe* soaked with distilled water.  The tip of the sounder
was rinsed with Hexane and distilled water at the completion of the
wipe.  The cable and the sounders were stored in plastic bags
between sample* points.

     Decontamination of the field equipment used in the seep and
soil sampling followed the proceedures in the "Revised Draft
Protocol For Ground-Water Inspections At Hazardous Waste Treatment,
Storage And Disposal Facilities."


Special Problems


Well 9B

     VERSAR'a PTFE bailer came untied and fell to the bottom of
the well.  The bottom section of the bailer with the check ball
broke on impact and separated from the rest of the bailer.  All
components of the bailer were retrieved by VERSAR using fishing
hooks and nylon fishing line.


Well SB-3

     VERSAR1s PTFE bailer came untied and fell to the bottom of
the well.  The entire bailer was retrieved as one unit by VERSAR
using fishing hooks and nylon fishing line.
                               -10-

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            VALIDITY OF DATA BASED ON FIELD CONDITIONS
     The volatile organics data from samples collected from the
wells identified in Table 4 could be biased in a negative
direction due to the time elapsed between the completion of the
purge and the initiation of the sample collection.
                               -11-

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ATTACHMENT B

-------
             ATTACHMENT B
 U.S. Environmental Protection Agency
               Region 9
Hazardous Waste Ground Water Task Force
              IT PANOCHE

     GROUND WATER SAMPLING AUDIT
           Peter Rubenstein

            December, 1986

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                        TABLE OP CONTENTS


                                                           Page

Introduction	          1

Review of IT Panoche's
May, 1986 Sampling Effort	          2
Review of IT Panoche's
Sampling and Analysis Plan	         12

Actual Nay 1986 Sampling vs.
the Sample and Analysis Plan Protocols 	         18

Review of ERG's and Engineering Science's
Documentation	         18

Recommendations 	•	         19
Appendix 1:  Photographs
              NOTE: The appendix 1 is not included in this  report
                    It is available in the E.P.A's file.

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                           INTRODUCTION
     A Sampling Audit was conducted at the International
Technology Corporation Panoche Facility (IT Panoche) by the EPA
from May 1 through May 15.  Samples were collected by the IT
Environmental Monitoring Team (EMT) and analyzed by the IT labo-
ratory in Pittsburg.r PA, the ERG Laboratory in Emeryville, CA and
the Engineering Science Laboratory in Berkeley, CA.  Visits were
made to ERG and Engineering Science as part of the sampling audit
process to review the sample handling procedures and documenta-
tion provided by the laboratory.

     The sampling audit is divided into five major sections:  A
descriptive review of IT Panoche1s May 1986 sampling effort; a
review of IT Panoche's sampling and analysis plan; a comparison
of the actual May 1986 sampling effort vs. the sampling and
analysis plan protocols; a review of the ERG and Engineering
Science documentation; and recommended changes which should be
made to the sample and analysis plan and the actual protocols
being followed.

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                               -2-
              IT PANOCHE'S MAY, 1986 SAMPLING EFFORT


Overview of the May 1986 Sampling Effort

      Forty-five samples, plus 1 duplicate and 2 blanks
were collected by IT over a 10 day period.  EPA representatives
observed all of the initial soundings and the the purge and
sampling at 14 monitoring wells.  The purging of the wells was
initiated by IT from 1 to  2 days prior to sampling.  The moni-
toring wells' were purged with submersible centrifugal pumps or
bailers and sampled with bladder pumps or bailers.

     The sample containers for coliform and for hexavalent chro-
mium, Cr (VI), were provided by ERG (Engineering Science provided
the autoclaved coliform containers to ERG).  All of the other
containers were provided by the IT Pittsburg laboratory.  Preser-
vatives were added to the empty containers by the laboratories
before sending them to the facility.

     Depth to water (DW) was measured at all wells on May 1 and 2
prior to initiation of the purge sequence.  The centrigual pumps
and bailers used to purge the wells were decontaminated before
their use at the sampler's staging area on site.

     After all of the sample containers were filled the field
water quality parameters were measured*.  Temperature, specific
conductivity, and pH were measured in quadruplicate at each
sample point.  Depth to water was measured at each point at the
completion of sampling.  The sample containers were put into
coolers under ice and stored.  The coliform and Cr (VI) samples
were hand carried to ERG on the day of sampling.  The other
samples were repackaged for shipping the same day or the
following day by Federal Express.

     This part of the audit report is divided into two major
sections;  field documentation and sample collection.


FIELD DOCUMENTATION

Sample Labels

     The sample containers were pre-labled by the laboratory as
to project name, project number, parameters, preservative, and
the filtering status.  The field personnel filled in the sample
location, boring/well number, collectors  name, and date (see
Figure 1).  The parameters which had more than 1 bottle were

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                               -3-
TOC/TOX, collected in quadruplicate, extractable organics col-
lected in 2 bottles, anions and cations collected in 2 bottles,
and the The "Bottle 	 of 	" section of the label was never
filled in.
Figure 1:
Project Name
Sample Location
Boring/ Well No._
Collector's Name
Sample Type: —
^^^M
Parameters
RftttU

IT CORPORATION
Prnjoct No


nat«
	 Ground Water 	 Surface Water
	 Soil 	 Sludge/Waste
	 	 _ Pr^flfwativa
nf 	 Fi|t^rq4 Nonfilterffd

Sample Labels for parameters being analyzed by IT
Pittsburg
Field Logs

     The IT EMT recorded initial water levels on an "IT Benicia
Facility Water Levels" worksheet (see Figure 2).  Other field
notes were kept on a "Sampling Information Form" (see Figure 3).
The completed forms for the Nay 1986 sampling event, document
ITP-007K, are with the site investigation files in the Regional
Office.

     The recorded time for the DTK measurements, purge sequence,
sample collection, and field water quality data collection was
not identified as to time initiated or time completed.  The
calculated purge volume for each well was recorded on the upper
left corner of the approprite Sampling Information Form.

     The formula and coefficients used to determine the purge
volume for each well are not given on the form nor in the Sample
and Analysis Plan.  The depth to bottom values for calculating
the purge volume are not included on the data sheet.

     A separate Sampling Information Form was not filled out for
the blanks or duplicate samples.  However, the data sheets for
the wells at which they were collected have notations indenti-
fying them as the point of collection for that QC sample.

Chain of Custody/Sample Analysis Request

     IT maintained a "Sample Identification/Field Chain of
Custody Record" for each sample set collected at a sample point
(see Figures 4 and 5).  The sampling point was identified by well
number and type of QC sample.  The 8 digit Field ID # identified

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                                 -4-

                       IT BENICIA FACILITY WATER LEVELS
                            Job Number:
     WELL     DATE    TIKE     DEPTH' *"   ELEVATION     BY     COMMENTS

    MW-

    MW-

    MW-

    MW-

    MW-

    MH

    MW-

    MW-

    MW-

    MW-

    MW-

    MW-

    MW-

    MW-

    MW-

    MW-

    MW-

    MW-

    MH-

    MW-

    MW-

    MW-

    MW-

    MW-

    MW-

    MW-
     (1)Measured from index mark at top of PVC casing.

Figure  2:   Data  Sheet used by IT  for recording waterlevels  in
            the monitoring  wells prior to purge.

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                                      -5-
                                     FIGURC £-2
                              SAMPLING INFORMATION FORM

   sm  _	** "°'
   WELL  	,	
   STATIC HATER LEVEL  Depth*A> 	 Date and Time	By
   EVACUATION
        Set  Pump I     •   ._            Oate and Time 	
                       Volume (gal)           Oate and Time    ty       Appearance
        Purge  1       __________         	  	   	
        Purge  2       	         ______________  	   	
        Purge  3       	         _____________  	   	
        Pull  Pump:  Oate  and Time 	    By
   SAMPLING
        Set Pump I	             Oate and Time 	
   FIELD WATER QUALITY DATA
        Meter type 	    Serial * 	
        Appearance 	           Odor	
                pH                                Specific Conductance
                     T1«e            Hcter Reading      Units      	
           Temperature *C
   WATER LEVEL    Depth*1)  	    Oate and TU
   COMMENTS
               from  index nark  at  top of PVC casing.

Figure  3:   Data  sheet  used  tor  record  purge  and  sample  collection
              information.

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                                          -6-
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                               -8-
the date awd time of collection (month » first 2 digits, day «
second 2 digits, time * last four digits).

     The sampling crew made sure to sign over custody of the
samples from individual to individual as the work progressed,
including the individual who packaged the samples for shipment.
Physical custody of the samples was maintained in an adequate
manner.

     Separate forms were filled out for the QC blanks and duplica-
ates.  The wells at which these samples were collected are
identified on the forms but the type of QC sample is not.
FIELD WORK


Purge

     A  Water Level Indicator* was used to measure depth to water
at all of the wells (see Photo 1).  The sounder calibration was
not checked as the equipment had been purchased just prior to the
sampling event.  The depth to water was measured at all wells on.
Hay 1 and 2.  The EMT used those measurements in conjunction with
the depth to bottom of the well design specifications to calcu-
late the casing volumes to be purged from each well.  Depth to
bottom was not measured during the sampling event.

     The wells were purged with submersible centrifugal pumps or
bailers (see Photos 2 and 3).  The purge volume at each well was
measured using a 5 gallon bucket.  The purge water was placed
into 55 or 30 gallon drums for later disposal by IT Panoche.

     The EMT purged 5 casing volumes whenever possible to comply
with State of California Katz Act.  Host of the wells had to be
purged in 2 or more episodes to remove the desired volume.


Sample Collection, Handling, and Preservation

     All of the samples were collected using freshly decontami-
nated ISCO bladder pumps or teflon bailers (see Photo 4).  The
cable which was used to raise and lower the sampling pumps was
not disposed of after sampling.  Instead, it was decontaminated
with the pump or bailer and reused.

     The bladder pumps were set just above the bottom of the
well, in the screened interval.  The samples collected by bailer
were always collected from just below the water surface which,
for some wells, coincided with the screened interval.

     The first 2 complete pump volumes were used to rinse the
bladder pumps prior to sampling.  The first three bailer trips

-------
                               -9-
were used to rinse the bailers.  The samples were then collected
with the general mineral aliquot collected first and the various
volatile organic aliquots collected last.  The other sample
containers were not filled according to any predetermined
sequence.  Table 1 identifies the sample aliquots and special
handling followed for each parameter.

     The sample bottles were filled over a drum or bucket to
prevent potentially contaminated groundwater from being poured to
ground A perforated drum cover was used to support the sample
containers while they were being filled, generally over the drum
with the purge water (see Photos 5 and 6).  There is a potential
for contamination of the TOX sample when samples are collected
over water containing contaminants.  Occasionally empty and
filled bottles were set on the drum cover in spilled water and
were not adequately wiped off prior to packaging.

     Extractable organic samples were occasionally collected in
clear bottles.

     The TOC/TOX sample, which was collected in one container was
preserved with ^28203.  The two parameters should be collected
in separate aliquots, placed in separate containers, and preser-
ved appropriately.

     The metals samples were collected through an inline filter
utilized for that parameter only (see Photo 6).  The filter
holders were decontaminated prior to use and a fresh filter was
put in place for each sample.
             was used as a preservative for all of the organic
parameters.  Its use is only appropriate when the sample contains
residual chlorine.  None of the samples collected from IT Impe-
rial monitoring wells should contain residual chlorine.

     The TOX sample should be the first parameter collected, not
the last, to minimize aeration effects.

     All of the samples were cooled with blue ice immediately
after they were collected.  The amount of blue ice used was not
always sufficient to keep the temperature of the samples down.


Field Parameters

     After all containers were filled at a well, a Martek Mark X*
was used downhole to measure temperature, specific conductance,
and pH (see Photo 7).  The parameters were measured in quad-
ruplicate and recorded on the field data sheets.  One direct
reading of electrical conductivity, normalized to 25° C, was also
measured and recorded on the data sheets.

-------
                                      -10-
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                               -11-


     All of-the probes were calibrated daily prior to sample
collection  according to the protocols given in the Martek  ins-
truction manual*  The pH probe was calibrated with buffer  solu-
tions of pH 4 and 7.  The sensor for conductivity was calibrated
with a 6680 umho KC1 solution  The temperature sensor was  checked
against a lab thermometer.  The calibration information was
recorded in a calibration log kept at the equipment storage area.

Packaging

     The coliform and Cr (VI) containers were set on ice and hand
carried to E-RG on the day of sample collection.  The other sample
containers were iced as they were collected and repackaged in
vermiculite and re-iced on the day of shipment, the day of or the
day following sample collection.  The samples were kept together
by and well and were accompanied by the Sample Identification/
Field Chain of Custody Record.

Decontamination

     The EMT decontaminated their sampling equipment at their
staging area on the Panoche site (see Photos 8 - 10).  The
plywood wash area was inadequate because the wood platform used
as a work area could never be properly decontaminated, even with
steam cleaning, and the water ran off into a roadside ditch which
empties into a runoff collection pond.

     Subsequent to the sample audit, IT Panoche has constructed a
concrete wash/decontamination station for the EMT which will
enable them to clean their equipment while minimizing the poten-
tial for cross contamination of equipment as well as minimize the
movement across the site of contaminants in the wash and rinse
water.

     A number of inadequacies in the IT decontamination process
were identified during the audit.  Braided cables and ropes were
used for raising and lowering the bladder and submersible pumps.
The braids can not be completely cleaned.  The exterior of the
hoses and cables for the pumps were steam cleaned while they were
coiled on spools.  This prevents the inner coils from being
adequately decontaminated.  The final distilled water rinse of
the sampling equipment was poured from a 5 gallon water bottle.
It was not directed by a nozzle or hose.  This can lead to
inadequate rinsing of the equipment, especially to coiled  lines
and hoses.

     Fresh lengths of silicon tubing were cut and decontaminated
at the wash area for use in the ISCO pumps (see Photo 11).  Crude
measurement of the silicon tube and rough knife cuts led to
occasional leaks in the bladder pumps in the field.

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                              -12-
               REVIEW OF SAMPLING AND ANALYSIS PLAN
     The Groundwater Sampling and Analysis Plan IT Corporation
Benicia Facility (dated 1/17/85), Attachment 4 to the
IT Panoche RCRA Part B application, was identified by the IT
samplers as their Sampling Plan.

     The EPA review of the sampling and analysis plan follows
the organization of the plan itself.

Cleaning (Section 3.0, page 2)

     This decontamination section does not include a discussion
on the decontamination of cables and lines used to haul the pumps
and bailers.  There should also be discussion on the decontamina-
tion of the interior of the bladder pumps and the water lines.

Transportation and Storage (Section 3.2, page 3)

     The section discusses newly cleaned PVC cases for transpor-
ting and storing pumps.  There should be a discussion in the
section above on how the cases will be cleaned.

Evacuation of Well (Section 4.0, page 3)

     This section mentions redevelopment of the wells if the
purged water is noted to be "highly turbid".  More discussion is
required on how the determination will be made that the water is
so highly turbid that redevelopment of the well is necessary.
The "standard well development techniques" which will be used
need elaboration.

     The use of a "gator" truck for well development needs to
be discussed more fully.

     Eighteen hours is too great a time lag between purge and
sample collection.  The EPA recommended maximum time lag is 3
hours.  The pump used to collect the samples should be the same
used to evacuate at least the last casing volume from the well.

     The purge, of at least the last casing volume should be at
a rate of flow which will match the well's recharge rate if it
is practical.

     Volatile organics should be collected as  soon as possible
after the completion of the purge.

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                              -13-


Monitorinq Well Water-Level Measurement (Section 5.1, page 4)


     It will take more than 2 hours to take all of the measure-
ments at the site.

     Well depth should be measured in addition to water level
prior to the purge.  This is dicussed in Appendix C but not in
this section.

     A second water level measurement should be taken at imme-
diately prior to sampling.  The information gained from water
level measurements taken after sampling is not as useful.
Appendix C discusses the collection of water level measurements
prior to sampling.  This conflicts with Appendix C.

     The calibration of the "calibrated electric probe" should
be checked on a routine basis.  The calibration schedule should
be identified in the Sampling and Analysis Plan.  A calibration
log should be kept with the equipment or in the field notes for
the sampling event.

     The use of "clean water" for the triple rinse of the probe
is not specific.  The water type should be identified, i.e.,
distilled, deionized,  or HPLC water.


Pump and Bailer Setting (Section 5.2, page 5-8)

     The samples should be collected from the screened interval
regardless of whether a bailer or a pump is used.

     A teflon coated stainless steel cable can be cleaned between
wells.  Other materials should be discarded between sampling
points to prevent cross-contamination.

     Appendix B does not include a Sampling Information Form.  It
is given on page 6.  There is no place on the form for electrical
conductivity normalized to 25* C.


Filling Sample Containers (Section 5.3, page 8-10)

     Organic samples (volatiles, extractables, phenols, TOC, and
TOX) should be collected first, before major anions and cations,
especially when there might not be enough water to collect the
full parameter suite.

     The rationale for when to rinse and when not to rinse sample
containers should be presented, either as an overall statement or
on a parameter by parameter basis.

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                               -14-
     This section should include a reference to Table A-l rela-
tive to sample containers and preservation techniques.

     The rationale for when to overfill, fill to the top, or
leave head space in the sample containers should be presented in
an overall statement or on a parameter by parameter basis.  The
phrases "completely filled" or "filled completely" are not
precise enough.  The Plan should state when containers will be
filled with no headspace, to the brim, or to the shoulder.

     The rationale for when samples should be acidified in the
field should-be presented in an overall statement or on a para-
meter by parameter basis.

     Phenols are listed in Table A-2.  They should also be iden-
tified in this section and in Table A-l.

     The only parameters identified in Section 5 which have
containers prepared with preservatives are cyanide, TOC/TOX and
sulfide.  This is not consistent with Table A-l which identifies
preservatives for sulfide, trace metals, cyanide, TOC/TOX,
extractable organics, radium, gross alpha and gross beta,
nitrates, and coliform.

     Based on the discussion in Section 4.0 turbidity is expected
to be a problem at some of the wells.  It should be a parameter
which is measured in the field or at the sampling team's staging
area.


Trace Metals (Section 5.3.2, page 9)

     These should be identified as dissolved (or filtered) trace
metals.  The Plan should identify whether the samples will be
filtered in-line or with a vacuum.

     The Plan notes that samples might have to filtered in the
IT Martinez laboratory if the turbidity is too great.  The plan
should clarify whether or not the samples will be acidified prior
to filtration.  If not, the Plan should specify what the interme-
diate sample container will be.


Non-Volatile Organics (Section 5.3.4, page 9)

     The samples should be protected from sun light.  Use of
amber bottles or aluminum foil around the bottles is recommended.
Cyanide (Section 5.3.6, page 9)

     Table A-2 includes a discussion on the use of lead acetate
paper to determine if cadmium nitrate powder is needed to remove

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                              -15-


sulfide from the water.  This should be discussed in greater
detail in the text.


Total Organic Carbon/Total Organic Halogens  (Section 5.3.7,
page 9)

     This section implies that TOC and TOX will be collected in
separate containers.  Table A-l indicates that they will combined
in one container.  They should be kept separate.  TOX should be
placed in an amber bottle without preservatives and eliminating
head space. , TOC should be preserved with HC1 or
Field Water Quality Measurements (Section 6.0, page 10)

     The plan should detail how the data will be collected when
downhole measurement is not possible.


Collection of Replicate Samples for Indicator Parameters  (Section
7.0 .page 10-11)

     This section of the Plan implies that TOC and TOX will be
collected in separate containers.  Table A-l indicates that they
will be in the same container.  They should be in separate con-  .
tainers (see comments for Section 5.3.7)

     The plan should identify the frequency at which the pH and
conductivity meter will be calibrated.  A calibration log should
be kept with the equipment or in the field notes for the sampling
event.
Collection of Duplicate and Blank Samples (Section 8.0, page 11)

     The use of travel blanks when volatile organic samples are
shipped is suggested.


Duplicate Samples (Section 8.1, page 11)

     The use of a "unique identification number" implies that the
duplicate samples will be "blind" to the laboratory.  This should
be stated explicitly one way or the other.


Field Methods Blank (Section 8.3 page 11)

     The plan discusses the collection of a field methods blank
when the regular groundwater samples are only collected with a
submersible bladder pump.  There is no discussion on the collec-
tion of the blank when regular sampling utilizes a teflon bailer.

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                               -16-
Sample Identification  (Section 9.0, page 12)

     Duplicates and blanks will not be blind samples according to
this numbering system.  This may lead to QA/QC difficulties.


Sample Preservation (Section 10.0, page 13)

     Each sample container should be placed in the ice chests as
soon as it is filled and not after the whole set as been filled.
This should be more explicit in the Plan.


Analytical Procedures (Section 12.0, page 14)

     A regular schedule for calibration of the field instruments
should be identified in the Plan.  This includes the probes used
for collecting water level measurements.


                            APPENDIX A

Table A-l

     Trace metal samples should be acidified after filtration.
The acid used should be stated.

     TOC and TOX samples have differing preservation requirements
and should not be placed in the same container with the same
preservative.  TOX should be placed in an amber bottle without
preservatives and without head space.  TOC should be preserved
with HC1 or H2SO4.

     Extractable organics should be protected from sunlight.  Use
of amber bottles or aluminum foil around the bottles is recom-
mended.  Sodium Thiosulfate is not necessary as a preservative
with these samples.  The Plan does not identify who adds preser-
vatives to this parameter.

     Phenols are listed in Table A-2.  They should also be listed
in Table A-l and Section 5.3.
                            APPENDIX B
Sample Identification (Section 1.0, page B-l)

     There is no place on the form for specifying the preserva-
tion method utilized for eachparameter.

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                               -17-
Chain-of-Custody (Section 3.0, page B-3)

     the use of custody seals or evidence tape to demonstrate
that the integrity of the samples has not been compromised should
be discussed in this section.
                            APPENDIX C


     The material in this appendix either duplicates material
already included in the text or contradicts material in the text.


Section 1, Page C-l

     This section calls for water level measurements prior to
sampling.  Section 5.1 discusses the collection of water level
measurements after sampling.  Appendix C conflicts with Section
5.1 of the text.

     A stinger and vacuum truck should not be used to purge a
well.
Section 2, page C-l

     The protocol for manual purging calls for purging until EC
has stabilized.  The protocol for pump purging calls for the
purging of three casing volumes or until the well is completely
evacuated.  The sample plan should discuss why there are sepa-
rate criteria for the two methods.

Section 3, pages C-l to C-2

     The possibility of contaminants entering the well due to the
use of a stinger for purging is great enough that it should not
be considered as an acceptable purge method.

Section 4, page C-2

     This section duplicates material already presented in the
Plan and is unnecessary.

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                               -18-


             COMPARISON OP THE MAY 1986 SAMPLING VS.
                   THE SAMPLE AND ANALYSIS PLAN


     The IT Environmental Monitoring Team follwed the Sampling
and Analysis Plan during the entire sampling effort with no
significant discrepencies noted.
     REVIEW OF ERG'S AND ENGINEERING SCIENCE'S DOCUMENTATION


     ERG, Emeryville is responsible for the analysis of Cr VI and
coliforms.  Both parameters have short holding times.  ERG has
contracted out the coliform work to Engineering Science in
Berkeley.  As part of the sample audit the EPA visited ERG and
Engineering Science and reviewed the sample tracking and documen-
tation procedures used there.

     Both the coliform and the Cr VI samples come to ERG with
notations as to the site and well number.  The coliform samples
are renumbered with using an ERG numbering system and sent to
Engineering Science as blind samples.


Chain of Custody

     Custody of all of the samples, which arrived at ERG, were
transferred with appropriate signatures on IT's chain of custody
records.  Chain of custody was not documented for the coliform
samples which were then transfered to Engineering Sciences.


Hold Times
                                                                  i
     Hexavalent chromium has a 24 hour hold time.  ERG begins its
analysis immediately upon receipt of the sample which prevents
the hold time from being exceeded.

     Coliforms have a 6 hour hold time.  Engineering Science sets
the samples in the incubator within shortly after receipt from
ERG.  Engineering Science is not told when the sample was collec-
ted, does not always record when the sample was received nor when
it is placed into the incubator.  The method hold times might
easily be exceeded by the time the coliform samples are placed
into the incubators.  It would be difficult to determine based on
the records kept by Engineering Science.

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                               -19-
                    SUMMARY OF RECOMMENDATIONS
Field notes should identify all values used to calculate purge
volumes.

The electrical water level sounders, should be calibrated on a
regular basis.

Well depth should be measured prior to purge on all wells where
there may be a silting problem.

Braided ropes and cables used to raise and lower the pumps and
bailers can not be properly decontaminated between wells.  They
should be used one time only or replaced with a cable which can
be adequately cleaned.

The silicon tubing used in the bladder pumps should be more
carefully cut and placed on the pumps.

Samples should be collected at the screened interval whether the
sample is collected with a pump or a bailer.

The volatile parameters should be collected as soon as possible
after the completion of the purge to minimize the loss due to
volatilization.

Extractable organic samples should be collected in amber bottles
to minimize the effects of sunlight.

TOC and TOX samples should be collected in separate containers.

N32$203 should not be used as a preservative in any of the
organic samples collected at this site.

The sample and analysis plan needs to be revised and updated.

The laboratories doing coliform and Cr+6 analyses for IT Panoche
should document date and time when the analyses are initiated
and completed.  Chain-of-custody should be documented for the
conform which are transferred from one lab to another.

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ATTACHMENT C

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            ATTACHMENT C
U.S.,Environmental Protection Agency
              Region 9
  National Ground Water Task Force
             IT PANOCHE

      LABORATORY AUDIT  REPORT
           Kevin W. Wong

          September, 1986

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                  PART I






OFF-SITE GROUNDWATER  ANALYSES LABORATORY




         IT ANALYTICAL SERVICES

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INTRODUCTION

    On May 12-13, 1986, a laboratory audit was conducted at IT
Analytical Services Laboratory (ITAS) in Export, PA, in support
of the Hazardous Waste Ground Water Task Force site investigation
at IT Panoche.  The ITAS Lab is a commercial laboratory owned
and operated by the IT Corporation.  As such, this laboratory
performs the majority of ground water analyses required of all of
IT RCRA sites in the nation.  In particular, essentially all of
IT Panoche'.s groundwater samples are submitted to the ITAS Lab
for inorganic (except chromium +6 and coliform)  and organic
chemistry analyses.

   The major objectives of this audit were twofold: 1)  To assess
the ITAS Laboratory's capabilities to conduct ground water
analyses, as well as their general ability to produce data of
acceptable quality, and 2) to investigate and assess the quality
of actual groundwater data generated specifically for the IT
Panoche site.

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II.  OVERVIEW

     The laboratory audit was conducted in three phases, as
discussed below.

     The initial objective of this audit was to conduct an infor-
mation gathering session with laboratory management, at which
time the definitive purpose of the audit was explained.  As an
integral aspect of the audit process, the laboratory director was
requested to describe the general organizational structure and
primary operations of the laboratory, including such factors as
the history of the laboratory, their overall analytical capabi-
lities, the credentials of key laboratory personnel, the descrip-
tions of analytical instrumentation, the extent of the labora-
tory's quality assurance/quality control (QA/QC) program, and the
laboratory's relationship with the IT Panoche Facility.  To
substantiate the accuracy of the verbal information provided, all
relevant documentation describing these processes were requested,
and subsequently acquired.  These documents are provided as
attachments to this report.

     The next phase of the audit consisted of a comprehensive
walkthrough of the laboratory.  At this stage, a number of inves-
tigatory steps were followed, including such activities as 1)
directing specific questions on various aspects of each organiza-
tion component of the laboratory to section supervisors and key
analysts, 2) recording visual observations of operational analy-
tical  instrumentation, 3) reviewing laboratory bench and QA/QC
records, 4) noting general impressions of routine laboratory
operations, and 5) conducting follow-up interviews with key staff
and managers in order to acquire answers to specific areas requi-
ring clarification.

    pnce all observations had been recorded and notes  compiled,
and all requested documents received and reviewed, an  exit
debriefing with management was conducted to discuss and summarize
all significant areas of concern.  The primary intent  of of this

exit interview was to identify those areas determined  to be most
in need of  improvement or upgrading, and to provide constructive
suggestions for rectifying deficiencies.

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DEFICIENCIES

QUALITY ASSURANCE PROGRAM

     The quality assurance (QA) program in place at the  time of
this audit was in general, adequate.  There were, however, speci-
fic areas which were determined to be marginally acceptable.
These areas are summarized as noted below.

Documentation

    There exists a noticable inconsistency in the manner  in which
quality control data is monitored and maintained.  This was
reflected by the lack of documentation regarding quality  control
charts, temperature records and standard curves.  Some of these
deficiencies may become self-correcting once the laboratory
establishes a centralized computer system.  However, until such
time when this system is established and implemented, it  is
recommended that the laboratory improve its method of QA  record-
keeping and data documentation.  It is likely that an improvement
in the mechanics and process will result in an easier transition
to a computerized system.

QC Acceptance Limits

     The laboratory has not formally established QC acceptance
limits for surrogate/matrix spike recoveries or duplicate sample
analyses.  At the time of this audit, the laboratory had  only
been utilizing those limits established for EPA QC samples, or
had generally been attempting to use those limits established in
EPA's Contract Laboratory Program (CLP).  Although the use of
these EPA limits is acceptable, it is still recommended that the
laboratory establish its own limits based on its own historical
analytical data base.  The laboratory's direction toward  establi-
shing a computerized data base will be quite helpful in retrieving
and manipulating data, and therefore should serve as a useful
tool in establishing data acceptance criteria.


SAMPLE RECEIPT AND STORAGE

Sample Storage

     The laboratory does have by its own admission a significant
sample storage problem.  The volume of analyses has created quite
a burden on sample management personnel, in attempting to main-
tain available storage space.  At present, there is no separate
storage space dedicated to enforcement confidential or enforce-
ment sensitive samples.  For purposes of proper chain-of-custody,
it is recommended that the laboratory explore the possibility of
allocating secure storage space for these type of samples.  The
laboratory also does not currently have a specified containment

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area for samples received in a leaky condition, or for those
samples containing relatively high concentrations of chemical
contaminants.  I was informed by laboratory personnel that con-
tainment hoods might be established in the future.  Such an
addition would be helpful in protecting worker safety and in
minimizing the chances of laboratory-wide contamination.  One
last area which could be improved involves the need to establish
a traceable QA/QC system for sample containers.  Based on the
information provided by laboratory personnel,  it does not appear
that the laboratory has a mechanism for tracing potential sources
of sample container contamination back to specific batches.  It
is therefore recommended that the laboratory establish a system
for recording batch numbers of sample containers purchased through
their supplier, as well as a routine for conducting QC analyses
on random blank bottles.
GENERAL OBSERVATIONS

     The laboratory in general appears to be well organized,
suitably equipped with adequate instrumentation, and staffed by
capable professionals.  Management is quite knowledgable on an-
alytical procedures applicable to various environmental programs,
and has demonstrated an attempt to ensure that all staff also
become aware of these requirements.  Management also appears to
display a conscientious effort to incorporate the appropriate
degree of QA/QC activities for each project, as was reflected in
the supervisors' routine practice of conducting daily project
update meetings.  Certain instrumentation used in inorganic anal-
lyses (AAs and ICP) and organic analyses (GCs and GCMSs) are
"dedicated", and thus are used only for specific types of anal-
yses.  In addition, the laboratory also has a number of backup
instrumentation in the event that primary instrumentation is not
available.  The IT Corporation appears to have in place an exten-
sive external QA program, which also serves in ensuring that all
IT laboratories uniformly follow standard QA/QC practices.
                              - 4 -

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CONCLUSIONS

     The laboratory generally has a number of QA/QC areas which
need to be modified or improved upon.  Although none of these
areas will singularly jeopardize the quality of data generated by
the laboratory, it is conceivable that, in combination, they can
cause significant problems.  It is therefore strongly recommended
that these concerns, as previously noted, be addressed and correc-
ted at the earliest opportunity.  First and foremost, laboratory
management must finalize and implement their QA plan.  Second,
the laboratory should accelerate its development of a centralized
computer program, and develop QC data acceptance limits.  Lastly,
documentation of records needs to maintained and reviewed.  In
summary, if the laboratory continues to maintain it current
standard of operation, positive attitude, and initiates the
recommended corrective action, it is expected that the laboratory
can satisfactorily analyze groundwater samples and generate data
of acceptable quality.

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                   PART  II






-OFF-SITE HAZAFDOUS WASTE ANALYSES  LABORATORY




            IT VINEHILL  LABORATORY

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I.  INTRODUCTION

     The IT Panoche facility utilizes an off-site laboratory
for the analyses of all hazardous waste samples prior to accep-
tance.  These pre-disposal analyses are conducted by the IT
Vinehill laboratory located in Martinez, CA, to ensure that the
chemical and physical characteristics of the hazardous waste
loads are suitable for disposal at the Panoche site.  The focus
of this audit was to determine whether these pre-disposal
analyses have been performed correctly, and to ascertain if the
laboratory has been following proper analytical and quality
assurance procedures.  This audit did not concentrate on truck
receiving analyses specific to the operation and waste management
activities of the IT Vinehill facility.  In conjunction with a
concurrent investigation by EPA's National Enforcement Investiga-
tion Center (NEIC), this audit was conducted in two phases over a
duration of three days.  The first phase involved a discussion of
the availability of relevant laboratory documentation, the
applicability and accuracy of the facility's Waste Analyses Plan,
and other administrative matters.  The second phase consisted of
a walkthrough of the laboratory, a discussion of analytical
methods, and a visual assessment of analytical instrumentation.
Specific comments and deficiencies regarding these activities are
summarized in subsequent sections of this report.

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.1.  DEFICIENCIES

    QUALITY ASSURANCE PROGRAM

         In general, the QA program in place at the time of the audit
    was adequate.  There were, however, specific areas which were
    determined  to be deficient.  These areas are summarized as noted
    below.

    Analytical  Procedures

         There  appear to be a number of circumstances where the lab's
    analysts depend on "best professional judgment" in conducting
    analyses and assessing data.  Although this approach may in most
    instances be technically sound, the lab should have specific
    documentation (i.e., standard operating procedures, procedural
    guidance, etc.) to substantiate their decisions.  Although a number
    of lab analysts were interviewed, it was not entirely clear
    whether the lab had established and followed a specific "decision
    tree" process in conducting their analyses.  As an example, there
    were instances where the analytical procedures described by
    particular  analysts or section supervisors were actually incorrect
    or inaccurate.  Specifically, the spot test procedure described for
    cyanide analyses was not consistent with the method sequence cited
    within the  laboratory's QA plan, and there was some confusion as
    to how and  why hydrocarbon vapor pressure (HCVP) hexane equivalents
    correlate to ignitability criteria.  These discrepancies may only
    be reflective of one specific area within the lab (i.e., truck
    receiving analyses) and not be characteristic of the lab's overall
    capabilities, but nevertheless should be investigated as an area
    needing improvement.

         Discrepancies were also noted in the area of inorganic metals
    analyses.   At present, the lab .does not establish a multi-level
    calibration curve during atomic absorption analyses (although this
    is done for ICP analyses).  As a result, it is unlikely that
    linearity can be established over a certain calibration range,
    and therefore questions regarding the accuracy of reported concen-
    trations might be raised.  It is therefore recommended that the
    lab establish at least a three-point calibration curve and attempt
    to "bracket" a concentration range.

    Standard Operating Procedures

        In terms of QA documentation, the IT laboratory has developed
    a corporate-wide QA plan as well as a QA plan specific to the
    operation of the Northern California (IT Vinehill) Laboratory.
    However, it was not clearly apparent that all of the laboratory
    personnel were familiar with the QA requirements outlined in
    either of these documents.  As an example, when questioned on the
    existence of standard operating procedures (SOPs) for such areas
    as truck sample receiving, pre-disposal receiving and glassware
    washing, personnel could not readily refer to an existing SOP.

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     In  order  that  proper  procedures  are  followed  in  a consistent
     manner, it  is  recommended  that management  ensure that  laboratory
     personnel are  routinely  trained  in  familiarizing themselves with
     changes in  laboratory QA operations.   This could be  accomplished
     via the use of formal training sessions, or through  internal
     a ud i t s.
[I.   CONCLUSION
          As  stated  previously,  the  focus  of  this  audit  was  to ascer-
     tain  whether  the  IT Vinehill  Laboratory  has been  conducting
     pre-disposal  analyses  correctly,  and  to  determine if  data gene-
     rated for  the IT  Panoche  facility is  of  adequate  quality.  In
     these terms,  it is felt  that  this laboratory  has  the  appropriate
     instrumentation,  adequate  facilities  and qualified  personnel  to
     satisfactorily  conduct pre-disposal analyses.   With the exception
     of  certain deficiencies  noted earlier, the laboratory generally
     utilizes the  correct analytical procedures for  pre-disposal
     analyses.  Conceptually,  the  QA program  is appropriately compre-
     hensive  and quite detailed.   However, although  the  laboratory is
     organizationally  stable  and has established a technically sound
     foundation, it  is apparent  that a number of deficient areas  need
     to  be addressed.  Specifically, management needs  to better dis-
     eminate  their technical  expertise and QA philosophy to  all
     laboratory staff.  Also,  there  appears to be  a  lack of  consis-
     tency in the  manner the  laboratory conducts pre-disposal analyses
     versus truck  receiving analyses.   This was clearly  apparent  based
     on  the discrepancies in  truck receiving  analyses  summarized  in
     EPA's NEIC RCRA Compliance  Inspection Report  (Sept. 1986).
     Lastly,  greater emphasis  has  to be placed on  ensuring that proper
     documentation is  maintained throughout each facet of  analyses.
     If  discrepancies  are noted, the laboratory should establish  a
     mechanism  to  either resolve these differences,  or have  a system
     to  substantiate the rationale for supporting  these  discrepancies.

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              PART  III
ON-SITE WASTE ANALYSES LABORATORY
             IT  PANOCHE

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  I.  INTRODUCTION

           On August 27,  1986,  an audit was conducted of the on-site
      waste disposal laboratory at IT Panoche. This laboratory is
      responsible for performing confirmatory "fingerprinting" analyses
      of all waste loads prior to acceptance and disposal at the facility.
      Pre-disposal analyses are not conducted at IT Panoche, but rather
      are the responsibility of the waste laboratory at IT Vinehill in
      Martinez,  California.  This audit focused on the capability of the
      IT Panoche laboratory to conduct the fingerprinting analyses
      correctly.

 II.  FINDINGS

           IT Panoche requires that pre-disposal analyses be performed
      on each new waste load, or annually on those waste loads which
      are submitted on a recurring basis by the same generator.  RCRA
      waste loads are typically bulk liquids received in vacumm trucks,
      as containerized liquids are not accepted for disposal.  The
      laboratory performing these analyses is situated in a limited but
      adequate space environment, and is essentially staffed by one
      fulltime chemist.  The chemist is responsible for managing the
      operation of the laboratory.

           As described by the chemist, the fingerprinting analyses
      conducted"by the laboratory are consistent with the methods
      identified in the facility's waste analyses plan.  These methods
      are quite standard,  and include such tests as pH, acid or base
      strength,  density,  and hydrocarbon vapor pressure determinations.
      All aqueous phase samples are subjected to spot tests for cyanide,
      sulfide,  and phenols.  Upon completion of the appropriate battery
      of tests,  the results are compared to the information generated
      during the pre-disposal analyses.  Waste loads are only accepted
      if the chemist determines that the fingerprinting results reasonably
      match that of the pre-disposal sample.   If the loads do not match,
      and are subsequently rejected, this information is then recorded
      and documented.

III.  CONCLUSION

           Despite the relatively small scale of operation existing at
      the IT Panoche facility,  there still exists a very good standard
      of work performed by the staff chemist at the laboratory.  The
      profiles of waste currently deemed acceptable for disposal at the
      site are well defined by IT, therefore it is an unusual occurance
      for the laboratory to receive a waste load which cannot be adequately
      characterized.   General laboratory practices are acceptable and
      staff are well experienced.  Based upon the findings of this audit,
      fingerprinting data generated by this laboratory is expected to be
      satisfactory specifically for the type of wasteloads presently
      accepted at the site.  However,  should the quantity and profile
      of future wasteloads increase or change as a result of expanded
      disposal capacity at this site,  then the lab should be re-evaluated
      for any new additional screening analyses.  In addition, these
      modifications should be adequately and appropriately reflected in
      a revised waste analyses plan.

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ATTACHMENT D

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      \        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

       I                        WASHINGTON, D.C.  20460
                                                                       OFFICE OF
                                                          POLICY, PLANNING AND EVALUATION
 MEMORANDUM                                       27  March 1987
Subject:    Review of the Statistical Methodology Proposed by International Technology
           Corporation for the Panoche, California Hazardous Waste Disposal Site.
From:     Barnes Johnson, Statistician
           Statistical Policy Branch
To:        Hannible Joma, Geologist
           EPA Region IX
           Hazardous Waste Ground-Water Task Force
     The general sampling and statistical analysis approach, (specifically the interest in
obtaining "true" replicate samples and the use of Analysis of Variance (ANOVA)) offered by
International Technology Corporation (IT) are  reasonable and should be encouraged.  However,
the details of the ANOVA approach are unacceptable because upgradient concentrations are not
compared with downgradient concentrations and because differences among wells and individual
well comaprisons are not tested as part of the approach.

Lack of a  Upgradient versus Downgradient Comparison

     IT is  proposing to  use a method which does not consider contamination that might  be
present in  the ground-water before the ground-water flows under the hazardous waste
management unit (HWMU) of concern.  A commercial facility, having many HWMUs under
independent evaluation  and with possible relict contamination, risks triggering the IT proposed
test when there is no contamination emerging from the HWMU with a higher than expected
probability.  Specifically,  under the ANOVA testing scenario that IT has proposed (and  that I
disagree with as discussed below) there may be a significant well by time interaction and
therefore a suggestion of contamination in the ground-water that actually has been caused by
external influences and  not the HWMU.  Upgradient ground-water  concentration patterns.
although discussed, are  not considered or evaluated in the proposed  method and there may
actually be a "natural" well by time interaction that is not caused by the HWMU.

     The only time that the upgradient data may not need to be considered is when there are
no upgradient concentrations of the indicator parameters measurable above  the detection limit.
In this case, however, under the scenario of no leakage from the HWMU there are also  few
downgradient concentrations above the detection limit which will make any conventional
ANOVA approach problematic.

-------
Lack of an Evaluation of Differences Among all Wells and Between Specific Wells

     IT proposes an ANOVA based method which will indicate contamination  when there is a
significant well by time  interaction.  In simple terms this means that the HWMU will trigger
when there is an indication that  all wells do not behave in the same pattern relative  to one
another over time.  This concept is best expressed graphically.  Figures 1A, IB, and 1C are
examples of hypothetical data that would trigger the interaction test proposed by IT.  First
notice that in 1A, IB, and.1C the difference between wells 1 and 2 is  not constant, therefore
the significant interaction. Also observe that in IA and  IB there is question as to whether
there is actually contamination and if so  in which well,  maybe  both wells, or maybe neither
well.  In 1C it appears that well 2 is  consistently greater than well 1 althought  the difference
is decreasing (a plot similar to  1C, also with a significant well by time interaction, could have
been shown with the concentrations in wells 1 and 2 getting progressively farther apart).  The
point is that a significant well  by time interaction may or may  not adequately indicate
contamination.  Figure ID illustrates the  situation where concentrations change over time but
the relationship between the wells does not change.  In Figure  ID there is not a significant
well by time interaction  but well 2 could be contaminated. Figure IE demonstrates the  most
startling scenario that might occur under  the IT approach.  In Figure IE there  is clearly no
well by time interaction, however well 2  has consistently larger concnetrations  than well 1.
Finally, Figure  IF illustrates the situation where there is little or  no interaction and probably
no statistically significant difference  in concentration between the wells. The conclusion  from
Figure  1 is  that using a significant well by  time interaction as the triggering threshold can
result in both false positives and false negative results at a higher than anticipated rate.


Suggestions for Improvement

     As mentioned earlier the  ANOVA approach is a reasonable construct for evaluating
contamination. However, IT has not gone far enough. Generally if a significant interaction  is
not found then differnces among wells should be tested to guard against the situations in
Figures ID  and IE.   If no differences are seen among wells after finding no interaction then,
unless all the  downgradient wells are contaminated, the  site is probably not  contaminating.  If
there are differences among wells then differences between specific wells or groups of  wells
should be evaluated,  using contrasts or other such multiple comparison procedures, to determine
in which wells the contamination is located.     If a significant well by time interaction is
found it is likely that at some time or at  all times as illustrated in Figures 1A,  IB, and  1C at
least one well has a larger concentration than the others. These can be evaluated by looking
at specific  contrasts within  the overall linear model.  Plotting the data as illustrated in Figure
1 will help  to focus  the  evaluation of specific well and time differences.

   Finally, the attached  article provides an  ANOVA approach to the evaluation of environmental
change. The approach advocates the use  of a before and after  effect in the model which is in
some  ways analagous to  the upgradient/downgradient scenario in this situation.


attachment
cc:    Mary Allen
      John Warren

-------
                WELL 1
             WELL 2
     I    I
            I    I
CJ

CD
                                  D
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    ^.   A   A   A   A
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T   I
                                            -A—A
       TIME
     Figure 1. Examples  of  Time  Differences,  Well
     Differences, and Well  by  Time  Interaction.

-------
ATTACHMENT E

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                        ATTACHMENT E




       Chronology of Ground Water Enforcement Actions


     Date           	Activity	
March 1984          EPA conducts RCRA interim status inspections

May 1984        .,   EPA notifies DHS & RWQCB of interim status
                    violations, including ground water monitoring

July 1984--          DHS refers case to the District Attorney for
                    Contra Costa County, Violations match EPA's

September 1984      EPA issues civil (administrative) complaint
                    to IT-Benicia for interim status violations,
                    including ground water monitoring

     Many discussions with the EPA, State and IT occured during
this time period.

January 1985        RWQCB issues Cleanup and Abatement Order
                    No. 85-003, which supercedes the ISD ground
                    water monitoring waiver,  orders compliance
                    with the Interim Status Document, and
                    requires assessment work.

July 1986           EPA and IT signed a Consent Agreement to
                    resolve the September 1984 complaint.
                    Ground water violations were withdrawn in
                    consideration of 1/85 RWQCB Cleanup and
                    Abatement Order.

September 86        RWQCB issues Cleanup and Abatement Order to
                    the Benicia facility to order further study
                    (assessment) of contaminant plumes in the
                    areas of surface impoundments 12 through 16,
                    surface impoundments O, P,  and Q, and surface
                    impoundments 1 and 2.  Monthly progress
                    reports to be submitted beginning January 1,
                    1987.  Surface seeps in the area south of
                    ponds 1 and 2 are ordered to be contained
                    by November 14, 1986.

-------
ATTACHMENT F

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TABLES

-------
                                    Table  1

      Benficial Water Use In The Vicinity of  IT Panoche Facility
              (Source; Leroy Crandal And Associates,  1985)

Well No.                                  Remarks

    1       Evidence of old windmill at abandoned farm house.  Stock pond
            nearby.

    2       Domestic Well (Stephen Thurlo, Box  2 Lake Herman Road, Benicia) -
            Shallow dug well, 15* wide x 30' deep, stone  and concrete lined,
            wooden cover, no seal.   Small electric submersible pump.  Sampling
            access  OK.  In swale near creek  with heavy riparian  growth.

    3       Stock Well (neighbor said IT owned well) - 6* PVC casing with
            electric submersible pump.  Discharge to stock trough.   4"
            open iron casing nearby,  probably abandoned well.  2"  lines,
            gage shows 46 psi  in pressure tank.  Located in  sandstone outcrop.
            Has 3/4" or 1" measuring port in well cover, no pad, concrete
            seal.  No information on  depth, age or construction.

    4       Domestic Well (W.A. Brady. 1048  Lopes Road, Benicia) - Well
            dug in  1867.  It is stone lined with concrete  collar  and  wood
         .   cover.   No seal, 12' deep, about  10' across with  electric pump
            (10  gpm).  Located in sag pond area within Green Valley Fault
            Zone.

    5       Gravel  Pit Well (1060 Lopes Road, Benicia) -  Neighbor reports it
            to have been drilled in 1984 to a  depth of 130 feet.

    6       Domestic Well  (Ben Villareal,  no address, Lopes Road) - 8* drilled
            well with steel casing.  Electric submersible pump.  No  information
            on depth.  Approximately 22 years old.

    7       Developed Spring (Harland Hall,  Lopez Road.  Benicia) - Well about
            100  years old.

    8       Quarry  Well - Reported to be drilled about 5  years  ago.

Unlocated Wells:   Doshier Grayson Drilling (5365 Napa Valley  Hwy.)  reports to
    have drilled  3 wells along Lopes Road.  1) Sweet Ranch Well is  200' deep,
    bottomed in  grey siltstone and sandstone  and makes 50 gpm,  1981.  Quarry
    Wells: 12 bottomed in basalt at 250', 275gpm, 1980; 13 bottomed  in grey clay
    and grey rock.  300' deep,  20 gpm, locations unknown.

-------
Table  2  GENERAL CHARACTERISTICS AND THE WELLS IN EACH CLUSTER
Group
1
2
3
4
5
C1:S04
10:1
Variable
10:1
<2:1
Variable ratios
Low chloride
concentration
SpCond
>5000
1000-6000
<5000
>2000
<2000
Wells
MW7, MW14, MW21,-1*728, l*J4$. 1*749 ,
MW56, 2B, C6, MW-13, M^-17, IW-53
MW12, MW16, 1*724* 1*736, 1*737, MW38,
MW39, 1*742
MW10, 1*722, 1*725, 1*727, 1*729, 1*734,
1*741, 1*743, MM46, MH48, 1*751, 1*752
1*71, 1*726, 1*731, MW47, C2
MW4, 1*78, 1*711, MW15, 1*720, MN23,
MH33, 1*735, 1*750, Cl, C4
         (Source; Camp  Dresser &  McKee, 1987)

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-------
TABLE 4  AVERAGE CONCENTRATIONS (mg/L)  OF  SELECTED INDICATORS  IN WELLS
                          MW-16, MW-35 throunh MW-39
lut_. flW-16 MW-37 MW-35 MW-38
y Background Shallow Bedrock
Cl 110
S04 146
SpCond
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               (Source;  Camp  Dresser  &  McKee,  1987)

-------
               Table  5

                HWGWTF
       Groundwater Monitoring Data
              August 1986
(Source; Camp Dresser  &  McKee, 1987)

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-------
ATTACHMENTS

-------
FIGURES

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  ^^      i T Y       _
                                                                       6000 FEET
•»
i
 ASSESSOR'S PARCEL NUMBERS FOR IT PROPERTY
 181-270-01  TO 04;  181-260-01,04 AND
 05;  181-240-01,02  AND  03 i 80-030-01
 AND  02.
 REFERENCE--
                                                          FIGURE 1
        SITE  LOCATION MAP


 IT CORPORATION PANOCHE FACILITY
7.5' U.S.O.S. TOPOGRAPHIC QUADRANGLES OF
BENICIA (1959), CORDELIA (1951), FAIRFIELD
SOUTH (1949) AND VINE HILL (1959), CALIFORNIA;
PHOTOREVISED:  1980, SCALE- l>24000
W3 •  WELL OR DEVELOPED SPRING
 "Do Not Seal* This Drawing

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c
                                           TRENCH  T-43

                                          GEOLOGIC UNITS

       A    ORGANIC SOIL - Sandy silt (stn), brown,  dry,  loose, subhorizontal soil ped
            fracturing near base of the unit.

       B    SOIL - Sandy silt.(sm), medium brown, dry, very loose, friable, many small
            tubular voids (highly permeable), few prismatic soil fractures are developed
            because of low shrink-swell potential.

       C    RESIDUAL SOIL - Clayey silt (mh), light gray, some orangish iron staining and
            very extensive prismatic soil fracturing.  At station 22, this unit grades into
            a shale bedrock unit described in Unit  E

       D    SANDSTONE BEDROCK - Moderately weathered, hard, heavily iron oxide stained;
            contains siltstone interbeds.

       E    SHALE BEDROCK - Light gray to tan weathered, thinly bedded clayey siltstone
            with heavy orangish brown, iron oxide staining along bedding plane surfaces.

       F    SANDSTONE BEDROCK - Whitish colored, massive to poorly bedded, medium fine-
            grained, weathered sandstone.

                                          GEOLOGIC NOTES

       1    Iron-stained joint:  N27eW, 63"SW dip.

       2    Bedding:  N44'E, 9*NW dip.

       3    Soil-bedrock contact believed to approximate bedding direction:  N29*E, 8*NW
            dip.

       4    Stone-line.  Layer of coarse gravel lain down or concentrated during the soil
            forming process.

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       PROTECTIVE STEEL CASINO
       WITH LOCKING CAP
Xj
CEMEN
(FINISH
PORTL
4 INCH
(FLUSH
BENTOt
NO. 1/2
NO. 3 N
(WASHC
4 INCH
INCH SI
(FLUSH
• ' 2 S

•***+


T BLOCK °
ED SURFACE SEAL ) 	 v

4» SCH. 40 PVC BLANK 	
-THREADED END JOINTS)
JlTP PPI 1 PT1 . •? PT __^__
O MONTEREY SANO-1 FT. -
IONTEREY SAND - 2 FT. 	
•D)
6 SCH. 40 PVC 0.020
-THREADED END JOINTS)
••
/—THREADED END CAP— ^
— NO. 3 MONTEREY SAND -
— NO. 1/20 MONTEREY
SAND (1 FT.) *
- BENTONITE TO 1 FT. ABOV
TOP OF END PLUG
-N
END PLUG
Y////////.
^
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1

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r
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. LAND SURF
2
I
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O
>

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2
Z
i


FIGURE t
TYPICAL SHALLO
      12 IN.
NOTE:
WITH 12 INCH AUGERS. THE END PLUG AT BOTTOM
AUGER 19 GENERALLY KNOCKED OUT AND LEFT IN
BOTTOM OF HOLE.  WHEN USING THIS TECHNIQUE.
ADVANCE HOLE 2 FT. DEEPER AND SEAL OFF THE
PLUG WITH BENTONITE.  SEE DIAGRAM •
                CONSTRUCTION
         IT CORPORATION BENICIA FACILITY
           IT CORPORATION

-------
     PROTECTIVE STEEL CASING
     WITH LOCKING CAP


     CEMENT BLOCK
     (FINISHED SURFACE SEAL )
SLIP-ON PVC CAP
(VENT THE CAP. NOT THE CASING)
                                                          LAND SURFACE
                                               1/9
                                             2-2"* FT. STICK-UP
     PORTLAND CEMENT
    * BOREHOLE

    * OUTER LINER CASINO
     4"$ SCH. 40 PVC BLANK
     (FLUSH-THREADED END
     JOINTS)
     BENTONITE PELLETS- 2 FT.
                                                TOP OF UNWEATHERED ZONE
     NO. 1/20 MONTEREY SANO-1 FT. - -
     NO. 3 MONTEREY SAND -
     TO 2 FT. ABOVE SCREEN
     (WASHED)

     4"0 SCH. 40 PVC 0.020
     INCH SLOTTED SCREEN-
     (FLUSH-THREADED END JOINTS)
    THREADED END CAP
     NO. 3 MONTEREY SAND
                                       r.v.

                                           •
                                           i
                                   B IN.
                                 MINIMUM  '
                                 BOREHOLE
DIAMETER TO BE DETERMINED
BASED ON AVAILABLE
DRILLING APPARATUS
                                                      FIGURE 16
                                           TYPICAL DEEP WELt CONSTRUCTION
                                           IT CORPORATION BENICIA FACILITY
                                              IT CORPORATION

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