700887031
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUNDWATER TASK FORCE
GROUNDWATER MONITORING EVALUATION
BFI/CECOS INTERNATIONAL, INC.
CALCASIEU FACILITY
LAKE CHARLES, LOUISIANA
SEPTEMBER 1987
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th HOOf
60604-3590
THOMAS E. AALTO
PROJECT COORDINATOR
U.S. EPA REGION VI, DALLAS, TEXAS
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UPDATE TO THE GROUNDWATER TASK FORCE REPORT
FOR
BFI/CECOS INTERNATIONAL, INC.
CALCASIEU FACILITY
LAKE CHARLES, LOUISIANA
The Task Force report discusses conditions that were present at
the site at the time of the January 1987 inspection. Listed below are
selected items pertaining to events which transpired after the
inspection during the period January 1987 to September 1987.
0 On April 20, 1987, the Louisiana Department of Environmental Quality
(LDEQ) commented on the facility's Revised Remedial Action
Plan, and stated that the "zone of interconnection" between the
"50-Foot Pervious Zone" and "200-Foot Sand" may be greater than
indicated by the facility and may underlie areas of contamination.
0 As a result of the conditions existing at the site, which
are not currently being controlled through a HSWA permit
or Federal administrative order, the facility was notified by
EPA on May 7, 1987, that it was ineligible to receive waste
from Superfund response actions according to EPA's Off-site
Policy.
0 The facility installed and sampled monitoring wells in the
"200-Foot Sand" near monitoring wells MW-39 and MW-41 during
the Spring of 1987. These wells are designated as MW-52
and MW-53 respectively. On May 7, 1987, the facility submitted
analytical results for these wells to the State and reported
that organic contaminants were detected in MW-52.
0 On June 5, 1987, the facility proposed a plan to install
additional monitoring wells in the "50-Foot Pervious Zone"
and "200-Foot Sand" along the south facility boundary.
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II
0 At the request of the State, the facility began operating a
self-actuating pump in the leachate detection system of landfill
cell 7 on June 15, 1987 to remove excess leachate.
0 On July 8, 1987, the facility submitted a proposal to install
additional monitoring wells around the active surface impoundments.
0 On July 13, 1987, the facility proposed to install additional
recovery wells to remove contaminated groundwater.
0 During July 1987, the Louisiana Department of Health and Human
Resources (LDHHR) conducted a drinking water well survey near the
site; three drinking water wells were identified in the immediate
vicinity of the site (near the south facility boundary). These
wells were subsequently sampled for volatile organic compounds by
LDHHR, and were reported to be uncontaminated (informal transmittals,
August 1987).
0 On August 19, 1987, the LDEQ responded to the facility's July 13, 1987
letter, and requested an additional recovery well to remove
contaminated groundwater.
0 On August 19, 1987, LDEQ requested that the facility install a
number of additional monitoring wells in the "50-Foot Sand"
near regulated land disposal units and areas of known; contamination.
0 On August 28, 1987, the LDEQ approved a facility plan to determine
the Teachability of wastes remaining in the former surface
impoundments.
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CONTENTS
EXECUTIVE SUMMARY Page
INTRODUCTION 1
SITE BACKGROUND 4
SUMMARY OF FINDINGS AND RECOMMENDATIONS 9
TECHNICAL REPORT
INVESTIGATION METHODS 13
'WASTE MANAGEMENT UNITS AND OPERATIONS 16
SITE HYDROGEOLOGY 26
GROUNDWATER MONITORING PROGRAM DURING INTERIM STATUS 33
GROUNDWATER MONITORING PROGRAM PROPOSED BY FACILITY FOR
FINAL PERMIT 64
TASK FORCE SAMPLE COLLECTION AND HANDLING PROCEDURES.... 66
TASK FORCE MONITORING DATA ANALYSES FOR INDICATIONS OF
WASTE RELEASE 73
REFERENCES 77
APPENDICES
A TASK FORCE GROUNDWATER ANALYTICAL DATA
B CONCENTRATIONS OF VOLATILE PRIORITY POLLUTANTS
FOURTH QUARTER, 1986
C GEOLOGIC CROSS-SECTIONS
D INVENTORY OF WELLS
FIGURES
1 SITE LOCATION MAP 5
2 FACILITY MAP 18
3 LOCATIONS OF WELLS AND BORINGS 35
4 CONCENTRATIONS OF 1,2-DICHLOROETHANE IN SHALLOW SANDS 40
5 CONCENTRATIONS OF 1,2-DICHLOROETHANE IN "50-FOOT
PERVIOUS ZONE" 41
6 LOCATIONS OF PROPOSED RECOVERY WELLS 44
7 GENERALIZED MONITORING WELL CONSTRUCTION 48
8 GENERALIZED RECOVERY WELL CONSTRUCTION 49
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Table of Contents (r.ont.)
TABLES
1 SUMMARY OF FACILITY HYDRAULIC CONDUCTIVITY STUDIES ,... 30
2 COMPOUNDS DETECTED IN SITE MONITORING WELLS 38
3 CALCULATED GROUNDWATER AND CONTAMINANT FLOW VELOCITIES 42
4 BFI/CECOS GROUNDWATER SAMPLING SCHEDULE 52
5 BFI/CECOS GROUNDWATER SAMPLE CONTAINERS AND PRESERVATIVES... 55
6 TASK FORCE GROUNDWATER LEVEL MEASUREMENTS 68
7 TASK FORCE GROUNDWATER PARAMETERS, CONTAINERS, AND
PRESERVATIVES 69
8 SELECTED GROUNDWATER SAMPLING RESULTS FROM THE TASK FORCE.
EVALUATION 76
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EXECUTIVE SUMMARY
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INTRODUCTION
Recently, concerns have been raised about whether hazardous waste
treatment, storage and disposal facilities (TSDFs) are in compliance
with the ground-water monitoring requirements promulgated under the
Resource Conservation and Recovery Act of 1976 (RCRA)*. Specifically,
the concerns focus on the ability of ground-water monitoring systems to
detect contaminant releases from waste management units at TSDFs. In
response to these concerns, the Administrator of the Environmental
Protection Agency (EPA) established a Hazardous Waste Ground-Water Task
Force (Task Force) to evaluate compliance at TSDFs and address the
cause(s) of noncompliance. The Task Force is comprised of personnel
from EPA headqjarters, EPA regional offices, and State regulatory
agencies. To determine compliance, the Task Force is conducting in-
depth onsite investigations of TSDFs. The objectives of these
evaluations are to:
0 Determine compliance with ground-water monitoring requirements
of 40 CFR Part 265, Suhpart F, "Interim Status Standards for
Groundwater Monitoring", as promulgated under RCRA or the State
equivalent (where the State has received RCRA authorization);
0 Evaluate the ground-water monitoring program described in the
facility's RCRA Part B permit application for compliance with
40 CFR Section 270.14(c), "Additional Information Requirements";
and potential compliance with the rules set forth in 40 CFR
Part 264, "Standards for Owners and Operators of Hazardous
Waste Treatment, Storage, and Disposal Facilities";
* Regulations promulgated under RCRA address hazardous waste
management facility operations, including ground-water monitor-
ing, to ensure that hazardous waste constituents are not released
to the environment.
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0 Determine if the ground water at the facility contains hazardous
waste or hazardous waste constituents;
0 Provide information to assist the Agency in determining if the
TSDF meets EPA ground-water monitoring requirements for waste
management facilities receiving waste from response actions
conducted under the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA)*; and
0 Assist in the development of vigorous, nationally consistent
methods for conducting groundwater evaluations and implementing
follow-up actions.
To address these objectives, each Task Force evaluation will determine
if:
0 The facility has developed and is following an adequate ground-
water sampling and analysis plan;
0 Designated RCRA-re quired and/or State-re quired monitoring wells
are properly located and constructed;
0 Required analyses have been conducted on samples from the
designated RCRA monitoring wells;
0 The groundwater quality assessment program outline (or plan
as the case may he) is adequate; and whether
0 Recordkeeping and reporting procedures for groundwater monitoring
are adequate.
* EPA policy, stated in the May 6, 1985 memorandum from Jack McGraw
on "Procedures for Planning and Implementing Offsite Response",
requires that TSDFs receiving CERCLA wastes he in compliance
with applicable RCRA ground-water monitoring requirements.
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The CECOS International, Inc. far.ility of Lake Charles, Louisiana
(hereinafter, "CECOS") Task Force evaluation was conducted by EPA Region
VI in cooperation with EPA Headqjarters and the Louisiana Department of
Environmental Quality. The evaluation included an extensive review of
State, Federal and facility records, a two-week onsite facility sampling
inspection, and subsequent review of analytical data results. The
onsite inspection was conducted from January 12 through January 21,
1987. It involved sampling, as well as extensive interviews with
facility management and personnel concerning the facility's groundwater
monitoring system and operation.
Disclaimer: The mention of any trade names in this report does not
constitute endorsement.
[Note: Unless otherwise stated, all Figures, Tables, and Diagrams presented
in this report were obtained from facility records.]
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SITE BACKGROUND
The CECOS International, Inc. facility of Lake Charles, Louisiana is
a commercial hazardous waste disposal site located approximately 10
miles northwest of Lake Charles and 5 miles northwest of Westlake in
Calcasieu Parish (Figure 1). The site is known by several names which
include the Calcasieu facility, the Westlake facility, the Lake Charles
facility, the Willow Springs facility (the small community of Willow
Springs is less than one-half mile to the southwest), and the Sulphur
facility. The site is also referred to as the Browning-Ferris Industries
(BFI)/CECOS facility. The facility's EPA identification number is LAD000618256.
The 80-acre facility lies on relatively flat, wooded ground near
the confluence of the Little River and the West Fork Calcasieu
River. The area immediately surrounding the facility consists mainly
of undeveloped land with some agricultural and timber activity, and is
sparsely populated. Most of the site is at an elevation of 20 to 25
feet above mean sea level, except for the northeast corner which
approaches within a few feet of sea level.
Operations at the site were begun in 1968 by Mud Movers, Inc. BFI
aquired the facility in 1972. BFI Chemical Services, Inc., a BFI
subsidiary, operated the site until mid-1983 when operational control
was transferred to CECOS International, Inc., another BFI subsidiary.
Initial hazardous waste management operations under Mud Movers, Inc.
consisted of storing various petrochemical and oil field production liquid
wastes in surface impoundments. These practices were continued by BFI
during the period 1972-1977, and an injection well was put into operation.
During the period 1977-1982 the surface impoundments were phased
out and replaced by landfilling operations. A total of eight landfills
were constructed (although the eighth landfill, constructed in 1983, was
never used) as the surface impoundments were closed (not RCRA closure).
Also, in 1979 two receiving basins, an equalization basin, and six mixing
basins were added to complement the injection and landfilling operations.
Groundwater contamination at the site was reported by the facility in
1982. As a result, all mixing basin and landfill operations ceased during
the period from late 1983 to early 1984. According to the facility, the
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Figure 1. Site location map, Louisiana. Scale 1:2,500,000,
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groundwater contamination is suspected to have resulted from previous
surface impoundment operation, and has not been linked to landfill ing
operations by the facility. Also, a 1985 report by the Louisiana Department
of Natural Resources entitled "The Geohydrology, Subsurface Geology,
and Reservoir Engineering As Related To The CECOS International Commercial
Class I Injection Well At The Willow Springs Site, Calcasieu Parish,
Louisiana" concluded that injection operations had not contributed to
the groundwater contamination at the site.
From 1984 to present, the only operating hazardous waste management
units have been the receiving basins, the equilization basin, and the
injection well. Current plans call for the continued use of the
injection well and replacement of the impoundments with above ground
storage tanks.
Due to various factors, including the presence of substantial
groundwater contamination at the site, the facility has received a fair
amount of public attention. In at least one case, a citizens group has
contracted a consulting engineering firm to evaluate site conditions
(see: "Waste Management Units and Operations"). A primary concern was
the fact that some nearby residents utilize private wells for drinking
water. Currently at least three nearby residences utilize private wells
for drinking water. These residences are located immediately south of
the facility. The facility reported that they were not aware of any
contamination of these private wells. Most nearby residents are connected
to a Public Water Supply system which taps the Chicot aquifer approximately
7 miles north of the site.
The regulatory history of the site involves administration by the
Louisiana Department of Natural Resources (DNR), the Louisiana Department
of Environmental Quality (DEQ), the Louisiana Department of Health and Human
Resources (DHHR) and EPA. These Federal/State and intrastate jurisdictions
have changed over time as have the program requirements themselves.
Operations at the site began prior to the development of the RCRA
provisions for hazardous waste management. The facility initially came
under the Louisiana Hazardous Waste Management Plan in 1979 and EPA
RCRA regulations in 1980. Louisiana was authorized to administer and
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enforce the interim status provisions of the RCRA program in 1980 and
the full RCRA program in 1984 (except for the RCRA amendments of 1984).
During the 1980-84 time period, EPA promulgated various revisions to
the RCRA regulations which, in turn, required revisions to Louisiana
regulations. Also, jurisdiction for the hazardous waste program was
transferred from DNR to DEQ.
Injection operations at the site began prior to an EPA-approved
Underground Injection Control (UIC) program (under the Safe Drinking
Water Act). The State received authorization to implement the UIC
program in 1982. Prior to that time, the injection well was regulated
by DNR and DHHR. Since 1982, the underground injection of hazardous
waste has been regulated by DNR.
The facility's original hazardous waste permit application was
submitted to DNR on May 19, 1981. Currently, the facility operates
under the interim status standards promulgated by Louisiana (which are
equivalent to RCRA interim status standards), and additional requirements
imposed by the RCRA amendments of 1984 (Hazardous and Solid Waste
Amendments of 1984, "HSWA"). These operations are now administered by
DEQ. (except for the provisions of HSWA, which are administered by EPA)
The injection well operates under a DNR UIC permit, and is authorized
to operate under RCRA interim status. It also is subject to the provisions
of HSWA. Surface water discharges from the site are regulated according to
State requirements and a Federal National Pollutant Discharge Elimination
System (NPDES) permit.
In order to address the groundwater contamination at the site, the
State Environmental Control Commission (ECC), issued an order on May
12, 1983 requiring the facility to devise a "Remedial Action Plan". The
facility submitted a plan on October 14, 1983. Another order was
issued by ECC on February 29, 1984, which required, in part, that the
facility submit a work plan for determining the extent of contamination
and a complete plan for remediation. On May 29, 1984 the facility
submitted a Revised Remedial Action Plan. This plan was included in
the facility's October 10, 1984 revised permit application.
Three groundwater monitoring programs are in operation at the site.
These are the Compliance Monitoring Program, the Corrective Action Program
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and the Piezometrio Program. Three major pervious zones are monitored
hy these programs. These are the "shallow sands", (in the northeast
corner of the facility), the "50-foot pervious zone", and the "200-foot
sand".
The Compliance Monitoring Program is designed to monitor the "50-
foot pervious zone" and the "200-foot sand" which lies beneath the
"50-foot pervious zone". Some monitoring wells in this program are
also completed on the "Shallow sands", above the "50-foot pervious
zone." The 28 monitoring wells in this program are located primarily
near the facility boundaries and are intended to monitor groundwater
flowing offsite. In all, four wells are completed in the shallow
sands, nineteen are completed in the "50-foot previous zone" and five
are completed in the "200-foot" sand.
The Corrective Action Program began in 1984, in response to the
February 29, 1984 ECC order. The Corrective Action Program is an effort to
clean up hazardous waste .constituents in the groundwater beneath the
facility. The facility intends for this program to supplement the
Compliance Monitoring Program. The Corrective Action Program consists of
ten monitoring wells, six recovery wells, and seven piezometers.
Groundwater is removed from contaminated portions of the "shallow sands"
and "50-foot pervious zone", and is disposed via the onsite injection well.
The Piezometric Program is used to determine groundwater elevations
and flow gradients across the site. A total of 48 piezometers are used
to monitor the three major pervious zones on a monthly basis. From
piezometer data, it has been determined that the general groundwater
flow direction is east in the "shallow sands", and southeast in the
"50-foot pervious zone" and "200-foot sand".
Over 300 borings have been completed at the site (including offsite
borings) to characterize the subsurface. The results of these borings
indicate that the three major pervious zones are in hydraulic communication
even though they are separated by clay layers in most places.
The facility certified compliance with applicable groundwater monitoring
and financial assurrance requirements as required by HSWA on November 7, 1985,
to maintain interim status under RCRA.
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SUMMARY OF FINDINGS AND RECOMMENDATIONS
The findings and recommendations presented in this report reflect the
conditions existing at the facility and practices used by facility
personnel at the time of the Task Force investigation in January 1987.
Subsequent actions taken by the facility, the State, and Region VI since
the investigation are summarized in the accompanying report update.
Significant groundwater contamination has been reported to exist
at the facility since 1982. The primary contaminants reported to exist
are volatile organic compounds such as 1,2-Dichloroethane, Carbon
Tetrachloride, and Chloroform (and a number of other volatile organic
compounds). These contaminants are reported to occur primarily in the
"50-Foot Pervious Zone", and "Shallow Sands" which immediately underlie
the facility, and may approach or exceed concentrations of 1,000 mg/1
in the south-central, and northeast portions of the site (as reported
in monitoring wells MW-36, MW-47, and other wells). Lower levels of
contaminants have been reported in the "200-Foot Sand", which represents
the top of the Chicot Aquifer [the Chicot Aquifer serves as a local
drinking water source, and is a proposed sole Source Aquifer as defined
under the Safe Drinking Water Act]. Levels of certain contaminants
(such as 1,2-Dichloroethane, and Carbon Tetrachloride), however, greatly
exceed the "Maximum Concentration Limit" (MCL) for drinking water
constituents established by EPA. The source and extent of contamination
in the "200-Foot Sand" has not been determined by the facility, and is
under assessment.
Analytical results for groundwater samples taken by the Task Force
closely agree with facility-reported data indicating substantial
groundwater contamination at the site. Due to "gaps" in the facility's
groundwater monitoring system (especially in the "200-Foot Sand"),
however, the extent of the contamination could not be clearly determined.
The Task Force discovered at least two regulatory deficiencies and
two technical deficiencies in the facility's groundwater monitoring program,
These findings, along with Task Force recommendations are presented below.
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Regulatory Deficiencies
1. The facility has not determined the rate and extent of migration of
the hazardous waste or hazardous waste constituents in the ground water
as required hy State and Federal regulations (Louisiana HWR Sec. 23.37(h)(l),
and 40 CFR §265.93(d)(4), and 40 CFR §270.14(c)(4)).
Recommendations:
The facility should immediately verify the extent of contamination
hy performing additional assessment work including the follow tasks:
a) Install a series of monitoring wells of variable depth in the
"zone of interconnection" between the "50-foot pervious zone"
and "200-foot sand". This should include coverage of the area
around borehole L-217 (B-113).
h) Install monitoring wells in the "200-foot sand" near to monitoring
wells in areas of known groundwater contamination. This should
include the installation of monitoring wells in the "200-foot
sand" adjacent to the following monitoring wells and recovery
wells: MW-27, MW-46, MW-45, MW-15, MW-47, MW-35, MW-30, RW-1,
RW-2, RW-3, RW-4.
c) Determine the extent of contamination present in the "200-foot
sand" at MW-39 and MW-41. This should include the installation
of offset, downgradient monitoring wells in the "200-foot sand."
d) The facility should immediately verify the vertical extent of
contamination in the northeast corner of the site. This should
include the installation of monitoring wells in the "50-foot
pervious zone" and "200-foot sand""in the area of monitoring
well MW-36.
e) The facility should attempt to further determine which
contaminants, if any, have migrated offsite. [This is
especially important due to local usage of the groundwater
as a drinking water source.] If possible, this should include
the installation of additional offsite, downgradient
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monitoring wells near the facility boundary.
f) The facility should continue to expand its groundwater
monitoring program until the vertical and horizontal extent
of contamination are adequately defined.
2. The facility reportedly does not routinely use field blanks during
groundwater sampling as specified in the facility's sampling
and analysis plan, as required by regulation.
Recommendations: The facility should ensure that field blanks are
utilized during each sampling event.
Technical Deficiencies
The Task Force noted the following technical deficiencies related
to site hydrogeologic characterization and the facility's groundwater
monitoring program:
1. Monitoring wells are not installed immediately downgradient
of all regulate hazardous waste units for detection of
contaminants.
Recommendations: The facility should install additional monitoring
wells immediately downgradient of the receiving basins, mixing
basins, equilization basin, surface impoundment 7 and landfill
cell 7, in the "50-Foot Pervious Zone" and "200-Foot Sand". Additional
monitoring wells should also be installed immediately downgradient
of landfill cells 1 and 6 to fill gaps in the existing monitoring
system.
2. The facility has not fully characterized the "200-Foot Sand, and
has not fully defined the extent of the "zone of interconnection"
between the "200-Foot Sand and the overlying "50-Foot Pervious Zone".
Recommendations: The facility should implement a boring
program to characterize the "200-Foot Sand" to its full depth.
These borings, however, should not be located in areas of
known contamination. Also, the facility should perform aquifer-
testing (slug tests) of the "200-Foot Sand" to determine insitu
values of hydraulic conductivity and flow rates. The area!
extent of the "zone of interconnection" should also be defined.
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Additional Task Force Recommendations:
1. The facility should commence contaminant recovery at all
existing highly contaminated wells as soon as possible.
Additionally, new monitoring wells that show contamination
may also have to be pumped.
2. The facility should further evaluate the effects of contaminants
on the clay confining layers (ie., dissolution effects, etc.).
3. The facility should continue to search for alternative corrective
action measures for effective site clean-up, and in the interim,
should determine the effectiveness of the existing clay cap
areas to reduce infiltration over contaminated areas.
4. The facility should keep local citizens appraised of this
matter (concerning groundwater contamination) as necessary.
5. The facility should perform additional hydrogeologic studies
of the "shallow sands" and "50-foot pervious zone", and should
further define the hydraulic relationship of these zones
with the Little River.
6. The facility should close the existing basins to minimize
induced head over contaminated areas.
7. The facility groundwater Sampling and Analysis Plan should be
modified to include procedures for sampling immiscible layers.
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TECHNICAL REPORT
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INVESTIGATION METHODS
The Task Force evaluation of the CECOS site consisted of:
0 Review and evaluation of records and documents
from EPA, DEQ, DNR, USGS, and CECOS;
0 An onsite sampling inspection, including
interviews with site personnel, conducted
from January 12 to January 21, 1987
0 Subsequent analysis of groundwater and
leachate sampling results
Records and documents from EPA Region VI and DEQ offices, compiled
by an EPA contractor, were reviewed prior to the onsite inspection.
Onsite facility records were reviewed to verify information currently
^
in Government files and to supplement this information where necessary.
Selected documents requiring in-depth evaluation were copied by the
Task Force during the inspection. Records were reviewed to include
evaluation of facility operations, construction of waste management
units, and groundwater monitoring activities.
Specific documents and records reviewed and evaluated included the
ground-water sampling and analysis plan, the facility's "Revised Remedial
Action Plan" (RRAP), which is the facility's equivalent to a ground-
water quality assessment program, analytical results from past ground-
water sampling, monitoring well construction data and logs, site geologic
reports, site operations plans, facility permits, unit design and
operation reports, and operating records showing the general types and
quantities of wastes disposed at the facility. Also, an inventory of
water wells within a 2-mile radius of the facility (from the facility's
October 10, 1984 permit application) was examined. The water well
inventory indicated that at least three drinking water wells exist in close
proximity to the facility, and a total of around 65 wells exist within
a 2-mile radius of the facility (most of these residences, however, are
connected to a Public Drinking Water Supply System).
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The facility inspection included identification of waste management
units, identification and assessment of waste management operations and
related practices for ground-water protection, and verification of
location of groundwater monitoring wells and leachate collection/detection
systems. Also, a "walk-through" visit of the facility's onsite laboratory
was performed.
Company representatives were interviewed to identify records and
documents of interest, (and answer questions about them) and to discuss
facility operations (past and present). The principal facility contacts
were Mr. Austin Arahie, site manager, and Mr. Richard Coons, Environmental
Affairs, BFI-Houston. Topics discussed during the interviews included,
(1) waste disposal practices, (2) site hydrogeology, (3) groundwater
monitoring system rationale, (4) the effectiveness of the existing
corrective action program, (5) the groundwater sampling and analysis
plan, (including sample handling and document control) and (6) laboratory
procedures for obtaining data on groundwater quality.
EPA's National Enforcement Investigation Center (NEIC) conducted
an in-depth multi-media investigation (including laboratory audits) at
the facility during December 1985. The report covering the NEIC investigation
was finalized in May 1987, and was used in the preparation of the Groundwater
Task Force report.
During the onsite inspection, the Task Force collected ground-
water samples from selected ground-water monitoring wells and from a
landfill leachate detection system. These samples were subsequently
analyzed for RCRA Appendix IX hazardous waste constituents. Also,
field measurements and samples for volatile organics were taken from
selected piezometers. All samples were taken by an EPA contractor and
sent to EPA contract laboratories for analysis. Splits of all samples
were provided to CECOS. Data from sampling analysis were reviewed for
the presence of hazardous waste constituents.
The procedures used by the Task Force followed the EPA "Hazardous
Waste Groundwater Task Force Protocol for Groundwater Evaluations"
(1986), and the EPA "RCRA Sroundwater Monitoring Technical Enforcement
Guidance Document" (1986). (See: "Task Force Sample Collect and Handling
Procedures"). These procedures included the use of individual log
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books to record information obtained in the field, or in the facility's
office during interviews with site personnel. No photographs were
taken by the Task Force, however much of the Task Force activities were
recorded by the facility on videotape.
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WASTE MANAGEMENT UNITS AND OPERATIONS
Hazardous waste management operations at the site were begun by
Mud Movers, Inc. in 1968. Various industrial liquid wastes from local
sources, including oil field production wastes (drilling muds and
brines), petrochemical and refinery wastes and other organic and
inorganic by-product material were stored in surface impoundments. The
impoundments covered about 27 acres of the site and ranged from about 6
to 8 feet in depth. These units were constructed by excavating a trench
around the inside perimeter of the impoundment and piling the excavated
material just outside the trench to form a dike. There was minimal bottom
preparation and compaction. Seven surface impoundments (numbers 2
through 8; number 1 never existed) were constructed for waste storage
between 1968 and 1972. Two additional ponds (9 and 10) were also
constructed during this time to hold contaminated rainwater runoff.
In September 1972, BFI Chemical Services, Inc. acquired the facility
from Mud Movers, Inc. Engineering studies were then undertaken to
upgrade the site. From these studies, the decision was made to dispose
of the impounded liquids by deep well injection (or other means) and
solidify the remaining sludges with cement kiln dust. Also, secure
landfills were proposed to be constructed as part of the plan to upgrade
the facility.
During November 1975, BFI received approval from the State to
convert an oil-production well to a waste-disposal well. The well was
completed for injection in August 1976 and subsequently began operations.
An underground Injection Control (UIC) permit for the well was issued
by the State on October 24, 1985. (#WD-85-10) to inject wastes at around
lOOgpm to a depth of around 4200 feet. [This permit is not a "permit
by rule" under RCRA unless the requirements under Section 3004(u)
("Corrective Action") of RCRA are met and a final RCRA permit is issued
to the facility. In the mean time, the well retains "interim status"
under RCRA].
Approval of the solidification and landfill construction plan was
approved by the State in November 1977. Between 1977 and 1982 BFI
proceeded to close the surface impoundments (except pond 10, which was
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in operation until early 1983), and constructed seven landfills (an eighth
landfill was constructed in 1983 but has not been used). Each landfill
was constructed with a five-foot thick recompacted clay liner, and a leachate
collection system. The final phase of landfill cell 7 also contains a
secondary leachate detection system. The facility disposes of collected
leachate via the injection well on an intermittent basis.
Closure of each cell (not RCRA-certified closed), as described by
NEIC was as follows:
Cell 1: Closed before 1980. History of disposal is not certain and
grid sheets were reconstructed after the fact. The cell had five lifts
and four quadrants. The waste buried in the cell described as: "from
pit 2, solidified sludge, lead asbestos and PPG waste - 42 barrels."
Only one grid sheet was in the files. The cell was capped with clay as
disposal was completed. Clay from other cell excavations was stockpiled
on the capped cell.
Cell 2: Closed before 1980. History of disposal is not certain and
grid sheets were reconstructed after the fact. The cell had six lifts
and four quadrants. The cell received wastes .from BFR Lake Charles and
Port Arthur. Only one grid sheet was in the files. The cell was
capped with clay as disposal was completed. Clay from other cell excavations
was stockpiled on the capped cell.
Cell 3: Closed before 1980. Active life was from October 17, 1979 to
December 11, 1979. The cell had two lifts and four quadrants. Beginning
with the second lift, the sketch of the burial area had dates and some
generator names. Solidified sludge from pond 8 was recorded on the
sketch for cell 3 as having been landfilled. The file contained five
grid sheets, mostly all filled in for manifest cross-reference and
quantity purposes. The cell was capped with clay as disposal was completed.
Clay from other cell excavations was stockpiled on the capped cell.
Cell 4: According to the 27 grid sheets in the file the active life
was from December 17, 1978 to July 14, 1980. The cell had five lifts
and four quadrants. The site chemists completed the grid sheets in the
laboratory; information was not written in the disposal logs or grid
sheets at the cell as disposal was completed. The chemists would either
obtain the information from landfill personnel or would go to the cell
-17-
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-18-
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to locate the disposal area. The cell map was also drawn by the chemist.
The grid sheets were complete with required information, however, the
grid sheets were not checked to determine if all incoming loads had
been recorded in the disposal logs. The cell was with clay as disposal
was completed.
Cell 5; Also known as 4a and 4 extension. According to the 46 grid
sheets in the file, the active life was from July 15, 1980 to January
17, 1981. While cell 4 was being filled with wastes, the Company
decided to extend the south end of cell 4 rather than lose the area for
disposal to the wall space. The cell was first designated 4a, then 4
extension and finally 5. The grid sheet records have 4a noted on them.
The cell had seven lifts and four quadrants. The Company filled lifts
1 through 4 in the northeast quadrant first, then used the remaining
quadrants before using the northeast quadrant again. In October 1980,
material was placed into "pit 7" which was in the west end of pond 7.
The waste, from the BFI Nederlands, Texas transfer station, was solidified
in pit 7 and then transferred to cell 4a. The site personnel stated
that the waste was transferred to 4a, but can't locate it within the
cell; the solidified waste may have been stockpiled before it was
buried. (The grid sheets for cell 6 show wastes stockpiled on the west
end of pit 7). The grid sheets were not complete; entries for quadrants
and lifts were sometimes left blank; however, the cell sketches show
dates, quadrants and lifts. The cell was capped with clay.
Cell 6: According to the 81 grid sheets in the file, the active life
was from January 16, 1981 to December 4, 1981. The last waste put into
the cell was from the stockpile at pit 7. Cell 6 was approximately 600
feet long by 150 feet wide, resulting in four quadrants of 300 feet by
75 feet; there were seven lifts used for disposal. For cell 6, the
Company began using new grid sheets which referenced the generator manifest
number, as required by the Louisiana HWMP. Wastes were stockpiled on top
of cell 6 on quadrants 3 and 4 according to the cell sketches in the file.
Cell 7: According to the 171 grid sheets in the file, the active life
was from December 3, 1981 to April 4, 1983. Cell 7 was constructed in
3 phases from north to south. Each phase had four quadrants and seven
lifts. The waste disposal in phases II and III began June 1, 1982 and
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January 20, 1983, respectively. Only phase III had a leachate detection
system. The cell was capped with clay; waste material was stockpiled
on top to line the bottom of the phase II area with stockpiled wastes.
It was reported by Company personnel that markers were not used in
cells 1 through 5 to locate quadrants or lifts. Flags were used in
cells 6 and 7 to identify quadrants.
After liquids from the impoundments were deep well injected (or
drained through surface outfalls: 9 and 10) the remaining oils and sludges
were solidified inplace with kiln dust. Solids from impoundment 2 and
impoundment 8 were disposed in landfill Cells 1, 2, and 3. Solids from
lagoon 7 were disposed in landfill Cells 6 and 7. The remaining solidified
materials in impoundments 3, 4, 5, 6, and 9 were left in place and capped
with clay. No solidification procedures were performed at impoundment
10. The history of impoundment (pond) closure is summarized as follows:
Pond 2: Closed before 1980. Solidified material transferred to landfill
cells 1, 2 or 3. The area where pond 2 was located became landfill cell 8.
Pond 3 and 4: Closed in October 1981. Ponds 3 and 4 became one large
"L" shaped pond in 1980. Solidified material was left in ponds 3 and 4
and both were capped with stockpiled clay.
Pond 5: Closed prior to July 1980. Solidified material was left in
place and the pond was capped with stockpiled clay.
Pond 6; Closed in 1981. Some material was solidified and transferred
to landfill cell 6 or 7 and the rest was solidified in place. The pond
was capped with stockpiled clay.
Pond 7: Closed in 1981-1982. Solidified material from the eastern
portion of pond 7 was transferred to landfill cell 7; the remaining
material was solidified and transferred to cell 6. Landfill cell 7 was
constructed at the location of pond 7 but covers more area.
Pond 8: Closed before 1980. Solidified material transferred to landfill
cell 3 and possibly to cells 1 and 2. Landfill cell 7 overlaps the
northern part of pond 8.
Pond 9: Closed in 1982. Material solidified in-place and capped.
Pond 10: Drained in February 1983. Excavation still exists.
The ponds were not discussed in the April 28/1981 closure plan (or in
subsequent closure plans), although ponds 3, 4, 7, 9 and possibly 6
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were closed after that date. The regulations require that these units
be closed as landfills.
To support the landfill operations for wastes coming from offsite,
six mixing basins with an approximate capacity of 700 cubic yards each were
constructed. These basins were constructed in natural soil and were
unlined. The basins were used to solidify liquid and semi-liquid wastes
for landfilling by mixing wastes with cement kiln dust.
To support the injection operations, two receiving basins (known
as the north and south receiving basins) and an equalization basin were
constructed in 1979. Liquid wastes are transferred from the receiving
basins to the equalization basin and then to the injection well. The
construction of these basins is summarized as follows:
North Receiving Basin: 650 feet long by 35 feet wide by 6 feet deep
(including 2 feet of freeboard), capacity of 680,000 gallons. The basin
originally had a 4-foot clay liner. It now has a 5-foot clay liner
which was constructed in June 1982 after the basin was cleaned out.
South Receiving Basin: 650 feet long by 50 feet wide by 10 feet deep
(including 2 feet of freeboard), capacity of 1,900,000 gallons; operating
capacity limited to 950,000 gallons by BFI. The basin has a 4-foot
clay liner.
Equalization Basin: 650 feet long by 250 feet wide by 12 feet deep
(including 2 feet of freeboard), operating capacity approximately
12,000,000 gallons. The basin has the 3-foot original clay liner.
The landfilling of wastes ceased on April 4, 1984, after the
discovery in 1982, of groundwater contamination (associated with the
pervious surface impoundments) and issuance of a major compliance order
on May 12, 1983 by DNR (although the closure order was overturned by the
Louisiana Supreme Court on April 1, 1984, the facility decided to
discontinue landfill ing operations). Cell 8-remains open and is not
planned to be used. The six mixing basins ceased operations in December
1983, and remain open.
Currently, the injection well and the three basins associated with
it (the two receiving basins and the equalization basin) are the only
hazardous waste management operations at the facility. The facility
plans the continued commercial use of the injection well and plans to replace
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the associated basins with above-ground tanks. The facility utilizes
the BFI/CECOS Livingston, LA facility for wastes or waste containers
(non-liquids) to be landfilled. It receives contaminated rainwater
from the Livingston site for deep-well disposal.
The incoming waste is sampled and analyzed to verify the manifested
waste description and to determine compatibility with other wastes
received. The waste is then emptied into one of two receiving basins
located at the north-central portion of the site (pH adjustment basins,
Figure 2). These two basins were constructed in 1979, with four-foot
clay liners. The northernmost of the two basins was rebuilt in 1982
with a clay liner of five feet.
In the receiving basins, oil and sludge are allowed to separate
from the aqueous phase of the waste. The aqueous phase is then pumped
into the equalization basin for further clarification before disposal by
deep well injection. Oil that accumulates on the equalization basin is
collected and returned to the receiving basins. The receiving and
equalization basins were dredged one time, and the sludge was placed
into landfill cell No. 7, which has subsequently been closed.
According to a permit application filed with the Louisiana Department
of Natural Resources, Injection and Mining Division, the disposal well
at the BFI site was originally a "wildcat" petroleum well drilled in
1958 by Delta Drilling Company of Lake Charles, Louisiana. The original
borehole was drilled to a depth of 8,797 feet and plugged with cement
back to 6,533 feet. The well was fitted, from 2,527 feet to the bottom,
with a seven-inch OD casing. The surface casing is 10.75-inch OD and
set at 2,554 feet. The petroleum well was modified to be a disposal
well in 1976 by completion of the disposal interval at a depth of
4,490 to 4,610 feet. The original injection interval was perforated in
the 7-ioncjh OD casing with 480 glass jets (35 gram shots), 4 shots per
foot. The injection interval was completed as a screen/liner gravel
pack completion. A 3.5" OD, 0.020-inch slot screen was set inside the
7" protection casing from 4436 to 4628 feet. In 1984, the well was
further modified to be used for injection at zones of 4,120 to 4,220
feet and 4,255 and 4,295 feet by perforating the seven-inch casing
through these zones. A cement retainer was set at 4,320 feet and the
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lower zone was abandoned hy placing acid resistant cement from 4,300 to
4,620 feet. A 3.5-inch, stainless steel screen liner was installed
from 3,997 to 4,280 feet. The 3.5-inch fiberglass injection tubing was
installed and pressure tested for leaks. The well was put hack into
operation on May 30, 1984. Pre-injection units include sand filters,
cartridge filters, and a 10,000 gallon surge tank.
Two additional basins, one for rainwater collection and one for
the facility's septic tank effluent, (oxidation pond) also exist at the
site. These basins are located in the south-central portion of the site.
The septic tank effluent and contaminated rainwater are disposed
via. the injection well. "Uncontaminated" rainwater is discharged from
the facility through three outfalls under the requirements of an NPDES
permit (#LA58882) issued to the facility on September 30, 1986, and
applicable State requirements. The outfalls are located in the
northwest, northeast, and southeast corners for the facility.
The location of all units (past and present) is shown in Figure 2.
The following is a list of general types and amounts of wastes received
at the facility (BFI, 1984 Part II Permit Application ):
Category I
(Category I hazardous wastes are chemicals and process waste streams
whose hazardous nature has been prescribed by prior determination
(as defined hy LHWR)
Hazardous waste nonspecific sources (F wastes)
Hazardous waste specific sources (K wastes)
Acute hazardous wastes (P wastes)
Toxic wastes (U wastes)
Mixture of Category I wastes
Category II
(Category II hazardous wastes are wastes which are ignitable,
corrosive, reactive, or toxic.)
Ignitahle (D001)
Corrosive (D002)
Reactive (D003)
EP Toxic (D004 - D013)
Mixture of Category II wastes
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Based on the results of various onsite and offsite studies (including
Organic Vapor Analyzer (OVA) surveys), contamination has been reported
in the upper 20 to 25 feet of soils and groundwater in the northeast
corner of the facility, and is found to around 50' deep in other portions
of the site. Contaminants have entered the "50-foot pervious zone"
beneath the site, and may have entered the "200-foot sand" (see "Site
Hydrogeology"). These contaminants are reported by the facility
to have originated from the previously used unlined surface impoundments,
and consist primarily of oily wastes and volatile and base-neutral
extractable compounds.
• The most prevalent contaminants found at the site include volatile
organics such as 1, 2-Dichloroethane, 1, 1-Trichloroethane, Chloroform,
Carbon Tetrachloride and others. In places, contaminants are present
at very high levels (e.g., 1-2-Dichloroethane at levels greater than
1,000 mg/1). Highest levels of contamination are reported in the
northeast, and south-central portions of the site, and correspond
generally to the area which contained the unlined surface impoundments.
As reported by the facility, over one million cubic yards of soil and
sixteen million gallons of groundwater are estimated to be contaminated
(May 1986 Supplementary Site Assessment Report; Reference Number 8).
During the operation of the surface impoundments, a condition of
"hydraulic loading" existed. The hydraulic head induced by the presence
of the standing liquids created a force for downward movement for the
liquids. This force was eliminated when the impoundments were drained
(except for the landfill cell 8 excavation which remains open and collects
rainwater). The potential for contaminant movement, however, may have
increased since the contaminants have entered the "shallow sands" and
"50-foot pervious zone", and entered the "200-foot sand" (the facility
is currently in the process of mitigating contamination in the "shallow
sands" and the "50-foot pervious zone" through a groundwater recovery
program).
As previously stated, subsurface contamination at the site is
reported to occur in two primary phases: a dense, oily phase and a
phase in solution with the groundwater. The mobility of the phase in
solution is much greater than the dense, oily phase due to viscus and
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attenuative forces. As a result, portions of the phase in solution
(such as chloride) may have migrated offsite, while oil phase contaminants
may not have migrated offsite.
No groundwater contamination from the landfill ing operations, or
active surface impoundments has been reported by the facility. However,
there may be insufficient monitoring around these units to determine if
a release has occurred (see: "Groundwater Monitoring During Interim
Status"). Also due to the existing contamination, it may be difficult
or impossible to determine if these units are leaking.
An investigation to determine whether the injection well had
contribution to groundwater contamination at the site was ordered by
DNR on April 1, 1985 (Compliance Order No. UIC85027). This order
required the facility to demonstrate that the well had not and would
not contribute to contamination and suspended the authorization to
inject pending a final determination. In response, CECOS submitted a
"Conservation Monitoring Plan" which was subsequently approved by DNR.
The plan called for the installation of a monitoring well in the lowermost
fresh water (<10,000 TDS) aquifer overlying the injection zone (at
around 1,100 feet deep). Analytical results of groundwater samples
taken from the well (known as MW-50) were reviewed by DNR, and appeared
to show no evidence of waste contamination. Based on the results of the
investigation, the order was modified on June 25, 1985 to allow resumption
of injection activities.
The granted authority continued until the UIC permit was issued on
October 24, 1985. A review of the injection well by LDEQ and the EPA
Region VI Water Management Division during September 1987 also indicated
that the well had not contaminated groundwater at the site above the
disposal formation.
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SITE HYDROGEOLOGY
The CECOS site lies within the Gulf Coastal Plain Province, on a
structural feature known as the Gulf Coast Geosyncline. This trough-
shaped feature has been developing since early Cretaceous time. In
places, many thousands of feet of alternating sand, silt and clay beds
have been deposited as subsidence occurred. As a result, these beds
dip gently (usually 5 to 15 feet per mile) to the south, and thicken as
they.approach the Gulf. Groundwater flow tends to conform to the
stratigraphy and is also in a southerly direction.
Regionally, faulting associated with subsidence is not uncommon.
The nearest confirmed fault to the CECOS site, is two miles to the
south along the Houston River. The presence of a suspected fault
beneath the site has been refuted in a recent report by the Louisiana
Department of Natural Resources which concerned a deep-well study of
the lowermost fresh water aquifer (DNR 1985).
As reported by the facility, beneath the site are deposits of
Pleistocene and Holocene (Recent) age. The Holocene deposits consists
of a thin veneer of sands, silts, and clays layed down by the Calcasieu
River and its tributaries. The Pleistocene deposits consist of five
distinct formations. In order of increasing age these are the Prairie,
Montgomery, Bentley, Williana, and Citronelle formations. The Montgomery,
Bentley, and Williana formations are members of the Chicot Aquifer
System of southwest Louisiana that serves as a major drinking water supply.
The Prairie Formation is composed of a deltaic sequence characterized
by occasional five gravels at its base, fining upward to sands, silts,
and clays. At the site, it is expressed geomorphologically as a terrace.
Here, tan and light gray clays are generally found to 40 or 50 feet
below ground surface. Red clays and silts of the Beaumont Terrace
merge with these clays in the west portion of the site. The clays are
generally stiff and contain silty stringers and sandy silt lenses in
places. Small interconnecting and non-interconnecting fractures are
commonly found throughout this formation. A pervious zone called the
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"50-Foot Pervious Zone" underlies the surficial clays. This zone
consists of silt and clayey silt with some layers of silty sands and
sands. This zone ranges from a maximum of about twenty feet thick in
eastern portions of the facility to only a few feet thick in western
portions of the facility. Beneath the 50-Foot Pervious Zone throughout
most of the facility (except for the SE portion of the site) is a clay
aquitard which may range to 20 feet in thickness. Where present, this
clay layer separates the "50-Foot Pervious Zone" from the underlying
Montgomery formation. As shown by boring logs however, this separation
does not prevent downward groundwater movement through small fractures
from the "50-foot pervious zone to the Montgomery Formation. The horizontal
component of groundwater flow in the "50-foot pervious zone" is to the
southeast.
The Montgomery formation, also known as the "200-foot sand", contains
the uppermost sand unit of the Chicot Aquifer System. It is found at
the site at approximately 80 to 100 feet below grade and extends to
approximately 150 to 160 feet. It is composed mainly of fine to medium
sand, is continuous across the site, and is used as a drinking water
source within a two-mile radius.
At about 250 feet beneath the facility the "500-foot sand"* is
encountered. This is the middle unit of the Chicot Aquifer System, and
is known as the Bentley formation. This aquifer serves as a major
drinking water source locally, and for the City of Lake Charles.
The lowermost member of the Chicot Aquifer System is the Williana
formation. This formation is also known as the "700-foot sand"* and is
found at a depth of about 600 feet beneath the facility. This aquifer
also serves as a drinking water source.
Each member of the Chicot Aquifer System is separated to some degree
from the other by layers of clay and silty clay. These clay layers
serve to limit, hydraulic communication but do not prevent vertical
groundwater movement between the members. Generally, vertical flow is
limited between the "500-foot sand" and the "700-foot sand", and occurs
*The depth implied in the name refers to the depth below land
surface of the base of the formation at Lake Charles.
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in a downward direction from the "200-foot sand" to the "500-foot
sand". The horizontal components of groundwater flow in the Chi cot
Aquifer System tends to be to the southeast.
The Citronelle formation is found beneath the Chicot Aquifer
System. This formation (and, the formations beneath it) is assumed to
be remote from the hydrogeologic, regime of concern, and is not
considered in this discussion.
An exception to the generalized sequence that has been discussed
is found in the northeast corner of the facility. Here, layers and
lenses of clayey and silty sand a few feet thick are found to depths of
around 25 feet. These sands interfinger with the surficial clays and
are referred to jointly as the "shallow sands". This zone is in hydraulic
communication with the underlying "50-foot pervious zone" and has an
easterly groundwater flow direction (toward the nearby river).
Due to the highly variable nature of the deposits from the surface
to the "200-foot sand", it would be difficult to calculate meaningful
values for downward flow velocities without conducting a pump test in
the "200-foot sand". This is because true values of permeability vary
widely, and the influence of secondary permeability (especially in
the clay confining layers) will have a significant effect on actual
rates of downward groundwater movement. To date, no full pump test has
conducted in the "200-foot sand" at the facility (note: any decision
to conduct a pump test in the "200-foot sand" should take into
consideration the risk of accelerating the movement of contaminated
groundwater from the "50-foot pervious zone" to the "200-foot sand").
Due to the discontinuous nature of "shallow sands" and the "50-
foot pervious zone", water level readings in these zones may not always
be reliable. This is because relatively isolated lenses of silts or
sands may be encountered that may not reflect the potentiometric surface
of adjacent zones that have areal hydraulic communication. Water level
readings in the "200-foot sand" are probably more reliable due to the
relative continuity of the formation. In either case, water level data
is probably of sufficient accuracy to reflect general gradients. It
should be realized, however, that groundwater flow paths may riot always
be normal to equipotential lines due to preferential flow around lenses
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nf clay and silty clay. This is an especially important consideration
in the "shallow sands", and "50-foot pervious zone".
Seasonal fluctuations in water level readings of several feet are
noted for many wells (up to 9 feet in some piezometers). These fluctua-
tions are influenced by seasonal precipitation patterns and river
stages of the nearby West Fork Calcasieu River. This indicates a
degree hydraulic inter-connection between the shallow, permeable zones
and river. As a result, water level readings in piezometers surround
pumping wells must be adjusted for these variations in order to adequately
assess aquifer response to pumping.
The facility reports that the "50-foot pervious zone" and the "200-
foot sand" are hydraulically connected in the southeast portion of the
site as shown in Appendix C. This is supported by piezometric data and
borehole logs (especially in the area of L-217 and L-63) and may indicate
that the "200-foot sand" is also part of the uppermost aquifer at the
facility (the facility considers the "50-foot pervious zone" as the
uppermost aquifer.) The actual areal extent of the zone of interconnection
nay be larger than indicated by the facility, and may underlie areas of
contamination.
The vertical groundwater flow direction is reported to be downward,
except perhaps near recovery wells. The flow direction of any constituents
in the groundwater, however, would depend on relative densities (contaminant
vs. groundwater) as well as flow forces. Therefore, if gravitational
forces due to relative density are greater than flow forces, it is
possible that "heavy" constituents in the groundwater could move downward
even if groundwater flow was upward. This is an important consideration
due to the fact that dense-phase contaminants (e.g., 1, 2-Dichloroethane)
are found in the "50-foot pervious zone" (MW-27 and MW-47) near the
zone of interconnection with the "200-foot sand". This could allow
contamination to sink into the "200-foot sand" through the connecting
zone even if an upward groundwater flow direction was indicated. (The
facility does not have any monitoring wells in the "200-foot sand" in
the zone of interconnection).
Also, cross-section prepared by facility consultants indicate minimal
separation between the "shallow sands", "50-foot pervious zone", and
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"200-foot sand" in the northeast corner of the site. This could provide
a pathway for contaminants to migrate downward to the "200-foot sand".
Values for hydraulic conductivity and flow rates at the site have
been estimated in various reports prepared by the facility and its
contractors. These values range widely, even within a given zone, but
are within the range of expected values for sediments of the Gulf
Coastal Plain. The actual values for the clays at the site however,
may be greater than indicated by the facility (> 10"7 cm/sec). This
is because the clays contain fractures that may greatly increase the
amount of fluid they can transmit. This position is supported by the
fact that contaminants have penetrated to a depth of 40 feet or more in
places (to the "50-foot pervious zone"). This is probably deeper than
can be accounted for without the influence of fractures. Similiarly,
the clays may not serve to effectively isolate the "200-foot sand" from
the contamination in the "50-foot pervious zone". Table 1 summaries
selected values of hydraulic conductivity obtained by the facility.
TABLE 1
SUMMARY OF FACILITY HYDRAULIC CONDUCTIVITY STUDIES
Slug Tests Summary
MW-2R
MM -19
MWr20
MW-21
MW-23
MW-15
MW-32
MW-30
PT-1
Shallow Zone
Shallow Zone
50' Zone
50' Zone
50 'Zone
Bailer Tests
50' Zone
50' Zone
24-hour Pump/Recovery
Shallow Zone
50' Zone
K = 9xlO~5 cm/sec
K = 7x10"; cm/sec
K = 8x10"? cm/sec
K = 4x10"; cm/sec
K = 4xlO"3 cm/sec
Summary
K = 6xlO"J cm/sec
K = 8xlO"4 cm/sec
Tests Summary
K = 2xlO-J cm/sec
K = 5xlO"4 cm/sec
-30-
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2
Transmissivity values are reported to range from 17ft /day to
45 ft2/day in the "50-foot pervious zone". The facility has relied on
average published values for determining hydraulic conductivity and
transmissivity values for the "200-foot sand". These values are 53 ft/day,
and 4,280 ft /day respectively. Flow velocities are on existing hydraulic
gradients and hydraulic conductivity are reported to range from 0.02 ft/day
to 0.4 ft/day for the "shallow sands", 0.003 ft/day to 0.6 ft/day for the
"50-foot pervious zone", and 0.07 ft/day for the "200-foot sand".
The facility has not fully characterized the "200-foot sand" to
its lower boundary beneath the site. Extensive characterization of the
uppermost aquifer to the top of the "200-foot sand" has been conducted
by CECOS and its consultants. This has included data obtained from 257
borings that depict subsurface materials, as well as groundwater quality
and potentiometric level data obtained from numerous monitoring wells
and piezometers. The information gathered by the facility is generally
adequate to define the hydrogeologic regime beneath the site, though
additional information may be needed concerning the area! extent of the
"zone of interconnection" between the "50-foot pervious zone" and the
"200-foot sand", and the degree of separation provided by the clay aquitard
separating these zones. Also, the potential for other nearby zones of
interconnection to exist offsite, in a downgradient direction, should
be evaluated in the context of contaminant pathways to the "200-foot sand".
In order to check for volatile organic contaminants in the subsurface,
the facility performed OVA surveys on a number of onsite and offsite
borehole "soil" samples during 1985. For samples with OVA readings
exceeding 10 ppm, a field GC was run to provide an indication of contaminants
present, and selected samples were sent to a laboratory for characterization.
Soil samples with OVA readings of less than lOppm were considered to be
uncontaminated. The facility has utilized this criteria (and groundwater
monitoring results) to delineate the general extent of contamination
present at the site. These procedures (and groundwater monitoring results)
have not indicated the presence of any appreciable offsite contamination.
However, these procedures are not adequate to determine the full extent of
contamination in the groundwater (See: GROUNDWATER MONITORING DURING INTERIM
STATUS).
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The facility has installed monitoring wells in most areas where
contamination has been indicated by OVA readings, except in the "zone of
interconnection". In the "zone of interconnection", OVA readings of
over 1000 ppm were reported in clay to a depth of 36 feet in borehole
1-217 (also known as B-113). Beginning at a depth of 42 feet, the log
of this boring shows sandy silts and silty sands to a depth of 75
feet where the "200-foot sand" is encountered. This clearly indicates a
potential for downward migration of contaminants to the "200-foot sand".
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GROUNDWATER MONITORING DURING INTERIM STATUS
Prior to interim status, the facility operated a groundwater
monitoring program to fulfill the requirements of the Louisiana Hazardous
Waste Management Plan (HWMP) [August 1, 1979 - November 19, 1980]. The
State amended the HWMP on September 5, 1980 so that it was compatible
with EPA hazardous waste management regulations promulgated on May 19,
1980. From November 17, 1980 to December 19, 1980, the facility was
subject to Louisiana interim status regulations contained in the HWMP
and EPA interim status regulations. On December 19, 1980, Louisiana
was authorized to administer and enforce the interim status provisions
of RCRA including applicable groundwater monitoring requirements.
Additional monitoring wells were added at the site following
interim status. Also, the facility began to monitor for organic priority
pollutants on a quarterly basis. In 1982, groundwater contamination was
detected in the northeast corner of the site (MW-2). As a result, the
Environmental Control Commission (ECC) issued an order on November 16,
1982 requiring installation of additional specified monitoring wells in
the "first continuous, more permeable, stratum in which horizontal
movement occurs" to investigate the areas of contamination. The order
also required the installation of leachate detection systems under all
landfill cells under construction or constructed in the future. In
response, the facility submitted a "Waste Disposal Site Evaluation"
report dated February 14, 1983.
On May 12, 1983, the ECC issued a major compliance order requiring
additional detailed hydrogeologic investigations, and a remedial action
plan. Also, landfilling operations were ordered to cease by December
31, 1983 (due to legal actions, landfilling operations were not
completely terminated until April 1984). During the last half of 1983,
DNR conducted various inspections of the facility and adjacent areas to
observe monitoring well sampling, including offsite citizen wells
(citizen interest had increased by this time and Law Engineering
Consultants was contracted by a citizen's group to perform an evaluation
of site conditions). On October 14, 1983, the facility submitted an
"Additional Investigation and Remedial Plan Development".
-33-
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On February 29, 1984, the ECC found the facility in violation of
the May 1983 order and issued a Findings of Fact Compliance Order and
Schedule. The February 1984 Order required in part that the facility
submit a work plan for determining the extent of contamination with a
complete plan for remediation. Also, the facility was required to
initiate recovery of contaminated groundwater from the "50-foot pervious
zone". The work plan was submitted to DEQ on March 28, 1984 and approved
in a letter dated April 4, 1984.
On May 29, 1984, the facility submitted a "Revised Remedial Action
Plan". This plan specifically addressed the February Order and was
included in the Part II permit application dated October 10, 1984. It
included information gathered through additional site investigations
and formed the basis for the facility's corrective action program.
This report serves as the facility's groundwater quality assessment plan.
Other reports submitted by the facility include a potential public
"Exposure Information Report", August 8, 1985 (as required by the
Hazardous and Solid Waste Amendments of 1984), a "Site Assessment Report",
March 3, 1986, and a "Supplemental Site Assessment Report", May 1, 1986.
In all, over 20 reports pertaining to site hydrogeology and the facility's
groundwater monitoring program have been submitted to the State since 1977.
The following is a summary of the current groundwater monitoring
program at the facility. The information is based on the findings of
the December 1985 NEIC investigation, and the January 1987 Task Force
evaluation.
GROUND-WATER MONITORING PROGRAMS
The Lake Charles facility operates three ground-water monitoring
programs according to the Part II permit application (Appendix D). These
programs are the Compliance Monitoring Program, Corrective Action Program
and Piezometric Levels Program. Figure 3 depicts the locations of monitoring
wells designated for each program. These programs are designed for compliance
with Section 18.3 of the Louisiana Hazardous Waste Regulations (HWR).
-34-
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Compliance Monitoring Program
The Compliance Monitoring Program is intended to monitor the "50-
foot pervious zone" which BFI/CECOS considers to he the uppermost
aquifer at the facility, and the "200-foot" sand. The program also
includes monitoring shallow sands present in the northeast corner of
the site. The facility has submitted analytical groundwater monitoring
results to the State since 1982. Summary results for the fourth quarter
of 1986 are shown in Appendix B.
. The monitoring wells in this program are located primarily near
the perimeter of the entire waste management area which includes former
landfills and surface impoundments. All the perimeter locations are
intended to monitor ground water flowing offsite from beneath past and
present waste disposal units.
There are twenty-eight monitoring wells, (designated as "MW"), that
compose the compliance monitoring system. Of these, four are completed
in the shallow sand, nineteen are in the "50-foot pervious" zone and
five are in the "200-foot" sand. The facility has least one upgradient
well in each of the pervious zones, and has been collecting. The upgradient
wells are MW-7 and MW-49 ("shallow sands"), MW-25, MW-14, MW-23, MW-24R,
MWL-34, MWL-37, MWL-40, and MW-48 ("50-foot pervious zone"), and MW-33
("200-foot sand"). The facility data indicates that some upgradient
wells (such as MW-48 and MW-49) have shown levels of 1,2-Dichloroethane
above the MCL. [This may he due to mounding from the previously used
surface impoundments which resulted in a temporary flow reversal].
Facility data indicates the presence of organic hazardous waste
constituents in the "shallow sands", "50-foot pervious" zone" and the
"200-foot" sand at the site. BFI/CECOS implemented a program to locate
and define the extent of the contaminant plume, in the "50-foot pervious
zone" and "shallow sand zone" and to identify the hazardous waste
constituents in the groundwater. The results of the investigation are
in the May 1984 "Revised Remedial Action Plan." The investigation of
site contamination resulted in the development of numerous clean-up
alternatives. BFI/CECOS, with informal agreement from the State, began
-36-
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a corrective action program. The facility has not verified the extent
of contamination in the "200-foot sand", and has not located monitoring
wells beneath areas of known contamination to check for contaminants
(see Figure 6).
Corrective Action Program
The Corrective Action Program began in 1984, in response to the
February 29, 1984 order. The Corrective Action Program is an effort to
clean up hazardous waste constituents in the groundwater beneath the
facility (Table 2). BFI/CECOS intends for the Corrective Action Program
to supplement the Compliance Monitoring Program. As previously stated,
the corrective as program is currently confined to certain areas of
known contamination, which are all onsite.
As of January 1987, there were ten monitoring wells and six recovery
wells in the Corrective Action Program. Seven piezometers installed
near the base of the "50-foot pervious" zone provide piezometric data
only and are not sampled BFI/CECOS uses the recovery wells to pump
contaminated groundwater from the "50-foot pervious" zone at an intermittent
rate which averages about 1 gallon per minute.
Corrective action in the northeast corner of the site includes
groundwater removal from the shallow sands (Figure 4). Groundwater is
removed using two 4-inch diameter recovery wells, MW-30 and MW-35 (which
were formerly monitoring wells). MW-30 began pumping in December 1983,
and MW-35 began pumping in April 1984. BFI/CECOS disposes of the groundwater
pumped from the recovery wells into the injection well. BFI/CECOS has
proposed installing a clay cap in the northeast portion of the site to
reduce infiltration of precipitation into the subsurface flow system and
reduce the volume of recovery pumping. This proposal awaits State approval.
Proposed corrective action in the area of the closed surface
impoundments numbers 2 through 8 also includes a clay cap and drainage
improvements. Already operating in this area are four large-diameter
recovery wells (RW-1, RW-2, RW-3 and RW-4) which collect water from the "50-
foot pervious" zone (Figure 5). BFI/CECOS installed RW-1 in April 1984, in
-37-
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Table 2: Compounds Detected in Site Monitoring Wells
(Excudes compounds considered to be due to cross-
contamination)
Volatiles
Base/Neutal Extractables
h
i;
Benzene
Carbon Tetrachloride
Chlorobenzene
Chloroethane
Chloroform
1,1-Dichloroethane
1,2-Dichloroethane
1,1-Dichloroethylene
Ethylbenzene
Methylene chloride
1,1,2,2-Tetrachloroethane
Tetrachloroethylene
Toluene
1,2-Trans-dichloroethylene
1,1,2-Trichloroethane
Trichloroethylene
Trichlorofluoromethane
Vinyl chloride
Acenaphthene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(a)fluoroanthene
Benzo(ghi)perylene
bis(2-chloroethyl)ether
bis(2-Chloroethyl)ether
Butyl benzyl phthalate
Chrysene
Dibenzo(a,h)anthracene
Fluoranthene
Fluorene
Indeno(l,2, 3-c,d)pyrene
Naphthalene
N-Nitrosodiphenylamine
Phenanthrene
Pyrene
TRIEGEL& ASSOCIATES, INC.
-38-
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response to the ECC Compliance Order dated February 29, 1984. BFI/CECOS
installed RW-2, RW-3, and RW-4 in February 1985 and began pumping them
immediately. All of the recovery wells pump continuously, intermittently,
at an average rate of 0.25 gpm to 2.6 gpm. Company consultants have
estimated the radii of influence and have found them to he highly
variable due to anisotropy of the subsurface materials.
As reported by the facility, the actual capture zone (zone within
the radii of influence where contaminants will he drawn to a given
recovery well) for each well does not reach all contaminated areas within
that well's radii of influence. In order to recover all contaminated
groundwater, the capture zone of each recovery well must he increased
or additional recovery wells must be added. The capture zones of the
existing recovery wells probably cannot be increased because, according to
the facility, these wells are being pumped at or near the maximum rate
possible. Therefore, additional recovery wells (including MW-47, MW-27,
MW-36, MW-32.L-207) are needed to effectively remove contaminants from
the groundwater.
The.recovery wells are operating at varying degrees of efficiency.
Recovery well RW-1 has a very limited clean-up. Recovery well RW-2
has a greater capture zone, however, it is not located in the most
contaminated areas (this is especially significant in light of the fact
that groundwater immediately around RW-2 will show an increase in
contamination as pumping continues.) The capture zone of RW-3 probably
includes MW-27 (a highly contaminated well), however, the facility estimates
that 20 to 30 years of pumping wll he required before significant improvements
in water quality will be seen. Recovery well RW-4 is report as having
a relatively small capture zone, and significant improvement in water
quality (especially 1,2-Dichloroethane) is not expected within 30 years.
As reported recovery wells MW-30 and MW-35 have overlapping capture
zones hut may also require an extended time to remove contaminants, and
may he incapable of removing certain oil-phase contaminants in the
vicinity of MW-36.
Monitoring well MW-39 was installed between closed impoundments 3 and 5
to check for contaminants in the "200-foot sand". The facility reported
the presence of certain volatile organic chemicals in this well (including
-39-
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TRIEGEL& ASSOCIATES, INC,
-42-
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1,2-Dichloroethane) and conducted a down-hole video survey and 72-hour
punping-test (2/86) to obtain information on the cause and extent of
contamination. The video survey indicated that casing failure may have
contributed to the observed contamination. This may be due to reactions
of the PVC casing with contaminants in the groundwater. The pumping-test
casued levels of 1,2-Dichloroethane to increase and then stabalize at
around 2 mg/1.
BFI/CECOS has proposed locations for six additional recovery wells to
the State (Figure 6): MW-47, MW-27, MW-36, L-207 (oily material found
at 50 feet), MW-15, and MW-32. These points all show "high levels" of
contamination (some show higher levels of contamination than the existing
recovery wells). The facility is awaiting formal state approval for
these proposed recovery wells.
As yet, contaminant levels in the recovery wells have not declined, and
are not expected to dec!one for some time. This is due to the volume
of contaminated water present and due to alternative and leaching
characteristics of the contaminants. According to the facility, current
pumping rates will extract one pore-volume of water from the contaminated
areas in approximately 13 years. Also, the facility has estimated that
certain contaminants may move at only a small fraction of groundwater velocity
(Table 3). Therefore, the current recovery program may required several
decades or more to show significant improvement of water quality. As such,
it is important to evaluate the actual radii of influence in relation
to the ability of the current recovery program to prevent wastes from
migrating offsite. Also, the ability of the recovery wells to remove onsite
dense oil-phase contaminants should be evaluated (some of these wastes,
especially at MW-47 might not be removed by the current recovery program).
The current recovery program is incapable of preventing wastes
from migrating offsite. This is evidenced in part by the fact that monitoring
well MW-47, located at the south boundary of the site, has shown an increase
in levels of 1,2-Dichloroethane over the past few years despite the operation
of the recovery wells. This trend indicates that contaminants will probably
move offsite in the area of MW-47 unless a recovery well is installed
in this area. In order to prevent contaminants from moving, offsite (if
they have not already moved offsite) a greatly increased groundwater
recovery program may be needed.
-43-
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I
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Also, the overall effectiveness of the corrective action program cannot
he assessed until the extent of contamination has been adequately defined.
In order to adequately define the extent of contamination, additional
monitoring wells must he installed to delineate the exact vertical and
horizontal plume boundaries. The facility must verify the extent of
contamination on the "200-foot sand" and "zone of interconnection". The
facility should also further define the plume boundaries beneath the "shallow
sands" and in the "50-foot pervious zone".
Piezometric Levels Program
BFI/CECOS implements the Piezometric Levels Program to determine
groundwater elevations and flow gradients across the Lake Charles
facility. BFI/CECOS measures water level elevations monthly in all 48
monitoring wells and piezometers completed in the shallow sand, "50-
foot pervious" zone and the "200-foot sand".
The Piezometric Levels Program began in 1982-1983 with measuring
water levels in wells initially installed for ground-water monitoring
in 1981-1982. The ECC deemed these wells to be unnecessary for RCRA
monitoring but asked that these wells be retained for water-level
monitoring across the site. BFI/CECOS included these early wells in
their piezometric monitoring.
In compliance with a February 1984 Compliance Order, BFI/CECOS
quarterly submits piezometric contour maps for the "50-foot previous"
zone and the "200-foot" sand at the Lake Charles facility.
MONITORING OF REGULATED UNITS
The active RCRA units (the receiving basins and the equalization
basin) are monitored by 4 monitoring wells (MW-17, MW-18, MW-41, and
MW-42). Two of these monitoring wells (MW-41, and MW-42) are located
downgradient (southeast) of the receiving basins in the "50-foot pervious
zone" (MW-42) and "200-foot sand" (MW-41). Two other wells, MW-17 and
MW-18 are located downgradient (southeast) of the equalization basin in
the "200-foot sand". The facility has proposed to install an additional
monitoring well in the "50-foot pervious zone" near the southwest corner
-45-
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of the equalization basin; an area which is currently not being monitored
("Supplementary Site Assessment Report, May 1, 1986"). The nearest
upgradient well in the "50-foot pervious zone" is MWL-34 (located
approximately 600 feet to the northwest of the north receiving basin).
No contamination has been detected in MWL-34 (upgradient). At
least one downgradient well, MW-41 (in the "200-Foot Sand") is reported
to have shown contamination, however, the source and extent of this
contamination has not been verified by the facility. (A down-hole
video survey revealed that casing failure may have allowed contaminants
to migrate from overlying soils to the "200-foot sand" via the well).
This casing failure may have been influenced by reactions with
contaminants in the groundwater. Water level readings from piezometers
and monitoring wells near the equalization basin are often higher than
water-level readings away from the impoundment. This is especially true
near P-2 and P-3 (near the south-central and southwest portions'
of the equalization basin). While facility states that this phenomenon
is probably due to "stacking" of groundwater at the transition of the
Beaumont and Prairie Terrace, it is more likely that the "observed
mounding" is being influenced by fluid in the equalization basin. As
previously stated, there are no monitoring wells near the south-central
or southwest portions of the equalization basin for leak detection. In
any event the existing surface impoundments create an additional hydraulic
head for downward movement of contaminants.
In siting any additional monitoring wells, the potential for
introducing existing soil contamination into the groundwater should be
considered. As stated in the facility's May 1986 report, an appropriate
location for an additional monitoring well in the "50-foot pervious zone"
would be between the two sets of piezometers designated as P-2 and P-3,
thereby avoiding areas of known soil contamination. The best location
would probably be near P-2 since this is directly downgradient of the
equalization basin. This could also provide for downgradient monitoring
of the inactive mixing basins. This would also be a good location for
an additional monitoring well in the "200-foot sand".
The need for more extensive monitoring of the "200-foot sand" in this
area should depend on whether significant contamination is verified in
-46-
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MW-41 and whether monitoring near P-2 shows significant levels of
contamination in the "50-foot pervious zone".
The regulated units do not have monitoring wells located immediately
downgradient along all potential contaminant pathways. This is also
true for closed landfill cells 1 and 6. In order to adequately assess
the contribution (if any) of these units to groundwater contamination
at the site, additional monitoring wells should he installed in the
"50-foot pervious zone" and "200-foot sand". Figure 6 shows recommended
locations for additional monitoring wells.
Other Monitoring Wells
Three other monitoring wells are also present at the site. These
wells are MW-16, WWN, and WWS. Monitoring wells MW-16 and WWN are
completed in the "500-foot sand", and monitoring well WWS is completed
in the "200-foot sand". WWN is currently used for the truck-wash
facility near the receiving basins. WWS has been used as the facility's
drinking water well, however, the facility now uses a public drinking
water supply system. All three wells are samples periodically for
priority pollutants; none are reported to be contaminated.
WELL CONSTRUCTION
Monitoring wells and small-diameter recovery wells at the Lake
Charles facility are constructed of 3 or 4-inch schedule 40
polyvinylchloride (PVC) casing with threaded joints (nine wells are
indicated as having glued joints). Screens are 0.010 inch slotted PVC.
Piezometers are constructed of either 3/4" or 2" schedule 40 PVC.
Generalized well construction specifications are shown in the Figure 7.
The annular space below and opposite the screen is filled with
#375 sand, which is overlain by a hentonite pellet seal that is generally
2 to 3 feet thick. Cement bentonite grout or cement mud grout overlies
the hentonite seal and fills the annular space to the ground surface.
The 6-inch protective steel surface casing is sealed with a gravel/cement
mix surface seal [Figure 7], Well construction diagrams do not specify
the depth of the protective surface casing, however the facility indicates
that protective casing was placed several feet deep.
-47-
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GROUND WATER OBSERVATION WELL REPORT,.
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RECOVERY WELL RW-3 DETAILS
BFI WASTE MANAGEMENT
CALCASIEU FACILITY
WILLOW SPRINGS, LOUISIANA
*
BROKING-FERRIS INDUSTRIES,
CHEMICAL SERVICES, INC.
HOL-370N. TEVAS WOnnw«Rn nvnr CONSULTANTS ™F' "nU4 ''
Figure 8 .
GENERALIZED RECOVERY WELL CONSTRUCTION
-------
The four large-diameter recovery wells are constructed of 12-inch
diameter #304 stainless steel casing. The screens are 12-inch diameter,
stainless steel with 0.012-inch openings. The large diameter provides
greater surface area for water to enter the well from the low-yield "50-
foot pervious zone". Each screen is 10 feet long. In addition to the
well casing, the 36-inch wellhore contains two 2-inch diameter steel
pipes in the annular space [Figure 8], Each of these pipes is fitted
with 10 feet of slotted pipe opposite the well screen. The large-
diameter annular space is backfilled with a sandpack, size 0.015-inch
through 0.020-inch from the bottom of the hold to several feet
(unspecified) above the screen. A second sandpack, size 0.030-inch
through 0.060-inch overlies the first for 16 to 25 feet in RW-2, RW-3
and RW-4 and for about 43 feet, to within 5 feet of the surface, in RW-1.
The remaining annular space is sealed with concrete to the surface.
All monitoring wells are equipped with locking caps which are attached
to the outer protective casing. This is to help ensure that only
authorized personnel have access to the wells.
Monitoring wells MW-2R, MW-19, MW-20, MWS-28, MW-29, MWL-34, MW-36,
and MWL-40, piezometers P-7 and P-8, and recovery wells MW-30 and MWS-
35 are below the historical high water elevation. [The casings of these
wells should he elevated to 19 feet (NGVD) or be sealed to prevent
floodwater infiltration.]
GROUND-WATER SAMPLING AND ANALYSIS PLAN
BFI/CECOS has developed and maintains a ground-water sampling and
analysis plan (SAP) onsite. The SAP is included in Chapter 18 ("Ground-
Water Protection") of the Part II permit application (October 10, 1984).
The SAP includes elements addressing sample collection, sample preservation
and shipment, analytical procedures and chain-of-custody control. This
section outlines the content of the SAP for the Lake Charles facility.
-50-
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Sample Collection
The sample collection section addressed well evacuation, field
measurements, field blanks and sample collection. The SAP includes the
following procedures:
0 Use either dedicated bottom-loading bailers or stainless steel
submersible Grunfos® pumps for well evacuation and sample collection.
All deep wells and recovery wells are equipped with pumps. Also,
a number of monitoring wells in the "50-foot pervious zone"
have pumps: MW-13, MW-24R, MW-32, and MW-43 through MW-48.
0 Evacuation water from the well until it runs dry or, if the well
recharges faster than the evacuation rate, evacuate four water-
column volumes.
0 Take one field measurement from each sample (onsite measurements
include pH and temperature). Note: The facility actually takes
four measurements in the field and should revise the SAP
to show this.
0 Run field blanks prior to sampling. Include two types of field
blanks: (1) Trip blanks, which are prepared prior to going into
the field and consist of de-ionized water in appropriate containers;
these containers are carried from the lab into the field and hack
to the laboratory, and (2) field blanks, which are poured in
the field by passing de-ionized water through sampling equipment
into appropriate containers and transported to the laboratory.
0 Collect samples, filling each bottle to the top. Allow no air
space in samples for volatile organics.
Table 4 shows the facility sampling schedule. The SAP does not include
procedures for measuring total well depth. However, the facility does
measure total well depth periodically to check for siltation (the SAP should
he revised to reflect the procedures used to determine total well depth).
Sample Preservation/Shipment
The SAP includes the following procedures for sample preservation
and shipment:
-51-
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Table 4
GROUNDWATER SAMPLING SCHEDULE
BFI/CECOS
Lake Charles, Louisiana
Sampling
Well Schedule Parameter
Compliance Monitoring Program
Monitoring wells Quarterly Conventionals*
PP volatile organics
Semi annually Priority pollutants
Drinking water
Parameters
**
Corrective Action Program
Monitoring wells Quarterly PP volatile organics
Recovery wells Monthly - PP volatile organics
Other
MW-16 Semiannually PP volatile organics
(first sampling)
Priority pollutants
(second sampling)
WWN Semiannually PP volatile organics
(first sampling)
Priority pollutants
and conventionals
(second sampling)
WWS Monthly Priority pollutants
* The Company's conventional include specific conductiv-
ity, total organic carbon, total organic halogen coli-
form bacteria, sodium, chloride, fluoride, sulfate and
gross alpha/beta.
** PP = Priority Pollutants. Priority pollutants are
defined in the June 7, 1976 Natural Resources Defense
Council (NRDC) vs. Russell Train (USEPA) settlement
agreement listing 123 compounds that are commonly
referred to as the "Priority Pollutant list."
-52-
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0 Refer to the following sources for preservation techniques and
types of sample containers:
1. U.S. Environmental Protection Agency, Method for Chemical
Analysis of Water and Waste and (EPA 600/4-79-020)
2. Federal Register, December 3, 1979, vol. 44, No. 233 p-69574
0 Label and pack samples in ice in strong containers, and
immediately ship them to the laboratory.
Analytical Procedures
The SAP refers to analytical procedures presented in the U.S.
EPA's manual of Methods for Chemical Analysis of Water and Wastes and
in the 14th edition of Standard Methods for the Examination of Water
and Wastewater as the analytical methods to be followed for ground-
water samples. The SAP states total organic halogen analysis will be
completed via EPA's Method 450.1 - Interim.
Chain-of-Custody Control
The SAP specifies that all samples collected at the facility be
accompanied at all times by chain-of-custody documentation including
the following information:
0 Name of study area
0 Collector's signature
0 Station number
0 Date and time
0 Type of sample
0 Number of containers
The SAP instructs that sample custodians sign the chain-of-custody form
when transferring custody to another individual. The recipient also
must sign at the time of transferral. The SAP also states that samples
are in custody if they are:
-53-
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0 In actual physical possession, or
0 In view, after being in physical possession, or
0 In physical possession and locked
BFI/CECOS Sample Collection and Handling Procedures
During the December 1985 facility sampling event, NEIC observed the
company's water-level measurement procedure for several wells and
sampling for three wells. This section summarizes NEIC's observations.
The Task Force interviewed facility representatives concerning groundwater
sampling and handling procedures hut did not witness sampling procedures.
Field Measurements, Sample Collection and Preservatives
The Company measured water levels in all wells and piezometers
prior to sampling with a Fisher M-Scope® electric water meter. The
measuring point was the top of the PVC casing. Elevations of the tops
of casings are recorded in the site sampling log.
The meter's probe was rinsed with de-ionized water prior to well entry.
The portion of the meter's tape entering the well and the probe were
wiped dry with a tissue and rinsed with de-ionized water after each
water level measurement. The probe was not covered during transport
between wells.
Company personnel recorded water levels on looseleaf notebook
paper in the field. They indicated the data would he transferred to
the field logs once all water-level measurements were completed.
All monitoring wells are equipped with either dedicated GRUNFOS®,
stain-less steel, impeller pumps or dedicated, bottom-loading, PVC
bailers. The bailer was suspended from a tripod equipped with a pulley
and positioned at the wellhead. Wells where NEIC observed purging were
dewatered. For wells that did not dewater, water column volumes were
calculated using the known depth of the well, depth to water and the
well radius.
Purged water was poured onto the ground rather than collected for
disposal. In view of the fact that some of these wells are known to
contain hazardous waste constituents, collecting the water and pumping
it down the injection well is a preferred method of disposal,, Wells
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dewatered during purging were allowed to recover prior to sampling. In
the case of MW-29, the well was purged two days prior to sampling during
December 1985 sampling event.
NEIC observed sampling procedures at three wells, MW-38, MW-29
and MW-19. Sampling personnel indicated that samples are visually
inspected for color and turbidity in the field and are smelled for
odor. No instruments for these characteristics are used in the field.
The samplers recorded temperature and four measurements for pH and
specific conductivity at each well. The pH meter was an ORION® Model SA
250. The conductivity meter was a YSI® Model 33. Both meters were
standardized in the field.
After making the field measurements, the sampling personnel
collected samples for analysis. Samples collected from these wells,
their containers and their preservatives are listed in Table 5. The
samplers bailed the samples and poured the water directly into the
sample containers from the bailer. Premeasured preservatives prepared
by the analytical laboratory were added immediately to the necessary
samples in the field.
Table 5
ANALYTICAL PARAMETERS, VOLUMES AND
PRESERVATIVES FOR SAMPLES
BFI/CECOS, Lake Charles, Louisiana
Parameter
No. and Container
Preservative
Base Neutral Acids
Cyanide
Phenols
Volatile Organics
Pesti ci des/herhi ci des
Metals
TOC
TOX
Coliform
Gross alpha/beta
2 1-liter amber glass
1 1-liter amber glass
2 40-ml glass
2 1-liter amber glass
1 1-liter plastic
1 1-liter amber glass
1 1-liter amber glass
1 250-ml clear glass
2 1-liter cuhitainers
NaOH
H2S04
-55-
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Shipping and Chain-of-Custody
The sample bottles for acid/base extractahles, cyanide, phenols,
volatile organir.s, pesticides/herbicides and metals are all prepared by
the principal contractor laboratory, ETC, in Edison, New Jersey, to
ensure uniform procedures. The bottles are pre-laheled for the required
parameters from each sampling point and shipped to the facility in
sealed "shuttles" together with the required documents for sampling
(chain-of-custody and field record sheets - documents CC-1 and CC-2,
respectively). Pre-measured preservatives for each appropriate sample
bottle are shipped in small vials attached to the bottle.
• Once the samples were collected and preserved, they were placed in
the shuttles, which are insulated containers with fitted plastic foam
inserts for the bottles. A signed chain-of-custody for (CC-1),
designating the analytical requirements, accompanied each shuttle.
This form included space for the location, date and time of sampling;
the sample size and preservatives; whether the sample was filtered and
the numbers of the custody seals.
Packs of "orange ice," frozen in an onsite freezer, were placed in
the shuttles to cool the samples during shipment NEIC did not observe
the sealing and shipment of the shuttles; however, the Company indicated
their practice is to complete and enclose the sampling documents, secure
the shuttle with a numbered plastic seal and ship it to the laboratory.
Samples for specific conductivity, chloride, fluoride, sodium, nitrate,
sulfate, TOC, TOX, Coliform and gross alpha/beta were sent to Core
Laboratories in Sulphur, Louisiana, for analysis. These samples were
not accompanied by custody sheets or by signed analysis request forms.
The Core laboratory indicated it knows by historical analysis requirements
which analyses are to he performed on samples from the BFI/CECOS Lake
Charles facility. Samples for Core lab were packed in insulated containers
and sealed with a wire seal for transport to the laboratory.
The NEIC noted that no field blanks were taken by the facility
during sampling. Also, the facility reported to NEIC that field blanks
were not routinely taken during sampling.
At the time of the Task Force, the facility was still utilizing
ETC as their primary contract laboratory for all groundwater samples except
inorganics. All inorganics samples were handled by Core lab in Sulphur.
Also, the facility reported to the Task Force that field blanks were not
routinely taken during sampling.
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SELECTED ITEMS PERTAINING TO THE DECEMBER 1985 NEIC INSPECTION
Groundwater Monitoring Programs
Compliance Monitoring Program
Improved monitoring coverage of the "200-foot" sand in the
southeastern portion of the site may he appropriate since MW-28 alone
covers this corner and since the ground-water flow direction in the
"200-foot" sand is generally to the southeast. Should MW-28, previously
"clean", show evidence of contamination, additional coverage here would
he ddvisahle. [More recent data ohtained hy the Task Force indicates
that additional downgradient monitoring wells are required in the
200-Foot Sand.]
Corrective Action Program
Consultants to BFI/CECOS are evaluating piezometric contour maps
drawn over time in order to define the radius of influence from each
recovery well since their implementation in 1985. Continued piezometric
monitoring for a longer period will indicate the effectiveness of the
recovery wells at inducing a hydraulic gradient directed toward the
site and intercepting groundwater that would otherwise flow offsite.
In the event recovery pumping reaches a steady state with the
aquifer and fails to provide an adequate radius of influence to ensure
sufficient recovery, additional recovery wells or alternative corrective
measures may he necessary. Installation of the four proposed additional
recovery wells would improve the prevention of ground-water flow offsite
hy expanding the area of influence of pumping.
Well Construction
PVC casing and glued joints may alter groundwater samples with
respect to organic constituents. In general, EPA recommends that
Teflon® coated or stainless steel casing he used for monitoring wells.
NEIC inspected the wellheads of several wells to he sampled hy
BFI/CECOS during the inspection. In several instances, wellhead
conditions were poor. For example, on MW-39, the seal of the well cap
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was not secure to the top of casing. Substantial rust, a cracked well
cap and loose holts were apparent. MW-19 has an extension of schedule
80 PVC attached to the top of the installed PVC casing as a protection
against flood water intrusion from the Little River. Nevertheless,
the well is potentially susceptible to flood waters. Standing water
above ground surface was observed in the annular space between the PVC
well casing and the protective surface casing. Inside the PVC casing,
water was below ground surface, indicating the surface seal is still
intact. Wells in this floodplain should he inspected regularly to
ensure the surface seal remains intact and to maintain the protection
against flood water instrusion.
Groundwater Sampling and Analysis Plan
Sample Collection
NEIC evaluated sample collection procedures for several wells
during the onsite inspections. BFI/CECOS followed the SAP for sample
collection procedures, including well evacuation and filling bottles.
The procedures were acceptable, with the exception of dumping purged
water onto the ground. BFI/CECOS did not follow the SAP with respect
to the number of replicate field measurements but did follow State and
Federal regulations [LHWR 23.36d, 40 CFR 265.92(c)(2)]. BFI/CECOS needs
to update the SAP to reflect that specific conductivity is measured
four times in the field, and that four replicate measurements, not one
measurement, are done for pH.
Ground-water samples taken during the onsite inspection were
preserved and shipped according to procedures in the SAP. The SAP
indicates that for certain samples requiring acid preservation, the
sample will be preserved to a pH of 2. NEIC noted that final pH is not
checked in the field. However, a previous NEIC inspection of the contracting
laboratory receiving acid-preserved BFI/CECOS samples revealed the pH
is checked upon sample arrival at the laboratory. In the event the pH
is not low enough, the procedure is for the laboratory to notify
BFI/CECOS to resample.
The NEIC also noted that field blanks were not taken by the facility
during sampling. The NEIC found that there were no records of field blanks
being taken since 1982, and that, according to the site manager, field blanks
were not routinely taken, in contradiction to the SAP and the regulations.
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ChaijT-of-Custody Control
The chain-of-custody procedures outlined in the SAP are acceptable,
although BFI/CECOS does not follow them completely. BFI/CECOS breached
their own chain-of-custody described in the SAP. NEIC observed unlocked,
unattended trip blanks and groundwater samples during the inspection,
although the samples were insice with security-controlled front gate.
The sample custodian, whose name appeared on custody records, had left
the site, leaving samples in the charge of other facility personnel
with no documentation of the transfer of custody. These relaxed custody
procedures could compromise both the integrity of the samples and the
documentation of actual possession.
Field parameter forms (CC-2) provided by the contractor laboratory
(ETC) with the sample shuttle were not fully completed by the samplers.
Specifically, no pH or specific conductivity standards or temperature
measurements were entered on the form. Well purging data (wellhead and
groundwater evaluations) were omitted from most of the CC-2 forms.
Preparation, Evaluation and Response
BFI/CECOS has reported their assessment of groundwater quality to
the regulatory authority as required hy the Louisiana HWR 23.37(i) and
(m) and 40 CFR 265.93(d)(l) and (5). BFI/CECOS has also reported ground-
water surface elevation regularly in accordance with Louisiana HWR
23.37(m) and 40 CFR 265.93(f).
TASK FORCE RECOMMENDATIONS
1. The facility should immediately install monitoring wells in the
"200-foot sand" in the "zone of interconnection" (southeast portion
of site). These wells should he located near boreholes L-214, and L-
217 and should he screened at depths of approximate 65 feet and
85 feet. The screened intervals should be no more than 10 feet in
length, and should he set in sand at the top of any clay or silt
clay layer. This will increase the likelihood of encountering
dense-phase contaminants. [High levels of contamination are found
immediately upgradient of this zone].
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2. The facility should immediately install at least one monitoring
well in the "200-foot sand" near MW-47 to ensure that contaminants
have not entered the "200-foot sand". This area is potentially
vulnerable due to its proximity to the "zone of interconnection"
and due to the extreme levels of contaminants found in the "50-foot
pervious zone" at the bottom of MW-47. Also, if contaminants were
to enter the "200-foot sand" in the area of MW-47, they would pass
offsite undetected as there are no monitoring wells in the "200-
foot sand" to the southeast (downgradient) of MW-47. If the facility
is unable to install this well in this area due to offsite access
problems, or due to existing soil contamination, it should consider
some other location near MW-47. Potential alternative locations
would include borehole L-63, or MW-16. This well (or wells) should
be screened at a depth of around 75 feet. The screened interval
should be set in sand at the top of any clay or silty clay layer.
3. The facility should install additional monitoring wells immediately
downgradient of all regulated units (receiving basins, mixing
basins, equalization basin, impoundment 7, and landfill cell 7) in
the "50-foot pervious zone" and "200-foot sand" to fill "gaps" in the
existing monitoring system. Also, additional monitoring wells
should he installed immediately downgradient of landfill cells 1
and 6 to determine if these units are contributing to groundwater
contamination at the site. Figure 6 shows recommended locations for
additional monitoring wells.
4. The facility should immediately verify the extent of the contamination
detected in the "200-foot sand" especially in monitoring wells MW-
39 and MW-41. Based on the findings of this investigation, the facility
may have to expand its clean-up efforts to include the "200-foot
sand". Other locations for monitoring wells in the "200-foot" sand
include the areas near MW-27, MW-46, and MW-15.
5. The facility should immediately initiate pumping of the "50-foot
pervious zone" to recover contaminated groundwater at the following
locations: MW-47, MW-46, MW-15, MW-27, MW-36, MW-32, and L-207.
This effort should he designed to supplement, and parallel the
recovery program already underway. It is important to pump these
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wells in order to expedite remediation, and to prevent unnecessary
contamination of groundwater. (The current recovery system does
not always withdraw groundwater from the most contaminated areas
(proposed recovery wells). If this continues, the groundwater
between the existing recovery wells and points of high contamiantion
will eventually show an increase in contaminants as contaminants
are drawn through this zone to the recovery wells).
6. The facility should immediately verify the vertical extent of
contamination beneath the northeast corner of the site. This
should include the installation of additional monitoring wells in
• the "50-foot pervious zone" and "200-foot sand" in the area of
monitoring well MW-36, and MW-30.
7. The facility should further define the extent, concentrations,
degradation products, and rate of movement of all priority pollutant
contaminants in the groundwater. This should include an assessment
of which contaminants have moved offsite or are likely to move
offsite, and which contaminants have entered or may enter the Chi cot
Aqn'fer System. This will require additional hydrogeologic characterization
of the site, especially the "200-foot sand", and "zone of interconnection".
8. The facility should evaluate the potential for contaminants to
migrate through the clay layer which separates the "50-foot pervious
zone" from the "200-foot sand". This evaluation should have a
hearing on the future scope of monitoring in the "200-foot sand",
and on long-term remediation strategies.
9. The facility should continue to evaluate the effectiveness of the current
corrective action programs in relation to current and projected recovery
rates.
10. The facility should evaluate the effectiveness of the corrective
action program in relation to continued leaching of contaminants
from above the "50-foot pervious zone". This evaluation should
include an assessment of the following: (1) estimated rates of
infiltration, (2) solubility effects, (3) degradation products and
rates, and (4) the level of clean-up that is required. Also, the
time required to implement this program should he considered.
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11. The facility should evaluate whether the current corrective action
program is effective in removing dense-phase contaminants from the
"50-foot pervious zone". The current program may not he capable of
recovering these contaminants, (except perhaps near recovery wells)
or may recover them at only a fraction of the rate of groundwater
withdraw!.
12. The facility should evaluate the effectiveness of alternative corrective
action measures. In the interim, the facility should probably install
an additional clay cap over contaminated areas to reduce infiltration.
13. The facility should evaluate the potential for contaminants to
enter the "200-foot sand" offsite. This is critical because local
citizens utilize the Chicot Aquifer as a drinking water source.
14. The facility should take steps to protect wells from flooding. A
number of wells in the northeast corner of the site are susceptible
to flooding, and were flooded during the Task Force inspection.
15. The facility should utilize field blanks in its groundwater sampling
procedures as stated in the facility's sampling and analysis plan (SAP).
As a result of interviews with facility representatives, the Task
Force determined that the facility was not routinely utilizing
field blanks as specified by the facility's SAP, and required by regulation.
16. In order to help ensure lasting well integrity, the facility should use
Teflon®, stainless steel, or other inert casing (and screen) materials
for all new monitoring wells. [This is especially important for all
monitoring wells pentrating the 200-Foot Sand, since these wells could
serve as pathways for downward contaminant migration if the wells are
deteriorated by contaminants.]
17. The facility should install self-actuating pumps in all landfill
leachate collection and detection systems to minimize leachate
accumulation.
18. The facility should not allow standing water to accumulate in the
landfill cell 8 excavation. Water accumulating in this area contributes
to a downward gradient and may increase the rate that contaminants
pass through the "zone of interconnection" to the "200-foot sand".
19. The facility should keep local citizens apprised of the migration
of groundwater contamination at the site, and should immediately
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notify local citizens if groundwater contamination from the site
is detected offsite.
20. The facility should close the existing surface impoundments as
soon as possible to reduce the downward hydraulic gradient near areas
of known contaminants.
21. The facility should modify the existing sampling and analysis plan to
include procedures for measuring and sampling immiscible layers
in monitoring wells.
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GROUNDWATER MONITORING PROGRAM PROPOSED BY FACILITY FOR FINAL PERMIT
The groundwater monitoring program proposed for the final permit
is similar to the current program discussed in the previous section.
The noteahle exceptions are the proposed completion of six additional
recovery wells (Figure 6), the potential replacement of two existing
wells, and the addition of a monitoring well downgradient of the active
surface impoundments. Also, clean-up goals, and time-frames, within
the point of compliance must he established.
The proposed additional recovery wells are designated as MW-27, MW-36,
MW-15, MW-32, MW-47, and borehole L-207. The wells are located in the
"50-foot pervious zone", except for MW-36 which is located in the "shallow
sands". The borehole (L-207) is currently grouted hut is proposed to
he completed in the "50-foot pervious zone". These wells would he used
to supplement the existing recovery program. The facility is awaiting
state approval to implement this proposal.
The facility may replace two "200-foot sand" monitoring wells-
(MW-39, MW-41) if these wells are found to be defective. These wells have
shown contamination which the facility contends migrated from overlying
contaminated soils through cracks in the casings. The facility has not
established the extent of the contamination that exits in "200-foot
sand" around these wells.
An additional monitoring well has been proposed near the southwest
corner of the equalization basin (the best location would probably he
near, piezometer, P-2). This well would he located in the "50-foot
pervious zone" downgradient of the active surface impoundment sand inactive
mixing basins. Currently, only two wells are immediately downgradient
of the equalization basin (MW-17 and MW-18).
The facility has not proposed, nor has the state established, the
level of clean-up (of existing contamination) required at the facility.
The State, however, may require clean-up to detection levels. It will
be necessary to establish clean-up goals in order to properly assess
the potential long-term effectiveness of any corrective action measures.
The facility proposes to use four indicator parameters (1,2-Dichloroethane,
toluene, arsenic, and cadmium) to identify significant increases in compliance
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monitoring wells. A nonparametric statistical test (Wilcoxon two-sample
test) is proposed to he used hy the facility to compare the values of
these parameters in upgradient and downgradient wells. This proposal is
under review hy LDEQ.
Task Force Recommendations
See recommendations listed under "Groundwater Monitoring During
Interim Status".
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TASK FORCE SAMPLE COLLECTION AND HANDLING PROCEDURES
During the first and second day of the onsite inspection, the Task
Force measured casing-diameters, water-levels, and total depths of most
of the facility's monitoring wells and piezometers. The data obtained
was used to determine (verify) groundwater flow directions and to
calculate the volume of water to he purged from each well prior to
sampling. Sampling was subsequently performed at a number of these
monitoring wells (and a few piezometers). All activities related to
water-level measurements, well-purging and sampling, and sample shipment
were performed by an EPA contractor, VERSAR, Inc. of Springfield
Virginia. Task Force personnel observed all sampling procedures.
Contract laboratories were used to perform the required analyses.
In all, 18 monitoring wells and 3 piezometers were sampled at the
facility. Other sample taken include 1 leachate sample, 6 sampling
blanks, and 4 sets of duplicate samples. Most of these samples were
analyzed for all of the Task Force parameters listed in Table 7. These
parameters include RCRA indicator parameters, inorganics, volatile, and
semi volatile organics, total and dissolved metals, herbicides, pesticides,
and dioxins and dibenzofurans. Splits of all samples were provided to
the facility. All Task Force sampling results are shown in Appendix A.
Sampling locations were selected to provide representative data
concerning upgradient and downgradient water quality at the site and to
verify the extent of reported contamination. As a result, certain
offsite wells were also selected for sampling. [The Task Force requested
and received permission from land owners to sample offsite wells. The
landowners contacted were Mr. Frank Pruitt of Powell Lumber Company
(north of site) and Mr. Richard Tanner (south of site). The offsite
wells sampled were MW-25, MW-33, MW-48, MW-49, and MW-51].
All Task Force groundwater sampling procedures followed the EPA
"Hazardous Waste Groundwater Task Force Protocol for Groundwater
Evaluations" (1986), and the EPA "RCRA Groundwater Monitoring Technical
Enforcement Guidance Document" (1986). The procedures used are discussed
below.
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Initially, each wellhead was monitored for chemical vapors and
radiation in order to assess the need for any special precautions. As
a result, it was found that high-levels of organic vapors existed at some
of the wells. In several cases, this required the use of special
protective equipment including air-purifying respirators.
The facility was requested to remove the pumps from wells to he
sampled (where applicable). Then, the depth to water and total depth
of the well were measured using an interface probe or steel tape
(referenced to the north side of the innermost casing). The probe was
also used to determine if immiscible layers were present. If an
immiscible layers was found to exist, (only found at MW-47) an attempt
was made to sample this layer using a bottom-filling Teflon® bailer
prior to well evacuation (purging). All Task Force groundwater level
measurements are shown in Table 6. [These measurements agree with
facility reported information concerning groundwater flow directions
and gradients.]
Three casing-volumes of standing water were then removed to ensure
that reprensenative formation water was recovered for sampling. This was
done using a dedicated bottom-filling teflon® bailer. Wells that went
dry during purging were allowed to recharge overnight before being
sampled. Contaminated purged water was placed in facility-supplied
drums or in the equalization basin (MW-18), and was thereafter (according
to the facility) deep-well injected via the onsite disposal well.
In all instances the dedicated teflon® bailers used for purging
were also used to obtain the required samples. Samples were taken in
the order of decreasing volatiliation sensitivity, beginning with
volatile organics. A list of the sampling containers and preservatives
used is shown on Table 7.
Field measurements for pH, specific conductance, and temperaturre,
were recorded for each well (except MW-47) at the time of sampling.
The presence of any sediment or any unusual color or odor were also
noted for each sample. This information was recorded on individual
well data sheets. Turbidity measurements and sample filtering (for
dissolved metals analysis) were performed within 24 hours of sampling.
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TABLE 6
TASK FORCE GROUNDWATER LEVEL MEASUREMENTS*
SHALLOW SANDS
P-7
P-8
MW-7
-3.23
-3.09
+12.34
MW-2R
MW-36
MW-w49
+1.58
+1.08
+13.21
50-FOOT PERVIOUS ZONE
MW-10
MW-5
MW-22
MW-45
P-13
MM -14
MW-23
MW-25
P-3A
P-l
P-2
P-3
MW-46
+1.95
-1.42
-11.46
-6.64
-10.74
-4.27
+3.08
+7.08
-6.60
-9.07
-3.88
-7.04
-7.50
MW-32
MW-42
MW-43
P-14
MW-21
MM -29
MW-20
MW-19
MW-48
MW-26
MW-51
MW-51
-7.79
-9.16
-0.96
-11.46
-12.23
-12.33
-12.16
-10.31
-8.01
+3.73
-12.05
-12.97
200-FOOT SAND
MW-39
MM -31
MW-28
-12.52
-10,91
-12.90
MM -41
MW-18
MW-33
-12.16
-12.04
-11.96
*A11 measurements are expressed in feet relative to mean sea level
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Table 7
PARAMETER, BOTTLE TYPE, AND PRESERVATIVE LIST
TASK FORCE SITES
Parameter
Bottlt Type
Preservative
Volatile Organic*
Purgeable Organic Carbon
(POC)
Purgeable Organic Halogen
(POX)
Extractable Organics:
Base/Neutral/Acids
Pesticide/PCBs
Herbicides
Dioxins/Furans
Total Metals
Dissolved Metals
Total Organic Carbon •
.(TOC) >.-•/ •-...; •'.'. "
Total Organic Halogens
(TOX) :
Phenols
Cyanide
Anions
Sulfide
2 40-ffll vials
1 40-01 vial
1 40-nl vial
2 1-liter amber glass
2 1-liter amber glass
2- 1-liter amber glass
2 1-liter amber glass
1 1-liter plastic
I 1-liter plastic
•*
1 4-oz. glass
1 1-liter amber glass
1 1-liter amber glass
1 1-liter plastic
1 1-liter plastic
1 4-oz. glass
Cool 4*C
Cool 4'C
Cool 4°C
Cool 4*C
Cool 4'C
Cool 4*C
Cool 4*C
Cool 4°C, HN03
Cool 4-C, HN03,
filtered
Cool 4*C, H2S04
Cool 4*C, no
headspace
Cool 4»C, H2S04
Cool 4°C, NaOH
Cool 4»C
Cool 4«C, Zinc
Acetate, NaOH
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All non-dedicated equipment was washed between sampling events to
prevent possible cross-contamination. This involved the use of non-
phosphate soap, hexane, and deionized water.
Collected samples were labeled and preserved as necessary and
packed in ice for shipment to the appropriate laboratory for analysis.
Chain-of-custody procedures were followed at all times to ensure proper
sample handling.
As stated, 6 sample blanks were taken at the facility: 4 were
equipment blanks, 1 was a trip blank, and 1 was a field blank. Also, 4
duplicate samples were taken (MM-47, MW-18, MW-29, MW-21). All samples
taken for volatile organic analysis were duplicated. Sample spikes
were also prepared for quality assurance/quality control purposes.
The Task Force attempted to sample wells with lower reported levels
of contamination first. This was done as an added precaution to ensure
that cross-contamination did not occur.
In order to obtain qualitative data concerning pH, and the potential
presence of volatile organic compounds in the groundwater near the south
and southwest portions of the equalization basin, the Task Force utilized
two facility piezometers, P-2 and P-3. These piezometers are constructed
of ^/A" pvc casing and are located in the "50-foot pervious zone". Two
dedicated aluminum bailers were fashioned at the site to accomodate the
small piezometer diameters. These bailers were constructed of /8"
aluminum pipe and were approximately 40" in length. A 1" wooden dowel
plug was driven into one end of the alumunum pipe and 2 V8" holes were
drilled at the other end of the pipe to accomodate hailing line. The
hailing line used was 201b - test monofilament fishing line. The
bailers were designed to he lowered into the piezometers with the wooden
plug facing down. After being lowered to the water in the well, the
bailer would sink, fill from the top, and he withdrawn for a check of pH.
These methods are not conventional and were not intended to be used for
evidence of a waste release. These methods were designed primarily to
provide for indications of low pH conditions (if these conditions
existed) in the groundwater around the equalization basin, and were
performed with the consent of the facility. Near the completion of
this acitivity, the bailer became stuck in P-2. The facility decided to
wait for an unspecified period of time before attempting to remove the
stuck bailer, and was subsequently able to remove the bailer intact.
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A bailer was lost in MW-43 during purging activities due to the
line-knot becoming untied. The bailer was subsequently recovered using
a fishing line with hook and sinker.
VOAs were taken at MW-21 and MW-29 immediately after purging during
the late afternoon of January 14. The next morning, these wells were
sampled for all parameters including VOAs. The purpose of this action
was to determine the effect, if any, of collecting VOAs immediately
after purging compared to collecting VOAs on the following day. This
was intended to provide information about whether purging activities
had caused volatiles to he lost due to disturbance and aeration. [No
obvious effects were observed.]
A black oily layer several feet thick was found at the bottom of
MW-47. This dense, immiscible layer had a strong ordor and required
the use of full-face respirators, saranar. suits, and nitrile gloves for
sampling. Samples of this layer were obtained prior to purging the
well by lowering the bottom-filling bailer to the bottom of the well.
Prior to sampling, plastic sheet was placed around the well, and Kitty litter
was polaced on top of the plastic sheet to absorb any liquids spilled
during sampling. No field measurements were taken due to the concentration
of contaminants. Samples of the aqueous phase were taken after purging
aproximately 50 gallons from the well.
One other well, MW-36, also required the use of respirators during
sampling. This well also had a strong odor, hut did no appear to have
an immiscible layer present.
At least 8 wells showed turbidity values in excess of 40 NTU.
These wells are P-3, MW-2R, MW-20, MW-25, MW-31, MW-43, MW-46. These
values may indicate excessive siltation in these wells.
Due to heavy rains and resultant high waters, the Task Force was
not able to sample several wells in the northeast corner of the facility.
Monitoring wells MW-2, MW-2R, MW-19, MW-30, MW-35 and MW-36, (sampled)
were all partially or completely inundated by floodwaters for a portion
of the onsite evaluation.
Leachate was removed from the leachate detection system of landfill
cell 7 using a GRUNFOS® pump. Samples were taken directly from a
1V2" flowline as the pump was operated. The flowline was directed
-71-
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into an 85 gallon overpar.k drum during sampling to collect all excess
water. All other procedures were the same as procedures used for collecting
samples from wells.
-72-
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TASK FORCE MONITORING DATA ANALYSIS FOR
INDICATIONS OF WASTE RELEASE
The Task Force utilized three contract laboratories to perform sample
analyses: EMSI of Newhury Park, California, (organic analyses) Centec
Laboratories of Salem, Virginia (inorganic and indicator analyses), and
CompuChem Laboratories, Inc. of Research Triangle Park, North Carolina
(dioxin/dihenzofuran analyses). Another EPA contractor, Planning Research
Corporation (PRC) of Chicago, Illinois, was utilized to evaluate the
quality control data generated by the contract analytical laboratories.
The. PRC evaluation of quality control data is provided in Appendix A.
In summary, the following data was deemed to he unusable: (1) all
medium concentration thallium results, (2) certain chromium results
(MQA924-33, 35-40, 42-46, 56) (3) all sulfide results, (4) all methylene
chloride results, (5) all bis(2-ethylhexyl) phthalate results, (6) all
chlorabenzilate results, and (7) one 4-methylphenol results (Q1528).
Also, the data for 2-chloroethylvinylether, 1,4-dioxane, and kepone
results were deemed to he unreliable. All other data is considered
usable, with conditions, and is presented in Appendix A. For a more
indepth evaluation of data useability the reader is referred to the
referenced PRC report.
The Task Force results generally agree with facility reports
concerning groundwater contamination at the site. Specifically, high
levels of volatile organic chemicals were found in groundwater samples
taken from the northeast corner (MW-36), and south portion (MW-47) of
the facility. Levels of volatile organic chemicals in MW-36 and MW-47
were found in the range of several hundred to over one thousand miligrams
per liter (m9/l). The most prevalent organic contaminant identified is
1,2-Dichloroethane. Other organic contaminants present in one or both
of these wells include Chloroform, Carbon Tetrachloride, Chloroethane,
1,1-Dichloroethane, 1,1-DiChloroethane, Tran-l,2-DiChloroethane, and
1,1-2-Trichlorethane. Due to the proximity of these wells to the
facility boundary, it is possible that some or all of these contaminants
may have migrated offsite. This is an extremely important consideration
due to local usage of the groundwater as a drinking water source.
-73-
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In order to check for possible offsite contamination in the vicinity
of MW-36 and MW-47, the Task Force sampled MW-2R, and MW-51. No clear
evidence of contamination was found, however, several compounds including
Cyclohexanol, and 7,7-Dichloro, hicyclo(4.1.0) heptane, Difluorodichloromethane
were tentatively identified in MW-51, and MW-2R showed a higher than
usual specific conductance (3850 umhos/cm) and Chloride value (1,030
mg/l). Also, MW-51 showed mercury at 93 ug/1 (which is far above the
MCL of 2 ug/1). Due to the fact that other flow paths exist for potential
offsite migration of contaminants, these results cannot he used to
quantify any offsite groundwater contamination.
• Monitoring wells MW-46 (southwest quarter of facility on southern
boundary) shows relatively moderate levels of certain volatile organic
chemicals. The most notable contaminants found in this well include
1,2-Dichlorethane and Chloroform. Certain other compounds (such as
Chlorohenzoic Acid) were also tentatively identified.
The results from piezometers P-2 and P-3 indicate the presence
of certain low-level organic contaminants. As previously discussed,
these results should not he considered quantitative- due to the modified
sampling method used. [pH values in P-2 and P-3 wear near neutral.]
The results for the offsite wells sampled north of the facility
(including MW-33, MW-48, MW-49, and MW-25) showed slightly elevated
levels of Total Organic Carbon (TOC) and Total Organic Halogens (TOX)
in all wells except MW-33. The highest levels for TOC and TOX in these
wells were found at MW-25 and MW-49. MW-25 showed TOX at 3,140 ug/1
and MW-49 showed TOX at 21 ug/1 and TOC at 12 mg/1. Also, MW-49 and
MW-33 showed some tentative identification of certain unknown organic
compounds, and MW-48, MW-49, and MW-25 showed low-levels of certain
semi-volatile organic compounds (Di-n-butylphthalate, and Phenol).
The field measurments taken by the Task Force showed pH values
ranging from 6 to 8 in most monitoring wells (except MW-45, which showed
a pH value of 5.8), and specific conductance values ranging from 500
umhos/cm to 1500 umhos/cm in most wells (except MW-2R, and MH-36, which showed
specific conductance values of 3850 umhos/cm, and 2370 umhos/cm respectively).
No field measurements for pH or specific conductance were taken at
MW-47 due to the levels of contaminants present.
-74-
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None of the samples taken from monitoring wells or piezometers
were positively identified as not containing contaminants. Each sample
contained identified, or tentatively identified contaminants, or RCRA
contaminant indicators. For most samples, the identified or tentatively
identified contaminants were present in relatively low concentrations.
As previously stated, the only samples containing excessively high levels
of contamination were taken from MW-36 and MW47; MW-46 contained relatively
moderate levels of contaminants.
The leachate sample contained detectable levels of certain volatile
organics including 1,2-Dichloroethane (32 ug/1), and showed a TOC value
of 97 m9/i (which is comparable to the TOC value in MW-47). Also,
another organic compound, Tetrahydrofuran, was tentatively identified.
No dioxins or dihenzofurans were detected in any of the samples
taken. However, the possiblity of false negative results should be
considered.
The Task Force did not sample all wells with reported contamination.
Wells with reported contamination that were not sampled by the Task
Force include MW-27, and the existing recovery wells: RW-1, RW-2, RW-
3, RW-4, MW-30, Mw-35. The Task Force accepts existing facility data
which indicates moderate to high levels of certain contaminants (including
1,2-Dichloroethane) in these wells.
A number of the volatile organic contaminants at the site are
listed as possible carcinogens in drinking water in the July 8, 1987 Federal
Register. For at least two of these contaminants, 1,2-Dichloroethane,
and Carbon Tetrachloride, Maximimum Concentration Limits (MCLs) have
been established for drinking water. Table 8 shows the level of acute
toxicity, and MCL values for selected site contaminants.
At the time of this writing, the analytical results for the oily
material that was taken from monitoring well MW-47 were not available.
These results, however, are expected to be available in the near future.
-75-
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TABLE 8
Selected Groundwater Sampling Results From The EPA Groundwater Task Force Evaluation
Selected Constituents*
1,2-Dichloroethane
Carbon Tetrachloride
Chloroform
1,1,2-Trichloroethane
1 ,2-Di chl oroethyl ene
Monitoring
Well
MW-47
SAMPLE A
620
51
910
210
Monitoring
Well
MW-47
SAMPLE B
460
42
680
160
Monitoring
Well
MW-36
1,100
460
Level of
Acute
Toxicity(l)
118
35
28.9
18
11.6
EPA
MCL
(2)
0.005
0.005
(all concentrations in mg/1)
(1) From "Handbook of Toxic and Hazardous Chemicals and Carcinogens",
Second Edition, 1985, by Marshall Sittig, Library of Congress
Catalog Card Number: 84-22755
(2) Federal Register dated July 8, 1987
*Selected EPA Priority Pollutants which are present at the site
and which are possible carcinogens.
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REFERENCES
1. U.S. EPA, "Hazardous Waste Ground Water Task Force Protocol for
Ground-Water Evaluations", September 1986
2. U.S. EPA, "RCRA Ground-Water Monitoring Technical Enforcement Guidance
Document", September 1986
3. U.S. EPA National Enforcement Investigations Center, "Multi-Media
Compliance Inspection, Browning-Ferris Industries/CECOS, Lake Charles,
Louisiana Facility [December 4-13, 1985]", May 1987
4. Woodward-Clyde Consultants, "Waste Disposal Site Evaluation, BFI-
Calcasieu Facility, Willow Springs, Louisiana", February 1983
5. 'Woodward-Clyde Consultants, "Additional Investigation and Remedial Plan
Development, BFI-Calcasieu Facility, Willow Springs, Louisiana",
October 1984
6. Browning-Ferris Industries, "Revised Remedial Action Plan for
Browning-Ferris Industries, Chemical Services, Inc., Willow Springs
Facility, Calcasieu Parish, Louisiana", May 1984
7. Roux Associates, Inc., "Site Assessment Report, BFI-CSI, Calcasieu
Facility, Calcasieu Parish, Louisiana", March 1986
8. Roux Associates, Inc., "Supplementary Site Assessment Report, BFI-CSI,
Calcasieu Facility, Calcasieu Parish, Louisiana", May 1986
9. Triegel & Associates, Inc., "1987 Annual Ground Water Report, BFI-CSI,
Calcasieu Facility, Calcasieu Parish, Louisiana", March 1987
10. Browning-Ferris Industries, "Hazardous Waste Facilities Permit
Application, Calcasieu Facility", [Revised] October 1984
11. Browning-Ferris Industries, "CECOS International, Inc., Calcasieu
Facility, Revisions To Part 2 Permit Application", July 1985
12. Louisiana Environmental Control Commission, "Findings of Fact
Compliance Order and Schedule, In the Matter of Browning-Ferris
Industries, Chemical Services, Inc., Willow Springs Facility",
February 1984
13. Browning-Ferris Industries, "CECOS International, Inc., Calcasieu
Facility, Exposure Information Report", August 1985
-77-
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APPENDICES
-------
APPENDIX A
TASK FORCE GROUNDWATER ANALYTICAL DATA
-------
pro
Planning Research Corporation
203 Eas; \Yac*er
Suite 500
C^caao iL GCGO
312-933-0210
EVALUATION OF QUALITY CONTROL ATTENDANT
TO THE ANALYSIS OF SAMPLES FROM THE
BFI/CECOS WESTLAKE FACILITY, LOUISIANA
FINAL MEMORANDUM
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Waste Programs Enforcement
Washington, D.C. 20460
Work Assignment No.
EPA Region
Site No.
Date Prepared
Contract No.
PRC No.
Prepared By
Telephone No.
EPA Primary Contact
Telephone No.
549
Headquarters
N/A
May 26, 1987
68-01-7037
15-054921-03
PFLC Environmental
Management, Inc.
(Ken Partymiller)
(713) 292-7568
Rich Steimle
(202) 382-7912
-------
MEMORANDUM
DATE: May 24, 1987
SUBJECT: Evaluation of Quality Control Attendant to the Analysis of Samples
from the BFI/CECOS, Westlake, Louisiana Facility
FROM: Ken Partymiller, Chemist
PRC Environmental Management
THRU: Paul H. Friedman, Chemist*
Studies and Methods Branch (WH-562B)
TO: HWGWTF: Richard Steimle, HWGWTF*
Garcth Pearson (EPA 8231)*
Michael Daggett, Region VI
Thomas Aalto, Region VI
John Haggard, Region VIII
This memo summarizes the evaluation of the quality control data generated
by the Hazardous Waste Ground-Water Task Force (HWGWTF) contract analytical
laboratories (1). This evaluation and subsequent conclusions pertain to the
data from the BFI/CECOS, Westlake, Louisiana sampling effort by the Hazardous
Waste Ground-Water Task Force.
The objective of this evaluation is to give users of the analytical data a
more precise understanding of the limitations of the data as well as their
appropriate use. A second objective is to identify weaknesses in the data
generation process for correction. This correction may act on future analyses
at this or other sites.
The evaluation was carried out on information provided in the accompanying
quality control reports (2-5) which contain raw data, statistically transformed
data, and graphically transformed data.
The evaluation process consisted of three steps. Step one consisted of
* HWGWTF Data Evaluation Committee Member
-------
generation of a package which presents the results of quality control
procedures, including the generation of data quality indicators, synopses of
statistical indicators, and the results of technical qualifier inspections. A
report on the results of the performance evaluation standards analyzed by the
laboratory was also generated. Step two was an independent examination of the
quality control package and the performance evaluation sample results by
members of the Data Evaluation Committee. This was followed by a meeting
(teleconference) of the Data Evaluation Committee to discuss the foregoing data
and data presentations. These discussions were to come to a consensus, if
possible, concerning the appropriate use of the data within the context of the
HWGWTF objectives. The discussions were also to detect and discuss specific or
general inadequacies of the data and to determine if these are correctable or
inherent in the analytical process.
Preface
The data user should review the pertinent materials contained in the
accompanying reports (2-5). Questions generated in the interpretation of these
data relative to sampling and analysis should be referred to Rich Steimle of
the Hazardous Waste Ground-Water Task Force.
I. Site Overview
The BFI/CECOS facility is a commercial facility located in Westlake,
Louisiana. Ground-water contamination was detected in shallow sand at the
facility approximately five years ago. The contamination detected included
1,2-dichloroethane and other unspecified contaminants.
Thirty-two field samples including a field blank (MQA934/Q1534), four
equipment blanks (MQA941/Q1541, MQA947, MQA858, and Q1558), a trip blank
(MQA923/Q1523), and four pairs of duplicate samples (well MW-18, samples
MQA932/Q1532 and MQA933/Q1533, well MW-21, samples MQA926/Q1526 and MQA859,
well MW-29, samples MQA927/Q1527 and MQA860, and well MW-47, samples
MQA945/Q1545 and MQA956/Q1556) were collected at this facility. Samples
MQA945/Q1545, MQA956/Q1556, and MQA936/Q1536 were specified by the sampling
team as medium concentration matrix ground-water samples and sample
MQA943/Q1543 was specified as a medium concentration leachate sample. There
was some confusion over the assignment of sample numbers by the sampling team.
The sample numbers and fractions which they represent are summarized in
Appendix 3 of Reference 2. Samples were not split with Region VI.
II. Evaluation of Quality Control Data and Analytical Data
1.0 Metals
1.1 Performance Evaluation Standards
Metal analyte performance evaluation standards were not evaluated in
conjunction with the samples collected from this facility.
1.2 Metals OC Evaluation
Total and dissolved metal spike recoveries were calculated for twenty-
four metals spiked into two low concentration matrix samples and one medium
-------
concentration matrix sample. Twenty-three total metal average spike recoveries
from the low concentration matrix samples were within the data quality
objectives (DQOs) for this Program. The total thallium average spike recovery
was outside DQO with a value of 51 percent. Five individual total metal spike
recoveries from the low concentration matrix samples were also outside DQO.
These are listed in Tables 3-la and 3-2a of Reference 2 as well as in the
following Sections. A listing of which samples were spiked for each analyte is
also available in Table 3-2a of Reference 2.
Twenty-three of twenty-four dissolved metal average spike recoveries from
the low concentration matrix samples were within the data quality objectives
(DQOs) for this Program. The dissolved antimony average spike recovery was
outside DQO with a value of 126 percent. One dissolved calcium and one
dissolved sodium matrix spike recovery were not calculated because the sample
results were greater than four times the amount of spike added. Two individual
dissolved metal spike recoveries from the low concentration matrix samples were
also outside DQO. These are listed in Tables 3-lc and 3-2c of Reference 2 as
well as in the following Sections. A listing of which samples were spiked for
each analyte is also available in Table 3-2c of Reference 2.
Twenty-three of twenty-four total metal spike recoveries from the medium
concentration spiked samples were within Program DQOs. Only one medium
concentration matrix sample was spiked for each metal. The total thallium
spike recovery was outside DQO with a recovery of 29 percent. A list of
individual total metal spike recoveries from the medium concentration matrix
samples is available in Table 3-lb of Reference 2. A listing of which samples
were spiked for each analyte is available in Table 3-2b of Reference 2.
Seventeen of twenty-four dissolved metal spike recoveries from the medium
concentration spiked samples were within Program DQOs. Only one medium
concentration matrix sample was spiked for each metal. The dissolved aluminum,
barium, cadmium, mercury, and silver spike recoveries were outside DQO with
recoveries of 133, 64, 142, 50, and 68 percent, respectively. The dissolved
calcium and dissolved sodium matrix spike recoveries were not calculated
because the sample results were greater than four times the amount of spike
added. A list of individual dissolved metal spike recoveries from the medium
concentration matrix samples is available in Table 3-ld of Reference 2. A
listing of which samples were spiked for each analyte is available in Table 3-
2d of Reference 2.
The calculable average relative percent differences (RPDs) for all
metallic analytes, with the exceptions of total aluminum and chromium from the
low concentration samples, were within Program DQOs. RPDs were not calculated
for about two-thirds of the metal analytes because the concentrations of many
of the metals in the field samples used for the RPD determination were less
than the CRDL and thus were not required, or in some cases, not possible to be
calculated.
Required analyses were performed on all metals samples submitted to the
laboratory.
No metals contamination was reported in the laboratory blanks. Total
chromium and mercury contamination were found in one of the equipment blanks at
-------
concentrations of 11 and 2 ug/L (the chromium CRDL equals 10 and the mercury
CRDL equals 0.2 ug/L).
1.3 Furnace Metals
The quality control for the graphite furnace metals (antimony, arsenic,
cadmium, lead, selenium, and thallium) was generally acceptable.
In the low concentration matrix samples, one total cadmium (sample
MQA937), one dissolved cadmium (MQA937), one dissolved antimony (MQA937), and
both total thallium (MQA927 and 937) spike recoveries were outside DQO with
values of 70, 132, 128, 37, and 64 percent, respectively. All results for
these metals should be considered semi-quantitative except for the total
thallium results which should be considered qualitative. The dissolved cadmium
and total thallium spike recoveries from the medium concentration matrix spike
sample (MQA936) were also outside DQO with recoveries of 142 and 29 percent.
The medium concentration dissolved cadmium results should be considered
qualitative while the total thallium results should not be used due to poor
matrix spike recoveries.
Several dissolved arsenic and total thallium continuing calibration
verifications were reported as "failed." Due to this and missing or only
partially included raw data, dissolved arsenic results for samples MQ'A929, 930,
and 931 should be considered semi-quantitative. Due to lack of required
recalibrations, dissolved arsenic results for samples MQA924, 936, and 937
should also be considered semi-quantitative. Due to lack of required
recalibration, missing or incomplete recalibration data, and/or missing raw
data, total thallium results for samples MQA924, 925, 926, 930, 932, 933, 934,
935, 936, 937, 941, 943, 945 should be considered semi-quantitative.
The correlation coefficient for the method of standard addition (MSA)
analysis of total lead in low concentration samples MQA924 and 937 was below
DQO. All positive lead results should be considered qualitative.
The double burn precision for total thallium in spiked sample MQA937 was
above DQO. Insufficient thallium continuing calibration verifications for the
samples were run. These faults were not judged to affect data quality. The
thallium four point calibration curve for the second thallium run had a poor
correlation coefficient. This was not judged to impact the data quality as the
thallium results fell within the linear portion of the curve.
All total antimony, arsenic, and selenium results and all dissolved lead,
selenium, and thallium results should be considered quantitative. All
dissolved arsenic and total lead results, with exceptions, should be considered
quantitative. All medium concentration total cadmium and lead and dissolved
antimony should also be considered quantitative. Dissolved arsenic results for
samples MQA924, 929, 930, 931, 936, and 937, all total and dissolved low
concentration cadmium results, and all low concentration dissolved antimony
results should be considered semi-quantitative. All low concentration total
thallium results, all medium concentration dissolved cadmium results and total
lead results for samples MQA924 and 937 should be considered qualitative. Due
to poor recovery, the medium concentration total thallium results should not be
used. The usability of all graphite furnace analytes is summarized in Section
4.0 and 4.1 at the end of this Report.
-------
1.4 ICP Metals
Total chromium contamination was found in equipment blank MQA947 at a
concentration of 11 ug/L. Total chromium was also found in the field blank
(MQA934) and another equipment blank (MQA941) at concentrations just below the
CRDL. The CRDL for chromium is 6 ug/L. Due to this contamination, total
chromium results for samples MQA924 through 933, 935 through 940, 942 through
946 and 956 should be considered unusable. Total chromium results for sample
MQA937 should be considered qualitative. The remaining total chromium results
should be considered semi-quantitative due to poor duplicate RPD values (see
the following comment).
Laboratory duplicate results for total aluminum in low concentration
samples MQA927 and 935, total chromium in low concentration matrix sample
MQA935, and dissolved tin in medium concentration sample MQA936 were outside
their DQOs. Because of this, all results for these metals in these matricies
should be considered semi-quantitative except for the low concentration total
aluminum results which should be considered qualitative.
The low level (twice CRDL) linear range check for total chromium, copper,
manganese, nickel, silver, and zinc and dissolved chromium, copper, and
manganese exhibited generally high recoveries on various analysis dates (see
Section B3 of Reference 3 for a detailed listing of analysis dates, samples
affected, and biases). The low level linear range check is an analysis of a
solution with elemental concentrations near the detection limit. The range
check analysis shows the accuracy which can be expected by the method for
results near the detection limits. The accuracy reported for these metals is
not unexpected.
Individual matrix spike recoveries were outside DQO for total tin in low
concentration matrix sample MQA927 with 126 percent recovery and for dissolved
aluminum, barium, and silver in medium concentration matrix sample MQA936 with
recoveries of 133, 64, and 68 percent, respectively. The results for these
metals in the specified matricies should all be considered to be semi-
quantitative due to the poor recoveries.
The serial dilution percent differences for total iron and dissolved
barium, calcium, and sodium in medium concentration sample MQA936 were above
DQO. Results for these metals in the medium concentration matrix should be
considered semi-quantitative except for the total iron results which should be
considered qualitative.
All total and dissolved beryllium, cobalt, copper, magnesium, manganese,
nickel, potassium, vanadium, and zinc results should be considered
quantitative. All total barium, calcium, sodium, and silver and dissolved
chromium and iron results should also be considered quantitative. All low
concentration dissolved metals results for aluminum, barium, calcium, sodium,
silver, and tin should be considered quantitative. Medium concentration total
aluminum and tin results, low concentration total iron results, and total
chromium results for samples MQA923, 934, 941, and 947 should be considered
quantitative. Medium concentration dissolved aluminum, barium, calcium,
sodium, and silver results, low concentration total chromium results, and low
concentration total and medium concentration dissolved tin results should be
-------
considered semi-quantitative. Low concentration total aluminum results, total
chromium results for sample MQA937, and medium concentration total iron results
should be considered qualitative. Total chromium results, with the above
mentioned exceptions, should not be used due to blank contamination. The
usability of all total and dissolved ICP metal analytes is summarized in
Section 4.2 and 4.3 at the end of this Report.
1.5 Mercury
Individual matrix spike recoveries were below DQO for total mercury in low
concentration matrix sample MQA927 with 70 percent recovery and for dissolved
mercury in medium concentration matrix sample MQA936 with 70 percent recovery.
Dissolved mercury results for the medium concentration samples (MQA936, 943,
945, and 956) should be considered qualitative. Total mercury results for the
low concentration samples should be considered semi-quantitative. All other
mercury results should be considered quantitative.
2.0 Inorganic and Indicator Analvtes
2.1 Performance Evaluation Standard
Inorganic and indicator analyte performance evaluation standards were not
evaluated in conjunction with the samples collected from this facility.
2.2 Inorganic and Indicator Analvte OC Evaluation
The average spike recoveries of all of the inorganic and indicator
analytes, except for chloride and cyanide in the low concentration samples and
POX and TOC in the medium concentration samples, were within the accuracy DQOs.
Accuracy DQOs have not been established for the bromide, fluoride, nitrite
nitrogen, and sulfide matrix spikes.
Average RPDs for all inorganic and indicator analytes, with the exception
of chloride from the low concentration samples, were within Program DQOs. The
RPDs were not calculated if either one or both of the duplicate values were
less than the CRDL. Precision DQOs have not been established for bromide,
fluoride, nitrite nitrogen, and sulfide.
Requested analyses were performed on all samples for the inorganic and
indicator analytes.
No laboratory blank contamination was reported for any inorganic or
indicator analyte. The field blank contained 176,000 ug/L of sulfide
contamination (the sulfide CRDL equals 1000 ug/L). This contamination is
discussed further in the next Section.
2.3 Inorganic and Indicator Analvte Data
All results for bromide, fluoride, sulfate, and TOX should be considered
quantitative with an acceptable probability of false negatives. There were 22
low concentration samples analyzed but only one matrix spike was analyzed for
cyanide, fluoride, chloride, bromide, nitrate and nitrite nitrogen, sulfate,
sulfide, and TOX. For this number of samples, two matrix spikes should have
been analyzed.
-------
The cyanide matrix spike recovery from the low concentration matrix
samples was below DQO with a recovery of 88 percent (DQO equals 90 to 110
percent). All low concentration matrix cyanide samples should be considered
semi-quantitative. All medium concentration cyanide results should be
considered quantitative.
The chloride matrix spike recovery from the low concentration matrix spike
was above DQO with a value of 111 percent (DQO equals 90 to 110 percent). The
laboratory duplicate RPD result for chloride in sample MQA927 was above DQO
with a value of 14 percent. All low concentration matrix chloride results
should be considered semi-quantitative. All medium concentration chloride
results should be considered quantitative.
The holding times for the nitrate and nitrite nitrogen analyses ranged
from 1 to 17 days from receipt of samples. The holding times for a portion of
the samples was longer than the recommended 48 hour holding time for
unpreserved samples. The nitrite nitrogen matrix spike recovery from the low
concentration matrix spike was above DQO with a value of 115 percent (DQO
equals 90 to 110 percent). Nitrate and nitrite nitrogen results should be
considered semi-quantitative except for results for sample MQA936 which should
be considered quantitative.
There were numerous unexplained peaks present in the total phenols raw
data. The source of these peaks is not known but the analytical laboratory has
suggested that there may be an equipment problem although there is no proof of
this. No total phenols were detected in the samples. The total phenols
results should be considered semi-quantitative due to this problem.
The TOC matrix spike recovery from the medium concentration matrix spike
was below DQO with a value of 35 percent (DQO equals 80 to 120 percent). All
medium concentration matrix TOC results should be considered qualitative with a
low bias. All low concentration matrix TOC results should be considered
quantitative.
Calibration verification standards for POC were not analyzed. A POC
spike solution was run during the analytical batch but the "true" value of the
spike was not provided by the laboratory. EPA needs to supply the inorganic
laboratory with a POC calibration verification solution. Until then, the
instrument calibration can not be assessed. POC holding times ranged from 13
to 17 days. Although the EMSL/Las Vegas data reviewers recommend a seven day
holding time, the laboratory has been instructed by the EPA Sample Management
Office that a 14 day holding time is acceptable. The POC results should be
considered qualitative.
The POX matrix spike recovery from the medium concentration matrix spike
was below DQO with a value of 25 percent (DQO equals 80 to 120 percent). The
medium concentration POX results should be considered qualitative. The low
concentration POX results should be considered quantitative.
Sulfide contamination was found in equipment blank MQA947 at a
concentration of 170,000 ug/1. The sulfide CRDL equals 1000 ug/L. Due to this
contamination all positive sulfide results, other than the trip, field, and
equipment blank, samples MQA923, 934, and 941, should not be used. The sulfide
-------
field duplicate precision for duplicate pair MQA932/933 was poor with 160,000
ug/L reported for the first sample and 77,000 ug/L reported for the second.
The comparative precision of the field duplicate results is not used in the
evaluation of sample results. It is not possible to determine the source of
this imprecision. This poor precision may be reflective of sample to sample
variation rather than actual sampling variations. Thus, field duplicate
precision is reported for informational purposes only.
3.0 Organics and Pesticides
3.1 Performance Evaluation Standard
Organic performance evaluation standards were not evaluated in conjunction
with the samples collected from this facility.
3.2 Organic OC Evaluation
All matrix spike average recoveries were within established Program DQOs
for accuracy. Individual matrix spike recoveries which were outside the
accuracy DQO will be discussed in the appropriate Sections below. All
surrogate spike average recoveries were within DQOs for accuracy. Individual
surrogate spike recoveries which were outside the accuracy DQO will be
discussed in the appropriate Sections below.
All matrix spike/matrix spike duplicate average RPDs, with the exceptions
of those for toluene in the medium concentration matrix samples and
trichlorobenzene in the low concentration matrix samples, were within Program
DQOs for precision. Individual matrix spike RPDs which were outside the
precision DQO will be discussed in the appropriate Sections below. All average
surrogate spike RPDs were within DQOs for precision. No surrogate standard was
used for the herbicide analysis.
All organic analyses were performed as requested. The medium
concentration sample results (MQA936, 943, 945, and 956) for semivolatiles,
pesticides, and herbicides were not included with the data package as they were
being reanalyzed due to poor acid fraction recovery.
Laboratory and sampling blank contamination was reported for organics and
is discussed in Reference 4 as well as the appropriate Sections below.
Detection limits for the organic fractions are summarized in Reference 4
as well as the appropriate Sections below.
3.3 Volatiles
Quality control data indicate that volatile organics were determined
acceptably. The chromatograms appear acceptable. Initial and continuing
calibrations, tunings and mass calibrations, matrix spikes and matrix spike
duplicates, surrogate spikes, and holding times were generally acceptable.
Laboratory blank contamination was reported.
Laboratory (method) blanks MB-1 through MB-6 contained methylene chloride
contamination. This common laboratory contaminant was present at levels of 5
to 11 ug/L. The methylene chloride CRDL is 5 ug/L. All positive methylene
-------
chloride results should not be used due to this laboratory blank contamination.
Laboratory (method) blanks MB-1 and MB-2 also contained acetone at values of
about one-half of the acetone CRDL of 10 ug/L. This had no impact on the data
as no acetone was detected in the field samples.
The instrument response factors for 2-chloroethylvinylether and 1,4-
dioxane in the initial and continuing calibrations were less that DQO. If
these analytes were present in the field samples, it might not be possible to
detect them. The absence of these two analytes may be a false negative result.
The RPD for toluene of 14 percent was greater than the DQO limit of 13
percent for matrix spike/matrix spike duplicate sample Q1536. This did not
affect data quality.
The organic analytical laboratory is not using the contract specified
primary ions to quantitate results for many of the HSL compounds. This has no
affect on the results. The laboratory has been made aware of this discrepancy
and is correcting it for future analyses.
The volatiles data are generally acceptable. Estimated method detection
limits were CRDL for all samples except Q1536 (10,000 times CRDL), Q1544 (20
times CRDL), Q1545 (5000 times CRDL), and Q1556 (5000 times CRDL). Dilution of
these samples was required due to high concentrations of organics. The
volatile compound results should be considered quantitative with the above
mentioned exceptions for positive methylene chloride results (unusable) and 2-
chloroethylvinylether and 1,4-dioxane (negative results are suspect). False
negatives for the samples (Q1536, 1544, 1545, and 1556) should be considered a
possibility due to large sample dilutions. The probability of false negative
results for all other compounds is acceptable.
3.4 Semivolatiles
Initial and continuing calibrations, tuning and mass calibrations, matrix
spikes/matrix spike duplicates, holding times, and chromatograms were
acceptable for the semivolatiles. Some problems were encountered with blanks
and surrogate spike recoveries. The results for the medium concentration
matrix samples (MQA936, 943, 945, and 956) were not included due to poor
surrogate recoveries. The laboratory indicated that these samples were being
reanalyzed.
Due to a dilution factor of 2.0, the estimated detection limits for the
semivolatiles were approximately twice the CRDL.
The phenol-D5 surrogate spike recoveries from samples MQA941 and MQA944
were 102 and 4 percent which are outside its DQO range of 10 to 94 percent.
There was no impact on the data usability as only one acid fraction surrogate
was affected.
One of the semivolatile laboratory (method) blanks, MB-1, contained 4-
methylphenol contamination at a concentration of 40 ug/L. The 4-methylphenol
CRDL is 10 ug/L. Sample Q1528 was extracted and analyzed on the same date as
MB-1 and also contains 4-methylphenol. 4-Methylphenol results for this sample
should not be used. Another of the semivolatile laboratory (method) blanks,
MB-2, contained bis(2-ethylhexyl)phthalate contamination at a concentration of
-------
8 ug/L. All positive bis(2-ethylhexyl)phthalate results should not be used.
Two of the semivolatile laboratory (method) blanks, MB-2 and MB-3, contained
unknown compound contamination at concentrations of 303, 203, and 9 ug/L. This
caused no impact on the data usability.
The organic analytical laboratory is not using the contract specified
primary ions to quantitate results for many of the HSL compounds. This has no
affect on the results. The laboratory has been made aware of this discrepancy
and is correcting it for future analyses.
The semivolatile data are acceptable and the results should be considered
quantitative for all samples with exceptions. Due to laboratory blank
contamination, the 4-methylphenol results for sample Q1528 should not be used.
The positive bis(2-ethylhexyl)phthalate results should not be used due to
laboratory blank contamination. The probability of false negatives for all
samples is acceptable.
3.5 Pesticides
The initial calibrations, matrix spike/matrix spike duplicates, blanks,
holding times, and chromatography for pesticides were acceptable. Surrogate
spike problems were encountered. The results for the medium concentration
matrix samples (MQA936, 943, 945, and 956) were not included due to poor
surrogate recoveries. The laboratory indicated that these samples were being
reanalyzed.
There were difficulties with the kepone analysis. Apparent kepone carry-
over from the kepone standards to the individual standards occurred. The
calibration factors for the kepone standards also exceeded DQO on several
occasions. Kepone was not detected in any samples.
The retention time shift for dibutylchlorendate on the confirmation column
was out of DQO on five occasions. This was not judged to affect data
usability.
The surrogate recovery of dibutylchlorendate from sample MQ'A939 was 195
percent which is above the DQO limits of 24 to 154 percent.
The estimated detection limits for the pesticides analyses is the CRDL.
The pesticides results should be considered quantitative with the exception of
the kepone analysis which should be considered unreliable.
3.6 Herbicides
Blanks, matrix spike/matrix spike duplicates, and chromatography were
acceptable for the herbicide analyses. No surrogate standard was used for the
herbicide analyses. The results for the medium concentration matrix samples
(MQA936, 943, 945, and 956) were not included. The laboratory indicated that
these samples were being reanalyzed.
The herbicides for which the laboratory analyzed include only 2,4-D,
2,4,5-T, 2,4,5-TP, chlorobenzilate, phorate, disulfoton, parathion, and
famphur.
-------
It was felt by the EMSL/Las Vegas data reviewers that the laboratory used
an inappropriate pair of columns to quantify and confirm the chloro-herbicides
analysis. Also, the laboratory should specify which column was used for
detection and which for confirmation so that data may be recalculated.
The use of DB-5 and DB-17 capillary columns for quantification and
confirmation for the chloro-herbicides is not acceptable as these two columns
are too similar.
The laboratory should have used a two column confirmation method to
analyze the organophosphorus herbicides.
The laboratory improperly established the retention time windows for the
chlorophenoxy acid herbicides on the DB-5 column on at least one date.
The proper external standard calibration procedure specified in Method
8150 was not followed as linearity over the calibration range was not
documented.
Chlorobenzilate could be more accurately determined by using the pesticide
method.
The herbicide results should be considered qualitative due to the lack of
herbicide surrogates and confirmation column analyses. The Chlorobenzilate
results should be considered unusable due to the inappropriate application of
the standard laboratory derivatization of Chlorobenzilate (ethyl ester) when
quantifying the methyl ester.
3.7 Dioxins and Dibenzofurans
Dioxin and dibenzofuran spike recovery from the blank spiked sample ranged
from 74 to 96 percent which is considered to be acceptable accuracy. No
performance evaluation standard was evaluated with the samples. No precision
(RPD) information was available as no dioxins were detected in the duplicate
samples (MQA931 and MQA931D). No contamination was found in the laboratory
(method) blanks.
Due to a method modification supplied to the laboratory by the Sample
Management Office, the column performance check solution was not analyzed by
the laboratory.
The internal standards shifted in scan number and retention time in the
initial and continuing calibrations. This could cause a problem with the
automatic data system and some isomers may have not been detected.
The laboratory is using two different methods to calculate RPDs.
The dioxin and dibenzofuran results should be considered to be semi-
quantitative because the method precision has not been established. False
negative results are a possibility due to shifts in the internal standards. No
dioxins or dibenzofurans were detected in any of the field samples.
-------
III. Data Usability Summary
4.0 Graphite Furnace Metals. Total
Quantitative:
Semi-quantitative:
Qualitative:
Unusable:
all'antimony, arsenic, and selenium results; all low
concentration lead results with exceptions; all medium
concentration lead and cadmium results
all low concentration cadmium results
all low concentration thallium results; lead results for
samples MQA924 and 937 (see Section 1.3 for explanations)
all medium concentration thallium results (see Section 1.3
for an explanation)
4.1 Graphite Furnace Results. Dissolved
Quantitative:
Semi-quantitative:
Qualitative:
all lead, selenium, and thallium results; all medium
concentration antimony results; arsenic results with
exceptions
all antimony and cadmium low concentration results; arsenic
results for samples MQA924, 929, 930, 931, 936, and 937
all medium concentration cadmium results (see Section 1.3
for an explanation)
4.2 ICP Metals. Total
Quantitative:
Semi-quantitative:
Qualitative:
Unusable:
all barium, beryllium, calcium, cobalt, copper, magnesium,
manganese, nickel, potassium, silver, sodium, vanadium, and
zinc results; all medium concentration aluminum and tin
results; all low concentration iron results; chromium
results for samples MQA923, 934, 941, and 947
all low concentration chromium and tin results
all low concentration aluminum results; all medium
concentration iron results; chromium results for sample
MQA937 (see Section 1.4 for explanations)
chromium results with the above exceptions (see Section 1.4
for an explanation)
4.3 ICP Metals. Dissolved
Quantitative:
Semi-quantitative:
4.4 Mercury
Quantitative:
Semi-quantitative:
Qualitative:
all beryllium, chromium, cobalt, copper, iron, magnesium,
manganese, nickel, potassium, vanadium, and zinc results;
all low concentration aluminum, barium, calcium, sodium,
silver, and tin results
all medium concentration aluminum, barium, calcium, sodium,
silver, and tin results
mercury results with exceptions
all low concentration total mercury results
dissolved mercury results for medium concentration samples
MQA936, 943, 945, and 956 (see Section 1.5 for an
explanation)
-------
4.5 Inorganic and Indicator Analvtes
Quantitative:
Semi-quantitative:
Qualitative:
Unusable:
4.6 Organics
Quantitative:
Qualitative:
Unreliable:
Unusable:
all bromide, fluoride, sulfate, and TOX results; all medium
concentration cyanide and chloride results; all low
concentration TOC and POX results; nitrate and nitrite
nitrogen results for sample MQA936; sulfide results for
blanks MQA923, 934, 941, and 947; all negative sulfide
results
nitrate and nitrite nitrogen results with an exception; all
low concentration cyanide and chloride results; all total
phenols results
all POC results; all medium concentration TOC and POX
results (see Section 2.3 for explanations)
all positive sulfide results with exceptions (see Section
2.3 for an explanation)
volatile, semivolatile, and pesticide results, all with
exceptions
herbicides with exceptions (see Section 3.6 for an
explanation)
2-chloroethylvinylether and 1,4-dioxane (volatiles)
results (see Section 3.3 for an explanation); all kepone (a
pesticide) results (see Section 3.5 for an explanation)
all positive methylene chloride (a volatile) results (see
Section 3.3 for an explanation); 4-methylphenol (a
semivolatile) results for sample Q1528 (see Section 3.4 for
an explanation); all positive bis(2-ethylhexyl)phthalate (a
semivolatile) results (see Section 3.4 for an explanation);
all chlorobenzilate (an herbicide) results (see Section 3.6
for an explanation)
4.7 Pioxins and Dibenzofurans
Semi-quantitative: all dioxin and dibenzofuran results
-------
IV. References
1. Organic Analyses: EMSI
2421 West Hillcrest Drive
Newbury Park, CA 91320
(805) 388-5700
Inorganic and Indicator Analyses:
Centec Laboratories
P.O. Box 956
2160 Industrial Drive
Salem, VA 24153
(703) 387-3995
Dioxin/Dibenzofuran Analyses:
CompuChem Laboratories, Inc.
P.O. Box 12652
3308 Chapel Hill/Nelson Highway
Research Triangle Park, NC 27709
(919) 549-8263
2. Draft Quality Control Data Evaluation Report (Assessment of the Usability
of the Data Generated) for site 44, BFI/CECOS, Westlake, Louisiana, 4/21/1987,
Prepared by Lockheed Engineering and Management Services Company, Inc., for the
US EPA Hazardous Waste Ground-Water Task Force.
3. Draft Inorganic Data Usability Audit Report, for the BFI/CECOS, Westlake,
Louisiana facility, Prepared by Laboratory Performance Monitoring Group,
Lockheed Engineering and Management Services Co., Las Vegas, Nevada, for US
EPA, EMSL/Las Vegas, 4/21/1987.
4. Draft Organic Data Usability Audit Report, for the BFI/CECOS, Westlake,
Louisiana facility, Prepared by Laboratory Performance Monitoring Group,
Lockheed Engineering and Management Services Co., Las Vegas, Nevada, for US
EPA, EMSL/Las Vegas, 4/22/1987.
5. Draft Dioxin/Dibenzofuran Usability Audit Report, for the BFI/CECOS,
Westlake, Louisiana facility, Prepared by Laboratory Performance Monitoring
Group, Lockheed Engineering and Management Services Co., Las Vegas, Nevada, for
US EPA, EMSL/Las Vegas, 4/21/1987.
-------
V. Addressees
Gareth Pearson
Quality Assurance Division
US EPA Environmental Monitoring Systems Laboratory - Las Vegas
P.O. Box 1198
Las Vegas, Nevada 89114
Richard Steimle
Hazardous Waste Ground-Water Task Force, OSWER (WH-562A)
US Environmental Protection Agency
401 M Street S.W.
Washington, DC 20460
Thomas Aalto
US Environmental Protection Agency
1201 Elm Street
Dallas, TX 75270
Michael Daggett
US Environmental Protection Agency
6608 Hornwood Drive
Houston, TX 77074
John Haggard
US Environmental Protection Agency
1860 Lincoln Street
Denver, CO 80295
Paul Friedman
US Environmental Protection Agency
401 M Street S.W.
Washington, DC 20460
Chuck Hoover
Laboratory Performance Monitoring Group
Lockheed Engineering and Management Services Company
P.O. Box 15027
Las Vegas, Nevada 89114
-------
SUMMARY OF CONCENTRATIONS FOR COMPOUNDS FOUND
IN GROUND-WATER AND SAMPLING
BLANK SAMPLES AT SITE 44, BFI, CECOS, WESTLAKE, LA
The following table lists the concentrations for compounds analyzed for
and found in samples at the site. Table A2-1 is generated by listing
all compounds detected and all tentatively identified compounds reported
on the organic Form I, Part B. All tentatively identified compounds
with a spectral purity greater than 850 are identified by name and
purity in the table. Those with a purity of less than 850 are labeled,
unknown.
Sample numbers are designated by the inorganic and corresponding organic
cample number.
A2-1
-------
TABLE KEY
A value without a flag indicates a result above the contract
required detection limit (CRDL).
J Indicates an estimated value. This flag is used either when
estimating a concentration for tentatively identified compounds
where a 1:1 response is assumed or when the mass spectral data
indicated the presence of a compound that meets the identification
criteria but the result is less than the specified detection limit
but greater than zero. If the limit of detection is 10 pg and a
concentration of 3 pg is calculated, then report as 3J.
B This flag is used when the analyte is found in the blank as well as
a sample. It indicates possible/probable blank contamination and
warns the data user to take appropriate action.
GW * ground-water
SW m surface-water
low and medium are indicators of concentration.
TIC = Tentatively identified compound.
A2-2
-------
SITE NO: 44 BH E3JS, UESTLAKE, Lfi
CASE NO: C-23£3tt
SAWLE NO:
SAiFLE LOCATION:
SA*'LE TYPE:
VOfl CARBON TETRACORIDE
CHLDROFDRr.
CORQETHAfc
1, 1-DICHLDROETHWc
KETHYLENE CHLORIDE
TRAN5-1 . S-DICHLDROETHEKE
TRICKLDRQETHEKE
1.1.2-TRICKLOROETHANE
VINYL CHLORIDE
fW^A — J U 1 f*L^ '^Cjlf 1 Lrr. ""^C. 1 rT^rt
VOQ TR1CH OPfTPl 1 inftflK™T"H(^^^
TIC- KEJCANE.
unc K^TWYI pv^t fiDPxrrflw^
VUn rV. 1 niL. L I u^uJ^u* ' fwC.
URAK,TETRAHYDRO
SEKI- BIS(2-ETHYLHE)tYL)PHTHflLATE
VGA DI-h-BUTYLPHTHftLATE
PHENOL
HERB E,4,5 T
PEST NO HITS
BNfl- UWNOHN ACID ESTER
TIC BICYHO(4.1.0)KEPTftȣ,7.7-DICHLDRO
DLDROBENZOIC KID
CYCLOHEXANOL
DIETHYLEJE B.YCCL
UKNDW
UNKNOUN ~ ~ '"
UWOUN
UNKNOUN
UWCWN " " '
DIOXIN/ tB HITS
FURAN
TOTAL ALUKIWJK
KETALS Af,TldNY
ARSENIC
BARIUK
BERYLUUK
CADMIUM
-- CALCIUPI
CHRWILM
COBALT
COPPER
IRON
LEAD
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SITE NO: 44 BPJ CEOS, MESTLAKE, LA
CASE NO: C-2363HB
SA*l£ NO: HM932/Q1532 (OA933/B1533 K»945/Q1545 MOH56/C1556 «W32£/Q'52£ KQA259
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-
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-------
SHI NO: 44 BH CECOE, UESTLflKE, Lfi
CASE ND: C-23£3HC
SAMPLE NO:
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SITE PC: *» VI CE02S, UESTLflKE, Lfl
CASE NO: C-£3£3HQ
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-------
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-------
SITE NO: 44 VI CEOS, WESTUKE, Lfl
BSE NO: C-2363K2
SAWU NO:
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-------
SITE «: 44 VI CEZE, ICSTUJKE, LA
CASE NO: C-2363HQ
SAMPLE NO:
SAMPLE LOCATION:
SAMPLE TYPE:
CIS. ALUMIUX
KETALS ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
CADMItf
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SITE NO: M BFI
COSE. X:i C-2363HG
ItSTLAKE, LA
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A2-11
-------
CfiSE NO: C-23o3HQ
SPHPLE NO*
SflWLE LOCATION:
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78
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301
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A2-12
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SITE NO: ** BFI CE2E, tCSTLAKE,
CASE NO: C-23£3HQ
SAMPLE NO:
SfWLE LCCATION:
SAHPLE TYPE:
LA
WELL^-3
6--LDU
01557
WELL «>•£
VOA
CARBON TETRACHLDRIDE
CHLDROFDRH
i,l-i
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KETHYLENE CHLORIDE
TRftNS-i.2-1
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I
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WOWJN ACID ESTER
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DLDRDBENZOIC ACID
CYCLOHEJANOL
CYODHEJANDfe
DIETHYLDE BLYCOL
(tWUH
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FURAN
TOTAL ALUKINUM
AtfTIMDNY
ARSENIC
BARIUM
BERYLLIUK
CADKIUW-
CALCIUH
CHROKIUK
COBALT
COPPER
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POTASSIUM
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PESTICIDE,
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ANALYSES
NOT
REQUIRED
INORSAKIC
NOT REQUIRED
FDR THIS
SAWLE
17
54
15
21
9 J
BNA.
PESTICIDE,
HERBICIDE
ANALYSES
NOT
REQUIRED
INORSANi:
ANALYSES
NOT RECUIRED
FDR THIS
SAMPLE
A2.
•-li
-------
SITE KO: 44 BFI CPK, WESTLAKE, Lfl
CASE MQ: C-£3o3H&
SAMPLE NO:
SA*LE LOCATION:
SAtfLE TYPE:
01546
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01557
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DIS. fiLLttlK*
INORS.
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PSTASSIUP!
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TIN
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BROKIDE
CHLORIDE ~
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NITRITE NITROEN
POC
POX
SULFflTE
SILFIDE
TDC
TDTftL WDDLS
TDX
fill CO?:^CR;.~:D?" c-
,.-./•
-------
APPENDIX B
CONCENTRATIONS OF VOLATILE PRIORITY POLLUTANTS
FOURTH QUARTER, 1986
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APPENDIX C
GEOLOGIC CROSS-SECTIONS
-------
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:—H !North
li.E6EKi'D' .
M.L OTUSC. 4
200 f»«t
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CROSS SECTION ONE
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APPENDIX D
INVENTORY OF WELLS
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-------
Table A2: Inventory of Borings
Calcasieu Facility, Calcasieu Parish, LA
Inventory of All Soil Borings and Wells
Boring #
MW-
16
WWN
WWS
L-
L-
L-
L-
L-
L-
Li™
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
X
G
D
G
G
D
D
F
E
D
E
E
D
D
E
F
D
D
D
G
F
G
F
G
F
D
E
G
D
E
G
D
E
G
A
B
A
B
D
A
B
D
A
B
D
B
D
K
Y
9
6
9
6
11
5
11
5
5
5
5
6
5
5
5
9
5
6
5
6
5
6
6
5
1
1
3
3
3
1
5
4
4
5
5
7
6
7
8
8
8
10
9
10
11
11
11
Description
(If Well)
CORR/PIEZ
CORR/PIEZ
COMPL/PIEZ
PIEZ
GROUTED
COMPL/PIEZ
PIEZ
PIEZ
GROUTED
PIEZ
PIEZ
COMPL/PIEZ
COMPL/PIEZ
GROUTED
COMPL/PIEZ
COMPL/PIEZ
GROUTED
COMPL/PIEZ
COMPL/PIEZ
COMPL/PIEZ
COMPL/PIEZ
-
Other
Number
MW-16
WWS
MW-1
MW-2
MW-3
MW-4
MW-5
MW-11
MW-9
MW-10
MW-8
MW-7
MW-14
MW-1 2
MW-13
MW-25
MW-2 4
MW-26
Total Surveyed
Depth Surface
Drilled Elev.
340
400
154
37
30
30
60
57
25
50
50
25
12
25
25
22
25
27
70
70
80
80
80
80
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
Location
of Log
(Report)
CAPOZZOLI,
CAPOZZOLI,
CAPOZZOLI,
CAPOZZOLI,
CAPOZZOLI,
CAPOZZOLI,
CAPOZZOLI,
CAPOZZOLI,
CAPOZZOLI,
CAPOZZOLI,
CAPOZZOLI,
CAPOZZOLI,
CAPOZZOLI,
CAPOZZOLI',
CAPOZZOLI,
CAPOZZOLI,
SOIL TEST,
SOIL TEST,
SOIL TEST,
SOIL TEST,
SOIL TEST,
SOIL TEST,
SOIL TEST,
SOIL TEST,
SOIL TEST,
SOIL TEST,
SOIL TEST,
SOIL TEST,
. SOIL TEST,
SOIL TEST,
SOIL TEST,
SOIL TEST,
SOIL TEST,
SOIL TEST,
SOIL TEST,
SOIL TEST,
SOIL TEST,
SOIL TEST,
CAPOZZOLI,
,
»
9/77
9/77
9/77
9/77
9/77
12/78
12/78
12/78
8/79
8/79
8/79
8/79
8/79
8/79
8/79
8/79
4/81
4/81
4/81
4/81
4/81
4/81
4/81
4/81
4/81
4/81
4/8L
4/81
4/81
A/83.
4/81
4/81
4/81
4/81
4/81
4/81
4/81
4/81
4/81
TR1EGEL & ASSOCIATES, INC.
-------
Table A2: Inventory of Borings (Page 2)
Calcasieu Facility, Calcasieu Parish, LA
Inventory of All Soil Borings and Wells
Boring #
L-
L-
L-
AJ"""
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
ij~~
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
L-
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
X
J
G
E
K
J
G
E
K
J
G
G
G
G
G
G
G
G
F
G
F
F
G
F
F
E
F
F
E
G
G
E
F
F
D
G
G
D
E
E
D
D
D
D
E
G
G
E
y
11
12
12
13
13
13
14
14
14
14
9
7
9
9
9
9
9
9
9
9
9
9
9
8
7
7
8
8
9
11
11
11
10
10
11
5
5
8
8
11
11
11
11
11
10
8
5
Description
(If Well)
COMPL/PIEZ
CORR/PIEZ
CORR/PIEZ
COMPL/PIEZ
COMPL/PIEZ
COMPL/PIEZ
COMPL/PIEZ
COMPL/PIEZ
COMPL/PIEZ
Other
Number
MW-15
B-9
B-10
B-ll
B-12
B-13
B-14
B-15
B-16
B-17
B-18
B-19
B-20
B-21
MW-17
MW-18
MW-2R-
MW-2R
B-22
MW-19
MW-20
MW-21
MW-22
MW-23
Total
Depth
Drilled
60
60
60
60
60
60
60
60
60
60
90
55
60
60
60
60
40
44
150
60
50
50
50
60
60
60
60
60
65
65
65
64.5
64.5
180
200
170
170
157.5
115
1 22
13
18
50
50.5
55.5
60
50
Surveyed
Surface
Elev.
2
15
21
20
25
25
2
2
1
1
16
21
20
21
.4
.3
.6
.6
.7
.6
.4
.2
.8
.1
.1
.4
.4
.4
Location
of Log
(Report)
CAPOZZOLI, 4/81
CAPOZZOLI, 4/81
CAPOZZOLI, 4/81
CAPOZZOLI, 4/81
CAPOZZOLI, 4/81
CAPOZZOLI, 4/81
CAPOZZOLI, 4/81
CAPOZZOLI, 4/81
CAPOZZOLI, 4/81
CAPOZZOLI, 4/81
SOIL TEST, 7/81
WCC, 3/82
WCC, 3/82
WCC, 3/82
WCC, 3/82
WCC, 3/82
WCC, 3/82
WCC, 3/82
WCC, 3/82
WCC, 3/82
WCC, 3/82'
WCC, 3/82
WCC (NOT DATED)
WCC (NOT DATED)
WCC (NOT DATED)
WCC (NOT DATED)
WCC (NOT DATED)
WCC (NOT DATED)
SOIL TEST
SOIL TEST
SOIL TEST
SOIL TEST
SOIL TEST
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
TRIEGEL & ASSOCIATES, INC.
-------
Table A2: Inventory of Borings (Page 3)
Calcasieu Facility, Calcasieu Parish, LA
Inventory of All Soil Borings and Wells
Boring #
L- 92
L- 93
L- 94
L- 95
L- 96
L- 97
L- 98
L- 99
L-100
L-101
L-102
L-103
L-104
L-105
L-106
L-107
L-108
L-109
L-110
L-lll
L-112
L-113
L-114
L-115
L-116
L-117
L-118
L-119
L-120
L-121
L-122
L-123
L-124
L-125
L-126
L-127
L-128
L-129
L-130
L-131
L-132
L-133
L-134
L-135
L-136
L-137
L-138
Description
X Y (If Well)
D 9
D 10
E 11
F 9
E 9
D 9
E 10
E 10
G 8
F 7
F 7
G 5
E 6
E 6
E 6
D 7
E 7
F 6
F 6
E 6
D 5
D 6
D 9
C 6
C 7
C 7
C 8
C 5
C 6
C 6
C 7
C 7
C 8
C 8
C 9
C 9
C 10
C 5
C 6
B 7
B 7
B 8
C 8
C 9
C 9
C 10
B 5
Other
Number
B-24
B-25
B-26
B-27
B-28
B-29
B-30
B-31
B-32
B-33
B-34
B-35
B-36
B-37
B-38
B-39
B-40
B-41
B-42
B-43
B-44
B-45
B-46
B-47
B-48
B-49
B-50
B-51
B-52
B-53
B-54
B-55
B-56
B-57
B-58
B-59
B-60
B-61
B-62
B-63
B-64
B-65
B-66
B-67
B-68
B-69
B-70
Total
Depth
Drilled
32
30
34
30
30
30
69.5
90
50
50
50
50
50
52
50
80
50
60
60
60
60
60
60
60
60
60
61.5
60
60
60
60
61.5
60
60
60
60
60
60
60
60
61.5
60
60
60
60
60
60
Surveyed
Surface
Elev.
20.5
14.2
6.6
22.4
23.3
23.5
23
28.6
22.2
23.3
24.7
21.3
24.2
23.8
23.3
21.2
25.3
30
28.2
24.4
20.9
20.2
21.5
16
18.6
19.6
20.5
18.2
11.4
17.7
19
19.4
20.5
19.9
19.6
20.9
20.3
18
11.5
20.9
20.3
20.6
19.1
20.7
20.8
19.5
18.3
Location
of Log
(Report)
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
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WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
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WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
WCC, 2/16/83
TRIEGEL& ASSOCIATES, INC.
-------
Table A2: Inventory of Borings (Page 4)
Calcasieu Facility, Calcasieu Parish, LA
Inventory of All Soil Borings and Wells
Boring #
L-139
L-140
L-141
L-142
L-143
L-144
L-145
L-146
L-147
L-148
L-149
L-150
L-151
L-152
L-153
L-154
L-155
L-156
L-157
L-158
L-159
L-160
L-161
L-162
L-163
L-164
L-165
L-166
L-167
L-168
L-169
L-170
L-171
L-172
L-173
L-174
L-175
L-176
L-177
L-178
L-179
L-180
L-181
L-182
L-183
L-184
L-185
X
B
B
B
B
B
B
B
A
A
A
A
A
A
A
F
F
F
E
F
F
F
F
E
E
F
E
E
E
E
F
G
E
G
D
F
F
B
D
D
D
E
E
E
E
E
E
E
Y
6
6
7
7
8
9
9
6
7
7
8
6
7
8
10
10
11
12
12
11
11
12
12
12
12
12
12
13
13
9
11
4
11
11
6
6
9
9
9
9
9
9
8
7
7
7
7
Description
(If Well)
CORR/PIEZ
COMPL/PIEZ
COMPL/PIEZ
COMPL/PIEZ
RW/PIEZ
COMPL/PIEZ
CORR/PIEZ
COMPL/PIEZ
CORR/PIEZ
CORR/PIEZ
CORR/PIEZ
CORR/PIEZ
CORR/PIEZ
PIEZ
PIEZ
PIEZ
PIEZ
PIEZ
Other
Number
B-71
B-72
B-73
B-74
B-75
B-76
B-77
B-78
B-79
B-80
B-81
B-82
B-83
B-84
B-85
B-86
B-87
B-88
B-89
B-90
B-91
B-92
B-93
B-94
B-95
B-96
B-97
B-98
B-99
MW-27
MW-28
MW-24R
MW-29
MW-30
MW-31
MW-32
MW-33
PT-1
PT-2
PT-3
PT-4
PT-5
P-l
P-2
P-2A
P-3
P-3A
Total
Depth
Drilled
60
60
60
60
60
60
180
60
60
60
60.
150
60
60.5
60
60
60
60
60
60.5
60
60
60
60
60
60
60
60
200
60
110
54
45.5
26
95
53
90
57.5
57.5
61.5
53.5
53.5
59
55
58
53
60
Surveyed
Surface
Elev.
9.1
11
20.3
20.2
18.7
18.7
18.8
5.1
11.8
17.2
16.1
3.3
14.7
18.6
20.1
19.4
19.4
9.2
9.7
17.9
16.6
11.9
10.9
8.4
11.1
12.4
10.8
12.8
12
18.63
15.1
19.54
15.66
3.45
24.86
25.21
14.98
24.6
25.4
25.2
23.1
23.1
25.7
26.4
26.4
25.3
25.3
Location
of Log
(Report)
wcc,
WCC,
WCC,
WCC,
WCC,
WCC,
WCC,
WCC,
WCC,
WCC,
wcc,
WCC,
wcc,
WCC,
WCC,
WCC,
WCC,
WCC,
wcc,
WCC,
wcc,
WCC,
WCC,
WCC,
WCC,
WCC,
wcc,
WCC,
WCC,
WCC,
WCC,
WCC,
WCC,
WCC,
wcc,
WCC,
WCC,
WCC,
wcc,
WCC,
WCC,
WCC,
WCC,
WCC,
WCC,
WCC,
WCC,
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
2/16/83
4/24/83
4/24/83
4/24/83
10/14/83
10/14/83
10/14/83
10/14/83
10/14/83
6/13/85
6/13/85
6/13/85
6/13/85
6/13/85
6/13/85
6/13/85
6/13/85
6/13/85
6/13/85
TRIEGEL & ASSOCIATES, INC.
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Table A2: Inventory of Borings (Page 5)
Calcasieu Facility, Calcasieu Parish, LA
Inventory of All Soil Borings and Wells
Boring #
L-186
L-187
L-188
L-189
L-190
L-191
L-192
L^193
L-194
L-195
L-196
L-197
L-198
L-199
L-200
L-201
L-202
L-203
L-204
L-205
L-206
L-207
L-208
L-209
L-210
L-211
L-212
L-213
L-214
L-215
L-216
L-217
L-218
L-219
L-220
L-221
L-222
L-223
L-224
L-225
L-226
L-227
L-228
L-229
L-230
L-231
L-232
X
E
E
D
D
D
D
D
F
D
E
E
D
D
F
F
E
E
E
E
E
E
D
D
E
E
E
E
F
F
F
F
F
G
F
D
D
F
F
E
D
E
F
G
G
G
C
C
Y
7
7
7
8
8
11
11
9
7
7
7
9
10
10
9
9
9
8
7
7
7
8
9
8
10
10
9
9
11
8
9
9
10
11
11
11
10
10
8
8
6
6
5
7
9
9
10
Description
(If Well)
PIEZ
PIEZ
PIEZ
PIEZ
PIEZ
PIEZ
PIEZ
PIEZ
PIEZ
PIEZ
PIEZ
RW/PIEZ
COMPL/PIEZ
CORR/PIEZ
CORR/PIEZ
CORR/PIEZ
CORR/PIEZ
CORR/PIEZ
CORR/PIEZ
COMPL/PIEZ
COMPL/PIEZ
COMPL/PIEZ
Other
Number
P-4
P-4A
P-5
P-6
P-6A
P-7
P-8
P-9
P-10
P-ll
P-12
CLB-1
CLB-2
CLB-3
CLB-4
CLB-5
CLB-5A
CLB-6
B-100
B-101
B-102
B-103
B-104
B-105
B-106
B-107
B-108
B-109
B-110
B-lll
B-112
B-113
B-114
B-115
MW-35
MW-36
MW-38
MW-39
MW-41
MW-42
MW-43
MW-44
MW-45
MW-46
MW-47
B-116
B-117
Total
Depth
Drilled
55
54
61
57
50
23
24
58
50
50
54
12
16.5
18
20
24
25
20
100
105
90
91.5
100
96
98
82
90
78
78
94
86
80
80
86
24
16
56
104
100
62
54
54
54
54
62
60
60
Surveyed
Surface
Elev.
22.1
22.1
23.3
20.4
20.4
3.4
4
24.05
25.8
27.07
27.88
27.8
29.4
28.8
30.5
29
29
27.6
26.4
25.3
22.1
20.4
27.85
27.64
29.21
11.85
28.5
20.94
25.33
21.89
23.19
22.43
24.63
3.69
3.62
21.92
27.86
24.11
21.75
26.6
24.65
20.87
21.2
21.11
Location
of Log
(Report)
WCC, 6/13/85
WCC, 6/13/85 .
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13785
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85 ,
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85 %
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
TRIEGEL & ASSOCIATES, INC.
-------
Table A2: Inventory of Borings (Page 6)
Calcasieu Facility, Calcasieu Parish, LA
Inventory of All Soil Borings and Wells
Boring #
L-233
L-234
L-235
L-236
L-237
L-238
L-239
L-240
L-241
L-242
L-243
L-244
L-245
L-246
L-247
L-248
L-249
L-250
L-251
L-252
L-253
L-254
L-255
L-256
L-257
L-258
L-259
L-260
L-261
X
C
C
C
D
D
C
C
G
G
E
E
F
F
G
G
G
G
G
D
G
F
E
E
F
F
E
E
D
E
Y
10
11
12
12
12
10
9
8
8
10
10
10
10
8
9
8
6
9
9
8
10
10
9
10
9
9
9
8
8
Description
(If Well)
COMPL/PIEZ
COMPL/PIEZ
CORR/PIEZ
CORR/PIEZ
CORR/PIEZ
CORR/PIEZ
CORR/PIEZ
CORR/PIEZ
UIC
(OLD L-240)
(OLD L-241)
(OLD L-242)
COMPL/PIEZ
RW
RW
RW
RW
COMPL/PIEZ
COMPL/PIEZ
Other
Number
B-118
B-119
B-120
B-121
B-122
MW-48
MW-49
P-13
P-14
P-15
P-16
P-17
P-18
MW-50
B-123
B-124
B-125
MW-51
RW-1
RW-2
RW-3
RW-4
39B
39C
39D
39E
Total
Depth
Drilled
60
60
60
60
60
62
26
65
65
75
75
75
75
1144
88
80
80
62
64
65
74
75
54
16
79.5
40
MW-52/39F 104
41B
40
MW-53/41C 100
Surveyed
Surface
Elev.
20.4
21
22.15
22.18
26.32
22.66
23.47
19.8
21.7
19.8
20.1
20.9
24.2
19.7
22.9
27.0
22.9
21.5
22.8
23.0
23.1
20.9
23.9
Location
of Log
(Report)
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
LAYNE, 5/23/85
WCC, 10/25/85
WCC, 10/25/85
WCC, 10/25/85
WCC, 10/25/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
WCC, 6/13/85
TAI, 3/30/87
TAI, 3/30/87
TAI, 3/30/87
TAI, 3/30/87
TAI, 3/30/87
TAI, 3/30/87
TAI, 3/30/87
Blanks: Data not available or not applicable
COMPL: Compliance PIEZ: Piezoraetric CORR: Corrective
RW: Corrective Action, Recovery Well
UIC: Underground Injection Control (3/25/87)
TRIEGEL & ASSOCIATES, INC.
------- |