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.
                                   -1-

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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.
                                   -2-

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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.]
                                  -3-

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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

                                  -4-

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               Figure 1.  Site location map,  Louisiana.  Scale 1:2,500,000,
                                          -5-

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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
                                   -6-

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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.
                                  -8-

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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.
                                  -9-

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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

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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).
                                  -31-

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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".
                                  -32-

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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-

-------
     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-

-------
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-

-------
         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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                                                                                                                                                                         r>

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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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RECOVERY WELL RW-3 DETAILS
BFI WASTE MANAGEMENT
CALCASIEU FACILITY
WILLOW SPRINGS, LOUISIANA
*
BROKING-FERRIS INDUSTRIES,
CHEMICAL SERVICES, INC.
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              Figure 8  .
GENERALIZED RECOVERY WELL CONSTRUCTION

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     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
                                  -54-

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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.
                                  -56-

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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
                                  -57-

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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.
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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.
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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.
                                            -76-

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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

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              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

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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

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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

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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

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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.

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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

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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

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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

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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.
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URAK,TETRAHYDRO
SEKI- BIS(2-ETHYLHE)tYL)PHTHflLATE
VGA DI-h-BUTYLPHTHftLATE
PHENOL
HERB E,4,5 T
PEST NO HITS
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TIC BICYHO(4.1.0)KEPTftȣ,7.7-DICHLDRO
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KETALS Af,TldNY
ARSENIC
BARIUK
BERYLUUK
CADMIUM
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CHRWILM
COBALT
COPPER
IRON
LEAD
HASfESIUM
MANGANESE
KERCURY
NICKEL
POTASSIUM
SELENIUM
SILVER
SODIUM
THALLIUK
TIN
VftNSIUtf
ZINC
«A923/C:523
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IPUR 971 90
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NOT REQUIRE!
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A2-3

-------
 SITE MO: M  FI CEOE,
 CASE MO: C-23£3HB
                                 LA
       LOCflTIOH:
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       PCC
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       SLLFIK
       TDC
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                                                   115
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                                                  A07
                                                   19
139
378
 15
                                                              J7£OQO
                                     129

                                      9
              £83
                                    393
                                     17
                      254
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                                                   520
                      525
                       15
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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
SA*v£ LOCATION: W£u. Mr-16 WELL *-16 WELL *~47 WEL. »W-47 HEo. *^2l WELT^-*'
SAW.! TYPE: 6*-LDW 6w-LDw DtF Br-M£t frr-MEL DUP 6HA S-^LoTDUP
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1, 1-DICHLDROHHAN£
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1. P~pICK^QRQ^THft?£
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FURAN
TOTAL ALUWNUK
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PUR 920 30 J
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-



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-------
SHI NO: 44  BH  CECOE, UESTLflKE, Lfi
CASE ND: C-23£3HC
SAMPLE NO:
SA*^ LOCATION:
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-------
 SITE PC: *»  VI CE02S,  UESTLflKE, Lfl
 CASE NO: C-£3£3HQ
SOCLE NO:
SOCLE LOCATION:
SOCLE TYPE:
VOfl CARBON TETROXDRIDE
DLDRCRWH
CHLDRQETHOE
l.l-DItX.OROETH»e
1,1-DICK_DROETHENE
1.2-DICKLOROETHWe
KETHYLENE CHJRIDE
TRflNS-i. ?-DIDU)R[ETHENE
TETRACK-DROETHENE
TRICHLDROETHENE
VINYL CHLORIDE
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VDA TRICHLDROFLUOROKETme
TIC- HEXANE
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VOfl DI-tf-BUTYLPHTHALATE
.PHENOL

HERB 2,4,5 T
PEST NO HITS
BNA- IflKNOUJ KID ESTER
TIC BICYCLD(4.1.0)HEPTANE,7,7-DIDii)RO
CHLORDBENZOIC KID
CYCLDKEXANOL
CYCLOHEXANONE
DIETHYLENE BLYCOL
UNKNOWN
UWNQtM
UNKNOWN . . _
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-------
SITE NO: 44 VI CEOS, WESTUKE, Lfl
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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
CALCIU1
CHROK1U1
COBALT
COPPER
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-------
SITE NO:  M   BFI
COSE. X:i  C-2363HG
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-------
  CfiSE NO: C-23o3HQ
SPHPLE NO*
SflWLE LOCATION:
SflHPLE TYPE:
CIS. ALLWIWX
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ARSENIC
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-------
SITE NO: **  BFI CE2E,  tCSTLAKE,
CASE NO: C-23£3HQ

SAMPLE NO:
SfWLE LCCATION:
SAHPLE TYPE:
                                  LA
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-------
SITE KO:  44  BFI  CPK, WESTLAKE,  Lfl
CASE MQ:  C-£3o3H&

SAMPLE NO:
SA*LE LOCATION:
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fill CO?:^CR;.~:D?" c-
                         ,.-./•

-------
                  APPENDIX B






CONCENTRATIONS OF VOLATILE PRIORITY POLLUTANTS



             FOURTH QUARTER, 1986

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                        TRIEGEL & ASSOCIATES, INC.

-------
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
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 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.

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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.

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