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Chicago, IL 60604-3590
GROUND WATER MONITORING EVALUATION
SOUTHERN WOOD PIEDMONT
AUGUSTA, GEORGIA
UPDATE
The Hazardous Waste Ground Water Task Force evaluated the Southern Wood
Piedmont facility in Augusta, Georgia, for compliance with the 40 CFR Part
265, Subpart F regulations during the week of January 26, 1987. Several
deficiencies pertaining to the RCRA ground water monitoring system were noted
during the evaluation. S. E. Matthews, project coordinator for the
evaluation, compiled a report that detailed these deficiencies and summarized
the results from water quality samples collected from the RCRA monitoring
wells at the facility.
This update chronicles activities at the Southern Wood Piedmont facility
following the Task Force evaluation and any actions taken by the Georgia
Environmental Protection Division (EPD) and EPA Region IV regarding RCRA
ground water monitoring at the facility.
In February 1987, Southern Wood Piedmont (SWP) sampled several of the
RCRA monitoring wells. K001 constituents were detected in some of the wells.
In March 1987, the Agency for Toxic Substances and Disease Registry
(ATSDR) prepared a RCRA Health Consultation for the SWP facility at the
request of the Georgia Department of Human Resources. The report concluded
that the data available indicated some concern over the potential exposure of
individuals within the residential community around the facility. The report
also indicated the need for more data to allow for a better determination of
the longer-term health risks. In April 1987, the Georgia Department of
Natural Resources reviewed the ATSDR report and prepared a letter listing
several questions and suggestions regarding the correct interpretation of the
report.
In May 1987, SWP sampled some of the RCRA monitoring wells. K001
constituents were detected. In June 1987, the Georgia EPD sampled neighborhood
wells in the vicinity of SWP. No K001 constituents were detected.
Also in June, EPD performed an inspection at SWP. In July, EPD issued
two Notices of Violation (NOV) based on deficiencies noted during the June
inspection. The violations included deficiencies in the groundwater
monitoring system, post-closure care of the surface impoundment and the
contingency plan. Many of the issues were resolved by August 1987.
Another sampling event occurred in July 1987, when SWP sampled more
monitoring wells. K001 constituents were detected.
In late July, EPD issued an NOV to SWP based on Consent Order EPD-HW-257.
This order addressed Part B deficiencies and had been issued prior to the
HWGW Task Force evaluation. These issues were resolved by August 1987.
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In August 1987, SWF submitted a request.to EFD to begin partial
corrective actions at the Augusta facility. EPD reviewed the plan and wrote
SWP to proceed. SWP began installing additional monitoring wells for
assessment purposes.
Also in August, EFD sampled a neighborhood well in which K001
constituents were detected. Another inspection was conducted at SWP.
Late September 1987, EPD issued a Notice of Deficiency to SWP for Part B
deficiencies and a NOV on the Ground Water Quality Assessment Plan. A meeting
was held between SWP and EPD in October to discuss the September NOD/NOV.
To date, EPA Region IV has taken no enforcement action against the
facility.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUND WATER TASK FORCE
GROUND WATER MONITORING EVALUATION
SOUTHERN WOOD PIEDMONT
AUGUSTA, GEORGIA
NOVEMBER 1987
SHARON E. MATTHEWS
PROJECT COORDINATOR
ENVIRONMENTAL SERVICES DIVISION
REGION IV
US-EPA
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TABLE OF CONTENTS
EXECUTIVE SUMMARY
INTRODUCTION 1
Background 2
SUMMARY OF FINDINGS AND CONCLUSIONS 4
COMPLIANCE WITH INTERIM STATUS REQUIREMENTS 4
265.90 Applicability 4
265.91 Ground Water Monitoring System .... 4
265.92 Sampling and Analysis 4
265.93 Preparation, Evaluation and Response 5
265.94 Recordkeeping and Reporting 5
COMPLIANCE WITH 40 CFR PART 270 5
COMPLIANCE WITH 40 CFR PART 264 6
TECHNICAL REPORT
INVESTIGATIVE METHODS 7
Records/Documents Review and Evaluation 7
Facility Inspection 7
Laboratory Evaluation 7
Ground Water Sampling and Analysis 8
WASTE MANAGEMENT UNITS AND OPERATIONS. 8
Surface Impoundment Description . . 8
Solid Waste Management Units 9
GEOLOGY/HYDROGEOLOGY 10
Regional/Site Geology 10
Regional/Site Hydrology 12
Adequacy of Hydrogeologic Characterization 13
GROUND WATER MONITORING PROGRAM DURING INTERIM STATUS 14
Regulatory Requirements 14
Monitoring Well Data. 14
Ground Water Sampling 19
Southern Wood Piedmont Sample Collection and Handling
Procedures 21
TASK FORCE SAMPLE COLLECTION AND HANDLING PROCEDURES 23
LABORATORY EVALUATION 25
MONITORING DATA ANALYSIS 27
REFERENCES 30
APPENDICES
A - Task Force Analytical Results
B - Monitoring Well Construction Data Summary
C - Southern Wood Piedmont's Sampling and Analysis Procedures
D - Compliance History
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TABLE OF CONTENTS CONTINUED
FIGURES
1 - Facility Location Map
2 - Process Water Flow Diagram
3 - Location of Ground Water Monitoring Wells
4 - Location of Potential Solid-Waste Management Units
5 - Schematic Geologic Section
TABLES
1 - RCRA Ground Water Monitoring Parameters
2 - Wells Designated for Ground Water Monitoring During
Interim Status
3 - Order of Sample Collection, Bottle Type and Preservative List
4 - Field Measurements
5 - Analytical Data Summary - HWGW Task Force
6 - Analytical Data Summary - BSD, Athens
7 - Parameters Indicating the Presence of K001 Chemicals
8 - Parameters Establishing Ground Water Quality
9 - Parameters Used as Indicators of Ground Water Contamination
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EXECUTIVE SUMMARY
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GROUND WATER MONITORING COMPLIANCE EVALUATION
SOUTHERN WOOD PIEDMONT
AUGUSTA, GEORGIA
BSD PROJECT NO. 87-065
EXECUTIVE SUMMARY
INTRODUCTION
Task Force Effort
Operations at hazardous waste treatment, storage and disposal (TSD) facili-
ties are regulated by the Resource Conservation and Recovery Act. Regulations
promulgated pursuant to RCRA (40 CFR Parts 260 through 265, effective on Novem-
ber 19, 1980 and subsequently modified) address hazardous waste site operations
including monitoring of ground water to ensure that hazardous constituents
are not released to the environment. The regulations for TSD facilities are
implemented (for EPA administered programs) through the hazardous waste permit
program outlined in 40 CFR Part 270.
The Administrator of the Environmental Protection Agency (EPA) established
a Hazardous Waste Ground Water Task Force (Task Force) to evaluate the level of
compliance with ground water monitoring requirements at commercial off-site and
selected on-site TSD facilities and address the cause of noncompliance. The
Task Force is comprised of personnel from the EPA Headquarters Core Team, Re-
gional EPA Offices and the States.
There were eight Task Force evaluations conducted in Region IV during
FY-86 and FY-87. Evaluations have been conducted at both of the region's two
off-site commercial facilities. Six evaluations were conducted at private,
on-site facilities. The evaluation of Southern Wood Piedmont was the fourth
private on-site investigation in Region IV and was conducted the week of January
26, 1987.
Objectives of the Evaluation
The principal objectives of the inspection at Southern Wood Piedmont (SWP)
were: to determine compliance of the RCRA surface impoundment with the require-
ments of 40 CFR Part 265, Subpart F - Ground Water Monitoring and to determine
compliance with related requirements of the Part 265 interim status regulations
and the state's counterpart regulations; to evaluate the ground water monitor-
ing program described in the RCRA Part B permit application for compliance with
Part 270.14(c) and potential compliance with Part 264; to evaluate any ground
water monitoring systems associated with solid waste management units at the
facility that would provide data and information to be used during the permit
review process; and to conduct an audit of the laboratory used by SWP for
ground water analyses.
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The SWF inspection was coordinated by the Region IV United States Environ-
mental Protection Agency (EPA), Environmental Services Division and included
participation by the EPA Headquarters Core Team, Region IV EPA Waste Management
Division and the Georgia Department of Natural Resources Environmental Protec-
tion Division (EPD). In general, the evaluation involved a review of State,
Federal and facility records, a facility inspection, a laboratory evaluation
and ground water sampling and analysis.
BACKGROUND
Locale/Facility/Operations
The SWP facility is a wood preserving plant located on a 78-acre site at
1650 Nixon Road, Augusta, Georgia (see Figure 1). The facility is approximately
two miles south of the Augusta corporate boundary.
Operations were apparently initiated at-the site in the early to mid-1920's
based upon property deeds dating back to 1923. Wood-treating preservatives
which have been used are creosote, pentachlorophenol, chromated copper arsenate
(CCA) and zinc meta-arsenite (ZMA) . Use of ZMA was discontinued about 1950,
and the use of creosote was discontinued in 1983, so that presently only penta-
chlorophenol and CCA are used as preservatives.
Raw wood materials are delivered by rail or truck to the facility for pro-
cessing by the following general steps:
1. Raw wood materials are shaped to the desired product dimensions.
2. Shaped wood products are seasoned by a natural drying processor or
by artificial steaming.
3. Seasoned wood is treated with a preservative. Treatment preserva-
tives included creosote, pentachlorophenol, or CCA (chromated copper
arsenate salts). Creosote was discontinued as a preservative in
December of 1983.
4. Following treatment, final wood products are stored on the plant site
until needed by a customer or are shipped directly by rail or truck
to customers.
Process water from SWP-Augusta facility operations consists of steam con-
densate and moisture extracted from wood during the seasoning process, and
vacuum pump seal water, vacuum jet condensate and waste stream condensate from
the creosote/pentachlorophenol treatment process. These wastes are
transported by equipment used to transfer treatment chemicals and, as a result
become contaminated with small quantities of creosote and pentachlorophenol.
Process waste from these sources is collected at various locations in the
processing area and is piped directly to the API separator in series for
recovery of organic wood treatment preservatives for recycling in the wood
preserving operation. Wastewater generated from the API separators flowed to
an unlined surface impoundment. The surface impoundment was aerated to
provide biological treatment, increase evaporation and provide sufficient
residence time to allow settling of organics and solids. At the time of the
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Task Force inspection, the surface impoundment was undergoing closure. (See
Figure 2 for flow diagram).
Sludge containing chromium and arsenic from the CCA process is shipped
off-site where the CCA sludge is reprocessed. Waste creosote was shipped off-
site and burned for energy recovery during the period when treatment with
creosote was performed.
The treatment process generates one waste listed as hazardous : "K001:
Bottom sediment sludge from the treatment of wastewater from wood preserving
processes that use creosote and/or pentachlorphenol." These sludges were
generated in and stored only in the surface impoundment at the SWF-Augusta
facility. However, the facility is closing the surface impoundment as a.
landfill, treating the wastewater and sending the wastewater to a POTW and the
sludge to a hazardous waste disposal site. According to the facility,
wastewater from the plant will be pretreated in a Wemco Unit, then sent
directly to a POTW.
According to facility reports, several potential contaminants source
areas are associated with present and previous plant operations. ZMA mixing
tanks were located in the area of the present locker room building. The
mixing tanks were not used after about 1950, when ZMA was discontinued as a
preserving agent, and the locker room building was constructed in the late
1950's. An old creosote dip tank for butt-treating poles was located near the
present bark silo until the late 1950's, when all creosote preserving was
accomplished by pressure cylinders. An old ditch was used until the late
1960's to carry waste preservatives to an off-site drainage ditch. A low area
at the southeast corner of the plant has been filled with bark, sawdust, plant
wastes and construction debris from the late 1960's to the late 1970's. The
extent of the fill area and the amount of wastes within it are presently being
explored in the field. The presence of the area was reported to the US-EPA in
1980 as a CERCLA site.
Several old sumps and basins, including an old API-type oil/water
separator, are located behind the laboratory building and main offices. The
present oil/water separator and spray cooling unit are also located in this
area. A barometric surge basin, located near the main treatment cylinder
building, was removed from service in June 1985. The K001 pond, installed in
1974, has recently been removed from service. Other potential contaminant
sources which are still in operation are the tank farm constructed in the
early 1960's and the track area.
The facility has RCRA interim status: GAD051034387. In June 1983, the
Part B for the facility was submitted for review. A Notice of Deficiency
(NOD) was issued by the Georgia Environmental Protection Division (EPD).
Since that time, both EPD and EPA-Atlanta have issued Administrative and
Consent Orders, NOD's and NOV's (Notice of Violation) for non-compliance with
the regulations. EPD and SWP have agreed under the terms of a consent order,
to address the entire site for 40 CFR Parts 264, 265, and 270 requirements.
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SUMMARY OF FINDINGS AND CONCLUSIONS
COMPLIANCE WITH INTERIM STATUS REQUIREMENTS
The Task Force investigated the interim status ground water monitoring
program implemented by SWF. The consensus opinion of the Task Force was that
this program is not fully in compliance with the 40 CFR Part 265 Subpart F and
the Georgia Hazardous Waste Management Regulations. The following is a more
detailed summary of the inspection findings and conclusions.
265.90 Applicability
According to this section of the regulations, an owner/operator of a land
disposal facility must implement a ground water monitoring program "capable of
determining the facility's impact on the quality of the ground-water in the
uppermost aquifer underlying the facility..." This program was to be imple-
mented by November 1981.
At the time of the Task Force evaluation, SWP had not fully defined the
hydrology and geology of the uppermost aquifers and had not documented flow
directions and gradients and noted any deviations from the norm.,
265.91 Ground Water Monitoring System
According to these regulations, an owner/operator must install a ground
water monitoring system that is capable of yielding samples for analysis; have
a sufficient number, locations and depths of background monitoring wells that
are not affected by the facility and yield background quality in the uppermost
aquifer; and have a sufficient number, locations and depths of downgradient
wells to immediately detect any statistically significant amounts of hazardous
waste or hazardous waste constituents that migrate from the waste management
area to the uppermost aquifer. The monitoring wells must be adequately con-
structed to obtain representative samples of the uppermost aquifer.
Four wells clusters, MW6 through MW9, were installed in Fall 1984 to re-
place the five original RCRA monitoring wells that were deemed inadequate by
EPD. Wells 6C, 7C, 8B and 9B are utilized for the student's t-test, with
well 7C used as the background well.
This well system is not adequate to meet the 265.91 requirements because:
background well 7C has shown measurable concentrations of K001 con-
stituents in water quality analyses;
ground water flow direction and gradient has not been adequately
defined to determine if the wells are properly located and screened
at the appropriate depths;
well construction materials and techniques may not enable represen-
tative ground water samples to be collected from these wells.
265.92 Sampling and Analysis
This section of the regulations requires an owner/operator to obtain and
analyze samples from the RCRA monitoring system and to develop a sampling and
analysis plan (SAP) that should include procedures and techniques for:
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a. sample collection,
b. sample preservation and shipment,
c. analytical procedures, and
d. chain-of-custody control.
x
It is the contention of the Task Force that the sampling and analysis
plan available for review at the time of the inspection was not sufficient to
satisfy the regulations. The SAP was neither detailed nor site-specific, but a
generic plan used for all SWP sites and lacked information such as:
What containers and preservatives are used for samples?
Are the FVC bailers decontaminated between sampling events?
What are the quality assurance/quality control procedures used for
sampling and analysis?
It was noted that the PVC bailers were left hanging in some wells between
sampling episodes and were discolored.
265.93 Preparation. Evaluation and Response
The facility tripped the student's T-test in November 1983 and
subsequently submitted a ground-water quality assessment plan (GWQAP) to EPD
for review. The plan was found to be inadequate and a revised version of the
plan was submitted. The present plan is not adequate to satisfy the
requirements of this section of the regulations because the hydrology and
geology underlying the site are not well defined for assessing the rate,
extent or concentrations of contaminants emanating from the site.
265.94 Recordkeeping and Reporting
This section of the regulations requires as owner/operator to keep any
information regarding the ground water monitoring system on-site, and to submit
specific information to the proper authorities by specific dates.
SWP has their corporate office in Spartanburg, South Carolina. Much of
the ground water monitoring data for the facility in Augusta is kept in the
corporate offices. The Task Force recommends that any data pertinent to ground
water monitoring at the SWP facility in Augusta should be kept on site.
Submittals of ground water monitoring data to State and Federal agencies
appears to be within the time constraints posed by the 265.94 regulations.
COMPLIANCE WITH 40 CFR PART 270
The 40 CFR Part 270 regulations cover basic EPA permitting requirements,
such as application requirements, standard permit conditions, and monitoring
and reporting requirements. These regulations require specific information
which is necessary to complete the RCRA post-closure permit application for the
SWP K001 surface impoundment. These requirements include:
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define the horizontal and vertical extent of the contaminant plume(s);
define the rate, extent, and concentrations of the hazardous constitu-
ents in the contaminant plume (s);
define the hydrology and geology of the uppermost and interconnected
aquifers.
The regulations also require that a corrective action plan be proposed to
remove and/or treat in place all contaminated ground water between the point of
compliance and the downgradient property line.
At the time of the Task Force inspection, SWF was in the process of closing
the K001 surface impoundment and was collecting hydrologic and geologic informa-
tion that would define all aspects of the contaminant plume(s). In addition,
SWF has submitted an alternate concentration limit proposal which, if approved,
will set clean-up standards at the point of compliance which are above back-
ground concentrations. The post-closure permit application and alternate con-
centration limit proposal are undergoing a completeness review by Georgia EPD.
COMPLIANCE WITH 40 CFR PART 264
These regulations define the standards for owners and operators of hazard-
ous waste treatment, storage, and disposal facilities. 40 CFR Part 264 -
Subpart F deals with releases from solid waste management units at a facility.
A solid waste management unit includes, but is not limited to, any landfill,
surface impoundment, waste pile, land treatment unit, incinerator, injection
well, tank, container storage unit, wastewater treatment unit, including all
conveyances and appurtenances used in waste management or storm water handling,
elementary neutralization unit, transfer station, and recycling unit from which
hazardous constituents might migrate, irrespective of whether the units were
intended for the management of solid and/or hazardous wastes.
Under 40 CFR 264.101, SWP is required to institute remedial investigations
and corrective action as necessary to protect human health and the environment
from all releases of hazardous waste or hazardous waste constituents from any
solid waste management unit at the facility, regardless of the time at which
the waste was placed in the unit. SWP has identified several solid waste
management units at the facility, and is currently assessing the extent of
contamination from these units. Remedial investigations and corrective action
will be addressed under the authorized State RCRA permit in accordance with the
1984 Hazardous and Solid Waste Amendments requirements. The permit will contain
schedules of compliance for such remedial investigations and corrective actions.
These units are not subject to post-closure permitting requirements under Parts
264 and 270, but SWP may decide to address contamination from the K001 surface
impoundment and solid waste management units under the same corrective action
plan. ;
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TECHNICAL REPORT
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TECHNICAL REPORT
INVESTIGATIVE METHODS
The Task Force evaluation of the SWP site consisted of:
o A review and evaluation of records and documents from EPA Region IV,
EPD and SWP.
o A facility on-site inspection conducted January 26-30, 1987.
o An off-site analytical laboratory evaluation.
o Sampling and subsequent analysis.
Records/Documents Review and Evaluation
Records and documents from EPA Region IV and the EPD offices, compiled by
an EPA contractor (PRC), were reviewed prior to the on-site inspection. During
the inspection, facility maps and files were reviewed for further information.
During the week of the inspection, the Task Force met with Mr. Ed Gibbs, Envi-
ronmental Manager for SWP, Steve Hudson, Plant Manager of the SWP Augusta fac-
ility,. Steve Blevins, Law Engineering consultant to SWP and other SWP personnel.
All members of the SWP Staff were helpful in providing information to the Task
Force.
Facility Inspection
The facility inspection, conducted January 26-30, 1987, included identifi-
cation of waste management units, identification and assessment of waste manage-
ment operations and pollution control practices and verification of location
of ground water monitoring wells.
Company representatives were interviewed to identify records and documents
of interest, answer questions about the documents and explain (1) facility
operations (past and present), (2) site hydrogeology, (3) ground water monitor-
ing system rationale, (4) the ground water sampling and analysis plan and (5)
laboratory procedures for obtaining data on ground water quality. Because
ground water samples are analyzed by an off-site laboratory, personnel from
these facilities will also be interviewed regarding sample handling and analy-
sis, and document control.
Laboratory Evaluation
The off-site laboratory facility handling ground water samples was
evaluated regarding its respective responsibilities under the SWP ground
water sampling and analysis plan. Analytical equipment and methods, quality
assurance procedures and documentation were examined for adequacy. Labora-
tory records were inspected for completeness, accuracy and compliance with
State and Federal requirements. The ability of the laboratory to produce =
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qual-ity data for the required analyses was evaluated. The evaluation
results are included as part of this report.
Ground Water Sampling and Analysis
Sampling Locations
Water samples were collected from wells 1A, IB, 1C, 5A, 5B, 5C, 6A, 6B,
6C, 8A, 8B, IOC, 13D, 18C, 30, 37A, 38A and 38B. Thirteen of the wells are
located on SWP property and five wells are located off-site. The selection
of these wells for sampling was based on location to provide areal coverage
both up and downgradient of the surface impoundment and to monitor possible
off-site contamination. The locations are identified in Figure 3.
Samples were taken by an EPA contractor (Alliance Technologies) and sent
to EPA contractor laboratories for analysis. EPA Region IV requested and re-
ceived four sample splits. SWP split for all samples, while EPD declined to
split samples for independent analysis. Data from sampling analysis was re-
viewed to further evaluate the SWP ground water monitoring program and identify
contaminants in the ground water. An analytical data summary of the results
from the samples collected for the Task Force is presented as Tables 5 and 6.
Actual analytical data is not incorporated into this report due to size, but
is available upon request from EPA Region IV.
WASTE MANAGEMENT UNITS AND OPERATIONS
Surface Impoundment Description
A surface impoundment or K001 pond was located in the northeast portion
of the SWP facility and was in use until 1985. K001 hazardous waste (bottom
sediment sludge) was generated in the surface impoundment when suspended solids
settled out of the process wastewater associated with the pressure treatment
of wood with creosote and pentachlorophenol. The surface impoundment was appar-
ently constructed during the late 1960's or early 1970's over an old drainage
ditch previously used to carry process wastewater to an off-site ditch.
According to facility reports, an estimated 118 cubic yards of K001 sludge
existed in the surface impoundment. The sludge was a semisolid composed of
creosote fractions, sand, wood sugars and sawdust contaminated with pentachloro-
phenol (61,000 ppm). Based on a January 1985 analysis, the sludge contained
significant levels of most K001 parameters as listed in 40 CFR 261, Appendix
VII. A subsequent analysis in June 1985 of a sample obtained after the dis-
continuation of creosote as a treating agent, showed a decrease of most of
the parameters. At the time of the Task Force inspection, the sludge had
been removed from the surface impoundment. The impoundment was then back-
filled with a clayey soil and a synthetic membrane installed on top of the
backfill. An upper cover soil was placed on top of the membrane and seeded
to minimize erosion and to complete closure as a landfill.
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Solid Waste Management Units
In January 1985, EFD requested information regarding solid waste manage-
ment units at the facility. In May 1985, SWP responded with the following
information. Locations of these units are delineated in Figure 4.
ZMA mix tanks: Zinc meta-arsenite was used until about 1950 as a wood-
treating preservative. The tanks were located in the area of the present
locker room building. These tanks have been backfilled.
Drip tracks: Contains treated utility poles' "kick back", which is a
mixture of water, preservative, wood sugars, and some of the creosote constitu-
ents found in Appendix VIII, along with some PGP and CCA. This is still an
active area.
Tank farm area: This area was constructed in the 1960's and is located
in the north central portion of the facility. These tanks are still in opera-
tion and hold the chemicals and treatment processes utilized by the facility.
Barometric surge tank: This tank was located near the main treatment
cylinder building and was removed from service in June 1985.
CERCLA landfill area: A low area at the southeast corner of the plant
where bark, sawdust, construction debris and plant wastes such as boiler ash
were placed on the ground from the late 1960's to the late 1970's. The presence
of the area was reported to EPA in 1980 as a CERCLA site. To the facility's
knowledge, no hazardous waste was deposited in the area. No records exist
of the exact nature and quantity of wastes placed in the area.
1973 spill: A SWP employee error resulted in the release of approximately
50,000 gallons of PGP from the treating cylinder. The PCP reportedly flowed
across the site and along the south side of Nixon Road to the east side of the
property where a temporary dam was constructed in the ditch and the PCP was
recovered. The spill was reportedly confined to ditches on or adjacent to
SWP property.
Old effluent ditch: Used until the late 1960's to carry waste preserva-
tives to an off-site drainage ditch, was located in the northeastern portion
of the facility and has been backfilled.
Dip tank for butt-treating poles: This old creosote tank was located
near the present bark silo until the late 1950's, when all creosote preserving
was accomplished by pressure. It has been abandoned.
Other solid waste management units include the diesel fuel oil and PCP
unloading system, old sump area, cooling water basin for barometric tank,
API oil/water separator and the creosote dip tank.
It is recommended that more information on these solid waste management
units be submitted for review to determine the contribution of the units to
the contaminant plume(s) at the facility.
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GEOLOGY/HYDROGEOLOGY
The following is a summary of geologic/hydrologic information compiled
by Law Engineering, consultants to SWP.
Regional/Site Geology
The SWP Augusta facility is located in the Fall Line Hills District of the
Atlantic Coastal Plain Physiographic Province (Clark and Zisa, 1976). The Fall
Line Hills District is highly dissected with little level land except the
marshy floodplains and their better drained, narrow stream terraces. Stream
valleys lie 50 to 250 feet below the adjacent ridge tops. Relief gradually
diminishes to the south and east within the district.
The Fall Line is the northern boundary of the Fall Line Hills District as
well as the boundary between the Atlantic Coastal Plain and Appalachian Pied-
mont Provinces. Geologically, it is the contact between the Cretaceous and
younger sediments of the Coastal Plain and the older, crystalline rocks of
the Piedmont. Several stream characteristics change as they flow south through
this area: rapids and shoals are common near the geologic contact, flood-
plains are considerably wider on the younger sediments, and the frequency
of stream meanders increases. The Fall Line crosses the Savannah River approxi-
mately six miles north of the site.
The SWP Augusta facility is situated on the western edge of the broad,
marshy stream terrace of the Savannah River. Much of the western Savannah
River terrace is occupied by Phinizy,Swamp. which occurs at an elevation of
approximately 115 feet above National Geodetic Vertical Datum (NGVD). Relief
along the terrace is very low below an elevation of 150 feet NGVD, where
typical Fall Line Hills are eroded away and covered by alluvium of the Savannah
River. Summit elevations of hilltops are as high as 450 feet NGVD. Average
elevation at the SWP Augusta facility is approximately 130 feet NGVD.
Several geologic units and hydrogeologic zones occur in the subsurface
beneath the SWP - Augusta site, including Recent alluvium and upper Cretaceous
Gaillard Formation. The relationship of the geologic units to the hydrologic
zones is shown schematically on Figure 5.
The site is underlain by Recent alluvium of the Savannah River (Georgia
Geologic Survey, 1976), derived from the adjacent, older crystalline rocks
of the Piedmont. The alluvial deposits of the Savannah River terrace range
in size from sand and gravel to clay and sandy clay. Sedimentation patterns
of the alluvium are complex, with clay beds commonly pinching out (Gorday,
1984). The thickness of the alluvium range from a feather-edge to 80 feet
(LeGrand, 1956).
Underlying the Recent alluvium in the Southern Wood Piedmont region are
the Cretaceous-aged sediments of the basal Gaillard Formation of the Oconee
group (Huddlestun, 1984). The term Tuscaloosa Formation has been used in
the past by a number of authors including Cooke (1936), LeGrand (1956) and
Siple (1967) for the sediments of the Gaillard Formation. Faye and Prowell
(1982), however, note that the sediments in eastern Georgia are younger in
age than the Tuscaloosa, and the Tuscaloosa, as defined in its type locality
in Alabama, does not extend east of Macon (Smith and King, 1983). Clarke,
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Brooks and Faye (1985) have referred to the Gaillard equivalent in South
Carolina as the Middendorf and the Black Creek Formations. A formal proposal
is in preparation by Huddlestun and Chowns to apply the name Gaillard Forma-
tion to the unnamed, upper Cretaceous-aged sediments in eastern Georgia.
The Gaillard Formation overlies weathered crystalline bedrock in the SWF
Augusta region. There is a minor unconformity marked by red, oxidized sands
or clays within the Gaillard. At the top of the formation, there is another
unconformity marked by oxidized sediments and indicating the contact with
the Tertiary Huber Formation.
The Gaillard Formation is comprised of sands, gravels and clays. The
main clay constituent is kaolin, which occurs in lenses or as interstitial
clay. The dense, basal sands of the Gaillard contain relatively large amounts
of kaolin clay. Balls and boulders of pure white kaolin are common. The sands
of the Gaillard tend to be poorly sorted, fine to coarse, angular to subangular
quartz, interspersed with clay and muscovite mica (Gorday, 1984). Sedimentary
structures include cross bedding. The formation is generally massive (LeGrand,
1956).
The Gaillard Formation dips and thickens to the southeast, creating a
wedge of sediments. The base of the Gaillard Formation dips to the south-
southeast at approximately 38 feet per mile, while the dip of the top of the
Gaillard is approximately 23 feet per mile (Gorday, 1984). Therefore, the
Gaillard thickens at a rate of about 15 feet per mile toward the southeast.
The crystalline bedrock which underlies the Gaillard Formation consists
of granitic intrusive rocks and a granite diorite complex generally referred
to as the Charlotte Belt (King, 1955). Rock types noted include gneisses and
schists of varying mineralogy, granite-diorite and slate (Gorday, 1984). The
upper 10 to 100 feet of the crystalline rock is typically saprolite (Faye and
Prowell, 1982). Saprolite is formed by the in-place weathering of crystalline
rock with the preservation of the relict texture of the parent rock. Saprolite
can be distinguished from the overlying poorly-consolidated Gaillard Formation
by mineralogy and texture.
The Recent alluvium beneath the SWP Augusta facility consists of aban-
doned backswamp deposits overlain by terrace overbank sediments. The aban-
doned backswamp of the Savannah River was probably similar to Phinizy Swamp
and formed when the river flowed at a higher stage than present. As the
Savannah River meandered and the river stage declined toward its present
level, channels were cut into the backswamp sediments and filled with coarser
channel deposits.
The abandoned backswamp deposits typically represent the lower confining
zone of the Recent alluvium. Where absent, lower confinement is provided by
the clayey, upper portion of the Gaillard Formation. Lower confinement of
the Gaillard Formation is theorized to the be the saprolite and crystalline
bedrock.
Based on stratigraphic data collected by Law Engineering, the partially
confining layer is continuous laterally beneath the site. This partially
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confining layer also is generally continuous off-site, but two areas have shown
an absence of this layer (well MW-34 and well cluster MW-45).
Regional/Site Hydrology
According to Law Engineering, the uppermost aquifer beneath the SWP
Augusta facility includes, in descending order, Recent alluvium and sands of
Cretaceous age (see Figure 5). The uppermost aquifer in the site region has
been referred to as the basal Cretaceous aquifer by Gorday (1984) and as the
Dublin-Midville aquifer system (Clark, Brooks and Faye, 1985). There is some
disagreement as to whether or not the base of the uppermost aquifer is the top
of the saprolite overlying the crystalline bedrock. In some locations in
Richmond County, a clay bed that may be of Cretaceous age'underlies the aquifer
(Gorday, 1984).
According to Law Engineering, the uppermost aquifer consists primarily of
the lower portion of the Gaillard Formation. Included in the uppermost aquifer
is the alluvium which overlies the Gaillard. The lower part of the regional
Savannah River alluvium is highly permeable and is hydraulically connected to
the underlying Gaillard Formation (Gorday, 1984). The clay beds in the lower
portion of the alluvium partially confine the underlying Gaillard formation
and provide a degree of hydraulic separation between the upper alluvium and the
Gaillard. However, the upper alluvium, the clay beds, and the Gaillard Forma-
tion are all included in the uppermost aquifer. Therefore, the uppermost
aquifer, as defined by Law Engineering, consists of an upper sand zone (surfi-
eial sand and clay), a partially-confining zone (soft organic clay) and a lower
sand (Gaillard Formation).
According to a USGS report, the crystalline bedrock which underlies the
uppermost aquifer is hard, dense and massive, and, in its natural state, practi-
cally impervious to water (Siple, 1967). Nonetheless, some water is stored in
secondary openings developed by processes that affected the rocks after they
had been formed, such as fissures, joints and other fracture openings. For
this reason, meager to fair supplies of water are generally obtained from wells
completed in the crystalline bedrock. Siple (1967) reports a range of well
yields for the bedrock of 2 to 100 gallons per minute (gpm), with a probable
average yield of 5 to 10 ppm if a representative sample of well yields and well
failures were included in the sampling.
Because of the confining property of the 10 to 100 feet of saprolite and/or
basal Cretaceous clay and to the relatively impermeable nature of the crystal-
line bedrock, the crystalline bedrock is not included as part of the uppermost
aquifer by Law Engineering. EPD and the Task Force contends that the hydro-
logic data collected to date does not support this concept.
Ground water flow in the Recent alluvium is generally toward the site from
the south and west and flows off-site in a northeasterly-easterly direction.
An average hydraulic gradient of 0.005 and a hydraulic conductivity of 1 X 10-3
ft/min has been determined for the Recent alluvium. Ground water flow velocity
has been calculated at 9 ft/yr.
Ground water flow in the Lower Sands appears to be to the northeast. An
average hydraulic gradient of 0.0025 and a hydraulic conductivity of 1.1 X 10-2
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ft/min has been calculated. The ground water flow velocity has been determined
to be 48 ft/yr.
Water levels in the lower sand zone are generally lower than water levels
in the upper sand zone, indicating a potential for downward movement of ground
water through the partially-confining organic clay beds.
The lower sand is the part of the uppermost aquifer that provides water
to most wells in the area. Drinking water for the City of Augusta comes from
reservoirs located approximately 3.5 miles north of the facility which receive
water from the Savannah River. Drinking water for Richmond County is supplied
from two well fields, the nearest of which is about 1/2 mile southwest (i.e.,
upgradient) of the facility.
The closest active industrial wells to the site are the Babcock and Wilcox
wells located about 0.5 miles north of the site. These wells, completed in the
lower sand zone, yield approximately 500,000 gallons of water per day. This
pumping produces a cone of depression extending outward 500 to 1,000 feet.
Based upon the configuration of the potentidmetic surface, it appears that
ground water beneath the SWP Augusta facility flows to the northeast in the
lower sand zone and is not affected by the pumping from Babcock and Wilcox.
Adequacy of Hvdrogeologic Characterization
The major sources of hydrogeologic information for this site are the Part
B, ground water monitoring data and data collected by Law Engineering. Work
has been done as part of the assessment program to develop site-specific data
on the physical properties of the aquifers and associated confining units
(i.e., vertical/horizontal hydraulic gradients, lithology, stratigraphy, etc.).
It is the consensus opinion of the Task Force that more work is needed to:
fully define the hydrology and geology of the uppermost and interconnected
aquifers; document flow directions and gradients and any deviations from the
norm; and define the rate, extent, and concentrations of the hazardous consti-
tuents in the contaminant plume(s).
The Task Force does not agree with the interpretation of the uppermost
aquifer by SWP or Law Engineering. The permeability data does not support
the saprolite and/or basal Cretaceous clay being identified as a confining
zone that hydraulically separates the crystalline bedrock from the Recent
alluvium and the Gaillard Formation. The definition of uppermost aquifer
must be consistent with the regulatory definition of 40 CFR Part 260.10.
The following information should be collected to resolve these hydro-
geologic issues:
1. Conduct additional borings to define the vertical and lateral extent
of confining units, interconnected aquifers, etc. across the entire
SWP site. Continuity, thickness, etc., of these units should be
determined. Conduct sieve analyses, permeability and porosity tests
on all cores.
2. .Install additional series of nested piezometers throughout the site to
.^adequately determine the potentiometric surface and to define the pre-
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sence and magnitude of vertical gradients. Note any fluctuations or
changes in flow direction and determine reasons for those changes.
The following information should be submitted to the State to resolve
the above issues:
construct flow net analysis,
seasonal potentiometric water level data and maps,
most recent reports on the ground water assessment program - include
cross sections, geologic logs, water quality, etc.,
any revisions to the Part B, closure/post-closure plan, sampling
and analysis plan, etc., and
conduct pumping tests both for site characterization and for corrective
action design.
GROUND WATER MONITORING PROGRAM DURING INTERIM STATUS
Ground water monitoring at the SWP facility has been conducted under State
interim status regulations and the State Consent Order. The following is an
evaluation of the monitoring program between November 1981, when the ground
water monitoring provisions of the RCRA regulations became effective, and
January 1987 when the Task Force investigation was conducted. A summary of
the compliance history for this facility has been included as Appendix D of
this report.
Regulatory Requirements
Ground water monitoring at this site is now regulated by the Georgia
Rules for Hazardous Waste Management. These Rules are the State equivalent of
40 CFR Part 265 Subpart F, which were to be implemented by November 19, 1981.
The State of Georgia received Final Authorization in August 1985. The
State regulations are enforceable in lieu of the Federal regulations. The
State interim status ground water monitoring requirements are found in Section
391-3-11-.10 of the Georgia Rules for Hazardous Waste Management 265 Subpart F -
Ground-Water Monitoring. Table 1 outlines the parameters that were to be
sampled and analyzed during the first year of sampling. All the parameters
were to be monitored quarterly for one year to establish background concentra-
tions for each parameter. During this period, four replicate measurements were
to be obtained for each parameter in Category 3 for each sampling event. After
the first year, Category 3 parameters were to be monitored semi-annually, while
Category 2 parameters were to be monitored annually.
Monitoring Well Data - Surface Impoundment Detection/Assessment/Corrective Action
The interim status monitoring program was instituted at this site in Fall
1981. Five ground water monitoring wells, designated MW1 to MW5 were installed
on October 22-29, 1981, by Froehling and Robertson, Inc. of Greenville, South
Carolina (see Table 2). These wells consisted of 1 7/8-inch i.d. PVC well
casing with 2 to 6 screened intervals per well. The screens were 0.010-inch
slotted PVC. Quarterly sampling was begun in January 1982 and a statistically
significant difference was reported in November 1983. Resampling verified
the statistical difference. EPD reviewed the Ground Water Quality Assessment
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Plan (GWQAP) and found it to be incomplete. EPD also asserted that the five
monitoring wells did not meet the requirements of 265.91(a)(2) or 264.97 and a
new system was requested. The five original monitoring wells were abandoned in
September 1985.
In September 1984, ten additional ground water monitoring wells and one
observation well were installed by Law Engineering, consultants to SWP retained
in early 1983. The wells were installed at four locations in clusters of two
or three wells to determine water quality and aquifer characteristics in
various water-bearing zones. The well clusters were designated MW6 through
MW9 for consistency with the previously installed monitoring wells. The
letter post-script A referred to the deepest well within a cluster, B as the
next deepest well and C as the shallowest. Well installation was completed
by October 1985. Wells MW6C, MW7C, MW8B and MW9B were utilized for the
statistical test, with well MW7C serving as the upgradient well for compari-
son purposes.
These wells were drilled with a 7 7/8-inch o.d. tricone roller bit, and
4-inch i.d. threaded PVC well casing was inserted in the hole and grouted in
place. The boreholes were then advanced with a 3 7/8-inch o.d. tricone roller
bit to total depth and 2-inch i.d. threaded PVC casing and 0.010-inch slotted
PVC screen was installed. The annulus between the well screen and the bore
hole was sand-packed, a bentonite seal was then placed over the sand and the
wells then were grouted with Portland cement. Split spoon samples were taken
at 2.5-foot intervals to a depth of 10.5 feet. Below that depth, samples were
taken at 5-foot intervals. Wells were developed by air-lifting with an air
compressor.
During quarterly sampling, the presence of K001 constituents were detected
in several of the wells. A deep water supply well located on the SWP property
was sampled and analyzed in May 1985. Several K001 constituents were found in
this well. Several private water wells in the SWP area were sampled by EPD in
May 1985. Two of the private wells showed low levels of extractable organic
compounds.
During June-July 1985, 36 new on-and off-site ground water monitoring wells
were installed for assessment purposes. The new wells, designated MW10 through
MW19, were installed in 12 clusters. Well clusters MW1 through MW5 were in-
stalled to replace previously existing monitoring wells MW1 and MW5 constructed
in 1981. All wells were installed with steam cleaned equipment. A borehole
was advanced with wash drilling techniques using potable water and bentonite
drilling mud. In the deepest borings, split spoon samples were taken at 5-foot
intervals or changes in lithology. In the shallower wells, split spoon samples
were taken in the screened interval only. The borehole was reamed to at least
9 inches and a 6-inch i.d. schedule 40 PVC casing was inserted and grouted
with a Portland cement/bentonite mixture. The borehole was then extended
using a 4 7/8 to 5 7/8-diameter tricone roller bit, potable water and bento-
nite mud. A 10-foot section of machine-slotted, 2-inch schedule 40 PVC screen
(0.010-inch slot) with a bottom cap was then installed in the borehole. Only
threaded PVC was used. A clean well-point sand pack was placed in the annulus
to a level at least 2 feet above the top of the screen. A 2-foot bentonite
clay seal was installed on top of the sand pack. Grout was then trended
from the top of the clay seal to ground surface. The wells were developed
using an air compressor, oil coalescer and air lift techniques to remove at
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least five well volumes from the well. An 8-inch diameter, steel outer
casing having a cover and lock was grouted in place at ground surface.
In January 1986, Law Environmental Services submitted Segment I of the
Corrective Action Plan to EPD for review. The plan described a concept for
a slurry-trench barrier wall and presented data to support the course of
action. At the time of that report, 41 monitoring wells, soil test borings
and source exploration wells had been completed. No construction details
were included in the report.
In March 1986, Law Environmental Services Submitted Segment II of the
Corrective Action Plan to EPD for review. The plan presented a two-phase
source control program consisting of soil excavation and free oil removal,
and construction of a bio-treatment facility. At the time of the report,
a total of 95 borings and wells had been installed. The wells included 29
temporary soil test boring wells along the plant perimeter, 8 source-exploration
wells at 6 on-site locations, 7 on- and off-site observation wells and 51
monitoring wells installed at 16 on- and off-site locations.
The soil test borings, designated STB-1 through STB-29 were constructed
with a 7 3/8-inch hollow-stem auger, with split-spoon samples taken at 2.5-
foot intervals. Average spacing between the borings was about 150 feet.
Temporary wells were placed in the soil test borings consisting of 2-inch
threaded PVC pipe with 4-foot slotted screens. Sand filters and bentonite
seals were placed in the annulus between the PVC and the borehole wall. Grout
was no.t used owing to the temporary purpose of the wells. Depths ranged from
10.5 to 15.5 feet.. The wells were, installed during, the period November 1985
to January 1986.
Eight source-exploration wells were installed on-site to evaluate soil
conditions and water quality in the Recent alluvium adjacent to solid waste
management units. Source exploration well B-l was installed October 1984 along
an old drainage ditch reported in the eastern portion of the plant. The B-2
well cluster was installed along the old drainage ditch adjacent to an old
sump area. Well cluster B-3 was installed in an area where free oil was ob-
served in nearby test pit TP-7, excavated in the Recent alluvium. Well B-4
was installed near the drip tracks but was destroyed by plant operations. Well
B-5 was installed as near the removed ZMA mix tank as present structures would
allow. Well B-6 was installed in the CERC1A landfill area. These wells were
constructed during the period November 1985 to January 1986. Completed depths
ranged from 9.5 to 20 feet below land surface.
Eight observation wells were installed from September to October 1985.
The wells, OW-1 to OW-8, were installed to collect water-level measurements.
The wells were hand-augered with sand packs, bentonite seals or grouts to
depths of 5.5 to 9.0 feet. Wells OW-1, OW-2, OW-5, OW-6 and OW-7 were
replaced with shallow monitoring wells and are now MW-17D, MW-20, MW-15D,
MD-13D and MW-14D, respectively. All of the replaced observation wells con-
sist of 2-inch PVC pipe with 4.0-foot slotted intervals.
In November 1985, well MW-18D was installed into the Recent alluvium.
Monitoring well MW-7C had been destroyed during plant operations and was
replaced in January 1986. This well had served as the background well for
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the student's T-test at the site. Also in January 1986, wells MW-21, MW-22,
and MW-23 were installed into the Recent alluvium.
Forty-two test pits were excavated on-site with a backhoe to observe
potential contaminant sources and to prospect for free oil or oil-impregnated
soils. Depths ranged from 1.5 to 12.5 feet. Oil impregnated soils and/or
free oil were noted in at least 14 of the test pits.
In March 1986, Law Environmental Services prepared a report on "Alternate
Concentration Limits" for the SWP facility in Augusta. The following is a sum-
mary of assessment activities at the time of the submittal:
o Installation of 29 temporary soil test boring/wells along the plant
perimeter for the purpose of evaluating soil and ground water condi-
tions in the Recent alluvium for design of a ground water migration
control barrier and to supplement previously obtained data on the
extent of ground water contamination.
o Installation of eight source-exploration wells at various on-site
locations to evaluate soil conditions and obtain representative
ground water samples from various zones within the Recent alluvium
and adjacent to specific solid waste management units.
o Installation of eight temporary observation wells for ground water
level measurements at on- and off-site locations.
o Installation of ten additional monitoring wells completed in the
Recent alluvium to provide specific ground water level and ground
water quality data.
o In-situ hydraulic conductivity testing at 12 wells installed in the
Recent alluvium.
o Laboratory falling-head permeability tests of four undisturbed soil
samples of the Recent alluvium.
o Grain-size analysis and Atterberg limits tests on 19 split-spoon
samples and four undisturbed samples to verify visual soil classifi-
cations and to allow comparison with field hydraulic conductivity
data.
o Excavation of 42 test pits to observe potential contaminant sources,
determine shallow soil conditions in the Recent alluvium, prospect
for free oil or oil impregnated soils and to obtain bulk soil samples
for chemical laboratory analysis.
o Measurement on four occasions of ground water levels from various
on- and off-site wells completed in the Recent alluvium and the upper
portion of the underlying Gaillard Formation.
o Sampling and analysis of ground water from all 55 newly-instailed
wells.
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o Chemical analysis of 48 bulk soil samples from the test pits and
selected split-spoon samples from the soil test borings.
o Surface geophysical surveying (electromagnetic and resistivity) in
an attempt to augment borehole data by providing electrical surveys
to interpolate subsurface data between boreholes and in areas where
no boreholes currently exist.
o Downhole geophysical logging of the unused 300+-foot deep production
well to determine extent of grout, casing leakage, and zones of
relatively higher permeability within the uncased bedrock.
In July 1986, Law Environmental Services submitted Segment III of the
Corrective Action Plan to EPD for review. The plan described planned actions
to further prevent off-site migration of wood preserving constituents and pro-
cedures to recover/treat ground water in areas where constituent concentrations
exceeded the maximum allowable concentration limits. At the time of the report,
42 monitoring wells were installed as part of the off-site corrective action
plan study. The wells were installed singly or as part of two or three well
clusters at 24 off-site locations. Wells or well clusters MW24 through MW47
were installed March to June 1986.
At the time of the Task Force Evaluation, SWP was preparing an update on
the assessment/corrective action activities at the site to be submitted to
EPD and EPA Region IV. In February 1987, the "1986 Annual Ground Water
Quality Assessment Report" was submitted for review and summarized all work
to assess ground water quality to date.
After reviewing the monitoring data, some deficiencies were noted. The
following are general comments on the well program as it was at the time of
the Task Force Evaluation.
1. PVC material is not recommended at sites where organics are of a
primary concern. Because organic constituents are the known major
problem at SWP Augusta, any future monitoring wells should be con-
structed on inert materials such as Teflon R or stainless steel. An
interphase probe is recommended to detect any immicible layers in the
water column.
2. Air should not be used to develop wells. RCRA monitoring wells
may be developed with surge blocks, bailers or pumps.
3. Some wells were drilled using drilling muds. This could bias the
chemical analyses for these wells. For example, the high barium
concentrations in some of the wells could be attributed to constitu-
ents in the drilling mud.
4. Upgradient well 7C had shown K001 constituents and was not truly
representative of background water quality at the site. At a minimum,
a new background well is recommended.
5. At the time of the Task Force evaluation, the assessment work had been
confined to assessing contamination in the Recent alluvium. The lower
hydrogeologic units should be assessed for possible contamination.
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Contaminant plumes emanating from solid waste management units as
well as the surface impoundment should also be addressed.
In summary, more assessment activities are needed to fully satisfy the
264/265/270 requirements and the State Consent Order.
Ground Water Sampling -- Surface Impoundment Detection/Assessment/
Corrective Action
The facility began their quarterly RCRA ground water in January 1982 for
wells MW-2, MW-3, MW-4 and MW-5, with MW-5 as the upgradient well. Quarterly
analyses were taken in January, May, August and October 1982. All parameters
required under 265.92(b)(1)(2) and (3) were sampled for. The facility had a
waiver from EPD exempting the radiological parameters from analysis. Well MW-3
exceeded the National Interim Primary Drinking Water Standards (NIPDWS) for
lead and arsenic the first and second quarters of sampling. In November 1983,
the facility notified EPD of a statistically significant difference in pH
for wells MW-2 and MW-4 and TOG for wells MW:3 and MW-4. These differences
were verified by resampling of the wells.
SWP developed and submitted a Ground Water Quality Assessment Plan (GWQAP)
to EPD on November 30, 1983. EPD reviewed the plan and deemed it inadequate.
EPD also asserted that the five monitoring wells were inadequate to meet the
265.91(a)(2) or 264.97 requirements.
In March 1984, EPD prepared a. proposed consent agreement to SWP requesting
a revised GWQAP and a new monitoring system that would meet the 265.91(a)(2)
and 264.97 requirements. The revised GWQAP was prepared by Law Engineering
for SWP and submitted to EPD May 1984. The plan called for the installation
of four new monitoring well clusters. In September 1984, EPD commented on
the plan and recommended that five quarterly samples be obtained over a five
month period.
In September 1984, installation of ten additional wells (well clusters
MW-6, MW-7, MW-8 and MW-9) and one observation well (B-l) was initiated by
Law Engineering. The wells were completed in October. Ground water quality
samples were collected in November and December 1984, January, March and
April 1985. THe analyses included 40 CFR 265.92(b)(l) parameters, dissolved
metals and K001 constituents. Previously existing monitoring wells MW-1
and MW-5 were also sampled in November 1984 for K001 constituents.
The presence of K001 constituents was found in several of the newly
installed monitoring wells (MW-6C, MW-7A, MW-7C, MW-8A, MW-8B, MW-9A, MW-9B).
Concentrations were highest in the shallow monitoring wells. Well MW-6C
exceeded the NIPDWS for arsenic. A deep water supply well located on SWP
property was sampled by EPD in May 1985. Several K001 constituents were
reported present in the well. The facility contends that the source of
contamination is suspected to be leakage through the casing from the upper
sand zone, and not a plume of contamination at 308 feet (depth of the well).
Several private wells were also sampled by EPD in May 1985. Some K001
constituents were detected in two of the private wells.
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EPD submitted a proposed Consent Order to SWP in May 1985. The Order
requested an updated GWQAP for the site that was to include results from com-
puter modeling of ground water data, a 40 CFR 261 Appendix VIII scan, and more
information on the hydrogeology of the site. The Consent Order was finalized
in June 1985.
Law Environmental Services prepared the updated GWQAP in June 1985. The
update included results of the Appendix VIII scan, delineation of the waste
management area and identification of the point of compliance at the facility.
Several Appendix VIII parameters were detected in well MW-6C.
In the November 1985 "Report of On-Going Ground Water Quality Assessment,"
a description of the assessment activities associated what work had been accom-
plished to date. Water quality sampling results from November-December 1984 and
January, March and April of 1985 were summarized. Sampling results from the
summer of 1985 were also summarized. K001 constituents were detected in wells
MC-1C and B-l. Barium exceeded the NIPDWS for well MW-5B. In summary, contami-
nation was detected in monitoring well clusters MW-1, MW-6, MW-7, MW-8, MW-9
and observation well B-l.
In January 1986, Segment I of the Corrective Action Plan was submitted
for review. This report merely summarized historical water quality data and
no new analytical results were submitted.
In March 1986, Segment II of the Corrective Action Plan was submitted.
It summarized ground water sampling performed November 1985 through January
1986. Parameters for analysis consisted of K001 constituents and arsenic and
zinc. K001 constituents were detected in 36 of 53 samples. Phenolic consti-
tuents were detected in wells installed in the central plant area (MW-1C, B-l,
B-2A, B-2B, B-3A and B-3B). These wells may be monitoring contamination emana-
ting from solid waste management units. The source of phenolic constituents in
wells installed adjacent to the drainage ditches north and east of the plant is
probably the PGP spill of April 1973.
Polynuclear Aromatic Hydrocarbons (PAH) were detected in 34 of 53 ground
water samples collected in the Recent alluvium. Wells with PAH constituents
included MW-6C, MW-8B, MW-9B, STB-11, MW-22, STB-25, B-6 and other wells lo-
cated north and east of the plant.
Arsenic and zinc were detected in several wells, with the highest con-
centrations in B-5, located near the discontinued ZMA mix system. Arsenic
exceeded the NIPDWS in STB-17, B-2B, and MW-1C.
Soil samples taken from test pits or soil test borings were analyzed
for K001 constituents and for arsenic, zinc and chromium. PAH and/or phenols
were detected in samples taken near the K001 surface impoundment, the CERCLA
landfill and the central plant area. Free oil was also encountered in many
test pits and soil borings around the plant.
In July 1986, Segment III of the Corrective Plan was submitted for review.
The report summarized the ground water sampling performed April-June 1986,
as well as historical water quality data from 1985. K001 constituents were
detected in 17 of the 38 wells. Contamination was found in wells, soil test
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borings, and test pits both on- and off-site. Contamination was more extensive
in the Recent alluvium.
At the time of the Task Force evaluation, the facility was preparing an
update on the GWQAP. It is obvious from historical water quality that con-
tamination from the K001 surface impoundment, solid waste management units
and spills is emanating from the SWP site and traveling off-site. The Task
Force recommends that the assessment program should be expanded to include
all of the SWP site and more monitoring should be directed towards the lower
aquifers underlying the site. Additional wells, soil test borings, cores, etc.
are needed to adequately assess the areal and vertical extent of the contamin-
ant plume(s).
Southern Wood Piedmont Sample Collection and Handling Procedures
At the time of the Task Force evaluation, SWP personnel followed the
"Sampling and Analysis Plan" submitted as a section of the October 1985
Part B. The following is a summary of the sampling protocol followed by
SWP personnel:
A. With gloves on, remove cap from well and place in plastic bag.
B. Remove bailer from well and rinse thoroughly with acetone and
distilled water.
C. Rinse water level indicator probe thoroughly with acetone and
distilled water.
D. Obtain elevation of the ground water using the water level meter.
E. Insert clean PVC bailer into well and lower until water is reached
(usually splashing sounds will be indicated). Continue to lower
bailer until filled. Proceed to raise bailer out of well casing.
F. Flush the well before obtaining sample by bailing well to dryness
or bailing 3 to 5 casings, (volume of water standing in well)
whichever is less. NOTE: In the event of low yielding wells, a
24-hour time span may be needed for recharging after evacuation
before sampling can be resumed.
G. Fill bottle(s) directly from bailer without over-filling or spilling -
the bottles contain preservatives.
H. When all bottles are full, rinse the bailer with distilled water
and store in the same well casing.
I. Replace cap.
J. Take pH, temperature and conductivity at site with designated
instrumentation.
K. Record all measurements taken on field data sheets.
-------
-22-
Sampling collection activities proceed from the least contaminated area
to the most contaminated area.
A copy of the October 1985 "Sampling and Analysis Plan," chain-of-custody,
etc. is included as Appendix C of this report.
At the time of the evaluation, no one from the Task Force was able to
observe the sampling collection and handling procedures utilized by SWP. Plans
were made for the Task Force project coordinator to observe quarterly sampling
at a later date. SWP had by that time implemented a revised "Sampling and
Analysis Plan" (March 1987). Observation of sampling procedures under the
revised protocol would not serve the purpose of the Task Force objectives.
However, EPA-Region IV had observed sampling procedures at other SWP facilities
in the Region. SWP utilized the same sampling and analysis plan for all facili-
ties . In all cases, SWP personnel closely followed the protocol that had been
established in the October 1985 sampling and analysis plan.
Some comments on the sampling protocol Used by SWP are:
1. Bailers should not be left hanging in the saturated zone in a well.
It is recommended that the bailers be thoroughly cleaned between
sampling episodes and stored wrapped in aluminum foil. New bailing
rope should be used for each sampling event.
2. PVC is not recommended as a sampling material when organics are of
a primary concern. A more inert material such as Teflon is recom-
mended .
3. Cleaning the bailers with acetone may introduce some organics into
the well if the bailers are not totally allowed to dry.
4. An interphase probe is recommended to detect any immicible layers in
the water column. Details should be given on how any immicible layers
will be sampled.
5. Blanks (equipment, trip, field, etc.) are recommended for quality
assurance/quality control purposes.
Except for the bailers left hanging in .the saturated zone of a well, the
procedures utilized by SWP for RCRA ground water monitoring appear adequate for
sampling purposes. However, the RCRA ground water sampling and analysis plan
(SAP) is incomplete.
The 265.92 section of the regulations requires an owner/operator to
obtain and analyze samples from the RCRA monitoring system and to develop
a SAP that should include procedures and techniques for:
a. sample collection,
b. sample preservation and shipment,
c. analytical procedures, and
d. chain-of-custody control.
It is the contention of the Task Force that the sampling and analysis
plan available for review at the time of the inspection was not sufficient
-------
-23-
to satisfy the regulations. The SAP was not detailed nor site-specific, but is
a generic plan used for all SWP sites and lacked information such as:
What type of containers and preservatives are used for samples?
Are the PVC bailers decontaminated between sampling events?
There are some references in the SAP for the reader to refer to the
permit application for specific information on sampling and analysis pro-
cedures. The SAP should stand alone as a document and include all information
pertinent to sampling and analysis at a facility.
TASK FORCE SAMPLE COLLECTION AND HANDLING PROCEDURES
This section describes the well evacuation and ground water sampling pro-
cedures followed by Task Force personnel during the January 1987 site inspection.
Samples were collected by an EPA contractor (Alliance Technologies Corp.) to
determine if the ground water contains hazardous waste constituents or other
indicators of contamination.
Water samples were collected from wells 1A,B,C, 5A,B,C, 6A,B,&C, 8A&B,
IOC, 13D, 30, 37A, and 38A&B. Thirteen of the wells are located on SWP pro-
perty and five wells are located off-site. The selection of these wells
was based on well locations to provide areal coverage both up and downgradient
of the surface impoundment, and to monitor possible off-site contamination.
The well locations are identified in Figure 3.
EPA Region IV requested and received split samples for the wells 5A,
8A&B, 13D. SWP split on all -samples and GA-EPD declined to split samples
for independent analysis. A field blank was poured the last day of sampling
by the EPA contractor at a location specified by the Task Force. Water used
to pour the blanks was HPLC water. Duplicates were taken from wells 8A and
38B for quality assessment/quality control (QA/QC) purposes. A trip blank was
poured after all samples were taken on the last day and an equipment blank was
poured prior to the trip for QA/QC purposes.
All sample bottles and preservatives were provided by an EPA contractor
(I-Chem). Samples were collected by the EPA sampling contractor using the
following protocol:
a. Depth to ground water was determined by using a Johnson water marker
and an Oil Recovery Systems interface probe to detect any immicible
layers in the water column. Total well depth also measured.
b. Height and volume of the water column then calculated.
c. Calculated three water column volumes.
d. Purged the well three well volumes using a precleaned 2-inch Teflon
double check-valve bailer.
e. Prior to sampling, the EPA sampling contractor monitored the open
well for chemical vapors using an OVA meter.
-------
-24-
f. Collected a sample aliquot and made field measurements (water tempera-
ture , specific conductance and pH) a minimum of three times.
g. EPA contractor filled VOA vials, then filled the remaining sample
containers in the order shown on Table 3.
h. EPA contractor placed samples on ice in an insulated container immedi-
ately after filling the bottles.
The first step in the ground water well sampling procedure is to measure
the depth from a reference point at the wellhead. At SWP, that reference is
a known elevation at a mark near the top of the well casing. The EPA sampling
contractor used an electric water-level recorder to measure the depth to water.
The recorder was rinsed with isopropanol alcohol, followed by a rinse with
HPLC deionized water and allowed to air dry. The recorder used for this exer-
cise was clean and kept protected from potential outside contamination. Water-
level measurements were made to within 0.01 foot. Task Force personnel noted
that the Oil Recovery Systems interface probe detected three distinct phases
in the water column for Well 1C. The sample taken from the well was a black,
viscous liquid.
The volume of water to be purged was then calculated. The column volume
of a well is the volume of standing water in the well and is calculated using
the depth-to-water measurement, total well depth (determined in the field
with well sounder) and casing radius. For purposes of the Task Force, the
column volume is multiplied by three to compute the purge volume. The volume
is measured into a graduated bucket as it is taken from the well. In all
cases, standard field measurements (temperature, pH, specific conductance) were
taken to determine when sampling should begin. Field measurements are given in
Table 4.
The wells were purged by the EPA sampling contractor using a pre-cleaned,
double check-valve Teflon bailer which was lowered into the well with Teflon-
covered stainless steel cable. Prior to purging, OVA readings were made to
monitor the open well for chemical vapors. Readings ranged from not above
background for most wells to 100 ppm in well 37A. Parameters by parameter,
the EPA contractor filled the sample containers in the order listed in
Table 3.
After sampling was completed, the EPA contractor took the samples to a
staging area where a turbidity measurement was taken. Samples for metals,
TOG, phenols, cyanide, and sulfides were preserved.
At the end of the day, samples were packaged for shipment to the EPA Con-
tract Laboratories. The EPA Region IV samples were released to EPA Region IV
Environmental Services Division personnel for transport. A "Receipt for
Samples" was given to SWP for the samples taken off-site by the Task Force.
All samples were shipped according to applicable Department of Transportation
regulations (40 CFR Part 171-177). All water samples from monitoring wells
were considered "environmental" for shipping purposes.
-------
-25-
LABORATORY EVALUATION
Savannah Laboratories and Environmental Services, Inc. (SLES) of
Savannah, Georgia, conducts the 40 CFR Part 265 Subpart F water-quality
analyses for Southern Wood Piedmont in Augusta, Georgia. The laboratory
facilities were evaluated as part of the Task Force Evaluation on September
29, 1987, by Mr. Michael H. Birch of the Laboratory Evaluation and Quality
Assurance Section of the EPA Region IV, Environmental Services Division.
The laboratory was evaluated for the ability to produce quality data for those
parameters required by Part 265.92 and Part 261.32 (K001 listing; of hazardous
chemicals for wood preservation).
Analytical equipment, sample handling, preservation technique, methods
and quality assurance procedures were examined for adequacy. Laboratory
records were reviewed for completeness, accuracy and compliance with State and
Federal requirements.
Ground-Water Sampling and Analysis Plan
The documents reviewed during the inspection were:
1. "Sample and Analysis Plan For Groundwater Monitoring," SWP,
March 1987.
2. "Generic Quality Assurance Plan," SLES, June 1986.
3. "Statement of Qualifications," SLES.
The SWP Sample & Analysis Plan (SAP) For Groundwater Monitoring is a
comprehensive document. It presents procedures for collecting, preserving,
handling, documenting (field records and chain-of-custody) and shipping
samples. The document is a generic plan for all related SWP facilities and
was made site specific for the Augusta facility by including tables. Table 2
in the SAP lists holding times of 24 hours for pH, 28 hours for specific
conductance, and none established for TOH. The TOH must be a misprint for
TOX.
Regulatory Requirement: Samples for pH and specific conductance analyses must
be analyzed immediately, and a maximum holding time of seven days is allowed
for TOX. (Reference: Table 11-1, SW-846, Third Edition.)
The sample containers prepared by SLES were prelabeled for the required
parameters and shipped to the facility. Premeasured preservatives for each
sample were shipped in the sampling bottles or in small vials. The sample
containers and preservatives meet the EPA requirements. SLES periodically
checks the sample preservation, where pH adjustment is required, after the
samples arrive in the laboratory.
In the SAP, the Procedures For Obtaining A Representative Ground Sample. (page
9) indicates that the laboratory will supply the filters (usually 0.45 micron
membrane filter) for filtering samples for dissolved metals.
Regulatory Requirement: Samples for dissolved metals must be filtered through
a 0.45 micron filter.
-------
-26-
On page 14, The SAP states that turbid samples for total metal analyses
are to be filtered in the field prior to preservation. Filtering of samples
collected for analysis of metals used to determine the suitability of ground
water as a drinking water supply is not consistent with methods required for
such supplies (40 CFR Part 141.23(f)). Data from analysis of filtered samples
may be biased low. The effects of filtering on ground-water samples collected
at the SWP, Augusta facility need to be documented. The data were reported as
"total" instead of "dissolved" metals.
Sample containers, preservatives, and holding times were consistent with
EPA requirements, except for the deficiencies mentioned in the SWP Sample and
Analysis Plan.
Field measurements (pH and specific conductance) conducted by SLES
personnel were not observed by the auditor. Meter calibration, quality
control checks, documentation and reporting were discussed with the SLES
staff. The pH meter was calibrated daily against a pH 7 buffer. Other
buffers were available, but were not used with each calibration.
Regulatory Requirements: The pH meter/electrode system must be calibrated for
each use period against a minimum of two buffers that bracket the expected pH
of the samples and are approximately three pH units or more apart. (See Method
9040, SW-846.)
Laboratory Sample Analysis
If TOG samples cannot be analyzed immediately, preservation by lowering
the sample pH to less than two ( <2) is required. SLES was preserving the
samples to meet this requirement to retard any biological action during
shipping and prior to analysis. The inorganic carbon constituents are
normally removed by lowering the sample pH, followed by purging with an inert
gas, prior to measuring the TOG. This technique, used for total organic
carbon (TOG) samples preserved with I^SO^, would cause volatiles to be
stripped from the sample during the sample preparation step to remove
inorganic carbon (CC^) prior to measurement of the organic carbon. The method
detection limit for TOG (approximately 1 mg/L) is at least one to two orders
of magnitude above the concentration of the volatile organic components of the
TOG. However, these volatiles should be detected in the VGA analysis.
Therefore, the emphasis on organic contamination should be placed on the VGA
results instead of the TOG data. Standards were carried through the
appropriate digestion steps and were analyzed at the start of each run.
However, a calibration standard or a quality control standard was not analyzed
periodically throughout the process while the samples were analyzed.
Regulatory Requirement: The calibration must be verified after every 15
samples throughout the analytical process to ensure proper calibration. (See
Method 9060, SW-846.)
Samples for phenol analysis were preserved with sulfuric acid to pH <2
and analyzed by EPA Method 420.1, EPA 600/04-79-020. The contract laboratory
lowered the sample aliquot pH to one (1) prior to the distillation step. This
practice may result in data biased low for this parameter. Check standards
were carried through the same procedure. ,
-------
-27-
Method 420.1, Method 9065, SW-846, and Footnote 25, 40 CFR Part 136,
Guidelines Establishing Test Procedures for the Analysis of Pollutants.
Federal Register, June 30, 1986, require that the sample pH be raised to
approximately 4 prior to distillation.
Assurance and Data Documentation
The SLES laboratory has established a formal quality assurance (QA)
program that consists of a QA plan, standard operating procedures (SOP) and
includes the use of duplicates, spikes, and reference standards to verify the
quality of data for each parameter analyzed. Instrument calibration and
maintenance records were maintained, and temperatures of regulated devices
were checked and documented. All raw data, quality control records and
calculations were documented and maintained on file as required. Method
detection limits (MDL) were determined according to procedures in EPA's 40 CFR
Part 136, Appendix B. When matrix interferences or some other problem
prevents the routine reporting of MDLs, the laboratory reports a Practical
Quantitation Limit (PQL) , which is proper protocol as stipulated in the
guidelines for EPA's Contract Laboratory Program for reporting data with
sample matrix interferences .
Summary
Based on the overall findings, the contract laboratory has the capability
to provide acceptable quality data for the ground- water monitoring program.
Field filtration of turbid samples could cause biased data for copper, arsenic
and chromium. The data would be something less than "total" metals. The
deficiencies noted for pH (holding time and methodology) could cause the
results to be questionable and subsequent failure of the Student's t Test.
The holding time deficiency noted for TOX would cause the data to be
questionable. The deficiencies noted for phenol and TOG would have no major
impact on data quality.
All other analytical data for parameters indicating the presence of K001
chemicals, (Table 7); parameters establishing ground-water quality, (Table 8);
and parameters used as indicators of ground-water contamination, (Table 9) ;
would be acceptable for the Subpart F, Ground-Water Monitoring requirements.
Please note that the Sampling and Analysis Plan in use at the time of the
Task Force evaluation is not the same plan that was evaluated as part of the
September 1987 lab evaluation. Both plans have been included in Appendix C for
the reader's reference.
MONITORING DATA ANALYSIS
Acceptability and Validity of Data
The samples collected during this evaluation were analyzed by Compu
Chem Laboratories, Research Triangle Park, North Carolina, and Centec Labora-
tories, Salem, Virginia. Compu Chem performed the organic analyses and
Centec performed the inorganic analyses. The results were compiled and
tabulated by Life Systems, Inc. and forwarded to the Task Force for evalua-
tion. The OSWER functional guidelines for evaluating contract laboratory
program data, as well as the Region IV EPA protocols were used to assess
-------
-28-
the validity of the data. The quality assurance/quality control check of the
data indicated that much of the purgeable, extractable, pesticide and PCB data
was unusable because the holding times for the samples were exceeded. Some
data for the inorganic, conventional and indicator parameters was considered to
be unreliable because contamination was found in the blanks taken in the field
and from the equipment used in the field. All other data was given as an actual
value, as quantitative or qualitative, as estimated in concentrations or as
presumptive evidence of material. (See Table 5 for analytical data summary.)
DISCUSSION OF RESULTS
Inorganic Elements/Compounds
The contract laboratory data indicated that 20 elements and compounds were
detected in samples collected from the monitoring wells at SWP. The National
Interim Primary Drinking Water Standard (NIPDWS) of 10 ug/1 for cadmium was
exceeded in well 13D with 14 ug/1. The NIPDWS of 50 ug/1 for lead was met or
exceeded in wells 13D and 37A, with 57 ug/1 and 50 ug/1 respectively. Well IB
had an estimated value of 3.8 ug/1 for mercury which exceeds the NIPDWS of 2
ug/1. The NIPDWS of 50 ug/1 was exceeded for arsenic in wells 1C and 6C with
estimated values of 36,000 ug/1 and 1,000 ug/1 respectively. The NIPDWS of 50
ug/1 for chromium was exceeded in well 30 with 170 ug/1. However, the analytical
data for arsenic and chromium should not be used because of blank contamination.
The Secondary Drinking Water Standards for iron and manganese were exceeded in
the majority of the eighteen wells sampled.
Conventional/Indicator Parameters
Nine conventional/indicator parameters were detected in the monitoring
wells sampled by the Task Force. Chloride values ranged from 20 ug/1 in well
8A to 1,800 mg/1 in well 8B. Fluoride concentrations ranged from not detected
to 9.4 mg/1 in well 1C. Sulfate values ranged from not detected to 2,900
mg/1 in well 6A. Values for sulfides ranged from not detected to 5.0 mg/1 in
well 1C. Values for phenols (4AAP) ranged from not detected to 49,000 mg/1 in
well 1C. POC concentrations ranged from not detected to an estimated value of
26 mg/1 in well 5B. POX concentrations ranged from not detected to an estimated
value of 290 ug/1 in well 13D. The majority of the TOG and TOX values were not
usable because of blank contamination.
Extractable Organic Compounds
The majority of the contract laboratory extractable data was not usable
because the holding times were exceeded for the samples. Very few actual
concentrations were given for the wells. Most of these values were estimated.
Resampling and reanalysis are necessary for verification.
Purgeable Organic Compounds
Again, as with the extractable data, the majority of the purgeable data
was not usable. Host actual values given are estimated. Any further
discussion of the results would be pointless.
-------
-29-
Split Samples '
Split samples were taken from wells 5A, 8A, 8B, and 13D. It was difficult
to compare the EPA-ESD data with the contract laboratory data because so much of
the contract data was unusable or unreliable for reasons stated previously.
The EPA-ESD data indicated that 49 extractable organic compounds were
detected in well 8B, six extractable compounds were detected in well 5A, only
one ex- tractable compound was detected in well 13D, and none in well 8A. No
purgeable organic compounds were detected in wells 8A and 13D, well 5A had one
purgeable compound, and well 8B indicated 10 purgeable compounds. None of the
NIPDWS were exceeded in these four wells. Iron exceeded the Secondary
Drinking Water Standard in wells 8A, 8B, and 13D. Manganese exceeded these
standards in well 8B.
-------
REFERENCES
1. Clark, W. Z. , Jr. and A. C. Zisa, Physiographic map of Georgia; Georgia
Geologic Survey map GM-8, 1976.
2. Clarke, J. S.; R. Brooks; and R. E. Faye, Hydrogeology of the Dublin and
Midville aquifer systems of east-central Georgia; Georgia Geologic Survey
Information Circular 74, 1985.
3. Cooke, C. W., Geology of the coastal plan of Georgia; U. S. Geological
Survey Bulletin 941, 1943.
4. Faye, R. E., and D. C. Prowell, Effects of late Cretaceous and Cenozoic
faulting on the geology of the coastal plain near the Savannah River,
Georgia and South Carolina; U. S. Geological Survey Open-File Report
82-156, 1982.
5. Georgia Geologic Survey, Geologic Map of Georgia; Georgia Geologic Survey
Geologic Map GM-7, 1976.
6. Gorday, L. L., The hydrogeology of the Coastal Plain strata of Richmond
and northern Burke Counties, Georgia; Georgia Geologic Survey Information
Circular 61, 1985.
7. Huddlestun, P. E., Correlation chart of the coastal plain of Georgia;
in Hydrogeologic evaluation for underground injection control in the
coastal plain of Georgia; R. Arora, ed.; Georgia Geologic Survey Hydro-
logic Atlas, 10.
8. Law Environmental Services, Additional Monitoring Well Installation and
Hydrogeologic Assessment. Southern Wood Piedmont, Augusta, Georgia,
January, 1985.
9. Law Environmental Services, Corrective Action Plan - Segment 1: Ground
Water Migration Control. Southern Wood Piedmont Company. Augusta.
Georgia Facility. January 1985.
10. Law Environmental Services, Report of On-Going Ground Water Quality
Assessment. Southern Wood Piedmont Company. Augusta. Georgia Facility.
November, 1985.
11. Law Environmental Services, Corrective Action Plan - Segment 2: Source
Control. Southern Wood Piedmont Company. Augusta. Georgia Facility.
March 1986.
12. Law Environmental Services, Corrective Action Plan - Segment 3: Off-Site
Plume Control. Southern Wood Piedmont Company. Augusta. Georgia Facility.
July 1986.
13. Law Enforcement Services, 1986 Annual Ground Water Quality Assessment
Report. Southern Wood Piedmont Company. Augusta. Georgia. February, 1987.
-------
14. LeGrand, H. F. Geology of the Coastal Plain and ground water resources,
in Geology, and ground water resources of central-east Georgia; Georgia
Geologic Survey Bulletin No. 64, 1956.
15. Siple, G. E., Geology and ground water of the Savannah River Plant and
vicinity, South Carolina; U. S. Geologic Survey Water Supply Paper 1841,
1967.
16. Smith, L. W., and D. T. King, Jr., The Tuscaloosa formation: fluvial
facies and their relationship to the basement topography and changes
in paleoslope, in Current studies of Cretaceous formations in eastern
Alabama and Columbus, Georgia, a guidebook for the Twentieth Annual
Field Trip of the Alabama Geological Society; 1982.
17. Southern Wood Piedmont, Part B Permit for Augusta, Georgia Facility,
October 1985.
-------
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-------
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FIGURE 3
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-------
TABLE 1
RCRA GROUND WATER MONITORING PARAMETERS
*Categorv
**Categorv 2
***Categorv 3
Arsenic
Barium
Cadmium
Chromium
Fluoride
Lead
Mercury
Nitrate (as N)
Selenium
Silver
Endrin
Lindane
Methoxychlor
Toxaphene
2, 4-D
2,4,5-TP Silvex
Radium
Gross Alpha
Gross Beta
Turbidity
Coliform Bacteria
Chloride
Iron
Manganese
Phenols
Sodium
Sulfate
pH
Specific Conductance
Total Organic Carbon
Total Organic Halogen
*EPA Interim Primary Drinking Water Standards
**Ground Water Quality Parameters
***Ground Water Contamination Indicator Parameters
-------
TABLE 2
Wells Designated for Ground Water Monitoring
Date of Monitoring
Well Active Monitoring Designation
MW2 January 1982 ' downgradient
MW3 to downgradient
MW4 October 1984 downgradient
MW5 upgradient:
MW6C October 1984 downgradient
MW7C to upgradient:
MW8B ? downgradient
MW9B downgradient
upgradient
-------
TABLE 3
ORDER OF SAMPLE COLLECTION,
BOTTLE TYPE AND PRESERVATIVE LIST
Parameter
Bottle
Preservative
Volatile Organic Analysis (VOA)
Purgeable Organic Carbon (POC)
Purgeable Organic Halogens (POX)
Extractable Organics
Total Metals
Total Organic Carbon (TOG)
Total Organic Halogens (TOX)
Phenols
Cyanide
Sulfide
Anions
Dioxin
Dissolved Metals
2 40-ml VOA vials
1 40-ml VOA vial
1 40-ml VOA vial
6 1-qt. amber glasses
1 qt. plastic
1 150-ml glass
1 qt. amber glass
1 qt. amber glass
1 qt. plastic
1 qt. plastic
1 40-oz. glass
2 1-qt amber glass
1 qt. plastic
HN03
H2S04
H2S04
NaOH
Zinc acetate,
N OH
-------
TABLE 4
FIELD MEASUREMENTS
SOUTHERN WOOD PIEDMONT
AUGUSTA, GEORGIA.
WELL
NUMBER
MW 1A
MW IB
MW 1C
MU 5A
MW SB
MW SC
MW 6A
MW 65
MW 6C
MW-8A
MW SB
MW IOC
MW 13D
MW 18C
MW 30
MW 37A
MW 38A
MW 38B
WATER
DATE LEVEL TOTAL GALLONS
SAMPLED (in feet DEPTH PURGED
from cop of well
of csg.) (In feet)
1-30-87 11.29 63.51 26.5
1-30-87 11.28 47.35 17.6
1-30-87 4.95 22.40 --
1-26-87 10.18 60.43 24.5
1-28-87 9.67 45.79 17.3
1-27-87 3.26 18.01 7.1
1-29-87 10.71 73.89 30.8
1-29-87 11.26 39.39 13.75
1-29-87 6.02 12.95 4.0
1-28-87 10.42 29.04 9.5
1-28-87 5.88 7.21 1.0
1-27-87 3.66 20.98 8.5
1-29-87 2.66 11.41 4.3
1-30-87 11.32 39.00 13.5
1-27-87 4.07 15.22 7.0
1-27-87 17.69 37.63 9.75
1.-28-87 6.20 30.05 11.5
1-28-87 0.96 7.68 4.5
TIME
0843
0901
0913
0857
0920
0935
1430
1500
1535
1020
1035
1510
1520
1530
0916
1258
1323
1345
1445
1450
1500
1610
1615
1345
1400
1410
1358
1410
1305
1335
0855
0859
0905
1120
1128
1130
1135
1140
1045
1325
1335
1340
0940
0955
1000
0945
0955
1000
pH
6.4
5.3
5.6
5.9
5.4
5.2
-
12.5
12.2
11.7
12.6
12.4
7.0
6.1
5.4
5.9
7.8
7.0
6.6
6.1
6.1
6.1
5.2
5.0
8.8
7.8
7.9
6.1
6.1
4.1
4.6
5.9
5.7
5.6
10.3
7.2
6.3
6.0
5.8
5.4
5.7
5.7
5.6
10.5
10.0
9.6
4.8
5.2
5.2
TEMP.
c.
21.3
20.8
20.6
21.0
20.9
20.8
18.5
18.1
18.1
16.9
16.4
13.4
15.9
15.8
10.7
18.6
18.7
18.7
18.5
19. C
19.1
15.0
14.1
15.2
17.2
17.9
13.2
12.6
12.1
14.6
10.1
12.2
12.5
20.4
19.8
19.4
19.4
19.5
19.3
18.0
16.7
18.0
15.7
17.9
17.6
10.4
12.1
12.3
SPECIFIC
CONDUCTIVITY
(umhos)
87
71
73
79
75
68
--
9500
5000
3500
11,500
10.500
310
290
250
275
12
85
66
185
140
101
490
470
155
136
130
6400
7250 . ' "
130
161
93
99
100
260
200
180
180
180
140
142
163
175
390
270
230
105
144
142-
OVA
(ppin)
NAB
NAB
40
NAB
NAB
NAB
NAB
NAB
NAB
100
REMARKS
low turbidity;
clear water
highly turbid;
yellow-gold color *
three distinct phases
in the water column;
black, viscous liquid
purged well to dryness;
turbid; visible suspended
particles; tan-colored
purged 1-26-87; turbid
over 100 NTU
over 100 NTU
turbid; cloudy;
white grey color
turbid; over 100
NTU; milky color
very turbid;
blue grey color
over 100 NTU
over 100 NTU; blue-grey
color; visible particles;
chemical odor in water
very turbid and silty;
grey-brown color
turbid; heavy
particulates; yellow
color
very turbid; grey-black
color; suspended
particles
purge water had low
turbidity; sample water*
had high turbidity '
very turbid; over
100 NTU; yellow color "
orange color;
clear hard crystals
on bailer rope
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TABLE 6
SOUTHERN WOOD PIEDMONT
AUGUSTA, GEORGIA
ESD - ATHENS
ANALYTICAL DATA SUMMARY
5A 8A 8B 13D
01/26/87 01/28/87 01/28/87 01/29/87
1600 1425 1600 0900
INORGANIC ELEMENT/COMPOUND
BARIUM
CHROMIUM
COPPER
STRONTIUM
TITANIUM
VANADIUM
YTTRIUM
ZINC
MERCURY
ALUMINUM
MANGANESE
CALCIUM
MAGNESIUM
IRON
SODIUM
EXTRACTABLE ORGANIC COMPOUNDS
NAPHTHALENE
ACENAPHTHENE
FLUORENE
PHENANTHRENE
PHENOL
2,4-DIMETHYLPHENOL
HYDROXYMETHOXYBENZALDEHYDE
(HYDROXYMETHOXYPHENYL)ETHANONE
(HYDROXYDIMETHOXYPHENYL)ETHANONE
PHOSPHORIC ACID,TRIPHENYL ESTER
CYCLOHEXANONE
DIMETHYL?YRIDINE
ETHYLMETHYLBENZENE (2 ISOMERS)
ISOCYANOBENZENE
TRIMETHYLPYRIDINE (2 ISOMERS)
ETHENYLMETHYLBENZENE (2 ISOMERS)
METHYLHEPTANONE
INDENE
TRIMETHYLBICYCLOHEPTANONE
DIMETHYLPHENOL (NOT 2,4-)(4 ISOMERS)
ETHYLHEXANOIC ACID
TRIMETHYLCYCLOHEXANEMETHANOL
METHYLPROPYNYLBENZENE
TRIMETHYLPENTANEDIOL
CHLOROPHENOL (NOT 2-)
BENZOTHIOPHENE
ETHYLHEXANEDIOL
UG/L
UG/L
MG/L
MG/L
1.1J
8JN
10JN
UN
3JN
UG/L
MG/L
5100
160
97
52
650
1100
200JN
50JN
100JN
50JN
200JN
400JN
200JN
200JN
50JN
1000JN
200JN
200JN
200JN
200JN
'800JN
500JN
100JN
UG/L
77
750
14
2900
. -
110
32
20
13
12
2000 %
500
45
520
140
150
90
NAI
20000
1800
85
48
18
52
260
160
18
20
51000
42
MG/L
160
0.61
6.5
UG/L
15
0.77
0.70
3.0
UG/L
120
29
180
1300
UG/L
4.0
1.5
20
22
UG/
-------
«J11 / UU Jl f ,
iBL
TABLE 6
SOUTHERN WOOD PIEDMONT
AUGUSTA, GEORGIA
BSD - ATHENS
ANALYTICAL DATA SUMMARY
5A 8A 8B 13D
01/26/87 01/28/87 01/28/87 01/29/87
1600 1425 1600 0900
EXTRACTABLE ORGANIC COMPOUNDS
ETHYLMETHYLPHENOL (3 ISOMERS)
BENZENEACETIC ACID
DIHYDROINDENONE
1-METHYLNAPHTHALENE
METHYLQUINOLINE (2 ISOMERS)
BENZENEPROPANOIC ACID
DIHYDROINDENOL
BIPHENYL
METHYLINDOLE
DIMETHYLQUINOLINE (2 ISOMERS)
METHYLDIHYDROINDOLE
NAPHTHALENECARBONITRILE
NAPHTHALENOL
BIPHENYLOL (2 ISOMERS)
METHYLNAPHTHALENOL (3 ISOMERS)
ISOQUINOLINONE
ISOQUINOLINOL
METHYLQUINOLINONE (2 ISOMERS)
METHYLQUINOLINOL (2 ISOMERS)
DIBENZOFURANOL
3 UNIDENTIFIED COMPOUNDS
HEXANOIC ACID
2-METHYLPHENOL
4-METHYLPHENOL
DIBENZOFURAN
2-METHYLNAPHTHALENE
OCTAMETHYLCYCLOTETRASILOXANE
PURGEABLE ORGANIC COMPOUNDS
BENZENE
TOLUENE
ETHYL BENZENE
TOTAL XYLENES
HEPTANONE (2 ISOMERS)
ACETONE
METHYL ETHYL KETONE
METHYL BUTYL KETONE
METHYL ISOBUTYL KETONE
STYRENE
i
I
CONVENTIONAL PARAMETERS
PHENOL (4AAP)
TOTAL ORGANIC CARBON
UG/L
UG/L
4JN
UG/L
UG/L
92J
UG/L
NA
MG/L
3.8
UG/L
NA
MG/L
UG/L
400 JN
300 JN
300 JN
3COJN
800 JN
800JN
300JN
100JN
50JN
100JN
200JN
200JN
200JN
400JN
100JN
1000JN
1000JN
200JN
100 JN
100JN
2000J
50JN
830
3500
100
280
UG/L
17
39
51
130
40JN
980
110
21J
7.6J
7.3J
UG/L
6100A
MG/L
250
UG/L
5JN
UG/L
UG/L
MG/L
8.7
-------
>..< UOJ1 I . lOlj
TABLE 6
SOUTHERN WOOD PIEDMONT
AUGUSTA, GEORGIA
BSD - ATHENS
ANALYTICAL DATA SUMMARY
5A 8A 8B 13D
01/26/87 01/28/87 01/28/87 01/29/87
1600 1425 1600 0900
**************t***t**i*******t***********t**********************
"FOOTNOTES***
" A - AVERAGE VALUE
NA - NOT ANALYZED
NAI - INTERFERENCES
J - ESTIMATED VALUE
N - PRESUMPTIVE EVIDENCE OF PRESENCE OF MATERIAL
- MATERIAL WAS ANALYZED FOR BUT NOT DETECTED
-------
TABLE 7
Parameters Indicating the Presence of K001 Chemicals
pentachlorophenol tetrachlorophenol
phenol phenanthrene + anthracene
2-chlorophenol chrysene + benz(a)anthracene
p-chloro-m-cresol ' naphthalene
2,4-dimethyIphenol fluoranthene
2,4-dinitrophenol ' benzo(b,k)fluoranthene
2,4,6-trichlorophenol indeno(l,2,3-cd)pyrene
acenaphthene benzo(a,h)anthracene
copper arsenic
chromium
TABLE 8
Parameters Establishing Ground Water Quality
Chloride Iron
Manganese Sodium
Sulfate
TABLE 9
Parameters Used As Indicators of Ground Water Contamination
Specific Conductance Total Organic Halogen
-------
APPENDIX A
Task Force Analytical Results
Due to size, the raw data is not included in this
report. A copy of the data can be requested from:
EPA, Region IV
Residuals Management Branch
Waste Compliance Section
345 Courtland Street, NE.
Atlanta, Georgia 30365
(404) 347-7603
-------
APPENDIX B
Monitoring Well Construction Data Summary
after Law Environmental Services
for Southern Wood Piedmont
-------
a
«n
<
z
ELL CONSTRUCT K
HONITORING W
ASSESSMENT REPORT
WATER QUALITY i
NUAL GROUND-
00
OK
e
IV, GEORGIA FACILII
DMONT - AUGUST
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:LL CONSTRUCT i
MONITORING
ASSESSMENT REPORT
WATER QUALITY
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APPENDIX C
Sampling and Analysis Plan
Southern Wood Piedmont
Augusta, Georgia
-------
SAMPLING AND ANALYSIS PLAN
FOR
((~~' ., SOUTHERN WOOD PIEDMONT COMPANY
GROUNDWATER MONITORING DURING CLOSURE
October, 1985
-------
TABLE OF CONTENTS
Page
Introduction 1
Parameter Selection 2
Frequency of Sampling and Analysis 2
Sample Collection 3
Sample Preservation and Shipment 3
Determination of Groundwater
Surface Elevation 5
Analytical Procedures 7
Chain of Custody and Sample Shipping 15
-------
list of Figures
Page
Schematic of Groundwater Quality
Monitoring Well
Type III Water Quality Monitoring Well 10
Schematic of Bailer for Well Sampling 12
c
-------
List of Tables
Page
Table 1 11
Table 2 13
Table 3 14
Table 4 15
c
-------
GROUND-WATER MONITORING PLAN
SAMPLING AND ANALYSIS PROCEDURES
INTRODUCTION
A basic premise in developing these procedures is the need for
obtaining a representative sample for analysis. Representative samples are
those which have the physical and chemical characteristics of the ground-water
in the zone being monitored. In particular, emphasis is placed on reducing
the potential for contamination or degradation of the sample by the sampling,
preservation and shipping processes. In general, the philosophy in developing
these procedures is to utilize simple equipment but not preclude the use of
more sophisticated equipment if desired at a future time. Parameter
(^ selection, sampling procedures, and analytical procedures are discussed herein.
WELL INSTALLATION PROCEDURES AND DEVELOPMENT METHODS
""" Type II or III ground-water quality monitoring wells will be
installed. Details of the wells are provided in Figures 2A and 2B (pages 9
and 10). The following items are important to the construction of a water
quality monitoring well.
-Pre-Drilling:
Construction materials and equipment {drill rods, casing, etc.)
will be properly cleaned to reduce the potential for well
contamination. The cleaning procedure will include steam cleaning.
After cleaning, materials (pipe, granular backfill, etc.) will be
protected from contamination. This will be accomplished by
wrapping pipe in plastic and covering stockpiled materials (sand,
gravel, etc.) with plastic.
Water used in well installation/drilling will be clean, preferably
of drinking quality.
-------
UM.illiy dtiu oaliifM Hiy
Type II well boreholes will be advanced without the use of drilling
muds such as bentonite.
Type III well outer casing installation only may use mud.
Split spoon samplers, drill rods, and augers will be steam cleaned
between each borehole location.
t
If borehole stability becomes a problem, a temporary casing will be
utilized.
-Well Installation:
Boreholes will be flushed with clear water during placement of the
screen, solid pipe, and granular backfill.
Depths of materials will be checked during installation to verify
continuity and "as installed" well configuration.
Wells will have a locking protective casing capable of being locked
to prevent damage and/or vandalism.
«
Wells will be allowed to stablize for a period of about 24 hours
and then developed by bailing, pumping, or airlift methods. The
C... amount of water to be removed is dependent on the subsurface
* conditions and drilling techniques. The criteria for well
development is visual (lack o.f significant turbidity) and chemical
(stabilized pH and/or conductivity measurements).
PARAMETER SELECTION
The parameters and concentrations to be evaluated by the ground-water
monitoring program have a direct impact on the procedures for sampling, sample
preservation and analysis. The specific parameters recommended for this
monitoring plan are presented in Table I (page 11).
FREQUENCY OF SAMPLING AND ANALYSIS
Southern Wood Piedmont will monitor those wells and parameters proposed
in the permit application. This sampling and analysis will be performed
quarterly, to continue to assess the rate and extent of the plume. This
.
monitoring will continue until a Post Closure Care Permit is granted. Once
this permit is granted, Compliance Monitoring/Corrective Action will be
initiated for those parameters determined by SWP and the Regional
Administrator.
-------
SAMPLE COLLECTION AND PRESERVATION
Sample collection will be performed by personnel thoroughly trained in
the collecting, handling and shipping of groundwater samples.
f^~ Analyses of the water samples will most probably be conducted by
Savannah Laboratories and Environmental Services of Savannah, Georgia.
Field personnel will use techniques that insure integrity of the sample
by precluding any outside contamination. They will report any problems with
*
or variance from these procedures. Such variations in sampling techniques may
be significant in the ultimate interpretation of the data. .
Since some compounds can be detected in the parts per billion or parts
per trillion range, care must be taken to prevent contamination of samples by
the sampling process. The following precautipns or suggestions should be
taken:
/*" 1) sample collection activities should proceed progressively from the
least contaminated area to the most contaminated area (if this
condition is known);
2) each sample should be obtained using appropriate equipment
(bailers).
i<
Two types of samples are normally collected: grab samples and
composite samples. Grab samples are defined as one time samples of limited
quantities taken for analyses of specific parameters. Composite samples,
i.
required when a larger volume is needed for the analyses of numerous
parameters, involve multiple sampling over a period of time and combining
subsamples to maintain representative conditions. For the groundwater samples
individual grab samples will be obtained using a properly cleaned PVC bailer.
An example of one type of bailer is illustrated in Figure 3 (page 12).
-------
composite sample. The composite sample can also be collected by using a
bailer to fill an.appropriate sized glass container which has been cleaned
prior to use.
NOTE: If samples are needed for metal analysis, they will be collected
I
and filtered in the field using an appropriate filter. The filters will be
,
discarded after use at each well site.
Sampling equipment: the following equipment will be used in the actual
sampling procedure.
1) bailers: SWP has designated PVC bailers per well which will remian'in
the wells when not in use. One bailer for each well will help minimize the
introduction of trace contaminants from other sources.
2) Sample bottles: Prelabled and preservative added sample bottles will be
used. Sample bottles will be prepared and labeled by the chosen laboratory.
Preservative will be added and the number and type of bottles for each well
will be on a form included with the bottles. Bottles will be prepared
according to EPA 600/4-79-020 and other EPA guidelines. Types of bottles and
preservatives are included in Table 2 (page 13). Size of bottles to be used
- . <<
will be determined by the laboratory (depending on parameter required).
3) Distilled water:
4) Gloves: All gloves used are disposable. A new pair will be used at each
well and discarded after use.
5) Plastic bags:
6) Acetone:
7) Rope: Polypropylene or nylon rope will be used and changed at each well
."
prior to sampling.
-------
8) pH meter: Corning Model 3 pH meter will be used.
j 9) Conductivity Bridge: YSI Model 31 Conductivity Bridge will be used.
it ."--''*.
i
r 10) Thermometer: A thermometer will be used to take the temperature of the
i
groundwater at the time of sampling.
11) Water depth Indicator: Soiltest, Inc., Model DR-760A water level meter
will be used to determine the water level of the wells prior to sampling. The
indicator will be rinsed with acetone and distilled water in between samplings
at each location.
ACTUAL SAMPLING PROCEDURE
A. With gloves on, remove cap from well and place in plastic bag.
B. Remove bailer from well and rinse thoroughly with acetone and
f.. distilled water.
C. Rinse water level indicator probe thoroughly with acetone and
1 a
distilled water.
D. Obtain elevation of the groundwater using the water level rneter.
»,
E. Insert clean PVC bailer into well and lower until water is reached
(usually splashing sounds will be indicated). Continue to lower
bailer until filled. Proceed to raise bailer out of well casing.
F. Flush the well before obtaining sample by bailing well to dryness
or bailing 3 to 5 casings, (volume of water standing in well)
whichever is less. NOTE: In the event of low yielding wells, a
.
24-hour time span may be needed for recharging after evacuation
before sampling can be resumed.
G. Fill bottle (s) directly from bailer without over-filling or
spillingthe bottles contain preservatives.
-------
n. wuen 3ii uOuuies ai"c iUi i, r.nse i.ne oaiier NICM uibuiieu water
and store in the same well casing.
I. Replace cap.
f-^ J. Take pH, temperature and conductivity at site with designated
instrumentation.
t
K. Record all measurements taken on field data sheets.
CHAIN OF CUSTODY AND SAMPLE SHIPPING
A Chain of Custody is defined as an accurate written record which will
trace possession and handling of the sample from the moment of collection
through laboratory analysis and final recording of results. An Example of a
Chain of Custody Form is shown on Table 3 (page 14).
The most practical way to minimize chain of custody problems is to
% ,
involve the least number of people and use standardized documentation. The
s activities associated with establishing and maintaining a chain of custody can
be summarized as follows:
* Each sample should be identified on the container(s).
Note: Table 2 (page 13).
* Proper packaging and dispatching samples to the appropriate
laboratory for analysis. Sample containers will be packed in a
L>
proper transportation container (cooler) along with the chain of
custody record form, copies of pertinent field records, and copies
of analysis request fonas, as needed. Field personnel will place a
seal (such as a strip of tape) around the cap of the individual
sample container which would indicate tampering if removed. The
transportation containers will then be sealed and labeled.
* When transferring'the possession of the samples, the transferee
will sign and record the date and time on the chain of custody
record. Each person who takes custody will fill in the appropriate
section of the chain of custody record.
-------
i
' I * Laboratory personnel should then reconcile the information on the
c f ' '- '
'~ll sample-label and seal against that on the chain of. custody record. ;..-
\ Discrepancies between the information on the sample and seal and
that on the chain of custody record and the sample analysis request
sheet should be resolved before the sample is assigned for
analysis. Samples should then be placed in a secured sample
storage room or locked cabinet until assigned to an analyst for
analysis.
ANALYTICAL PROCEDURES
The parameters to be analyzed are summarized in Table 1 (page 11). The
recommended methods for analyses of these parameters are presented in Table 4,
C(page 15).
, ,
-------
* j CHECKLIST OF DO'S AND DON'TS FOR SAMPLING GROUND-WATER .--,-. w^ .,
M ' ' ' ' -f "' ' ''" .-; >-.>' " ~ "- "r^'-- ,VV '-':
\ I The fol 1 owing checkl 1st of "do' s.and don' ts" 1 s included for', personnel %
who conduct the sampling.
00
~~ CLEAN EQUIPMENT BEFORE MEASURING WATER LEVELS AI\ID OBTAINING SAMPLES
MEASURE WATER LEVELS BEFORE DISTURBING THE WELL
REMOVE WATER FROM THE WELL BEFORE COLLECTING WATER SAMPLES
USE WATERPROOF, INDELIBLE INK FOR FIELD RECORDS
RECORD ANY INDICATION OF UNUSUAL CONDITIONS AT SAMPLING LOCATIONS
FILTER TURBID SAMPLES FOR METAL ANALYSES IN THE FIELD PRIOR TO
PRESERVATION, IF APPLICABLE.
REPORT ANY PROBLEMS IN FIELD MEASUREMENTS OR SAMPLING
/' DON'T
' V
ALLOW CLEAN SAMPLE CONTAINERS TO "BECOME CONTAMINATED PRIOR TO USE
PRESERVE TURBID SAMPLES FOR METAL ANALYSES IN FIELD PRIOR TO FILTERING
ASSUME SAMPLES SHIPPED TO LABORATORY ARRIVE ON TIME - ALWAYS CONFIRM.
-------
trir
(NOT TO SCALE)
SOUTHERN WOOD
PIEDMONT CO.
LAW &NGINEERINC TcSTING
COMPANY
SCHEMATIC Of GROUND-WATER
QUALITY MONITORING WELL
TV!'!: II
I
JOB NO. MH234S
FIGURE 2A 4
-------
IRMANENT CASING '*£
ALS OFF CONTAMINATED^
3NE (USED ONLY
HEN NECESSARY)
X1
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GROUND SURFACE
THRSADEO JOINT
ALLOWS FO
GRAVEL PACKING
SLOTTED
(SCREEN)
CENTRALIZER ALLOWS
FOR IMPROVED
GRAVEL PACKING
-\
GROUT SEAL
3ENTONITI SEAL
COARSE SANO OR
FINE GRAVEL
3OTTOM
(NOT TO SCALE}
SOUTHERN WOOD
PIEDMONT CO.
LAW ENGINEERING TESTING
COMPANY
TYPE ill
V/ATcR QUALITY
MONITORmG WELL
JOB NO. MH2345
FIGURE 2B
-------
i I TABLE 1
n . ~~~ ,-,-v
i. 1 . ' " ' ""'-'.
; 11 Summary of Parameters and Frequency of Analyses
.r Groundwater Monitoring Program r
v_ Southern Wood Piedmont
Parameters proposed to indicate the presence of contaminants
are listed in the permit application.
The samples will be taken and analyzed quarterly
c
-------
c
i-i/4~aax i 1.0.
PVCPIPE
18 TO 36"LONG
3/4 OIA
GLASS MAHSt_£
EXTHUOGD ROD
HCL£
NOTE: A PVC FOOT VALVE
ALSO ACCEPTABLE
SOUTHERN WOOD
PIEDMONT CO.
AUGUSTA. GEORGIA
LAW ENGINEERING TESTING
COMPANY
SCHEMATIC OF BAILER
FOR WELL SAMP1.ING
JOB NO. MHZ34S |r|GURC 3
I.
10
-------
TABLE 2
IMDI.I. C.
SAMPLE CONTAINERS, PRESERVATIVES, VOLUMES
COLOR HOLDING
K001 PARAMETERS CONTAINER CODE PRESERVATIVES TIME
Refer to permit .
application Glass purple cool at 4 C 7 days
C
-------
Company:
Name:
Location:
Collector's Name:
Date Sampled:
Field Information:
SAMPLE MONITORING
CHAIN OF CUSTODY RECORD
Company:
c
Sample
Identification
1.
Collector
2.
Time
Chain of Possession
Company
Savannah
/ Lab ID#
Date Sampled
Recipient
Savannah Laboratories
Date Received
-------
1 TABLE 4
i ? ' . '-'W' .- "> :-- :'
Jl "-V , .GROUND-WATER QUALITY fARAMEJERS AND METHODS:
GROUND-WATER PARAMETERS ANALYTICAL METHOD
K001 constituents as
listed in the permit
application EPA 8040-8100
c
-------
SAMPLING AND ANALYSIS PLAN
FOR
GROUNDWATER MONITORING
SOUTHERN WOOD PIEDMONT COMPANY
AUGUSTA, GEORGIA
MARCH, 1987
-------
TABLE OF CONTENTS
Page
I. Introduction 1-2
II. Well and Parameter Selection 3
III. Water Level Evaluation 3
A. Measuring Water Levels 4
IV. Well Evacuation Procedure 4-5
V. Sampling Equipment 6-8
VI. Procedure for Obtaining Representative Sample 9-10
VII. Preparation of Sample for Shipment to
Analytical Lab 11
VIII. Documentation of Field Events 12
A. Field Log Book 12
B. Chain of Custody Form 12 - 13,21
IX. Checklist of Do's and Don'ts 14
-------
List of Figures
Page
FIGURE I Type III Water Quality Monitoring Well 15
FIGURE IISchematic of Bailer for Well Sampling 16
-------
List of Tables
Table 1 Well and Parameter Selection 17
Table 2 Sample Containers, Preservatives 18-20
and Holding Times
Table 3 Chain of Custody Form 21
Table 4 EPA Analytical Methods 22-23
-------
Page 1
SAMPLING AND ANALYSIS PROCEDURES
GROUND-WATER MONITORING PLAN
INTRODUCTION
The basic premise in developing this plan is the need to obtain a
representative groundwater sample.
Representative samples have the physical and chemical characteristics of the
groundwater within the zone (aquifer) from which a sample is obtained. This
plan when followed will guide environmental field personnel in techniques that
insure the integrity of the sample during the collection, storage, and
transportation processes.
This plan and the procedures outlined should be read carefully and completely
before sampling begins. Don't refer to individual sections without having
read the entire S & A procedures.
Emphasis has been placed on procedures that not only reduce the potential of
contaminating the sample by careless sampling but that prevent degradating the
sample from improper preservation and/or packaging for shipment prior to
chemical analysis.
Groundwater sampling and analysis requires implementation of the following
sequence of decisions, procedures or events:
1) Well and Parameter selection
2) Water level evaluation
3) Well evacuation procedure
4) Procedure for obtaining representative sample
5) Preparation of sample for shipment to analytical lab
6) Proper documentation of field events including Chain of
Custody
Procedures for each of the above are found in the following plan.
-------
Page 2
GENERAL SAMPLING REQUIREMENTS
Environmental sampling will be performed by an outside contractor or
SWP personnel trained in collecting and processing environmental samples for
transport to a qualified analytical laboratory. Personnel are required to
maintain a field log and record the following: 1) All Calcuations
2) Visual Observations
3) Field Measurements (pH,
temperature, conductance, etc.), and 4) Problems or variance from
procedures listed in this plan.
Before beginning the sampling event, personnel are requested to review
the following:
1) sample collection activities should proceed progressively from the
least contaminated area to the most contaminated area (if this
condition is known);
2) each sample should be obtained using appropriate sampling
equipment. Dedicated bailers are provided at routinely monitored
wells. New rope will be used at each well. This rope will be
discarded after sampling.
3) Equipment must be cleaned prior to use by the procedure below:
a. Rinse thoroughly with distilled water
b. Rinse with appropriate *solvent
c. Final rinse with distilled water.
d. Rinse bailer with distilled water before storing.
* Use Hexane unless visual contaminates are noted. Acetone should then
be used. Carefully remove, by distilled water rinse any residual acetone.
-------
Page 3
I. WELL AND PARAMETER SELECTION
The groundwater wells listed in Table I, page 15, have been chosen
because their hydrogeologic location enables them to yield groundwater, when
analyzed, that indicates groundwater quality at the site. Southern Wood
Piedmont will collect and analyze water from these wells once a quarter to
continue the sites' Groundwater Assessment Program.
The chemical analytical parameters have been chosen because they are
representative of plant operations. These parameters are listed in Table I,
page 15.
EPA analytical methods to be used for'the parameters selected for this
plan are presented in Table 4, page 20.
II. WELL WATER LEVEL DETERMINATION
A groundwater level determination at each well is necessary before
sampling can begin. The water level within the well is used to calculate the
volume of standing water in the well casing and when converted to mean sea
level is evaluated by hydrogeologists to determine groundwater flow
direction. The measurement is taken as follows:
A. Preparation for water level measurement:
1. Place a clean plastic sheet on ground around well. This sheet
will be used to prevent surface soils from coming into contact
with the purging equipment and lines which would introduce
contamination into the well.
2. Unlock well and place cap on the plastic sheet or in plastic bag.
3. Remove bailer from well and place on the plastic sheet.
4. Rinse water level indicator probe thoroughly with solvent and
distilled water, being careful not to get into or on well.
5. Using water level meter, obtain the water level using the
following procedure:
-------
rage
B. Measuring Water Levels:
1. Turn switch on meter
2. Check instrument to see if working properly by pressing knob until
needle reads 1 miliamperes.
3. Rinse probe with solvent followed by distilled water.
4. Begin to lower cord into well watching closely for the first meter
reading.
5. When needle moves, continue to lower cord until 1 miliamperes
reading is obtained. Repeat for accuracy.
6. Mark the cord at the top of the PVC pipe immediately when the
meter deflects.
7. Remove cord from pipe and measure from the marked area to the
nearest number (ft.) on the cord.
8. Record this number in field log book.
9. Remove the cord from well.
10. Rinse indicator probe with solvent and distilled water.
11. Place water level meter in appropriate container and proceed with
well evacuation.
III. WELL EVACUATION PROCEDURE:
Monitoring wells must be purged prior to sampling. The purging process
is necessary to avoid collection of nonrepresentative (stagnant or stratified)
water and to allow water representative of the aquifer to enter the well.
A. Record in field log book the calculated amount of water to be
evacuated from the well. Also record the calculations from which the
number was obtained.
-------
Page 5
B. Determine the volume of water to be removed from well using the following
equations:
1. Refer to well boring logs for the depth of the well. Subtract the
depth to water elevation from the total depth of well to obtain the
amount of standing water in the well casing.
2. Calculate area (A) (in square feet) using the following equations.
A-TTr2 7^=3.14 r=l/2d d=diameter of well. (All SWP
monitoring wells should have a 2 inch diameter.)
3. To obtain the volume of the well, multiply the area of the well by
the standing water depth in the well using this equation: V = A x
D depth(ft.)
4. Multiply the volume of water obtained by the constant, 7.48 to
convert the volume from square feet to gallons.
5. To convert from gallons to liters, multiply gallons by 4. Evacuate
at least three but preferable five times the number obtained.
C. Remove the calculated amount of water from the well by bailing and
collecting it in a container of known volume (5 gallon pail)*.
D. Once the calculated amount of water has been evacuated, discard water as
follows and proceed with the sampling procedure. Purge water should be
disposed of on-site preferably in the wastewater treatment system, unless
the pruged water is deemed a hazardous material. It should then be
drummed and disposed of using facility disposal processes.
E. After the evuacation procedure is complete rinse bailer with solvent
followed by distilled water. Catch rinse (water obtained from rinsing
the bailer) and place in bottle labelled 'field blank'. One (1) to two
(2) field blanks will be collected per sampling event. The field blank
will be analyzed for the same parameters as the other samples.
* Bail the well to dryness or 3 to 5 volumes, whichever is less. If well
is slow to recharge, allow enough time after purging (not to exceed 24
hours) for water to re-enter casing before sampling.
-------
Page 6
IV. SAMPLING EQUIPMENT: Detailed below is a list of equipment and
implements needed to obtain a represenative ground water sample.
1) Bailers: Each well has a dedicated PVC bailer. (An example of the
bailer is illustrated in Figure 3, page 14). Bailers are stored in the
wells unless visual contamination exist in the well, or headspace in the
well is not sufficient to keep bailer from touching water. When the
bailers can not be stored in the well, they will be labelled and stored
elsewhere on the site.
2) Sample containers: The container type (glass, plastic), the
perservatives it contains (if any), and the number of each type of
container to be filled at each well, will be on a form included with the
sample bottles. The types of containers and preservatives used are
included in Table 2 (page 16). The containers will be prepared by the
laboratory according to EPA 600/4-79-020 and other EPA guidelines .
Field and trip blank containers will be included with each sampling
event. The field blank is to contain water from the final rinsing of
equipment used during sampling. The field blank will be analyzed for
the same parameters as the sample. The trip blank will contain water
from the analytical laboratory. The trip blank will also be analyzed
along with the sample. Size of sample containers will be determined by
the laboratory (depending on parameter required). The sample container
will be shipped to the plant site in coolers prior to each sampling
event. The laboratory will also include with the sample containers a
Chain of Custody form to be used when returning filled containers to the
lab for analysis.
-------
Page 7
3) Distilled water: distilled water is required for cleaning equipment
and implements before and after the sampling event.
4) Gloves: Disposable plastic or rubber gloves will be used at each
well or sampling site and discarded after use.
5) Plastic bags: optional
6) Appropriate cleaning solvent: Acetone or Hexane; used for cleaning
equipment.
7) Rope: New polypropylene or nylon rope must be used at each well
prior to sampling. Discard rope after sampling at each well is
complete.
8) pH meter: Corning Model 3 pH Meter or equivalent will be used.
Calibrate pH meter with buffer prior to use.
9) Conductivity Bridge: YSI Model 31 Conductivity Bridge or equivalent
will be used. Calibrate conductivity meter with standard solutions
prior to use.
10) Thermometer: A thermometer will be used to take the temperature of
the groundwater at the time of sampling.
-------
Page 8
11) Water Depth Indicator: Soiltest, Inc., Model DR-760A water level
meter or equivalent such as an electronic meter or wetted tape, will be
used to determine the water level of the wells prior to sampling. The
indicator will be rinsed with appropriate solvent and distilled water in
between samplings at each location.
12) Plastic Sheets: These sheets approximately 4 feet by 4 feet, will be
placed on the ground around the well during sampling. The sheet will be
discarded after sampling and a different sheet used at the next well.
13) Measuring tape: to be used during water level measurements.
14) Five (5) gallon pail: to contain the groundwater during evacuation.
15) Funnel (optional): for transferring sample from bailer to sample
bottle.
16) Beaker: to be used when measuring pH, Specific Conductance and
temperature.
17) Sealing tape: for sealing cooler and/or bottles prior to shipping to
analytical laboratory.
-------
Page 9
V. PROCEDURES FOR OBTAINING A REPRESENTATIVE GROUND WATER SAMPLE
After the water level measurement has been taken and the well has been purged,
use the following procedures to obtain a resentative groundwater sample .
1. Connect an adequate length of clean new rope to the well's dedicated
bailer. Obtain groundwater samples by lowering bailer into well until
it contacts the water surface. Allow bailer to sink, filling with
minimal water surface disturbance. Slowly retrieve bailer from well
taking care not to allow rope or bailer to contact ground or
surrounding obstacles.
2. Quickly transfer enough water to a beaker and measure the pH,
temperature and specific conductance. Record these measurements in
field log book.
3. Sample collection bottles will have been provided by the laboratory
contracted to analyze the ground water. The bottles will need only to
be labelled as to the well from which the sample was obtained. Fill
the labelled bottles in a way as to minimize agitation and aeration,
using a funnel if necessary.
Do not overfill bottles as some may contain preservatives. The
contract laboratory will provide; l) a form in the shipping container
indicating the number and type of bottles to be filled during the
sampling event and; 2) prelabelled bottles with the necessary
perservatives.
4. The sample request form accompanying the sample containers will
indicate when samples are needed for dissolved metals. The laboratory
will supply the field filter (usually 0.45 micron membrane filter).
Filter the sample in the field. Label the bottle containing the
filtered sample, "Dissolved Metals." Discard filter after use. When
samples are needed for "Total Metals," do not filter sample.
-------
Page 10
5. Repeat above steps as needed to acquire a sufficient sample volume to
fill all containers.
6. Observe sample as container(s) are filled and record observations in
field log book, ie., extremely turbid, visual oil, etc.
NOTE; 1) pH and conductance must be analyzed in quadruplicates at
up-gradient wells.
2) Do not take pH, conductance or temperature directly from sample
bottle.
7. Rinse pH and conductivity probes and thermometer with appropriate
solvent and distilled water. Collect rinse and add to bottle labeled
"field blank." After rinsing, place instruments in designated
containers.
8. Add any needed information to labels, (ie., MW4, up-gradient,
filtered, etc.)
9. Immediately place sample containers in ice.
10. Remove rope from bailer and discard.
11. Rinse bailer with appropriate solvent and distilled water. Store
bailer as discussed on page 6.
12. Wash any other equipment used, ie., beaker, funnel, 5 gallon pail,
etc., with water and detergent, solvent and distilled water.
13. Discard plastic sheet, gloves, etc. and repeat the same procedure at
the next well.
-------
Page 11
VI. PREPARATION OF SAMPLE FOR SHIPMENT TO ANALYTICAL LABORATORY
After all samples are obtained and placed into shipping container, before
the sample can be sent to the analytical laboratory, the following steps must
be taken:
1. Pack sample containers very carefully
2. Place ice in shipping container after packing
3. Place shipping label on container to be shipped
4. Seal container with tape
5. Check package for intergerity
Carefully fill out Chain of Custody Form to include sample identification;
sample number; date sample taken, etc. If Sample Analysis Form is used,
indicate which bottles are to be analyzed and what parameters are needed. If
Sample Analysis Form is not used indicate on Chain of Custody Form analysis
requested. Refer to description of Chain of Custody Form, page 21.
Make a copy of the Chain of Custody Form, Sample Analysis Form, and Field
Log. Place original paperwork in cooler with sample bottles. Add more ice to
cooler, if necessary, label and seal cooler. Ship cooler to analytical
laboratory.
-------
Page 12
VII. DOCUMENTATION OF FIELD EVENTS
All field events, ie., observations, measurements, calculations, etc.,
must be documented. Field personnel are instructed to record all field events
in log notebook. At the end of the sampling the notes should be dated, signed
and copied. A copy should accompany the sample bottles when shipped to the
analytical laboratory.
A Chain of Custody Form should also accompany the sample bottles. A
Chain of Custody form is an accurate written record which will trace
possession and handling of the sample from the moment of collection through
laboratory analysis and final recording of results.' An example of a Chain of
Custody Form is shown on Table 3 (page 19).
The most practical way to minimize chain of custody problems is to
involve the least number of people and use standardized documentation. The
activities associated with establishing and maintaining a chain of custody can
be summarized as follows:
* Each sample should be identified on the container(s).
Note: Table 2 (page 16).
* Proper packaging and dispatching samples to the appropriate
laboratory for analysis. Sample containers will be packed in a
proper transportation container (cooler) along with the chain of
custody record form, copies of pertinent field records, and copies
of analysis request forms, as needed. Field personnel will place a
seal (such as a strip of tape) around the cap of the individual
sample container or around the transportation containers which
would indicate tampering if removed.
-------
Page 13
* When transferring the possession of the samples, the transferee
will sign and record the date and time on the chain of custody
record. Each person who takes custody will fill in the appropriate
section of the chain of custody record.
* Laboratory personnel should then reconcile the information on the
sample label and seal against that on the chain of custody reocrd.
Discrepancies between the information on the sample and seal and
that on the chain of custody record and the sample analysis request
sheet should be resolved before the sample is assigned for
analysis. Samples should then be placed in a secured sample
storage room or locked cabinet until assigned to an analyst for
analysis.
-------
Page 14
CHECKLIST OF DO'S AND DON'TS FOR SAMPLING GROUND-WATER
The following checklist of "do's and don'ts" is included for personnel
who conduct the sampling.
DO
CLEAN EQUIPMENT BEFORE MEASURING WATER LEVELS AND OBTAINING SAMPLES
MEASURE WATER LEVELS BEFORE DISTURBING THE WELL
REMOVE WATER FROM THE WELL BEFORE COLLECTING WATER SAMPLES
USE WATERPROOF, INDELIBLE INK FOR FIELD RECORDS
RECORD ANY INDICATION OF UNUSUAL CONDITIONS AT SAMPLING LOCATIONS
FILTER TURBID SAMPLES FOR METAL ANALYSES IN THE FIELD PRIOR TO
PRESERVATION, IF APPLICABLE.
REPORT ANY PROBLEMS IN FIELD MEASUREMENTS OR SAMPLING
DON'T
ALLOW CLEAN SAMPLE CONTAINERS TO BECOME CONTAMINATED PRIOR TO USE
PRESERVE TURBID SAMPLES FOR METAL ANALYSES IN FIELD PRIOR TO FILTERING
ASSUME SAMPLES SHIPPED TO LABORATORY ARRIVE ON TIME - ALWAYS CONFIRM.
-------
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Page 17
TABLE I
SUMMARY OF WELL AND PARAMETER SELECTION
Parameters Indicating presence of K001
pentachlorophenol tetrachlorophenol
phenol phenanthrene + anthracene
2-chlorophenol chrysene + benz(a)anthracene
p-chloro-m-cresol naphthalene
2,4-dimethylphenol fluoranthene
2,4-dinitrophenol benzo(b,k)fluoranthene
2,4,6-trichlorophenol indeno(l,2,3-cd)pyrene +
benzo(a,h)anthracene
acenaphthene
Parameters indicating presence of metals
copper
arsenic
chromium
Wells to be sampled
STB-13
STB-18
MW-1A
MW-5B
MW-6B
MW-9A
MW-12C
MW-25A
MW-29B
MW-45A
STB-10
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MW-36A
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Page 21
Table 3
CHAIN OF CUSTODY FORM
Company/Location
Sample Location:
Collector's Name:
Sample Date:
Field Information: pH
Wastewater Soil
Conductance
Sludge
Temp.
Groundwater
Analysis Requested:
SWP Identification No.
Time
Relinquished by
Relinquished by
Method of Shipment:
4-
LAB ID #
Chain of Possession
Illl
Date/Time
Received By
Date/Time
Received By
Date/Time
Date/Time
Internal Temp, of Container:
Container sealed before shipment:
Container sealed upon receipt:
n-i-o oVil rmlna
On receiot
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Page 22
TABLE 4
GROUND-WATER QUALITY PARAMETERS AND ANALYTICAL METHODS
GROUND-WATER PARAMETERS ANALYTICAL METHOD
Arsenic EPA 206.2
Chromium EPA 218.2
Pentachlorophenol EPA 8040
Phenol EPA 8040
2-chlorophenol EPA 8040
p-chloro-m-cresol EPA 8040
2,4-dimethylphenol EPA 8040
2,4-dinitrophenol EPA 8040
2,4,6-trichlorophenol EPA 8040
Acenaphthene EPA 8100
Tetrachlorophenol EPA 8040
Phenanthrene + antracene EPA 8100
Chrysene + benz (a) anthracene EPA 8100
Benzo (b,k) fluoranthene EPA 8100
Indeno (1,2,3-cd) pyrene + benzo (a,h) anthracene EPA 8100
Naphthalene EPA 8100
Fluoranthene EPA 8100
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APPENDIX D
Compliance History
SOUTHERN WOOD PIEDMONT
Augusta, Georgia
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Compliance History
The following is a summary, in chronological order, of the correspondence,
reports, enforcement actions, etc. pertaining to the SWP Augusta facility.
This should not be interpreted as a complete record.
10/81 RCRA monitoring wells MWl through MW5 installed by Froehling
and Robertson for SWP.
1/5/82 First quarter sampling results for wells MW2 to MW5; lead and
arsenic exceed the NIPDWS for MW3.
1/8/82 EPD gives SWP waiver from analyzing gross alpha, gross beta and
radium
5/18/82 Second quarter sampling results for wells MW2 to MW5; lead and
arsenic exceed the NIPDWS for MW3.
5/21/82 EPD inspection performed at SWP.
8/12/82 Third quarter sampling results for wells MW2 to MW5.
10/4/82 Fourth quarter sampling results for wells MW2 to MW5.
6/6/83 Part B submitted for review to EPD.
10/31/83 EPD issues a NOD for Part B deficiencies; ground water monitoring
system does not meet the 265 Subpart F requirements.
11/16/83 SWP notifies EPD of statistically significant differences; differ-
ences are verified by resampling of wells.
11/30/83 Ground water quality assessment plan (GWQAP) submitted to EPD for
review.
2/8/84 EPD issues a NOV for a GWQAP that is not adequate to meet 265
regulations.
3/8/84 EPD consent agreement proposed.to revise GWQAP.
3/28/84 SWP submits proposed consent agreement to EPD.
5/2/84 SWP/EPD meet to discuss proposed consent agreement.
5/14/84 Revised GWQAP prepared by Law for SWP.
5/22/84 Revised GWQAP submitted to EPD.
7/24/84 SWP/EPD meet to discuss GWM; consent agreement not signed by SWP.
8/9/84 EPD letter to SWP: define uppermost aquifer and define ground
water flow direction, etc. Also tank certification is due 8/31/84.
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-D-2-
8/22/84 SWP/EPD meet to discuss the ground water monitoring system at the
site.
9/5/84 EPD makes recommendations on revised GWQAP.
9/7/84 SWP submits incomplete information on tank certification.
9/84-10/84 Well clusters MW6 to MW9 and Bl installed.
10/84 K001 detected in ground water samples.
11/2/84 First quarter sampling for wells 6C, 7C, 8B and 9B, and MW1
through MW5.
11/16/84 EPD issues a NOV - previously requested ground water monitoring
information is due 12/3/84.
12/84 K001 detected in ground water samples.
12/1/84 Second quarter sampling for wells 6C, 1C, 8B and 9B.
12/11/84 EPD inspection performed at SWP; ground water monitoring viola-
tions noted.
12/11/84 EPD samples Richmond County water supply well - No K001 constitu-
ents are detected.
1/85 K001 detected in the ground water; arsenic exceeds the NIPDWS.
1/3/85 Law Engineering submits the report "Additional Monitoring Well
Installation and Hydrogeological Assessment" for SWP.
1/9/85 EPD requests information on solid waste management units - this
information is due 3/15/85.
1/11/85 EPD issues an NOV based on the 12/11/84 EPD inspection; information
is due 2/8/85.
1/12/85 Third quarter sampling for wells 6C, 7C, 8B and 9B.
1/16/85 EPD drafts an Administrative Order for SWP to bring the facility
into compliance with the regulations.
1/21/85 SWP submits an incomplete tank certification.
1/23/85 SWP/EPD meet to discuss the ground water monitoring system.
1/25/85 Additional tank information due 2/15/85.
2/5/85 Ground water elevations measured for wells MW6 to MW9.
2/15/85 SWP submits additional ground water monitoring information.
3/10/85 Fourth quarter sampling for wells 6C, 7C, 8B and 9B.
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-D-3-
3/13/85 SWP requests approval to close wells MW1 through MW5.
3/15/85 SWP submits quarterly sampling results.
3/22/85 EPD issues a second NOV based on the 12/11/84 EPD inspection.
4/10/85 Quarterly sampling results for wells 6C, 7C, 8B and 9B.
4/25/85 Tank cannot be certified due to large cracks.
5/1/85 EPD samples neighborhood wells - K001 constituents detected.
5/2/85 Comments form EPA Site Screening and Identification Unit.
5/2/85 EPD samples the SWP 308-foot production well - K001 constituents
detected.
5/3/85 EPD proposes a consent order for 265/270 deficiencies.
5/7/85 EPD issues a NOD for Part B deficiencies.
5/8/85 Well MW6C is sampled for Appendix VIII constituents.
5/8/85 EPD reports on samples taken from neighborhood wells.
5/16/85 SWP responds to the 5/3/85 consent order.
5/23/85 SWP notifies EPD that well MW6C has been sampled for Appendix
VIII.
5/30/85 EPD samples more neighborhood wells - K001 constituents detected.
5/31/85 EPD samples the SWP 308-foot production well - K001 constituents
detected.
6/4/85 SWP submits information to EPD regarding solid waste management
units.
6/5/85 EPD issues Administrative Order EPD-HW-212 to bring the facility
into compliance.
6/5/85 Law Engineering submits a GWQAP update to SWP.
6/10/85 EPA issues a consent order to bring the facility into compliance.
6/10/85 SWP begins installing more monitoring wells for assessment purposes.
6/13/85 GWQAP revision prepared by Law Engineering for SWP.
6/17/85 EPD trip report for the May 1985 inspection.
6/21/85 SWP submits more ground water monitoring information.
6/24/85 SWP submits information on solid waste management units.
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-D-4-
6/27/85 SWP files a "Petition for Hearing" to challenge Administrative
Order EPD-HW-212.
7/3/85 SWP/EPD meet to discuss Administrative Order EPD-HW-212.
7/15/85 Closure plan submitted for the surface impoundment.
7/25-26/85 Samples for ground water sampling of all well clusters taken
by Law Environmental Services.
7/29/85 EPD files pleadings in connection with Administrative Order
EPD-HW-212.
7/31/85 EPD sends letters to neighborhood residents regarding the results
of sampling their private wells.
7/31/85 Law submits a "Compliance Monitoring Program Outline" for SWP.
8/2/85 SWP/EPD meet to discuss the Administrative Order.
8/9/85 Monitoring wells sampled by Law Environmental Services.
8/30/85 EPD requests information drilled by Virginia Supply and Well
Company, about a well drilled 20 to 25 years ago screened in
sand that yielded only creosote.
9/3/85 Ground water levels are measured in all monitoring wells.
9/15/85 ' Wells MW1 to MW5 abandoned.
9/17/85 SWP/EPD meet to discuss consent orders.
10/1/85 Part B revision is submitted.
10/85 A sampling and analysis plan for ground water monitoring during
closure is submitted.
10/25/85 Ground water levels are measured in the monitoring wells.
11/6/85 "Report of On-Going Ground Water Quality assessment" prepared
by Law Engineering for SWP.
12/10/85 EPD samples neighborhood wells - No K001 constituents detected;
EPD also samples surface water and sediment in the vicinity of SWP.
12/17/85 Consent Order EPD-HW-258 signed.
1/2/86 "Human Health and Environmental Assessment" report to submitted
EPD for review.
1/10/86 EPD Consent Order EPD-HW-257.
1/13/86 "Corrective Action - Segment I" prepared by Law Engineering
for SWP.
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-D-5-
3/4/86 SWP/EPD/EPA meet to discuss ground water monitoring.
3/17/86 "Corrective Action - Segment II" prepared by Law Engineering
for SWP.
3/18/86 ACL's submitted; prepared by Law Engineering for SWP.
4/7/86 The closure plan for the surface impoundment is submitted.
4/9/86 A revised closure plan is submitted to EPD.
5/14/86 EPD performs an inspection at SWP.
5/19/86 Interim Status - Corrective Action Evaluation submitted for
review.
5/20/86 EPA issues the Final Agreement and Final Order 85-29-R to SWP.
6/2/86 EPD in-house memo regarding the ground water assessment at SWP.
6/9/86 A proposal for closure is presented by Rollins (second revision)
7/3/86 EPD requests DHR to perform a Health Consultation for the area
around SWP.
7/16/86 The revised compliance monitoring program is submitted.
7/16/86 The Ground Water Quality Assessment Summary for closure is
submitted.
7/18/86 "Corrective Action - Segment II" prepared by Law Engineering
for SWP.
7/22/86 EPD samples two SWP monitoring wells for Appendix VIII analyses.
7/22/86 SWP submits a revised Part B permit application.
7/29/86 Consent Order EPD-HW-257 is amended and executed.
8/8/86 SWP/EPD/EPA meet to discuss ground water monitoring issues.
8/20/86 EPD samples neighborhood wells - K001 constituents detected.
8/26/86 EPD inspection performed at SWP.
10/14/86 EPD receives results from the Rocky Mountain Analytical Labora-
tory for two wells at SWP. The wells showed detectable con-
centrations of chlorinated volatile compounds.
10/27/86
EPD approves the closure plan for the surface impoundment at SWP.
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-D-6-
12/3/86 SWP begins installing additional monitoring wells for assessment
purposes.
1/26/87 HWGWTF performs an evaluation of the SWP ground water monitoring
system.
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